# SUPPORTING STATEMENT FOR

EPA INFORMATION COLLECTION REQUEST

NUMBER 1572.10

HAZARDOUS WASTE SPECIFIC UNIT REQUIREMENTS

AND

SPECIAL WASTE PROCESSES AND TYPES

APRIL 2013

# TABLE OF CONTENTS

Page

1. IDENTIFICATION OF THE IN FORMATION COLLECTION .......................................................... 4

1(a) TITLE AND NUMBER OF THE INFORMATION COLLECTION ...................................... 4

1(b) SHORT CHARACTERIZATION OF THE INFORMATION

COLLECTION .................................................................................................................... .... 4

2. NEED FOR AND USE OF THE COLLECTION ................................................................................ 4

2(a) NEED AND AUTHORITY FOR THE COLLECTION .......................................................... 4

2(b) PRACTICAL UTILITY AND USERS OF THE DATA .......................................................... 5

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION

CRITERIA ...................................................................................................................... ...................... 5

3(a) NONDUPLICATION ........................................................................................................... ... 5

3(b) PUBLIC NOTICE REQUIRED PRIOR TO ICR SUBMISSION TO OMB .......................... 5

3(c) CONSULTATIONS ............................................................................................................ ..... 5

3(d) EFFECTS OF LESS FREQUENT COLLECTION ................................................................. 5

3(e) GENERAL GUIDELINES ...................................................................................................... 5

3(f) CONFIDENTIALITY............ ...................................................... ....................... 6

3(g) SENSITIVE QUESTIONS ...................................................................................................... 6

4. THE RESPONDENTS AND THE INFORMATION REQUESTED ................................................... 6

4(a) RESPONDENTS/ NAICS CODES .......................................................................................... 6

4(b) INFORMATION REQUESTED .............................................................................................. 7

5. THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, COLLECTION

METHODOLOGY, AND INFORMATION MANAGEMENT ...................................................... 132

5(a) AGENCY ACTIVITIES ...................................................................................................... 1 32

5(b) COLLECTION METHODOLOGY AND MANAGEMENT ............................................. 139

5(c) SMALL ENTITY FLEXIBILITY ....................................................................................... 139

5(d) COLLECTION SCHEDULE............................................................................................... 140

6. ESTIMATING THE BURDEN AN D COST OF THE COLLECTION .......................................... 143

6(a) ESTIMATING RESPONDENT BURDEN ......................................................................... 143

6(b) ESTIMATING RESPONDENT COSTS ............................................................................. 143

# 6(c) ESTIMATING AGENCY BURDEN AND COST ............................................................. 144

6(d) ESTIMATING THE REPONDENT UNIVERSE AND TOTAL BURDEN

AND COST....................................................................................................................... ... 144

6(e) BOTTOM LINE BURDEN HOURS AND COSTS............................................................ 173

6(f) REASONS FOR CHANGE IN BURDEN .......................................................................... 173

6(g) BURDEN STATEMENT .................................................................................................... 173

EXHIBITS APPENDIX

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1. IDENTIFICATION OF TH E INFORMATION COLLECTION

1(a) TITLE AND NUMBER OF TH E INFORMATION COLLECTION

Hazardous Waste Specific Unit Requirements and Special Waste Processes and Types, EPA ICR

Number 1572.10

1(b) SHORT CHARACTERIZATION OF THE INFORMATION COLLECTION

Section 3004 of the Resource Conservation and Recovery Act (RCRA) of 1976, as amended,

requires that the U.S. Environmental Protection Agen cy develop standards for hazardous waste treatment,

storage, and disposal facilities (TSDFs), as may be necessary, to protect human health and the

environment. Section 3004, Subsections (1), (3), (4), (5), and (6) specify that these standards include, but

not be limited to, the following requirements:

(1) Maintaining records of all hazardous wastes identified or listed under this title which are

treated, stored, or disposed of, ... and the manner in which such wastes were treated,

stored, or disposed of;

(3) Treatment, storage, or disposal of all su ch waste received by the unit pursuant to such

operating methods, techniques, and practices as may be satisfactory to the Administrator;

(4) The location, design, and construction of such hazardous waste treatment, disposal, or

storage facilities;

(5) Contingency plans for effective action to minimize unanticipated damage from any

treatment, storage, or disposal of any such hazardous waste; and

(6) The maintenance or operation of such facilities and requiring such additional

qualifications as to ownership, continuity of operation, training for personnel, and

financial responsibility as may be necessary or desirable.

The regulations implementing these requirement s are published in the Code of Federal

Regulations (CFR) Title 40, Parts 261, 264, 265, and 266, Subpart F.

Section 4(b) of this ICR contains a more de tailed description of the information collection

requirements, including the data items and responde nt activities associated with each requirement.

2. NEED FOR AND USE OF THE COLLECTION

2(a) NEED AND AUTHORITY FOR THE COLLECTION

This subsection establishes the need and legal au thority for each information collection covered

in this ICR. All of the collection requirements cove red in this ICR have been published in 40 CFR Parts

261, 264 and 265, Subparts I through DD, and 40 CFR Part 266, Subpart F. With each collection covered

in this ICR, EPA is aiding the goal of complyi ng with its statutory manda te under RCRA to develop

standards for hazardous waste TSDFs, as may be necessary, to protect human health and the environment.

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Section 2(b) lists each information collection along with its regulatory citation, and provides precise

information regarding the decisions EPA makes with the information provided by the respondents.

2(b) PRACTICAL UTILITY AND USERS OF THE DATA

The information in this section is used for the following:

- Monitor compliance

- Assure hazardous waste is handled properly

- Assure human health and the environment is protected

3. NONDUPLICATION, CONSULTATION S, AND OTHER COLLECTION CRITERIA

3(a) NONDUPLICATION

The information collections covered in this I CR are not available from sources other than the

respondents. EPA’s Office of Solid Waste (and authorized States in lieu of EPA) is the only Office within

the Agency collecting this information, and no ot her Federal agency or department collects this

information. In addition, the Office of Solid Wast e in partnership with the States has systematically

reorganized its information collection stru cture to eliminate gaps or duplication.

3(b) PUBLIC NOTICE REQUIRED PRIOR TO ICR SUBMISSION TO OMB

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

26, 2010 (75 FR 65625). The public comment period extended through December 27, 2010. EPA

received one public comment that was not applicable to this ICR during the public comment period.

3(c) CONSULTATIONS

The activities and factors for estimating the burden hours and cost estimates for this ICR are well

established. EPA consulted with members of the regulated community that are respondents for the

information collection request. Consultations were conducted with: Kevin Sheehan, Chemical Waste

Management, (716) 754-8231. Richard Devine, Divers ified Scientific Services, Inc. (865) 376-0084

3(d) EFFECTS OF LESS FREQUENT COLLECTION

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

unit and by special waste processes and types regulati ons. Consequently, EPA is confident that those

activities required of all respondents are necessary, an d to the extent possible, has minimized the burden

imposed. EPA believes strongly that if the minimum requirements specified under the regulations are not

met, EPA will be unable to fulfill its Congressional ma ndate to protect public health and the environment.

3(e) GENERAL GUIDELINES

This ICR adheres to the guidelines stated in the 1995 Paperwork Reduction Act, OMB’s

implementing regulations, EPA’s Information Collec tion Review Handbook, and other applicable OMB

guidance.

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3(f) CONFIDENTIALITY

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

the public disclosure of information, contain provisi ons for confidentiality. EPA also ensures that the

information collection procedures comply with the Privacy Act of 1974 and the OMB Circular 108. EPA

does not anticipate requesting an y confidential information.

3(g) SENSITIVE QUESTIONS

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

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) RESPONDENTS UNIVERSE AND NAICS CODES

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

associated with the respondents most likely to be affected by the information collection requirements

detailed in this ICR.

211112 Natural Gas Liquid Extraction

221111 Hydroelectric Power Generation

221112 Fossil Fuel Electric Power Generation

221113 Nuclear Electric Power Generation

221119 Other Electric Power Generation

221121 Electric Bulk Power Transmission and Control

221122 Electric Power Distribution

22132 Sewage Treatment Facilities

311942 Spice and Extract Manufacturing

323110 Commercial Litographic Printing

323114 Quick Printing

32411 Petroleum Refineries

32511 Petrochemical Manufacturing

32512 Industrial Gas Manufacturing

325131 Inorganic Dye and Pigment Manufacturing

325188 All Other Basic Inorganic Chemical Manufacturing

325193 Ethyl Alcohol Manufacturing

325199 All Other Basic Organic Chemical Manufacturing

325211 Plastics Material and Resin Manufacturing

32551 Paint and Coating Manufacturing

325998 All Other Miscellaneous Chemical Product and Preparation Manufacturing

331311 Alumina Refining

33271 Machine Shops

332813 Electroplating, Plating, Polishing, Anodizing, and Coloring

332999 All Other Miscellaneous Fabr icated Metal Product Manufacturing

333319 Other Commercial and Service Industry Machinery Manufacturing

333999 All Other Miscella neous General Purpose Machinery Manufacturing

33422 Radio and Television Broadcasting and Wireless Communications Equipment

Manufacturing

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33431 Audio and Video Equipment Manufacturing

334418 Printed Circuit Assembly (Electronic Assembly) Manufacturing

334419 Other Electronic Component Manufacturing

336211 Motor Vehicle Body Manufacturing

336312 Gasoline Engine and Engine Parts Manufacturing

336322 Other Motor Vehicle Electrical and Electronic Equipment Manufacturing

33633 Motor Vehicle Steering and Suspension Components (except Spring) Manufacturing

33634 Motor Vehicle Brake System Manufacturing

33635 Motor Vehicle Transmission and Power Train Parts Manufacturing

336399 All Other Motor Vehicle Parts Manufacturing

42271 Petroleum Bulk Stations and Terminals

44111 New Car Dealers

44711 Gasoline Stations with Convenience Store

44719 Other Gasoline Stations

454311 Heating Oil Dealers

454312 Liquefied Petroleum Gas (Bottled Gas) Dealers

48411 General Freight Trucking, Local

48421 Used Household and Office Goods Moving

48422 Specialized Freight (except Used Goods) Trucking, Local

562111 Solid Waste Collection

562112 Hazardous Waste Collection

562119 Other Waste Collection

562211 Hazardous Waste Treatment and Disposal

562212 Solid Waste Landfill

562213 Solid Waste Combustors and Incinerators

562219 Other Non-hazardous Waste Treatment and Disposal

56292 Materials Recovery Facilities

811111 General Automotive Repair

4(b) INFORMATION REQUESTED

The following subsection presents the data items and respondent activities required for each of

the broad information collection areas introduced in the previous section.

CONTAINERS

Interim status facilities:

Regulations

Each owner/operator regulated under 40 CFR Part 265, Subpart I is expected to read the

regulations.

Inspections

40 CFR 265.174 requires owners and operators of in terim status containers to conduct inspections

of the areas where the containers are stored. Data items and respondent activities associated with these

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requirements are covered in this ICR. However, the burden for recordkeeping the applicable data items is

covered in the “General Hazardous Waste Facility Standards ICR” (EPA ICR Number 1571).

(i) Data item:

The data item required to comply with these requirements includes:

• Documentation pertaining to the weekly in spection of the areas where the containers are

stored. During each inspection, owners and operators must look for leaks and for

deterioration caused by corrosion or other factors.

(ii) Respondent activity:

Respondents must perform the following activity in documenting in the operating record of the

facility the inspection of the area where the containers are stored:

• Record all inspection data.

Air emission standards

40 CFR 265.178 requires owners a nd operators of interim stat us facilities to manage all

hazardous waste placed in a containe r in accordance with the applicab le requirements of Subparts AA,

BB, and CC. All data items and respondent activ ities under Subparts AA and BB, as applicable to

containers, are covered later in this ICR under pro cess vents and equipment leaks, respectively. Data

items and respondent activities under Subpart CC, as a pplicable to containers, are covered in the

Supporting Statement for EPA ICR Number 1593: “Sta ndards of Performance for Air Emission Standards

for Tanks, Surface Improvements and Containers, 40 CFR Part 264, Subpart CC and 40 CFR Part 265,

Subpart CC.”

Permitted facilities:

Regulations

Each owner/operator regulated under 40 CFR Part 264, Subpart I is expected to read the

regulations.

Inspections

40 CFR 264.174 requires owners and operators of permitted containers to conduct inspections of

the areas where the containers are stored. Data items and respondent activiti es associated with these

requirements are covered in this ICR. However, the burden for recordkeeping the applicable data items is

covered in the “General Hazardous Waste Facility Standards ICR” (EPA ICR Number 1571).

(i) Data item:

The data item required to comply with these requirements includes:

• Documentation pertaining to the weekly in spection of the areas where the containers are

stored. During each inspection, owners and operators must look for leaks and for

deterioration caused by corrosion or other factors.

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(ii) Respondent activity: Respondents must perform the following activity in

documenting to the operating record of the facility th e inspection of the area where the containers are

stored:

• Record all inspection data.

Air emission standards

40 CFR 264.179 requires owners a nd operators of interim stat us facilities to manage all

hazardous waste placed in a containe r in accordance with the applicab le requirements of subparts AA,

BB, and CC. All data items and respondent activ ities under Subparts AA and BB, as applicable to

containers, are covered later in this ICR under pro cess vents and equipment leaks, respectively. Data

items and respondent activities under Subpart CC, as a pplicable to containers, are covered in the

Supporting Statement for EPA ICR Number 1593: “Sta ndards of Performance for Air Emission Standards

for Tanks, Surface Improvements and Containers, 40 CFR Part 264, Subpart CC and 40 CFR Part 265,

Subpart CC.”

TANK SYSTEMS

Interim status facilities:

Regulations

Each owner/operator regulated under 40 CFR Part 265, Subpart J is expected to read the

regulations.

No-free-liquids demonstration

40 CFR 265.190(a) releases tank system owner/operators from the requirements of §265.193

(containment and detection of releases) provided that the tanks are located in buildings with impermeable

floors and are used to store or treat wastes that contain no free liquids. Owner/operators must

demonstrate the absence of free liquids by using EPA Method 9095 (Paint Filter Liquids Test) as

described in “Test Methods for Evaluating Solid W astes, Physical/Chemical Methods” (EPA Publication

No. SW-846) in order to be exempt from these requirements.

(i) Data item:

The data item required to comply with this requirement includes:

• Results of the Paint Filter Liquids Test, performed as specified in SW-846.

(ii) Respondent activities:

Respondents must perform the following activ ities in performing this demonstration:

• Perform Paint Filter Liquids Test as required; and

• File test results at the facility.

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Assessment of existing tank systems’ integrity

Under 40 CFR 265.191 owner/operato rs of facilities with tank systems that (1) store or treat

waste that becomes hazardous after July 14, 198 6 and (2) do not meet the secondary containment

requirements of 40 CFR 265.193 must determine that the tank systems are sufficient for storing or

treating hazardous waste.

(i) Data item:

The data item required to comply with this requirement includes:

• For each tank system, a written assessment that has been reviewed and certified by an

independent, qualified registered professi onal engineer in accordance with 40 CFR

270.11(d). At a minimum, the assess ment must consider the following:

-- The design standards to which the tank and ancillary equipment were

constructed;

-- Hazardous characteristics of the wast e(s) that has been and will be handled;

-- Existing corrosion protection measures;

-- The tank’s documented or estimated age; and

-- Results of a leak test performed as specified in 40 CFR 265.191(b)(5)(i) and (ii).

(ii) Respondent activities:

Respondents must perform the following activities in assessing their tank systems:

• Perform the leak test as specified in 40 CFR 265.191(b)(5)(i) and (ii);

• Write or have written an assessment certifie d by an independent, qualified, registered

professional engineer that attests to the tank system’s integrity; and

• File the assessment at the facility.

Design and installation of new tank systems or components

40 CFR 265.192 requires owner/opera tors of new tank systems or components to obtain a written

assessment attesting that the tank system is accepta ble for storing and treating hazardous waste. In

addition, owner/operators must obtain and keep on file at the unit statements written by those who

designed the tank system and supervised its constructi on. These statements will verify that the system

was designed and constructed properly.

(i) Data items:

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Data items required to comply with these requirements include:

• For each new tank system, a written assessment that has been reviewed and certified by

an independent, qualified, registered professional engineer in accordance with 40 CFR

270.11(d). At a minimum, the assessment must report on the following:

-- The design standards to which the tank and ancillary equipment were

constructed;

-- Hazardous characteristics of the waste(s) to be handled;

-- For new systems or components in which any external metal component of the

tank system will be in contact with soil or water, a determination by a corrosion

expert of the factors affecting the potential for and protection from corrosion as

specified in 40 CFR 265.192(a)(3)(i) and (ii);

-- For underground tank systems likely to be adversely affected by vehicular traffic,

the design or operational measures that will protect the tank system from

damage; and

-- Design considerations to ensure that: (1) tank foundations will maintain the load

of a full tank, (2) the systems will not floa t or dislodge when placed in a saturated

or seismic fault zone, and (3) the systems will withstand the effects of frost

heave.

• Maintain records of statements written by those who certify the tank system’s design and

supervise its installation (§265.192(g)). These records must verify that the system was

designed and installed according to the regul atory requirements, and that any needed

repairs were performed. They must also include the certification statement as required in

40 CFR 270.11(d).

(ii) Respondent activities:

Respondents must perform the following activ ities in complying with these requirements:

• Prepare the written assessment and have it reviewed and certified;

• Obtain written statements from those who certified the design of the tank system and

supervised its installation; and

• Maintain the written statements at the facility.

Containment and detection requirements

40 CFR 265.193 requires tank systems to have secondary containment that will prevent the

release of hazardous constituents into the environm ent. New tank systems must have the containment

installed prior to their being put into service. Th e dates by which containment must be installed on

existing tank systems depend upon the waste types handled, the system’s age, and other factors. The

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information collection requirements in this section in clude reports to the Regional Administrator that will

exempt, when appropriate, tank syst em owner/operators from specific sec ondary containment standards.

In addition, 40 CFR 265.193(g) allows owner/ope rators to obtain a variance from all secondary

containment requirements if they can demonstrate to the Regional Administrator that alternative design

and operating practices, together with location charact eristics, will be as protective of the environment as

secondary containment.

Equivalent containment devices

40 CFR 265.193(d) requires all secondary containment for tank systems to include one or more of

the following devices: a liner; a vault; a double-walled tank; or an equivalent device, as approved by the

Regional Administrator. The regulations do not specify the means by which respondents will obtain

approval of their equivalent containment devices. Though some respondents may choose to use a

previously-approved containment device, this I CR assumes that owner/operators will submit to the

Regional Administrator written information regarding the design and type of device, as well as additional

information that may be necessary to substantiate a clai m that the device is equivalent to a liner, vault, or

double-walled tank.

(i) Data item:

The data item required to comply with this requirement includes:

• Written information regarding the design and type of containment device as well as

additional information that may be necessary to substantiate a claim that the device is

equivalent to a liner, vault, or double-walled tank.

(ii) Respondent activities:

Respondents must perform the following activities in obtaining approval for their equivalent

containment device:

• Gather information regarding the design and type of containment device as well as

additional information necessary to substantiate a claim that the device is equivalent to a

liner, vault, or double-walled tank; and

• Submit the information to the Regional Administrator.

Exemption from 24-hour leak detection requirement

40 CFR 265.193(e)(3)(iii) requires secondary contai nment systems to have a leak detection

system that will detect a release within 24 hours. If owner/operators can demonstrate that existing

technologies or site conditions will not allow detection within 24 hours, they may use a leak detection

system that will detect failure or contamination “at the earliest practicable time.”

(i) Data item:

The data item required to comply with this requirement includes:

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• Any such evidence regarding existing technologi es or site conditions sufficient to show

that the leak detection system cannot detect failure or contamination within 24 hours.

(ii) Respondent activities:

Respondents must perform the following activities in obtaining an exemption from the 24 hour

detection requirement:

• Compile evidence showing that the leak detection system cannot detect failure or

contamination within 24 hours; and

• Submit the evidence to the Regional Administrator.

Variance from secondary containment requirements

40 CFR 265.193(g) allows owner/operators to obt ain a variance from all secondary containment

requirements if they can demonstrate to the Regi onal Administrator that (1) alternative design and

operating practices, together with location character istics, will prevent the migration of hazardous

constituents into the ground water or surface water as effectively as secondary containment or (2) if a

release does migrate to ground or surface water, that the release will pose no

substantial hazard.

(i) Data item:

The data item required to comply with this requirement includes:

• A written notification to the Regional Admini strator indicating intent to conduct and

submit a demonstration for a variance from s econdary containment. This notification

must contain:

-- A description of the steps necessary to conduct the demonstration (which must

address each factor listed in 40 CFR 265.193(g)(1) and (2)); and

-- A timetable for completing each step.

(ii) Respondent activities:

Respondents must perform the following activ ities in obtaining a variance from secondary

containment:

• Prepare and submit, to the Regional Administra tor, the notification of intent to conduct a

demonstration (for existing tank systems, notif ication must be submitted 24 months prior

to the date at which secondary containment must be provided; for new systems,

notification must be submitted at least 30 days before entering into a contract to install

the system);

• Complete the demonstration in accordan ce with 40 CFR 265.193(g)(1) and (2); and

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• Submit the completed demonstration to the Regional Administrator within 180 days of

submitting the notification.

Annual leak tests and inspections

40 CFR 265.193(i) requires owner/operators, un til they meet the secondary containment

requirements, to conduct annual leak tests and/or in spections of their tanks a nd ancillary equipment.

Records of these assessments must be kept on file at the facility. Data items and respondent activities

associated with these requirements are covered in this ICR. However, the burden for recordkeeping the

applicable data items is covered in the “General Hazardous Waste Facility Standards ICR” (EPA ICR

Number 1571).

(i) Data item:

The data item required for these recordkeeping requirements is:

• A record of the results of the leak t ests and/or inspections required under 40 CFR

265.193(i).

(ii) Respondent activities:

Respondents must perform the following activities in filing a record of the assessment results:

• For non-enterable underground tanks, conduct a leak test that meets the requirements of

40 CFR 265.191(b)(5);

• For all other tanks and for ancillary equipment, conduct an annual leak test that meets the

requirements in 40 CFR 265.191(b)(5) or have the tanks and equipment inspected as

described in 40 CFR 265.193(i)(2); and

• Record the inspection and/or test results.

Inspections

40 CFR 265.195 requires owners and operators of interim status tank systems to conduct

inspections of their units. Data items and responde nt activities associated w ith these requirements are

covered in this ICR. However, the burden for record keeping the applicable data items is covered in the

“General Hazardous Waste Facility Standards ICR” (EPA ICR Number 1571).

(i) Data items:

The data items required to comply with these requirements include:

 Documentation pertaining to the daily in spection, where present, of the following

components of the tank system:

-- Overfill/spill control equipment (e.g., w aste-feed cutoff systems, bypass systems,

and drainage systems) to ensure that it is in good working order;

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-- The aboveground portions of the tank system, if any, to detect corrosion or

release of waste;

-- Data gathered from monitoring equi pment and leak-detection equipment (e.g.,

pressure and temperature gauges, monitoring wells) to ensure that the tank

system is being operated according to its design; and

-- The construction materials and the ar ea immediately surrounding the externally

accessible portion of the tank system including secondary containment structures

(e.g., dikes) to detect erosion or signs of releases of hazardous waste (e.g., wet

spots, dead vegetation).

 Documentation pertaining to the inspection of cathodic protection systems, if present,

according to, at a minimum, the following sch edule to ensure that they are functioning

properly:

-- The proper operation of the cathodic protection system must be confirmed within

six months after initial installation, and annually thereafter; and

-- All sources of impressed current must be inspected and/or tested, as appropriate,

at least bimonthly (i.e., every other month).

(ii) Respondent activity:

Respondents must perform the following activity in documenting in the operating record of the

facility the inspection of the tank systems:

 Record all inspection data.

Responses to leaks or spills; disposition of leaking or unfit-for-use tank systems

Exemption from the 24-hour waste removal requirement

40 CFR 265.196 requires a tank syst em or secondary containment system from which there has

been a spill to be removed from service immediat ely. Paragraph (b) of that section requires

owner/operators, within 24 hours, to remove enough waste from the system to prevent further release and

allow for inspection and repair of the tank. If the ow ner/operator can demonstrate that it is not possible to

do so within 24 hours, the waste may be removed at the earliest practicable time.

(i) Data item:

The data item required for this demonstration includes:

• Any such evidence sufficient to show that , within 24 hours, the owner/operator cannot

remove enough waste from the system to prev ent further release and allow for system

inspection and repair.

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(ii) Respondent activities:

Respondents must perform the following ac tivities in making this demonstration:

• Compile evidence showing that, within 24 hours, enough waste cannot be removed from

the system to prevent further release and allow for system inspection and repair; and

• Submit the evidence to the Regional Administrator.

Release notifications and reports ; major repair certifications

40 CFR 265.196(d) requires facilities to comply w ith certain reporting requirements in the case of

a leak or spill. Owner/operators must notify the Regi onal Administrator of any release to the environment

(except as defined in 40 CFR 265.196(d)(2)) within 24 hours of detection, 1 

# and submit a detailed report

within 30 days. In addition, where the leak or spill is caused by major system damage, 40 CFR

265.196(f) requires that owner/operators submit to th e Regional Administrator a certification of major

repairs. This documents that the system has been repaired and is capable of handling hazardous waste

without release, and must be submitted to the Region al Administrator within 7 days of returning the

system to use.

(i) Data items:

Data items required for release no tifications and reports include:

• A notification to the Regional Admini strator that there has been a release;

• A report to the Regional Administrator containing the following information:

-- The release’s likely migration route;

-- The surrounding soil characteristics;

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

release (if not available within 30 days, results must be submitted as soon as

practicable);

-- The release’s proximity to down gradient drinking water, surface water, and

population areas; and

-- A description of the response actions taken or planned.

Data items required for a certifi cation of major repairs include:

1 

# If the release has been reported pursuant to 40 CFR Part 302 (CERCLA §103), that report will satisfy this

requirement.

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• A certification by an independent, qualifie d, registered professional engineer in

accordance with 40 CFR 270.11(d) that the re paired system is capable of handling

hazardous wastes without release for the intended life of the system.

(ii) Respondent activities:

Respondents must perform the following ac tivities in preparing and submitting release

notifications and reports:

• Within 24 hours of detection, notify the Regional Administrator that there has been a

release; and

• Within 30 days of detection, prepare a de tailed report for submission to the Regional

Administrator. In order to do so, owner/operators must:

-- Determine the release’s likely migration route;

-- Provide information on the surrounding soil characteristics;

-- Conduct appropriate monitoring or sampling;

-- Determine the release’s proximity to down gradient drinking water, surface

water, and population areas;

-- Describe the response actions taken or planned; and

-- Compile and submit the report to the Regional Administrator.

Respondents must perform the following activities in preparing and submitting a certification of

major repairs:

• Obtain a certification in accordance with 40 CFR 270.11(d); and

• Within 7 days of returning the system to use, submit the certification to the Regional

Administrator.

Closure and post-closure care

Decontamination demonstration

40 CFR 265.197 regulates tank system closure and po st-closure care. Paragraph (a) stipulates

that the closure plan, closure activities, cost estim ates for closure, and financial responsibility for tank

systems must meet all of the requirements of 40 CFR Subparts G and H. Tank systems will be required to

submit a decontamination of soils demonstrati on under §264.197(b) and §265.197(b). All other

information collection requirements for tank system closure and post-closure care are contained in EPA

ICR Number 1571, “General Hazardous Waste Facility Standards.”

(i) Data items:

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No specific data items are to be included in this demonstration.

(ii) Respondent activities:

Respondents must perform the following activ ities in performing this demonstration:

• Prepare decontamination demonstration; and

• Submit demonstration to EPA.

Waste analysis and trial tests

40 CFR 265.200 requires interim status tank system ow ner/operators to gather waste analysis data

(in addition to that required in §265.13) when a ta nk system is used to treat chemically or store a

hazardous waste that is substantially different from wast e previously treated or stored in that tank system;

or treat chemically a hazardous waste with a substan tially different process than any previously used in

that tank system. Data items and respondent activiti es associated with these re quirements are covered in

this ICR. However, the burden for recordkeeping the applicable data items is covered in the “General

Hazardous Waste Facility Standards ICR” (EPA ICR Number 1571).

(i) Data item:

The data item required to comply with this requirement includes:

 Documentation pertaining to waste analyses and trial treatment or storage tests (e.g.,

bench-scale or pilot-plant scale tests);

OR

 Documentation on similar waste under simila r operating conditions to show that the

proposed treatment or storage will meet the requirements of §265.194(a).

(ii) Respondent activities:

Respondents must perform the following activ ities in performing this demonstration:

• Conduct the waste analyses and trial tests; and

 Obtain written, documented information to show that the proposed treatment or storage

will meet the requirements of §265.194(a).

Air emission standards

40 CFR 265.202 requires owners a nd operators of interim stat us facilities to manage all

hazardous waste placed in a tank in accordance with the applicable requirements of 40 CFR part 265,

Subparts AA, BB, and CC. All data items and respondent activities under Subparts AA and BB, as

applicable to tanks, are covered later in this ICR under process vents and equipment leaks, respectively.

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Data items and respondent activities under Subpart CC, as applicable to tanks, are covered in the

Supporting Statement for EPA ICR Number 1593: “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.”

Permitted facilities:

Regulations

Each owner/operator regulated under 40 CFR Part 264, Subpart J is expected to read the

regulations.

No-free-liquids demonstration

40 CFR 264.190(a) releases tank system owner/operators from the requirements of §§ 264.193

(containment and detection of releases) provided that the tanks are located in buildings with impermeable

floors and are used to store or treat wastes that contain no free liquids. Owner/operators must

demonstrate the absence of free liquids by using EPA Method 9095 (Paint Filter Liquids Test) as

described in “Test Methods for Evaluating Solid W astes, Physical/Chemical Methods” (EPA Publication

No. SW-846) in order to be exempt from these requirements.

(i) Data item:

The data item for demonstrating the absence of free liquids includes:

• Results of the Paint Filter Liquids Test, performed as specified in SW-846.

(ii) Respondent activities:

Respondents must perform the following activ ities in performing this demonstration:

• Perform the Paint Filter Liquids Test as required; and

• File test results at the facility.

Assessment of existing tank systems’ integrity

Under 40 CFR 264.191 owner/operato rs of facilities with tank systems that (1) store or treat

waste that becomes hazardous after July 14, 198 6 and (2) do not meet the secondary containment

requirements of 40 CFR 264.193 must determine that the tank systems are sufficient for storing or

treating hazardous waste.

(i) Data items:

Data items for this determination include:

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• For each tank system, a written assessment that has been reviewed and certified by an

independent, qualified registered professi onal engineer in accordance with 40 CFR

270.11(d). At a minimum, the assess ment must consider the following:

-- The design standards to which the tank and ancillary equipment were

constructed;

-- Hazardous characteristics of the wast e(s) that has been and will be handled;

-- Existing corrosion protection measures;

-- The tank’s documented or estimated age; and

-- Results of a leak test performed as specified in 40 CFR 264.191(b)(5)(i) and (ii).

(ii) Respondent activities:

Respondents must perform the following activities in assessing their tank systems:

• Perform the leak test as specified in 40 CFR 264.191(b)(5)(i) and (ii);

• Write or have written an assessment certifie d by an independent, qualified, registered

professional engineer that attests to the tank system’s integrity; and

• File the assessment at the unit.

Design and installation of new tank systems or components

40 CFR 264.192 requires owner/opera tors of new tank systems or components to obtain a written

assessment attesting that the tank system is acceptabl e for storing and treating hazardous waste. Since

permitted facilities submit this assessment with their pa rt B permit application, activities associated with

obtaining and submitting a written assessment are cove red in the “Part B Permit Application, Permit

Modification, and Special Permits ICR” (EPA ICR Number 1573).

40 CFR 264.192(g) requires owner/operators to obt ain and keep on file at the unit statements

written by those who designed the tank system and supervised its construction. These

statements will verify that the system was designed and constructed properly.

(i) Data item:

The data item for this requirement includes:

• Maintaining records of statements written by those who certify the tank system’s design

and supervise its installation. These must verify that the system was designed and

installed according to the regulatory requirem ents, and that any needed repairs were

performed. They must also include the certification statement as required in 40 CFR

270.11(d).

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(ii) Respondent activities:

Respondents must perform the following activ ities in complying with these requirements:

• Obtain written statements from those who certified the design of the tank system and

supervised its installation; and

• Maintain the written statements at the unit.

Containment and detection requirements

Equivalent containment device

40 CFR 264.193(d) requires all secondary containment for tank systems to include one or

more of the following devices: a liner; a vault; a double-walled tank; or an equivalent device, as

approved by the Regional Administrator. The regul ations do not specify the means by which respondents

will obtain approval of their equivalent containmen t devices. Though some respondents may choose to

use a previously-approved containment device, this ICR assumes that owner/operators will submit to the

Regional Administrator written information regarding the design and type of device, as well as additional

information that may be necessary to substantiate a clai m that the device is equivalent to a liner, vault, or

double-walled tank. Since permitted facilities subm it an applications for obtaining equivalent

containment device approval with their part B permit a pplication, data items and activities associated with

preparing and submitting this information are cove red in the Part B Permit Application, Permit

Modification, and Special Permits ICR” (EPA ICR Number 1573).

Exemption from 24-hour leak detection requirements

40 CFR 264.193(e)(3)(iii) requires secondary contai nment systems to have a leak detection

system that will detect a release within 24 hours. If owner/operators can demonstrate that existing

technologies or site conditions will not allow detection within 24 hours, they may use a leak detection

system that will detect failure or contamination “at the earliest practicable time.” Since permitted

facilities submit applications for exemption from 24-hour leak detection requirements with their part B

permit application, data items and activities associated with preparing and subm itting this information are

covered in the “Part B Permit Application, Permit Modification, and Special Permits ICR” (EPA ICR

Number 1573).

Variance from secondary containment requirements

40 CFR 264.193(g) allows owner/operators to obt ain a variance from all secondary containment

requirements if they can demonstrate to the Regi onal Administrator that (1) alternative design and

operating practices, together with location charact eristics, will prevent the migration of hazardous

constituents into the ground water or surface water as effectively as secondary containment or (2) if a

release does migrate to ground or surface water, that the release will pose no substantial hazard. Since

permitted facilities submit an applications for vari ances from secondary containment requirements with

their part B permit application, data items and ac tivities associated with preparing and submitting this

information are covered in the “Part B Permit App lication, Permit Modification, and Special Permits

ICR” (EPA ICR Number 1573).

Annual leak tests and inspections

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40 CFR 264.193(i) requires owner/operators, un til they meet the secondary containment

requirements, to conduct annual leak tests on the tank system and ancillary equipment and/or develop a

schedule and procedures for assessing their tanks. Record s of the tests and assessments must be kept on

file at the facility. Data items and respondent activ ities associated with these re quirements are covered in

this ICR. However, the burden for recordkeeping the applicable data items is covered in “General

Hazardous Waste Facility Standards ICR” (EPA ICR Number 1571).

(i) Data item:

The data item required for these recordkeeping requirements is:

• A record of the results of the leak t ests and/or inspections required under 40 CFR

264.193(i).

(ii) Respondent activities:

Respondents must perform the following activities in filing a record of the assessment results:

• For non-enterable underground tanks, conduct a leak test that meets the requirements of

40 CFR 264.191(b)(5), or other method approved or required by the Regional

Administrator;

• For all other tanks and ancillary equipmen t, conduct the annual leak test (above) or

develop a schedule and procedure, in accordance with 40 CFR 264.193(i)(2), for

assessing the overall condition of the tank system. This assessment must be performed

by an independent, qualified, re gistered professional engineer; and

• Record all inspection and/or test results.

Inspections

40 CFR 264.195 requires owners and operators of in terim tank systems to conduct inspections of

their units. Data collected during these inspections mu st be documented in the operating record of the

facility. Data items and respondent activities associated with these requirements are covered in this ICR.

However, the burden for recordkeeping the applicable data items is covered in “General Hazardous Waste

Facility Standards ICR” (EPA ICR Number 1571).

(i) Data items:

The data items required to comply with these requirements include:

 Documentation pertaining to the inspection of overfill controls (i.e., schedule,

procedures, and data collected during inspections).

 Documentation pertaining to the daily inspection of the following components of the tank

system:

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-- The aboveground portions of the tank system, if any, to detect corrosion or

release of waste;

-- Data gathered from monitoring equi pment and leak-detection equipment (e.g.,

pressure and temperature gauges, monitoring wells) to ensure that the tank

system is being operated according to its design; and

-- The construction materials and the ar ea immediately surrounding the externally

accessible portion of the tank system including secondary containment structures

(e.g., dikes) to detect erosion or signs of releases of hazardous waste (e.g., wet

spots, dead vegetation).

 Documentation pertaining to the inspection of cathodic protection systems, if present,

according to, at a minimum, the following sch edule to ensure that they are functioning

properly:

-- The proper operation of the cathodic protection system must be confirmed within

six months after initial installation, and annually thereafter; and

-- All sources of impressed current must be inspected and/or tested, as appropriate,

at least bimonthly (i.e., every other month).

(ii) Respondent activity:

Respondents must perform the following activity in documenting in the operating record of the

facility the inspection of the tank systems:

 Record all inspection data.

Responses to leaks or spills; disposition of leaking or unfit-for-use tank systems

Exemption from the 24-hour waste removal requirement

40 CFR 264.196 requires a tank syst em or secondary containment system from which there has

been a spill to be removed from service immediat ely. Paragraph (b) of that section requires

owner/operators, within 24 hours, to remove enough waste from the system to prevent further release and

allow for inspection and repair of the tank. If the ow ner/operator can demonstrate that it is not possible to

do so within 24 hours, the waste may be removed at the earliest practicable time.

(i) Data item:

The data item required for this demonstration includes:

• Any such evidence sufficient to show that , within 24 hours, the owner/operator cannot

remove enough waste from the system to prev ent further release and allow for system

inspection and repair.

(ii) Respondent activities:

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Respondents must perform the following ac tivities in making this demonstration:

• Compile evidence showing that, within 24 hours, enough waste cannot be removed from

the system to prevent further release and allow for system inspection and repair; and

• Submit the evidence to the Regional Administrator.

Release notifications and reports ; major repair certifications

40 CFR 264.196(d) requires facilities to comply w ith certain reporting requirements in the case of

a leak or spill. Owner/operators must notify the Regi onal Administrator of any release to the environment

(except as defined in 40 CFR 264.196(d)(2)) within 24 hours of detection, 2 

# and submit a detailed report

within 30 days. In addition, where the leak or spill is caused by major system damage, 40 CFR

264.196(f) requires that owner/operators submit to th e Regional Administrator a certification of major

repairs. This documents that the system has been repaired and is capable of handling hazardous waste

without release, and must be submitted to the Region al Administrator within 7 days of returning the

system to use.

(i) Data items:

Data items required for release no tifications and reports include:

• A notification to the Regional Admini strator that there has been a release;

• A report to the Regional Administrator containing the following information:

-- The release’s likely migration route;

-- The surrounding soil characteristics;

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

release (if not available within 30 days, results must be submitted as soon as

practicable);

-- The release’s proximity to down gradient drinking water, surface water, and

population areas; and

-- A description of the response actions taken or planned.

Data items required for a certifi cation of major repairs include:

• A certification by an independent, qualifie d, registered professional engineer in

accordance with 40 CFR 270.11(d) that the re paired system is capable of handling

hazardous wastes without release for the intended life of the system.

2 

# If the release has been reported pursuant to 40 CFR Part 302 (CERCLA §103), that report will satisfy this

requirement.

# 25

(ii) Respondent activities:

Respondents must perform the following ac tivities in preparing and submitting release

notifications and reports:

• Within 24 hours of detection, notify the Regional Administrator that there has been a

release;

• Within 30 days of detection, prepare a de tailed report for submission to the Regional

Administrator. In order to do so, owner/operators must:

-- Determine the release’s likely migration route;

-- Provide information on the surrounding soil characteristics;

-- Conduct appropriate monitoring or sampling;

-- Determine the release’s proximity to down gradient drinking water, surface

water, and population areas;

-- Describe the response actions taken or planned; and

-- Compile and submit the report to the Regional Administrator.

Respondents must perform the following activities in preparing and submitting a certification of

major repairs:

• Obtain a certification in accordance with 40 CFR 270.11(d); and

• Within 7 days of returning the system to use, submit the certification to the Regional

Administrator.

Closure and post-closure care

Decontamination demonstration

40 CFR 264.197 regulates tank system closure and po st-closure care. Paragraph (a) stipulates

that the closure plan, closure activities, cost estim ates for closure, and financial responsibility for tank

systems must meet all of the requirements of 40 CFR Part 264, Subparts G and H. Tank systems will be

required to submit a decontamination of soils dem onstration under §264.197(b) and §265.197(b). All

other information collection requirements for tank syst em closure and post-closure care are contained in

ICR Number 1571, “General Hazar dous Waste Facility Standards.”

(i) Data items:

No specific data items are to be included in this demonstration.

# 26

(ii) Respondent activities:

Respondents must perform the following activ ities in performing this demonstration:

• Prepare decontamination demonstration; and

• Submit demonstration to EPA.

Air emission standards

40 CFR 264.200 requires owners a nd operators of permitted facilit ies to manage all hazardous

waste placed in a tank in accordan ce with the applicable requirements of 40 CFR part 264, Subparts AA,

BB, and CC. All data items and respondent activities under Subparts AA and BB, as applicable to tanks,

are covered later in this ICR under process vents and equipment leaks, respectively. Data items and

respondent activities under Subpart CC, as applicable to tanks, are covered in the Supporting Statement

for EPA ICR Number 1593: “Standards of Perform ance for Air Emission Standards for Tanks, Surface

Impoundments and Containers, 40 CFR Part 264, Su bpart CC and 40 CFR Part 265, Subpart CC.”

SURFACE IMPOUNDMENTS

Interim status facilities:

Regulations

Each owner/operator regulated under 40 CFR Part 265, Subpart K is expected to read the

regulations.

Design and operating requirements

Under 40 CFR 265.221, interim status facilities w ill need to submit information to EPA or the

authorized State if they seek an exemption from the lin er and/or leachate system requirements specified in

§265.221(a), (c), or (e).

40 CFR 265.221 requires interim status facilities to notify EPA at least 60 days before receiving

waste. Respondents are also required to file Part B of their permit application within six months of EPA’s

receipt of the notification. The Part B information collection activities are described in the “Part B Permit

Application, Permit Modification, and Special Permits ICR (EPA ICR Number 1573).

Under the general operating requi rements detailed in §265.222, facilities must assess their design

features and operating plans with regard to dike ove rtopping prevention requirements. Records of these

assessments must be maintained at the unit.

(i) Data items:

In seeking an exemption from the liner and/or leachate system requirements specified in

§265.221(a), (c), or (e), respondents will need to report and maintain records on the following data item:

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• A written assessment of alternate design and operating practices, together with location

characteristics, that will prevent the migra tion of any hazardous constituents into the

ground water or surface water as effectively as the requirements.

The data item required to comply w ith the notification requirement is:

• A notification to EPA or the authorized Stat e at least 60 days prior to receiving waste.

The data items for the recordkeeping requirement under §265.222 include:

• A written identification of the alternate design features or operating plans that will

prevent overtopping of a dike; and

• A certification from a qualified engineer that these alternate design features or operating

plans will prevent overtopping.

(ii) Respondent activities:

In order to complete the assessment, facilities will need to perform the following activities:

• Prepare and submit the written assessment of alternative design and operating practices to

EPA or the authorized State; and

• File and maintain the written assessm ent and related data at the unit.

Respondents will need to engage in the follo wing activities in order to notify EPA before

receiving waste:

• Prepare the notification and submit it to the Regional Administrator.

Respondents will perform the following activities in assessing their dike overtopping design

features and operating plans:

• Prepare the written identification of the alternate design features or operating plans that

will prevent overtopping of a dike;

• Obtain the certification from a qualified engineer that these alternate design features or

operating plans will prevent overtopping; and

• Maintain the certification and written identification at the unit.

Developing and submitting action leakage rates

Pursuant to section 265.222(a), the owner or operator of each new and replacement surface

impoundment and each lateral expansion of a surface impoundment subject to §265.221(a) must propose

an action leakage rate, with rationale, to EPA wh en submitting the notice required under §265.221(b) for

interim status facilities. After 60 days from the notification date, the action leakage rate will be

established as proposed by the interim status owner or operator, unless otherwise acted upon by EPA. In

# 28

addition, §265.73 requires owners or operators to mainta in records of all monitoring, testing, or analytical

data, and corrective action in connection with th e action leakage rate, as required under §265.222.

(i) Data item:

The data item required to comply with this requirement includes:

• A proposed action leakage rate that is the maximum design flow rate that the leak

detection system can remove without the flui d head on the bottom liner exceeding one (1)

foot, allowing for an adequate safety margin to allow for uncertainties in the design,

construction, operation, and location of the leak detection system; waste and leachate

characteristics; likelihood and amounts of other sources of liquids in the leak detection

system; and proposed response actions.

(ii) Respondent activities:

Respondents must perform the following activiti es for developing action leakage rates:

• Develop and submit to EPA a proposed action leakage rate and rationale, as specified in

section 265.222; and

• Maintain results of analyses, as required by §265.73.

Calculating average daily flow rates

To determine if the action leakage rate has been exceeded, the owner or operator of the surface

impoundment must use the weekly or monthly flow rates from the monitoring data obtained under

§265.226(b) and calculate average daily flow rates (in gallons per acre per day), in accordance with

§265.222(c). Unless EPA specifies otherwise, the av erage daily flow rates for each sump must be

calculated weekly during the active life and closur e period, and monthly during the post-closure care

period, if the unit is closed in accordance w ith section 265.228(b), and wh en required under section

265.226(b).

(i) Data item:

The data item required to comply with these requirements includes:

• Calculation of the average daily flow rates weekly during the active life and closure

period, and monthly during the post-closure care period.

(ii) Respondent activity:

Respondents must perform the following activity:

• Calculate average daily flow rates as required by §265.222(c).

Completion and submittal of the Response Action Plan and recordkeeping of response actions

# 29

Section 265.223(a) require the owner or operator of each new surface impoundment unit, each

replacement of an existing surface impoundment unit, and each lateral expansion of a surface

impoundment unit subject to section 265.221(a) to prepar e a Response Action Plan (RAP). The plan must

set forth the actions to be taken if the action leakag e rate has been exceeded. It must describe, at a

minimum, the actions required under §265.223(b). In terim status facilities must submit the RAP to EPA

when submitting the action leakage rate under §265.223(a).

(i) Data item:

The data item required to comply with these requirements includes:

 Response Action Plan.

(ii) Respondent activities:

 Develop Response Action Plan;

 Submit Response Action Plan to the Regional Administrator; and

 Maintain a copy of the Response Ac tion Plan and records of analyses.

Action leakage reporting

In the event the flow rate into the leak detection system exceeds the action leakage rate, section

265.223(b) requires the owner or operator to undertake the following activities.

(i) Data items:

The following data items are required if the action leakage rate is exceeded:

• Notification to the Regional Administrator, in writing, of the exceedance within seven

days of the determination;

• Submittal of a preliminary written assessment to the Regional Administrator within 14

days of the determination, as to the amount of liquids, likely sour ces of liquids, possible

location, size and cause of any leaks, and short-term actions ta ken and planned;

• Determination of, to the extent practicable, the location, size, and cause of any leaks;

• Determination as to whether waste receipt should cease or be curtailed;

 Determination as to whether any waste shoul d be removed from the unit for inspection,

repairs, or controls, and whether or not the unit should be closed;

• Determination of any other s hort-term and longer-term actions to be taken to mitigate or

stop any leaks; and

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• Submittal to the Regional Administrator, within 30 days after the notification that the

action leakage rate has been exceeded, the resu lts of the analyses specified, the results of

actions taken, and actions planned. As long as the ALR is exceeded, the owner or

operator must submit to the Regional Admi nistrator monthly reports summarizing the

results of any remedial actions taken and actions planned.

(ii) Respondent activities:

Respondents must perform the following activities as specified in the RAP:

• Notify the Regional Administrator, in writing, of the exceedance within seven days of the

determination, as required by §265.223(b)(1);

• Submit a preliminary written assessment to the Regional Administrator within 14 days of

the determination, as required §265.223(b)(2);

• Determine, to the extent practicable, the location, size and cause of any leak, as required

by §265.223(b)(3);

• Determine whether waste receipt should cease or be curtailed;

 Determine whether any waste should be removed from the unit for inspection, repairs, or

controls, and whether or not the unit should be closed;

• Determine any other short-term and longer-t erm actions to be taken to mitigate or stop

any leaks, as required by §265.223(b)(5); and

• Submit to the Regional Administrator, within 30 days after the notification that the ALR

has been exceeded, the results of the analyses specified in pa ragraphs(b)(3), (4), and (5),

the results of the actions taken, and actions planned, and monthly thereafter as required

by §265.223(b)(6).

Remediation determination analyses

Under 40 CFR 265.223(b)(3), (4), and (5), owne rs and operators must make leak and/or

remediation determinations.

(i) Data items:

The data items required to comply with these requirements include:

• Assessment of the source liquids and amounts of liquids by source;

• Execution of a fingerprint, hazardous constituent, of other analyses of the liquids in the

leak detection system to identify the source of liquids and possible location of any leaks,

and the hazard and mobility of the liquid; and

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• Assessment of the seriousness of any leak s in terms of potential for escaping into the

environment.

OR

• Documentation as to why assess ments above are not needed.

(ii) Respondent activities:

Respondents must perform the following activiti es when conducting a remediation determination

analyses:

 Perform the following activities to make leak and/or remediation determinations:

-- Assess the source of liquids and amounts of liquids, as required by section

§265.223(c)(1)(i);

-- Conduct a fingerprint, hazardous constituent, or other analyses, as required by

section §265.223(c)(1)(ii); and

-- Assess the seriousness of any leaks, as required by section 265.223(c)(1)(ii).

OR

-- Document why assessments above are not needed, as required by

§265.223(c)(1)(iii).

Waste analysis and trial tests

40 CFR 265.225 requires interim status surface im poundment owner/operators to gather waste

analysis data (in addition to that required in §264 .13) when a surface impoundment is used to chemically

treat hazardous waste with a substantially differ ent method than any previously used in the same

impoundment. If this is the case, the owner or opera tor must gather and maintain records on the data

items listed below.

Data items and respondent activities associated with these requirements are covered in this ICR.

However, the burden for recordkeeping the applicable data items is covered in “General Hazardous Waste

Facility Standards ICR” (EPA ICR Number 1571).

(i) Data items:

Data items required to comply with these requirements include:

 Documentation pertaining to waste analyses and trial treatment tests (e.g., bench-scale or

pilot-plant scale tests); and

• Documentation on similar treatment of si milar waste under similar operating conditions

to show that the treatment will comply with §265.17(b).

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(ii) Respondent activities:

Respondents must perform the following activities in gathering these data:

 Conduct waste analyses and trial tests; and

• Obtain written, documented information to show that the treatment will comply with

§265.17(b).

Monitoring and inspection

Section 265.226(a) and (b) require owners and operators of fac ilities that have interim status

surface impoundments to inspect their units and to reco rd the specified inspecti on activities. Data items

and respondent activities associated with these requireme nts are covered in this ICR. However, the

burden for recordkeeping the applicable data items is covered in “General Hazardous Waste Facility

Standards ICR” (EPA ICR Number 1571)

.



# i Data items:

Data items required to comply with these requirements include:

ii Records pertaining to the inspection of the free board level at least once each operating day, as

required by §265.222 (§265.226(a));

iii Records pertaining to the inspection of the su rface impoundment, including dikes and vegetation

surrounding the dike, at least once a week to detect any leaks, deterioration, or failures in

the impoundment (§265.226(a)); and

iv Records pertaining to the level of any liquids in the leak detection system removal sumps and the

amount of liquids removed from the LDS sumps each week during the active life and

closure period, as specified in §265.226(b)(1); and, if applicable, at least monthly during

the post-closure care period, at least quarterly if the liquid level in the sump stays below

the pump operating level for two consecutive months, or at least semi-annually if the

liquid level in the sump stays below the pump operating level for two consecutive

quarters, as specified in §265.226(b)(2) (§265.226(b)).

(ii) Respondent activity:

Respondents must perform the following activity for actions associated with monitoring and

inspections:

• Record all inspection data.

Developing and submitting pump operating levels

Section 265.226(b)(3) require ow ners or operators of each new surface impoundment unit, each

replacement of an existing surface impoundment unit, and each lateral expansion of a surface

impoundment unit required to have leak detecti on systems (LDS) under section 265.221(a) to submit

pump operating level proposals, with rationale, to EP A when submitting the action leakage rate proposal

# 33

required under §265.222(a). In additi on, section 265.73 require owners a nd operators to maintain records

of all monitoring, testing, or analytical data, a nd corrective action associated with the monitoring and

inspection activities require d under section 265.226.

(i) Data items:

Data items required to comply with these requirements include:

• A proposed pump operating level that is a li quid level based on the pump activation level,

sump dimensions, and level that avoids backup into the drainage layer and that minimizes

the head in the sump; and

• Recordkeeping, as required by §265.73, of all monitoring, testing, or analytical data, and

corrective action associated with the monito ring and inspection activities required under

section 265.226.

(ii) Respondent activities:

Respondents must perform the following activ ities when developing pump operating levels:

• Develop and submit to the Regional Admini strator a pump operating level and rationale,

as specified in section 265.226(b)(3); and

• Maintain records of all monitoring, testi ng, or analytical data, and corrective action

associated with the monitoring and inspec tion activities, in accordance with section

265.73.

Requirements for ignitable or reactive waste

Under 40 CFR 265.229, interim status facilities ma y not place ignitable or reactive waste in a

surface impoundment unless the waste meets the specifications of §265.229(a) or the impoundment is

used solely for emergencies, or: (1) the waste is pr otected from any conditions that may cause it to ignite

or react, and (2) the owner/operato r obtains a certification from a chemist or engineer that the design

features or unit operating plans will prevent ignition or reaction, and (3) the certification and the basis for

it are maintained at the unit.

(i) Data items:

The data items required to comply with the certification requirement are:

• A certification from a qualified chemist or engineer that the design features or unit

operating plans will prevent ignition or reaction; and

• The basis by which the chemist or engineer made the certification.

(ii) Respondent activities:

Respondents must perform the following activiti es to comply with this data collection:

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• Obtain the certification as required in 40 CFR 265.229; and

• File and maintain this certifica tion and related data at the unit.

Closure

Under 40 CFR 265.113(e) an owner or operator of a hazardous waste surface impoundment that

is not in compliance with the liner and leachate co llection system requirements in 42 U.S.C. 3004(o)(1)

and 3005(j)(1) or 2 U.S.C. 3004(o)(2) or (3) or 3005(j)(2), (3),(4), or (13) must implement closure and

corrective action measures.

(i) Data items:

The data items required to comply with these requirements are:

• A contingent corrective measures plan, unless a corrective action plan has already been

submitted under;

• A plan for removing hazardous wastes in co mpliance with paragraph (e)(2) of this

section;

• An extension request, based on a demonstr ation that the removal of hazardous wastes

will, of necessity, take longer than the allotte d period to complete and that an extension

will not pose a threat to human health and the environment; and

• A semi-annual report to the Regional Admini strator that describes the progress of the

corrective action program.

(ii) Respondent activities:

• Prepare and submit a contingent corr ective measures plan in accordance with

§265.113(e)(1)(i);

• Prepare and submit a hazardous wast e removal plan in accordance with

§265.113(e)(1)(ii);

• Prepare and submit an extension request, as specified in §265.113(e)(3); and

• Prepare and submit a corrective action report twice per year, as required by

§265.113(e)(5).

Air emission standards

40 CFR 265.231 requires owners a nd operators of interim stat us facilities to manage all

hazardous waste placed in a surface impoundment in acco rdance with the applicable requirements of 40

CFR Part 265, Subparts BB and CC. All data items and respondent activities under Subpart BB, as

applicable to surface impoundments, are covered later in this ICR under equipment leaks. Data items and

respondent activities under Subpart CC, as applicable to surface impoundments, are covered in the

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Supporting Statement for EPA ICR Number 1593: “Standards of Performance for Air Emission

Standards for Tanks, Surface Impoundments and Cont ainers, 40 CFR Part 264, Subpart CC and 40 CFR

Part 265, Subpart CC.”

Permitted facilities:

Regulations

Each owner/operator regulated under 40 CFR Part 264, Subpart K is expected to read the

regulations.

Design and operating requirements

Under 40 CFR 264.221, facilities will need to submit information to EPA or the authorized State

if they seek an exemption from the liner and/or l eachate system requirements specified in §264.221(a),

(c), or (e). Since permitted facilities submit applications for exemption from the liner and/or leachate

system requirements with their part B permit application, data items and activities associated with

preparing and submitting applications for exemption from the liner and/or leachate system requirements

are covered in the “Part B Permit Application, Permit Modification, and Special Permits ICR” (EPA ICR

Number 1573).

Calculating average daily flow rates

To determine if the action leakage rate has been exceeded, the owner or operator of the surface

impoundment must use the weekly or monthly flow rates from the monitoring data obtained under

§264.226(d) and calculate average daily flow rates (in gallons per acre per day), in accordance with

§264.222(b). Unless EPA specifies otherwise, the average daily flow rates for each sump must be

calculated weekly during the active life and closur e period, and monthly during the post-closure care

period, if the unit is closed in accordance w ith section 264.228(b), and wh en required under section

264.226(d).

(i) Data item:

The data item required to comply with this requirement is:

• Estimate of the average daily flow rates weekly during the active life and closure period,

and monthly during the post-closure care period.

(ii) Respondent activity:

Respondents must perform the following activity:

• Calculate the average daily flow rates as required by §264.222(b).

Completion and submittal of the Response Action Plan and recordkeeping of response actions

Section 264.223(a) require the owner or operator of each new surface impoundment unit, each

replacement of an existing surface impoundment unit, and each lateral expansion of a surface

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impoundment unit subject to section 264.221(a) to prep are a Response Action Plan (RAP). The plan

must set forth the actions to be taken if the action l eakage rate has been exceeded. It must describe, at a

minimum, the actions required under §264.223(b). Permitted facilities and facilities seeking initial

permits must submit the RAP for EPA approval in a Pa rt B permit application or modification before the

receipt of waste. Data items and respondent activ ities associated with preparing and submitting the RAP

are covered in the “Part B Application, Permit Modification, and Special Permits ICR” (EPA ICR

Number 1573).

Action leakage reporting

In the event the flow rate into the leak detection system exceed s the action leakage rate (ALR),

section 264.223(b) requires the owner or operator to undertake the following activities.

(i) Data items:

Data items required to comply with this requirement include:

• Notification to the Regional Administrator, in writing, of the exceedance within seven

days of the determination;

• Submittal of a preliminary written assessment to the Regional Administrator within 14

days of the determination, as to the amount of liquids, likely sour ces of liquids, possible

location, size and cause of any leaks, and short-term actions ta ken and planned;

• Determination of, to the extent practicable, the location, size, and cause of any leaks;

• Determination as to whether waste receipt should cease or be curtailed;

 Determination as to whether any waste shoul d be removed from the unit for inspection,

repairs, or controls, and whether or not the unit should be closed;

• Determination of any other s hort-term and longer-term actions to be taken to mitigate or

stop any leaks; and

• Submittal to the Regional Administrator, with in 30 days after the notification that the

action leakage rate has been exceeded, the resu lts of the analyses specified, the results of

actions taken, and actions planned. As long as the ALR is exceeded, the owner or

operator must submit to the Regional Admi nistrator monthly reports summarizing the

results of any remedial actions taken and actions planned.

(ii) Respondent activities:

Respondents must perform the following activities as specified in the RAP:

• Notify the Regional Administrator, in writing, of the exceedance within seven days of the

determination, as required by §264.223(b)(1);

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• Submit a preliminary written assessment to the Regional Administrator within 14 days of

the determination, as required by §264.223(b)(2);

• Determine, to the extent practicable, the location, size and cause of any leak, as required

by §264.223(b)(3);

• Determine whether waste receipt should cease or be curtailed;

 Determine whether any waste should be removed from the unit for inspection, repairs, or

controls, and whether or not the unit should be closed;

• Determine any other short-term and longer-term actions to be taken to mitigate or stop

any leaks, as required by §264.223(b)(5); and

• Submit to the Regional Administrator, within 30 days after the notification that the ALR

has been exceeded, the results of the analyses specified in pa ragraphs(b)(3), (4), and (5),

the results of the actions taken, and actions planned, and monthly thereafter as required

by §264.223(b)(6).

Remediation determination analyses

Under 40 CFR 264.223(b)(3), (4), and (5), owne rs and operators must make leak and/or

remediation determinations.

(i) Data items:

Data items required to comply with the requirements include:

• Assessment of the source liquids and amounts of liquids by source;

• Execution of a fingerprint, hazardous constituent, of other analyses of the liquids in the

leak detection system to identify the source of liquids and possible location of any leaks,

and the hazard and mobility of the liquid; and

• Assessment of the seriousness of any leak s in terms of potential for escaping into the

environment.

OR

• Documentation as to why assess ments above are not needed.

(ii) Respondent activities:

Respondents must perform the following activiti es when conducting remediation determination

analyses:

• Perform the following activities to make leak and/or remediation determinations:

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-- Assess the source of liquids and amounts of liquids, as required by sections

264.223(c)(1)(i);

-- Conduct a fingerprint, hazardous constituent, or other analyses, as required by

section 264.223(c)(1)(ii); and

-- Assess the seriousness of any leaks, as required by sections 264.223(c)(1)(ii).

OR

-- Document why assessments above are not needed, as required by

§264.223(c)(1)(iii).

Dike re-certification

Under 40 CFR 264.226(c) surface impoundment owne r/operators must, prior to issuance of a

permit and after any extended period of time in which the impoundment was not in use, obtain a

certification from a qualified engineer that the impoundmen t’s dike has sufficient structural integrity.

Since permitted facilities submit these certifications prior to or with their part B permit application, data

items and activities associated with preparing and s ubmitting these certifications are covered in the “Part

B Permit Application, Permit Modification, and Speci al Permits ICR” (EPA ICR Number 1573). The

burden associated with re-certifying dikes after extende d periods of non-use is covered in this ICR.

(i) Data item:

The data item required to comply with this requirement includes:

• A certification from a qualified engineer that the impoundment’s dike, including any

portion of the dike that provides freeboard, has structural integrity according to the

standards detailed in §264.226(c)(1) and (2).

(ii) Respondent activities:

To fulfill this requirement, permittees will need to perform the following activities:

• Obtain the certification from a qualified engineer; and

• File and maintain certification and related data at the unit.

Monitoring and inspection

Section 264.226(a) and (b) re quire owners and operators of facilities that use surface

impoundments to inspect their units and to record th e specified inspection activities. Data items and

respondent activities associated with these requirements ar e covered in this ICR. However, the burden for

recordkeeping the applicable data items is covered in “General Hazardous Waste Facility Standards ICR”

(EPA ICR Number 1571)

.



# i Data items:

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Data items required to comply with these requirements include:

v Records pertaining to inspections done during the co nstruction and installation of liners (except in

the case of existing portions of surface impoundments exempt form §264.221(a)) and

cover systems (e.g., membranes, sheets, or coatings) for uniformity, damage, and

imperfections (e.g., holes, cracks, thin spots, or foreign materials) (§264.226(a));

vi Records pertaining to the inspection of synthetic lin ers and covers to ensure tight seams and joints

an the absence of tears, punctures, or bl isters immediately after construction and

installation (§264.226(a));

vii Records pertaining to the inspection of so il-based and admixed liners and covers for

imperfections including lenses, cracks, channels, root holes, or other structural nonuniformities that may cause an increase in the permeability of the liner or cover

immediately after construction a nd installation (§264.226(a)); and

viii Records pertaining to the inspection of the surf ace impoundment weekly and after storms while it

is operation to detect evidence of any of the following (§264.226(b)):

-- Deterioration, malfunctions , or improper operation of overtopping

control systems;

-- Sudden drops in the level of the impoundment’s contents; and

-- Severe erosion or other signs of deterioration in dikes or other

containment devices.

(ii) Respondent activity:

Respondents must perform the following activity for actions associated with monitoring and

inspections:

ix Record all inspection data.

Emergency repairs and contingency plans

40 CFR 264.227 details criteria applicable to duri ng emergency situations (i.e., those in which

there is a precipitous drop in liquid levels or the impoundment is known to be leaking).

In addition, §264.227(d)(2)(ii) stipulates that no surface impoundment that contains a liner system

and has been removed from service under §264.227(a)(1 ) may be restored to service unless the repaired

liner system is certified by an engineer as meeting the design specifications approved in the permit.

(i) Data items:

For each surface impoundment removed from service under §264.227(a) owne r/operators must,

in addition to complying with other requ irements, provide the following data item:

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• A written notification to the Regional Administrator of a surface impoundment’s removal

from service.

The data item required under §264.227(d)(2)(ii) includes:

• A certification by a qualified engineer that the repaired liner system meets the design

specifications approved in the permit.

(ii) Respondent activities:

In order to complete this notification, permittees will need to engage in the following activities:

• Within seven days, notify the Regiona l Administrator in writing of a surface

impoundment’s removal from service; and

• File and maintain related data.

Respondents must perform the following activities in recertifying dikes:

• Obtain certification of the dike’s su fficient structural integrity; and

• Maintain the certification on file.

OR

• Obtain a liner repair certification, as required under §264.227(d)(2)(ii); and

• Maintain the certification on file.

Closure

Under 40 CFR 264.113(e) an owner or operator of a hazardous waste surface impoundment that

is not in compliance with the liner and leachate co llection system requirements in 42 U.S.C. 3004(o)(1)

and 3005(j)(1) or 2 U.S.C. 3004(o)(2) or (3) or 3005(j)(2), (3),(4), or (13) must implement closure and

corrective action measures.

(i) Data items:

The data items required to comply with these requirements are:

• A contingent corrective measures plan, unless a corrective action plan has already been

submitted under;

• A plan for removing hazardous wastes in co mpliance with paragraph (e)(2) of this

section;

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• An extension request, based on a demonstr ation that the removal of hazardous wastes

will, of necessity, take longer than the allotte d period to complete and that an extension

will not pose a threat to human health and the environment; and

• A semi-annual report to the Regional Admini strator that describes the progress of the

corrective action program.

(ii) Respondent activities:

• Prepare and submit a contingent corr ective measures plan in accordance with

§264.113(e)(1)(i);

• Prepare and submit a hazardous wast e removal plan in accordance with

§264.113(e)(1)(ii);

• Prepare and submit an extension request, as specified in §264.113(e)(3); and

• Prepare and submit a corrective action report twice per year, as required by

§264.113(e)(5).

Special requirements for hazardous wastes F 020, F021, F022, F023, F026, and F027

40 CFR 264.231 prohibits placing F020, F021, F022 , F023, F026, and F027 wastes in any surface

impoundment unless the owner/operator operates the impoundment in accordance with a management

plan approved by the Regional Administrator. Sin ce the waste management plan is submitted with the

Part B permit application, data items and respondent activities associated with this requirement are

covered in the “Part B Permit Application, Perm it Modification, and Special Permits ICR” (1573).

Air emission standards

40 CFR 264.232 requires owners a nd operators of permitted facilit ies to manage all hazardous

waste placed in a surface impoundment in accordance with the applicable requirements of 40 CFR part

264, Subparts BB and CC. All data items and res pondent activities under Subpart BB, as applicable to

surface impoundments, are covered later in this ICR under equipment leaks. Data items and respondent

activities under Subpart CC, as applicable to su rface impoundments, are covered in the Supporting

Statement for EPA ICR Number 1593: “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.”

WASTE PILES

Interim status facilities:

Regulations

Each owner/operator regulated under 40 CFR Part 265, Subpart L is expected to read the

regulations.

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Waste analysis

40 CFR 265.252 requires interim status waste pile owner/operators to analyze a representative

sample of waste from each incoming movement before adding the waste to any existing pile, unless (1)

the only wastes the facility receives which are amenable to piling are compatible with each other, or (2)

the waste received is compatible with the waste in th e pile to which it is to be added. The analysis

conducted must be able to differentiating between th e types of hazardous waste the owner or operator

places in piles, so that mixing of incompatible wast e does not inadvertently occur. The analysis must

include a visual comparison of color and texture. These waste analyses are in addition to the analyses

required under §265.13.

Note that data items and respondent activities asso ciated with these requirements are covered in

this ICR. However, the burden for recordkeeping th e applicable data items is covered in “General

Hazardous Waste Facility Standard s ICR” (EPA ICR Number 1571).

(i) Data item:

The data item required to comply with these requirements includes:

• Waste analysis data from each incoming movement before adding the waste to any

existing pile.

(ii) Respondent activity:

Respondents must perform the following activity in gathering these data:

• Conduct waste analyses.

Exemption from design and operating requirements

40 CFR 265.254 requires waste piles to comply with the regulations established 40 CFR 264.251

by having liners and leachate coll ection and removal systems sufficient to prevent any waste migration

for the active life of the pile (including the closure period). It also details design, construction, and

installation requirements for the liners and collection systems. 40 CFR 265.254 also exempts waste piles

from the requirements in paragraph §264.251(a) if the owner/operator can demonstrate to the Regional

Administrator that alternate design and operating prac tices, together with location characteristics, will

prevent hazardous constituents from migrating into th e ground or surface water at any future time.

Though the regulations provide no specific details re garding the demonstrations’ content, they do list

information that the Regional Administrator will consid er in deciding whether to grant an exemption.

This ICR assumes that respondents will include this information when submitting their demonstration.

(i) Data items:

The data items required for an exemption from §264.251(a) are:

• Information regarding the natu re and quantity of the wastes;

• The proposed alternate design and operation;

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• The unit’s hydrogeologic setting, includi ng attenuative capacity and thickness of the

liners and soils present between the pile and ground water or surface water; and

• All other factors that would influence the quality and mobility of the leachate produced

and the potential for it to migrate to ground water or surface water.

(ii) Respondent activities:

Respondents must perform the following ac tivities in making this demonstration:

• Gather the information necessary to pr ovide adequate demonstration; and

• Submit the information to the Regional Administrator.

Variance from design and operating requirements

40 CFR 265.254 also allows waste piles to seek a variance from the liner/leachate system design

requirements in 40 CFR 264.251(a) by submitting an alternative design or operating practices to the

Regional Administrator for approval, as long as the al ternative complies with the requirements contained

in 40 CFR 264.251(d). Though the regulations provide no specific details regarding the variance’s

content, they do list information that the Regional Administrator will consider in deciding whether to

grant a variance. This ICR assumes that respondents will include this information when submitting their

demonstration.

(i) Data item:

The data item required in making the demonstration includes:

 Demonstration of alternative design or operating practices.

(ii) Respondent activities:

Respondents must perform the following ac tivities in making this demonstration:

• Gather the information necessary for dem onstrating an alternative design; and

• Submit the information to the Regional Administrator.

Developing and submitting action leakage rates

Pursuant to section 265.255(a), th e owner or operator of each new and replacement waste pile and

each lateral expansion of a waste pile subject to §265.254 must propose an action leakage rate (ALR) to

EPA when submitting the notice required under §265.254 fo r interim status facilities. After 60 days from

the notification date, the ALR will be established as proposed by the interim st atus owner or operator,

unless otherwise acted upon by EPA. In addition, § 265.73 requires owners and operators to maintain

records of all monitoring, testing, or analytical data, and corrective action in connection with action

leakage rates, as required under §265.255.

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(i) Data item:

The data item required to comply with this requirement is:

• A proposed action leakage rate (ALR) that is the maximum design flow rate that the leak

detection system (LDS) can remove without the fluid head on the bottom liner exceeding

one (1) foot, allowing for an adequate safet y margin to allow for uncertainties in the

design, construction, operation, and location of the LDS; waste and leachate

characteristics; likelihood and amounts of other sources of liquids in the LDS; and

proposed response actions.

(ii) Respondent activities:

Respondents must perform the following activiti es for developing action leakage rates:

• Develop and submit to EPA a proposed action leakage rate, as specified in section

265.255; and

 Maintain results of analyses, as required by §265.73.

Calculating average daily flow rates

To determine if the action leakage rate has been exceeded, the owner or operator of the waste pile

must use the weekly flow rates from the monitoring data obtained under §265.260 and calculate average

daily flow rates (in gallons per acre per day), in accordance with §265.255(c). Unless EPA specifies

otherwise, the average daily flow rates for each sump must be calculated weekly during the active life and

closure period.

(i) Data item:

The data item required to comply with this requirement is:

• Estimate of the average daily flow rates w eekly during the active life and closure period.

(ii) Respondent activity:

Respondents must perform the following activity:

• Calculate the average daily flow rates, as required by §265.255(c).

Completion and submittal of the Response Action Plan and recordkeeping of response actions

Section 265.259(a) requires the owner or operator of each new waste pile unit, each replacement

of an existing waste pile unit, and each lateral expans ion of a waste pile unit subject to section 265.254 to

prepare and submit to EPA a Response Action Plan (RAP ). The plan must set forth the actions to be

taken if the action leakage rate has been exceeded. It must describe, at a minimum, the actions required

under section 265.259(b). Interim status facilities mu st submit the RAP to EPA when submitting the

ALR under §265.255.

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(i) Data item:

The data item required to comply with this requirement is:

 Response Action Plan.

(ii) Respondent activities:

 Develop Response Action Plan;

 Submit Response Action Plan to the Regional Administrator; and

 Maintain a copy of the Response Ac tion Plan and records of analyses.

Action leakage reporting

In the event the flow rate into the leak detection system exceeds the action leakage rate, section

265.259(b) requires the owner or operator to collect the following data items.

(i) Data items:

The following data items are required if the action leakage rate is exceeded:

• Notification to the Regional Administrator, in writing, of the exceedance within seven

days of the determination;

• Submittal of a preliminary written assessment to the Regional Administrator within 14

days of the determination, as the amount of liquids, likely sources of liquids, possible

location, size and cause of any leaks, and short-term actions taken and planned;

• Determination of, to the extent practicable, the location, size, and cause of any leaks;

• Determination as to whether waste receipt should cease or be curtailed;

 Determination as to whether any waste shoul d be removed from the unit for inspection,

repairs, or controls, and whether or not the unit should be closed;

• Determination of any other s hort-term and longer-term actions to be taken to mitigate or

stop any leaks; and

• Submittal to the Regional Administrator, with in 30 days after the notification that the

action leakage rate has been exceeded, the resu lts of the analyses specified, the results of

actions taken, and actions planned. As long as the ALR is exceeded, the owner or

operator must submit to the Regional Admi nistrator monthly reports summarizing the

results of any remedial actions taken and actions planned.

(ii) Respondent activities:

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Respondents must perform the following activities as outlined in the RAP:

• Notify the Regional Administrator, in writing, of the exceedance within seven days of the

determination, as required by §265.259(b)(1);

• Submit a preliminary written assessment to the Regional Administrator within 14 days of

the determination, as required by §265.259(b)(2);

• Determine, to the extent practicable, the location, size and cause of any leak, as required

by §265.259(b)(3);

• Determine whether waste receipt should cease or be curtailed;

 Determine whether any waste should be removed from the unit for inspection, repairs, or

controls, and whether or not the unit should be closed;

• Determine any other short-term and longer-term actions to be taken to mitigate or stop

any leaks, as required by §265.259(b)(5); and

• Submit to the Regional Administrator, within 30 days after the notification that the ALR

has been exceeded, the results of the analyses specified in pa ragraphs(b)(3), (4), and (5),

the results of the actions taken, and actions planned, and monthly thereafter as required

by §265.259(b)(6).

Remediation determination analyses

Under 40 CFR 265.259(b)(3), (4), and (5), owne rs and operators must make leak and/or

remediation determinations.

(i) Data items:

Data items required to comply with these requirements include:

• Assessment of the source liquids and amounts of liquids by source;

• Execution of a fingerprint, hazardous constituent, of other analyses of the liquids in the

leak detection system to identify the source of liquids and possible location of any leaks,

and the hazard and mobility of the liquid; and

• Assessment of the seriousness of any leak s in terms of potential for escaping into the

environment.

OR

• Documentation as to why assess ments above are not needed.

(ii) Respondent activities:

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Respondents must perform the following activiti es when conducting remediation determination

analyses:

• Perform the following activities to make leak and/or remediation determinations:

-- Assess the source of liquids and amounts of liquids, as required by sections

265.259(c)(1)(i);

-- Conduct a fingerprint, hazardous constituent, or other analyses, as required by

section 265.259(c)(1)(ii); and

-- Assess the seriousness of any leaks, as required by section 265.259(c)(1)(ii).

OR

-- Document why assessments above are not needed, as required by

§265.259(c)(1)(iii).

Monitoring and inspections

Section 265.260 requires owners or operators of each new waste pile unit, each replacement of an

existing waste pile unit, and each la teral expansion of a waste pile un it required to have leak detection

systems under §265.254 to record specified inspectio n activities. In addition, section 265.73 require

owners or operators to maintain records of all monito ring, testing, or analytical data, and corrective action

associated with the monitoring and inspec tion activities required under section 265.260.

Note that data items and respondent activities asso ciated with these requirements are covered in

this ICR. However, the burden for recordkeeping th e applicable data items is covered in “General

Hazardous Waste Facility Standard s ICR” (EPA ICR Number 1571).

(i) Data item:

The data item required to comply with these requirements is:

• Records pertaining to the level of any liquid s in the leak detection system removal sumps

and the amount of liquids removed from th e LDS sumps each week during the active life

and closure period, as specified in §265.260.

(ii) Respondent activity:

Respondents must perform the following activity for actions associated with monitoring and

inspections:

• Record the level of any liquids in the l eak detection system removal sumps and the

amount of liquids removed from the LDS sumps each week during the active life and

closure period, as required by §265.260.

Permitted facilities:

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Regulations

Each owner/operator regulated under 40 CFR Part 264, Subpart L is expected to read the

regulations.

Exemption from design and operating requirements

40 CFR 264.251(a) requires owner/operators to comp ly with the provisions in 40 CFR 264.251.

Under 40 CFR 264.251(a), owner/operators with waste piles subject to Subpart L are required to have

liners and leachate collection and removal systems suffi cient to prevent any waste migration for the active

life of the pile (including the closure period). Th is citation also details design, construction, and

installation requirements for the liners and collecti on systems. 40 CFR 264.251(b) exempts waste piles

from the requirements in §264.251(a) if the owne r/operator can demonstrate to the Regional

Administrator that alternate design and operating prac tices, together with location characteristics, will

prevent hazardous constituents from migrating into the ground or surface water at any future time. Since

permitted facilities submit applications for exemp tion from 40 CFR 264.251 with their part B permit

application, data items and activities associated with this exemption are covered in the “Part B Permit

Application, Permit Modification, and Speci al Permits ICR” (EPA ICR Number 1573).

Variance from design and operating requirements

40 CFR 264.251(d) allows owne r/operators of waste piles to seek a variance from the

liner/leachate system requirements by submitting an alternative design or operating practices, as long as

the alternative complies with the requirements gi ven in section 264.251(d). Since permitted facilities

submit applications for variance from 40 CFR 264.251 w ith their part B permit application, data items

and activities associated with this variance are c overed in the “Part B Permit Application, Permit

Modification, and Special Permits ICR” (EPA ICR Number 1573).

Calculating average daily flow rates

To determine if the action leakage rate has been exceeded, the owner or operator of the waste pile

must use the weekly flow rates from the monitoring data obtained under §264.254(c) and calculate

average daily flow rates (in gallons per acre per day), in accordance with §264.252(b). Unless EPA

specifies otherwise, the average daily flow rates for each sump must be calculated weekly during the

active life and closure period.

(i) Data item:

The data item required to comply with this requirement is:

• Estimate of the average daily flow rates w eekly during the active life and closure period.

(ii) Respondent activity:

Respondents must perform the following activity:

• Calculate the average daily flow rates as required by §264.252(b).

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Completion and submittal of the Response Action Plan and recordkeeping of response actions

Section 264.253(a) requires the owner or operator of each new waste pile unit, each replacement

of an existing waste pile unit, and each lateral expans ion of a waste pile unit subject to section 264.253(c)

or (d) to prepare and submit to EPA a Response Action Plan (RAP). The plan must set forth the actions

to be taken if the action leakage rate has been exceed ed. It must describe, at a minimum, the actions

required under §264.253(b). Permitted facilities and facilities seeking initial pe rmits must submit the

RAP for EPA approval in a Part B permit application or modification before the receipt of waste. Data

items and respondent activities associated with prepar ing and submitting the RAP are covered in the “Part

B Application, Permit Modification, and Special Permits ICR” (EPA ICR Number 1573).

Action leakage reporting

In the event the flow rate into the leak detection system exceeds the action leakage rate, section

264.253(b) requires the owner or operator to collect the following data items.

(i) Data items:

The following data items are required if the action leakage rate is exceeded:

• Notification to the Regional Administrator, in writing, of the exceedance within seven

days of the determination;

• Submittal of a preliminary written assessment to the Regional Administrator within 14

days of the determination, as the amount of liquids, likely sources of liquids, possible

location, size and cause of any leaks, and short-term actions taken and planned;

• Determination of, to the extent practicable, the location, size, and cause of any leaks;

• Determination as to whether waste receipt should cease or be curtailed;

 Determination as to whether any waste shoul d be removed from the unit for inspection,

repairs, or controls, and whether or not the unit should be closed;

• Determination of any other s hort-term and longer-term actions to be taken to mitigate or

stop any leaks; and

• Submittal to the Regional Administrator, with in 30 days after the notification that the

action leakage rate has been exceeded, the resu lts of the analyses specified, the results of

actions taken, and actions planned. As long as the ALR is exceeded, the owner or

operator must submit to the Regional Admi nistrator monthly reports summarizing the

results of any remedial actions taken and actions planned.

(ii) Respondent activities:

Respondents must perform the following activities as outlined in the RAP:

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• Notify the Regional Administrator, in writing, of the exceedance within seven days of the

determination, as required by §264.253(b)(1);

• Submit a preliminary written assessment to the Regional Administrator within 14 days of

the determination, as required by §264.253(b)(2);

• Determine, to the extent practicable, the location, size and cause of any leak, as required

by §264.253(b)(3);

• Determine whether waste receipt should cease or be curtailed;

 Determine whether any waste should be removed from the unit for inspection, repairs, or

controls, and whether or not the unit should be closed;

• Determine any other short-term and longer-term actions to be taken to mitigate or stop

any leaks, as required by §264.253(b)(5); and

• Submit to the Regional Administrator, within 30 days after the notification that the ALR

has been exceeded, the results of the analyses specified in para graphs (b)(3), (4), and (5),

the results of the actions taken, and actions planned, and monthly thereafter as required

by §264.253(b)(6).

Remediation determination analyses

Under 40 CFR 264.253(b)(3), (4), and (5), owne rs and operators must make leak and/or

remediation determinations.

(i) Data items:

Data items required to comply with these requirements include:

• Assessment of the source liquids and amounts of liquids by source;

• Execution of a fingerprint, hazardous constituent, of other analyses of the liquids in the

leak detection system to identify the source of liquids and possible location of any leaks,

and the hazard and mobility of the liquid; and

• Assessment of the seriousness of any leak s in terms of potential for escaping into the

environment.

OR

• Documentation as to why assess ments above are not needed.

(ii) Respondent activities:

Respondents must perform the following activiti es when conducting remediation determination

analyses:

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• Perform the following activities to make leak and/or remediation determinations:

-- Assess the source of liquids and amounts of liquids, as required by sections

264.253(c)(1)(i);

-- Conduct a fingerprint, hazardous constituent, or other analyses, as required by

sections 264.253(c)(1)(ii); and

-- Assess the seriousness of any leaks, as required by sections 264.253(c)(1)(ii).

OR

-- Document why assessments above are not needed, as required by

§264.253(c)(1)(iii).

Monitoring and inspections

Section 264.254(a) and (b) require owners and operators of fac ilities that use waste piles to

inspect their units and to record the specified inspection activities. Data items and respondent activities

associated with these requirements are covered in this ICR. However, the burden for recordkeeping the

applicable data items is covere d in “General Hazardous Waste Facility Standards ICR” (EPA ICR

Number 1571)

.



# (i) Data items:

Data items required to comply with these requirements include:

i Records pertaining to inspections done during the co nstruction and installation of liners (except in

the case of existing portions of surface impoundments exempt form §264.251(a)) and cover

systems (e.g., membranes, sheets, or coatings) for uniformity, damage, and imperfections (e.g.,

holes, cracks, thin spots, or foreign materials) (§264.254(a));

ii Records pertaining to the inspection of synthetic lin ers and covers to ensure tight seams and joints

an the absence of tears, punctures, or blisters immediately after construction and installation

(§264.254(a));

iii Records pertaining to the inspection of so il-based and admixed liners and covers for

imperfections including lenses, cracks, channels, root holes, or other structural non-uniformities

that may cause an increase in the permeability of th e liner or cover immediately after construction

and installation (§264.254(a)); and

iv Records pertaining to the inspection of the wast e pile weekly and after storms while it is

operation to detect evidence of any of the following (§264.254(b)):

-- Deterioration, malfunctions, or improper operation of run-on and run-off

control systems;

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-- Proper functioning of wind dispersal control systems, where present; and

-- The presence of leachate in and proper functioning of leachate collection

and removal systems, where present.

(ii) Respondent activity:

Respondents must perform the following activity for actions associated with monitoring and

inspections:

v Record all inspection data.

Special requirements for hazardous wastes F 020, F021, F022, F023, F026, and F027

40 CFR 264.259 prohibits placing F020, F021, F022, F023, F026, and F027 wastes in any waste

pile unless the owner/operator operates the waste pile in accordance with a management plan approved by

the Regional Administrator. Since the waste management plan is submitted with the Part B permit

application, data items and respondent activities associat ed with this requirement are covered in the “Part

B Permit Application, Permit Modificati on, and Special Permits ICR” (1573).

LAND TREATMENT

Interim status facilities :

Regulations

Each owner/operator regulated under 40 CFR Part 265, Subpart M is expected to read the

regulations.

Waste analysis

40 CFR 265.273 requires owners and operators of in terim status land treatment units to conduct

waste analyses (in addition to the waste analyses required under §265.13) before placing a hazardous

waste in or on a land treatment facility. The waste anal ysis results must be used to determine: (1) the

concentrations in the waste of any substances that cau se a waste to exhibit the Toxicity Characteristic; (2)

the concentrations of any substances which caused the waste to be listed as a hazardous waste; and (3) if

food chain crops are grown, the concentrations in the waste of arsenic, cadmium, lead, and mercury,

unless the owner or operator has written, documented data that show that the constituent is not present.

Note that data items and respondent activities asso ciated with these requirements are covered in

this ICR. However, the burden for recordkeeping th e applicable data items is covered in “General

Hazardous Waste Facility Standard s ICR” (EPA ICR Number 1571).

(i) Data items:

Data items required to comply with these requirements include:

 Waste analysis data for waste placed in or on a land treatment unit; and

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If food chain crops are grown and arsenic, cadmium, lead, and mercury are not present in the

waste:

 Documentation indicating that these cons tituents are not present in the waste.

(ii) Respondent activities:

Respondents must perform the following activities in complying with the §265.273 requirements:

 Conduct waste analyses; and

If food chain crops are grown and arsenic, cadmium, lead, and mercury are not present in the

waste:

 Obtain and maintain documentation indicati ng that these constituents are not present in

the waste.

Food-chain crops

40 CFR 265.276 regulates the growth of food-chai n crops at interim status hazardous waste land

treatment facilities. Owner/operators must notify the Regional Administrator if crops are grown, or have

been grown and will be grown again, on the unit. Th ese owner/operators must also keep records of the

information necessary to make a demonstration under 40 CFR 265.276(b)(1) at the unit, as stated below,

but are under no regulatory obligation to submit this information to EPA.

(i) Data items:

The data items for these requirements include:

• Notification, within 60 days of obtaining in terim status, that food chain crops are being

grown, or have been grown and will be grown in the future, on the unit (40 CFR

265.276(a));

• A record maintained at the interim status unit of all information necessary to demonstrate,

based on field testing, that arsenic, lead, me rcury, or other constitu ents identified under

40 CFR 265.273(b): (1) will not be transferre d to the food portion of the crop by plant

uptake or direct contact and will not be ingest ed by food chain animals, or (2) that these

constituents will not occur in greater con centrations in the crops grown on the land

treatment unit than in the same crops grown on untreated soils under similar conditions in

the same region (§265.276(b)(1)). This report must include:

-- Descriptions of crop and soil characteristics;

-- Sample selection criteria;

-- Sample size determination;

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-- Analytical methods; and

-- Statistical procedures.

Under section 265.276(c)(2)(iii) ow ner/operators must develop an operating plan that

demonstrates how the animal feed will be di stributed to preclude ingestion by humans.

(ii) Respondent activities:

Respondents must perform the following activities in complying with the §265.276 requirements:

• Prepare the notification required under 40 CFR 265.276(a) and submit it to EPA;

• Compile the information necessary to make the demonstration required under 40 CFR

265.276(b)(1);

• Maintain records of the information collected for the demonstrations; and

• Develop an operating plan as specified in §265.276(c)(2)(iii).

. Unsaturated-zone monitoring

Owner/operators subject to the unsaturated-z one monitoring requirements of 40 CFR 265.278

must establish an unsaturated-zone monitoring progr am to determine whether hazardous constituents

migrate out of the treatment zone. The interim stat us regulations require no re ports to be submitted to

EPA, but owner/operators must maintain a record of the plan at the unit.

(i) Data items:

The data items for these requirements include:

• A written record of the unsaturated-zone monitoring plan and the rationale used in

developing this plan, which must be kept at the unit (§265.278(d)). The plan must

include soil-core monitoring and soil-pore water monitoring.

(ii) Respondent activities:

Respondents must perform the following activiti es in compiling the unsaturated-zone monitoring

record:

• Develop an unsaturated-zone monitoring plan; and

• File the written plan at the unit.

Closure and post-closure care

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40 CFR 265.280 regulates cl osure and post-closure care at interim status hazardous waste land

treatment facilities. The regulations require owner/op erators to provide EPA with certification of closure

when unit closure is completed.

(i) Data items:

The data items for this requirement include:

• Certification by both an independent qua lified scientist, in lieu of an independent

registered professional engineer, and the owner/ operator that the unit has been closed in

accordance with the specifications in th e approved closure plan (§265.280(e)).

(ii) Respondent activities:

Respondents must perform the following activities in complying with §265.280:

• Obtain certification of closure from a qualified scientist;

• Produce owner/operator’s certification of closure; and

• Submit certification(s) to EPA.

Permitted facilities:

Regulations

Each owner/operator regulated under 40 CFR Part 264, Subpart M is expected to read the

regulations.

Food-chain crops

40 CFR 264.276 regulates the grow th of food-chain crops at permitted hazardous waste land

treatment facilities. Since the owner/operator must make the demonstrations outlined in §264.276(a)

prior to submitting the Part B permit application, data items and activities associated with this

demonstration are covered in the “Part B Permit App lication, Permit Modification, and Special Permits

ICR” (EPA ICR Number 1573). The burden associated with maintaining (i.e., filing and photocopying)

this documentation is covered in this ICR.

Under section 264.276(b)(2)(iii), owne r/operators must develop and maintain an operating plan

that demonstrates how the animal feed will be distributed to preclude ingestion by humans.

(i) Data items:

 Operating plan that demonstrates how the animal feed will be distributed to preclude

ingestion by humans.

(ii) Respondent activities:

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• Maintain food-chain crop documentation at the facility; and

 Develop and maintain an operating plan.

Unsaturated-zone monitoring

Owner/operators of permitted facilities subject to the unsaturated-zone monitoring requirements

of 40 CFR 264.278 must establish an unsaturated-zone monitoring program to determine whether

hazardous constituents migrate out of the treatment zone. These owner/operators must notify EPA

whenever they determine that there is a statistica lly significant increase of hazardous constituents below

the treatment zone, and must (1) submit a permit modification application to modify the operating

practices at the unit, or (2) submit a report to EPA demonstrating that the source of the increase is not the

regulated unit. If, however, the demonstration does no t show that a source other than the regulated units

or some error in sampling, analysis, or evalua tion caused the increase in hazardous constituents, the

owner/operator must submit the permit modification request within the specified time period.

(i) Data items:

Data items for these requirements include:

• Notification of statistically significant in creases of hazardous waste constituents below

the treatment zone. This notification must be made within seven days and must include

information on what constituents have shown statistically significant increases

(§264.278(g)(1));

• An application for a permit modification, submitted within 90 days, to modify operating

practices at the unit in order to maximize the success of degradation, transformation, or

immobilization processes in the treatment zone (§264.278(g)(2));

• Notification of intent to demonstrate that the increase was not caused by the regulated

units. This notification must be submitted within seven days of identifying the increase

(§264.278(h)(1)); and

• A report, submitted within 90 days, demonstra ting that a source other than the regulated

units caused the increase or that the increase re sulted from error in sampling, analysis, or

evaluation (§264.278(h)(2)).

(ii) Respondent activities:

Respondents must perform the following activities in complying with these notification, report,

and application requirements:

• Prepare and submit a notice of statistically significant increases in the concentration of

hazardous constituents;

• Prepare and submit notice of intent to ma ke a demonstration under 40 CFR 264.278(h);

and

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• Prepare and submit a report demonstrating th at a source other than the regulated units

caused the increase or that the increase resu lted from error in sampling, analysis, or

evaluation.

Closure and post-closure care

40 CFR 264.280 regulates cl osure and post-closure care at hazardous waste land treatment

facilities. The regulations require owner/operators to provide EPA with certification of closure when unit

closure is completed. The regulations also allo w exemptions from both the requirement to establish a

vegetative cover (§264.280(a)(8)), and the post-closure care requirements (§264.280(c)) if facilities make

the appropriate demonstrations.

(i) Data items:

Data items for these requirements include:

• Certification by an independent qualified sci entist, in lieu of an independent registered

professional engineer, that the unit has been closed in accordance wi th the specifications

in the approved closure plan (§264.280(b)); and

• For exemption from the vegetative cover and post-closure requirements, a demonstration

that the level of hazardous constituents in the treatment zone soil does not exceed the

background value of those constituents by a statistically significant amount

(§264.280(d)). This demonstration may be submitted at any time during the closure or

post-closure care periods.

(ii) Respondent activities:

Respondents must perform the following activ ities in complying with these requirements:

• Obtain certification of closure from a qualified scientist;

• Submit the certification(s) to EPA; and

• If applying for a demonstration under §264. 280(d), prepare the demonstration and submit

it to EPA.

Special requirements for hazardous wastes F 020, F021, F022, F023, F026, and F027

40 CFR 264.283 prohibits placing F020, F021, F022, F023, F026, and F027 wastes in any land

treatment unit unless the owner/operator operates th e unit in accordance with a management plan

approved by the Regional Administrator. Since the w aste management plan is submitted with the Part B

permit application, data items and respondent activities associated with this requirement are covered in

the “Part B Permit Application, Permit Modi fication, and Special Permits ICR” (1573).

LANDFILLS

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Interim status facilities:

Regulations

Each owner/operator regulated under 40 CFR Part 265, Subpart N is expected to read the

regulations.

Design requirements

40 CFR 265.301 requires owner operators of interim status landfills to install two or more liners

and leachate collection systems above and between the lin ers if they (1) plan to replace an existing unit,

(2) laterally expand an existing unit, or (3) install a new unit. The section provides for an exemption from

these requirements if the owner/operator can demonstrat e to the Regional Administrator that alternative

design and operating practices, together with locati on characteristics, will prevent the migration of

hazardous constituents as effectively as do the liners a nd leachate collection systems. In addition, the

regulations provide for a double liner requirement waiver for monofills (in certain instances). Under

§265.301(b), these facilities also must notify the Regiona l Administrator at least 60 days before receiving

waste, and file a Part B permit application within 6 months of EPA’s receipt of the notice (the Part B

information collection activities are described in a separate ICR (EPA ICR Number 1573)).

Under §265.301(d), the double liner requirement in §265.301(a) may be waived for any monofill

if: (1) the monofill contains only hazardous wastes de scribed in §265.301(d)(1), and (2) the monofill has

at least one non-leaking liner, and (3) the monofill is located more that one-quarter mile from an

underground source of drinking water, and (4) the mo nofill complies with the appropriate ground water

monitoring requirements under RCRA §3005(c) or the owner/operator demonstrates that the monofill is

located, designed, and operated so as to assure that there will be migration of any hazardous constituent

into ground water or surface water at any future time.

(i) Data items:

Data items required for the notification of intent to receive waste are:

• A notification to the Regional Administrato r at least 60 days prior to receiving waste.

The data items necessary to ga in an exemption under §265.301(c) from the liner and leachate

collection system requirements are:

• The proposed alternate design and operating practices; and

• Information concerning the landfill’s location characteristics.

The data item required for the waiver de monstration under §265.301(d) includes:

• Information regarding the monofill’s locati on, design, and operation as may be necessary

to make the demonstration.

(ii) Respondent activities:

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Respondents will need to engage in the following activities to comply with the §265.301

notification requirement:

• Prepare the notification and submit it to the Regional Administrator.

Respondents must perform the following activities in applying for an exemption from the liner

and leachate collection system requirements:

• Collect the required information; and

• Submit the information to the Regional Administrator.

Respondents must perform the following activities in order to be granted a waiver from the

double liner requirements:

• Collect the required information; and

• Submit the information to the Regional Administrator.

Developing and submitting action leakage rates

As required by section §265.302(a) , the owner or operator of each new and replacement landfill

and each lateral expansion of a landfill subject to §265 .301 (a) must submit an action leakage rate (ALR)

proposal and rationale to EPA when submitting the no tice required under §265.301 (b) for interim status

facilities. After 60 days from the notification date , the ALR will be established as proposed by the

interim status owner or operator unless otherwise acted upon by EPA. In addition, section 265.73

requires owners or operators to maintain records of all monitoring, testing, or analytical data, and

corrective action in connection with the ALR as required under §265.302.

(i) Data item:

The data item required to comply with these requirements is:

• A proposed action leakage rate (ALR) that is the maximum design flow rate that the leak

detection system (LDS) can remove without the fluid head on the bottom liner exceeding

one (1) foot, allowing for an adequate safet y margin to allow for uncertainties in the

design, construction, operation, and location of the LDS; waste and leachate

characteristics; likelihood and amounts of other sources of liquids in the LDS; and

proposed response actions.

(ii) Respondent activities:

Respondents must perform the following activ ities when developing action leakage rates:

• Develop and submit to EPA a proposed action leakage rate and rationale, as specified in

§265.302; and

• Maintain results of analyses, as required by §265.73.

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Calculating average daily flow rates

To determine if the action leakage rate has been exceeded, section 265.302(c) requires the owner

or operator of each landfill unit to use the weekly or monthly flow rates from the monitoring data

obtained under §265.304(b) and calculate average daily flow rates (in gallons per acre per day). Unless

EPA specifies otherwise, the average daily flow rat es for each sump must be calculated weekly during the

active life and closure period, and monthly during the post-closure care period, if the unit is closed in

accordance with section 265.310(b)(2), and when required under section 265.304(b).

(i) Data item:

The data item required to comply with these requirements is:

• Estimate of the average daily flow rates weekly during the active life and closure period,

and monthly during the post-closure care period.

(ii) Respondent activity:

Respondents must perform the following activity:

• Calculate the average daily flow rates as required by §265.302(c).

Completion and submittal of the Response Action Plan and recordkeeping of response actions

Section 265.303(a) requires the owner or operato r of each new landfill unit, each replacement of

an existing landfill unit, and each lateral expansion of a landfill unit subject to section 265.301(a) to

prepare a Response Action Plan (RAP). The plan must set forth the actions to be taken if the action

leakage rate has been exceeded. It must describe, at a minimum, the actions required under §265.303(b).

Interim status facilities must submit the RAP to EPA when submitting the ALR under §265.302.

(i) Data item:

The data item required to comply with these requirements is:

 Response Action Plan.

(ii) Respondent activities:

 Develop Response Action Plan;

 Submit Response Action Plan to the Regional Administrator; and

 Maintain a copy of the Response Ac tion Plan and records of analyses.

Action leakage reporting

40 CFR 265.303(b) requires the owner or operator to collect certain information in the event the

flow rate into the leak detection system exceeds the action leakage rate.

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(i) Data items:

The following data items are required if the action leakage rate is exceeded:

• Notification to the Regional Administrator, in writing, of the exceedance within seven

days of the determination;

• Submittal of a preliminary written assessment to the Regional Administrator within 14

days of the determination, as the amount of liquids, likely sources of liquids, possible

location, size and cause of any leaks, and short-term actions taken and planned;

Determination of, to the extent practicable, the location, size, and cause of any leaks;

• Determination as to whether waste receipt should cease or be curtailed;

 Determination as to whether any waste shoul d be removed from the unit for inspection,

repairs, or controls, and whether or not the unit should be closed;

• Determination of any other s hort-term and longer-term actions to be taken to mitigate or

stop any leaks; and

• Submittal to the Regional Administrator, with in 30 days after the notification that the

action leakage rate has been exceeded, the resu lts of the analyses specified, the results of

actions taken, and actions planned. As long as the ALR is exceeded, the owner or

operator must submit to the Regional Admi nistrator monthly reports summarizing the

results of any remedial actions taken and actions planned.

(ii) Respondent activities:

Respondents must perform the following activities as outlined in the RAP:

• Notify the Regional Administrator, in writing, of the exceedance within seven days of the

determination, as required by §265.303(b)(1);

• Submit a preliminary written assessment to the Regional Administrator within 14 days of

the determination, as required by §265.303(b)(2);

• Determine, to the extent practicable, the location, size and cause of any leak, as required

by §265.303(b)(3);

• Determine whether waste receipt should cease or be curtailed;

 Determine whether any waste should be removed from the unit for inspection, repairs, or

controls, and whether or not the unit should be closed;

• Determine any other short-term and longer-term actions to be taken to mitigate or stop

any leaks, as required by §265.303(b)(5); and

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• Submit to the Regional Administrator, within 30 days after the notification that the ALR

has been exceeded, the results of the analyses specified in pa ragraphs(b)(3), (4), and (5),

the results of the actions taken, and actions planned, and monthly thereafter as required

by §265.303(b)(6).

Remediation determination analyses

Under 40 CFR 265.303 (b)(3), (4) and (5), owners and operators must make the leak and/or

remediation determinations.

(i) Data items:

Data items required to comply with these requirements include:

• Assessment of the source liquids and amounts of liquids by source;

• Execution of a fingerprint, hazardous constituent, of other analyses of the liquids in the

leak detection system to identify the source of liquids and possible location of any leaks,

and the hazard and mobility of the liquid; and

• Assessment of the seriousness of any leak s in terms of potential for escaping into the

environment.

OR

• Documentation as to why assess ments above are not needed.

(ii) Respondent activities:

Respondents must perform the following activities to make leak and/or remediation

determinations:

• Perform the following activities to make leak and/or remediation determinations:

-- Assess the source of liquids and amounts of liquids, as required by section

§265.303(c)(1)(i);

-- Conduct a fingerprint, hazardous constituent, or other analyses, as required by

section §265.303(c)(1)(ii); and

-- Assess the seriousness of any leaks, as required by section 265.303(c)(1)(ii).

OR

-- Document why assessments above are not needed, as required by

§265.303(c)(1)(iii).

Monitoring and inspections

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Section 265.304 requires owners or operators of each new landfill unit, each replacement of an

existing landfill unit, and each latera l expansion of a landfill unit required to have a leak detection system

under §265.301(a) to record inspection activities as sp ecified in the regulations. In addition, section

265.73 require owners and opera tors to maintain records of all monitoring, testing, or analytical data, and

corrective action associated with the monitoring and inspection activities required under section 265.304.

Note that data items and respondent activities asso ciated with these requirements are covered in

this ICR. However, the burden for recordkeeping the applicable data items is covered in the “General

Hazardous Waste Facility Standard s ICR” (EPA ICR Number 1571).

(i) Data items:

The data items required to comply with these requirements include:

• Records pertaining to the level of liquids in the leak detection system removal sumps and

the amount of liquids removed from the LDS sumps each operating week during the

active life and closure period, as specified in §265.304(a); and, if applicable, at least

monthly during the post-closure care period, at least quarterly if the liquid level in the

sump stays below the pump operating level for two consecutive months, or at least

semi-annually if the liquid level in the sump stays below the pump operating level for

two consecutive quarters, as specified in §265.304(b); and

• Recordkeeping, as required by 265.73, of records of all monitoring, testing, or analytical

data, and corrective action associated with the monitoring and inspection activities as

required under section 265.304.

(ii) Respondent activity:

Respondents must perform the following activity for actions associated with monitoring and

inspections:

• Record the level of liquids in the leak detection system removal sumps and the amount of

liquids removed from the LDS sumps each operating week during the active life and

closure period, as required by §265.304(a); and, if applicable, at least monthly during the

post-closure care period, at least quarterly if the liquid level in the sump stays below the

pump operating level for two consecutive months , or at least semi-annually if the liquid

level in the sump stays below the pump operating level for two consecutive quarters, as

specified in §265.304(b).

Developing and submitting pump operating levels

Section 265.304(c) requires owners or operators of each new landfill unit, each replacement of an

existing landfill unit, and each latera l expansion of a landfill unit required to have leak detection systems

(LDS) under section 265.301 (a) to submit pump operating level proposals, with rationale, to EPA when

submitting the action leakage rate proposal required under §265.302(a). In addition, section 265.73

requires owners and operators to maintain records of all monitoring, testing, or analytical data, and

corrective action associated with the monitoring and inspection activities required under sections 265.304.

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(i) Data items:

The data items required to comply with these requirements include:

• A proposed pump operating level that is a li quid level based on the pump activation level,

sump dimensions, and level that avoids backup into the drainage layer and that minimizes

the head in the sump; and

• Recordkeeping, as required by §265.73, of all monitoring, testing, or analytical data, and

corrective action associated with the monito ring and inspection activities required under

section 265.304.

(ii) Respondent activities:

Respondents must perform the following activ ities when developing pump operating levels:

• Develop and submit to the Regional Admini strator a pump operating level and rationale,

as specified in section 265.304(c); and

• Maintain records of all monitoring, testi ng, or analytical data, and corrective action

associated with the monitoring and inspec tion activities, in accordance with section

§265.73.

Special requirements for bulk and containerized liquids

40 CFR 265.314(b) prohibits dispos ing bulk or containerized liquid hazardous waste or hazardous

waste containing free liquids in any landfill. 40 CF R 265.314(d) requires owner/operators to demonstrate

the absence or presence of free liquids in bulk or c ontainerized waste, using EPA Method 9095 (Paint

Filter Liquids Test) as described in “Test Methods for Evaluating Solid Wastes, Physical/Chemical

Methods” (EPA Publication No. SW-846).

In addition, 40 CFR 265.314(f) prohibits placi ng non-hazardous liquid waste in a landfill unless

the landfill owner/operator can demonstrate to the Regi onal Administrator, or the Regional Administrator

determines, that: (1) the only reasonably available a lternative is placing the waste in another landfill that

contains or is expected to contain hazardous wast e, and (2) placing the waste in the owner/operator’s

landfill will not risk contaminating any underground s ource of drinking water. The regulations do not

specify the exact form this demonstration must take; depending on the circumstances surrounding each

demonstration, the effort and data required to ga in an exemption may vary. This ICR assumes that

owner/operators will present inform ation regarding (1) the situational constraints that necessitate

disposing the waste in a landfill containing hazardous waste (e.g., the lack of access to any other suitable

disposal arrangement), and (2) hydrogeological and ot her information sufficient to show that doing so

cannot contaminate any underground source of drinking water.

(i) Data items:

The data items for demonstrating the absence of free liquids include:

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• Results of the Paint Filter Liquids Test, performed as specified in SW-846.

The data items required for the demons tration under 40 CFR 265.314(f) include:

• Information sufficient to show that the on ly reasonably available alternative to placing

the waste in the owner/operator’s landfill w ould be to place the waste in another landfill

or unlined surface impoundment that contains or is expected to contain hazardous waste;

and

• Information sufficient to show that placing th e waste in the owner/operator’s landfill will

not present a risk of contamination of an y underground source of drinking water.

(ii) Respondent activities:

Respondents must perform the following activities in performing the no-free-liquids

demonstration:

• Record and file the observation results.

Respondents must perform the following activiti es in order to gain an exemption from the

requirements in §265.314(f):

• Gather the information necessary to make the demonstration; and

• Submit the information to the Regional Administrator.

Permitted facilities:

Regulations

Each owner/operator regulated under 40 CFR Part 264, Subpart N is expected to read the

regulations.

Calculating average daily flow rates

To determine if the action leakage rate has been exceeded, section 264.302(b) requires the owner

or operator of each landfill unit to use the weekly or monthly flow rates from the monitoring data

obtained under §264.303(c)(2) and calculate average daily flow rates (in gallons per acre per day). Unless

EPA specifies otherwise, the average daily flow rat es for each sump must be calculated weekly during the

active life and closure period, and monthly during the post-closure care period, if the unit is closed in

accordance with section 264.310(b)(3), and wh en required under section 264.303(c)(1).

(i) Data item:

The data item required to comply with these requirements is:

• Estimate of the average daily flow rates weekly during the active life and closure period,

and monthly during the post-closure care period.

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(ii) Respondent activity:

Respondents must perform the following activity:

• Calculate the average daily flow rates as required by §264.302(b).

Monitoring and inspection

Section 264.303(a) and (b) require owners and operators of facilities that have landfills to inspect

their units and to record the specified inspecti on activities. Data items and respondent activities

associated with these requirements are covered in this ICR. However, the burden for recordkeeping the

applicable data items is covere d in “General Hazardous Waste Facility Standards ICR” (EPA ICR

Number 1571)

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# (i) Data items:

Data items required to comply with these requirements include:

i Records pertaining to inspections done during the co nstruction and installation of liners (except in

the case of existing portions of surface impoundments exempt form §264.301(a)) and

cover systems (e.g., membranes, sheets, or coatings) for uniformity, damage, and

imperfections (e.g., holes, cracks, thin spots, or foreign materials) (§264.303(a));

ii Records pertaining to the inspection of synthetic lin ers and covers to ensure tight seams and joints

an the absence of tears, punctures, or bl isters immediately after construction and

installation (§264.303(a));

iii Records pertaining to the inspection of so il-based and admixed liners and covers for

imperfections including lenses, cracks, channels, root holes, or other structural nonuniformities that may cause an increase in the permeability of the liner or cover

immediately after construction a nd installation (§264.303(a)); and

iv Records pertaining to the inspection of the wast e pile weekly and after storms while it is

operation to detect evidence of any of the following (§264.303(b)):

-- Deterioration, malfunctions, or improper operation of run-on and run-off

control systems;

-- Proper functioning of wind dispersal control systems, where present; and

-- The presence of leachate in and proper functioning of leachate collection

and removal systems, where present.

(ii) Respondent activity:

Respondents must perform the following activity for actions associated with monitoring and

inspections:

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v Record all inspection data.

Completion and submittal of the Response Action Plan and recordkeeping of response actions

Section 264.304(a) requires the owner or operato r of each new landfill unit, each replacement of

an existing landfill unit, and each lateral expansion of a landfill unit subject to section 264.301(c) or (d) to

prepare a Response Action Plan (RAP). The plan must set forth the actions to be taken if the action

leakage rate has been exceeded. It must describe, at a minimum, the actions required under §264.303(b).

Permitted facilities and facilities seeking initial permits mu st submit the RAP for EPA approval in a Part

B permit application or modification before the recei pt of waste. Data items and respondent activities

associated with preparing and submitting the RAP ar e covered in the “Part B Application, Permit

Modification, and Special Permits ICR” (EPA ICR Number 1573).

Action leakage reporting

40 CFR 264.304(b) requires owners and operators to collect certain information in the event the

flow rate into the leak detection system exceeds the action leakage rate.

(i) Data items:

The following data items are required if the action leakage rate is exceeded:

• Notification to the Regional Administrator, in writing, of the exceedance within seven

days of the determination;

• Submittal of a preliminary written assessment to the Regional Administrator within 14

days of the determination, as the amount of liquids, likely sources of liquids, possible

location, size and cause of any leaks, and short-term actions taken and planned;

Determination of, to the extent practicable, the location, size, and cause of any leaks;

• Determination as to whether waste receipt should cease or be curtailed;

 Determination as to whether any waste shoul d be removed from the unit for inspection,

repairs, or controls, and whether or not the unit should be closed;

• Determination of any other s hort-term and longer-term actions to be taken to mitigate or

stop any leaks; and

• Submittal to the Regional Administrator, with in 30 days after the notification that the

action leakage rate has been exceeded, the resu lts of the analyses specified, the results of

actions taken, and actions planned. As long as the ALR is exceeded, the owner or

operator must submit to the Regional Admi nistrator monthly reports summarizing the

results of any remedial actions taken and actions planned.

(ii) Respondent activities:

Respondents must perform the following activities as outlined in the RAP:

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• Notify the Regional Administrator, in writing, of the exceedance within seven days of the

determination, as required by §264.304(b)(1);

• Submit a preliminary written assessment to the Regional Administrator within 14 days of

the determination, as required by §264.304(b)(2);

• Determine, to the extent practicable, the location, size and cause of any leak, as required

by §264.304(b)(3);

• Determine whether waste receipt should cease or be curtailed;

 Determine whether any waste should be removed from the unit for inspection, repairs, or

controls, and whether or not the unit should be closed;

• Determine any other short-term and longer-term actions to be taken to mitigate or stop

any leaks, as required by §264.304(b)(5); and

• Submit to the Regional Administrator, within 30 days after the notification that the ALR

has been exceeded, the results of the analyses specified in pa ragraphs(b)(3), (4), and (5),

the results of the actions taken, and actions planned, and monthly thereafter as required

by §264.304(b)(6).

Remediation determination analyses

Under 40 CFR 264.304(b)(3), (4) and (5), owne rs and operators must make leak and/or

remediation determinations.

(i) Data items:

Data items required to comply with these requirements include:

• Assessment of the source liquids and amounts of liquids by source;

• Execution of a fingerprint, hazardous constituent, of other analyses of the liquids in the

leak detection system to identify the source of liquids and possible location of any leaks,

and the hazard and mobility of the liquid; and

• Assessment of the seriousness of any leak s in terms of potential for escaping into the

environment.

OR

• Documentation as to why assess ments above are not needed.

(ii) Respondent activities:

Respondents must perform the following activities to make leak and/or remediation

determinations:

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• Perform the following activities to make leak and/or remediation determinations:

-- Assess the source of liquids and amounts of liquids, as required by section

264.304(c)(1)(i);

-- Conduct a fingerprint, hazardous constituent, or other analyses, as required by

section 264.304(c)(1)(ii); and

-- Assess the seriousness of any leaks, as required by section 264.304(c)(1)(ii).

OR

-- Document why assessments above are not needed, as required by

§264.304(c)(1)(iii).

Special requirements for bulk and containerized liquids

40 CFR 264.314(b) prohibits dispos ing bulk or containerized liquid hazardous waste or hazardous

waste containing free liquids in any landfill. 40 CF R 264.314(c) requires owner/operators to demonstrate

the absence or presence of free liquids in bulk or c ontainerized waste using EPA Method 9095 (Paint

Filter Liquids Test) as described in “Test Methods for Evaluating Solid Wastes, Physical/Chemical

Methods” (EPA Publication No. SW-846).

In addition, 40 CFR 264.314(e) prohibits pl acing non-hazardous liquid waste in a landfill unless

the landfill owner/operator can demonstrate to the Regi onal Administrator, or the Regional Administrator

determines, that: (1) the only reasonably available a lternative is placing the waste in another landfill that

contains or is expected to contain hazardous wast e, and (2) placing the waste in the owner/operator’s

landfill will not risk contaminating any underground s ource of drinking water. The regulations do not

specify the exact form this demonstration must take; depending on the circumstances surrounding each

demonstration, the effort and data required to ga in an exemption may vary. This ICR assumes that

owner/operators will present inform ation regarding (1) the situational constraints that necessitate

disposing the waste in a landfill containing hazardous waste (e.g., the lack of access to any other suitable

disposal arrangement), and (2) hydrogeological and ot her information sufficient to show that doing so

cannot contaminate any underground source of drinking water.

(i) Data items:

The data items for demonstrating the absence of free liquids include:

• Results of the Paint Filter Liquids Test, performed as specified in SW-846.

The data items required for the demonstr ation under 40 CFR 264.314(e) include:

• Information sufficient to show that the on ly reasonably available alternative to placing

the waste in the owner/operator’s landfill woul d be to place the waste in another landfill

or unlined surface impoundment that contains or is expected to contain hazardous waste;

and

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• Information sufficient to show that placing th e waste in the owner/operator’s landfill will

not present a risk of contamination of an y underground source of drinking water.

(ii) Respondent activities:

Respondents must perform the following activities in performing the no-free-liquids

demonstration:

• Record and file the observation results.

Respondents must perform the following activiti es in order to gain an exemption from the

requirements in §264.314(e):

• Gather the information necessary to make the demonstration; and

• Submit the information to the Regional Administrator.

Special requirements for hazardous wastes F 020, F021, F022, F023, F026, and F027

40 CFR 264.317 prohibits placing F020, F021, F022 , F023, F026, and F027 wastes in any landfill

unless the landfill is operated in accordance with a management plan approved by the Regional

Administrator. Since the waste management plan is submitted with the Part B permit application, data

items and respondent activities associated with this requirement are covered in the “Part B Permit

Application, Permit Modification, and Speci al Permits ICR” (EPA ICR Number 1573).

INCINERATORS

Interim status facilities:

Regulations

Each owner/operator regulated under 40 CFR Part 265, Subpart O is expected to read the

regulations.

Applicability

40 CFR Part 265, Subpart O presents interim stat us hazardous waste incinerator standards.

Section 265.340(b) exempts incinerator owner/ope rators from these regulations (except §265.351--

Closure).

(i) Data item:

The data item required for an exemption from th e interim status incinerator requirements is:

• Written documentation that the waste to be incinerated meets the requirements listed in

40 CFR 265.340(b) and cannot r easonably be expected to contain any of the hazardous

constituents listed in 40 CFR 261, Appendix VIII.

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(ii) Respondent activities:

Respondents must perform the following activities in order to be exempt from these

requirements:

• Determine whether the waste in questio n meets the requirements listed in 40 CFR

265.340(b) and Part 261, Appendix VIII, and document the fact in writing; and

• File the documentation at the unit.

Waste analysis

40 CFR 265.341 requires owner/operators of an interi m status incinerator to gather waste analysis

data (in addition to that required in §265.13) for hazardous waste that has not been previously burned in

his incinerator to enable him to establish steady st ate (normal) operating conditions (including waste and

auxiliary fuel feed and air flow) and to determine th e type of pollutants which might be emitted. At a

minimum, the waste analysis must determine:

 Heating value of the waste;

 Halogen content and sulfur content in the waste; and

 Concentrations in the waste of lead and mercury, unless the owner or operator has

written, documented data that show that the element is not present.

Note that data items and respondent activities asso ciated with these requirements are covered in

this ICR. However, the burden for recordkeeping the applicable data items is covered in the “General

Hazardous Waste Facility Standard s ICR” (EPA ICR Number 1571).

(i) Data item:

The data item required to comply with these requirements include:

 Records of the waste analysis results.

(ii) Respondent activity:

Respondents must perform the following activity in gathering these data:

• Conduct waste analysis.

Monitoring and inspections

Section 265.347(a) and (b) require owners and operators of inci nerators to conduct monitoring

and inspection activities and to collect data gath ered by these activities when incinerating hazardous

waste. Data items and respondent activities associated with these requirements are covered in this ICR.

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However, the burden for recordkeeping the applicable data items is covered in “General Hazardous Waste

Facility Standards ICR” (EPA ICR Number 1571)

.



# (i) Data items:

Data items required to comply with these requirements include:

vi Records pertaining to the monitoring of existi ng instruments which relate to combustion and

emission control every 15 minutes (§264.347(a));

vii Records pertaining to the inspection of the co mplete incinerator and associated equipment

(pumps, valves, conveyors, pipes, etc.), at least daily, for leaks, spills, and fugitive

emissions (§264.347(b)); and

 Records pertaining to the inspection of all emergency shutdown controls and system

alarms to assure proper operation (§264.347(b)).

(ii) Respondent activity:

Respondents must perform the following activity in gathering these data:

viii Record all inspection data.

Special requirements for hazardous wastes F 020, F021, F022, F023, F026, and F027

Under 40 CFR 265.352, these wastes may be burned in interim status hazardous waste

incinerators if owner/operators receive a certifica tion from the Assistant Administrator for Solid Waste

and Emergency Response that they can meet the perf ormance standards of Subpart O of Part 264.

(i) Data item:

The data item required to receive this certification include:

• An application to the Assistant Administ rator containing the information in §§ 270.19

and 270.62.

(ii) Respondent activities:

Respondents must perform the following activities to receive this certification:

• Complete an application that demonstrat es the incinerator can meet the performance

standards in Subpart O of Part 264, including a trial burn; and

• Submit the application to EPA.

Permitted facilities:

Regulations

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Each owner/operator regulated under 40 CFR Part 264, Subpart O is expected to read the

regulations.

Applicability

40 CFR Part 264, Subpart O presents permitted stat us hazardous waste incinerator standards.

Section 264.340(b) exempts incinerator owner/ operators from these regulations. Since the

owner/operator submits applicability exemptions with the Part B Permit Application, data items and

respondent activities associated with this requirement are covered in the “Part B Permit Application,

Permit Modification, and Special Pe rmits ICR” (EPA ICR Number 1573).

Notification of intent to burn hazardous wastes

40 CFR 264.343(a)(2) requires owner/operators to notify the Regional Administrator prior to

burning EPA Hazardous Waste Codes F020, F021, F022, F023, F026, and F027.

(i) Data items:

No specific data items are to be included in this notification.

(ii) Respondent activities:

To comply with 40 CFR 264.343(a)(2), owners/ operators must perform the following activities:

• Prepare notification of intent to burn wastes; and

• Submit notification to the Regional Administrator.

Monitoring and inspections

40 CFR 264.347(a), (b) and (c) detail the monito ring and inspection requirements for Subpart O

incinerators. Data items and respondent activities asso ciated with these requireme nts are covered in this

ICR. However, the burden for recordkeeping the ap plicable data items is covered in the “General

Hazardous Waste Facility Standard s ICR” (EPA ICR Number 1571).

(i) Data items:

Data items required to comply with these requirements include:

ix Records pertaining to the following monitoring activities (§264.347(a)):

-- Combustion temperature, waste feed rate, and the indicator of combustion gas

velocity specified in the facility permit must be monitored on a continuous basis;

-- CO must be monitored on a continuous basis at a point in the incinerator

downstream of the combustion zone and pr ior to release to the atmosphere; and

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-- Upon request by the Regional Administrator, sampling and analysis of the waste

and exhaust emissions mu st be conducted to verify that the operating

requirements established in the permit achieve the performance standards of

§264.343;

 Records pertaining to thorough visual inspections, conducted at least daily, of the

incinerator and associated equipment (pumps, valves, conveyors, pipes, etc.) for leaks,

spills, fugitive emissions, and signs of tampering (§264.347(b)); and

 Records pertaining to operational testing, conducted at least weekly, of the emergency

waste feed cutoff system and associated alar ms to verify operab ility (§264.347(c));

OR

• A demonstration for exemption under §264.347( c) from the requirements to test the

emergency waste feed cutoff system and associate alarms on a weekly basis; and

 Records pertaining to operational testing, c onducted at least monthly, of the emergency

waste feed cutoff system and associated alar ms to verify operab ility (§264.347(c)).

(ii) Respondent activity:

Respondents must perform the following activity in order to be exempt from these requirements:

• Record all inspection data.

THERMAL TREATMENT UNITS (Interim Status Facilities Only)

Regulations

Each owner/operator regulated under 40 CFR Part 265, Subpart P is expected to read the

regulations.

Waste analysis

40 CFR 265.375 requires owner/operators of a ther mal treatment unit to gather waste analysis

data (in addition to that required in §265.13) for hazardous waste that has not been previously treated in

his thermal treatment process to enable him to establi sh steady state (normal) or other appropriate (for

non-continuous process) opera ting conditions (including auxiliary fuel feed) and to determine the type of

pollutants which might be emitted. Data items and respondent activities associated with these

requirements are covered in this ICR. However, the burden for recordkeeping the applicable data items is

covered in the “General Hazardous Waste Fac ility Standards ICR” (EPA ICR Number 1571).

At a minimum, the analysis must determine:

 Heating value of the waste;

 Halogen content and sulfur content in the waste; and

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 Concentrations in the waste of lead and mercury, unless the owner or operator has

written, documented data that show that the element is not present.

(i) Data item:

The data item required to comply with these requirements include:

 Records of the waste analysis results.

(ii) Respondent activity:

Respondents must perform the following activity in gathering this data:

• Conduct waste analysis.

Monitoring and inspections

40 CFR 265.377 requires owner/operators of an inte rim status thermal treat ment unit to conduct

monitoring and inspection activities and collect the data gathered during these activities. Data items and

respondent activities associated with these requirements ar e covered in this ICR. However, the burden for

recordkeeping the applicable data items is covered in the “General Hazardous Waste Facility Standards

ICR” (EPA ICR Number 1571).

(i) Data items:

The data items required for owners and oper ators of Subpart P incinerators include:

 Records pertaining to the monitoring, at least every 15 minutes, of existing instruments

which relate to temperature and emission control (if an emission control device is

present);

 Records pertaining to the visual observation, at least hourly, of the stack plume

(emissions), where present, for normal appearance (color and capacity);

 Records pertaining to the inspection, at least daily, of the complete thermal process and

associated equipment (pumps, valves, conveyors, pipes, etc.) for leaks, spills, and fugitive

emissions; and

 Records pertaining to the inspection, at least daily, of all emergency shutdown controls

and system alarms to assure proper operation.

(ii) Respondent activities:

Respondents must perform the following activities in gathering these data:

 Monitor existing instruments which relate to temperature and emission control (if an

emission control device is present);

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 Observe visually the stack plume, wh ere present, for normal appearance;

• Inspect the complete thermal process and associated equipment for leaks, spills, and

fugitive emissions; and

• Inspect all emergency shutdown controls and system alarms to assure proper operation.

Application to burn F020, F021, F023, F026, or F027

40 CFR 265.383(b)(1) requires owners /operators of facilities that thermally treat hazardous waste

in devices other than enclosed devices using c ontrolled flame combustion who chose to burn EPA

Hazardous Wastes F020, F021, F022, F023, F026, or F027 to submit an application to burn these wastes.

Applications to burn EPA Hazardous Wastes F020, F 021, F022, F023, F026, or F027 must include the

applicable information in §§ 270.19 and 270.62.

(i) Data item:

The data item required to comply with this requirement includes:

• An application to the Assistant Administ rator for Solid Waste and Emergency Response

containing information in §270.62 or §270.19(c).

(ii) Respondent activities:

To comply with §265.383(b)(1), responde nts must perform the following activities:

• Collect information and prepare application; and

• Submit application to the Assistant Admi nistrator for Solid Waste and Emergency

Response.

CHEMICAL, PHYSICAL, AND BI OLOGICAL TREATMENT UNITS (Interim Status Facilities

Only)

Regulations

Each owner/operator regulated under 40 CFR Part 265, Subpart Q is expected to read the

regulations.

Waste analysis and trial tests

40 CFR 265.402 requires owner/operators of a chemi cal, physical, or biological treatment unit to

conduct waste analyses (in addition to those requi red in §265.13) for hazardous waste, whenever:

 A hazardous waste which is substantially diffe rent from waste previously treated in a

treatment process or equipment at the facility is to be treated in that process or

equipment;

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OR

 A substantially different process th an any previously used at th e facility is to be used to

chemically treat hazardous waste.

Note that data items and respondent activities asso ciated with these requirements are covered in

this ICR. However, the burden for recordkeeping the applicable data items is covered in the “General

Hazardous Waste Facility Standards ICR” (EPA ICR Number 1571).

(i) Data items:

The data items required for owners and operators of Subpart Q units include:

 Records of waste analyses and trial treatment tests (e.g., bench scale or pilot plant scale);

OR

 A demonstration that the proposed treatment will meet all applicable requirements of

§265.401(a) and (b), based on written, documen ted information on similar treatment of

similar waste under similar operating conditions.

(ii) Respondent activities:

Respondents must perform the following activities in gathering this data:

• Conduct waste analyses and trial treatment tests;

OR

• Obtain written, documented information on similar treatment of similar waste under

similar operating conditions.

Inspections

40 CFR 265.403 requires owner/operators of a chem ical, physical, or biological unit to conduct

inspections of the unit, as specified below. Data items and respondent activities associated with these

requirements are covered in this ICR. However, the burden for recordkeeping the applicable data items is

covered in the “General Hazardous Waste Fac ility Standards ICR” (EPA ICR Number 1571).

(i) Data items:

The data items required for owners and oper ators of Subpart Q treatment units include:

 Records pertaining to the inspection of discharge control and safety equipment (e.g.,

waste feed cutoff system, by-pass systems, drainage systems, and pressure relief

systems), where present, at least once each ope rating day, to ensure that it is in good

working order (§265.403(a)(1));

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 Data gathered from monitoring equipment (e .g., pressure and temperature gauges), at

least once each operating day, to ensure that the treatment process or equipment is being

operating according to its design (§265.403(a)(2));

 Records pertaining to the inspection of construction materials of the treatment process or

equipment, at least weekly, to detect corrosion or leaking fixtures or seams

(§265.403(a)(3)); and

 Records pertaining to the inspection of construction materials of, and the area

immediately surrounding, discharge confinement structures (e.g., dikes), at least weekly,

to detect erosion or obvious signs of leak age (e.g., wet spots or dead vegetation)

(§265.403(a)(4)).

(ii) Respondent activities:

Respondents must perform the following activities in gathering these data:

 Inspect discharge control and safety equipm ent, where present, at least once each

operating day, to ensure that it is in good working order (§265.403(a)(1));

 Gather data from monitoring equipment, where present, at least once each operating day,

to ensure that the treatment process or e quipment is being operating according to its

design (§265.403(a)(2));

 Inspect construction materials of the treatment process or equipment, where present, at

least weekly, to detect corrosion or leaking fixtures or seams (§265.403(a)(3)); and

 Inspect construction materials of, and the area immediately surrounding, discharge

confinement structures (e.g., dikes), where presen t, at least weekly, to detect erosion or

obvious signs of leakage (e.g., wet spots or dead vegetation) (§265.403(a)(4)).

DRIP PADS

Generators:

Regulations

Each respondent regulated under 40 CFR Part 261 is expected to read the regulations.

Equipment cleaning or replacement plan

40 CFR 261.35(b) requires owners and operators of facilities th at generate wastes from wood

preserving processes to either prepare, sign, and follow an equipment cleaning plan, or prepare, sign, and

follow an equipment replacement plan. In addition, generators must document equipment cleaning and

replacement in accordance with §261.35(b)(1)(iii). Ge nerators must also maintain records documenting

all equipment cleaning or replacement (§261.35(c)).

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(i) Data item:

The data item required to comply with these requirements include:

 Documentation of equipment cleaning and replacement.

(ii) Respondent activities:

Respondents must perform the following activities in gathering this data:

• Prepare and follow an equipment cleaning plan;

OR

• Prepare and follow an equipment replacement plan;

OR

• Document cleaning and replacement; and

• Maintain documentation of equipment cleaning and replacement.

Interim Status facilities:

Regulations

Each owner/operator regulated under 40 CFR Part 265, Subpart W is expected to read the

regulations.

Contingency plan

40 CFR 265.440 requires owners and operators of facilities that use new or existing drip pads to

convey treated wood drippage, precipitation, and/or surface water run-on to an associated collection

system. The requirements are not applicable, however , to the management of infrequent and incidental

drippage in storage yards provided that the owner or operator maintains and complies with a written

contingency plan that describes how the owner or ope rator will respond immediately to the discharge of

such infrequent and incidental drippage.

(i) Data item:

The data item required to comply with these requirements includes:

• Contingency plan describing how the owner or operator will do the following: (1) clean

up the drippage; (2) document the cleanup of the drippage; (3) retain documents

regarding cleanup for three years; and (4) ma nage the contaminated media in a manner

consistent with Federal regulations (§265.440(c)).

(ii) Respondent activities:

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To comply with §265.440(c), respondents must perform the following activities:

• Develop and maintain a contingency plan for discharge of drippage, including

documentation of drippage.

Assessment of existing drip pad integrity

40 CFR 265.441(a) requires that for each existing drip pad as defined in §265.440, the owner or

operator must evaluate the drip pad and determine th at it meets all of the requirements of this Subpart,

except the requirements for liners and leak detection systems of §265.443(b).

(i) Data item:

The data item for this evaluation includes:

• A written assessment of the drip pad, review ed and certified by an independent, qualified

registered professional engineer that attests to the results of the evaluation.

(ii) Respondent activities:

To comply with §265.441(a), respondents must perform the following activities:

• Obtain and submit a written, certif ied assessment of the drip pad;

• Maintain the written assessme nt of the drip pad; and

• Review, update, and re-certify the assessment annually.

Plan for upgrading, repairing, and modifying the drip pad

40 CFR 265.441(b) requires that the owner or operator develop a written plan for upgrading,

repairing, and modifying the drip pad to meet the requirements of §265.443(b) a nd must submit this plan

no later than two years before the date that all repair s, upgrades, and modifications will be complete. This

written plan must describe all changes to be made to the drip pad. Upon completion of all repairs and

modifications, the owner or operator must submit the as-built drawing with certification by and

independent, qualified engineer attes ting that the drip pad conforms to the drawings, as specified in 40

CFR 265.441(c).

(i) Data items:

The data items for these requirements include:

• A written plan reviewed and certified by an independent qualified, registered professional

engineer; and

• As-built drawings for the drip pad togeth er with a certification by an independent,

qualified registered professional engineer att esting that the drip pad conforms to the

drawings.

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(ii) Respondent activities:

To comply with §265.441(b)-(c), respondent s must perform the following activities:

• Develop and submit to the Regional Administrator a written certified plan;

• Maintain a written assessment of the plan; and

• Obtain and submit as-built dr awings and a certification.

Design and operating requirements

40 CFR 265.443 specifies design and operating re quirements for owners and operators of

facilities with drip pads. Sections 265.443(a), (b), (g), (i), and (k) include information collection

requirements associated with the design, construction, operation, and maintenance of the drip pads.

(i) Data items:

The data items required to comply with these requirements include:

• A written assessment of the drip pad, review ed and certified by an independent, qualified

registered professional engineer that attest s to the results of the evaluation. The

assessment must be reviewed, updated, and recertified annually. The evaluation must

document the extent to which the drip pad meets the design and operating standards of

this section (§265.443(a)(4)(ii));

• Documentation in the unit’s operating log of the date and time of any leakage collected

and removed from the leakage collection syst em immediately above the liner that is

designed, constructed, maintained, and opera ted to collect leakage from the drip pad

(§265.443(b)(3));

• Certification from an independent, qualified registered professional engineer stating that

the drip pad design meets the requirements of §265.443 (§265.443(g));

• Documentation in the unit’s operating log of the date and time of each weekly cleaning of

the drip pad and the cleaning procedure used (§265.443(i)); and

• Records sufficient to document that all treated wood is held on the pad following

treatment in accordance with this requirement (§265.443(k)).

(ii) Respondent activities:

To comply with §265.443(a), (b), (g), (i), and (k), respondents must perform the following

activities:

• Obtain and maintain a written certif ied assessment of a new drip pad;

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• Update and maintain the written certifie d assessment of the drip pad annually;

• Maintain documentation of the date and tim e of any leakage collected and removed from

the leakage collection system immediately above the liner;

 Obtain and maintain a certification from an independent, qualified registered professional

engineer stating that the drip pad design meets the requirements of §265.443;

• Maintain documentation of th e date and time of each weekly cleaning of the drip pad;

and

• Maintain records that all treated wood is held on the drip pad after treatment.

Emergency response

40 CFR 265.443(m) requires that throughout the active life of the drip pad, the owner or operator

must repair within a reasonably prompt period of tim e any condition detected that may have caused or has

caused a release of hazardous waste.

(i) Data items:

The data items for this requirement include:

• A record of discovery of each condition in the unit operating log;

 A 24-hour notification;

• Written notification of the condition to the Regional Administrator within 10 working

days of the discovery, providi ng a description of the steps that will be taken to repair the

drip pad, and clean up any leakage, and the schedule for accomplishing this work; and

• Written notification with a certification by an independent, qualified, registered

professional engineer to the Regional Administ rator showing that all repairs and clean up

have been completed according to the written plan submitted.

(ii) Respondent activities:

To comply with §265.443(m), respondent s must perform the following activities:

• Enter a record of discovery for each condition;

 Notify EPA of each condition within 24 hours;

• Provide written notification to EPA within 10 working days; and

• Prepare and submit a report with certification to EPA when all repairs and clean up are

complete.

Facility operating record

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40 CFR 265.443(n) requires that the owner or operato r of a unit with drip pads must maintain as

part of the unit’s operating log, documentation of past operating and waste handling practices.

(i) Data item:

The data item for this requirement is:

• Documentation of past operating and waste handling practices, which must include

identification of preservative formulations u sed in the past, a description of drippage

management practices, and a description of treated wood storage and handling practices.

(ii) Respondent activity:

To comply with §265.443(n), respondents must perform the following activity:

• Maintain documentation of past ope rating and waste handling practices.

Inspections

40 CFR 265.444 requires that during construction or installation, liners and cover systems (e.g.,

membranes sheets, or coatings) must be inspected for uniformity, damage, and imperfections (e.g., holes,

cracks, thin spots, or foreign materials). Data items and respondent activ ities associated with these

requirements are covered in this ICR. However, the burden for recordkeeping the applicable data items is

covered in the “General Hazardous Waste Fac ility Standards ICR” (EPA ICR Number 1571).

(i) Data items:

The data items for this requirement include:

• Inspection of liners immediately after construction or installation with certification by an

independent qualified, registered professiona l engineer. Also, drip pads must be

inspected weekly while in operation; and

• Certifications of inspection must be mainta ined at the unit as part of the unit’s operating

record.

(ii) Respondent activities:

To comply with §265.444 respondents must perform the following activity:

• Inspect and certify liners immediately after construction or installation; and

• Inspect and certify liners on a weekly basis.

Permitted facilities:

Regulations

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Each owner/operator regulated under 40 CFR Part 264, Subpart W is expected to read the

regulations.

Contingency plan

40 CFR 264.570 requires owners and operators of facilities that use new or existing drip pads to

convey treated wood drippage, precipitation, and/or surface water run-on to an associated collection

system. The requirements are not applicable, however , to the management of infrequent and incidental

drippage in storage yards provided that the owner or operator maintains and complies with a written

contingency plan that describes how the owner or ope rator will respond immediately to the discharge of

such infrequent and incidental drippage.

(i) Data item:

The data item for this requirement includes:

• Contingency plan describing how the owner or operator will do the following: (1) clean

up the drippage; (2) document the cleanup of the drippage; (3) retain documents

regarding cleanup for three years; and (4) ma nage the contaminated media in a manner

consistent with Federal re gulations (§264.570(c)(1)).

(ii) Respondent activity:

To comply with §264.570(c)(1), respondent s must perform the following activity:

• Develop and maintain a contingency plan for discharge of drippage, including

documentation of drippage.

Assessment of existing drip pad integrity

40 CFR 264.571(a) requires that for each existing drip pad as defined in §264.570, the owner or

operator must evaluate the drip pad and determine th at it meets all of the requirements of this Subpart,

except the requirements for liners and leak detection systems of §264.573(b).

(i) Data item:

The data item for this evaluation includes:

• A written assessment of the drip pad, review ed and certified by an independent, qualified

registered professional engineer that attests to the results of the evaluation.

(ii) Respondent activities:

To comply with §264.571(a), respondents must perform the following activities:

• Obtain a written, certified assessment of the drip pad;

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• Maintain on file the written asse ssment of the drip pad; and

• Review, update, and re-certify the assessment annually.

Plan for upgrading, repairing, and modifying the drip pad

40 CFR 264.571(b) requires that the owner or operator develop a written plan for upgrading,

repairing, and modifying the drip pad to meet the requirements of §264.573(b) a nd must submit this plan

no later than two years before the date that all repair s, upgrades, and modifications will be complete. This

written plan must describe all changes to be made to the drip pad. Upon completion of all repairs and

modifications, the owner or operator must submit the as-built drawing with certification by and

independent, qualified engineer attes ting that the drip pad conforms to the drawings, as specified in 40

CFR 264.571(c).

(i) Data items:

The data items for these requirements include:

• A written plan reviewed and certified by an independent qualified, registered professional

engineer; and

• As-built drawings for the drip pad togeth er with a certification by an independent,

qualified registered professional engineer att esting that the drip pad conforms to the

drawings.

(ii) Respondent activities:

To comply with §264.571(b)-(c), respondent s must perform the following activities:

• Develop and submit to the Regional Administrator a written certified plan;

• Maintain a written assessment of the plan; and

• Obtain and submit as-built dr awings and a certification.

Design and operating requirements

40 CFR 264.573 specifies design and operating re quirements for owners and operators of

facilities with drip pads. Sections 264.573(a), (b), (g), (i), and (k) include information collection

requirements associated with the design, construction, operation, and maintenance of the drip pads.

(i) Data items:

The data items required to comply with these requirements include:

• A written assessment of the drip pad, review ed and certified by an independent, qualified

registered professional engineer that attest s to the results of the evaluation. The

assessment must be reviewed, updated, and recertified annually. The evaluation must

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document the extent to which the drip pad meets the design and operating standards of

this section (§264.573(a)(4)(ii));

• Documentation in the unit’s operating log of the date and time of any leakage collected

and removed from the leakage collection syst em immediately above the liner that is

designed, constructed, maintained, and opera ted to collect leakage from the drip pad

(§264.573(b)(3));

• Certification from an independent, qualified registered professional engineer stating that

the drip pad design meets the requirements of §264.573 (§264.573(g));

• Documentation in the unit’s operating log of the date and time of each weekly cleaning of

the drip pad and the cleaning procedure used (§264.573(i)); and

• Records sufficient to document that all treated wood is held on the pad following

treatment in accordance with this requirement (§264.573(k)).

(ii) Respondent activities:

To comply with §264.573(a), (b), (g), (i), and (k), respondents must perform the following

activities:

• Obtain and maintain a written certif ied assessment of a new drip pad;

• Update and maintain the written certifie d assessment of the drip pad annually;

• Maintain documentation of the date and tim e of any leakage collected and removed from

the leakage collection system immediately above the liner;

 Obtain and maintain a certification from an independent, qualified registered professional

engineer stating that the drip pad design meets the requirements of §264.573;

• Maintain documentation of th e date and time of each weekly cleaning of the drip pad;

and

• Maintain records that all treated wood is held on the drip pad after treatment.

Emergency response

40 CFR 264.573(m) requires that throughout the active life of the drip pad, the owner or operator

must repair within a reasonably prompt period of tim e any condition detected that may have caused or has

caused a release of hazardous waste.

(i) Data items:

The data items for this requirement include:

• A record of discovery of each condition in the unit operating log;

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 A 24-hour notification;

• Written notification of the condition to the Regional Administrator within 10 working

days of the discovery, providi ng a description of the steps that will be taken to repair the

drip pad, and clean up any leakage, and the schedule for accomplishing this work; and

• Written notification with a certification to the Regional Administrator showing that all

repairs and clean up have been complete d according to the written plan submitted.

(ii) Respondent activities:

To comply with §264.573(m), respondent s must perform the following activities:

• Enter a record of discovery for each condition;

 Notify EPA of each condition within 24 hours;

• Provide written notification to EPA within 10 working days; and

• Prepare and submit a report with certification to EPA when all repairs and clean up are

complete.

Facility operating record

40 CFR 264.573(n) requires that the owner or operato r of a unit with drip pads must maintain as

part of the unit’s operating log, documentation of past operating and waste handling practices.

(i) Data item:

The data item for this requirement is:

• Documentation of past operating and waste handling practices, which must include

identification of preservative formulations u sed in the past, a description of drippage

management practices, and a description of treated wood storage and handling practices.

(ii) Respondent activity:

To comply with §264.573(n), respondents must perform the following activity:

• Maintain documentation of past ope rating and waste handling practices.

Inspections

40 CFR 264.574 requires that during construction or installation, liners and cover systems (e.g.,

membranes sheets, or coatings) must be inspected for uniformity, damage, and imperfections (e.g., holes,

cracks, thin spots, or foreign materials). Data items and respondent activiti es associated with these

requirements are covered in this ICR. However, the burden for recordkeeping the applicable data items is

covered in the “General Hazardous Waste Fac ility Standards ICR” (EPA ICR Number 1571).

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(i) Data items:

The data items for this requirement include:

• Inspection of liners immediately after construction or installation with certification by an

independent qualified, registered professiona l engineer. Also, drip pads must be

inspected weekly while in operation; and

• Certifications of inspection must be mainta ined at the unit as part of the unit’s operating

record.

(ii) Respondent activities:

To comply with §264.574 respondents must perform the following activity:

• Inspect and certify liners immediately after construction or installation; and

• Inspect and certify liners on a weekly basis.

MISCELLANEOUS UNITS (Per mitted Facilities Only)

Because developing and following a written schedule for inspecting equipment is covered in the

“General Hazardous Waste Facility Standards I CR” ( EPA ICR Number 1571), submitting a biennial

report is covered in the “Biennial Report ICR” (EPA ICR Number 976), preparing an unmanifested waste

report is covered in the “Manifest ICR” (EPA ICR Number 801), preparing release, fire, explosion, and

closure reports are covered in the “General Hazar dous Waste Facility Standards ICR” (EPA ICR Number

1571), and documenting post-closure care procedur es for closed miscellaneous units that have

contaminated soils or ground water are covered in the “Part B Permit Application, Permit Modification,

and Special Permits ICR” (EPA ICR Number 1573), th ese data items and activities associated with them

are not covered in this ICR. The only burden cove red in this ICR for respondents regulated under 40

CFR Part 264, Subpart X is for reading the regulations.

PROCESS VENTS

Interim status facilities:

Regulations

Each owner/operator regulated under 40 CFR Part 265, Subpart AA is expected to read the

regulations.

Control device operation documentation

40 CFR 265.1033(i) requires owner/ operators to prepare documentation describing the operation

of control devices different from those specified in §265.1033(f), (g), and (h) and identifying process

parameters that indicate proper operation and maintenance of those control devices.

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(i) Data items:

The data items for this determination include:

• Information describing the control device operation; and

• Information on the process parameter or parame ters that will be used to indicate proper

operation and maintenance of the control device.

(ii) Respondent activities:

To comply with §265.1033(i), respondent s must perform the following activities:

• Gather information on control devi ce operation and process parameters;

• Document control device operation and process parameter information;

 Reassess and file control device/process parameter information;

• Modify control device documentation, if necessary; and

• Maintain documentation at the unit (required under §265.1035(e)).

Waste determination

40 CFR 265.1034(d)(2) requires owner/operators to document waste determinations that are

based on knowledge of the waste rather than testing.

(i) Data items:

Data items required for documenting waste determ inations are not specified, but may include the

following:

• Production process information documenti ng that no organic compounds are used;

• Waste generation information documenting that the waste is generated by a process

identical to a process at the same or another unit that has previously been demonstrated

by direct measurement to generate a waste st ream having a total organic content less than

10 ppmw; and

• Prior specification analysis results on the sa me waste stream where it can be documented

that no process changes have occurred since th e specification analysis was conducted that

could affect the waste total organic concentration.

(ii) Respondent activities:

To comply with §265.1034(d)(2), responde nts must perform the following activities:

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• Gather information on production processes, wa ste generation, and specification analysis;

• Document information on production processes, waste generation, and specification

analysis; and

• Maintain documentation at the unit.

Facility operating record

Implementation schedule

Under 40 CFR 265.1035(b)(1), owner/operators of facilities that comply with the provisions of

§265.1033(a)(2) are required to put the implem entation schedule in the unit operating record.

(i) Data item:

The data item for this requirement includes:

• An implementation schedule that includes da tes by which the closed-vent system and

control device will be installed and in oper ation. The schedule must also include a

rationale of why the installation cannot be completed at an earlier date.

(ii) Respondent activities:

To comply with §265.1035(b)(1), responde nts must perform the following activities:

 Prepare implementation schedule;

 Reassess implementation schedule;

 File and maintain implementation schedule; and

 Modify implementation schedule, if necessary.

Up-to-date documentation of compliance with the process vent standards in §265.1032

Under 40 CFR 265.1035(b)(2), owner/operators are required to record the following information

in the unit operating record to document up-to-date compliance with §265.1032.

(i) Data items:

The data items for this requirement include:

 Information and data identifying all aff ected process vents, annual throughput and

operating hours of each affected unit, estimated emission rates for each affected vent and

for the overall unit, and the approximate loca tion within the unit of each affected unit;

and

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 Information and data supporting determin ations of vent emissions and emission

reductions achieved by add-on control devi ces based on engineering calculations or

source tests.

(ii) Respondent activities:

To comply with §265.1035(b)(2), responde nts must perform the following activities:

 Prepare documentation of compliance;

 Reassess documentation of compliance;

 File and maintain documentation of compliance; and

 Modify documentation of compliance, if necessary.

Performance test plan

Under 40 CFR 265.1035(b)(3), owner/operators are required to put the performance test plan in

the unit operating record.

(i) Data item:

The data item for this requirement includes:

• Where an owner or operator chooses to use test data to determine the organic removal

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

performance test plan that incl udes the following information:

-- A description of how it is determined that the planned test is going to be

conducted when the hazardous waste manage ment unit is operating at the highest

load or capacity level reasonably expected to occur. This shall include the

estimated or design flow rate and organic content of each vent stream and define

the acceptable operating ranges of key process and control device parameters

during the test program;

-- A detailed engineering description of the closed-vent system and control device,

including:

- Manufacturer’s name and m odel number of control device;

- Type of control device;

- Dimensions of the control device;

- Capacity;

- Construction materials; and

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-- A detailed description of sampling and monitoring procedures, including

sampling and monitoring locations in the system, the equipment to be used,

sampling and monitoring frequency, a nd planned analytical procedures for

sample analysis.

(ii) Respondent activities:

To comply with §265.1035(b)(3), responde nts must perform the following activities:

 Prepare performance test plan;

 Reassess performance test plan;

 File and maintain performance test plan; and

 Modify performance test plan, if necessary.

Documentation of compliance with §265.1033

Under 40 CFR 265.1035(b)(4), owner/operators are required to record the following information

in the unit operating record to document compliance with §265.1033.

(i) Data items:

The data items for this requirement include:

 A list of all information references and s ources used in preparing the documentation;

 Records including the dates of each comp liance test required by §265.1033(j);

 If engineering calculations are used, a design analysis, specifications, drawings,

schematics, and piping and instrumentation di agrams based on the appropriate sections of

“APTI Course 415: Control of Gaseous Emi ssions” or other engineering texts acceptable

to the Regional Administrator that present basic control device design information.

Documentation provided by the control devi ce manufacturer or vendor that describes the

control device design in accordance with pa ragraphs (b)(4)(iii)(A) through (b)(4)(iii)(G)

of this section may be used;

 A statement signed and dated by the owne r/operator certifying that the operating

parameters used in the design analysis reas onably represent the conditions that exist when

the hazardous waste management unit is or w ould be operating at the highest load or

capacity level reasonably expected to occur;

 A statement signed and dated by the owner/ope rator certifying that the control device is

designed to operate at an efficiency of 95 percent or greater unless the total organic

concentration limit of §265.1032(a) is achieved at an efficiency less than 95 percent or

the total organic emission limits of §265.1032(a) for affected process vents at the unit can

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be attained by a control device involving vapor recovery at an efficiency less than 95

weight percent. A statement provided by the control device manufacturer or vendor

certifying that the control equipment meets the design specifications may be used to

comply with this requirement; and

 If performance tests are used to demonstrate compliance, all tests results.

(ii) Respondent activities:

To comply with §265.1035(b)(4), responde nts must perform the following activities:

 Prepare documentation of compliance;

 Reassess documentation of compliance;

 File and maintain documentation of compliance; and

 Modify documentation of compliance, if necessary.

Design, monitoring, operation, and inspection information

Under 40 CFR 265.1035(c), owner/operators are requir ed to record the following information in

the unit operating record for each closed-vent syst em and control device required to comply with

§265.1033.

(i) Data items:

The data items for this requirement include:

 Description and date of each modification that is made to the closed-vent system or

control device design;

 Identification of operating parameter, description of monitoring device, and diagram of

monitoring sensor location or locations used to comply with §§ 265.1033(f)(1) and (f)(2);

 Monitoring, operating and inspection informa tion required by paragraphs (f) through (k)

of §265.1033;

 Date, time, and duration of each period that o ccurs while the control device is operating

when any monitored parameter exceeds the va lue established in the control device design

analysis;

 Explanation for each period recorded under pa ragraph (4) of the cause for control device

operating parameter exceeding the design valu e and the measures implemented to correct

the control device operation;

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 For a carbon adsorption system operated subject to requirements specified in

§§ 265.1033(g) or 265.1033(h)(2), date when existing carbon in the control device is

replaced with fresh carbon;

 For a carbon adsorption system operated subject to requirements specified in

§265.1033(h)(1), a log recording the following information:

-- Date and time when control device is monitored for carbon breakthrough and the

monitoring device reading; and

-- Date existing carbon in control device is replaced with fresh carbon;

 Date of each control device start-up and shutdown;

 Where an owner or operator designates an y components of a closed-vent system as

unsafe to monitor pursuant to §265.1033(n), the owner or operator must record in a log

that is kept in the facility operating record : the identification of closed-vent system

components that are designated unsafe to monitor pursuant to §265.1033(n), an

explanation for each closed-vent system com ponent stating why the closed-vent system

component is unsafe to monitor, and the pl an for monitoring each closed-vent system

component; and

 When each leak is detected as specified in §265.1033(k), record the following

information:

-- The instrument identification numb er, the closed-vent system component

identification number, and the operator na me, initials, or identification number;

-- The date the leak was detected and the date of first attempt to repair the leak;

-- The date of successful repair of the leak;

-- Maximum instrument reading measured by Method 21 of 40 CFR part 60,

appendix A after it is successfully repaired or determined to be nonrepairable;

and

-- “Repair delayed” and the reason for the de lay if a leak is not repaired within 15

calendar days after discovery of the leak.

(ii) Respondent activities:

To comply with §265.1035(c), respondent s must perform the following activities:

 Prepare design, monitoring, operation, and inspection information;

 Reassess design, monitoring, operatio n, and inspection information;

 File and maintain design, monitoring, op eration, and inspection information; and

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 Modify design, monitoring, operation, a nd inspection information, if necessary.

Determination of applicability of §265.1032

Under 40 CFR 265.1035(f), owner/operators are requir ed to record the following information in

the unit operating record used to determine the a pplicability of §2 65.1032 process vent standards.

(i) Data item:

The data item for this requirement includes:

• Up-to-date information and data used to determine whether or not a process vent is

subject to the requirements in §265.1032 including supporting documentation as required

by §265.1034(d)(2) when application of th e knowledge of the nature of the hazardous

waste stream or the process by which it was produced is used.

(ii) Respondent activities:

To comply with §265.1035(f), respondent s must perform the following activities:

• Prepare the determination of applicability;

• Reassess the determination of applicability;

• File and maintain the determination of applicability; and

• Modify the determination of applicability, if necessary.

Permitted facilities:

Regulations

Each owner/operator regulated under 40 CFR Part 264, Subpart AA is expected to read the

regulations.

Control device operation documentation

40 CFR 264.1033(j) requires owner/ operators to prepare documentation describing the operation

of control devices different from those specified in §264.1033(f), (g), and (h) and identifying process

parameters that indicate proper operation and maintenance of those control devices.

(i) Data items:

The data items for this determination include:

• Information describing the control device operation; and

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• Information on the process parameter or parame ters that will be used to indicate proper

operation and maintenance of the control device.

(ii) Respondent activities:

To comply with §264.1033(j), respondent s must perform the following activities:

• Gather information on control devi ce operation and process parameters;

• Document control device operation and process parameter information;

• Reassess control device operation documentation;

• Modify control device operation documentation, if necessary; and

• Maintain documentation at the unit (required under §264.1035(e)).

Waste determination

40 CFR 264.1034(d)(2) requires owner/operators to document waste determinations that are

based on knowledge of the waste rather than testing.

(i) Data items:

Data items required for documenting waste determ inations are not specified, but may include the

following:

• Production process information documenti ng that no organic compounds are used;

• Waste generation information documenting that the waste is generated by a process

identical to a process at the same or another unit that has previously been demonstrated

by direct measurement to generate a waste st ream having a total organic content less than

10 ppmw; and

• Prior specification analysis results on the sa me waste stream where it can be documented

that no process changes have occurred since th e specification analysis was conducted that

could affect the waste total organic concentration.

(ii) Respondent activities:

To comply with §264.1034(d)(2), responde nts must perform the following activities:

• Gather information on production processes, wa ste generation, and specification analysis;

• Document information on production processes, waste generation, and specification

analysis; and

• Maintain documentation at the unit.

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Facility operating record

Implementation schedule

Under 40 CFR 264.1035(b)(1), owner/operators of facilities that comply with the provisions of

§264.1033(a)(2) are required to record the following information in the unit operating record.

(i) Data item:

The data item for this requirement includes:

• An implementation schedule that includes da tes by which the closed-vent system and

control device will be installed and in oper ation. The schedule must also include a

rationale of why the installation cannot be completed at an earlier date;

(ii) Respondent activities:

To comply with §264.1035(b)(1), responde nts must perform the following activities:

• Prepare the implementation schedule;

• Reassess the implementation schedule;

• File and maintain the implementation schedule; and

• Modify the implementation schedule, if necessary.

Up-to-date documentation of compliance with the process vent standards in §264.1032

Under 40 CFR 264.1035(b)(2), owner/operators are required to record the following information

in the unit operating record to document up-to-date compliance with §264.1032.

(i) Data items:

The data items for this requirement include:

 Information and data identifying all aff ected process vents, annual throughput and

operating hours of each affected unit, estimated emission rates for each affected vent and

for the overall unit, and the approximate loca tion within the unit of each affected unit;

and

 Information and data supporting determin ations of vent emissions and emission

reductions achieved by add-on control devi ces based on engineering calculations or

source tests.

(ii) Respondent activities:

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To comply with §264.1035(b)(2), responde nts must perform the following activities:

• Prepare documentation of compliance;

• Reassess documentation of compliance;

• File and maintain documentation of compliance; and

• Modify documentation of compliance, if necessary.

Performance test plan

Under 40 CFR 264.1035(b)(3), owners/operators that choose to use test data to determine the

organic removal efficiency or total organic com pound concentration achieved by the control device are

required to record the following info rmation in the unit operating record.

(i) Data item:

The data item for this requirement includes:

• A performance test plan that includes the following information:

-- A description of how it is determined that the planned test is going to be

conducted when the hazardous waste manage ment unit is operating at the highest

load or capacity level reasonably expected to occur. This shall include the

estimated or design flow rate and organic content of each vent stream and define

the acceptable operating ranges of key process and control device parameters

during the test program;

-- A detailed engineering description of the closed-vent system and control device,

including:

- Manufacturer’s name and m odel number of control device;

- Type of control device;

- Dimensions of the control device;

- Capacity;

- Construction materials; and

-- A detailed description of sampling and monitoring procedures, including

sampling and monitoring locations in the system, the equipment to be used,

sampling and monitoring frequency, a nd planned analytical procedures for

sample analysis.

(ii) Respondent activities:

To comply with §264.1035(b)(3), responde nts must perform the following activities:

• Prepare performance test plan;

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• Reassess performance test plan;

• File and maintain performance test plan; and

• Modify performance test plan, if necessary.

Documentation of compliance with §264.1033

Under 40 CFR 264.1035(b)(4), owner/operators are required to record the following information

in the unit operating record to document compliance with §264.1033.

(i) Data items:

The data items for this requirement include:

 A list of all information references and s ources used in preparing the documentation;

 Records including the dates of each complia nce test required by §264.1033(k);

 If engineering calculations are used, a design analysis, specifications, drawings,

schematics, and piping and instrumentation di agrams based on the appropriate sections of

“APTI Course 415: Control of Gaseous Emi ssions” or other engineering texts acceptable

to the Regional Administrator that present basic control device design information.

Documentation provided by the control devi ce manufacturer or vendor that describes the

control device design in accordance with pa ragraphs (b)(4)(iii)(A) through (b)(4)(iii)(G)

of this section may be used;

 A statement signed and dated by the owne r/operator certifying that the operating

parameters used in the design analysis reas onably represent the conditions that exist when

the hazardous waste management unit is or w ould be operating at the highest load or

capacity level reasonably expected to occur;

 A statement signed and dated by the owner/ope rator certifying that the control device is

designed to operate at an efficiency of 95 percent or greater unless the total organic

concentration limit of §264.1032(a) is achieved at an efficiency less than 95 percent or

the total organic emission limits of §264.1032(a) for affected process vents at the unit can

be attained by a control device involving vapor recovery at an efficiency less than 95

weight percent. A statement provided by the control device manufacturer or vendor

certifying that the control equipment meets the design specifications may be used to

comply with this requirement; and

 If performance tests are used to demonstrate compliance, all test results.

(ii) Respondent activities:

To comply with §264.1035(b)(4), responde nts must perform the following activities:

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• Prepare documentation of compliance;

• Reassess documentation of compliance;

• File and maintain documentation of compliance; and

• Modify documentation of compliance, if necessary.

Design, monitoring, operation, and inspection information

Under 40 CFR 264.1035(c), owner/operators are requir ed to record the following information in

the unit operating record for each closed-vent syst em and control device required to comply with

§264.1033.

(i) Data items:

Data items for this requirement include:

 Description and date of each modification that is made to the closed-vent system or

control device design;

 Identification of operating parameter, description of monitoring device, and diagram of

monitoring sensor location or locations used to comply with §§ 264.1033(f)(1) and (f)(2);

 Monitoring, operating and inspection informa tion required by paragraphs (f) through (k)

of §264.1033;

 Date, time, and duration of each period that o ccurs while the control device is operating

when any monitored parameter exceeds the va lue established in the control device design

analysis;

 Explanation for each period recorded under pa ragraph (4) of the cause for control device

operating parameter exceeding the design valu e and the measures implemented to correct

the control device operation;

 For a carbon adsorption system operated subject to requirements specified in

§§ 264.1033(g) or 264.1033(h)(2), date when existing carbon in the control device is

replaced with fresh carbon;

 For a carbon adsorption system operated subject to requirements specified in

§264.1033(h)(1), a log recording the following information:

-- Date and time when control device is monitored for carbon breakthrough and the

monitoring device reading; and

-- Date existing carbon in control device is replaced with fresh carbon;

 Date of each control device startup and shutdown;

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 Where an owner or operator designates an y components of a closed-vent system as

unsafe to monitor pursuant to §264.1033(o), the owner or operator must record in a log

that is kept in the facility operating record : the identification of closed-vent system

components that are designated unsafe to monitor pursuant to §265.1033(o), an

explanation for each closed-vent system com ponent stating why the closed-vent system

component is unsafe to monitor, and the pl an for monitoring each closed-vent system

component; and

 When each leak is detected as specified in §264.1033(l), record the following

information:

-- The instrument identification numb er, the closed-vent system component

identification number, and the operator na me, initials, or identification number;

-- The date the leak was detected and the date of first attempt to repair the leak;

-- The date of successful repair of the leak;

-- Maximum instrument reading measured by Method 21 of 40 CFR part 60,

appendix A after it is successfully repaired or determined to be nonrepairable;

and

-- “Repair delayed” and the reason for the de lay if a leak is not repaired within 15

calendar days after discovery of the leak.

(ii) Respondent activities:

To comply with §264.1035(c), respondent s must perform the following activities:

• Prepare design, monitoring, operation, and inspection information;

• Reassess design, monitoring, operatio n, and inspection information;

• File and maintain design, monitoring, op eration, and inspection information; and

• Modify design, monitoring, operation, a nd inspection information, if necessary.

Determination of applicability of §264.1032

Under 40 CFR 264.1035(f), owner/operators are requir ed to record the following information in

the unit operating record used to determine the a pplicability of §2 64.1032 process vent standards.

(i) Data item:

The data item for this requirement includes:

• Up-to-date information and data used to determine whether or not a process vent is

subject to the requirements in §264.1032 including supporting documentation as required

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by §264.1034(d)(2) when application of th e knowledge of the nature of the hazardous

waste stream or the process by which it was produced is used.

(ii) Respondent activities:

To comply with §264.1035(f), respondent s must perform the following activities:

• Prepare determination of applicability;

• File and maintain determination of applicability;

• Reassess determination of applicability; and

• Modify determination of applicability, if necessary.

Semiannual report of control device monitoring events

40 CFR 264.1036 requires owner/ope rators with control devices that have exceeded or operated

outside of the design specifications as defined in §264.1035(c)(4) for more than 24 hours or flares that

have operated with visible emissions as defined in §264.1033(d) to submit a semiannual report to the

Regional Administrator. The report must contain the following information:

• The EPA identification number, name, and address of the unit;

• Dates when the control device exceeded or op erated outside of the design specifications

as indicated by the control device monitoring required by §264.1033(f) which were not

corrected within 24 hours;

• Dates when a flare operated with visible emissions as defined in §264.1033(d) and as

determined by Method 22 monitoring;

• The duration and cause of each control device exceedance or visible emissions; and

• Corrective measures taken for each contro l device exceedance or visible emissions.

(i) Data item:

The data item for this requirement includes:

 A semiannual report.

(ii) Respondent activities:

To comply with §264.1036, respondents must perform the following activities:

• Prepare the semiannual report; and

• Submit the semiannual report to the Regional Administrator.

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EQUIPMENT LEAKS

Interim status facilities:

Regulations

Each owner/operator regulated under 40 CFR Part 265, Subpart BB is expected to read the

regulations.

Notification to implement the alternate valve standard specified in §265.1061(a)

40 CFR 265.1061(b)(1) requires owners or operato rs that have decided to implement the

alternative standard for valves specified in §265. 1061(a) to notify the Regional Administrator.

(i) Data items:

No specific data items are to be included in this notification.

(ii) Respondent activities:

To comply with §265.1061(b)(1), responde nts must perform the following activities:

• Prepare notification; and

• Submit notification to the Regional Administrator.

Notification to discontinue implementing the altern ative valve standard specified in §265.1061(a)

40 CFR 265.1061(d) requires owners or operato rs that no longer wish to implement the

alternative standard for valves specified in §265. 1061(a) to notify the Regional Administrator.

(i) Data items:

No specific data items are to be included in this notification.

(ii) Respondent activities:

To comply with §265.1061(d), respondents must perform the following activities:

• Prepare notification; and

• Submit notification to the Regional Administrator.

Notification to implement the alternative valve standard specified in §§ 265.1062(b)(2), or

265.1062(b)(3)

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40 CFR 265.1062(a)(2) requires owners or operato rs that have decided to implement the

alternative standard for valves specified in §§ 265.1 062(b)(2), or 265.1062(b)(3) to notify the Regional

Administrator.

(i) Data items:

No specific data items are to be included in this notification.

(ii) Respondent activities:

To comply with §265.1062(a)(2), respondent s must perform the following activities:

• Prepare notification; and

• Submit notification to the Regional Administrator.

Non-hazardous waste documentation

40 CFR 265.1063(d)(3) requires owners or opera tors that determining that each piece of

equipment does or does not contain hazardous waste with organic concentration that equals or exceeds 10

percent waste to document the determination if it was based on knowledge rather than testing.

(i) Data items:

Data items required for documenting waste determ inations are not specified, but may include the

following:

• Production process information documenti ng that no organic compounds are used;

• Waste generation information documenting that the waste is generated by a process

identical to a process at the same or another unit that has previously been demonstrated

by direct measurement to generate a waste st ream having a total organic content less than

10 ppmw; and

• Prior specification analysis results on the sa me waste stream where it can be documented

that no process changes have occurred since th e specification analysis was conducted that

could affect the waste total organic concentration.

(ii) Respondent activities:

To comply with §265.1063(d)(3), responde nts must perform the following activities:

• Gather information on production processes, wa ste generation, and specification analysis;

• Document information on production processes, waste generation, and specification

analysis; and

• Maintain documentation at the unit.

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Facility operating record

Equipment record

Under 40 CFR 265.1064(b)(1), owner/operators are required to record the following information

in the unit operating record for each piece of equipment to which Subpart BB applies.

(i) Data items:

Data items for this requirement include:

 Equipment identification number and hazardous waste management unit identification;

 Approximate locations within the unit;

 Type of equipment;

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

 Hazardous waste state at the equipment; and

 Method of compliance with the standard.

(ii) Respondent activities:

To comply with §265.1064(b)(1), responde nts must perform the following activities:

 Prepare equipment record;

 Reassess equipment record;

 File and maintain equipment record; and

 Modify equipment record, if necessary.

Implementation schedule

Under 40 CFR 265.1064(b)(2), owner/operators of facilities that comply with the provisions of

§265.1033(a)(2) are required to record the following information in the unit operating record.

(i) Data item:

The data item for this requirement includes:

• An implementation schedule that includes da tes by which the closed-vent system and

control device will be installed and in oper ation. The schedule must also include a

rationale of why the installation cannot be completed at an earlier date.

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(ii) Respondent activities:

To comply with §265.1064(b)(2), responde nts must perform the following activities:

 Prepare implementation schedule;

 Reassess implementation schedule;

 File and maintain implementation schedule; and

 Modify implementation schedule, if necessary.

Performance test plan

Under 40 CFR 265.1064(b)(3), owner/operators that choose to use test data to demonstrate the

organic removal efficiency or total organic com pound concentration achieved by the control device are

required to record the following info rmation in the unit operating record.

(i) Data item:

The data item for this requirement includes:

• A performance test plan as specified in §265.1035(b)(3).

(ii) Respondent activities:

To comply with §265.1064(b)(3), responde nts must perform the following activities:

 Prepare performance test plan;

 Reassess performance test plan;

 File and maintain performance test plan; and

 Modify performance test plan, if necessary.

Documentation of compliance with §265.1060

Under 40 CFR 265.1064(b)(4), owner/operators are required to record the following information

in the unit operating record to document compliance with §265.1060.

(i) Data item:

The data item for this requirement includes:

• Detailed design documentation or performance test results specified in §265.1035(b)(4).

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(ii) Respondent activities:

To comply with §265.1064(b)(4), responde nts must perform the following activities:

 Prepare documentation of compliance;

 Reassess documentation of compliance;

 File and maintain documentation of compliance; and

 Modify documentation of compliance, if necessary.

Leak inspection log

Under 40 CFR 265.1064(d), owner/operators are requir ed to record the following information in

the unit operating record when each leak is detected as specified in §§ 265.1 052, 265.1053, 265.1057, and

265.1058.

(i) Data item:

The data item for this requirement includes:

• An inspection log that incl udes the following information:

-- Instrument and operator identificati on numbers and the equipment identification

number;

-- The date evidence of a potentia l leak was found in accordance with

§265.1058(a);

-- The date the leak was detected and th e dates of each attempt to repair the leak;

-- Repair methods applied in each attempt to repair the leak;

-- “Above 10,000” if the maximum instrument reading measured by the methods

specified in §265.1063(b) after each repair attempt is equal to or greater than

10,000 ppm;

-- “Repair delayed” and the reason for the de lay if a leak is not repaired within 15

calendar days after discovery of the leak;

-- Documentation supporting the delay of repair of a valve in compliance with

§265.1059(c);

-- The signature of the owner or operato r (or designate) whose decision it was that

repair could not be effected wit hout a hazardous waste management unit

shutdown;

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-- The expected date of successful repair of the leak if a leak is not repaired within

15 calendar days; and

-- The date of successful repair of the leak.

(ii) Respondent activities:

To comply with §265.1064(d), respondents must perform the following activities:

 Prepare leak inspection log;

 Reassess leak inspection log;

 File and maintain leak inspection log; and

 Modify leak inspection log, if necessary.

Design, monitoring, operation, and inspection information

Under 40 CFR 265.1064(e), owner/operators are requir ed to record the following information in

the unit operating record for each closed-vent syst em and control device required to comply with

§265.1060.

(i) Data items:

Data item for this requirement include:

 Description and date of each modification that is made to the closed-vent system or

control device design;

 Identification of operating parameter, description of monitoring device, and diagram of

monitoring sensor location or locations used to comply with §§ 265.1033(f)(1) and (f)(2);

 Monitoring, operating and inspection informa tion required by paragraphs (f) through (j)

of §265.1033;

 Date, time, and duration of each period that o ccurs while the control device is operating

when any monitored parameter exceeds the va lue established in the control device design

analysis;

 Explanation for each period recorded under pa ragraph (3) of the cause for control device

operating parameter exceeding the design valu e and the measures implemented to correct

the control device operation;

 For a carbon adsorption system operated subject to requirements specified in

§§ 265.1033(g) or 265.1033(h)(2), date when existing carbon in the control device is

replaced with fresh carbon;

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 For a carbon adsorption system operated subject to requirements specified in

§265.1033(h)(1), a log recording the following information:

-- Date and time when control device is monitored for carbon breakthrough and the

monitoring device reading; and

-- Date when existing carbon in the control device is replaced with fresh carbon;

and

 Date of each control device startup and shutdown.

(ii) Respondent activities:

To comply with §265.1064(e), respondent s must perform the following activities:

 Prepare design, monitoring, operation, and inspection information;

 Reassess design, monitoring, operatio n, and inspection information;

 File and maintain design, monitoring, op eration, and inspection information; and

 Modify design, monitoring, operation, a nd inspection information, if necessary.

Monitoring and inspection information for other control devices

Under 40 CFR 265.1064(f), owner/operators are requir ed to record the following information in

the unit operating record for a control device other th an a thermal vapor incinerator, catalytic vapor

incinerator, flare, boiler, process heater, condenser, or carbon adsorption system.

(i) Data item:

The data item for this requirement includes:

• Monitoring and inspection information indi cating proper operation and maintenance of

the control device.

(ii) Respondent activities:

To comply with §265.1064(f), respondent s must perform the following activities:

 Prepare monitoring and inspection information;

 Reassess monitoring and inspection information;

 File and maintain monitoring and inspection information; and

 Modify monitoring and inspection information, if necessary.

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Equipment log

Under 40 CFR 265.1064(g), owner/operators are requir ed to record the following information in

the unit operating record for all equipment subject to §§ 265.1052 through §265.1060.

(i) Data item:

The data item for this requirement includes:

• A log recording the following information:

-- A list of identification numbers (excep t welded fittings) for equipment subject to

the standards of Subpart BB;

-- A list of identification numbers for equipment that the owner or operator elects to

designate for no detectable emissions, as indicated by an instrument reading of

less than 500 ppm above background, u nder §§ 265.1052(e), 265.1053(i), and

265.1057(f);

-- Signed designation of this equipment as subject to the requirements of

§§ 265.1052(e), 265.1053(i) , and 265.1057(f) by the owner or operator;

-- A list of equipment identification numbe rs for pressure relief devices required to

comply with §265.1054(a);

-- The dates of each compliance test required in §§ 265.1052(e), 265.1053(i),

265.1054, and 265.1057(f);

-- The background level measured during each compliance test;

-- The maximum instrument reading measured at the equipment during each

compliance test;

-- A list of identification numbers for equipment in vacuum service; and

-- Identification, either by list or locati on (area or group) of equipment that contains

or contacts hazardous waste with an organic concentration of at least 10 percent

by weight for less than 300 hours per calendar year.

(ii) Respondent activities:

To comply with §265.1064(g), respondents must perform the following activities:

 Prepare equipment log;

 Reassess equipment log;

 File and maintain equipment log; and

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 Modify equipment log, if necessary.

Valve log for all valves subject to §265.1057(g) and (h)

Under 40 CFR 265.1064(h), owner/operators are requir ed to record the following information in

the unit operating record.

(i) Data item:

The data item for this requirement includes:

 A log for all valves subject to §265.1057(g) and (h) that includes the following

information:

-- A list of identification numbers for valves that are designated as unsafe to

monitor, an explanation for each valve sta ting why the valve is unsafe to monitor,

and the plan for monitoring each valve; and

-- A list of identification numbers for valves that are designated as difficult to

monitor, an explanation for each valve stating why the valve is difficult to

monitor, and the planned schedule for monitoring each valve.

(ii) Respondent activities:

To comply with §265.1064(h), respondents must perform the following activities:

 Prepare valve log;

 Reassess valve log;

 File and maintain valve log; and

 Modify valve log, if necessary.

Valve log for all valves subject to §265.1062

Under 40 CFR 265.1064(i), owner/operators are requir ed to record the following information in

the unit operating record.

(i) Data item:

The data item for this requirement includes:

• For all valves complying with §265.1062, a log containing the following information:

-- A schedule for monitoring; and

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-- The percent of valves found l eaking during each monitoring period.

(ii) Respondent activities:

To comply with §265.1064(i), respondent s must perform the following activities:

 Prepare valve log;

 Reassess valve log;

 File and maintain valve log; and

 Modify valve log, if necessary.

Criteria log

Under 40 CFR 265.1064(j), owner/operators are requir ed to record the following information in

the unit operating record.

(i) Data item:

The data item for this requirement includes:

• A criteria log containing the following information:

-- Criteria required in §265.1052(d)(5)(ii) and §265.1053(e)(2) and an explanation

of the design criteria; and

-- Any changes to these criteria and the reasons for these changes.

(ii) Respondent activities:

To comply with §265.1064(j), respondent s must perform the following activities:

 Prepare criteria log;

 Reassess criteria log;

 File and maintain criteria log; and

 Modify criteria log, if necessary.

Exemption log

Under 40 CFR 265.1064(k), owner/operators are requir ed to record the following information in

the unit operating record.

(i) Data item:

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The data item for this requirement includes:

• An exemption log containing the following information:

-- An analysis determining the design capacity of the hazardous waste management

unit;

-- A statement listing the hazardous wast e influent to and effluent from each

hazardous waste management unit subject to the requirements in §§ 265.1052

through 265.1060 and an an alysis determining whether these hazardous wastes

are heavy liquids; and

-- An up-to-date analysis and the supporting information and data used to determine

whether or not equipment is subject to the requirements in §§ 265.1052 through

265.1060. The record shall include supporting documentation as required by

§265.1063(d)(3) when application of the knowledge of the nature of the

hazardous waste stream or the process by which it was produced is used.

(ii) Respondent activities:

To comply with §265.1064(k), respondents must perform the following activities:

 Prepare exemption log;

 Reassess exemption log;

 File and maintain exemption log; and

 Modify exemption log, if necessary.

Permitted facilities:

Regulations

Each owner/operator regulated under Part 264 is expected to read the regulations.

Notification to implement the alternate valve standard specified in §264.1061(a)

40 CFR 264.1061(b)(1) requires owners or operato rs that have decided to implement the

alternative standard for valves specified in §264. 1061(a) to notify the Regional Administrator.

(i) Data items:

No specific data items are to be included in this notification.

(ii) Respondent activities:

To comply with §264.1061(b)(1), responde nts must perform the following activities:

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• Prepare notification; and

• Submit notification to the Regional Administrator.

Notification to discontinue implementing the altern ative valve standard specified in §264.1061(a)

40 CFR 264.1061(d) requires owners or operato rs that no longer wish to implement the

alternative standard for valves specified in §264. 1061(a) to notify the Regional Administrator.

(i) Data items:

No specific data items are to be included in this notification.

(ii) Respondent activities:

To comply with §264.1061(d), respondents must perform the following activities:

• Prepare notification; and

• Submit notification to the Regional Administrator.

Notification to implement the alternative valve standard specified in §§ 264.1062(b)(2), or

§264.1062(b)(3)

40 CFR 264.1062(a)(2) requires owners or operato rs that have decided to implement the

alternative standard for valves specified in §§ 264 .1062(b)(2) or 264.1062(b)(3) to notify the Regional

Administrator.

(i) Data items:

No specific data items are to be included in this notification.

(ii) Respondent activities:

To comply with §264.1062(a)(2), respondent s must perform the following activities:

• Prepare notification; and

• Submit notification to the Regional Administrator.

Non-hazardous waste documentation

40 CFR 264.1063(d)(3) requires owners or opera tors that determining that each piece of

equipment does or does not contain hazardous waste with organic concentration that equals or exceeds 10

percent waste to document the determination if it was based on knowledge rather than testing.

(i) Data items:

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Data items required for documenting waste determ inations are not specified, but may include the

following:

• Production process information documenti ng that no organic compounds are used;

• Waste generation information documenting that the waste is generated by a process

identical to a process at the same or another unit that has previously been demonstrated

by direct measurement to generate a waste st ream having a total organic content less than

10 ppmw; and

• Prior specification analysis results on the sa me waste stream where it can be documented

that no process changes have occurred since th e specification analysis was conducted that

could affect the waste total organic concentration.

(ii) Respondent activities:

To comply with §264.1063(d)(3), responde nts must perform the following activities:

• Gather information on production processes, wa ste generation, and specification analysis;

• Document information on production processes, waste generation, and specification

analysis; and

• Maintain documentation at the unit.

Facility operating record

Equipment record

Under 40 CFR 264.1064(b)(1), owner/operators are required to record the following information

in the unit operating record for each piece of equipment to which Subpart BB applies.

(i) Data items:

Data items for this requirement include:

 Equipment identification number and hazardous waste management unit identification;

 Approximate locations within the unit;

 Type of equipment;

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

 Hazardous waste state at the equipment; and

 Method of compliance with the standard.

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(ii) Respondent activities:

To comply with §264.1064(b)(1), responde nts must perform the following activities:

 Prepare equipment record;

 Reassess equipment record;

 File and maintain equipment record; and

 Modify equipment record, if necessary.

Implementation schedule

Under 40 CFR 264.1064(b)(2), owner/operators of facilities that comply with the provisions of

§264.1033(a)(2) are required to record the following information in the unit operating record.

(i) Data item:

The data item for this requirement includes:

• An implementation schedule that includes da tes by which the closed-vent system and

control device will be installed and in oper ation. The schedule must also include a

rationale of why the installation cannot be completed at an earlier date.

(ii) Respondent activities:

To comply with §264.1064(b)(2), responde nts must perform the following activities:

 Prepare implementation schedule;

 Reassess implementation schedule;

 File and maintain implementation schedule; and

 Modify implementation schedule, if necessary.

Performance test plan

Under 40 CFR 264.1064(b)(3), owner/operators that choose to use test data to demonstrate the

organic removal efficiency or total organic com pound concentration achieved by the control device are

required to record the following info rmation in the unit operating record.

(i) Data item:

The data item for this requirement includes:

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• A performance test plan as specified in §264.1035(b)(3).

(ii) Respondent activities:

To comply with §264.1064(b)(3), responde nts must perform the following activities:

 Prepare performance test plan;

 Reassess performance test plan;

 File and maintain performance test plan; and

 Modify performance test plan, if necessary.

Documentation of compliance with §264.1060

Under 40 CFR 264.1064(b)(4), owner/operators are required to record the following information

in the unit operating record.

(i) Data item:

The data item for this requirement includes:

• Documentation of compliance with §264.10 60, including detailed design documentation

or performance test results specified in §264.1035(b)(4).

(ii) Respondent activities:

To comply with §264.1064(b)(4), responde nts must perform the following activities:

 Prepare documentation of compliance;

 Reassess documentation of compliance;

 File and maintain documentation of compliance; and

 Modify documentation of compliance, if necessary.

Leak inspection log

Under 40 CFR 264.1064(d), owner/operators are requir ed to record the following information in

the unit operating record.

(i) Data item:

The data item for this requirement includes:

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• When each leak is detected as specifi ed in §§ 264.1052, 26 4.1053, 264.1057, and

264.1058, an inspection log that includes the following information:

-- Instrument and operator identificati on numbers and the equipment identification

number;

-- The date evidence of a potentia l leak was found in accordance with

§264.1058(a);

-- The date the leak was detected and th e dates of each attempt to repair the leak;

-- Repair methods applied in each attempt to repair the leak;

-- “Above 10,000” if the maximum instrument reading measured by the methods

specified in §264.1063(b) after each repair attempt is equal to or greater than

10,000 ppm;

-- “Repair delayed” and the reason for the de lay if a leak is not repaired within 15

calendar days after discovery of the leak;

-- Documentation supporting the delay of repair of a valve in compliance with

§264.1059(c);

-- The signature of the owner or operato r (or designate) whose decision it was that

repair could not be effected wit hout a hazardous waste management unit

shutdown;

-- The expected date of successful repair of the leak if a leak is not repaired within

15 calendar days; and

-- The date of successful repair of the leak.

(ii) Respondent activities:

To comply with §264.1064(d), respondents must perform the following activities:

 Prepare leak inspection log;

 Reassess leak inspection log;

 File and maintain leak inspection log; and

 Modify leak inspection log, if necessary.

Design, monitoring, operation, and inspection information

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Under 40 CFR 264.1064(e), owner/operators are requir ed to record the following information in

the unit operating record for each closed-vent syst em and control device required to comply with

§264.1060.

(i) Data items:

Data items for this requirement include:

 Description and date of each modification that is made to the closed-vent system or

control device design;

 Identification of operating parameter, description of monitoring device, and diagram of

monitoring sensor location or locations used to comply with §§ 264.1033(f)(1) and (f)(2);

 Monitoring, operating and inspection informa tion required by paragraphs (f) through (k)

of §264.1033;

 Date, time, and duration of each period that o ccurs while the control device is operating

when any monitored parameter exceeds the va lue established in the control device design

analysis;

 Explanation for each period recorded under pa ragraph (4) of the cause for control device

operating parameter exceeding the design valu e and the measures implemented to correct

the control device operation;

 For a carbon adsorption system operated subject to requirements specified in

§§ 264.1033(g) or 264.1033(h)(2), date when existing carbon in the control device is

replaced with fresh carbon;

 For a carbon adsorption system operated subject to requirements specified in

§264.1033(h)(1), a log recording the following information:

-- Date and time when control device is monitored for carbon breakthrough and the

monitoring device reading; and

-- Date when existing carbon in the control device is replaced with fresh carbon;

and

 Date of each control device startup and shutdown.

(ii) Respondent activities:

To comply with §264.1064(e), respondent s must perform the following activities:

 Prepare design, monitoring, operation, and inspection information;

 Reassess design, monitoring, operatio n, and inspection information;

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 File and maintain design, monitoring, op eration, and inspection information; and

 Modify design, monitoring, operation, a nd inspection information, if necessary.

Monitoring and inspection information for other control devices

Under 40 CFR 264.1064(f), owner/operators are requir ed to record the following information in

the unit operating record for a control device other th an a thermal vapor incinerator, catalytic vapor

incinerator, flare, boiler, process heater, condenser, or carbon adsorption system.

(i) Data items:

Data items for this requirement include:

• Recordkeeping information specified by the Regional Administrator.

(ii) Respondent activities:

To comply with §264.1064(f), respondent s must perform the following activities:

 Prepare monitoring and inspection information;

 Reassess monitoring and inspection information;

 File and maintain monitoring and inspection information; and

 Modify monitoring and inspection information, if necessary.

Equipment log

Under 40 CFR 264.1064(g), owner/operators are requir ed to record the following information in

the unit operating record.

(i) Data items:

Data items for this requirement include:

• A log recording the following information for all equipment subject to §§ 264.1052

through 264.1060:

-- A list of identification numbers (excep t welded fittings) for equipment subject to

the standards of Subpart BB;

-- A list of identification numbers for equipment that the owner or operator elects to

designate for no detectable emissions, as indicated by an instrument reading of

less than 500 ppm above background, u nder §§ 264.1052(e), 264.1053(i), and

264.1057(f);

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-- Signed designation of this equipment as subject to the requirements of

§§ 264.1052(e), 264.1053(i) , and 264.1057(f) by the owner or operator;

-- A list of equipment identification numbe rs for pressure relief devices required to

comply with §264.1054(a);

-- The dates of each compliance test required in §§ 264.1052(e), 264.1053(i),

264.1054, and 264.1057(f);

-- The background level measured during each compliance test;

-- The maximum instrument reading measured at the equipment during each

compliance test;

-- A list of identification numbers for equipment in vacuum service; and

-- Identification either by list or location (area or group) of equipment that contains

or contacts hazardous waste with an organic concentration of at least 10 percent

by weight for less than 300 hours per calendar year.

(ii) Respondent activities:

To comply with §264.1064(g), respondents must perform the following activities:

 Prepare equipment log;

 Reassess equipment log;

 File and maintain equipment log; and

 Modify equipment log, if necessary.

Valve log for all valves subject to §264.1057(g) and (h)

Under 40 CFR 264.1064(h), owner/operators are requir ed to record the following information in

the unit operating record.

(i) Data item:

The data item for this requirement includes:

• A log for valves subject to §264.1057(g) and (h), including the following:

-- List of identification numbers for va lves designated as unsafe to monitor, an

explanation for each valve stating why th e valve is unsafe to monitor, and the

plan for monitoring each valve; and

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-- List of identification numbers for va lves designated as difficult to monitor, an

explanation for each valve stating why the valve is difficult to monitor, and the

planned schedule for monitoring each valve.

(ii) Respondent activities:

To comply with §264.1064(h), respondents must perform the following activities:

 Prepare valve log;

 Reassess valve log;

 File and maintain valve log; and

 Modify valve log, if necessary.

Valve log for all valves subject to §264.1062

Under 40 CFR 264.1064(i), owner/operators are requir ed to record the following information in

the unit operating record.

(i) Data item:

The data item for this requirement includes:

• For all valves complying with §264.1062, a log containing the following information:

-- A schedule for monitoring; and

-- The percent of valves found l eaking during each monitoring period.

(ii) Respondent activities:

To comply with §264.1064(i), respondent s must perform the following activities:

 Prepare valve log;

 Reassess valve log;

 File and maintain valve log; and

 Modify valve log, if necessary.

Criteria log

Under 40 CFR 264.1064(j), owner/operators are requir ed to record the following information in

the unit operating record.

(i) Data item:

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The data item for this requirement includes:

• A criteria log containing the following information:

-- Criteria required in §§ 264.1052(d)(5)( ii) and 264.1053(e)(2) and an explanation

of the design criteria; and

-- Any changes to these criteria and the reasons for these changes.

(ii) Respondent activities:

To comply with §264.1064(j), respondent s must perform the following activities:

 Prepare criteria log;

 Reassess criteria log;

 File and maintain criteria log; and

 Modify criteria log, if necessary.

Exemption log

Under 40 CFR 264.1064(k), owner/operators are requir ed to record the following information in

the unit operating record.

(i) Data item:

The data item for this requirement includes:

• An exemption log containing the following information:

-- An analysis determining design cap acity of the hazardous waste management

unit;

-- A statement listing hazardous waste infl uent to and effluent from each hazardous

waste management unit subject to §§ 264.1052 through 264.1060 and an analysis

determining whether these hazardous wastes are heavy liquids; and

-- An up-to-date analysis and the supporting information and data used to determine

whether or not equipment is subject to the requirements in §§ 264.1052 through

264.1060. The record shall include supporting documentation as required by

§264.1063(d)(3) when application of the knowledge of the nature of the

hazardous waste stream or the process by which it was produced is used.

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(ii) Respondent activities:

To comply with §264.1064(k), respondents must perform the following activities:

 Prepare exemption log;

 Reassess exemption log;

 File and maintain exemption log; and

 Modify exemption log, if necessary.

Semiannual report of control device monitoring events

40 CFR 264.1065 requires owner/ope rators with control devices that have exceeded or operated

outside of the design specifications as defined in §264.1035(c)(4) for more than 24 hours or flares that

have operated with visible emissions as defined in §264.1033(d) to submit a semiannual report to the

Regional Administrator. The report must contain the following information:

• The EPA identification number, name, and address of the unit;

• For each month during the semiannual reporting period:

-- The equipment identification number of each valve for which a leak was not

repaired as required in §264.1057(d);

-- The equipment identification number of each pump for which a leak was not

repaired as required in §§ 264.1052(c) and (d)(6); and

-- The equipment identification number of each compressor for which a leak was

not repaired as required in §264.1053(g);

• Dates of hazardous waste management un it shutdowns that occurred within the

semiannual reporting period; and

• For each month during the semiannual reportin g period, dates when the control device

installed as required by §§ 264.1052, 264.1 053, 264.1054, or 264.1055 exceeded or

operated outside the design specifications a nd was not corrected within 24 hours, the

duration and cause of each exceedance, and any corrective measures taken.

(i) Data item:

The data item for this requirement includes:

 A semiannual report

(ii) Respondent activities:

To comply with §264.1065, respondents must perform the following activities:

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• Prepare the semiannual report; and

• Submit the semiannual report to the Regional Administrator.

CONTAINMENT BUILDINGS

Interim status facilities:

Regulations

Each owner/operator regulated under 40 CFR Part 265, Subpart DD is expected to read the

regulations.

Demonstration that unit meets the standards of Subpart DD

Under §265.1101(b)(4), for existing units other th an 90-day generator units, EPA may delay the

secondary containment requirement for up to two year s, based on a demonstration by the owner/operator

that the unit substantially meets the standards of this Subpart. In making a demonstration, the

owner/operator must meet the requireme nts of §265.1101(b)(4)(i) and (ii).

(i) Data item:

The data item for this requirement includes:

• A demonstration that the unit substantially meets the standards of Subpart DD, if the

owner/operator wants the secondary containm ent requirement to be delayed. The

demonstration must include:

-- Written notice of the request, describi ng the unit and its opera ting practices with

specific reference to the performance of existing containment systems and

specific plans for retrofitting the unit with secondary containment;

-- Response to comments from the Regional Administrator; and

-- Fulfillment of the terms of the revised plan, if such plans are approved by EPA.

(ii) Respondent activity:

To comply with §265.1101(b)(4), responde nts must perform the following activity:

• Demonstrate that the unit substantially m eets the standards of Subpart DD, if the

owner/operator wants the secondary containmen t requirement to be delayed, as required

by or §265.1101(b)(4).

Certification and response procedures

Pursuant to §265.1101(c)(2 ), owner/operators of all containm ent units placed into operation prior

to the effective date of the rule must obtain and maintain in the operating record (on-site files for

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generators who are not formally required to have operating records) a certification by a qualified

registered professional engineer. The certification must certify that the containment building design

meets the requirements of §265.1101(a) through (c). Throughout the active life of the containment

building, if the owner/operator detects a condition that could lead to or has caused a release of hazardous

waste, s/he must repair the condition promptly, in accordance with the proce dures in §265.1101(c)(3).

The owner/operator must also inspect and record in the unit 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 su rrounding the containment building to detect signs of releases of

hazardous waste, as required by §265.1101(c)(4).

(i) Data items:

Data items for this requirement include:

• Certification by a qualified registered prof essional engineer that the containment building

design meets the requirements of §265.1101(a) through (c);

• Upon the owner/operator’s detecting a condition that has caused a release:

-- A record of discovery of the release into the unit operating record;

-- A schedule for accomplishing cleanup and repairs;

-- Notification to the Regional Administrator of the condition within 7 days after

the discovery of the condition;

-- A written notice with a description of the steps taken to repair the containment

building, and a schedule for accomplishing the work; and

-- Notification to the Regional Administrator in writing and a verification signed by

a qualified, registered professional engin eer that the repairs and cleanup have

been completed according to the writte n plan submitted in accordance with

paragraph (c)(3)(i)(D) of this section;

• Data from monitoring and leak detection e quipment, the containment building, and the

area immediately surrounding the containment building.

(ii) Respondent activities:

To comply with §265.1101(c), respondent s must perform the following activities:

• Obtain a certification by a qualified regist ered professional engineer and place this

certification in the unit’s operating r ecord, as required by §265.1101(c)(2);

• Upon detecting a condition that has caused a release, the owner/operator must perform

the following activities, as required by §265.1101(c)(3)(i):

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-- Enter a record of discovery of the release into the unit’s operating record, as

required by §265.1101(c)(3)(i)(A);

-- Establish a schedule for accomplishing cleanup and repairs, as required by

§265.1101(c)(3)(i)(C);

-- Notify the Regional Administrator of the condition within 7 days after the

discovery of the condition, as required by §265.1101(c)(3)(i)(D);

-- Provide to EPA within 14 days a wr itten notice with a description of the steps

taken to repair the containment build ing, and a schedule for accomplishing the

work, as required by §265.1101(c)(3)(i)(D); and

-- Upon completing all repairs and cleanup, notify the Regional Administrator in

writing and provide a verification signed by a qualified, registered professional

engineer that the repairs and cleanup have been completed according to the

written plan submitted in accordance with paragraph (c)(3)(i)(D) of this section,

as required by §265.1101(c)(3)(i)(D)(iii);

• Inspect and record in the unit’s operating r ecord, at least once every seven days, data

from monitoring and leak detection equipment, the containment building, and the area

immediately surrounding the containment building, as required by §265.1101(c)(4).

Operating procedures for areas without secondary containment

Under 40 CFR 265.1101(d)(3), owners/operators of containment buildings that contain areas with

and without secondary containment must maintain in the unit’s operating log a written description of the

operating procedures used to maintain the inte grity of areas without secondary containment.

(i) Data item:

The data item for this requirement includes:

• A written description of the operating procedures used to ma intain the integrity of areas

without secondary containment.

(ii) Respondent activity:

To comply with §265.1101(d)(3), responde nts must perform the following activity:

• Maintain in the unit’s operating log a writte n description of the operating procedures used

to maintain the integrity of areas without secondary containment, as required by

§265.1101(d)(3).

Demonstration for exemption from secondary containment requirements

Under 40 CFR 265.1101(e), the owner/operator of a permitted containment building may obtain a

waiver from secondary containment from EPA. In orde r to obtain this waiver, the owner/operator has to

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demonstrate that the only free liquids in the unit are limited amounts of dust suppression liquids required

to meet occupational health and safety requirements, or that containment of managed wastes and liquids

can be assured without a secondary containment system.

(i) Data item:

The data item for this requirement includes:

• A demonstration that the only free liquids in the unit are limited amounts of dust

suppression liquids required to meet occupationa l health and safety requirements and that

containment of managed wastes and li quids can be assured without a secondary

containment system, if applicable.

(ii) Respondent activity:

To comply with §265.1101(e), respondents must perform the following activity:

• Demonstrate that only free liquids in the unit are limited amounts of dust suppression

liquids and that containment of managed wastes and liquids can be assured without a

containment system, if the owner/operator wants EPA to waive secondary containment

requirements for a permitted containment building, as provided by §265.1101(e).

Permitted facilities:

Regulations

Each owner/operator regulated under 40 CFR Part 264, Subpart DD is expected to read the

regulations.

Demonstration that unit meets the standards of Subpart DD

Under §264.1101(b)(4), for existing units other th an 90-day generator units, EPA may delay the

secondary containment requirement for up to two year s, based on a demonstration by the owner/operator

that the unit substantially meets the standards of this Subpart. In making a demonstration, the

owner/operator must meet the requireme nts of §264.1101(b)(4)(i) and (ii).

(i) Data item:

The data item for this requirement includes:

• A demonstration that the unit substantially meets the standards of Subpart DD, if the

owner/operator wants the secondary containm ent requirement to be delayed. The

demonstration must include:

-- Written notice of the request, describi ng the unit and its opera ting practices with

specific reference to the performance of existing containment systems and

specific plans for retrofitting the unit with secondary containment;

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-- Response to comments from the Regional Administrator; and

-- Fulfillment of the terms of the revised plan, if such plans are approved by EPA.

(ii) Respondent activity:

To comply with §264.1101(b)(4), responde nts must perform the following activity:

• Demonstrate that the unit substantially m eets the standards of Subpart DD, if the

owner/operator wants the secondary containmen t requirement to be delayed, as required

by or §264.1101(b)(4).

Certification and response procedures

Pursuant to §264.1101(c)(2 ), owner/operators of all containm ent units placed into operation prior

to the effective date of the rule must obtain and maintain in the operating record (on-site files for

generators who are not formally required to have operating records) a certification by a qualified

registered professional engineer. The certification must certify that the containment building design

meets the requirements of §§264.1101(a) through (c). Throughout the active life of the containment

building, if the owner/operator detects a condition that could lead to or has caused a release of hazardous

waste, s/he must repair the condition promptly, in accordance with the proce dures in §264.1101(c)(3).

The owner/operator must also inspect and record in the unit 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 su rrounding the containment building to detect signs of releases of

hazardous waste, as required by §264.1101(c)(4).

(i) Data items:

Data items for this requirement include:

• Certification by a qualified registered prof essional engineer that the containment building

design meets the requirements of §264.1101(a) through (c);

• Upon the owner/operator’s detecting a condition that has caused a release:

-- A record of discovery of the release into the unit operating record;

-- A schedule for accomplishing cleanup and repairs;

-- Notification to the Regional Administrator of the condition within 7 days after

the discovery of the condition;

-- A written notice with a description of the steps taken to repair the containment

building, and a schedule for accomplishing the work; and

-- Notification to the Regional Administrator in writing and a verification signed by

a qualified, registered professional engin eer that the repairs and cleanup have

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been completed according to the writte n plan submitted in accordance with

paragraph (c)(3)(i)(D) of this section; and

• Data from monitoring and leak detection e quipment, the containment building, and the

area immediately surrounding the containment building.

(ii) Respondent activities:

To comply with §264.1101(c), respondent s must perform the following activities:

• Obtain a certification by a qualified regist ered professional engineer and place this

certification in the unit’s operating r ecord, as required by §264.1101(c)(2);

• Upon detecting a condition that has caused a release, the owner/operator must perform

the following activities, as required by §264.1101(c)(3)(i):

-- Enter a record of discovery of the release into the unit’s operating record, as

required by §264.1101(c)(3)(i)(A);

-- Establish a schedule for accomplishing cleanup and repairs, as required by

§264.1101(c)(3)(i)(C);

-- Notify the Regional Administrator of the condition within 7 days after the

discovery of the condition, as required by §264.1101(c)(3)(i)(D);

-- Provide to EPA within 14 days a wr itten notice with a description of the steps

taken to repair the containment build ing, and a schedule for accomplishing the

work, as required by §264.1101(c)(3)(i)(D); and

-- Upon completing all repairs and cleanup, notify the Regional Administrator in

writing and provide a verification signed by a qualified, registered professional

engineer that the repairs and cleanup have been completed according to the

written plan submitted in accordance with paragraph (c)(3)(i)(D) of this section,

as required by §264.1101(c)(3)(i)(D)(iii); and

• Inspect and record in the unit’s operating r ecord, at least once every seven days, data

from monitoring and leak detection equipment, the containment building, and the area

immediately surrounding the containment building, as required by §264.1101(c)(4).

Operating procedures for areas without secondary containment

Under 40 CFR 264.1101(d)(3), owners/operators of containment buildings that contain areas with

and without secondary containment must maintain in the unit’s operating log a written description of the

operating procedures used to maintain the inte grity of areas without secondary containment.

(i) Data item:

The data item for this requirement includes:

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• A written description of the operating procedures used to ma intain the integrity of areas

without secondary containment.

(ii) Respondent activity:

To comply with §264.1101(d)(3), responde nts must perform the following activities:

• Maintain in the unit’s operating log a writte n description of the operating procedures used

to maintain the integrity of areas without secondary containment, as required by

§264.1101(d)(3).

Demonstration for exemption from secondary containment requirements

Under 40 CFR 264.1101(e), the owner/operator of a permitted containment building may obtain a

waiver from secondary containment from EPA. In orde r to obtain this waiver, the owner/operator has to

demonstrate that the only free liquids in the unit are limited amounts of dust suppression liquids required

to meet occupational health and safety requirements, or that containment of managed wastes and liquids

can be assured without a secondary containment system.

(i) Data item:

The data item for this requirement includes:

• A demonstration that the only free liquids in the unit are limited amounts of dust

suppression liquids required to meet occupationa l health and safety requirements and that

containment of managed wastes and li quids can be assured without a secondary

containment system, if applicable.

(ii) Respondent activity:

To comply with §264.1101(e), respondents must perform the following activity:

• Demonstrate that only free liquids in the unit are limited amounts of dust suppression

liquids and that containment of managed wastes and liquids can be assured without a

containment system, if the owner/operator wants EPA to waive secondary containment

requirements for a permitted containment building, as provided by §264.1101(e).

SPECIFIC HAZARDOUS WASTE RECOVERY/RECYCLING FACILITIES

Regulations

Each owner/operator regulated under 40 CFR Part 266 is expected to read the regulations.

Recyclable materials utilized for precious metal recovery

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40 CFR 266.70(c) requires those who store recycled materials regulated under 40 CFR Part 266,

Subpart F to keep records showing that they are not accumulating the materials speculatively (as defined

in 261.1(c)).

(i) Data items:

The data items for this recordkeeping requirement are:

• Information showing the volume of recycled materials regulated under 40 CFR Part 266,

Subpart F that are stored at the beginning of the calendar year;

• The amount of materials regulated under 40 CFR Part 266, Subpart F that are generated

or received during the calendar year; and

• The amount of materials regulated under 40 CFR Part 266, Subpart F that are remaining

at the end of the calendar year.

(ii) Respondent activities:

Respondents must perform the following activ ities to comply with this requirement:

• Record the information specified in 40 CFR 266.70(c); and

• File and maintain the information.

5. THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, COLLECTION

METHODOLOGY, AND INFORMATION MANAGEMENT

The following subsections discuss how EPA (and au thorized States in lieu of EPA) will collect

information, what activities EPA (and authorized Stat es in lieu of EPA) will perform once the information

has been received, and how EPA will manage the inform ation it collects. The subsections also include a

discussion of how information collection requirements affect small entities.

5(a) AGENCY ACTIVITIES

“Agency” in this section means EPA and the au thorized States in lieu of EPA. The agency

activities associated with respondent reporting are disc ussed below. This analysis assumes that there are

no agency activities associated with recordkeeping activities (i.e., filing and maintaining documentation at

the respondent’s unit) because documentation is not fo rmally submitted to the agency. Although EPA

will examine unit records during periodic inspections as activities that are a part of EPA’s overall

compliance and enforcement program, the cost associated with there ac tivities is not attributed to the

Subparts covered in this ICR. In addition, review of items submitted with Part B permit applications are

covered in the “Part B Permit Application, Permit Modification, and Special Permits ICR” (EPA ICR

Number 1573).

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TANK SYSTEMS

Interim status facilities:

Agency activities associated with requirements for owners and operators of interim status tank

systems include the following:

• Reviewing equivalent containment device information;

• Reviewing information submitted for exem ption from the 24-hour leak detection

requirement;

• Reviewing information submitted for varian ce from secondary containment requirements;

• Reviewing information submitted for exemption from 24-hour waste removal

requirement;

• Reviewing release notifications and reports;

• Reviewing major repair certifications; and

• Reviewing decontamin ation demonstrations.

Permitted facilities:

Agency activities associated with requirement s for owners and opera tors of permitted tank

systems include the following:

• Reviewing information submitted for exemption from 24-hour waste removal

requirement;

• Reviewing release notifications and reports;

• Reviewing major repair certifications; and

• Reviewing decontamin ation demonstrations.

SURFACE IMPOUNDMENTS

Interim status facilities:

Agency activities associated with requirements for owners and operators of interim status surface

impoundments include the following:

• Reviewing assessments of alternate design and operating practices and notifications of

intent to receive waste;

• Reviewing notifications of intent to receive wastes;

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• Reviewing and establishing action leakage rates;

• Reviewing Response Action Plans;

• Reviewing written action leakage rate exceedance notifications;

• Reviewing leakage reports;

• Entering RAP data into a data base;

• Reviewing and establishi ng pump operating levels;

• Reviewing contingent corrective measures plans;

• Reviewing hazardous waste removal plans;

• Reviewing extension requests; and

• Reviewing corrective action reports.

Permitted facilities:

Agency activities associated with requirements for owners and operators of permitted surface

impoundments include the following:

• Reviewing written action leakage rate exceedance notifications;

• Reviewing leakage reports;

• Entering RAP data into a data base;

• Reviewing notifications of surface impoundment removal from service.

• Reviewing contingent corrective measures plans;

• Reviewing hazardous waste removal plans;

• Reviewing extension requests; and

• Reviewing corrective action reports.

WASTE PILES

Interim status facilities:

Agency activities associated with requirements for owners and operators of interim status waste

piles include the following:

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• Reviewing exemptions from de sign and operating requirements;

• Reviewing and establishing action leakage rates;

• Reviewing Response Action Plans;

• Reviewing written action leakage rate exceedance notifications;

• Reviewing leakage reports; and

• Entering RAP data into a data base.

Permitted facilities:

Agency activities associated with requirements for owners and ope rators of permitted waste piles

include the following:

• Reviewing written action leakage rate exceedance notifications;

• Reviewing leakage reports; and

• Entering RAP data into a data base.

LAND TREATMENT

Interim status facilities:

Agency activities associated with the requirements for interim status land treatment facilities

include:

• Reviewing food-chain crop notifications; and

• Reviewing certifications of closure.

Permitted facilities:

Agency activities associated with the requirements for permitted land treatment facilities include

the following:

• Reviewing notifications of significant in creases of hazardous constituents below the

treatment zone;

• Reviewing notifications of intent to demons trate that regulated unit is not the source of

increase in hazardous constituents below the treatment zone;

• Reviewing demonstrations that regulated un it is not the source of increase in hazardous

constituents below the treatment zone;

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• Reviewing §264.280(d) demonstrations; and

• Reviewing closure certifications.

LANDFILLS

Interim status facilities:

Agency activities associated with the requirements for interim status land treatment facilities

include the following:

• Reviewing notifications of intent to receive waste;

• Reviewing demonstrations for exemption from the liner and leachate collection system

requirements;

• Reviewing information for waivers of the double liner requirements;

• Reviewing and establishing action leakage rates;

• Reviewing Response Action Plans;

• Reviewing written action leakage rate exceedance notifications;

• Reviewing leakage reports;

• Entering RAP data into a data base;

• Reviewing and establishing pump operating levels; and

• Reviewing demonstrations for placing non-hazardous liquid waste in landfills

(265.314(e)).

Permitted facilities:

Agency activities associated with the requirements for permitted land treatment facilities include

the following:

• Reviewing written action leakage rate exceedance notifications;

• Reviewing leakage reports;

• Entering RAP data into a data base; and

• Reviewing demonstrations for placing non-hazardous liquid waste in landfills

(§264.314(e)).

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INCINERATORS

Interim status facilities:

Agency activities associated with the requirements for interim status incinerators consist of

reviewing applications for certification to burn hazardous wastes F020, F021 , F022, F023, F026 and

F027.

Permitted facilities:

Agency activities associated with the requirements for permitted inci nerators consist of reviewing

notifications of intent to burn hazardous wastes F 020, F021, F022, F023, F026 and F027, and reviewing

demonstrations for exemption from emergency w aste feed cutoff system testing requirements.

THERMAL TREATMENT UNITS

Interim status facilities:

Agency activities associated with 40 CFR Part 265, Subpart P include reviewing applications to

burn hazardous wastes F020, F021, F022, F023, F0 26 and F027.

DRIP PADS

Interim status facilities:

Agency activities associated with 40 CFR Part 265, Subpart W include:

• Reviewing plans for updating, repairing, and modifying the drip pad; and

• Reviewing release notifications and reports.

Permitted facilities:

Agency activities associated with 40 CFR Part 264, Subpart W include:

• Reviewing plans for updating, repairing, and modifying the drip pad; and

• Reviewing release notifications and reports.

PROCESS VENTS

Permitted facilities:

Agency activities associated with the requirem ents for permitted facilities with process vents

include reviewing semiannual reports.

EQUIPMENT LEAKS

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Interim status facilities:

Agency activities associated with the requirements for interim status facilities with equipment

subject to Subpart BB include:

• Reviewing notifications to implement th e alternate valve standard specified in

§265.1061(a));

• Reviewing notifications to discontinue im plementing the alternate valve specified in

§265.1061(a)); and

• Reviewing notifications to implement th e alternate valve standard specified in

§§ 265.1062(b)(2) or (b)(3)).

Permitted facilities:

Agency activities associated with the requirements for permitted facilities with equipment subject

to Subpart BB include:

• Reviewing notifications to implement th e alternate valve standard specified in

§264.1061(a));

• Reviewing notifications to discontinue im plementing the alternate valve specified in

§264.1061(a));

• Reviewing notifications to implement th e alternate valve standard specified in

§§ 264.1062(b)(2) or (b)(3)); and

• Reviewing semiannual reports.

CONTAINMENT BUILDINGS

Interim status facilities:

Agency activities associated with the requirements for interim status facilities with containment

buildings subject to Subpart DD include:

• Collecting written notices of requests for delay of secondary containment;

• Reviewing and commenting on plans to retrofit a unit;

• Reviewing responses to comments and approving/disa pproving a delay;

• Receiving notifications of release;

• Reviewing written notices, descriptions, or remedial steps, and schedules for cleanup;

• Reviewing information and determining if a unit must be removed from service;

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• Notifying owner/operator in writing of determination;

• Reviewing verification of cleanup; and

• Reviewing no-free-liquid demonstrations.

Permitted facilities:

Agency activities associated with the requirem ents for permitted facilities with containment

buildings subject to Subpart DD include:

• Collecting written notices of requests for delay of secondary containment;

• Reviewing and commenting on plans to retrofit a unit;

• Reviewing responses to comments and approving/disa pproving a delay;

• Receiving notifications of release;

• Reviewing written notices, descriptions, or remedial steps, and schedules for cleanup;

• Reviewing information and determining if a unit must be removed from service;

• Notifying owner/operator in writing of determination;

• Reviewing verification of cleanup; and

• Reviewing no-free-liquid demonstrations.

5(b) COLLECTION METHODOLOGY AND MANAGEMENT

Respondents are required to submit certain documentation to the agency as discussed in Section

6. The submitted documents are maintained by the r eceiving agency. The agency enters select data about

the respondents’ facilities and the submitted doc uments into RCRAInfo; RCRAInfo is EPA’s

comprehensive information system which provid es access to data supporting the implementation and

management of the RCRA hazardous waste program.

5(c) SMALL ENTITY FLEXIBILITY

EPA does not anticipate that many small busin esses will be engaging in the types of activities

covered in this ICR. However, to the extent that there are small entities with, for example, a regulated

hazardous waste tank system, they are subject to the same standards as larger entities. EPA has been

directed by Congress to promulgate standards to pr otect public health and the environment. In cases

where small businesses engage in activities that endange r the environment, EPA believes it is alleviating

its responsibility to respond to its Congressional mandate by exempting them from regulation.

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5(d) COLLECTION SCHEDULE

TANK SYSTEMS

Interim status facilities:

Facilities must submit release notification reports within 30 days of detecting a release. In

addition, the certification of major repairs (require d under §265.196(f)) must be submitted within 7 days

of returning the repaired tank system to use.

Permitted facilities:

Release notification reports must be submitted with in 24 hours of detection, and certification of

major repairs must be submitted within 7 days af ter returning the repaired tank system to use.

SURFACE IMPOUNDMENTS

Interim status facilities:

Notification of intent to receive waste must be submitted 60 days prior to receiving waste.

Notification of an exceedance of the action leakage rate must be submitted to EPA within seven days, and

a preliminary written assessment identifying the amount of liquids, likely sources, etc., must be submitted

within 14 days of the determination of exceedance. Within 30 days after the notification of ALR

exceedance, the analysis results must be submitted, along with the results of any actions taken, and

actions planned.

Permitted facilities:

Notification of removal of a surface impoundment from service must be submitted to the

Regional Administrator within 7 days after detection of a release. Notification of an exceedance of the

action leakage rate must be submitted to EPA with in seven days, and a preliminary written assessment

identifying the amount of liquids, likely sources, etc., must be submitted within 14 days of the

determination of exceedance. Within 30 days afte r the notification of ALR exceedance, the analysis

results must be submitted, along with the results of any actions taken, and actions planned.

WASTE PILES

Interim status facilities:

Notification of an exceedance of the action leakag e rate must be submitted to EPA within seven

days, and a preliminary written assessment identifying th e amount of liquids, likely sources, etc., must be

submitted within 14 days of the determination of exc eedance. Within 30 days after the notification of

ALR exceedance, the analysis results must be submitted, along with the results of any actions taken, and

actions planned.

Permitted facilities:

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Notification of an exceedance of the action leakag e rate must be submitted to EPA within seven

days, and a preliminary written assessment identifying th e amount of liquids, likely sources, etc., must be

submitted within 14 days of the determination of exc eedance. Within 30 days after the notification of

ALR exceedance, the analysis results must be submitted, along with the results of any actions taken, and

actions planned.

LAND TREATMENT

Interim status facilities:

Notification to the Regional Administrator that fo od crops are being grown, or have been grown

and will be grown in the future, at a land treatment unit must be submitted within 60 days after the

effective date of these regulations.

Permitted facilities:

Notification of statistically significant contaminant increases must be submitted to the Regional

Administrator within 7 days of determination. No tification of intent to make a demonstration under

§264.278(h) must be submitted to the Regional Administ rator within 7 days of the above determination,

and the demonstration must be submitted within 90 days. Certification of closure must be submitted

within 60 days of closure in accordance with §265.115. Demonstrations for exemption from

§264.280(a)(8) and (c) may be submitted at any time dur ing the closure or post-closure period, depending

on the desire of the owner or operator to submit such a demonstration.

LANDFILLS

Interim status facilities:

Notification of intent to receive waste must be submitted to the Regional Administrator at least 60

days prior to receiving the waste. Notification of an exceedance of the action leakage rate must be

submitted to EPA within seven days, and a pre liminary written assessment identifying the amount of

liquids, likely sources, etc., must be submitted within 14 days of the determination of exceedance. Within

30 days after the notification of ALR exceedance, the analysis results must be submitted, along with the

results of any actions taken, and actions planned.

Permitted facilities:

Notification of an exceedance of the action leakag e rate must be submitted to EPA within seven

days, and a preliminary written assessment identifying th e amount of liquids, likely sources, etc., must be

submitted within 14 days of the determination of exc eedance. Within 30 days after the notification of

ALR exceedance, the analysis results must be submitted, along with the results of any actions taken, and

actions planned

THERMAL TREATMENT UNITS

Interim status facilities:

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Owner/operators must submit doc umentation required under 40 CFR Part 265, Subpart P prior to

burning EPA Hazardous Wastes F020, F021, F022, F023, F026 , or F027. Unless the Director approves a

later date, trial burn certification must be submitted with in 90 days of completion. Data collected during

the trial burn must be submitted followi ng completion of the trial burn.

DRIP PADS

Interim status facilities:

Notification of a condition detected that may ha ve caused or has caused a release of hazardous

waste must be submitted to the EPA within 10 working days of the discovery.

Permitted facilities:

Notification of a condition detected that may ha ve caused or has caused a release of hazardous

waste must be submitted to the EPA within 10 working days of the discovery.

PROCESS VENTS

Permitted facilities:

Owner/operators submit semiannual reports to EPA on dates specified by the Regional

Administrator.

EQUIPMENT LEAKS

Permitted facilities:

Owner/operators submit semiannual reports to EPA on dates specified by the Regional

Administrator.

CONTAINMENT BUILDINGS

Interim status facilities:

Owner/operators must submit notification of any condition that has caused a release within 7 days

after the discovery of the condition. A description of the steps taken to repair the containment building,

and a schedule for accomplishing the work must be su bmitted to EPA within 14 days after discovery of

the condition.

Permitted facilities:

Owner/operators must submit notification of any condition that has caused a release within 7 days

after the discovery of the condition. A description of the steps taken to repair the containment building,

and a schedule for accomplishing the work must be su bmitted to EPA within 14 days after discovery of

the condition.

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6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

EPA estimates respondent burden for both Pr ivate respondents (private sector businesses and

industries) and Governments respondents (includes St ate, County, Municipal, District, and Tribal

governments). Table 1 presents the estimated numb er of RCRA facilities with each specific type of

existing interim status and permitted units that are e xpected to comply annual ly with the information

collection requirements covered in this ICR.

EPA derived these data for this ICR from RCRAInfo. 

# RCRAInfo is EPA's comprehensive

information system which provides access to data supporting the implementation and

management of the RCRA Subtitle C hazardous waste program. The data is entered into the system

by States and EPA. RCRAInfo allows the Permitting Program to track facilities through the permitting

process and communicate their performance and progress.

6(a) ESTIMATING RESPONDENT BURDEN

EPA estimates respondent burden for units associated with all of the require ments covered in this

ICR in Exhibits 1a through 12a for Private res pondents and Exhibits 1b through 12b for Governments

Respondents. The exhibits (see Exhibits Appendix) address the following specific unit requirements:

Exhibit 1 – Containers

Exhibit 2 -- Tank systems

Exhibit 3 -- Surface impoundments

Exhibit 4 -- Waste piles

Exhibit 5 -- Land treatment

Exhibit 6 -- Landfills

Exhibit 7 -- Incinerators

Exhibit 8 -- Drip pads

Exhibit 9 -- Miscellaneous units

Exhibit 10 -- Process vents

Exhibit 11 -- Equipment leaks

Exhibit 12 -- Containment buildings

In Exhibits 1 through 12, EPA estimates the numbe r of hours required to conduct each individual

information collection activity.

6(b) ESTIMATING RESPONDENT COSTS

EPA estimates that the total annual respondent co st for all activities covered in this ICR is

$43,154,199 per year. This cost includes annual la bor, capital, and operation and maintenance (O&M)

costs to be incurred by respondents affected by the information collection requi rements covered in this

ICR. A brief discussion follows.

Labor Rates

EPA estimates an average hourly Private responde nt labor cost (including overhead) of $109.63

for legal staff, $77.94 for managerial staff, $37.55 for technical staff, and $21.99 for clerical staff. These

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wage rates and the burden hours presented in Exhibits 1a and b through 12a & b are used to estimate the

Private respondent costs associated with all of the in formation collection activities covered in this ICR.

EPA estimates an average hourly non-federal G overnments respondent labor cost (including

overhead) of $58.46 for legal staff, $54.88 for managerial staff, $32.84 for technical staff, and $20.95 for

clerical staff. These wage rates and the burden hour s presented in Exhibits 1a & b through 12a and b are

used to estimate the Governments respondent costs associated with all of the information collection

activities covered in this ICR.

Capital Costs

EPA assumes that all facilities with interim status and permitted units already possess file storage

systems, either for electronic or paper filing. Ther efore, no capital costs will be incurred during the three

year period of this ICR.

Operation and Maintenance Costs

EPA also estimates that facilities will incur opera tion and maintenance (O&M) costs. O&M costs

include postage for submittals of information or no tices. EPA estimates that facilities will incur $5.00 in

postage costs for every submittal to EPA, based on th e mailing cost of $5.00 for a two-pound package.

O&M costs also include purchased material costs and/or lump-sum purchased service costs (e.g., waste

analyses, inspection/certification by an independent re gistered professional engineer). From O&M costs

in Exhibits 13a and b (see Subsection 6(e)), EPA est imates that the total annual O&M cost for conducting

respondent activities covered in the ICR is $6,838,196.

6(c) ESTIMATING AGENCY BURDEN AND COST

EPA estimates the Federal agency average hourly labor cost to be $80.31 for legal staff (GS-15,

Step 5), $70.87 for managerial staff (GS-15, Step 1), $50.98 for technical staff (GS-13, Step 1), and

$21.73 for clerical staff (GS-06, Step 1). To deri ve these hourly estimates, EPA referred to the General

Schedule (GS) Salary Table 2011. This publica tion summarizes the unloaded (base) hourly rate for

various labor categories in the Federal Government. EPA then applied the standard government overhead

factor of 1.485 to the unloaded rate to derive loaded hourly rates.

EPA estimates an average hourly State agency labor cost (including overhead) of $58.46 for legal

staff, $54.88 for managerial staff, $32.84 for technical staff, and $20.95 for clerical staff. These wage

rates and the burden hours presented in Exhibit 14b are used to estimate the Stat e agency costs associated

with all of the information collec tion activities covered in this ICR

EPA assumes that EPA conducts only 10 percent of the agency activities and States conduct 90

percent of the agency activities. EPA burden and cost s are presented in Exhibit 14a and States in Exhibit

14b (see Exhibits Appendix).

6(d) ESTIMATING THE RESPONDENT UNIVERSE AND TOTAL BURDEN AND COST

Respondent Universe

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EPA estimates respondent burden for both Pr ivate respondents (private sector businesses and

industries) and Governments respondents (includes St ate, County, Municipal, District, and Tribal

governments).

Table 1 presents the estimated number of RCRA facilities with interim status and permitted units

for each specific unit type that are expected to comply annually with the information collection

requirements covered in this ICR. For example, if a facility has three tank units and two incinerators, it

counts as one for each specific unit type – one for tanks and one for incinerators. This facility would have

units subject to three different specific unit type regulations (Subparts I, J, and O).

As shown in the Table 1, EPA estimates that a nnually a total of 4,349 facilities with specific unit

types will be subject to the information collection requ irements covered in this ICR. Of these, 88 units

are interim status units and 4,261 are permitted units.

Table 1

Number of Interim Status and Permitted Units for Each Specific Unit Type

Subject to Information Collection Re quirements Covered in this ICR

Specific Unit Type Interim Status Units Total

Interim

Status Permitted Units Total

Permitted Total

Units

Private Governments Private Governments

Subpart I - Containers 

# 3 3 6 211 577 788 794

Subpart J – Tank Systems 

# 12 9 21 52 533 585 606

Subpart K - Surface

Impoundments 

# 1 1 2 2 36 38 40

Subpart L - Waste Piles 

# 0 0 0 3 5 8 8

Subpart M - Land Treatment 

# 0 0 0 0 8 8 8

Subpart N - Landfills 

# 0 0 0 0 43 43 43

Subpart O - Incinerators 

# 0 0 0 11 41 52 52

Subpart W - Drip Pads 

# 0 0 0 0 0 0 0

Subpart AA - Process Vents 

# 18 3 21 742 80 822 843

Subpart BB - Equipment

Leaks 

# 35 3 38 1,752 127 1,879 1,907

Subpart DD - Containment

Buildings 

# 0 0 0 13 25 38 38

TOTALS 65 19 88 2,786 1,475 4,261 4,349

Respondent Burden and Costs

Based on the universe data presented in Table 1, EPA estimates Private respondent and

Governments respondent burden and costs associated w ith all the requirements covered in this ICR in

Exhibits 1a and b through 12a and b, respectively. A discussion of the Private and Governments burden

estimates presented in these exhibits follows; the da ta in the discussion is the sum of the respective

Private respondent and Governments respondent burdens.

CONTAINERS

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Interim status facilities:

EPA estimates that these interim status container units are subject to 40 CFR Part 265, Subpart I.

(1) Read the Regulations

EPA assumes that owners and operators of existi ng interim status units have already read the

regulations. Thus, EPA estimates that there is no burden associated with this activity.

(2) Inspections

EPA estimates that these interim status units will record all inspection data, as required by

§ 265.174.

Permitted facilities:

EPA estimates that these permitted container units are subject to 40 CFR Part 264, Subpart I.

(1) Read the Regulations

EPA assumes that owners and operators of ex isting permitted units have already read the

regulations.

(2) Inspections

EPA estimates that these permitted units will reco rd all inspection data, as required by §264.174.

TANK SYSTEMS

Interim status facilities:

EPA estimates that these interim status tank system units are subject to 40 CFR Part 265, Subpart

J.

(1) Read the Regulations

EPA assumes that owners and operators of existi ng interim status units have already read the

regulations. Thus, EPA estimates that there is no burden associated with this activity.

(2) No-Free-Liquids Demonstration

Based on previous experience, EPA estimates that five percent of interim status units will

perform the paint filter liquids test an average of 40 times per year. In addition, EPA estimates O&M

costs for supplies.

(3) Assessment of Existing Tank Systems’ Integrity

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Since tanks without secondary containment have a ll been closed, no interim status units will be

required to prepare and maintain an assessment of tank systems integrity.

O&M costs cover contractor costs associated with performing the leak test and for obtaining a

certification from an independent, qualifie d, registered, professional engineer.

(4) Design and Installation of New Tank Systems or Components

This ICR assumes that existing interim status un its have already prepared a new tank systems

assessment and certification. Therefore, nob ody will submit new tank system assessments and

certifications. All interim status units will maintain records of statements written by those who certified

design of the tank system and supervised its installation.

O&M costs for this activity include one-time fe es associated with an independent, qualified,

registered, professional engineer attesting that the system has sufficient structural integrity and is

acceptable for storing and treating of hazardous waste.

(5) Containment and Detection Requirements

• Equivalent Containment Device

This ICR assumes that existing interim status units have already submitted information for

approval of an equivalent containment device under §265.193(d). Therefore, nobody will submit

information to obtain an equivalent containment exemption.

• Exemption from 24-hour Leak Detection Requirement

This ICR assumes that existing interim status units with double-walled tanks have already

submitted information demons trating that existing leak detection technology or site conditions will not

allow detection of a release within 24 hours. Therefore, nobody will s ubmit this information.

• Variance from Secondary Containment Requirements

This ICR assumes that existing interim status units have already submitted information for

approval of a variance from secondary containmen t requirements. Therefore, nobody will submit

information to obtain exemption from secondary containment requirements.

• Annual Leak Test and Inspection

All interim status units subject to Subpart J that have not submitted a no-free-liquids

demonstration and do not meet secondary containmen t requirements are required to conduct a leak test

annually. As indicated previously, all interim status tank systems without secondary containment devices

have been closed. Therefore, no interim status units will conduct leak tests and inspections pursuant to

§265.193(i).

(6) Inspections

EPA estimates that these interim status units will record all inspection data, as required by

§265.195.

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(7) Responses to leaks or spills, disposition of leaking or unfit-for-use tank systems

• Exemption From the 24-hour Waste Removal Requirement

Based on previous experience, EPA estimates that 25 percent of interim status units subject to

Subpart J will detect leakage each year. EPA estimates that 33 percent of the units will submit

information to obtain exemption from the 24-hour waste removal requirement.

O&M costs for this activity include contractor fees associated with preparing information to

receive the exemption.

• Release Notifications and Repo rts/Major Repair Certifications

As indicated previously, EPA maintains that interi m status units subject to Subpart J will detect

leaks or spills. Therefore, these interim status units w ill have to prepare release notifications and reports.

EPA further estimates that leaks or spills from 50 pe rcent of these units will be caused by major system

damage. Therefore, these interim status units will submit major repair certifications.

O&M costs for this activity include one-time fe es associated with the services of a registered,

professional engineer to prepare the certification.

(8) Closure and Post-Closure Care

• Decontamination demonstration

EPA does not expect any interim status units s ubject to Subpart J to close their tank systems

during the period covered in this ICR. Therefore, no units will have to demonstrate that all contaminate

soils can be practicably removed or de contaminated as required in §265.197(a).

(9) Waste Analysis and Trial Tests

Based on previous experience, EPA estimates that zero percent of interim status tank system

owner/operators will chemically treat hazardous w aste that is substantially different from waste

previously treated in the tank system. Therefore, no interim status units will be required to conduct waste

analyses and trial tests and obtain written, documented information to show that the treatment or storage

will meet the requirements of §265.194(a).

O&M costs for this activity include contract or fees associated with conducting the waste

analyses.

Permitted facilities:

EPA estimates that these permitted tank system units are subject to 40 CFR Part 264, Subpart J.

(1) Read the Regulations

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EPA assumes that owners and operators of ex isting permitted units have already read the

regulations.

(2) No Free Liquids Demonstration

Based on previous experience, EPA estimates th at one percent of permitted units will make no

free liquids demonstrations and average of 40 times per year. In addition, EPA estimates O&M costs

associated with obtaining materials for the test.

(3) Assessment of Existing Tank Systems’ Integrity

Since tanks without secondary containment have all been closed, no permitted units will be

required to prepare or obtain and mainta in assessments of tank system integrity.

(4) Design and Installation of New Tank Systems or Components

As indicated previously, preparation of new tank system assessments and certifications are

covered in the “Part B Permit Application, Permit Modification, and Special Permits ICR (EPA ICR

Number 1573). However, activities associated with maintaining this documentation (photocopying,

filing, and updating) are covered in this ICR. EPA estimates that all permitted units will maintain this

information in the unit operating record.

(5) Containment and Detection Requirements

• Annual Leak Test and Inspection

All permitted units subject to Subpart J that ha ve not submitted a no-free-liquids demonstration

and do not meet secondary containment requirements are required to conduct a leak test annually. As

indicated previously, all permitted tank systems without secondary containment devices have been closed.

Therefore, no permitted status units will conduct l eak tests and inspections pursuant to 40 CFR

264.193(i).

(6) Inspections

EPA estimates that these permitted units will reco rd all inspection data, as required by §264.195.

(7) Responses to Leaks, Spills, Dispositio n of Leaking or Unfit-For-Use Tank Systems

• Exemption From the 24-hour Waste Removal Requirement

Based on previous experience, EPA estimates th at 25 percent of permitted units subject to

Subpart J will detect leakage each year. EPA estimates that 33 percent of these units will submit

information to obtain exemption from the 24-hour waste removal requirement.

O&M costs for this activity include contractor fees associated with preparing information to

receive the exemption.

• Release Notifications and Repo rts/Major Repair Certifications

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As indicated previously, EPA maintains that each year permitted units subject to Subpart J will

detect leaks or spills. Therefore, these units will ha ve to prepare release notifications and reports. EPA

further estimates that leaks or spills from one per cent of these units will be caused by major system

damage. Therefore, these permitted units will be required to submit major repair certifications.

O&M costs for this activity include one-time fe es associated with the services of a registered,

professional engineer to prepare the certification.

(8) Closure and Post-Closure Care

• Decontamination demonstration

EPA does not expect any permitted units subject to Subpart J to close their tank systems during

the period covered in this ICR. Therefore, no units w ill have to demonstrate that all contaminate soils can

be practicably removed or decontaminated as required in §264.197(a).

SURFACE IMPOUNDMENTS

Interim status units:

EPA estimates that these interim status surface impoundment units are subject to 40 CFR Part

265, Subpart K.

(1) Read the Regulations

EPA assumes that owners and operators of existi ng interim status units have already read the

regulations. Thus, EPA estimates that there is no burden associated with this activity.

(2) Design and Operating Requirements

EPA estimates that none of the existing interim status surface impoundments will be replaced or

laterally expanded during the period covered by this ICR. Therefore, no units will have to submit and

maintain a written assessment of alternate design and operating practices, together with location

characteristics, that will prevent the migration of any hazardous constituents into the ground water or

surface water as effectively as the requirements. Furt hermore, no units will be required to notify EPA or

the authorized State prior to receiving waste.

EPA estimates that all interim status units that have submitted exemptions from the requirements

of §§ 265.221 and 265.222 (five percent of the existi ng universe) will maintain (i.e., file and photocopy)

the written assessment and related da ta at the unit. Therefore, no units will have to maintain the

certification and written identification at the units.

This ICR assumes that existing interim status units that have surface impoundments with less than

60 centimeters of freeboard level have already obtained written identification and certification of alternate

design features or operating plans that will prevent ov ertopping. EPA estimates that all interim status

units that have obtained written identification and cer tification of alternate design features or operating

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plans that will prevent overtopping (five percent of the existing universe will maintain (i.e., file and

photocopy) the written assessment a nd related data at the unit.

O&M costs for this activity include contractor fees associated with services of a registered

engineer in preparing the certification.

(3) Developing and Submitting Action Leakage Rates

EPA estimates that, no units will submit action leakage rate (ALR) proposals to EPA in

accordance with §265.222(a). The ex isting interim status unit will maintain the results of the action

leakage rate analysis at the facility.

(4) Calculating Average Daily Flow Rates

EPA estimates that, no units will calculate av erage daily flow rates as specified under

§265.222(c).

(5) Response Action Plan and Recordkeeping of Response Actions

EPA estimates that, units will complete and submit a Response Action Plan (RAP) to EPA.

Additionally, one interim status unit will maintain records of the analyses conducted for the RAP, in

accordance with §265.223(a).

(6) Action Leakage Reporting

EPA estimates that one percent of all interim stat us units will have to comply with action leakage

reporting requirements, as required under §265.223(b).

(7) Remediation Determination Analyses

EPA estimates that one percent of all interim st atus units will conduct remediation determination

analyses in response to flow rates at the unit ex ceeding the action leakage rate, as specified under

§265.223(c).

(8) Waste Analysis and Trial Tests

Based on previous experience, EPA estimates that one percent of interim status surface

impoundment owner/operators will chemically treat hazar dous waste that is substantially different from

waste previously treated in the impoundment, or chem ically treat hazardous waste with a substantially

different process than any previously used in the im poundment. Therefore, these interim status units will

be required to conduct waste analyses or obtain wr itten, documented information to show that the

treatment will comply with §265.17(b).

(9) Monitoring and Inspections

EPA estimates that the interim status units w ill record the monitoring and inspection activities as

required by §265.226(b)(1).

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(10) Developing and Submitting Pump Operating Levels

EPA estimates that, no units will develop a nd submit pump operating level proposals. In

addition, EPA estimates that one interim status unit w ill maintain the results of the associated analyses at

the unit (§265.226(b)(3)).

(11) Requirements for Ignitable or Reactive Wastes

Based on previous experience, EPA estimates that no interim status surface impoundment

owner/operators will place ignitable or reactive w astes in their surface impoundments. Therefore, no

units will be required to obtain certification unde r §265.229(b) that design features and unit operating

plans will prevent ignition or reaction.

(12) Closure

EPA does not expect any interim status surf ace impoundments to submit this information.

Permitted units:

EPA estimates that these permitted surface impoundmen t units are subject to 40 CFR Part 264,

Subpart K.

(1) Read the Regulations

EPA assumes that owners and operators of ex isting permitted units have already read the

regulations.

(2) Calculating Average Daily Flow Rates

EPA estimates that all permitted units will have already calculated average daily flow rates as

specified under §264.222(c). Thus, no units will calculate the average leakage flow rates.

(3) Action Leakage Reporting

EPA estimates that one percent of all perm itted units will undertake action leakage reporting

procedures and submit action leakage reports in resp onse to an exceedance of action leakage levels, as

required under §264.223(b).

O&M costs for this activity include one-time c ontractor fees associated with determining the

location, size and cause of any leak.

(4) Remediation Determination Analyses

EPA estimates that one percent of all permitte d units will conduct reme diation determination

analyses in response to flow rates at the unit ex ceeding the action leakage rate, as specified under

§264.223(c).

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O&M costs for this activity include one-time contractor fees associated with conducting the

remediation determination analysis.

(5) Dike Re-certification

EPA estimates that 10 percent of the existing permitted surface impoundment respondent

universe will have surface impoundments that are out of use for six months or more. Therefore, these

units will be required to obtain certification that the impoundments dike, including any portion of the dike

that provides freeboard, has structural integrity accord ing to the standards deta iled in §264.226(c)(1) and

(2).

O&M costs for this activity include one-time fees associated with obtaining a certification from a

qualified engineer that the impoundments’ dike has structural integrity.

(6) Monitoring and Inspections

EPA estimates that all permitted units will reco rd the monitoring and inspection activities as

required by §264.226(d)(1).

(7) Emergency Repairs and Contingency Plans

EPA estimates that one percent of permitted units will be required to remove a surface

impoundment from service due to sudden drops in liquid levels or a leaking dike. Therefore, these units

will be required to submit a written notification to the Regional Administrator of the removal. EPA

estimates that all surface impoundments removed from servi ce will be repaired. Therefore, these units

will be required to obtain certification that the repair ed liner system meets design specifications approved

in the permit.

O&M costs for this activity include one-time fees associated with obtaining a certification from a

qualified engineer that the repaired lin er system meets design specifications.

(8) Closure

EPA estimates that all permitted units will have al ready prepared and submitted the plans, reports,

and requests for closure activities, as specified in §2 64.113(e). Therefore, no units are expected to be

burdened by closure requirements.

WASTE PILES

Interim status units:

EPA estimates that these interim status waste pile units are subject to 40 CFR Part 265, Subpart

L.

Permitted units:

EPA estimates that these permitted waste pile units are subject to 40 CFR Part 264, Subpart L.

# 154

(1) Read the Regulations

EPA assumes that owners and operators of ex isting permitted units have already read the

regulations.

(2) Calculating Average Daily Flow Rates

EPA estimates that all newly permitted units from interim status have already calculated their

average leakage flow rates while operating under interim status.

(3) Action Leakage Reporting

EPA estimates that one percent of all perm itted units will undertake action leakage reporting

procedures and submit action leakage reports in resp onse to an exceedance of action leakage levels, as

required under §264.253(b).

(4) Remediation Determination Analyses

EPA estimates that one percent of all permitte d units will conduct reme diation determination

analyses in response to flow rates at the unit ex ceeding the action leakage rate, as specified under

§264.253(c).

(5) Monitoring and Inspections

EPA estimates that all permitted units will reco rd the monitoring and inspection activities as

required by §264.254(c).

LAND TREATMENT

Interim status units:

EPA estimates that these interim status land treatment units are subject to 40 CFR Part 265,

Subpart M.

Permitted units:

EPA estimates that these permitted land treatment units are subject to 40 CFR Part 264, Subpart

M.

(1) Read the Regulations

EPA assumes that the owner or operator of the f acilities with the existing permitted units have

already read the regulations. Thus, EPA estimates that there is no burden associated with this activity.

(2) Food Chain Crops

This ICR assumes that the facilities with the ex isting permitted units have already notified the

Regional Administrator that it is or has been growing crops on its unit.

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Based on previous experience, EPA estimates that 25 percent of the existing permitted universe is

growing or has grown food-chain cr ops on their unit. Therefore, zero units will be required to maintain

(i.e., file and photocopy) records of information collect ed for the food-chain crop demonstration at their

unit.

(3) Unsaturated-zone Monitoring

This ICR assumes that the facilities with the exis ting permitted units have already established an

unsaturated-zone monitoring program. Therefore, no permitted units will be required to develop an

unsaturated-zone monitoring plan during the period covered in this ICR.

Based on previous experience, EPA estimates th at 25 percent of the permitted land treatment

universes are subject to the unsaturated-zone monito ring requirements of 40 CFR 264.278. However,

EPA estimates that these units will be require d to submit a permit modification request.

(4) Closure and Post-closure

EPA does not expect the existing permitted land treatment units to close during the period

covered by this ICR. Therefore, no permitted unit w ill be required to submit a certification of closure.

EPA further estimates that no unit will submit a demonstration under §264.280(d).

LANDFILLS

Interim status units:

EPA estimates that these interim status landfill units are subject to 40 CFR Part 265, Subpart N.

(1) Read the Regulations

EPA assumes that owners and operators of existi ng interim status units have already read the

regulations. Thus, EPA estimates that there is no burden associated with this activity.

(2) Design Requirements

EPA estimates that none of the existing interim status landfills will be replaced or laterally

expanded during the period covered by this ICR. Ther efore, zero units will submit an application for an

exemption from the liner and leachate collection system requirement or a notification prior to receiving

waste.

(3) Developing and Submitting Action Leakage Rates

EPA estimates that these units will submit acti on leakage rate (ALR) proposals to EPA in

accordance with §265.302(a). EPA estimates that landfill un its that are subject to Subpart N will maintain

results of their ALR analysis.

O&M costs for this activity include one-time fees contractor associated with preparing the action

leak rates.

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(4) Calculating Average Daily Flow Rates

EPA estimates that these units will calculate average daily flow rates as specified under

§265.302(c).

(5) Response Action Plan and Recordkeeping of Response Actions

EPA estimates that these units will complete and submit a Response Action Plan (RAP) to EPA.

EPA estimates that landfill units that are subject to Subpart N will maintain records of the analyses

conducted for the RAP, in accordance with §265.303(a).

O&M costs for this activity include one-time cont ractor fees associated with completing the RAP.

(6) Action Leakage Reporting

EPA estimates that one percent of all interim stat us units will have to comply with action leakage

reporting requirements, as required under §265.303(b).

(7) Remediation Determination Analyses

EPA estimates that one percent of all interim st atus units will conduct remediation determination

analyses in response to flow rates at the unit ex ceeding the action leakage rate, as specified under

§265.303(c).

(8) Monitoring and Inspections

EPA estimates that the interim status unit will record the monitoring and inspection activities as

required by §265.304(b).

(9) Developing and Submitting Pump Operating Levels

EPA estimates that these units will develop and submit pump operating level proposals and

maintain the results of the associated analyses at the unit (§265.304(b)). EPA estimates that one unit is

subject to Subpart N will maintain the resu lts of their pump operating level analysis.

(10) Special Requirements for bulk and containerized liquids

Based on previous experience, EPA estimates that 50 percent of interim status units will record

and file the results of observations of the absence or presence of free liquids in bulk or containerized

waste. EPA further estimates that 0.5 percent of these units will submit a demonstration for placing nonhazardous liquid waste in a landfill.

Permitted units:

EPA estimates that these permitted landfill units ar e subject to 40 CFR Part 264, Subpart N.

(1) Read the Regulations

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EPA assumes that owners and operators of ex isting permitted units have already read the

regulations.

(2) Calculating Average Daily Flow Rates

EPA estimates that these units will calculate av erage daily flow rates, as specified under

§264.302(c).

(3) Monitoring and Inspections

EPA estimates that these permitted units will r ecord the monitoring and inspection activities as

required by §264.304(b).

(4) Action Leakage Reporting

EPA estimates that one percent of all perm itted units will undertake action leakage reporting

procedures, and submit action leakage reports in res ponse to an exceedance of action leakage levels, as

required under §264.303(b).

O&M costs for this activity include one-time c ontractor fees associated with determining the

location, size, and cause of any leak.

(5) Remediation Determination Analyses

EPA estimates that these units will conduct reme diation determination analyses in response to

flow rates at the units exceeding the action leakage rate, as specified under §264.303(c).

O&M costs for this activity include one-time cont ractor fees associated with making remediation

determinations to assess the source of liquids and the seriousness of any leaks.

(6) Special Requirements for bulk and containerized liquids

Based on previous experience, EPA estimates that 50 percent of permitted units will record and

file the results of observations of the absence or prese nce of free liquids in bulk or containerized waste.

EPA further estimates that 0.5 percent of these units will submit demonstrations for placing nonhazardous liquid waste in landfills.

INCINERATORS

Interim status units:

EPA estimates that these interim status incinerator units are subject to 40 CFR Part 265, Subpart

O.

(1) Read the Regulations

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EPA assumes that owners and operators of existi ng interim status units have already read the

regulations. Thus, EPA estimates that there is no burden associated with this activity.

(2) Applicability

EPA estimates that these units will submit a dem onstration for exemption from the requirements

of Subpart O.

(3) Waste Analysis

Based on previous experience, EPA estimates that one percent of interim status incinerator

owner/operators will treat hazardous waste that is subs tantially different from waste previously treated in

the incinerator. Therefore, these interim status units will be required to conduct waste analyses.

(4) Monitoring and Inspections

EPA estimates that these interim status units w ill record the monitoring and inspection activities

as required by §265.347(b).

(5) Special Requirements for Hazardous Wastes F020, F021, F022, F023, F026, and

F027

EPA estimates that no interim status incinerators will be allowed to burn F020, F021, F022, F023,

F026, or F027. Thus, no facilities will complete and submit the application.

Permitted units:

EPA estimates that permitted incinerator units are subject to 40 CFR Part 264, Subpart O.

(1) Read the Regulations

EPA assumes that owners and operators of ex isting permitted units have already read the

regulations.

(2) Notification of Intent to Burn Hazardous Wastes F020, F021, F022, F023, F026, and

F027

This ICR assumes that existing permitted units burning hazardous wastes F020, F021, F022,

F023, F026, and F027 have already notified the Regiona l Administrator. EPA further estimates that no

permitted incinerators are currently burning F020, F0 21, F022, F023, F026, and F027 wastes. Therefore,

zero units will be required to submit a notification of intent to burn hazardous wastes F020, F021, F022,

F023, F026, and F027.

(3) Monitoring and Recordkeeping

Based on previous experience, EPA estimates that 0.5 percent of the permitted units subject to

Subpart O will submit a demonstration for an exempt ion from the requirements to test the emergency

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waste feed cutoff system and associate alarms on a week ly basis. All permitted units with incinerators

must record monitoring and inspection data in the operating log required by §264.73.

THERMAL TREATMENT UNITS (see Miscellaneous Units)

CHEMICAL, PHYSICAL, AND BIOLOGICAL TREATMENT UNITS (see Miscellaneous Units)

DRIP PADS

EPA estimates that drip pad units are subject to 40 CFR Part 265, Subpart W.

(1) Read the Regulations

EPA assumes that owners and operators of existing units have already read the regulations. Thus,

EPA estimates that there is no burd en associated with this activity.

(2) Contingency Plan

Because EPA estimates that no units will maintain a contingency plan for discharge of drippage,

including documentation of drippage, as specified under §265.440(c)(1).

(3) Assessment of Existing Drip Pad Integrity

EPA estimates that the no existing units subject to Subpart W will review and recertify the drip

pad maintain records of the asse ssment, according to §265.441(a).

O&M costs for this activity include one-time cont ractor fees associated with preparing a written

assessment of the drip pad by a registered engin eer, and for fees for reviewing, updating, and recertification.

(4) Plan for Upgrading, Repairing, and Modifying the Drip Pad

Because EPA estimates that no units will enter th e universe, no units w ill develop and submit a

plan for upgrading, repairing, and modifying a drip pad and all as-built drawings of a drip pad

(§265.441(b)-(c)).

(5) Design and Operating Requirements

Because EPA estimates that no units will enter the interim status universe, zero units will obtain a

written assessment of a new drip pad. However, EP A estimates that units are subject to Subpart W and

none will obtain an evaluation and certification of th e drip pad annually, docum ent the date and time of

cleaning, and maintain records of wood treated on the pad, in accordance with §265.443(a)(-(k).

O&M costs for this activity include one-time fe es contractor associated with a written certified

assessment of a new drip pad by a registered engi neer, as well as an annual evaluation and certification.

(6) Emergency Response

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EPA estimates that no units will be required to follow emergency response procedures due to a

release of hazardous waste, as specified under §265.443(m).

(7) Facility operating record

EPA estimates that the existing units subject to Subpart W will maintain documentation of past

operating and waste handling practices in accordance with §265.443(n).

(8) Inspections

EPA estimates that the existing units subject to Subpart W will inspect and certify liners on a

weekly basis as required under §265.444.

O&M costs for this activity include one-time cont ractor fees associated with certifying liners.

MISCELLANEOUS UNITS

EPA estimates that these permitted units are subject to 40 CFR Part 264, Subpart X.

(1) Read the Regulations

EPA assumes that owners and operators of ex isting permitted units have already read the

regulations.

PROCESS VENTS

Interim status units:

EPA estimates that these interim status units with process vents are subject to 40 CFR Part 265,

Subpart AA.

(1) Read the Regulations

EPA assumes that owners and operators of existi ng interim status units have already read the

regulations. Thus, EPA estimates that there is no burden associated with this activity.

(2) Control Device Operation Documentation

This ICR assumes that existing interim status un its with process vents that have implemented

control devices different from those specified in §265.1033(f), (g), and (h) have already prepared

documentation describing the operation of control devices and identifying process parameters that

indicate proper operation and maintenance of those control devices. Thus, no units will implement

control devices different from those specified in §265. 1033(f), (g), and (h) and no units will be required to

prepare this documentation. EPA estimates that a ll interim status units will reassess control device

operation documentation annually, an d 30 percent will modify it annually. Finally, EPA believes that all

units will maintain documentation at their facility.

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(3) Waste Determination

Based on previous experience, EPA estimates that 10 percent of interim status units with process

vents will use knowledge of the waste to determine th at its total organic concentration is less than 10

ppmw. EPA further estimates that owner/operators will make knowledge-based waste determinations

approximately 200 times per year. Therefore, these interim status units will be required to prepare

documentation of waste determinations 200 times per year, for a total of 400 activities.

O&M costs for this activity include one-time contractor fees associated with lab fees.

(4) Facility operating record

All interim status units subject to Subpart AA ar e required to maintain a unit operating record.

However, the contents of the record will vary accord ing to unit-specific circumstances. A discussion of

the respondent burden for each data item is presented below:

• Implementation schedule

This ICR assumes that existing interim status units with process vents that are complying with the

provisions of §265.1033(a) (2) have already prepared an implementation schedule. Therefore, no units

will be required to prepare an implementation schedule.

EPA estimates that these interim status units w ill reassess their implementation schedule, and 30

percent will modify it annually.

• Up-to-date documentation of compliance with §265.1032

This ICR assumes that existing interim status un its with process vents have already prepared

documentation of compliance with §265.1032. Therefor e, no units will be required to prepare §265.1032

compliance documentation.

EPA estimates that these interim status units will reassess, file, and maintain their §265.1032

compliance documentation, and 30 pe rcent will modify it annually.

• Performance Test Plan

This ICR assumes that existing interim status units with process vents that are using test data to

determine the organic removal efficiency or to tal organic compound concentration achieved by the

control device have already prepared a performance t est plan. Therefore, EPA estimates that no units will

be required to prepare a performance test plan.

EPA estimates that all interim status units will r eassess, file, and maintain their performance test

plan, and 30 percent will modify it annually.

• Documentation of compliance with §265.1033

# 162

This ICR assumes that existing interim status a nd permitted units with process vents have already

prepared documentation of complianc e with §265.1033. Therefore, no units will be required to prepare

§265.1033 compliance documentation.

EPA estimates that all interim status units will reassess, file, and maintain §265.1033 compliance

documentation, and that 30 percent will modify it annually.

• Design, monitoring, operation, and inspection information

This ICR assumes that existing interim status w ith process vents have already prepared design,

monitoring, and inspection information for each closed -vent system and control device. Therefore, no

units will be required to prepare design, monito ring, operation, and inspection information.

EPA estimates that all interim status units w ill reassess, file, and maintain control device

operation documentation, and 30 pe rcent will modify it annually.

• Determination of Applicability of §265.1032

This ICR assumes that existing interim status units have already documented information

determining applicability of §265.1032 to their unit pro cess vents. Therefore, no units will be required to

document information determining applicability of §265.1032 to their unit process vents.

EPA estimates that all interim status units will r eassess, file, and maintain this documentation,

and 30 percent will modify it annually.

Permitted units:

EPA estimates that these permitted units are subject to 40 CFR Part 264, Subpart AA.

(1) Read the Regulations

EPA assumes that owners and operators of ex isting permitted units have already read the

regulations.

(2) Control Device Operation Documentation

This ICR assumes that existing permitted units with process vents that have implemented control

devices different from those specified in §264.1033(f), (g), and (h) have already prepared documentation

describing the operation of control devices and id entifying process parameters that indicate proper

operation and maintenance of those control devices.

EPA estimates that these permitted units will reass ess, file, and maintain control device operation

documentation, and that 10 percent will modify it annually.

(3) Waste Determination

Based on previous experience, EPA estimates th at 10 percent of permitted units with process

vents will use knowledge of the waste to determine th at its total organic concentration is less than 10

# 163

ppmw. EPA further estimates that knowledge-based w aste determinations will be made approximately

200 times per year. Therefore, 82 permitted units w ill be required to prepare documentation of waste

determinations 16,400 times per year.

O&M costs for this activity include one-time contractor fees associated with lab fees.

(4) Facility operating record

All permitted units subject to Subpart AA are re quired to maintain a unit operating record.

However, the contents of the record will vary accord ing to unit-specific circumstances. A discussion of

the respondent burden for each data item is presented below:

• Implementation schedule

This ICR assumes that existing permitted units w ith process vents that are complying with the

provisions of §264.1033(a) (2) have already prepared an implementation schedule. EPA estimates that

these permitted units will reassess, file, and maintain their implementation schedule, and 10 percent will

modify it annually.

• Up-to-date documentation of compliance with §264.1032

This ICR assumes that existing permitted units with process vents have already prepared

documentation of compliance with §264.1032.

EPA estimates that all permitted units will reass ess, file, and maintain §264.1032 compliance

documentation, and 10 percent will modify it annually.

• Performance Test Plan

This ICR assumes that existing permitted units with process vents that are using test data to

determine the organic removal efficiency or to tal organic compound concentration achieved by the

control device have already prepared a performance test plan.

EPA estimates that all permitted units will reassess, file, and maintain their performance test plan,

and 10 percent will modify it annually.

• Documentation of compliance with §264.1033

This ICR assumes that existing permitted units with process vents have already prepared

documentation of compliance with §264.1033.

EPA estimates that all permitted units will reass ess, file, and maintain §264.1033 compliance

documentation, and 10 percent will modify it annually.

• Design, monitoring, operation, and inspection information

This ICR assumes that existing permitted units with process vents have already prepared design,

monitoring, and inspection information for each closed-vent system and control device.

# 164

EPA estimates that these permitted units will reass ess, file, and maintain control device operation

documentation, and that 10 percent will modify it annually.

• Determination of Applicability of §264.1032

This ICR assumes that existing permitted units have already documented information determining

applicability of §264.1032 to their unit process vents.

EPA estimates that these permitted units will reassess, file, and maintain this documentation, and

that 10 percent will modify it annually.

(5) Semiannual Report of Cont rol Device Monitoring Events

Based on previous experience, EPA estimates th at 60 percent of permitted units with process

vents will have control devices that exceed or operate outside design specifications or have flares that

operate with visible emissions. Therefore, these units will be required to submit a semiannual report.

EQUIPMENT LEAKS

Interim status units:

EPA estimates that these interim status units are subject to 40 CFR Part 265, Subpart BB.

(1) Read the Regulations

EPA assumes that owners and operators of existi ng interim status units have already read the

regulations. Thus, EPA estimates that there is no burden associated with this activity.

(2) Notification to implement the alternat e valve standard specified in §265.1061(a)

Based on previous experience, EPA estimates that, each year, 20 percent of interim status units

subject to Subpart BB will decide to implement the alternative standard specified in §265.1061(a).

Therefore, these units will be required to prepare notif ication to implement the alternate valve standard

specified in §265.1061(a).

(3) Notification to discontinue implementing the alternative valve standard specified in

§265.1061(a)

Based on previous experience, EPA estimates that no interim status units subject to Subpart BB

have implemented the alternative standard for valv es specified in §265.1061(a) and one percent of these

units will discontinue using the alte rnative standard each year. Theref ore, no units will be required to

prepare notification to discontinue implementing the alternate valve standard specified in §265.1061(a).

(4) Notification to implement the alternative valve standard specified in §265.1062(b)

(2), or (b) (3).

# 165

Based on previous experience, EPA estimates that, each year, five percent of interim status units

subject to Subpart BB will decide to implement the a lternative standard specified in §265.1062(b)(2) or

(b)(3). Therefore, these units will be required to pr epare notification to implement the alternate valve

standard specified in §§ 265.1062(b) (2) or (b) (3).

(5) Non-Hazardous Waste Documentation

Based on previous experience, EPA estimates that te n percent of existing interim status units with

equipment subject to Subpart BB will use knowledge to determine that each piece of equipment does or

does not contain hazardous waste with organic concentra tion that equals or exceeds ten percent waste.

EPA estimates that units will make these determinati ons four times per year. Therefore, these units will

be required to prepare non-hazardous wa ste documentation four times per year.

O&M costs for this activity include one-time contr actor fees associated with analyzing the waste.

(6) Facility operating record

All interim status units subject to Subpart BB ar e required to maintain a unit operating record.

The contents of the operating record will vary accord ing to unit-specific circumstances. A discussion of

the respondent burden for each data item is presented below:

• Equipment Record

This ICR assumes that existing interim status un its with equipment subject to Subpart BB have

already prepared an equipment record. Therefore, no units will be required to prepare an equipment

record.

EPA estimates that all interim status units will r eassess, file, and maintain their equipment record,

and 30 percent will modify it annually.

• Implementation Schedule

This ICR assumes that existing interim status un its with equipment subject to Subpart BB have

already prepared an implementation schedule. Th erefore, no units will be required to prepare an

implementation schedule.

EPA estimates that all interim status units will reassess, file, and maintain their implementation

schedule, and 30 percent will modify it annually.

• Performance Test Plan

This ICR assumes that existing interim status units using test data to demonstrate the organic

removal efficiency or total organic compound concen tration achieved by the control device have already

prepared a performance test plan. Therefore, no units w ill be required to prepare a performance test plan.

EPA estimates that all interim status units usi ng test data to demonstrate the organic removal

efficiency or total organic compound concentration ach ieved by the control device will reassess, file, and

maintain their performance test plan, and 30 percent will modify it annually.

# 166

• Documentation of Compliance with §265.1060

This ICR assumes that existing interim status units subject to Subpart BB have already prepared a

documentation of compliance. Therefore, EPA estimates that zero units will be required to prepare

§265.1060 compliance documentation.

EPA estimates that all interim status units w ill reassess, file, and maintain their §265.1060

compliance documentation, and 30 percent will modify it annually.

• Leak Inspection Log

EPA estimates that all interim status units w ill be required to prepare and maintain a leak

inspection log. All interim status un its will be required to reassess and m odify their leak inspection log.

• Design, Monitoring, Operation, and Inspection Information

This ICR assumes that existing interim status un its with equipment subject to Subpart BB have

already prepared design, monitoring, and inspection information for each closed-vent system and control

device. Therefore no units will be required to prepare design, monitoring, operation, and inspection

information.

EPA estimates that all interim status units with closed-vent systems and control devices will

reassess, file, and maintain control device opera tion documentation, and 30 percent will modify it

annually.

 Monitoring and Inspection Inform ation for Other Control Devices

Based on previous experience, EPA estimates that one percent of existing interim status units

with equipment subject to Subpart BB has a contro l device other than a thermal vapor incinerator,

catalytic vapor incinerator, flare, boiler, process heater, condenser, or carbon adsorption system. In

addition, EPA assumes that existing interim status units with other types of control devices have already

prepared monitoring and inspection information for each control device. Therefore no units will be

required to prepare monitoring and inspection in formation for other types of control devices.

EPA estimates that all interim status units with other types of control devices will reassess, file,

and maintain control device operation documentati on, and 30 percent of these units will modify it

annually.

• Equipment Log

This ICR assumes that existing interim status units subject to Subpart BB have already prepared

an equipment log. Therefore, no units will be required to prepare an equipment log.

EPA estimates that all interim status units will reassess, file, and maintain their equipment log

annually, and 30 percent will modify it annually.

• Valve Log for Valves Subject to §265.1057(g) and (h)

# 167

This ICR assumes that existing interim status units with valves subject to §265.1057(g) and (h)

have already prepared a valve log. Therefore no units will be required to prepare a valve log.

EPA estimates that all interim status units w ith valves subject to §265.1057(g) and (h) (25

percent) will reassess, file, and maintain their va lve log annually, and 30 percent of these units will

modify it annually.

• Valve Log for Valves Subject to §265.1062

This ICR assumes that existing interim status un its with valves subject to §265.1062 have already

prepared a valve log. Therefore, no units will be required to prepare a valve log.

EPA estimates that all interim status units w ith valves subject to §265.1062 (approximately five

percent) will reassess, file, and maintain their va lve log, and 30 percent will modify it annually.

• Criteria Log

This ICR assumes that existing interim status units subject to Subpart BB have already prepared a

criteria log documenting information required in §§ 2 65.1052(d)(5)(ii) and 265.1053(e)(2) for pumps in

light liquid service and compressors. Therefore, no units will be required to prepare a criteria log.

EPA estimates that all interim status units w ith equipment subject to §§ 265.1052(d)(5)(ii) and

265.1053(e)(2) will reassess, file, and maintain their cr iteria log and 30 percent will modify it annually.

• Exemption Log

This ICR assumes that existing interim status units potentially subject to Subpart BB have already

documented information determining applicability of S ubpart BB to their unit’s equipment. Therefore, no

units will be required to prepare this documentation. EPA estimates that all interim status units will

reassess, file, and maintain this documentati on, and 30 percent will modify it annually.

Permitted units:

EPA estimates that these permitted units are subject to 40 CFR Part 264, Subpart BB.

(1) Read the Regulations

EPA assumes that owners and operators of ex isting permitted units have already read the

regulations.

(2) Notification to implement the alternat e valve standard specified in §264.1061(a)

Based on previous experience, EPA estimates th at, each year, 20 percent of permitted units

subject to Subpart BB will decide to implement the alternative standard specified in §264.1061(a).

Therefore, these units will be required to prepare notif ication to implement the alternate valve standard

specified in §264.1061(a).’

# 168

(3) Notification to discontinue implementing the alternative valve standard specified in

§264.1061(a)

Based on previous experience, EPA estimates th at permitted units subject to Subpart BB have

implemented the alternative standard for valves speci fied in §264.1061(a) and one percent of these units

will discontinue using the alternative standard each year. Therefore, these units will be required to

prepare notification to discontinue implementing the alternate valve standard specified in §264.1061(a).

(4) Notification to implement the alt ernative valve standard specified in

§264.1062(b)(2), or (b)(3)

Based on previous experience, EPA estimates that , each year, five percent of permitted units

subject to Subpart BB will decide to implement the a lternative standard specified in §264.1062(b)(2) or

(b)(3). Therefore, these units will be required to pr epare notification to implement the alternate valve

standard specified in §264.1062(b)(2) or (b)(3).

(5) Non-Hazardous Waste Documentation

Based on previous experience, EPA estimates that ten percent of existing permitted units with

equipment leaks subject to Subpart BB will use knowl edge to determine that each piece of equipment

does or does not contain hazardous waste with organic concentration that equals or exceeds ten percent

waste. EPA estimates that units will make these dete rminations four times per year. Therefore, these

units will be required to prepare non-hazardous waste documentation four times per year.

O&M costs for this activity include one-time cont ractor fees associated with analyzing waste.

(6) Facility operating record

All permitted units subject to Subpart BB are requi red to maintain a unit operating record. The

contents of the operating record will vary according to unit-specific circumstanc es. A discussion of the

respondent burden for each data item is presented below:

• Equipment Record

This ICR assumes that existing permitted units with equipment subject to Subpart BB have

already prepared an equipment record.

EPA estimates that all permitted units will reassess, file, and maintain their equipment record, and

10 percent will modify it annually.

• Implementation Schedule

This ICR assumes that existing permitted units with equipment subject to Subpart BB have

already prepared an implementation schedule.

EPA estimates that all permitted units will reass ess, file, and maintain their implementation

schedule, and 10 percent will modify it annually.

# 169

• Performance Test Plan

This ICR assumes that existing permitted units using test data to demonstrate the organic removal

efficiency or total organic compound concentration ach ieved by the control device have already prepared

a performance test plan.

EPA estimates that all permitted units using t est data to demonstrate the organic removal

efficiency or total organic compound concentration ach ieved by the control device will reassess, file, and

maintain their performance test plan, and 10 percent will modify it annually.

• Documentation of Compliance with §264.1060

This ICR assumes that existing permitted units su bject to Subpart BB have already prepared a

documentation of compliance.

EPA estimates that all permitted units will r eassess, file, and maintain their §264.1060

compliance documentation, and 10 percent will modify it annually.

• Leak Inspection Log

EPA estimates that all permitted units subject to Subpart BB will have equipment leaks during the

period covered by this ICR. Therefore, all permitted units will be required to prepare and maintain a leak

inspection log. All permitted un its will be required to reassess and modify their inspection log.

• Design, monitoring, operation, and inspection information

This ICR assumes that existing permitted units with equipment subject to Subpart BB have

already prepared design, monitoring, and inspection information for each closed-vent system and control

device.

EPA estimates that all permitted units with clo sed-vent systems and cont rol devices will reassess,

file, and maintain control device operation document ation, and 10 percent will modify it annually.

 Monitoring and Inspection Inform ation for Other Control Devices

Based on previous experience, EPA estimates that one percent of existing permitted units with

equipment subject to Subpart BB will have a contro l device other than a thermal vapor incinerator,

catalytic vapor incinerator, flare, boiler, process heater, condenser, or carbon adsorption system. In

addition, EPA assumes that existing permitted units with other types of control devices have already

prepared monitoring and inspection information for each control device. Therefore no units will be

required to prepare monitoring and inspection in formation for other types of control devices.

EPA estimates that all permitted units with other types of control devices will reassess, file, and

maintain control device operation documentation, and 30 percent will modify it annually.

• Equipment Log

# 170

This ICR assumes that existing permitted units with equipment subject to Subpart BB have

already prepared an equipment log.

EPA estimates that all permitted units will reassess, file, and maintain thei r equipment log, and 10

percent will modify it annually.

• Valve Log for Valves Subject to §264.1057(g) and (h)

This ICR assumes that existing permitted units with valves subject to §264.1057(g) and (h) have

already prepared a valve log.

EPA estimates that all permitted units with valves subject to §264.1057(g) and (h) (approximately

25 percent of all permitted units) will reassess, file, and maintain their valve log, and 10 percent will

modify it annually.

• Valve Log for Valves Subject to §264.1062

This ICR assumes that existing permitted units w ith valves subject to §264.1062 have already

prepared a valve log.

EPA estimates that all permitted units with valv es subject to §264.1062 will reassess, file, and

maintain their valve log, and 10 percent will modify it annually.

• Criteria Log

This ICR assumes that existing permitted units su bject to Subpart BB have already prepared a

criteria log documenting information required in §§ 2 64.1052(d)(5)(ii) and 264.1053(e)(2) for pumps in

light liquid service and compressors.

EPA estimates that all permitted units with e quipment subject to §§ 264.1052(d)(5)(ii) and

264.1053(e)(2) will reassess, file, and maintain their crite ria log, and 10 percent will modify it annually.

• Exemption Log

This ICR assumes that existing permitted units po tentially subject to Subpart BB have already

documented information determining applicabilit y of Subpart BB to their unit’s equipment.

EPA estimates that all permitted units will reassess, file, and maintain th is documentation, and 10

percent will modify it annually.

(7) Semiannual Report of Cont rol Device Monitoring Events

Based on previous experience, EPA estimates that 60 percent of existing permitted units will have

control devices that have exceeded or operated outside design specifications or have flares with visible

emissions.

CONTAINMENT BUILDINGS

# 171

Interim status units:

EPA estimates that these interim status units are subject to 40 CFR Part 265, Subpart DD.

(1) Read the Regulations

EPA assumes that owners and operators of existi ng interim status units have already read the

regulations. Thus, EPA estimates that there is no burden associated with this activity.

(2) Demonstration that unit meets the standards of Subpart DD

EPA estimates that no units will demonstrate th at the unit substantially meets standards of

Subpart DD in order to delay the secondary containment requirement (§265.1101(b)).

(3) Certification and Response Procedures

EPA estimates that no units will need to obtain a professional engineer’s certification and place it

in the unit’s operating record. In addition, EPA estimates that 25 percent of interim status units will

detect leaks or spills from containment buildings. Th us, one unit will collect in formation associated with

leaks or spills from containment buildings. EPA estimat es that all interim status units will inspect and

record in the facility’s operating record, at least once every seven days, data specified in §265.1101.

O&M costs for this activity include one-time contractor fees associated with obtaining a

certification by a registered engineer that the cont ainment building meets the requirements of Section

265.1101(a)-(c).

(4) Operating Procedures for Area s without Secondary Containment

EPA estimates that 50 percent of the interim status units will maintain in the unit log a written

description of operating procedures used to main tain the integrity of areas without secondary

containment, as specified in §265.1101(d)(3).

(5) Demonstration for Exemption from Secondary Containment Requirements

EPA estimates that 50 percent of the interim status units will demonstrate that the only free

liquids in the containment building are limited amount s of dust suppression liquids in order to obtain a

waiver from the secondary containment requirements under §265.1101(e).

O&M costs for this activity include one-time fees associated with contractor services in preparing

a demonstration that the only free liquids in the unit are limited to amounts of dust suppression liquid.

Permitted units:

EPA estimates that these permitted units are subject to 40 CFR Part 264, Subpart DD.

(1) Read the Regulations

# 172

EPA assumes that owners and operators of ex isting permitted units have already read the

regulations.

(2) Demonstration that unit meets the standards of Subpart DD

EPA estimates that 10 percent of the newly pe rmitted units with containment buildings will

demonstrate that the unit substantially meets standa rds of Subpart DD in order to delay the secondary

containment requirement (§264.1101(b)).

(3) Certification and Response Procedures

EPA estimates that, each year, 25 percent of the universe will detect leaks or spills from

containment buildings. These units will have to reco rd the spill, schedule necessary repairs and cleanup,

and notify EPA. EPA expects all units to inspect and record data weekly.

O&M costs for this activity include one-time fe es associated with obtaining a certification by a

registered engineer that the containment building meets the requirements of Section 265.1101(a)-(c).

(4) Operating Procedures for Area s without Secondary Containment

EPA estimates that 50 percent of the permitted cont ainment buildings will maintain in the unit log

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

containment, as specified in §264.1101(d)(3).

(5) Demonstration for Exemption from Secondary Containment Requirements

EPA estimates that 50 percent of the permitted units will demonstrate that the only free liquids in

the containment building are limited amounts of dust suppression liquids in order to obtain a waiver from

the secondary containment requirements under §264.1101(e).

O&M costs for this activity include one-time fees associated with contractor services in preparing

a demonstration that the only free liquids in the unit are limited to amounts of dust suppression liquid.

# 173

6(e) BOTTOM LINE BURDEN HOURS AND COSTS

Respondent and Agency bottom line burden hours and costs are summarized in this subsection.

The bottom line burden hours and cost to respondents and agencies are based on a three-year time-span

over which the ICR is effective.

Respondent Tally

Exhibits 13a and b below summarize, respectivel y, the total annual Private and non-federal

Governments respondent burdens and costs associated w ith all the requirements covered in this ICR. For

the sum of the two exhibits, EPA estimates the total annual respondent burden to be 637,022 hours at a

total annual cost of $3,718,200

Agency Tally

Exhibits 15 below summarizes the total annual EPA and State burden and cost associated with all

the requirements covered in this ICR. EPA estimates the total annual agency burd en to be 1,311 hours at

a total annual cost of $66,807.

6(f) REASONS FOR CHANGE IN BURDEN

There is an increase in burden of 10,546 hours over the previous ICR. This increase is mainly

due to an increase in the number of e quipment leaks reporting in RCRAInfo.

6(g) BURDEN STATEMENT

The public (Private and Govern ments respondents) reporting burden for each of the requirements

covered in this ICR are listed in Exhibits 16a and b below.

Burden means the total time, effort, or fina ncial 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 in formation, processing and maintaining information,

and disclosing and providing information; adjust the existing ways to comply with any previously

applicable instructions and requirements; train pe rsonnel to be able to respond to a collection of

information; search data sources; complete and revi ew the collection of information; and transmit or

otherwise disclose the information. An agency may not conduct or sponsor, a nd 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 lis ted in 40 CFR Part 9 and 48 CFR Chapter 15.

To comment on the Agency’s need for this in formation, 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 No. EPA-HQRCRA-2010-0834, which is available for public viewing at the Resource Conservation and Recovery Act

(RCRA) Docket in the EPA Docket Center (EPA/D C), EPA West, Room 3334, 1301 Constitution Ave.,

NW, Washington, DC. The EPA/DC Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday

through Friday, excluding legal holidays. The te lephone 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

# 174

public docket is available through http://www.regulations.gov by entering the Docket ID above in the

search form.

Use http://www.regulations.gov 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. Once in the system, select “search,” then key in the docket ID number identified above.

Also, you can send comments to the Office of In formation and Regulatory Affairs, Office of

Management and Budget, 725 17 th 

# Street, NW, Washington DC 20503, Attention: Desk Officer for EPA.

Please include the EPA Docket ID No. EPA-HQ-RCRA-2010-0834 and OMB Control No. 2050-0050 in

any correspondence.

# EXHIBITS APPENDIX1EXHIBIT 1aCONTAINERS - INTERIM STATUS FACILITIESANNUAL PRIVATE RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/Cost/Startup O&M of Res- Hours/Cost/ACTIVITYYear Year Cost Cost pondents Year YearContainers - Interim StatusRead the RegulationsRead the Regulations0.00 0.00 12.00 0.00 12.00 $450.61 $0.00 $0.00 0 0.00 $0.00Inspections (265.195)Recordallinspectiondata0.000.0072.500.0072.50$2,722.41$0.00$0.0039,352.50$8,167.24SUBTOTAL0.000.00varies0.00varies varies varies$0.00varies9,352.50$8,167.24EXHIBIT 1a (CONTINUED)CONTAINERS - PERMITTEDANNUAL PRIVATE RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearContainers- PermittedRead the RegulationsRead the Regulations0.00 0.00 12.00 0.00 12.00 $450.61 $0.00 $0.00 0 576.00 $0.00Inspections (264.195)Recordallinspectiondata0.000.0072.500.0072.50$2,722.41$0.00$0.0021165,032.50$574,429.35SUBTOTAL0.000.00varies0.00varies varies varies$0.00varies65,608.50$574,429.35GRANDTOTAL0.000.00varies0.00varies varies varies$0.00varies74,961.00$582,596.592EXHIBIT 1bCONTAINERS - INTERIM STATUS FACILITIESANNUAL GOVERNMENTS RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearContainers - Interim StatusRead the RegulationsRead the Regulations0.00 0.00 12.00 0.00 12.00 $394.08 $0.00 $0.00 0 0.00 $0.00Inspections (265.195)Recordallinspectiondata0.000.0072.500.0072.50$2,380.90$0.00$0.0039,352.50$7,142.70SUBTOTAL0.000.00varies0.00varies varies varies$0.00varies9,352.50$7,142.70EXHIBIT 1b (CONTINUED)CONTAINERS - PERMITTEDANNUAL GOVERNMENTS RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearContainers- PermittedRead the RegulationsRead the Regulations0.00 0.00 12.00 0.00 12.00 $394.08 $0.00 $0.00 0 576.00 $0.00Inspections (264.195)Recordallinspectiondata0.000.0072.500.0072.50$2,380.90$0.00$0.0057765,032.50$1,373,779.30SUBTOTAL0.000.00varies0.00varies varies varies$0.00varies65,608.50$1,373,779.30GRANDTOTAL0.000.00varies0.00varies varies varies$0.00varies74,961.00$1,380,922.003EXHIBIT 2aTANK SYSTEMS - INTERIM STATUS FACILITIESANNUAL PRIVATE RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/Cost/Startup O&M of Res- Hours/Cost/ACTIVITYYear Year Cost Cost pondents Year YearTank Systems - Interim StatusRead the RegulationsRead the Regulations0.00 0.00 12.00 0.00 12.00 $450.61 $0.00 $0.00 0 0.00 $0.00No free liquids demonstration (265.190(a))PerformPaintFilterLiquidsTest(40times annually)0.000.0060.000.0060.00$2,253.03$0.00$80.00136.00$1,399.82File test results atfacility(40times annually)0.000.000.0020.0020.00$439.71$0.00$0.00112.00$263.83Assessment of existing tank systems' integrity (265.191)Perform theleaktest(265.191(b)(5)(i)and(ii))0.002.008.000.7510.75$472.78$0.00$1,850.0000.00$0.00Prepare certifiedassessment0.000.001.000.501.50$48.54$0.00$340.0000.00$0.00File assessment at thefacility0.000.000.000.500.50$10.99$0.00$0.0000.00$0.00Design and installation of new tank systems or components (265.192)Prepare, review , andcertify w ritten assessment1.003.50130.003.00137.50$5,329.96$0.00$6,300.0000.00$0.00Obtain w ritten statementsfromcertifier oftankdesign andsuperviser ofitsinstallation0.000.000.500.501.00$29.77$0.00$0.0000.00$0.00Maintain the statements at thefacility0.000.000.000.500.50$10.99$0.00$0.00126.00$131.91Equivalent containment devices (265.193(d)(4))Gatherinformation that thedeviceis equivalent to aliner, vault, ordouble-w alledtank1.002.5020.002.5026.00$1,110.46$0.00$10,000.004102.96$43,997.44Submitinformation to theRegion0.000.000.000.500.50$10.99$0.00$3.0041.98$55.41Exemption from 24-hour leak detection requirement (265.193(e)(3)(iii))Compile evidence that theLDScannotdetectfailure or contamination within24hours1.001.0010.001.0013.00$585.07$0.00$5,000.0000.00$0.00Submit evidence to theRegion0.000.000.000.500.50$10.99$0.00$3.0000.00$0.00Variance from secondary containment requirements (265.193(g))Prepare andsubmit notification ofintent to conductdemonstration0.000.501.500.502.50$106.29$0.00$3.0000.00$0.00Prepare thedemonstration0.001.0020.001.0022.00$850.94$0.00$3,000.0000.00$0.00Submitdemonstration to theRegion0.000.000.000.500.50$10.99$0.00$3.0000.00$0.00Annual leak tests and inspections (265.193(i))For non-enterable undergroundtanks conductleaktests(265.191(b)(5))0.000.008.000.758.75$316.89$0.00$1,850.0000.00$0.00For other tanks/ancillary equipment, conduct annualleaktests/inspections0.000.002.000.002.00$75.10$0.00$1,850.0000.00$0.00Recordinspection andtest results0.000.001.000.501.50$48.54$0.00$0.0000.00$0.00Inspections (265.195)Recordallinspectiondata0.000.0072.500.0072.50$2,722.41$0.00$0.0012870.00$32,668.97Exemption from 24-hour waste removal requirement (265.196(b))Compile evidence that, within24hours, enoughw aste cannotberemovedto preventfurther release andallowforinspection andrepair0.000.504.000.505.00$200.17$0.00$2,000.0014.95$2,178.16Submit evidence to theRegion0.000.000.000.300.30$6.60$0.00$3.0010.30$9.50Release notifications and reports (265.196(d)); major repair certification (265.196(f))Notify theRegion ofrelease0.000.500.000.250.75$44.47$0.00$3.0032.25$142.40Prepare report on the release0.001.007.501.009.50$381.56$0.00$0.00328.50$1,144.67Obtain certification0.000.002.000.502.50$86.09$0.00$340.0025.00$852.19Submit certification to theRegion0.000.000.000.500.50$10.99$0.00$3.0021.00$27.99Decontamination demonstration (265.197)Preparedecontaminationdemonstration0.000.503.000.504.00$162.62$0.00$600.0000.00$0.00Submitdemonstration toEPA0.000.000.000.500.50$10.99$0.00$3.0000.00$0.00Waste analysis and trial tests (265.200)Conduct w aste analyses andtrialtests0.000.005.000.005.00$187.75$0.00$750.0000.00$0.00Obtain w ritten,documentedinformation to show that theproposedtreatment or storage willmeet the requirements of§265.194(a)0.000.001.000.501.50$48.54$0.00$0.0000.00$0.00SUBTOTALvaries varies varies varies varies varies varies varies varies1,070.94$82,872.294EXHIBIT 2a (CONTINUED)TANK SYSTEMS - PERMITTEDANNUAL PRIVATE RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearTank Systems - PermittedRead the RegulationsRead the Regulations0.00 0.00 12.00 0.00 12.00 $450.61 $0.00 $0.00 0 0.00 $0.00No free liquids demonstration (264.190(a))Perform Paint Filter Liquids Tests (40 times annually) 0.00 0.00 60.00 0.00 60.00 $2,253.03 $0.00 $80.00 1 60.00 $2,333.03File test results at facility (40 times annually) 0.00 0.00 0.00 20.00 20.00 $439.71 $0.00 $0.00 1 20.00 $439.71Assessment of existing tank systems' integrity (264.191)Perform the leak test (265.191(b)(5)(i) and (ii)) 0.00 2.00 8.00 0.75 10.75 $472.78 $0.00 $1,850.00 0 0.00 $0.00Prepare certified assessment 0.00 0.00 1.00 0.50 1.50 $48.54 $0.00 $340.00 0 0.00 $0.00File assessment at the facility 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 0 0.00 $0.00Design and installation of new tank systems or components (264.192)Obtain w ritten statements from those w ho certified the tanksystem designand supervised its installation 0.00 0.00 0.50 0.50 1.00 $29.77 $0.00 $0.00 0 0.00 $0.00Maintain statements at the facility 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 52 26.00 $571.63Annual leak tests and inspections (264.193(i))For non-enterable underground tanks, conduct a leak test (264.191(b)(5)) 0.00 0.00 8.00 0.75 8.75 $316.89 $0.00 $1,850.00 0 0.00 $0.00For all other tanks and ancillary equipment, conduct annual leaktests or develop a schedule for assessing the condition of the tanksystem 0.00 0.00 2.00 0.00 2.00 $75.10 $0.00 $1,850.00 0 0.00 $0.00Record inspections and test results 0.00 0.00 1.00 0.50 1.50 $48.54 $0.00 $0.00 0 0.00 $0.00Inspections (264.195)Recordallinspectiondata0.000.0072.500.0072.50$2,722.41$0.00$0.00523,770.00$141,565.53Exemption from the 24-hour waste removal requirement (264.196(b))Compile evidence that, w ithin 24 hours, enough w aste cannot beremoved to prevent further release and allow for inspection and repair 0.00 0.50 4.00 0.50 5.00 $200.17 $0.00 $1,850.00 4 20.00 $8,200.66Submit evidence to the Region 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $3.00 4 2.00 $55.97Release notifications and reports (264.196(d)); major repair certifications (264.196(f))Notify the Region of release 0.00 0.50 0.00 0.25 0.75 $44.47 $0.00 $3.00 13 9.75 $617.08Prepare report on the release 0.00 1.00 7.50 1.00 9.50 $381.56 $0.00 $0.00 13 123.50 $4,960.24Obtain certification0.00 0.00 2.00 0.50 2.50 $86.09 $0.00 $340.00 0 0.00 $0.00Submit certification to the Region 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $3.00 0 0.00 $0.00Decontamination demonstration (264.197)Prepare decontamination demonstration 0.00 0.50 3.00 0.50 4.00 $162.62 $0.00 $600.00 0 0.00 $0.00Submit demonstration to EPA 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $3.00 0 0.00 $0.00SUBTOTALvaries varies varies varies varies varies varies varies varies4,031.25$158,743.85GRANDTOTALvaries varies varies varies varies varies varies varies varies5,102.19$241,616.145EXHIBIT 2bTANK SYSTEMS - INTERIM STATUS FACILITIESANNUAL GOVERNMENTS RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearTank Systems - Interim StatusRead the RegulationsRead the Regulations0.00 0.00 12.00 0.00 12.00 $394.08 $0.00 $0.00 0 0.00 $0.00No free liquids demonstration (265.190(a))PerformPaintFilterLiquidsTest(40times annually)0.000.0060.000.0060.00$1,970.40$0.00$80.00027.00$922.68File test results atfacility(40times annually)0.000.000.0020.0020.00$419.00$0.00$0.0009.00$188.55Assessment of existing tank systems' integrity (265.191)Perform theleaktest(265.191(b)(5)(i)and(ii))0.002.008.000.7510.75$388.19$0.00$1,850.0000.00$0.00Prepare certifiedassessment0.000.001.000.501.50$43.32$0.00$340.0000.00$0.00File assessment at thefacility0.000.000.000.500.50$10.48$0.00$0.0000.00$0.00Design and installation of new tank systems or components (265.192)Prepare, review , andcertify w ritten assessment1.003.50130.003.00137.50$4,582.59$0.00$6,300.0000.00$0.00Obtain w ritten statementsfromcertifier oftankdesign andsuperviser ofitsinstallation0.000.000.500.501.00$26.90$0.00$0.0000.00$0.00Maintain the statements at thefacility0.000.000.000.500.50$10.48$0.00$0.0094.50$94.28Equivalent containment devices (265.193(d)(4))Gatherinformation that thedeviceis equivalent to aliner, vault, ordouble-w alledtank1.002.5020.002.5026.00$904.84$0.00$10,000.00377.22$32,387.36Submitinformation to theRegion0.000.000.000.500.50$10.48$0.00$3.0031.49$40.02Exemption from 24-hour leak detection requirement (265.193(e)(3)(iii))Compile evidence that theLDScannotdetectfailure or contamination within24hours1.001.0010.001.0013.00$462.69$0.00$5,000.0000.00$0.00Submit evidence to theRegion0.000.000.000.500.50$10.48$0.00$3.0000.00$0.00Variance from secondary containment requirements (265.193(g))Prepare andsubmit notification ofintent to conductdemonstration0.000.501.500.502.50$87.18$0.00$3.0000.00$0.00Prepare thedemonstration0.001.0020.001.0022.00$732.63$0.00$3,000.0000.00$0.00Submitdemonstration to theRegion0.000.000.000.500.50$10.48$0.00$3.0000.00$0.00Annual leak tests and inspections (265.193(i))For non-enterable undergroundtanks conductleaktests(265.191(b)(5))0.000.008.000.758.75$278.43$0.00$1,850.0000.00$0.00For other tanks/ancillary equipment, conduct annualleaktests/inspections0.000.002.000.002.00$65.68$0.00$1,850.0000.00$0.00Recordinspection andtest results0.000.001.000.501.50$43.32$0.00$0.0000.00$0.00Inspections (265.195)Recordallinspectiondata0.000.0072.500.0072.50$2,380.90$0.00$0.009652.50$21,428.10Exemption from 24-hour waste removal requirement (265.196(b))Compile evidence that, within24hours, enoughw aste cannotberemovedto preventfurther release andallowforinspection andrepair0.000.504.000.505.00$169.28$0.00$2,000.0013.71$1,610.69Submit evidence to theRegion0.000.000.000.300.30$6.29$0.00$3.0010.22$6.89Release notifications and reports (265.196(d)); major repair certification (265.196(f))Notify theRegion ofrelease0.000.500.000.250.75$32.68$0.00$3.0021.50$71.36Prepare report on the release0.001.007.501.009.50$322.13$0.00$0.00219.00$644.26Obtain certification0.000.002.000.502.50$76.16$0.00$340.0012.50$416.16Submit certification to theRegion0.000.000.000.500.50$10.48$0.00$3.0010.50$13.48Decontamination demonstration (265.197)Preparedecontaminationdemonstration0.000.503.000.504.00$136.44$0.00$600.0000.00$0.00Submitdemonstration toEPA0.000.000.000.500.50$10.48$0.00$3.0000.00$0.00Waste analysis and trial tests (265.200)Conduct w aste analyses andtrialtests0.000.005.000.005.00$164.20$0.00$750.0000.00$0.00Obtain w ritten,documentedinformation to show that theproposedtreatment or storage willmeet the requirements of§265.194(a)0.000.001.000.501.50$43.32$0.00$0.0000.00$0.00SUBTOTALvaries varies varies varies varies varies varies varies varies799.14$57,823.816EXHIBIT 2b (CONTINUED)TANK SYSTEMS - PERMITTEDANNUAL GOVERNMENTS RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearTank Systems - PermittedRead the RegulationsRead the Regulations0.00 0.00 12.00 0.00 12.00 $394.08 $0.00 $0.00 0 0.00 $0.00No free liquids demonstration (264.190(a))Perform Paint Filter Liquids Tests (40 times annually) 0.00 0.00 60.00 0.00 60.00 $1,970.40 $0.00 $80.00 5 300.00 $10,252.00File test results at facility (40 times annually) 0.00 0.00 0.00 20.00 20.00 $419.00 $0.00 $0.00 5100.00 $2,095.00Assessment of existing tank systems' integrity (264.191)Perform the leak test (265.191(b)(5)(i) and (ii)) 0.00 2.00 8.00 0.75 10.75 $388.19 $0.00 $1,850.00 0 0.00 $0.00Prepare certified assessment 0.00 0.00 1.00 0.50 1.50 $43.32 $0.00 $340.00 0 0.00 $0.00File assessment at the facility 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 0 0.00 $0.00Design and installation of new tank systems or components (264.192)Obtain w ritten statements from those w ho certified the tanksystem designand supervised its installation 0.00 0.00 0.50 0.50 1.00 $26.90 $0.00 $0.00 0 0.00 $0.00Maintain statements at the facility 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 533 266.50 $5,583.18Annual leak tests and inspections (264.193(i))For non-enterable underground tanks, conduct a leak test (264.191(b)(5)) 0.00 0.00 8.00 0.75 8.75 $278.43 $0.00 $1,850.00 0 0.00 $0.00For all other tanks and ancillary equipment, conduct annual leaktests or develop a schedule for assessing the condition of the tank system 0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 $1,850.00 0 0.00 $0.00Record inspections and test results 0.00 0.00 1.00 0.50 1.50 $43.32 $0.00 $0.00 0 0.00 $0.00Inspections (264.195)Recordallinspectiondata0.000.0072.500.0072.50$2,380.90$0.00$0.0053338,642.50$1,269,019.70Exemption from the 24-hour waste removal requirement (264.196(b))Compile evidence that, w ithin 24 hours, enough w aste cannot beremoved to prevent further release and allow for inspection and repair 0.00 0.50 4.00 0.50 5.00 $169.28 $0.00 $1,850.00 44 220.00 $88,848.10Submit evidence to the Region 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $3.00 44 22.00 $592.90Release notifications and reports (264.196(d)); major repair certifications (264.196(f))Notify the Region of release 0.00 0.50 0.00 0.25 0.75 $32.68 $0.00 $3.00 133 99.75 $4,745.11Prepare report on the release 0.00 1.00 7.50 1.00 9.50 $322.13 $0.00 $0.00 133 1,263.50 $42,843.29Obtain certification0.00 0.00 2.00 0.50 2.50 $76.16 $0.00 $340.00 1 2.50 $416.16Submit certification to the Region 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $3.00 1 0.50 $13.48Decontamination demonstration (264.197)Prepare decontamination demonstration 0.00 0.50 3.00 0.50 4.00 $136.44 $0.00 $600.00 0 0.00 $0.00Submit demonstration to EPA 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $3.00 0 0.00 $0.00SUBTOTALvaries varies varies varies varies varies varies varies varies40,917.25$1,424,408.90GRANDTOTALvaries varies varies varies varies varies varies varies varies41,716.39$1,482,232.717EXHIBIT 3aSURFACE IMPOUNDMENTS - INTERIM STATUSANNUAL RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearSurface Impoundments - Interim StatusRead the RegulationsRead the Regulations0.00 0.00 5.00 0.00 5.00 $187.75 $0.00 $0.00 0 0.00 $0.00Design and operating requirements (265.221) and (265.222)Prepare and submit w ritten assessment ofalternative design and operating practices to EPA or authorized State 1.00 1.00 2.00 1.00 5.00 $284.66 $0.00 $5,000.00 0 0.00 $0.00File and maintain assessment and related data at facility 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 0 0.00 $0.00Prepare and submit the notification of intent 0.00 1.00 0.00 0.25 1.25 $83.44 $0.00 $3.00 0 0.00 $0.00Prepare w ritten identification of alternate design features oroperating plans to prevent overtopping of a dike 0.00 0.00 3.00 0.50 3.50 $123.64 $0.00 $0.00 0 0.00 $0.00Obtain certification that alternate design/operating plans prevent overtopping 0.00 0.00 1.00 0.50 1.50 $48.54 $0.00 $340.00 0 0.00 $0.00Maintain certification andwrittenidentification at thefacility0.000.000.000.500.50$10.99$0.00$0.0000.00$0.00Develop and Submit Action Leakage Rates (265.222(a))Develop andsubmit toEPA0.001.002.501.004.50$193.80$0.00$3,750.0000.00$0.00Maintain results ofanalyses0.000.000.000.500.50$10.99$0.00$0.0010.50$10.99Calculate Average Daily Flow Rates (265.222(c))Calculateflow rates0.000.5020.000.5021.00$800.97$0.00$0.0000.00$0.00Reporting and Recordkeeping of Response Action Plans (265.223(a))Complete theRAP0.0020.0040.001.0061.00$3,082.85$0.00$0.0000.00$0.00Submit theRAPtoEPA0.000.000.000.200.20$4.40$0.00$3.0000.00$0.00Maintain records ofanalyses0.000.000.000.500.50$10.99$0.00$0.0010.50$10.99Action Leakage Reporting (265.223(b))$0.00NotifyEPA,in w riting, ofthe exceedence within7days0.000.500.000.000.50$38.97$0.00$3.0000.00$0.00Submit a w ritten assessment to theRegionalAdministrator within14days ofthedetermination0.000.503.001.004.50$173.61$0.00$3.0000.00$0.00Determine thelocation, size, andcause ofanyleak0.0026.00210.0026.00262.00$10,483.74$0.00$0.0000.00$0.00Determine whether the unit shouldstop or curtailw aste receipt0.003.0015.001.0019.00$819.07$0.00$0.0000.00$0.00Determine whether w aste shouldberemovedfrom the unit or the unit shouldbe closeddow n0.002.0017.502.0021.50$856.99$0.00$0.0000.00$0.00Determine short-term andlong-term actions necessary to mitigate theleak0.004.0030.002.0036.00$1,482.26$0.00$0.0000.00$0.00Compile andsubmitinformation toEPAeachmonththeALRis exceeded(average of6times per year)0.000.006.006.0012.00$357.22$0.00$18.0000.00$0.00Remediation Determination Analyses (265.223(c))Conduct remediationdetermination analyses0.004.0012.000.0016.00$762.38$0.00$800.0000.00$0.00Waste analysis and trial tests (265.225)Conduct w aste analyses0.000.005.000.005.00$187.75$0.00$750.0000.00$0.00Obtain w ritten,documentedinformation to showthat the treatment willcomply with§265.17(b)0.000.001.000.501.50$48.54$0.00$0.0000.00$0.00Monitoring and Inspections (265.226(b)(1))Recordallinspectiondata0.000.0072.500.0072.50$2,722.41$0.00$0.00172.50$2,722.41Develop and Submit Pump Operating Level (265.226(b)(3))Develop andsubmit toEPA0.000.003.750.003.75$140.81$0.00$3.0000.00$0.00Maintain results ofanalyses0.000.000.000.250.25$5.50$0.00$0.0010.25$5.50Requirements for ignitable or reactive waste (265.229)Obtain the certification(265.229)0.000.002.501.003.50$115.86$0.00$340.0000.00$0.00Maintain the certification andrelateddata at thefacility0.000.000.000.500.50$10.99$0.00$0.0000.00$0.00Closure (265.113(e))Prepare and submit contingent corrective measures plan 0.00 0.00 8.00 0.50 8.50 $311.40 $0.00 $5,000.00 0 0.00 $0.00Prepare and submit hazardous w aste removal plan 0.00 0.00 1.00 0.25 1.25 $43.05 $0.00 $3.00 0 0.00 $0.00Prepare and submit extension request 0.00 0.00 1.00 0.25 1.25 $43.05 $0.00 $3.00 0 0.00 $0.00Prepare and submit corrective action report (2 times annually) 0.00 0.00 2.00 0.25 2.25 $80.60 $0.00 $18.00 0 0.00 $0.00TOTALvaries varies varies varies varies varies varies varies varies 73.75$2,749.908EXHIBIT 3a (CONTINUED)SURFACE IMPOUNDMENTS - PERMITTEDANNUAL PRIVATE RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearSurface Impoundments - PermittedRead the RegulationsRead the regulations0.00 0.00 5.00 0.00 5.00 $187.75 $0.00 $0.00 0 0.00 $0.00Calculate Average Daily Flow Rates (264.222(c))Calculate flow rates0.00 0.50 20.00 0.50 21.00 $800.97 $0.00 $0.00 1 21.00 $800.97Action Leakage Reporting (264.223(b))Notify EPA, in w riting, of the exceedence w ithin 7 days 0.00 0.50 0.00 0.00 0.50 $38.97 $0.00 $3.00 0 0.00 $0.00Submit a w ritten assessment to theRegional Administrator w ithin 14 days of the determination 0.00 0.50 3.00 1.00 4.50 $173.61 $0.00 $3.00 0 0.00 $0.00Determine the location, size, and cause of any leak 0.00 26.00 210.00 26.00 262.00 $10,483.74 $0.00 $0.00 0 0.00 $0.00Determine w hether the unit should stop or curtail w aste receipt 0.00 3.00 15.00 1.00 19.00 $819.07 $0.00 $0.00 0 0.00 $0.00Determine w hether w aste should beremoved from the unit or the unit should be closed dow n 0.00 2.00 17.50 2.00 21.50 $856.99 $0.00 $0.00 0 0.00 $0.00Determine short-term and long-term actions necessary to mitigate the leak 0.00 5.90 29.50 1.90 37.30 $1,609.37 $0.00 $0.00 0 0.00 $0.00Compile and submit information to EPAeach month the ALR is exceeded (average of 6 times per year) 0.00 0.00 6.00 6.00 12.00 $357.22 $0.00 $18.00 0 0.00 $0.00Remediation Determination Analyses (264.223(c))Conduct remediation determination analyses 0.00 4.00 12.00 0.00 16.00 $762.38 $0.00 $800.00 0 0.00 $0.00Dike re-certification (264.226(c))Obtain certification that theimpoundment'sdikehas structuralintegrity0.000.003.000.503.50$123.64$0.00$340.0000.00$0.00Maintain certification andrelateddata at thefacility0.000.000.000.500.50$10.99$0.00$0.0000.00$0.00Monitoring and Inspections (264.226(d)(1))Recordallinspectiondata0.000.0072.500.0072.50$2,722.41$0.00$0.002145.00$5,444.83Emergency repairs and contingency plans (264.227)Notify theRegionin w riting0.000.500.000.250.75$44.47$0.00$3.0000.00$0.00Maintain relateddata0.000.000.000.500.50$10.99$0.00$0.0000.00$0.00Obtain certification0.00 0.00 2.00 0.50 2.50 $86.09 $0.00 $340.00 0 0.00 $0.00Maintain certification on file 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 0 0.00 $0.00Closure (264.113(e))Prepare and submit contingent corrective measures plan 0.00 0.00 8.00 0.50 8.50 $311.40 $0.00 $5,000.00 0 0.00 $0.00Prepare and submit hazardous w aste removal plan 0.00 0.00 1.00 0.25 1.25 $43.05 $0.00 $3.00 0 0.00 $0.00Prepare and submit extension request 0.00 0.00 1.00 0.25 1.25 $43.05 $0.00 $3.00 0 0.00 $0.00Prepare and submit corrective action report (2 times annually) 0.00 0.00 2.00 0.25 2.25 $80.60 $0.00 $18.00 0 0.00 $0.00SUBTOTALvaries varies varies varies varies varies varies varies varies166.00$6,245.80GRAND TOTALvaries varies varies varies varies varies varies varies varies239.75$8,995.709EXHIBIT 3bSURFACE IMPOUNDMENTS - INTERIM STATUSANNUAL GOVERNMENTS RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearSurface Impoundments - Interim StatusRead the RegulationsRead the Regulations0.00 0.00 5.00 0.00 5.00 $164.20 $0.00 $0.00 0 0.00 $0.00Design and operating requirements (265.221) and (265.222)Prepare and submit w ritten assessment ofalternative design and operating practices to EPA or authorized State 1.00 1.00 2.00 1.00 5.00 $199.97 $0.00 $5,000.00 0 0.00 $0.00File and maintain assessment and related data at facility 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 0 0.00 $0.00Prepare and submit the notification of intent 0.00 1.00 0.00 0.25 1.25 $60.12 $0.00 $3.00 0 0.00 $0.00Prepare w ritten identification of alternate design features oroperating plans to prevent overtopping of a dike 0.00 0.00 3.00 0.50 3.50 $109.00 $0.00 $0.00 0 0.00 $0.00Obtain certification that alternate design/operating plans prevent overtopping 0.00 0.00 1.00 0.50 1.50 $43.32 $0.00 $340.00 0 0.00 $0.00Maintain certification andwrittenidentification at thefacility0.000.000.000.500.50$10.48$0.00$0.0000.00$0.00Develop and Submit Action Leakage Rates (265.222(a))Develop andsubmit toEPA0.001.002.501.004.50$157.93$0.00$3,750.0000.00$0.00Maintain results ofanalyses0.000.000.000.500.50$10.48$0.00$0.0010.50$10.48Calculate Average Daily Flow Rates (265.222(c))Calculateflow rates0.000.5020.000.5021.00$694.72$0.00$0.0000.00$0.00Reporting and Recordkeeping of Response Action Plans (265.223(a))Complete theRAP0.0020.0040.001.0061.00$2,432.15$0.00$0.0000.00$0.00Submit theRAPtoEPA0.000.000.000.200.20$4.19$0.00$3.0000.00$0.00Maintain records ofanalyses0.000.000.000.500.50$10.48$0.00$0.0010.50$10.48Action Leakage Reporting (265.223(b))$0.00NotifyEPA,in w riting, ofthe exceedence within7days0.000.500.000.000.50$27.44$0.00$3.0000.00$0.00Submit a w ritten assessment to theRegionalAdministrator within14days ofthedetermination0.000.503.001.004.50$146.91$0.00$3.0000.00$0.00Determine thelocation, size, andcause ofanyleak0.0026.00210.0026.00262.00$8,867.98$0.00$0.0000.00$0.00Determine whether the unit shouldstop or curtailw aste receipt0.003.0015.001.0019.00$678.19$0.00$0.0000.00$0.00Determine whether w aste shouldberemovedfrom the unit or the unit shouldbe closeddow n0.002.0017.502.0021.50$726.36$0.00$0.0000.00$0.00Determine short-term andlong-term actions necessary to mitigate theleak0.004.0030.002.0036.00$1,246.62$0.00$0.0000.00$0.00Compile andsubmitinformation toEPAeachmonththeALRis exceeded(average of6times per year)0.000.006.006.0012.00$322.74$0.00$18.0000.00$0.00Remediation Determination Analyses (265.223(c))Conduct remediationdetermination analyses0.004.0012.000.0016.00$613.60$0.00$800.0000.00$0.00Waste analysis and trial tests (265.225)Conduct w aste analyses0.000.005.000.005.00$164.20$0.00$750.0000.00$0.00Obtain w ritten,documentedinformation to showthat the treatment willcomply with§265.17(b)0.000.001.000.501.50$43.32$0.00$0.0000.00$0.00Monitoring and Inspections (265.226(b)(1))Recordallinspectiondata0.000.0072.500.0072.50$2,380.90$0.00$0.00172.50$2,380.90Develop and Submit Pump Operating Level (265.226(b)(3))Develop andsubmit toEPA0.000.003.750.003.75$123.15$0.00$3.0000.00$0.00Maintain results ofanalyses0.000.000.000.250.25$5.24$0.00$0.0010.25$5.24Requirements for ignitable or reactive waste (265.229)Obtain the certification(265.229)0.000.002.501.003.50$103.05$0.00$340.0000.00$0.00Maintain the certification andrelateddata at thefacility0.000.000.000.500.50$10.48$0.00$0.0000.00$0.00Closure (265.113(e))Prepare and submit contingent corrective measures plan 0.00 0.00 8.00 0.50 8.50 $273.20 $0.00 $5,000.00 0 0.00 $0.00Prepare and submit hazardous w aste removal plan 0.00 0.00 1.00 0.25 1.25 $38.08 $0.00 $3.00 0 0.00 $0.00Prepare and submit extension request 0.00 0.00 1.00 0.25 1.25 $38.08 $0.00 $3.00 0 0.00 $0.00Prepare and submit corrective action report (2 times annually) 0.00 0.00 2.00 0.25 2.25 $70.92 $0.00 $18.00 0 0.00 $0.00TOTALvaries varies varies varies varies varies varies varies varies73.75$2,407.0910EXHIBIT 3b (CONTINUED)SURFACE IMPOUNDMENTS - PERMITTEDANNUAL GOVERNMENTS RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearSurface Impoundments - PermittedRead the RegulationsRead the regulations0.00 0.00 5.00 0.00 5.00 $164.20 $0.00 $0.00 0 0.00 $0.00Calculate Average Daily Flow Rates (264.222(c))Calculate flow rates0.00 0.50 20.00 0.50 21.00 $694.72 $0.00 $0.00 1 21.00 $694.72Action Leakage Reporting (264.223(b))Notify EPA, in w riting, of the exceedence w ithin 7 days 0.00 0.50 0.00 0.00 0.50 $27.44 $0.00 $3.00 0 0.00 $0.00Submit a w ritten assessment to theRegional Administrator w ithin 14 days of the determination 0.00 0.50 3.00 1.00 4.50 $146.91 $0.00 $3.00 0 0.00 $0.00Determine the location, size, and cause of any leak 0.00 26.00 210.00 26.00 262.00 $8,867.98 $0.00 $0.00 0 0.00 $0.00Determine w hether the unit should stop or curtail w aste receipt 0.00 3.00 15.00 1.00 19.00 $678.19 $0.00 $0.00 0 0.00 $0.00Determine w hether w aste should beremoved from the unit or the unit should be closed dow n 0.00 2.00 17.50 2.00 21.50 $726.36 $0.00 $0.00 0 0.00 $0.00Determine short-term and long-term actions necessary to mitigate the leak 0.00 5.90 29.50 1.90 37.30 $1,332.38 $0.00 $0.00 0 0.00 $0.00Compile and submit information to EPAeach month the ALR is exceeded (average of 6 times per year) 0.00 0.00 6.00 6.00 12.00 $322.74 $0.00 $18.00 0 0.00 $0.00Remediation Determination Analyses (264.223(c))Conduct remediation determination analyses 0.00 4.00 12.00 0.00 16.00 $613.60 $0.00 $800.00 0 0.00 $0.00Dike re-certification (264.226(c))Obtain certification that theimpoundment'sdikehas structuralintegrity0.000.003.000.503.50$109.00$0.00$340.00414.00$1,795.98Maintain certification andrelateddata at thefacility0.000.000.000.500.50$10.48$0.00$0.0042.00$41.90Monitoring and Inspections (264.226(d)(1))Recordallinspectiondata0.000.0072.500.0072.50$2,380.90$0.00$0.00362,610.00$85,712.40Emergency repairs and contingency plans (264.227)Notify theRegionin w riting0.000.500.000.250.75$32.68$0.00$3.0000.00$0.00Maintain relateddata0.000.000.000.500.50$10.48$0.00$0.0000.00$0.00Obtain certification0.00 0.00 2.00 0.50 2.50 $76.16 $0.00 $340.00 0 0.00 $0.00Maintain certification on file 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 0 0.00 $0.00Closure (264.113(e))Prepare and submit contingent corrective measures plan 0.00 0.00 8.00 0.50 8.50 $273.20 $0.00 $5,000.00 0 0.00 $0.00Prepare and submit hazardous w aste removal plan 0.00 0.00 1.00 0.25 1.25 $38.08 $0.00 $3.00 0 0.00 $0.00Prepare and submit extension request 0.00 0.00 1.00 0.25 1.25 $38.08 $0.00 $3.00 0 0.00 $0.00Prepare and submit corrective action report (2 times annually) 0.00 0.00 2.00 0.25 2.25 $70.92 $0.00 $18.00 0 0.00 $0.00SUBTOTALvaries varies varies varies varies varies varies varies varies2,647.00$88,245.00GRAND TOTALvaries varies varies varies varies varies varies varies varies2,720.75$90,652.0811EXHIBIT 4aWASTE PILES - INTERIM STATUSANNUAL PRIVATE RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearWaste Piles - Interim StatusRead the RegulationsRead the Regulations0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 0 0.00 $0.00Waste analysis (265.252)Conduct w aste analyses 0.00 0.00 5.00 0.00 5.00 $187.75 $0.00 $750.00 0 0.00 $0.00Exemption from design and operating requirements (265.254)Gather the information necessaryfor exemption from liner/leachate system requirements 0.00 0.50 8.00 1.00 9.50$361.36 $0.00 $25,000.00 0 0.00 $0.00Submit demonstration to the Region 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $3.00 0 0.00 $0.00Variance from design and operating requirements (265.254)Gather the information necessaryfor variance from liner/leachate system requirements 0.00 0.50 8.00 1.00 9.50 $361.36 $0.00 $25,000.00 0 0.00 $0.00Submitdemonstration to theRegion0.000.000.000.500.50$10.99$0.00$3.0000.00$0.00Develop and Submit Action Leakage Rates (265.255(a))Develop and submit to EPA 0.00 1.00 2.50 1.00 4.50 $193.80 $0.00 $3,750.00 0 0.00 $0.00Maintain results of analyses 0.00 0.00 0.00 1.00 1.00 $21.99 $0.00 $0.00 0 0.00 $0.00Calculate Average Daily Flow Rates (265.255(c))Calculate average daily flow rates 0.00 0.50 20.00 0.50 21.00 $800.97 $0.00 $0.00 0 0.00 $0.00Reporting and Recordkeeping of Response Action Plans (265.259(a))Complete the RAP0.00 20.00 40.00 1.00 61.00 $3,082.85 $0.00 $0.00 0 0.00 $0.00Submit the RAP to EPA0.00 0.00 0.00 0.20 0.20 $4.40 $0.00 $3.00 0 0.00 $0.00Maintain records of analyses 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 0 0.00 $0.00Action Leakage Reporting (265.259(b))Notify EPA, in w riting, of the exceedence w ithin 7 days 0.00 0.50 0.00 0.00 0.50 $38.97 $0.00 $3.00 0 0.00 $0.00Submit a w ritten assessment to theRegional Administrator w ithin 14 days of the determination 0.00 0.50 3.00 1.00 4.50 $173.61 $0.00 $3.00 0 0.00 $0.00Determine the location, size, and cause of any leak 0.00 26.00 210.00 26.00 262.00 $10,483.74 $0.00 $0.00 0 0.00 $0.00Determine w hether the unit should stop or curtail w aste receipt 0.00 3.00 15.00 1.00 19.00 $819.07 $0.00 $0.00 0 0.00 $0.00Determine w hether w aste should beremoved from the unit or the unit should be closed dow n 0.00 2.00 17.50 2.00 21.50 $856.99 $0.00 $0.00 0 0.00 $0.00Determine short-term and long-term actions necessary to mitigate the leak 0.00 4.00 30.00 2.00 36.00 $1,482.26 $0.00 $0.00 0 0.00 $0.00Compile and submit information to EPA each month the ALR is exceeded 0.00 0.00 6.00 0.00 6.00 $225.30 $0.00 $18.00 0 0.00 $0.00Remediation Determination Analyses (265.259(c))Conduct remediation determination analyses 0.00 4.00 12.00 0.00 16.00 $762.38 $0.00 $800.00 0 0.00 $0.00Monitoring and Inspections (265.260)Record all inspection data 0.00 0.00 13.00 4.00 17.00 $576.10 $0.00 $0.00 0 0.00 $0.00SUBTOTALvaries varies varies varies varies varies varies varies varies0.00$0.0012EXHIBIT 4a (CONTINUED)WASTE PILES - PERMITTEDANNUAL PRIVATE RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearWaste Piles - PermittedRead the RegulationsRead the Regulations0.00 0.00 0.25 0.00 0.25 $9.39 $0.00 $0.00 0 0.00 $0.00Calculate Average Daily Flow Rates (264.252(c))Calculate average daily flow rates 0.00 0.50 20.00 0.50 21.00 $800.97 $0.00 $0.00 0 0.00 $0.00Action Leakage Reporting (264.253(b))Notify EPA, in w riting, of the exceedence w ithin 7 days 0.00 0.50 0.00 0.00 0.50 $38.97 $0.00 $3.00 0 0.00 $0.00Submit a w ritten assessment to theRegional Administrator w ithin 14 days of the determination 0.00 0.50 3.00 1.00 4.50 $173.61 $0.00 $3.00 0 0.00 $0.00Determine the location, size, and cause of any leak 0.00 26.00 210.00 26.00 262.00 $10,483.74 $0.00 $0.00 0 0.00 $0.00Determine w hether the unit should stop or curtail w aste receipt 0.00 3.00 15.00 1.00 19.00 $819.07 $0.00 $0.00 0 0.00 $0.00Determine w hether w aste should beremoved from the unit or the unit should be closed dow n 0.00 2.00 17.50 2.00 21.50 $856.99 $0.00 $0.00 0 0.00 $0.00Determine short-term and long-term actions necessary to mitigate the leak 0.00 4.00 30.00 2.00 36.00 $1,482.26 $0.00 $0.00 0 0.00 $0.00Compile and submit information to EPA each month the ALR is exceeded 0.00 0.00 6.00 6.00 12.00 $357.22 $0.00 $18.00 0 0.00 $0.00Remediation Determination Analyses (264.253(c))Conduct remediation determination analyses 0.00 4.00 12.00 0.00 16.00 $762.38 $0.00 $800.00 0 0.00 $0.00Monitoring and Inspections (264.254(c))Record all inspection data 0.00 0.00 13.00 4.00 17.00 $576.10 $0.00 $0.00 3 51.00 $1,728.30SUBTOTALvaries varies varies varies varies varies varies varies varies 51.00 $1,728.30GRAND TOTALvaries varies varies varies varies varies varies varies varies 51.00 $1,728.3013EXHIBIT 4bWASTE PILES - INTERIM STATUSANNUAL GOVERNMENTS RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearWaste Piles - Interim StatusRead the RegulationsRead the Regulations0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 0 0.00 $0.00Waste analysis (265.252)Conduct w aste analyses0.00 0.00 5.00 0.00 5.00 $164.20 $0.00 $750.00 0 0.00 $0.00Exemption from design and operating requirements (265.254)Gather the information necessaryfor exemption from liner/leachate system requirements 0.00 0.50 8.00 1.00 9.50 $311.11 $0.00 $25,000.00 0 0.00 $0.00Submit demonstration to the Region 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $3.00 0 0.00 $0.00Variance from design and operating requirements (265.254)Gather the information necessaryfor variance from liner/leachate system requirements 0.00 0.50 8.00 1.00 9.50 $311.11 $0.00 $25,000.00 0 0.00 $0.00Submitdemonstration to theRegion0.000.000.000.500.50$10.48$0.00$3.0000.00$0.00Develop and Submit Action Leakage Rates (265.255(a))Develop and submit to EPA 0.00 1.00 2.50 1.00 4.50 $157.93 $0.00 $3,750.00 0 0.00 $0.00Maintain results of analyses 0.00 0.00 0.00 1.00 1.00 $20.95 $0.00 $0.00 0 0.00 $0.00Calculate Average Daily Flow Rates (265.255(c))Calculate average daily flow rates 0.00 0.50 20.00 0.50 21.00 $694.72 $0.00 $0.00 0 0.00 $0.00Reporting and Recordkeeping of Response Action Plans (265.259(a))Complete the RAP0.00 20.00 40.00 1.00 61.00 $2,432.15 $0.00 $0.00 0 0.00 $0.00Submit the RAP to EPA0.00 0.00 0.00 0.20 0.20 $4.19 $0.00 $3.00 0 0.00 $0.00Maintain records of analyses 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 0 0.00 $0.00Action Leakage Reporting (265.259(b))Notify EPA, in w riting, of the exceedence w ithin 7 days 0.00 0.50 0.00 0.00 0.50 $27.44 $0.00 $3.00 0 0.00 $0.00Submit a w ritten assessment to theRegional Administrator w ithin 14 days of the determination 0.00 0.50 3.00 1.00 4.50 $146.91 $0.00 $3.00 0 0.00 $0.00Determine the location, size, and cause of any leak 0.00 26.00 210.00 26.00 262.00 $8,867.98 $0.00 $0.00 0 0.00 $0.00Determine w hether the unit should stop or curtail w aste receipt 0.00 3.00 15.00 1.00 19.00 $678.19 $0.00 $0.00 0 0.00 $0.00Determine w hether w aste should beremoved from the unit or the unit should be closed dow n 0.00 2.00 17.50 2.00 21.50 $726.36 $0.00 $0.00 0 0.00 $0.00Determine short-term and long-term actions necessary to mitigate the leak 0.00 4.00 30.00 2.00 36.00 $1,246.62 $0.00 $0.00 0 0.00 $0.00Compile and submit information to EPA each month the ALR is exceeded 0.00 0.00 6.00 0.00 6.00 $197.04 $0.00 $18.00 0 0.00 $0.00Remediation Determination Analyses (265.259(c))Conduct remediation determination analyses 0.00 4.00 12.00 0.00 16.00 $613.60 $0.00 $800.00 0 0.00 $0.00Monitoring and Inspections (265.260)Record all inspection data 0.00 0.00 13.00 4.00 17.00 $510.72 $0.00 $0.00 0 0.00 $0.00SUBTOTALvaries varies varies varies varies varies varies varies varies0.00$0.0014EXHIBIT 4b (CONTINUED)WASTE PILES - PERMITTEDANNUAL GOVERNMENTS RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearWaste Piles - PermittedRead the RegulationsRead the Regulations0.00 0.00 0.25 0.00 0.25 $8.21 $0.00 $0.00 0 0.00 $0.00Calculate Average Daily Flow Rates (264.252(c))Calculate average daily flow rates 0.00 0.50 20.00 0.50 21.00 $694.72 $0.00 $0.00 0 0.00 $0.00Action Leakage Reporting (264.253(b))Notify EPA, in w riting, of the exceedence w ithin 7 days 0.00 0.50 0.00 0.00 0.50 $27.44 $0.00 $3.00 0 0.00 $0.00Submit a w ritten assessment to theRegional Administrator w ithin 14 days of the determination 0.00 0.50 3.00 1.00 4.50 $146.91 $0.00 $3.00 0 0.00 $0.00Determine the location, size, and cause of any leak 0.00 26.00 210.00 26.00 262.00 $8,867.98 $0.00 $0.00 0 0.00 $0.00Determine w hether the unit should stop or curtail w aste receipt 0.00 3.00 15.00 1.00 19.00 $678.19 $0.00 $0.00 0 0.00 $0.00Determine w hether w aste should beremoved from the unit or the unit should be closed dow n 0.00 2.00 17.50 2.00 21.50 $726.36 $0.00 $0.00 0 0.00 $0.00Determine short-term and long-term actions necessary to mitigate the leak 0.00 4.00 30.00 2.00 36.00 $1,246.62 $0.00 $0.00 0 0.00 $0.00Compile and submit information to EPA each month the ALR is exceeded 0.00 0.00 6.00 6.00 12.00 $322.74 $0.00 $18.00 0 0.00 $0.00Remediation Determination Analyses (264.253(c))Conduct remediation determination analyses 0.00 4.00 12.00 0.00 16.00 $613.60 $0.00 $800.00 0 0.00 $0.00Monitoring and Inspections (264.254(c))Record all inspection data 0.00 0.00 13.00 4.00 17.00 $510.72 $0.00 $0.00 5 85.00 $2,553.60SUBTOTALvaries varies varies varies varies varies varies varies varies 85.00 $2,553.60GRAND TOTALvaries varies varies varies varies varies varies varies varies 85.00 $2,553.6015EXHIBIT 5aLAND TREATMENT - PERMITTEDANNUAL PRIVATE RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearLand Treatment - PermittedRead the regulationsRead the regulations0.00 0.00 2.00 0.00 2.00 $75.10 $0.00 $0.00 0 0.00 $0.00Food-chain crops (264.276)Maintain food-chain crop documentation at the facility 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 0 0.00 $0.00Develop and maintain operating plan (264.276(b)(2)(iii)) 0.00 0.00 1.00 0.25 1.25 $43.05 $0.00 $0.00 0 0.00 $0.00Unsaturated zone monitoring (264.278)Prepare and submit a notice of statistically significant increases 0.00 0.50 10.00 1.00 11.50 $436.46 $0.00 $0.00 0 0.00 $0.00Prepare and submit notice of intent to make a demonstration 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $3.00 0 0.00 $0.00Prepare and submit report 0.00 2.00 6.00 2.00 10.00 $425.16 $0.00 $3.00 0 0.00 $0.00Closure and post-closure care (264.280)Obtain certification ofclosure0.000.000.500.501.00$29.77$0.00$340.0000.00$0.00Submit the certification toEPA0.000.000.000.500.50$10.99$0.00$3.0000.00$0.00Prepare andsubmit thedemonstration0.0010.0080.0010.00100.00$4,003.32$0.00$9,000.0000.00$0.00SUBTOTALvaries varies varies varies varies varies varies varies varies0.00$0.00GRAND TOTALvaries varies varies varies varies varies varies varies varies 0.00 $0.0016EXHIBIT 5bLAND TREATMENT - PERMITTEDANNUAL GOVERNMENTS RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearLand Treatment - PermittedRead the regulationsRead the regulations0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 $0.00 0 0.00 $0.00Food-chain crops (264.276)Maintain food-chain crop documentation at the facility 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 0 0.00 $0.00Develop and maintain operating plan (264.276(b)(2)(iii)) 0.00 0.00 1.00 0.25 1.25 $38.08 $0.00 $0.00 0 0.00 $0.00Unsaturated zone monitoring (264.278)Prepare and submit a notice of statistically significant increases 0.00 0.50 10.00 1.00 11.50 $376.79 $0.00 $0.00 0 0.00 $0.00Prepare and submit notice of intent to make a demonstration 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $3.00 0 0.00 $0.00Prepare and submit report 0.00 2.00 6.00 2.00 10.00 $348.70 $0.00 $3.00 0 0.00 $0.00Closure and post-closure care (264.280)Obtain certification ofclosure0.000.000.500.501.00$26.90$0.00$340.0000.00$0.00Submit the certification toEPA0.000.000.000.500.50$10.48$0.00$3.0000.00$0.00Prepare andsubmit thedemonstration0.0010.0080.0010.00100.00$3,385.50$0.00$9,000.0000.00$0.00SUBTOTALvaries varies varies varies varies varies varies varies varies0.00$0.00GRAND TOTALvaries varies varies varies varies varies varies varies varies 0.00 $0.0017EXHIBIT 6aLANDFILLS - INTERIM STATUSANNUAL PRIVATE RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearLandfills - Interim StatusRead the RegulationsRead the Regulations0.00 0.00 2.00 0.00 2.00 $75.10 $0.00 $0.00 0 0.00 $0.00Design Requirements (265.301)Prepare andsubmit notification ofintention to receive w aste0.000.000.000.250.25$5.50$0.00$3.0000.00$0.00Collect the requiredinformation0.000.507.250.508.25$322.21$0.00$0.0000.00$0.00Submitinformation to theRegion0.000.000.000.500.50$10.99$0.00$3.0000.00$0.00Collect the requiredinformationfor w aiver ofthedoubleliner requirement0.001.008.001.0010.00$400.33$0.00$25,000.0000.00$0.00Submitinformation to theRegion0.000.000.000.500.50$10.99$0.00$3.0000.00$0.00Develop and Submit Action Leakage Rates (265.302(a))Develop andsubmit toEPA0.001.002.501.004.50$193.80$0.00$3,750.0000.00$0.00Maintain results ofanalyses0.000.000.000.500.50$10.99$0.00$0.0000.00$0.00Calculate Average Daily Flow Rates (265.302(c))Calculateflow rates0.000.5020.000.5021.00$800.97$0.00$0.0000.00$0.00Reporting and Recordkeeping of Response Action Plans (265.303(a))Complete theRAP0.0020.0040.001.0061.00$3,082.85$0.00$0.0000.00$0.00Submit theRAPtoEPA0.000.000.000.200.20$4.40$0.00$3.0000.00$0.00Maintain records ofanalyses0.000.000.000.500.50$10.99$0.00$0.0000.00$0.00Action Leakage Reporting (265.303(b))NotifyEPA,in w riting, ofthe exceedence within7days0.000.500.000.000.50$38.97$0.00$3.0000.00$0.00Submit a w ritten assessment to theRegionalAdministrator within14days ofthedetermination0.000.503.001.004.50$173.61$0.00$3.0000.00$0.00Determine thelocation, size, andcause ofanyleak0.0026.00210.0026.00262.00$10,483.74$0.00$0.0000.00$0.00Determine whether the unit shouldstop or curtailw aste receipt0.003.0020.001.0024.00$1,006.82$0.00$0.0000.00$0.00Determine whether w aste shouldberemovedfrom the unit or the unit shouldbe closeddow n0.003.003.501.007.50$387.24$0.00$0.0000.00$0.00Determine short-term andlong-term actions necessary to mitigate theleak0.006.0030.002.0038.00$1,638.14$0.00$0.0000.00$0.00Compile andsubmitinformation toEPAeachmonththeALRis exceeded(6times a year)0.000.001.001.002.00$59.54$0.00$18.0000.00$0.00Remediation Determination Analyses (265.303(c))Conduct remediationdetermination analyses0.0011.0076.008.0095.00$3,887.09$0.00$36,000.0000.00$0.00Monitoring and Inspections (265.304(b))Recordallinspectiondata0.000.0026.004.0030.00$1,064.26$0.00$3.0000.00$0.00Develop and Submit Pump Operating Level (265.304(c))Develop andsubmit toEPA0.000.003.750.504.25$151.81$0.00$0.0000.00$0.00Special requirements for bulk and containerized liquids (265.314)Recordandfile the observation results0.000.002.0010.0012.00$294.96$0.00$0.0000.00$0.00Gatherinformation necessaryfor thedemonstration(265.314(f))0.000.008.000.508.50$311.40$0.00$0.0000.00$0.00Submitinformation to theRegion0.000.000.000.500.50$10.99$0.00$3.0000.00$0.00SUBTOTALvaries varies varies varies varies varies varies varies varies0.00$0.0018EXHIBIT 6a (CONTINUED)LANDFILLS - PERMITTEDANNUAL PRIVATE RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearLandfills - PermittedRead the RegulationsRead the Regulations0.00 11.00 2.00 0.00 13.00 $932.47 $0.00 $0.00 0 0.00 $0.00Calculate Average Daily Flow Rates (264.302(c))Calculate average daily flow rates 0.00 0.50 20.00 0.50 21.00 $800.97 $0.00 $0.00 0 0.00 $0.00Monitoring and Inspections (264.303(c)(1))Record all inspection data 0.00 0.00 26.00 4.00 30.00 $1,064.26 $0.00 $0.00 0 0.00 $0.00Action Leakage Reporting (264.304(b))Notify EPA, in w riting, of the exceedence w ithin 7 days 0.00 0.50 0.00 0.00 0.50 $38.97 $0.00 $3.00 0 0.00 $0.00Submit a w ritten assessment to theRegional Administrator w ithin 14 days of the determination 0.00 0.50 3.00 1.00 4.50 $173.61 $0.00 $3.00 0 0.00 $0.00Determine the location, size, and cause of any leak 0.00 26.00 210.00 26.00 262.00 $10,483.74 $0.00 $0.00 0 0.00 $0.00Determine w hether the unit should stop or curtail w aste receipt 0.00 3.00 20.00 1.00 24.00 $1,006.82 $0.00 $0.00 0 0.00 $0.00Determine w hether w aste should beremoved from the unit or the unit should be closed dow n 0.00 3.00 3.50 1.00 7.50 $387.24 $0.00 $0.00 0 0.00 $0.00Determine short-term and long-term actions necessary to mitigate the leak 0.00 6.00 30.00 2.00 38.00 $1,638.14 $0.00 $0.00 0 0.00 $0.00Compile and submit information to EPA each month the ALR is exceeded 0.00 0.00 6.00 6.00 12.00 $357.22 $0.00 $18.00 0 0.00 $0.00Remediation Determination Analyses (264.304(c))Conduct remediation determination analyses 0.00 11.00 76.00 8.00 95.00 $3,887.09 $0.00 $36,000.00 0 0.00 $0.00Special requirements for bulk and containerized liquids (264.314)Recordandfile the observation results0.000.002.0010.0012.00$294.96$0.00$0.0000.00$0.00Gatherinformation necessaryfor thedemonstration(265.314(f))0.000.008.000.508.50$311.40$0.00$0.0000.00$0.00Submitinformation to theRegion0.000.000.000.500.50$10.99$0.00$3.0000.00$0.00SUBTOTALvaries varies varies varies varies varies varies varies varies0.00$0.00GRAND TOTALvaries varies varies varies varies varies varies varies varies 0.00 $0.0019EXHIBIT 6bLANDFILLS - INTERIM STATUSANNUAL GOVERNMENTS RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearLandfills - Interim StatusRead the RegulationsRead the Regulations0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 $0.00 0 0.00 $0.00Design Requirements (265.301)Prepare andsubmit notification ofintention to receive w aste0.000.000.000.250.25$5.24$0.00$3.0000.00$0.00Collect the requiredinformation0.000.507.250.508.25$276.01$0.00$0.0000.00$0.00Submitinformation to theRegion0.000.000.000.500.50$10.48$0.00$3.0000.00$0.00Collect the requiredinformationfor w aiver ofthedoubleliner requirement0.001.008.001.0010.00$338.55$0.00$25,000.0000.00$0.00Submitinformation to theRegion0.000.000.000.500.50$10.48$0.00$3.0000.00$0.00Develop and Submit Action Leakage Rates (265.302(a))Develop andsubmit toEPA0.001.002.501.004.50$157.93$0.00$3,750.0000.00$0.00Maintain results ofanalyses0.000.000.000.500.50$10.48$0.00$0.0000.00$0.00Calculate Average Daily Flow Rates (265.302(c))Calculateflow rates0.000.5020.000.5021.00$694.72$0.00$0.0000.00$0.00Reporting and Recordkeeping of Response Action Plans (265.303(a))Complete theRAP0.0020.0040.001.0061.00$2,432.15$0.00$0.0000.00$0.00Submit theRAPtoEPA0.000.000.000.200.20$4.19$0.00$3.0000.00$0.00Maintain records ofanalyses0.000.000.000.500.50$10.48$0.00$0.0000.00$0.00Action Leakage Reporting (265.303(b))NotifyEPA,in w riting, ofthe exceedence within 7days0.000.500.000.000.50$27.44$0.00$3.0000.00$0.00Submit a w ritten assessment to theRegionalAdministrator within14days ofthedetermination0.000.503.001.004.50$146.91$0.00$3.0000.00$0.00Determine thelocation, size, andcause ofanyleak0.0026.00210.0026.00262.00$8,867.98$0.00$0.0000.00$0.00Determine whether the unit shouldstop or curtailw aste receipt0.003.0020.001.0024.00$842.39$0.00$0.0000.00$0.00Determine whether w aste shouldberemovedfrom the unit or the unit shouldbe closeddow n0.003.003.501.007.50$300.53$0.00$0.0000.00$0.00Determine short-term andlong-term actions necessary to mitigate theleak0.006.0030.002.0038.00$1,356.38$0.00$0.0000.00$0.00Compile andsubmitinformation toEPAeachmonththeALRis exceeded(6times a year)0.000.001.001.002.00$53.79$0.00$18.0000.00$0.00Remediation Determination Analyses (265.303(c))Conduct remediationdetermination analyses0.0011.0076.008.0095.00$3,267.12$0.00$36,000.0000.00$0.00Monitoring and Inspections (265.304(b))Recordallinspectiondata0.000.0026.004.0030.00$937.64$0.00$3.0000.00$0.00Develop and Submit Pump Operating Level (265.304(c))Develop andsubmit toEPA0.000.003.750.504.25$133.63$0.00$0.0000.00$0.00Special requirements for bulk and containerized liquids (265.314)Recordandfile the observation results0.000.002.0010.0012.00$275.18$0.00$0.0000.00$0.00Gatherinformation necessaryfor thedemonstration(265.314(f))0.000.008.000.508.50$273.20$0.00$0.0000.00$0.00Submitinformation to theRegion0.000.000.000.500.50$10.48$0.00$3.0000.00$0.00SUBTOTALvaries varies varies varies varies varies varies varies varies0.00$0.0020EXHIBIT 6b (CONTINUED)LANDFILLS - PERMITTEDANNUAL GOVERNMENTS RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearLandfills - PermittedRead the RegulationsRead the Regulations0.00 11.00 2.00 0.00 13.00 $669.36 $0.00 $0.00 0 0.00 $0.00Calculate Average Daily Flow Rates (264.302(c))Calculate average daily flow rates 0.00 0.50 20.00 0.50 21.00 $694.72 $0.00 $0.00 0 0.00 $0.00Monitoring and Inspections (264.303(c)(1))Record all inspection data 0.00 0.00 26.00 4.00 30.00 $937.64 $0.00 $0.00 43 1,290.00 $40,318.52Action Leakage Reporting (264.304(b))Notify EPA, in w riting, of the exceedence w ithin 7 days 0.00 0.50 0.00 0.00 0.50 $27.44 $0.00 $3.00 0 0.00 $0.00Submit a w ritten assessment to theRegional Administrator w ithin 14 days of the determination 0.00 0.50 3.00 1.00 4.50 $146.91 $0.00 $3.00 0 0.00 $0.00Determine the location, size, and cause of any leak 0.00 26.00 210.00 26.00 262.00 $8,867.98 $0.00 $0.00 0 0.00 $0.00Determine w hether the unit should stop or curtail w aste receipt 0.00 3.00 20.00 1.00 24.00 $842.39 $0.00 $0.00 0 0.00 $0.00Determine w hether w aste should beremoved from the unit or the unit should be closed dow n 0.00 3.00 3.50 1.00 7.50 $300.53 $0.00 $0.00 0 0.00 $0.00Determine short-term and long-term actions necessary to mitigate the leak 0.00 6.00 30.00 2.00 38.00 $1,356.38 $0.00 $0.00 0 0.00 $0.00Compile and submit information to EPA each month the ALR is exceeded 0.00 0.00 6.00 6.00 12.00 $322.74 $0.00 $18.00 0 0.00 $0.00Remediation Determination Analyses (264.304(c))Conduct remediation determination analyses 0.00 11.00 76.00 8.00 95.00 $3,267.12 $0.00 $36,000.00 0 0.00 $0.00Special requirements for bulk and containerized liquids (264.314)Recordandfile the observation results0.000.002.0010.0012.00$275.18$0.00$0.0022264.00$6,053.96Gatherinformation necessaryfor thedemonstration(265.314(f))0.000.008.000.508.50$273.20$0.00$0.0000.00$0.00Submitinformation to theRegion0.000.000.000.500.50$10.48$0.00$3.0000.00$0.00SUBTOTALvaries varies varies varies varies varies varies varies varies1,554.00$46,372.48GRAND TOTALvaries varies varies varies varies varies varies varies varies 1,554.00 $46,372.4821EXHIBIT 7aINCINERATORS - INTERIM STATUSANNUAL PRIVATE RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/Cost/Startup O&M of Res- Hours/Cost/ACTIVITYYear Year Cost Cost pondents Year YearIncinerators - Interim StatusRead the RegulationsRead the regulations0.00 0.00 2.00 0.00 2.00 $75.10 $0.00 $0.00 0 0.00 $0.00Applicability (265.340(b))Determine whether w aste meetsthe requirements anddocument thefactin w riting0.000.508.000.509.00$350.37$0.00$0.0000.00$0.00Filedocumentation at thefacility0.000.000.000.500.50$10.99$0.00$0.0000.00$0.00Waste analysis (265.341)Conduct w aste analysis0.000.005.000.005.00$187.75$0.00$750.0000.00$0.00Monitoring and inspections (265.347(b))Inspect the completeincinerator andassocitedequipment, atleastdaily0.000.001.500.001.50$56.33$0.00$0.0000.00$0.00Inspect allemergency shutdow n controls andsystem alarms0.000.001.500.001.50$56.33$0.00$0.0000.00$0.00Special requirements for hazardous wastes F020, F021, F022, F023, F026, and F027 (265.352(b)(1))Complete the applicationdemonstrating thattheincinerator can meet performance standards0.0025.00200.0025.00250.00$10,008.31$0.00$100,000.0000.00$0.00Submit the application0.000.000.000.500.50$10.99$0.00$3.0000.00$0.00SUBTOTALvaries varies varies varies varies varies varies varies varies0.00$0.00EXHIBIT 7a (CONTINUED)INCINERATORS - PERMITTEDANNUAL PRIVATE RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearIncinerators - PermittedRead the RegulationsRead the regulations0.00 0.00 2.00 0.00 2.00 $75.10 $0.00 $0.00 0 0.00 $0.00Notification of intent to burn hazardous wastes F020, F021, F022, F023, F026, and F027 (264.343(a)(2))Prepare notification0.00 0.25 1.00 0.25 1.50 $62.53 $0.00 $0.00 0 0.00 $0.00Submit notification to the Region 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $3.00 0 0.00 $0.00Monitoring and inspections (264.347(b) and (c))Conduct thorough visual inspections, at least daily,of the incinerator and associated equipment 0.00 0.00 1.50 0.00 1.50 $56.33 $0.00 11 16.50 $619.58Conduct operational testing, at least w eekly,of the emergency w aste feed cutoff systemand associated alarms 0.00 0.00 1.50 0.00 1.50 $56.33 $0.00 11 16.50 $619.58Prepare exemption demonstration (264.347(c)) 0.00 0.00 208.00 0.00 208.00 $7,810.51 $0.00 $0.00 1 208.00 $7,810.51Submit demonstration to the Region 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $3.00 1 0.50 $13.99If the demonstration is approved, inspect athe emergencyw aste feed cutoffsystemand associated alarms on a monthly basis 0.00 0.00 0.25 0.00 0.25 $9.39 $0.00 $0.00 1 0.25 $9.39SUBTOTALvaries varies varies varies varies varies varies varies varies 241.75 $9,073.06GRAND TOTALvaries varies varies varies varies varies varies varies varies241.75$9,073.0622EXHIBIT 7bINCINERATORS - INTERIM STATUSANNUAL GOVERNMENTS RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/Cost/ Startup O&M of Res- Hours/Cost/ACTIVITYYear Year Cost Cost pondents Year YearIncinerators - Interim StatusRead the RegulationsRead the regulations0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 $0.00 0 0.00 $0.00Applicability (265.340(b))Determine whether w aste meetsthe requirements anddocument thefactin w riting0.000.508.000.509.00$300.64$0.00$0.0000.00$0.00Filedocumentation at thefacility0.000.000.000.500.50$10.48$0.00$0.0000.00$0.00Waste analysis (265.341)Conduct w aste analysis0.000.005.000.005.00$164.20$0.00$750.0000.00$0.00Monitoring and inspections (265.347(b))Inspect the completeincinerator andassocitedequipment, atleastdaily0.000.001.500.001.50$49.26$0.00$0.0000.00$0.00Inspect allemergency shutdow n controls andsystem alarms0.000.001.500.001.50$49.26$0.00$0.0000.00$0.00Special requirements for hazardous wastes F020, F021, F022, F023, F026, and F027 (265.352(b)(1))Complete the applicationdemonstrating thattheincinerator can meet performance standards0.0025.00200.0025.00250.00$8,463.75$0.00$100,000.0000.00$0.00Submit the application0.000.000.000.500.50$10.48$0.00$3.0000.00$0.00SUBTOTALvaries varies varies varies varies varies varies varies varies0.00$0.00EXHIBIT 7b (CONTINUED)INCINERATORS - PERMITTEDANNUAL GOVERNMENTS RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearIncinerators - PermittedRead the RegulationsRead the regulations0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 $0.00 0 0.00 $0.00Notification of intent to burn hazardous wastes F020, F021, F022, F023, F026, and F027 (264.343(a)(2))Prepare notification0.00 0.25 1.00 0.25 1.50 $51.80 $0.00 $0.00 0 0.00 $0.00Submit notification to the Region 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $3.00 0 0.00 $0.00Monitoring and inspections (264.347(b) and (c))Conduct thorough visual inspections, at least daily,of the incinerator and associated equipment 0.00 0.00 1.50 0.00 1.50 $49.26 $0.00 41 61.50 $2,019.66Conduct operational testing, at least w eekly,of the emergency w aste feed cutoff system and associated alarms 0.00 0.00 1.50 0.00 1.50 $49.26 $0.00 41 61.50 $2,019.66Prepare exemption demonstration (264.347(c)) 0.00 0.00 208.00 0.00 208.00 $6,830.72 $0.00 $0.00 1 208.00 $6,830.72Submit demonstration to the Region 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $3.00 1 0.50 $13.48If the demonstration is approved, inspect athe emergencyw aste feed cutoff system and associated alarms on a monthly basis 0.00 0.00 0.25 0.00 0.25 $8.21 $0.00 $0.00 1 0.25 $8.21SUBTOTALvaries varies varies varies varies varies varies varies varies 331.75 $10,891.73GRAND TOTALvaries varies varies varies varies varies varies varies varies331.75$10,891.7323EXHIBIT 8aDRIP PADSANNUAL PRIVATE RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearDrip PadsRead the RegulationsRead the Regulations0.00 0.00 1.50 0.00 1.50 $56.33 $0.00 $0.00 0 0.00 $0.00Contingency Plan (265.440(c)(1))Develop and maintain a contingencyplan for discharge of drippage, including documentation of drippage 0.00 0.00 2.00 0.50 2.50 $86.09 $0.00 $0.00 0 0.00 $0.00Assessment of Existing Drip Pad Integrity (265.441(a))Obtain and submit a w ritten certified assessment 0.00 0.50 0.00 0.00 0.50 $38.97 $0.00 $340.00 0 0.00 $0.00Maintain w ritten assessment 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 0 0.00 $0.00Review , update, and re-certify assessment annually 0.00 0.50 0.00 0.00 0.50 $38.97 $0.00 $340.00 0 0.00 $0.00Plan for Upgrading, Repairing, and Modifying the Drip Pad (265.441(b) and (c))Develop and submit a w ritten certified plan 0.00 1.00 8.00 0.00 9.00 $378.35 $0.00 $1,500.00 0 0.00 $0.00Submit the plan0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $3.00 0 0.00 $0.00Obtain and submit as-built draw ings and a certification 0.00 1.00 1.00 0.50 2.50 $126.49 $0.00 $340.00 0 0.00 $0.00Design andOperatingRequirements(265.443(a)(4)(ii),(b)(3),(g),(i), and(k))Obtain and maintain a w ritten certified assessment of a new drip pad 0.00 1.00 0.00 0.00 1.00 $77.94 $0.00 $340.00 0 0.00 $0.00Update and maintain w ritten certified assessment of drip pad annually 0.00 1.00 0.00 0.00 1.00 $77.94 $0.00 $340.00 0 0.00 $0.00Maintain documentation of the date and time of any leakeage collected andremoved from the leakage collectionsystem immediatelyabove the liner 0.00 0.00 1.00 4.00 5.00 $125.49 $0.00 $0.00 0 0.00 $0.00Obtain and maintain a certification of compliance w ith §265.443 froman independent, qualified registered professional engineer 0.00 1.00 0.00 0.00 1.00 $77.94 $0.00 $340.00 0 0.00 $0.00Maintain documentation of the date and time of cleaning of the drip pad 0.00 0.00 1.00 4.00 5.00 $125.49 $0.00 $0.00 0 0.00 $0.00Maintain records of treated w ood on pad 0.00 0.00 1.00 4.00 5.00 $125.49 $0.00 $0.00 0 0.00 $0.00Emergency Response (265.443(m))Enter a record of discovery 0.00 0.00 1.00 0.00 1.00 $37.55 $0.00 $0.00 0 0.00 $0.00Notifiy EPA of each condition w ithin 24 hours 0.00 0.50 0.00 0.25 0.75 $44.47 $0.00 $3.00 0 0.00 $0.00Provide w ritten notification to EPA w ithin 10 w orking days 0.00 0.50 0.00 0.25 0.75 $44.47 $0.00 $3.00 0 0.00 $0.00Prepare and submit report and certificationto EPA w hen all repairs and clean up are complete 0.00 1.00 7.50 1.50 10.00 $392.55 $0.00 $340.00 0 0.00 $0.00Facility Operating Record (265.443(n))Maintain documentation of past operating and w aste handling practices 0.00 2.00 6.00 0.00 8.00 $381.19 $0.00 $0.00 0 0.00 $0.00Inspections (265.444)Inspect and certify liners immediately after construction or installation 0.00 0.00 4.33 0.00 4.33 $162.59 $0.00 $340.00 0 0.00 $0.00Inspect and certify liners on a w eekly basis 0.00 0.00 4.33 0.00 4.33 $162.59 $0.00 $340.00 0 0.00 $0.00GRAND TOTALvaries varies varies varies varies varies varies varies varies 0.00 $0.0024EXHIBIT 8bDRIP PADSANNUAL GOVERNMENTS RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearDrip PadsRead the RegulationsRead the Regulations0.00 0.00 1.50 0.00 1.50 $49.26 $0.00 $0.00 0 0.00 $0.00Contingency Plan (265.440(c)(1))Develop and maintain a contingencyplan for discharge of drippage, including documentation of drippage 0.00 0.00 2.00 0.50 2.50 $76.16 $0.00 $0.00 0 0.00 $0.00Assessment of Existing Drip Pad Integrity (265.441(a))Obtain and submit a w ritten certified assessment 0.00 0.50 0.00 0.00 0.50 $27.44 $0.00 $340.00 0 0.00 $0.00Maintain w ritten assessment 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 0 0.00 $0.00Review , update, and re-certify assessment annually 0.00 0.50 0.00 0.00 0.50 $27.44 $0.00 $340.00 0 0.00 $0.00Plan for Upgrading, Repairing, and Modifying the Drip Pad (265.441(b) and (c))Develop and submit a w ritten certified plan 0.00 1.00 8.00 0.00 9.00 $317.60 $0.00 $1,500.00 0 0.00 $0.00Submit the plan0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $3.00 0 0.00 $0.00Obtain and submit as-built draw ings and a certification 0.00 1.00 1.00 0.50 2.50 $98.20 $0.00 $340.00 0 0.00 $0.00Design andOperatingRequirements(265.443(a)(4)(ii),(b)(3),(g),(i), and(k))Obtain and maintain a w ritten certified assessment of a new drip pad 0.00 1.00 0.00 0.00 1.00 $54.88 $0.00 $340.00 0 0.00 $0.00Update and maintain w ritten certified assessment of drip pad annually 0.00 1.00 0.00 0.00 1.00 $54.88 $0.00 $340.00 0 0.00 $0.00Maintain documentation of the date and time of any leakeage collected andremoved from the leakage collection system immediately above the liner 0.00 0.00 1.00 4.00 5.00 $116.64 $0.00 $0.00 0 0.00 $0.00Obtain and maintain a certification of compliance w ith §265.443 froman independent, qualified registered professional engineer 0.00 1.00 0.00 0.00 1.00 $54.88 $0.00 $340.00 0 0.00 $0.00Maintain documentation of the date and time of cleaning of the drip pad 0.00 0.00 1.00 4.00 5.00 $116.64 $0.00 $0.00 0 0.00 $0.00Maintain records of treated w ood on pad 0.00 0.00 1.00 4.00 5.00 $116.64 $0.00 $0.00 0 0.00 $0.00Emergency Response (265.443(m))Enter a record of discovery 0.00 0.00 1.00 0.00 1.00 $32.84 $0.00 $0.00 0 0.00 $0.00Notifiy EPA of each condition w ithin 24 hours 0.00 0.50 0.00 0.25 0.75 $32.68 $0.00 $3.00 0 0.00 $0.00Provide w ritten notification to EPA w ithin 10 w orking days 0.00 0.50 0.00 0.25 0.75 $32.68 $0.00 $3.00 0 0.00 $0.00Prepare and submit report and certificationto EPA w hen all repairs and clean up are complete 0.00 1.00 7.50 1.50 10.00 $332.61 $0.00 $340.00 0 0.00 $0.00Facility Operating Record (265.443(n))Maintain documentation of past operating and w aste handling practices 0.00 2.00 6.00 0.00 8.00 $306.80 $0.00 $0.00 0 0.00 $0.00Inspections (265.444)Inspect and certify liners immediately after construction or installation 0.00 0.00 4.33 0.00 4.33 $142.20 $0.00 $340.00 0 0.00 $0.00Inspect and certify liners on a w eekly basis 0.00 0.00 4.33 0.00 4.33 $142.20 $0.00 $340.00 0 0.00 $0.00GRAND TOTALvaries varies varies varies varies varies varies varies varies 0.00 $0.0025EXHIBIT 9aMISCELLANEOUS UNITS - PERMITTEDANNUAL PRIVATE RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearMiscellaneous Units - Permitted Facilities OnlyRead the RegulationsRead the regulations0.00 0.00 2.00 0.00 2.00 $75.10 $0.00 $0.00 0 0.00 $0.00GRAND TOTALvaries varies varies varies varies varies varies varies varies 0.00 $0.00EXHIBIT 9bMISCELLANEOUS UNITS - PERMITTEDANNUAL GOVERNMENTS RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearMiscellaneous Units - Permitted Facilities OnlyRead the RegulationsRead the regulations0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 $0.00 0 0.00 $0.00GRAND TOTALvaries varies varies varies varies varies varies varies varies 0.00 $0.0026EXHIBIT 10aPROCESS VENTS - INTERIM STATUSANNUAL PRIVATE RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearProcess Vents - Interim StatusRead the RegulationsRead the regulations0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 0 0.00 $0.00Control Device Operation Documentation (265.1033(i))Gather control device operation/process parameter information 0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 0 0.00 $0.00Document control device/process parameter information 0.00 0.00 2.00 0.00 2.00 $75.10 $0.00 $0.00 0 0.00 $0.00Reassess and file control device operation documentation 0.00 0.00 2.00 0.00 2.00 $75.10 $0.00 $0.00 18 36.00 $1,351.82Modify control device operation documentation 0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 5 20.00 $751.01Maintain documentation at thefacility (265.1035)(e) 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 18 9.00 $197.87Waste Determination (265.1034(d)(2))Gather production process, w aste generation andspecification analysis information (200 times annually) 0.00 400.00 2,800.00 400.00 3,600.00 $145,112.69 $0.00 $40,000.00 2 7,200.00 $370,225.37Document production process, w aste generation andspecification analysis information (200 times annually) 0.00 0.00 0.00 100.00 100.00 $2,198.56 $0.00 $0.00 2 200.00 $4,397.12Maintain documentation at the facility (200 times annually) 0.00 0.00 0.00 100.00 100.00 $2,198.56 $0.00 $0.00 2 200.00 $4,397.12Facility operating record: Implementation schedule (265.1035(b)(1))Prepare implementation schedule 0.00 1.00 6.00 1.00 8.00 $325.23 $0.00 $0.00 0 0.00 $0.00Reassess implementation schedule 0.00 0.00 2.00 0.00 2.00 $75.10 $0.00 $0.00 18 36.00 $1,351.82File and maintain implementation schedule 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 18 9.00 $197.87Modify implementation schedule 0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 5 20.00 $751.01Facility operating record: Up-to-date documentation of compliance with 265.1032 (265.1035(b)(2))Prepare documentation of compliance 0.00 1.00 6.00 1.00 8.00 $325.23 $0.00 $0.00 0 0.00 $0.00Reassess documentation of compliance 0.00 0.00 2.00 0.00 2.00 $75.10 $0.00 $0.00 18 36.00 $1,351.82File and maintain documentation of compliance 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 18 9.00 $197.87Modify documentation of compliance 0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 5 20.00 $751.01Facility operating record: Performance test plan (265.1035(b)(3))Prepare performance test plan 0.00 1.00 6.00 1.00 8.00 $325.23 $0.00 $0.00 0 0.00 $0.00Reassess performance test plan 0.00 0.00 2.00 0.00 2.00 $75.10 $0.00 $0.00 18 36.00 $1,351.82File and maintain performance test plan 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 18 9.00 $197.87Modify performance test plan 0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 5 20.00 $751.01Facility operating record: Documentation of compliance with 265.1033 (265.1035(b)(4))Prepare documentation of compliance 0.00 1.00 6.00 1.00 8.00 $325.23 $0.00 $0.00 0 0.00 $0.00Reassess documentation of compliance 0.00 0.00 2.00 0.00 2.00 $75.10 $0.00 $0.00 18 36.00 $1,351.82File and maintain documentation of compliance 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 18 9.00 $197.87Modify documentation of compliance 0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 5 20.00 $751.01Facility operating record: Design/monitoring/operation/inspection information (265.1035(c))Prepare design/monitoring/operation/inspection information 0.00 1.00 6.00 1.00 8.00 $325.23 $0.00 $0.00 0 0.00 $0.00Reassess design/monitoring/operation/inspection information 0.00 0.00 2.00 0.00 2.00 $75.10 $0.00 $0.00 18 36.00 $1,351.82File and maintain design/monitoring/operation/inspection information 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 18 9.00 $197.87Modify design/monitoring/operation/inspection information 0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 5 20.00 $751.01Facility operating record: Determination of applicability of 265.1032 (265.1035(f))Prepare determination of applicability 0.00 0.00 7.00 1.00 8.00 $284.84 $0.00 $0.00 0 0.00 $0.00Reassess determination of applicability 0.00 0.00 2.00 0.00 2.00 $75.10 $0.00 $0.00 18 36.00 $1,351.82File and maintain determination of applicability 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 18 9.00 $197.87Modify determination of applicability 0.00 0.00 3.00 1.00 4.00 $134.64 $0.00 $0.00 5 20.00 $673.19SUBTOTALvaries varies varies varies varies varies varies varies varies 8,055.00 $395,046.6827EXHIBIT 10a (CONTINUED)PROCESS VENTS - PERMITTEDANNUAL PRIVATE RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearProcess Vents - PermittedRead the RegulationsRead the regulations0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 0 0.00 $0.00Control Device Operation Documentation (264.1033(i))Gather information0.00 0.00 3.50 0.50 4.00 $142.42 $0.00 $0.00 1 4.00 $142.42Document information0.00 0.00 2.00 0.00 2.00 $75.10 $0.00 $0.00 1 2.00 $75.10Reassess and file documentation 0.00 0.00 1.50 0.50 2.00 $67.32 $0.00 $0.00 742 1,484.00 $49,950.40Modify documentation0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 74 296.00 $11,114.96Maintain documentation at the facility (264.1035)(e)(2) 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 742 371.00 $8,156.65Waste Determination (264.1034(d)(2))Gather information (200 times annually) 0.00 400.00 2,800.00 400.00 3,600.00 $145,112.69 $0.00 $40,000.00 74 266,400.00 $13,698,338.72Document information (200 times annually) 0.00 0.00 0.00 100.00 100.00 $2,198.56 $0.00 $0.00 74 7,400.00 $162,693.36Maintain documentation at the facility (200 times annually) 0.00 0.00 0.00 100.00 100.00 $2,198.56 $0.00 $0.00 74 7,400.00 $162,693.36Facility operating record: Implementation schedule (264.1035(b)(1))Prepare implementation schedule 0.00 0.00 7.00 1.00 8.00 $284.84 $0.00 $0.00 0 0.00 $0.00Reassess implementation schedule 0.00 0.00 2.00 0.00 2.00 $75.10 $0.00 $0.00 742 1,484.00 $55,725.00File and maintain implementation schedule 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 742 371.00 $8,156.65Modify implementation schedule 0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 74 296.00 $11,114.96Facility operating record: Up-to-date documentation of compliance with 264.1032 (264.1035(b)(2))Prepare documentationof compliance 0.00 0.00 7.00 1.00 8.00 $284.84 $0.00 $0.00 0 0.00 $0.00Reassess documentation of compliance 0.00 0.00 2.00 0.00 2.00 $75.10 $0.00 $0.00 742 1,484.00 $55,725.00File and maintain documentation of compliance 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 742 371.00 $8,156.65Modify documentation of compliance 0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 74 296.00 $11,114.96Facility operating record: Performance test plan (264.1035(b)(3))Prepare performance test plan 0.00 0.00 7.00 1.00 8.00 $284.84 $0.00 $0.00 0 0.00 $0.00Reassess performance test plan 0.00 0.00 2.00 0.00 2.00 $75.10 $0.00 $0.00 742 1,484.00 $55,725.00File and maintain performance test plan 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 742 371.00 $8,156.65Modify performance test plan 0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 74 296.00 $11,114.96Facility operating record: Documentation of compliance with 264.1033 (264.1035(b)(4))Prepare documentation of compliance 0.00 0.00 7.00 1.00 8.00 $284.84 $0.00 $0.00 0 0.00 $0.00Reasses documentation of compliance 0.00 0.00 2.00 0.00 2.00 $75.10 $0.00 $0.00 742 1,484.00 $55,725.00File and maintain documentation of compliance 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 742 371.00 $8,156.65Modify documentation of compliance 0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 74 296.00 $11,114.96Facility operating record: Design/monitoring/operation/inspection information (264.1035(c))Prepare design/monitoring/operation/inspection information 0.00 0.00 7.00 1.00 8.00 $284.84 $0.00 $0.00 0 0.00 $0.00Reassess design/monitoring/operation/inspection information 0.00 0.00 2.00 0.00 2.00 $75.10 $0.00 $0.00 742 1,484.00 $55,725.00File and maintain design/monitoring/operation/inspection information 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 742 371.00 $8,156.65Modify design/monitoring/operation/inspection information 0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 74 296.00 $11,114.96Facility operating record: Determination of applicability of 264.1032 (264.1035(f))Prepare determination of applicability 0.00 0.00 7.00 1.00 8.00 $284.84 $0.00 $0.00 0 0.00 $0.00Reassess determination of applicability 0.00 0.00 2.00 0.00 2.00 $75.10 $0.00 $0.00 742 1,484.00 $55,725.00File and maintain determination of applicability 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 742 371.00 $8,156.65Modify determination of applicability 0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 74 296.00 $11,114.96Semiannual Report of Control Device Monitoring Events (264.1036)Prepare the semiannual report 0.00 4.00 6.00 6.00 16.00 $668.99 $0.00 $0.00 445 7,120.00 $297,698.86Submit semiannual report tothe Region 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $3.00 445 222.50 $6,226.79SUBTOTALvaries varies varies varies varies varies varies varies varies 303,605.50 $14,847,070.29GRAND TOTALvaries varies varies varies varies varies varies varies varies 311,660.50 $15,242,116.9828EXHIBIT 10bPROCESS VENTS - INTERIM STATUSANNUAL GOVERNMENTS RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearProcess Vents - Interim StatusRead the RegulationsRead the regulations0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 0 0.00 $0.00Control Device Operation Documentation (265.1033(i))Gather control device operation/process parameter information 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 0 0.00 $0.00Document control device/process parameter information 0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 $0.00 0 0.00 $0.00Reassess and file control device operation documentation 0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 $0.00 3 6.00 $197.04Modify control device operation documentation 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 1 4.00 $131.36Maintain documentation at thefacility (265.1035)(e) 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 3 1.50 $31.43Waste Determination (265.1034(d)(2))Gather production process, w aste generation andspecification analysis information (200 times annually) 0.00 400.00 2,800.00 400.00 3,600.00 $122,284.00 $0.00 $40,000.00 0 0.00 $0.00Document production process, w aste generation andspecification analysis information (200 times annually) 0.00 0.00 0.00 100.00 100.00 $2,095.00 $0.00 $0.00 0 0.00 $0.00Maintain documentation at the facility (200 times annually) 0.00 0.00 0.00 100.00 100.00 $2,095.00 $0.00 $0.00 0 0.00 $0.00Facility operating record: Implementation schedule (265.1035(b)(1))Prepare implementation schedule 0.00 1.00 6.00 1.00 8.00 $272.87 $0.00 $0.00 0 0.00 $0.00Reassess implementation schedule 0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 $0.00 3 6.00 $197.04File and maintain implementation schedule 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 3 1.50 $31.43Modify implementation schedule 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 1 4.00 $131.36Facility operating record: Up-to-date documentation of compliance with 265.1032 (265.1035(b)(2))Prepare documentation of compliance 0.00 1.00 6.00 1.00 8.00 $272.87 $0.00 $0.00 0 0.00 $0.00Reassess documentation of compliance 0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 $0.00 3 6.00 $197.04File and maintain documentation of compliance 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 3 1.50 $31.43Modify documentation of compliance 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 1 4.00 $131.36Facility operating record: Performance test plan (265.1035(b)(3))Prepare performance test plan 0.00 1.00 6.00 1.00 8.00 $272.87 $0.00 $0.00 0 0.00 $0.00Reassess performance test plan 0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 $0.00 3 6.00 $197.04File and maintain performance test plan 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 3 1.50 $31.43Modify performance test plan 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 1 4.00 $131.36Facility operating record: Documentation of compliance with 265.1033 (265.1035(b)(4))Prepare documentation of compliance 0.00 1.00 6.00 1.00 8.00 $272.87 $0.00 $0.00 0 0.00 $0.00Reassess documentation of compliance 0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 $0.00 3 6.00 $197.04File and maintain documentation of compliance 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 3 1.50 $31.43Modify documentation of compliance 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 1 4.00 $131.36Facility operating record: Design/monitoring/operation/inspection information (265.1035(c))Prepare design/monitoring/operation/inspection information 0.00 1.00 6.00 1.00 8.00 $272.87 $0.00 $0.00 0 0.00 $0.00Reassess design/monitoring/operation/inspection information 0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 $0.00 3 6.00 $197.04File and maintain design/monitoring/operation/inspection information 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 3 1.50 $31.43Modify design/monitoring/operation/inspection information 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 1 4.00 $131.36Facility operating record: Determination of applicability of 265.1032 (265.1035(f))Prepare determination of applicability 0.00 0.00 7.00 1.00 8.00 $250.83 $0.00 $0.00 0 0.00 $0.00Reassess determination of applicability 0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 $0.00 3 6.00 $197.04File and maintain determination of applicability 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 3 1.50 $31.43Modify determination of applicability 0.00 0.00 3.00 1.00 4.00 $119.47 $0.00 $0.00 1 4.00$119.47SUBTOTALvaries varies varies varies varies varies varies varies varies 80.50 $2,506.8929EXHIBIT 10b (CONTINUED)PROCESS VENTS - PERMITTEDANNUAL GOVERNMENTS RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearProcess Vents - PermittedRead the RegulationsRead the regulations0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 0 0.00 $0.00Control Device Operation Documentation (264.1033(i))Gather information0.00 0.00 3.50 0.50 4.00 $125.42 $0.00 $0.00 1 4.00 $125.42Document information0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 $0.00 1 2.00 $65.68Reassess and file documentation 0.00 0.00 1.50 0.50 2.00 $59.74 $0.00 $0.00 80 160.00 $4,778.80Modify documentation0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 8 32.00 $1,050.88Maintain documentation at the facility (264.1035)(e)(2) 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 80 40.00 $838.00Waste Determination (264.1034(d)(2))Gather information (200 times annually) 0.00 400.00 2,800.00 400.00 3,600.00 $122,284.00 $0.00 $40,000.00 8 28,800.00 $1,298,272.00Document information (200 times annually) 0.00 0.00 0.00 100.00 100.00 $2,095.00 $0.00 $0.00 8 800.00 $16,760.00Maintain documentation at the facility (200 times annually) 0.00 0.00 0.00 100.00 100.00 $2,095.00 $0.00 $0.00 8 800.00 $16,760.00Facility operating record: Implementation schedule (264.1035(b)(1))Prepare implementation schedule 0.00 0.00 7.00 1.00 8.00 $250.83 $0.00 $0.00 0 0.00 $0.00Reassess implementation schedule 0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 $0.00 80 160.00 $5,254.40File and maintain implementation schedule 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 80 40.00 $838.00Modify implementation schedule 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 8 32.00 $1,050.88Facility operating record: Up-to-date documentation of compliance with 264.1032 (264.1035(b)(2))Prepare documentationof compliance 0.00 0.00 7.00 1.00 8.00 $250.83 $0.00 $0.00 0 0.00 $0.00Reassess documentation of compliance 0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 $0.00 80 160.00 $5,254.40File and maintain documentation of compliance 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 80 40.00 $838.00Modify documentation of compliance 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 8 32.00 $1,050.88Facility operating record: Performance test plan (264.1035(b)(3))Prepare performance test plan 0.00 0.00 7.00 1.00 8.00 $250.83 $0.00 $0.00 0 0.00 $0.00Reassess performance test plan 0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 $0.00 80 160.00 $5,254.40File and maintain performance test plan 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 80 40.00 $838.00Modify performance test plan 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 8 32.00 $1,050.88Facility operating record: Documentation of compliance with 264.1033 (264.1035(b)(4))Prepare documentation of compliance 0.00 0.00 7.00 1.00 8.00 $250.83 $0.00 $0.00 0 0.00 $0.00Reasses documentation of compliance 0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 $0.00 80 160.00 $5,254.40File and maintain documentation of compliance 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 80 40.00 $838.00Modify documentation of compliance 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 8 32.00 $1,050.88Facility operating record: Design/monitoring/operation/inspection information (264.1035(c))Prepare design/monitoring/operation/inspection information 0.00 0.00 7.00 1.00 8.00 $250.83 $0.00 $0.00 0 0.00 $0.00Reassess design/monitoring/operation/inspection information 0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 $0.00 80 160.00 $5,254.40File and maintain design/monitoring/operation/inspection information 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 80 40.00 $838.00Modify design/monitoring/operation/inspection information 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 8 32.00 $1,050.88Facility operating record: Determination of applicability of 264.1032 (264.1035(f))Prepare determination of applicability 0.00 0.00 7.00 1.00 8.00 $250.83 $0.00 $0.00 0 0.00 $0.00Reassess determination of applicability 0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 $0.00 80 160.00 $5,254.40File and maintain determination of applicability 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 80 40.00 $838.00Modify determination of applicability 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 8 32.00 $1,050.88Semiannual Report of Control Device Monitoring Events (264.1036)Prepare the semiannual report 0.00 4.00 6.00 6.00 16.00 $542.26 $0.00 $0.00 48 768.00 $26,028.48Submit semiannual report tothe Region 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $3.00 48 24.00 $646.80SUBTOTALvaries varies varies varies varies varies varies varies varies 32,822.00 $1,408,185.74GRAND TOTALvaries varies varies varies varies varies varies varies varies 32,902.50 $1,410,692.6230EXHIBIT 11aEQUIPMENT LEAKS - INTERIM STATUSANNUAL PRIVATE RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearEquipment Leaks - Interim StatusRead the RegulationsRead the regulations0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 0 0.00 $0.00Notification to implement the alternative valve standard in 265.1061(a) (265.1061(b)(1))Prepare notification0.00 0.25 1.00 0.25 1.50 $62.53 $0.00 $0.00 7 10.50 $437.73Submit notification to the Region 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $3.00 7 3.50 $97.95Notification to discontinue alternative valve standard in 265.1061(a) (265.1061(d))Prepare notification0.00 0.25 1.00 0.25 1.50 $62.53 $0.00 $0.00 0 0.00 $0.00Submit notification to the Region 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $3.00 0 0.00 $0.00Notification to implement the alternative valve standard in 265.1062(b)(2) and (3) (265.1062(a)(2))Prepare notification0.00 0.25 1.00 0.25 1.50 $62.53 $0.00 $0.00 2 3.00 $125.07Submit notification to the Region 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $3.00 2 1.00 $27.99Non-hazardous waste documentation (265.1063(d)(3))Gather production process, w astegeneration, andspecification analysis(4times annually)0.000.0016.000.0016.00$600.81$0.00$800.00464.00$5,603.23Document production process,w aste generation andspecification analysis(4times annually)0.000.0016.000.0016.00$600.81$0.00$0.00464.00$2,403.23Maintaindocumentation at thefacility(4times annually)0.000.000.002.002.00$43.97$0.00$0.0048.00$175.88Facility operating record: Equipment record (265.1064(b)(1))Prepare equipment record 0.00 0.00 6.00 1.00 7.00 $247.29 $0.00 $0.00 0 0.00 $0.00Reassess equipment record 0.00 0.00 2.00 0.00 2.00 $75.10 $0.00 $0.00 35 70.00 $2,628.54File and maintain equipment record 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 35 17.50 $384.75Modify equipment record 0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 11 44.00 $1,652.22Facility operating record: Implementation schedule (265.1064(b)(2))Prepare implementation schedule 0.00 0.50 2.00 0.50 3.00 $125.07 $0.00 $0.00 0 0.00 $0.00Reassess implementation schedule 0.00 0.00 1.00 0.00 1.00 $37.55 $0.00 $0.00 35 35.00 $1,314.27File and maintain schedule 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 35 17.50 $384.75Modify implementation schedule 0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 11 44.00 $1,652.22Facility operating record: Performance test plan (265.1064(b)(3))Prepare performance test plan 0.00 1.00 16.00 2.00 19.00 $722.72 $0.00 $0.00 0 0.00 $0.00Reassess performance test plan 0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 4 16.00 $600.81File and maintain plan0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 4 2.00 $43.97Modify performance test plan 0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 1 4.00 $150.20Facility operating record: Documentation of compliance with 265.1060 (265.1064(b)(4))Prepare documentation0.00 1.00 16.00 2.00 19.00 $722.72 $0.00 $0.00 0 0.00 $0.00Reassess documentation 0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 35 140.00 $5,257.08File and maintain documentation 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 35 17.50 $384.75Modify documentation0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 11 44.00 $1,652.22Facility operating record: Leak inspection log (265.1064(d))Prepare a leak inspection log 0.00 0.00 4.00 2.00 6.00 $194.17 $0.00 $0.00 35 210.00 $6,796.07Reassess leak inspection log 0.00 0.00 2.00 0.00 2.00 $75.10 $0.00 $0.00 35 70.00 $2,628.54File and maintain leak inspection log 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 35 17.50 $384.75Modify leak inspection log 0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 35 140.00 $5,257.08Facility operating record: Design/monitoring/operation/inspection information (265.1064(e))Prepare design/monitoring/operation/inspection information 0.00 1.00 16.00 2.00 19.00 $722.72 $0.00 $0.00 0 0.00 $0.00Reassess design/monitoring/operation/inspection information 0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 35 140.00 $5,257.08File and maintain design/monitoring/operation/inspection information 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 35 17.50 $384.75Modify design/monitoring/operation/inspection information 0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 11 44.00 $1,652.2231EXHIBIT 11a (CONTINUED)EQUIPMENT LEAKS - INTERIM STATUSANNUAL PRIVATE RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearFacility operating record: Monitoring and inspection information for other control devices (265.1064 (f))Prepare monitoring and inspection information 0.00 1.00 16.00 2.00 19.00 $722.72 $0.00 $0.00 0 0.00 $0.00Reassess monitoring and inspection information 0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 1 4.00 $150.20File and maintain monitoring and inspection information 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 1 0.50 $10.99Modify monitoring and inspection information 0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 1 4.00 $150.20Facility operating record: Equipment log (265.1064(g))Prepare an equipment log 0.00 0.00 4.00 2.00 6.00 $194.17 $0.00 $0.00 0 0.00 $0.00Reassess equipment log 0.00 0.00 2.00 0.00 2.00 $75.10 $0.00 $0.00 35 70.00 $2,628.54File and maintain an equipment log 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 35 17.50 $384.75Modify equipment log0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 11 44.00 $1,652.22Facility operating record: Valve log for all valves subject to 265.1057(g) and (h) (265.1064(h))Prepare valve log0.00 0.00 6.00 2.00 8.00 $269.27 $0.00 $0.00 0 0.00 $0.00Reassess valve log0.00 0.00 2.00 0.00 2.00 $75.10 $0.00 $0.00 9 18.00 $675.91File and maintain log0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 9 4.50 $98.94Modify valve log0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 3 12.00 $450.61Facility operating record: Valve log for all valves subject to 265.1062 (265.1064(i))Prepare valve log0.00 0.00 6.00 2.00 8.00 $269.27 $0.00 $0.00 0 0.00 $0.00Reassess valve log0.00 0.00 2.00 0.00 2.00 $75.10 $0.00 $0.00 2 4.00 $150.20File and maintain valve log 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 2 1.00 $21.99Modify valve log0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 1 4.00 $150.20Facility operating record: Criteria log (265.1064(j))Prepare criteria log0.00 0.00 4.00 2.00 6.00 $194.17 $0.00 $0.00 0 0.00 $0.00Reassess criteria log0.00 0.00 2.00 0.00 2.00 $75.10 $0.00 $0.00 35 70.00 $2,628.54File and maintain criteria log 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 35 17.50 $384.75Modify criteria log0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 11 44.00 $1,652.22Facility operating record: Exemption log (265.1064(k))Prepare exemption log0.00 0.00 4.00 1.00 5.00 $172.19 $0.00 $0.00 0 0.00 $0.00Reassess exemption log 0.00 0.00 1.00 0.00 1.00 $37.55 $0.00 $0.00 35 35.00 $1,314.27File and maintain exemption log 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 35 17.50 $384.75Modify exemption log0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 11 44.00 $1,652.22SUBTOTALvaries varies varies varies varies varies varies varies varies 1,656.00 $61,878.8332EXHIBIT 11a (CONTINUED)EQUIPMENT LEAKS - PERMITTEDANNUAL PRIVATE RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearFacility operating record: Monitoring and inspection information for other control devices (264.1064 (f))Prepare monitoring and inspection information 0.00 1.00 16.00 2.00 19.00 $722.72 $0.00 $0.00 0 0.00 $0.00Reassess monitoring and inspection information 0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 17 68.00 $2,553.44File and maintain monitoring and inspection information 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 17 8.50 $186.88Modify monitoring and inspection information 0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 5 20.00 $751.01Facility Operating Record: Equipment log (264.1064(g))Prepare an equipment log 0.00 0.00 4.00 2.00 6.00 $194.17 $0.00 $0.00 0 0.00 $0.00Reassess equipment log 0.00 0.00 2.00 0.00 2.00 $75.10 $0.00 $0.00 1,752 3,504.00 $131,577.08File and maintain an equipment log 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 1,752 876.00 $19,259.38Modify equipment log0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 175 700.00 $26,285.38Facility Operating Record: Valve log for all valves subject to 264.1057(g) and (h) (264.1064(h))Prepare valve log0.00 0.00 6.00 2.00 8.00 $269.27 $0.00 $0.00 0 0.00 $0.00Reassess valve log0.00 0.00 2.00 0.00 2.00 $75.10 $0.00 $0.00 438 876.00 $32,894.27File and maintain valve log 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 438 219.00 $4,814.84Modify valve log0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 44 176.00 $6,608.89Facility Operating Record: Valve log for all valves subject to 264.1062 (264.1064(i))Prepare valve log0.00 0.00 6.00 2.00 8.00 $269.27 $0.00 $0.00 0 0.00 $0.00Reassess valve log0.00 0.00 2.00 0.00 2.00 $75.10 $0.00 $0.00 88 176.00 $6,608.89File and maintain valve log 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 88 44.00 $967.37Modify valve log0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 9 36.00 $1,351.82Facility Operating Record: Criteria log (264.1064(j))Prepare criteria log0.00 0.00 4.00 2.00 6.00 $194.17 $0.00 $0.00 0 0.00 $0.00Reassess criteria log0.00 0.00 2.00 0.00 2.00 $75.10 $0.00 $0.00 1,752 3,504.00 $131,577.08File and maintain criteria log 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 1,752 876.00 $19,259.38Modify criteria log0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 175 700.00 $26,285.38Facility Operating Record: Exemption log (264.1064(k))Prepare exemption log0.00 0.00 4.00 1.00 5.00 $172.19 $0.00 $0.00 0 0.00 $0.00Reassess exemption log 0.00 0.00 1.00 0.00 1.00 $37.55 $0.00 $0.00 1,752 1,752.00 $65,788.54File and maintain exemption log 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $0.00 1,752 876.00 $19,259.38Modify exemption log0.00 0.00 4.00 0.00 4.00 $150.20 $0.00 $0.00 175 700.00 $26,285.38Semiannual Report of Control Device Monitoring Events (264.1065)Prepare semiannual report 0.00 1.00 6.00 2.00 9.00 $347.22 $0.00 $0.00 1,051 9,459.00 $364,924.82Submit semiannual report to Region 0.00 0.00 0.00 0.50 0.50 $10.99 $0.00 $3.00 1,051 525.50 $14,706.43SUBTOTALvaries varies varies varies varies varies varies varies varies 81,330.00 $3,023,408.29GRAND TOTALvaries varies varies varies varies varies varies varies varies 82,986.00 $3,085,287.1233EXHIBIT 11bEQUIPMENT LEAKS - INTERIM STATUSANNUAL GOVERNMENTS RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearEquipment Leaks - Interim StatusRead the RegulationsRead the regulations0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 0 0.00 $0.00Notification to implement the alternative valve standard in 265.1061(a) (265.1061(b)(1))Prepare notification0.00 0.25 1.00 0.25 1.50 $51.80 $0.00 $0.00 1 1.50 $51.80Submit notification to the Region 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $3.00 1 0.50 $13.48Notification to discontinue alternative valve standard in 265.1061(a) (265.1061(d))Prepare notification0.00 0.25 1.00 0.25 1.50 $51.80 $0.00 $0.00 0 0.00 $0.00Submit notification to the Region 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $3.00 0 0.00 $0.00Notification to implement the alternative valve standard in 265.1062(b)(2) and (3) (265.1062(a)(2))Prepare notification0.00 0.25 1.00 0.25 1.50 $51.80 $0.00 $0.00 0 0.00 $0.00Submit notification to the Region 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $3.00 0 0.00 $0.00Non-hazardous waste documentation (265.1063(d)(3))Gather production process, w astegeneration, andspecification analysis(4times annually)0.000.0016.000.0016.00$525.44$0.00$800.0000.00$0.00Document production process,w aste generation andspecification analysis(4times annually)0.000.0016.000.0016.00$525.44$0.00$0.0000.00$0.00Maintaindocumentation at thefacility(4times annually)0.000.000.002.002.00$41.90$0.00$0.0000.00$0.00Facility operating record: Equipment record (265.1064(b)(1))Prepare equipment record 0.00 0.00 6.00 1.00 7.00 $217.99 $0.00 $0.00 0 0.00 $0.00Reassess equipment record 0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 $0.00 3 6.00 $197.04File and maintain equipment record 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 3 1.50 $31.43Modify equipment record0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 1 4.00 $131.36Facility operating record: Implementation schedule (265.1064(b)(2))Prepare implementation schedule 0.00 0.50 2.00 0.50 3.00 $103.60 $0.00 $0.00 0 0.00 $0.00Reassess implementation schedule 0.00 0.00 1.00 0.00 1.00 $32.84 $0.00 $0.00 3 3.00 $98.52File and maintain schedule 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 3 1.50 $31.43Modify implementation schedule 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 1 4.00 $131.36Facility operating record: Performance test plan (265.1064(b)(3))Prepare performance test plan 0.00 1.00 16.00 2.00 19.00 $622.22 $0.00 $0.00 0 0.00 $0.00Reassess performance test plan 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 0 0.00 $0.00File and maintain plan0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 0 0.00 $0.00Modify performance test plan 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 0 0.00 $0.00Facility operating record: Documentation of compliance with 265.1060 (265.1064(b)(4))Prepare documentation0.00 1.00 16.00 2.00 19.00 $622.22 $0.00 $0.00 0 0.00 $0.00Reassess documentation0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 3 12.00 $394.08File and maintain documentation 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 3 1.50 $31.43Modify documentation0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 1 4.00 $131.36Facility operating record: Leak inspection log (265.1064(d))Prepare a leak inspection log 0.00 0.00 4.00 2.00 6.00 $173.26 $0.00 $0.00 3 18.00 $519.78Reassess leak inspection log 0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 $0.00 3 6.00 $197.04File and maintain leak inspection log 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 3 1.50 $31.43Modify leak inspection log0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 3 12.00 $394.08Facility operating record: Design/monitoring/operation/inspection information (265.1064(e))Prepare design/monitoring/operation/inspection information 0.00 1.00 16.00 2.00 19.00 $622.22 $0.00 $0.00 0 0.00 $0.00Reassess design/monitoring/operation/inspection information 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 3 12.00 $394.08File and maintain design/monitoring/operation/inspection information 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 3 1.50 $31.43Modify design/monitoring/operation/inspection information 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 1 4.00 $131.3634EXHIBIT 11b (CONTINUED)EQUIPMENT LEAKS - INTERIM STATUSANNUAL GOVERNMENTS RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearFacility operating record: Monitoring and inspection information for other control devices (265.1064 (f))Prepare monitoring and inspection information 0.00 1.00 16.00 2.00 19.00 $622.22 $0.00 $0.00 0 0.00 $0.00Reassess monitoring and inspection information 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 1 4.00 $131.36File and maintain monitoring and inspection information 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 1 0.50 $10.48Modify monitoring and inspection information 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 1 4.00 $131.36Facility operating record: Equipment log (265.1064(g))Prepare an equipment log0.00 0.00 4.00 2.00 6.00 $173.26 $0.00 $0.00 0 0.00 $0.00Reassess equipment log0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 $0.00 3 6.00 $197.04File and maintain an equipment log 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 3 1.50 $31.43Modify equipment log0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 1 4.00 $131.36Facility operating record: Valve log for all valves subject to 265.1057(g) and (h) (265.1064(h))Prepare valve log0.00 0.00 6.00 2.00 8.00 $238.94 $0.00 $0.00 0 0.00 $0.00Reassess valve log0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 $0.00 1 2.00 $65.68File and maintain log0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 1 0.50 $10.48Modify valve log0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 0 0.00 $0.00Facility operating record: Valve log for all valves subject to 265.1062 (265.1064(i))Prepare valve log0.00 0.00 6.00 2.00 8.00 $238.94 $0.00 $0.00 0 0.00 $0.00Reassess valve log0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 $0.00 0 0.00 $0.00File and maintain valve log 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 0 0.00 $0.00Modify valve log0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 0 0.00 $0.00Facility operating record: Criteria log (265.1064(j))Prepare criteria log0.00 0.00 4.00 2.00 6.00 $173.26 $0.00 $0.00 0 0.00 $0.00Reassess criteria log0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 $0.00 3 6.00 $197.04File and maintain criteria log 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 3 1.50 $31.43Modify criteria log0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 1 4.00 $131.36Facility operating record: Exemption log (265.1064(k))Prepare exemption log0.00 0.00 4.00 1.00 5.00 $152.31 $0.00 $0.00 0 0.00 $0.00Reassess exemption log0.00 0.00 1.00 0.00 1.00 $32.84 $0.00 $0.00 3 3.00 $98.52File and maintain exemption log 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 3 1.50 $31.43Modify exemption log0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 1 4.00 $131.36SUBTOTALvaries varies varies varies varies varies varies varies varies 137.00 $4,272.7635EXHIBIT 11b (CONTINUED)EQUIPMENT LEAKS - PERMITTEDANNUAL GOVERNMENTS RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearEquipment Leaks - PermittedRead the RegulationsRead the regulations0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 0 0.00 $0.00Notification to implement the alternative valve standard in 264.1061(a) (264.1061(b)(1))Prepare notification0.00 0.25 1.00 0.25 1.50 $51.80 $0.00 $0.00 25 37.50 $1,294.94Submit notification to the Region 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $3.00 25 12.50 $336.88Notification to discontinue alternative valve standard in 264.1061(a) (264.1061(d))Prepare notification0.00 0.25 1.00 0.25 1.50 $51.80 $0.00 $0.00 0 0.00 $0.00Submit notification to the Region 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $3.00 0 0.00 $0.00Notification to implement alternative valve standard (264.1062)(b)(2) and (3) (264.1062(a)(2))Prepare notification0.00 0.25 1.00 0.25 1.50 $51.80 $0.00 $0.00 6 9.00 $310.79Submit notification to the Region 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $3.00 6 3.00 $80.85Non-hazardous waste documentation (264.1063(d)(3))Gather production process, w aste generationand specification analysis (4 times annually) 0.00 0.00 16.00 0.00 16.00 $525.44 $0.00 $800.00 13 208.00 $17,230.72Document production process, w aste generationand specification analysis (4 times annually) 0.00 0.00 16.00 0.00 16.00 $525.44 $0.00 $0.00 13 208.00 $6,830.72Maintain documentation at the facility (4 times annually) 0.00 0.00 0.00 2.00 2.00 $41.90 $0.00 $0.00 13 26.00 $544.70Facility Operating Record: Equipment record (264.1064(b)(1))Prepare equipment record 0.00 0.00 6.00 1.00 7.00 $217.99 $0.00 $0.00 0 0.00 $0.00Reassess equipment record 0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 $0.00 127 254.00 $8,341.36File and maintain equipment record 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 127 63.50 $1,330.33Modify equipment record0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 13 52.00 $1,707.68Facility Operating Record: Implementation schedule (264.1064(b)(2))Prepare implementation schedule 0.00 0.50 2.00 0.50 3.00 $103.60 $0.00 $0.00 0 0.00 $0.00Reassess implementation schedule 0.00 0.00 1.00 0.00 1.00 $32.84 $0.00 $0.00 127 127.00 $4,170.68File and maintain schedule 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 127 63.50 $1,330.33Modify implementation schedule 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 13 52.00 $1,707.68Facility Operating Record: Performance test plan (264.1064(b)(3))Prepare performance test plan 0.00 1.00 16.00 2.00 19.00 $622.22 $0.00 $0.00 0 0.00 $0.00Reassess performance test plan 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 25 100.00 $3,284.00File and maintain performance test plan 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 25 12.50 $261.88Modify performance test plan 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 3 12.00 $394.08Facility Operating Record: Documentation of compliance with 264.1060 (264.1064(b)(4))Prepare documentation0.00 1.00 16.00 2.00 19.00 $622.22 $0.00 $0.00 0 0.00 $0.00Reassess documentation0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 127 508.00 $16,682.72File and maintain documentation 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 127 63.50 $1,330.33Modify documentation0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 13 52.00 $1,707.68Facility Operating Record: Leak inspection log (264.1064(d))Prepare a leak inspection log 0.00 0.00 4.00 2.00 6.00 $173.26 $0.00 $0.00 127 762.00 $22,004.02Reassess leak inspection log 0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 $0.00 127 254.00 $8,341.36File and maintain leak inspection log 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 127 63.50 $1,330.33Modify leak inspection log0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 127 508.00 $16,682.72Facility Operating Record: Design/monitoring/operation/inspection information (264.1064(e))Prepare design/monitoring/operation/inspection information 0.00 1.00 16.00 2.00 19.00 $622.22 $0.00 $0.00 11 209.00 $6,844.42Reassess design/monitoring/operation/inspection information 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 127 508.00 $16,682.72File and maintain design/monitoring/operation/inspection information 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 127 63.50 $1,330.33Modify design/monitoring/operation/inspection information 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 13 52.00 $1,707.6836EXHIBIT 11b (CONTINUED)EQUIPMENT LEAKS - PERMITTEDANNUAL GOVERNMENTS RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearFacility operating record: Monitoring and inspection information for other control devices (264.1064 (f))Prepare monitoring and inspection information 0.00 1.00 16.00 2.00 19.00 $622.22 $0.00 $0.00 0 0.00 $0.00Reassess monitoring and inspection information 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 17 68.00 $2,233.12File and maintain monitoring and inspection information 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 17 8.50 $178.08Modify monitoring and inspection information 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 5 20.00 $656.80Facility Operating Record: Equipment log (264.1064(g))Prepare an equipment log0.00 0.00 4.00 2.00 6.00 $173.26 $0.00 $0.00 0 0.00 $0.00Reassess equipment log0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 $0.00 127 254.00 $8,341.36File and maintain an equipment log 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 127 63.50 $1,330.33Modify equipment log0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 13 52.00 $1,707.68Facility Operating Record: Valve log for all valves subject to 264.1057(g) and (h) (264.1064(h))Prepare valve log0.00 0.00 6.00 2.00 8.00 $238.94 $0.00 $0.00 0 0.00 $0.00Reassess valve log0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 $0.00 32 64.00 $2,101.76File and maintain valve log 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 32 16.00 $335.20Modify valve log0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 3 12.00 $394.08Facility Operating Record: Valve log for all valves subject to 264.1062 (264.1064(i))Prepare valve log0.00 0.00 6.00 2.00 8.00 $238.94 $0.00 $0.00 0 0.00 $0.00Reassess valve log0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 $0.00 6 12.00 $394.08File and maintain valve log 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 6 3.00 $62.85Modify valve log0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 1 4.00 $131.36Facility Operating Record: Criteria log (264.1064(j))Prepare criteria log0.00 0.00 4.00 2.00 6.00 $173.26 $0.00 $0.00 0 0.00 $0.00Reassess criteria log0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 $0.00 127 254.00 $8,341.36File and maintain criteria log 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 127 63.50 $1,330.33Modify criteria log0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 13 52.00 $1,707.68Facility Operating Record: Exemption log (264.1064(k))Prepare exemption log0.00 0.00 4.00 1.00 5.00 $152.31 $0.00 $0.00 0 0.00 $0.00Reassess exemption log0.00 0.00 1.00 0.00 1.00 $32.84 $0.00 $0.00 127 127.00 $4,170.68File and maintain exemption log 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $0.00 127 63.50 $1,330.33Modify exemption log0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 $0.00 13 52.00 $1,707.68Semiannual Report of Control Device Monitoring Events (264.1065)Prepare semiannual report 0.00 1.00 6.00 2.00 9.00 $293.82 $0.00 $0.00 76 684.00 $22,330.32Submit semiannual report to Region 0.00 0.00 0.00 0.50 0.50 $10.48 $0.00 $3.00 76 38.00 $1,024.10SUBTOTALvaries varies varies varies varies varies varies varies varies 6,195.00 $203,611.05GRAND TOTALvaries varies varies varies varies varies varies varies varies 6,332.00 $207,883.8137EXHIBIT 12aCONTAINMENT BUILDINGS - INTERIM STATUSANNUAL PRIVATE RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearContainment Buildings - Interim StatusRegulationsRead the Regulations0.00 1.25 5.00 0.00 6.25 $285.18 $0.00 $0.00 0 0.00 $0.00Demonstration that unit meets the standards of Subpart DD (265.1101(b))Demonstrate that the unit substantially meetsstandards of Subpart DD, if the ow ner oroperator w ants the secondary containment requirement to be delayed 1.00 1.00 16.00 0.50 18.50 $799.38 $0.00 $3.00 0 0.00 $0.00Certification and Response Procedures (265.1101(c))Obtain and place a professional engineercertification into the facility's operating record 0.00 0.00 4.00 0.25 4.25 $155.70 $0.00 $340.00 0 0.00 $0.00Upon detecting a condition that hascaused a release of hazardous w aste:$0.00Enter a record of the discovery in the facility operating record 0.00 0.25 0.50 0.00 0.75 $38.26 $0.00 $0.00 0 0.00 $0.00Establish a schedule of accomplishing the cleanup and repairs 0.00 0.25 0.50 0.00 0.75 $38.26 $0.00 $0.00 0 0.00 $0.00Notify EPA of the condition w ithin 7 days of discovery of the condition 0.00 0.00 0.50 0.00 0.50 $18.78 $0.00 $3.00 0 0.00 $0.00Provide w ithin 14 days w ritten notice and schedule for cleanup to EPA 0.00 0.00 0.50 0.25 0.75 $24.27 $0.00 $3.00 0 0.00 $0.00Notify EPA and verify in w riting that cleanup and repairs have been completed 0.00 0.50 0.00 0.25 0.75 $44.47 $0.00 $3.00 0 0.00 $0.00Inspect and record in the facility's operating record,at least once every 7 days, data specified in (265.1101) 0.00 0.00 26.00 0.00 26.00 $976.31 $0.00 $0.00 0 0.00 $0.00Operating Procedures for Areas without Secondary Containment (265.110(d)(3))Maintain in the facility log a w rittendescription of operating procedures used tomaintain the integrity of areas w ithout secondary containment 0.00 0.00 1.00 0.25 1.25 $43.05 $0.00 $0.00 0 0.00 $0.00Demonstration for Exemption from Secondary Containment Requirements (265.1101(e))Demonstratethatthe onlyfreeliquidsinthe unitarelimited amounts of dust suppression liquids, if the ow ner/operatorw ants a w aiver from the secondary containment requirements 1.00 1.00 2.00 0.50 4.50 $273.67 $0.00 $1,500.00 0 0.00 $0.00SUBTOTALvaries varies varies varies varies varies varies varies varies 0.00 $0.0038EXHIBIT 12a (CONTINUED)CONTAINMENT BUILDINGS - PERMITTEDANNUAL PRIVATE RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ NumberINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Total Hours Total CostACTIVITYYear Year Cost Cost pondents Per Year Per YearContainment Buildings - PermittedRegulationsRead the Regulations0.00 1.25 5.00 0.00 6.25 $285.18 $0.00 $0.00 0 0.00 $0.00Demonstration that unit meets the standards of Subpart DD (264.1101(b))Demonstrate that the unit substantially meets standards of Subpart DD, if theow ner or operator w ants the secondary containment requirement to be delayed 1.00 1.00 16.00 0.50 18.50 $799.38 $0.00 $3.00 0 0.00 $0.00Certification and Response Procedures (264.1101(c))Obtain and place a professional engineercertification into the facility's operating record 0.00 0.00 4.00 0.25 4.25 $155.70 $0.00 $340.00 4 17.00 $1,982.79Upon detecting a condition that hascaused a release of hazardous w aste:$0.00Enter a record of the discovery in the facility operating record 0.00 0.00 0.50 0.00 0.50 $18.78 $0.00 $0.00 3 1.50 $56.33Establish a schedule of accomplishing the cleanup and repairs 0.00 0.25 0.50 0.00 0.75 $38.26 $0.00 $0.00 3 2.25 $114.78Notify EPA of the condition w ithin 7 days of discovery of the condition 0.00 0.00 0.50 0.00 0.50 $18.78 $0.00 $3.00 3 1.50 $65.33Provide w ithin 14 days w ritten notice and schedule for cleanup to EPA 0.00 0.00 0.50 0.25 0.75 $24.27 $0.00 $3.00 3 2.25 $81.81Notify EPA and verify in w riting that cleanup and repairs have been completed 0.00 0.50 0.00 0.25 0.75 $44.47 $0.00 $3.00 3 2.25 $142.40Inspect and record in the facility's operating record,at least once every 7 days, data specified in (264.1101) 0.00 0.00 26.00 0.00 26.00 $976.31 $0.00 $0.00 13 338.00 $12,692.08Recordkeeping Requirement (264.1101(d)(3))Maintain in the facility log a w ritten description of operating proceduresused to maintain the integrity of areas w ithout secondary containment 0.00 0.00 1.00 0.25 1.25 $43.05 $0.00 $0.00 7 8.75 $301.33Exemption Demonstration (264.1101(e))Demonstrate that the onlyfreeliquidsin the unit arelimitedamountsw ants a w aiver of dust suppression liquids, if the ow ner/operatorfrom the secondary containment requirements 1.00 1.00 2.00 0.50 4.50 $273.67 $0.00 $1,500.00 7 31.50 $12,415.68SUBTOTALvaries varies varies varies varies varies varies varies varies 405.00 $27,852.54GRAND TOTALvaries varies varies varies varies varies varies varies varies 405.00 $27,852.5439EXHIBIT 12bCONTAINMENT BUILDINGS - INTERIM STATUSANNUAL GOVERNMENTS RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ Number Total TotalINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Hours/ Cost/ACTIVITYYear Year Cost Cost pondents Year YearContainment Buildings - Interim StatusRegulationsRead the Regulations0.00 1.25 5.00 0.00 6.25 $232.80 $0.00 $0.00 0 0.00 $0.00Demonstration that unit meets the standards of Subpart DD (265.1101(b))Demonstrate that the unit substantially meetsstandards of Subpart DD, if the ow ner oroperator w ants the secondary containment requirement to be delayed 1.00 1.00 16.00 0.50 18.50 $649.26 $0.00 $3.00 0 0.00 $0.00Certification and Response Procedures (265.1101(c))Obtain and place a professional engineercertification into the facility's operating record 0.00 0.00 4.00 0.25 4.25 $136.60 $0.00 $340.00 0 0.00 $0.00Upon detecting a condition that hascaused a release of hazardous w aste:$0.00Enter a record of the discovery in the facilityoperating record 0.00 0.25 0.50 0.00 0.75 $30.14 $0.00 $0.00 0 0.00 $0.00Establish a schedule of accomplishing the cleanup and repairs 0.00 0.25 0.50 0.00 0.75 $30.14 $0.00 $0.00 0 0.00 $0.00Notify EPA of the condition w ithin 7 days of discovery of the condition 0.00 0.00 0.50 0.00 0.50 $16.42 $0.00 $3.00 0 0.00 $0.00Provide w ithin 14 days w ritten notice and schedule for cleanup to EPA 0.00 0.00 0.50 0.25 0.75 $21.66 $0.00 $3.00 0 0.00 $0.00Notify EPA and verify in w riting that cleanup and repairs have been completed 0.00 0.50 0.00 0.25 0.75 $32.68 $0.00 $3.00 0 0.00 $0.00Inspect and record in the facility's operating record,at least once every 7 days, data specified in (265.1101) 0.00 0.00 26.00 0.00 26.00 $853.84 $0.00 $0.00 0 0.00 $0.00Operating Procedures for Areas without Secondary Containment (265.110(d)(3))Maintain in the facility log a w rittendescription of operating procedures used tomaintain the integrity of areas w ithout secondary containment 0.00 0.00 1.00 0.25 1.25 $38.08 $0.00 $0.00 0 0.00 $0.00Demonstration for Exemption from Secondary Containment Requirements (265.1101(e))Demonstratethatthe onlyfreeliquidsinthe unitarelimited amounts of dust suppression liquids, if the ow ner/operatorw ants a w aiver from the secondary containment requirements 1.00 1.00 2.00 0.50 4.50 $189.50 $0.00 $1,500.00 0 0.00 $0.00SUBTOTALvaries varies varies varies varies varies varies varies varies 0.00 $0.0040EXHIBIT 12b (CONTINUED)CONTAINMENT BUILDINGS - PERMITTEDANNUAL GOVERNMENTS RESPONDENT BURDEN/COST ESTIMATESLegal Managerial Technical Clerical Respon. Labor Capital/ NumberINFORMATION COLLECTION Hours Hours Hours Hours Hours/ Cost/ Startup O&M of Res- Total Hours Total CostACTIVITYYear Year Cost Cost pondents Per Year Per YearContainment Buildings - PermittedRegulationsRead the Regulations0.00 1.25 5.00 0.00 6.25 $232.80 $0.00 $0.00 0 0.00 $0.00Demonstration that unit meets the standards of Subpart DD (264.1101(b))Demonstrate that the unit substantially meets standards of Subpart DD, if theow ner or operator w ants the secondary containment requirement to be delayed 1.00 1.00 16.00 0.50 18.50 $649.26 $0.00 $3.00 0 0.00 $0.00Certification and Response Procedures (264.1101(c))Obtain and place a professional engineercertification into the facility's operating record 0.00 0.00 4.00 0.25 4.25 $136.60 $0.00 $340.00 4 17.00 $1,906.39Upon detecting a condition that hascaused a release of hazardous w aste:$0.00Enter a record of the discovery in the facility operating record 0.00 0.00 0.50 0.00 0.50 $16.42 $0.00 $0.00 6 3.00 $98.52Establish a schedule of accomplishing the cleanup and repairs 0.00 0.25 0.50 0.00 0.75 $30.14 $0.00 $0.00 6 4.50 $180.84Notify EPA of the condition w ithin 7 days of discovery of the condition 0.00 0.00 0.50 0.00 0.50 $16.42 $0.00 $3.00 6 3.00 $116.52Provide w ithin 14 days w ritten notice and schedule for cleanup to EPA 0.00 0.00 0.50 0.25 0.75 $21.66 $0.00 $3.00 6 4.50 $147.95Notify EPA and verify in w riting that cleanup and repairs have been completed 0.00 0.50 0.00 0.25 0.75 $32.68 $0.00 $3.00 6 4.50 $214.07Inspect and record in the facility's operating record,at least once every 7 days, data specified in (264.1101) 0.00 0.00 26.00 0.00 26.00 $853.84 $0.00 $0.00 25 650.00 $21,346.00Recordkeeping Requirement (264.1101(d)(3))Maintain in the facility log a w ritten description of operating proceduresused to maintain the integrity of areas w ithout secondary containment 0.00 0.00 1.00 0.25 1.25 $38.08 $0.00 $0.00 13 16.25 $495.01Exemption Demonstration (264.1101(e))Demonstrate that the onlyfreeliquidsin the unit arelimitedamountsw ants a w aiver of dust suppression liquids, if the ow ner/operatorfrom the secondary containment requirements 1.00 1.00 2.00 0.50 4.50 $189.50 $0.00 $1,500.00 13 58.50 $21,963.44SUBTOTALvaries varies varies varies varies varies varies varies varies 761.25 $46,468.72GRAND TOTALvaries varies varies varies varies varies varies varies varies 761.25 $46,468.7241EXHIBIT 13aTOTAL ANNUAL PRIVATE RESPONDENT BURDEN AND COSTTotal Total Total Total TotalHours per Capital Cost per O&M Cost per Labor Cost per Cost perYear Year Year Year YearSUBPART ICONTAINERS74,961 $0 $0 $582,597 $582,597SUBPART JTANK SYSTEMS5,102 $0 $49,869 $191,747 $241,616SUBPART KSURFACE IMPOUNDMENTS 240 $0 $0 $8,996 $8,996SUBPART LWASTE PILES51 $0 $0 $1,728 $1,728SUBPART MLAND TREATMENT0.00 $0 $0 $0 $0SUBPART NLANDFILLS0 $0 $0 $0 $0SUBPART OINCINERATORS242 $0 $3 $9,070 $9,073SUBPART XMISCELLANEOUS UNITS0 $0 $0 $0 $0SUBPART WDRIP PADS0 $0 $0 $0 $0SUBPART AAPROCESS VENTS311,661 $0 $3,041,335 $12,200,782 $15,242,117SUBPART BBEQUIPMENT LEAKS82,986 $0 $147,706 $2,937,581 $3,085,287SUBPART DDCONTAINMENT BUILDINGS405 $0 $11,887 $15,966 $27,853PURCHASE OF FILE CABINETS 0 $0 0 0 0TOTAL PRIVATE RESPONDENT BURDEN PER YEAR 475,647$ $0 3,250,800$ 15,948,467$ 19,199,266$Respondent Burden over Three Years 1,426,942 $57,597,79942EXHIBIT 13bTOTAL ANNUAL GOVERNMENTS RESPONDENT BURDEN AND COSTTotal Total Total Total TotalHours per Capital Cost per O&M Cost per Labor Cost per Cost perYear Year Year Year YearSUBPART ICONTAINERS74,961 $0 $0 $1,380,922 $1,380,922SUBPART JTANK SYSTEMS41,716 $0 $114,255 $1,367,978 $1,482,233SUBPART KSURFACE IMPOUNDMENTS 2,721 $0 $1,360 $89,292 $90,652SUBPART LWASTE PILES85 $0 $0 $2,554 $2,554SUBPART MLAND TREATMENT0.00 $0 $0 $0 $0SUBPART NLANDFILLS1,554 $0 $0 $46,372 $46,372SUBPART OINCINERATORS332 $0 $3 $10,889 $10,892SUBPART XMISCELLANEOUS UNITS0 $0 $0 $0 $0SUBPART WDRIP PADS0 $0 $0 $0 $0SUBPART AAPROCESS VENTS32,903 $0 $320,144 $1,090,549 $1,410,693SUBPART BBEQUIPMENT LEAKS6,332 $0 $10,724 $197,160 $207,884SUBPART DDCONTAINMENT BUILDINGS761 $0 $20,914 $25,555 $46,469PURCHASE OF FILE CABINETS 0 $0 0 0 0TOTAL GOVERNMENTS RESPONDENT BURDEN PER YEAR 161,365$ $0 467,400$ 4,211,270$ 4,678,670$Respondent Burden over Three Years 484,094 14,036,00943EXHIBIT 14aANNUAL EPA BURDEN AND COSTLegal Managerial Technical Clerical Respon. Labor Number of Total TotalHours Hours Hours Hours Hours Cost O&M Respondent Hours CostPer Year Per Year Costs Activities Per Year Per YearTank Systems - Interim StatusReview equivalent containment device information 0.00 0.00 4.00 0.00 4.00 $203.91 $0.00 0 1.58 $80.75Review information submitted for exemption from 24-hour leak detection requirement 0.00 0.00 4.00 0.00 4.00 $203.91 $0.00 0 0.00 $0.00Review information submitted for variance from secondary containment requirements 0.00 0.00 4.00 0.00 4.00 $203.91 $0.00 0 0.00 $0.00Review information submitted for exemption from the 24-hour waste removal requirement 0.00 0.00 2.00 0.00 2.00 $101.96 $0.00 0 0.20 $10.09Review release notifications and reports0.00 0.00 4.00 0.00 4.00 $203.91 $0.00 1 2.40 $122.35Review major repair certifications0.00 0.00 8.00 0.00 8.00 $407.82 $0.00 0 1.60 $81.56Review decontamination demonstrations0.00 0.00 4.00 0.00 4.00 $203.91 $0.00 0 0.00 $0.00Tank Systems - PermittedReview information submitted for exemption from the 24-hour waste removal requirement 0.00 0.00 4.00 0.00 4.00 $203.91 $0.00 0 1.60 $81.56Review release notifications and reports0.00 0.00 4.00 0.00 4.00 $203.91 $0.00 3 10.40 $530.17Review major repair certifications0.00 0.00 8.00 0.00 8.00 $407.82 $0.00 0 0.00 $0.00Review decontamination demonstrations0.00 0.00 4.00 0.00 4.00 $203.91 $0.00 0 0.00 $0.00Surface Impoundments - Interim StatusReview assessments of alternate design and operating practices0.00 0.00 16.00 0.00 16.00 $815.64 $0.00 0 0.00 $0.00Review notifications of intent to receive waste 0.00 0.00 2.00 0.00 2.00 $101.96 $0.00 0 0.00 $0.00Review and establish action leakage rates0.00 0.00 10.00 0.00 10.00 $509.78 $0.00 0 0.00 $0.00Review Response Action Plans0.00 0.00 20.00 0.00 20.00 $1,019.55 $0.00 0 0.00 $0.00Receive and review written action leakage rate exceedance notifications 0.00 0.50 3.50 0.00 4.00 $213.86 $0.00 0 0.00 $0.00Review leakage reports0.00 0.50 10.00 0.00 10.50 $545.21 $0.00 0 0.00 $0.00Enter RAP data into a data base0.00 0.00 0.00 0.10 0.10 $2.17 $0.00 0 0.00 $0.00Review information submitted when the ALR is exceeded 0.00 0.50 10.00 0.00 10.50 $545.21 $0.00 0 0.00 $0.00Review and establish pump operating levels0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0.00 $0.00Review contingent corrective measures plan 0.00 0.00 4.00 0.00 4.00 $203.91 $0.00 0 0.00 $0.00Review hazardous waste removal plan0.00 0.00 1.00 0.00 1.00 $50.98 $0.00 0 0.00 $0.00Review extension request0.00 0.00 0.50 0.00 0.50 $25.49 $0.00 0 0.00 $0.00Review corrective action report (2 times annually) 0.00 0.00 4.00 0.00 4.00 $203.91 $0.00 0 0.00 $0.00Surface Impoundments - PermittedReceive and review written action leakage rate exceedance notifications 0.00 0.50 3.50 0.00 4.00 $213.86 $0.00 0 0.00 $0.00Review leakage reports0.00 0.50 10.00 0.00 10.50 $545.21 $0.00 0 0.00 $0.00Review notification of surface impoundment removal from service 0.00 0.00 2.00 0.00 2.00 $101.96 $0.00 0 0.00 $0.00Review contingent corrective measures plan 0.00 0.00 4.00 0.00 4.00 $203.91 $0.00 0 0.00 $0.00Review hazardous waste removal plan0.00 0.00 1.00 0.00 1.00 $50.98 $0.00 0 0.00 $0.00Review extension request0.00 0.00 0.50 0.00 0.50 $25.49 $0.00 0 0.00 $0.00Review corrective action report (2 times annually) 0.00 0.00 4.00 0.00 4.00 $203.91 $0.00 0 0.00 $0.00W aste Piles - Interim StatusReview exemptions from design and operating requirements 0.00 0.00 7.00 0.00 7.00 $356.84 $0.00 0 0.00 $0.00Review exemptions from liner/ leachate system requirements 0.00 0.00 7.00 0.00 7.00 $356.84 $0.00 0 0.00 $0.00Review and establish action leakage rates0.00 0.00 10.00 0.00 10.00 $509.78 $0.00 0 0.00 $0.00Review Response Action Plans0.00 0.00 20.00 0.00 20.00 $1,019.55 $0.00 0 0.00 $0.00Receive and review written action leakage rate exceedance notifications 0.00 0.50 3.50 0.00 4.00 $213.86 $0.00 0 0.00 $0.00Review leakage reports0.00 0.50 10.00 0.00 10.50 $545.21 $0.00 0 0.00 $0.00Enter RAP data into a data base0.00 0.00 0.00 0.10 0.10 $2.17 $0.00 0 0.00 $0.00Review information submitted when the ALR is exceeded 0.00 0.50 10.00 0.00 10.50 $545.21 $0.00 0 0.00 $0.00W aste Piles - PermittedReceive andreview written actionleakage rate exceedance notifications0.000.503.500.004.00$213.86$0.0000.00$0.00Review leakage reports0.00 0.50 10.00 0.00 10.50 $545.21 $0.00 0 0.00 $0.00Review information submitted when the ALR is exceeded 0.00 0.50 10.00 0.00 10.50 $545.21 $0.00 0 0.00 $0.0044EXHIBIT 14a (CONTINUED)ANNUAL AGENCY BURDEN AND COSTLegal Managerial Technical Clerical Respon. Labor Number of Total TotalHours Hours Hours Hours Hours Cost O&M Respondent Hours CostPer Year Per Year Costs Activities Per Year Per YearLand-Treatment - Interim StatusReview food-chain crop notifications0.00 0.00 1.00 0.00 1.00 $50.98 $0.00 0 0.00 $0.00Review certifications of closure0.00 0.00 4.00 0.00 4.00 $203.91 $0.00 0 0.00 $0.00Land Treatment - PermittedReview notifications of significant releases of hazardous constituents below the treatment zone 0.00 0.00 1.00 0.00 1.00 $50.98 $0.00 00.00 $0.00Review notifications of intent to demonstrate that regulated unit0.00is not the source of increase in hazardous constituents 0.00 0.00 1.00 0.00 1.00 $50.98 $0.00 0 0.00 $0.00Review demonstrations that regulated unit is not the source of increase0.00in hazardous constituents below the treatment zone 0.00 0.00 16.00 0.00 16.00 $815.64 $0.00 0 0.00 $0.00Review (264.280)(d) demonstrations0.00 0.00 8.00 0.00 8.00 $407.82 $0.00 0 0.00 $0.00Review closure certifications0.00 1.00 4.00 0.00 5.00 $274.78 $0.00 0 0.00 $0.00Landfills - Interim StatusReview notifications of intent to receive waste 0.00 0.00 1.00 0.00 1.00 $50.98 $0.00 0 0.00 $0.00Review demonstrations for exemption from liner and leachate collection system requirements 0.00 0.00 16.00 0.00 16.00 $815.64 $0.00 0 0.00 $0.00Review information for waivers of the double liner requirements 0.00 0.00 4.00 0.00 4.00 $203.91 $0.00 0 0.00 $0.00Review and establish action leakage rates0.00 0.00 10.00 0.00 10.00 $509.78 $0.00 0 0.00 $0.00Review Response Action Plans0.00 0.00 20.00 0.00 20.00 $1,019.55 $0.00 0 0.00 $0.00Receive and review written action leakage rate exceedance notifications 0.00 0.50 3.50 0.00 4.00 $213.86 $0.00 0 0.00 $0.00Review leakage reports0.00 0.50 10.00 0.00 10.50 $545.21 $0.00 0 0.00 $0.00Enter RAP data into a data base0.00 0.00 0.00 0.10 0.10 $2.17 $0.00 0 0.00 $0.00Review information submitted when the ALR is exceeded 0.00 0.50 10.00 0.00 10.50 $545.21 $0.00 0 0.00 $0.00Review and establish pump operating levels0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0.00 $0.00Review demonstrations for placing non-hazardous liquid waste in landfills 0.00 0.00 7.00 0.00 7.00 $356.84 $0.00 0 0.00 $0.00Landfills - PermittedReceive and review written action leakage rate exceedance notifications 0.00 0.50 3.50 0.00 4.00 $213.86 $0.00 0 0.00 $0.00Review leakage reports0.00 0.50 10.00 0.00 10.50 $545.21 $0.00 0 0.00 $0.00Review information submitted when the ALR is exceeded 0.00 0.50 10.00 0.00 10.50 $545.21 $0.00 0 0.00 $0.00Review demonstrations for placing non-hazardous liquid waste in landfills 0.00 0.00 7.00 0.00 7.00 $356.84 $0.00 0 0.00 $0.00Incinerators - Interim StatusReview applications for certification to burn F020, F021, F022, F023, F026, and F027 0.00 0.50 20.00 0.00 20.50 $1,054.99 $0.00 0 0.00 $0.00Incinerators - PermittedReview notifications of intent to burn hazardous wastes F020, F021, F022, F023, F026, and F027 0.00 0.25 1.00 0.00 1.25 $68.70 $0.00 0 0.00 $0.00Review demonstrations for exemption from emergencywaste feed cutoff system testing requirements (264.347(c)) 0.00 0.00 16.00 0.00 16.00 $815.64 $0.00 0 1.60 $81.56Msc Units -Interim Status and PermittedCovered in other ICRs0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0.00 $0.00Drip PadsReview plan for updating, repairing, and modifying the drip pad 0.00 0.00 2.00 0.00 2.00 $101.96 $0.00 0 0.00 $0.00Review release notifications and reports0.00 0.00 1.00 0.00 1.00 $50.98 $0.00 0 0.00 $0.00Process Vents - PermittedReview semiannual reports0.00 0.00 8.00 0.00 8.00 $407.82 $0.00 45 356.00 $18,148.0746EXHIBIT 14a (CONTINUED)ANNUAL EPA BURDEN AND COSTLegal Managerial Technical Clerical Respon. Labor Number of Total TotalHours Hours Hours Hours Hours Cost O&M Respondent Hours CostPer Year Per Year Costs Activities Per Year Per YearEquipment Leaks - Interim StatusReview notifications to implement the alternative valve standard in (265.1061)(a) 0.00 0.00 2.00 0.00 2.00 $101.96 $0.00 1 1.40 $71.37Review notifications to discontinue alternative valve standard in (265.1061)(a) 0.00 0.00 2.00 0.00 2.00 $101.96 $0.00 0 0.00 $0.00Review notifications to implement alternative valve standard in (265.1062)(b)(2) or (265.1062)(b)(3) 0.00 0.00 2.00 0.00 2.00 $101.96$0.00 0 0.40 $20.39Equipment Leaks - PermittedReview notifications to implement the alternative valve standard in (264.1061)(a) 0.00 0.00 2.00 0.00 2.00 $101.96 $0.00 35 70.00 $3,568.44Review notifications to discontinue alternative valve standard in (264.1061)(a) 0.00 0.00 2.00 0.00 2.00 $101.96 $0.00 0 0.80 $40.78Review notifications to implement alternative valve standard in (264.1062)(b)(2) or (264.1062)(b)(3) 0.00 0.00 2.00 0.00 2.00 $101.96$0.00 9 17.60 $897.21Review semiannual reports0.00 0.00 8.00 0.00 8.00 $407.82 $0.00 105 840.80 $42,862.08Containment Buildings - Interim StatusCollect written notice of request for delay of secondary containment 0.00 0.00 0.25 0.00 0.25 $12.74 $0.00 0 0.00 $0.00Review and comment on plans to retrofit unit 0.00 0.50 4.00 0.50 5.00 $250.21 $0.00 0 0.00 $0.00Review response to comments and approve/ disapprove delay 0.00 0.25 2.00 0.25 2.50 $125.11 $0.00 0 0.00 $0.00Receive notification of release0.00 0.00 0.25 0.00 0.25 $12.74 $0.00 0 0.00 $0.00Review written notice, description or remedial steps, and schedule for cleanup 0.00 0.00 0.25 0.00 0.25 $12.74 $0.00 0 0.00 $0.00Review information and determine if unit must be removed from service 0.00 0.00 2.00 0.00 2.00 $101.96 $0.00 0 0.00 $0.00Notify owner/ operator in writing of determination 0.00 0.00 0.50 0.25 0.75 $30.92 $0.00 0 0.00 $0.00Review verification of cleanup0.00 0.00 0.25 0.00 0.25 $12.74 $0.00 0 0.00 $0.00Review demonstration that free liquids are for dust suppression and approve or disapprove waiver 0.00 0.25 1.00 0.25 1.50 $74.13 $0.000 0.00 $0.00Containment Buildings - PermittedCollect written notice of request for delay of secondary containment 0.00 0.00 0.25 0.00 0.25 $12.74 $0.00 0 0.00 $0.00Review and comment on plans to retrofit unit 0.00 0.00 4.00 0.50 4.50 $214.78 $0.00 0 1.35 $64.43Review response to comments and approve/ disapprove delay 0.00 0.50 2.00 0.25 2.75 $142.82 $0.00 0 0.83 $42.85Receive notification of release0.00 0.00 0.25 0.00 0.25 $12.74 $0.00 0 0.08 $3.82Review written notice, description or remedial steps, and schedule for cleanup 0.00 0.00 0.25 0.00 0.25 $12.74 $0.00 0 0.08 $3.82Review information and determine if unit must be removed from service 0.00 0.00 2.00 0.00 2.00 $101.96 $0.00 0 0.60 $30.59Notify owner/ operator in writing of determination 0.00 0.00 0.50 0.25 0.75 $30.92 $0.00 0 0.23 $9.28Review verification of cleanup0.00 0.00 0.25 0.00 0.25 $12.74 $0.00 0 0.08 $3.82Review demonstration that free liquids are for dust suppression and approve or disapprove waiver 0.00 0.25 1.00 0.25 1.50 $74.13 $0.001 1.05 $51.89TOTAL0.00 varies varies varies varies varies $0.00 varies 1,310.66 $66,806.892EXHIBIT 14bANNUAL STATES BURDEN AND COSTLegal Managerial Technical Clerical Respon. Labor Number of Total TotalHours Hours Hours Hours Hours Cost O&M Respondent Hours CostPer Year Per Year Costs Activities Per Year Per YearTank Systems - Interim StatusReview equivalent containment device information 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 3 10.69 $351.13Review information submitted for exemption from 24-hour leak detection requirement 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 0 0.00 $0.00Review information submitted for variance from secondary containment requirements 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 0 0.00 $0.00Review information submitted for exemption from the 24-hour waste removal requirement 0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 1 1.34 $43.89Review release notifications and reports0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 4 14.40 $472.90Review major repair certifications0.00 0.00 8.00 0.00 8.00 $262.72 $0.00 1 7.20 $236.45Review decontamination demonstrations0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 0 0.00 $0.00Tank Systems - PermittedReview information submitted for exemption from the 24-hour waste removal requirement 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 40 158.40 $5,201.86Review release notifications and reports0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 239 957.60 $31,447.58Review major repair certifications0.00 0.00 8.00 0.00 8.00 $262.72 $0.00 1 7.20 $236.45Review decontamination demonstrations0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 0 0.00 $0.00Surface Impoundments - Interim StatusReview assessments of alternate design and operating practices0.00 0.00 16.00 0.00 16.00 $525.44 $0.00 0 0.00 $0.00Review notifications of intent to receive waste 0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 0 0.00 $0.00Review and establish action leakage rates0.00 0.00 10.00 0.00 10.00 $328.40 $0.00 0 0.00 $0.00Review Response Action Plans0.00 0.00 20.00 0.00 20.00 $656.80 $0.00 0 0.00 $0.00Receive and review written action leakage rate exceedance notifications 0.00 0.50 3.50 0.00 4.00 $142.38 $0.00 0 0.00 $0.00Review leakage reports0.00 0.50 10.00 0.00 10.50 $355.84 $0.00 0 0.00 $0.00Enter RAP data into a data base0.00 0.00 0.00 0.10 0.10 $2.10 $0.00 0 0.00 $0.00Review information submitted when the ALR is exceeded 0.00 0.50 10.00 0.00 10.50 $355.84 $0.00 0 0.00 $0.00Review and establish pump operating levels0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0.00 $0.00Review contingent corrective measures plan 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 0 0.00 $0.00Review hazardous waste removal plan0.00 0.00 1.00 0.00 1.00 $32.84 $0.00 0 0.00 $0.00Review extension request0.00 0.00 0.50 0.00 0.50 $16.42 $0.00 0 0.00 $0.00Review corrective action report (2 times annually) 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 0 0.00 $0.00Surface Impoundments - PermittedReceive and review written action leakage rate exceedance notifications 0.00 0.50 3.50 0.00 4.00 $142.38 $0.00 0 0.00 $0.00Review leakage reports0.00 0.50 10.00 0.00 10.50 $355.84 $0.00 0 0.00 $0.00Review notification of surface impoundment removal from service 0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 0 0.00 $0.00Review contingent corrective measures plan 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 0 0.00 $0.00Review hazardous waste removal plan0.00 0.00 1.00 0.00 1.00 $32.84 $0.00 0 0.00 $0.00Review extension request0.00 0.00 0.50 0.00 0.50 $16.42 $0.00 0 0.00 $0.00Review corrective action report (2 times annually) 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 0 0.00 $0.00W aste Piles - Interim StatusReview exemptions from design and operating requirements 0.00 0.00 7.00 0.00 7.00 $229.88 $0.00 0 0.00 $0.00Review exemptions from liner/ leachate system requirements 0.00 0.00 7.00 0.00 7.00 $229.88 $0.00 0 0.00 $0.00Review and establish action leakage rates0.00 0.00 10.00 0.00 10.00 $328.40 $0.00 0 0.00 $0.00Review Response Action Plans0.00 0.00 20.00 0.00 20.00 $656.80 $0.00 0 0.00 $0.00Receive and review written action leakage rate exceedance notifications 0.00 0.50 3.50 0.00 4.00 $142.38 $0.00 0 0.00 $0.00Review leakage reports0.00 0.50 10.00 0.00 10.50 $355.84 $0.00 0 0.00 $0.00Enter RAP data into a data base0.00 0.00 0.00 0.10 0.10 $2.10 $0.00 0 0.00 $0.00Review information submitted when the ALR is exceeded 0.00 0.50 10.00 0.00 10.50 $355.84 $0.00 0 0.00 $0.00W aste Piles - PermittedReceive andreview written actionleakage rate exceedance notifications0.000.503.500.004.00$142.38$0.0000.00$0.00Review leakage reports0.00 0.50 10.00 0.00 10.50 $355.84 $0.00 0 0.00 $0.00Review information submitted when the ALR is exceeded 0.00 0.50 10.00 0.00 10.50 $355.84 $0.00 0 0.00 $0.003EXHIBIT 14b (CONTINUED)ANNUAL STATES BURDEN AND COSTLegal Managerial Technical Clerical Respon. Labor Number of Total TotalHours Hours Hours Hours Hours Cost O&M Respondent Hours CostPer Year Per Year Costs Activities Per Year Per YearLand-Treatment - Interim StatusReview food-chain crop notifications0.00 0.00 1.00 0.00 1.00 $32.84 $0.00 0 0.00 $0.00Review certifications of closure0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 0 0.00 $0.00Land Treatment - PermittedReview notifications of significant releases of hazardous constituents below the treatment zone 0.00 0.00 1.00 0.00 1.00 $32.84 $0.00 00.00 $0.00Review notifications of intent to demonstrate that regulated unit0.00is not the source of increase in hazardous constituents 0.00 0.00 1.00 0.00 1.00 $32.84 $0.00 0 0.00 $0.00Review demonstrations that regulated unit is not the source of increase0.00in hazardous constituents below the treatment zone 0.00 0.00 16.00 0.00 16.00 $525.44 $0.00 0 0.00 $0.00Review (264.280)(d) demonstrations0.00 0.00 8.00 0.00 8.00 $262.72 $0.00 0 0.00 $0.00Review closure certifications0.00 1.00 4.00 0.00 5.00 $186.24 $0.00 0 0.00 $0.00Landfills - Interim StatusReview notifications of intent to receive waste 0.00 0.00 1.00 0.00 1.00 $32.84 $0.00 0 0.00 $0.00Review demonstrations for exemption from liner and leachate collection system requirements 0.00 0.00 16.00 0.00 16.00 $525.44 $0.00 0 0.00 $0.00Review information for waivers of the double liner requirements 0.00 0.00 4.00 0.00 4.00 $131.36 $0.00 0 0.00 $0.00Review and establish action leakage rates0.00 0.00 10.00 0.00 10.00 $328.40 $0.00 0 0.00 $0.00Review Response Action Plans0.00 0.00 20.00 0.00 20.00 $656.80 $0.00 0 0.00 $0.00Receive and review written action leakage rate exceedance notifications 0.00 0.50 3.50 0.00 4.00 $142.38 $0.00 0 0.00 $0.00Review leakage reports0.00 0.50 10.00 0.00 10.50 $355.84 $0.00 0 0.00 $0.00Enter RAP data into a data base0.00 0.00 0.00 0.10 0.10 $2.10 $0.00 0 0.00 $0.00Review information submitted when the ALR is exceeded 0.00 0.50 10.00 0.00 10.50 $355.84 $0.00 0 0.00 $0.00Review and establish pump operating levels0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0.00 $0.00Review demonstrations for placing non-hazardous liquid waste in landfills 0.00 0.00 7.00 0.00 7.00 $229.88 $0.00 0 0.00 $0.00Landfills - PermittedReceive and review written action leakage rate exceedance notifications 0.00 0.50 3.50 0.00 4.00 $142.38 $0.00 0 0.00 $0.00Review leakage reports0.00 0.50 10.00 0.00 10.50 $355.84 $0.00 0 0.00 $0.00Review information submitted when the ALR is exceeded 0.00 0.50 10.00 0.00 10.50 $355.84 $0.00 0 0.00 $0.00Review demonstrations for placing non-hazardous liquid waste in landfills 0.00 0.00 7.00 0.00 7.00 $229.88 $0.00 0 0.00 $0.00Incinerators - Interim StatusReview applications for certification to burn F020, F021, F022, F023, F026, and F027 0.00 0.50 20.00 0.00 20.50 $684.24 $0.00 0 0.00 $0.00Incinerators - PermittedReview notifications of intent to burn hazardous wastes F020, F021, F022, F023, F026, and F027 0.00 0.25 1.00 0.00 1.25 $46.56 $0.00 0 0.00 $0.00Review demonstrations for exemption from emergencywaste feed cutoff system testing requirements (264.347(c)) 0.00 0.00 16.00 0.00 16.00 $525.44 $0.00 1 14.40 $472.90Msc Units -Interim Status and PermittedCovered in other ICRs0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 0 0.00 $0.00Drip PadsReview plan for updating, repairing, and modifying the drip pad 0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 0 0.00 $0.00Review release notifications and reports0.00 0.00 1.00 0.00 1.00 $32.84 $0.00 0 0.00 $0.00Process Vents - PermittedReview semiannual reports0.00 0.00 8.00 0.00 8.00 $262.72 $0.00 43 345.60 $11,349.504EXHIBIT 14b (CONTINUED)ANNUAL STATES BURDEN AND COSTLegal Managerial Technical Clerical Respon. Labor Number of Total TotalHours Hours Hours Hours Hours Cost O&M Respondent Hours CostPer Year Per Year Costs Activities Per Year Per YearEquipment Leaks - Interim StatusReview notifications to implement the alternative valve standard in (265.1061)(a) 0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 1 1.80 $59.11Review notifications to discontinue alternative valve standard in (265.1061)(a) 0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 0 0.00 $0.00Review notifications to implement alternative valve standard in (265.1062)(b)(2) or (265.1062)(b)(3) 0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 0 0.00 $0.00Equipment Leaks - PermittedReview notifications to implement the alternative valve standard in (264.1061)(a) 0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 23 45.00 $1,477.80Review notifications to discontinue alternative valve standard in (264.1061)(a) 0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 0 0.00 $0.00Review notifications to implement alternative valve standard in (264.1062)(b)(2) or (264.1062)(b)(3) 0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 5 10.80 $354.67Review semiannual reports0.00 0.00 8.00 0.00 8.00 $262.72 $0.00 68 547.20 $17,970.05Containment Buildings - Interim StatusCollect written notice of request for delay of secondary containment 0.00 0.00 0.25 0.00 0.25 $8.21 $0.00 0 0.00 $0.00Review and comment on plans to retrofit unit 0.00 0.50 4.00 0.50 5.00 $169.28 $0.00 0 0.00 $0.00Review response to comments and approve/ disapprove delay 0.00 0.25 2.00 0.25 2.50 $84.64 $0.00 0 0.00 $0.00Receive notification of release0.00 0.00 0.25 0.00 0.25 $8.21 $0.00 0 0.00 $0.00Review written notice, description or remedial steps, and schedule for cleanup 0.00 0.00 0.25 0.00 0.25 $8.21 $0.00 0 0.00 $0.00Review information and determine if unit must be removed from service 0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 0 0.00 $0.00Notify owner/ operator in writing of determination 0.00 0.00 0.50 0.25 0.75 $21.66 $0.00 0 0.00 $0.00Review verification of cleanup0.00 0.00 0.25 0.00 0.25 $8.21 $0.00 0 0.00 $0.00Review demonstration that free liquids are for dust suppression and approve or disapprove waiver 0.00 0.25 1.00 0.25 1.50 $51.80 $0.000 0.00 $0.00Containment Buildings - PermittedCollect written notice of request for delay of secondary containment 0.00 0.00 0.25 0.00 0.25 $8.21 $0.00 0 0.00 $0.00Review and comment on plans to retrofit unit 0.00 0.00 4.00 0.50 4.50 $141.84 $0.00 5 24.30 $765.91Review response to comments and approve/ disapprove delay 0.00 0.50 2.00 0.25 2.75 $98.36 $0.00 5 14.85 $531.13Receive notification of release0.00 0.00 0.25 0.00 0.25 $8.21 $0.00 5 1.35 $44.33Review written notice, description or remedial steps, and schedule for cleanup 0.00 0.00 0.25 0.00 0.25 $8.21 $0.00 5 1.35 $44.33Review information and determine if unit must be removed from service 0.00 0.00 2.00 0.00 2.00 $65.68 $0.00 5 10.80 $354.67Notify owner/ operator in writing of determination 0.00 0.00 0.50 0.25 0.75 $21.66 $0.00 5 4.05 $116.95Review verification of cleanup0.00 0.00 0.25 0.00 0.25 $8.21 $0.00 5 1.35 $44.33Review demonstration that free liquids are for dust suppression and approve or disapprove waiver 0.00 0.25 1.00 0.25 1.50 $51.80 $0.0012 17.55 $606.03TOTAL0.00 varies varies varies varies varies $0.00 varies 2,197.23 $72,181.975EXHIBIT 15TOTAL ANNUAL EPA BURDEN AND COSTSTotal Total Total Total TotalHours per Capital Cost per O&M Cost per Labor Cost per Cost perEXHIBIT Year Year Year Year YearSUBPART ICONTAINERS 0 $0 $0 $0 $0SUBPART JTANK SYSTEMS 18 $0 $0 $906 $906SUBPART KSURFACE IMPOUNDMENTS 0 $0 $0 $0 $0SUBPART LWASTE PILES 0 $0 $0 $0 $0SUBPART MLAND TREATMENT 0 $0 $0 $0 $0SUBPART NLANDFILLS 0 $0 $0 $0 $0SUBPART OINCINERATORS 2 $0 $0 $82 $82SUBPART XMISCELLANEOUS UNITS 0 $0 $0 $0 $0SUBPART WDRIP PADS 0 $0 $0 $0 $0SUBPART AAPROCESS VENTS 356 $0 $0 $18,148 $18,148SUBPART BBEQUIPMENT LEAKS 931 $0 $0 $47,460 $47,460SUBPART DDCONTAINMENT BUILDINGS 4 $0 $0 $211 $211PART 266SPECIFIC HAZARDOUS WASTE RECOVERY/RECYCLING FACILITIES 0 $0 $0 $0 $0TOTAL EPA BURDEN 1,311 $0 $0 $66,807 $66,807Over 3-year period 3,932200,421$6EXHIBIT 15bTOTAL ANNUAL STATES BURDEN AND COSTSTotal Total Total Total TotalHours per Capital Cost per O&M Cost per Labor Cost per Cost perEXHIBIT Year Year Year Year YearSUBPART ICONTAINERS 0 $0 $0 $0 $0SUBPART JTANK SYSTEMS 1,157 $0 $0 $37,990 $37,990SUBPART KSURFACE IMPOUNDMENTS 0 $0 $0 $0 $0SUBPART LWASTE PILES 0 $0 $0 $0 $0SUBPART MLAND TREATMENT 0 $0 $0 $0 $0SUBPART NLANDFILLS 0 $0 $0 $0 $0SUBPART OINCINERATORS 14 $0 $0 $473 $473SUBPART XMISCELLANEOUS UNITS 0 $0 $0 $0 $0SUBPART WDRIP PADS 0 $0 $0 $0 $0SUBPART AAPROCESS VENTS 346 $0 $0 $11,350 $11,350SUBPART BBEQUIPMENT LEAKS 605 $0 $0 $19,862 $19,862SUBPART DDCONTAINMENT BUILDINGS 76 $0 $0 $2,508 $2,508PART 266SPECIFIC HAZARDOUS WASTE RECOVERY/RECYCLING FACILITIES 0 $0 $0 $0 $0TOTAL STATES BURDEN 2,197 $0 $0 $72,182 $72,182Over 3-year period 6,592216,546$7EXHIBIT 16aTOTAL PRIVATE AVERAGE RESPONDENT BURDENAverage Average Average AverageReporting Recordkeeping Reporting RecordkeepingBurden Burden Burden BurdenSUBPART ICONTAINERS 0 73 0 73SUBPART JTANK SYSTEMS 12 77 3 75SUBPART KSURFACE IMPOUNDMENTS 0 74 0 83SUBPART LWASTE PILES 0 0 0 17SUBPART MLAND TREATMENT 0 0 0 0SUBPART NLANDFILLS 0 0 0 0SUBPART OINCINERATORS 0 0 19 3SUBPART XMISCELLANEOUS UNITS N/A N/A 0 0SUBPART WDRIP PADS 0 34 0 0SUBPART AAPROCESS VENTS 0 448 10 399SUBPART BBEQUIPMENT LEAKS 1 47 6 40SUBPART DDCONTAINMENT BUILDINGS 0 0 3 28InterimStatusPermitted8EXHIBIT 16bTOTAL AVERAGE GOVERNMENTS RESPONDENT BURDENAverage Average Average AverageReporting Recordkeeping Reporting RecordkeepingBurden Burden Burden BurdenSUBPART ICONTAINERS 0 0 0 73SUBPART JTANK SYSTEMS 12 77 3 74SUBPART KSURFACE IMPOUNDMENTS 0 0 0 74SUBPART LWASTE PILES 0 0 0 0SUBPART MLAND TREATMENT 0 0 0 0SUBPART NLANDFILLS 0 0 0 0SUBPART OINCINERATORS 0 0 0 0SUBPART XMISCELLANEOUS UNITS N/A N/A 0 0SUBPART WDRIP PADS 0 34 0 0SUBPART AAPROCESS VENTS 0 27 10 400SUBPART BBEQUIPMENT LEAKS 1 45 6 43SUBPART DDCONTAINMENT BUILDINGS 0 0 0 0Interim Status Permitted