SUPPORTING STATEMENT FOR
               EPA INFORMATION COLLECTION REQUEST NUMBER 0976.18
"2017 HAZARDOUS WASTE REPORT, NOTIFICATION OF REGULATED WASTE ACTIVITY, AND PART A HAZARDOUS
                 WASTE PERMIT APPLICATION AND MODIFICATION"

                                 December 2016

                 Office of Resource Conservation and Recovery
                 United States Environmental Protection Agency
                            Washington, D.C. 20460

                               TABLE OF CONTENTS

1.	IDENTIFICATION OF THE INFORMATION COLLECTION	3
1(a)	TITLE AND NUMBER OF THE INFORMATION COLLECTION	3
1(b)	CHARACTERIZATION OF THE INFORMATION COLLECTION	3
2.	NEED FOR AND USE OF THE COLLECTION	3
2(a)	NEED AND AUTHORITY FOR THE COLLECTION	3
2(b)	PRACTICAL UTILITY AND USERS OF THE DATA	5
3.	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA	7
3(a)	NONDUPLICATION	7
3(b)	PUBLIC NOTICE	7
3(c)	CONSULTATIONS	8
3(d)	EFFECTS OF LESS FREQUENT COLLECTION	9
3(e)	GENERAL GUIDELINES	10
3(f)	CONFIDENTIALITY	10
3(g)	SENSITIVE QUESTIONS	11
4.	THE RESPONDENTS AND THE INFORMATION REQUESTED	11
4(a)	RESPONDENTS AND NAICS CODES	11
4(b)	INFORMATION REQUESTED	12
5.	THE INFORMATION COLLECTED:  AGENCY ACTIVITIES, COLLECTION
METHODOLOGY, AND INFORMATION MANAGEMENT	26
5(a)	AGENCY ACTIVITIES	26
5(b)	COLLECTION METHODOLOGY AND MANAGEMENT	29
5(c)	SMALL ENTITY FLEXIBILITY	29
5(d)	COLLECTION SCHEDULE	30
6.	ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION	34
6(a)	ESTIMATING RESPONDENT BURDEN HOURS	34
6(b)	ESTIMATING RESPONDENT COSTS	39
6(c)	ESTIMATING AGENCY HOUR AND COST BURDEN	41
6(d)	ESTIMATING RESPONDENT UNIVERSE AND TOTAL HOUR
AND COST BURDEN	42
6(e)	BOTTOM LINE HOUR AND COST BURDEN	53
6(f)	REASONS FOR CHANGE IN BURDEN	54
6(g)	PUBLIC BURDEN STATEMENT	56
1.	IDENTIFICATION OF THE INFORMATION COLLECTION

	1(a)	TITLE AND NUMBER OF THE INFORMATION COLLECTION

      This Information Collection Request (ICR) is entitled "2017 Hazardous Waste Report, Notification of Regulated Waste Activity, and Part A Hazardous Waste Permit Application and Modification (Renewal)," EPA ICR Number 0976.18, 2050-0024.

	1(b)	CHARACTERIZATION OF THE INFORMATION COLLECTION

      This is a request to renew a currently approved ICR of the U.S. Environmental Protection Agency (EPA): "2017 Hazardous Waste Report, Notification of Regulated Waste Activity, and Part A Hazardous Waste Permit Application and Modification," EPA ICR Number 0976.18 (OMB Control Number 2050-0024).  The ICR addresses the following requirements:

 Hazardous Waste Report requirements of Sections 3002 and 3004 of the Resource Conservation and Recovery Act (RCRA), as amended, which require reporting to EPA or to authorized States at least every two years.  The Hazardous Waste Report [EPA Form 8700-13 Form A/B], or comparable State report, is used by generators and treatment, storage, and disposal facilities (TSDFs) to satisfy this requirement.

 Notification requirements of Section 3010 of RCRA, as amended; 40 CFR 260.42 (hazardous secondary material activity); 40 CFR Part 262, Subpart K (alternative generator standards for academic laboratories); 40 CFR Part 273, Subpart C (universal waste activity); and 40 CFR Part 279 (used oil activity).  EPA Form 8700-12 is used by facilities to satisfy this requirement.

 Permit application requirements of Sections 3004 and 3005 of RCRA, as amended, which require anyone who owns or operates a facility where hazardous waste is treated, stored, or disposed to have a RCRA hazardous waste permit issued by EPA.  There are two parts to a RCRA hazardous waste permit application:  Part A and Part B.  Part A consists of EPA Form 8700-23, or comparable State form, along with maps, drawings, and photographs, as required by 40 CFR 270.13.  Part B contains detailed, site-specific information.  There is no form for the Part B Permit Application; rather, the Part B Permit Application must be submitted in narrative form and contain the information described in applicable sections of 40 CFR 270.14 through 270.27.  This ICR addresses the information collection requirements associated with completing and submitting a Part A Permit Application, or modifying a hazardous waste permit by submitting a revised application.  The information collection requirements associated with the Part B Permit Application are covered under a separate ICR.

2.	NEED FOR AND USE OF THE COLLECTION

      2(a)	NEED AND AUTHORITY FOR THE COLLECTION

(1)	Hazardous Waste Report

      RCRA Sections 3002 and 3004 authorize the Hazardous Waste Report.  Both sections require EPA to establish standards for recordkeeping and reporting of hazardous waste.  Section 3002 applies to hazardous waste generators and Section 3004 applies to hazardous waste TSDFs.  The implementing regulations are found at 40 CFR 262.40(b) and (d); 262.41(a)(1)-(5), (a)(8), and (b); 264.75(a)-(e) and (j); 265.75(a)-(e) and (j); and 270.30(l)(9).  This is mandatory reporting by the respondents.

      Section 3002(a)(6) requires submission of reports to EPA or the States at least every two years on the:  (1) quantities and nature of hazardous wastes that have been generated during the year and (2) disposition of these hazardous wastes.

      Section 3004(a) requires EPA to issue regulations establishing performance standards applicable to owners and operators of facilities for the treatment, storage, or disposal of hazardous waste that include reporting and maintaining records of all hazardous wastes treated, stored, or disposed and the manner in which such wastes were treated, stored, or disposed.

      There are a number of uses of the Hazardous Waste Report data.  EPA uses these data for planning and developing regulations.  In addition, Hazardous Waste Report data allow the Agency to determine whether its regulations are having the desired effect on the generation and management of hazardous waste.   For example, Hazardous Waste Report data provide information on whether wastes have shifted from one method of disposal to another.  Some State uses of Hazardous Waste Report data include:  support of planning, fee assessment, compliance monitoring, and enforcement.

(2)	Notification of Regulated Waste Activity

      Section 3010 of Subtitle C of RCRA, as amended, requires any person who generates, transports, or recycles regulated wastes or who owns or operates a facility for the treatment, storage, or disposal of regulated wastes to notify EPA of their activities, including the location and general description of the activities and the regulated wastes handled.  As required by statute, EPA promulgated regulations to implement these notification requirements at 40 CFR Parts 262, 263, 264, 265, 266, 270, 273, and 279.  EPA needs this information to determine the universe of persons who generate, handle, and manage these regulated wastes; assign EPA Identification Numbers; and ensure that these regulated wastes are managed in a way that protects human health and the environment, as required by RCRA, as amended.

 Part A Hazardous Waste Permit Application and Modification

      EPA promulgated regulations at 40 CFR 270.1 requiring owners or operators of TSDFs to submit a Part A Permit Application.  EPA needs information contained in the Part A Permit Application to identify the person(s) legally responsible for hazardous waste activity, to determine which facilities require permits under more than one program, to assess potential for the facility to pollute nearby ground and surface waters, to identify the time frame available for EPA to process permit applications, and to define the specific wastes a facility is legally allowed to handle for different purposes.

      EPA promulgated regulations at 40 CFR 270.72 outlining changes that require owners or operators to submit revised Part A Permit Applications.  Section 270.72(a)(1)-(3) requires owner/operators to submit both a revised Part A Permit Application and a written justification for changes in the design capacity of processes used at the facility, and/or changes or additions in a facility's hazardous waste treatment, storage, or disposal processes.  Under Section 270.72(a)(4), if an owner or operator changes ownership, or operational control of a facility, the new owner or operator is required to submit a revised Part A Permit Application, and a Subpart H compliance demonstration.  EPA needs revised permit applications, justifications, and compliance demonstrations to determine whether desired changes are acceptable or should be more closely reviewed as part of a full permit issuance process.

      2(b)	PRACTICAL UTILITY AND USERS OF THE DATA

(1)	Hazardous Waste Report

      Implementation of the RCRA program requires the collection of information on the characteristics of the regulated community generally (e.g., number of generators and TSDFs), as well as the specific characteristics of individual sites (e.g., waste handling activities undertaken).  This information is used for waste activity monitoring, compliance monitoring, technical assistance, program planning, waste minimization, and other program activities taken by EPA and the States.  The information also is used by public interest groups (such as the Right-to-Know Network) and industry.

      The Hazardous Waste Report also provides information to States for tracking shipments of waste.  Many States do not collect or track manifests, which provide, information on off-site shipments of hazardous waste; therefore, the Hazardous Waste Report serves as the only source of this information.

      Since 1991, EPA compiles and publishes the National Biennial RCRA Hazardous Waste Report based on the data for each odd number reporting year.  EPA and the States have many uses for Hazardous Waste Report information, including:

 Describing the various source activities that generate hazardous waste and the generated waste types and quantities.

 Describing the management methods by which the waste is treated, disposed, or recycled and the quantities managed by each method.

 Providing information for analysis of trends in waste generation, waste treatment and disposal, recycling, and source reduction.

 Understanding how much waste a State receives from out of State or sends out of State.

 Estimating available capacity for treating, recycling, and disposing hazardous wastes.

      Additionally, EPA utilizes the Hazardous Waste Report information for planning and developing regulations; regulation development depends on descriptions and quantities of generated hazardous waste and management methods used for treatment, recycling, and disposal.  The information allows the Agency to determine whether regulations are having the desired effect on the generation and management of hazardous waste; for example, the report provides information on whether the treatment of wastes has shifted from one method to another.  EPA also uses the information for conducting technical assistance, planning facility inspections, and carrying out regulatory enforcement.  States use the information for many of the same purposes as EPA; other State uses include planning, setting waste minimization goals, assessing fees, monitoring compliance, and carrying out enforcement.

      EPA and States receive requests for the information from many public and private organizations, including government agencies, businesses, public interest groups, and interested citizens.  Many requests come from businesses that supply chemicals, equipment, and services to hazardous waste generators and TSDFs.

(2)	Notification of Regulated Waste Activity

      EPA enters notification information submitted by respondents into an EPA national data system and assigns EPA Identification Numbers.  EPA uses the information primarily for tracking purposes, and secondarily for a variety of enforcement and inspection purposes.  In addition, EPA uses this information to identify the universe of regulated waste generators, handlers, and managers and their specific regulated waste activities.  Finally, EPA uses this information to ensure that regulated waste is managed properly, that statutory provisions are upheld, and that regulations are adhered to by facility owners or operators.

 Part A Hazardous Waste Permit Application and Modification

      EPA uses information in the Part A Permit Application to define which processes can be used and which wastes can be handled at newly regulated facilities subject to permitting requirements for the first time and permitted facilities with newly regulated units.  This includes defining allowable changes in facility operations and applies to new facilities not yet constructed; newly regulated facilities subject to RCRA permitting requirements for the first time; permitted facilities with newly regulated units; and interim status facilities.  EPA uses information in the Part A Permit Application to:

 Set priorities for processing permit applications;

 Respond to requests from hazardous waste generators for the names and locations of facilities where they can send their waste for storage, treatment, or disposal;

 Respond to public and Congressional inquiries regarding particular hazardous waste management facilities; and

 Ensure that facilities are operating in a manner protective of human health and the environment.

      EPA uses information from revised Part A Permit Applications and associated justifications and Subpart H compliance demonstrations to determine whether desired changes are acceptable under interim status or whether the change should be more closely reviewed as part of a full permit issuance process.  In addition, modifying the Part A Permit Application allows inspectors to have up-to-date information on major aspects of the facility, including the size of the operation, the hazardous wastes handled, and the types of processes used.  Without this documentation, EPA would be unable to determine the owner or operator's compliance with the management standards of 40 CFR Parts 264 or 265 or the rules governing changes during interim status.  This documentation also is useful for both EPA and the owner or operator in an enforcement action.

3.	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

      3(a)	NONDUPLICATION

      The information collected under this ICR is not available from any source other than respondents.  EPA's Office of Resource Conservation and Recovery (ORCR) is the only office within the Agency requiring the recordkeeping or reporting of this information.  No other Federal agency or department collects this information.

      The RCRA site identification information is collected on one common form--the Site ID Form--for the Hazardous Waste Report, the Notification of Regulated Waste Activity, and the RCRA Hazardous Waste Part A Permit Application.  A respondent may submit a copy of a previously reported Site ID Form and note any changes; this verifies and updates the site identification information.

      3(b)	PUBLIC NOTICE

      In compliance with the Paperwork Reduction Act of 1995, EPA issued a public notice in the Federal Register on April 18, 2016 (81 FR 25398).  The notice indicated that EPA was planning to submit an ICR, "2017 Hazardous Waste Report, Notification of Regulated Waste Activity, and Part A Hazardous Waste Permit Application and Modification" (EPA ICR No. 0976. 18, OMB Control No. 2050 - 0024), to the Office of Management and Budget (OMB) for review and approval in accordance with the Paperwork Reduction Act.  The notice also requested comments on the information collection and burden estimates covered in the ICR.  The public comment period extended through June 27, 2016.  EPA received 4 comments on this ICR in response to the Federal Register notice.

      Two comments that were received, one from the State of Hawaii Department of Health, and one from the Ohio Environmental Protection Agency, suggested edits and clarifications to the 2017 Hazardous Waste Report Instructions and Form booklet (EPA Form 8700-13).  Most of these minor edits and clarifications have been made to the booklet.  A third comment was an anonymous public submission that requested the definition for Management Method Code H135 be changed to clarify that this management method is for waste that were first stored or transported prior to being discharged to a Clean Water Act regulated unit.  EPA agrees with the comment and have made this clarification to the definition of H135.

      A final comment, from Morgan, Lewis & Bockius, LLP, took issue with the changes in the information to be reported on exports of hazardous waste in the Notification booklet (EPA Form 8700-12).  The commenter felt the Agency had not undergone proper rulemaking procedures before proposing to make such changes to the form.  In fact, EPA did propose changes to the regulations exports of hazardous waste on October 19, 2015 (80 FR 63482).  The "Hazardous Waste Export-Import Revisions" final rule was published on November 28, 2016 (81 FR 85696).  As was mentioned in the preamble to the final rule, changes will be made to form 8700-12 to implement the changes to reporting requirements for exporters of hazardous waste.  These changes have been made to form 8700-12 effective with this ICR renewal.

      3(c)	CONSULTATIONS

                                    Table 1
        Organizations EPA Contacted during the Development of this ICR

                                 Organization
                                 Contact Name
                                 Phone Number
Industry
W.L. Gore & Associates
Krista Gooch
<PHONE_NUMBER>
Indiana University
Kevin Mouser
<PHONE_NUMBER>
CVS Pharmacies
Charles Savage
<PHONE_NUMBER>
Essorc Cement Corporation
Stephen Roosz
<PHONE_NUMBER>
Tradebe Treatment and Recycling LLC
John Parise
<PHONE_NUMBER>
Frontier Scientific
Scott Williams
<PHONE_NUMBER>
State
Arizona Department of Environmental Quality
David R. Janke
<PHONE_NUMBER>
Indiana Department of Environmental Management
Yuliia Sheron
<PHONE_NUMBER>
Utah Department of Environmental Quality
Carlee Christofeersen
<PHONE_NUMBER>
	The Industry consultants were asked to review the burden estimates on gathering information, completing and submitting the three forms covered by this ICR.  The State consultants were asked to review the burden estimates on collecting, reviewing, and uploading the information on the three forms.  Based on the consultation information, the burden estimates for this renewal have remained the same.

      3(d)	EFFECTS OF LESS FREQUENT COLLECTION

      EPA has carefully considered the information collection burden imposed by the information collection requirements covered in this ICR.  EPA is confident that those activities required of respondents are necessary and, to the extent possible, the Agency has attempted to minimize the burden imposed.  A number of the required activities, for example, will be performed once (e.g., one-time notifications).  EPA believes strongly that, if the minimum information collection requirements are not met, EPA will not be able to ensure that hazardous waste and hazardous secondary material is being properly managed and do not pose a threat to human health and the environment.

 Hazardous Waste Report

      For the Hazardous Waste Report, the two-year cycle is statutorily required.  Although some States collect information on an annual or quarterly basis, EPA does not require more frequent data collection.

(2)	Notification of Regulated Waste Activity

      New hazardous waste generators, transporters, or TSDFs must submit EPA Form 8700-12 (i.e., the Site ID Form) and obtain an EPA Identification Number prior to treating (including recycling), storing, transporting, offering for transport, or disposing of hazardous waste.  Existing hazardous waste generators, transporters, or TSDFs are required to notify the Agency of their hazardous waste activity(ies) not later than 90 days after the promulgation or revision of regulations in 40 CFR Part 261 (identification and listing of hazardous wastes).  Owners or operators of smelting, melting, and refining furnaces that process hazardous waste either solely for metals recovery or for recovery of economically significant amounts of certain precious metals under sections 266.100(c)(1)(i) and 266.100(f)(1), respectively, and facilities that qualify for the small quantity on-site burner exemption under section 266.108(d) must provide a written, one-time notification of their hazardous waste activities.  Under Section 273.32(a), large quantity handlers of universal waste must submit a written, one-time notification of universal waste management to the Regional Administrator and obtain an EPA Identification Number before meeting or exceeding the 5,000 kilogram storage limit, unless they already have notified EPA, as provided by section 273.32(a)(2) or 273.32(a)(3).  Under sections 279.42, 279.51, 279.62 and 279.73, used oil handlers who have not previously complied with the notification requirement (under 40 CFR Part 266, Subpart E) must submit a written, one-time notification of used oil management activities and obtain an EPA Identification Number.  Any reduction in the frequency of this information collection would prevent the Agency from meeting the statutory requirements of RCRA Section 3010.

 Part A Hazardous Waste Permit Application and Modification

      A respondent's provision of information on a Part A Permit Application is essentially a one-time exercise that must occur when a facility is new or if an existing facility becomes subject to new permitting requirements.  Subsequent revisions to the Part A Permit Application are necessary only if an interim status facility changes its ownership and/or process or management of wastes.  EPA strongly believes that if the minimum requirements specified under the regulations are not met, neither the facilities nor EPA can ensure that hazardous wastes are being properly managed, and do not pose a serious threat to human health and the environment.

      3(e)	GENERAL GUIDELINES

	This ICR adheres to the guidelines stated in the Paperwork Reduction Act of 1995, OMB's implementing regulations, applicable OMB guidance, and EPA's ICR Handbook.  In addition, this information collection complies with EPA's Data Standards and Information Quality Guidelines.

      3(f)	CONFIDENTIALITY

 Hazardous Waste Report

      The Hazardous Waste Report requires businesses to provide information on various aspects of hazardous waste generation and management.  Some businesses consider some of their hazardous waste information to be Confidential Business Information (CBI).  A business may, if it desires, protect its Hazardous Waste Report information from public disclosure by asserting a claim of confidentiality covering all or part of its information.  If a confidentiality claim were asserted, EPA will treat the information in accordance with the confidentiality regulations at 40 CFR Part 2, Subpart B.  EPA also will ensure that the information collection procedures comply with the Privacy Act of 1974 and the OMB Circular 108.

(2)	Notification of Regulated Waste Activity

      The Agency does not anticipate that businesses will assert a claim of confidentiality covering all or part of the information submitted as part of their notifications.  However, if a confidentiality claim were asserted, EPA will treat the information in accordance with the confidentiality regulations at 40 CFR Part 2, Subpart B.  EPA also will ensure that the information collection procedures comply with the Privacy Act of 1974 and the OMB Circular 108.

 Part A Hazardous Waste Permit Application and Modification

      All information submitted in a Part A Permit Application or revision will be subject to public disclosure, without notice to the facility, in accordance with the Freedom of Information Act (5 U.S.C. Section 552) and EPA Freedom of Information Regulations at 40 CFR Part 2.  Because of the general nature of the information requested, only a few Part A Permit Applications to date have qualified for exemption to disclosure under the business confidentiality exception.  Claims of confidentiality must be clearly indicated on the forms and attachments, and must be accompanied, at the time of filing, by a written substantiation of the claim in accordance with 40 CFR Part 2, Subpart B (particularly the information described at 40 CFR 2.204(e)).  Information that is determined to be confidential is placed in a secured "confidential file" for future use.  Only persons with special clearance for confidential information have access to these files.

      3(g)	SENSITIVE QUESTIONS

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

4.	THE RESPONDENTS AND THE INFORMATION REQUESTED

      4(a)	RESPONDENTS AND NAICS CODES

      The following is a list of North American Industry Classification System (NAICS) codes associated with industries most likely affected by the information collection requirements covered in this ICR.

                            NAICS Code Description
                                  NAICS Code
Agriculture, Forestry, Fishing, and Hunting
                                      11
Mining
                                      21
Utilities
                                      22
Construction
                                      23
Manufacturing
                                     31-33
Wholesale Trade
                                      42
Retail Trade
                                     44-45
Transportation and Warehousing
                                     48-49
Information
                                      51
Finance and Insurance
                                      52
Real Estate, Rental, Leasing
                                      53
Professional, Scientific, and Technical Services
                                      54
Management of Companies and Enterprises
                                      55
Administrative Support, Waste Management, and Remediation
                                      56
Educational Services
                                      61
Health Care and Social Assistance
                                      62
Arts, Entertainment, Recreation
                                      71
Accommodation and Food Services
                                      72
Other Services
                                      81
Public Administration
                                      92

      4(b)	INFORMATION REQUESTED

 Hazardous Waste Report

      The Hazardous Waste Report consists of four forms:  RCRA Subtitle Site Identification Form (Site ID Form), Waste Generation and Management (Form GM), Waste Received from Off-Site (Form WR), and Off-Site Identification (Form OI; used only by States).  Only LQGs and TSDFs are required to complete the Hazardous Waste Report.

      As with most of the RCRA program, the Hazardous Waste Report data collection process is delegated to the States.  States provide respondents with either the Federal form or a State equivalent, collect the responses, contact non-respondents, enter the data (or load files if the State employs electronic methods for preparation and submittal of reports by regulated entities) into RCRAInfo using off-the-shelf software packages which have been developed to support the collection of Hazardous Waste Report data, assure data quality, and forward the data to EPA.

	States have discretion on the methods used to identify entities to whom they distribute forms and the subsequent tracking of reports received.  Most States generate mailing lists based on previous report submittals, augmented by recent notifications of regulated activity.  Many States levy fees based on the nature and extent of regulated activity identified in the report.  EPA makes all reported data (except any that may be claimed as CBI) available to the public on the Internet.  This provides further incentive for sites (and also for States and EPA) to ensure the information is complete and accurate because the public regularly accesses this information.

      (i)	Data Items:

                   Site ID Form - RCRA Subtitle C Site Identification Form.  The Site ID Form must be submitted by all sites required to file the Hazardous Waste Report.  This form collects information such as site name, EPA Identification Number, address, contact, and type of hazardous waste generation and management activities taking place at the site; it verifies their information, especially the site's generator status as the date of submission of the report.  It requires a certification signature for the submission of the report.

                   Form GM - Waste Generation and Management.  Form GM must be submitted by all respondents that generated or shipped large quantity generator amounts of RCRA hazardous waste during the reporting year.  This form collects information on each generated waste, including a narrative waste description, a waste characterization (waste codes, source, and form), quantity generated, and the method of waste management (whether managed on-site or shipped off-site).

                   Form WR - Waste Received From Off-Site.  Form WR must be submitted by all sites that received RCRA hazardous waste from off-site during the reporting year.  This form collects information on each waste received from off-site, including a narrative description of the waste, a brief waste characterization (e.g., waste codes), the EPA Identification Number of the off-site generator, the quantity of waste received, and the method of waste management.

                   Form OI - Off-Site Identification.  Form OI is not required by EPA; rather, it is provided as an option for States to collect the names and addresses of transporters, generators that ship waste, and receivers of waste reported on Forms GM and WR where only the EPA Identification Number is listed.

	(ii)	Respondent Activities:

            Facilities (i.e., LQGs and TSDFs) must perform the following activities, as applicable:

                   Read the Hazardous Waste Report instructions.

                   Gather information and complete Site ID Form.

                   Gather information and complete Form GM.

                   Gather information and complete Form WR.

                   Gather information and complete Form OI if required by the State (State-optional form, not a Federal form).

                   Submit the report to the State (or EPA Regional Office for some States and Territories).

                   Maintain a copy of each form for three years.

      State agencies must perform the following activities:

                   Distribute Hazardous Waste Report forms and instructions.

                   Assist respondents.

                   Key entry of report submissions.

                   Perform quality assurance.

(2)	Notification of Regulated Waste Activity

      (a)	Notification of Hazardous Secondary Material Activity under 40 CFR 260.42

      40 CFR 260.42(a) provides that hazardous secondary material generators, tolling contractors, toll manufacturers, reclaimers, and intermediate facilities managing hazardous secondary materials which are excluded from regulation under section 261.2(a)(2)(ii) or section 261.4(a)(23), (24), or (25) must send a notification prior to operating under the exclusion(s) and by March 1 of each even numbered year thereafter to the Regional Administrator using the RCRA Subtitle C Site Identification Form (EPA Form 8700-12) that includes the specified information at section 260.42(a)(1)-(10).

      Section 260.42(b) provides that, if a hazardous secondary material generator, tolling contractor, toll manufacturer, reclaimer or intermediate facility has submitted a notification, but then subsequently stops managing hazardous secondary materials in accordance with the exclusion(s), the facility must notify the Regional Administrator within thirty (30) days using EPA Form 8700-12.  For purposes of this section, a facility has stopped managing hazardous secondary materials if the facility no longer generates, manages and/or reclaims hazardous secondary materials under the exclusion(s) and does not expect to manage any amount of hazardous secondary materials for at least one year

      (i)	Data Items:

 Notification using EPA Form 8700-12, which includes the following information:
 The name, address, and EPA ID number (if applicable) of the facility;
 The name and telephone number of a contact person;
 The NAICS code of the facility;
 The exclusion under which the hazardous secondary materials will be managed (e.g., section 261.2(a)(2)(ii), section 261.4(a)(23), (24), and/or (25));
 For reclaimers and intermediate facilities managing hazardous secondary materials in accordance with section 261.4(a)(24) or (25), whether the reclaimer or intermediate facility has financial assurance (not applicable for persons managing hazardous secondary materials generated and reclaimed under the control of the generator);
 When the facility expects to begin managing the hazardous secondary materials in accordance with the exclusion;
 A list of hazardous secondary materials that will be managed according to the exclusion (reported as the EPA hazardous waste numbers that would apply if the hazardous secondary materials were managed as hazardous wastes);
 For each hazardous secondary material, whether the hazardous secondary material, or any portion thereof, will be managed in a land-based unit;
 The quantity of each hazardous secondary material to be managed annually; and
 The certification (included in EPA Form 8700-12) signed and dated by an authorized representative of the facility.

      (ii)	Respondent Activities:

      Facilities must perform the following activities, as applicable:

                   Complete and submit EPA Form 8700-12 prior to operating under exclusion(s).

                   Complete and submit EPA Form 8700-12 by March 1 of each even numbered year thereafter.

                   Complete and submit EPA Form 8700-12 indicating that the hazardous secondary materials are no longer managed in accordance with the exclusion, if applicable.

      State agencies must perform the following activities:

                   Review completed EPA Form 8700-12.

                   Enter EPA Form 8700-12 information into RCRAInfo.

      (b)	Notification of Hazardous Waste Activity under RCRA Section 3010

      Facilities that generate, transport, recycle, treat, store, or dispose of hazardous waste as defined by 40 CFR Part 261 must notify EPA of their hazardous waste activities and obtain an EPA Identification Number.  These notification requirements are codified at 40 CFR Parts 262, 263, 264, 265, 266, 270, and 273.  In order to comply with these requirements, facilities must complete and submit the RCRA Subtitle C Site Identification Form (EPA Form 8700-12).

      (i)	Data Item:

                   Notification using EPA Form 8700-12, which includes the following information:
                      Name of the facility;
                      Facility mailing address;
                      Facility location;
                      Name, title, and business telephone number of the person who should be contacted regarding information on the form;
                      Ownership information, including the legal status of the current owner of the facility;
                      Information on the type of hazardous waste activity;
                      Information on whether this is the initial notification or a subsequent notification;
                      A description of the hazardous wastes handled at the facility; and
                      A certification signed by the facility owner, operator, or authorized representative.

      (ii)	Respondent Activities:

      Facilities must perform the following activities:

                   Complete and submit EPA Form 8700-12.

      State agencies must perform the following activities:

                   Review completed EPA Form 8700-12.

                   Enter EPA Form 8700-12 information into RCRAInfo.

                   Generate EPA Identification Number and send EPA Identification Number to facility (if applicable).

      (c)	Notification of Hazardous Waste Activity under 40 CFR Part 262, Subpart K

      (c1)	Intent to Comply with Subpart K and Recordkeeping of Agreements

      40 CFR 262.203(a) provides that an eligible academic entity must notify the appropriate EPA Regional Administrator in writing, using the RCRA Subtitle C Site Identification Form (EPA Form 8700-12), that it is electing to be subject to the requirements of Subpart K for all the laboratories owned by the eligible academic entity under the same EPA Identification Number.  An eligible academic entity that is a CESQG and does not have an EPA Identification Number must notify that it is electing to be subject to the requirements of Subpart K for all the laboratories owned by the eligible academic entity that are on-site.  An eligible academic entity must submit a separate notification (Site ID Form) for each EPA Identification Number (or site, for CESQGs) that is electing to be subject to the requirements of Subpart K.

      When submitting the Site ID Form, the eligible academic entity must, at a minimum, fill out the fields on the form that are specified at section 262.203(b)(1)-(11).

      Section 262.203(c) provides that an eligible academic entity must keep a copy of the notification on file at the eligible academic entity while its laboratories are subject to Subpart K.

      Section 262.203(d) provides that a teaching hospital that is not owned by a college or university must keep a copy of its formal written affiliation agreement with a college or university on file at the teaching hospital while its laboratories are subject to Subpart K.

	Section 262.203(e) provides that a non-profit research institute that is not owned by a college or university must keep a copy of its formal written affiliation agreement with a college or university on file at the non-profit research institute while its laboratories are subject to Subpart K.

      (i)	Data Items:

 Notification, using EPA Form 8700-12, with the following fields filled out, at a minimum:
 Reason for submittal;
 Site EPA Identification Number (except for CESQGs);
 Site name;
 Site location information;
 Site land type;
 North American Industry Classification System (NAICS) code(s) for the site;
 Site mailing address;
 Site contact person;
 Operator and legal owner of the site;
 Type of regulated waste activity; and
 Certification.

 A copy of the formal written affiliation agreement with a college or university, as specified under section 262.203(d).

 A copy of the formal written affiliation agreement with a college or university, as specified under section 262.203(e).

      (ii)	Respondent Activities:

      Facilities must perform the following activities, as applicable:

                   Eligible academic entities electing to be subject to the requirements of Subpart K must perform the following:
                      Complete and submit EPA Form 8700-12; and
                      Keep a copy of the notification on file.

                   Teaching hospitals that are not owned by a college or university must:
                      Keep a copy of their formal written affiliation agreement with college or university on file while its laboratories are subject to Subpart K.

                   Non-profit research institutes that are not owned by a college or university must:
                      Keep a copy of the formal written affiliation agreement with a college or university on file at the non-profit research institute while its laboratories are subject to Subpart K.

      State agencies must perform the following activities:

                   Review completed EPA Form 8700-12.

                   Enter EPA Form 8700-12 information into RCRAInfo.

      (c2)	Withdrawal from 40 CFR Part 262, Subpart K

	40 CFR 262.204(a) provides that an eligible academic entity must notify the appropriate EPA Regional Administrator in writing, using the RCRA Subtitle C Site Identification Form (EPA Form 8700-12), that it is electing to no longer be subject to the requirements of Subpart K for all the laboratories owned by the eligible academic entity under the same EPA Identification Number.  An eligible academic entity that is a CESQG and does not have an EPA Identification Number must notify that it is withdrawing from the requirements of Subpart K for all the laboratories owned by the eligible academic entity that are on-site.  An eligible academic entity must submit a separate notification (Site ID Form) for each EPA Identification Number (or site, for CESQGs) that is withdrawing from the requirements of Subpart K.

      When submitting the Site ID Form, the eligible academic entity must, at a minimum, fill out the fields on the form that are specified at section 262.204(b)(1)-(11).

	Section 262.204(c) provides that an eligible academic entity must keep a copy of the withdrawal notice on file at the eligible academic entity for three years from the date of the notification.

	(i)	Data Items:

 A Site ID Form with the following fields filled out, at a minimum:
 Reason for submittal;
 Site EPA Identification Number (except for CESQGs);
 Site name;
 Site location information;
 Site land type;
 North American Industry Classification System (NAICS) code(s) for the site;
 Site mailing address;
 Site contact person;
 Operator and legal owner of the site;
 Type of regulated waste activity; and
 Certification.

      (ii)	Respondent Activities:

      Facilities must perform the following activities:

                   Complete and submit EPA Form 8700-12.

                   Keep a copy of the withdrawal notice on file.

      State agencies must perform the following activities:

                   Review completed EPA Form 8700-12.

                   Enter EPA Form 8700-12 information into RCRAInfo.

      (d)	Notification of Universal Waste Activity under 40 CFR Part 273, Subpart C

      Large quantity handlers of universal waste must notify EPA of their universal waste activities and obtain an EPA Identification Number.  These notification requirements are codified at 40 CFR Part 273, Subpart C.  In order to comply with these requirements, large quantity handlers of universal waste must complete and submit the RCRA Subtitle C Site Identification Form (EPA Form 8700-12), or complete and submit a letter to EPA requesting an EPA Identification Number.

      (i)	Data Items:

                   Notification (EPA Form 8700-12) that includes the following information:
                      Name of the facility;
                      Facility mailing address;
                      Facility location;
                      Name, title, and business telephone number of the person who should be contacted regarding information on the form;
                      Ownership information, including the legal status of the current owner of the facility;
                      Information on the type of hazardous waste activity;
                      Information on whether this is the initial notification or a subsequent notification;
                      A description of the hazardous wastes handled at the facility; and
                      A certification signed by the facility owner, operator, or authorized representative.

            Or

                   A letter that includes:
                      The universal waste handler's name and mailing address;
                      Name and business telephone number of the person who should be contacted regarding the universal waste management activities;
                      Address or physical location of the universal waste management activities;
                      A list of all of the types of universal waste managed by the handler; and
                      A statement indicating that the handler is accumulating more than 5,000 kilograms of universal waste at one time and the types of universal waste (e.g., batteries, pesticides, thermostats) the handler is accumulating above this quantity.

      (ii)	Respondent Activities:

      Facilities must perform the following activities:

                   Complete and submit EPA Form 8700-12 or a letter requesting an EPA Identification Number.

      State agencies must perform the following activities:

                   EPA Form 8700-12
 Review completed EPA Form 8700-12.
 Enter EPA Form 8700-12 information into RCRAInfo.
 Generate EPA Identification Number and send EPA Identification Number to facility (if applicable).

                  Or

                   Letter
 Review letter requesting EPA Identification Number.
 Enter letter information into RCRAInfo.
 Generate EPA Identification Number and send EPA Identification Number to facility (if applicable).

      (e)	Notification of Used Oil Activity under 40 CFR Part 279

      Used oil handlers must notify EPA of their used oil activities and obtain an EPA Identification Number.  These notification requirements are codified at 40 CFR Part 279.  In order to comply with these requirements, used oil handlers must complete and submit the RCRA Subtitle C Site Identification Form (EPA Form 8700-12), or complete and submit a letter to EPA requesting an EPA Identification Number.

      (i)	Data Items:

                   Notification using EPA Form 8700-12, which includes the following information:
 Name of the facility;
 Facility mailing address;
 Facility location;
 Name, title, and business telephone number of the person who should be contacted regarding information on the form;
 Ownership information, including the legal status of the current owner of the facility;
 Information on the type of hazardous waste activity;
 Information on whether this is the initial notification or a subsequent notification;
 A description of the hazardous wastes handled at the facility; and
 A certification signed by the facility owner, operator, or authorized representative.

            Or

                   A letter that includes:
                      Company name;
                      Owner of company;
                      Mailing address of company;
                      Name and telephone number of company contact;
                      Type of used oil management activity(ies);
                      Location of facility(ies) (except for used oil fuel marketers); and
                      Name and telephone number of each contact at each transfer facility, if applicable (for used oil transporters and transfer facilities only).

      (ii)	Respondent Activities:

      Facilities must perform the following activities:

                   Complete and submit EPA Form 8700-12 or a letter requesting an EPA Identification Number.

      State agencies must perform the following activities:

                   EPA Form 8700-12
 Review completed EPA Form 8700-12.
 Enter EPA Form 8700-12 information into RCRAInfo.
 Generate EPA Identification Number and send EPA Identification Number to facility (if applicable).

                  Or

                   Letter
 Review letter requesting EPA Identification Number.
 Enter letter information into RCRAInfo.
 Generate EPA Identification Number and send EPA Identification Number to facility (if applicable).

 Part A Hazardous Waste Permit Application and Modification

             Part A Permit Application

	(a1)	Contents of the Part A Permit Application

	40 CFR 270.1 requires owners or operators of newly regulated facilities subject to permitting requirements for the first time and permitted facilities with newly regulated units to prepare and submit a Part A Permit Application (EPA Form 8700-23).

      (i)	Data Items:

                   A list of the activities conducted by the applicant that require the owner or operator to obtain a RCRA permit.

                   Name, mailing address, and location, including latitude and longitude of the facility for which the application is submitted.

                   Up to four NAICS codes that best reflect the principal products or services provided by the facility.

                   Operator's name, address, telephone number, ownership status, and status as Federal, State, private, public or other entity.

                   Name, address, and phone number of the owner of the facility.

                   Whether the facility is located on Indian lands.

                   An indication of whether the facility is new or existing and whether it is a first or revised application.

                   For existing facilities, the following information:
                      A scale drawing of the facility showing the location of all past, present, and future treatment, storage, and disposal areas and
                      Photographs of the facility clearly delineating all existing structures; existing treatment, storage and disposal areas; and sites of future treatment, storage, and disposal areas;

                   A description of the processes to be used for treating, storing, and disposing of hazardous waste, and the design capacity of these items.

                   A specification of the hazardous wastes listed or designated under 40 CFR Part 261 to be treated, stored, or disposed of at the facility; an estimate of the quantity of such wastes to be treated, stored, or disposed annually; and a general description of the processes to be used for such wastes.

                   A listing of all permits or construction approvals received or applied for under any of the following programs:
                      Hazardous Waste Management program under RCRA
                      Underground Injection Control (UIC) Program under the Safe Drinking Water Act (SDWA)
                      National Pollutant Discharge Elimination System (NPDES) program under the Clean Water Act (CWA)
                      Prevention of Significant Deterioration (PSD) program under the Clean Air Act (CAA)
                      Nonattainment program under the CAA
                      National Emission Standards for Hazardous Air Pollutants (NESHAPS) preconstruction approval under the CAA
                      Ocean dumping permits under the Marine Protection Research and Sanctuaries Act
                      Dredge or fill permits under section 404 of the CWA
                      Other relevant environmental permits, including State permits.

                   A topographic map (or other map if a topographic map is unavailable) extending one mile beyond the property boundaries of the source, depicting the following aspects of the facility:
                      Each of its intake and discharge structures;
                      Each of its hazardous waste treatment, storage, or disposal facilities;
                      Each well where fluids from the facility are injected underground; and
                      Wells, springs, other surface water bodies, and drinking water wells listed in public records or otherwise known to the applicant within 1/4 mile of the facility property boundary.

                   A brief description of the nature of the business.

                   For hazardous debris, a description of the debris category(ies) and containment category(ies) to be treated, stored, or disposed of at the facility.

      (ii)	Respondent Activities:

      Facilities must perform the following activities:

                   Read the regulations and instructions.

                   Prepare the Site ID Form.

                   Prepare the Hazardous Waste Permit Information Form and reports.

      (a2)	Signatories to Permit Applications and Permit Application Reports

      40 CFR 270.11(a) requires operators of facilities to obtain the necessary signatures and certifications for the Part A Permit Application, reports, and other information requested by EPA.  Additionally, operators must obtain new authorization for authorizations deemed invalid.

      (i)	Data Items:

                   Signatures required on Part A Permit Applications:
                      For a corporation, the signature of a responsible corporate officer as defined at 40 CFR 270.11(a)(1).
                      For a partnership or sole proprietorship, the signature of a general partner or proprietor as defined at 40 CFR 270.11(a)(2).
                      For a municipality, State, Federal, or other public agency, the signature of either a principal executive officer or ranking elected official as defined at 40 CFR 270.11(a)(3).

                   Signatures for reports required by permits and other information requested by the Director:
                      For a corporation, the signature of a responsible corporate officer as defined at 40 CFR 270.11(a)(1).
                      For a partnership or sole proprietorship, the signature of a general partner or proprietor as defined at 40 CFR 270.11(a)(2).
                      For a municipality, State, Federal, or other public agency, the signature of either a principal executive officer or ranking elected official as defined at 40 CFR 270.11(a)(3).
                      Signature of a duly authorized representative of one of the persons listed above as defined at 40 CFR 270.11(b).

                   New authorization satisfying the requirements of 40 CFR 270.11(b) if an authorization under 40 CFR 270.11(b) is no longer accurate because a different individual or position has responsibility for the overall operation of the facility.  Data items for this requirement are the same as those under 40 CFR 270.11(b).

                   Certification:

                  I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted.  Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is to be the best of my knowledge and belief, true, accurate, and complete.  I am aware that there are significant penalties for submitting false information, including possibility of fine and imprisonment for knowing violations.

      (ii)	Respondent Activities:

      Facilities must perform the following activities:

                   Obtain signatures and certifications for the Part A Permit Application, reports, and other information requested by EPA.

                   Obtain a new authorization for invalid authorizations.

      (a3)	Submittal of Part A Permit Application

      40 CFR 270.70(b) requires owners and operators who submit a Part A Permit Application to EPA, to explain or cure an alleged deficiency in the Part A Permit Application, if EPA notifies the applicant that the application fails to meet the requirements of 40 CFR 270.13.

      (i)	Data Items:

                   Part A Permit Application and reports.

                   Explanation of alleged deficiency in the Part A Permit Application.

      (ii)	Respondent Activities:

      Facilities must perform the following activities:

                   Submit the Part A Permit Application and reports.

                   Explain or cure an alleged deficiency in the Part A Permit Application, if required.

      State agencies must perform the following activities:

                   Review information contained in the application.

                   Ensure that the Part A Permit Application and associated reports are signed by the appropriate person.

                   Review newly authorized signatures when a different individual or position gains responsibility for the overall operation of a facility.

                   Review signature certifications.

                   Enter information into RCRAInfo.

                   Notify applicant of deficiency in the Part A Permit Application.

             Revised Part A Permit Applications and Associated Justifications and Subpart H Compliance Demonstrations

      Under 40 CFR 270.72, interim status facilities must prepare and submit a revised Part A Permit Application if the Agency promulgates a rulemaking that affects the facility, or if the owner/operator otherwise modifies the facility.  Interim status facilities who modify their Part A Permit Application are required to submit a revised Part A Permit Application.

      (i)	Data Items:

                   Part A application using EPA Form 8700-23.

      (ii)	Respondent Activities:

      Facilities must perform the following activities:

                   Read the regulations and instructions in preparation for revising a Part A Permit Application in response to an Agency rulemaking or a facility modification.

                   Prepare and submit a revised Part A Permit Application in response to an Agency rulemaking or facility modification.

                   Prepare and submit justifications for changes, if needed.

                   Submit Subpart H compliance demonstrations, if needed.

      State agencies must perform the following activities:

                   Review information revised Part A Permit Application.

                   Enter revised Part A Permit Application information into RCRAInfo.

                   Review justifications for changes.

                   Review Subpart H compliance demonstrations.

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

      5(a)	AGENCY ACTIVITIES

(1)	Hazardous Waste Report

      As discussed in Section 4(b) of this document, the Hazardous Waste Report data collection process is delegated to the States.  However, EPA is involved throughout this process.  The extent of EPA's involvement depends on the activities performed by the States in the data collection process.  The following paragraphs briefly describe EPA's participation in the data collection process.

      In some cases, the EPA Region performs all of the State roles.  That is, EPA Regions VII and IX, where the Region implements the RCRA hazardous waste program for Iowa and Alaska respectively, provide respondents with the Federal form, collect the responses, contact non-respondents, enter the data into RCRAInfo using off-the-shelf software packages which have been developed to support the collection of Hazardous Waste Report data, assure data quality, and forward the data to EPA Headquarters.

      In other cases, the EPA Region provides direct processing support for some, but not all, of the collection activities.  For example, the EPA Region may support the State in data gathering and data quality assessment.

      In still other cases, the EPA Regions provide additional resources to the States.  For example, the EPA Region may provide technical support to States for the transfer of their files to EPA for incorporation into RCRAInfo.

      EPA Headquarters produces and distributes the Federal forms and related guidance, defines the data and file format for data, establishes the schedule for submitting data, manages the incorporation of State data into RCRAInfo, coordinates national data quality review, maintains RCRAInfo, and prepares a national report listing major facts about the national picture of hazardous waste generation and management for the reporting year.

      EPA activities for the Hazardous Waste Report include the following:

 Develop Hazardous Waste Report forms and instructions.

 Distribute Hazardous Waste Report forms and instructions.  EPA Headquarters distributes the form and instruction booklets to the States and Regions.  Regions prepare mailing lists, mail forms and instructions, record receipt of completed forms, and contact sites that fail to respond within the specified time period.

 Develop computer capabilities required to compile national data.  EPA Headquarters develops the computer capabilities required to load data into RCRAInfo, the reports which support data quality assessment and other programmatic use of the data, and preparation of the national report.

 Assist respondents.  EPA Regions and Headquarters provide assistance to respondents.  States are, however, the first point of contact for answering respondent questions and assistance, where applicable.

 Key entry of report submissions.  EPA Regions and the regulated entities, key enter or electronically load the data into RCRAInfo they select and maintain.  The data entry function was privatized for the 1999 Hazardous Waste Report process.  Many States, Regions, and the regulated community use one of the private vendor's software packages for data entry and recordkeeping.  Some reports are entered directly on State or vendor hosted Internet sites and some are submitted on diskettes.

 Perform quality assurance.  EPA Regions and Headquarters perform data quality assurance.  This includes:  follow-up to non-respondents, detection and correction of unacceptable responses (e.g., in cases where the respondent misunderstood the instructions); verification of exceptional responses (e.g., data reported by a respondent that differ significantly from data reported by the rest of the respondent universe) and identification of significant response changes between reporting years.  The national software supports these activities with a variety of data editing functions.

            Once reports are received, the QA/QC procedures include a hierarchy of assessments.  First, system procedures ensure the data has fundamental internal consistency (e.g., required data fields are populated and the values are of the correct data type and within allowed ranges).

            Second, the information content of the data for individual sites is evaluated to identify any potential over or under reporting (exception reports support identification of extremes and significant variance from one cycle to another).

            Third, assessment reports support evaluation of intra-State and inter-State shipments of wastes to identify potential discrepancies between reports submitted by generators and the TSDF's who were identified by the generator as receivers of the waste.

            Based on the assessments, EPA Regions identify cases where accuracy may be questionable.  For those cases, they generally contact the site to review the information received; and site respondent confirms that the data are correct or that the site intends to submit an amended report to correct discrepancies.

 Prepare the national report.  EPA Headquarters will prepare The National Biennial RCRA Hazardous Waste Report that will be made available to the Congress and the public by December 2018.

 Store the data.  The Hazardous Waste Reports will be stored by the EPA Regions for three years and may be maintained by each Region.  RCRAInfo is maintained by EPA Headquarters.

(2)	Notification of Regulated Waste Activity

      EPA activities are the same for all of the notification requirements covered in this ICR.  These activities include:

 For initial notifications:
                Reviewing the completed EPA Form 8700-12 or letter requesting an EPA Identification Number, as specified.
                Entering information into the EPA national data system.
                Generating an EPA Identification Number and sending the EPA Identification Number to the facility.

 For subsequent notifications:
                Reviewing the completed EPA Form 8700-12 or letter requesting an EPA Identification Number, as specified.
                Entering information into the EPA national data system.

 Part A Hazardous Waste Permit Application and Modification

      EPA activities associated with Part A Permit Applications include the following:

 For Part A Permit Applications:
             Reviewing information contained in the application.
             Ensuring that the Part A Permit Application and associated reports are signed by the appropriate person.
             Reviewing newly authorized signatures when a different individual or position gains responsibility for the overall operation of a facility.
             Reviewing signature certifications.
             Entering information into RCRAInfo.
             Notifying applicant of deficiency in the Part A Permit Application.

 For revised Part A Permit Applications, justifications, and compliance demonstrations:
             Review information revised Part A Permit Application.
             Enter revised Part A Permit Application information into RCRAInfo.
             Review justifications for changes.
             Review Subpart H compliance demonstrations.

     5(b)	COLLECTION METHODOLOGY AND MANAGEMENT

     In collecting and analyzing the information associated with this ICR, EPA and authorized States may use a telephone system, personal computers, and applicable RCRAInfo software.  They will ensure the accuracy and completeness of collected information by reviewing the submittals.  They will keep records of this information in file cabinets and/or computer systems.

     5(c)	SMALL ENTITY FLEXIBILITY

(1)	Hazardous Waste Report

      EPA uses the quantity of waste generated per month to determine the extent to which a firm should be regulated.  EPA categorizes generators of less than 1,000 kilograms of non-acute hazardous waste per month as small quantity generators (SQGs) and relieves them of specific requirements.

      SQGs are not required to file the Hazardous Waste Report.  A SQG who is sent the Hazardous Waste Report booklet due to a change in generator status or error need not respond.  They must return a completed RCRA Subtitle C Site Identification Form to update their generator status to ensure they are not subject to follow-up contact for biennial reporting.

(2)	Notification of Regulated Waste Activity

      Some respondents will be individuals or small organizations.  However, EPA believes that the information to be collected is the minimum amount necessary to fulfill the statutory requirements of RCRA.

 Part A Hazardous Waste Permit Application and Modification

      Interim status is statutorily conferred without regard to facility size.  Therefore, EPA believes that requirements regarding Part A submissions and revisions must apply equally to large and small businesses.  Although the legal requirements for Part A Permit Application information are the same for large and small businesses, the Agency believes that in practice the small entities will find it easier to provide the required information.  In many instances, a small organization will be able to complete or revise the Part A Permit Application in less time than larger organizations because they use fewer processes for the management of hazardous wastes and they manage fewer types of wastes.  As a rule of thumb, the complexity of preparing a Part A Permit Application depends upon the complexity of the processes of a hazardous waste facility and the wastes managed at the facility.  Therefore, if a small organization operates a complex facility (e.g., a chemical landfill that manages a very large number of waste streams), then the time to complete the Part A Permit Application will necessarily be greater.  Again, EPA has taken steps to minimize the burden on all respondents by providing detailed instructions for completion of the Part A Permit Application form and by requiring short answer responses to most of the items of the application.

      It also should be noted that the reporting requirements for changes are brief.  Therefore, owners or operators can easily comply with these requirements.  In addition, most of the revisions to Part A Permit Applications will entail merely checking boxes or filling in numbers to indicate the type of new activity or new waste to be handled at the facility.  Any written justification entails a short letter from the owner or operator.  EPA, therefore, estimates that the potential burden on small businesses caused by this information collection is minimal.

     5(d)	COLLECTION SCHEDULE

(1)	Hazardous Waste Report

      EPA's 2017 Hazardous Waste Report national implementation schedule is outlined in Table 2.

                                    Table 2
         2017 Hazardous Waste Report National Implementation Schedule

                                   Activity
                           Tentative
Completion Date
Facilities submit completed forms to Regions/States
                                  March 2018
Regions/States begin loading the data into RCRAInfo
                                  April 2018
Regions/States complete data loads
                                   July 2018
EPA Headquarters publishes Preliminary 2017 National Biennial data summaries
                                  August 2018
Last day to request a State Summary Report from EPA Headquarters
                                 October 2018
Regions/States complete loading corrected (if necessary) data into RCRAInfo
                                 November 2018
EPA Headquarters makes Final 2017 National Biennial data available on RCRAInfo Web (public Web site)
                                 December 2018

(2)	Notification of Regulated Waste Activity

      (a)	Notification of Hazardous Secondary Material Activity under 40 CFR 260.42

      A claimant must prepare and submit a notification to EPA prior to operating under the exclusion(s).  In addition, the claimant must update and submit notification to EPA by March 1 of each even numbered year thereafter.  A claimant that submitted a notification but then subsequently stops managing hazardous secondary materials in accordance with the exclusion(s) must submit notification to EPA within 30 days.

      (b)	Notification of Hazardous Waste Activity under RCRA Section 3010

      Under sections 262.12, 263.11, 264.11 and 265.11, all new hazardous waste generators, transporters, and TSDFs must notify EPA of their hazardous waste activities and obtain an EPA Identification Number before treating, storing, transporting, offering for transport, or disposing of hazardous waste.  Under section 270.1(b), these hazardous waste generators, transporters, and TSDFs, are also subject to newly promulgated or revised regulations at 40 CFR Part 261 (identification and listing of hazardous wastes) and must notify EPA of new or revised hazardous waste activities no later than 90 days after promulgation or revision.  In addition, other generators; transporters; recyclers; and treatment, storage and disposal facilities that are subject to notification requirements under sections 266.21, 266.22, 266.23, 266.70(b)(1), 266.80(b)(1)(i), 266.80(b)(2)(i), 266.101(a), 266.101(b), 266.101(c), 266.102(a)(2)(ii), 266.103(a)(4)(ii), and 273.60(a) must notify EPA of their hazardous waste activities within the same time frame.  Under section 273.54, universal waste transporters who determine that any material resulting from a release of universal waste is a hazardous waste are subject to 40 CFR Part 262.  As a result, these transporters may also be subject to, under these circumstances, the section 262.12 notification requirements and procedures.  As such, these transporters must, at that time, notify EPA of their hazardous waste activities and obtain an EPA Identification Number before treating, storing, transporting, offering for transport, or disposing of hazardous waste.  Finally, owners or operators of smelting, melting, and refining furnaces that process hazardous waste either solely for metals recovery or for recovery of economically significant amounts of certain precious metals under sections 266.100(c)(1)(i) and 266.100(f)(1), respectively, and facilities that qualify for the small quantity on-site burner exemption under section 266.108(d) must provide a written, one-time notification of their hazardous waste activities.

      (c)	Notification of Hazardous Waste Activity under 40 CFR Part 262, Subpart K

      (c1)	Intent to Comply with Subpart K and Recordkeeping of Agreements

      Under 40 CFR 262.203(a), an eligible academic entity must notify the appropriate EPA Regional Administrator in writing, using the RCRA Subtitle C Site Identification Form (EPA Form 8700-12), that it is electing to be subject to the requirements of Subpart K for all the laboratories owned by the eligible academic entity under the same EPA Identification Number.  An eligible academic entity that is a CESQG and does not have an EPA Identification Number must notify for all the laboratories owned by the eligible academic entity that are on-site.  An eligible academic entity must submit a separate notification (Site ID Form) for each EPA Identification Number (or site, for CESQGs) that is electing to be subject to the requirements of Subpart K.  This is a one-time notification.

      Section 262.203(c) provides that an eligible academic entity must keep a copy of the notification on file at the eligible academic entity while its laboratories are subject to Subpart K.

      Section 262.203(d) provides that a teaching hospital that is not owned by a college or university must keep a copy of its formal written affiliation agreement with a college or university on file at the teaching hospital while its laboratories are subject to Subpart K.

	Section 262.203(e) provides that a non-profit research institute that is not owned by a college or university must keep a copy of the formal written affiliation agreement with a college or university on file at the non-profit research institute while its laboratories are subject to Subpart K.

      (c2)	Withdrawal from 40 CFR Part 262, Subpart K

      Under 40 CFR 262.204(a), an eligible academic entity must notify the appropriate EPA Regional Administrator in writing, using the RCRA Subtitle C Site Identification Form (EPA Form 8700-12), that it is electing to no longer be subject to the requirements of Subpart K for all the laboratories owned by the eligible academic entity under the same EPA Identification Number.  An eligible academic entity that is a CESQG and does not have an EPA Identification Number must notify for all the laboratories owned by the eligible academic entity that are on-site.  An eligible academic entity must submit a separate notification (Site ID Form) for each EPA Identification Number (or site, for CESQGs) that is withdrawing from the requirements of Subpart K.  This is a one-time notification.

	Section 262.204(c) provides that an eligible academic entity must keep a copy of the withdrawal notice on file at the eligible academic entity for three years from the date of the notification.

      (d)	Notification of Universal Waste Activity under 40 CFR Part 273, Subpart C

      Under Section 273.32(a)(1), large quantity handlers of universal waste must submit a written, one-time notification of universal waste activity to the Regional Administrator and obtain an EPA Identification Number before meeting or exceeding the 5,000 kilogram storage limit, unless they already have notified EPA, as provided by section 273.32(a)(2) or 273.32(a)(3).

      (e)	Notification of Used Oil Activity under 40 CFR Part 279

      Under sections 279.42, 279.51, 279.62 and 279.73, used oil handlers who were not previously required to comply with the notification requirements (under 40 CFR Part 266, Subpart E) must submit a written, one-time notification of their used oil management activities and obtain an EPA Identification Number.

 Part A Hazardous Waste Permit Application and Modification

       Part A Permit Application

      Owners or operators of new hazardous waste management facilities that are not yet constructed are required to submit their Part A Permit Application, including signatures and certifications at least 180 days before physical construction is expected to commence.  For existing facilities newly subject to RCRA permitting requirements due to promulgation of a new regulation or listing of hazardous waste, the new regulation typically specifies the date by which Part A Permit Applications, including signatures and certifications, must be submitted.

             Revised Part A Permit Applications and Associated Justifications and Subpart H Compliance Demonstrations

      The time frame in which owners or operators must submit a revised Part A Permit Application varies according to the nature of changes at the facility.  For the following types of changes, the owner or operator must submit revised Part A Permit Applications and justifications prior to making the changes:

 Treating, storing, or disposing of hazardous wastes not previously identified in the Part A Permit Application.

 Increasing the design capacity of processes used at the facility.

 Changing or adding processes for treating, storing, or disposing of hazardous wastes.

	For changes in ownership or operational control of a facility, the new owner or operator must submit a revised Part A Permit Application no later than 90 days prior to the scheduled change.  Subpart H compliance demonstrations must be submitted within six months of the date of the change in ownership or operational control of the facility.

6.	ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION

      6(a)	ESTIMATING RESPONDENT BURDEN HOURS

      Exhibits 1 through 3 provide estimates of the respondent hourly burden associated with the information collection requirements covered in this ICR.  The exhibits include burden hours (total and by labor type) per respondent, as well as the overall burden hours for all respondents.  The majority of the hour estimates in Exhibits 1 through 3 are based on consultations with industry and States.

	In the following paragraphs, EPA describes the methodologies used to estimate the hourly burden associated with the information collections covered in this ICR.

 Hazardous Waste Report

      (a)	Methodology for Accounting for Site Identification Forms Pre-Populated by States

      In estimating the hourly burden for preparing the Site ID Form of the Hazardous Waste Report, EPA assumes that 65 percent of all the Site ID Forms will be pre-populated by States prior to distribution to respondents or by vendor software used by the respondents.  EPA also assumes that the remaining 35 percent of all the Site ID Forms will be completed manually.

      EPA estimates the burden for updating a pre-populated Site ID Form to be about 37 minutes (0.61 hour) per respondent and the burden for completing a Site ID Form in its entirety (i.e., completing a blank form manually) to be 1.26 hour per respondent.

      The above burden estimates are reflected in Exhibit 1 as weighted-averages.  EPA derived the weighted averages using the calculations in Table 3 below.  EPA multiplied the percentage of pre-populated Site ID Forms by the average burden for updating the information contained in the form.  EPA also multiplied the percentage of blank Site ID Forms by the average burden for completing the blank form.  Then, EPA added up these two products to derive an overall weighted-average burden.

                                    Table 3
    Assumptions and Weighted-Average Equation Used in Estimating Burden to
      Complete the Site Identification Form of the Hazardous Waste Report

                                  Assumptions
                           Weighted-Average Equation
0.61 hours to complete pre-populated form; 65 percent of the forms are pre-populated
                     (0.61 hr x 0.65) + (1.26 hrs x 0.35)
                                 = 0.84 hours
1.26 hour to complete blank form;
35 percent of the forms are blank

      (b)	Methodology for Accounting for Form GM and Form WR Electronic Reporting

      During consultations conducted during the development of previous versions of this ICR, State and facility representatives indicated that Forms GM and WR often can be completed from RCRAInfo that track manifests or other information for billing purposes.  Based on these consultations, EPA estimated the hourly burden for the Forms GM and WR submitted electronically to be significantly less than for forms submitted on paper.

      To estimate the percentage of facilities that submit Forms GM and WR electronically, EPA used information gained from consultations and 2015 Hazardous Waste Report data.  For Form GM submissions, EPA estimated that, based on consultations and best professional judgment, facilities submitting five (5) or more Forms GM for the Hazardous Waste Report are likely to do so electronically.  Using 2015 Hazardous Waste Report data, EPA identified sites submitting Forms GM, counted their Forms GM submitted, and calculated the percentage that their Forms GM represented of the total number of Forms GM.  Based on this methodology, EPA estimates that 94 percent of Forms GM are submitted electronically, while the remaining 6 percent are sent manually.

      For Forms WR, EPA believes that TSDFs receiving large numbers of off-site shipments are more likely to have systems in place to track waste stream data, and as a consequence, to submit Hazardous Waste Report data electronically.  Using 2015 Hazardous Waste Report data, EPA reviewed the list of Forms WR reported to the Hazardous Waste Report by facility and, based on its own professional judgment and consultations, estimates that 100 percent of Forms WR are submitted electronically.

      To estimate the average burden per respondent in preparing a Form GM or WR, EPA used the weighted-average calculations in Table 4.  EPA multiplied the percentage of both forms submitted electronically by their respective burden for electronic reporting and the percentage of both forms submitted manually by their respective burden for manual reporting.  Then, EPA added the two products for each form, respectively, to calculate an overall weighted-average burden for both forms.

                                    Table 4
    Assumptions and Weighted-Average Equations Used in Estimating Burden to
          Complete Form GM and Form WR of the Hazardous Waste Report

                                   Activity
                                  Assumptions
                           Weighted-Average Equation
                                   Complete
                                    Form GM
0.27 hour to complete electronically;
94 percent of the forms are completed electronically

1.19 hours to complete manually;
6 percent of the forms are completed manually
                     (0.27 hr x 0.94) + (1.19 hrs x 0.06)
                                  = 0.32 hour
                                   Complete
                                    Form WR
0.12 hour to complete electronically;
100% of the forms are completed electronically
                                  0.12 hr x 1
                                  = 0.12 hour

(2)	Notification of Regulated Waste Activity

      (a)	Notification of Hazardous Secondary Material Activity under 40 CFR 260.42

      For purposes of this ICR, EPA anticipates that all of the facilities electing to operate under the hazardous secondary material exclusion under 40 CFR 260.42 during the two-year period covered by this ICR have already submitted the Site ID Form at least once.  Of these facilities, EPA estimates that 50 percent will complete a blank Site ID Form to notify EPA or the State prior to operating under the exclusion and by March 1 of each even numbered year.  EPA estimates that the other 50 percent will use their most recently submitted Site ID Form in complying with these notification requirements.

      EPA estimates the burden for completing a blank Site ID Form under section 260.42 to be 1.33 hours per respondent and the burden for using a previously submitted form to be 0.95 hours per respondent.  EPA notes that section 260.42 imposes several substantive requirements specific to the exclusions that must be completed (e.g., quantity of secondary material to be managed annually) in addition to the rest of the Site ID Form.

      For the notification submitted indicating that the hazardous secondary materials are no longer managed in accordance to the exclusion, EPA estimates the average hourly burden for completing the Site ID Form in its entirety (i.e., a blank form) to be about 50 minutes (0.83 hour) per respondent.  EPA also estimates the average hourly burden for updating the most recently submitted Site ID Form to be 27 minutes (0.45 hour) per respondent.

      The above burden estimates are reflected in Exhibit 2 as weighted-averages.  EPA derived the weighted averages using the calculations in Table 5 below.  EPA multiplied the percentage of facilities completing the Site ID Form on its entirety by the average burden for completing the blank form.  EPA also multiplied the percentage of facilities that will use the most recently submitted Site ID Form by the average burden for updating the information contained in the form.  Then, EPA added up these two products to derive an overall weighted-average burden.

                                    Table 5
                   Assumptions and Weighted-Average Equation
           Used in Estimating Burden to Complete the Notification of
           Hazardous Secondary Material Activity under 40 CFR 260.42

                                  Assumptions
                           Weighted-Average Equation
Notification Prior to Operating under Exclusion AND
Notification Submitted by March 1 of Each Even Numbered Year Thereafter
1.33 hours to complete blank form;
50 percent of the facilities
                     (1.33 hrs x 0.50) + (0.95 hr x 0.50)
                                 = 1.14 hours
0.95 hour to update most recently submitted form;
50 percent of the facilities

Notification Indicating that Hazardous Secondary Materials are no Longer Managed in Accordance to the Exclusion
0.83 hour to complete blank form;
50 percent of the facilities
                      (0.83 hr x 0.50) + (0.45 hr x 0.50)
                                  = 0.64 hour
0.45 hour to update most recently submitted form;
50 percent of the facilities

 Notification of Hazardous Waste Activity under 40 CFR Part 262, Subpart K

      For purposes of this ICR, EPA anticipates that all of the facilities opting into Subpart K during the two-year period covered by this ICR have already submitted the Site ID Form at least once.  Of these facilities, EPA estimates that 50 percent will complete a blank Site ID Form in opting into Subpart K and in withdrawing from Subpart K.  EPA estimates that the other 50 percent will use their most recently submitted Site ID Form in complying with these notification requirements.

      EPA estimates the burden for completing a blank Site ID Form under Subpart K to be 50 minutes (0.83 hour) per respondent and the burden for using a previously submitted form to be 27 minutes (0.45 hour) per respondent.

      The above burden estimates are reflected in Exhibit 2 as weighted-averages.  EPA derived the weighted averages using the calculations in Table 6 below.  EPA multiplied the percentage of facilities completing the Site ID Form on its entirety by the average burden for completing the blank form.  EPA also multiplied the percentage of facilities that will use the most recently submitted Site ID Form by the average burden for updating the information contained in the form.  Then, EPA added up these two products to derive an overall weighted-average burden.

                                    Table 6
                   Assumptions and Weighted-Average Equation
           Used in Estimating Burden to Complete the Notification of
           Hazardous Waste Activity under 40 CFR Part 262, Subpart K

                                  Assumptions
                           Weighted-Average Equation
0.83 hour to complete blank form;
50 percent of the facilities
                      (0.83 hr x 0.50) + (0.45 hr x 0.50)
                                  = 0.64 hour
0.45 hour to update most recently submitted form;
50 percent of the facilities

 Other Notifications Covered in this ICR

      For purposes of this ICR, EPA anticipates that 50 percent of the facilities submitting subsequent notifications under RCRA Section 3010; 40 CFR Part 273, Subpart C; and 40 CFR Part 279 will complete a blank Site ID Form.  EPA estimates that the other 50 percent will use their most recently submitted Site ID Form in complying with these notification requirements.

      EPA estimates the burden for completing a blank Site ID Form to be 50 minutes (0.83 hour) per respondent and the burden for using a previously submitted form to be 27 minutes (0.45 hour) per respondent.

      The above burden estimates are reflected in Exhibit 2 as weighted-averages.  EPA derived the weighted averages using the calculations in Table 7 below.  EPA multiplied the percentage of facilities completing the Site ID Form on its entirety by the average burden for completing the blank form.  EPA also multiplied the percentage of facilities that will use the most recently submitted Site ID Form by the average burden for updating the information contained in the form.  Then, EPA added up these two products to derive an overall weighted-average burden.

                                    Table 7
               Assumptions and Weighted-Average Equation Used in
     Estimating Burden to Complete Other Notifications Covered in this ICR

                                  Assumptions
                           Weighted-Average Equation
0.83 hour to complete blank form;
50 percent of the facilities
                      (0.83 hr x 0.50) + (0.45 hr x 0.50)
                                  = 0.64 hour
0.45 hour to update most recently submitted form;
50 percent of the facilities

 Part A Hazardous Waste Permit Application and Modification

      In estimating the hourly burden for preparing the Site ID Form of the Part A Permit Application, EPA assumes that all of the facilities submitting a Part A Permit Application or Modification during the two-year period covered by this ICR have already submitted the Site ID Form at least once.  Of these facilities, EPA estimates that 50 percent will complete a blank Site ID Form and the remaining 50 percent will use their most recently submitted Site ID Form.

      EPA estimates the burden for completing a blank Site ID Form to be 1.26 hour per respondent and the burden for using a previously submitted form to be 37 minutes (0.61 hour) per respondent.

      The above burden estimates are reflected in Exhibit 3 as weighted-averages.  EPA derived the weighted averages using the calculations in Table 8 below.  EPA multiplied the percentage of facilities completing the Site ID Form on its entirety by the average burden for completing the blank form.  EPA also multiplied the percentage of facilities that will use the most recently submitted Site ID Form by the average burden for updating the information contained in the form.  Then, EPA added up these two products to derive an overall weighted-average burden.

                                    Table 8
Assumptions and Weighted-Average Equation Used in Estimating
Burden to Complete the Site Identification Form of the Part A Permit Application

                                  Assumptions
                           Weighted-Average Equation
1.26 hour to complete blank form;
50 percent of the facilities
                     (1.26 hrs x 0.50) + (0.61 hr x 0.50)
                                  = 0.94 hour
0.61 hour to update most recently submitted form;
50 percent of the facilities

      6(b)	ESTIMATING RESPONDENT COSTS

      Exhibits 1 through 3 provide estimates of the annual respondent costs associated with the information collection requirements covered in this ICR.  These costs are based on the cost of labor, capital, and operation and maintenance (O&M).

(1)	Labor Costs

	Using the total burden hours discussed in Section 6(a) and the hourly labor costs outlined in this section, Exhibits 1 through 3 illustrate the labor costs associated with the information collection requirements covered in this ICR.

       Private Sector Facilities

	EPA estimates an average hourly respondent labor cost (including fringe and overhead) of $136.44 for legal staff, $80.64 for managerial staff, $60.08 for technical staff, and $36.14 for clerical staff.  These respondent labor costs were obtained from the previously approved ICR and updated to 2016 levels using Employment Cost Indexes developed by the U.S. Bureau of Labor Statistics.

       State and Local Government Facilities and Agencies

	EPA estimates an average hourly respondent labor cost (including fringe and overhead) of $63.48 for legal staff, $59.59 for managerial staff, $35.65 for technical staff, and $22.74 for clerical staff.  These respondent labor costs were obtained from the previously approved ICR and updated to 2016 levels using Employment Cost Indexes developed by the U.S. Bureau of Labor Statistics.

(2)	Capital Costs

      Capital costs usually include any produced physical good needed to provide the needed information, such as machinery, computers, and other equipment.  EPA does not anticipate that respondents will incur capital costs in carrying out the information collection requirements covered in this ICR.

(3)	Operation and Maintenance Costs

      O&M costs are those costs associated with an information collection requirement incurred continually over the life of the ICR.  For this ICR, O&M costs include mailing costs:

 EPA estimates that facilities submitting a Hazardous Waste Report or a Part A Permit Application to EPA or States will incur a cost of $6.51 to mail an 11-ounce large envelope by certified mail ($3.08 for postage, $3.30 for the certified-mail fee, and $0.14 for a catalog envelope)., ,

 EPA estimates that facilities submitting a notification to EPA will incur a cost of $3.82 to mail a one-ounce letter by certified mail (i.e., $0.49 for first-class letter postage, $3.30 for the certified-mail fee, and $0.03 for standard business envelope)., ,

 EPA estimates that State agencies distributing the Hazardous Waste Report to facilities will incur a cost of $3.21 to mail an 11-ounce large envelope ($3.08 for postage and $0.14 for a catalog envelope).[,]

      The above O&M costs are shown in Exhibits 1 through 3 for all applicable respondent activities.

      6(c)	ESTIMATING AGENCY HOUR AND COST BURDEN

      EPA estimates the Agency hour and cost burden associated with the information collection requirements covered in this ICR in Exhibits 4 through 6.  As shown in the exhibits, EPA estimates an average hourly labor cost of $89.18 for legal staff (GS15, Step 5), $78.69 for managerial staff (GS-15, Step 1), $56.61 for technical staff (GS-13, Step 1), and $24.16 for clerical staff (GS-06, Step 1).  To derive these hourly estimates, EPA referred to the General Schedule (GS) Salary Table 2016.  This publication summarizes the unloaded (base) hourly rate for various labor categories in the Federal Government.  EPA then applied the standard government overhead factor of 1.6 to the unloaded rate to derive loaded hourly rates.

      EPA does not anticipate that the Agency will incur capital costs in carrying out the information collection requirements covered in this ICR.

	O&M costs are associated with Hazardous Waste Report activities.  In particular, EPA estimates that the Agency will incur a cost of $22,283 in printing paper and CD copies of the Hazardous Waste Report forms and instructions, $278,540 in developing computer capabilities required to compile national data, $55,708 in preparing the National Report, and $38,534 in storing the national data.  These O&M costs were obtained from the previously approved ICR and updated to 2016 levels using Consumer Price Indexes developed by the Bureau of Labor Statistics.  EPA O&M costs are shown in Exhibit 4 for all applicable activities.

      6(d)	ESTIMATING RESPONDENT UNIVERSE AND TOTAL HOUR AND COST BURDEN

      In this section, EPA first describes the estimated respondent universe.  EPA then estimates the annual burden to respondents under the information collection requirements covered in this ICR.

      EPA notes that, as used in this document, the term "respondent" includes:

 Hazardous waste facilities complying with the Hazardous Waste Report, notification, and Part A Permit Application requirements covered in this ICR.  This includes:
                Private sector entities; and
                State and local government agencies that are regulated entities.

 State agencies administering the RCRA hazardous waste program.

(1)	Respondent Universe

       Hazardous Waste Report

      Based on 2015 Hazardous Waste Report data, EPA estimates that the total number of respondents to the 2017 Hazardous Waste Report will be 26,190, which annualized over the two-year report cycle equals 13,095 per year (i.e., 26,190/2).  Table 9 presents information on the total number of forms associated with the 2017 Hazardous Waste Report.  In estimating annual respondent burden and cost, EPA annualized these numbers over the two-year report cycle.

                                    Table 9
               Total Number of 2017 Hazardous Waste Report Forms

                          Hazardous Waste Report Form
                              Number of Forms [a]

                                Private Sector
                          State and Local Government
                                     Total
Site Identification (Site ID) Form
                                    24,689
                                     1,394
                                    26,083
Form GM - Generation and Management
                                    278,567
                                    11,191
                                    289,758
Form WR - Waste Received from Offsite
                                   1,213,209
                                     9,356
                                   1,022,565
                                                                          Total
                                   1,516,465
                                    21,941
                                   1,538,406

      The number of respondents and forms for each respondent activity is presented in Exhibit 1.  These estimates assume that all forms are submitted in accordance with the Hazardous Waste Report instructions.  Exhibit 1 also estimates the annual respondent burden and cost for the activities examined.

      (b)	Notification of Regulated Waste Activity

      In estimating the number of respondents subject to the notification requirements covered in this ICR, EPA referred to RCRAInfo.  EPA estimated the annual number of notifications tracked by RCRAInfo.  EPA then averaged the number of notifications submitted in 2014 and 2015.  These estimates are presented in Table 10 and used to estimate the total respondent burden and costs per information collection activity shown in Exhibit 2 of this ICR.

       Part A Hazardous Waste Permit Application and Modification

      In estimating the number of respondents subject to the Part A Permit Application requirements covered in this ICR, EPA referred to the RCRAInfo system.  EPA estimated the annual number of Part A Permit Applications tracked by RCRAInfo.  EPA then averaged the number of applications submitted in 2014 and 2015.  These estimates are presented in Table 11 and used to estimate the total respondent burden and costs per information collection activity shown in Exhibit 3 of this ICR.

                                   Table 10
Annual Number of Respondents Subject to the Notification Requirements Covered in this ICR [a]

                              Respondent Universe
                                   Year 2014
                                   Year 2015
                        Average of Years 2014 and 2015

                                    Private
                                  Sector [b]
                                   State and
                                     Local
                                Government [c]
                                     Total
                                    Private
                                  Sector [b]
                                   State and
                                     Local
                                Government [c]
                                     Total
                                    Private
                                  Sector [b]
                                   State and
                                     Local
                                Government [c]
                                     Total
Notification of Hazardous Secondary Material Activity under 40 CFR 260.42
Number of facilities submitting notification prior to operating under exclusion
                                      23
                                       1
                                      24
                                      16
                                       0
                                      16
                                      20
                                       1
                                      21
Number of small quantity generators (SQGs) and conditionally-exempt small quantity generators (CESQGs) submitting notification by March 1 of each even numbered year thereafter
                                      11
                                       0
                                      11
                                       2
                                       0
                                       2
                                       7
                                       0
                                       7
Number of facilities submitting notification indicating that they will no longer manage hazardous secondary materials in accordance with the exclusion
                                       2
                                       0
                                       2
                                       2
                                       0
                                       2
                                       2
                                       0
                                       2
Notification of Hazardous Waste Activity under RCRA Section 3010
Number of facilities submitting initial notification
                                     9,191
                                      920
                                    10,111
                                     8,919
                                      974
                                     9,893
                                     9,055
                                      947
                                    10,002
Number of facilities submitting subsequent notification
                                    38,202
                                     1,980
                                    40,182
                                    38,320
                                     1,944
                                    40,264
                                    38,261
                                     1,962
                                    40,223
Notification of Hazardous Waste Activity under 40 CFR Part 262, Subpart K
Number of eligible academic entities submitting notification of intent to comply with Subpart K and recordkeeping of agreements
                                      0
                                      6
                                      6
                                       8
                                      7
                                      15
                                       4
                                       7
                                      11
Number of teaching hospitals not owned by a college or university opting into Subpart K
                                      5
                                      0
                                      5
                                      1
                                      0
                                      1
                                       3
                                       0
                                       3
Number of non-profit research institutes not owned by a college or university opting into Subpart K
                                      0
                                      0
                                      0
                                      0
                                      0
                                      0
                                       0
                                       0
                                       0
Number of eligible academic entities submitting notification of withdrawal from 40 CFR Part 262, Subpart K
                                      33
                                      0
                                      33
                                      44
                                      2
                                      46
                                      39
                                       1
                                      40
Notification of Universal Waste Activity under 40 CFR Part 273, Subpart C
Number of facilities submitting initial notification
                                      67
                                      13
                                      80
                                      41
                                      10
                                      51
                                      54
                                      12
                                      66
Number of facilities submitting subsequent notification
                                      96
                                      11
                                      107
                                      67
                                      18
                                      85
                                      82
                                      15
                                      97
Notification of Used Oil Activity under 40 CFR Part 279
Number of facilities submitting initial notification
                                      85
                                       5
                                      90
                                      49
                                       2
                                      51
                                      67
                                       4
                                      71
Number of facilities submitting subsequent notification
                                      220
                                       7
                                      227
                                      329
                                      11
                                      340
                                      275
                                       9
                                      284
[a]  Based on data from the following RCRAInfo tables:  (1) "Hhandler," (2) "Howner_operator," (3) "Huniversal_waste," and (4) "Hhsm_basic."
[b]  Includes facilities owned and/or operated by "private" or "other."  Note that, in order to qualify as "private," the facility cannot be owned or operated by a Federal, State, or local government.  For example, a facility owned by a State government and operated by a private entity would qualify as a "State and local government" facility, not as a "private" facility.
[c]  Includes facilities owned and/or operated by a "County," "District," "Indian," "Municipal," or "State."  Note that, in order to qualify as "State and local government," the facility cannot be owned or operated by the Federal government.  For example, a facility owned by the Federal government and operated by a Municipal government would qualify as a "Federal government" facility, not a "State and local government" facility.

                                   Table 11
Annual Number of Respondents Subject to the Part A Permit Application Requirements Covered in this ICR [a]

                                  Respondent
                                   Universe
                                   Year 2014
                                   Year 2015
                        Average of Years 2014 and 2015

                                    Private
                                  Sector [b]
                                   State and
                                     Local
                                Government [c]
                                     Total
                                    Private
                                  Sector [b]
                                   State and
                                     Local
                                Government [c]
                                     Total
                                    Private
                                  Sector [b]
                                   State and
                                     Local
                                Government [c]
                                     Total
Number of facilities submitting initial Part A Permit Application
                                       1
                                       0
                                       1
                                       2
                                       0
                                       2
                                       2
                                       0
                                       2
Number of facilities submitting Part A Permit Modification
                                       8
                                       1
                                       9
                                      15
                                       0
                                      15
                                      12
                                       1
                                      13
   [a]  Based on data from the following RCRAInfo tables:  (1) "Hhandler" and (2) "Howner_operator."
   [b]  Includes facilities owned and/or operated by "private" or "other."  Note that, in order to qualify as "private," the facility cannot be owned or operated by a Federal, State, or local government.  For example, a facility owned by a State government and operated by a private entity would qualify as a "State and local government" facility, not as a "private" facility.
   [c]  Includes facilities owned and/or operated by a "County," "District," "Indian," "Municipal," or "State."  Note that, in order to qualify as "State and local government," the facility cannot be owned or operated by the Federal government.  For example, a facility owned by the Federal government and operated by a Municipal government would qualify as a "Federal government" facility, not a "State and local government" facility.

(2)	Annual Respondent Burden

      (a)	Hazardous Waste Report - Facilities (Exhibits 1A and 1B)

      (a1)	Read the Hazardous Waste Report Instructions

      EPA estimates that all 26,084 respondents will read the Hazardous Waste Report instructions.  Annualized over the two-year report cycle, this results in 13,042 respondents reading the instructions each year (i.e., 12,345 private sector facilities and 697 State and local government facilities).

      (a2)	Revise In-House or Commercial Data System

      EPA estimates that all 15,652 electronic reporters will revise their in-house or commercial data system to include new Hazardous Waste Report data items that are not part of the facility's general business operations.  Annualized over the two-year report cycle, this results in 7,826 respondents revising their in-house or commercial data systems each year (i.e., 7,604 private sector facilities and 222 State and local government facilities).

      (a3)	Gather Information and Complete Site Identification Form

      EPA estimates that all 26,084 respondents will complete and submit a Site ID Form with the Hazardous Waste Report.  Annualized over the two-year report cycle, this results in 13,042 respondents preparing and submitting a Site ID Form each year (i.e., 12,345 private sector facilities and 697 State and local government facilities).

      (a4)	Gather Information and Complete Form GM

      EPA estimates that respondents will submit a total of 289,760 Forms GM with the Hazardous Waste Report.  Annualized over the two-year report cycle, this results in 144,880 Forms GM each year (i.e., 139,284 forms from private sector facilities and 5,596 forms from State and local government facilities).

      (a5)	Gather Information and Complete Form WR

      EPA estimates that respondents will submit a total of 1,222,566 Forms WR with the Hazardous Waste Report.  Annualized over the two-year report cycle, this results in 611,283 Forms WR each year (i.e., 606,605 forms from private sector facilities and 4,678 forms from State and local government facilities).

      Note that the number of Forms WR represents the number of blocks on Form WR that have been completed; the paper form actually contains three blocks of the same WR information (i.e., the same questions, repeated three times on the same page).

      (a6)	Gather Information and Complete Form OI

      Because this form is a State-optional form, EPA does not expect any facilities to submit Form OI and therefore does not calculate the burden for this form.

      (a7)	Submit the Biennial Report to State/Region

      EPA expects each respondent, 13,042 facilities per year (i.e., 12,345 private sector facilities and 697 State and local government facilities), to submit the report to the appropriate State or Region.

      (a8)	Maintain a Copy of Each Form

      EPA expects facilities to retain an estimated 769,205 (i.e., 13,042 Site ID Forms + 144,880 Forms GM + 611,283 Forms WR) forms each year (i.e., 758,234 forms from private sector facilities and 10,971 forms from State and local government facilities).

      (b)	Hazardous Waste Report  -  State Agencies (Exhibit 1C)

      (b1)	Distribute Hazardous Waste Report Forms and Instructions

      EPA estimates that State agencies will distribute Hazardous Waste Report forms and instructions to 25,856 respondents.  Annualized over the two-year report cycle, this results in 12,928 respondents each year.

      (b2)	Assist Respondents

      EPA expects State agencies to provide assistance to all 25,856 respondents.  Annualized over the two-year report cycle, this results in 12,928 respondents each year.

      (b3)	Key Entry of Report Submissions

      EPA estimates that State agencies will need to key enter data for 26,318 Hazardous Waste Report forms (i.e., Site ID Form, Form GM, and Form WR) completed manually by the facilities.  Annualized over the two-year report cycle, this results in 13,159 respondents each year.

      (b4)	Perform Quality Assurance

      EPA expects State agencies to perform data quality assurance on all 1,534,856 Hazardous Waste Report forms (i.e., Site ID Form, Form GM, and Form WR) submitted by facilities.  Annualized over the two-year report cycle, this results in 767,428 respondents each year.

      (c)	Notification of Regulated Waste Activity - Facilities (Exhibits 2A and 2B)

      (c1)	Notification of Hazardous Secondary Material Activity under 40 CFR 260.42

      EPA estimates that, each year, 21 entities (i.e., 20 private sector facilities and 1 State and local government facility) will notify under 40 CFR 260.42 prior to operating under the exclusion and be required to complete the information laid out at section 260.42(a).

      In addition, entities must re-notify using the Site ID Form by March 1 of each even numbered year thereafter.  Note that the Hazardous Waste Report regulations already require the submittal of the Site ID Form by March 1 of each even numbered year by LQGs (40 CFR Part 262) and TSDFs (40 CFR Part 264 and 265).  Hence, this section of the ICR estimates burden for SQG and CESQG re-notifications only.  For purposes of this ICR, EPA estimates that, each year, a total of 9 SQGs and CESQGs will re-notify (i.e., 7 private sector facilities and 0 State and local government facilities).

      EPA estimates that, each year, 2 entities will re-notify because they stopped operating under the exclusion (i.e., 2 private sector facilities and 0 State and local government facilities).

      (c2)	Notification of Hazardous Waste Activity under RCRA Section 3010

      EPA estimates that, each year, 10,002 facilities (i.e., 9,055 private sector facilities and 947 State and local government facilities) will submit an initial notification of hazardous waste activity under RCRA Section 3010.  EPA also estimates that, each year, 40,223 facilities (i.e., 38,261 private sector facilities and 1,962 State and local government facilities) will submit a subsequent notification associated with these requirements.

      (c3)	Notification of Hazardous Waste Activity under 40 CFR Part 262, Subpart K

      Intent to Comply with Subpart K and Recordkeeping of Agreements

      An eligible academic entity must submit the Site ID Form to notify EPA or the authorized State that it is electing to be subject to Subpart K for all laboratories owned by the eligible academic entity under the same EPA Identification Number.  An eligible academic entity that is a CESQG and does not have an EPA Identification Number must notify for all laboratories that are owned or operated by the eligible academic entity that are on-site.  EPA estimates that, each year, 11 forms will be completed, submitted, and retained (i.e., 4 forms from private sector entities and 7 forms from State and local government entities).

      Teaching hospitals opting into Subpart K must keep a copy of their formal written affiliation agreement with a college or university on file if they are not owned by a college or university.   EPA estimates that, each year, 3 site will retain the agreement on file (i.e., 0 agreements from private sector entities and 3 agreement from State and local government entities).

      Non-profit research institutes not owned by a college or university opting into Subpart K must keep a copy of the formal written affiliation agreement with a college or university on file.  EPA estimates that, each year, 0 sites will retain the agreement on file (i.e., 0 agreements from private sector entities and 0 agreements from State and local government entities).

      Withdrawal from 40 CFR Part 262, Subpart K

      EPA estimates that, each year, 40 eligible academic entities will submit a notification of withdrawal from 40 CFR Part 262, Subpart K. (i.e., 39 notifications from private sector entities and 1 notification from State and local government entities).

      (c4)	Notification of Universal Waste Activity under 40 CFR Part 273, Subpart C

      EPA estimates that, each year, 67 facilities (i.e., 50 private sector facilities and 17 State and local government facilities) will submit an initial notification of universal waste activity under 40 CFR Part 273, Subpart C.  Of these facilities, 75 percent (i.e., 67 x 0.75 = 50) will use the Site ID Form and 25 percent (i.e., 67 x 0.25 = 17) will prepare and submit a letter requesting an EPA Identification Number.

      EPA also estimates that, each year, 97 facilities (i.e., 82 private sector facilities and 15 State and local government facilities) will submit a subsequent notification of universal waste activity under 40 CFR Part 273, Subpart C.  Of these facilities, 75 percent (i.e., 97 x 0.75 = 73) will use the Site ID Form and 25 percent (i.e., 97 x 0.25 = 24) will prepare and submit a letter requesting an EPA Identification Number.

      (c5)	Notification of Used Oil Activity under 40 CFR Part 279

      EPA estimates that, each year, 70 facilities (i.e., 67 private sector facilities and 3 State and local government facilities) will submit an initial notification of used oil activity under 40 CFR Part 279.  Of these facilities, 75 percent (i.e., 67 x 0.75 = 52) will use the Site ID Form and 25 percent (i.e., 67 x 0.25 = 18) will prepare and submit a letter requesting an EPA Identification Number.

      EPA also estimates that, each year, 283 facilities (i.e., 275 private sector facilities and 8 State and local government facilities) will submit a subsequent notification of universal waste activity under 40 CFR Part 273, Subpart C.  Of these facilities, 75 percent (i.e., 275 x 0.75 = 212) will use the Site ID Form and 25 percent (i.e., 275 x 0.25 = 71) will prepare and submit a letter requesting an EPA Identification Number.
      (d)	Notification of Regulated Waste Activity  -  State Agencies (Exhibit 2C)

	State agencies will conduct the information collection activities associated with the Notification of Regulated Waste Activity in Authorized States.

      (d1)	Notification of Hazardous Secondary Material Activity under 40 CFR 260.42

      EPA estimates that, each year, State agencies will review and enter notification information into RCRAInfo for 16 facilities that plan to operate under the exclusion at 40 CFR 260.42, 5 facilities that must re-notify by March 1 of each even numbered year, and 2 facilities that will re-notify because they stopped operating under the exclusion.

      (d2)	Notification of Hazardous Waste Activity under RCRA Section 3010

      EPA estimates that, each year, State agencies will review and enter notification information into RCRAInfo for 9,702 facilities that will submit an initial notification of hazardous waste activity under RCRA Section 3010 and for 39,016 facilities that will submit a subsequent notification associated with these requirements.

      (d3)	Notification of Hazardous Waste Activity under 40 CFR Part 262, Subpart K

      Intent to Comply with Subpart K and Recordkeeping of Agreements

      EPA estimates that, each year, State agencies will review and enter notification information into RCRAInfo for 11 eligible academic entities that elect to be subject to Subpart K for all laboratories owned by the eligible academic entity under the same EPA Identification Number.

      Withdrawal from 40 CFR Part 262, Subpart K

      EPA estimates that, each year, State agencies will review and enter notification information into RCRAInfo for 40 eligible academic entities that withdraw from the 40 CFR Part 262, Subpart K requirements.

      (d4)	Notification of Universal Waste Activity under 40 CFR Part 273, Subpart C

      EPA estimates that, each year, State agencies will review and enter initial notification information into RCRAInfo for 65 facilities.  Of these facilities, 49 will use the Site ID Form and 16 will prepare and submit a letter requesting an EPA Identification Number.

      EPA also estimates that, each year, State agencies will review and enter subsequent notification information into RCRAInfo for 94 facilities.  Of these facilities, 71 will use the Site ID Form and 23 will prepare and submit a letter requesting an EPA Identification Number.

      (d5)	Notification of Used Oil Activity under 40 CFR Part 279

      EPA estimates that, each year, State agencies will review and enter initial notification information into RCRAInfo for 67 facilities.  Of these facilities, 50 will use the Site ID Form and 17 will prepare and submit a letter requesting an EPA Identification Number.

      EPA also estimates that, each year, State agencies will review and enter subsequent notification information for 275 facilities.  Of these facilities, 206 will use the Site ID Form and 69 will prepare and submit a letter requesting an EPA Identification Number.
      (e)	Part A Hazardous Waste Permit Application and Modification - Facilities (Exhibits 3A and 3B)

      (e1)	Part A Permit Application

      EPA estimates that, each year, 2 facilities (i.e., 2 private sector facilities and 0 State and local government facility) will submit a new Part A Permit Application.  All facilities will need to obtain signatures for the Part A Permit Application, Part A Permit Application reports, and other information requested by the Director.  In addition, all facilities will need to obtain certifications from persons signing permit documentation.