40 CFR Part 270, Subpart C specifies conditions applicable to all permitted facilities. 40 CFR 270.30( h) requires owners and operators of permitted facilities to furnish any relevant information requested by EPA to determine whether cause exists for modifying, revoking and reissuing, or terminating a permit, or to determine compliance with the permit. Section 270.30( j)( 2) and ( 3) requires permittees to retain records of all monitoring information, copies of all reports required by the permit, the certification required by § 264.73( b)( 9), and records of all data used to complete the application for a period of at least three years from the date of the sample, measurement, report, certification, or application. [ These requirements are burdened in the section entitled " Operating Record" of this ICR.] In addition, section 270.30( l) specifies the following reporting requirements, which are applicable to all permitted facilities:

C Prompt notice of planned physical alternations or additions ( § 270.30( l)( 1));

C Notice of planned changes or activities which may result in noncompliance with permit requirements ( § 270.30( l)( 2));

C Letter certifying that the facility has been constructed or modified in compliance with the permit ( § 270.30( l)( 2)( i);

C Monitoring reports, submitted at the intervals specified in the permit ( § 270.30( l)( 4));

C Reports of compliance or noncompliance with, or any progress reports on, interim and final requirements contained in any compliance schedule of the permit, submitted no later than 14 days following each schedule date ( § 270.30( l)( 5));

C A report containing information concerning a release that may threaten drinking water supplies ( § 270.30( l)( 6)( i)( A), or information concerning a release, fire, or explosion which could threaten human health or the environment outside the facility ( § 270.30( l)( 6)( i)( B)), within 24 hours from the time the permittee becomes aware of the circumstances. Such a report must include the following information:

 Name, address, and telephone number of the owner or operator;

 Name, address, and telephone number of the facility;

 Date, time, and type of incident;

 Name and quantity of material( s) involved; 55  The extent of injuries, if any;

 An assessment of actual or potential hazards to the environment and human health outside the facility; and  Estimated quantity and disposition of recovered material that resulted from the incident.

C A written notice within five days of noncompliance, or a written report within 15 days, that includes a description of the noncompliance and its cause, the period of noncompliance, the anticipated time the noncompliance is expected to continue, and steps taken to reduce, eliminate, and prevent reoccurrence of the noncompliance ( § 270.30( l)( 6)( iii);

C Report of any manifest discrepancy, as required by § 264.72 ( § 270.30( l)( 7). [ This requirement is burdened in " Requirements for Generators, Transporters, and Waste Management Facilities Under the RCRA Hazardous Waste Manifest System", ICR # 801.];

C Report of any receipt of unmanifested waste, as required by § 264.76 ( § 270.30( l)( 8)). [ This requirement is burdened in " Requirements for Generators, Transporters, and Waste Management Facilities Under the RCRA Hazardous Waste Manifest System", ICR # 801.];

C A biennial report covering facility activities, as required by § 264.75 ( § 270.30( l)( 9)). [ This requirement is burdened in the " Hazardous Waste Report ICR", ICR # 976.]

C Report of other noncompliance not submitted with monitoring reports, compliance schedule reports, and reports of releases, fires, or explosions ( § 270.30( l)( 10)); and C For cases where the permittee becomes aware that he or she failed to submit any relevant facts in a permit application, or submitted incorrect information in any permit application or report, corrected or new information ( § 270.30( l)( 11)).

( ii) Respondent activities:

In order to comply with 40 CFR Part 270, Subpart C, owners and operators of permitted facilities must perform the following activities:

C Read the regulations; and C Prepare and submit the required information as described above. 56 5. THE INFORMATION COLLECTED AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT The following subsections discuss how EPA will collect the information, what activities EPA will perform once the information has been received, and how EPA will manage the information it collects. The subsections also include a discussion of how the information collection requirements affect small entities.

5( a) AGENCY ACTIVITIES GENERAL FACILITY OPERATING STANDARDS Although the information is not formally submitted to EPA, EPA may review information collected from the requirements outlined in Subpart E during facility inspections. Therefore, this analysis assumes that the Agency will spend a minimal amount of review time annually at each facility.

The requirements for the foreign shipment import report, however, state that owners or operators must notify the Regional Administrator of the anticipated collection of hazardous waste. In turn, the Agency must review the information included in the notification.

RECORDKEEPING REQUIREMENTS Only one Agency activity is associated with the operating record requirements: on site review of the record.

CONTINGENCY PLAN AND EMERGENCY REPORTING REQUIREMENTS ( 1) Contingency Plan Two Agency activities are associated with the development and amendment of the contingency plan: reviewing the contingency plan during on site inspections and reviewing revisions to the contingency plan. ( 2) Emergency Reporting Requirements Agency activities associated with emergency reporting requirements include reviewing documents in the owners' or operators' and emergency coordinators' emergency reports.

RELEASES FROM SOLID WASTE MANAGEMENT UNITS There are two Agency activities associated with ground water monitoring demonstrations and procedures: reviewing demonstrations to terminate the compliance period and review and approval of proposed sampling methods and intervals.

CLOSURE AND POST CLOSURE REQUIREMENTS Agency activities associated with the regulations promulgated in 40 CFR, Parts 264 and 265, Subpart G, include reviewing the following data items: 57 C Closure plans;

C Closure plan amendment notifications;

C Partial/ final closure notifications;

C Closure extensions and allowances;

C Survey plats;

C Post closure plans;

C Post closure plan amendment notifications;

C Post closure plan modifications;

C Hazardous waste disposal records; and C Post closure permit modifications.

FINANCIAL REQUIREMENTS EPA uses the cost estimates and financial assurance mechanisms to ensure compliance with Subpart H. In the event that an owner or operator is unable or unwilling to perform closure or post closure activities or to pay third party damages, EPA will draw upon the mechanisms. The cost estimates are normally retained by the owner or operator during interim status; they are submitted to the Region or authorized State as part of the permit process.

The financial assurance instruments for closure, post closure care, and liability coverage, with standard wording, are submitted by the owner or operator ( or the third party financial entity) to the Region or authorized State that serves the area and where the facility is located. These submissions must be made by the effective date of the regulations for existing facilities  July 6, 1982 ( Assurance) and July 15, 1982 ( Liability)  and sixty days before the initial receipt of hazardous wastes at new facilities. There was a phase in period for nonsudden coverage for existing facilities. January 16, 1985 was the final phase in date.

When financial assurance information is submitted, EPA conducts a review for completeness, then enters the information into the RCRIS data base. The EPA Regional or State offices establish a file for each applicant that contains the submissions. The financial instruments are maintained in a secure area.

Submissions are tabulated in the EPA Regional Offices and Headquarters and are used by Agency management to oversee implementation of the RCRA financial responsibility requirements. The information is also shared with States to assist them in implementing their hazardous waste management programs. There are no plans to publish information obtained under the Subpart H financial requirements.

CONDITIONS APPLICABLE TO ALL PERMITS 58 EPA reviews all information submitted at intervals specified in the permit. This information includes monitoring reports and reports on compliance or noncompliance with compliance schedules. EPA also reviews information that may be submitted on occasion by facilities, if necessary. Such information includes notices of planned physical alterations or additions; notices of planned changes or activities; letters certifying compliance; information concerning releases, fires, or explosions; reports of other noncompliance; and corrected or new information.

5( b) COLLECTION METHODOLOGY AND MANAGEMENT To collect and analyze the information discussed in this ICR., EPA keeps records of and reviews all of the information submitted. Authorized States and EPA Regions enter the information into electronic data base systems. States coordinate with the EPA Regions and OSW Headquarters to supply EPA with the data reported for inclusion in the RCRAInfo national database.

5( c) SMALL ENTITY FLEXIBILITY When promulgating the regulations covered under this ICR, EPA considered developing separate and simplified requirements for small businesses. Since small facilities conduct operations that are equally as hazardous to the environment as those conducted by larger facilities, EPA determined that small businesses should be required to comply with the same regulations as large businesses. As a result of this interpretation, no specific requirements are outlined for smaller facilities.

5( d) COLLECTION SCHEDULE GENERAL FACILITY STANDARDS The reporting requirements outlined in the regulations will vary according to individual facility circumstances ( e. g., when receiving hazardous waste from a foreign source).

RECORDKEEPING REQUIREMENTS Since the operating record is maintained at the facility, discussion of a collection schedule is not applicable. Copies of records of waste disposal are submitted to EPA upon closure of the facility.

CONTINGENCY PLAN AND EMERGENCY REPORTING REQUIREMENTS The contingency plan is collected when the permittee submits the Part B permit application. A discussion of the contingency plan collection schedule for permitted facilities is included in the Hazardous Waste Part B Permit Applications, Special Permits, and Permit Modifications ICR (# 1573). Since interim status facilities are not required to submit their contingency plans to EPA, discussion of a collection schedule for these facilities is not applicable.

The owner or operator must submit a written report of any incident that requires implementation of the contingency plan within 15 days after the incident occurs. The emergency coordinator must immediately notify the appropriate authorities of an imminent or actual emergency situation.

CLOSURE AND POST CLOSURE REQUIREMENTS 59 Permitted facilities submit their closure and post closure plans to EPA when submitting a Part B permit application. A discussion addressing collection schedules for permitted facilities is included in the Hazardous Waste Part B Permit Applications, Special Permits, and Permit Modifications ICR (# 1573).

Interim status closure and post closure plans must be submitted according to the following schedules:

C The owner or operator must submit the closure plan to the Regional Administrator at least 180 days prior to the date on which he or she expects to begin closure of the first surface impoundment, waste pile, land treatment, or landfill unit, or final closure if it involves such a unit, whichever is earlier;

C The owner or operator must submit the closure plan to the Regional Administrator at least 45 days prior to the date on which he or she expects to begin final closure of a facility with only tanks, container storage, or incinerator units;

C Owners or operators with approved closure plans must notify the Regional Administrator in writing at least 60 days prior to the date on which they expect to begin closure of a surface impoundment, waste pile, landfill, or land treatment unit, or final closure of a facility involving such a unit;

C Owners and operators with approved closure plans must notify the Regional Administrator in writing at least 45 days prior to the date on which they expect to begin final closure of a facility with only tanks, container storage, or incinerator units;

C The owner or operator must submit the closure plan to the Regional Administrator no later than 15 days after:

 Termination of interim status except when a permit is issued simultaneously with termination of interim status; or  Issuance of a judicial decree or final order under § 3008 of RCRA to cease receiving hazardous wastes or close C If the Regional Administrator does not approve the closure plan, he or she shall provide the owner or operator with a detailed written statement of reasons for the refusal and the owner or operator must modify the plan or submit a new plan for approval within 30 days after receiving such written statement;

C An owner or operator of a surface impoundment or waste pile that intends to remove all hazardous waste at closure must prepare a post closure plan and submit it to the Regional Administrator within 90 days of the date that the owner or operator or Regional Administrator determines that the hazardous waste management unit or facility must be closed as a landfill, subject to the requirements of § § 265.117 through 265.120;

C If an owner or operator of a surface impoundment or a waste pile who intended to remove all hazardous wastes at closure in accordance with § 265.228( b) or § 265.258( a) is required to close as a landfill in accordance with § 265.310, the owner or operator must submit a 60 post closure plan within 90 days of the determination by the owner or operator or Regional Administrator that the unit must be closed;

C If the Regional Administrator determines that an owner or operator of a surface impoundment or waste pile who intended to remove all hazardous wastes at closure must close the facility as a landfill, the owner or operator must submit a post closure plan for approval to the Regional Administrator within 90 days of the determination;

C The owner or operator must submit the post closure plan to the Regional Administrator at least 180 days before the date he or she expects to begin partial or final closure of the first hazardous waste disposal unit. The date he " expects to begin closure" of the first hazardous waste disposal unit must be either within 30 days after the date on which the hazardous waste management unit receives the known final volume of hazardous waste or, if there is a reasonable possibility that the hazardous waste management unit will receive additional hazardous wastes, no later than one year after the date on which the unit received the most recent volume of hazardous wastes; and C The owner or operator must submit his post closure plan to the Regional Administrator no later than 15 days after:

 Termination of interim status except when a permit is issued simultaneously with termination of interim status; or  Issuance of a judicial decree or final order under § 3008 of RCRA to cease receiving hazardous wastes or close.

Both interim status and permitted facilities are required to request approval for post closure plan modifications. Since permitted facilities must submit permit modifications to authorize changes to their post closure plans, a discussion addressing scheduling requirements for permitted facilities' modifications to the post closure plan is included in ICR # 1573. The following is a schedule for interim status facilities:

C An owner or operator with an approved post closure plan must submit the modified plan to the Regional Administrator at least 60 days prior to the proposed change in facility design or operation, or no more than 60 days after an unexpected event has occurred which has affected the post closure plan; and C If the Regional Administrator requests modifications to the post closure plan, the owner or operator with an approved post closure plan must submit the modified plan to the Regional Administrator no later than 60 days of the request from the Regional Administrator.

Both interim status and permitted facilities are required to submit closure certifications, survey plats, and post closure notices according to the following schedules:

C The owner or operator must submit a certification of closure to the Regional Administrator within 60 days of completion of closure for each hazardous waste surface impoundment, waste pile, land treatment, and landfill unit and within 60 days of final closure; 61 C No later than the submission of the certification of closure, the owner or operator must submit to the Regional Administrator a survey plat;

C If the Regional Administrator does not approve the post closure plan, he shall provide the owner or operator with a detailed written statement of reasons for the refusal and the owner or operator must modify the plan or submit a new plan for approval within 30 days after receiving such written statement;

C The owner or operator must submit a post closure notice to the Regional Administrator within 60 days of certification of closure for each hazardous waste disposal unit;

C No later than 60 days after certification of closure of each hazardous waste disposal unit, the owner or operator must submit to the Regional Administrator a record of the type, location, and quantity of hazardous wastes disposed of within each cell or other disposal unit of the facility; and C No later than 60 days after the completion of the established post closure care period for each hazardous waste disposal unit, the owner or operator must submit to the Regional Administrator a certification that the post closure care period for the unit was performed in accordance with the specifications in the approved post closure plan.

FINANCIAL REQUIREMENTS For closure and post closure cost estimates, owners or operators must prepare initial cost estimates for activities identified in the closure and post closure plans. Thereafter, owners or operators must provide annual adjustments of these cost estimates to account for inflation. Also, owners or operators may be required to prepare new cost estimates, if changes in the closure or post closure plan increase closure or post closure costs. This burden will vary from facility to facility.

For closure and post closure care financial instruments, owners or operators must initially establish a financial instrument( s) assuring the cost of closure and post closure care. Thereafter, owners or operators must annually check the amount covered by the instrument( s) to make sure it equals the adjusted cost estimate, and change the amount assured accordingly.

For liability coverage requirements, owners or operators of facilities identified in § § 264.147 and 265.147 must initially demonstrate liability coverage for sudden and nonsudden accidents during the facilities' active life. Some of the financial instruments for liability coverage require additional reporting on an annual basis; for example, owners or operators must annually submit documentation to EPA supporting the use of the financial test or guarantee. Furthermore, owners or operators may also have to provide information due to varying circumstances; for example, whenever a claim for bodily injury or property damages caused by a hazardous waste treatment, storage, or disposal facility is made.

CONDITIONS APPLICABLE TO ALL PERMITS EPA collects information from permitted facilities at intervals specified in the permit. EPA may also collect other information if the Agency determines that it needs information to determine whether a permit should be terminated, revoked and reissued, or modified. EPA may collect additional information from permitted facilities if noncompliance with permit conditions occurs. 62 6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION 6( a) ESTIMATING RESPONDENT BURDEN EPA estimated respondent burden hours associated with all of the requirements covered in this ICR in Exhibits 1 through 8. The exhibits address the following requirements:

C Exhibit 1  General facility standards;

C Exhibit 2  Operating record requirements;

C Exhibit 3  Contingency plan and emergency procedure requirements;

C Exhibit 4  Requirements for releases from solid waste management units;

C Exhibit 5  Closure and post closure requirements;

C Exhibit 6  Financial requirements;

C Exhibit 7  Conditions applicable to all permits; and C Exhibit 8  Total respondent burden and costs.

Exhibits 1 through 7 present the number of hours required to conduct each individual information collection activity and the cost associated with that activity. Exhibit 8 presents annual respondent bottom line burden hours and costs for all information collection requirements in this ICR.

6( b) ESTIMATING RESPONDENT COSTS LABOR COSTS EPA estimates an average hourly respondent labor cost ( including overhead) of $ 116 for legal staff, $ 84.00 for managerial staff, $ 64.00 for technical staff, and $ 36.00 for clerical staff. To arrive at these estimates, EPA consulted the May 2004 Occupational Employment Statistics ( OES) Survey from the Bureau of Labor Statistics, Department of Labor; this survey summarizes the unloaded factor of 2.3 for non legal staff and 3.0 for legal staff to derive their loaded hourly rates. Using the burden hours discussed in Section 6( a) and the wage rates outlined in this section, Exhibit 1 illustrates the labor costs associated with all the information collection requirements covered in this ICR.

CAPITAL COSTS EPA estimates that all new facilities and facilities with new Part B permits will incur capital costs associated with purchasing file storage systems for maintaining records. EPA realizes that facilities will likely use different and various file storage systems ( e. g., file cabinets, CD ROM, off site storage, etc) and store their files on different media ( paper, microfiche, electronic files, etc). For purposes of estimating these capital costs across all facilities, EPA has made the conservative assumption that every facility will store their files in paper form in file cabinets. 63 In addition, EPA estimates that during the facilities' operating and post closure periods each facility will store an average 48,000 pieces of paper. Therefore, the average facility will need to purchase three 5 drawer lateral file cabinets that each hold 16,000 pieces of paper. As the current market price for such a file cabinet is $ 549, each facility would therefore purchase $ 1,647 worth of file cabinets.

To annualize this capital cost of $ 1,647, EPA assumed a discount rate of 7 percent and a discount period of 15 years ( based on the average life of file cabinets). As such, the present value factor for this discount rate and period would be 9.1079. Thus, EPA estimates the annualized net present value of this capital cost as $ 180.83 per facility.

As most of the recordkeeping in this ICR is associated with paperwork activities listed in Exhibit 2, EPA added an activity for purchasing file storage systems at the end of this exhibit. Even though there are additional recordkeeping activities in Exhibit 1, EPA accounts for all file maintenance capital costs in this one exhibit and line item. As such, EPA multiplied this annualized capital cost over all new facilities for a total annualized capital cost of $ 12,658.

OPERATION AND MAINTENANCE COSTS EPA also estimates that facilities will incur operations and maintenance ( O& M) costs such as postage costs for submitting information to EPA, purchased material costs, and various lump sum purchased service costs. These O& M costs are expected to be incurred on an ongoing, annual, or periodic basis per the associated regulatory requirement and assumptions in this ICR.

As shown in all exhibits, postage costs are estimated at $ 0.37 per one ounce letter, $ 4.14 per submittal for all other submittals weighing up to two pounds and sent by priority mail, and $ 9.75 per submittal that must be sent by registered, priority mail. In Exhibit 1, EPA estimates purchased material costs/ and or lump sum purchased service costs for waste analysis, specifically $ 750 per analysis for noncommercial facilities and $ 400 per analysis for commercial facilities. In Exhibit 5, EPA estimates lumpsum purchased service costs for certain inspections and/ or certifications that must be completed by independent professionals, specifically $ 1,000 per inspection/ certification by an independent registered professional engineer and $ 750 per survey/ certification by a professional land surveyor.

6( c) ESTIMATING AGENCY BURDEN AND COST EPA estimates annual Agency burden hours and costs associated with all the requirements covered in this ICR in Exhibit 9. Based on a 2005 GS pay schedule, EPA estimates an average hourly Regional labor cost of $ 87.01 for legal staff, $ 76.77 for managerial staff, $ 55.23 for technical staff, and $ 23.55 for clerical staff. The labor costs were based on the following GS levels and steps: legal labor rates were based on GS Level 15, Step 5, managerial labor rates were based on GS Level 15, Step 1, technical labor rates were based on GS Level 13, Step 1, and clerical labor rates were based on GS Level 6, Step 1. EPA multiplied hourly rates by the standard government overhead factor of 1.6. As shown in Exhibit 10, EPA estimates that the annual Agency burden for all activities covered in this ICR is approximately 52,420 hours, at an annual cost of $ 2,069,585. 64 6( d) RESPONDENT UNIVERSE AND TOTAL RESPONDENT BURDEN AND COST RESPONDENT UNIVERSE Table 1 presents the estimated universe of facilities that are affected by the General Facility Standard requirements. 65 TABLE 1 Estimated Universe of Facilities Affected by General Facility Standard Requirements Permitted Interim Status Total All Facilities ( Operating & Closed/ Post Closed) 1,333 198 1,531 Operating Facilities 864 58 922 Commercial 284 9 293 Non Commercial 580 49 629 Closed Facilities ( New Annual Closures) 49 20 69 Post Closed Facilities 573 124 697 Land Disposal Facilities ( Op. & Cl/ P Cl) 654 115 769 Operating LDFs 87 7 20 Closed LDFs ( New Annual Closures) 15 5 25 Post Closed LDFs 552 103 655 Closed or Post Closed LDFs 567 108 675 Facilities with Incinerators 81 4 85 Treatment and Storage Only Facilities 676 73 749 New Interim Status NA 0 NA New Part B Permits ( Incl. New Construction) 13 NA NA Facilities Who Intend to Close Annually 19 9 28 LDFs Who Intend to Close Annually 2 7 9 Facilities Who Intend to Post Close Annually 22 11 33 LDFs Who Intend to Post Close Annually 3 2 5 Facilities Completing Post Closure Annually 0 0 0 GENERAL FACILITY OPERATING REQUIREMENTS ( 1) Foreign Shipment Import Report Based on previous experience, EPA estimates that approximately six percent of the operating respondent universe ( 52 permitted and 4 interim status facilities) will submit foreign shipment import reports annually.

( 2) Notice of Appropriate Permits EPA estimates that approximately 12 percent of operating TSDFs accept off site waste. EPA estimates that each of these facilities ( 104 permitted facilities) will accept waste from an average of 55 new generators each year during the period covered by this ICR. These commercial facilities must submit a onetime notice to these generators before accepting their waste.

( 3) Notice of Part 264 or Part 265, and Part 270 Requirements 66 1 " All facilities" includes facilities that are operating and those that have closed or post closed. The sum of operating, closed, and post closed facilities taken individually is greater than the number of " all facilities" because some facilities can have both operating and closed or post closed units. EPA estimates that approximately one percent of all facilities 1 ( 13 permitted and 2 interim status facilities) will experience a transfer in ownership each year. The owners and operators of these facilities will be required to submit a notice of Part 264 or 265 and Part 270 requirements to the new owner or operator of the facility.

( 4) Waste Analysis Only operating facilities are required to conduct waste analysis testing. EPA believes that the commercial incinerator and land disposal sites have the greatest responsibility for waste analysis. Based on previous experience, EPA estimates that the 293 commercial incinerator and land disposal facilities ( 284 permitted and 9 interim status facilities) will conduct testing 50 times a year, while all remaining operating facilities ( 580 permitted and 49 interim status facilities) will conduct this analysis twice a year.

( 5) Waste Analysis Plan This ICR assumes that existing interim status and permitted facilities have already developed a waste analysis plan. Therefore, only new interim and permitted facilities will develop waste analysis plans. EPA estimates that no new interim facilities will be entering the universe whereas the 13 newly permitted facilities will have to prepare a waste analysis plan. In addition to preparing a waste analysis plan, these 13 facilities must also maintain ( i. e., photocopy and file) the plan at the facility.

EPA also assumes that 20 percent of all operating facilities ( 173 permitted and 12 interim status facilities) will modify the plan and maintain the modified plan each year.

( 6) Inspection Schedule This ICR assumes that existing interim status and permitted facilities have already developed an inspection schedule. Therefore, only new permitted and interim status facilities will develop inspection schedules. EPA estimates that no new interim and 13 new permitted facilities will enter the universe during the period covered by this ICR.

In addition to preparing an inspection schedule, the 13 new permitted facilities must also maintain ( i. e., photocopy, file, and update) the schedule at the facility. EPA estimates that five percent of all operating facilities and facilities undergoing closure or post closure will modify their inspection schedules annually and maintain the modified inspection schedule, for a total of 65 permitted and 10 interim status facilities. All operating facilities are required to record problems in an inspection log. 67 ( 7) Personnel Training This ICR assumes that existing interim status and permitted facilities have already collected the information necessary to prepare a personnel training record. Therefore, only new interim status facilities and newly constructed permitted facilities will be required to collect information regarding their employees' training experiences. EPA estimates that no new interim status facilities will join the universe during the period covered by this ICR. Thirteen newly constructed facilities with Part B permits will have to read the regulations and collect information.

All operating and newly constructed facilities ( 864 permitted and 58 interim status facilities) must also maintain ( i. e., photocopy, file, and update) their training records.

( 8) Documentation of Compliance for Ignitable, Reactive, or Incompatible Wastes Based on previous experience, EPA estimates that 40 percent of the permitted operating universe ( 346facilities) will have to maintain documentation of compliance for ignitable, reactive, or incompatible wastes.

( 9) Construction Quality Assurance Plan This ICR assumes that existing permitted and interim status facilities have submitted their construction quality assurance plan to EPA. Therefore, only new interim status facilities will be required to submit the CQA plan. EPA estimates that no new facilities will obtain interim status during the period covered by this ICR. 68 EXHIBIT 1 ANNUAL ESTIMATED RESPONDENT BURDEN AND COST GENERAL FACILITY OPERATING STANDARDS Number of Respondents Hours and Costs per Respondent or Activity Total Hours and Costs Legal Manager Technical Clerical Labor Capital/ Total Total Interim $ 116.00/ $ 84.00/ $ 64.00/ $ 36.00/ Cost Startup O& M Hours per Cost per INFORMATION COLLECTION ACTIVITY Permitted Status hour hour hour hour $/ Year Cost Cost Year Year Foreign Shipment Import Report ( 264.12( a) and 265.12( a))

Read the regulations 52 3 0.00 0.25 0.75 0.00 $ 69.00 $ 0.00 $ 0.00 55.32 $ 3,817.08 Collect Data 52 3 0.00 0.00 0.75 0.25 $ 57.00 $ 0.00 $ 0.00 55.32 $ 3,153.24 Prepare and submit notification 52 3 0.00 0.25 0.50 0.25 $ 62.00 $ 0.00 $ 0.33 55.32 $ 3,448.10 Subtotal 52 3 0.00 0.50 2.00 0.50 $ 188.00 $ 0.00 $ 0.33 165.96 $ 10,418.42 Notice of appropriate permit( s) ( 264.12( b)

Read the regulations 104 N/ A 0.00 0.10 0.25 0.00 $ 24.40 $ 0.00 $ 0.00 36.29 $ 2,529.79 Prepare, keep records of, and submit notice ( 55 annually) 104 N/ A 0.00 0.13 0.25 0.13 $ 31.00 $ 0.00 $ 0.33 2,851.20 $ 178,656.19 Subtotal 104 N/ A 0.00 0.23 0.50 0.13 $ 55.40 $ 0.00 $ 0.33 2,887.49 $ 181,185.98 Notice of Part 264 or 265 and Part 270 requirements ( 264.12( c) and 265.12( b))

Read the regulations 13 2 0.00 0.10 0.25 0.00 $ 24.40 $ 0.00 $ 0.00 5.36 $ 373.56 Prepare and submit notice 13 2 0.00 0.00 0.50 0.13 $ 36.68 $ 0.00 $ 0.33 9.65 $ 566.62 Subtotal 13 2 0.00 0.10 0.75 0.13 $ 61.08 $ 0.00 $ 0.33 15.00 $ 940.19 Waste Analysis ( 264.13( a)( 1) and 265.13( a)( 1))

Non commercial facilities Read the regulations 580 49 0.00 0.25 0.75 0.00 $ 69.00 $ 0.00 $ 0.00 629.00 $ 43,401.00 Collect data ( twice annually) 580 49 0.00 0.00 3.00 0.50 $ 210.00 $ 0.00 $ 0.00 4,403.00 $ 264,180.00 Perform waste analysis ( twice annually) 580 49 0.00 0.00 10.00 0.00 $ 640.00 $ 0.00 $ 750.00 12,580.00 $ 1,748,620.00 Commercial facilities Read the regulations 284 9 0.00 0.25 0.75 0.00 $ 69.00 $ 0.00 $ 0.00 293.00 $ 20,217.00 Collect data ( 50 times annually) 284 9 0.00 0.00 1.50 0.25 $ 105.00 $ 0.00 $ 0.00 25,637.50 $ 1,538,250.00 Perform waste analysis ( 50 times annually) 284 9 0.00 0.00 20.00 0.00 $ 1,280.00 $ 0.00 $ 400.00 293,000.00 $ 24,612,000.00 Subtotal varies varies varies varies varies varies varies varies varies 336,542.50 $ 28,226,668.00 Waste Analysis Plan ( 264.13( b) and 265.13( b))

Read the regulations N/ A 0 0.00 0.25 0.75 0.00 $ 69.00 $ 0.00 $ 0.00 0.00 $ 0.00 Collect data N/ A 0 0.00 0.00 10.00 0.00 $ 640.00 $ 0.00 $ 0.00 0.00 $ 0.00 Write the waste analysis plan N/ A 0 0.00 10.00 60.00 0.50 $ 4,698.00 $ 0.00 $ 0.00 0.00 $ 0.00 Maintain the waste analysis plan 13 0 0.00 0.00 0.00 1.00 $ 36.00 $ 0.00 $ 0.00 13.00 $ 468.00 Modify the waste analysis plan 173 12 0.00 10.00 80.00 0.50 $ 5,978.00 $ 0.00 $ 0.00 16,688.20 $ 1,102,343.20 Maintain the modified waste analysis plan 173 12 0.00 0.00 0.00 1.00 $ 36.00 $ 0.00 $ 0.00 184.40 $ 6,638.40 Subtotal varies varies varies varies varies varies varies varies varies 16,885.60 $ 1,109,449.60 Inspection Schedule ( 264.15( b)( 1) and 265.15( b)( 1))

Read the regulations N/ A 0 0.00 0.25 0.75 0.00 $ 69.00 $ 0.00 $ 0.00 0.00 $ 0.00 Develop an inspection schedule N/ A 0 0.00 8.00 80.00 1.00 $ 5,828.00 $ 0.00 $ 0.00 0.00 $ 0.00 Maintain the inspection schedule 13 0 0.00 0.00 0.00 1.00 $ 36.00 $ 0.00 $ 0.00 13.00 $ 468.00 Modify the inspection schedule 719 91 0.00 0.00 8.00 0.00 $ 512.00 $ 0.00 $ 0.00 6,476.00 $ 414,464.00 Maintain the modified inspection schedule 719 91 0.00 0.00 0.00 1.00 $ 36.00 $ 0.00 $ 0.00 809.50 $ 29,142.00 Record problems in the inspection log 864 58 0.00 0.00 100.00 0.00 $ 6,400.00 $ 0.00 $ 0.00 92,200.00 $ 5,900,800.00 Subtotal varies varies varies varies varies varies varies varies varies 99,498.50 $ 6,344,874.00 69 EXHIBIT 1 ( continued)

ANNUAL ESTIMATED RESPONDENT BURDEN AND COST GENERAL FACILITY OPERATING STANDARDS Number of Respondents Hours and Costs per Respondent or Activity Total Hours and Costs Legal Manager Technical Clerical Labor Capital/ Total Total Interim $ 116.00/ $ 84.00/ $ 64.00/ $ 36.00/ Cost Startup O& M Hours per Cost per INFORMATION COLLECTION ACTIVITY Permitted Status hour hour hour hour $/ Year Cost Cost Year Year Personnel Training ( 264.16( d) and 265.16( d))

Read the regulations 8 0 0.00 0.25 0.75 0.00 $ 69.00 $ 0.00 $ 0.00 8.00 $ 552.00 Collect data 8 0 0.00 0.50 2.00 0.50 $ 188.00 $ 0.00 $ 0.00 24.00 $ 1,504.00 Maintain training records ( new facilities) 8 0 0.00 0.00 0.00 80.00 $ 2,880.00 $ 0.00 $ 0.00 640.00 $ 23,040.00 Maintain training records ( existing facilities) 864 58 0.00 0.00 0.00 4.00 $ 144.00 $ 0.00 $ 0.00 3,688.00 $ 132,768.00 Subtotal varies varies varies varies varies varies varies varies varies 4,360.00 $ 157,864.00 Documentation of Compliance for Ignitable, Reactive, or Incompatible Wastes ( 264.17)

Read the regulations 346 N/ A 0.00 0.25 0.75 0.00 $ 69.00 $ 0.00 $ 0.00 345.60 $ 23,846.40 Collect and document data 346 N/ A 0.00 1.00 40.00 1.00 $ 2,680.00 $ 0.00 $ 0.00 14,515.20 $ 926,208.00 Maintain documentation at the facility 346 N/ A 0.00 0.00 0.00 1.00 $ 36.00 $ 0.00 $ 0.00 345.60 $ 12,441.60 Subtotal 346 N/ A 0.00 1.25 40.75 2.00 $ 2,785.00 $ 0.00 $ 0.00 15,206.40 $ 962,496.00 Construction Quality Assurance Plan ( 265.19)

Read the regulations N/ A 0 0.00 0.00 1.00 0.00 $ 64.00 $ 0.00 $ 0.00 0.00 $ 0.00 Complete the data items of 265.19( b), and,

if applicable, an alternative demonstration N/ A 0 0.00 0.00 15.00 5.00 1140 $ 0.00 $ 0.00 0.00 $ 0.00 Obtain a certification from CQA officer N/ A 0 0.00 0.00 1.00 0.00 $ 64.00 $ 0.00 $ 0.00 0.00 $ 0.00 Submit materials to EPA N/ A 0 0.00 0.00 0.00 0.50 $ 18.00 $ 0.00 $ 3.20 0.00 $ 0.00 Maintain records of materials N/ A 0 0.00 0.00 0.00 1.00 $ 36.00 $ 0.00 $ 0.00 0.00 $ 0.00 Subtotal N/ A 0 0.00 0.00 17.00 6.50 $ 1,322.00 $ 0.00 $ 3.20 0.00 $ 0.00 TOTAL varies varies varies varies varies varies varies varies varies 475,561.45 $ 36,993,896.19 70 RECORDKEEPING REQUIREMENTS ( 1) Operating Record Excluding the inspection information requirement, only operating facilities are required to comply with the operating record recordkeeping requirements. EPA estimates that 864 permitted and 58 interim status facilities must maintain operating records. There are sixteen information components of the operating record requirements contained in 40 CFR § § 264.73( b)( 1)( 16) and 265.73( b)( 1)( 16). Some of the requirements apply only to certain types of facilities:

C Facilities must document any refusal of State and local agencies to enter into arrangements to address emergency situations ( § 264.37( b)). EPA estimates that only one percent of all operating facilities ( 9 permitted and 1 interim status facilities) will be required to comply with this regulation.

C Facilities that have emergency incidents requiring implementation of the contingency plan must maintain ( i. e., photocopy and file) written documentation of the incident ( § § 264.73( b)( 4) and 265.73( b)( 4)). EPA estimates that only one percent of all operating facilities ( 9 permitted and 1 interim status facilities) will be required to comply with this regulation.

C Both operating and post closure facilities ( 1,333 permitted and 198 interim status facilities) are required to maintain updated inspection information in the operating record ( 264.73( b)( 5) and 265.73( b)( 5)).

C Only land disposal facilities and incinerator facilities are required to collect and record monitoring data ( § § 264.73( b)( 6)) in the operating record. EPA estimates that, during the three year period covered by this ICR, the number of land disposal facilities and incinerators subject to this requirement will average 168 permitted and 11 interim status facilities per year.

C Only facilities that receive hazardous waste from an off site source ( except where the owner or operator is also the generator) are required to maintain ( i. e., photocopy and file) notices for generators verifying that they have a permit to handle the hazardous waste they are receiving ( § § 264.73( b)( 7) and 265.73( b)( 7)). Thus, EPA has determined that 12 percent of the operating universe ( 104 permitted and 7 interim status facilities), including noncommercial facilities, will need to maintain, in the operating record, the notice to generators.

C All facilities must maintain updated information in the operating record closure cost estimates. However, only land disposal facilities must maintain post closure cost estimates ( § § 264.73( b)( 8) and 265.73( b)( 8)). EPA estimates that all 1,333 permitted and 198 interim status facilities will have to maintain closure cost estimates and 87 permitted and 7 interim status operating land disposal facilities will need to maintain post closure cost estimates.

C All operating land disposal facilities ( 87 permitted and 7 interim status facilities) must also maintain records of the quantities ( and date of placement) for each shipment of hazardous waste placed in land disposal units under an extension to the effective date of any land 71 disposal restriction, or a certification, and the applicable notice required by the generator ( § § 264.73( b)( 10) and 265.73( b)( 10)).

C Only off site TSDFs are required to maintain ( i. e., photocopy and file) a copy of the notice, and the certification and demonstration, if applicable, required by the generator or owner or operator in the operating record ( § § 264.73( b)( 11), ( 13), and ( 15) and 265.73( b)( 11), ( 13), and ( 15)). Thus, EPA has determined that five percent of the operating universe ( 43 permitted and 3 interim status facilities) will need to maintain ( i. e., photocopy and file) this information in the operating record.

C Only on site TSDFs are required to maintain ( i. e., photocopy and file) the information contained in the notice ( except the manifest number), and the certification and demonstration if applicable, required by the generator or owner or operator ( § § 264.73( b)( 12), ( 14), and ( 16) and 265.73( b)( 12), ( 14), and ( 16)). EPA has determined that 95 percent of the operating universe ( 821 permitted and 55 interim status facilities) will need to maintain ( i. e., photocopy and file) this information in the operating record.

The remaining requirements ( § § 264.73( b)( 1)( 3), and ( 9) and 265.73( b)( 1)( 3), and ( 9)) apply to the entire universe of operating facilities. The average annual number of facilities subject to these requirements will be 864 permitted and 58 interim status facilities over the three year period covered by this ICR. 72 EXHIBIT 2 ANNUAL ESTIMATED RESPONDENT BURDEN AND COST OPERATING RECORD Number of Respondents Hours and Costs per Respondent or Activity Total Hours and Costs Legal Manager Technical Clerical Labor Capital/ Total Total Interim $ 116.00/ $ 84.00/ $ 64.00/ $ 36.00/ Cost Startup O& M Hours per Cost per INFORMATION COLLECTION ACTIVITY Permitted Status hour hour hour hour $/ Year Cost Cost Year Year Arrangements with Local Authorities ( 264.37( b) and 265.37( b))

Document refusal of State or local authorities to enter into arrangements 9 1 0.00 0.25 1.00 0.50 $ 103.00 $ 0.00 $ 0.00 16.14 $ 949.66 Determine Quantity of Waste ( 264.73 and 265.73( b)( 1) & ( b)( 2))

Maintain updated information in operating record 864 58 0.00 0.00 40.00 40.00 $ 4,000.00 $ 0.00 $ 0.00 73,760 $ 3,688,000.00 Records and Results of Waste Analysis ( 264.73 and 265.73( b)( 3))

Maintain updated information in operating record 864 58 0.00 0.00 0.00 20.00 $ 720.00 $ 0.00 $ 0.00 18,440 $ 663,840.00 Emergency Reports ( 264.73 and 265.73( b)( 4))

Maintain updated information in operating record 9 1 0.00 0.00 0.00 4.00 $ 144.00 $ 0.00 $ 0.00 36.88 $ 1,327.68 Inspections ( 264.73 and 265.73( b)( 5))

Maintain updated information in operating record 1,437 182 0.00 0.00 4.00 20.00 $ 976.00 $ 0.00 $ 0.00 38,856 $ 1,580,144.00 Monitoring, Testing, or Analytical Data and Corrective Action ( 264.73 and 265.73( b)( 6))

Maintain updated information in operating record 654 115 0.00 0.00 2.00 10.00 $ 488.00 $ 0.00 $ 0.00 9,228 $ 375,272.00 Notices to Generators ( 264.73 and 265.73( b)( 7))

Maintain updated information in operating record 104 7 0.00 0.00 0.00 2.00 $ 72.00 $ 0.00 $ 0.00 221.28 $ 7,966.08 Closure Cost Estimates ( 264.73 and 265.73( b)( 8))

Maintain updated information in operating record 1,333 198 0.00 0.00 0.00 0.25 $ 9.00 $ 0.00 $ 0.00 382.75 $ 13,779.00 Post Closure Cost Estimates ( 264.73 and 265.73( b)( 8))

Maintain updated information in operating record 87 7 0.00 0.00 0.00 0.25 $ 9.00 $ 0.00 $ 0.00 23.5 $ 846.00 Certification ( 264.73 and 265.73( b)( 9))

Maintain updated information in operating record 864 58 0.00 0.00 0.00 2.00 $ 72.00 $ 0.00 $ 0.00 1,844 $ 66,384.00 Records of waste disposed under an extension to effective date of the LDRs and notice required by generator under 268.7( a) ( 264.73 and 265.73( b)( 10))

Maintain updated information in operating record 87 7 0.00 0.00 1.00 2.00 $ 136.00 $ 0.00 $ 0.00 282 $ 12,784.00 Copy of notice, certification, and demonstration required by generator: Off site treatment, storage, and disposal facilities ( 264.73 and 265.73( b)( 11), ( b)( 13), and ( b)( 15))

Maintain updated information in operating record 43 3 0.00 0.00 0.00 2.00 $ 72.00 $ 0.00 $ 0.00 92.2 $ 3,319.20 Information in the notice, certification and demonstraton required by generator or owner or operator: On site treatment, storage, and disposal facilities ( 264.73 and 265.73( b)( 12), ( b)( 14), and ( b)( 16))

Maintain updated information in operating record 821 55 0.00 0.00 0.00 2.00 $ 72.00 $ 0.00 $ 0.00 1,751.8 $ 63,064.80 File Storage Systems for Recordkeeping Purchase file cabinets 1,333 198 0.00 0.00 0.00 0.00 $ 0.00 $ 180.83 $ 0.00 0.00 $ 276,853.83 TOTAL varies varies varies varies varies varies varies varies varies 144,934.55 $ 6,754,530.25 73 CONTINGENCY PLAN AND EMERGENCY REPORTING REQUIREMENTS ( 1) Contingency Plan For this ICR, the Agency assumes that existing interim status and permitted facilities have already prepared contingency plans. Therefore, only new interim status facilities will be required to prepare a contingency plan. ( Modifications to contingency plans of permitted facilities are covered under the Hazardous Waste Part B Permit Applications, Special Permits, and Permit Modifications ICR (# 1573)). EPA estimates that no new facilities will obtain interim status during the period covered by this ICR (# 1571), or submit the contingency plan to all local police and fire departments, hospitals, and State and local response teams.

( 2) Emergency Reporting And Recordkeeping Based on program experience, the Agency estimates that one percent of all facilities will experience an emergency situation each year that will require the help of State or local authorities with designated response roles. Therefore, approximately 15 emergency coordinators ( 13 at permitted facilities and 2 at interim status facilities) will be required to notify these authorities of an actual or imminent emergency situation ( § § 264.56( a)( 2) and 265.56( a)( 2)).

EPA estimates that one percent of those facilities experiencing an emergency situation ( approximately one permitted status facility) will have a release, fire, or explosion for which the emergency coordinator determines that it may be advisable to evacuate local areas.

EPA estimates that one percent of facilities will notify either a government official designated as the on scene coordinator or the National Response Center of a release, fire, or explosion ( § § 264.56( d)( 2) and 265.56( d)( 2)). EPA estimates that only one percent of all facilities will have emergency incidents requiring implementation of the contingency plan. Therefore, approximately 15 facilities ( 13 at permitted and 2 at interim status facilities) will be required to prepare an emergency report.

All owners and operators experiencing an emergency situation are required to notify the Regional Administrator that the facility is in compliance with § 265.56( h) before resuming operation in the affected areas. The owner or operator must also submit a written report to the Regional Administrator 15 days after the incident ( § § 264.56( j) and 265.56( j)). The respondent burden for recording emergency details in the operating record is covered in the operating record section. 74 EXHIBIT 3 ANNUAL ESTIMATED RESPONDENT BURDEN AND COST CONTINGENCY PLAN AND EMERGENCY PROCEDURES Number of Respondents Hours and Costs per Respondent or Acitivity Total Hours and Costs Legal Manager Technical Clerical Labor Capital/ Total Total Interim $ 116.00/ $ 84.00/ $ 64.00/ $ 36.00/ Cost Startup O& M Hours per Cost per INFORMATION COLLECTION ACTIVITY Permitted Status hour hour hour hour $/ Year Cost Cost Year Year Prepare and Submit Contingency Plan ( 265.50  .54)

Read the regulations N/ A 0 0.00 0.25 0.75 0.00 $ 69.00 $ 0.00 $ 0.00 0.00 $ 0.00 Collect information required to develop or modify the contingency plan N/ A 0 0.00 0.00 12.00 3.00 $ 876.00 $ 0.00 $ 0.00 0.00 $ 0.00 Develop the contingency plan N/ A 0 0.00 1.00 60.00 4.00 $ 4,068.00 $ 0.00 $ 0.00 0.00 $ 0.00 Submit contingency plan to local authorities 0 0 0.00 0.00 0.00 0.50 $ 18.00 $ 0.00 $ 3.20 0.00 $ 0.00 Maintain the contingency plan 0 0 0.00 0.00 0.00 1.00 $ 36.00 $ 0.00 $ 0.00 0.00 $ 0.00 Subtotal 0 0 0.00 1.25 72.75 8.50 $ 5,067.00 $ 0.00 $ 3.20 0.00 $ 0.00 Emergency Coordinator Reports ( 264.56( a)( 2), ( d)( 1), and ( d)( 2)), and 265.56( a)( 2), ( d)( 1), and ( d)( 2))

Notify State and local authorities of an imminent or actual emergency situation 13 2 0.00 0.50 0.00 0.00 $ 42.00 $ 0.00 $ 0.00 7.66 $ 643.02 Collect information required for an emergency report 13 2 0.00 0.00 2.50 0.50 $ 178.00 $ 0.00 $ 0.00 45.93 $ 2,725.18 Notify local authorities of the need to evacuate local areas 0 0 0.00 1.00 0.00 0.00 $ 84.00 $ 0.00 $ 0.00 0.15 $ 12.86 Submit an emergency report to the on scene coordinator or the National Response Center 13 2 0.00 1.00 0.00 0.00 $ 84.00 $ 0.00 $ 3.20 15.31 $ 1,335.03 Subtotal varies varies varies varies varies varies varies varies varies 69.05 $ 4,716.09 Notify Regional Administrator that facility is in compliance with 264.56( h) or 265.56( h) before resuming operations in the affected area ( 264.56( i) and 265.56( i))

Compile information that demonstrates that all affected areas are in compliance with 264.56( h) or 265.56( h) 13 2 0.00 0.00 2.50 0.50 $ 178.00 $ 0.00 $ 0.00 45.93 $ 2,725.18 Prepare and submit notification letter 13 2 0.00 0.25 1.50 0.25 $ 126.00 $ 0.00 $ 0.33 30.62 $ 1,934.11 Subtotal 13 2 0.00 0.25 4.00 0.75 $ 304.00 $ 0.00 $ 0.33 76.55 $ 4,659.29 Prepare an Owner/ Operator's Emergency Report ( 264.56( j) and 265.56( j))

Read the regulations 13 2 0.00 0.25 0.75 0.00 $ 69.00 $ 0.00 $ 0.00 15.31 $ 1,056.39 Collect information required in the emergency report 13 2 0.00 0.00 8.00 0.50 $ 530.00 $ 0.00 $ 0.00 130.14 $ 8,114.30 Prepare and submit the emergency report 13 2 0.00 0.25 4.00 0.50 $ 295.00 $ 0.00 $ 3.20 72.72 $ 4,565.44 Subtotal 13 2 0.00 0.50 12.75 1.00 $ 894.00 $ 0.00 $ 3.20 218.17 $ 13,736.13 TOTAL varies varies varies varies varies varies varies varies varies 363.77 $ 23,111.52 75 RELEASES FROM SOLID WASTE MANAGEMENT UNITS EPA expects that no facilities will be required to demonstrate that the ground water protection standard of § 264.92 has not been exceeded for three consecutive years ( § 264.96( c)). EPA also expects all facilities submitting a Part B permit application ( 13 facilities) to develop and submit sampling procedures to EPA ( § 264.97( g)).

CLOSURE AND POST CLOSURE REQUIREMENTS ( 1) Reading the Regulations The only facilities that are expected to read the closure regulations will be the newly permitted facilities. 13 land disposal facilities are expected to read the post closure regulations.

( 2) Closure Plans Since existing interim status and permitted facilities have already developed closure and post closure plans, activities associated with developing closure/ post closure plans apply to newly interim status facilities only. EPA expects no new facilities to develop and submit closure plans.

( 3) Closure Plan Amendment Based on previous experience, EPA estimates that five percent of operating or closing interim status facilities ( 6 facilities), such as facilities converting waste piles to containment buildings, will amend their closure plans annually and will submit a request to the Regional Administrator to authorize a change in the closure plan. Since closure plan amendments for permitted facilities are associated with permit modifications, amendments are discussed in the Hazardous Waste Part B Permit Applications, Special Permits, and Permit Modifications ICR, # 1573.

( 4) Partial Closure and Final Closure Notification Owners and operators of all 19 permitted and 9 interim status facilities who intend to close their facility annually must notify EPA of closure. In addition, owners and operators of the 9 interim status facilities must also submit their closure plans to EPA.

( 5) Extensions and Allowances During the Closure Period Of the total number of facilities that will be closing, EPA estimates that 20 percent annually, or 4 permitted and 2 interim status facilities, will request an extension for the treatment, storage, or removal of hazardous waste ( § § 264.113( a) and 265.113( a)). EPA estimates that an additional 20 percent ( 4 permitted and 2 interim status facilities) will request an extension for completing closure activities. EPA also estimates that an additional five percent of all closing facilities ( approximately 1 permitted and 0 interim facilities) will request an allowance to receive non hazardous wastes in a land based unit after the final receipt of hazardous waste ( § § 264.113( d) and 265.113( d)). 76 ( 6) Closure Certification EPA estimates that all of the 19 permitted and 9 interim status facilities that will be closing annually will complete a certification of closure.

( 7) Survey Plat EPA estimates that 50 percent of the nine land disposal facilities that will be closing annually ( 1 permitted and 4 interim status facilities) will submit a survey plat to the Regional Administrator.

( 8) Post Closure Plan Existing permitted land disposal facilities already have approved post closure plans. Therefore, only new interim status land disposal facilities will develop post closure plans. EPA estimates that no new interim status land disposal facilities ( no new facilities) will prepare a post closure plan annually. In addition to preparing a post closure plan, all permitted and interim status land disposal facilities ( 102 permitted and 12 interim status facilities) must also maintain ( i. e., photocopy, file, and update) the postclosure plan at the facility.

( 9) Notification and Amendment of Post Closure Plan Under 265.118( d)

Since respondent activities associated with permit modifications are discussed in the Hazardous Waste Part B Permit Applications, Special Permits, and Permit Modifications ICR (# 1573), this ICR focuses on interim status facilities' activities associated with notification of a post closure amendment. EPA estimates that 20 percent of interim status facilities that will be undergoing post closure, or two facilities, will amend their post closure plans and submit written notification of a change in the approved post closure plans.

( 10) Amendment of Post Closure Plan Under 265.118( d)( 4), ( f), and ( g)( 1)

In some cases, the Regional Administrator will require owners or operators of surface impoundments or waste piles who intend to remove all hazardous wastes at closure to modify their postclosure plans. EPA expects that ten percent of interim status facilities that are undergoing post closure ( approximately one facility) will be required to modify their post closure plan. EPA estimates that the Agency will reject ten percent of these plans, which will require approximately no facilities to modify its plan or submit a new plan.

In some cases, facilities will request that the Agency extend or reduce the post closure period applicable to a hazardous waste management unit or facility, or to alter the requirements of the post closure care period. EPA estimates that 20 percent of interim status facilities that are undergoing post closure ( two facilities), will prepare and submit such a request.

( 11) Hazardous Waste Disposal Records All nine owners and operators who close their land disposal facilities annually ( 2 permitted and 7 interim status facilities) must submit hazardous waste disposal records.

( 12) Hazardous Waste Notation Certification 77 All nine owners and operators who close their land disposal facilities annually ( 2 permitted and 7 interim status facilities) must submit a certification that they have recorded the notation required in § § 264.119( b)( 2) and 265.119( b)( 2).

( 13) Post Closure Plan Modifications EPA does not expect that any interim status facilities will subject to section 265.119( c) during the effective period of this ICR.

( 14) Post Closure Care Certification Since the post closure care period lasts for 30 years, except for those facilities that qualify for " early outs," EPA does not expect many owners/ operators to submit certifications of post closure care during the period covered by this ICR. Based on previous experience, EPA estimates that no facilities will complete post closure care and be required to submit certifications. 78 EXHIBIT 4 ANNUAL ESTIMATED RESPONDENT BURDEN AND COST RELEASES FROM SOLID WASTE MANAGEMENT UNITS Number of Respondents Hours and Costs per Respondent or Activity Total Hours and Costs Legal Manager Technical Clerical Labor Capital/ Total Total Interim $ 116.00/ $ 84.00/ $ 64.00/ $ 36.00/ Cost Startup O& M Hours per Cost per INFORMATION COLLECTION ACTIVITY Permitted Status hour hour hour hour $/ Year Cost Cost Year Year Termination of compliance period ( 264.96( c))

Read the regulations 0 N/ A 0.00 0.25 0.75 0.00 $ 69.00 $ 0.00 $ 0.00 0.00 $ 0.00 Prepare and submit demonstration 0 N/ A 0.00 1.00 4.00 1.00 $ 376.00 $ 0.00 $ 3.20 0.00 $ 0.00 Subtotal 0 N/ A 0.00 1.25 4.75 1.00 $ 445.00 $ 0.00 $ 3.20 0.00 $ 0.00 Proposal of sampling procedure and interval ( 264.97( g))

Read the regulations 13 N/ A 0.00 0.25 0.75 0.00 $ 69.00 $ 0.00 $ 0.00 13.00 $ 897.00 Develop and submit sampling procedure 13 N/ A 0.00 20.00 100.00 2.00 $ 8,152.00 $ 0.00 $ 3.20 1586.00 $ 106,017.60 Subtotal 62 N/ A 0.00 20.25 100.75 2.00 $ 8,221.00 $ 0.00 $ 3.20 1,599.00 $ 106,914.60 Total varies varies varies varies varies varies varies varies varies 1,599.00 $ 106,914.60 79 EXHIBIT 5 ANNUAL ESTIMATED RESPONDENT BURDEN AND COST CLOSURE AND POST CLOSURE REQUIREMENTS Number of Respondents Hours and Costs per Respondent or Activity Total Hours and Costs Legal Manager Technical Clerical Labor Capital/ Total Total Interim $ 116.00/ $ 84.00/ $ 64.00/ $ 36.00/ Cost Startup O& M Hours per Cost per INFORMATION COLLECTION ACTIVITY Permitted Status hour hour hour hour $/ Year Cost Cost Year Year Closure Plan ( 265.112( a))

Read the regulations N/ A 0 0.00 0.50 3.00 0.00 $ 234.00 $ 0.00 $ 0.00 0.00 $ 0.00 Conduct an inventory of hazardous waste N/ A 0 0.00 0.00 8.00 0.00 $ 512.00 $ 0.00 $ 0.00 0.00 $ 0.00 Record results of inventory N/ A 0 0.00 0.00 2.00 0.50 $ 146.00 $ 0.00 $ 0.00 0.00 $ 0.00 Write descriptions for activities N/ A 0 0.00 1.00 20.00 3.00 $ 1,472.00 $ 0.00 $ 0.00 0.00 $ 0.00 Estimate final closure N/ A 0 0.00 0.25 0.25 0.00 $ 37.00 $ 0.00 $ 0.00 0.00 $ 0.00 Write the closure schedule N/ A 0 0.00 0.50 1.00 0.50 $ 124.00 $ 0.00 $ 0.00 0.00 $ 0.00 Subtotal N/ A 0 0.00 2.25 34.25 4.00 $ 2,525.00 $ 0.00 $ 0.00 0.00 $ 0.00 Notification and Amendment of Closure Plan ( 265.112( c))

Prepare and submit notification of amendment N/ A 4 0.00 0.25 1.00 0.25 $ 94.00 $ 0.00 $ 0.33 5.85 $ 367.89 Amend and submit closure plan N/ A 4 0.00 0.00 8.00 1.00 $ 548.00 $ 0.00 $ 3.20 35.10 $ 2,149.68 Subtotal N/ A 4 0.00 0.25 9.00 1.25 $ 642.00 $ 0.00 $ 3.53 40.95 $ 2,517.57 Notification of Partial or Final Closure ( 264.112( d) and 265.112( d))

Prepare and submit notification of closure 19 9 0.00 0.25 0.50 0.25 $ 62.00 $ 0.00 $ 0.33 28.00 $ 1,745.24 Submit closure plan 19 9 0.00 0.00 0.00 1.00 $ 36.00 $ 0.00 $ 3.20 28.00 $ 1,097.60 Subtotal 19 9 0.00 0.25 0.50 1.25 $ 98.00 $ 0.00 $ 3.53 56.00 $ 2,842.84 Extension and Allowances During the Closure Period ( 264.113( a), 265.113( a), 264.113( b), 265.113( b), 264.113( d), and 265.113( d))

Prepare and submit demonstration for extension for treatment, storage, or removal of hazardous waste ( 264/ 265.113( a)) 4 2 0.00 4.00 80.00 1.00 $ 5,492.00 $ 0.00 $ 3.20 476.00 $ 30,773.12 Prepare and submit demonstration for extension of the closure period ( 264/ 265.113( b)) 4 2 0.00 4.00 80.00 1.00 $ 5,492.00 $ 0.00 $ 3.20 476.00 $ 30,773.12 Prepare and submit demonstration for receiving non hazardous waste ( 264/ 265.113( d)) 1 0 0.00 4.00 100.00 1.00 $ 6,772.00 $ 0.00 $ 3.20 147.00 $ 9,485.28 Subtotal varies varies varies varies varies varies varies varies varies 1,099.00 $ 71,031.52 Certification of Closure ( 264.115 and 265.115)

Have an independent registered professional engineer inspect the facility 19 9 0.00 0.00 1.00 0.00 $ 64.00 $ 0.00 $ 1,000.00 28.00 $ 29,792.00 Collect documentation to support certification and submit certification 19 9 0.00 0.00 3.00 2.00 $ 264.00 $ 0.00 $ 9.20 140.00 $ 7,649.60 Subtotal 19 9 0.00 0.00 4.00 2.00 $ 328.00 $ 0.00 $ 1,009.20 168.00 $ 37,441.60 Survey Plat ( 264.116 and 265.116)

Have a professional land surveyor prepare and certify plat, and submit plat 1 4 0.00 0.00 1.00 2.00 $ 136.00 $ 0.00 $ 750.00 13.50 $ 3,987.00 Subtotal 1 4 0.00 0.00 1.00 2.00 $ 136.00 $ 0.00 $ 750.00 13.50 $ 3,987.00 Post Closure Plan ( 265.118)

Read the regulations N/ A 0 0.00 0.50 3.00 0.00 $ 234.00 $ 0.00 $ 0.00 0.00 $ 0.00 Collect data N/ A 0 0.00 1.00 12.00 7.00 $ 1,104.00 $ 0.00 $ 0.00 0.00 $ 0.00 Write and submit post closure plan N/ A 0 0.00 1.00 20.00 2.00 $ 1,436.00 $ 0.00 $ 3.20 0.00 $ 0.00 Maintain post closure plan 0 0 0.00 0.00 0.00 1.00 $ 36.00 $ 0.00 $ 0.00 0.00 $ 0.00 Subtotal varies varies varies varies varies varies varies varies varies 0.00 $ 0.00 80 Notification and Amendment of Post Closure Plan Under 265.118( a)( 1)( 3)

Prepare and submit notification of amendment N/ A 1 0.00 0.25 1.00 0.25 $ 94.00 $ 0.00 $ 0.33 2.10 $ 132.06 Prepare and submit amended post closure plan N/ A 1 0.00 0.00 8.00 1.00 $ 548.00 $ 0.00 $ 3.20 12.60 $ 771.68 Subtotal N/ A 1 0.00 0.25 9.00 1.25 $ 642.00 $ 0.00 $ 3.53 14.70 $ 903.74 Amendment of Post Closure Plan Under 265.118( d)( 4), ( f), and ( g)( 1)

Amend and submit post closure plan as requested by EPA ( 265.118( d)( 4)) N/ A 1 0.00 0.50 6.00 1.50 $ 480.00 $ 0.00 $ 3.20 5.60 $ 338.24 Modify and resubmit plan, if not approved by EPA ( 265.118( f)) N/ A 0 0.00 0.50 6.00 2.00 $ 498.00 $ 0.00 $ 3.20 0.60 $ 35.08 Petition to extend or reduce the post closure care period ( 265.118( g)( 1)) N/ A 1 0.00 0.50 1.00 0.50 $ 124.00 $ 0.00 $ 3.20 2.80 $ 178.08 Subtotal N/ A varies varies varies varies varies varies varies varies 9.00 $ 551.40 Hazardous Waste Disposal Records ( 264.119 and 265.119( a))

Determine specifications of hazardous waste activity 2 7 0.00 0.00 2.00 0.00 $ 128.00 $ 0.00 $ 0.00 18.00 $ 1,152.00 Establish and submit a record of activity 2 7 0.00 0.00 1.00 0.00 $ 64.00 $ 0.00 $ 3.20 9.00 $ 604.80 Maintain the record of activity 2 7 0.00 0.00 0.00 1.00 $ 36.00 $ 0.00 $ 0.00 9.00 $ 324.00 Subtotal 2 7 0.00 0.00 3.00 1.00 $ 228.00 $ 0.00 $ 3.20 36.00 $ 2,080.80 Hazardous Waste Notation Certification Record notation on deed, and develop and submit certification 2 7 1.00 0.00 1.00 2.00 $ 252.00 $ 0.00 $ 0.33 36.00 $ 2,270.97 Subtotal 2 7 0.00 0.00 1.00 2.00 $ 252.00 $ 0.00 $ 0.33 36.00 $ 2,270.97 Post Closure Plan Modifications ( 265.119( c))

Prepare request for modification N/ A 0 0.00 0.50 1.25 0.25 $ 131.00 $ 0.00 $ 0.00 0.00 $ 0.00 Demonstrate compliance N/ A 0 0.00 0.25 1.75 1.00 $ 169.00 $ 0.00 $ 0.00 0.00 $ 0.00 Subtotal N/ A 0 0.00 0.75 3.00 1.25 $ 300.00 $ 0.00 $ 0.00 0.00 $ 0.00 Certification of Completion of Post Closure Care ( 264.120 and 265.120)

Obtain certification of compliance from an independent registered professional engineer 0 0 0.00 1.00 4.00 0.00 $ 340.00 $ 0.00 $ 1,000.00 0.00 $ 0.00 Maintain a copy of the certification 0 0 0.00 0.00 0.00 1.00 $ 36.00 $ 0.00 $ 0.00 0.00 $ 0.00 Submit documentation to EPA 0 0 0.00 0.00 0.00 1.00 $ 36.00 $ 0.00 $ 3.20 0.00 $ 0.00 Subtotal 0 0 0.00 1.00 4.00 2.00 $ 412.00 $ 0.00 $ 1,003.20 0.00 $ 0.00 TOTAL varies varies varies varies varies varies varies varies varies 1,473.15 $ 123,627.44 EXHIBIT 5 ( continued)

ANNUAL ESTIMATED RESPONDENT BURDEN AND COST CLOSURE AND POST CLOSURE REQUIREMENTS Number of Respondents Hours and Costs per Respondent or Activity Total Hours and Costs Legal Manager Technical Clerical Labor Capital/ Total Total Interim $ 116.00/ $ 84.00/ $ 64.00/ $ 36.00/ Cost Startup O& M Hours per Cost per INFORMATION COLLECTION ACTIVITY Permitted Status hour hour hour hour $/ Year Cost Cost Year Year 81 FINANCIAL REQUIREMENTS ( 1) Reading the Regulations All operating and newly constructed facilities ( 864 permitted and 58 interim status facilities) are expected to read the financial requirements regulations.

( 2) Financial Responsibility for Corrective Action Because financial responsibility for corrective action is required under Part 264, only permitted facilities are included in the burden estimate. EPA estimates that 80 percent of permitted facilities completed a RCRA Facility Assessment ( RFA) that indicated that further investigation, or a RCRA Facility Investigation ( RFI), was necessary. Because such further investigation will entail the submission of corrective action financial assurance documentation, EPA concludes that 80 percent of the 1,333 permitted facilities, or 1,066 facilities, will need to meet corrective action financial responsibility requirements. These facilities will need to include this financial assurance documentation in their permit renewals; because most TSDF permits are valid for five years, EPA estimates that each year approximately 20 percent, or 213 of these 1,066 facilities will submit financial assurance documentation for corrective action. EPA estimates that ten percent of these facilities per year ( 21 facilities) will need to provide the additional demonstration of denied permission to implement corrective action beyond facility boundaries.

( 3) Cost Estimates for Closure and Post Closure Care The burden for respondents to collect data, to prepare closure and post closure care cost estimates, and to maintain these estimates at the facility is already calculated in Exhibit 5, Closure and Post Closure Care Requirements. Therefore, Exhibit 6 only determines the burden for owners or operators to update cost estimates on a yearly basis to reflect inflation, and the burden for amending cost estimates due to changes in the closure or post closure care plan. Except for those facilities already closed or post closed, all operating facilities ( 864 permitted and 58 interim status) will need to adjust estimates annually to reflect inflation. For amendments of cost estimates due to changes in closure or post closure plans, EPA estimates, as shown in Exhibit 5, 21 interim status facilities that are not closed or post closed will amend their closure or postclosure plans annually ( 20 closure plan amendments and 1 post closure plan amendments). Since closure and post closure plan amendments for permitted facilities are associated with permit modifications, such amendments are instead discussed in the Hazardous Waste Part B Permit Applications, Special Permits, and Permit Modifications ICR (# 1573).

( 4) Financial Assurance for Closure or Post Closure Care Because evidence of establishing a financial instrument for closure or post closure care is submitted with the Part B permit application, such activities for permitted facilities are discussed in the Hazardous Waste Part B Permit Applications, Special Permits, and Permit Modifications ICR (# 1573). However, prior to submitting a permit application, interim status facilities must present evidence of an established financial instrument for closure or post closure care under § § 265.143 and 265.145. Therefore, preparation of the required evidence for interim status facilities is discussed in Exhibit 6. In addition, the burden associated with annual updates or modifications to financial instruments is calculated in this exhibit for both permitted and interim status facilities. 82 Only new interim facilities will have to choose between the financial test for liability coverage and the other coverage options. EPA estimates that no new interim facilities will join the universe in the period this ICR covers.

EPA projects that two percent of existing facilities amend closure and post closure financial instruments due to changes in the cost estimates or plans. Therefore, EPA calculates that 27 permitted facilities and 4 interim status facilities will need to engage in activities to modify amounts covered by each financial instrument. Finally, all facilities covered under the financial test will need to submit annual updates; accordingly, 50 percent of existing facilities ( 667 permitted and 99 interim status facilities) will submit this update.

( 5) Liability Requirements EPA calculates the number of respondents for demonstrating liability coverage in a manner similar to determining the number of closure and post closure care respondents. Because evidence of establishing a financial instrument for liability coverage is submitted with the Part B permit application, such activities for permitted facilities are discussed in the Hazardous Waste Part B Permit Applications, Special Permits, and Permit Modifications ICR (# 1573). However, prior to submitting a permit application, interim status facilities must present evidence of an established financial instrument for liability coverage under § 265.147. Therefore, preparation of the required evidence for interim status facilities is shown in Exhibit 6 of this ICR. In addition, the burden associated with annual updates or modifications to financial instruments for liability coverage is calculated in this exhibit for both permitted and interim status facilities.

Only new interim facilities will have to choose between the liability coverage options. EPA estimates that no new interim facilities will join the universe in the period this ICR covers.

EPA expects that all existing TSDFs using the financial test or guarantee will submit the financial test documentation on an annual basis for review. Using the estimate that 25 percent of all non closed and non post closed facilities choose each of these mechanisms, EPA estimates that 333 permitted and 50 interim status facilities will submit this information on an annual basis for each option.

EPA estimates that one percent of all facilities ( 13 permitted and 2 interim status) will become bankrupt and will need to submit evidence of insurance. EPA further estimates, based on earlier estimates, that 10 facilities will submit claim notifications ( 8 permitted facilities and 2 interim status facilities, based on the ratio of permitted facilities to interim status facilities).

( 6) Other Requirements As discussed above, the average bankruptcy rate of one percent will generate 13 permitted and 2 interim status respondents for the incapacity of owners or operators, guarantors, or financial institutions requirements.

For activities relating to State required mechanisms and State assumption of responsibility, EPA estimates that one percent of interim status facilities, or 2 facilities ( permitted facilities are included in ICR # 1573), will be included in the respondent burden estimate. EPA estimates that of these 2 facilities, only one percent ( approximately zero interim status facilities) will be required by EPA to furnish additional information under the State assumption of responsibility requirements. 83 CONDITIONS APPLICABLE TO ALL PERMITS EPA estimates that each year 20 percent of permitted facilities, or 173 facilities, will submit a permit modification at the request of the Agency. These permittees will be required to furnish any relevant information requested by EPA to determine whether cause exists to modify, revoke and reissue, or terminate a permit, or to determine compliance with a permit.

EPA estimates that 15 percent of permitted facilities, or 130 facilities will annually submit a notice of physical alterations or additions. Of these facilities, 50 percent ( 65 facilities) will submit a notice of planned changes that may result in noncompliance with permit requirements. Of these 65 facilities, 50 percent ( 33 facilities) will submit a letter certifying that the facility has been constructed or modified in compliance with the terms of the permit.

EPA estimates that all permitted facilities with land based units and incinerators ( 168 facilities) must submit monitoring reports. EPA further estimates that one percent or 13 facilities will be required to prepare and submit reports of compliance and noncompliance with the compliance schedule at intervals specified in the permit.

EPA estimates that one percent of all permitted facilities, or 13 facilities, will experience a release, fire, or explosion that may threaten drinking water supplies, human health, or the environment outside the facility. These facilities will be required to submit a report within 24 hours of the incident and a more detailed written notice or report within 5 or 15 days, respectively, of the incident.

EPA estimates that two percent of all permitted facilities, or 26 facilities will be required to submit reports of other noncompliance that are not submitted with monitoring reports, compliance schedule reports, and reports of releases, fires, and explosions. An additional one percent, or 13 facilities, will submit amended information that was incorrect or omitted during an initial submittal.

TOTAL RESPONDENT BURDEN AND COST Exhibit 8 illustrates the total respondent burden and costs associated with all of the information collection activities covered in this ICR. As shown in Exhibit 8, EPA estimates that the total annual respondent burden for all activities covered in the ICR is approximately 652,312 hours, at an annual cost of $ 45,906,572. 84 EXHIBIT 6 ANNUAL ESTIMATED RESPONDENT BURDEN AND COST FINANCIAL REQUIREMENTS Number of Respondents Hours and Costs per Respondent Total Hours and Costs Legal Manager Technical Clerical Labor Capital/ Total Total Interim $ 116.00/ $ 84.00/ $ 64.00/ $ 36.00/ Cost Startup O& M Hours per Cost per INFORMATION COLLECTION ACTIVITY Permitted Status hour hour hour hour $/ Year Cost Cost Year Year Reading the Regulations Read the regulations covering financial responsibility requirements ( new facilities) 8 0 8.00 2.00 8.00 0.00 $ 1,608.00 $ 0.00 $ 0.00 144 $ 12,864.00 Read the regulations covering financial responsibility requirements ( existing facilities) 864 58 4.00 1.00 4.00 0.00 $ 804.00 $ 0.00 $ 0.00 8,298 $ 741,288.00 Subtotal varies varies varies varies varies varies varies varies varies 8,298 $ 754,152.00 Financial Responsibility for Corrective Action ( 264.101)

Prepare and submit documented assurances of financial responsibility for corrective action 216 N/ A 2.00 0.50 5.50 1.00 $ 662.00 $ 0.00 $ 3.20 1,944 $ 143,647.28 Demonstrate, if applicable, that permission denied to implement correction action beyond facility boundary 22 N/ A 1.00 0.50 1.25 0.25 $ 247.00 $ 0.00 $ 3.20 65 $ 5,402.97 Subtotal varies N/ A varies varies varies varies varies varies varies 2,008 $ 149,050.25 Cost Estimates for Closure and Post Closure Care ( 264.142, 264.144, 265.142, and 265.144)

Adjust estimate annually to reflect inflation 864 58 0.00 0.00 0.50 0.00 $ 32.00 $ 0.00 $ 0.00 461 $ 29,504.00 Amend cost estimate due to closure/

post closure plan changes 0 5 0.00 0.50 6.50 0.50 $ 476.00 $ 0.00 $ 0.00 38 $ 2,380.00 Subtotal varies varies varies varies varies varies varies varies varies 499 $ 31,884.00 Closure or Post Closure Trust Fund ( 264.143, 265.143, 264.145, and 265.145)

Establish a closure or post closure trust fund 0 0 4.00 1.50 2.00 0.50 $ 736.00 $ 0.00 $ 0.00 0 $ 0.00 Submit orginally signed duplicate of trust agreement 0 0 0.00 0.00 0.00 0.50 $ 18.00 $ 0.00 $ 3.20 0 $ 0.00 Submit formal certification of acknowledgement ( post closure trust funds only) 0 0 0.00 0.00 0.00 1.00 $ 36.00 $ 0.00 $ 0.33 0 $ 0.00 Submit receipt for first payment under trust agreement ( new facilities) 0 0 0.00 0.00 0.00 1.00 $ 36.00 $ 0.00 $ 0.33 0 $ 0.00 Amend trust fund due to changes in closure/ post closure plan 3 0 2.00 1.00 0.75 0.25 $ 373.00 $ 0.00 $ 0.00 15 $ 1,427.66 Subtotal varies varies varies varies varies varies varies varies varies 15 $ 1,427.66 Surety bond guaranteeing payment into a closure or post closure trust fund ( 264.143( b), 265.143( b), 264.145( b) and 265.145( b)), or guaranteeing performance of closure or post closure care ( 264.143( c) and 264.145( c))

Establish surety bond and trust agreement 0 0 4.00 1.50 2.00 0.50 $ 736.00 $ 0.00 $ 0.00 0 $ 0.00 Submit orginally signed duplicates of bond/ trust agreement 0 0 0.00 0.00 0.00 0.50 $ 18.00 $ 0.00 $ 3.20 0 $ 0.00 Submit evidence of alternate financial mechanisms, if bond cancelled 0 0 0.00 0.00 0.00 1.00 $ 36.00 $ 0.00 $ 3.20 0 $ 0.00 Increase penal sum amount, if cost estimate modified 3 0 2.25 0.75 1.00 0.00 $ 388.00 $ 0.00 $ 0.00 15 $ 1,485.07 Submit evidence of increase in cost estimate 3 0 0.00 0.00 0.00 1.00 $ 36.00 $ 0.00 $ 3.20 4 $ 150.04 Subtotal varies varies varies varies varies varies varies varies varies 19 $ 1,635.11 85 EXHIBIT 6 ( continued)

ANNUAL ESTIMATED RESPONDENT BURDEN AND COST FINANCIAL REQUIREMENTS Number of Respondents Hours and Costs per Respondent Total Hours and Costs Legal Manager Technical Clerical Labor Capital/ Total Total Interim $ 116.00/ $ 84.00/ $ 64.00/ $ 36.00/ Cost Startup O& M Hours per Cost per INFORMATION COLLECTION ACTIVITY Permitted Status hour hour hour hour $/ Year Cost Cost Year Year Closure or Post Closure Letter of Credit ( 264.143( d), 265.143( c), 264.145( d), and 265.145c))

Obtain and submit letter of credit from issuing institution 0 0 4.00 1.50 2.00 0.50 $ 736.00 $ 0.00 $ 0.33 0 $ 0.00 Write and submit letter to accompany letter of credit 0 0 1.25 0.25 0.00 0.50 $ 184.00 $ 0.00 $ 0.33 0 $ 0.00 Submit originally signed duplicate of the trust agreement 0 0 0.00 0.00 0.00 0.50 $ 18.00 $ 0.00 $ 3.20 0 $ 0.00 Increase credit amount, if cost estimate modified 3 0 0.75 0.50 0.75 0.00 $ 177.00 $ 0.00 $ 0.00 8 $ 677.47 Submit evidence of increase in cost estimate 3 0 0.00 0.00 0.00 1.00 $ 36.00 $ 0.00 $ 3.20 4 $ 150.04 Subtotal varies varies varies varies varies varies varies varies varies 11 $ 827.51 Closure or Post Closure Insurance ( 264.143( e), 265.143( d), 264.145( e), and 265.145( d))

Establish closure or post closure insurance policy 0 0 4.00 1.50 2.00 0.50 $ 736.00 $ 0.00 $ 0.00 0 $ 0.00 Submit insurance policy certificate to EPA 0 0 0.00 0.00 0.00 0.50 $ 18.00 $ 0.00 $ 0.33 0 $ 0.00 Submit letter from insurer ( for some interim status facilities only) 0 0 0.00 0.00 0.00 1.00 $ 36.00 $ 0.00 $ 0.33 0 $ 0.00 Increase insured amount, if cost estimate modified 3 0 2.50 0.50 0.00 0.00 $ 332.00 $ 0.00 $ 0.00 11 $ 1,270.73 Submit evidence of increase in cost estimate 3 0 0.00 0.00 0.00 1.00 $ 36.00 $ 0.00 $ 3.20 4 $ 150.04 Subtotal varies varies varies varies varies varies varies varies varies 15 $ 1,420.77 Financial Test and Corporate Guarantee ( 264.143( f), 265.143( e), 264.145( f), and 265.145( e))

Write and submit letter signed by chief financial officer 0 0 1.00 0.25 2.00 0.75 $ 292.00 $ 0.00 $ 0.33 0 $ 0.00 Submit copy of public accountant's report and special report 0 0 0.00 0.00 0.00 1.00 $ 36.00 $ 0.00 $ 3.20 0 $ 0.00 Submit updated information annually 667 99 0.00 0.00 0.00 4.00 $ 144.00 $ 0.00 $ 3.20 3,062 $ 112,681.60 Write and submit notice of intent to establish other financial assurance, if applicable 13 2 3.25 0.25 0.00 0.50 $ 416.00 $ 0.00 $ 0.33 61 $ 6,374.01 Write and submit any additional reports of financial condition 13 2 2.25 0.25 1.00 0.50 $ 364.00 $ 0.00 $ 3.20 61 $ 5,621.83 Submit corporate guarantee from parent corporation 0 0 0.00 0.00 0.00 1.00 $ 36.00 $ 0.00 $ 0.33 0 $ 0.00 Subtotal varies varies varies varies varies varies varies varies varies 3,184 $ 124,677.44 Coverage for Sudden or Nonsudden Accidental Occurrences ( 264.147( a), 265.147( a), 264.147( b), and 265.147( b))

Prepare, write, and submit a claim notification, if applicable 7 1 2.50 1.00 0.00 0.50 $ 392.00 $ 0.00 $ 0.33 31 $ 3,003.29 Prepare, write, and submit notification of reduction of liability coverage amount if applicable 27 4 2.00 1.00 0.50 0.50 $ 366.00 $ 0.00 $ 0.33 122 $ 11,217.02 Subtotal varies varies varies varies varies varies varies varies varies 153 $ 14,220.31 86 EXHIBIT 6 ( continued)

ANNUAL ESTIMATED RESPONDENT BURDEN AND COST FINANCIAL REQUIREMENTS Number of Respondents Hours and Costs per Respondent Total Hours and Costs Legal Manager Technical Clerical Labor Capital/ Total Total Interim $ 116.00/ $ 84.00/ $ 64.00/ $ 36.00/ Cost Startup O& M Hours per Cost per INFORMATION COLLECTION ACTIVITY Permitted Status hour hour hour hour $/ Year Cost Cost Year Year Variance of financial responsibility regulations ( 265.147( c))

Prepare and submit petition for variance 0 0 0.50 0.50 0.50 0.00 $ 132.00 $ 0.00 $ 3.20 0 $ 0.00 Subtotal 0 0 0.50 0.50 0.50 0.00 $ 264.00 $ 0.00 $ 3.20 0 $ 0.00 Financial Test for Liability Coverage ( 264.147( f) and 265.147( f))

Prepare, write, and submit letter signed by chief financial officer 0 0 1.00 0.25 2.00 0.75 $ 292.00 $ 0.00 $ 0.33 0 $ 0.00 Submit copy of public accountant's report and special report 0 0 0.00 0.00 0.00 1.00 $ 36.00 $ 0.00 $ 3.20 0 $ 0.00 Submit updated information annually 333 50 0.00 0.00 0.00 4.00 $ 144.00 $ 0.00 $ 3.20 1,531 $ 56,340.80 Submit evidence of insurance obtained for entire liability coverage, if applicable 13 2 0.00 0.00 0.00 2.00 $ 72.00 $ 0.00 $ 3.20 31 $ 1,151.31 Subtotal varies varies varies varies varies varies varies varies varies 1,562 $ 57,492.11 Guarantee for Liability Coverage ( 264.147( g) and 265.147( g))

Obtain and submit written guarantee from parent corporation 0 0 0.50 0.50 0.50 0.50 $ 150.00 $ 0.00 $ 0.33 0 $ 0.00 Submit letter from guarantor's chief financial officer 0 0 0.00 0.00 0.00 1.00 $ 36.00 $ 0.00 $ 0.33 0 $ 0.00 Submit updated information annually 333 50 0.00 0.00 0.00 4.00 $ 144.00 $ 0.00 $ 3.20 1,531 $ 56,340.80 Subtotal varies varies varies varies varies varies varies varies varies 1,531 $ 56,340.80 Letter of Credit for Liability Coverage ( 264.147( h) and 265.147( h))

Obtain and submit stand by letter of credit 0 0 4.00 1.00 2.00 1.00 $ 712.00 $ 0.00 $ 0.33 0 $ 0.00 Subtotal 0 0 4.00 1.00 2.00 1.00 $ 712.00 $ 0.00 $ 0.33 0 $ 0.00 Liability Insurance ( 264.147( a) and ( b), and 265.147( a) and ( b))

Obtain and submit insurance policy documentation 0 2 4.00 1.00 2.00 1.00 $ 712.00 $ 0.00 $ 3.20 16 $ 1,430.40 Subtotal 0 2 4.00 1.00 2.00 1.00 $ 712.00 $ 0.00 $ 3.20 16 $ 1,430.40 Surety Bond for Liability Coverage ( 264.147( i) and 265.147( i))

Obtain surety bond and submit copy to EPA 0 2 4.00 1.00 2.00 1.00 $ 712.00 $ 0.00 $ 0.33 16 $ 1,424.66 Subtotal 0 2 4.00 1.00 2.00 1.00 $ 712.00 $ 0.00 $ 0.33 16 $ 1,424.66 Trust Fund for Liability Coverage ( 264.147( j) and 265.147( j))

Establish trust fund 0 2 4.50 1.50 1.00 1.00 $ 748.00 $ 0.00 $ 0.00 16 $ 1,496.00 Submit originally signed duplicate of trust agreement to EPA 0 2 0.00 0.00 0.00 1.00 $ 36.00 $ 0.00 $ 3.20 2 $ 78.40 Subtotal 0 2 4.50 1.50 1.00 2.00 $ 784.00 $ 0.00 $ 3.20 18 $ 1,574.40 Incapacity of Owners or Operators, Guarantors, or Financial Institutions ( 264.148 and 265.148)

Submit notice indicating commencement of bankruptcy proceedings 13 2 0.00 0.00 0.00 1.00 $ 36.00 $ 0.00 $ 0.33 15 $ 556.21 Subtotal 13 2 0.00 0.00 0.00 1.00 $ 36.00 $ 0.00 $ 0.33 15 $ 556.21 87 EXHIBIT 6 ( continued)

ANNUAL ESTIMATED RESPONDENT BURDEN AND COST FINANCIAL REQUIREMENTS Number of Respondents Hours and Costs per Respondent Total Hours and Costs Legal Manager Technical Clerical Labor Capital/ Total Total Interim $ 116.00/ $ 84.00/ $ 64.00/ $ 36.00/ Cost Startup O& M Hours per Cost per INFORMATION COLLECTION ACTIVITY Permitted Status hour hour hour hour $/ Year Cost Cost Year Year Use of State Required Mechanisms ( 264.149) and 265.149)

Submit letter from owner or operator 0 2 0.00 0.00 0.00 4.00 $ 144.00 $ 0.00 $ 0.33 8 $ 285.77 Submit written evidence of establishment of State required financial assurance mechanism 0 2 0.00 0.00 0.00 2.00 $ 72.00 $ 0.00 $ 3.20 4 $ 148.90 Subtotal 0 2 0.00 0.00 0.00 6.00 $ 216.00 $ 0.00 $ 3.53 12 $ 434.67 State Assumption of Responsibility ( 264.150 and 265.150)

Prepare and submit letter from owner or operator 0 2 1.00 5.00 2.00 0.50 $ 682.00 $ 0.00 $ 0.33 17 $ 1,351.01 Obtain and submit letter from State describing assumption of responsiblity 0 2 0.00 0.00 0.00 1.00 $ 36.00 $ 0.00 $ 0.33 2 $ 71.93 Prepare and submit any additional information requested by EPA 0 0.0 0.75 0.25 0.75 0.25 $ 165.00 $ 0.00 $ 3.20 0 $ 3.33 Subtotal varies varies varies varies varies varies varies varies varies 19 $ 1,426.28 Estimated decrease in Federally required cost due to facilities using State required mechanisms 0 2 5.00 3.00 11.00 3.00 $ 1,644.00 $ 0.00 $ 0.00 44 $ 3,255.12 Subtotal 0 2 5.00 3.00 11.00 3.00 $ 1,644.00 $ 0.00 $ 0.00 44 $ 3,255.12 TOTAL varies varies 0.00 varies varies varies varies varies varies 17,436 $ 1,203,229.69 88 EXHIBIT 7 ANNUAL ESTIMATED RESPONDENT BURDEN AND COST PERMIT CONDITIONS Number of Respondents Hours and Costs per Respondent Total Hours and Costs Legal Manager Technical Clerical Labor Capital/ Total Total Interim $ 116.00/ $ 84.00/ $ 64.00/ $ 36.00/ Cost Startup O& M Hours per Cost per INFORMATION COLLECTION ACTIVITY Permitted Status hour hour hour hour $/ Year Cost Cost Year Year Conditions applicable to all permits ( 270.30( h) and ( l))

Prepare and submit information requested by EPA 173 N/ A 0.00 0.25 1.00 0.25 $ 94.00 $ 0.00 $ 3.20 259.50 $ 16,815.60 Prepare and submit notice of planned physical alterations or additions 155 N/ A 0.00 0.25 1.00 0.25 $ 94.00 $ 0.00 $ 0.33 232.50 $ 14,621.15 Prepare and submit notice of planned changes or activities which may result in noncompliance 78 N/ A 0.00 0.25 1.00 0.25 $ 94.00 $ 0.00 $ 0.33 117.00 $ 7,357.74 Prepare and submit letter certifying compliance 39 N/ A 0.00 0.25 1.00 0.25 $ 94.00 $ 0.00 $ 0.33 58.50 $ 3,678.87 Prepare and submit monitoring reports 1171 N/ A 0.00 0.25 8.00 0.25 $ 542.00 $ 0.00 $ 3.20 9953.50 $ 638,429.20 Prepare and submit reports of compliance or noncompliance with compliance schedule 13 N/ A 0.00 0.25 2.00 1.00 $ 185.00 $ 0.00 $ 3.20 43.32 $ 2,508.71 Compile and submit information for 24 hour reporting of a release of hazardous waste, a fire,

or an explosion 13 N/ A 0.00 0.50 8.00 0.50 $ 572.00 $ 0.00 $ 3.20 119.97 $ 7,667.42 Prepare and submit notice of noncompliance due to a release, fire, or explosion 13 N/ A 0.00 0.50 4.00 0.50 $ 316.00 $ 0.00 $ 0.33 66.65 $ 4,216.68 Prepare and submit a report of other noncompliance 27 N/ A 0.00 0.50 2.00 0.50 $ 188.00 $ 0.00 $ 3.20 79.98 $ 5,097.39 Prepare and submit omitted or corrected information 13 N/ A 0.00 0.25 0.50 0.25 $ 62.00 $ 0.00 $ 3.20 13.33 $ 869.12 TOTAL varies N/ A varies varies varies varies varies varies varies 10,944.25 $ 701,261.87 89 EXHIBIT 8 TOTAL ESTIMATED RESPONDENT BURDEN AND COST SUMMARY Total Total Total Total Total Hours per Capital per O& M per Labor Cost Cost per EXHIBIT Year Year Year per Year Year Exhibit 1 General Facility Standards 475,561 $ 0 $ 589,008 $ 36,404,889 $ 36,993,896 Exhibit 2 Recordkeeping Requirements 144,935 $ 12,658 $ 0 $ 6,741,872 $ 6,754,530 Exhibit 3 Contingency Plan and Emergency Procedures 364 $ 0 $ 103 $ 23,008 $ 23,112 Exhibit 4 Ground Water Monitoring Requirements 1,599 $ 0 $ 42 $ 106,873 $ 106,915 Exhibit 5 Closure and Post Closure Requirements 1,473 $ 0 $ 31,829 $ 91,798 $ 123,627 Exhibit 6 Financial Requirements 17,436 $ 0 $ 3,222 $ 1,200,007 $ 1,203,230 Exhibit 7 Permit Conditions 10,944 $ 0 $ 4,608 $ 696,654 $ 701,262 TOTAL 652,312 12,658 628,812 45,265,102 $ 45,906,572 90 EXHIBIT 9 ESTIMATED ANNUAL AGENCY BURDEN AND COST Number of Respondents Hours and Costs per Respondent or Activity Total Hours and Costs Legal Manager Technical Clerical Labor Capital/ Total Total $ 60.42/ $ 38.35/ $ 26.91/ $ 16.36/ Cost Startup O& M Hours per Cost per INFORMATION COLLECTION ACTIVITY Permitted Interim hour hour hour hour $/ Year Cost Cost Year Year GENERAL FACILITY OPERATING REQUIREMENTS Foreign Shipment Import Report Review foreign shipment import report 52 3 0.00 0.00 1.00 0.00 39.44 0.00 0.00 55.32 $ 2,181.82 Review of records during inspections 13 0 0.00 0.00 1.00 0.00 $ 39.44 $ 0.00 $ 0.00 13.00 $ 512.72 Subtotal varies varies 0.00 0.00 varies varies varies $ 0.00 $ 0.00 68.32 $ 2,694.54 RECORDKEEPING REQUIREMENTS Operating Record On site review of the operating record 864 58 0.00 0.00 2.00 0.00 78.88 0.00 0.00 1,844.00 $ 72,727.36 Subtotal 864 58 0.00 0.00 2.00 0.00 78.88 0.00 0.00 1,844.00 $ 72,727.36 CONTINGENCY PLAN AND EMERGENCY PROCEDURES Contingency Plan On site review of the contingency plan 1,333 198 0.00 0.00 0.50 0.00 19.72 0.00 0.00 765.50 $ 30,191.32 Emergency Reporting Requirements Review owner/ operator's emergency report 13 2 0.00 0.00 1.00 0.00 $ 39.44 $ 0.00 $ 0.00 15.31 $ 603.83 Subtotal varies varies 0.00 0.00 varies varies varies $ 0.00 $ 0.00 780.81 $ 30,795.15 RELEASES FROM SOLID WASTE MANAGEMENT UNITS Review demonstration to terminate compliance period 0 N/ A 0.00 0.00 4.00 0.10 $ 159.64 $ 0.00 $ 0.00 0.00 $ 0.00 Review and approve proposed sampling procedures 13 N/ A 0.00 0.00 2.00 0.00 $ 78.88 $ 0.00 $ 0.00 26.00 $ 1,025.44 Subtotal varies 0 0.00 0.00 varies varies varies 0.00 0.00 26.00 $ 1,025.44 CLOSURE AND POST CLOSURE Review closure plans N/ A 0 0.00 0.00 15.00 0.00 $ 591.60 $ 0.00 $ 0.00 0.00 $ 0.00 Review closure plan amendment notifications N/ A 4 0.00 0.00 2.00 0.00 $ 78.88 $ 0.00 $ 0.00 7.80 $ 307.63 Review partial or final closure notifications and closure plans ( interim status facilities) 19 9 0.00 0.00 2.00 0.00 $ 78.88 $ 0.00 $ 0.00 56.00 $ 2,208.64 Review demonstration for extension for treatment storage, or removal of hazardous waste 4 2 0.00 0.00 2.00 0.00 $ 78.88 $ 0.00 $ 0.00 11.20 $ 441.73 Review demonstration for extension of closure period 4 2 0.00 0.00 1.00 0.00 $ 39.44 $ 0.00 $ 0.00 5.60 $ 220.86 Review demonstration for receiving non hazardous waste 1 0 0.00 0.00 0.50 0.00 $ 19.72 $ 0.00 $ 0.00 0.70 $ 27.61 Review closure certifications 19 9 0.00 0.00 4.00 0.00 $ 157.76 $ 0.00 $ 0.00 112.00 $ 4,417.28 Review survey plat 1 4 0.00 0.00 1.00 0.00 $ 39.44 $ 0.00 $ 0.00 4.50 $ 177.48 Review post closure plan N/ A 0 0.00 0.00 15.00 0.00 $ 591.60 $ 0.00 $ 0.00 0.00 $ 0.00 Review post closure plan amendment notifications and amended plans N/ A 1 0.00 0.00 2.00 0.00 $ 78.88 $ 0.00 $ 0.00 2.80 $ 110.43 Review post closure plan modifications N/ A 1 0.00 0.00 2.00 0.00 $ 78.88 $ 0.00 $ 0.00 1.40 $ 55.22 Review resubmitted plans N/ A 0 0.00 0.00 2.00 0.00 $ 78.88 $ 0.00 $ 0.00 0.14 $ 5.52 Review petition to extend or reduce the post closure care period N/ A 1 0.00 0.50 1.00 0.00 $ 66.34 $ 0.00 $ 0.00 2.10 $ 92.87 Review hazardous waste disposal records 2 7 0.00 0.00 1.00 0.00 $ 39.44 $ 0.00 $ 0.00 9.00 $ 354.96 Review hazardous waste notation certification 2 7 0.00 0.00 1.00 0.00 $ 39.44 $ 0.00 $ 0.00 9.00 $ 354.96 Review post closure care certification 0 0 0.00 0.00 4.00 0.00 $ 157.76 $ 0.00 $ 0.00 0.00 $ 0.00 Subtotal varies varies 0.00 varies varies varies varies $ 0.00 $ 0.00 222.24 $ 8,775.19 91 EXHIBIT 9 ( continued)

ESTIMATED ANNUAL AGENCY BURDEN AND COST Number of Respondents Hours and Costs per Respondent or Activity Total Hours and Costs Legal Manager Technical Clerical Labor Capital/ Total Total $ 60.42/ $ 38.35/ $ 26.91/ $ 16.36/ Cost Startup O& M Hours per Cost per INFORMATION COLLECTION ACTIVITY Permitted Interim hour hour hour hour $/ Year Cost Cost Year Year FINANCIAL REQUIREMENTS Review increases in sum amounts, if cost estimate modified, and additional reports of financial conditions 0 0 0.00 0.00 8.00 0.00 $ 315.52 $ 0.00 $ 0.00 0.00 $ 0.00 Review new estimates and instruments 0 0 0.00 0.00 7.50 0.00 $ 295.80 $ 0.00 $ 0.00 0.00 $ 0.00 Review annual closure cost updates to reflect inflation 0 0 0.00 0.00 0.50 0.00 $ 19.72 $ 0.00 $ 0.00 0.00 $ 0.00 Review liability claim notifications 0 0 1.00 0.00 2.00 0.00 $ 136.40 $ 0.00 $ 0.00 0.00 $ 0.00 Review and approve or deny petition for variance 0 59 0.00 0.50 1.00 0.00 $ 66.34 $ 0.00 $ 0.00 88.50 $ 3,913.77 Review revisions due to plan changes 56 274 0.00 0.00 8.00 0.00 $ 315.52 $ 0.00 $ 0.00 2,640.00 $ 104,121.60 Review updated financial test and corporate guarantee information 1,390 3,624 0.00 0.00 8.00 0.00 $ 315.52 $ 0.00 $ 0.00 40,112.00 $ 1,582,017.28 Review bankruptcy notifications 28 72 1.00 0.00 2.00 0.00 $ 136.40 $ 0.00 $ 0.00 300.00 $ 13,640.00 Review State assumptions of responsibility/

required mechanism documentation 0 0 0.00 0.00 2.00 0.00 $ 78.88 $ 0.00 $ 0.00 0.00 $ 0.00 Review corrective action financial assurance 0 0 1.00 0.00 8.00 0.00 $ 373.04 $ 0.00 $ 0.00 0.00 $ 0.00 Subtotal varies varies varies varies varies 0.00 varies $ 0.00 $ 0.00 43,140.50 $ 1,703,692.65 PERMIT CONDITIONS Review submitted information 173 0 0.00 0.25 1.00 0.10 $ 54.77 $ 0.00 $ 0.00 233.55 $ 9,475.47 Review notice of planned physical alterations or additions 155 0 0.00 0.00 0.50 0.10 $ 21.60 $ 0.00 $ 0.00 93.00 $ 3,348.62 Review notice of planned changes or activities 78 0 0.00 0.25 0.50 0.10 $ 35.05 $ 0.00 $ 0.00 66.30 $ 2,734.02 Review letter certifying compliance 39 0 0.00 0.25 0.50 0.10 $ 35.05 $ 0.00 $ 0.00 33.15 $ 1,367.01 Review monitoring reports 1171 0 0.00 0.00 5.00 0.00 $ 197.20 $ 0.00 $ 0.00 5,855.00 $ 230,921.20 Review reports of compliance or noncompliance 13.33 0 0.00 0.00 1.00 0.10 $ 41.32 $ 0.00 $ 0.00 14.66 $ 550.85 Review information concerning a release,

fire, or explosion 13 0 0.00 0.00 0.50 0.10 $ 21.60 $ 0.00 $ 0.00 8.00 $ 287.98 Review notices and reports of noncompliance 13 0 0.00 0.00 0.50 0.10 $ 21.60 $ 0.00 $ 0.00 8.00 $ 287.98 Review reports of other noncompliance 27 0 0.00 0.00 0.50 0.10 $ 21.60 $ 0.00 $ 0.00 16.00 $ 575.96 Review corrected information 13 0 0.00 0.00 0.50 0.25 $ 24.43 $ 0.00 $ 0.00 10.00 $ 325.65 Subtotal varies 0 0.00 varies varies varies varies $ 0.00 $ 0.00 6,337.65 $ 249,874.74 TOTAL varies varies varies varies varies varies varies varies varies 52,419.52 $ 2,069,585.06 92 EXHIBIT 10 TOTAL ESTIMATED AGENCY BURDEN AND COST SUMMARY Total Total Hours per Cost per EXHIBIT Year Year General Facility Standards 68 2,695 Recordkeeping Requirements 1,844 72,727 Contingency Plan and Emergency Procedures 781 30,795 Releases from Solid Waste Management Units 26 1,025 Closure and Post Closure Requirements 222 8,775 Financial Requirements 43,141 1,703,693 Permit Conditions 6,338 249,875 TOTAL 52,420 $ 2,069,585 EXHIBIT 11 TOTAL AVERAGE RESPONDENT BURDEN Average Average Reporting Recordkeeping Burden Burden EXHIBIT ( Hours) ( Hours)

Exhibit 1 General Facility Standards 113 113 Exhibit 2 Operating Record 0 140 Exhibit 3 Contingency Plan and Emergency Procedures 0 0 Exhibit 4 Releases from Solid Waste Management Units 1 0 Exhibit 5 Closure and Post Closure Requirements 45 0 Exhibit 6 Financial Requirements 12 0 Exhibit 7 Permit Conditions 13 0 TOTAL 185 254 93 6( e) BOTTOM LINE BURDEN HOURS AND COSTS Exhibits 8 and 10 show the aggregate burden and cost to respondents and the government, respectively. The bottom line burden to respondents over three years is 1,956,936 hours, with a cost of $ 137,719,716. The bottom line burden to the Agency over three years is 157,260 hours, at a cost of $ 6,208,755.

6( f) REASONS FOR CHANGE IN BURDEN This ICR is a comprehensive description of the total respondent burden for all activities related to general facility operating requirements, recordkeeping requirements, contingency plan and emergency reporting requirements, releases from solid waste management units, closure/ post closure requirements, financial requirements, corrective action management unit requirements, and conditions applicable to all permits.

The respondent universe numbers in this ICR are lower than those estimated for the 2002 version of this ICR. Some of this decrease is due to the ongoing consolidation and contraction of the hazardous waste treatment, storage, and disposal industry, and some is due to more accurate RCRAInfo data.

Because of these revisions, the total bottom line burden to respondents has decreased over the previous ICR. Whereas the previous ICR estimated a total annual respondent burden of 719,059 hours, this ICR estimates a total annual respondent burden of 652,312. EPA believes that this lower burden reflects a more accurate portrait of the existing burden on the regulated community.

6( g) BURDEN STATEMENT The annual public reporting burden for this collection of information is estimated to average 185 hours per respondent, and the annual public recordkeeping burden for this collection of information is estimated to average 254 hours per respondent ( see Exhibit 11). Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number EPA HQRCRA 2005 0014, which is available for online viewing at www. regulations. gov, or in person viewing at the RCRA docket in the EPA Docket Center ( EPA/ DC), EPA West, Room B102, 1301 Constitution Avenue, NW, Washington, D. C. The EPA Docket Center Public Reading Room is open from 8: 30 a. m. to 4: 30 p. m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is ( 202) 566 1744, and the telephone number for the RCRA is ( 202) 566 0270. An electronic version of the 94 public docket is available at www. regulations. gov. This site can be used to submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronically. When in the system, select " search," then key in the Docket ID Number identified above. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, D. C. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA HQ RCRA 2005 0014 and OMB Control Number 2050 0120 in any correspondence.