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;

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

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:

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

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:

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;

No later than the submission of the certification of closure, the owner
or operator must submit to the Regional Administrator a survey plat;

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;

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;

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

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.

6.	ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a)	ESTIMATING RESPONDENT BURDEN

	Exhibits 1 through 7 below 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.  Exhibits 11 and 12 present the number of
hours for State Agencies.

6(b)	ESTIMATING RESPONDENT COSTS6(a)ESTIMATING RESPONDENT BURDEN

LABOR COSTS

For the private sector, EPA estimates an average hourly respondent labor
cost (including fringe and overhead) of $126.89 for legal staff, $75.00
for managerial staff, $55.89 for technical staff, and $33.62 for
clerical staff.  These wage rates are based on the rates from last
renewal, multiplied by an inflation rate of 3.4% to bring them up to
2016 rates.

	For State Agencies, EPA estimates an average hourly respondent labor
cost (including fringe and overhead) of $60.57 for legal staff, $56.86
for managerial staff, $34.02 for technical staff, and $21.70 for
clerical staff.  These labor costs were obtained from EPA ICR Number
0976.16.

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.

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.

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 $0.49 per one
ounce letter, $5.75 per submittal for flat-rate by priority mail, and
$12.20 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 $1,000 per
analysis for non-commercial facilities and $400 per analysis for
commercial facilities.

In Exhibit 5, EPA estimates lump-sum 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 Exhibits 9 and 10.  EPA
estimates the Agency hour and cost burden associated with the
information collection requirements covered in this ICR.  EPA estimates
an average hourly labor cost of $86.56 for legal staff (GS15, Step 5),
$76.38 for managerial staff (GS-15, Step 1), $54.94 for technical staff
(GS-13, Step 1), and $23.44 for clerical staff (GS-06, Step 1).  To
derive these hourly estimates, EPA referred to the General Schedule (GS)
Salary Table 2016.  This publication summarizes the unloaded (base)
hourly rate for various labor categories in the Federal Government.  EPA
then applied the standard government overhead factor of 1.6 to the
unloaded rate to derive loaded hourly rates.

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.

TABLE 1

Estimated Universe of Facilities Affected by General Facility Standard
Requirements

Permitted

Interim Status

Total

All Facilities (Operating & Closed/Post Closed)

1,427

395

1,822

Operating Facilities

707

28

838

     Commercial

310

5

315

     Non-Commercial

397

             23

420

Closed Facilities (New Annual Closures)

                134

13

147

Post-Closed Facilities

586

88

674

Land Disposal Facilities (Op. & Cl/P-Cl)

609

229

838

     Operating LDFs

              72

                            3

75

     Closed LDFs (New Annual Closures)

7

4

                         11

     Post-Closed LDFs

560

80

640

     Closed or Post-Closed LDFs

583

                          226

809

Facilities with Incinerators

58

                            0

                    58

Treatment and Storage Only Facilities

               665

                          25

                  690

New Interim Status

 NA

0

 0

New Part B Permits (Incl. New Construction)

7

 NA

 7

Facilities Who Intend to Close Annually

                 58

                            4

                      62

LDFs Who Intend to Close Annually

                    9

                              0

                         9

Facilities Who Intend to Post-Close Annually

                  8

                            0

                       8

LDFs Who Intend to Post-Close Annually

                    2

                              0

                         2

Facilities Completing Post-Closure Annually

5

0

5

GENERAL FACILITY OPERATING REQUIREMENTS

(1)	Foreign Shipment Import Report

Based on previous experience, EPA estimates that approximately six
percent of the operating respondent universe 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.  These commercial facilities must submit a one-time
notice to these generators before accepting their waste.

(3)	Notice of Part 264 or Part 265, and Part 270 Requirements

EPA estimates that approximately one percent of all 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 commercial incinerator and land
disposal facilities will conduct testing 50 times a year, while the
remaining operating 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 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, 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.  All operating facilities are required to
record problems in an inspection log.

(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.  Newly constructed facilities
with Part B permits will have to read the regulations and collect
information.

All operating and newly constructed 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 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.

RECORDKEEPING REQUIREMENTS

	Operating Record

	Excluding the inspection information requirements, only operating
facilities are required to comply with the operating record
recordkeeping requirements.  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:

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 will be
required to comply with this regulation.

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 will be
required to comply with this regulation.

Both operating and post-closure facilities are required to maintain
updated inspection information in the operating record (§§264.73(b)(5)
and (265.73(b)(5)).Only land disposal facilities and incinerator
facilities are required to collect and record monitoring data
(§264.73(b)(6)) in the operating record.

Only land disposal facilities and incinerator facilities are required to
collect and record monitoring data (§264.73(b)(6)) in the operating
record.

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, including non-commercial facilities,
will need to maintain, in the operating record, the notice to
generators.

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 expects that all permitted and interim status
facilities will have to maintain closure cost estimates.  Permitted and
interim status operating land disposal facilities will also need to
maintain post-closure cost estimates.

All operating land disposal 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 disposal restriction, or a certification, and the applicable
notice required by the generator (§§264.73(b)(10) and (265.73(b)(10)).

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 will need to maintain (i.e., photocopy and file) this
information in the operating record.

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 had determined that 95 percent of
the operating universe 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.

CONTINGENCY PLAN AND EMERGENCY REPORTING REQUIREMENTS

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
Application, 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.

Emergency Reporting And Recordkeeping

	Based on program experience, the Agency estimates that one percent of
all facilities with experience an emergency situation each year that
will require the help of State or local authorities with

designated response roles.  Therefore, emergency coordinators at
permitted and 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 will have a release, fire, or explosion for which
the emergency coordination determines that is 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 and 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 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.

RELEASES FROM SOLIE 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 to develop and submit sampling
procedures to EPA (§264.97(g)).

CLOSURE AND POST-CLOSURE REQUIREMENTS

Reading the Regulations

	The only facilities that are expected to read the closure requirements
will be the newly permitted facilities.  Land disposal facilities are
expected to read the post-closure regulations.

Closure Plans

	Since existing interim status and permitted facilities have already
developed closure and post-closure plans, activities associated with
developing closure/pose-closure plans apply to newly interim

status facilities only.  EPA expects no new facilities to develop and
submit closure plans.

Closure Plan Amendment

	Based on previous experience, EPA estimates that five percent of
operating or closing interim

status facilities, such as facilities converting waste piles to
containment building, 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 and
discussed in the Hazardous Waste Part B Permit Application, Special

Permits, and Permit Modifications ICR, #1573.

Partial Closure and Final Closure Notification

	Owners and operators of all permitted and interim status facilities who
intend to close their facility annually must notify EPA of closure.  In
addition, owners and operators of the interim status facilities must
also submit their closure plans to EPA.

Extensions and Allowances During the Closure Period

	Of the total number of facilities that will be closing, EPA estimates
that 20 percent 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 will request an extension for
completing closure activities.  EPA also estimates that an additional
five percent of all closing 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)).

Closure Certification

	EPA estimates that all of the permitted and interim status facilities
that will be closing annually will complete a certification of closure.

Survey Plat

	EPA estimates that 50 percent of the land disposal facilities that will
be closing annually 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 will prepare a post-closure plan
annually.  In addition to preparing a post-closure plan, all permitted
and interim status land disposal facilities must also maintain (i.e.,
photocopy, file, and update) the post-closure 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 post-closure plans.  EPA
expects that ten percent of interim status facilities that are
undergoing post-closure 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 owners and operators who close their land disposal facilities
annually must submit hazardous waste disposal records.

(12)	Hazardous Waste Notation Certification

All owners and operators who close their land disposal facilities
annually 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.

FINANCIAL REQUIREMENTS

(1)	Reading the Regulations

All operating and newly constructed 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
permitted 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 will submit financial assurance documentation
for corrective action.  EPA estimates that ten percent of these
facilities per year 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 will
need to adjust estimates annually to reflect inflation.  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.

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.  Finally, all facilities covered under the financial test will
need to submit annual updates; accordingly, 50 percent of existing
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.  EPA estimates that one percent of all facilities will
become bankrupt and will need to submit evidence of insurance.

(6)	Other Requirements

For activities relating to State-required mechanisms and State
assumption of responsibility, EPA estimates that one percent of interim
status facilities (permitted facilities are included in ICR #1573), will
be included in the respondent burden estimate.  EPA estimates that of
these 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.

CONDITIONS APPLICABLE TO ALL PERMITS

EPA estimates that each year 20 percent of permitted 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 will annually
submit a notice of physical alterations or additions.  Of these
facilities, 50 percent will submit a notice of planned changes that may
result in noncompliance with permit requirements.  Of these facilities,
50 percent 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 must submit monitoring reports.  EPA further estimates that
one percent 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 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 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 will submit
amended information that was incorrect or omitted during an initial
submittal.

6(e)	BOTTOM LINE BURDEN HOURS AND COSTS

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 619,997
hours, at an annual cost of $520,867.

6(f)	REASONS FOR CHANGE IN BURDEN

 ADVANCE \d12 		There is no change in burden hours in this renewal.

6(g)	BURDEN STATEMENT

The annual public reporting burden for this collection of information is
estimated to average 324 hours per respondent, and the annual public
recordkeeping burden for this collection of information is estimated to
average 88 hours per respondent. 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 EPA 's need for this information, the accuracy of the
provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID Number
EPA-HQ-RCRA-2015-0606, 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<PHONE_NUMBER>,
and the telephone number for the RCRA Docket is<PHONE_NUMBER>.  An
electronic version of the public docket is available at
www.regulations.gov.  This site can be used to submit or view public
comments, access the index listing of the contents of the public docket,
and to access those documents in the public docket that are available
electronically.  When in the system, 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-2015-0606 and OMB Control Number 2050-0120 in any
correspondence.

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Comment Info: =================

General Comment:Vaping is a healthier option to smoking, and has helped me to quit smoking cigarettes, which is widely known to cause lung cancer. A 75 day comment period is insufficient time for the vaping industry and the wider vaping community to comment on the proposed deeming regulations. I would respectfully request that the period for comment be extended to 180 days..


3.) The proposed Poultry Processing Effluent Limitations Guidelines and Pretreatment Standards published on April 24, 1975 at 80 FR 18150 are attached.

4.) The January 31, 1992 court approved consent decree between EPA and NRDC is attached.