(#83) Records of Sampling and Analysis of PCB Bulk Product Waste: Persons disposing of PCB bulk product waste in solid waste landfills must keep records of the sampling and analysis of PCB bulk product waste as well as required notifications. The records must be maintained for three years from the date of their creation and made available to EPA upon request [§761.62(b)(5)].

      (#84) Attempts to Secure Disposal: The regulations include a provision that would grant individuals an automatic one-year extension to store waste beyond the one-year deadline for disposal if certain conditions are met. One of the conditions is that the individual must maintain a written record of his efforts to secure disposal capacity until the waste is disposed. These records must be made available for inspection by the EPA [§§761.65(a)(2)(ii), and (3)].

      (#85 - 86) Spill Prevention, Control, and Countermeasure (SPCC) Plan: Owners/operators of facilities using PCB storage containers, as per 29 CFR 1910.106, must prepare SPCC plans. SPCC plans are also necessary to temporarily store containers of PCB liquids >50 ppm. An SPCC plan is necessary when an individual has not previously stored liquid PCBs on a temporary basis [§§761.65(c)(1)(iv) and (7)(ii)].

      (#87) Records of PCB Items in Stationery Storage Containers: PCB Items shall be dated when removed from service for disposal. For each batch of PCBs added to storage containers, as per §761.65(c)(7), owners of the containers shall maintain a record that includes the quantity of the batch and date the batch was added to the container. The record shall also include the date, quantity, and disposition of any batch of PCBs removed from the container [§761.65(c)(8)].

      (#88) Records of Storage for Disposal of PCBs and PCB Items: Owners/operators of commercial storage facilities must establish and maintain records, as per §761.180, for the storage and disposal PCBs and PCB Items >=50 ppm [§§761.65(c)(10) and .180].

      (#89) Incinerator Records: Owners and operators of incinerators must keep records 5 years after the date of collection of the quantity of PCBs fed into the incinerator and the rate at which the PCBs are fed, the temperature of the incineration process, the results of continuous monitoring of combustion products for oxygen and carbon monoxide, at a frequency specified by EPA, and information on the weight of solid residue generated by the incinerator [§§761.70(a)(3), (4), and (7); (c); and .180(c)].

      (#90) High Efficiency Boiler (HEB) Feed Rate and Emissions Record Retention: Persons burning liquids other than mineral oil dielectric fluid, containing PCBs between 50 and 500 ppm, in an approved HEB must retain the following records for a period of 5 years: the quantity of low concentration PCBs burned in the boiler each month, monthly waste analysis records, and the data required in §§761.71(b)(1)(vi) and (b)(1)(vii), which includes the carbon monoxide concentration and excess oxygen percentage in the stack gas; the fuel feed rate; waste fluid feed rate; and the quantities of fuel and waste fluid fed to the boiler [§§761.71(a)(1)(vi) and (vii), (a)(4), (b)(1)(vi) and (b)(1)(vii), (b)(5), and .180(e)].

      (#91) PCB Disposal Using Scrap Metal Recovery Ovens and Smelters: The use of scrap metal recovery ovens and smelters is authorized for disposing of PCB-contaminated items when the equipment meets certain operating parameters and conditions. One of these parameters addresses the temperature of the hearth (i.e., at least 1,000º C when charged with PCB Items). Operators are required to record the temperature and retain the data at the facility for three years from the date each charge is introduced. Because these devices are considered disposal units, owners of the equipment must meet all applicable recordkeeping requirements in 40 CR 761 Subparts J and K (e.g., maintain annual document log and annual records) [§§761.72(a)(9) and (b)(6)].

      (#92) Chemical Waste Landfill Records: Owners/operators of chemical waste landfills that dispose of PCBs must maintain records at least 20 years after a facility ceases disposal operations of all PCB disposal operations, including PCB concentration in liquid wastes, the three-dimensional burial coordinates for PCBs and PCB Items, water sampling and analysis (i.e., samples of surface and ground water at locations and frequencies specified by EPA in their approvals), and additional records. The samples must be analyzed for PCBs, pH, specific conductance, and chlorinated organics [§§761.75(b)(6)(iii) and (b)(8)(iv) and .180(d)].

      (#93 - 94) Decontamination Activities: If individuals follow self-implementing decontamination procedures (and maintain the required records), they will not need to obtain a PCB disposal approval, as is currently the case, to decontaminate for continued use or distribution in commerce items that had been contaminated with PCBs. Test and validation results of performance-based decontamination activities using PODFs and VADFs must be retained [Subpart T, §761.79(d)(4)]. Also, individuals that conduct PCB decontamination activities must maintain records of sampling activities that show sampling locations, analytical results, and information about the wastes generated by a decontamination process. These records must be retained at the site of decontamination for a period of three years for inspection by EPA [§§761.79(f)(1) and (2)].

Subpart E -- Exemptions

      (#95 - 96) Manufacture of PCBs and Processing/Distributing of Limited Quantities of PCBs or PCBs in Waste Materials for R&D: Under the class exemptions for manufacturers of PCBs and processors and distributors of limited quantities of PCBs and PCB analytical reference samples derived from waste materials for purposes of research and development, facilities seeking the exemption must maintain records on the source(s) of PCBs, the person(s) to whom the PCBs were shipped, and the amount(s) of PCBs received, processed and distributed in commerce annually. These records must be retained for a period of either three years after ceasing the processing and/or distributing operations or 5 years [§§761.80(e)(5), (g)(1), and (i)(7)].

Subpart G -- PCB Spill Cleanup Policy

      (#97 - 98) Records of Spill Cleanup and Delays: Parties responsible for cleaning up PCB spills must maintain documentation of the cleanup activities and certification of the documentation for five years. Owners of PCB spills who have delayed cleanup because of circumstances such as civil emergency; hurricane, tornado, or other similar adverse weather conditions; lack of access due to physical impossibility; or emergency operating conditions, must keep records documenting the fact that circumstances precluded rapid response [§§761.125(b)(3), (c)(1) and (c)(5) and .61(a)(9)].

Subpart J -- General Records and Reports

      (#99) The Annual Document Log for PCBs and PCB Items: Owners/operators of PCBs and PCB Items in service or projected for disposal must maintain annual records and a written annual document log for three years after the PCB activities cease. The records must include signed manifests, Certificates of Disposal, records of inspections and cleanups, facility and Item identification information, total number of Items, telephone records, and Item transfer information. Individuals must also collect and maintain documents, correspondence, and data pertaining to storage/disposal of PCBs that have been provided to as well as received from any state or local government agency and any application/correspondence submitted to local, state, or federal permitting authorities [§§761.180(a), (a)(4), (b), and (f); and 761.65(c)(5)].

      (#100) Recordkeeping of Monitoring Data for Inadvertently Generated PCBs: Any importers of or manufacturers generating PCBs in excluded manufacturing process must maintain for a period of 3 years after ceasing process operations or importation, or for seven years, whichever is shorter, monitoring or analytical data used to determine compliance of import, manufacture, process, distribution in commerce, or use of chemicals containing inadvertently generated PCBs. The manufacturers' records must include the reaction(s) believed to be generating PCBs, the levels of PCBs generated, and the levels of PCBs released. Importer records must include the reaction(s) believed to be generating PCBs, the levels of PCBs generated, the basis for all estimations of PCB concentrations, and the name and qualifications of the person performing the analyses. Monitoring data must include the method of analysis, the results of the analysis, description of the plan matrix, names of the analysts, date and time of the analysis, and number for the lots from which the samples were taken [§§761.185(c)(2), (d), and .193(a) and (b)].

Subpart K -- PCB Waste Disposal Records and Reports

      (#101 - 102) Recordkeeping of Manifests and Certificates of Disposal: PCB waste generators must retain a written record of all manifests and telephone and other confirmations regarding manifesting communications, which are to be included in the annual document log, in accordance with §761.180 [§761.210(a)(3) and (e)(4)]. Each transporter, storer, and disposer must retain one copy of each manifest or shipping paper [§§761.211(d)(2), (e)(5), (f)(1)(iv), (f)(3)(ii), (f)(4)(ii), 761.213(a)(2)(v), and (b)(5)]. Each PCB waste-handling facility that initiates or receives a manifest must file and maintain a copy of each manifest. The generator of PCB waste shall keep a copy of each manifest until the generator receives a signed copy from the designated commercial storage or disposal facility that received the PCB waste. The generator, transporter, and owners/operators of the storage and disposal facilities shall keep a copy signed by the storer or disposer for at least three years from the date the PCB waste was accepted by the initial transporter [§761.214(a),(b), and (c)]. Generators and commercial storers of PCB waste must also maintain a copy of each Certificates of Disposal received from disposers [§761.218(c) and (d)].

Subpart T -- Comparison Study for Validating a New Performance-Based Decontamination Solvent Under §761.79(d)(4)

      (#103) Results of Validation Studies: Persons conducting studies to validate a new performance-based decontamination solvent must record the testing parameters and experimental procedures in standard operating practices and must affix in an appendix the results of the validation study [§761.398(c)].

 Respondent Activities

      Typical respondents include: manufacturers, processors, distributors of PCBs in commerce; owners of PCB-contaminated equipment and PCB Items; PCB waste generators, transporters, commercial storers, and disposers (i.e., PCB waste handlers); owners/operators of laboratories; and other users of PCBs. All respondents must read the rule and determine which provisions are applicable to their operations; plan and modify their procedures to come into compliance with the rule; provide training to appropriate staff; process, compile, and review information for accuracy and appropriateness; and record, disclose, and/or report the required information. Specific responsibilities for each type of respondent are as follows:

      Manufacturers, Processors, Distributors in Commerce of PCBs: Individuals who are included in the manufacturing exclusions must gather and document data on raw materials and intermediates used in the manufacturing process; analyze the reactions and conditions at issue; survey the facility site and specific equipment to determine and document where and to what extent PCBs could be released into air, water, and end products. Individuals who seek exemptions from the manufacturing, processing, or distribution in commerce bans must document the amount of PCBs affected by the exemption request; describe the manufacturing/processing/distribution in commerce processes; comply with additional statutory requirements of TSCA section 6(e)(3)(B); quantify the economic consequences of an exemption denial; and provide specifics about servicing and use activities, develop certification statements, and complete other paperwork.

      Owners of PCB Items and PCB-Contaminated Equipment: There are various requirements for owners of the many different types of PCB Items. Owners of newly discovered PCB Transformers must register their Transformers with EPA and building owners, providing information on the number of PCB Transformers, their locations, and his or her name, address, telephone number and signature, or that of the authorized representative, which certifies the accuracy of the submitted information. Owners of these PCB Transformers must record inspection and maintenance information and file and maintain the data and information in the annual log about any transfer of ownership of a PCB Transformer. Owners of reclassified transformers, voltage regulators, electromagnets, and switches must maintain records showing that they followed the required reclassification procedures. When testing is required, equipment owners must keep records of the pre-and post-reclassification PCB concentration measurements. They must also provide records of the reclassification procedure to EPA and recipients of the equipment, upon request.

      Individuals who discover fire-related incidents that result from a rupture of a PCB Transformer or PCB Voltage Regulator must report the incident to the National Response Center. Owners of PCB Items distributed in commerce for reuse must retain records in the annual document log of any transfers of ownership. Owners of large capacitors located in protected locations who choose not to mark these units individually must maintain records for identifying the Capacitors.

      Owners of PCB Articles stored for reuse must maintain records of the Articles. Some owners of PCB Items may want to obtain approval to store equipment for disposal beyond the current one-year limit, or to exceed the five-year limit for the storage of equipment for purposes of reuse. In those cases, they would be required to contact the appropriate EPA Regional Administrator and compile and submit the requisite information. Utilities and other owners of PCB-contaminated equipment must create or modify their Spill Prevention, Control, and Countermeasure Plan (SPCC) if temporarily storing PCB liquids. Owners of PCB Items (in addition to PCB Transformers) are also required to record and maintain records of inspection, maintenance activities, cleanup, disposal, and certain decontamination activities. When PCB Items are removed from service for disposal, the owners of the Items must place the date on the item.

      When owners of PCB Items generate wastes that must be handled as a PCB remediation or bulk product waste, they will need to determine which of the available disposal options (i.e., self-implementing, performance-based, or risk-based options) should be used to address their disposal needs. These disposal options will require compliance with various reporting and recordkeeping requirements.

      PCB Waste Handlers: PCB waste handlers must respond to the notification requirements by filling out a brief one-time form (EPA Form 7710-53) (see Appendix D) and filing and maintaining the information. Individuals who handle PCB-Contaminated liquid wastes must notify chemical waste landfill owners of the certain specified properties of the waste, and the landfill must obtain written approval from the EPA Regional Administrator before disposing of these wastes. Individuals disposing of PCB waste, such as in a high efficiency boiler, must notify the Regional Administrator about the activity.

      Waste handlers attempting to secure disposal must maintain records of these attempts to be granted an automatic one-year extension to store wastes beyond the one-year deadline for disposal. If waste handlers change their waste-handling activities, they are also required to file an amended TSCA PCB notification form (EPA Form 7710-53, Appendix D), which provides information on the amended activity.

      To handle PCB remediation wastes under the self-implementing option, site owners must notify the EPA Regional Administrator and other authorities about the remediation activities and submit a written certification to the Regional Administrator that site sampling and waste characterization plans are on file at a specified location. Generators of bulk PCB remediation waste must provide written notice to off-site waste handling facilities about the quantities that will be shipped to the facilities and the highest concentration of PCBs in the shipment. Property owners with remediation sites that require the use of a fence or a cap must submit to EPA a certification that the property deed has a notation to that effect. The recordkeeping activities for individuals using the self-implementing remediation provisions for disposing of PCB remediation waste include retaining written waivers received from EPA or other authorities for five years, maintaining records of sampling plans and characterization procedures, recording in the deed any sites that require the use of a fence or cap, and keeping records of cleanup activities for five years. PCB waste handlers are required to record and maintain records, such as calculations used and validation and sampling results, on certain decontamination activities.

      Any person using the risk-based disposal option to dispose of PCB bulk product waste must apply in writing to EPA to do so. Persons handling PCB bulk product waste must maintain records of sampling and analysis for three years. Any person with a spill involving one pound or more of PCBs must report the spill to the National Response Center.

      PCB waste generators must provide manifests and/or shipping papers that will accompany the waste shipment to the transporters and to the disposers. When a generator uses an independent transporter, he or she must confirm either by phone or some other convenient means that the receiving PCB storage and/or disposal facility actually received the wastes. Generators, storers, transporters, and disposers must sign and retain copies of the manifests when they handle a shipment of PCB waste. Generators must submit exception reports to EPA when they fail to receive confirmation from the disposer that a shipment of PCB waste has been properly disposed of.

      Persons seeking coordinated approval for their waste-handling activities are required to submit requests for approval to the EPA Regional Administrator. These individuals are required to adhere to recordkeeping and reporting requirements, submit additional information as required by EPA, or submit an application for a TSCA PCB approval, and notify the Regional Administrator of any changes relating to the waste management documents that serve as the basis for the coordinated approval.

      Owners and Operators of PCB Disposal Facilities: These respondents are expected to complete the EPA approval process: develop a description and a plan for a demonstration of the system; conduct demonstration and complete an analytical assessment of the results; and record/disclose information; submit a demonstration report; and develop standard operating procedures, a closure plan and financial assurance that cover the closure costs of the facility. Operators of approved chemical waste landfills, incinerators, or alternate PCB disposal technologies must also notify state and local officials prior to the first use of the technology, and if requested by a state or local government, provide annual notice of the quantities and types of PCBs disposed of during the year.

      Owners/operators of incinerators must keep records regarding the PCBs fed into the incinerator and the operating conditions of the equipment. Owners of chemical waste landfills must collect and analyze samples of surface and ground water at EPA-approved locations. To dispose of residual PCB waste in a scrap metal recovery oven or smelter, the owner must obtain a permit or have the unit approved by the EPA Regional Administrator, and comply with applicable reporting requirements of Subparts J and K, such as recording operating temperatures. Persons burning PCB liquids in high efficiency boilers must retain records of the quantities burned, waste analysis results, and operational conditions of the boiler.

      Owners and operators of PCB disposal facilities are required to submit annual reports to EPA. PCB waste disposers must submit unmanifested waste reports to EPA when they accept a shipment of PCB waste without an accompanying manifest. Disposers also must submit discrepancy reports when the PCB waste they receive for disposal does not match the description of the manifest that accompanies it. Owners/operators of disposal facilities must submit Certificates of Disposal to waste generators when a disposal is complete for each item on a manifested waste shipment. The disposers must maintain all of the above records. Owners/operators of PCB disposal facilities also are required to attempt to contact the generator when they receive a shipment of PCB waste that does not include a manifest.

      Owners/Operators of Commercial Storage Facilities: These respondents must complete the EPA approval process; i.e., submit closure plans and financial assurances to EPA. They must notify the appropriate EPA Regional Administrator when it is necessary to exceed the one-year storage limitation, to modify the facility, or amend the financial assurance mechanism. For subsequent extensions to the storage limitations, the requestor must submit specific justification for the extension and indicate measures he is taking to secure disposal. Owners of commercial storage facilities must record and maintain records associated with PCB equipment inspections and cleanups. They must also submit a summary report to EPA of the type and quantity of PCB wastes that were managed at the facility during the preceding year. Commercial storers of PCB wastes must submit Exception Reports when they transfer the PCBs or PCB Items to the disposer within 9 months from the date of removal of the Item from service or when they have not received within 13 months from the date of removal from service for disposal a Certificate of Disposal confirming the disposal of the Item, as applicable.

      Users of PCB waste storage containers can use containers other than those prescribed by ANSI for nuclear criticality safety if the user demonstrates that such containers are protective of human health and the environment. Managers of large bulk PCB storage containers shall have a record that includes for each batch of PCBs the quantity of the batch and the date the batch was added to the container.

      If owners of storage facilities change their waste-handling activities, they would also be required to file an amended TSCA PCB notification form. EPA will approve changes in ownership of storage facilities if the transferee has established financial assurance for closure and the transferor has resolved any deficiencies, such as with operations, closure plans, and cost estimates.

      Owners/operators of PCB commercial storage facilities are required to attempt to reconcile, with either the generator and/or transporter any significant discrepancy in the manifest. Owners/operators of PCB commercial storage facilities are required to attempt to contact the generator when they receive a shipment of PCB waste that doesn't include a manifest.

      Laboratories: Persons conducting R&D on PCB disposal are required to obtain an EPA identification number and notify EPA and other authorities before conducting the R&D activities. R&D facilities must also manifest wastes, as applicable, and submit requests to EPA when exceeding the specified limits for the PCBs used. R&D facilities can also submit requests for extensions in the duration of the activity. Facilities can submit exemption petitions to qualify for the class exemptions to manufacture PCBs for disposal-related R&D activities or to process or distribute PCBs or PCB analytical reference samples derived from waste materials. Facilities seeking the exemption must maintain records of the activities for the annual log. Laboratories conducting self-implementing R&D for disposal activities must maintain annual records, as well.

      R&D facilities seeking coordinated approvals may submit requests for approval to the EPA Regional Administrator. They are required to adhere to recordkeeping and reporting requirements, submit additional information as required by EPA or submit an application for a TSCA PCB approval, and notify the Regional Administrator of any changes relating to the waste management documents that serve as the basis for the coordinated approval.

      Operators of laboratories who wish to exceed quantity limitations for the manufacture, processing, or distribution in commerce of PCBs will have to submit requests to EPA.

      Other Individuals (e.g., Users of PCBs): Owners of PCB-Contaminated natural gas pipeline systems who sell or distribute natural gas, can use these systems if they keep records of sampling and analysis results and actions taken to reduce the PCB concentrations to below regulated levels and submit a description of the system to EPA, if requested. Documentation of data and actions must also be made available to EPA upon request. Owners of natural gas pipelines must also include the system in public service notification programs, which inform landowners that they should contact the utilities before beginning any excavation work on their property. Owners of other PCB-contaminated gas liquid systems must obtain the consent of the EPA (Director, NPCD) to use the systems.

       Persons burning for energy recovery used oil or liquids containing PCBs <50 ppm from a natural gas pipeline system must keep records of each certification notice, and marketers of these liquids must retain records related to transactions that they claim do not contain detectable PCBs. Other users of PCBs may have to deal with remediation waste or PCB bulk waste disposal issues. In that event, they will need to determine which of the available options (i.e., self-implementing, performance-based, leachability or risk-based) could be used to address their disposal needs. These disposal options will require compliance with various reporting and recordkeeping requirements.

 THE INFORMATION COLLECTION  --  AGENCY ACTIVITIES,  COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT

 Agency Activities

      EPA resources are devoted to reviewing and analyzing data submissions, compiling and recording data, maintaining hard-copy files of submitted data, inspecting facilities, producing inspection reports, responding to public inquiry, providing regulatory interpretations and developing rulemakings. OPPT staff members do not print or otherwise prepare collection instruments, compile mailing lists, or publish results.. On the Agency's website, EPA maintains a dedicated PCB homepage (www.epa.gov/pcbs) that offers extensive information on management of PCBs, including EPA regulations and waste handling.   More specific Agency activities are discussed below.

      Data submitted to EPA for consideration in granting or denying requests for exemptions are reviewed, analyzed for confidentiality and appropriate protection, and placed in the docket. EPA makes determinations of whether to grant exemptions and develops rulemakings in response to the requests for exemptions. Agency staff also receives, analyzes, and reviews requests to exceed quantity limitations imposed by class exemptions.

      Under the self-implementing procedures of the PCB regulations, data are submitted to EPA to qualify for the exclusion for processes/products containing low levels of PCBs from the statutory bans on the manufacture (including import), processing, and distribution in commerce of PCBs. These data are reviewed and stored pursuant to confidentiality requirements, when appropriate, and placed in the docket for public review (sanitized documents only); inspections are conducted as prescribed by the enforcement policy. The information is used by EPA to identify manufacturers and importers of products containing low levels of PCBs, as well as for compliance monitoring and enforcement purposes.

      Pursuant to the use authorization for PCB Transformers, EPA staff members created and maintain the PCB Transformer Registration Database. Staff presently process registrations for newly discovered PCB Transformers. As Agency resources permit, EPA updates the database to include additional information voluntarily submitted by PCB Transformer owners on the current status of PCB Transformers previously registered. This supplemental data is not required or solicited by EPA. On an "as requested basis," EPA resources provide information from the PCB Transformers Database to environmental and emergency response officials. EPA also has placed these data on the PCB webpage.

      EPA staff also process both new and amended PCB notifications of waste handling activities and updates the  as well as the National List of Facilities that have Notified of PCB Activity, also available on the PCB webpage.

      Information from annual reports that are submitted by storers and disposers of PCB waste enables the Agency to respond to public and Congressional inquiries, target inspections, and conduct compliance monitoring and other enforcement activities. To produce the inspection reports, EPA inputs, indexes and files data that are obtained during inspections, and prepares, reviews and revises the inspection reports. EPA compiles annual report data into a PCB Annual Report of disposal statistics, currently available through 2105 and available to the public upon request (U.S. EPA, 2015)

      Activities routinely conducted by EPA in processing requests for permits to operate a PCB disposal facility are as follows:
       Review/analyze applications to determine whether facilities have adequate technical plans and financial capabilities to operate and maintain the facility.
       Attend demonstrations.
       Grant/deny approval.
       Store the data.

      Engineers in EPA's Office of Resource Conservation and Recovery as well as staff in regional offices review the PCB disposal applications. The adequacy of the data contained in these applications is evaluated during a thorough review of the data and calculations and the assessment of subsequent demonstrations. In addition to disposal approvals, the Agency receives, analyzes, and reviews applications for commercial storage approvals and coordinated approvals; as well as requests to exceed R&D and storage limitations and to use alternate disposal methods. For commercial storage approvals, EPA must also determine if the facility will be able to close in an environmentally safe manner. EPA makes a List of Approved Polychlorinated Biphenyl (PCB) Commercial Storage and Disposal Facilities available to the public on the PCB webpage.

 Collection Methodology and Management

      Currently, given the nature of the collections and disclosure requirements, all of the PCB information collections are done in hard copy form. Although the content of these various collections has been specified earlier in this Supporting Statement, the majority of the collections do not require the use of a specific form or format. Only two of the collections involve a specifically prescribed form.  EPA is currently engaged in the adoption of an electronic manifesting system for RCRA hazardous wastes. As many of the RCRA provisions for the Uniform Hazardous Waste Manifest are incorporated by reference into the PCB regulations at 40 CFR Part 761 Subpart K, the electronic manifest can in most instances also be used for PCB waste shipments, at the option of the user..

      Requests for disposal approval may be submitted in the form most convenient to the applicant. Because of the nature of the information (i.e., CBI, engineering blueprints), much information is still submitted on paper, rather than electronically,but EPA encourages and readily accepts data in electronic format. There is no requirement for the information to be submitted in an automated, electronic, mechanical, or other technological information format.

      Records are maintained at EPA by the staff overseeing the review of permit applications. Applications are retained for the duration of the disposal facilities operating approval. The public may access the non-confidential portions of applications.

 Small Entity Flexibility

      Small businesses are not exempt from the PCB regulations under TSCA, and the information collections will affect all entities, regardless of size, that own or use PCBs or PCB-containing equipment and generate PCB waste. The potential health ramifications necessitate equal reporting and recordkeeping requirements for all persons, and due to heightened awareness and concern for proper PCB disposal practices, the potential human and environmental risk necessitates equal disclosure by all applicants regardless of size. While all practical steps have been taken to minimize the reporting and recordkeeping burdens, the requirements imposed are the minimum necessary to maintain proper accountability for the disposition of the PCBs. These requirements assist EPA in meeting its statutory obligation to make a finding of no unreasonable risk for an authorized activity and determining, for example, whether a petitioner is eligible to receive the benefit of an approval, exemption, or exclusion. In general, while the reporting and recordkeeping requirements impose additional obligations on small businesses, these requirements are of a conventional nature that should be familiar to businesses, and are no more burdensome than conventional standard business practices. In addition, some requirements overlap with sound business practices, such as periodically inspecting valuable equipment, maintaining an inventory of property and other basic recordkeeping.

      Small organizations will usually handle smaller volumes of PCBs than larger entities, thereby minimizing their reporting and recordkeeping burdens. The complexity of toxic material disposal and the required financial assurance to ensure against environmental liabilities seem to deter smaller businesses from engaging in disposal facility enterprises (e.g., it is economically infeasible). In another example, the majority of PCB Transformers subject to these requirements are located in large industrial and utility locations, as the use of transformers designed to use PCBs (Askarel transformers) is associated with high-voltage applications. Therefore, fewer small businesses are likely to own many PCB Transformers because of the nature of their application as well as significant costs associated with the initial purchase of the equipment and the long-term expense for operation and maintenance. Moreover, even assuming that PCB Transformers are as likely to be owned by small entities as larger firms, the regulatory cost remains very small relative to overall revenues.

      In another example, the manufacturing exclusion was designed to minimize the burdens of the TSCA section 6(e) bans on chemical manufacturers. This rule has relieved small business manufacturers from the burdens of filing annual petitions for exemption from the manufacturing, processing, and distribution in commerce bans, as required under section 6(e)(3). Further, to minimize the burdens of information collection on small organizations, EPA allows significant flexibility in its information collection requirements so that manufacturers have options available to them for supporting their requests for exclusion. One option avoids the need for repeated sampling and reporting by allowing manufacturers to conduct theoretical analyses rather than actual sampling of process streams to estimate the levels of PCBs generated by the processes. If the basis for the theoretical analysis is sound, the manufacturer may certify compliance on the basis of that analysis, until and unless he or she engages in a new process or significantly alters the reported process. Additional flexibility is available for estimating the levels of PCBs generated and released. Rather than specifying any one sampling regime or method of theoretical analysis, the reports require only that petitioners support the estimates by any defensible basis. For example, sampling results may be accompanied by a description of the sample matrix and any data from a quality assurance plan.

 Small Entities Affected by the PCB Regulations

      Small business entities may include both those in the public and private sectors, and not-for-profit organizations as well as for-profit entities. The Regulatory Flexibility Act identifies three classes of small entities of special concern:
       Small for-profit businesses as defined by the Small Business Administration's (SBA) Table of Size Standards (U.S. SBA, 2010)
       Small governments, defined as governmental jurisdictions, such as cities, towns, counties, or school districts, with a population less than 50,000.
       Small organizations, defined as not-for-profit enterprises that are independently owned and not dominant in their fields.

Entities generating PCB wastes comprise the following classes:
       Electric utility industry: PCB-oil and contaminated mineral oil from electrical equipment such as transformers and large capacitors. Included in this category are publicly owned entities such as municipal and county electric systems as well as other public power systems such as irrigation districts.
       Non-utility entities with privately owned electrical equipment, such as PCB Transformers and Capacitors and other PCB-Contaminated electrical equipment. This group includes those entities that own high-voltage transformers and large capacitors. A 1989 EPA report identified such entities as most likely to be in oil and gas production, manufacturing, railroads, and telecommunication industries. Not-for-profit entities such as colleges and universities and hospitals are also to be included in this group (EPA, 1989). Public-sector operations such as prisons might also possess this type of equipment.
       Entities with PCB ballasts from fluorescent light fixtures. Due to the widespread use of fluorescent lighting, any entity operating out of a fixed location built prior to the late 1970s is a possible candidate for inclusion in this class of waste generators. Included are government bodies, such as school districts, that have such lighting equipment.
       Entities operating natural gas pipelines may have PCB-contaminated pipeline equipment resulting from the contact of condensate with PCB-contaminated oils used in pipeline compressors.
       PCBs have been found in electrical components of appliances and in automobiles, and disposal operations such as automobile or appliance shredding may generate PCB-contaminated materials.
       Cleanup of Superfund sites and other hazardous waste sites may generate PCB-contaminated materials.

      Electric Utilities: It has been estimated that 60 to 70 percent of the PCBs produced were used in dielectric fluid for transformers and capacitors. Thus, such high-voltage equipment, including askarel and mineral oil transformers, represents a major, albiet steadily declining, source of PCB waste generation. EPA studies of the numbers of such equipment in use assumed that utilities owned 30 percent of the askarel transformers and80 percent of the mineral oil transformers, , with the remainder owned by non-utility industrial enterprises (U. S. EPA, 2004). In 2003, EPA estimated that 3,170 utilities might own PCB and PCB-contaminated electrical equipment (U.S. EPA, 2003). The SBA small-entity definition for the electric utility industry includes entities producing 4 million megawatt-hours of electricity sales or less. Small publicly owned utilities are those owned by government bodies with a population of less than 50,000 (U.S. SBA, 2010)

      Other Industrial Sectors: The available evidence suggests that PCB waste generation related to contaminated electrical equipment, fluorescent light ballasts, and other PCB wastes, is common throughout a number of industrial sectors. The 1989 EPA study, based on Arkansas, New York, and California state information about PCB waste generators, identified oil and gas production (NAICS 211111), manufacturing (NAICS 31-33), line-haul railroads (NAICS 48211), telephone communications (NAICS 513), and refuse systems (NAICS 562111) as accounting for over 90 percent of the non-utility, private sector PCB waste generators. Information on PCB waste generators for New York and California indicate that a large proportion of non-utility PCB waste generators fall within NAICS codes 211, 31-33, 335, and 562. These industries are expected to account for most of the PCB wastes associated with the disposal of electrical equipment. Hospitals (NAICS 62211) and colleges and universities (NAICS 61131) are also likely to have high-voltage electrical equipment of the type associated with PCB contamination and thus should be included within the class of PCB waste generators associated with such equipment. This assumption is corroborated by the inclusion of such establishments among the New York hazardous waste generators listed as disposing of PCB transformers and capacitors. The specific description of the wastes for each generator provided by the New York data also confirms the belief that wastes associated with fluorescent light ballasts are generated by establishments throughout the private and public sectors.

      EPA used this information about the industrial pattern of PCB waste generation to develop industry-specific estimates of the number of establishments that might have PCB and PCB-Contaminated Electrical Equipment. Based on a previous study of the electric utility industry, EPA estimated that 0.3 percent of electric utility customers receive power at high voltage levels (ERG, 1993). High-voltage customers in most cases have transformers, capacitors, and other equipment necessary to transform the voltages and distribute electricity within their premises. That study also estimated that 85 percent of such establishments own their own high-voltage transformation equipment, the remainder using transformation equipment provided or leased to them by their utility company.

      Previously, EPA estimated that approximately 50,000 industrial establishments have affected equipment (U.S. EPA, 2003). While the likelihood of owning the regulated equipment increases for high-voltage customers, it is not the only characteristic that is relevant. Low-voltage distribution equipment can also be PCB-contaminated.

      EPA distributed the affected establishments among industries using judgments of the distribution of high voltage equipment among 3-digit NAICS industries. Thus, while an establishment need not be a high-voltage customer to be affected by the regulations, being a high-voltage customer was considered the best indicator of whether the establishment would be using PCB-containing equipment. The methodology included the following judgments. First, the industries were stratified according to whether they would include a substantial number (high prevalence), relatively few (low prevalence), or a negligible number of high-voltage users. Second, high-prevalence industries were judged to account for two-thirds of the list of high-voltage users. The 50,000 affected establishments were then distributed among industries within these two groups on the basis of the overall distribution of establishments. The results of this distribution methodology are shown in Table 3-2 of the Draft Analysis of the Cost Impacts of Potential Amendments to the PCB Regulations at 40 CFR 761 (U.S. EPA, 2003).

      For most NAICS industries, SBA classifies small entities by employment size. Depending upon the industry, entities with fewer than 500, 750, or 1,000 employees are classified as small businesses. For most of the remaining industries, small firms are classified by revenue size.  To estimate the number of small entities for these industries, average revenues per entity were calculated for each employment size category in each six-digit NAICS code. The average revenue per entity for employment size classification in each NAICS code was then compared to the SBA small business definition. All entities in size classifications falling below the small business definition were counted as small businesses.

      Table 3-3 in the Draft Analysis of the Cost Impacts of Potential Amendments to the PCB Regulations at 40 CFR 761 presents estimates of the number of entities in each industry that own affected equipment (U.S. EPA, 2003). These estimates are based on the distribution of high-voltage equipment establishments and assume that the frequency of high-voltage equipment ownership among entities is the same among establishments. Also, small entities are assumed to be as likely to own high-voltage equipment as larger firms, an assumption that may result in an overstatement of the actual number of small entities that own such equipment. Updating this table with census  data (U.S. Census, 2007) suggests that in addition to the estimated 8,911 non-utility entities with high-voltage equipment, 1,858 electric utilities own high-voltage equipment. Similarly, 8,571 small non-utility entities and 1,681small utility entities are estimated to own high-voltage equipment. Additionally, comments submitted to EPA by the Utility Solid Waste Activities Group (USWAG, 2010) suggests that companies have disposed of approximately 2 to 3 percent of PCB equipment annually, with PCB equipment estimated to be phased out by 2029. This indicates that the number of small businesses being impacted continues to decrease.

 Collection Schedule

      Most of the reporting activities are triggered by specific events or on an as-needed basis rather than by specific dates, as shown on Table 5-1 and 5-2.

                         TABLE 5-1: REPORTING SCHEDULE
Ref. #
Regulatory Section(s)
Collection Requirement
Collection Schedule

40 CFR 761

                              Subpart A -- General

1

§761.(f)(1)(2), and (3)

Submit new reports or modifications to existing reports to qualify for manufacturing/import exclusions, pursuant to compliance with the reporting requirements of Subpart J.

Within 90 days of initiating a manufacturing process/import. Subsequent submission of information is required if a manufacturer significantly alters a production process, or to report periods of unusually high generation or release of PCBs. (See numbers 42 and 43)

                                Subpart B -- Use

2

§§761.20(b) and
 (c)(1) and (3)

Submit an exemption petition as per TSCA section 6(e)(3) to manufacture (import), process, or distribute in commerce (export) PCBs, unless otherwise authorized.

On an as needed basis.

3

§761.30(a)(1)(vi)
and (vii); (xv)(D)

Register newly discovered PCB Transformers.

Within 30 days of identifying Transformer.

4

§§761.30(a)(2)(v)(C) and .30(h)(2)(v)(C)

Submit requests to reclassify equipment using alternate methods.

On an as needed basis.

5

§761.30(i)(1)(iii)
(A)(1) and (C)

For gas pipeline systems owned/operated by a seller or distributor of natural gas, submit a description of the systems that contain >50 ppm PCBs and make available documentation of data and actions to comply with use authorizations.

Upon request of EPA.

6

§761.30(t)(3)

Obtain EPA approval for the use of PCBs in other gas or liquid systems.

When planning use of system.

7

§761.35(b)

Obtain EPA Regional Administrator approval for an extended storage for reuse period.

6 months prior to expiration.

Subpart D -- Storage and Disposal

8

§§761.60(e) and (i)(2), .70(a), (b), and (d), and
.75(b)(7), (b)(8)(ii),
and (c).

Submit disposal permit applications, when appropriate, and demonstration plans.

Applications are submitted as needed. Once an approval is granted, the permittee must notify the Agency prior to the expiration date if a renewal of the approval is desired. If no changes or modifications have been made to the disposal process in the year preceding expiration, the permittee must simply re-demonstrate the process.

9

§761.60(j)(1)(i)

Obtain an identification number for PCB R&D disposal.

When planning R&D for disposal.

10

§761.60(j)(1)(ii)

Notify EPA (as well as state and local environmental officials) of PCB disposal R&D activities.

30 days prior to initiating R&D activity.

11

§761.60(j)(2)

Obtain a waiver to increase the volume or concentration of PCBs or duration of an R&D activity. R&D disposal approval may be required by the EPA Regional Administrator.

When needed.

12

§§761.61(a)(3)(i) and (ii)

Notify EPA (as well as state and local environmental officials) of self-implementing remediation activity. Additional information may be requested.

30 days prior to remediation.

13

§761.61(a)(3)(ii)

Notify EPA of changes to self-implementing remediation activities.

Within the 30-day notification period.

14

§761.61(a)(3)(iii)

Request a waiver of the notification requirement.

If remediation is needed.

15

§761.61(a)(8)(i)(B)

Submit certification that the deed notation for properties requiring a fence or cap has been recorded and includes the cap/fence notice.

Within 60 days of completion of remediation.

16

§761.61(c)(1)

Apply for risk-based disposal of PCB remediation wastes. Submit additional information as requested by EPA.

Before alternative activity takes place.

17

§761.62(c)(1)

Obtain approval for risk-based disposal or storage of PCB bulk product waste. Provide additional information and periodic progress reports, as requested by EPA

Before activity takes place.

18

§761.65(a)(2)

Provide information on continuing attempts to secure disposal. Request a one-year storage extension.

 30 days prior to disposal deadline.

19

§761.65(a)(3)

Submit request for additional extensions beyond the initial one-year extension, including justification and information on measures taken to secure disposal.

When needed.

20

§761.65(a)(4)

Submit request for modifications to TSCA approval to allow for extended storage period.

Before extension expires.

21

§761.65(c)(6)(i)(C)

Demonstrate that other containers for storage of PCB/radioactive wastes are protective of health and the environment.

When needed.

22

§§761.65(d); (e)(1),(6), and (8); and (f)

Prepare application for commercial storage approval. Notify EPA of facility modification, impending closure, and completion of closure.

When needed; 60 days before final is scheduled to begin; within 60 days of completion of closure.

23

§§761.65(e)(4)

Submit a written request to the EPA Regional Administrator to modify a storage approval to amend the closure plan, when there are changes in ownership, changes in expected dates of closure, and/or unexpected events.

When needed.

24

§761.65(g)(9)

Notify EPA of modifications to commercial storage facilities.

Within 30 days of facility modification.

25

§§761.65(j)

Demonstrate that a new commercial storage facility owner has established financial assurance for closure.

As of the date of final EPA approval. Submit new or amended commercial storage application as a result of change in ownership.

26

§§761.70(a)(8), (9); and (d)(5)

Obtain approval of alternate measures when regulatory requirements cannot be met for operating an incinerator used for incinerating PCBs.

When needed.

27

§§761.70(d)(8);
761.75(c)(7)

Notify EPA of change in ownership of disposal facility (i.e., for incinerators and landfills).

Within 30 days of transferring ownership.

28

§§761.71(a)(2) and
(b)(2)

Notify EPA of high efficiency boiler information, (e.g., HEB owner, address, and specifications).

Seek approval to burn liquids, other than mineral oil dielectric fluid in a high efficiency boiler.

One-time notification 30 days before initially burning mineral oil dielectric fluid (MODEF) in the boiler.

One-time approval prior to burning liquids.

29

§761.72(c)(2)

Notify EPA as a scrap metal recovery oven or smelter used to dispose of PCBs.

Before burning PCBs (Also see #44).

30

§761.72(c)(3)

Request approval to dispose of PCBs in an oven or smelter based on site-specific risk assessments, in lieu of meeting requirements listed in §761.72.

Before use of unit.

31

§§761.77(a)(1)(i),
(a)(1)(ii)(A)(1) and (C), and  .77(a)(2)

Submit a notification to the EPA Regional Administrator for coordinated approval and additional information, as requested by EPA. Submit an application for TSCA disposal approval, if the Regional Administrator denies the request for a coordinated approval or determines that the conditions of the coordinated approval are not met.

When seeking coordinated approval; when requested by the Regional Administrator.

32

§761.77(a)(3)

Notify EPA of changes in PCB waste management requirements in the document(s) used to obtain TSCA PCB coordinated approvals.

Within 5 days of when changes are made.

33

§761.79(h)

Request approval of alternative decontamination or sampling methods.

When needed.

                            Subpart E -- Exemptions

34

§§761.80(e)(1) and (i)(1)

Submit R&D exemption petition to qualify for the class exemption for manufacturing PCBs for disposal and for processing and distributing PCBs and analytical reference samples derived from PCB waste.

60 days prior to activities.

35

§761.80(e), (i)(2)
and (n)

Submit certified letter to request renewal of certain exemptions.

6 months prior to expiration.

36

§§761.80(e)(3),
(g)(2) and (i)(4)

Obtain approval to exceed limits of the exemption.

60 days before manufacture of PCBs.

37

§761.80(e)(4)

Notify EPA in writing when R&D activities will include the manufacture of PCBs.

30 days prior to beginning R&D activities.

38

§§761.80(n)

Submit a petition for certain exemptions to address increases in the amount of PCBs to be processed and distributed, imported (manufactured), or exported, or changes in the manner of processing and distributing, importing (manufacturing), or exporting PCBs.

When needed.

           Subpart F -- Transboundary Shipments of PCBs for Disposal

39

§§761.93(a) and .97(a)

Submit an exemption petition to import or export PCBs or PCB Items for disposal.

When needed (See #2).

                     Subpart G -- PCB Spill Cleanup Policy

40

§761.125(a)(1)(i) to (iii)

Report all spills to certain areas of 10 pounds or more to EPA (and spills involving 1 pound of PCBs to the National Response Center).

Within 24 hours of discovery.

                    Subpart J -- General Records and Reports

41

§§761.180(b), (b)(3), and (c)(5)

Submit annual reports for PCB wastes disposed of in a PCB disposal facility (including wastes disposed of by waste generators), and for wastes stored by commercial storage facilities.

By July 15 of each year for the previous calendar year.

41a

§761.180(g)

Provide records of PCB equipment reclassification, if requested, to EPA. Also see #68a.

Upon request.

42

§761.185

Notify EPA and certify low level PCB product contamination to be exempt from the requirements of Subpart B, regarding processes inadvertently generating PCBs and imports of products containing inadvertently generated PCBs. Certification must be repeated if the previous certification is no longer valid.

Within 90 days of having processes or imports for which such reports are required.

43

§761.187

Notify EPA when PCB releases exceed limits, to be exempt from the requirements of Subpart B, for products, manufactured or imported containing inadvertently generated PCBs.

When limits are exceeded.

              Subpart K -- PCB Waste Disposal Records and Reports

44

§§761.202(a); 205(a) to (c)

Notify EPA of waste handling activities, for generators, commercial storers, transporters, or disposers of PCB waste.

Prior to engaging in PCB waste handling activities.

45

§761.205(f)

Report changes in notifications previously submitted by PCB waste handlers.

Within 30 days of making a change.

46

§§761.217(a) and (b) and §761.219(a),(b), and (c)

Submit Exception Reports to EPA when PCB waste generators, disposers, and/or commercial storers do not receive confirmation that a shipment of a PCB waste has been properly disposed of. Also, Submit a One-year Exception Report when the disposer of PCB waste could not dispose of the affected PCBs or PCB Items within 1 year of the date of removal from service for disposal; or the generator or commercial storer either has not received within 13 months from the date of removal from service for disposal a Certificate of Disposal confirming the disposal of the affected PCBs or PCB Items, or the generator or commercial storer receives a Certificate of Disposal confirming disposal of the affected PCBs or PCB Items on a date more than 1 year after the date of removal from service
Submit Exception Report to EPA for rejected shipments of PCB waste that are forwarded to an alternate facility by a designated facility using a new manifest.

Within 45 days of the events that trigger the report.

47

§761.215(c)

Submit Discrepancy Reports along with a copy of the manifest to EPA when the PCB waste received by a disposer is significantly different from the description on the manifest, and the discrepancy is not resolved after receiving the waste.

Within 15 days after receiving the unmanifested PCB waste.
48

No Longer Required

49

§761.216(a)
Submit Unmanifested Waste Reports (e.g., waste description, volume, disposition; date received; ID numbers of waste handlers for that waste) to EPA when disposers accept a shipment of PCB waste without an accompanying manifest, and the owner or operator of the commercial storage or disposal facility cannot contact the generator of the PCB waste

Within 15 days after receiving the unmanifested PCB waste.

Subpart T -- Comparison Study for Validating a New Performance-Based Decontamination Solvent under §761.79(d)(4)

50

§§761.395 and
761.398

Submit results of analysis and validation study to the Director, Office of Resource Conservation and Recovery.

Prior to the first use of a new solvent for alternate decontamination

                  TABLE 5-2: THIRD-PARTY REPORTING SCHEDULE
Ref. #
Regulatory Section(s)
Collection Requirement
Collection Schedule

                                  40 CFR 761

Subpart B -- Use

51

§§761.20(e)(3)(ii); .30(i)(5)(ii); and .60(b)(5)(iv)(B)

Burner of used oil must provide a 1-time certification to the marketer that he is in compliance with notification requirement at §761.71(a)(2).

Before accepting the first shipment of used oil.

52

§§761.30(a)(xi)
and (xv)(A) and
.30(h)(1)(ii)(B)

Notify National Response Center of PCB Transformer and PCB Voltage Regulator fires.

Immediately upon discovery of an incident.

53

§761.30(a)(1)
(xiv)

Notify owner of PCB Transformer that equipment may pose risk of exposure to food or feed.

When discovering potential exposure to food or feed.

54

§761.30(a)(1)(xv)
(D)

Register PCB Transformers with the building owner.

Within 30 days of discovery of the PCB Transformer.

Subpart D -- Storage and Disposal

55

§761.60(a)(3)(ii)

Provide information to chemical waste landfills that liquids do not exceed 500 ppm and are not ignitable.

Prior to disposal in the landfill.

56

§761.60(b)(5)(i)
(A)(1)

Include natural gas pipes that contain PCBs in public service notification programs.

Before abandoning natural gas pipes.

57

§761.60(f)(1)(i)

Notify state and local officials of PCB disposal in chemical waste landfill, incinerator, or an alternate PCB disposal technology.

At least 30 days before a facility is first used.

58

§761.60(f)(1)(ii)

Provide annual notice to state and local governments about PCBs disposed of during the year.

At the request of the state or local governments.

59

§761.60(j)(1)(ii)

Notify state and local environmental officials (as well as EPA) of PCB disposal R&D activities.

30 days prior to initiating R&D activity.

60

§761.60(j)(1)(vii)

Manifest wastes generated by R&D on PCB disposal that are transported from the R&D facility to a commercial storage or disposal facility, unless the residuals or unused samples are returned to the site of generation.

Upon transport of waste.

61

§§761.61(a)(3)(i)

Notify state and local environmental officials (as well as EPA) of self-implementing remediation activity.

30 days prior to remediation and when additional information is requested.

62

§761.61(a)(5)(i)
(B)(2)(iv)

Notify offsite non-TSCA facility of pending shipment of PCB remediation waste.

15 days prior to [first] shipment.

63

§761.61(a)(8)(i)
(A)

Attach a notation to the deed for property at which remediation projects require a permanent fence or cap.

Within 60 days of completion of the cleanup activity.

64

§§761.62(b)(4)(i) and (ii) (See also §§761.357 and 359)

Provide notification to a receiving facility that does not have a commercial PCB storage/ disposal approval of a pending shipment of remediation or bulk product waste.

15 days in advance of the first shipment and with each shipment thereafter.

65

§§761.65(c)(1)
and (8)

Attach a notation to a PCB Item or PCB Container containing the item indicating the date the Item was removed from service for disposal, to be able to temporarily store the item/container in an area that does not comply with the storage requirements of paragraph (b) of this section.

When removed from service for disposal.

66

§761.65(i)(3)

Send information, instead of manifest, regarding the sample collector, laboratory, and date of sample shipment with sample.

When sending PCB samples to a laboratory for testing.

                     Subpart G -- PCB Spill Cleanup Policy

67

§761.125(a)(1)

Report spills involving 1 pound or more by weight of PCBs to the National Response Center (and all spills to certain areas or of 10 pounds or more to EPA).

Within 24 hours of discovery.

68

§761.125(c)
(2)(ii)

Place label or notice of PCB contamination at cleanup site.

When contaminated soil is cleaned up to 50 ppm PCBs and not 25 ppm.

                   Subpart J -- General  Records and Reports

68a

§761.180(g)

Provide records of PCB equipment reclassification, if requested, to recipient of equipment. Also see #41a.

Upon request.

Subpart K -- PCB Waste Disposal Records and Reports

69

§§761. 210(b), (c), and (d)(1) and (2)

Send manifests to the next transporter

When generators ship PCB wastes .

70

§§761. 213(a)(2)(v) and (b)(4)

Send a copy of the manifest or shipping papers to the generator.

Within 30 days after delivery.

71

§§761.218(a) and (b)

Send Certificates of Disposal to generators of PCB waste when disposal of each item is complete for a manifested PCB waste shipment.

Within 30 days after the disposal date.

 ESTIMATING THE BURDEN AND COST OF THE COLLECTION

 Estimating Respondent Burden

      To update the respondent burden for this ICR, the hourly burdens and the total number of respondents for each requirement was reviewed by EPA using a number of data and information sources and consultations with regulated entities, prior to submission of the amended ICR to OMB for approval. The level of effort has been updated to reflect the current best estimates in this ICR.

      The current ICR data is based on several sources. One data source used to support this ICR was. an Inventory and Cost Estimates for PCB-Containing Electrical Equipment Owned/Operated by U.S. Electrical Utilities, prepared by ENVIRON and submitted by the Utility Solid Waste Activities Group in rulemaking comments to EPA in 2010 (USWAG, 2010). This industry-commissioned document includes updated estimates of PCB electrical equipment, including transformers and capacitors, as well as projected rates of equipment retirement. . Other data sources include EPA's PCB Annual Report, List of Approved Polychlorinated Biphenyl (PCB) Commercial Storage and Disposal Facilities, National List of Facilities that have Notified of PCB Activity, PCB Transformer Registration database and the U.S. Coast Guard's National Response Center. Prior to this update, EPA's PCB Regional Coordinators were also contacted to obtain information about the number of notifications, etc., that were submitted to the Agency over the existing ICR period (2016, 2017 and 2018)In EPA Headquarters, OLEM and OCSPP also reviewed relevant data on number of notifications, applications, etc.   Information was also obtained from the public comments on the draft ICR, summarized in section 3(b).

      New hourly wage rates were included for managerial, professional and technical (e.g., engineers), and clerical staff. Wages for these categories were taken from the Bureau of Labor Statistics (BLS) Employer Costs for Employee Compensation (ECEC) supplementary tables data for private manufacturing industry workers (BLS, 2018). The cost of fringe benefits such as paid leave and insurance, specific to each labor category, are taken from the same ECEC series. An additional loading factor of 17 percent is applied to wages to account for overhead. This approach is used for consistency with Office of Pollution Prevention and Toxics economic analyses (Rice, 2002). This overhead loading factor is added to the benefits loading factor, and the total is then applied to the base wage to derive the fully loaded wage. Fully loaded costs for managerial, profession/technical, and clerical labor are calculated as shown in Table 6-1.

      Burden summary. The total estimated time for respondents to comply with the reporting, third-party reporting, and recordkeeping requirements of this Consolidated ICR is 681,407 hours. The annual burden associated with respondents complying with the reporting requirements of this Consolidated ICR is estimated to average 122,545 hours industry-wide. The total third-party reporting burden is estimated to average 3,858 hours, industry-wide, and the total recordkeeping burden of this Consolidated ICR is estimated to average 555,004 hours, industry-wide. The average hourly estimates and total number of respondents for each reporting, third-party reporting, and recordkeeping burden are explained on Tables 6-2 to 6-4, respectively. Note that the burdens associated with requirement numbers 1, 2, 4, 6, 11, 19, 20, 26, 28-30, 32, 36, 38, 39, 42, 43, 47, 51, 53-55, 58, 59, 61, 64, 66, 72, and 73 will either have negligible impacts to the requirements or were costed with other requirements as indicated on the tables, and thus no estimates were included for these requirements.  Also note that the burdens associated with requirements numbers 46,49,60,69,70 and 71 reflect PCB regulatory provisions that incorporates RCRA Universal Hazardous Waste Manifest provisions by reference or otherwise duplicate the RCRA provisions. Since PCB waste is transported using the Universal Hazardous Waste Manifest, the burden for this reporting requirement is already accounted for by the recently revised ICR number 0801.22, which accounts for all manifest usage, without distinguishing whether a manifest is used for RCRA waste, PCB waste or combination shipments. Therefore, to prevent double counting of manifesting burden hours for PCB waste shipments, the burden for these line items is being reported as 0 in this ICR.

             TABLE 6-1: DERIVATION OF LOADED RESPONDENT WAGE RATES
Labor Category
BLS Series
Wage
(a)
Fringe Benefit
(b)
Fringes as % wage
(c)=(b)/(a)
Over-head % wage
(d)
Fringe + overhead factor*
(e)=(c)+(d)+1
Loaded Wages
(f)=(a)* (e)
Managerial
Management, business and financial
                                    $47.19
                                    $22.62
                                      48%
                                      17%
                                     1.65
                                    $77.86
Professional/
Technical
Professional and related
                                    $46.08
                                    $24.63
                                      53%
                                      17%
                                     1.70
                                    $78.33
Clerical
Office and administrative support
                                    $22.48
                                    $11.50
                                      51%
                                      17%
                                     1.68
                                    $37.76
  Methodology Source: Rice, 2002; Data Source: BLS, 2018.

      To simplify the presentation of the numerous hourly burden and cost estimates, the data are arrayed according to reporting, third-party reporting, and recordkeeping requirements for each section of the regulation, consistent with the presentation of the information in the tables of sections 2 and 5, rather than to rearrange and present the data by respondent type. EPA anticipates that no one individual would be subject to all of the requirements 40 CFR Part 761. Refer to section 4 for a complete description of the activities listed on Tables 6-2 to 6-4.

 Estimating Respondent Costs

      Tables 6-5, 6-6, and 6-7 show the annual respondent hourly burden and cost estimates for the reporting, third-party reporting, and recordkeeping requirements of the Consolidated ICR. Refer to section 6(a), above, for an explanation of the wage rates used, which are as follows:
 Managers -- $77.86
 Professional/technical -- $78.33
 Clerical -- $37.76

      There is one capital cost associated with this ICR. For Item # 68, there is an estimated $50 per site cost to place a sign at a PCB contamination cleanup site. For 194 sites, the total estimated annual capital cost would be $9,690 (not annualized). There are no new training costs anticipated to the affected industries or the Federal government associated with responding to the information collections that are subject to renewal, nor have there been any Federal costs associated with printing or mailing. Costs associated with reading the rules, providing training, and updating procedures to comply with the reporting and recordkeeping requirements are not included in this renewal as no new regulations have been promulgated that involve paperwork burdens. One-time requirements remain annualized for a three-year period, as indicated on Tables 6-5 to 6-7. Because operations and maintenance costs for these information collections (i.e., costs associated with telephone calls, photocopying, and other general office overhead expenses) have been estimated to be relatively low and within the range of the estimation error, there are no added costs for these activities. Also note that variations in some of the totals on the tables are caused by rounding.
             TABLE 6-2: REPORTING BURDENS UNDER TSCA SECTION 6(e)
Ref. #
Regulatory Section(s)
Collection Requirement
Time Estimate
Total #
Respondents
Per Year
Comments

                                  40 CFR 761

                              Subpart A -- General
1
§761.1(f)(1), (2), and (3)
Submit new reports or modifications to existing reports to qualify for manufacturing/ import exclusions, pursuant to compliance with the reporting requirements of Subpart J.
 --
 --
Burdens are reported under §§761.185 and §761.187. See numbers 42 and 43.

                                Subpart B -- Use
2

§§761.20(b) and
 (c)(1) and (3)

Submit an exemption petition as per TSCA section 6(e)(3) to manufacture (import), process, or distribute in commerce (export) PCBs, unless otherwise authorized.
 --
 --
Burdens are reported under §§761.80(e) and (i). See number 34.
3
§761.30(a)(1)(vi)
(A)(1), (xv)(D)
Register PCB Transformers, as appropriate, within 30 days of discovery.
1 hour
30  PCB Transformers
Only requirements for new disclosures are now applicable. The revised number of disclosures is based on an average of the number of PCB Transformers registered in the existing ICR timeframe (2016, 2017 and 2018).
4
§§761.30(a)(2) (v)(C) and .30(h)(2)(v)(C)
Obtain EPA approval to use alternate method to reclassify PCB equipment.
20 hours
0 requests

The number of respondentsremains unchanged, based on requests received by the Agency in the existing ICR timeframe.
5
§761.30(i)(1)(iii)
(A)(1) and (C)
Submit a description of a natural gas pipeline system that contains >50 ppm PCBs, and/or make available documentation of data and actions to comply with use authorization if requested by EPA.
4 hours
0  systems
No requests were made in the 2016 -2018 existing ICR timeframe and none are anticipated in this ICR period.
6
§761.30(t)(3)
Obtain approval for the use of PCBs in other gas or liquid systems.
20 hours
0
No respondents anticipated based on no requests in the 2016-2018 timeframe, as well as in previous years
7
§761.35(b)
Obtain approval for PCB Articles stored for reuse for >5 years in a facility that does not comply with §761.65(b).
0.166 hour (10 minutes per piece of equipment)
0
 No new requests were made in the 2016-2018 timeframe and none are expected in this ICR period.

                       Subpart D -- Storage and Disposal
8
§§761.60(e) and (i)(2); .70(a), (b), and (d); .75(b) (7), (b)(8)(ii), and (c)
Submit permit application and, when applicable, a demo plan for obtaining approval to operate a PCB disposal facility (i.e., alternative method of disposal, incinerator, chemical waste landfill). Submit requests for approval of R&D for PCB disposal for persons not following self-implementing requirements.
15 applications per year, as follows: 5 new applications for incinerator and non-thermal (alternate and landfill) facilities (2,000 hrs to prepare); 3 applications for incinerator modifications and 2 modification applications for non-thermal (alternate and landfill) facilities (700 hrs to prepare); 5 renewal requests for all technologies, without modifications (8 hours to prepare).Number of applicants is based on the number of applications submitted to the Regions and EPA Headquartersduring FY2017, the most recent year of full disposal statistics available).

Revised weighted average burden remains the same, about 900 hours per submission, , based on a slightly higher numbers for new applications, but a reduced effort due to a new guidance for permit applicants which clarifies andstreamlines the application process. [(2,000 x 5) + (700 x 5) + (8 x 5)]/15.
9
§761.60(j)(1)(i)
Notify EPA to obtain an identification number for conducting R&D on PCB disposal activities.
1.5 hours
5 facilities
The estimated total number of respondents remains the same, based on the number of notifications the Agency has received over the existing ICR timeframe.
10
§761.60(j)(1)(ii)
Notify EPA (as well as state, and local) officials prior to conducting R&D on PCB disposal activities.
6 hours
10 facilities
Burden reported here for both EPA and third-party notification at Table 6-3. Estimated total number of respondents remained the same, based on the number of notifications the Agency has received over theexisting ICR timeframe.
11
§761.60(j)(2)
Submit permit application and, when applicable, a demo plan for obtaining approval to operate a PCB disposal facility (i.e., alternative method of disposal, incinerator, chemical waste landfill). Submit requests for approval of R&D for PCB disposal for persons not following self-implementing requirements, as per paragraph (j) of this section.
2000 hours
0
No respondents anticipated. Time estimate revised to more accurately reflect application preparation time.
12
§§761.61(a)(3)(i) and (ii).
Notify EPA (as well as state, tribal, and local) officials of self-implementing remediation activity, including a summary of the procedures used to sample contaminated areas and sample collection and analysis data; submit additional information as requested; and certify that records of remediation activity are on file at the location designated in the certificate.
100 hours
58 sites
Number of respondents stayed the same, based on the number of notifications received by the Agencyin FY2017. Burden is reported here for this requirement and is listed on Table 6-3.
13
§761.61(a)(3)(ii)
Notify EPA of changes to notification of self-implementing activities.
2 hours
13 sites
Number of respondents stayed the same based on the number of notifications the Agency has received over the existing ICR timeframe. The hourly estimate is based on the time estimate to prepare other notifications for the self-implementing remediation requirements.
14
§761.61(a)(3)(iii)
Request a waiver of the notification requirement for conducting cleanup of PCB remediation waste.
20 hours
17 sites
Number of respondents stayed the same based on number of notifications the Agency received over theexisting ICR timeframe.
15
§761.61(a)(8)(i)
(B)
Submit certification of recording the deed notation required under paragraph (a)(8)(i)(A) of this section has been recorded.
4 hours
28 sites
Number of sites stayed the same based on the number of notices the Agency has received in theexisting ICR timeframe.
16
§761.61(c)(1)
Apply for risk-based disposal of PCB remediation wastes. Submit additional information as requested.
800 hours
100
Number of respondents increased based on the number of applications the Agencyreceived In FY2017. The average time estimate has decreased, as many applicants take advantage of a 61(a)/61(c) hybrid approval that only requires a risk-based determination for the non-self-implementing components of the cleanup.

17

§761.62(c)(1)

Obtain approval for risk-based disposal or storage of PCB bulk product waste. Provide additional information.

800 hours

5

Number of respondents decreased  based on the number of applications the Agencyreceived in FY2017. . The average time estimate has decreased, as many applicants take advantage of a 62(a)/62(c) hybrid approval that only requires a risk-based determination for the non-self-implementing components of the disposal plan.

18

 §761.65(a)(2)

Notify of continuing attempts to secure disposal and to request a one-year storage extension.

3 hours

5 waste storers

Combined for numbers 18, 19, and 20. Estimated total notifications stayed the same, based on number of notifications the Agency has receivedover the existing ICR timeframe.

19

§761.65(a)(3)

Submit request for additional extensions beyond the initial one-year extension, including justification and information on measures taken to secure disposal.

 --

 --

See #18, above.

20

§761.65(a)(4)

Submit request for modifications to TSCA approval to allow for extended storage period.

 --

 --

See # 18, above.

21

§761.65(c)(6)(i)
(C)

Demonstrate that other containers for storage of PCB/radioactive wastes are protective of health and the environment.

40 hours

5

Number of demonstrations remained the same, based on the number conducted over the existing ICR timeframe.

22

§761.65(d); (e)(1), (6), and (8); and (f)

Prepare application for commercial storage approval, including qualifications of key employees, closure plan, and closure cost estimate. Commercial storer must also notify EPA of facility modification, closure schedule, and completion of closure activities.

188 hours

3 new; 7 renewal applications

Number of new applications and renewals decreased based on the number the Agency received in FY2017. The weighted average to prepare new and renewal application is 240 hours [(392 hrs x 3 new) + (100 hrs x 7 renewal)]/10. Time to prepare notification of modification was estimated to be about one-fourth the time to prepare initial application. (Also see # 25.)

23

§761.65(e)(4)

Submit a written request to the EPA Regional Administrator to modify a storage approval to amend the closure plan, when there are changes in ownership, changes in expected dates of closure, and/or unexpected events.

2 hours

10 times

Number of requests stayed the same based on the number the Agency has received over the existing ICR timeframe.

24

§761.65(g)(9)

Notify issuing authority of modifications to commercial storage facilities.

2 hours

7 storage facilities

Number of notifications stayed the same based on the number the Agency has received in theexisting ICR timeframe.

25

§§761.65(j)

Demonstrate that a new owner of a commercial storage facility has established financial assurance for closure. Submit new or amended commercial storage application as a result of change in ownership.

120 hours

3 applications

Total number of respondents is consistent with the total number of applications for commercial storage approval, as per # 22, above. Number of notifications decreased based on the number of applications the Agency received in FY2017.

26

§§761.70(a)(8),
(9); and (d)(5)

Obtain approval of alternate measures when regulatory requirements cannot be met for operating a PCB incinerator.

1,910 hours

0

No respondents anticipated. It was assumed that if a facility does not meet the performance criteria, it will not accept PCB waste.

27

§§761.70(d)(8);
761.75(c)(7)

Notify EPA of change in ownership of disposal facility (i.e., for incinerators and landfills).

8 hours

5 facilities

Note that the hourly estimate includes only a cursory review of the existing permits by the new owner, not a thorough review. Number of notifications remained the same, based on the number of notifications the Agency has received overthe existing ICR timeframe.

28

§§761.71(a)(2)
and (b)(2)

Notify EPA prior to initial use of a high efficiency boiler to burn mineral oil dielectric fluid. Seek approval to burn liquids, other than mineral oil dielectric fluid in a HEB.

1.5 hours to notify EPA of HEB information; 40 hours to prepare approval request letter to the RA

0
respondents

The number of notifications and approvals remained the same, based on the number EPA has receivedover the existing ICR timeframe. Also see # 44.
29
§761.72(c)(2)
Notify EPA as a scrap metal recovery oven or smelter used to dispose of PCBs and comply with the reporting requirements of Subparts J and K.
1.5 hours
0

No requests anticipated. Also see # 44.
30
§761.72(c)(3)
Request approval to dispose of PCBs in an oven or smelter based on site-specific risk assessments, in lieu of meeting requirements listed in §761.72.
1,600 hours
0
No requests anticipated.
31
§§761.77(a)(1)(i), (a)(1)(ii)(A)(1) and (C), and .77(a)(2)
Submit a notification to the EPA Regional Administrator for coordinated approval and additional information, as requested by EPA. Submit an application for TSCA disposal approval, if the Regional Administrator denies the request for a coordinated approval or determines that the conditions of the coordinated approval are not being met.
36 hours (notification); 480 hours (approval application)
6 notifications;
0 approval applications
Number of notifications remained the same, based on notifications the Agency received inFY2017.

32
§761.77(a)(3)
Notify EPA of changes in waste management requirements in the non-TSCA waste management document used to obtain TSCA PCB coordinated approvals.
8 hours
0 waste disposers
No notifications were submitted over the existing ICR timeframe.
33
§761.79(h)

Prepare requests for decontamination approvals of alternative decontamination or sampling methods. EPA may request additional information.
800 hours
10
Number of notifications decreased based on notifications the Agency received in FY2017. EPA's time estimate is revised downward to account for the increased proportion of existing-approval amendments received to denovo approval requests received. Amendments are less time intensive to propose.

                            Subpart E -- Exemptions
34
§§761.80(e)(1) and (i)(1)
Submit R&D exemption petition to qualify for the class exemptions to mfg. PCBs for disposal R&D and to mfg., import, process, distribute, and export PCBs and analytical reference samples derived from PCB waste for the purpose of R&D.
40 hours
1 company
Number of respondents is based on recent Agency submissions (existing ICR timeframe). Estimates are combined for numbers 2, 34, 36, and 38.
35
§761.80(e)(2) and (i)(2)
Submit requests for renewal of the exemptions as per §§750.11 and 31. (Renewals to company-specific exemptions can be handled following the same procedures.)
1 hour
1 request
Number of respondents is based on recent Agency requests.
36
§§761.80(e)(3), (g)(2), and (i)(4)
Obtain approval from EPA to exceed limits of the exemption.

 --
0 requests for approval
See # 34, above.
37
§761.80(e)(4)
Notify EPA before beginning R&D activities that include the manufacture of PCBs.
20 hours
1 notification
Number of respondents is based on recent Agency submissions.
38
§761.80(n)
Submit a petition for certain exemptions to address increases in the amount of PCBs to be processed and distributed, imported (manufactured), or exported, or changes in the manner of processing and distributing, importing (manufacturing), or exporting PCBs. (See #35 for renewals.)
40 hours
0 requests
There have been no such requests in the existing ICR timeframe . Total captured in Item # 34.

           Subpart F -- Transboundary Shipments of PCBs for Disposal
39
§§761.93(a) and .97(a)
Submit an exemption petition to import or export PCBs or PCB Items for disposal.

___

___
Burden is reported at §§761.20(b) and (c)(1) and (3). See # 34.

                     Subpart G -- PCB Spill Cleanup Policy
40
§§761.125(a)(1)
(i) to (iii)
Report certain spills of PCBs to the EPA.
0.167 hours (10 minutes)
50 calls
Number of calls remained the same, based on the amount the Agency received in the existing ICR timeframe . Requirement also on Table 6-3.

                    Subpart J -- General Records and Reports
41
§§761.180(b), (b)(3), and (c)(5)
Submit annual reports for the operation of PCB incinerators, chemical waste landfills, high efficiency boilers, and commercial storage facilities, including facilities that dispose of the PCB wastes they generate. Report suspension of operations.
59 hours
124 facilities
The estimate for number of facilities was generated by using the total number of EPA-approved storage and disposal facilities (110), and increasing this number by 15 percent to reflect the additional facilities that also dispose of the waste that they generate (U.S. EPA, 2018a.
41a
§761.180(g)
Provide records of PCB equipment reclassification, if requested, by EPA.

0.25 hours
0  Transformers
No records were requested by EPA in the existing ICR period (2016-2018) and no requests are anticipated in the new ICR period. The hourly estimate assumes it takes 15 minutes for equipment owners to provide requested records (ERG, 2000).
42
§761.185
Notify EPA and certify low level PCB product contamination to be exempt from the requirements of Subpart B, regarding processes inadvertently generating PCBs and imports of products containing inadvertently generated PCBs. Certification must be repeated if the previous certification is no longer valid.
20 hours
0 companies
Number of submissions unchanged based on the numbers received in the existing ICR timeframe.

43

§761.187

Notify EPA when PCB releases exceed limits, to be exempt from the requirements of Subpart B, for products, manufactured or imported containing inadvertently generated PCBs.

20 hours

0 company

Number of notifications remained the same, based on the number received by the Agency in theexisting ICR period. Hourly estimate is based on time to review the monitoring log and compile information into the notification.

              Subpart K -- PCB Waste Disposal Records and Reports

44

§§761.202(a); 205(a) to (c)

Notify EPA of waste handling activities, for generators, commercial storers, transporters, or disposers of PCB waste.

1.5 hours

100 waste handlers

Roughly 9,2500 notices have been received; in recent years (2016-2018) approximately 100 per year, relatively few "new" submissions are anticipated. Also see numbers 9, 28, and 29, above. (U.S. EPA, 2018b)

45

§761.205(f)

Report changes in notifications previously submitted by PCB waste handlers.

1.5 hours

200 waste handlers

 --

46

§§761.217(a) and (b) and §761.219(a),(b), and (c)

Submit Exception Reports to EPA when PCB waste generators, disposers, and/or commercial storers do not receive confirmation that a shipment of a PCB waste has been properly disposed of. Also, Submit a One-year Exception Report when the disposer of PCB waste could not dispose of the affected PCBs or PCB Items within 1 year of the date of removal from service for disposal; or the generator or commercial storer either has not received within 13 months from the date of removal from service for disposal a Certificate of Disposal confirming the disposal of the affected PCBs or PCB Items, or the generator or commercial storer receives a Certificate of Disposal confirming disposal of the affected PCBs or PCB Items on a date more than 1 year after the date of removal from service
Submit Exception Report to EPA for rejected shipments of PCB waste that are forwarded to an alternate facility by a designated facility using a new manifest.

2 hours

0  reports

 This provision incorporates RCRA Universal Hazardous Waste Manifest provisions by reference. Since PCB waste is transported using the Universal Hazardous Waste Manifest, the burden for this reporting requirement is already accounted for by the recently revised ICR number 0801.22. (ICR 0801.22 counts all manifests used, without distinguishing whether they are used for RCRA waste, PCB waste or combination shipments. To prevent double counting of burden hours, the burden is being reported as 0 in this PCB ICR. For more information, please see the Supporting Statement for ICR 0801.22, specifically: Exception reports are counted on p. 67 (Section b(8)). Discrepancy Reports are counted on p. 72 (Section d(6)). Unmanifested Waste Reports are counted on p. 75 (Section d(9)).

47

§761.215(c)

Submit Discrepancy Reports along with a copy of the manifest to EPA when the PCB waste received by a disposer is significantly different from the description on the manifest, and the discrepancy is not resolved after receiving the waste.

 --

 --

See # 46, above.
48

No Longer Required

49

§761.216(a)

Submit unmanifested Waste Reports (e.g., waste description, volume, disposition; date received; ID numbers of waste handlers for that waste) to EPA when disposers accept a shipment of PCB waste without an accompanying manifest.

2 hours

0 reports

See #46, above.

Subpart T -- Comparison Study for Validating a New Performance-Based Decontamination Solvent under §761.79(d)(4)

50

§§761.395 and 761.398

Submit results of analysis and validation study to the Director, Office of Resource Conservation and Recovery (ORCR).

16 hours

5 studies

Estimate for the total number of respondents is 5 percent of the estimated 100 decontamination sites. Also refer to # 93, Table 6-4.

       TABLE 6-3: THIRD-PARTY REPORTING BURDENS UNDER TSCA SECTION 6(e)
Ref. #
Regulatory Section(s)
Collection Requirement
Time Estimate
Total #
Respondents
Per Year
Comments

                                  40 CFR 761

	Subpart B -- Use

51

§§761.20(e)(3)(ii); .30(i)(5)(ii); and .60(b)(5)(iv)(B)

Burner of used oil must provide a 1-time certification to the marketer that he is in compliance with notification requirement at §761.71(a)(2).

1 hour

0

No respondents anticipated.

52

§§761.30(a)(1)(xi) and (xv)(A); .30 (h)(1)(ii)(B)

Report PCB Transformers and Voltage Regulator fire incidents to the National Response Center.

0.167 hour (10 minutes)

20 calls

National Response Center data for 2015-2017 indicate the Center received a total of 204 PCB-related calls(See #67). An overview of these data indicates that a number of calls were to report transformer fire incidents. It will be assumed for this ICR that 10 percent of all calls (20 calls) are to report fire-related incidents.

53

§761.30(a)(1)
(xiv)

Notify owner of PCB Transformer that equipment may pose risk of exposure to food or feed.

 --

 --

No burden. All notifications were to have been made, and use prohibited, by October 1, 1985.

54

§761.30(a)(1)(xv)(D)

Register PCB Transformers with the building owner within 30 days of discovery

 --

 --

Burden reported on Table 6-1.

                       Subpart D -- Storage and Disposal

55

§761.60(a)(3)(ii)

Provide information to chemical waste landfills that liquids do not exceed 500 ppm and are not ignitable.

20 hours

 --

No respondents anticipated.

56

§761.60(b)(5)(i)
(A)(1)

Include abandoned natural gas pipes that contain PCBs in public service notification programs.

0.25 hour (15 minutes)

50 pipes
Number unchanged. Industry estimate (Lacey, 2003).

57

§761.60(f)(1)(i)

Provide state and local officials with notification prior to first use of an approved chemical waste landfill, incinerator, or alternate PCB disposal technology.

0.50 hour (30 minutes).

600 notifications

Since cleanup activities remain the same, the estimates for the use of mobile equipment at 300 unique sites remains the same, and will be used as follows:  200 substations per year will use mobile equipment to clean PCB transformers; about 50 remediation sites will use solvent extraction units; 5 sites will use mobile incinerators, vitrification units, or physical separation units, and 45 sites will use other existing or newly permitted equipment.

58

§761.60(f)(1)(ii)

Provide annual notice of the quantities and description of the PCBs disposed of to state or local governments, at their request.

0.5 hour

 --

Since the annual reporting requirement to state/local governments would be initiated at the state or local government level, EPA has no way of estimating this total burden.

59

§761.60(j)(1)(ii)

Notify state and local officials (as well as EPA) of PCB R&D disposal activities.

 --

 --

Total burden for EPA and third-party reporting requirements are reported on Table 6-1.

60

§761.60(j)(1)(vii)

Use manifests, pursuant to Subpart K, for all R&D PCB wastes being transported from the R&D facility to an approved PCB storage or disposal facility.

1 hour

0 facilities

See #46, above. PCB R&D waste is counted in the total hazardous waste manifest burden in ICR 0801.22, specifically Section d1, d2, and d4."[Note: 66 R&D facilities listed on the National List of Facilities that have Notified of PCB Activities (U.S. EPA, 2018b)].

61

§§761.61(a)(3)(i)

Notify state and local officials (as well as EPA) of self-implementing remediation activity.

 --

 --

Total burden for EPA and third-party reporting requirements is reported on Table 6-1.

62

§761.61(a)(5)(i)
(B)(2)(iv)

Notify offsite non-TSCA facility of pending shipment of remediation waste.

2 hours

100 waste shippers

Combined for remediation and bulk product wastes (numbers 62 and 64).

63

§761.61(a)(8)(i)
(A)

Attach a notation to the deed for property at which remediation projects require a permanent fence or cap.

3 hours

100 sites

 --

64

§§761.62(b)(4)(i) and (ii) (See also
§§761.357 and
 359)

Provide notification to a receiving facility that does not have a commercial PCB storage or disposal approval before the first shipment of a PCB bulk product waste stream. In addition, for certain waste this notice must be provided with each shipment thereafter.

 --

 --

See # 62, above.

65

§§761.65(c)(1)
and (8)

Attach a notation to a PCB item or PCB container containing the item indicating the date the item was removed from service for disposal, to be able to temporarily store the item/container in an area that does not comply with the storage requirements of paragraph (b) of this section.

0.083 hours
(5 minutes)

22,297
items,
containers,
and article
containers

The number of items, containers, and article containers is based on the sum of capacitors, PCB transformers, articles containers and containers reported as being disposed of in 2015 (US EPA 2015).

The time estimate for these requirements considers that all items must be dated when removed from service for disposal, whether or not the item will be placed in temporary storage or not.

66

§761.65(i)(3)

Send information regarding the sample collector, the lab, date of shipment, quantity, and description of sample, when sending PCB samples to a laboratory for testing.

4 hours

 --

Since EPA has no way of estimating the number of samples that would be sent off-site annually for testing, or the frequency with which the samples are sent to an off-site lab, EPA cannot estimate the total annual burden associated with this requirement.

                     Subpart G -- PCB Spill Cleanup Policy

67

§761.125(a)(1)

Report certain spills of PCBs to the National Response Center.

0.167 hours (10 minutes)

204incidences

New average based on the number of PCB-related incidences reported to the National Response Center for 2015-2017 (U.S. Coast Guard, 2015, 2016, 2017). Related requirement to notify EPA is included on Table 6-1.

68

§761.125(c)
(2)(ii)

Place label or notice at PCB contamination cleanup sites at outdoor electrical substations that involved 1 lb or more PCBs by weight (270 gallons or more of untested mineral oil).

1 hour

194 sites

Revised estimate assumes that the > 1-lb spills at electrical substations are a large subset but not all of all the spills that must be reported to the National Response Center; 95 percent of the average annual 204 spills reported for 2015-17 (U.S. Coast Guard, 2015, 2016, 2017).

The capital costs for placing the sign is assumed to be $50 per site (e.g., for posts, labels, etc.), for a total of $9,690.
                    Subpart J -- General Records and Reports

68a

§761.180(g)

Provide records of PCB equipment reclassification, if requested, by recipients of equipment.

0.5 hours

72  units

EPA estimates 143 transformers will be reclassified annually during this ICR period (See #75). Of this amount, 50 percent will be retained by owners, and 50 percent (72) will be transferred to other entities (e.g., sold, loaned, leased, sent for servicing).

Estimate assumes it takes 5 minutes for a manager to approve and delegate each request for records and 25 minutes for a clerk to copy and send a paper or electronic version of each complete record (ERG, 2000).

              Subpart K -- PCB Waste Disposal Records and Reports
69
§§761. 210(b), (c), and (d)(1) and (2)
Prepare manifests and provide generator-initiated manifests of PCB waste to each transporter or designated commercial storage or disposal facility.
0.083 (5  minutes) average
0 items
See #46, above. PCB Manifests are counted in the total hazardous waste manifest burden in ICR 0801.22, specifically Section d1, d2, and d4.
70
§§761. 213(a)(2)(v) and (b)(4)
Storer or disposer sends a copy of the manifest or shipping paper to the generator.
0.167 hours (10 minutes)
0  reports
See #46, above. PCB Manifests are counted in the total hazardous waste manifest burden in ICR 0801.22, specifically Section d1, d2, and d4.
71
§§761.218(a) and (b)
Send certificates of disposal to generators of PCB waste when disposal of each item is complete for a manifested PCB waste shipment.
0.25 hour (15 minutes) average

 2,695 certificates
Based on the PCB Annual Report, the average annual total number of capacitors, Article containers, transformers, and PCB containers disposed of from 1996 to 2015 is 53,893 (U.S. EPA, 2015). Assuming that information regarding 20 items is included on one certificate of disposal, then there are a total of 2,695 certificates. Also refer to # 102.

           TABLE 6-4: RECORDKEEPING BURDENS UNDER TSCA SECTION 6(e)
Ref. #
Regulatory Section(s)
Collection Requirement
Time Estimate
Total #
Respondents
Per Year
Comments

                                  40 CFR 761

                              Subpart A -- General

72

§§761.1(f)

Comply with recordkeeping requirements of Subpart J [§§761.185(c)(2) and (d), and .193] as a condition of the exclusion from the PCB bans, for persons who inadvertently manufacture or import PCBs generated as unintentional impurities in excluded manufacturing processes or generate PCBs in excluded manufacturing process or products with recycled PCBs.

 --

 --

Burden is reported at §§761.185(c)(2) and (d), and 761.193(a). See # 100.

Subpart B -- Manufacturing, Processing, Distribution in Commerce, and Use of PCBs and PCB Items

73

§§761.20(e)(4)(i) and (ii); .30(i)(5) (ii); and .60(b)(5) (iv)(B)

Marketer who first claims used oil does not contain detectable PCBs must retain records supporting the claim and a copy of each certification notice received or prepared relating to transactions involving PCB-containing used oil. Burners must include among the records a copy of each certification notice that has been provided to a marketer of PCB-containing used oil.

0.25 hours (15 minutes)

 --

No significant burden anticipated.

74a,b

§§761.30(a)(1) (xii) and (xiv)

Maintain records of inspection and maintenance history for at least three years after the disposal of a PCB transformer, including records of registration, as per §761.30(a)(1)(vi)(C).

0.05 hour (3 minutes) to track inspection data; 0.033 (2 minutes) to file and maintain data

12,457  PCB
Transformers.

5 percent are inspected
quarterly

12,457 PCB Transformers are registered on EPA's most current inventory. EPA assumes not more than 5% are inspected quarterly (only Askarel units without secondary containment). The majority are inspected annually.
Time estimate remains the same and reflects the average time for a technician to track the data (3 minutes) and for a clerk to file and maintain the data (2 minutes). This report does not account for actual inspection time. The calculations for this estimate account for the differences in burden between annual and quarterly inspections. It is assumed that the time to maintain records for the disposed transformers is insignificant.

75
§§761.30(a)(2)(v)(C) and (D); 761.30(h)(2)(vi)
(C) and (D); and 761.180(a)

Maintain records at the facility where electrical transformers, voltage regulators, electromagnets, and switches have been reclassified to a lower PCB concentration.
0.25 (15 minutes)
143  transformers
The number of respondents is based on the application of the past estimate of a 1.15% annual reclassification rate to the most current inventory of 12,457 identified (registered) PCB Transformers.
It is assumed that the burden associated with reclassified equipment other than transformers will be insignificant. It was also assumed that it will take 15 minutes to maintain the records on pre-and post-reclassification concentration of the transformer (EPA, 2000).
76
§§761.30(i)(1)
(iii)(B) and (C)
Keep records on certain natural gas pipeline systems with >=50 ppm PCBs and records of actions taken to reduce PCB contamination for three years after PCBs reduced to <50 ppm.
4 hours
100 systems
It is not anticipated that new records will need to be developed; historical data can be used.
77
§761.35(a)(2)
Keep records of equipment stored for reuse.
0.15 hour
3,000 pieces of equipment
In 2010, USWAG estimated that the 2009-2010 inventory of all equipment >50 ppm was 1,141,241 items, and that this inventory would decrease by approximately 111,000 items annually. Using this estimate, EPA assumes that 30,000 items remain after 10 years, in 2019-20, and, as in previous ICRs, that 10% of the inventory is in storage for reuse (3,000 items).

                   Subpart C -- Marking of PCBs and PCB Items
78
§761.40(c)(2)(ii) and (k)
Keep records of the protected location of PCB large capacitors where owner chooses not to mark individually (optional).
0.1 hour (6 minutes)
500  pieces of equipment
Based on analysis contained in USWAG 2010 comments on the PCBs Reassessment of Use Authorization ANPRM (USWAG, 2010). Study reported inventory of large PCB capacitors  reduced 95% in 2010 and estimated almost all would be retired by 2013. In comments on this new ICR, USWAG affirmed the trend but noted "some" PCB Large Capacitors remain in use. In 2015, 1,115 Large Capacitors were disposed of (US EPA 2015). For this ICR, EPA estimates 5,000 PCB Large Capacitors remain in use, of which 10% (500) are not marked individually and require records.

                       Subpart D -- Storage and Disposal
79
§761.60(j)(1)(ix)
Keep records of R&D for disposal activities.

12 hours

66 facilities

Number of facilities based on data contained in the National Report of Facilities that have Notified of PCB Activty (U.S. EPA, 2018b).
80
§§761.61(a)(3)(i)
(E); and (a)(6)

Retain records of the sampling plans, sample collection procedures, sample preparation procedures, extraction procedures, and instrumental/chemical analysis procedures used to assess or characterize the PCB contamination at the cleanup site, and certification that these records are on file at the location designated in the certificate. Keep records of comparison studies for any alternate method used that meet or exceed the requirements of §761.326. Keep records of sampling and sample analysis to verify cleanup and on-site disposal of bulk PCB remediation wastes and porous surfaces, as per Subpart O, §761.295.

1 hour

100 sites

Also see §761.295.

81
§761.61(a)(3)(iii)
Retain original waivers from the self-implementing remediation requirements received from the EPA Regional Administrator, state, and local agencies.

0.167 hour (10 minutes)

100 sites

This estimate remained the same.
82
§761.61(a)(9)
Keep records in accordance with §761.125 (c)(5) for (a)(3), (a)(4), and (a)(5) of this part.

20 hours

100 sites

This estimate remained the same.
83
§761.62(b)(5)
Maintain a written record of all sampling and analysis of PCBs or notifications made under this part and make available upon request.

4 hours

26 sites

Estimate is 15 percent of 170 total number of affected sites.
84
§§761.65(a)(2)(ii) and (a)(3)
Keep a written record of attempts to secure disposal capacity. Records may be required for periods of extended storage.

4 hours
75 waste storers

Number of waste storers is 1 percent of the total number of waste generators and storers (7,518) listed in the National List of Facilities that have Notified of PCB Activty (U.S. EPA, 2018b).
85a,b

§761.65(c)(1)(iv)
Prepare/modify Spill Prevention, Control and Countermeasure (SPCC) Plans to address liquid PCBs >500 ppm, to be able to temporarily store PCB Containers containing liquid PCBs at >=50 ppm in areas that do not comply with the storage requirements of §761.65.

60 hours/new plan; 2 hours/ adapted plan

5 new
respondents; 10 adapt existing plans

It is estimated that only 5 waste generation facilities will be required to prepare plans from scratch and 10 facilities will adapt existing plans.
86
§761.65(c)(7)(ii)
Prepare SPCC Plan, when using stationary storage containers, as per 29 CFR 1910.106, for liquid PCBs.

60 hours

5 facilities

It is not foreseen that many facilities will enter into the PCB storage business each year.
87
§761.65(c)(8)
Keep records of the quantity and the date of each batch added to the stationary storage container.

0.083 hours (5 minutes)

30,000
batches

Number of batches remained the same.
88
§§761.65(c)(10) and 761.180
Establish and maintain records as per §761.180 for storing for disposal PCBs and PCB Items >=50 ppm.

843 hours

65 commercial
storers

The total number of storers was obtained from EPA's List of Approved Polychlorinated Biphenyl (PCB) Commercial Storage and Disposal Facilities (U.S. EPA, 2018a). Note:  See #99 for generator burden, including generators with storage units.
89
§§761.70(a)(3), (4) and (7); (c); and 761.180(c)
Maintain for incinerators records of quantities, feed rates, temperatures, combustion products, and operations, and special records, as per §761.180(c).

843 hours

4 incinerators

From the EPA's list of List of Approved Polychlorinated Biphenyl (PCB) Commercial Storage and Disposal Facilities (U.S. EPA, 2018a.
90
§§761.71(a)(1)(vi) and (vii), (a)(4), (b)(1)(vi-vii), (b)(5);761.180(e)
Record and retain monthly HEB operation data.

12 hours

20 HEBs

Note that 5 of these HEBs (from EPA Region VI) are used intermittently, so that total hourly burden may actually be less than indicated in this report. Also, total number of HEBs is based on EPA estimate of 2 per region.
91
§§761.72(a)(9) and (b)(6)
Record and retain records of temperature readings from scrap metal recovery ovens.

3 hours

7 ovens

From EPA's List of Approved Polychlorinated Biphenyl (PCB) Commercial Storage and Disposal Facilities (U.S. EPA, 2018a.
92
§§761.75(b)(6)(iii) and (b)(8)(iv); 761.180(d)
Maintain records for all PCB disposal operations at chemical waste landfills, including PCB concentration in liquid wastes, the three-dimensional burial coordinates for PCBs and PCB items, water sampling and analysis, and additional records as required in §761.180.

843 hours

11 landfills

From EPA's List of Approved Polychlorinated Biphenyl (PCB) Commercial Storage and Disposal Facilities (U.S. EPA, 2018a.

93
§761.79(d)(4) and Subpart T
Retain test/validation results of PODFs and VADFs.

0.5 hour

5 facilities

Estimate is 5 percent of the 100 decontamination sites.
94
§§761.79(f)(1) and (2)
Keep records of confirmatory sampling and sampling locations/results for decontamination activities and compliance with self-implementing decontamination procedures.

2 hours

100 sites

No change.

                            Subpart E -- Exemptions
95
§761.80(e)(5) and (i)(7)
Keep records of activities associated with manufacture/processing/distribution in commerce of PCBs or PCB reference samples derived from waste materials for R&D.

12 hours

66 facilities

Number of facilities based on the National List of Facilities that have Notified of PCB Activties (U.S. EPA, 2018b).
96
§761.80(g)(1)
Keep records of PCB processing and distribution in commerce activities, for facilities that process and distribute small quantities of PCBs for R&D.

12 hours

15 facilities

Total number of facilities remained unchanged based on an Agency review of existing petitions.

                     Subpart G -- PCB Spill Cleanup Policy
97
§§761.125(b)(3) and (c)(5); .61(a)(9)
Maintain records of cleanup and certification of decontamination.

8 hours

204 sets of records

Based on the annual number of spills reported to the National Response Center in 2015-2017 (U.S. Coast Guard, 2015, 2016, 2017).
98
§761.125(c)(1)
Maintain records documenting delay in spill cleanup activities and areas of visible contamination.

0.5 hours

11 sites

It is anticipated that 5 percent of the total number of spills, as reported above, would face delays in cleanup.

                    Subpart J -- General Records and Reports
99
§§761.180(a),(a) (4), (b) and (f);  761.65(c)(5)
Maintain annual records and document log for PCBs and PCB items for 5 years after facility ceases, including manifests, CDs, records of inspections and cleanups, facility and item ID information, number of Items, phone records, and Item transfer information, for owners/operators of storage and disposal facilities. Collect and maintain documents, correspondence, and data pertaining to storage/disposal of PCBs that have been provided to as well as received from any state/local agency and any application/ correspondence submitted to permitting authorities.

52 hours

9,141 waste
handlers

The time to keep the annual log varies widely, based on the level of PCB activity taking place and the volume of PCBs and PCB items handled. To keep the annual log takes from 1 hour to over 40 hours each week. Total number of facilities is the total number of PCB waste handlers (9,251) minus the total number of commercial storers and disposers (110 facilities). (U.S. EPA, 2004, 2018b).
100
§§761.185(c)(2), (d) and .193(a) and (b)
Maintain theoretical analysis or monitoring records by persons who import, manufacture, process, distribute in commerce, or use products containing inadvertently generated or recycled PCBs, pursuant to §761.1(f)(1) to (3). Maintain letter certifying compliance with §761.1(f), for excluded manufacturing processes.

 8 hours to file and maintain records

10 respondents

Number of respondents based on Agency records since 2010. Industry estimates 4-5 domestic manufacturers maintain records (Wawer, 2018) EPA assumes a similar number of importers would also maintain import records. Industry estimates 12-24 hours annually, more than past Agency estimate of approximately 5 hours. EPA estimates importer record burden is substantially  less, as foreign chemical supplier would provide all supporting test data to the importer. Time estimate is therefore a composite [(5x12 hours + 5x4 hours)/10= 8 hours]

              Subpart K -- PCB Waste Disposal Records and Reports
101
§§761.210(a)(3), (e)(4), 211(d)(2), (e)(5), (f)(1)(iv), (f)(3)(ii), (f)(4)(ii), 213(a)(2)(v), (b)(5), 214(a),(b), and (c)
File and maintain manifests initiated or received by the PCB generator and any subsequent PCB waste handler.
0.167 hour (10 minutes)
0 manifests
."See #46 above. This burden is accounted for by ICR number 0801.22, Section a1.
102
§761.218(c) and (d)
Maintain a copy of each certificate of disposal received from disposers, for generators and commercial storers of PCB waste.
0.167 hour (10 minutes)
 2,695  certificates
Total number of manifests is an average of 20 items per manifest applied to  a total of 53,893 items disposed of per year for a total of 2,695 disposal certificates. See #71 for details. . [Note that this retention requirement is not accounted for by ICR number 0801.22]

		Subpart T -- Comparison Study for Validating a New Performance-Based Decontamination Solvent under §761.79(d)(4)
103
§761.398(c)
Record testing parameters and experimental conditions in SOP. Results of validation study are to be affixed in an appendix.
16 hours
5 facilities
No change.

  TABLE 6-5: ANNUAL RESPONDENT HOURLY BURDEN AND COST ESTIMATE  -  REPORTING

                        Hours and Costs Per Respondent
                              Total Hours and Costs

                                    Mgr. @
                                    Tech. @
                                    Cler. @
                                    Hours/
                                     Labor
                                     Total
                                     Total
                                     Total

                                    $77.86
                                    $78.33
                                    $37.76
                                    Resp./
                                  Cost/Resp.
                                     # of
                                    Hours/
                                     Cost/
Ref #
Regulatory Citation
Information Collection Activity
                                     /Hour
                                     /Hour
                                     /Hour
                                   Year (a)
                                   Year (b)
                                     Resp.
                                   Year (c)
                                  Year (d, e)

Subpart B

                                                                              3
761.30(a)(1)(vi),(vii), (xv)(D)
Register newly discovered PCB Transformers
                                                                              1
                                                                              -
                                                                              -
                                                                              1
                                                                            $78
                                                                             30
                                                                            30
                                                                         $913
(e)
                                                                              5
 761.30(i)(1)(iii)(A)(1)
Submit descriptions of gas pipeline systems and make documents available to EPA
                                                                              1
                                                                              1
                                                                              2
                                                                              4
                                                                           $232
                                                                             0
                                                                             0
                                              $0
(e)
                                                                              7
 761.35(b)
Obtain approval for PCB Article storage in a facility that does not meet 761.65(b)

                                                                          0.166

                                                                          0.166
                                                                            $16
                                                                             0
                                                                             0
                                                                            $0
(e)

Subpart D

                                                                              8
 761.60(e), (i)(2); .70(a),(b),(d)(2); .75(b)(7),(b)(8)(ii),(c)
Submit disposal permit applications
                                                                              -
                                                                            825
                                                                             75
                                                                            900
                                                                        $67,454
                                                                             15
                                                                        13,500
                                                                      $394,606
(e)
                                                                              9
 761.60(j)(1)(i)
Obtain identification number for R&D disposal
                                                                              -
                                                                            1.5
                                                                              -
                                                                            1.5
                                                                        $117.50
                                                                              5
                                                                              8
                                                                           $229
(e)
                                                                             10
 761.60(j)(1)(ii)
Notify officials of R&D activities
                                                                              -
                                                                              4
                                                                              2
                                                                              6
                                                                        $464.24
                                                                             10
                                                                             60
                                                                         $4,642

                                                                             12
 761.61(a)(3)(i),(ii)
Notify officials of self-imp. remediation
                                                                             30
                                                                             50
                                                                             20
                                                                            100
                                                                      $7,007.50
                                                                             58
                                                                          5,800
                                                                       $406,435

                                                                             13
 761.61(a)(3)(ii)
Notify EPA of self-imp. remed. changes
                                                                              -
                                                                              2
                                                                              -
                                                                              2
                                                                        $156.66
                                                                             13
                                                                             26
                                                                         $2,036

                                                                             14
761.61(a)(3)(iii)
Request waiver of notification requirement
                                                                              2
                                                                             16
                                                                              2
                                                                             20
                                                                         $1,483
                                                                             17
                                                                            340
                                                                       $25,225

                                                                             15
 761.61(a)(8)(i)(B)
Certify recording of deed notation
                                                                              -
                                                                              4

                                                                              4
                                                                        $313.32
                                                                             28
                                                                            112
                                                                         $8,773

                                                                             16
 761.61(c)(1)
Apply for risk-based disposal approval for remediation waste
                                                                              -
                                                                            740
                                                                             60
                                                                            800
                                                                       $ 60,230
                                                                            100
                                                                         80,000
                                                                    $2,348,970
(e)
                                                                             17
 761.62(c)91)
Apply for risk-based disposal or storage approval for bulk PCB product waste
                                                                              -
                                                                            740
                                                                             60
                                                                            800
                                                                       $ 60,230
                                                                             5
                                                                          4,000
                                                                     $117,449
(e)
                                                                             18
 761.65(a)(2),(3),(4)
Notify of attempts to secure disposal
                                                                              -
                                                                              2
                                                                              1
                                                                              3
                                                                        $194.42
                                                                              5
                                                                             15
                                                                           $972

                                                                             21
 761.65(c)(6)(i)(C)
Demonstrate that storage containers for PCB/rad waste are protective of health/env
                                                                              -
                                                                             32
                                                                              8
                                                                             40
                                                                      $2,808.64
                                                                              5
                                                                            200
                                                                         $5,477
(e)