Supporting Statement for
Anaerobic Digestion Facilities Processing Wasted Food
to Support EPA's Sustainable Materials Management Program and Sustainable Management of Food Efforts

                                  Renewal ICR
                                       
                                       

                                       
                                       
                                 June 1, 2020

                            EPA ICR Number 2533.04
                         OMB Control Number 2050-0217
                                       
                                       
                                       
                                       
                                       
                                       
                     U.S. Environmental Protection Agency
               Resource Conservation and Sustainability Division
                          Materials Management Branch
                           1200 Pennsylvania Ave. NW
                             Washington, DC 20460
                                       
                                       
                                       
                                       

Contents
1.IDENTIFICATION OF THE INFORMATION COLLECTION	1
1(a)	Title of the Information Collection	1
1(b)	Short Characterization/Abstract	1
2. NEED FOR AND USE OF THIS COLLECTION	3
2(a)	Need/Authority for the Collection	3
2(b)	Practical Utility/Users of the Data	3
3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA	3
3(a) 	Nonduplication	3
3(b)	Public Notice Required Prior to ICR Submission to OMB	4
3(c) 	Consultations	4
3(d)	Effects of Less Frequent Collection	4
3(e)	General Guidelines	4
3(f) 	Confidentiality	5
3(g) 	Sensitive Questions	5
4. THE RESPONDENTS AND THE INFORMATION REQUESTED	5
4(a)	Respondent NAICS Codes	5
4(b)	Information Requested	8
5. THE INFORMATION COLLECTED - AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT	9
5(a)	Agency Activities	9
5(b)	Collection Methodology and Management	9
5(c)	Small Entity Flexibility	10
5(d)	Collection Schedule	10
6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION	10
6(a)	Estimating Respondent Burden	10
6(b)	Estimating Respondent Costs	11
6(c)	Estimating Agency Burden and Costs	13
6(d)	Estimating the Respondent Universe	15
6(e)	Bottom Line Burden Hours and Costs	16
6(f)	Reasons for Change in Burden	16
6(g)	Burden Statement	16



                                       
 IDENTIFICATION OF THE INFORMATION COLLECTION

1(a)	Title of the Information Collection

      Anaerobic Digestion Facilities Processing Wasted Food to support EPA's Sustainable Materials Management Program and Sustainable Management of Food (SMF) Efforts. 
      
1(b)	Short Characterization/Abstract

      Sustainable Management of Food is a systematic approach that seeks to reduce wasted food and its associated impacts over the entire lifecycle of food. The lifecycle of food includes use of natural resources, manufacturing, sales, and consumption and ends with decisions on recovery or final disposal. Diversion of food waste from landfills is a critical component of this effort. To effectively divert food waste from landfills, sufficient capacity to process the diverted materials is required, much of which is provided by anaerobic digestion facilities. Knowledge of organics processing capacity is needed to facilitate food waste diversion.
      
      EPA's (or the Agency's) food recovery hierarchy prioritizes potential actions to prevent and divert wasted food. According to the hierarchy, processing wasted food via anaerobic digestion is a more desirable option than landfilling or incineration because it creates more benefits for the environment, society and the economy. Anaerobic digestion of food waste and other organic materials can generate renewable energy, reduce methane emissions to the atmosphere, and provide opportunities to improve soil health through the production of soil amendments. EPA's SMF program supports these efforts by educating state and local governments and communities about the benefits of wasted food diversion. EPA also builds partnerships with strategic partners interested in developing organics processing capacity and provides tools and technical support to assist organizations in developing anaerobic digestion (AD) projects.
        
   The nationwide collection of data about AD facilities processing food waste began in 2017 with a survey of all known AD facilities under the initial Information Collection Request (ICR No. 2533.01). EPA developed surveys for three different types of digesters: (1) stand-alone food waste digesters; (2) on-farm digesters that co-digest food waste; and (3) digesters at water resource recovery facilities (WRRFs) that co-digest food waste. The surveys are electronic and the data are exported to EPA in spreadsheet form. Links to the surveys are distributed by email and made accessible on EPA's AD website. The first report of findings based on these data was released in July 2018. These data allow EPA to:
      
 Verify the number and location of known AD facilities;
 Document the total processing capacity at these AD facilities;
 Document the types of food wastes, and the sources of these wastes, that are accepted at AD facilities;
 Document how much food waste was processed;
 Document how much biogas was produced; 
    Analyze the end-uses of AD products (biogas and digestate); and,
 Understand additional information about AD facilities such as pre-processing/de-packaging activity, operational specifications, and gas cleaning systems.
 
   To maintain accuracy over time, this information collection will be conducted annually followed by annual publication of the aggregated results. Respondents for this ICR are: (1) Project Developers; (2) Project Owners/Operators; and (3) Livestock Farmers. EPA, state and local governments and other stakeholders can use the results to:
   
 Track changes in the AD facility universe, processing capacity, amount of food waste processed, and biogas production over time; 
 Document trends in feedstock sources and types of feedstock processed; 
 Focus efforts to decrease landfilling of wasted food; and
 Promote a better understanding of tipping fees, pre-processing/de-packaging activities, operational specifications, and gas cleaning systems.
      
   This ICR is for a renewal request for a collection approved by OMB for one year in September of 2019.  In their terms of clearance for the previous ICR (EPA ID: 2533.02), OMB specified that, "Upon re-submission to OMB, EPA must provide a Supporting Statement B and provide a robust rationale and justification for collecting the data."  Those items are addressed in this current package.  Because this ICR is being submitted in relatively soon after its predecessor, most other sections of the discussion, as well as the burden calculations, remain the unchanged.  
   
   
   
2. NEED FOR AND USE OF THIS COLLECTION

2(a)	Need/Authority for the Collection

      The related legal authority is the Resource Conservation and Recovery Act (RCRA) Subtitle H Section 8003, "Coordination, Collection, and Dissemination of Information."

      Information collected from respondents will allow EPA to track, facilitate and measure the increase in capacity to process wasted food (organics) via anaerobic digestion throughout the United States. As the practice of organics diversion gains momentum in this country, the rate at which wasted food is diverted from landfills will continue to increase. The success of EPA's food waste diversion program is dependent on a steady increase of processing capacity over time. Prior to implementation of this ICR, EPA did not have the necessary data to demonstrate this growth or to document a baseline processing capacity. These data are essential for EPA to evaluate Agency activities designed to build such capacity. The importance of this type of data was also emphasized in EPA's SMM Strategic Plan (Fiscal Year 2017-2022).
      
2(b)	Practical Utility/Users of the Data

EPA will use information submitted by respondents to update and expand its dataset of AD facilities. Development and maintenance of this dataset enables EPA to support its stakeholders through identification of viable outlets for diverted food waste. Analysis of facility locations by state also supports evaluation of various state waste and energy policies for their effect on existing capacity as well as increases in capacity over time.

The data collected regarding design specifications, tipping fees, pre-processing of feedstocks, gas cleaning systems and end uses of AD products will increase EPA's ability to provide technical assistance to states and municipalities related to project design, implementation, cost effectiveness and successful business models. Collectively, these efforts are anticipated to have a positive impact on infrastructure development and industry growth overall.

EPA, state and local governments and other stakeholders can use the results to: track changes in facility universe, processing capacity, amount of food waste processed, and biogas production over time; document trends in feedstock sources and types processed; and focus efforts to decrease landfilling of wasted food.

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a) 	Nonduplication

For new respondents, the information to be collected has not been collected previously by EPA or any other federal agency. Comprehensive information about existing and new AD projects is not available through any other mechanism. To avoid requesting information that has already been collected, these data are collected annually for specific operational timeframes. Previously collected data cover operating years 2015, 2016, 2017, and 2018. Respondents are also given the opportunity to update other data parameters during each collection.

3(b)	Public Notice Required Prior to ICR Submission to OMB

      This Supporting Statement is associated with the second Federal Register notice for this ICR renewal. There were no comments received after the first Federal Register notice, 85 FR 34627, published June 5, 2020.
      
3(c) 	Consultations

      EPA staff contacted three respondents in 2018 to request information on the estimated amount of time required to respond to the electronic survey. All respondents consulted reported that the survey took between 10 and 30 minutes to complete. No new consultations were conducted on this renewal due to the fact that previous renewal was approved only one-year prior on 9/10/19. 
      
Table 1: List of Respondent Consultations for the AD Facility Data Collection
Contact Person, Organization 
Role
Email Address
Chanel Kirkpatrick, Chief Operator, Santa Rita Wastewater Reclamation Plant
WRRF AD Operator
Chanel.Kirkpatrick@durangogov.org
Josh Rapport, VP of Research and Development, CleanWorld
AD Vendor/Consultant
josh.rapport@cleanworld.com
John Van Nelson, Technical Services Manager, MillerCoors
Stand-alone AD Operator 
John.VanNelson@millercoors.com
      
3(d)	Effects of Less Frequent Collection
      
      The electronic surveys used to collect the AD facility data will be distributed to potential respondents annually. EPA believes that any reduction in the frequency of this information collection would impede efforts to track changes in the AD facility universe, processing capacity, amount food waste processed, and biogas production over time. This information is needed to support and focus the EPA's SMF efforts to decrease landfilling of wasted food.
 
3(e)	General Guidelines
      
      Information collections performed under this clearance will follow all of OMB's General Guidelines regarding federal data collection.

3(f) 	Confidentiality

Participation in this data collection effort is voluntary. Respondents are not required to reveal confidential business information. 

3(g) 	Sensitive Questions
      
      No questions of a sensitive nature are asked as part of this collection. 
      
4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a)	Respondent NAICS Codes

      This ICR will include three different types of respondents involved in developing and operating anaerobic digesters: 1) project developers (including engineering firms and environmental consultants), 2) project owners and plant operators; and 3) livestock farmers.
      
      Table 2 identifies the applicable North American Industry Classification System (NAICS) codes for project developers and project owners/plant operators. The NAICS codes are further described using the Standard Occupational Classification (SOC) code and a description for each code. The SOC code will be used to determine the applicable labor rate for each type of respondent in these categories.

      Although there are specific NAICS codes for the cattle, dairy and swine farming industry, the Bureau of Labor Statistics (BLS) does not publish labor rates by SOC code within these specific NAICS codes. BLS adheres to a threshold of reliability before publishing more detailed data within the NAICS structure. For the farming sector there is not enough available data to meet this threshold. As a result, appropriate SOC codes from within the overall farming sector (Sector 11  -  Agriculture, Forestry, Fishing and Hunting) have been selected for applicable labor rates.
      
      
Table 2: Respondents to Information Collection
Respondent Type
NAICS Code
Standard Occupational Classification (SOC) code and description
Project Developers
541330
SOC code 17-2081: Environmental Engineers - Research, design, plan, or perform engineering duties in the prevention, control, and remediation of environmental hazards using various engineering disciplines. Work may include waste treatment, site remediation, or pollution control technology.

Project Owners or Plant Operators
221300
SOC Code 51-8031: Water and Wastewater Treatment Plant and System Operators - Operate or control an entire process or system of machines, often through the use of control boards, to transfer or treat water or wastewater.

541330
SOC code 17-2081: Environmental Engineers - Research, design, plan, or perform engineering duties in the prevention, control, and remediation of environmental hazards using various engineering disciplines. Work may include waste treatment, site remediation, or pollution control technology.

Livestock Farmers 
N/A
Sector 11 - Agriculture, Forestry, Fishing and Hunting. SOC code 45-2091: Agricultural Equipment Operators
 	
 		Table 3, below, provides example respondents under each respondent type, the applicable NAICS codes where appropriate, and the number of potential respondents for the program covered by this ICR. This table shows the number of potential respondents for each NAICS or sector. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 3: Number of Potential Respondents
Respondent Type
NAICS Code
Example Respondent(s)
Number of potential respondents
Project Developers
541330
Engineering firms, biogas vendors, construction companies, environmental consultants and system developers
                                      20
Project Owners or Plant Operators
221300
Water and Wastewater Treatment Plant and System Operator
                                       
                                      100
                                       

541330
AD facility operator, consulting firms/vendors (owner)
                                      60
Livestock Farmers
N/A
On-farm AD operators
                                       
                                      50
                                       
TOTAL (Year 1)
                                      230

TOTAL (Year 2)
                                      253

TOTAL (Year 3)
                                      278

Average Annual Respondents
                                      254


4(b)	Information Requested 

      (i)	Data Items, Including Recordkeeping Requirements
      
Information will be collected annually for EPA's AD facility data collection. Electronic surveys specific to digester type will be used to collect information and track updates. As stated above in Section 1(b), data collected on anaerobic digesters for EPA's AD facility data collection is intended to provide information on the capacity for recycling of food-based materials and the growth of this capacity over time. Respondents will be requested to provide data via an electronic survey designed to obtain the following information on the facilities that are within their purview:

 Project name, type, location, and operational status;
 Feedstock type, source, and volume processed;
 Digester characteristics and capacity; and
 Information on tipping fees, pre-processing/de-packaging activities, operational specifications, gas cleaning systems, and the end-use of AD products.

This information is needed to effectively track existing AD projects and their capacity for processing food and other organic wastes and to gain a better understanding of the market for AD products. EPA's initial effort compiled preliminary AD facility data based on publicly available information. This original dataset has been supplemented with information collected during the first three years of annual data collection under this ICR. 

The data on AD facilities will be collected annually for specific operational timeframes. Data collected in 2017 covered the operating year 2015, data collected in 2018 covered the operating year 2016, and data collected in 2019 covered the operating years 2017 and 2018. Upon authorization of this ICR, data will be collected from September 2020 through September 2023 for operating years 2019, 2020, and 2021. 

Project owners and operators may choose to provide information to EPA more frequently than annually if there are changes to project status, capacity, processing rates etc. However, the effort will update information made available to the public on all projects on an annual basis. Participation does not require that any records be kept, although respondents will likely maintain file copies of information submitted to EPA. 

 (ii)	Respondent Activities
      Respondents will provide the following information:
 
For first time data submittals respondents will:

          complete the electronic survey for their specific digester type (provided by EPA); and
          maintain a filed copy of the information submitted electronically (optional).

To provide annual updates to the AD facility dataset respondents will:

          provide updated information, if applicable, on the projects under the respondents' purview by completing an electronic survey (provided by EPA); and
          maintain a file copy of the information submitted electronically (optional).
         
5. THE INFORMATION COLLECTED - AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT

5(a)	Agency Activities

In requesting and receiving information under this ICR for development and maintenance of the AD facility dataset, EPA will complete the following tasks:

 Maintain a copy of all submitted data;
 Review information provided and follow up with the respondent, if necessary;
 Use information collected to enhance the existing AD facility dataset (annually); 
 Prepare a Report of Findings using the data collected; and
 Post a Report of Findings on EPA's website (annually).
         
5(b)	Collection Methodology and Management 

      EPA selected the methods for collecting this information to optimize efficiency and minimize the burden for respondents and EPA. The program will notify respondents by email with a request to complete the electronic survey. Data will be exported to EPA upon completion of the electronic survey. All information received from individual respondents (facilities) will be aggregated prior to its public release so that data from any one individual facility cannot be ascertained. Information on capacity, quantities processed, and tipping fees for individual facilities will be managed as confidential business information. 
      
      In addition, to protect personally identifiable information, EPA will not disclose the exact address of any facility or information that could be used to identify any individual responding to this survey. To allow interested parties to identify the general location of AD facilities in the United States, the name of the facility, state, city, facility type, and operational status will be shared on EPA's website in the Report of Findings. However, the survey contains a question that participants can answer to opt out of having their general location being included in the report and the Excess Food Opportunities Map. 
      
5(c)	Small Entity Flexibility 

      Many of the project owners are municipalities or cities and the project operators are employees of municipalities or cities. Both municipalities and cities are considered government entities. According to the United States Small Business Administration (SBA), government entities are not permitted to be classified as small businesses for the purposes of this analysis. 
      
      Based on the applicable thresholds for the remaining NAICS codes as established by the SBA (see: https://www.sba.gov/content/small-business-size-standards) some project developers and livestock farms may be considered small entities.  
      
      In particular, engineering firms, biogas vendors, construction companies, environmental consultants, and system developers could all be classified as small entities. 
      
      However, the average annual burden and cost per respondent requested under this ICR is estimated to be 30 minutes and $60, respectively.  The response burden does not require any capital investments, only a small amount of labor and EPA ensures that the process for responding to the AD electronic surveys is as efficient as possible through automatic data submission at the completion of the survey. This annual burden and cost is not expected to pose a significant burden on small entities. In addition, a response is requested by EPA, but not required and respondents may choose not to respond. 
      
5(d)	Collection Schedule

      EPA will collect information annually for the AD facility data collection via electronic surveys. Data input by the respondents will be exported to EPA in spreadsheet form.
      
6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION 

6(a)	Estimating Respondent Burden

      To obtain accurate hourly burden and cost estimates, EPA consulted with three stakeholders in 2018 regarding burden and cost assumptions. These stakeholders provided feedback on the survey revisions incorporated into this ICR renewal. 
      
      The overall burden has not changed in this ICR, which was previously approved for one year by OMB in September 2019.  
      
      
Table 4: Total Burden Hours for SMF AD Data Collection (3 Year Period)
Respondent Type
NAICS Code
Total Burden (hours) for 3-year ICR period (September 2020  -  September 2023)
Project Developers
                                    541330
                                      34
Project Owners or Plant Operators
                                    221300
                                      166

                                    541330
                                      100
Livestock Farmers 
                                      N/A
                                      83
TOTAL
                                       
                                      382
Average Annual Burden Hours
                                      127

      
      The burden hours listed in the table above are based on the following assumption: each annual AD facility data collection requires 30 minutes (or less). The burden hour estimates displayed in Table 4 are rounded to the nearest hour. The respondent costs, including wage rate assumptions, are described below. Table 6 presents the estimated total respondent costs during the 3-year ICR period for each type of respondent, using the wage rates outlined in Table 5.
      
6(b)	Estimating Respondent Costs

             Estimating Labor Costs
            
      For each respondent type and NAICS code, EPA used the mean hourly wage for the applicable SOC codes, which are listed in Table 5, below. Since there are no SOC codes associated with the Livestock Farming NAICS codes, we are using the SOC codes for the appropriate agricultural sector (Sector 11 - Agriculture, Forestry, Fishing and Hunting - SOC code 45-2091: Agricultural Equipment Operators). Labor rates were not divided into clerical, legal, or other labor sub-categories for a specific NAICS code since respondents subject to the information collection effort will be primarily engineers/scientists. Rates were obtained from the Bureau of Labor Statistics' May 2019 National Industry-Specific Occupational Employment and Wage Estimates (see: http://www.bls.gov/oes/current/oessrci.htm#11). The total labor rate used to calculate cost was obtained by applying an overhead rate of 110 percent. 
       
Table 5: Mean Hourly Wages by Respondent Type and SOC Code
Respondent Type
NAICS Code
SOC code
May 2019
Mean Hourly Wage ($)
May 2019
Mean Hourly Wage ($)
(+110% overhead)
Project Developers
541330
SOC code 17-2081: Environmental Engineers
                                       
                                     46.74
                                       
                                     98.15
Project Owners and Plant Operators
221300
SOC Code 51-8031: Water and Wastewater Treatment Plant and System Operators
                                       
                                     23.26
                                       
                                     48.85

541330
SOC code 17-2081: Environmental Engineers
                                       
                                     46.74
                                       
                                     98.15
Livestock Farmers
N/A (Using Sector 11  -  Agriculture, Forestry, Fishing and Hunting)
SOC code 45-2091: Agricultural Equipment Operators 
                                       
                                     15.30
                                       
                                     32.13





 	
             Estimating Capital and Operations and Maintenance Costs
            
      Because this information collection requires respondents only to report information that is already available to them, there are no capital costs. EPA does not expect that the operations and maintenance (O&M) costs of this program will be significant. The total costs for this information collection are summarized in Table 6, below, and are rounded to the nearest dollar. The total cost values are based on the fully loaded labor rates that include overhead as shown in Table 5 and the total burden hours in Table 4.

Table 6: Summary of Respondent Burden  -  Total Cost for SMF AD Data Collection (3 Year Period)
Respondent Type
NAICS Code
  Total Burden Cost ($) for 3-year ICR period (October 2020  -  October 2023)
Project Developers
                                    541330
                                        
                                     3,337
Project Owners or Plant Operators
                                    221300
                                       
                                     8,109

                                    541330
                                       
                                     9,815
Livestock Farmers 
                                      N/A
                                       
                                     2,667
TOTAL
                                       
                                    23,928
Average Annual Burden Cost
                                       
                                     7,976

	The total cost for the entire 3-year ICR period is $23,928. This represents the total overall cost for the respondent portion of this ICR since there are no capital expenditures or O&M costs.

6(c)	Estimating Agency Burden and Costs 

The following is a summary of the Agency burden associated with each activity, as described in Section 5(a). 

 Maintain all submitted data received automatically through electronic surveys
   Clerical: 2 hours per update (updates are annual; 2 hours per year)
 Review the information provided and follow up with the respondent, if necessary
         Technical: 40 hours per update (updates are annual; 40 hours per year) 
 Use information collected to enhance the existing AD facility dataset (annually) 
         Technical: 40 hours (updates are annual; 40 hours per year) 
 Prepare a Report of Findings using the data collected
   Technical: 120 hours (Technical Report will be produced annually; 8 hours per year) 
 Review Report of Findings 
         Managerial: 8 hours 
 Post AD facility data collection data on the EPA website
Technical: 8 hours per update (updates are annual; 8 hours per year)
      
      Tables 7a and 7b present the estimated total Agency burden hours and costs, respectively, for the information collection activities associated with this ICR. The burden hours in Table 7a reflect the entire 3-year period covered by this ICR. The totals are rounded to the nearest hour. To obtain an hourly burden estimate for the entire ICR period, annual time estimates for each relevant labor category, as described above, were multiplied by three because all activities will be conducted annually. The totals in Table 7b reflect the associated cost by labor category based on the total burden hours presented in Table 7a. 
          
EPA estimates an average hourly cost using set EPA salary rates for labor plus an additional 60 percent for overhead. To derive these estimates, EPA used the "Salary Table 2020 - GS" from the Department of Personnel Management (see: https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2020/GS_h.pdf). For purposes of this ICR, EPA assigned staff the following government service levels: (1) Managerial Staff GS-15, Step 1; (2) Technical Staff - GS-13, Step 2; and (3) Clerical Staff - GS-5, Step 1. The corresponding salary rates are $52.40 for managerial staff, $35.93 for technical staff and $14.43 for clerical staff. When the 60 percent overhead is included, the corresponding rates are $83.84 for managerial staff, $57.48 for technical staff and $23.09 for clerical staff. 

Table 7a: Total Agency Burden Hours 

Labor Category
                         Total Agency Burden (hours):
                         October 2020  -  October 2023
Managerial (GS 15, step 1)
                                      24
Technical (GS-13, step 2)
                                      624
Clerical (GS-5, step 1)
                                       6
TOTAL
                                      654
Average Annual Burden Hours
                                      218
		

Table 7b: Total Agency Cost 
Labor Category
                            Total Agency Cost ($):
                         October 2020  -  October 2023
                    Total Agency Cost +  60% Overhead ($):
                         October 2020  -  October 2023
Managerial (GS-15, step 1)
                                     1,257
                                     2,012
Technical (GS-13, step 2)
                                    22,420
                                    25,872
Clerical (GS-5, step 1)
                                     86.58
                                      138
TOTAL ($)
                                    23,764
                                    38,023
Average Annual Costs
                                     7,921
                                    12,674
 		
Table 7b presents the total cost to the Agency as described in Section 5(a). The total Agency burden for the relevant ICR period is 654 hours and the total cost is $38,023.

6(d)	Estimating the Respondent Universe

These burden estimates are based on the total respondent universe.

Table 8a: Total Hours (3 Year Period)

                                 Total Hours:
                         October 2020  -  October 2023
AGENCY BURDEN 
                                      654
RESPONDENT BURDEN
                                      382
 	
 	
Table 8b: Total Costs (3 Year Period)

                                Total Cost ($):
                         October 2020  -  October 2023
AGENCY COST
                                    38,023
RESPONDENT COST
                                    23,928
O&M/Capital Costs
                                       0
 		
6(e)	Bottom Line Burden Hours and Costs

Over the 3-year period covered by this ICR, EPA estimates the total respondent burden to be 382 hours and $23,928. There are no O&M or capital costs. EPA estimates the total Agency burden to be 654 hours and $38,023. The annual respondent burden and cost, averaged over the three-year period, is 127 hours and $7,615, respectively. The annual Agency burden and cost, averaged over the three-year period, is 218 hours and $12,674. 

6(f)		Reasons for Change in Burden 

      The respondent burden remains unchanged in this renewal ICR.  

6(g)	Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average approximately 30 minutes per response. 

Burden means the total time, effort or financial resources expended by persons to generate, maintain, retain, and disclose or provide information to or for a federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.

      To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket OLEM-2020-0259, which is available for online viewing at www.regulations.gov, or in person viewing at the Resource Conservation and Recovery Act Docket in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave. NW, Washington, DC. The EPA/DC Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is 202-566-1744, and the telephone number for the Resource Conservation and Recovery Act Docket is 202-566-0270.
      
	An electronic version of the public docket is available at www.regulations.gov. This site can be used to submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronically. When in the system, select "search," then key in the Docket ID Number identified above. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-RCRA-2015-0836 and OMB Control Number 2050-0217 in any correspondence. 
