SUPPORTING
STATEMENT
FOR
INFORMATION
COLLECTION
REQUEST
NUMBER
1935.01
"
STANDARDIZED
PERMIT
FOR
RCRA
HAZARDOUS
WASTE
MANAGEMENT
FACILITIES"

November
22,
1999
Table
of
Contents
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
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1
1(
a)
Title
and
Number
of
the
Information
Collection
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1
1(
b)
Short
Characterization
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1
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
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7
2(
a)
Need
and
Authority
for
the
Collection
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7
2(
b)
Practical
Utility
and
Users
of
the
Data
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13
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
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16
3(
a)
Nonduplication
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16
3(
b)
Public
Notice
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16
3(
c)
Consultations
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16
3(
d)
Effects
of
Less
Frequent
Collection
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16
3(
e)
General
Guidelines
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17
3(
f)
Confidentiality
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17
3(
g)
Sensitive
Questions
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17
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
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18
4(
a)
Respondents
and
SIC
Codes
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18
4(
b)
Information
Requested
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19
5.
THE
INFORMATION
COLLECTED
­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
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66
5(
a)
Agency
Activities
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66
5(
b)
Collection
Methodology
and
Management
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68
5(
c)
Small
Entity
Flexibility
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68
5(
d)
Collection
Schedule
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68
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
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70
6(
a)
Estimating
Respondent
Burden
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70
6(
b)
Estimating
Respondent
Costs
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70
6(
c)
Estimating
Agency
Burden
and
Costs
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71
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Cost
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95
6(
e)
Bottom
Line
Burden
Hours
and
Costs
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103
6(
f)
Reasons
for
Change
In
Burden
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105
6(
g)
Burden
Statement
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105
List
of
Tables
Table
1:
Captive
Facilities
that
Treat
and/
or
Store
Hazardous
Waste
in
Containers,
Tanks,
and
Containment
Buildings
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95
Table
2:
Captive
Treatment
and/
or
Storage
Facilities
Expected
to
Apply
for
a
Standardized
Permit
Annually
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97
List
of
Exhibits
Estimated
Annual
Respondent
Burden
and
Cost
Exhibit
1:
Applying
for
a
Standardized
Permit
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72
Exhibit
2:
Maintaining
a
Standardized
Permit
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76
Exhibit
3:
General
Facility
Standards
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77
Exhibit
4:
Preparedness
and
Prevention
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79
Exhibit
5:
Contingency
Plan
and
Emergency
Procedures
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80
Exhibit
6:
Record
Keeping,
Reporting,
and
Notifying
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81
Exhibit
7:
Closure
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82
Exhibit
8:
Financial
Requirements
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83
Exhibit
9:
Specific
Unit
Requirements
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87
Estimated
Annual
Agency
Burden
and
Cost
Exhibit
10:
Applying
for
a
Standardized
Permit
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89
Exhibit
11:
Maintaining
a
Standardized
Permit
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89
Exhibit
12:
General
Facility
Standards
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90
Exhibit
13:
Preparedness
and
Prevention
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91
Exhibit
14:
Contingency
Plan
and
Emergency
Procedures
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91
Exhibit
15:
Record
Keeping,
Reporting,
and
Notifying
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92
Exhibit
16:
Closure
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92
Exhibit
17:
Financial
Requirements
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93
Exhibit
18:
Specific
Unit
Requirements
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94
Exhibit
19:
Total
Estimated
Annual
Respondent
Burden
and
Cost
Summary
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104
Exhibit
20:
Total
Estimated
Annual
Agency
Burden
and
Cost
Summary
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104
1
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
and
Number
of
the
Information
Collection
This
Information
Collection
Request
(
ICR)
is
entitled
"
Standardized
Permit
for
RCRA
Hazardous
Waste
Management
Facilities,"
ICR
Number
1935.01.

1(
b)
Short
Characterization
Under
the
authority
of
sections
3004,
3005,
3008
and
3010
of
the
Resource
Conservation
and
Recovery
Act
(
RCRA),
as
amended,
the
U.
S.
Environmental
Protection
Agency
(
EPA)
is
proposing
revisions
to
the
RCRA
hazardous
waste
permitting
program
to
allow
a
"
standardized
permit."
The
standardized
permit
would
be
available
to
facilities
that
generate
hazardous
waste
and
routinely
manage
the
waste
on­
site
in
non­
thermal
units
such
as
tanks,
containers,
and
containment
buildings.
The
RCRA
standardized
permit
would
consist
of
two
components:
a
uniform
portion
that
is
included
in
all
cases,
and
a
supplemental
portion
that
the
Director
of
a
regulatory
agency
would
include
at
his
or
her
discretion.
The
uniform
portion
would
consist
of
terms
and
conditions,
relevant
to
the
unit(
s)
at
the
permitted
facility,
and
would
be
established
on
a
national
basis.
The
Director,
at
his
or
her
discretion,
may
also
issue
a
supplemental
portion
on
a
case­
by­
case
basis.
The
supplemental
portion
would
impose
site­
specific
permit
terms
and
conditions
that
the
Director
determines
necessary
to
institute
corrective
action
under
section
264.101
(
or
State
equivalent),
or
otherwise
necessary
to
protect
human
health
and
the
environment.
Owners
and
operators
would
have
to
comply
with
the
terms
and
conditions
in
the
supplemental
portion,
in
addition
to
those
in
the
uniform
portion.

This
ICR
presents
a
comprehensive
description
of
the
information
collection
requirements
for
owners
and
operators
submitting
applications
for
a
standardized
permit
or
a
standardized
permit
modification
under
the
proposed
rule.
This
ICR
also
estimates
the
total
annual
burden
and
cost
to
respondents
and
government
agencies
under
the
proposed
rule.

In
the
following
paragraphs,
EPA
briefly
describes
the
information
collection
requirements
in
the
proposed
rule.

APPLYING
FOR
A
STANDARDIZED
PERMIT
Under
40
CFR
124.202,
an
owner
or
operator
wishing
to
apply
for
a
standardized
permit
must
submit
to
the
Director
a
written
notice
of
his
or
her
intent
to
operate
under
the
standardized
permit.
Along
with
this
notice
of
intent,
section
270.275
requires
that
the
applicant
submits
to
the
permitting
agency
information
(
e.
g.,
summary
of
the
pre­
application
public
meeting,
a
signed
certification
of
the
facility's
compliance
with
part
267)
that
will
be
used
as
the
basis
of
the
standardized
permit
application.
Owners
and
operators
whose
facilities
are
not
in
compliance
with
part
267
at
the
time
they
submit
their
notice
of
intent
must
submit
a
schedule
of
compliance
to
the
Director.
This
schedule
must
include
an
enforceable
sequence
of
actions
with
milestones,
2
leading
to
compliance
with
the
requirements
for
which
the
facility
is
in
noncompliance
at
the
time
the
notice
of
intent
is
submitted
(
section
270.285).

40
CFR
270.290
requires
owners
and
operators
operating
under
a
standardized
permit
to
keep
general
types
of
information
at
their
facilities.
This
information
includes,
among
other
things,
a
general
description
of
the
facility;
a
copy
of
the
waste
analysis
plan
and
chemical
and
physical
analyses
of
the
hazardous
waste
and
hazardous
debris
handled
at
the
facility;
a
copy
of
the
general
inspection
schedule;
a
copy
of
the
contingency
plan;
a
description
of
employee
training
programs;
a
copy
of
the
closure
plan;
and
documentation
showing
compliance
with
liability
requirements.

In
addition,
the
proposal
establishes
unit­
specific
record
keeping
requirements:


Owners
and
operators
that
store
or
treat
hazardous
waste
in
containers
must
keep
at
their
facility
information
on
the
design
and
operation
of
the
container
storage
area
,
including
its
containment
system.
In
addition,
they
must
keep
information
demonstrating
compliance
with
special
requirements
for
ignitable
or
reactive
waste
and
for
incompatible
wastes,
as
specified
in
section
267.174
and
section
267.175,
respectively.
(
section
270.300)


Owners
and
operators
that
store
or
treat
hazardous
waste
in
tanks
must
keep
at
their
facility
tank
system
information.
This
information
deals
with
design,
construction,
and
operation
parameters.
(
section
270.305)


Owners
and
operators
of
facilities
with
equipment
subject
to
part
264,
subpart
BB
requirements
(
air
emissions
standards
for
equipment
leaks)
must
keep
at
their
facility
information
required
for
that
type
of
equipment.
These
information
requirements
concern
emission
standards
for
equipment
that
contains
or
comes
in
contact
with
hazardous
waste
with
organic
concentrations
of
at
least
10
percent
by
weight.
(
section
270.310)


Owners
and
operators
of
facilities
with
tanks
or
containers
must
keep
at
their
facility
information
required
for
tanks
and
containers
subject
to
part
264,
subpart
CC
(
air
emission
standards
for
tanks,
surface
impoundments,
and
containers).
These
information
requirements
concern
compliance
with
air
emission
controls
that
apply
to
facilities
managing
hazardous
waste
in
tanks
and
containers.
(
section
270.315)

Finally,
section
270.10(
h)
requires
owners
and
operators
wishing
to
reapply
for
a
standardized
permit
to
submit
a
notice
of
intent
under
270.10(
b)(
1)
at
least
180
days
before
the
expiration
date
of
the
effective
permit.
3
MAINTAINING
A
STANDARDIZED
PERMIT
Sections
124.212,
124.213,
and
270.320
specify
procedures
for
making
routine
and
significant
changes
to
the
standardized
permit.
Sections
124.212
and
270.320(
a)
require
owners
and
operators
seeking
to
make
routine
changes
(
Class
1
or
Class
2
permit
modifications
under
40
CFR
270.42,
Appendix
I)
to
their
standardized
permits
to
submit
to
the
Director
the
revised
information
pursuant
to
section
270.267(
b)(
1);
and
to
provide
notice
of
the
changes
to
the
facility
mailing
list
and
to
state
and
local
governments,
in
accordance
with
the
procedures
in
sections
124.10(
c)(
1)(
ix)
and
(
x).
Sections
124.213
and
270.320(
b)
require
owners
and
operators
seeking
to
make
significant
changes
(
based
on
the
criteria
specified
in
sections
270.320(
b)(
1)­(
3)
to
their
standardized
permits
to
provide
notice
and
conduct
a
public
meeting.
After
holding
the
public
meeting,
the
owner
or
operator
of
the
facility
must
submit
a
modification
request
to
the
Director.

GENERAL
FACILITY
STANDARDS
40
CFR
part
267,
subpart
B
(
sections
267.10
through
267.18)
specifies
general
facility
standards
that
apply
to
owners
and
operators
of
facilities
who
treat
or
store
hazardous
waste
under
a
standardized
permit.
To
comply
with
this
subpart,
owners
and
operators
must
obtain
an
EPA
identification
number
(
section
267.12)
and
follow
requirements
for
waste
analyses
(
section
267.13);
security
(
section
267.14);
inspections
(
section
267.15);
employee
training
(
section
267.16);
management
of
ignitable,
reactive,
or
incompatible
wastes
(
section
267.17);
and
facility
location
(
section
267.18).
EPA
enables
owners
and
operators
to
apply
for
a
waiver
from
the
security
requirements
if
they
believe
that
physical
contact
with
the
waste,
structures,
or
equipment
within
the
active
portion
of
the
facility
will
not
injure
people
or
livestock,
or
that
disturbing
the
waste
or
the
equipment
will
not
cause
a
violation
of
the
requirements
of
part
267
(
section
267.14(
a)).

PREPAREDNESS
AND
PREVENTION
Under
40
CFR
part
267,
subpart
C,
owners
and
operators
of
facilities
that
treat
or
store
hazardous
waste
under
a
standardized
permit
must
design,
construct,
maintain,
and
operate
their
facilities
to
minimize
the
possibility
of
a
fire,
explosion,
or
any
unplanned
sudden
or
non­
sudden
release
of
hazardous
waste
or
hazardous
waste
constituents
to
air,
soil,
or
surface
water
that
could
threaten
human
health
or
the
environment.
Specifically,
section
267.36
states
that
the
owners
and
operators
of
these
facilities
must
attempt
to
make
arrangements
with
the
police,
fire
departments,
emergency
response
teams,
and
hospitals,
as
appropriate
for
the
type
of
waste
handled
at
the
facility
and
the
potential
need
for
services
of
these
organizations.
If
State
or
local
authorities
decline
to
enter
into
such
arrangements,
the
owner
or
operator
of
the
facility
must
document
the
refusal
in
the
operating
record.
4
CONTINGENCY
PLAN
AND
EMERGENCY
PROCEDURES
40
CFR
part
267,
subpart
D
(
sections
267.50
through
267.58)
requires
owners
and
operators
of
a
facility
under
a
standardized
permit
to
prepare
and
maintain
updated
contingency
plans
and
comply
with
emergency
reporting
and
record
keeping
requirements.
The
contingency
plan
describes
the
actions
facility
personnel
will
take
should
a
fire,
explosion,
or
any
unplanned
sudden
or
non­
sudden
release
of
hazardous
waste
constituents
to
air,
soil,
or
surface
water
occur.
Local
emergency
response
teams
use
the
information
required
in
the
contingency
plan
to
minimize
unanticipated
damage
from
the
treatment,
storage,
or
disposal
of
hazardous
waste.
The
contingency
plan
also
enables
EPA
to
assess
the
effectiveness
of
facility
responses
to
incidents
that
may
threaten
human
health
or
the
environment.

Other
emergency
reporting
and
record
keeping
requirements
under
40
CFR
part
267,
subpart
D,
include
notifying
State
and
local
authorities
of
an
imminent
or
actual
emergency
situation
(
267.56(
a)(
2),
and
notifying
local
authorities
of
the
need
to
evacuate
local
areas
(
267.56(
c)(
1)).
If
a
release,
fire,
or
explosion
occurs,
the
owner
or
operator
must
notify
the
onscene
coordinator
or
the
National
Response
Center
(
267.56(
c)(
2)).
Owners
and
operators
also
must
notify
the
Regional
Administrator
that
a
facility
is
in
compliance
with
specific
regulations
before
operations
resume
in
any
area
affected
by
an
emergency
situation
(
267.58(
a)),
and
submit
a
report
to
the
Regional
Administrator
containing
details
of
any
emergency
situation
that
requires
implementation
of
the
contingency
plan
(
267.58(
b)).

RECORD
KEEPING,
REPORTING,
AND
NOTIFYING
40
CFR
part
267,
subpart
E
(
sections
267.70
through
267.74)
directs
owners
and
operators
of
facilities
that
treat
or
store
hazardous
waste
under
a
standardized
permit
to
keep
written
operating
records
at
their
facilities.
Since
the
operating
record
is
not
submitted
to
EPA
but
must
be
available
for
inspection,
maintaining
an
operating
record
is
a
record
keeping
activity.
The
operating
record
contains
information
regarding
general
operating
practices
conducted
at
the
facility.
Other
record
keeping
requirements
under
40
CFR
part
267,
subpart
E,
include
maintaining
records
of
the
location
of
each
hazardous
waste
within
the
facility
and
the
quantity
at
each
location
(
267.71(
b)(
2)).
In
addition,
40
CFR
267.36(
b)
requires
facilities
to
document
in
the
operating
record
any
refusal
of
State
or
local
authorities
to
enter
into
arrangements
for
emergency
situations.
Information
collected
pursuant
to
these
regulations
is
used
by
EPA
and
the
owner
or
operator
to
assure
safe
operation
of
the
facility.

Section
267.73
requires
owners
and
operators
to
prepare
and
submit
a
single
copy
of
a
biennial
report
to
the
Regional
Administrator
by
March
1
of
each
calendar
year.
In
addition
to
submitting
the
biennial
reports,
owners
and
operators
must
report
to
the
Regional
Administrator
releases,
fires,
and
explosions;
facility
closures;
and
as
otherwise
required
by
subparts
I,
J,
and
DD
of
40
CFR
part
267
and
subparts
BB
and
CC
of
40
CFR
part
264.
5
Section
267.74
requires
that,
before
transferring
ownership
or
operation
of
a
facility
during
its
operating
life,
an
owner
or
operator
must
notify
the
new
owner
or
operator
in
writing
of
the
requirements
of
parts
267
and
270.

CLOSURE
40
CFR
part
267,
subpart
G
(
sections
267.110
through
267.117)
specifies
the
procedures
that
owners
and
operators
of
a
facility
that
treat
hazardous
waste
under
a
standardized
permit
must
follow
when
closing
storage
and
treatment
units
and/
or
when
closing
the
facility.
Storage
and
treatment
units
must
be
closed
in
a
manner
that
minimizes
need
for
further
maintenance
and
controls,
minimizes,
or
eliminates,
to
the
extent
necessary
to
protect
human
health
and
the
environment,
post­
closure
escape
of
hazardous
waste,
hazardous
constituents,
leachate,
contaminated
runoff,
or
hazardous
waste
decomposition
products
to
the
ground
or
surface
waters
or
to
the
atmosphere
(
section
267.111).
To
close
a
facility,
the
owner
or
operator
must
have
an
approved
closure
plan
and
follow
notification
requirements
(
section
267.112).
In
addition,
owners
and
operators
are
required
to
submit
to
the
Director
a
certification
of
closure
within
60
days
of
the
completion
of
final
closure
of
each
unit
under
a
standardized
permit
(
section
267.117).

EPA
uses
closure
plans
to
ensure
that
hazardous
waste
management
facilities
close
in
accordance
with
the
Congressional
mandate
of
protecting
human
health
and
the
environment.
EPA
reviews
closure
certifications
to
determine
whether
closure
took
place
in
accordance
with
the
approved
closure
plan
and
EPA,
local
authorities,
and
potential
purchasers
of
a
closed
facility
review
closure
notices
to
ensure
that
future
uses
of
the
site
will
not
lead
to
a
release
of
hazardous
waste.

FINANCIAL
REQUIREMENTS
40
CFR
part
267,
subpart
H
(
sections
267.140
through
267.150)
establishes
financial
responsibility
requirements
for
owners
and
operators
who
treat
or
store
hazardous
waste
under
a
standardized
permit.
Owners
and
operators
must
prepare
a
closure
cost
estimate
(
section
267.142),
demonstrate
financial
assurance
for
closure
(
section
267.143),
and
demonstrate
financial
assurance
for
liability
(
section
267.147).
Owners
and
operators
also
are
required
to
submit
a
notification
of
the
commencement
of
a
voluntary
or
involuntary
proceeding
under
Title
11
(
Bankruptcy),
U.
S.
Code,
naming
the
owner
or
operator
as
debtor
(
if
the
guarantor
is
named
as
the
debtor,
the
collection
of
this
data
is
the
guarantor's
responsibility)
(
section
267.148).
Finally,
owners
and
operators
are
required
to
notify
EPA
when
a
State
assumes
legal
responsibility
or
assures
availability
of
funds
for
an
owner's
or
operator's
compliance
with
the
closure,
post­
closure
care,
or
liability
requirements
of
this
part
(
section
267.150).
6
USE
AND
MANAGEMENT
OF
CONTAINERS
40
CFR
part
267,
subpart
I
(
sections
267.170
through
267.177)
specifies
the
standards
for
the
use
and
management
of
containers
under
a
standardized
permit.
These
standards
apply
to,
for
example,
the
condition
of
the
containers,
to
the
compatibility
of
waste
with
the
containers,
and
to
the
management
of
the
containers,
and
the
control
of
air
emissions
from
containers.
Section
267.172
requires
owners
and
operators
that
store
or
treat
hazardous
waste
in
containers
to
inspect
areas
where
they
store
containers,
at
least
weekly.
During
these
inspections,
owners
and
operators
should
look
for
leaking
containers
and
for
deterioration
of
containers
and
the
containment
system
caused
by
corrosion
or
other
factors.

TANK
SYSTEMS
40
CFR
part
267,
subpart
J
(
sections
267.190
through
267.204)
specifies
the
standards
for
above­
ground
and
on­
ground
tanks
used
for
the
treatment
or
storage
of
hazardous
waste
under
a
standardized
permit.
These
standards
require
record
keeping
and
reporting
associated
with
demonstrations
for
secondary
containment
waivers
(
section
267.190),
design
and
construction
standards
(
section
267.191),
installation
requirements
(
section
267.194),
inspection
requirements
(
section
267.199),
leaks
and
spills
(
section
267.200),
closure
of
tanks
(
section
267.201),
special
requirements
for
reactive,
ignitable,
and
incompatible
wastes
(
sections
267.202
and
267.203),
and
control
of
air
emissions
(
section
267.204).

CONTAINMENT
BUILDINGS
40
CFR
part
267,
subpart
DD
(
sections
267.1100
through
267.1108)
specifies
standards
applicable
to
containment
buildings
under
a
standardized
permit.
These
standards
require
record
keeping
and
reporting
associated
with
inspections
(
section
267.1103);
demonstrations
for
secondary
containment
requirement
waivers
(
section
267.1104);
containment
buildings
containing
areas
both
with
and
without
secondary
containment
(
section
267.1105);
and
detection
of
releases
(
section
267.1106).
7
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need
and
Authority
for
the
Collection
This
section
describes
the
need
and
authority
for
each
type
of
information
collection
analyzed
in
this
ICR.
Information
collection
requirements
in
the
standardized
permit
proposal
are
authorized
by
sections
2002
and
3007
of
RCRA,
as
amended.
In
particular,
section
2002
gives
the
Administrator
the
authority
to
promulgate
such
regulations
as
are
necessary
to
carry
out
the
functions
of
this
subchapter.
Section
3007
gives
EPA
the
authority
to
compel
anyone
who
generates,
stores,
treats,
transports,
disposes
of
or
otherwise
handles
or
has
handled
hazardous
wastes
to
"
furnish
information
related
to
such
wastes"
and
make
such
information
available
to
the
government
for
"
the
purposes
of
...
enforcing
the
provisions
of
this
chapter."
EPA
believes
the
information
collection
requirements
in
the
proposal
are
necessary
to
balance
the
reduction
in
regulatory
burden
with
the
Agency's
responsibility
to
protect
human
health
and
the
environment.

APPLYING
FOR
A
STANDARDIZED
PERMIT
Section
270.275
requires
that
applicants
for
a
standardized
permit
submit
to
the
permitting
agency
information
that
will
be
used
as
the
basis
of
the
standardized
permit
application.
This
information
includes:


Part
A
permit
information
required
by
section
270.13;


A
summary
of
the
pre­
application
public
meeting
and
other
materials
required
by
section
124.31;


Documentation
of
compliance
with
the
location
standards
of
sections
267.18
and
270.14(
b)(
11);


Information
that
allows
the
Director
to
carry
out
his
obligations
under
other
Federal
laws
required
in
section
270.3;


Solid
waste
management
unit
information
required
by
section
270.14(
d);
and

A
signed
certification
of
the
facility's
compliance
with
part
267,
as
specified
at
section
270.280.

EPA
needs
this
information
to
comprehensively
evaluate
the
potential
risk
posed
by
facilities
seeking
permits.
This
information
aids
EPA
in
meeting
its
goal
of
ascertaining
and
minimizing
risks
to
human
health
and
the
environment
from
hazardous
waste
management
facilities.

In
addition,
facilities
that
store
or
treat
hazardous
waste
under
a
standardized
permit
must
keep
at
their
facilities
general
types
of
information
(
section
270.290),
as
well
as
unit­
specific
8
information
for
containers
(
section
270.300),
tanks
(
section
270.305),
equipment
subject
to
part
264,
subpart
BB
(
section
270.310),
and
tanks
and
containers
subject
to
part
264,
subpart
CC
(
section
270.315).
EPA
anticipates
that
the
owner
or
operator
will
use
this
information
to
ensure
that
tanks,
containers,
and
other
equipment
are
in
good
condition
and
that
operating
requirements
are
being
satisfied,
and
to
prevent
placing
in
proximity
wastes
that
are
incompatible
with
other
wastes
that
are
likely
to
ignite
or
explode.
EPA
needs
this
information
to
evaluate
compliance
of
facilities
with
the
permitting
standards.
These
requirements
contribute
to
EPA's
goal
of
insuring
that
hazardous
waste
management
facilities
are
operated
in
a
manner
fully
protective
of
human
health
and
the
environment.

MAINTAINING
A
STANDARDIZED
PERMIT
Sections
124.212,
124.213,
and
270.320
specify
procedures
for
making
routine
and
significant
changes
to
the
standardized
permit.
Sections
124.212
and
270.320(
a)
require
owners
and
operators
seeking
to
make
routine
changes
to
their
standardized
permits,
which
amend
the
information
submitted
with
the
notice
of
intent
to
operate
under
a
standardized
permit,
to
submit
to
the
Director
the
revised
information
pursuant
to
section
270.267(
b)(
1).
Owners
and
operators
are
also
required
to
provide
notice
of
the
changes
to
the
facility
mailing
list
and
to
state
and
local
governments,
in
accordance
with
the
procedures
in
sections
124.10(
c)(
1)(
ix)
and
(
x).
Sections
124.213
and
270.320(
b)
require
owners
and
operators
seeking
to
make
significant
changes
(
based
on
the
criteria
specified
in
section
270.320(
b)(
1)­(
3))
to
their
standardized
permits
to
provide
notice
and
conduct
a
public
meeting.
After
holding
the
public
meeting,
the
owner
or
operator
of
the
facility
must
submit
a
modification
request
to
the
Director.

EPA
needs
this
information
to
comprehensively
evaluate
whether
requests
for
routine
or
significant
changes
should
be
granted.
The
permit
modification
procedures
contribute
to
EPA's
goal
of
providing
a
role
for
the
public
in
the
permitting
process.
In
general,
these
informational
requirements
aid
in
meeting
EPA's
goal
of
ascertaining
and
minimizing
risks
to
human
health
and
the
environment
from
hazardous
waste
management
facilities.

GENERAL
FACILITY
STANDARDS
40
CFR
part
267,
subpart
B
(
sections
267.10
through
267.18)
specifies
general
facility
standards
that
apply
to
owners
and
operators
of
facilities
who
treat
or
store
hazardous
waste
under
a
standardized
permit.
To
comply
with
this
subpart,
owners
and
operators
must
follow
record
keeping
and
reporting
requirements
for
waste
analyses
(
section
267.13);
security
(
section
267.14);
inspections
(
section
267.15);
employee
training
(
section
267.16);
management
of
ignitable,
reactive,
or
incompatible
wastes
(
section
267.17);
and
facility
location
(
section
267.18).
9
(
1)
Waste
Analyses
EPA
and
owners
and
operators
use
information
obtained
in
waste
analysis
results
to
determine:
(
1)
whether
the
facility
can
adequately
handle
the
waste,
and
(
2)
whether
the
waste
is
really
what
the
generator
claims
it
to
be.
The
owner
or
operator
also
uses
information
obtained
from
the
waste
analysis
to
determine
whether
there
are
any
potential
dangers
from
handling
the
waste.

(
2)
Security
EPA
uses
information
on
security
to
ensure
that
the
owner
and
operator
of
the
facility
has
taken
the
necessary
measures
to
ensure
that
there
is
no
physical
contact
with
the
waste,
structures,
or
equipment
within
the
active
portion
of
the
facility
that
would
injure
people
or
livestock.

(
3)
Inspections
EPA
and
owners
and
operators
use
information
in
the
inspection
log
to
determine
whether
facility
equipment
is
safe
for
handling
hazardous
waste.
The
inspection
requirement
contributes
to
EPA's
goal
of
preventing
hazardous
waste
constituents
from
being
released
into
the
environment
due
to
faulty
or
deteriorated
equipment.

(
4)
Employee
Training
Both
EPA
and
owners
and
operators
use
information
in
employee
training
records
to
determine
whether
employees
have
acquired
the
necessary
expertise
to
perform
their
jobs.
EPA
also
reviews
personnel
records
to
determine
whether
employees
are
receiving
a
level
of
training
that
is
commensurate
with
their
duties
and
responsibilities
as
well
as
their
ability
to
respond
to
any
emergency
situations
at
the
facility.
Requiring
owners
and
operators
to
maintain
personnel
training
documents
decreases
the
likelihood
that
employees
are
unqualified
to
handle
hazardous
waste
or
respond
to
emergencies.
The
personnel
record
keeping
requirement
contributes
to
EPA's
goal
of
minimizing
the
potential
for
employee­
related
mistakes
that
may
threaten
human
health
and
the
environment.

(
5)
Demonstration
of
Compliance
for
Ignitable,
Reactive,
or
Incompatible
Wastes
EPA
uses
information
in
the
documentation
of
compliance
for
ignitable,
reactive,
or
incompatible
wastes
to
determine
whether
facilities
are
operating
in
a
manner
that
is
protective
of
human
health
and
the
environment.
The
documentation
requirement
contributes
to
EPA's
goal
of
minimizing
unanticipated
damage
from
the
treatment,
storage,
or
disposal
of
hazardous
waste.
10
(
6)
Facility
Location
EPA
and
owners
and
operators
use
site­
specific
information
to
determine
whether
a
location
is
suitable
for
conducting
hazardous
waste
management
activities
in
a
manner
that
does
not
pose
a
threat
to
human
health
or
the
environment.
In
addition,
EPA
uses
the
site­
specific
information
in
determining
if
a
waiver
should
be
issued
to
a
facility.

EPA
needs
all
the
information
described
above
to
evaluate
the
compliance
of
facilities
with
the
permitting
standards.
These
requirements
contribute
to
EPA's
goal
of
insuring
that
hazardous
waste
management
facilities
are
operated
in
a
manner
fully
protective
of
human
health
and
the
environment.

PREPAREDNESS
AND
PREVENTION
Sections
267.30
through
267.36
require
owners
and
operators
to
design,
construct,
maintain,
and
operate
their
facilities
in
a
manner
that
minimizes
threats
to
human
health
and
the
environment
caused
by
the
release
of
waste
from
a
fire,
explosion,
or
any
unplanned
event.
Section
267.36(
b)
specifically
requires
owners
and
operators
to
document
any
refusal
on
the
part
of
any
local
authorities
to
enter
into
an
arrangement
to
handle
emergencies.
EPA
and
the
owner
and
operator
of
a
facility
use
this
information
to
ensure
that
adequate
emergency
response
personnel
are
available,
if
needed,
and
to
document
that
all
necessary
arrangements
with
State
or
local
authorities
have
been
made.

CONTINGENCY
PLAN
AND
EMERGENCY
PROCEDURES
Section
3004(
a)(
5)
of
RCRA,
as
amended,
requires
EPA
to
develop
standards
for
contingency
plans
for
effective
action
to
minimize
unanticipated
damage
from
any
treatment,
storage,
or
disposal
of
any
such
hazardous
waste.
Sections
267.50
through
267.58
require
all
owners
and
operators
of
hazardous
waste
facilities
to
prepare
and
maintain
contingency
plans,
and
to
notify
State
and
local
authorities
and
prepare
and
emergency
reports
whenever
an
imminent
or
actual
emergency
situation
occurs.
EPA
reviews
the
contingency
plan
and
emergency
reports
to
determine
whether
a
facility
has
developed
adequate
procedures
to
respond
to
unplanned
sudden
or
non­
sudden
releases
of
hazardous
waste
or
hazardous
constituents
to
air,
soil,
or
surface
water.
Notifications
to
State
and
local
authorities
facilitate
remedial
actions
and
evacuations,
if
necessary.
Requiring
facilities
to
develop
and
maintain
contingency
plans
and
prepare
emergency
response
reports
and
notifications
contributes
to
EPA's
goal
of
minimizing
unanticipated
damage
from
the
treatment,
storage,
or
disposal
of
hazardous
waste.

RECORD
KEEPING,
REPORTING,
AND
NOTIFYING
Section
267.70
through
267.74
direct
owners
or
operators
of
facilities
that
treat
or
store
hazardous
waste
under
a
standardized
permit
to
keep
an
operating
record
at
the
facility.
The
operating
record
must
include,
among
other
things,
a
description
and
the
quantity
of
each
11
hazardous
waste
received,
and
the
method(
s)
and
date(
s)
of
its
treatment,
storage,
or
disposal
at
the
facility;
records
and
results
of
waste
analyses
performed;
summary
reports
and
details
of
all
incidents
that
require
implementing
the
contingency
plan;
and
records
and
results
of
inspection
reports.
EPA
uses
information
collected
pursuant
to
these
regulations
to
select
appropriate
corrective
action
and
cleanup
measures
should
an
unanticipated
release
of
hazardous
waste
occur.
EPA
compliance
officials
refer
to
the
operating
record
to
determine
the
following:
(
1)
what
cleanup
measures
are
appropriate
and
(
2)
whether
operating
requirements
can
be
better
tailored
to
the
needs
of
a
particular
site.
EPA
anticipates
that
the
owner
or
operator
will
use
information
included
in
the
operating
record
to
prevent
receiving,
or
placing
in
proximity,
wastes
that
are
incompatible
with
other
wastes
that
are
likely
to
ignite
or
explode.
Requiring
facilities
to
develop
and
maintain
an
operating
record
and
conduct
the
record
keeping
activities
contributes
to
EPA's
goal
of
minimizing
damage
to
the
environment
due
to
the
treatment,
storage,
or
disposal
of
hazardous
waste.

CLOSURE
40
CFR
part
267,
subpart
G
(
sections
267.110
through
267.117)
requires
owners
and
operators
to
develop
closure
plans,
amend
these
plans
when
appropriate,
and
submit
to
EPA
closure
certifications.
EPA
reviews
information
in
the
closure
plans
to
determine
whether
closure
activities
will
comply
with
the
regulatory
requirements.
EPA
uses
information
in
the
closure
certifications
to
determine
that
closure
took
place
in
accordance
with
the
approved
closure
plan.

Requiring
facilities
to
comply
with
these
regulations
contributes
to
EPA's
goal
of
ensuring
that
all
hazardous
waste
management
facilities
are
closed
in
a
manner
that
controls,
minimizes,
or
eliminates
post­
closure
escape
of
waste,
leachate,
contaminated
rainfall,
or
waste
decomposition
products
to
ground
or
surface
waters
and
the
atmosphere
to
the
extent
necessary
to
protect
human
health
and
the
environment.

FINANCIAL
REQUIREMENTS
Section
3004(
a)(
6)
of
the
Resource
Conservation
and
Recovery
Act
of
1976
(
RCRA),
as
amended,
requires
EPA
to
promulgate
regulations
that
include
requirements
respecting
"
the
maintenance
of
operations
of
such
facilities
and
requiring
such
additional
qualifications
as
to
...
financial
responsibility
(
including
financial
responsibility
for
corrective
action)
as
may
be
necessary
or
desirable."

The
need
for
financial
assurance
of
closure
care
is
indicated
by
the
numerous
instances
of
environmental
damage
resulting
from
abandonment
of
hazardous
waste
management
facilities
and
other
failures
by
owners
and
operators
to
provide
adequately
for
closure
care.
The
likelihood
of
such
failure
is
increased
by
the
fact
that
the
costs
for
closure
care
are
expected
to
commence
when
the
economic
value
of
the
facility
is
either
at
a
minimum
or
nonexistent.
12
EPA
believes
that
significant
numbers
of
owners
and
operators
would
lack
the
ability
to
provide
for
closure
care
without
effective
requirements
for
financial
assurance.
Consequently,
the
Agency
developed
40
CFR
part
267,
subpart
H
financial
responsibility
requirements
for
closure
care.

The
liability
requirements
are
designed
to
assure
that
funds
will
be
available
during
the
operating
life
of
a
facility
from
which
third
parties
can
seek
compensation
for
bodily
injury
and
property
damage
arising
from
the
operation
of
the
facility.
The
liability
requirements
are
necessary
for
several
reasons.
First,
the
requirements
provide
protection
to
human
health
and
the
environment
by
assuring
that
funds
are
available
to
owners
and
operators
to
compensate
for
damage
caused
by
accidents
at
hazardous
waste
facilities,
including
payments
for
bodily
injury
and
property
damage.
In
addition,
the
Agency
believes
that
without
liability
coverage
requirements,
there
would
be
less
public
confidence
in
and
greater
opposition
to
proposed
and
existing
hazardous
waste
facilities.
The
liability
requirements
also
result
in
other
potential
benefits
for
human
health
and
the
environment:
the
incentive,
in
the
form
of
lower
insurance
premiums,
to
improve
design
and
operation
of
the
facility,
and
the
oversight
that
insurers
provide
over
facility
operations.

USE
AND
MANAGEMENT
OF
CONTAINERS
Sections
267.172
and
267.15(
d)
require
owners
and
operators
that
store
or
treat
hazardous
waste
in
containers
to
inspect
areas
where
they
store
containers,
at
least
weekly,
and
record
the
inspection
results.
EPA
needs
this
information
to
evaluate
the
compliance
of
facilities
with
the
permitting
standards
and
ensure
that
containers
used
for
the
storage
and
treatment
of
hazardous
waste,
under
the
standardized
permit,
do
not
pose
a
threat
to
human
health
and
the
environment.
These
requirements
contribute
to
EPA's
goal
of
safe
management
of
hazardous
waste.

TANK
SYSTEMS
40
CFR
part
267,
subpart
J
specifies
record
keeping
and
reporting
requirements
associated
with
demonstrations
for
secondary
containment
waivers
(
section
267.190),
design
and
construction
standards
(
section
267.191),
installation
requirements
(
section
267.194),
inspection
requirements
(
section
267.199),
and
leaks
and
spills
(
section
267.200).
EPA
needs
this
information
to
evaluate
the
compliance
of
facilities
with
the
permitting
standards
and
ensure
that
tank
systems
used
for
the
storage
and
treatment
of
hazardous
waste,
under
the
standardized
permit,
do
not
pose
a
threat
to
human
health
and
the
environment.
These
requirements
contribute
to
EPA's
goal
of
safe
management
of
hazardous
waste.

CONTAINMENT
BUILDINGS
40
CFR
part
267,
subpart
DD
specifies
record
keeping
and
reporting
requirements
associated
with
inspections
(
section
267.1103);
demonstrations
for
secondary
containment
13
requirement
waivers
(
section
267.1104);
containment
buildings
containing
areas
both
with
and
without
secondary
containment
(
section
267.1105);
and
detection
of
releases
(
section
267.1106).
EPA
needs
this
information
to
evaluate
the
compliance
of
facilities
with
the
permitting
standards
and
ensure
that
containment
buildings
used
for
the
storage
and
treatment
of
hazardous
waste,
under
the
standardized
permit,
do
not
pose
a
threat
to
human
health
and
the
environment.
These
requirements
contribute
to
EPA's
goal
of
safe
management
of
hazardous
waste.

2(
b)
Practical
Utility
and
Users
of
the
Data
APPLYING
FOR
A
STANDARDIZED
PERMIT
EPA
uses
information
submitted
by
facilities
to
evaluate
exposure
potential
and
minimize
any
risks
to
human
health
from
hazardous
waste
management
facilities.
If
EPA
determines
that
a
facility
poses
a
substantial
risk
to
human
health,
EPA
may
request
that
the
Agency
for
Toxic
Substances
and
Disease
Registry
conduct
a
health
assessment.

EPA
uses
information
regarding
specific
units
at
facilities
to
evaluate
the
adequacy
of
each
unit
to
manage
hazardous
wastes.
Additional
information
is
required
because
each
of
the
different
types
of
hazardous
waste
management
units
present
different
risks
to
the
environment
and
consequently
requires
different
standards.
EPA
reviews
the
submittals
of
each
type
of
hazardous
waste
management
unit
to
evaluate
whether
it
is
designed,
constructed,
and
operated
in
a
manner
protective
of
human
health
and
the
environment.
EPA
uses
the
information
required
by
part
264,
subparts
BB
and
CC
to
ensure
compliance
with
air
emission
standards.

MAINTAINING
A
STANDARDIZED
PERMIT
EPA
uses
permit
information
to
evaluate
the
initial
permit
application
and
any
subsequent
request
for
modification.
The
public
may
also
use
draft
EPA
permit
and
permit
modification
determinations,
which
incorporate
data
submitted
by
facilities,
to
assess
hazardous
waste
management
facilities
being
developed
in
their
communities.

GENERAL
FACILITY
STANDARDS
EPA
uses
the
information
requirements
in
40
CFR
parts
267
and
270
for
owners
and
operators
submitting
standardized
permit
applications
to
evaluate
compliance
with
various
elements
of
the
regulations.
The
waste
analysis
and
waste
analysis
plan,
as
well
as
the
inspection
schedule
and
documentation
of
compliance
for
ignitable
or
incompatible
wastes,
are
primarily
internal
record
keeping
requirements
used
by
owners
and
operators
of
facilities
to
assure
that
they
can
adequately
handle
the
waste,
to
assure
that
the
incoming
waste
is
really
what
the
generator
claims
it
to
be,
and
to
prevent
undetected
releases
or
reactions
of
hazardous
waste
on­
site.
Much
of
the
information
in
the
waste
analysis
plan
will
also
be
used
to
provide
a
quality
assurance
check
on
both
the
generator
and
the
owners'
and
operators'
facilities.
Both
EPA
and
owners
and
operators
use
information
in
the
employee
training
records
to
ensure
that
employees
acquire
the
14
necessary
expertise
to
perform
their
jobs.
During
inspections,
EPA
reviews
job
descriptions
and
training
documents
to
determine
whether
each
person
is
receiving
a
level
of
training
that
is
commensurate
with
the
person's
duties
and
responsibilities
as
well
as
the
ability
to
respond
to
any
emergency
situations
at
the
facility.

PREPAREDNESS
AND
PREVENTION
The
facility
owner
or
operator
uses
the
documented
refusal
on
the
part
of
the
State
or
local
authorities
to
enter
in
emergency
response
arrangements
to
demonstrate
that
he
or
she
has
undertaken
all
the
necessary
activities
to
minimize
threats
to
human
health
and
the
environment
caused
by
the
release
of
waste
from
a
fire,
explosion,
or
any
unplanned
event.

CONTINGENCY
PLAN
AND
EMERGENCY
PROCEDURES
Local
emergency
response
teams,
facility
owners
or
operators,
and
EPA
use
information
included
in
the
contingency
plan
to
assure
an
appropriate
response
to
any
unplanned
release
of
hazardous
waste
or
hazardous
waste
constituents.
EPA
reviews
information
in
the
contingency
plan
and
emergency
report
to
determine
whether
additional
site­
specific
emergency
provisions
are
necessary.

RECORD
KEEPING,
REPORTING,
AND
NOTIFYING
The
facility
owner
or
operator
uses
information
included
in
the
operating
record
and
waste
disposal
location
and
quantity
records
to
prevent
the
facility
from
placing
in
proximity
wastes
that
are
incompatible
or
that
are
likely
to
ignite
or
explode.
If
an
unanticipated
release
of
hazardous
waste
occurs,
the
owner
or
operator
may
review
information
in
the
operating
record
to
determine
the
composition
of
the
waste.
Reviewing
information
in
the
operating
record
facilitates
the
owner's
or
operator's
selection
of
an
appropriate
corrective
action
and
cleanup
measure.
By
providing
facility­
specific
data,
the
operating
record
also
enables
EPA
compliance
officials
to
determine
whether
operating
requirements
can
be
better
tailored
to
the
needs
of
a
particular
site.

CLOSURE
EPA
uses
information
contained
in
closure
plans
to
determine
whether
an
owner
or
operator's
planned
closure
activities
will
comply
with
environmental
regulations.
EPA
officials
use
information
contained
in
closure
certifications
to
ensure
that
the
owner
or
operator
closed
his/
her
facility
according
to
the
specifications
outlined
in
the
approved
closure
plan.
EPA
uses
information
contained
in
demonstrations
to
ensure
that
any
activities
taking
place
during
the
closure
period
are
protective
of
human
health
and
the
environment.
Local
authorities,
EPA,
and
potential
purchasers
of
a
closed
facility
review
information
included
in
closure
notices
to
ensure
that
new
owners
or
operators
will
not
use
land
in
a
manner
that
will
lead
to
a
release
of
hazardous
waste
into
the
environment.
15
FINANCIAL
REQUIREMENTS
EPA
uses
the
financial
insurance
information
requirements
to
evaluate
the
facility
owner's
financial
ability
to
close
the
facility,
to
maintain
the
facility
after
closure,
and
to
respond
to
any
contingencies.
The
closure
and
liability
coverage
financial
instruments
submitted
by
the
owner
or
operator
are
reviewed
by
EPA
to
determine
compliance
with
the
applicable
subpart
H
regulations.
This
review
involves
determinations
of
the
validity
of
the
instrument,
acceptability
of
the
financial
assurance
provider,
adequacy
of
the
instrument
amount,
and
fulfillment
of
the
other
regulatory
requirements.
The
information
is
also
used
to
direct
funds
for
closure,
post­
closure
care,
and
liability
coverage
in
the
event
of
default
or
bankruptcy
of
a
facility
owner
or
operator.

USE
AND
MANAGEMENT
OF
CONTAINERS
EPA
uses
information
on
containers
obtained
during
facility
inspections
to
evaluate
the
adequacy
of
each
container
to
manage
hazardous
wastes,
and
ensure
that
containers
are
being
used
in
a
manner
protective
of
human
health
and
the
environment.

TANK
SYSTEMS
EPA
uses
information
on
tank
systems
obtained
during
facility
inspections
to
evaluate
the
adequacy
of
each
tank
to
manage
hazardous
wastes,
and
ensure
that
tank
systems
are
being
used
in
a
manner
protective
of
human
health
and
the
environment.

CONTAINMENT
BUILDINGS
EPA
uses
information
on
containment
buildings
obtained
during
facility
inspections
to
evaluate
the
adequacy
of
each
containment
building
to
manage
hazardous
wastes,
and
ensure
that
containment
buildings
are
being
used
in
a
manner
protective
of
human
health
and
the
environment.
16
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
In
proposing
the
standardized
permit,
EPA
is
attempting
to
streamline
the
permit
process
by
allowing
certain
types
of
facilities
to
obtain
and
modify
permits
more
easily
while
maintaining
the
protectiveness
currently
existing
in
the
individual
RCRA
permit
process.
Thus,
the
proposal
would
relieve
facility
owners
and
operators
of
certain
RCRA
record
keeping
and
reporting
requirements
that
currently
exist
under
the
RCRA
permitting
process.

3(
b)
Public
Notice
In
compliance
with
the
Paperwork
Reduction
Act
of
1995,
EPA
has
issued
a
public
notice
of
the
proposed
rule
in
the
Federal
Register.
To
assist
the
public
in
commenting
on
the
proposal,
EPA
has
raised
a
number
of
issues
in
the
preamble
about
the
proposed
rule
and
asks
for
the
public
to
comments
on
them.
At
the
end
of
the
comment
period,
EPA
will
review
and
respond
to
the
comments
received
and
take
the
comments
into
consideration
when
taking
further
action.

3(
c)
Consultations
EPA
convened
a
special
task
force
in
1994
to
look
at
permitting
activities
throughout
its
different
programs
and
to
make
specific
recommendations
to
improve
these
permitting
programs.
This
task
force,
known
as
the
Permits
Improvement
Team
(
PIT),
spent
two
years
working
with
stakeholders
from
the
Agency,
State
permitting
agencies,
industry,
and
the
environmental
community.
The
PIT
stakeholders
suggested,
among
other
things,
that
permitting
activities
should
be
commensurate
with
the
complexity
of
the
activity.
The
stakeholders
felt
that
current
Agency
permitting
programs
were
not
flexible
enough
to
allow
streamlined
procedures
for
routine
permitting
activities.
The
PIT
recommended,
among
other
things,
that
regulations
be
developed
to
allow
"
standardized
permits"
for
on­
site
storage
and
non­
thermal
treatment
of
hazardous
waste
in
tanks,
containers,
and
containment
buildings.

EPA
has
requested
public
comments
on
the
proposed
rule.
Public
comments
will
be
incorporated
in
the
final
draft
ICR.

3(
d)
Effects
of
Less
Frequent
Collection
The
proposed
standardized
permit
application
procedures
are
less
cumbersome
than
the
procedures
for
an
individual
permit.
Owners
and
operators
do
not
have
to
submit
the
amount
of
information
needed
to
support
an
individual
permit
application,
although
they
need
to
keep
the
information
at
their
facility.
In
addition,
the
proposed
procedures
for
modifying
standardized
permits
would
allow
owners
and
operators
to
make
certain
types
of
routine
changes
without
prior
approval,
provided
that
they
inform
both
the
regulatory
agency
and
the
public
of
the
changes.
17
EPA
believes
the
collection
frequencies
specified
in
the
proposal
are
necessary
to
ensure
protection
of
human
health
and
the
environment.

3(
e)
General
Guidelines
This
ICR
adheres
to
the
guidelines
stated
in
the
Paperwork
Reduction
Act
of
1995,
OMB's
implementing
regulations,
EPA's
Information
Collection
Review
Handbook,
and
other
applicable
OMB
guidance.

3(
f)
Confidentiality
Section
3007(
b)
of
RCRA
and
40
CFR
part
2,
subpart
B,
which
define
EPA's
general
policy
on
public
disclosure
of
information,
contain
provisions
for
confidentiality.
EPA
does
not
anticipate
requesting
any
confidential
information.

3(
g)
Sensitive
Questions
No
questions
of
a
sensitive
nature
are
included
in
the
proposed
information
collection
requirements.
18
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents
and
NAICS
Codes
The
following
is
a
list
of
North
American
Industrial
Classification
System
(
NAICS)
codes
associated
with
industries
most
likely
affected
by
the
information
collection
requirements
covered
under
this
ICR.

323110
Commercial
Lithographic
Printing
323114
Quick
Printing
325131
Inorganic
Dye
and
Pigment
Manufacturing
325188
All
Other
Basic
Inorganic
Chemical
Manufacturing
325998
All
Other
Miscellaneous
Chemical
Product
Manufacturing
331311
Alumina
refining
325211
Plastics
Material
and
Resins
Manufacturing
32551
Paint
and
Coating
Manufacturing
32511
Petrochemical
Manufacturing
32512
Industrial
Gas
Manufacturing
325188
All
Other
Inorganic
Chemical
Manufacturing
325193
Ethyl
Alcohol
Manufacturing
325199
All
Other
Basic
Organic
Chemical
Manufacturing
325998
All
Other
Miscellaneous
Chemical
Product
Manufacturing
311942
Spice
and
Extract
Manufacturing
32411
Petroleum
Refineries
332813
Electroplating,
Plating,
Polishing,
Anodizing
and
Coloring
33271
Machine
Shops
332991
All
Other
Miscellaneous
Fabricated
Metal
Product
Manufacturing
333319
Other
Commercial
or
Service
Industry
Machinery
Manufacturing
Accessories
333999
All
Other
General
Purpose
Machinery
Manufacturing
336399
All
Other
Motor
Vehicle
Part
Manufacturing
334
Computer
and
Electronic
Product
Manufacturing
336
Transportation
Equipment
Manufacturing
48422
Specialized
Freight
(
except
Used
Goods)
Trucking,
Local
56211
Waste
Collection
22111
Electric
Power
Generation
22112
Fossil
Fuel
Electric
Power
Generation
22132
Sewage
Treatment
Facilities
56292
Materials
Recovery
Facilities
56221
Waste
Treatment
and
Disposal
42271
Petroleum
Bulk
Stations
and
Terminals
45431
Fuel
Dealers
4411
Automobile
Dealers
19
4471
Gasoline
Stations
811111
General
Automotive
Repair
4(
b)
Information
Requested
This
section
describes
information
collection
requirements
applicable
to
facilities
that
will
be
affected
by
the
proposed
rule.

APPLYING
FOR
A
STANDARDIZED
PERMIT
(
1)
General
Information
Requirements
(
i)
Data
items:

Sections
124.202,
270.275,
270.280,
and
270.285
require
owners
and
operators
wishing
to
obtain
a
standardized
permit
to
provide
the
following
data
items:

°
A
written
notice
to
the
Director
that
the
owner
or
operator
intends
to
operate
under
a
standardized
permit;

°
The
Part
A
information
required
by
section
270.13
(
this
information
is
described
and
burdened
under
the
Part
A
Permit
Application
ICR);

°
A
meeting
summary
and
other
materials
required
by
section
124.31;

°
Documentation
of
compliance
with
the
location
standards
of
sections
267.18
and
270.14(
b)(
11),
including:

­­
An
identification
of
the
political
jurisdiction
in
which
the
facility
is
proposed
to
be
located;

­­
If
the
facility
is
proposed
to
be
located
in
an
area
listed
in
Appendix
VI
of
part
264,
a
demonstration
of
compliance
with
the
seismic
standard
as
defined
under
section
264.18(
a).
This
demonstration
may
be
made
using
either
published
geologic
data
or
data
obtained
from
field
investigations
carried
out
by
the
applicant;

­­
An
identification
of
whether
the
facility
is
located
within
a
100­
year
floodplain;
and
­­
If
applicable,
a
demonstration
made
under
section
267.18;
20
°
Information
that
allows
the
Director
to
carry
out
his
obligations
under
other
Federal
laws
required
in
section
270.3;

°
Solid
waste
management
unit
information
required
by
section
270.14(
d),
including:

­­
The
location
of
each
unit
on
the
topographic
map
required
under
section
270.14(
b)(
19);

­­
Designation
of
the
type
of
each
unit;

­­
General
dimensions
and
structural
description
of
each
unit;

­­
Dates
when
each
unit
was
operated;

­­
Specification
of
all
wastes
that
have
been
managed
at
each
unit,
to
the
extent
available;

­­
All
available
information
pertaining
to
any
release
of
hazardous
wastes
or
hazardous
constituents
from
each
unit
(
section
270.14(
d)(
2));

­­
Results
of
sampling
and
analysis,
where
the
Director
ascertains
that
a
RCRA
Facility
Assessment
is
necessary.

°
A
signed
certification
of
the
facility's
compliance
with
part
267,
as
specified
at
section
270.280;
and
°
For
facilities
that
are
not
in
compliance
with
part
267
at
the
time
the
notice
of
intent
is
submitted,
a
schedule
of
compliance.
This
schedule
must
include
an
enforceable
sequence
of
actions
with
milestones,
leading
to
compliance
with
the
requirements
for
which
the
facility
is
in
noncompliance
at
the
time
the
notice
of
intent
is
submitted
(
section
270.285).

(
ii)
Respondent
activities:

In
order
to
obtain
a
standardized
permit,
owners
and
operators
will
have
to
perform
the
following
activities:

°
Read
the
regulations;

°
Prepare
a
written
notice
of
intent
to
operate
under
a
standardized
permit;

°
Obtain
the
Part
A
information;
°
Obtain
the
meeting
summary
and
other
materials
required
by
section
124.31;
21
°
Develop
documentation
of
compliance
with
location
standards;

°
Prepare
information
that
allows
the
Director
to
carry
out
his
obligations
under
other
Federal
laws;

°
Prepare
the
solid
waste
management
unit
information;

°
Prepare
and
sign
the
certification
of
compliance
with
part
267;

°
If
necessary,
prepare
a
schedule
of
compliance
with
part
267;
and
°
Submit
the
above
information
to
the
Director.

(
2)
Record
Keeping
Requirements
(
i)
Data
items:

Section
270.290
requires
owners
and
operators
applying
for
a
standardized
permit
to
keep
the
following
information
at
their
facilities:

°
A
general
description
of
the
facility;

°
Chemical
and
physical
analyses
of
the
hazardous
waste
and
hazardous
debris
handled
at
the
facility.
At
a
minimum,
these
analyses
must
contain
all
the
information
required
to
treat
or
store
the
wastes
properly
under
the
requirements
of
part
267;

°
A
copy
of
the
waste
analysis
plan
required
by
section
267.13(
b);

°
A
description
of
the
security
procedures
and
equipment
required
by
section
267.14,
or
a
justification
demonstrating
the
reasons
for
a
waiver
from
these
requirements;

°
A
copy
of
the
general
inspection
schedule
required
by
section
267.15(
b),
as
well
as
the
applicable
inspection
schedule
requirements
of
sections
267.174,
267.193,
267.195,
267.1033,
267.1052,
267.1053,
267.1058,
and
267.1088;

°
A
justification
for
any
modification
of
the
preparedness
and
prevention
requirements
of
part
267,
subpart
C;

°
A
copy
of
the
contingency
plan
required
by
part
267,
subpart
D;
°
A
description
of
the
procedures,
structures,
or
equipment
used
at
the
facility
to:
22
­­
Prevent
hazards
in
unloading
operations;

­­
Prevent
runoff
from
hazardous
waste
handling
areas
to
other
areas
of
the
facility
or
environment,
or
to
prevent
flooding;

­­
Prevent
contamination
of
water
supplies;

­­
Mitigate
effects
of
equipment
failure
and
power
outages;

­­
Prevent
undue
exposure
of
personnel
to
hazardous
waste;
and
­­
Prevent
releases
to
the
atmosphere;

°
A
description
of
precautions
to
prevent
accidental
ignition
or
reaction
of
ignitable,
reactive,
or
incompatible
wastes
as
required
by
section
267.17;

°
A
description
of
traffic
patterns,
estimated
volumes,
and
controls
near
the
facility;

°
An
outline
of
both
the
introductory
and
continuing
programs
you
will
use
to
prepare
employees
to
operate
or
maintain
the
facility
safely,
as
required
by
section
267.16;

°
A
brief
description
of
how
training
will
be
designed
to
meet
actual
job
tasks
under
section
267.16(
a)(
3)
requirements;

°
A
copy
of
the
closure
plan
required
by
section
267.112.
Specific
requirements
in
sections
267.178,
267.197,
and
267.1102
should
be
included,
where
applicable,
as
part
of
the
plans;

°
The
most
recent
closure
cost
estimate
for
the
facility
prepared
under
section
267.142,
and
a
copy
of
the
documentation
required
to
demonstrate
financial
assurance
under
section
267.143.
For
new
facilities,
this
documentation
must
be
gathered
at
least
60
days
prior
to
the
initial
receipt
of
hazardous
wastes;

°
Where
applicable,
a
copy
of
the
insurance
policy
or
other
documentation
that
complies
with
the
liability
requirements
of
section
267.147.
For
a
new
facility,
documentation
showing
the
amount
of
insurance
meeting
the
specification
of
section
267.147(
a)
that
the
owner
or
operator
plans
to
have
in
effect
before
initial
receipt
of
hazardous
waste
for
treatment
or
storage;

°
Where
appropriate,
proof
of
coverage
by
a
State
financial
mechanism,
as
required
by
section
267.149
or
section
267.150;
and
23
°
A
topographic
map
that
meets
the
requirements
specified
at
section
270.290(
s).

(
ii)
Respondent
activities:

In
order
to
provide
the
data
items
listed
above,
owners
and
operators
will
have
to
perform
the
following
activities:

°
Read
the
regulations;

°
Prepare
and
maintain
a
general
description
of
the
facility;

°
Maintain
documentation
of
chemical
and
physical
analyses
of
the
hazardous
waste
and
hazardous
debris
handled
at
the
facility
(
this
activity
is
covered
in
the
"
Waste
Analysis"
section,
under
section
267.13(
a));

°
Maintain
a
copy
of
the
waste
analysis
plan
required
by
section
267.13(
b)
(
this
activity
is
covered
under
"
Waste
Analysis
Plan");

°
Prepare
and
maintain
a
description
of
the
security
procedures
and
equipment
required
by
section
267.14,
or
a
justification
demonstrating
the
reasons
for
a
waiver
from
these
requirements
(
this
activity
is
covered
under
"
Security");

°
Maintain
a
copy
of
the
applicable
inspection
schedules
(
this
activity
is
covered
under
"
Inspections");

°
Prepare
and
maintain
a
justification
for
any
modification
of
the
preparedness
and
prevention
requirements
of
part
267,
subpart
C;

°
Maintain
a
copy
of
the
contingency
plan
(
this
activity
is
covered
under
"
Contingency
Plan");

°
Prepare
and
maintain
a
description
of
the
procedures,
structures,
or
equipment
used
at
the
facility
to:

­­
Prevent
hazards
in
unloading
operations;

­­
Prevent
runoff
from
hazardous
waste
handling
areas
to
other
areas
of
the
facility
or
environment,
or
to
prevent
flooding;

­­
Prevent
contamination
of
water
supplies;

­­
Mitigate
effects
of
equipment
failure
and
power
outages;
24
­­
Prevent
undue
exposure
of
personnel
to
hazardous
waste;
and
­­
Prevent
releases
to
the
atmosphere;

°
Maintain
a
description
of
precautions
to
prevent
accidental
ignition
or
reaction
of
ignitable,
reactive,
or
incompatible
wastes
(
this
activity
is
covered
under
"
Ignitable,
Reactive,
or
Incompatible
Wastes");

°
Prepare
and
maintain
a
description
of
traffic
patterns,
estimated
volumes,
and
controls
near
the
facility;

°
Maintain
an
outline
of
both
the
introductory
and
continuing
programs
you
will
use
to
prepare
employees
to
operate
or
maintain
the
facility
safely,
as
required
by
section
267.16
(
this
activity
is
covered
under
"
Employee
Training");

°
Maintain
a
brief
description
of
how
training
will
be
designed
to
meet
actual
job
tasks
(
this
activity
is
covered
under
"
Employee
Training");

°
Maintain
a
copy
of
the
closure
plan
(
this
activity
is
covered
under
"
Closure
Plan");

°
Maintain
records
of
most
recent
closure
cost
estimate
and
a
copy
of
the
documentation
required
to
demonstrate
financial
assurance
(
this
activity
is
covered
under
"
FINANCIAL
REQUIREMENTS");

°
Where
applicable,
maintain
a
copy
of
the
insurance
policy
or
other
documentation
that
complies
with
the
liability
requirements
of
section
267.147
(
this
activity
is
covered
under
"
FINANCIAL
REQUIREMENTS");

°
Where
appropriate,
maintain
proof
of
coverage
by
a
State
financial
mechanism
(
this
activity
is
covered
under
"
FINANCIAL
REQUIREMENTS";
and
°
Obtain
and
maintain
a
topographic
map.

(
3)
Container
Information
Requirements
(
i)
Data
items:

In
addition
to
the
general
information
requirements
listed
at
section
270.290,
section
270.300
requires
owners
and
operators
of
facilities
with
containers
to
keep
the
following
information
at
their
facilities:

°
A
description
of
the
containment
system
to
demonstrate
compliance
with
section
267.173;
25
°
For
storage
areas
that
store
containers
holding
wastes
that
do
not
contain
free
liquids,
a
demonstration
of
compliance
with
section
267.173.
This
description
must
show
the
following:

­­
Basic
design
parameters,
dimensions,
and
materials
of
construction;

­­
How
the
design
promotes
drainage
or
how
containers
are
kept
from
contact
with
standing
liquids
in
the
containment
system;

­­
The
capacity
of
the
containment
system
relative
to
the
number
and
volume
of
containers
to
be
stored;

­­
Provisions
for
preventing
or
managing
run­
on;
and
­­
How
accumulated
liquids
can
be
analyzed
and
removed
to
prevent
overflow;

°
For
storage
areas
that
store
containers
holding
wastes
that
do
not
contain
free
liquids,
a
demonstration
of
compliance
with
section
267.173(
c),
including:

­­
Test
procedures
and
results
of
other
documentation
or
information
to
show
that
the
wastes
do
not
contain
free
liquids;
and
­­
A
description
of
how
the
storage
area
is
designed
or
operated
to
drain
and
remove
liquids
or
how
containers
are
kept
from
contact
with
standing
liquids;

°
Sketches,
drawings,
or
data
demonstrating
compliance
with
section
267.174
(
location
of
buffer
zone
and
containers
holding
ignitable
or
reactive
wastes)
and
section
267.175(
c)
(
location
of
incompatible
wastes),
where
applicable;

°
Where
incompatible
wastes
are
stored
or
otherwise
managed
in
containers,
a
description
of
the
procedures
used
to
ensure
compliance
with
sections
267.175(
a)
and
(
b);
and
°
Information
on
air
emission
control
equipment,
as
required
by
section
270.315.
26
(
ii)
Respondent
activities:

In
order
to
provide
the
data
items
listed
above,
owners
and
operators
will
need
to
perform
the
following
activities:

°
Read
the
regulations;

°
Prepare
and
maintain
a
description
of
the
containment
system;

°
For
storage
areas
that
store
containers
holding
wastes
that
do
not
contain
free
liquids,
prepare
and
maintain
a
demonstration
of
compliance
with
section
267.173(
c);

°
Where
applicable,
obtain
and
maintain
sketches,
drawings,
or
data
demonstrating
compliance
with
sections
267.174
and
267.175(
c);

°
Where
incompatible
wastes
are
stored
or
otherwise
managed
in
containers,
prepare
and
maintain
a
description
of
the
procedures
used
to
ensure
compliance
with
sections
267.175(
a)
and(
b);
and
°
Maintain
information
on
air
emission
control
equipment
(
this
activity
is
covered
under
"
Air
Emissions
Control
Information
Requirements").

(
4)
Tank
Information
Requirements
(
i)
Data
items:

In
addition
to
the
general
information
requirements
listed
at
section
270.290,
section
270.305
requires
owners
and
operators
of
facilities
with
tanks
to
keep
the
following
information
at
their
facilities:

°
A
written
assessment
that
is
reviewed
and
certified
by
an
independent,
qualified,
registered
professional
engineer
on
the
structural
integrity
and
suitability
for
handling
hazardous
waste
of
each
tank
system,
as
required
under
sections
267.191
and
267.192;

°
The
dimensions
and
capacity
of
each
tank;

°
A
description
of
feed
systems,
safety
cutoff,
bypass
systems,
and
pressure
controls;

°
A
diagram
of
piping,
instrumentation,
and
a
process
flow
for
each
tank
system;
27
°
A
description
of
materials
and
equipment
used
to
provide
external
corrosion
protection,
as
required
under
section
267.192;

°
For
new
tank
systems,
a
detailed
description
of
how
the
tank
system(
s)
will
be
installed
in
compliance
with
section
267.194;

°
Detailed
plans
and
a
description
of
how
the
secondary
containment
system
for
each
tank
system
is
or
will
be
designed,
constructed,
and
operated
to
meet
the
requirements
of
sections
267.195
and
267.196;

°
A
description
of
controls
and
practices
to
prevent
spills
and
overflows,
as
required
under
section
267.198;

°
For
tank
systems
in
which
ignitable,
reactive,
or
incompatible
wastes
are
to
be
stored
or
treated,
a
description
of
how
operating
procedures
and
tank
system
and
facility
design
will
achieve
compliance
with
the
requirements
of
sections
267.202
and
267.203;
and
°
Information
on
air
emission
control
equipment
as
required
by
section
270.315.

(
ii)
Respondent
activities:

In
order
to
provide
the
data
items
listed
above,
owners
and
operators
will
need
to
perform
the
following
activities:

°
Read
the
regulations;

°
Maintain
an
engineer's
written
assessment
on
the
structural
integrity
and
suitability
for
handling
hazardous
waste
of
each
tank
system
(
this
activity
is
covered
under
"
TANK
SYSTEMS");

°
Document
and
maintain
the
dimensions
and
capacity
of
each
tank;

°
Prepare
and
maintain
a
description
of
feed
systems,
safety
cutoff,
bypass
systems,
and
pressure
controls;

°
Prepare
and
maintain
a
diagram
of
piping,
instrumentation,
and
a
process
flow
for
each
tank
system;

°
Maintain
a
description
of
materials
and
equipment
used
to
provide
external
corrosion
protection
(
this
activity
is
covered
under
"
TANK
SYSTEMS");
28
°
For
new
tank
systems,
prepare
and
maintain
a
detailed
description
of
how
the
tank
system(
s)
will
be
installed
in
compliance
with
section
267.194;

°
Prepare
and
maintain
detailed
plans
and
a
description
of
how
the
secondary
containment
system
for
each
tank
system
is
or
will
be
designed,
constructed,
and
operated
to
meet
the
requirements
of
sections
267.195
and
267.196;

°
Prepare
and
maintain
a
description
of
controls
and
practices
to
prevent
spills
and
overflows;

°
For
tank
systems
in
which
ignitable,
reactive,
or
incompatible
wastes
are
to
be
stored
or
treated,
prepare
and
maintain
a
description
of
how
operating
procedures
and
tank
system
and
facility
design
will
achieve
compliance
with
the
requirements
of
sections
267.202
and
267.203;
and
°
Maintain
information
on
air
emission
control
equipment
(
this
activity
is
covered
under
"
Air
Emissions
Control
Information
Requirements").

(
5)
Equipment
Information
Requirements
(
i)
Data
items:

In
addition
to
the
general
information
requirements
listed
at
section
270.290,
section
270.310
requires
owners
and
operators
of
facilities
with
equipment
to
which
subpart
BB
of
part
264
applies
to
keep
the
following
information
at
their
facilities:

°
For
each
piece
of
equipment
to
which
subpart
BB
of
part
264
applies:

­­
Equipment
identification
number
and
hazardous
waste
management
unit
identification;

­­
Approximate
locations
within
the
facility;

­­
Type
of
equipment;

­­
Percent
by
weight
of
total
organics
in
the
hazardous
waste
stream
at
the
equipment;

­­
Hazardous
waste
state
at
the
equipment
(
e.
g.,
gas/
vapor
or
liquid);
and
­­
Method
of
compliance
with
the
standard;
29
°
For
facilities
that
cannot
install
a
closed­
vent
system
and
control
device
to
comply
with
40
CFR
part
264
subpart
BB
on
the
effective
date
that
the
facility
becomes
subject
to
the
subpart
BB
provisions,
an
implementation
schedule
as
specified
in
section
264.1033(
a)(
2);

°
For
owners
and
operators
who
apply
for
permission
to
use
a
control
device
other
than
a
thermal
vapor
incinerator,
catalytic
vapor
incinerator,
flare,
boiler,
process
heater,
condenser,
or
carbon
absorption
system
and
they
choose
to
use
test
data
to
determine
the
organic
removal
efficiency
or
the
total
organic
compound
concentration
achieved
by
the
control
device,
a
performance
test
plan
as
specified
in
section
264.1035(
b)(
3);

°
Documentation
that
demonstrates
compliance
with
the
equipment
standards
in
sections
264.1052
and
254.1059;
and
°
Documentation
to
demonstrate
compliance
with
section
264.1060.
This
documentation
must
include
the
following
information:

­­
A
list
of
all
information
references
and
sources
used
in
preparing
the
documentation;

­­
Records,
including
the
dates,
of
each
compliance
test
required
by
section
264.1033(
j);

­­
A
design
analysis,
specifications,
drawings,
schematics,
and
piping
and
instrumentation
diagrams.
The
design
analysis
must
address
the
vent
stream
characteristics
and
control
device
operation
parameters
as
specified
in
section
260.1035(
b)(
4)(
iii);

­­
A
statement,
signed
and
dated
by
the
owner
or
operator,
certifying
that
the
operating
parameters
used
in
the
design
analysis
reasonably
represent
the
conditions
that
exist
when
the
hazardous
waste
management
unit
is
operating
at
the
highest
load
or
capacity
level
reasonably
expected
to
occur;
and
­­
A
statement,
signed
and
dated
by
the
owner
or
operator,
certifying
that
the
control
device
is
designed
to
operate
at
an
efficiency
of
95
weight
percent
or
higher.
30
(
ii)
Respondent
activities:

In
order
to
provide
the
data
items
listed
above,
owners
and
operators
will
need
to
perform
the
following
activities:

°
Read
the
regulations;

°
For
each
piece
of
equipment
to
which
subpart
BB
of
section
264
applies:

­­
Maintain
the
equipment
identification
number
and
hazardous
waste
management
unit
identification;

­­
Prepare
and
maintain
approximate
locations
within
the
facility;

­­
Prepare
and
maintain
a
description
of
the
type
of
equipment;

­­
Prepare
and
maintain
a
description
of
the
percent
by
weight
of
total
organics
in
the
hazardous
waste
stream
at
the
equipment;

­­
Prepare
and
maintain
a
description
of
the
hazardous
waste
state
at
the
equipment
(
e.
g.,
gas/
vapor
or
liquid);
and
­­
Prepare
and
maintain
a
description
of
the
method
of
compliance
with
the
standard;

°
For
facilities
that
cannot
install
a
closed­
vent
system
and
control
device
to
comply
with
40
CFR
part
264
subpart
BB
on
the
effective
date
that
the
facility
becomes
subject
to
the
subpart
BB
provisions,
prepare
and
maintain
an
implementation
schedule;

°
For
owners
and
operators
who
apply
for
permission
to
use
a
control
device
other
than
a
thermal
vapor
incinerator,
catalytic
vapor
incinerator,
flare,
boiler,
process
heater,
condenser,
or
carbon
absorption
system
and
choose
to
use
test
data
to
determine
the
organic
removal
efficiency
or
the
total
organic
compound
concentration
achieved
by
the
control
device,
develop
and
maintain
a
performance
test
plan
as
specified;

°
Develop
and
maintain
documentation
that
demonstrates
compliance
with
the
equipment
standards
in
sections
264.1052
and
254.1059;
and
°
Develop
and
maintain
documentation
to
demonstrate
compliance
with
section
264.1060.
31
(
6)
Air
Emissions
Control
Requirements
(
i)
Data
items:

In
addition
to
the
general
information
requirements
listed
at
section
270.290,
section
270.315
requires
owners
and
operators
of
facilities
with
equipment
subject
to
subpart
CC
of
part
264
to
keep
the
following
information
at
their
facilities:

°
Documentation
for
each
floating
roof
cover
installed
on
a
tank
subject
to
sections
264.1084(
d)(
1)
or
(
d)(
2)
that
includes
information
prepared
by
the
owner
or
operator
or
provided
by
the
manufacturer
describing
the
cover
design;

°
A
certification
that
the
cover
meets
applicable
design
specifications
listed
in
sections
264.1084(
e)(
1)
or
(
f)(
1);

°
Identification
of
each
container
area
subject
to
the
requirements
of
part
264,
subpart
CC,
and
a
certification
that
the
requirements
of
this
subpart
are
met;

°
Documentation
for
each
enclosure
used
to
control
air
pollutant
emissions
from
tanks
or
containers
under
requirements
of
sections
264.1084(
d)(
5)
or
264.1086(
e)(
1)(
ii).
This
documentation
must
include
records
for
the
most
recent
set
of
calculations
and
measurements
performed
to
verify
that
the
enclosure
meets
the
criteria
of
a
permanent
enclosure
as
specified
in
section
52.741,
appendix
B;

°
Documentation
for
each
closed­
vent
system
and
control
device
installed
under
requirements
of
section
264.1087
that
includes
design
and
performance
information
as
specified
in
section
270.24(
c)
and
(
d);
and
°
An
emission
monitoring
plan
for
both
Method
21
in
40
CFR
part
60,
appendix
A,
and
control
device
monitoring
methods.
This
plan
must
include
monitoring
points,
monitoring
methods
for
control
devices,
monitoring
frequency,
procedures
for
documenting
exceedances,
and
procedures
for
mitigating
noncompliances.

(
ii)
Respondent
activities:

In
order
to
provide
the
data
items
listed
above,
owners
and
operators
will
need
to
perform
the
following
activities:

°
Read
the
regulations;

°
Prepare
and
maintain
documentation
for
each
floating
roof
cover
installed
on
a
tank
subject
to
sections
264.1084(
d)(
1)
or
(
d)(
2);
32
°
Prepare
and
maintain
a
certification
that
the
cover
meets
applicable
design
specifications
listed
in
sections
264.1084(
e)(
1)
or
(
f)(
1);

°
Prepare
and
maintain
an
identification
of
each
container
area
subject
to
the
requirements
of
part
264,
subpart
CC,
and
a
certification
that
the
requirements
of
this
subpart
are
met;

°
Prepare
and
maintain
documentation
for
each
enclosure
used
to
control
air
pollutant
emissions
from
tanks
or
containers
under
requirements
of
sections
264.1084(
d)(
5)
or
264.1086(
e)(
1)(
ii);

°
Prepare
and
maintain
documentation
for
each
closed­
vent
system
and
control
device
installed
under
requirements
of
section
264.1087;
and
°
Develop
and
maintain
an
emission
monitoring
plan
for
both
Method
21
in
40
CFR
part
60,
appendix
A,
and
control
device
monitoring
methods.

(
7)
Switching
from
an
Individual
RCRA
Permit
to
a
Standardized
Permit
(
i)
Data
items:

Section
124.203
allows
owners
and
operators
to
switch
their
individual
RCRA
permits
to
standardized
permits
by
submitting
a
request
to
the
Director
requesting
that
their
individual
permits
be
revoked
and
reissued
as
a
standardized
permit,
in
accordance
with
section
124.5.

(
ii)
Respondent
activities:

In
order
to
provide
the
data
item
listed
above,
owners
and
operators
seeking
to
switch
from
a
RCRA
individual
permit
to
a
standardized
permit
will
need
to
perform
the
following
activities:

°
Read
the
regulations;
and
°
Prepare
and
submit
the
request
to
the
Director.

(
8)
Reapplying
for
a
Standardized
Permit
(
i)
Data
items:

Section
270.10(
h)
requires
owners
and
operators
wishing
to
reapply
for
a
standardized
permit
to
submit
a
notice
of
intent
under
270.10(
b)(
1)
at
least
180
days
before
the
expiration
date
of
the
effective
permit.
33
(
ii)
Respondent
activities:

Owners
and
operators
reapplying
for
a
standardized
permit
will
need
to
perform
the
following
activities:

°
Read
the
regulations;

°
Prepare
and
submit
the
notice
of
intent.

MAINTAINING
A
STANDARDIZED
PERMIT
(
1)
Making
Routine
Changes
(
i)
Data
items:

Sections
124.212
and
270.320(
a)
require
owners
and
operators
seeking
to
make
routine
changes
(
class
1
or
class
2
permit
modifications
under
40
CFR
270.42
Appendix
I)
to
their
standardized
permits
to
provide
the
following
data
items:

°
The
revised
information
pursuant
to
section
270.267(
b)(
1);
and
°
A
notice
of
changes
to
the
facility
mailing
list
and
to
state
and
local
governments
in
accordance
with
the
procedures
in
sections
124.10(
c)(
1)(
ix)
and
(
x).

(
ii)
Respondent
activities:

In
order
to
provide
the
data
items
listed
above,
owners
and
operators
will
need
to
perform
the
following
activities:

°
Read
the
regulations;

°
Prepare
and
submit
the
revised
information
to
the
Director;
and
°
Submit
the
revised
information
to
the
facility
mailing
list
and
local
governments.

(
2)
Making
Significant
Changes
(
124.213,
270.320(
b))

(
i)
Data
items:

Sections
124.213
and
270.320(
b)
require
owners
and
operators
seeking
to
make
significant
changes
(
based
on
the
criteria
specified
in
section
270.320(
b)(
1)­(
3))
to
their
standardized
permits
to
provide
the
following
data
items:
34
°
A
public
meeting
(
with
prior
notice);

°
A
modification
request
to
the
Director
that:

­­
Describes
the
exact
change(
s)
desired,
and
whether
they
are
changes
to
information
provided
under
section
270.275
or
to
terms
and
conditions
in
the
supplemental
portion
of
the
standardized
permit;

­­
Explains
why
the
modification
is
needed;
and
­­
Includes
a
summary
of
the
public
meeting
described
above,
along
with
the
list
of
attendees
and
their
addresses
and
copies
of
any
written
comments
or
materials
submitted
at
the
meeting.

(
ii)
Respondent
activities:

In
order
to
provide
the
data
items
listed
above,
owners
and
operators
will
need
to
perform
the
following
activities:

°
Read
the
regulations;

°
Provide
notice
of
and
hold
a
public
meeting;
and
°
Prepare
and
submit
the
modification
request
to
the
Director
(
after
holding
the
public
meeting).

GENERAL
FACILITY
STANDARDS
(
1)
Obtaining
an
Identification
Number
(
i)
Data
items:

Section
267.12
requires
owners
and
operators
of
facilities
to
obtain
an
EPA
identification
number.

(
ii)
Respondent
activities:

In
order
to
obtain
an
EPA
identification
number,
owners
and
operators
will
need
to
perform
the
following
activities:

°
Read
the
regulations;
and
°
Obtain,
fill
out,
and
submit
an
application
for
an
EPA
identification
number.
35
(
2)
Waste
Analysis
(
i)
Data
items:

Section
267.13(
a)
requires
an
owner
or
operator
to
obtain
a
detailed
chemical
and
physical
analysis
of
any
hazardous
waste
he
or
she
intends
to
treat
or
store.
The
analysis
may
include
data,
either
existing
or
published,
developed
under
40
CFR
part
261,
as
well
as
existing
data
on
the
hazardous
waste
or
hazardous
waste
generated
from
similar
processes.

(
ii)
Respondent
activities:

In
order
to
comply
with
section
267.13,
respondents
must
perform
the
following
activities:

°
Read
the
regulations;

°
Collect
data;
and
°
Perform
waste
analysis
(
sampling,
testing).

(
3)
Waste
Analysis
Plan
(
i)
Data
items:

Section
267.13(
b)
states
that
an
owner
or
operator
of
a
hazardous
waste
facility
must
develop
and
follow
a
written
waste
analysis
plan
that
describes
the
procedures
to
be
used
in
obtaining
a
detailed
chemical
and
physical
analysis
of
the
waste.
The
owner
or
operator
is
required
to
keep
the
waste
analysis
plan
at
the
facility.
At
a
minimum,
the
plan
must
include
the
following
information:

°
Parameters
for
which
each
hazardous
waste
will
be
analyzed
and
the
rationale
for
the
selection
of
these
parameters;

°
Test
methods
used
to
test
for
the
parameters;

°
Sampling
method
used
to
obtain
a
representative
sample
of
the
waste
to
be
analyzed;

°
Frequency
with
which
the
initial
analysis
of
the
waste
will
be
reviewed
or
repeated
to
ensure
that
the
analysis
is
accurate
and
up
to
date;

°
Where
applicable,
the
methods
which
will
be
used
to
meet
additional
waste
analysis
requirements
for
specific
waste
management
methods
as
specified
in
sections
264.17,
264.1034(
d),
264.1063(
d),
and
264.1083
36
(
ii)
Respondent
activities:

To
meet
the
requirements
outlined
in
section
267.13(
b),
owners
or
operators
must
perform
the
following
activities:

°
Read
the
regulations;

°
Collect
the
data
required
in
the
waste
analysis
plan;

°
Write
the
waste
analysis
plan;
and
°
Maintain
the
plan
(
e.
g.,
photocopying
and
filing).

(
4)
Security
(
i)
Data
items:

Section
267.14(
b)
requires
owners
and
operators
seeking
a
waiver
from
the
267.14(
a)
security
requirements
to
keep
records
at
the
facility
justifying
the
reasons
for
the
waiver.

(
ii)
Respondent
activities:

Owners
and
operators
seeking
the
waiver
under
267.14(
b)
must
perform
the
following
activities:

°
Read
the
regulations;

°
Collect
the
required
documents;
and
°
Maintain
the
required
documents
at
the
facility.

(
5)
Inspections
(
i)
Data
items:

Section
267.15
requires
owners
and
operators
to
develop
and
follow
a
written
schedule
for
monitoring
equipment
that
is
important
in
preventing,
detecting,
or
responding
to
environmental
or
human
health
hazards.
This
schedule
must
be
kept
at
the
facility;
and
must
identify
the
equipment
and
devices
to
be
inspected,
as
well
as
the
problems
to
be
looked
for.
The
frequency
of
inspections
must
be
based
on
the
rate
of
deterioration
of
the
equipment
and
the
probability
of
an
environmental
or
human
health
incident
if
the
deterioration,
malfunction,
or
any
operator
error
goes
undetected
between
inspections.
At
a
minimum,
the
inspection
schedule
must
37
include
the
items
and
frequencies
required
in
sections
267.174,
267.193,
267.195,
264.1033,
264.1052,
264.1053,
264.1058,
and
264.1083
through
264.1089,
where
applicable.

Section
267.15(
d)
states
that
an
owner
or
operator
must
record
inspections
conducted
according
to
the
written
schedule
developed
pursuant
to
section
267.15(
b)
in
an
inspection
log
or
summary
that
is
to
be
maintained
at
the
facility.
The
inspection
log
or
summary
must
contain,
at
a
minimum,
the
date
and
time
of
the
inspection,
the
name
of
the
inspector,
a
notation
of
the
observations
made,
and
the
date
and
nature
of
any
repairs
or
other
remedial
actions.

(
ii)
Respondent
activities:

To
meet
the
requirements
outlined
in
sections
267.15(
b)
and
267.15(
d),
the
owner
or
operator
must
conduct
the
following
activities:

°
Read
the
regulations;

°
Prepare
the
inspection
schedule;
and
°
Record
the
results
of
inspections
in
the
inspection
log.

(
6)
Employee
Training
(
i)
Data
items:

Section
267.16(
d)
requires
an
owner
or
operator
to
maintain
copies
of
personnel
training
documents
and
records
at
the
facility.
These
documents
should
include
the
following
data
items:

°
Job
title
for
each
position
at
the
facility
related
to
hazardous
waste
management,
and
the
name
of
the
employee
filling
each
job;

°
Written
job
description
for
each
position,
which
includes
the
necessary
skill,
education,
or
other
qualifications
and
duties
of
employees
assigned
to
each
position;

°
Written
description
of
the
type
and
amount
of
both
introductory
and
continuing
training
that
will
be
given
to
each
person
filling
a
position;
and
°
Records
that
document
that
the
training
or
job
experience
required
have
been
given
to,
and
completed
by,
facility
personnel.

(
ii)
Respondent
activities:
38
Respondent
activities
associated
with
section
267.16
(
d)
include
reading
the
regulations,
collecting
the
data
items
listed
above,
and
maintaining
(
e.
g.,
photocopying
and
filing)
the
information
at
the
facility.

(
7)
Ignitable,
Reactive,
or
Incompatible
Wastes
(
i)
Data
items:

Section
267.17(
c)
states
that
the
owner
or
operator
of
a
hazardous
waste
facility
must
take
precautions
to
prevent
accidental
ignition
or
reaction
of
ignitable
or
reactive
waste.
The
owner
or
operator
of
a
permitted
facility
must
document
compliance
with
the
requirements
outlined
in
sections
267.17(
a)
and
(
b).
The
documentation
may
be
based
on
references
to
published
scientific
or
engineering
literature,
data
from
trial
tests
(
e.
g.,
bench
scale
or
pilot
scale
tests),
waste
analyses
(
as
specified
in
section
267.13),
or
the
results
of
the
treatment
of
similar
wastes
by
similar
treatment
processes
and
under
similar
operating
conditions.

(
ii)
Respondent
activities:

Respondent
activities
associated
with
section
267.17(
c)
include
reading
the
regulations,
collecting
and
documenting
the
data
items
mentioned
above,
and
maintaining
(
e.
g.,
photocopying
and
filing)
documentation
at
the
facility.

(
8)
Location
Factors
(
i)
Data
items:

Section
267.18(
a)(
3)(
B)
allows
owners
and
operators
of
facilities
located
in
a
100­
year
flood
plain
to
exempt
their
facilities
from
the
applicable
design
requirements
if
they
demonstrate
that
they
can
safely
remove
the
waste,
before
flood
waters
can
reach
the
facility,
to
a
location
where
the
wastes
will
not
be
vulnerable
to
flood
waters.

(
ii)
Respondent
activities:

The
respondent
activities
associated
with
section
267.18(
a)(
3)(
B)
include
reading
the
regulations,
preparing
the
demonstration,
and
submitting
it
to
the
Director.
These
activities
are
burdened
above
under
"
General
Information
Requirements."
39
PREPAREDNESS
AND
PREVENTION
(
1)
Arrangements
with
Local
Authorities
(
i)
Data
items:

Section
267.36(
b)
requires
owners
and
operators
to
document
any
refusal
on
the
part
of
local
authorities
to
enter
into
an
arrangement
to
handle
emergencies.

(
ii)
Respondent
activities:

Respondent
activities
associated
with
section
267.36(
b)
include
reading
the
regulations,
documenting
any
refusals,
and
placing
this
documentation
into
the
facility
operating
record.

CONTINGENCY
PLAN
AND
EMERGENCY
PROCEDURES
(
1)
Contingency
Plan
(
i)
Data
items:

Section
267.51
requires
owners
or
operators
to
have
a
contingency
plan
for
their
facilities
and
section
267.53
requires
the
owner
or
operator
to
maintain
a
copy
of
an
updated
contingency
plan
at
the
facility.
Section
267.52
outlines
the
data
elements
that
should
be
included
in
this
plan:

°
A
description
of
the
actions
facility
personnel
will
take
to
comply
with
sections
267.51
and
267.56
in
response
to
fires,
explosions,
or
any
unplanned
releases
of
hazardous
waste
from
the
facility;

°
A
description
of
the
arrangements
agreed
to
by
local
police
departments,
fire
departments,
hospitals,
contractors,
and
State
and
local
emergency
response
teams
to
coordinate
emergency
services;

°
An
updated
list
of
the
names,
addresses,
and
phone
numbers
(
office
and
home)
of
all
persons
qualified
to
act
as
emergency
coordinators;

°
An
updated
list
of
all
emergency
equipment
at
the
facility
and
the
location,
physical
description,
and
capabilities
of
the
emergency
equipment.
The
contingency
plan
should
also
indicate
where
the
emergency
equipment
will
be
required;
and
°
An
evacuation
plan
for
facility
personnel
where
there
is
a
possibility
that
evacuation
may
be
necessary.
40
Section
267.53(
b)
requires
owner
and
operators
to
submit
a
copy
of
the
contingency
plan
and
all
revisions
to
all
local
police
departments,
fire
departments,
hospitals,
and
State
and
local
emergency
response
teams
that
may
be
called
upon
to
provide
emergency
services.

Section
267.54
requires
owners
and
operators
to
review
and,
if
necessary,
immediately
amend
the
contingency
plan
whenever:

°
The
facility
permit
is
revised;

°
The
plan
fails
in
an
emergency;

°
The
facility
is
changed
in
a
way
that
increases
the
potential
for
an
emergency
or
changes
the
response
necessary
in
an
emergency;

°
The
list
of
emergency
coordinators
is
changed;
or
°
The
list
of
emergency
equipment
is
changed.

(
ii)
Respondent
activities:

In
order
to
comply
with
contingency
plan
requirements,
owners
or
operators
are
required
to
perform
the
following
activities:

°
Read
the
regulations;

°
Collect
the
data
required
in
the
contingency
plan;

°
Write
the
contingency
plan;

°
Submit
the
contingency
plan
to
State
and
local
authorities;

°
Maintain
(
e.
g.,
photocopy
and
file)
the
contingency
plan;
and
°
Amend
the
contingency
plan
when
appropriate.

(
2)
Emergency
Reporting
(
i)
Data
items:

Section
267.56(
c)(
1)
requires
owners
and
operators
to
immediately
notify
State
and
local
authorities
with
designated
response
roles
of
an
imminent
or
actual
emergency
situation.
41
Section
267.56(
c)(
2)
the
facility
emergency
coordinator
to
notify
the
on­
scene
coordinator
or
the
National
Response
Center
of
any
release,
fire,
or
explosion
that
could
threaten
human
health
or
the
environment
outside
the
facility.
The
emergency
notification
report
must
include
the
following
information:

°
Name
and
telephone
number
of
reporter;

°
Name
and
address
of
facility;

°
Time
and
type
of
incident;

°
Name
and
quantity
of
material(
s)
involved;

°
The
extent
of
injuries;
and
°
Possible
hazards
to
human
health
or
the
environment
outside
the
facility.

Section
267.58(
a)
states
that
the
owner
or
operator
should
notify
the
Regional
Administrator
and
appropriate
State
and
local
authorities
that
their
facility
is
in
compliance
with
section
267.57(
b)
before
resuming
operations
in
the
affected
area(
s)
of
the
facility.

Within
15
days
of
the
incident,
owners
and
operators
are
required,
under
section
267.58(
b)
to
submit
a
written
report
on
the
incident
to
the
Regional
Administrator.
The
report
must
include
the
following
data
items:

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

°
Name,
address,
and
telephone
number
of
the
facility;

°
Date,
time,
and
type
of
incident;

°
Name
and
quantity
of
material(
s)
involved;

°
The
extent
of
any
injuries;

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

Section
267.58(
b)
also
requires
owners
and
operators
to
note
the
time,
date,
and
details
of
any
incident
that
requires
implementing
the
contingency
plan
in
the
operating
record.
42
(
ii)
Respondent
activities:

In
order
to
comply
with
the
reporting
requirements
of
section
267.58(
c)(
1),
owners
and
operators
must
submit
the
required
notification
of
an
imminent
or
actual
emergency
situation
to
State
and/
or
local
authorities.

In
order
to
comply
with
the
reporting
requirements
of
section
267.56(
c)(
2),
owners
and
operators
must
perform
the
following
activities:

°
Notify
the
on­
scene
coordinator
or
the
National
Response
Center
of
any
release.

°
Collect
the
information
required
in
the
emergency
report;
and
°
Write
the
emergency
notification
report.

In
order
to
prepare
an
owner/
operator's
emergency
report
under
section
267.58(
a),
owners
and
operators
must
conduct
the
following
activities:

°
Read
the
regulations;

°
Collect
the
information
required
in
the
emergency
report;
and
°
Write
the
emergency
report.

In
addition
to
preparing
an
emergency
report,
the
owner
or
operator
must
notify
the
Regional
Administrator
that
the
facility
is
in
compliance
with
section
267.57(
b)
before
resuming
operations
in
affected
areas
of
the
facility.
Respondent
activities
associated
with
this
requirement
include
the
following:

°
Compiling
information
that
demonstrates
that
all
affected
areas
are
in
compliance;
and
°
Preparing
a
letter
notifying
the
Regional
Administrator
of
this
compliance.

To
comply
with
the
requirements
of
section
267.58,
owners
and
operators
must
record
the
details
of
any
incident
that
requires
implementing
the
contingency
plan
in
the
operating
record.
43
RECORD
KEEPING,
REPORTING,
AND
NOTIFYING
(
1)
Record
Keeping
(
i)
Data
items:

Section
267.71
requires
owners
and
operators
to
record
and
maintain
the
following
information,
as
it
becomes
available,
in
the
facility
operating
record
until
the
facility
is
closed:

°
A
description
and
the
quantity
of
each
hazardous
waste
received,
and
the
method(
s)
and
date(
s)
of
its
treatment,
storage,
or
disposal
at
the
facility
as
required
by
Appendix
I
of
part
264;

°
The
location
of
each
hazardous
waste
within
the
facility
and
the
quantity
at
each
location;

°
Records
and
results
of
waste
analyses
performed;

°
Summary
reports
and
details
of
all
incidents
that
require
implementing
the
contingency
plan;

°
Records
and
results
of
inspection
reports
(
which
must
be
kept
for
three
years);

°
Monitoring,
testing,
or
analytical
data
and
corrective
action
where
required;

°
All
closure
cost
estimates;

°
A
certification
by
the
permittee,
no
less
often
than
annually,
that
the
permittee
has
a
program
in
place
to
reduce
the
volume
and
toxicity
of
hazardous
waste
that
he
generates
to
the
degree
determined
by
the
permittee
to
be
economically
practicable;
and
the
proposed
method
of
treatment,
storage,
or
disposal
that
is
the
practicable
method
currently
available
to
the
permittee
which
minimizes
the
present
and
future
threat
to
human
health
and
the
environment;

°
For
an
on­
site
treatment
facility,
the
information
contained
in
the
notice
(
except
the
manifest
number),
and
the
certification
and
demonstration
required
under
section
268.7
or
section
268.8;

°
For
an
on­
site
storage
facility,
the
information
in
the
notice
(
except
the
manifest
number),
and
the
certification
and
demonstration
if
applicable,
required
under
section
268.7
or
section
268.8.
44
(
ii)
Respondent
activities:

In
order
to
comply
with
section
267.71,
owners
or
operators
are
required
to
maintain
a
written
operating
record
at
the
facility.
Respondent
activities
associated
with
maintaining
an
operating
record
include
maintaining
(
e.
g.,
photocopying
and
filing)
the
data
items
listed
above.

(
2)
Reports
(
i)
Data
items:

Section
267.73(
a)
requires
owners
and
operators
to
submit
a
single
copy
of
a
biennial
report
to
the
Regional
Administrator
by
March
1
of
each
calendar
year.
This
requirement
is
covered
in
the
Supporting
Statement
For
EPA
Information
Collection
Request
976.09,
"
The
1999
Hazardous
Waste
Report."

Section
267.73(
b)
requires
owners
and
operators
to
report
to
the
Regional
Administrator:

°
Releases,
fires,
and
explosions
as
specified
in
section
267.58(
b);

°
Facility
closures
specified
in
section
267.117;
and
°
As
otherwise
required
by
subparts
I,
J,
and
DD
of
part
267
and
subparts
BB
and
CC
of
part
264.

(
ii)
Respondent
activities:

As
discussed
above,
the
requirements
at
section
267.73(
a)
are
covered
under
another
ICR,
and
therefore
are
not
burdened
here.
Additionally,
the
reports
described
in
section
267.73(
b)
are
burdened
under
the
applicable
sections
for
each
individual
report.

(
3)
Notifications
(
i)
Data
items:

Section
267.74
requires
that,
before
transferring
ownership
or
operation
of
a
facility
during
its
operating
life,
an
owner
or
operator
must
notify
the
new
owner
or
operator
in
writing
of
the
requirements
of
parts
267
and
270.

(
ii)
Respondent
activities:

In
order
to
meet
the
requirement
described
above,
owners
and
operators
must
prepare
a
written
notification
informing
the
new
owner
or
operator
of
the
requirements
of
parts
267
and
270.
45
CLOSURE
(
1)
Closure
Plan
(
i)
Data
items:

Owners
and
operators
are
required
by
section
267.112
to
submit
a
written
closure
plan
at
least
180
days
prior
to
closure.
The
plan
must
identify
steps
necessary
to
perform
partial
and/
or
final
closure
of
the
facility,
and
must
include
at
least
the
following
items:

°
A
description
of
how
each
hazardous
waste
management
unit
at
the
facility
will
be
closed
in
accordance
with
section
267.111;

°
A
description
of
how
final
closure
of
the
facility
will
be
conducted
in
accordance
with
section
267.111
The
description
must
identify
the
maximum
extent
of
operations
which
will
be
unclosed
during
the
active
life
of
the
facility;

°
An
estimate
of
the
maximum
inventory
of
hazardous
wastes
ever
on­
site
over
the
active
life
of
the
facility.
This
should
include
a
detailed
description
of
the
methods
to
be
used
during
partial
closures
and
final
closure
such
as
methods
for
removing,
transporting,
treating,
storing,
or
disposing
of
all
hazardous
wastes,
and
identification
of
the
type(
s)
of
off­
site
hazardous
waste
management
units
to
be
used,
if
applicable;

°
A
detailed
description
of
the
steps
needed
to
remove
or
decontaminate
all
hazardous
waste
residues
and
contaminated
containment
system
components,
equipment,
structures,
and
soils
during
partial
and
final
closure;

°
A
detailed
description
of
other
activities
necessary
during
the
closure
period
to
ensure
that
all
partial
closures
and
final
closure
satisfy
the
closure
performance
standards;
and
°
A
schedule
for
closure
of
each
hazardous
waste
management
unit
and
for
final
closure
of
the
facility.
The
schedule
must
include,
at
a
minimum:

­­
The
total
time
required
to
close
each
hazardous
waste
management
unit;
and
­­
The
time
required
for
intervening
closure
activities
which
will
allow
tracking
of
the
progress
of
partial
and
final
closure.
46
(
ii)
Respondent
activities:

The
respondent
activities
associated
with
the
closure
plan
described
above
include:

°
Reading
the
regulations;

°
Conducting
an
inventory
of
the
hazardous
waste
present;

°
Recording
results
of
inventory;
Writing
descriptions
for
the
necessary
activities;

°
Estimating
final
closure;
and
°
Writing
the
closure
schedule.

(
2)
Notification
Before
Partial
Closure
and
Final
Closure
(
i)
Data
items:

Section
267.112(
c)
requires
owners
and
operators
to
notify
the
Director
in
writing
at
least
45
days
before
beginning
final
closure
of
a
treatment
or
storage
tank,
container
storage,
or
containment
building.

(
ii)
Respondent
activities:

To
meet
the
above
requirement,
respondents
must
read
the
regulations,
and
prepare
a
written
notification.

(
3)
Certification
of
Closure
(
i)
Data
items:

Section
267.117
requires
owners
and
operators
to
submit
to
the
Director
a
certification
of
closure
within
60
days
of
the
completion
of
final
closure
of
each
unit
under
a
part
270
subpart
I
standardized
permit.
This
certification
must
sent
by
registered
mail;
must
certify
that
each
hazardous
waste
management
unit
or
facility
has
been
closed
following
the
specifications
in
the
closure
plan;
and
must
be
signed
by
the
owner
or
operator
and
an
independent
registered
engineer.

(
ii)
Respondent
activities:

The
respondent
activities
associated
with
the
certification
of
closure
include:

°
Reading
the
regulations;
47
°
Preparing
the
certification;
and
°
Submitting
the
certification.

FINANCIAL
REQUIREMENTS
(
1)
Cost
Estimate
for
Closure
(
i)
Data
items:

Section
267.142(
a)
requires
owners
and
operators
to
develop
a
detailed
written
estimate,
in
current
dollars,
of
the
cost
of
closing
the
facility
in
accordance
with
the
requirements
in
sections
267.111
through
267.115
and
applicable
closure
requirements
in
sections
267.178,
267.197,
267.1102.
Section
267.142(
b)
specifies
that
this
estimate
must
be
updated
annually
for
inflation.
Section
267.142(
c)
specifies
that
owners
and
operators
must
keep
the
latest
closure
cost
estimate
(
adjusted
to
the
current
year)
at
the
facility.

(
ii)
Respondent
activities:

The
requirements
described
above
will
entail
the
following
activities:

°
Reading
the
regulations;

°
Preparing
a
detailed
estimate
of
closure
costs;

°
Updating
the
estimate
for
inflation
annually;
and
°
Maintaining
the
estimate
at
the
facility.

(
2)
Closure
Trust
Fund
(
i)
Data
items:

Section
267.143(
a)
explains
that
owners
and
operators
may
use
a
closure
trust
fund
to
meet
the
financial
assurance
requirements
of
section
267.143.
Data
items
for
this
mechanism
include:

°
A
trust
agreement
in
compliance
with
sections
264.143(
a)(
1)
and
(
2),
and
264.143(
a)(
6)­(
11).
The
wording
of
this
agreement
must
follow
the
wording
specified
in
section
264.151(
a)(
1);
48
°
For
new
facilities,
a
receipt
from
the
trustee
must
be
submitted
to
the
Regional
Administrator
prior
to
the
initial
storage
of
waste;

(
ii)
Respondent
activities:

Owners
and
operators
establishing
a
trust
fund
to
meet
the
financial
assurance
requirements
for
closure
will
perform
the
following
activities:

°
Reading
the
regulations;

°
Establishing
a
closure
trust
fund;

°
Submitting
an
originally
signed
duplicate
of
the
trust
agreement
to
the
EPA
Regional
Administrator;

°
For
owners
and
operators
of
new
facilities,
submitting
a
receipt
for
the
first
payment
under
the
trust
agreement
before
the
initial
receipt
of
hazardous
wastes.

(
3)
Surety
Bond
Guaranteeing
Payment
into
a
Closure
Trust
Fund
(
i)
Data
items:

Section
267.143(
b)
allows
owners
and
operators
to
meet
the
financial
assurance
requirements
for
closure
by
obtaining
a
surety
bond
guaranteeing
payment
into
a
closure
trust
fund.
The
data
items
associated
with
this
mechanism
are:

°
A
surety
bond
instrument,
as
specified
at
section
264.151(
b);
and
°
A
standby
trust
agreement,
as
specified
at
section
264.143(
b)(
3).

In
collecting
these
data
items,
owners
and
operators
will
need
to
engage
in
the
following
respondent
activities:

°
Reading
the
regulations;

°
Establishing
a
surety
bond
and
trust
agreement
that
comply
with
the
financial
assurance
requirements
of
section
267.143(
b);
and
°
Submitting
originally
signed
duplicates
of
the
surety
bond
and
trust
agreement
to
the
Regional
Administrator.
49
(
4)
Surety
Bond
Guaranteeing
Performance
of
Closure
(
i)
Data
items:

Section
267.143(
c)
allows
owners
and
operators
to
meet
the
financial
assurance
requirements
for
closure
by
obtaining
a
surety
bond
guaranteeing
the
performance
of
closure.
The
data
items
for
this
instrument
include:

°
A
surety
bond
instrument
specified
at
section
264.151(
c);
and
°
A
standby
trust
agreement,
as
specified
at
section
264.143(
c)(
3).

(
ii)
Respondent
activities:

The
respondent
activities
associated
with
this
financial
assurance
instrument
include:

°
Reading
the
regulations;

°
Obtaining
a
surety
bond
and
trust
agreement
that
comply
with
the
financial
assurance
requirements
of
section
267.143(
c);
and
°
Submitting
originally
signed
duplicates
of
the
surety
bond
and
trust
agreement
to
the
Regional
Administrator.

(
5)
Closure
Letter
of
Credit
(
i)
Data
items:

Section
267.143(
d)
specifies
that
owners
or
operators
may
obtain
an
irrevocable
standby
letter
of
credit
in
order
to
satisfy
financial
assurance
requirements
for
closure.
Data
items
for
this
information
collection
include:

°
A
letter
of
credit
from
an
issuing
institution
authorized
to
issue
letters
of
credit
and
whose
letter­
of­
credit
operations
are
regulated
and
examined
by
a
Federal
or
State
agency;
and
°
A
trust
agreement
indicating
the
conditions
of
payment
into
the
standby
trust
fund
specified
in
section
264.143(
d)(
3).

(
ii)
Respondent
activities:

Owners
or
operators
will
need
to
engage
in
the
following
activities
in
order
to
satisfy
the
financial
assurance
requirements
with
a
closure
letter
of
credit:
50
°
Reading
the
regulations;

°
Obtaining
a
letter
of
credit
from
an
issuing
institution
and
establishing
the
stand­
by
trust
fund;
and
°
The
letter
of
credit
and
an
originally
signed
duplicate
of
the
trust
agreement
to
the
Regional
Administrator.

(
6)
Closure
Insurance
(
i)
Data
items:

Owners
or
operators
may
satisfy
the
financial
assurance
requirements
for
closure
by
establishing
closure
insurance
according
to
section
267.143(
e).
The
data
item
for
this
information
collection
is
a
closure
insurance
policy
(
identified
by
a
certificate
of
insurance)
that
meets
the
requirements
specified
in
section
264.143(
e).

(
ii)
Respondent
activities:

The
following
activities
are
necessary
to
meet
the
above
requirement:

°
Reading
the
regulations;

°
Obtaining
a
closure
or
post­
closure
insurance
policy
that
satisfies
the
requirements
of
section
264.143(
e);
and
°
Submitting
a
certificate
of
this
insurance
policy
to
the
Regional
Administrator.

(
7)
Corporate
Financial
Test
and
Corporate
Guarantee
(
i)
Data
items:

Section
267.143(
f)
allows
owners
and
operators
to
satisfy
closure
financial
assurance
requirements
by
demonstrating
financial
strength
using
the
financial
test
specified
in
this
section.
Data
items
for
this
demonstration
include:

°
A
letter
signed
by
the
owner's
or
operator's
chief
financial
officer
as
specified
in
section
267.143(
f)(
2)(
i)(
A);

°
A
copy
of
an
independent
certified
public
accountant's
report
on
examination
of
the
owner's
or
operator's
financial
statements
for
the
latest
completed
fiscal
year;
51
°
A
special
report
from
the
owner's
or
operator's
independent
certified
public
accountant
to
the
owner
or
operator
covering
the
specifications
outlined
in
sections
267.143(
f)(
2)(
i)(
c)
and
(
d);

°
Annual
updates
of
the
above
data
items;

°
A
notice
of
intent
to
establish
alternative
financial
assurance,
if
the
owner
or
operator
fails
the
financial
test
and
no
longer
meets
the
requirements
of
section
267.143(
f)(
1);

°
Reports
of
financial
conditions
as
required
by
the
Regional
Administrator
under
section
267.143(
f)(
2)(
v)(
A);
and
°
If
applicable,
a
written
guarantee
from
the
parent
corporation
of
the
owner
or
operator
that
satisfies
the
requirements
at
section
267.143(
g)(
1).

(
ii)
Respondent
activities:

Owners
and
operators
will
need
to
perform
the
following
activities
to
provide
the
data
items
listed
above:

°
Reading
the
regulations;

°
Writing
the
letter
signed
by
the
chief
financial
officer;

°
Submitting
the
following
documents
to
the
Regional
Administrator
(
for
new
facilities,
these
documents
must
be
submitted
at
least
sixty
days
prior
to
placing
waste
in
the
facility):

­­
The
letter
signed
by
the
chief
financial
officer;

­­
A
copy
of
the
independent
certified
public
accountant's
report;
and
­­
The
special
report
from
the
independent
certified
public
accountant;

°
Submitting
updated
information
annually;

°
If
applicable,
writing
and
submitting
a
notice,
by
certified
mail,
to
the
Regional
Administrator
of
intent
to
establish
other
financial
assurance;
and
°
Writing
and
submitting
additional
reports
of
financial
condition
at
any
time,
as
directed
by
the
Regional
Administrator;
and
52
°
If
applicable,
submitting
the
corporate
guarantee
from
the
parent
corporation
of
the
owner
or
operator.

(
8)
Use
of
a
Financial
Assurance
Instrument
for
Multiple
Facilities
(
i)
Data
items:

Section
267.143(
i)
allows
owners
and
operators
to
use
a
single
financial
mechanism
for
multiple
facilities,
as
specified
in
section
264.143(
h).
In
such
cases,
the
owner
and
operator
must
provide
the
following
data
items
for
each
facility:

°
EPA
identification
number,
name,
and
address;
and
°
The
amount
of
funds
for
closure
or
post­
closure
care
assured
by
the
mechanism.

(
ii)
Respondent
activities:

In
order
to
provide
the
data
items
listed
above,
owners
and
operators
will
need
to
perform
the
following
activities:

°
Reading
the
regulations;

°
Submitting
the
data
items
listed
above
to
the
Regional
Administrator;
and
°
If
the
facilities
covered
by
the
mechanism
are
located
in
more
than
one
Region,
submitting
identical
evidence
of
financial
assurance
to
all
the
applicable
Regional
Administrators.

(
9)
Trust
Fund
for
Liability
Coverage
(
i)
Data
items:

Section
267.147(
a)(
3)
allows
owners
or
operators
to
satisfy
financial
requirements
for
liability
by
establishing
a
trust
agreement
that
conforms
to
the
requirements
specified
in
section
264.147(
j).

(
ii)
Respondent
activities:

Owners
or
operators
using
this
option
to
satisfy
financial
assurance
for
liability
will
need
to
engage
in
the
following
activities:

°
Reading
the
regulations;
53
°
Establishing
the
trust
fund
described
above;
and
°
Submitting
an
originally
signed
duplicate
of
the
trust
agreement
to
the
Regional
Administrator.

(
10)
Surety
Bond
for
Liability
Coverage
(
i)
Data
items:

Section
267.147(
a)(
2)
allows
owners
or
operators
to
satisfy
financial
requirements
for
liability.
The
owner/
operator
must
obtain
a
surety
bond
(
and
other
information,
where
applicable)
that
conforms
to
the
requirements
specified
in
section
264.147(
i).

(
ii)
Respondent
activities:

Owners
or
operators
using
this
option
to
satisfy
financial
assurance
for
liability
will
need
to
engage
in
the
following
activities:

°
Reading
the
regulations;

°
Obtaining
the
surety
bond
described
above;
and
°
Submitting
a
copy
of
this
surety
bond
to
the
Regional
Administrator.

(
11)
Letter
of
Credit
for
Liability
Coverage
(
i)
Data
items:

Section
267.147(
a)(
3)
allows
owners
or
operators
to
satisfy
financial
requirements
for
liability
by
obtaining
an
irrevocable
standby
letter
of
credit
that
conforms
to
the
requirements
of
section
264.147(
h).

(
ii)
Respondent
activities:

Owners
or
operators
using
this
option
to
satisfy
financial
assurance
for
liability
will
need
to
engage
in
the
following
activities:

°
Reading
the
regulations;

°
Obtaining
the
standby
letter
of
credit
described
above;
and
°
Submitting
a
copy
of
this
letter
of
credit
to
the
Regional
Administrator.
54
(
12)
Liability
Insurance
(
i)
Data
items:

Section
267.147
allows
owners
or
operators
to
satisfy
financial
requirements
for
liability
by
obtaining
liability
insurance
that
conforms
to
the
requirements
of
section
264.147(
h).
The
following
data
items
are
required:

°
A
duplicate
of
the
endorsement
or
certificate
of
insurance;
and
°
A
duplicate
of
the
insurance
policy,
if
requested
by
the
Regional
Administrator.

(
ii)
Respondent
activities:

Owners
or
operators
will
need
to
engage
in
the
following
activities
to
complete
the
requirements
for
this
option:

°
Reading
the
regulations;

°
Obtaining
an
insurance
policy
amended
by
attachment
of
the
Hazardous
Waste
Facility
Liability
Endorsement
or
evidenced
by
a
Certificate
of
Liability
Insurance
and
meeting
other
specifications
outlined
in
sections
264.147(
a)(
1)
and
264.147(
b)(
1);

°
Submitting
a
signed
duplicate
original
of
the
endorsement
or
the
certificate
of
insurance
to
the
Regional
Administrator,
or
Regional
Administrators
if
the
facilities
are
located
in
more
than
one
Region;
and
°
If
requested
by
the
Regional
Administrator,
submitting
a
signed
duplicate
original
of
the
insurance
policy
(
for
new
facilities
this
must
be
submitted
at
least
sixty
days
before
receiving
hazardous
waste
for
treatment
or
storage).

(
13)
Financial
Test
for
Liability
Coverage
(
i)
Data
items:

Section
267.147(
a)(
5)
allows
owners
or
operators
to
satisfy
liability
requirements
by
passing
a
financial
test,
as
specified
at
section
267.147(
f).
Data
items
for
this
option
include:

°
A
letter
signed
by
the
owner's
or
operator's
chief
financial
officer
and
worded
as
specified
in
section
264.151(
g);
if
the
financial
test
is
also
being
used
to
demonstrate
closure
or
post­
closure
financial
assurance,
the
letter
specified
in
55
section
264.151(
g)
must
be
submitted
to
cover
both
forms
of
financial
responsibility;

°
A
copy
of
an
independent
certified
public
accountant's
report
on
examination
of
the
owner's
or
operator's
financial
statements
for
the
latest
completed
fiscal
year;

°
A
special
report
from
the
owner's
or
operator's
independent
certified
public
accountant
to
the
owner
or
operator
covering
the
specifications
of
section
267.147(
f)(
2)(
i)(
C);

°
Annual
updates
of
the
above
data
items;
and
°
Should
the
owner
or
operator
fail
the
test
and
no
longer
meet
the
requirements
of
section
267.147(
f)(
1),
evidence
of
alternate
financial
assurance
obtained
for
the
entire
amount
of
required
liability
coverage
specified
in
section
267.147.

(
ii)
Respondent
activities:

Owners
or
operators
will
need
to
engage
in
the
following
respondent
activities
in
order
to
collect
the
data
required
by
these
sections:

°
Reading
the
regulations;

°
Writing
the
letter
signed
by
the
chief
financial
officer;

°
Submitting
the
following
documents
to
the
Regional
Administrator
(
for
new
facilities,
these
documents
must
be
submitted
at
least
sixty
days
prior
to
receiving
hazardous
waste
for
treatment
or
storage):

­­
The
letter
signed
by
the
chief
financial
officer;

­­
A
copy
of
an
independent
certified
public
accountant's
report;
and
­­
The
special
report
from
an
independent
certified
public
accountant;

°
Submitting
updated
information
annually;
and
°
Should
the
owner
or
operator
fail
the
test
and
no
longer
meet
section
267.147
requirements,
submitting
evidence
to
the
Regional
Administrator
of
alternate
financial
assurance
for
the
entire
amount
of
required
liability
coverage
specified
in
this
section.
56
(
14)
Corporate
Guarantee
for
Liability
Coverage
(
i)
Data
items:

Section
267.147(
g)
allows
owners
or
operators
to
meet
liability
requirements
by
obtaining
a
written
guarantee,
under
the
conditions
specified
in
section
267.147(
g)(
2).
Data
items
for
this
option
include:

°
A
certified
copy
of
a
written
guarantee
from
the
direct
or
higher­
tier
parent
corporation
of
the
owner
or
operator,
a
firm
whose
parent
corporation
is
the
parent
corporation
of
the
owner
or
operator,
or
a
firm
with
a
"
substantial
business
relationship"
with
the
owner
or
operator;

°
In
the
case
of
corporations
incorporated
in
the
United
States,
a
written
statement
from
applicable
Attorney(
s)
General
or
Insurance
Commissioners
to
EPA
indicating
that
a
guarantee
executed
as
described
in
the
regulations
is
a
legally
valid
and
enforceable
obligation
in
that
State;

°
In
the
case
of
corporations
incorporated
outside
the
United
States,
identification
by
the
non­
U.
S.
corporation
of
a
registered
agent
for
service
of
process
in
each
State
in
which
the
facility
covered
by
the
guarantee
is
located
and
in
the
State
in
which
it
has
its
principal
place
of
business,
and
a
written
statement
from
applicable
Attorney(
s)
General
or
Insurance
Commissioner
of
each
applicable
State
indicating
that
a
guarantee
executed
as
described
in
the
regulations
is
a
legally
valid
and
enforceable
obligation
in
that
State;
and
°
A
letter
from
the
guarantor's
chief
financial
officer
as
specified
in
section
267.147(
f)(
2)(
A)
that
demonstrates
that
the
guarantor
has
passed
the
financial
test.

(
ii)
Respondent
activities:

Owners
or
operators
will
need
to
engage
in
the
following
respondent
activities
in
order
to
collect
the
data
required
by
these
sections:

°
Reading
the
regulations;

°
Obtaining
a
written
guarantee
from
the
direct
or
higher­
tier
parent
corporation
of
the
owner
or
operator,
a
firm
whose
parent
corporation
is
the
parent
corporation
of
the
owner
or
operator,
or
a
firm
with
a
"
substantial
business
relationship"
with
the
owner
or
operator;

°
Submitting
a
certified
copy
of
this
written
guarantee
to
the
Regional
Administrator
along
with
the
items
specified
in
section
267.147(
f)(
2);
and
57
°
Submitting
a
letter
from
the
guarantor's
chief
financial
officer
as
specified
in
section
264.147(
f)(
2)(
i)(
A)
that
demonstrates
that
the
guarantor
has
passed
the
financial
test.

(
15)
Incapacity
of
Owners
or
Operators,
Guarantors,
or
Financial
Institutions
(
i)
Data
items:

Section
267.148
requires
owners
or
operators
to
submit
a
notification
of
the
commencement
of
a
voluntary
or
involuntary
proceeding
under
Title
11
(
Bankruptcy),
U.
S.
Code,
naming
the
owner
or
operator
as
debtor
(
if
the
guarantor
is
named
as
the
debtor,
the
collection
of
this
data
is
the
guarantor's
responsibility).

(
ii)
Respondent
activities:

Activities
for
this
data
collection
will
include:

°
Reading
the
regulations;
and
°
Submitting,
by
certified
mail,
a
notice
to
the
Regional
Administrator
indicating
the
commencement
of
bankruptcy
proceedings
in
which
the
owner
or
operator
or
guarantor
is
named
as
debtor.

(
16)
State
Assumption
of
Responsibility
(
i)
Data
items:

Section
267.150
requires
owners
or
operators
to
notify
EPA
when
a
State
assumes
legal
responsibility
or
assures
availability
of
funds
for
an
owner's
or
operator's
compliance
with
the
closure,
post­
closure
care,
or
liability
requirements
of
this
part.
Data
items
to
be
collected
in
this
case
include:

°
A
letter
from
the
owner
or
operator
requesting
that
the
State's
assumption
of
responsibility
be
considered
acceptable
for
meeting
the
requirements
of
this
subpart;

°
A
letter
from
the
State
describing
the
nature
of
the
State's
assumption
of
responsibility,
including
the
following
information:

­­
The
facility's
EPA
identification
number,
name,
and
address;
and
58
­­
The
amount
of
funds
for
closure
or
post­
closure
care
or
liability
coverage
that
are
guaranteed
by
the
State;
and
°
Any
additional
information
which
the
Regional
Administrator
deems
necessary
to
make
the
determination
whether
the
State's
assumption
of
responsibility
is
acceptable.

(
ii)
Respondent
activities:

Activities
for
this
data
collection
will
include:

°
Reading
the
regulations;
and
°
Submitting
to
the
Regional
Administrator:

­­
The
letter
from
the
owner
or
operator;
and
­­
The
letter
from
the
State
describing
the
State's
assumption
of
responsibility
and
including
the
information
specified
above;
and
°
Submitting
any
additional
information
requested
by
the
Regional
Administrator.

USE
AND
MANAGEMENT
OF
CONTAINERS
(
i)
Data
items:

Section
267.172
requires
owners
and
operators
of
facilities
that
store
or
treat
hazardous
waste
in
containers
to
inspect
areas
where
they
store
containers,
at
least
weekly.

(
ii)
Respondent
activities:

In
order
to
provide
the
above
data
item,
owners
and
operators
will
need
to
perform
the
following
activities:

°
Read
the
regulations;

°
Inspect
the
areas
where
they
store
containers,
at
least
weekly
(
section
267.172);
and
°
Record
the
results
of
the
inspection
(
section
267.15(
d)).
59
In
addition,
section
267.177
requires
owners
and
operators
to
manage
all
hazardous
waste
placed
in
containers
according
to
the
air
emission
requirements
established
in
subparts
BB
and
CC
of
part
264.
These
requirements,
however,
are
not
addressed
in
this
ICR
since
they
are
already
covered
in
the
Supporting
Statement
for
EPA
Information
Collection
Request
Number
1572.04,"
Hazardous
Waste
Specific
Unit
Requirements,
and
Special
Waste
Processes
and
Types"
and
in
the
Supporting
Statement
Environmental
Protection
Agency
Information
Collection
Request
Number
1593.04
"
Standards
of
Performance
for
Air
Emission
Standards
for
Tanks,
Surface
Impoundments
and
Containers,
40
CFR
Part
264,
Subpart
CC
and
40
CFR
Part
265,
Subpart
CC."

TANK
SYSTEMS
(
1)
Applicability
(
i)
Data
items:

Section
267.190
allows
owners
and
operators
to
exempt
their
facilities
from
the
secondary
containment
requirements
in
section
267.195
if
they
can
demonstrate
that
their
tank
systems
do
not
contain
free
liquids
and
are
situated
inside
a
building
with
an
impermeable
floor.
To
obtain
this
exemption,
owners
and
operators
must
demonstrate
the
absence
or
presence
of
free
liquids
in
the
stored/
treated
waste,
using
Method
9095
(
Paint
Filter
Liquids
Test)
as
described
in
"
Test
Methods
for
Evaluating
Solid
Waste,
Physical/
Chemical
Methods,"
EPA
Publication
SW­
846.

(
ii)
Respondent
activities:

Respondent
activities
associated
with
the
above
data
item
include:

°
Reading
the
regulations;
and
°
Preparing
the
no
free
liquids
demonstration.

(
2)
Design
and
Construction
Standards
(
i)
Data
items:

Section
267.191
requires
owners
and
operators
to
obtain
a
written
assessment,
reviewed
and
certified
by
an
independent,
qualified
registered
professional
engineer,
following
section
270.11(
d),
attesting
that
the
tank
system
has
sufficient
structural
integrity
and
is
acceptable
for
the
storing
and
treating
of
hazardous
waste.
This
assessment
must
include
at
least
the
following
information:

°
Design
standard(
s)
for
the
construction
of
tank(
s)
and/
or
the
ancillary
equipment;
60
°
Hazardous
characteristics
of
the
waste(
s)
to
be
handled;

°
Factors
affecting
the
potential
for
corrosion
and
the
type
and
degree
of
external
corrosion
protection
needed
to
ensure
the
integrity
of
the
tank
system;
and
°
Design
considerations
to
ensure
that
the
tank
foundations
will
maintain
the
load
of
a
full
tank,
will
be
anchored
to
prevent
flotation
or
dislodgement,
and
will
withstand
the
effects
of
frost
heave.

(
ii)
Respondent
activities:

In
order
to
provide
the
data
items
described
above,
owners
and
operators
will
need
to
perform
the
following
activities:

°
Read
the
regulations;
and
°
Obtain
a
written
assessment
from
an
independent,
qualified
registered
professional
engineer.

(
3)
Installation
Requirements
(
i)
Data
items:

Section
267.194
requires
owners
and
operators
to
obtain,
and
keep
at
the
facility,
written
statements
by
those
persons
required
to
certify
the
design
of
the
tank
system
and
to
supervise
the
installation
of
the
tank
system
as
required
in
sections
267.192,
267.193,
and
267.194(
a)
and
(
b).

(
ii)
Respondent
activities:

In
order
to
provide
the
data
items
described
above,
owners
and
operators
will
need
to
perform
the
following
activities:

°
Reading
the
regulations;

°
Obtaining
the
written
statements;
and
°
Maintaining
the
statements
at
the
facility.
61
(
4)
Inspection
Requirements
(
i)
Data
items:

Section
267.199
requires
owners
and
operators
to
provide
the
following
data
items:

°
A
schedule
and
procedure
for
inspecting
overfill
controls;
and
°
The
results
of
inspections
carried
out
pursuant
to
267.199(
a)­(
c).

(
ii)
Respondent
activities:

In
order
to
comply
with
section
267.199
requirements,
owners
and
operators
must
perform
the
following
activities:

°
Reading
the
regulations;

°
Developing
and
follow
a
schedule
and
procedure
for
inspecting
overfill
controls;

°
Inspecting
the
following
at
least
once
each
operating
day:

­­
Aboveground
portions
of
the
tank
system
to
detect
corrosion
or
releases
of
waste;

­­
Data
gathered
from
monitoring
and
leak
detection
equipment
to
ensure
that
the
tank
system
is
being
operated
according
to
its
design;
and
­­
The
construction
materials
and
the
area
immediately
surrounding
the
externally
accessible
portion
of
the
tank
system,
including
the
secondary
containment
system
to
detect
erosion
or
signs
of
releases
of
hazardous
waste;

°
Inspecting
cathodic
protection
systems,
if
present,
according
to,
at
a
minimum,
the
following
schedule
to
ensure
that
they
are
functioning
properly:

­­
Confirm
that
the
cathodic
protection
system
is
operating
properly
within
six
months
after
initial
installation
and
annually
thereafter;

­­
Inspect
and/
or
test
all
sources
of
impressed
current,
as
appropriate,
at
least
every
other
month;
and
°
Documenting
in
the
facility
operating
record
the
results
of
the
above
required
inspections.
62
(
5)
Leaks
and
Spills
(
i)
Data
items:

Section
267.200
requires
owners
and
operators
to
provide
the
following
data
items
if
there
has
been
a
leak
or
spill
from
a
tank
system
or
secondary
containment
system,
or
if
either
system
is
unfit
for
use:

°
A
report
informing
the
Regional
Administrator
of
the
release
within
24
hours
of
its
detection;
and
°
A
report
to
the
Regional
Administrator,
within
30
days
of
detection,
containing
the
following
information:

­­
The
likely
route
of
migration
of
the
release;

­­
The
characteristics
of
the
surrounding
soil;

­­
The
results
of
any
monitoring
or
sampling
conducted
in
connection
with
the
release;

­­
The
proximity
to
downgradient
drinking
water,
surface
water,
and
populated
areas;
and
­­
A
description
of
response
actions
taken
or
planned.

Section
267.200(
f)
requires
owners
and
operators
who
have
made
extensive
repairs
to
a
tank
system
in
accordance
with
section
267.200(
e)
to
obtain
and
submit
a
certification
from
an
independent,
qualified,
registered,
professional
engineer
that
the
repaired
system
is
capable
of
handling
hazardous
waste
without
release
for
the
intended
life
of
the
system.

(
ii)
Respondent
activities:

The
data
items
above
will
require
the
following
respondent
activities:

°
Reading
the
regulations;

°
Preparing
and
submitting
a
report
to
the
Regional
Administrator
within
24
hours
of
leak
detection;

°
Preparing
and
submitting
a
report
to
the
Regional
Administrator
within
30
days
of
leak
detection;
and
63
°
Obtaining
and
submitting
an
engineer's
certification.

In
addition,
section
267.204
requires
owners
and
operators
to
manage
all
hazardous
waste
placed
in
a
tank
according
to
the
air
emission
requirements
established
in
subparts
BB
and
CC
of
part
264.
These
requirements,
however,
are
not
addressed
in
this
ICR
since
they
are
already
covered
in
the
Supporting
Statement
for
EPA
Information
Collection
Request
Number
1572.04,"
Hazardous
Waste
Specific
Unit
Requirements,
and
Special
Waste
Processes
and
Types"
and
in
the
Supporting
Statement
Environmental
Protection
Agency
Information
Collection
Request
Number
1593.04
"
Standards
of
Performance
for
Air
Emission
Standards
for
Tanks,
Surface
Impoundments
and
Containers,
40
CFR
Part
264,
Subpart
CC
and
40
CFR
Part
265,
Subpart
CC."

CONTAINMENT
BUILDINGS
(
1)
Additional
Standards
for
Liquid
Storage
(
i)
Data
items:

Section
267.1103(
d)
requires
owners
and
operators
to
inspect
and
record
in
the
facility's
operating
record,
at
least
once
every
seven
days,
data
gathered
from
monitoring
equipment
and
leak
detection
equipment
as
well
as
the
containment
building
and
the
area
immediately
surrounding
the
containment
building
to
detect
signs
of
releases
of
hazardous
waste.

(
ii)
Respondent
activities:

In
order
to
provide
the
above
data
items,
owners
and
operators
will
have
to
perform
the
following
activities:

°
Read
the
regulations;
°
Inspect
data
at
least
once
every
seven
days;
and
°
Record
the
results
in
the
facility's
operating
record.

(
2)
Waiver
from
Secondary
Containment
Requirements
(
i)
Data
items:

Section
267.1104
allows
owners
and
operators
to
obtain
a
waiver
from
secondary
containment
requirements
by
demonstrating
that
the
only
free
liquids
in
the
unit
are
limited
amounts
of
dust
suppression
liquids
required
to
meet
occupational
health
and
safety
requirements.

(
ii)
Respondent
activities:
64
Owners
and
operators
wishing
to
waive
the
secondary
containment
requirements
must
perform
the
following
activities:

°
Reading
the
regulations;
and
°
Preparing
the
demonstration.

(
3)
Containment
Buildings
with
Areas
Both
with
and
Without
Secondary
Containment
(
i)
Data
items:

Section
267.1105
requires
owners
and
operators
of
containment
buildings
that
have
areas
both
with
and
without
secondary
containment
to
maintain
in
the
facility's
operating
log
a
written
description
of
the
operating
procedures
used
to
maintain
the
integrity
of
areas
without
secondary
containment.

(
ii)
Respondent
activities:

Respondent
activities
associated
with
the
above
data
items
include:

°
Reading
the
regulations;
and
°
Preparing
and
maintaining
a
written
description
of
the
operating
procedures.

(
4)
Releases
of
Hazardous
Waste
(
i)
Data
items:

Section
267.1106
requires
owners
and
operators
that
detect
a
condition
that
could
lead
to
or
has
caused
a
release
of
hazardous
waste
to
provide
the
following:

°
A
record
of
the
discovery
in
the
facility
operating
record;

°
A
notification
to
the
Director
of
the
condition;

°
A
written
notice
to
the
Director
with
a
description
of
the
steps
taken
to
repair
the
containment
building,
and
the
schedule
for
accomplishing
the
work;
and
°
Upon
completion
of
all
repairs
and
cleanup,
a
written
notification
to
the
Director
providing
verification,
signed
by
a
qualified,
registered,
professional
engineer,
that
the
repairs
and
cleanup
have
been
completed
according
to
the
written
plan
described
above.
65
(
ii)
Respondent
activities:

In
order
to
provide
the
above
data
items,
owners
and
operators
will
need
to
perform
the
following
activities:

°
Reading
the
regulations;

°
Entering
a
record
of
the
discovery
in
the
operating
record;

°
Preparing
and
submitting
a
notification
to
the
Director
within
7
days
of
the
discovery;

°
Preparing
and
submitting
the
written
notice
to
the
Director
within
14
working
days
of
the
discovery;
and
°
Preparing
and
submitting
the
written
verification
to
the
Director.
66
5.
THE
INFORMATION
COLLECTED
­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
The
following
section
discusses
how
EPA
and
implementing
agencies
would
collect
and
manage
the
information
received
from
respondents.
This
section
also
includes
a
discussion
of
how
EPA
would
take
steps
to
ensure
that
the
information
collections
are
not
overly
burdensome
on
small
entities.

5(
a)
Agency
Activities
APPLYING
FOR
A
STANDARDIZED
PERMIT
Agency
activities
associated
with
a
standardized
permit
application
and
renewal
include
reviewing
the
incoming
notice
of
intent
and
supporting
information,
determining
whether
the
facility
is
eligible
for
the
standardized
permit,
and
entering
the
information
into
a
database.

MAINTAINING
A
STANDARDIZED
PERMIT
(
1)
Routing
Changes
Agency
activities
associated
with
routine
changes
to
a
standardized
permit
include
reviewing
the
information
submitted
by
the
permit
holder.

(
2)
Significant
Changes
Agencies
activities
associated
with
significant
changes
to
a
standardized
permit
include
reviewing
the
incoming
modification
request
and
supporting
information,
reviewing
the
proof
of
public
notice,
and
entering
the
information
into
a
database.

GENERAL
FACILITY
STANDARDS
Agency
activities
associated
with
general
facility
standards
requirements
include:


Issuing
an
identification
number
to
new
facilities,
and
entering
the
facility
in
the
hazardous
waste
facility
data
system.


During
inspection
of
the
facility,
reviewing
the
security
procedures
and
determining
if
the
components
of
the
security
system
are
in
place
and
in
working
order.


Reviewing
information
submitted
by
permit
holders
seeking
for
a
waiver
from
security
requirements,
and
deciding
whether
to
grant
the
request.
67

Reviewing
demonstration
of
compliance
with
location
factors
submitted
by
permit
holders.


Reviewing
information
submitted
by
permit
holders
seeking
for
a
waiver
from
location
standards.

PREPAREDNESS
AND
PREVENTION
Although
the
information
is
not
formally
submitted
to
the
permitting
agency,
the
permitting
agency
may
review
documentation
on
any
refusal
on
the
part
of
local
authorities
to
enter
into
an
arrangement
to
handle
emergencies.

CONTINGENCY
PLAN
AND
EMERGENCY
PROCEDURES
Agency
activities
associated
with
the
development
and
amendment
of
the
contingency
plan
include:
reviewing
the
contingency
plan
during
on­
site
inspections
and
reviewing
revisions
to
the
contingency
plan.

Agency
activities
associated
with
emergency
reporting
requirements
include
reviewing
documents
in
the
owners'
or
operators'
and
emergency
coordinators'
emergency
reports.

RECORD
KEEPING,
REPORTING,
AND
NOTIFYING
Only
one
Agency
activity
is
associated
with
the
operating
record
requirements:
on­
site
review
of
the
record.

CLOSURE
Agency
activities
associated
with
closure
include
reviewing
closure
plans,
closure
plan
amendment
notifications,
partial/
final
closure
notifications,
and
closure
certifications.
In
addition,
the
permitting
agency
must
issue
a
public
notice
for
comments
on
the
closure
plan
and
make
a
determination
whether
to
approve,
modify,
or
disapprove
the
closure
plan.

FINANCIAL
REQUIREMENTS
Agency
activities
pertaining
to
financial
requirements
include:


Reviewing
closure
cost
estimates,
demonstrations
of
financial
assurance
for
closure,
and
demonstrations
of
financial
assurance
for
liability.


Entering
the
information
into
the
RCRIS
database.
68
USE
AND
MANAGEMENT
OF
CONTAINERS
Although
the
information
is
not
formally
submitted
to
the
permitting
agency,
the
permitting
agency
may
review
inspection
records
during
site
inspections.

TANK
SYSTEMS
Agency
activities
pertaining
to
tank
systems
requirements
include
reviewing
notifications
and
detailed
reports
on
any
releases
to
the
environment.
In
addition,
the
permitting
agency
may
review
inspection
records
during
site
inspections.

CONTAINMENT
BUILDINGS
Agency
activities
pertaining
to
tank
systems
requirements
include
reviewing
notifications
on
any
releases
to
the
environment
and
documentation
submitted
to
support
requests
for
secondary
containment
requirements
waivers.
In
addition,
the
permitting
agency
may
review
inspection
records
during
site
inspections.

5(
b)
Collection
Methodology
and
Management
The
permitting
agency
will
receive
and
keep
records
of
the
notifications
and
supporting
documentation
submitted
by
facility
owners
and
operators
applying
for,
renewing,
or
modifying
a
standardized
permit.
The
permitting
agency
will
also
collect
and
keep
records
of
closure
plans
and
closure
certifications
submitted
by
facilities
operating
under
a
standardized
permit.
In
collecting
and
reviewing
this
information,
the
permitting
agency
would
use
state­
of­
the­
art
electronic
equipment
such
as
personal
computers
and
applicable
data
software,
when
appropriate.

5(
c)
Small
Entity
Flexibility
The
proposed
rule
would
provide
regulatory
relief
from
parts
of
RCRA
hazardous
waste
permitting
program
for
facilities
with
tanks,
containers,
and
containment
buildings
that
apply
and
obtain
a
standardized
permit.
Thus,
small
facilities,
among
others,
would
see
relief.
In
addition,
the
proposed
regulations
would
allow
these
facilities
to
maintain
most
information
in
facility
records
rather
than
in
submittals
to
EPA,
thus
reducing
time
and
costs
for
providing
information.
Since
small
facilities
conduct
operations
that
are
equally
as
hazardous
to
the
environment
as
those
conducted
by
larger
facilities,
EPA
determined
that
small
businesses
should
be
required
to
comply
with
the
same
regulations
as
large
businesses.
As
a
result
of
this
interpretation,
no
specific
requirements
are
outlined
for
smaller
facilities.

5(
d)
Collection
Schedule
Under
section
124.204,
the
permitting
agency
is
required
to
collect,
review,
and
keep
records
of
notices
of
intent
and
supporting
information
submitted
by
facility
owners
and
operators
69
applying
for
standardized
permits.
This
information
is
used
to
determine
whether
a
facility
is
or
is
not
eligible
to
operate
under
a
standardized
permit.
Once
the
permitting
agency
makes
the
preliminary
decision
to
either
grant
or
deny
coverage
under
the
standardized
permit,
section
124.207
requires
the
permitting
agency
to
provide
public
notice
of
the
draft
permit
decision,
including
any
proposed
site­
specific
conditions
in
a
supplemental
portion,
and
to
provide
an
opportunity
for
the
public
to
submit
comments
and
request
a
hearing
on
that
decision.
The
public
notice
issued
by
the
permitting
agency
must
allow
at
least
45
days
for
people
to
submit
written
comments
on
the
draft
permit
decision
(
section
124.208(
a)).
Information
collected
during
the
public
comment
period
is
considered
when
making
a
final
determination
on
whether
to
grant
or
deny
coverage
to
a
facility
to
operate
under
the
standardized
permit.
If
coverage
is
granted,
the
permitting
agency
considers
the
public
comments
when
specifying
terms
and
conditions
in
the
supplemental
portion
of
the
standardized
permit,
if
any.

Under
section
267.112,
facility
owners
and
operators
must
submit
a
written
closure
plan
at
least
180
days
before
they
expect
to
begin
closure.
Once
the
permitting
agency
receives
this
information,
it
must
review
and
approve
the
closure
plan.
In
addition,
the
permitting
agency
must
provide
the
public
an
opportunity
to
comment
on
the
plan.
The
comment
period
will
be
open
for
30
days.
The
permitting
agency
will
also,
in
response
to
a
request
or
at
its
own
discretion,
hold
a
public
hearing
whenever
such
a
hearing
might
clarify
one
or
more
issues
concerning
the
closure
plan.
After
review
of
the
public
comments,
the
permitting
agency
will
approve,
modify,
or
disapprove
the
plan.
If
the
permitting
agency
does
not
approve
the
closure
plan,
it
must
provide
the
facility
owner
or
operator
with
a
detailed
written
statement
of
reasons
for
the
refusal.
The
permitting
agency
then
will
approve
or
modify
the
new
closure
plan.
Once
closure
is
completed,
the
permitting
agency
must
collect
and
review
a
certification
submitted
by
the
facility
owner
or
operator
stating
that
each
hazardous
waste
management
unit
or
facility,
as
applicable,
has
been
closed
following
the
specifications
in
the
closure
plan.
70
1
To
the
greatest
extent
possible,
EPA
obtained
its
burden
estimates
for
activities
in
this
ICR
from
approved
Office
of
Solid
Waste
(
OSW)
ICRs
(
e.
g.,
Supporting
Statement
for
EPA
Information
Collection
Request
Number
1573.05,
"
Part
B
Permit
Application,
Permit
Modifications,
and
Special
Permits").

2
The
book
was
edited
by
Eva
Jacobs,
and
was
published
in
1998
by
Bernan
Press.

3
The
report
was
authored
by
U.
S.
EPA,
RCRA
Enforcement
Division,
Office
of
Regulatory
Enforcement,
and
was
published
in
February
1997.
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
EPA
estimated
respondent
burden
associated
with
all
of
the
requirements
covered
in
this
ICR
in
Exhibits
1
through
9.
The
exhibits
estimate
the
number
of
hours
required
to
conduct
each
individual
information
collection
activity
and
the
cost
associated
with
that
activity.
1
6(
b)
Estimating
Respondent
Costs
Labor
Costs
EPA
estimates
an
average
hourly
respondent
labor
cost
(
including
overhead)
of
$
102.00
for
legal
staff,
$
73.00
for
managerial
staff,
$
53.00
for
technical
staff,
and
$
27.00
for
clerical
staff.
To
arrive
at
these
estimates,
EPA
consulted
the
Handbook
of
U.
S.
Labor
Statistics,
Second
Edition2,
and
the
EPA
report
Estimating
Costs
for
the
Economic
Benefits
of
RCRA
Noncompliance.
3
These
publications
summarize
the
unloaded
(
base)
hourly
rate
for
various
labor
categories
in
U.
S.
firms.
EPA
then
applied
an
overhead
factor
of
2.3
for
non­
legal
staff
and
3.0
for
legal
staff
to
derive
their
loaded
hourly
rates.
Using
the
total
burden
hours
mentioned
in
the
above
section,
Exhibits
1
through
9
estimate
the
respondent
costs
associated
with
all
of
the
information
collection
activities
covered
in
this
ICR.

Capital
Costs
EPA
estimates
that
only
new
facilities
will
incur
capital
costs
associated
with
purchasing
file
storage
systems
for
maintaining
records.
EPA
realizes
that
facilities
will
likely
use
different
and
various
file
storage
systems
(
e.
g.,
file
cabinets,
CD­
ROM,
off­
site
storage,
etc)
and
store
their
files
on
different
media
(
paper,
microfiche,
electronic
files,
etc).
For
purposes
of
estimating
these
capital
costs
across
all
facilities,
EPA
has
made
the
conservative
assumption
that
every
new
facility
will
store
their
files
in
paper
form
in
file
cabinets.
71
4
EPA
assumes
existing
permitted
and
interim­
status
facilities
have
already
compiled
much
of
the
materials
required
in
the
standardized
permit
application;
and
thus,
they
have
already
purchased
the
file
cabinets
needed.
EPA
estimates
that
each
new
facility
will
need
to
purchase
one
5­
drawer
lateral
file
cabinet
to
maintain
their
application
materials
over
the
ten­
year
life
of
their
permit.
4
The
current
market
price
for
such
a
file
cabinet
is
$
549.
EPA
has
annualized
this
cost
at
a
discount
rate
of
7
percent
over
ten
years
(
based
on
the
average
life
of
the
permit).
Thus,
EPA
estimates
the
annualized
net
present
value
of
this
capital
cost
to
be
$
78
per
facility.
In
Exhibit
19,
EPA
has
included
the
annualized
capital
cost
for
the
two
new
facilities
expected
to
apply
for
and
obtain
a
standardized
permit
each
year
($
156
per
year).

Operation
and
Maintenance
Costs
EPA
estimates
that
respondents
may
incur
annual
operations
and
maintenance
costs
associated
with
the
proposed
information
collection
requirements.
EPA
estimates
that
sending
a
notification
to
EPA
under
sections
124.202,
270.275,
270.280,
and
270.285
would
cost
about
$
3.00
for
the
mailing
expense
(
e.
g.,
for
certified
mail
with
return
receipt).

In
this
ICR,
EPA
also
estimates
costs
to
respondents
for
obtaining
contractor­
related
services,
such
as
preparing
compliance
demonstrations
for
containers
and
tank
systems.

6(
c)
Estimating
Agency
Burden
and
Costs
EPA
estimates
annual
Agency
burden
and
costs
associated
with
all
of
the
requirements
covered
in
this
ICR
in
Exhibits
10
through
18.
Based
on
a
1999
GS
pay
schedule,
EPA
estimates
an
average
hourly
Regional
labor
cost
of
$
60.89
for
legal
staff,
$
56.95
for
managerial
staff,
$
41.75
for
technical
staff,
and
$
16.77
for
clerical
staff.
The
labor
costs
were
based
on
the
following
GS
levels
and
steps:
legal
labor
rates
were
based
on
GS
Level
15,
Step
1,
managerial
labor
rates
were
based
on
GS
Level
14,
Step
4,
technical
labor
rates
were
based
on
GS
Level
12,
Step
5,
and
clerical
labor
rates
were
based
on
GS
Level
5,
Step
1.

To
derive
hourly
estimates,
EPA
divided
annual
compensation
estimates
by
2,080,
which
is
the
number
of
hours
in
the
Federal
work­
year.
EPA
then
multiplied
hourly
rates
by
the
standard
government
overhead
factor
of
1.6.
72
EXHIBIT
1
STANDARDIZED
PERMITS
ESTIMATED
ANNUAL
RESPONDENT
BURDEN
AND
COST
APPLYING
FOR
A
STANDARDIZED
PERMIT
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Leg.

$
102.00/

Hour
Mgr.

$
73.00/

Hour
Tech.

$
53.00/

Hour
Cler.

$
27.00/

Hour
Respon.

Hours/

Year
Labor
Cost/

Year
O
&
M
Cost
Respon.

or
Activities
Total
Hours/

Year
Total
Cost/

Year
General
Information
Requirements
(
124.202,
270.275,
270.280,
&
270.285)

Read
the
regulations
­
0.50
0.50
­
1.00
$
63.00
$
­
175
175
$
11,025
Prepare
a
written
notice
of
intent
to
operate
under
a
standardized
permit
0.10
0.10
0.25
0.17
0.62
$
35.34
$
­
175
109
$
6,185
Obtain
the
Part
A
information
1.50
3.00
9.00
1.50
15.00
$
889.50
$
­
2
30
$
1,779
Obtain
the
meeting
summary
and
other
materials
required
by
section
124.31
­
4.00
12.00
2.00
18.00
$
982.00
$
­
175
3,150
$
171,850
Develop
documentation
of
compliance
with
location
standards
­
­
2.00
0.50
2.50
$
119.50
$
­
82
205
$
9,799
Prepare
information
allowing
the
Director
to
carry
out
other
Federal
obligations
­
1.00
4.00
2.00
7.00
$
339.00
$
­
82
574
$
27,798
Prepare
the
solid
waste
management
unit
information
­
0.25
4.00
0.25
4.50
$
237.00
$
­
82
369
$
19,434
Prepare
and
sign
the
certification
of
compliance
with
part
267
0.10
0.10
0.25
0.17
0.62
$
35.34
$
­
175
109
$
6,185
Prepare
a
schedule
of
compliance
with
part
267
0.17
0.25
2.00
0.50
2.92
$
155.09
$
­
9
26
$
1,396
Submit
the
above
information
to
the
Director
­
­
­
0.50
0.50
$
13.50
$
3.00
175
88
$
2,888
Record
Keeping
Requirements
(
270.290)

Read
the
regulations
­
0.50
0.50
­
1.00
$
63.00
$
­
82
82
$
5,166
Prepare
and
maintain
a
general
description
of
the
facility
­
1.00
8.00
2.00
11.00
$
551.00
$
­
2
22
$
1,102
Prepare
and
maintain
a
justification
for
any
modification
of
the
preparedness
and
prevention
requirements
­
­
0.50
0.50
1.00
$
40.00
$
­
9
9
$
360
Prepare
and
maintain
a
description
of
the
procedures,
structures,
and
equipment
used
at
the
facility
­
0.25
4.00
0.50
4.75
$
243.75
$
­
82
390
$
19,988
Prepare
and
maintain
a
description
of
traffic
patterns,
estimated
volumes,
and
controls
near
the
facility
­
0.10
1.00
0.15
1.25
$
64.35
$
­
82
103
$
5,277
Obtain
and
maintain
a
topographic
map
­
­
11.00
0.50
11.50
$
596.50
$
20.00
2
23
$
1,233
EXHIBIT
1
(
CONTINUED)

STANDARDIZED
PERMITS
ESTIMATED
ANNUAL
RESPONDENT
BURDEN
AND
COST
APPLYING
FOR
A
STANDARDIZED
PERMIT
73
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Leg.

$
102.00/

Hour
Mgr.

$
73.00/

Hour
Tech.

$
53.00/

Hour
Cler.

$
27.00/

Hour
Respon.

Hours/

Year
Labor
Cost/

Year
O
&
M
Cost
Respon.

or
Activities
Total
Hours/

Year
Total
Cost/

Year
Container
Information
Requirements
(
270.300)

Read
the
regulations
­
0.25
0.25
­
0.50
$
31.50
$
­
81
41
$
2,552
Prepare
and
maintain
a
description
of
the
containment
system
­
1.00
4.80
0.40
6.20
$
338.20
$
1,233.33
81
502
$
127,294
Prepare
and
maintain
a
demonstration
of
compliance
with
Section
267.175(
c)
­
0.30
2.40
0.20
2.90
$
154.50
$
500.00
81
235
$
53,015
Obtain
and
maintain
sketches,
drawings,
or
data
demonstrating
compliance
with
Sections
267.174
&

267.175(
c)
­
1.00
5.00
0.50
6.50
$
351.50
$
500.00
81
527
$
68,972
Prepare
and
maintain
a
description
of
the
procedures
used
to
ensure
compliance
with
Sections
267.175(
a)
&
(
b)
­
1.30
16.80
1.30
19.40
$
1,020.40
$
700.00
81
1,571
$
139,352
Tank
Information
Requirements
(
270.305)

Read
the
regulations
­
0.25
0.25
­
0.50
$
31.50
$
­
68
34
$
2,142
Document
and
maintain
the
dimensions
and
capacity
of
each
tank
­
3.00
12.00
1.00
16.00
$
882.00
$
2,000.00
68
1,088
$
195,976
Prepare
and
maintain
a
description
of
feed
systems,
safety
cutoff,
bypass
systems,
and
pressure
controls
­
­
3.00
1.00
4.00
$
186.00
$
500.00
68
272
$
46,648
Prepare
and
maintain
a
diagram
of
piping,

instrumentation,
and
a
process
flow
of
each
tank
system
­
3.00
12.00
1.00
16.00
$
882.00
$
500.00
68
1,088
$
93,976
Prepare
and
maintain
a
detailed
description
of
how
new
tank
systems
will
be
installed
in
compliance
with
Section
267.194
­
­
4.00
0.50
4.50
$
225.50
$
500.00
14
63
$
10,157
Prepare
and
maintain
detailed
plans
for
containment
systems
­
1.00
5.00
0.40
6.40
$
348.80
$
1,200.00
68
435
$
105,318
Prepare
and
maintain
a
description
of
controls
and
practices
to
prevent
spills
and
overflows
­
­
3.00
0.50
3.50
$
172.50
$
­
68
238
$
11,730
Prepare
and
maintain
a
description
of
operating
procedure
compliance
for
ignitable,
reactive,
or
incompatible
wastes
­
­
3.00
0.50
3.50
$
172.50
$
­
68
238
$
11,730
EXHIBIT
1
(
CONTINUED)

STANDARDIZED
PERMITS
ESTIMATED
ANNUAL
RESPONDENT
BURDEN
AND
COST
APPLYING
FOR
A
STANDARDIZED
PERMIT
74
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Leg.

$
102.00/

Hour
Mgr.

$
73.00/

Hour
Tech.

$
53.00/

Hour
Cler.

$
27.00/

Hour
Respon.

Hours/

Year
Labor
Cost/

Year
O
&
M
Cost
Respon.

or
Activities
Total
Hours/

Year
Total
Cost/

Year
Equipment
Information
Requirements
(
270.310)

Read
the
regulations
­
0.25
0.25
­
0.50
$
31.50
$
­
1
1
$
32
Maintain
the
equipment
identification
number
and
hazardous
waste
management
unit
identification
­
0.25
0.25
0.10
0.60
$
34.20
$
­
1
1
$
34
Prepare
and
maintain
approximate
locations
within
the
facility
­
0.25
0.25
0.10
0.60
$
34.20
$
­
1
1
$
34
Prepare
and
maintain
descriptions
of
the
type
of
equipment
­
0.50
3.00
0.50
4.00
$
209.00
$
­
1
4
$
209
Prepare
and
maintain
descriptions
of
the
percent
by
weight
of
total
organics
in
the
hazardous
waste
stream
at
the
equipment
­
0.25
1.00
0.25
1.50
$
78.00
$
­
1
2
$
78
Prepare
and
maintain
descriptions
of
the
hazardous
waste
state
at
the
equipment
­
0.25
1.00
0.25
1.50
$
78.00
$
­
1
2
$
78
Prepare
and
maintain
descriptions
of
the
methods
of
compliance
0.25
1.00
0.25
1.50
$
78.00
$
­
1
2
$
78
Prepare
and
maintain
an
implementation
schedule
for
compliance
with
Part
264
subpart
BB
requirements
­
0.25
1.00
0.25
1.50
$
78.00
$
­
1
2
$
78
Develop
and
maintain
a
performance
test
plan
­
1.00
7.00
2.00
10.00
$
498.00
$
­
1
10
$
498
Develop
and
maintain
documentation
that
demonstrates
compliance
with
equipment
standards
­
1.00
16.00
2.00
19.00
$
975.00
$
­
1
19
$
975
Develop
and
maintain
documentation
to
demonstrate
compliance
with
Section
264.1060
­
0.50
2.00
0.50
3.00
$
156.00
$
­
1
3
$
156
EXHIBIT
1
(
CONTINUED)

STANDARDIZED
PERMITS
ESTIMATED
ANNUAL
RESPONDENT
BURDEN
AND
COST
APPLYING
FOR
A
STANDARDIZED
PERMIT
75
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Leg.

$
102.00/

Hour
Mgr.

$
73.00/

Hour
Tech.

$
53.00/

Hour
Cler.

$
27.00/

Hour
Respon.

Hours/

Year
Labor
Cost/

Year
O
&
M
Cost
Respon.

or
Activities
Total
Hours/

Year
Total
Cost/

Year
Air
Emissions
Control
Requirements
(
270.315)

Read
the
regulations
­
0.25
0.25
­
0.50
$
31.50
$
­
2
1
$
63
Prepare
and
maintain
documentation
for
floating
roof
covers
­
0.25
0.25
­
0.50
$
31.50
$
­
2
1
$
63
Prepare
and
maintain
a
certification
that
covers
meet
applicable
design
specifications
­
0.25
0.50
­
0.75
$
44.75
$
­
2
2
$
90
Prepare
and
maintain
identification
and
certifications
for
container
areas
­
0.25
0.50
­
0.75
$
44.75
$
­
2
2
$
90
Prepare
and
maintain
documentation
for
enclosures
used
to
control
air
pollutant
emissions
from
tanks
or
containers
­
0.10
0.15
­
0.25
$
15.25
$
­
2
1
$
31
Prepare
and
maintain
documentation
for
closedvent
systems
and
control
devices
­
0.10
0.15
­
0.25
$
15.25
$
­
2
1
$
31
Develop
and
maintain
emission
monitoring
plans
and
control
device
monitoring
methods
­
3.00
6.00
2.00
11.00
$
591.00
$
­
2
22
$
1,182
Switching
from
an
Individual
RCRA
Permit
to
a
Standardized
Permit
(
124.203)

Read
the
regulations
­
0.25
0.25
­
0.50
$
31.50
$
­
79
40
$
2,489
Prepare
and
submit
the
request
to
the
Director
0.50
1.00
2.00
0.50
4.00
$
243.50
$
3.00
79
316
$
19,474
Reapplying
for
a
Standardized
Permit
(
270.10(
h))

Read
the
regulations
­
0.25
0.25
­
0.50
$
31.50
$
­
0
0
$
0
Prepare
and
submit
the
notice
of
intent
0.50
1.00
2.00
0.50
4.00
$
243.50
$
3.00
0
0
$
0
Total
Varies
Varies
Varies
Varies
Varies
Varies
Varies
2,469
12,229
1,186,090
76
EXHIBIT
2
STANDARDIZED
PERMITS
ESTIMATED
ANNUAL
RESPONDENT
BURDEN
AND
COST
MAINTAINING
A
STANDARDIZED
PERMIT
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Leg.

$
102.00/

Hour
Mgr.

$
73.00/

Hour
Tech.

$
53.00/

Hour
Cler.

$
27.00/

Hour
Respon.

Hours/

Year
Labor
Cost/

Year
O
&
M
Cost
Respon.

or
Activities
Total
Hours/

Year
Total
Cost/

Year
Making
Routine
Changes
(
124.212
&
270.320(
a))

Read
the
regulations
2.00
1.00
1.00
­
4.00
$
330.00
$
­
18
72
$
5,940
Prepare
and
submit
revised
information
to
the
Director
1.00
1.00
8.00
2.00
12.00
$
653.00
$
3.00
18
216
$
11,808
Submit
revised
information
to
facility
mailing
list
and
local
governments
­
0.25
1.00
0.25
1.50
$
78.00
$
3.00
18
27
$
1,458
Making
Significant
Changes
(
124.213
&
270.320(
b))

Read
the
regulations
2.00
1.00
1.00
­
4.00
$
330.00
$
­
7
28
$
2,310
Prepare
and
submit
proof
of
public
notice
­
0.25
1.00
0.25
1.50
$
78.00
$
3.00
7
11
$
567
Prepare
and
submit
the
modification
request
to
the
Director
5.00
15.00
80.00
12.00
112.00
$
6,169.00
$
8,000.00
7
784
$
99,183
Total
Varies
Varies
Varies
Varies
Varies
Varies
Varies
75
1,138
$
121,266
77
EXHIBIT
3
STANDARDIZED
PERMITS
ESTIMATED
ANNUAL
RESPONDENT
BURDEN
AND
COST
GENERAL
FACILITY
STANDARDS
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Leg.

$
102.00/

Hour
Mgr.

$
73.00/

Hour
Tech.

$
53.00/

Hour
Cler.

$
27.00/

Hour
Respon.

Hours/

Year
Labor
Cost/

Year
O
&
M
Cost
Respon.

or
Activities
Total
Hours/

Year
Total
Cost/

Year
Obtaining
an
Identification
Number
(
267.12)

Read
the
regulations
­
0.25
0.25
­
0.50
$
31.50
$
­
0
0
$
0
Obtain,
fill
out,
and
submit
an
application
for
an
EPA
identification
number
­
0.25
0.50
0.25
1.00
$
51.50
$
3.00
0
0
$
0
Waste
Analysis
(
267.13(
a))

Read
the
regulations
­
0.25
0.75
­
1.00
$
58.00
$
­
0
0
$
0
Collect
data
­
­
3.00
0.50
3.50
$
172.50
$
­
0
0
$
0
Perform
waste
analysis
­
­
10.00
­
10.00
$
530.00
$
1,500.00
0
0
$
0
Waste
Analysis
Plan
(
267.13(
b))

Read
the
regulations
­
0.25
0.75
­
1.00
$
58.00
$
­
0
0
$
0
Collect
the
data
required
for
the
waste
analysis
plan
­
­
10.00
­
10.00
$
530.00
$
­
0
0
$
0
Write
the
waste
analysis
plan
­
10.00
60.00
0.50
70.50
$
3,923.50
$
­
0
0
$
0
Maintain
the
waste
analysis
plan
­
­
­
1.00
1.00
$
27.00
$
­
0
0
$
0
Security
(
267.14(
b))

Read
the
regulations
­
0.25
0.25
­
0.50
$
31.50
$
­
0
0
$
0
Collect
the
required
documents
­
­
1.00
0.50
1.50
$
66.50
$
­
0
0
$
0
Maintain
the
required
documents
­
­
­
1.00
1.00
$
27.00
$
­
0
0
$
0
EXHIBIT
3
(
CONTINUED)

STANDARDIZED
PERMITS
ESTIMATED
ANNUAL
RESPONDENT
BURDEN
AND
COST
GENERAL
FACILITY
STANDARDS
78
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Leg.

$
102.00/

Hour
Mgr.

$
73.00/

Hour
Tech.

$
53.00/

Hour
Cler.

$
27.00/

Hour
Respon.

Hours/

Year
Labor
Cost/

Year
O
&
M
Cost
Respon.

or
Activities
Total
Hours/

Year
Total
Cost/

Year
Inspections
(
267.15)

Read
the
regulations
­
0.25
0.75
­
1.00
$
58.00
$
­
0
0
$
0
Prepare
the
inspection
schedule
­
8.00
80.00
1.00
89.00
$
4,851.00
$
­
0
0
$
0
Record
the
results
of
inspections
in
the
inspection
log
­
­
100.00
­
100.00
$
5,300.00
$
­
0
0
$
0
Maintain
the
inspection
schedule
­
­
­
1.00
1.00
$
27.00
$
100.00
0
0
$
0
Employee
Training
(
267.16(
d))

Read
the
regulations
­
0.25
0.75
­
1.00
$
58.00
$
­
0
0
$
0
Collect
employee
training
documentation
­
0.50
2.00
0.50
3.00
$
156.00
$
­
0
0
$
0
Maintain
the
employee
training
documentation
­
­
­
80.00
80.00
$
2,160.00
$
100.00
0
0
$
0
Ignitable,
Reactive,
or
Incompatible
Wastes
(
267.17(
c))

Read
the
regulations
­
0.25
0.75
­
1.00
$
58.00
$
­
0
0
$
0
Collect
and
document
compliance
­
1.00
40.00
1.00
42.00
$
2,220.00
$
­
0
0
$
0
Maintain
the
compliance
documentation
­
­
­
1.00
1.00
$
27.00
$
­
0
0
$
0
Total
Varies
Varies
Varies
Varies
Varies
Varies
Varies
0
0
$
0
79
EXHIBIT
4
STANDARDIZED
PERMITS
ESTIMATED
ANNUAL
RESPONDENT
BURDEN
AND
COST
PREPAREDNESS
AND
PREVENTION
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Leg.

$
102.00/

Hour
Mgr.

$
73.00/

Hour
Tech.

$
53.00/

Hour
Cler.

$
27.00/

Hour
Respon.

Hours/

Year
Labor
Cost/

Year
O
&
M
Cost
Respon.

or
Activities
Total
Hours/

Year
Total
Cost/

Year
Arrangements
with
Local
Authorities
(
267.36(
b))

Read
the
regulations
­
0.25
0.75
­
1.00
$
58.00
$
­
0
0
$
0
Document
any
refusals
of
local
authorities
and
place
in
operating
record
­
0.25
1.00
0.50
1.75
$
84.75
$
­
0
0
$
0
Total
Varies
Varies
Varies
Varies
Varies
Varies
Varies
0
0
$
0
80
EXHIBIT
5
STANDARDIZED
PERMITS
ESTIMATED
ANNUAL
RESPONDENT
BURDEN
AND
COST
CONTINGENCY
PLAN
AND
EMERGENCY
PROCEDURES
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Leg.

$
102.00/

Hour
Mgr.

$
73.00/

Hour
Tech.

$
53.00/

Hour
Cler.

$
27.00/

Hour
Respon.

Hours/

Year
Labor
Cost/

Year
O
&
M
Cost
Respon.

or
Activities
Total
Hours/

Year
Total
Cost/

Year
Contingency
Plan
(
267.51­
54)

Read
the
regulations
­
0.25
0.75
­
1.00
$
58.00
$
­
0
0
$
0
Collect
the
data
required
in
the
contingency
plan
­
­
12.00
3.00
15.00
$
717.00
$
­
0
0
$
0
Write
the
contingency
plan
­
1.00
60.00
4.00
65.00
$
3,361.00
$
­
0
0
$
0
Submit
the
contingency
plan
to
State
and
local
authorities
­
­
­
0.50
0.50
$
13.50
$
3.00
0
0
$
0
Maintain
the
contingency
plan
­
­
­
1.00
1.00
$
27.00
$
­
0
0
$
0
Emergency
Reporting
(
267.56(
c),
267.58(
a)
&
(
b))

Read
the
regulations
­
0.25
0.75
­
1.00
$
58.00
$
­
0
0
$
0
Submit
the
notification
of
an
imminent
or
actual
emergency
situation
to
State
and/
or
local
authorities
­
0.50
­
­
0.50
$
36.50
$
­
0
0
$
0
Notify
the
on­
scene
coordinator
or
the
National
Response
Center
of
any
release
­
0.50
­
­
0.50
$
36.50
$
­
0
0
$
0
Collect
the
information
required
in
the
emergency
report
­
­
2.50
0.50
3.00
$
146.00
$
­
0
0
$
0
Write
the
emergency
notification
report
­
1.00
­
­
1.00
$
73.00
$
­
0
0
$
0
Collect
the
information
required
in
the
emergency
report
­
­
8.00
0.50
8.50
$
437.50
$
­
0
0
$
0
Write
the
emergency
report
­
0.25
4.00
0.50
4.75
$
243.75
$
­
0
0
$
0
Compile
information
that
demonstrates
that
all
affected
areas
are
in
compliance
­
­
2.50
0.50
3.00
$
146.00
$
­
0
0
$
0
Prepare
a
letter
notifying
the
Regional
Administrator
of
compliance
­
0.25
1.50
0.25
2.00
$
104.50
$
­
0
0
$
0
Record
the
details
of
any
incident
that
requires
implementing
the
contingency
plan
in
the
operating
record
­
­
0.50
0.25
0.75
$
33.25
$
­
0
0
$
0
Total
Varies
Varies
Varies
Varies
Varies
Varies
Varies
0
0
$
0
81
EXHIBIT
6
STANDARDIZED
PERMITS
ESTIMATED
ANNUAL
RESPONDENT
BURDEN
AND
COST
RECORD
KEEPING,
REPORTING,
AND
NOTIFYING
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Leg.

$
102.00/

Hour
Mgr.

$
73.00/

Hour
Tech.

$
53.00/

Hour
Cler.

$
27.00/

Hour
Respon.

Hours/

Year
Labor
Cost/

Year
O
&
M
Cost
Respon.

or
Activities
Total
Hours/

Year
Total
Cost/

Year
Record
Keeping
(
267.71)

Maintain
documents
in
the
facility
operating
record
­
­
50.00
100.00
150.00
$
5,350.00
$
­
0
0
$
0
Notifications
(
267.74)

Read
the
regulations
­
0.10
0.25
­
0.35
$
20.55
$
­
0
0
$
0
Prepare
and
submit
written
notification
to
new
owner
or
operator
­
­
0.50
0.13
0.63
$
30.01
$
­
0
0
$
0
Total
Varies
Varies
Varies
Varies
Varies
Varies
Varies
0
0
$
0
82
EXHIBIT
7
STANDARDIZED
PERMITS
ESTIMATED
ANNUAL
RESPONDENT
BURDEN
AND
COST
CLOSURE
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Leg.

$
102.00/

Hour
Mgr.

$
73.00/

Hour
Tech.

$
53.00/

Hour
Cler.

$
27.00/

Hour
Respon.

Hours/

Year
Labor
Cost/

Year
O
&
M
Cost
Respon.

or
Activities
Total
Hours/

Year
Total
Cost/

Year
Closure
Plan
(
267.112)

Read
the
regulations
­
0.50
3.00
­
3.50
$
195.50
$
­
0
0
$
0
Conduct
a
hazardous
waste
inventory
­
­
8.00
­
8.00
$
424.00
$
­
0
0
$
0
Record
the
results
of
the
hazardous
waste
inventory
­
­
2.00
0.50
2.50
$
119.50
$
­
0
0
$
0
Write
a
description
for
the
necessary
closure
activities
­
1.00
20.00
3.00
24.00
$
1,214.00
$
­
0
0
$
0
Estimate
final
closure
­
0.25
0.25
­
0.50
$
31.50
$
­
0
0
$
0
Write
the
closure
schedule
­
0.50
1.00
0.50
2.00
$
103.00
$
­
0
0
$
0
Notification
Before
Partial
Closure
and
Final
Closure
(
267.112(
c))

Read
the
regulations
­
0.10
0.25
­
0.35
$
20.55
$
­
0
0
$
0
Prepare
the
written
notification
of
closure
­
0.25
0.50
0.25
1.00
$
51.50
$
3.00
0
0
$
0
Submit
the
closure
plan
­
­
­
1.00
1.00
$
27.00
$
3.00
0
0
$
0
Certification
of
Closure
Read
the
regulations
­
0.10
0.25
­
0.35
$
20.55
$
­
0
0
$
0
Prepare
the
certification
­
­
11.00
2.00
13.00
$
637.00
$
500.00
0
0
$
0
Submit
the
certification
­
­
­
1.00
1.00
$
27.00
$
3.00
0
0
$
0
Total
Varies
Varies
Varies
Varies
Varies
Varies
Varies
0
0
$
0
83
EXHIBIT
8
STANDARDIZED
PERMITS
ESTIMATED
ANNUAL
RESPONDENT
BURDEN
AND
COST
FINANCIAL
REQUIREMENTS
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Leg.

$
102.00/

Hour
Mgr.

$
73.00/

Hour
Tech.

$
53.00/

Hour
Cler.

$
27.00/

Hour
Respon.

Hours/

Year
Labor
Cost/

Year
O
&
M
Cost
Respon.

or
Activities
Total
Hours/

Year
Total
Cost/

Year
Reading
the
Regulations
Read
the
regulations
covering
financial
requirements
8.00
2.00
8.00
­
18.00
$
­
$
­
0
0
$
0
Cost
Estimate
for
Closure
(
267.142(
a)­(
c))

Prepare
a
detailed
estimate
of
closure
costs
­
­
10.00
3.00
13.00
$
611.00
$
­
0
0
$
0
Update
the
estimate
for
inflation
annually
­
­
0.50
­
0.50
$
26.50
$
­
0
0
$
0
Maintain
the
estimate
at
the
facility
(
under
record
keeping)
­
$
­
0
0
$
0
Closure
Trust
Fund
(
267.143(
a))

Establish
a
closure
trust
fund
4.00
1.50
2.00
0.50
8.00
$
637.00
$
­
0
0
$
0
Submit
a
signed
duplicate
of
the
trust
agreement
to
the
Regional
Administrator
­
­
­
0.50
0.50
$
13.50
$
3.00
0
0
$
0
Submit
a
receipt
for
the
first
payment
to
the
Regional
Administrator
­
­
­
1.00
1.00
$
27.00
$
3.00
0
0
$
0
Surety
Bond
Guaranteeing
Payment
into
a
Closure
Trust
Fund
(
267.143(
b))

Establish
a
surety
bond
and
trust
agreement
4.00
1.50
2.00
0.50
8.00
$
637.00
$
­
0
0
$
0
Submit
originally
signed
duplicates
of
the
surety
bond
and
trust
agreement
to
the
Regional
Administrator
­
­
­
0.50
0.50
$
13.50
$
3.00
0
0
$
0
Surety
Bond
Guaranteeing
Performance
of
Closure
(
267.143(
c))

Obtain
a
surety
bond
and
trust
agreement
4.00
1.50
2.00
0.50
8.00
$
637.00
$
­
0
0
$
0
Submit
signed
duplicates
of
the
surety
bond
and
trust
agreement
to
the
Regional
Administrator
­
­
­
0.50
0.50
$
13.50
$
3.00
0
0
$
0
EXHIBIT
8
(
CONTINUED)

STANDARDIZED
PERMITS
ESTIMATED
ANNUAL
RESPONDENT
BURDEN
AND
COST
FINANCIAL
REQUIREMENTS
84
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Leg.

$
102.00/

Hour
Mgr.

$
73.00/

Hour
Tech.

$
53.00/

Hour
Cler.

$
27.00/

Hour
Respon.

Hours/

Year
Labor
Cost/

Year
O
&
M
Cost
Respon.

or
Activities
Total
Hours/

Year
Total
Cost/

Year
Closure
Letter
of
Credit
(
267.143(
d))

Obtain
a
letter
of
credit
and
establish
a
standby
trust
fund
4.00
1.50
2.00
0.50
8.00
$
637.00
$
­
0
0
$
0
Submit
the
letter
of
credit
and
a
duplicate
of
the
trust
agreement
to
the
Regional
Administrator
­
­
­
0.50
0.50
$
13.50
$
3.00
0
0
$
0
Closure
Insurance
(
267.143(
e))

Obtain
a
closure
insurance
policy
4.00
1.50
2.00
0.50
8.00
$
637.00
$
­
0
0
$
0
Submit
a
certificate
of
the
insurance
policy
to
the
Regional
Administrator
­
­
­
0.50
0.50
$
13.50
$
3.00
0
0
$
0
Corporate
Financial
Test
and
Corporate
Guarantee
(
267.143(
f)
&
(
g))

Prepare
and
submit
the
letter
signed
by
the
chief
financial
officer
1.00
0.25
2.00
0.75
4.00
$
246.50
$
3.00
0
0
$
0
Submit
a
copy
of
the
independent
certified
public
accountant's
report
and
special
report
­
­
­
1.00
1.00
$
27.00
$
3.00
0
0
$
0
Submit
updated
information
annually
­
­
­
4.00
4.00
$
108.00
$
3.00
0
0
$
0
Prepare
and
submit
a
notice
of
intent
to
establish
alternate
financial
assurance
to
the
Regional
Administrator
3.25
0.25
­
0.50
4.00
$
363.25
$
3.00
0
0
$
0
Write
and
submit
additional
reports
of
the
facility's
financial
condition,
as
directed
by
the
Regional
Administrator
2.25
0.25
1.00
0.50
4.00
$
314.25
$
3.00
0
0
$
0
Submit
the
corporate
guarantee
from
the
parent
corporation
­
­
­
1.00
1.00
$
27.00
$
3.00
0
0
$
0
Use
of
a
Financial
Assurance
Instrument
for
Multiple
Facilities
(
267.143(
i))

Submit
required
information
to
the
Regional
Administrator
0.50
1.00
0.50
2.00
4.00
$
204.50
$
3.00
0
0
$
0
Submit
evidence
of
financial
assurance
to
all
other
applicable
Regional
Administrators
­
­
­
0.50
0.50
$
13.50
$
3.00
0
0
$
0
EXHIBIT
8
(
CONTINUED)

STANDARDIZED
PERMITS
ESTIMATED
ANNUAL
RESPONDENT
BURDEN
AND
COST
FINANCIAL
REQUIREMENTS
85
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Leg.

$
102.00/

Hour
Mgr.

$
73.00/

Hour
Tech.

$
53.00/

Hour
Cler.

$
27.00/

Hour
Respon.

Hours/

Year
Labor
Cost/

Year
O
&
M
Cost
Respon.

or
Activities
Total
Hours/

Year
Total
Cost/

Year
Trust
Fund
for
Liability
Coverage
(
267.147(
a)(
3))

Establish
a
trust
fund
4.50
1.50
1.00
1.00
8.00
$
648.50
$
­
0
0
$
0
Submit
a
duplicate
of
the
trust
agreement
to
the
Regional
Administrator
­
­
­
1.00
1.00
$
27.00
$
3.00
0
0
$
0
Surety
Bond
for
Liability
Coverage
(
267.147(
a)(
2))

Obtain
a
surety
bond
and
submit
a
copy
to
the
Regional
Administrator
4.00
1.00
2.00
1.00
8.00
$
614.00
$
3.00
0
0
$
0
Letter
of
Credit
for
Liability
Coverage
(
267.147(
a)(
3))

Obtain
a
standby
letter
of
credit
and
submit
a
copy
to
the
Regional
Administrator
4.00
1.00
2.00
1.00
8.00
$
614.00
$
3.00
0
0
$
0
Liability
Insurance
(
267.147(
a)(
4))

Obtain
an
insurance
policy
and
submit
documentation
to
the
Regional
Administrator
4.00
1.00
2.00
1.00
8.00
$
614.00
$
3.00
0
0
$
0
Financial
Test
for
Liability
Coverage
(
267.147(
a)(
5)
&
267.147(
f))

Prepare,
write,
and
submit
the
letter
signed
by
the
chief
financial
officer
1.00
0.25
2.00
0.75
4.00
$
246.50
$
3.00
0
0
$
0
Obtain
and
submit
the
report
and
special
report
from
the
independent
certified
public
accountant
­
­
­
1.00
1.00
$
27.00
$
3.00
0
0
$
0
Submit
updated
information
annually
­
­
­
4.00
4.00
$
108.00
$
3.00
0
0
$
0
Prepare
and
submit
a
notice
of
intent
to
establish
alternate
financial
assurance
to
the
Regional
Administrator
3.25
0.25
­
0.50
4.00
$
363.25
$
3.00
0
0
$
0
EXHIBIT
8
(
CONTINUED)

STANDARDIZED
PERMITS
ESTIMATED
ANNUAL
RESPONDENT
BURDEN
AND
COST
FINANCIAL
REQUIREMENTS
86
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Leg.

$
102.00/

Hour
Mgr.

$
73.00/

Hour
Tech.

$
53.00/

Hour
Cler.

$
27.00/

Hour
Respon.

Hours/

Year
Labor
Cost/

Year
O
&
M
Cost
Respon.

or
Activities
Total
Hours/

Year
Total
Cost/

Year
Corporate
Guarantee
for
Liability
Coverage
(
267.147(
g)

Obtain
and
submit
a
written
guarantee
to
the
Regional
Administrator
0.50
0.50
0.50
0.50
2.00
$
127.50
$
3.00
0
0
$
0
Submit
a
letter
from
the
guarantor's
chief
financial
officer
­
­
­
1.00
1.00
$
27.00
$
3.00
0
0
$
0
Submit
updated
information
annually
­
­
­
4.00
4.00
$
108.00
$
3.00
0
0
$
0
Incapacity
of
Owners
or
Operator,
Guarantors,
or
Financial
Institutions
(
267.148)

Submit
by
certified
mail
a
notice
of
bankruptcy
to
the
Regional
Administrator
­
­
­
1.00
1.00
$
27.00
$
3.00
0
0
$
0
State
Assumption
of
Responsibility
(
267.150)

Prepare
and
submit
a
letter
from
the
owner
or
operator
to
the
Regional
Administrator
1.00
5.00
2.00
0.50
8.50
$
586.50
$
3.00
0
0
$
0
Obtain
and
submit
the
letter
from
the
State
­
­
­
1.00
1.00
$
27.00
$
3.00
0
0
$
0
Prepare
and
submit
any
additional
information
requested
by
the
Regional
Administrator
0.75
0.25
0.75
0.25
2.00
$
141.25
$
3.00
0
0
$
0
Total
Varies
Varies
Varies
Varies
Varies
Varies
Varies
0
0
$
0
87
EXHIBIT
9
STANDARDIZED
PERMITS
ESTIMATED
ANNUAL
RESPONDENT
BURDEN
AND
COST
SPECIFIC
UNIT
REQUIREMENTS
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Leg.

$
102.00/

Hour
Mgr.

$
73.00/

Hour
Tech.

$
53.00/

Hour
Cler.

$
27.00/

Hour
Respon.

Hours/

Year
Labor
Cost/

Year
O
&
M
Cost
Respon.

or
Activities
Total
Hours/

Year
Total
Cost/

Year
CONTAINERS
Inspection
Requirements
(
267.172
&
267.15(
d))

Read
the
regulations
­
0.25
0.25
­
0.50
$
31.50
$
­
0
0
$
0
Perform
weekly
inspections
and
record
results
­
­
100.00
­
100.00
$
5,300.00
$
­
0
0
$
0
TANK
SYSTEMS
Applicability
(
267.190)

Read
the
regulations
­
0.25
0.25
­
0.50
$
31.50
$
­
0
0
$
0
Prepare
the
no
free
liquids
demonstration
­
­
1.50
­
1.50
$
79.50
$
475.00
0
0
$
0
Design
and
Construction
Standards
(
267.191)

Read
the
regulations
­
0.25
0.25
­
0.50
$
31.50
$
­
0
0
$
0
Obtain
an
engineer's
written
assessment
­
3.00
12.00
1.00
16.00
$
882.00
$
2,000.00
0
0
$
0
Installation
Requirements
(
267.194)

Read
the
regulations
­
0.25
0.25
­
0.50
$
31.50
$
­
0
0
$
0
Obtain
the
written
statements
­
­
7.00
1.50
8.50
$
411.50
$
1,000.00
0
0
$
0
Maintain
the
written
statements
at
the
facility
­
­
­
0.10
0.10
$
2.70
$
3.00
0
0
$
0
Inspection
Requirements
(
267.199)

Read
the
regulations
­
0.25
0.25
­
0.50
$
31.50
$
­
0
0
$
0
Develop
an
inspection
schedule
­
8.00
80.00
1.00
89.00
$
4,851.00
$
­
0
0
$
0
Perform
daily
inspections
and
record
the
results
­
­
100.00
­
100.00
$
5,300.00
$
­
0
0
$
0
Perform
annual
inspections
of
cathodic
protection
system
and
record
the
results
­
­
20.00
­
20.00
$
1,060.00
$
­
0
0
$
0
Perform
bimonthly
inspections
of
sources
of
impressed
current
and
record
the
results
­
­
40.00
­
40.00
$
2,120.00
$
­
0
0
$
0
EXHIBIT
9
(
CONTINUED)

STANDARDIZED
PERMITS
ESTIMATED
ANNUAL
RESPONDENT
BURDEN
AND
COST
SPECIFIC
UNIT
REQUIREMENTS
88
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Leg.

$
102.00/

Hour
Mgr.

$
73.00/

Hour
Tech.

$
53.00/

Hour
Cler.

$
27.00/

Hour
Respon.

Hours/

Year
Labor
Cost/

Year
O
&
M
Cost
Respon.

or
Activities
Total
Hours/

Year
Total
Cost/

Year
Leaks
and
Spills
(
267.200)

Read
the
regulations
­
0.25
0.25
­
0.50
$
31.50
$
­
0
0
$
0
Prepare
and
submit
a
report
to
the
Regional
Administrator
(
within
24
hours
of
leak
detection)
­
­
0.25
­
0.25
$
13.25
$
3.00
0
0
$
0
Prepare
and
submit
a
report
to
the
Regional
Administrator
(
within
30
days
of
leak
detection)
­
1.00
7.50
1.00
9.50
$
497.50
$
3.00
0
0
$
0
Obtain
and
submit
an
engineer's
certification
­
­
­
0.50
0.50
$
13.50
$
3.00
0
0
$
0
CONTAINMENT
BUILDINGS
Additional
Standards
for
Liquid
Storage
(
267.1103(
d))

Read
the
regulations
­
0.25
0.25
­
0.50
$
31.50
$
­
0
0
$
0
Inspect
data
weekly
and
record
the
results
­
­
26.00
­
26.00
$
1,378.00
$
­
0
0
$
0
Waiver
from
Secondary
Containment
Requirements
(
267.1104)

Read
the
regulations
­
0.25
0.25
0.50
­
$
45.00
$
­
0
0
$
0
Prepare
the
free
liquids
demonstration
1.00
1.00
2.00
0.50
4.50
$
294.50
$
1,500.00
0
0
$
0
Containment
Buildings
with
Areas
Both
with
and
without
Secondary
Containment
(
267.1105)

Read
the
regulations
­
0.25
0.25
­
0.50
$
31.50
$
­
0
0
$
0
Prepare
and
maintain
a
written
description
of
operating
procedures
­
­
1.00
0.25
1.25
$
59.75
$
­
0
0
$
0
Releases
of
Hazardous
Waste
(
267.1106)

Read
the
regulations
­
0.25
0.25
­
0.50
$
31.50
$
­
0
0
$
0
Enter
a
record
of
the
discovery
in
the
operating
record
­
­
0.50
­
0.50
$
26.50
$
­
0
0
$
0
Prepare
and
submit
a
notification
to
the
Director
within
7
days
­
­
0.50
­
0.50
$
26.50
$
3.00
0
0
$
0
Prepare
and
submit
a
written
notification
within
14
days
­
­
0.50
0.25
0.75
$
33.25
$
3.00
0
0
$
0
Prepare
and
submit
the
written
verification
to
the
Director
­
0.50
­
0.25
0.75
$
43.25
$
3.00
0
0
$
0
Total
Varies
Varies
Varies
Varies
Varies
Varies
Varies
0
0
$
0
89
EXHIBIT
10
STANDARDIZED
PERMITS
ESTIMATED
ANNUAL
AGENCY
BURDEN
AND
COST
APPLYING
FOR
A
STANDARDIZED
PERMIT
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Leg.

$
60.89/

Hour
Mgr.

$
56.95/

Hour
Tech.

$
41.75/

Hour
Cler.

$
16.77/

Hour
Respon.

Hours/

Year
Labor
Cost/

Year
O
&
M
Cost
Respon.

or
Activities
Total
Hours/

Year
Total
Cost/

Year
Applying
for
a
Standardized
Permit
(
124.204,
270.275,
270.280,
&
270.285)

Review
the
notice
of
intent
and
supporting
information,
and
make
a
determination
20.00
1.00
40.00
­
61.00
$
2,944.75
$
­
175
10,675
$
515,331
Enter
information
into
a
database
­
­
­
0.50
0.50
$
8.39
$
­
175
88
$
1,468
Total
Varies
Varies
Varies
Varies
Varies
Varies
Varies
350
10,763
$
516,799
EXHIBIT
11
STANDARDIZED
PERMITS
ESTIMATED
ANNUAL
AGENCY
BURDEN
AND
COST
MAINTAINING
A
STANDARDIZED
PERMIT
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Leg.

$
60.89/

Hour
Mgr.

$
56.95/

Hour
Tech.

$
41.75/

Hour
Cler.

$
16.77/

Hour
Respon.

Hours/

Year
Labor
Cost/

Year
O
&
M
Cost
Respon.

or
Activities
Total
Hours/

Year
Total
Cost/

Year
Routine
Changes
(
124.212
&
270.320(
a))

Review
the
information
submitted
by
the
permittee
­
0.25
1.00
­
1.25
$
55.99
$
­
18
23
$
1,008
Significant
Changes
(
124.213
&
270.320(
b))

Review
the
modification
request
and
supporting
information
20.00
1.00
40.00
­
61.00
$
2,944.75
$
­
7
427
$
20,613
Review
proof
of
public
notice
­
0.25
1.00
­
1.25
$
55.99
$
­
7
9
$
392
Enter
information
into
a
database
­
­
­
0.50
0.50
$
8.39
$
­
7
4
$
59
Total
Varies
Varies
Varies
Varies
Varies
Varies
Varies
39
463
$
22,072
90
EXHIBIT
12
STANDARDIZED
PERMITS
ESTIMATED
ANNUAL
AGENCY
BURDEN
AND
COST
GENERAL
FACILITY
STANDARDS
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Leg.

$
60.89/

Hour
Mgr.

$
56.95/

Hour
Tech.

$
41.75/

Hour
Cler.

$
16.77/

Hour
Respon.

Hours/

Year
Labor
Cost/

Year
O
&
M
Cost
Respon.

or
Activities
Total
Hours/

Year
Total
Cost/

Year
General
Facility
Standards
(
267.12,
267.14,
&
267.18)

Issue
an
identification
number
(
to
new
facilities)

and
enter
the
facility
into
the
hazardous
waste
facility
data
system
­
0.25
2.00
0.50
2.75
$
106.12
$
­
0
0
$
0
Review
the
security
procedures
and
inspect
the
security
system
during
an
on­
site
inspection
­
­
1.00
­
1.00
$
41.75
$
­
0
0
$
0
Review
the
information
submitted
by
permittees
seeking
a
waiver
from
the
security
requirements
and
make
a
determination
­
0.25
0.50
­
0.75
$
35.11
$
­
0
0
$
0
Review
the
demonstration
of
compliance
with
location
factors
­
­
1.00
­
1.00
$
41.75
$
­
0
0
$
0
Review
information
submitted
by
permittees
seeking
a
waiver
from
the
location
standards
and
make
a
determination
­
0.25
2.00
­
2.25
$
97.74
$
­
0
0
$
0
Total
Varies
Varies
Varies
Varies
Varies
Varies
Varies
0
0
$
0
91
EXHIBIT
13
STANDARDIZED
PERMITS
ESTIMATED
ANNUAL
AGENCY
BURDEN
AND
COST
PREPAREDNESS
AND
PREVENTION
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Leg.

$
60.89/

Hour
Mgr.

$
56.95/

Hour
Tech.

$
41.75/

Hour
Cler.

$
16.77/

Hour
Respon.

Hours/

Year
Labor
Cost/

Year
O
&
M
Cost
Respon.

or
Activities
Total
Hours/

Year
Total
Cost/

Year
Agreements
with
Local
Authorities
(
267.36)

If
necessary,
review
during
inspections
the
documentation
of
any
refusals
of
local
authorities
to
enter
into
emergency
arrangements
­
­
0.25
­
0.25
$
10.44
$
­
0
0
$
0
Total
Varies
Varies
Varies
Varies
Varies
Varies
Varies
0
0
$
0
EXHIBIT
14
STANDARDIZED
PERMITS
ESTIMATED
ANNUAL
AGENCY
BURDEN
AND
COST
CONTINGENCY
PLAN
AND
EMERGENCY
PROCEDURES
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Leg.

$
60.89/

Hour
Mgr.

$
56.95/

Hour
Tech.

$
41.75/

Hour
Cler.

$
16.77/

Hour
Respon.

Hours/

Year
Labor
Cost/

Year
O
&
M
Cost
Respon.

or
Activities
Total
Hours/

Year
Total
Cost/

Year
Contingency
Plan
and
Emergency
Reporting
(
267.51­
54,
267.55,
&
267.58)

Review
the
contingency
plan
during
on­
site
inspections
­
­
0.50
­
0.50
$
20.88
$
­
0
0
$
0
Review
emergency
reports
­
­
1.00
­
1.00
$
41.75
$
­
0
0
$
0
Total
Varies
Varies
Varies
Varies
Varies
Varies
Varies
0
0
$
0
92
EXHIBIT
15
STANDARDIZED
PERMITS
ESTIMATED
ANNUAL
AGENCY
BURDEN
AND
COST
RECORD
KEEPING,
REPORTING,
AND
NOTIFYING
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Leg.

$
60.89/

Hour
Mgr.

$
56.95/

Hour
Tech.

$
41.75/

Hour
Cler.

$
16.77/

Hour
Respon.

Hours/

Year
Labor
Cost/

Year
O
&
M
Cost
Respon.

or
Activities
Total
Hours/

Year
Total
Cost/

Year
Record
keeping
(
267.71)

Review
the
facility
operating
record
during
onsite
inspections
­
­
2.00
­
2.00
$
83.50
$
­
0
0
$
0
Total
Varies
Varies
Varies
Varies
Varies
Varies
Varies
0
0
$
0
EXHIBIT
16
STANDARDIZED
PERMITS
ESTIMATED
ANNUAL
AGENCY
BURDEN
AND
COST
CLOSURE
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Leg.

$
60.89/

Hour
Mgr.

$
56.95/

Hour
Tech.

$
41.75/

Hour
Cler.

$
16.77/

Hour
Respon.

Hours/

Year
Labor
Cost/

Year
O
&
M
Cost
Respon.

or
Activities
Total
Hours/

Year
Total
Cost/

Year
Closure
(
267.112)

Review
all
closure
plans,
closure
plan
amendment
notifications,
partial/
final
closure
notifications,
and
closure
certifications
­
­
15.00
­
15.00
$
626.25
$
­
0
0
$
0
Review
the
closure
plan
amendment
notifications
­
­
2.00
­
2.00
$
83.50
$
­
0
0
$
0
Review
the
partial/
final
closure
notifications
­
­
2.00
­
2.00
$
83.50
$
­
0
0
$
0
Review
the
closure
certifications
­
­
4.00
­
4.00
$
167.00
$
­
0
0
$
0
Total
Varies
Varies
Varies
Varies
Varies
Varies
Varies
0
0
$
0
93
EXHIBIT
17
STANDARDIZED
PERMITS
ESTIMATED
ANNUAL
AGENCY
BURDEN
AND
COST
FINANCIAL
REQUIREMENTS
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Leg.

$
60.89/

Hour
Mgr.

$
56.95/

Hour
Tech.

$
41.75/

Hour
Cler.

$
16.77/

Hour
Respon.

Hours/

Year
Labor
Cost/

Year
O
&
M
Cost
Respon.

or
Activities
Total
Hours/

Year
Total
Cost/

Year
Financial
Requirements
(
267.142,
267.143,
267.147,
267.148,
&
267.150)

Review
closure
cost
estimates,
demonstrations
of
financial
assurance
for
closure,
and
demonstrations
of
financial
assurance
for
liability
4.00
1.00
16.00
­
21.00
$
968.51
$
­
0
0
$
0
Enter
the
information
into
the
RCRIS
database
­
­
­
0.25
0.25
$
4.19
$
­
0
0
$
0
Total
Varies
Varies
Varies
Varies
Varies
Varies
Varies
0
0
$
0
94
EXHIBIT
18
STANDARDIZED
PERMITS
ESTIMATED
ANNUAL
AGENCY
BURDEN
AND
COST
SPECIFIC
UNIT
REQUIREMENTS
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Leg.

$
60.89/

Hour
Mgr.

$
56.95/

Hour
Tech.

$
41.75/

Hour
Cler.

$
16.77/

Hour
Respon.

Hours/

Year
Labor
Cost/

Year
O
&
M
Cost
Respon.

or
Activities
Total
Hours/

Year
Total
Cost/

Year
Use
and
Management
of
Containers
(
267.15
&
267.172)

Review
inspection
records,
if
necessary,
during
on­
site
inspections
­
­
1.00
­
1.00
$
41.75
$
­
0
0
$
0
Tank
Systems
(
267.200)

Review
notifications
and
detailed
reports
on
releases
to
the
environment
­
­
4.00
­
4.00
$
167.00
$
­
0
0
$
0
Review
inspection
records,
if
necessary,
during
on­
site
inspections
­
­
1.00
­
1.00
$
41.75
$
­
0
0
$
0
Containment
Buildings
(
267.1104
&
267.1106)

Review
notifications
on
any
releases
to
the
environment
­
­
0.25
­
0.25
$
10.44
$
­
0
0
$
0
Review
documentation
submitted
to
support
requests
for
secondary
containment
requirement
waivers
­
0.25
1.00
0.25
1.50
$
60.18
$
­
0
0
$
0
Review
inspection
records,
if
necessary,
during
on­
site
inspections
­
­
1.00
­
1.00
$
41.75
$
­
0
0
$
0
Total
Varies
Varies
Varies
Varies
Varies
Varies
Varies
0
0
$
0
95
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Cost
Respondent
Universe
Table
1
presents
the
estimated
universe
of
captive
treatment,
storage,
and
disposal
facilities
(
TSDFs)
that
currently
store
or
non­
thermally
treat
hazardous
waste
in
containers,
tanks,
and/
or
containment
buildings.

Table
1
Captive
Facilities
that
Treat
and/
or
Store
Hazardous
Waste
in
Containers,
Tanks,
and
Containment
Buildingsa
Type
of
facility
Number
facilities
Permitted
facilities
Interim
status
Facilities
with
storage
and/
or
non­
thermal
treatment
units
only
Containers
611
418
194
Tanks
431
273
158
Containment
buildings
9
4
5
All
storage
and/
or
treatment
facilitiesb
641
444
197
Facilities
with
storage,
non­
thermal
treatment,
and
other
type
of
units
Containers
188
105
83
Tanks
191
106
86
Containment
buildings
13
2
11
All
storage
and/
or
treatment
facilitiesb
224
140
84
Total
Containers
800
523
277
Tanks
623
379
244
Containment
buildings
22
6
16
All
storage
and/
or
treatment
facilitiesb
866
584
281
a
Estimates
are
from
the
Permitting
Program
Accomplishments
Report
(
PAR)
for
the
period
October
1,
1980
to
October
4,
1999.
Estimated
numbers
of
facilities
presented
in
this
table
do
not
include
federally
owned
and
operated
facilities.
b
Note
that
certain
facilities
own
or
operate
more
than
one
type
of
unit
(
e.
g.,
containers
and
tanks).
Therefore,
the
number
of
facilities
with
containers,
tanks,
and
containment
buildings
in
the
table
are
not
additive.

As
shown
in
the
table,
the
total
number
of
captive
TSDFs
with
storage
and/
or
non­
thermal
treatment
units
is
866
(
584
permitted
and
281
interim
status).
Of
these
866
TSDFs,
641
(
444
permitted
and
197
interim
status)
facilities
have
storage
and/
or
non­
thermal
treatment
units
only
and
224
(
140
permitted
and
84
interim
status)
facilities
have
storage,
non­
thermal
treatment,
and
other
type
of
units.

Of
the
641
captive
TSDFs
that
have
storage
and/
or
non­
thermal
treatment
units
only,
611
facilities
have
at
least
one
container,
431
facilities
have
at
least
one
tank,
and
9
facilities
have
at
least
one
containment
building.
Of
the
224
captive
TSDFs
that
have
storage,
non­
thermal
treatment,
and
other
type
of
units,
188
facilities
have
at
least
one
container,
191
facilities
have
at
least
one
tank,
and
13
facilities
have
at
least
one
containment
building.
In
order
to
determine
the
96
5
Based
on
analysis
of
permitting
data
from
the
Permitting
Program
Accomplishments
Report
(
PAR)
for
the
period
October
1,
1980
to
October
4,
1999
and
EPA's
best
professional
judgement.

6
Ibid.

7
Ibid.

8
Ibid.

9
Ibid.

10
Ibid.
number
of
captive
TSDFs
that
would
apply
for
a
standardized
permit
within
the
three­
year
period
of
this
ICR,
EPA
made
the
following
assumptions:

Operating,
fully
permitted
facilities

For
facilities
with
storage
and
non­
thermal
treatment
units
only,
the
annual
number
of
permit
renewals
are
expected
to
be
approximately
12.
All
of
these
facilities
are
expected
to
apply
for
a
standardized
permit.
5

Of
the
facilities
with
storage
and/
or
non­
thermal
treatment
units
only
that
are
not
up
for
permit
renewal,
50
percent
are
expected
to
apply
for
a
standardized
permit
(
68
facilities
per
year).
6

For
facilities
with
storage,
non­
thermal
treatment,
and
other
type
of
units,
the
annual
number
of
permit
renewals
is
expected
to
be
2.
All
of
these
facilities
are
expected
to
apply
for
a
standardized
permit.
7

For
facilities
that
have
storage,
non­
thermal
treatment,
and
other
type
of
units
that
are
not
up
for
permit
renewal,
25
percent
are
expected
to
apply
for
a
standardized
permit
(
11
facilities
per
year).
8
Operating,
interim­
status
facilities

All
facilities
with
storage
and
non­
thermal
treatment
units
only
are
expected
to
apply
for
a
standardized
permit
(
66
facilities
per
year).
9

50
percent
of
the
facilities
that
have
storage,
non­
thermal
treatment,
and
other
type
of
units
are
expected
to
apply
for
a
standardized
permit
(
14
facilities
per
year).
10
97
11
EPA's
best
professional
judgement.
New
facilities

2
new
facilities
per
year
are
expected
to
apply
for
a
standardized
permit
each
year.
11
The
universe
data
for
facilities
expected
to
apply
for
a
standardized
permit
are
summarized
in
Table
2.

Table
2
Captive
Treatment
and/
or
Storage
Facilities
Expected
to
Apply
for
a
Standardized
Permit
Annuallya
Type
of
facility
Permitted
facilities
Interim
status
facilities
New
facilitiesb
Total
Permit
renewals
Permitted
facilities
switching
to
a
standardized
permit
prior
to
permit
renewal
Facilities
with
storage
and/
or
non­
thermal
treatment
units
only
Containers
11
64
65
 
140
Tanks
7
42
53
 
102
Containment
buildings
0
1
2
 
3
All
storage
and/
or
treatment
facilitiesc
12
68
66
 
146
Facilities
with
storage,
non­
thermal
treatment,
and
other
type
of
units
Containers
1
9
14
 
24
Tanks
1
9
14
 
24
Containment
buildings
0
0
2
 
2
All
storage
and/
or
treatment
facilitiesc
2
11
14
 
27
Total
Containers
12
73
79
2
166
Tanks
8
51
67
1
127
Containment
buildings
0
1
4
0
5
All
storage
and/
or
treatment
facilitiesc
14
79
80
2
175
a
Estimates
are
from
the
Permitting
Program
Accomplishments
Report
(
PAR)
for
the
period
October
1,
1980
to
October
4,
1999.
Estimated
numbers
of
facilities
presented
in
this
table
do
not
include
federally
owned
and
operated
facilities.
b
EPA
is
uncertain
whether
new
facilities
will
own
storage
and
treatment
only
or
storage,
non­
thermal
treatment,
and
other
type
of
units.
However,
this
issue
has
no
bearing
on
this
ICR.
c
Note
that
certain
facilities
own
or
operate
more
than
one
type
of
unit
(
e.
g.,
containers
and
tanks).
Therefore,
the
number
of
facilities
with
containers,
tanks,
and
containment
buildings
in
the
table
are
not
additive.
98
12
The
5­
percent
estimate
is
based
on
EPA's
experience
under
the
RCRA
program.
Respondent
Burden
and
Costs
under
the
Proposed
Rule
Based
on
the
universe
data
presented
in
Table
2,
EPA
estimated
respondent
burden
and
costs
associated
with
all
of
the
requirements
covered
in
this
ICR
in
Exhibits
1
through
9.
A
discussion
of
the
burden
estimates
presented
in
these
exhibits
follows.

APPLYING
FOR
A
STANDARDIZED
PERMIT
(
1)
General
Information
Requirements
EPA
estimates
that
a
total
of
175
(
permitted,
interim
status,
and
new)
captive
TSDFs
per
year
will
apply
for
a
standardized
permit
(
see
Table
2).
All
of
these
facilities
are
expected
to
read
the
regulations
and
submit
a
written
notice
of
intent
to
operate
under
a
standardized
permit,
a
public
meeting
summary,
and
a
certification
of
compliance
with
part
267.

For
permitted
facilities,
EPA
estimates
that
93
facilities
per
year
(
i.
e.,
14
permit
renewals
and
79
permitted
facilities
switching
to
a
standardized
permit
prior
to
permit
renewal)
will
apply
for
the
standardized
permit
within
the
three­
year
period
of
this
ICR.
EPA
assumes
that
all
of
these
facilities
already
have
collected
most
of
the
required
information
as
part
of
their
previous
permitting
process
(
e.
g.,
Part
A
information,
documentation
of
compliance
with
location
standards,
waste
management
unit
information).
Permitted
facilities
will
only
need
to
collect
those
data
items
not
already
required
at
part
264
or
270,
e.
g.,
notice
of
intent
to
operate
under
a
standardized
permit.

EPA
assumes
that
interim
status
and
new
facilities
(
i.
e.,
a
total
of
82
facilities
per
year)
will
have
to
prepare
and
maintain
all
general
information,
with
two
exceptions.
One
exception
pertains
to
submitting
the
Part
A
application.
EPA
assumes
that
only
new
facilities
will
incur
burden
for
this
activity,
since
interim
status
facilities
should
already
have
submitted
this
information
to
EPA.

The
other
exception
pertains
to
compliance
schedules.
EPA
assumes
that,
of
the
93
permitted
facilities
and
the
80
interim
status
facilities,
5
percent
of
the
facilities
(
i.
e.,
a
total
of
9
facilities)
will
not
be
in
compliance
with
general
information
requirements
of
part
264
or
265.12
These
facilities
would
have
to
prepare
and
submit
a
schedule
of
compliance
with
part
267
as
part
of
their
standardized
permit
application.

(
2)
Record
Keeping
Requirements
With
few
exceptions,
EPA
assumes
that
only
interim­
status
and
new
facilities
(
i.
e.,
a
total
of
82
facilities
per
year)
will
have
to
incur
burden
for
record
keeping
information.
The
exceptions
pertain
to
the
record
keeping
of
particular
data
items.
Specifically,
EPA
assumes
that
only
new
facilities
will
incur
burden
for
preparing
a
general
description
of
the
facility
and
obtaining
a
99
13
Ibid.

14
The
10­
percent
estimate
is
based
on
EPA's
experience
under
the
RCRA
program.
topographic
map
(
i.
e.,
2
facilities).
EPA
also
assumes
that,
of
the
93
permitted
facilities
and
the
80
interim
status
facilities,
5
percent
will
have
to
prepare
a
justification
for
modifications
of
the
preparedness
and
prevention
requirements
(
i.
e.,
a
total
of
9
facilities).
13
(
3)
Container
Information
Requirements
EPA
assumes
permitted
facilities
will
not
incur
burden
in
compiling
information
on
their
containers.
EPA
also
assumes
that
interim
status
and
new
facilities
will
need
to
collect
information
on
containers,
under
section
270.300.
EPA
estimates
that
the
affected
universe
will
include
approximately
81
facilities
with
containers
(
i.
e.,
79
interim
status
facilities
and
2
new
facilities).

(
4)
Tank
Information
Requirements
EPA
assumes
permitted
facilities
will
not
incur
burden
in
compiling
information
on
their
tanks.
EPA
also
assumes
that
interim
status
and
new
facilities
will
need
to
collect
information
on
tanks,
under
section
270.305.
EPA
estimates
that
the
affected
universe
will
include
approximately
68
facilities
with
tanks
(
i.
e.,
67
interim
status
facilities
and
1
new
facility).
In
addition,
EPA
estimates
that
10
percent
of
the
permitted
and
interim
status
facilities
and
one
new
facility
owning
tank
systems
(
i.
e.,
0.10
x
[
59
permitted
facilities
+
67
interim
status
facilities]
+
1
new
facility
=
14
facilities
in
total)
will
need
to
prepare
a
detailed
description
of
how
new
tank
systems
will
be
installed
in
compliance
with
section
267.194.14
(
5)
Equipment
Information
Requirements
EPA
assumes
permitted
and
interim
status
facilities
will
not
incur
burden
in
compiling
information
on
their
equipment.
All
permitted
and
interim
status
facilities
are
already
required
to
have
this
information
under
40
CFR
part
270.
However,
EPA
assumes
that
the
one
new
facility
owning
tank
systems
will
be
subject
to
the
equipment
standards.

(
6)
Air
Emissions
Control
Requirements
EPA
assumes
permitted
and
interim
status
facilities
will
not
incur
burden
in
compiling
information
on
their
air
emission
controls.
All
permitted
and
interim
status
facilities
are
already
required
to
have
this
information
under
40
CFR
part
270.
However,
EPA
assumes
that
the
two
new
facilities
will
be
subject
to
the
air
emission
control
standards.
100
15
EPA
is
unsure
of
the
percent
of
facilities
that
will
seek
a
standardized
permit
modification.
EPA
referred
to
the
Supporting
Statement
for
EPA
Information
Collection
Request
Number
1573.05,
"
Part
B
Permit
Application,
Permit
Modifications,
and
Special
Permits"
to
identify
the
percent
of
facilities
seeking
Class
I,
II,
and
III
permit
modifications.
EPA
used
these
percentages
as
a
surrogate
for
estimating
the
percent
of
facilities
expected
to
make
routine
and
significant
changes
to
a
standardized
permit.
(
7)
Switching
from
an
Individual
RCRA
Permit
to
a
Standardized
Permit
For
permitted
facilities
switching
to
a
standardized
permit
prior
to
permit
renewal
(
i.
e.,
79
facilities),
EPA
has
added
the
burden
of
reading
the
regulations
and
preparing
and
submitting
a
request
to
the
permitting
agency.

(
8)
Reapplying
for
a
Standardized
Permit
For
the
purposes
of
this
ICR,
EPA
assumes
that
no
facilities
will
be
reapplying
for
a
standardized
permit
during
the
three­
year
period
of
this
ICR.

MAINTAINING
A
STANDARDIZED
PERMIT
EPA
estimates
that
approximately
10
percent
of
the
captive
TSDFs
(
i.
e.,
0.10
x
175
facilities
=
18
facilities)
operating
under
a
standardized
permit
will
have
to
make
routine
changes
to
their
permits
each
year.
Approximately
4
percent
of
the
captive
TSDFs
(
i.
e.,
0.04
x
175
facilities
=
7
facilities)
operating
under
a
standardized
permit
are
expected
to
make
significant
changes
to
their
permits
each
year.
15
GENERAL
FACILITY
STANDARDS
Information
collection
requirements
pertaining
to
general
facility
standards
are
already
covered
in
the
Supporting
Statement
for
EPA
Information
Collection
Request
Number
1571.06,"
General
Hazardous
Waste
Facility
Standards"
and
the
Supporting
Statement
for
EPA
Information
Collection
Request
Number
1573.05,
"
Part
B
Permit
Application,
Permit
Modifications,
and
Special
Permits."
Thus,
EPA
has
chosen
not
to
burden
captive
TSDFs
applying
for
and
obtaining
a
standardized
permit
with
these
requirements
in
this
ICR,
i.
e.,
the
number
of
respondents
or
activities
is
equal
to
zero.
(
Note
that
the
two
new
facilities
expected
to
apply
for
and
obtain
a
standardized
permit
are
covered
in
the
above
mentioned
ICRs.)

PREPAREDNESS
AND
PREVENTION
Information
collection
requirements
pertaining
to
preparedness
and
prevention
are
already
covered
in
the
Supporting
Statement
for
EPA
Information
Collection
Request
#
1571.06,
"
General
Hazardous
Waste
Facility
Standards."
Thus,
EPA
has
chosen
not
to
burden
captive
TSDFs
applying
for
and
obtaining
a
standardized
permit
with
these
requirements
in
this
ICR,
i.
e.,
101
the
number
of
respondents
or
activities
is
equal
to
zero.
(
Note
that
the
two
new
facilities
expected
to
apply
for
and
obtain
a
standardized
permit
are
covered
in
the
above
mentioned
ICR.)

CONTINGENCY
PLAN
AND
EMERGENCY
PROCEDURES
Information
collection
requirements
pertaining
to
the
contingency
plan
and
emergency
procedures
are
already
covered
in
the
Supporting
Statement
for
EPA
Information
Collection
Request
Number
1571.06,"
General
Hazardous
Waste
Facility
Standards"
and
the
Supporting
Statement
for
EPA
Information
Collection
Request
Number
1573.05,
"
Part
B
Permit
Application,
Permit
Modifications,
and
Special
Permits."
Thus,
EPA
has
chosen
not
to
burden
captive
TSDFs
applying
for
and
obtaining
a
standardized
permit
with
these
requirements
in
this
ICR,
i.
e.,
the
number
of
respondents
or
activities
is
equal
to
zero.
(
Note
that
the
two
new
facilities
expected
to
apply
for
and
obtain
a
standardized
permit
are
covered
in
the
above
mentioned
ICRs.)

RECORD
KEEPING,
REPORTING,
AND
NOTIFYING
Information
collection
requirements
pertaining
to
record
keeping
and
reporting
are
already
covered
in
the
Supporting
Statement
for
EPA
Information
Collection
Request
Number
1571.06,"
General
Hazardous
Waste
Facility
Standards."
Thus,
EPA
has
chosen
not
to
burden
captive
TSDFs
applying
for
and
obtaining
a
standardized
permit
with
these
requirements
in
this
ICR,
i.
e.,
the
number
of
respondents
or
activities
is
equal
to
zero.
(
Note
that
the
two
new
facilities
expected
to
apply
for
and
obtain
a
standardized
permit
are
covered
in
the
above
mentioned
ICR.)

CLOSURE
Information
collection
requirements
pertaining
to
closure
are
already
covered
in
the
Supporting
Statement
for
EPA
Information
Collection
Request
Number
1571.06,"
General
Hazardous
Waste
Facility
Standards"
and
the
Supporting
Statement
for
EPA
Information
Collection
Request
Number
1573.05,
"
Part
B
Permit
Application,
Permit
Modifications,
and
Special
Permits."
Thus,
EPA
has
chosen
not
to
burden
captive
TSDFs
applying
for
and
obtaining
a
standardized
permit
with
these
requirements
in
this
ICR,
i.
e.,
the
number
of
respondents
or
activities
is
equal
to
zero.
(
Note
that
the
two
new
facilities
expected
to
apply
for
and
obtain
a
standardized
permit
are
covered
in
the
above
mentioned
ICRs.)

FINANCIAL
REQUIREMENTS
Information
collection
requirements
pertaining
to
financial
assurance
are
already
covered
in
the
Supporting
Statement
for
EPA
Information
Collection
Request
Number
1571.06,"
General
Hazardous
Waste
Facility
Standards"
and
the
Supporting
Statement
for
EPA
Information
Collection
Request
Number
1573.05,
"
Part
B
Permit
Application,
Permit
Modifications,
and
Special
Permits."
Thus,
EPA
has
chosen
not
to
burden
captive
TSDFs
applying
for
and
obtaining
a
standardized
permit
with
these
requirements
in
this
ICR,
i.
e.,
the
number
of
respondents
or
102
activities
is
equal
to
zero.
(
Note
that
the
two
new
facilities
expected
to
apply
for
and
obtain
a
standardized
permit
are
covered
in
the
above
mentioned
ICRs.)
103
USE
AND
MANAGEMENT
OF
CONTAINERS
Information
collection
requirements
pertaining
to
the
use
and
management
of
containers
are
already
covered
in
the
Supporting
Statement
for
EPA
Information
Collection
Request
Number
1573.05,
"
Part
B
Permit
Application,
Permit
Modifications,
and
Special
Permits,"
the
Supporting
Statement
for
EPA
Information
Collection
Request
Number
1572.04,"
Hazardous
Waste
Specific
Unit
Requirements,
and
Special
Waste
Processes
and
Types,"
and
the
Supporting
Statement
Environmental
Protection
Agency
Information
Collection
Request
Number
1593.04
"
Standards
of
Performance
for
Air
Emission
Standards
for
Tanks,
Surface
Impoundments
and
Containers,
40
CFR
Part
264,
Subpart
CC
and
40
CFR
Part
265,
Subpart
CC."
Thus,
EPA
has
chosen
not
to
burden
captive
TSDFs
applying
for
and
obtaining
a
standardized
permit
with
these
requirements
in
this
ICR,
i.
e.,
the
number
of
respondents
or
activities
is
equal
to
zero.
(
Note
that
the
two
new
facilities
expected
to
apply
for
and
obtain
a
standardized
permit
are
covered
in
the
above
mentioned
ICRs.)

TANK
SYSTEMS
Information
collection
requirements
pertaining
to
tank
systems
are
already
covered
in
the
Supporting
Statement
for
EPA
Information
Collection
Request
Number
1573.05,
"
Part
B
Permit
Application,
Permit
Modifications,
and
Special
Permits,"
the
Supporting
Statement
for
EPA
Information
Collection
Request
Number
1572.04,"
Hazardous
Waste
Specific
Unit
Requirements,
and
Special
Waste
Processes
and
Types,"
and
the
Supporting
Statement
Environmental
Protection
Agency
Information
Collection
Request
Number
1593.04
"
Standards
of
Performance
for
Air
Emission
Standards
for
Tanks,
Surface
Impoundments
and
Containers,
40
CFR
Part
264,
Subpart
CC
and
40
CFR
Part
265,
Subpart
CC."
Thus,
EPA
has
chosen
not
to
burden
captive
TSDFs
applying
for
and
obtaining
a
standardized
permit
with
these
requirements
in
this
ICR,
i.
e.,
the
number
of
respondents
or
activities
is
equal
to
zero.
(
Note
that
the
two
new
facilities
expected
to
apply
for
and
obtain
a
standardized
permit
are
covered
in
the
above
mentioned
ICRs.)

CONTAINMENT
BUILDINGS
Information
collection
requirements
pertaining
to
containment
buildings
are
already
covered
in
the
Supporting
Statement
for
EPA
Information
Collection
Request
Number
1572.04,"
Hazardous
Waste
Specific
Unit
Requirements,
and
Special
Waste
Processes
and
Types."
Thus,
EPA
has
chosen
not
to
burden
captive
TSDFs
applying
for
and
obtaining
a
standardized
permit
with
these
requirements
in
this
ICR,
i.
e.,
the
number
of
respondents
or
activities
is
equal
to
zero.
(
Note
that
the
two
new
facilities
expected
to
apply
for
and
obtain
a
standardized
permit
are
covered
in
the
above
mentioned
ICR.)

Existing
Paperwork
Requirements
The
proposed
rule
would
relieve
facilities
applying
for
and
operating
under
a
standardized
permit
of
several
existing
RCRA
paperwork
requirements.
Specifically,
the
proposed
rule
would
104
relieve
facilities
from
reporting
and
record
keeping
requirements
already
covered
in
the
following
ICRs:


Supporting
Statement
for
EPA
Information
Collection
Request
Number
1571.06,"
General
Hazardous
Waste
Facility
Standards;"


Supporting
Statement
for
EPA
Information
Collection
Request
Number
1573.05,
"
Part
B
Permit
Application,
Permit
Modifications,
and
Special
Permits;"


Supporting
Statement
for
EPA
Information
Collection
Request
Number
1572.04,"
Hazardous
Waste
Specific
Unit
Requirements,
and
Special
Waste
Processes
and
Types;"
and

Supporting
Statement
Environmental
Protection
Agency
Information
Collection
Request
Number
1593.04
"
Standards
of
Performance
for
Air
Emission
Standards
for
Tanks,
Surface
Impoundments
and
Containers,
40
CFR
Part
264,
Subpart
CC
and
40
CFR
Part
265,
Subpart
CC."

In
developing
this
ICR,
EPA
decided
against
calculating
the
burden
relief
that
would
be
afforded
to
respondents
under
the
proposal.
EPA
normally
calculates
the
burden
relief
under
a
rulemaking
by
identifying
all
existing
ICRs
affected
by
the
rule
and
quantifying
the
burden
savings
associated
with
each
ICR's
paperwork
requirements.
For
the
standardized
permit
proposal,
however,
EPA
notes
that
some
of
the
affected
ICRs
are
currently
being
updated
and
renewed.
Thus,
their
burden
and
cost
estimates
are
not
final
or
available
for
analysis
in
this
ICR.
EPA
intends
to
calculate
the
proposal's
burden
savings
when
the
rule
is
finalized.

6(
e)
Bottom
Line
Burden
Hours
and
Costs
Respondent
Tally
Exhibit
19
summarizes
the
total
annual
respondent
burden
and
cost
associated
with
all
the
requirements
covered
in
this
ICR.
As
shown
in
the
exhibit,
EPA
estimates
that
the
annual
respondent
burden
to
be
approximately
13,367
hours,
at
an
annual
cost
of
$
1,307,512.
The
bottom
line
burden
to
respondents
over
three
years
is
40,101
hours,
with
a
cost
of
$
3,922,536.

Agency
Tally
Exhibit
20
summarizes
the
estimated
Agency
burden
associated
with
all
activities
covered
in
this
ICR.
As
shown
in
the
exhibit,
EPA
estimates
that
the
annual
agency
burden
is
approximately
11,226
hours,
at
an
annual
cost
of
$
538,871.
The
bottom
line
burden
to
the
Agency
over
three
years
is
33,678
hours,
at
a
cost
of
$
1,616,613.
105
EXHIBIT
19
STANDARDIZED
PERMITS
TOTAL
ESTIMATED
ANNUAL
RESPONDENT
BURDEN
AND
COST
SUMMARY
Exhibit
Title
Annual
Burden
Annual
Labor
Cost
Annual
Capital/

Startup
Cost
Annual
O&
M
Cost
Total
Annual
Cost
Exhibit
1
Applying
for
a
Standardized
Permit
12,229
$
655,088
$
156
$
531,002
$
1,186,246
Exhibit
2
Maintaining
a
Standardized
Permit
1,138
$
65,137
$
0
$
56,129
$
121,266
Exhibit
3
General
Facility
Standards
0
$
0
$
0
$
0
$
0
Exhibit
4
Preparedness
and
Prevention
0
$
0
$
0
$
0
$
0
Exhibit
5
Contingency
Plan
and
Emergency
Procedures
0
$
0
$
0
$
0
$
0
Exhibit
6
Record
Keeping,
Reporting,
and
Notifying
0
$
0
$
0
$
0
$
0
Exhibit
7
Closure
0
$
0
$
0
$
0
$
0
Exhibit
8
Financial
Requirements
0
$
0
$
0
$
0
$
0
Exhibit
9
Specific
Unit
Requirements
0
$
0
$
0
$
0
$
0
Annual
Total
13,367
$
720,225
$
156
$
587,131
$
1,307,512
3­
Year
Total
40,101
$
2,160,675
$
468
$
1,761,393
$
3,922,536
EXHIBIT
20
STANDARDIZED
PERMITS
TOTAL
ESTIMATED
ANNUAL
AGENCY
BURDEN
AND
COST
SUMMARY
Exhibit
Title
Annual
Burden
Annual
Labor
Cost
Annual
Capital/

Startup
Cost
Annual
O&
M
Cost
Total
Annual
Cost
Exhibit
10
Applying
for
a
Standardized
Permit
10,763
$
516,799
$
0
$
0
$
516,799
Exhibit
11
Maintaining
a
Standardized
Permit
463
$
22,072
$
0
$
0
$
22,072
Exhibit
12
General
Facility
Standards
0
$
0
$
0
$
0
$
0
Exhibit
13
Preparedness
and
Prevention
0
$
0
$
0
$
0
$
0
Exhibit
14
Contingency
Plan
and
Emergency
Procedures
0
$
0
$
0
$
0
$
0
Exhibit
15
Record
Keeping,
Reporting,
and
Notifying
0
$
0
$
0
$
0
$
0
Exhibit
16
Closure
0
$
0
$
0
$
0
$
0
Exhibit
17
Financial
Requirements
0
$
0
$
0
$
0
$
0
Exhibit
18
Specific
Unit
Requirements
0
$
0
$
0
$
0
$
0
Annual
Total
11,226
$
538,871
$
0
$
0
$
538,871
3­
Year
Total
33,678
$
1,616,613
$
0
$
0
$
1,616,613
106
6(
f)
Reasons
for
Change
In
Burden
In
proposing
the
standardized
permit
for
facilities
that
generate
waste
and
routinely
manage
the
waste
on­
site
in
tanks,
containers,
and
containment
buildings,
EPA
is
attempting
to
streamline
the
administrative
permitting
process
and
dramatically
shorten
the
time
required
to
obtain
a
RCRA
permit,
without
lessening
the
environmental
protection
provided
by
the
permit.
The
new
permit
system
should
also
reduce
the
amount
of
time
and
administrative
resources
required
to
maintain
a
RCRA
permit
throughout
the
operating
life
of
the
facility
by
providing
streamlined
permit
modification
and
renewal
processes
for
the
standardized
permit.
These
new
paperwork
requirements
reflect
a
program
change
and
are
triggered
only
if
a
facility
owner
or
operator
seeks
the
standardized
permit.

6(
g)
Burden
Statement
The
annual
reporting
burden
for
the
new
information
collection
requirements
in
this
ICR
is
estimated
to
range
from
53
to
57
hours
per
respondent.
This
burden
includes
time
for
facility
owners
and
operators
to
submit
to
the
permitting
agency
a
notice
of
intent
and
supporting
materials
for
a
standardized
permit
application,
if
required,
and
permit
modification
requests
for
significant
changes.

The
annual
record
keeping
burden
for
the
new
information
collection
requirements
in
this
ICR
is
estimated
to
range
from
31
to
178
hours
per
respondent.
This
includes
time
for
reading
the
regulations
and
keeping
records
under
section
270.290
and,
if
required,
under
sections
270.300
to
270.315
for
containers,
tanks,
equipment,
and
air
emission
controls.

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

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Director,
Collection
Strategies
Division,
U.
S.
Environmental
Protection
Agency
(
2822),
1200
Pennsylvania
Ave.,
NW,
Washington,
D.
C.
20460;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
and
OMB
control
number
in
any
correspondence.
