1
Supporting
Statement
For
Information
Collection
Request
(
ICR)
801.15
Requirements
for
Generators,
Transporters,
&
Waste
Management
Facilities
Under
the
RCRA
Hazardous
Waste
Manifest
System
30
December
2004
Prepared
by:
ICF
Consulting
Inc.
and
Mark
Eads,
Economist
USEPA
Office
of
Solid
Waste
USEPA­
OSWER
ICR
801.15
30
Dec
2004
2
TABLE
OF
CONTENTS
PREFACE
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3
1.
BURDEN
SUMMARY
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4
1A
Disaggregate
Burden
Hour
&
Cost
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4
1B
National
Aggregate
Burden
Hour
&
Cost
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4
2.
NEED,
AUTHORITY
&
USE
FOR
THE
INFORMATION
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5
2A
Need
&
Authority
to
Collect
Information
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5
2B
Practical
Utility
&
Users
of
the
Information
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5
3.
NONDUPLICATION,
CONSULTATIONS
&
OTHER
COLLECTION
CRITERIA
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7
3A
Nonduplication
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7
3B
Public
Notice
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7
3C
Consultations
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7
3D
Effects
of
Less
Frequent
Collection
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8
3E
Confidentiality
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9
3F
Sensitive
Questions
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9
4.
UNIVERSE
OF
AFFECTED
RESPONDENTS
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7
4A
Economic
Sectors
&
Industries
Affected
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10
4B
Types
&
Counts
of
Entities
Affected
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10
4C
Number
of
Annual
RCRA
Manifests
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12
5.
ELEMENTS
OF
INFORMATION
REQUESTED
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14
5A
Manifest
Printer
Registrant
Requirements
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14
5B
Generator
Requirements
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17
5C
Transporter
Requirements
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21
5D
Designated
TSDF
Requirements
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25
6.
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY
&
INFORMATION
MANAGEMENT
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29
6A
Agency
Activities
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29
6B
Collection
Methodology
&
Management
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29
6C
Small
Entity
Flexibility
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29
6D
Collection
Schedule
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30
7.
ESTIMATE
OF
BURDEN
HOURS
&
COST
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31
7A
Labor
Wage
Rates
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31
7B
Respondent
Capital
Costs
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31
7C
Respondent
O&
M
Costs
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32
7D
Itemized
Estimates
of
National
Burden
Hours
&
Costs
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32
BURDEN
ESTIMATION
SPREADSHEETS
(
Exhibits
1
to
20)
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37
REVISED
RCRA
MANIFEST
FORM
(
EPA
Form
8700­
22
&
8700­
22A
Continuation
Sheet)
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58
USEPA­
OSWER
ICR
801.15
30
Dec
2004
3
PREFACE
ICF
Consulting
Inc.
(
Fairfax,
Virginia)
prepared
an
initial
09
April
2004
draft
of
this
document
(
91
pages,
Bryan
Groce,
USEPA­
OSW­
HWID
worktask
manager),
based
on
the
ICR
content
outline
provided
in
USEPA's
"
ICR
Handbook"
("
EPA's
Guide
to
Writing
Information
Collection
Requests
Under
the
Paperwork
Reduction
Act
of
1995",
revised
Feb
1999
&
June
2001,
145
pages,
http://
www.
epa.
gov/
wed/
pages/
opportunities/
icrhndbk.
pdf).
This
ICR
adheres
to
the
guidelines
stated
in
the
Paperwork
Reduction
Act
of
1995,
OMB's
implementing
regulations,
and
USEPA's
ICR
Handbook.
To
reduce
excess
reader
burden
from
redundant
text
content
created
by
adherence
to
the
USEPA
ICR
Handbook's
outline,
Mark
Eads,
OSW
Economist,
eliminated
redundant
sections
and
subsections
of
text
from
the
April
2004
draft
document,
by
revising
the
format
in
deviation
from
the
ICR
Handbook
outline.
Deviation
in
the
format
of
ICRs
is
anticipated
by
USEPA's
ICR
Handbook:

"
This
handbook
is
intended
to
serve
as
a
comprehensive
document,
offering
guidance
on
completing
ICRs
for
the
entire
spectrum
of
Agency
collection
activities.
Therefore,
as
you
use
it,
bear
in
mind
that
it
may
go
into
more
detail
in
certain
areas
than
you
need
or
find
helpful...
Never
let
the
handbook
become
an
obstacle
to
preparing
your
ICR."
(
pages
I­
1
&
I­
2,
PDF
file
pages
6
&
7
of
145)

The
format
revisions
involved:
°
Eliminating
subsection
1(
a)
"
Title
&
Number
of
the
Information
Collection"
which
was
a
duplicative
restatement
of
the
ICR
title
and
ICR
number
already
provided
on
the
title
page
to
this
document.
°
Eliminating
duplicative
text
in
subsection
1(
b)
"
Short
Characterization"
and
subsection
2(
a)
"
Need
&
Authority
for
the
Collection",
by
integrating
into
subsection
4(
b)
"
Information
Collected".
°
Eliminated
subsection
3(
e)
"
General
Guidelines"
which
is
duplicative
with
this
Preface.
°
Moving
subsection
6(
g)
"
Burden
Statement"
from
the
end
of
the
April
2004
draft
document,
to
the
front
of
this
revised
document
within
Section
1.
°
Moving
the
"
Respondent
Universe"
data
from
subsection
6(
d)
"
Estimating
the
Respondent
Universe
and
Total
Hour
and
Cost
Burden",
to
subsection
4(
a)
"
Respondents
and
SIC/
NAICS
Codes".
°
Changing
section
and
subsection
headings
and
numbering
sequence
(
to
reflect
above
changes).
°
Reducing
font
size
from
12
to
10,
and
reducing
page
margin
widths
(
to
reduce
overall
page
count).

The
revised
format
of
this
ICR
Supporting
Statement
is
also
consistent
with
OMB's
October
1995
instructions
on
the
format
and
information
content
of
Federal
agency
ICR
Supporting
Statements
(
see
PDF
page
6
of
7
at:
http://
www.
whitehouse.
gov/
omb/
inforeg/
83i­
fill.
pdf),
which
do
not
prescribe
a
strict
section/
subsection
outline
as
adopted
by
USEPA's
ICR
Handbook.
In
addition,
Eads
revised
the
text
subsections
and
computation
spreadsheets
of
this
document
pertaining
to
reporting
and
recordkeeping
for
hazardous
waste
import
manifests,
to
update
the
associated
requirements
in
line
with
OSW's
final
rule,
compared
to
the
May
2001
proposed
rule
requirements
for
import
manifests
applied
as
assumptions
in
the
09
April
2004
draft
ICR
Supporting
Statement.
To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
burden
estimates
provided
in
this
Supporting
Statement,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
USEPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
RCRA­
2001­
0032,
which
is
available
for
public
viewing
at
the
RCRA
Docket
Center
(
EPA/
DC),
EPA
West
Building,
Room
B102,
1301
Constitution
Avenue,
NW,
Washington
DC
20460
(
phone:
202­
566­
0270).
The
USEPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.
Monday
through
Friday,
excluding
Federal
holidays
(
phone:
202­
566­
1744).
Internet
access
to
an
electronic
version
of
USEPA's
Docket
is
available
via
the
Electronic
Docket
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Please
use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
Search",
then
key­
in
the
docket
ID
number
identified
above.
Also
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs
(
OIRA)
at
the
Office
of
Management
and
Budget
(
OMB)
at
725
17th
Street,
NW,
Washington
DC
20503,
Attention:
Desk
Officer
for
USEPA.
Please
include
the
USEPA
Docket
ID
number
(
RCRA­
2001­
0032).
USEPA­
OSWER
ICR
801.15
30
Dec
2004
4
1.
BURDEN
SUMMARY
1A.
Disaggregate
Burden
Hour
&
Cost
Table
1
summarizes
the
estimated
average
burden
hours
for
reporting
and
recordkeeping
per
affected
entities
(
i.
e.
registrants,
generators,
transporters,
and
TSDFs)
under
USEPA's
final
rule
revising
the
RCRA
hazardous
waste
manifest
system.

Reporting
burden:
For
generators
includes
time
for
reviewing
and
signing
the
manifest
(
i.
e.
for
generators
whose
manifests
are
prepared
by
TSDFs).
May
also
include
time
for
preparing
the
entire
manifest
and
submitting
an
exception
report
to
USEPA.
For
transporters
includes
time
to
carry
copies
during
shipment.
For
TSDFs
includes
time
for
reviewing
the
manifest
at
shipment
delivery
and
transmitting
a
copy
to
the
generator.
May
also
include
time
for
preparing
a
generator's
manifest
and
submitting
a
discrepancy
report
to
USEPA.

Recordkeeping
burden:
For
generators
includes
time
reading
the
regulations
once
per
year
and
keeping
copies
of
the
initial
manifest
and
final
manifest
received
from
the
TSDF.
For
LQGs
and
TSDFs,
it
may
also
include
time
for
keeping
a
copy
of
an
exception
report.
For
transporters
and
TSDFs,
the
recordkeeping
burden
includes
time
for
reading
the
regulations
once
per
year
and
keeping
a
copy
of
the
manifest
accompanying
the
shipment.

Table
1:
Summary
of
Disaggregate
Paperwork
Burden
Hours
(
Per
Affected
Entity
Per
Waste
Shipment)

Respondent
Type
Reporting
Burden
(
Hours)
Recordkeeping
Burden
(
Hours)
Row
Total
Burden
(
Hours)

1
Manifest
printer
registrants
1.72
­
2.42
1.25
2.97
­
3.67
2
Hazardous
Waste
Generators
Large
Quantity
Generators
(
LQGs)
0.04
­
1.84
1.45
­
1.55
1.49
­
3.39
TSDFs
acting
as
generators
0.54
­
1.87
1.45
­
1.55
1.99
­
3.42
Small
Quantity
Generators
(
SQGs)
0.04
­
1.20
1.45
1.49
­
2.65
3
Transporters
0.17
­
2.80
1.42
1.59
­
4.22
4
Designated
TSDFs
0.44
­
1.42
1.42
­
1.59
1.86
­
3.01
1B.
National
Aggregate
Burden
Hour
&
Cost
National
aggregate
respondent
and
Agency
burden
hour
and
associated
costs
are
summarized
below,
as
estimated
in
spreadsheet
Exhibits
1
to
20
provided
as
an
appendix
to
this
document.
Cumulative
burden
hours
and
costs
are
based
on
a
3­
year
time­
span
over
which
the
ICR
is
effective,
and
over
which
USEPA
averaged
burden
and
cost
estimates.
Therefore,
cumulative
burden
is
equal
to
annual
burden
estimates
multiplied
by
three.

Respondent
Burden
(
Exhibits
1
to
18):
3.27
million
hours
at
an
average
annual
cost
of
$
153.0
million,
including
$
846,000
per
year
capital
cost
and
$
1.81
million
per
year
O&
M
cost.
Cumulative
burden
to
respondents
over
three
years
is
9.81
million
hours
at
a
cost
of
$
459.0
million.

Agency
Burden
(
Exhibit
19):
About
8,000
hours
at
an
average
annual
cost
of
$
0.3
million.
Cumulative
burden
to
the
Agency
over
three
years
is
about
24,000
hours
at
a
cost
of
$
0.9
million.

Total
Burden
(
Respondents
+
Agency):
3.28
million
hours
at
an
average
annual
cost
of
$
153.3
million.
Cumulative
total
burden
over
three
years
is
9.83
million
hours
at
a
cost
of
$
459.9
million.

Change
in
Burden
(
Exhibit
20):
The
Supporting
Statement
(
31
Jan
2002,
68
pages)
for
the
previously
approved
RCRA
Manifest
ICR
801.14
(
01
April
2002,
http://
www.
epa.
gov/
icr/
icrs/
0801_
14.
html),
estimated
an
annual
burden
of
3.62
million
hours
(
respondents
+
Agency).
In
comparison,
ICR
801.15
which
replaces
ICR
801.14,
USEPA­
OSWER
ICR
801.15
30
Dec
2004
5
estimates
an
annual
burden
of
3.28
million
hours,
which
represents
a
reduction
of
0.34
million
annual
hours
compared
to
ICR
801.14.
USEPA­
OSWER
ICR
801.15
30
Dec
2004
1
USEPA
intended
the
manifest
to
serve
three
primary
purposes:
(
1)
to
serve
as
a
tracking
device
which
creates
clear
lines
of
accountability
among
the
participants
in
the
hazardous
waste
systems;
(
2)
to
serve,
together
with
other
USEPA
and
USDOT
requirements,
to
protect
human
health
and
the
environment
during
the
transportation
of
hazardous
waste
by
providing
information
on
the
waste
to
persons
handling
the
waste
and
to
emergency
response
personnel;
and
(
3)
to
provide
the
principal
basis
for
USEPA's
recordkeeping
and
reporting
requirements.

2
Pursuant
to
the
1995
Paperwork
Reduction
Act,
this
ICR
examines
only
Federal
information
collection
requirements.
It
does
not
address
State
requirements
(
e.
g.,
State­
optional
elements
of
the
manifest,
or
manifest
burden
associated
with
state­
only
regulated
hazardous
wastes).

3
This
ICR
examines
the
paperwork
requirements
and
average
annualized
respondent
burden
during
the
next
three
years,
under
the
RCRA
manifest
system,
as
amended
by
USEPA's
final
rule
establishing
the
revised
manifest
form.
USEPA
acknowledges
that,
during
the
first
18
months
after
publication
of
the
final
rule
establishing
the
new
manifest,
the
existing
manifest
will
be
in
use.
After
this
phase­
out
period,
the
revised
manifest
form
and
requirements
must
be
used.
The
final
rule
adds
new
paperwork
activities
to
the
existing
Federal
program
and
does
not
eliminate
any.
Hence,
this
ICR
captures
all
of
the
existing
Federal
manifest
requirements,
as
well
as
the
new
requirements
that
will
be
phased
in
18
months
after
rule
publication,
but
this
ICR
does
not
capture
the
final
rule's
burden
reduction
on
respondents
from
elimination
of
state
government
datafields
from
the
manifest
form.

6
2.
NEED,
AUTHORITY
&
USE
FOR
THE
INFORMATION
2A.
Need
&
Authority
to
Collect
Information
This
ICR
801.15
is
a
final
rule
ICR
for
USEPA's
RCRA
hazardous
waste
manifest
system,
but
at
the
same
it
is
renewing
the
existing
information
collection
(
ICR
nr.
801.14)
for
a
three­
year
extension,
thereby
superseding
and
replacing
the
existing
ICR.
EPA's
authority
to
require
use
of
a
hazardous
waste
manifest
system
stems
primarily
from
Section
3002(
a)(
5)
of
the
1976
Resource
Conservation
and
Recovery
Act
(
RCRA)
(
See
also
RCRA
Sections
3003(
a)(
3)
and
3004.)
Regulations
are
found
in
40
CFR
262
(
registrant
organizations
and
generators),
40
CFR
263
(
transporters),
and
40
CFR
264
&
265
(
TSDFs).
Section
3002(
a)(
5)
of
RCRA,
as
amended,
directs
the
US
Environmental
Protection
Agency
(
EPA)
to:

"...
establish
requirements
respecting...
use
of
a
manifest
system
and
any
other
reasonable
means
necessary
to
assure
that
all
such
hazardous
waste
generated
is
designated
for
treatment,
storage,
or
disposal,
and
arrives
at
treatment,
storage,
or
disposal
facilities...
for
which
a
permit
has
been
issued..."

Under
this
authority,
USEPA
published
regulations
for
a
manifest
system
on
February
26,
1980
(
45
Federal
Register
12724).
1
USEPA
established
requirements
for
manifest
completion,
transmittal,
and
recordkeeping
for
hazardous
waste
generators
at
40
CFR
262
subpart
B,
for
transporters
at
40
CFR
263
subpart
B,
and
for
treatment,
storage,
and
disposal
facilities
(
TSDFs)
at
40
CFR
264
&
265
subpart
E.
In
1984,
USEPA
published
the
Uniform
Hazardous
Waste
Manifest,
which
consisted
of
a
Federally­
required
portion
(
i.
e.,
Federally
required
data
elements
in
Blocks
1­
20)
and
a
State­
optional
portion
(
i.
e.,
Blocks
A­
K
on
the
manifest
reserved
for
optional
State
use).
2
In
2005,
USEPA
finalized
modifications
to
the
RCRA
manifest
system
to
minimize
unnecessary
paperwork
burden
on
hazardous
waste
handlers
resulting
from
variable
State
manifest
data
requirements,
and
to
address
other
stakeholderrequested
improvements
to
the
manifest
system.
USEPA
proposed
these
modifications
on
22
May
2001
(
http://
www.
epa.
gov/
epaoswer/
hazwaste/
gener/
manifest/
mods.
htm).
Specifically,
USEPA
has
eliminated
the
State­
optional
blocks
from
EPA's
RCRA
manifest
form
(
EPA
Form
8700­
22
&
8700­
22A
continuation
sheet),
and
made
the
manifest
form
completely
uniform.
USEPA
has
also
established
special
tracking
procedures
for
international
hazardous
waste
shipments
(
i.
e.
exports/
imports),
rejected
waste
loads,
and
waste
container
residues.
In
addition,
USEPA
has
established
a
RCRA
manifest
printing
registry
process
at
40
CFR
262.21.
Under
these
regulations,
any
organization
(
e.
g.,
waste
handler,
commercial
printer,
State
agency)
can
register
with
USEPA
to
print
RCRA
manifests.
Members
of
the
public
can
only
obtain
blank
manifest
forms
from
these
registered
sources.
Manifest
users
must
use
the
newly
revised
manifest
18
months
after
publication
of
the
final
rule
in
the
Federal
Register.
3
2B.
Practical
Utility
&
Users
of
the
Information
(
a)
USEPA
Registry
of
Approved
Manifest
Printers
In
regard
to
the
USEPA
registry,
USEPA
will
review
the
initial
application
from
each
registrant
to:
(
1)
ascertain
basic
organizational
information
(
e.
g.,
name
and
address
of
organization);
(
2)
determine
if
the
registrant's
proposed
suffix
is
unique;
(
3)
evaluate
the
qualifications
of
the
printing
company;
USEPA­
OSWER
ICR
801.15
30
Dec
2004
7
(
4)
understand
how
the
registrant
intends
to
print,
use,
and
distribute
the
forms;
and
(
5)
review
the
registrant's
proposed
controls,
and
establish
additional
controls
as
needed,
to
ensure
that
the
registrant
tightly
controls
its
tracking
numbers
and
prints
a
quality
manifest.

EPA
will
review
the
registrant's
form
samples
to:
(
1)
evaluate
the
competence
of
the
registrant
to
print
the
manifest;
(
2)
evaluate
if
the
registrant's
form
satisfies
the
print
requirements
of
40
CFR
262.21(
f)
(
e.
g.,
by
visually
examining
the
samples
and
writing
on
them
to
see
if
they
convey
handwritten
imprints
legibly
from
copy
to
copy,
as
required
under
40
CFR
262.21(
f)(
5));
and
(
3)
ascertain
the
paper
type,
paper
weight,
ink
color
of
the
instructions,
and
binding
method
of
the
registrant's
form.

If
the
registrant
is
approved
to
print
the
form,
the
registrant
must
print
the
form
according
to
the
paper
type,
paper
weight,
ink
color,
and
binding
method
of
its
approved
samples.

(
b)
Manifest
Procedures
In
regard
to
the
manifest
procedures,
generators,
transporters,
and
designated
TSDFs
handling
hazardous
waste
are
required
to
complete
the
data
requirements
for
manifests
and
other
reports
primarily
to:
(
1)
track
each
shipment
of
hazardous
waste
from
the
generator
to
a
designated
facility;
(
2)
provide
information
requirements
sufficient
to
allow
the
use
of
a
manifest
in
lieu
of
a
USDOT
shipping
paper
or
bill
of
lading,
thereby
reducing
the
duplication
of
paperwork
to
the
regulated
community;
(
3)
provide
information
to
transporters
and
waste
management
facility
workers
on
the
hazardous
nature
of
the
waste;
(
4)
inform
emergency
response
teams
of
the
waste's
hazard
in
the
event
of
an
accident,
spill,
or
leak;
and
(
5)
ensure
that
shipments
of
hazardous
waste
are
managed
properly
and
delivered
to
their
designated
facilities.

Although
the
generators,
transporters,
TSDFs,
and
emergency
response
teams
(
in
the
case
of
accidents)
are
the
primary
users
of
these
records,
USEPA
may
review
these
documents
during
a
facility
inspection
to
make
sure
proper
records
are
being
kept
and
regulations
are
complied
with.
USEPA
also
reviews
and
responds
to
exception
reports,
discrepancy
reports,
and
unmanifested
waste
reports.
USEPA­
OSWER
ICR
801.15
30
Dec
2004
4
Any
person
who
offers
a
hazardous
material
for
transportation
in
commerce
must
describe
the
hazardous
material
on
a
USDOT
shipping
paper
in
the
manner
required
in
49
CFR
172
subpart
C.
A
shipping
paper
includes
  
a
shipping
order,
bill
of
lading,
manifest
or
other
shipping
document
serving
a
similar
purpose
and
containing
the
information
required
by
49
CFR
172.202,
172.203
&
172.204.''
49
CFR
171.8
provides
a
definition
of
  
shipping
paper''.
49
CFR
172.205(
h)
states
that
an
USEPA
RCRA
hazardous
waste
manifest
(
EPA
Form
8700­
22)
  
may
be
used
as
the
shipping
paper''
if
it
contains
all
the
information
required
by
49
CFR
172
subpart
C.

8
3.
NONDUPLICATION,
CONSULTATIONS
&
OTHER
COLLECTION
CRITERIA
3A.
Nonduplication
No
document
identical
or
similar
in
purpose
to
the
manifest
is
required
by
the
Federal
government
for
the
shipment
of
RCRA
hazardous
waste.
Although
a
USDOT
hazardous
materials
shipping
paper4
contains
most
of
the
information
contained
on
the
manifest,
it
does
not
appear
to
be
legally
sufficient
to
track
hazardous
waste
shipments
from
the
generator
to
the
designated
facility
(
i.
e.
from
"
cradle­
to­
grave").
For
example,
USDOT's
shipping
paper
does
not
require
USEPA
ID
numbers
and
signatures
of
the
transporters
and
all
other
chain­
of­
custody
entities
involved
in
shipping
or
handling
the
hazardous
waste.
USEPA
requires
such
signatures
and
identification
numbers
on
the
manifest
to
ensure
accountability
of
each
waste
handler
during
shipment
of
the
hazardous
waste.
Also,
since
USEPA
coordinated
the
development
of
the
manifest
with
USDOT,
the
manifest
form
can
be
used
as
a
USDOT
shipping
paper,
thus
eliminating
the
need
for
the
transporter
to
carry
both
documents.
Furthermore,
the
manifest
form
was
developed
as
a
means
of
standardizing
the
information
requirements,
both
Federal
and
State,
thereby
eliminating
the
need
for
a
generator
to
complete
and
a
transporter
to
carry
multiple
manifests
for
interstate
shipments.

3B.
Public
Notice
In
compliance
with
the
Paperwork
Reduction
Act
of
1995,
USEPA
issued
a
public
notice
in
the
Federal
Register
on
May
22,
2001
(
66
Federal
Register
28240)
proposing
to
revise
the
Uniform
Hazardous
Waste
Manifest
regulations
and
the
manifest
form
(
USEPA
Forms
8700­
22
&
8700­
22A),
used
to
track
the
offsite
shipment
of
hazardous
wastes
from
generators
to
site
of
ultimate
disposition.
USEPA
received
66
public
comments
in
response
to
the
May
2001
proposed
rule.
USEPA
reviewed
and
addressed
these
public
comments
in
preparing
the
final
rule
and
background
documents,
including
this
ICR.

3C.
Consultations
1985:
Manifest
officials
in
several
State
environmental
agencies
formed
an
International
Hazardous
Waste
Manifest
Coordinators
Group
(
IHWMCG)
to
address
manifesting
issues
and
to
increase
uniformity
among
State
manifest
programs.
1988:
The
IHWMCG
served
on
the
Association
of
State
and
Territorial
Solid
Waste
Management
Officials
(
ASTSWMO)
Manifest
Revisions
Task
Force
to
develop
regulatory
recommendations
to
USEPA
to
increase
consistency
in
the
use
of
the
manifest
across
the
country.
1990:
The
Task
Force's
recommendations
for
specific
modifications
to
the
Uniform
Hazardous
Waste
Manifest
were
submitted
to
USEPA
as
a
rulemaking
petition
on
January
8,
1990.
1992:
EPA
embarked
upon
a
negotiated
rulemaking
effort
in
an
attempt
to
take
advantage
of
the
near
consensus
already
reached
by
States
in
the
ASTSWMO
petition.
USEPA
hoped
that
solutions
could
be
easily
found
which
would
meet
the
needs
of
all
affected
parties.
These
solutions
essentially
were
based
on
the
consolidation
of
the
current
State
optional
requirements
into
the
Federal
portion
of
the
form,
and
while
these
changes
would
have
created
a
more
uniform
manifest
system,
they
would
not
have
resulted
in
the
kind
of
decrease
in
manifest
burden
the
Agency
sought.
1994:
EPA
consulted
with
waste
handlers
on
average
respondent
burden
hours
under
the
manifest
system
(
1994
and
1995).
USEPA
asked
respondents
to
estimate
the
average
burden
hours
for
completing
a
manifest,
exception
report,
discrepancy
report,
and
unmanifested
waste
report.
1996:
EPA
reestablished
an
Agency
workgroup
charged
with
building
upon
the
best
recommendations
of
the
negotiated
rulemaking
effort,
along
with
better
accommodating
the
Agency's
burden
reduction
goals.
1998:
EPA
held
forums
with
State
and
industry
representatives
and
other
interested
parties
to
discuss
the
Agency's
initiatives
to
reduce
regulatory
burdens
under
the
manifest
system.
1999:
Furthermore,
USEPA
contacted
State
manifest
programs
regarding
the
number
of
manifests
originating
in
their
State
and
one
TSDF
regarding
its
activities
in
reconciling
manifest
discrepancies.
USEPA­
OSWER
ICR
801.15
30
Dec
2004
9
2003:
The
majority
of
burden
assumptions
in
this
ICR
are
based
on
the
pre­
2003
outreach
efforts.
In
developing
this
current
ICR,
USEPA
conducted
further,
limited
outreach
to
understand
the
burdens
associated
with
its
final
rule.
Specifically,
USEPA
collected
information
on
burden
associated
with
the
registration
process
under
40
CFR
262.21
(
the
Agency
found
that
registrants
will
incur
approximately
$
500
in
developing
their
form
samples)
and
the
rejected
waste
and
container
residue
provisions
at
40
CFR
264.72
&
265.72
(
the
Agency
found
that
approximately
3%
of
shipments
received
by
the
designated
TSDF
are
rejected
or
identified
as
container
residues).
The
organizations
contacted
are
identified
in
Table
2
below.

Table
2
List
of
Organizations
Contacted
by
ICF
Consulting
Inc
in
2003
on
Behalf
of
USEPA­
OSW
to
Obtain
Supplemental
Data
on
Burden
Assumptions
for
this
ICR
Supporting
Statement
Name
of
Organization
Name
of
Contact
Person
Telephone
Number
1
Budget
Printers
Mike
Gordon
(
800)
800­
2138
2
California
Office
of
State
Printing
Noel
Soliz
(
916)
322­
2373
3
Environmental
Technology
Council
Scott
Slesinger
(
202)
783­
0870
4
Label
Master
Jeanne
Zmick
(
773)
279­
2303
5
LRD
Systems
&
Forms
Dar
Sheply
(
815)
338­
6620
6
Moore
Wallace
Darrel
Drennan
(
210)
732­
6221
7
NCR
Corporation
Chris
Kaderli
(
512)
248­
2593
8
Standard
Register
Mike
Lyons
(
630)
719­
1910
ext.
234
9
Webb
Mason
Timothy
Maderas
(
888)
926­
2766
ext.
1361
3D.
Effects
of
Less
Frequent
Collection
USEPA
requires
registrants
to
submit
an
initial
application
to
USEPA
under
40
CFR
262.21(
b)
and
form
samples
and
descriptions
under
40
CFR
262.21(
d).
These
are
one­
time
submittals.
Registrants
need
not
submit
any
other
application
information
under
40
CFR
262.21(
b)
or
(
d),
except
if
USEPA
requests
changes
or
has
questions.
If
USEPA
did
not
receive
these
submittals,
USEPA
would
not
be
able
to
determine
if
the
registrant:
°
will
tightly
control
its
manifest
tracking
numbers
to
ensure
that
each
number
pre­
printed
on
the
manifest
is
unique;
°
will
use
appropriate
quality
control
measures
to
print
a
quality
manifest
consistently;
and
°
is
competent
to
print
the
manifest.
USEPA
also
would
not
have
any
way
to
determine
if
the
registrant's
manifest
satisfies
the
print
requirements
at
40
CFR
262.21(
f).
USEPA
needs
to
visually
examine
the
samples
(
e.
g.,
to
determine
if
it
has
acceptable
copy­
to­
copy
registration;
if
the
instructions
on
the
back
of
the
copies
do
not
bleed
through;
if
the
binding
method
is
adequate;
if
the
paper
weight
and
paper
type
are
adequate
to
convey
handwritten
imprints
copy
to
copy).
An
approved
registrant
need
not
re­
submit
information
to
the
Agency,
unless
it:
°
updates
its
initial
application
approved
under
40
CFR
262.21(
c)
°
wants
a
new
suffix
°
seeks
to
change
the
paper
type,
paper
weight,
ink
color
of
the
instructions,
or
binding
method
of
its
approved
forms
°
seeks
to
change
the
printing
company.
In
regard
to
updates
to
the
application,
USEPA
needs
to
learn
about
any
updates.
For
example,
if
the
name
or
address
of
the
registrant
changes,
USEPA
must
be
informed
of
this.
If
the
registrant
updates
its
quality
control
methods,
USEPA
must
be
apprised
so
it
can
evaluate
the
updated
methods
and
require
modifications
if
needed.
Less
frequent
information
submittal
would
not
allow
USEPA
to
learn
about
these
important
updates
and
ensure
they
are
appropriate.
USEPA­
OSWER
ICR
801.15
30
Dec
2004
10
In
regard
to
requests
for
a
new
suffix,
USEPA
needs
to
evaluate
the
registrant's
proposed
new
suffix
to
ensure
it
is
unique.
Each
registrant
must
generate
its
unique
manifest
tracking
numbers
using
its
unique
suffix.
If
registrants
do
not
submit
a
request
to
USEPA
for
a
new
suffix,
USEPA
will
not
have
a
way
to
ensure
that
a
registrant's
new
suffix
is
unique.
In
regard
to
changes
to
the
paper
type,
paper
weight,
ink
color,
or
binding
method
or
changes
to
the
approved
printer,
USEPA
must
evaluate
the
form
to
determine
if
it
satisfies
the
print
requirements
of
40
CFR
262.21(
f).
After
they
are
approved
to
print
the
form,
for
example,
some
registrants
might
seek
to
change
their
paper
type
to
a
lesser
grade,
which
may
not
effectively
convey
impressions
copy
to
copy.
Less
frequent
information
submittal
would
not
allow
USEPA
to
evaluate
changes
to
these
key
aspects
of
the
registrant's
form.
In
regard
to
the
manifest
requirements,
USEPA
does
not
collect
manifests
under
normal
situations,
but
requires
instead
preparation
of
the
manifest,
use
of
the
manifest
during
transportation,
and
recordkeeping
of
the
manifests
for
a
3­
year
period.
Manifests
are
only
collected
by
USEPA
either
to
accompany
an
exception
or
discrepancy
report
or
in
the
case
of
an
export.
In
addition,
since
the
manifest
is
required
to
accompany
all
shipments
of
hazardous
waste
when
shipped
off
site
by
the
generator,
less
frequent
preparation
is
not
possible.
The
frequency
of
off­
site
shipment
is
determined
by
the
generator
and
depends
on:
°
the
quantities
of
waste
to
be
shipped
as
they
impact
the
economies
of
shipment
°
transporter
scheduling
°
the
applicable
regulatory
requirements.
The
present
system
gives
the
generator
the
opportunity
to
maximize
the
economies
of
off­
site
shipments
by
selecting
a
shipping
frequency
that
is
appropriate
for
the
rate
of
waste
generation.
Further,
by
requiring
a
manifest
to
accompany
each
shipment,
USEPA
ensures
the
manifest
is
available
in
the
case
of
a
discharge
of
hazardous
waste
during
transportation.
Information
on
the
manifest
could
be
useful
to
emergency
response
personnel
responding
to
the
scene.
In
this
regard,
less
frequent
manifesting
could
result
in
a
less
expedient
or
protective
response
to
the
release.
Note,
however,
that
USEPA
provides
a
manifest
exemption
at
40
CFR
262.20(
e)
and
(
f)
for
specified
types
of
shipments,
as
appropriate.
Under
40
CFR
262.20(
e),
small
quantity
generators
(
SQGs),
or
those
generators
who
generate
between
100
and
1,000
kilograms/
month
of
hazardous
waste,
can
be
exempt
from
manifest
requirements
if
the
waste
is
reclaimed
under
a
contractual
agreement
that
specifies
the
type
of
waste
and
frequency
of
shipments;
the
transporting
vehicle
is
owned
and
operated
by
the
reclaimer;
and
the
generator
retains
a
copy
of
the
reclamation
agreement
for
three
years
after
termination
or
expiration
of
the
agreement.
Under
40
CFR
262.20(
f),
generators
who
transport
hazardous
wastes
on
a
public
or
private
right­
of­
way
within
or
along
the
border
of
contiguous
property
under
the
control
of
the
same
person,
even
if
such
contiguous
property
is
divided
by
a
public
or
private
right­
of­
way,
are
exempt
from
manifesting
requirements.

3E.
Confidentiality
Section
3007(
b)
of
RCRA
and
40
CFR
2
subpart
B,
which
define
USEPA's
general
policy
on
the
public
disclosure
of
information,
contain
provisions
for
confidentiality.
However,
the
Agency
does
not
anticipate
that
businesses
will
assert
a
claim
of
confidentiality
covering
all
or
part
of
the
information
collection
requirements
covered
in
this
ICR.
If
such
a
claim
was
asserted,
USEPA
must
and
will
manage
that
information
in
accordance
with
the
regulations
cited
above.

3F.
Sensitive
Questions
No
questions
of
a
sensitive
nature
are
included
in
any
of
the
information
collection
requirements.
USEPA­
OSWER
ICR
801.15
30
Dec
2004
5
Memorandum
to
Bryan
Groce,
USEPA­
OSW­
HWID
entitled
"
Preliminary
Draft
Cost
Estimate
for
the
Manifest
Registry
System,"
24
Feb
2003.

6
Ibid.

11
4.
UNIVERSE
OF
AFFECTED
RESPONDENTS
4A.
Economic
Sectors
&
Industries
Affected
Table
3
below
presents
a
list
of
Standard
Industrial
Classification
(
SIC)
codes
and
corresponding
North
American
Industry
Classification
System
(
NAICS)
codes
associated
with
the
industries
most
likely
affected
by
this
ICR.

Table
3
List
of
Economic
Sectors
With
Industries
Affected
by
the
Paperwork
Requirements
of
this
ICR
Item
Industrial
Sector
SIC
Code(
s)
NAICS
Code(
s)

1
Agriculture,
Forestry,
Fishing,
and
Hunting
01­
09
11
2
Mining
10­
14
21
3
Utilities
49
22
4
Construction
15­
17
23
5
Manufacturing
20­
39
31­
33
6
Wholesale
Trade
50­
51
42
7
Retail
Trade
52­
59
44­
45
8
Transportation
and
Warehousing
40­
47
48­
49
9
Information
27,
48,
73
(
partial),
78
51
10
Waste
Management
&
Remediation
Services
1799,
4953,
4959
562
11
Public
Administration
91­
97
92
4B.
Types
&
Count
of
Entities
Affected
There
are
basically
five
categories
of
entities
affected
by
the
respondent
activities
required
for
each
information
collection
element
discussed
in
this
ICR:
°
Registrant
organizations
(
manifest
printer
registry)
°
Hazardous
waste
generators
which
ship
hazardous
waste
offsite
°
Hazardous
waste
transporters
°
Hazardous
waste
TSDFs
(
treatment,
storage,
disposal
facilities)
which
receive
offsite
shipments
°
Agency
(
i.
e.
Federal
RCRA­
authorized
state
government
programs,
and
USEPA
regional
offices,
and
USEPA
headquarters)

(
4B.
1)
Registrant
Organizations
As
displayed
in
Table
4,
USEPA
estimates
that
40
entities
will
apply
to
USEPA's
manifest
printing
registry
during
the
first
two
years
covered
by
this
ICR.
5
This
includes
the
roughly
20
States
that
currently
print
the
manifest
and
20
TSDFs
or
large
generators.
In
addition,
USEPA
used
its
best
judgment
to
estimate
that
the
Agency
will
receive
two
new
applications
in
the
third
year
covered
by
this
ICR.
6
Thus,
USEPA
estimates
that,
on
average,
14
registrant
organizations
will
be
subject
to
the
requirements
in
40
CFR
262.21
over
the
3­
year
period
covered
by
this
ICR.
USEPA­
OSWER
ICR
801.15
30
Dec
2004
7
To
determine
the
number
of
LQGs
and
TSDFs
shipping
hazardous
waste
off
site,
USEPA
used
information
from
the
Waste
Generation
and
Management
(
GM)
Form
and
the
RCRA
Subtitle
C
Site
Identification
(
Site
ID)
Form
of
the
2001
BRS.
USEPA
then
eliminated
facilities
operated
by
the
Federal
government
(
i.
e.,
government­
owned,
government­
operated
facilities
(
GOGOs)
and
privately­
owned,
government­
operated
facilities
(
POGOs)).

8
These
percentages
are
based
on
an
analysis
of
prior
year
data
on
TSDFs
contained
in
USEPA's
Office
of
Solid
Waste
RCRA
Hazardous
Waste
Biennial
Report
database
(
http://
www.
epa.
gov/
epaoswer/
hazwaste/
data/
biennialreport/
index.
htm).

9
ICF
Consulting
Inc
collected
data
used
in
this
analysis
from
USEPA's
Office
of
Solid
Waste
RCRAInfo
database
during
07­
14
Nov
2003
(
http://
www.
epa.
gov/
epaoswer/
hazwaste/
data/
index.
htm#
rcra­
info).

10
In
estimating
the
number
of
SQGs
that
shipped
hazardous
waste
off
site,
USEPA
used
the
methodology
approved
by
USEPA's
Office
of
Solid
Waste
in
2000.
For
a
description
of
this
methodology,
refer
to
the
following
memoranda:
(
1)
Memorandum
from
ICF
Consulting
Inc.
to
Patricia
Mercer,
USEPA,
"
Report
on
the
Estimation
of
Small
Quantity
Generator
Universe,"
19
Jan
2000
and
(
2)
Memorandum
from
ICF
to
Peggy
Vyas,
USEPA,
"
SQG
Up­
Date,"
31
July
2000.

11
The
estimate
does
not
include
facilities
operated
by
the
Federal
government
(
i.
e.,
GOGOs
or
POGOs).

12
Based
on
data
in
USEPA­
OSW's
"
Economics
Background
Document"
developed
for
this
final
rulemaking.

13
The
estimate
does
not
include
facilities
operated
by
the
Federal
government
(
i.
e.,
GOGOs
or
POGOs).

12
Table
4
Estimated
Number
of
Registrant
Organizations
Subject
to
40
CFR
262.2
EPA
Manifest
Printing
Registry
Year
1
Year
2
Year
3
Average
Number
of
registry
applicants
20
20
2
14
(
4B.
2)
Waste
Handlers
For
purposes
of
estimating
respondent
burden,
it
is
appropriate
to
distinguish
between
LQGs
that
generate
but
do
not
manage
hazardous
waste
onsite,
versus
LQGs
that
both
generate
and
manage
(
i.
e.,
treat,
store,
or
dispose
of)
hazardous
waste
on
site.
Specifically,
USEPA
has
found
differences
between
these
two
groups
in
their
manifesting
practices
and
number
of
outbound
shipments.
Based
on
USEPA­
OSW's
2001
RCRA
Hazardous
Waste
Biennial
Report
(
BR)
data
(
http://
www.
epa.
gov/
epaoswer/
hazwaste/
data/
brs01/
national.
pdf),
USEPA
estimates
that
17,462
LQGs
in
the
US
generate
but
do
not
manage
hazardous
waste
(
these
sites
are
referred
to
simply
as
"
LQGs"
in
this
ICR.)
In
addition,
2001
BR
data
indicate
that
1,209
sites
in
the
US
both
generate
and
manage
hazardous
waste
onsite
and
hence
qualify
as
TSDFs.
7
(
This
ICR
refers
to
these
1,209
sites
as
"
TSDFs
acting
as
generators.")
EPA
estimates
that,
of
the
1,209
TSDFs
acting
as
generators,
approximately
25%
are
commercial
TSDFs
(
302)
and
75%
are
captive
TSDFs
(
907).
8
USEPA
defines
a
commercial
TSDF
as
a
facility
whose
waste
management
capacity
is
available
to
any
generators
or
facilities
for
commercial
hazardous
waste
management,
or
to
a
limited
group
of
generators
or
facilities
for
commercial
hazardous
waste
management.
A
captive
TSDF
is
a
facility
that
receives
hazardous
waste
from
on­
site
sources
only,
or
from
on­
site
sources
and
off­
site
sources
that
are
part
of
its
same
company
only.
USEPA
estimates
there
are
significant
differences
between
commercial
and
captive
TSDFs
regarding
waste
volumes
managed
and
number
of
manifests
completed,
and
thus,
the
Agency
has
chosen
to
examine
their
manifest
preparation
burdens
separately
in
this
ICR.

To
determine
the
number
of
SQGs
that
ship
hazardous
waste
off
site
each
year,
USEPA
performed
an
in­
depth
analysis
of
data
from
the
2001
BR
and
data
from
other
USEPA
information
collection
instruments
(
e.
g.,
3010
Notification).
9
Based
on
this
analysis,
USEPA
estimates
that
113,132
SQGs
ship
hazardous
waste
off
site
each
year
and
are
subject
to
the
manifest
system.
10,
11
In
addition,
there
are
414
hazardous
waste
transporter
companies
subject
to
the
manifest
system.
12
Finally,
USEPA
referred
to
2001
BR
data
to
estimate
that,
each
year,
581
TSDFs
receive
hazardous
waste
from
off
site.
13
Table
5
summarizes
the
number
of
waste
handlers
subject
to
manifesting
requirements
each
year.
USEPA­
OSWER
ICR
801.15
30
Dec
2004
13
Table
5
Annual
Number
of
Waste
Handlers
Subject
to
Manifesting
System
Type
of
Waste
Handler
Number
of
Waste
Handlers
1
Generators
LQGs
17,462
a
Commercial
TSDFs
302
b
Captive
TSDFs
907
b
SQGs
113,132
a
Subtotal
131,803
2
Transporters
414
3
Designated
TSDFs
("
receiving
facilities")
581b
a
Includes
sites
that
generate
hazardous
waste
but
do
not
manage
it
onsite
under
a
permit.
b
Many
TSDFs
acting
as
generators
may
also
qualify
as
designated
TSDFs.
Hence,
the
number
of
designated
TSDFs
and
TSDFs
acting
as
generators
are
not
additive.

4C.
Number
of
Annual
RCRA
Manifests
(
4C.
1)
Number
of
Manifests
that
Accompany
Shipments
Initiated
by
the
Generator
This
ICR
addresses
the
RCRA
manifesting
requirements
for
three
types
of
hazardous
waste
shipments
estimated
in
Table
6:
°
Domestic
shipments
of
hazardous
waste
(
i.
e.
shipments
originating
and
terminating
within
the
US)
°
Import
shipments
(
i.
e.
shipments
received
from
a
foreign
country
and
shipped
within
the
US)
°
Export
shipments
subject
to
40
CFR
262
subpart
E
(
i.
e.
exports
from
the
US
to
non­
designated
members
of
the
Organization
for
Economic
Cooperation
and
Development
(
OECD),
as
identified
at
40
CFR
262.58(
a)(
1)).
[
Note:
this
ICR
does
not
include
manifest
burden
for
waste
exports
to
designated
OECD
countries.]

Table
6
Estimated
Annual
Number
of
Manifests
Completed
by
Hazardous
Waste
Generators:
Domestic
Shipments
+
Export
Shipments
to
Non­
Designated
OECD
Countries
Type
of
Generator
Number
of
Generators
that
Manifest
Average
Annual
Number
of
Manifests
Completed
per
Generator*
Annual
Number
of
Manifests
Completed
LQGs
17,462
46
795,219
Commercial
TSDFs
302
347
104,926
Captive
TSDFs
907
36
32,325
SQGs**
93,132**
9
829,806
Total
111,803
16
1,762,276
*
These
numbers
are
rounded.
**
Of
the
113,132
SQGs
shipping
hazardous
waste
off
site
each
year,
USEPA
estimates
that
93,132
must
prepare
and
transmit
a
manifest
with
their
off­
site
shipments
and
the
remaining
20,000
operate
under
a
reclamation
agreement
(
based
on
consultations
with
industry
in
Sept
2003).
As
provided
under
40
CFR
262.20(
e),
these
20,000
SQGs
need
not
undertake
any
manifesting
activities
for
their
hazardous
waste
shipments
to
the
recycling
facility.

Table
7
breaks
down
the
annual
number
of
manifests
that
accompany
domestic
shipments,
import
shipments,
and
export
shipments
to
non­
designated
OECD
countries.
Based
on
USEPA
consultations,
as
well
as
data
compiled
by
USEPA's
Office
of
Enforcement
and
Compliance
Assurance
(
OECA),
USEPA
estimates
that
1,725,143
manifests
accompany
domestic
shipments
of
hazardous
waste
and
19,509
manifests
accompany
export
shipments
to
non­
designated
OECD
countries
each
year,
including
Mexico
and
Canada.
In
addition,
USEPA
has
used
its
best
judgment
to
estimate
that
17,624
manifests
are
prepared
each
year
by
transporters
for
imported
hazardous
wastes
at
point­
of­
entry
into
the
US
and
all
are
received
by
commercial
TSDFs
(
i.
e.
"
receiving
facilities"),
which
represents
1%
of
total
annual
manifests.
USEPA­
OSWER
ICR
801.15
30
Dec
2004
14
Table
7
Estimated
Total
Annual
Number
of
Manifests
Completed
for
Domestic
Shipments,
Import
Shipments,
and
Export
Shipments
to
Non­
Designated
OECD
Countries
Type
of
Generator
Total
Number
of
Manifests
Completed/
Year
Domestic
Shipments
Import
Shipments
Export
Shipments
to
Non­
Designated
OECD
Counties
a
All
Shipments
LQGs
786,050
0
9,169
795,219
Commercial
TSDFs
85,741
17,624
1,561
104,926
Captive
TSDFs
31,740
0
585
32,325
SQGs
821,612
0
8,194
829,806
Total
1,725,143
17,624
19,509
1,762,276
a
Includes
Mexico
and
Canada.

(
4C.
2)
Number
of
Manifests
that
Accompany
Shipments
Rejected
by
the
Designated
TSDF
EPA
estimates
that
each
manifest
completed
and
sent
off
site
by
a
generator
(
1,762,276)
will
be
delivered
to
the
designated
TSDF,
minus
those
manifests
accompanying
export
shipments
(
19,509
manifests)
or
lost
during
transport
(
173
manifests),
plus
import
manifests
(
17,624).
Hence,
USEPA
estimates
that
1,760,218
manifests
will
be
delivered
to
the
designated
TSDF.
USEPA
estimates
that
3%
(
58,674)
will
be
rejected.
Table
8
presents
the
number
of
manifests
accompanying
shipments
that
are
rejected
or
for
which
a
container
residue
is
identified
by
the
TSDF.
USEPA
estimates
that
50%
of
these
problem
shipments
(
29,337)
involve
partially
rejected
loads
or
container
residues
identified
after
the
transporter
has
left
the
TSDF's
premises.
USEPA
estimates
that
99%
of
these
shipments
will
be
sent
to
the
alternate
TSDF
and
1%
will
be
sent
back
to
the
generator.
A
new
manifest
must
be
prepared
to
send
these
shipments
to
the
alternate
TSDF
or
generator.
EPA
estimates
that
the
remaining
50%
of
these
problem
shipments
(
29,337)
involve
fully
rejected
loads
or
container
residues
identified
while
the
transporter
is
still
on
the
TSDFs'
premises.
USEPA
estimates
that
99%
of
these
shipments
will
be
sent
to
the
alternate
TSDF
and
1%
will
be
sent
back
to
the
generator.
The
original
manifest
may
be
used
to
send
these
shipments
to
the
alternate
TSDF
or
generator.

Table
8
Total
Annual
Number
of
Manifests
that
Accompany
Rejected
Loads
and
Container
Residues
a
Type
of
Shipment
Estimated
Annual
Number
of
Manifests
New
Manifests
that
Accompany
Rejected
Shipments
or
Container
Residues
Shipments
sent
back
to
generator
(
1%)
293
Shipments
sent
to
alternate
TSDF
(
99%)
29,044
Subtotal
29,337
Original
Manifests
that
Accompany
Rejected
Shipments
or
Container
Residues
Shipments
sent
back
to
generator
(
1%)
293
Shipments
sent
to
alternate
TSDF
(
99%)
29,044
Subtotal
29,337
Total
58,674
a
Table
contains
rounding
error.
USEPA­
OSWER
ICR
801.15
30
Dec
2004
15
5.
ELEMENTS
OF
INFORMATION
COLLECTED
5A.
Manifest
Printer
Registrant
Requirements
(
a)
Applying
to
the
Registry
40
CFR
262.21(
a)
provides
that
a
person
may
not
print
the
manifest
for
use
or
distribution
unless
his/
her
organization
(
e.
g.,
company,
State
agency)
has
received
approval
from
USEPA
to
do
so
under
40
CFR
262.21(
c)
and
(
e).
In
order
to
receive
USEPA
approval,
a
registrant
must
submit
to
USEPA
an
application
that
contains
the
information
specified
in
40
CFR
262.21(
b).
Upon
USEPA
approval
of
the
application,
the
registrant
must
submit
three
fully
assembled
manifests
and,
if
needed,
continuation
sheets
that
meet
the
specifications
of
40
CFR
262.21(
f)
and
a
description
of
the
form
samples,
as
specified
in
40
CFR
262.21(
d).
In
reviewing
these
submittals,
USEPA
may
request
modification
to
them
before
approval.
In
developing
the
registry
process,
USEPA
performed
thorough
consultation
with
waste
handlers,
commercial
printers,
and
States
and
concluded
that
it
is
imperative
for
USEPA
to
evaluate
the
printing
capabilities
and
form
samples
of
registrants.
Although
many
commercial
printers
have
developed
an
expertise
in
multi­
forms
printing
(
the
final
rule
requires
RCRA
manifests
to
be
printed
on
a
six­
copy
form),
USEPA
expects
that
certain
prospective
registrants
will
not
have
such
expertise.
Printing
the
manifest
requires
some
degree
of
sophistication
and
expertise
in
order
to
consistently
satisfy
the
performance
requirements
at
40
CFR
262.21(
f).
For
example,
registrants
must
design
their
manifest
so
that
handwritten
and
typed
imprints
are
legible
on
all
six
copies,
the
manifest
instructions
do
not
bleed
through
the
front
of
the
copies,
and
the
binding
of
copies
is
reasonably
secure.
Although
USEPA
intends
to
post
print
guidance
on
the
web,
significant
discretion
will
be
left
to
the
registrant
to
determine
the
appropriate
paper
type,
paper
weight,
ink
color
of
the
instructions,
and
binding
methods
that
will
satisfy
the
print
specifications.
Because
of
this,
it
is
essential
that
the
registry
review
samples
of
their
forms
to
determine
if
they
comply
with
the
print
specifications,
e.
g.,
to
evaluate
the
samples
to
see
if
they
comply
with
the
performance
requirements.
In
addition,
USEPA
and
the
States
are
keenly
interested
in
making
sure
that
manifest
tracking
numbers
pre­
printed
on
forms
are
tightly
controlled
and
remain
unique.
One
of
the
highest
priorities
of
the
registry
is
ensuring
that
each
manifest
used
or
distributed
to
the
pubic
has
a
unique
tracking
number.
Because
USEPA
will
allow
registrants
to
pre­
print
numbers
onto
their
manifests
without
any
ongoing
Agency
oversight,
it
is
essential
that
the
registry
evaluate
and
approve
the
registrant's
procedures
and
systems
for
controlling
their
tracking
numbers,
as
described
in
their
applications.

Data
Items
°
An
application
that
contains
the
following
information:
­­
Name
and
mailing
address
of
registrant.
­­
Name,
telephone
number,
and
email
address
of
contact
person.
­­
Brief
description
of
registrant's
government
or
business
activity.
­­
EPA
ID
number
of
the
registrant,
if
applicable.
­­
Description
of
the
scope
of
the
operations
that
the
registrant
plans
to
undertake
in
printing,
distributing,
and
using
its
manifests,
including:
­
A
description
of
the
printing
operation.
The
description
should
include
an
explanation
of
whether
the
registrant
intends
to
print
its
manifests
in­
house
or
through
a
separate
printing
company.
If
the
registrant
intends
to
use
a
separate
printing
company
to
print
the
manifest
on
its
behalf,
the
application
must
identify
this
printing
company
and
discuss
how
the
registrant
will
oversee
the
company.
If
this
includes
the
use
of
intermediaries,
the
role
of
each
must
be
discussed.
The
application
must
provide
the
name
and
mailing
address
of
each
company.
It
also
must
provide
the
name
and
telephone
number
of
the
contact
person
at
each
company.
­
A
description
of
how
the
registrant
will
ensure
that
its
organization
and
unaffiliated
companies,
if
any,
comply
with
the
requirements
of
40
CFR
262.21.
The
application
must
discuss
how
the
registrant
will
ensure
that
a
unique
manifest
tracking
number
will
be
pre­
printed
on
each
manifest.
The
application
must
describe
the
internal
control
procedures
to
be
followed
by
the
registrant
and
unaffiliated
companies
to
ensure
that
numbers
are
tightly
controlled
and
remain
unique.
If
computer
systems
or
other
infrastructure
will
be
used
to
maintain,
track,
or
assign
numbers,
these
should
be
indicated.
The
application
must
indicate
how
the
printer
will
pre­
print
a
unique
number
on
each
form.
The
application
must
explain
the
quality
procedures
to
be
followed
by
each
establishment
and
printing
company
to
ensure
that
all
required
print
specifications
USEPA­
OSWER
ICR
801.15
30
Dec
2004
16
are
consistently
achieved
and
that
printing
violations
are
identified
and
corrected
at
the
earliest
practicable
time.
­
An
indication
of
whether
the
registrant
intends
to
use
the
manifests
for
its
own
business
operations
or
to
distribute
the
manifests
to
a
separate
company
or
to
the
general
public
(
e.
g.,
for
purchase).
­­
A
brief
description
of
the
qualifications
of
the
company
that
will
print
the
manifest.
The
registrant
may
use
readily
available
information
to
do
so
(
e.
g.,
corporate
brochures,
product
samples,
customer
references,
documentation
of
ISO
certification),
so
long
as
such
information
pertains
to
the
establishments
or
company
being
proposed
to
print
the
manifest.
­­
Proposed
unique
three­
letter
manifest
tracking
number
suffix.
If
the
registrant
is
approved
to
print
the
manifest,
the
registrant
must
use
this
suffix
to
pre­
print
a
unique
manifest
tracking
number
on
each
manifest.
­­
A
signed
certification
by
a
duly
authorized
employee
of
the
registrant
that
the
organizations
and
companies
in
its
application
will
comply
with
the
procedures
of
its
approved
application
and
the
requirements
of
40
CFR
262.21
and
that
it
will
notify
USEPA
of
any
duplicated
manifest
tracking
numbers
on
manifests
that
have
been
used
or
distributed
to
other
parties
as
soon
as
this
becomes
known.
°
Three
fully
assembled
manifests
and,
if
needed,
continuation
sheets
that
meet
all
of
the
specifications
in
40
CFR
262.21(
f).
The
form
samples
must
be
printed
by
the
company
that
will
print
the
manifest
as
identified
in
the
application
approved
under
40
CFR
262.21(
c).
The
registrant
need
not
submit
samples
of
the
continuation
sheet
if
the
continuation
sheet
will
be
printed
using
the
same
paper
type,
paper
weight,
ink
color
of
the
instructions,
and
binding
method
as
the
manifest.
°
A
description
of
the
manifest
samples
as
follows:
­­
Paper
type
(
i.
e.,
manufacturer
and
grade
of
the
manifest
paper).
­­
Paper
weight
of
each
copy.
­­
Ink
color
of
the
manifest's
instructions.
If
screening
of
the
ink
was
used,
the
registrant
must
indicate
the
extent
of
the
screening.
­­
Method
of
binding
the
copies.

Respondent
Activities
°
Prepare
and
submit
initial
application.
°
Submit
revised
initial
application
to
USEPA,
if
requested.
°
Submit
three
fully
assembled
manifests
and,
if
needed,
continuation
sheets
and
a
description
of
the
form
samples.
°
Submit
revised
form
samples
based
on
USEPA
comment
on
the
initial
samples,
if
requested.

(
b)
Updating
General
Information
in
the
Approved
Application
40
CFR
262.21(
h)(
1)
provides
that,
if
an
approved
registrant
would
like
to
update
any
of
the
information
provided
in
its
application
(
e.
g.,
to
update
a
company
phone
number
or
name
of
contact
person),
the
registrant
must
revise
the
application
and
submit
it
to
USEPA,
along
with
an
indication
or
explanation
of
the
update,
as
soon
as
practicable
after
the
change
occurs.
USEPA
will
review
and
either
approve
or
deny
the
revision.
If
the
revision
is
denied,
the
registrant
must
respond
to
the
Agency's
concerns.

Data
Item
°
Revised
application,
along
with
an
indication
or
explanation
of
the
update.

Respondent
Activities
°
Revise
and
submit
the
application
to
USEPA,
along
with
an
indication
or
explanation
of
the
update.
°
Respond
to
the
Agency's
concerns,
if
applicable.

(
c)
Requesting
Approval
for
a
New
Tracking
Number
Suffix
40
CFR
262.21(
h)(
2)
provides
that,
if
an
approved
registrant
would
like
a
new
tracking
number
suffix,
the
registrant
must
submit
a
proposed
suffix
to
USEPA,
along
with
the
reason
for
requesting
it.

Data
Item
USEPA­
OSWER
ICR
801.15
30
Dec
2004
17
°
Proposed
tracking
number
suffix,
along
with
the
reason
for
requesting
it.

Respondent
Activity
°
Submit
a
proposed
tracking
number
suffix,
along
with
the
reason
for
requesting
it.

(
d)
Requesting
Approval
for
Changes
to
Printing
Specifications
or
Use
of
a
New
Printer
40
CFR
262.21(
h)(
3)
provides
that,
if
a
registrant
would
like
to
change
the
paper
type,
paper
weight,
ink
color
of
the
manifest
instructions,
or
binding
method
of
its
manifest
or
continuation
sheet
subsequent
to
approval
under
40
CFR
262.21(
e),
then
the
registrant
must
submit
three
samples
of
the
revised
form
for
USEPA
review
and
approval.
If
the
approved
registrant
would
like
to
use
a
new
printer,
the
registrant
must
submit
three
manifest
samples
printed
by
the
new
printer,
along
with
a
brief
description
of
the
printer's
qualifications
to
print
the
manifest.
In
reviewing
these
submittals,
USEPA
may
request
modification
to
them
before
approval.

Data
Items
°
Three
samples
of
the
manifest
form
and/
or
continuation
sheet.
°
A
brief
description
of
the
qualifications
of
the
new
printer,
if
applicable.

Respondent
Activity
°
Submit
three
samples
of
the
manifest
form
and/
or
continuation
sheet
and,
if
applicable,
a
brief
description
of
the
qualifications
of
the
new
printer.
°
Submit
revised
manifest
form
and/
or
continuation
sheet
samples
to
USEPA,
if
requested.

(
e)
Typesetting
the
Manifest
Form
Subsequent
to
its
Approval
40
CFR
262.21(
i)
provides
that,
if
subsequent
to
its
approval
under
40
CFR
262.21(
e),
a
registrant
typesets
its
manifest
or
continuation
sheet
instead
of
using
the
electronic
file
of
the
forms
provided
by
USEPA,
it
must
submit
three
samples
of
the
manifest
or
continuation
sheet
to
the
registry
for
approval.
The
registrant
cannot
use
or
distribute
its
typeset
forms
until
USEPA
approves
them.

Data
Items
°
Three
samples
of
the
manifest
or
continuation
sheet.

Respondent
Activity
°
Submit
three
samples
of
the
manifest
or
continuation
sheet
to
the
registry
for
approval.

(
f)
Requesting
an
Exemption
40
CFR
262.21(
j)
provides
that
USEPA
may
exempt
a
registrant
from
the
requirement
to
submit
form
samples
under
40
CFR
262.21(
d)
or
262.21(
h)(
3)
if
the
Agency
is
persuaded
that
a
separate
review
of
the
registrant's
forms
would
serve
little
purpose
in
informing
an
approval
decision
(
e.
g.,
a
registrant
certifies
that
it
will
print
the
manifest
using
the
same
paper
type,
paper
weight,
ink
color
of
the
instructions,
and
binding
method
of
the
form
samples
approved
for
some
other
registrant).
A
registrant
may
request
an
exemption
from
USEPA
by
indicating
why
an
exemption
is
warranted.

Data
Item
°
Documentation
indicating
why
an
exemption
is
warranted.

Respondent
Activity
°
Submit
documentation
to
USEPA
indicating
why
an
exemption
is
warranted.

(
g)
Notifying
USEPA
of
a
Printing
Specification
Violation
40
CFR
262.21(
k)
requires
an
approved
registrant
to
notify
USEPA
by
phone
or
email
as
soon
as
it
becomes
aware
that
it
has
used
or
distributed
manifests
that
contain
duplicated
manifest
tracking
numbers.

Data
Item
°
Notification
of
duplicated
manifest
tracking
numbers.
USEPA­
OSWER
ICR
801.15
30
Dec
2004
18
Respondent
Activity
°
Notify
USEPA
of
duplicated
manifest
tracking
numbers.

(
h)
Revising
the
Approved
Manifest
if
Requested
by
USEPA
40
CFR
262.21(
l)
provides
that,
if,
subsequent
to
approval
of
a
registrant
under
40
CFR
262.21(
e),
USEPA
becomes
aware
that
the
registrant's
approved
form
does
not
satisfactorily
meet
the
print
specifications
in
40
CFR
262.21(
f),
USEPA
will
contact
the
registrant
and
require
modifications
to
the
form.

Data
Item
°
Revised
manifest
form
samples.

Respondent
Activity
°
Submit
revised
manifest
form
samples
to
USEPA,
if
requested.

(
i)
Responding
to
Suspension
and
Revocation
Procedures
40
CFR
262.21(
m)
provides
that
USEPA
may
suspend
and,
if
necessary,
revoke
printing
privileges
if
it
finds
that
the
registrant:
(
i)
has
deviated
from
its
application
approved
under
40
CFR
262.21(
c)
in
printing
the
form;
(
ii)
has
knowingly
used
or
distributed
forms
that
deviate
from
its
approved
form
samples
in
regard
to
paper
weight,
paper
type,
ink
color
of
the
instructions,
or
binding
method;
or
(
iii)
exhibits
a
continuing
pattern
of
behavior
in
using
or
distributing
manifests
that
contain
duplicate
manifest
tracking
numbers.
USEPA
will
send
a
warning
letter
to
the
registrant
that
specifies
the
date
by
which
it
must
come
into
compliance
with
the
requirements.
If
the
registrant
does
not
come
in
compliance
by
the
specified
date,
USEPA
will
send
a
second
letter
notifying
the
registrant
that
USEPA
has
suspended
or
revoked
its
printing
privileges.
An
approved
registrant
must
provide
information
on
its
printing
activities
to
USEPA
if
requested.

Data
Item
°
Information
requested
by
USEPA.

Respondent
Activity
°
Submit
information
if
requested
by
USEPA.

5B.
Generator
Requirements
The
1976
RCRA
statute,
as
well
as
regulations
promulgated
by
USEPA,
established
the
following
requirements
for
hazardous
waste
generators,
and
related
waste
handlers:
°
Large
Quantity
Generators
(
LQGs):
RCRA,
as
amended,
requires
USEPA
to
establish
the
"
use
of
a
manifest
system
and
any
other
reasonable
means
necessary
to
assure
that
all
such
hazardous
waste...
arrives
at"
the
designated
facility
(
Section
3002(
5)).
On
May
19,
1980,
USEPA
promulgated
regulations
calling
for
the
use
of
manifests
by
generators
of
greater
than
1,000
kilograms/
month
of
hazardous
waste,
thereby
establishing
the
manifest
system.
°
Small
Quantity
Generators
(
SQGs:
generators
of
between
100
and
1,000
kilograms/
month):
The
Hazardous
and
Solid
Waste
Amendments
of
1984
(
HSWA)
directed
USEPA
to
promulgate
standards
for
the
generation,
treatment,
and
disposal
of
hazardous
waste
produced
by
SQGs.
In
compliance
with
HSWA,
USEPA
promulgated
regulations
on
March
24,
1986,
that
require
SQGs
to
comply
with
the
manifest
requirements
of
40
CFR
262
subpart
B.
A
SQG
can
be
exempt
from
the
requirements
listed
in
this
section
when
its
waste
is
reclaimed
under
a
contractual
agreement
and
certain
other
conditions
are
met.
However,
the
SQG
must
maintain
records
of
the
agreement
for
at
least
three
years
after
termination
or
expiration
of
the
agreement,
as
required
by
40
CFR
262.20(
e)(
2).
°
Hazardous
Waste
Exporters:
On
August
8,
1986,
USEPA
promulgated
regulations
relating
to
the
export
of
hazardous
waste
out
of
the
US
to
supplement
the
1980
regulations.
40
CFR
262
subpart
E
sets
forth
special
manifesting
requirements
that
primary
exporters
must
meet
in
exporting
their
waste.

(
a)
Manifest
Completion
USEPA­
OSWER
ICR
801.15
30
Dec
2004
14
The
generator's/
offeror's
certification
in
Item
15
of
the
manifest
form
references
the
waste
minimization
certification
codified
at
40
CFR
262.27.

19
40
CFR
262.20
requires
generators
transporting,
or
offering
for
transportation,
hazardous
waste
for
off­
site
treatment,
storage,
or
disposal
to
prepare
a
manifest
(
EPA
Form
8700­
22)
and,
if
necessary,
continuation
sheets
(
EPA
Form
8700­
22A).
Generators
must
prepare
these
forms
in
accordance
with
40
CFR
262.20,
262.23,
262.54,
and
262.60,
as
appropriate,
as
well
as
the
instructions
in
the
appendix
to
40
CFR
262.

Data
Items

The
generator's
USEPA
ID
or
State
ID
number.
°
The
total
number
of
pages
used
to
complete
the
manifest.
°
The
emergency
response
phone
number.
°
The
manifest
tracking
number.


The
generator's
name
and
mailing
address.


The
generator's
phone
number.
°
The
generator's
site
address
(
if
different
than
mailing
address).


The
name
and
USEPA
ID
number
for
transporters.


The
designated
facility's
name
and
site
address.
°
The
designated
facility's
phone
number.


The
USEPA
ID
number
of
the
designated
facility.
°
The
USDOT
description
of
the
waste.


The
container
description
(
number
and
type).


The
total
quantity
of
each
waste
described.


The
unit
of
measure.
°
The
waste
codes
representing
the
waste.


Special
handling
instructions
and
additional
information.


The
generator's/
offeror's
certification.
14
°
For
primary
exporters
only:
The
primary
exporter
must
prepare
the
manifest
in
accordance
with
40
CFR
262.20
and
262.23,
except
as
provided
under
40
CFR
262.54(
a)
through
(
d):


In
lieu
of
the
site
name,
site
address
and
USEPA
ID
number
of
the
designated
permitted
facility,
enter
the
name
and
site
address
of
the
consignee.


In
lieu
of
the
name,
site
address,
and
USEPA
ID
number
of
a
permitted
alternate
facility,
enter
the
name
and
site
address
of
any
alternate
consignee.


In
the
International
Shipments
Block,
check
the
export
box
and
enter
the
point
of
exit
(
city
and
State)
from
the
US.
°
For
primary
importers
only:
The
primary
importer
must
prepare
the
manifest
in
accordance
with
40
CFR
262.20
&
262.23,
except
as
provided
in
40
CFR
262.60(
b)
and
(
d):


In
place
of
the
generator's
name,
address,
and
USEPA
ID
number,
use
the
name
and
address
of
the
foreign
generator
and
the
importer's
name,
address,
and
USEPA
ID
number.


In
place
of
the
generator's
signature
on
the
certification
statement,
the
US
importer
or
his
agent
must
sign
and
date
the
certification
and
obtain
the
signature
of
the
initial
transporter.


In
the
International
Shipment
Block,
check
the
import
box
and
enter
the
point
of
entry
(
city
and
State)
into
the
US.

Respondent
Activities

Complete
the
manifest
for
domestic,
export,
and
import
shipments.


Complete
continuation
sheet,
if
required.

(
b)
Compliance
with
State
Program
Requirements
Under
40
CFR
262.21(
g)(
2),
generators
must
determine
whether
the
consignment
State
regulates
any
additional
wastes
(
beyond
those
regulated
Federally)
as
hazardous
wastes
under
its
State
hazardous
waste
program.
Generators
must
also
determine
whether
the
consignment
State
or
generator
State
requires
the
generator
to
submit
any
copies
of
the
manifest
to
these
States.

Data
Item
°
Information
provided
by
the
State
on
its
manifest
program.
USEPA­
OSWER
ICR
801.15
30
Dec
2004
20
Respondent
Activities
°
Contact
the
consignment/
generator
State
if
needed
and
submit
any
copies
of
the
manifest
to
these
States,
as
applicable.

(
c)
Manifest
Transmittal
and
Recordkeeping
Generators
must
transmit
and
keep
records
of
the
manifest
in
accordance
with
40
CFR
262.23,
262.40,
262.44,
262.54
and
262.60,
as
appropriate.

Data
Items

A
generator
must
sign
and
give
copies
of
the
manifest
to
the
transporter
along
with
the
hazardous
waste
in
accordance
with
40
CFR
262.23(
a)
&
(
b),
and
retain
copies
of
the
manifest
in
accordance
with
40
CFR
262.23(
a)
&
262.40(
a).


For
shipments
of
hazardous
waste
within
the
US
solely
by
water
(
bulk
shipments
only),
the
generator,
as
required
by
40
CFR
262.23(
c),
must
send
three
copies
of
the
manifest
to
the
owner/
operator
of
the
designated
facility
or
the
last
water
transporter
to
handle
the
waste
in
the
US
if
exported
by
water.


For
rail
shipments
of
hazardous
waste
within
the
US
which
originate
at
the
site
of
generation,
the
generator,
as
required
under
40
CFR
262.23(
d),
must
send
at
least
three
copies
of
the
manifest
to
the
next
non­
rail
transporter,
the
designated
facility,
or
the
last
rail
transporter
to
handle
the
waste
in
the
US
if
exported
by
rail.
°
Exports:
Acknowledgment
of
Consent:
For
exports,
the
primary
exporter
must
provide
the
transporter
with
a
USEPA
Acknowledgment
of
Consent,
and
an
additional
copy
of
the
manifest
or
shipping
papers
for
delivery
to
the
US
Customs
official
at
the
point
the
hazardous
waste
exits
the
US,
as
required
by
40
CFR
262.54(
h)
and
(
i).
°
Reclamation
Agreements:
In
the
event
an
SQG's
waste
is
reclaimed
under
a
contractual
agreement
pursuant
to
40
CFR
262.20(
e)(
1),
the
SQG
must
retain
the
reclamation
agreement
for
at
least
three
years
from
the
date
of
termination
or
expiration
of
the
agreement,
as
required
by
40
CFR
262.20(
e)(
2).

Respondent
Activities

Sign
the
manifest
certification
and
obtain
the
signature
of
the
initial
transporter
and
date
of
acceptance
on
the
manifest
in
accordance
with
40
CFR
262.23(
a).


Keep
a
copy
of
the
manifest
and
give
the
remaining
copies
to
the
initial
transporter,
in
accordance
with
40
CFR
262.23(
a)
&
(
b).


Keep
a
copy
of
the
manifest
returned
from
the
designated
facility
for
at
least
three
years
from
the
date
the
waste
was
accepted
by
the
initial
waste
transporter,
in
accordance
with
40
CFR
262.40(
a)
or
262.44(
a).


For
shipments
solely
by
water,
send
three
copies
of
the
manifest,
dated
and
signed
in
accordance
with
40
CFR
262.23(
a),
to
the
designated
facility
or
the
last
water
transporter
to
handle
the
waste
in
the
US,
as
required
by
40
CFR
262.23(
c).
[
Note:
Copies
of
the
manifest
are
not
required
for
each
transporter.]


For
shipments
by
rail
originating
at
the
site
of
generation,
send
at
least
three
copies
of
the
manifest
to
the
next
non­
rail
transporter,
the
designated
facility,
or
the
last
rail
transporter
to
handle
the
waste
in
the
US,
as
required
by
40
CFR
262.23(
d).
°
Exports:
Acknowledgment
of
Consent:
Primary
exporters
must
provide
the
transporter
with
an
USEPA
Acknowledgment
of
Consent
and
an
additional
copy
of
the
manifest
or
shipping
papers
for
delivery
to
the
US
Customs
official
at
the
point
the
hazardous
waste
exits
the
US,
as
required
by
40
CFR
262.54(
h)
and
(
i).
°
Reclamation
Agreements:
An
SQG
operating
under
a
tolling
agreement
must
retain
a
copy
of
each
reclamation
agreement,
if
applicable,
for
at
least
three
years
after
the
termination
or
expiration
of
the
agreement,
as
required
by
40
CFR
262.20(
e)(
2).

(
d)
Undeliverable
Shipments
Generators
must
provide
instructions
to
the
transporter
on
how
to
deal
with
shipments
that
cannot
be
delivered
to
the
designated
or
the
alternate
TSDF.
For
shipments
that
a
transporter
is
unable
to
deliver
to
the
designated
facility
or
the
alternate
facility,
generators
must
designate
another
facility
or
instruct
the
transporter
to
return
the
waste,
as
required
by
40
CFR
262.20(
d)
and
262.54(
g)(
3).

Data
Item
USEPA­
OSWER
ICR
801.15
30
Dec
2004
21
°
Instructions
to
the
transporter
on
how
to
deal
with
shipments
that
cannot
be
delivered
to
the
designated
or
the
alternate
TSDF.

Respondent
Activity
°
For
shipments
that
a
transporter
is
unable
to
deliver
to
the
designated
facility
or
the
alternate
facility,
designate
another
facility
or
instruct
the
transporter
to
return
the
waste.

(
e)
Rejected
Waste
and
Container
Residues
USEPA
has
promulgated
regulations
at
40
CFR
262.34(
j)
to
improve
the
tracking
of
rejected
waste
and
container
residues.
USEPA
has
also
expanded
the
definition
of
"
designated
facility"
to
include
generators
that
receive
rejected
loads
or
container
residues
from
the
TSDF
designated
on
their
manifest
to
receive
the
waste.
It
is
important
to
clarify
the
procedures
that
generators
will
need
to
follow
for
receiving
and
managing
rejected
load
or
container
residue
shipments
sent
back
by
the
designated
TSDF.
These
regulations
will
improve
hazardous
waste
tracking,
while
placing
minimal
paperwork
burden
on
generators
(
i.
e.
generators
need
only
sign
the
form
accompanying
the
problem
shipment
delivered
to
them).
Under
40
CFR
262.34(
j),
a
generator
who
sends
a
shipment
of
hazardous
waste
to
a
designated
facility
with
the
understanding
that
the
designated
facility
can
accept
and
manage
the
waste
and
later
receives
that
shipment
back
as
a
rejected
load
or
residue
in
accordance
with
the
manifest
discrepancy
provisions
of
40
CFR
264.72
or
265.72
may
accumulate
the
returned
waste
on­
site,
as
specified.
Upon
receipt
of
the
returned
shipment,
the
generator
must
sign
the
manifest
that
accompanies
the
rejected
load
or
residue.

Data
Item

Complete
a
manifest.

Respondent
Activities
°
Sign
Item
18c
of
the
manifest,
if
the
transporter
returned
the
shipment
using
the
original
manifest.
°
Sign
Item
20
of
the
manifest,
if
the
transporter
returned
the
shipment
using
a
new
manifest.

(
f)
Exception
Reports:
Completion,
Submission,
and
Recordkeeping
(
f1)
Large
Quantity
Generators
USEPA's
May
19,
1988
RCRA
manifest
regulations
included
requirements
for
generators
to
prepare,
submit,
and
keep
records
of
exception
reports
(
40
CFR
262.42).
In
the
event
an
LQG
does
not
receive
a
copy
of
the
signed
manifest
from
the
designated
facility
owner/
operator
within
35
days
of
the
date
the
waste
was
accepted
by
the
initial
transporter,
the
LQG
must
contact
the
transporter
and/
or
the
owner/
operator
of
the
designated
facility
to
determine
the
status
of
the
hazardous
waste.
The
LQG
must
submit
an
exception
report
to
USEPA
if
he/
she
has
not
received
a
copy
of
the
signed
manifest
from
the
designated
facility
owner/
operator
within
45
days
of
the
date
the
waste
was
accepted
by
the
initial
transporter
and
must
retain
a
copy
of
the
exception
report
for
at
least
three
years
from
the
due
date
of
the
report,
in
accordance
with
40
CFR
262.42(
a)
and
262.40(
b).

Data
Item
°
An
exception
report
containing
the
following
data:
­­
A
legible
copy
of
the
manifest
for
which
the
generator
does
not
have
confirmation
of
delivery,
as
required
by
40
CFR
262.42(
a)(
2)(
i).
­­
A
cover
letter
signed
by
the
generator
or
his
authorized
representative
explaining
the
efforts
taken
to
locate
the
hazardous
waste
and
the
results
of
those
efforts,
as
required
by
40
CFR
262.42(
a)(
2)(
ii).

Respondent
Activities

Prepare
and
submit
a
signed
cover
letter
to
USEPA
explaining
the
generator's
efforts
to
locate
the
hazardous
waste
and
the
results
of
those
efforts,
along
with
a
legible
copy
of
the
manifest,
in
accordance
with
40
CFR
262.42(
a)(
2)(
i)
and
(
ii).


Keep
a
copy
of
each
exception
report,
as
required
by
40
CFR
262.40(
b).

(
f2)
Small
Quantity
Generators
USEPA­
OSWER
ICR
801.15
30
Dec
2004
22
EPA's
March
24,
1986
final
regulations
mandated
use
of
the
manifest
system
by
SQGs,
but
exempted
them
from
the
exception
report
requirements
applicable
to
LQGs.
On
June
6,
1986,
the
Environmental
Defense
Fund
(
EDF)
sued
in
the
US
Court
of
Appeals
for
the
reinstatement
of
the
exception
report
requirement.
Under
the
terms
of
the
settlement
agreement
negotiated
with
EDF,
the
Agency
agreed
to
propose
a
modified
exception
report
requirement
for
SQGs
and
to
take
comment
on
other
options
for
accomplishing
the
exception
reporting
purpose.
On
September
23,
1987,
USEPA
promulgated
regulations
calling
for
exception
reporting
by
SQGs.
These
regulations
are
similar
to
the
existing
requirements
for
LQGs,
except
that
the
SQG
is
not
required
to
contact
the
transporter
or
facility
owner/
operator
to
determine
the
waste's
disposition,
the
length
of
time
before
an
exception
report
is
required
is
60
days,
and
the
generator
need
only
note
on
the
manifest
that
he
has
not
received
confirmation
of
delivery
(
§
262.42).
In
the
event
an
SQG
does
not
receive
a
copy
of
the
signed
manifest
from
the
owner/
operator
of
the
designated
facility
within
60
days
of
the
date
the
waste
was
accepted
by
the
initial
transporter,
he/
she
must
submit
to
the
USEPA
Regional
Administrator
a
legible
copy
of
the
manifest
with
some
indication
that
he
has
not
received
confirmation
of
delivery,
in
accordance
with
40
CFR
262.42(
b).

Data
Item
°
A
legible
copy
of
the
manifest
with
some
indication
that
the
SQG
has
not
received
confirmation
of
delivery.

Respondent
Activity
°
Submit
a
legible
copy
of
the
manifest
with
some
indication
that
the
waste
has
not
been
delivered.

5C.
Transporter
Requirements
(
a)
Manifest
Completion,
Transmittal,
and
Recordkeeping
A
critical
part
of
the
manifest
system
is
the
use
of
multiple
copies
of
the
manifest
to
track
the
shipment
of
hazardous
waste
as
it
moves
from
the
generator
to
the
designated
TSDF
by
way
of
the
transporter.
Regulations
found
in
40
CFR
263
subpart
B
require
transporters
to
ensure
that
the
manifest
accompanies
the
hazardous
waste
during
transportation,
to
deliver
the
hazardous
waste
and
the
manifest
as
indicated
on
the
manifest,
and
to
keep
records
of
the
manifests.
Under
40
CFR
263.20
&
263.22,
a
SQG's
waste,
transported
following
a
reclamation
agreement,
can
be
exempt
from
the
manifest
requirements
of
the
section.
However,
the
transporter
is
required
to
record
waste
generator
data
information
on
a
log
or
shipping
paper
and
retain
a
copy
of
these
records,
as
required
by
40
CFR
263.20(
h).
40
CFR
263.20,
263.21
&
263.22
detail
the
completion,
transmittal,
and
recordkeeping
requirements
of
manifests
or
shipping
papers
for
hazardous
waste
transporters,
including
those
exporting
hazardous
waste
outside
the
US.
In
accordance
with
these
requirements,
transporters
must
complete
specified
parts
of
the
manifest
(
or
shipping
paper,
as
provided
in
40
CFR
263.20(
e)(
2)),
retain
a
copy
of
the
manifest
(
or
shipping
paper),
transmit
copies
to
specified
parties,
and
ensure
that
the
original
manifest
or
shipping
papers
accompany
the
waste
to
its
destination.

(
a1)
Hazardous
Waste
Transporters
(
except
as
exempted
by
40
CFR
263.20(
e)
and
(
f))

Except
for
certain
water
and
rail
transporters
exempted
under
40
CFR
263.20(
e)&(
f),
transporters
transporting
hazardous
waste
outside
the
US
(
40
CFR
263.20(
g))
and
transporters
transporting
hazardous
waste
pursuant
to
a
reclamation
agreement
(
40
CFR
263.20(
h))
&
263.20(
b),
(
c),(
d)
require
transporters
to
sign
and
date
the
manifest
acknowledging
acceptance
of
the
waste
from
the
generator
before
transporting
the
hazardous
waste.
Before
leaving
the
property,
the
transporter
must
return
or
transmit
a
signed
copy
of
the
manifest
to
the
generator.
In
addition,
the
transporter
must
ensure
that
a
copy
of
the
manifest
or
other
shipping
paper
accompanies
the
shipment
and
is
readily
available
and
recognizable.
A
transporter
who
delivers
a
hazardous
waste
to
another
transporter
or
to
the
designated
facility
must
obtain
the
date
of
delivery
and
the
signature
of
the
transporter
or
designated
facility;
retain
a
copy
in
accordance
with
40
CFR
263.22;
and
give
the
remaining
copies
of
the
manifest
to
the
accepting
transporter
or
designated
facility,
as
required
at
40
CFR
263.20(
d).

Data
Item

Complete
a
manifest
and/
or
shipping
paper.

Respondent
Activities

Sign
and
date
the
manifest,
as
required
by
40
CFR
263.20(
b).


Return
a
signed
copy
of
the
manifest
to
the
generator,
as
required
under
40
CFR
263.20(
b).
USEPA­
OSWER
ICR
801.15
30
Dec
2004
23

Ensure
that
the
manifest
(
or
other
shipping
paper)
accompanies
the
waste
to
its
destination,
as
required
by
40
CFR
263.20(
c).


In
delivering
the
hazardous
waste
and
manifest
to
another
transporter
or
to
the
designated
facility,
perform
the
following
activities,
as
required
by
40
CFR
263.20(
d):
­­
Obtain
the
date
of
delivery
and
signature
of
that
transporter
or
the
owner/
operator
of
the
facility
or
alternate
facility
designated
on
the
manifest,
pursuant
to
40
CFR
263.20(
d)(
1).
­­
Retain
a
copy
of
the
manifest
pursuant
to
40
CFR
263.22(
a).
­­
Give
remaining
copies
of
the
manifest
to
the
accepting
transporter
or
facility,
in
accordance
with
40
CFR
263.20(
d)(
3).

(
a2)
Water
(
Bulk
Shipment)
Transporters
Regulated
under
40
CFR
263.20(
e)

Water
(
bulk
shipment)
transporters
who
are
regulated
under
40
CFR
263.20(
e)
must
sign
and
date
the
manifest
upon
receipt
of
the
hazardous
waste;
must
ensure
that
a
shipping
paper
containing
the
generator,
waste,
and
facility
information,
and
a
USEPA
Acknowledgment
of
Consent
for
exports,
accompany
the
waste
during
transportation;
must
obtain
the
signature
of
the
facility
owner/
operator
on
the
manifest
or
shipping
paper;
and
must
retain
a
copy
of
the
manifest
or
shipping
paper
for
three
years.

Data
Items

Copies
of
the
manifest.


Copies
of
the
shipping
paper
containing
all
the
information
on
the
manifest
except
the
USEPA
ID
numbers,
the
generator
certification,
and
required
signatures,
as
required
under
40
CFR
263.20(
e).


A
USEPA
Acknowledgment
of
Consent
(
for
exporters
only),
as
required
by
40
CFR
263.20(
e)(
2).

Respondent
Activities

Obtain
the
date
of
delivery
and
signature
of
the
initial
water
transporter
on
the
manifest,
in
accordance
with
40
CFR
263.20(
e)(
4).


Forward
the
manifest
to
the
designated
facility,
in
accordance
with
40
CFR
263.20(
e)(
4).
°
Bulk
water
transporters
identified
under
40
CFR
263.20(
e)
must
perform
the
following
activities:


Ensure
that
the
shipping
paper
(
and
Acknowledgment
of
Consent,
for
exports)
accompanies
the
waste
to
its
destination,
as
required
by
40
CFR
263.20(
e)(
2).


If
the
delivering
(
water)
transporter,
obtain
the
date
of
delivery
and
signature
of
the
owner/
operator
of
the
designated
facility
on
either
the
manifest
or
shipping
paper,
as
required
by
40
CFR
263.20(
e)(
3).


If
the
initial
water
transporter,
sign
and
date
the
manifest
and
return
it
to
the
delivering
transporter
so
that
the
manifest
can
be
forwarded
to
the
designated
facility
owner/
operator,
as
required
by
40
CFR
263.20(
e)(
4).


Retain
a
copy
of
the
manifest
or
shipping
paper,
as
required
by
40
CFR
263.22(
b).

(
a3)
Rail
Transporters
Regulated
under
40
CFR
263.20(
f)

Under
40
CFR
263.20(
f)(
1),
initial
rail
transporters
must
sign
and
date
the
manifest
acknowledging
acceptance
of
the
hazardous
waste;
return
or
transmit
a
signed
copy
of
the
manifest
to
the
non­
rail
transporter;
and
forward
at
least
three
copies
of
the
manifest
to
the
next
non­
rail
transporter,
the
designated
facility,
if
the
shipment
is
delivered
to
that
facility
by
rail,
or
the
last
rail
transporter
designated
to
handle
the
waste
in
the
US;
and
retain
a
copy
of
the
manifest
and
rail
shipping
paper
in
accordance
with
40
CFR
263.22.
Rail
transporters
must
ensure
that
a
shipping
paper
containing
all
the
information
required
on
the
manifest
(
excluding
the
USEPA
ID
numbers,
generator
certification,
and
signatures)
and,
for
exports,
a
USEPA
Acknowledgment
of
Consent
accompanies
the
hazardous
waste
at
all
times,
as
required
by
40
CFR
263.20(
f)(
2).
When
delivering
hazardous
waste
to
the
designated
facility,
a
rail
transporter
must
obtain
the
date
of
delivery
and
signature
of
the
owner
or
operator
of
the
designated
facility
on
the
manifest,
or
a
signature
on
the
shipping
paper
(
if
the
manifest
has
not
been
received
by
the
facility)
and
retain
a
copy
of
the
manifest
or
signed
shipping
paper,
as
required
under
40
CFR
263.20(
f)(
3).
When
delivering
hazardous
waste
to
a
non­
rail
transporter,
a
rail
transporter
must
obtain
the
date
of
delivery
and
the
signature
of
the
next
non­
rail
transporter
on
the
manifest
and
retain
a
copy
of
the
manifest,
as
required
under
40
CFR
263.20(
f)(
4).
Before
accepting
hazardous
waste
from
a
rail
transporter,
a
non­
rail
transporter
must
sign
and
date
the
manifest
and
provide
a
copy
to
the
rail
transporter,
as
required
by
40
CFR
263.20(
f)(
5).
USEPA­
OSWER
ICR
801.15
30
Dec
2004
24
Data
Items

Complete
a
manifest.


A
shipping
paper
containing
all
the
information
on
the
manifest,
except
the
USEPA
ID
numbers,
the
generator
certification,
and
required
signatures.


A
USEPA
Acknowledgment
of
Consent
(
for
exports
only).

Respondent
Activities

When
accepting
waste
from
a
non­
rail
transporter,
sign
and
date
the
manifest,
as
required
by
40
CFR
263.20(
f)(
1)(
i)
and
return
or
transmit
a
signed
copy
of
the
manifest
to
the
non­
rail
transporter,
as
required
by
40
CFR
263.20(
f)(
1)(
ii).


Forward
at
least
three
copies
of
the
manifest
to
either
the
next
non­
rail
transporter,
the
designated
facility,
or
the
last
rail
transporter
designated
to
handle
the
waste
in
the
US,
as
required
by
40
CFR
263.20(
f)(
1)(
iii).


Ensure
a
shipping
paper
containing
all
the
information
required
on
the
manifest
excluding
the
USEPA
ID
number,
generator
certification,
and
signatures
(
and
for
exports
an
Acknowledgment
of
Consent)
accompanies
the
waste,
as
required
under
40
CFR
263.20(
f)(
2).


When
delivering
hazardous
waste
to
the
designated
facility
or
to
the
next
non­
rail
transporter,
obtain
the
signature
and
date
of
delivery
of
the
facility
or
non­
rail
transporter
on
the
manifest,
as
required
under
40
CFR
263.20(
f)(
3)(
i)
or
(
f)(
4)(
i).


Retain
a
copy
of
the
manifest
and/
or
rail
shipping
paper,
as
required
under
40
CFR
263.20(
f)(
1)(
iv),
263.20(
f)(
3)(
ii),
263.20(
f)(
4)(
ii)
and
263.22,
as
applicable.


Before
accepting
hazardous
waste
from
a
rail
transporter,
sign
and
date
the
manifest
and
provide
a
copy
to
the
rail
transporter,
as
required
under
40
CFR
263.20(
f)(
5).

(
a4)
Transporters
Who
Import
or
Export
Hazardous
Wastes
(
40
CFR
263.20(
g)
&
(
i))

Under
40
CFR
263.20(
g),
transporters
who
either
transport
hazardous
waste
into
(
import)
or
out
of
(
export)
the
US,
must
sign
and
date
the
manifest
to
indicate
the
date
that
the
shipment
arrived
(
import)
or
left
(
export)
the
US,
respectively;
retain
one
copy
in
accordance
with
40
CFR
263.22;
for
exports
return
a
signed
copy
to
the
generator
and
provide
a
copy
of
the
exported
waste
manifest
to
a
US
Customs
official
at
the
point
of
departure
from
the
US.
In
addition
for
exports,
the
transporter
also
must
ensure
that
a
copy
of
the
USEPA
Acknowledgment
of
Consent
accompanies
the
waste,
as
required
by
40
CFR
263.20(
a).

Data
Items

Complete
a
manifest
or
shipping
paper.


EPA
Acknowledgment
of
Consent.

Respondent
Activities

For
imports
and
exports,
sign
and
date
the
manifest
in
the
International
Shipments
block
to
indicate
the
date
that
the
shipment
entered
or
left
the
US,
respectively,
as
required
by
40
CFR
263.20(
g)(
1).


For
imports
and
exports,
retain
a
copy
of
the
manifest,
as
required
by
40
CFR
263.20(
g)(
2).


For
exports,
return
a
signed
copy
of
the
manifest
to
the
generator,
as
required
by
40
CFR
263.20(
g)(
3).
°
For
exports,
give
a
copy
of
the
manifest
to
a
US
Customs
official
at
the
point
of
departure
from
the
US,
as
required
by
40
CFR
263.20(
g)(
4).


For
exports,
ensure
that
copies
of
the
manifest
and
USEPA
Acknowledgment
of
Consent
accompanies
the
waste,
as
required
by
40
CFR
263.20(
a).

(
a5)
Transporters
Who
Transport
Hazardous
Waste
Pursuant
to
a
Reclamation
Agreement
(
263.20(
h))

40
CFR
263.20(
h)
provides
that
transporters
can
be
exempt
from
the
requirements
of
40
CFR
263.20
&
263.22
when
transporting
a
SQG's
waste
pursuant
to
a
reclamation
agreement
in
accordance
with
40
CFR
262.20(
e).
These
transporters
are
required
to
record
data
items
on
a
log
or
shipping
papers,
carry
the
record
to
the
reclamation
facility,
and
retain
these
records,
as
required
by
40
CFR
263.20(
h).

Data
Items

The
name,
address,
and
USEPA
ID
number
of
the
hazardous
waste
generator.


The
quantity
of
waste
accepted.
USEPA­
OSWER
ICR
801.15
30
Dec
2004
25

All
USDOT­
required
shipping
information.


The
date
the
waste
is
accepted.
Respondent
Activities

Record
the
waste
information
on
a
log
or
shipping
paper,
as
required
by
40
CFR
263.20(
h)(
2).


Carry
the
record
when
transporting
waste
to
the
reclamation
facility,
as
required
by
40
CFR
263.20(
h)(
3).


Retain
the
records
for
at
least
three
years
after
termination
or
expiration
of
the
agreement,
as
required
by
40
CFR
263.20(
h)(
4).

(
b)
Undeliverable
Shipments
Under
40
CFR
263.21(
a),
the
transporter
must
deliver
the
entire
quantity
of
hazardous
waste
which
he
has
accepted
from
a
generator
or
a
transporter
to
the
designated
facility
listed
on
the
manifest;
the
alternate
designated
facility,
the
next
designated
transporter;
or
the
place
outside
the
US
designated
by
the
transporter.
40
CFR
263.21(
b)(
1)
requires
that,
if
the
hazardous
waste
cannot
be
delivered
in
accordance
with
40
CFR
263.21(
a)
because
of
an
emergency
condition
other
than
rejection
of
the
waste
by
the
designated
facility,
then
the
transporter
must
contact
the
generator
for
further
directions
and
must
revise
the
manifest
according
to
the
generator's
instructions.

Data
Items

A
manifest
that
has
been
revised
according
to
the
generator's
instructions.

Respondent
Activities
°
Contact
the
generator
for
further
directions
and
revise
the
manifest
according
to
the
generator's
instructions.

(
c)
Rejected
Waste
and
Container
Residues
USEPA
has
promulgated
regulations
at
40
CFR
263.21
to
improve
the
tracking
of
rejected
waste
and
container
residues.
These
regulations
further
clarify
procedures
that
transporters
will
need
to
follow
when
dealing
with
rejected
waste
or
container
residue
shipments
sent
back
to
the
original
generator
or
to
an
alternate
TSDF.
Under
40
CFR
263.21(
b)(
2),
if
a
hazardous
waste
is
rejected
or
a
container
residue
is
identified
by
the
designated
facility
listed
on
the
manifest
while
the
transporter
is
on
the
facility's
premises,
then
the
transporter
must
comply
with
the
appropriate
procedures:
°
Partial
load
rejections:
The
transporter
must
obtain
the
facility's
signature
and
date,
the
manifest
tracking
number
of
the
new
form,
and
a
description/
indication
of
the
rejected
waste
in
the
discrepancy
block
on
the
original
manifest.
The
transporter
must
retain
this
copy
of
the
manifest
in
accordance
with
40
CFR
263.22
and
give
the
remaining
copies
to
the
designated
facility.
If
the
transporter
is
forwarding
the
shipment
to
the
alternate
facility
or
returning
it
the
generator,
the
transporter
must
obtain
the
new
manifest
for
the
shipment.
°
Full
load
rejections
or
container
residues:
The
transporter
must
obtain
the
original
manifest
that
includes
the
facility's
signature
and
date,
name
and
address
of
the
alternate
facility
or
generator,
and
a
description
of
the
rejected
load
or
container
residue
in
the
discrepancy
block
as
appropriate.
The
transporter
must
retain
this
copy
of
the
manifest
in
accordance
with
40
CFR
263.22
and
give
a
copy
to
the
facility.
If
the
original
manifest
is
not
used,
then
the
transporter
must
obtain
a
new
manifest
for
the
shipment.

Data
Item

Complete
a
manifest.

Respondent
Activities
°
For
partially
rejected
loads
made
while
the
transporter
is
on
site,
obtain
the
amended
manifest
from
the
facility,
keep
a
copy,
and,
if
receiving
the
rejected
waste,
obtain
the
new
manifest.
°
For
fully
rejected
loads
made
or
container
residues
identified
while
the
transporter
is
on
site,
obtain
the
original
manifest,
as
amended,
from
the
facility.

(
d)
Notification
of
Discharge
of
Hazardous
Waste
The
49
CFR
263
subpart
C
regulations
reference
USDOT
notification
requirements
for
hazardous
waste
transporters
responding
to
a
discharge
of
hazardous
waste
and
establish
requirements
for
water
(
bulk
shipment)
transporters
who
discharge
hazardous
waste,
similar
to
notification
requirements
for
oil
and
hazardous
substances
releases.
USEPA­
OSWER
ICR
801.15
30
Dec
2004
26
In
the
event
of
a
discharge
of
hazardous
waste
during
transportation,
40
CFR
263.30(
a)
requires
the
transporter
to
take
appropriate
immediate
action
to
protect
human
health
and
the
environment,
for
example,
notifying
local
authorities.
40
CFR
263.30(
c)
requires
an
air,
rail,
highway,
or
water
transporter
who
has
discharged
hazardous
waste
to
give
notice,
if
required
by
49
CFR
171.15,
to
NRC
and
to
report
in
writing
to
USDOT
as
required
by
49
CFR
171.16.
40
CFR
263.30(
d)
requires
a
water
(
bulk
shipment)
transporter
who
has
discharged
hazardous
waste
to
give
the
same
notice
as
required
by
33
CFR
153.203
for
oil
and
hazardous
substances,
if
not
already
required
under
33
CFR
153.203.
Water
(
bulk
shipment)
transporters,
as
soon
as
they
have
knowledge
of
any
discharge
of
hazardous
waste,
must
immediately
notify
NRC,
US
Coast
Guard,
as
required
by
33
CFR
153.203.
If
the
direct
reporting
to
the
NRC
is
not
practicable,
reports
may
be
made
to
the
US
Coast
Guard
or
USEPA
predesignated
OSC
for
the
geographic
area
where
the
discharge
occurs.
If
it
is
not
possible
to
notify
the
NRC
or
the
predesignated
OSC
immediately,
reports
may
be
made
immediately
to
the
nearest
US
Coast
Guard
unit,
provided
the
transporter
notifies
the
NRC
as
soon
as
possible.

Data
Item
°
Notification
of
a
discharge
of
hazardous
waste
Respondent
Activities

In
the
event
of
a
discharge
of
hazardous
waste
during
transportation,
the
transporter
must
take
appropriate
action
to
protect
human
health
and
the
environment,
including
notification
of
the
discharge
to
local
authorities,
as
required
by
40
CFR
263.30(
a).


Water
(
bulk
shipment)
transporters
must
immediately
notify
NRC
of
the
discharge
or,
if
it
is
not
practicable
to
notify
the
NRC,
a
predesignated
OSC
can
be
notified.
If
the
OSC
is
notified,
the
transporter
must
notify
the
NRC
of
the
discharge
as
soon
as
possible,
as
required
by
40
CFR
263.30(
d)
and
33
CFR
153.203.
[
Note:
This
ICR
does
not
include
hour
and
cost
burden
estimates
for
activities
associated
with
the
49
CFR
171
notification
requirements
referenced
in
40
CFR
263
since
Part
263
does
not
add
any
notification
requirements
to
those
already
in
49
CFR
171.]

5D.
Designated
Treatment,
Storage,
and
Disposal
Facility
Requirements
(
a)
Manifest
Completion,
Transmittal,
and
Recordkeeping
40
CFR
264.71(
a),(
b)
and
40
CFR
265.71(
a),(
b)
set
forth
completion,
transmittal,
and
recordkeeping
requirements
for
TSDFs
that
receive
hazardous
waste
accompanied
by
a
manifest
or
shipping
paper.
40
CFR
264.71(
a),(
b)
and
40
CFR
265.71(
a),(
b)
provide
that,
if
a
facility
receives
hazardous
waste
accompanied
by
a
manifest
(
or
shipping
paper,
for
certain
rail
or
water
shipments),
the
TSDF
or
his/
her
agent
must
sign
and
date
each
copy
of
the
manifest
to
certify
that
the
hazardous
waste
covered
by
the
manifest
was
received;
note
any
significant
discrepancies
in
the
manifest
on
each
copy;
immediately
return
to
the
transporter
a
signed
copy;
within
30
days
of
delivery
send
a
copy
of
the
manifest
to
the
generator;
and
retain
a
copy
for
at
least
three
years
from
the
date
of
delivery.

Data
Items

Copies
of
the
manifest
or
shipping
paper.

Respondent
Activities

Complete,
transmit,
and
retain
copies
of
the
manifest,
as
required
by
40
CFR
264.71(
a),(
b)
or
40
CFR
265.71(
a),(
b)
and
the
manifest
instructions:
­­
Enter
the
name
of
the
person
accepting
the
waste
and
sign
and
date
each
copy
of
the
manifest
(
or
shipping
paper,
if
applicable).
­­
Complete
the
management
method
codes.
­­
Note
any
discrepancies
(
as
defined
in
40
CFR
264.72(
a))
on
each
copy
of
the
manifest
(
or
shipping
paper,
if
applicable).
­­
Immediately
give
the
transporter
at
least
one
copy
of
the
manifest
(
or
shipping
paper).
­­
Within
30
days
of
delivery,
send
a
copy
of
the
manifest
(
or
shipping
paper)
to
the
generator.
 
Imported
wastes:
Within
30
days
of
delivery,
the
receiving
TSDF
must
mail
a
final
signed
copy
of
the
imported
waste
manifest
to
EPA's
International
Compliance
Assurance
Division.
­­
Retain
a
copy
of
the
manifest
(
or
shipping
paper)
for
at
least
three
years
from
the
date
of
delivery.
[
Note:
Although
the
noting
of
manifest
or
shipping
paper
discrepancies
is
mentioned
above,
it
is
burdened
in
the
subsection
entitled
"
Discrepancy
Reports."]
USEPA­
OSWER
ICR
801.15
30
Dec
2004
27
USEPA­
OSWER
ICR
801.15
30
Dec
2004
28
(
b)
Compliance
with
State
Program
Requirements
Under
40
CFR
264.71(
e)
and
40
CFR
265.71(
e),
TSDFs
must
determine
whether
the
consignment
State
for
a
shipment
regulates
any
additional
hazardous
wastes
(
beyond
those
regulated
Federally).
TSDFs
must
also
determine
whether
the
consignment
State
or
generator
State
requires
the
facility
to
submit
any
copies
of
the
manifest
to
these
States.

Data
Item
°
Information
provided
by
the
State
on
its
manifest
program.

Respondent
Activities
°
Contact
the
consignment/
generator
State
if
needed
and
submit
any
copies
of
the
manifest
to
these
States,
as
applicable.

(
c)
Discrepancy
Reports
The
40
CFR
264
&
265
subpart
E
regulations
also
require
TSDFs
to
note
and
potentially
report
discrepancies
(
40
CFR
264.71&
264.72;
265.71
&
265.72),
and
make
records
and
reports
available
to
USEPA
(
40
CFR
264.74
&
264.77;
265.74
&
265.77).
40
CFR
264.72
and
265.72
provide
that,
upon
discovering
a
significant
discrepancy,
TSDFs
must
attempt
to
reconcile
the
discrepancy
with
the
waste
generator
or
transporter.
If
the
discrepancy
is
not
resolved
within
15
days
after
receiving
the
waste,
the
owner/
operator
must
immediately
submit
to
USEPA
a
copy
of
the
manifest
or
shipping
paper
in
question,
as
well
as
a
letter
describing
the
discrepancy
and
attempts
to
reconcile
it.

Data
Items

A
copy
of
the
manifest
or
shipping
paper
in
question.
°
A
letter
describing
the
manifest
discrepancy
and
the
facility's
efforts
to
reconcile
it.

Respondent
Activities
°
Attempt
to
reconcile
any
discrepancies,
as
required
by
40
CFR
264.72(
c)
or
265.72(
c).
°
Prepare
and
submit
a
letter
to
USEPA
describing
the
discrepancy
and
attempts
to
reconcile
it,
along
with
a
copy
of
the
manifest
or
shipping
paper
at
issue,
as
required
by
40
CFR
264.72(
c)
or
265.72(
c).

(
d)
Rejected
Waste
and
Container
Residues
40
CFR
264.72
and
40
CFR
265.72
provide
that
the
TSDF
must
forward
rejected
waste
or
container
residues
to
an
alternate
facility
that
can
accept
the
waste.
If
the
TSDF
is
unable
to
locate
an
alternate
facility
to
take
the
waste,
then
the
TSDF
may
return
the
shipment
to
the
original
generator.
40
CFR
264.72(
d)
through
(
g)
and
40
CFR
265.72(
d)
through
(
g)
describe
manifest
procedures
for
TSDFs
that
originate
a
rejected
waste
or
container
residue.

(
d1)
Rejection
of
Waste
after
the
Transporter
Leaves
the
Facility
For
full
or
partial
load
rejections
and
residues
that
are
to
be
sent
off
site
to
an
alternate
facility
or
back
to
the
generator
after
the
transporter
has
left
the
facility,
the
facility
is
required
to
prepare
a
new
manifest,
as
required
by
40
CFR
264.72(
d),
(
e)(
1)­(
6),
or
(
f)(
1)­(
6)
or
40
CFR
265.72(
d),
(
e)(
1)­(
6),
or
(
f)(
1)­(
6).
In
addition,
if
a
facility
rejects
a
waste
or
identifies
a
container
residue
that
exceeds
the
quantity
limits
for
"
empty"
containers
set
forth
in
40
CFR
261.7(
b)
after
it
has
signed,
dated,
and
returned
a
copy
of
the
manifest
to
the
transporter,
the
facility
must
comply
with
40
CFR
264.72(
g)
or
265.72(
g).
The
facility
must
amend
its
copy
of
the
manifest
to
indicate
the
rejected
wastes
or
residues
in
the
discrepancy
space
of
the
amended
manifest.
The
facility
must
also
copy
the
manifest
tracking
number
from
Item
4
of
the
new
manifest
to
the
Discrepancy
space
of
the
amended
manifest,
and
must
re­
sign
and
date
the
manifest
to
certify
to
the
information
as
amended.
The
facility
must
retain
the
amended
manifest
for
at
least
three
years
from
the
date
of
amendment,
and
must
within
30
days,
send
a
copy
of
the
amended
manifest
to
the
delivering
transporter
and
to
the
generator.

Data
Items
°
Instructions
provided
by
the
generator.


Copy
of
the
original
manifest
and/
or
shipping
paper.


Copy
of
a
new
manifest
and/
or
shipping
paper.
USEPA­
OSWER
ICR
801.15
30
Dec
2004
29
Respondent
Activities

Contact
the
generator
to
obtain
the
generator's
instructions
for
forwarding
the
waste
to
another
facility
that
can
manage
the
waste,
as
required
by
40
CFR
264.72(
d)
or
265.72(
d).
°
Prepare
a
new
manifest
for
rejected
loads
or
container
residues
sent
to
the
alternate
designated
facility
or
back
to
the
generator:
­­
Write
the
facility's
USEPA
ID,
name,
and
address
in
the
appropriate
blocks
of
the
new
manifest
(
i.
e.
Items
1
and
5),
as
required
by
40
CFR
264.72(
e)(
1)
or
(
f)(
1)
or
265.72(
e)(
1)
or
(
f)(
1).
­­
Write
the
name
of
the
alternate
designated
facility/
initial
generator
and
the
facility's/
generator's
USEPA
ID
number
in
the
designated
facility
block
(
Item
8)
of
the
new
manifest,
as
required
by
40
CFR
264.72(
e)(
2)
or
(
f)(
2)
or
265.72(
e)(
2)
or
(
f)(
2).
­­
Copy
the
manifest
tracking
number
found
in
Item
4
of
the
old
manifest
to
the
Special
Handling
and
Additional
Information
Block
of
the
new
manifest,
and
indicate
that
the
shipment
is
a
residue
or
rejected
waste
from
the
previous
shipment,
as
required
by
40
CFR
264.72(
e)(
3)
or
(
f)(
3)
or
265.72(
e)(
3)
or
(
f)(
3).
­­
Copy
the
manifest
tracking
number
found
in
Item
4
of
the
new
manifest
to
the
manifest
reference
number
line
in
the
Discrepancy
Block
of
the
old
manifest
(
Item
18a),
as
required
by
40
CFR
264.72(
e)(
4)
or
(
f)(
4)
or
265.72(
e)(
4)
or
(
f)(
4).
­­
Write
the
USDOT
description
for
the
rejected
load
or
the
residue
in
the
Item
9
(
USDOT
Description)
of
the
new
manifest
and
write
the
container
types,
quantity,
and
volume(
s)
of
waste,
as
required
by
40
CFR
264.72(
e)(
5)
or
(
f)(
5)
or
265.72(
e)(
5)
or
(
f)(
5).
­­
Sign
the
Generator's/
Offeror's
Certification
to
certify,
as
the
offeror
of
the
shipment,
that
the
waste
has
been
properly
packaged,
marked
and
labeled
and
is
in
proper
condition,
as
required
by
40
CFR
264.72(
e)(
6)
or
(
f)(
6)
or
265.72(
e)(
6)
or
(
f)(
6).


Amend
the
facility's
copy
of
the
manifest
to
indicate
the
rejected
wastes
or
residues
in
the
discrepancy
space
of
the
amended
manifest,
as
required
by
40
CFR
264.72(
g)
or
265.72(
g).
°
Copy
the
manifest
tracking
number
from
Item
4
of
the
new
manifest
to
the
Discrepancy
space
of
the
amended
manifest,
as
required
by
40
CFR
264.72(
g)
or
265.72(
g).
°
Re­
sign
and
date
the
manifest,
as
required
by
40
CFR
264.72(
g)
or
265.72(
g).
°
Retain
the
amended
manifest
for
at
least
three
years
from
the
date
of
the
amendment,
as
required
by
40
CFR
264.72(
g)
or
265.72(
g).
°
Within
30
days,
send
a
copy
of
the
amended
manifest
to
the
delivering
transporter
and
to
the
generator,
as
required
by
40
CFR
264.72(
g)
or
265.72(
g).

(
d2)
Rejection
of
Waste
while
the
Transporter
Remains
Present
at
the
Facility
For
container
residues
and
full
load
rejections
that
are
made
while
the
transporter
remains
present
at
the
facility,
the
facility
may
forward
the
shipment
to
the
alternate
facility
or
return
the
shipment
to
the
generator
using
the
original
manifest,
as
specified
in
40
CFR
264.72(
e)(
7)
or
(
f)(
7)
or
40
CFR
265.72(
e)(
7)
or
(
f)(
7).

Data
Item

Copy
of
the
original
manifest
and/
or
shipping
paper.

Respondent
Activities
°
Contact
the
generator
to
obtain
the
generator's
instructions
for
forwarding
the
waste
to
another
facility
that
can
manage
the
waste,
as
required
by
40
CFR
264.72(
d)
or
265.72(
d).
°
Complete
Item
18a
and
18b
of
the
original
manifest,
as
applicable,
by
supplying
the
information
on
the
next
destination
facility
or
the
generator
in
the
Alternate
Facility
space.
°
Retain
a
copy
of
the
manifest.
°
Give
the
remaining
copies
back
to
the
transporter.

(
e)
Unmanifested
Waste
Report:
Completion
and
Submission
Pursuant
to
40
CFR
264.76
and
265.76,
if
the
TSDF
accepts
a
hazardous
waste
for
treatment,
storage,
or
disposal
from
any
off­
site
source
without
an
accompanying
manifest
or
a
shipping
paper
as
described
in
40
CFR
263.20(
e)(
2),
and
the
waste
is
not
excluded
from
the
manifest
requirement,
the
facility
owner/
operator
must
prepare
and
submit
a
letter
to
USEPA.
USEPA­
OSWER
ICR
801.15
30
Dec
2004
30
Data
Items

The
USEPA
ID
number,
name,
and
address
of
facility.


The
date
the
facility
received
the
waste.


The
USEPA
ID
number,
name,
and
address
of
generator
and
transporter,
if
available.


A
description
and
quantity
of
each
unmanifested
hazardous
waste
the
facility
received.


The
method
of
treatment,
storage,
or
disposal
for
each
hazardous
waste.


The
certification
signed
by
the
owner/
operator
of
the
facility
or
his
authorized
representative.


A
brief
explanation
of
why
the
waste
was
unmanifested,
if
known.

Respondent
Activities:


Prepare
and
submit
to
USEPA
a
letter
of
the
unmanifested
waste
within
15
days
after
receiving
the
waste.
USEPA­
OSWER
ICR
801.15
30
Dec
2004
31
6.
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY
&
INFORMATION
MANAGEMENT
The
following
subsections
discuss
how
USEPA
will
collect
the
information,
what
activities
USEPA
will
perform
once
the
information
has
been
received,
and
how
USEPA
will
manage
the
information
it
collects
under
the
manifest
system.
The
subsections
also
include
a
discussion
of
how
the
information
collection
requirements
will
affect
small
entities.

6A.
Agency
Activities
The
Agency
activities
associated
with
the
manifest
requirements
include
the
review
of
exception
reports,
discrepancy
reports,
and
unmanifested
waste
reports.
The
Agency
reviews
these
reports
to
identify
potentially
non­
compliant
or
otherwise
unresolved
activities
that
warrant
Agency
attention.
For
example,
upon
receipt
of
an
exception
report,
the
Agency
may
conduct
a
follow­
up
investigation
to
assist
the
generator
in
locating
the
shipment.
The
Agency
keeps
these
reports
on
file.
In
addition,
USEPA
requires
manifest
form
printers
to
register
with
USEPA,
as
provided
under
40
CFR
262.21.
The
Agency
will
need
to
review,
process,
and
keep
records
of
the
data
submitted.
Note
that,
as
provided
under
the
regulations,
manifests,
shipping
papers,
contractual
agreements,
and
reclamation
agreements
are
not
formally
submitted
to
USEPA,
but
must
be
kept
on
file
at
the
generator's,
transporter's
or
TSDF's
location
and
made
available
to
USEPA
upon
request.
Accordingly,
this
analysis
does
not
include
Agency
activities
associated
with
review
of
these
documents.

6B.
Collection
Methodology
&
Management
Under
the
registry,
USEPA
will
collect
registrants'
initial
applications
under
40
CFR
262.21(
b)
through
the
regular
mail,
although
some
registrants
may
voluntarily
choose
to
send
them
by
certified
mail.
USEPA
will
examine
each
application
to
ensure
that
the
registrant
takes
appropriate
steps
to
control
its
tracking
numbers
and
print
a
quality
manifest.
USEPA
will
then
request
form
samples
from
the
registrant
through
the
mail.
USEPA
will
evaluate
each
registrant's
form
samples
to
ensure
they
satisfy
the
print
specifications
at
40
CFR
262.21(
f).
USEPA
will
then
keep
the
forms
on
file
for
future
reference.
USEPA
will
post
the
name,
manifest
tracking
number
suffix,
and
contact
information
of
each
approved
registrant
on
its
web
site,
so
that
the
general
public
is
aware
of
who
the
approved
registrants
are,
what
suffixes
have
been
approved,
and
how
to
contact
registrants
for
forms.
USEPA
collects
reports
submitted
by
waste
handlers
under
the
manifest
system
(
e.
g.,
exception
reports
and
discrepancy
reports)
through
the
regular
mail,
although
some
waste
handlers
may
voluntarily
choose
to
send
them
by
certified
mail.
USEPA
reviews
the
reports
to
understand
the
situation
at
issue
and
take
follow
up
action
as
needed.
USEPA
keeps
the
files
on
record
for
future
reference.

6C.
Small
Entity
Flexibility
The
current
regulations
require
both
large
and
small
quantity
generators
of
hazardous
waste
to
use
the
manifest
to
track
shipments
of
hazardous
waste.
However,
the
Agency
has
found
that
most
small
businesses
do
not
generate
hazardous
waste
either
at
all
or
in
large
enough
quantities
to
make
them
subject
to
regulation
and,
therefore,
are
not
affected
by
the
manifest
requirements.
Generators
of
less
than
100
kg/
month
(
conditionally
exempt
small
quantity
generators)
are
exempted
from
manifest
requirements.
Also,
USEPA
has
exempted
from
the
manifest
requirements
universal
wastes
(
i.
e.,
batteries,
mercury
thermostats,
lamps,
and
pesticides,
as
specified),
spent
lead­
acid
batteries
going
for
recycling,
and
used
oil
being
recycled
or
burned
for
energy
recovery.

(
1)
Contractual
Reclamation
Agreements
A
small
quantity
generator
(
SQG)
is
exempt
from
the
manifest
requirements
when
his
hazardous
waste
is
reclaimed
under
a
contractual
agreement,
and
he
complies
with
limited
requirements,
including
recordkeeping
of
the
contractual
agreement,
as
required
by
40
CFR
262.20(
e)(
2).

(
2)
Exception
Reports
The
exception
report
requirements,
under
40
CFR
262.42,
for
SQGs
are
less
stringent
than
those
for
large
quantity
generators
(
LQGs).
A
SQG
is
only
required
to
submit
to
USEPA
a
legible
copy
of
the
manifest
with
some
indication
he/
she
has
not
received
confirmation
of
delivery
and
has
60
days
to
fulfill
this
requirement.
LQGs,
on
the
other
hand,
are
required
to
contact
the
transporter
or
facility
owner/
operator
if
he/
she
has
not
received
a
copy
of
the
manifest
within
35
days.
In
addition,
if
45
days
have
passed
and
the
LQG
still
has
not
received
a
signed
copy
of
the
manifest,
he/
she
must
submit
a
copy
of
the
manifest
as
USEPA­
OSWER
ICR
801.15
30
Dec
2004
32
well
as
a
cover
letter
explaining
the
generator's
efforts
to
locate
the
hazardous
waste.
Hence,
the
exception
report
requirements
for
SQGs
are
not
as
burdensome.

6D.
Collection
Schedule
(
1)
Registry
Document
Collection:
Registrant
Organizations
Before
printing
the
manifest
for
use
or
distribution,
registrants
must
submit
an
initial
application,
three
fully
assembled
manifests,
and
a
description
of
the
form
samples
to
USEPA.
USEPA
will
either
approve
the
registrant
to
print
the
forms,
or
request
modification
to
the
application
and/
or
samples
before
approval.
In
addition,
registrants
that
would
like
to
use
a
new
tracking
number
suffix,
change
the
printing
specifications
of
their
manifest,
use
a
new
printer,
or
typeset
their
manifest
subsequent
to
USEPA
approval
to
print
the
manifest
must
submit
additional
documentation
(
e.
g.,
proposed
suffix,
manifest
samples,
brief
description
of
the
new
printer's
qualifications
to
print
the
manifest),
as
specified.
Before
an
approved
registrant
can
change
its
form
in
regard
to
paper
type,
paper
weight,
ink
color
of
the
instructions,
or
binding
method,
or
before
using
a
new
printer,
it
must
seek
USEPA
approval
by
submitting
new
form
samples
and,
if
applicable,
a
description
of
the
new
printer.
Note,
however,
that
a
registrant
may
request
an
exemption
from
the
requirement
to
submit
form
samples
if
the
Agency
is
persuaded
that
a
separate
review
of
the
registrant's
forms
would
serve
little
purpose
in
informing
an
approval
decision.
Any
approved
registrant
wanting
to
update
any
information
provided
in
its
application
must
revise
the
application
and
submit
it
to
USEPA,
along
with
an
indication
or
explanation
of
the
update,
as
soon
as
practicable
after
the
change
occurs.
Finally,
an
approved
registrant
must
notify
USEPA
by
phone
or
email
as
soon
as
it
becomes
aware
that
it
has
duplicated
manifest
tracking
numbers
on
forms
that
have
been
used
or
distributed.
The
registrant
must
also
provide
information
on
its
printing
activities,
if
requested
by
USEPA.

(
2)
Manifest
and
Other
Document
Collection:
Generators,
Transporters,
and
TSDFs
Since
copies
of
manifests,
shipping
papers,
contractual
agreements,
and
reclamation
agreements
are
kept
at
the
generator's,
transporter's
or
TSDF's
location
and
not
normally
submitted
to
USEPA,
discussion
of
a
collection
schedule
is
not
applicable.

(
3)
Exception
Reports
Collection:
Generators
LQGs
must
submit
exception
reports
to
USEPA
within
45
days
of
the
date
the
waste
was
accepted
by
the
initial
transporter,
if
he
or
she
has
not
received
a
copy
of
the
manifest
signed
by
the
TSDF.
SQGs
must
submit
an
abbreviated
version
of
an
exception
report
to
USEPA
within
60
days.

(
4)
Manifests
Returned
to
Generators:
Designated
TSDFs
Designated
TSDFs
must
return
a
signed
and
dated
copy
of
the
manifest
to
the
generator
within
30
days
after
delivery
of
the
waste.

(
5)
Discrepancy
and
Unmanifested
Waste
Report
Collection:
Designated
TSDFs
Designated
TSDFs
must
submit
discrepancy
reports
and
unmanifested
waste
reports
to
USEPA
within
15
days
of
delivery
of
the
waste
to
the
TSDF.
USEPA­
OSWER
ICR
801.15
30
Dec
2004
33
7.
ESTIMATE
OF
BURDEN
HOURS
&
COST
The
attached
spreadsheet
Exhibits
1
to
19
present
USEPA's
estimates
of
burden
hours
and
associated
costs
for
all
the
information
collection
requirements
covered
in
this
ICR.
The
burden
estimates
for
each
activity
presented
in
spreadsheet
Exhibits
1
through
18
include
the
burden
hours
(
total
and
by
labor
type)
per
respondent,
as
well
as
the
overall
burden
hours
for
all
respondents.
Associated
annual
costs
for
all
paperwork
burden
activities
covered
in
this
ICR
include
annual
labor,
capital,
and
operation
and
maintenance
(
O&
M)
costs.
According
to
the
1995
Paperwork
Reduction
Act,
"
burden"
is
defined
as
follows:

"
The
term
`
burden'
means
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
or
provide
information
to
or
for
a
Federal
agency,
including
the
resources
expended
for:
(
a)
reviewing
instructions;
(
b)
acquiring,
installing,
and
utilizing
technology
and
systems
(
c)
adjusting
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
(
d)
searching
data
sources;
(
e)
completing
and
reviewing
the
collection
of
information;
and
(
f)
transmitting
or
otherwise
disclosing
the
information."
(
PRA
Section
3502(
2)).

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.
Therefore,
OMB
Control
No.
must
appear
on
the
front
page
of
the
manifest
form
(
EPA
form
8700­
22)
and
continuation
sheet
(
EPA
Form
8700­
22a).
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
and
48
CFR
chapter
15.
Additionally,
OMB
requires,
if
appropriate,
that
the
expiration
date
appear
on
the
front
page
of
an
OMB­
approved
form.
EPA
believes
it
is
inappropriate
to
include
the
expiration
date
on
the
manifest
form
and
continuation
sheet,
because
the
format
and
appearance
of
these
forms
will
not
be
affected
by
the
information
collection
renewal
process
for
this
ICR,
which
generally
will
occur
every
three
years
before
the
expiration
date.
Any
future
revisions
to
the
manifest
form
and
continuation
sheet
would
require
a
formal
rulemaking
process
(
e.
g.,
ANPRM
and
final
action),
including
a
revised
ICR
supporting
that
rulemaking.
Therefore,
the
manifest
form
and
continuation
sheet
do
not
include
an
expiration
date.

7A.
Labor
Wage
Rates
(
7A.
1)
Respondent
Labor:

EPA
estimates
an
average
hourly
respondent
labor
cost
(
overhead
and
fringe
benefits
loaded
wage
rates):
°
$
114.04
for
legal
staff
°
$
89.44
for
managerial
staff
°
$
58.54
for
technical
staff
°
$
30.62
for
clerical
staff.
These
respondent
labor
costs
were
obtained
from
the
previously
approved
RCRA
Manifest
ICR
801.14,
and
updated
to
year
2004
levels
using
Employment
Cost
Indexes
developed
by
the
US
Bureau
of
Labor
Statistics.

(
7A.
2)
Agency
Labor:

USEPA
estimates
the
Agency
hour
and
cost
burden
associated
with
the
new
information
collection
requirements
covered
in
this
ICR
in
Exhibit
19.
Based
on
the
General
Schedule
(
GS)
Salary
Table
2004,
USEPA
estimates
the
following
average
hourly
labor
costs
(
overhead
and
fringe
benefit
loaded
wage
rates):
°
$
66.26
for
legal
staff
(
GS­
15,
Step
1)
°
$
47.66
for
managerial
staff
(
GS­
13,
Step
1)
°
$
33.44
for
technical
staff
(
GS­
11,
Step
1)
°
$
20.34
for
clerical
staff
(
GS­
06,
Step
1).
To
derive
these
hourly
estimates,
USEPA
multiplied
the
basic
hourly
rates
by
the
standard
government
overhead
factor
of
1.6.

7B.
Respondent
Capital
Costs
Capital
costs
usually
include
any
produced
physical
good
needed
to
provide
the
needed
information,
such
as
machinery,
computers,
and
other
equipment.
For
this
ICR,
USEPA
estimates
that
respondents
will
incur
capital
costs
associated
with
the
purchase
of
file
cabinets,
estimated
by
the
following
steps:
USEPA­
OSWER
ICR
801.15
30
Dec
2004
15
File
cabinet
cost
based
on
the
Feb
2004
advertised
price
for
a
Hon
600
Series
36"
Wide
5­
drawer
lateral
file
from
http://
www.
staples.
com
34
°
Annual
manifest
copies
for
file
storage:
Under
the
manifest
system,
generators,
transporters,
and
designated
TSDFs
must
keep
copies
of
manifests
and
other
manifest­
related
documents
for
a
period
of
three
years
(
the
RCRA
manifest
is
printed
as
a
six­
copy
form).
In
addition,
as
of
2001,
34
state
governments
collect
at
least
one
completed
manifest
copy
representing
76%
of
annual
manifests,
and
some
states
collect
two
copies,
both
initial
and
final
(
source:
USEPA­
OSW
"
Economics
Background
Document"
for
the
final
rule).
Thus,
at
any
given
time
during
the
effective
period
of
this
ICR,
the
hazardous
waste
industry
and
state
governments
are
keeping
about
four
copies
of
three
years'
worth
of
RCRA
manifests:
[(
1,762,726
manifests/
year)
x
(
3
years
retention)
x
(
4
copies/
manifest)]
=
21,152,712
copies/
year
°
Number
of
file
cabinets
needed:
USEPA
estimates
that
a
standard­
size,
office
five­
drawer,
lateral
file
cabinet
holds
16,000
pages
and
costs
$
640
each.
15
Thus,
for
storing
copies
of
RCRA
manifests,
waste
handlers
would
need
to
purchase
the
following
number
of
file
cabinets
each
year:
[(
21,152,712
manifest
copies/
year)
/
(
16,000
copies/
file
cabinet)]
=
1,322
file
cabinets/
year
[(
1,322
file
cabinets/
year)
x
($
640/
cabinet)]
=
$
846,080/
year
7C.
Respondent
O&
M
Costs
O&
M
costs
are
those
costs
associated
with
a
paperwork
requirement
incurred
continually
over
the
life
of
the
ICR.
They
are
defined
by
the
Paperwork
Reduction
Act
of
1995
as
"
the
recurring
dollar
amount
of
costs
associated
with
O&
M
or
purchasing
services."
For
this
ICR,
O&
M
costs
include:

°
Mailing
costs:
USEPA
estimates
that
respondents
will
incur
a
cost
of
$
0.38
to
mail
a
one­
ounce
package
($
0.37
for
postage
and
$
0.01
for
standard­
size
envelope).
USEPA
also
estimates
that
respondents
will
incur
a
cost
of
$
3.64
for
mailing
a
larger
package
(
i.
e.,
a
five­
ounce
package)
by
certified
mail
($
1.29
for
postage,
$
2.30
for
the
certified­
mail
fee,
and
$
0.05
for
a
manila
envelope).
°
Photocopying
costs:
USEPA
estimates
that
respondents
will
incur
a
cost
of
$
0.10
for
each
photocopy
they
make.
°
Long
distance
telephone
call
costs:
USEPA
estimates
that
respondents
will
incur
a
cost
of
$
2.00
for
each
long
distance
telephone
call
they
make.
°
Printing
cost
for
sample
manifests:
USEPA
estimates
that
respondents
will
incur
a
cost
of
$
500
for
each
set
of
manifest
form
samples.
These
respondents
are
expected
to
contract
with
a
printing
company.
Hence,
the
fee
of
$
500
is
considered
a
lump­
sum
cost.

These
O&
M
costs
are
shown
in
Exhibits
1
through
19
for
all
applicable
respondent
activities.

7D.
Itemized
Estimates
of
Burden
Hours
and
Costs
Based
on
the
labor
wage
rates
and
capital
and
O&
M
cost
assumptions
presented
above,
the
attached
spreadsheet
Exhibits
1
to
18
present
USEPA's
estimates
of
respondents'
burden
hour
and
costs
associated
with
all
the
requirements
covered
in
this
ICR.
Exhibit
19
presents
USEPA's
estimate
of
Agency
burden.

(
a)
Registrant
Organization
Requirements
(
a1)
Reading
the
Regulations
Exhibit
1
presents
the
total
annual
hour
and
cost
burden
to
registrant
organizations
in
reading
the
manifest
regulations
at
40
CFR
262.21.
USEPA
expects
that
on
average,
14
registrant
organizations
will
read
40
CFR
262.21
regulations
each
year.

(
a2)
Applying
to
the
Registry
USEPA
estimates
that
each
year,
14
entities
will
register
with
USEPA
to
print
their
own
forms.
As
shown
in
Exhibit
1,
USEPA
estimates
that
all
14
entities
registering
with
USEPA
will
submit
an
application,
three
fully
assembled
manifests,
and
a
description
of
the
manifest
form
samples,
as
required
by
40
CFR
262.21(
b)
and
(
d).
USEPA
further
estimates
that,
USEPA­
OSWER
ICR
801.15
30
Dec
2004
35
each
year,
50%
of
registrants
(
i.
e.,
seven
registrants)
will
need
to
prepare
and
submit
a
revised
application
under
40
CFR
262.21(
c).
USEPA
expects
that
no
registrant
will
need
to
submit
revised
manifest
form
samples
under
40
CFR
262.21(
e).

(
a3)
Updating
General
Information
in
the
Approved
Application
USEPA
estimates
that,
each
year,
one
registrant
organization
will
revise
and
submit
its
application
to
USEPA,
along
with
an
indication
or
explanation
of
the
update,
under
40
CFR
262.21(
h)(
1).
USEPA
further
estimates
that
no
registrant
organization
will
need
to
respond
to
USEPA's
concerns
regarding
its
revised
application
during
the
3­
year
period
covered
by
this
ICR.
USEPA
will
provide
print
guidance
to
each
prospective
registrant
on
the
USEPA
website
to
assist
them
in
designing
an
approvable
form,
minimizing
the
likelihood
that
they
will
be
asked
to
resubmit
samples
to
the
registry.

(
a4)
Requesting
Approval
for
a
New
Tracking
Number
Suffix
EPA
estimates
that
no
approved
registrant
organization
will
request
a
new
tracking
number
suffix
during
the
3­
year
period
covered
by
this
ICR.
Because
each
manifest
tracking
number
consists
of
the
three­
letter
suffix
and
nine
digits,
each
registrant
will
be
able
to
generate
more
than
999
million
forms
using
its
original
suffix.
USEPA
does
not
expect
a
registrant
to
request
a
new
suffix
for
many
years.

(
a5)
Requesting
Approval
for
Changes
to
Printing
Specifications
or
Use
of
a
New
Printer
USEPA
estimates
that
no
registrant
organization
will
request
approval
for
changes
to
its
form
or
for
the
use
of
a
new
printer
during
the
3­
year
period
covered
by
this
ICR,
assuming
that
each
registrant
will
be
forward
looking
when
originally
applying
to
the
registry.
Applicants
will
determine
the
appropriate
paper
type,
paper
weight,
and
other
form
aspects,
so
that
they
will
not
need
to
seek
changes
to
their
forms
subsequent
to
their
approval
under
40
CFR
262.21(
e).

(
a6)
Typesetting
the
Manifest
Form
Subsequent
to
its
Approval
USEPA
estimates
that
no
registrant
organization
will
typeset
its
manifest
form,
instead
of
using
the
electronic
file
of
the
forms
provided
by
USEPA,
during
the
3­
year
period
covered
by
this
ICR.
Upon
approval
of
a
registrant's
application
under
40
CFR
262.21(
c),
USEPA
will
provide
it
with
an
electronic
file
of
the
manifest,
continuation
sheet,
and
instructions
and
ask
it
to
use
these
files
to
develop
the
forms.
In
its
consultations,
USEPA
found
that
printers
intend
to
share
these
files
among
their
printing
establishments
so
that
none
will
need
to
typeset
the
form.
Typesetting
the
form
would
be
unappealing
to
registrants
because
of
the
level
of
effort
required
in
comparison
with
using
the
electronic
files.

(
a7)
Requesting
an
Exemption
USEPA
estimates
that,
each
year,
one
registrant
organization
will
submit
a
request
for
an
exemption
under
40
CFR
262.21(
j).
As
mentioned,
USEPA
expects
each
registrant
to
be
forward
looking
when
originally
registering
under
40
CFR
262.21(
b)
through
(
e),
and
carefully
select
the
appropriate
paper
type,
paper
weight,
and
other
aspects
of
the
form.
Therefore,
few,
if
any,
are
expected
to
request
changes
to
the
approved
form
subsequent
to
approval.

(
a8)
Notifying
USEPA
of
a
Printing
Specification
Violation
EPA
estimates
that
no
registrant
organization
will
notify
USEPA
that
it
has
duplicated
tracking
numbers
on
forms
used
or
distributed
to
other
parties.
Registrants
must
print
their
forms
according
to
their
approved
applications,
which
will
lay
out
procedures
for
tightly
controlling
their
tracking
numbers
and
ensuring
that
each
manifest
has
a
unique
number.
Because
of
these
assurances,
USEPA
expects
that
no
registrant
will
duplicate
its
numbers
and
notify
USEPA.

(
a9)
Revising
the
Approved
Manifest
if
Requested
by
USEPA
USEPA
estimates
that
no
registrant
organization
will
need
to
submit
revised
manifest
form
samples,
per
USEPA's
request,
during
the
3­
year
period
covered
by
this
ICR.
USEPA
will
carefully
review
each
registrant's
forms
under
40
CFR
262.21(
e)
to
determine
if
they
satisfy
the
requirements
of
40
CFR
262.21(
f).
USEPA
does
not
expect
to
identify
problems
in
forms
that
have
been
approved.

(
a10)
Responding
to
Suspension
and
Revocation
Procedures
USEPA­
OSWER
ICR
801.15
30
Dec
2004
36
USEPA
does
not
expect
to
conduct
suspension
or
revocation
procedures
during
the
3­
year
period
covered
by
this
ICR.
The
registration
process
under
40
CFR
262.21(
b)
through
(
e)
will
ensure
that
each
approved
registrant
is
capable
of
tightly
controlling
its
tracking
numbers
and
printing
forms
consistent
with
the
approved
samples
and
the
print
specifications.
Therefore,
USEPA
anticipates
it
will
rarely
invoke
its
suspension
and
revocation
procedures.

(
b)
Generator
Requirements
(
b1)
Reading
the
Regulations
Exhibit
2
presents
the
total
annual
hour
and
cost
burden
to
hazardous
waste
generators
in
reading
the
manifest
regulations
at
40
CFR
262.
In
total,
USEPA
expects
that
131,803
generators
will
read
the
40
CFR
262
regulations
each
year.

(
b2)
Manifest
Completion
Exhibits
3
and
4
present
the
total
annual
hour
and
cost
burden
for
generators
to
complete
their
manifests.
Note
that
the
exhibits
reflect
the
fact
that
destination
sites
(
referred
to
as
designated
TSDFs)
often
provide
assistance
to
their
generator
customers
in
preparing
manifests
for
shipments
to
their
facility.
For
purposes
of
analysis,
this
ICR
assumes
that
a
percentage
of
LQGs
and
SQGs
rely
on
the
designated
TSDFs'
assistance
in
manifest
preparation,
while
the
remaining
LQGs
and
SQGs,
as
well
as
all
TSDFs
acting
as
generators,
prepare
their
manifests
themselves,
as
follows:

°
Completing
the
Manifest
Without
the
Assistance
of
Designated
TSDF:
Based
on
consultations
with
hazardous
waste
generators
and
the
States,
USEPA
estimates
that
about
58%
of
LQG
manifests
and
20%
of
SQG
manifests
accompanying
hazardous
waste
shipments
are
prepared
without
the
assistance
of
the
designated
TSDF.
This
is
reflected
in
Exhibit
3.
In
addition,
USEPA
estimates
that
about
5%
of
manifests
include
continuation
sheets.

°
Completing
the
Manifest
With
the
Assistance
of
Designated
TSDF:
As
discussed,
USEPA
recognizes
that
many
LQGs
and
SQGs
rely
on
the
assistance
of
the
designated
TSDF
to
complete
the
manifest
form.
Because
the
designated
TSDF
normally
fills
out
most
of
the
manifest
form
for
the
generator,
the
collaborative
effort
significantly
reduces
the
burden
on
generators.
Based
on
its
consultations,
USEPA
estimates
that
about
42%
of
manifests
from
LQGs
and
80%
of
manifests
from
SQGs
are
jointly
completed
with
the
designated
TSDF.
This
is
reflected
in
Exhibit
4.
[
Note:
Refer
to
Exhibit
14
for
the
hour
and
cost
burden
for
designated
TSDFs
to
assist
LQGs
and
SQGs
in
completing
their
manifests.]

(
b3)
Compliance
with
State
Program
Requirements
40
CFR
262.21(
g)(
2)
provides
that
generators
must
determine
whether
they
are
required
to
comply
with
requirements
specific
to
State
hazardous
waste
manifest
programs.
As
shown
in
Exhibit
5,
USEPA
assumes
that
each
generator
must
contact,
on
average,
three
State
manifest
programs
each
year.
Because
these
activities
are
already
required
under
State
hazardous
waste
programs,
they
are
not
burdened
in
this
ICR.

(
b4)
Manifest
Transmittal
and
Recordkeeping
As
shown
in
Exhibit
6,
USEPA
estimates
that
LQGs,
TSDFs
acting
as
generators,
and
SQGs
will
send
3%
of
their
manifests
with
water
shipments
and
6%
with
rail
shipments.
Generators
must
comply
with
the
requirements
of
40
CFR
262.23,
262.24,
and
262.40
when
transmitting
and
keeping
records
of
the
manifest,
as
appropriate.
In
addition,
USEPA
estimates
that,
each
year,
LQGs,
TSDFs
acting
as
generators,
and
SQGs
will
send
19,509
manifests
with
exports
of
hazardous
waste
and
17,624
manifests
with
imports
of
hazardous
waste.
Finally,
USEPA
estimates
that
approximately
20,000
SQGs
ship
their
hazardous
waste
off
site
under
a
reclamation
agreement,
pursuant
to
40
CFR
262.20.
These
SQGs
are
required
to
keep
a
copy
of
the
contractual
agreement
under
which
their
hazardous
waste
is
shipped
to
the
recycling
facility.

(
b5)
Undeliverable
Shipments
Based
on
consultations
as
shown
in
Exhibit
7,
USEPA
estimates
that
roughly
0.10%
of
shipments
cannot
be
delivered
to
the
designated
TSDF
each
year.
Generators
must
provide
instructions
to
the
transporter
on
how
to
deal
with
these
shipments,
as
required
by
40
CFR
262.20(
d)
and
262.54(
g)(
3).
USEPA­
OSWER
ICR
801.15
30
Dec
2004
37
(
b6)
Rejected
Waste
and
Container
Residues
As
shown
in
Exhibit
8,
USEPA
estimates
that,
each
year,
a
total
of
586
shipments
initiated
by
generators
will
be
rejected
by
designated
TSDFs
and
sent
back
to
the
generator
(
see
Table
8).
Upon
receipt
of
the
rejected
shipments,
generators
must
sign
the
manifest
that
accompanies
the
rejected
load
or
residue.

(
b7)
Exception
Reports:
Completion,
Submission,
and
Recordkeeping
EPA
estimates
that,
on
average,
LQGs,
TSDFs
acting
as
generators,
and
SQGs
will
need
to
develop
an
exception
report
under
40
CFR
262.42
for
approximately
0.5%
of
the
manifests
sent
off
site.
This
assumption
is
reflected
in
Exhibit
9.

(
c)
Transporter
Requirements
(
c1)
Reading
the
Regulations
As
shown
in
Exhibit
10,
there
are
reportedly
414
hazardous
waste
transporter
companies
subject
to
the
RCRA
manifest
system.
USEPA
expects
that
each
company
will
read
the
manifest
regulations
once
a
year.

(
c2)
Manifest
Completion,
Transmittal,
and
Recordkeeping
Exhibit
11
examines
the
manifesting
hour
and
cost
burden
for
transporters
transporting
domestic
and
international
shipments
of
hazardous
waste.
USEPA
estimates
that,
of
themanifests
completed
and
transmitted
each
year
for
domestic
and
import
shipments,
approximately
91%
will
accompany
highway
shipments,
3%
will
accompany
water
shipments,
and
6%
will
accompany
rail
shipments.
USEPA
further
estimates
that
17,624
manifest
forms
will
accompany
imports
and
19,509
manifest
forms
will
accompany
exports
to
non­
designated
OECD
countries.
Finally,
USEPA
estimates
that
transporters
transporting
hazardous
waste
shipments
under
a
reclamation
agreement
will
need
to
comply
with
40
CFR
263.20(
h).

(
c3)
Undeliverable
Shipments
In
Exhibit
11
EPA
estimates
that
each
year
transporters
will
be
unable
to
deliver
approximately
1,762
shipments
of
hazardous
waste
they
have
accepted
from
a
generator
or
a
transporter
to
the
designated
facility
listed
on
the
manifest,
the
alternate
designated
facility,
the
next
designated
transporter,
or
the
place
outside
the
US
designated
by
the
generator.
These
transporters
will
have
to
contact
the
generator
for
further
directions
and
revise
the
manifest
according
to
the
generator's
instructions,
as
required
by
40
CFR
263.21.

(
d3)
Rejected
Waste
and
Container
Residues
Exhibit
11
also
provides
an
estimate
that
each
year
2,934
shipments
are
partially
rejected
while
the
transporter
is
still
on
the
premises.
The
transporter
must
follow
applicable
procedures
for
obtaining
the
manifest
from
the
facility
and,
if
it
accepts
the
forwarded
shipment,
it
must
obtain
the
new
manifest.
USEPA
estimates
that
29,337
shipments
initiated
by
generators
will
be
fully
rejected
by
the
designated
TSDF
while
the
transporter
is
on
the
facility's
premises.
For
these
shipments,
the
transporter
must
follow
applicable
procedures
for
obtaining
the
original
manifest
from
the
facility
in
order
to
forward
the
waste
to
the
alternate
facility
or
generator.

(
d4)
Notification
of
Discharge
of
Hazardous
Waste
The
Statistical
Abstract
of
the
United
States,
released
in
2001
by
the
US
Census
Bureau
indicates
that
there
were
16,977
accidents
involving
transporters
of
hazardous
substances
in
1999.
Of
these,
USEPA
estimates
that
approximately
5%
(
849)
involved
hazardous
waste
transporters
who
had
a
discharge
of
hazardous
waste.
In
Exhibit
12,
USEPA
used
its
best
professional
judgment
to
estimate
that
approximately
849
hazardous
waste
transporters
will
be
required
to
notify
local
authorities
of
a
hazardous
waste
discharge
annually,
as
required
under
40
CFR
263.30.
In
addition,
the
NRC
indicates
that
it
received
approximately
4,378
notifications
of
marine
source
incidents
in
2001
for
discharges
of
oil
or
hazardous
substances.
NRC
estimates
that
about
66%
of
these
incidents
involved
oil
discharges
(
2,919)
and
that
33%
involved
hazardous
substances
discharges
(
1,459).
Of
the
1,459
discharges
of
hazardous
substances,
NRC
estimates
that
5%
(
73)
involved
a
hazardous
waste.
As
shown
in
Exhibit
12,
USEPA
expects
that,
on
average,
73
water
transporters
transporting
hazardous
waste
will
notify
NRC
or
USEPA
under
33
CFR
153.
The
purpose
of
USEPA­
OSWER
ICR
801.15
30
Dec
2004
38
33
CFR
153
is
to
prescribe
regulations
concerning
notification
to
the
US
Coast
Guard
of
the
discharge
of
oil
or
hazardous
substances
as
required
by
the
Federal
Water
Pollution
Control
Act,
as
amended;
the
procedures
for
the
removal
of
a
discharge
of
oil;
and
the
costs
that
may
be
imposed
or
reimbursed
for
the
removal
of
a
discharge
of
oil
or
hazardous
substances.

(
d)
Designated
Treatment,
Storage,
and
Disposal
Facility
Requirements
(
d1)
Reading
the
Regulations
Based
on
USEPA's
2001
RCRA
Hazardous
Waste
Biennial
Report
(
BR)
data,
USEPA
estimates
that
581
TSDFs
receive
off­
site
shipments
of
hazardous
waste
each
year.
As
shown
in
Exhibit
13,
USEPA
expects
that
each
facility
will
read
the
manifest
regulations
once
a
year.

(
d2)
Manifest
Completion,
Transmittal,
and
Recordkeeping
Exhibit
14
presents
USEPA's
estimates
that
approximately
42%
and
80%
of
manifests
from
LQGs
and
SQGs,
respectively,
are
completed
jointly
with
the
designated
TSDF.
In
addition,
USEPA
estimates
that
5%
of
these
manifests
include
continuation
sheets.
Exhibit
15
presents
the
burden
to
designated
TSDFs
for
receiving
and
completing
manifests
that
are
not
rejected
and
that
do
not
result
in
a
container
residue.

(
d3)
Compliance
with
State
Program
Requirements
40
CFR
264.71(
e)
and
265.71(
e)
provides
that
TSDFs
must
determine
whether
they
are
required
to
comply
with
requirements
specific
to
State
hazardous
waste
manifest
programs.
USEPA
assumes
that
each
TSDFs
must
contact,
on
average,
three
State
manifest
programs
each
year.
Because
these
activities
are
already
required
under
State
hazardous
waste
programs,
they
are
not
burdened
in
this
ICR.
This
is
reflected
in
Exhibit
15.

(
d4)
Discrepancy
Reports
As
shown
in
Exhibit
15,
USEPA
estimates
that
approximately
25%
of
manifests
accepted
by
the
designated
TSDF
require
reconciling
discrepancies
between
the
manifest
data
and
the
shipment
(
e.
g.
by
phoning
the
generator).
USEPA
further
estimates
that
about
0.4%
of
manifests
accepted
by
the
designated
TSDF
will
require
a
discrepancy
report
under
40
CFR
264.72
or
265.72.

(
d5)
Rejected
Waste
and
Container
Residues
°
Rejection
of
Waste
after
the
Transporter
Leaves
the
Facility:
As
shown
in
Exhibit
16,
USEPA
estimates
that
each
year
designated
TSDFs
will
reject
a
shipment
or
identify
a
container
residue
after
the
transporter
has
left
the
TSDFs'
premises
for
29,337
hazardous
waste
shipments
received.
°
Rejection
of
Waste
while
the
Transporter
Remains
Present
at
the
Facility:
As
shown
in
Exhibit
16,
USEPA
estimates
that
each
year
designated
TSDFs
will
fully
reject
or
identify
a
container
residue
while
the
transporter
is
on
the
TSDFs'
premises
for
29,337
hazardous
waste
shipments
received.
°
Manifest
Completion
by
the
Alternate
TSDF:
Also
shown
in
Exhibit
16,
USEPA
estimates
that
each
year
designated
TSDFs
will
reject
a
total
of
58,674
shipments
and
forward
58,088
shipments
to
an
alternate
TSDF
(
see
Table
8).

(
d6)
Unmanifested
Waste
Reports:
Completion
and
Submission
As
shown
in
Exhibit
17,
USEPA
estimates
that
designated
TSDFs
will
need
to
complete
approximately
173
letters
notifying
the
Agency
of
unmanifested
waste
shipments
each
year,
as
required
under
40
CFR
264.76
or
265.76.
USEPA­
OSWER
ICR
801.15
30
Dec
2004
39
BURDEN
ESTIMATION
SPREADSHEETS
(
Exhibits
1
to
20)
USEPA­
OSWER
ICR
801.15
30
Dec
2004
40
EXHIBIT
1
ESTIMATED
ANNUAL
HOUR
AND
COST
BURDEN
FOR
REGISTRANT
ORGANIZATIONS
a
Legal
Managerial
Technical
Clerical
Hours/
Labor
Cost/
O&
M
Costs/
Number
of
@
$
114.04/
hr
@
$
89.44/
hr
@
$
58.54/
hr
@
$
30.62/
hr
Respondent
Respondent
Respondent
Registrants
Total
Hours
Total
Cost
Read
the
regulations
0.00
0.25
1.00
0.00
1.25
$
80.90
$
0.00
14
18
$
1,133
Prepare
and
submit
initial
application
0.00
0.25
1.00
0.10
1.35
$
83.96
$
3.64
14
19
$
1,226
Submit
revised
initial
application
to
EPA,
if
requested
0.00
0.10
0.50
0.10
0.70
$
41.28
$
3.64
7
5
$
314
Submit
three
fully
assembled
manifests
and,
if
needed,
continuation
sheets
and
a
description
of
the
form
samples
0.00
0.10
0.17
0.10
0.37
$
21.96
$
503.64
14
5
$
7,358
Submit
revised
form
samples
based
on
EPA
comment
on
the
initial
samples,
if
requested
0.00
0.10
0.17
0.10
0.37
$
21.96
$
503.64
0
0
$
0
Revise
and
submit
the
application
to
EPA,
along
with
an
indication
or
explanation
of
the
update
0.00
0.10
0.17
0.10
0.37
$
21.96
$
0.38
1
0
$
22
Respond
to
the
Agency's
concerns,
if
applicable
0.00
0.10
0.17
0.00
0.27
$
18.90
$
0.00
0
0
$
0
Submit
a
proposed
tracking
number
suffix,
along
with
the
reason
for
requesting
it
0.00
0.10
0.17
0.10
0.37
$
21.96
$
0.38
0
0
$
0
Submit
three
samples
of
the
manifest
form
and/
or
continuation
sheet
and,
if
applicable,
a
brief
description
of
the
qualifications
of
the
new
printer
0.00
0.10
0.17
0.10
0.37
$
21.96
$
503.64
0
0
$
0
Submit
revised
manifest
form
and/
or
continuation
sheet
samples
to
EPA,
if
requested
0.00
0.10
0.17
0.10
0.37
$
21.96
$
503.64
0
0
$
0
Submit
three
samples
of
the
manifest
or
continuation
sheet
to
the
registry
for
approval
0.00
0.00
0.17
0.10
0.27
$
13.01
$
503.64
0
0
$
0
Submit
documentation
to
EPA
indicating
why
an
exemption
is
warranted
0.00
0.10
0.17
0.10
0.37
$
21.96
$
0.38
1
0
$
22
Notify
EPA
of
duplicated
manifest
tracking
numbers
0.00
0.00
0.25
0.00
0.25
$
14.64
$
2.00
0
0
$
0
Submit
revised
manifest
form
samples
to
EPA,
if
requested
0.00
0.10
0.17
0.10
0.37
$
21.96
$
503.64
0
0
$
0
Submit
information
if
requested
by
EPA
0.00
0.25
0.50
0.00
0.75
$
51.63
$
0.38
0
0
$
0
TOTAL
0.00
varies
varies
varies
varies
varies
varies
varies
47
$
10,075
a
Exhibit
contains
rounding
error.

Revising
the
Approved
Manifest
if
Requested
by
EPA
(
262.21(
l))

Typesetting
the
Manifest
Form
Subsequent
to
its
Approval
(
262.21(
i))

Responding
to
Suspension
and
Revocation
Procedures
(
262.21(
m))

Requesting
an
Exemption
(
262.21(
j))

Notifying
EPA
of
a
Printing
Specification
Violation
(
262.21(
k))

Requesting
Approval
for
a
New
Tracking
Number
Suffix
(
262.21(
h)(
2))

Requesting
Approval
for
Changes
to
Printing
Specifications
or
Use
of
a
New
Printer
(
262.21(
h)(
3))

Hours
per
Generator
Applying
to
the
Registry
(
262.21(
b)
and
262.21(
d))

Read
the
regulations
Updating
General
Information
in
the
Approved
Application
(
262.21(
h)(
1))
USEPA­
OSWER
ICR
801.15
30
Dec
2004
41
EXHIBIT
2
ESTIMATED
ANNUAL
HOUR
AND
COST
BURDEN
FOR
GENERATORS
a
READING
THE
REGULATIONS
Legal
Managerial
Technical
Clerical
Hours/
Labor
Cost/
O&
M
Costs/
Number
of
@
$
114.04/
hr
@
$
89.44/
hr
@
$
58.54/
hr
@
$
30.62/
hr
Respondent
Respondent
Respondent
Generators
Total
Hours
Total
Cost
LQGs
0.00
0.25
1.00
0.00
1.25
$
80.90
$
0.00
17,462
21,828
$
1,412,676
TSDFs
0.00
0.25
1.00
0.00
1.25
$
80.90
$
0.00
1,209
1,511
$
97,808
SQGs
0.00
0.25
1.00
0.00
1.25
$
80.90
$
0.00
113,132
141,415
$
9,152,379
TOTAL
(
LQGs,
TSDFs,
and
SQGs)
0.00
0.25
1.00
0.00
1.25
$
80.90
$
0.00
131,803
164,754
$
10,662,863
a
Exhibit
contains
rounding
error.

EXHIBIT
3
ESTIMATED
ANNUAL
HOUR
AND
COST
BURDEN
FOR
GENERATORS
a
COMPLETING
THE
MANIFEST
(
WITHOUT
ASSISTANCE
OF
DESIGNATED
TSDFs)

Legal
Managerial
Technical
Clerical
Hours/
Labor
Cost/
O&
M
Costs/
Number
of
@
$
114.04/
hr
@
$
89.44/
hr
@
$
58.54/
hr
@
$
30.62/
hr
Respondent
Respondent
Respondent
Manifests
Total
Hours
Total
Cost
Complete
the
manifest
0.00
0.00
0.40
0.10
0.50
$
26.48
$
0.00
461,227
230,614
$
12,213,291
Complete
the
continuation
sheet
0.00
0.00
0.19
0.04
0.23
$
12.35
$
0.00
23,061
5,304
$
284,803
Subtotal
(
for
LQGs)
0.00
0.00
varies
varies
varies
varies
$
0.00
461,227
235,918
$
12,498,094
Complete
the
manifest
0.00
0.00
0.43
0.10
0.53
$
28.23
$
0.00
104,926
55,611
$
2,962,061
Complete
the
continuation
sheet
0.00
0.00
0.18
0.04
0.22
$
11.76
$
0.00
5,246
1,154
$
61,693
Complete
the
manifest
0.00
0.00
0.43
0.10
0.53
$
28.23
$
0.00
32,325
17,132
$
912,535
Complete
the
continuation
sheet
0.00
0.00
0.18
0.05
0.23
$
12.07
$
0.00
1,616
372
$
19,505
Subtotal
(
for
TSDFs)
0.00
0.00
varies
varies
varies
varies
$
0.00
137,251
74,269
$
3,955,794
Complete
the
manifest
0.00
0.00
0.40
0.08
0.48
$
25.87
$
0.00
165,961
79,661
$
4,293,411
Complete
the
continuation
sheet
0.00
0.00
0.18
0.03
0.21
$
11.46
$
0.00
8,298
1,743
$
95,095
Subtotal
(
for
SQGs)
0.00
0.00
varies
varies
varies
varies
$
0.00
165,961
81,404
$
4,388,506
TOTAL
(
LQGs,
TSDFs,
and
SQGs)
0.00
0.00
varies
varies
varies
varies
$
0.00
764,439
391,591
$
20,842,394
a
Exhibit
contains
rounding
error.
Hours
per
Generator
Read
the
regulations
Manifest
completion:
LQGs
(
262.20)

Manifest
completion:
TSDFs
who
are
also
generators
(
262.20)

Commercial
TSDFs
Manifest
completion:
SQGs
(
262.20)
Hours
per
Generator
Captive
TSDFs
USEPA­
OSWER
ICR
801.15
30
Dec
2004
42
EXHIBIT
4
ESTIMATED
ANNUAL
HOUR
AND
COST
BURDEN
FOR
GENERATORS
a
COMPLETING
THE
MANIFEST
(
WITH
ASSISTANCE
OF
DESIGNATED
TSDFs)

Legal
Managerial
Technical
Clerical
Hours/
Labor
Cost/
O&
M
Costs/
Number
of
@
$
114.04/
hr
@
$
89.44/
hr
@
$
58.54/
hr
@
$
30.62/
hr
Respondent
Respondent
Respondent
Manifests
Total
Hours
Total
Cost
Complete
the
manifest
0.00
0.00
0.02
0.01
0.03
$
1.48
$
0.00
333,992
10,020
$
494,308
Complete
the
manifest
0.00
0.00
0.02
0.01
0.03
$
1.48
$
0.00
663,845
19,915
$
982,491
TOTAL
(
LQGs
and
SQGs)
0.00
0.00
0.02
0.01
0.03
$
1.48
$
0.00
997,837
29,935
$
1,476,799
a
Exhibit
contains
rounding
error.

EXHIBIT
5
ESTIMATED
ANNUAL
HOUR
AND
COST
BURDEN
FOR
GENERATORS
a
COMPLIANCE
WITH
STATE
PROGRAM
REQUIREMENTS
Legal
Managerial
Technical
Clerical
Hours/
Labor
Cost/
O&
M
Costs/
Number
of
@
$
114.04/
hr
@
$
89.44/
hr
@
$
58.54/
hr
@
$
30.62/
hr
Respondent
Respondent
Respondent
Phone
Calls
Total
Hours
Total
Cost
Contact
the
consignment/
generator
State
if
needed
and
submit
any
copies
of
the
manifest
to
these
States,
as
applicable
0.00
0.00
0.00
0.00
0.00
$
0.00
$
0.00
52,386
0
$
0
Contact
the
consignment/
generator
State
if
needed
and
submit
any
copies
of
the
manifest
to
these
States,
as
applicable
0.00
0.00
0.00
0.00
0.00
$
0.00
$
0.00
906
0
$
0
Contact
the
consignment/
generator
State
if
needed
and
submit
any
copies
of
the
manifest
to
these
States,
as
applicable
0.00
0.00
0.00
0.00
0.00
$
0.00
$
0.00
2,721
0
$
0
Subtotal
(
for
TSDFs)
0.00
0.00
0.00
0.00
0.00
$
0.00
$
0.00
3,627
0
$
0
Contact
the
consignment/
generator
State
if
needed
and
submit
any
copies
of
the
manifest
to
these
States,
as
applicable
0.00
0.00
0.00
0.00
0.00
$
0.00
$
0.00
279,396
0
$
0
TOTAL
(
LQGs,
TSDFs,
and
SQGs)
0.00
0.00
0.00
0.00
0.00
$
0.00
$
0.00
335,409
0
$
0
a
Exhibit
contains
rounding
error.

Manifest
completion:
LQGs
(
262.20)
Hours
per
Generator
Commercial
TSDFs
Captive
TSDFs
Compliance
with
State
program
requirements:
TSDFs
who
are
also
generators
(
262.21(
g))
Hours
per
Generator
Compliance
with
State
program
requirements:
LQGs
(
262.21(
g))

Manifest
completion:
SQGs
(
262.20)

Compliance
with
State
program
requirements:
SQGs
(
262.21(
g))
USEPA­
OSWER
ICR
801.15
30
Dec
2004
43
EXHIBIT
6
ESTIMATED
ANNUAL
HOURANDCOST
BURDENFORGENERATORS
a
TRANSMITTING
THE
MANIFEST
Annual
Legal
Managerial
Technical
Clerical
Hours/
Labor
Cost/
O&
M
Costs/
Number
of
@
$
114.04/
hr
@
$
89.44/
hr
@
$
58.54/
hr
@
$
30.62/
hr
Respondent
Respondent
Respondent
Manifests
Total
Hours
Total
Cost
Sign
the
manifest
certification
and
obtain
the
signature
of
the
initial
transporter
and
date
of
acceptance
on
the
manifest
0.00
0.00
0.01
0.00
0.01
$
0.59
$
0.00
795,219
7,952
$
469,179
Keep
a
copy
of
the
manifest
and
give
the
remaining
copies
to
the
initial
transporter
0.00
0.00
0.00
0.10
0.10
$
3.06
$
0.00
795,219
79,522
$
2,433,370
Keep
a
copy
of
the
manifest
returned
from
the
designated
facility
0.00
0.00
0.00
0.10
0.10
$
3.06
$
0.00
795,219
79,522
$
2,433,370
For
shipments
solely
by
water,
send
three
copies
of
the
manifest,

dated
and
signed,
to
the
designated
facility
or
the
last
water
transporter
to
handle
the
waste
in
the
U.
S.
0.00
0.00
0.00
0.16
0.16
$
4.90
$
0.38
23,857
3,817
$
125,965
For
shipments
by
rail
originating
at
the
site
of
generation,
send
at
least
three
copies
of
the
manifest
to
the
next
non­
rail
transporter,
the
designated
facility,
or
the
last
rail
transporter
to
handle
the
waste
in
the
U.
S.
0.00
0.00
0.00
0.16
0.16
$
4.90
$
0.38
47,713
7,634
$
251,925
Provide
the
transporter
with
an
EPA
Acknowledgment
of
Consent
andan
additional
copy
of
themanifest
or
shipping
papers
for
delivery
to
the
U.
S.
Customs
official
at
the
point
the
hazardous
waste
exits
the
U.
S.
0.00
0.00
0.00
0.25
0.25
$
7.66
$
0.10
9,169
2,292
$
71,152
Subtotal
(
for
LQGs)
0.00
0.00
varies
varies
varies
varies
varies
varies
180,739
$
5,784,961
Hours
per
Generator
Manifest
transmittal
and
recordkeeping:
LQGs
Exports
(
262.54(
h)
and
(
i))

Manifest
(
262.23(
a),
262.23(
b),
and
262.40(
a))
USEPA­
OSWER
ICR
801.15
30
Dec
2004
44
EXHIBIT
6
(
CONTINUED)

ESTIMATED
ANNUAL
HOURAND
COST
BURDEN
FORGENERATORS
a
TRANSMITTING
THE
MANIFEST
Annual
Legal
Managerial
Technical
Clerical
Hours/
Labor
Cost/
O&
M
Costs/
Number
of
@
$
114.04/
hr
@
$
89.44/
hr
@
$
58.54/
hr
@
$
30.62/
hr
Respondent
Respondent
Respondent
Manifests
Total
Hours
Total
Cost
Manifest
(
262.23(
a),
262.23(
b),
and
262.40(
a))

Sign
the
manifest
certification
and
obtain
the
signature
of
the
initial
transporter
and
date
of
acceptance
on
the
manifest
0.00
0.00
0.01
0.00
0.01
$
0.59
$
0.00
104,926
1,049
$
61,906
Keep
a
copy
of
the
manifest
and
give
the
remaining
copies
to
the
initial
transporter
0.00
0.00
0.00
0.10
0.10
$
3.06
$
0.00
104,926
10,493
$
321,074
Keep
a
copy
of
the
manifest
returned
from
the
designated
facility
0.00
0.00
0.00
0.10
0.10
$
3.06
$
0.00
104,926
10,493
$
321,074
For
shipments
solely
by
water,
send
three
copies
of
the
manifest,

dated
and
signed,
to
the
designated
facility
or
the
last
water
transporter
to
handle
the
waste
in
the
U.
S.(
Domestic
and
Exports)
0.00
0.00
0.00
0.16
0.16
$
4.90
$
0.38
3,148
504
$
16,621
For
shipments
by
rail
originating
at
thesite
of
generation,
send
at
least
three
copies
of
the
manifest
to
the
next
non­
rail
transporter,
the
designated
facility,
or
the
last
rail
transporter
to
handle
the
waste
in
theU.
S.
(
Domestic
and
Exports)
0.00
0.00
0.00
0.16
0.16
$
4.90
$
0.38
6,296
1,007
$
33,242
Provide
the
transporter
with
an
EPAAcknowledgment
of
Consent
andan
additional
copy
of
the
manifest
or
shipping
papers
for
delivery
to
the
U.
S.
Customs
official
at
the
point
the
hazardous
waste
exits
the
U.
S.
0.00
0.00
0.00
0.25
0.25
$
7.66
$
0.10
1,561
390
$
12,113
Subtotal
(
for
Commercial
TSDFs)
0.00
0.00
varies
varies
varies
varies
varies
varies
23,936
$
766,030
Hours
per
Generator
Manifest
transmittal
and
recordkeeping:
Commercial
TSDFs
Exports
(
262.54(
h)
and
(
i))
USEPA­
OSWER
ICR
801.15
30
Dec
2004
45
EXHIBIT
6
(
CONTINUED)

ESTIMATED
ANNUAL
HOURAND
COST
BURDEN
FOR
GENERATORS
a
TRANSMITTING
THE
MANIFEST
Annual
Legal
Managerial
Technical
Clerical
Hours/
Labor
Cost/
O&
M
Costs/
Number
of
@
$
114.04/
hr
@
$
89.44/
hr
@
$
58.54/
hr
@
$
30.62/
hr
Respondent
Respondent
Respondent
Manifests
Total
Hours
Total
Cost
Manifest
(
262.23(
a),
262.23(
b),
and
262.40(
a))

Signthe
manifest
certificationandobtain
thesignatureof
theinitial
transporter
anddate
of
acceptanceon
themanifest
0.00
0.00
0.01
0.00
0.01
$
0.59
$
0.00
32,325
323
$
19,072
Keepa
copy
of
themanifest
andgive
theremaining
copies
to
the
initial
transporter
0.00
0.00
0.00
0.10
0.10
$
3.06
$
0.00
32,325
3,233
$
98,915
Keepa
copy
of
themanifest
returnedfrom
the
designated
facility
0.00
0.00
0.00
0.10
0.10
$
3.06
$
0.00
32,325
3,233
$
98,915
For
shipments
solely
by
water,
sendthreecopies
of
themanifest,

dated
andsigned,
to
the
designated
facility
or
the
last
water
transporter
to
handlethe
waste
in
theU.
S.(
Domestic
andExports)
0.00
0.00
0.00
0.16
0.16
$
4.90
$
0.38
970
155
$
5,122
For
shipments
by
rail
originatingat
thesite
of
generation,
send
at
least
threecopies
of
themanifest
to
thenext
non­
rail
transporter,
the
designatedfacility,
or
thelast
rail
transporter
to
handlethewaste
in
the
U.
S.
(
Domestic
and
Exports)
0.00
0.00
0.00
0.16
0.16
$
4.90
$
0.38
1,940
310
$
10,243
Providethe
transporter
with
anEPA
Acknowledgment
of
Consent
andan
additional
copy
of
themanifest
or
shippingpapers
for
delivery
to
the
U.
S.
Customs
official
at
thepoint
thehazardous
waste
exits
the
U.
S.
0.00
0.00
0.00
0.25
0.25
$
7.66
$
0.10
585
146
$
4,540
Subtotal
(
for
Captive
TSDFs)
0.00
0.00
varies
varies
varies
varies
varies
varies
7,400
$
236,807
Hours
per
Generator
Manifest
transmittal
and
recordkeeping:
Captive
TSDFs
Exports(
262.54(
h)
and
(
i))
USEPA­
OSWER
ICR
801.15
30
Dec
2004
46
EXHIBIT
6
(
CONTINUED)

ESTIMATED
ANNUAL
HOUR
AND
COST
BURDEN
FORGENERATORS
a
TRANSMITTING
THE
MANIFEST
Annual
Legal
Managerial
Technical
Clerical
Hours/
Labor
Cost/
O&
M
Costs/
Number
of
@
$
114.04/
hr
@
$
89.44/
hr
@
$
58.54/
hr
@
$
30.62/
hr
Respondent
Respondent
Respondent
Man
i
fests
Total
Hours
Total
Cost
Manifest
(
262.23(
a),
262.23(
b),
and
262.40(
a))

Sign
the
manifest
certification
and
obtain
the
signature
of
the
initial
transporter
and
date
of
acceptance
on
the
manifest
0.00
0.00
0.01
0.00
0.01
$
0.59
$
0.00
829,806
8,298
$
489,586
Keep
a
copy
of
the
manifest
and
give
the
remaining
copies
to
the
initial
transporter
0.00
0.00
0.00
0.10
0.10
$
3.06
$
0.00
829,806
82,981
$
2,539,206
Keep
a
copy
of
the
manifest
returned
from
the
designated
facility
0.00
0.00
0.00
0.10
0.10
$
3.06
$
0.00
829,806
82,981
$
2,539,206
For
shipments
solely
by
water,
send
three
copies
of
the
manifest,

dated
and
signed,
to
the
designated
facility
or
the
last
water
transporter
to
handlethe
waste
in
the
U.
S.(
Domestic
and
Exports)
0.00
0.00
0.00
0.16
0.16
$
4.90
$
0.38
24,894
3,983
$
131,441
For
shipments
by
rail
originating
at
the
site
of
generation,
send
at
least
three
copies
of
the
manifest
to
the
next
non­
rail
transporter,
the
designated
facility,
or
the
last
rail
transporter
to
handle
the
waste
in
the
U.
S.
(
Domestic
and
Exports)
0.00
0.00
0.00
0.16
0.16
$
4.90
$
0.38
49,788
7,966
$
262,880
Provide
thetransporter
with
an
EPA
Acknowledgment
of
Consent
and
an
additional
copy
of
the
manifest
or
shipping
papers
for
delivery
to
the
U.
S.
Customs
official
at
the
point
the
hazardous
waste
exits
the
U.
S.
0.00
0.00
0.00
0.25
0.25
$
7.66
$
0.10
8,194
2,049
$
63,585
Retain
a
copy
of
each
reclamation
agreement
0.00
0.00
0.00
0.10
0.10
$
3.06
$
0.00
20,000
2,000
$
61,200
Subtotal
(
for
SQGs)
0.00
0.00
varies
varies
varies
varies
varies
varies
190,258
$
6,087,104
TOTAL(
LQGs,
TSDFs,
and
SQGs)
0.00
0.00
varies
varies
varies
varies
varies
varies
402,333
$
12,874,902
a
Exhibit
contains
rounding
error.
Hours
per
Generator
Manifest
transmittal
and
recordkeeping:
SQGs
Exports
(
262.54(
h)
and(
i))

Reclamation
agreements
(
262.20(
e)(
2))
USEPA­
OSWER
ICR
801.15
30
Dec
2004
47
EXHIBIT
7
ESTIMATED
ANNUAL
HOUR
ANDCOST
BURDEN
FORGENERATORS
a
UNDELIVERABLE
SHIPMENTS
Legal
Managerial
Technical
Clerical
Hours/
Labor
Cost/
O&
M
Costs/
Number
of
@
$
114.04/
hr
@
$
89.44/
hr
@
$
58.54/
hr
@
$
30.62/
hr
Respondent
Respondent
Respondent
Manifests
Total
Hours
Total
Cost
Designate
another
facility
or
instruct
the
transporter
to
return
the
waste
0.00
0.00
0.08
0.00
0.08
$
4.68
$
0.00
795
64
$
3,721
Designate
another
facility
or
instruct
the
transporter
to
return
the
waste
0.00
0.00
0.08
0.00
0.08
$
4.68
$
0.00
105
8
$
491
Designate
another
facility
or
instruct
the
transporter
to
return
the
waste
0.00
0.00
0.08
0.00
0.08
$
4.68
$
0.00
32
3
$
150
Designate
another
facility
or
instruct
the
transporter
to
return
the
waste
0.00
0.00
0.08
0.00
0.08
$
4.68
$
0.00
830
66
$
3,884
TOTAL
(
LQGs,
TSDFs,
and
SQGs)
0.00
0.00
0.08
0.00
0.08
$
4.68
$
0.00
1,762
141
$
8,246
a
Exhibit
contains
rounding
error.

EXHIBIT
8
ESTIMATED
ANNUAL
HOUR
ANDCOST
BURDEN
FORGENERATORS
a
REJECTED
WASTE
ANDCONTAINERRESIDUES
Legal
Managerial
Technical
Clerical
Hours/
Labor
Cost/
O&
M
Costs/
Number
of
@
$
114.04/
hr
@
$
89.44/
hr
@
$
58.54/
hr
@
$
30.62/
hr
Respondent
Respondent
Respondent
Manifests
Total
Hours
Total
Cost
Sign
Item
18c
of
the
manifest,
if
the
transporter
returned
the
shipment
using
the
original
manifest
0.00
0.00
0.01
0.00
0.01
$
0.59
$
0.00
293
3
$
173
Sign
Item
20
of
the
manifest,
if
the
transporter
returned
the
shipment
using
a
new
manifest
0.00
0.00
0.01
0.00
0.01
$
0.59
$
0.00
293
3
$
173
TOTAL
0.00
0.00
0.01
0.00
0.01
$
0.59
$
0.00
586
6
$
346
a
Exhibit
contains
rounding
error.
Hours
per
TSDF
Undeliverable
shipments:
Commercial
TSDFs
(
262.20(
d)
and
262.54(
g)(
3))

Undeliverable
shipments:
Captive
TSDFs
(
262.20(
d)
and
262.54(
g)(
3))

Undeliverable
shipments:
SQGs
(
262.20(
d)
and
262.54(
g)(
3))

Undeliverable
shipmentst:
LQGs
(
262.20(
d)
and
262.54(
g)(
3))

Rejected
waste
and
container
residues
(
262.34(
j))
Hours
per
TSDF
USEPA­
OSWER
ICR
801.15
30
Dec
2004
48
EXHIBIT
9
ESTIMATED
ANNUAL
HOUR
AND
COST
BURDEN
FOR
GENERATORS
a
DEVELOPING
EXCEPTION
REPORTS
Legal
Managerial
Technical
Clerical
Hours/
Labor
Cost/
O&
M
Costs/
Number
of
@
$
114.04/
hr
@
$
89.44/
hr
@
$
58.54/
hr
@
$
30.62/
hr
Respondent
Respondent
Respondent
Reports
Total
Hours
Total
Cost
Prepare
and
submit
a
signed
cover
letter
to
EPA
explaining
the
generator's
efforts
to
locate
the
hazardous
waste
and
the
results
of
those
efforts,
along
with
a
legible
copy
of
the
manifest
0.00
0.50
0.50
0.10
1.10
$
77.05
$
0.48
3,976
4,374
$
308,259
Keep
a
copy
of
each
exception
report
0.00
0.00
0.00
0.10
0.10
$
3.06
$
0.10
3,976
398
$
12,565
Subtotal
(
for
LQGs)
0.00
varies
varies
0.10
varies
varies
$
0.58
3,976
4,772
$
320,824
Prepare
and
submit
a
signed
cover
letter
to
EPA
explaining
the
generator's
efforts
to
locate
the
hazardous
waste
and
the
results
of
those
efforts,
along
with
a
legible
copy
of
the
manifest
0.00
0.50
0.50
0.10
1.10
$
77.05
$
0.48
525
578
$
40,703
Keep
a
copy
of
each
exception
report
0.00
0.00
0.00
0.10
0.10
$
3.06
$
0.10
525
53
$
1,660
Subtotal
(
for
Commercial
TSDFs)
0.00
varies
varies
0.10
varies
varies
$
0.58
525
631
$
42,363
Prepare
and
submit
a
signed
cover
letter
to
EPA
explaining
the
generator's
efforts
to
locate
the
hazardous
waste
and
the
results
of
those
efforts,
along
with
a
legible
copy
of
the
manifest
0.00
0.50
0.50
0.10
1.10
$
77.05
$
0.48
162
178
$
12,560
Keep
a
copy
of
each
exception
report
0.00
0.00
0.00
0.10
0.10
$
3.06
$
0.10
162
16
$
512
Subtotal
(
for
Captive
TSDFs)
0.00
varies
varies
0.10
varies
varies
$
0.58
162
194
$
13,072
Submit
a
legible
copy
of
the
manifest
with
some
indication
that
the
waste
has
not
been
delivered
0.00
0.25
0.25
0.00
0.50
$
37.00
$
0.48
4,149
2,075
$
155,505
Subtotal
(
for
SQGs)
0.00
0.25
0.25
0.00
0.50
$
37.00
$
0.48
4,149
2,075
$
155,505
TOTAL
(
LQGs,
TSDFs,
and
SQGs)
0.00
varies
varies
varies
varies
varies
varies
varies
7,672
$
531,764
a
Exhibit
contains
rounding
error.

EXHIBIT
10
ESTIMATED
ANNUAL
HOUR
AND
COST
BURDEN
FOR
TRANSPORTERS
a
READING
THE
REGULATIONS
Legal
Managerial
Technical
Clerical
Hours/
Labor
Cost/
O&
M
Costs/
Number
of
@
$
114.04/
hr
@
$
89.44/
hr
@
$
58.54/
hr
@
$
30.62/
hr
Respondent
Respondent
Respondent
Transporters
Total
Hours
Total
Cost
Transporters
0.00
0.25
1.00
0.00
1.25
$
80.90
$
0.00
414
518
$
33,493
TOTAL
0.00
0.25
1.00
0.00
1.25
$
80.90
$
0.00
414
518
$
33,493
a
Exhibit
contains
rounding
error.

Exception
report
completion,
submission,
and
recordkeeping:
LQGs
(
262.42(
a)(
i)­(
ii)
and
262.40(
b))

Hours
per
Generator
Exception
report
completion,
submission,
and
recordkeeping:
SQGs
(
262.42(
b))

Exception
report
completion,
submission,
and
recordkeeping:
Commercial
TSDFs
(
262.42(
a)(
i)­(
ii)
and
262.40(
b))

Read
the
regulations
Exception
report
completion,
submission,
and
recordkeeping:
Captive
TSDFs
(
262.42(
a)(
i)­(
ii)
and
262.40(
b))

Hours
per
Transporter
USEPA­
OSWER
ICR
801.15
30
Dec
2004
49
EXHIBIT
11
ESTIMATED
ANNUAL
HOUR
AND
COST
BURDEN
FOR
TRANSPORTERS
a
COMPLETING
AND
TRANSMITTING
THE
MANIFEST
Legal
Managerial
Technical
Clerical
Hours/
Labor
Cost/
O&
M
Costs/
Number
of
@
$
114.04/
hr
@
$
89.44/
hr
@
$
58.54/
hr
@
$
30.62/
hr
Respondent
Respondent
Respondent
Manifests
Total
Hours
Total
Cost
Sign
and
date
the
manifest
0.00
0.00
0.01
0.00
0.01
$
0.59
$
0.00
1,612,615
16,126
$
951,443
Return
a
signed
copy
of
the
manifest
to
the
generator
0.00
0.00
0.01
0.00
0.01
$
0.59
$
0.00
1,612,615
16,126
$
951,443
Ensure
that
the
manifest
(
or
other
shipping
paper)
accompanies
the
waste
to
its
destination
0.00
0.00
0.13
0.00
0.13
$
7.61
$
0.00
1,612,615
209,640
$
12,272,000
Obtain
the
date
of
delivery
and
signature
of
that
transporter
or
the
owner/
operator
of
the
facility
or
alternate
facility
designated
on
the
manifest
0.00
0.00
0.01
0.00
0.01
$
0.59
$
0.00
1,612,615
16,126
$
951,443
Retain
a
copy
of
the
manifest
0.00
0.00
0.00
0.17
0.17
$
5.21
$
0.00
1,612,615
274,145
$
8,401,724
Give
remaining
copies
of
the
manifest
to
the
accepting
transporter
or
facility
0.00
0.00
0.01
0.00
0.01
$
0.59
$
0.00
1,612,615
16,126
$
951,443
Obtain
the
date
of
delivery
and
signature
of
the
initial
water
transporter
on
the
manifest
0.00
0.00
0.00
0.01
0.01
$
0.31
$
0.00
53,163
532
$
16,481
Forward
the
manifest
to
the
designated
facility
0.00
0.00
0.00
0.16
0.16
$
4.90
$
0.38
53,163
8,506
$
280,701
Ensure
that
the
shipping
paper
(
and
Acknowledgment
of
Consent,

for
exports)
accompanies
the
waste
to
its
destination
0.00
0.00
0.13
0.00
0.13
$
7.61
$
0.00
53,163
6,911
$
404,570
If
the
delivering
(
water)
transporter,
obtain
the
date
of
delivery
and
signature
of
the
owner/
operator
of
the
designated
facility
on
either
the
manifest
or
shipping
paper
0.00
0.00
0.01
0.00
0.01
$
0.59
$
0.00
53,163
532
$
31,366
If
the
initial
water
transporter,
sign
and
date
the
manifest
and
return
it
to
the
delivering
transporter
so
that
the
manifest
can
be
forwarded
to
the
designated
facility
owner/
operator
0.00
0.00
0.01
0.00
0.01
$
0.59
$
0.00
53,163
532
$
31,366
Retain
a
copy
of
the
manifest
or
shipping
paper
0.00
0.00
0.00
0.17
0.17
$
5.21
$
0.00
53,163
9,038
$
276,979
When
accepting
waste
from
a
non­
rail
transporter,
sign
and
date
the
manifest
and
return
or
transmit
a
signed
copy
of
the
manifest
to
the
non­
rail
transporter
0.00
0.00
0.01
0.00
0.01
$
0.59
$
0.00
106,326
1,063
$
62,732
Forward
at
least
three
copies
of
the
manifest
to
either
the
next
nonrail
transporter,
the
designated
facility,
or
the
last
rail
transporter
designated
to
handle
the
waste
in
the
U.
S.
0.00
0.00
0.00
0.16
0.16
$
4.90
$
0.38
106,326
17,012
$
561,401
Ensure
a
shipping
paper
containing
all
the
information
required
on
the
manifest
excluding
the
U.
S.
EPA
ID
number,
generator
certification,
and
signatures
(
and
for
exports
an
Acknowledgment
of
Consent)
accompanies
the
waste
0.00
0.00
0.13
0.00
0.13
$
7.61
$
0.00
106,326
13,822
$
809,141
When
delivering
hazardous
waste
to
the
designated
facility
or
to
the
next
non­
rail
transporter,
obtain
the
signature
and
date
of
delivery
of
the
facility
or
non­
rail
transporter
on
the
manifest
0.00
0.00
0.01
0.00
0.01
$
0.59
$
0.00
106,326
1,063
$
62,732
Retain
a
copy
of
the
manifest
and/
or
rail
shipping
paper
0.00
0.00
0.00
0.17
0.17
$
5.21
$
0.00
106,326
18,075
$
553,958
Before
accepting
hazardous
waste
from
a
rail
transporter,
sign
and
date
the
manifest
and
provide
a
copy
to
the
rail
transporter
0.00
0.00
0.01
0.00
0.01
$
0.59
$
0.00
106,326
1,063
$
62,732
Manifest
requirements
for
highway
transporters
(
263.20(
b),
263.20(
c),
263.20(
d),
and
263.22(
a))

Manifest
completion,
transmittal
and
recordkeeping:
Transporters
Manifest
requirements
for
person
delivering
to
initial
water
transporters
(
263.20(
e))

Manifest
requirements
for
water
(
bulk
shipment)
transporters
(
263.20(
e))

Manifest
requirements
for
rail
transporters
(
263.20(
f)
and
263.22(
c))
Hours
per
Transporter
USEPA­
OSWER
ICR
801.15
30
Dec
2004
50
EXHIBIT
11
(
CONTINUED)

ESTIMATED
ANNUAL
HOUR
AND
COST
BURDEN
FOR
TRANSPORTERS
a
COMPLETING
AND
TRANSMITTING
THE
MANIFEST
Annual
Legal
Managerial
Technical
Clerical
Hours/
Labor
Cost/
O&
M
Costs/
Number
of
@
$
114.04/
hr
@
$
89.44/
hr
@
$
58.54/
hr
@
$
30.62/
hr
Respondent
Respondent
Respondent
Manifests
Total
Hours
Total
Cost
For
imports
and
exports,
sign
and
date
the
manifest
in
the
International
Shipments
block
to
indicate
the
date
that
the
shipment
left
the
U.
S.,
as
required
by
section
263.20(
g)(
1)
0.00
0.00
0.01
0.00
0.01
$
0.59
$
0.00
37,133
371
$
21,908
For
imports
and
exports,
retain
a
copy
of
the
manifest,
as
required
by
section
263.20(
g)(
2)
0.00
0.00
0.00
0.17
0.17
$
5.21
$
0.00
37,133
6,313
$
193,463
For
imports
give
copy
of
import
manifest
to
TSDF
receiving
facility
0.00
0.00
0.01
0.00
0.01
$
0.59
$
0.00
17,624
176
$
10,398
For
exports,
return
a
signed
copy
of
the
manifest
to
the
generator,
as
required
by
section
263.20(
g)(
3)
0.00
0.00
0.00
0.01
0.01
$
0.31
$
0.00
19,509
195
$
6,048
For
exports,
give
a
copy
of
the
manifest
to
a
U.
S.
Customs
official
at
the
point
of
departure
from
the
U.
S.,
as
required
by
section
263.20(
g)(
4)
0.00
0.00
0.01
0.00
0.01
$
0.59
$
0.10
19,509
195
$
13,461
For
exports,
ensure
that
copies
of
the
manifest
and
EPA
Acknowledgment
of
Consent
accompanies
the
waste,
as
required
by
section
263.20(
a)
0.00
0.00
0.13
0.00
0.13
$
7.61
$
0.00
19,509
2,536
$
148,463
Record
the
waste
information
on
a
log
or
shipping
paper
0.00
0.25
0.75
0.00
1.00
$
66.27
$
0.00
20,000
20,000
$
1,325,400
Carry
the
record
when
transporting
waste
to
the
reclamation
facility
0.00
0.00
0.01
0.00
0.01
$
0.59
$
0.00
20,000
200
$
11,800
Retain
the
records
0.00
0.00
0.00
0.17
0.17
$
5.21
$
0.00
20,000
3,400
$
104,200
Contact
the
generator
for
further
directions
and
revise
the
manifest
according
to
the
generator's
instructions
0.00
0.00
0.08
0.00
0.08
$
4.68
$
2.00
1,762
141
$
11,770
For
partially
rejected
loads
made
while
the
transporter
is
on
site,

obtain
the
amended
manifest
from
the
facility,
keep
a
copy,
and,
if
receiving
the
rejected
waste,
obtain
the
new
manifest
0.00
0.00
0.10
0.00
0.10
$
5.85
$
0.00
2,934
293
$
17,164
For
fully
rejected
loads
made
or
container
residues
identified
while
the
transporter
is
on
site,
obtain
the
original
manifest,
as
amended,

from
the
facility
0.00
0.00
0.01
0.00
0.01
$
0.59
$
0.00
29,337
293
$
17,309
TOTAL
varies
varies
varies
varies
varies
varies
varies
varies
660,551
$
29,515,039
a
Exhibit
contains
rounding
error.

Undeliverable
shipments
(
263.21(
b)(
1))

Rejected
waste
and
container
residues
(
263.21(
b)(
2))

Manifest
requirements
for
transporters
who
transport
waste
into
and/
or
out
of
the
U.
S.
(
263.20(
g)
and
(
i))

Manifest
requirements
for
transporters
who
transport
waste
pursuant
to
a
reclamation
agreement
(
263.20(
h))

Hours
per
Transporter
Manifest
completion,
transmittal
and
recordkeeping:
Transporters
USEPA­
OSWER
ICR
801.15
30
Dec
2004
51
EXHIBIT
12
ESTIMATED
ANNUAL
HOUR
AND
COST
BURDEN
FOR
TRANSPORTERS
a
NOTIFYING
OF
DISCHARGE
OF
HAZARDOUS
WASTE
Legal
Managerial
Technical
Clerical
Hours/
Labor
Cost/
O&
M
Costs/
Number
of
@
$
114.04/
hr
@
$
89.44/
hr
@
$
58.54/
hr
@
$
30.62/
hr
Respondent
Respondent
Respondent
Notifications
Total
Hours
Total
Cost
Notify
local
authorities
0.00
0.25
1.00
0.00
1.25
$
80.90
$
0.00
849
1,061
$
68,684
Notify
NRC,
or
a
predesignated
OSC,
of
the
discharge
0.00
0.25
1.00
0.00
1.25
$
80.90
$
0.00
73
91
$
5,906
TOTAL
0.00
varies
1.00
0.00
1.25
$
80.90
$
0.00
varies
1,152
$
74,590
a
Exhibit
contains
rounding
error.

EXHIBIT
13
ESTIMATED
ANNUAL
HOUR
AND
COST
BURDEN
FOR
DESIGNATED
TREATMENT,
STORAGE,
AND
DISPOSAL
FACILITIES
(
TSDFs)
a
READING
THE
REGULATIONS
Legal
Managerial
Technical
Clerical
Hours/
Labor
Cost/
O&
M
Costs/
Number
of
@
$
114.04/
hr
@
$
89.44/
hr
@
$
58.54/
hr
@
$
30.62/
hr
Respondent
Respondent
Respondent
TSDFs
Total
Hours
Total
Cost
TSDFs
0.00
0.25
1.00
0.00
1.25
$
80.90
$
0.00
581
726
$
47,003
TOTAL
0.00
0.25
1.00
0.00
1.25
$
80.90
$
0.00
581
726
$
47,003
a
Exhibit
contains
rounding
error.

EXHIBIT
14
ESTIMATED
ANNUAL
HOUR
AND
COST
BURDEN
FOR
DESIGNATED
TREATMENT,
STORAGE,
AND
DISPOSAL
FACILITIES
(
TSDFs)
a
COMPLETING
THE
MANIFEST
(
ASSISTING
THE
GENERATORS)
Annual
Legal
Managerial
Technical
Clerical
Hours/
Labor
Cost/
O&
M
Costs/
Number
of
@
$
114.04/
hr
@
$
89.44/
hr
@
$
58.54/
hr
@
$
30.62/
hr
Respondent
Respondent
Respondent
Manifests
Total
Hours
Total
Cost
Complete
the
manifest
0.00
0.00
0.43
0.10
0.53
$
28.23
$
0.00
997,837
528,854
$
28,168,939
Complete
continuation
sheets
0.00
0.00
0.18
0.05
0.23
$
12.07
$
0.00
49,892
11,475
$
602,196
TOTAL
0.00
0.00
varies
varies
varies
varies
$
0.00
997,837
540,329
$
28,771,135
a
Exhibit
contains
rounding
error.
Hours
per
Transporter
Hours
per
TSDF
Hours
per
TSDF
Read
the
regulations
Notification
of
discharge
of
hazardous
waste:
Water
(
bulk
shipment)
Transporters
(
33
CFR
153.203)

Notification
of
discharge
of
hazardous
waste:
Transporters
(
263.30(
a))

Manifest
completion:
Designated
TSDFs
(
264.71(
a)
and
(
b),
or
265.71(
a)
and
(
b))
USEPA­
OSWER
ICR
801.15
30
Dec
2004
52
EXHIBIT
15
ESTIMATED
ANNUAL
HOUR
AND
COST
BURDEN
FOR
DESIGNATED
TREATMENT,
STORAGE,
AND
DISPOSAL
FACILITIES
(
TSDFs)
a
TRANSMITTING
THE
MANIFEST
AND
REPORTING
TO
EPA
Annual
Legal
Managerial
Technical
Clerical
Hours/
Labor
Cost/
O&
M
Costs/
Number
of
@
$
114.04/
hr
@
$
89.44/
hr
@
$
58.54/
hr
@
$
30.62/
hr
Respondent
Respondent
Respondent
Manifests
Total
Hours
Total
Cost
Enter
the
name
of
the
person
accepting
the
waste
and
sign
and
date
each
copy
of
the
manifest
(
or
shipping
paper,
if
applicable)
0.00
0.00
0.01
0.00
0.01
$
0.59
$
0.00
1,742,594
17,426
$
1,028,130
Complete
the
management
method
code
0.00
0.00
0.02
0.00
0.02
$
1.17
$
0.00
1,742,594
34,852
$
2,038,835
Note
any
discrepancies
on
each
copy
of
the
manifest
(
or
shipping
paper,
if
applicable)
0.00
0.00
0.08
0.00
0.08
$
4.68
$
0.00
425,386
34,031
$
1,990,806
Immediately
give
the
transporter
at
least
one
copy
of
the
manifest
(
or
shipping
paper)
0.00
0.00
0.17
0.00
0.17
$
9.95
$
0.00
1,742,594
296,241
$
17,338,810
Within
30
days
of
delivery,
send
a
copy
of
the
manifest
(
or
shipping
paper)
to
the
generator
(
or
to
EPA­
OECA
for
import
manifests)
0.00
0.00
0.00
0.15
0.15
$
4.59
$
0.38
1,760,218
264,033
$
8,748,284
Retain
a
copy
of
the
manifest
(
or
shipping
paper)
for
at
least
three
years
from
the
delivery
date
(
includes
import
manifests)
0.00
0.00
0.00
0.17
0.17
$
5.21
$
0.00
1,760,218
299,237
$
9,170,736
Subtotal
(
manifest
completion,
transmittal,
and
recordkeeping)
0.00
0.00
varies
varies
varies
varies
varies
varies
945,820
$
40,315,601
Contact
the
consignment/
generator
State
if
needed
and
submit
any
copies
of
the
manifest
to
these
States,
as
applicable
0.00
0.00
0.00
0.00
0.00
$
0.00
$
0.00
906
0
$
0
Contact
the
consignment/
generator
State
if
needed
and
submit
any
copies
of
the
manifest
to
these
States,
as
applicable
0.00
0.00
0.00
0.00
0.00
$
0.00
$
0.00
2,721
0
$
0
Subtotal
(
for
TSDFs)
0.00
0.00
0.00
0.00
0.00
$
0.00
$
0.00
3,627
0
$
0
Attempt
to
reconcile
any
discrepancies
0.00
0.00
0.08
0.00
0.08
$
4.68
$
2.00
425,386
34,031
$
2,841,578
Prepare
and
submit
a
letter
to
EPA
describing
the
discrepancy
and
attempts
to
reconcile
it,
along
with
a
copy
of
the
manifest
or
shipping
paper
at
issue
0.00
0.10
0.17
0.10
0.37
$
21.96
$
0.48
6,806
2,518
$
152,727
Subtotal
(
discrepancy
report)
0.00
varies
varies
varies
varies
varies
varies
varies
36,549
$
2,994,305
TOTAL
0.00
varies
varies
varies
varies
varies
varies
varies
982,369
$
43,309,906
a
Exhibit
contains
rounding
error.

Commercial
TSDFs
Captive
TSDFs
Discrepancy
report
completion
and
submission:
Designated
TSDFs
(
264.72(
c)
or
265.72(
c))

Manifest
completion,
transmittal
and
recordkeeping:
Designated
TSDFs
(
264.71(
a)
and
(
b),
or
265.71(
a)
and
(
b))

Hours
per
TSDF
Compliance
with
State
program
requirements:
TSDFs
who
are
also
generators
(
264.71(
e)
and
265.71(
e))
USEPA­
OSWER
ICR
801.15
30
Dec
2004
53
EXHIBIT
16
ESTIMATED
ANNUAL
HOUR
AND
COST
BURDEN
FOR
DESIGNATED
TREATMENT,
STORAGE,
AND
DISPOSAL
FACILITIES
(
TSDFs)
a
REJECTED
WASTE
AND
CONTAINER
RESIDUES
Legal
Managerial
Technical
Clerical
Hours/
Labor
Cost/
O&
M
Costs/
Number
of
@
$
114.04/
hr
@
$
89.44/
hr
@
$
58.54/
hr
@
$
30.62/
hr
Respondent
Respondent
Respondent
Manifests
Total
Hours
Total
Cost
Enter
the
name
of
the
person
accepting
the
waste
and
sign
and
date
each
copy
of
the
manifest
(
or
shipping
paper,
if
applicable)
0.00
0.00
0.01
0.00
0.01
$
0.59
$
0.00
29,337
293
$
17,309
Complete
the
management
method
code
0.00
0.00
0.02
0.00
0.02
$
1.17
$
0.00
29,337
587
$
34,324
Immediately
give
the
transporter
at
least
one
copy
of
the
manifest
(
or
shipping
paper)
0.00
0.00
0.17
0.00
0.17
$
9.95
$
0.00
29,337
4,987
$
291,903
Within
30
days
of
delivery,
send
a
copy
of
the
manifest
(
or
shipping
paper)
to
the
generator
0.00
0.00
0.00
0.16
0.16
$
4.90
$
0.00
29,337
4,694
$
143,751
Contact
the
generator
to
obtain
the
generator's
instructions
for
forwarding
the
waste
to
another
facility
that
can
manage
the
waste
0.00
0.00
0.08
0.00
0.08
$
4.68
$
2.00
29,337
2,347
$
195,971
Prepare
a
new
manifest
for
rejected
loads
or
container
residues
sent
to
the
alternate
designated
facility
or
back
to
the
generator
0.00
0.00
0.43
0.10
0.53
$
28.23
$
0.00
29,337
15,549
$
828,184
Amend
the
facility's
copy
of
the
manifest
to
indicate
the
rejected
wastes
or
residues
in
the
discrepancy
space
of
the
amended
manifest
0.00
0.00
0.01
0.00
0.01
$
0.59
$
0.00
29,337
293
$
17,309
Copy
the
manifest
tracking
number
from
Item
4
of
the
new
manifest
to
the
Discrepancy
space
of
the
amended
manifest
0.00
0.00
0.02
0.00
0.02
$
1.17
$
0.00
29,337
587
$
34,324
Re­
sign
and
date
the
manifest
0.00
0.00
0.01
0.00
0.01
$
0.59
$
0.00
29,337
293
$
17,309
Retain
the
amended
manifest
for
at
least
three
years
from
the
date
of
the
amendment
0.00
0.00
0.00
0.17
0.17
$
5.21
$
0.00
29,337
4,987
$
152,846
Within
30
days,
send
a
copy
of
the
amended
manifest
to
the
delivering
transporter
and
to
the
generator
0.00
0.00
0.00
0.16
0.16
$
4.90
$
0.38
29,337
4,694
$
154,899
Subtotal
0.00
0.00
varies
varies
varies
varies
varies
varies
39,311
$
1,888,129
Enter
the
name
of
the
person
accepting
the
waste
and
sign
and
date
each
copy
of
the
manifest
(
or
shipping
paper,
if
applicable)
0.00
0.00
0.01
0.00
0.01
$
0.59
$
0.00
29,337
293
$
17,309
Contact
the
generator
to
obtain
the
generator's
instructions
for
forwarding
the
waste
to
another
facility
that
can
manage
the
waste
0.00
0.00
0.08
0.00
0.08
$
4.68
$
2.00
29,337
2,347
$
195,971
Complete
Item
18a
and
18b
of
the
original
manifest,
as
applicable
0.00
0.00
0.08
0.00
0.08
$
4.68
$
0.00
29,337
2,347
$
137,297
Retain
a
copy
of
the
manifest
(
or
shipping
paper)
for
at
least
three
years
from
the
date
of
delivery
0.00
0.00
0.00
0.17
0.17
$
5.21
$
0.00
29,337
4,987
$
152,846
Give
the
remaining
copies
back
to
the
transporter
0.00
0.00
0.01
0.00
0.01
$
0.59
$
0.00
29,337
293
$
17,309
Subtotal
0.00
0.00
varies
varies
varies
varies
varies
varies
10,267
$
520,732
Enter
the
name
of
the
person
accepting
the
waste
and
sign
and
date
each
copy
of
the
manifest
(
or
shipping
paper,
if
applicable)
0.00
0.00
0.01
0.00
0.01
$
0.59
$
0.00
58,088
581
$
34,272
Complete
the
management
method
code
0.00
0.00
0.02
0.00
0.02
$
1.17
$
0.00
58,088
1,162
$
67,963
Note
any
discrepancies
on
each
copy
of
the
manifest
(
or
shipping
paper,
if
applicable)
0.00
0.00
0.08
0.00
0.08
$
4.68
$
0.00
58,088
4,647
$
271,852
Immediately
give
the
transporter
at
least
one
copy
of
the
manifest
(
or
shipping
paper)
0.00
0.00
0.17
0.00
0.17
$
9.95
$
0.00
58,088
9,875
$
577,976
Within
30
days
of
delivery,
send
a
copy
of
the
manifest
(
or
shipping
paper)
to
the
generator
0.00
0.00
0.00
0.16
0.16
$
4.90
$
0.38
58,088
9,294
$
306,704
Retain
a
copy
of
the
manifest
(
or
shipping
paper)
for
at
least
three
years
from
the
date
of
delivery
0.00
0.00
0.00
0.17
0.17
$
5.21
$
0.00
58,088
9,875
$
302,638
Subtotal
0.00
0.00
varies
varies
varies
varies
varies
varies
35,434
$
1,561,405
TOTAL
0.00
0.00
varies
varies
varies
varies
varies
varies
85,012
$
3,970,266
a
Exhibit
contains
rounding
error.

Manifest
completion,
transmittal
and
recordkeeping
by
Alternate
TSDFs
(
264.71(
a)
and
(
b),
or
265.71(
a)
and
(
b))

Rejected
waste
and
container
residues
(
264.72(
d)
through
(
g)
and
265.72(
d)
through
(
g))

Rejection
of
Waste
while
the
Transporter
Remains
Present
at
the
Facility
Rejection
of
Waste
after
the
Transporter
Leaves
the
Facility
Hours
per
TSDF
USEPA­
OSWER
ICR
801.15
30
Dec
2004
54
EXHIBIT
17
ESTIMATED
ANNUAL
HOUR
AND
COST
BURDEN
FOR
DESIGNATED
TREATMENT,
STORAGE,
AND
DISPOSAL
FACILITIES
(
TSDFs)
a
UNMANIFESTED
WASTE
REPORTS
Legal
Managerial
Technical
Clerical
Hours/
Labor
Cost/
O&
M
Costs/
Number
of
@
$
114.04/
hr
@
$
89.44/
hr
@
$
58.54/
hr
@
$
30.62/
hr
Respondent
Respondent
Respondent
Shipments
Total
Hours
Total
Cost
Prepare
and
submit
to
EPA
a
letter
of
the
unmanifested
waste
within
15
days
after
receiving
waste
0.00
0.50
1.00
0.50
2.00
$
118.57
$
0.48
173
346
$
20,596
TOTAL
0.00
0.50
1.00
0.50
2.00
$
118.57
$
0.48
173
346
$
20,596
a
Exhibit
contains
rounding
error.

Unmanifested
waste
report:
completion
and
submission
(
264.76(
a)
and
265.76(
a))
Hours
per
TSDF
USEPA­
OSWER
ICR
801.15
30
Dec
2004
55
EXHIBIT
18
TOTAL
ANNUAL
RESPONDENT
HOUR
AND
COST
BURDEN
BY
TYPE
OF
RESPONDENT
AND
MANIFESTING
ACTIVITY
a
Total
Hourly
Total
Annual
Total
Annual
Total
Annual
Total
Annual
Burden
Capital
Costs
O&
M
Costs
Labor
Costs
Costs
Reading
the
regulations
18
$
0
$
0
$
1,133
$
1,133
Applying
to
the
registry
29
$
0
$
7,127
$
1,771
$
8,898
Updating
general
information
in
the
approved
application
0
$
0
$
0
$
22
$
22
Requesting
approval
for
a
new
tracking
number
suffix
0
$
0
$
0
$
0
$
0
Requesting
approval
for
changes
to
printing
specifications
or
use
of
a
new
printer
0
$
0
$
0
$
0
$
0
Typesetting
the
manifest
form
subsequent
to
its
approval
0
$
0
$
0
$
0
$
0
Requesting
an
exemption
0
$
0
$
0
$
22
$
22
Notifying
EPA
of
a
printing
specification
violation
0
$
0
$
0
$
0
$
0
Revising
the
approved
manifest
if
requested
by
EPA
0
$
0
$
0
$
0
$
0
Responding
to
suspension
and
revocation
procedures
0
$
0
$
0
$
0
$
0
Subtotal
(
Registrant
Organizations)
47
$
0
$
7,127
$
2,948
$
10,075
Reading
the
regulations
164,754
$
0
$
0
$
10,662,863
$
10,662,863
Manifest
completion
(
without
assistance
of
designated
TSDF)
391,591
$
0
$
0
$
20,842,394
$
20,842,394
Manifest
completion
(
with
assistance
of
designated
TSDF)
29,935
$
0
$
0
$
1,476,799
$
1,476,799
Compliance
with
State
program
requirements
0
$
0
$
0
$
0
$
0
Manifest
transmittal
and
recordkeeping
402,333
$
0
$
62,221
$
12,812,681
$
12,874,902
Undeliverable
shipments
141
$
0
$
0
$
8,246
8,246
Rejected
waste
and
container
residues
6
$
0
$
0
$
346
$
346
Exception
report
completion,
submission,
and
recordkeeping
7,672
$
0
$
4,697
$
527,067
$
531,764
Subtotal
(
Generators)
996,432
$
0
$
66,918
$
46,330,396
$
46,397,314
Reading
the
regulations
518
$
0
$
0
$
33,493
$
33,493
Manifest
completion,
transmittal,
and
recordkeeping
(
domestic
+

imports
+
exports)
659,824
$
0
$
62,557
$
29,406,239
$
29,468,796
Undeliverable
shipments
141
$
0
$
3,524
$
8,246
$
11,770
Rejected
waste
and
container
residues
586
$
0
$
0
$
34,473
$
34,473
Notification
of
discharge
of
hazardous
waste
1,152
$
0
$
0
$
74,590
$
74,590
Subtotal
(
Transporters)
662,221
$
0
$
66,081
$
29,557,041
$
29,623,122
Reading
the
regulations
726
$
0
$
0
$
47,003
$
47,003
Manifest
completion
(
assisting
the
generators)
540,329
$
0
$
0
$
28,771,135
$
28,771,135
Manifest
transmittal
and
recordkeeping
(
domestic
+
imports)
945,820
$
0
$
668,883
$
39,646,718
$
40,315,601
Compliance
with
State
program
requirements
0
$
0
$
0
$
0
$
0
Discrepancy
report
completion
and
submission
36,549
$
0
$
854,039
$
2,140,266
$
2,994,305
Rejected
waste
and
container
residues
85,012
$
0
$
150,569
$
3,819,697
$
3,970,266
Unmanifested
waste
report
completion
and
submission
346
$
0
$
83
$
20,513
$
20,596
Subtotal
(
Designated
TSDFs)
1,608,782
$
0
$
1,673,574
$
74,445,332
$
76,118,906
File
cabinets
­­
$
846,080
­­
­­
$
846,080
TOTAL:
ALL
RESPONDENTS
3,267,482
$
846,080
$
1,813,700
$
150,335,717
$
152,995,497
a
Exhibit
contains
rounding
error.

Three
Year
Burden
9,802,446
$
458,986,491
Registrant
Organizations
Designated
TSDFs
Annualized
capital
costs
Transporters
Generators
(
LQGs,
SQGs,
TSDFs
acting
as
generators)
USEPA­
OSWER
ICR
801.15
30
Dec
2004
56
EXHIBIT
19
TOTAL
ANNUAL
AGENCY
HOUR
AND
COST
BURDEN
a
Number
of
Legal
Managerial
Technical
Clerical
Hours/
Labor
Cost/
O&
M
Costs/
Reports
@
$
66.26/
hr
@
$
47.66/
hr
@
$
33.44/
hr
@
$
20.34/
hr
Respondent
Respondent
Respondent
Received
Total
Hours
Total
Cost
Review
initial
application
0.00
0.10
0.40
0.00
0.50
$
18.14
$
0.00
14
7
$
254
Notify
registrant
of
EPA's
decision
regarding
its
application
0.00
0.00
0.00
0.10
0.10
$
2.03
$
0.38
14
1
$
33
Review
revised
application
0.00
0.10
0.40
0.00
0.50
$
18.14
$
0.00
7
4
$
127
If
application
is
approved,
provide
electronic
file
of
the
manifest,

continuation
sheet,
and
manifest
instructions
to
approved
registrant
and
request
manifest
form
samples
0.00
0.00
0.00
0.10
0.10
$
2.03
$
3.64
14
1
$
79
Evaluate
manifest
form
samples
0.00
0.10
0.40
0.00
0.50
$
18.14
$
0.00
14
7
$
254
Notify
registrant
of
EPA's
decision
regarding
its
manifest
form
samples
0.00
0.00
0.00
0.10
0.10
$
2.03
$
0.38
14
1
$
33
Evaluate
revised
manifest
form
samples
0.00
0.10
0.40
0.00
0.50
$
18.14
$
0.00
0
0
$
0
Review
revised
application
0.00
0.10
0.40
0.00
0.50
$
18.14
$
0.00
1
1
$
18
Review
documentation
submitted
by
registrant
0.00
0.10
0.40
0.00
0.50
$
18.14
$
0.00
0
0
$
0
Provide
new
tracking
number
suffix
to
registrant
0.00
0.10
0.25
0.10
0.45
$
15.16
$
0.38
0
0
$
0
Evaluate
manifest
form
samples
0.00
0.10
0.40
0.00
0.50
$
18.14
$
0.00
0
0
$
0
Evaluate
revised
manifest
form
samples
0.00
0.10
0.40
0.00
0.50
$
18.14
$
0.00
0
0
$
0
Evaluate
manifest
form
samples
0.00
0.10
0.40
0.00
0.50
$
18.14
$
0.00
0
0
$
0
Review
documentation
submitted
by
registrant
0.00
0.10
0.40
0.00
0.50
$
18.14
$
0.00
1
1
$
18
Receive
notification
that
a
serious
violation
of
a
printing
specification
0.00
0.20
0.80
0.00
1.00
$
36.28
$
0.00
0
0
$
0
Evaluate
revised
manifest
form
samples
0.00
0.10
0.40
0.00
0.50
$
18.14
$
0.00
0
0
$
0
Review
documentation
submitted
by
registrant
0.00
0.10
0.40
0.00
0.50
$
18.14
$
0.00
0
0
$
0
Subtotal
(
Registrant
Organizations)
0.00
varies
varies
varies
varies
varies
varies
varies
23
$
816
Requesting
Approval
for
Changes
to
Printing
Specifications
or
Use
of
a
New
Printer
(
262.21(
h)(
3))

Applying
to
the
registry
(
262.21(
c)
and
262.21(
e))

Updating
General
Information
in
the
Approved
Application
(
262.21(
h)(
1))
Hours
per
Agency
Respondent
Registrant
Organizations
Typesetting
the
Manifest
Form
Subsequent
to
its
Approval
(
262.21(
i))

Requesting
an
Exemption
(
262.21(
j))

Notifying
EPA
of
a
Printing
Specification
Violation
(
262.21(
k))

Revising
the
Approved
Manifest
if
Requested
by
EPA
(
262.21(
l))

Responding
to
Suspension
and
Revocation
Procedures
(
262.21(
m))

Requesting
Approval
for
a
New
Tracking
Number
Suffix
(
262.21(
h)(
2))
USEPA­
OSWER
ICR
801.15
30
Dec
2004
57
EXHIBIT
19
(
CONTINUED)

TOTAL
ANNUAL
AGENCY
HOUR
AND
COST
BURDEN
a
Number
of
Legal
Managerial
Technical
Clerical
Hours/
Labor
Cost/
O&
M
Costs/
Reports
@
$
66.26/
hr
@
$
47.66/
hr
@
$
33.44/
hr
@
$
20.34/
hr
Respondent
Respondent
Respondent
Received
Total
Hours
Total
Cost
Review
the
exception
report:
LQGs
0.00
0.10
0.40
0.00
0.50
$
18.14
$
0.00
3,976
1,988
$
72,125
Review
the
exception
report:
Commercial
TSDFs
0.00
0.10
0.40
0.00
0.50
$
18.14
$
0.00
525
263
$
9,524
Review
the
exception
report:
Captive
TSDFs
0.00
0.10
0.40
0.00
0.50
$
18.14
$
0.00
162
81
$
2,939
Review
the
exception
report:
SQGs
0.00
0.10
0.40
0.00
0.50
$
18.14
$
0.00
4,149
2,075
$
75,263
Subtotal
(
Generators)
0.00
0.10
0.40
0.00
0.50
$
18.14
$
0.00
varies
4,407
$
159,851
Receive
notification
of
discharge
0.00
0.20
0.80
0.00
1.00
$
36.28
$
0.00
73
73
$
2,648
Subtotal
(
Transporters)
0.00
0.20
0.80
0.00
1.00
$
36.28
$
0.00
73
73
$
2,648
Receive
import
manifests
(
264.71(
a)(
3)
&
265.71(
a)(
3))
0.00
0.00
0.10
0.00
0.10
$
3.34
$
0.00
17,624
1,762
$
58,864
Review
the
discrepancy
report
0.00
0.10
0.40
0.00
0.50
$
18.14
$
0.00
6,806
3,403
$
123,461
Review
unmanifested
waste
report
0.00
0.10
0.40
0.00
0.50
$
18.14
$
0.00
173
87
$
3,138
Subtotal
(
TSDFs)
0.00
0.10
0.40
0.00
0.50
$
18.14
$
0.00
varies
3,490
$
126,599
TOTAL:
AGENCY
0.00
varies
varies
varies
varies
varies
varies
varies
7,993
$
289,914
a
Exhibit
contains
rounding
error.
Three
Year
Burden
23,979
$
869,742
Notification
of
discharge
(
263.30(
a)
and
(
d))

Designated
TSDFs
Discrepancy
report
(
264.72(
a)
and
(
b)
and
265.72(
a)
and
(
b))

Unmanifested
waste
report
(
264.76
and
265.76)

Transporters
Exception
report
(
262.42)
Hours
per
Agency
Respondent
Generators
USEPA­
OSWER
ICR
801.15
30
Dec
2004
58
This
Exhibit
presents
a
summary
of
the
reasons
for
change
in
burden
hour
estimates
between
the
prior
approved
RCRA
manifest
ICR
801.14
(
01
April
2002),

compared
to
the
revised
RCRA
manifest
ICR
801.15.
The
primary
drivers
behind
the
changes
listed
in
the
Exhibit
below
are
changes
(
i.
e.
decrease
or
increase)
in
estimated:
(
a)
numbers
of
affected
entities,
(
b)
annual
numbers
of
affected
manifests,
(
c)
per­
manifest
burden
hours
associated
with
an
activity,
(
d)
deletion
or
addition
of
manifest
system
requirements
in
USEPA­
OSW's
revised
manifest
final
rule.
Exhibit
20
Summary
of
Changes
in
Burden
Hour
Estimates
Between
ICR
801.14
Compared
to
ICR
801.15
(
Decreases
in
burden
hour
estimates
are
shown
in
parentheses)

Changes
in
ICR
801.15
Burden
Hours
in
ICR
801.14
Burden
Hours
in
ICR
801.15
Change
in
Annual
Burden
Hours
in
ICR
801.15
A.
Respondent
Burden:

1
Addition
of
information
collection
requirements
associated
with
the
manifest
registry
at
40
CFR
262.21
0
47
47
2
Decrease
in
generators
reading
the
regulations
at
40
CFR
262
183,773
164,754
(
19,019)

3
Increase
in
LQGs
completing
manifests
and
continuation
sheets
without
assistance
of
designated
TSDFs
197,439
235,918
38,479
4
Decrease
in
TSDFs
completing
manifests
and
continuation
sheets
without
assistance
of
designated
TSDFs
102,954
74,269
(
28,685)

5
Decrease
in
SQGs
completing
manifests
and
continuation
sheets
without
assistance
of
designated
TSDFs
87,050
81,404
(
5,646)

6
Decrease
in
manifests
completed
by
LQGs
with
assistance
of
designated
TSDFs
10,500
10,020
(
480)

7
Decrease
in
manifests
completed
by
SQGs
with
assistance
of
designated
TSDFs
26,923
19,915
(
7,008)

8
Decrease
in
manifests
transmitted
and
recordkept
by
LQGs
193,223
180,739
(
12,484)

9
Decrease
in
manifests
transmitted
and
recordkept
by
TSDFs
54,178
31,336
(
22,842)

10
Decrease
in
manifests
transmitted
and
recordkept
by
SQGs
257,265
190,258
(
67,007)

11
Decrease
in
manifests
that
accompany
undeliverable
shipments
260
141
(
119)

12
Addition
of
information
collection
requirements
associated
with
rejected
loads
and
container
residues
at
40
CFR
262.34(
j)
0
6
6
13
Decrease
in
exception
reports
9,280
7,672
(
1,608)

14
Decrease
in
transporters
reading
the
regulations
at
40
CFR
263
625
518
(
107)

15
Decrease
in
manifests
associated
with
hazardous
waste
transporters
775,045
659,824
(
115,221)
USEPA­
OSWER
ICR
801.15
30
Dec
2004
Exhibit
20
Summary
of
Changes
in
Burden
Hour
Estimates
Between
ICR
801.14
Compared
to
ICR
801.15
(
Decreases
in
burden
hour
estimates
are
shown
in
parentheses)

Changes
in
ICR
801.15
Burden
Hours
in
ICR
801.14
Burden
Hours
in
ICR
801.15
Change
in
Annual
Burden
Hours
in
ICR
801.15
59
16
Decrease
in
manifests
that
accompany
undeliverable
shipments
1,040
141
(
899)

17
Addition
of
information
collection
requirements
associated
with
rejected
loads
and
container
residues
at
40
CFR
263.21(
b)(
2)
0
586
586
18
Increase
in
notifications
of
discharge
1,042
1,152
110
19
Decrease
in
TSDFs
reading
the
regulations
at
40
CFR
264
&
265
785
726
(
59)

20
Decrease
in
TSDFs
assisting
generators
to
complete
their
manifests
&
continuation
sheets
546,993
540,329
(
6,664)

21
Decrease
in
manifests
received
by
designated
TSDFs
1,116,694
945,820
(
170,874)

22
Decrease
in
discrepancy
reports
47,032
36,549
(
10,483)

23
Addition
of
information
collection
requirements
associated
with
rejected
loads
and
container
residues
at
40
CFR
264.72
&
265.72
0
85,012
85,012
24
Decrease
in
unmanifested
shipments
438
346
(
92)

Sub­
Total
Respondent
Burden
=
3,612,539
3,267,486
(
345,053)

B.
Agency
Burden
10,067
7,993
(
2,074)

Resultant
Overall
Annual
Burden
Hour
s
(
Respondents
+
Agency)
=
3,622,606
3,275,475
(
337,064)

Resultant
Overall
3­
Year
Burden
Hours
(
Respondents
+
Agency)
=
10,867,818
9,826,425
(
1,041,393)

Note:
USEPA­
OSW's
revised
manifest
final
rule
added
import
manifest
reporting
and
recordkeeping
requirements
at
40
CFR
264.71(
a)(
3)
&
265.71(
a)(
3),
which
are
included
in
items
above
and
not
listed
above
to
avoid
double­
counting,
but
sub­
total
10,750
additional
burden
hours
(
respondents
+
Agency).
USEPA­
OSWER
ICR
801.15
60
REVISED
RCRA
MANIFEST
FORM
(
EPA
Form
8700­
22
and
8700­
22A
Continuation
Sheet)
USEPA­
OSWER
ICR
801.15
61
INSTRUCTIONS
(
EPA
FORMS
8700­
22
AND
8700­
22A
AND
THEIR
INSTRUCTIONS)
U.
S.
EPA
FORM
8700­
22
Read
all
instructions
before
completing
this
form.
1.
This
form
has
been
designed
for
use
on
a
12­
pitch
(
elite)
typewriter
which
is
also
compatible
with
standard
computer
printers;
a
firm
point
pen
may
also
be
used
­­
press
down
hard.
2.
Federal
regulations
require
generators
and
transporters
of
hazardous
waste
and
owners
or
operators
of
hazardous
waste
treatment,
storage,
and
disposal
facilities
to
complete
this
form
(
8700­
22)
and,
if
necessary,
the
continuation
sheet
(
8700­
22A)
for
both
inter­
and
intrastate
transportation
of
hazardous
waste.
USEPA­
OSWER
ICR
801.15
62
[
INSERT
MANIFEST
FORM
(
EPA
FORM
8700­
22)
HERE]
USEPA­
OSWER
ICR
801.15
63
The
OMB
Control
Number
must
appear
on
the
front
page
of
an
OMB­
approved
form
or
survey,
or
on
the
first
screen
viewed
by
the
respondent
for
an
on­
line
application.
The
rest
of
the
burden
statement
must
be
included
somewhere
on
the
form,
questionnaire
or
other
collection
of
information,
or
in
the
instructions
for
such
collection.
OMB
Control
No.
2050­
0039
The
following
statement
must
be
included
with
each
Uniform
Hazardous
Waste
Manifest,
either
on
the
form,
in
the
instructions
to
the
form,
or
accompanying
the
form:
Public
reporting
burden
for
this
collection
of
information
is
estimated
to
average:
30
minutes
for
generators,
10
minutes
for
transporters,
and
25
minutes
for
owners
or
operators
of
treatment,
storage,
and
disposal
facilities.
This
includes
time
for
reviewing
instructions,
gathering
data,
completing,
reviewing
and
transmitting
the
form.
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,
1200
Pennsylvania
Ave.,
NW,
Washington,
D.
C.
20460.
Include
the
OMB
control
number
in
any
correspondence.
Do
not
send
the
completed
form
to
this
address.
_________________________________________________________________
I.
INSTRUCTIONS
FOR
GENERATORS
Item
1.
Generator's
U.
S.
EPA
Identification
Number
Enter
the
generator's
U.
S.
EPA
twelve
digit
identification
number,
or
the
State
generator
identification
number
if
the
generator
site
does
not
have
an
EPA
identification
number.
Item
2.
Page
1
of
_____
Enter
the
total
number
of
pages
used
to
complete
this
Manifest
(
i.
e.,
the
first
page
(
EPA
Form
8700­
22)
plus
the
number
of
Continuation
Sheets
(
EPA
Form
8700­
22A),
if
any).
Item
3.
Emergency
Response
Phone
Number
Enter
a
phone
number
for
which
emergency
response
information
can
be
obtained
in
the
event
of
an
incident
during
transportation.
The
emergency
response
phone
number
must:
1.
Be
the
number
of
the
generator
or
the
number
of
an
agency
or
organization
who
is
capable
of
and
accepts
responsibility
for
providing
detailed
information
about
the
shipment;
2.
Reach
a
phone
that
is
monitored
24
hours
a
day
at
all
times
the
waste
is
in
transportation
(
including
transportation
related
storage);
and
3.
Reach
someone
who
is
either
knowledgeable
of
the
hazardous
waste
being
shipped
and
has
comprehensive
emergency
response
and
spill
cleanup/
incident
mitigation
information
for
the
material
being
shipped
or
has
immediate
access
to
a
person
who
has
that
knowledge
and
information
about
the
shipment.
Note:
Emergency
Response
phone
number
information
should
only
be
entered
in
Item
3
when
there
is
one
phone
number
that
applies
to
all
the
waste
materials
described
in
Item
9b.
If
a
situation
(
e.
g.,
consolidated
shipments)
arises
where
more
than
one
Emergency
Response
phone
number
applies
to
the
various
wastes
listed
on
the
manifest,
the
phone
numbers
associated
with
each
specific
material
should
be
entered
after
its
description
in
Item
9b.
Item
4.
Manifest
Tracking
Number
This
unique
tracking
number
must
be
pre­
printed
on
the
manifest
by
the
forms
printer.
Item
5.
Generator's
Mailing
Address,
Phone
Number
and
Site
Address
Enter
the
name
of
the
generator,
the
mailing
address
to
which
the
completed
manifest
signed
by
the
designated
facility
should
be
mailed,
and
the
generator's
telephone
number.
Note,
the
telephone
number
(
including
area
code)
should
be
the
number
where
the
generator
or
his
authorized
agent
may
be
reached
to
provide
instructions
in
the
event
of
an
emergency
or
if
the
designated
and/
or
alternate
(
if
any)
facility
rejects
some
or
all
of
the
shipment.
Also
enter
the
physical
site
address
from
which
the
shipment
originates
only
if
this
address
is
different
than
the
mailing
address
Item
6.
Transporter
1
Company
Name,
and
U.
S.
EPA
ID
Number
Enter
the
company
name
and
U.
S.
EPA
ID
number
of
the
first
transporter
who
will
transport
the
waste.
Vehicle
or
driver
information
may
not
be
entered
here.
Item
7.
Transporter
2
Company
Name
and
U.
S.
EPA
ID
Number
If
applicable,
enter
the
company
name
and
U.
S.
EPA
ID
number
of
the
second
transporter
who
will
transport
the
waste.
Vehicle
or
driver
information
may
not
be
entered
here.
If
more
than
two
transporters
are
needed,
use
a
Continuation
Sheet(
s)
(
EPA
Form
8700
­
22A).
Item
8.
Designated
Facility
Name,
Site
Address,
and
U.
S.
EPA
ID
Number
Enter
the
company
name
and
site
address
of
the
facility
designated
to
receive
the
waste
listed
on
this
manifest.
Also
enter
the
facility's
phone
number
and
the
U.
S.
EPA
twelve
digit
identification
number
of
the
facility.
Item
9.
U.
S.
DOT
Description
(
Including
Proper
Shipping
Name,
Hazard
Class
or
Division,
Identification
Number,
and
Packing
Group)
USEPA­
OSWER
ICR
801.15
64
Item
9a.
If
the
wastes
identified
in
Item
9b
consist
of
both
hazardous
and
nonhazardous
materials,
then
identify
the
hazardous
materials
by
entering
an
"
X"
in
this
Item
next
to
the
corresponding
hazardous
material
identified
in
Item
9b.
Item
9b.
Enter
the
U.
S.
DOT
Proper
Shipping
Name,
Hazard
Class
or
Division,
Identification
Number
(
UN/
NA)
and
Packing
Group
for
each
waste
as
identified
in
49
CFR
172.
Include
technical
name(
s)
and
reportable
quantity
references,
if
applicable.
NOTE:
If
additional
space
is
needed
for
waste
descriptions,
enter
these
additional
descriptions
in
Item
27
on
the
Continuation
Sheet
(
EPA
Form
8700­
22A).
Also,
if
more
than
one
Emergency
Response
phone
number
applies
to
the
various
wastes
described
in
either
Item
9b
or
Item
27,
enter
applicable
Emergency
Response
phone
numbers
immediately
following
the
shipping
descriptions
for
those
Items.
Item
10.
Containers
(
Number
and
Type)
Enter
the
number
of
containers
for
each
waste
and
the
appropriate
abbreviation
from
Table
I
(
below)
for
the
type
of
container.
TABLE
I.
TYPES
OF
CONTAINERS
BA
=
Burlap,
cloth,
paper,
or
plastic
bags
CF
=
Fiber
or
plastic
boxes,
cartons,
cases
CM
=
Metal
boxes,
cartons,
cases
(
including
roll­
offs)
CW
=
Wooden
boxes,
cartons,
cases
CY
=
Cylinders
DF
=
Fiberboard
or
plastic
drums,
barrels,
kegs
DM
=
Metal
drums,
barrels,
kegs
DT
=
Dump
truck
DW
=
Wooden
drums,
barrels,
kegs
HG
=
Hopper
or
gondola
cars
TC
=
Tank
cars
TP
=
Portable
tanks
TT
=
Cargo
tanks
(
tank
trucks)
Item
11.
Total
Quantity
Enter,
in
designated
boxes,
the
total
quantity
of
waste.
Round
partial
units
to
the
nearest
whole
unit,
and
do
not
enter
decimals
or
fractions.
To
the
extent
practical,
report
quantities
using
appropriate
units
of
measure
that
will
allow
you
to
report
quantities
with
precision.
Waste
quantities
entered
should
be
based
on
actual
measurements
or
reasonably
accurate
estimates
of
actual
quantities
shipped.
Container
capacities
are
not
acceptable
as
estimates.
Item
12.
Units
of
Measure
(
Weight/
Volume)
Enter,
in
designated
boxes,
the
appropriate
abbreviation
from
Table
II
(
below)
for
the
unit
of
measure.
TABLE
II.
UNITS
OF
MEASURE
G
=
Gallons
(
liquids
only)
K
=
Kilograms
L
=
Liters
(
liquids
only)
M
=
Metric
Tons
(
1000
kilograms)
N
=
Cubic
Meters
P
=
Pounds
T
=
Tons
(
2000
pounds)
Y
=
Cubic
Yards
Note:
Tons,
Metric
Tons,
Cubic
Meters,
and
Cubic
Yards
should
only
be
reported
in
connection
with
very
large
bulk
shipments,
such
as
rail
cars,
tank
trucks,
or
barges.
Item
13.
Waste
Codes
Enter
up
to
six
federal
and
state
waste
codes
to
describe
each
waste
stream
identified
in
Item
9b.
State
waste
codes
that
are
not
redundant
with
federal
codes
must
be
entered
here,
in
addition
to
the
federal
waste
codes
which
are
most
representative
of
the
properties
of
the
waste.
Item
14.
Special
Handling
Instructions
and
Additional
Information.
1.
Generators
may
enter
any
special
handling
or
shipment­
specific
information
necessary
for
the
proper
management
or
tracking
of
the
materials
under
the
generator's
or
other
handler's
business
processes,
such
as
waste
profile
numbers,
container
codes,
bar
codes,
or
response
guide
numbers.
Generators
also
may
use
this
space
to
enter
additional
descriptive
information
about
their
shipped
materials,
such
as
chemical
names,
constituent
percentages,
physical
state,
or
specific
gravity
of
wastes
identified
with
volume
units
in
Item
12.
2.
This
space
may
be
used
to
record
limited
types
of
federally
required
information
for
which
there
is
no
specific
space
provided
on
the
manifest,
including
any
alternate
facility
designations;
the
manifest
tracking
number
of
the
original
manifest
for
rejected
wastes
and
residues
that
are
re­
shipped
under
a
second
manifest;
and
the
specification
of
PCB
waste
USEPA­
OSWER
ICR
801.15
65
descriptions
and
PCB
out­
of­
service
dates
required
under
40
CFR
761.207.
Generators,
however,
cannot
be
required
to
enter
information
in
this
space
to
meet
state
regulatory
requirements.
Item
15.
Generator's/
Offeror's
Certifications
1.
The
generator
must
read,
sign,
and
date
the
waste
minimization
certification
statement.
In
signing
the
waste
minimization
certification
statement,
those
generators
who
have
not
been
exempted
by
statute
or
regulation
from
the
duty
to
make
a
waste
minimization
certification
under
section
3002(
b)
of
RCRA
are
also
certifying
that
they
have
complied
with
the
waste
minimization
requirements.
The
Generator's
Certification
also
contains
the
required
attestation
that
the
shipment
has
been
properly
prepared
and
is
in
proper
condition
for
transportation
(
the
shipper's
certification).
The
content
of
the
shipper's
certification
statement
is
as
follows:
I
hereby
declare
that
the
contents
of
this
consignment
are
fully
and
accurately
described
above
by
proper
shipping
name
and
are
classified,
packed,
marked,
and
labeled,
and
are
in
all
respects
in
proper
condition
for
transport
by
highway
according
to
applicable
international
and
national
governmental
regulations.
When
a
party
other
than
the
generator
prepares
the
shipment
for
transportation,
this
party
may
also
sign
the
shipper's
certification
statement
as
the
offeror
of
the
shipment.
2.
Generator
or
Offeror
personnel
may
preprint
the
words,
"
On
behalf
of"
in
the
signature
block
or
may
hand
write
this
statement
in
the
signature
block
prior
to
signing
the
generator/
offeror
certification,
to
indicate
that
the
individual
signs
as
the
employee
or
agent
of
the
named
principal.
NOTE:
All
of
the
above
information
except
the
handwritten
signature
required
in
Item
15
may
be
pre­
printed.
______________________________________________________________________________
II.
INSTRUCTIONS
FOR
INTERNATIONAL
SHIPMENT
BLOCK
Item
16.
International
Shipments
For
export
shipments,
the
primary
exporter
must
check
the
export
box,
and
enter
the
point
of
exit
(
city
and
state)
from
the
United
States.
For
import
shipments,
the
importer
must
check
the
import
box
and
enter
the
point
of
entry
(
city
and
state)
into
the
United
States.
For
exports,
the
transporter
must
sign
and
date
the
manifest
to
indicate
the
day
the
shipment
left
the
United
States.
Transporters
of
hazardous
waste
shipments
must
deliver
a
copy
of
the
manifest
to
the
U.
S.
Customs
when
exporting
the
waste
across
U.
S.
borders.

III.
INSTRUCTIONS
FOR
TRANSPORTERS
Item
17.
Transporters'
Acknowledgments
of
Receipt
Enter
the
name
of
the
person
accepting
the
waste
on
behalf
of
the
first
transporter.
That
person
must
acknowledge
acceptance
of
the
waste
described
on
the
manifest
by
signing
and
entering
the
date
of
receipt.
Only
one
signature
per
transportation
company
is
required.
Signatures
are
not
required
to
track
the
movement
of
wastes
in
and
out
of
transfer
facilities,
unless
there
is
a
change
of
custody
between
transporters.
If
applicable,
enter
the
name
of
the
person
accepting
the
waste
on
behalf
of
the
second
transporter.
That
person
must
acknowledge
acceptance
of
the
waste
described
on
the
manifest
by
signing
and
entering
the
date
of
receipt.

NOTE:
Transporters
acting
as
importers
may
have
responsibilities
to
enter
information
in
the
International
Shipments
Block.
Transporters
carrying
exports
may
also
have
responsibilities
to
enter
information
in
the
International
Shipments
Block
See
above
instructions
for
Item
16.
IV.
INSTRUCTIONS
FOR
OWNERS
AND
OPERATORS
OF
TREATMENT,
STORAGE,
AND
DISPOSAL
FACILITIES
Item
18
Discrepancy
Item
18a.
Discrepancy
Indication
Space
1.
The
authorized
representative
of
the
designated
(
or
alternate)
facility's
owner
or
operator
must
note
in
this
space
any
discrepancies
between
the
waste
described
on
the
Manifest
and
the
waste
actually
received
at
the
facility.
Manifest
discrepancies
are:
significant
differences
(
as
defined
by
§
§
264.72(
b)
and
265.72(
b))
between
the
quantity
or
type
of
hazardous
waste
designated
on
the
manifest
or
shipping
paper,
and
the
quantity
and
type
of
hazardous
waste
a
facility
actually
receives,
rejected
wastes,
which
may
be
a
full
or
partial
shipment
of
hazardous
waste
that
the
TSDF
cannot
accept,
or
container
residues,
which
are
residues
that
exceed
the
quantity
limits
for
"
empty"
containers
set
forth
in
40
CFR
261.7(
b).
2.
For
rejected
loads
and
residues
(
40
CFR
264.72(
d),
(
e),
and
(
f),
or
40
CFR
265.72(
d),
(
e),
or
(
f)),
check
the
appropriate
box
if
the
shipment
is
a
rejected
load
(
i.
e.,
rejected
by
the
designated
and/
or
alternate
facility
and
is
sent
to
an
alternate
facility
or
returned
to
the
generator)
or
a
regulated
residue
that
cannot
be
removed
from
a
container.
Enter
the
reason
for
the
rejection
or
the
inability
to
remove
the
residue
and
a
description
of
the
waste.
Also,
reference
the
manifest
tracking
number
for
any
additional
manifests
being
used
to
track
the
rejected
waste
or
residue
shipment
on
the
original
manifest.
Indicate
the
original
manifest
tracking
number
in
Item
14,
the
Special
Handling
Block
and
Additional
Information
Block
of
the
additional
manifests.
USEPA­
OSWER
ICR
801.15
66
3.
Owners
or
operators
of
facilities
located
in
unauthorized
States
(
i.
e.,
states
in
which
the
U.
S.
EPA
administers
the
hazardous
waste
management
program)
who
cannot
resolve
significant
differences
in
quantity
or
type
within
15
days
of
receiving
the
waste
must
submit
to
their
Regional
Administrator
a
letter
with
a
copy
of
the
Manifest
at
issue
describing
the
discrepancy
and
attempts
to
reconcile
it
(
40
CFR
264.72(
c)
and
265.72(
c)).
4.
Owners
or
operators
of
facilities
located
in
authorized
States
(
i.
e.,
those
States
that
have
received
authorization
from
the
U.
S.
EPA
to
administer
the
hazardous
waste
management
program)
should
contact
their
State
agency
for
information
on
where
to
report
discrepancies
involving
"
significant
differences"
to
state
officials.
Item
18b.
Alternate
Facility
(
or
Generator)
for
Receipt
of
Full
Load
Rejections
Enter
the
name,
address,
phone
number,
and
EPA
Identification
Number
of
the
Alternate
Facility
which
the
rejecting
TSDF
has
designated,
after
consulting
with
the
generator,
to
receive
a
fully
rejected
waste
shipment.
In
the
event
that
a
fully
rejected
shipment
is
being
returned
to
the
generator,
the
rejecting
TSDF
may
enter
the
generator's
site
information
in
this
space.
This
field
is
not
to
be
used
to
forward
partially
rejected
loads
or
residue
waste
shipments.
Item
18c.
Alternate
Facility
(
or
Generator)
Signature.
The
authorized
representative
of
the
alternate
facility
(
or
the
generator
in
the
event
of
a
returned
shipment)
must
sign
and
date
this
field
of
the
form
to
acknowledge
receipt
of
the
fully
rejected
wastes
or
residues
identified
by
the
initial
TSDF.
Item
19.
Hazardous
Waste
Report
Management
Method
Codes
Enter
the
most
appropriate
Hazardous
Waste
Report
Management
Method
code
for
each
waste
listed
in
Item
9.
The
Hazardous
Waste
Report
Management
Method
code
is
to
be
entered
by
the
first
treatment,
storage,
or
disposal
facility
(
TSDF)
that
receives
the
waste
and
is
the
code
that
best
describes
the
way
in
which
the
waste
is
to
be
managed
when
received
by
the
TSDF.
Item
20.
Designated
Facility
Owner
or
Operator
Certification
of
Receipt
(
Except
As
Noted
in
Item
18a)
Enter
the
name
of
the
person
receiving
the
waste
on
behalf
of
the
owner
or
operator
of
the
facility.
That
person
must
acknowledge
receipt
or
rejection
of
the
waste
described
on
the
Manifest
by
signing
and
entering
the
date
of
receipt
or
rejection
where
indicated.
Since
the
Facility
Certification
acknowledges
receipt
of
the
waste
except
as
noted
in
the
Discrepancy
Space
in
Item
18a,
the
certification
should
be
signed
for
both
waste
receipt
and
waste
rejection,
with
the
rejection
being
noted
and
described
in
the
space
provided
in
Item
18a.
Fully
rejected
wastes
may
be
forwarded
or
returned
using
Item
18b
after
consultation
with
the
generator.
Enter
the
name
of
the
person
accepting
the
waste
on
behalf
of
the
owner
or
operator
of
the
alternate
facility
or
the
original
generator.
That
person
must
acknowledge
receipt
or
rejection
of
the
waste
described
on
the
Manifest
by
signing
and
entering
the
date
they
received
or
rejected
the
waste
in
Item
18c.
Partially
rejected
wastes
and
residues
must
be
re­
shipped
under
a
new
manifest,
to
be
initiated
and
signed
by
the
rejecting
TSDF
as
offeror
of
the
shipment.
USEPA­
OSWER
ICR
801.15
67
[
INSERT
MANIFEST
CONTINUATION
SHEET
(
EPA
FORM
8700­
22A)
HERE]
USEPA­
OSWER
ICR
801.15
68
INSTRUCTIONS
 
CONTINUATION
SHEET,
U.
S.
EPA
FORM
8700­
22A
Read
all
instructions
before
completing
this
form.
This
form
has
been
designed
for
use
on
a
12­
pitch
(
elite)
typewriter;
a
firm
point
pen
may
also
be
used
 
press
down
hard.
This
form
must
be
used
as
a
continuation
sheet
to
U.
S.
EPA
Form
8700­
22
if:
°
More
than
two
transporters
are
to
be
used
to
transport
the
waste;
or
°
More
space
is
required
for
the
U.
S.
DOT
descriptions
and
related
information
in
Item
9
of
U.
S.
EPA
Form
8700­
22.
Federal
regulations
require
generators
and
transporters
of
hazardous
waste
and
owners
or
operators
of
hazardous
waste
treatment,
storage,
or
disposal
facilities
to
use
the
uniform
hazardous
waste
manifest
(
EPA
Form
8700­
22)
and,
if
necessary,
this
continuation
sheet
(
EPA
Form
8700­
22A)
for
both
interstate
and
intrastate
transportation.
Item
21.
Generator's
ID
Number
Enter
the
generator's
U.
S.
EPA
twelve
digit
identification
number
or,
the
State
generator
identification
number
if
the
generator
site
does
not
have
an
EPA
identification
number.
Item
22.
Page
___
 
Enter
the
page
number
of
this
Continuation
Sheet.
Item
23.
Manifest
Tracking
Number
Enter
the
Manifest
Tracking
number
from
Item
4
of
the
Manifest
form
to
which
this
continuation
sheet
is
attached.
Item
24.
Generator's
Name
 
Enter
the
generator's
name
as
it
appears
in
Item
5
on
the
first
page
of
the
Manifest.
Item
25.
Transporter
 
Company
Name
If
additional
transporters
are
used
to
transport
the
waste
described
on
this
Manifest,
enter
the
company
name
of
each
additional
transporter
in
the
order
in
which
they
will
transport
the
waste.
Enter
after
the
word
"
Transporter"
the
order
of
the
transporter.
For
example,
Transporter
3
Company
Name.
Also
enter
the
U.
S.
EPA
twelve
digit
identification
number
of
the
transporter
described
in
Item
25.
Item
26.
Transporter
 
Company
Name
If
additional
transporters
are
used
to
transport
the
waste
described
on
this
Manifest,
enter
the
company
name
of
each
additional
transporter
in
the
order
in
which
they
will
transport
the
waste.
Enter
after
the
word
"
Transporter"
the
order
of
the
transporter.
For
example,
Transporter
4
Company
Name.
Each
Continuation
Sheet
can
record
the
names
of
two
additional
transporters.
Also
enter
the
U.
S.
EPA
twelve
digit
identification
number
of
the
transporter
named
in
Item
26.
Item
27.
U.
S.
D.
O.
T.
Description
Including
Proper
Shipping
Name,
Hazardous
Class,
and
ID
Number
(
UN/
NA)
For
each
row
enter
a
sequential
number
under
Item
27b
that
corresponds
to
the
order
of
waste
codes
from
one
continuation
sheet
to
the
next,
to
reflect
the
total
number
of
wastes
being
shipped.
Refer
to
instructions
for
Item
9
of
the
manifest
for
the
information
to
be
entered.
Item
28.
Containers
(
No.
And
Type)
Refer
to
the
instructions
for
Item
10
of
the
manifest
for
information
to
be
entered.
Item
29.
Total
Quantity
Refer
to
the
instructions
for
Item
11
of
the
manifest
form.
Item
30.
Units
of
Measure
(
Weight/
Volume)
Refer
to
the
instructions
for
Item
12
of
the
manifest
form.
Item
31.
Waste
Codes
Refer
to
the
instructions
for
Item
13
of
the
manifest
form.
Item
32.
Special
Handling
Instructions
and
Additional
Information
Refer
to
the
instructions
for
Item
14
of
the
manifest
form.

TRANSPORTERS
Item
33.
Transporter
 
Acknowledgment
of
Receipt
of
Materials
Enter
the
same
number
of
the
Transporter
as
identified
in
Item
25.
Enter
also
the
name
of
the
person
accepting
the
waste
on
behalf
of
the
Transporter
(
Company
Name)
identified
in
Item
25.
That
person
must
acknowledge
acceptance
of
the
waste
described
on
the
Manifest
by
signing
and
entering
the
date
of
receipt.
Item
34.
Transporter
 
Acknowledgment
of
Receipt
of
Materials
Enter
the
same
number
of
the
Transporter
as
identified
in
Item
26.
Enter
also
the
name
of
the
person
accepting
the
waste
on
behalf
of
the
Transporter
(
Company
Name)
identified
in
Item
26.
That
person
must
acknowledge
acceptance
of
the
waste
described
on
the
Manifest
by
signing
and
entering
the
date
of
receipt.
OWNER
AND
OPERATORS
OF
TREATMENT,
STORAGE,
OR
DISPOSAL
FACILITIES
Item
35.
Discrepancy
Indication
Space
Refer
to
Item
18.
This
space
may
be
used
to
more
fully
describe
information
on
discrepancies
identified
in
Item
18a
of
the
manifest
form.
USEPA­
OSWER
ICR
801.15
69
Item
36.
Hazardous
Waste
Report
Management
Method
Codes
For
each
field
here,
enter
the
sequential
number
that
corresponds
to
the
waste
materials
described
under
Item
27,
and
enter
the
appropriate
process
code
that
describes
how
the
materials
will
be
processed
when
received.
If
additional
continuation
sheets
are
attached,
continue
numbering
the
waste
materials
and
process
code
fields
sequentially,
and
enter
on
each
sheet
the
process
codes
corresponding
to
the
waste
materials
identified
on
that
sheet.
USEPA­
OSWER
ICR
801.15
70
