ENVIRONMENTAL
PROTECTION
AGENCY
AGENCY
INFORMATION
COLLECTION
ACTIVITIES:
Final
Authorization
for
Hazardous
Waste
Management;
response
to
comments
SUMMARY:
One
(
1)
comment
was
received
in
response
to
the
proposed
information
collection
request
from
the
Association
of
State
and
Territorial
Solid
Waste
Management
Officials
(
ASTSWMO).
The
comment
stated
that
the
burden
calculation
in
the
ICR
seriously
underestimated
the
actual
burden
experienced
by
respondents
in
generating
the
required
documents
and
interacting
with
EPA
to
resolve
authorization
issues.

ASTSWMO
stated
that
the
record
keeping
and
reporting
estimates
contained
within
the
Burden
Statement
of
the
proposed
ICR
significantly
underestimate
the
actual
time
required
by
State
staff
to
generate
the
necessary
documents
and
interact
with
EPA
to
resolve
authorization
issues.
ASTSWMO
polled
some
of
their
members
and
determined
that
burden
should
be
increased
to
880
hours
per
respondent
(
44,000
total)
from
the
ICR
estimate
of
11,376
hours.
ASTSWMO
recommended
several
documentary
and
process
changes
that
would
decrease
their
burden.
ASTSWMO
also
recommended
that
EPA
identify
processes
that
would
lend
themselves
to
automatic
approvals
vice
the
current
practice
of
State
submission
of
documents
and
EPA
review
and
approval.

RESPONSE
TO
COMMENTS:

The
ICR
calculation
is
based
on
the
number
of
rules
expected
to
be
promulgated
during
the
period
of
the
ICR,
and
institutional
process
changes
that
will
occur
during
this
period.
EPA
has
restructured
the
authorization
process
to
include
many
of
the
recommendations
that
the
commentor
suggested.
This
restructuring
is
called
"
Express
Authorization",
and
it
significantly
reduces
the
volume
of
materials
that
States
need
to
prepare
in
order
to
revise
their
RCRA
programs.
Express
Authorization,
along
with
the
Abbreviated
authorization
process
for
minor
and
routine
rules
(
40
CFR
271.21(
h)),
provide
States
and
EPA
with
more
tools
to
reduce
the
administrative
burden
of
program
revisions.
A
significant
portion
of
the
burden
experienced
by
each
State
is
dependent
upon
factors
that
are
not
controlled
by
the
process
outlined
in
the
ICR.
The
method
by
which
the
States
use
to
revise
their
program,
and
the
administrative
requirement's
States
levy
on
their
staff
is
a
significant
factor
in
the
amount
of
burden
experienced.
The
amount
of
burden
incurred
in
developing
and
revising
the
hazardous
waste
program
ranges
widely
based
on
these
issues.
The
burden
hours
for
program
revisions
was
recalculated
based
on
the
comment
received
to
average
399
hours
per
respondent.
The
requirements
for
the
authorization
of
the
hazardous
waste
program
are
statutory
and
cannot
be
modified
to
the
certification
proposal
that
ASTSWMO
advocates
without
an
act
of
Congress.
However,
many
of
the
bottlenecks
experienced
by
the
States
and
EPA
could
be
eliminated
or
significantly
reduced
with
better
communication
and
cooperation.
The
key
to
decreasing
burden
within
the
current
system
is
to
utilize
the
process
tools;
implement
abbreviated
authorization
procedures
provided
by
EPA,
and
by
streamlining
the
internal
processes
of
the
respondents
and
EPA.
