SUPPORTING
STATEMENT
FOR
EPA
INFORMATION
COLLECTION
REQUEST
NUMBER
1597.05
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
THE
PROPOSED
RULE
ON
MERCURY­
CONTAINING
EQUIPMENT
REUSE
AND
RECYCLING
DRAFT
November
2001
Page
i
TABLE
OF
CONTENTS
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
........................
1
1(
a)
Title
and
Number
of
Information
Collection
.................................
1
1(
b)
Characterization
of
the
Information
Collection
................................
1
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
...................................
3
2(
a)
Need
and
Authority
for
the
Collection
......................................
3
2(
b)
Use
and
Users
of
the
Data
...............................................
3
3.
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
.........................
3
3(
a)
Respondents
and
SIC
Codes
.............................................
3
3(
b)
Information
Requested
.................................................
4
4.
THE
INFORMATION
COLLECTED
­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
.........................
7
4(
a)
Agency
Activities
.....................................................
7
4(
b)
Collection
Methodology
and
Management
...................................
7
4(
c)
Small
Entity
Flexibility
.................................................
7
4(
d)
Collection
Schedule
....................................................
8
5.
NON­
DUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
.....
8
5(
a)
Non­
duplication
......................................................
8
5(
b)
Effects
of
Less
Frequent
Collection
........................................
8
5(
c)
General
Guidelines
....................................................
9
5(
d)
Confidentiality
.......................................................
9
5(
e)
Sensitive
Questions
....................................................
9
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
COLLECTION
.......................
9
6(
a)
Number
of
Respondents
................................................
9
6(
b)
Estimating
Respondent
Burden
...........................................
9
6(
c)
Estimating
Respondent
Costs
...........................................
14
6(
d)
Estimating
Agency
Burden
and
Cost
......................................
14
6(
e)
Bottom
Line
Burden
Hours
and
Costs
.....................................
15
6(
f)
Reasons
for
Change
in
Burden
..........................................
17
6(
g)
Burden
Statement
....................................................
19
Page
ii
LIST
OF
TABLES
Table1
EstimatedNumber
ofMCEShipments
...................................
10
Table
2
Reporting
and
Recordkeeping
Requirements
for
Universal
Waste
MCE
Regulated
Entities:
One
time
costs
and
Annual
Estimated
Respondent
Burden
and
Cost
..............
11
Table
3
Reporting
and
Recordkeeping
Requirements
for
Universal
Waste
MCE
Handlers,
TSDFs,
and
Transporters:
Annual
Respondent
Burden
and
Cost
Summary
(All
Respondents)
.
16
Table
4
Reporting
and
Recordkeeping
Requirements
for
Universal
Waste
MCE
Regulated
Entities:
AnnualEstimatedAgencyBurdenandCost................................
16
Table
5
Average
and
Total
Annual
Avoided
Respondent
Burden
(Hours)
................
18
Table
6
Average
Annual
Burden
per
Respondent
(Hours)
.........................
19
Page
1
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
Background
1(
a)
Title
and
Number
of
Information
Collection
This
Information
Collection
Request
(ICR)
is
entitled
"Reporting
and
Recordkeeping
Requirements
for
the
Proposed
Rule
on
Mercury­
Containing
Equipment
Reuse
and
Recycling",
ICR
Number
1597.05
1(
b)
Characterization
of
the
Information
Collection
Section
3001
of
the
Resource
Conservation
and
Recovery
Act
(RCRA)
of
1976,
as
amended,
requires
the
Environmental
Protection
Agency
(EPA)
to
identify
which
solid
wastes
are
hazardous
wastes
and
therefore
must
be
managed
as
hazardous
waste
during
treatment,
storage,
or
disposal.
Under
this
authority,
EPA
established
four
hazardous
waste
characteristics
(toxicity,
reactivity,
ignitability,
and
corrosivity),
and
listed
specific
wastes
that
must
be
managed
as
hazardous
wastes.
Waste
mercury­
containing
equipment
(MCE)
are
often
hazardous
because
they
exhibit
the
characteristic
of
toxicity
by
exceeding
the
regulatory
level
for
mercury.
As
a
result,
currently
most
waste
MCE
are
subject
to
strict
controls
under
RCRA
Subtitle
C
hazardous
waste
regulations.

After
consideration
of
the
issues,
EPA
added
hazardous
waste
MCE
to
the
existing
universal
waste
regulations
at
40
CFR
Part
273.
The
existing
universal
waste
regulations,
published
on
May
11,
1995,
provide
streamlined
procedures
for
certain
widely
generated
wastes
identified
as
universal
wastes
(60
FR
25492).
The
universal
waste
standards
are
designed
to
accomplish
the
following
general
goals:

°
Encourage
resource
conservation
while
ensuring
protection
of
human
health
and
the
environment;

°
Improve
implementation
of
the
Subtitle
C
hazardous
waste
program
through
a
simplified
set
of
requirements
that
are
easily
understood
by
handlers
of
MCE
waste;
and
°
Separate
universal
waste
from
the
municipal
waste
stream
by
encouraging
individuals
and
organizations
to
collect
these
wastes
and
to
manage
them
in
an
appropriate
hazardous
waste
management
system.

The
final
universal
waste
MCE
rule
requires
generators
of
this
equipment
to
follow
procedures
for
maintaining
the
condition
of
the
MCE
(e.
g.,
proper
packaging),
storing
MCE
(e.
g.,
accumulation
time
limits,
labeling),
notifying
EPA
as
specified,
and
responding
to
releases.
The
universal
waste
standards
establish
management
standards
for
two
types
of
MCE
generators:
small
quantity
handlers
(SQHUWs)
and
large
quantity
handlers
(LQHUWs)
of
MCE
wastes.
SQHUWs
are
universal
waste
handlers
who
do
not
accumulate
more
than
5,000
kilograms
total
of
universal
waste
at
any
one
time.
LQHUWs
are
universal
waste
handlers
that
accumulate
5,000
Page
2
kilograms
or
more
total
of
universal
waste
at
any
time.
Destination
sites
receiving
waste
MCE
are
subject
to
the
RCRA
hazardous
waste
regulations
at
40
CFR
Parts
264­
270
and
124,
as
applicable.

This
ICR
is
a
comprehensive
description
of
the
information
collection
requirements
for
handlers
of
hazardous
waste
MCE
under
the
universal
waste
requirements.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need
and
Authority
for
the
Collection
The
requirements
covered
in
this
ICR
are
necessary
for
EPA
to
obtain
general
information
on
universal
waste
MCE
regulated
entities
and
to
facilitate
enforcement
of
Part
273
regulations.
The
notification
requirements
are
needed
to
assist
the
Agency
in
identifying
and
tracking
large
quantity
handlers
of
universal
waste
MCE.
EPA
requires
large
quantity
handlers
to
mark
and
track
MCE
shipments
to
help
ensure
that
universal
waste
MCE
are
being
accumulated
responsibly.
EPA
requires
tracking
of
universal
waste
MCE
shipments
to
help
ensure
that
universal
waste
MCE
is
being
properly
treated,
recycled,
or
disposed.

2(
b)
Use
and
Users
of
the
Data
EPA
will
use
the
collected
information
to
ensure
that
universal
waste
MCE
are
being
managed
in
a
protective
manner.
This
information
aids
the
Agency
in
tracking
universal
waste
MCE
shipments
and
identifying
improper
management
practices.
In
addition,
information
kept
in
facility
records
will
help
handlers
demonstrate,
and
on­
site
inspectors
ensure,
that
facilities
are
managing
MCE
properly.
Information
marked
on
MCE
or
MCE
containers
will
assist
handlers,
and
transporters
in
ensuring
proper
management
during
storage
and
shipment.

3.
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
3(
a)
Respondents
and
SIC
Codes
The
following
is
a
list
of
Standard
Industrial
Classification
(SIC)
codes
associated
with
entities
handling
MCE
likely
to
be
affected
by
the
information
collection
requirements
covered
under
this
ICR:

SIC
Code
*
Industry
*

AGRICULTURE
7
Agricultural
services
CONSTRUCTION
15
General
contractors
17
Special
trade
contractors
SIC
Code
*
Industry
*

Page
3
MANUFACTURING
20
Food
&
kindred
products
34
Fabricated
metal
products
35
Industrial
machinery
&
equipment
36
Electronic
&
other
electronic
equipment
37
Transportation
equipment
38
Instrument
&
related
products
PUBLIC
UTILITIES
49
Electronic,
gas,
&
sanitary
services
WHOLESALE
TRADE
50
Wholesale
trade­
durable
goods
RETAIL
TRADE
58
Eating
&
drinking
places
SERVICES
72
Personal
services
73
Business
services
75
Auto
repair,
services,
&
parking
76
Misc.
repair
services
80
Health
services
82
Educational
services
*
Source:
U.
S.
Bureau
of
the
Census
(1997).

3(
b)
Information
Requested
This
section
describes
information
collection
requirements
applicable
to
universal
waste
MCE
regulated
entities
that
would
be
affected
by
the
proposed
rule.

Notification
(i)
Data
items:

The
proposed
rule
requires
large
quantity
handlers
to
send
written
notification
of
universal
waste
MCE
management
to
the
Regional
Administrator,
and
receive
an
EPA
identification
number.
Specifically,
large
quantity
handlers
must
send
written
notification
before
meeting
or
exceeding
the
5,000
kilogram
accumulation
limit
of
universal
waste.
Large
quantity
handlers
who
have
already
notified
EPA
of
their
hazardous
waste
management
activities
under
RCRA
or
Page
4
pesticide
management
under
FIFRA
and
have
received
an
EPA
Identification
number
are
not
required
to
renotify.

The
notification
must
include
the
following
data
items:

°
The
universal
waste
handler's
name
and
mailing
address;

°
The
name
and
business
telephone
number
of
the
person
at
the
universal
waste
handler's
site
who
should
be
contacted
regarding
universal
waste
management
activities;

°
The
address
or
physical
location
of
the
universal
waste
management
activities;

°
A
list
of
all
types
of
universal
waste
managed
by
the
handler;
and

A
statement
indicating
that
the
handler
is
accumulating
5,000
kilograms
or
more
of
universal
waste
at
one
time
and
a
description
of
the
types
of
waste
accumulated.

(ii)
Respondent
activities:


Large
quantity
handlers
must
prepare
and
submit
written
notification
of
universal
waste
MCE
management
to
the
Regional
Administrator.
Marking
(i)
Data
items:

Small
and
large
quantity
handlers
are
required
to
mark
or
label
their
universal
waste
MCE
materials
in
accordance
with
the
following
procedures:


Mercury­
containing
equipment
or
containers
must
be
marked
or
labeled
with
the
words:
"Universal
Waste­
Mercury­
Containing
Equipment"
or
"Waste­
MercuryContaining
Equipment"
or
"Used
Mercury­
Containing
Equipment".

(ii)
Respondent
Activities:


Handlers
must
mark
or
label
the
universal
waste
MCE
or
the
containers
holding
universal
waste
MCE.
Page
5
Accumulation
Time
Limits
(i)
Data
items:

Small
quantity
handlers
and
large
quantity
handlers
are
required
to
demonstrate
the
length
of
time
that
the
MCE
has
been
accumulated
from
the
date
it
was
received
or
became
a
waste.
The
demonstration
may
be
made
by
using
any
of
the
following
methods:


Placing
the
universal
waste
MCE
in
a
container
and
marking
or
labeling
the
container
with
the
earliest
date
that
any
MCE
in
the
container
became
a
waste
or
was
received.


Marking
or
labeling
each
individual
item
of
universal
waste
MCE
with
the
date
it
became
a
waste
or
was
received.


Maintaining
an
inventory
system
on
site
that
identifies
the
date
the
MCE
being
accumulated
became
wastes
or
were
received.


Maintaining
an
inventory
system
on
site
that
identifies
the
earliest
date
any
MCE
in
a
group
of
MCE
items
or
a
group
of
containers
of
MCE
became
a
waste
or
was
received.


Placing
the
MCE
in
a
specific
accumulation
area
and
identifying
the
earliest
date
that
any
MCE
in
the
area
became
a
waste
or
was
received.


Any
other
method
which
clearly
demonstrates
the
length
of
time
that
the
MCE
has
been
accumulated
from
the
date
it
became
a
waste
or
was
received.

(ii)
Respondent
Activities:


Handlers
must
demonstrate
the
length
of
time
that
MCE
has
been
accumulated
since
it
became
a
waste
or
was
received.

Tracking
MCE
Shipments
(i)
Data
items:

The
proposed
rule
requires
large
quantity
handlers
to
keep
records
of
each
incoming
or
outgoing
universal
waste
MCE
shipment.
Records
of
shipments
must
be
kept
for
a
period
of
three
years
from
the
day
of
receipt
or
the
day
the
shipment
left
the
facility.

The
data
items
required
are:


Records
of
incoming
and
outgoing
shipments
must
contain
the
following
information:
Page
6

Name
and
address
of
the
originating
or
destination
facility;


Quantity
of
universal
waste
MCE
received
or
sent;
and

Date
the
shipment
was
sent
or
received.

(ii)
Respondent
activities:


Large
quantity
handlers
must:


Maintain
records
of
all
shipments
for
a
period
of
three
years.

Exports
(i)
Data
Items:

Under
the
proposed
rule,
shipments
of
MCE
to
a
foreign
destination
must
comply
with
the
same
requirements
as
shipments
of
hazardous
waste
(i.
e.,
40
CFR
262,
Subparts
E
or
H).
These
reporting
and
recordkeeping
activities
are
not
evaluated
in
this
ICR
because
they
already
are
addressed
in
the
"Requirements
for
Generators,
Transporters,
and
Waste
Management
Facilities
under
the
RCRA
Hazardous
Waste
Manifest
System"
(ICR
No.
801)
and
in
the
"Exports
from
and
Imports
to
the
U.
S.
under
the
Organization
for
Economic
Cooperation
and
Development
(OECD)
Decision"
(ICR
No.
1647).

4.
THE
INFORMATION
COLLECTED
­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
The
following
section
discusses
how
EPA
and
implementing
agencies
would
collect
and
manage
the
information
received
from
respondents.
This
section
also
includes
a
discussion
of
how
EPA
would
take
steps
to
ensure
that
the
information
collections
are
not
overly
burdensome
on
small
entities.

4(
a)
Agency
Activities
Most
of
the
information
that
is
required
of
universal
waste
MCE
handlers
would
be
kept
on
site
and
not
be
submitted
to
EPA
formally.
The
Agency
will
conduct
the
following
activities
in
response
to
information
submittals:


Review
and
file
notification
of
universal
waste
MCE
management
provided
by
large
quantity
handlers;


Send
an
EPA
identification
number
to
large
quantity
handlers;
and
Page
7

Enter
notification
information
into
a
database.

4(
b)
Collection
Methodology
and
Management
In
collecting
and
analyzing
the
information
associated
with
this
ICR,
EPA
will
use
electronic
equipment
such
as
personal
computers
and
applicable
database
software.
EPA
will
ensure
the
accuracy
and
completeness
of
the
collected
information
by
reviewing
each
submittal.
EPA
then
would
enter
the
information
into
a
database
and
aggregate
data
to
monitor
universal
waste
MCE
program.

4(
c)
Small
Entity
Flexibility
By
adding
hazardous
waste
MCE
intended
for
recycling
into
the
federal
list
of
universal
waste,
the
proposed
rule
will
provide
regulatory
relief
from
the
full
Subtitle
C
management
requirement
for
all
entities
involved
in
MCE
management
and
willing
to
recycle
MCE.
These
entities
include
generators,
transporters,
and
MCE
recycling
facilities.
Small
quantity
generators
of
hazardous
waste
MCE
will
become
small
quantity
handlers
of
universal
waste
MCE.
The
regulatory
requirements
associated
with
small
quantity
handlers
of
universal
waste
are
considerably
simpler
than
those
applicable
to
small
quantity
generators
of
hazardous
waste.

Further,
EPA
relieved
small
quantity
handlers
from
several
administrative
requirements
applicable
to
large
quantity
handlers.
For
example,
the
proposed
rule
does
not
require
small
quantity
handlers
to
submit
notifications
of
universal
waste
MCE
management
or
to
obtain
an
EPA
identification
number.
EPA
also
does
not
require
small
quantity
handlers
to
keep
records
of
their
universal
waste
MCE
shipments.
EPA
believes
these
exemptions
would
encourage
small
businesses
to
safely
manage
universal
waste
MCE
in
compliance
with
the
proposed
rule.
In
addition,
EPA
allows
conditionally
exempt
small
quantity
generators
(CESQGs)
to
manage
their
hazardous
waste
MCE
either
under
the
specific
provisions
of
the
proposed
rule
or
under
the
existing
CESQG
exemption
in
40
CFR
261.5.

Finally,
the
universal
waste
MCE
rule
is
a
regulatory
relief
initiative
that
should
reduce
regulatory
burden
and
costs
for
all
universal
waste
handlers,
but
should
particularly
benefit
small
entities.

4(
d)
Collection
Schedule
EPA
does
not
collect
any
information
on
a
regular
schedule,
except
for
annual
notification
schedule
for
exports
of
MCE
to
non­
OECD
countries
and
annual
report
of
exports
of
MCE
to
OECD
countries.

5.
NON­
DUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
5(
a)
Non­
duplication
Page
8
The
streamlined
MCE
requirements
minimize
the
paperwork
activities
respondents
must
undertake
in
relation
to
the
full
hazardous
waste
program,
and
enable
them
to
follow
standard
industry
practices
and
other
Federal
agency
requirements,
where
appropriate,
to
satisfy
the
universal
waste
MCE
requirements.
The
information
required
by
the
proposed
regulations
covered
by
this
ICR
is
not
available
from
any
source
but
the
respondents.

5(
b)
Effects
of
Less
Frequent
Collection
EPA
will
consider
carefully
the
burden
imposed
upon
the
regulated
community
by
the
proposed
regulations,
and
to
the
extent
possible,
will
attempt
to
minimize
the
burden
imposed.
EPA
believes
strongly
that
if
the
minimum
requirements
specified
under
the
proposed
regulations
are
not
met,
neither
the
facilities
nor
EPA
will
be
able
to
ensure
that
waste
MCE
are
being
managed
in
a
manner
protective
of
human
health
and
the
environment.

5(
c)
General
Guidelines
This
ICR
adheres
to
the
guidelines
stated
in
the
1995
Paperwork
Reduction
Act,
OMB's
implementing
regulations,
OMB's
Information
Collection
Review
Handbook,
and
other
applicable
OMB
guidance.

5(
d)
Confidentiality
Section
3007(
b)
of
RCRA
and
40
CFR
Part
2,
Subpart
B,
which
define
EPA's
general
policy
on
public
disclosure
of
information,
contain
provisions
for
confidentiality.
The
information
provided
by
the
entities
regulated
under
the
proposed
regulations
will
be
treated
in
accordance
with
these
provisions,
as
appropriate.

5(
e)
Sensitive
Questions
No
questions
of
a
sensitive
nature
are
included
in
any
of
the
information
collection
requirements.
Page
9
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
COLLECTION
6(
a)
Number
of
Respondents
The
number
of
facilities
that
would
be
covered
by
the
proposed
rule
was
obtained
from
EPA's
"Draft
Economic
Analysis
of
Including
Mercury­
Containing
Devices
(MCD)
in
the
Universal
Waste
System,
Notice
of
Proposed
Rulemaking"
dated
September
5,
2001.
The
report
estimated
that
there
would
be
1,
864
small
quantity
handlers,
13
large
quantity
handlers,
18
TSDFs,
and
600
transporters.
For
the
purpose
of
evaluating
the
annual
costs
associated
with
new
facilities,
the
Agency
also
estimates
that
one
percent
of
the
facilities
are
new
facilities.

6(
b)
Estimating
Respondent
Burden
This
ICR
presents
a
comprehensive
characterization
of
the
reporting
and
recordkeeping
burden
and
costs
to
universal
waste
MCE
handlers,
TSDFs
and
transporters
under
the
proposed
rule.
Except
for
manifest
requirements,
recyclers
of
universal
waste
(destination
facilities/
TSDFs)
must
comply
with
the
same
requirements
that
apply
to
recyclers
of
hazardous
wastes.

Reading
the
Regulations
EPA
expects
that
regulated
universal
waste
MCE
entities
will
read
the
applicable
universal
waste
MCE
regulations
as
a
one­
time
activity
in
order
to
familiarize
themselves
with
the
new
rule.

Notification
All
large
quantity
handlers
would
be
required
to
send
EPA
a
written
notification
of
universal
waste
MCE
management
under
the
proposed
rule.
EPA
expects
that
one
percent
of
the
generators
are
new
facilities.

Marking
EPA
expects
that
all
handlers
will
mark
or
label
universal
waste
MCE
or
containers
holding
universal
waste
MCE.
Handlers
are
expected
to
mark
containers
rather
than
individual
MCE,
thus
minimizing
the
recordkeeping
burden.

Accumulation
Time
Limits
EPA
expects
that
some
MCE
entities
will
keep
records
on
their
storage
time
limits
according
to
procedures
specified
on
the
regulations.
EPA
believes
the
remaining
entities
will
use
standard
business
practices.
Page
10
Tracking
MCE
Shipments
Table
1
provides
background
data
on
the
number
of
universal
waste
MCE
entities
and
shipments.
Table
2
shows
the
one
time
cost
for
rule
familiarization
and
notification
of
hazardous
waste
activity
and
the
average
annual
burden
and
costs
for
handlers,
TSDFs,
and
transporters
to
comply
with
each
MCE
requirement.
The
table
includes
estimated
labor
costs
and
operation
and
maintenance
(O&
M)
costs.
Table
3
summarizes,
by
respondent
type,
the
total
annual
burden
and
costs.
Table
3
also
includes
capital
costs
for
respondents
(i.
e.,
file
cabinets).

Table
1
Estimated
Number
of
MCE
Shipments
Type
of
Regulated
Entity
Number
of
Regulated
Entities
Total
#
of
Shipments
Sent
Off
Site/
Year
#
of
Shipments
Received/
Year
Small
Quantity
Handlers
1,
864
1,
864
0
Large
Quantity
Handlers
13
13
0
TSDFs
18
0
1,877
Transporters
600
0
1,
877
Total
2,495
3,000
1,877
Page
11
TABLE
2
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
UNIVERSAL
WASTE
MCE
REGULATED
ENTITIES:
ONE
TIME
COST
PERFACILITY
O&
M
Costs
per
Respondent
Number
of
Respondents
Hours
per
Respondent
Postage/
Shipping
Photocopies
Contractor
Support
Hours
per
Respondent
Cost
per
Respondent
Total
Cost
All
Respondents
Legal
Manager
Technical
Clerical
@

$3/
doc
@
$0.10/
page
@$

88.05/
hr
@$

116.53/
hr
@$

110.95/
hr
@$

60.89/
hr
@$

43.44/
hr
Rule
Familiarization
Small
Quantity
Handlers
1,864
0.0
1.
0
1.5
0.
0
$0.00
$0.00
$0.00
2.5
$202.28
$377,049.92
Large
Quantity
Handlers
13
0.5
1.
0
1.5
0.
0
$0.00
$0.00
$0.00
3
$260.55
$3,387.15
TSDFs
18
0.
5
1.0
1.
5
0.0
$0.00
$0.00
$0.00
2.5
$260.55
$4,689.90
Transporters
600
0.5
1.
0
1.5
0.
0
$0.00
$0.00
$0.00
3
$260.55
$156,330.00
SUBTOTAL
2,495
1.5
4.
0
6.0
0.
0
$0.00
$0.00
$0.00
11
$983.93
$541,456.97
Prepare
and
submit
written
notification
of
MCE
management
Large
Quantity
Handlers
13
0.0
0.
5
1.0
0.
5
$3.00
$1.00
$0.00
2
$145.09
$1,886.17
TOTAL
ONE
TIME
COST
PER
ENTITY
Small
Quantity
Handlers
1,864
0.0
1.
0
1.5
0.
0
$0.00
$0.00
$0.00
2.5
$202.28
$377,049.92
Large
Quantity
Handlers
13
0.5
1.
5
2.5
0.
0
$3.00
$1.00
$0.00
4.5
$402.64
$5,234.32
TSDFS
18
0.
5
1.0
1.
5
0.0
$0.00
$0.00
$0.00
2.5
$260.55
$4,689.90
Transporters
600
0.5
1.
0
1.5
0.
0
$0.00
$0.00
$0.00
3
$260.55
$156,330.00
TOTALS
2,495
1.5
4.
5
7.0
0.
0
$3.00
$1.00
$0.00
12.5
$1,126.02
$543,304.14
Page
12
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
UNIVERSAL
WASTE
MCE
REGULATED
ENTITIES:
ANNUAL
ESTIMATED
RESPONDENT
BURDEN
AND
COST
O&
M
Costs
per
Respondent
Number
of
Respondents
Hours
per
Respondent
Postage/
Shipping
Photocopies
Contractor
Support
Hours
per
Year
per
Respondent
Cost
per
Year
per
Respondent
Total
Cost
per
Year
All
Respondents
Legal
Manager
Technical
Clerical
@

$3/
doc
@
$0.10/
page
@$

88.05/
hr
@$

116.53/
hr
@$

110.95/
hr
@$

60.89/
hr
@$

43.44/
hr
LABELING
AND
MARKING
Mark
the
MCE
or
MCE
containers
Small
Quantity
Handlers
1,864
0.0
0.
0
1.0
0.
5
$0.00
$0.00
$0.00
1.5
$82.61
$153,985.04
Large
Quantity
Handlers
13
0.0
0.
0
1.0
1.
0
$0.00
$0.00
$0.00
2
$104.33
$1,356.29
TSDFs
18
0.
0
0.0
2.
0
0.0
$0.00
$0.00
$0.00
2
$121.78
$2,192.04
SUBTOTAL
1,895
0.0
0.
0
4.0
1.
5
$0.00
$0.00
$0.00
5.5
$308.72
$157,533.37
STORAGE
TIME
LIMITS
Mark
MCE
or
MCE
containers
with
the
date
the
waste
was
received
or
became
a
waste
Small
Quantity
Handlers
1,864
0.0
0.
0
0.5
0.
5
$0.00
$0.00
$0.00
1
$52.17
$97,244.88
Large
Quantity
Handlers
13
0.0
0.
0
1.0
0.
5
$0.00
$0.00
$0.00
1.5
$82.61
$1,073.93
Subtotal
1,877
0.0
0.
0
1.5
1.
0
$0.0
$0.00
$0.00
2.5
$134.78
$98,318.81
TRACKING
MCE
SHIPMENTS
Keep
a
record
of
each
shipment
of
MCE
Large
Quantity
Handlers
13
0.0
0.
0
0.5
0.
0
$0.00
$1.80
$0.00
0.5
$32.25
$419.25
TSDFs
18
0.
0
0.0
15.0
10.0
$0.00
$5.00
$0.00
25
$1,352.75
$24,349.50
SUBTOTAL
31
0.0
0.
0
15.5
10.0
$0.00
$6.80
$0.00
25.5
$1,385.00
$24,768.75
Page
13
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
UNIVERSAL
WASTE
MCE
REGULATED
ENTITIES:
ANNUAL
ESTIMATED
RESPONDENT
BURDEN
AND
COST
O&
M
Costs
per
Respondent
Number
of
Respondents
Hours
per
Respondent
Postage/
Shipping
Photocopies
Contractor
Support
Hours
per
Year
per
Respondent
Cost
per
Year
per
Respondent
Total
Cost
per
Year
All
Respondents
Legal
Manager
Technical
Clerical
@

$3/
doc
@
$0.10/
page
@$

88.05/
hr
@$

116.53/
hr
@$

110.95/
hr
@$

60.89/
hr
@$

43.44/
hr
Small
Quantity
Handler
Total
1,864
0.0
0.
0
1.5
1.
0
$0.00
$0.00
$0.00
2.5
$134.78
$251,229.92
Large
Quantity
Handler
Total
13
0.0
0.
0
2.5
1.
5
$0.00
$1.80
$0.00
4
$219.19
$2,849.47
TSDF
Total
18
0.0
0.
0
17.0
10.0
$0.00
$5.00
$0.00
27
$1,479.53
$26,631.54
TOTAL
1,

895
0.0
0.
0
21.0
12.5
$0.00
$6.80
$0.00
33.5
$1,833.50
$280,710.93
Page
14
6(
c)
Estimating
Respondent
Costs
Labor
The
average
annual
salaries
of
the
professionals
listed
in
Table
2
are
based
on
data
found
in
the
U.
S.
Department
of
Labor
Statistics
(BLS)
"National
Compensation
Survey:
Occupational
Wages
in
the
United
States,
1997."
Wages
were
calculated
using
the
BLS
rate
with
the
labor
multiplier.
The
labor
rates
are
based
on
a
full­
time
employee
with
a
40­
hour
work
week.
Total
one­
time
costs
are
estimated
to
be
$543,304
from
Table
2
and
the
annual
respondent
labor
costs
summarized
in
t
Table
3
are
estimated
to
be
$280,615.

Operation
and
Maintenance
O&
M
costs
are
those
costs
associated
with
a
paperwork
requirement
incurred
continually
over
the
life
of
the
ICR.
They
are
defined
by
the
1995
Paperwork
Reduction
Act
as
"the
recurring
dollar
amount
of
cost
associated
with
O&
M
or
purchasing
services."
For
this
ICR,
O&
M
costs
cover
postage
and
for
reports
sent
to
other
parties
($
3
per
package)
and
photocopying
($
0.10
per
page).
In
addition,
O&
M
costs
include
contractor
costs
(i.
e.,
costs
charged
by
firms
acting
as
agents
for
their
customers).
Total
annual
respondent
O&
M
costs,
summarized
in
the
5
th
column
of
Table
3,
are
estimated
to
be
$113.

Capital
In
the
following
paragraphs,
EPA
estimates
capital
costs
associated
with
the
information
requirements
covered
by
this
ICR.
Capital
costs
usually
include
any
produced
physical
good
needed
to
provide
or
keep
records
of
the
needed
information,
such
as
machinery,
computers,
and
other
equipment.
For
this
ICR,
the
only
required
capital
is
file
cabinets
for
maintaining
reports.
The
file
cabinet
costs
are
based
on
the
assumption
that
large
quantity
handlers
would
need
to
buy
approximately
one
cabinet
every
five
years
and
TSDFs
and
transporters
would
not
need
any
additional
file
storage
capacity.
EPA
estimates
that
the
purchasing
price
for
one
file
cabinet
is
$550,
including
delivery.
Total
annual
respondent
capital
costs,
summarized
in
the
4
th
column
of
Table
3,
are
estimated
to
be
$1,430.

6(
d)
Estimating
Agency
Burden
and
Cost
Table
4
estimates
EPA's
annual
burden
hours
and
costs
associated
with
the
requirements
covered
in
this
ICR.
Since
Regional
Offices
generally
would
process
all
the
information
collected
under
the
requirements
covered
in
this
ICR,
Regional
labor
costs
are
used
in
the
calculation
of
Federal
Agency
costs.
EPA
estimates
an
average
Regional
labor
cost
of
$60
per
hour
for
legal
staff,
$43
per
hour
for
managerial
staff,
$30
per
hour
for
technical
staff,
and
$18
per
hour
for
clerical
staff.
To
derive
these
estimates,
EPA
used
the
U.
S.
Office
of
Personnel
Management
2000
Federal
Pay
Schedule
salary
figures
to
estimate
the
annual
compensation
of
these
staff.
EPA
estimates
an
annual
Agency
burden
of
29.2hours,
at
an
annual
cost
of
$832.
For
the
purposes
of
this
ICR,
EPA
assigned
Regional
staff
the
following
government
service
levels:
Page
15

Legal
staff
GS­
15,
Step
1
($
77,614
per
year,
or
$60
per
hour)


Managerial
staff
GS­
13,
Step
1
($
55,837
per
year,
or
$43
per
hour)


Technical
staff
GS­
11,
Step
1
($
39,178
per
year,
or
$30
per
hour)


Clerical
staff
GS­
06,
Step
1
($
23,820
per
year,
or
$18
per
hour)

To
derive
hourly
estimates,
EPA
divided
annual
compensation
estimates
by
2,
080,
the
number
of
hours
in
a
Federal
work
year.
EPA
then
multiplied
the
rates
by
the
standard
government
overhead
factor
of
1.6.

6(
e)
Bottom
Line
Burden
Hours
and
Costs
The
bottom
line
burden
to
respondents
over
the
three­
year
period
covered
by
this
ICR
is
estimated
at
15,694
hours
with
a
cost
of
approximately
$924,012.
The
bottom­
line
burden
for
the
Agency
is
87.6
hours,
with
a
cost
of
$2,496.
EPA
expects,
however,
that
the
regulatory
relief
resulting
from
the
proposed
regulations
will
lead
to
a
net
decrease
in
the
overall
respondent
burden
(see
Section
6(
f)
below).
Page
16
TABLE
3
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
UNIVERSAL
WASTE
MCE
HANDLERS,
TSDFs
and
TRANSPORTERS:
ANNUAL
RESPONDENT
BURDEN
AND
COST
SUMMARY
(ALL
RESPONDENTS)
Respondent
Type
Total
Hours
Labor
Costs
Capital
Costs
O&
M
Costs
Total
Costs
Small
quantity
handlers
4,660
$251,230
$0
$0
$251,230
Large
quantity
handlers
52
$2,
826
$1,
430
$23
$4,
279
TSDFs
486
$26,560
$0
$90
$26,650
TOTAL
5,198
$280,615
$1,430
$113
$282,158
TABLE
4
REPORTING
AND
RECORDKEEPING
REQUIREMENTSFORUNIVERSALWASTEMCE
REGULATED
ENTITIES:
ANNUAL
ESTIMATED
AGENCY
BURDEN
AND
COST
O&
M
Review
Costs
per
Respondent
Review
Hours
Review
Cost
Total
Review
Cost
Number
of
Review
Hours
per
Respondent
Postage/

Photocopies
per
Year
per
Year
per
Year
Respondents
Legal
Managerial
Technical
Clerical
Shipping
@

All
per
Alll
@$
60/
hr
@$
43/
hr
@$
30/
hr
@$
18/
hr
@$
3/

doc
$0.10/
page
Respondents
Respondent
Respondents
NOTIFICATION
Review
notification
for
completeness
and
accuracy
Large
Quantity
Handlers
13.0
0.
0
0.5
0.
5
0.0
$0.00
$0.00
13.0
$36.5
$474.5
Issue
EPA
ID
number
to
regulated
entities
Large
Quantity
Handlers
13.0
0.
0
0.0
0.
3
0.0
$3.00
$1.00
5.4
$11.5
$201.5
Enter
information
into
database
Large
Quantity
Handlers
13.0
0.
0
0.0
0.
3
0.3
$0.00
$0.00
10.8
$12.0
$156.0
TOTAL
0.
0
0.5
1.
1
0.3
$3.00
$1.00
29.2
$60.0
$832.0
Page
17
6(
f)

Reasons
for
Change
in
Burden
EPA
expects
that
the
proposed
rule
will
result
in
a
reduction
in
burden
to
the
regulated
waste
MCE
community.
Universal
waste
MCE
entities
no
longer
would
be
subject
to
full
Subtitle
C
requirements.
Following
is
a
list
of
primary
RCRA
reporting
and
recordkeeping
requirements
that
MCE
entities
may
be
relieved
of:

Reporting
waste
generation
data
for
the
EPA's
Biennial
Report,

as
covered
in
ICR
No.

976,

Biennial
Report
ICR;

Reporting
and
recordkeeping
under
the
land
disposal
restrictions
(LDRs)
program
of
40
CFR
Part
268,

as
covered
in
ICR
No.

1442,
Land
Disposal
Restrictions
ICR;

Reporting
and
recordkeeping
under
the
hazardous
waste
manifest
requirements,

as
covered
in
ICR
No.

801,

Manifest
ICR;
and

Recordkeeping
and/
or
reporting
of
personnel
training,

contingency
plan,
and
emergency
procedures
under
the
generator
standards
of
40
CFR
Part
262,

as
covered
in
ICR
No.

820,

Hazardous
Waste
Generator
Standards
ICR.
Table
5
presents
the
average
and
the
total
avoided
respondent
burden
resulting
from
the
proposed
rule.

This
avoided
burden
is
based
on
the
average
annual
burden
per
respondent
as
estimated
in
the
ICRs
listed
above.
Table
5
also
presents
the
total
estimated
avoided
entity
burden
by
multiplying
the
average
avoided
burden
per
respondent
by
the
total
number
of
MCE
entities
expected
to
be
affected
by
the
proposed
rule.
Page
18
Table
5
Average
and
Total
Annual
Avoided
Respondent
Burden
(Hours)
Primary
RCRA
Requirements
No
Longer
Applicable
to
MCE
Regulated
Entities
Average
Annual
Respondent
Burden
Savings
per
Regulated
Entity
(in
hours)
Small
Quantity
Handler
Large
Quantity
Handler
TSDF
Transporter
Prepare
and
submit
Hazardous
Waste
Biennial
Report
Forms
N/
A
12
(RP)

0
N/
A
Prepare
and
transmit
LDR
notifications
to
treatment
and
disposal
facilities
and
keep
records
2
(RP)

2(

RP)

N/
A
N/
A
1
(RK)

1
(RK)

N/
A
Prepare
and
transmit
manifests
and
keep
records
1
(RP)

2(

RP)

8
(RP)

12
(RP)
0.5
(RK)

1(

RK)

2
(RK)

3(

RK)
Personnel
training
0.
5
(RK)

4
(RK)

0
1(

RK)
Contingency
plan
N/
A
3
(RK)

0
N/
A
Emergency
procedures
0
0
0
0
Total
Avoided
Burden
per
Regulated
Entity
3
(RP)

16
(RP)

8(
RP)

12(
RP)
1.5
(RK)

9(
RK)

2
(RK)

4(
RK)
Number
of
Regulated
Entities
Affected
by
the
Proposed
Rule
1,864
13
18
600
Total
Avoided
Burden
5,592
(RP)

208
(RP)

144
(RP)

7,200
(RP)
2,796
(RK)

117
(RK)

36
(RK)

2,400
(RK)
RP:

Reporting;

RK:

Recordkeeping
Page
19
6(
g)

Burden
Statement
Table
6
presents
the
estimated
average
burden
hours
per
respondent
per
year
for
the
reporting
and
recordkeeping
requirements
covered
by
this
ICR.

The
reporting
burden
includes
time
to
comply
with
the
proposed
notification,
environmental
justice,
and
exporting
requirements.

The
recordkeeping
burden
includes
time
to
read
and
understand
the
regulations,
and
to
follow
the
proposed
labeling/
marking,
storage
time
limits,
and
shipment
tracking
requirements.
Table
6
Estimated
Annual
Burden
per
MCE
Respondent
(Hours)
Type
of
regulate
Entity
Estimated
Annual
Reporting
Burden
Estimated
Annual
Recordkeeping
Burden
Estimated
Number
of
Each
Entity
Estimated
Total
Burden
Small
Quantity
3
1.
5
1,

864
8,

388
Large
Quantity
9
16
13
325
TSDFs
8
2
18
180
Transporters
12
4
600
9600
As
shown
in
Table
6,

the
total
annual
burden
is
estimated
to
be
4.
5
hours
for
small
quantity
handlers,

25
hours
for
large
quantity
handlers,

10
hours
for
TSDFs,
and
16
hours
for
transporters.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,

a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.

The
OMB
numbers
for
EPA's
regulation
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.
Send
comments
regarding
these
burden
statements
or
any
other
aspect
of
this
collection,
including
suggestions
for
reducing
the
burden,

including
through
the
use
of
automated
collection
techniques,

to
the
Director,
Office
of
Policy,

U.
S.

Environmental
Protection
Agency
(2822),
1200
Pennsylvania
Ave.,

N.

W.,

Washington,

D.
C.

20460
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,

Attention:

Desk
Officer
for
EPA,
725
17th
Street,

N.

W.,

Washington,

D.
C.

20503.
Include
the
OMB
control
number
in
any
correspondence.
