1
SUPPORTING
STATEMENT
FOR
EPA
INFORMATION
COLLECTION
REQUEST
976.10
"
THE
2001
HAZARDOUS
WASTE
REPORT"

(
September
19,
2000)
REVISED
11/
22/
00
Page
i
TABLE
OF
CONTENTS
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
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1
1(
a)
Title
and
Number
of
the
Information
Collection
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1
1(
b)
Characterization
of
the
Information
Collection
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1
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
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1
2(
a)
Need
and
Authority
for
the
Collection
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1
2(
b)
Use
and
Users
of
the
Data
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3
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
6
3(
a)
Nonduplication
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6
3(
b)
Public
Notice
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6
3(
c)
Consultations
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6
3(
d)
Effects
of
Less
Frequent
Collection
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6
3(
e)
General
Guidelines
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6
3(
f)
Confidentiality
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6
3(
g)
Sensitive
Questions
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4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
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7
4(
a)
Respondents
and
Standard
Industrial
Classification
(
SIC)
Codes
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7
4(
b)
Information
Requested
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8
5.
THE
INFORMATION
COLLECTED
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AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
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9
5(
a)
Agency
Activities
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9
5(
b)
Collection
Methodology
and
Management
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11
5(
c)
Small
Entity
Flexibility
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12
5(
d)
Collection
Schedule
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12
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
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13
6(
a)
Estimating
Respondent
Burden
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13
6(
b)
Estimating
Respondent
Costs
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16
6(
c)
Estimating
Agency
Burden
and
Cost
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19
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Cost
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19
6(
e)
Bottom
Line
Burden
and
Cost
Tables
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21
6(
f)
Reasons
For
Change
In
Burden
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22
6(
g)
Burden
Statement
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22
APPENDIX
A:
2001
Hazardous
Waste
Report
Forms
and
Instructions
APPENDIX
B:
Federal
Register
Notice
on
2001
Hazardous
Waste
Report
Renewal
Page
1
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
and
Number
of
the
Information
Collection
This
information
collection
request
(
ICR)
is
entitled
"
The
2001
Hazardous
Waste
Report,"
EPA
ICR
Number
976.10.

1(
b)
Characterization
of
the
Information
Collection
This
ICR
is
a
renewal
of
an
on­
going
information
collection
request
to
support
the
reporting
by
hazardous
waste
generators
and
treatment,
storage,
or
disposal
facilities
(
TSDFs)
required
by
the
Resource
Conservation
and
Recovery
Act
of
1976
(
RCRA).
RCRA
Sections
3002
and
3004,
as
amended
by
the
Hazardous
and
Solid
Waste
Amendments
of
1984
(
HSWA),
requires
reporting
to
EPA
or
to
authorized
States
at
least
every
two
years.
The
2001
Hazardous
Waste
Report
(
also
called
the
Biennial
Report),
or
comparable
State
report,
is
the
report
used
by
generators
and
TSDFs
to
satisfy
this
requirement.

Hazardous
waste
generators
and
TSDFs
must
report
information
on
the
quantities,
type,
and
management
method
of
generated
hazardous
wastes
and
hazardous
wastes
received
from
off
site.
The
data
collected
are
used
by
EPA's
Office
of
Solid
Waste
(
OSW)
to
prepare
a
national
report
that
is
made
available
to
Congress
and
the
public,
summarizing
hazardous
waste
generation
and
management
activities.
The
data
also
are
used
by
EPA
and
the
States
for
programmatic
and
regulatory
needs.

Data
are
collected
from
respondents
on
Form
8700­
13
A/
B,
or
comparable
State
forms,
either
on
paper
or
in
electronic
media
and
entered
into
an
electronic
database
by
State
and
Regional
environmental
authorities.
States
coordinate
with
EPA
Regions
and
OSW
Headquarters
to
supply
EPA
with
the
data
reported
by
regulated
entities
for
inclusion
in
a
national
database.
These
Biennial
Report
data
are
maintained
within
the
national
RCRAInfo
database
residing
on
centrally
managed
EPA
servers
at
the
Agency's
National
Computing
Center.
Once
an
initial
version
of
the
national
database
is
compiled,
EPA
coordinates
a
national
data
quality
review
process
with
States
and
EPA
Regions
to
identify
cases
where
the
State
or
Region
may
wish
to
confirm
that
data
were
correctly
entered,
and/
or
contact
a
regulated
entity
to
confirm
what
they
reported,
and
provide
them
with
the
opportunity
to
submit
an
updated
report
if
the
original
contained
errors.
Following
submittal
of
final
data
from
States
and
EPA
Regions,
no
further
changes
are
made
to
the
database
and
it
reflects
the
final
versions
of
reports
as
submitted
by
regulated
entities
for
a
given
report
cycle.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need
and
Authority
for
the
Collection
This
subsection
establishes
the
need
and
legal
authority
for
each
information
collection
covered
in
this
ICR.
Page
2
Table
1
Summary
of
RCRA
Sections
3002
and
3004
Authorizing
the
Hazardous
Waste
Report
Section
3002(
a)(
6)
requires
submission
of
reports
to
EPA
or
the
States
at
least
every
two
years
on
the:

°
Quantities
and
nature
of
hazardous
wastes
that
have
been
generated
during
the
year;

°
Disposition
of
these
hazardous
wastes;
and
°
Changes
in
volume
and
toxicity
of
waste
achieved
during
the
year
in
comparison
with
previous
years.

Section
3004(
a)
requires
EPA
to
issue
regulations
establishing
performance
standards
applicable
to
owners
and
operators
of
facilities
for
the
treatment,
storage,
or
disposal
of
hazardous
waste
that
include:

C
Maintaining
records
of
all
hazardous
wastes
treated,
stored
or
disposed
of
and
the
manner
in
which
such
wastes
were
treated,
stored,
or
disposed
of.
Need
for
the
Information
Collection
RCRA
requires
EPA
to
establish
standards
applicable
to
generators
and
TSDFs
to
protect
human
health
and
the
environment.
Specifically
included
are
provisions
requiring
the
submission
of
reports,
at
least,
once
every
two
years.

There
are
a
number
of
Federal
and
State
uses
of
Hazardous
Waste
Report
information.
EPA
uses
Hazardous
Waste
Report
information
for
planning
and
developing
regulations.
Regulation
development
and
compliance
tracking
depend
on
descriptions
and
quantities
of
generated
hazardous
waste
and
management
methods
used
by
TSDFs.
Also,
Hazardous
Waste
Report
information
allows
the
Agency
to
ascertain
whether
its
regulations
are
having
the
desired
effect
on
the
generation
and
management
of
hazardous
waste.
For
example,
Hazardous
Waste
Reports
provide
information
on
whether
wastes
have
shifted
from
one
method
of
disposal
to
another.
Some
State
uses
of
Hazardous
Waste
Report
data
include
support
of
planning,
fee
assessment,
compliance
monitoring,
and
enforcement.

Legal
Authority
for
the
Information
Collection
RCRA
Sections
3002
and
3004
authorize
the
Hazardous
Waste
Report.
Both
sections
require
EPA
to
establish
and
promulgate
standards
regarding
record
keeping
and
reporting
for
Subtitle
C
hazardous
wastes.
Section
3002
applies
to
hazardous
waste
generators
and
Section
3004
applies
to
hazardous
waste
treatment,
storage,
and
disposal
facilities.
The
pertinent
text
of
RCRA
Sections
3002
and
3004
is
summarized
in
Table
1.
Page
3
2(
b)
Use
and
Users
of
the
Data
Implementation
of
the
RCRA
program
requires
the
collection
of
information
on
the
characteristics
of
the
regulated
community
generally
(
e.
g.,
number
of
generators
and
TSDFs),
as
well
as
the
specific
characteristics
of
individual
sites
(
e.
g.,
waste
handling
activities
undertaken).
This
information
is
used
for
waste
activity
monitoring,
compliance
monitoring,
technical
assistance,
program
planning,
waste
minimization,
and
other
program
activities
taken
by
EPA
and
the
States.
The
information
is
also
used
by
public
interest
groups
(
Right­
to­
Know
Network)
and
industry.

In
addition
to
the
above­
mentioned
uses,
the
Hazardous
Waste
Report
also
provides
valuable
information
to
States
for
tracking
intra­
and
interstate
shipments
of
waste.
Many
States
do
not
collect
or
track
manifests,
which
provide
some
information
on
off­
site
shipments
of
hazardous
waste;
therefore,
the
Hazardous
Waste
Report
serves
as
the
only
source
of
this
information.

EPA
has
made
significant
modifications
to
the
Hazardous
Waste
Report
for
the
2001
collection
based
on
a
lengthy
study
of
the
information
needs
of
EPA
and
State
hazardous
waste
programs.
These
modifications
are
described
fully
in
the
June
21,
2000
background
document,
2001
Hazardous
Waste
Report
(
Biennial
Report),
Part
A
Permit
Application,
and
Notification
of
Regulated
Waste
Activity
Information
Collection
Request.
They
include:

C
Clarifying
the
types
of
hazardous
wastes
to
be
reported;

C
Streamlining
the
Hazardous
Waste
Report's
source,
origin,
form,
and
system
type
codes;

C
Removing
point
of
measurement,
Standard
Industrial
Classification
(
SIC)
code,
and
off­
site
availability
data
elements
from
the
Hazardous
Waste
Report;
and
C
Replacing
the
Identification
and
Certification
(
IC)
Form
with
a
new
form:
the
Site
Identification
Form.

These
modifications
to
the
2001
Hazardous
Waste
Report
are
described
further
in
the
following
paragraphs.

Clarifying
the
Types
of
Hazardous
Wastes
to
be
Reported.
The
Biennial
Reporting
instructions
have
been
changed
to
clarify
that
generators
should
report
only
the
hazardous
wastes
which
count
toward
the
determination
of
their
generator
status
(
except
as
otherwise
required
by
the
State
agency).
This
includes
wastes
that
are
generated,
accumulated
and
subsequently
managed
on
site,
or
shipped
off
site.
TSDFs
should
report
hazardous
waste
received
from
off
site,
the
management
of
the
hazardous
waste
while
on
site,
and
any
shipments
of
hazardous
waste
off
site.
Page
4
Streamlining
the
Hazardous
Waste
Report's
Source,
Origin,
Form,
and
System
Type
Codes.
The
source
codes
in
the
1999
Hazardous
Waste
Report
have
been
consolidated,
regrouped,
and
merged
with
the
origin
codes
to
provide
a
simpler
coding
structure.
EPA
believes
that
this
approach
will
provide
more
meaningful
and
consistent
responses,
reduce
at
least
some
of
the
reporting
burden,
and
support
the
high­
level
information
categorization
needs
of
the
RCRA
program.
This
new
coding
scheme
reduces
the
number
of
choices
from
60
to
30
and
the
groups
from
seven
to
six.
We
believe
that
this
approach
will
result
in
increase
data
accuracy
and
quality
through
reduced
variation
in
response.

In
addition,
the
form
codes
have
been
revised
and
streamlined.
The
new
coding
scheme
reduces
the
number
of
form
codes
from
89
to
47
with
seven
high­
level
groups.
This
improvement
will
result
in
increased
data
accuracy
and
quality
through
reduced
variation
in
response
with
a
minor
decrease
in
burden
for
both
handlers
and
program
implementers.

Finally,
EPA
has
replaced
system
type
codes
with
management
method
codes.
The
management
method
coding
scheme
eliminates
overlap
with
form
codes.
This
coding
structure
is
based
in
part
on
analysis
of
the
frequency
and
perceived
accuracy
with
which
different
system
type
codes
were
reported
in
the
1995
Biennial
Reporting
System
(
BRS)
data.
The
impact
of
the
land
disposal
restriction
(
LDR)
treatment
codes
was
also
considered
in
establishing
this
list.
This
new
coding
scheme
reduces
the
detailed
list
from
65
entries
to
28
and
the
high­
level
groups
from
14
to
four.
We
believe
this
approach
will
result
in
increased
data
accuracy
and
quality
through
reduced
variation
in
response
with
a
minor
decrease
in
burden
for
both
handlers
and
program
implementers.

Removing
Point
of
Measurement,
Standard
Industrial
Classification
(
SIC)
Code,
and
Off­
Site
Availability
Data
Elements
from
the
Hazardous
Waste
Report.
The
"
point
of
measurement"
data
element
on
the
1999
Waste
Generation
and
Management
Form
(
Form
GM)
consists
of
four
codes
showing
whether
the
waste
being
reported
was
mixed
with
other
wastes
prior
to
being
measured.
EPA
determined
that
there
is
no
significant
need
for
this
information.
Additionally,
because
the
point
of
measurement
is
confusing
to
respondents,
the
data
are
often
of
questionable
quality.
Thus,
the
point
of
measurement
was
eliminated
from
Form
GM.

In
addition,
we
removed
the
SIC
code
from
Form
GM,
since
we
added
the
North
American
Industrial
Classification
System
(
NAICS)
codes
(
the
replacement
for
the
SIC
codes)
to
the
Site
Identification
Form.
Completion
of
the
NAICS
codes
on
the
Site
Identification
Form
is
mandatory.

The
off­
site
availability
code
showed
whether
an
off­
site
facility
is
a
commerciallyavailable
TSDF,
or
if
it
is
only
permitted
to
accept
wastes
from
firms
owned
by
the
same
company.
EPA
did
not
find
any
need
for
this
information.
Thus,
the
off­
site
availability
code
was
eliminated
from
Form
GM.
Page
5
[
Note:
The
Hazardous
Waste
Report
asks
whether
the
waste
being
reported
is
a
RCRA
radioactive
mixed
waste.
EPA
did
not
find
a
significant
national
need
for
this
information.
However,
we
learned
that
some
existing
EPA
compliance
agreements
with
Federal
facilities
require
this
data
for
compliance
monitoring.
Thus,
we
determined
that
it
would
be
disruptive
to
drop
the
requirement
since
it
is
being
used
in
these
limited
areas.
Information
on
RCRA
radioactive
mixed
waste
will
continue
to
be
collected
for
the
2001
Biennial
Report
cycle.
At
this
time,
however,
we
are
planning
to
remove
it
starting
with
the
2003
Hazardous
Waste
Report,
as
long
as
the
compliance
agreement
information
needs
are
able
to
be
satisfied
by
another
source
of
information.]

Replacing
the
Identification
and
Certification
(
IC)
Form
with
the
Site
Identification
Form.
For
the
2001
Hazardous
Waste
Report,
EPA
has
replaced
the
1999
IC
Form
with
the
Site
Identification
Form.
Currently,
basic
site
information
(
e.
g.,
information
on
hazardous
waste
handling
activities
taking
place
at
RCRA­
regulated
sites)
is
being
collected
on
three
different
forms,
each
with
its
own
instructions
and
definitions.
This
sometimes
gives
regulators
conflicting
information
about
the
same
site
and
is
burdensome
for
respondents.
Specifically,
large
quantity
generators
and
TSDFs
report
site
information
on
the
Hazardous
Waste
Report
IC
Form.
Basic
site
information
is
also
collected
from
all
RCRA­
regulated
facilities
on
the
Notification
Form.
Finally,
TSDFs
seeking
a
permit
or
permit
renewal
submit
site
information
on
the
Part
A
Application
Form.
In
regard
to
the
2001
Hazardous
Waste
Report,
EPA
believes
that
replacing
the
IC
Form
with
the
Site
Identification
Form
will
result
in
increased
data
accuracy
and
quality
through
reduced
variation
in
response.

In
summary,
the
2001
Hazardous
Waste
Report
will
request
the
following
basic
information
for
each
waste
reported:

C
Narrative
waste
description;

C
Hazardous
waste
codes;

C
Physical/
chemical
form
of
the
waste;

C
Source
of
the
waste;

C
Quantity
generated
in
reporting
year;

C
For
waste
treated
on
site,
what
treatment
it
received;
and
C
For
waste
shipped
off
site
for
treatment,
the
kind
of
treatment
it
received,
and
how
much
was
managed.
Page
6
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
EPA
has
determined
that
no
other
Federal
agency
collection
satisfies
the
statutory
requirements
of
Sections
3002
and
3004
of
RCRA,
as
amended.
Except
for
the
site
identification
information
that
will
be
collected
on
one
form
(
combining
the
Biennial
Report,
Notification,
a
nd
Part
A
Permit
application
site
identification
information),
none
of
this
information
is
duplicative
of
other
information
collected
by
othe
EPA
offices
or
other
federal
agencies.

3(
b)
Public
Notice
EPA
solicited
public
comments
on
this
ICR
through
an
announcement
in
the
Federal
Register
on
June
23,
2000
(
65
FR
39142).
The
public
comment
period
ended
August
22,
2000.
EPA
received
nine
comments.
Commenters
supported
implementation
of
the
proposed
changes
to
the
2001
Hazardous
Waste
Report.
Commenters:
supported
the
merging
of
common
elements
of
site
identification
information
(
from
the
Biennial
Report
IC
form,
the
Notification
of
Hazardous
Waste
Activity
form,
and
the
Part
A
Permit
Application
form);
collecting
waste
codes
on
the
notification
form;
not
reporting
hazardous
waste
exports
in
the
Biennial
Report;
to
report
hazardous
waste
imports
in
the
Biennial
Report;
clarifing
the
types
of
hazardous
wastes
reported
in
the
Biennial
Report;
to
streamline
the
Biennial
Report
Source,
Origin,
Form,
and
Management
codes;
removing
certain
data
elements
from
the
Biennial
Report.
Comments
were
mixed
on:
the
reporting
of
universal
waste
on
the
new
Site
Identification
form;
whether
the
Source
of
waste
should
be
a
mandatory
data
element;
and
whether
the
Biennial
Report
is
a
useful
tool
for
information
gathering
and
disemination.

3(
c)
Consultations
EPA
consulted
with
one
TSDF
and
several
States
to
obtain
input
on
the
assumptions
used
in
this
ICR.
The
states
were
suggested
by
the
Association
of
State
and
Territorial
Solid
Waste
Management
Officials,
the
state
organization
who
partnered
this
effort
with
EPA.
The
consultations
were
conducted
with:

Name
of
Company
or
State
Contact
Telephone
No.
Safety
Kleen
Scott
Webber
803­
933­
4200
State
of
Indiana
Jenny
Dooley
371­
232­
8925
State
of
Louisiana
James
Miller
and
Joyce
Metoyer
225­
765­
0219
and
225­
765­
0168
State
of
Missouri
Bob
Krager
573­
751­
3176
We
also
sent
out
the
recommended
changes
to
the
Biennial
Report
to
all
fifty
states
for
their
review.
We
received
comments
from
thirty
states.
1
Literally
hundreds
of
SIC
codes
were
reported
to
the
1997
Hazardous
Waste
Report
at
the
4­
digit
level.
EPA
has
abbreviated
the
list,
as
shown
in
this
ICR,
by
identifying
these
SIC
codes
at
the
2­
digit
level
(
i.
e.,
28
instead
of
2823).
This
does
not
mean,
however,
that
all
4­
digit
SIC
codes
beginning
with
the
2­
digit
codes
shown
in
the
list
were
reported
to
the
Hazardous
Waste
Report.

Page
7
3(
d)
Effects
of
Less
Frequent
Collection
The
two­
year
cycle
is
statutorily
required.
Though
some
States
collect
the
information
contained
in
the
Hazardous
Waste
Report
on
an
annual
or
quarterly
basis,
EPA
does
not
require
more
frequent
data
collection.

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

3(
f)
Confidentiality
The
2001
Hazardous
Waste
Report
requires
businesses
to
provide
information
on
various
aspects
of
hazardous
waste
generation
and
management.
Some
businesses
consider
some
of
their
hazardous
waste
information
to
be
Confidential
Business
Information
(
CBI).
A
business
may,
if
it
desires,
protect
its
Hazardous
Waste
Report
information
from
public
disclosure
by
asserting
a
claim
of
confidentiality
covering
all
or
part
of
the
information
in
the
Hazardous
Waste
Report
it
furnishes
to
EPA.
When
such
a
claim
is
asserted,
EPA
must
and
will
treat
the
information
in
accordance
with
the
confidentiality
regulations
set
forth
in
40
CFR
Part
2,
Subpart
B.
EPA
also
ensures
that
the
information
collection
procedures
comply
with
the
Privacy
Act
of
1974
and
the
OMB
Circular
108.

3(
g)
Sensitive
Questions
There
are
no
sensitive
questions
asked
in
the
2001
Hazardous
Waste
Report.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents
and
SIC
Codes
Based
on
1997
BRS
data,
the
SIC
codes
that
represent
the
respondents
are
as
follows
(
also
shown
are
the
new
North
American
Industrial
Classification
System
(
NAICS)
codes
that
correspond
to
the
SIC
codes
listed):
1
Page
8
SIC
Code
Description
SIC
Code
NAICS
Agriculture,
Forestry,
and
Fisheries
01­
09
111­
115
Mineral
Industries
10­
14
211­
213
Construction
Industries
15­
17
233­
235
Manufacturing
20­
39
311­
339
Transportation,
Communication,
and
Utilities
41­
49
481­
493;
513
Wholesale
Trade
50­
51
421­
422
Retail
Trade
52­
59
441­
454
SIC
Code
Description
SIC
Code
NAICS
Page
9
Finance,
Insurance,
and
Real
Estate
60­
67
521­
525;
531­
533
Service
Industries
70­
89
541
­
814
Public
Administration
91­
97
921­
928
Nonclassifiable
Establishments
99
Not
Available
4(
b)
Information
Requested
The
Hazardous
Waste
Report
consists
of
four
forms:
Site
Identification
Form,
Waste
Generation
and
Management
(
Form
GM),
Waste
Received
From
Off­
Site
(
Form
WR),
and
Off­
Site
Identification
(
Form
OI).
Only
Large
Quantity
Generators
and
Treatment,
Storage,
and
Disposal
Facilities
complete
the
Hazardous
Waste
Report.

(
i)
Data
Items:

C
Site
Identification
Form.
The
Site
Identification
Form
must
be
submitted
by
all
sites
required
to
file
the
2001
Hazardous
Waste
Report.
This
form
collects
information
such
as
site
name,
EPA
ID
number,
address,
and
type
of
hazardous
waste
handling
activities
taking
place
at
the
site.

C
Form
GM
­
Waste
Generation
and
Management.
Form
GM
must
be
submitted
by
all
respondents
that
generated
or
shipped
large
quantity
generator
amounts
of
RCRA
hazardous
waste
during
2001.
This
form
collects
information
on
each
generated
or
shipped
waste,
including
a
narrative
waste
description,
a
waste
characterization
(
e.
g.,
waste
codes,
source
codes),
quantity
generated,
and
what
was
done
with
it.

C
Form
WR
­
Waste
Received
From
Off­
Site.
Form
WR
must
be
submitted
by
all
sites
that
received
RCRA
hazardous
waste
from
off
site
during
2001.
This
form
collects
information
on
each
waste
received
from
off
site,
including
a
narrative
description
of
the
waste,
a
brief
waste
characterization
(
e.
g.,
waste
codes),
the
EPA
ID
number
of
the
generator,
the
quantity
of
waste
received,
and
the
method
of
waste
management.

C
Form
OI
­
Off­
Site
Identification.
Form
OI
is
not
required;
rather,
it
is
provided
as
an
option
for
States
to
collect
the
names
and
addresses
of
those
handlers
that
transport
waste
from,
ship
waste
to,
or
receive
waste
from
their
respondents.
Page
10
Whether
a
code
should
be
mandatory
or
voluntary
was
extensively
discussed
by
the
Waste
Information
Needs
Initiative
team.
Decisions
on
this
issue
represent
a
consensus
opinion
of
EPA
and
state
staff
experts
and
management.

EPA's
state
partners
in
the
Waste
Information
Needs
requested
that
we
include
some
of
the
optional
elements
in
the
2001
Biennial
Report.
The
Form
code
will
help
both
the
states
and
EPA
better
understand
the
nature
of
the
hazardous
waste
being
reported.

The
State
Hazardous
Waste
Codes
were
requested
by
states
who
have
their
own
state
codes
and
would
like
to
track
what
happens
to
this
waste.
If
this
code
did
not
appear
on
the
Biennial
Report,
they
may
not
be
authorized
by
their
state
statutes
to
collect
this
information.
However,
since
not
all
states
collect
state
hazardous
waste
data,
the
WIN
team
decided
that
the
code
would
not
be
mandatory.

Finally,
the
RCRA
Radioactive
Mixed
Waste
code
provides
EPA
with
information
needed
to
monitor
compliance
agreements
with
facilities
under
consent
decrees.
The
WIN
team
did
not
believe
that
this
code
needed
to
be
mandatory.

Review
of
response
rates
in
1995
and
1997
for
these
three
optional
data
elements
showed
that
the
response
rate
was
high
­
94%
response
rate
for
the
Form
code.
Since
there
is
a
high
response
rate,
and
the
data
we
receive
is
of
good
quality,
the
WIN
team
believes
it
is
appropriate
to
keep
collecting
these
optional
data
elements.
Page
11
(
ii)
Respondent
Activities:

Respondents
must
perform
the
following
activities:

C
Read
the
2001
Hazardous
Waste
Report
instructions;
C
Gather
information
and
prepare
Site
Identification
Form;
C
Gather
information
and
prepare
Form
GM;
C
Gather
information
and
prepare
Form
WR;
C
Gather
information
and
prepare
Form
OI
(
State­
optional
form,
not
a
Federal
form);
C
Submit
the
report
to
the
State
or
Regional
EPA
Office;
and
C
Maintain
a
copy
of
each
form
for
three
years.

5.
THE
INFORMATION
COLLECTED
­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
As
with
most
of
the
RCRA
program,
the
Hazardous
Waste
Report
data
collection
process
is
delegated
to
the
States
through
the
EPA
Regions.
Briefly,
the
process
is
as
follows.

States
(
or
EPA
Regions
where
the
Region
implements
the
RCRA
hazardous
waste
program
for
a
given
State)
provide
potential
respondents
with
either
the
Federal
form
or
a
State
equivalent,
collect
the
responses,
endeavor
to
contact
non­
respondents,
enter
the
data
(
or
load
files
if
the
State
employs
electronic
methods
for
preparation
and
submittal
of
reports
by
regulated
entities)
into
a
database
using
off­
the­
shelf
software
packages
which
have
been
developed
to
support
the
collection
of
Biennial
Report
data,
assure
data
quality,
and
forward
the
data
to
EPA.

The
methods
used
by
States
to
identify
those
entities
to
whom
they
distribute
forms
and
the
methods
for
subsequent
tracking
of
reports
received
are
at
the
discretion
of
States.
Most
States
generate
initial
mailing
lists
based
on
previous
report
submittals
augmented
by
recent
notifications
of
regulated
activity.
Many
States
levy
fees
based
on
the
nature
and
extent
of
regulated
activity
identified
in
the
report.
Therefore
they
typically
devote
considerable
care
to
validating
that
all
those
who
are
required
to
submit
reports
do
so.
EPA
does
not
require
States
to
provide
statistics
on
response
rates
so
exact
information
is
not
available.
However,
the
response
rates
are
generally
considered
to
be
very
high.
In
addition,
EPA
makes
all
report
data
(
except
for
that
claimed
as
CBI)
publicly
available
over
the
Internet.
This
provides
further
incentive
for
sites
(
and
also
for
States
and
EPA)
to
ensure
the
information
is
complete
and
accurate
because
the
public
does
regularly
access
this
information
The
Regions
work
with
and
support
States
in
data
gathering
and
data
quality
assessment.
Regions
may
also
provide
technical
support
to
States
for
the
transfer
of
their
files
to
EPA
for
incorporation
into
the
national
database.
Page
12
EPA
Headquarters
produces
and
distributes
the
Federal
forms
and
related
guidance,
defines
the
data
and
file
format
for
nationally
required
data,
establishes
the
schedule
for
submitting
data,
manages
the
incorporation
of
State
data
into
the
national
database,
coordinates
national
data
quality
review,
maintains
the
national
database,
and
prepares
a
national
report
listing
major
facts
about
the
national
picture
of
hazardous
waste
generation
and
management
for
the
reporting
cycle.

In
practice,
this
distribution
of
activities
does
not
always
follow
this
path.
In
some
cases,
the
Region
performs
all
of
the
State
roles.
In
others,
the
Region
provides
direct
processing
support
for
some,
but
not
all,
of
the
collection
activities.
In
still
other
cases,
the
Regions
provide
additional
resources
to
the
States.

EPA
activities
for
the
2001
Hazardous
Waste
Report
include
the
following:

C
Develop
2001
Hazardous
Waste
Report
forms
and
instructions.

C
Distribute
Hazardous
Waste
Report
forms
and
instructions.
EPA
Headquarters
distributes
the
form
and
instruction
booklets
to
the
States
and
Regions.
States
(
or
Regions)
prepare
mailing
lists,
mail
forms
and
instructions,
record
receipt
of
completed
forms,
and
contact
sites
that
fail
to
respond
within
the
specified
time
period.
Some
States
may
pre­
populate
Site
Identification
Forms
prior
to
distribution.

C
Develop
computer
capabilities
required
to
compile
national
data.
EPA
Headquarters
develops
the
computer
capabilities
required
to
load
data
into
the
national
database,
the
reports
which
support
data
quality
assessment
and
other
programmatic
use
of
the
data,
and
preparation
of
the
national
report.

C
Assist
respondents.
States,
Regions,
and
Headquarters
provide
assistance
to
respondents.
EPA
operates
a
national
toll­
free
telephone
help
line
to
answer
respondent
questions.

C
Enter
report
submissions.
States
or
Regions,
and
the
regulated
entities,
key
enter
or
electronically
load
the
data
into
a
database.
The
data
entry
function
is
being
privatized
for
the
2001
Hazardous
Waste
Report
cycle.
States,
Regions,
and
the
regulated
community
will
use
one
of
the
private
vendor's
software
packages
for
data
entry.

C
Perform
quality
assurance.
States,
Regions,
and
Headquarters
all
perform
data
quality
assurance.
This
includes
follow­
up
to
non­
respondents,
the
detection
and
correction
of
unacceptable
responses
(
e.
g.,
in
cases
where
the
respondent
misunderstood
the
instructions),
and
the
verification
of
exceptional
responses
(
e.
g.,
data
reported
by
a
respondent
that
differ
significantly
from
data
reported
by
the
rest
of
the
respondent
universe)
and
significant
response
changes
between
Page
13
report
years.
The
national
software
will
support
these
activities
with
a
variety
of
functions.

Once
reports
are
received,
the
QA/
QC
procedures
include
a
hierarchy
of
assessments.
First,
system
procedures
ensure
the
data
has
fundamental
internal
consistency
(
required
elements
are
populated;
elements
are
of
the
correct
data
type;
values
are
within
allowed
ranges).

Second,
the
information
content
of
the
data
for
individual
sites
is
evaluated
to
identify
any
potential
over
or
under
reporting
(
exception
reports
support
identification
of
extremes,
and
significant
variance
from
one
cycle
to
another).

Third,
assessment
reports
support
evaluation
of
intra­
State
and
inter­
State
shipments
of
wastes
to
identify
potential
discrepancies
between
reports
submitted
by
generators
and
the
TSDF's
who
were
identified
by
the
generator
as
having
received
the
waste.

Based
on
the
results
of
the
assessments
noted
above,
States
identify
any
cases
where
accuracy
may
be
questionable.
For
those
cases
they
generally
contact
the
site
to
review
the
information
received,
and
obtain
confirmation
that
it
is
correct
or
that
the
site
intends
to
submit
an
amended
report
to
correct
discrepancies.
If
they
feel
it
is
warranted,
they
may
chose
to
perform
an
inspection
at
the
site
to
validate
the
information.
However,
that
would
be
an
exceptional
case.

C
Prepare
the
national
report.
EPA
will
prepare
The
National
Biennial
RCRA
Hazardous
Waste
Report
(
Based
on
2001
Data)
that
will
be
made
available
to
the
Congress
and
the
public.

C
Store
the
data.
The
2001
Hazardous
Waste
Reports
(
paper
copies)
will
be
stored
by
the
States
or
Regions
for
three
years,
and
an
electronic
database
may
be
maintained
by
each
State
or
Region.
The
national
database
will
be
maintained
by
EPA
Headquarters.

5(
b)
Collection
Methodology
and
Management
To
ensure
that
the
Hazardous
Waste
Report
data
collected
are
accurate,
complete,
and
retrievable,
EPA
has
employed
a
variety
of
user
support,
automatic
data
processing,
and
process
management
techniques.
Page
14
User
Support.
To
ensure
that
respondents
can
accurately
complete
the
forms,
EPA
has
provided
a
toll­
free
telephone
help
line.
The
help
line
will
refer
respondents
to
the
appropriate
State
or
Regional
contact
for
assistance
if
they
wish
to
file
their
2001
Hazardous
Waste
Report
on
magnetic
media.

Automatic
Data
Processing.
The
Hazardous
Waste
Report
data
collection
effort
is
delegated
to
the
States
and
is
therefore
decentralized.
Central
to
the
this
process
is
the
national
Biennial
Reporting
System
software
and
related
procedures
developed
by
EPA
to
support:

C
Acceptance
of
the
data
into
a
standard
electronic
format;

C
Quality
assurance
of
the
data;

C
Storage
of
national
data;
and
C
Use
of
the
data.

To
support
the
submission
of
data
by
the
States
and
Regions,
EPA
developed
electronic
reporting
standards,
the
documentation
necessary
to
produce
submissions
to
those
electronic
reporting
standards,
and
the
software
necessary
to
load
electronic
submissions.
The
standards
are
simple
ASCII
files.
The
standards
used
for
sites
to
submit
electronically
will
depend
on
which
software
package
the
State
or
Region
is
using.

EPA
provides
a
range
of
reports
to
support
the
national
data
quality
assessment
process.
The
reports
highlight
outlying
data
values
(
e.
g.,
data
reported
by
one
or
more
respondents
that
differ
significantly
from
data
reported
by
the
rest
of
the
respondent
universe),
significant
changes
from
one
report
cycle
to
another
for
a
given
entity
who
has
previously
reported,
and
significant
differences
between
waste
reported
as
shipped
by
one
entity
and
the
corresponding
waste
reported
as
received
by
the
receiving
entity.

EPA
also
provides
technical
reports
to
support
the
loading
of
files
into
the
national
database.
These
reports
facilitate
the
identification
and
resolution
of
incorrect
or
incomplete
data
or
file
formats.

To
protect
the
data
from
unauthorized
alteration,
EPA
implements
security
controls
on
the
national
database
which
limit
file
loading
and
update
privileges
to
authorized
database
administrators,
and
prevents
anything
other
than
read
access
on
the
part
of
State
and
EPA
users.
No
direct
public
access
to
the
national
RCRAInfo
database
is
allowed.
On­
line
public
access
is
supported
by
an
extract
of
the
data
which
is
then
made
available
through
EPA's
Internetaccessible
Envirofacts
database.

Any
information
claimed
as
CBI
is
kept
completely
separate
from
all
other
report
data.
For
compilation
of
the
national
report,
data
is
submitted
to
the
OSW
CBI
office
where
it
is
logged
Page
15
per
the
same
process
used
for
other
CBI
documents.
The
information
on
quantities
of
waste
claimed
as
CBI
are
tabulated
to
include
in
the
quantity
data
for
the
national
report
but
absent
any
references
that
would
allow
derivation
of
the
specific
components
of
an
original
report
or
who
sent
it.

Process
Management.
To
ensure
that
the
necessary
implementation
activities
occur,
EPA
has
established
a
data
collection
process,
assigned
responsibilities
in
the
process,
and
established
a
schedule
for
the
implementation
of
the
process.
Senior
level
EPA
managers
in
the
Regions
and
Headquarters
are
attentive
to
implementation
progress.

States
(
and
EPA
where
EPA
implements
the
program
for
a
given
State)
track
and
monitor
initial
responses
from
the
regulated
community
and
provide
periodic
status
reports
on
progress
to
EPA
Headquarters
coordinators.
As
implementation
proceeds,
headquarters
staff
coordinate
conference
calls
with
Regions
and
their
States
to
confirm
progress
and
identify
any
emerging
problem
areas
(
e.
g.
significant
delays
on
the
part
of
a
given
State).
Mid
and
senior
level
national
managers
are
regularly
updated
on
the
status
of
progress
(
bi­
weekly).

In
addition
to
routine
updating
for
management,
Headquarters
staff
use
the
information
obtained
from
their
regular
discussions
with
States
and
Regions
to
identify
for
senior
management
any
specific
cases
which
may
require
senior
management
action.
Where
necessary,
senior
Headquarters
managers
will
consult
with
their
counterparts
in
the
Regions
to
review
potential
problem
areas
and
determine
approaches
to
overcoming
them
(
e.
g.
shifting
of
resources/
priorities).

Generally,
management
level
discussions
of
progress
with
Regions
occur
as
part
of
regularly
scheduled
monthly
conference
calls
with
senior
RCRA
personnel.
Separate
discussions
with
a
specific
Regional
senior
managers
will
occur
if
there
is
a
unique
problem
case.
Regional
managers
typically
coordinate
discussions
with
State
managers
where
necessary.
In
addition,
senior
State
and
Regional
managers
receive
copies
of
the
national
report
and
they
know
the
information
which
appears
in
the
final
report
will
receive
highly
visible
notice
across
States
and
Regions
as
well
as
from
the
public.

Also,
EPA
provides
training
and
documentation
for
State
and
Regional
personnel
on
the
overall
process
and
on
the
use
of
RCRAInfo.

Finally,
EPA
holds
regular
conference
calls
to
discuss
progress
and
difficulties.
Periodic
status
reports
are
sent
to
EPA
and
State
management
on
progress
towards
meeting
milestones.

5(
c)
Small
Entity
Flexibility
In
implementing
RCRA
Subtitle
C,
EPA
uses
the
quantity
of
waste
generated
per
month
to
determine
the
extent
to
which
a
firm
should
be
regulated.
EPA
categorizes
generators
of
less
Page
16
than
1,000
kilograms
of
non­
acute
hazardous
waste
per
month
as
small
quantity
generators
(
SQGs)
and
relieves
them
of
specified
requirements.

In
particular,
these
SQGs
are
not
required
to
file
the
2001
Hazardous
Waste
Report.
A
SQG
who
is
sent
the
2001
Hazardous
Waste
Report
due
to
a
recent
change
in
status
or
error
need
not
respond.
EPA
has
also
included
a
return
postcard
in
the
2001
Hazardous
Waste
Report
package
to
be
used
to
ensure
they
are
not
the
subject
of
follow­
up
contacts
for
biennial
reporting.

5(
d)
Collection
Schedule
EPA's
2001
Hazardous
Waste
Report
implementation
schedule
is
outlined
below.

Reporting
and
Implementation
Schedule
Activity
Lead
(
HQ,
Region,
or
State)
Start
Date
End
Date
Print
2001
Forms
HQ
January
2001
January
2001
Distribute
2001
Forms
to
States
HQ
Not
Applicable
January
2001
Distribute
2001
Forms
to
Handlers
States
Not
Applicable
January
2001
BRS
Help
Line
HQ
January
2001
June
2002
Handler
2001
Forms
Due
States
Not
Applicable
March
1,
2002
Final
State/
Regional
Data
due
to
HQ
Region
Not
Applicable
November
1,
2002
Develop
Draft
2001
National
Biennial
RCRA
Hazardous
Waste
Report
HQ
November
2002
December
31,
2002
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
EPA
presents
estimates
for
the
respondent
burden
hours
associated
with
all
of
the
information
collection
requirements
covered
in
this
ICR
in
Exhibit
1.
The
exhibit
lists
all
of
the
respondent
activities
associated
with
the
2001
Hazardous
Waste
Report
and
presents
burden
and
cost
estimates
for
each.
The
burden
estimates
are
broken
down
by
labor
category
(
legal,
managerial,
technical,
and
clerical)
and
totaled
on
a
per
activity
basis.
These
burden
estimates
are
then
multiplied
by
the
estimated
number
of
respondents
and
the
estimated
number
of
Page
17
activities
per
respondent
to
obtain
an
estimate
of
the
overall
burden
to
the
regulated
universe
for
each
activity.

Source
of
Burden
Estimates
The
burden
estimates
for
each
activity
are
based
on
the
estimates
contained
in
the
previous
version
of
this
ICR
and
have
been
validated
through
informal
consultations
held
with
States
and
members
of
the
regulated
community
(
see
Section
3(
c)).

Methodology
for
Accounting
for
Site
Identification
Forms
Pre­
Populated
by
States
In
estimating
the
hourly
burden
for
preparing
the
Site
Identification
Form,
EPA
assumed
that
50
percent
of
all
the
Site
Identification
Forms
would
be
pre­
populated
by
States
prior
to
distribution
to
respondents.
This
is
based
on
information
received
from
our
state
partners
in
the
Waste
Information
Needs
Initiative.
Respondents
receiving
these
pre­
populated
forms
need
only
review
and
update
the
data.

Respondents
receiving
blank
forms
would
have
to
complete
the
entire
Site
Identification
Form.
EPA
estimates
the
average
hourly
burden
for
updating
the
pre­
populated
Site
Identification
Form
to
be
0.17
hours
per
respondent,
and
for
completing
the
Site
Identification
Form
in
its
entirety,
0.34
hours
per
respondent.

To
estimate
the
average
burden
per
respondent
in
preparing
a
Site
Identification
Form,
EPA
used
the
weighted­
average
calculation
shown
in
Table
2.
EPA
multiplied
the
percentage
of
(
i)
pre­
populated
Site
Identification
Forms
by
the
average
burden
for
updating
the
information
contained
in
the
form
and
(
ii)
blank
forms
by
the
average
burden
for
completing
the
blank
form.
Then,
EPA
added
up
these
two
products
to
derive
an
overall
weighted­
average
burden.
This
weighted­
average
burden
is
used
to
calculate
the
burden
to
all
respondents
in
completing
the
Site
Identification
Form,
as
shown
in
Exhibit
1.

Table
2
Assumptions
and
Weighted­
Average
Equation
Used
in
Estimating
Burden
to
Prepare
the
Site
Identification
Form
Assumptions
Weighted­
Average
Equation
0.17
hours
to
complete
pre­
populated
form;
50
percent
of
the
forms
are
pre­
populated
(
0.17
hours
x
0.50)
+
(
0.34
hours
x
0.50)
=
0.26
hours
0.34
hours
to
complete
blank
form;
50
percent
of
the
forms
are
blank
Methodology
for
Accounting
for
Electronic
Reporting
Page
18
For
the
2001
Hazardous
Waste
Report,
EPA
held
consultations
with
a
few
State
and
facility
representatives
to
get
feedback
on
the
ICR's
data
and
assumptions.
In
these
conversations,
the
representatives
indicated
that
GM
and
WR
Forms
often
can
be
prepared
from
databases
that
track
manifests
or
other
information
for
billing
purposes.
Based
on
these
and
previous
years'
consultations,
EPA
estimated
the
hourly
burden
for
the
GM
and
WR
Forms
submitted
electronically
to
be
significantly
less
than
for
forms
submitted
on
paper.

To
estimate
the
percentage
of
facilities
that
submit
GM
and
WR
Forms
electronically,
EPA
used
information
gained
from
the
consultations
and
1997
BRS
data.
For
GM
submissions,
EPA
estimated
that,
based
on
consultations
and
best
professional
judgment,
facilities
submitting
15
or
more
GM
Forms
for
the
Hazardous
Waste
Report
are
likely
to
do
so
electronically.
Using
1997
BRS
data,
EPA
identified
sites
submitting
15
or
more
GM
Forms,
counted
their
GM
Forms
submitted,
and
calculated
the
percentage
that
their
GM
Forms
represented
of
the
total
number
of
GM
Forms.
Based
on
this
methodology,
EPA
estimates
that
70
percent
of
GM
Forms
are
submitted
electronically,
while
the
remaining
30
percent
are
sent
manually.

For
WR
Forms,
EPA
believes
that
TSDFs
receiving
large
numbers
of
off­
site
shipments
are
more
likely
to
have
systems
in
place
to
track
waste
stream
data,
and
as
a
consequence,
to
report
Hazardous
Waste
Report
data
electronically.
Using
the
1997
BRS
data,
EPA
reviewed
the
list
of
WR
Forms
reported
to
the
Hazardous
Waste
Report
by
facility
and,
based
on
its
own
professional
judgment
and
consultations,
estimates
that
90
percent
of
WR
Forms
are
submitted
electronically,
while
the
remaining
10
percent
are
sent
manually.

To
estimate
the
average
burden
per
respondent
in
preparing
a
Form
GM
or
WR,
EPA
used
the
weighted­
average
calculations
shown
in
Table
3.
EPA
multiplied
(
i)
the
percentage
of
both
forms
submitted
electronically
by
their
respective
burden
for
electronic
reporting
and
(
ii)
the
percentage
of
both
forms
submitted
manually
by
their
respective
burden
for
manual
reporting.
Then,
EPA
added
the
two
products
for
each
form
respectively
to
calculate
an
overall
weightedaverage
burden
for
both
forms.
These
weighted­
average
burden
estimates
are
used
to
calculate
the
burden
to
all
respondents
in
preparing
these
forms,
as
shown
in
Exhibit
1.

Table
3
Assumptions
and
Weighted­
Average
Equations
Used
in
Estimating
Burden
to
Prepare
the
GM
and
WR
Forms
Activity
Assumptions
Weighted­
Average
Equation
Page
19
Prepare
GM
Form
1.26
hours
to
complete
manually;
30
percent
of
the
forms
are
completed
manually
0.08
hours
to
complete
electronically;
70
percent
of
the
forms
are
completed
electronically
(
1.26
hours
x
0.30)
+
(
0.08
hours
x
0.70)
=
0.43
hours
Prepare
WR
Form
1.31
hours
to
complete
manually;
10
percent
of
the
forms
are
completed
manually
0.13
hours
to
complete
electronically;
90
percent
of
the
forms
are
completed
electronically
(
1.31
hours
x
0.10)
+
(
0.13
hours
x
0.90)
=
0.25
hours
2
The
book
was
edited
by
Eva
Jacobs,
and
was
published
in
1998
by
Bernan
Press.
EPA
used
the
labor
rates
in
the
1998
publication
and
then
updated
them
to
year
2000
levels
using
an
annual
employment
cost
index
of
3.0.

3
Based
on
the
report
Estimating
Costs
for
the
Economic
Benefits
of
RCRA
Noncompliance.
The
report
was
authored
by
U.
S.
EPA,
RCRA
Enforcement
Division,
Office
of
Regulatory
Enforcement,
and
was
published
in
February
1997.

Page
20
6(
b)
Estimating
Respondent
Costs
Estimating
Labor
Costs
EPA
estimates
an
average
hourly
respondent
labor
cost
(
including
overhead)
of
$
108.00
for
legal
staff,
$
77.00
for
managerial
staff,
$
57.00
for
technical
staff,
and
$
29.00
for
clerical
staff.
To
arrive
at
these
estimates,
EPA
consulted
the
Handbook
of
U.
S.
Labor
Statistics,
Second
Edition2,
which
summarizes
the
unloaded
(
base)
hourly
rate
for
various
labor
categories
in
U.
S.
firms.
EPA
then
applied
an
overhead
factor
of
2.3
for
non­
legal
staff
and
3.0
for
legal
staff
to
derive
their
loaded
hourly
rates.
3
Using
the
total
burden
hours
discussed
in
Section
6(
a)
and
the
wage
rates
outlined
in
this
section,
Exhibit
1
illustrates
the
labor
costs
associated
with
all
of
the
information
collection
requirements
covered
in
this
ICR.

Estimating
Capital
and
O&
M
Costs
To
submit
the
Hazardous
Waste
Report,
EPA
estimates
that
facilities
will
incur
a
onetime
postage
cost
of
$
1.50
each
year
for
the
two­
year
period
of
the
ICR.
This
estimate
is
based
on
the
mailing
cost
of
$
3.00
for
a
certified
mail
package.

EPA
estimates
that
facilities
will
incur
annual
operation
and
maintenance
(
O&
M)
costs
associated
with
maintaining
a
copy
of
each
form
for
three
years.
For
respondents
that
submit
paper
versions
of
the
forms,
EPA
estimates
that
to
maintain
files,
facilities
will
purchase
file
cabinets
and
make
photocopies.
For
respondents
that
submit
the
information
electronically,
EPA
estimates
that
to
maintain
files,
facilities
will
purchase
disk
storage
space
(
e.
g.,
floppy
disks).
EPA
estimates
that
file
storage,
whether
paper
or
electronic,
will
cost
$
0.01
per
form
and
that
photocopying
charges
will
cost
$
0.10
per
form
submitted
for
the
two­
year
period
of
the
ICR.
As
with
burden
hours,
the
costs
for
electronic
reporting
are
incorporated
into
the
cost
estimates
for
the
GM
and
WR
Forms
by
multiplying
the
proportion
electronically
reporting
by
the
O&
M
cost
for
electronic
reporting
($
0.01)
plus
the
proportion
using
manual
reporting
multiplied
by
the
O&
M
costs
for
respondents
that
submit
the
paper
forms
($
0.01+$
0.10).
Page
21
EXHIBIT
1
THE
2001
HAZARDOUS
WASTE
REPORTa
ESTIMATED
ANNUAL
RESPONDENT
BURDEN
AND
COST
Hours
and
Costs
Per
Respondent
Total
Hours
and
Costs
Leg.
Mgr.
Tech.
Cler.
Respon.
Labor
Capital/
Number
of
Total
Total
INFORMATION
COLLECTION
$
108.00/
$
77.00/
$
57.00/
$
29.00/
Hours/
Cost/
Startup
O&
M
Respon.
Hours/
Cost/
ACTIVITY
Hour
Hour
Hour
Hour
Activity
Activity
Cost
Cost
Activities
Year
Year
Read
the
2001
Hazardous
Waste
Report
instructions
0.00
1.00
1.00
0.00
2.00
$
134.00
$
0.00
$
0.00
10,157
20,314
$
1,361,038
Gather
information
and
prepare
Site
Identification
Form
0.00
0.05
0.16
0.05
0.26
$
14.14
$
0.00
$
0.00
10,157
2,590
$
143,620
Gather
information
and
prepare
Form
GM
0.00
0.08
0.32
0.04
0.43
$
25.06
$
0.00
$
0.00
125,327
54,267
$
3,140,695
Gather
information
and
prepare
Form
WR
0.00
0.00
0.19
0.06
0.25
$
12.68
$
0.00
$
0.00
369,563
91,775
$
4,686,059
Gather
information
and
prepare
Form
OI
0.00
0.00
0.00
0.00
0.00
$
0.00
$
0.00
$
0.00
0
0
$
0
Submit
report
to
the
State
or
Regional
EPA
Office
0.00
0.00
0.00
0.10
0.10
$
2.90
$
0.00
$
1.50
10,157
1,016
$
44,691
Maintain
a
copy
of
each
form
for
three
years
0.00
0.00
0.01
0.04
0.05
$
1.73
$
0.00
$
0.02
505,047
25,252
$
883,832
TOTAL
Varies
Varies
Varies
Varies
Varies
Varies
Varies
Varies
Varies
195,214
$
10,259,935
a
The
exhibit
contains
rounding.
Page
22
EXHIBIT
2
THE
2001
HAZARDOUS
WASTE
REPORT
ESTIMATED
ANNUAL
AGENCY/
STATE
BURDEN
AND
COST
Hours
and
Costs
Per
Respondent
Total
Hours
and
Costs
Leg.
Mgr.
Tech.
Cler.
Respon.
Labor
Capital/
Number
of
Total
Total
INFORMATION
COLLECTION
$
67.44/
$
59.50/
$
42.80/
$
18.26/
Hours/
Cost/
Startup
O&
M
Respon.
Hours/
Cost/
ACTIVITY
Hour
Hour
Hour
Hour
Activity
Activity
Cost
Cost
Activities
Year
Year
Develop
2001
Report
forms
and
instructions
0.00
4.00
16.00
0.00
20.00
$
922.80
$
0.00
$
20,000.00
1
20
$
20,923
Distribute
and
collect
Report
forms
and
instructions
0.00
0.05
0.39
0.43
0.87
$
27.52
$
0.00
$
1.50
10,157
8,837
$
294,756
Develop
computer
capabilities
required
to
compile
national
data
0.00
12.00
32.00
0.00
44.00
$
2,083.60
$
0.00
$
250,000.00
1
44
$
252,084
Assist
respondents
0.00
0.08
0.39
0.63
1.10
$
32.96
$
0.00
$
0.00
10,157
11,173
$
334,775
Key
entry
of
report
submissions
0.00
0.01
0.04
0.22
0.27
$
6.44
$
0.00
$
0.00
79,633
21,501
$
512,837
Perform
quality
assurance
0.00
0.03
0.18
0.17
0.38
$
12.41
$
0.00
$
0.00
505,047
191,918
$
6,267,633
Prepare
the
National
Report
and
other
Analyses
0.00
12.00
40.00
8.00
60.00
$
2,572.08
$
0.00
$
50,000.00
1
60
$
52,572
Store
the
data
0.00
0.00
2.00
1.00
3.00
$
103.86
$
0.00
$
35,000.00
1
3
$
35,104
TOTAL
Varies
Varies
Varies
Varies
Varies
Varies
Varies
Varies
Varies
233,556
$
7,770,683
4
The
annual
number
of
respondents
for
the
2001
Hazardous
Waste
Report
(
10,157)
is
based
on
the
total
number
of
large
quantity
generators
responding
to
the
1997
Hazardous
Waste
Report
(
i.
e.,
20,314/
2).

Page
23
6(
c)
Estimating
Agency
and
State
Burden
and
Cost
EPA
estimates
annual
Agency
burden
hours
and
costs
associated
with
all
of
the
requirements
covered
in
this
ICR
in
Exhibit
2.
EPA
believes
that
the
Headquarters,
Regional,
and
State
offices
will
be
involved
in
these
activities.
These
burdens
assume
that
all
States
use
the
Federal
2001
Hazardous
Waste
Report
forms
and
BRS
software.
Based
on
the
2000
GS
Pay
Schedule,
EPA
estimates
an
average
hourly
labor
cost
of
$
67.44
for
legal
staff
(
GS­
15,
Step
5),
$
59.50
for
managerial
staff
(
GS­
15,
Step
1),
$
42.80
for
technical
staff
(
GS­
13,
Step
1),
and
$
18.26
for
clerical
staff
(
GS­
6,
Step
1).
To
derive
these
hourly
estimates,
EPA
divided
the
annual
compensation
estimates
by
2,080,
which
is
the
number
of
hours
in
the
Federal
work­
year,
and
then
multiplied
the
hourly
rates
by
the
standard
government
overhead
factor
of
1.6.

As
shown
in
Exhibit
2,
depending
on
the
type
of
Agency
and
State
activity,
some
of
the
total
burden
per
Agency
activity
is
based
on
the
number
of
respondents
or
the
number
of
forms.
Burden
hours
for
entering
report
submissions
for
each
labor
category
account
for
electronic
reporting;
burden
for
key
entry
is
multiplied
by
the
proportion
of
total
forms
submitted
on
paper
and
added
to
the
burden
for
electronically
loading
the
data
(
estimated
to
be
one­
tenth
the
burden
for
key
entry)
multiplied
by
the
proportion
of
forms
expected
to
be
submitted
electronically
(
see
Section
6(
a)).

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Cost
EPA
estimates
that
the
total
number
of
respondents
to
the
2001
Hazardous
Waste
Report
will
be
approximately
20,314,
which
annualized
over
the
two­
year
report
cycle
equals
10,157
per
year.
4
We
considered
other
methods
of
estimating
the
number
of
responses
(
such
as
looking
at
the
number
of
respondents
in
past
Biennial
Reports,
but
the
numbers
fluctuated,
and
we
could
not
develop
projections).

The
number
of
respondents
and
forms
for
each
respondent
activity
is
presented
below.
These
estimates
assume
that
all
questions
and
forms
are
submitted
in
accordance
with
the
Biennial
Report
instructions.
Exhibit
1
calculates
the
annual
respondent
burden
and
cost
for
the
activities
examined.

Read
the
Instructions
EPA
estimates
that
all
20,314
respondents
will
read
the
instructions
to
the
2001
Hazardous
Waste
Report.
Annualized
over
the
two­
year
report
cycle,
this
results
in
10,157
facilities
reading
the
instructions
each
year.
5
The
number
of
2001
Forms
GM
submitted
per
year
(
125,327)
is
based
on
the
total
number
of
Forms
GM
submitted
to
the
1997
Hazardous
Waste
Report,
less
exports
(
i.
e.,
250,653/
2).

6
The
annual
number
of
respondents
submitting
2001
Forms
WR
(
272)
is
based
on
the
total
number
of
respondents
submitting
Forms
WR
for
the
1997
Hazardous
Waste
Report
(
i.
e.,
543/
2).
The
number
of
Forms
WR
submitted
per
year
(
369,563)
is
based
on
the
total
number
of
Forms
WR
submitted
to
the
1997
Hazardous
Waste
Report
(
i.
e.,
739,126/
2).

Page
24
Gather
Information
and
Prepare
Site
Identification
Form
EPA
estimates
that
all
20,314
respondents
will
prepare
and
submit
a
Site
Identification
Form
with
the
2001
Hazardous
Waste
Report.
Annualized
over
the
two­
year
report
cycle,
this
results
in
10,157
respondents
preparing
and
submitting
a
Site
Identification
Form
each
year.
EPA
further
assumes
that
50
percent
of
forms
will
be
pre­
populated
by
States,
in
which
case
respondents
need
only
review
and
update
the
data.
Respondents
receiving
blank
forms
will
need
to
complete
the
form.
EPA
estimates
that,
on
average,
a
pre­
populated
Site
Identification
Form
will
take
about
0.17
hours
to
update
and
a
blank
Site
Identification
Form
will
take
about
0.34
hours
to
prepare.
Thus,
on
average,
EPA
assumes
each
respondent
will
take
about
0.26
hours
(
weighted­
average)
to
update/
prepare
a
Site
Identification
Form.

Gather
Information
and
Prepare
Form
GM
EPA
anticipates
that
each
year
10,157
respondents
will
submit
125,327
GM
Forms
to
EPA.
5
EPA
estimates
that,
on
average,
a
Form
GM
will
take
about
1.26
hours
to
prepare
manually
and
0.08
hours
to
prepare
electronically.
EPA
further
assumes
that
30
percent
of
forms
will
be
prepared
manually
and
70
percent
will
be
prepared
electronically.
Thus,
on
average,
EPA
assumes
each
respondent
will
take
about
0.43
hours
(
weighted­
average)
to
prepare
each
Form
GM.

Gather
Information
and
Prepare
Form
WR
EPA
expects
that
each
year
272
(
543/
2)
respondents
will
each
submit
a
total
of
369,563
Forms
WR
to
EPA.
6
Note
that
the
number
of
WR
Forms
represents
the
number
of
blocks
on
Form
WR
that
have
been
completed;
the
paper
form
actually
contains
three
blocks
of
the
same
WR
information
(
i.
e.,
the
same
questions,
repeated
three
times
on
the
same
page).
EPA
estimates
that
a
Form
WR
will
take,
on
average,
about
1.31
hours
to
prepare
manually
and
0.13
hours
to
prepare
electronically.
EPA
further
assumes
that
10
percent
of
forms
will
be
prepared
manually
and
90
percent
will
be
prepared
electronically.
Thus,
on
average,
EPA
assumes
each
respondent
will
take
about
0.25
hours
(
weighted­
average)
to
prepare
each
Form
WR.

Gather
Information
and
Prepare
Form
OI
Page
25
Because
this
form
is
a
State­
optional
form,
EPA
does
not
expect
any
facilities
to
submit
Form
OI
and
therefore
does
not
calculate
the
burden
for
this
form.

Submit
the
Hazardous
Waste
Report
to
State/
Region
EPA
expects
each
respondent,
10,157
facilities
per
year,
to
submit
the
report
to
the
appropriate
State
or
Region.

Maintain
a
Copy
of
Each
Form
EPA
expects
facilities
to
retain
an
estimated
505,047
(
10,157
+
125,327
+
369,563)
forms
each
year.

6(
e)
Bottom
Line
Burden
and
Cost
Tables
Respondent
Tally
Exhibit
3
presents
the
bottom
line
respondent
burden
and
costs
associated
with
the
2001
Hazardous
Waste
Report.
EPA
estimates
that
respondents
will
incur
an
annual
burden
of
195,214
hours
and
a
cost
of
$
10,259,935.
Exhibit
3
also
presents
cost
estimates
by
type
(
labor,
capital/
startup,
or
O&
M)
as
well
as
two­
year
totals
for
burden
and
costs
(
to
reflect
the
overall
burden
and
costs
incurred
by
respondents
over
the
two­
year
period
covered
by
this
ICR).

EXHIBIT
3
THE
2001
HAZARDOUS
WASTE
REPORT
TOTAL
ESTIMATED
RESPONDENT
BURDEN
AND
COST
SUMMARY
(
FROM
EXHIBIT
1)

Annual
Burden
Annual
Labor
Cost
Annual
Capital/
Startup
Cost
Annual
O&
M
Cost
Total
Annual
Cost
Total
195,214
$
10,234,598
$
0
$
25,336
$
10,259,935
2­
Year
Total
390,428
$
20,469,196
$
0
$
50,673
$
20,519,870
Agency
Tally
Exhibit
4
presents
the
bottom
line
Agency
burden
and
costs
associated
with
the
2001
Hazardous
Waste
Report.
EPA
estimates
an
Agency
annual
burden
of
233,556
hours
and
a
cost
of
$
7,770,683.
Exhibit
4
also
presents
cost
estimates
by
type
(
labor,
capital/
startup,
or
O&
M)
as
well
as
two­
year
totals
for
burden
and
costs
(
to
reflect
the
overall
burden
and
costs
incurred
by
the
Agency
over
the
two­
year
period
covered
by
this
ICR).
Page
26
EXHIBIT
4
THE
2001
HAZARDOUS
WASTE
REPORT
TOTAL
ESTIMATED
AGENCY/
STATE
BURDEN
AND
COST
SUMMARY
(
FROM
EXHIBIT
2)

Annual
Burden
Annual
Labor
Cost
Annual
Capital/
Startup
Cost
Annual
O&
M
Cost
Total
Annual
Cost
Total
233,556
$
7,400,447
$
0
$
370,236
$
7,770,683
2­
Year
Total
467,112
$
14,800,895
$
0
$
740,471
$
15,541,366
6(
f)
Reasons
For
Change
In
Burden
As
shown
in
Exhibit
3,
the
overall
(
two­
year)
burden
estimate
for
the
2001
Hazardous
Waste
Report
is
390,428.
This
represents
an
increase
of
61,822
hours
from
the
estimated
burden
of
the
1999
Hazardous
Waste
Report
(
328,606
hours).

This
change
in
burden
has
occurred
for
several
reasons.
EPA
has
reduced
and
streamlined
the
data
elements
on
the
2001
GM
and
WR
Forms.
This
has
resulted
in
a
minor
reduction
in
the
time
spent
by
those
manually
filling
out
the
forms
(
resulting
in
an
approximately
one
percent
annual
burden
reduction
to
the
regulated
community
overall).

However,
this
reduction
in
burden
was
offset
because
EPA
decreased
its
estimate
of
the
percentage
of
GM
and
WR
Forms
submitted
electronically
(
from
72
to
70
percent
for
GM
Forms
and
from
97
to
90
percent
for
WR
Forms).
Decreasing
the
percentage
of
forms
submitted
electronically
increased
EPA's
estimated
weighted­
average
burden
per
form,
which
was
used
in
Exhibit
1
to
calculate
the
burden
for
the
entire
respondent
universe.
(
See
Table
3
for
a
description
of
the
weighted­
average
calculations.)
In
addition,
EPA
increased
its
estimate
of
the
respondent
universe
from
18,700
respondents
in
the
1999
ICR
to
20,314
in
the
2001
ICR.
Note
that
the
1999
ICR
used
preliminary
1997
BRS
data,
whereas
the
2001
ICR
uses
finalized
1997
BRS
data.

6(
g)
Burden
Statement
Total
public
burden
for
this
information
collection
is
estimated
to
average
approximately
19.22
hours
per
respondent
annually.
The
annual
reporting
burden
is
estimated
to
average
16.73
hours
per
respondent,
and
includes
time
for
reviewing
instructions,
gathering
data,
completing
and
reviewing
the
forms,
and
submitting
the
report.
The
annual
record
keeping
requirement
is
estimated
to
average
2.49
hours
per
respondent
and
includes
the
time
for
filing
and
storing
the
Hazardous
Waste
Report
submission
for
three
years.

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

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Director,
Collection
Strategies
Division,
U.
S.
Environmental
Protection
Agency
(
2137),
1200
Pennsylvania
Avenue,
N.
W.,
Washington,
D.
C.
20460;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
and
OMB
control
number
in
any
correspondence.
