3
The
annual
number
of
respondents
for
the
2003
Biennial
Report
(
10,178)
is
based
on
the
total
number
of
large
quantity
generators
responding
to
the
2001
Hazardous
Waste
Report
(
i.
e.,
20,356
divided
by
2).

19
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Cost
EPA
estimates
that
the
total
number
of
respondents
to
the
2003
Biennial
Report
will
be
approximately
20,356,
which
annualized
over
the
two­
year
report
cycle
equals
10,178
per
year.
3
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
20,356
respondents
will
read
the
instructions
to
the
2003
Biennial
Report.
Annualized
over
the
two­
year
report
cycle,
this
results
in
10,178
facilities
reading
the
instructions
each
year.

Gather
Information
and
Prepare
Site
Identification
Form
EPA
estimates
that
all
20,356
respondents
will
prepare
and
submit
a
Site
Identification
Form
with
the
2003
Biennial
Report.
Annualized
over
the
two­
year
report
cycle,
this
results
in
10,178
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
0.5
hours
to
update
and
a
blank
Site
Identification
Form
will
take
about
0.7
hours
to
prepare.
Thus,
on
average,
EPA
assumes
each
respondent
will
take
about
0.6
hours
(
weighted­
average)
to
update/
prepare
a
Site
Identification
Form.

Gather
Information
and
Prepare
Form
GM
EPA
anticipates
that
each
year
10,178
respondents
will
submit
116,901
GM
Forms
to
EPA.
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.
4
The
annual
number
of
respondents
submitting
2001
Forms
WR
(
272)
is
based
on
the
total
number
of
respondents
submitting
Forms
WR
for
the
1997
Biennial
Report
(
i.
e.,
543/
2).

20
Gather
Information
and
Prepare
Form
WR
EPA
expects
that
each
year
272
(
543/
2)
respondents
will
each
submit
a
total
of
377,172
Forms
WR
to
EPA.
4
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
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
Biennial
Report
to
State/
Region
EPA
expects
each
respondent,
10,178
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
505,251
(
10,178
+
116,901
+
377,172)
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
2003
Biennial
Report.
EPA
estimates
that
respondents
will
incur
an
annual
burden
of
196,976
hours
and
a
cost
of
$
10,311,438.
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).
21
EXHIBIT
3
THE
2003
BIENNIAL
REPORT
TOTAL
ESTIMATED
RESPONDENT
BURDEN
AND
COST
SUMMARY
(
FROM
EXHIBIT
1)

Burden
Labor
Cost
Capital/
Startup
Cost
O&
M
Cost
Total
Cost
Annual
Total
196,976
$
10,286,102
$
0
$
25,336
$
10,311,438
2­
Year
Total
393,952
$
20,572,204
$
0
$
50,673
$
20,622,877
Agency
Tally
Exhibit
4
presents
the
bottom
line
Agency
burden
and
costs
associated
with
the
2003
Biennial
Report.
EPA
estimates
an
Agency
annual
burden
of
232,820
hours
and
a
cost
of
$
7,750,798.
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).

EXHIBIT
4
THE
2003
BIENNIAL
REPORT
TOTAL
ESTIMATED
AGENCY/
STATE
BURDEN
AND
COST
SUMMARY
(
FROM
EXHIBIT
2)

Burden
Labor
Cost
Capital/
Startup
Cost
O&
M
Cost
Total
Cost
Annual
Total
232,820
$
7,750,798
$
0
$
370,236
$
8,121,034
2­
Year
Total
465,640
$
15,501,596
$
0
$
740,471
$
16,242,067
6(
f)
Reasons
For
Change
In
Burden
As
shown
in
Exhibit
3,
the
overall
(
two­
year)
burden
estimate
for
the
2003
Hazardous
Waste
Report
is
393,952
hours.
Based
on
reported
data
for
the
2001Hazardous
Waste
Report,
EPA
estimates
a
slight
increase
of
3,524
hours
from
the
estimated
burden
of
the
2001Hazardous
Waste
Report
(
390,428
hours).
This
change
in
burden
has
occurred
for
several
reasons.
Based
on
reported
data
for
the
2001Hazardous
Waste
Report,
EPA
estimates
a
slight
increase
in
the
number
of
respondents,
an
additional
42;
we
estimate
the
increase
in
the
number
of
submitted
forms
to
be
15,218.
The
completion
of
the
RCRA
Subtitle
C
Site
Identification
Form
will
require
an
estimated
additional
20
minutes.
This
has
resulted
in
a
minor
increase
of
2%
in
the
time
to
complete
the
report.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
19.35
hours
per
response.
The
annual
reporting
burden
is
estimated
to
average
16.87
hours
per
response
including
time
for
reviewing
instructions,
gathering
data,
completing
and
reviewing
the
forms,
and
submitting
the
report.
The
annual
recordkeeping
22
requirement
is
estimated
to
average
2.48
hours
per
respondent
including
the
time
for
filing
and
storing
the
Biennial
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.
To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
Number
RCRA­
2002­
0024,
which
is
available
for
public
viewing
at
the
RCRA
Docket
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
RCRA
Docket
is
(
202)
566­
0270.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
Number
RCRA­
2002­
0024
and
OMB
Control
Number
2050­
0024
in
any
correspondence.
