1
Refer
to
proposed
40
CFR
262.200
for
the
definitions
of
"
college/
university"
and
"
laboratory"
under
the
rule.
December
19,
2005
MEMORANDUM
TO:
Patricia
Mercer,
EPA
FROM:
Maribelle
Rodríguez
and
Earl
Harris
SUBJECT:
Analysis
of
Alternative
Options
to
the
Information
Collection
Requirements
in
the
Proposed
Rule
on
Generator
Standards
Applicable
to
C/
U
Laboratories;
Work
Assignment
Number
3­
33,
Contract
Number
68­
W­
02­
006
This
memorandum
is
submitted
under
Task
2
of
the
referenced
work
assignment.
The
memorandum
estimates
the
annual
incremental
hour
and
cost
burden
to
college
and
universities
(
C/
Us)
under
alternative
options
to
the
information
collection
requirements
in
the
proposed
rule
on
generator
standards
applicable
to
C/
U
laboratories.

Section
1
of
this
memorandum
provides
an
overview
of
the
proposed
rule
and
the
alternative
options
considered
by
EPA.
Section
2
discusses
the
methodology
used
to
estimate
the
annual
incremental
hour
and
cost
burden
under
the
alternative
options.
Section
3
estimates
the
annual
incremental
burden
under
Alternative
Option
1.
Section
4
estimates
the
annual
incremental
burden
under
Alternative
Option
2.
Section
5
presents
the
annual
incremental
burden
under
the
proposed
rule
and
the
alternative
options.

Please
do
not
hesitate
to
contact
Earl
at
(
301)
871­
2591
with
questions
or
comments.

1.
Overview
of
the
Proposed
Rule
and
the
Alternative
Options
EPA
is
proposing
to
amend
the
regulations
under
the
Resource
Conservation
and
Recovery
Act
(
RCRA)
applicable
to
the
management
of
hazardous
wastes
generated
in
C/
U
laboratories.
1
The
intent
of
the
proposed
rule
is
to
establish
an
alternative
set
of
generator
requirements
for
C/
U
laboratories
that
is
better
suited
to
their
unique
circumstances,
and
promotes
environmental
protection
and
public
health
through
safer
management
of
laboratory
chemical
wastes.
This
set
of
requirements
would
be
codified
at
40
CFR
Part
262,
Subpart
K.
The
requirements
of
Subpart
K
would
only
apply
to
wastes
generated
in
C/
U
laboratories.
2
EPA,
Assessment
of
Potential
Costs,
Benefits
and
Other
Impacts
for
the
Proposed
Revised
Standards
Applicable
to
Generators
of
Hazardous
Waste;
Subpart
K
­
Academic
Laboratories,
Final
Report.

Page
2
Hazardous
wastes
generated
in
other
parts
of
the
C/
U
and
laboratories
located
in
non­
C/
Us
would
remain
subject
to
the
existing
hazardous
waste
regulations.

Under
the
proposed
rule,
a
C/
U
with
laboratories
that
generate
hazardous
waste
would
have
the
choice
to
manage
its
hazardous
waste
in
accordance
with
the
optional,
alternative
set
of
regulations
or
remain
subject
to
the
existing
generator
regulations
promulgated
in
40
CFR
Part
262.
Unwanted
materials
that
are
generated
in
laboratories
of
participating
C/
Us
must
be
managed
in
the
laboratory
in
accordance
with
the
proposed
Subpart
K
requirements
(
e.
g.,
container
labeling).

In
developing
the
proposed
rule,
EPA
considered
two
alternative
options.
Attachment
A
describes
the
information
collection
requirements
under
the
proposed
rule
and
the
two
alternative
options.

2.
Methodology
In
estimating
the
annual
incremental
hour
and
cost
burden
to
C/
Us
under
the
alternative
options,
ICF
obtained
the
spreadsheets
developed
for
the
Information
Collection
Request
(
ICR)
Supporting
Statement
developed
for
the
proposed
rule
(
i.
e.,
"
Generator
Standards
Applicable
to
College
and
University
Laboratories").
ICF
then
made
minor
modifications
to
the
spreadsheets,
as
appropriate,
in
order
to
estimate
the
annual
incremental
hour
and
cost
burden
to
respondents
under
each
alternative
option.

The
primary
assumptions
used
in
estimating
the
annual
incremental
burden
under
the
alternative
options
include
the
respondent
universe
carrying
out
specified
information
collection
activities,
as
well
as
the
associated
hour
and
cost
burden.
A
general
discussion
of
these
analytical
assumptions
follows.

2.1
Respondent
Universe
Respondent
universe
estimates
were
obtained
from
the
economic
background
document
developed
for
the
proposed
rulemaking.
2
These
estimates
are
discussed
in
the
following
paragraphs.

Alternative
Option
1
Under
this
alternative
option,
EPA
estimates
that
a
total
of
291
C/
Us
will
comply
with
the
Subpart
K
requirements.
Of
these
C/
Us,
EPA
estimates
that
141
will
be
LQGs
and
150
will
be
SQGs.
Page
3
In
addition,
EPA
expects
that,
each
year,
a
total
of
1,240,540
containers
of
unwanted
material
will
be
generated
at
C/
Us
subject
to
the
Subpart
K
requirements.
This
estimate
is
based
on
the
following
assumptions:

°
Each
C/
U
LQG
has
527
laboratories
and
will
generate
1.33
containers
of
unwanted
material
each
month.
Thus,
C/
U
LQGs
will
generate
a
total
of
1,185,940
containers
of
unwanted
material
each
year
(
i.
e.,
141
LQGs
x
527
laboratories/
LQG
x
1.33
containers/
laboratory/
month
x
12
months).

°
Each
C/
U
SQG
has
182
laboratories
and
will
generate
2
containers
of
unwanted
material
each
year.
Thus,
C/
U
SQGs
will
generate
a
total
of
54,600
containers
of
unwanted
material
each
year
(
i.
e.,
150
SQGs
x
182
laboratories/
SQG
x
2
containers/
laboratory/
year).

Alternative
Option
2
Under
this
alternative
option,
EPA
estimates
that
a
total
of
681
C/
Us
will
comply
with
the
Subpart
K
requirements.
Of
these
C/
Us,
EPA
estimates
that
164
will
be
LQGs
and
517
will
be
SQGs.

In
addition,
EPA
expects
that,
each
year,
a
total
of
1,567,579
containers
of
unwanted
material
will
be
generated
at
C/
Us
subject
to
the
Subpart
K
requirements.
This
estimate
is
based
on
the
following
assumptions:

°
Each
C/
U
LQG
has
527
laboratories
and
will
generate
1.33
containers
of
unwanted
material
each
month.
Thus,
C/
U
LQGs
will
generate
a
total
of
1,379,391
containers
of
unwanted
material
each
year
(
i.
e.,
164
LQGs
x
527
laboratories/
LQG
x
1.33
containers/
laboratory/
month
x
12
months).

°
Each
C/
U
SQG
has
182
laboratories
and
will
generate
2
containers
of
unwanted
material
each
year.
Thus,
C/
U
SQGs
will
generate
a
total
of
188,188
containers
of
unwanted
material
each
year
(
i.
e.,
517
SQGs
x
182
laboratories/
SQG
x
2
containers/
laboratory/
year).

2.2
Hour
and
Cost
Burden
Hour
Burden
In
estimating
annual
incremental
hour
burden,
ICF
referred
to
the
ICR
Supporting
Statement
and
the
economic
background
document
developed
for
the
proposed
rulemaking.
Page
4
Cost
Burden
Annual
respondent
costs
associated
with
the
information
collection
requirements
under
the
alternative
options
are
based
on
the
cost
of
labor,
capital,
and
operation
and
maintenance
(
O&
M).
These
costs
are
discussed
in
the
following
subsections.

Labor
Costs
Following
are
the
hourly
respondent
labor
rates
(
including
fringe
and
overhead)
used
in
estimating
the
labor
costs
in
under
the
alternative
options:

°
Legal
staff
$
121.71
°
Managerial
staff
$
60.94
°
Technical
staff
$
33.74
°
Clerical
staff
$
25.23
The
above
hourly
labor
rates
are
in
2005
dollars.
Refer
to
the
ICR
Supporting
Statement
for
a
discussion
on
the
derivation
of
these
hourly
labor
rates.

Capital
Costs
Capital
costs
usually
include
any
produced
physical
good
needed
to
provide
the
needed
information,
such
as
machinery,
computers,
and
other
equipment.
For
purposes
of
this
analysis,
it
is
assumed
that
respondents
will
not
incur
any
incremental
capital
costs
in
carrying
out
the
information
collection
requirements
under
the
alternative
options.

Operation
&
Maintenance
Costs
O&
M
costs
are
those
costs
associated
with
a
paperwork
requirement
incurred
continually
over
the
life
of
the
ICR.
They
are
defined
by
the
Paperwork
Reduction
Act
of
1995
as
"
the
recurring
dollar
amount
of
costs
associated
with
O&
M
or
purchasing
services."
For
purposes
of
this
analysis,
incremental
O&
M
costs
include:

°
Mailing
costs:
EPA
estimates
that
respondents
will
incur
an
incremental
cost
of
$
2.68
to
mail
a
one­
ounce
package
by
certified
mail
($
0.01
for
standard­
size
envelope,
$
0.37
for
postage,
and
$
2.30
for
the
certified­
mail
fee).

°
Label
costs:
EPA
estimates
that
respondents
will
incur
an
incremental
cost
of
$
0.066
per
label.
This
O&
M
cost
is
based
on
label
costs
presented
in
the
economic
background
document
developed
for
this
rulemaking.
Page
5
3.
Annual
Hour
and
Cost
Burden
under
Alternative
Option
1
In
this
section,
ICF
estimates
the
annual
incremental
hour
and
cost
burden
to
respondents
under
Alternative
Option
1.
As
shown
in
Attachment
B,
the
total
annual
incremental
hour
and
cost
burden
to
respondents
under
this
alternative
option
is
57,390
hours
and
$
2,023,184.

A
discussion
of
the
assumptions
used
in
the
development
of
the
burden
estimates
in
Attachment
B
is
presented
in
the
following
subsections.

3.1
Reading
the
Regulations
All
291
C/
Us
electing
to
be
subject
to
the
Subpart
K
requirements
are
expected
to
read
the
regulations
once
during
the
three­
year
life
of
the
ICR.
In
estimating
the
annual
incremental
burden
to
respondents
over
the
three­
year
period
covered
by
the
ICR,
the
burden
of
this
one­
time
activity
was
annualized
by
dividing
the
number
of
respondents
by
three.
Thus,
it
is
estimated
that,
on
average,
97
C/
Us
(
i.
e.,
291
C/
Us
/
3
years)
will
read
the
regulations
each
year.

3.2
Notification
of
Intent
to
Comply
with
the
Subpart
K
Requirements
All
291
C/
Us
electing
to
be
subject
to
the
Subpart
K
requirements
are
expected
to
submit
a
one­
time
notification.
In
estimating
the
annual
incremental
burden
to
respondents
over
the
three­
year
period
covered
by
the
ICR,
the
burden
of
this
one­
time
activity
was
annualized
by
dividing
the
number
of
respondents
by
three.
Thus,
it
is
estimated
that,
each
year,
97
C/
Us
(
i.
e.,
291
C/
Us
/
3
years)
will
prepare,
submit,
and
keep
a
copy
of
the
notification
of
intent
to
comply
with
the
Subpart
K
requirements.

3.3
Notification
of
Intent
to
No
Longer
Comply
with
the
Subpart
K
Requirements
None
of
the
C/
Us
is
expected
to
submit
a
withdrawal
notification
during
the
three­
year
period
covered
by
the
ICR.

3.4
Labeling
of
Containers
of
Unwanted
Materials
in
the
Laboratory
C/
Us
are
expected
to
generate
a
total
of
1,240,540
containers
of
unwanted
materials
each
year.
Under
this
alternative
option,
C/
Us
will
be
required
to
comply
with
prescriptive
labeling
requirements.

3.5
Training
and
Instruction
Under
this
alternative
option,
C/
Us
must
train
all
individuals
working
in
a
laboratory
(
e.
g.,
laboratory
workers)
commensurate
with
their
duties.
In
addition,
C/
Us
that
are
LQGs
must
maintain
training
records
for
laboratory
workers.
Page
6
Under
existing
regulations
(
e.
g.,
OSHA
and
EPA
regulations)
and
C/
Us'
standard
operating
practices,
C/
Us
provide
a
variety
of
training
to
individuals
that
use
and/
or
manage
chemicals,
hazardous
materials,
and
hazardous
wastes
as
part
of
their
job
responsibilities.
Thus,
it
is
assumed
that
the
training
and
instruction
requirements
under
this
alterative
option
will
not
impose
incremental
burden
on
respondents.

3.6
Removal
of
Containers
of
Unwanted
Material
from
the
Laboratory
All
C/
Us
electing
to
be
subject
to
the
Subpart
K
requirements
are
expected
to
remove
their
containers
of
unwanted
material
and
acutely
reactive
unwanted
materials
from
each
laboratory
on
a
monthly
basis.
Because
of
this
frequency
in
the
removal
of
containers,
none
of
the
C/
U
laboratories
are
expected
to
accumulate
more
than
55
gallons
of
unwanted
material
or
1
quart
of
acutely
reactive
unwanted
material
before
the
regularly
scheduled
removal.
As
a
result,
none
of
the
C/
Us
will
need
to
label
any
of
its
containers
with
the
date
the
55
gallons
or
the
1
quart
of
unwanted
material
is
exceeded.

3.7
Making
the
Hazardous
Waste
Determination
in
the
Laboratory
It
is
estimated
that,
each
year,
hazardous
waste
determinations
will
be
made
in
the
laboratory
for
6,552
containers
of
unwanted
materials.
It
is
assumed
that
unwanted
materials
in
all
of
these
containers
will
be
determined
to
be
hazardous
waste
per
40
CFR
261.3
and
thus,
the
appropriate
hazardous
waste
code(
s)
will
be
added
to
the
label
that
is
affixed
to
the
containers.

For
purposes
of
this
analysis,
only
the
addition
of
the
appropriate
hazardous
waste
code(
s)
to
the
container
labels
is
considered
incremental
burden.
Under
existing
regulations
(
40
CFR
262.11),
generators
must
determine
if
their
waste
is
hazardous
per
40
CFR
261.3.
Thus,
the
hazardous
waste
determination
does
not
impose
incremental
burden
on
respondents.

3.8
Making
the
Hazardous
Waste
Determination
at
an
On­
Site
Central
Accumulation
Area
It
is
estimated
that,
each
year,
hazardous
waste
determinations
will
be
made
in
the
on­
site
central
accumulation
area
for
1,233,988
containers
of
unwanted
materials.
It
is
assumed
that
unwanted
materials
in
all
of
these
containers
will
be
determined
to
be
hazardous
waste
per
40
CFR
261.3
and
thus,
the
appropriate
hazardous
waste
code(
s)
will
be
added
to
the
label
that
is
affixed
to
the
containers.

For
purposes
of
this
analysis,
only
the
addition
of
the
appropriate
hazardous
waste
code(
s)
to
the
container
labels
is
considered
incremental
burden.
Under
existing
regulations
(
40
CFR
262.11),
generators
must
determine
if
their
waste
is
hazardous
per
40
CFR
261.3.
Thus,
the
hazardous
waste
determination
does
not
impose
incremental
burden
on
respondents.
Page
7
3.9
Making
the
Hazardous
Waste
Determination
at
an
On­
Site
Interim
Status
or
Permitted
TSDF
It
is
expected
that
no
hazardous
waste
determinations
will
be
made
at
an
on­
site
interim
status
or
permitted
TSDF
during
the
three­
year
period
covered
by
the
ICR.

3.10
Laboratory
Clean­
Outs
Under
this
alternative
option,
each
C/
U
laboratory
is
expected
to
conduct
a
clean­
out
once
per
year.
As
a
result,
101,607
laboratory
clean­
outs
will
be
conducted
under
this
alternative
option.
These
C/
U
laboratories
must
document
the
activities
of
the
laboratory
clean­
out
and
maintain
this
documentation
as
long
as
they
operate
under
Subpart
K.

3.11
Laboratory
Management
Plan
All
291
C/
Us
electing
to
be
subject
to
the
Subpart
K
requirements
will
be
required
to
develop
a
Laboratory
Management
Plan
that
describes
how
the
C/
U
will
comply
with
the
specified
requirements.
These
C/
Us
are
expected
to
revise
an
existing
plan
(
e.
g.,
Chemical
Hygiene
Plan)
to
comply
with
the
Laboratory
Management
Plan
requirement.
In
estimating
the
annual
incremental
burden
to
respondents
over
the
three­
year
period
covered
by
the
ICR,
the
burden
of
this
one­
time
activity
was
annualized
by
dividing
the
number
of
respondents
by
three.
Thus,
it
is
estimated
that,
on
average,
97
C/
Us
(
i.
e.,
291
C/
Us
/
3
years)
will
develop
a
Laboratory
Management
Plan
each
year.

In
addition,
all
291
C/
Us
are
expected
to
review
and
revise
their
Laboratory
Management
Plan
each
subsequent
year.
Thus,
for
purposes
of
this
analysis,
it
is
assumed
that
C/
Us
will
review
and
revise
their
Laboratory
Management
Plan
twice
over
the
three­
year
period
covered
by
the
ICR.
In
estimating
the
annual
incremental
burden
to
respondents
over
this
three­
year
period,
the
burden
of
this
activity
was
annualized
by
multiplying
the
number
of
respondents
by
2/
3.
Thus,
it
is
estimated
that,
on
average,
194
C/
Us
(
i.
e.,
291
x
2/
3)
will
review
and
revise
their
Laboratory
Management
Plan
each
year.

Finally,
all
291
C/
Us
must
retain
the
most
recent
version
of
the
Laboratory
Management
Plan
on
site.

4.
Annual
Hour
and
Cost
Burden
under
Alternative
Option
2
In
this
section,
ICF
estimates
the
annual
incremental
hour
and
cost
burden
to
respondents
under
Alternative
Option
2.
As
shown
in
Attachment
C,
the
total
annual
incremental
hour
and
cost
burden
to
respondents
under
this
alternative
option
is
66,541
hours
and
$
2,324,718
A
discussion
of
the
assumptions
used
in
the
development
of
the
burden
estimates
in
Attachment
C
is
presented
in
the
following
subsections.
Page
8
4.1
Reading
the
Regulations
All
681
C/
Us
electing
to
be
subject
to
the
Subpart
K
requirements
(
i.
e.,
164
LQGs
+
517
SQGs)
are
expected
to
read
the
regulations
once
during
the
three­
year
life
of
the
ICR.
In
estimating
the
annual
incremental
burden
to
respondents
over
the
three­
year
period
covered
by
the
ICR,
the
burden
of
this
one­
time
activity
was
annualized
by
dividing
the
number
of
respondents
by
three.
Thus,
it
is
estimated
that,
on
average,
227
C/
Us
(
i.
e.,
681
C/
Us
/
3
years)
will
read
the
regulations
each
year.

4.2
Labeling
of
Containers
of
Unwanted
Materials
in
the
Laboratory
C/
Us
are
expected
to
generate
a
total
of
1,567,579
containers
of
unwanted
materials
each
year
(
i.
e.,
1,379,391
LQG
containers
+
188,188
SQG
containers).
Under
this
alternative
option,
C/
Us
will
be
required
to
label
each
of
these
containers
with:
(
1)
information
on
the
hazards
or
contents
of
the
container,
(
2)
sufficient
information
for
hazardous
waste
determination,
and
(
3)
the
date
that
unwanted
material
first
began
accumulating
in
the
container.

4.3
Removal
of
Containers
of
Unwanted
Material
from
the
Laboratory
All
C/
Us
electing
to
be
subject
to
the
Subpart
K
requirements
are
expected
to
remove
their
containers
of
unwanted
material
and
acutely
reactive
unwanted
materials
from
each
laboratory
on
a
monthly
basis.
Because
of
this
frequency
in
the
removal
of
containers,
none
of
the
C/
U
laboratories
are
expected
to
accumulate
more
than
55
gallons
of
unwanted
material
or
1
quart
of
acutely
reactive
unwanted
material
before
the
regularly
scheduled
removal.
As
a
result,
none
of
the
C/
Us
will
need
to
label
any
of
its
containers
with
the
date
the
55
gallons
or
the
1
quart
of
unwanted
material
is
exceeded.

4.4
Making
the
Hazardous
Waste
Determination
in
the
Laboratory
It
is
estimated
that,
each
year,
hazardous
waste
determinations
will
be
made
in
the
laboratory
for
73,398
containers
of
unwanted
materials
(
i.
e.,
50,466
LQG
containers
+
22,932
SQG
containers).
It
is
assumed
that
unwanted
materials
in
all
of
these
containers
will
be
determined
to
be
hazardous
waste
per
40
CFR
261.3
and
thus,
the
appropriate
hazardous
waste
code(
s)
will
be
added
to
the
label
that
is
affixed
to
the
containers.

For
purposes
of
this
analysis,
only
the
addition
of
the
appropriate
hazardous
waste
code(
s)
to
the
container
labels
is
considered
incremental
burden.
Under
existing
regulations
(
40
CFR
262.11),
generators
must
determine
if
their
waste
is
hazardous
per
40
CFR
261.3.
Thus,
the
hazardous
waste
determination
does
not
impose
incremental
burden
on
respondents.
Page
9
4.5
Making
the
Hazardous
Waste
Determination
at
an
On­
Site
Central
Accumulation
Area
It
is
estimated
that,
each
year,
hazardous
waste
determinations
will
be
made
in
the
on­
site
central
accumulation
area
for
1,494,181
containers
of
unwanted
materials
(
i.
e.,
1,328,925
LQG
containers
+
165,256
SQG
containers).
It
is
assumed
that
unwanted
materials
in
all
of
these
containers
will
be
determined
to
be
hazardous
waste
per
40
CFR
261.3
and
thus,
the
appropriate
hazardous
waste
code(
s)
will
be
added
to
the
label
that
is
affixed
to
the
containers.

For
purposes
of
this
analysis,
only
the
addition
of
the
appropriate
hazardous
waste
code(
s)
to
the
container
labels
is
considered
incremental
burden.
Under
existing
regulations
(
40
CFR
262.11),
generators
must
determine
if
their
waste
is
hazardous
per
40
CFR
261.3.
Thus,
the
hazardous
waste
determination
does
not
impose
incremental
burden
on
respondents.

4.6
Making
the
Hazardous
Waste
Determination
at
an
On­
Site
Interim
Status
or
Permitted
TSDF
It
is
expected
that
no
hazardous
waste
determinations
will
be
made
at
an
on­
site
interim
status
or
permitted
TSDF
during
the
three­
year
period
covered
by
the
ICR.

4.7
Laboratory
Clean­
Outs
Under
this
alternative
option,
each
C/
U
laboratory
is
expected
to
conduct
a
clean­
out
once
per
year.
As
a
result,
86,428
laboratory
clean­
outs
will
be
conducted
at
C/
U
LQGs
(
i.
e.,
164
LQGs
x
527
laboratories/
LQG)
and
94,094
laboratory
clean­
outs
will
be
conducted
at
C/
U
SQGs
(
i.
e.,
517
SQGs
x
182
laboratories/
SQG).
These
180,522
C/
U
laboratories
(
i.
e.,
86,428
+
94,094)
must
document
the
activities
of
the
laboratory
clean­
out
and
maintain
this
documentation
as
long
as
they
operate
under
Subpart
K.

5.
Summary
Exhibit
1
presents
the
annual
incremental
burden
under
the
proposed
rule
and
the
alternative
options.
It
shows
that
the
annual
incremental
burden
to
respondents
is:

°
59,136
hours
and
$
2,084,260
under
the
proposed
rule;

°
57,390
hours
and
$
2,023,184
under
Alternative
Option
1;
and
°
66,541
hours
and
$
2,324,718
under
Alternative
Option
2.
Page
10
Hour
Cost
Hour
Cost
Hour
Cost
99.00
$
6,190.47
97.00
$
6,065.41
227.00
14,194.31
79.20
$
4,031.28
178.48
$
7,855.06
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
25,651.89
$
943,989.42
24,810.79
$
913,037.23
31,351.58
$
1,153,738.06
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
972.13
$
32,566.42
131.04
$
4,389.84
1,467.95
$
49,176.34
24,679.75
$
826,771.77
24,679.75
$
826,771.77
29,883.63
$
1,001,101.51
0.00
$
0.00
0.00
$
0.00
0.00
$
0.00
2,084.84
$
61,502.78
2,032.14
$
59,948.13
3,610.44
$
106,507.98
5,569.60
$
209,207.92
5,461.10
$
205,116.20
0.00
$
0.00
59,136.41
$
2,084,260.06
57,390.30
$
2,023,183.64
66,540.60
$
2,324,718.20
Proposed
Rule
Alternative
Option
1
Alternative
Option
2
Exhibit
1
Annual
Incremental
Hour
and
Cost
Burden
to
Respondents
under
the
Proposed
Rule
and
the
Alternative
Options
a
Page
A­
1
Attachment
A
Description
of
Information
Collection
Requirements
under
the
Proposed
Rule
and
Alternative
Options
Proposed
Rule
Alternative
Option
1
Alternative
Option
2
Notification
of
Intent
to
Comply
with
the
Subpart
K
Requirements
(
40
CFR
262.203)

A
C/
U
must
notify
the
appropriate
EPA
Regional
Administrator
or
State
Director
that
it
is
electing
to
be
subject
to
the
requirements
of
Subpart
K
for
all
laboratories
located
at
the
C/
U
under
the
same
EPA
ID
number.
A
copy
of
the
notification
must
be
kept
on
file
at
the
C/
U
while
the
C/
U
is
subject
to
Subpart
K.
Same
as
Proposed
Rule.
No
notification
requirement.

Notification
of
Intent
to
No
Longer
Comply
with
the
Subpart
K
Requirements
(
40
CFR
262.204)

A
C/
U
may
elect
to
notify
the
appropriate
EPA
Regional
Administrator
or
State
Director
in
writing
that
the
C/
U
no
longer
will
be
subject
to
the
requirements
of
Subpart
K
for
the
laboratories
located
at
the
C/
U
under
the
same
EPA
ID
number.

A
copy
of
the
withdrawal
notice
must
be
kept
on
file
at
the
C/
U
for
three
years
from
the
date
of
the
letter.
Same
as
Proposed
Rule.
No
notification
requirement.

Labeling
of
Containers
of
Unwanted
Materials
in
the
Laboratory
(
40
CFR
262.206)

C/
Us
must
label
containers
of
unwanted
materials
managed
in
a
laboratory
with:
(
1)
information
on
the
hazards
or
contents
of
the
container,
(
2)
sufficient
information
for
hazardous
waste
determination,
and
(
3)
the
date
that
unwanted
material
first
began
accumulating
in
the
container.
This
is
a
performance­
based
requirement.
Specific
labeling
requirements
would
be
listed
in
the
rule
language
(
i.
e.,
prescriptive
requirements).
For
example,
the
rule
would
specifically
require,
among
other
things,
that
containers
have
associated
labels
that
include
a
chemical
description
of
the
unwanted
material,
whether
the
material
is
used
or
unused,
the
manner
in
which
the
chemicals
were
used,
and
a
description
of
the
hazardous
properties
of
the
material.
Same
as
Proposed
Rule.
Attachment
A
(
continued)

Description
of
Information
Collection
Requirements
under
the
Proposed
Rule
and
Alternative
Options
Proposed
Rule
Alternative
Option
1
Alternative
Option
2
Page
A­
2
Training
and
Instruction
(
40
CFR
262.207)

C/
Us
must
train
all
individuals
working
in
a
laboratory
(
e.
g.,

laboratory
workers,
students).
This
training
or
instruction
must
be
commensurate
with
their
duties.
This
is
a
performance­
based
requirement.

C/
Us
that
are
LQGs
must
maintain
training
records
for
laboratory
workers.
These
records
must
be
sufficient
to
determine
whether
laboratory
workers
have
been
trained.
Records
must
be
maintained
for
the
duration
specified
in
section
265.16(
e).
C/
Us
would
be
required
to
train/
instruct
all
individuals
working
in
a
laboratory
commensurate
with
their
duties.
Under
this
option,
specific
training
and
instruction
requirements
would
be
listed
in
the
rule
language
(
i.
e.,
prescriptive
requirements).

Specifically,
C/
Us
must:
(
1)
instruct
students
on
proper
container
management
and
labeling,

collection
procedures
for
unwanted
materials,
and
emergency
procedures
and
(
2)
train
laboratory
workers
in
the
same
subject
matter
as
students,
and
any
additional
subject
matter
necessary
to
perform
their
individuals
duties.

C/
Us
that
are
LQGs
must
maintain
training
records
for
laboratory
workers.
These
records
must
be
sufficient
to
determine
whether
laboratory
workers
have
been
trained.
Records
must
be
maintained
for
the
duration
specified
in
section
265.16(
e).
No
training
and
instruction
requirement.

Removal
of
Containers
of
Unwanted
Material
from
the
Laboratory
(
40
CFR
262.208)

C/
Us
must
remove
all
containers
of
unwanted
material
and
acutely
reactive
unwanted
materials
from
each
laboratory
on
a
regular
interval,
not
to
exceed
six
months.
If
a
laboratory
accumulates
more
than
55
gallons
of
unwanted
material
or
1
quart
of
acutely
reactive
unwanted
material
before
the
regularly
scheduled
removal,
then
all
containers
of
such
material
must
be
labeled
with
the
date
the
55
gallons
or
the
1
quart
is
exceeded.
Same
as
Proposed
Rule.
Same
as
Proposed
Rule.
Attachment
A
(
continued)

Description
of
Information
Collection
Requirements
under
the
Proposed
Rule
and
Alternative
Options
Proposed
Rule
Alternative
Option
1
Alternative
Option
2
Page
A­
3
Making
the
Hazardous
Waste
Determination
in
the
Laboratory
(
40
CFR
262.210
)

A
fully
RCRA­
trained
individual
must
determine
if
the
unwanted
material
is
a
hazardous
waste
per
40
CFR
261.3
by
the
time
the
unwanted
material
is
removed
from
the
laboratory.
If
an
unwanted
material
meets
the
definition
of
hazardous
waste,
the
appropriate
hazardous
waste
code(
s)
must
be
placed
on
the
container
label
that
is
affixed
to
the
container,
before
the
hazardous
waste
may
be
transferred
to
an
on­
site
central
accumulation
area,
an
on­
site
interim
status
or
permitted
TSDF,
or
transported
off
site
to
a
designated
facility.
Same
as
Proposed
Rule.
Same
as
Proposed
Rule.

Making
the
Hazardous
Waste
Determination
at
an
On­
Site
Central
Accumulation
Area
(
40
CFR
262.211)

A
fully
RCRA­
trained
individual
must
determine
if
the
unwanted
material
is
a
hazardous
waste
per
40
CFR
261.3
within
four
calendar
days
of
arriving
at
the
on­
site
central
accumulation
area.

If
the
unwanted
material
meets
the
definition
of
hazardous
waste,

the
appropriate
hazardous
waste
code(
s)
must
be
placed
on
the
container
label
that
is
affixed
to
the
container,
before
the
hazardous
waste
may
be
transferred
to
another
on­
site
central
accumulation
area
or
on­
site
interim
status
or
permitted
TSDF,
or
transported
off
site
to
a
designated
facility.
Same
as
Proposed
Rule.
Same
as
Proposed
Rule.
Attachment
A
(
continued)

Description
of
Information
Collection
Requirements
under
the
Proposed
Rule
and
Alternative
Options
Proposed
Rule
Alternative
Option
1
Alternative
Option
2
Page
A­
4
Making
the
Waste
Determination
at
an
On­
Site
Interim
Status
or
Permitted
TSDF
(
40
CFR
262.212)

A
fully
RCRA­
trained
individual
must
determine
if
the
unwanted
material
is
a
hazardous
waste
per
40
CFR
261.3
within
four
calendar
days
of
arriving
at
an
on­
site
interim
status/
permitted
TSDF.
If
the
unwanted
materials
meet
the
definition
of
hazardous
waste,
the
appropriate
hazardous
waste
code(
s)
must
be
placed
on
the
container
label
that
is
affixed
to
the
container,
before
the
hazardous
waste
may
be
transferred
to
another
interim
status
or
permitted
TSDF
or
transported
off
site
to
a
designated
facility.
Same
as
Proposed
Rule.
Same
as
Proposed
Rule.

Laboratory
Clean­
Outs
(
40
CFR
262.213)

A
C/
U
that
conducts
a
laboratory
clean­
out
in
accordance
to
proposed
section
262.213(
a)
and
(
b)
must
document
the
activities
of
the
laboratory
clean­
out.
In
addition,
the
C/
U
must
maintain
the
laboratory
clean­
out
documentation
as
long
as
it
operates
under
Subpart
K.
Same
as
Proposed
Rule.
Same
as
Proposed
Rule.

Laboratory
Management
Plan
(
40
CFR
262.214)

A
C/
U
that
chooses
to
be
subject
to
Subpart
K
in
lieu
of
section
262.34(
c)
must
develop,
implement,
and
retain
on
site
a
Laboratory
Management
Plan,
or
revise
an
existing
plan,
that
describes
how
the
C/
U
will
comply
with
the
specified
Subpart
K
requirements.
The
C/
U
must
make
its
Laboratory
Management
Plan
available
to
laboratory
workers,
students,
or
others
at
the
C/
U
who
request
it.
The
C/
U
must
review
and
revise
its
Laboratory
Management
Plan
as
needed.
Implementation
of
the
Laboratory
Management
Plan
is
not
an
enforceable
action.
Same
as
Proposed
Rule;
however,
implementation
of
the
Laboratory
Management
Plan
is
not
an
enforceable
action.
No
Laboratory
Management
Plan
requirement.
Page
B­
1
ATTACHMENT
B
GENERATOR
STANDARDS
APPLICABLE
TO
COLLEGE
AND
UNIVERSITY
LABORATORIES
a
ALTERNATIVE
OPTION
1
ESTIMATED
ANNUAL
RESPONDENT
HOUR
AND
COST
BURDEN
Hours
and
Costs
per
Respondent
Legal
Manager
Technical
Clerical
INFORMATION
COLLECTION
ACTIVITY
$
121.71/
Hr
$
60.94/
Hr
$
33.74/
Hr
$
25.23/
Hr
Read
the
regulations
0.25
0.25
0.50
0.00
1.00
$
62.53
$
0.00
$
0.00
97
97.00
$
6,065.41
Subtotal
0.25
0.25
0.50
0.00
1.00
$
62.53
$
0.00
$
0.00
97
97.00
$
6,065.41
Prepare
and
submit
notification
of
intent
to
comply
with
Subpart
K
requirements
to
the
EPA
Regional
Administrator
or
State
Director
0.00
0.64
1.06
0.04
1.74
$
75.78
$
0.00
$
2.68
97
168.78
$
7,610.62
Keep
a
copy
of
the
notification
on
file
at
the
C/
U
0.00
0.00
0.00
0.10
0.10
$
2.52
$
0.00
$
0.00
97
9.70
$
244.44
Subtotal
0.00
0.64
1.06
0.14
1.84
$
78.30
$
0.00
$
2.68
97
178.48
$
7,855.06
Prepare
and
submit
withdrawal
notification
to
the
EPA
Regional
Administrator
or
State
DirectorPrepare
and
submit
one­
time
notification
to
the
EPA
Regional
Administrator
or
State
Director
0.00
0.64
1.06
0.04
1.74
$
75.78
$
0.00
$
2.68
0
0.00
$
0.00
Keep
a
copy
of
the
withdrawal
notification
on
file
at
the
C/
U
0.00
0.00
0.00
0.10
0.10
$
2.52
$
0.00
$
0.00
0
0.00
$
0.00
Subtotal
0.00
0.64
1.06
0.14
1.84
$
78.30
$
0.00
$
2.68
0
0.00
$
0.00
Label
container
0.00
0.00
0.02
0.00
0.02
$
0.67
$
0.00
$
0.066
1,240,540
24,810.79
$
913,037.23
Subtotal
0.00
0.00
0.02
0.00
0.02
$
0.67
$
0.00
$
0.066
1,240,540
24,810.79
$
913,037.23
Train
individuals
working
in
a
laboratory
0.00
0.00
0.00
0.00
0.00
$
0.00
$
0.00
$
0.00
291
0.00
$
0.00
Maintain
training
records
for
laboratory
workers
(
LQGs
only)
0.00
0.00
0.00
0.00
0.00
$
0.00
$
0.00
$
0.00
141
0.00
$
0.00
Subtotal
0.00
0.00
0.00
0.00
0.00
$
0.00
$
0.00
$
0.00
varies
0.00
$
0.00
Label
container
with
the
date
the
55
gallons
or
the
1
quart
of
unwanted
material
is
exceeded
0.00
0.00
0.02
0.00
0.02
$
0.67
$
0.00
$
0.00
0
0.00
$
0.00
Subtotal
0.00
0.00
0.02
0.00
0.02
$
0.67
$
0.00
$
0.00
0
0.00
$
0.00
Make
hazardous
waste
determination
0.00
0.00
0.00
0.00
0.00
$
0.00
$
0.00
$
0.00
6,552
0.00
$
0.00
Add
the
appropriate
EPA
hazardous
waste
code(
s)
to
the
container
label
0.00
0.00
0.02
0.00
0.02
$
0.67
$
0.00
$
0.00
6,552
131.04
$
4,389.84
Subtotal
0.00
0.00
0.02
0.00
0.02
$
0.67
$
0.00
$
0.00
6,552
131.04
$
4,389.84
Make
hazardous
waste
determination
0.00
0.00
0.00
0.00
0.00
$
0.00
$
0.00
$
0.00
1,233,988
0.00
$
0.00
Add
the
appropriate
EPA
hazardous
waste
code(
s)
to
the
container
label
0.00
0.00
0.02
0.00
0.02
$
0.67
$
0.00
$
0.00
1,233,988
24,679.75
$
826,771.77
Subtotal
0.00
0.00
0.02
0.00
0.02
$
0.67
$
0.00
$
0.00
1,233,988
24,679.75
$
826,771.77
Make
hazardous
waste
determination
0.00
0.00
0.00
0.00
0.00
$
0.00
$
0.00
$
0.00
0
0.00
$
0.00
Add
the
appropriate
EPA
hazardous
waste
code(
s)
to
the
container
label
0.00
0.00
0.02
0.00
0.02
$
0.67
$
0.00
$
0.00
0
0.00
$
0.00
Subtotal
0.00
0.00
0.02
0.00
0.02
$
0.67
$
0.00
$
0.00
0
0.00
$
0.00
Document
activities
of
the
laboratory
clean­
out
0.00
0.00
0.01
0.00
0.01
$
0.34
$
0.00
$
0.00
101,607
1,016.07
$
34,546.38
Maintain
documentation
on
laboratory
clean­
out
0.00
0.00
0.00
0.01
0.01
$
0.25
$
0.00
$
0.00
101,607
1,016.07
$
25,401.75
Subtotal
0.00
0.00
0.01
0.01
0.02
$
0.59
$
0.00
$
0.00
101,607
2,032.14
$
59,948.13
Develop
Laboratory
Management
Plan,
or
revise
an
existing
plan
0.00
8.00
40.00
0.00
48.00
$
1,837.12
$
0.00
$
0.00
97
4,656.00
$
178,200.64
Review
and
revise
the
Laboratory
Management
Plan
0.00
0.00
4.00
0.00
4.00
$
134.96
$
0.00
$
0.00
194
776.00
$
26,182.24
Retain
Laboratory
Management
Plan
on
site
0.00
0.00
0.00
0.10
0.10
$
2.52
$
0.00
$
0.00
291
29.10
$
733.32
Subtotal
0.00
varies
varies
varies
varies
varies
$
0.00
$
0.00
varies
5,461.10
$
205,116.20
TOTAL
varies
varies
varies
varies
varies
varies
$
0.00
varies
varies
57,390.30
$
2,023,183.64
MAKING
THE
HAZARDOUS
WASTE
DETERMINATION
IN
THE
LABORATORY
(
40
CFR
262.210)

MAKING
THE
HAZARDOUS
WASTE
DETERMINATION
AT
AN
ON­
SITE
CENTRAL
ACCUMULATION
AREA
(
40
CFR
262.211)

MAKING
THE
WASTE
DETERMINATION
AT
AN
ON­
SITE
INTERIM
STATUS
OR
PERMITTED
TSDF
(
40
CFR
262.212)

LABORATORY
CLEAN­
OUTS
(
40
CFR
262.213)

LABELING
OF
CONTAINERS
OF
UNWANTED
MATERIALS
IN
THE
LABORATORY
(
40
CFR
262.206)

TRAINING
AND
INSTRUCTION
(
40
CFR
262.207)

REMOVAL
OF
CONTAINERS
OF
UNWANTED
MATERIAL
FROM
THE
LABORATORY
(
40
CFR
262.208)

READING
THE
REGULATIONS
Total
Hours
and
Costs
NOTIFICATION
OF
INTENT
TO
NO
LONGER
COMPLY
WITH
THE
SUBPART
K
REQUIREMENTS
(
40
CFR
262.204)
Number
of
Respondents/
Ac
tivities
Total
Hours/

Year
Total
Cost/

Year
Respon.

Hours/

Year
Labor
Cost/

Year
NOTIFICATION
OF
INTENT
TO
COMPLY
WITH
THE
SUBPART
K
REQUIREMENTS
(
40
CFR
262.203)
Capital/

Startup
Cost
O&
M
Cost
LABORATORY
MANAGEMENT
PLAN
(
40
CFR
262.214)
Attachment
B
Annual
Incremental
Hour
and
Cost
Burden
to
Respondents
under
Alternative
Option
1
a
Page
C­
1
ATTACHMENT
C
GENERATOR
STANDARDS
APPLICABLE
TO
COLLEGE
AND
UNIVERSITY
LABORATORIES
a
ALTERNATIVE
OPTION
2
ESTIMATED
ANNUAL
RESPONDENT
HOUR
AND
COST
BURDEN
Hours
and
Costs
per
Respondent
Legal
Manager
Technical
Clerical
INFORMATION
COLLECTION
ACTIVITY
$
121.71/
Hr
$
60.94/
Hr
$
33.74/
Hr
$
25.23/
Hr
Read
the
regulations
0.25
0.25
0.50
0.00
1.00
$
62.53
$
0.00
$
0.00
227
227.00
$
14,194.31
Subtotal
0.25
0.25
0.50
0.00
1.00
$
62.53
$
0.00
$
0.00
227
227.00
$
14,194.31
Label
container
0.00
0.00
0.02
0.00
0.02
$
0.67
$
0.00
$
0.066
1,567,579
31,351.58
$
1,153,738.06
Subtotal
0.00
0.00
0.02
0.00
0.02
$
0.67
$
0.00
$
0.066
1,567,579
31,351.58
$
1,153,738.06
Label
container
with
the
date
the
55
gallons
or
the
1
quart
of
unwanted
material
is
exceeded
0.00
0.00
0.02
0.00
0.02
$
0.67
$
0.00
$
0.00
0
0.00
$
0.00
Subtotal
0.00
0.00
0.02
0.00
0.02
$
0.67
$
0.00
$
0.00
0
0.00
$
0.00
Make
hazardous
waste
determination
0.00
0.00
0.00
0.00
0.00
$
0.00
$
0.00
$
0.00
73,398
0.00
$
0.00
Add
the
appropriate
EPA
hazardous
waste
code(
s)
to
the
container
label
0.00
0.00
0.02
0.00
0.02
$
0.67
$
0.00
$
0.00
73,398
1,467.95
$
49,176.34
Subtotal
0.00
0.00
0.02
0.00
0.02
$
0.67
$
0.00
$
0.00
73,398
1,467.95
$
49,176.34
Make
hazardous
waste
determination
0.00
0.00
0.00
0.00
0.00
$
0.00
$
0.00
$
0.00
1,494,181
0.00
$
0.00
Add
the
appropriate
EPA
hazardous
waste
code(
s)
to
the
container
label
0.00
0.00
0.02
0.00
0.02
$
0.67
$
0.00
$
0.00
1,494,181
29,883.63
$
1,001,101.51
Subtotal
0.00
0.00
0.02
0.00
0.02
$
0.67
$
0.00
$
0.00
1,494,181
29,883.63
$
1,001,101.51
Make
hazardous
waste
determination
0.00
0.00
0.00
0.00
0.00
$
0.00
$
0.00
$
0.00
0
0.00
$
0.00
Add
the
appropriate
EPA
hazardous
waste
code(
s)
to
the
container
label
0.00
0.00
0.02
0.00
0.02
$
0.67
$
0.00
$
0.00
0
0.00
$
0.00
Subtotal
0.00
0.00
0.02
0.00
0.02
$
0.67
$
0.00
$
0.00
0
0.00
$
0.00
Document
activities
of
the
laboratory
clean­
out
0.00
0.00
0.01
0.00
0.01
$
0.34
$
0.00
$
0.00
180,522
1,805.22
$
61,377.48
Maintain
documentation
on
laboratory
clean­
out
0.00
0.00
0.00
0.01
0.01
$
0.25
$
0.00
$
0.00
180,522
1,805.22
$
45,130.50
Subtotal
0.00
0.00
0.01
0.01
0.02
$
0.59
$
0.00
$
0.00
180,522
3,610.44
$
106,507.98
TOTAL
varies
varies
varies
varies
varies
varies
$
0.00
varies
varies
66,540.60
$
2,324,718.20
MAKING
THE
HAZARDOUS
WASTE
DETERMINATION
IN
THE
LABORATORY
(
40
CFR
262.210)

MAKING
THE
HAZARDOUS
WASTE
DETERMINATION
AT
AN
ON­
SITE
CENTRAL
ACCUMULATION
AREA
(
40
CFR
262.211)

MAKING
THE
WASTE
DETERMINATION
AT
AN
ON­
SITE
INTERIM
STATUS
OR
PERMITTED
TSDF
(
40
CFR
262.212)

LABORATORY
CLEAN­
OUTS
(
40
CFR
262.213)
Total
Hours
and
Costs
Number
of
Respondents/
Ac
tivities
Total
Hours/

Year
Total
Cost/

Year
O&
M
Cost
LABELING
OF
CONTAINERS
OF
UNWANTED
MATERIALS
IN
THE
LABORATORY
(
40
CFR
262.206)

REMOVAL
OF
CONTAINERS
OF
UNWANTED
MATERIAL
FROM
THE
LABORATORY
(
40
CFR
262.208)

READING
THE
REGULATIONS
Respon.

Hours/

Year
Labor
Cost/

Year
Capital/

Startup
Cost
Attachment
C
Annual
Incremental
Hour
and
Cost
Burden
to
Respondents
under
Alternative
Option
2
a
Page
C­
2
