SUPPORTING
STATEMENT
FOR
INFORMATION
COLLECTION
REQUEST
NUMBER
1189.11
"
ZINC
FERTILIZERS
MADE
FROM
RECYCLED
HAZARDOUS
SECONDARY
MATERIALS
­
FINAL
RULE
"

April
12,
2002
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)
SHORT
CHARACTERIZATION
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1
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
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3
2(
a)
NEED
AND
AUTHORITY
FOR
THE
COLLECTION
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3
2(
b)
PRACTICAL
UTILITY
AND
USERS
OF
THE
DATA
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5
3.
NON­
DUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
7
3(
a)
NON­
DUPLICATION
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7
3(
b)
PUBLIC
NOTICE
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7
3(
c)
CONSULTATIONS
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7
3(
d)
EFFECTS
OF
LESS
FREQUENT
COLLECTION
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7
3(
e)
GENERAL
GUIDELINES
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7
3(
f)
CONFIDENTIALITY
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7
3(
g)
SENSITIVE
QUESTIONS
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8
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
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8
4(
a)
RESPONDENTS
AND
SIC
CODES
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8
4(
b)
INFORMATION
REQUESTED
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8
5.
THE
INFORMATION
COLLECTED
­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
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13
5(
a)
AGENCY
ACTIVITIES
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13
5(
b)
COLLECTION
METHODOLOGY
AND
MANAGEMENT
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13
5(
c)
SMALL
ENTITY
FLEXIBILITY
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13
5(
d)
COLLECTION
SCHEDULE
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13
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
COLLECTION
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14
6(
a)
ESTIMATING
RESPONDENT
BURDEN
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14
6(
b)
ESTIMATING
RESPONDENT
COSTS
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14
6(
c)
ESTIMATING
AGENCY
BURDEN
AND
COST
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15
6(
d)
ESTIMATING
THE
RESPONDENT
UNIVERSE
AND
TOTAL
BURDEN
AND
COSTS
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15
6(
e)
BOTTOM
LINE
BURDEN
HOURS
AND
COSTS
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19
6(
f)
REASONS
FOR
CHANGE
IN
BURDEN
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19
6(
g)
BURDEN
STATEMENT
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19
EXHIBITS
ESTIMATED
ANNUAL
RESPONDENT
BURDEN
AND
COST
(
EXHIBIT
1)
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21
TOTAL
ANNUAL
RESPONDENT
BURDEN
AND
COST
SUMMARY
(
EXHIBIT
2)
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22
ESTIMATED
ANNUAL
AGENCY
BURDEN
AND
COST
(
EXHIBIT
3)
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23
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
and
Number
of
the
Information
Collection
This
Information
Collection
Request
(
ICR)
is
entitled
"
Zinc
Fertilizers
Made
from
Recycled
Hazardous
Secondary
Materials
­
Final
Rule,"
ICR
Number
1189.11.

1(
b)
Short
Characterization
Under
Section
3001
of
the
Resource
Conservation
and
Recovery
Act
(
RCRA),
as
amended,
EPA
is
authorized
to
develop
and
promulgate
regulations
identifying
the
characteristics
of
hazardous
waste
and
listing
particular
hazardous
wastes
which
should
be
subject
to
EPA's
hazardous
waste
regulatory
system.
Under
this
authority,
EPA
promulgated
regulations
at
40
CFR
Part
261
that
identify
hazardous
characteristics
(
Subpart
C)
and
list
hazardous
wastes
(
Subpart
D).
Part
261
also
includes,
among
other
things,
procedures
for
making
a
hazardous
waste
determination
and
exclusions
from
the
definition
of
solid
and
hazardous
waste.

EPA
has
now
revised
the
regulations
at
Part
261
that
apply
to
recycling
of
hazardous
secondary
materials
to
make
zinc
fertilizer
products.
The
rule
establishes
a
more
consistent
regulatory
framework
for
these
recycling
practices,
and
establishes
conditions
for
excluding
such
hazardous
secondary
materials
from
the
definition
of
solid
waste
under
RCRA.
Under
the
rule,
zinc
fertilizer
manufacturers
and
their
suppliers
will
be
able
to
manage
hazardous
secondary
materials
outside
the
current
RCRA
"
cradle
to
grave"
hazardous
waste
management
system,
provided
they
meet
certain
conditions
involving
storage
of
the
material,
and
reporting
and
recordkeeping.
In
this
sense
the
rule
is
deregulatory
in
nature,
and
will
relieve
industry
from
a
number
of
information
collection
requirements
that
apply
under
current
hazardous
waste
regulations.
The
rule
also
establishes
new
limits
on
contaminants
in
zinc
fertilizers
made
from
hazardous
secondary
materials,
and
specifies
conditions
for
notification,
reporting
and
recordkeeping,
and
testing
of
fertilizer
products.

With
regard
specifically
to
paperwork
requirements,
the
rule
requires
generators
of
zincbearing
hazardous
waste
secondary
materials
and
manufacturers
of
zinc
fertilizer
or
zinc
fertilizer
ingredients
participating
in
the
conditional
exclusion
to
submit
one­
time
notices
to
EPA
(
or
the
authorized
State)
as
specified,
and
keep
on­
site
records
of
shipments
of
excluded
secondary
materials.
Manufacturers
also
must
conduct
annual
reporting,
periodic
product
sampling/
analysis,
and
recordkeeping
of
analytical
data.

In
Sections
1
through
5
of
this
ICR,
EPA
presents
a
comprehensive
description
of
the
new
information
collection
requirements
in
the
rule.
In
Section
6,
EPA
estimates
the
total
annual
burden
and
cost
to
respondents
and
government
associated
with
these
new
paperwork
requirements
under
the
rule.
In
addition,
EPA
estimates
in
Section
6(
d)
the
burden
and
cost
savings
to
respondents
for
no
longer
needing
to
manage
zinc­
bearing
secondary
materials
as
hazardous
waste
under
the
existing
RCRA
paperwork
requirements.
In
Section
6(
e),
EPA
1
presents
the
combined
burden
and
costs
under
the
new
and
previous
requirements.

In
the
following
paragraphs,
EPA
briefly
describes
the
new
information
collection
requirements
that
are
contained
in
the
rule.

Notification
for
Generators
and
Intermediate
Handlers
New
40
CFR
261.4(
a)(
20)(
ii)(
A)
requires
generators
and
intermediate
handlers
of
zincbearing
hazardous
waste
secondary
materials
that
are
to
be
incorporated
into
zinc
fertilizers
to
submit
a
one­
time
notification
to
the
Regional
Administrator
or
State
Director.
The
notification
includes
the
name,
address
and
EPA
ID
number
of
the
generator
facility,
and
specifies
when
the
facility
intends
to
begin
managing
secondary
materials
under
the
conditions
of
the
exclusion.

Record
of
Shipments
for
Generators
and
Intermediate
Handlers
New
40
CFR
261.4(
a)(
20)(
ii)(
D)
requires
secondary
material
generators
and
intermediate
handlers
to
keep
records
of
shipments
of
excluded
hazardous
secondary
materials.
The
shipping
records
at
a
minimum
will
provide
the
name
of
the
transporter
and
date
of
the
shipment;
the
name
and
address
of
the
fertilizer
manufacturer
who
received
the
excluded
material;
and
the
type
and
quantity
of
excluded
secondary
material
in
each
shipment.
Generators
will
need
to
keep
shipping
records
for
at
least
three
years.

Notification
for
Manufacturers
New
40
CFR
261.4(
a)(
20)(
iii)(
B)
requires
manufacturers
of
zinc
fertilizers
or
zinc
fertilizer
ingredients
made
from
excluded
hazardous
secondary
materials
to
submit
a
one­
time
notification
to
the
Regional
Administrator
or
State
Director.
The
notification
will
need
to
include
the
name
of
the
manufacturer,
address
and
EPA
ID
number
of
the
manufacturing
facility;
and
must
specify
when
the
facility
intends
to
begin
managing
secondary
materials
under
the
conditions
of
the
exclusion.

Records
of
Shipments
for
Manufacturers
Under
40
CFR
261.4(
a)(
20)(
iii)(
C),
manufacturers
of
zinc
fertilizers
or
zinc
fertilizer
ingredients
made
from
excluded
hazardous
secondary
materials
will
need
to
maintain
for
a
minimum
of
three
years
records
of
all
shipments
of
excluded
secondary
materials
received
by
the
manufacturers.
The
records
will
include
the
name
and
address
of
the
generating
facility;
the
name
of
the
transporter
and
date
the
materials
were
received;
the
quantity
received;
and
a
brief
description
of
the
industrial
process
that
generated
the
waste.
2
Annual
Report
for
Manufacturers
Under
40
CFR
261.4(
a)(
21)(
iii)(
D),
manufacturers
of
zinc
fertilizers
or
zinc
fertilizer
ingredients
made
from
excluded
hazardous
secondary
materials
will
need
to
submit
to
the
Director
an
annual
report
that
identifies
the
total
quantities
of
all
excluded
hazardous
secondary
materials
that
were
used
to
manufacture
zinc
fertilizer
or
zinc
fertilizer
ingredients
in
the
previous
year;
the
name
and
address
of
each
generating
facility;
and
the
industrial
process(
es)
from
which
the
materials
were
generated.

Product
Sampling
and
Analysis
for
Manufacturers
Under
40
CFR
261.4(
a)(
21)(
ii),
the
manufacturer
will
need
to
perform
sampling
and
analysis
of
the
fertilizer
product
to
determine
compliance
with
the
contaminant
limits
for
metals
no
less
than
every
six
months,
and
for
dioxins
no
less
than
every
twelve
months.
Testing
must
also
be
performed
whenever
changes
occur
to
manufacturing
processes
or
ingredients
that
could
significantly
affect
the
amounts
of
contaminants
in
the
fertilizer
product.
The
manufacturer
may
use
any
reliable
analytical
method
to
demonstrate
that
no
constituent
of
concern
is
present
in
the
product
at
concentrations
above
the
applicable
limits.
It
is
the
responsibility
of
the
manufacturer
to
ensure
that
the
sampling
and
analysis
are
unbiased,
precise,
and
representative
of
the
product(
s)
that
is
introduced
into
commerce.

Under
40
CFR
216.4(
a)(
21)(
iii),
the
manufacturer
will
also
need
to
maintain
records
of
these
activities
for
no
less
than
three
years.
The
records
will
include
the
dates
and
times
product
samples
were
taken,
and
the
dates
the
samples
were
analyzed;
the
names
and
qualifications
of
the
person(
s)
taking
the
samples;
a
description
of
the
methods
and
equipment
used
to
take
the
samples;
the
name
and
address
of
the
laboratory
facility
at
which
analyses
of
the
samples
were
performed;
a
description
of
the
analytical
methods
used,
including
any
cleanup
and
sample
preparation
methods;
and
all
laboratory
analytical
results
used
to
determine
compliance
with
the
contaminant
limits
specified
in
this
paragraph.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need
and
Authority
for
the
Collection
EPA
is
authorized
to
require
information
collection
pursuant
to
RCRA
Section
2002,
which
authorizes
EPA
to
prescribe
regulations,
including
information
collection
requirements,
as
are
necessary
to
carry
out
the
hazardous
waste
program.
Under
this
authority,
EPA
has
finalized
new
conditions
for
reporting
and
recordkeeping
by
generators
and
manufacturers,
which
are
designed
primarily
to
improve
and
streamline
government
oversight
over
the
handlers
of
excluded
materials
(
e.
g.,
generators
and
manufacturers).
These
conditions
replace
the
previous
hazardous
waste
regulatory
requirements
for
reporting
and
recordkeeping.
The
need
for
these
reporting
and
recordkeeping
requirements
is
further
described
in
the
following
paragraphs.
3
Notification
for
Generators
and
Intermediate
Handlers
The
rule
requires
generators
and
intermediate
handlers
of
excluded
hazardous
secondary
materials
to
submit
a
one­
time
notice
to
the
EPA
Regional
Administrator
(
or
the
state
Director
in
an
authorized
state)
identifying
the
name,
location
and
EPA
ID
number
of
the
generating
facility,
and
when
the
facility
intends
to
begin
managing
hazardous
secondary
materials
according
to
the
terms
of
the
conditional
exclusion.
Regulatory
agencies
need
this
minimum
amount
of
information
to
readily
identify
for
tracking
and
enforcement
purposes
the
generators
who
supply
excluded
secondary
materials
to
zinc
fertilizer
producers.

Record
of
Shipments
for
Generators
and
Intermediate
Handlers
The
rule
requires
generators
and
intermediate
handlers
to
maintain
records
of
all
shipments
of
excluded
hazardous
secondary
materials
for
a
minimum
of
three
years.
These
records
will
be
needed
to
identify
for
each
shipment
the
name
of
the
transporter,
date
of
the
shipment,
name
and
location
of
the
fertilizer
manufacturer
who
received
the
shipment,
the
quantity
shipped
and
a
brief
description
of
the
excluded
material
in
the
shipment.
These
requirements
are
somewhat
analogous
to
the
current
requirements
for
shipping
hazardous
wastes
under
manifests
and
maintenance
of
manifest
records.
Copies
of
manifests
are
typically
kept
at
the
generator's
facility,
though
some
states
require
copies
of
manifests
to
be
submitted
to
the
state
agency.

Notification
for
Manufacturers
As
a
condition
of
the
exclusion,
manufacturers
will
need
to
submit
a
one­
time
notice
to
the
state
Director
or
Regional
Administrator
that
identifies
the
name
and
location
of
the
manufacturing
facility,
and
when
the
manufacturer
intendes
to
begin
managing
hazardous
secondary
materials
under
the
terms
of
the
exclusion
in
this
rule.
The
intent
of
this
one­
time
notice
is
to
provide
regulators
with
knowledge
of
which
manufacturers
intend
to
make
use
of
the
conditional
exclusion,
and
when.

Record
of
Shipments
for
Manufacturers
The
rule
requires
manufacturers
to
retain
for
a
minimum
of
three
years
records
of
all
shipments
of
excluded
hazardous
secondary
materials
that
were
received
by
the
zinc
fertilizer
manufacturer
during
that
period.
This
recordkeeping
condition
is
intended
to
enhance
the
capability
of
regulatory
agencies
to
(
when
necessary)
track
and
account
for
shipments
of
excluded
secondary
materials.

Annual
Report
for
Manufacturers
The
rule
requires
each
zinc
fertilizer
manufacturer
who
uses
excluded
hazardous
secondary
materials
to
submit
to
the
appropriate
regulatory
agency
an
annual
report
that
identifies
the
types,
quantities
and
origins
of
all
such
excluded
materials
that
were
received
by
the
4
manufacturer
in
the
preceding
year.
This
new
requirement
is
intended
to
ensure
an
adequate
tracking
and
accountability
system
for
these
excluded
materials.

Product
Sampling
and
Analysis
for
Manufacturers
The
rule
requires
manufacturers
of
conditionally
excluded
zinc
fertilizer
products
to
sample
and
analyze
their
products
at
least
once
every
six
months
for
the
purpose
of
demonstrating
compliance
with
the
product
specifications
for
metals,
and
at
least
once
per
year
for
dioxins.
Testing
must
also
be
performed
whenever
changes
occur
to
manufacturing
processes
or
ingredients
that
could
significantly
affect
the
amounts
of
contaminants
in
the
fertilizer
product.
As
a
practical
matter,
EPA
believes
that
fertilizer
manufacturers
typically
sample
and
analyze
their
products
for
contaminants
on
more
or
less
an
ongoing
basis,
as
a
means
of
monitoring
quality
control.
EPA
believes
that
the
testing
requirements
are
reasonable,
and
will
likely
impose
only
minor
additional
testing
burdens
on
manufacturers.

2(
b)
Practical
Utility
and
Users
of
the
Data
In
the
following
paragraphs,
EPA
discusses
how
the
data
required
under
the
rule
will
be
used
and
identifies
the
primary
users.

Notification
for
Generators
and
Intermediate
Handlers
This
reporting
requirement
is
analogous
to
the
current
requirement
for
generators
of
excluded
secondary
materials,
which
requires
the
generator
to
place
a
similar
one­
time
notice
in
the
generator
facility's
on­
site
files.
However,
the
requirement
enhances
regulatory
agencies'
tracking
and
oversight
capabilities,
since
the
information
would
be
submitted
directly
to
the
overseeing
agency,
rather
than
being
maintained
in
the
facility's
files.

Record
of
Shipments
for
Generators
and
Intemediate
Handlers
The
recordkeeping
conditions
should
enable
regulatory
agencies
to
more
accurately
track
shipments
of
excluded
materials
for
compliance
and
enforcement
purposes
(
e.
g.,
if
requested
by
on­
site
EPA
inspectors).
It
is
consistent
with
normal
business
recordkeeping
practices,
and
is
not
expected
to
impose
significant
additional
paperwork
burdens
on
generators.

Notification
for
Manufacturers
This
notice
replaces
and
streamlines
the
current
notification
requirements
for
hazardous
waste
recyclers
who
make
products
used
in
a
manner
constituting
disposal,
as
specified
in
existing
40
CFR
268.7(
b)(
6).
Under
those
requirements,
manufacturers
of
hazardous
waste
derived
fertilizers
must
submit
to
the
overseeing
agency
an
LDR
certification
statement,
and
certain
other
information
relating
to
compliance
with
LDR
treatment
standards,
for
each
shipment
of
fertilizer
products.
While
it
may
be
reasonable
and
desirable
for
regulatory
agencies
to
be
informed
as
to
5
which
companies
are
making
zinc
fertilizer
from
excluded
secondary
materials
and
what
materials
they
intend
to
use,
the
Agency
does
not
believe
that
it
is
necessary
to
require
reporting
on
every
shipment
of
fertilizer
products,
especially
in
light
of
the
proposed
annual
reporting
requirement
for
manufacturers.

Record
of
Shipments
for
Manufacturers
These
recordkeeping
conditions
will
enable
regulatory
agencies
(
e.
g.,
on­
site
EPA
inspectors)
to
more
accurately
track
shipments
of
excluded
materials
for
compliance
and
enforcement
purposes.
It
is
consistent
with
normal
business
recordkeeping
practices,
and
is
not
expected
to
impose
significant
additional
paperwork
burdens
on
manufacturers.

Annual
Report
for
Manufacturers
The
annual
report
will
be
used
to
enhance
the
ability
of
regulatory
agencies
to
assess
compliance
with
regulatory
requirements
by
manufacturers
and
to
understand
the
management
and
recycling
practices
being
undertaken.

Product
Sampling
and
Analysis
for
Manufacturers
Under
the
rule,
manufacturers
will
need
to
sample
and
analyse
fertilizers
to
determine
compliance
with
the
contaminant
limits
in
the
rule.
This
will
provide
overseeing
agencies
with
data
to
establish
the
manufacturers'
compliance
with
this
condition
of
the
exclusion.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
None
of
the
new
information
required
by
the
rule
is
duplicative
with
any
information
required
by
the
existing
RCRA
regulations.

3(
b)
Public
Notice
EPA
published
the
proposed
rule
in
the
Federal
Register
and
solicited
public
comments.
To
assist
the
public
in
commenting
on
the
proposal,
EPA
raised
a
number
of
issues
in
the
preamble
about
the
proposed
rule
and
asked
for
the
public
to
comment
on
them.
EPA
also
held
a
public
hearing
on
the
rule,
on
November
29,
2001.
EPA
has
reviewed
all
of
the
comments
received,
and
has
responded
to
those
comments
in
the
preamble
to
the
final
rule,
and
in
the
response
to
comments
document
prepared
in
support
of
this
final
action.
6
3(
c)
Consultations
EPA
held
stakeholder
meetings
on
hazardous
waste
derived
fertilizers
on
November
12­
13,
1998,
and
met
with
a
number
of
other
stakeholders,
including
regulated
companies,
public
interest
groups,
state
regulatory
officials,
and
others.
The
views
of
the
various
stakeholders
were
considered
and
incorporated
as
appropriate
in
the
final
rulemaking.

3(
d)
Effects
of
Less
Frequent
Collection
EPA
has
carefully
considered
the
burden
imposed
upon
the
regulated
community
by
this
rule.
EPA
is
confident
that
those
activities
required
of
respondents
are
necessary,
and
to
the
extent
possible,
the
Agency
has
attempted
to
minimize
the
burden
imposed.
EPA
believes
strongly
that,
if
the
minimum
information
collection
requirements
of
the
rule
are
not
met,
neither
the
industry
nor
regulatory
agencies
will
be
able
to
ensure
that
this
recycling
practice
is
being
conducted
according
to
the
requirements
and
conditions
of
the
regulation.

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

3(
f)
Confidentiality
Section
3007(
b)
of
RCRA
and
40
CFR
Part
2,
Subpart
B,
which
defines
EPA's
general
policy
on
public
disclosure
of
information,
contain
provisions
for
confidentiality.
However,
the
Agency
does
not
anticipate
that
businesses
will
assert
claims
of
confidentiality
with
regard
to
complying
with
this
rule.
If
such
a
claim
is
asserted,
EPA
must
and
will
treat
the
information
in
accordance
with
the
regulations
cited
above.
EPA
also
will
assure
that
this
information
collection
complies
with
the
Privacy
Act
of
1974
and
OMB
Circular
108.

3(
g)
Sensitive
Questions
No
questions
of
a
sensitive
nature
are
included
in
the
information
collection
requirements.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents/
SIC
Codes
Entities
affected
by
this
proposed
rulemaking
will
be
generators
of
zinc­
bearing
hazardous
waste
secondary
materials,
and
manufacturers
of
zinc
fertilizers
or
zinc
fertilizer
ingredients
made
from
excluded
hazardous
secondary
materials.
The
following
is
a
list
of
North
American
Industrial
Classification
System
(
SIC)
codes
associated
with
the
generators
and
manufacturers
7
that
may
be
affected
by
the
information
collection
requirements
covered
under
this
ICR.

NAICS
Code
Industrial
Sector
32532
Fertilizer
manufacturing
32531
Zinc
sulfide
manufacturing
331111
Iron
and
steel
mills
331419
Zinc
refining,
primary
331492
Zinc
dust
reclaiming
562112
Hazardous
waste
collection
4(
b)
Information
Requested
In
the
following
paragraphs,
EPA
describes
the
new
information
collection
requirements
under
the
rule.

(
1)
Notification
for
Generators
and
Intermediate
Handlers
40
CFR
261.4(
a)(
20)(
ii)(
A)
requires
generators
and
intermediate
handlers
of
zinc­
bearing
hazardous
waste
secondary
materials
that
are
to
be
incorporated
into
zinc
fertilizers
to
submit
a
one­
time
notification
to
the
Regional
Administrator
or
State
Director.

(
i)
Data
Items
The
one­
time
notification
must
include
the
following
information:

°
Name,
address
and
EPA
ID
number
of
the
generator
facility;

°
When
the
facility
intendes
to
begin
managing
hazardous
secondary
materials
in
accordance
with
the
conditions
in
the
rule.

(
ii)
Respondent
Activity
°
Complete
and
submit
the
one­
time
notification.

(
2)
Record
of
Shipments
for
Generators
and
Intermediate
Handlers
40
CFR
261.4(
a)(
20)(
ii)(
C)
requires
secondary
materials
generators
and
intermediate
handlers
to
keep
records
of
shipments
of
excluded
hazardous
secondary
materials
for
no
less
than
three
years.

(
i)
Data
Items
8
The
shipping
records
must
at
a
minimum
contain
the
following
information:

°
Name
of
the
transporter
and
date
of
the
shipment;

°
Name
and
address
of
the
fertilizer
manufacturer
who
received
the
excluded
material;
and
°
Type
and
quantity
of
excluded
secondary
material
in
each
shipment.

(
ii)
Respondent
Activity
°
Keep
the
following
records
of
shipping
activities:

S
Name
of
the
transporter
and
date
of
the
shipment;

S
Name
and
address
of
the
fertilizer
manufacturer
who
received
the
excluded
material;
and
S
Type
and
quantity
of
excluded
secondary
material
in
each
shipment.

(
3)
Notification
for
Manufacturers
40
CFR
261.4(
a)(
20)(
iii)(
B)
requires
manufacturers
of
zinc
fertilizers
or
zinc
fertilizer
ingredients
made
from
excluded
hazardous
secondary
materials
to
submit
a
one­
time
notification
to
the
Regional
Administrator.

(
i)
Data
Items
The
one­
time
notification
must
include
the
following
information:

°
Name
of
the
manufacturer,
address
and
EPA
ID
number
of
the
manufacturing
facility;
and
°
When
the
facility
intendes
to
begin
managing
hazardous
secondary
materials
in
accordance
with
the
conditions
in
the
rule.

(
ii)
Respondent
Activity
°
Complete
and
submit
the
one­
time
notification.

(
4)
Record
of
Shipments
for
Manufacturers
Under
proposed
40
CFR
261.4(
a)(
20)(
iii)(
C),
manufacturers
of
zinc
fertilizers
or
zinc
9
fertilizer
ingredients
made
from
excluded
hazardous
secondary
materials
must
maintain
for
a
minimum
of
three
years
records
of
all
shipments
of
excluded
secondary
materials
received
by
the
manufacturers.

(
i)
Data
Items
The
shipping
records
would
at
a
minimum
contain
the
following
information:

°
Name
and
address
of
the
generating
facility;

°
Name
of
transporter
and
date
the
materials
were
received;

°
Quantity
received;
and
°
Brief
description
of
the
industrial
process
that
generated
the
waste.

(
ii)
Respondent
Activity
°
Keep
the
following
records:

S
Name
and
address
of
the
generating
facility;

S
Name
of
transporter
and
date
the
materials
were
received;

S
Record
of
the
quantity
received;
and
S
Brief
description
of
the
industrial
process
that
generated
the
waste.

(
5)
Annual
Report
for
Manufacturers
Under
40
CFR
261.4(
a)(
20)(
iii)(
D),
manufacturers
of
zinc
fertilizers
or
zinc
fertilizer
ingredients
made
from
excluded
hazardous
secondary
materials
must
submit
to
the
Director
an
annual
report
that
identifies
the
total
quantities
of
all
excluded
hazardous
secondary
materials
that
were
used
to
manufacture
zinc
fertilizer
or
zinc
fertilizer
ingredients
in
the
previous
year.

(
i)
Data
Items
The
annual
report
must
include
the
following:

°
Record
of
the
total
quantities
of
all
excluded
hazardous
secondary
materials
that
were
used
to
manufacture
zinc
fertilizer
or
zinc
fertilizer
ingredients
in
the
previous
year;
10
°
Name
and
address
of
each
generating
facility;
and
°
The
industrial
process(
es)
from
which
the
materials
were
generated.

(
ii)
Respondent
Activity
°
Complete
and
submit
the
annual
report.

(
6)
Product
Sampling
and
Analysis
for
Manufacturers
Under
40
CFR
261.4(
a)(
21)(
ii),
the
manufacturer
must
perform
sampling
and
analysis
of
the
fertilizer
product
to
determine
compliance
with
the
contaminant
limits
for
metals
no
less
than
every
six
months,
and
for
dioxins
no
less
than
every
twelve
months.
The
manufacturer
may
use
any
reliable
analytical
method
to
demonstrate
that
no
constituent
of
concern
is
present
in
the
product
at
concentrations
above
the
applicable
limits.
It
is
the
responsibility
of
the
manufacturer
to
ensure
that
the
sampling
and
analysis
are
unbiased,
precise,
and
representative
of
the
product(
s)
that
is
introduced
into
commerce.
The
recordkeeping
requirements
for
product
sampling
and
analysis
are
listed
in
40
CFR
261.4(
a)(
21)(
iii),
and
require
the
manufacturer
to
maintain
specified
sampling/
analysis
records
for
no
less
than
three
years.

(
i)
Data
Items
The
records
of
sampling/
analysis
must
include
the
following:

°
The
dates
and
times
product
samples
were
taken,
and
the
dates
the
samples
were
analyzed;

°
The
names
and
qualifications
of
the
person(
s)
taking
the
samples;

°
A
description
of
the
methods
and
equipment
used
to
take
the
samples;

°
The
name
and
address
of
the
laboratory
facility
at
which
analyses
of
the
samples
were
performed;

°
A
description
of
the
analytical
methods
used,
including
any
cleanup
and
sample
preparation
methods;
and
°
All
laboratory
analytical
results
used
to
determine
compliance
with
the
contaminant
limits
specified
in
this
paragraph.

(
ii)
Respondent
Activities
°
Sample
and
analyze
the
product
as
specified;
and
11
°
Keep
records
of
all
sampling
and
analyses
for
three
years.

5.
THE
INFORMATION
COLLECTED
­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
The
Agency
activities
associated
with
the
rule
include
processing
the
one­
time
notifications
received
from
generators
and
manufacturers
under
40
CFR
261.4(
a)(
20)(
ii)(
B)
and
40
CFR
261.4(
a)(
20)(
iii)(
B),
respectively,
and
the
annual
reports
received
from
manufacturers
under
40
CFR
261.4(
a)(
20)(
iii)(
D).
The
Agency
burden
and
costs
associated
with
these
activities
are
estimated
in
Exhibit
3.

5(
b)
Collection
Methodology
and
Management
In
collecting
and
analyzing
the
information
required
under
the
zinc
fertilizer
regulations,
EPA
uses
electronic
equipment
such
as
personal
computers
and
applicable
database
software,
when
appropriate.

5(
c)
Small
Entity
Flexibility
The
conditional
exclusion
is
intended
to
be
de­
regulatory,
and
would
relieve
both
small
and
large
generators
of
secondary
fertilizer
materials
from
most
of
the
RCRA
hazardous
waste
program
requirements,
as
specified.
In
addition,
EPA
has
kept
the
paperwork
requirements
under
the
conditional
exclusion
as
streamlined
and
as
consistent
with
standard
industry
practices
as
possible,
to
thereby
minimize
the
burden
on
both
large
and
small
entities.

5(
d)
Collection
Schedule
The
rule
would
require
generators
to
submit
to
EPA
a
one­
time
notification
of
their
intent
to
begin
managing
hazardous
secondary
materials
under
the
terms
of
the
exclusion.
Generators
would
keep
a
record
on
site
of
all
shipments
of
hazardous
secondary
materials
for
at
least
three
years.
The
rule
also
requires
manufacturers
to
sample
and
analyze
the
fertilizer
product
to
determine
compliance
with
the
contaminant
limits
for
metals
no
less
than
every
six
months,
and
for
dioxins
no
less
than
every
twelve
months.
In
addition,
manufacturers
will
submit
an
annual
report
to
EPA
describing
the
hazardous
secondary
materials
used
to
make
zinc
fertilizer.
Manufacturers
also
must
keep
a
record
of
all
shipments
of
hazardous
secondary
materials
received
for
at
least
three
years.
1The
$
1,800
estimate
for
laboratory
costs
is
taken
from
the
March
6,
2000
proposed
"
Land
Disposal
Restrictions,"
ICR
No.
1442.17.

12
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
In
Exhibit
1,
EPA
estimates
the
respondent
burden
associated
with
the
new
paperwork
requirements
in
the
proposed
rule.
As
shown
in
the
exhibit,
EPA
estimates
that
the
total
annual
respondent
burden
for
the
new
paperwork
requirements
in
the
rule
is
approximately
61
hours
per
year.

6(
b)
Estimating
Respondent
Costs
EPA
estimates
that
the
total
annual
respondent
cost
for
the
new
paperwork
requirements
in
the
rule
is
approximately
$
12,653.
This
cost
includes
annual
labor,
capital,
and
operation
and
maintenance
(
O&
M)
costs
to
be
incurred
by
respondents
affected
by
the
information
collection
requirements
covered
in
this
ICR.
Specific
data
and/
or
assumptions
used
in
developing
these
costs
are
described
below.

Labor
Costs
For
purposes
of
this
analysis,
EPA
estimates
an
average
hourly
respondent
labor
cost
of
$
90
for
legal
staff,
$
69.30
for
managerial
staff,
$
54.33
for
technical
staff,
and
$
24.29
for
clerical
staff.
These
estimates
include
overhead
and
fringe
costs
and
are
consistent
with
the
labor
rates
in
the
"
Part
B
Permit
Application,
Permit
Modification,
and
Special
Permits
ICR"
No.
1573.

Annual
Capital
and
Operation
&
Maintenance
Costs
Capital
costs
usually
include
any
produced
physical
good
needed
to
provide
the
needed
information,
such
as
machinery,
computers,
and
other
equipment.
EPA
does
not
anticipate
that
respondents
will
incur
capital
costs
in
carrying
out
the
information
collection
requirements
of
the
proposed
rule.

O&
M
costs
are
those
costs
associated
with
paperwork
requirements
incurred
continually
over
the
life
of
the
ICR.
They
are
defined
by
the
EPA
as
"
the
recurring
dollar
amount
of
costs
associated
with
O&
M
or
purchasing
services."
EPA
expects
that
the
only
respondent
O&
M
costs
incurred
under
the
rule
will
be
for
generators
and
manufacturers
to
make
submittals
to
the
Agency
(
i.
e.,
$
3.00
in
certified
mailing
costs)
and
for
manufacturers
to
sample
their
products
(
i.
e.,
$
1,800
in
annual
laboratory
costs).
1
2These
universe
assumptions
are
based
on
the
document,
"
Economic
Analysis
for
Regulatory
Modifications
to
the
Definition
of
Solid
Waste
for
Zinc­
Containing
Hazardous
Waste­
Derived
Fertilizers,
Notice
of
Final
Rulemaking."

13
6(
c)
Estimating
Agency
Burden
and
Costs
Agency
labor
costs
are
based
on
the
2000
GS
pay
schedule.
EPA
estimates
an
average
hourly
labor
cost
of
$
59.50
for
legal
staff
(
GS­
15,
Step
1),
$
55.65
for
managerial
staff
(
GS­
14,
Step
4),
$
40.80
for
technical
staff
(
GS­
12,
Step
5),
and
$
16.38
for
clerical
staff
(
GS­
5,
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.

Exhibit
3
shows
the
annual
burden
and
costs
to
the
Agency
for
collecting
information
under
the
rule.
As
shown
in
Exhibit
3,
EPA
estimates
that
the
total
annual
burden
and
cost
to
the
Agency
would
be
approximately
seven
hours
and
$
244.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Cost
Respondent
Universe
In
Exhibit
1,
EPA
provides
estimates
of
the
annual
number
of
respondents
that
will
be
required
to
comply
with
the
new
paperwork
requirements
in
the
proposed
rule.
In
the
same
exhibit,
EPA
estimates
respondent
burden
and
costs
associated
with
these
requirements.
Table
1
presents
the
number
of
respondents
that
are
expected
to
participate
under
the
rule.
2
As
shown
in
the
table,
EPA
estimated
that
24
generators
of
zinc­
bearing
secondary
materials
used
to
make
fertilizers
and
five
manufacturers
of
zinc
fertilizers
or
zinc
fertilizer
ingredients
will
participate
in
the
proposed
conditional
exclusion.
14
Table
1
Number
of
Generators
of
Zinc­
Bearing
Secondary
Materials
Used
in
Fertilizer
and
Manufacturers
of
Zinc
Fertilizers
or
Zinc
Fertilizer
Ingredients
Type
of
Waste
Handler
Number
of
Affected
Entities
Under
Rule
Generators
of
Zinc­
Bearing
Secondary
Materials
Used
in
Fertilizer
Steel
Mill
1
Ingot
Makers
9
Brass
Foundries
5
Brass
Mills
9
Subtotal
24
Manufacturers
of
Zinc
Fertilizer
or
Zinc
Fertilizer
Ingredients
5
Total
Number
of
Affected
Entities
29
Respondent
Burden
and
Cost
In
the
following
paragraphs,
EPA
discusses
the
universe
assumptions
of
Table
1
in
regard
to
the
paperwork
requirements
in
the
proposed
rule.

Reading
the
Regulations
As
shown
in
Exhibit
1,
EPA
estimates
that
24
generators
and
five
manufacturers
will
read
the
rule
for
zinc
fertilizers
each
year.
Thus,
in
total,
EPA
expects
29
generators
and
manufacturers
to
read
the
rule
annually.

Notification
for
Generators
EPA
expects
that
24
generators
will
be
required
to
submit
one­
time
notices
to
EPA
of
their
activities
under
40
CFR
261.4(
a)(
20)(
ii)(
B).
[
Note
that
Exhibit
1
presents
annual
burden
and
costs
over
the
three­
year
effective
life
of
this
ICR.
The
exhibit
presents
the
burden
and
cost
of
one­
time
activities
by
dividing
the
total
number
of
respondents
by
three.]

Record
of
Shipments
for
Generators
EPA
expects
that
24
generators
will
be
required
to
keep
records
of
off­
site
shipments
of
secondary
materials
each
year,
as
required
under
40
CFR
261.4(
a)(
20)(
ii)(
C).
Note
that
EPA
3This
$
1,800
estimate
is
obtained
from
the
proposed
"
Land
Disposal
Restrictions"
ICR,
No.
1442.17,
dated
March
6,
2000.

15
expects
generators
to
incur
negligible
burden
for
this
activity
since
they
would
most
likely
keep
such
records
as
a
standard
business
practice
(
e.
g.,
invoices
or
shipping
papers).

Notification
for
Manufacturers
Under
40
CFR
261.4(
a)(
20)(
iii)(
B),
five
manufacturers
of
zinc­
bearing
fertilizer
products
are
expected
to
submit
one­
time
notices
to
EPA
of
their
activities.
During
the
three­
year
effective
life
of
the
ICR,
this
equates
to
approximately
1.3
manufacturers
per
year.

Record
of
Shipments
for
Manufacturers
Under
40
CFR
261.4(
a)(
20)(
iii)(
C),
five
manufacturers
are
expected
to
keep
records
of
off­
site
shipments
received
each
year
from
generators
of
zinc­
bearing
secondary
materials.
EPA
expects
that
the
manufacturers
would
incur
negligible
burden
for
this
activity
since
they
would
most
likely
keep
such
records
as
a
standard
business
practice
(
e.
g.,
invoices
or
shipping
papers).

Annual
Report
for
Manufacturers
EPA
expects
the
five
manufacturers
to
submit
a
report
of
their
recycling
activities
once
each
year
under
proposed
40
CFR
261.4(
a)(
20)(
iii)(
D).

Product
Sampling
and
Analysis
for
Manufacturers
EPA
expects
that
the
five
manufacturers
will
perform
sampling
and
analysis
and
keep
records
as
specified
under
40
CFR
261.4(
a)(
21)(
ii).
EPA
expects
that
they
would
incur
approximately
$
1,800
in
annual
laboratory
costs
for
these
activities.
3
Total
Respondent
Burden
and
Cost
In
Exhibit
2,
EPA
presents
a
summary
of
the
total
annual
respondent
burden
and
costs
associated
with
both
new
and
existing
paperwork
requirements.
The
specific
information
collection
activities
of
the
new
paperwork
requirements
are
described
throughout
this
ICR,
and
the
total
annual
burden
and
cost
estimates
associated
with
them
are
calculated
in
Exhibit
1,
summarized
in
Exhibit
2,
and
briefly
described
below.
The
existing
paperwork
requirements
are
those
that
are
contained
in
the
current
RCRA
regulations
and
that
apply
to
generators
of
secondary
materials
and
manufacturers
of
zinc
fertilizer
or
zinc
fertilizer
ingredients,
as
applicable.
These
existing
requirements,
the
existing
ICRs
with
which
they
are
associated,
and
the
total
annual
burden
and
cost
associated
with
them
also
are
summarized
in
Exhibit
2
and
briefly
described
below.
16
New
Paperwork
Requirements
Using
the
per
respondent
burden
estimated
in
Section
6(
a),
the
per
respondent
costs
estimated
in
Section
6(
b),
and
the
respondent
universe
estimated
in
this
section,
Exhibit
1
illustrates
the
total
respondent
burden
and
costs
associated
with
all
of
the
new
information
collection
activities
in
the
proposed
rule.
As
noted
above,
this
exhibit
presents
the
annual
burden
and
costs
over
the
three­
year
effective
life
of
the
ICR.
The
exhibit
calculates
the
burden
and
cost
of
one­
time
activities
by
dividing
the
total
number
of
respondents
by
three.
In
Exhibit
2,
EPA
summarizes
the
total
annual
respondent
burden
and
cost
of
these
new
paperwork
requirements
derived
in
Exhibit
1.

Existing
Paperwork
Requirements
In
addition
to
the
new
paperwork
requirements
in
the
proposed
rule,
EPA
also
estimated
the
burden
and
cost
savings
that
generators
and
manufacturers
would
expect
for
no
longer
following
the
existing
RCRA
information
collection
requirements
for
the
excluded
materials.
In
Exhibit
2,
EPA
presents
the
total
annual
respondent
burden
and
cost
savings
under
the
existing
paperwork
requirements,
broken
out
by
the
five
existing
EPA
ICRs
that
are
affected
by
the
rule.
In
developing
Exhibit
2,
EPA
reviewed
each
of
the
affected
ICRs
to
identify
the
existing
information
collection
activities
that
are
currently
undertaken
by
generators
and
manufacturers,
calculated
the
associated
burden
and
costs
(
or
savings),
and
presented
the
totals
in
the
exhibit.

The
total
costs
in
Exhibit
2
are
broken
down
into
labor,
capital,
and
operation
and
maintenance
(
O&
M)
costs.
In
Section
6(
b),
EPA
presents
a
discussion
of
the
capital
and
O&
M
costs
associated
with
new
paperwork
requirements
from
the
rule.
In
the
following
paragraph,
EPA
presents
a
brief
discussion
of
the
capital
and
O&
M
costs
associated
with
each
of
the
existing
ICRs
that
are
affected
by
the
rule.

There
are
no
O&
M
costs
associated
with
the
Generator
Standards
ICR
(
ICR
No.
820)
or
with
the
Specific
Units
ICR
(
ICR
No.
1572).
For
the
Biennial
Report
ICR
(
ICR
No.
976),
O&
M
costs
are
associated
with
submitting
the
Hazardous
Waste
report
and
maintaining
copies
of
Waste
Generation
and
Management
(
GM)
and
Waste
Received
from
Off­
Site
(
WR)
forms.
For
the
General
Facility
Standards
ICR
(
ICR
No.
1571),
the
O&
M
costs
are
associated
with
performing
a
waste
analysis
twice
annually
and
submittal
of
documents
to
EPA.
For
the
Part
B
ICR
(
ICR
No.
1573),
O&
M
costs
are
associated
with
submitting
the
Part
B
application
materials
to
EPA.
Capital
costs
are
not
associated
with
any
of
these
ICRs
except
for
one.
For
the
General
Facility
Standards
ICR
(
ICR
No.
1571),
capital
costs
are
associated
with
keeping
the
operating
record
in
a
filing
cabinet.
17
6(
e)
Bottom
Line
Burden
Hours
and
Costs
Respondent
Tally
In
Exhibit
2,
EPA
presents
the
total
annual
respondent
burden
and
cost
for
both
new
and
existing
paperwork
requirements
associated
with
the
rule.
As
described
specifically
in
Section
6(
d)
above,
these
new
and
existing
paperwork
requirements
apply
to
generators
and
intermediate
handlers
of
zinc­
bearing
secondary
materials
used
in
fertilizers
and
manufacturers
of
zinc
fertilizer
or
zinc
fertilizer
ingredients.
As
shown
in
Exhibit
2,
the
total
annual
respondent
burden
for
these
new
paperwork
requirements
is
approximately
61
hours,
at
an
annual
cost
of
$
12,653.
As
also
shown
in
Exhibit
2,
the
total
annual
respondent
burden
savings
under
the
existing
paperwork
requirements,
which
are
associated
with
five
existing
EPA
ICRs,
is
408
hours,
at
annual
cost
savings
of
approximately
$
21,149.
In
the
same
Exhibit
2,
EPA
then
combines
the
burden
and
cost
impacts
under
both
new
and
existing
paperwork
requirements
and
estimates
the
total
annual
respondent
burden
savings
for
all
information
collection
activities
at
348
hours
and
an
annual
cost
savings
of
approximately
$
8,496.

The
bottom
line
respondent
burden
hours
saved
over
the
three­
year
period
covered
by
this
ICR
is
approximately
1,044
hours,
at
a
total
cost
savings
of
$
25,488.

Agency
Tally
In
Exhibit
3,
EPA
presents
the
total
annual
Agency
burden
or
cost
associated
with
this
rule.
As
shown
in
Exhibit
3,
the
total
annual
Agency
burden
for
these
new
paperwork
requirements
is
seven
hours,
at
an
annual
cost
of
approximately
$
244.

The
bottom
line
Agency
burden
over
the
three­
year
period
covered
by
this
ICR
is
21
hours,
at
a
total
cost
of
approximately
$
735.

6(
f)
Reasons
for
Change
In
Burden
In
finalizing
the
conditional
exclusion
at
40
CFR
261.4(
a)(
20)
and
(
21),
EPA
will
relieve
generators
and
intermediate
handlers
of
hazardous
secondary
materials
used
in
fertilizer
manufacturing
from
existing
RCRA
Subtitle
C
regulations
for
that
waste.
Manufacturers
receiving
and
processing
these
secondary
materials
also
will
be
relieved
of
RCRA
regulations
for
that
waste.
These
generators,
intermediate
handlers
and
manufacturers
will
only
need
to
comply
with
a
tailored
set
of
conditions
in
generating,
transporting
and
otherwise
managing
these
secondary
wastes
under
RCRA.

6(
g)
Burden
Statement
The
public
reporting
burden
for
generators
of
zinc­
bearing
secondary
materials
under
the
new
paperwork
requirements
is
estimated
to
be
about
21
minutes
over
the
three­
year
life
of
this
18
ICR.
This
includes
time
for
preparing
and
submitting
the
one­
time
notification
to
EPA.
(
This
one­
time
burden
of
21
minutes
equates
to
an
annualized
burden
of
7
minutes
per
year,
if
annualized
of
the
three­
year
life
of
this
ICR.)
The
recordkeeping
burden
for
these
generators
under
the
new
paperwork
requirements
is
estimated
to
be
about
one
hour
and
21
minutes
per
year.
This
includes
time
for
reading
the
rule
and
keeping
records
of
offsite
shipments
of
zincbearing
secondary
materials.

The
public
reporting
burden
for
manufacturers
of
zinc­
bearing
fertilizer
or
fertilizer
ingredients
under
the
new
paperwork
requirements
is
estimated
to
range
from
about
two
hours
and
45
minutes
to
three
hours
per
year.
This
includes
time
for
preparing
and
submitting
the
onetime
notice
and
an
annual
report
to
EPA.
The
recordkeeping
burden
for
these
manufacturers
under
the
new
paperwork
requirements
is
estimated
to
be
about
two
hours
and
27
minutes
per
year.
This
includes
time
for
reading
the
rule,
keeping
records
of
offsite
shipments
of
zinc­
bearing
secondary
materials,
performing
sampling/
analysis
as
specified,
and
keeping
records
of
the
sampling/
analysis.

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
1.

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
burden
estimates
contained
in
the
ICR,
and
any
suggestions
for
reducing
the
burden,
to
the
Director,
Regulatory
Information
Division,
Office
of
Policy,
U.
S.
Environmental
Protection
Agency
(
2822T),
1200
Pennsylvania
Ave.,
NW,
Washington,
D.
C.
20460;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
N.
W.,
Washington,
D.
C.,
20503.
19
EXHIBIT
1
ESTIMATED
ANNUAL
RESPONDENT
BURDEN
AND
COST
Hours
and
Costs
per
Respondent
Total
Hours
and
Costs
INFORMATION
COLLECTION
ACTIVITY
Legal
$
90.00/
hr
Manager
$
69.30/
hr
Technical
$
54.33/
hr
Clerical
$
24.29/
hr
Respon.

Hours/

Year
Labor
Cost/

Year
Capital/

Startup
Costs
O&
M
Costs
Number
of
Respondents
Total
Hours/

Year
Total
Cost/

Year
Read
the
Regulations
0.25
0.5
0.5
0
1.25
$
84.32
$
0.00
$
0.00
20
25
$
1,686.30
Complete
and
submit
notification
0
0.1
0.25
0
0.35
$
20.51
$
0.00
$
3.00
5
1.75
$
117.56
Keep
records
of
shipping
activities
0
0
0
0.1
0.1
$
2.43
$
0.00
$
0.00
16
1.6
$
38.86
Subtotal
varies
varies
varies
varies
varies
varies
$
0.00
varies
varies
3.35
$
156.43
Complete
and
submit
notification
0
0.1
0.25
0
0.35
$
20.51
$
0.00
$
3.00
1.3
0.455
$
30.57
Keep
records
of
shipping
activities
0
0
0
0.1
0.1
$
2.43
$
0.00
$
0.00
4
0.4
$
9.72
Complete
and
submit
the
annual
report
0
0.25
2
0.5
2.75
$
138.13
$
0.00
$
3.00
4
11
$
564.52
Sample
and
analyze
the
product
0
0
1
0
1
$
54.33
$
0.00
$
1,800.00
4
4
$
7,417.32
Keep
sampling
and
analysis
records
0
0
0
0.1
0.1
$
2.43
$
0.00
$
0.00
4
0.4
$
9.72
Subtotal
varies
varies
varies
varies
varies
varies
$
0.00
varies
varies
16.255
$
8,031.84
Total
varies
varies
varies
varies
varies
varies
$
0.00
varies
varies
44.605
$
9,874.56
Product
sampling
and
analysis
(
261.4(
a)(
21)(
ii)
and
(
iii))

Requirements
for
Generators
Requirements
for
Manufacturers
Record
of
shipments
(
261.4(
a)(
20)(
iii)(
C))

Annual
report
(
261.4(
a)(
20)(
iii)(
D)

Reading
the
Regulations
­
Generators
and
Manufacturers
Notification
(
261.4(
a)(
20)(
ii)(
B))

Record
of
shipments
(
261.4(
a)(
20)(
ii)(
C))

Notification
(
261.4(
a)(
20)(
iii)(
B))
20
EXHIBIT
2
ESTIMATED
ANNUAL
RESPONDENT
BURDEN
AND
COST
SUMMARY
(
INCLUDING
INCREMENTAL
INCREASE
IN
PAPERWORK
BURDEN
FOR
EXISTING
ICRS)

Requirements
for
Zinc
Fertilizers
Made
from
Recycled
Hazardous
Secondary
Materials
45
$
2,644
$
0
$
7,231
$
9,875
Generator
Standards
820
­
3
­$
154
$
0
$
0
­$
154
Biennial
Report
976
­
2
­$
150
$
0
­$
2
­$
152
General
Facility
Standards
1571
­
279
­$
12,464
­$
181
­$
1,506
­$
14,151
Specific
Units
1572
­
87
­$
4,650
$
0
$
0
­$
4,650
Part
B
Permit
Application,
Permit
Modifications,
and
Special
Permits
1573
­
37
­$
2,042
$
0
­$
1
­$
2,043
Subtotal
N/
A
­
408
­$
19,460
­$
181
­$
1,509
­$
21,149
TOTAL
N/
A
­
364
­$
16,816
­$
181
$
5,722
­$
11,275
Existing
Paperwork
Requirements
ICR
Name
ICR
Number
Total
Hours/
Year
New
Paperwork
Requirements
Total
Labor
Cost/
Year
Total
Annual
Capital
Cost
Total
Annual
O&
M
Cost
Total
Cost
21
EXHIBIT
3
ESTIMATED
ANNUAL
AGENCY
BURDEN
AND
COST
Hours
and
Costs
per
Respondent
Total
Hours
and
Costs
INFORMATION
COLLECTION
ACTIVITY
Legal
$
59.50/
hr
Manager
$
55.65/
hr
Technical
$
40.80/
hr
Clerical
$
16.38/
hr
Respon.

Hours/

Year
Labor
Cost/

Year
Capital/

Startup
Costs
O&
M
Costs
Number
of
Respondents
Total
Hours/

Year
Total
Cost/

Year
Receive
and
process
notification
0
0
0.25
0.1
0.35
$
11.84
$
0.00
$
0.00
5
1.75
$
59.19
Receive
and
process
notification
0
0
0.25
0.1
0.35
$
11.84
$
0.00
$
0.00
1.3
0.455
$
15.39
Receive
and
process
the
annual
report
0
0
1
0.1
1.1
$
42.44
$
0.00
$
0.00
4
4.4
$
169.75
Total
varies
varies
varies
varies
varies
varies
$
0.00
$
0.00
varies
6.605
$
244.34
Generator
Notifications
Notification
(
261.4(
a)(
20)(
iii)(
B))

Annual
report
(
261.4(
a)(
20)(
iii)(
D)

Notification
(
261.4(
a)(
20)(
ii)(
B))

Manufacturer
Notifications
and
Annual
Reports
