SUPPORTING
STATEMENT
FOR
EPA
INFORMATION
COLLECTION
REQUEST
2005.01
"
THE
RCRA
SUBTITLE
C
SITE
IDENTIFICATION
FORM"

May
22,
2001
Page
i
TABLE
OF
CONTENTS
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
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1
1(
a)
Title
and
Number
of
the
Information
Collection
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1
1(
b)
Characterization
of
the
Information
Collection
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1
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
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2
2(
a)
Need
and
Authority
for
the
Collection
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2
2(
b)
Use
and
Users
of
the
Data
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3
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3
3(
a)
Nonduplication
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3
3(
b)
Public
Notice
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3
3(
c)
Consultations
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3
3(
d)
Effects
of
Less
Frequent
Collection
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4
3(
e)
General
Guidelines
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4
3(
f)
Confidentiality
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4
3(
g)
Sensitive
Questions
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4
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
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5
4(
a)
Respondents
and
Standard
Industrial
Classification
(
SIC)
Codes
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5
4(
b)
Information
Requested
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6
5.
THE
INFORMATION
COLLECTED
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AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
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6
5(
a)
Agency
Activities
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6
5(
b)
Collection
Methodology
and
Management
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6
5(
c)
Small
Entity
Flexibility
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7
5(
d)
Collection
Schedule
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7
6.
ESTIMATING
THE
HOUR
AND
COST
BURDEN
OF
THE
COLLECTION
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8
6(
a)
Estimating
Respondent
Hourly
Burden
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8
6(
b)
Estimating
Respondent
Cost
Burden
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8
6(
c)
Estimating
Agency
Hour
and
Cost
Burden
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9
6(
d)
Estimating
the
Respondent
Universe
and
Total
Hour
and
Cost
Burden
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9
6(
e)
Bottom
Line
Hour
and
Cost
Tables
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13
6(
f)
Reasons
For
Change
In
Burden
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14
6(
g)
Burden
Statement
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15
Page
1
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
and
Number
of
the
Information
Collection
This
information
collection
request
(
ICR)
is
entitled
"
The
RCRA
Subtitle
C
Site
Identification
Form,"
EPA
ICR
Number
2005.01.

1(
b)
Characterization
of
the
Information
Collection
The
Resource
Conservation
and
Recovery
Act
of
1976
(
RCRA),
as
amended,
requires
hazardous
waste
generators
and
treatment,
storage,
and
disposal
facilities
(
TSDFs)
to
report
their
hazardous
waste
activities
to
EPA
or
authorized
States
at
least
every
two
years
(
RCRA
3002
and
3004).
These
requirements
are
in
40
CFR
Part
262
for
generators,
and
40
CFR
Parts
264
and
265
for
TSDFs.

The
Hazardous
Waste
Report
(
also
known
as
the
Biennial
Report)
is
the
instrument
used
by
generators
and
TSDFs
to
satisfy
these
requirements.
The
1999
Hazardous
Waste
Report
(
the
most
recently
completed
collection)
consisted
of
four
forms:
(
i)
Identification
and
Certification
(
Form
IC);
(
ii)
Waste
Generation
and
Management
(
Form
GM);
(
iii)
Waste
Received
from
Off
Site
(
Form
WR);
and
(
iv)
Off­
Site
Identification
(
Form
OI).

During
2000,
EPA
completed
an
analysis
of
the
information
needs
of
EPA
and
the
States,
and
developed
recommendations
for
improving
EPA's
information
collection
processes.
The
analysis
noted
that
three
different
EPA
forms
collected
basic
site
identification
information
from
the
regulated
community.
Specifically,
large
quantity
generators
and
TSDFs
report
site
information
for
the
Hazardous
Waste
Report
(
EPA
Form
8700­
13A/
B)
on
the
Form
IC.
Basic
site
information
is
also
collected
from
all
RCRA­
regulated
sites
on
the
Notification
of
Regulated
Waste
Activity
form
(
EPA
Form
8700­
12).
Finally,
TSDFs
seeking
a
permit
or
permit
renewal
submit
site
information
on
the
RCRA
Hazardous
Waste
Part
A
Permit
Application
(
EPA
Form
8700­
23).
The
multiple
reporting
requirements
can
give
regulators
conflicting
information
about
the
same
site.
It
is
also
burdensome
for
respondents.

To
address
these
concerns
EPA
developed
a
new
form,
the
RCRA
Site
Identification
(
Site
ID)
Form,
which
standardizes
the
site
information
collected
on
the
three
forms.
For
the
2001
Hazardous
Waste
Report,
EPA
has
replaced
the
1999
Form
IC
with
the
Site
ID
Form.
This
ICR
only
deals
with
the
Site
ID
form
as
part
of
the
Hazardous
Waste
Report.
Please
note
that
the
Site
ID
Form
also
replaces
the
Notification
of
Regulated
Waste
Activity
form,
and
is
submitted
as
part
of
the
Part
A
permit
application.
EPA
believes
that
the
Site
ID
Form
will
result
in
increased
data
accuracy
and
quality
through
reduced
variation
in
response.

All
sites
required
to
submit
the
2001
Hazardous
Waste
Report
must
submit
a
Site
ID
Form.
EPA
expects
that
some
states
will
fill
out
Site
ID
Forms
with
information
about
a
facility
Page
2
from
their
files
prior
to
sending
out
the
form
(
known
as
pre­
populating
a
form).
Respondents
receiving
these
pre­
populated
forms
need
only
review
and
update
the
required
items
of
the
form.
Sections
1
through
5
of
this
ICR
describe
the
respondent
activities
associated
with
preparing
and
submitting
the
Site
ID
Form
with
the
2001
Hazardous
Waste
Report,
as
well
as
the
Agency
activities
associated
with
processing
the
Site
ID
Form.
Section
6
of
this
ICR
presents
the
respondent
and
Agency
hour
and
cost
burden
associated
with
these
activities.

Note
that
this
ICR
does
not
examine
the
entire
burden
of
the
2001
Hazardous
Waste
Report.
Rather,
the
ICR
examines
the
Site
ID
Form
separately
because
it
is
used
in
three
different
information
collections,
as
described
above,
and
has
its
own
OMB
control
number.
This
ICR
also
does
not
address
the
other
uses
of
the
Site
ID
Form
(
the
site
notifications
and
Part
A
permit
applications).

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need
and
Authority
for
the
Collection
This
subsection
establishes
the
need
and
legal
authority
for
the
Site
ID
Form.

Need
for
the
Information
Collection
The
Site
ID
Form
requests
the
name
and
phone
number
of
the
site's
contact
person,
the
site's
physical
and
mailing
address,
and
information
on
the
types
of
hazardous
waste
activities
at
the
site.
EPA
and
the
states
need
this
information
to
ascertain
the
location
of
regulated
sites
and
the
identity
of
responsible
personnel.
Regulators
also
need
this
information
to
learn
what
is
happening
at
the
site.
EPA
and
the
states
will
use
the
Site
ID
Form
information
for
compliance
purposes
(
preparing
for
site
inspections),
for
planning,
and
to
help
develop
regulations.

Legal
Authority
for
the
Information
Collection
Under
the
authority
of
RCRA
Sections
3002
and
3004,
as
amended,
EPA
requires
generators
and
TSDFs
to
prepare
and
submit
the
Hazardous
Waste
Report
every
two
years.
The
Hazardous
Waste
Report
collects
information
on
the
quantities
and
nature
of
hazardous
wastes
that
have
been
generated
during
the
year,
the
disposition
of
these
hazardous
wastes,
and
changes
in
the
volume
of
waste
achieved
in
comparison
with
previous
years.

Each
site
required
to
complete
the
Hazardous
Waste
Report
must
complete
and
submit
a
Site
ID
Form.
Because
the
Site
ID
Form
collects
general
site
identification
information,
it
assists
EPA
and
the
states
in
learning
the
identity,
number,
types
of
hazardous
waste
activities,
and
regulated
status
of
sites
submitting
the
Hazardous
Waste
Report.
The
Site
ID
Form
also
provides
site
contact
information
that
is
used
to
follow
up
with
sites
in
case
there
are
data
problems
or
questions
about
the
Hazardous
Waste
Report
submittal.
The
Site
ID
Form
is
an
essential
tool
in
implementing
RCRA's
reporting
requirements.
Page
3
2(
b)
Use
and
Users
of
the
Data
Implementation
of
the
RCRA
program
requires
the
collection
of
information
on
the
number
of
generators
and
TSDFs,
as
well
as
the
characteristics
of
individual
sites.
This
information,
which
is
collected
on
the
Site
ID
Form,
is
used
for
waste
activity
monitoring,
compliance
monitoring,
technical
assistance,
program
planning,
and
waste
minimization.
The
information
is
also
used
by
public
interest
groups
(
such
as
the
Right­
to­
Know
Network)
and
industry.

The
data
collected
in
the
Site
ID
Form
and
the
other
Hazardous
Waste
Report
forms
(
Form
GM
and
WR)
are
also
used
by
EPA's
Office
of
Solid
Waste
(
OSW)
to
prepare
a
national
report
summarizing
hazardous
waste
generation
and
management
activities.
The
data
also
are
used
by
EPA
and
the
states
for
programmatic
and
regulatory
needs.
States
coordinate
with
EPA
Regions
and
OSW
to
supply
EPA
with
the
data
reported
by
regulated
entities
for
inclusion
in
a
national
database
(
called
RCRAInfo).

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
The
primary
purpose
of
the
Site
ID
Form
is
to
eliminate
the
duplication
among
three
existing
EPA
collection
mechanisms
that
collect
site
information
from
the
regulated
community.
As
discussed
above,
the
Site
ID
Form
standardizes
the
RCRA
site
information
collected
on
Form
IC
of
the
Hazardous
Waste
Report,
the
Notification
of
Regulated
Waste
Activity
form,
and
the
RCRA
Hazardous
Waste
Part
A
Permit
Application.
The
Site
ID
Form
replaces
the
Form
IC
and
the
Notification
of
Regulated
Waste
Activity
form,
and
is
used
in
conjunction
with
the
Part
A
permit
application.
Once
a
site
has
submitted
the
Site
ID
Form,
it
can
just
attach
a
copy
of
the
previous
submittal
(
with
any
changes)
when
site
identification
information
is
requested
again.

3(
b)
Public
Notice
EPA
solicited
public
comments
on
the
burden
assumptions
included
in
this
ICR
through
an
announcement
in
the
Federal
Register
on
June
23,
2000
(
65
FR
39142).
The
public
comment
period
ended
August
22,
2000.
EPA
received
nine
comments.
Commenters
supported
the
merging
of
common
elements
of
site
identification
information
onto
the
Site
ID
form.

3(
c)
Consultations
Over
the
past
several
years,
EPA
and
the
states
have
worked
closely
in
evaluating
and
improving
EPA's
information
collection
processes.
The
objective
of
this
initiative
(
referred
to
as
1
WIN
stands
for
Waste
Information
Needs,
and
is
the
OSW
portion
of
the
project.
INFORMED
stands
for
Information
Needed
for
Making
Environmental
Decisions,
and
is
the
State
portion
of
the
project.

Page
4
the
WIN/
INFORMED
Initiative1)
is
to
assess
the
information
needs
of
the
hazardous
waste
program,
assess
the
way
information
is
managed,
and
make
recommendations
for
improvement.
WIN/
INFORMED
also
is
making
changes
to
improve
the
collection,
quality,
use,
and
management
of
hazardous
waste
information,
and
finding
ways
to
make
that
information
more
available
to
states,
Tribes,
and
the
public.

In
addition
to
working
closely
with
our
state
partners
on
the
WIN/
INFORMED
Team,
EPA
sent
the
recommended
Site
ID
form
to
all
fifty
states
for
their
review.
The
Agency
received
comments
from
thirty
states.

Finally,
as
discussed
in
Section
3(
b)
of
this
ICR,
EPA
solicited
and
received
public
comments
on
the
recommendations
via
the
June
23,
2000,
Federal
Register
notice.
EPA
reviewed
and
considered
these
comments
in
designing
the
Site
ID
form.

3(
d)
Effects
of
Less
Frequent
Collection
The
Site
ID
Form
is
part
of
the
Hazardous
Waste
Report,
which
is
submitted
every
two
years.
This
two­
year
cycle
is
statutorily
required.
Though
some
states
collect
the
information
contained
in
the
Hazardous
Waste
Report
annually
or
quarterly,
EPA
does
not
require
more
frequent
data
collection.

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

3(
f)
Confidentiality
Section
3007(
b)
of
RCRA
and
40
CFR
Part
2,
Subpart
B,
which
define
EPA's
general
policy
on
public
disclosure
of
information,
contain
provisions
for
confidentiality.

3(
g)
Sensitive
Questions
There
are
no
sensitive
questions
asked
in
the
Site
ID
Form.
2
Literally
hundreds
of
SIC
codes
were
reported
to
the
1997
Hazardous
Waste
Report
at
the
4­
digit
level.
EPA
has
abbreviated
the
list,
as
shown
in
this
ICR,
by
identifying
these
SIC
codes
at
the
2­
digit
level
(
e.
g.,
28
instead
of
2823).
This
does
not
mean,
however,
that
all
4­
digit
SIC
codes
beginning
with
the
2­
digit
codes
shown
in
the
list
were
reported
to
the
Hazardous
Waste
Report.

Page
5
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents
and
SIC
Codes
Based
on
1997
Biennial
Reporting
System
(
BRS)
data,
the
most
recent
data
available
when
this
analysis
was
done,
the
SIC
codes
that
represent
the
respondents
are
as
follows
(
also
shown
are
the
new
North
American
Industrial
Classification
System
(
NAICS)
codes
that
correspond
to
the
SIC
codes
listed):
2
SIC
Code
Description
SIC
Code
NAICS
Code
Agriculture,
Forestry,
and
Fisheries
01­
09
111­
115
Mineral
Industries
10­
14
211­
213
Construction
Industries
15­
17
233­
235
Manufacturing
20­
39
311­
339
Transportation,
Communication,
and
Utilities
41­
49
481­
493;
513
Wholesale
Trade
50­
51
421­
422
Retail
Trade
52­
59
441­
454
Finance,
Insurance,
and
Real
Estate
60­
67
521­
525;
531­
533
Service
Industries
70­
89
541
­
814
Public
Administration
91­
97
921­
928
Nonclassifiable
Establishments
99
Not
Available
Page
6
4(
b)
Information
Requested
The
Site
ID
Form
must
be
submitted
by
each
respondent
required
to
file
the
2001
Hazardous
Waste
Report.

(
i)
Data
Item:


Following
are
the
Site
ID
Form
items
that
must
be
completed
for
the
Hazardous
Waste
Report:

­
Reason
for
submittal
of
the
form;
­
Site
EPA
ID
number;
­
Site
name;
­
Site
location
information;
­
North
American
Industry
Classification
System
code
for
the
site;
­
Site
mailing
address;
­
Name
and
phone
number
of
site
contact
person;
­
Type
of
hazardous
waste
activities
at
the
site
that
require
submittal
of
a
Hazardous
Waste
Report;
and
­
Certification
that
the
information
provided
in
the
form
is
truthful,
accurate,
and
complete.

(
ii)
Respondent
Activities:


Respondents
must
perform
the
following
activities:

­
Read
the
Site
ID
Form
instructions;
­
Gather
information
and
prepare
Site
ID
Form;
­
Submit
the
Site
ID
Form
to
the
State
or
Regional
EPA
Office;
and
­
Maintain
a
copy
of
the
Site
ID
Form
for
three
years.

5.
THE
INFORMATION
COLLECTED
­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
Agency
activities
associated
with
the
Site
ID
Form
include
preparing
and
distributing
the
form,
reviewing
submittals,
entering
the
information
into
a
database,
and
processing
the
information
(
preparing
tallies
and
reports).

5(
b)
Collection
Methodology
and
Management
3
In
implementing
RCRA
Subtitle
C,
EPA
uses
the
quantity
of
waste
generated
per
month
to
determine
the
extent
to
which
a
firm
should
be
regulated.
EPA
categorizes
generators
of
less
than
1,000
kilograms
of
non­
acute
hazardous
waste
per
month
as
small
quantity
generators
(
SQGs)
and
relieves
them
of
specified
requirements.

Page
7
Data
are
collected
from
the
Site
ID
Form
and
the
other
Hazardous
Waste
Report
forms
(
Form
GM
and
WR),
and
entered
into
an
electronic
database
by
the
states
and
Regions.
States
coordinate
with
EPA
Regions
and
OSW
to
supply
EPA
with
the
data
reported.
These
data
are
maintained
in
the
RCRAInfo
database
residing
on
centrally
managed
EPA
servers
at
the
Agency's
National
Computing
Center.
Once
an
initial
version
of
the
national
database
is
compiled,
EPA
coordinates
a
data
quality
review
process
with
states
and
EPA
Regions
to:
identify
cases
where
a
state
or
Region
wishes
to
confirm
that
data
were
correctly
entered,
to
contact
a
regulated
entity
to
confirm
what
they
reported,
and
to
provide
the
reporter
the
opportunity
to
submit
an
updated
report
if
the
original
contained
errors.
Following
submittal
of
final
data
from
states
and
Regions,
no
further
changes
are
made
to
the
database.

5(
c)
Small
Entity
Flexibility
The
Site
ID
Form
reduces
the
reporting
burden
for
both
large
and
small
entities.
As
mentioned
above,
the
Site
ID
Form
replaces
the
Form
IC
of
the
Hazardous
Waste
Report.
Once
a
site
completes
a
Site
ID
Form,
the
site
can
just
attach
a
copy
of
the
previous
submittal
(
with
any
changes)
when
site
identification
information
is
requested
again.
EPA
also
expects
that
some
states
will
pre­
populate
the
Site
ID
Form
prior
to
its
distribution
to
sites.

Further,
since
small
quantity
generators
(
SQGs)
are
not
required
to
file
the
2001
Hazardous
Waste
Report,
they
will
not
need
to
complete
the
Site
ID
Form
for
that
information
collection.
3
5(
d)
Collection
Schedule
The
Site
ID
Form
will
be
distributed
and
collected
along
with
the
rest
of
the
2001
Hazardous
Waste
Report.
EPA's
2001
Hazardous
Waste
Report
implementation
schedule
is
outlined
below.

Reporting
and
Implementation
Schedule
Activity
Lead
(
HQ,
Region,
or
State)
Start
Date
End
Date
Print
2001
Forms
HQ
July
2001
July
2001
Activity
Lead
(
HQ,
Region,
or
State)
Start
Date
End
Date
4
The
book
was
edited
by
Eva
Jacobs,
and
was
published
in
1998
by
Bernan
Press.
EPA
used
the
labor
rates
in
the
1998
publication
and
then
updated
them
to
year
2000
levels
using
an
annual
employment
cost
index
of
3.0.

Page
8
Distribute
2001
Forms
to
States
HQ
September
2001
October
2001
Distribute
2001
Forms
to
Handlers
States
October
2001
December
2001
BRS
Help
Line
HQ
January
2001
June
2002
Handler
2001
Forms
Due
States
Not
Applicable
March
1,
2002
Final
State/
Regional
Data
due
to
HQ
Region
Not
Applicable
November
1,
2002
Develop
Draft
2001
National
Biennial
RCRA
Hazardous
Waste
Report
HQ
November
2002
December
31,
2002
6.
ESTIMATING
THE
HOUR
AND
COST
BURDEN
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Hourly
Burden
Exhibit
1
lists
all
of
the
respondent
activities
associated
with
preparing
the
Site
ID
Form,
and
presents
hour
and
cost
burden
estimates
for
each
activity.
The
hourly
burden
estimates
are
broken
down
by
labor
category
(
legal,
managerial,
technical,
and
clerical)
and
totaled
on
a
peractivity
basis.
The
burden
estimates
are
then
multiplied
by
the
estimated
number
of
respondents
to
obtain
an
estimate
of
the
overall
hourly
burden
to
the
regulated
universe
for
each
activity.

6(
b)
Estimating
Respondent
Cost
Burden
Estimating
Labor
Costs
EPA
estimates
an
average
hourly
respondent
labor
cost
(
including
overhead)
of
$
108.00
for
legal
staff,
$
77.00
for
managerial
staff,
$
57.00
for
technical
staff,
and
$
29.00
for
clerical
staff.
To
arrive
at
these
estimates,
EPA
consulted
the
Handbook
of
U.
S.
Labor
Statistics,
Second
Edition,
4
which
summarizes
the
unloaded
(
base)
hourly
rate
for
various
labor
categories
in
U.
S.
firms.
EPA
then
applied
an
overhead
factor
of
2.3
for
non­
legal
staff
and
3.0
for
legal
staff
to
5
Based
on
the
report
Estimating
Costs
for
the
Economic
Benefits
of
RCRA
Noncompliance.
The
report
was
authored
by
U.
S.
EPA,
RCRA
Enforcement
Division,
Office
of
Regulatory
Enforcement,
and
was
published
in
February
1997.

6
The
annual
number
of
respondents
for
the
2001
Hazardous
Waste
Report
(
10,157)
is
based
on
the
total
number
of
large
quantity
generators
responding
to
the
1997
Hazardous
Waste
Report
(
i.
e.,
20,314/
2).

Page
9
derive
their
loaded
hourly
rates.
5
Using
the
total
burden
hours
discussed
in
Section
6(
a)
and
the
wage
rates
outlined
in
this
section,
Exhibit
1
illustrates
the
labor
costs
associated
with
the
respondent
information
collection
activities
covered
in
this
ICR.

Estimating
Capital
and
O&
M
Costs
EPA
estimates
that
each
site
will
incur
a
one­
time
postage
cost
of
$
1.50/
form
in
submitting
the
Site
ID
Form.
EPA
estimates
that
sites
also
will
use/
purchase
file
cabinets
(@
a
cost
of
$
0.01/
form)
and
make
photocopies
(@
a
cost
of
$
0.10/
form)
to
keep
a
copy
of
the
form
on
site
for
three
years.

6(
c)
Estimating
Agency
Hour
and
Cost
Burden
EPA
estimates
annual
Agency
burden
hours
and
costs
associated
with
the
Site
ID
Form
in
Exhibit
2.
EPA
believes
that
the
Headquarters,
Regional,
and
State
offices
will
be
involved
in
these
activities.
Based
on
the
2000
GS
Pay
Schedule,
EPA
estimates
an
average
hourly
labor
cost
of
$
67.44
for
legal
staff
(
GS­
15,
Step
5),
$
59.50
for
managerial
staff
(
GS­
15,
Step
1),
$
42.80
for
technical
staff
(
GS­
13,
Step
1),
and
$
18.26
for
clerical
staff
(
GS­
6,
Step
1).
To
derive
these
hourly
estimates,
EPA
divided
the
annual
compensation
estimates
by
2,080,
which
is
the
number
of
hours
in
the
Federal
work­
year,
and
then
multiplied
the
hourly
rates
by
the
standard
government
overhead
factor
of
1.6.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Hour
and
Cost
Burden
EPA
estimates
that
the
total
number
of
respondents
to
the
2001
Hazardous
Waste
Report
will
be
approximately
20,314,
which
annualized
over
the
two­
year
report
cycle,
equals
10,157
per
year.
6
Sites
required
to
submit
the
2001
Hazardous
Waste
Report
must
submit
a
Site
ID
Form.
Note
that
we
considered
other
methods
of
estimating
the
number
of
responses
(
such
as
looking
at
the
number
of
respondents
in
past
Hazardous
Waste
Reports,
but
the
numbers
fluctuated,
and
we
could
not
develop
projections).
Exhibit
1
calculates
the
annual
respondent
hour
and
cost
burden
for
the
activities
examined.

Read
the
Instructions
Page
10
EPA
estimates
that
all
20,314
respondents
to
the
Biennial
Report
will
read
the
instructions
to
the
Site
ID
Form.
Annualized
over
the
two­
year
report
cycle,
this
results
in
10,157
respondents
reading
the
instructions
each
year.

Gather
Information
and
Prepare
Site
ID
Form
EPA
estimates
that
all
20,314
respondents
will
prepare
and
submit
a
Site
ID
Form
with
the
2001
Biennial
Report.
Annualized
over
the
two­
year
report
cycle,
this
results
in
10,157
respondents
preparing
and
submitting
a
Site
ID
Form
each
year.

In
estimating
the
hourly
burden
for
preparing
the
Site
ID
Form,
EPA
assumed
that
50
percent
of
all
the
Site
ID
Forms
would
be
pre­
populated
by
states
prior
to
distribution
to
respondents.
This
is
based
on
information
received
from
our
state
partners
in
the
Waste
Information
Needs
Initiative.
Respondents
receiving
these
pre­
populated
forms
need
only
review
and
update
the
data.
Page
11
EXHIBIT
1
THE
2001
SITE
IDENTIFICATION
FORMa
ESTIMATED
ANNUAL
RESPONDENT
HOUR
AND
COST
BURDEN
Hours
and
Costs
Per
Respondent
Total
Hours
and
Costs
Leg.
Mgr.
Tech.
Cler.
Respon.
Labor
Capital/
Number
of
Total
Total
INFORMATION
COLLECTION
$
108.00/
$
77.00/
$
57.00/
$
29.00/
Hours/
Cost/
Startup
O&
M
Respon.
Hours/
Cost/

ACTIVITY
Hour
Hour
Hour
Hour
Activity
Activity
Cost
Cost
Activities
Year
Year
Read
the
Site
ID
Form
instructions
0.00
0.33
0.33
0.00
0.66
$
44.22
$
0.00
$
0.00
10,157
6,704
$
449,143
Gather
information
and
prepare
Site
ID
Form
0.00
0.05
0.16
0.05
0.26
$
14.14
$
0.00
$
0.00
10,157
2,641
$
143,620
Submit
Site
ID
Form
to
State
or
Regional
EPA
Office
0.00
0.00
0.00
0.10
0.10
$
2.90
$
0.00
$
1.50
10,157
1,016
$
44,691
Maintain
a
copy
of
form
for
three
years
0.00
0.00
0.01
0.04
0.05
$
1.73
$
0.00
$
0.11
10,157
508
$
18,689
TOTAL
0.00
0.38
0.50
0.19
1.07
$
62.99
$
0.00
$
1.61
10,157
10,869
$
656,143
a
The
exhibit
contains
rounding.
Page
12
EXHIBIT
2
THE
2001
SITE
IDENTIFICATION
FORMa
ESTIMATED
ANNUAL
AGENCY/
STATE
HOUR
AND
COST
BURDEN
Hours
and
Costs
Per
Respondent
Total
Hours
and
Costs
Leg.
Mgr.
Tech.
Cler.
Respon.
Labor
Capital/
Number
of
Total
Total
INFORMATION
COLLECTION
$
67.44/
$
59.50/
$
42.80/
$
18.26/
Hours/
Cost/
Startup
O&
M
Respon.
Hours/
Cost/

ACTIVITY
Hour
Hour
Hour
Hour
Activity
Activity
Cost
Cost
Activities
Year
Year
Develop
Site
ID
Form
0.00
2.00
8.00
0.00
10.00
$
461.40
$
0.00
$
0.00
1
10
$
461
Distribute
and
review
Site
ID
Form
0.00
0.00
0.25
0.00
0.25
$
10.70
$
0.00
$
1.50
10,157
2,539
$
123,915
Enter
information
into
database
0.00
0.00
0.00
1.00
1.00
$
18.26
$
0.00
$
0.00
10,157
10,157
$
185,467
Process
information
0.00
0.00
0.00
0.25
0.25
$
4.57
$
0.00
$
0.00
10,157
2,539
$
46,417
TOTAL
0.00
Varies
Varies
Varies
Varies
Varies
$
0.00
Varies
Varies
15,245
$
356,260
a
The
exhibit
contains
rounding
Page
13
Respondents
receiving
blank
forms
would
have
to
complete
all
required
items,
as
specified
on
the
form.
EPA
estimates
the
average
hourly
burden
for
updating
the
pre­
populated
Site
ID
Form
as
0.17
hours
per
respondent,
and
for
completing
the
Site
ID
Form
in
its
entirety,
0.34
hours
per
respondent.

To
estimate
the
average
burden
per
respondent
in
preparing
a
Site
ID
Form,
EPA
used
the
weighted­
average
calculation
shown
in
Table
1.
EPA
multiplied
the
percentage
of
(
i)
prepopulated
Site
ID
Forms
by
the
average
burden
for
updating
the
information
contained
in
the
form
and
(
ii)
blank
forms
by
the
average
burden
for
completing
the
blank
form.
Then,
EPA
added
up
these
two
products
to
derive
an
overall
weighted­
average
burden.
This
weightedaverage
burden
(
0.26
hours/
form)
is
used
to
calculate
the
burden
to
all
respondents
in
completing
the
Site
ID
Form,
as
shown
in
Exhibit
1.

Table
1
Assumptions
and
Weighted­
Average
Equation
Used
in
Estimating
Burden
to
Prepare
the
Site
ID
Form
Assumptions
Weighted­
Average
Equation
0.17
hours
to
complete
pre­
populated
form;
50
percent
of
the
forms
are
pre­
populated
(
0.17
hours
x
0.50)
+
(
0.34
hours
x
0.50)
=
0.26
hours
0.34
hours
to
complete
blank
form;
50
percent
of
the
forms
are
blank
Submit
the
Hazardous
Waste
Report
to
State/
Region
EPA
expects
each
respondent,
10,157
per
year,
to
submit
the
Site
ID
Form
to
the
appropriate
State
or
Region.

Maintain
a
Copy
of
Each
Form
EPA
expects
sites
to
retain
an
estimated
10,157
Site
ID
Forms
each
year.

6(
e)
Bottom
Line
Hour
and
Cost
Tables
Respondent
Tally
Exhibit
3
presents
the
bottom
line
respondent
hour
and
cost
burden
for
preparing/
submitting
the
Site
ID
Form
with
the
2001
Hazardous
Waste
Report.
EPA
estimates
that
respondents
will
incur
an
annual
burden
of
about
10,869
hours
and
$
656,143.
Exhibit
3
also
presents
cost
estimates
by
type
(
labor,
capital/
startup,
or
O&
M)
as
well
as
two­
year
totals
for
hour
and
cost
burden
(
to
reflect
the
overall
burden
incurred
by
respondents
over
the
two­
year
period
covered
by
this
ICR).
7
This
is
an
approximation
of
the
burden
for
Form
IC.
The
1999
ICR
does
not
break
out
the
entire
burden
for
the
Form
IC
separate
from
the
rest
of
the
1999
Hazardous
Waste
Report.
For
purposes
of
comparison,
EPA
has
estimated
the
bottom
line
biennial
respondent
burden
for
Form
IC
to
consist
of
the
following:
[
12,466
hours
for
reading
the
instructions
+
6,358
hours
for
preparing
the
form
+
1,870
hours
for
submitting
the
form
+
936
hours
for
keeping
a
copy
=
21,630
hours.]
See
Exhibit
1
of
"
The
1999
Hazardous
Waste
Report,"
ICR
Number
976.09,
for
additional
information.

Page
14
EXHIBIT
3
THE
2001
SITE
IDENTIFICATION
FORMa
TOTAL
ESTIMATED
RESPONDENT
HOUR
AND
COST
SUMMARY
(
FROM
EXHIBIT
1)

Annual
Burden
Annual
Labor
Cost
Annual
Capital/
Startup
Cost
Annual
O&
M
Cost
Total
Annual
Cost
Total
10,869
$
639,790
$
0
$
16,353
$
656,143
2­
Year
Total
21,738
$
1,279,580
$
0
$
32,706
$
1,312,286
a
The
exhibit
contains
rounding
Agency
Tally
Exhibit
4
presents
the
bottom
line
Agency
hour
and
cost
burden
for
processing
Site
ID
Forms
submitted
with
the
2001
Hazardous
Waste
Report.
EPA
estimates
an
annual
Agency
burden
of
15,245
hours
and
$
356,260.
Exhibit
4
also
presents
cost
estimates
by
type
(
labor,
capital/
startup,
or
O&
M)
as
well
as
two­
year
totals
for
hour
and
cost
burden
(
to
reflect
the
overall
burden
incurred
by
the
Agency
over
the
two­
year
period
covered
by
this
ICR).

EXHIBIT
4
THE
2001
SITE
IDENTIFICATION
FORMa
TOTAL
ESTIMATED
AGENCY/
STATE
HOUR
AND
COST
SUMMARY
(
FROM
EXHIBIT
2)

Annual
Burden
Annual
Labor
Cost
Annual
Capital/
Startup
Cost
Annual
O&
M
Cost
Total
Annual
Cost
Total
15,245
$
341,025
$
0
$
15,235
$
356,260
2­
Year
Total
30,490
$
682,050
$
0
$
30,470
$
712,520
a
The
exhibit
contains
rounding
6(
f)
Reasons
For
Change
In
Burden
As
shown
in
Exhibit
3,
the
overall
(
two­
year)
respondent
burden
for
preparing
and
submitting
the
Site
ID
Form
with
the
2001
Hazardous
Waste
Report
is
21,738
hours.
This
represents
an
increase
of
108
hours
from
the
burden
for
the
1999
Form
IC
(
i.
e.,
21,630
hours7).
8
Respondents
receiving
blank
forms
must
complete
the
entire
form,
as
specified.

Page
15
This
increase
has
occurred
for
two
reasons.
This
ICR
assumes
that
50
percent
of
Site
ID
Forms
will
be
pre­
populated
by
States
prior
to
distribution
to
respondents.
Respondents
receiving
these
pre­
populated
forms
need
only
review
and
update
the
data
as
needed.
8
This
results
in
a
modest
savings
to
these
respondents
in
comparison
with
the
time
needed
to
prepare
their
1999
Form
IC.
However,
this
ICR
also
assumes
that
the
number
of
sites
completing
the
Site
ID
Form
in
2001
will
increase
over
1999
levels
(
i.
e.,
from
18,700
to
20,314).
This
increase
in
respondents
more
than
offsets
the
expected
savings
from
the
Site
ID
Form,
resulting
in
a
net
burden
increase
of
108
hours.

6(
g)
Burden
Statement
The
total
public
burden
for
the
Site
ID
Form,
when
submitted
with
the
2001
Hazardous
Waste
Report,
is
estimated
to
average
about
32
minutes
per
respondent
annually
(
the
total
respondent
burden
of
about
1
hour
annualized
over
two
years).
The
annual
reporting
burden
is
estimated
to
average
about
30
minutes
per
respondent,
and
includes
time
for
reviewing
the
Site
ID
Form
instructions,
gathering
data,
completing
and
reviewing
the
form,
and
submitting
the
form.
The
annual
recordkeeping
burden
is
estimated
to
average
about
two
minutes
per
respondent
annually,
and
includes
the
time
for
filing
and
storing
the
form.

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

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Director,
Collection
Strategies
Division,
U.
S.
Environmental
Protection
Agency
(
2822),
1200
Pennsylvania
Avenue,
N.
W.,
Washington,
D.
C.
20460;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
and
OMB
control
number
in
any
correspondence.
