SUPPORTING
STATEMENT
FOR
EPA
INFORMATION
COLLECTION
REQUEST
NUMBER
1597.06
"
REQUIREMENTS
AND
EXEMPTIONS
FOR
SPECIFIC
RCRA
WASTES"

October
26,
2004
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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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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2
3.
NONDUPLICATION,
CONSULTATIONS
AND
OTHER
COLLECTION
CRITERIA
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2
3(
a)
Nonduplication
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2
3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
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3
3(
c)
Consultations
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3
3(
d)
Effects
of
Less
Frequent
Collection
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3
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
COLLECTED
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4
4(
a)
Respondents
and
SIC/
NAICS
Codes
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4
4(
b)(
1)
Information
Requested
for
Universal
Waste
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5
A.
Notification
of
Universal
Waste
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5
(
i)
Data
Items
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5
(
ii)
Respondent
Activities
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6
B.
Labeling/
Marking
of
Universal
Waste
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6
(
i)
Data
Items
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6
(
ii)
Respondent
Activities
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6
C.
Accumulation
Time
Limits
for
Universal
Waste
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6
(
i)
Data
Items
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6
(
ii)
Respondent
Activities
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7
D.
Off­
Site
Shipments
of
Universal
Waste
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7
(
i)
Data
Items
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7
(
ii)
Respondent
Activities
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7
E.
Tracking
Shipments
of
Universal
Waste
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7
(
i)
Data
Items
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7
(
ii)
Respondent
Activities
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8
F.
Petitions
to
Include
Other
Wastes
under
40
CFR
Part
273
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8
(
i)
Data
Items
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8
(
ii)
Respondent
Activities
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8
4(
b)(
2)
Information
Requested
for
Mixed
Waste
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8
A.
Storage
and
Treatment
Conditional
Exemption
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8
(
i)
Data
Items
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8
(
ii)
Respondent
Activities
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9
B.
Loss
of
Storage
and
Treatment
Conditional
Exemption
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9
(
i)
Data
Items
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9
(
ii)
Respondent
Activities
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10
C.
Record
Keeping
for
Storage
and
Treatment
Conditional
Exemption
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10
(
i)
Data
Items
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10
(
ii)
Respondent
Activities
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10
D.
Transportation
and
Disposal
Conditional
Exemption
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10
(
i)
Data
Items
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10
(
ii)
Respondent
Activities
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11
E.
Loss
of
Transportation
and
Disposal
Conditional
Exemption
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11
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i)
Data
Items
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11
(
ii)
Respondent
Activities
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11
F.
Record
Keeping
for
Transportation
and
Disposal
Conditional
Exemption
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11
(
i)
Data
Items
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11
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ii)
Respondent
Activities
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12
5
THE
INFORMATION
COLLECTED
­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
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12
5(
a)
Agency
Activities
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12
5(
b)
Collection
Methodology
and
Management
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12
5(
c)
Small
Entity
Flexibility
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12
5(
d)
Collection
Schedule
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13
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
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13
6(
a)
Estimating
Respondent
Burden
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13
6(
b)
Estimating
Respondent
Costs
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.
.
13
(
i)
Estimating
Labor
Costs
.
.
.
.
.
.
.
.
.
.
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.
.
.
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.
.
.
.
13
(
ii)
Estimating
O&
M
Costs
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
.
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.
.
.
.
.
.
14
(
iii)
Estimating
Capital
Costs
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
.
.
.
.
.
.
.
.
.
14
6(
c)
Estimating
Agency
Burden
and
Cost
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
.
.
.
.
14
6(
d)(
1)
Estimating
the
Respondent
Universe
for
Universal
Waste
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
14
A.
Reading
the
Regulations
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
.
.
.
.
.
.
15
B.
Notification
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
15
C.
Labeling/
Marking
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
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.
.
.
.
.
.
.
.
15
D.
Storage
Time
Limits
.
.
.
.
.
.
.
.
.
.
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.
.
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.
.
.
.
.
.
15
E.
Off­
Site
Shipments
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
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.
.
.
.
.
.
.
.
.
15
F.
Responses
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
.
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.
.
.
.
.
.
.
.
15
G.
Tracking
Shipments
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
.
.
.
16
H.
Petitions
to
Include
Other
Wastes
under
40
CFR
Part
273
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
16
6(
d)(
2)
Estimating
the
Respondent
Universe
for
Mixed
Waste
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
16
A.
Storage
and
Treatment
Conditional
Exemption
Eligibility
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
16
B.
Reading
the
Regulations
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
17
C.
Loss
of
the
Storage
and
Treatment
Conditional
Exemption
.
.
.
.
.
.
.
.
.
.
.
.
.
.
17
D.
Record
Keeping
for
the
Storage
and
Treatment
Conditional
Exemption
.
.
.
.
.
17
E.
Transportation
and
Disposal
Conditional
Exemption
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
17
F.
Reading
the
Regulations
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
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.
.
.
.
.
.
.
.
.
.
.
.
.
18
G.
Notification
for
the
Transportation
and
Disposal
Conditional
Exemption
.
.
.
.
.
18
H.
Loss
of
the
Transportation
and
Disposal
Conditional
Exemption
.
.
.
.
.
.
.
.
.
.
18
I.
Record
Keeping
for
the
Transportation
and
Disposal
Conditional
Exemption
.
18
6(
e)
Bottom
Line
Burden
Hours
and
Costs
.
.
.
.
.
.
.
.
.
.
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.
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.
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.
18
(
i)
Respondent
Tally
.
.
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.
.
19
(
ii)
Agency
Tally
.
.
.
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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
Exhibit
1A
Reporting
and
Recordkeeping
Requirements
for
Universal
Waste
Handlers
and
Destination
Facilities
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
21
Exhibit
1B
Estimated
Annual
Respondent
Burden
and
Cost
for
the
Storage
and
Treatment
Conditional
Exemption
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
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.
.
.
.
.
.
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.
.
.
.
.
.
.
22
Exhibit
1C
Estimated
Annual
Respondent
Burden
and
Cost
for
the
Transportation
and
Disposal
Conditional
Exemption
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
23
Exhibit
2A
Universal
Waste
Handlers
and
Destination
Facilities
Annual
Respondent
Burden
and
Cost
Summary
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
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.
.
.
.
.
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.
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.
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.
.
.
.
.
.
.
.
.
24
Exhibit
2B
Total
Estimated
Annual
Respondent
Burden
and
Cost
Summary
for
the
Conditional
Exemptions
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
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.
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.
.
.
.
.
.
.
.
.
24
Exhibit
3A
Annual
Estimated
Agency
Burden
and
Cost
for
Universal
Waste
Requirements
.
.
.
.
.
25
Exhibit
3B
Estimated
Annual
Agency
Burden
and
Cost
for
the
Storage
and
Treatment
Conditional
Exemption
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
26
Exhibit
3C
Estimated
Annual
Agency
Burden
and
Cost
for
the
Transportation
and
Disposal
Conditional
Exemption
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
26
1
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
and
Number
of
Information
Collection
This
ICR
is
entitled
"
Reporting
and
Recordkeeping
Requirements
for
Certain
Waste­
Specific
Regulations",
ICR
number
1597.04.
This
ICR
consolidates
two
ICRs:
the
"
Reporting
and
Recordkeeping
Requirements
for
Universal
Waste,"
ICR
number
1597.05,
and
the
"
Storage,
Treatment,
Transportation,
and
Disposal
of
Mixed
Waste,"
ICR
number
1922.02
(
OMB
Control
Number
2050­
0181).

1(
b)
Short
Characterization/
Abstract
In
the
1976
Resource
Conservation
and
Recovery
Act
(
RCRA),
as
amended,
Congress
directs
the
U.
S.
Environmental
Protection
Agency
(
EPA)
to
develop
and
administer
a
comprehensive
program
for
the
safe
management
and
disposal
of
hazardous
waste.
In
1980,
EPA
promulgated
regulations
in
40
CFR
Part
261­
265
to
comply
with
RCRA.
EPA
has
since
added
to
these
regulations
on
many
occasions.

In
1995,
EPA
promulgated
regulations
in
40
CFR
Part
273
that
govern
the
collection
and
management
of
widely
generated
hazardous
wastes
known
as
"
Universal
Wastes".
Universal
Wastes
are
wastes
that
are
generated
in
non­
industrial
settings
by
a
vast
community,
and
are
present
in
nonhazardous
waste
management
systems.
Examples
of
Universal
Wastes
include
certain
batteries,
pesticides,
mercury­
containing
lamps
and
thermostats.
The
Part
273
regulations
are
designed
to
separate
Universal
Waste
from
the
municipal
wastestream
by
encouraging
individuals
and
organizations
to
collect
these
wastes
and
to
manage
them
in
an
appropriate
hazardous
waste
management
system.
EPA
distinguishes
two
types
of
handlers
of
Universal
Wastes:
small
quantity
handlers
of
Universal
Waste
(
SQHUW)
and
large
quantity
handlers
of
Universal
Waste
(
LQHUW).
SQHUWs
do
not
accumulate
more
than
5,000
kg
of
any
one
category
of
Universal
Waste
at
one
time,
while
LQHUWs
may
accumulate
quantities
at
or
above
this
threshold.
More
stringent
requirements
are
imposed
on
LQHUWs
because
of
greater
potential
environmental
risks.

In
2001,
EPA
promulgated
regulations
in
40
CFR
Part
266
that
provide
increased
flexibility
to
facilities
managing
wastes
commonly
known
as
"
Mixed
Waste".
Mixed
Waste
are
low­
level
mixed
waste
(
LLMW),
and
naturally
occurring
and/
or
accelerator­
produced
radioactive
material
(
NARM)
containing
hazardous
waste.
These
wastes
are
also
regulated
by
the
Atomic
Energy
Act.
As
long
as
specified
eligibility
criteria
and
conditions
are
met,
LLMW
and
NARM
are
exempt
from
the
definition
of
hazardous
waste
as
defined
in
Part
261.
Although
these
eligible
wastes
are
exempted
from
RCRA
manifest,
transportation,
and
disposal
requirements,
they
must
still
comply
with
the
manifest,
transportation,
and
disposal
requirements
under
the
Nuclear
Regulatory
Commission
(
NRC)
regulations,
or
NRC­
Agreement
State
regulations.
There
are
two
conditional
exemptions:

Storage
and
Treatment
Conditional
Exemption
This
conditional
exemption
for
storage
and
treatment
applies
to
any
generator
of
LLMW
who
is
licensed
by
NRC
or
an
NRC
Agreement
State
to
manage
radioactive
materials.
The
conditional
exemption
is
available
only
to
LLMW
generated
under
a
single
NRC
or
NRC
Agreement
State
license.
LLMW
generators
must
notify
EPA
of
the
LLMW
storage
units
for
which
they
are
claiming
an
exemption,
and
must
meet
the
conditions
listed
in
section
266.230.
The
exemption
is
valid
as
long
as
the
Mixed
Waste
meets
the
conditions,
remains
in
a
conditionally
exempt
storage
unit,
and
is
subject
to
NRC
regulation.

Transportation
and
Disposal
Conditional
Exemption
This
conditional
exemption
from
the
definition
of
hazardous
waste
applies
to
generators
and
treaters
who
send
their
treated
waste
to
a
commercial
low­
level
radioactive
waste
disposal
facility
(
LLRWDF)
licensed
by
NRC
or
NRC
Agreement
State.
The
eligible
LLMW
or
NARM
waste
would
be
exempted
from
RCRA
Subtitle
C
once
it
is
placed
on
the
transportation
vehicle
bound
for
disposal
at
the
LLRWDF.
The
waste
could
then
be
transported
to
the
LLRWDF
as
strictly
radioactive
waste
using
an
NRC
Uniform
LLW
Manifest.
Generators
and
treaters
under
2
the
exemption
must
undertake
the
information
collection
requirements
listed
in
section
266.345.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need
and
Authority
for
the
Collection
EPA
promulgated
the
Universal
Waste
regulations
at
Part
273
under
the
authority
of
Subtitle
C
of
RCRA.
EPA
needs
to
collect
information
to
ensure
that
Universal
Waste
is
being
managed
in
a
manner
protective
of
human
health
and
the
environment.
For
example,
EPA
needs
to
collect
notifications
of
Universal
Waste
management
from
LQHUWs
to
obtain
general
information
on
these
handlers
and
to
facilitate
enforcement
of
the
Part
273
regulations.
EPA
promulgated
labeling
and
marking
requirements
and
accumulation
time
limits
to
ensure
that
Universal
Waste
is
being
accumulated
responsibly.
EPA
needs
to
collect
information
on
illegal
Universal
Waste
shipments
to
enforce
compliance
with
applicable
regulations.
Finally,
EPA
requires
tracking
of
Universal
Waste
shipments
to
help
ensure
that
Universal
Waste
is
being
properly
treated,
recycled,
or
disposed.

EPA
promulgated
the
`
Storage,
Treatment,
Transportation
and
Disposal
of
Mixed
Waste"
rule
in
response
to
negotiations
with
commercial
nuclear
power
plants
and
their
trade
representatives.
The
industry
expressed
interest
in
regulatory
flexibility
to
allow
the
disposal
of
Mixed
Waste
in
commercial
low­
level
radioactive
waste
disposal
facilities
(
LLRWDFs)
as
a
RCRA­
exempt
waste.
The
negotiations
resulted
in
a
final
consent
decree,
which
required
EPA
to
publish
a
proposed
rule
that
requested
comment
on
an
exemption
from
the
RCRA
regulations
for
Mixed
Waste
generated
by
nuclear
power
plants.
The
final
rule
promulgated
the
conditional
exemptions,
which
have
been
revised
and
finalized
after
receipt
and
consideration
of
public
comments.

2(
b)
Use
and
Users
of
the
Data
EPA
uses
collected
information
to
ensure
that
Universal
Waste
is
being
managed
in
a
protective
manner.
This
data
aids
the
Agency
in
tracking
Universal
Waste
shipments
and
identifying
improper
management
practices.
In
addition,
information
kept
in
facility
records
helps
handlers
and
destination
facilities
to
ensure
that
they
and
other
facilities
are
managing
Universal
Waste
properly.
Finally,
petitions
submitted
under
sections
273.80
and
273.81
in
support
of
regulating
other
wastes
or
waste
categories
under
Part
273
help
EPA
to
compile
information
on
these
wastes,
and
to
determine
whether
regulation
as
a
Universal
Waste
is
appropriate.

EPA
has
developed
minimum
criteria
in
section
266.230
to
ensure
that
LLMW
generators
take
appropriate
steps
to
qualify
for
the
Storage
and
Treatment
Conditional
Exemption,
and
requires
that
generators
or
treaters
notify
EPA
or
the
Authorized
State
that
they
are
claiming
the
transportation
and
disposal
exemption
prior
to
the
initial
shipment
of
a
waste
to
a
LLRWDF.
Section
266.345(
a)
requires
that
generators
or
treaters
notify
EPA
or
the
Authorized
State
that
they
are
claiming
the
Transportation
and
Disposal
Conditional
Exemption
prior
to
the
initial
shipment
of
a
waste
to
a
LLRWDF.
This
exemption
notice
provides
a
tool
for
RCRA
program
regulatory
agencies
to
become
aware
of
the
generator's
exemption
claims.
The
information
contained
in
the
notification
package
provides
the
RCRA
program
regulatory
agencies
with
a
general
understanding
of
the
claimant.
This
information
also
allows
the
agencies
to
document
the
generator's
exemption
status
and
to
plan
inspections
and
review
exemption­
related
records.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
The
streamlined
requirements
for
Universal
Wastes
minimize
the
paperwork
activities
respondents
must
undertake
in
relation
to
the
full
hazardous
waste
program,
and
enable
them
to
follow
standard
industry
practices
and
other
Federal
agency
requirements,
where
appropriate,
to
satisfy
the
Universal
Waste
requirements.
For
example,
LQHUWs
may
use
a
log,
invoice,
bill
of
lading,
or
other
shipping
document
to
track
off­
site
shipments
received
and
sent
(
i.
e.,
in
lieu
of
a
RCRA
manifest).
As
such,
the
Universal
Waste
requirements
minimize
the
potential
for
duplication
with
other
paperwork
3
requirements
of
EPA's
and
other
Federal
agencies'
regulatory
programs.

The
information
collected
for
LLMW
or
NARM
waste
eligible
for
the
conditional
exemptions
is
not
available
from
any
existing
sources
of
information.
Furthermore,
the
exemptions
are
self­
implementing,
and
intended
to
provide
relief
to
respondents
from
duplicative
information
collection
requirements.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
In
compliance
with
the
Paperwork
Reduction
Act
of
1995,
EPA
issues
public
notices
in
the
Federal
Register
taking
comment
on
our
intent
to
renew
ICRs.
On
April
26,
2004
EPA
issued
a
public
notice
in
the
Federal
Register
on
the
Mixed
Waste
ICR
renewal
(
69
FR
22507),
and
on
June
25,
2004
EPA
issued
a
public
notice
on
the
Universal
Waste
ICR
renewal
(
69
FR
35594).
EPA
received
no
comments
in
response
to
either
of
the
Federal
Register
notices.

3(
c)
Consultations
As
noted
above,
EPA
published
two
separate
Federal
Register
notices
for
both
the
Universal
Waste
ICR
renewal
and
the
Mixed
Waste
ICR
renewal.
EPA
also
conducted
separate
consultations
with
both
entities
that
implement
the
Universal
Waste
requirements,
and
with
facilities
that
generate
Mixed
Waste.
EPA
decided
to
consolidate
these
two
ICRs
after
these
consultations
had
already
taken
place.
No
more
than
nine
facilities
were
contacted
for
either
ICR
renewal.

Organizations
Contacted
in
Updating
the
Universal
Waste
Portion
of
the
ICR
Trade
Organizations
and
Recyclers
Association
of
Lighting
and
Mercury
Recyclers
Retrofit
Co.
USAg
Recycling
States
Alabama
Department
of
Environmental
Management
Florida
Department
of
Environmental
Protection
Georgia
Environmental
Protection
Division
Oregon
Department
of
Environmental
Quality
West
Virginia
Division
of
Environmental
Protection
Organizations
and
Individuals
Contacted
in
Updating
the
Mixed
Waste
Portion
of
the
ICR
Universities
Penn
State
University
Mark
Linsley
814­
865­
3450
University
of
Notre
Dame
Robert
Zerr
574­
631­
5037
Industries
DuPont
Pharmaceuticals
Company
David
Timmins
302­
774­
8056
Merck
&
Company,
Inc.
Renee
Richardson
908­
423­
7813
Commercial
TSDFs
Diversified
Scientific
Services
Richard
Franco
865­
376­
0084
Onyx
Environmental
Services
Greg
Siedor
630­
218­
1635
3(
d)
Effects
of
Less
Frequent
Collection
For
both
waste
categories,
EPA
has
carefully
considered
the
burden
imposed
upon
the
regulated
community
by
the
regulations.
EPA
is
confident
that
those
activities
required
of
respondents
are
necessary
and
has
attempted
to
minimize
the
burden
imposed.
For
the
Universal
Waste
requirements,
EPA
believes
strongly
that
if
the
minimum
requirements
specified
under
the
regulations
are
not
met,
1
SIC
codes
and
the
corresponding
NAICS
codes
can
be
found
in
the
Federal
Register
at
61
FR
57006,
November
5,
1996.
Note
that
an
SIC
code
may
have
many
corresponding
NAICS
codes.
EPA
used
its
best
judgement
to
list
the
most
relevant
NAICS
codes
in
Table
1.

4
neither
the
facilities
nor
EPA
can
ensure
that
Universal
Waste
is
being
managed
in
a
manner
protective
of
human
health
and
the
environment.
For
the
Mixed
Waste
exemptions,
these
requirements
constitute
the
minimum
amount
of
reporting
that
could
be
required
while
still
maintaining
some
level
of
EPA
supervision.

3(
e)
General
Guidelines
This
ICR
adheres
to
the
guidelines
stated
in
the
1995
Paperwork
Reduction
Act,
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
define
EPA's
general
policy
on
the
public
disclosure
of
information,
contain
provisions
for
confidentiality.

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

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents
and
SIC/
NAICS
Codes
Table
1
presents
a
list
of
Standard
Industrial
Classification
(
SIC)
codes
associated
with
industries
most
likely
affected
by
the
information
collection
requirements
covered
under
this
ICR
for
both
Universal
Waste
and
Mixed
Waste.
Also
shown
are
the
North
American
Industrial
Classification
System
(
NAICS)
codes
that
correspond
to
the
SIC
codes
listed.
1
Table
1
List
of
SIC
and
NAICS
Codes
Description
SIC
Codes
NAICS
Codes
Crop
Production
01
011
Soil
Preparation
0711
115112
Crop
Services
and
Harvesting
072
115113
Landscape
Services
078
54132
56173
Forestry
and
Logging
08
113
1153
Plumbing,
Heating,
and
Air
Conditioning
171
23511
Wrecking
and
Demolition
Work
1795
23594
Textile
Mills
22
313
Pulp
Mills
261
3221
Paper
Manufacturing
266
322
Printing
and
Publishing
27
323
Inorganic
Chemicals
Manufacturing
281
32518
Plastics
and
Synthetic
Resins
282
325212
Description
SIC
Codes
NAICS
Codes
5
Pharmaceutical
and
Medicine
Manufacturing
283
3254
Soap,
Detergents,
etc.
284
325611
Paints,
Varnishes,
etc.
285
32551
Organic
Chemicals
Manufacturing
286
32519
Pesticides,
Fertilizers,
and
Other
Agricultural
Chemical
Manufacturing
287
3253
Plastics
and
Rubber
Product
Manufacturing
30
326
Leather
Tanning
and
Finishing
3111
31611
Ceramic
Wall
and
Floor
Tile
3253
327122
Asbestos
Products
including
brake
linings
3292
33634
327999
Primary
Metal
Industries
33
331
Fabricated
Metal
Products
34
332
Industrial
and
Commercial
Machinery
and
Computer
Equipment
35
333
334
Electronics
and
Other
Electrical
Equipment
and
Components,
Except
Computer
36
335
Transportation
Equipment
37
336
Medical
Equipment,
Including
Ophthalmic
Goods
3851
33911
Miscellaneous
Manufacturing
39
339
Rail
Transportation
401
482
Transit
and
Ground
Passenger
Transportation
41
485
Motor
Freight
Transportation
Warehousing
42
484
493
Air
Transportation
45
481
Electric,
Gas,
and
Sanitary
Services
49
221
Scrap
and
Waste
Materials
5093
42193
Wholesale
Petroleum
Marketing
517
4543
4227
Automobile
Dealers
551
4411
Dry
Cleaning
and
Laundry
Services
721
8123
Photographic
Studios
722
541921
Funeral
Services
and
Crematories
726
8122
Miscellaneous
Business
Service
739
561439
Automotive
Repair
Services
753
8111
Motion
Picture
and
Video
Industries
781
5121
Services
to
Buildings
and
Dwellings
734
5617
Health
Services
80
62
Colleges,
Universities,
Professional
Schools,
and
Junior
Colleges
822
61121
61131
Research,
Development,
and
Testing
Services
873
5417
5419
Other
Services
8999
54169
54199
National
Security
971
92811
Nonclassifiable
Establishments
9999
N/
A
4(
b)(
1)
Information
Requested
for
Universal
Waste
6
A.
Notification
of
Universal
Waste
(
i)
Data
Items
Section
273.32
requires
LQHUWs
to
send
written
notification
of
Universal
Waste
management
to
the
Regional
Administrator,
and
receive
an
EPA
identification
number,
before
exceeding
the
5,000
kilogram
accumulation
limit
of
Universal
Waste.
(
Sections
273.32(
a)(
2)
and
(
3),
however,
exempt
LQHUWs
from
this
requirement
if
they
have
already
notified
EPA
of
either
hazardous
waste
activities
under
RCRA
or
pesticide
management
under
FIFRA.)

The
notification
must
include
the
following
data
items:

°
Universal
Waste
handler's
name
and
address
(
§
273.32(
b)(
1));

°
Name
and
phone
number
of
the
contact
person
at
the
Universal
Waste
handler's
site
(
§
273.32(
b)(
2));

°
Location
of
the
Universal
Waste
management
activities
(
§
273.32(
b)(
3));

°
A
list
of
all
types
of
Universal
Waste
managed
(
§
273.32(
b)(
4));
and
°
A
statement
that
5,000
kilograms
or
more
of
waste
are
accumulated
at
one
time,
and
a
description
of
the
types
of
waste
accumulated
above
this
quantity
(
§
273.32(
b)(
5)).

(
ii)
Respondent
Activities
Prepare
and
send
written
notification
of
Universal
Waste
management.

B.
Labeling/
Marking
of
Universal
Waste
(
i)
Data
Items
Sections
273.14
and
273.34
require
SQHUWs
and
LQHUWs,
respectively,
to
label
or
mark
their
Universal
Waste.
The
information
must
identify
the
type
of
waste,
and
be
provided
on
the
waste
itself,
or
the
container,
tank,
or
transport
vehicle
in
which
the
waste
is
contained
(
§
§
273.14
and
273.34).

(
ii)
Respondent
Activities
Label
or
mark
the
Universal
Waste
to
identify
the
type
of
waste.

C.
Accumulation
Time
Limits
for
Universal
Waste
(
i)
Data
Items
Sections
273.15
and
273.35
require
SQHUWs
and
LQHUWs,
respectively,
to
demonstrate
the
length
of
time
that
the
Universal
Waste
has
been
accumulated
from
the
date
it
was
received
or
became
a
waste.
The
demonstration
may
be
made
by
using
any
of
the
following
methods:

°
Placing
the
Universal
Waste
in
a
container
and
marking
or
labeling
the
container
with
the
earliest
date
that
any
Universal
Waste
in
the
container
became
a
waste
or
was
received
(
§
273.15(
c)(
1)
or
§
273.35(
c)(
1));

°
Marking
or
labeling
the
individual
item
of
Universal
Waste
with
the
date
it
became
a
waste
or
was
received
(
§
273.15(
c)(
2)
or
§
273.35(
c)(
2));

°
Maintaining
an
inventory
system
on­
site
that
identifies
the
date
the
Universal
Waste
7
being
accumulated
became
a
waste
or
was
received
(
§
273.15(
c)(
3)
or
§
273.35(
c)(
3));

°
Maintaining
an
inventory
system
on­
site
that
identifies
the
earliest
date
any
Universal
Waste
in
a
group
of
Universal
Waste
items
or
a
group
of
containers
of
Universal
Waste
became
a
waste
or
was
received
(
§
273.15(
c)(
4)
or
§
273.35(
c)(
4));

°
Placing
the
Universal
Waste
in
a
specific
accumulation
area
and
identifying
the
earliest
date
that
any
Universal
Waste
in
the
area
became
a
waste
or
was
received
(
§
273.15(
c)(
5)
or
§
273.35(
c)(
5));
or
°
Any
other
method
approved
in
advance
by
the
Regional
Administrator
or
the
State
Director
(
§
273.15(
c)(
6)
or
§
273.35(
c)(
6)).

(
ii)
Respondent
Activities
Demonstrate
the
length
of
time
that
Universal
Waste
has
been
accumulated
since
it
became
a
waste
or
was
received.

D.
Off­
Site
Shipments
of
Universal
Waste
(
i)
Data
Items
Sections
273.18(
f),
273.38(
f),
and
273.61(
b)
require
SQHUWs,
LQHUWs,
and
destination
facilities,
respectively,
to
notify
a
Universal
Waste
handler
if
a
shipment
or
a
portion
of
a
shipment
is
rejected.
Sections
273.18(
g),
273.38(
g),
and
273.61(
c)
require
SQHUWs,
LQHUWs,
and
destination
facilities,
respectively,
to
notify
the
regional
EPA
office
of
any
illegal
shipment
of
waste.
The
data
items
required
for
rejection
notifications
or
illegal
shipment
notifications
are:

°
Notification
to
the
originating
handler
of
the
rejection
of
the
shipment
(
§
§
273.18(
f),
273.38(
f),
or
273.61(
b));
and/
or
°
Notification
to
EPA
of
the
illegal
shipment,
including
the
name,
address,
and
phone
number
of
the
originating
shipper
(
§
§
273.18(
g),
273.38(
g),
and
273.61(
c)).

(
ii)
Respondent
Activities
°
If
necessary,
prepare
and
submit
a
notice
of
rejection
of
shipment
to
the
originating
handler;
and/
or
°
If
necessary,
prepare
and
submit
a
notice
of
illegal
shipment
to
EPA.

E.
Tracking
Shipments
of
Universal
Waste
(
i)
Data
Items
Sections
273.39
and
273.62
require
LQHUWs
and
destination
facilities,
respectively,
to
maintain
records
of
each
Universal
Waste
shipment
received
and
sent,
and
to
retain
those
records
for
a
period
of
three
years
from
the
day
of
receipt
or
sending
of
the
shipment.
The
following
information
is
required
in
the
records:

For
shipments
received
on
site,
data
items
must
consist
of:

°
The
name
and
address
of
the
originating
Universal
Waste
handler
from
whom
the
waste
was
sent
(
§
§
273.39(
a)(
1)
and
273.62(
a)(
1));

°
The
quantity
of
each
type
of
Universal
Waste
received
(
§
§
273.39(
a)(
2)
and
273.62(
a)(
2));
and
8
°
The
date
the
Universal
Waste
was
received
(
§
§
273.39(
a)(
3)
and
273.62(
a)(
3)).

For
shipments
sent
off­
site
for
further
management,
data
items
must
consist
of:

°
The
name
and
address
of
the
Universal
Waste
handler
to
whom
the
waste
was
sent
(
§
§
273.39(
b)(
1)
and
273.62(
b)(
1));

°
The
quantity
of
each
type
of
Universal
Waste
sent
(
§
§
273.39(
b)(
2)
and
273.62(
b)(
2));
and
°
The
date
the
Universal
Waste
was
sent
(
§
§
273.39(
b)(
3)
and
273.62(
b)(
3)).

(
ii)
Respondent
Activities
°
For
shipments
received
on
site,
maintain
records
for
a
period
of
three
years.

°
For
shipments
sent
off­
site,
maintain
records
for
a
period
of
three
years.

F.
Petitions
to
Include
Other
Wastes
under
40
CFR
Part
273
(
i)
Data
Items
Section
273.80
allows
any
person
to
petition
EPA
for
an
amendment
to
add
a
hazardous
waste
or
category
of
hazardous
waste
to
the
Universal
Waste
regulations
in
40
CFR
Part
273.
The
petitioner
must
demonstrate
that
regulation
under
part
273
is:
(
1)
appropriate
for
the
waste
or
category
of
waste,
(
2)
will
improve
management
practices
for
the
waste
or
category
of
waste,
and
(
3)
will
improve
implementation
of
the
hazardous
waste
program.
The
demonstration
must
include:

°
A
description
of
the
need
for
regulation
and
regulatory
impacts
(
§
273.80(
b)).

°
Information
required
under
40
CFR
260.20(
b)

°
Information
addressing
the
factors
listed
in
40
CFR
273.81.

(
ii)
Respondent
Activities
Prepare
and
submit
a
petition
supporting
regulation
of
a
waste
or
waste
category
under
Part
273.

4(
b)(
2)
Information
Requested
for
Mixed
Waste
A.
Storage
and
Treatment
Conditional
Exemption
(
i)
Data
Items
Facilities
seeking
the
mixed
waste
storage
and
treatment
exemption
must
provide,
or
conduct
and
maintain
the
following,
as
required
by
§
266.230:

°
A
written
notification
submitted
by
certified
delivery
stating
that
the
facility
intends
to
claim
the
conditional
exemption
for
LLMW
stored
at
the
facility.
The
dated
notification
must
include
the
facility
name,
address,
RCRA
identification
number,
NRC
or
NRC
Agreement
State
license,
the
waste
code(
s)
and
storage
unit(
s)
for
which
the
facility
is
seeking
an
exemption,
and
a
statement
that
the
facility
meets
the
conditions
of
this
part.
The
notification
must
be
signed
by
the
facility's
authorized
representative
certifying
that
the
information
in
the
claim
is
true,
accurate,
and
complete.
The
notification
must
be
9
submitted
within
90
days
of
the
effective
date
of
this
rule
in
each
State,
or
within
90
days
of
when
a
storage
unit
is
first
used
to
store
conditionally
exempt
LLMW,
as
required
by
§
266.230(
a);

°
A
certification
that
facility
personnel
who
manage
stored
conditionally
exempt
LLMW
are
trained
in
a
manner
that
ensures
that
the
conditionally
exempt
waste
is
safely
managed
and
includes
training
in
chemical
waste
management
and
hazardous
materials
incidents
response
that
meets
the
personnel
training
standards
found
in
40
CFR
265.16(
a)(
3),
as
required
by
§
266.230(
b)(
3);

°
An
inventory
of
stored
conditionally
exempt
LLMW
(
conducted
at
least
annually),
as
required
by
§
266.230(
b)(
4);

°
Inspections
of
stored
conditionally
exempt
LLMW
for
compliance
with
the
conditions
listed
in
Part
266
Subpart
N
(
conducted
at
least
quarterly),
as
required
by
§
266.230(
b)(
4);
and
°
An
accurate
emergency
plan
describing
emergency
response
arrangements
with
local
authorities
and
evacuation
plans;
listing
the
names,
addresses,
and
telephone
numbers
of
all
facility
personnel
qualified
to
work
with
local
authorities
as
emergency
coordinators;
and
listing
emergency
equipment,
as
required
by
§
266.230(
b)(
5).

(
ii)
Respondent
Activities
°
Prepare
and
submit
by
certified
delivery
the
notification
of
intent
to
claim
the
conditional
exemption
for
LLMW
stored
at
the
facility;

°
Prepare
the
certification
that
facility
personnel
have
been
appropriately
trained;

°
Inventory
conditionally
exempt
LLMW
and
record
findings
(
at
least
annually);

°
Conduct
compliance
inspections
of
conditionally
exempt
LLMW
and
record
findings
(
at
least
quarterly);
and
°
Maintain
an
emergency
plan
on
site
and
provide
it
to
all
local
emergency
response
authorities
who
may
have
to
respond
to
a
fire,
explosion,
or
release
of
hazardous
waste
or
hazardous
constituents.

B.
Loss
of
Storage
and
Treatment
Conditional
Exemption
(
i)
Data
Items
Facilities
that
lose
the
exemption
for
their
conditionally
exempt
LLMW
because
they
no
longer
meet
the
requirements
in
§
266.230
must
provide
the
following,
as
required
by
§
266.240:

°
A
written
notification
submitted
by
certified
delivery
within
30
days
of
becoming
aware
of
the
failure
informing
EPA
or
the
Authorized
State
and
the
NRC
or
oversight
agency
in
the
NRC
Agreement
State
of
the
condition(
s)
the
facility
failed
to
meet,
a
description
of
the
LLMW
(
including
the
waste
name,
hazardous
waste
codes,
and
the
quantity),
the
storage
location
at
the
facility,
and
the
date(
s)
on
which
the
facility
failed
to
meet
the
conditions,
as
required
by
§
266.240(
a)(
1);
and
°
If
the
failure
may
endanger
human
health
or
the
environment,
an
oral
notification
to
EPA
or
the
Authorized
State,
within
24
hours
of
learning
of
the
failure,
followed
by
a
written
notification
within
five
days,
as
required
by
§
266.240(
a)(
2).

In
order
to
reclaim
an
exemption
for
LLMW,
a
facility
must
provide
a
notice
signed
by
the
10
facility's
authorized
representative
and
submitted
by
certified
delivery
to
EPA
or
the
Authorized
State
as
required
by
§
266.245(
a)(
2).
This
notice
must
include
the
following:

°
An
explanation
of
the
circumstances
of
the
failure(
s);

°
Certification
that
all
failures
that
caused
the
facility
to
lose
the
exemption
for
its
LLMW
have
been
corrected
and
that
the
facility
again
meets
all
of
the
conditions
in
§
266.230
as
of
the
date
specified;

°
A
description
of
the
plan
implemented,
listing
specific
steps
taken,
to
ensure
the
conditions
will
be
met
in
the
future;
and
°
Any
additional
information
the
facility
would
like
to
submit.

(
ii)
Respondent
Activities
°
Prepare
and
submit
by
certified
delivery
the
written
notification
of
exemption
loss;

°
Inform
the
EPA
Region
or
the
Authorized
State
of
the
failure
(
orally
and
follow­
up
written
notification)
in
cases
of
endangerment
to
human
health
or
the
environment;
and
°
Prepare
and
submit
by
certified
delivery
the
notice
reclaiming
the
exemption
for
LLMW.

C.
Record
Keeping
for
Storage
and
Treatment
Conditional
Exemption
(
i)
Data
Items
In
addition
to
those
records
required
by
the
NRC
or
NRC
Agreement
State
license,
all
facilities
subject
to
the
mixed
waste
exemption
requirements
must
develop
and
maintain
the
following
as
required
by
§
266.250:

°
Initial
notification
records,
return
receipts,
reports
to
EPA
or
the
Authorized
State
of
failure(
s)
to
meet
the
exemption
conditions,
and
all
records
supporting
any
reclaim
of
an
exemption;

°
Records
of
LLMW
annual
inventories,
and
quarterly
inspections;

°
Certification
that
facility
personnel
who
manage
stored
mixed
waste
are
trained
in
safe
management
of
LLMW
including
training
in
chemical
waste
management
and
hazardous
materials
incidents
response;
and
°
Emergency
plan
as
specified
in
§
266.230(
b).

(
ii)
Respondent
Activities
Maintain
and
update
records
of
notifications,
return
receipts,
failure
report(
s),
inventories,
inspections,
certifications,
and
the
emergency
plans.

D.
Transportation
and
Disposal
Conditional
Exemption
(
i)
Data
Items
Facilities
claiming
a
Transportation
and
Disposal
Conditional
Exemption
must
provide
the
following,
as
required
by
§
266.345(
a)
and
(
b):

°
A
written
notification
submitted
to
EPA
or
the
Authorized
State
by
certified
delivery
prior
to
the
first
shipment
of
waste
to
the
LLRWDF
that
states
that
the
facility
is
claiming
the
11
Transportation
and
Disposal
Conditional
Exemption.
The
notification
must
include
the
date
and
the
facility
name,
address,
phone
number,
and
RCRA
ID
number,
as
required
by
§
266.345(
a).

°
A
notification
sent
by
certified
delivery
to
the
LLRWDF
prior
to
each
shipment
of
exempted
waste,
as
required
by
§
266.345(
b).

(
ii)
Respondent
Activities
Prepare
and
submit
the
notification
to
EPA
or
the
Authorized
State
and
prepare
and
submit
the
LLRWDF
notifications.

E.
Loss
of
Transportation
and
Disposal
Conditional
Exemption
(
i)
Data
Items
Owners
or
operators
of
facilities
who
fail
to
satisfy
any
of
the
conditions
for
the
transportation
and
disposal
exemption
for
their
waste
must
provide
the
following:

°
A
report
signed
by
the
facility's
authorized
representative
and
submitted
by
certified
delivery
within
30
days
of
becoming
aware
of
the
failure,
as
required
by
§
266.355(
a)(
1).

°
A
description
of
the
waste
(
including
the
waste
name,
hazardous
waste
codes
and
quantity)
that
lost
the
exemption;
and
°
The
date(
s)
on
which
the
facility
failed
to
meet
the
condition(
s)
for
the
waste.

°
If
the
failure
may
endanger
human
health
or
the
environment,
oral
notification
to
EPA
or
the
Authorized
State
within
24
hours,
followed
by
a
notification
within
five
days,
as
required
by
§
266.355(
a)(
2).

To
reclaim
the
Transportation
and
Disposal
Conditional
Exemption
for
the
waste,
another
notification
must
be
signed
by
the
facility's
authorized
representative
and
submitted
by
certified
delivery,
as
required
by
§
266.360(
a)(
2).
This
notification
must
include:

°
An
explanation
of
the
circumstances
of
each
failure;

°
A
certification
that
all
failures
that
caused
the
facility
to
lose
the
exemption
for
the
waste
have
been
corrected
and
that
the
facility
again
meets
all
of
the
applicable
conditions
for
the
waste
as
of
the
date
specified;

°
A
description
of
the
plan
implemented,
listing
specific
steps
taken,
to
ensure
the
conditions
will
be
met
in
the
future;
and
°
Any
additional
information
the
facility
would
like
to
submit.

(
ii)
Respondent
Activities
°
Prepare
and
submit
by
certified
delivery
the
report
of
the
failure;

°
Inform
EPA
or
the
Authorized
State
of
the
failure
(
orally
and
follow­
up
notification)
in
cases
of
endangerment
to
human
health
or
the
environment;
and
°
Prepare
and
submit
by
certified
delivery
the
notice
for
reinstatement.

F.
Record
Keeping
for
Transportation
and
Disposal
Conditional
Exemption
12
(
i)
Data
Items
In
addition
to
those
records
required
by
the
NRC
or
NRC
Agreement
State
license,
facilities
must
develop
and
maintain
the
following
items,
as
required
in
§
266.350:

°
All
applicable
existing
records
required
under
§
§
264.73,
265.73,
and
268.7
to
demonstrate
that
the
facility's
waste
has
met
LDR
treatment
standards
prior
to
claiming
the
exemption.
[
These
are
existing
recordkeeping
requirements
and
are
not
burdened
in
this
ICR.]

°
A
copy
of
all
notifications
and
return
receipts
sent
under
§
§
266.355
and
266.360
for
three
years
after
the
exempted
waste
is
sent
for
disposal;

°
A
copy
of
all
notifications
and
return
receipts
required
by
§
266.345(
a)
for
three
years
after
the
last
exempted
waste
is
sent
for
disposal;

°
A
copy
of
the
notification
and
return
receipt
required
by
§
266.345(
b)
for
three
years
after
the
exempted
waste
is
sent
for
disposal;
and
°
If
the
facility
or
its
waste
is
not
already
subject
to
NRC
or
NRC
Agreement
State
equivalent
manifest
and
transportation
regulations
for
the
shipment
of
its
waste,
it
must
keep
a
copy
of
all
other
documents
related
to
tracking
the
exempted
waste
as
required
under
10
CFR
20.2006
or
NRC
Agreement
State
equivalent
regulations,
including
applicable
NARM
requirements,
in
addition
to
the
records
specified
in
§
266.350(
a)
through
(
d).

(
ii)
Respondent
Activities
Copy,
when
necessary,
and
maintain
the
records
listed
above.

5.
THE
INFORMATION
COLLECTED
­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
For
the
Universal
Waste
requirements,
most
information
required
of
Universal
Waste
handlers
is
maintained
in
records
and
therefore
is
not
formally
submitted
to
EPA.
For
the
information
that
is
submitted,
the
Agency:
reviews
and
files
notifications
of
Universal
Waste
management;
sends
an
EPA
identification
number
to
Universal
Waste
handlers
who
wish
to
exceed
the
5,000
kilogram
limit
on
accumulation;
enters
notification
information
into
a
database;
reviews
and
files
notices
of
rejected
or
illegal
waste
shipments;
review
petitions
supporting
regulation
of
a
waste
or
category
of
waste
under
the
Part
273
Universal
Waste
regulations;
prepares
and
sends
a
written
decision
to
the
petitioner;
and
compiles
and
files
all
information
on
the
petition.

For
Mixed
Waste
exemptions,
EPA
reviews
notifications
of
intent
to
claim
an
exemption,
reviews
the
written
notification
of
exemption
loss,
reviews
the
oral
and
written
follow
up
notice
if
the
failure
endangers
human
health
or
the
environment;
and
reviews
notices
reclaiming
an
exemption.

5(
b)
Collection
Methodology
and
Management
For
the
Universal
Wastes
requirements,
most
information
can
be
maintained
in
facility
records
rather
than
in
submittals
to
EPA.
For
the
information
that
must
be
submitted,
EPA
ensures
the
accuracy
and
completeness
of
the
collected
information
by
reviewing
each
submittal.
EPA
enters
information
into
a
database
and
aggregates
data
to
monitor
the
Universal
Waste
program.

For
the
Mixed
Waste
exemptions,
the
reporting
requirements
are
not
intended
to
provide
EPA
with
data
it
will
use
for
research;
rather,
they
are
intended
to
serve
as
tools
by
which
the
Agency
and
13
respondents
can
monitor
compliance
and
assure
that
the
conditions
of
the
exemption
are
met.
EPA
only
reviews
notifications
submitted
by
respondents
and,
if
necessary,
notify
them
of
any
actions
taken
by
the
Agency
or
required
of
the
respondent.

5(
c)
Small
Entity
Flexibility
For
the
Universal
Waste
requirements,
EPA
exempted
SQHUWs
from
several
administrative
requirements.
For
example,
EPA
does
not
require
SQHUWs
to
submit
notifications
of
Universal
Waste
management,
or
to
obtain
an
EPA
identification
number.
EPA
also
does
not
require
SQHUWs
to
track
(
keep
records
of)
their
Universal
Waste
shipments.
EPA
believes
these
exemptions
encourage
small
businesses
to
safely
manage
Universal
Waste
in
compliance
with
Part
273.
In
addition,
EPA
allows
Universal
Waste
generators
to
count
their
monthly
generation
of
Universal
Wastes
separately
from
their
other
hazardous
wastes
in
determining
their
regulated
status
under
40
CFR
261.5.
Generators
who
generate
100
kilograms
of
Universal
Waste
or
less
in
a
calendar
month
may
comply
with
the
Universal
Waste
regulations
or
the
exemption
in
section
261.5.

For
the
Mixed
Waste
exemptions,
the
information
collection
requirements
do
not
adversely
impact
small
entities.
The
exemptions
are
self­
implementing
and
intended
to
provide
regulatory
relief.
Facilities
would
not
claim
the
exemption
for
the
waste
unless,
by
doing
so,
they
expect
to
save
time
and/
or
money.
Additionally,
these
requirements
apply
equally
to
small
and
large
entities
and
will
not
impose
a
disproportionate
burden
on
either.

5(
d)
Collection
Schedule
For
the
Universal
Waste
requirements,
EPA
expects
LQHUWs
to
submit
notifications
of
Universal
Waste
management
before
they
meet
or
exceed
the
5,000
kilogram
accumulation
limit.
EPA
expects
any
Universal
Waste
handler
to
notify
EPA
if
it
receives
an
illegal
shipment
of
waste.
EPA
expects
to
receive
petitions
under
sections
273.80
and
273.81
if
and
when
an
organization
believes
that
a
waste
or
category
of
waste
should
be
subject
to
the
Part
273
Universal
Waste
regulations
rather
than
full
Subtitle
C
requirements.

For
the
Mixed
Waste
exemptions,
respondents
wishing
to
claim
a
storage
or
treatment
exemption
for
their
LLMW
must
do
so
within
90
days
of
the
date
on
which
the
unit
is
first
used
to
store
conditionally
exempt
LLMW.
If
a
facility
fails
to
meet
any
of
the
conditions
specified
in
section
266.230,
the
facility
must
report
to
EPA
or
the
Authorized
State
and
the
NRC
or
the
oversight
agency
in
the
NRC
Agreement
State
in
writing
by
certified
delivery
within
30
days
of
learning
of
the
failure,
as
required
by
section
266.240(
a)(
1).
If
the
failure
to
meet
any
of
the
conditions
may
endanger
human
health
or
the
environment,
the
facility
must
notify
EPA
or
the
Authorized
State
orally
(
within
24
hours)
and
follow
up
with
written
notification
within
five
days,
as
required
by
section
266.240(
a)(
2).
Respondents
wishing
to
claim
a
transportation
and
disposal
exemption
may
do
so
any
time
they
generate
a
waste
stream
that
meets
the
conditions
of
the
exemption.
They
must
submit
a
notification
to
EPA
or
the
Authorized
State
prior
to
the
initial
shipment
claiming
the
exemption.
In
addition,
for
wastes
that
no
longer
meet
the
conditions
for
exemption,
a
respondent
has
30
days
after
learning
of
the
failure
to
submit
a
notification,
as
required
by
section
266.355(
a)(
1).
If
the
failure
to
meet
any
of
the
conditions
may
endanger
human
health
or
the
environment,
the
facility
must
also
immediately
notify
EPA
or
the
Authorized
State
orally
within
24
hours
and
follow
up
with
a
notification
within
five
days,
as
required
by
section
266.355(
a)(
2).

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
COLLECTION
6(
a)
Estimating
Respondent
Burden
The
respondent
burden
estimates
for
this
information
collection
are
presented
in
Exhibits
1A
­
1C.
The
exhibits
estimate
the
number
of
hours
required
to
conduct
each
individual
information
collection
activity
and
the
cost
associated
with
that
activity.
The
exhibits
also
show
the
total
annual
burden
and
costs
for
conducting
all
of
the
activities.

6(
b)
Estimating
Respondent
Costs
14
(
i)
Estimating
Labor
Costs
EPA
estimates
an
average
hourly
respondent
labor
cost
(
including
overhead)
of
$
119.91/
hr
for
legal
staff,
$
85.82/
hr
for
managerial
staff,
$
62.30/
hr
for
technical
staff,
and
$
31.74/
hr
for
clerical
staff.
These
rates
are
based
on
previous
industry
consultations
and
have
been
updated
to
reflect
year
2004
salary
levels.

(
ii)
Estimating
O&
M
Costs
The
operating
and
maintenance
(
O&
M)
costs
associated
with
this
ICR
are
presented
in
Exhibits
1A
­
1C.
EPA
anticipates
that
respondents
will
only
incur
O&
M
costs
associated
with
submitting
notifications,
making
long­
distance
telephone
calls,
and
making
photocopies
of
documents.
EPA
estimates
that
respondents
will
submit
their
notifications
via
certified
delivery
at
a
cost
of
$
3
per
submittal
and
that
long­
distance
phone
calls
will
cost
an
average
of
$
2
per
call.
EPA
estimates
that
respondents
will
incur
photocopying
costs
of
$
0.10
per
page.
EPA
also
estimates
that
the
costs
for
reports
sent
to
other
parties
would
be
$
0.37.

(
iii)
Estimating
Capital
Costs
EPA
estimates
$
1,655
in
capital
costs
for
the
Universal
Waste
portion
of
the
ICR,
but
EPA
does
not
anticipate
any
notable
capital
costs
for
the
Mixed
Waste
portion
of
this
ICR.

6(
c)
Estimating
Agency
Burden
and
Cost
Agency
burden
and
cost
estimates
are
presented
in
Exhibits
3A
­
3C.
Based
on
the
2004
GS
pay
schedule,
EPA
estimates
an
average
hourly
labor
cost
of
$
67.26/
hr
for
legal
staff
(
GS­
15,
Step
1),
$
48.39/
hr
for
managerial
staff
(
GS­
13,
Step
1),
$
33.95/
hr
for
technical
staff
(
GS­
11,
Step
1),
and
$
20.64/
hr
for
clerical
staff
(
GS­
6,
Step
1).
EPA
used
the
2004
Federal
Pay
Schedule
salary
figures
to
estimate
annual
compensation
of
Regional
legal,
managerial,
technical,
and
clerical
staff.
For
purposes
of
this
ICR,
EPA
assigned
Regional
staff
the
following
government
service
levels:

Legal
staff
GS­
15,
Step
1
Managerial
staff
GS­
13,
Step
1
Technical
staff
GS­
11,
Step
1
Clerical
staff
GS­
06,
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.
These
rates
were
taken
from
the
Office
of
Personnel
Management
Web
site
(
http://
www.
opm.
gov/
oca/
payrates/
index.
htm).

6(
d)(
1)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Cost
for
Universal
Waste
The
Universal
Waste
management
system
covers
handlers
of
hazardous
waste
batteries,
pesticides,
thermostats,
and
lamps.
Hazardous
waste
batteries
consist
of
sealed
nickel­
cadmium
(
n­
c)
batteries,
vented
n­
c
batteries,
and
mercuric
oxide
batteries.
Hazardous
waste
pesticides
consist
of
pesticides
that
are
recalled
by
a
manufacturer,
and
unused
pesticides
that
are
collected
and
managed
as
part
of
a
waste
pesticide
collection
and
disposal
program
administered
or
recognized
by
a
state.
Hazardous
waste
thermostats
consist
of
mercury­
containing
thermostats
that
are
removed
from
service.
Hazardous
waste
lamps
consist
of
the
bulb
or
tube
portion
of
an
electric
lighting
device,
such
as
fluorescent,
high
intensity
discharge,
neon,
mercury
vapor,
high
pressure
sodium,
and
metal
halide
lamps.

To
estimate
the
number
of
large
and
small
quantity
handlers
of
Universal
Waste,
EPA
conducted
consultations
with
the
sample
of
States
listed
in
Section
3(
b)
of
this
ICR.
EPA
then
extrapolated
the
sample
data
to
the
entire
population
of
large
and
small
handlers
in
the
U.
S.
As
a
final
step,
EPA
spoke
with
the
Universal
Waste
trade
organizations
and
recyclers
listed
in
Section
3(
b)
who
agreed
that
the
15
estimates
are
reasonable.
Table
2
presents
the
estimated
waste
handler
universe
for
these
Universal
Wastes.

Table
2
Estimated
Number
of
Annual
Universal
Waste
Handlers
and
Destination
Facilities
Number
of
SQHUWs
Number
of
LQHUWs
Number
of
Destination
Facilities
Total
Universe
Estimate
118,367
1,313
58
119,738
A.
Reading
the
Regulations
EPA
expects
that
all
Universal
Waste
handlers
and
destination
facilities
will
spend
0.5
hours
each
year
reading
the
applicable
regulations.

B.
Notification
All
LQHUWs
are
required
to
send
to
EPA
a
written
notification
of
Universal
Waste
management
under
section
273.32.
However,
the
following
LQHUWs
do
not
need
to
notify:
(
1)
a
LQHUW
that
has
already
notified
EPA
of
its
hazardous
waste
activities
and
received
an
EPA
Identification
Number;
and
(
2)
a
LQHUW
of
exclusively
recalled
Universal
Waste
pesticides
that
has
sent
notification
to
EPA
required
under
FIFRA
section
19(
b)
and
6(
b).
EPA
estimates
that
20
percent
of
LQHUWs
(
i.
e.,
2,283)
need
to
notify
EPA
of
their
activities
each
year.

C.
Labeling/
Marking
All
SQHUWs
and
LQHUWs
must
label
or
mark
their
Universal
Waste
for
identification
purposes.
EPA
expects
that
all
SQHUWs
and
LQHUWs
label
or
mark
containers,
tanks,
and
transport
vehicles
used
to
store
Universal
Waste.
Handlers
are
not
expected
to
mark
each
individual
piece
of
Universal
Waste
but
rather
accumulate
them
in
clearly
marked
containers
and
vehicles,
thus
minimizing
the
recordkeeping
burden.

D.
Storage
Time
Limits
EPA
expects
all
handlers
subject
to
the
Universal
Waste
management
system
to
keep
records
under
sections
273.15
and
273.35
that
demonstrate
how
long
their
waste
has
been
stored.
EPA
estimates
that
80
percent
of
handlers
make
this
demonstration
by
labeling
storage
containers
or
storage
areas
with
the
earliest
date
that
Universal
Waste
became
a
waste
or
was
received.
EPA
estimates
that
the
other
20
percent
of
facilities
use
a
standard
business
practice
to
account
for
storage
time;
these
facilities
therefore
are
not
burdened
in
this
ICR.

E.
Off­
Site
Shipments
All
SQHUWs,
LQHUWs,
and
destination
facilities
are
required
to
notify
an
originating
handler
if
a
Universal
Waste
shipment
is
rejected.
(
See
Table
3
for
the
estimated
number
of
total
shipments
sent
and
received
by
Universal
Waste
handlers.)
EPA
estimates
that
0.5
percent
of
all
shipments
received
by
SQHUWs,
LQHUWs,
and
destination
facilities
are
rejected.

All
SQHUWs,
LQHUWs,
and
destination
facilities
also
are
required
to
notify
EPA
if
they
receive
a
shipment
containing
hazardous
waste
that
is
not
a
Universal
Waste.
EPA
estimates
that
0.25
percent
of
all
shipments
received
are
illegal
shipments.

F.
Responses
Responses
are
calculated
from
the
number
of
shipments
shipped
and
received.
16
Table
3
Estimated
Annual
Number
of
Universal
Waste
Shipments
and
Responses
Facility
Type
Number
Shipments
per
Handler
Number
of
Shipments
Number
of
Responses
SQHUWs
118,367
1
118,367
118,367
LQHUWs
1,313
2
2,626
2,626
Destination
Facilities
53
3
174
174
Total
Number
of
Responses
121,167
G.
Tracking
Shipments
Table
3
presents
the
estimated
number
of
Universal
Waste
shipments
each
year.
LQHUWs
and
destination
facilities
are
required
under
sections
273.39(
a)
and
273.62(
a)
to
keep
records
of
each
shipment
of
Universal
Waste
received.
EPA
estimates
that
75
percent
of
all
Universal
Waste
shipments
are
received
by
destination
facilities,
with
the
remaining
25
percent
received
by
LQHUWs
for
consolidation
and
eventual
shipment.

LQHUWs
also
are
required
under
section
273.39(
b)
to
keep
records
of
each
Universal
Waste
shipment
sent
off­
site
to
another
facility.

H.
Petitions
to
Include
Other
Wastes
under
40
CFR
Part
273
EPA
expects
that
each
year,
one
organization
will
prepare
and
submit
a
petition
supporting
regulation
under
Part
273
for
a
waste
or
waste
category.

6(
d)(
2)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Cost
for
Mixed
Waste
A.
Storage
and
Treatment
Conditional
Exemption
Eligibility
The
Storage
and
Treatment
Conditional
Exemption
exempts
LLMW
from
the
regulatory
definition
of
hazardous
waste
in
section
261.3
if
the
waste
meets
the
eligibility
criteria
in
section
266.225
and
the
facilities
meet
the
conditions
in
section
266.230.
Low­
level
mixed
waste
(
LLMW),
defined
in
section
266.210,
is
eligible
for
the
conditional
exemption
if
it
is
generated
and
managed
under
a
single
NRC
or
NRC
Agreement
State
license.
(
Mixed
waste
generated
at
a
facility
with
a
different
license
and
shipped
to
a
facility
for
storage
or
treatment
requires
a
permit
and
is
ineligible
for
this
exemption.
In
addition,
NARM
waste
is
ineligible
this
exemption.)
For
LLMW
to
qualify
for
the
exemption,
licensees
must
satisfy
the
conditions
of
section
266.230
(
e.
g.,
store
LLMW
in
compliance
with
NRC
license).

The
conditions
in
section
266.230
include
preparing
and
submitting
a
notification
to
EPA
or
the
Authorized
State
claiming
the
exemption
and
preparing
a
certification
that
all
facility
personnel
have
been
appropriately
trained.
According
to
the
2001
Hazardous
Waste
Report
Cycle,
there
were
83
handlers
who
claimed
to
have
generated
mixed
waste.
Over
the
three­
year
period
of
this
ICR,
an
estimated
27
sites
(
83
sites
/
3
years
=
27
sites)
will
perform
these
activities
each
year.
(
Note
that
EPA
expects
that
facilities
claiming
the
exemption
for
more
than
one
storage
unit
would
submit
a
single
notification
for
all
units,
as
opposed
to
a
separate
notification
for
each
unit.)

In
addition,
these
facilities
must
also
inventory
their
conditionally
exempt
LLMW
at
least
annually,
inspect
the
conditionally
exempt
LLMW
at
least
quarterly
(
83
sites
*
4
inspections
=
332
inspections
annually),
and
document
the
findings
of
these
efforts.
Finally,
they
must
maintain,
on
site,
a
copy
of
an
emergency
plan
and
provide
it
to
local
authorities.
Note
that
licensees
are
already
subject
to
existing
inspection,
inventory,
and
emergency
preparedness
and
2
Klein,
J.
A.,
J.
E.
Mrochek,
R.
L.
Jolley,
I.
W.
Osborne­
Lee,
A.
A.
Francis
and
T.
Wright,
National
Profile
on
Commercially
Generated
Low­
Level
Radioactive
Mixed
Waste,
Oak
Ridge
Laboratory,
prepared
for
the
U.
S.
Nuclear
Regulatory
Commission
and
the
U.
S.
Environmental
Protection
Agency,
December
1992.

3
The
four
treatment
facilities
include
Envirocare
of
Utah,
DSSI,
NSSI,
and
Perma­
Fix
Environmental
Services.
See
EPA's
web
site,
www.
epa.
gov/
radiation/
mixed­
waste,
for
a
description
of
these
facilities.

17
contingency
planning
requirements
under
the
NRC
regulations.
EPA
therefore
does
not
expect
licensees
to
see
much
additional
incremental
burden
from
the
storage
exemption
for
these
activities.
These
assumptions
are
reflected
in
Exhibit
1B.

B.
Reading
the
Regulations
for
the
Storage
and
Treatment
Conditional
Exemption
EPA
estimates
that
approximately
27
sites
will
read
the
regulations
annually
and
that
they
will
spend
approximately
3
hours
per
year
reading
the
regulations.
This
assumption
is
reflected
in
Exhibit
1B.

C.
Loss
of
the
Storage
and
Treatment
Conditional
Exemption
Licensees
would
lose
the
exemption
if
their
LLMW
failed
to
satisfy
any
of
the
conditions
listed
at
section
266.230.
Based
on
its
best
judgment,
EPA
estimates
that,
each
year,
five
percent
of
licensees
(
83
sites
*
0.05
=
4
sites)
would
need
to
report
to
EPA
or
the
Authorized
State
their
failure
to
meet
a
condition.
Of
these,
an
estimated
one
percent
(
4
sites
*
0.01
=
0
sites)
would
need
to
telephone
EPA
and
follow
up
with
a
written
report,
informing
the
Agency
of
a
threat
to
human
health
or
the
environment.

Licensees
that
lose
the
exemption
for
their
LLMW
must
notify
EPA
or
the
Authorized
State
to
reclaim
the
exemption.
EPA
estimates
that
all
of
the
licensees
losing
the
exemption
each
year
(
4
sites)
will
provide
notice
to
EPA
or
the
Authorized
State
that
they
are
reclaiming
the
exemption.
These
assumptions
are
reflected
in
Exhibit
1B.

D.
Recordkeeping
for
the
Storage
and
Treatment
Conditional
Exemption
Licensees
must
keep
records
of
their
initial
notifications,
return
receipts,
records
of
inventories
and
inspections,
and
other
documents
as
specified
in
section
266.250.
EPA
expects
all
of
the
83
licensees
under
the
exemption
to
maintain
and
update
their
records
each
year.
This
assumption
is
reflected
in
Exhibit
1B.

E.
Transportation
and
Disposal
Conditional
Exemption
Eligibility
The
Transportation
and
Disposal
Conditional
Exemption
exempts
eligible
waste
from
the
regulatory
definition
of
hazardous
waste
in
section
261.3
if
the
waste
meets
the
eligibility
criteria
under
section
266.310,
and
the
facility
meets
the
conditions
of
section
266.315.
Eligible
wastes
must
be
a
LLMW,
as
defined
in
section
266.210,
that
meets
the
waste
acceptance
criteria
of
a
LLRWDF,
and/
or
an
eligible
NARM
waste,
as
defined
in
section
266.210.

Based
on
an
analysis
of
the
National
Profile
on
Commercially
Generated
Low­
Level
Radioactive
Mixed
Waste
(
National
Profile),
2
EPA
estimates
that
about
46
licensed
nuclear
power
reactors
in
the
U.
S.
generate
listed
LLMW
and
would
treat
it
on
site
and
claim
the
disposal
exemption.
EPA
also
estimates
that
four
commercial
mixed
waste
treatment
facilities
would
claim
the
disposal
exemption
for
their
treated
eligible
mixed
waste.
3
In
total,
EPA
estimates
that
about
50
licensees
would
claim
the
disposal
exemption.
Each
of
these
licensees
is
expected
to
read
the
regulations
once
over
the
three­
year
life
of
this
ICR
(
50
sites
/
3
years
=
17
sites/
yr).

For
the
purposes
of
this
analysis,
EPA
assumes
that
no
other
licensee
generators
would
claim
the
exemption.
Rather,
these
licensees
would
send
their
eligible
waste
to
a
commercial
mixed
18
waste
treater
in
compliance
with
the
full
RCRA
regulations,
as
applicable.
These
assumptions
are
reflected
in
Exhibit
1C.

F.
Reading
the
Regulations
for
the
Transportation
and
Disposal
Conditional
Exemption
EPA
estimates
that
approximately
17sites
will
read
the
regulations
annually
and
that
they
will
spend
approximately
3
hours
per
year
reading
the
regulations.
This
assumption
is
reflected
in
Exhibit
1C.

G.
Notification
for
the
Transportation
and
Disposal
Conditional
Exemption
As
required
by
section
266.345(
a),
licensees
must
submit
a
one­
time
notice
to
EPA
or
the
Authorized
State
stating
that
they
are
claiming
the
exemption
prior
to
the
initial
shipment
of
an
exempted
waste
to
the
LLRWDF.
This
ICR
estimates
that
17
licensees
will
submit
a
notification
to
EPA
or
the
Authorized
State
each
year
(
50
sites
/
3
years
=
17
sites/
yr).

Further,
licensees
must
also
submit
a
notification
to
the
LLRWDF
prior
to
each
shipment
of
exempted
waste.
Based
on
its
best
professional
judgment,
EPA
assumes
that
each
of
the
46
nuclear
power
reactors
qualifies
as
a
RCRA
large
quantity
generator
(
i.
e.,
for
their
eligible
mixed
waste
and
other
hazardous
wastes
generated).
EPA
estimates
these
reactors
would
send,
on
average,
four
shipments
of
exempted
waste
offsite
each
year
(
i.
e.,
once
every
90
days).
In
total,
EPA
estimates
these
nuclear
reactors
would
make
about
184
shipments
in
total
each
year.
In
addition,
EPA
estimates
that
the
four
commercial
mixed
waste
treatment
facilities
will
each
send
one
shipment
of
exempted
waste
to
the
LLRWDF
each
year
(
4
shipments/
yr).
That
is,
EPA
expects
these
facilities
to
store
their
treated
waste
on
site
during
the
year
in
order
to
minimize
the
number
of
shipments
to
the
LLRWDF.
In
total,
EPA
estimates
that
these
generator
and
treater
licensees
would
make
188
shipments
of
exempted
waste
annually
and
that
they
would
therefore
need
to
prepare
and
submit
188
notifications
to
LLRWDFs
annually.

Note
that
once
the
eligible
mixed
waste
is
placed
on
the
truck
en
route
to
the
LLRWDF,
it
exits
RCRA
Subtitle
C
regulation.
The
licensees
need
not
prepare
a
RCRA
manifest
for
the
shipment;
however,
they
must
transmit
the
NRC
Uniform
LLW
Manifest
(
not
burdened
in
this
ICR).
These
assumptions
are
reflected
in
Exhibit
1C.

H.
Loss
of
the
Transportation
and
Disposal
Conditional
Exemption
Any
waste
will
automatically
lose
its
exemption
if
it
is
not
managed
in
accordance
with
all
of
the
applicable
conditions
specified
in
section
266.315.
EPA
or
the
Authorized
State
may
conduct
inspections
and
audits
of
the
generator
of
the
waste
and
any
other
person
claiming
the
exemption.
If
the
claimant
fails
to
satisfy
any
of
the
specified
conditions,
the
conditional
exemption
would
be
void.
The
claimant
must
notify
EPA
or
the
Authorized
State
of
the
failure
within
30
days
from
the
date
when
the
failure
becomes
known.
Based
on
its
best
professional
judgment,
EPA
estimates
that,
each
year,
about
five
percent
of
licensees
(
50
sites
*
0.05
=
3
sites)
would
submit
this
notification.
Of
these,
an
estimated
one
percent
(
3
sites*
0.01
=
0
sites)
would
need
to
telephone
EPA
or
the
Authorized
State
and
follow
up
with
a
report
because
the
failure
threatens
human
health
or
the
environment.

Licensees
may
regain
the
exempt
status
for
their
eligible
waste,
as
provided
by
section
266.360.
Licensees
must
notify
EPA
or
the
Authorized
State
that
they
are
re­
claiming
the
exemption.
EPA
estimates
that
all
of
the
licensees
that
lose
an
exemption
(
3
sites
annually)
would
apply
to
have
their
exemption
reinstated.
These
assumptions
are
reflected
in
Exhibit
1C.

I.
Recordkeeping
for
the
Transportation
and
Disposal
Conditional
Exemption
Licensees
claiming
the
exemption
must
maintain
records
as
specified
at
section
266.350
(
e.
g.,
copy
of
notifications,
return
receipts).
EPA
estimates
that
each
of
the
50
licensees
claiming
the
exemption
would
need
to
keep
and
update
these
records
annually.
This
assumption
is
reflected
19
in
Exhibit
1C.

6(
e)
Bottom
Line
Burden
Hours
and
Costs
(
i)
Respondent
Tally
Table
4
summarizes
the
information
found
in
this
supporting
statement,
and
the
locations
in
the
supporting
statement
where
the
numbers
came
from.
This
is
the
information
used
to
fill
out
the
OMB
83­
I
form.

Table
4
Summary
of
Annual
Respondent
Bottom
Line
Hours
and
Costs
Universal
Waste
Source
Mixed
Waste
Source
Total
Number
of
respondents
119,738
Table
2
44
6(
b)(
2)
A
+
6(
b)(
2)
E
119,782
Total
annual
responses
121,167
Table
3
948
Exhibit
2B
122,115
Total
annual
hours
185,487
Exhibit
1A
480
Exhibit
2B
185,967
Total
annualized
capital/
startup
costs
$
1,655
Exhibit
2A
$
0
Exhibit
2B
$
1,655
Total
annual
O&
M
costs
$
430
Exhibit
2A
$
966
Exhibit
2B
$
1,396
(
ii)
Agency
Tally
Exhibits
3A
­
3C
show
the
calculations
for
the
total
annual
Agency
burden
and
costs
associated
with
this
ICR.
For
the
Universal
Waste
requirements,
EPA
estimates
an
annual
Agency
burden
of
1,655
hours
and
a
cost
of
$
79,803.
For
the
Mixed
Waste
exemptions,
EPA
estimates
an
annual
Agency
burden
of
19
hours
and
a
cost
of
$
612.
The
total
annual
Agency
burden
for
this
ICR
is
therefore
1,674
hours
and
$
80,415.

6(
f)
Reasons
for
Change
in
Burden
The
burden
associated
with
the
2001
Mixed
Waste
Final
Rule
ICR
(
2050­
0181)
has
been
added
to
the
Universal
Waste
requirements
ICR,
in
order
to
consolidate
the
two
ICRs.
Therefore,
there
is
an
addition
of
3,079
annual
reporting
and
recordkeeping
burden
hours
due
to
the
incorporation
of
the
Mixed
Waste
Final
Rule
ICR.
There
is
also
a
decrease
of
35,280
hours,
which
is
an
adjustment,
and
is
explained
in
the
paragraph
below.
The
net
adjustment
for
this
renewal
is
a
decrease
of
32,201
hours.

The
number
of
large
quantity
handlers
of
Universal
Waste
(
LQUWHs)
has
decreased
since
the
last
time
this
ICR
was
approved,
from
11,414
in
2001
to
1,313
for
this
renewal.
The
number
of
LQUHWs
was
determined
from
information
received
during
the
2001
Hazardous
Waste
Report
Cycle.
The
number
of
Mixed
Waste
handlers
also
decreased,
from
831
to
83.
The
number
of
Mixed
Waste
handlers
was
not
known
at
the
time
of
the
2001
final
rule,
and
EPA
made
the
universe
estimate
based
on
the
number
of
facilities
that
stored
Mixed
Waste
in
1990,
according
to
the
1992
National
Profile
on
Commercially
Generated
Low­
Level
Radioactive
Mixed
Waste.
For
this
renewal,
EPA
was
able
to
determine
the
number
of
generators
of
Mixed
Waste
from
the
2001
Hazardous
Waste
Report
cycle.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
20
estimated
to
average
2.0
hours
per
response.
The
total
public
reporting
and
recordkeeping
burden
for
the
Universal
Waste
requirements
is
estimated
to
average
1.5
hours
per
response.
The
total
public
reporting
and
recordkeeping
burden
for
the
Mixed
Waste
exemptions
is
estimated
to
average
0.5
hours
per
response.

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

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
RCRA­
2004­
0005,
which
is
available
for
public
viewing
at
the
Resource
Conservation
and
Recovery
Act
(
RCRA)
Docket
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
RCRA
Docket
is
(
202)
566­
0270.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
RCRA­
2004­
0005
and
OMB
control
number
2050­
0145
in
any
correspondence.
21
EXHIBIT
1A
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
UNIVERSAL
WASTE
HANDLERS
AND
DESTINATION
FACILITIES
ANNUAL
ESTIMATED
RESPONDENT
BURDEN
AND
COST
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
O&
M
Costs
Postage/
Cost
per
Number
of
Legal
Manager
Technical
Clerical
Shipping
Respondent
Respondents
Total
Hours
Total
Cost
@
$
119.91/
hr
@
$
85.82/
hr
@
$
62.30/
hr
@
$
31.74/
hr
@
$
0.37/
doc
or
Activity
or
Activities
per
Year
per
Year
READING
THE
REGULATIONS
Read
the
Universal
Waste
Regulations
SQHUWs
0.10
0.17
0.25
0.00
$
0.00
$
42.16
118,367
61,551
$
4,990,353
LQHUWs
0.10
0.17
0.25
0.00
$
0.00
$
42.16
1,313
683
$
55,356
Destination
facilities
0.10
0.17
0.25
0.00
$
0.00
$
42.16
58
30
$
2,445
SUBTOTAL
0.10
0.17
0.25
0.00
$
0.00
$
42.16
119,738
62,264
$
5,048,154
NOTIFICATION
(
273.32)

Prepare
written
notification
of
universal
waste
management
LQHUWs
0.00
1.00
0.50
0.75
$
0.00
$
140.78
263
592
$
37,025
Submit
written
notification
of
universal
waste
management
LQHUWs
0.00
0.00
0.00
0.16
$
0.37
$
5.45
263
42
$
1,433
SUBTOTAL
0.00
1.00
0.50
0.91
$
0.37
$
146.23
263
634
$
38,458
LABELING/
MARKING
(
273.14
and
273.34)

Label
or
mark
the
universal
waste
or
storage
container
to
identify
the
type
of
universal
waste
SQHUWs
0.00
0.00
0.25
0.25
$
0.00
$
23.51
118,367
59,184
$
2,782,808
LQHUWs
0.00
0.00
0.50
0.50
$
0.00
$
47.02
1,313
1,313
$
61,737
SUBTOTAL
0.00
0.00
varies
varies
$
0.00
varies
varies
60,497
$
2,844,545
STORAGE
TIME
LIMITS(
273.15
and
273.35)

Mark
or
label
storage
container
or
area
used
to
store
universal
waste
with
the
date
the
waste
was
received
or
became
a
waste
SQHUWs
0.00
0.00
0.25
0.25
$
0.00
$
23.51
94,694
47,347
$
2,226,256
LQHUWs
0.00
0.00
0.50
0.50
$
0.00
$
47.02
1,050
1,050
$
49,371
SUBTOTAL
0.00
0.00
varies
varies
$
0.00
varies
varies
48,397
$
2,275,627
OFF­
SITE
SHIPMENTS
(
273.18,273.36,
and
273.61)

Prepare
notice
to
originating
handler
of
rejection
of
universal
waste
shipment
SQHUWs
and
LQHUWs
0.00
0.25
0.25
0.15
$
0.00
$
41.79
150
98
$
6,269
Destination
Facilities
0.00
0.25
0.25
0.15
$
0.00
$
41.79
449
292
$
18,764
Submit
notice
to
originating
handler
of
rejection
of
universal
waste
shipment
SQHUWs
and
LQHUWs
0.00
0.00
0.00
0.16
$
0.37
$
5.45
150
24
$
818
Destination
Facilities
0.00
0.00
0.00
0.16
$
0.37
$
5.45
449
72
$
2,447
Prepare
notice
to
EPA
of
illegal
waste
shipments
SQHUWs
and
LQHUWs
1.00
0.50
0.50
0.25
$
0.00
$
201.91
75
169
$
15,143
Destination
Facilities
1.00
0.50
0.50
0.25
$
0.00
$
201.91
225
506
$
45,430
Submit
notice
to
EPA
of
illegal
waste
shipments
SQHUWs
and
LQHUWs
0.00
0.00
0.00
0.16
$
0.37
$
5.45
75
12
$
409
Destination
Facilities
0.00
0.00
0.00
0.16
$
0.37
$
5.45
225
36
$
1,226
SUBTOTAL
varies
varies
varies
varies
varies
varies
varies
1,209
$
90,506
TRACKING
UNIVERSAL
WASTE
SHIPMENTS
(
273.39
and
273.62)

Keep
a
record
of
each
shipment
of
universal
waste
received
LQHUWs
0.00
0.00
0.00
0.10
$
0.00
$
3.17
29,935
2,993
$
94,892
Destination
Facilities
0.00
0.00
0.00
0.10
$
0.00
$
3.17
89,804
8,980
$
284,677
Keep
a
record
of
each
shipment
of
universal
waste
sent
to
other
facilities
LQHUWs
0.00
0.00
0.00
0.10
$
0.00
$
3.17
2,626
263
$
8,324
SUBTOTAL
0.00
0.00
0.00
0.10
$
0.00
varies
varies
12,236
$
387,893
PETITIONS
TO
INCLUDE
OTHER
WASTES
UNDER
40
CFR
PART
273
(
273.80
and
278.81)

Prepare
a
petition
supporting
regulation
under
Part
273
for
a
waste
or
waste
category
30.00
40.00
150.00
30.00
$
0.00
$
17,327.30
1
250
$
17,327
Submit
a
petition
supporting
regulation
under
Part
273
for
a
waste
or
waste
category
0.00
0.00
0.00
0.16
$
0.37
$
5.45
1
0.16
$
5
SUBTOTAL
30.00
40.00
150.00
30.16
$
0.37
$
17,332.75
1
250
$
17,332
TOTAL
varies
varies
varies
varies
varies
varies
varies
185,487
$
10,702,515
22
EXHIBIT
1B
CONDITIONAL
EXEMPTION
FOR
LOW­
LEVEL
MIXED
WASTE
STORAGE
ANDDISPOSAL
ESTIMATED
ANNUAL
RESPONDENT
BURDEN
AND
COST
STORAGE
ANDTREATMENT
CONDITIONAL
EXEMPTION
Total
Hours
and
Costs
119.91
$
85.82
$
62.30
$
31.74
$

Leg.
Mgr.
Tech.
Cler.
Respon.
Labor
Capital/
Respon.
Total
Total
$
119.91/
$
85.82/
$
62.30/
$
31.74/
Hours/
Cost/
Startup
O
&
M
or
Hours/
Cost/

INFORMATIONCOLLECTION
ACTIVITY
Hour
Hour
Hour
Hour
Year
Year
Cost
Cost
Activities
Year
Year
Reading
the
Regulations
Read
the
regulations
0.50
0.50
2.00
­
3.00
227.47
$
­

$
­

$
27
81
$
6,142
Storage
and
Treatment
Conditional
Exemption
and
Eligibility
Prepare
and
submit
notification
of
intent
to
claim
exemption
(
266.230(
a))
0.10
0.25
1.00
0.25
1.60
103.68
$
­

$
3.00
$
27
43
$
2,880
Prepare
certification
that
facility
personnel
have
been
appropriately
trained
(
266.230(
b)(
3))
­
0.08
0.17
­
0.25
17.46
$
­

$
­

$
27
7
$
471
Inventory
conditionally
exempt
LLMW
and
record
findings
(
annually)
(
266.230(
b)(
4))
­
­
0.08
­
0.08
4.98
$
­

$
­

$
83
7
$
413
Conduct
compliance
inspections
of
conditionally
exempt
LLMW
and
record
findings
(
quarterly)
(
266.230(
b)(
4))
­
­
0.08
­
0.08
4.98
$
­

$
­

$
332
27
$
1,653
Maintain
emergency
contingency
plan
on­
site
and
provide
it
to
local
authorities
(
266.230(
b)(
5))
­
­
­
0.10
0.10
3.17
$
­

$
1.00
$
83
8
$
346
Loss
of
Conditional
Exemption
Prepare
and
submit
written
notification
of
exemption
loss
(
266.240(
a)(
1))
­
0.25
1.50
0.25
2.00
122.84
$
­

$
6.00
$
4
8
$
515
Inform
EPARegion
or
the
Authorized
State
orally
of
exemption
loss
with
a
follow­
up
written
notification
in
cases
of
endangerment
to
human
health
or
the
environment
(
266.240(
a)(
2))
­
0.25
0.50
­
0.75
52.61
$
­

$
5.00
$
­
­
$
0
Prepare
and
submit
notice
reclaiming
the
exemption
for
LLMW
(
266.245(
a))
­
0.25
4.00
0.75
5.00
294.46
$
­

$
3.00
$
4
20
$
1,190
Record
Keeping
Maintain
and
update
records
of
notifications,
return
receipts,

failure
report(
s),
inventories,
inspections,
certifications,
and
emergency
plans
(
266.250)
­
­
­
1.00
1.00
31.74
$
­

$
1.00
$
83
83
$
2,717
Subtotal
Varies
Varies
Varies
Varies
Varies
Varies
0
Varies
670
284
$
16,327
Hours
and
Costs
Per
Respondent
Per
Activity
23
EXHIBIT
1C
CONDITIONAL
EXEMPTIONFORLOW­
LEVELMIXED
WASTESTORAGEAND
DISPOSAL
ESTIMATED
ANNUALRESPONDENTBURDEN
AND
COST
TRANSPORTATION
ANDDISPOSALCONDITIONALEXEMPTION
Total
Hours
and
Costs
119.91
$
85.82
$
62.30
$
31.74
$

Leg.
Mgr.
Tech.
Cler.
Respon.
Labor
Capital/
Respon.
Total
Total
$
119.91/
$
85.82/
$
62.30/
$
31.74/
Hours/
Cost/
Startup
O
&
M
or
Hours/
Cost/

INFORMATION
COLLECTION
ACTIVITY
Hour
Hour
Hour
Hour
Year
Year
Cost
Cost
Activities
Year
Year
Reading
theRegulations
Readtheregulations
0.50
0.50
2.00
­
3.00
227.47
$
­

$
­

$
17
51
$
3,867
Notifications
Prepareandsubmit
notification
to
EPA
or
the
Authorized
State
(
266.345(
a))
0.10
0.25
1.00
0.25
1.60
103.68
$
­

$
3.00
$
17
27
$
1,814
Prepareandsubmit
notification
to
LLRWDF
(
prior
to
each
shipment
of
exemptedwaste)
(
266.345(
b))
­
­
0.25
­
0.25
15.58
$
­

$
3.00
$
188
47
$
3,493
Record
Keeping
Copy
andmaintainexemptionrecords
(
266.350)
­
­
­
1.00
1.00
31.74
$
­

$
1.00
$
50
50
$
1,637
Loss
of
Conditional
Exemption
Prepareandsubmit
notificationof
the
failure(
266.355(
a)(
1))
0.10
0.25
1.50
0.25
2.10
134.83
$
­

$
3.00
$
3
6
$
413
Inform
EPAReg
i
on
or
the
Author
i
zed
State
ora
l
y
of
exemption
losswithafollow­
upnotificationin
cases
of
endangerment
to
humanhealthor
theenvironment
(
266.355(
a)(
2))
­
0.25
0.50
­
0.75
52.61
$
­

$
5.00
$
­
­
$
0
Prepareandsubmit
thenoticefor
reinstatement
(
266.360(
a)(
2))
­
0.25
4.00
0.75
5.00
294.46
$
­

$
3.00
$
3
15
$
892
Subtotal
Varies
Varies
Varies
Varies
Varies
Varies
0
Varies
278
196
$
12,116
Hours
and
Costs
Per
Respondent
Per
Activity
24
EXHIBIT
2B
CONDITIONAL
EXEMPTION
FOR
LOW­
LEVEL
MIXED
WASTE
STORAGE
AND
DISPOSAL
TOTAL
ESTIMATED
ANNUAL
RESPONDENT
BURDEN
AND
COST
SUMMARY
Exhibit
Title
Annual
Activities
Annual
Burden
Annual
Labor
Cost
Annual
Capital/

Startup
Cost
Annual
O&
M
Cost
Total
Annual
Cost
Exhibit
1B
Storage
and
Treatment
Conditional
Exemption
670
284
$
16,044
$
0
$
283
$
16,327
Exhibit
1C
Transportation
and
Disposal
Conditional
Exemption
278
196
$
11,433
$
0
$
683
$
12,116
Annual
Total
948
480
$
27,477
$
0
$
966
$
28,443
25
EXHIBIT
2A
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
UNIVERSAL
W
ASTE
HANDLERS
AND
DESTINATION
FACILITIES
ANNUAL
RESPONDENT
BURDEN
AND
COST
SUMMARY
Respondent
Type
Total
Hours
Labor
Costs
Capital
Costs
O&
M
Costs
Total
Costs
SQHUW
s
168,382
$
10,021,725.29
­­­
$
82.34
$
10,021,807.63
LQHUW
s
6,939
$
308,288.15
­­­
$
98.22
$
308,386.37
Destination
Facilities
9,916
$
354,739.62
­­­
$
249.38
$
354,989.00
Petitioners
250
$
17,331.63
­­­
$
0.37
$
17,332.00
Capital
Costs
­­­
­­­
$
1,664.77
­­­
$
1,664.77
TOTAL
185,487
$
10,702,084.69
$
1,664.77
$
430.31
$
10,704,179.77
EXHIBIT
3A
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
UNIVERSAL
WASTE
ANNUAL
ESTIMATED
AGENCY
BURDEN
AND
COST
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
O&
M
Costs
Legal
Managerial
Technical
Clerical
Post/
Shipping
Respondent
Respondents
Total
Hours
Total
Cost
@
$
67.26/
hr
@
$
48.39/
hr
@
$
33.95/
hr
@
$
20.64/
hr
@
$
0.37/
doc
or
Activity
or
Activities
per
Year
per
Year
NOTIFICATION
(
273.62)

Review
notification
for
completeness
and
accuracy
LQHUWs
0.00
0.00
0.25
0.00
$
0.00
$
8.49
263
66
$
2,233
Issue
EPAID
number
to
LQHUW
LQHUWs
0.00
0.00
0.00
0.25
$
0.00
$
5.16
263
66
$
1,357
Enter
information
into
Database
LQHUWs
0.00
0.00
0.00
0.25
$
0.00
$
5.16
263
66
$
1,357
SUBTOTAL
0.00
0.00
0.25
0.50
$
0.00
$
18.81
263
198
$
4,947
OFF
SITE
SHIPMENTS
(
273.18,
273.36,
and
273.61)

Review
and
file
notice
of
illegal
shipment
LQHUWs
2.00
1.00
1.00
0.25
$
0.00
$
222.02
75
319
$
16,652
Destination
Facilities
2.00
1.00
1.00
0.25
$
0.00
$
222.02
225
956
$
49,955
SUBTOTAL
2.00
1.00
1.00
0.25
$
0.00
$
222.02
300
1,275
$
66,607
PETITIONS
TO
INCLUDEOTHER
WASTESUNDER
40
CFR
PART
273
(
278.80
AND
273.81)

Review
petition
and
make
a
decision
on
the
applicability
of
regulation
under
the
universal
waste
program
40.00
50.00
80.00
0.00
$
0.00
$
7,825.92
1
170
$
7,826
Prepare
and
send
written
decision
to
the
petitioner
2.00
2.00
2.00
2.00
$
0.00
$
340.49
1
8
$
340
Compile
and
file
all
information
on
the
petition
0.00
0.00
0.00
4.00
$
0.00
$
82.57
1
4
$
83
SUBTOTAL
42.00
52.00
82.00
6.00
$
0.00
$
8,248.98
1
182
$
8,249
TOTAL
varies
varies
varies
varies
$
0.00
varies
varies
1,655
$
79,803
26
EXHIBIT
3B
CONDITIONAL
EXEMPTION
FOR
LOW­
LEVEL
MIXED
WASTE
STORAGE
AND
DISPOSAL
ESTIMATED
ANNUAL
AGENCY
BURDENANDCOST
STORAGEANDTREATMENT
CONDITIONAL
EXEMPTION
Total
Hours
and
Costs
67.26
$
48.39
$
33.95
$
20.64
$

Leg.
Mgr.
Tech.
Cler.
Respon.
Labor
Capital/
Respon.
Total
Total
$
67.26/
$
48.39/
$
33.95/
$
20.64/
Hours/
Cost/
Startup
O&
M
or
Hours/
Cost/

INFORMATIONCOLLECTIONACTIVITY
Hour
Hour
Hour
Hour
Year
Year
Cost
Cost
Activities
Year
Year
Storage
and
Treatment
Conditional
Exemption
and
Eligibility
Review
notification
of
intent
to
claim
exemption
(
266.230(
a))
­
­
0.25
0.10
0.35
10.55
$
­

$
­

$
27
9
$
285
Loss
of
Conditional
Exemption
Review
written
notification
of
exemption
loss
(
266.240(
a)(
1))
­
­
0.25
0.10
0.35
10.55
$
­

$
­

$
4
1
$
42
Receive
and
review
oral
and
follow
up
notification
if
failure
endangers
human
health
or
the
environment
(
266.240(
a)(
2))
­
­
0.50
0.10
0.60
19.04
$
­

$
­

$
­
­
$
0
Review
application
for
reinstatement
of
exemption
(
266.245)
­
­
0.25
0.10
0.35
10.55
$
­

$
­

$
4
1
$
42
Subtotal
Varies
Varies
Varies
Varies
Varies
Varies
Varies
Varies
35
11
$
369
Hours
and
Costs
Per
Respondent
Per
Activity
27
EXHIBIT
3C
CONDITIONAL
EXEMPTION
FOR
LOW­
LEVEL
MIXED
WASTE
STORAGE
AND
DISPOSAL
ESTIMATED
ANNUAL
AGENCY
BURDEN
AND
COST
TRANSPORTATION
AND
DISPOSAL
CONDITIONAL
EXEMPTION
Total
Hours
and
Costs
67.26
$
48.39
$
33.95
$
20.64
$

Leg.
Mgr.
Tech.
Cler.
Respon.
Labor
Capital/
Respon.
Total
Total
$
67.26/
$
48.39/
$
33.95/
$
20.64/
Hours/
Cost/
Startup
O
&
M
or
Hours/
Cost/

INFORMATION
COLLECTION
ACTIVITY
Hour
Hour
Hour
Hour
Year
Year
Cost
Cost
Activities
Year
Year
Notifications
Review
initial
notification
(
266.345(
a))
­
­
0.25
0.10
0.35
10.55
$
­

$
­

$
17
6
$
179
Loss
of
Conditional
Exemption
Review
notification
of
the
failure
(
266.355(
a)(
1))
­
­
0.25
0.10
0.35
10.55
$
­

$
­

$
3
1
$
32
Receive
and
review
oral
and
follow
up
notification
if
failure
endangers
human
health
or
the
environment
(
266.355(
a)(
2))
­
­
0.50
0.10
0.60
19.04
$
­

$
­

$
­
­
$
0
Review
notification
of
reinstated
exemption
(
266.360)
­
­
0.25
0.10
0.35
10.55
$
­

$
­

$
3
1
$
32
Subtotal
Varies
Varies
Varies
Varies
Varies
Varies
Varies
Varies
23
8
$
243
Hours
and
Costs
Per
Respondent
Per
Activity
