SUPPORTING
STATEMENT
FOR
EPA
INFORMATION
COLLECTION
REQUEST
NUMBER
0820.09
HAZARDOUS
WASTE
GENERATOR
STANDARDS
October
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)
Characterization
of
the
Information
Collection
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1
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
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8
2(
a)
Need
and
Authority
for
the
Collection
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8
2(
b)
Use
and
Users
of
the
Data
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13
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
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17
3(
a)
Nonduplication
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17
3(
b)
Consultations
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17
3(
c)
Effects
of
Less
Frequent
Collection
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18
3(
d)
General
Guidelines
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18
3(
e)
Confidentiality
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18
3(
f)
Sensitive
Questions
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18
4.
THE
RESPONDENTS
AND
THE
INFORMATION
COLLECTED
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18
4(
a)
Respondents
and
SIC
Codes
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18
4(
b)
Information
Requested
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19
5.
THE
INFORMATION
COLLECTED
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AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
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63
5(
a)
Agency
Activities
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63
5(
b)
Collection
Methodology
and
Management
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66
5(
c)
Small
Entity
Flexibility
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66
5(
d)
Collection
Schedule
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6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
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69
6(
a)
Estimating
Annual
Respondent
Burden
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69
6(
b)
Estimating
Annual
Respondent
Costs
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69
6(
c)
Estimating
Annual
Agency
Burden
and
Cost
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70
6(
d)
Estimating
the
Respondent
Universe
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71
6(
e)
Bottom
Line
Burden
Hours
and
Costs
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94
6(
f)
Reasons
for
Change
in
Burden
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94
6(
g)
Burden
Statement
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94
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
TITLE
AND
NUMBER
OF
THE
INFORMATION
COLLECTION
This
information
collection
request
(
ICR)
is
entitled
"
Hazardous
Waste
Generator
Standards,"
ICR
Number
0820.09.
This
ICR
renews
the
previously
approved
ICR,
"
Hazardous
Waste
Generator
Standards,"
ICR
Number
0820.08.

1(
b)
CHARACTERIZATION
OF
THE
INFORMATION
COLLECTION
In
the
Resource
Conservation
and
Recovery
Act
of
1976
(
RCRA),
as
amended,
Congress
authorized
the
U.
S.
Environmental
Protection
Agency
(
EPA)
to
develop
and
administer
a
national
hazardous
waste
program.
The
core
of
the
program
is
the
regulation
of
hazardous
waste
from
generation
to
eventual
disposal,
i.
e.,
from
"
cradle
to
grave."
Sections
3001(
d)
and
3002
of
RCRA
authorize
EPA
to
develop
and
promulgate
regulations
for
generators
of
hazardous
waste.
Among
other
things,
EPA
is
authorized
to
establish
generator
standards
for
recordkeeping,
labeling/
use
of
containers,
use
of
a
manifest
system,
and
biennial
reporting
to
EPA.
[
Note:
This
ICR
does
not
cover
any
manifesting
or
biennial
reporting
requirements.
Manifesting
requirements
are
addressed
in
ICR
Number
801.
Biennial
reporting
requirements
are
addressed
in
ICR
Number
976.]
In
addition,
RCRA
section
3010
sets
forth
requirements
for
generators
and
other
hazardous
waste
handlers
to
notify
EPA
of
their
hazardous
waste
activities.
[
Note:
These
notification
requirements
are
addressed
in
ICR
Number
261.]
Finally,
RCRA
section
3017
sets
forth
requirements
for
exporters
exporting
hazardous
waste
from
the
United
States
(
e.
g.,
notification
and
annual
reporting
requirements).

In
1980,
EPA
promulgated
the
principal
elements
of
the
generator
requirements
in
40
CFR
part
262.
These
regulations
have
been
amended
on
several
occasions.
This
ICR
discusses
five
categories
of
information
collection
requirements
in
p
262:
hazardous
waste
determination
requirements;
pre­
transport
requirements;
air
emission
standards
for
large
quantity
generators
(
LQGs);
recordkeeping
and
reporting
requirements;
and
export
requirements.
Sections
1
through
5
of
this
ICR
describe
these
information
collection
requirements.
In
Section
6,
EPA
estimates
the
annual
burden
and
cost
to
respondents
and
the
Agency
in
carrying
out
these
requirements.

A
brief
summary
of
the
information
collection
requirements
at
40
CFR
part
262
is
provided
below.

HAZARDOUS
WASTE
DETERMINATION
REQUIREMENTS
40
CFR
262.11
requires
that,
if
a
person
generates
a
solid
waste,
he
or
she
must
determine
if
that
waste
is
a
hazardous
waste.
The
person
should
first
determine
if
the
waste
is
excluded
from
regulation
under
40
CFR
261.4.
He
or
she
must
then
determine
if
the
waste
is
listed
as
a
hazardous
waste
in
subpart
D
of
40
CFR
part
261.
For
purposes
of
compliance
with
40
CFR
part
268,
or
if
the
waste
is
not
listed
in
subpart
D
of
40
CFR
part
261,
the
generator
must
then
2
1
Note,
however,
that
40
CFR
262.34(
g)
provides
that
a
generator
who
generates
1,000
kilograms
or
greater
of
hazardous
waste
per
month
who
also
generates
wastewater
treatment
sludges
from
electroplating
operations
(
F006),
as
specified,
may
accumulate
F006
waste
on
site
for
more
than
90
days,
but
no
more
than
180
days,
without
a
permit
or
interim
status,
provided
that
the
generator
complies
with
specified
requirements
(
i.
e.,
basically
the
standards
applicable
to
LQGs,
as
modified
for
the
extended
accumulation
period.)
determine
whether
the
waste
is
identified
in
subpart
C
of
40
CFR
part
261
by
either
testing
the
waste
or
applying
knowledge
of
the
hazard
characteristics
of
the
waste
in
light
of
the
materials
or
the
processes
used.
If
the
waste
is
determined
to
be
hazardous,
the
generator
must
manage
it
according
to
applicable
RCRA
hazardous
waste
regulations.

LARGE
QUANTITY
GENERATOR
PRE­
TRANSPORT
REQUIREMENTS
LQGs
generate
1,000
kilograms
or
more
of
hazardous
waste
in
a
calendar
month.
LQGs
may
accumulate
hazardous
waste
on
site
for
90
days
or
less
in
tanks,
containers,
drip
pads,
or
containment
buildings
without
a
permit
or
interim
status
if
they
comply
with
requirements
specified
in
section
262.34.1
There
are
seven
categories
of
pre­
transport
information
collection
requirements
applicable
to
LQGs
included
or
referenced
in
section
262.34:
container
labeling,
personnel
training,
contingency
planning
and
emergency
procedures,
tank
systems,
drip
pads,
containment
buildings,
and
requests
for
extensions
of
the
accumulation
period.

(
1)
Labeling
40
CFR
262.34(
a)(
2)
and
(
3)
require
that
LQGs
label
each
container
or
tank
accumulating
hazardous
waste
with
the
date
upon
which
each
period
of
accumulation
begins
and
the
words
"
Hazardous
Waste."
Section
262.34(
c)(
1)
requires
LQGs
accumulating
either
hazardous
waste
or
acutely
hazardous
waste
at
or
near
the
point
of
generation
(
i.
e.,
at
satellite
accumulation
areas)
to
mark
the
containers
with
the
words
"
Hazardous
Waste"
or
other
words
that
identify
the
contents
of
the
containers.
Section
262.34(
c)(
2)
further
requires
that,
if
the
LQG
accumulates
hazardous
waste
or
acutely
hazardous
waste
at
a
satellite
accumulation
area
in
excess
of
specified
amounts,
the
LQG
must,
within
three
days,
move
that
excess
waste
to
a
90­
day
accumulation
area.
During
that
three­
day
period,
the
LQG
must
continue
to
comply
with
section
262.34(
c)(
1)
and
mark
the
container
holding
the
excess
accumulation
with
the
date
the
excess
amount
began
accumulating.

(
2)
Personnel
Training
Under
section
262.34(
a)(
4),
LQGs
must
comply
with
the
personnel
training
requirements
in
40
CFR
265.16(
d)
and
(
e).
LQGs
must
document
personnel
training
of
hazardous
wastes.
Required
information
includes
relevant
job
titles
for
each
position
and
the
name
of
each
person
filling
each
job,
a
written
job
description
and
necessary
qualifications
for
each
position,
and
the
training
given
to
the
individual
filling
that
position.

(
3)
Contingency
Planning
and
Emergency
Procedures
3
Under
section
262.34(
a)(
4),
LQGs
must
comply
with
the
preparedness
and
prevention
and
contingency
plan
and
emergency
procedure
requirements
in
subparts
C
and
D
of
part
265.
LQGs
must
record
whether
State
or
local
authorities
declined
to
enter
into
an
arrangement
to
become
more
familiar
with
the
generator's
facility
and
its
wastes,
prepare
and
maintain
contingency
plans,
and
comply
with
emergency
reporting
requirements.
The
contingency
plan
describes
the
actions
facility
personnel
will
take
should
a
fire,
explosion,
or
any
unplanned
sudden
or
non­
sudden
release
of
hazardous
waste
constituents
to
air,
soil,
or
surface
water
occur.
Local
emergency
response
teams
use
the
information
required
in
the
contingency
plan
to
minimize
unanticipated
damage
from
the
unintended
release
of
hazardous
waste.

Other
emergency
reporting
requirements
underp
265
subpart
D
include
notifying
the
Regional
Administrator
that
the
facility
is
in
compliance
with
specific
regulations
before
operations
resume
in
any
area
affected
by
an
emergency
situation
(
§
265.56(
i)),
and
submitting
a
report
to
the
Regional
Administrator
containing
details
of
any
emergency
situation
that
requires
implementation
of
the
contingency
plan
(
§
265.56(
j)).

(
4)
Tank
Systems
Section
262.34(
a)(
1)
requires
LQGs
that
accumulate
hazardous
waste
in
tank
systems
for
90
days
or
less
to
comply
with
part
265
subpart
J.
Depending
on
how
the
tank
owner
desires
to
comply
with
the
regulations,
he
or
she
may
need
to
perform
one
or
more
of
the
following:

!
A
no­
free­
liquids
demonstration
(
§
265.190(
a));

!
Existing
tank
system
assessments
(
§
265.191);

!
An
equivalent
containment
exemption
(
§
265.193(
d));

!
A
variance
from
secondary
containment
requirements
(
§
265.193(
g)
and
(
h));

!
Annual
leak
tests
and
inspection
documentation
(
§
265.193(
i):
§
265.195(
c));
or
!
An
exemption
from
the
24­
hour
leak
detection
requirement
(
§
265.193(
e)(
3)(
iii)).

In
addition,
if
any
LQG
has
a
new
tank
or
new
components,
he
or
she
must
perform
new
tank
system
assessments
and
certifications
(
§
265.192(
g)).
If
an
LQG
storing
hazardous
waste
in
tanks
has
a
release
and
seeks
an
exemption
from
the
24­
hour
waste
removal
requirement
(
§
265.196)(
b)),
he
or
she
may
submit
a
demonstration
that
such
removal
is
not
possible.
Any
LQG
that
releases
hazardous
waste
being
stored
in
a
tank
to
the
environment
must
report
the
release
and
file
a
report
with
the
Regional
Administrator.
Where
any
LQG
repairs
a
tank,
he
or
she
must
obtain
a
major
repair
certification
and
submit
that
certification
to
the
Regional
Administrator
(
§
265.196(
f)).

(
5)
Drip
Pads
LQGs
that
accumulate
hazardous
waste
on
a
drip
pad
may
have
to
prepare,
collect
and/
or
submit
information
as
specified
at
section
262.34(
a)
and
part
265,
subpart
W.
If
they
only
have
infrequent
and
incidental
drippage,
they
may
be
exempt
from
the
drip
pad
requirements,
provided
they
submit
a
contingency
plan
that
describes
their
clean­
up
response
to
such
drippage
4
(
§
265.440(
c)(
1)).
Generators
that
have
an
existing
drip
pad
must
maintain
on
file
an
assessment
of
pad
integrity
(
§
265.441(
a))
and
submit
a
plan
for
upgrading
the
pad
to
regulatory
standards
to
the
Regional
Administrator
(
§
265.441(
b)).
These
generators
also
must
prepare
and
submit
drawings
and
a
certification
of
repairs
or
modifications
to
the
Regional
Administrator
(
§
265.441(
c)).

All
generators
using
drip
pads
must
maintain
on
file
an
assessment
of
the
drip
pad
(
§
265.443(
a)(
4)(
ii)),
maintain
records
of
releases
from
the
pad
in
the
operating
log
(
§
265.443(
m)(
1)(
i)),
and
notify
the
Regional
Administrator
and
provide
written
notice
of
any
release
of
hazardous
waste
from
the
pad
(
§
265.443(
m)(
1)(
iv)).
Should
repairs
be
necessary,
such
hazardous
waste
generators
must
notify
the
Regional
Administrator
of
the
completion
of
repairs
and
provide
certification
of
the
repairs
(
§
265.443(
m)(
3)).
Generators
using
drip
pads
must
document
operating
and
waste
handling
practices
in
an
operating
log
(
§
265.443(
n))
and
place
a
certification
of
the
adequacy
of
the
liner
in
that
log
(
§
265.444(
a)).
Finally,
these
generators
must
maintain
a
description
of
90­
day
waste
removal
practices
(
§
262.34(
a)(
1)(
iii)(
A))
and
document
each
waste
removal
(
§
262.34(
a)(
1)(
iii)(
B)).

(
6)
Containment
Buildings
LQGs
that
accumulate
hazardous
waste
in
a
containment
building
may
have
to
prepare,
collect
and/
or
submit
information
as
specified
in
section
262.34
and/
or
part
265,
subpart
DD.
LQGs
must
place
a
certification
that
the
containment
building
meets
design
requirements
in
the
operating
record
(
§
265.1101(
c)
and
§
262.34(
a)(
1)(
iv))),
enter
a
record
of
any
release
of
hazardous
waste
(
§
265.1101(
c)(
3)(
i)(
A)),
and
notify
the
Regional
Administrator
of
the
release
within
7
days
and
provide
written
notice
within
14
days
(
§
265.1101(
c)(
3)(
i)(
D)).
Generators
repairing
containment
buildings
must
notify
the
Regional
Administrator
of
completion
of
the
repairs
(
§
265.1101(
c)(
3)(
iii)).
LQGs
accumulating
hazardous
waste
in
containment
buildings
must
also
place
monitoring
data
in
the
operating
record
at
least
every
7
days
(
§
265.1101(
c)(
4)),
place
a
description
of
procedures
to
maintain
the
integrity
of
areas
lacking
secondary
containment
in
the
record
(
§
265.1101(
d)),
and
document
that
the
unit
is
emptied
at
least
once
every
90
days
(
§
262.34(
a)(
1)(
iv)(
B)).
Finally,
such
facilities
must
prepare
written
procedures
for
waste
stored
less
than
90
days;
document
waste
generation
and
management
practices;
and
document
that
required
procedures
are
satisfied
(
§
262.34(
a)(
1)(
iv)(
A)).

(
7)
Requests
for
Extensions
of
the
Accumulation
Period
Section
262.34(
b)
allows
LQGs
to
request
from
the
Regional
Administrator
an
extension
(
up
to
30
days)
of
the
accumulation
period
limit.

LARGE
QUANTITY
GENERATOR
AIR
EMISSION
STANDARDS
LQGs
that
accumulate
hazardous
wastes
on
site
for
90
days
or
less
in
tanks
or
containers
without
a
permit
or
interim
status
must
comply
with
40
CFR
part
265,
subparts
AA
(
Air
Emission
5
Standards
for
Process
Vents),
BB
(
Air
Emission
Standards
for
Equipment
Leaks),
and
CC
(
Air
Emission
Standards
for
Tanks,
Surface
Impoundments,
and
Containers),
as
applicable.

(
1)
Air
Emissions
from
Process
Vents
In
40
CFR
part
265,
subpart
AA,
EPA
promulgated
regulations
governing
emissions
to
air
from
process
vents
associated
with
distillation,
fractionation,
thin­
film
evaporation,
solvent
extraction,
or
air
or
steam
stripping
operations
that
manage
hazardous
wastes
with
organic
concentrations
of
at
least
10­
ppmw
if
the
unit:
is
subject
to
the
permitting
requirements
of
40
CFR
part
270;
is
not
exempt
from
permitting
under
the
provisions
of
40
CFR
262.34(
a)
(
i.
e.,
a
hazardous
waste
recycling
unit
that
is
not
a
90­
day
tank
or
container)
and
is
located
at
a
hazardous
waste
management
facility
otherwise
subject
to
the
permitting
requirements
of
40
CFR
part
270;
or
is
exempt
from
permitting
under
the
provisions
of
40
CFR
262.34(
a)
(
i.
e.,
a
90­
day
tank
or
container)
and
is
not
a
recycling
unit
under
40
CFR
261.6.
To
comply
with
these
regulations,
respondents
must
submit
several
information
collections,
including
some
or
all
of
the
following:

!
Documentation
describing
the
operation
of
and
identifying
process
parameters
that
indicate
proper
operation
and
maintenance
of
control
devices
other
than
those
specified
under
this
part;

!
Documentation
of
waste
determination,
if
the
waste
determination
was
based
on
knowledge
of
the
waste
rather
than
testing
(
§
265.1034(
d)(
2));
and
!
An
operating
record
containing
documentation
specified
in
section
265.1035(
b)­
(
f)(
§
265.1035(
b)).

(
2)
Air
Emissions
from
Equipment
Leaks
In
40
CFR
part
265,
subpart
BB,
EPA
promulgated
regulations
governing
emissions
to
air
from
equipment
that
contains
or
contacts
hazardous
wastes
with
organic
concentrations
of
at
least
10
percent
by
weight
if
the
unit:
is
subject
to
the
permitting
requirements
of
40
CFR
part
270;
is
not
exempt
from
permitting
under
the
provisions
of
40
CFR
262.34(
a)
(
i.
e.,
a
hazardous
waste
recycling
unit
that
is
not
a
90­
day
tank
or
container)
and
is
located
at
a
hazardous
waste
management
facility
otherwise
subject
to
the
permitting
requirements
of
40
CFR
part
270;
or
is
exempt
from
permitting
under
the
provisions
of
40
CFR
262.34(
a)
(
i.
e.,
a
90­
day
tank
or
container)
and
is
not
a
recycling
unit
under
40
CFR
261.6.
To
comply
with
these
regulations,
respondents
must
submit
several
information
collections,
including
some
or
all
of
the
following:

!
Notification
that
an
owner/
operator
has
decided
to
implement
the
alternative
valves
in
gas/
vapor
service
or
in
light
liquid
service
standard
specified
in
section
265.1061(
a)
(
§
265.1061(
b)(
1));
6
!
Notification
that
an
owner/
operator
no
longer
implementing
the
alternative
standard
specified
in
section
265.1061(
a)
will
follow
the
work
practice
standards
in
section
265.1057(
a)
through
(
e)
(
§
265.1061(
d));

!
Notification
that
an
owner/
operator
has
decided
to
implement
the
alternative
standard
for
valves
specified
in
either
section
265.1062(
b)(
2)
or
(
b)(
3)
(
§
265.1062(
a)(
2));

!
Documentation
of
the
determination
that
each
piece
of
equipment
does
or
does
not
contain
or
contact
hazardous
waste
with
organic
concentration
that
equals
or
exceeds
10
percent
by
weight,
if
this
determination
was
based
on
knowledge
rather
than
testing
(
§
265.1063(
d)(
3));
and
!
Unit
operating
record
containing
documentation
specified
in
section
265.1064(
b)­
(
m)
(
§
265.1064(
b)).

(
3)
Air
Emissions
from
Tanks,
Surface
Impoundments,
and
Containers
In
40
CFR
part
265,
subpart
CC,
EPA
promulgated
regulations
governing
emissions
to
air
from
containers,
tanks,
and
surface
impoundments
subject
to
either
subparts
I,
J
or
K,
except
as
otherwise
specified.
[
Note:
The
subpart
CC
requirements
are
not
addressed
in
this
ICR.
They
are
examined
in
the
ICR
entitled,
"
Subpart
CC
­
Standards
of
Performance
for
Air
Emission
Standards
for
Tanks,
Surface
Impoundments
and
Containers,"
ICR
Number
1593.]

SMALL
QUANTITY
GENERATOR
PRE­
TRANSPORT
REQUIREMENTS
Generators
who
generate
more
than
100
kilograms
and
less
than
1,000
kilograms
of
nonacute
hazardous
waste
in
a
calendar
month
and
less
than
1
kilogram
of
acute
hazardous
waste
in
a
calendar
month
are
small
quantity
generators
(
SQGs).
SQGs
may
accumulate
up
to
6,000
kilograms
of
hazardous
waste
for
180
days
(
or
270
days
if
the
generator
must
transport
the
waste
more
than
200
miles
to
a
hazardous
waste
management
facility)
without
a
permit
or
interim
status
if
they
comply
with
the
requirements
in
part
262.
Applicable
information
collection
requirements
for
SQGs
include
labeling
of
containers
or
tanks
as
required
by
section
262.34(
a)(
2)
and
(
3)
for
180­
or
270­
day
accumulation
areas
and
by
section
262.34(
c)(
1)
and
(
2)
for
satellite
accumulation
areas.
In
addition,
section
262.34(
d)
references
section
265.37(
b),
which
requires
SQGs
to
document
if
State
or
local
authorities
decline
to
enter
into
arrangements
to
become
familiar
with
the
site
and
section
262.34(
d)(
5)(
ii),
which
requires
posting
of
emergency
information
near
the
phone.
Section
262.34(
d)(
5)(
iv)
requires
SQGs
to
notify
and
provide
information
to
the
fire
department
in
the
event
of
a
fire,
or
the
National
Response
Center
immediately
in
the
event
of
a
fire,
explosion,
or
other
release
which
could
threaten
human
health
outside
the
facility
or
when
the
generator
has
knowledge
that
a
spill
has
reached
surface
water.
Finally,
section
262.34(
f)
allows
SQGs
to
request
from
the
Regional
Administrator
an
extension
(
up
to
30
days)
of
the
accumulation
period
limit.
7
2
Although
the
OECD
Decision
requires
the
use
of
a
tracking
document,
the
OECD
only
recommends
forms
for
notification
and
tracking
purposes.
Neither
the
OECD
nor
the
U.
S.
requires
their
use.
Therefore,
OECD
member
countries
are
allowed
to
use
any
document,
provided
all
of
the
required
information
is
contained
in
the
document.
If
OECD
decides
to
require
the
use
of
OECD
forms,
EPA
will
codify
this
requirement
and
assess
the
burden.
RECORDKEEPING
AND
REPORTING
REQUIREMENTS
All
generators
(
both
LQGs
and
SQGs)
must
comply
with
the
recordkeeping
and
reporting
requirements
detailed
in
sections
262.40
and
.43.
Section
262.40(
c)
requires
generators
to
keep
records
of
any
test
results,
waste
analyses,
or
other
determinations
for
at
least
three
years.
The
period
of
recordkeeping
is
automatically
extended
during
enforcement
actions,
and
by
the
request
of
the
Administrator.
Section
262.43
requires
generators
to
furnish
additional
reports
regarding
the
volume
and
nature
of
their
hazardous
wastes,
as
deemed
necessary
by
the
Administrator.

EXPORT
AND
IMPORT
REQUIREMENTS
All
generators
(
both
LQGs
and
SQGs)
must
comply
with
the
export
requirements
detailed
in
sections
262.52
­
.57,
if
applicable.
These
requirements
apply
to
"
primary
exporters,"
individuals
originating
a
manifest
for
the
export
of
a
shipment
of
hazardous
waste,
and
intermediaries
arranging
the
shipment
(
e.
g.,
brokers).
Persons
meeting
the
definition
of
"
primary
exporter"
are
required
to
notify
EPA
of
their
intention
to
export
hazardous
waste,
renotify
EPA
if
the
conditions
of
the
original
notification
are
altered,
file
an
Annual
Report
with
the
Administrator
summarizing
the
types,
quantities,
frequencies,
and
ultimate
destination
of
all
hazardous
wastes
exported
during
the
previous
year,
and
keep
copies
of
relevant
documents
for
a
period
of
three
years.
40
CFR
part
262,
subpart
H
requires
similar
notification
by
US
exporters
of
hazaroudous
waste
to
any
OECD
member
country,
however
some
additional
informaiton
is
required
as
part
of
the
Notification
of
Intent
to
Export
to
these
countries.
Futher,
EPA
may
also
request
that
primary
exporters
provide
additional
information,
as
requested
by
the
receiving
country.

Under
the
part
262,
subpart
E
export
regulations,
U.
S.
exporters
also
must
complete
and
transmit
a
Uniform
Hazardous
Waste
Manifest.
The
OECD
Decision
requires
exporters
of
hazardous
waste
to
complete
and
transmit
a
tracking
document.
2
Some
information
required
in
the
tracking
document
exceeds
that
presently
required
for
the
hazardous
waste
manifest.
Most
of
the
additional
information
required
for
the
tracking
document
under
the
OECD
Decision
is
information
necessary
for
the
OECD
Notification
of
Intent
to
Export.
A
tracking
document
is
required
each
time
an
export
shipment
of
hazardous
waste
is
initiated.
This
ICR
adresses
only
the
additional
data
elements,
and
not
the
basic
US
manifest
requirements,
which
are
addressed
in
ICR
Number
801.

Under
the
non­
OECD
hazardous
waste
import
regulations,
U.
S.
hazardous
waste
management
facilities
regulated
under
40
CFR
part
264
or
265
must
notify
EPA
at
least
four
weeks
prior
to
the
date
of
receipt
of
hazardous
waste
imports.
Importing
facilities
must
confirm
receipt
of
the
shipment
by
sending
a
signed
copy
of
the
manifest
to
the
generator,
e.
g.,
foreign
8
generator
or
U.
S.
importer
(
40
CFR
part
262,
subpart
F).
The
OECD
Decision
also
requires
recovery
facilities
importing
hazardous
waste
into
the
U.
S.
to
return
signed
copies
of
the
tracking
document
to
the
foreign
exporter
and
competent
authorities
of
the
concerned
countries
(
exporting,
importing,
and
transit,
if
any).
The
OECD
Decision
did
not
significantly
change
the
previously
existing
requirements,
but
required
the
signing
and
transmission
of
additional
copies
of
the
tracking
document
and
an
expedition
of
this
process
(
three
working
days
instead
of
30
days).

ZINC
FERTILIZERS
MADE
FROM
RECYCLED
HAZARDOUS
SECONDARY
MATERIALS
EPA
has
revised
regulations
at
part
261
that
apply
to
recycling
of
hazardous
secondary
materials
to
make
zinc
fertilizer
products.
Under
the
Rule,
zinc
fertilizer
manufacturers
and
their
suppliers
are
able
to
manage
hazardous
secondary
materials
outside
the
current
RCRA
management
system,
provided
they
meet
certain
conditions
involving
storage
of
the
material,
and
reporting
and
recodkeeping.
in
this
sense
the
rule
is
deregulatory
in
nature
and
relieves
industry
from
a
number
of
information
collection
requirements
that
would
otherwise
apply.
This
ICR
reflects
the
decreased
burden
for
these
generators,
and
a
separate
ICR
is
no
longer
necessary.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
NEED
AND
AUTHORITY
FOR
THE
COLLECTION
Under
sections
3001(
d)
and
3002
of
RCRA,
EPA
is
required
to
promulgate
regulations
applicable
to
generators
of
hazardous
waste
as
necessary
to
protect
human
health
and
the
environment.

HAZARDOUS
WASTE
DETERMINATION
REQUIREMENTS
Under
RCRA
section
3001,
Congress
authorized
EPA
to
develop
and
promulgate
criteria
for
identifying
the
characteristics
of
hazardous
waste,
and
for
listing
hazardous
waste,
which
would
be
subject
to
the
hazardous
waste
program.
In
implementing
this
mandate,
EPA
created
the
hazardous
waste
determination
requirements
at
40
CFR
262.11.
These
requirements
provide
that
generators
must
determine
if
their
solid
waste
is
listed
or
exhibits
a
hazardous
characteristic
based
on
testing
or
knowledge
of
the
waste.
Hazardous
waste
determination
requirements
are
needed
to
ensure
that
generators
and
subsequent
handlers
manage
and
dispose
of
the
hazardous
waste
in
compliance
with
the
hazardous
waste
program.

LARGE
QUANTITY
GENERATOR
PRE­
TRANSPORT
REQUIREMENTS
(
1)
Labeling
Section
262.34(
a)
and
(
c)
require
LQGs
to
label
containers
and
tanks
as
specified
(
e.
g.,
with
the
date
accumulation
began
and
the
words,
"
Hazardous
Waste").
EPA
and
LQGs
need
information
on
the
time
waste
began
accumulating
for
enforcement
and
monitoring
purposes.
9
(
2)
Personnel
Training
Section
262.34(
a)(
4)
requires
LQGs
to
maintain
copies
of
personnel
training
documents
and
records
(
under
§
265.16(
d)
and
(
e))
at
their
facilities.
Both
EPA
and
LQGs
need
information
in
personnel
training
records
to
determine
whether
employees
have
acquired
the
necessary
expertise
to
perform
their
jobs.
EPA
also
needs
this
information
to
review
personnel
records
to
determine
whether
employees
are
receiving
a
level
of
training
that
is
commensurate
with
their
duties
and
responsibilities
as
well
as
their
ability
to
respond
to
any
emergency
situations
at
the
facility.
Requiring
generators
to
maintain
personnel
training
documents
decreases
the
likelihood
that
employees
are
unqualified
to
handle
hazardous
waste
or
respond
to
emergencies.
The
personnel
recordkeeping
requirement
contributes
to
EPA's
goal
of
minimizing
the
potential
for
employee­
related
mistakes
that
may
threaten
human
health
and
the
environment.

(
3)
Contingency
Planning
and
Emergency
Procedures
Under
section
262.34(
a)(
4),
LQGs
must
comply
with
subparts
C
and
D
of
part
265,
which
detail
requirements
for
contingency
plans
for
effective
action
to
minimize
unanticipated
damage
from
the
accumulation
of
any
hazardous
waste.
These
regulations
require
LQGs
to
record
whether
State
or
local
authorities
declined
to
enter
into
arrangement
to
become
more
familiar
with
the
generator's
facility
and
its
wastes,
prepare
and
maintain
contingency
plans,
and
prepare
emergency
reports
whenever
imminent
or
actual
emergency
situations
occur.
EPA
inspectors
may
review
the
contingency
plans
to
determine
whether
LQGs
have
developed
adequate
procedures
to
respond
to
unplanned
sudden
or
non­
sudden
releases
of
hazardous
waste
or
hazardous
constituents
to
air,
soil,
or
surface
water.
Requiring
LQGs
to
develop
and
maintain
contingency
plans
and
prepare
emergency
response
reports
contributes
to
EPA's
goal
of
minimizing
unanticipated
damage
from
the
accumulation
of
hazardous
waste
at
generator
sites.

(
4)
Tank
Systems
Under
section
262.34(
a)(
1)(
ii),
EPA
requires
LQGs
that
accumulate
hazardous
waste
in
tank
systems
to
comply
with
subpart
J
of
part
265.
These
requirements
ensure
that
LQGs
only
operate
tank
systems
that
are
fully
protective
of
human
health
and
the
environment
and
that,
if
releases
to
the
environment
occur,
action
is
taken
immediately.
These
requirements
also
contribute
to
EPA's
goal
of
preventing
contamination
of
the
environment
from
hazardous
waste
accumulation
practices.
10
(
5)
Drip
Pads
Under
section
262.34(
a)(
1)(
iii),
EPA
requires
LQGs
that
accumulate
hazardous
waste
on
drip
pads
to
comply
with
subpart
W
of
part
265,
as
well
as
to
describe
and
document
waste
removal.
These
requirements
ensure
that
drip
pads
are
designed
and
used
in
a
manner
that
is
11
protective
of
human
health
and
the
environment.
The
information
collection
requirements
document
the
proper
design
and
use
of
this
type
of
unit.

(
6)
Containment
Buildings
Under
section
262.34(
a)(
1)(
iv),
EPA
requires
LQGs
that
accumulate
hazardous
waste
in
containment
buildings
to
comply
with
subpart
DD
of
part
265,
as
well
as
to
document
the
existence
of
procedures
that
ensure
the
waste
remains
in
the
unit
for
no
more
than
90
days,
that
waste
generation
and
management
practices
are
consistent
with
90­
day
storage,
that
these
procedures
are
complied
with,
and
that
the
unit
is
emptied
at
least
every
90
days.
These
requirements
ensure
that
containment
buildings
are
designed
and
used
in
a
manner
that
is
protective
of
human
health
and
the
environment.
The
information
collection
requirements
document
the
proper
design
and
use
of
this
type
of
unit.

(
7)
Requests
for
Extensions
of
the
Accumulation
Period
EPA
promulgated
regulations
in
section
262.34(
b)
allowing
LQGs
to
request
from
the
Regional
Administrator
extensions
(
up
to
30
days)
of
the
accumulation
period
limit
due
to
unforeseen,
temporary,
and
uncontrollable
circumstances.
EPA
needs
information
about
the
extension
to
evaluate
the
cause
of
the
generators'
requests
for
extensions
and
to
approve/
deny
requests.
These
requirements
ensure
that
only
generators
genuinely
in
need
of
an
extension
are
allowed
to
accumulate
wastes
longer
than
90
days,
and
contribute
to
EPA's
goal
of
preventing
contamination
of
the
environment.

LARGE
QUANTITY
GENERATOR
AIR
EMISSION
STANDARDS
(
1)
Air
Emissions
from
Process
Vents
In
40
CFR
part
265,
subpart
AA,
EPA
promulgated
regulations
governing
emissions
to
air
from
process
vents
associated
with
distillation,
fractionation,
thin­
film
evaporation,
solvent
extraction,
or
air
or
steam
stripping
operations
that
manage
hazardous
wastes
with
organic
concentrations
of
at
least
10­
ppmw
if
the
unit:
is
subject
to
the
permitting
requirements
of
40
CFR
part
270;
is
not
exempt
from
permitting
under
the
provisions
of
40
CFR
262.34(
a)
(
i.
e.,
a
hazardous
waste
recycling
unit
that
is
not
a
90­
day
tank
or
container)
and
is
located
at
a
hazardous
waste
management
facility
otherwise
subject
to
the
permitting
requirements
of
40
CFRp
270;
or
is
exempt
from
permitting
under
the
provisions
of
40
CFR
262.34(
a)
(
i.
e.,
a
90­
day
tank
or
container).
EPA
needs
information
from
generator
facilities
concerning
hazardous
waste
releases
to
air
from
process
vents
to
ensure
that
activities
and
control
devices
used
by
such
facilities
are
consistent
with
EPA's
goal
of
preventing
contamination
of
the
environment.

(
2)
Air
Emissions
from
Equipment
Leaks
In
40
CFR
part
265,
subpart
BB,
EPA
promulgated
regulations
governing
emissions
to
air
12
from
equipment
that
contains
or
contacts
hazardous
wastes
with
organic
concentrations
of
at
least
10
percent
by
weight
if
the
unit:
is
subject
to
the
permitting
requirements
of
40
CFR
part
270;
is
not
exempt
from
permitting
under
the
provisions
of
40
CFR
262.34(
a)
(
i.
e.,
a
hazardous
waste
recycling
unit
that
is
not
a
90­
day
tank
or
container)
and
is
located
at
a
hazardous
waste
management
facility
otherwise
subject
to
the
permitting
requirements
of
40
CFR
part
270;
or
is
exempt
from
permitting
under
the
provisions
of
40
CFR
262.34(
a)
(
i.
e.,
a
90­
day
tank
or
container).
EPA
needs
information
from
generator
facilities
concerning
hazardous
waste
releases
to
air
from
equipment
leaks
to
ensure
that
activities
and
equipment
used
by
such
facilities
are
consistent
with
EPA's
goal
of
preventing
contamination
of
the
environment.

SMALL
QUANTITY
GENERATOR
PRE­
TRANSPORT
REQUIREMENTS
(
1)
Labeling
Section
262.34(
a)(
2)
and
(
3)
and
(
c)
require
SQGs
to
label
their
containers
and
tanks
as
specified
(
e.
g.,
with
the
words
"
Hazardous
Waste"
and
the
date
that
accumulation
began).
This
information
assists
SQGs
and
EPA
to
monitor
and
enforce
the
accumulation
requirements.

(
2)
Emergency
Procedures
EPA
promulgated
regulations
in
Section
262.34
requiring
SQGs
to
immediately
notify
the
fire
department
in
the
event
of
a
fire,
or
the
National
Response
Center
in
the
event
of
a
fire,
explosion,
or
other
release
which
could
threaten
human
health
outside
the
facility,
or
when
SQGs
have
knowledge
that
a
spill
has
reached
surface
water.
Applicable
provisions
also
require
SQGs
to
document
if
State
or
local
authorities
decline
to
enter
into
arrangements
to
become
familiar
with
the
site,
and
require
SQGs
to
post
emergency
information
near
the
phone.
EPA
needs
this
information
in
order
to
evaluate
and,
if
necessary,
respond
to
releases
of
hazardous
waste
into
the
environment.
It
also
increases
the
likelihood
that
appropriate
procedures
are
in
place
in
case
of
an
emergency.
This
information
also
contributes
to
EPA's
goal
of
quickly
responding
to,
and
minimizing
the
deleterious
effects
of,
hazardous
waste
releases
into
the
environment.

(
3)
Requests
for
Extensions
of
the
Accumulation
Period
EPA
promulgated
regulations
in
section
262.34(
f)
allowing
SQGs
to
request
from
the
Regional
Administrator
extensions
(
up
to
30
days)
of
the
accumulation
period
limit
for
unforeseen,
temporary,
and
uncontrollable
circumstances.
EPA
needs
information
about
the
extension
to
evaluate
the
cause
of
the
generators'
requests
for
extensions
and
to
approve/
deny
requests.
These
requirements
ensure
that
only
generators
genuinely
in
need
of
an
extension
are
allowed
to
accumulate
wastes
longer
than
180/
270
days
(
depending
on
the
distance
to
an
off­
site
destination),
and
contribute
to
EPA's
goal
of
preventing
contamination
of
the
environment.

RECORDKEEPING
AND
REPORTING
REQUIREMENTS
13
Authority
for
the
recordkeeping
requirements
is
derived
from
RCRA
sections
2002
and
3002.
In
section
3002(
a)(
5),
Congress
directed
EPA
to
establish
requirements
regarding
"
recordkeeping
practices
that
accurately
identify
the
quantities
of
such
hazardous
waste
generated,
the
constituents
thereof
which
are
significant
in
quantity
or
in
potential
harm
to
human
health
or
the
environment,
and
the
disposition
of
such
wastes."
In
section
2002(
a)(
1),
Congress
authorized
the
Administrator
to
"
prescribe,
in
consultation
with
Federal,
State,
and
Regional
authorities,
such
regulations
as
are
necessary
to
carry
out
his
functions."
By
requiring
generators
to
keep
copies
of
test
results,
waste
analyses,
or
other
records
documenting
that
a
waste
is
hazardous
and
to
submit
additional
reports
requested
by
EPA,
EPA
will
have
a
better
understanding
of
which
waste
streams
at
a
facility
are
hazardous
wastes.
In
addition,
generators
will
have
more
immediate
access
to
the
information
describing
their
hazardous
wastes'
composition;
this
information
may
be
extremely
important
to
prevent
accidental
releases
(
along
with
the
resulting
environmental
and
human
health
problems).
Finally,
this
information
may
be
useful
to
the
generators
in
complying
with
reporting
requirements
of
other
environmental
laws.

EXPORT
AND
IMPORT
REQUIREMENTS
Authority
for
the
export
informational
requirements
is
derived
from
RCRA
section
3017.
Section
3017
directs
EPA
to
implement
requirements
for
individuals
exporting
hazardous
waste
from
the
United
States,
including
a
notification
of
the
intent
to
export,
and
an
Annual
Report
summarizing
the
types,
quantities,
frequency,
and
ultimate
destination
of
all
exported
hazardous
waste.
EPA
also
added
additional
requirements
for
generators
to
renotify
the
EPA
if
the
conditions
of
the
original
notification
are
altered
and
keep
copies
of
relevant
documents
for
a
period
of
three
years.
EPA
needs
this
additional
information
to
ensure
that
foreign
governments
consent
to
U.
S.­
exported
waste,
to
document
that
exported
waste
is
actually
managed
at
facilities
listed
in
the
original
notifications,
and
to
guarantee
that
these
documents
are
available
for
compliance
audits
and
any
enforcement
actions.
These
requirements
contribute
to
EPA's
goal
of
ensuring
that
all
hazardous
waste
generated
in
the
United
States
is
managed
in
a
manner
protective
of
human
health
and
the
environment.

EPA
may
also
request
that
primary
exporters
provide
additional
information,
as
requested
by
the
receiving
country.

2(
b)
USE
AND
USERS
OF
THE
DATA
HAZARDOUS
WASTE
DETERMINATION
REQUIREMENTS
Hazardous
waste
generators
must
follow
the
waste
determination
requirements
at
40
CFR
262.11
to
ensure
that
they
fully
and
accurately
determine
whether
their
solid
wastes
qualify
as
RCRA
hazardous
wastes.
Generators
who
determine
their
solid
waste
to
be
hazardous
must
handle
and
dispose
of
the
waste
in
compliance
with
the
hazardous
waste
program.
Generators
14
have
the
flexibility
to
use
either
testing
or
knowledge
of
the
waste
in
making
their
determinations.

LARGE
QUANTITY
GENERATOR
PRE­
TRANSPORT
REQUIREMENTS
(
1)
Labeling
LQGs
use
the
labeling
information
to
maintain
compliance
with
RCRA
requirements.

(
2)
Personnel
Training
Both
EPA
and
LQGs
use
information
in
the
personnel
training
records
to
ensure
that
personnel
acquire
the
necessary
expertise
to
perform
their
jobs.
During
inspections,
EPA
reviews
job
descriptions
and
training
documents
to
determine
whether
each
person
is
receiving
a
level
of
training
that
is
commensurate
with
the
person's
duties
and
responsibilities
as
well
as
the
ability
to
respond
to
any
emergency
situations
at
the
facility.

(
3)
Contingency
Plan
and
Emergency
Procedures
Local
emergency
response
teams,
LQGs,
and
EPA
use
information
included
in
the
contingency
plan
to
assure
an
appropriate
response
to
any
unplanned
release
of
hazardous
waste
or
hazardous
waste
constituents.
EPA
reviews
information
in
the
contingency
plan
and
emergency
report
to
determine
whether
additional
site­
specific
emergency
provisions
are
necessary.

EPA,
as
well
as
local
and
State
government
agencies
responding
to
any
releases,
uses
the
information
submitted
by
LQGs
under
section
262.34
to
document
and
respond
to
any
spills
or
other
unplanned
releases
of
hazardous
wastes
into
the
environment.

(
4)
Tank
Systems
In
section
262.34(
a)(
1),
EPA
requires
LQGs
that
accumulate
hazardous
waste
in
tank
systems
to
comply
with
standards
detailed
in
part
265
subpart
J.
The
following
lists
each
information
collection
requirement
that
applies
to
tank
systems
and
describes
how
EPA
uses
the
information.

!
A
no­
free­
liquids
demonstration
(
§
265.190(
a)).
EPA
uses
this
demonstration
to
decide
whether
it
may
exempt
LQGs
that
meet
this
and
other
conditions
(
using
tanks
that
contain
no
free
liquids
and
are
situated
in
a
building
with
an
impermeable
floor)
from
the
requirements
of
section
265.193.

!
Existing
tank
system
assessments
(
§
265.191).
EPA
uses
this
information
to
assure
that
LQGs
operating
tank
systems
without
secondary
containment
carefully
evaluate
the
tank
systems'
primary
containment
capability
to
ensure
that
the
tank
systems
are
not
leaking.

!
New
tank
system
assessments
and
certifications
(
§
265.192).
EPA
uses
new
tank
system
assessments
and
certifications
to
assure
that
any
new
system
components
15
installed
at
the
LQG
facilities
are
appropriate
for
and
will
adequately
contain
hazardous
waste.

!
An
equivalent
containment
exemption
(
§
265.193(
d)(
4)).
EPA
may
grant
this
exemption
to
LQGs
that
can
demonstrate
that
their
release
containment
system
is
equivalent
to
a
liner,
vault,
or
double­
walled
tank.
This
exemption
lessens
the
burden
on
LQGs
without
compromising
public
health
or
the
environment.

!
An
exemption
from
the
24­
hour
leak
detection
requirement
(
§
265.193(
e)(
3)(
iii)).
EPA
may
grant
this
exemption
to
LQGs
that
can
demonstrate
that
existing
technologies
or
site
conditions
will
not
allow
detection
of
a
leak
within
24
hours.
This
exemption
allows
these
LQGs
to
use
a
system
that
will
detect
failure
and
contamination
at
the
earliest
practicable
time.

!
A
variance
from
the
secondary
containment
requirements
(
§
265.193(
g)).
EPA
may
grant
LQGs
a
variance
from
all
secondary
containment
requirements
if
they
can
demonstrate
that
alternative
design
and
operating
principles,
together
with
location
characteristics,
will
be
as
protective
of
the
environment
as
secondary
containment.
This
variance
lessens
the
burden
on
LQGs
without
compromising
public
health
or
the
environment.

!
A
notification
of
intent
to
conduct
and
submit
a
demonstration
for
a
variance
from
secondary
containment
(
§
265.193(
h)).
The
Regional
Administrator
must
be
notified
of
the
intent
of
an
owner
or
operator
to
conduct
and
submit
a
demonstration
for
a
variance
from
secondary
containment
so
that
EPA
can
evaluate
and
the
public
can
participate
in
the
process
and
to
reduce
the
burden
and
costs
without
compromising
protection
of
human
health
and
the
environment.

!
Annual
leak
tests
and
inspections
for
LQGs
using
tests
that
do
not
meet
the
secondary
containment
requirements
(
§
265.193(
i)).
EPA
uses
this
information
to
ensure
that
hazardous
wastes
are
not
leaking
into
the
environment.

!
An
exemption
from
the
24­
hour
waste
removal
requirement
(
§
265,196(
b)).
EPA
uses
information
submitted
by
LQGs
under
these
sections
to
decide
whether
to
grant
the
exemptions.
EPA
regulations
require
facilities
at
which
there
has
been
a
spill
to
remove,
within
24
hours,
enough
waste
from
the
system
to
prevent
further
release
and
allow
for
inspection
and
repair
of
the
tank.
If
the
LQG
can
demonstrate
that
it
is
not
possible
to
do
so
within
24
hours,
EPA
will
allow
the
LQG
to
remove
the
waste
at
the
earliest
practicable
time.

!
Release
notifications
and
reports,
and
major
repair
certifications
(
§
265.196(
d)
and
(
f)).
EPA
uses
release
notifications
and
reports
to
document
hazardous
waste
releases
and
track
the
progress
of
their
cleanup.
In
cases
in
which
a
release
has
been
caused
by
major
system
damage,
the
Agency
uses
the
certifications
to
document
that
the
system
has
been
adequately
repaired.

(
5)
Drip
Pads
16
EPA
requires
LQGs
that
accumulate
hazardous
waste
on
drip
pads
to
comply
with
contingency
plan,
assessment,
upgrading,
repair,
and
release­
related
information
collection
requirements,
as
well
as
to
document
the
proper
use
of
drip
pads
and
compliance
with
90
day
waste
removal
requirements
(
§
262.34(
a)(
1)(
iii))).
EPA
uses
these
data
to
ensure
that
drip
pads
are
protective
of
health
and
the
environment
and
are
designed,
improved,
repaired
and
used
in
a
manner
that
is
environmentally
sound.
Moreover,
EPA
uses
this
information
to
document
compliance
with
the
limitations
placed
on
generators
using
drip
pads
for
90­
day
accumulation.

(
6)
Containment
Buildings
EPA
requires
LQGs
that
accumulate
hazardous
waste
in
containment
buildings
to
comply
with
certification,
release
notification,
repair,
and
design­
related
requirements,
as
well
as
to
document
the
existence
of
storage
procedures
that
ensure
the
waste
remains
in
the
unit
for
no
more
than
90
days,
that
waste
generation
and
management
practices
are
consistent
with
90­
day
storage,
that
these
procedures
are
complied
with,
or
that
the
unit
is
emptied
at
least
every
90
days
(
§
262.34(
a)(
1)(
iv)).
EPA
uses
this
data
to
ensure
that
the
containment
building
is
designed
according
to
applicable
standards,
that
releases
are
reported
and
documented,
and
that
necessary
repairs
are
documented.
The
Agency
also
uses
this
information
to
document
compliance
with
the
90­
day
limit
on
waste
storage.
Overall,
these
requirements
ensure
that
containment
buildings
are
used
in
a
manner
that
is
protective
of
human
health
and
the
environment.

(
7)
Requests
for
Extensions
of
the
Accumulation
Period
EPA
uses
the
information
submitted
in
the
accumulation
extension
period
request
to
determine
whether
a
generator
should
be
granted
additional
time
to
accumulate
waste
on
site
in
unforeseen,
temporary,
and
uncontrollable
circumstances.

LARGE
QUANTITY
GENERATOR
AIR
EMISSION
STANDARDS
(
1)
Air
Emissions
from
Process
Vents
Records
and
reports
required
in
40
CFR
part
265,
subpart
AA
are
used
to
enable
EPA
to:
(
1)
identify
generators
that
are
not
in
compliance
with
the
standard
and
(
2)
ensure
that
the
standards
required
by
section
3004(
n)
are
being
implemented
effectively.
Based
on
reported
information,
EPA
can
decide
how
many
generator
inspections
will
be
needed,
which
generators
should
be
inspected,
and
what
records
or
processes
should
be
reviewed
at
the
generator
unit.
The
records
that
generators
will
maintain
will
play
a
significant
role
for
the
unit
owner
or
operator
in
assessing
unit
personnel
efforts
and
in
determining
whether
the
unit
is
in
compliance
with
the
standard.
The
records
will
reveal
misunderstandings
about
how
the
standard
is
to
be
implemented.

(
2)
Air
Emissions
from
Equipment
Leaks
Records
and
reports
required
in
40
CFR
part
265,
subpart
BB
are
used
for
the
same
purposes
as
the
information
required
under
subpart
AA,
e.
g.,
to
identify
generators
that
are
not
in
17
compliance
with
the
standards
and
take
enforcement
action,
if
needed.

SMALL
QUANTITY
GENERATOR
PRE­
TRANSPORT
REQUIREMENTS
(
1)
Labeling
SQGs
use
the
labeling
requirements
to
ensure
compliance
with
accumulation
and
handling
requirements.

(
2)
Emergency
Procedures
EPA,
as
well
as
local
and
State
government
agencies
responding
to
any
releases,
uses
the
information
submitted
by
SQGs
under
section
262.34(
d)(
5)
to
document
and
respond
to
any
spills
or
other
unplanned
releases
of
hazardous
wastes
into
the
environment.
EPA
also
uses
this
information
to
assess
the
needs
and
state
of
readiness
of
generators
and
to
facilitate
appropriate
responses
in
cases
of
an
emergency.

(
3)
Requests
for
Extensions
of
the
Accumulation
Period
EPA
uses
the
information
submitted
in
the
accumulation
period
extension
to
determine
whether
an
SQG
should
be
granted
additional
time
to
accumulate
waste
on
site
in
unforeseen,
temporary,
or
uncontrollable
circumstances.

RECORDKEEPING
AND
REPORTING
REQUIREMENTS
In
monitoring
compliance
and
enforcing
regulations,
EPA
relies
on
the
recordkeeping
requirements
in
sections
262.40
and
.43
to
provide
a
record
of
generators'
hazardous
waste
generation,
determination
status
(
e.
g.,
testing),
and
its
eventual
disposition.

EXPORT
AND
IMPORT
REQUIREMENTS
EPA
uses
the
information
submitted
by
primary
exporters
to
notify
and
seek
consent
of,
in
conjunction
with
the
Department
of
State,
the
receiving
country
and
any
transit
country
of
the
export
of
hazardous
waste.
EPA
also
uses
the
export
information
to
document
that
hazardous
wastes
being
shipped
to
foreign
treatment,
storage,
and
disposal
facilities
are
not
diverted
to
other
destinations.
EPA
uses
information
from
importers
to
determine
the
number,
origin,
destination
and
type
of
imports
to
the
U.
S.
for
tracking
purposes
and
for
reporting
to
the
OECD
as
required
by
treaty.
This
information
is
also
used
to
assess
the
efficiency
of
the
program.
18
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
NONDUPLICATION
Most
of
the
information
required
by
the
regulations
covered
by
this
ICR
are
not
available
from
any
source
but
the
respondents.
In
certain
occasions,
such
as
the
notification
of
intent
to
export
hazardous
waste,
EPA
allows
the
primary
exporter
to
submit
one
notice
that
covers
activities
over
a
period
of
twelve
months.

Although
some
of
the
information
required
for
the
hazardous
waste
manifest
and
the
tracking
document
is
substantively
the
same,
up
to
six
pieces
of
additional
information
are
required
for
the
tracking
document.
In
addition,
these
two
documents
serve
different
purposes.
A
signed
copy
of
the
hazardous
waste
manifest,
which
is
not
valid
beyond
U.
S.
borders,
is
dropped
off
at
the
U.
S.
Customs
check
point
when
the
shipment
leaves
the
U.
S.
to
verify
pertinent
information,
including
point
of
departure,
date,
destination,
and
contents
of
the
shipment.
The
tracking
document
must
accompany
the
shipment
until
it
reaches
the
foreign
recovery
facility.
The
signed
tracking
document
is
subsequently
returned
to
EPA
and
the
U.
S.
exporter
to
acknowledge
receipt
of
the
shipment
in
accordance
with
the
OECD
Decision.

In
certain
cases,
some
of
the
information
on
the
tracking
document
also
may
be
collected
by
the
Department
of
Commerce
in
its
Census
Bureau
form
titled
"
Shipper's
Export
Declaration"
(
15
CFR
part
30).
This
form,
which
is
required
for
all
shipments
that
have
a
value
in
excess
of
$
1,500,
must
be
filed
at
the
U.
S.
port
of
exit,
similar
to
the
current
export
requirements.
However,
the
information
contained
in
the
Census
Bureau's
form
is
not
adequate
for
EPA's
purpose
of
tracking
and
identifying
the
export
of
hazardous
waste
from
the
U.
S.
For
example,
the
wastes
are
identified
by
tariff
codes
that
are
less
precise
than
the
waste
codes
required
by
the
tracking
document.

3(
b)
CONSULTATIONS
The
regulations
covered
by
this
ICR
were
promulgated
using
proper
rulemaking
procedures.
EPA
made
every
effort
to
consult
with
the
general
public,
State
and
industry
officials,
and
appropriate
Federal
agencies
in
developing
the
regulations.
EPA
held
public
hearings
and
received
substantial
comments.
As
a
result,
EPA
has
made
a
number
of
modifications
to
its
original
regulations.

In
addition,
EPA
issued
this
supporting
statement
for
public
comment
on
July
7,
2004
(
69
FR
40901)
(
FRL­
7782­
7)
No
comments
were
received.

3(
c)
EFFECTS
OF
LESS
FREQUENT
COLLECTION
EPA
has
carefully
considered
the
burden
imposed
upon
the
regulated
community
by
the
generator
standards.
EPA
is
confident
that
those
activities
required
of
respondents
are
necessary,
and
to
the
extent
possible,
have
attempted
to
minimize
the
burden
imposed.
EPA
believes
19
3
NAICS
codes
can
be
found
in
the
Federal
Register
at
61
FR
57006,
November
5,
1996.
strongly
that
if
the
minimum
requirements
specified
under
the
regulations
are
not
met,
neither
the
generators
nor
EPA
can
ensure
that
hazardous
wastes
are
being
properly
managed,
and
do
not
pose
a
serious
threat
to
human
health
and
the
environment.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

3(
d)
GENERAL
GUIDELINES
This
ICR
adheres
to
the
guidelines
started
in
the
1995
Paperwork
Reduction
Act
(
PRA),
OMB's
implementing
regulations,
OMB's
Information
Collection
Review
Handbook,
and
other
applicable
OMB
guidance.

3(
e)
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(
f)
SENSITIVE
QUESTIONS
No
questions
of
a
sensitive
nature
are
included
in
any
of
the
information
collection
requirements.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
COLLECTED
4(
a)
RESPONDENTS
AND
NAIC
CODES
The
following
is
a
list
of
North
American
Industry
Classification
System
(
NAICS)
codes,
associated
with
generators
most
likely
to
be
affected
by
the
generator
information
requirements
covered
under
this
ICR:
3
20
Table
2
List
of
and
NAICS
Codes
NAICS
code
Description
113
Forestry
and
Logging
115
Support
Activities
for
Agriculture
and
Forestry
211
Oil
and
Gas
Extraction
221
Utilities
311
Food
Manufacturing
313
Textile
Mills
314
Textile
Product
Mills
315
Apparel
Manufacturing
316
Leather
and
Allied
Product
Manufacturing
321
Wood
Product
Manufacturing
322
Paper
Manufacturing
323
Printing
and
Related
Support
Activities
324
Petroleum
and
Coal
Products
Manufacturing
325
Chemical
Manufacturing
326
Plastics
and
Rubber
Products
Manufacturing
331
Primary
Metal
Manufacturing
333
Machinery
Manufacturing
334
Computer
and
Electronic
Product
Manufacturing
335
Electrical
Equipment,
Appliance
and
Compontne
Manufacturing
336
Transportation
Equipment
Manufacturing
337
Furniture
and
Related
Product
Manufacturing
339
Miscellaneous
Manufacturing
511
Publishing
Industries
512
Motion
Picture
and
Sound
Recording
Industries
541
Professional,
Scientific,
and
Technical
Services
561
Administrative
and
Support
Services
812
Personal
and
Laundry
Services
4(
b)
INFORMATION
REQUESTED
HAZARDOUS
WASTE
DETERMINATION
REQUIREMENTS
21
40
CFR
262.11
requires
that,
if
a
person
generates
a
solid
waste,
he
or
she
must
determine
if
that
waste
is
a
hazardous
waste.
The
person
should
first
determine
if
the
waste
is
excluded
from
regulation
under
40
CFR
261.4.
He
or
she
must
then
determine
if
the
waste
is
listed
as
a
hazardous
waste
in
subpart
D
of
40
CFR
part
261.
For
purposes
of
compliance
with
40
CFR
part
268,
or
if
the
waste
is
not
listed
in
subpart
D
of
40
CFR
part
261,
the
generator
must
then
determine
whether
the
waste
is
identified
in
subpart
C
of
40
CFR
part
261
by
either
testing
the
waste
or
applying
knowledge
of
the
hazard
characteristics
of
the
waste
in
light
of
the
materials
or
the
processes
used.

(
i)
Data
item:

!
See
"
Recordkeeping
and
Reporting
Requirements,"
later
in
this
section,
for
the
data
items
associated
with
the
waste
determination
requirements.

(
ii)
Respondent
activities:

In
making
a
hazardous
waste
determination,
respondents
must:

!
Test
their
waste;
or
!
Use
knowledge
of
the
waste.

LARGE
QUANTITY
GENERATOR
PRE­
TRANSPORT
REQUIREMENTS
Large
quantity
generator
pre­
transport
requirements
comprise
seven
distinct
categories
of
informational
requirements:
labeling,
personnel
training,
contingency
planning
and
emergency
procedures,
tank
systems,
drip
pads,
containment
buildings,
and
requests
for
extensions
of
the
accumulation
period.

(
1)
Labeling
40
CFR
262.34(
a)(
2)
and
(
3)
require
that
LQGs
label
each
container
or
tank
accumulating
hazardous
waste
with
the
date
upon
which
each
period
of
accumulation
begins
and
the
words
"
Hazardous
Waste."
Section
262.34(
c)(
1)
requires
LQGs
accumulating
either
hazardous
waste
or
acutely
hazardous
waste
at
or
near
the
point
of
generation
to
mark
these
containers
in
"
satellite
accumulation"
with
the
words
"
Hazardous
Waste"
or
other
words
that
identify
the
contents
of
the
containers.
Section
262.34(
c)(
2)
further
requires
that,
if
the
LQG
accumulates
hazardous
waste
or
acutely
hazardous
waste
at
satellite
accumulation
in
excess
of
specified
amounts,
the
LQG
must,
within
three
days,
move
that
excess
waste
to
a
90­
day
accumulation
area.
During
that
three­
day
period,
the
LQG
must
mark
the
container
holding
the
excess
accumulation
with
the
date
the
excess
amount
began
accumulating.
22
(
i)
Data
items
!
Labels
with
the
words
"
Hazardous
Waste"
and
the
date
that
accumulation
began.

(
ii)
Respondent
activities
Respondents
must
perform
the
following
requirements
in
complying
with
section
262.34(
a)(
2)
and
(
3)
and
262.34(
c)(
1)
and
(
2):

!
Label
all
containers
and
tanks
with
the
words
"
Hazardous
Waste"
and
the
date
that
accumulation
began.

!
Label
all
containers
with
the
words
"
Hazardous
Waste"
or
other
words,
and
label
all
containers
with
excess
accumulation
with
the
date
that
the
excess
accumulation
began
(
satellite
accumulation
areas
only).

(
2)
Personnel
Training
In
section
262.34(
a)(
4),
LQGs
must
comply
with
requirements
in
section
265.16(
d)
and
(
e).
Section
265.16(
d)
requires
LQGs
to
maintain
copies
of
personnel
training
documents
and
records
at
the
facility.
Section
265.16(
e)
requires
that
training
records
be
held
until
closure
of
the
facility,
except
as
otherwise
specified.

(
i)
Data
items
!
Personnel
training
records
should
include
the
following
data
items:

­­
Job
title
for
each
position
at
the
facility
related
to
hazardous
waste
management,
and
the
name
of
the
employee
filling
each
job;

­­
Written
job
description
for
each
position,
which
includes
the
necessary
skill,
education,
or
other
qualifications
and
duties
of
employees
assigned
to
each
position;

­­
Written
description
of
the
type
and
amount
of
both
introductory
and
continuing
training
that
will
be
given
to
each
person
filling
a
position;
and
­­
Records
that
document
that
the
training
or
job
experience
required
have
been
given
to,
and
completed
by,
facility
personnel.

(
ii)
Respondent
activities
Respondents
must
perform
the
following
activities
under
section
265.16(
d)
and
(
e):

!
Collect
the
data
items
listed
above;
and
23
!
Maintain
(
e.
g.,
photocopying
and
filing)
the
information
at
the
facility.

(
3)
Contingency
Plan
and
Emergency
Procedures
In
section
262.34(
a)(
4),
LQGs
are
required
to
comply
with
the
preparedness
and
prevention
and
contingency
plan
and
emergency
procedure
requirements
in
subparts
C
and
D
of
part
265.

(
a)
Contingency
Plan
Section
265.37(
b)
requires
generators
to
note
whether
local
authorities
decline
to
enter
into
agreements
to
become
more
familiar
with
the
generators'
facility
and
wastes.
Section
265.51
requires
LQGs
to
have
a
contingency
plan
for
their
facilities.
Section
265.53(
a)
requires
the
generators
to
maintain
a
copy
of
an
updated
contingency
plan
at
the
facility.
Data
elements
required
by
this
plan
are
outlined
in
section
265.52.

(
i)
Data
items
!
Contingency
plan
should
include
the
following
data
items:

­­
A
description
of
the
actions
facility
personnel
will
take
in
response
to
fires,
explosions,
or
any
unplanned
sudden
or
non­
sudden
release
of
hazardous
waste
or
hazardous
waste
constituents
to
air,
soil
or,
surface
water
at
this
facility;

­­
A
description
of
the
arrangements
agreed
to
by
local
police
departments,
fire
departments,
hospitals,
contractors,
and
State
and
local
emergency
response
teams
to
coordinate
emergency
services;

­­
An
updated
list
of
names,
addresses
and
phone
numbers
(
office
and
home)
of
all
persons
qualified
to
act
as
emergency
coordinators
plus
designated
as
primary
emergency
coordinators
and
alternates
listed
in
order;

­­
An
updated
list
of
all
emergency
equipment
at
the
facility
and
the
location,
physical
description,
and
capabilities
of
the
emergency
equipment.
The
contingency
plan
should
also
indicate
where
the
emergency
equipment
will
be
required;
and
­­
An
evacuation
plan
for
the
facility
personnel
where
there
is
a
possibility
that
evacuation
may
be
necessary
including
a
description
of
signals
used
to
begin
evacuation,
evacuation
routes,
and
alternate
routes.

!
Documentation
of
whether
State
or
local
authorities
decline
to
enter
into
agreement
to
become
more
familiar
with
the
LQG's
facility
and
its
waste.
24
(
ii)
Respondent
activities
In
order
to
comply
with
these
requirements,
generators
are
required
to
perform
the
following
activities:

!
Collect
the
data
required
in
the
contingency
plan;

!
Note,
where
appropriate,
whether
State
or
local
authorities
decline
to
enter
into
agreement
to
become
familiar
with
the
LQG's
facility
and
its
wastes;

!
Write
the
contingency
plan;

!
Keep
a
copy
of
the
contingency
plan
on
site;

!
Submit
copies
of
plan
to
local
police
departments,
hospitals,
and
state
local
emergency
response
teams;
and
!
Amend
the
contingency
plan
when
appropriate.

(
b)
Emergency
Procedures
Under
sections
265.56(
a)
through
(
d),
whenever
there
is
an
imminent
or
actual
emergency
situation,
the
emergency
coordinator
must
immediately
activate
alarms
and
notify
personnel
and
appropriate
State
or
local
emergency
response
agencies.
Whenever
there
is
a
release,
fire,
or
explosion,
the
emergency
coordinator
must
immediately
investigate
and
assess
the
release
and
hazard
conditions.
If
the
emergency
coordinator
determines
that
the
facility
has
had
a
release,
fire
or
explosion
which
could
threaten
human
health
or
the
environment
outside
the
facility,
he
must
report
his
findings
to
local
authorities,
as
specified,
and
the
government
official
designated
as
the
on­
scene
coordinator
for
that
geographical
area
or
the
National
Response
Center
(
NRC).

(
i)
Data
items
!
Notification
to
fire
department
of
imminent
or
actual
emergency
situation.

!
Emergency
report
to
the
on­
scene
coordinator
or
NRC,
including:

­­
Name
and
telephone
number
of
reporter;

­­
Name
and
address
of
facility;

­­
Time
and
type
of
incident;

­­
Name
and
quantity
of
material(
s)
involved;

­­
The
extent
of
injuries;
and
25
­­
Possible
hazards
to
human
health
or
the
environment
outside
the
facility.

(
ii)
Respondent
activities
Emergency
coordinators,
or
their
designees,
must
conduct
the
following
activities,
as
applicable:

!
Notify
State
or
local
emergency
response
agencies
of
imminent
or
actual
emergency
situation;

!
Whenever
there
is
a
release,
fire,
or
explosion,
immediately
investigate
and
assess
the
release
and
hazard
conditions;
and
!
If
the
facility
has
had
a
release,
fire,
or
explosion
which
could
threaten
human
health
or
the
environment
outside
the
facility
boundary,
notify
local
authorities
if
local
evacuation
is
advisable
and
notify
OSC
for
that
geographical
area
or
the
NRC.

(
c)
Notification
of
Compliance
Section
265.56(
i)
states
that
LQGs
should
notify
the
Regional
Administrator
and
appropriate
State
and
local
authorities
that
their
facilities
are
in
compliance
with
section
265.56(
h)
and
note
same
in
operating
record
before
resuming
operations
in
the
affected
area(
s)
of
the
facilities.
Within
15
days
of
the
incident,
LQGs
are
required,
under
section
265.56(
j),
to
submit
a
written
report
on
the
incident
to
the
Regional
Administrator.

(
i)
Data
items
!
The
report
must
include
the
following
data
items:

­­
Name,
address,
and
telephone
number
of
the
generator;

­­
Name,
address,
and
telephone
number
of
the
facility;

­­
Date,
time,
and
type
of
incident;

­­
Name
and
quantity
of
material(
s)
involved;

­­
The
extent
of
injuries;

­­
An
assessment
of
actual
or
potential
hazards
to
human
health
or
the
environment;
and
­­
Estimated
quantity
and
disposition
of
recovered
material
that
resulted
from
the
incident.
26
(
ii)
Respondent
activities
As
required
by
section
265.56(
i),
LQGs
must:

!
Compile
information
that
demonstrates
that
all
affected
areas
are
in
compliance;

!
Prepare
a
letter
notifying
the
Regional
Administrator
of
this
compliance;
and
!
Submit
the
report.

As
required
by
section
265.56(
j),
LQGs
must:

!
Collect
the
information
required
in
the
emergency
report;

!
Write
the
emergency
notification
report;
and
!
Submit
the
report.

(
4)
Tank
Systems
In
section
262.34(
a)(
1),
LQGs
that
use
tanks
to
accumulate
hazardous
waste
for
90
days
or
less
are
required
to
comply
with
the
requirements
in
40
CFR
part
265
subpart
J.

(
a)
No
Free
Liquids
Demonstration
Section
265.190(
a)
exempts
LQGs
from
the
requirements
of
section
265.193
(
containment
and
detection
of
releases)
provided
that
the
tanks
are
located
in
buildings
with
impermeable
floors
and
are
used
to
accumulate
wastes
that
contain
no
free
liquids.

(
i)
Data
item
!
Demonstration
of
absence
of
free
liquids,
including
the
results
of
the
Paint
Filter
Liquids
Test,
performed
as
specified
in
SW­
846.
Generators
must
retain
the
test
results
on
site,
in
accordance
with
section
262.40(
c).

(
ii)
Respondent
activities
Respondents
must
perform
the
following
activities
in
performing
this
demonstration:

!
Perform
the
test;
and
!
Place
copy
of
results
in
record.

(
b)
Assessments
of
Existing
Tank
Systems'
Integrity
27
Section
265.191
requires
LQGs
with
tank
systems
that
1)
accumulate
waste
that
became
hazardous
after
July
14,
1986
and
2)
do
not
meet
the
secondary
containment
requirements
of
section
265.193
to
determine
if
their
tank
systems
are
sufficient
for
accumulating
hazardous
waste.

(
i)
Data
items
!
For
each
existing
tank
system,
a
written
assessment
that
has
been
reviewed
and
certified
by
an
independent,
qualified
registered
professional
engineer
in
accordance
with
section
270.11(
d).
At
a
minimum,
the
assessment
must
consider
the
following:

­­
The
design
standards
to
which
the
tank
and
ancillary
equipment
were
constructed;

­­
Hazardous
characteristics
of
the
waste(
s)
that
has
been
and
will
be
handled;

­­
Existing
corrosion
protection
measures;

­­
The
tank's
documented
or
estimated
age;
and
­­
Results
of
a
leak
test
performed
as
specified
in
section
265.191(
b)(
5)(
i)
and
(
ii).

(
ii)
Respondent
activities
Respondents
must
perform
the
following
activities
in
assessing
their
tank
systems:

!
Perform
the
leak
test
as
specified
in
section
265.191(
b)(
5)(
i)
and
(
ii);

!
Obtain
the
written
assessment
certified
by
an
independent,
qualified
and
registered
professional
engineer
that
attests
to
the
tank
system's
integrity;
and
!
File
the
assessment
at
the
facility.

(
c)
Design
and
Installation
of
New
Tank
Systems
or
Components
Section
265.192
requires
LQGs
that
install
new
tank
systems
or
components
to
obtain
written
assessments
attesting
that
their
tank
systems
are
acceptable
for
storing
hazardous
wastes.
In
addition,
LQGs
must
obtain
and
keep
on
file
at
the
facility
statements
written
by
those
who
designed
the
tank
systems
and
supervised
their
construction.
These
statements
will
verify
that
the
systems
were
designed
and
constructed
properly.

(
i)
Data
items
28
!
For
each
new
tank
system,
a
written
assessment
that
has
been
reviewed
and
certified
by
an
independent,
qualified,
registered
professional
engineer
in
accordance
with
section
270.11(
d).
At
a
minimum,
the
assessment
must
report
on
the
following:

­­
The
design
standards
to
which
the
tank
and
ancillary
equipment
were
constructed;

­­
Hazardous
characteristics
of
the
waste(
s)
to
be
handled;

­­
For
new
systems
or
components
in
which
any
external
metal
component
of
the
tank
system
will
be
in
contact
with
soil
or
water,
a
determination
by
a
corrosion
expert
of
the
factors
affecting
the
potential
for
and
protection
from
corrosion
as
specified
in
section
265.192(
a)(
3)(
i)
and
(
ii);

­­
For
underground
tank
systems
likely
to
be
adversely
affected
by
vehicular
traffic,
the
design
or
operational
measures
that
will
protect
the
tank
system
from
damage;
and
­­
Design
considerations
to
ensure
that:
1)
tank
foundations
will
maintain
the
load
of
a
full
tank,
2)
the
systems
are
anchored
so
that
they
will
not
float
or
dislodge
when
placed
in
a
saturated
or
seismic
fault
zone,
and
3)
the
systems
will
withstand
the
effects
of
frost
heave.

!
Records
of
statements
written
by
those
who
certify
the
tank
system's
design
and
supervise
its
installation
(
§
265.192(
g)).
These
records
must
verify
that
the
system
was
designed
and
installed
according
to
the
regulatory
requirements,
and
that
any
needed
repairs
were
performed.
They
must
also
include
the
certification
statement
as
required
in
section
270.11(
d).

(
ii)
Respondent
activities
Respondents
must
perform
the
following
activities
in
complying
with
these
requirements:

!
Obtain
the
written
assessment
and
have
it
reviewed
and
certified;

!
Obtain
written
statements
from
those
who
certified
the
design
of
the
tank
system
and
supervised
its
installation;
and
!
File
the
written
statements
at
the
facility.

(
d)
Containment
and
Detection
of
Releases
Section
265.193
requires
LQGs
operating
tank
systems
to
have
secondary
containment
that
will
prevent
the
release
of
hazardous
constituents
into
the
environment.
New
tank
systems
29
must
have
the
containment
installed
prior
to
their
being
put
into
service.
The
dates
by
which
containment
must
be
installed
on
existing
tank
systems
depend
upon
the
waste
types
handled,
the
system's
age,
and
other
factors.
The
information
collection
requirements
in
this
section
include
reports
to
the
Regional
Administrator
that,
upon
approval,
will
exempt,
when
appropriate,
tank
system
generators
from
specific
secondary
containment
standards.
In
addition,
section
265.193(
g)
allows
LQGs
to
obtain
variances
from
all
secondary
containment
requirements
if
they
can
demonstrate
to
the
Regional
Administrator
that
alternative
design
and
operating
practices,
together
with
location
characteristics,
will
be
as
protective
of
the
environment
as
secondary
containment.

(
d1)
Equivalent
Containment
Devices
Section
265.193(
d)
requires
all
secondary
containment
for
tank
systems
to
include
one
or
more
of
the
following
devices:
a
liner;
a
vault;
a
double­
walled
tank;
or
an
equivalent
device,
as
approved
by
the
Regional
Administrator.
Though
some
respondents
may
choose
to
use
a
previously­
approved
containment
device,
this
ICR
assumes
that
generators
will
submit
to
the
Regional
Administrator
written
information
regarding
the
design
and
type
of
device,
as
well
as
additional
information
that
may
be
necessary
to
substantiate
a
claim
that
the
device
is
equivalent
to
a
liner,
vault,
or
double­
walled
tank.

(
i)
Data
items
!
Written
information
regarding
the
design
and
type
of
containment
device
as
well
as
additional
information
that
may
be
necessary
to
substantiate
a
claim
that
the
device
is
equivalent
to
a
liner,
vault,
or
double­
walled
tank.

(
ii)
Respondent
activities
Respondents
must
perform
the
following
activities
in
obtaining
approval
for
their
equivalent
containment
device:

!
Gather
information
regarding
the
design
and
type
of
containment
device
as
well
as
additional
information
necessary
to
substantiate
a
claim
that
the
device
is
equivalent
to
a
liner,
vault,
or
double­
walled
tank;
and
!
Submit
the
information
to
the
Regional
Administrator.

(
d2)
Exemption
from
24
hour
Leak
Detection
Requirement
Section
265.193(
e)(
3)(
iii)
requires
secondary
containment
systems
to
have
a
leak
detection
system
that
will
detect
a
release
within
24
hours.
If
LQGs
can
demonstrate
to
EPA
that
existing
technologies
or
site
conditions
will
not
allow
detection
within
24
hours,
they
may
use
a
leak
detection
system
that
will
detect
failure
or
contamination
"
at
the
earliest
practicable
time."

(
i)
Data
items
30
!
Demonstration
regarding
existing
technologies
or
site
conditions
sufficient
to
show
that
the
leak
detection
system
cannot
detect
failure
or
contamination
within
24
hours.

(
ii)
Respondent
activities
Respondents
must
perform
the
following
activities
in
obtaining
an
exemption
from
the
24­
hour
detection
requirement:

!
Compile
evidence
showing
that
the
leak
detection
system
cannot
detect
failure
or
contamination
within
24
hours;
and
!
Submit
the
evidence
to
the
Regional
Administrator.

(
d3)
Variance
from
Secondary
Containment
Requirement
Section
265.193(
g)
allows
LQGs
to
obtain
a
variance
from
all
secondary
containment
requirements
if
they
can
demonstrate
to
the
Regional
Administrator
that
alternative
design
and
operating
practices,
together
with
location
characteristics,
will
prevent
the
migration
of
hazardous
constituents
into
the
ground
water
or
surface
water
as
effectively
as
secondary
containment.
In
the
event
of
a
release
that
does
migrate
to
ground
or
surface
water,
facilities
must
demonstrate
the
release
will
pose
no
substantial
hazard.

(
i)
Data
items
!
Written
notification
to
the
Regional
Administrator
indicating
intent
to
conduct
and
submit
a
demonstration
for
a
variance
from
secondary
containment.
This
notification
must
contain:

­­
Description
of
the
steps
necessary
to
conduct
the
demonstration
(
which
must
address
each
factor
listed
in
§
265.193(
g)(
1)
and
(
2));
and
­­
Timetable
for
completing
each
step.

(
ii)
Respondent
activities
Respondents
must
perform
the
following
activities
in
obtaining
a
variance
from
secondary
containment:

!
Prepare
the
notification
of
intent
to
conduct
a
demonstration;

!
Submit
the
notification
to
the
Regional
Administrator
(
for
existing
tank
systems,
notification
must
be
submitted
24
months
prior
to
the
date
at
which
secondary
containment
must
be
provided;
for
new
systems,
notification
must
be
submitted
at
least
30
days
before
entering
into
a
contract
to
install
the
system);
31
!
Complete
the
demonstration
in
accordance
with
section
265.193(
g)(
1)
and
(
2);
and
!
Submit
the
completed
demonstration
to
the
Regional
Administrator
within
180
days
of
submitting
the
notification.

(
d4)
Annual
Leak
Test
and
Inspections
Section
265.193(
i)
requires
LQGs,
until
they
meet
the
secondary
containment
requirements,
to
conduct
annual
leak
tests
and/
or
inspections
of
their
tanks
and
ancillary
equipment.
Records
of
these
assessments
must
be
kept
on
file
at
the
facility.

(
i)
Data
items
!
Record
of
the
results
of
the
leak
tests
and/
or
inspections
(
§
265.193(
i)).

(
ii)
Respondent
activities
Respondents
must
perform
the
following
activities
in
filing
a
record
of
the
assessment
results:

!
For
non­
enterable
underground
tanks,
conduct
a
leak
test
that
meets
the
requirements
of
section
265.191(
b)(
5);

!
For
all
other
tanks
and
for
ancillary
equipment,
conduct
an
annual
leak
test
that
meets
the
requirements
in
section
265.191(
b)(
5)
or
have
the
tanks
and
equipment
inspected
as
described
in
section
265.193(
I)(
1);

!
Record
the
inspection
and/
or
test
results;
and
!
Maintain
on
file
at
the
facility
a
record
of
the
results.

(
e)
Responses
to
Leaks
or
Spills;
Disposition
of
Leaking
or
Unfit­
for­
Use
Tank
Systems
Section
265.196
requires
LQGs
with
a
tank
system
or
secondary
containment
system
from
which
there
has
been
a
spill
to
remove
it
from
service
immediately.
Section
265.196(
b)
requires
LQGs,
within
24
hours,
to
remove
enough
waste
from
the
system
to
prevent
further
release
and
allow
for
inspection
and
repair
of
the
tank.
If
the
LQG
can
demonstrate
that
it
is
not
possible
to
do
so
within
24
hours,
the
waste
may
be
removed
at
the
earliest
practicable
time.

(
e1)
Exemptions
from
24
hour
waste
removal
requirement
(
i)
Data
items
32
!
Demonstration
sufficient
to
show
that,
within
24
hours,
the
generator
cannot
remove
enough
waste
from
the
system
to
prevent
further
release
and
allow
for
system
inspection
and
repair.

(
ii)
Respondent
activities
Respondents
must
perform
the
following
activities
in
making
this
demonstration:

!
Compile
evidence
showing
that,
within
24
hours,
enough
waste
cannot
be
removed
from
the
system
to
prevent
further
release
and
allow
for
system
inspection
and
repair.

!
Submit
the
evidence
to
the
Regional
Administrator.

(
e2)
Release
Notifications
and
Reports
Section
265.196(
d)
requires
LQGs
to
comply
with
certain
reporting
requirements
in
the
case
of
a
leak
or
spill.
LQGs
must
notify
the
Regional
Administrator
of
any
release
to
the
environment
(
except
as
defined
in
§
265.196(
d)(
2))
within
24
hours
of
detection
(
if
the
release
has
been
reported
pursuant
to
40
CFR
part
302
(
CERCLA
§
103),
that
report
will
satisfy
this
requirement),
and
submit
a
detailed
report
within
30
days.
In
addition,
if
the
generator
has
made
major
repairs
to
the
system,
section
265.196(
f)
requires
that
generators
submit
to
the
Regional
Administrator
a
certification
of
major
repairs.
This
certification,
obtained
by
an
independent
qualified
registered
professional
engineer
in
accordance
with
section
270.1(
d),
documents
that
the
system
has
been
repaired
and
is
capable
of
handling
hazardous
waste
without
release,
and
must
be
submitted
to
the
Regional
Administrator
within
seven
days
of
returning
the
system
to
use.

(
i)
Data
items
!
A
notification
to
the
Regional
Administrator
that
there
has
been
a
release;

!
A
report
to
the
Regional
Administrator
containing
the
following
information:

­­
The
release's
likely
migration
route;
­­
The
surrounding
soil
characteristics;
­­
The
results
of
any
monitoring
or
sampling
conducted
in
connection
with
the
release
(
if
not
available
within
30
days,
results
must
be
submitted
as
soon
as
practicable);
­­
The
release's
proximity
to
downgradient
drinking
water,
surface
water,
and
population
areas;
and
­­
A
description
of
the
response
actions
taken
or
planned.

!
A
certification
by
an
independent,
qualified,
registered
professional
engineer
in
accordance
with
section
270.11(
d)
that
the
repaired
system
is
capable
of
handling
hazardous
wastes
without
release
for
the
intended
life
of
the
system.
33
(
ii)
Respondent
activities
Respondents
must
perform
the
following
activities
in
preparing
and
submitting
release
notifications
and
reports:

!
Within
24
hours
of
detection,
notify
the
Regional
Administrator
that
there
has
been
a
release;

!
Within
30
days
of
detection,
the
LQG
must:

­­
Determine
the
release's
likely
migration
route;
­­
Provide
information
on
the
surrounding
soil
characteristics;
­­
Conduct
appropriate
monitoring
or
sampling;
­­
Determine
the
release's
proximity
to
downgradient
drinking
water,
surface
water,
and
population
areas;
­­
Describe
the
response
actions
taken
or
planned;
and
­­
Compile
the
report.

!
Submit
the
report.

(
e3)
Major
Repair
Certifications
(
i)
Data
item
!
Certification
(
ii)
Respondent
Activities
Respondents
must
perform
the
following
activities
in
preparing
and
submitting
a
certification
of
major
repairs:

!
Obtain
a
certification
from
an
independent,
qualified,
registered
professional
engineer,
in
accordance
with
section
270.11(
d);
and
!
Within
seven
days
of
returning
the
system
to
use,
submit
the
certification
to
the
Regional
Administrator.

(
5)
Drip
Pads
Under
section
262.34(
a)(
1)(
iii),
EPA
requires
LQGs
that
accumulate
hazardous
waste
on
drip
pads
to
comply
with
contingency
plan,
assessment,
upgrading,
repair,
and
release­
related
information
collection
requirements,
as
well
as
to
document
the
proper
use
of
drip
pads
and
compliance
with
90
day
waste
removal
requirements.
34
(
a)
Contingency
Plan
Section
265.440(
c)(
1)
provides
that
facilities
with
infrequent
and
incidental
drippage
in
storage
yards
may
be
exempt
from
drip
pad
requirements
if
they
prepare
a
contingency
plan
that
responds
to
such
drippage.

(
i)
Data
items
!
Maintenance
of
contingency
plan
that
addresses
clean­
up
of
incidental
drippage;
and
!
Records
of
clean­
up.

(
ii)
Respondent
activities
Respondents
must
perform
the
following
activities:

!
Prepare
contingency
plan;

!
Document
clean­
up
of
incidental
drippage;
and
!
Retain
documentation
for
3
years.

(
b)
Adequacy
of
Existing
Drip
Pads
Sections
265.441(
a),
(
b)
and
(
c)
require
generators
using
drip
pads
to
maintain
on
file
an
assessment
of
pad
integrity,
prepare
and
submit
a
plan
for
upgrading
the
pad
(
as
necessary
to
meet
applicable
regulation)
to
the
Regional
Administrator,
and
submit
drawings
and
a
certification
of
the
pad
to
Regional
Administration.

(
i)
Data
items
!
An
assessment
of
pad
integrity;

!
A
plan
for
upgrading
the
pad
to
meet
the
applicable
regulatory
standards;
and
!
Drawings
of
the
pad
and
a
certification
by
an
independent,
qualified,
registered
professional
engineer
that
upon
completion
of
repairs
and
modifications
the
pad
conforms
to
the
drawings.

(
ii)
Respondent
activities
Respondents
must
perform
the
following
activities:

!
Prepare
and
maintain
an
assessment
of
pad
integrity;
35
!
Prepare
a
plan
for
upgrading
the
pad
to
meet
the
applicable
regulatory
standards;
and
!
Prepare
drawings
of
the
pad
and
obtain
the
certification
of
an
independent,
qualified,
registered
professional
engineer
that
the
pad
conforms
to
the
drawings.

(
c)
Design
and
Operating
Requirements
Section
265.443
requires
that
generators
using
drip
pads
must
maintain
an
assessment
of
the
drip
pad
and
records
of
any
release
of
hazardous
waste.
These
generators
must
also
notify
the
Regional
Administrator
and
provide
written
notice
of
any
release
of
hazardous
waste
as
well
as
of
the
completion
of
modifications
or
repairs.
Certification
of
such
modifications
or
repairs
is
also
required.
Finally,
generators
using
drip
pads
must
document
operating
and
waste
handling
practices
in
their
operating
log.

(
i)
Data
items
!
An
assessment
of
the
drip
pad
reviewed
and
certified
by
an
independent,
qualified,
registered
professional
engineer;

!
A
record
of
any
condition
contributing
to
or
actual
release
of
hazardous
waste
from
the
drip
pad;

!
Notice
to
the
Regional
Administrator
of
any
release
of
hazardous
waste;

!
Notice
to
the
Regional
Administrator
of
completion
of
any
repairs
required
to
meet
applicable
standards;

!
Certification
of
an
independent,
qualified,
registered
professional
engineer
that
the
repairs
satisfy
applicable
standards;
and
!
Documentation
of
operating
and
waste
handling
practices.

(
ii)
Respondent
activities
Respondents
must
perform
the
following
activities:

!
Prepare
an
assessment
of
the
drip
pad
and
have
the
assessment
certified
by
an
independent,
qualified,
registered
professional
engineer;

!
Place
a
record
of
any
condition
contributing
to
or
actual
releases
of
hazardous
waste
from
the
drip
pad
in
the
operating
log;
36
!
Notify
the
Regional
Administrator
of
releases
of
hazardous
waste
and
provide
written
notice
of
same;

!
Provide
notice
to
the
Regional
Administrator
of
the
completion
of
any
repairs
required
to
meet
applicable
standards;

!
Provide
a
copy
of
the
certification
of
an
independent,
qualified,
registered
professional
engineer
that
the
repairs
satisfy
applicable
standards
to
the
Regional
Administrator;
and
!
Prepare
documentation
of
operating
and
waste
handling
practices.

(
d)
Certification
of
Liner
Section
265.444(
a)
requires
generators
using
drip
pads
to
place
a
certification
of
the
adequacy
of
the
liner
in
their
operating
log.

(
i)
Data
items
!
Certification
by
an
independent,
qualified,
registered
professional
engineer
that
following
construction
or
installation
the
liner
meets
the
specified
regulatory
standard.

(
ii)
Respondent
activities
Respondents
must
perform
the
following
activities:

!
Obtain
the
certification
of
an
independent,
qualified,
registered
professional
engineer
that
following
construction
or
installation
the
liner
meets
the
specified
regulatory
standard;
and
!
Place
the
certification
in
the
operating
log.

(
e)
Documentation
of
Waste
Removal
Section
262.34(
a)(
1)(
iii)
requires
generators
using
drip
pads
to
maintain
a
description
of
their
90­
day
waste
removal
practices
and
to
document
each
waste
removal.

(
i)
Data
items
!
A
description
of
90­
day
waste
removal
practices;
and
!
Documentation
of
each
waste
removal.

(
ii)
Respondent
activities
37
Respondents
must
perform
the
following
activities:

!
Prepare
a
description
of
90­
day
waste
removal
practices;
and
!
Document
each
waste
removal.

(
6)
Containment
Buildings
Under
section
262.34(
a)(
1)(
iv),
EPA
requires
LQGs
that
accumulate
hazardous
waste
in
containment
buildings
to
comply
with
certification,
release
notification,
repair,
and
design­
related
requirements
as
well
as
to
document
storage
procedures,
waste
generation
and
management
practices,
compliance
with
procedures,
and
that
the
unit
is
emptied
at
least
every
90
days.

(
a)
Design
and
Performance
Documentation
Section
265.1101(
c)
and
(
d)
require
that
generators
using
containment
buildings
must
place
a
certification
of
compliance
with
applicable
standards
in
the
record,
record
releases
of
hazardous
waste,
and
notify
the
Regional
Administrator
of
dangerous
conditions
or
releases
of
waste
within
7
days
and
provide
written
notice
within
14
days.
These
generators
must
notify
Regional
Administrator
upon
completion
of
repairs.
They
must
also
record
and
place
in
the
operating
plan
every
7
days
information
about
operating
procedures
used
to
verify
the
integrity
of
areas
lacking
secondary
containment
(
only
in
buildings
that
contain
areas
both
with
and
without
secondary
containment).

(
i)
Data
items
!
A
certification
of
an
independent,
qualified,
registered
professional
engineer
that
the
design
of
the
containment
building
meets
applicable
regulatory
standards;

!
Records
of
any
release
of
hazardous
waste
from
a
containment
building;

!
Notification
of
the
Regional
Administrator
of
any
release
of
hazardous
waste
within
7
days
followed
by
written
notice
within
14
days;

!
Notification
of
the
Regional
Administrator
of
the
completion
of
required
repairs
or
clean­
up;
and
!
Monitoring
data
and
leak
detection
data.

(
ii)
Respondent
activities
Respondents
must
perform
the
following
activities:
38
!
Obtain
the
certification
of
an
independent,
qualified,
registered
professional
engineer
that
the
design
of
the
containment
building
meets
applicable
regulatory
standards;

!
Place
the
certification
in
the
operating
record;

!
Maintain
records
of
any
release
of
hazardous
waste
from
a
containment
building;

!
Notify
the
Regional
Administrator
of
any
condition
contributing
to
or
actual
releases
of
hazardous
waste
within
7
days,
and
provide
follow­
up
written
notice
within
14
days
of
a
release;

!
Notify
the
Regional
Administrator
of
the
completion
of
required
repairs
or
cleanup
and
!
Record
monitoring
data
and
leak
detection
data
and
place
that
data
in
the
operating
record
at
least
every
7
days.

(
b)
Documentation
of
Areas
Lacking
Secondary
Containment
Section
265.1101(
d)
requires
generators
using
containment
buildings
to
place
a
description
of
the
facility's
procedures
to
maintain
the
integrity
of
areas
lacking
secondary
containment
in
their
operating
log.
This
requirement
only
applies
to
containment
buildings
that
contain
areas
both
with
and
without
secondary
containment.

(
i)
Data
item
!
Description
of
procedures
to
maintain
integrity
of
areas
lacking
secondary
containment.

(
ii)
Respondent
activities
Respondents
must
perform
the
following
activity:

!
Place
description
of
the
facility's
procedures
to
maintain
the
integrity
of
areas
lacking
secondary
containment
in
the
operating
log.

(
c)
Documentation
of
Procedures
and
Compliance
Section
262.34(
a)(
1)(
iv)
provides
that
generators
using
containment
buildings
must
develop
written
procedures
to
ensure
that
waste
stored
for
90
days
or
less.
These
generators
must
also
describe
their
waste
generation
and
management
practices
and
document
that
procedures
ensuring
limited
storage
are
satisfied.
Finally,
these
generators
must
document
that
their
containment
building
is
emptied
at
least
once
every
90
days.
39
(
i)
Data
items
!
A
written
description
of
the
procedures
to
ensure
that
waste
is
stored
no
more
than
90
days;

!
A
written
description
of
the
waste
generation
and
management
practices
showing
they
are
consistent
with
such
90
day
storage;

!
Documentation
that
procedures
restricting
the
time
of
storage
are
satisfied;
and
!
Documentation
that
the
unit
is
emptied
at
least
once
every
90
days.

(
ii)
Respondent
activities
Respondents
must
perform
the
following
activities:

!
Prepare
a
written
description
of
the
procedures
to
ensure
that
waste
is
stored
no
more
than
90
days;

!
Prepare
a
written
description
of
the
waste
generation
and
management
practices
showing
they
are
consistent
with
such
90
day
storage;

!
Prepare
documentation
that
90­
day
storage
procedures
are
satisfied;
and
!
Prepare
documentation
that
the
unit
is
emptied
at
least
once
every
90
days.

(
7)
Requests
for
Extensions
of
the
Accumulation
Period
In
the
case
of
an
unforeseen,
temporary,
or
an
uncontrollable
circumstance,
section
262.
34(
b)
allows
large
quantity
generators
to
apply
for
up
to
a
30­
day
extension
of
the
90­
day
accumulation
period
limit.
At
the
discretion
of
the
Regional
Administrator,
these
extensions
will
be
granted
on
a
case­
by­
case
basis.

(
i)
Data
items
The
data
items
required
in
making
this
request
are:

!
The
unforeseen,
temporary,
or
uncontrollable
circumstances
causing
the
need
for
an
extension,
and
!
The
length
of
desired
extension
(
up
to
a
limit
of
30
days).

(
ii)
Respondent
activities
In
order
to
submit
this
request,
the
respondent
must
undertake
the
following
tasks:
40
!
Prepare
and
submit
the
request
to
the
Regional
Administrator.

LARGE
QUANTITY
GENERATOR
AIR
EMISSION
STANDARDS
Large
quantity
generator
air
emission
standards
comprise
two
new
categories
of
informational
requirements:
air
emission
standards
for
process
vents
and
air
emission
standards
for
equipment
leaks.

(
1)
Air
Emissions
from
Process
Vents
(
a)
Control
Device
Operation
Documentation
40
CFR
265.1033(
i)
requires
owner/
operators
to
prepare
documentation
describing
the
operation
of
control
devices
different
from
those
specified
in
section
265.1033(
f),
(
g),
and
(
h)
and
identifying
process
parameters
that
indicate
proper
operation
and
maintenance
of
those
control
devices.

(
i)
Data
items
!
Description
of
the
control
device
operation;
and
!
Information
on
the
process
parameter
or
parameters
that
will
be
used
to
indicate
proper
operation
and
maintenance
of
the
control
device.

(
ii)
Respondent
activities
To
comply
with
section
265.1033(
i),
respondents
must
perform
the
following
activities:

!
Gather
information
on
control
device
operation
and
process
parameters;

!
Document
control
device
operation
and
process
parameter
information;

!
Maintain
documentation
at
the
unit
(
required
under
§
265.1035(
e));

!
Reassess
control
device
documentation;
and
!
Modify
control
device
documentation,
if
necessary.

(
b)
Waste
Determination
40
CFR
265.1034(
d)(
2)
requires
owner/
operators
to
document
waste
determinations
that
are
based
on
knowledge
of
the
waste
rather
than
testing.

(
i)
Data
item
41
Data
items
required
for
documenting
waste
determinations
are
not
specified,
but
may
include
the
following:

!
Production
process
information
documenting
that
no
organic
compounds
are
used;

!
Waste
generation
information
documenting
that
the
waste
is
generated
by
a
process
identical
to
a
process
at
the
same
or
another
unit
that
has
previously
been
demonstrated
by
direct
measurement
to
generate
a
waste
stream
having
a
total
organic
content
less
than
10
ppmw;
and
!
Prior
specification
analysis
results
on
the
same
waste
stream
where
it
can
be
documented
that
no
process
changes
have
occurred
since
the
specification
analysis
was
conducted
that
could
affect
the
waste
total
organic
concentration.

(
ii)
Respondent
activities
To
comply
with
section
265.1034(
d)(
2),
respondents
must
perform
the
following
activities:

!
Gather
information
on
production
processes,
waste
generation,
and
specification
analysis
!
Document
information
on
production
processes,
waste
generation,
and
specification
analysis;
and
!
Maintain
documentation
at
the
unit.

(
c)
Unit
Operating
Record
(
c1)
Implementation
Schedule
(
i)
Data
item
Under
40
CFR
265.1035(
b)
owner/
operators
are
required
to
record
the
following
information
in
the
unit
operating
record:

!
For
facilities
that
comply
with
the
provisions
of
section
265.1033(
a)(
2),
an
implementation
schedule
that
includes
dates
by
which
the
closed­
vent
system
and
control
device
will
be
installed
and
in
operation.
The
schedule
must
also
include
a
rationale
of
why
the
installation
cannot
be
completed
at
an
earlier
date.

(
ii)
Respondent
Activities
!
Prepare
the
data
item;
42
!
Reassess;

!
File
and
Maintain;
and
!
Modify.

(
c2)
Up­
to­
date
Documentation
of
Compliance
(
i)
Data
item
!
Up­
to­
date
documentation
of
compliance
with
the
process
vent
standards
in
section
265.1032,
including:

­­
Information
and
data
identifying
all
affected
process
vents,
annual
throughput
and
operating
hours
of
each
affected
unit,
estimated
emission
rates
for
each
affected
vent
and
for
the
overall
unit,
and
the
approximate
location
within
the
unit
of
each
affected
unit.

­­
Information
and
data
supporting
determinations
of
vent
emissions
and
emission
reductions
achieved
by
add­
on
control
devices
based
on
engineering
calculations
or
source
tests.

(
ii)
Respondent
Activities
!
Prepare
the
data
item;

!
Reassess;

!
File
and
Maintain;
and
!
Modify.

(
c3)
Performance
Test
Plan
(
i)
Data
item
!
Where
an
owner
or
operator
chooses
to
use
test
data
to
determine
the
organic
removal
efficiency
or
total
organic
compound
concentration
achieved
by
the
control
device,
a
performance
test
plan
that
includes
the
following
information:

­­
A
description
of
how
it
is
determined
that
the
planned
test
is
going
to
be
conducted
when
the
hazardous
waste
management
unit
is
operating
at
the
highest
load
or
capacity
level
reasonably
expected
to
occur.
This
shall
include
the
estimated
or
design
flow
rate
and
organic
content
of
each
vent
43
stream
and
define
the
acceptable
operating
ranges
of
key
process
and
control
device
parameters
during
the
test
program.

­­
A
detailed
engineering
description
of
the
closed­
vent
system
and
control
device,
including:

­
Manufacturer's
name
and
model
number
of
control
device;
­
Type
of
control
device;
­
Dimensions
of
the
control
device;
­
Capacity;
­
Construction
materials.

­­
A
detailed
description
of
sampling
and
monitoring
procedures,
including
sampling
and
monitoring
locations
in
the
system,
the
equipment
to
be
used,
sampling
and
monitoring
frequency,
and
planned
analytical
procedures
for
sample
analysis.

(
ii)
Respondent
Activities
!
Prepare
the
data
item;

!
Reassess;

!
File
and
maintain;
and
!
Modify.

(
c4)
Documentation
of
Compliance
(
i)
Data
item
!
Documentation
of
compliance
with
section
265.1033
including
the
following
information:

­­
A
list
of
all
information
references
and
sources
used
in
preparing
the
documentation;

­­
If
engineering
calculations
are
used,
a
design
analysis,
specifications,
drawings,
schematics,
and
piping
and
instrumentation
diagrams
based
on
the
appropriate
sections
of
"
APTI
Course
415:
Control
of
Gaseous
Emissions"
or
other
engineering
texts
acceptable
to
the
Regional
Administrator
that
present
basic
control
device
design
information.
Documentation
provided
by
the
control
device
manufacturer
or
vendor
that
describes
the
control
device
design
in
accordance
with
paragraphs
(
b)(
4)(
iii)(
A)
through
(
b)(
4)(
iii)(
G)
of
this
section
may
be
used;
44
­­
A
statement
signed
and
dated
by
the
owner/
operator
certifying
that
the
operating
parameters
used
in
the
design
analysis
reasonably
represent
the
conditions
that
exist
when
the
hazardous
waste
management
unit
is
or
would
be
operating
at
the
highest
load
or
capacity
level
reasonably
expected
to
occur;
and
­­
A
statement
signed
and
dated
by
the
owner/
operator
certifying
that
the
control
device
is
designed
to
operate
at
an
efficiency
of
95
percent
or
greater
unless
the
total
organic
concentration
limit
of
section
265.1032(
a)
is
achieved
at
an
efficiency
less
than
95
percent
or
the
total
organic
emission
limits
of
section
265.1032(
a)
for
affected
process
vents
at
the
unit
can
be
attained
by
a
control
device
involving
vapor
recovery
at
an
efficiency
less
than
95
weight
percent.
A
statement
provided
by
the
control
device
manufacturer
or
vendor
certifying
that
the
control
equipment
meets
the
design
specifications
may
be
used
to
comply
with
this
requirement.

(
ii)
Respondent
Activities
!
Prepare
the
data
item;

!
Reassess;

!
File
and
Maintain;
and
!
Modify.

(
c5)
Design,
Monitoring
and
Inspections
Information
(
i)
Data
item
!
Design
documentation
and
monitoring,
operating,
and
inspection
information
for
each
closed­
vent
system
and
control
device
required
to
comply
with
the
provisions
including:

­­
Description
and
date
of
each
modification
that
is
made
to
the
closed­
vent
system
or
control
device
design;

­­
Identification
of
operating
parameter,
description
of
monitoring
device,
and
diagram
of
monitoring
sensor
location
or
locations
used
to
comply
with
sections
265.1033(
f)(
1)
and
(
f)(
2);

­­
Monitoring,
operating
and
inspection
information
required
by
paragraphs
(
f)
through
(
k)
of
section
265.1033;
45
­­
Date,
time,
and
duration
of
each
period
that
occurs
while
the
control
device
is
operating
when
any
monitored
parameter
exceeds
the
value
established
in
the
control
device
design
analysis;

­­
Explanation
for
each
period
recorded
under
paragraph
(
4)
of
the
cause
for
control
device
operating
parameter
exceeding
the
design
value
and
the
measures
implemented
to
correct
the
control
device
operation;

­­
For
a
carbon
adsorption
system
operated
subject
to
requirements
specified
in
sections
265.1033(
g)
or
265.1033(
h)(
2),
date
when
existing
carbon
in
the
control
device
is
replaced
with
fresh
carbon;

­­
For
a
carbon
adsorption
system
operated
subject
to
requirements
specified
in
section
265.1033(
h)(
1),
a
log
recording
the
following
information:

­
Date
and
time
when
control
device
is
monitored
for
carbon
breakthrough
and
the
monitoring
device
reading;

­
Date
existing
carbon
in
control
device
is
replaced
with
fresh
carbon;
and
­
Date
of
each
control
device
start­
up
and
shutdown.

(
ii)
Respondent
Activities
!
Prepare
the
data
item;

!
Reassess;

!
File
and
Maintain;
and
!
Modify.

(
c6)
Determination
of
Applicability
to
Subpart
AA
(
i)
Data
item
!
Up­
to­
date
information
and
data
used
to
determine
whether
or
not
a
process
vent
is
subject
to
the
requirements
in
section
265.1032
including
supporting
documentation
as
required
by
section
265.1034(
d)(
2)
when
application
of
the
knowledge
of
the
nature
of
the
hazardous
waste
stream
or
the
process
by
which
it
was
produces
is
used.

(
ii)
Respondent
Activities
46
!
Prepare
the
data
item;

!
Reassess;

!
File
and
Maintain;
and
!
Modify.

(
2)
Air
Emissions
from
Equipment
Leaks
(
a)
Notification
to
implement
the
alternate
valve
standard
specified
in
section
265.1061(
a)

(
i)
Data
items
!
40
CFR
265.1061(
b)(
1)
requires
owners
or
operators
that
have
decided
to
implement
the
alternative
standard
for
valves
specified
in
section
265.1061(
a)
to
notify
the
Regional
Administrator.
No
specific
data
items
are
to
be
included
in
this
notification.

(
ii)
Respondent
activities
To
comply
with
section
265.1061(
b)(
1),
respondents
must
perform
the
following
activities:

!
Prepare
notification;
and
!
Submit
notification
to
the
Regional
Administrator.

(
b)
Notification
to
discontinue
implementing
the
alternative
valve
standard
specified
in
section
265.1061(
a)

(
i)
Data
items
!
40
CFR
265.1061(
d)
requires
owners
or
operators
that
no
longer
wish
to
implement
the
alternative
standard
for
valves
specified
in
section
265.1061(
a)
to
notify
the
Regional
Administrator.
No
specific
data
items
are
to
be
included
in
this
notification.

(
ii)
Respondent
activities
To
comply
with
section
265.1061(
d),
respondents
must
perform
the
following
activities:

!
Prepare
notification;
and
47
!
Submit
notification
to
the
Regional
Administrator.

(
c)
Notification
to
implement
the
alternative
valve
standard
specified
in
sections
265.1062(
b)(
2)
or
265.1062(
b)(
3).

(
i)
Data
items
!
40
CFR
265.1062(
a)(
2)
requires
owners
or
operators
that
have
decided
to
implement
the
alternative
standard
for
valves
specified
in
sections
265.1062(
b)(
2),
or
265.1062(
b)(
3)
to
notify
the
Regional
Administrator.
No
specific
data
items
are
to
be
included
in
this
notification.

(
ii)
Respondent
activities
To
comply
with
section
265.1062(
a)(
2),
respondents
must
perform
the
following
activities:

!
Prepare
notification;
and
!
Submit
notification
to
the
Regional
Administrator.

(
d)
Non­
Hazardous
waste
documentation
(
i)
Data
items
40
CFR
265.1063(
d)(
3),
requires
owners
or
operators
that
determining
that
each
piece
of
equipment
does
or
does
not
contain
hazardous
waste
with
organic
concentration
that
equals
or
exceeds
10
percent
waste
to
document
the
determination
if
it
was
based
on
knowledge
rather
than
testing.
Data
items
required
for
documenting
waste
determinations
are
not
specified,
but
may
include
the
following:

!
Production
process
information
documenting
that
no
organic
compounds
are
used;

!
Waste
generation
information
documenting
that
the
waste
is
generated
by
a
process
identical
to
a
process
at
the
same
or
another
unit
that
has
previously
been
demonstrated
by
direct
measurement
to
generate
a
waste
stream
having
a
total
organic
content
less
than
10
ppmw;
and
!
Prior
specification
analysis
results
on
the
same
waste
stream
where
it
can
be
documented
that
no
process
changes
have
occurred
since
the
specification
analysis
was
conducted
that
could
affect
the
waste
total
organic
concentration.

(
ii)
Respondent
activities
48
To
comply
with
section
265.1063(
d)(
3),
respondents
must
perform
the
following
activities:

!
Gather
information
on
production
processes,
waste
generation,
and
specification
analysis;

!
Document
information
on
production
processes,
waste
generation,
and
specification
analysis;

!
Maintain
documentation
at
the
unit.

(
e)
Unit
operating
record
(
e1)
Equipment
Record
(
i)
Data
item
Under
40
CFR
265.1064(
b)
owner/
operators
are
required
to
record
the
following
information
in
the
unit
operating
record:

!
For
each
piece
of
equipment
to
which
subpart
BB
applies:

­­
Equipment
identification
number
and
hazardous
waste
management
unit
identification;

­­
Approximate
locations
within
the
unit;

­­
Type
of
equipment;

­­
Percent­
by­
weight
total
organics
in
the
hazardous
waste
stream
at
the
equipment;

­­
Hazardous
waste
state
at
the
equipment;
and
­­
Method
of
compliance
with
the
standard.

(
ii)
Respondent
activities
!
Prepare
the
data
item;

!
Reassess
the
data
item;

!
File
and
maintain
the
data
item
in
the
unit
operating
record;
and
!
Modify
the
data
item,
if
necessary.
49
(
e2)
Implementation
Schedule
(
i)
Data
item
!
For
facilities
that
comply
with
the
provisions
of
section
265.1033(
a)(
2),
an
implementation
schedule
that
includes
dates
by
which
the
closed­
vent
system
and
control
device
will
be
installed
and
in
operation.
The
schedule
must
also
include
a
rationale
of
why
the
installation
cannot
be
completed
at
an
earlier
date.

(
ii)
Respondent
activities
!
Prepare
the
data
item;

!
Reassess
the
data
item;

!
File
and
maintain
the
data
item
in
the
unit
operating
record;
and
!
Modify
the
data
item,
if
necessary.

(
e3)
Performance
Test
Plan
(
i)
Data
item
!
Where
an
owner/
operator
chooses
to
use
test
data
to
demonstrate
the
organic
removal
efficiency
or
total
organic
compound
concentration
achieved
by
the
control
device,
a
performance
test
plan
as
specified
in
section
265.1035(
b)(
3);
(
ii)
Respondent
activities
!
Prepare
the
data
item;

!
Reassess
the
data
item;

!
File
and
maintain
the
data
item
in
the
unit
operating
record;
and
!
Modify
the
data
item,
if
necessary.

(
e4)
Documentation
of
Compliance
(
i)
Data
item
!
Documentation
of
compliance
with
section
265.1060,
including
detailed
design
documentation
or
performance
test
results
specified
in
section
265.1035(
b)(
4);

(
ii)
Respondent
activities
50
!
Prepare
the
data
item;

!
Reassess
the
data
item;

!
File
and
maintain
the
data
item
in
the
unit
operating
record;
and
!
Modify
the
data
item,
if
necessary.

(
e5)
Leak
Inspection
Log
(
i)
Data
item
!
When
each
leak
is
detected
as
specified
in
sections
265.1052,
265.1053,
265.1057,
and
265.1058,
an
inspection
log
that
includes
the
following
information:

­­
Instrument
and
operator
identification
numbers
and
the
equipment
identification
number;

­­
The
date
evidence
of
a
potential
leak
was
found
in
accordance
with
section
265.1058(
a);

­­
The
date
the
leak
was
detected
and
the
dates
of
each
attempt
to
repair
the
leak;

­­
Repair
methods
applied
in
each
attempt
to
repair
the
leak;

­­
"
Above
10,000"
if
the
maximum
instrument
reading
measured
by
the
methods
specified
in
section
265.1063(
b)
after
each
repair
attempt
is
equal
to
or
greater
than
10,000
ppm;

­­
"
Repair
delayed"
and
the
reason
for
the
delay
if
a
leak
is
not
repaired
within
15
calendar
days
after
discovery
of
the
leak;

­­
Documentation
supporting
the
delay
of
repair
of
a
valve
in
compliance
with
section
265.1059(
c);

­­
The
signature
of
the
owner
or
operator
(
or
designate)
whose
decision
it
was
that
repair
could
not
be
effected
without
a
hazardous
waste
management
unit
shutdown;

­­
The
expected
date
of
successful
repair
of
the
leak
if
a
leak
is
not
repaired
within
15
calendar
days;
and
­­
The
date
of
successful
repair
of
the
leak.
51
(
ii)
Respondent
activities
!
Prepare
the
data
item;

!
Reassess
the
data
item;

!
File
and
maintain
the
data
item
in
the
unit
operating
record;
and
!
Modify
the
data
item,
if
necessary.

(
e6)
Design,
Monitoring,
Operation,
and
Inspection
Information
(
i)
Data
item
!
Design
documentation
and
monitoring,
operating,
and
inspection
information
for
each
closed­
vent
system
and
control
device
required
to
comply
with
section
265.1060
including:

­­
Description
and
date
of
each
modification
that
is
made
to
the
closed­
vent
system
or
control
device
design;

­­
Identification
of
operating
parameter,
description
of
monitoring
device,
and
diagram
of
monitoring
sensor
location
or
locations
used
to
comply
with
section
265.1033(
f)(
1)
and
(
f)(
2);

­­
Monitoring,
operating
and
inspection
information
required
by
paragraphs
(
f)
through
(
j)
of
section
265.1033;

­­
Date,
time,
and
duration
of
each
period
that
occurs
while
the
control
device
is
operating
when
any
monitored
parameter
exceeds
the
value
established
in
the
control
device
design
analysis;

­­
Explanation
for
each
period
recorded
under
paragraph
(
3)
of
the
cause
for
control
device
operating
parameter
exceeding
the
design
value
and
the
measures
implemented
to
correct
the
control
device
operation;

­­
For
a
carbon
adsorption
system
operated
subject
to
requirements
specified
in
sections
265.1033(
g)
or
265.1033(
h)(
2),
date
when
existing
carbon
in
the
control
device
is
replaced
with
fresh
carbon;

­­
For
a
carbon
adsorption
system
operated
subject
to
requirements
specified
in
section
265.1033(
h)(
1),
a
log
recording
the
following
information:

­
Date
and
time
when
control
device
is
monitored
for
carbon
breakthrough
and
the
monitoring
device
reading;
and
52
­
Date
when
existing
carbon
in
the
control
device
is
replaced
with
fresh
carbon;

­­
Date
of
each
control
device
startup
and
shutdown;

(
ii)
Respondent
activities
!
Prepare
the
data
item;

!
Reassess
the
data
item;

!
File
and
maintain
the
data
item
in
the
unit
operating
record;
and
!
Modify
the
data
item,
if
necessary.

(
e7)
Equipment
Log
(
i)
Data
item
!
A
log
recording
the
following
information
for
all
equipment
subject
to
sections
265.1052
through
265.1060:

­­
A
list
of
identification
numbers
(
except
welded
fittings)
for
equipment
subject
to
the
standards
of
subpart
BB;

­­
A
list
of
identification
numbers
for
equipment
that
the
owner
or
operator
elects
to
designate
for
no
detectable
emissions,
as
indicated
by
an
instrument
reading
of
less
than
500
ppm
above
background,
under
sections
265.1052(
e),
265.1053(
i),
and
265.1057(
f);

­­
Signed
designation
of
this
equipment
as
subject
to
the
requirements
of
sections
265.1052(
e),
265.1053(
i),
and
265.1057(
f)
by
the
owner
or
operator;

­­
A
list
of
equipment
identification
numbers
for
pressure
relief
devices
required
to
comply
with
section
265.1054(
a);

­­
The
dates
of
each
compliance
test
required
in
sections
265.1052(
e),
265.1053(
i),
265.1054,
and
265.1057(
f);

­­
The
background
level
measured
during
each
compliance
test;

­­
The
maximum
instrument
reading
measured
at
the
equipment
during
each
compliance
test;
and
53
­­
A
list
of
identification
numbers
for
equipment
in
vacuum
service.

(
ii)
Respondent
activities
!
Prepare
the
data
item;

!
Reassess
the
data
item;

!
File
and
maintain
the
data
item
in
the
unit
operating
record;
and
!
Modify
the
data
item,
if
necessary.

(
e8)
Valve
log
(
i)
Data
item
!
A
log
for
all
valves
subject
to
section
265.1057(
g)
and
(
h)
that
includes
the
following
information:

­­
A
list
of
identification
numbers
for
valves
that
are
designated
as
unsafe
to
monitor,
an
explanation
for
each
valve
stating
why
the
valve
is
unsafe
to
monitor,
and
the
plan
for
monitoring
each
valve;
and
­­
A
list
of
identification
numbers
for
valves
that
are
designated
as
difficult
to
monitor,
an
explanation
for
each
valve
stating
why
the
valve
is
difficult
to
monitor,
and
the
planned
schedule
for
monitoring
each
valve.

(
ii)
Respondent
activities
Respondents
must:

!
Prepare
the
data
item;

!
Reassess
the
data
item;

!
File
and
maintain
the
data
item
in
the
unit
operating
record;
and
!
Modify
the
data
item,
if
necessary.

(
e9)
In­
compliance
Valve
Log
(
i)
Data
item
!
For
valves
complying
with
section
265.1062,
a
log
containing
the
following
information:
54
­­
A
schedule
for
monitoring;
and
­­
The
percent
of
valves
found
leaking
during
each
monitoring
period;

(
ii)
Respondent
activities
!
Prepare
the
data
item;

!
Reassess
the
data
item;

!
File
and
maintain
the
data
item
in
the
unit
operating
record;
and
!
Modify
the
data
item,
if
necessary.

(
e10)
Criteria
Log
(
i)
Data
item
!
A
criteria
log
containing
the
following
information:

­­
Criteria
required
in
section
265.1052(
d)(
5)(
ii)
and
section
265.1053(
e)(
2)
and
an
explanation
of
the
design
criteria;
and
­­
Any
changes
to
these
criteria
and
the
reasons
for
these
changes.

(
ii)
Respondent
activities
!
Prepare
the
data
item;

!
Reassess
the
data
item;

!
File
and
maintain
the
data
item
in
the
unit
operating
record;
and
!
Modify
the
data
item,
if
necessary.

(
e11)
Exemption
Log
(
i)
Data
item
!
An
exemption
log
containing
the
following
information:

­­
An
analysis
determining
the
design
capacity
of
the
hazardous
waste
management
unit;
55
­­
A
statement
listing
the
hazardous
waste
influent
to
and
effluent
from
each
hazardous
waste
management
unit
subject
to
the
requirements
in
sections
265.1052
through
265.1060
and
an
analysis
determining
whether
these
hazardous
wastes
are
heavy
liquids;
and
­­
An
up­
to­
date
analysis
and
the
supporting
information
and
data
used
to
determine
whether
or
not
equipment
is
subject
to
the
requirements
in
sections
265.1052
through
265.1060.
The
record
shall
include
supporting
documentation
as
required
by
section
265.1063(
d)(
3)
when
application
of
the
knowledge
of
the
nature
of
the
hazardous
waste
stream
or
the
process
by
which
it
was
produced
is
used.

(
ii)
Respondent
activities
!
Prepare
the
data
item;

!
Reassess
the
data
item;

!
File
and
maintain
the
data
item
in
the
unit
operating
record;
and
!
Modify
the
data
item,
if
necessary.

SMALL
QUANTITY
GENERATOR
PRE­
TRANSPORT
REQUIREMENTS
(
1)
Labeling
40
CFR
262.34(
a)(
2)
and
(
3)
require
that
SQGs
label
each
container
or
tank
accumulating
hazardous
waste
with
the
date
upon
which
each
period
of
accumulation
begins
and
the
words
"
Hazardous
Waste."
Section
262.34(
c)(
1)
requires
SQGs
accumulating
either
hazardous
waste
or
acutely
hazardous
waste
at
or
near
the
point
of
generation
to
mark
these
containers
with
the
words
"
Hazardous
Waste"
or
other
words
that
identify
the
contents
of
the
containers.
Section
262.34(
c)(
2)
further
requires
that,
if
the
SQG
accumulates
hazardous
waste
or
acutely
hazardous
waste
at
satellite
accumulation
in
excess
of
specified
amounts,
the
SQG
must,
within
three
days,
move
that
excess
waste
to
a
90­
day
accumulation
area.
During
that
three­
day
period,
the
SQG
must
mark
the
container
holding
the
excess
accumulation
with
the
date
the
excess
amount
began
accumulating.

(
i)
Data
items:

!
Labels
with
the
words
"
Hazardous
Waste"
and
the
date
that
accumulation
began.

(
ii)
Respondent
Activities:

Respondents
must
perform
the
following
requirements
in
complying
with
section
262.34(
a)(
2)
and
(
3)
and
262.34(
c)(
1)
and
(
2):
56
!
Label
all
containers
and
tanks
with
the
words
"
Hazardous
Waste"
and
the
date
that
accumulation
began.

!
Label
all
containers
with
the
words
"
Hazardous
Waste"
or
other
words,
and
label
all
containers
with
excess
accumulation
with
the
date
that
the
excess
accumulation
began
(
satellite
accumulation
areas
only)

(
2)
Emergency
Procedures
Section
262.34(
d)(
5)(
iv)(
A)
requires
that,
in
the
event
of
a
fire,
SQGs
must
call
the
fire
department
or
attempt
to
extinguish
it
using
a
fire
extinguisher.
Section
262.34(
d)(
5)(
iv)(
C)
requires
SQGs
to
immediately
notify
the
National
Response
Center
in
the
event
of
a
fire,
explosion,
or
other
release
which
could
threaten
human
health
outside
the
facility
or
when
the
generator
has
knowledge
that
a
spill
has
reached
surface
water.
Applicable
provisions
also
require
SQGs
to
document
if
State
or
local
authorities
decline
to
enter
into
arrangements
to
become
familiar
with
the
site
(
265.37(
b)),
and
require
SQGs
to
post
emergency
information
near
the
phone
(
262.34(
d)(
5)(
ii)).

(
i)
Data
items
The
data
items
required
in
making
this
report
are:

!
The
name,
address,
and
US
EPA
identification
number
of
the
generator;

!
Date,
time,
and
type
of
incident;

!
Quantity
and
type
of
hazardous
waste
involved
in
the
incident;

!
Extent
of
injuries,
if
any;
and
!
Estimated
quantity
and
disposition
of
recovered
materials,
if
any.

Other
data
items
include:

!
Notification
to
fire
department.

!
Documentation
that
local
officials
decline
to
enter
into
arrangements
for
coordinating
response.

!
Emergency
information
by
the
phone.

(
ii)
Respondent
activities
In
order
to
submit
data
items,
the
respondent
must
undertake
the
following
tasks:
57
!
Observe
the
scene
of
hazardous
waste
discharge
and
gather
information
regarding
the
incident;

!
Report
by
phone
the
requested
data
items
to
the
fire
department
and/
or
National
Response
Center;

!
Document
that
local
officials
decline
to
enter
into
arrangements
for
coordinating
response;
and
!
Post
emergency
information
by
the
phone.

(
3)
Requests
for
Extensions
of
the
Accumulation
Period
Section
262.34(
f)
allows
SQGs
to
apply
for
up
to
a
30­
day
extension
of
the
180­
or
270­
day
accumulation
period
limit.
At
the
discretion
of
the
Regional
Administrator,
these
extensions
will
be
granted
in
a
case­
by­
case
basis.

(
i)
Data
items
The
data
items
required
in
making
this
request
are:

!
The
unforeseen,
temporary,
or
uncontrollable
circumstances
causing
the
need
for
an
extension,
and
!
The
length
of
desired
extension
(
up
to
a
limit
of
30
days).

(
ii)
Respondent
activities
In
order
to
submit
this
request,
the
respondent
must
undertake
the
following
task:

!
Prepare
and
submit
the
request
to
the
Regional
Administrator.

RECORDKEEPING
AND
REPORTING
REQUIREMENTS
Sections
262.40
and
.43
require
all
generators
to
keep
records
that
may
be
reviewed
by
EPA
during
inspections,
and
to
report
additional
information
as
required
by
the
Administrator.
Section
262.40
requires
generators
to
keep
a
copy
of
items,
such
as
the
records
of
test
results,
for
at
least
three
years.
Section
262.43
requires
generators
to
furnish
additional
reports
regarding
the
volume
and
nature
of
their
hazardous
wastes
as
deemed
necessary.

(
i)
Data
items
Copies
of
any
records
of
test
results,
waste
analyses,
or
other
determinations.
The
Administrator
may
require,
as
deemed
necessary,
additional
information
regarding
the
quantity
and
disposition
of
hazardous
wastes.
58
(
ii)
Respondent
activities
In
order
to
submit
the
recordkeeping
and
reporting
data
items,
generators
must
undertake
the
following
tasks:

!
Maintain
the
test
results,
waste
analyses,
or
other
determinations;

!
Gather
and
provide
any
additional
information
requested
by
the
Administrator.

EXPORTS
AND
IMPORTS
OF
HAZARDOUS
WASTES
Sections
262.53
­
.57
are
requirements
for
"
primary
exporters,"
or
the
persons
shipping
or
arranging
to
ship
hazardous
waste
to
a
TSDF
outside
the
boundaries
of
the
United
States.
All
generators
meeting
the
definition
of
"
primary
exporters"
are
required
to
notify
EPA
of
their
intention
to
export
hazardous
waste,
renotify
the
EPA
if
the
conditions
of
the
original
notification
are
altered
(
including,
under
certain
circumstances,
if
a
shipment
cannot
be
delivered
to
the
designated
or
alternate
consignee
for
any
reason),
file
an
Annual
Report
with
the
Administrator
summarizing
the
types,
quantities,
frequencies,
and
ultimate
destination
of
all
hazardous
wastes
exported
during
the
previous
years,
and
keep
copies
of
relevant
documents
for
a
period
of
three
years.
EPA
may
also
request
that
primary
exporters
provide
additional
information,
as
requested
by
the
receiving
country.

Sections
262.83­
.85
are
requirements
for
primary
exporters
exporting
to
OECD
countries,
and
are
basically
the
same,
except
for
a
few
additional
information
items,
which
are
separately
identified
below.

(
1)
Notification
of
Intent
to
Export
Section
262.53(
a)
requires
the
primary
exporters
of
hazardous
wastes
to
submit
a
signed
notification
of
intent
to
export.

(
i)
Data
items
The
data
items
required
by
this
notification
include:

!
The
name,
mailing
address,
telephone
number,
and
EPA
ID
number
of
the
primary
exporter;
and
!
For
each
consignee,
the
following
information
for
hazardous
waste
type:

­­
A
description
of
the
hazardous
wastes
and
EPA
waste
number
and
DOT
description;
­­
An
estimate
of
the
frequency
and
time
period
of
the
shipment
to
the
consignee;
­­
Total
quantity
of
hazardous
wastes;
59
­­
Points
of
entry
of
(
or
departure
from)
each
foreign
country;
­­
A
description
of
the
means
of
transportation
and
the
types
of
containers
containing
the
hazardous
wastes;
­­
A
description
of
the
waste
management
techniques
to
be
utilized
in
managing
the
wastes
in
the
host
countries;
­­
The
name
and
site
address,
of
the
consignee
and
any
alternate
consignee;
and
­­
The
name
of
any
countries
through
which
the
hazardous
wastes
will
transit,
as
well
as
the
period
of
time
the
wastes
will
remain
in
the
transit
countries
and
the
nature
of
its
handling
while
there;
­­
After
consent
is
granted,
exporter
will
receive
EPA
acknowledgment
of
consent
from
EPA
and
must
attach
acknowledgment
of
consent
to
manifest.

!
additional
data
items
only
for
exporters
to
OECD
countries
(
262.83)

­­
Fax
number
­­
Serial
number/
identifier
of
notification
form
­­
Intended
carrier(
s)
and/
or
agents
 
Countries
of
export,
import,
and
transit
and
relevant
competent
authorities
 
Certification
of
the
existence
of
written
contract,
chain
of
custody,
or
equivalent
arrangement
with
consignee,
between
exporter
and
importer
 
Certification
that
the
information
is
complete
and
correct
 
Certification
of
financial
guarantee
if
required
by
any
concerned
country
(
importing
and
transit).

(
ii)
Respondent
activities
In
order
to
comply
with
the
notification
of
intent
to
export
requirements,
the
primary
exporter
must
undertake
the
following
tasks:

!
Collect
information;
and
!
Prepare
and
submit
a
notification.

Additional
tasks
are
required
of
exporters
to
OECD
countries:

!
Read
the
regulations
codifying
the
OECD
Decision
and
assess
applicability
!
Complete
the
additional
information
for
the
Notification
of
Intent
to
Export
(
2)
Renotification
of
Intent
to
Export
60
Generators
are
also
required
to
notify
EPA
should
certain
information
on
the
notification
be
modified,
such
as
an
increase
of
the
volume
of
hazardous
wastes
shipped,
before
the
hazardous
wastes
are
exported
(
§
262.53(
c)).
Under
section
262.54(
g),
if
a
shipment
cannot
be
delivered
to
the
designated
or
alternate
consignee
for
any
reason,
the
primary
exporter
must
either
renotify
EPA
before
the
delivery
of
the
shipment
to
a
new
consignee
(
in
accordance
with
§
262.53(
c)),
or
instruct
the
transporter
to
return
the
waste
to
the
exporter
or
a
management
facility
in
the
United
States.

(
i)
Data
items
!
Written
description
of
any
of
the
modified
notification
information.
For
certain
categories
of
information
(
e.
g.,
telephone
numbers,
ports
of
entry
and
exit,
or
decreases
in
quantity),
EPA
has
waived
this
renotification
requirement.
EPA
will
inform
the
recipient
and
transit
countries
of
the
changes
and,
upon
their
consent,
forward
to
the
primary
exporter
an
EPA
Acknowledgment
of
Consent.

(
ii)
Respondent
activities
In
order
to
comply
with
the
renotification
of
the
intent
to
export
requirements,
the
primary
exporter
must
undertake
the
following
tasks:

!
Collect
change
to
export
information;
and
!
Prepare
and
submit
a
renotification
documenting
changes.

(
3)
OECD
Tracking
Document
Under
section
262.84,
primary
exporters
of
hazardous
wastes
to
OECD
countries
must
provide
information
on
a
tracking
document,
in
addition
to
information
provided
for
US
manifest
requirements
(
ICR
Number
801).

(
i)
Data
items
!
Fax
numbers
of
the
export
notifier,
consignee,
and
carrier
!
Technologies
employed
by
the
recovery
facility
!
Means
and
mode
of
transport,
including
types
of
packaging
!
Countries
of
export,
import,
and
transit
and
relevant
competent
authorities
!
Frequency
of
shipment
(
single
or
general
notification).

(
ii)
Respondent
activities
61
In
order
to
comply
with
the
tracking
requirements,
the
primary
exporter
or
importer
ust
undertake
the
following
tasks:

!
Read
the
regulations
codifying
the
OECD
Decision
and
assess
applicability
!
Complete
the
additional
information
for
the
tracking
document.

(
4)
One
time
Import
Notification
The
following
information,
which
is
required
by
the
OECD
Decision,
is
in
addition
to
the
information
required
for
non­
OECD
exports
and
imports,
under
40
CFR
part
262,
subparts
E
and
F,
respectively:

The
rule
codifying
the
OECD
Decision
did
not
impose
any
significant
new
or
additional
information
collection
requirements
on
U.
S.
importers
of
hazardous
waste
destined
for
recovery.
However,
U.
S.
recovery
facilities
that
import
hazardous
waste
are
required
to
sign
additional
copies
of
the
tracking
document
and
transmit
them
to
the
appropriate
parties
within
three
working
days
instead
of
the
previously
required
30
days
[
see
§
§
264.71(
d)
and
265.71(
d)].

(
ii)
Respondent
Activities
!
Read
the
regulations
codifying
the
OECD
Decision
and
assess
applicability
!
Sign
and
transmit
the
additional
copies
of
the
tracking
document
to
EPA,
competent
authority
of
exporter
country,
and
competent
authority
of
transit
country
(
if
applicable)

!
Comply
with
the
expedited
response
time
(
three
working
days)
to
transmit
copies
of
the
signed
tracking
document
to
the
foreign
exporter,
EPA,
competent
authority
of
exporter
country,
and
competent
authority
of
transit
country
(
if
applicable).
Although
the
response
time
has
been
reduced,
there
is
no
additional
labor
effort
or
paperwork
burden.
Therefore,
no
burden
estimates
are
calculated
for
this
effort.

(
5)
Additional
Reporting
Under
sections
262.53(
d)
and
262.85(
g),
EPA
may
request
that
primary
exporters
submit
additional
information,
as
requested
by
the
receiving
country.

(
i)
Data
items
!
The
data
items
required
by
this
demonstration
are
specified
by
the
receiving
country.

(
ii)
Respondent
activities
62
In
order
to
submit
these
reporting
data
items,
primary
exporters
must:

!
Gather
and
provide
any
additional
information
requested
by
EPA
on
behalf
of
the
receiving
country.

(
4)
Annual
Report
Requirements
Section
262.56(
a)
requires
exporters
of
hazardous
wastes
to
file
an
Annual
Report
with
the
Administrator
summarizing
hazardous
waste
export
activities.

(
i)
Data
items
The
following
data
items
must
be
reported
annually:

!
The
EPA
identification
number,
name,
and
mailing
address
and
site
of
the
exporter;

!
The
calendar
year
covered
by
the
report;

!
The
name
and
site
address
of
each
consignee;

!
For
each
consignee,
the
following
data:

­­
A
description
of
the
hazardous
waste,
­­
The
EPA
hazardous
waste
number,
­­
The
DOT
hazard
class,
­­
The
name
and
US
EPA
ID
number
for
each
transporter
used,
­­
The
total
amount
of
waste
shipped,
and
­­
The
number
of
shipments
pursuant
to
each
notification;

!
A
description
of
efforts
undertaken
to
reduce
the
volume
and
toxicity
of
wastes
generated,
as
well
as
a
description
of
any
variation
in
the
volume
and
toxicity
of
wastes
relative
to
previous
years
(
not
applicable
to
SQGs,
or
to
LQGs
that
submitted
this
information
in
a
Biennial
Report);
and
!
A
signed
certification.

(
ii)
Respondent
activities
In
order
to
comply
with
the
Annual
Report
requirements,
the
primary
exporter
must
undertake
the
following
tasks:

!
Research
the
information
needed
for
SQGs
and
LQGs;
and
!
Prepare
and
submit
a
report.
63
(
5)
Recordkeeping
Requirements
Section
262.57(
a)
requires
all
primary
exporters
to
keep
a
copy
of
certain
documents
for
a
period
of
at
least
three
years
after
the
wastes
were
accepted
by
the
initial
transporter
(
or
longer
if
requested
by
the
Administrator
or
if
related
to
an
activity
subject
to
an
enforcement
action):

(
i)
Data
items
The
following
records
must
be
kept:

!
Notification
of
intent
to
export;

!
EPA
acknowledgment
of
consent;

!
Confirmation
of
delivery
from
the
consignee;
and
!
Annual
report.

(
ii)
Respondent
activities
In
order
to
comply
with
the
recordkeeping
requirements,
the
generator
must
undertake
the
following
task:

!
File
and
maintain
the
notification
of
intent,
acknowledgment
of
consent,
confirmation
of
delivery,
Annual
Report,
and
Exception
Reports
for
a
period
of
at
least
three
years.

5.
THE
INFORMATION
COLLECTED
­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
The
following
subsections
discuss
how
EPA
will
collect
the
information,
what
activities
EPA
will
perform
once
the
information
has
been
received,
and
how
EPA
will
manage
the
information
it
collects.
The
subsections
also
include
a
discussion
of
how
the
information
collection
requirements
affect
small
entities.

5(
a)
AGENCY
ACTIVITIES
HAZARDOUS
WASTE
DETERMINATION
REQUIREMENTS
There
are
no
Agency
activities
associated
directly
with
generator
waste
determinations.
EPA
may
review
results
of
such
determinations
during
site
inspections.

LARGE
QUANTITY
GENERATOR
PRE­
TRANSPORT
REQUIREMENTS
64
Although
personnel
training
information
is
not
formally
submitted
to
EPA,
EPA
may
review
information
collected
from
the
requirements
during
facility
inspections.
Therefore,
this
analysis
assumes
that
the
Agency
will
spend
a
minimal
amount
of
review
time
at
certain
facilities.

Agency
activities
associated
with
emergency
reporting
requirements
include
reviewing
documents
in
the
emergency
coordinators'
emergency
reports.

Agency
activities
associated
with
the
receipt
of
reports
of
releases
are
review
of
the
information
submitted,
entry
of
this
information
into
a
database
tracking
all
releases,
and,
if
necessary,
transmittal
of
the
information
to
the
respective
emergency
response
authorities.

Agency
activities
associated
with
requirements
for
generators'
tank
systems
include
the
following:

!
Review
and
evaluate
information
on
equivalent
containment
devices;

!
Evaluate
information
submitted
for
exemption
from
the
24­
hour
leak
detection
requirement;
and
!
Evaluate
information
submitted
for
variances
from
secondary
containment
requirements,
including
no­
free
liquids
demonstrations.

In
addition,
the
Agency
must
perform
the
following
activities
for
generators'
tank
systems:

!
Evaluate
information
submitted
for
exemption
from
24­
hour
waste
removal
requirement;

!
Review
existing
tank
integrity
assessments;

!
Review
new
tank
design
and
installation
assessments;

!
Review
release
notification
reports;

!
Review
major
repair
certifications;
and
!
Review
requests
for
accumulation
period
extensions.

Agency
activities
associated
with
requirements
for
generators'
drip
pads
include
the
following:

!
Review
plans
for
upgrading
drip
pads;

!
Review
and
evaluate
drawings
and
certifications
of
drip
pads;

!
Evaluate
notices
of
releases
from
drip
pads;
and
65
!
Review
repairs
conducted
to
drip
pads.

Agency
activities
associated
with
requirements
for
generators'
containment
buildings
include
the
following:

!
Review
and
evaluate
notifications
of
releases
of
hazardous
waste;
and
!
Review
notices
of
repairs
to
containment
buildings.

Some
of
the
records
and
certifications
required
under
this
section
are
not
formally
submitted
to
EPA,
but
must
be
kept
on
file
at
the
facility
and
made
available
to
EPA
upon
request.
On
others,
the
regulations
are
not
explicit
about
whether
a
demonstration
must
be
submitted
to
EPA;
this
ICR
generally
assumes
that
LQGs
submit
the
demonstrations
anyway.

LARGE
QUANTITY
GENERATOR
AIR
EMISSION
STANDARDS
(
1)
Air
Emissions
from
Process
Vents
There
are
no
Agency
activities
associated
with
the
requirements
for
generators
with
process
vents.
Although
EPA
will
examine
monitoring
documentation,
control
device
documentation,
waste
determination
documentation,
and
information
required
in
the
operating
record
during
periodic
inspections,
these
activities
are
a
part
of
EPA's
overall
compliance
and
enforcement
program.
Therefore,
the
cost
associated
with
these
activities
is
not
attributable
to
subpart
AA.

(
2)
Air
Emissions
from
Equipment
Leaks
Agency
activities
associated
with
the
requirements
for
generators
with
equipment
subject
to
subpart
BB
include:

!
Reviewing
notifications
to
implement
the
alternate
valve
standard
specified
in
section
265.1061(
a));

!
Reviewing
notifications
to
discontinue
implementing
the
alternate
valve
specified
in
section
265.1061(
a));
and
!
Reviewing
notifications
to
implement
the
alternate
valve
standard
specified
in
sections
265.1062(
b)(
2)
or
(
b)(
3)).

SMALL
QUANTITY
GENERATOR
PRE­
TRANSPORT
REQUIREMENTS
The
Agency
activities
associated
with
SQG
pre­
transport
requirements
include
reviewing
requests
for
extensions
of
the
accumulation
period
under
section
262.34(
e).
No
other
information
66
4
The
quantifiable
benefit
to
EPA
in
implementing
the
OECD
Decision
is
the
reduced
burden
cost
to
EPA
to
implement
the
exporter
procedures
required
under
the
OECD
Decision.
The
Agency
is
relieved
of
having
to
forward
the
importing
country's
Acknowledgment
of
Consent
or
denial
to
the
U.
S.
exporter.
is
required
to
be
submitted
to
EPA
(
SQG
notification
requirements
include
contacting
the
National
Response
Center,
operated
by
the
Coast
Guard).

RECORDKEEPING
AND
REPORTING
Agency
activities
associated
with
the
recordkeeping
and
reporting
requirements
are
the
on
site
review
of
the
documents
maintained
at
the
facility,
and
the
review
of
submitted
information
and
the
entry
of
this
information
into
a
database.

EXPORT
AND
IMPORT
REQUIREMENTS
Agency
activities
associated
with
the
receipt
of
notifications
and
renotifications
of
intent
to
export
hazardous
waste
are
to
review
to
this
information,
and
to
submit,
in
conjunction
with
the
Department
of
State,
a
notification
to
the
receiving
country
and
any
transit
countries.
Upon
the
consent
(
or
refusal)
of
the
receiving
countries
to
the
receipt
of
the
hazardous
waste,
the
Agency
will
forward
to
the
primary
exporter
an
acknowledgment
of
consent
(
or
a
written
notification
of
the
objection).
Other
Agency
activities
associated
with
the
export
of
hazardous
waste
are
the
receipt
of
Annual
Reports.
The
Agency
will
review
these
documents
and
enter
them
into
a
database.
During
compliance
inspections,
the
Agency
will
also
review
records
kept
on
site.

The
OECD
Decision
requires
the
Agency
to
perform
the
following
additional
information
collection
and
management
activities.
These
activities
are
in
addition
to
the
baseline
(
non­
OECD)
information
collection
and
management
requirements
already
imposed
by
RCRA
for
hazardous
waste
exports
and
imports.
4
Exports
From
the
U.
S.:

°
Receive
and
record
the
Acknowledgment
of
Receipt
from
the
importing
country
°
Receive
and
record
the
Tracking
Document
received
from
the
foreign
recovery
facility.

Imports
To
the
U.
S.:

°
Transmit
an
Acknowledgment
of
Receipt
to
the
foreign
exporter,
competent
authority
of
the
foreign
exporting
country,
and
competent
authority
of
transit
country(
ies)
if
applicable
°
Receive
and
record
the
Tracking
Document
received
from
the
U.
S.
recovery
facility.
67
5(
b)
COLLECTION
METHODOLOGY
AND
MANAGEMENT
In
collecting
and
analyzing
the
information
required
under
the
generator
requirements,
EPA
uses
personal
computers
and
applicable
database
software,
when
appropriate.

5(
c)
SMALL
ENTITY
FLEXIBILITY
When
promulgating
the
regulations
covered
under
this
ICR,
EPA
considered
the
effect
of
these
regulations
on
small
businesses.
EPA
found,
however,
that
most
small
businesses
do
not
generate
hazardous
waste
and,
therefore,
are
not
significantly
affected
by
the
generator
standards.
EPA
has
been
directed
by
Congress
to
promulgate
standards
to
protect
public
health
and
the
environment.
In
certain
cases,
such
as
the
Annual
Report
requirements
for
primary
exporters
of
hazardous
waste,
EPA
has
limited
the
informational
requirements
for
small
generators.
These
facilities
do
not
have
to
include
a
description
of
efforts
taken
to
reduce
waste
volume
or
toxicity,
or
descriptions
of
any
variation
in
the
volume
and
toxicity
of
wastes
relative
to
previous
years.
Certain
categories
of
small
entities
are
exempt
from
the
information
collection
requirements
described
herein.
Others
are
subject
to
reduced
requirements.
The
training
requirements
do
not
apply
to
small
quantity
generators.
Nor
are
they
subject
to
the
contingency
plan
and
emergency
procedure
requirements.
Finally,
such
generators
are
subject
to
reduced
tank
standards
under
section
265.201.

5(
d)
COLLECTION
SCHEDULE
HAZARDOUS
WASTE
DETERMINATION
REQUIREMENTS
There
is
no
collection
schedule
for
generators'
hazardous
waste
determinations.

PRE­
TRANSPORT
REQUIREMENTS
(
FOR
BOTH
LQGs
AND
SQGs)

The
reporting
requirements
outlined
in
the
regulations
will
vary
according
to
individual
facility
circumstances.
Because
container
labeling
and
keeping
records
of
personnel
training
are
conducted
onsite,
a
discussion
of
a
collection
schedule
is
not
relevant.

There
is
no
collection
schedule
for
generators
reporting
releases
of
hazardous
waste
into
the
environment,
as
facilities
only
report
on
these
occasions.
The
emergency
coordinator
must
immediately
notify
the
appropriate
authorities
of
an
imminent
or
actual
emergency
situation.
An
LQG
must
submit
a
written
report
of
any
incident
that
requires
the
implementation
of
the
contingency
plan
within
15
days
of
its
occurrence.
Since
generators
are
not
required
to
submit
their
contingency
plans
to
EPA,
discussion
of
a
collection
schedule
for
these
facilities
is
not
applicable.

Records
of
tank
system
assessments,
statements
on
design
and
installation,
and
records
of
annual
leak
tests
and
inspections
are
kept
by
the
LQGs.
Therefore,
a
discussion
of
a
collection
68
schedule
is
not
applicable.
The
time
frame
for
submitting
demonstrations
provided
under
this
section
is
dependent
upon
the
desire
of
LQGs
to
submit
such
demonstrations.
However,
the
regulations
do
specify
time
frames
for
submissions
related
to
certain
situations.
LQGs
must
submit
release
notification
reports
within
30
days
of
detecting
a
release.
In
addition,
the
certification
of
major
repairs
(
required
under
§
265.196(
f))
must
be
submitted
within
seven
days
of
returning
the
repaired
tank
system
to
use.
With
regard
to
drip
pads,
plans
for
upgrading
drip
pads
must
be
prepared
2
years
before
completion
of
such
repairs,
pad
assessments
must
be
recertified
annually,
records
of
releases
must
be
documented
upon
detection
and
notice
provided
to
EPA
within
24
hours
(
written
notice
in
within
10
days),
and
notice
of
repairs
provided
upon
completion
of
such
repairs.
As
for
containment
buildings,
certification
that
the
building
meets
design
requirements
is
required
within
60
days
of
initiating
operation,
records
of
releases
must
be
filed
upon
detection
and
notice
to
EPA
provided
within
7
days
(
written
notice
within
14
days).
In
addition,
monitoring
data
must
be
placed
in
the
record
every
7
days.

There
is
no
collection
schedule
for
generators
requesting
extensions
from
the
Regional
Administrator
of
the
accumulation
period,
as
these
requests
presume
unforeseen
circumstances.

LARGE
QUANTITY
GENERATOR
AIR
EMISSION
STANDARDS
The
regulations
at
40
CFR
part
265,
subparts
AA
and
BB
for
generators
do
not
specify
time
frames
for
submittals,
and
a
discussion
of
a
schedule
regarding
these
requirements
is
not
applicable.

RECORDKEEPING
AND
REPORTING
As
the
recordkeeping
regulations
in
section
262.40
do
not
require
the
transmittal
of
any
information,
a
discussion
of
a
schedule
regarding
this
requirement
is
not
applicable.
Additionally,
as
section
262.43
allows
the
Administrator
to
require
additional
information
of
generators
on
an
irregular
basis,
a
discussion
of
a
collection
schedule
is
not
applicable.

EXPORT
REQUIREMENTS
Generators
meeting
the
definition
of
primary
exporters
should
notify
the
EPA
60
days
before
the
initial
shipment
of
waste
is
scheduled
to
leave
the
United
States
(
§
262.53).
The
notifications
of
intent
to
export
are
collected
as
necessitated
by
generator
activities.
EPA
has
limited
the
burden
of
collection
by
allowing
one
notification
to
cover
activities
extending
over
a
twelve­
month
period,
unless
certain
conditions
are
altered.

Under
the
rule
codifying
the
OECD
Decision,
Notification
of
Intent
to
Export
submissions
and
tracking
documents
are
generated
and
sent
to
EPA
on
a
random,
occurrence­
specific
basis
for
which
there
is
no
formalized
schedule.
Once
these
events
do
occur,
notifications
must
be
sent
to
EPA
within
45
days
prior
to
initiating
waste
exports,
and
tracking
documents
must
be
sent
to
EPA
by
U.
S.
recovery
facilities
within
three
working
days
of
receipt
of
imported
wastes.
69
4
Exhibits
contain
rounding
error.
The
collection
schedule
for
export
activity
Annual
Reports
requires
their
submittal
no
later
than
March
1
of
the
following
year
(
§
262.56).
The
report
must
include
information
regarding
the
primary
exporter,
transporter,
and
consignee,
as
well
as
the
volume
and
characteristics
of
the
waste.
The
report
must
also
include
a
description
of
any
variation
in
the
volume
and
toxicity
of
wastes
relative
to
previous
years
(
not
applicable
to
generators
of
more
than
100
kilograms
but
less
than
1000
kilograms
of
hazardous
waste
in
a
calendar
month
or
to
those
already
submitting
information
in
the
Biennial
Report),
and
a
signed
certification.
The
recordkeeping
regulations
in
section
262.57
do
not
require
the
transmittal
of
any
information;
a
discussion
of
a
schedule
regarding
this
requirement
is
not
applicable.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
ESTIMATING
ANNUAL
RESPONDENT
BURDEN
This
ICR
is
a
comprehensive
presentation
of
all
of
the
information
collection
activities
required
for
generator
standards
and
covers
Fiscal
Years
2004
­
2006.

Exhibit
1
summarizes
the
universe
of
generators.
EPA
estimated
respondent
burden
hours
and
costs
associated
with
all
of
the
requirements
covered
in
this
ICR
in
the
following
exhibits:
Exhibit
2
addresses
both
LQG
and
SQG
respondent
burden
for
reading
the
regulations;
Exhibit
3
addresses
LQG
pre­
transport
requirements;
Exhibit
4
addresses
LQG
air
emission
standards;
Exhibit
5
addresses
SQG
pre­
transport
requirements;
Exhibit
6
addresses
certain
recordkeeping
and
reporting
requirements
for
all
generators;
Exhibit
7
and
8
address
specific
export
requirements
for
all
generators;
and
Exhibit
9
summarizes
total
annual
aggregate
respondent
burden
and
costs
for
all
activities.
5
6(
b)
ESTIMATING
ANNUAL
RESPONDENT
COSTS
Exhibits
2
through
8
estimate
the
costs
to
generators
based
on
the
cost
of
labor,
operation
and
maintenance
(
O&
M),
and
capital.
For
purposes
of
this
analysis,
EPA
estimates
an
average
hourly
respondent
labor
cost
(
including
fringe
and
overhead)
of119.91
for
legal
staff,
$
85.82
for
managerial
staff,
$
62.30
for
technical
staff,
and
$
31.74
for
clerical
staff.
These
rates
are
based
on
previous
industry
consultations
and
have
been
updated
to
reflect
year
2004
salary
levels.

In
the
following
paragraphs,
EPA
estimates
capital
costs
associated
with
the
information
requirements
covered
by
this
ICR.
Capital
costs
usually
include
any
produced
physical
good
needed
to
provide
the
needed
information,
such
as
machinery,
computers,
and
other
equipment.
For
this
ICR,
the
only
required
capital
is
file
cabinets
for
maintaining
reports.
As
shown
in
Exhibit
9,
EPA
estimates
the
total
average
annual
capital
cost
to
all
generators,
collectively,
to
be
approximately
$
22,770.
In
ICR
0820.08,
EPA
took
the
following
steps
to
derive
these
costs:
70
!
Estimate
the
total
annual
volume
of
reports
required
to
be
retained
by
all
generators.
In
total,
EPA
estimates
that
LQGs
must
maintain
approximately
91
pages
of
reports
annually,
while
SQGs
maintain
approximately
2
pages.

!
Ascertain
the
number
of
standard­
size
file
cabinets
that
would
provide
the
needed
capacity
and
estimate
the
aggregate
purchasing
price.
Given
that
a
standard­
size,
five­
drawer,
lateral
file
cabinet
holds
approximately
16,000
pages,
EPA
estimates
that
the
hazardous
waste
industry
would
need
to
purchase
approximately
114
file
cabinets
each
year
(
i.
e.,
1,825,731/
16,000).
These
111
file
cabinets
represent
the
total
capacity
needed
by
the
industry,
collectively,
to
store
all
of
its
reports.
Based
on
its
consultations,
EPA
estimates
that
the
purchasing
price
for
one
file
cabinet
is
$
550,
and
for
all
114
file
cabinets,
$
62,700.

!
Annualize
the
aggregate
purchasing
price
using
a
net
present
value
formula.
EPA
used
the
following
annualized
net
present
value
formula
to
calculate
the
annual
cost
to
the
hazardous
waste
industry
to
acquire
these
file
cabinets:

Annual
Cost
=
$
62,700(
A/
P,
k,
t)

where
A/
P
=
capital
recovery
factor;
k
=
discount
rate
of
7
percent;
t
=
life
of
equipment
(
3
years).

Based
on
this
formula,
the
total
annualized
cost
of
file
cabinets
was
reported
in
ICR
0820.08
to
be
approximately
$
23,892.

°
For
this
ICR,
because
the
estimated
cost
of
one
file
cabinet
was
confirmed
to
be
the
same
as
in
previous
years,
the
total
costs
were
estimated
by
using
a
percentage
of
the
previous
total
based
on
the
decrease
in
the
universe
of
respondents.

O&
M
costs
are
those
costs
associated
with
a
paperwork
requirement
incurred
continually
over
the
life
of
the
ICR.
They
are
defined
by
the
PRA
as
"
the
recurring
dollar
amount
of
cost
associated
with
O&
M
or
purchasing
services."
For
this
ICR,
O&
M
costs
cover
postage
and
an
envelope
for
reports
sent
to
other
parties
$
1.29
postage,
5
cents
per
envelope)
photocopying
of
reports
submitted
to
the
Agency
(
10
cents
per
page),
for
long­
distance
phone
calls
($
5.00
per
call).
O&
M
costs
are
shown
in
Exhibits
2
though
9
for
all
applicable
activities.

6(
c)
ESTIMATING
ANNUAL
AGENCY
BURDEN
AND
COST
EPA
estimates
Agency
burden
hours
and
costs
associated
with
all
the
requirements
covered
in
this
ICR
in
Exhibit
9.
EPA
estimates
an
average
hourly
Agency
labor
cost
of
$
61.32
for
Regional
legal
staff,
$
44.11
for
Regional
managerial
staff,
$
30.95
for
Regional
technical
staff,
and
$
18.82
for
Regional
clerical
staff.
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:
71
Legal
staff
GS­
15,
Step
1
Managerial
staff
GS­
13,
Step
1
Technical
staff
GS­
11,
Step
1
Clerical
staff
GS­
06,
Step
1
EPA
divided
annual
compensation
estimates
by
2,080,
the
number
of
hours
in
a
Federal
work
year,
and
multiplied
the
rates
by
the
standard
government
overhead
factor
of
1.6
to
derive
hourly
rates.

6(
d)
ESTIMATING
THE
RESPONDENT
UNIVERSE
LARGE
QUANTITY
GENERATOR
AND
SMALL
QUANTITY
GENERATOR
REQUIREMENTS
(
Exhibits
1
and
2)

(
1)
Reading
the
Regulations
Based
on
the
2001
Biennial
Reporting
System
(
BRS),
which
is
the
most
current
available,
EPA
estimates
that
there
are
approximately
1,9081
LQGs.
In
addition,
EPA
estimates
that
there
are
1
new
entrant
exporter
LQG
under
the
OECD
agreement,
and
26
new
entrant
exporters
under
Bilateral
agreements.
However,
EPA
estimates
that
a
total
of
24
LQGs
will
be
newly
exempt
as
generators
of
zinc
bearing
materials
used
in
fertilizer,
and
an
additional
5
LQGs
will
be
newly
exempt
as
zinc
fertilizer
manufacturers,
for
a
total
of
19,097
LQGs.
A
number
of
these
LQGs
(
1,395),
however,
are
also
hazardous
waste
treatment,
storage,
and
disposal
facilities
(
TSDFs).
These
facilities
are
covered
by
other
ICRs
and
were
deleted
from
facilities
covered
in
this
document,
yielding
an
estimated
17,684
LQGs.
Based
on
its
analysis
of
the
2001
BRS
and
the
Resource
Conservation
and
Recovery
Information
System
(
RCRIS),
EPA
estimates
that
there
are
approximately
108,232
SQGs.
EPA
believes
that
a
number
of
the
LQGs
(
about
668)
and
SQGs
(
about
866)
also
are
government­
owned
and
government­
operated
facilities
and,
therefore,
not
addressed
in
this
ICR.
Subsequently,
these
government­
owned
and
government­
operated
generators
were
deleted
from
the
universe
covered
in
this
ICR,
yielding
an
estimated
17,016
LQGs
and107,366
SQGs.
As
shown
in
Exhibit
1,
approximately124,382
generators
comprise
the
respondent
universe.
As
shown
in
Exhibit
2,
EPA
expects
that
each
LQG
will
average
one
hour
to
read
the
generator
standards
once
a
year,
while
each
SQG
will
average
42
minutes
per
year.

EXHIBIT
1
UNIVERSE
OF
GENERATORS
WASTE
HANDLER
TYPE
total
number
TSD
federal
NUMBER
OF
WASTE
HANDLERS
Large
Quantity
Generator
19,079
1,395
668
17,016
72
Small
Quantity
Generator
108,232
866
107,366
Total
124,382
HAZARDOUS
WASTE
DETERMINATION
REQUIREMENTS
(
Exhibit
3)

Under
40
CFR
262.11,
all
generators
must
determine
whether
their
solid
waste
qualifies
as
hazardous
under
RCRA.
Generators
may
test
the
waste
or
use
knowledge
of
the
waste
to
make
this
determination.

EPA
notes
that
generators
must
also
determine,
under
the
Land
Disposal
Restrictions
(
LDR)
Program,
whether
their
hazardous
waste
is
restricted
from
land
disposal,
as
required
by
40
CFR
268.7(
a)(
1)
and
268.9(
a).
EPA
has
burdened
generators
for
their
LDR
determinations
in
the
Land
Disposal
Restrictions
ICR,
Number
1442.

EPA
has
confirmed
through
consultations
that
generators
normally
make
their
hazardous
waste
and
LDR
determinations
simultaneously
and
therefore
do
not
incur
a
separate
burden
for
each
determination.
For
example,
a
generator
would
normally
make
a
single
request
to
a
laboratory
to
determine
if
its
waste
is
both
hazardous
and
restricted
from
land
disposal.
Given
this
reasoning,
EPA
does
not
burden
generators
in
this
ICR
for
making
hazardous
waste
determinations,
since
this
burden
is
already
reflected
in
ICR
1442.17.

LARGE
QUANTITY
GENERATOR
PRE­
TRANSPORT
REQUIREMENTS
(
Exhibit
3)

(
1)
Labeling
In
section
262.34(
a)(
2)
and
(
3),
EPA
requires
all
LQGs
to
label
containers
with
the
words
"
Hazardous
Waste"
and
the
date
of
accumulation.
EPA
expects
that
all
LQGs
to
comply
with
this
requirement.
In
section
262.34
(
c)(
1)
and
(
2),
EPA
requires
LQGs
accumulating
hazardous
waste
at
satellite
accumulation
areas
to
label
containers
as
specified.
EPA
expects
that
all
LQGs
will
comply
with
these
requirements
each
year.

(
2)
Personnel
Training
In
section
262.34(
a)(
4),
EPA
requires
all
LQGs
to
comply
with
the
personnel
training
requirements
in
section
265.16(
d).
Section
265.16(
d)
and
(
e)
require
that
LQGs
maintain
copies
of
personnel
training
documents
and
records
at
their
facilities.
Based
on
an
examination
of
historical
BRS
data
and
trends,
EPA
estimates
that
about
3744
LQGs
each
year
are
new
entrants
into
the
hazardous
waste
universe
and
will
be
required
to
collect
information
regarding
their
employees'
training
experiences.

(
3)
Contingency
Planning
and
Emergency
Procedures
73
7
Based
on
an
analysis
of
ERNS
data
finalized
in
April
2000.,
adjusted
to
2004
BRS
levels.
This
ICR
assumes
that
existing
LQGs
have
already
prepared
contingency
plans.
Therefore,
only
new
LQGs
will
be
required
to
document
whether
State
or
local
authorities
decline
to
enter
into
an
agreement
to
become
familiar
with
the
LQG's
facility
and
its
wastes,
and
to
prepare
and
maintain
a
contingency
plan.
EPA
estimates
LQGs
will
need
to
make
copies
of
and
send
the
plans
to
three
local
authorities,
on
average.
Amendments
to
contingency
plans
of
LQGs
must
also
be
made
when
appropriate.
EPA
estimates
that
3744
new
LQGs
will
prepare
original
contingency
plans
annually,
and
that1702
LQGs
will
amend
their
contingency
plan
annually,
during
the
period
covered
by
this
ICR.

Based
on
Emergency
Response
and
Notification
System
(
ERNS)
data,
the
Agency
estimates
that
about
1.7
percent
of
all
LQGs
will
have
emergency
incidents
requiring
implementation
of
the
contingency
plan.
7
Therefore,
approximately289
LQGs
will
be
required
to
prepare
emergency
reports
each
year.
LQGs
are
also
required
to
notify
the
Regional
Administrator
that
the
facility
is
in
compliance
with
section
265.56(
h)
before
resuming
operation
in
the
affected
areas.

(
4)
Tank
Systems
In
section
262.34(
a)(
1),
EPA
requires
all
LQGs
that
accumulate
hazardous
waste
in
tanks
for
90
days
or
less
to
comply
with
subpart
J
of
part
265.
Of
all
17,016
LQGs,
EPA
estimates
that
75
percent
use
containers
to
accumulate
hazardous
waste,
and
the
remaining
25
percent
use
tank
systems.
The
respondent
universe
for
LQGs
operating
tank
systems
is
4,254
LQGs.

Depending
on
how
the
tank
owner
desires
to
comply
with
the
regulations,
he
or
she
may
need
to
submit
one
or
more
of
the
following:
a
no­
free­
liquids
demonstration
(
§
265.190(
a)),
existing
tank
system
assessments
(
§
265.191),
an
equivalent
containment
exemption
(
§
265.193(
d)),
a
variance
from
secondary
containment
requirements
(
§
265.193(
g)),
or
annual
leak
tests
and
inspections
(
§
265.193(
i)).
Most
LQGs
seeking
to
operate
under
these
conditions
have
already
made
the
required
demonstrations.
In
general,
only
LQGs
recently
subjected
to
hazardous
waste
regulations
will
need
to
perform
these
demonstrations.
EPA
estimates
that
approximately
three
percent
or
128
respondents
are
subject
to
the
leak
tests
and
that
one
percent
or
43
LQGs
are
subject
to
the
other
demonstration
and
testing
requirements
in
sections
265.190
through
265.193.

In
addition,
in
certain
circumstances
(
e.
g.,
a
new
tank,
a
hazardous
waste
release,
or
a
repair
to
a
tank),
LQGs
must
submit
one
or
more
of
the
following:
new
tank
system
assessments
and
certifications
(
§
265.192);
an
exemption
from
the
24­
hour
leak
detection
requirement
(
§
265.193(
e)(
3)(
iii));
or
release
notifications
and
reports,
and
major
repair
certifications
(
§
265.196(
d)
and
(
f)).
As
these
are
ongoing
informational
requirements,
EPA
estimates
that:
74
!
Three
percent
or
128
LQGs
will
need
to
make
new
tank
system
assessments
and
certifications.
Of
that
number,
approximately
four
facilities
will
petition
for
an
exemption
from
the
24­
hour
leak
detection
requirement;
and
!
One
percent
or
43
LQGs
will
report
a
release
or
a
major
repair
certification.
In
addition,
approximately
four
facilities
will
need
compile
evidence
of
their
inability
to
comply
with
the
24­
hour
waste
removal
requirement.

(
5)
Drip
Pads
Under
section
262.34(
a)(
iii),
EPA
authorizes
LQGs
to
store
hazardous
waste
on
drip
pads
for
90
days
or
less
pursuant
to
part
265,
subpart
W.
Part
265,
subpart
W
is
primarily
applicable
to
those
facilities
conducting
wood
preserving
operations.
EPA
expects
that
most
existing
wood
preserving
sites
have
already
conducted
the
one­
time
activities
(
e.
g.,
contingency
planning,
integrity
assessments)
required
in
part
265.
New
entrants
to
the
wood
preserving
industry,
however,
would
be
subject
to
these
requirements.
Based
on
an
analysis
of
2001
BRS
data,
EPA
expects
that,
each
year,
10
new
sites
will
be
subject
to
these
one­
time
requirements.
EPA
further
expects
that
15
percent
of
facilities
(
2)
will
prepare
a
contingency
plan
for
incidental
drippage
and
will
have
a
condition
contributing
to
an
actual
release
of
hazardous
waste
and
be
subject
to
the
recordkeeping,
notification,
repair
and
certification
requirements.

(
6)
Containment
Buildings
Under
section
262.34(
a)(
iv),
EPA
authorizes
LQGs
to
store
hazardous
waste
in
containment
buildings
for
90
days
or
less
pursuant
to
part
265,
subpart
DD.
Part
265,
subpart
DD
is
potentially
applicable
to
all
large
quantity
hazardous
waste
generators.
EPA
estimates
that
approximately
10
percent
of
the
LQGs
(
1,702)
use
containment
buildings.
EPA
estimates
that
three
percent
of
these
facilities
(
51)
will
be
subject
to
the
recordkeeping
and
notice
requirements
associated
with
hazardous
waste
releases,
and
that
25
percent
of
these
facilities
(
425)
will
require
documentation
for
areas
lacking
secondary
containment.

(
7)
Requests
for
Extensions
of
the
Accumulation
Period
EPA
promulgated
regulations
in
section
262.34(
b)
allowing
LQGs
to
request
extensions
(
up
to
30
days)
of
the
accumulation
period
limit
from
the
Regional
Administrator
.
EPA
estimates
that
only
one
tenth
of
one
percent
of
all
LQGs,
approximately
17
LQGs,
will
request
this
extension
each
year.

LARGE
QUANTITY
GENERATOR
AIR
EMISSION
STANDARDS
(
Exhibit
4)

(
1)
Air
Emissions
from
Process
Vents
EPA
estimates
that
no
generators
will
be
subject
to
40
CFR
part
265,
subpart
AA,
in
light
of
the
applicability
requirements
of
section
265.1030(
b)(
1)­(
3).
75
(
2)
Air
Emissions
from
Equipment
Leaks
Based
on
an
analysis
of
the
2001
BRS,
EPA
estimates
that
4,764LQGs
are
subject
to
40
CFR
part
265,
subpart
BB.

(
a)
Notification
to
implement
the
alternate
valve
standard
specified
in
Section
265.1061(
a)

Based
on
previous
experience,
EPA
estimates
that
20
percent
of
generators
subject
to
subpart
BB
will
decide
to
implement
the
alternative
standard
specified
in
section
265.1061(
a)
each
year.
Therefore,
953
units
will
be
required
to
prepare
notification
to
implement
the
alternate
valve
standard
specified
in
section
265.1061(
a).

(
b)
Notification
to
discontinue
implementing
the
alternative
valve
standard
specified
in
Section
265.1061(
a)

Based
on
previous
experience,
EPA
estimates
that953
generators
subject
to
subpart
BB
have
implemented
the
alternative
standard
for
valves
specified
in
section
265.1061(
a),
and
one
percent
of
these
generators
will
discontinue
using
the
alternative
standard
each
year.
Therefore,
10
generators
will
be
required
to
prepare
notification
to
discontinue
implementing
the
alternate
valve
standard
specified
in
section
265.1061(
a).

(
c)
Notification
to
implement
the
alternative
valve
standard
specified
in
Section
265.1062(
b)(
2),
or
(
b)(
3).

Based
on
previous
experience,
EPA
estimates
that
five
percent
of
generators
subject
to
subpart
BB
will
decide
to
implement
the
alternative
standard
specified
in
section
265.1062(
b)(
2)
or
(
b)(
3)
each
year.
Therefore,
238
generators
will
be
required
to
prepare
notification
to
implement
the
alternate
valve
standard
specified
in
section
265.1062(
b)(
2)
or
(
b)(
3).

(
d)
Non­
Hazardous
Waste
Documentation
Based
on
previous
experience,
EPA
estimates
that
10
percent
of
generators
with
equipment
subject
to
subpart
BB
will
use
knowledge
to
determine
that
each
piece
of
equipment
does
or
does
not
contain
hazardous
waste
with
organic
concentration
that
equals
or
exceeds
10
percent
waste.
Therefore,
approximately
476
units
will
be
required
to
prepare
non­
hazardous
waste
documentation.

(
e)
Unit
Operating
Record
All
generators
subject
to
subpart
BB
are
required
to
maintain
a
unit
operating
record.
The
contents
of
the
operating
record
will
vary
according
to
site­
specific
circumstances.
A
discussion
of
the
respondent
burden
for
each
data
item
is
presented
below:

(
i)
Equipment
Record
76
This
ICR
assumes
that
generators
with
equipment
subject
to
subpart
BB
have
already
prepared
an
equipment
record.
EPA
estimates
that
all
generators
(
4,764
units)
will
reassess,
file,
and
maintain
their
equipment
record,
and
10
percent
(
approximately
476
units)
will
modify
it
annually.

(
ii)
Implementation
Schedule
This
ICR
assumes
that
generators
with
equipment
subject
to
subpart
BB
have
already
prepared
an
implementation
schedule.
EPA
estimates
that
all
generators
(
4,764
units)
will
reassess,
file,
and
maintain
their
implementation
schedule,
and
10
percent
(
approximately
476
units)
will
modify
it
annually.

(
iii)
Performance
Test
Plan
This
ICR
assumes
that
generators
using
test
data
to
demonstrate
the
organic
removal
efficiency
or
total
organic
compound
concentration
achieved
by
the
control
device
have
already
prepared
a
performance
test
plan.
EPA
estimates
that
all
generators
using
test
data
to
demonstrate
the
organic
removal
efficiency
or
total
organic
compound
concentration
achieved
by
the
control
device
(
approximately
4,764
units)
will
reassess,
file,
and
maintain
their
performance
test
plan,
and
10
percent
(
approximately
476
units)
will
modify
it
annually.

(
iv)
Documentation
of
Compliance
with
Section
264.1060
This
ICR
assumes
that
generators
subject
to
subpart
BB
have
already
prepared
a
documentation
of
compliance.
EPA
estimates
that
all
generators
(
4,764
units)
will
reassess,
file,
and
maintain
their
section
265.1060
compliance
documentation,
and
10
percent
(
approximately
476
units)
will
modify
it
annually.

(
v)
Leak
Inspection
Log
EPA
estimates
that
all
generators
subject
to
subpart
BB
(
4,764
units)
will
have
equipment
leaks
during
the
period
covered
by
this
ICR.
Therefore,
4,764
will
be
required
to
prepare
and
maintain
a
leak
inspection
log.
All
generators
will
be
required
to
reassess
and
modify
their
inspection
log.

(
vi)
Design,
Monitoring,
Operation,
and
Inspection
Information
This
ICR
assumes
that
generators
with
equipment
subject
to
subpart
BB
have
already
prepared
design,
monitoring,
and
inspection
information
for
each
closed­
vent
system
and
control
device.
EPA
estimates
that
all
generators
with
closed­
vent
systems
and
control
devices
(
approximately
4,764
units)
will
reassess,
file,
and
maintain
control
device
operation
documentation,
and
10
percent
(
approximately
476
units)
will
modify
it
annually.
77
(
vii)
Equipment
Log
This
ICR
assumes
that
generators
with
equipment
subject
to
subpart
BB
have
already
prepared
an
equipment
log.
EPA
estimates
that
all
generators
(
4,764
units)
will
reassess,
file,
and
maintain
their
equipment
log,
and
10
percent
(
approximately
476
units)
will
modify
it
annually.

(
viii)
Valve
Log
for
Valves
Subject
to
Section
265.1057(
g)
and
(
h)

This
ICR
assumes
that
generators
with
valves
subject
to
section
265.1057(
g)
and
(
h)
have
already
prepared
a
valve
log.
EPA
estimates
that
all
generators
with
valves
subject
to
section
265.1057(
g)
and
(
h)
(
approximately1,191
units)
will
reassess,
file,
and
maintain
their
valve
log,
and
10
percent
(
approximately
119
units)
will
modify
it
annually.

(
ix)
Valve
Log
for
Valves
Subject
to
Section
265.1062
This
ICR
assumes
that
generators
with
valves
subject
to
section
265.1062
have
already
prepared
a
valve
log.
EPA
estimates
that
all
generators
with
valves
subject
to
section
265.1062
(
approximately
238
units)
will
reassess,
file,
and
maintain
their
valve
log,
and
10
percent
(
approximately
24
units)
will
modify
it
annually.

(
x)
Criteria
Log
This
ICR
assumes
that
generators
subject
to
subpart
BB
have
already
prepared
a
criteria
log
documenting
information
required
in
sections
265.1052(
d)(
5)(
ii)
and
265.1053(
e)(
2)
for
pumps
in
light
liquid
service
and
compressors.
EPA
estimates
that
all
generators
with
equipment
subject
to
sections
265.1052(
d)(
5)(
ii)
and
265.1053(
e)(
2)
(
4,764
units)
will
reassess,
file,
and
maintain
their
criteria
log,
and
10
percent
(
approximately
476
units)
will
modify
it
annually.

(
xi)
Exemption
Log
This
ICR
assumes
that
generators
potentially
subject
to
subpart
BB
have
already
documented
information
determining
applicability
of
subpart
BB
to
their
unit's
equipment.
EPA
estimates
that
all
generators
(
4,764
units)
will
reassess,
file,
and
maintain
this
documentation,
and
10
percent
(
approximately
476
units)
will
modify
it
annually.

SMALL
QUANTITY
GENERATOR
PRE­
TRANSPORT
REQUIREMENTS
(
Exhibit
5)

(
1)
Labeling
This
ICR
assumes
that
all
SQGs
will
need
to
label
their
containers
and
tanks
in
compliance
with
the
section
262.34(
a)(
2)
and
(
3)
and
section
262.34(
c)
requirements.

(
2)
Emergency
Procedures
78
EPA
promulgated
regulations
in
section
262.34
requiring
SQGs
to
immediately
notify
the
local
fire
department
and/
or
National
Response
Center,
as
specified,
for
emergencies.
Based
on
recent
ERNS
data,
EPA
estimates
that
1.7
percent
of
all
SQGs
(
1,825)
will
report
such
an
event
each
year.

(
3)
Requests
for
Extensions
of
the
Accumulation
Period
EPA
promulgated
regulations
in
section
262.34(
f)
allowing
SQGs
to
request
from
the
Regional
Administrator
extensions
(
up
to
30
days)
of
the
accumulation
period
limit.
EPA
estimates
that
one
tenth
of
one
percent
of
all
respondents,
approximately
107
SQGs,
will
request
an
extension
each
year.

RECORDKEEPING
AND
REPORTING
REQUIREMENTS
(
Exhibit
6)

All
generators
(
both
LQGs
and
SQGs)
must
comply
with
the
recordkeeping
and
reporting
requirements
detailed
in
sections
262.40
and
.43.
This
ICR
does
not
burden
generators
for
their
hazardous
waste
determinations,
since
they
are
already
burdened
for
recordkeeping
of
test
results
in
the
LDR
ICR,
Number
1442.17.
(
Refer
to
the
"
Hazardous
Waste
Determination
Requirements"
in
this
section
for
further
discussion
on
EPA's
assumptions.)
EPA
estimates
that
one
tenth
of
one
percent
of
all
generators,
approximately
128,
will
also
be
required
to
submit
certain
additional
information
(
§
262.43).
Based
on
the
ratio
of
LQGs
to
SQGs,
EPA
estimates
that
approximately
17
are
LQGs
and
107
are
SQGs.

EXPORT
AND
IMPORT
REQUIREMENTS
(
Exhibit
7
and
8)

Based
on
export
notifications
tracked
by
EPA's
Office
of
Enforcement
and
Compliance
Assurance
(
OECA),
EPA
estimates
that
approximately
770
generators
will
export
hazardous
waste
each
year
under
40
CFR
262.53,
and
.55
­
.57,
and
will
be
required
to
notify
EPA
of
their
intention
to
export
hazardous
waste,
file
an
Annual
Report
with
the
Administrator
summarizing
the
types,
quantities,
frequencies,
and
ultimate
destination
of
all
hazardous
wastes
exported
during
the
previous
years,
and
keep
copies
of
relevant
documents
for
a
period
of
three
years.
Because
SQGs
are
not
required
to
submit
waste
volume
and
toxicity
reduction
information
in
their
Annual
Reports,
EPA
accordingly
differentiated
LQG
and
SQG
Annual
Report
burden
hour
estimates
in
Exhibit
7.
EPA
estimates
that
95
percent,
or
731
of
the
770
exporters,
will
be
LQGs
and
five
percent,
or
39
of
the
770
exporters,
will
be
SQGs.
79
EXHIBIT
2:

ANNUAL
RESPONDENT
BURDEN/
COST
ESTIMATES
READING
THE
REGULATIONS
O&
M
Costs/
Respondent
Cost
per
Number
of
Hours
per
Respondent
Postage/
Photocopies
Other
Total
Hours
Respondent/
Total
Cost
Respondent
s
Legal
Managerial
Technical
Clerical
Shipping
per
Year
Shipment
per
Year
@

$
119.91/
hr
@
$
85.82/
hr
@

$
62.30/
hr
@
$
31.74/
hr
@
$
0.37/
doc
@

$
0.10/
page
Read
the
Regulations:

LQGs
17,016
0.25
0.25
0.50
0.00
$
0.00
$
0.00
$
0.00
17,016
$
82.58
$
1,405,237
SQGs
107,366
0.15
0.15
0.40
0.00
$
0.00
$
0.00
$
0.00
75,156
$
55.78
$
5,988,830
TOTAL
N/
A
N/
A
N/
A
N/
A
0.00
$
0.00
$
0.00
$
0.00
92,172
varies
$
7,394,067
80
EXHIBIT
3:

ANNUAL
RESPONDENT
BURDEN/
COST
ESTIMATES
FOR
LARGE
QUANTITY
GENERATORS
O&
M
Costs/
Respondent
Cost
per
Numbe
r
of
Hours
per
Respondent
Postage/
Photocopie
s
Other
Total
Hours
Responden
t/
Total
Cost
Respon
dents
Legal
Mana
gerial
Techni
cal
Clerical
Shipping
per
Year
Shipment
per
Year
@

$
119.91
/
hr
@

$
85.82
/
hr
@

$
62.30
/
hr
@

$
31.74/

hr
@

$
1.29/
do
c
@

$
0.10/
page
Hazardous
Waste
Determination
Requirements
(
LQGs
and
SQGs):

Test
the
Waste
0
0.00
0.00
20.00
0.00
$
1.29
$
1.00
$
1,959.09
0
$
3,207.38
$
0
Use
Knowledge
of
the
Waste
0
0.00
0.00
0.00
0.00
$
0.00
$
0.00
$
0.00
0
$
0.00
$
0
Subtotal
0
0.00
0.00
20.00
0.00
$
0.00
$
0.00
$
0.00
0
$
3,207.38
$
0
Large
Quantity
Generator
Pre­
Transport
Requirements
Labeling
Label
containers
in
90­
day
accumulation
(
262.34(
a)(
2)
and
(
3))
17,016
0.00
0.00
1.00
0.00
$
0.00
$
0.00
$
0.00
17,016
$
62.30
$
1,060,09
7
Label
the
containers
in
satellite
accumulation(
262.34(
c))
17,016
0.00
0.00
0.50
0.00
$
0.00
$
0.00
$
0.00
8,508
$
31.15
$
530,048
Subtotal
17,045
0.00
varies
1.50
varies
$
0.00
$
0.00
$
0.00
25,524
varies
$
1,590,14
5
Personnel
Training
(
265.16(
d))

Collect
job­
related
data
3,744
0.00
0.00
0.00
0.50
$
0.00
$
0.00
$
0.00
1,872
$
15.87
$
59,410
81
O&
M
Costs/
Respondent
Cost
per
Numbe
r
of
Hours
per
Respondent
Postage/
Photocopie
s
Other
Total
Hours
Responden
t/
Total
Cost
Respon
dents
Legal
Mana
gerial
Techni
cal
Clerical
Shipping
per
Year
Shipment
per
Year
@

$
119.91
/
hr
@

$
85.82
/
hr
@

$
62.30
/
hr
@

$
31.74/

hr
@

$
1.29/
do
c
@

$
0.10/
page
Maintain
information
at
facility
3,744
0.00
0.00
0.00
0.10
$
0.00
$
0.00
$
0.00
374
$
3.17
$
11,882
Subtotal
3,750
0.00
0.00
0.00
0.60
$
0.00
$
0.00
$
0.00
2,246
varies
$
71,292
Contingency
Planning
and
Emergency
Procedures
Requirements
Contingency
Plan
(
265.37(
b),
265.51,
265.52,

and
265.53(
a))

Collect
data
required
in
contingency
plan
3,744
0.00
0.00
2.00
1.00
$
0.00
$
0.00
$
0.00
11,231
$
156.34
$
585,268
Document
whether
authorities
decline
arrangement
3,744
0.00
0.00
0.00
0.10
$
0.00
$
0.00
$
0.00
374
$
3.17
$
11,882
Write
contingency
plan
3,744
0.00
0.00
6.00
2.00
$
0.00
$
0.00
$
0.00
29,948
$
437.28
$
1,636,98
2
Maintain
contingency
plan
3,744
0.00
0.00
0.00
0.10
$
0.00
$
0.00
$
0.00
374
$
3.17
$
11,882
Submit
contingency
plan
to
relevant
emergency
centers
3,744
0.00
0.00
0.00
0.16
$
1.29
$
3.00
$
0.30
599
$
9.67
$
36,194
Amend
contingency
plan
when
appropriate
1,702
0.00
0.00
1.00
1.00
$
0.00
$
0.10
$
0.00
3,403
$
94.14
$
160,190
Emergency
Procedures
(
265.56(
d))

Collect
information
required
in
emergency
report
289
0.00
0.00
1.00
1.00
$
0.00
$
0.00
$
0.00
579
$
94.04
$
27,203
Write
emergency
report
289
0.17
0.00
1.00
0.00
$
0.00
$
0.00
$
0.00
338
$
82.68
$
23,919
Call
OSC
or
notify
NRC;
notify
local
authorities
if
advisable
289
0.00
0.10
0.90
0.00
$
0.00
$
0.00
$
10.00
289
$
74.65
$
21,595
Notification
of
Compliance
(
265.56(
i)
and
(
j))

Collect
information
required
in
emergency
289
0.00
0.00
0.50
0.50
$
0.00
$
0.00
$
0.00
289
$
47.02
$
13,602
82
O&
M
Costs/
Respondent
Cost
per
Numbe
r
of
Hours
per
Respondent
Postage/
Photocopie
s
Other
Total
Hours
Responden
t/
Total
Cost
Respon
dents
Legal
Mana
gerial
Techni
cal
Clerical
Shipping
per
Year
Shipment
per
Year
@

$
119.91
/
hr
@

$
85.82
/
hr
@

$
62.30
/
hr
@

$
31.74/

hr
@

$
1.29/
do
c
@

$
0.10/
page
notification
report
Write
emergency
notification
report
289
0.17
0.00
0.50
0.50
$
0.00
$
0.00
$
0.00
338
$
67.40
$
19,498
Submit
report
to
Regional
Administrator
289
0.00
0.00
0.00
0.16
$
1.29
$
0.50
$
0.05
46
$
6.92
$
2,001
Compile
information
demonstrating
compliance
289
0.00
0.00
0.50
0.00
$
0.00
$
0.00
$
0.00
145
$
31.15
$
9,011
Prepare
letter
notifying
Regional
Administrator
of
compliance
289
0.16
0.00
0.25
0.00
$
0.00
$
0.00
$
0.00
119
$
34.76
$
10,055
Submit
notification
289
0.00
0.00
0.00
0.16
$
1.29
$
0.50
$
0.05
46
$
6.92
$
2,001
Subtotal
varies
0.00
varies
varies
varies
$
5,575.5
2
$
11,690.11
$
4,044.74
48,120
varies
$
2,571,28
4
Tank
System
Requirements
Free
Liquids
Absence
Demonstration
(
265.190(
a))

Perform
test
as
required
43
0.00
0.00
0.50
0.00
$
0.00
$
0.00
$
0.00
22
$
31.15
$
1,339
Place
test
results
in
record
43
0.00
0.00
0.00
0.10
$
0.00
$
0.00
$
0.00
4
$
3.17
$
136
Sufficiency
Demonstration
(
265.191)

Perform
leak
test
43
0.00
0.00
10.00
0.00
$
0.00
$
0.00
$
0.00
430
$
623.00
$
26,789
Obtain
independent
engineer's
assessment
of
tank
integrity
43
0.00
0.00
6.00
2.00
$
0.00
$
0.00
$
0.00
344
$
437.28
$
18,803
File
assessment
at
facility
43
0.00
0.00
0.00
0.10
$
0.00
$
0.00
$
0.00
4
$
3.17
$
136
Tank
System
Assessments
(
265.192)

Obtain
written
assessment
and
have
it
reviewed
&
certified
128
0.00
1.00
13.00
1.00
$
0.00
$
0.00
$
0.00
1,920
$
927.46
$
118,715
83
O&
M
Costs/
Respondent
Cost
per
Numbe
r
of
Hours
per
Respondent
Postage/
Photocopie
s
Other
Total
Hours
Responden
t/
Total
Cost
Respon
dents
Legal
Mana
gerial
Techni
cal
Clerical
Shipping
per
Year
Shipment
per
Year
@

$
119.91
/
hr
@

$
85.82
/
hr
@

$
62.30
/
hr
@

$
31.74/

hr
@

$
1.29/
do
c
@

$
0.10/
page
Obtain
written
statements
from
those
who
certified
design
of
tank
system
and
supervised
installation
128
0.00
1.00
7.00
4.00
$
0.00
$
0.00
$
0.00
1,536
$
648.88
$
83,057
File
written
statements
at
facility
128
0.00
0.00
0.00
0.10
$
0.00
$
0.00
$
0.00
13
$
3.17
$
406
Secondary
Containment
(
265.193)

Equivalent
Containment
Devices
(
265.193(
d))

Gather
design
and
other
information
43
0.00
0.00
2.00
2.00
$
0.00
$
0.00
$
0.00
172
$
188.08
$
8,087
Submit
information
to
Regional
Administrator
43
0.00
0.10
0.00
0.16
$
1.29
$
0.50
$
0.05
11
$
15.50
$
667
Exemption
from
24­
Hour
Leak
Detection
Requirement
(
265.193(
e)(
3)(
iii))

Compile
evidence
that
leak
detection
system
cannot
detect
failure
or
contamination
within
24
hours
4
0.00
0.00
4.00
0.00
$
0.00
$
0.00
$
0.00
16
$
249.20
$
997
Submit
evidence
to
Regional
Administrator
4
0.00
0.10
0.00
0.16
$
1.29
$
0.50
$
0.05
1
$
15.50
$
62
Variance
from
Secondary
Containment
Requirements
(
265.193(
g))

Prepare
notification
of
intent
to
conduct
demonstration
4
0.00
0.00
1.00
0.00
$
0.00
$
0.00
$
0.00
4
$
62.30
$
249
Submit
notification
to
Regional
Administrator
4
0.00
0.00
0.00
0.16
$
1.29
$
0.50
$
0.05
1
$
6.92
$
28
Complete
demonstration
4
0.00
1.00
9.00
2.00
$
0.00
$
0.00
$
0.00
48
$
710.00
$
2,840
Submit
completed
demonstration
to
Regional
4
0.00
0.10
0.00
0.16
$
1.29
$
0.50
$
0.05
1
$
15.50
$
62
84
O&
M
Costs/
Respondent
Cost
per
Numbe
r
of
Hours
per
Respondent
Postage/
Photocopie
s
Other
Total
Hours
Responden
t/
Total
Cost
Respon
dents
Legal
Mana
gerial
Techni
cal
Clerical
Shipping
per
Year
Shipment
per
Year
@

$
119.91
/
hr
@

$
85.82
/
hr
@

$
62.30
/
hr
@

$
31.74/

hr
@

$
1.29/
do
c
@

$
0.10/
page
Administrator
Annual
Leak
Tests
and
Inspections
(
265.193(
i))

Conduct
leak
test
(
non­
enterable
underground
tanks
only)
128
0.00
0.00
12.00
0.00
$
0.00
$
0.00
$
0.00
1,536
$
747.60
$
95,693
Conduct
annual
leak
test
(
all
other
tanks)
128
0.00
0.00
16.00
0.00
$
0.00
$
0.00
$
0.00
2,048
$
996.80
$
127,590
Record
inspection
and/
or
test
results
128
0.00
0.00
2.00
0.00
$
0.00
$
0.00
$
0.00
256
$
124.60
$
15,949
Maintain
record
of
results
on
file
at
facility
128
0.00
0.00
0.00
0.10
$
0.00
$
0.00
$
0.00
13
$
3.17
$
406
Exemptions
from
24­
Hour
Waste
Removal
Requirement
(
265.196(
b))

Compile
evidence
of
inability
to
remove
waste
timely
4
0.00
0.00
2.00
1.00
$
0.00
$
0.00
$
0.00
12
$
156.34
$
625
Submit
evidence
to
Regional
Administrator
4
0.00
0.10
0.00
0.16
$
1.29
$
0.50
$
0.05
1
$
15.50
$
62
Release
Notifications
and
Reports
(
265.196(
d))

Notify
Regional
Administrator
of
release
43
0.00
0.10
0.40
0.00
$
0.00
$
0.00
$
5.00
22
$
38.50
$
1,656
Prepare
detailed
report
for
Regional
Administrator
43
0.17
0.10
3.00
1.90
$
0.00
$
0.00
$
0.00
222
$
276.17
$
11,875
Submit
report
to
Regional
Administrator
43
0.00
0.10
0.00
0.16
$
1.29
$
0.50
$
0.05
11
$
15.50
$
667
Major
Repair
Certifications
(
265.196(
f))

Obtain
certification
43
0.00
0.00
4.00
4.00
$
0.00
$
0.00
$
0.00
344
$
376.16
$
16,175
Submit
certification
to
Regional
Administrator
43
0.00
0.00
0.00
0.16
$
1.29
$
0.50
$
0.05
7
$
6.92
$
297
Subtotal
varies
0.00
varies
varies
varies
$
187.05
$
72.50
$
222.25
8,999
varies
$
533,369
Drip
Pad
Requirements
(
262.34(
a)(
1)(
iii))
85
O&
M
Costs/
Respondent
Cost
per
Numbe
r
of
Hours
per
Respondent
Postage/
Photocopie
s
Other
Total
Hours
Responden
t/
Total
Cost
Respon
dents
Legal
Mana
gerial
Techni
cal
Clerical
Shipping
per
Year
Shipment
per
Year
@

$
119.91
/
hr
@

$
85.82
/
hr
@

$
62.30
/
hr
@

$
31.74/

hr
@

$
1.29/
do
c
@

$
0.10/
page
Contingency
Plan
(
265.440(
c)(
1))

Write
contingency
plan
2
0.00
0.00
2.00
0.00
$
0.00
$
0.00
$
0.00
3
$
124.60
$
212
Document
clean­
up
of
incidental
drippage
2
0.00
0.00
0.25
0.25
$
0.00
$
0.00
$
0.00
1
$
23.51
$
40
Retain
documentation
for
3
years
2
0.00
0.00
0.00
0.10
$
0.00
$
0.00
$
0.00
0
$
3.17
$
5
Assess
adequacy
of
drip
pads
(
265.441(
a)(
b)(
c))

Prepare
and
maintain
assessment
of
pad
integrity
0
0.00
0.00
2.00
1.00
$
0.00
$
0.00
$
0.00
0
$
156.34
$
0
Prepare
plan
for
upgrading
pad
0
0.00
0.10
5.00
1.00
$
0.00
$
0.00
$
0.00
0
$
351.82
$
0
Prepare
drawings
of
pad
and
obtain
independent
certification
0
0.00
0.20
6.50
0.30
$
0.00
$
0.50
$
0.05
0
$
432.19
$
0
Design
and
Operating
Requirements
(
265.443)

Prepare
an
assessment
of
drip
pad
and
obtain
certification
10
0.00
0.25
4.00
0.25
$
0.00
$
0.00
$
0.00
46
$
278.59
$
2,844
Place
a
record
of
any
condition
contributing
to
or
actual
release
of
hazardous
waste
from
drip
pad
in
operating
log
2
0.00
0.00
0.25
0.00
$
0.00
$
0.00
$
0.00
0
$
15.58
$
27
Notify
Regional
Administrator
of
release
&

provide
written
notice
2
0.17
0.10
0.40
0.00
$
1.29
$
0.50
$
2.00
1
$
57.68
$
98
Notify
Regional
Adminstrator
of
completion
of
repairs
2
0.00
0.10
0.40
0.00
$
1.29
$
0.20
$
0.00
1
$
34.99
$
60
Provide
Regional
Administrator
independent
certification
86
O&
M
Costs/
Respondent
Cost
per
Numbe
r
of
Hours
per
Respondent
Postage/
Photocopie
s
Other
Total
Hours
Responden
t/
Total
Cost
Respon
dents
Legal
Mana
gerial
Techni
cal
Clerical
Shipping
per
Year
Shipment
per
Year
@

$
119.91
/
hr
@

$
85.82
/
hr
@

$
62.30
/
hr
@

$
31.74/

hr
@

$
1.29/
do
c
@

$
0.10/
page
that
repairs
satisfy
applicable
standards
2
0.00
0.10
1.00
0.10
$
1.29
$
0.50
$
0.05
2
$
75.90
$
129
Prepare
documentation
of
operating/
waste
handling
practices
10
0.00
0.00
2.00
0.00
$
0.00
$
0.50
$
0.05
20
$
125.15
$
1,278
Certification
of
liner
(
265.444(
a))

Obtain
independent
certification
of
liner
10
0.00
0.00
2.00
0.10
$
0.00
$
0.00
$
0.00
21
$
127.77
$
1,305
Place
certification
in
operating
log
10
0.00
0.00
0.00
0.10
$
0.00
$
0.00
$
0.00
1
$
3.17
$
32
Documentation
of
waste
removal
(
262.34(
a)(
1)(
iii))

Prepare
description
of
90­
day
waste
removal
practices
10
0.00
0.00
0.25
0.00
$
0.00
$
0.00
$
0.00
3
$
15.58
$
159
Document
each
waste
removal
10
0.00
0.00
0.25
0.00
$
0.00
$
0.00
$
0.00
3
$
15.58
$
159
Subtotal
varies
0.00
varies
varies
varies
$
6.59
$
7.15
$
4.00
103
varies
$
6,348
Containment
Building
Requirements
(
262.34(
a)(
1)(
iv))

Design
and
Performance
Documentation
(
265.1101(
c)(
d))

Obtain
independent
certification
of
building
design
1,702
0.00
0.00
2.00
0.10
$
0.00
$
0.00
$
0.00
3,573
$
127.77
$
217,420
Place
certification
in
operating
record
1,702
0.00
0.00
0.00
0.10
$
0.00
$
0.00
$
0.00
170
$
3.17
$
5,401
Maintain
records
of
any
release
from
containment
building
51
0.00
0.00
0.25
0.10
$
0.00
$
0.00
$
0.00
18
$
18.75
$
957
Notify
Regional
administrator
of
any
condition
contributing
to
87
O&
M
Costs/
Respondent
Cost
per
Numbe
r
of
Hours
per
Respondent
Postage/
Photocopie
s
Other
Total
Hours
Responden
t/
Total
Cost
Respon
dents
Legal
Mana
gerial
Techni
cal
Clerical
Shipping
per
Year
Shipment
per
Year
@

$
119.91
/
hr
@

$
85.82
/
hr
@

$
62.30
/
hr
@

$
31.74/

hr
@

$
1.29/
do
c
@

$
0.10/
page
or
actual
release
of
hazardous
waste
and
follow­
up
notice
51
0.00
0.00
2.00
0.00
$
0.00
$
0.00
$
0.00
102
$
124.60
$
6,361
Notify
Regional
Administrator
of
clean­
up
or
repairs
51
0.17
0.10
0.40
0.10
$
0.00
$
0.00
$
0.00
39
$
57.06
$
2,913
Record
monitoring
and
leak
detection
data
and
place
in
operating
record
at
least
every
7
days
1,702
0.00
0.00
0.00
10.00
$
0.00
$
0.00
$
0.00
17,016
$
317.40
$
540,088
Documentation
of
Areas
Lacking
Secondary
Containment
(
265.1101(
d)

Place
in
operating
log
description
of
procedures
to
maintain
integrity
of
areas
lacking
secondary
containment
425
0.00
0.00
2.00
0.10
$
0.00
$
0.00
$
0.00
893
$
127.77
$
54,355
Documentation
of
Procedures
and
Compliance
(
262.34(
a)(
1)(
iv))

Prepare
procedures
ensuring
waste
is
stored
no
more
than
90
days
1,702
0.00
0.00
1.00
0.10
$
0.00
$
0.00
$
0.00
1,872
$
65.47
$
111,411
Prepare
description
of
waste
generation
and
waste
management
practices
1,702
0.00
0.00
1.50
0.10
$
0.00
$
0.00
$
0.00
2,723
$
96.62
$
164,415
Document
that
90­
day
storage
procedures
are
satisfied
1,702
0.00
0.00
0.25
0.00
$
0.00
$
0.00
$
0.00
425
$
15.58
$
26,502
88
O&
M
Costs/
Respondent
Cost
per
Numbe
r
of
Hours
per
Respondent
Postage/
Photocopie
s
Other
Total
Hours
Responden
t/
Total
Cost
Respon
dents
Legal
Mana
gerial
Techni
cal
Clerical
Shipping
per
Year
Shipment
per
Year
@

$
119.91
/
hr
@

$
85.82
/
hr
@

$
62.30
/
hr
@

$
31.74/

hr
@

$
1.29/
do
c
@

$
0.10/
page
Document
that
unit
is
emptied
at
least
once
every
90
days
1,702
0.00
0.00
1.00
0.40
$
0.00
$
0.00
$
0.00
2,382
$
75.00
$
127,613
Subtotal
varies
0.00
varies
varies
varies
$
0.00
$
0.00
$
0.00
29,214
1,029
$
1,257,43
6
Requests
for
Extensions
of
Accumulation
Period
(
262.34(
b))

Prepare
and
submit
request
to
Regional
Administrator
17
0.10
0.10
0.00
0.40
$
1.29
$
0.00
$
0.00
10
$
34.56
$
588
Subtotal
17
0.10
0.10
0.00
0.40
$
21.95
$
0.00
$
0.00
10
$
55.22
$
588
Subtotal
for
LQG
Pre­
Transport
Requirements
varies
0.00
varies
varies
varies
$
5,791.1
0
$
11,769.75
$
4,270.99
114,216
varies
$
6,030,46
3
89
EXHIBIT
4:

ANNUAL
RESPONDENT
BURDEN/
COST
ESTIMATES
FOR
LARGE
QUANTITY
GENERATORS
O&
M
Costs/
Respondent
Cost
per
Number
of
Hours
per
Respondent
Postage
/
Photoco
pies
Other
Total
Hours
Responde
nt/
Total
Cost
Responde
nts
Legal
Manag
erial
Technic
al
Clerical
Shippin
g
per
Year
Shipment
per
Year
@

$
119.91
/
hr
@

$
85.82/

hr
@

$
62.30/

hr
@

$
31.74/
h
r
@

$
1.29/
d
oc
@

$
0.10/
pa
ge
Large
Quantity
Generator
Air
Emission
Standards
Requirements
Process
Vents
Control
Device
Operation
Documentation
Reassess
and
file
documentation
0
0.00
0.00
1.50
0.50
$
0.00
$
0.00
$
0.00
0
$
109.32
$
0
Modify
documentation
0
0.00
0.00
4.00
0.00
$
0.00
$
0.00
$
0.00
0
$
249.20
$
0
Maintain
documentation
at
the
facility
(
265.1035)(
e)(
2)
0
0.00
0.00
0.00
0.10
$
0.00
$
0.00
$
0.00
0
$
3.17
$
0
Waste
Determination
Gather
information
(
initially
and
annually
thereafter)
0
0.00
8.00
16.00
8.00
$
0.00
$
0.00
$
0.00
0
$
1,937.28
$
0
Document
information
(
initially
and
annually
thereafter)
0
0.00
0.00
0.00
2.00
$
0.00
$
0.00
$
0.00
0
$
63.48
$
0
Maintain
documentation
at
the
facility
(
initially
and
annually
thereafter)
0
0.00
0.00
0.00
0.40
$
0.00
$
0.00
$
0.00
0
$
12.70
$
0
Facility
operating
record:
Implementation
schedule
90
Number
of
Hours
per
Respondent
Postage
/
Photoco
pies
Other
Total
Hours
Responde
nt/
Total
Cost
Responde
nts
Legal
Manag
erial
Technic
al
Clerical
Shippin
g
per
Year
Shipment
per
Year
@

$
119.91
/
hr
@

$
85.82/

hr
@

$
62.30/

hr
@

$
31.74/
h
r
@

$
1.29/
d
oc
@

$
0.10/
pa
ge
Reassess
implementation
schedule
0
0.00
0.00
2.00
0.00
$
0.00
$
0.00
$
0.00
0
$
124.60
$
0
File
and
maintain
implementation
schedule
0
0.00
0.00
0.00
0.10
$
0.00
$
0.00
$
0.00
0
$
3.17
$
0
Modify
implementation
schedule
0
0.00
0.00
4.00
0.00
$
0.00
$
0.00
$
0.00
0
$
249.20
$
0
Facility
operating
record:
Up­
to­
date
documentation
of
compliance
(
265.1032)

Reassess
up­
to­
date
documentation
of
compliance
0
0.00
0.00
2.00
0.00
$
0.00
$
0.00
$
0.00
0
$
124.60
$
0
File
and
maintain
up­
to­
date
documentation
of
compliance
0
0.00
0.00
0.00
0.10
$
0.00
$
0.00
$
0.00
0
$
3.17
$
0
Modify
up­
to­
date
documentation
of
compliance
0
0.00
0.00
4.00
0.00
$
0.00
$
0.00
$
0.00
0
$
249.20
$
0
Facility
operating
record:
Performance
Test
Plan
Reassess
performance
test
plan
0
0.00
0.00
2.00
0.00
$
0.00
$
0.00
$
0.00
0
$
124.60
$
0
File
and
maintain
performance
test
plan
0
0.00
0.00
0.00
0.10
$
0.00
$
0.00
$
0.00
0
$
3.17
$
0
Modify
performance
test
plan
0
0.00
0.00
4.00
0.00
$
0.00
$
0.00
$
0.00
0
$
249.20
$
0
Facility
operating
record:
Documentation
of
compliance
(
265.1033)

Reasses
up­
to­
date
documentation
0
0.00
0.00
2.00
0.00
$
0.00
$
0.00
$
0.00
0
$
124.60
$
0
File
and
maintain
up­
to­
date
documentation
0
0.00
0.00
0.00
0.10
$
0.00
$
0.00
$
0.00
0
$
3.17
$
0
Modify
up­
to­
date
documentation
0
0.00
0.00
4.00
0.00
$
0.00
$
0.00
$
0.00
0
$
249.20
$
0
Facility
operating
record:

Design/
monitoring/
operation/
inspection
information
Reassess
information
0
0.00
0.00
2.00
0.00
$
0.00
$
0.00
$
0.00
0
$
124.60
$
0
File
and
maintain
information
0
0.00
0.00
0.00
0.10
$
0.00
$
0.00
$
0.00
0
$
3.17
$
0
Modify
information
0
0.00
0.00
4.00
0.00
$
0.00
$
0.00
$
0.00
0
$
249.20
$
0
91
Number
of
Hours
per
Respondent
Postage
/
Photoco
pies
Other
Total
Hours
Responde
nt/
Total
Cost
Responde
nts
Legal
Manag
erial
Technic
al
Clerical
Shippin
g
per
Year
Shipment
per
Year
@

$
119.91
/
hr
@

$
85.82/

hr
@

$
62.30/

hr
@

$
31.74/
h
r
@

$
1.29/
d
oc
@

$
0.10/
pa
ge
Facility
operating
record:
Determination
of
applicability
to
Subpart
AA
Reassess
determination
0
0.00
0.00
2.00
0.00
$
0.00
$
0.00
$
0.00
0
$
124.60
$
0
File
and
maintain
determination
0
0.00
0.00
0.00
0.10
$
0.00
$
0.00
$
0.00
0
$
3.17
$
0
Modify
determination
0
0.00
0.00
4.00
0.00
$
0.00
$
0.00
$
0.00
0
$
249.20
$
0
Subtotal
0
0.00
varies
varies
varies
$
0.00
$
0.00
$
0.00
0
varies
$
0
Equipment
Leaks
Notification
to
implement
the
alternative
valve
standard
in
(
265.1061)(
a)

Prepare
notification
953
0.00
0.25
1.00
0.25
$
0.00
$
0.00
$
0.00
1,429
$
91.69
$
87,371
Submit
notification
to
the
Region
953
0.00
0.00
0.00
0.16
$
1.29
$
0.00
$
0.00
152
$
6.37
$
6,068
Notification
to
discontinue
alternative
valve
standard
in
(
265.1061)(
a)

Prepare
notification
10
0.00
0.25
1.00
0.25
$
0.00
$
0.00
$
0.00
15
$
91.69
$
936
Submit
notification
to
the
Region
10
0.00
0.00
0.00
0.16
$
1.29
$
0.00
$
0.00
2
$
6.37
$
65
Notification
to
implement
alternative
valve
standard
(
265.1061)(
b)(
2)
and
(
265.1062)(
b)(
3)

Prepare
notification
238
0.00
0.25
1.00
0.25
$
0.00
$
0.00
$
0.00
357
$
91.69
$
21,843
Submit
notification
to
the
Region
238
0.00
0.00
0.00
0.16
$
1.29
$
0.00
$
0.00
38
$
6.37
$
1,517
Non­
hazardous
waste
documentation
Gather
production
process,
waste
generation,
and
specification
analysis
(
4
times
annually)
476
0.00
0.00
10.00
0.00
$
0.00
$
0.00
$
0.00
4,764
$
623.00
$
296,82
7
92
Number
of
Hours
per
Respondent
Postage
/
Photoco
pies
Other
Total
Hours
Responde
nt/
Total
Cost
Responde
nts
Legal
Manag
erial
Technic
al
Clerical
Shippin
g
per
Year
Shipment
per
Year
@

$
119.91
/
hr
@

$
85.82/

hr
@

$
62.30/

hr
@

$
31.74/
h
r
@

$
1.29/
d
oc
@

$
0.10/
pa
ge
Document
production
process,
waste
generation
and
$
0.00
specification
analysis
(
4
times
annually)
476
0.00
0.00
16.00
0.00
$
0.00
$
0.00
$
0.00
7,623
$
996.80
$
474,92
3
Maintain
documentation
at
the
facility
(
4
times
annually)
476
0.00
0.00
0.00
2.00
$
0.00
$
0.00
$
0.00
953
$
63.48
$
30,245
Facility
Operating
Record
(
265.1064)(
b):
Equipment
record
Reassess
equipment
record
4,764
0.00
0.00
2.00
0.00
$
0.00
$
0.00
$
0.00
9,529
$
124.60
$
593,65
4
File
and
maintain
equipment
record
4,764
0.00
0.00
0.00
0.10
$
0.00
$
0.00
$
0.00
476
$
3.17
$
15,122
Modify
equipment
record
476
0.00
0.00
4.00
0.00
$
0.00
$
0.00
$
0.00
1,906
$
249.20
$
118,73
1
Facility
Operating
Record:
Implementation
schedule
Reassess
implementation
schedule
4,764
0.00
0.00
1.00
0.00
$
0.00
$
0.00
$
0.00
4,764
$
62.30
$
296,82
7
File
and
maintain
schedule
4,764
0.00
0.00
0.00
0.10
$
0.00
$
0.00
$
0.00
476
$
3.17
$
15,122
Modify
implementation
schedule
476
0.00
0.00
4.00
0.00
$
0.00
$
0.00
$
0.00
1,906
$
249.20
$
118,73
1
Facility
Operating
Record:
Performance
Test
Plan
Reassess
performance
test
plan
4,764
0.00
0.00
4.00
0.00
$
0.00
$
0.00
$
0.00
19,058
$
249.20
$
1,187,3
08
File
and
maintain
plan
4,764
0.00
0.00
0.00
0.10
$
0.00
$
0.00
$
0.00
476
$
3.17
$
15,122
Modify
performance
test
plan
476
0.00
0.00
4.00
0.00
$
0.00
$
0.00
$
0.00
1,906
$
249.20
$
118,73
1
93
Number
of
Hours
per
Respondent
Postage
/
Photoco
pies
Other
Total
Hours
Responde
nt/
Total
Cost
Responde
nts
Legal
Manag
erial
Technic
al
Clerical
Shippin
g
per
Year
Shipment
per
Year
@

$
119.91
/
hr
@

$
85.82/

hr
@

$
62.30/

hr
@

$
31.74/
h
r
@

$
1.29/
d
oc
@

$
0.10/
pa
ge
Facility
Operating
Record:
Documentation
of
compliance
with
(
265.1060)

Reassess
up­
to­
date
documentation
4,764
0.00
0.00
4.00
0.00
$
0.00
$
0.00
$
0.00
19,058
$
249.20
$
1,187,3
08
File
and
maintain
up­
to­
date
documentation
4,764
0.00
0.00
0.00
0.10
$
0.00
$
0.00
$
0.00
476
$
3.17
$
15,122
Modify
up­
to­
date
documentation
476
0.00
0.00
4.00
0.00
$
0.00
$
0.00
$
0.00
1,906
$
249.20
$
118,73
1
Facility
Operating
Record:
Leak
inspection
log
Prepare
a
leak
inspection
log
4,764
0.00
0.00
4.00
2.00
$
0.00
$
0.00
$
0.00
28,587
$
312.68
$
1,489,7
58
Reassess
leak
inspection
log
4,764
0.00
0.00
2.00
0.00
$
0.00
$
0.00
$
0.00
9,529
$
124.60
$
593,65
4
File
and
maintain
inspection
log
4,764
0.00
0.00
0.00
0.10
$
0.00
$
0.00
$
0.00
476
$
3.17
$
15,122
Modify
leak
inspection
log
4,764
0.00
0.00
4.00
0.00
$
0.00
$
0.00
$
0.00
19,058
$
249.20
$
1,187,3
08
Facility
Operating
Record:

Design/
monitoring/
operation/
inspection
information
Reassess
information
4,764
0.00
0.00
4.00
0.00
$
0.00
$
0.00
$
0.00
19,058
$
249.20
$
1,187,3
08
File
and
maintain
information
4,764
0.00
0.00
0.00
0.10
$
0.00
$
0.00
$
0.00
476
$
3.17
$
15,122
Modify
information
476
0.00
0.00
4.00
0.00
$
0.00
$
0.00
$
0.00
1,906
$
249.20
$
118,73
1
Facility
Operating
Record:
Equipment
Log
94
Number
of
Hours
per
Respondent
Postage
/
Photoco
pies
Other
Total
Hours
Responde
nt/
Total
Cost
Responde
nts
Legal
Manag
erial
Technic
al
Clerical
Shippin
g
per
Year
Shipment
per
Year
@

$
119.91
/
hr
@

$
85.82/

hr
@

$
62.30/

hr
@

$
31.74/
h
r
@

$
1.29/
d
oc
@

$
0.10/
pa
ge
Reassess
equipment
log
4,764
0.00
0.00
2.00
0.00
$
0.00
$
0.00
$
0.00
9,529
$
124.60
$
593,65
4
File
and
maintain
an
equipment
log
4,764
0.00
0.00
0.00
0.10
$
0.00
$
0.00
$
0.00
476
$
3.17
$
15,122
Modify
equipment
log
476
0.00
0.00
4.00
0.00
$
0.00
$
0.00
$
0.00
1,906
$
249.20
$
118,73
1
Facility
Operating
Record:
Valve
Log
(
265.1057)(
g)

and
(
h)
(
Not
in
compliance)

Reassess
valve
log
1,191
0.00
0.00
2.00
0.00
$
0.00
$
0.00
$
0.00
2,382
$
124.60
$
148,41
4
File
and
maintain
valve
log
1,191
0.00
0.00
0.00
0.10
$
0.00
$
0.00
$
0.00
119
$
3.17
$
3,781
Modify
valve
log
119
0.00
0.00
4.00
0.00
$
0.00
$
0.00
$
0.00
476
$
249.20
$
29,683
Facility
Operating
Record:
Valve
Log
(
265.1062)
(
In
compliance)

Reassess
valve
log
238
0.00
0.00
2.00
0.00
$
0.00
$
0.00
$
0.00
476
$
124.60
$
29,683
File
and
maintain
valve
log
238
0.00
0.00
0.00
0.10
$
0.00
$
0.00
$
0.00
24
$
3.17
$
756
Modify
valve
log
24
0.00
0.00
4.00
0.00
$
0.00
$
0.00
$
0.00
95
$
249.20
$
5,937
Facility
Operating
Record:
Criteria
Log
Reassess
criteria
log
4,764
0.00
0.00
2.00
0.00
$
0.00
$
0.00
$
0.00
9,529
$
124.60
$
593,65
4
File
and
maintain
criteria
log
4,764
0.00
0.00
0.00
0.10
$
0.00
$
0.00
$
0.00
476
$
3.17
$
15,122
Modify
criteria
log
476
0.00
0.00
4.00
0.00
$
0.00
$
0.00
$
0.00
1,906
$
249.20
$
118,73
1
Facility
Operating
Record:
Exemption
Log
Reassess
exemption
log
4,764
0.00
0.00
1.00
0.00
$
0.00
$
0.00
$
0.00
4,764
$
62.30
$
296,82
95
Number
of
Hours
per
Respondent
Postage
/
Photoco
pies
Other
Total
Hours
Responde
nt/
Total
Cost
Responde
nts
Legal
Manag
erial
Technic
al
Clerical
Shippin
g
per
Year
Shipment
per
Year
@

$
119.91
/
hr
@

$
85.82/

hr
@

$
62.30/

hr
@

$
31.74/
h
r
@

$
1.29/
d
oc
@

$
0.10/
pa
ge
7
File
and
maintain
exemption
log
4,764
0.00
0.00
0.00
0.10
$
0.00
$
0.00
$
0.00
476
$
3.17
$
15,122
Modify
exemption
log
476
0.00
0.00
4.00
0.00
$
0.00
$
0.00
$
0.00
1,906
$
249.20
$
118,73
1
Subtotal
varies
0.00
varies
varies
varies
$
1,549.

72
$
0.00
$
0.00
190,906
varies
$
11,431,

259
Subtotal
for
LQG
Air
Emission
Standards
Requirements
varies
0.00
varies
varies
varies
$
1,549.

72
$
0.00
$
0.00
190,906
varies
$
11,431,

259
96
EXHIBIT
5:

ANNUAL
RESPONDENT
BURDEN/
COST
ESTIMATES
FOR
SMALL
QUANTITY
GENERATORS
O&
M
Costs/
Respondent
Cost
per
Number
of
Hours
per
Respondent
Postage
/
Photocopie
s
Other
Total
Hours
Responde
nt/
Total
Cost
Responde
nts
Legal
Manage
rial
Technic
al
Clerical
Shippin
g
per
Year
Shipment
per
Year
@

$
119.91/

hr
@

$
85.82/

hr
@

$
62.30/

hr
@

$
31.74/

hr
@

$
1.29/
d
oc
@

$
0.10/
page
Small
Quantity
Generator
Pre­
Transport
Requirements
Labeling
Label
containers
in
180­
day
accumulation
107,366
0.00
0.00
0.25
0.00
$
0.00
$
0.00
$
0.00
26,842
$
15.58
$
1,672,225
Label
containers
in
satellite
accumulation
107,366
0.00
0.00
0.25
0.00
$
0.00
$
0.00
$
0.00
26,842
$
15.58
$
1,672,225
Subtotal
107,366
0.00
0.00
0.50
varies
$
0.00
$
0.00
$
0.00
53,683
varies
$
3,344,451
Emergency
Procedures
(
262.34(
d))

Observe
scene
of
hazardous
waste
discharge
1,825
0.00
0.00
0.50
0.00
$
0.00
$
0.00
$
0.00
913
$
31.15
$
56,856
Report
by
phone
requested
data
items
to
NRC
1,825
0.00
0.00
0.50
0.00
$
0.00
$
0.00
$
5.00
913
$
36.15
$
65,982
Document
that
local
officials
decline
to
enter
into
arrangements
for
coordinating
response
1,825
0.00
0.00
0.10
0.00
$
0.00
$
0.00
$
0.00
183
$
6.23
$
11,371
Post
emergency
information
by
phone
1,825
0.00
0.00
0.00
0.10
$
0.00
$
0.00
$
0.00
183
$
3.17
$
5,793
97
Subtotal
1,825
0.00
0.00
1.10
0.10
$
0.00
$
0.00
$
0.00
2,190
varies
$
140,002
Requests
for
Extensions
of
the
Accumulation
Period
(
262.34(
f))

Prepare
and
submit
request
to
Regional
Administrator
107
0.00
0.10
0.00
0.40
$
1.29
$
0.00
$
0.00
54
$
22.57
$
2,423
Subtotal
107
0.00
0.10
0.00
0.40
$
138.50
$
0.00
$
0.00
54
$
22.57
$
2,423
Subtotal
for
SQG
Pre­
Transport
Requirements
varies
0.00
varies
varies
varies
$
138.50
$
0.00
$
9,126.11
55,927
varies
$
3,486,876
98
EXHIBIT
6:

ANNUAL
RESPONDENT
BURDEN/
COST
ESTIMATES
RECORDKEEPING
AND
REPORTING
REQUIREMENTS
O&
M
Costs/
Respondent
Cost
per
Number
of
Hours
per
Respondent
Postage/
Photocopie
s
Other
Total
Hours
Respond
ent/
Total
Cost
Responde
nts
Legal
Manager
ial
Technica
l
Clerical
Shipping
per
Year
Shipmen
t
per
Year
@

$
119.91
/
hr
@

$
85.82/
h
r
@

$
62.30/
h
r
@

$
31.74/
h
r
@

$
1.29/
doc
@

$
0.10/
page
Recordkeeping
and
Reporting
Requirements
Recordkeeping
and
Reporting
Requirements
(
262.40,
262.43)

Store,
file,
and
maintain
records
of
any
test
results,
waste
analyses,
or
other
determinations
0
0.00
0.00
0.10
0.00
$
0.00
$
0.00
$
0.00
0
$
6.23
$
0
Gather,
provide
additional
information
requested
by
EPA
­
LQG
17
0.00
0.25
0.10
0.00
$
1.29
$
1.00
$
0.00
6
$
29.98
$
510
Gather,
provide
additional
information
requested
by
EPA
­
SQG
107
0.00
0.25
0.10
0.00
$
1.29
$
0.50
$
0.00
38
$
29.48
$
3,165
TOTAL
varies
0.00
varies
0.10
0.00
$
160.45
$
70.70
$
0.00
44
varies
$
3,675
99
EXHIBIT
7:

EXPORT
REQUIREMENTS
ANNUAL
RESPONDENT
BURDEN/
COST
ESTIMATES
O&
M
Costs/
Respondent
Cost
per
Number
of
Hours
per
Respondent
Postage/
Photocopi
es
Other
Total
Hours
Responde
nt/
Total
Cost
Respondents
Legal
Manager
ial
Technic
al
Clerical
Shipping
per
Year
Shipment
per
Year
@

$
119.91/

hr
@

$
85.82/
h
r
@

$
62.30/

hr
@

$
31.74/
h
r
@

$
1.29/
do
c
@

$
0.10/
pag
e
Notification
of
Intent
to
Export
Requirements
(
262.53(
a))

Export
Requirements
280
0.00
0.00
1.50
0.00
$
0.00
$
0.50
$
0.00
420
$
93.95
$
26,306
Prepare
and
submit
notification
to
EPA
(
262.83(
e))
280
0.00
0.10
0.30
1.50
$
1.29
$
0.00
$
0.00
532
$
76.17
$
21,328
Subtotal
280
0.00
varies
varies
varies
$
361.20
$
140.00
$
0.00
952
varies
$
47,634
Renotification
of
Intent
to
Export
Requirements
(
262.54(
g))

Collect
specific
changes
to
export
information
18
0.00
0.00
0.50
0.00
$
0.00
$
0.50
$
0.00
9
$
31.65
$
570
Prepare
and
submit
notification
to
EPA
18
0.00
0.10
0.00
0.50
$
1.29
$
0.00
$
0.00
11
$
25.74
$
463
Subtotal
18
0.00
varies
varies
varies
$
23.22
$
9.00
$
0.00
20
varies
$
1,033
Additional
Reporting
(
262.53(
d))

Gather
and
provide
additional
information
1
0.00
0.00
0.50
0.50
$
1.29
$
0.50
$
0.00
1
$
48.81
$
49
Subtotal
1
0.00
0.00
0.50
0.50
$
1.29
$
0.50
$
0.00
1
$
48.81
$
49
Annual
Report
Requirements
(
262.56(
a))
100
Research
specific
export
information
(
LQGs)
268
0.00
0.00
1.00
1.00
$
0.00
$
0.50
$
0.00
536
$
94.54
$
25,337
Prepare
and
submit
report
(
LQGs)
268
0.00
0.10
1.00
0.30
$
1.29
$
0.00
$
0.00
375
$
81.69
$
21,894
Research
specific
export
information
(
SQGs)
12
0.00
0.00
0.50
0.50
$
0.00
$
0.50
$
0.00
12
$
47.52
$
570
Prepare
and
submit
report
(
SQGs)
12
0.00
0.10
0.50
0.50
$
1.29
$
0.00
$
0.00
13
$
56.89
$
683
Subtotal
varies
0.00
varies
varies
varies
$
15.48
$
6.00
$
0.00
936
varies
$
48,484
Recordkeeping
Requirements
(
262.57(
a))

File
and
maintain
notification
and
reports
listed
above
280
0.00
0.00
0.00
0.25
$
0.00
$
0.00
$
0.00
70
$
7.94
$
2,222
Subtotal
280
0.00
0.00
0.00
0.25
$
0.00
$
0.00
$
0.00
70
$
7.94
$
2,222
Subtotal
for
Export
Requirements
­
varies
0.00
varies
varies
varies
$
401.19
$
155.50
$
0.00
1,979
varies
$
99,421
101
EXHIBIT
8
IMPORTS/
EXPORTS
ESTIMATED
ANNUAL
INCREMENTAL
RESPONDENT
BURDEN
AND
COST
(
OECD
Countries
Only)

(
Recycling
only)
O&
M
Costs/
Respondent
Cost
per
Number
of
Hours
per
Respondent
Postage/
Photocopi
es
Other
Total
Hours
Respondent
/
Total
Cost
Responde
nts
Legal
Manage
rial
Technic
al
Clerical
Shipping
per
Year
Shipment
per
Year
@

$
119.91/

hr
@

$
85.82/

hr
@

$
62.30/

hr
@

$
31.74/

hr
@

$
1.29/
do
c
@

$
0.10/
pag
e
Notification
Requirements:
Intent
to
Trade
(
262.83(
e))

Collect
specific
information
6
0.00
0.00
1.75
0.00
$
0.00
$
0.50
$
0.00
11
$
109.53
$
657
Prepare
and
submit
notification
to
EPA
6
0.00
0.25
0.60
1.75
$
1.29
$
0.00
$
0.00
16
$
115.67
$
694
Subtotal
6
0.00
varies
varies
varies
$
7.74
$
3.00
$
0.00
26
varies
$
1,351
Additional
Reporting
(
262.85(
g))

Gather
and
provide
additional
information
0
0.00
0.00
0.55
0.55
$
1.29
$
0.50
$
0.00
0
$
53.51
$
0
Subtotal
0
0.00
0.00
0.00
0.00
$
0.00
$
0.00
$
0.00
0
$
53.51
$
0
Annual
Report
Requirements
(
262.87(
a))

Research
specific
export
information
(
LQGs)
6
0.00
0.00
1.00
1.00
$
0.00
$
0.50
$
0.00
12
$
94.54
$
567
Prepare
and
submit
report
(
LQGs)
6
0.00
0.10
1.00
0.30
$
1.29
$
0.00
$
0.00
8
$
81.69
$
490
Research
specific
export
information
(
SQGs)
0
0.00
0.00
0.50
0.50
$
0.00
$
0.50
$
0.00
0
$
47.52
$
0
Prepare
and
submit
report
(
SQGs)
0
0.00
0.10
0.50
0.50
$
1.29
$
0.00
$
0.00
0
$
56.89
$
0
Subtotal
varies
0.00
varies
varies
varies
$
7.74
$
3.00
$
0.00
20
varies
$
1,057
102
Recordkeeping
Requirements
(
262.87(
c))

File
and
maintain
notification
and
reports
listed
above
6
0.00
0.00
0.00
0.25
$
0.00
$
0.00
$
0.00
2
$
7.94
$
48
Subtotal
6
0.00
0.00
0.00
0.25
$
0.00
$
0.00
$
0.00
2
$
7.94
$
48
OECD
Tracking
Document
(
262.84)

Exporter
Completes
Tracking
Document
(
LQGs
+

SQGs)
6
0.00
0.00
0.50
0.50
$
0.00
$
0.50
$
0.00
6
$
47.52
$
285
Importer
Signes
Tracking
Document
and
Transmits
Copies
81
0.00
0.10
0.50
0.50
$
1.29
$
0.00
$
0.00
89
$
56.89
$
4,608
Subtotal
varies
0.00
varies
varies
varies
$
104.49
$
3.00
$
0.00
95
varies
$
4,893
Sub
Total
for
OECD
Requirements
varies
0.00
varies
varies
varies
$
119.97
$
9.00
$
0.00
143
varies
$
7,349.56
103
Exhibit
9
SUMMARY
OF
ANNUAL
AND
THREE­
YEAR
RESPONDENT
BURDEN
AND
COST*

GENERATOR
ACTIVITY
TOTAL
HOURLY
BURDEN
TOTAL
ANNUAL
LABOR
COST
CAPITAL
COSTS
O&
M
COSTS
TOTAL
COSTS
READ
REGULATIONS
(
LQGs
+
SQGs)
92,172
$
7,394,067
­­­­­
$
0
$
7,394,067
LQGs
PRETRANSPORT
114,216
$
6,008,631
­­­­­
$
21,832
$
6,030,463
LQGs
AIR
EMISSION
STANDARDS
190,906
$
11,429,710
­­­­­
$
1,550
$
11,431,259
LQGs
RECORDKEEPING
AND
REPORTING
6
$
471
$
0
$
0
$
471
SQGs
PRETRANSPORT
55,927
$
3,477,611
­­­­­
$
9,265
$
3,486,876
SQGs
RECORDKEEPING
AND
REPORTING
38
$
2,972
­­­­­
$
192
$
3,165
EXPORTER
REQUIREMENTS
1,979
$
98,865
­­­­­
$
557
$
99,421
IMPORTEREXPORTER
REQUIREMENTS
OECD
and
BILATERAL
143
$
7,221
­­­­­
$
129
$
7,350
ANNUAL
CAPITAL
COSTS
­­­­­
­­­­­
$
22,770
­­­­­
$
22,770
TOTAL
ONE
YEAR
455,387
$
28,419,548
$
22,770
$
33,524
$
28,475,842
104
TOTAL
THREE­
YEAR
1,366,160
$
85,258,645
$
68,310
$
100,572
$
85,427,527
EXHIBIT
10:
ESTIMATED
ANNUAL
AGENCY
BURDEN
AND
COSTS
Number
of
O&
M
Costs/
Respondent
Cost
per
Respondents
/
Hours
per
Respondent
Postage/
Photocopi
es
Total
Hours
Responde
nt/
Total
Cost
Shipments
Legal
Manager
ial
Technic
al
Clerical
Shipping
per
Year
Shipment
per
Year
@

$
76.85/
h
r
@

$
65.33/
h
r
@

$
55.28/

hr
@

$
29.02/
h
r
@

$
1.29/
do
c
@

$
0.10/
pag
e
Estimated
Annual
Agency
Burden
and
Costs
Pre­
Transport
Requirements
(
for
both
Large
and
Small
Quantity
Generators)

Review
documents
in
generator/
emergency
coordinator
reports
3,744
0.00
0.00
0.50
0.00
$
0.00
$
0.00
1,872
$
27.64
$
103,484
Review
submitted
release
report
information
43
0.00
0.00
0.50
0.00
$
0.00
$
0.00
22
$
27.64
$
1,189
Enter
information
into
database
tracking
all
releases
43
0.00
0.00
0.50
0.50
$
0.00
$
0.00
43
$
42.15
$
1,812
Transmit
information
to
respective
response
authorities
43
0.00
0.00
0.25
0.25
$
0.00
$
0.00
22
$
21.08
$
906
Review
information
on
equivalent
containment
devices
110
0.00
0.00
10.00
0.00
$
0.00
$
0.00
1,101
$
552.80
$
60,861
Evaluate
information
for
24­
hour
waste
removal
exemption
8
0.00
0.00
6.00
0.00
$
0.00
$
0.00
48
$
331.68
$
2,653
Evaluate
information
for
secondary
containment
variance
43
0.00
0.00
6.00
0.00
$
0.00
$
0.00
258
$
331.68
$
14,262
Review
annual
leak
tests
and
inspections
0
0.00
0.00
1.00
0.00
$
0.00
$
0.00
0
$
55.28
$
0
Review
release
notification
reports
43
0.00
0.00
4.00
0.00
$
0.00
$
0.00
172
$
221.12
$
9,508
Review
major
repair
certifications
43
0.00
0.00
8.00
0.00
$
0.00
$
0.00
344
$
442.24
$
19,016
105
Number
of
O&
M
Costs/
Respondent
Cost
per
Respondents
/
Hours
per
Respondent
Postage/
Photocopi
es
Total
Hours
Responde
nt/
Total
Cost
Shipments
Legal
Manager
ial
Technic
al
Clerical
Shipping
per
Year
Shipment
per
Year
@

$
76.85/
h
r
@

$
65.33/
h
r
@

$
55.28/

hr
@

$
29.02/
h
r
@

$
1.29/
do
c
@

$
0.10/
pag
e
Review
requests
for
accumulation
period
extensions
124
0.00
0.00
3.00
0.00
$
0.00
$
0.00
373
$
165.84
$
20,625
Review
and
evaluate
drawings
and
certifications
of
drip
pads
0
0.00
0.00
2.00
0.00
$
0.00
$
0.00
0
$
110.56
$
0
Evaluate
notices
of
releases
from
drip
pads
2
0.00
0.00
2.00
0.00
$
0.00
$
0.00
4
$
110.56
$
221
Review
repairs
conducted
to
drip
pads
and
independent
certifications
2
0.00
0.00
1.00
0.00
$
0.00
$
0.00
8
$
55.28
$
111
Review
and
evaluate
notificiations
of
releases
of
hazardous
waste
from
containment
buildings
51
0.00
0.00
3.00
0.00
$
0.00
$
0.00
153
$
165.84
$
8,458
Review
notices
of
repairs
to
containment
buildings
51
0.00
0.00
2.00
0.00
$
0.00
$
0.00
102
$
110.56
$
5,639
Subtotal
varies
0.00
0.00
varies
varies
varies
varies
4,521
­­­­­­­­­­­­
­
$
248,746
Air
Emission
Standards
Requirements
(
40
CFR
Subparts
AA
and
BB)
Review
notice
to
implement
alternative
valve
standard
in
(
265.1061)(
a)
953
0.00
0.00
1.00
0.00
$
0.00
$
0.00
953
$
55.28
$
52,682
Review
notice
to
discontinue
alternative
valve
standard
in
(
265.1061)(
a)
10
0.00
0.00
1.00
0.00
$
0.00
$
0.00
10
$
55.28
$
553
Review
notice
to
implement
alternative
valve
standard
(
265.1061)(
b)(
2)
and
(
265.1062)(
b)(
3)
238
0.00
0.00
1.00
0.00
$
0.00
$
0.00
238
$
55.28
$
13,157
Subtotal
varies
0.00
0.00
1.00
varies
varies
varies
1,201
­­­­­­­­­
$
66,391
Recordkeeping
and
Reporting
Requirements
(
262.40,
106
Number
of
O&
M
Costs/
Respondent
Cost
per
Respondents
/
Hours
per
Respondent
Postage/
Photocopi
es
Total
Hours
Responde
nt/
Total
Cost
Shipments
Legal
Manager
ial
Technic
al
Clerical
Shipping
per
Year
Shipment
per
Year
@

$
76.85/
h
r
@

$
65.33/
h
r
@

$
55.28/

hr
@

$
29.02/
h
r
@

$
1.29/
do
c
@

$
0.10/
pag
e
262.43)
Review
submitted
information
124
0.00
0.00
0.50
0.00
$
0.00
$
0.00
62
$
27.64
$
3,437
Enter
information
into
database
124
0.00
0.00
0.50
0.50
$
0.00
$
0.00
124
$
42.15
$
5,242
Subtotal
varies
0.00
0.00
0.50
varies
varies
varies
187
­­­­­­­­­
$
8,680
International
Trade
Requirements
(
262.53,
262.55,
262.56,
262.57,
262.83(
e),

262.85(
g))

Review
submitted
information
304
0.00
0.00
1.00
0.00
$
0.00
$
0.00
304
$
55.28
$
16,805
Submit,
in
conjunction
with
Department
of
State,

notification
to
receiving
country
and
any
transit
countries
304
0.00
0.00
0.00
0.16
$
2.58
$
0.50
49
$
7.72
$
2,348
Forward
to
primary
exporter
acknowledgement
of
consent
or
written
notification
of
objection
304
0.00
0.00
0.00
0.16
$
2.58
$
0.50
49
$
7.72
$
2,348
Review
annual
reports
262.56(
a)
286
0.00
0.00
0.25
0.00
$
0.00
$
0.00
72
$
13.82
$
3,953
Forward
to
receiving
government
additional
information
1
0.00
0.00
0.00
0.16
$
2.58
$
0.50
0
$
7.72
$
8
Enter
reviewed
information
into
database
591
0.00
0.00
0.00
0.50
$
0.00
$
0.00
296
$
14.51
$
8,575
Subtotal
varies
0.00
0.00
varies
varies
varies
varies
768
­­­­­­­­­­­
$
34,036
OECD
Countries
:
Exporter
Provisions
for
Recovery
(
262.83(
b)&

(
c),
262.84(
e))

Receive
and
Record
Acknowledgement
of
Receipt
from
Importing
country
81
0.00
0.25
0.00
0.10
$
0.00
$
0.00
28
$
19.23
$
1,558
107
Number
of
O&
M
Costs/
Respondent
Cost
per
Respondents
/
Hours
per
Respondent
Postage/
Photocopi
es
Total
Hours
Responde
nt/
Total
Cost
Shipments
Legal
Manager
ial
Technic
al
Clerical
Shipping
per
Year
Shipment
per
Year
@

$
76.85/
h
r
@

$
65.33/
h
r
@

$
55.28/

hr
@

$
29.02/
h
r
@

$
1.29/
do
c
@

$
0.10/
pag
e
Receive
and
record
Tracking
Document
from
Importing
country
81
0.00
0.25
0.00
0.10
$
0.00
$
0.00
28
$
19.23
$
1,558
Subtotal
162
0.00
0.50
0.00
0.20
varies
varies
57
­­­­­­­­­­­­
­
$
3,116
OECD
Countries
:
Importer
Provisions
for
Recovery
(
262.83(
b)&

(
c),
262.84(
e))

Transmit
Acknowledgement
of
Receipt
to
foreign
exporters
and
competent
authority
81
0.00
0.25
0.00
0.10
$
2.58
$
0.00
28
$
21.81
$
1,767
Receive
and
record
Tracking
Document
from
Importing
facility
81
0.00
0.25
0.00
0.10
$
0.00
$
0.00
28
$
19.23
$
1,558
Subtotal
162
0.00
0.50
0.00
0.20
varies
varies
57
­­­­­­­­­­­­
$
3,325
Total
varies
varies
varies
varies
varies
varies
varies
6,790
­­­­­­­­­­
$
364,294
*
Some
totals
may
not
add
up
due
to
rounding.
108
6(
e)
BOTTOM
LINE
BURDEN
HOURS
AND
COSTS
(
i)
Respondent
Tally
As
shown
in
Exhibit
9,
EPA
estimates
the
total
annual
respondent
burden
to
be
455,387
hours
and
the
annual
cost
to
be
$
28,475,842
The
bottom
line
burden
to
respondents
over
three
years
is
estimated
to
be
1,366,160
hours
with
a
cost
of
approximately
$
85,427,527.

(
ii)
Agency
Tally
As
shown
in
Exhibit
10,
EPA
estimates
the
total
annual
Agency
burden
to
be
6,790
hours
and
the
annual
cost
to
be
$
364,294
The
bottom
line
burden
to
the
Agency
over
three
years
is
estimated
to
be
20370
hours
with
a
cost
of
$
1,092,882.

6(
f)
REASONS
FOR
CHANGE
IN
BURDEN
The
previous
Generator
Standards
ICR,
Number
0820.08,
estimated
an
annual
respondent
burden
of
485,136
hours.
This
current
ICR,
Number
0820.09,
estimates
an
annual
respondent
burden
of
455,387
hours,
which
is
a
29,749
hour
decrease
from
ICR
0820.08.
The
pimary
reasons
for
this
change
are
decrease
in
universe
size
and
a
re­
caluculation
of
the
burden
on
international
activities
covered
by
this
ICR.
In
March
of
1004,
a
change
worsksheet
was
file
with
OMB,
reallocating
the
burden
from
ICR
Number
1647.04
to
ICR
number
0820.08.
However,
it
has
been
determined
that
the
burden
of
the
two
are
not
additive,
as
there
was
a
certain
amount
of
double
counting
between
the
two
ICRs.
The
current
analysis
is
a
better
representation
of
the
actual
burden
incurred
by
importers
and
exporters
of
hazardous
waste
covered
by
this
ICR.

6(
g)
BURDEN
STATEMENT
Exhibit
11
presents
the
estimated
average
burden
hours
per
respondent
per
year
for
the
public
reporting
and
recordkeeping
requirements
covered
by
this
ICR
.
The
average
public
reporting
and
recordkeeping
burden
for
LQGs
under
this
collection
of
information
is
estimated
to
be
13.18
hours
(
averaged
across
all
LQG
respondents).
The
average
public
reporting
and
recordkeeping
burden
for
SQGs
under
this
collection
of
information
is
estimated
to
be
1.22
hours
(
averaged
across
all
SQG
respondents).

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
109
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.

EXHIBIT
11
ANNUAL
AVERAGE
RESPONDENT
BURDEN
Respondent
Type
Reporting
and
Recordkeeping
Burden
LQGs
13.18
hours
SQGs
1.22
hours
To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
number
RCRA­
2004­
2006
which
is
available
for
public
viewing
at
the
Office
of
Solid
Waste
and
Emergency
Response
(
OSWER)
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
OSWER
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
0006)
and
OMB
control
number
(
2050­
0035)
in
any
correspondence.
