SUPPORTING
STATEMENT
FOR
EPA
INFORMATION
COLLECTION
REQUEST
NUMBER
959.12
"
FACILITY
GROUND­
WATER
MONITORING
REQUIREMENTS
"

January
17,
2005
TABLE
OF
CONTENTS
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
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1
1(
a)
TITLE
AND
NUMBER
OF
THE
INFORMATION
COLLECTION
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1
1(
b)
SHORT
CHARACTERIZATION
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1
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
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4
2(
a)
NEED
AND
AUTHORITY
FOR
THE
COLLECTION
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4
2(
b)
USE
AND
USERS
OF
THE
DATA
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6
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
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8
3(
a)
NONDUPLICATION
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8
3(
b)
PUBLIC
NOTICE
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8
3(
c)
CONSULTATIONS
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9
3(
d)
EFFECTS
OF
LESS
FREQUENT
COLLECTION
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9
3(
e)
GENERAL
GUIDELINES
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9
3(
f)
CONFIDENTIALITY
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9
3(
g)
SENSITIVE
QUESTIONS
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9
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
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10
4(
a)
RESPONDENTS
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10
4(
b)
INFORMATION
REQUESTED
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10
5.
THE
INFORMATION
COLLECTED
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AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
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19
5(
a)
AGENCY
ACTIVITIES
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19
5(
b)
COLLECTION
METHODOLOGY
AND
MANAGEMENT
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20
5(
c)
SMALL
ENTITY
FLEXIBILITY
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20
5(
d)
COLLECTION
SCHEDULE
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21
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
COLLECTION
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22
6(
a)
ESTIMATING
RESPONDENT
BURDEN
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22
6(
b)
ESTIMATING
RESPONDENT
COSTS
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22
6(
c)
ESTIMATING
AGENCY
BURDEN
AND
COSTS
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23
6(
d)
ESTIMATING
THE
RESPONDENT
UNIVERSE
AND
TOTAL
BURDEN
AND
COSTS
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24
6(
e)
BOTTOM
LINE
BURDEN
HOURS
AND
COST
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29
6(
f)
REASONS
FOR
CHANGE
IN
BURDEN
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29
6(
g)
BURDEN
STATEMENT
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29
EXHIBITS
Estimated
Annual
Respondent
Hour
and
Cost
Burden:
Permitted
Facilities
(
Exhibit
1)
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31
Estimated
Annual
Respondent
Hour
and
Cost
Burden:
Interim
Status
Facilities
(
Exhibit
2)
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33
Estimated
Agency
Burden
and
Hour
Burden:
Permitted
Facilities
(
Exhibit
3)
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36
Estimated
Agency
Hour
and
Cost
Burden:
Interim
Status
Facilities
(
Exhibit
4)
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37
Respondent
Burden
and
Cost
Summary
(
Exhibit
5)
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39
Agency
Burden
and
Cost
Summary
(
Exhibit
6)
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40
1
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
and
Number
of
the
Information
Collection
This
Information
Collection
Request
(
ICR)
is
entitled,
"
Facility
Ground­
Water
Monitoring
Requirements,"
ICR
number
959.12.
This
ICR
renews
the
previous
ICR,
"
Facility
Ground­
Water
Monitoring
Requirements,"
ICR
number
959.11.

1(
b)
Short
Characterization
Subtitle
C
of
the
Resource
Conservation
and
Recovery
Act
of
1976
(
RCRA)
creates
a
comprehensive
program
for
the
safe
management
of
hazardous
waste.
Section
3004
of
RCRA
requires
owners
and
operators
of
facilities
that
treat,
store,
or
dispose
of
hazardous
waste
to
comply
with
standards
established
by
EPA
that
are
"
necessary
to
protect
human
health
and
the
environment."
Section
3005
provides
for
implementation
of
these
standards
under
permits
issued
to
owners
and
operators
by
EPA
or
authorized
States.
Section
3005
also
allows
owners
and
operators
of
facilities
in
existence
when
the
regulations
came
into
effect
to
comply
with
applicable
notice
requirements
to
operate
until
a
permit
is
issued
or
denied.
This
statutory
authorization
to
operate
prior
to
permit
determination
is
commonly
known
as
"
interim
status."
Owners
and
operators
of
interim
status
facilities
also
must
comply
with
standards
set
under
Section
3004.

EPA
promulgated
ground­
water
monitoring
standards
for
interim
status
facilities
in
1980
(
45
FR
33154;
May
19,
1980),
codified
in
40
CFR
Part
265,
Subpart
F,
and
for
permitted
facilities
in
1982
(
47
FR
32274;
July
26,
1982),
codified
in
40
CFR
Part
264,
Subpart
F.
Both
sets
of
standards
establish
programs
for
protecting
ground
water
from
releases
of
hazardous
wastes
from
land
disposal
facilities
(
LDFs).
Under
Part
264,
LDFs
also
are
known
as
regulated
units
and
include
surface
impoundments,
waste
piles,
land
treatment
units,
and
landfills.

This
ICR
examines
the
ground­
water
monitoring
standards
for
permitted
and
interim
status
facilities
at
40
CFR
Parts
264
and
265,
as
specified.
Sections
1
through
5
of
this
ICR
describe
the
groundwater
monitoring
information
collection
requirements.
In
Section
6,
EPA
estimates
the
annual
hour
and
cost
burden
to
respondents
and
the
Agency
in
carrying
out
these
requirements.

There
were
no
terms
of
clearance
from
the
Office
of
Management
and
Budget
(
OMB)
that
were
applied
to
the
previous
GWM
ICR,
959.11.
In
the
supporting
statement
for
959.11,
EPA
discussed
OMB
terms
of
clearance
from
the
earlier
GWM
ICR,
including
examining
record
keeping
and
reporting
requirements
and
burden
reduction
considerations.
At
that
time,
EPA
determined
that
it
was
not
appropriate
to
make
changes
in
GWM
reporting
requirements.
No
changes
have
been
made
to
the
GWM
requirements
since
2001.
EPA
is
currently
undertaking
a
larger
burden
reduction
initiative
for
the
RCRA
program
which
has
not
been
finalized.

The
following
paragraphs
describe
the
information
collection
requirements
addressed
in
this
ICR.

PERMITTED
FACILITIES
40
CFR
Part
264,
Subpart
F
establishes
requirements
for
permitted
LDFs,
but
not
all
information
requirements
in
Part
264
are
covered
in
this
ICR.
The
information
collection
requirements
in
the
following
2
sections
are
found
in
either
"
General
Hazardous
Waste
Facility
Standards,"
ICR
number
1571,
or
"
Part
B
Permit
Application,
Permit
Modifications,
and
Special
Permits,"
ICR
number
1573.

Applicability,
Compliance
Period,
and
General
Ground­
Water
Monitoring
Requirements
Information
collection
requirements
under
sections
264.90,
264.96,
and
264.97
are
covered
in
either
ICR
Nos.
1571
or
1573
because
they
are
either
retained
in
the
operating
record
or
submitted
with
a
permit
application.
Section
264.90(
b)
discusses
demonstrations
for
exemption
from
regulation
of
releases
into
the
uppermost
aquifer.
These
requirements
are
covered
in
ICR
number
1573.
Section
264.96(
c)
discusses
demonstrations
that
the
ground­
water
protection
standard
of
section
264.92
has
not
been
exceeded
for
three
years.
Section
264.97(
g)(
1)­(
2)
covers
proposals
for
intervals
between
sampling
and
sampling
procedures.
These
requirements
are
covered
in
ICR
number
1571.
Section
264.97(
h)
discusses
statistical
methods
used
for
evaluating
ground­
water
data.
Section
264.97(
j)
discusses
the
recordkeeping
of
ground­
water
data.
These
requirements
are
covered
in
ICR
number
1573.
Requirements
under
these
sections
are
not
discussed
elsewhere
in
this
ICR.

Detection
Monitoring
Program
Under
section
264.98,
owners
and
operators
of
LDFs
are
required
to
implement
a
detection
monitoring
program
to
determine
whether
hazardous
wastes
are
leaking
from
the
facility
at
levels
great
enough
to
warrant
compliance
monitoring
under
section
264.99.
The
detection
monitoring
requirements
under
40
CFR
264.98
require
owners
and
operators
to
keep
a
record
of
all
ground­
water
analytical
data
collected
during
monitoring,
and
to
submit
notifications
of
detected
contamination,
the
presence
of
new
constituents,
and
exceeded
concentration
limits.
Records
under
these
sections
must
be
made
available
to
EPA
for
review.
The
following
detection
monitoring
sections
are
not
included
in
this
ICR.
Section
264.98(
g)(
4)
addresses
application
for
a
permit
modification
to
establish
a
compliance
monitoring
program.
Section
264.98(
h)
addresses
application
for
a
permit
modification
to
make
changes
to
the
detection
monitoring
program.
These
requirements
are
covered
in
ICR
number
1573.

Compliance
Monitoring
Program
Under
section
264.99,
owners
and
operators
may
have
to
implement
a
compliance
monitoring
program
to
determine
if
a
statistically
significant
increase
over
the
concentration
limits
of
the
hazardous
constituents
listed
in
the
permit
exists.
The
compliance
monitoring
requirements
under
40
CFR
264.99
require
owners
and
operators
to
keep
a
record
of
all
ground­
water
analytical
data
collected
during
monitoring,
and
to
submit
notifications
of
detected
contamination,
the
presence
of
new
constituents,
and
exceeded
concentration
limits.
Records
under
these
sections
must
be
made
available
to
EPA
for
review.
Owners
and
operators
of
facilities
detecting
contamination
must
also
submit
an
engineering
feasibility
plan
for
corrective
action
or,
if
they
wish
to
seek
approval
of
an
alternate
concentration
limit
(
ACL),
all
data
necessary
to
establish
an
ACL.
The
following
compliance
monitoring
sections
are
not
included
in
this
ICR.
Section
264.99(
h)(
2)
discusses
application
for
a
permit
modification
to
establish
a
corrective
action
program.
Sections
264.99(
i)(
3)
and
264.99(
j)
discuss
applications
for
permit
modifications
to
make
changes
to
the
compliance
monitoring
program
because
of
contamination
from
a
non­
regulated
unit,
and
changes
to
the
compliance
monitoring
program,
respectively.
These
requirements
are
covered
in
ICR
number
1573.
3
Corrective
Action
Under
section
264.100,
corrective
action
may
be
instituted
to
bring
a
facility
back
into
compliance
with
the
ground­
water
protection
standard.
The
corrective
action
requirements
under
40
CFR
264.100
require
owners
and
operators
to
make
demonstrations
in
order
to
terminate,
or
obtain
exemptions
from,
corrective
action.
Owners
and
operators
conducting
a
corrective
action
program
must
keep
a
record
of
all
ground­
water
analytical
data
collected
during
monitoring,
submit
reports
on
the
effectiveness
of
the
program,
and
submit
permit
modification
applications
where
appropriate.
The
following
corrective
action
program
sections
are
not
included
in
this
ICR.
Section
264.100(
h)
addresses
application
for
permit
modifications
to
make
changes
to
the
corrective
action
program.
These
requirements
are
covered
in
ICR
number
1573.
Section
264.101(
c)
discusses
demonstrations
for
exemption
from
undertaking
corrective
action
beyond
the
facility
boundary.
These
requirements
are
all
covered
in
ICR
number
1571.

INTERIM
STATUS
FACILITIES
40
CFR
Part
265,
Subpart
F
establishes
requirements
for
interim
status
land
disposal
facilities.
All
of
the
information
collection
requirements
for
interim
status
LDFs
are
covered
by
this
ICR.

Applicability
and
Alternative
Ground­
Water
Monitoring
Systems
Under
section
265.90,
all
or
part
of
the
interim
status
ground­
water
monitoring
requirements
may
be
waived
if
the
owner
or
operator
provides
(
1)
a
written
demonstration
establishing
that
corrosive
wastes
from
the
facility
will
be
neutralized
to
the
extent
that
they
no
longer
meet
corrosivity
characteristics
before
they
can
migrate
out
of
the
impoundment,
and/
or
(
2)
a
written
demonstration,
kept
at
the
facility,
which
establishes
that
there
is
a
low
potential
for
migration
of
hazardous
waste
or
hazardous
waste
constituents
from
the
facility
through
the
uppermost
aquifer
to
water
supply
wells
or
to
surface
water.
The
first
demonstration
applies
only
to
surface
impoundments
that
are
used
to
neutralize
wastes
which
are
hazardous
solely
because
they
exhibit
corrosivity
characteristics,
and
contain
no
other
hazardous
wastes.

40
CFR
265.90
also
allows
some
owners
and
operators
to
implement
an
alternative
ground­
water
monitoring
system.
Owners
and
operators
installing
an
alternative
system
must
submit
a
specific
plan
that
meets
the
regulatory
standards
of
section
265.93(
d)(
3).
Owners
and
operators
of
these
facilities
must
also
conduct
a
ground­
water
quality
assessment
program,
report
the
initial
results
of
the
assessment
program
to
the
Regional
Administrator,
and
keep
records
of
subsequent
quarterly
assessments
until
final
closure
of
the
facility.
An
annual
ground­
water
quality
assessment
report
is
also
required.

40
CFR
265.91
also
allows
some
owners
and
operators
to
select
an
alternate
hydraulically
downgradient
monitoring
well
location,
provided
they
meet
certain
criteria,
make
and
a
submit
a
demonstration
and
obtain
a
certification
from
a
qualified
ground­
water
scientist.

Sampling,
Analysis
and
Assessment
40
CFR
265.92
and
265.93
require
owners
and
operators
of
non­
exempt
interim
status
facilities
to
develop
and
conduct
a
sampling
and
analysis
program
to
monitor
for
ground­
water
contamination,
and
to
implement
a
ground­
water
quality
assessment
program
if
contamination
is
detected.
Ground­
water
quality
assessment
plans
must
be
submitted
to
EPA.
The
sampling
and
analysis
plan
must
be
kept
at
the
facility,
and
made
available
for
inspection
so
that
EPA
may
refer
to
it
in
evaluating
the
effectiveness
of
the
4
program.
Owners
and
operators
must
also
provide
notification
of
changes
in
indicator
parameter
concentrations
and
provide
an
initial
ground­
water
quality
assessment
report.
Notifications
and
reports
are
collected
and
analyzed
by
EPA
in
order
to
provide
immediate
information
on
contamination
and
changes
in
ground­
water
quality.

Recordkeeping
and
Recording
Specific
recordkeeping
and
reporting
requirements
for
interim
status
LDFs
are
established
under
40
CFR
265.94.
These
regulations
require
that
facilities
not
conducting
ground­
water
quality
assessments
keep
records
of
all
ground­
water
analytical
data
at
the
facility.
These
facilities
also
are
required
to
submit
quarterly
reports
during
the
first
year
on
drinking
water
suitability
parameters,
and
annual
reports
on
indicator
parameter
concentrations,
variations
from
background
levels,
and
ground­
water
surface
elevations.
Facilities
conducting
ground­
water
quality
assessments
must
keep
records
of
the
data
obtained
during
the
assessments,
and
submit
annual
ground­
water
quality
assessment
reports.
Reports
collected
under
this
section
provide
EPA
with
the
information
necessary
to
evaluate
the
impact
of
the
facility
on
ground­
water
quality.
Records
are
not
submitted
to
EPA
but
must
be
made
available
for
inspection.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
NEED
AND
AUTHORITY
FOR
THE
COLLECTION
PERMITTED
FACILITIES
Detection
Monitoring
40
CFR
264.98(
c)
requires
owners
and
operators
of
facilities
conducting
a
detection
monitoring
program
to
keep
a
record
of
all
ground­
water
analytical
data
obtained
under
the
program.
Owners
and
operators
must
notify
EPA
of
any
statistically
significant
evidence
of
ground­
water
contamination
(
§
264.98(
g)(
1)),
but
may
demonstrate
that
such
contamination
is
caused
by
a
source
other
than
the
regulated
facility.
Owners
and
operators
detecting
contamination
are
required
to
submit
an
engineering
feasibility
plan
for
a
corrective
action
program
and,
if
they
wish
to
seek
approval
for
an
ACL,
all
data
necessary
to
establish
an
ACL
(
§
264.98(
g)(
5)).
Owners,
operators
and
EPA
use
the
information
required
under
this
section
to
determine
whether
the
facility
is
affecting
ground­
water
quality,
and
whether
a
compliance
monitoring
program
under
section
264.99
is
warranted.
This
information
is
also
used
for
developing
and
evaluating
an
appropriate
compliance
monitoring
program.
The
detection
monitoring
requirements
contribute
to
EPA's
goal
of
preventing
undetected
releases
of
hazardous
waste
from
treatment,
storage,
and
disposal
facilities.

Compliance
Monitoring
40
CFR
264.99(
c)(
2)
requires
owners
and
operators
of
facilities
conducting
a
compliance
monitoring
program
to
keep
a
record
of
all
ground­
water
analytical
data
obtained
during
monitoring.
Owners
and
operators
are
required
under
sections
264.99(
g)
and
(
h)
to
notify
EPA
of
the
presence
of
new
constituents
or
exceeded
concentration
limits
at
any
monitoring
well.
Section
264.99(
i)
allows
owners
and
operators
to
demonstrate
that
the
exceeded
concentration
limits
are
caused
by
a
source
other
than
the
regulated
facility,
or
by
an
error
in
sampling
and
analysis.
The
information
in
this
section
is
used
by
owners,
operators
and
EPA
to
evaluate
the
extent
of
ground­
water
contamination
at
the
facility
and
to
5
determine
whether
a
corrective
action
program
under
section
264.100
is
warranted.
The
compliance
monitoring
requirements
contribute
to
EPA's
goal
of
ensuring
that
ground­
water
contamination
that
exceeds
acceptable
levels
is
quickly
identified
and
addressed.

Corrective
Action
EPA
promulgated
regulations
in
40
CFR
264.100
establishing
requirements
for
owners
and
operators
of
hazardous
waste
LDFs
conducting
a
corrective
action
program.
Section
264.100(
g)
requires
owners
and
operators
conducting
a
corrective
action
program
to
submit
a
semi­
annual
report
on
the
effectiveness
of
the
program.
This
report
allows
EPA
to
monitor
the
progress
of
corrective
action
and
identify
any
changes
that
should
be
made
to
the
program.
Exemption
from
the
corrective
action
requirements
may
be
obtained
by
submitting
a
demonstration
under
section
264.100(
e)(
2).
Corrective
action
may
be
terminated
by
demonstrating
that
the
ground­
water
protection
standard
has
not
been
exceeded
for
a
period
of
three
consecutive
years
under
section
264.100(
f).
This
information
is
used
by
EPA
to
confirm
that
corrective
action
is
undertaken
where
necessary
to
address
ground­
water
contamination.
The
corrective
action
requirements
contribute
to
EPA's
goal
of
minimizing
damage
to
the
environment
caused
by
the
treatment,
storage
and
disposal
of
hazardous
waste
by
bringing
regulated
facilities
back
into
compliance
with
their
ground­
water
protection
standards.

INTERIM
STATUS
FACILITIES
Applicability
and
Alternative
Ground­
Water
Monitoring
Systems
EPA
promulgated
standards
in
40
CFR
265.90
establishing
the
applicability
of
ground­
water
monitoring
and
requirements
for
alternative
ground­
water
monitoring
systems.
To
waive
the
ground­
water
monitoring
requirements,
owners
and
operators
must
submit
the
demonstrations
required
under
40
CFR
265.90(
c)
and/
or
265.90(
e).
The
demonstrations
under
this
section
are
meant
to
ensure
that
LDFs
are
not
unnecessarily
required
to
conduct
ground­
water
monitoring.
Non­
exempt
facilities
planning
to
implement
an
alternative
ground­
water
monitoring
system
must
submit
a
monitoring
plan
(
§
265.90(
d)(
1)),
as
well
as
initial
and
periodic
reports
on
ground­
water
quality
as
required
under
sections
265.90(
d)(
3)
and
(
5),
and
must
maintain
a
record
of
all
ground­
water
quality
assessments
at
the
facility.
Facilities
planning
to
implement
an
alternate
hydraulically
downgradient
monitoring
well
location
must
meet
certain
criteria,
make
and
a
submit
a
demonstration
and
obtain
a
certification
from
a
qualified
ground­
water
scientist.
The
requirements
for
alternative
ground­
water
monitoring
systems
ensure
that
the
alternative
systems
used
are
capable
of
early
contamination
detection,
and
the
reports
submitted
to
EPA
are
used
to
assess
the
impact
of
the
facility
on
ground­
water
quality.
This
information
contributes
to
EPA's
goal
of
quickly
detecting
and
characterizing
contamination
from
LDFs
in
order
to
minimize
damage
to
human
health
and
the
environment.

Sampling,
Analysis
and
Assessment
EPA
promulgated
regulations
in
40
CFR
265.92
requiring
owners
and
operators
to
develop
and
implement
sampling
and
analysis
procedures
for
identifying
ground­
water
contamination.
The
sampling
and
analysis
plan
must
be
kept
on
file
at
the
facility
and
may
be
reviewed
by
EPA
to
determine
whether
the
procedures
effectively
detect
ground­
water
contamination
(
§
265.92(
a)).
Section
265.93(
d)(
1)
requires
owners
and
operators
to
notify
EPA
in
writing
of
significant
increases
(
or
pH
decreases)
in
indicator
parameter
concentrations
at
downgradient
wells.
Owners
and
operators
of
facilities
where
contamination
is
6
detected
must
develop
and
implement
a
ground­
water
quality
assessment
program,
and
submit
an
initial
assessment
report
(
§
265.93(
d)).
These
requirements
provide
EPA
with
the
information
necessary
to
evaluate
the
impact
of
the
facility
on
ground­
water
quality.
The
sampling,
analysis
and
assessment
requirements
contribute
to
EPA's
goal
of
quickly
detecting
and
characterizing
contamination
from
LDFs
in
order
to
minimize
damage
to
human
health
and
the
environment.

Recordkeeping
and
Reporting
EPA
promulgated
regulations
in
40
CFR
265.94(
a)
establishing
recordkeeping
and
reporting
requirements
for
interim
status
facilities
not
conducting
a
ground­
water
quality
assessment
program.
The
regulations
direct
owners
and
operators
of
these
facilities
to
keep
records
of
initial
background
data,
annual
and
semi­
annual
ground­
water
quality
and
indicator
parameter
analyses,
and
ground­
water
surface
elevation
data.
A
record
of
subsequent
indicator
parameter
comparisons
with
background
levels
is
also
required.
Reports
included
under
this
section
include
a
quarterly
report
on
drinking
water
suitability
parameters
during
the
first
year,
and
annual
reports
on
indicator
parameters
and
variances
from
background
concentrations,
and
an
annual
report
on
ground­
water
surface
elevations.

40
CFR
265.94(
b)
establishes
recordkeeping
and
reporting
requirements
for
facilities
conducting
ground­
water
quality
assessment
programs.
Owners
and
operators
of
these
facilities
are
required
to
keep
records
of
analyses
and
evaluations
conducted
under
the
program,
and
to
submit
annual
assessment
reports
to
the
Regional
Administrator.

The
records
required
under
this
section
provide
owners
and
operators
with
the
information
necessary
to
evaluate
changes
in
ground­
water
quality
at
their
facilities
over
time.
The
reporting
requirements
supply
EPA
with
the
information
necessary
to
determine
the
impact
of
the
facility
on
groundwater
quality.
These
recordkeeping
and
reporting
requirements
contribute
to
EPA's
goal
of
preventing
undetected
releases
of
hazardous
waste
from
treatment,
storage
and
disposal
facilities.

2(
b)
USE
AND
USERS
OF
THE
DATA
PERMITTED
FACILITIES
Detection
Monitoring
Records
of
ground­
water
analytical
data
are
used
primarily
by
owners
and
operators
in
determining
whether
their
facilities
are
contaminating
ground­
water.
Notifications
of
detected
contamination
are
used
by
EPA
to
identify
facilities
that
warrant
closer
attention,
and
as
a
basis
for
evaluating
plans
for
compliance
monitoring
programs
at
these
facilities.
EPA
uses
data
justifying
ACLs
to
determine
whether
the
new
limits
requested
by
owners
and
operators
at
a
contaminated
facility
are
appropriate,
and
uses
engineering
feasibility
plans
for
corrective
action
to
determine
whether
the
proposed
corrective
action
program
will
be
effective
at
the
contaminated
facility.
Demonstrations
submitted
under
this
section
are
used
by
owners
and
operators
to
obtain
exemptions
from
the
burden
of
conducting
further
monitoring
or
corrective
action
activities
for
contamination
which
is
unrelated
to
activities
at
the
facility.
7
Compliance
Monitoring
Records
of
ground­
water
analytical
data
required
under
the
compliance
monitoring
program
are
used
primarily
by
owners
and
operators
in
determining
the
extent
of
ground­
water
contamination,
and
in
identifying
exceeded
concentration
limits
or
new
constituents.
Notifications
of
new
constituents
are
used
by
EPA
in
updating
the
facility
monitoring
requirements
so
that
all
constituents
are
carefully
monitored.
EPA
uses
notifications
of
exceeded
concentration
limits
to
learn
as
much
as
possible
about
the
ground­
water
impact
of
each
contaminated
facility,
and
as
a
basis
for
evaluating
plans
for
corrective
action.
Demonstrations
submitted
under
this
section
are
used
by
owners
and
operators
to
obtain
exemptions
from
the
burden
of
conducting
corrective
action
for
contamination
which
is
unrelated
to
activities
at
the
facility.

Corrective
Action
Owners
and
operators
of
some
contaminated
facilities
use
the
exemption
demonstration
submitted
under
this
section
to
establish
lack
of
need
to
implement
a
corrective
action
program.
The
demonstration
required
to
terminate
corrective
action
is
used
by
EPA
to
evaluate
the
need
for
continued
efforts
where
corrective
action
has
already
been
instituted,
and
by
owners
and
operators
to
justify
such
termination.
Reports
on
the
effectiveness
of
corrective
action
are
used
by
both
EPA
and
owners
and
operators
to
evaluate
the
success
of
corrective
action
and
identify
any
improvements
which
can
be
made
to
the
program.

INTERIM
STATUS
FACILITIES
Applicability
and
Alternative
Ground­
Water
Monitoring
Systems
The
exemption
demonstrations
provided
under
this
section
are
used
by
owners
and
operators
of
interim
status
facilities
to
minimize
their
monitoring
burden,
provided
that
their
facilities
pose
little
or
no
threat
to
ground­
water
quality.
Plans
for
an
alternative
ground­
water
monitoring
system
are
used
by
owners
and
operators
of
some
facilities
as
a
guideline
for
conducting
ground­
water
quality
analyses.
The
alternative
ground­
water
monitoring
plan
is
reviewed
by
EPA
to
determine
whether
it
is
appropriate
for
the
specific
facility,
and
the
terms
of
the
plan
are
enforceable
against
the
owner
or
operator.
Ground­
water
quality
assessment
reports
and
records
of
analyses
conducted
at
facilities
using
alternative
systems
are
used
by
owners,
operators
and
EPA
to
determine
the
impact
of
these
facilities
on
ground­
water
quality,
and
to
identify
any
changes
which
should
be
made
to
the
alternative
ground­
water
monitoring
program.
Alternate
downgradient
well
locations
give
some
facilities
flexibility
in
placing
ground­
water
monitoring
wells.
The
demonstrations
allow
EPA
to
assure
that
these
alternate
well
locations
will
not
adversely
threaten
groundwater
quality.

Sampling,
Analysis
and
Assessment
The
ground­
water
sampling
and
analysis
plan
required
under
this
section
is
used
primarily
by
owners
and
operators
as
a
guideline
for
determining
whether
their
facilities
are
leaking.
Although
the
sampling
and
analysis
plan
is
not
formally
submitted
to
EPA,
it
may
be
reviewed
by
EPA
at
any
time
to
determine
whether
it
is
appropriate
for
identifying
and
evaluating
ground­
water
contamination
at
the
facility.
The
terms
of
the
plan
are
enforceable
against
the
owner
or
operator.
Notifications
of
increased
indicator
parameter
concentrations
are
used
by
EPA
to
identify
facilities
requiring
ground­
water
quality
assessment
plans.
The
plan
is
used
primarily
as
a
guideline
for
owners
and
operators
in
determining
the
extent
of
ground­
water
contamination.
Reports
on
ground­
water
quality
are
used
both
by
owners
and
8
operators
and
by
EPA
to
evaluate
the
degree
of
ground­
water
contamination
and
the
extent
of
contaminant
migration.

Recordkeeping
and
Reporting
The
recordkeeping
requirements
under
section
265.90(
a)
require
owners
and
operators
of
facilities
not
conducting
ground­
water
quality
assessment
programs
to
keep
records
of
initial
background
data;
subsequent
analyses
of
ground­
water
quality
and
indicator
parameters;
ground­
water
surface
elevations;
indicator
parameter
comparisons
with
background
levels;
and
ground­
water
quality
assessment
data.
These
records
are
used
primarily
by
owners
and
operators,
but
may
also
be
reviewed
by
EPA
upon
request.
Background
data
are
used
as
a
baseline
for
evaluations
of
ground­
water
quality.
Subsequent
analyses
and
comparisons
with
background
levels
are
used
by
owners
and
operators
to
identify
leaking
contaminants.
Records
of
ground­
water
surface
elevations
assist
owners
and
operators
in
determining
whether
monitoring
samples
are
being
drawn
from
appropriately
located
wells.
Records
required
in
this
section
also
provide
an
ongoing
history
of
ground­
water
quality
at
the
facility,
which
is
important
because
changes
in
ground­
water
quality
may
occur
slowly
over
time.

Reports
on
drinking
water
suitability
parameters
submitted
during
the
first
year
are
used
by
EPA
to
identify
facilities
which
may
already
be
contaminating
ground
water
and
to
establish
priorities
for
issuing
permits.
Reports
on
indicator
parameters
are
used
by
EPA
to
evaluate
the
impact
of
the
facility
on
ground­
water
quality
and
to
identify
facilities
where
further
investigation
or
action
is
warranted.
Reports
on
ground­
water
surface
elevations
are
used
by
EPA
to
confirm
that
monitoring
wells
are
appropriately
placed.

The
recordkeeping
requirements
of
section
265.90(
b)
require
owners
and
operators
of
facilities
conducting
ground­
water
quality
assessments
to
record
and
report
on
information
collected
during
the
assessments.
The
records
and
reports
are
used
by
owners
and
operators
and
EPA,
respectively,
to
evaluate
the
impact
of
facilities
on
ground­
water
quality.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
NONDUPLICATION
RCRA
is
currently
the
sole
Federal
statutory
vehicle
for
protecting
ground­
water
quality
from
the
effects
of
the
hazardous
waste
TSDFs
for
which
this
monitoring
is
being
required.
Pursuant
to
the
Clean
Water
Act,
standards
have
been
established
for
maintaining
surface
water
quality;
however,
that
Act
has
limited
jurisdiction
over
ground­
water,
and
the
implementation
of
the
Act
has
only
sought
to
protect
against
ground­
water
contamination
by
activities
such
as
sewage
treatment
and
related
sludge
disposal.
The
requirements
of
RCRA
thus
provide
the
only
means
for
gathering
information
to
use
in
determining
the
ground­
water
quality
impacts
of
the
regulated
facilities.
Most
of
the
information
required
by
RCRA
is
not
available
from
any
source
but
the
respondents.

3(
b)
PUBLIC
NOTICE
9
3(
c)
CONSULTATIONS
EPA
consulted
with
EPA
Region
4
Remediation
Cost
Estimating
expert,
Robert
Stewart,
who
indicated
there
have
not
been
significant
changes
in
GWM
costs
over
the
last
three
years.
EPA
checked
sampling
analyses
cost
tables
from
the
R.
S.
Means
Cost
Estimating
Guide,
used
by
industry
for
changes
in
sampling
costs
between
2001
and
2004.
The
changes
in
analytical
costs
for
a
several
organic
and
inorganic
analyses
in
water
varied
between
9
and
11%.
Because
there
did
not
appear
to
be
dramatic
changes
in
costs,
and
EPA
chose,
to
apply
the
national
average
cost
index
of
1.078
to
the
2001
ICR
cost
estimates
instead
of
recalculating.
This
cost
index
multiplier
was
taken
from
the
U.
S.
Department
of
Labor
Bureau
of
Labor
Statistics
Consumer
Price
Index,
and
represents
the
change
from
December
2001
through
November
2004.

3(
d)
EFFECTS
OF
LESS
FREQUENT
COLLECTION
Collecting
these
data
less
frequently
would
hinder
the
Agency
in
promptly
identifying
facilities
that
may
be
discharging
hazardous
wastes
or
constituents
to
ground­
water.
Thus,
Agency
action
to
require
remediation
for
the
protection
of
potential
ground­
water
users
would
be
hampered
or
delayed.
If
contamination
problems
are
allowed
to
proliferate
and
persist
unremediated,
the
potential
cost
of
future
remediation
may
grow
substantially.
Additionally,
for
facilities
which
are
known
to
be
discharging
hazardous
wastes
to
ground­
water,
a
reduction
in
the
information
collection
requirements
would
seriously
impair
the
Agency's
ability
to
assess
the
rate
of
movement
and
extent
of
contamination
from
discharging
facilities.

3(
e)
GENERAL
GUIDELINES
Requirements
and
justification
for
reporting
information
to
the
Agency
more
often
than
quarterly
are
discussed
under
Section
4(
d).
Collection
activities
that
must
be
prepared
in
less
than
30
days
are
also
discussed
in
Section
4(
d).
Sections
265.94(
a)(
1)
and
265.94(
b)(
1)
require
the
maintenance
of
records
throughout
the
active
life
of
the
facility
and,
for
disposal
facilities,
throughout
the
post­
closure
care
period
as
well.
These
records
provide
a
baseline
for
determining
the
presence
and
concentration
of
hazardous
releases
to
ground­
water,
and
provide
a
means
to
assess
the
effects
of
the
facility
on
ground­
water
throughout
its
active
life.
Without
these
records,
the
impact
of
the
facility
on
the
ground­
water
beneath
and
adjacent
to
it
cannot
be
ascertained.

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

3(
g)
SENSITIVE
QUESTIONS
No
questions
of
a
sensitive
nature
are
included
in
any
of
the
information
collection
requirements.
10
4.
THE
RESPONDENTS
AND
THE
INFORMATION
COLLECTED
4(
a)
Respondents
and
SIC
Codes
Following
are
the
Standard
Industrial
Classification
(
SIC)
codes
and
the
North
American
Industry
Classification
System
(
NAICS)
codes
of
facilities
most
likely
subject
to
the
requirements
in
this
ICR.

Description
SIC
Codes
NAICS
Codes
Industrial
Inorganic
Chemicals
281
32518,
32513
Plastic
materials,
Synthetic
Resins,
etc.
282
3252
Drugs
283
3254
Soaps,
Detergents,
etc.
284
3256
Paints,
Varnishes,
etc.
285
32551
Industrial
Organic
Chemicals
286
32511,
32512,
32519
Miscellaneous
Chemical
Products
289
3255
Petroleum
291
324199
Metal
Working
330
331
Sanitary
Services
495
5622,
5629
4(
b)
Information
Collected
PERMITTED
FACILITIES
Reading
the
Regulations
(
i)
Data
items:

There
are
no
data
items
associated
with
reading
the
regulations.
However,
respondents
must
first
read
the
regulations
in
order
to
comply
with
ground­
water
monitoring
requirements.

(
ii)
Respondent
activities:

In
order
to
comply
with
the
ground­
water
monitoring
requirements,
respondents
must
perform
the
following
activities:

!
Read
the
regulations.

Ground­
water
Monitoring
System
11
(
i)
Data
items:

There
are
no
data
items
associated
with
implementing
a
ground­
water
monitoring
system.
However,
respondents
must
implement
a
ground­
water
monitoring
system
in
order
to
comply
with
groundwater
monitoring
requirements.

(
ii)
Respondent
activities:

In
order
to
implement
a
ground­
water
monitoring
system,
respondents
must
perform
the
following
activities:

!
Conduct
a
hydrogeologic
investigation;
and
!
Design
and
install
a
ground­
water
monitoring
system.

Detection
Monitoring
(
i)
Data
items:

Owners
and
operators
required
to
perform
detection
monitoring
must
provide
the
following
data:

!
A
record
of
ground­
water
analytical
data
as
measured
and
in
a
form
necessary
for
the
determination
of
statistical
significance,
as
required
by
§
264.98(
c);

!
Notification
to
the
Regional
Administrator
within
seven
days
of
statistically
significant
evidence
of
contamination,
including
information
on
chemical
parameters
or
hazardous
constituents,
as
required
by
§
264.98(
g)(
1);

!
All
data
necessary
to
justify
an
alternate
concentration
limit
if
sought
under
§
264.94(
b),
submitted
within
180
days
of
confirmation
of
a
release
of
hazardous
constituents
to
ground­
water,
as
required
by
§
264.98(
g)(
5)(
i);

!
An
engineering
feasibility
plan
for
a
corrective
action
program,
submitted
within
180
days
of
confirmation
of
a
release
of
hazardous
constituents
to
ground­
water,
as
required
by
§
264.98(
g)(
5)(
ii);

!
To
demonstrate
that
contamination,
if
detected,
is
caused
by
a
source
other
than
a
regulated
unit
or
by
an
error
in
sampling,
analysis,
statistical
evaluation
or
natural
variation
in
the
ground­
water,
as
required
by
§
264.98(
g)(
6);

­
A
notification
to
the
Regional
Administrator,
submitted
within
seven
days
of
detection,
of
intent
to
make
such
a
demonstration.

­
A
report
to
EPA,
submitted
within
90
days
of
the
notification,
demonstrating
that
the
exceeded
standards
were
caused
by
a
source
other
than
a
regulated
unit
or
by
an
error
in
sampling,
analysis,
or
evaluation.
12
(
ii)
Respondent
activities:

In
order
to
provide
the
data
items
listed
above,
respondents
must
perform
the
following
activities:

!
Determine
the
ground­
water
flow
rate
and
direction
(
annually);

!
Sample
and
analyze
ground­
water
(
semi­
annually);

!
Record
ground­
water
analytical
data
at
the
facility
(
semi­
annually);

!
Prepare
and
submit
the
notification
of
contamination;

!
Re­
sample
and
analyze
ground­
water
for
Appendix
IX
constituents;

!
Compile
and
submit
data
necessary
to
establish
an
alternate
concentration
limit;

!
Prepare
and
submit
an
engineering
feasibility
plan
for
corrective
action;

!
Prepare
and
submit
notification
of
intent
to
make
a
demonstration
of
error
or
contamination
from
another
source;
and
!
Prepare
and
submit
the
demonstration.

Compliance
Monitoring
(
i)
Data
items:

Owners
and
operators
required
to
perform
compliance
monitoring
must
provide
the
following
data:

!
A
record
of
all
ground­
water
analytical
data
obtained
under
the
compliance
monitoring
program
as
measured
and
in
a
form
necessary
for
the
determination
of
statistical
significance
by
§
264.99(
c)(
2);

!
Notification,
submitted
to
the
Regional
Administrator
within
seven
days
of
initial
or
confirmed
analysis,
of
the
presence
of
new
constituents
in
ground­
water
not
already
identified
in
the
facility
permit,
and
their
concentrations,
as
required
by
§
264.99(
g);

!
Notification,
submitted
to
the
Regional
Administrator
within
seven
days
of
detection,
that
concentration
limits
under
§
264.94
are
being
exceeded
at
any
monitoring
well,
as
required
by
§
264.99(
h)(
1);

!
To
demonstrate
that
contamination,
if
detected,
is
caused
by
a
source
other
than
a
regulated
unit
or
by
an
error
in
sampling,
analysis,
statistical
evaluation
or
natural
variation
in
the
ground­
water,
as
required
by
§
264.99(
i):

­
A
notification
to
the
Regional
Administrator,
submitted
within
seven
days
of
detection,
of
intent
to
make
such
a
demonstration.
13
­
A
report,
submitted
within
90
days
of
the
notification,
demonstrating
that
the
exceeded
standards
were
caused
by
a
source
other
than
a
regulated
unit
or
by
an
error
in
sampling,
analysis,
or
evaluation.

(
ii)
Respondent
activities:

In
order
to
provide
the
data
items
listed
above,
respondents
must
perform
the
following
activities:

!
Determine
the
ground­
water
flow
rate
and
direction
(
annually);

!
Sample
and
analyze
ground­
water
(
semi­
annually);

!
Record
ground­
water
analytical
data
at
the
facility
(
semi­
annually).

!
Compile
information
for
notification
of
new
constituents;

!
Prepare
and
submit
the
notification
of
new
constituents;

!
Compile
information
on
exceeded
concentration
limits;

!
Prepare
and
submit
the
notification
of
exceeded
concentration
limits;

!
Prepare
and
submit
a
notification
of
intent
to
make
a
demonstration
of
error
or
contamination
from
another
source;
and
!
Prepare
and
submit
the
demonstration.

Corrective
Action
(
i)
Data
items:

Owners
and
operators
required
to
perform
corrective
action
must
provide
the
following
data:

!
To
obtain
an
exemption
from
the
requirements
to
take
corrective
action
beyond
the
facility's
boundary,
a
demonstration
that
the
owner
or
operator
was
unable
to
obtain
the
necessary
permission
to
undertake
such
corrective
action,
despite
his
or
her
best
efforts,
as
required
by
§
264.100(
e)(
2);

!
To
terminate
corrective
action,
a
demonstration,
as
required
by
§
264.100(
f)
that
the
ground­
water
protection
standard
has
not
been
exceeded
for
a
period
of
three
consecutive
years;

!
A
semi­
annual
report
on
the
effectiveness
of
the
corrective
action
program,
as
required
by
§
264.100(
g);
and
(
ii)
Respondent
activities:
14
In
order
to
provide
the
data
items
listed
above,
respondents
must
perform
the
following
activities:

!
Design
and
install
additional
ground­
water
monitoring
wells;

!
Sample
and
analyze
ground­
water
(
semi­
annually);

!
Record
ground­
water
analytical
data
at
the
facility
(
semi­
annually);

!
Compile
and
submit
information
for
the
demonstration
for
exemption
from
corrective
action;

!
Compile
and
submit
information
for
the
demonstration
for
termination
of
corrective
action;

!
Develop
and
submit
to
EPA
a
semi­
annual
report
on
the
effectiveness
of
the
program.

INTERIM
STATUS
FACILITIES
Reading
the
Regulations
(
i)
Data
items:

There
are
no
data
items
associated
with
regulations.
However,
respondents
must
first
read
the
regulations
in
order
to
comply
with
ground­
water
monitoring
requirements.

(
ii)
Respondent
activities:

In
order
to
comply
with
the
ground­
water
monitoring
requirements,
respondents
must
perform
the
following
activities:

!
Read
the
regulations.

Applicability
and
Alternative
Ground­
Water
Monitoring
Systems
(
i)
Data
items:

Section
265.90
establishes
the
applicability
of
the
ground­
water
monitoring
requirements
at
interim
status
facilities,
and
discusses
requirements
for
alternative
ground­
water
monitoring
systems.
Data
items
required
under
these
regulations
include:

!
A
demonstration,
necessary
in
order
to
waive
all
or
part
of
the
ground­
water
monitoring
requirements,
of
low
potential
for
migration
of
hazardous
waste
or
hazardous
waste
constituents
from
the
facility
through
the
uppermost
aquifer
to
water
supply
wells
or
surface
water
(
§
265.90
(
c)).
This
demonstration
must
be
kept
in
writing
at
the
facility
and
must
be
certified
by
a
qualified
geologist
or
geotechnical
engineer.
The
demonstration
must
establish
the
following:
15
­
The
potential
for
migration
of
hazardous
waste
or
hazardous
waste
constituents
from
the
facility
to
the
uppermost
aquifer
by
an
evaluation
of
water
balance
and
unsaturated
zone
characteristics;
and
­
The
potential
for
hazardous
waste
or
hazardous
waste
constituents
which
enter
the
uppermost
aquifer
to
migrate
to
a
water
supply
well
or
surface
water
by
an
evaluation
of
saturated
zone
characteristics
and
the
proximity
of
the
facility
to
water
supply
wells
or
surface
water;

!
A
demonstration,
necessary
in
order
to
waive
the
ground­
water
monitoring
requirements
for
certain
surface
impoundments,
that
establishes,
based
upon
consideration
of
the
characteristics
of
the
wastes
and
the
impoundment,
that
the
corrosive
wastes
will
be
neutralized
to
the
extent
that
they
no
longer
meet
the
corrosivity
characteristic
before
they
can
migrate
out
of
the
impoundment.
This
demonstration
must
be
in
writing
and
must
be
certified
by
a
qualified
professional
(
§
265.90(
e));

!
If
necessary,
a
specific
plan
for
an
alternative
ground­
water
monitoring
system,
certified
by
a
qualified
geologist
or
geotechnical
engineer
and
submitted
to
the
Regional
Administrator
within
one
year
after
the
effective
date
of
the
regulations
or
within
one
year
of
obtaining
interim
status
(
§
265.90(
d)(
1));

!
If
an
alternative
ground­
water
monitoring
system
is
used,
a
written
report
containing
an
assessment
of
ground­
water
quality
submitted
to
the
Regional
Administrator
within
15
days
of
the
initial
assessment,
followed
by
annual
reports
submitted
by
March
1
following
each
calendar
year
(
§
265.90(
d)(
3)
and
(
5));
and
!
For
alternative
systems,
a
record
of
the
analyses
conducted
to
determine
ground­
water
quality
under
§
265.90(
d)(
3)
to
be
kept
throughout
the
active
life
of
the
facility,
and,
for
disposal
facilities
throughout
the
post­
closure
period
as
well
(
§
265.90(
d)(
5)).

!
For
alternate
hydraulically
downgradient
monitoring
well
locations,
a
demonstration
showing
that
the
location
will
meet
the
criteria
outlined
in
§
265.91(
a)(
3)
and
a
certification
by
a
qualified
ground­
water
scientist
that
(
ii)
Respondent
Activities:

In
order
to
provide
the
data
items
listed
above,
respondents
must
perform
the
following
activities:

!
Develop
and
submit
the
demonstrations;

!
Maintain
records
of
the
demonstrations;

!
Compile
information
for
an
alternative
ground­
water
monitoring
plan;

!
Obtain
certification;

!
Develop
and
submit
the
plan;
16
!
Compile
information
for
the
ground­
water
quality
assessment
reports;

!
Develop
and
submit
the
reports;

!
Maintain
a
record
of
the
ground­
water
quality
assessment
data
(
quarterly);

!
Develop
and
submit
the
demonstration
for
an
alternate
well
location
;
and
!
Maintain
records
of
the
demonstration.

Sampling,
Analysis
and
Assessment
(
i)
Data
items:

Sections
265.92
and
265.93
require
owners
and
operators
of
interim
status
facilities
to
conduct
sampling,
analysis
and
assessment
to
identify
and
evaluate
changes
in
the
concentrations
of
hazardous
constituents
in
ground
water.
Data
items
required
under
these
regulations
include:

!
Development
of
a
ground­
water
sampling
and
analysis
plan,
which
must
be
kept
at
the
facility.
The
plan
must
include
procedures
and
techniques
for
sample
collection,
sample
preservation
and
shipment,
analytical
procedures,
and
chain
of
custody
control
(
§
265.92(
a));

!
If
there
is
a
confirmed
significant
increase
(
or
pH
decrease)
in
indicator
parameter
concentrations
in
downgradient
wells,
a
written
notification
to
the
Regional
Administrator
within
seven
days
that
the
facility
may
be
affecting
ground­
water
quality
(
§
265.93(
d)(
1));

!
If
there
is
a
confirmed
significant
increase
(
or
pH
decrease)
of
indicator
parameter
concentrations
in
downgradient
wells,
a
specific
plan
to
be
submitted
to
the
Regional
Administrator
within
15
days
after
the
notification
for
a
ground­
water
quality
assessment
program
at
the
facility
(
§
265.93(
d)(
2)).
This
plan
must
be
certified
by
a
qualified
geologist
or
geotechnical
engineer,
and
must
specify:

­
The
number,
location,
and
depth
of
the
wells;

­
Sampling
and
analytical
methods
for
those
hazardous
waste
constituents
in
the
facility;

­
Evaluation
procedures,
including
any
use
of
previously
gathered
ground­
water
quality
information;
and
­
A
schedule
of
implementation;

!
A
written
report
containing
an
assessment
of
ground­
water
quality
submitted
to
the
Regional
Administrator
within
15
days
after
it
is
determined
(
§
265.93(
d)(
5)).
If
the
indicator
evaluation
program
is
reinstated,
this
information
must
also
be
included
in
this
ground­
water
quality
assessment
report
(
§
265.93(
d)(
6));
and
17
!
A
written
report
of
any
ground­
water
quality
assessment
conducted
to
satisfy
the
requirements
of
§
264.93(
d)(
4)
which
is
initiated
prior
to
final
closure
of
the
facility.
The
report
must
be
submitted
to
the
Regional
Administrator
within
15
days
after
the
assessment
is
completed
and
reported
in
accordance
with
§
265.93(
d)(
5)
(
§
265.93(
e)).

(
ii)
Respondent
activities:

In
order
to
provide
the
data
items
listed
above,
respondents
must
perform
the
following
activities:

!
Conduct
a
hydrogeologic
investigation;

!
Design
and
install
ground­
water
monitoring
system;

!
Compile
information
for
a
written
sampling
and
analysis
plan;

!
File
the
plan
at
the
facility;

!
Prepare
a
ground­
water
quality
assessment
plan
outline;

!
Compile
and
submit
notification;

!
Develop
and
submit
the
ground­
water
quality
assessment
plan;

!
Develop
and
submit
the
initial
ground­
water
quality
assessment
report;

!
Prepare
and
submit
report
of
any
ground­
water
quality
assessment
initiated
prior
to
final
closure;

!
Conduct
quarterly
sampling
and
analysis
of
ground­
water
to
determine
ground­
water
quality
under
alternate
ground­
water
monitoring
system;

!
Conduct
semi­
annual
sampling
and
analysis
of
ground­
water
to
obtain
ground­
water
analytical
data;
and
!
Conduct
quarterly
sampling
and
analysis
as
part
of
a
ground­
water
quality
assessment
program.

Recordkeeping
and
Reporting
(
i)
Data
items:

Section
265.94
outlines
specific
recordkeeping
and
reporting
requirements
for
owners
and
operators
of
interim
status
facilities.
Owners
and
operators
of
interim
status
facilities
that
are
not
required
to
implement
a
ground­
water
quality
assessment
program
under
§
265.93(
d)(
4)
must
perform
reporting
and
recordkeeping
activities
throughout
the
active
life
of
the
facility,
and
for
disposal
facilities
that
do
not
clean
close,
throughout
the
post­
closure
care
period
as
well
(
§
265.94(
a)).
Required
data
items
include:
18
!
A
record
of
information
required
under
§
265.94(
a)(
1),
including:

­
Initial
background
concentrations
or
values
for
ground­
water
quality
parameters
at
all
monitoring
wells
as
calculated
under
§
265.92(
c)(
1);

­
The
initial
arithmetic
mean
and
variance
for
indicator
parameters
as
calculated
under
§
265.92(
c)(
2);

­
Annual
analyses
of
parameters
used
to
establish
ground­
water
quality
and
semiannual
analyses
of
indicators
of
ground­
water
contamination
as
determined
under
§
§
265.92(
d)(
1)
and
(
2);

­
Ground­
water
elevation
as
determined
under
§
265.92(
e);

­
Subsequent
calculations
of
arithmetic
means
and
variances
for
each
indicator
parameter
at
each
well
monitored,
and
comparisons
with
background
means
to
determine
statistically
significant
increases
(
or
pH
decreases)
over
initial
background
concentrations
during
the
contamination
indication
program
as
calculated
under
§
265.93(
b);

!
A
report
to
the
Regional
Administrator,
during
the
first
year
when
initial
background
concentrations
are
being
established
for
the
facility,
of
concentrations
or
values
of
parameters
characterizing
the
suitability
of
the
ground
water
as
a
drinking
water
supply
for
each
ground­
water
monitoring
well
(
§
265.92(
b)(
1))
within
15
days
after
completing
each
quarterly
analysis,
and
an
identification
of
any
parameters
whose
concentration
or
value
has
been
found
to
exceed
the
maximum
contaminant
levels
listed
in
Appendix
III
(
§
265.94(
a)(
2)(
i));

!
An
annual
report
to
the
Regional
Administrator,
submitted
by
March
1
following
each
calendar
year,
on
concentrations
or
values
of
the
indicator
parameters
listed
in
§
265.92(
b)(
3)
for
each
monitoring
well,
as
well
as
the
required
evaluations
for
these
parameters
as
calculated
under
§
265.93(
b).
Also,
a
separate
identification
of
any
statistically
significant
differences
from
initial
background
concentrations
found
in
the
upgradient
wells
as
calculated
under
§
265.93(
b)
and
required
by
§
265.93(
c)(
1)
(
§
265.94(
a)(
2)(
ii));
and
!
A
report
to
the
Regional
Administrator,
submitted
by
March
1
following
each
calendar
year,
of
the
results
of
the
evaluations
of
ground­
water
surface
elevations
under
§
265.93(
f)
and
a
description
of
the
response
to
that
evaluation
where
applicable
(
§
265.94(
a)(
2)(
iii)).

Owners
and
operators
of
facilities
conducting
a
ground­
water
quality
assessment
program
under
§
265.93(
d)(
4)
are
required
to
provide
the
following
data
items:

!
A
record
of
analyses
and
evaluations
specified
in
the
assessment
plan
required
under
265.93(
d)(
3)
throughout
the
active
life
of
the
facility,
and,
for
disposal
facilities,
throughout
the
post­
closure
care
period
(
§
265.94(
b)(
1));
19
!
An
annual
report,
submitted
to
the
Regional
Administrator
no
later
than
March
1
following
each
calendar
year
until
final
closure
of
the
facility,
containing
the
results
of
the
groundwater
quality
assessment
program,
including
the
calculated
or
measured
rate
of
migration
of
hazardous
waste
or
hazardous
waste
constituents
in
the
ground
water
during
the
reporting
period
(
§
265.94(
b)(
2)).

(
ii)
Respondent
activities:

In
order
to
provide
the
data
items
listed
above,
respondents
must
perform
the
following
activities:

!
Record
ground­
water
analytical
data
at
the
facility
(
semi­
annually);

!
Prepare
and
submit
a
quarterly
report
of
concentrations
or
values
of
the
drinking
water
suitability
parameters
(
quarterly);

!
Prepare
and
submit
a
report
on
indicator
parameter
concentrations
(
annually);

!
Prepare
and
submit
a
report
of
any
significant
indicator
parameter
increases
(
or
pH
decreases)
in
upgradient
wells;

!
Prepare
and
submit
a
report
on
ground­
water
surface
elevations
(
annually);

!
Record
ground­
water
quality
assessment
data
(
quarterly);
and
!
Prepare
and
submit
a
report
on
the
ground­
water
quality
assessment
program.

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
PERMITTED
FACILITIES
Detection
and
Compliance
Monitoring
Agency
activities
associated
with
the
detection
and
compliance
monitoring
requirements
include
reviewing
notifications
and
demonstrations
and
entering
information
into
a
data
base.
The
detection
monitoring
requirements
also
require
EPA
to
evaluate
ACL
data
and
engineering
feasibility
plans
for
corrective
action
submitted
under
section
264.98(
g)(
5)
to
determine
whether
the
proposed
ACLs
and
corrective
action
programs
are
appropriate,
and
to
enter
information
into
a
data
base.
Records
of
groundwater
analytical
data
required
under
sections
264.98(
c)
and
264.99(
c)(
2)
are
not
formally
submitted
to
EPA,
but
must
be
kept
on
file
at
the
facility
and
made
available
to
EPA
upon
request.
Accordingly,
this
analysis
assumes
that
there
are
no
Agency
activities
associated
with
these
recordkeeping
requirements.
20
Corrective
Action
Agency
activities
associated
with
the
corrective
action
requirements
include
reviewing
demonstrations,
evaluating
reports
on
the
effectiveness
of
corrective
action,
and
entering
the
information
into
a
data
base.

INTERIM
STATUS
FACILITIES
Applicability
and
Alternative
Ground­
Water
Monitoring
Systems
Agency
activities
associated
with
applicability
and
alternative
ground­
water
monitoring
systems
include
reviewing
demonstrations,
alternative
ground­
water
monitoring
plans,
ground­
water
quality
assessment
reports
and
alternate
well
location
demonstrations,
and
entering
information
into
a
data
base.
The
records
required
under
this
section
are
not
formally
submitted
to
EPA
but
must
be
filed
at
the
facility
and
made
available
upon
request
for
EPA
review.
Accordingly,
this
analysis
assumes
that
there
are
no
Agency
activities
associated
with
these
recordkeeping
requirements.

Sampling,
Analysis
and
Assessment
Agency
activities
associated
with
the
sampling,
analysis
and
assessment
requirements
include
reviewing
the
notification
of
increased
indicator
parameter
concentrations,
evaluating
the
ground­
water
quality
assessment
plan
and
initial
reports,
and
entering
information
into
a
data
base.
Although
EPA
may
review
the
sampling
and
analysis
plan
required
under
this
section,
the
plan
is
not
formally
submitted
to
EPA.
Therefore,
there
is
no
Agency
activity
associated
with
this
requirement.

Recordkeeping
and
Reporting
Agency
activities
associated
with
the
reporting
requirements
of
this
section
include
reviewing
the
information
submitted
and
entering
the
information
into
a
database.
Records
required
under
this
section
are
not
formally
submitted
to
EPA.
Therefore,
there
are
no
Agency
activities
associated
with
these
recordkeeping
requirements
under
this
section.

5(
b)
COLLECTION
METHODOLOGY
AND
MANAGEMENT
In
collecting
and
analyzing
the
information
required
under
the
ground­
water
monitoring
regulations,
EPA
uses
state­
of­
the­
art
electronic
equipment
such
as
personal
computers
and
applicable
data
base
software,
when
appropriate.

5(
c)
SMALL
ENTITY
FLEXIBILITY
The
burden
imposed
by
the
ground­
water
monitoring
requirements
is
a
function
of
the
threat
of
contamination
of
ground­
water,
from
which
many
people
derive
their
drinking
water,
and
is
not
sensitive
to
the
size
of
the
organization.
Therefore,
small
entities
must
comply
with
the
same
requirements
as
large
entities.
21
5(
d)
COLLECTION
SCHEDULE
PERMITTED
FACILITIES
Detection
Monitoring
Since
records
of
ground­
water
analytical
data
collected
under
detection
monitoring
are
kept
at
the
facility,
discussion
of
a
collection
schedule
is
not
applicable.
Notification
of
statistically
significant
evidence
of
contamination
must
be
submitted
within
seven
days
of
the
initial
or
confirmed
detection.
If
an
alternate
concentration
limit
is
sought
under
section
264.94(
b),
the
data
necessary
to
justify
the
alternate
concentration
limit,
along
with
the
required
engineering
feasibility
plan
for
a
corrective
action
program,
must
be
submitted
within
180
days
of
the
initial
or
confirmed
detection.
If
the
owner
or
operator
plans
to
make
a
demonstration
under
section
264.98(
g)(
6),
the
notification
of
intent
to
make
such
a
demonstration
must
be
submitted
within
seven
days
of
detection,
and
the
demonstration
submitted
within
90
days
of
detection.

Compliance
Monitoring
Since
records
of
ground­
water
analytical
data
collected
under
compliance
monitoring
are
kept
at
the
facility,
discussion
of
a
collection
schedule
is
not
applicable.
Notification
of
the
presence
of
new
constituents
or
exceeded
concentration
limits
must
be
submitted
within
seven
days
of
detection.
If
the
owner
or
operator
plans
to
make
a
demonstration
under
section
264.99(
i),
the
notification
of
intent
to
make
such
demonstration
must
be
submitted
within
seven
days
of
detection,
and
the
demonstration
report
submitted
within
90
days
of
detection.

Corrective
Action
The
time
frame
for
submission
of
demonstrations
under
sections
264.100(
e)(
2)
and
264.100(
f)
is
dependent
upon
the
desire
of
owners
and
operators
to
submit
such
demonstrations.
Reports
on
the
effectiveness
of
the
corrective
action
program
must
be
submitted
semi­
annually.

INTERIM
STATUS
FACILITIES
Applicability
Alternative
Ground­
Water
Monitoring
Systems
The
time
frame
for
submission
of
demonstrations
under
sections
265.90(
c),
265.90(
e),
and
265.91(
a)(
3)
are
dependent
upon
the
desire
of
owners
and
operators
to
submit
such
demonstrations.
If
an
owner
or
operators
seeks
to
implement
an
alternative
ground­
water
monitoring
program,
a
plan
for
the
alternative
program
must
be
submitted
within
one
year
of
obtaining
interim
status.
Ground­
water
quality
assessment
reports
for
alternative
systems
must
be
submitted
within
15
days
of
the
initial
assessment,
and
then
annually
no
later
than
March
1
following
each
calendar
year.
Since
records
of
the
analyses
conducted
under
the
alternative
ground­
water
monitoring
program
are
kept
at
the
facility,
a
discussion
of
a
collection
schedule
is
not
applicable.
22
Sampling,
Analysis
and
Assessment
Since
the
sampling
and
analysis
plan
must
be
kept
at
the
facility
and
made
available
to
the
Regional
Administrator
upon
request,
discussion
of
a
collection
schedule
is
not
applicable.
Notification
of
significant
increases
(
or
pH
decreases)
in
indicator
parameter
concentrations
in
downgradient
wells
must
be
submitted
within
seven
days
of
confirmation.
Plans
for
a
ground­
water
quality
assessment
program
must
be
submitted
within
15
days
of
the
notification.
The
report
of
the
results
of
the
initial
ground­
water
quality
assessment
must
be
submitted
within
15
days
of
determination.
Subsequent
ground­
water
quality
assessment
reports
will
be
submitted
within
15
days
of
determination
at
intervals
outlined
in
the
groundwater
quality
assessment
plan,
which
will
differ
for
each
facility.

Recordkeeping
and
Reporting
Since
the
records
required
under
sections
265.94(
a)(
1)
and
265.94(
b)(
1)
are
kept
at
the
facility,
discussion
of
a
collection
schedule
is
not
applicable.
Reports
of
drinking
water
suitability
parameter
concentrations
and
exceeded
maximum
contaminant
levels
(
MCLs)
must
be
submitted
within
15
days
of
each
quarterly
analysis
conducted
during
the
first
year
of
interim
status
standing,
when
initial
background
levels
are
being
established.
Reports
of
indicator
parameter
concentrations,
variations
from
initial
background
concentrations,
and
ground­
water
surface
elevations
must
be
submitted
annually,
during
the
active
life
of
the
facility,
no
later
than
March
1
following
each
calendar
year.
Owners
and
operators
conducting
a
ground­
water
quality
assessment
program
must
submit
results
of
the
ground­
water
quality
assessment
program
annually
no
later
than
March
1
following
each
calendar
year.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
ESTIMATING
RESPONDENT
BURDEN
Exhibits
1
and
2
identify
the
reporting
and
recordkeeping
activities
and
associated
burden
to
respondents
under
the
ground­
water
monitoring
program.
EPA
relied
on
much
of
the
research
conducted
for
the
2001
GWM
ICR,
updating
estimates
and
assumptions
used
to
develop
the
burden
estimates
in
the
2001
ICR.
For
that
ICR,
EPA
used
many
of
the
estimates
in
the
"
Part
B
Permit
Application,
Permit
Modifications,
and
Special
Permits,"
ICR
number
1573.
The
Part
B
ICR
examines
many
activities
that
are
similar
to
the
activities
in
this
ICR.
EPA
incorporated
the
Part
B
ICR's
burden
assumptions
into
the
2001
ICR,
as
appropriate.
In
addition,
EPA
conducted
limited
consultations
with
industry
to
ascertain
the
burden
to
regulated
entities
and
their
contractors
for
certain
activities
that
are
not
examined
in
the
Part
B
ICR
(
e.
g.,
ground­
water
sampling).
Finally,
EPA
used
its
best
judgment
in
a
few
circumstances
to
develop
burden
estimates
for
regulated
entities
and
contractors
(
e.
g.,
for
notifications
and
other
low­
burden
activities).

6(
b)
ESTIMATING
RESPONDENT
COSTS
Labor
Costs
EPA
referred
to
the
recently
completed
Hazardous
Waste
Generator
Standards
ICR,
(
ICR
#
0820.09)
for
labor
salary
estimates.
EPA
estimates
that
respondents
will
incur
an
average
hourly
cost
(
labor
plus
fringe
and
overhead)
of
$
119.91
for
legal
staff,
$
85.82.
for
managerial
staff,
$
62.30
for
technical
staff,
and
$
31.74
for
clerical
staff.
EPA
used
the
estimates
from
the
2001
GWM
ICR
regarding
23
1
USEPA,
Office
of
Regulatory
Enforcement,
"
Estimating
Costs
for
the
Economic
Benefits
of
Noncompliance,"
March
1997.
Updated
to
2001
levels
using
Consumer
Price
Index.

2
USEPA,
Office
of
Regulatory
Enforcement,
"
Estimating
Costs
for
the
Economic
Benefits
of
Noncompliance,"
March
1997.
Updated
to
2001
levels
using
Consumer
Price
Index.
the
hours
that
are
assigned
to
each
task;
those
estimates,
as
noted
in
section
3(
c)
were
derived
from
consultations
with
industry
representatives
and
from
estimates
developed
for
ICR
number
1573.

Operation
and
Maintenance
(
O&
M)
Costs
O&
M
costs
include
postage,
materials,
and
lump­
sum
purchased
service
costs.
Examples
of
O&
M
costs
include:

!
Laboratory
fees
for
analyzing
ground­
water
samples;

!
Contractor
travel/
lodging
costs;

!
Transportation/
disposal
costs
(
if
required
for
drill
cuttings,
purge
water);

!
Professional
certifications
for
certain
work
performed;

!
Mailing
and
shipping
costs;

!
Software
costs
(
e.
g.,
applications
of
computer­
based
models
for
aquifer
step
drawdown
or
slug
tests,
statistical
analysis
computer
program
for
demonstration);
and
!
Personal
protective
equipment.

Capital
Costs
The
capital/
startup
costs
associated
with
the
ground­
water
monitoring
requirements
are
the
costs
of
designing
and
installing
a
ground­
water
monitoring
system.
For
permitted
facilities,
we
updated
the
estimated
cost
used
for
the
2001
ICR
by
multiplying
it
by
the
cost
index
of
1.0785;
this
cost
is
estimated
to
be
$
142,880.1
Annualized
over
20
years
at
the
OMB­
approved
discount
rate
of
seven
percent,
the
cost
is
about
#
13,400
per
year.
For
interim
status
facilities,
this
cost
is
estimated
to
be
$
48,0702
Annualized
over
20
years
at
the
OMB­
approved
discount
rate
of
seven
percent,
the
cost
is
about
$
4,500
per
year.

In
addition,
the
Agency
estimates
a
cost
for
file
cabinets
of
$
1
for
each
document
filed
at
permitted
and
interim
status
facilities.

6(
c)
ESTIMATING
AGENCY
BURDEN
AND
COSTS
Labor
Costs
24
3
These
universe
data
were
finalized
in
early
2000
based
on
feedback
from
EPA
Regions
1,
2,
3
(
with
the
exception
of
Pennsylvania),
4,
5,
6,
8,
and
10,
and
from
a
query
of
the
RCRIS
database
in
Envirofacts
for
Regions
7
and
9
and
Pennsylvania.
Exhibits
3
and
4
show
the
Agency
burden
hours
and
costs
associated
with
the
reporting
requirements
covered
in
this
ICR.
EPA
derived
these
estimates
using
the2004
General
Schedule
Hourly
Rates
for
DCB.
EPA
applied
a
1.6
fringe/
overhead
multiplier
to
develop
loaded
rates..
EPA
estimates
hourly
labor
costs
of
$
76.85
for
legal
staff,
$
65.33
for
managerial
staff,
$
55.28
for
technical
staff,
and
$
29.02
for
clerical
staff.
For
the
purposes
of
this
ICR,
EPA
assigned
staff
the
following
government
service
levels:

!
Legal
Staff
GS­
15,
Step
1
!
Managerial
Staff
GS­
14,
Step
4
!
Technical
Staff
GS­
12,
Step
5
!
Clerical
Staff
GS­
5,
Step
1
To
derive
hourly
estimates,
EPA
divided
annual
compensation
estimates
by
2,080,
which
is
the
number
of
hours
in
the
Federal
work­
year.
EPA
then
multiplied
the
hourly
rates
by
the
standard
government
overhead
factor
of
1.6.

Operation
and
Maintenance
(
O&
M)
Costs
EPA
does
not
expect
any
O&
M
costs
to
the
Agency
as
a
result
of
these
requirements.

Capital
Costs
EPA
does
not
expect
any
capital
costs
to
the
Agency
as
a
result
of
these
requirements.

6(
d)
ESTIMATING
THE
RESPONDENT
UNIVERSE
AND
TOTAL
BURDEN
AND
COSTS
EPA
does
not
believe
there
are
any
new
facilities
since
2001
that
would
fall
under
the
groundwater
requirements.
Thus,
EPA
used
the
same
universe
estimate
as
the
2001
ICR.
As
shown
in
Table
1,
EPA
estimates
that
there
are
currently
824
land
disposal
facilities
under
the
ground­
water
monitoring
requirements.
This
includes
382
facilities
with
permitted
units
only,
431
facilities
with
interim
status
units
only,
and
11
facilities
with
both
permitted
and
interim
status
units.
For
purposes
of
estimating
burden
in
this
ICR,
EPA
averaged
the
11
facilities
over
both
the
Part
264
and
265
requirements
on
a
50:
50
basis.
Therefore,
this
ICR
estimates
a
total
of
387.5
permitted
facilities
and
436.5
interim
status
facilities.
3
[
Note:
All
respondent
estimates
in
Exhibits
1
through
4
are
calculated
from
these
unrounded
universe
numbers.
For
simplicity,
however,
we
have
rounded
the
respondent
numbers
and
activities
in
the
text
below.]
For
the
purposes
of
this
ICR,
EPA
also
assumes
that
the
respondent
universe
will
be
constant
over
FYs
2005­
2007,
since
LDFs
that
close
remain
in
the
interim
as
post­
closure
facilities,
and
the
number
of
25
new
facilities
entering
the
universe
is
expected
to
be
so
small
that
it
will
have
no
significant
impact
on
the
burden
hour
and
cost
estimates
for
ground­
water
monitoring.
26
Table
1
Permitted
and
Interim
Status
Land
Disposal
Facilities
Included
in
the
ICR
Type
of
Facility
Number
of
Facilities
Permitted
a,
b
Interim
Status
c,
d
Total
Facilities
with
permitted
land
disposal
units
only
382
382
Facilities
with
interim
status
land
disposal
units
only
431
431
Facilities
with
permitted
and
interim
status
land
disposal
units
11
11
Total
e
387.5
436.5
824
a
Permitted
land
disposal
facilities
include
those
facilities
that
own
and/
or
operate
landfills,
land
treatment
units,
surface
impoundments,
and/
or
waste
piles
subject
to
40
CFR
Part
264.

b
Permitted
facilities
were
identified
based
on
the
legal
status
and
operating
status
of
their
land
disposal
units.
Permitted
facilities
included
in
this
ICR
own
and/
or
operate
land
disposal
units
with
the
following
RCRIS
process
legal
status
codes:
PC
(
post­
closure
permitted),
PI
(
permitted),
PR
(
proposed),
PT
(
permit
terminated/
permit
expired,
not
continued),
and
RQ
(
requested
but
not
approved).
For
further
information
on
these
legal
status
codes,
refer
to
EPA,
Resource
Conservation
and
Recovery
Information
System
(
RCRIS)
Data
Element
Dictionary
(
v.
7.1.0),
August
1998.

c
Interim
status
land
disposal
facilities
include
those
facilities
that
own
and/
or
operate
landfills,
land
treatment
units,
and/
or
surface
impoundments
subject
to
40
CFR
Part
265.

d
Interim
status
facilities
were
identified
based
on
the
legal
status
and
operating
status
of
their
land
disposal
units.
Interim
status
facilities
included
in
this
ICR
own
and/
or
operate
land
disposal
units
with
the
following
RCRIS
process
legal
status
codes:
IS
(
interim
status),
IT
(
interim
status
terminated),
LI
(
loss
of
interim
status),
NN
(
non­
notifier/
illegal),
and
RQ
(
requested
but
not
approved).
For
further
information
on
these
legal
status
codes,
refer
to
EPA,
Resource
Conservation
and
Recovery
Information
System
(
RCRIS)
Data
Element
Dictionary
(
v.
7.1.0),
August
1998.

e
The
eleven
facilities
with
both
permitted
and
interim
status
land
disposal
units
were
divided
equally
into
the
permitted
and
interim
status
facilities.
27
PERMITTED
FACILITIES
(
EXHIBIT
1)

EPA
used
the
same
assumptions
used
for
the
2001
GWM
ICR
(
based
upon
information
available
in
2001)
regarding
percentage
of
facilities
undertaking
specific
tasks.
EPA
estimates
that
about
53
percent
of
permitted
facilities
are
conducting
detection
monitoring,
10
percent
compliance
monitoring
and
37
percent
are
undertaking
corrective
action.
EPA
applied
these
percentages
to
the
universe
of
permitted
facilities
to
provide
a
breakdown
of
the
types
of
activities
being
conducted
at
facilities.
Accordingly,
EPA
estimates
that
of
the
approximately
387
permitted
facilities
subject
to
the
ground­
water
monitoring
requirements,
about
205
are
conducting
detection
monitoring,
39
are
conducting
compliance
monitoring,
and
143
are
undertaking
corrective
action.

EPA
estimates
that
each
of
the
approximately
387
permitted
facilities
will
read
the
regulations.
Over
the
three
years
covered
by
this
ICR,
an
average
of
about
129
facilities
will
read
the
regulations
each
year.

Each
of
the
approximately
387
permitted
facilities
is
required
to
conduct
ground­
water
sampling
and
analysis.
These
activities
require
the
implementation
of
a
ground­
water
monitoring
system,
which
involves
conducting
a
hydrogeologic
investigation
and
designing
and
installing
a
ground­
water
monitoring
system.
EPA
assumes
that
permitted
facilities
will
already
have
operational
ground­
water
monitoring
systems
in
place;
and
since
the
number
of
permitted
facilities
is
assumed
to
be
constant,
no
facilities
are
expected
to
perform
the
activities
associated
with
implementing
a
ground­
water
monitoring
system.

Detection
Monitoring
EPA
estimates
that
205
permitted
facilities
will
conduct
detection
monitoring
annually
during
the
period
covered
by
this
ICR.
EPA
estimates
that
all
205
facilities
conducting
detection
monitoring
will
determine
the
ground­
water
flow
rate
and
direction
annually,
sample
and
analyze
the
ground­
water
semiannually
and
record
all
ground­
water
analytical
data.

EPA
estimates
that
approximately
10
percent
of
the
facilities
conducting
detection
monitoring
21
facilities)
will
be
required
to
submit
a
notification
of
contamination
under
section
264.98(
g)(
1),
and
will
conduct
additional
sampling
and
analysis.
EPA
estimates
that
50
percent
of
these
facilities
(
10
facilities)
will
identify
Appendix
IX
constituents
in
the
ground­
water.
EPA
estimates
that
40
percent
of
the
facilities
identifying
Appendix
IX
constituents
(
4
facilities)
will
submit
all
data
necessary
to
establish
an
ACL,
and
that
approximately
20
percent
of
those
who
submit
such
data
(
1
facility)
will
receive
EPA
approval
to
establish
an
ACL.
Facilities
not
submitting
an
ACL
and
facilities
that
do
not
obtain
approval
for
an
ACL
must
submit
an
engineering
feasibility
plan
for
corrective
action
under
section
264.98(
g)(
5)(
ii).

Although
EPA
estimates
that
10
percent
of
the
facilities
detecting
Appendix
IX
constituents
(
1
facility)
will
submit
a
demonstration
to
show
contamination
from
an
outside
source,
EPA
estimates
that
none
will
receive
an
exemption
from
compliance
monitoring
regulations.

Compliance
Monitoring
EPA
estimates
that
39
facilities
will
conduct
compliance
monitoring
annually
during
the
period
covered
by
this
ICR.
EPA
assumes
that
the
sampling
and
analysis
and
recordkeeping
activities
necessary
28
to
maintain
ground­
water
analytical
data
at
the
facility
are
conducted
semi­
annually.
These
facilities
must
also
determine
the
ground­
water
flow
rate
and
direction
annually.

EPA
estimates
that
approximately
25
percent
of
the
facilities
conducting
compliance
monitoring
(
10
facilities)
will
confirm
the
presence
of
new
constituents
and
submit
a
notification
under
section
264.99(
g).

EPA
estimates
that
approximately
50
percent
of
the
facilities
conducting
compliance
monitoring
(
20
facilities)
will
identify
exceeded
concentration
limits,
and
will
therefore
compile
and
submit
a
notification
under
section
264.99(
h)(
1).
Of
the
facilities
identifying
exceeded
concentration
limits,
EPA
estimates
that
10
percent
(
2
facilities)
will
apply
for
an
exemption
from
the
corrective
action
requirements,
but
that
no
facility
will
submit
sufficient
information
to
justify
an
exemption.

Corrective
Action
EPA
estimates
that
143
facilities
will
conduct
corrective
action
annually
during
the
period
covered
by
this
ICR.
This
ICR
assumes
that
each
of
these
facilities
will
sample
and
analyze
ground­
water
and
submit
reports
on
the
effectiveness
of
corrective
action
semi­
annually.

Owners
and
operators
of
facilities
already
conducting
corrective
action
who
wish
to
submit
a
demonstration
under
section
264.100(
e)(
2)
will
have
done
so
upon
implementing
corrective
action.
Of
the
facilities
beginning
corrective
action
during
the
period
covered
by
this
ICR,
EPA
does
not
expect
any
to
submit
a
demonstration.
In
addition,
because
very
few
corrective
action
measures
have
been
implemented
to
date,
and
since
ground­
water
corrective
action
measures
often
take
5­
10
years
to
complete,
EPA
estimates
that
the
number
of
facilities
requesting
a
termination
of
corrective
action
activities
will
be
zero.

INTERIM
STATUS
FACILITIES
(
EXHIBIT
2)

EPA
estimates
that
each
of
the
approximately
436
interim
status
facilities
will
read
the
regulations.
Over
the
three
years
covered
by
this
ICR,
an
average
of
about
146
facilities
will
read
the
regulations
each
year.

Applicability
and
Alternative
Ground­
Water
Monitoring
Systems
As
no
new
LDFs
will
enter
the
interim
status
universe
during
the
period
covered
by
this
ICR,
EPA
estimates
that
no
facilities
will
submit
a
demonstration
under
sections
265.90(
c)
or
(
e),
or
under
section
265.91(
a)(
3).
This
ICR
assumes
that
demonstrations
under
this
section
are
submitted
in
written
form
to
the
Regional
Administrator.

This
ICR
also
assumes
that
facilities
wishing
to
submit
an
alternative
ground­
water
monitoring
plan
do
so
upon
obtaining
interim
status.
As
no
new
LDFs
will
enter
interim
status
during
the
period
covered
by
this
ICR,
no
new
interim
status
facilities
will
submit
plans
for
an
alternative
ground­
water
monitoring
system
each
year.
EPA
estimates
that,
prior
to
the
period
covered
by
this
ICR,
approximately
22
interim
status
facilities
(
5
percent)
submitted
alternative
ground­
water
monitoring
plans
and
10
percent
of
those
who
applied
(
2
facilities)
received
approval
to
operate
an
alternative
ground­
water
monitoring
system.
These
facilities
are
subject
to
the
recordkeeping
and
reporting
requirements
of
sections
265.90(
d)(
3)
and
(
5).
EPA
assumes
that
ground­
water
sampling
and
analysis
and
recordkeeping
activities
29
will
be
conducted
quarterly
(
2*
4
=
8
sampling
events
per
year),
and
that
ground­
water
quality
assessment
reports
will
be
developed
and
submitted
annually.

Sampling,
Analysis
and
Assessment
Each
of
the
approximately
436
interim
facilities
is
required
to
conduct
ground­
water
sampling
and
analysis
of
some
sort.
These
activities
require
the
implementation
of
a
ground­
water
monitoring
system.
EPA
assumes
that
all
interim
status
facilities
will
already
have
operational
ground­
water
monitoring
systems
in
place;
and
since
the
no
new
LDFs
are
expected
to
enter
the
universe
during
the
period
covered
by
this
ICR,
the
number
of
facilities
expected
to
perform
the
activities
associated
with
implementing
a
ground­
water
monitoring
system
is
zero.

This
ICR
assumes
that
only
new
interim
status
facilities
will
submit
sampling
and
analysis
plans
under
section
265.92(
a)
and
outlines
of
ground­
water
quality
assessment
plans
under
section
265.93(
a).
As
no
new
LDFs
will
enter
the
interim
status
universe,
no
new
interim
status
facilities
will
submit
sampling
and
analysis
plans
or
outlines
of
ground­
water
quality
assessment
plans.

However,
this
ICR
assumes
that
all
interim
status
facilities
not
conducting
an
alternative
groundwater
monitoring
program
and
that
have
not
already
detected
contamination
((
436
­
2)
x
0.50
=
217
facilities)
are
required
to
conduct
ground­
water
sampling
and
analysis
under
section
265.93(
b).

In
deriving
these
facility
estimates,
EPA
estimates
that
50
percent
of
all
interim
status
facilities
not
conducting
an
alternative
ground­
water
program
((
436
­
2)
x
.5
=
217
facilities)
have
already
detected
contamination.
These
facilities
must
conduct
sampling
and
analysis
on
a
quarterly
basis
in
accordance
with
section
265.93(
d)(
4).
In
addition,
EPA
estimates
that
2
percent
of
these
facilities
(
4
facilities)
will
confirm
the
presence
of
ground­
water
contamination
each
year.
These
facilities
must
submit
a
notification
of
contamination
to
the
Regional
Administrator,
submit
a
ground­
water
quality
assessment
plan
based
on
the
outline
developed
under
section
265.93(
b),
conduct
an
initial
ground­
water
quality
assessment,
and
submit
a
ground­
water
quality
assessment
report
as
required
under
section
265.93(
d)(
5).

The
remaining
217
facilities
must
conduct
sampling
and
analysis
semi­
annually,
in
accordance
with
sections
265.92(
d)
and
(
e).

This
ICR
assumes
that
there
is
no
additional
burden
associated
with
the
requirements
of
section
265.93(
e).
Any
facilities
subject
to
the
requirements
of
this
section
are
considered
in
the
burden
estimates
under
section
265.93(
d)(
5).

Recordkeeping
and
Reporting
The
requirements
of
section
265.94(
a)
apply
only
to
the
217
facilities
that
are
not
conducting
an
alternative
ground­
water
monitoring
program
and
have
not
already
detected
contamination.
EPA
assumes
that
the
records
of
ground­
water
analytical
data
required
under
this
section
will
be
updated
semi­
annually.
Drinking
water
suitability
parameter
reports
are
developed
and
submitted
only
by
newly
interim
facilities
on
a
quarterly
basis
during
the
first
year.
Reports
on
indicator
parameters
and
ground­
water
surface
elevations
are
submitted
annually
by
all
respondents
subject
to
the
section
265.94(
a)
requirements.
30
Based
on
past
experience,
EPA
estimates
that
two
percent
of
the
217
facilities
conducting
a
ground­
water
monitoring
program
in
accordance
with
section
265.93(
b)
(
4
facilities)
will
detect
significant
indicator
parameter
increases
(
or
pH
decreases)
in
upgradient
wells,
and
will
therefore
be
required
to
develop
and
submit
a
report
in
accordance
with
section
265.93(
c)(
1).

The
requirements
of
section
265.94(
b)
apply
to
the
217
facilities
conducting
ground­
water
quality
assessments.
Facilities
conducting
assessments
as
part
of
an
alternative
ground­
water
monitoring
system
are
covered
in
the
burden
estimates
for
section
265.90
(
2
facilities).
EPA
assumes
that
the
recordkeeping
requirements
of
section
265.94
are
conducted
on
a
quarterly
basis,
and
that
reports
on
the
results
of
the
ground­
water
quality
assessment
program
are
submitted
annually.

6(
e)
BOTTOM
LINE
BURDEN
HOURS
AND
COST
Respondent
Tally
Exhibit
5
shows
the
aggregate
annual
hours,
labor
costs,
total
capital/
startup
costs,
total
O&
M
costs,
and
the
overall
annual
costs
to
respondents.
The
bottom
line
burden
to
respondents
over
three
years
is
290,739
hours,
with
a
cost
of
approximately
$
72,045,453.

Agency
Tally
Exhibit
6
shows
the
annual
hour
and
cost
burden
to
the
Agency.
The
bottom
line
annual
burden
to
the
Agency
over
three
years
is
98,610
hours
and
$
5,049,405.

6(
f)
REASONS
FOR
CHANGE
IN
BURDEN
This
current
ICR
(#
959.12)
renews
and
updates
the
previously
approved
ICR
on
the
groundwater
monitoring
requirements
(
i.
e.,
ICR
#
959.11).
ICR
#
959.11
estimated
a
total
annual
respondent
burden
of
96,913
hours.
ICR
#
959.12
estimates
a
total
annual
respondent
burden
of
96,913
hours.
This
is
the
same
burden
as
estimated
for
the
previous
ICR.
The
reason
for
this
is
that
we
have
used
the
same
assumptions
for
the
universe
and
the
hourly
burden
per
task
that
were
used
in
the
2001
ICR.
We
used
these
same
assumptions
for
two
reasons.
The
first
reason
is
we
do
not
believe
the
universe
has
expanded;
we
do
not
believe
there
have
new
facilities
with
land
disposal
units
in
the
last
three
years.
Those
facilities
that
were
existing
in
2001,
are
probably
still
required
to
conduct
ground­
water
monitoring
between
FY
2005­
2007.
The
second
reason
why
the
burden
estimates
remain
the
same
is
that
we
believe
our
estimates
of
hourly
burden
per
task
in
the
2001
ICR
are
appropriate
today.
There
have
not
been
significant
changes
in
the
costs
associated
with
GWM
and
so
we
assume
that
the
hour
spent
per
task
remain
the
same.

The
costs
associated
with
the
burden
hours
have
changed.
That
is
because
EPA
revised
the
hourly
wage
assumptions
for
the
regulated
community
to
reflect
the
salary
assumptions
used
in
another
2004
ICR.
The
Agency
costs
have
been
to
revised
to
reflect
2004
values.

6(
g)
BURDEN
STATEMENT
PERMITTED
FACILITIES
31
EPA
estimates
that
permitted
LDFs
will
incur
an
average
reporting
burden
of
about
10
hours
per
year,
which
includes
time
for
developing
and
submitting
notifications,
reports,
and
demonstrations.
They
will
also
incur
a
recordkeeping
burden
of
about
130
hours
per
year,
which
includes
time
for
reading
the
regulations,
implementing
a
ground­
water
monitoring
system,
performing
and
keeping
records
of
groundwater
monitoring,
and
maintaining
records.
These
estimates
represent
the
average
reporting
and
recordkeeping
burdens
placed
on
permitted
facilities
for
detection
monitoring,
compliance
monitoring,
or
corrective
action.

INTERIM
STATUS
FACILITIES
EPA
estimates
that
interim
status
LDFs
will
incur
an
average
reporting
burden
of
about
10
hours
per
year,
which
includes
time
for
developing
and
submitting
notifications,
reports,
and
demonstrations.
They
will
also
incur
a
recordkeeping
burden
of
about
80
hours
per
year,
which
includes
time
for
reading
the
regulations,
implementing
a
ground­
water
monitoring
system,
performing
and
keeping
records
of
ground­
water
monitoring,
and
maintaining
records.

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

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
RCRA­
2004­
0033,
which
is
available
for
public
viewing
at
the
Resource
Conservation
and
Recovery
(
RCRA)
Docket
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
RCRA
Docket
is
(
202)
566­
0270.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
(
RCRA­
2004­
0013)
and
OMB
control
number
(
2050­
0033)
in
any
correspondence.
32
EXHIBIT
1
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
GROUND­
WATER
ANNUAL
ESTIMATED
RESPONDENT
BURDEN
AND
COST
PERMITTED
FACILITIES
Updated
1/
17/
05
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Number
Leg.
Mgr.
Tech.
Cler.
Respon
Labor
Capital/
Respon.
Total
Total
$
119.91
$
85.82
$
62.30
$
31.74
Hours
Cost
Startup
O
&
M
or
Hours/
Cost/

INFORMATION
COLLECTION
ACTIVITY
/
Year
/
Year
/
Year
/
Year
/
Year
/
Year
Cost
Cost
Activitie
Year
Year
Reading
the
Regulations
Read
the
regulations
0.50
0.50
0.50
0.00
1.50
$
134
$
0
$
0
129
193.50
$
17,286
SUBTOTAL
varies
varies
varies
varies
varies
varies
varies
varies
193.50
$
17,286
Implement
Ground­
water
Monitoring
System
Conduct
hydrogeologic
investigation
0.00
0.00
40.00
0.00
40.00
$
2,492
$
0
$
48,663
0
0.00
$
0
Design
and
install
ground­
water
monitoring
system
0.00
0.00
4.00
0.00
4.00
$
249
$
12,236
$
0
0
0.00
$
0
SUBTOTAL
varies
varies
varies
varies
varies
varies
varies
varies
0.00
$
0
DETECTION
MONITORING
Sampling
and
Analysis
Determine
ground­
water
flow
rate
and
direction
(
annually)(
264.98(
e))
0.00
4.00
25.00
4.00
33.00
$
2,028
$
0
$
4,314
205
6,765.00
$
1,300,110
Sample
and
analyze
ground­
water
(
semi­
annually)

(
264.98(
d)­(
f))
0.00
8.00
32.00
8.00
48.00
$
2,934
$
0
$
9,707
410
19,680.00
$
5,182,605
Record
ground­
water
analytical
data
(
semi­
annually)
(
264.98(
c))
0.00
0.50
1.00
0.50
2.00
$
121
$
1
$
0
410
820.00
$
50,020
Notification
of
Contamination
Prepare
and
submit
the
notification
of
contamination
(
264.98(
g)(
1))
0.25
0.50
1.00
0.50
2.25
$
151
$
0
$
4
21
47.25
$
3,246
Re­
sampling
and
Analysis
Re­
sample
and
analyze
ground­
water
for
Appendix
IX
compounds
(
264.98(
g)(
2))
0.00
14.00
60.00
14.00
88.00
$
5,384
$
0
$
17,795
21
1,848.00
$
486,764
Record
ground­
water
analytical
data
(
264.98(
c))
0.00
0.50
1.00
0.50
2.00
$
121
$
1
$
0
21
42.00
$
2,562
Alternate
Concentration
Limits
Compile
and
submit
data
necessary
to
establish
an
alternate
concentration
limit
(
264.98(
g)(
5)(
i))
0.00
2.00
16.00
2.00
20.00
$
1,232
$
0
$
26,963
4
80.00
$
112,778
Engineering
Feasibility
plans
Prepare
and
submit
an
engineering
feasibility
plan
for
corrective
action
if
required
under
264.98(
g)(
5)(
ii)
0.00
2.00
80.00
2.00
84.00
$
5,219
$
0
$
43,140
10
840.00
$
483,590
Demonstration
Prepare
and
submit
notification
of
intent
to
make
a
demonstration
under
264.98(
g)(
6)
0.25
0.50
1.00
0.50
2.25
$
151
$
0
$
4
1
2.25
$
155
Prepare
and
submit
the
demonstration
(
264.98(
g)(
6))
0.00
2.00
16.00
2.00
20.00
$
1,232
$
0
$
5,000
1
20.00
$
6,232
SUBTOTAL
varies
varies
varies
varies
varies
varies
varies
varies
30,144.50
$
7,628,062
33
EXHIBIT
1
(
continued)

REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
GROUND­
WATER
ANNUAL
ESTIMATED
RESPONDENT
BURDEN
AND
COST
PERMITTED
FACILITIES
Updated
1/
17/
05
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Number
Leg.
Mgr.
Tech.
Cler.
Respon
Labor
Capital/
Respon.
Total
Total
$
119.91
$
85.82
$
62.30
$
31.74
Hours
Cost
Startup
O
&
M
or
Hours
Cost
INFORMATION
COLLECTION
ACTIVITY
/
Year
/
Year
/
Year
/
Year
/
Year
/
Year
Cost
Cost
Activitie
/
Year
/
Year
COMPLIANCE
MONITORING
Sampling
and
Analysis
Determine
ground­
water
flow
rate
and
direction
(
annually)(
264.99(
e))
0.00
4.00
25.00
4.00
33.00
$
2,028
$
0
$
4,314
39
1,287.00
$
247,338
Sample
and
analyze
ground­
water
(
semi­
annually)

(
264.99(
f)­(
g))
0.00
14.00
60.00
14.00
88.00
$
5,384
$
0
$
17,795
78
6,864.00
$
1,807,982
Record
ground­
water
analytical
data
(
semi­
annually)(
264.99(
c)(
2))
0.00
0.50
1.00
0.50
2.00
$
121
$
1
$
0
78
156.00
$
9,516
Notification
of
New
Constituents
Compile
information
for
notification
of
new
constituents
(
264.99(
g))
0.00
2.00
4.00
2.00
8.00
$
484
$
0
$
0
10
80.00
$
4,840
Prepare
and
submit
the
notification
(
264.99(
g))
0.25
1.00
2.00
1.00
4.25
$
272
$
0
$
4
10
42.50
$
2,756
Notification
of
Exceeded
Concentration
Limits
Compile
information
on
exceeded
concentration
limits
(
264.99(
h)(
1))
0.00
0.50
1.00
0.50
2.00
$
121
$
0
$
0
20
40.00
$
2,420
Prepare
and
submit
the
notification
(
264.99(
h)(
1))
0.25
0.50
1.00
0.50
2.25
$
151
$
0
$
4
20
45.00
$
3,091
Demonstration
Prepare
and
submit
a
notification
of
intent
(
264.99(
i)(
1))

to
make
a
demonstration
under
264.99(
i)
0.25
0.50
1.00
0.50
2.25
$
151
$
0
$
4
2
4.50
$
309
Prepare
and
submit
the
demonstration
(
264.99(
i)(
2))
0.00
2.00
16.00
2.00
20.00
$
1,232
$
0
$
5,393
2
40.00
$
13,249
SUBTOTAL
varies
varies
varies
varies
varies
varies
varies
varies
8,559.00
$
2,091,500
CORRECTIVE
ACTION
Sampling
and
Analysis
Sample
and
analyze
ground­
water
(
semi­
annually)

(
264.100(
d))
0.00
8.00
32.00
8.00
48.00
$
2,934
$
0
$
9,707
286
13,728.00
$
3,615,183
Record
ground­
water
analytical
data
(
semi­
annually)(
264.100(
d))
0.00
0.50
1.00
0.50
2.00
$
121
$
1
$
0
286
572.00
$
34,892
Demonstrations
Compile
and
submit
information
for
the
demonstration
from
corrective
action
(
264.100(
e)(
2))
1.00
8.00
32.00
4.00
45.00
$
2,927
$
0
$
4
0
0.00
$
0
Compile
and
submit
information
for
the
demonstration
for
termination
of
corrective
action
(
264.100(
f))
0.00
2.00
16.00
2.00
20.00
$
1,232
$
0
$
5,393
0
0.00
$
0
Report
on
the
Effectiveness
of
Corrective
Action
Develop
and
submit
the
report
(
semi­
annually)

(
264.100(
g))
0.00
2.00
8.00
2.00
12.00
$
734
$
0
$
5,393
286
3,432.00
$
1,752,179
SUBTOTAL
varies
varies
varies
varies
varies
varies
varies
varies
17,732.00
$
5,402,254
TOTAL
varies
varies
varies
varies
varies
varies
varies
varies
56,629.00
$
15,139,102
34
EXHIBIT
2
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
GROUND­
WATER
MONITORING
ANNUAL
ESTIMATED
RESPONDENT
BURDEN
AND
COST
INTERIM
STATUS
FACILITIES
Updated
1/
17/
05
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Number
Leg.
Mgr.
Tech.
Cler.
Respon
Labor
Capital/
Respon.
Total
Total
$
119.91
$
85.82
$
62.30
$
31.74
Hours/
Cost
Startup
O
&
M
or
Hours
Cost
INFORMATION
COLLECTION
ACTIVITY
/
Year
/
Year
/
Year
/
Year
/
Year
/
Year
Cost
Cost
Activitie
/
Year
/
Year
Reading
the
Regulations
Read
the
regulations
1.00
1.50
1.50
0.00
4.00
$
342
$
0
$
0
146
584.00
$
49,932
SUBTOTAL
varies
varies
varies
varies
varies
varies
varies
varies
584.00
$
49,932
APPLICABILITY
AND
ALTERNATE
GROUND­
WATER
MONITORING
SYSTEMS
Demonstrations
(
265.90(
c)
and
265.90(
e))

Develop
and
submit
the
demonstration
(
265.90(
c))
0.00
30.00
75.00
15.00
120.00
$
7,723
$
0
$
93,830
0
0.00
$
0
Develop
and
submit
the
demonstration
(
265.90(
e))
0.00
30.00
75.00
15.00
120.00
$
7,723
$
0
$
93,830
0
0.00
$
0
Maintain
records
0.00
0.50
1.00
0.50
2.00
$
121
$
1
$
0
0
0.00
$
0
Alternate
Ground­
water
Monitoring
Plan
(
265.90(
d)(
1))

Compile
information
for
an
alternate
ground­
water
monitoring
plan
0.00
200.00
400.00
150.00
750.00
$
46,845
$
0
$
0
0
0.00
$
0
Obtain
certification
0.00
10.00
25.00
5.00
40.00
$
2,574
$
0
$
5,393
0
0.00
$
0
Develop
and
submit
the
plan
3.00
30.00
60.00
10.00
103.00
$
6,990
$
0
$
4
0
0.00
$
0
Ground­
water
Quality
Assessment
Reports
(
265.90(
d)(
3)
and
(
5))

Develop
and
submit
the
reports
0.00
1.00
20.00
3.00
24.00
$
1,427
$
0
$
5,393
2
48.00
$
13,639
Maintain
a
record
of
the
ground­
water
quality
assessment
data
at
the
facility
0.00
0.50
1.00
0.50
2.00
$
121
$
1
$
0
2
4.00
$
244
Demonstration
for
alternate
well
location
(
265.91(
a)(
3))

Develop
and
submit
the
demonstration
0.00
2.00
16.00
2.00
20.00
$
1,232
$
0
$
5,393
0
0.00
$
0
Maintain
records
0.00
0.50
1.00
0.50
2.00
$
121
$
1
$
0
0
0.00
$
0
SUBTOTAL
varies
varies
varies
varies
varies
varies
varies
varies
52.00
$
13,883
Implementing
Ground­
water
Monitoring
System
(
265.90)

Conduct
hydrogeologic
investigation
0.00
24.00
200.00
24.00
248.00
$
15,281
$
0
$
32,355
0
0.00
$
0
Design
and
install
ground­
water
monitoring
system
0.00
40.00
120.00
8.00
168.00
$
11,163
$
4,314
$
0
0
0.00
$
0
SUBTOTAL
varies
varies
varies
varies
varies
varies
varies
varies
0.00
$
0
35
EXHIBIT
2
(
continued)

REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
GROUND­
WATER
MONITORING
ANNUAL
ESTIMATED
RESPONDENT
BURDEN
AND
COST
INTERIM
STATUS
FACILITIES
Updated
1/
17/
05
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Number
Leg.
Mgr.
Tech.
Cler.
Respon
Labor
Capital/
Respon.
Total
Total
$
119.91
$
85.82
$
62.30
$
31.74
Hours
Cost
Startup
O
&
M
or
Hours
Cost
INFORMATION
COLLECTION
ACTIVITY
/
Year
/
Year
/
Year
/
Year
/
Year
/
Year
Cost
Cost
Activitie
/
Year
/
Year
SAMPLING,
ANALYSIS
AND
ASSESSMENT
Sampling
and
Analysis
Plan
(
265.92(
a))

Compile
information
for
a
written
sampling
and
analysis
plan
0.00
0.00
40.00
0.00
40.00
$
2,492
$
0
$
5,393
0
0.00
$
0
File
the
plan
at
the
facilty
0.00
0.50
1.00
0.50
2.00
$
121
$
1
$
0
0
0.00
$
0
Notification
of
Increased
Indicator
Parameter
Concentrations
(
265.93(
d)(
1))

Prepare
a
ground­
water
quality
assessment
plan
outline
(
265.93(
a))
0.00
5.00
24.00
16.00
45.00
$
2,432
$
0
$
0
0
0.00
$
0
Compile
and
submit
notification
1.00
1.00
5.00
2.00
9.00
$
581
$
0
$
4
4
36.00
$
2,338
Ground­
water
Quality
Assessment
Program
Plan
(
265.93(
d)(
2)­(
3))

Develop
and
submit
plan
0.00
8.00
24.00
16.00
48.00
$
2,690
$
0
$
4
4
192.00
$
10,774
Initial
Ground­
water
Quality
Assessment
Report
(
265.93(
d)(
5))

Develop
and
submit
the
report
0.00
1.00
20.00
3.00
24.00
$
1,427
$
0
$
5,393
4
96.00
$
27,278
Sampling
and
Analysis
Conduct
sampling
and
analysis
to
determine
ground­
water
quality
under
alternate
ground­
water
0.00
4.00
16.00
4.00
24.00
$
1,467
$
0
$
4,853
8
192.00
$
50,562
Conduct
sampling
and
analysis
of
ground­
water
to
obtain
analytical
data
(
semi­
annually)
(
265.92(
d)­(
e))
0.00
4.00
16.00
4.00
24.00
$
1,467
$
0
$
4,853
434
10,416.00
$
2,742,989
Conduct
sampling
and
analysis
as
part
of
ground­
water
quality
assessment
program
(
quarterly)
(
265.93(
d)(
4))
0.00
4.00
16.00
4.00
24.00
$
1,467
$
0
$
4,853
870
20,880.00
$
5,498,618
SUBTOTAL
varies
varies
varies
varies
varies
varies
varies
varies
31,812.00
$
8,332,558
36
EXHIBIT
2
(
continued)

REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
GROUND­
WATER
MONITORING
ANNUAL
ESTIMATED
RESPONDENT
BURDEN
AND
COST
INTERIM
STATUS
FACILITIES
Updated
1/
17/
05
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Number
Leg.
Mgr.
Tech.
Cler.
Respon
Labor
Capital/
Respon.
Total
Total
$
119.91
$
85.82
$
62.30
$
31.74
Hours
Cost
Startup
O
&
M
or
Hours
Cost
INFORMATION
COLLECTION
ACTIVITY
/
Year
/
Year
/
Year
/
Year
/
Year
/
Year
Cost
Cost
Activitie
/
Year
/
Year
RECORDKEEPING
AND
REPORTING
Recordkeeping
(
265.94(
a)(
1))

Record
ground­
water
analytical
data
at
the
facility
(
semi­
annually)
0.00
0.50
1.00
0.50
2.00
$
121
$
1
$
0
434
868.00
$
52,948
Report
on
Drinking
Water
Suitability
Parameters
(
265.94(
a)(
2)(
i))

Prepare
and
submit
a
report
of
concentrations
or
values
of
the
drinking
water
suitability
parameters
(
quarterly)
0.00
0.50
1.00
0.50
2.00
$
121
$
1
$
4
0
0.00
$
0
Reports
on
Indicator
Parameters
and
Groundwater
Surface
Elevations
(
265.94(
a)(
2)(
ii)
and
(
iii))

Prepare
and
submit
a
report
on
indicator
parameter
concentrations
and
evaluations
as
determined
under
265.93(
b)
0.00
2.00
4.00
2.00
8.00
$
484
$
1
$
4
217
1,736.00
$
106,017
Prepare
and
submit
a
report
of
any
significant
indicator
parameter
increases
(
or
pH
decreases)

in
upgradient
wells
(
265.93(
c)(
1))
0.00
1.00
2.00
1.00
4.00
$
242
$
1
$
4
4
16.00
$
986
Prepare
and
submit
a
report
on
ground­
water
surface
elevations
as
determined
under
265.92(
e)
0.00
2.00
4.00
2.00
8.00
$
484
$
1
$
4
217
1,736.00
$
106,017
Record
of
Ground­
water
Quality
Assessment
(
265.94(
b)(
1))

Record
ground­
water
quality
assessment
data
obtained
under
265.93(
d)(
4)
(
quarterly)
0.00
0.50
2.00
0.50
3.00
$
183
$
1
$
0
870
2,610.00
$
160,080
Ground­
water
Quality
Assessment
Report
(
265.94(
b)(
2))

Prepare
and
submit
a
report
on
the
results
of
the
ground­
water
quality
assessment
program
(
annually)
0.00
1.00
2.00
1.00
4
$
242
$
1
$
4
217.5
870.00
$
53,627
SUBTOTAL
varies
varies
varies
varies
varies
varies
varies
varies
7,836.00
$
479,675
TOTAL
varies
varies
varies
varies
varies
varies
varies
varies
40,284.00
$
8,876,049
37
EXHIBIT
3
ANNUAL
ESTIMATED
AGENCY
BURDEN
AND
COST
PERMITTED
FACILITIES
Updated
1/
17/
05
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Number
Leg.
Mgr.
Tech.
Cler.
Respon
Labor
Capital/
Respon.
Total
Total
$
76.85
$
65.33
$
55.28
$
29.02
Hours
Cost
Startup
O
&
M
or
Hours
Cost
INFORMATION
COLLECTION
ACTIVITY
/
Year
/
Year
/
Year
/
Year
/
Year
/
Year
Cost
Cost
Activitie
/
Year
/
Year
DETECTION
MONITORING
Notification
of
Contamination
(
264.98(
g)(
1))

Review
the
notification
0.00
0.00
8.00
0.00
8.00
$
442
$
0
$
0
21
168.00
$
9,282
Enter
the
information
into
data
base
0.00
0.00
0.00
2.00
2.00
$
58
$
0
$
0
21
42.00
$
1,218
Alternate
Concentration
Limits
(
264.98(
g)(
5)(
i))

Evaluate
data
submitted
to
justify
an
alternate
concentration
limit
0.00
0.00
160.00
0.00
160.00
$
8,845
$
0
$
0
4
640.00
$
35,380
Enter
information
into
data
base
0.00
0.00
0.00
4.00
4.00
$
116
$
0
$
0
4
16.00
$
464
Engineering
Feasibility
plans
(
264.98(
g)(
5)(
ii)

Evaluate
engineering
feasibility
plan
for
a
corrective
action
program
0.00
0.00
160.00
0.00
160.00
$
8,845
$
0
$
0
10
1,600.00
$
88,450
Enter
information
into
data
base
0.00
0.00
0.00
4.00
4.00
$
116
$
0
$
0
10
40.00
$
1,160
Demonstration
(
264.98(
g)(
6))

Review
notification
of
intent
to
submit
a
demonstration
of
contamination
from
an
outside
source
0.00
0.00
8.00
0.00
8.00
$
442
$
0
$
0
1
8.00
$
442
Review
the
demonstration
0.00
0.00
40.00
0.00
40.00
$
2,211
$
0
$
0
1
40.00
$
2,211
$
0
$
0
SUBTOTAL
varies
varies
varies
varies
varies
varies
varies
varies
2,554.00
$
138,607
COMPLIANCE
MONITORING
Demonstration
(
264.99(
i))

Review
the
notification
0.00
0.00
8.00
0.00
8.00
$
442
$
0
$
0
2
16.00
$
884
Review
the
demonstration
0.00
0.00
40.00
0.00
40.00
$
2,211
$
0
$
0
2
80.00
$
4,422
Notification
of
New
Constituents
(
264.99(
g))

Review
the
notification
0.00
0.00
8.00
0.00
8.00
$
442
$
0
$
0
10
80.00
$
4,420
Enter
information
into
data
base
0.00
0.00
0.00
2.00
2.00
$
58
$
0
$
0
10
20.00
$
580
Notification
of
Exceeded
Concentration
Limits
(
264.99(
h)(
1))

Review
notification
0.00
0.00
8.00
0.00
8.00
$
442
$
0
$
0
20
160.00
$
8,840
Enter
information
into
data
base
0.00
0.00
0.00
2.00
2.00
$
58
$
0
$
0
20
40.00
$
1,160
SUBTOTAL
varies
varies
varies
varies
varies
varies
varies
varies
396.00
$
20,306
CORRECTIVE
ACTION
Demonstrations
(
264.100(
e)(
2)
and
264.100(
f))

Review
the
demonstrations
0.00
0.00
40.00
0.00
40.00
$
2,211
$
0
$
0
0
0.00
$
0
Report
on
the
Effectiveness
of
Corrective
Action
(
264.100(
g))

Evaluate
report
0.00
0.00
40.00
0.00
40.00
$
2,211
$
0
$
0
286
11,440.00
$
632,346
Enter
information
into
data
base
0.00
0.00
0.00
8.00
8.00
$
232
$
0
$
0
286
2,288.00
$
66,352
SUBTOTAL
varies
varies
varies
varies
varies
varies
varies
varies
13,728.00
$
698,698
38
EXHIBIT
4
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
GROUND­
WATER
ANNUAL
ESTIMATED
AGENCY
BURDEN
AND
COST
INTERIM
STATUS
FACILITIES
Updated
1/
17/
05
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Number
Leg.
Mgr.
Tech.
Cler.
Respon
Labor
Capital/
Respon.
Total
Total
$
76.85
$
65.33
$
55.28
$
29.02
Hours
Cost
Startup
O
&
M
or
Hours
Cost
INFORMATION
COLLECTION
ACTIVITY
/
Year
/
Year
/
Year
/
Year
/
Year
/
Year
Cost
Cost
Activitie
/
Year
/
Year
APPLICABILITY
AND
ALTERNATE
GROUND­
WATER
MONITORING
SYSTEMS
Demonstrations
(
265.90(
c)
and
265.90(
e))

Review
the
demonstrations
0.00
40.00
70.00
10.00
120.00
$
6,773
$
0
$
0
0
0.00
$
0
Alternate
Ground­
water
Monitoring
Plan
(
265.90(
d)(
1))

Review
the
alternate
ground­
water
monitoring
plan
0.00
25.00
50.00
5.00
80.00
$
4,542
$
0
$
0
0
0.00
$
0
Ground­
water
Quality
Assessment
Reports
(
265.90(
d)(
3)
and
(
5))

Review
the
reports
0.00
15.00
25.00
0.00
40.00
$
2,362
$
0
$
0
2
80.00
$
4,724
Enter
information
into
a
database
0.00
0.00
0.00
8.00
8.00
$
232
$
0
$
0
2
16.00
$
464
Demostration
for
alternate
well
location
(
265.91(
a)(
3))

Review
the
demonstrations
0.00
20.00
35.00
5.00
60.00
$
3,387
$
0
$
0
0
0.00
$
0
SUBTOTAL
varies
varies
varies
varies
varies
varies
varies
varies
96.00
$
5,188
SAMPLING,
ANALYSIS,
AND
ASSESSMENT
Notification
of
Increased
Indicator
Parameter
Concentrations
(
265.93(
d)(
1))

Review
the
notification
0.00
2.00
6.00
0.00
8.00
$
462
$
0
$
0
4
32.00
$
1,848
Enter
information
into
a
database
0.00
0.00
0.00
8.00
8.00
$
232
$
0
$
0
4
32.00
$
928
Ground­
water
Quality
Assessment
Plan
(
265.93(
d)(
2))

Evaluate
the
plan
0.00
10.00
30.00
0.00
40.00
$
2,312
$
0
$
0
4
160.00
$
9,248
Initial
Ground­
water
Quality
Assessment
Report
(
265.93(
d)(
5))

Evaluate
the
reports
0.00
10.00
30.00
0.00
40.00
$
2,312
$
0
$
0
4
160.00
$
9,248
Enter
information
into
a
database
0.00
0.00
0.00
8.00
8.00
$
232
$
0
$
0
4
32.00
$
928
SUBTOTAL
varies
varies
varies
varies
varies
varies
varies
varies
416.00
$
22,200
39
EXHIBIT
4
(
continued)

REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
GROUND­
WATER
ANNUAL
ESTIMATED
AGENCY
BURDEN
AND
COST
INTERIM
STATUS
FACILITIES
Updated
1/
17/
05
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Number
Leg.
Mgr.
Tech.
Cler.
Respon
Labor
Capital/
Respon.
Total
Total
$
76.85
$
65.33
$
55.28
$
29.02
Hours
Cost
Startup
O
&
M
or
Hours
Cost
INFORMATION
COLLECTION
ACTIVITY
/
Year
/
Year
/
Year
/
Year
/
Year
/
Year
Cost
Cost
Activitie
/
Year
/
Year
RECORDKEEPING
AND
REPORTING
Report
on
Drinking
Water
Suitability
Parameters
(
265.94(
a)(
2)(
i))

Review
the
report
0.00
23.00
69.00
0.00
92.00
$
5,317
$
0
$
0
0
0.00
$
0
Enter
information
into
a
database
0.00
0.00
0.00
32.00
32.00
$
929
$
0
$
0
0
0.00
$
0
Reports
on
Indicator
Parameters
and
Groundwater
Surface
Elevations
(
265.94(
a)(
2)(
ii)
and
(
iii))

Review
report
on
indicator
concentrations
and
evaluations
as
determined
under
265.93(
b)
0.00
1.50
6.00
0.50
8.00
$
444
$
0
$
0
217
1,736.00
$
96,348
Review
report
on
significant
indicator
parameter
increases
in
upgradient
wells
0.00
1.50
6.00
0.50
8.00
$
444
$
0
$
0
4
32.00
$
1,776
Review
report
on
ground­
water
surface
elevations
as
determined
under
265.92(
e)
0.00
1.50
6.00
0.50
8.00
$
444
$
0
$
0
217
1,736.00
$
96,348
Enter
information
into
a
database
0.00
0.00
0.00
8.00
8.00
$
232
$
0
$
0
217
1,736.00
$
50,344
Ground­
water
Quality
Assessment
Report
(
265.94(
b)(
2))

Review
the
ground­
water
quality
assessment
report
0.00
10.00
30.00
0.00
40.00
$
2,312
$
0
$
0
217.5
8,700.00
$
502,860
Enter
information
into
a
database
0.00
0.00
0.00
8.00
8.00
$
232
$
0
$
0
217.5
1,740.00
$
50,460
SUBTOTAL
varies
varies
varies
varies
varies
varies
varies
varies
15,680.00
$
798,136
TOTAL
varies
varies
varies
varies
varies
varies
varies
varies
16,192.00
$
825,524
40
EXHIBIT
5
TOTAL
ESTIMATED
RESPONDENT
BURDEN
AND
COST
SUMMARY
PERMITTED
AND
INTERIM
STATUS
FACILITIES
Updated
1/
17/
05
Total
Total
Total
Annual
Total
Total
Hours
per
Labor
Cost
Capital/
Startup
Annual
O&
M
Cost
per
EXHIBIT
Year
Per
Year
Costs
Per
Year
Costs
Per
Year
Year
PERMITTED
FACILITIES
Reading
the
Regulations
194
$
17,286
$
0
$
0
$
17,286
Implement
Ground­
water
Monitoring
System
0
$
0
$
0
$
0
$
0
Detection
Monitoring
30,145
$
1,845,567
$
431
$
5,782,064
$
7,628,062
Compliance
Monitoring
8,559
$
524,248
$
78
$
1,567,174
$
2,091,500
Corrective
Action
17,732
$
1,083,654
$
286
$
4,318,314
$
5,402,254
SUBTOTAL
56,629
$
3,470,755
$
795
$
11,667,552
$
15,139,102
INTERIM
STATUS
FACILITIES
Reading
the
Regulations
584
$
49,932
$
0
$
0
$
49,932
Applicability
and
Alternate
Groundwater
Monitoring
Systems
52
$
3,096
$
2
$
10,785
$
13,883
Implement
Ground­
water
Monitoring
System
0
$
0
$
0
$
0
$
0
Sampling,
Analysis,
and
Assessment
31,812
$
1,943,496
$
0
$
6,389,062
$
8,332,558
Recordkeeping
and
Reporting
7,836
$
475,383
$
1,960
$
2,333
$
479,675
SUBTOTAL
40,284
$
2,471,907
$
1,962
$
6,402,180
$
8,876,049
TOTAL
96,913
$
5,942,662
$
2,757
$
18,069,732
$
24,015,151
41
EXHIBIT
6
TOTAL
ESTIMATED
AGENCY
BURDEN
AND
COST
SUMMARY
PERMITTED
AND
INTERIM
STATUS
FACILITIES
Updated
1/
17/
05
Total
Total
Hours
per
Cost
per
EXHIBIT
Year
Year
PERMITTED
FACILITIES
Detection
Monitoring
2,554
$
138,607
Compliance
Monitoring
396
$
20,306
Corrective
Action
13,728
$
698,698
SUBTOTAL
16,678
$
857,611
INTERIM
STATUS
FACILITIES
Applicability
and
Alternate
Groundwater
Monitoring
Systems
96
$
5,188
Sampling,
Analysis,
and
Assessment
416
$
22,200
Recordkeeping
and
Reporting
15,680
$
798,136
SUBTOTAL
16,192
$
825,524
TOTAL
32,870
$
1,683,135
