SUPPORTING
STATEMENT
FOR
EPA
INFORMATION
COLLECTION
REQUEST
#
1608.04
STATE
PROGRAM
ADEQUACY
DETERMINATION:

MUNICIPAL
SOLID
WASTE
LANDFILLS
(
MSWLFs)
and
NON­
MUNICIPAL,
NON­
HAZARDOUS
WASTE
DISPOSAL
UNITS
THAT
RECEIVE
CONDITIONALLY
EXEMPT
SMALL
QUANTITY
GENERATOR
(
CESQG)
HAZARDOUS
WASTE
(
40
CFR
PART
293)
(
RENEWAL)
1
TABLE
OF
CONTENTS
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
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3
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a)
Title
and
number
of
the
information
collection
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3
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b)
Short
Characterization
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3
2.
NEED
FOR
AND
USE
OF
THE
INFORMATION
COLLECTION
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4
(
a)
Need
and
authority
for
the
information
collection
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4
(
b)
Practical
utility/
users
of
the
data
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5
3.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
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5
(
a)
Respondents/
SIC
Codes
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5
(
b)
Information
Requested
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5
Develop
Program
Application
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5
(
i)
Data
items,
Including
Record
keeping
Requirements
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5
(
ii)
Respondent
Activities.
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6
Adequacy
Determination
Process
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6
(
i)
Data
items,
including
Record
keeping
Requirements
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6
(
ii)
Respondent
Activities.
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6
4.
THE
INFORMATION
COLLECTED
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AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
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6
(
a)
Agency
Activities
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6
(
b)
Collection
Methodology
and
Management
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.7
(
c)
Small
Entity
Flexibility
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7
(
d)
Collection
Schedule
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8
5.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
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8
(
a)
Nonduplication
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8
(
b)
Effects
of
Less
Frequent
Collection
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8
(
c)
Consultations
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9
(
d)
General
Guidelines
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9
(
e)
Confidentiality
and
Sensitive
Questions
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9
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
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9
(
a)
Estimating
Respondent
Burden
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10
(
b)
Estimating
Respondent
Costs
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10
(
c)
Estimating
Agency
Burden
and
Cost
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10
(
d)
Bottom
Line
Burden
Hours
and
Costs
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11
(
e)
Respondent
Universe
and
Total
Burden
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11
(
f)
Reasons
For
Change
in
Burden
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11
(
g)
Burden
Statement
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12
2
(
h)
Request
for
Comments
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12
Exhibit
1:
10
States/
Territories
Preparing
Applications
for
Non­
municipal,
Non­
hazardous
Waste
Disposal
Units
that
Receive
CESQG
Hazardous
Waste
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.13
Exhibit
2:
8
States/
Territories
Preparing
Municipal
Solid
Waste
Landfill
Program
Applications.
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.14
Exhibit
3:
EPA
Regions
Responding
to
10
Applications
for
Non­
municipal,
Nonhazardous
Waste
Disposal
Units
that
Receive
CESQG
Hazardous
Waste
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15
Exhibit
4:
EPA
Regions
Responding
to
8
Applications
for
MSWLF
Permit
Programs.
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16
Exhibit
5:
Total
Burden
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.19
3
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
and
Number
of
the
Information
Collection
This
Information
Collection
Request
(
ICR)
is
entitled
"
Municipal
Solid
Waste
Landfills
(
MSWLFs)
and
State
Program
Adequacy
Determination­
Non­
municipal,
Non­
hazardous
Waste
Disposal
Units
that
Receive
Conditionally
Exempt
Small
Quantity
Generator
(
CESQG)
Hazardous
Waste
(
Renewal),"
ICR
number
1608.04.

The
request
for
public
comment
for
this
ICR
was
published
in
the
Federal
Register
on
January
04,
2005
(
70
FR
356);
no
comments
were
received.

1(
b)
Short
Characterization
Section
4010(
c)
of
the
Resource
Conservation
and
Recovery
Act
(
RCRA)
of
1976
requires
that
the
Environmental
Protection
Agency
(
EPA)
revise
the
landfill
criteria
promulgated
under
paragraph
(
1)
of
Section
4004(
a)
and
Section
1008(
a)(
3).
Section
4005(
c)
of
RCRA,
as
amended
by
the
Hazardous
Solid
Waste
Amendments
(
HSWA)
of
1984,
requires
states
to
develop
and
implement
permit
programs
to
ensure
that
non­
municipal,
non­
hazardous
waste
disposal
units
that
receive
household
hazardous
waste
or
CESQG
hazardous
waste
and
municipal
solid
waste
landfills
are
in
compliance
with
the
revised
criteria
for
the
design
and
operation
of
non­
municipal,
non­
hazardous
waste
disposal
units
under
40
CFR
part
257,
subpart
B
and
MSWLFs
under
40
CFR
part
258.
(
40
CFR
part
257,
subpart
B
and
40
CFR
part
258
are
henceforth
referred
to
as
the
"
revised
federal
criteria".)
Section
4005(
c)
of
RCRA
further
mandates
the
EPA
Administrator
to
determine
the
adequacy
of
state
permit
programs
to
ensure
owner/
operator
compliance
with
the
revised
federal
criteria.
A
state
program
that
is
deemed
adequate
to
ensure
compliance
may
afford
flexibility
to
owners/
operators
in
the
approaches
they
use
to
meet
federal
requirements,
significantly
reducing
the
burden
associated
with
compliance.

In
response
to
the
statutory
requirement
in
§
4005(
c),
EPA
developed
40
CFR
part
239,
commonly
referred
to
as
the
State
Implementation
Rule
(
SIR).
The
SIR
describes
the
state
application
and
EPA
review
procedures
and
defines
the
elements
of
an
adequate
state
permit
program.

The
collection
of
information
from
the
state
during
the
permit
program
adequacy
determination
process
allows
EPA
to
evaluate
whether
a
program
for
which
approval
is
requested
is
appropriate
in
structure
and
authority
to
ensure
owner/
operator
compliance
with
the
40
CFR
part
257,
subpart
B
and/
or
the
40
CFR
part
258
criteria.
The
SIR
does
not
require
the
use
of
a
particular
application
form.
However,
§
239.3
of
the
SIR
requires
that
all
state
applications
contain
the
following
five
components:

(
1)
A
transmittal
letter
requesting
permit
program
approval;
4
(
2)
A
narrative
description
of
the
state
permit
program,
including
a
demonstration
that
the
state's
non­
municipal,
non­
hazardous
waste
disposal
units
that
receive
CESQG
hazardous
standards
are
technically
comparable
to
the
part
257,
subpart
B
criteria
and/
or
that
its
MSWLF
standards
are
technically
comparable
to
the
part
258
criteria;

(
3)
A
legal
certification
demonstrating
that
the
state
has
the
authority
to
carry
out
the
program;

(
4)
Copies
of
relevant
state
laws,
regulations,
and
guidance
that
the
state
believes
demonstrate
program
adequacy;
and
(
5)
Copies
of
relevant
state­
tribal
agreements
if
the
state
has
negotiated
with
a
tribe
for
the
implementation
of
a
permit
program
for
non­
municipal,
non­
hazardous
waste
disposal
units
that
receive
CESQG
hazardous
waste
and/
or
municipal
solid
waste
landfills
on
Indian
Lands.

A
more
detailed
description
of
the
data
elements,
respondent
activities,
and
Record
keeping
requirements
associated
with
each
of
the
information
collection
requirements
is
presented
in
Section
3.

The
attached
supporting
statement
provides
justification
for
the
information
collection
requirements
included
in
40
CFR
part
239.
It
examines
the
burden
to
states
associated
with
preparing
and
submitting
a
program
application
that
complies
with
SIR
requirements.
This
ICR
also
estimates
the
cost
that
the
federal
government
will
incur
in
reviewing
state
program
applications
and
determining
the
adequacy
of
state
permit
programs.

2.
NEED
FOR
AND
USE
OF
THE
INFORMATION
COLLECTION
2(
a)
Need
and
Authority
for
the
Information
Collection
Section
4010(
c)
of
RCRA
requires
EPA
to
establish
minimum
criteria
to
ensure
that
nonmunicipal
non­
hazardous
waste
disposal
units
that
receive
CESQG
hazardous
waste
and
MSWLFs
are
designed
and
managed
in
a
manner
that
is
protective
of
human
health
and
the
environment.
40
CFR
part
257,
subpart
B
establishes
these
minimum
federal
criteria
for
nonmunicipal
non­
hazardous
waste
disposal
units
that
receive
CESQG
hazardous
waste
and
40
CFR
part
258
establishes
them
for
MSWLFs.
The
statute
also
requires
states
to
adopt
permit
programs
to
ensure
that
owners
and
operators
of
both
types
of
waste
disposal
units
comply
with
the
relevant
federal
criteria.

The
need
for
this
collection
of
information
from
the
states
derives
from
Section
4005(
c)
of
RCRA
which
requires
the
EPA
Administrator
to
review
state
permit
programs
to
determine
if
they
are
adequate
to
ensure
compliance
with
the
federal
criteria.
The
SIR
(
40
CFR
part
239)
establishes
the
procedures
EPA
has
developed
to
carry
out
this
mandate.
To
make
the
required
determination,
EPA
must
collect
information
from
states.
That
information
is
provided
to
the
Agency
in
the
context
of
an
application
for
permit
program
approval.

States
which
do
not
submit
the
information
necessary
to
make
a
determination
of
program
adequacy
will
be
deemed
to
have
inadequate
programs.
Where
the
state
program
is
deemed
inadequate,
owners
and
operators
of
both
non­
municipal,
non­
hazardous
waste
disposal
units
and
5
MSWLFs
must
comply
with
the
self­
implementing
provisions
of
the
federal
revised
criteria
in
40
CFR
part
257,
subpart
B
and
40
CFR
part
258,
and
may
not
be
able
to
take
advantage
of
the
flexibility
that
may
be
afforded
to
owners/
operators
by
states
with
approved
permit
programs.

EPA
has
granted
full
approval
to
49
states
and
territories
for
their
MSWLF
programs
under
40
CFR
258.
In
addition,
EPA
has
determined
that
45
states
have
adequate
provisions
in
place
to
require
that
CESQG
waste
is
disposed
in
suitable
facilities.

2(
b)
Practical
Utility/
Users
of
the
Data
The
EPA
Administrator
has
delegated
the
authority
to
make
determinations
of
adequacy,
as
contained
in
the
statute,
to
the
EPA
Regional
Administrators.
Therefore,
the
appropriate
EPA
Regional
Office
uses
the
information
provided
by
each
state
to
determine
whether
the
state's
permit
program
satisfies
the
statutory
test
reflected
in
the
requirements
of
40
CFR
part
239.
In
all
cases,
the
information
is
analyzed
to
determine
the
adequacy
of
the
state's
permit
program
for
ensuring
compliance
with
the
federal
revised
criteria.

3.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
3(
a)
Respondents/
SIC
Codes
The
universe
of
respondents
involved
in
this
information
collection
will
be
limited
to
states
that
seek
approval
of
their
permit
programs
or
modifications
to
their
previously
approved
permit
programs
for
non­
municipal,
non­
hazardous
waste
disposal
units
that
receive
CESQG
waste
and/
or
for
MSWLFs.
This
information
collection
effort
includes
approved
states
that
revise
their
criteria
for
MSWLFs
to
allow
states
to
issue
research,
development,
and
demonstration
(
RD&
D)
permits
for
new
and
existing
MSWLF
units
and
lateral
expansions.
No
entities
with
SIC
codes
will
be
affected
by
this
information
collection.

3(
b)
Information
Requested
Develop
Program
Application
States
requesting
program
approval
must
submit
a
program
application
as
described
in
the
SIR.
Prior
to
the
final
submission,
EPA
encourages
the
states
to
submit
draft
applications
for
Agency
comment
and
suggestions.
The
costs
of
draft
application
submission
are
incorporated
into
the
costs
of
final
application
submission.

(
i)
Data
Items,
Including
Record
keeping
Requirements
EPA
is
not
prescribing
Record
keeping
requirements
for
applicants
associated
with
this
rule.
The
primary
data
item
for
the
adequacy
determination
process
is
the
state
program
application.
Data
items
include:

$
Narrative
description
of
the
state
program(
s)

$
Transmittal
letter
6
$
Legal
certification
$
Copies
of
relevant
statutes,
regulations,
and
guidance
$
Copies
of
relevant
state­
tribal
agreements
(
ii)
Respondent
Activities
$
Read
the
SIR
and
40
CFR
part
257,
subpart
B
and/
or
40
CFR
part
258
$
Prepare
the
narrative
program
description
$
Write
the
transmittal
letter
$
Prepare
the
legal
certification
$
Compile
relevant
statutes,
regulations,
and
guidance
$
Compile
relevant
agreements
between
state
and
tribe(
s)

Adequacy
Determination
Process
The
state
will
submit
a
formal
application
containing
all
required
elements,
to
the
appropriate
EPA
Regional
Office.
After
the
formal
application
has
been
reviewed
by
the
EPA
Region,
the
Agency
may
request
revisions
or
additional
information
from
the
state,
particularly
in
response
to
comments
received
during
the
public
comment
period
that
the
Agency
is
required
to
provide.
The
state
will
meet
with
the
EPA
Region
to
discuss
such
changes
and
may
need
to
modify
and
resubmit
the
application.

(
i)
Data
Items,
including
Record
keeping
Requirements
Under
this
rule,
EPA
is
not
prescribing
Record
keeping
requirements
for
applicants.
The
primary
data
item
for
the
adequacy
determination
process
is
the
state
program
application.

(
ii)
Respondent
Activities
$
Submit
an
application
for
state
program
approval
$
Modify
the
application,
if
necessary,
to
respond
to
comments
from
the
EPA
Region
and/
or
the
public
$
Resubmit
the
application,
if
necessary
4.
THE
INFORMATION
COLLECTED
­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
4(
a)
Agency
Activities
7
Develop
Program
Application
As
the
states
develop
and
complete
their
program
applications,
the
appropriate
EPA
Regions
will
review
them
and
provide
written
comments
to
the
state.
As
part
of
this
process,
a
Region
may
conduct
meetings
with
state
representatives.

Adequacy
Determination
Process
After
a
Region
determines
that
a
state
application
is
complete,
the
Region
will
review
it
and
make
a
final
adequacy
determination.
The
Region
will
make
every
attempt
to
complete
its
review
and
make
a
final
determination
of
adequacy
within
180
days
of
receipt
of
a
complete
application;
however,
submission
of
an
application
for
program
approval
does
not
ensure
automatic
approval
should
EPA
fail
to
meet
the
180
day
time
frame.
During
the
review
process,
the
Region
will
be
responsible
for
the
following
activities:

$
Review
the
application
for
completeness
and
request
additional
information
if
necessary;

$
Review
the
completed
application,
draft
and
forward
comments
to,
and
meet
with
state
as
needed;

$
After
consultation
with
Regional
staff,
the
Regional
Administrator
will
make
a
tentative
determination;

$
Prepare
and
publish
a
Federal
Register
notice
of
tentative
determination;

$
Hold
public
hearing(
s),
if
necessary;

$
Respond
to
public
comments
if
significant
comments
are
received;

$
After
meetings
between
the
Regional
and
state
staff
to
resolve
any
remaining
issues,
the
Regional
Administrator
will
make
a
final
determination;
and
$
Prepare
and
publish
a
Federal
Register
notice
of
final
determination.

4(
b)
Collection
Methodology
and
Management
EPA
does
not
prescribe
through
regulation
the
manner
in
which
the
application
is
to
be
submitted:
Respondents
have
flexibility
regarding
the
manner
in
which
they
submit
information
(
i.
e.,
hardcopy
or
electronically
word
processed);
however,
database
submission
is
not
practicable.
Regions
will
be
required
to
maintain
a
copy
of
the
notice
of
proposed
rulemaking
for
public
review
and
a
docket
for
the
final
rule.
These
records
may
be
kept
at
a
public
library,
where
they
will
require
minimal
space
and
upkeep.

4(
c)
Small
Entity
Flexibility
8
The
rule
requires
states
to
submit
applications
for
permit
program
approval
for
non­
municipal,
non­
hazardous
waste
disposal
units
that
receive
CESQG
hazardous
waste
and/
or
for
municipal
solid
waste
landfills.
It
does
not
impact
the
flexibility
of
small
entities.

4(
d)
Collection
Schedule
The
40
CFR
part
258
criteria
were
promulgated
on
October
9,
1991
and
were
generally
effective
beginning
on
October
9,
1993.
Criteria
for
non­
municipal,
non­
hazardous
waste
disposal
units
that
receive
CESQG
hazardous
waste
(
40
CFR
part
257,
subpart
B)
were
promulgated
on
July
1,
1996.
Location
and
record
keeping
criteria
were
effective
on
January
1,
1998
and
groundwater
monitoring
and
corrective
action
requirements
became
effective
on
July
1,
1998.
Research,
Development,
and
Demonstration
Permits
for
MSWLFs
(
40
CFR
part
285.4,
subpart
A)
became
effective
on
April
21,
2004.
Requirements
for
States
and
Territiories
to
submit
applications
for
determination
of
adequacy
of
their
Subtitle
D
solid
waste
programs
and
procedures
for
EPA
determination
of
adequacy
are
contained
in
40
CFR
239.
EPA
has
determined
that
30
states
have
existing
permit
programs
for
CESQG
hazardous
waste
disposal
that
are
adequate
to
meet
the
40
CFR
part
257,
subpart
B
requirements.

States
have
been
encouraged
to
apply
for
and
gain
program
approval
as
quickly
as
possible,
to
allow
the
state
and
facility
owners/
operators
to
fully
utilize
the
flexibility
in
the
part
257,
subpart
B
and
part
258
criteria.
Schedules
submitted
in
lieu
of
an
application
were
expected
to
outline
how
the
state
would
make
progress
toward
completing
its
application.
States
failing
to
submit
an
application
within
the
scheduled
time
frame
could
be
deemed
"
inadequate."

5.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
5(
a)
Nonduplication
The
information
collection
covered
in
this
ICR
is
not
available
from
sources
other
than
the
respondents.
There
is
no
other
federal
agency
that
collects
information
on
the
adequacy
of
state
non­
municipal,
non­
hazardous
waste
disposal
units
that
receive
CESQG
hazardous
waste
and/
or
of
MSWLF
permit
programs.
Therefore,
this
information
collection
does
not
represent
a
duplicative
effort
by
any
other
source.

5(
b)
Effects
of
Less
Frequent
Collection
EPA
has
encouraged
states
to
work
with
regional
EPA
staff,
and
to
submit
early
drafts
to
ensure
that
their
applications
are
complete,
with
sufficient
detail
to
lessen
the
potential
need
for
revision.
It
is
anticipated
that,
due
to
the
extensive
interaction
between
states
and
the
regional
EPA
staff
in
the
development
of
both
the
permit
programs
and
the
applications
for
adequacy
determinations,
states
will
not
be
required
to
submit
revised
applications.

Additional
review
and
revision
of
state
programs
may
be
needed
when
federal
or
state
statutory
or
regulatory
authorities
are
subsequently
altered
or
when
the
state
shifts
permit
program
9
responsibility
from
one
agency
to
another.
The
Regional
Administrator
will
determine,
on
a
caseby
case
basis,
whether
subsequent
statutory
or
regulatory
changes
warrant
revision
of
the
state
program
or
modifications
to
a
state's
original
program
approval
application..
Procedures
for
this
process
are
detailed
in
40
CFR
part
239.12
and
are
designed
to
minimize
state
burdens.

5(
c)
Consultations
EPA
made
substantial
efforts
to
consult
with
state
officials
during
the
development
of
the
State
Implementation
Rule.
During
this
time
EPA
met
with
the
following
people:
Tom
Kennedy
and
Kerry
Callahan,
Association
of
State
and
Territorial
Solid
Waste
Management
Officials
(
ASTSWMO);
Richard
Barlow,
Connecticut;
James
Dunbar,
Georgia;
Thomas
Epstein,
Rhode
Island;
Bill
Cass
and
Carol
Ansheles,
Northeast
Waste
Management
Officials
Association
(
NEWMOA);
Hector
Mendietta,
Texas;
Jim
Warner,
Minnesota;
Neil
Weber,
New
Mexico;
Mark
Witherspoon,
Arkansas;
and
other
state
personnel.
EPA,
through
ASTSWMO,
provided
copies
of
drafts
for
the
State
Implementation
Rule,
at
various
stages
in
its
development,
to
provide
all
states
and
territories
an
opportunity
for
input
on
the
procedures
used
to
assess
the
adequacy
of
affected
state
permitting
programs.

5(
d)
General
Guidelines
This
ICR
adheres
to
guidelines
stated
in
the
1980
Paperwork
Reduction
Act,
as
amended
in
1995,
OMB's
implementing
regulations,
OMB's
Information
Collection
Review
Handbook,
and
other
applicable
OMB
guidance.

5(
e)
Confidentiality
and
Sensitive
Questions
The
information
that
states
would
submit
is
public
information;
therefore,
no
problems
of
confidentiality
or
sensitive
questions
arise.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
The
following
burden
and
cost
estimates
are
based
upon
EPA's
experience
in
processing
state
MSWLF
permit
program
adequacy
determinations.
The
estimates
also
reflect
the
Agency's
burden
and
costs
from
reviewing
similar
activities
of
other
regulatory
programs,
and
from
discussions
with
states.

Under
40
CFR
part
257,
subpart
B,
owners/
operators
of
non­
municipal,
non­
hazardous
disposal
units
that
receive
CESQG
hazardous
waste
must
comply
with
location
restrictions,
ground­
water
monitoring,
and
corrective
action
standards.
EPA
has
determined
that
45
states
have
existing
permit
programs
for
CESQG
hazardous
waste
disposal
that
are
adequate
to
meet
the
40
CFR
part
257,
subpart
B
requirements.
Over
the
next
three
years,
EPA
expects
up
to
5
additional
states/
territories
to
seek
permit
program
adequacy
determinations
for
non­
municipal,
nonhazardous
waste
disposal
units
that
receive
CESQG
hazardous
waste.
The
burden
and
cost
estimates
for
the
permit
program
adequacy
determinations
for
non­
municipal,
non­
hazardous
waste
disposal
units
that
receive
CESQG
hazardous
waste
will
be
higher
than
for
the
streamlined
approval
process
used
for
the
45
states
already
approved,
but
less
than
for
the
MSWLF
permit
program
adequacy
determinations
because
the
requirements
for
non­
municipal,
non­
hazardous
10
disposal
units
that
receive
CESQG
hazardous
waste
are
less
cumbersome
than
those
required
for
MSWLFs.

To
date,
EPA
has
fully
or
partially
approved
54
state/
territorial
MSWLF
permit
programs.
Over
the
next
three
years,
EPA
expects
to
receive
permit
program
applications
from
the
remaining
2
states/
territories
and
expects
up
to
5
states/
territories
to
modify
previously
approved
programs.
EPA
expects
9
approved
states
over
the
next
three
years
to
seek
RD&
D
approval
for
MSWLFs.

6(
a)
Estimating
Respondent
Burden
EPA
estimates
respondent
burden
hours
associated
with
all
of
the
requirements
covered
in
this
ICR
in
Exhibits
1­
5.
Separate
scenarios
were
developed
for
MSWLF
and
non­
municipal,
nonhazardous
waste
permit
program
approval
applications.
Each
is
presented
in
a
chart
at
the
end
of
this
statement
which
shows
the
estimated
burden
hours
and
costs
for
each
collection
activity.

$
Exhibit
1
assumes
that
5
states/
territories
will
submit
permit
program
approval
applications
for
non­
municipal,
non­
hazardous
waste
disposal
units
that
receive
CESQG
hazardous
waste.

$
Exhibit
2
assumes
that
2
states/
territories
will
submit
an
application
for
MSWLF
permit
program
approval
(
Exhibit
2a)
and
that
5
states
will
modify
their
existing
approved
programs
(
Exhibit
2b).

6(
b)
Estimating
Respondent
Costs
The
average
hourly
salary
rates
contained
in
the
current
ICR
for
this
rule
were
from
2001.
For
this
ICR
renewal
request
EPA
used
rates
from
the
2004
GS
salary
table,
Step
5
and
applied
an
overhead
factor
of
1.6.

For
states
and
territories,
EPA
estimates
an
average
hourly
salary
rate
of
$
64.59
(
GS
14)
for
legal
staff,
$
75.97
(
GS
15)
for
managerial
staff,
$
45.97
(
GS
12)
for
technical
staff,
and
$
25.90
(
GS
7)
for
clerical
staff.
These
rates
include
the
overhead
factor
of
1.6.

6(
c)
Estimating
Agency
Burden
and
Cost
In
estimating
Agency
burden
hours
and
costs
associated
with
activities
in
this
ICR,
EPA
examined
ICRs
that
had
already
been
approved
by
OMB.
ICRs
reviewed
include
those
for
the
UST
program,
Subtitle
C
program,
and
the
original
ICR
that
is
now
being
renewed.

Estimates
of
Agency
burden
hours
and
costs
associated
with
all
of
the
requirements
of
this
ICR
are
provided
in
Exhibits
3
and
4.
EPA
Regional
Offices
will
be
involved
in
these
activities.

$
Exhibit
3
estimates
EPA's
burden
and
costs
for
responding
to
permit
program
approval
applications
for
non­
municipal,
non­
hazardous
waste
disposal
units
that
receive
CESQG
hazardous
waste.
11
$
Exhibit
4
estimates
EPA's
burden
and
costs
for
responding
to
both
new
and
modified
MSWLF
permit
program
applications.

Agency
Burden
Estimates
Agency
burden
figures
are
based
on
EPA's
experience
in
undertaking
and
completing
this
activity
to
date.
Since
it
is
not
possible
to
accurately
estimate
how
many
respondents
will
submit
applications
in
a
given
year,
the
estimates
show
total
estimated
burden
and
costs
during
the
three
year
period
suggested
for
submission
in
the
regulation.
Average
annual
burden
is
obtained
by
dividing
the
total
burden
by
three.

Agency
Labor
Costs
The
average
hourly
salary
rates
contained
in
the
current
ICR
for
this
rule
were
from
2001.
For
this
ICR
renewal
request
EPA
used
rates
from
the
2004
GS
salary
table,
Step
5
and
applied
an
overhead
factor
of
1.6.

EPA
estimates
an
average
hourly
Regional
labor
cost
of
$
64.59
(
GS
14)
for
legal
staff,
$
75.97
(
GS
15)
for
managerial
staff,
$
45.97
(
GS
12)
for
technical
staff,
and
$
25.90
(
GS
7)
for
clerical
staff.
These
hourly
rates
include
the
standard
government
overhead
factor
of
1.6.

6(
d)
Bottom
Line
Burden
Hours
and
Costs
Exhibit
5
shows
the
total
burden
and
cost
to
respondents
and
the
State
and
government
for
all
information
collection
requirements
covered
in
this
ICR.
EPA
estimates
that
the
total
bottom
line
burden
for
this
information
collection
activity
is
$
352,758
or
$
117,586
per
year.

6(
e)
Respondent
Universe
and
Total
Burden
Costs
The
total
number
of
respondents
are
12
and
the
total
burden
hours
are
7,214
over
3
years,
or
2,405
hours
per
year.
The
total
cost
burden
is
$
352,758
over
3
years,
or
$
117,586
per
year.

6(
f)
Reasons
For
Change
in
Burden
This
ICR
replaces
ICR
1608.03,
approved
by
OMB
through
June
30,
2005.
Burden
hours
for
this
ICR
continue
to
decrease.
For
the
prior
ICR
renewal
all
mention
of
burden
estimates
for
tribes
which
were
contained
in
the
original
ICR
were
removed.
In
addition,
since
the
last
clearance,
additional
states
and
territories
have
been
moving
through
the
approval
process
for
their
MSWLF
permit
programs.
Therefore,
the
number
of
state
and
territorial
remaining
to
obtain
MSWLF
permit
program
adequacy
determinations
has
decreased
from
3
to
2.
In
addition,
EPA
estimates
that
as
many
as
5
states
may
choose
to
submit
modifications
to
their
approved
programs.

Under
the
July
1,
1996
rulemaking
for
non­
municipal,
non­
hazardous
waste
disposal
units
that
may
receive
CESQG
hazardous
waste,
45
states/
territories
have
received
CESQG
hazardous
12
waste
permit
program
adequacy
determinations.
EPA
estimates
that
no
more
than
5
additional
States
will
apply
for
an
adequacy
determination
during
the
next
3
years.

6(
g)
Burden
Statement
The
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
242
hours
per
response.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
and
48
CFR
chapter
15.

6(
h)
Request
for
Comments
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
0020,
which
is
available
for
public
viewing
at
the
Office
of
Solid
Waste
and
Emergency
Response
(
OSWER)
Docket
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
OSWER
Docket
is
(
202)
566­
0270.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Please
include
the
EPA
Docket
ID
No.
(
RCRA­
2004­
0020)
and
OMB
control
number
(
2050­
0152)
in
any
correspondence.
13
EXHIBITS
EXHIBIT
1:
5
STATES/
TERRITORIES
APPLICATIONS
FOR
NON­
MUNICIPAL,
NONHAZARDOUS
WASTE
DISPOSAL
UNITS
THAT
RECEIVE
CESQG
HAZARDOUS
WASTE
PERMIT
PROGRAMS
Collection
Activities
Burden
Hours
per
Applicant
Legal
$
64.59
per
hour
Manager
$
75.97
per
hour
Technical
$
45.97
per
hour
Clerical
$
25.90
per
hour
Total
Hours
Read
40
CFR
part
239
and
40
CFR
part
257,
subpart
B
5
10
32.5
0
47.5
Prepare
narrative
program
description
0
20
80
20
120
Write
transmittal
memorandum
0
0.5
1
0.5
2
Prepare
legal
certification
1.5
0.5
0
0.5
2.5
Compile
copies
of
relevant
statutes,
regulations,
and
guidance
4
0
4
7.5
15.5
Modify
application,
as
necessary
4
10
40
10
64
Total
hours
per
Respondent
14.5
41
157.5
38.5
251.5
Total
cost
per
Respondent
$
936.56
$
3,114.77
$
7,240.28
$
997.15
$
12,288.76
Total
Burden:
Hour
Total
(
251.5)
x
No.
of
Respondents
(
5)
=
1,258
Hours
Total
Cost:
Cost
Total
($
12,288.76)
x
No.
of
Respondents
(
5)
=
$
61,443.80.
14
EXHIBIT
2:
7
STATE/
TERRITORIES
PREPARING
APPLICATIONS
FOR
MSWLF
PERMIT
PROGRAMS
EXHIBIT
2a:
2
STATES/
TERRITORIES
PREPARING
NEW
APPLICATIONS
Collection
Activities
Burden
Hours
per
Applicant
Legal
$
64.59
per
hour
Manager
$
75.97
per
hour
Technical
$
45.97
per
hour
Clerical
$
25.90
per
hour
Total
Hours
Read
40
CFR
part
239
and
40
CFR
part
258
10
20
65
0
95
Prepare
narrative
program
description
0
40
160
40
240
Write
transmittal
memorandum
0
1
2
1
4
Prepare
legal
certification
3
1
0
1
5
Compile
copies
of
relevant
statutes,
regulations,
and
guidance
8
0
8
15
31
Modify
application,
as
necessary
8
20
80
20
128
Total
hours
per
Respondent
29
82
315
77
503
Total
cost
per
Respondent
$
1,873.11
$
6,229.54
$
14,480.55
$
1,994.30
$
24,577.50
Total
Burden:
Hour
Total
(
503)
x
No.
of
Respondents
(
2)
=
1,006
Hours
Total
Cost:
Cost
Total
($
24,577.50)
x
No.
of
Respondents
(
2)
=
$
49,155
EXHIBIT
2b:
5
STATES/
TERRITORIES
MODIFYING
APPROVED
PROGRAMS
Collection
Activities
Burden
Hours
per
Applicant
Legal
$
64.59
per
hour
Manager
$
75.97
per
hour
Technical
$
45.97
per
hour
Clerical
$
25.90
per
hour
Total
Hours
Modify
program,
as
necessary
8
20
80
20
128
Total
hours
per
Respondent
8
20
80
20
128
Total
cost
per
Respondent
$
516.72
$
1,519.40
$
3,677.60
$
518.00
$
6,231.72
Total
Burden:
Hour
Total
(
128)
x
No.
of
Respondents
(
5)
=
640
Hours
Total
Cost:
Cost
Total
($
6,231.72)
x
No.
of
Respondents
(
5)
=
$
31,158.60.

EXHIBIT
2
TOTAL
BURDEN
(
2a+
2b):
1,646
Hours
TOTAL
COST
(
2a+
2b):
$
80,313.60
15
EXHIBIT
3:
EPA
REGIONS
RESPONDING
TO
5
APPLICATIONS
FOR
NON­
MUNICIPAL,
NON­
HAZARDOUS
WASTE
DISPOSAL
UNITS
THAT
RECEIVE
CESQG
HAZARDOUS
WASTE
PERMIT
PROGRAMS
Collection
Activities
Burden
Hours
per
Application
Legal
$
64.59
per
hour
Manager
$
75.97
per
hour
Technical
$
45.97
per
hour
Clerical
$
25.90
per
hour
Total
Hours
Review
and
comment
on
draft
application,
including
meetings
with
applicant
5
5
40
8
58
Process
and
distribute
application
0
0
5
4
9
Review
application
for
completeness,
and
request
additional
information
5
5
40
1
51
Review
complete
application
1
5
20
8
34
Regional
Administrator
makes
tentative
determination
2
5
5
0
12
Prepare
and
publish
Federal
Register
notice
0
0.5
5
2.5
8
Hold
public
hearing
0
0
8
2.5
10.5
Respond
to
significant
comments
2
2
20
2.5
26.5
Regional
Administrator
makes
final
determination
2
5
5
0
12
Prepare
and
publish
Federal
Register
notice
2
0.5
8
2.5
13
Total
hours
per
Application
19
28
156
31
234
Total
cost
per
Application
$
1,227.21
$
2,127.16
$
7,171.32
$
802.90
$
11,328.59
Total
Burden:
Hour
(
234)
x
No.
of
Respondents
(
5)
=
1170
Hours
Total
Cost:
Cost
($
11,328.59)
x
No.
of
Respondents
(
5)
=
$
56,642.95.
16
EXHIBIT
4:
EPA
REGIONS
RESPONDING
TO
7
APPLICATIONS
FOR
MSWLF
PERMIT
PROGRAMS
EXHIBIT
4a:
EPA
REGIONS
RESPONDING
TO
2
"
NEW"
APPLICATIONS
Collection
Activities
Burden
Hours
per
Application
Legal
$
64.59
per
hour
Manager
$
75.97
per
hour
Technical
$
45.97
per
hour
Clerical
$
25.90
per
hour
Total
Hours
Review
and
comment
on
draft
application,
including
meetings
with
applicant
10
10
80
16
116
Process
and
distribute
application
0
0
10
8
18
Review
application
for
completeness,
and
request
additional
information
10
10
80
2
102
Review
complete
application
2
10
40
16
68
Regional
Administrator
makes
tentative
determination
4
10
10
0
24
Prepare
and
publish
Federal
Register
notice
0
1
10
5
16
Hold
public
hearing
0
0
16
5
21
Respond
to
significant
comments
4
4
40
5
53
Regional
Administrator
makes
final
determination
4
10
10
0
24
Prepare
and
publish
Federal
Register
notice
4
1
16
5
26
Total
hours
per
Application
38
56
312
62
468
Total
cost
per
Application
$
2,454.42
$
4,254.32
$
14,342.64
$
1,605.80
$
22,657.18
Total
Burden:
Hour
(
468)
x
No.
of
Respondents
(
2)
=
936
Hours
Total
Cost:
Cost
($
22,657.18)
x
No.
of
Respondents
(
2)
=
$
45,314.36.
17
EXHIBIT
4b:
EPA
REGIONS
RESPONDING
TO
5
"
MODIFIED"
APPLICATIONS
Collection
Activities
Burden
Hours
per
Application
Legal
$
64.59
per
hour
Manager
$
75.97
per
hour
Technical
$
45.97
per
hour
Clerical
$
25.90
per
hour
Total
Hours
Review
complete
application
2
10
40
16
68
Regional
Administrator
makes
tentative
determination
4
10
10
0
24
Prepare
and
publish
Federal
Register
notice
0
1
10
5
16
Hold
public
hearing
0
0
16
5
21
Respond
to
significant
comments
4
4
40
5
53
Regional
Administrator
makes
final
determination
4
10
10
0
24
Prepare
and
publish
Federal
Register
notice
4
1
16
5
26
Total
hours
per
Application
18
36
142
36
232
Total
cost
per
Application
$
1,162.62
$
2,734.92
$
6,527.74
$
932.40
$
11,357.68
Total
Burden:
Hour
(
232)
x
No.
of
Respondents
(
5)
=
1,160
Hours
Total
Cost:
Cost
($
11,357.68)
x
No.
of
Respondents
(
5)
=
$
56,788.40.
18
EXHIBIT
4c:
EPA
REGIONS
RESPONDING
TO
9
"
RD&
D"
APPLICATIONS
Collection
Activities
Burden
Hours
per
Application
Legal
$
64.59
per
hour
Manager
$
75.97
per
hour
Technical
$
45.97
per
hour
Clerical
$
25.90
per
hour
Total
Hours
Review
complete
application
1
5
20
2
28
Regional
Administrator
makes
tentative
determination
2
5
5
0
12
Prepare
and
publish
Federal
Register
notice
0
1
4
3
8
Hold
public
hearing
0
0
8
5
13
Respond
to
significant
comments
4
4
20
5
33
Regional
Administrator
makes
final
determination
2
5
5
0
12
Prepare
and
publish
Federal
Register
notice
2
1
4
3
10
Total
hours
per
Application
11
21
66
18
116
Total
cost
per
Application
$
710.49
$
1,595.37
$
3,034.02
$
466.20
$
5,806.08
Total
Burden:
Hour
(
116)
x
No.
of
Respondents
(
9)
=
1,044
Hours
Total
Cost:
Cost
($
5,806.08)
x
No.
of
Respondents
(
9)
=
$
52,254.72
EXHIBIT
4
TOTAL
BURDEN
(
4a+
4b+
4c):
3,140
Hours
TOTAL
COST
(
4a+
4b+
4c):
$
154,357.48
19
EXHIBIT
5:
TOTAL
BURDEN
EXHIBIT
5a:
TOTAL
HOUR
BURDEN
Regions
States/
Territories
Total
Preparing
Non­
Municipal,
Non­
Hazardous
Waste
Disposal
Units
that
Receive
CESQG
Hazardous
Waste
Permit
Program
Applications
1,170
1,258
2,428
Preparing
MSWLF
Permit
Program
Applications
3,140
1,646
4,786
Total
Burden
4,310
2,904
7,214
States/
Territories
Total
Hour
Burden:
2,904
hours
over
3
years,
or
968
hours
per
year
GRAND
TOTAL
HOUR
BURDEN:
7,214
hours
over
3
years,
or
2,405
hours
per
year
EXHIBIT
5b:
TOTAL
COST
BURDEN
(
Dollars)

Regions
States/
Territories
Total
Preparing
Non­
Municipal,
Non­
Hazardous
Waste
Disposal
Units
that
Receive
CESQG
Hazardous
Waste
Permit
Program
Applications
$
56,643
$
61,444
$
118,087
Preparing
MSWLF
Permit
Program
Applications
$
154,357
$
80,314
$
234,671
Total
Burden
$
211,000
$
141,758
$
352,758
States/
Territories
Total
Cost
Burden
(
Dollars):
$
141,798
over
3
years
or
$
47,249
per
year
GRAND
TOTAL
COST
BURDEN
(
Dollars):
$
352,758
over
3
years
or
$
117,586
per
year
