SUPPORTING
STATEMENT
FOR
INFORMATION
COLLECTION
REQUEST
NUMBER
1775.04
"
HAZARDOUS
REMEDIATION
WASTE
MANAGEMENT
REQUIREMENTS
(
HWIR­
MEDIA)"

August
30,
2005
TABLE
OF
CONTENTS
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
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1
1(
a)
Title
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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6
2(
a)
Need/
Authority
for
the
Collection
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6
2(
b)
Practical
Utility/
Users
of
the
Data
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10
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
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12
3(
a)
Nonduplication
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12
3(
b)
Public
Notice
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12
3(
c)
Consultations
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12
3(
d)
Effects
of
Less
Frequent
Collection
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13
3(
e)
General
Guidelines
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13
3(
f)
Confidentiality
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13
3(
g)
Sensitive
Questions
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14
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
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14
4(
a)
Respondent
SIC/
NAICS
Codes
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14
4(
b)
Information
Requested
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15
5.
THE
INFORMATION
COLLECTED
 
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY
AND
INFORMATION
MANAGEMENT
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28
5(
a)
Agency
Activities
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28
5(
b)
Collection
Methodology
and
Management
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33
5(
c)
Small
Entity
Flexibility
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33
5(
d)
Collection
Schedule
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33
6.
ESTIMATING
THE
HOUR
AND
COST
BURDEN
OF
THE
COLLECTION
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34
6(
a)
Estimating
Respondent
Hours
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34
6(
b)
Estimating
Respondent
Costs
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34
6(
c)
Estimating
Agency
Hour
and
Cost
Burden
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35
6(
d)
Estimating
the
Respondent
Universe
and
Total
Hour
and
Cost
Burden
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35
6(
e)
Bottom
Line
Hour
and
Cost
Burden
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40
6(
f)
Reasons
for
Change
in
Burden
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41
6(
g)
Burden
Statement
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41
Exhibit
1:
Estimated
Annual
Respondent
Hour
and
Cost
Burden
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43
Exhibit
2:
Estimated
Annual
Agency
Hour
and
Cost
Burden
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45
1
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
of
the
Information
Collection
This
Information
Collection
Request
(
ICR)
is
entitled
"
Hazardous
Waste
Management
Requirements
(
HWIR­
Media)
(
Renewal),"
ICR
Number
1775.04.

1(
b)
Short
Characterization
The
Resource
Conservation
and
Recovery
Act
of
1976
(
RCRA),
as
amended,
requires
the
U.
S.
Environmental
Protection
Agency
(
EPA)
to
establish
a
national
regulatory
program
to
ensure
that
hazardous
wastes
are
managed
in
a
manner
protective
of
human
health
and
the
environment.
Under
this
program
(
known
as
the
RCRA
Subtitle
C
program),
EPA
regulates
newly
generated
hazardous
wastes,
as
well
as
hazardous
remediation
wastes
(
i.
e.,
hazardous
wastes
managed
during
cleanup).

To
facilitate
prompt
and
protective
treatment,
storage,
and
disposal
of
hazardous
remediation
wastes,
EPA
established
three
requirements
for
remediation
waste
management
sites
that
are
different
from
those
for
facilities
managing
newly
generated
hazardous
waste:

°
Performance
standards
for
remediation
waste
management
sites
at
40
CFR
264.1(
j)
that
replaced
the
detailed
requirements
in
40
CFR
part
264,
subparts
B,
C,
and
D
(
General
Facility
Standards,
Preparedness
and
Prevention,
and
Contingency
Plans
and
Emergency
Procedures);

°
A
provision
excluding
remediation
waste
management
sites
from
RCRA
section
3004(
u)'
s
requirements
for
facility­
wide
corrective
action;
and
°
A
new
form
of
RCRA
permit
for
treating,
storing,
and
disposing
of
hazardous
remediation
wastes
at
40
CFR
part
270,
subpart
H.
The
new
permit,
a
Remedial
Action
Plan
(
RAP),
streamlines
the
permitting
process
for
remediation
waste
management
sites
to
allow
cleanups
to
take
place
more
quickly.

In
addition,
EPA
created
a
new
kind
of
unit
called
a
"
staging
pile"
at
40
CFR
264.554
that
allows
more
flexibility
in
storing
remediation
waste
during
cleanup.

This
ICR
describes
the
requirements
applicable
to
owners/
operators
of
remediation
waste
management
sites
at
40
CFR
264.1(
j)
and
part
270,
subpart
H,
as
well
as
the
requirements
for
staging
piles
at
40
CFR
264.554.
It
replaces
the
previously
approved
ICR
on
remediation
waste
management
requirements
(
i.
e.,
ICR
Number
1775.03).
Sections
1
through
5
of
this
ICR
describe
2
1
Facilities
other
than
remediation
facilities
must
comply
with
40
CFR
part
264,
subparts
B,
C,
and
D.
the
specific
information
collection
requirements
(
e.
g.,
from
the
standpoint
of
need,
use,
respondent
activities).
In
Section
6,
EPA
estimates
the
annual
hour
and
cost
burden
to
respondents
and
the
Agency
under
these
requirements,
and
discusses
the
reasons
for
the
change
in
annual
burden
since
the
previously
approved
ICR.

Following
is
a
brief
description
of
the
information
collection
requirements
applicable
to
owners/
operators
of
remediation
waste
management
sites.

(
1)
General
Requirements
for
Hazardous
Remediation
Waste
Management
Sites
Hazardous
remediation
waste
management
sites
must
comply
with
all
parts
of
40
CFR
part
264
except
subparts
B,
C,
and
D,
and
section
264.101.
In
place
of
the
requirements
in
subparts
B,
C,
and
D,
however,
they
need
to
comply
with
performance
standards
based
on
the
general
requirement
goals
in
these
sections,
which
are
codified
at
40
CFR
264.1(
j).
1
40
CFR
264.1(
j)(
1)
requires
owners/
operators
of
remediation
waste
management
sites
to
obtain
an
EPA
identification
number.

40
CFR
264.1(
j)(
2)
requires
owners/
operators
of
remediation
waste
management
sites
to
obtain
a
detailed
chemical
and
physical
analysis
of
a
representative
sample
of
the
hazardous
remediation
wastes
to
be
managed
at
the
site.
At
a
minimum,
the
waste
analysis
must
contain
all
the
information
that
must
be
known
to
treat,
store
or
disposed
of
the
waste
in
accordance
with
40
CFR
parts
264
and
268,
and
must
be
kept
accurate
and
up
to
date.

40
CFR
264.1(
j)(
4)
requires
owners/
operators
to
inspect
the
remediation
waste
management
site
for
malfunctions,
deterioration,
operator
errors,
and
discharges
that
may
be
causing,
or
may
lead
to,
a
release
of
hazardous
waste
constituents
to
the
environment,
or
a
threat
to
human
health.
The
owner/
operator
must
conduct
these
inspections
often
enough
to
identify
problems
in
time
to
correct
them
before
they
harm
human
health
or
the
environment,
and
must
remedy
the
problem
before
it
leads
to
a
human
health
or
environmental
hazard.
Where
a
hazard
is
imminent
or
has
already
occurred,
the
owner/
operator
must
take
remedial
action
immediately.

Under
40
CFR
264.1(
j)(
7),
owners/
operators
of
remediation
waste
management
sites
must
design,
construct,
operate,
and
maintain
units
within
a
100­
year
floodplain
to
prevent
washout
of
any
hazardous
waste
by
a
100­
year
flood,
unless
they
can
meet
the
demonstration
requirements
of
section
264.18(
b).

40
CFR
264.1(
j)(
9)
requires
owners/
operators
to
develop
and
maintain
a
construction
quality
assurance
program
for
all
surface
impoundments,
waste
piles,
and
landfill
units
that
are
required
to
comply
with
sections
264.221(
c)
and
(
d),
264.251(
c)
and
(
d),
and
264.301(
c)
and
(
d)
3
at
the
remediation
waste
management
site,
according
to
the
requirements
of
section
264.19.

40
CFR
264.1(
j)(
10)
requires
owners/
operators
of
remediation
waste
management
sites
to
develop
and
maintain
procedures
to
prevent
accidents.
These
procedures
must
address
proper
design,
construction,
maintenance,
and
operation
of
hazardous
remediation
waste
management
units
at
the
site.
In
addition,
owners/
operators
must
develop
and
maintain
a
contingency
and
emergency
plan
to
control
accidents
that
occur.
The
plan
must
explain
specifically
how
to
treat,
store,
and
dispose
of
the
hazardous
remediation
waste
in
question,
and
must
be
implemented
immediately
whenever
fire,
explosion,
or
release
of
hazardous
waste
or
hazardous
waste
constituents
that
could
threaten
human
health
or
the
environment.

40
CFR
264.1(
j)(
12)
requires
owners/
operators
of
remediation
waste
management
sites
to
develop,
maintain,
and
implement
a
plan
to
meet
the
requirements
in
sections
264.1(
j)(
2)
through
(
j)(
6)
and
sections
264.1(
j)(
9)
through
(
j)(
10).

40
CFR
264.1(
j)(
13)
requires
owners/
operators
of
remediation
waste
management
sites
to
maintain
records
documenting
compliance
with
sections
264.1(
j)(
1)
through
(
j)(
12).
Under
40
CFR
264.73(
b)(
17),
owners/
operators
of
remediation
waste
management
sites
are
required
to
record,
as
it
becomes
available,
and
maintain
in
the
operating
record
any
records
required
under
section
264.1(
j)(
13).

(
2)
Requirements
for
Staging
Piles
A
staging
pile
is
an
accumulation
of
remediation
waste
that
is
not
a
containment
building
and
is
used
only
during
remedial
operations
for
temporary
storage
at
a
facility.
A
staging
pile
is
not
subject
to
land
disposal
restrictions
or
minimum
technology
requirements
and
must
be
used
as
part
of
an
approved
RCRA
permit,
RAP,
closure
plan,
or
corrective
action
order
issued
under
section
3008(
h)
of
RCRA.

Under
40
CFR
264.554(
c)(
1),
owners/
operators
seeking
staging
pile
designations
must
provide
sufficient
and
accurate
information
to
enable
the
Director
to
impose
standards
and
design
criteria
for
the
staging
pile.
In
addition,
under
section
264.554(
c)(
2),
the
owner/
operator
must
provide
a
certification
by
an
independent,
qualified,
registered
professional
engineer
for
technical
data
(
e.
g.,
design
drawings
and
specifications,
engineering
studies),
unless
the
Director
determines,
based
on
information
provided
by
the
owner/
operator,
that
the
certification
is
not
necessary
to
ensure
that
the
staging
pile
will
protect
human
health
and
the
environment.
Finally,
under
section
264.554(
c)(
3),
the
owner/
operator
must
provide
any
additional
information
the
Director
determines
is
necessary
to
protect
human
health
and
the
environment.

As
provided
under
40
CFR
264.554(
d)(
1)(
iii),
a
staging
pile
must
not
operate
for
more
than
two
years,
except
when
the
Director
grants
an
operating
term
extension
under
section
264.554(
i).
The
owner/
operator
must
measure
the
two­
year
limit,
or
other
operating
term
specified
by
the
Director
in
the
permit,
closure
plan,
or
order,
from
the
first
time
remediation
4
waste
is
placed
into
the
staging
pile.
The
owner/
operator
must
maintain
a
record
of
the
date
when
remediation
waste
was
first
placed
into
the
staging
pile
for
the
life
of
the
permit,
order,
or
approved
closure
plan,
or
for
three
years,
whichever
is
longer.

Under
40
CFR
264.554(
i)(
1),
the
Director
may
grant
one
operating
term
extension
for
a
staging
pile
of
up
to
180
days
beyond
the
operating
term
limit
contained
in
the
permit,
closure
plan,
or
order.
To
obtain
an
extension,
owners/
operators
must
document
that
an
extension
will
not
pose
a
threat
to
human
health
and
the
environment
and
is
necessary
to
ensure
timely
and
efficient
implementation
of
remedial
actions
at
the
facility.

40
CFR
264.554(
k)
provides
that,
within
180
days
after
the
operating
term
of
the
staging
pile
expires,
owners/
operators
must
close
a
staging
pile
located
in
an
uncontaminated
area
of
the
site
in
accordance
with
sections
264.258(
a)
and
265.258(
a)
and
sections
264.111
and
265.111
(
i.
e.,
the
closure
requirements
for
waste
piles).

40
CFR
264.554(
l)
specifies
procedures
for
incorporating
staging
piles
into
existing
permits
(
including
RAPs),
closure
plans,
or
orders.
Pursuant
to
section
264.554(
l)(
1),
a
permit,
other
than
a
RAP,
may
be
modified
to
incorporate
a
staging
pile
or
staging
pile
operating
term
extension
as
part
of
an
Agency­
initiated
permit
modification
under
section
270.41or
as
part
of
an
owner/
operator
initiated
Class
2
permit
modification
under
section
270.42.
Pursuant
to
section
264.554(
l)(
2),
an
owner/
operator
may
modify
an
existing
RAP
to
incorporate
a
staging
pile
or
staging
pile
operating
term
extension
by
complying
with
the
RAP
modification
requirements
under
sections
270.170
and
270.175.
Pursuant
to
section
265.554(
l)(
3),
an
owner/
operator
may
modify
an
existing
closure
plan
to
incorporate
a
staging
pile
or
staging
pile
operating
term
extension
by
following
the
applicable
requirements
under
section
264.112(
c)
or
265.112(
c).
Pursuant
to
section
264.554(
l)(
4),
an
owner/
operator
may
modify
an
existing
order
to
incorporate
a
staging
pile
or
staging
pile
operating
term
extension
by
following
the
terms
of
the
order
and
the
applicable
provisions
of
section
270.72(
a)(
5)
or
270.72(
b)(
5).

(
3)
Remedial
Action
Plans
40
CFR
270.80(
a)
defines
a
RAP
as
a
special
form
of
RCRA
permit
that
an
owner/
operator
of
a
remediation
waste
management
site
may
obtain,
instead
of
a
permit
issued
under
sections
270.3
through
270.66,
to
treat,
store,
or
dispose
of
hazardous
remediation
waste
at
a
remediation
waste
management
site.

Under
40
CFR
270.85(
a),
whenever
an
owner/
operator
treats,
stores,
or
disposes
of
hazardous
remediation
waste
in
a
manner
that
requires
a
RCRA
permit
under
section
270.1,
the
owner/
operator
must
either
obtain
a
RCRA
permit
or
a
RAP.

Under
40
CFR
270.85(
c),
an
owner/
operator
may
obtain
a
RAP
for
managing
hazardous
remediation
waste
at
an
already
permitted
RCRA
facility.
This
RAP
must
be
approved
as
a
modification
to
the
existing
permit
according
to
the
requirements
of
section
270.41
or
section
5
270.42.
However,
when
the
owner/
operator
submits
an
application
for
such
modification,
the
information
requirements
in
section
270.42(
a)(
1)(
i),
(
b)(
1)(
iv),
and
(
c)(
1)(
iv)
do
not
apply;
instead,
the
owner/
operator
must
submit
the
information
required
under
section
270.110.
When
the
permit
is
modified,
the
RAP
becomes
part
of
the
RCRA
permit.

Under
40
CFR
270.95,
an
owner/
operator
may
apply
for
a
RAP
by
completing
an
application,
signing
it,
and
submitting
it
to
the
Director.

40
CFR
270.100
provides
that,
when
a
facility
or
remediation
waste
management
site
is
owned
by
one
person,
but
the
treatment,
storage,
or
disposal
activities
are
operated
by
another
person,
it
is
the
operator's
duty
to
obtain
a
RAP.
Under
section
270.105,
both
the
owner
and
the
operator
must
sign
the
RAP
application
and
any
required
reports
according
to
sections
270.11(
a)
through
(
c).
In
addition,
both
the
owner
and
the
operator
must
also
make
the
certification
required
under
section
270.11(
d)(
1).
However,
the
owner
may
choose
the
alternative
certification
under
section
270.11(
d)(
2)
if
the
operator
certifies
under
section
270.11(
d)(
1).

The
RAP
application
must
include
all
the
information
specified
in
section
270.110.
Under
section
270.115,
an
owner/
operator
may
claim
as
confidential
any
or
all
of
the
information
he
submits
to
EPA.
Any
such
claim
must
be
asserted
at
the
time
he
submits
his
RAP
application
or
other
submissions
by
stamping
the
words
"
confidential
business
information"
on
each
page
containing
such
information.
The
owner/
operator
must
submit
the
RAP
application
to
the
Director
for
approval
(
§
270.120).
If
the
RAP
application
is
submitted
as
part
of
another
document,
he
must
clearly
identify
the
components
of
that
document
that
constitute
the
RAP
application
(
§
270.125).

40
CFR
270.130(
b)
provides
that,
if
the
Director
tentatively
finds
that
a
RAP
application
does
not
include
all
of
the
information
requested
in
section
270.110
or
that
the
proposed
remediation
waste
management
activities
do
not
meet
the
regulatory
standards,
the
Director
may
request
additional
information
from
the
owner/
operator
or
ask
the
owner/
operator
to
correct
deficiencies
in
his
application.

Under
40
CFR
270.170,
the
Director
must
specify
in
a
RAP,
either
directly
or
by
reference,
procedures
for
future
modifications,
revocations
and
reissuance,
or
termination
of
the
RAP.
These
procedures
must
provide
adequate
opportunities
for
public
review
and
comment
on
any
modification,
revocation
and
reissuance,
or
termination
that
would
significantly
change
the
management
of
the
remediation
waste,
or
that
otherwise
merits
public
review
and
comment.

If
the
RAP
has
been
incorporated
into
a
traditional
RCRA
permit,
as
allowed
under
section
270.85(
c),
then
the
RAP
will
be
modified
according
to
the
applicable
requirements
in
sections
270.40
through
270.42,
revoked
and
reissued
according
to
the
applicable
requirements
in
sections
270.41
and
270.43,
or
terminated
according
to
applicable
requirements
of
section
270.43.
6
Under
40
CFR
270.195,
RAPs
must
be
issued
for
a
fixed
term,
not
to
exceed
ten
years,
although
they
may
be
renewed
upon
approval
by
the
Director
in
fixed
increments
of
no
more
than
ten
years.
Under
section
270.200,
if
an
owner/
operator
wishes
to
renew
his
expiring
RAP,
he
must
follow
the
process
for
application
for
and
issuance
of
RAPs.

40
CFR
270.210
requires
owners/
operators
of
remediation
waste
management
sites
to
keep
records
concerning
their
RAP.
All
records
must
be
kept
for
a
period
of
at
least
three
years
from
the
date
the
RAP
application
is
signed.

Under
40
CFR
270.220(
a),
owners/
operators
of
remediation
waste
management
sites
may
transfer
their
RAPs
to
new
owners/
operators.
To
transfer
the
RAP,
owners/
operators
must
follow
the
requirements
specified
in
their
RAP
for
RAP
modification
to
identify
the
new
owner/
operator,
and
incorporate
any
other
necessary
requirements.
The
new
owner/
operator
must
submit
a
revised
RAP
application
no
later
than
90
days
before
the
scheduled
change
along
with
a
written
agreement
containing
a
specific
date
for
transfer
of
RAP
responsibility
between
the
owner/
operator
and
the
new
permittees.

Under
40
CFR
270.220(
b),
when
a
transfer
of
ownership
occurs,
the
old
owner/
operator
must
comply
with
applicable
requirements
of
40
CFR
part
264,
subpart
H,
until
the
new
owner/
operator
has
demonstrated
compliance
(
i.
e.,
within
six
months
of
the
date
of
the
change).

Under
40
CFR
270.230(
a),
owners/
operators
may
request
a
RAP
for
remediation
waste
management
activities
at
a
location
removed
from
the
area
where
the
remediation
wastes
originated
if
they
believe
such
a
location
would
be
more
protective
than
the
contaminated
area
or
areas
in
close
proximity.
Owners/
operators
must
request
the
RAP,
and
the
Director
will
approve
or
deny
the
RAP,
according
to
the
requirements
in
part
270,
subpart
H
(
§
270.230(
c)).

A
RAP
for
an
alternative
location
must
meet
the
additional
requirements
specified
in
section
270.230(
d),
including
the
RCRA
expanded
public
participation
requirements
in
sections
124.31
through
124.33.
In
addition,
under
section
270.230(
e)(
2),
these
alternative
locations
are
remediation
waste
management
sites,
and
retain
the
benefit
of
complying
with
the
requirements
of
section
264.1(
j)
in
lieu
of
part
264,
subparts
B,
C,
and
D.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
This
section
describes
the
need
and
authority
for
each
type
of
information
collection
analyzed
in
this
ICR.
All
information
collection
requirements
associated
with
the
hazardous
remediation
waste
management
requirements
were
established
under
the
authority
of
sections
3004
and
3005
of
RCRA,
as
amended.
EPA
believes
these
information
collection
requirements
are
necessary
to
balance
streamlined
regulation
of
remediation
wastes
with
the
Agency's
responsibility
to
protect
human
health
and
the
environment.
7
(
1)
General
Requirements
for
Hazardous
Remediation
Waste
Management
Sites
Hazardous
remediation
waste
management
sites
must
comply
with
all
parts
of
40
CFR
part
264
except
subparts
B,
C,
and
D,
and
section
264.101.
In
place
of
the
requirements
in
subparts
B,
C,
and
D,
however,
they
need
to
comply
with
performance
standards
based
on
the
general
requirement
goals
in
these
sections,
which
are
codified
at
40
CFR
264.1(
j).

Section
264.1(
j)(
1)
requires
owners/
operators
of
hazardous
waste
remediation
sites
to
obtain
an
EPA
identification
number
by
applying
to
the
Administrator
using
EPA
Form
8700­
12.
This
information
collection
is
required
by
section
3010
of
RCRA,
and
is
needed
to
ensure
consistent
and
coordinated
identification
of
the
site
by
EPA
under
RCRA
and
other
regulatory
programs.

Section
264.1(
j)(
2)
requires
owners/
operators
of
remediation
waste
management
sites
to
obtain
a
detailed
chemical
and
physical
analysis
of
a
representative
sample
of
the
waste
that
will
be
remediated.
At
a
minimum,
the
waste
analysis
must
contain
all
the
information
which
must
be
known
to
treat,
store,
or
dispose
of
the
waste
in
accordance
with
40
CFR
parts
264
and
268.
The
owner/
operator
needs
the
information
obtained
from
the
waste
analysis
to
determine
whether
there
are
any
potential
dangers
from
handling
the
remediation
waste.
The
waste
analysis
requirement
contributes
to
EPA's
goal
of
preventing
undetected
releases
or
reactions
of
hazardous
waste
on
site.

Section
264.1(
j)(
4)
requires
owners/
operators
to
inspect
the
remediation
waste
management
site
for
malfunctions,
deterioration,
operator
errors,
and
discharges
that
may
be
causing,
or
may
lead
to,
a
release
of
hazardous
waste
constituents
to
the
environment,
or
a
threat
to
human
health.
The
owner/
operator
needs
to
conduct
these
inspections
to
identify
problems
in
time
to
correct
them
before
they
harm
human
health
or
the
environment.
EPA
needs
owners/
operators
to
perform
inspections
in
order
to
prevent
undetected
releases
or
other
problems
at
the
facility.

Section
264.1(
j)(
7)
requires
owners/
operators
not
to
locate
remediation
waste
management
units
within
a
floodplain
unless
the
owner/
operator
can
meet
the
demonstration
of
section
264.18(
b).
In
particular,
the
owner/
operator
must
demonstrate
that
procedures
will
be
in
effect
to
remove
waste
safely
before
flood
waters
reach
the
unit
in
the
event
of
a
flood,
or
no
adverse
effects
on
human
health
or
the
environment
would
result
from
a
washout.
This
information
collection
contributes
to
EPA's
goal
of
preventing
unforseen
releases
of
hazardous
wastes.

Section
264.1(
j)(
9)
requires
owners/
operators
to
develop
and
maintain
a
construction
quality
assurance
program
for
surface
impoundments,
waste
piles,
and
landfills,
as
specified.
EPA
needs
this
information
to
ensure
that
the
units
are
constructed
and
designed
to
prevent
unforseen
releases
of
hazardous
wastes.
8
Section
264.1(
j)(
10)
codifies
streamlined
contingency
and
emergency
plan
regulations
for
hazardous
remediation
waste
sites.
Requiring
remediation
waste
management
sites
to
develop
and
maintain
contingency
and
emergency
plans
contributes
to
EPA's
goal
of
minimizing
unanticipated
damage
from
the
treatment,
storage,
or
disposal
of
hazardous
waste.
Contingency
planning
is
also
mandated
by
RCRA
section
3004(
a)(
5).

Section
264.1(
j)(
12)
requires
owners/
operators
of
remediation
waste
management
sites
to
develop,
maintain,
and
implement
a
plan
to
meet
the
requirements
in
sections
264.1(
j)(
2)
through
(
j)(
6)
and
sections
264.1(
j)(
9)
through
(
j)(
10).
40
CFR
264.1(
j)(
13)
requires
owners/
operators
of
remediation
waste
management
sites
to
maintain
records
documenting
compliance
with
sections
264.1(
j)(
1)
through
(
j)(
12).
Under
40
CFR
264.73(
b)(
17),
owners/
operators
of
remediation
waste
management
sites
are
required
to
record,
as
it
becomes
available,
and
maintain
in
the
operating
record
any
records
required
under
section
264.1(
j)(
13).
EPA
needs
a
record
of
this
information
to
be
sure
that
the
requirements
of
section
264.1(
j)
are
being
met.

(
2)
Requirements
for
Staging
Piles
Staging
piles
are
codified
at
40
CFR
264.554
under
the
authority
of
section
3004
of
RCRA.
Sections
264.554(
c)
and
(
d)
identify
procedures
and
information
requirements
for
designating
staging
piles.
Information
provided
to
EPA
by
owners/
operators
seeking
designation
of
staging
piles
is
needed
to
ensure
that
the
design
and
operation
of
the
staging
pile
will
comply
with
all
applicable
regulations
and
will
be
protective
of
human
health
and
the
environment.

Owners/
operators
may
request
an
extension
of
up
to
six
months
to
the
two­
year
limit
for
staging
pile
operation.
Extensions
are
authorized
under
section
264.554(
i)
and
require
a
request
with
supporting
information
to
be
submitted
to
EPA.
EPA
requires
information
in
extension
requests
to
ensure
that
continued
operation
of
the
staging
pile
is
necessary
and
will
not
pose
a
threat
to
human
health
and
the
environment.
In
addition,
the
information
may
be
necessary
to
develop
further
standards
and
design
criteria
for
the
staging
pile.

Section
264.554(
k)
provides
that,
within
180
days
after
the
operating
term
of
the
staging
pile
expires,
owners/
operators
must
close
a
staging
pile
located
in
an
uncontaminated
area
of
the
site
in
accordance
with
sections
264.258(
a)
and
265.258(
a)
and
sections
264.111
and
265.111
(
i.
e.,
the
closure
requirements
for
waste
piles).

Section
264.554(
l)
specifies
procedures
for
incorporating
staging
piles
into
existing
permits
(
including
RAPs),
closure
plans,
or
orders,
at
the
owner/
operator's
initiative.
These
procedures
are
needed
to
keep
the
permit,
closure
plans,
or
orders
up
to
date.

(
3)
Remedial
Action
Plans
Under
40
CFR
270.80
through
270.90,
EPA
provides
general
information
on
RAPs
(
e.
g.,
a
definition
of
a
RAP,
applicability
criteria).
Under
section
270.95
through
270.125,
EPA
9
describes
how
to
apply
for
a
RAP.
These
procedures
are
needed
to
ensure
owners/
operators
understand
the
requirements
and
procedures
they
must
follow.

Under
section
270.130(
b),
if
the
Director
tentatively
finds
that
the
RAP
application
does
not
include
all
of
the
information
required
under
section
270.110
or
that
the
proposed
remediation
waste
management
activities
do
not
meet
regulatory
standards,
the
Director
may
request
additional
information
from
the
owner/
operator.
EPA
needs
this
information
to
ensure
that
the
proposed
remediation
waste
management
activities
meet
the
regulatory
standards.

The
Agency
believes
that
the
information
collected
in
the
RAP
applications
is
necessary
to
determine
how
and
where
media
and
remediation
waste
will
be
managed.
The
information
is
essential
to
determine
whether
the
management
of
these
materials
will
be
protective
of
human
health
and
the
environment,
and
will
be
in
compliance
with
standards
established
pursuant
to
RCRA.

Under
section
270.170,
the
Director
must
specify
in
a
RAP,
either
directly
or
by
reference,
procedures
for
future
modifications,
revocations
and
reissuance,
or
termination
of
the
RAP.
Owners/
operators
and
EPA
need
these
procedures
to
ensure
that
modifications
can
be
made
in
a
manner
that
protects
human
health
and
the
environment.

Under
section
270.195,
RAPs
must
be
issued
for
a
fixed
term,
not
to
exceed
ten
years,
although
they
may
be
renewed
upon
approval
by
the
Director
in
fixed
increments
of
no
more
than
ten
years
by
following
the
requirements
of
section
270.200.
EPA
needs
this
information
to
determine
whether
the
management
of
these
materials
will
be
protective
of
human
health
and
the
environment,
and
will
be
in
compliance
with
standards
established
pursuant
to
RCRA.

Section
270.210
requires
owners/
operators
of
remediation
waste
management
sites
to
keep
records
concerning
their
RAP.
Recordkeeping
is
required
to
ensure
that
owners/
operators
are
following
the
requirements
for
preparing
and
maintaining
a
RAP.

Under
section
270.220,
owners/
operators
of
remediation
waste
management
sites
may
transfer
their
RAPs
to
new
owners/
operators.
Records
of
such
changes
are
needed
to
ensure
that
owners/
operators
are
aware
of
their
rights
and
obligations
under
part
270,
subpart
H.

Under
section
270.230,
owners/
operators
may
request
a
RAP
for
remediation
waste
management
activities
at
a
location
removed
from
the
area
where
the
remediation
wastes
originated
if
they
believe
such
a
location
would
be
more
protective
than
the
contaminated
area
or
areas
in
close
proximity.
This
information
is
essential
to
determine
whether
the
management
of
hazardous
remediation
waste
will
be
protective
of
human
health
and
the
environment,
and
will
be
in
compliance
with
standards
established
pursuant
to
RCRA.
10
2(
b)
Practical
Utility/
Users
of
the
Data
(
1)
General
Requirements
for
Hazardous
Remediation
Waste
Management
Sites
An
owner/
operator
of
a
hazardous
remediation
waste
management
site
must
request
an
EPA
identification
number
by
completing
and
submitting
EPA
Form
8700­
12,
according
to
section
264.1(
j)(
1).
EPA
uses
Form
8700­
12
to
process
the
request
and
to
ensure
accurate
and
consistent
identification
of
the
site.
Both
EPA
and
the
owner/
operator
use
the
EPA
identification
number
as
a
standard
way
of
identifying
the
site
(
e.
g.,
in
correspondence,
reports).

In
performing
waste
analysis,
pursuant
to
section
264.1(
j)(
2),
the
owner/
operator
of
a
remediation
waste
management
site
obtains
detailed
chemical
and
physical
properties
of
the
remediation
waste.
The
owner/
operator
uses
these
data
to
design
and
implement
effective
and
safe
remedial
actions
and
to
prevent
unanticipated
contaminant
releases.

Section
264.1(
j)(
4)
requires
owners/
operators
to
inspect
the
remediation
waste
management
site
for
malfunctions,
deterioration,
operator
errors,
and
discharges
that
may
be
causing,
or
may
lead
to,
a
release
of
hazardous
waste
constituents
to
the
environment,
or
a
threat
to
human
health.
The
owner/
operator
uses
the
data
collected
in
order
to
identify
problems
in
time
to
correct
them
before
they
harm
human
health
or
the
environment.

Under
section
264.1(
j)(
7),
owners/
operators
planning
to
design,
construct,
operate,
or
maintain
a
hazardous
remediation
waste
management
unit
in
a
100­
year
floodplain
must
demonstrate
that
the
unit
meets
the
criteria
of
section
264.18(
b).
The
Director
uses
the
information
in
the
demonstration
to
evaluate
whether
the
risk
of
contamination
due
to
a
flood
is
greater
if
the
wastes
are
left
unremediated
within
the
floodplain
than
if
the
remediation
wastes
are
managed
in
a
unit
within
the
floodplain.

Section
264.1(
j)(
9)
requires
owners/
operators
to
develop
and
maintain
a
construction
quality
assurance
program
for
surface
impoundments,
waste
piles,
and
landfills,
as
specified.
Owners/
operators
use
this
plan
to
construct
and
maintain
these
units
in
a
manner
that
prevents
unforseen
releases
of
hazardous
wastes.

Section
264.1(
j)(
10)
requires
owners/
operators
of
remediation
waste
management
sites
to
develop
and
maintain
contingency
and
emergency
plans.
The
contingency
and
emergency
plans
are
used
by
the
owner/
operator
to
assure
an
appropriate
response
to
any
unplanned
release
of
hazardous
waste
or
hazardous
waste
constituents
during
the
remedial
action.

Section
264.1(
j)(
12)
requires
owners/
operators
of
remediation
waste
management
sites
to
develop,
maintain,
and
implement
a
plan
to
meet
the
requirements
in
sections
264.1(
j)(
2)
through
(
j)(
6)
and
sections
264.1(
j)(
9)
through
(
j)(
10).
40
CFR
264.1(
j)(
13)
requires
owners/
operators
of
remediation
waste
management
sites
to
maintain
records
documenting
compliance
with
sections
264.1(
j)(
1)
through
(
j)(
12).
Under
40
CFR
264.73(
b)(
17),
owners/
operators
of
remediation
11
waste
management
sites
are
required
to
record,
as
it
becomes
available,
and
maintain
in
the
operating
record
any
records
required
under
section
264.1(
j)(
13).
Owners/
operators
use
these
records
to
keep
track
of
maintenance
and
repairs,
inspections,
design
criteria,
and
compliance
with
other
aspects
of
hazardous
waste
remediation.

(
2)
Requirements
for
Staging
Piles
Data
submitted
by
owners/
operators
seeking
designation
of
staging
piles
is
used
by
EPA
to
evaluate
and
approve
proposed
remedial
actions
involving
staging
piles.
Specifically,
EPA
uses
the
data
to
develop
standards
and
design
criteria
for
staging
piles
that
are
included
in
an
approved
permit,
order,
or
closure
plan.
Similarly,
when
owners/
operators
request
extensions
to
the
two­
year
limit
for
operating
a
staging
pile,
EPA
uses
submitted
data
to
evaluate
the
need
for
and
protectiveness
of
the
extension,
and
to
issue
further
standards
and
design
criteria
if
needed.

Owners/
operators
using
a
staging
pile
in
uncontaminated
areas
must
close
the
staging
piles
in
accordance
with
applicable
requirements
of
sections
264.258(
a)
and
264.111
or
265.258(
a)
and
265.111.
Information
submitted
by
owners/
operators
pursuant
to
these
closure
and
post­
closure
care
requirements
is
used
by
EPA
to
approve
closure
plans
and
ensure
that
the
site
does
not
pose
a
continuing
threat
to
human
health
and
the
environment.

Section
264.554(
l)
specifies
procedures
for
incorporating
staging
piles
into
existing
RCRA
permits,
closure
plans,
or
orders.
In
processing
the
information
collected,
EPA
ensures
that
the
proposed
modifications
will
comply
with
all
applicable
provisions
of
RCRA.

(
3)
Remedial
Action
Plans
Information
submitted
in
RAP
applications
and
renewals,
including
requested
additional
information,
is
used
by
the
Director
to
verify
that
proposed
remedial
activities
will
be
conducted
in
accordance
with
applicable
regulations
and
in
a
manner
which
protects
human
health
and
the
environment.
In
addition,
the
Director
may
use
the
information
in
aggregate
(
e.
g.,
number
of
RAPs
approved)
to
track
and
evaluate
RCRA
implementation
and
to
assist
with
further
program
development.

Section
270.210
requires
owners/
operators
to
maintain
a
file
of
RAP­
related
documents.
The
owners/
operators
use
information
included
in
the
operating
record
to
minimize
unanticipated
damage
from
the
treatment,
storage,
or
disposal
of
hazardous
remediation
waste.
If
an
unanticipated
release
occurs,
the
owner/
operator
may
review
the
information
in
the
file
to
determine
the
composition
of
the
waste
and
appropriate
contingency
measures.

In
the
event
that
a
remediation
waste
management
site
changes
ownership,
a
RAP
may
be
transferred
to
the
new
owner/
operator
under
the
procedures
in
section
270.220.
Specifically,
the
current
owner/
operator
is
required
to
submit
to
the
Director
a
modified
RAP
and
a
written
agreement
between
the
current
and
new
owner/
operator.
The
Director
uses
this
information
to
12
maintain
accurate
records
on
the
ownership
of
the
sites
and
to
ensure
that
new
owners/
operators
are
aware
of
their
rights
and
obligations
under
part
270,
subpart
H.

Under
section
270.230,
owners/
operators
may
request
a
RAP
for
remediation
waste
management
activities
at
a
location
removed
from
the
area
where
the
remediation
wastes
originated
if
they
believe
such
a
location
would
be
more
protective
than
the
contaminated
area
or
areas
in
close
proximity.
The
Director
uses
the
information
to
verify
that
proposed
remedial
activities
will
be
conducted
in
accordance
with
applicable
regulations
in
a
manner
that
protects
human
health
and
the
environment.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
No
document
identical
or
similar
in
purpose
to
the
RAP
is
required
by
the
Federal
government.
Since
management
of
hazardous
contaminated
media
will
take
place
under
many
Federal
and
State
remedial
programs,
the
Agency
has
established
RAP
requirements
that
are
flexible
enough
so
that
any
enforceable
document
used
by
one
of
these
programs,
which
contains
the
relevant
information
and
goes
through
at
least
the
minimum
public
participation
requirements
in
section
270.145,
can
be
considered
equivalent
to
the
RAP.
A
respondent
would
not
be
required
to
duplicate
effort
or
documentation
to
meet
the
requirements
of
the
RAP.

Most
of
the
information
required
by
the
regulations
is
not
available
from
any
source
but
the
respondents.
To
avoid
duplicating
previous
work,
EPA
allows
respondents
to
draw
upon
similar
analyses
in
compiling
data
(
e.
g.,
for
waste
analyses),
provided
the
information
meets
the
requirements
specified
in
the
regulations.

3(
b)
Public
Notice
In
compliance
with
the
Paperwork
Reduction
Act
of
1995,
EPA
issued
a
public
notice
in
the
Federal
Register
on
April
14,
2005
(
70
FR
19757).
No
comments
were
received.

3(
c)
Consultations
In
developing
this
ICR
for
the
HWIR­
Media
final
rule,
EPA
conducted
consultations
with
industry
regarding
the
hazardous
remediation
waste
management
requirements
covered
in
this
ICR.
Their
feedback
enabled
the
Agency
to
develop
hour
and
cost
assumptions
that
are
representative
of
their
"
real­
world"
experience.
These
respondents
were
identified
in
that
previous
ICR.
As
with
the
previous
renewal
(
ICR
Number
1775.03),
EPA
has
updated
the
costs
to
reflect
inflation,
but
has
no
reason
to
believe
that
the
number
of
burden
hours
has
changed.

In
developing
this
current
ICR,
EPA
consulted
with
four
State
agencies
to
ascertain
the
13
number
of
respondents
subject
to
the
RAP
requirements
under
40
CFR
part
270.
Contact
information
for
these
four
States
is
provided
below:

State
Agency
Contact
Name
Phone
Number
Connecticut
Department
of
Environmental
Protection
Ms.
Diane
Duva
(
860)
424­
3271
Illinois
Environmental
Protection
Agency
Mr.
Jim
Moore
(
217)
524­
3300
Missouri
Department
of
Natural
Resources
Mr.
Rob
Morrison
(
573)
751­
3553
Oklahoma
Department
of
Environmental
Quality
Ms.
Catherine
Sharp
(
405)
702­
5100
3(
d)
Effects
of
Less
Frequent
Collection
EPA
has
carefully
considered
the
burden
imposed
upon
the
regulated
community
by
the
general
requirements
for
remediation
waste
management
sites.
EPA
is
confident
that
those
activities
required
of
respondents
are
necessary,
and
to
the
extent
possible,
has
attempted
to
minimize
the
burden
imposed.
EPA
believes
strongly
that
if
the
minimum
requirements
specified
under
the
regulations
are
not
met,
neither
the
facilities
nor
EPA
can
ensure
that
hazardous
remediation
wastes
will
be
managed
properly,
and
will
not
pose
a
serious
threat
to
human
health
and
the
environment.

Since
the
RAP
is
a
one­
time
document
for
a
particular
remediation
waste
management
site,
less
frequent
preparation
is
not
possible.
At
some
sites,
periodic
review
or
renewal
of
the
RAP
may
be
needed
to
assure
that
the
remedy
continues
to
comply
with
currently
applicable
RCRA
requirements.
RAPs
are
for
fixed
terms,
not
to
exceed
ten
years.
When
remedies
continue
beyond
the
term
of
the
RAP,
the
Director
may
renew
the
RAP
unchanged
or
with
changes
as
needed.
In
addition,
the
Director
must
review
RAPs
for
hazardous
waste
land
disposal
facilities
every
five
years.
Although
the
RAP
renewals
and
five­
year
reviews
do
not
require
owners/
operators
to
submit
progress
reports
or
new
applications,
communication
will
be
necessary
to
appraise
the
Director
of
the
status
of
the
cleanup.

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

3(
f)
Confidentiality
Section
3007(
b)
of
RCRA
and
40
CFR
part
2,
subpart
B,
which
define
EPA's
general
policy
on
public
disclosure
of
information,
contain
provisions
for
confidentiality.
In
addition,
under
section
270.115,
EPA
has
established
procedures
that
owners/
operators
submitting
RAPs
may
use
to
claim
as
confidential
any
or
all
of
the
information
submitted
as
part
of
the
application.
14
If
such
a
claim
were
asserted,
EPA
must
and
will
treat
the
information
in
accordance
with
the
regulations
above.
Finally,
EPA
has
ensured
that
this
information
collection
complies
with
the
Privacy
Act
of
1974
and
OMB
Circular
108.

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

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondent
SIC/
NAICS
Codes
The
following
is
a
list
of
Standard
Industrial
Classification
(
SIC)
codes
and
corresponding
North
American
Industrial
Classification
System
(
NAICS)
codes
associated
with
facilities
most
likely
affected
by
the
information
requirements
covered
in
this
ICR.

Industry
Sector
SIC
Code(
s)
NAICS
Code(
s)
Wood
Preservation
2491
321114
Alkalies
and
Chlorine
Manufacturing
2812
325181
All
Other
Miscellaneous
Chemical
Product
and
Preparation
Manufacturing
2819,
2899
325998
Plastics
Material
and
Resin
Manufacturing
2821
325211
All
Other
Basic
Organic
Chemical
Manufacturing
2869
325199
Pesticide
and
Other
Agricultural
Chemical
Manufacturing
2879
32532
Petroleum
Refineries
2911
32411
Plastics
and
Rubber
Products
Manufacturing
3000
326
All
Other
Plastic
Products
Manufacturing
3089
326199
Other
Pressed
and
Blown
Glass
and
Glassware
Manufacturing
3229
327212
Rolled
Steel
Shape
Manufacturing
3316
331221
Nonferrous
Metal
(
except
Aluminum)
Production
and
Processing
3339
3314
Secondary
Smelting
and
Alloying
of
Aluminum
3341
331314
Fabricated
Metal
Product
Manufacturing
3470
332
Small
Arms
Ammunition
Manufacturing
3482
332992
Other
Ordnance
and
Accessories
Manufacturing
3489
332995
Mechanical
Power
Transmission
Equipment
Manufacturing
3568
333613
Communications
Equipment
Manufacturing
3662
3342
Semiconductors
and
Related
Device
Manufacturing
3674
334413
Storage
Battery
Manufacturing
3691
335911
Aerospace
Product
and
Parts
Manufacturing
3728
3364
Guided
Missile
and
Space
Vehicle
Propulsion
Unit
and
Propulsion
Unit
Parts
Manufacturing
3764
336415
15
Industry
Sector
SIC
Code(
s)
NAICS
Code(
s)
Travel
Trailer
and
Camper
Manufacturing
3792
336214
Navigational,
Measuring,
Electromedical,
and
Control
Instruments
Manufacturing
3820
3345
Surgical
and
Medical
Instrument
Manufacturing
3840
339112
Other
Support
Activities
for
Road
Transportation
4231
48849
Support
Activities
for
Air
Transportation
4581
4881
Waste
Treatment
and
Disposal
4953
5622
Dry
Cleaning
and
Laundry
Services
7210
8123
Colleges,
Universities,
and
Professional
Schools
8221
61131
National
Security
9711
92811
4(
b)
Information
Requested
(
1)
General
Requirements
for
Hazardous
Remediation
Waste
Management
Sites
(
a)
EPA
Identification
Number
40
CFR
264.1(
j)(
1)
requires
owners/
operators
of
remediation
waste
management
sites
to
have
EPA
identification
numbers.
An
EPA
identification
number
can
be
obtained
by
applying
to
the
Administrator
using
EPA
Form
8700­
12.

(
i)
Data
Item:

The
data
item
required
of
owners/
operators
includes:

°
A
completed
EPA
Form
8700­
12.

(
ii)
Respondent
Activities:

In
order
to
comply
with
the
above
requirements,
owners/
operators
must
conduct
the
following
activities:

°
Complete
and
submit
EPA
Form
8700­
12.

[
Note:
This
ICR
does
not
address
the
requirement
in
40
CFR
264.1(
j)(
1)
for
obtaining
an
EPA
identification
number.
Refer
to
"
Notification
of
Regulated
Waste
Activity,"
ICR
Number
261,
for
this
requirement.]

(
b)
Waste
Analyses
40
CFR
264.1(
j)(
2)
requires
owners/
operators
of
remediation
waste
management
sites
to
obtain
a
detailed
chemical
and
physical
analysis
of
a
representative
sample
of
the
hazardous
remediation
wastes
to
be
managed
at
the
site.
At
a
minimum,
the
waste
analysis
must
contain
all
16
the
information
that
must
be
known
to
treat,
store
or
disposed
of
the
waste
in
accordance
with
40
CFR
parts
264
and
268,
and
must
be
kept
accurate
and
up
to
date.

(
i)
Data
Item:

The
data
item
required
of
owners/
operators
includes:

°
A
detailed
chemical
and
physical
analysis
of
a
representative
sample
of
the
hazardous
remediation
wastes
to
be
managed
at
the
site.

(
ii)
Respondent
Activity:

In
order
to
comply
with
the
above
requirements,
owners/
operators
must
conduct
the
following
activity:

°
Perform
waste
analysis.

(
c)
Inspections
40
CFR
264.1(
j)(
4)
requires
owners/
operators
to
inspect
the
remediation
waste
management
site
for
malfunctions,
deterioration,
operator
errors,
and
discharges
that
may
be
causing,
or
may
lead
to,
a
release
of
hazardous
waste
constituents
to
the
environment,
or
a
threat
to
human
health.
The
owner/
operator
must
conduct
these
inspections
often
enough
to
identify
problems
in
time
to
correct
them
before
they
harm
human
health
or
the
environment,
and
must
remedy
the
problem
before
it
leads
to
a
human
health
or
environmental
hazard.
Where
a
hazard
is
imminent
or
has
already
occurred,
the
owner/
operator
must
take
remedial
action
immediately.

(
i)
Data
Item:

The
data
item
required
of
owners/
operators
includes:

°
An
inspection
record.

(
ii)
Respondent
Activity:

In
order
to
comply
with
the
above
requirements,
owners/
operators
must
conduct
the
following
activity:

°
Conduct
inspections.

(
d)
Demonstrations
for
Remediation
Waste
Management
Sites
in
Floodplains
Under
40
CFR
264.1(
j)(
7),
owners/
operators
of
remediation
waste
management
sites
17
subject
to
regulation
under
part
264,
subparts
I
through
O
and
subpart
X
must
design,
construct,
operate,
and
maintain
units
within
a
100­
year
floodplain
to
prevent
washout
of
any
hazardous
waste
by
a
100­
year
flood,
unless
they
can
meet
the
demonstration
requirements
of
section
264.18(
b).

(
i)
Data
Item:

The
data
item
required
of
owners/
operators
includes:

°
A
demonstration
that
establishes
that
procedures
are
in
effect
which
will
cause
the
waste
to
be
removed
safely,
before
flood
waters
can
reach
the
facility,
to
a
location
where
the
wastes
will
not
be
vulnerable
to
flood
waters.

(
ii)
Respondent
Activity:

In
order
to
comply
with
the
above
requirements,
owners/
operators
must
conduct
the
following
activity:

°
Prepare
and
submit
demonstration
for
exemption
from
design
and
operating
standards
under
§
264.18(
b).

(
e)
Construction
Quality
Assurance
Program
40
CFR
264.1(
j)(
9)
requires
owners/
operators
to
develop
and
maintain
a
construction
quality
assurance
program
for
all
surface
impoundments,
waste
piles,
and
landfill
units
that
are
required
to
comply
with
sections
264.221(
c)
and
(
d),
264.251(
c)
and
(
d),
and
264.301(
c)
and
(
d)
at
the
remediation
waste
management
site,
according
to
the
requirements
of
section
264.19.

(
i)
Data
Item:

The
data
item
required
of
owners/
operators
includes:

°
A
construction
quality
assurance
program.

(
ii)
Respondent
Activities:

In
order
to
comply
with
the
above
requirements,
owners/
operators
must
conduct
the
following
activities:

°
Develop
and
maintain
a
construction
quality
assurance
program.

(
f)
Contingency
and
Emergency
Plan
18
40
CFR
264.1(
j)(
10)
requires
owners/
operators
of
remediation
waste
management
sites
to
develop
and
maintain
procedures
to
prevent
accidents.
These
procedures
must
address
proper
design,
construction,
maintenance,
and
operation
of
hazardous
remediation
waste
management
units
at
the
site.

In
addition,
owners/
operators
must
develop
and
maintain
a
contingency
and
emergency
plan
to
control
accidents
that
occur.
The
plan
must
explain
specifically
how
to
treat,
store,
and
dispose
of
the
hazardous
remediation
waste
in
question,
and
must
be
implemented
immediately
whenever
fire,
explosion,
or
release
of
hazardous
waste
or
hazardous
waste
constituents
that
could
threaten
human
health
or
the
environment.

(
i)
Data
Items:

The
data
items
required
of
owners/
operators
include:

°
Procedures
to
prevent
accidents;
and
°
A
contingency
and
emergency
plan.

(
ii)
Respondent
Activities:

In
order
to
comply
with
the
above
requirements,
owners/
operators
must
conduct
the
following
activities:

°
Develop
and
maintain
procedures
to
prevent
accidents;
and
°
Develop
and
maintain
contingency
and
emergency
plan.

(
g)
Compliance
Plan
40
CFR
264.1(
j)(
12)
requires
owners/
operators
of
remediation
waste
management
sites
to
develop,
maintain,
and
implement
a
plan
to
meet
the
requirements
in
sections
264.1(
j)(
2)
through
(
j)(
6)
and
sections
264.1(
j)(
9)
through
(
j)(
10).

(
i)
Data
Item:

The
data
item
required
of
owners/
operators
includes:

°
A
compliance
plan.

(
ii)
Respondent
Activities:

In
order
to
comply
with
the
above
requirements,
owners/
operators
must
conduct
the
19
following
activities:

°
Develop,
maintain,
and
implement
a
plan
to
meet
the
requirements
in
§
§
264.1(
j)(
2)
through
(
j)(
6)
and
§
§
264.1(
j)(
9)
through
(
j)(
10).

(
h)
Recordkeeping
Requirements
40
CFR
264.1(
j)(
13)
requires
owners/
operators
of
remediation
waste
management
sites
to
maintain
records
documenting
compliance
with
sections
264.1(
j)(
1)
through
(
j)(
12).
These
records
must
be
maintained
in
the
operating
record
as
required
under
section
264.73(
b)(
17).

(
i)
Data
Items:

The
data
items
required
of
owners/
operators
include:

°
Records
documenting
compliance
with
§
§
264.1(
j)(
1)
through
(
j)(
12).

(
ii)
Respondent
Activity:

In
order
to
comply
with
the
above
requirements,
owners/
operators
must
conduct
the
following
activity:

°
Keep
records
documenting
compliance
with
§
§
264.1(
j)(
1)
through
(
j)(
12).

(
2)
Requirements
for
Staging
Piles
(
a)
Designation
of
Staging
Piles
Under
40
CFR
264.554(
c)(
1),
owners/
operators
seeking
staging
pile
designations
must
provide
sufficient
and
accurate
information
to
enable
the
Director
to
impose
standards
and
design
criteria
for
the
staging
pile.
In
addition,
under
section
264.554(
c)(
2),
the
owner/
operator
must
provide
a
certification
by
an
independent,
qualified,
registered
professional
engineer
for
technical
data
(
e.
g.,
design
drawings
and
specifications,
engineering
studies),
unless
the
Director
determines,
based
on
information
provided
by
the
owner/
operator,
that
the
certification
is
not
necessary
to
ensure
that
the
staging
pile
will
protect
human
health
and
the
environment.
Finally,
under
section
264.554(
c)(
3),
the
owner/
operator
must
provide
any
additional
information
the
Director
determines
is
necessary
to
protect
human
health
and
the
environment.

(
i)
Data
Items:

The
data
items
required
of
owners/
operators
include:

°
Information
that
will
enable
the
Director
to
impose
standards
and
design
criteria
20
for
the
staging
pile;

°
Certification
by
an
independent,
qualified,
registered
professional
engineer
for
technical
data;
and
°
Any
additional
information
requested
by
the
Director.

(
ii)
Respondent
Activities:

In
order
to
comply
with
the
above
requirements,
owners/
operators
must
conduct
the
following
activities:

°
Prepare
information
that
will
enable
the
Director
to
impose
standards
and
design
criteria
for
the
staging
pile;

°
Obtain
certification
by
an
independent,
qualified,
registered
professional
engineer
for
technical
data,
unless
the
Director
determines
that
the
certification
is
not
necessary;

°
Submit
information
to
the
Director;
and
°
Prepare
and
submit
additional
information
requested
by
the
Director,
if
requested.

(
b)
Staging
Pile
Recordkeeping
As
provided
under
40
CFR
264.554(
d)(
1)(
iii),
a
staging
pile
must
not
operate
for
more
than
two
years,
except
when
the
Director
grants
an
operating
term
extension
under
section
264.554(
i).
The
owner/
operator
must
measure
the
two­
year
limit,
or
other
operating
term
specified
by
the
Director
in
the
permit,
closure
plan,
or
order,
from
the
first
time
remediation
waste
is
placed
into
the
staging
pile.
The
owner/
operator
must
maintain
a
record
of
the
date
when
remediation
waste
was
first
placed
into
the
staging
pile
for
the
life
of
the
permit,
order,
or
approved
closure
plan,
or
for
three
years,
whichever
is
longer.

(
i)
Data
Item:

The
data
item
required
of
owners/
operators
includes:

°
A
record
of
the
date
when
the
remediation
waste
was
first
placed
into
the
staging
pile.

(
ii)
Respondent
Activities:

In
order
to
comply
with
the
above
requirements,
owners/
operators
must
conduct
the
21
following
activities:

°
Record
the
date
of
waste
placement
in
the
unit;
and
°
File
the
record.

(
c)
Staging
Pile
Extensions
Under
40
CFR
264.554(
i)(
1),
the
Director
may
grant
one
operating
term
extension
for
a
staging
pile
of
up
to
180
days
beyond
the
operating
term
limit
contained
in
the
permit,
closure
plan,
or
order.
To
obtain
an
extension,
owners/
operators
must
document
that
an
extension
will
not
pose
a
threat
to
human
health
and
the
environment
and
is
necessary
to
ensure
timely
and
efficient
implementation
of
remedial
actions
at
the
facility.

(
i)
Data
Item:

The
data
item
required
of
owners/
operators
includes:

°
Information
documenting
that
an
extension:
(
1)
will
not
pose
a
threat
to
human
health
and
the
environment
and
(
2)
is
necessary
to
ensure
timely
and
efficient
implementation
of
remedial
actions
at
the
facility.

(
ii)
Respondent
Activities:

In
order
to
comply
with
the
above
requirements,
owners/
operators
must
conduct
the
following
activities:

°
Prepare
documentation
supporting
an
extension;
and
°
Submit
request
for
extension.

(
d)
Closure
of
Staging
Piles
40
CFR
264.554(
k)
provides
that,
within
180
days
after
the
operating
term
of
the
staging
pile
expires,
owners/
operators
must
close
a
staging
pile
located
in
an
uncontaminated
area
of
the
site
in
accordance
with
sections
264.258(
a)
and
265.258(
a)
and
sections
264.111
and
265.111
(
i.
e.,
the
closure
requirements
for
waste
piles).
[
Note:
This
ICR
does
not
address
the
requirements
in
40
CFR
264.258(
a),
265.258(
a),
264.111,
and
265.111
for
closing
a
staging
pile.
Refer
to
"
General
Hazardous
Waste
Facility
Standards,"
ICR
Number
1571,
for
these
requirements.

(
e)
Incorporation
of
Staging
Piles
into
Existing
Permits
22
40
CFR
264.554(
l)
specifies
procedures
for
incorporating
staging
piles
into
existing
permits
(
including
RAPs),
closure
plans,
or
orders.
Pursuant
to
section
264.554(
l)(
1),
a
permit,
other
than
a
RAP,
may
be
modified
to
incorporate
a
staging
pile
or
staging
pile
operating
term
extension
as
part
of
an
Agency­
initiated
permit
modification
under
section
270.41or
as
part
of
an
owner/
operator
initiated
Class
2
permit
modification
under
section
270.42.
[
Note:
This
ICR
does
not
address
the
requirements
in
40
CFR
270.41
and
270.42
for
modifying
an
existing
RCRA
permit.
Refer
to
"
Part
B
Permit
Application,
Permit
Modifications,
and
Special
Permits,"
ICR
Number
1573,
for
these
requirements.]

Pursuant
to
section
264.554(
l)(
2),
an
owner/
operator
may
modify
an
existing
RAP
to
incorporate
a
staging
pile
or
staging
pile
operating
term
extension
by
complying
with
the
RAP
modification
requirements
under
sections
270.170
and
270.175.
[
Note:
Refer
to
subsection
"
RAP
Modification,
Revocation
and
Reissuance,
and
Termination"
of
this
ICR
for
requirements
applicable
to
owners/
operators
of
remediation
waste
management
sites
modifying
their
RAP.]

Pursuant
to
section
265.554(
l)(
3),
an
owner/
operator
may
modify
an
existing
closure
plan
to
incorporate
a
staging
pile
or
staging
pile
operating
term
extension
by
following
the
applicable
requirements
under
section
264.112(
c)
or
265.112(
c).
[
Note:
This
ICR
does
not
address
the
requirements
in
40
CFR
264.112(
c)
or
265.112(
c)
for
modifying
an
existing
closure
plan.
Refer
to
"
Part
B
Permit
Application,
Permit
Modifications,
and
Special
Permits,"
ICR
Number
1573,
for
the
requirements
under
section
264.112(
c).
Refer
to
"
General
Hazardous
Waste
Facility
Standards,"
ICR
Number
1571,
for
the
requirements
under
section
265.112(
c).]

Pursuant
to
section
264.554(
l)(
4),
an
owner/
operator
may
modify
an
existing
order
to
incorporate
a
staging
pile
or
staging
pile
operating
term
extension
by
following
the
terms
of
the
order
and
the
applicable
provisions
of
section
270.72(
a)(
5)
or
270.72(
b)(
5).
[
Note:
Facilities
incorporating
staging
piles
into
their
orders
would
not
follow
the
requirements
in
this
ICR.
Rather,
they
would
follow
the
procedures
spelled
out
in
their
site­
specific
order.
As
such,
these
facilities
are
not
addressed
in
this
ICR.]

(
3)
Remedial
Action
Plans
(
a)
RAP
Application
40
CFR
270.80(
a)
defines
a
RAP
as
a
special
form
of
RCRA
permit
that
an
owner/
operator
of
a
remediation
waste
management
site
may
obtain,
instead
of
a
permit
issued
under
sections
270.3
through
270.66,
to
treat,
store,
or
dispose
of
hazardous
remediation
waste
at
a
remediation
waste
management
site.

Under
40
CFR
270.85(
a),
whenever
an
owner/
operator
treats,
stores,
or
disposes
of
hazardous
remediation
waste
in
a
manner
that
requires
a
RCRA
permit
under
section
270.1,
the
owner/
operator
must
either
obtain
a
RCRA
permit
or
a
RAP.
23
Under
40
CFR
270.85(
c),
an
owner/
operator
may
obtain
a
RAP
for
managing
hazardous
remediation
waste
at
an
already
permitted
RCRA
facility.
This
RAP
must
be
approved
as
a
modification
to
the
existing
permit
according
to
the
requirements
of
section
270.41
or
section
270.42.
However,
when
the
owner/
operator
submits
an
application
for
such
modification,
the
information
requirements
in
section
270.42(
a)(
1)(
i),
(
b)(
1)(
iv),
and
(
c)(
1)(
iv)
do
not
apply;
instead,
the
owner/
operator
must
submit
the
information
required
under
section
270.110.
When
the
permit
is
modified,
the
RAP
becomes
part
of
the
RCRA
permit.
[
Note:
This
ICR
does
not
address
the
requirements
in
40
CFR
270.41
and
270.42
for
modifying
an
existing
RCRA
permit.
Refer
to
"
Part
B
Permit
Application,
Permit
Modifications,
and
Special
Permits,"
ICR
Number
1573,
for
these
requirements.]

Under
40
CFR
270.95,
an
owner/
operator
may
apply
for
a
RAP
by
completing
an
application,
signing
it,
and
submitting
it
to
the
Director.

40
CFR
270.100
provides
that,
when
a
facility
or
remediation
waste
management
site
is
owned
by
one
person,
but
the
treatment,
storage,
or
disposal
activities
are
operated
by
another
person,
it
is
the
operator's
duty
to
obtain
a
RAP.
Under
section
270.105,
both
the
owner
and
the
operator
must
sign
the
RAP
application
and
any
required
reports
according
to
sections
270.11(
a)
through
(
c).
In
addition,
both
the
owner
and
the
operator
must
also
make
the
certification
required
under
section
270.11(
d)(
1).
However,
the
owner
may
choose
the
alternative
certification
under
section
270.11(
d)(
2)
if
the
operator
certifies
under
section
270.11(
d)(
1).

The
RAP
application
must
include
all
the
information
specified
in
section
270.110.
Under
section
270.115,
an
owner/
operator
may
claim
as
confidential
any
or
all
of
the
information
he
submits
to
EPA.
Any
such
claim
must
be
asserted
at
the
time
he
submits
his
RAP
application
or
other
submissions
by
stamping
the
words
"
confidential
business
information"
on
each
page
containing
such
information.

The
owner/
operator
must
submit
the
RAP
application
to
the
Director
for
approval
(
§
270.120).
If
the
RAP
application
is
submitted
as
part
of
another
document,
he
must
clearly
identify
the
components
of
that
document
that
constitute
the
RAP
application
(
§
270.125).

40
CFR
270.130(
b)
provides
that,
if
the
Director
tentatively
finds
that
a
RAP
application
does
not
include
all
of
the
information
requested
in
section
270.110
or
that
the
proposed
remediation
waste
management
activities
do
not
meet
the
regulatory
standards,
the
Director
may
request
additional
information
from
the
owner/
operator
or
ask
the
owner/
operator
to
correct
deficiencies
in
his
application.

(
i)
Data
Item:

The
data
item
required
of
owners/
operators
includes
a
RAP
application
with
the
following
information:
24
°
Owner
and
operator
signatures
in
accordance
with
§
270.11(
a)
through
(
c);

°
Owner
and
operator
certifications
required
under
§
270.11(
d);

°
Information
specified
in
§
270.110:

­­
The
name,
address,
and
EPA
identification
number
of
the
remediation
waste
management
site;
­­
The
name,
address,
and
telephone
number
of
the
owner
and
operator;
­­
The
latitude
and
longitude
of
the
site;
­­
The
U.
S.
Geological
Survey
or
county
map
showing
the
location
of
the
remediation
waste
management
site;
­­
A
scaled
drawing
of
the
remediation
waste
management
site
showing:


The
remediation
waste
management
site
boundaries;


Any
significant
physical
structures;


The
boundary
of
all
areas
on
site
where
remediation
waste
is
to
be
treated,
stored,
or
disposed;
­­
A
specification
of
the
hazardous
remediation
waste
to
be
treated,
stored,
or
disposed
of
at
the
facility
or
remediation
waste
management
site,
including
the
following
information:


Constituent
concentrations
and
other
properties
of
the
hazardous
remediation
wastes
that
may
affect
how
such
materials
should
be
treated
and/
or
otherwise
managed;


An
estimate
of
the
quantity
of
these
wastes;


A
description
of
the
processes
that
will
be
used
to
treat,
store,
or
dispose
of
the
waste
including
technologies,
handling
systems,
design,
and
operating
parameters
that
will
be
used
to
treat
hazardous
remediation
wastes
before
disposing
of
them
according
to
the
land
disposal
restrictions
standards
of
part
268,
as
applicable;
­­
Enough
information
to
demonstrate
that
operations
that
follow
the
provision
in
the
RAP
application
will
ensure
compliance
with
applicable
requirements
of
parts
264,
266,
and
268;
­­
Such
information
as
may
be
necessary
to
enable
the
Regional
Administrator
to
carry
out
his
duties
under
other
Federal
laws
as
required
for
traditional
RCRA
permits
under
§
270.14(
b)(
20);
­­
Any
other
information
the
Director
decides
is
necessary
for
demonstrating
compliance
with
40
CFR
part
270,
subpart
H
or
for
determining
any
additional
RAP
conditions
that
are
necessary
to
protect
human
health
and
the
environment;
and
°
If
claiming
as
confidential
any
or
all
of
the
information
on
the
RAP
application
or
other
submissions,
a
stamp
with
the
words
"
confidential
business
information"
on
each
page
containing
such
information.
25
(
ii)
Respondent
Activities:

In
order
to
comply
with
the
above
requirements,
owners/
operators
must
conduct
the
following
activities:

°
Prepare
RAP
application;

°
Submit
RAP
application;
and
°
Prepare
and
submit
additional
information,
if
requested.

(
b)
RAP
Modification,
Revocation
and
Reissuance,
and
Termination
Under
40
CFR
270.170,
the
Director
must
specify
in
a
RAP,
either
directly
or
by
reference,
procedures
for
future
modifications,
revocations
and
reissuance,
or
termination
of
the
RAP.
These
procedures
must
provide
adequate
opportunities
for
public
review
and
comment
on
any
modification,
revocation
and
reissuance,
or
termination
that
would
significantly
change
the
management
of
the
remediation
waste,
or
that
otherwise
merits
public
review
and
comment.

If
the
RAP
has
been
incorporated
into
a
traditional
RCRA
permit,
as
allowed
under
section
270.85(
c),
then
the
RAP
will
be
modified
according
to
the
applicable
requirements
in
sections
270.40
through
270.42,
revoked
and
reissued
according
to
the
applicable
requirements
in
sections
270.41
and
270.43,
or
terminated
according
to
applicable
requirements
of
section
270.43.
[
Note:
This
ICR
does
not
address
the
requirements
in
40
CFR
270.41
through
270.43
for
modifying,
revoking
and
reissuing,
and
terminating
a
RCRA
permit.
Refer
to
"
Part
B
Permit
Application,
Permit
Modifications,
and
Special
Permits,"
ICR
Number
1573,
for
these
requirements.]

(
i)
Data
Item:

The
data
item
required
of
owners/
operators
includes:

°
Information
necessary
to
modify
RAP,
as
specified
in
the
RAP.

(
ii)
Respondent
Activities:

In
order
to
comply
with
the
above
requirements,
owners/
operators
must
conduct
the
following
activities:

°
Prepare
and
submit
information
to
modify
RAP
in
accordance
with
procedures
specified
in
the
RAP.
26
2
These
modifications
do
not
constitute
"
significant"
modifications
for
purposes
of
section
270.170.
(
c)
RAP
Renewal
Under
40
CFR
270.195,
RAPs
must
be
issued
for
a
fixed
term,
not
to
exceed
ten
years,
although
they
may
be
renewed
upon
approval
by
the
Director
in
fixed
increments
of
no
more
than
ten
years.
Under
section
270.200,
if
an
owner/
operator
wishes
to
renew
his
expiring
RAP,
he
must
follow
the
process
for
application
for
and
issuance
of
RAPs.
[
Note:
Refer
to
subsection
"
RAP
Application"
of
this
ICR
for
requirements
applicable
to
owners/
operators
of
remediation
waste
management
sites
renewing
their
RAP.]

(
d)
RAP
Recordkeeping
40
CFR
270.210
requires
owners/
operators
of
remediation
waste
management
sites
to
keep
records
concerning
their
RAP.
All
records
must
be
kept
for
a
period
of
at
least
three
years
from
the
date
the
RAP
application
is
signed.

(
i)
Data
Items:

The
data
items
required
of
owners/
operators
include:

°
All
data
used
to
complete
RAP
applications
and
any
supplemental
information
submitted;
and
°
Any
operating
and/
or
other
records
required
as
a
condition
of
the
RAP.

(
ii)
Respondent
Activity:

In
order
to
comply
with
the
above
requirements,
owners/
operators
must
conduct
the
following
activity:

°
Maintain
a
file
of
RAP
documents.

(
e)
RAP
Transfers
Under
40
CFR
270.220(
a),
owners/
operators
of
remediation
waste
management
sites
may
transfer
their
RAPs
to
new
owners/
operators.
To
transfer
the
RAP,
owners/
operators
must
follow
the
requirements
specified
in
their
RAP
for
RAP
modification
to
identify
the
new
owner/
operator,
and
incorporate
any
other
necessary
requirements.
2
The
new
owner/
operator
must
submit
a
revised
RAP
application
no
later
than
90
days
before
the
scheduled
change
along
with
a
written
agreement
containing
a
specific
date
for
transfer
of
RAP
responsibility
between
the
owner/
operator
and
the
new
permittees.
27
Under
40
CFR
270.220(
b),
when
a
transfer
of
ownership
occurs,
the
old
owner/
operator
must
comply
with
applicable
requirements
of
40
CFR
part
264,
subpart
H,
until
the
new
owner/
operator
has
demonstrated
compliance
(
i.
e.,
within
six
months
of
the
date
of
the
change).
[
Note:
The
demonstrations
under
40
CFR
part
264,
subpart
H
are
addressed
in
"
General
Hazardous
Waste
Facility
Standards,"
ICR
Number
1571.]

(
i)
Data
Items:

The
data
item
required
of
the
owner/
operator
with
the
RAP
includes:

°
Information
specified
in
the
RAP
for
RAP
modification.

The
data
items
required
of
the
new
owner/
operator
include:

°
A
revised
RAP
application;
and
°
A
written
agreement
containing
a
specific
date
for
transfer
of
RAP
responsibility
between
the
owner/
operator
and
the
new
permittees.

(
ii)
Respondent
Activities:

In
order
to
comply
with
the
above
requirements,
owners/
operators
with
the
RAP
must
conduct
the
following
activity:

°
Modify
RAP.

In
order
to
comply
with
the
above
requirements,
the
new
owners/
operators
must
conduct
the
following
activities:

°
Prepare
a
revised
RAP
application
and
a
written
agreement
containing
a
specific
date
for
transfer
of
RAP
responsibility
between
the
owner/
operator
and
the
new
permittees;
and
°
Submit
modified
RAP
and
written
agreement
to
the
Director
no
later
than
90
days
before
the
scheduled
changes.

(
f)
RAP
for
an
Off­
Site
Location
Under
40
CFR
270.230(
a),
owners/
operators
may
request
a
RAP
for
hazardous
remediation
waste
management
activities
at
a
location
removed
from
the
area
where
the
remediation
wastes
originated
if
they
believe
such
a
location
would
be
more
protective
than
the
contaminated
area
or
areas
in
close
proximity.
Owners/
operators
must
request
the
RAP,
and
the
Director
will
approve
or
deny
the
RAP,
according
to
the
requirements
in
part
270,
subpart
H
28
(
§
270.230(
c)).
[
Note:
Refer
to
subsection
"
RAP
Application"
of
this
ICR
for
requirements
applicable
to
owners/
operators
of
remediation
waste
management
sites
applying
for
a
RAP.]

A
RAP
for
an
alternative
location
must
meet
the
additional
requirements
specified
in
section
270.230(
d),
including
the
RCRA
expanded
public
participation
requirements
in
sections
124.31
through
124.33.
[
Note:
This
ICR
does
not
address
the
expanded
public
participation
requirements
in
40
CFR
124.31
through
124.33.
Refer
to
"
RCRA
Expanded
Public
Participation,"
ICR
Number
1688,
for
these
requirements.]

In
addition,
under
section
270.230(
e)(
2),
these
alternative
locations
are
remediation
waste
management
sites,
and
retain
the
benefit
of
complying
with
the
requirements
of
section
264.1(
j)
in
lieu
of
part
264,
subpart
B,
C,
and
D.
[
Note:
Refer
to
subsection
"
General
Requirements
for
Hazardous
Remediation
Waste
Management
Sites"
of
this
ICR
for
these
requirements.]

5.
THE
INFORMATION
COLLECTED
 
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
(
1)
General
Requirements
for
Hazardous
Remediation
Waste
Management
Sites
(
a)
Demonstrations
for
Remediation
Waste
Management
Sites
in
Floodplains
The
Director
must
receive
and
review
information
submitted
by
owners/
operators
to
meet
the
demonstration
of
section
264.18(
b).

(
2)
Requirements
for
Staging
Piles
(
a)
Designation
of
Staging
Piles
The
Director
must
receive
and
review
information
submitted
by
all
owners/
operators
seeking
a
staging
pile
designation.
Based
on
this
information,
the
Director
designates
a
staging
pile
in
a
permit,
closure
plan,
or
order
under
section
264.554(
b)
and
establishes
standards
and
design
criteria
in
accordance
with
section
264.554(
d).
In
addition,
the
Director
may
receive
and
review
additional
information
for
staging
pile
designations
submitted
under
section
264.554(
c)(
3).

(
b)
Staging
Pile
Extensions
Under
40
CFR
264.554(
h),
the
Director
designates
in
the
permit
the
length
of
time
the
owner/
operator
may
use
a
staging
pile,
which
may
be
up
to
two
years.
Under
section
264.554(
i),
the
Director
may
grant
extensions
of
up
to
180
days
for
the
use
of
staging
piles.
The
Director
must
receive
and
review
request
for
extensions
from
owners/
operators,
and
determine
whether
to
grant
an
extension.
The
Director
may,
as
a
condition
of
the
extension,
specify
further
standards
29
and
design
criteria
in
the
permit,
closure
plan,
or
order.

(
c)
Closure
of
Staging
Piles
40
CFR
264.554(
j)
provides
that,
within
180
days
after
the
operating
term
of
the
staging
pile
expires,
owners/
operators
must
close
a
staging
pile
located
in
a
previously
contaminated
area
of
the
site
by
removing
or
decontaminating
all
remediation
waste,
contaminated
containment
system
components,
and
structures
and
equipment
contaminated
with
waste
and
leachate.
The
owner/
operator
must
also
decontaminate
subsoils
in
a
manner
and
according
to
a
schedule
that
the
Director
determines
will
protect
human
health
and
the
environment.
The
Director
must
include
these
requirements
in
the
permit,
closure
plan,
or
order
in
which
the
staging
pile
is
designated.

Section
264.554(
k)
provides
that,
within
180
days
after
the
operating
term
of
the
staging
pile
expires,
owners/
operators
must
close
a
staging
pile
located
in
an
uncontaminated
area
of
the
site
according
to
sections
264.258(
a)
and
264.111;
or
according
to
sections
265.258(
a)
and
265.111.
The
Director
must
include
the
above
requirement
in
the
permit,
closure
plan,
or
order
in
which
the
staging
pile
is
designated.

[
Note:
This
ICR
does
not
address
the
requirements
for
preparing
a
permit
(
other
than
a
RAP),
a
closure
plan,
or
an
order.
Refer
to
"
General
Hazardous
Waste
Facility
Standards,"
ICR
Number
1571,
for
these
requirements.]

(
d)
Incorporation
of
Staging
Piles
into
Existing
Permits
40
CFR
264.554(
l)
specifies
procedures
for
incorporating
staging
piles
into
existing
permits
(
including
RAPs),
closure
plans,
or
orders.
Pursuant
to
section
264.554(
l)(
1),
a
permit,
other
than
a
RAP,
may
be
modified
to
incorporate
a
staging
pile
or
staging
pile
operating
term
extension
as
part
of
an
Agency­
initiated
permit
modification
under
section
270.41or
as
part
of
an
owner/
operator
initiated
Class
2
permit
modification
under
section
270.42.
[
Note:
This
ICR
does
not
address
the
requirements
in
40
CFR
264.41
and
264.42
for
modifying
an
existing
RCRA
permit.
Refer
to
"
Part
B
Permit
Application,
Permit
Modifications,
and
Special
Permits,"
ICR
Number
1573,
for
these
requirements.]

(
e)
Data
Availability
Under
section
264.554(
m),
the
Director
must
document
the
rationale
for
designating
a
staging
pile
or
staging
pile
operating
term
extension
and
make
this
documentation
available
to
the
public.
30
(
3)
Remedial
Action
Plans
(
a)
RAP
Applications
According
to
40
CFR
270.95
and
270.120,
the
Director
must
receive
RAP
applications
for
approval.
Sections
270.130
through
270.140
identify
the
activities
the
Director
must
follow
to
review
and
approve
RAP
applications.
As
part
of
this
process,
the
Director
may
require
RAP
applicants
to
provide
additional
information,
as
described
in
section
270.110(
i).
When
additional
information
is
requested,
the
Director
must
receive
and
review
the
information
to
ensure
that
the
RAP
application
complies
with
applicable
hazardous
remediation
waste
management
standards
and,
if
necessary,
develop
additional
permit
conditions.

Based
on
the
RAP
application,
the
Director
must
prepare
either
a
draft
RAP
or
a
notice
of
intent
to
deny
the
RAP.
Section
270.135
describes
what
the
Director
must
include
in
a
draft
RAP.

Under
section
270.140(
a),
the
Director
must
prepare
a
statement
of
basis
that
briefly
describes
the
derivation
of
conditions
of
the
draft
RAP
or
the
rationale
for
the
notice
of
intent
to
deny
the
RAP.
Under
section
270.140(
b),
the
Director
must
compile
an
administrative
record.
Under
section
270.140(
c),
the
Director
must
make
that
record
available
to
the
public.
The
administrative
record
should
include
the
following
items:

°
The
RAP
application
and
any
supporting
data
furnished
by
the
applicant;

°
The
draft
RAP
or
notice
of
intent
to
deny;

°
The
statement
of
basis
and
all
documents
cited
therein;
and
°
Other
documents
supporting
the
decision
to
approve
or
deny
the
RAP
Under
40
CFR
270.85(
c),
an
owner/
operator
may
obtain
a
RAP
for
managing
hazardous
remediation
waste
at
an
already
permitted
RCRA
facility.
This
RAP
must
be
approved
as
a
modification
to
the
existing
permit
according
to
the
requirements
of
section
270.41
or
section
270.42.
When
the
permit
is
modified,
the
RAP
becomes
part
of
the
RCRA
permit.
[
Note:
This
ICR
does
not
address
the
requirements
in
40
CFR
270.41
and
270.42
for
modifying
an
existing
RCRA
permit.
Refer
to
"
Part
B
Permit
Application,
Permit
Modifications,
and
Special
Permits,"
ICR
Number
1573,
for
these
requirements.]

(
b)
Public
Comment
on
the
Draft
RAP
or
Notice
of
Intent
to
Deny
Under
40
CFR
270.145,
the
Director
must
notify
the
applicant
of
his
intention
to
approve
or
deny
the
RAP
application.
The
Director
also
must
notify
the
public
of
his
intention
to
approve
or
deny
the
RAP
application
by
publishing
a
notice
in
a
major
local
newspaper
or
general
31
circulation
and
broadcasting
his
intention
over
a
local
radio
station.
In
addition,
the
Director
must
notify
the
applicable
local
government
and
State
agencies
of
his
intention.

The
public
notice
must
provide
an
opportunity
for
the
public
to
submit
written
comments
on
the
draft
RAP
or
notice
of
intent
to
deny
within
at
least
45
days.
If,
within
the
comment
period,
the
Director
receives
written
notice
of
opposition
to
his
intention
to
approve
or
deny
the
RAP
application
and
a
request
for
a
hearing,
the
Director
must
hold
an
informal
public
hearing
to
discuss
issues
related
to
the
approval
or
denial
of
the
RAP
application.
The
Director
may
also
determine
on
his
own
initiative
that
an
informal
hearing
is
appropriate.
The
Director
must
notify
the
public
that
a
hearing
will
take
place.

(
c)
RAP
Final
Decisions
40
CFR
270.150
specifies
the
procedures
by
which
the
Director
must
make
a
final
decision
on
RAP
applications.
If
the
RAP
is
to
be
approved,
the
Director
must
issue
a
final
RAP
and
notify
the
applicant
and
all
commenters
on
the
draft
RAP
of
the
approval
in
writing.
If
the
RAP
is
denied,
the
Director
must
prepare
and
send
to
the
applicant
and
all
commenters
on
the
draft
RAP
of
the
denial
in
writing.
Before
issuing
a
final
decision,
the
Director
must
compile
an
administrative
record
that
includes
the
following
items:

°
All
comments
received
during
the
public
comment
period;

°
Tapes
or
transcripts
of
any
hearings;

°
Any
written
materials
submitted
at
such
hearings;

°
The
responses
to
comments;

°
Any
new
material
placed
in
the
record
since
issuance
of
the
draft
RAP;

°
Any
other
documents
supporting
the
RAP;
and
°
A
copy
of
the
final
RAP.

(
d)
Administrative
Appeal
of
a
RAP
Application
Under
40
CFR
270.155,
the
Director
must
review
administrative
appeals
of
the
Director's
decision
to
approve
or
deny
a
RAP.
The
Director
must
then
give
public
notice
of
any
grant
of
review
of
RAPs
by
the
Environmental
Appeals
Board
(
EAB).
32
(
e)
RAP
Modification,
Revocation
and
Reissuance,
and
Termination
Under
40
CFR
270.170,
the
Director
must
specify
in
a
RAP,
either
directly
or
by
reference,
procedures
for
future
modifications,
revocations
and
reissuance,
or
termination
of
the
RAP.
These
procedures
must
provide
adequate
opportunities
for
public
review
and
comment
on
any
modification,
revocation
and
reissuance,
or
termination
that
would
significantly
change
the
management
of
the
remediation
waste,
or
that
otherwise
merits
public
review
and
comment.

Under
sections
270.175
and
270.185,
the
Director
may
choose
to
modify
the
final
RAP
because
the
owner/
operator
made
material
and
substantial
alterations
to
the
RAP,
new
information
became
available,
or
standards
and
regulations
under
which
the
RAP
was
submitted
have
changed.
In
addition,
if
the
RAP
includes
a
compliance
schedule,
the
Director
may
modify
it
if
events
over
which
the
owner/
operator
has
little
control
over
affect
RAP
activities
(
e.
g.,
a
flood).

If
the
RAP
has
been
incorporated
into
a
traditional
RCRA
permit,
as
allowed
under
section
270.85(
c),
then
the
RAP
will
be
modified
according
to
the
applicable
requirements
in
sections
270.40
through
270.42,
revoked
and
reissued
according
to
the
applicable
requirements
in
sections
270.41
and
270.43,
or
terminated
according
to
applicable
requirements
of
section
270.43.
[
Note:
This
ICR
does
not
address
the
requirements
in
40
CFR
270.41
through
270.43
for
modifying,
revoking
and
reissuing,
and
terminating
a
RCRA
permit.
Refer
to
"
Part
B
Permit
Application,
Permit
Modifications,
and
Special
Permits,"
ICR
Number
1573,
for
these
requirements.]

(
f)
Administrative
Appeal
of
a
Modification,
Revocation
and
Reissuance,
or
Termination
of
a
RAP
Under
40
CFR
270.190(
c),
the
EAB
must
review
administrative
appeals
of
revisions
to
a
RAP.
The
Board
must
act
on
the
appeal
within
60
days
of
receiving
it;
otherwise,
the
appeal
is
considered
denied.

(
g)
RAP
Expiration
Under
40
CFR
270.195,
the
Director
may
renew
the
RAP
for
up
to
10
years.
In
addition,
the
Director
must
review
any
RAP
for
hazardous
waste
land
disposal
five
years
after
the
RAP
is
issued
or
reissued.

(
h)
RAP
Transfers
Under
40
CFR
270.220,
once
the
new
owner/
operator
has
submitted
a
revised
RAP
application,
and
has
demonstrated
compliance
with
40
CFR
part
264,
subpart
H,
the
Director
will
notify
the
previous
owner/
operator
that
he
or
she
no
longer
has
to
comply
with
40
CFR
part
264,
subpart
H.
33
(
i)
RAP
for
an
Off­
Site
Location
Under
40
CFR
270.230,
if
the
applicant
wishes
to
perform
remediation
waste
management
activities
under
a
RAP
at
a
location
removed
from
the
area
where
the
waste
originated,
the
Director
must
approve
a
RAP
for
this
alternative
location
and
must
include
in
the
RAP
that
the
alternative
location
meets
the
requirements
of
section
270.230(
d).
[
Note:
Refer
to
subsection
"
RAP
Applications"
of
this
ICR
for
Agency
requirements
associated
with
the
RAP
application
process.
Refer
to
"
RCRA
Expanded
Public
Participation,"
ICR
Number
1688,
for
the
expanded
public
participation
requirements
in
40
CFR
124.31
through
124.33.]

5(
b)
Collection
Methodology
and
Management
In
collecting
and
analyzing
the
information
submitted,
EPA
uses
equipment
such
as
personal
computers
and
applicable
data
base
software,
when
appropriate.
As
part
of
the
RAP
application
process,
the
public
will
receive
information
through
newspaper
announcements
and
other
media,
and,
upon
request,
will
have
access
to
additional
data
in
the
administrative
record.

5(
c)
Small
Entity
Flexibility
RAPs
are
not
mandatory.
The
Agency
believes
that
the
RAP
provisions
provide
a
flexible,
less
burdensome
alternative
to
RCRA
permitting
at
remediation
waste
management
sites.

Staging
piles
provide
an
alternative
to
placing
hazardous
remediation
waste
in
a
waste
pile.
Staging
piles
are
less
burdensome
because
the
waste
need
not
be
treated
to
land
disposal
restriction
standards
before
being
placed
in
the
pile,
as
is
the
case
for
a
waste
pile.

These
regulatory
alternatives
may
decrease
burden
for
both
small
and
large
entities.

5(
d)
Collection
Schedule
(
1)
Requirements
for
Staging
Piles
As
provided
under
40
CFR
264.554(
d)(
1)(
iii),
a
staging
pile
must
not
operate
for
more
than
two
years,
except
when
the
Director
grants
an
operating
term
extension
under
section
264.554(
i).
The
owner/
operator
must
measure
the
two­
year
limit,
or
other
operating
term
specified
by
the
Director
in
the
permit,
closure
plan,
or
order,
from
the
first
time
remediation
waste
is
placed
into
the
staging
pile.
The
owner/
operator
must
maintain
a
record
of
the
date
when
remediation
waste
was
first
placed
into
the
staging
pile
for
the
life
of
the
permit,
order,
or
approved
closure
plan,
or
for
three
years,
whichever
is
longer.

Under
40
CFR
264.554(
i)(
1),
the
Director
may
grant
one
operating
term
extension
for
a
34
staging
pile
of
up
to
180
days
beyond
the
operating
term
limit
contained
in
the
permit,
closure
plan,
or
order.
To
obtain
an
extension,
owners/
operators
must
document
that
an
extension
will
not
pose
a
threat
to
human
health
and
the
environment
and
is
necessary
to
ensure
timely
and
efficient
implementation
of
remedial
actions
at
the
facility.

40
CFR
264.554(
k)
provides
that,
within
180
days
after
the
operating
term
of
the
staging
pile
expires,
owners/
operators
must
close
a
staging
pile
located
in
an
uncontaminated
area
of
the
site
in
accordance
with
sections
264.258(
a)
and
265.258(
a)
and
sections
264.111
and
265.111
(
i.
e.,
the
closure
requirements
for
waste
piles).

(
2)
Remedial
Action
Plans
Under
40
CFR
270.220(
a),
owners/
operators
of
remediation
waste
management
sites
may
transfer
their
RAPs
to
new
owners/
operators.
To
transfer
the
RAP,
owners/
operators
must
follow
the
requirements
specified
in
their
RAP
for
RAP
modification
to
identify
the
new
owner/
operator,
and
incorporate
any
other
necessary
requirements.
The
new
owner/
operator
must
submit
a
revised
RAP
application
no
later
than
90
days
before
the
scheduled
change
along
with
a
written
agreement
containing
a
specific
date
for
transfer
of
RAP
responsibility
between
the
owner/
operator
and
the
new
permittees.

6.
ESTIMATING
THE
HOUR
AND
COST
BURDEN
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Hours
EPA
estimates
respondent
hourly
burden
for
all
the
information
collection
requirements
covered
in
this
ICR
in
Exhibit
1.
The
burden
estimates
for
each
activity
presented
in
Exhibit
1
include
the
burden
hours
(
total
and
by
labor
type)
per
respondent,
as
well
as
the
overall
burden
hours
for
all
respondents.

6(
b)
Estimating
Respondent
Costs
Exhibit
1
estimates
the
annual
costs
to
respondents
based
on
the
cost
of
labor,
capital,
and
operations
and
maintenance
(
O&
M).

(
1)
Labor
Costs
EPA
used
the
Bureau
of
Labor
Statistics
Employment
Cost
Index
for
state
and
local
government
workers
ending
May
2004.
EPA
estimates
an
average
hourly
salary
rate
of
$
116.17
for
legal
staff,
$
94.73
for
managerial
staff,
$
60.86
for
technical
staff,
and
$
34.97
for
clerical
staff,
which
includes
an
average
overhead
factor
of
1.728.

(
2)
Capital
Costs
35
3
Postage
cost
estimates
are
from
the
U.
S.
Postal
Service
and
are
based
on
the
mailing
cost
for
a
two­
pound
package.

4
Waste
analysis
costs
are
based
on
testing
cost
estimates
for
§
264.13(
a)(
1)
in
"
General
Hazardous
Waste
Facility
Standards,"
ICR
Number
1571.
These
testing
cost
estimates
were
updated
to
2004
cost
levels
using
Consumer
Price
Indexes
developed
by
the
U.
S.
Bureau
of
Labor
Statistics.

5
Specifically,
EPA
contacted
four
States
that
have
adopted
the
RAP
provisions.
EPA
found
that,
over
the
past
two
years,
these
States
have
issued
a
total
of
nineteen
RAPs.
Given
this,
EPA
extrapolated
to
the
entire
nation
based
on
the
relative
quantity
of
hazardous
waste
managed
in
these
four
States
versus
all
Capital
costs
usually
include
any
produced
physical
good
needed
to
provide
the
necessary
information,
such
as
machinery,
computers,
and
other
equipment.
EPA
does
not
anticipate
that
respondents
will
incur
capital
costs
in
carrying
out
the
information
collection
requirements
covered
in
this
ICR.

(
3)
Operation
&
Maintenance
Costs
O&
M
costs
are
those
costs
associated
with
a
paperwork
requirement
incurred
continually
over
the
life
of
the
ICR.
They
are
defined
by
the
Paperwork
Reduction
Act
of
1995
as
"
the
recurring
dollar
amount
of
cost
associated
with
O&
M
or
purchasing
services."
For
this
ICR,
O&
M
costs
cover
mailing
costs
($
4.48
per
submittal)
3
and
waste
analysis
costs
($
845
per
respondent).
4
6(
c)
Estimating
Agency
Hour
and
Cost
Burden
EPA
estimates
the
Agency
hour
and
cost
burden
associated
with
all
the
requirements
covered
in
this
ICR
in
Exhibit
2.
Based
on
the
"
General
Schedule
(
GS)
Salary
Table
2005,"
EPA
estimates
an
average
hourly
labor
rate
of
$
68.70
for
legal
staff
(
GS­
15,
Step
1),
$
64.24
for
managerial
staff
(
GS­
14,
Step
4),
$
56.02
for
technical
staff
(
GS­
12,
Step
5),
and
$
18.91
for
clerical
staff
(
GS­
5,
Step
1).
To
derive
these
hourly
estimates,
EPA
multiplied
the
basic
hourly
rates
by
the
standard
government
overhead
factor
of
1.6.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Hour
and
Cost
Burden
(
1)
Respondent
Universe
(
a)
Hazardous
Remediation
Waste
Management
Sites
Subject
to
40
CFR
264.1(
j)
and
Part
270,
Subpart
H
In
estimating
the
number
of
owners/
operators
of
hazardous
remediation
waste
management
sites
subject
to
40
CFR
264.1(
j)
and
part
270,
subpart
H
(
i.
e.,
the
requirements
for
sites
with
RAPs),
EPA
conducted
consultations
with
a
number
of
States
and
extrapolated
these
data
for
the
entire
country.
5
Based
on
this
analysis,
EPA
estimates
that,
currently,
there
are
14
36
States.
Refer
to
Section
3
of
this
ICR
for
a
list
of
the
States
contacted.

6
In
estimating
the
number
of
existing
hazardous
remediation
waste
management
sites,
EPA
analyzed
data
submitted
by
generators
of
remediation­
derived
waste
(
i.
e.,
BRS
source
codes
G41,
G42,
G43,
G44,
G45,
and
G49)
to
the
2001
and
2003
BRS.
Based
on
these
data,
EPA
found
that,
currently,
there
are
1,756
sites
generating
remediation­
derived
wastes.
For
purposes
of
this
ICR,
EPA
assumes
that
only
five
percent
of
these
sites
(
i.
e.,
0.05
x
1,756
=
88)
are
subject
to
40
CFR
264.554.
hazardous
remediation
waste
management
sites
with
RAPs.
EPA
also
estimates
that,
each
year,
eight
new
owners/
operators
of
hazardous
remediation
waste
management
sites
will
apply
for
a
RAP.
Thus,
EPA
estimates
that,
on
average,
30
sites
will
be
subject
to
the
requirements
in
40
CFR
264.1(
j)
and
part
270,
subpart
H
over
the
three­
year
period
of
this
ICR.
This
is
reflected
in
Table
1.

Table
1
Number
of
Hazardous
Remediation
Waste
Management
Sites
Subject
to
40
CFR
264.1(
j)
and
Part
270,
Subpart
H
Type
of
Remediation
Site
Year
1
Year
2
Year
3
Existing
14
22
30
New
8
8
8
Total
22
30
38
Note
that
this
ICR
addresses
only
non­
permitted
sites
under
40
CFR
264.1(
j)
and
part
270,
subpart
H.
As
discussed
earlier
in
this
ICR,
a
site
may
conduct
cleanup
through
a
RAP,
permit,
or
other
specified
mechanism.
Permitted
facilities
would
obtain
a
RAP
by
modifying
their
permit.
These
activities
are
already
addressed
in
"
Part
B
Permit
Application,
Permit
Modifications,
and
Special
Permits,"
ICR
Number
1573.
Therefore,
this
ICR
addresses
only
nonpermitted
sites
under
the
RAP
requirements.

(
b)
Hazardous
Remediation
Waste
Management
Sites
Subject
to
40
CFR
264.554
In
estimating
the
number
of
owners/
operators
of
hazardous
remediation
waste
management
sites
subject
to
the
40
CFR
264.554
requirements
for
staging
piles,
EPA
referred
to
the
Biennial
Reporting
System
(
BRS).
Based
on
analysis
of
BRS
data,
EPA
estimates
that,
currently,
there
are
88
existing
hazardous
remediation
waste
management
sites
with
staging
piles.
6
EPA
also
estimates
that,
each
year,
58
owners/
operators
of
non­
permitted
hazardous
remediation
37
7
In
estimating
the
number
of
new
hazardous
remediation
waste
management
sits,
EPA
conducted
a
trend
analysis
of
data
submitted
by
generators
of
remediation
derived
waste
to
the
2001
and
2003
BRS.
Based
on
these
data,
EPA
found
that,
each
year,
1,158
new
sites
generate
remediation­
derived
wastes.
For
purposes
of
this
ICR,
EPA
assumes
that
only
five
percent
of
the
owners/
operators
of
these
sites
(
i.
e.,
0.05
x
1,158
=
58)
will
seek
a
staging
pile
designation
each
year.

8
Permitted
facilities
must
modify
their
permit
to
incorporate
a
staging
pile.
Refer
to
"
Part
B
Permit
Application,
Permit
Modifications,
and
Special
Permits,"
ICR
Number
1573,
for
the
burden
to
these
facilities.
waste
management
sites
will
seek
a
new
staging
pile
designation.
7,
8
(
2)
Annual
Respondent
Hour
and
Cost
Burden
(
a)
Reading
the
Regulations
EPA
estimates
that
176
owners/
operators
of
hazardous
remediation
waste
management
sites
(
i.
e.,
30
+
88
+
58
=
176)
will
be
subject
to
the
requirements
in
this
ICR
and
will,
therefore,
read
the
regulations
each
year.

(
b)
General
Requirements
for
Hazardous
Remediation
Waste
Management
Sites
Following
is
a
discussion
of
the
Agency's
burden
assumptions
regarding
sites
subject
to
the
40
CFR
264.1(
j)
requirements.

(
b1)
Waste
Analyses
Owners/
operators
of
hazardous
remediation
waste
managements
sites
are
required
to
obtain
a
detailed
chemical
and
physical
analysis
of
a
representative
sample
of
the
hazardous
remediation
waste
to
be
managed
at
the
site.
EPA
estimates
that
the
owners/
operators
of
all
30
remediation
sites
will
perform
waste
analyses
in
order
to
obtain
this
information
each
year.

(
b2)
Inspections
Owners/
operators
must
inspect
the
remediation
waste
management
site
for
malfunctions,
deterioration,
operator
errors,
and
discharges
that
may
be
causing,
or
may
lead
to,
a
release
of
hazardous
waste
constituents
to
the
environment,
or
a
threat
to
human
health.
Note
that
this
ICR
burdens
inspections
under
Section
b6
of
this
subsection,
"
Compliance
Plan."
38
(
b3)
Demonstrations
for
Remediation
Waste
Management
Sites
in
Floodplains
Hazardous
remediation
waste
management
units
must
be
designed,
constructed,
operated,
and
maintained
in
such
a
way
as
to
prevent
washout
of
any
hazardous
waste
within
a
100­
year
floodplain.
Exceptions
are
allowed
for
sites
that
meet
the
demonstration
requirements
of
section
264.18(
b).

EPA
assumes
that
owners/
operators
of
existing
remediation
sites
have
already
prepared
and
submitted
the
above
demonstration,
if
applicable.
EPA
further
assumes
that,
each
year,
five
percent
of
owners/
operators
of
new
remediation
sites
(
i.
e.,
0.05
x
8
=
0)
will
prepare
and
submit
the
demonstration.
Thus,
EPA
estimates
that
no
owner/
operator
of
a
remediation
site
will
need
to
comply
with
this
information
collection
requirement
during
the
three­
year
period
covered
in
this
ICR.

(
b4)
Construction
Quality
Assurance
Program
Owners/
operators
of
hazardous
remediation
waste
management
sites
are
required
to
develop
and
maintain
a
construction
quality
assurance
program
for
all
surface
impoundments,
waste
piles,
and
landfill
units,
as
specified.
EPA
assumes
that
existing
remediation
sites
have
already
developed
their
construction
quality
assurance
programs.
Thus,
EPA
estimates
that
only
the
eight
new
remediation
sites
will
have
to
conduct
this
activity
each
year.

(
b5)
Contingency
and
Emergency
Plan
Owners/
operators
of
hazardous
remediation
waste
management
sites
are
required
to
develop
and
maintain
procedures
to
prevent
accidents.
EPA
assumes
that
existing
remediation
sites
have
already
developed
these
procedures.
Thus,
EPA
estimates
that
only
the
eight
new
remediation
sites
will
have
to
conduct
this
activity
each
year.

Owners/
operators
of
hazardous
remediation
waste
management
sites
also
are
required
to
develop
and
maintain
a
contingency
and
emergency
plan.
EPA
assumes
that
existing
remediation
sites
have
already
developed
their
contingency
and
emergency
plans.
Thus,
EPA
estimates
that
only
the
eight
new
remediation
sites
will
have
to
conduct
this
activity
each
year.

(
b6)
Compliance
Plan
Owners/
operators
of
hazardous
remediation
waste
management
sites
are
required
to
develop,
maintain,
and
implement
a
plan
to
meet
the
requirements
in
sections
264.1(
j)(
2)
through
(
j)(
6)
and
sections
264.1(
j)(
9)
through
(
j)(
10).
EPA
estimates
that
the
owners/
operators
of
all
30
remediation
sites
will
need
to
comply
with
this
information
collection
requirement
each
year.
39
(
b7)
Recordkeeping
Requirements
Owners/
operators
of
hazardous
remediation
waste
management
sites
are
required
to
maintain
records
documenting
compliance
with
sections
264.1(
j)(
1)
through
(
j)(
12)
in
the
operating
record.
EPA
estimates
that
the
owners/
operators
of
all
30
remediation
sites
will
need
to
comply
with
these
recordkeeping
requirements
each
year.

(
c)
Requirements
for
Staging
Piles
Following
is
a
discussion
of
the
Agency's
burden
assumptions
regarding
sites
subject
to
the
40
CFR
264.554
requirements
for
staging
piles.

(
c1)
Designation
of
Staging
Piles
To
manage
hazardous
remediation
waste
in
a
staging
pile,
owners/
operators
of
hazardous
remediation
waste
management
sites
must
seek
a
staging
pile
designation
from
the
Director.
EPA
estimates
that,
each
year,
58
owners/
operators
of
hazardous
remediation
waste
management
sites
will
seek
staging
pile
designations
under
section
264.554(
c).
EPA
also
estimates
that
one
percent
(
i.
e.,
0.01
x
58
=
1)
of
these
owners/
operators
will
need
to
prepare
and
submit
additional
information
requested
by
the
Director.

(
c2)
Staging
Pile
Recordkeeping
Owners/
operators
of
staging
piles
must
keep
a
record
of
the
date
when
waste
was
first
placed
in
the
staging
pile.
EPA
estimates
that,
each
year,
all
58
owners/
operators
of
hazardous
remediation
waste
management
sites
seeking
staging
pile
designations
under
section
264.554(
c)
will
need
to
comply
with
the
recordkeeping
requirements
under
section
264.554(
d)(
1)(
iii).

(
c3)
Staging
Pile
Extensions
Staging
piles
are
intended
to
be
used
for
up
to
two
years.
Under
certain
circumstances,
the
Director
may
grant
an
extension
of
up
to
six
months.
EPA
estimates
that,
each
year,
20
percent
of
owners/
operators
with
existing
staging
piles
(
i.
e.,
0.20
x
146
=
29)
will
request
an
operating
term
extension
for
a
staging
pile.
40
(
d)
Remedial
Action
Plans
Following
is
a
discussion
of
the
Agency's
burden
assumptions
regarding
sites
subject
to
the
40
CFR
part
270,
subpart
H
requirements.

(
d1)
RAP
Application
EPA
estimates
that,
each
year,
eight
owners/
operators
of
hazardous
remediation
waste
management
sites
will
submit
a
RAP
application.
EPA
assumes
that
50
percent
of
these
owners/
operators
(
i.
e.,
0.50
x
8
=
4)
will
be
able
to
use
existing
documents
that
satisfy
the
requirements
for
a
RAP
in
preparing
their
RAP
applications.
The
remaining
50
percent
(
i.
e.,
0.50
x
8
=
4)
will
not
have
existing
documents
that
satisfy
the
requirements
for
a
RAP
and
thus,
will
have
to
develop
RAP
applications
from
new
information.
All
owners/
operators
must
submit
their
RAP
application
to
the
Director.

The
Director
may
request
additional
information
if
necessary.
EPA
estimates
that
ten
percent
of
owners/
operators
submitting
RAP
applications
each
year
(
i.
e.,
0.10
x
8
=
1)
will
be
required
to
prepare
and
submit
additional
information.

(
d2)
RAP
Modification,
Revocation
and
Reissuance,
and
Termination
To
modify
a
RAP,
owners/
operators
must
prepare
and
submit
information
to
modify
their
RAP
in
accordance
to
the
procedures
specified
in
the
RAP.
EPA
estimates
that,
each
year,
five
percent
of
owners/
operators
of
hazardous
remediation
waste
management
sites
with
a
RAP
will
need
to
modify
it.
Thus,
EPA
estimates
that
two
owner/
operators
(
i.
e.,
0.05
x
30
=
2)
will
need
to
modify
his
RAP.

(
d3)
RAP
Recordkeeping
Owners/
operators
of
hazardous
remediation
waste
management
sites
with
RAPs
are
required
to
keep
records
concerning
their
RAPs.
EPA
estimates
that
all
30
owners/
operators
of
hazardous
remediation
waste
management
sites
with
RAPs
will
maintain
a
file
of
RAP
documents.

(
d4)
RAP
Transfers
Owners/
operators
of
hazardous
remediation
waste
management
sites
with
RAPs
may
transfer
the
RAPs
to
new
owners/
operators.
EPA
assumes
that,
each
year,
one
percent
of
the
owners/
operators
(
i.
e.,
0.01
x
30
=
0)
will
transfer
their
RAP.
Thus,
EPA
estimates
that
no
owner/
operator
will
need
to
comply
with
this
information
collection
requirement
during
the
threeyear
period
covered
in
this
ICR.

6(
e)
Bottom
Line
Hour
and
Cost
Burden
41
(
1)
Respondent
Tally
Exhibit
1
shows
the
aggregate
annual
hour
and
cost
burden
to
respondents.
As
shown
in
the
exhibit,
EPA
estimates
the
annual
respondent
burden
to
be
4,944
hours
and
$
360,537.

(
2)
Agency
Tally
Exhibit
2
shows
the
annual
Agency
hour
and
cost
burden
associated
with
all
the
requirements
covered
in
this
ICR.
As
shown
in
this
exhibit,
EPA
estimates
the
annual
Agency
burden
to
be
2,737
hours
and
$
149,505.

6(
f)
Reasons
for
Change
in
Burden
The
burden
in
this
ICR
has
not
changed
appreciably
from
the
previous
renewal
(
ICR
#
1775.03).
The
total
annual
O&
M
burden
in
this
ICR
decreased
by
$
9,000
from
the
previous
renewal
(
ICR
#
1775.03),
which
is
due
to
refinements
in
the
burden
estimates.
This
decrease
of
$
9,000
is
therefore
considered
an
"
adjustment".

6(
g)
Burden
Statement
For
owners/
operators
of
hazardous
remediation
waste
management
sites
subject
to
the
40
CFR
264.1(
j)
and
part
270,
subpart
H
requirements,
the
reporting
burden
is
estimated
to
be
27.33
hours
per
respondent
per
year.
This
hourly
burden
includes
time
for
preparing
and
submitting
a
RAP
application,
information
to
modify
a
RAP,
and
information
to
transfer
a
RAP.
The
recordkeeping
burden
is
estimated
to
be
42.13
hours
per
respondent
per
year.
This
hourly
burden
includes
time
for
reading
the
regulations
and
maintaining
documentation
(
e.
g.,
waste
analyses
results,
contingency
and
emergency
plan,
file
of
RAP
documents)
on
site.

For
owners/
operators
of
hazardous
remediation
waste
management
sites
subject
to
the
40
CFR
264.554
requirements
for
staging
piles,
the
reporting
burden
is
estimated
to
be
7.08
hours
per
year
per
respondent.
This
hourly
burden
includes
time
for
preparing
and
submitting
information
for
a
staging
pile
designation
and
documentation
supporting
a
staging
pile
extension.
The
recordkeeping
burden
is
estimated
to
be
12.61
hours
per
respondent
per
year.
This
hourly
burden
includes
time
for
reading
the
regulations
and
complying
with
the
recordkeeping
requirements
in
section
264.554(
d)(
1)(
iii).

Burden
means
the
total
time,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
resources
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purpose
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
42
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
Number
RCRA­
2005­
0006,
which
is
available
for
public
viewing
at
the
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
Number
RCRA­
2005­
0006
and
OMB
Control
Number
2050­
0161
in
any
correspondence.
43
EXHIBIT
1
HWIR­
MEDIA
ICR
ESTIMATED
ANNUAL
RESPONDENT
HOUR
AND
COST
BURDEN
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Number
of
Leg.
Mgr.
Tech.
Cler.
Respon.
Labor
Capital/
Respon.
Total
Total
$
116.17
$
94.73
$
60.86
$
34.97
Hours/
Cost/
Startup
O
&
M
or
Hours/
Cost/

INFORMATION
COLLECTION
ACTIVITY
per
Year
per
Year
per
Year
per
Year
Year
Year
Cost
Cost
Activities
Year
Year
Reading
the
Regulations
Read
the
regulations
2.00
2.00
8.00
0.00
12.00
$
909
$
0
$
0
176
2,112
$
159,984
SUBTOTAL
2.00
2.00
8.00
0.00
12.00
$
909
$
0
$
0
176
2,112
$
159,984
GENERAL
REQUIREMENTS
FOR
HAZARDOUS
REMEDIATION
WASTE
MANAGEMENT
SITES
Waste
Analysis
(
264.1(
j)(
2))

Perform
waste
analysis
0.00
0.00
5.00
0.00
5.00
$
304
$
0
$
845
30
150
$
34,470
Inspections
(
264.1(
j)(
4))

Conduct
inspections
0.00
0.00
0.00
0.00
0.00
$
0
$
0
$
0
30
0
$
0
Demonstrations
for
Remediation
Waste
Management
Sites
in
Floodplains
(
264.1(
j)(
7))

Prepare
and
submit
demonstration
0.00
0.25
4.00
0.00
4.25
$
267
$
0
$
4.48
0
0
$
0
Construction
Quality
Assurance
Program
(
264.1(
j)(
9))

Develop
and
maintain
the
program
0.00
0.00
15.00
5.00
20.00
$
1,088
$
0
$
0
8
160
$
8,704
Contingency
and
Emergency
Plan
(
264.1(
j)(
10))

Develop
and
maintain
procedures
to
prevent
accidents
0.00
0.50
30.00
2.00
32.50
$
1,943
$
0
$
0
8
260
$
15,544
Develop
and
maintain
contingency
and
emergency
plan
0.00
0.00
0.00
0.50
0.50
$
17
$
0
$
0
8
4
$
136
Compliance
Plan
(
264.1(
j)(
12))

Develop,
maintain,
and
implement
plan
0.00
0.50
1.50
0.00
2.00
$
139
$
0
$
0
30
60
$
4,170
Recordkeeping
Requirements
(
261.4(
j)(
13))

Keep
records
documenting
compliance
0.00
0.00
0.00
6.00
6.00
$
210
$
0
$
0
30
180
$
6,300
SUBTOTAL
varies
varies
varies
varies
varies
varies
varies
varies
varies
814
$
69,324
STAGING
PILES
Designation
of
Staging
Piles
(
264.554(
c))

Prepare
information
for
designation
1.00
2.00
8.00
1.00
12.00
$
827
$
0
$
0
58
696
$
47,966
Obtain
certification
from
a
professional
engineer
0.00
0.00
1.00
0.00
1.00
$
61
$
0
$
0
58
58
$
3,538
Submit
designation
information
0.00
0.10
0.00
0.10
0.20
$
13
$
0
$
4.48
58
12
$
1,014
Prepare
and
submit
additional
information,
if
requested
0.00
0.50
1.00
0.50
2.00
$
126
$
0
$
4.48
1
2
$
130
Staging
Pile
Recordkeeping
(
264.554(
d)(
1)(
iii))

Record
the
date
of
waste
placement
0.00
0.50
0.00
0.50
1.00
$
65
$
0
$
0
58
58
$
3,770
File
the
record
0.00
0.00
0.00
0.50
0.50
$
17
$
0
$
0
58
29
$
986
Staging
Pile
Extensions
(
264.554(
i)(
1))

Prepare
documentation
supporting
extension
0.50
2.00
5.00
1.00
8.50
$
587
$
0
$
0
29
247
$
17,023
Submit
request
for
extension
0.00
0.10
0.00
0.10
0.20
$
13
$
0
$
4.48
29
6
$
507
SUBTOTAL
varies
varies
varies
varies
varies
varies
varies
varies
varies
1,108
$
74,934
44
EXHIBIT
1
(
continued)

HWIR­
MEDIA
ICR
ESTIMATED
ANNUAL
RESPONDENT
HOUR
AND
COST
BURDEN
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Number
of
Leg.
Mgr.
Tech.
Cler.
Respon.
Labor
Capital/
Respon.
Total
Total
$
116.17
$
94.73
$
60.86
$
34.97
Hours/
Cost/
Startup
O
&
M
or
Hours/
Cost/

INFORMATION
COLLECTION
ACTIVITY
per
Year
per
Year
per
Year
per
Year
Year
Year
Cost
Cost
Activities
Year
Year
REMEDIAL
ACTION
PLANS
RAPs
Applications
(
270.85
through
270.125)

Prepare
RAP
from
previously
existing
documents
1.00
5.00
30.00
4.00
40.00
$
2,556
$
0
$
0
4
160
$
10,224
Prepare
RAP
from
new
information
4.00
20.00
120.00
16.00
160.00
$
10,222
$
0
$
0
4
640
$
40,888
Submit
RAP
application
0.00
0.10
0.00
0.10
0.20
$
13
$
0
$
4.48
8
2
$
140
Prepare
and
submit
additional
information,
if
requested
0.00
0.50
1.00
0.50
2.00
$
126
$
0
$
4.48
1
2
$
130
RAP
Modification,
Revocation
and
Reissuance,
and
Termination
(
270.170)

Prepare
and
submit
information
to
modify
RAP
0.00
0.00
8.00
0.00
8.00
$
487
$
0
$
4.48
2
16
$
983
RAP
Recordkeeping
(
270.210)

Maintain
file
of
RAP
documents
0.00
0.00
1.00
2.00
3.00
$
131
$
0
$
0
30
90
$
3,930
RAP
Transfers
(
270.220)

Modify
RAP
0.50
0.50
0.00
0.50
1.50
$
123
$
0
$
0
0
0
$
0
Prepare
a
revised
RAP
application
and
written
agreement
1.00
1.00
0.50
0.50
3.00
$
259
$
0
$
0
0
0
$
0
Submit
modified
RAP
and
written
agreement
0.00
0.10
0.00
0.10
0.20
$
13
$
0
$
4.48
0
0
$
0
SUBTOTAL
varies
varies
varies
varies
varies
varies
varies
varies
varies
910
$
56,295
TOTAL
varies
varies
varies
varies
varies
varies
varies
varies
varies
4,944
$
360,537
45
EXHIBIT
2
HWIR­
MEDIA
ICR
ESTIMATED
ANNUAL
AGENCY
HOUR
AND
COST
BURDEN
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Number
of
Leg.
Mgr.
Tech.
Cler.
Labor
Labor
Capital/
Respon.
Total
Total
$
68.70
$
64.24
$
56.02
$
18.91
Hours/
Cost/
Startup
O
&
M
or
Hours/
Cost/

INFORMATION
COLLECTION
ACTIVITY
per
Year
per
Year
per
Year
per
Year
Year
Year
Cost
Cost
Activities
Year
Year
GENERAL
REQUIREMENTS
FOR
HAZARDOUS
REMEDIATION
WASTE
MANAGEMENT
SITES
Demonstrations
for
Remediation
Waste
Management
Sites
in
Floodplains
Receive
and
review
demonstration
information
0.00
0.50
2.00
0.20
2.70
$
148
$
0
$
0
0
0
$
0
SUBTOTAL
varies
varies
varies
varies
varies
varies
varies
varies
varies
0
$
0
STAGING
PILES
Designation
of
Staging
Piles
(
264.554(
b),
(
c)
and
(
d))

Receive
and
review
designation
information
0.50
2.00
8.00
1.00
11.50
$
630
$
0
$
0
58
667
$
36,540
Receive
and
review
additional
information
0.00
0.50
2.00
0.20
2.70
$
148
$
0
$
0
1
3
$
148
Designate
staging
pile
0.00
0.50
1.00
0.50
2.00
$
98
$
0
$
0
58
116
$
5,684
Establish
standards
and
design
criteria
1.00
3.00
12.00
1.00
17.00
$
953
$
0
$
0
58
986
$
55,274
Staging
Pile
Extensions
(
264.554(
h)
and
(
i))

Designate
length
of
time
the
staging
pile
is
active
0.00
0.50
1.00
0.50
2.00
$
98
$
0
$
0
29
58
$
2,842
Receive
and
review
request
for
extension
0.00
1.00
5.00
0.25
6.25
$
349
$
0
$
0
29
181
$
10,121
Deny
or
approve
extension
0.50
1.00
3.00
0.50
5.00
$
276
$
0
$
0
29
145
$
8,004
Data
Availability
(
264.554(
m))

Document
the
rationale
for
designating
a
staging
pile
0.00
0.00
2.00
0.00
2.00
$
112
$
0
$
0
58
116
$
6,496
SUBTOTAL
varies
varies
varies
varies
varies
varies
varies
varies
varies
2,272
$
125,109
REMEDIAL
ACTION
PLANS
RAP
Applications
(
270.95,
270.110(
i),
270.120,
270.130
through
270.140)

Receive/
review
RAP
application
1.00
2.00
10.00
1.00
14.00
$
776
$
0
$
0
8
112
$
6,208
Receive/
review
additional
information
0.00
0.50
2.00
0.25
2.75
$
149
$
0
$
0
1
3
$
149
Prepare
Draft
RAP
1.00
3.00
20.00
2.00
26.00
$
1,420
$
0
$
0
7
182
$
9,940
Prepare
Notice
of
Intent
to
deny
RAP
0.50
1.50
0.50
0.50
3.00
$
168
$
0
$
0
1
3
$
168
Prepare
Statement
of
Basis
0.00
1.00
2.00
0.50
3.50
$
186
$
0
$
0
8
28
$
1,488
Compile
an
administrative
record
0.00
0.00
0.50
1.00
1.50
$
47
$
0
$
0
8
12
$
376
Public
Comment
on
the
Draft
RAP
or
Notice
of
Intent
to
Deny
(
270.145)

Notify
applicant
of
intent
to
approve
or
deny
RAP
0.00
0.00
1.00
0.50
1.50
$
65
$
0
$
4.48
8
12
$
556
Notify
the
public
of
intent
to
approve
or
deny
RAP
0.00
0.00
1.00
0.50
1.50
$
65
$
0
$
4.48
8
12
$
556
Notify
State
and
local
government
of
intent
to
approve
or
deny
RAP
0.00
0.00
1.00
0.50
1.50
$
65
$
0
$
4.48
8
12
$
556
Notify
the
public
and
hold
public
meetings,
if
necessary
0.00
0.00
1.00
0.50
1.50
$
65
$
0
$
4.48
1
2
$
69
46
EXHIBIT
2
(
continued)

HWIR­
MEDIA
ICR
ESTIMATED
ANNUAL
AGENCY
HOUR
AND
COST
BURDEN
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Number
of
Leg.
Mgr.
Tech.
Cler.
Labor
Labor
Capital/
Respon.
Total
Total
$
68.70
$
64.24
$
56.02
$
18.91
Hours/
Cost/
Startup
O
&
M
or
Hours/
Cost/

INFORMATION
COLLECTION
ACTIVITY
per
Year
per
Year
per
Year
per
Year
Year
Year
Cost
Cost
Activities
Year
Year
REMEDIAL
ACTION
PLANS
(
continued)

RAP
Final
Decisions
(
270.150)

Issue
Final
RAP
0.00
1.50
3.00
1.00
5.50
$
283
$
0
$
4.48
7
39
$
2,012
Prepare
Notification
of
Approval
0.50
1.00
0.50
0.50
2.50
$
136
$
0
$
4.48
7
18
$
983
Prepare
Notice
of
Denial
0.50
1.00
0.50
0.50
2.50
$
136
$
0
$
4.48
1
3
$
140
Compile
an
administrative
record
0.00
0.00
0.50
1.00
1.50
$
47
$
0
$
0
8
12
$
376
Administrative
Appeal
of
a
RAP
Application
(
270.155)

Receive
and
review
administrative
appeal
0.00
0.50
2.00
0.20
2.70
$
148
$
0
$
0
1
3
$
148
Notify
the
public
of
any
review
of
RAPs
by
the
EAB
0.00
0.00
1.00
0.50
1.50
$
65
$
0
$
4.48
1
2
$
69
RAP
Modification,
Revocation
and
Reissuance,
and
Termination
(
270.170
through
270.185)

Specify
procedures
for
future
modification,
revocation
and
reissuance,
and
termination
0.00
0.00
1.00
0.00
1.00
$
56
$
0
$
0
2
2
$
112
Administrative
Appeal
of
a
RAP
Modification,
Revocation
and
Reissuance,
and
Termination
(
270.190(
c))

EAB
review
of
administrative
appeals
1.00
1.00
2.00
0.00
4.00
$
245
$
0
$
0
1
4
$
245
Act
on
the
appeal,
if
it
is
not
denied
1.00
1.00
2.00
0.00
4.00
$
245
$
0
$
0
1
4
$
245
RAP
Expiration
(
270.195)

Renew
the
RAP
for
up
to
10
years
0.00
1.00
2.00
0.50
3.50
$
186
$
0
$
0
0
0
$
0
Review
RAP
for
land
disposal
5
years
after
issuing
it
0.00
1.00
2.00
0.50
3.50
$
186
$
0
$
0
0
0
$
0
RAP
Transfers
(
270.220)

Receive/
review
written
agreement
0.00
0.50
0.00
0.20
0.70
$
36
$
0
$
0
0
0
$
0
Notification
to
previous
owner/
operator
0.00
1.00
0.00
0.50
1.50
$
74
$
0
$
0
0
0
$
0
SUBTOTAL
varies
varies
varies
varies
varies
varies
varies
varies
varies
465
$
24,396
TOTAL
varies
varies
varies
varies
varies
varies
varies
varies
varies
2,737
$
149,505
