SUPPORTING
STATEMENT
FOR
EPA
INFORMATION
COLLECTION
REQUEST
NUMBER
0262.11
RCRA
HAZARDOUS
WASTE
PERMIT
APPLICATION
AND
MODIFICATION,
PART
A
(
RENEWAL)

July
2005
TABLE
OF
CONTENTS
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION....................................
1
1(
a)
TITLE
AND
NUMBER
OF
THE
INFORMATION
COLLECTION..................
1
1(
b)
CHARACTERIZATION
OF
THE
INFORMATION
COLLECTION
..................
1
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION...........................................................
2
2(
a)
NEED
AND
AUTHORITY
FOR
THE
COLLECTION......................................
2
2(
b)
USE
AND
USERS
OF
THE
DATA...................................................................
2
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3
3(
a)
NONDUPLICATION.........................................................................................
3
3(
b)
PUBLIC
NOTICE
..............................................................................................
4
3(
c)
CONSULTATIONS
...........................................................................................
4
3(
d)
EFFECTS
OF
LESS
FREQUENT
COLLECTION.............................................
4
3(
e)
GENERAL
GUIDELINES
.................................................................................
4
3(
f)
CONFIDENTIALITY.........................................................................................
4
3(
g)
SENSITIVE
QUESTIONS.................................................................................
5
4.
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
......................................
5
4(
a)
RESPONDENTS
AND
NAICS
CODES.............................................................
5
4(
b)
INFORMATION
REQUESTED.........................................................................
6
5.
THE
INFORMATION
COLLECTED
­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
....................................
10
5(
a)
AGENCY
ACTIVITIES...................................................................................
10
5(
b)
COLLECTION
METHODOLOGY
AND
MANAGEMENT
............................
11
5(
c)
SMALL
ENTITY
FLEXIBILITY.....................................................................
11
5(
d)
COLLECTION
SCHEDULE............................................................................
11
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
COLLECTION
................................
12
6(
a)
ESTIMATING
RESPONDENT
BURDEN.......................................................
12
6(
b)
ESTIMATING
RESPONDENT
COSTS............................................................
13
6(
c)
ESTIMATING
AGENCY
BURDEN
AND
COST............................................
13
6(
d)
ESTIMATING
THE
RESPONDENT
UNIVERSE
AND
TOTAL
BURDEN
AND
COSTS...................................................................................................
16
6(
e)
BOTTOM
LINE
BURDEN
HOURS
AND
COSTS
.........................................
18
6(
f)
REASONS
FOR
CHANGE
IN
BURDEN.........................................................
18
6(
g)
BURDEN
STATEMENT
.................................................................................
18
EXHIBITS
ESTIMATED
RESPONDENT
BURDEN
AND
COST
(
EXHIBIT
1)
....................................
14
ESTIMATED
AGENCY
BURDEN
AND
COST
(
EXHIBIT
2)
..............................................
15
TOTAL
ESTIMATED
RESPONDENT
BURDEN
AND
COST
SUMMARY
(
EXHIBIT
3)
..
17
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
TITLE
AND
NUMBER
OF
THE
INFORMATION
COLLECTION
This
ICR
is
entitled
RCRA
Hazardous
Waste
Permit
Application
and
Modification,
Part
A,
(
Renewal),
ICR
number
262.11.

1(
b)
SHORT
CHARACTERIZATION
The
Resource
Conservation
and
Recovery
Act
(
RCRA)
of
1976,
as
amended
by
the
Hazardous
and
Solid
Waste
Amendments
(
HSWA)
of
1984,
requires
EPA
to
establish
a
national
regulatory
program
to
insure
that
hazardous
wastes
are
managed
in
a
manner
protective
of
human
health
and
the
environment.
Specifically,
the
statute
requires
EPA
to
promulgate
regulations
that
establish
performance
standards
and
permitting
requirements
applicable
to
hazardous
waste
treatment,
storage,
and
disposal
facilities
(
TSDFs).
Section
3004
of
Subtitle
C
establishes
performance
standards
applicable
to
these
facilities.
Section
3005
requires
EPA
to
promulgate
regulations
requiring
these
facilities
to
obtain
a
permit.
In
the
event
permit
modifications
are
proposed
by
an
applicant
or
EPA,
modifications
must
conform
to
the
requirements
under
Sections
3004
and
3005.
The
regulations
implementing
these
requirements
are
codified
at
40
CFR
Part
270.

This
ICR
provides
a
comprehensive
discussion
of
the
requirements
for
owner/
operators
of
TSDFs
submitting
Part
A
Permit
Applications
or
Part
A
Permit
Modifications.
Four
types
of
facilities
are
subject
to
the
requirements
covered
in
this
ICR:
new
facilities
not
yet
constructed;
newly
regulated
existing
facilities
subject
to
RCRA
permitting
requirements
for
the
first
time;
permitted
facilities
with
newly
regulated
units;
and
interim
status
facilities.
The
information
collections
contained
in
this
ICR
are
divided
into
two
sections:
Contents
of
the
Part
A
Permit
Application;
and
Revised
Part
A
Permit
Applications,
Associated
Justifications
and
Compliance
Demonstrations.

Part
A
Permit
Application
40
CFR
Part
270
contains
requirements
for
submitting
and
modifying
a
Part
A
Permit
Application.
The
Part
A
Permit
Application
contains
the
general
information
required
in
§
270.13.
That
information
includes
names
and
addresses
of
the
owner
and
operator
of
the
facility
and
the
activities
conducted
at
the
facility
that
requires
a
RCRA
permit.
The
applicant
must
also
provide
information
on
the
location
of
the
facility,
including
a
map,
and
what
hazardous
wastes
are
being
managed
and
the
processes
involved
in
the
waste
management.
Section
270.11
specifies
the
signature
requirements
for
Part
A
Permit
Applications
and
reports.

Revised
Part
A
Permit
Applications
and
Associated
Justifications
and
Subpart
H
Compliance
Demonstrations
2
Section
270.72
identifies
the
types
of
changes
requiring
interim
status
facilities
or
owners/
operators
of
permitted
facilities
with
newly
regulated
units
to
submit
a
revised
Part
A
Permit
Application,
associated
justifications,
and
compliance
demonstrations.
The
changes
that
require
a
revised
Part
A
include
managing
wastes
not
listed
on
the
original
Part
A,
increasing
the
design
capacity
of
the
facility,
and
changing
the
processes
or
adding
new
units
for
treating,
storing,
or
disposing
of
the
waste.
In
all
cases,
the
owner
must
include
justification
for
the
change,
and
the
Director
must
approve
the
changes.
If
the
owner
or
operator
changes,
which
also
requires
a
revised
Part
A,
both
the
old
and
new
owner
or
operator
must
demonstrate
that
the
financial
responsibility
requirements
of
40
CFR
part
265,
subpart
H
will
continue
uninterrupted
during
the
change.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
NEED
AND
AUTHORITY
FOR
THE
COLLECTION
This
section
describes
the
need
and
authority
for
each
type
of
information
collection
analyzed
in
this
ICR.

Part
A
Permit
Application
EPA
promulgated
regulations
in
§
270.1
requiring
owners
or
operators
of
TSDFs
to
submit
a
Part
A
Permit
Application.
EPA
needs
information
contained
in
the
Part
A
Permit
Application
to
identify
the
person(
s)
legally
responsible
for
hazardous
waste
activity,
to
determine
which
facilities
require
permits
under
more
than
one
program,
to
assess
potential
for
the
facility
to
pollute
nearby
ground
and
surface
waters,
to
identify
the
time
frame
available
for
EPA
to
process
permit
applications,
and
to
define
the
specific
wastes
a
facility
is
legally
allowed
to
handle
for
different
purposes.

Revised
Part
A
Permit
Applications
and
Associated
Justifications
and
Subpart
H
Compliance
Demonstrations
EPA
promulgated
regulations
in
§
270.72
outlining
changes
that
require
owners
or
operators
to
submit
revised
Part
A
Permit
Applications.
Section
270.72(
a)(
1)­(
3)
require
owner/
operators
to
submit
both
a
revised
Part
A
Permit
Application
and
a
written
justification
for
changes
in
the
design
capacity
of
processes
used
at
the
facility,
and/
or
changes
or
additions
in
a
facility's
hazardous
waste
treatment,
storage,
or
disposal
processes.
Under
§
270.72(
a)(
4),
if
an
owner
or
operator
changes
ownership,
or
operational
control
of
a
facility,
the
new
owner
or
operator
is
required
to
submit
a
revised
Part
A
Permit
Application,
and
a
Subpart
H
compliance
demonstration.
EPA
needs
revised
permit
applications,
justifications,
and
compliance
demonstrations
to
determine
whether
desired
changes
are
acceptable
or
should
be
more
closely
reviewed
as
part
of
a
full
permit
issuance
process.

2(
b)
PRACTICAL
UTILITY
AND
USERS
OF
THE
DATA
3
Part
A
Permit
Application
EPA
uses
information
in
the
Part
A
Permit
Application
to
define
which
processes
can
be
used
and
which
wastes
can
be
handled
at
newly
regulated
facilities
subject
to
permitting
requirements
for
the
first
time
and
permitted
facilities
with
newly
regulated
units.
This
includes
defining
allowable
changes
in
facility
operations
and
applies
to
new
facilities
not
yet
constructed;
newly
regulated
facilities
subject
to
RCRA
permitting
requirements
for
the
first
time;
permitted
facilities
with
newly
regulated
units;
and
interim
status
facilities.
EPA
uses
information
in
the
Part
A
Permit
Application
to:

 
Set
priorities
for
processing
permit
applications;

 
Respond
to
requests
from
hazardous
waste
generators
for
the
names
and
locations
of
facilities
where
they
can
send
their
waste
for
storage,
treatment,
or
disposal;

 
Respond
to
public
and
Congressional
inquiries
regarding
particular
hazardous
waste
management
facilities;
and
 
Ensure
that
facilities
are
not
operating
in
a
manner
unprotective
of
human
health
and
the
environment.

Revised
Part
A
Permit
Applications
and
Associated
Justifications
and
Subpart
H
Compliance
Demonstrations
EPA
uses
this
information
to
determine
whether
desired
changes
are
acceptable
under
interim
status
or
whether
the
change
should
be
more
closely
reviewed
as
part
of
a
full
permit
issuance
process.
In
addition,
modifying
the
Part
A
Permit
Application
allows
inspectors
to
have
up­
to­
date
information
on
major
aspects
of
the
facility,
including
the
size
of
the
operation,
the
hazardous
wastes
handled,
and
the
types
of
processes
used.
Without
this
documentation,
EPA
would
be
unable
to
determine
the
owner
or
operator's
compliance
with
the
management
standards
of
40
CFR
Parts
264
or
265
or
the
rules
governing
changes
during
interim
status.
This
documentation
is
also
useful
for
both
EPA
and
the
owner
or
operator
in
an
enforcement
action.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
NONDUPLICATION
There
are
no
other
Federal
agencies
with
a
hazardous
waste
permit
program,
and
information
collected
from
a
RCRA
Part
A
Permit
Application
(
EPA
Form
8700­
23)
is
the
minimum
information
necessary
to
fulfill
the
statutory
requirements
of
RCRA
Section
3005.
Similarly,
the
information
requested
in
§
270.72
for
interim
status
facility
changes
is
not
available
from
other
data
sources.
Any
duplication
of
information
collection
requirements
between
a
Part
A
Permit
Application
and
the
RCRA
Section
3010
notification
(
EPA
Form
8700­
12)
is
necessary
for
4
proper
identification
of
the
facility
and
proper
form
management.
[
The
information
collection
requirements
associated
with
EPA
Form
8700­
12
are
addressed
in
the
"
Notification
of
Regulated
Waste
Activity
ICR,"
OMB
Control
Number
2050­
0028.]
Under
section
3006
of
RCRA,
EPA
began
in
fiscal
year
1982
to
authorize
States
to
carry
out
permitting
activities
in
lieu
of
the
Federal
program.
In
order
to
obtain
authorization,
the
States
must
agree
to
collect
the
same
information
as
EPA
collects.
Although
the
States
are
not
required
to
use
the
same
form
that
EPA
uses,
the
Agency
strongly
encourages
this
for
national
consistency.
Facilities
applying
for
a
permit
or
change
in
interim
status
in
an
authorized
State
are
required
to
file
only
with
the
State.

3(
b)
PUBLIC
NOTICE
EPA
issued
a
public
notice
in
the
Federal
Register
on
May
2,
2005
(
70
FR
22657).
The
public
comment
period
ended
on
July
1,
2005.
No
comments
were
received
in
response
to
the
notice.

3(
c)
CONSULTATIONS
The
burden
hours
and
cost
estimates
for
this
ICR
have
been
well
established,
and
were
verified
through
the
development
of
the
Information
Collection
Request
2005.01,
the
RCRA
subtitle
C
Site
Identification
Form,
January
5,
2001.
No
additional
consultations
were
made
for
this
ICR.

3(
d)
EFFECTS
OF
LESS
FREQUENT
COLLECTION
A
respondent's
provision
of
information
on
a
Part
A
Permit
Application
is
essentially
a
one­
time
exercise
that
must
occur
when
a
facility
is
new
or
if
an
existing
facility
becomes
subject
to
new
permitting
requirements.
Subsequent
revisions
to
the
Part
A
Permit
Application
are
necessary
only
if
an
interim
status
facility
changes
its
ownership
and/
or
process
or
management
of
wastes.
EPA
strongly
believes
that
if
the
minimum
requirements
specified
under
the
regulations
are
not
met,
neither
the
facilities
nor
EPA
can
ensure
that
hazardous
wastes
are
being
properly
managed,
and
do
not
pose
a
serious
threat
to
human
health
and
the
environment.

3(
e)
GENERAL
GUIDELINES
This
ICR
adheres
to
the
guidelines
stated
in
the
Paperwork
Reduction
Act
of
1995,
OMB's
implementing
regulations,
EPA's
Information
Collection
Review
Handbook,
and
other
applicable
OMB
guidance.
5
3(
f)
CONFIDENTIALITYAll
information
submitted
in
a
Part
A
Permit
Application
or
revision
will
be
subject
to
public
disclosure,
without
notice
to
the
facility,
in
accordance
with
the
Freedom
of
Information
Act,
5
U.
S.
C.
section
552,
and
EPA
Freedom
of
Information
Regulations,
40
CFR
Part
2.
Because
of
the
general
nature
of
the
information
requested,
only
a
few
Part
A
Permit
Applications
to
date
have
qualified
for
exemption
to
disclosure
under
the
business
confidentiality
exception.
Claims
of
confidentiality
must
be
clearly
indicated
on
the
forms
and
attachments,
and
must
be
accompanied,
at
the
time
of
filing,
by
a
written
substantiation
of
the
claim
in
accordance
with
40
CFR
Part
2,
Subpart
B
(
particularly
the
information
described
at
40
CFR
section
2.204(
e).)
Information
that
is
determined
to
be
confidential
is
placed
in
a
secured
"
confidential
file"
for
future
use.
Only
persons
with
special
clearance
for
confidential
information
have
access
to
these
files.

3(
g)
SENSITIVE
QUESTIONS
No
questions
of
a
sensitive
nature
are
included
in
these
information
collection
requirements.

4.
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
RESPONDENTS
AND
NAICS
CODES
The
following
is
a
list
of
NAICS
codes
associated
with
the
facilities
most
likely
to
be
affected
by
the
Part
A
Permit
Application
and
permit
modifications
under
this
ICR:

NAICS
Code
221121
Electric
Bulk
Power
Transmission
and
Control
221122
Electric
Power
Distribution
22132
Sewage
Treatment
Facilities
311942
Spice
and
Extract
Manufacturing
323114
Quick
Printing
32411
Petroleum
Refineries
325131
Inorganic
Dye
and
Pigment
Manufacturing
325199
All
Other
Basic
Organic
Chemical
Manufacturing
325211
Plastics
Material
and
Resin
Manufacturing
32551
Paint
and
Coating
Manufacturing
325998
All
Other
Miscellaneous
Chemical
Product
Manufacturing
331311
Alumina
Refining
33271
Machine
Shops
332813
Electroplating,
Plating,
Polishing,
Anodizing,
and
Coloring
332999
All
Other
Miscellaneous
Fabricated
Metal
Product
Manufacturing
333319
Other
Commercial
and
Service
Industry
Machinery
Manufacturing
6
333999
All
Other
General
Purpose
Machinery
Manufacturing
33422
Radio
and
Television
Broadcasting
and
Wireless
Communications
Equipment
Manufacturing
334418
Printed
Circuit/
Electronics
Assembly
Manufacturing
334419
Other
Electronic
Component
Manufacturing
336211
Motor
Vehicle
Body
Manufacturing
336312
Gasoline
Engine
and
Engine
Parts
Manufacturing
336322
Other
Motor
Vehicle
Electrical
and
Electronic
Equipment
Manufacturing
33633
Motor
Vehicle
Steering
and
Suspension
Components
(
except
Spring)
Manufacturing
33634
Motor
Vehicle
Brake
System
Manufacturing
33635
Motor
Vehicle
Transmission
and
Power
Train
Parts
Manufacturing
336399
All
Other
Motor
Vehicle
Part
Manufacturing
44111
New
Car
Dealers
44711
Gasoline
Stations
with
Convenience
Store
44719
Other
Gasoline
Stations
454312
Liquefied
Petroleum
Gas
(
Bottled
Gas)
Dealers
48411
General
Freight
Trucking,
Local
48421
Used
Household
and
Office
Goods
Moving
48422
Specialized
Freight
(
except
Used
Goods)
Trucking,
Local
562112
Hazardous
Waste
Collection
562211
Hazardous
Waste
Treatment
and
Disposal
562219
Other
Nonhazardous
Waste
Treatment
and
Disposal
56292
Materials
Recovery
Facilities
811111
General
Automotive
Repair
4(
b)
INFORMATION
REQUESTED
Part
A
Permit
Application
Contents
of
the
Part
A
Permit
Application
(
i)
Data
Items
40
CFR
270.1
requires
owners
or
operators
of
newly
regulated
facilities
subject
to
permitting
requirements
for
the
first
time
and
permitted
facilities
with
newly
regulated
units
to
prepare
and
submit
a
Part
A
Permit
Application.
Data
items
required
in
EPA
Form
8700­
23
are
outlined
in
§
270.13
and
include
the
following:

 
A
list
of
the
activities
conducted
by
the
applicant
that
require
the
owner
or
operator
to
obtain
a
RCRA
permit;
7
 
Name,
mailing
address,
and
location,
including
latitude
and
longitude
of
the
facility
for
which
the
application
is
submitted;

 
Up
to
four
NAICS
codes
that
best
reflect
the
principal
products
or
services
provided
by
the
facility;

 
Operator's
name,
address,
telephone
number,
ownership
status,
and
status
as
Federal,
State,
private,
public
or
other
entity;

 
Name,
address,
and
phone
number
of
the
owner
of
the
facility;

 
Whether
the
facility
is
located
on
Indian
lands;

 
An
indication
of
whether
the
facility
is
new
or
existing
and
whether
it
is
a
first
or
revised
application;

 
For
existing
facilities,
the
following
information:

­­
A
scale
drawing
of
the
facility
showing
the
location
of
all
past,
present,
and
future
treatment,
storage,
and
disposal
areas
and
­­
Photographs
of
the
facility
clearly
delineating
all
existing
structures;
existing
treatment,
storage
and
disposal
areas;
and
sites
of
future
treatment,
storage,
and
disposal
areas;

 
A
description
of
the
processes
to
be
used
for
treating,
storing,
and
disposing
of
hazardous
waste,
and
the
design
capacity
of
these
items;

 
A
specification
of
the
hazardous
wastes
listed
or
designated
under
40
CFR
Part
261
to
be
treated,
stored,
or
disposed
of
at
the
facility;
an
estimate
of
the
quantity
of
such
wastes
to
be
treated,
stored,
or
disposed
annually;
and
a
general
description
of
the
processes
to
be
used
for
such
wastes;

 
A
listing
of
all
permits
or
construction
approvals
received
or
applied
for
under
any
of
the
following
programs:

­­
Hazardous
Waste
Management
program
under
RCRA
­­
Underground
Injection
Control
(
UIC)
Program
under
the
Safe
Drinking
Water
Act
(
SDWA)
­­
National
Pollutant
Discharge
Elimination
System
(
NPDES)
program
under
the
Clean
Water
Act
(
CWA)
8
­­
Prevention
of
Significant
Deterioration
(
PSD)
program
under
the
Clean
Air
Act
(
CAA)
­­
Nonattainment
program
under
the
CAA
­­
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAPS)
preconstruction
approval
under
the
CAA
­­
Ocean
dumping
permits
under
the
Marine
Protection
Research
and
Sanctuaries
Act
­­
Dredge
or
fill
permits
under
section
404
of
the
CWA
­­
Other
relevant
environmental
permits,
including
State
permits.

 
A
topographic
map
(
or
other
map
if
a
topographic
map
is
unavailable)
extending
one
mile
beyond
the
property
boundaries
of
the
source,
depicting
the
following
aspects
of
the
facility:

­­
Each
of
its
intake
and
discharge
structures;
­­
Each
of
its
hazardous
waste
treatment,
storage,
or
disposal
facilities;
­­
Each
well
where
fluids
from
the
facility
are
injected
underground;
and
­­
Wells,
springs,
other
surface
water
bodies,
and
drinking
water
wells
listed
in
public
records
or
otherwise
known
to
the
applicant
within
1/
4
mile
of
the
facility
property
boundary.

 
A
brief
description
of
the
nature
of
the
business.

 
For
hazardous
debris,
a
description
of
the
debris
category(
ies)
and
containment
category(
ies)
to
be
treated,
stored,
or
disposed
of
at
the
facility.

(
ii)
Respondent
Activities
To
comply
with
§
270.1,
owners
or
operators
must
perform
the
following
activities:

 
Read
the
regulations
and
instructions;
and
 
Prepare
the
Part
A
Permit
Application
and
reports.

Signatories
to
Permit
Applications
and
Permit
Application
Reports
(
i)
Data
Items
 
§
270.11(
a)
specifies
signatures
required
on
Part
A
Permit
Applications.
Data
items
required
include:
9
­­
For
a
corporation,
the
signature
of
a
responsible
corporate
officer
as
defined
in
§
270.11(
a)(
1);
­­
For
a
partnership
or
sole
proprietorship,
the
signature
of
a
general
partner
or
proprietor
as
defined
in
§
270.11(
a)(
2);
and
­­
For
a
municipality,
State,
Federal,
or
other
public
agency,
the
signature
of
either
a
principal
executive
officer
or
ranking
elected
official
as
defined
in
§
270.11(
a)(
3).

 
§
270.11(
b)
requires
signatures
for
reports
required
by
permits
and
other
information
requested
by
the
Director.
Data
items
required
for
these
reports
include:

­­
For
a
corporation,
the
signature
of
a
responsible
corporate
officer
as
defined
in
§
270.11(
a)(
1);
­­
For
a
partnership
or
sole
proprietorship,
the
signature
of
a
general
partner
or
proprietor
as
defined
in
§
270.11(
a)(
2);
­­
For
a
municipality,
State,
Federal,
or
other
public
agency,
the
signature
of
either
a
principal
executive
officer
or
ranking
elected
official
as
defined
in
§
270.11(
a)(
3);
or
­­
Signature
of
a
duly
authorized
representative
of
one
of
the
persons
listed
above
as
defined
in
§
270.11(
b).

 
§
270.11(
c)
requires
an
owner
or
operator
to
submit
to
the
Director,
a
new
authorization
satisfying
the
requirements
of
§
270.11(
b)
if
an
authorization
under
§
270.11(
b)
is
no
longer
accurate
because
a
different
individual
or
position
has
responsibility
for
the
overall
operation
of
the
facility.
Data
items
for
this
requirement
are
the
same
as
those
under
§
270.11(
b).

 
§
270.11(
d)
requires
any
person
signing
a
document
under
§
270.11(
a)
or
(
b)
to
make
the
following
certification:

I
certify
under
penalty
of
law
that
this
document
and
all
attachments
were
prepared
under
my
direction
or
supervision
in
accordance
with
a
system
designed
to
assure
that
qualified
personnel
properly
gather
and
evaluate
the
information
submitted.
Based
on
my
inquiry
of
the
person
or
persons
who
manage
the
system,
or
those
persons
directly
responsible
for
gathering
the
information,
the
information
submitted
is
to
be
the
best
of
my
knowledge
and
belief,
true,
accurate,
and
complete.
I
am
aware
that
there
are
significant
penalties
for
submitting
false
information,
including
possibility
of
fine
and
imprisonment
for
knowing
violations.
10
(
ii)
Respondent
Activities
To
comply
with
§
270.11,
owners
or
operators
must
perform
the
following
activities:

 
Obtain
signatures
and
certifications
for
the
Part
A
Permit
Application,
reports,
and
other
information
requested
by
EPA;
and
 
Obtain
a
new
authorization
for
invalid
authorizations.

Submittal
of
Part
A
Permit
Application
(
i)
Data
Items
Section
270.70(
b)
requires
owners
and
operators
who
submit
a
Part
A
Permit
Application
to
EPA,
to
explain
or
cure
an
alleged
deficiency
in
the
Part
A
Permit
Application,
if
EPA
notifies
the
applicant
that
the
application
fails
to
meet
the
requirements
of
§
270.13.

(
ii)
Respondent
Activities
To
comply
with
§
§
270.11
and
270.70,
respondents
must
perform
the
following
activities:
 
Submit
the
Part
A
Permit
Application
and
reports;
and
 
Explain
or
cure
an
alleged
deficiency
in
the
Part
A
Permit
Application,
if
required.

Revised
Part
A
Permit
Applications
and
Associated
Justifications
and
Subpart
H
Compliance
Demonstrations
(
i)
Data
Items
Under
§
270.72,
interim
status
facilities
must
prepare
and
submit
a
revised
Part
A
Permit
Application
if
the
Agency
promulgates
a
rulemaking
that
affects
the
facility,
or
if
the
owner/
operator
otherwise
modifies
the
facility.
Interim
status
facilities
who
modify
their
Part
A
Permit
Application
are
required
to
submit
a
revised
Part
A
Permit
Application
containing
the
data
items
listed
in
the
data
item
section
for
EPA
Form
8700­
23.

(
ii)
Respondent
Activities
To
comply
with
§
270.72,
owners
or
operators
must
perform
the
following
activities:

 
Read
the
regulations
and
instructions
in
preparation
for
revising
a
Part
A
Permit
Application
in
response
to
an
Agency
rulemaking
or
a
facility
modification;

 
Prepare
and
submit
a
revised
Part
A
Permit
Application
in
response
to
an
Agency
11
rulemaking
or
facility
modification;

 
Prepare
and
submit
justifications
for
changes,
if
needed;
and
 
Submit
Subpart
H
compliance
demonstrations,
if
needed.

5.
THE
INFORMATION
COLLECTED
­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
AGENCY
ACTIVITIES
Part
A
Permit
Application
Agency
activities
associated
with
Part
A
Permit
Applications
include
reviewing
information
contained
in
the
application,
ensuring
that
the
Part
A
Permit
Application
and
associated
reports
are
signed
by
the
appropriate
person,
reviewing
newly
authorized
signatures
when
a
different
individual
or
position
gains
responsibility
for
the
overall
operation
of
a
facility,
reviewing
signature
certifications,
and
entering
information
into
the
RCRAInfo
database.
EPA
may
also
identify
deficiencies
in
the
Part
A
Permit
Application.

Revised
Part
A
Permit
Applications
and
Associated
Justifications
and
Subpart
H
Compliance
Demonstrations
Agency
activities
associated
with
revised
Part
A
Permit
Applications,
justifications,
and
compliance
demonstrations
include
reviewing
information
contained
in
each
of
these
items,
and
entering
revised
information
into
the
RCRAInfo
database.

5(
b)
COLLECTION
METHODOLOGY
AND
MANAGEMENT
EPA
keeps
records
of
and
reviews
all
of
the
information
submitted.
Authorized
States
and
EPA
Regions
enter
information
on
the
Part
A
forms
into
electronic
data
base
systems.
States
coordinate
with
the
EPA
Regions
and
OSW
Headquarters
to
supply
EPA
with
the
data
reported
for
inclusion
in
a
the
RCRAInfo
national
database.

5(
c)
SMALL
ENTITY
FLEXIBILITY
Interim
status
is
statutorily
conferred
without
regard
to
facility
size.
Therefore,
EPA
believes
that
requirements
regarding
Part
A
submissions
and
revisions
must
apply
equally
to
large
and
small
businesses.
Although
the
legal
requirements
for
Part
A
Permit
Application
information
are
the
same
for
large
and
small
businesses,
the
Agency
believes
that
in
practice
the
small
entities
will
find
it
easier
to
provide
the
required
information.
In
many
instances,
a
small
organization
will
be
able
to
complete
or
revise
the
Part
A
Permit
Application
in
less
time
than
larger
organizations
12
because
they
use
fewer
processes
for
the
management
of
hazardous
wastes
and
they
manage
fewer
types
of
wastes.
As
a
rule
of
thumb,
the
complexity
of
preparing
a
Part
A
Permit
Application
depends
upon
the
complexity
of
the
processes
of
a
hazardous
waste
facility
and
the
wastes
managed
at
the
facility.
Therefore,
if
a
small
organization
operates
a
complex
facility
(
e.
g.,
a
chemical
landfill
that
manages
a
very
large
number
of
waste
streams),
then
the
time
to
complete
the
Part
A
Permit
Application
will
necessarily
be
greater.
Again,
EPA
has
taken
steps
to
minimize
the
burden
on
all
respondents
by
providing
detailed
instructions
for
completion
of
the
Part
A
Permit
Application
form
and
by
requiring
short
answer
responses
to
most
of
the
items
of
the
application.

It
also
should
be
noted
that
the
reporting
requirements
for
changes
are
brief.
Therefore,
owners
or
operators
can
easily
comply
with
these
requirements.
In
addition,
most
of
the
revisions
to
Part
A
Permit
Applications
will
entail
merely
checking
boxes
or
filling
in
numbers
to
indicate
the
type
of
new
activity
or
new
waste
to
be
handled
at
the
facility.
Any
written
justification
entails
a
short
letter
from
the
owner
or
operator.
EPA,
therefore,
estimates
that
the
potential
burden
on
small
businesses
caused
by
this
information
collection
is
minimal.

5(
d)
COLLECTION
SCHEDULE
Part
A
Permit
Application
Owners
or
operators
of
new
hazardous
waste
management
facilities
that
are
not
yet
constructed
are
required
to
submit
their
Part
A
Permit
Application,
including
signatures
and
certifications
at
least
180
days
before
physical
construction
is
expected
to
commence.
For
existing
facilities
newly
subject
to
RCRA
permitting
requirements
due
to
promulgation
of
a
new
regulation
or
listing
of
hazardous
waste,
the
new
regulation
typically
specifies
the
date
by
which
Part
A
Permit
Applications,
including
signatures
and
certifications,
must
be
submitted.

Revised
Part
A
Permit
Applications
and
Associated
Justifications
and
Subpart
H
Compliance
Demonstrations
The
time
frame
in
which
owners
or
operators
must
submit
a
revised
Part
A
Permit
Application
varies
according
to
the
nature
of
changes
at
the
facility.
For
the
following
types
of
changes,
the
owner
or
operator
must
submit
revised
Part
A
Permit
Applications
and
justifications
prior
to
making
the
changes:

 
Treating,
storing,
or
disposing
of
hazardous
wastes
not
previously
identified
in
the
Part
A
Permit
Application;

 
Increasing
the
design
capacity
of
processes
used
at
the
facility;
and
13
 
Changing
or
adding
processes
for
treating,
storing,
or
disposing
of
hazardous
wastes.

For
changes
in
ownership
or
operational
control
of
a
facility,
the
new
owner
or
operator
must
submit
a
revised
Part
A
Permit
Application
no
later
than
90
days
prior
to
the
scheduled
change.
Subpart
H
compliance
demonstrations
must
be
submitted
within
six
months
of
the
date
of
the
change
in
ownership
or
operational
control
of
the
facility.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
COLLECTION
6(
a)
ESTIMATING
RESPONDENT
BURDEN
EPA's
estimated
respondent
burden
hours
and
costs
associated
with
all
of
the
requirements
covered
in
this
ICR
are
shown
in
Exhibit
1.
The
exhibit
includes
the
number
of
hours
required
to
conduct
the
information
collection
activity
and
the
cost
associated
with
each
requirement.
Some
totals
may
not
add
up
due
to
rounding
errors.
In
developing
burden
estimates
for
each
information
collection
requirement
in
the
ICR,
EPA
relied
on
the
results
of
consultations
with
members
of
the
regulated
community
from
previous
ICRS
for
this
activity,
including
consultations
from
the
January
5,
2001
Supporting
Statement
for
the
RCRA
Subtitle
C
Site
Identification
Form.

6(
b)
ESTIMATING
RESPONDENT
COSTS
In
Exhibit
1,
EPA
also
estimates
respondent
costs
associated
with
this
ICR.
In
the
following
paragraphs,
EPA
describes
the
data
and
assumptions
used
in
the
exhibit.

(
i)
Estimating
Labor
Costs
EPA
estimates
an
average
hourly
respondent
labor
cost
(
including
overhead)
of
$
116.00
for
legal
staff,
$
84.00
for
managerial
staff,
$
64.00
for
technical
staff,
and
$
36.00
for
clerical
staff.
To
arrive
at
these
estimates,
EPA
consulted
the
May
2004
Occupational
Employment
Statistics
(
OES)
Survey
from
the
Bureau
of
Labor
Statistics,
Department
of
Labor;
this
survey
summarizes
the
unloaded
(
base)
hourly
rate
for
various
labor
categories
in
U.
S.
firms.
EPA
then
applied
an
overhead
factor
of
2.3
for
non­
legal
staff
and
3.0
for
legal
staff
to
derive
their
loaded
hourly
rates.
Using
the
total
burden
hours
discussed
in
Section
6(
a)
and
the
wage
rates
outlined
in
this
section,
Exhibit
1
illustrates
the
labor
costs
associated
with
all
of
the
information
collection
requirements
covered
in
this
ICR.
14
(
ii)
Estimating
Capital
and
Operations
and
Maintenance
(
O&
M)
Costs
EPA
estimates
that
facilities
may
incur
annual
capital
and
operations
and
maintenance
costs
associated
with
specific
activities.
There
are
no
capital
costs
associated
with
completing
and
submitting
the
Part
A
Permit
Application.
For
submittal
of
information
or
notices,
EPA
estimates
that
facilities
will
incur
$
4.20
in
costs
each
year
for
the
three­
year
period
of
the
ICR.
This
estimate
is
based
on
the
mailing
cost
of
$
4.20
for
a
two­
pound
package.
There
are
no
costs
associated
with
the
purchase
of
a
service
included
in
the
O&
M
costs.

6(
c)
ESTIMATING
AGENCY
BURDEN
AND
COSTS
EPA
estimates
annual
Agency
burden
hours
and
costs
associated
with
all
of
the
requirements
covered
in
this
ICR
in
Exhibit
2.
Based
on
a
2002
GS
pay
schedule,
EPA
estimates
an
average
hourly
Regional
labor
cost
of
$
90.32
for
legal
staff,
$
79.70
for
managerial
staff,
$
57.33
for
technical
staff,
and
$
24.46
for
clerical
staff.
The
labor
costs
were
based
on
the
following
GS
levels
and
steps:
legal
labor
rates
were
based
on
GS
Level
15,
Step
5,
managerial
labor
rates
were
based
on
GS
Level
15,
Step
1,
technical
labor
rates
were
based
on
GS
Level
13,
Step
1,
and
clerical
labor
rates
were
based
on
GS
Level
6,
Step
1.
To
derive
hourly
estimates,
EPA
divided
annual
compensation
estimates
by
2,080,
which
is
the
number
of
hours
in
the
Federal
work­
year.
EPA
then
multiplied
hourly
rates
by
the
standard
government
overhead
factor
of
1.6.
As
shown
in
Exhibit
2,
EPA
estimates
the
total
annual
Agency
burden
to
be
approximately
95.1
hours,
at
an
annual
cost
of
$
4,971.34.
Some
totals
may
not
add
up
due
to
rounding
errors.
15
EXHIBIT
1
RCRA
HAZARDOUS
WASTE
PERMIT
APPLICATION
AND
MODIFICATION,
PART
A
(
RENEWAL)

ESTIMATED
ANNUAL
RESPONDENT
BURDEN
AND
COST
Hours
and
Costs
per
Respondent
Total
Hours
and
Costs
INFORMATION
COLLECTION
ACTIVITY
Legal
$
116.00/

hr.
Manager
$
84.00/
hr.
Technical
$
64.00/
hr.
Clerical
$
36.00/
hr.
Respons.

Hours/

Year
Labor
Cost/

Year
Capital/

Startup
Cost
O&
M
Cost
Number
of
Respond.
Total
Hours/

Year
Total
Cost/

Year
Part
A
Permit
Application
requirements
Read
the
regulations
and
instructions
2.00
1.00
3.00
0.00
6.00
$
508.00
$
0.00
$
0.00
8
48.00
$
4,046.08
Prepare
the
Part
A
Permit
Application
and
reports
1.33
2.75
8.00
1.40
13.50
$
947.68
$
0.00
$
4.20
8
108.00
$
7,615.04
Signatories
to
Permit
Applications
and
Permit
Application
Reports
Obtain
signatures
and
certifications
for
Part
A
permit
applications,
reports,
and
other
information
requested
by
EPA
0.00
0.50
1.00
1.00
2.50
$
142.00
$
0.00
$
0.00
8
20.00
$
1,136.00
Obtain
a
new
authorization
for
invalid
authorizations
0.00
0.50
1.00
0.50
2.00
$
124.00
$
0.00
$
0.00
1
2.00
$
124.00
Submittal
of
Part
A
Permit
Application
Submit
Part
A
Permit
Application
and
reports
0.00
0.50
1.00
1.50
3.00
$
160.00
$
0.00
$
4.20
8
24.00
$
1,313.60
Explain
or
cure
an
alleged
deficiency
in
Part
A
application,
if
required
0.00
0.50
2.00
1.00
3.50
$
206.00
$
0.00
$
0.00
1
3.50
$
206.00
Subtotal*
varies
varies
varies
varies
varies
varies
$
0.00
varies
varies
205.50
$
14,458.64
Revised
Part
A
Permit
Application/
Justifications/
Subpart
H
Compliance
Demonstrations
Read
the
regulations
and
instructions
(
for
Agency
rulemaking)
0.00
1.00
2.00
0.00
3.00
$
212.00
$
0.00
$
0.00
5
15.00
$
1,060.00
Read
the
regulations
and
instructions
(
for
facility
modification)
0.00
1.00
2.00
0.00
3.00
$
212.00
$
0.00
$
0.00
10
30.00
$
2,120.00
Prepare
and
submit
revised
Part
A
(
for
rulemaking)
1.75
1.40
1.78
1.82
6.75
$
500.04
$
0.00
$
4.20
5
33.75
$
2,521.20
Prepare
and
submit
revised
Part
A
(
for
facility
modification)
1.75
1.40
1.78
1.82
6.75
$
500.04
$
0.00
$
4.20
10
67.50
$
5,042.40
Prepare
and
submit
justifications
for
changes,
if
needed
1.00
1.00
2.00
1.00
5.00
$
364.00
$
0.00
$
4.20
5
25.00
$
1,841.00
Submit
Subpart
H
compliance
demonstrations,
if
needed
1.00
1.00
2.00
1.00
5.00
$
364.00
$
0.00
$
4.20
5
25.00
$
1,841.00
Subtotal*
varies
varies
varies
varies
varies
varies
$
0.00
varies
varies
196.25
$
14,425.60
TOTAL*
varies
varies
varies
varies
varies
varies
$
0.00
varies
varies
401.75
$
28,884.24
*
Some
totals
may
not
add
up
due
to
rounding
errors.
16
EXHIBIT
2
RCRA
HAZARDOUS
WASTE
PERMIT
APPLICATION
AND
MODIFICATION,
PART
A
(
RENEWAL)
ESTIMATED
ANNUAL
AGENCY
BURDEN
AND
COST
Hours
and
Costs
per
Respondent
Total
Hours
and
Costs
INFORMATION
COLLECTION
ACTIVITY
Legal
$
90.32/
hr.
Manager
$
79.70/
hr.
Technical
$
57.33/
hr.
Clerical
$
24.46/
hr.
Respons.

Hours/

Year
Labor
Cost/

Year
Capital/

Startup
Cost
O&
M
Cost
Number
of
Respond.
Total
Hours/

Year
Total
Cost/

Year
Part
A
Permit
Application
Review
Part
A
Permit
Applications
0.00
0.00
3.00
0.25
3.25
$
178.11
$
0.00
$
0.00
8
26.00
$
1,424.88
Enter
Part
A
Application
information
into
RCRAInfo
Data
Base
0.00
0.00
0.00
1.00
1.00
$
24.46
$
0.00
$
0.00
8
8.00
$
195.68
Notify
applicant
of
deficiency
in
Part
A
Application
0.00
0.00
0.50
0.10
0.60
$
31.12
$
0.00
$
0.00
1
0.60
$
31.12
Signatories
to
Permit
Applications
and
Permit
Application
Reports
Ensure
that
Part
A
Permit
Application
and
Reports
have
been
signed
by
appropriate
person
0.00
0.00
0.25
0.00
0.25
$
14.33
$
0.00
$
0.00
8
2.00
$
114.64
Review
newly
authorized
signatures
0.00
0.00
0.25
0.00
0.25
$
14.33
$
0.00
$
0.00
1
0.25
$
14.33
Review
signature
certifications
0.00
0.00
0.25
0.00
0.25
$
14.33
$
0.00
$
0.00
8
2.00
$
114.64
Subtotal*
varies
varies
varies
varies
varies
varies
$
0.00
$
0.00
varies
38.85
$
1895.29
Revised
Part
A
Permit
Application/
Justifications/
Subpart
H
Compliance
Demonstrations
Review
revised
Part
A
Permit
Application
0.00
0.00
2.00
0.25
2.25
$
120.78
$
0.00
$
0.00
15
33.75
$
1,811.70
Enter
revised
Part
A
Permit
Application
information
into
RCRAInfo
Data
Base
0.00
0.00
0.00
0.50
0.50
$
12.23
$
0.00
$
0.00
15
7.50
$
183.45
Review
justifications
for
changes
0.50
0.25
0.75
0.00
1.50
$
108.09
$
0.00
$
0.00
5
7.50
$
540.45
Review
Subpart
H
compliance
demonstrations
0.50
0.25
0.75
0.00
1.50
$
108.09
$
0.00
$
0.00
5
7.50
$
540.45
Subtotal*
varies
varies
varies
varies
varies
varies
$
0.00
$
0.00
varies
56.25
$
3,076.05
TOTAL*
varies
varies
varies
varies
varies
varies
$
0.00
$
0.00
varies
95.1
$
4,971.34
*
Some
totals
may
not
add
up
due
to
rounding
errors.
17
6(
d)
ESTIMATING
THE
RESPONDENT
UNIVERSE
AND
TOTAL
BURDEN
AND
COSTS
Respondent
Universe
Part
A
Permit
Application
EPA
estimates
that
approximately
8
facilities
will
be
required
to
submit
new
Part
A
Permit
Applications
annually
during
the
period
covered
by
this
ICR.
This
estimate
was
derived
from
averaging
the
number
of
new
Part
A
applications
received
in
years
2002,
2003
and
2004,
from
RCRAInfo
data.
All
8
facilities
will
be
required
to
obtain
signatures
for
the
Part
A
Permit
Application,
Part
A
Permit
Application
reports,
and
other
information
requested
by
the
Director.
In
addition,
all
8
facilities
will
be
required
to
obtain
certifications
from
persons
signing
permit
documentation.

EPA
estimates
that
10
percent
of
the
facilities
submitting
Part
A
Permit
Applications
will
have
authorizations
that
are
no
longer
accurate
because
a
different
individual
or
position
has
responsibility
for
the
overall
operation
of
the
facility.
Therefore,
approximately
1
facility
will
be
required
to
obtain
a
new
authorization.

Revised
Part
A
Permit
Applications
and
Associated
Justifications
and
Subpart
H
Compliance
Demonstrations
Similarly,
EPA
also
estimates
that
15
facilities
will
need
to
revise
their
Part
A
Permit
Application
annually
during
the
period
covered
in
this
ICR.
This
number
is
also
derived
from
averaging
data
from
2002,
2003,
and
2004.
Of
these,
EPA
expects
that
approximately
one­
third
(
5
facilities)
will
submit
a
revised
Part
A
Permit
Application
in
response
to
an
EPA
rulemaking,
and
two­
thirds
(
10
facilities)
will
submit
a
revised
Part
A
Permit
Application
for
a
facility
modification.
EPA
further
estimates
that
one­
third
of
facilities
submitting
revised
Part
A
Permit
Applications
(
5
facilities)
will
be
required
to
submit
justifications
due
to
either
changes
in
the
design
capacity
of
processes
used
at
the
facility
and/
or
changes
or
additions
in
a
facility's
hazardous
waste
treatment,
storage,
or
disposal
processes.
In
addition,
EPA
estimates
that
onethird
of
facilities
submitting
revised
Part
A
Permit
Applications
(
5
facilities)
will
be
required
to
submit
a
Subpart
H
compliance
demonstration
due
to
changes
in
ownership
or
operational
control
of
a
facility.
There
were
thus
23
Respondents
with
34
Responses.

Total
Burden
and
Costs
Using
the
total
burden
hours
estimated
in
the
above
section,
Exhibit
3
illustrates
the
respondent
costs
associated
with
all
of
the
information
collection
activities
covered
in
this
ICR.
As
shown
in
Exhibit
3,
EPA
estimates
that
the
total
annual
respondent
burden
for
all
activities
covered
in
this
ICR
is
approximately
401.75
hours
at
an
annual
cost
of
$
28,884.24.
18
EXHIBIT
3
RCRA
HAZARDOUS
WASTE
PERMIT
APPLICATION
AND
MODIFICATION,
PART
A
(
RENEWAL)

TOTAL
ESTIMATED
RESPONDENT
BURDEN
AND
COST
SUMMARY
Total
Hourly
Burden
Total
Annual
Capital
Costs
Total
Annual
O&
M
Costs
Total
Annual
Labor
Costs
Total
Annual
Costs
Part
A
Permit
Application
requirements
Read
the
regulations
and
instructions
48
$
0.00
$
0.00
$
4,064.00
$
4,064.00
Prepare
the
Part
A
Permit
Application
and
reports
108
$
0.00
$
33.60
$
7,581.44
$
7,615.04
Signatories
to
Permit
Applications
and
Permit
Application
Reports
Obtain
signatures
and
certifications
for
Part
A
permit
applications,
reports,

and
other
information
requested
by
EPA
20
$
0.00
$
0.00
$
1,136.00
$
1,136.00
Obtain
a
new
authorization
for
invalid
authorizations
2
$
0.00
$
0.00
$
124.00
$
124.00
Submittal
of
Part
A
Permit
Application
Submit
Part
A
Permit
Application
and
reports
24
$
0.00
$
33.60
$
1,280.00
$
1,313.60
Explain
or
cure
an
alleged
deficiency
in
Part
A
application,
if
required
3.5
$
0.00
$
0.00
$
206.00
$
206.00
Subtotal*
205.5
$
0.00
$
67.20
$
14,391.44
$
14,458.64
Revised
Part
A
Permit
Application/
Justifications/
Subpart
H
Compliance
Demonstrations
Read
the
regulations
and
instructions
(
for
Agency
rulemaking)
15
$
0.00
$
0.00
$
1,060.00
$
1,060.00
Read
the
regulations
and
instructions
(
for
facility
modification)
30
$
0.00
$
0.00
$
2,120.00
$
2,120.00
Prepare
and
submit
revised
Part
A
(
for
rulemaking)
33.75
$
0.00
$
21.00
$
2,500.02
$
2,521.20
Prepare
and
submit
revised
Part
A
(
for
facility
modification)
67.50
$
0.00
$
42.00
$
5,000.04
$
5,042.40
Prepare
and
submit
justifications
for
changes,
if
needed
25
$
0.00
$
21.00
$
1,820.00
$
1,841.00
Submit
Subpart
H
compliance
demonstrations,
if
needed
25
$
0.00
$
21.00
$
1,820.00
$
1,841.00
Subtotal*
196.25
$
0.00
$
105.00
$
14,320.24
$
14,425.60
TOTAL:
ALL
RESPONDENTS
401.75
$
0.00
$
172.20
$
28,711.68
$
28,884.24
*
Some
totals
may
not
add
up
due
to
rounding
errors.
19
6(
e)
BOTTOM
LINE
BURDEN
HOURS
AND
COSTS
Exhibits
1
and
2
show
the
average
annual
burden
and
cost
to
Respondents
and
the
Agency,
respectively.
The
bottom
line
burden
to
Respondents
over
three
years
is
1,205.25
hours,
with
a
cost
of
approximately
$
86,652.72
(
401.75
hours
annually,
at
a
cost
of
$
28,884
annually).
The
bottom
line
burden
to
the
Agency
over
three
years
is
285.3
hours,
at
a
cost
of
$
14,914.02
(
95.1
hours
annually,
at
a
cost
of
$
4,971
annually).

6(
f)
REASONS
FOR
CHANGE
IN
BURDEN
This
ICR
describes
the
total
respondent
burden
for
all
activities
required
for
the
Part
Permit
A
Permit
Application.
In
reviewing
burden
estimates
for
the
submitting
new
and
revising
existing
Part
A
Permit
Applications,
EPA
relied
on
the
estimates
from
the
previous
ICRs
for
this
activity,
and,
in
particular,
estimates
made
for
the
RCRA
Subtitle
C
Site
Identification
Form
ICR
(
number
2005.1),
January,
2001.
The
estimates
for
that
ICR
form
the
basis
for
some
of
the
estimated
burden
reduction
in
this
ICR.
The
major
reduction
is
from
a
decrease
in
the
number
of
revised
Part
A
Applications
since
the
previous
ICR.
Based
on
this
data,
EPA
has
lowered
its
estimate
of
the
overall
burden
associated
with
new
and
revised
Part
A
Permit
Applications.

The
purpose
of
the
Site
ID
Form
is
to
standardize
the
RCRA
site
identification
information
that
is
currently
collected
on
three
forms:
(
1)
Notification
of
Regulated
Waste
Activity
(
EPA
Form
8700­
12),
(
2)
RCRA
Part
A
Permit
Application
(
EPA
Form
8700­
23),
and
(
3)
Hazardous
Waste
Report
(
Biennial
Report;
EPA
Form
8700­
13
A/
B).
As
a
result
of
the
Site
ID
Form,
the
burden
and
cost
estimates
for
the
ICRs
for
all
three
activities
will
be
affected.
In
particular,
the
estimated
time
to
prepare
the
Part
A
Permit
Application
will
be
reduced
for
both
the
initial
and
revised
Part
A
applications.
For
new
applications,
we
assume
the
applicant
has
already
completed
a
Site
ID
Form
for
the
Notification
of
Regulated
Waste
Activity
Form.
For
submission
of
revised
Part
A
applications,
we
assume
the
applicant
has
already
completed
a
Site
ID
Form
for
the
Biennial
Report.

For
the
previous
ICR,
available
data
showed
an
annual
average
of
8
new
Part
A
Applications
and
28
revised
Part
A
Applications
for
the
years
1999,
2000,
and
2001.
For
this
ICR,
the
data
from
RCRAInfo
shows
an
average
8
new
and
15
revised
Part
A
Applications
for
the
years
2002,
2003,
and
2004.

As
such,
EPA
estimates
in
this
ICR
that
the
overall
annual
respondent
burden
associated
with
both
new
and
revised
Part
A
Permit
Applications
will
decrease
from
576
hours
in
the
previous
ICR
to
401.75
hours
in
this
ICR.
This
is
a
decrease
of
approximately
174.25
hours
or
approximately
30
percent.

6(
g)
BURDEN
STATEMENT
20
The
reporting
burden
for
information
collection
requirements
associated
with
the
Part
A
permit
application
requirements
is
estimated
to
be
approximately
25
hours.
The
burden
estimate
includes
time
for
reading
the
regulations
and
preparing
and
submitting
Part
A
Permit
Applications.
There
are
no
record
keeping
requirements
associated
with
new
Part
A
Permit
Applications,
and
as
such,
there
is
no
record
keeping
burden.

The
reporting
burden
for
information
collection
requirements
associated
with
revising
Part
A
Permit
Applications
is
estimated
to
be
approximately
13
hours.
The
burden
estimate
includes
time
for
reading
the
regulations,
preparing
and
submitting
revised
Part
A
Permit
Applications,
preparing
and
submitting
justifications
for
changes,
and
preparing
and
submitting
Subpart
H
compliance
demonstrations.
There
are
no
record
keeping
requirements
associated
with
revising
Part
A
Permit
Applications,
and
as
such,
there
is
no
record
keeping
burden.

Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.

An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
valid
OMB
Control
Number.
The
OMB
Control
Numbers
for
EPA's
regulations
are
listed
at
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
0008,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
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
Resource
Conservation
and
Recovery
(
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.
When
in
the
system,
select
"
search,"
then
key
in
the
Docket
ID
Number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Please
include
the
EPA
Docket
ID
Number
RCRA­
2005­
0008
and
OMB
Control
Number
2050­
0034
in
any
correspondence
