SUPPORTING
STATEMENT
FOR
EPA
INFORMATION
COLLECTION
REQUEST
#
1571.08
"
GENERAL
HAZARDOUS
WASTE
FACILITY
STANDARDS"

February
13,
2006
TABLE
OF
CONTENTS
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
and
Number
of
the
Information
Collection
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1
1(
b)
Characterization
of
the
Information
Collection
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1
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need
and
Authority
for
the
Collection
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4
2(
b)
Use
and
Users
of
the
Data
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9
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
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11
3(
b)
Consultations
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11
3(
c)
Public
Notice
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11
3(
d)
Effects
of
Less
Frequent
Collection
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11
3(
e)
General
Guidelines
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11
3(
f)
Confidentiality
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12
3(
g)
Sensitive
Questions
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12
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents/
NAICS
Codes
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12
4(
b)
Information
Requested
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13
5.
THE
INFORMATION
COLLECTED 
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
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56
5(
b)
Collection
Methodology
and
Management
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58
5(
c)
Small
Entity
Flexibility
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58
5(
d)
Collection
Schedule
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58
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
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62
6(
b)
Estimating
Respondent
Cost
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62
6(
c)
Estimating
Agency
Burden
and
Cost
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63
6(
d)
Respondent
Universe
and
Total
Respondent
Burden
and
Costs
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64
Exhibit
1
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67
Exhibit
2
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71
Exhibit
3
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73
Exhibit
4
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77
Exhibit
5
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78
Exhibit
6
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83
Exhibit
7
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87
Exhibit
8
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88
Exhibit
9
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89
Exhibit
10
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91
Exhibit
11
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91
6(
e)
Bottom
Line
Burden
Hours
and
Costs
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92
6(
f)
Reasons
for
Change
in
Burden
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92
1
6(
g)
Burden
Statement
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92
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
TITLE
AND
NUMBER
OF
THE
INFORMATION
COLLECTION
This
ICR
is
entitled
"
General
Hazardous
Waste
Facility
Standards
(
Renewal),"
ICR
#
1571.08
and
OMB
Control
#
2050­
0120.

1(
b)
CHARACTERIZATION
OF
THE
INFORMATION
COLLECTION
Section
3004
of
the
Resource
Conservation
and
Recovery
Act
(
RCRA),
as
amended,
requires
that
the
U.
S.
Environmental
Protection
Agency
(
EPA)
develop
standards
for
hazardous
waste
treatment,
storage
and
disposal
facilities
(
TSDFs)
as
may
be
necessary
to
protect
human
health
and
the
environment.
Subsections
3004(
a)(
1),
(
3),
(
4),
(
5)
and
(
6)
specify
that
these
standards
include,
but
not
be
limited
to,
the
following
requirements:

C
Maintaining
records
of
all
hazardous
wastes
identified
or
listed
under
Subtitle
C
that
are
treated,
stored,
or
disposed
of,
and
the
manner
in
which
such
wastes
were
treated,
stored,
or
disposed
of;

C
Operating
methods,
techniques,
and
practices
for
treatment,
storage,
or
disposal
of
hazardous
waste;

C
Location,
design,
and
construction
of
such
hazardous
waste
treatment,
disposal,
or
storage
facilities;

C
Contingency
plans
for
effective
action
to
minimize
unanticipated
damage
from
any
treatment,
storage,
or
disposal
of
any
such
hazardous
waste;
and
C
Maintaining
or
operating
such
facilities
and
requiring
such
additional
qualifications
as
to
ownership,
continuity
of
operation,
training
for
personnel,
and
financial
responsibility
as
may
be
necessary
or
desirable.

The
regulations
implementing
these
requirements
are
codified
in
the
Code
of
Federal
Regulations
(
CFR)
Title
40,
Parts
264
and
265.
A
brief
summary
of
the
information
collection
requirements
associated
with
each
TSDF
regulation
for
the
above
areas
is
provided
below.
A
more
specific
discussion
of
the
data
elements
and
respondent
activities
associated
with
each
of
the
information
collection
requirements
is
presented
in
Section
4.

GENERAL
FACILITY
OPERATING
REQUIREMENTS
EPA
promulgated
the
general
facility
standards
in
40
CFR
Parts
264
and
265,
Subpart
B.
In
order
to
comply
with
these
regulations,
owners
or
operators
of
TSDFs
must
collect,
record,
and
in
some
cases
report,
data
to
EPA.
Information
collection
requirements
associated
with
the
general
facility
standards
regulations
include:

C
Foreign
Shipment
Import
Report
(
§
264.12(
a)
and
§
265.12(
a));
2
C
Notice
of
Appropriate
Permits
(
§
264.12(
b));

C
Notice
of
Part
264
and
Part
270
Requirements
(
§
264.12(
c)
and
§
265.12(
b));

C
Waste
Analysis
(
§
264.13(
a)(
1)
and
§
265.13(
a)(
1));

C
Waste
Analysis
Plan
(
§
264.13(
b)
and
§
265.13(
b));

C
Inspection
Schedule
(
§
264.15(
d)
and
§
265.15(
d));

C
Personnel
Training
(
§
264.16(
d)
and
§
265.16(
d));

C
Documentation
of
Compliance
for
Ignitable,
Reactive,
or
Incompatible
Wastes
(
§
264.17(
c));
and
C
Construction
Quality
Assurance
Plan
(
§
265.19).

EPA
uses
the
general
facility
information
to
determine
whether
facilities
are
operating
in
a
manner
that
is
protective
of
human
health
and
the
environment.

RECORDKEEPING
REQUIREMENTS
In
40
CFR
264.73
and
265.73,
EPA
promulgated
regulations
directing
owners
or
operators
of
hazardous
waste
TSDFs
to
keep
written
operating
records
at
their
facilities.
Since
the
operating
record
is
not
submitted
to
EPA
but
must
be
available
for
inspection,
maintaining
an
operating
record
is
a
recordkeeping
activity.
The
operating
record
contains
information
regarding
general
operating
practices
conducted
at
the
facility.
Other
recordkeeping
requirements
under
40
CFR
Parts
264
and
265,
Subpart
E,
include
maintaining
copies
of
records
of
waste
disposal
locations
and
quantities
(
§
§
264.74(
c)
and
265.74(
c)).
In
addition,
40
CFR
264.37(
b)
requires
facilities
to
document
in
the
operating
record
any
refusal
of
State
or
local
authorities
to
enter
into
arrangements
for
emergency
situations.
Information
collected
pursuant
to
these
regulations
is
used
by
EPA
and
the
owner
or
operator
to
assure
safe
operation
of
the
facility.

CONTINGENCY
PLAN
AND
EMERGENCY
PROCEDURES
Contingency
plan
and
emergency
procedure
regulations
promulgated
in
40
CFR
264.51
through
264.54
and
264.56,
and
265.51
through
265.54
and
265.56,
require
permitted
and
interim
status
facilities
to
prepare
and
maintain
contingency
plans
and
comply
with
emergency
reporting
and
recordkeeping
requirements.
The
contingency
plan
describes
the
actions
facility
personnel
will
take
should
a
fire,
explosion,
or
any
unplanned
sudden
or
non­
sudden
release
of
hazardous
waste
constituents
to
air,
soil,
or
surface
water
occur.
Local
emergency
response
teams
use
the
information
required
in
the
contingency
plan
to
minimize
unanticipated
damage
from
the
treatment,
storage,
or
disposal
of
hazardous
waste.
The
contingency
plan
also
enables
EPA
to
assess
the
effectiveness
of
facility
responses
to
incidents
that
may
threaten
human
health
or
the
environment.

Other
emergency
reporting
and
recordkeeping
requirements
under
40
CFR
Parts
264
and
265,
Subpart
D,
include
notifying
State
and
local
authorities
of
an
imminent
or
actual
emergency
situation
3
(
264.56(
a)(
2)
and
265.56(
a)(
2)),
and
notifying
local
authorities
of
the
need
to
evacuate
local
areas
(
264.56(
d)(
1)
and
265.56(
d)(
1)).
If
a
release,
fire,
or
explosion
occurs,
the
owner
or
operator
must
notify
the
on­
scene
coordinator
or
the
National
Response
Center
(
264.56(
d)(
2)
and
265.56(
d)(
2)).
Owners
and
operators
also
must
notify
the
Regional
Administrator
that
a
facility
is
in
compliance
with
specific
regulations
before
operations
resume
in
any
area
affected
by
an
emergency
situation
(
§
§
264.56(
i)
and
265.56(
i)),
and
submit
a
report
to
the
Regional
Administrator
containing
details
of
any
emergency
situation
that
requires
implementation
of
the
contingency
plan
(
§
264.56(
j)
and
265.56(
j)).

RELEASES
FROM
SOLID
WASTE
MANAGEMENT
UNITS
In
40
CFR
Part
264,
Subpart
F,
EPA
promulgated
regulations
pertaining
to
releases
from
solid
waste
management
units.
Section
264.96(
c)
requires
owners
and
operators
to
prepare
and
submit
a
demonstration
for
termination
of
the
compliance
period
during
which
the
ground­
water
protection
standard
of
§
264.92
applies.
Under
40
CFR
264.97(
g),
owners
and
operators
must
propose
to
EPA
an
appropriate
sampling
procedure
and
interval
for
each
hazardous
constituent
listed
in
the
facility
permit.

CLOSURE
AND
POST­
CLOSURE
REQUIREMENTS
In
40
CFR
Parts
264
and
265,
Subpart
G,
EPA
promulgated
regulations
requiring
owners
or
operators
to
provide
for
the
proper
closure
of
hazardous
waste
management
(
HWM)
facilities,
and
for
proper
post­
closure
care
of
hazardous
waste
disposal
facilities.
Under
40
CFR
264.112,
265.112,
264.118,
and
265.118
owners
or
operators
are
required
to
maintain
closure
and
post­
closure
plans
at
the
facilities,
notify
EPA
and
amend
the
closure
and
post­
closure
plans
when
appropriate,
and
submit
these
plans
to
EPA
when
necessary.
Other
closure
and
post­
closure
requirements
under
Subpart
G
of
Part
264
and
265
include
requiring
owners
or
operators
to:

C
Demonstrate
that
they
can
comply
with
specific
regulations
if
requesting
an
extension
for
treatment,
storage,
or
removal
of
hazardous
waste
(
§
§
264.113(
a)
and
265.113(
a));
Demonstrate
that
they
can
comply
with
specific
regulations
if
requesting
an
extension
for
completing
closure
activities
under
an
approved
closure
plan
(
§
§
264.113(
b)
and
265.113(
b));
Demonstrate
that
they
can
comply
with
specific
regulations
if
requesting
an
allowance
to
receive
non­
hazardous
waste
after
the
final
receipt
of
hazardous
waste
(
§
§
264.113(
d)
and
265.113(
d));
Certify
that
a
facility
has
been
closed
in
accordance
with
the
approved
closure
and
post­
closure
plans
(
§
§
264.115,
265.115,
264.120,
and
265.120);
Submit
a
certified
survey
plat
(
§
§
264.116
and
265.116);
Submit
an
amended
post­
closure
plan,
if
necessary
(
§
265.118(
d)(
4));
Submit
a
modified
post­
closure
plan,
if
the
original
plan
is
not
approved
by
EPA
(
§
265.118(
f));
Submit
a
petition
to
extend
or
reduce
the
postclosure
period
(
§
265.118(
g)(
1));
and
C
Submit
a
record
of
the
type,
location,
and
quantity
of
hazardous
wastes
disposed
of
at
the
facility,
record
a
notation
on
the
property
deed
according
to
the
requirements
in
§
§
264.119(
b)(
1)
and
265.119(
b)(
1),
submit
certification
of
this
notation,
and
request
a
modification
to
the
post­
closure
permit,
if
necessary.
(
§
§
264.119
and
265.119).

EPA
uses
closure
and
post­
closure
plans
to
ensure
that
hazardous
waste
management
facilities
close
in
accordance
with
the
Congressional
mandate
of
protecting
human
health
and
the
environment.
EPA
reviews
closure
certifications
to
determine
whether
closure
took
place
in
accordance
with
the
approved
4
closure
plan
and
EPA,
local
authorities,
and
potential
purchasers
of
a
closed
facility
review
closure
notices
to
ensure
that
future
uses
of
the
site
will
not
lead
to
a
release
of
hazardous
waste.

FINANCIAL
REQUIREMENTS
In
40
CFR
Parts
264
and
265,
Subpart
H,
EPA
promulgated
regulations
requiring
owners
or
operators
to
establish
financial
assurance
mechanisms
for
closure,
post­
closure
care,
and
liability
for
thirdparty
bodily
injury
or
property
damage,
and
to
provide
EPA
with
evidence
of
such
established
financial
mechanisms.
Owners
or
operators
are
also
required
by
Subpart
H
to
provide
initial
cost
estimates
and
subsequent
updates
of
those
estimates
for
closure
and
post­
closure
care.
EPA
uses
these
financial
assurance
requirements
to
ensure,
in
the
case
of
closure
and
post­
closure
care,
that
hazardous
waste
management
facilities
have
the
financial
means
to
conduct
closure
or
post­
closure
care,
and
in
the
case
of
liability
requirements,
that
human
health
and
the
environment
are
protected
in
the
event
of
accidental
release
of
hazardous
constituents
from
the
facility.

CONDITIONS
APPLICABLE
TO
ALL
PERMITS
40
CFR
Part
270,
Subpart
C
specifies
conditions
applicable
to
all
RCRA
permits.
40
CFR
270.30(
h)
requires
owners
and
operators
of
permitted
facilities
to
furnish
any
relevant
information
requested
by
EPA
to
determine
whether
cause
exists
for
modifying,
revoking
and
reissuing,
or
terminating
a
permit,
or
to
determine
compliance
with
the
permit.
In
addition,
section
270.30(
l)
specifies
the
following
reporting
requirements,
which
are
applicable
to
all
permitted
facilities:

C
Notice
of
planned
physical
alterations
or
additions
(
270.30(
l)(
1));
Notice
of
planned
changes
or
activities
which
may
result
in
noncompliance
(
270.30(
l)(
2));
Letter
certifying
that
the
facility
has
been
constructed
or
modified
in
compliance
with
the
permit
(
270.30(
l)(
2)(
i));
Monitoring
reports
(
270.30(
l)(
4));
Reports
of
compliance
or
noncompliance
with
compliance
schedule
(
270.30(
l)(
5));
Information
concerning
a
release
that
may
threaten
drinking
water
(
270.30(
l)(
6)(
i)(
A));
Information
concerning
a
release,
fire,
or
explosion
that
could
threaten
human
health
or
the
environment
outside
of
the
facility
(
270.30(
l)(
6)(
i)(
B));
Notice
of
noncompliance
due
to
a
release,
fire,
or
explosion
(
270.30(
l)(
6)(
iii));
Report
of
other
noncompliance
(
270.30(
l)(
10));
and
C
Submittal
of
originally
omitted
or
corrected
information
(
270.30(
l)(
11)).

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.

GENERAL
FACILITY
OPERATING
REQUIREMENTS
(
1)
Foreign
Shipment
Import
Report
5
EPA
promulgated
regulations
in
§
§
264.12(
a)
and
265.12(
a)
requiring
owners
and
operators
of
hazardous
waste
facilities
that
have
arranged
to
receive
hazardous
wastes
from
foreign
sources
to
notify
the
Regional
Administrator
in
writing
at
least
four
weeks
prior
to
the
expected
date
of
arrival
of
the
shipments
at
the
facility.
EPA
uses
information
in
the
foreign
shipment
import
report
to
determine:
(
1)
whether
hazardous
wastes
will
be
transported
safely
to
the
United
States,
and
(
2)
whether
the
waste
will
be
managed
in
a
manner
that
is
protective
of
human
health
and
the
environment.
The
foreign
shipment
import
report
requirement
contributes
to
EPA's
goal
of
minimizing
detrimental
impacts
to
the
environment
resulting
from
the
unsafe
transportation
and
management
of
hazardous
waste.

(
2)
Notice
of
Appropriate
Permits
Section
264.12(
b)
requires
the
owner
or
operator
of
a
facility
receiving
off­
site
waste
to
send
a
one­
time
notice
to
the
generator
stating
that
he
or
she
has
the
appropriate
permits,
and
will
accept
the
waste
the
generator
is
shipping.
The
owner
or
operator
must
retain
a
copy
of
the
notice
at
the
facility.
The
notice
is
needed
to
ensure
that
waste
is
being
managed
properly.
EPA
may
examine
the
notices
during
inspections
to
ensure
that
the
notifications
are
being
transmitted.

(
3)
Notice
of
Part
264
or
265
and
Part
270
Requirements
Sections
264.12(
c)
and
265.12(
b)
require
owners
and
operators
transferring
ownership
of
a
facility
during
its
operating
life,
or
of
a
disposal
facility
during
the
post­
closure
care
period,
to
notify
the
new
owner
or
operator
in
writing
of
the
requirements
of
40
CFR
Parts
264
and
270.
This
information
is
needed
to
help
new
owners
and
operators
understand
applicable
regulations
and
facilitate
compliance.

(
4)
Waste
Analysis
EPA
promulgated
regulations
in
§
§
264.13(
a)(
1)
and
265.13(
a)(
1)
requiring
owners
or
operators
to
obtain
a
detailed
chemical
and
physical
analysis
of
a
representative
sample
of
the
waste
that
will
be
received.
EPA
and
the
owner
or
operator
use
information
obtained
in
the
waste
analysis
sample
to
determine:
1)
whether
a
facility
can
adequately
handle
incoming
waste,
and
2)
whether
the
waste
is
really
what
the
generator
claims
it
to
be.
The
owner
or
operator
also
uses
information
obtained
from
the
waste
analysis
to
determine
whether
there
are
any
potential
dangers
from
handling
the
waste.
The
waste
analysis
requirement
contributes
to
EPA's
goal
of
preventing
releases
or
reactions
of
hazardous
waste
on­
site.

(
5)
Waste
Analysis
Plan
Sections
264.13(
b)
and
265.13(
b)
state
that
the
owner
or
operator
of
a
hazardous
waste
facility
must
develop
and
follow
a
written
waste
analysis
plan
that
describes
the
procedures
to
be
used
in
obtaining
a
detailed
chemical
and
physical
analysis
of
the
waste.
EPA
uses
the
waste
analysis
plan
as
a
planning
tool
to
ensure
the
quality
of
information
obtained
from
the
waste
analysis
samples
required
in
264.13(
a)(
1)
and
265.13(
a)(
1).
6
(
6)
Inspection
Schedule
EPA
promulgated
regulations
in
§
§
264.15(
d)
and
265.15(
d)
requiring
the
owner
or
operator
of
a
facility
to
record
inspections
in
an
inspection
log
or
summary.
EPA
and
owners
and
operators
use
information
in
the
inspection
log
to
determine
whether
facility
equipment
is
safe
for
handling
hazardous
waste.
The
inspection
requirement
contributes
to
EPA's
goal
of
preventing
hazardous
waste
constituents
from
being
released
into
the
environment
due
to
faulty
or
deteriorated
equipment.

(
7)
Personnel
Training
Sections
264.16(
d)
and
265.16(
d)
require
owners
and
operators
to
maintain
copies
of
personnel
training
documents
and
records
at
their
facilities.
Both
EPA
and
owners
and
operators
use
information
in
personnel
training
records
to
determine
whether
employees
have
acquired
the
necessary
expertise
to
perform
their
jobs.
EPA
also
reviews
personnel
records
to
determine
whether
employees
are
receiving
a
level
of
training
that
is
commensurate
with
their
duties
and
responsibilities
as
well
as
their
ability
to
respond
to
any
emergency
situations
at
the
facility.
Requiring
owners
and
operators
to
maintain
personnel
training
documents
decreases
the
likelihood
that
employees
are
unqualified
to
handle
hazardous
waste
or
respond
to
emergencies.
The
personnel
recordkeeping
requirement
contributes
to
EPA's
goal
of
minimizing
the
potential
for
employee­
related
mistakes
that
may
threaten
human
health
and
the
environment.

(
8)
Documentation
of
Compliance
for
Ignitable,
Reactive
or
Incompatible
Wastes
Section
264.17(
c)
states
that
any
owner
or
operator
who
treats,
stores,
or
disposes
of
ignitable
or
reactive
wastes,
or
mixes
incompatible
wastes,
must
document
compliance
with
§
264.17(
a)
and
(
b),
which
require
certain
precautions
to
prevent
reactions.
EPA
uses
information
in
the
documentation
of
compliance
to
determine
whether
facilities
are
operating
in
a
manner
that
is
protective
of
human
health
and
the
environment.
The
documentation
requirement
contributes
to
EPA's
goal
of
minimizing
damage
from
the
treatment,
storage,
or
disposal
of
hazardous
waste.

(
9)
Construction
Quality
Assurance
Plan
Section
265.19(
b)
requires
each
owner
or
operator
of
a
surface
impoundment,
waste
pile,
or
landfill
to
develop
a
written
construction
quality
assurance
(
CQA)
plan
that
identifies
steps
that
will
be
used
to
monitor
and
document
the
quality
of
materials
and
the
condition
and
manner
of
their
installation.
The
CQA
plan
helps
to
ensure
proper
structural
stability
and
integrity
of
all
unit
components,
and
proper
construction
of
all
units.

RECORDKEEPING
REQUIREMENTS
EPA
promulgated
regulations
in
40
CFR
264.73
and
265.73
directing
owners
or
operators
of
hazardous
waste
treatment,
storage,
or
disposal
facilities
to
keep
a
written
operating
record
at
the
facility.
Other
recordkeeping
requirements
under
40
CFR
Parts
264
and
265,
Subpart
E,
include
submitting
copies
of
records
of
waste
disposal
locations
and
quantities
under
§
§
264.73(
b)(
2)
and
265.73(
b)(
2)
to
the
Regional
Administrator
and
local
land
authority
upon
closure
of
the
facility
(
§
§
264.74(
c)
and
265.74(
c)).
In
addition,
40
CFR
264.37(
b)
requires
facilities
to
document
in
the
operating
record
any
refusal
of
State
or
local
authorities
to
enter
into
arrangements
for
emergency
situations.
EPA
uses
information
collected
7
pursuant
to
these
regulations
to
select
appropriate
corrective
action
and
cleanup
measures
should
an
unanticipated
release
of
hazardous
waste
occur.
EPA
compliance
officials
refer
to
the
operating
record
to
determine
the
following:
1)
what
cleanup
measures
are
appropriate
and
2)
whether
operating
requirements
can
be
better
tailored
to
the
needs
of
a
particular
site.
EPA
anticipates
that
the
owner
or
operator
will
use
information
included
in
the
operating
record
to
prevent
receiving,
or
placing
in
proximity,
wastes
that
are
incompatible
with
other
wastes
that
are
likely
to
ignite
or
explode.
Requiring
facilities
to
develop
and
maintain
an
operating
record
and
conduct
the
recordkeeping
activities
contributes
to
EPA's
goal
of
minimizing
damage
to
the
environment
due
to
the
treatment,
storage,
or
disposal
of
hazardous
waste.

CONTINGENCY
PLAN
AND
EMERGENCY
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
Section
3004(
a)(
5)
of
RCRA,
as
amended,
requires
EPA
to
develop
standards
for
contingency
plans
for
effective
action
to
minimize
damage
from
any
treatment,
storage,
or
disposal
of
any
such
hazardous
waste.
EPA
codified
regulations
that
address
this
statutory
requirement
in
40
CFR
Parts
264
and
265.
40
CFR
§
§
264.51
through
264.54
and
264.56
and
265.51
through
265.54
and
265.56
require
all
owners
and
operators
of
hazardous
waste
facilities
to
prepare
and
maintain
contingency
plans,
and
to
notify
State
and
local
authorities
and
prepare
and
emergency
reports
whenever
an
imminent
or
actual
emergency
situation
occurs.
EPA
reviews
the
contingency
plan
and
emergency
reports
to
determine
whether
a
facility
has
developed
adequate
procedures
to
respond
to
unplanned
sudden
or
non­
sudden
releases
of
hazardous
waste
or
hazardous
constituents
to
air,
soil,
or
surface
water.
Notifications
to
State
and
local
authorities
facilitate
remedial
actions
and
evacuations,
if
necessary.
Requiring
facilities
to
develop
and
maintain
contingency
plans
and
prepare
emergency
response
reports
and
notifications
contributes
to
EPA's
goal
of
minimizing
damage
from
the
treatment,
storage,
or
disposal
of
hazardous
waste.

RELEASES
FROM
SOLID
WASTE
MANAGEMENT
UNITS
Under
40
CFR
264.96(
c),
EPA
requires
owners
and
operators
to
demonstrate
that
the
groundwater
protection
standard
has
not
been
exceeded
for
a
period
of
three
years
to
ensure
that
the
compliance
period
can
be
safely
terminated.
40
CFR
264.97(
g)
requires
owners
and
operators
to
prepare
and
submit
an
appropriate
sampling
procedure
and
interval
to
ensure
that
ground­
water
monitoring
is
being
performed
accurately
and
adequately.

CLOSURE
AND
POST­
CLOSURE
REQUIREMENTS
EPA
promulgated
regulations
in
40
CFR
Parts
264
and
265,
Subpart
G
(
§
§
264.112,
264.115,
264.116,
264.118­
120
and
265.112,
265.113,
265.115,
265.116,
and
265.118­
120),
that
require
owners
and
operators
to
develop
closure
and
post­
closure
plans,
amend
these
plans
when
appropriate,
and
submit
to
EPA
closure
certifications
and
post­
closure
notices.
EPA
reviews
information
in
the
closure
and
postclosure
plans
to
determine
whether
closure
and
post­
closure
activities
will
comply
with
the
regulatory
requirements.
EPA
uses
information
in
the
closure
certifications
to
determine
that
closure
took
place
in
accordance
with
the
approved
closure
plan.
EPA,
local
authorities,
and
potential
purchasers
of
a
closed
facility
review
information
included
in
the
post­
closure
notices
to
determine
what
future
uses
of
the
site
will
not
lead
to
a
release
of
hazardous
waste.

In
addition,
40
CFR
264.113
and
265.113
allow
owners
and
operators
to
apply
for
allowances
and
8
extensions
during
the
closure
period
by
preparing
and
submitting
demonstrations.
These
demonstrations
are
needed
to
ensure
that
any
activities
taking
place
during
closure
are
protective
of
human
health
and
the
environment.

Requiring
facilities
to
comply
with
these
regulations
contributes
to
EPA's
goal
of
ensuring
that
all
hazardous
waste
management
facilities
are
closed
in
a
manner
that
minimizes
the
need
for
post­
closure
maintenance,
and
controls,
minimizes,
or
eliminates
post­
closure
escape
of
waste,
leachate,
contaminated
rainfall,
or
waste
decomposition
products
to
ground
or
surface
waters
and
the
atmosphere
to
the
extent
necessary
to
protect
human
health
and
the
environment.

FINANCIAL
REQUIREMENTS
Section
3004(
a)(
6)
of
the
Resource
Conservation
and
Recovery
Act
of
1976
(
RCRA),
as
amended,
requires
EPA
to
promulgate
regulations
that
include
requirements
respecting
"
the
maintenance
of
operations
of
such
facilities
and
requiring
such
additional
qualifications
as
to
...
financial
responsibility
(
including
financial
responsibility
for
corrective
action)
as
may
be
necessary
or
desirable."

(
1)
Closure
and
Post­
Closure
Financial
Assurance
Requirements
The
need
for
financial
assurance
of
closure
and
post­
closure
care
is
indicated
by
the
numerous
instances
of
environmental
damage
resulting
from
abandonment
of
hazardous
waste
management
(
HWM)
facilities
and
other
failures
by
owners
and
operators
to
provide
adequately
for
closure
and
post­
closure
care.
The
likelihood
of
such
failure
is
increased
by
the
fact
that
the
costs
for
closure
and
post­
closure
care
are
expected
to
commence
when
the
economic
value
of
the
facility
is
either
at
a
minimum
or
nonexistent.
For
most
disposal
facilities,
post­
closure
care
will
extend
for
at
least
30
years
beyond
the
operating
life
of
the
facility.

EPA
believes
that
significant
numbers
of
owners
and
operators
would
lack
the
ability
to
provide
for
closure
and
post­
closure
care
without
effective
requirements
for
financial
assurance.
Consequently,
the
Agency
developed
40
CFR
Parts
264
and
265,
Subpart
H
financial
responsibility
requirements
for
closure
and
post­
closure
care.
(
The
requirements
in
Part
264,
Subpart
H,
are
identical
to
the
requirements
in
Part
265,
Subpart
H.
The
remainder
of
this
supporting
statement
will
use
the
reference
to
Subpart
H
as
referring
to
both
the
Part
264
and
Part
265
financial
responsibility
requirements.)

(
2)
Liability
Requirements
The
liability
requirements
are
designed
to
assure
that
funds
will
be
available
during
the
operating
life
of
a
facility
from
which
third
parties
can
seek
compensation
for
bodily
injury
and
property
damage
arising
from
the
operation
of
the
facility.
The
liability
requirements
are
necessary
for
several
reasons.
First,
the
requirements
provide
protection
to
human
health
and
the
environment
by
assuring
that
funds
are
available
to
owners
and
operators
to
compensate
for
damage
caused
by
accidents
at
hazardous
waste
facilities,
including
payments
for
bodily
injury
and
property
damage.
In
addition,
the
Agency
believes
that
without
liability
coverage
requirements,
there
would
be
less
public
confidence
in
and
greater
opposition
to
proposed
and
existing
hazardous
waste
facilities.
The
liability
requirements
also
result
in
other
potential
benefits
for
human
health
and
the
environment:
the
incentive,
in
the
form
of
lower
insurance
premiums,
to
improve
design
and
operation
of
the
facility,
and
the
oversight
that
insurers
provide
over
facility
operations.
9
CONDITIONS
APPLICABLE
TO
ALL
PERMITS
EPA
promulgated
conditions
applicable
to
all
permits
at
40
CFR
Part
270,
Subpart
C.
Information
collected
under
this
authority
is
needed
to
ensure
that
permittees
are
complying
with
permit
conditions,
and
to
determine
whether
cause
exists
for
modifying,
revoking
and
reissuing,
or
modifying
a
permit.

2(
b)
USE
AND
USERS
OF
THE
DATA
GENERAL
FACILITY
OPERATING
REQUIREMENTS
(
1)
Foreign
Shipment
Import
Report,
Notice
of
Appropriate
Permit(
s),
and
Notice
of
Part
264
and
Part
270
Requirements
EPA
uses
foreign
shipment
import
reports
to
determine
the
quantities
and
types
of
hazardous
wastes
being
imported
from
abroad.
Information
in
the
foreign
shipment
import
report
also
allows
EPA
to
determine
whether
hazardous
wastes
will
be
safely
transported
and
managed.

Generators
use
notices
of
appropriate
permits
to
ensure
that
their
waste
is
being
managed
by
a
permitted
facility.
Owners
and
operators
of
TSDFs
must
keep
the
notices
in
the
operating
record,
and
these
notices
may
be
reviewed
by
EPA
during
facility
inspections.

New
owners
and
operators
use
the
notice
of
Part
264
and
Part
270
requirements
to
improve
their
understanding
of
applicable
regulations.

(
2)
Waste
Analysis,
Waste
Analysis
Plan,
Inspection
Schedule,
and
Documentation
of
Compliance
The
waste
analysis
and
waste
analysis
plan,
as
well
as
the
inspection
schedule
and
documentation
of
compliance
for
ignitable
or
incompatible
wastes,
are
primarily
internal
recordkeeping
requirements
used
by
owners
and
operators
of
facilities
to
assure
that
they
can
adequately
handle
incoming
waste,
to
assure
that
the
incoming
waste
is
really
what
the
generator
claims
it
to
be,
and
to
prevent
undetected
releases
or
reactions
of
hazardous
waste
on­
site.
Much
of
the
information
in
the
waste
analysis
plan
will
also
be
used
to
provide
a
quality
assurance
check
on
both
the
generator
and
the
owners'
and
operators'
facilities.

(
3)
Personnel
Training
Both
EPA
and
owners
and
operators
use
information
in
the
personnel
training
records
to
ensure
that
personnel
acquire
the
necessary
expertise
to
perform
their
jobs.
During
inspections,
EPA
reviews
job
descriptions
and
training
documents
to
determine
whether
each
person
is
receiving
a
level
of
training
that
is
commensurate
with
the
person's
duties
and
responsibilities
as
well
as
the
ability
to
respond
to
any
emergency
situations
at
the
facility.

RECORDKEEPING
REQUIREMENTS
The
facility
owner
or
operator
uses
information
included
in
the
operating
record
and
waste
disposal
location
and
quantity
records
to
prevent
the
facility
from
receiving
or
placing
in
proximity
wastes
that
are
10
incompatible
or
that
are
likely
to
ignite
or
explode.
If
an
unanticipated
release
of
hazardous
waste
occurs,
the
owner
or
operator
may
review
information
in
the
operating
record
to
determine
the
composition
of
the
waste.
Reviewing
information
in
the
operating
record
facilitates
the
owner's
or
operator's
selection
of
an
appropriate
corrective
action
and
cleanup
measure.
By
providing
facility­
specific
data,
the
operating
record
also
enables
EPA
compliance
officials
to
determine
whether
operating
requirements
can
be
better
tailored
to
the
needs
of
a
particular
site.

CONTINGENCY
PLAN
AND
EMERGENCY
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
Local
emergency
response
teams,
certain
hazardous
waste
generators,
treatment,
storage,
and
disposal
facility
owners
or
operators,
and
EPA
use
information
included
in
the
contingency
plan
to
assure
an
appropriate
response
to
any
unplanned
release
of
hazardous
waste
or
hazardous
waste
constituents.
EPA
reviews
information
in
the
contingency
plan
and
emergency
report
to
determine
whether
additional
site­
specific
emergency
provisions
are
necessary.

RELEASES
FROM
SOLID
WASTE
MANAGEMENT
UNITS
EPA
uses
data
demonstrating
compliance
with
the
ground­
water
protection
standard
to
ensure
that
the
compliance
period
can
be
safely
terminated.
EPA
collects
and
reviews
proposed
sampling
procedures
and
intervals
to
ensure
that
facilities
are
taking
appropriate
steps
to
ensure
that
any
ground­
water
contamination
is
detected
rapidly
and
effectively.

CLOSURE
AND
POST­
CLOSURE
REQUIREMENTS
EPA
uses
information
contained
in
closure
and
post­
closure
plans
to
determine
whether
an
owner
or
operator's
planned
closure
and
post­
closure
activities
will
comply
with
environmental
regulations.
EPA
officials
use
information
contained
in
closure
certifications
to
ensure
that
the
owner
or
operator
closed
his/
her
facility
according
to
the
specifications
outlined
in
the
approved
closure
plan.
EPA
uses
information
contained
in
demonstrations
to
ensure
that
any
activities
taking
place
during
the
closure
period
are
protective
of
human
health
and
the
environment.
Local
authorities,
EPA,
and
potential
purchasers
of
a
closed
facility
review
information
included
in
post­
closure
notices
to
ensure
that
new
owners
or
operators
will
not
use
land
in
a
manner
that
will
lead
to
a
release
of
hazardous
waste
into
the
environment.

FINANCIAL
REQUIREMENTS
The
closure,
post­
closure
care,
and
liability
coverage
financial
instruments
submitted
by
the
owner
or
operator
are
reviewed
by
EPA
to
determine
compliance
with
the
applicable
Subpart
H
regulations.
This
review
involves
determinations
of
the
validity
of
the
instrument,
acceptability
of
the
financial
assurance
provider,
adequacy
of
the
instrument
amount,
and
fulfillment
of
the
other
regulatory
requirements.
The
information
is
also
used
to
direct
funds
for
closure,
post­
closure
care,
and
liability
coverage
in
the
event
of
default
or
bankruptcy
of
a
facility
owner
or
operator.

CONDITIONS
APPLICABLE
TO
ALL
PERMITS
EPA
uses
data
collected
from
permitted
facilities
to
evaluate
compliance
with
the
terms
of
the
permit
and
to
decide
whether
cause
exists
for
modifying,
revoking
and
reissuing,
or
terminating
the
permit.
11
By
collecting
this
information,
EPA
ensures
that
permitted
facilities
are
operating
in
a
manner
protective
of
human
health
and
the
environment.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
NONDUPLICATION
Most
of
the
information
required
by
the
regulation
is
not
available
from
any
source
but
the
respondents.
To
avoid
duplicating
previous
work,
EPA
is
allowing
respondents
to
draw
upon
similar
analyses
in
compiling
data
for
waste
analysis
and
testing
requirements,
provided
the
information
meets
the
requirements
specified
in
the
regulations.

3(
b)
CONSULTATIONS
The
burden
hours
and
cost
estimates
for
this
ICR
have
been
well
established,
and
no
additional
consultations
have
been
made.
Based
on
a
comment
received
for
the
1999
ICR,
we
solicited
comments
on
the
burden
of
doing
waste
analyses
in
the
Federal
Register
(
see
section
6(
d)(
4)).
No
comments
were
received
on
that
item,
so
the
burden
has
not
been
changed.

3(
c)
PUBLIC
NOTICE
In
compliance
with
the
Paperwork
Reduction
Act
of
1995,
EPA
issued
a
public
notice
in
the
Federal
Register
on
September
8,
2005
(
70
FR
53356),
and
provided
a
60
day
comment
period.
No
comments
were
received.

3(
d)
EFFECTS
OF
LESS
FREQUENT
COLLECTION
EPA
has
carefully
considered
the
burden
imposed
upon
the
regulated
community
by
the
general
facility
standards.
EPA
is
confident
that
those
activities
required
of
respondents
are
necessary,
and
to
the
extent
possible,
have
attempted
to
minimize
the
burden
imposed.
EPA
believes
strongly
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
In
general,
the
information
collection
requirements
covered
by
this
ICR
adhere
to
the
guidelines
stated
in
the
1995
Paperwork
Reduction
Act
as
amended,
OMB's
implementing
regulations,
EPA's
Information
Collection
Review
Handbook,
and
other
applicable
OMB
guidance.
However,
certain
general
facility
regulations
listed
below
require
TSDFs
to
retain
records
for
more
than
three
years.
As
explained
below,
EPA
believes
that
maintenance
of
these
records
for
longer
than
three
years
meets
substantial
needs
to
protect
human
health
and
the
environment
12
GENERAL
FACILITY
OPERATING
STANDARDS
(
1)
General
Inspection
Requirements
The
general
inspection
requirements
require
the
owner
or
operator
to
keep
inspection
records
at
the
facility
for
at
least
three
years
from
the
date
of
inspection.
Keeping
inspection
records
for
longer
than
three
years
may
be
advisable
to
keep
track
of
any
long
standing
violations
or
continued
areas
of
concern
regarding
potential
spills,
leaks
or
mismanagement
of
the
hazardous
wastes.

(
2)
Personnel
Training
Training
records
on
current
employees
must
be
kept
at
the
facility
until
closure
of
the
facility.
Records
of
former
employees
must
be
held
for
at
least
three
years
after
the
date
the
employee
left
the
facility.
Keeping
these
records
will
provide
documentation
of
preparations
made
for
handling
hazardous
waste,
and
allow
the
facility
to
keep
up
to
date
on
its
employee
training.

OPERATING
RECORD
Owners
or
operators
are
required
to
maintain
an
operating
record
at
the
facility
until
closure.
This
record
will
help
ensure
compliance
with
the
hazardous
waste
regulations,
and
make
it
easier
to
locate
the
cause
of
any
potential
hazardous
waste
leak
or
spill.

CLOSURE/
POST­
CLOSURE
PLANS
Owners
or
operators
are
required
to
keep
a
copy
of
the
closure
plan
at
the
facility
until
closure.
The
owner
or
operator
is
also
required
to
keep
the
certification
of
closure
at
the
facility
until
the
facility
is
released
from
financial
assurance
requirements
for
closure.
These
requirements
assure
that
the
facility
is
closing
in
accordance
with
the
regulations
at
the
least
possible
risk
to
human
health
and
the
environment.

3(
f)
CONFIDENTIALITY
Section
3007(
b)
of
RCRA
and
40
CFR
Part
2,
Subpart
B,
which
define
EPA's
general
policy
on
the
public
disclosure
of
information,
contain
provisions
for
confidentiality.
EPA
does
not
anticipate
requesting
any
confidential
information.

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)
RESPONDENTS/
NAICS
CODES
The
following
is
a
list
of
North
American
Industrial
Classification
System
(
NAICS)
codes
associated
with
industries
most
likely
affected
by
the
information
collection
requirements
covered
under
this
ICR.
13
323110
Commercial
Lithographic
Printing
323114
Quick
Printing
325131
Inorganic
Dye
and
Pigment
Manufacturing
325188
All
Other
Basic
Inorganic
Chemical
Manufacturing
325998
All
Other
Miscellaneous
Chemical
Product
Manufacturing
331311
Alumina
refining
325211
Plastics
Material
and
Resins
Manufacturing
32551
Paint
and
Coating
Manufacturing
32511
Petrochemical
Manufacturing
32512
Industrial
Gas
Manufacturing
325188
All
Other
Inorganic
Chemical
Manufacturing
325193
Ethyl
Alcohol
Manufacturing
325199
All
Other
Basic
Organic
Chemical
Manufacturing
325998
All
Other
Miscellaneous
Chemical
Product
Manufacturing
311942
Spice
and
Extract
Manufacturing
32411
Petroleum
Refineries
332813
Electroplating,
Plating,
Polishing,
Anodizing
and
Coloring
33271
Machine
Shops
332991
All
Other
Miscellaneous
Fabricated
Metal
Product
Manufacturing
333319
Other
Commercial
or
Service
Industry
Machinery
Manufacturing
Accessories
333999
All
Other
General
Purpose
Machinery
Manufacturing
336399
All
Other
Motor
Vehicle
Part
Manufacturing
334
Computer
and
Electronic
Product
Manufacturing
336
Transportation
Equipment
Manufacturing
48422
Specialized
Freight
(
except
Used
Goods)
Trucking,
Local
56211
Waste
Collection
22111
Electric
Power
Generation
22112
Fossil
Fuel
Electric
Power
Generation
22132
Sewage
Treatment
Facilities
56292
Materials
Recovery
Facilities
56221
Waste
Treatment
and
Disposal
42271
Petroleum
Bulk
Stations
and
Terminals
45431
Fuel
Dealers
4411
Automobile
Dealers
4471
Gasoline
Stations
811111
General
Automotive
Repair
4(
b)
INFORMATION
REQUESTED
The
following
subsections
summarize
the
data
items
and
respondent
activities
required
for
each
of
the
information
collection
requirements
discussed
in
this
ICR.
The
information
collection
requirements
are
divided
into
seven
categories:

C
General
facility
operating
requirements;

C
Recordkeeping
requirements;
14
C
Contingency
plan
and
emergency
reporting
and
recordkeeping
requirements;

C
Releases
from
solid
waste
management
units;

C
Closure
and
post­
closure
requirements;

C
Financial
requirements;

C
Corrective
action
management
unit
requirements;
and
C
Conditions
applicable
to
all
permits.

GENERAL
FACILITY
OPERATING
REQUIREMENTS
(
1)
Foreign
Shipment
Import
Report
(
i)
Data
items:

Sections
264.12(
a)
and
265.12(
a)
require
owners
or
operators
that
have
arranged
to
receive
hazardous
wastes
from
foreign
sources
to
notify
the
Regional
Administrator
in
writing
at
least
four
weeks
prior
to
the
expected
date
of
arrival
of
the
shipments
at
the
facility.
Data
items
that
should
be
included
in
this
notification
include:

C
Description
of
the
type
and
quantity
of
waste
to
be
received;

C
Date
shipment
is
expected
to
arrive;
and
C
Description
of
how
imported
waste
will
be
managed
at
the
facility.

(
ii)
Respondent
activities:

In
order
to
comply
with
the
foreign
shipment
report
requirements,
respondents
must
perform
the
following
activities:

C
Read
the
regulations;

C
Collect
data;
and
C
Prepare
and
submit
the
notification.
15
(
2)
Notice
of
Appropriate
Permits
(
i)
Data
item:

Section
264.12(
b)
requires
the
owner
or
operator
of
a
facility
that
receives
off­
site
waste
to
inform
the
generator
in
writing
that
he
or
she
has
the
appropriate
permits,
and
will
accept
the
waste
the
generator
is
shipping.
This
notice
must
be
sent
to
the
generator
before
receiving
the
first
shipment
of
waste.
The
owner
or
operator
must
retain
a
copy
of
the
notice
at
the
facility.

(
ii)
Respondent
activities:

In
order
to
comply
with
Section
264.12(
b),
respondents
must
perform
the
following
activities:

C
Read
the
regulations;

C
Prepare
and
submit
the
one­
time
notice;
and
C
Retain
a
copy
of
the
notice.

(
3)
Notice
of
Part
264
and
Part
270
Requirements
(
i)
Data
item:

Sections
264.12(
c)
and
265.12(
b)
require
owners
or
operators
transferring
ownership
of
a
facility
during
its
operating
life,
or
of
a
disposal
facility
during
the
post­
closure
care
period,
to
notify
the
new
owner
or
operator
in
writing
of
the
requirements
of
40
CFR
Part
264
or
265
and
Part
270.
This
notice
must
be
submitted
before
the
transfer
in
ownership.

(
ii)
Respondent
activities:

In
order
to
comply
with
sections
264.12(
c)
and
265.12(
b),
respondents
must
perform
the
following
activities:

C
Read
the
regulations;
and
C
Prepare
and
submit
the
notice.

(
4)
Waste
Analysis
(
i)
Data
items:

Sections
264.13(
a)(
1)
and
265.13(
a)(
1)
require
an
owner
or
operator
to
obtain
a
detailed
chemical
and
physical
analysis
of
any
hazardous
waste
he
or
she
intends
to
treat,
store,
or
dispose.
Sections
264.13(
a)(
2)
and
265.13(
a)(
2)
state
that
the
analysis
may
include
data,
either
existing
or
published,
developed
under
40
CFR
Part
261,
as
well
as
existing
data
on
the
hazardous
waste
or
hazardous
waste
generated
from
similar
processes.
16
(
ii)
Respondent
activities:

In
order
to
comply
with
sections
264.13(
a)(
1)
and
265.13(
a)(
1),
respondents
must
perform
the
following
activities:

C
Read
the
regulations;

C
Collect
data;
and
C
Perform
waste
analysis
(
sampling,
testing).

(
5)
Waste
Analysis
Plan
(
i)
Data
items:

Sections
264.13(
b)­(
c)
and
265.13(
b)­(
c)
state
that
an
owner
or
operator
of
a
hazardous
waste
facility
must
develop
and
follow
a
written
waste
analysis
plan
that
describes
the
procedures
to
be
used
in
obtaining
a
detailed
chemical
and
physical
analysis
of
the
waste.
The
owner
or
operator
is
required
to
keep
the
waste
analysis
plan
at
the
facility.
At
a
minimum,
the
plan
must
include
the
following
information:

C
Parameters
for
which
each
hazardous
waste
will
be
analyzed
and
the
rationale
for
the
selection
of
these
parameters;

C
Test
methods
used
to
test
for
the
parameters;

C
Sampling
method
used
to
obtain
a
representative
sample
of
the
waste
to
be
analyzed;

C
Frequency
with
which
the
initial
analysis
of
the
waste
will
be
reviewed
or
repeated
to
ensure
that
the
analysis
is
accurate
and
up
to
date;

C
For
off­
site
facilities,
the
waste
analyses
that
hazardous
waste
generators
have
agreed
to
supply;

C
Where
applicable,
the
methods
which
will
be
used
to
meet
additional
waste
analysis
requirements
for
specific
waste
management
methods
as
specified
in
§
§
264.17,
264.314,
264.341,
264.1034(
d),
264.1063(
d),
265.200,
265.225,
265.252,
265.273,
265.314,
265.341,
265.375,
265.402,
265.1034(
d),
265.1063(
d),
and
268.7;
For
surface
impoundments
exempted
from
land
disposal
restrictions
under
Section
268.4(
a)
procedures
and
schedules
for:

­­
The
sampling
of
impoundment
contents;

­­
The
analysis
of
test
data;

­­
The
annual
removal
of
residues
which
are
not
delisted
under
17
§
260.22
or
which
exhibit
a
characteristic
of
hazardous
waste
and
meet
the
requirements
specified
in
§
§
264.13(
b)(
7)(
iii)(
A),(
B),(
B)(
1)
or
(
B)(
2)
and
265.13(
b)(
7)(
iii)(
A),
(
B),
(
B)(
1),
or
(
B)(
2);
and
C
For
off­
site
facilities,
the
procedures
used
to
inspect
and
analyze
each
movement
of
hazardous
waste
received
at
the
facility,
as
required
under
§
§
264.13(
c)
and
265.13(
c),
including:

­­
Procedures
that
will
be
used
to
determine
the
identity
of
each
movement
of
waste
managed
at
the
facility;
and
­­
The
sampling
method
which
will
be
used
to
obtain
a
representative
sample
of
the
waste
to
be
identified,
if
the
identification
method
includes
sampling.

(
ii)
Respondent
activities:

Since
permitted
facilities
submit
the
waste
analysis
plan
with
the
Part
B
permit
application,
activities
associated
with
developing
and
modifying
the
waste
analysis
plan
are
discussed
in
the
Hazardous
Waste
Part
B
Permit
Applications,
Special
Permits,
and
Permit
Modifications
ICR
(#
1573).
However,
prior
to
submitting
a
permit
application,
an
interim
status
facility
must
prepare
a
waste
analysis
plan.
Therefore,
preparation
and
modification
of
waste
analysis
plans
for
interim
status
facilities
will
be
discussed
in
this
ICR
(#
1571).
In
addition
to
the
development
of
the
plan,
this
ICR
will
also
focus
on
activities
associated
with
the
recordkeeping
aspects
of
the
regulations
for
both
permitted
and
interim
status
facilities.

To
meet
the
recordkeeping
requirement
outlined
in
§
§
264.13(
b)
and
265.13(
b),
owners
or
operators
must
file
the
waste
analysis
plan
at
the
facility.
Activities
associated
with
developing
a
waste
analysis
plan
include:

C
Reading
the
regulations;

C
Collecting
the
data
required
in
the
waste
analysis
plan;

C
Writing
the
waste
analysis
plan;

C
Maintaining
the
plan
(
e.
g.,
photocopying
and
filing);
and
C
Modifying
the
waste
analysis
plan
(
for
new
and
existing
interim
status
facilities).

(
6)
Inspection
Schedule
(
i)
Data
items:

Sections
264.15(
b)(
1)
and
265.15(
b)(
1)
require
owners
and
operators
to
develop
and
follow
a
written
schedule
for
monitoring
equipment
that
is
important
in
preventing,
detecting,
or
responding
to
environmental
or
human
health
hazards.
At
a
minimum,
the
inspection
schedule
must
include
the
terms
and
18
frequencies
called
for
in
§
§
264.174,
264.194,
264.226,
264.253,
264.254,
264.303,
264.347,
264.602,
264.1033,
264.1052,
264.1053,
264.1058,
265.174,
265.193,
265.195,
265.226,
265.347,
265.377,
265.403,
265.1033,
265.1052,
265.1053,
and
265.1058
and
must
identify
the
types
of
problems
that
are
to
be
investigated
during
the
inspection.

Section
264.15(
d)
and
265.15(
d)
state
that
an
owner
or
operator
must
record
inspections
conducted
according
to
the
written
schedule
developed
pursuant
to
§
§
264.15(
b)(
1)
and
265.15(
b)(
1)
in
an
inspection
log
or
summary
that
is
to
be
maintained
at
the
facility.
The
inspection
log
or
summary
must
contain
the
following
data
items:

C
Date
and
time
of
inspection;

C
Name
of
inspector;

C
Notation
of
the
observations
made;
and
C
Date
and
nature
of
any
repairs
or
other
remedial
action.

(
ii)
Respondent
activities:

Since
permitted
facilities
submit
the
inspection
schedule
with
the
Part
B
permit
application,
activities
associated
with
developing
and
modifying
the
schedule
are
discussed
in
the
Hazardous
Waste
Part
B
Permit
Applications,
Special
Permits,
and
Permit
Modifications
ICR
(#
1573).
Prior
to
submitting
a
permit
application,
interim
status
facilities
must
prepare
an
inspection
schedule;
preparation
of
and
modification
to
the
inspection
schedule
for
these
facilities
will
be
discussed
in
this
ICR(#
1571).
This
ICR
will
also
focus
on
activities
associated
with
the
recordkeeping
aspects
of
the
regulations
for
both
permitted
and
interim
status
facilities.

To
meet
the
requirements
outlined
in
§
§
264.15(
d)
and
265.15(
d),
the
owner
or
operator
must
conduct
the
following
activities:

C
Read
the
regulations;

C
Develop
an
inspection
schedule
(
new
interim
status
facilities
only);

C
Maintain
and
modify
the
inspection
schedule
at
the
facility
(
new
and
existing
interim
facilities
only);
and
C
Record
problems
identified
during
inspections
in
the
inspection
log.

(
7)
Personnel
Training
(
i)
Data
items:

Sections
264.16(
d)
and
265.16(
d)
require
an
owner
or
operator
to
maintain
copies
of
personnel
training
documents
and
records
at
the
facility.
These
documents
should
include
the
following
data
items:
19
C
Job
title
for
each
position
at
the
facility
related
to
hazardous
waste
management,
and
the
name
of
the
employee
filling
each
job;

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

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

(
ii)
Respondent
activities:

Respondent
activities
associated
with
Sections
264.16(
d)
and
265.16(
d)
include:

C
Reading
the
regulations;

C
Collecting
the
data
items
listed
above;
and
C
Maintaining
(
e.
g.,
photocopying
and
filing)
the
information
at
the
facility.

(
8)
Documentation
of
Compliance
for
Ignitable,
Reactive,
or
Incompatible
Wastes
(
i)
Data
items:

Section
264.17(
c)
states
that
the
owner
or
operator
of
a
hazardous
waste
facility
must
take
precautions
to
prevent
accidental
ignition
or
reaction
of
ignitable
or
reactive
waste.
The
owner
or
operator
of
a
permitted
facility
must
document
compliance
with
the
requirements
outlined
in
§
§
264.17(
a)
and
(
b).
The
documentation
may
be
based
on
references
to
published
scientific
or
engineering
literature,
data
from
trial
tests
(
e.
g.,
bench
scale
or
pilot
scale
tests),
waste
analyses
(
as
specified
in
§
264.13),
or
the
results
of
the
treatment
of
similar
wastes
by
similar
treatment
processes
and
under
similar
operating
conditions.

(
ii)
Respondent
activities:

Respondent
activities
associated
with
Section
264.17(
c)
include:

C
Reading
the
regulations;

C
Collecting
and
documenting
the
data
items
mentioned
above;
and
C
Maintaining
(
e.
g.,
photocopying
and
filing)
documentation
at
the
facility.
20
(
9)
Construction
Quality
Assurance
Plan
(
i)
Data
items:

Section
265.19(
b)
requires
any
owner
or
operator
of
an
interim
status
surface
impoundment,
waste
pile,
or
landfill
to
develop
a
written
construction
quality
assurance
(
CQA)
plan
that
identifies
steps
that
will
be
used
to
monitor
and
document
the
quality
of
materials
and
the
condition
and
manner
of
their
installation.
[
Permitted
facilities
must
also
develop
a
CQA
plan
for
surface
impoundments,
waste
piles,
and
landfills.
Activities
associated
with
CQA
plans
at
permitted
facilities
are
burdened
in
the
Part
B
Permit
Application,
Permit
Modifications,
and
Special
Permits
ICR,
#
1573.]
The
CQA
plan
must
include
the
following
information:

C
Identification
of
applicable
units,
and
a
description
of
how
they
will
be
constructed;

C
Identification
of
key
personnel
in
the
development
and
implementation
of
the
CQA
plan,
and
CQA
officer
qualifications;

C
A
description
of
inspection
and
sampling
activities
for
all
unit
components,
including
observations
and
tests
that
will
be
used
before,
during,
and
after
construction
to
ensure
that
the
construction
materials
and
the
installed
unit
components
meet
design
specifications.
This
description
must
cover:

­
Sampling
size
and
locations;

­
Frequency
of
testing;

­
Data
evaluation
procedures;

­
Acceptance
and
rejection
criteria
for
construction
materials;

­
Plans
for
implementing
corrective
measures;
and
­
Data
or
other
information
to
be
recorded
and
retained
in
the
operating
record
under
§
265.73.

The
owner
or
operator
also
must
prepare
and
submit
a
certification
signed
by
the
CQA
officer
at
least
30
days
prior
to
receiving
waste
that
the
CQA
plan
has
been
successfully
carried
out
and
that
the
unit
meets
the
requirements
of
§
§
265.221(
a),
265.254,
or
265.301(
a).

(
ii)
Respondent
activities:

In
order
to
comply
with
Section
265.19,
owners
and
operators
must:

C
Read
the
regulations;

C
Prepare
the
CQA
plan;
21
C
Prepare
the
certification;

C
Submit
materials
to
EPA;
and
C
Maintain
records
of
the
materials.

RECORDKEEPING
REQUIREMENTS
(
1)
Operating
Record
Requirements
(
i)
Data
items:

Sections
264.73
and
265.73
outline
specific
operating
recordkeeping
requirements
that
are
imposed
on
TSDFs.
This
ICR
covers
the
requirements
found
at
§
264.73(
b)(
1)­(
16)
and
§
265.73(
b)(
1)­(
16),
which
state
that
the
operating
record
must
contain
the
following
data
items:

C
A
description
and
the
quantity
of
each
hazardous
waste
received,
and
the
method(
s)
and
date(
s)
of
its
treatment,
storage,
or
disposal
at
the
facility
as
required
by
Appendix
I;

C
The
location
of
each
hazardous
waste
within
the
facility
and
the
quantity
at
each
location.
For
disposal
facilities,
the
location
and
quantity
of
each
hazardous
waste
must
be
recorded
on
a
map
or
diagram
of
each
cell
or
disposal
area;

C
Records
and
results
of
waste
analyses
performed;

C
Summary
reports
and
details
of
all
incidents
that
require
implementing
the
contingency
plan;

C
Records
and
results
of
inspection
reports
(
which
must
be
kept
for
three
years);

C
Monitoring,
testing,
or
analytical
data
and
corrective
action
where
required;

C
Copies
of
written
notices
(
for
off­
site
facilities)
certifying
that
the
facility
is
permitted
and
will
accept
the
waste
the
generator
is
shipping;

C
Closure
cost
estimates
and,
for
disposal
facilities,
post­
closure
cost
estimates;

C
A
certification
by
the
permittee,
no
less
often
than
annually,
that
the
permittee
has
a
program
in
place
to
reduce
the
volume
and
toxicity
of
hazardous
waste
that
he
generates
to
the
degree
determined
by
the
permittee
to
be
economically
practicable;
and
the
proposed
method
of
treatment,
storage,
or
disposal
that
is
the
practicable
method
currently
available
to
the
permittee
which
minimizes
the
present
and
future
threat
to
human
health
and
the
environment;

C
Records
of
the
quantities
(
and
date
of
placement)
for
each
shipment
of
hazardous
waste
placed
in
land
disposal
units
under
an
extension
to
the
effective
date
of
any
land
disposal
restriction,
or
a
certification,
and
the
applicable
notice
required
by
a
generator;
22
C
Documents
stating
refusal
of
State
or
local
authorities
to
enter
into
arrangements
to
address
emergency
situations;

C
Records
of
hazardous
waste
application
dates
and
rates;
and
C
Maps
detailing
(
1)
the
exact
location,
dimensions,
and
depths
of
each
cell
with
respect
to
permanently
surveyed
benchmarks,
and
(
2)
the
contents
of
each
cell
and
the
approximate
location
of
each
hazardous
waste
type
within
each
cell.

(
ii)
Respondent
activities:

In
order
to
comply
with
sections
264.73
and
265.73,
264.37,
264.279
and
265.279,
and
264.309
and
265.309,
owners
or
operators
are
required
to
maintain
a
written
operating
record
at
the
facility.
Respondent
activities
associated
with
maintaining
an
operating
record
include
maintaining
(
e.
g.,
photocopying
and
filing)
the
data
items
listed
above.

(
2)
Other
Recordkeeping
and
Reporting
Requirements
Sections
264.74(
c)
and
265.74(
c)
require
owners
or
operators
to
submit
to
the
Regional
Administrator
and
local
land
authority
a
copy
of
the
records
of
waste
disposal
locations
and
quantities
under
§
§
264.73(
b)(
2)
and
265.73(
b)(
2)
upon
closure
of
the
facility.
Since
this
information
is
submitted
upon
closure
of
the
facility,
data
items
and
respondent
activities
are
included
in
the
closure/
post­
closure
section.

CONTINGENCY
PLAN
AND
EMERGENCY
REPORTING
REQUIREMENTS
(
1)
Contingency
Plan
Requirements
(
i)
Data
items:

Sections
264.51
and
265.51
require
owners
or
operators
to
have
a
contingency
plan
for
their
facilities
and
sections
264.53(
a)
and
265.53(
a)
require
the
owner
or
operator
to
maintain
a
copy
of
an
updated
contingency
plan
at
the
facility.
Sections
264.52
and
265.52
outline
the
data
elements
that
should
be
included
in
this
plan:

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

C
An
updated
list
of
the
names,
addresses,
and
phone
numbers
(
office
and
home)
of
all
persons
qualified
to
act
as
emergency
coordinators;

C
An
updated
list
of
all
emergency
equipment
at
the
facility
and
the
location,
physical
description,
and
capabilities
of
the
emergency
equipment.
The
contingency
plan
should
also
indicate
where
the
emergency
equipment
will
be
required;
and
23
C
An
evacuation
plan
for
facility
personnel
where
there
is
a
possibility
that
evacuation
may
be
necessary.

In
addition,
sections
264.53(
b)
and
265.53(
b)
require
owner/
operators
to
submit
a
copy
of
the
contingency
plan
and
all
revisions
to
all
local
police
departments,
fire
departments,
hospitals,
and
State
and
local
emergency
response
teams
that
may
be
called
upon
to
provide
emergency
services.

(
ii)
Respondent
activities:

Since
permitted
facilities
submit
the
contingency
plan
with
the
Part
B
permit
application,
activities
associated
with
developing
and
modifying
the
contingency
plan
are
discussed
in
the
Hazardous
Waste
Part
B
Permit
Applications,
Special
Permits,
and
Permit
Modifications
ICR
(#
1573).
Interim
status
facilities
must
prepare
contingency
plans
prior
to
submitting
a
permit
application;
therefore,
preparation
of
the
contingency
plan
for
these
facilities
is
covered
under
this
ICR
(#
1571).
This
ICR
also
includes
submittal
of
the
plan
to
State
and
local
authorities
and
recordkeeping
activities
for
both
permitted
and
interim
status
facilities.

In
order
to
comply
with
contingency
plan
requirements,
owners
or
operators
are
required
to
perform
the
following
activities:

C
Read
the
regulations;

C
Collect
the
data
required
in
the
contingency
plan;

C
Write
the
contingency
plan
(
new
interim
status
facilities
only);

C
Submit
the
contingency
plan
to
State
and
local
authorities;

C
Maintain
(
e.
g.,
photocopy
and
file)
the
contingency
plan;
and
C
Amend
the
contingency
plan
when
appropriate.

[
Although
permitted
and
interim­
status
facilities
must
comply
with
appropriate
requirements
for
amending
a
contingency
plan,
this
ICR
addresses
only
interim
status
facilities
amending
their
plans.
As
mentioned,
permitted
facilities
amending
their
plans
must
comply
with
sections
264.54
and
submit
a
permit
modification
under
section
270.42.
These
permitted
facilities
are
addressed
in
the
Hazardous
Waste
Part
B
Permit
Applications,
Special
Permits,
and
Permit
Modifications,
ICR
#
1573].

(
2)
Emergency
Reporting
and
Recordkeeping
Requirements
(
i)
Data
items:

Sections
264.56(
a)(
2)
and
265.56(
a)(
2)
require
owners
and
operators
to
immediately
notify
State
and
local
authorities
with
designated
response
roles
of
an
imminent
or
actual
emergency
situation.
Sections
264.56(
d)(
1)
and
265.56(
d)(
1)
require
owners
and
operators
to
notify
local
authorities
if
his
or
her
assessment
of
a
release,
fire,
or
explosion
indicates
that
evacuation
of
local
areas
may
be
advisable.
24
Sections
264.56(
d)(
2)
and
265.56(
d)(
2)
require
the
facility
emergency
coordinator
to
notify
the
onscene
coordinator
or
the
National
Response
Center
of
any
release,
fire,
or
explosion
that
could
threaten
human
health
or
the
environment
outside
the
facility.
The
emergency
notification
report
must
include
the
following
information:

C
Name
and
telephone
number
of
reporter;

C
Name
and
address
of
facility;

C
Time
and
type
of
incident;

C
Name
and
quantity
of
material(
s)
involved;

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

Sections
264.56(
i)
and
265.56(
i)
state
that
the
owner
or
operator
should
notify
the
Regional
Administrator
and
appropriate
State
and
local
authorities
that
their
facility
is
in
compliance
with
§
§
264.56(
h)
and
265.56(
h)
before
resuming
operations
in
the
affected
area(
s)
of
the
facility.

Within
15
days
of
the
incident,
owners
and
operators
are
required,
under
Sections
264.56(
j)
and
265.56(
j)
to
submit
a
written
report
("
owner/
operator
emergency
report")
on
the
incident
to
the
Regional
Administrator.
The
report
must
include
the
following
data
items:

C
Name,
address,
and
telephone
number
of
the
owner
or
operator;

C
Name,
address,
and
telephone
number
of
the
facility;

C
Date,
time,
and
type
of
incident;

C
Name
and
quantity
of
material(
s)
involved;

C
The
extent
of
injuries;

C
An
assessment
of
actual
or
potential
hazards
to
human
health
or
the
environment;
and
C
Estimated
quantity
and
disposition
of
recovered
material
that
resulted
from
the
incident.

(
ii)
Respondent
activities:

In
order
to
comply
with
the
reporting
requirements
of
§
264.56(
a)(
2)
and
§
265.56(
a)(
2),
owners
and
operators
must
perform
the
following
activities:

C
Submit
the
required
notification
of
an
imminent
or
actual
emergency
situation
to
State
and/
or
local
authorities.
25
In
order
to
comply
with
the
reporting
requirements
of
§
264.56(
d)(
1)
and
§
265.56(
d)(
1),
owners
and
operators
must
perform
the
following
activities:

C
Notify
local
authorities
of
the
owner
or
operator's
recommendation
to
evacuate
local
areas.

In
order
to
comply
with
the
reporting
requirements
of
§
264.56(
d)(
2)
and
§
265.56(
d)(
2),
owners
and
operators
must
perform
the
following
activities:

C
Notify
the
on­
scene
coordinator
or
the
National
Response
Center
of
any
release.

In
order
to
prepare
an
emergency
report
under
§
264.56(
d)(
2)
and
§
265.56(
d)(
2),
emergency
coordinators
must
conduct
the
following
activities:

C
Collect
the
information
required
in
the
emergency
report;
and
C
Write
the
emergency
notification
report.

In
order
to
prepare
an
owner/
operator's
emergency
report
under
§
264.56(
j)
and
§
265.56(
j),
owners
and
operators
must
conduct
the
following
activities:

C
Read
the
regulations;

C
Collect
the
information
required
in
the
emergency
report;
and
C
Prepare
and
submit
the
emergency
report.

In
addition
to
preparing
an
emergency
report,
the
owner
or
operator
must
notify
the
Regional
Administrator
that
the
facility
is
in
compliance
with
§
§
264.56(
h)
and
265.56(
h)
before
resuming
operations
in
affected
areas
of
the
facility.
In
order
to
comply
with
this
requirement,
respondents
must
conduct
the
following
activities:

C
Compile
information
that
demonstrates
that
all
affected
areas
are
in
compliance;
and
C
Prepare
and
submit
a
letter
notifying
the
Regional
Administrator
of
this
compliance.

Sections
264.56
and
265.56
require
the
owner/
operator
to
note
in
the
operating
record
the
time,
date,
and
details
of
any
incident
that
requires
implementing
the
contingency
plan
(
§
§
264.56(
j)
and
265.56(
j)).
Respondent
activities
associated
with
this
requirement
are
burdened
in
the
respondent
activity
section
for
the
operating
record
requirements.
26
RELEASES
FROM
SOLID
WASTE
MANAGEMENT
UNITS
(
1)
Termination
of
Compliance
Period
(
i)
Data
item:

Section
264.96(
c)
extends
the
compliance
period
for
facilities
that
are
engaged
in
corrective
action.
Owners
and
operators
of
these
facilities
must
demonstrate,
with
monitoring
data,
that
the
ground­
water
protection
standard
of
§
264.92
has
not
been
exceeded
for
a
period
of
three
consecutive
years
to
complete
the
compliance
period.

(
ii)
Respondent
activities:

In
order
the
comply
with
section
264.96(
c),
owners
and
operators
must
perform
the
following
activities:

C
Read
the
regulations;
and
C
Prepare
the
monitoring
data
and
submit
it
to
EPA.

(
2)
Sampling
Procedures
and
Intervals
(
i)
Data
items:

Section
264.97(
g)
requires
owners
and
operators
conducting
detection
monitoring
and
compliance
monitoring
to
determine
an
appropriate
sampling
procedure
and
interval
for
each
hazardous
constituent
listed
in
the
facility
permit.
The
sampling
procedure
must
include:

C
A
sequence
of
at
least
four
samples,
taken
at
an
interval
that
assures,
to
the
greatest
extent
technically
possible,
that
an
independent
sample
is
obtained,
by
reference
to
the
uppermost
aquifer's
effective
porosity,
hydraulic
conductivity,
and
hydraulic
gradient,
and
the
fate
and
transport
characteristics
of
the
potential
contaminants;
or
C
An
alternative
sampling
procedure
proposed
by
the
owner
or
operators
and
approved
by
EPA.

(
ii)
Respondent
activities:

In
order
to
comply
with
section
264.97(
g),
owners
and
operators
must
perform
the
following
activities:

C
Read
the
regulations;
and
C
Develop
an
appropriate
sampling
procedure
and
interval,
and
submit
this
information
to
EPA
for
approval.
27
CLOSURE
AND
POST­
CLOSURE
REQUIREMENTS
(
1)
Closure
Plan
(
i)
Data
items:

Sections
264.112(
a)
and
265.112(
a)
state
that
an
owner
or
operator
must
have
a
written
closure
plan.
The
closure
plan
must
include
the
following
data
items:

C
A
description
of
how
each
hazardous
waste
management
unit
at
the
facility
will
be
closed
in
accordance
with
§
§
264.111
and
265.111;

C
A
description
of
how
final
closure
of
the
facility
will
be
conducted
in
accordance
with
§
§
264.111
and
265.111.
The
description
must
identify
the
maximum
extent
of
operations
which
will
be
unclosed
during
the
active
life
of
the
facility;

C
An
estimate
of
the
maximum
inventory
of
hazardous
wastes
ever
on­
site
over
the
active
life
of
the
facility.
This
should
include
a
detailed
description
of
the
methods
to
be
used
during
partial
closures
and
final
closure
such
as
methods
for
removing,
transporting,
treating,
storing,
or
disposing
of
all
hazardous
wastes,
and
identification
of
the
type(
s)
of
off­
site
hazardous
waste
management
units
to
be
used,
if
applicable;

C
A
detailed
description
of
the
steps
needed
to
remove
or
decontaminate
all
hazardous
waste
residues
and
contaminated
containment
system
components,
equipment,
structures,
and
soils
during
partial
and
final
closure;

C
A
detailed
description
of
other
activities
necessary
during
the
closure
period
to
ensure
that
all
partial
closures
and
final
closure
satisfy
the
closure
performance
standards,
including
ground­
water
monitoring,
leachate
collection,
and
run­
on
and
run­
off
control;

C
A
schedule
for
closure
of
each
hazardous
waste
management
unit
and
for
final
closure
of
the
facility.
The
schedule
must
include,
at
a
minimum:

­­
The
total
time
required
to
close
each
hazardous
waste
management
unit;
and
­­
The
time
required
for
intervening
closure
activities
which
will
allow
tracking
of
the
progress
of
partial
and
final
closure;
and
C
For
facilities
that
use
trust
funds
to
establish
financial
assurance
under
§
§
264.143
and
265.143,
or
264.145
and
265.145,
and
that
are
expected
to
close
prior
to
the
expiration
of
the
permit,
an
estimate
of
the
expected
year
of
final
closure.

Certain
permitted
surface
impoundments
and
waste
piles
from
which
the
owner
or
operator
intends
to
remove
or
decontaminate
the
hazardous
waste
at
partial
or
final
closure
are
required
by
Sections
264.228(
c)(
1)(
ii)
and
264.258(
c)(
1)(
ii)
to
have
contingent
closure
plans.
In
addition,
owners
or
operators
of
tank
systems
or
drip
pads
that
intend
to
remove
or
decontaminate
hazardous
waste
at
partial
or
final
28
closure
are
required
to
submit
contingent
closure
plans
as
specified
in
sections
264.197(
c)(
1)
and
265.197(
c)(
1),
and
264.575(
c)(
1)(
i)
and
265.445(
c)(
1)(
i),
respectively.

(
ii)
Respondent
activities:

Since
permitted
facilities
submit
the
closure
plan
and
contingency
closure
plans
with
the
Part
B
permit
application,
activities
associated
with
developing
and
modifying
the
closure
plan
are
discussed
in
the
Hazardous
Waste
Part
B
Permit
Applications,
Special
Permits,
and
Permit
Modifications
ICR
(#
1573).
Prior
to
submitting
a
permit
application,
interim
status
facilities
must
prepare
a
closure
plan.
Therefore,
preparation
of
and
modification
to
the
closure
plan
for
interim
status
facilities
will
be
covered
in
this
ICR
(#
1571).
This
ICR
will
also
include
activities
associated
with
the
recordkeeping
aspects
of
the
regulations
for
both
permitted
and
interim
status
facilities.

Maintaining
the
closure
plan
at
the
facility
is
the
only
respondent
activity
associated
with
the
recordkeeping
aspects
of
this
regulation.
Respondent
activities
associated
with
developing
a
closure
plan
include:

C
Reading
the
regulations;

C
Conducting
an
inventory
of
the
hazardous
waste
present;

C
Recording
results
of
inventory;

C
Writing
descriptions
for
the
necessary
activities;

C
Estimating
final
closure;
and
C
Writing
the
closure
schedule.

(
2)
Notification
and
Amendment
of
Closure
Plan
(
i)
Data
items:

Permit
modifications
for
permitted
facilities
under
section
264.112(
c)
are
included
in
the
Hazardous
Waste
Part
B
Permit
Applications,
Special
Permits,
and
Permit
Modifications
ICR
(#
1573).
Under
section
265.112(
c),
owners
or
operators
of
interim
status
facilities
may
amend
the
closure
plan
at
any
time
prior
to
notification
of
partial
or
final
closure
of
the
facility.
An
owner
or
operator
with
an
approved
closure
plan
must
submit
a
written
request
to
EPA
to
authorize
a
change
in
the
approved
closure
plan.
The
owner
or
operator
must
amend
the
closure
plan
at
least
60
days
prior
to
the
proposed
change
in
the
facility
design
or
operation,
or
no
later
than
60
days
after
an
unexpected
event
has
occurred
which
has
affected
the
closure
plan.
An
owner
or
operator
with
an
approved
closure
plan
must
submit
the
amended
plan
to
EPA.

(
ii)
Respondent
activities:

Interim
status
facilities
with
approved
closure
plans
must
prepare
and
submit
a
notification
of
amendment,
amend
the
plan,
and
submit
the
plan
to
EPA,
pursuant
to
section
265.112(
c).
29
(
3)
Partial
Closure
and
Final
Closure
Notification
(
i)
Data
items:

Under
Section
264.112(
d)(
1),
owners
or
operators
of
permitted
facilities
must
notify
the
Regional
Administrator
of
imminent
closure
intentions.
Section
265.112(
d)(
1)
requires
owners
or
operators
of
interim
status
facilities
with
approved
closure
plans
to
notify
EPA
of
closure
in
writing
within
a
specified
period
of
time
before
closure
of
the
unit.
Section
265.112(
d)(
1)
also
requires
owners
or
operators
of
interim
status
facilities
to
submit
a
closure
plan
to
the
Regional
Administrator
prior
to
closure.
In
addition,
section
265.112(
d)(
3)
requires
owners
or
operators
of
interim
status
facilities
to
submit
the
closure
plan
to
the
Regional
Administrator
no
later
than
15
days
after
termination
of
interim
status.

(
ii)
Respondent
activities:

Under
section
264.112(
d)(
1)
or
265.112(
d)(
1)
permitted
and
interim
status
facilities
must
prepare
and
submit
a
notification
to
EPA
of
imminent
closure.
Interim
status
facilities
also
must
submit
a
closure
plan
under
section
265.112(
d)(
1)
or
265.112(
d)(
3).

(
4)
Extensions
and
Allowances
During
the
Closure
Period
(
i)
Data
items:

Under
40
CFR
264.113
and
265.113,
owners
and
operators
may
prepare
demonstrations
in
support
of
certain
extensions
and
allowances
during
the
closure
period.
Sections
264.113(
a)
and
265.113(
a)
allow
owners
and
operators
to
request
an
extension
for
the
treatment,
storage,
or
removal
of
hazardous
waste.
To
receive
such
an
extension,
the
owner
or
operator
must
request
a
permit
modification
and
demonstrate
the
following:

C
Treatment,
storage,
and
removal
activities
will,
of
necessity,
take
longer
than
90
days
to
complete;
or
C
The
hazardous
waste
management
unit
or
facility
has
the
capacity
to
receive
additional
hazardous
or
non­
hazardous
wastes;
there
is
a
likelihood
that
operations
will
be
recommenced
within
one
year;
and
closure
of
the
unit
would
be
incompatible
with
continued
operation
of
the
site;
and
C
The
owner
or
operator
has
taken
and
will
continue
to
take
all
steps
necessary
to
prevent
threats
to
human
health
and
the
environment,
including
compliance
with
all
applicable
permit
requirements.

Sections
264.113(
b)
and
265.113(
b)
allow
owners
and
operators
to
request
an
extension
of
the
closure
period.
To
receive
such
an
extension,
the
owner
or
operator
must
request
a
permit
modification
and
demonstrate
the
following:

C
Partial
or
final
closure
activities
will,
of
necessity,
take
longer
than
180
days
to
complete;
or
30
C
The
hazardous
waste
management
unit
or
facility
has
the
capacity
to
receive
additional
hazardous
or
non­
hazardous
wastes;
there
is
a
reasonable
likelihood
that
operations
will
be
recommenced
within
one
year;
and
closure
of
the
unit
would
be
incompatible
with
continued
operation
of
the
site;
and
C
The
owner
or
operator
has
taken
and
will
continue
to
take
all
steps
necessary
to
prevent
threats
to
human
health
and
the
environment,
including
compliance
with
all
applicable
permit
requirements.

Sections
264.113(
d)
and
265.113(
d)
allow
owners
and
operators
to
request
an
allowance
to
receive
only
non­
hazardous
wastes
in
a
landfill,
land
treatment,
or
surface
impoundment
unit
after
the
final
receipt
of
hazardous
waste.
To
receive
such
an
allowance,
the
owner
or
operator
must
request
a
permit
modification,
and
include
the
following
demonstrations
and
information:

C
The
unit
has
the
existing
design
capacity
as
indicated
on
the
part
A
application
to
receive
non­
hazardous
wastes;

C
There
it
a
reasonable
likelihood
that
operations
will
be
recommenced
within
one
year
after
the
final
receipt
of
hazardous
wastes;

C
The
non­
hazardous
wastes
will
not
be
incompatible
with
any
remaining
wastes
in
the
unit
or
facility;

C
Closure
of
the
unit
would
be
incompatible
with
continued
operation
of
the
site;

C
The
owner
or
operator
is
operating
and
will
continue
to
operate
in
compliance
with
all
applicable
permit
requirements;

C
The
request
to
modify
the
permit
includes
an
amended
waste
analysis
plan,
ground­
water
monitoring
and
response
program,
human
exposure
assessment,
closure
and
post­
closure
plans,
updated
cost
estimates
and
demonstrations
of
financial
assurance
for
closure
and
post­
closure
care,
and
changes
in
closure
activities.

(
ii)
Respondent
activities:

The
burden
associated
with
developing
a
permit
modification
for
such
an
extension
or
allowance
is
addressed
in
the
Hazardous
Waste
Part
B
Permit
Application,
Permit
Modifications,
and
Special
Permits
ICR
(#
1573).
Other
respondent
activities
associated
with
obtaining
an
extension
or
allowance
include
the
following:

C
Reading
the
regulations;

C
Preparing
and
submitting
the
demonstration
for
an
extension
for
treatment,
storage,
or
removal
of
hazardous
waste;

C
Preparing
and
submitting
the
demonstration
for
an
extension
of
the
closure
period;
and
C
Preparing
and
submitting
the
demonstration
for
receiving
non­
hazardous
wastes.
31
(
5)
Closure
Certification
(
i)
Data
items:

Sections
264.115
and
265.115
require
owners
or
operators
to
submit
to
the
Regional
Administrator
a
certification
that
the
unit
or
facility
has
been
closed
in
accordance
with
the
specifications
in
the
approved
closure
plan.
Documentation
supporting
the
independent
registered
professional
engineer's
certification
must
be
furnished
to
the
Regional
Administrator
upon
request
before
he
or
she
releases
the
owner
or
operator
from
the
financial
assurance
requirements
for
closure
under
§
§
264.143(
i)
and
265.143(
h).

(
ii)
Respondent
activities:

In
order
to
certify
that
the
unit
or
facility
has
been
closed
in
accordance
with
the
specifications
in
the
approved
closure
plan,
respondents
must
perform
the
following
activities:

C
Read
the
regulations;

C
Have
a
registered
professional
engineer
inspect
the
facility;
and
C
Collect
documentation
to
support
the
certification
and
submit
the
certification.

(
6)
Survey
Plat
(
i)
Data
item:

Sections
264.116
and
265.116
require
an
owner
or
operator
to
submit
to
the
Regional
Administrator
a
survey
plat
indicating
the
location
and
dimensions
of
landfill
cells
or
other
hazardous
waste
disposal
units
with
respect
to
permanently
surveyed
benchmarks.

(
ii)
Respondent
activities:

In
order
to
comply
with
§
264.116
and
§
265.116,
respondents
must
have
a
professional
land
surveyor
prepare
and
certify
a
survey
plat,
and
submit
the
plat
to
the
Regional
Administrator.

(
7)
Post­
Closure
Plan
(
i)
Data
items:

Sections
264.118(
a)
and
265.118(
a)
state
that
the
owner
or
operator
of
a
hazardous
waste
disposal
facility
must
have
a
written
post­
closure
plan.
Surface
impoundments
and
waste
piles
from
which
the
owner
or
operator
intends
to
remove
or
decontaminate
the
hazardous
waste
at
partial
or
final
closure
are
required
by
§
§
264.228(
c)(
1)(
ii)
and
264.258(
c)(
1)(
ii)
to
have
contingent
post­
closure
plans
submitted
with
the
Part
B
permit
application.
In
addition,
owners
or
operators
of
tank
systems
or
drip
pads
that
intend
to
remove
or
decontaminate
the
hazardous
waste
at
partial
or
final
closure
are
required
to
submit
a
contingent
post­
closure
plan,
as
specified
in
sections
264.197(
c)(
2)
and
265.197(
c)(
2),
and
264.575(
c)(
1)(
ii)
and
32
265.445(
c)(
1)(
ii),
respectively.
Section
265.118
requires
owners
or
operators
to
maintain
a
copy
of
the
post­
closure
plan
at
the
facility.

Data
items
included
in
the
post­
closure
plan
are
listed
below:

C
A
description
of
the
facility's
monitoring
activities
and
frequencies
at
which
they
will
be
performed
to
comply
with
Subparts
F,
K,
L,
M,
N,
and
X
during
the
post­
closure
care
period;

C
A
description
of
the
planned
maintenance
activities,
and
frequencies
at
which
they
will
be
performed;

C
The
name,
address,
and
phone
number
of
the
person
or
office
to
contact
about
the
hazardous
waste
disposal
unit
or
facility
during
the
post­
closure
care
period;
and
C
A
copy
of
the
approved
post­
closure
plan,
to
be
provided
to
the
Regional
Administrator
upon
request,
until
final
closure
of
the
facility.

(
ii)
Respondent
activities:

Since
permitted
facilities
submit
post­
closure
and
contingent
post­
closure
plans
with
the
Part
B
permit
application,
activities
associated
with
developing
these
post­
closure
plans
are
discussed
in
the
Hazardous
Waste
Part
B
Permit
Applications,
Special
Permits,
and
Permit
Modifications
ICR
(#
1573).
Prior
to
submitting
a
permit,
interim
status
facilities
must
develop
a
post­
closure
plan.
Therefore,
preparation
of
these
plans
for
interim
status
facilities
will
be
covered
in
this
ICR
(#
1571).
This
ICR
will
also
focus
on
activities
associated
with
the
recordkeeping
aspects
of
the
regulations
for
both
permitted
and
interim
status
facilities.

Section
265.118(
e)
requires
an
interim
status
facility
owner
or
operator
to
submit
a
post­
closure
plan
to
the
Regional
Administrator
no
later
than
15
days
after
termination
of
interim
status,
except
when
a
permit
is
issued
simultaneously
with
termination
of
interim
status,
or
the
facility
is
issued
a
judicial
decree
or
final
order
under
§
3008
of
RCRA
to
cease
receiving
hazardous
wastes
or
close.
If
the
Regional
Administrator
does
not
approve
the
plan,
the
owner
or
operator
must
modify
the
plan
or
submit
a
new
plan
for
approval.

In
order
to
comply
with
the
post­
closure
plan
requirements,
respondents
must
perform
the
following
activities:

C
Read
the
regulations;

C
Collect
the
necessary
information;

C
Prepare
and
submit
the
post­
closure
plan
or
contingent
post­
closure
plan,
if
applicable
(
new
interim
status
facilities
only);
and
C
Maintain
the
plan.
33
(
8)
Notification
and
Amendment
of
Post­
Closure
Plan
Under
265.118(
d)(
1)­(
3)

(
i)
Data
items:

Section
265.118(
d)(
1)­(
3)
requires
owners
or
operators
of
interim
status
facilities
to
submit
written
requests
to
authorize
changes
to
approved
post
closure
plans,
and
requires
submittal
of
modified
plans
to
the
Regional
Administrator.
Under
section
264.118(
d)(
1)­(
3),
permitted
facilities
must
request
permit
modifications
to
authorize
and
make
changes
to
approved
post­
closure
plans.
Such
permit
modifications
are
included
in
ICR
#
1573.

(
ii)
Respondent
activities:

Interim
status
facilities
must:

C
Prepare
a
notification
of
amendment;

C
Amend
the
plan;
and
C
Submit
these
data
items
to
EPA,
as
required
by
section
265.118(
d)(
1)­(
3).

(
9)
Amendment
of
Post­
Closure
Plan
Under
265.118(
d)(
4),
(
f),
and
(
g)(
1)

(
i)
Data
items:

Under
40
CFR
265.118(
d)(
4),
if
the
Regional
Administrator
determines
that
an
owner
or
operator
of
a
surface
impoundment
or
waste
pile
who
intended
to
remove
all
hazardous
wastes
at
closure
must
close
the
facility
as
a
landfill,
the
owner
or
operator
must
submit
to
the
Regional
Administrator
within
90
days
of
the
determination
a
post­
closure
plan
for
approval.
If
the
Regional
Administrator
requests
modifications
to
the
plan,
the
owner
or
operator
must
submit
the
modified
plan
no
later
than
60
days
after
the
Regional
Administrator's
request
or
no
later
than
90
days
if
the
unit
is
a
surface
impoundment
or
waste
pile
not
previously
required
to
prepare
a
contingent
closure
plan.

Under
section
265.118(
f),
if
the
Regional
Administrator
does
not
approve
the
plan,
he
or
she
must
provide
the
owner
or
operator
with
a
detailed
written
statement
of
reasons
for
the
refusal.
The
owner
or
operator
must
modify
the
plan
or
submit
a
new
plan
within
30
days
after
receiving
such
written
statement.

Under
section
265.118(
g)(
1),
the
owner
or
operator
may
prepare
and
submit
a
petition
to
the
Regional
Administrator
to
extend
or
reduce
the
post­
closure
period
applicable
to
a
hazardous
waste
management
unit
or
facility,
or
to
alter
the
requirements
of
the
post­
closure
care
period.

(
ii)
Respondent
activities:

In
order
to
comply
with
sections
265.118(
d)(
4)
and
265.118(
f),
respondents
must
perform
the
following
activities:

C
Prepare
an
amended
post­
closure
plan;

C
Submit
the
amended
plan
to
EPA;
and
34
C
Modify
and
resubmit
plan,
if
not
approved
by
EPA
In
order
to
obtain
an
extension
or
reduction
of
the
post­
closure
period,
per
section
265.118(
g)(
1),
respondents
must
prepare
a
petition
and
submit
it
to
EPA.
(
Permitted
facilities
are
covered
in
the
Hazardous
Waste
Part
B
Permit
Applications,
Specific
Permits
and
Permit
Modifications
ICR,
#
1573.)

(
10)
Hazardous
Waste
Disposal
Records
(
i)
Data
items:

Sections
264.119(
a)
and
265.119(
a)
require
owners
or
operators
to
submit
to
the
local
zoning
authority,
or
to
the
authority
with
jurisdiction
over
local
land
use,
and
to
the
Regional
Administrator
a
record
of
the
type,
location,
and
quantity
of
hazardous
wastes
disposed
of
within
each
cell
or
other
disposal
unit
of
the
facility.

(
ii)
Respondent
activities:

In
order
to
comply
with
sections
264.119(
a)
and
265.119(
a),
respondents
must
perform
the
following
activities:

C
Determine
the
specifications
of
the
hazardous
waste
activity;
and
C
Establish,
submit,
and
maintain
(
i.
e.,
photocopying
and
filing)
a
record
of
the
activity.

(
11)
Hazardous
Waste
Notation
Certification
(
i)
Data
items:

Sections
264.119(
b)(
2)
and
265.119(
b)(
2)
require
owners
or
operators
to
submit
to
the
Regional
Administrator
a
signed
certification
that
they
have
recorded
the
notation
required
in
§
§
264.119(
b)(
1)
and
265.119(
b)(
1),
including
a
copy
of
the
document
in
which
the
notation
has
been
placed.

(
ii)
Respondent
activities:

In
order
to
comply
with
sections
264.119(
b)(
2)
and
265.119(
b)(
2),
respondents
must
record
the
notation
on
the
deed,
and
develop
and
submit
the
certification
to
the
Regional
Administrator.

(
12)
Post­
Closure
Permit
Modification
(
i)
Data
items:

Sections
264.119(
c)
and
265.119(
c)
state
that
if
an
owner
wishes
to
remove
hazardous
wastes
and
residues,
liners,
or
contaminated
soils,
he
or
she
must
request
a
modification
to
the
post­
closure
permit
and
demonstrate
that
removal
of
hazardous
waste
will
satisfy
the
criteria
of
§
§
264.117(
c)
and
265.118(
g).
For
permitted
facilities,
the
modification
will
be
done
through
the
permit
modification
process
and
will
be
covered
by
the
Hazardous
Waste
Part
B
Permit
Applications,
Special
Permits,
and
Permit
Modifications
ICR
(#
1573).
35
(
ii)
Respondent
activities:

Respondent
activities
associated
with
modification
of
the
post­
closure
permit
include:

C
Reading
the
regulations;

C
Preparing
a
request
for
modification;
and
C
Demonstrating
compliance
through
a
written
document
or
some
other
form
of
notification.

(
13)
Post­
Closure
Care
Certification
(
i)
Data
items:

Sections
264.120
and
265.120
state
that
owners
or
operators
must
submit
to
the
Regional
Administrator
a
certification
that
the
post­
closure
care
period
for
the
facility
was
performed
in
accordance
with
the
specifications
in
the
approved
closure
plan.
Documentation
supporting
the
independent
registered
professional
engineer's
certification
must
be
furnished
to
the
Regional
Administrator
upon
request
before
he
or
she
releases
the
owner
from
the
financial
assurance
requirements
for
closure
under
§
§
264.145(
i)
and
265.145(
h).

(
ii)
Respondent
activities:

Respondent
activities
associated
with
certifying
completion
of
post­
closure
care
include:

C
Reading
the
regulations;

C
Obtaining
certification
of
compliance
from
an
independent
registered
professional
engineer;

C
Maintaining
a
copy
of
the
certification;
and
C
Submitting
the
necessary
documentation
to
the
Regional
Administrator
as
required.

FINANCIAL
REQUIREMENTS
(
1)
Financial
Responsibility
for
Corrective
Action
(
i)
Data
item:

Sections
264.101(
b)
and
264.101(
c)
require
owners
and
operators
of
facilities
containing
solid
waste
management
units
(
SWMUs)
to
institute
corrective
action
as
necessary,
and
to
provide
assurances
of
financial
responsibility
for
completing
such
corrective
action.
This
assurance
must
contain
the
documented
assurances
of
financial
responsibility
in
the
permit
for
the
means
of
corrective
action
chosen.
36
(
ii)
Respondent
activity:

In
order
to
comply
with
sections
264.101(
b)
and
264.101(
c),
respondents
must
prepare
and
submit
to
the
Regional
Administrator,
with
the
permit,
documented
assurances
of
financial
responsibility
for
the
corrective
action
chosen
to
be
implemented.

(
2)
Cost
Estimates
for
Closure
and
Post­
Closure
Care
(
i)
Data
items:

Sections
264.142,
265.142,
264.144,
and
265.144
require
owners
and
operators
to
maintain
a
detailed
written
estimate
of
the
cost
of
facility
closure
or
post­
closure
care,
in
accordance
with
the
requirements
specified
in
§
§
264.142(
a),
265.142(
a),
264.144(
a),
and
265.144(
a),
respectively.
Section
264.144
only
applies
to
owners
or
operators
of
disposal
surface
impoundments,
disposal
miscellaneous
units,
land
treatment
units,
or
landfill
units,
or
owners
or
operators
of
surface
impoundments
or
waste
piles
required
to
prepare
contingency
closure
and
post­
closure
plans,
while
Section
265.144
applies
to
owners
or
operators
of
interim
status
hazardous
waste
disposal
units.
These
estimates
must
include
the
following
data
items:

C
A
written
estimate
containing:

­­
The
costs
of
final
closure
at
the
point
in
the
facility's
active
life
when
the
extent
and
manner
of
its
operation
would
make
closure
the
most
expensive,
as
indicated
by
its
closure
plan
(
§
§
264.142(
a)(
1)
and
265.142(
a)(
1));
or
­­
The
annual
cost
of
post­
closure
monitoring
and
maintenance
of
the
facility
in
accordance
with
the
applicable
post­
closure
regulations
specified
in
§
§
264.144(
a)
and
265.144(
a);

C
Estimates
of
the
following
cost,
as
required
under
§
264.258(
c)(
2)
for
waste
piles
only:

­­
The
cost
of
complying
with
the
contingent
closure
plan
or
the
contingent
post­
closure
plan,
but
not
the
cost
of
expected
closure
under
§
264.258(
c)(
2);

C
Estimates
of
the
following
cost,
as
required
under
§
§
264.197(
c)(
3)
and
265.197(
c)(
3)
for
tank
systems
only:

­­
The
cost
of
complying
with
the
contingent
closure
plan
and
the
contingent
post­
closure
plan,
if
those
costs
are
greater
than
the
costs
of
complying
with
the
closure
plan
prepared
for
the
expected
closure
under
§
§
264.197(
a)
and
265.197(
a).

C
Estimates
of
the
following
cost,
as
required
under
§
264.228(
c)(
2)
for
surface
impoundments,
§
§
264.575(
c)(
2)
and
265.445(
c)(
2)
for
drip
pads,
and
§
264.258(
c)(
2)
for
waste
piles:
37
­­
The
cost
of
complying
with
the
contingent
closure
plan
and
the
contingent
post­
closure
plan,
but
not
the
cost
of
expected
closure
under
§
§
264.228(
a)
for
surface
impoundments,
264.575(
a)
or
265.445(
a)
for
drip
pads,
and
264.258(
a)
for
waste
piles.

C
Costs
to
owners
or
operators
of
hiring
a
third
party
to
conduct
closure
or
post­
closure
care
at
the
facility;

C
An
adjustment
of
the
closure
or
post­
closure
cost
estimate
for
inflation
within
sixty
days
of
the
anniversary
date
of
the
establishment
of
the
financial
instrument(
s)
used
to
assure
financial
responsibility
for
closure
(
thirty
days
in
the
case
of
owners
or
operators
using
the
financial
test
or
corporate
guarantee)(
§
§
264.142(
b),
265.142(
b),
264.144(
b),
and
265.144(
b));
and
C
A
revision
of
the
closure
or
post­
closure
cost
estimate
no
later
than
thirty
days
after
a
modification
has
been
made
to
the
closure
or
post­
closure
plan
which
increases
the
closure
or
post­
closure
cost
(
§
§
264.142(
c),
265.142(
c),
264.144(
c),
and
265.144(
c)).

(
ii)
Respondent
activities:

Owners
and
operators
will
need
to
engage
in
several
activities
in
order
to
collect
and
maintain
the
data
required
by
§
§
264.142,
265.142,
264.144,
and
265.144:

C
Reading
the
regulations;

C
Collecting
data;

C
Preparing
the
written
cost
estimate;

C
Periodically
adjusting
the
cost
estimate
to
include
inflation
and/
or
revisions
to
the
closure
or
post­
closure
plan;
and
C
Maintaining
at
the
facility
the
latest
closure
or
post­
closure
cost
estimate
and
any
subsequent
adjustments.

(
3)
Financial
Assurance
for
Closure
and
Post­
Closure
Care
Owners
or
operators
are
required
to
establish
and
provide
evidence
of
financial
assurance
for
facility
closure
(
§
§
264.143
and
265.143)
and
post­
closure
care
(
§
§
264.145
and
265.145).
Several
financial
instruments
are
described
throughout
these
sections
for
the
purpose
of
establishing
financial
assurance:

(
a)
Closure
or
Post­
Closure
Trust
Fund
(
i)
Data
items:

Sections
264.143(
a),
265.143(
a),
264.145(
a),
and
265.145(
a)
explain
that
owners
or
operators
may
establish
a
closure
or
post­
closure
trust
fund
in
order
to
comply
with
§
§
264.143,
265.143,
264.145,
38
and
265.145
requirements.
Data
items
for
establishing
and
providing
evidence
of
a
closure
or
post­
closure
trust
fund
include:

C
A
trust
agreement
in
compliance
with
§
§
264.143(
a)(
2)­(
8)
and
(
10),
265.143(
a)(
2)­(
8)
and
(
10),
264.145(
a)(
2)­(
8)
and
(
11),
and
265.145(
a)(
2)­(
8)
and
(
11);
and
C
For
post­
closure
trust
funds,
a
formal
certification
of
acknowledgment
(
§
§
264.145(
a)(
2)
and
265.145(
a)(
2)).

(
ii)
Respondent
activities:

Owners
and
operators
establishing
a
trust
fund
in
order
to
comply
with
the
closure
and
post­
closure
financial
assurance
requirements
of
sections
264.143,
265.143,
264.145,
and
265.145
will
need
to
engage
in
the
following
respondent
activities:

C
Reading
the
regulations;

C
Establishing
a
closure
or
post­
closure
trust
fund,
in
compliance
with
§
§
264.143(
a)(
2)­(
8)
and
(
10),
265.143(
a)(
2)­(
8)
and
(
10),
264.145(
a)(
2)­(
8)
and
(
11),
and
265.145(
a)(
2)­(
8)
and
(
11);

C
Submitting
an
originally
signed
duplicate
of
the
trust
agreement
to
the
EPA
Regional
Administrator
(
owners
or
operators
of
new
facilities
must
submit
this
at
least
sixty
days
prior
to
receiving
hazardous
waste
for
treatment,
storage,
or
disposal);

C
Submitting
the
formal
certification
of
acknowledgment
required
for
post­
closure
trust
funds;
and
C
For
owners
and
operators
of
new
facilities,
submitting
a
receipt
for
the
first
payment
under
the
trust
agreement
before
the
initial
receipt
of
hazardous
wastes.

(
b)
Surety
Bond
Guaranteeing
Payment
into
a
Closure
or
Post­
Closure
Trust
Fund
(
i)
Data
items:

Sections
264.143(
b),
265.143(
b),
264.145(
b),
and
265.145(
b)
allow
owners
and
operators
to
establish
surety
bonds
in
order
to
comply
with
the
financial
assurance
requirements
of
Sections
264.143,
265.143,
264.145,
and
265.145.
Establishing
surety
bonds
that
guarantee
payment
into
a
closure
or
postclosure
trust
fund
will
entail
the
collection
of
the
following
data
items:

C
A
surety
bond
and
trust
agreement
indicating
the
conditions
of
payment
into
the
closure
or
post­
closure
standby
trust
fund
specified
in
§
§
264.143(
b)(
2)­(
6)
and
(
8),
265.143(
b)(
2)­(
6)
and
(
8),
264.145(
b)(
2)­(
6)
and
(
8),
and
265.145(
b)(
2)­(
6)
and
(
8);
and
C
Evidence
of
an
increase
or
decrease
in
the
closure
or
post­
closure
cost
estimate
that
may
require
the
penal
sum
of
the
surety
bond
to
be
increased
or
decreased
accordingly
(
§
§
264.143(
b)(
7),
265.143(
b)(
7),
264.145(
b)(
7),
and
265.145(
b)(
7)).
39
(
ii)
Respondent
activities:

In
collecting
these
data
items,
owners
and
operators
will
need
to
engage
in
the
following
respondent
activities:

C
Reading
the
regulations;

C
Establishing
a
surety
bond
and
trust
agreement
that
comply
with
the
financial
assurance
requirements
of
§
§
264.143,
265.143,
264.145,
and
265.145;

C
Submitting
originally
signed
duplicates
of
the
surety
bond
and
trust
agreement
to
the
Regional
Administrator
(
for
new
facilities,
these
must
be
submitted
at
least
sixty
days
before
receiving
hazardous
waste
for
disposal);

C
Submitting
evidence
of
and
obtaining
approval
from
the
Regional
Administrator
for
alternate
financial
assurance
mechanisms,
in
the
case
of
cancellation
of
the
bond
by
the
surety;

C
Increasing
the
penal
sum
amount,
in
the
case
of
an
corresponding
increase
in
the
closure
or
post­
closure
cost
estimate;
and
C
Submitting
evidence
of
such
an
increase
in
the
closure
or
post­
closure
cost
estimate
to
the
Regional
Administrator.

(
c)
Surety
Bond
Guaranteeing
Performance
of
Closure
or
Post­
Closure
Care
(
i)
Data
items:

Sections
264.143(
c)
and
264.145(
c)
allow
owners
or
operators
of
permitted
facilities
to
comply
with
§
§
264.143
and
264.145
requirements
by
obtaining
a
surety
bond
that
guarantees
performance
of
closure
or
post­
closure
care.
Data
items
for
this
option
include:

C
A
surety
bond
and
trust
agreement
indicating
the
conditions
of
payment
into
the
standby
trust
fund
specified
in
§
§
264.143(
c)(
2)­(
6)
and
(
8)
and
264.145(
c)(
2)­(
6)
and
(
9);
and
C
Evidence
of
an
increase
in
the
closure
or
post­
closure
cost
estimate
that
may
require
the
penal
sum
of
the
surety
bond
to
be
increased
or
decreased
accordingly
(
§
§
264.143(
c)(
7)
and
264.145(
c)(
7)).

(
ii)
Respondent
activities:

In
collecting
these
data
items,
owners
and
operators
will
need
to
engage
in
the
following
respondent
activities:

C
Reading
the
regulations;
40
C
Obtaining
a
surety
bond
and
trust
agreement
that
comply
with
the
financial
assurance
requirements
of
§
§
264.143
and
264.145;

C
Submitting
originally
signed
duplicates
of
the
surety
bond
and
trust
agreement
to
the
Regional
Administrator
(
for
new
facilities,
these
must
be
submitted
at
least
sixty
days
prior
to
receiving
hazardous
wastes
for
disposal);

C
Submitting
evidence
of
and
obtaining
approval
from
the
Regional
Administrator
for
alternate
financial
assurance
mechanisms,
in
the
case
of
cancellation
of
the
bond
by
the
surety;

C
Increasing
the
penal
sum
amount,
in
the
case
of
a
corresponding
increase
in
the
closure
or
post­
closure
cost
estimate;
and
C
Submitting
evidence
of
such
an
increase
in
the
closure
or
post­
closure
cost
estimate
to
the
Regional
Administrator.

(
d)
Closure
or
Post­
Closure
Letter
of
Credit
(
i)
Data
items:

Sections
264.143(
d),
265.143(
c),
264.145(
d),
and
265.145(
c)
specify
that
owners
or
operators
may
obtain
an
irrevocable
standby
letter
of
credit
in
order
to
satisfy
financial
assurance
requirements.
Data
items
for
this
information
collection
include:

C
A
letter
of
credit
from
an
issuing
institution
authorized
to
issue
letters
of
credit
and
whose
letter­
of­
credit
operations
are
regulated
and
examined
by
a
Federal
or
State
agency;

C
A
trust
agreement
indicating
the
conditions
of
payment
into
the
standby
trust
fund
specified
in
§
§
264.143(
d)(
2)­(
4)
and
(
6),
265.143(
c)(
2)­(
4)
and
(
6),
264.145(
d)(
2)­(
6),
and
265.145(
c)(
2)­(
6);

C
Notification
from
the
issuing
institution
to
the
owner/
operator
and
EPA
of
a
decision
not
to
extend
the
expiration
date
mailed
at
least
120
days
before
the
current
expiration
date
of
the
letter
of
credit
(
§
§
264.143(
d)(
5)
and
265.143(
c)(
5));

C
A
letter
(
to
accompany
the
letter
of
credit)
from
the
owner
or
operator
providing
the
following
information:

­­
The
number,
issuing
institution,
and
date
of
the
letter
of
credit;

­­
The
EPA
identification
number,
name,
and
address
of
the
facility;
and
­­
The
amount
of
funds
assured
for
closure
of
or
post­
closure
care
for
the
facility
by
the
letter
of
credit;
and
41
C
Evidence
of
an
increase
in
the
closure
or
post­
closure
cost
estimate
that
may
require
the
amount
of
credit
to
be
increased
accordingly
(
§
§
264.143(
d)(
7),
265.143(
c)(
7),
264.145(
d)(
7),
and
265.145(
c)(
7)).

(
ii)
Respondent
activities:

Owners
or
operators
will
need
to
engage
in
the
following
activities
in
order
to
satisfy
the
financial
assurance
requirements
with
a
closure
or
post­
closure
letter
of
credit:

C
Reading
the
regulations;

C
Obtaining
a
letter
of
credit
from
an
issuing
institution
and
establishing
the
stand­
by
trust
fund;

C
Writing
a
letter
from
the
owner
or
operator
to
accompany
the
letter
of
credit;

C
Submitting
the
following
documents
to
the
Regional
Administrator:

­­
The
letter
of
credit
(
in
the
case
of
new
permitted
facilities,
this
must
be
submitted
at
least
sixty
days
prior
to
receiving
hazardous
waste
for
treatment,
storage,
or
disposal,
pursuant
to
§
§
264.143(
d)(
1)
and
264.145(
d)(
1));

­­
The
accompanying
letter
from
the
owner
or
operator;
and
­­
An
originally
signed
duplicate
of
the
trust
agreement;

C
Increasing
the
amount
of
the
letter
of
credit,
in
the
case
of
corresponding
increase
in
the
closure
or
post­
closure
cost
estimate;
and
C
Submitting
evidence
of
such
an
increase
in
the
closure
or
post­
closure
cost
estimate
to
the
Regional
Administrator.

(
e)
Closure
or
Post­
Closure
Insurance
(
i)
Data
items:

Owners
or
operators
may
satisfy
the
financial
assurance
requirements
for
closure
or
post­
closure
care
by
establishing
closure
or
post­
closure
insurance
according
to
§
§
264.143(
e),
265.143(
d),
264.145(
e),
and
265.145(
d).
Data
items
for
this
information
collection
include:

C
A
closure
or
post­
closure
insurance
policy
(
identified
by
a
certificate
of
insurance)
that
meets
the
requirements
specified
in
§
§
264.143(
e)(
1)­(
4)
and
(
8),
265.143(
d)(
1)­(
4)
and
(
8),
264.145(
e)(
1)­(
5)
and
(
8),
or
265.145(
d)(
1)­(
5)
and
(
8);

C
In
the
case
of
some
interim
status
facilities,
a
letter
from
an
insurer
stating
that
an
owner
or
operator
is
being
considered
for
a
closure
insurance
policy
(
§
§
265.143(
d)(
1)
and
265.145(
d)(
1));
and
42
C
Evidence
of
an
increase
in
the
closure
or
post­
closure
cost
estimate
that
may
require
the
face
amount
of
the
insurance
policy
to
be
increased
accordingly
(
§
§
264.143(
e)(
7),
265.143(
d)(
7),
264.145(
e)(
7),
and
265.145(
d)(
7)).

(
ii)
Respondent
activities:

Collecting
this
data
will
entail
the
following
respondent
activities:

C
Reading
the
regulations;

C
Obtaining
a
closure
or
post­
closure
insurance
policy
that
satisfies
the
requirements
of
§
§
264.143,
265.143,
264.145,
or
265.145;

C
Submitting
a
certificate
of
this
insurance
policy
to
the
Regional
Administrator
(
for
new
facilities,
this
must
be
submitted
at
least
sixty
days
prior
to
receiving
hazardous
wastes
for
treatment,
storage,
or
disposal);

C
In
the
case
of
some
interim
status
facilities,
submitting
a
letter
from
an
insurer
stating
that
the
insurer
is
considering
issuance
of
an
insurance
certificate
(
in
this
case,
owners
or
operators
must
submit
the
certificate
of
insurance
within
ninety
days
of
the
effective
date
of
these
regulations);
and
C
Submitting
evidence
of
an
increase
in
the
current
closure
or
post­
closure
cost
estimate
that
may
require
the
face
amount
of
the
insurance
policy
to
be
modified
accordingly.

(
f)
Financial
Test
and
Corporate
Guarantee
for
Closure
or
Post­
Closure
Care
(
i)
Data
items:

Sections
264.143(
f),
265.143(
e),
264.145(
f),
and
265.145(
e)
allow
owners
and
operators
to
satisfy
closure
or
post­
closure
financial
assurance
requirements
by
demonstrating
financial
strength
using
the
financial
test
specified
in
these
sections.
Data
items
for
this
demonstration
include:

C
A
letter
signed
by
the
owner's
or
operator's
chief
financial
officer
and
worded
as
specified
in
§
264.151(
f);

C
A
copy
of
an
independent
certified
public
accountant's
report
on
examination
of
the
owner's
or
operator's
financial
statements
for
the
latest
completed
fiscal
year;

C
A
special
report
from
the
owner's
or
operator's
independent
certified
public
accountant
to
the
owner
or
operator
covering
the
specifications
outlined
in
§
§
264.143(
f)(
3)(
iii),
265.143(
e)(
3)(
iii),
264.145(
f)(
3)(
iii),
or
265.145(
e)(
3)(
iii);

C
If
an
extension
of
submission
of
the
above
documents
is
sought,
a
letter
from
the
owner's
or
operator's
chief
financial
officer
to
the
Regional
Administrator
of
each
Region
in
which
43
facilities
to
be
covered
under
the
financial
test
are
located.
This
letter,
allowed
only
under
§
§
265.143(
e)(
4)
and
265.145(
e)(
4),
must
contain
the
following
data
items:

­­
A
request
for
the
extension;

­­
A
certification
that
the
chief
financial
officer
believes
that
the
owner
or
operator
meets
the
criteria
of
the
financial
test;

­­
For
each
facility
to
be
covered
by
the
test,
the
EPA
identification
number,
name,
address,
and
current
closure
and
post­
closure
cost
estimates
to
be
covered
by
the
test;

­­
A
specification
of
the
date
(
no
later
than
ninety
days
after
the
end
of
such
fiscal
year)
when
the
owner
or
operator
will
submit
the
documents
specified
in
§
§
265.143(
e)(
3)
and
265.145(
e)(
3);
and
­­
A
certification
that
the
year­
end
financial
statements
of
the
owner
or
operator
for
such
fiscal
year
will
be
audited
by
an
independent
certified
public
accountant;

C
Annual
updates
of
the
above
data
items;

C
A
notice
of
intent
to
establish
alternative
financial
assurance,
if
the
owner
or
operator
fails
the
financial
test
and
no
longer
meets
the
requirements
of
§
§
264.143(
f)(
1),
265.143(
e)(
1),
264.145(
f)(
1),
or
265.145(
e)(
1);

C
Reports
of
financial
conditions
as
required
by
the
Regional
Administrator
(
§
§
264.143(
f)(
7),
265.143(
e)(
7),
264.145(
f)(
7),
and
265.145(
e)(
7));

C
If
applicable,
a
written
guarantee
from
the
parent
corporation
of
the
owner
or
operator
that
satisfies
financial
assurance
requirements
(
§
§
264.143(
f)(
10),
265.143(
e)(
10),
264.145(
f)(
10),
or
265.145(
e)(
10));
and
C
Notification
from
the
insurer
to
the
owner/
operator
and
EPA
of
a
decision
to
cancel,
terminate,
or
fail
to
renew
the
policy
(
§
§
264.145(
f)(
11)(
ii)
and
265.143(
e)(
11)(
ii)).

(
ii)
Respondent
activities:

Owners
or
operators
will
need
to
engage
in
the
following
respondent
activities
in
order
to
collect
the
data
required
by
these
sections:

C
Reading
the
regulations;

C
Writing
the
letter
signed
by
the
chief
financial
officer;

C
Submitting
the
following
documents
to
the
Regional
Administrator
(
for
new
facilities,
these
documents
must
be
submitted
at
least
sixty
days
prior
to
receiving
hazardous
waste
for
treatment,
storage,
or
disposal):
44
­­
The
letter
signed
by
the
chief
financial
officer;

­­
A
copy
of
the
independent
certified
public
accountant's
report;
and
­­
The
special
report
from
the
independent
certified
public
accountant;

C
Submitting
updated
information
annually;

C
If
applicable,
writing
and
submitting
a
notice,
by
certified
mail,
to
the
Regional
Administrator
of
intent
to
establish
other
financial
assurance;

C
Writing
and
submitting
additional
reports
of
financial
condition
at
any
time,
as
directed
by
the
Regional
Administrator;
and
C
If
applicable,
submitting
the
corporate
guarantee
from
the
parent
corporation
of
the
owner
or
operator.

(
g)
Use
of
a
Financial
Mechanism
for
Multiple
Facilities
(
i)
Data
items:

Sections
264.143(
h),
265.143(
g),
264.145(
h),
and
265.145(
g)
specify
that
owners
or
operators
may
use
one
of
the
above
financial
assurance
mechanisms
to
meet
the
requirements
of
§
§
264.143,
265.143,
264.145,
or
265.145
for
more
than
one
facility.
In
such
cases,
the
owner
and
operator
must
provide
the
following
data
items
for
each
facility:

C
EPA
identification
number,
name,
and
address;
and
C
The
amount
of
funds
for
closure
or
post­
closure
care
assured
by
the
mechanism.

(
ii)
Respondent
activities:

To
comply
with
the
requirements
of
these
sections,
owners
and
operators
will
need
to
engage
in
the
following
activities:

C
Reading
the
regulations;

C
Submitting
the
data
items
listed
above
to
the
Regional
Administrator;
and
C
If
the
facilities
covered
by
the
mechanism
are
located
in
more
than
one
Region,
submitting
identical
evidence
of
financial
assurance
to
all
the
applicable
Regional
Administrators.

(
4)
Liability
Requirements
(
a)
Coverage
for
Sudden
or
Nonsudden
Accidental
Occurrences
(
I)
Data
items:
45
Sections
264.147(
a)
and
265.147(
a)
specify
that
owners
and
operators
of
hazardous
waste
treatment,
storage,
and
disposal
facilities
must
demonstrate
financial
responsibility
for
bodily
injury
and
property
damage
to
third
parties
caused
by
sudden
accidental
occurrences
arising
from
operations
of
the
facility
or
group
of
facilities.
Similarly,
§
§
264.147(
b)
and
265.147(
b)
require
owners
or
operators
of
surface
impoundments,
landfills,
land
treatment
facilities
managing
hazardous
wastes,
or
combinations
of
such
facilities
to
demonstrate
financial
responsibility
for
bodily
injury
and
property
damage
to
third
parties
caused
by
nonsudden
accidental
occurrences
arising
from
facilities'
operations.
In
order
to
comply
with
these
sections,
owners
or
operators
will
need
to
gather
the
following
data
items:

C
Liability
coverage
demonstrated
by
one
of
the
following
documents
(
data
items
for
these
documents
are
described
in
full
in
the
following
sections):

­­
A
liability
insurance
policy
(
§
§
264.147(
a)(
1),
265.147(
a)(
1),
264.147(
b)(
1),
or
265.147(
b)(
1)),
accompanied
by
a
signed
duplicate
original
of
a
Hazardous
Waste
Facility
Liability
Endorsement
or
a
Certificate
of
Liability
Insurance
(
§
§
264.147(
a)(
1)
and
264.147(
b)(
1)
only);

­­
Written
evidence
of
passing
a
financial
test
or
a
written
guarantee
for
liability
coverage
from
the
owner's
or
operator's
parent
corporation,
a
firm
whose
parent
corporation
is
the
parent
corporation
of
the
owner
or
operator,
or
a
firm
with
a
"
substantial
business
relationship"
with
the
owner
or
operator
(
§
§
264.147(
a)(
2),
265.147(
a)(
2),
264.147(
b)(
2),
and
265.147(
b)(
2));

­­
A
letter
of
credit
for
liability
coverage
(
§
§
264.147(
a)(
3),
265.147(
a)(
3),
264.147(
b)(
3),
and
265.147(
b)(
3));

­­
A
surety
bond
for
liability
coverage
(
§
§
264.147(
a)(
4),
265.147(
a)(
4),
264.147(
b)(
4),
and
265.147(
b)(
4));

­­
A
trust
fund
for
liability
coverage
(
§
§
264.147(
a)(
5),
265.147(
a)(
5),
264.147(
b)(
5),
and
265.147(
b)(
5));
or
­­
A
combination
of
insurance,
financial
test,
guarantee,
letter
of
credit,
surety
bond,
and
trust
fund
(
§
§
264.147(
a)(
6),
265.147(
a)(
6),
264.147(
b)(
6),
and
265.147(
b)(
6));

C
A
written
notification
to
the
Regional
Administrator
whenever
a
claim
or
verification
of
a
valid
claim
for
bodily
injury
or
property
damages
caused
by
the
operation
of
a
hazardous
waste
treatment,
storage,
or
disposal
facility
is
made
against
the
owner
or
operator
(
§
§
264.147(
a)(
7),
265.147(
a)(
7),
264.147(
b)(
7),
and
265.147(
b)(
7));
and
C
A
written
notification
to
the
Regional
Administrator
whenever
the
amount
of
financial
assurance
for
liability
coverage
under
one
of
the
above­
mentioned
instruments
is
reduced,
contingent
on
a
claim
or
verification
of
a
valid
claim
(
§
§
264.147(
a)(
7),
265.147(
a)(
7),
264.147(
b)(
7),
and
265.147(
b)(
7)).
46
(
ii)
Respondent
activities:

Owners
or
operator
will
need
to
engage
in
the
following
activities
in
order
to
comply
with
the
information
collection
requirements
of
§
§
264.147(
a)
and
(
b),
and
265.147(
a)
and
(
b):

C
Read
the
regulations;

C
Establish
liability
coverage
using
one
of
the
financial
instruments
listed
above;

C
Submit
appropriate
evidence
of
such
financial
instruments
to
the
Regional
Administrator
(
in
the
case
of
new
facilities
establishing
liability
insurance,
this
must
be
submitted
at
least
sixty
days
before
receiving
hazardous
wastes
for
treatment,
storage,
or
disposal,
according
to
§
§
264.147(
a)(
1)(
i)
and
265.147(
b)(
1)(
i));

C
Prepare,
write,
and
submit
a
notification
to
the
Regional
Administrator
whenever
a
claim
for
bodily
injury
is
made
against
the
owner
or
operator;
and
C
Prepare,
write,
and
submit
a
notification
to
the
Regional
Administrator
whenever
the
amount
of
financial
assurance
for
liability
coverage
is
reduced.

Submission
of
the
two
notifications
listed
immediately
above
will
only
occur
in
the
event
of
a
claim;
therefore,
if
no
accidental
releases
occur,
owners
or
operators
may
never
need
to
submit
these
notifications.

(
b)
Liability
Insurance
(
I)
Data
item:

Sections
264.147(
a)(
1),
264.147(
b)(
1),
265.147(
a)(
1),
and
265.147(
b)(
1)
require
owners
or
operators
to
submit
a
duplicate
of
the
endorsement
or
certificate
of
insurance,
and,
if
requested
by
the
Regional
Administrator,
a
duplicate
of
the
insurance
policy.

(
ii)
Respondent
activities:

Owners
or
operators
will
need
to
engage
in
the
following
activities
to
complete
the
requirements
for
this
option:

C
Reading
the
regulations;

C
Obtaining
an
insurance
policy
amended
by
attachment
of
the
Hazardous
Waste
Facility
Liability
Endorsement
or
evidenced
by
a
Certificate
of
Liability
Insurance
and
meeting
other
specifications
outlined
in
§
§
264.147(
a)(
1),
264.147(
b)(
1),
265.147(
a)(
1),
or
265.147(
b)(
1);

C
Submitting
a
signed
duplicate
original
of
the
endorsement
or
the
certificate
of
insurance
to
the
Regional
Administrator,
or
Regional
Administrators
if
the
facilities
are
located
in
more
than
one
Region;
and
47
C
If
requested
by
the
Regional
Administrator,
submitting
a
signed
duplicate
original
of
the
insurance
policy
(
for
new
facilities
this
must
be
submitted
at
least
sixty
days
before
receiving
hazardous
waste
for
treatment,
storage,
or
disposal).

(
c)
Variance
of
Financial
Responsibility
Regulations
(
i)
Data
item:

Section
265.147(
c)
provides
for
a
variance
from
the
financial
responsibility
requirements
if
the
owner
or
operator
can
demonstrate
that
the
required
levels
of
financial
responsibility
are
not
consistent
with
the
degree
and
duration
of
risk
associated
with
treatment,
storage,
or
disposal
at
the
facility.
The
request
for
a
variance
must
be
submitted
in
writing
to
EPA,
and
may
include
technical
and
engineering
information
that
is
deemed
necessary
by
the
Regional
Administrator.

(
ii)
Respondent
Activity:

Owners
and
operators
that
wish
to
apply
for
a
variance
must
prepare
and
submit
information
in
support
of
the
variance.

(
d)
Financial
Test
for
Liability
Coverage
(
i)
Data
items:

Sections
264.147(
f)
and
265.147(
f)
allow
owners
or
operators
to
satisfy
liability
requirements
by
passing
a
financial
test.
Data
items
for
these
sections
include:

C
A
letter
signed
by
the
owner's
or
operator's
chief
financial
officer
and
worded
as
specified
in
§
264.151(
g);
if
the
financial
test
is
also
being
used
to
demonstrate
closure
or
postclosure
financial
assurance,
the
letter
specified
in
§
264.151(
g)
must
be
submitted
to
cover
both
forms
of
financial
responsibility;

C
A
copy
of
an
independent
certified
public
accountant's
report
on
examination
of
the
owner's
or
operator's
financial
statements
for
the
latest
completed
fiscal
year;

C
A
special
report
from
the
owner's
or
operator's
independent
certified
public
accountant
to
the
owner
or
operator
covering
the
specifications
outlined
in
§
§
264.147(
f)(
3)(
iii)
and
265.147(
f)(
3)(
iii);

C
If
an
extension
of
submission
of
the
above
documents
is
sought,
a
letter
from
the
owner's
or
operator's
chief
financial
officer
to
the
Regional
Administrator
of
each
Region
in
which
facilities
to
be
covered
under
the
financial
test
are
located.
This
letter,
allowed
only
under
§
265.147(
f)(
4),
must
contain
the
following
data
items:

­­
A
request
for
the
extension;

­­
A
certification
that
the
chief
financial
officer
believes
that
the
owner
or
operator
meets
the
criteria
of
the
financial
test;
48
­­
For
each
facility
to
be
covered
by
the
test,
the
EPA
identification
number,
name,
address,
and
current
closure
and
post­
closure
cost
estimates
to
be
covered
by
the
test;

­­
A
specification
of
the
date
(
no
later
than
ninety
days
after
the
end
of
such
fiscal
year)
when
the
owner
or
operator
will
submit
the
documents
specified
in
§
§
265.147(
f)(
3);
and
­­
A
certification
that
the
year­
end
financial
statements
of
the
owner
or
operator
for
such
fiscal
year
will
be
audited
by
an
independent
certified
public
accountant;

C
Annual
updates
of
the
above
data
items;
and
C
Should
the
owner
or
operator
fail
the
test
and
no
longer
meet
the
requirements
of
§
§
264.147(
f)(
1)
or
265.147(
f)(
1),
evidence
of
insurance
obtained
for
the
entire
amount
of
required
liability
coverage
specified
in
§
§
264.147
and
265.147.

(
ii)
Respondent
activities:

Owners
or
operators
will
need
to
engage
in
the
following
respondent
activities
in
order
to
collect
the
data
required
by
these
sections:

C
Reading
the
regulations;

C
Writing
the
letter
signed
by
the
chief
financial
officer;

C
Submitting
the
following
documents
to
the
Regional
Administrator
(
for
new
facilities,
these
documents
must
be
submitted
at
least
sixty
days
prior
to
receiving
hazardous
waste
for
treatment,
storage,
or
disposal):

­­
The
letter
signed
by
the
chief
financial
officer;

­­
A
copy
of
an
independent
certified
public
accountant's
report;
and
­­
The
special
report
from
an
independent
certified
public
accountant;

C
Submitting
updated
information
annually;
and
C
Should
the
owner
or
operator
fail
the
test
and
no
longer
meet
§
§
264.147
or
265.147
requirements,
submitting
evidence
to
the
Regional
Administrator
of
insurance
obtained
for
the
entire
amount
of
required
liability
coverage
specified
in
these
sections.

(
e)
Guarantee
for
Liability
Coverage
(
i)
Data
items:
49
Sections
264.147(
g)
and
265.147(
g)
allow
owners
or
operators
to
meet
liability
requirements
by
obtaining
a
written
guarantee,
under
the
conditions
specified
in
§
§
264.147(
g)(
2)
and
265.147(
g)(
2).
Data
items
for
this
option
include:

C
A
certified
copy
of
a
written
guarantee
from
the
direct
or
higher­
tier
parent
corporation
of
the
owner
or
operator,
a
firm
whose
parent
corporation
is
the
parent
corporation
of
the
owner
or
operator,
or
a
firm
with
a
"
substantial
business
relationship"
with
the
owner
or
operator;

C
In
the
case
of
corporations
incorporated
in
the
United
States,
a
written
statement
from
applicable
Attorney(
s)
General
or
Insurance
Commissioners
to
EPA
indicating
that
a
guarantee
executed
as
described
in
the
regulations
is
a
legally
valid
and
enforceable
obligation
in
that
State
(
§
§
264.147(
g)(
2)
and
265.147(
g)(
2));

C
In
the
case
of
corporations
incorporated
outside
the
United
States,
identification
by
the
non­
U.
S.
corporation
of
a
registered
agent
for
service
of
process
in
each
State
in
which
the
facility
covered
by
the
guarantee
is
located
and
in
the
State
in
which
it
has
its
principal
place
of
business,
and
a
written
statement
from
applicable
Attorney(
s)
General
or
Insurance
Commissioner
of
each
applicable
State
indicating
that
a
guarantee
executed
as
described
in
the
regulations
is
a
legally
valid
and
enforceable
obligation
in
that
State
(
§
§
264.147(
g)(
2)
and
265.147(
g)(
2));
and
C
A
letter
from
the
guarantor's
chief
financial
officer
as
specified
in
§
§
264.147(
f)(
3)
and
265.147(
f)(
3)
that
demonstrates
that
the
guarantor
has
passed
the
financial
test.

(
ii)
Respondent
activities:

Owners
or
operators
will
need
to
engage
in
the
following
respondent
activities
in
order
to
collect
the
data
required
by
these
sections:

C
Reading
the
regulations;

C
Obtaining
a
written
guarantee
from
the
direct
or
higher­
tier
parent
corporation
of
the
owner
or
operator,
a
firm
whose
parent
corporation
is
the
parent
corporation
of
the
owner
or
operator,
or
a
firm
with
a
"
substantial
business
relationship"
with
the
owner
or
operator;

C
Submitting
a
certified
copy
of
this
written
guarantee
to
the
Regional
Administrator
along
with
the
items
specified
in
§
§
264.147(
f)(
3)
and
265.147(
f)(
3);
and
C
Submitting
a
letter
from
the
guarantor's
chief
financial
officer
as
specified
in
§
§
264.147(
f)(
3)
and
265.147(
f)(
3)
that
demonstrates
that
the
guarantor
has
passed
the
financial
test.

(
f)
Letter
of
Credit
for
Liability
Coverage
(
i)
Data
items:
50
Sections
264.147(
h)
and
265.147(
h)
allow
owners
or
operators
to
satisfy
financial
requirements
for
liability
by
obtaining
the
following
data
item:

C
An
irrevocable
standby
letter
of
credit
that
conforms
to
applicable
requirements
and
is
submitted
from
a
financial
institution
with
the
authority
to
issue
letters
of
credit,
whose
letter
of
credit
operations
are
regulated
and
examined
by
a
Federal
or
State
agency,
and
whose
letters
of
credit
meet
the
requirements
of
§
264.147(
h).

(
ii)
Respondent
activities:

Owners
or
operators
using
this
option
to
satisfy
financial
assurance
for
liability
will
need
to
engage
in
the
following
activities:

C
Reading
the
regulations;

C
Obtaining
the
standby
letter
of
credit
described
above;
and
C
Submitting
a
copy
of
this
letter
of
credit
to
the
Regional
Administrator.

(
g)
Surety
Bond
for
Liability
Coverage
(
i)
Data
item:

Sections
264.147(
i)
and
265.147(
i)
allow
owners
or
operators
to
satisfy
financial
requirements
for
liability.
Under
sections
264.147(
i)(
4)
and
265.147(
i)(
4),
a
surety
bond
may
be
used
to
satisfy
the
requirements
of
this
section
only
if
the
applicable
Attorneys
General
or
Insurance
Commissioners
have
submitted
a
written
statement
to
EPA
that
a
surety
bond
executed
as
described
in
the
regulations
is
a
legally
valid
and
enforceable
obligation
in
that
State.
The
owner/
operator
must
obtain
a
surety
bond
(
and
other
information,
where
applicable)
that
conforms
to
the
requirements
specified
in
§
§
264.147(
i)
and
265.147(
i).

(
ii)
Respondent
activities:

Owners
or
operators
using
this
option
to
satisfy
financial
assurance
for
liability
will
need
to
engage
in
the
following
activities:

C
Reading
the
regulations;

C
Obtaining
the
surety
bond
described
above;
and
C
Submitting
a
copy
of
this
surety
bond
to
the
Regional
Administrator.

(
h)
Trust
Fund
for
Liability
Coverage
(
i)
Data
item:
51
Sections
264.147(
j)
and
265.147(
j)
allow
owners
or
operators
to
satisfy
financial
requirements
for
liability
by
establishing
a
trust
fund
that
conforms
to
the
requirements
specified
in
§
§
264.147(
j)
and
265.147(
j).

(
ii)
Respondent
activities:

Owners
or
operators
using
this
option
to
satisfy
financial
assurance
for
liability
will
need
to
engage
in
the
following
activities:

C
Reading
the
regulations;

C
Establishing
the
trust
fund
described
above;
and
C
Submitting
an
originally
signed
duplicate
of
the
trust
agreement
to
the
Regional
Administrator.

(
i)
Adjustments
by
the
Regional
Administrator
(
i)
Data
items:

Sections
264.147(
d)
and
265.147(
d)
allow
Regional
Administrators
to
adjust
the
level
of
financial
responsibility
required
under
§
§
264.147
and
265.147
in
order
to
protect
human
health
and
the
environment.
Respondents
will
need
to
furnish
the
following
data
items
should
Regional
Administrators
make
such
a
determination:

C
Any
information
which
the
Regional
Administrator
requests
to
determine
whether
cause
exists
for
such
adjustments
of
level
or
type
of
coverage;
and
C
If
the
Regional
Administrator
decides
to
adjust
the
level
or
type
of
coverage,
the
data
elements
necessary
for
a
permit
modification
(
detailed
in
ICR
#
1573).

(
ii)
Respondent
activities:

Owners
or
operators
will
need
to
engage
in
the
following
activities
in
order
to
satisfy
the
information
collection
requirements
of
this
section:

C
Reading
the
regulations;

C
Submitting
to
the
Regional
Administrator
any
requested
information;
and
°
Preparing,
writing,
and
submitting
a
permit
modification
if
the
Regional
Administrator
decides
to
adjust
level
or
type
of
coverage
(
specific
respondent
activities
for
permit
modifications
are
detailed
in
ICR
#
1573).

(
5)
Incapacity
of
Owners
or
Operators,
Guarantors,
or
Financial
Institutions
(
i)
Data
item:
52
Sections
264.148
and
265.148
require
owners
or
operators
to
submit,
if
applicable,
a
notification
of
the
commencement
of
a
voluntary
or
involuntary
proceeding
under
Title
11
(
Bankruptcy),
U.
S.
Code,
naming
the
owner
or
operator
as
debtor
(
if
the
guarantor
is
named
as
the
debtor,
the
collection
of
this
data
is
the
guarantor's
responsibility).

(
ii)
Respondent
activities:

Activities
for
this
data
collection
will
include:

C
Reading
the
regulations;
and
C
Submitting,
by
certified
mail,
a
notice
to
the
Regional
Administrator
indicating
the
commencement
of
bankruptcy
proceedings
in
which
the
owner
or
operator
or
guarantor
is
named
as
debtor.

(
6)
Use
of
State­
Required
Mechanisms
(
i)
Data
items:

Sections
264.149
and
265.149
allow
owners
or
operators
to
use
State­
required
financial
assurance
mechanisms
to
meet
§
§
264.143,
264.145,
264.147,
265.143,
265.145,
or
265.147
requirements.
Data
items
for
this
option
include:

C
A
letter
from
the
owner
or
operator
requesting
that
the
State­
required
mechanism
be
considered
acceptable
for
meeting
the
requirements
of
this
subpart;

C
Evidence
of
the
establishment
of
a
State­
required
mechanism,
including
the
following
information:

­­
The
facility's
EPA
identification
number,
name,
and
address;
and
­­
The
amount
of
funds
for
closure
or
post­
closure
care
or
liability
coverage
assured
by
the
mechanism;
and
C
Any
additional
information
required
by
the
Regional
Administrator
in
order
to
make
the
determination.

(
ii)
Respondent
activities:

Activities
for
this
data
collection
will
include:

C
Reading
the
regulations;
and
C
Submitting
to
the
Regional
Administrator:
­­
The
letter
from
the
owner
or
operator;

­­
Written
evidence
of
the
establishment
of
a
State­
required
financial
assurance
mechanism;
and
53
­­
Any
additional
information
requested
by
the
Regional
Administrator.

(
7)
State
Assumption
of
Responsibility
(
i)
Data
items:

Sections
264.150
and
265.150
require
owners
or
operators
to
notify
EPA
when
a
State
assumes
legal
responsibility
or
assures
availability
of
funds
for
an
owner's
or
operator's
compliance
with
the
closure,
post­
closure
care,
or
liability
requirements
of
this
part.
Data
items
to
be
collected
in
this
case
include:

C
A
letter
from
the
owner
or
operator
requesting
that
the
State's
assumption
of
responsibility
be
considered
acceptable
for
meeting
the
requirements
of
this
subpart;

C
A
letter
from
the
State
describing
the
nature
of
the
State's
assumption
of
responsibility,
including
the
following
information:

­­
The
facility's
EPA
identification
number,
name,
and
address;
and
­­
The
amount
of
funds
for
closure
or
post­
closure
care
or
liability
coverage
that
are
guaranteed
by
the
State;
and
C
Any
additional
information
which
the
Regional
Administrator
deems
necessary
to
make
the
determination
whether
the
State's
assumption
of
responsibility
is
acceptable.

(
ii)
Respondent
activities:

Activities
for
this
data
collection
will
include:

C
Reading
the
regulations;
and
C
Submitting
to
the
Regional
Administrator:

­­
The
letter
from
the
owner
or
operator;
and
­­
The
letter
from
the
State
describing
the
State's
assumption
of
responsibility
and
including
the
information
specified
above;
and
C
Submitting
any
additional
information
requested
by
the
Regional
Administrator.

(
8)
Subpart
F
and
G
Requirements
(
§
§
266.70
and
266.80)

Sections
266.70(
d)
and
266.80(
b)(
2)
explain
that
two
specific
groups
of
respondents
are
also
subject
to
Parts
264
and
265
financial
assurance
requirements:
54
C
Persons
who
generate,
transport,
or
store
recyclable
materials
that
are
reclaimed
to
recover
economically
significant
amounts
of
gold,
silver,
platinum,
palladium,
iridium,
osmium,
rhodium,
ruthenium,
or
any
combination
of
these;
and
C
Owners
or
operators
of
facilities
that
store
spent
lead
acid
batteries
before
reclaiming
them.

CONDITIONS
APPLICABLE
TO
ALL
PERMITS
(
i)
Data
items:

40
CFR
Part
270,
Subpart
C
specifies
conditions
applicable
to
all
permitted
facilities.
40
CFR
270.30(
h)
requires
owners
and
operators
of
permitted
facilities
to
furnish
any
relevant
information
requested
by
EPA
to
determine
whether
cause
exists
for
modifying,
revoking
and
reissuing,
or
terminating
a
permit,
or
to
determine
compliance
with
the
permit.
Section
270.30(
j)(
2)
and
(
3)
requires
permittees
to
retain
records
of
all
monitoring
information,
copies
of
all
reports
required
by
the
permit,
the
certification
required
by
§
264.73(
b)(
9),
and
records
of
all
data
used
to
complete
the
application
for
a
period
of
at
least
three
years
from
the
date
of
the
sample,
measurement,
report,
certification,
or
application.
[
These
requirements
are
burdened
in
the
section
entitled
"
Operating
Record"
of
this
ICR.]
In
addition,
section
270.30(
l)
specifies
the
following
reporting
requirements,
which
are
applicable
to
all
permitted
facilities:

C
Prompt
notice
of
planned
physical
alternations
or
additions
(
§
270.30(
l)(
1));

C
Notice
of
planned
changes
or
activities
which
may
result
in
noncompliance
with
permit
requirements
(
§
270.30(
l)(
2));

C
Letter
certifying
that
the
facility
has
been
constructed
or
modified
in
compliance
with
the
permit
(
§
270.30(
l)(
2)(
i);

C
Monitoring
reports,
submitted
at
the
intervals
specified
in
the
permit
(
§
270.30(
l)(
4));

C
Reports
of
compliance
or
noncompliance
with,
or
any
progress
reports
on,
interim
and
final
requirements
contained
in
any
compliance
schedule
of
the
permit,
submitted
no
later
than
14
days
following
each
schedule
date
(
§
270.30(
l)(
5));

C
A
report
containing
information
concerning
a
release
that
may
threaten
drinking
water
supplies
(
§
270.30(
l)(
6)(
i)(
A),
or
information
concerning
a
release,
fire,
or
explosion
which
could
threaten
human
health
or
the
environment
outside
the
facility
(
§
270.30(
l)(
6)(
i)(
B)),
within
24
hours
from
the
time
the
permittee
becomes
aware
of
the
circumstances.
Such
a
report
must
include
the
following
information:

­­
Name,
address,
and
telephone
number
of
the
owner
or
operator;

­­
Name,
address,
and
telephone
number
of
the
facility;

­­
Date,
time,
and
type
of
incident;

­­
Name
and
quantity
of
material(
s)
involved;
55
­­
The
extent
of
injuries,
if
any;

­­
An
assessment
of
actual
or
potential
hazards
to
the
environment
and
human
health
outside
the
facility;
and
­­
Estimated
quantity
and
disposition
of
recovered
material
that
resulted
from
the
incident.

C
A
written
notice
within
five
days
of
noncompliance,
or
a
written
report
within
15
days,
that
includes
a
description
of
the
noncompliance
and
its
cause,
the
period
of
noncompliance,
the
anticipated
time
the
noncompliance
is
expected
to
continue,
and
steps
taken
to
reduce,
eliminate,
and
prevent
reoccurrence
of
the
noncompliance
(
§
270.30(
l)(
6)(
iii);

C
Report
of
any
manifest
discrepancy,
as
required
by
§
264.72
(
§
270.30(
l)(
7).
[
This
requirement
is
burdened
in
"
Requirements
for
Generators,
Transporters,
and
Waste
Management
Facilities
Under
the
RCRA
Hazardous
Waste
Manifest
System",
ICR
#
801.];

C
Report
of
any
receipt
of
unmanifested
waste,
as
required
by
§
264.76
(
§
270.30(
l)(
8)).
[
This
requirement
is
burdened
in
"
Requirements
for
Generators,
Transporters,
and
Waste
Management
Facilities
Under
the
RCRA
Hazardous
Waste
Manifest
System",
ICR
#
801.];

C
A
biennial
report
covering
facility
activities,
as
required
by
§
264.75
(
§
270.30(
l)(
9)).
[
This
requirement
is
burdened
in
the
"
Hazardous
Waste
Report
ICR",
ICR
#
976.]

C
Report
of
other
noncompliance
not
submitted
with
monitoring
reports,
compliance
schedule
reports,
and
reports
of
releases,
fires,
or
explosions
(
§
270.30(
l)(
10));
and
C
For
cases
where
the
permittee
becomes
aware
that
he
or
she
failed
to
submit
any
relevant
facts
in
a
permit
application,
or
submitted
incorrect
information
in
any
permit
application
or
report,
corrected
or
new
information
(
§
270.30(
l)(
11)).

(
ii)
Respondent
activities:

In
order
to
comply
with
40
CFR
Part
270,
Subpart
C,
owners
and
operators
of
permitted
facilities
must
perform
the
following
activities:

C
Read
the
regulations;
and
C
Prepare
and
submit
the
required
information
as
described
above.
56
5.
THE
INFORMATION
COLLECTED­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
The
following
subsections
discuss
how
EPA
will
collect
the
information,
what
activities
EPA
will
perform
once
the
information
has
been
received,
and
how
EPA
will
manage
the
information
it
collects.
The
subsections
also
include
a
discussion
of
how
the
information
collection
requirements
affect
small
entities.

5(
a)
AGENCY
ACTIVITIES
GENERAL
FACILITY
OPERATING
STANDARDS
Although
the
information
is
not
formally
submitted
to
EPA,
EPA
may
review
information
collected
from
the
requirements
outlined
in
Subpart
E
during
facility
inspections.
Therefore,
this
analysis
assumes
that
the
Agency
will
spend
a
minimal
amount
of
review
time
annually
at
each
facility.

The
requirements
for
the
foreign
shipment
import
report,
however,
state
that
owners
or
operators
must
notify
the
Regional
Administrator
of
the
anticipated
collection
of
hazardous
waste.
In
turn,
the
Agency
must
review
the
information
included
in
the
notification.

RECORDKEEPING
REQUIREMENTS
Only
one
Agency
activity
is
associated
with
the
operating
record
requirements:
on­
site
review
of
the
record.

CONTINGENCY
PLAN
AND
EMERGENCY
REPORTING
REQUIREMENTS
(
1)
Contingency
Plan
Two
Agency
activities
are
associated
with
the
development
and
amendment
of
the
contingency
plan:
reviewing
the
contingency
plan
during
on­
site
inspections
and
reviewing
revisions
to
the
contingency
plan.
(
2)
Emergency
Reporting
Requirements
Agency
activities
associated
with
emergency
reporting
requirements
include
reviewing
documents
in
the
owners'
or
operators'
and
emergency
coordinators'
emergency
reports.

RELEASES
FROM
SOLID
WASTE
MANAGEMENT
UNITS
There
are
two
Agency
activities
associated
with
ground­
water
monitoring
demonstrations
and
procedures:
reviewing
demonstrations
to
terminate
the
compliance
period
and
review
and
approval
of
proposed
sampling
methods
and
intervals.

CLOSURE
AND
POST­
CLOSURE
REQUIREMENTS
Agency
activities
associated
with
the
regulations
promulgated
in
40
CFR,
Parts
264
and
265,
Subpart
G,
include
reviewing
the
following
data
items:
57
C
Closure
plans;

C
Closure
plan
amendment
notifications;

C
Partial/
final
closure
notifications;

C
Closure
extensions
and
allowances;

C
Survey
plats;

C
Post­
closure
plans;

C
Post­
closure
plan
amendment
notifications;

C
Post­
closure
plan
modifications;

C
Hazardous
waste
disposal
records;
and
C
Post­
closure
permit
modifications.

FINANCIAL
REQUIREMENTS
EPA
uses
the
cost
estimates
and
financial
assurance
mechanisms
to
ensure
compliance
with
Subpart
H.
In
the
event
that
an
owner
or
operator
is
unable
or
unwilling
to
perform
closure
or
post­
closure
activities
or
to
pay
third­
party
damages,
EPA
will
draw
upon
the
mechanisms.
The
cost
estimates
are
normally
retained
by
the
owner
or
operator
during
interim
status;
they
are
submitted
to
the
Region
or
authorized
State
as
part
of
the
permit
process.

The
financial
assurance
instruments
for
closure,
post­
closure
care,
and
liability
coverage,
with
standard
wording,
are
submitted
by
the
owner
or
operator
(
or
the
third­
party
financial
entity)
to
the
Region
or
authorized
State
that
serves
the
area
and
where
the
facility
is
located.
These
submissions
must
be
made
by
the
effective
date
of
the
regulations
for
existing
facilities
­­
July
6,
1982
(
Assurance)
and
July
15,
1982
(
Liability)
­­
and
sixty
days
before
the
initial
receipt
of
hazardous
wastes
at
new
facilities.
There
was
a
phase­
in
period
for
nonsudden
coverage
for
existing
facilities.
January
16,
1985
was
the
final
phase­
in
date.

When
financial
assurance
information
is
submitted,
EPA
conducts
a
review
for
completeness,
then
enters
the
information
into
the
RCRIS
data
base.
The
EPA
Regional
or
State
offices
establish
a
file
for
each
applicant
that
contains
the
submissions.
The
financial
instruments
are
maintained
in
a
secure
area.

Submissions
are
tabulated
in
the
EPA
Regional
Offices
and
Headquarters
and
are
used
by
Agency
management
to
oversee
implementation
of
the
RCRA
financial
responsibility
requirements.
The
information
is
also
shared
with
States
to
assist
them
in
implementing
their
hazardous
waste
management
programs.
There
are
no
plans
to
publish
information
obtained
under
the
Subpart
H
financial
requirements.

CONDITIONS
APPLICABLE
TO
ALL
PERMITS
58
EPA
reviews
all
information
submitted
at
intervals
specified
in
the
permit.
This
information
includes
monitoring
reports
and
reports
on
compliance
or
noncompliance
with
compliance
schedules.
EPA
also
reviews
information
that
may
be
submitted
on
occasion
by
facilities,
if
necessary.
Such
information
includes
notices
of
planned
physical
alterations
or
additions;
notices
of
planned
changes
or
activities;
letters
certifying
compliance;
information
concerning
releases,
fires,
or
explosions;
reports
of
other
noncompliance;
and
corrected
or
new
information.

5(
b)
COLLECTION
METHODOLOGY
AND
MANAGEMENT
To
collect
and
analyze
the
information
discussed
in
this
ICR.,
EPA
keeps
records
of
and
reviews
all
of
the
information
submitted.
Authorized
States
and
EPA
Regions
enter
the
information
into
electronic
data
base
systems.
States
coordinate
with
the
EPA
Regions
and
OSW
Headquarters
to
supply
EPA
with
the
data
reported
for
inclusion
in
the
RCRAInfo
national
database.

5(
c)
SMALL
ENTITY
FLEXIBILITY
When
promulgating
the
regulations
covered
under
this
ICR,
EPA
considered
developing
separate
and
simplified
requirements
for
small
businesses.
Since
small
facilities
conduct
operations
that
are
equally
as
hazardous
to
the
environment
as
those
conducted
by
larger
facilities,
EPA
determined
that
small
businesses
should
be
required
to
comply
with
the
same
regulations
as
large
businesses.
As
a
result
of
this
interpretation,
no
specific
requirements
are
outlined
for
smaller
facilities.

5(
d)
COLLECTION
SCHEDULE
GENERAL
FACILITY
STANDARDS
The
reporting
requirements
outlined
in
the
regulations
will
vary
according
to
individual
facility
circumstances
(
e.
g.,
when
receiving
hazardous
waste
from
a
foreign
source).

RECORDKEEPING
REQUIREMENTS
Since
the
operating
record
is
maintained
at
the
facility,
discussion
of
a
collection
schedule
is
not
applicable.
Copies
of
records
of
waste
disposal
are
submitted
to
EPA
upon
closure
of
the
facility.

CONTINGENCY
PLAN
AND
EMERGENCY
REPORTING
REQUIREMENTS
The
contingency
plan
is
collected
when
the
permittee
submits
the
Part
B
permit
application.
A
discussion
of
the
contingency
plan
collection
schedule
for
permitted
facilities
is
included
in
the
Hazardous
Waste
Part
B
Permit
Applications,
Special
Permits,
and
Permit
Modifications
ICR
(#
1573).
Since
interim
status
facilities
are
not
required
to
submit
their
contingency
plans
to
EPA,
discussion
of
a
collection
schedule
for
these
facilities
is
not
applicable.

The
owner
or
operator
must
submit
a
written
report
of
any
incident
that
requires
implementation
of
the
contingency
plan
within
15
days
after
the
incident
occurs.
The
emergency
coordinator
must
immediately
notify
the
appropriate
authorities
of
an
imminent
or
actual
emergency
situation.

CLOSURE
AND
POST­
CLOSURE
REQUIREMENTS
59
Permitted
facilities
submit
their
closure
and
post­
closure
plans
to
EPA
when
submitting
a
Part
B
permit
application.
A
discussion
addressing
collection
schedules
for
permitted
facilities
is
included
in
the
Hazardous
Waste
Part
B
Permit
Applications,
Special
Permits,
and
Permit
Modifications
ICR
(#
1573).

Interim
status
closure
and
post­
closure
plans
must
be
submitted
according
to
the
following
schedules:

C
The
owner
or
operator
must
submit
the
closure
plan
to
the
Regional
Administrator
at
least
180
days
prior
to
the
date
on
which
he
or
she
expects
to
begin
closure
of
the
first
surface
impoundment,
waste
pile,
land
treatment,
or
landfill
unit,
or
final
closure
if
it
involves
such
a
unit,
whichever
is
earlier;

C
The
owner
or
operator
must
submit
the
closure
plan
to
the
Regional
Administrator
at
least
45
days
prior
to
the
date
on
which
he
or
she
expects
to
begin
final
closure
of
a
facility
with
only
tanks,
container
storage,
or
incinerator
units;

C
Owners
or
operators
with
approved
closure
plans
must
notify
the
Regional
Administrator
in
writing
at
least
60
days
prior
to
the
date
on
which
they
expect
to
begin
closure
of
a
surface
impoundment,
waste
pile,
landfill,
or
land
treatment
unit,
or
final
closure
of
a
facility
involving
such
a
unit;

C
Owners
and
operators
with
approved
closure
plans
must
notify
the
Regional
Administrator
in
writing
at
least
45
days
prior
to
the
date
on
which
they
expect
to
begin
final
closure
of
a
facility
with
only
tanks,
container
storage,
or
incinerator
units;

C
The
owner
or
operator
must
submit
the
closure
plan
to
the
Regional
Administrator
no
later
than
15
days
after:

­­
Termination
of
interim
status
except
when
a
permit
is
issued
simultaneously
with
termination
of
interim
status;
or
­­
Issuance
of
a
judicial
decree
or
final
order
under
§
3008
of
RCRA
to
cease
receiving
hazardous
wastes
or
close
C
If
the
Regional
Administrator
does
not
approve
the
closure
plan,
he
or
she
shall
provide
the
owner
or
operator
with
a
detailed
written
statement
of
reasons
for
the
refusal
and
the
owner
or
operator
must
modify
the
plan
or
submit
a
new
plan
for
approval
within
30
days
after
receiving
such
written
statement;

C
An
owner
or
operator
of
a
surface
impoundment
or
waste
pile
that
intends
to
remove
all
hazardous
waste
at
closure
must
prepare
a
post­
closure
plan
and
submit
it
to
the
Regional
Administrator
within
90
days
of
the
date
that
the
owner
or
operator
or
Regional
Administrator
determines
that
the
hazardous
waste
management
unit
or
facility
must
be
closed
as
a
landfill,
subject
to
the
requirements
of
§
§
265.117
through
265.120;

C
If
an
owner
or
operator
of
a
surface
impoundment
or
a
waste
pile
who
intended
to
remove
all
hazardous
wastes
at
closure
in
accordance
with
§
265.228(
b)
or
§
265.258(
a)
is
required
to
close
as
a
landfill
in
accordance
with
§
265.310,
the
owner
or
operator
must
submit
a
60
post­
closure
plan
within
90
days
of
the
determination
by
the
owner
or
operator
or
Regional
Administrator
that
the
unit
must
be
closed;

C
If
the
Regional
Administrator
determines
that
an
owner
or
operator
of
a
surface
impoundment
or
waste
pile
who
intended
to
remove
all
hazardous
wastes
at
closure
must
close
the
facility
as
a
landfill,
the
owner
or
operator
must
submit
a
post­
closure
plan
for
approval
to
the
Regional
Administrator
within
90
days
of
the
determination;

C
The
owner
or
operator
must
submit
the
post­
closure
plan
to
the
Regional
Administrator
at
least
180
days
before
the
date
he
or
she
expects
to
begin
partial
or
final
closure
of
the
first
hazardous
waste
disposal
unit.
The
date
he
"
expects
to
begin
closure"
of
the
first
hazardous
waste
disposal
unit
must
be
either
within
30
days
after
the
date
on
which
the
hazardous
waste
management
unit
receives
the
known
final
volume
of
hazardous
waste
or,
if
there
is
a
reasonable
possibility
that
the
hazardous
waste
management
unit
will
receive
additional
hazardous
wastes,
no
later
than
one
year
after
the
date
on
which
the
unit
received
the
most
recent
volume
of
hazardous
wastes;
and
C
The
owner
or
operator
must
submit
his
post­
closure
plan
to
the
Regional
Administrator
no
later
than
15
days
after:

­­
Termination
of
interim
status
except
when
a
permit
is
issued
simultaneously
with
termination
of
interim
status;
or
­­
Issuance
of
a
judicial
decree
or
final
order
under
§
3008
of
RCRA
to
cease
receiving
hazardous
wastes
or
close.

Both
interim
status
and
permitted
facilities
are
required
to
request
approval
for
post­
closure
plan
modifications.
Since
permitted
facilities
must
submit
permit
modifications
to
authorize
changes
to
their
post­
closure
plans,
a
discussion
addressing
scheduling
requirements
for
permitted
facilities'
modifications
to
the
post­
closure
plan
is
included
in
ICR
#
1573.
The
following
is
a
schedule
for
interim
status
facilities:

C
An
owner
or
operator
with
an
approved
post­
closure
plan
must
submit
the
modified
plan
to
the
Regional
Administrator
at
least
60
days
prior
to
the
proposed
change
in
facility
design
or
operation,
or
no
more
than
60
days
after
an
unexpected
event
has
occurred
which
has
affected
the
post­
closure
plan;
and
C
If
the
Regional
Administrator
requests
modifications
to
the
post­
closure
plan,
the
owner
or
operator
with
an
approved
post­
closure
plan
must
submit
the
modified
plan
to
the
Regional
Administrator
no
later
than
60
days
of
the
request
from
the
Regional
Administrator.

Both
interim
status
and
permitted
facilities
are
required
to
submit
closure
certifications,
survey
plats,
and
post­
closure
notices
according
to
the
following
schedules:

C
The
owner
or
operator
must
submit
a
certification
of
closure
to
the
Regional
Administrator
within
60
days
of
completion
of
closure
for
each
hazardous
waste
surface
impoundment,
waste
pile,
land
treatment,
and
landfill
unit
and
within
60
days
of
final
closure;
61
C
No
later
than
the
submission
of
the
certification
of
closure,
the
owner
or
operator
must
submit
to
the
Regional
Administrator
a
survey
plat;

C
If
the
Regional
Administrator
does
not
approve
the
post­
closure
plan,
he
shall
provide
the
owner
or
operator
with
a
detailed
written
statement
of
reasons
for
the
refusal
and
the
owner
or
operator
must
modify
the
plan
or
submit
a
new
plan
for
approval
within
30
days
after
receiving
such
written
statement;

C
The
owner
or
operator
must
submit
a
post­
closure
notice
to
the
Regional
Administrator
within
60
days
of
certification
of
closure
for
each
hazardous
waste
disposal
unit;

C
No
later
than
60
days
after
certification
of
closure
of
each
hazardous
waste
disposal
unit,
the
owner
or
operator
must
submit
to
the
Regional
Administrator
a
record
of
the
type,
location,
and
quantity
of
hazardous
wastes
disposed
of
within
each
cell
or
other
disposal
unit
of
the
facility;
and
C
No
later
than
60
days
after
the
completion
of
the
established
post­
closure
care
period
for
each
hazardous
waste
disposal
unit,
the
owner
or
operator
must
submit
to
the
Regional
Administrator
a
certification
that
the
post­
closure
care
period
for
the
unit
was
performed
in
accordance
with
the
specifications
in
the
approved
post­
closure
plan.

FINANCIAL
REQUIREMENTS
For
closure
and
post­
closure
cost
estimates,
owners
or
operators
must
prepare
initial
cost
estimates
for
activities
identified
in
the
closure
and
post­
closure
plans.
Thereafter,
owners
or
operators
must
provide
annual
adjustments
of
these
cost
estimates
to
account
for
inflation.
Also,
owners
or
operators
may
be
required
to
prepare
new
cost
estimates,
if
changes
in
the
closure
or
post­
closure
plan
increase
closure
or
post­
closure
costs.
This
burden
will
vary
from
facility
to
facility.

For
closure
and
post­
closure
care
financial
instruments,
owners
or
operators
must
initially
establish
a
financial
instrument(
s)
assuring
the
cost
of
closure
and
post­
closure
care.
Thereafter,
owners
or
operators
must
annually
check
the
amount
covered
by
the
instrument(
s)
to
make
sure
it
equals
the
adjusted
cost
estimate,
and
change
the
amount
assured
accordingly.

For
liability
coverage
requirements,
owners
or
operators
of
facilities
identified
in
§
§
264.147
and
265.147
must
initially
demonstrate
liability
coverage
for
sudden
and
nonsudden
accidents
during
the
facilities'
active
life.
Some
of
the
financial
instruments
for
liability
coverage
require
additional
reporting
on
an
annual
basis;
for
example,
owners
or
operators
must
annually
submit
documentation
to
EPA
supporting
the
use
of
the
financial
test
or
guarantee.
Furthermore,
owners
or
operators
may
also
have
to
provide
information
due
to
varying
circumstances;
for
example,
whenever
a
claim
for
bodily
injury
or
property
damages
caused
by
a
hazardous
waste
treatment,
storage,
or
disposal
facility
is
made.

CONDITIONS
APPLICABLE
TO
ALL
PERMITS
EPA
collects
information
from
permitted
facilities
at
intervals
specified
in
the
permit.
EPA
may
also
collect
other
information
if
the
Agency
determines
that
it
needs
information
to
determine
whether
a
permit
should
be
terminated,
revoked
and
reissued,
or
modified.
EPA
may
collect
additional
information
from
permitted
facilities
if
noncompliance
with
permit
conditions
occurs.
62
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
ESTIMATING
RESPONDENT
BURDEN
EPA
estimated
respondent
burden
hours
associated
with
all
of
the
requirements
covered
in
this
ICR
in
Exhibits
1
through
8.
The
exhibits
address
the
following
requirements:

C
Exhibit
1
­
General
facility
standards;

C
Exhibit
2
­
Operating
record
requirements;

C
Exhibit
3
­
Contingency
plan
and
emergency
procedure
requirements;

C
Exhibit
4
­
Requirements
for
releases
from
solid
waste
management
units;

C
Exhibit
5
­
Closure
and
post­
closure
requirements;

C
Exhibit
6
­
Financial
requirements;

C
Exhibit
7
­
Conditions
applicable
to
all
permits;
and
C
Exhibit
8
­
Total
respondent
burden
and
costs.

Exhibits
1
through
7
present
the
number
of
hours
required
to
conduct
each
individual
information
collection
activity
and
the
cost
associated
with
that
activity.
Exhibit
8
presents
annual
respondent
bottom­
line
burden
hours
and
costs
for
all
information
collection
requirements
in
this
ICR.

6(
b)
ESTIMATING
RESPONDENT
COSTS
LABOR
COSTS
EPA
estimates
an
average
hourly
respondent
labor
cost
(
including
overhead)
of
$
116
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
factor
of
2.3
for
non­
legal
staff
and
3.0
for
legal
staff
to
derive
their
loaded
hourly
rates.
Using
the
burden
hours
discussed
in
Section
6(
a)
and
the
wage
rates
outlined
in
this
section,
Exhibit
1
illustrates
the
labor
costs
associated
with
all
the
information
collection
requirements
covered
in
this
ICR.

CAPITAL
COSTS
EPA
estimates
that
all
new
facilities
and
facilities
with
new
Part
B
permits
will
incur
capital
costs
associated
with
purchasing
file
storage
systems
for
maintaining
records.
EPA
realizes
that
facilities
will
likely
use
different
and
various
file
storage
systems
(
e.
g.,
file
cabinets,
CD­
ROM,
off­
site
storage,
etc)
and
store
their
files
on
different
media
(
paper,
microfiche,
electronic
files,
etc).
For
purposes
of
estimating
these
capital
costs
across
all
facilities,
EPA
has
made
the
conservative
assumption
that
every
facility
will
store
their
files
in
paper
form
in
file
cabinets.
63
In
addition,
EPA
estimates
that
during
the
facilities'
operating
and
post­
closure
periods
each
facility
will
store
an
average
48,000
pieces
of
paper.
Therefore,
the
average
facility
will
need
to
purchase
three
5­
drawer
lateral
file
cabinets
that
each
hold
16,000
pieces
of
paper.
As
the
current
market
price
for
such
a
file
cabinet
is
$
549,
each
facility
would
therefore
purchase
$
1,647
worth
of
file
cabinets.

To
annualize
this
capital
cost
of
$
1,647,
EPA
assumed
a
discount
rate
of
7
percent
and
a
discount
period
of
15
years
(
based
on
the
average
life
of
file
cabinets).
As
such,
the
present
value
factor
for
this
discount
rate
and
period
would
be
9.1079.
Thus,
EPA
estimates
the
annualized
net
present
value
of
this
capital
cost
as
$
180.83
per
facility.

As
most
of
the
recordkeeping
in
this
ICR
is
associated
with
paperwork
activities
listed
in
Exhibit
2,
EPA
added
an
activity
for
purchasing
file
storage
systems
at
the
end
of
this
exhibit.
Even
though
there
are
additional
recordkeeping
activities
in
Exhibit
1,
EPA
accounts
for
all
file
maintenance
capital
costs
in
this
one
exhibit
and
line
item.
As
such,
EPA
multiplied
this
annualized
capital
cost
over
all
new
facilities
for
a
total
annualized
capital
cost
of
$
12,658.

OPERATION
AND
MAINTENANCE
COSTS
EPA
also
estimates
that
facilities
will
incur
operations
and
maintenance
(
O&
M)
costs
such
as
postage
costs
for
submitting
information
to
EPA,
purchased
material
costs,
and
various
lump­
sum
purchased
service
costs.
These
O&
M
costs
are
expected
to
be
incurred
on
an
ongoing,
annual,
or
periodic
basis
per
the
associated
regulatory
requirement
and
assumptions
in
this
ICR.

As
shown
in
all
exhibits,
postage
costs
are
estimated
at
$
0.37
per
one
ounce
letter,
$
4.14
per
submittal
for
all
other
submittals
weighing
up
to
two
pounds
and
sent
by
priority
mail,
and
$
9.75
per
submittal
that
must
be
sent
by
registered,
priority
mail.
In
Exhibit
1,
EPA
estimates
purchased
material
costs/
and
or
lump­
sum
purchased
service
costs
for
waste
analysis,
specifically
$
750
per
analysis
for
noncommercial
facilities
and
$
400
per
analysis
for
commercial
facilities.
In
Exhibit
5,
EPA
estimates
lumpsum
purchased
service
costs
for
certain
inspections
and/
or
certifications
that
must
be
completed
by
independent
professionals,
specifically
$
1,000
per
inspection/
certification
by
an
independent
registered
professional
engineer
and
$
750
per
survey/
certification
by
a
professional
land
surveyor.

6(
c)
ESTIMATING
AGENCY
BURDEN
AND
COST
EPA
estimates
annual
Agency
burden
hours
and
costs
associated
with
all
the
requirements
covered
in
this
ICR
in
Exhibit
9.
Based
on
a
2005
GS
pay
schedule,
EPA
estimates
an
average
hourly
Regional
labor
cost
of
$
87.01
for
legal
staff,
$
76.77
for
managerial
staff,
$
55.23
for
technical
staff,
and
$
23.55
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.
EPA
multiplied
hourly
rates
by
the
standard
government
overhead
factor
of
1.6.
As
shown
in
Exhibit
10,
EPA
estimates
that
the
annual
Agency
burden
for
all
activities
covered
in
this
ICR
is
approximately
52,420
hours,
at
an
annual
cost
of
$
2,069,585.
64
6(
d)
RESPONDENT
UNIVERSE
AND
TOTAL
RESPONDENT
BURDEN
AND
COST
RESPONDENT
UNIVERSE
Table
1
presents
the
estimated
universe
of
facilities
that
are
affected
by
the
General
Facility
Standard
requirements.
65
TABLE
1
Estimated
Universe
of
Facilities
Affected
by
General
Facility
Standard
Requirements
Permitted
Interim
Status
Total
All
Facilities
(
Operating
&
Closed/
Post
Closed)
1,333
198
1,531
Operating
Facilities
864
58
922
Commercial
284
9
293
Non­
Commercial
580
49
629
Closed
Facilities
(
New
Annual
Closures)
49
20
69
Post­
Closed
Facilities
573
124
697
Land
Disposal
Facilities
(
Op.
&
Cl/
P­
Cl)
654
115
769
Operating
LDFs
87
7
20
Closed
LDFs
(
New
Annual
Closures)
15
5
25
Post­
Closed
LDFs
552
103
655
Closed
or
Post­
Closed
LDFs
567
108
675
Facilities
with
Incinerators
81
4
85
Treatment
and
Storage
Only
Facilities
676
73
749
New
Interim
Status
NA
0
NA
New
Part
B
Permits
(
Incl.
New
Construction)
13
NA
NA
Facilities
Who
Intend
to
Close
Annually
19
9
28
LDFs
Who
Intend
to
Close
Annually
2
7
9
Facilities
Who
Intend
to
Post­
Close
Annually
22
11
33
LDFs
Who
Intend
to
Post­
Close
Annually
3
2
5
Facilities
Completing
Post­
Closure
Annually
0
0
0
GENERAL
FACILITY
OPERATING
REQUIREMENTS
(
1)
Foreign
Shipment
Import
Report
Based
on
previous
experience,
EPA
estimates
that
approximately
six
percent
of
the
operating
respondent
universe
(
52
permitted
and
4
interim
status
facilities)
will
submit
foreign
shipment
import
reports
annually.

(
2)
Notice
of
Appropriate
Permits
EPA
estimates
that
approximately
12
percent
of
operating
TSDFs
accept
off­
site
waste.
EPA
estimates
that
each
of
these
facilities
(
104
permitted
facilities)
will
accept
waste
from
an
average
of
55
new
generators
each
year
during
the
period
covered
by
this
ICR.
These
commercial
facilities
must
submit
a
onetime
notice
to
these
generators
before
accepting
their
waste.

(
3)
Notice
of
Part
264
or
Part
265,
and
Part
270
Requirements
66
1
"
All
facilities"
includes
facilities
that
are
operating
and
those
that
have
closed
or
post­
closed.
The
sum
of
operating,
closed,
and
post­
closed
facilities
taken
individually
is
greater
than
the
number
of
"
all
facilities"
because
some
facilities
can
have
both
operating
and
closed
or
post­
closed
units.
EPA
estimates
that
approximately
one
percent
of
all
facilities
1
(
13
permitted
and
2
interim
status
facilities)
will
experience
a
transfer
in
ownership
each
year.
The
owners
and
operators
of
these
facilities
will
be
required
to
submit
a
notice
of
Part
264
or
265
and
Part
270
requirements
to
the
new
owner
or
operator
of
the
facility.

(
4)
Waste
Analysis
Only
operating
facilities
are
required
to
conduct
waste
analysis
testing.
EPA
believes
that
the
commercial
incinerator
and
land
disposal
sites
have
the
greatest
responsibility
for
waste
analysis.
Based
on
previous
experience,
EPA
estimates
that
the
293
commercial
incinerator
and
land
disposal
facilities
(
284
permitted
and
9
interim
status
facilities)
will
conduct
testing
50
times
a
year,
while
all
remaining
operating
facilities
(
580
permitted
and
49
interim
status
facilities)
will
conduct
this
analysis
twice
a
year.

(
5)
Waste
Analysis
Plan
This
ICR
assumes
that
existing
interim
status
and
permitted
facilities
have
already
developed
a
waste
analysis
plan.
Therefore,
only
new
interim
and
permitted
facilities
will
develop
waste
analysis
plans.
EPA
estimates
that
no
new
interim
facilities
will
be
entering
the
universe
whereas
the
13
newly
permitted
facilities
will
have
to
prepare
a
waste
analysis
plan.
In
addition
to
preparing
a
waste
analysis
plan,
these
13
facilities
must
also
maintain
(
i.
e.,
photocopy
and
file)
the
plan
at
the
facility.

EPA
also
assumes
that
20
percent
of
all
operating
facilities
(
173
permitted
and
12
interim
status
facilities)
will
modify
the
plan
and
maintain
the
modified
plan
each
year.

(
6)
Inspection
Schedule
This
ICR
assumes
that
existing
interim
status
and
permitted
facilities
have
already
developed
an
inspection
schedule.
Therefore,
only
new
permitted
and
interim
status
facilities
will
develop
inspection
schedules.
EPA
estimates
that
no
new
interim
and
13
new
permitted
facilities
will
enter
the
universe
during
the
period
covered
by
this
ICR.

In
addition
to
preparing
an
inspection
schedule,
the
13
new
permitted
facilities
must
also
maintain
(
i.
e.,
photocopy,
file,
and
update)
the
schedule
at
the
facility.
EPA
estimates
that
five
percent
of
all
operating
facilities
and
facilities
undergoing
closure
or
post­
closure
will
modify
their
inspection
schedules
annually
and
maintain
the
modified
inspection
schedule,
for
a
total
of
65
permitted
and
10
interim
status
facilities.
All
operating
facilities
are
required
to
record
problems
in
an
inspection
log.
67
(
7)
Personnel
Training
This
ICR
assumes
that
existing
interim
status
and
permitted
facilities
have
already
collected
the
information
necessary
to
prepare
a
personnel
training
record.
Therefore,
only
new
interim
status
facilities
and
newly
constructed
permitted
facilities
will
be
required
to
collect
information
regarding
their
employees'
training
experiences.
EPA
estimates
that
no
new
interim
status
facilities
will
join
the
universe
during
the
period
covered
by
this
ICR.
Thirteen
newly
constructed
facilities
with
Part
B
permits
will
have
to
read
the
regulations
and
collect
information.

All
operating
and
newly
constructed
facilities
(
864
permitted
and
58
interim
status
facilities)
must
also
maintain
(
i.
e.,
photocopy,
file,
and
update)
their
training
records.

(
8)
Documentation
of
Compliance
for
Ignitable,
Reactive,
or
Incompatible
Wastes
Based
on
previous
experience,
EPA
estimates
that
40
percent
of
the
permitted
operating
universe
(
346facilities)
will
have
to
maintain
documentation
of
compliance
for
ignitable,
reactive,
or
incompatible
wastes.

(
9)
Construction
Quality
Assurance
Plan
This
ICR
assumes
that
existing
permitted
and
interim
status
facilities
have
submitted
their
construction
quality
assurance
plan
to
EPA.
Therefore,
only
new
interim
status
facilities
will
be
required
to
submit
the
CQA
plan.
EPA
estimates
that
no
new
facilities
will
obtain
interim
status
during
the
period
covered
by
this
ICR.
68
EXHIBIT
1
ANNUAL
ESTIMATED
RESPONDENT
BURDEN
AND
COST
GENERAL
FACILITY
OPERATING
STANDARDS
Number
of
Respondents
Hours
and
Costs
per
Respondent
or
Activity
Total
Hours
and
Costs
Legal
Manager
Technical
Clerical
Labor
Capital/
Total
Total
Interim
$
116.00/
$
84.00/
$
64.00/
$
36.00/
Cost
Startup
O&
M
Hours
per
Cost
per
INFORMATION
COLLECTION
ACTIVITY
Permitted
Status
hour
hour
hour
hour
$/
Year
Cost
Cost
Year
Year
Foreign
Shipment
Import
Report
(
264.12(
a)
and
265.12(
a))

Read
the
regulations
52
3
0.00
0.25
0.75
0.00
$
69.00
$
0.00
$
0.00
55.32
$
3,817.08
Collect
Data
52
3
0.00
0.00
0.75
0.25
$
57.00
$
0.00
$
0.00
55.32
$
3,153.24
Prepare
and
submit
notification
52
3
0.00
0.25
0.50
0.25
$
62.00
$
0.00
$
0.33
55.32
$
3,448.10
Subtotal
52
3
0.00
0.50
2.00
0.50
$
188.00
$
0.00
$
0.33
165.96
$
10,418.42
Notice
of
appropriate
permit(
s)
(
264.12(
b)

Read
the
regulations
104
N/
A
0.00
0.10
0.25
0.00
$
24.40
$
0.00
$
0.00
36.29
$
2,529.79
Prepare,
keep
records
of,
and
submit
notice
(
55
annually)
104
N/
A
0.00
0.13
0.25
0.13
$
31.00
$
0.00
$
0.33
2,851.20
$
178,656.19
Subtotal
104
N/
A
0.00
0.23
0.50
0.13
$
55.40
$
0.00
$
0.33
2,887.49
$
181,185.98
Notice
of
Part
264
or
265
and
Part
270
requirements
(
264.12(
c)
and
265.12(
b))

Read
the
regulations
13
2
0.00
0.10
0.25
0.00
$
24.40
$
0.00
$
0.00
5.36
$
373.56
Prepare
and
submit
notice
13
2
0.00
0.00
0.50
0.13
$
36.68
$
0.00
$
0.33
9.65
$
566.62
Subtotal
13
2
0.00
0.10
0.75
0.13
$
61.08
$
0.00
$
0.33
15.00
$
940.19
Waste
Analysis
(
264.13(
a)(
1)
and
265.13(
a)(
1))

Non­
commercial
facilities
Read
the
regulations
580
49
0.00
0.25
0.75
0.00
$
69.00
$
0.00
$
0.00
629.00
$
43,401.00
Collect
data
(
twice
annually)
580
49
0.00
0.00
3.00
0.50
$
210.00
$
0.00
$
0.00
4,403.00
$
264,180.00
Perform
waste
analysis
(
twice
annually)
580
49
0.00
0.00
10.00
0.00
$
640.00
$
0.00
$
750.00
12,580.00
$
1,748,620.00
Commercial
facilities
Read
the
regulations
284
9
0.00
0.25
0.75
0.00
$
69.00
$
0.00
$
0.00
293.00
$
20,217.00
Collect
data
(
50
times
annually)
284
9
0.00
0.00
1.50
0.25
$
105.00
$
0.00
$
0.00
25,637.50
$
1,538,250.00
Perform
waste
analysis
(
50
times
annually)
284
9
0.00
0.00
20.00
0.00
$
1,280.00
$
0.00
$
400.00
293,000.00
$
24,612,000.00
Subtotal
varies
varies
varies
varies
varies
varies
varies
varies
varies
336,542.50
$
28,226,668.00
Waste
Analysis
Plan
(
264.13(
b)
and
265.13(
b))

Read
the
regulations
N/
A
0
0.00
0.25
0.75
0.00
$
69.00
$
0.00
$
0.00
0.00
$
0.00
Collect
data
N/
A
0
0.00
0.00
10.00
0.00
$
640.00
$
0.00
$
0.00
0.00
$
0.00
Write
the
waste
analysis
plan
N/
A
0
0.00
10.00
60.00
0.50
$
4,698.00
$
0.00
$
0.00
0.00
$
0.00
Maintain
the
waste
analysis
plan
13
0
0.00
0.00
0.00
1.00
$
36.00
$
0.00
$
0.00
13.00
$
468.00
Modify
the
waste
analysis
plan
173
12
0.00
10.00
80.00
0.50
$
5,978.00
$
0.00
$
0.00
16,688.20
$
1,102,343.20
Maintain
the
modified
waste
analysis
plan
173
12
0.00
0.00
0.00
1.00
$
36.00
$
0.00
$
0.00
184.40
$
6,638.40
Subtotal
varies
varies
varies
varies
varies
varies
varies
varies
varies
16,885.60
$
1,109,449.60
Inspection
Schedule
(
264.15(
b)(
1)
and
265.15(
b)(
1))

Read
the
regulations
N/
A
0
0.00
0.25
0.75
0.00
$
69.00
$
0.00
$
0.00
0.00
$
0.00
Develop
an
inspection
schedule
N/
A
0
0.00
8.00
80.00
1.00
$
5,828.00
$
0.00
$
0.00
0.00
$
0.00
Maintain
the
inspection
schedule
13
0
0.00
0.00
0.00
1.00
$
36.00
$
0.00
$
0.00
13.00
$
468.00
Modify
the
inspection
schedule
719
91
0.00
0.00
8.00
0.00
$
512.00
$
0.00
$
0.00
6,476.00
$
414,464.00
Maintain
the
modified
inspection
schedule
719
91
0.00
0.00
0.00
1.00
$
36.00
$
0.00
$
0.00
809.50
$
29,142.00
Record
problems
in
the
inspection
log
864
58
0.00
0.00
100.00
0.00
$
6,400.00
$
0.00
$
0.00
92,200.00
$
5,900,800.00
Subtotal
varies
varies
varies
varies
varies
varies
varies
varies
varies
99,498.50
$
6,344,874.00
69
EXHIBIT
1
(
continued)

ANNUAL
ESTIMATED
RESPONDENT
BURDEN
AND
COST
GENERAL
FACILITY
OPERATING
STANDARDS
Number
of
Respondents
Hours
and
Costs
per
Respondent
or
Activity
Total
Hours
and
Costs
Legal
Manager
Technical
Clerical
Labor
Capital/
Total
Total
Interim
$
116.00/
$
84.00/
$
64.00/
$
36.00/
Cost
Startup
O&
M
Hours
per
Cost
per
INFORMATION
COLLECTION
ACTIVITY
Permitted
Status
hour
hour
hour
hour
$/
Year
Cost
Cost
Year
Year
Personnel
Training
(
264.16(
d)
and
265.16(
d))

Read
the
regulations
8
0
0.00
0.25
0.75
0.00
$
69.00
$
0.00
$
0.00
8.00
$
552.00
Collect
data
8
0
0.00
0.50
2.00
0.50
$
188.00
$
0.00
$
0.00
24.00
$
1,504.00
Maintain
training
records
(
new
facilities)
8
0
0.00
0.00
0.00
80.00
$
2,880.00
$
0.00
$
0.00
640.00
$
23,040.00
Maintain
training
records
(
existing
facilities)
864
58
0.00
0.00
0.00
4.00
$
144.00
$
0.00
$
0.00
3,688.00
$
132,768.00
Subtotal
varies
varies
varies
varies
varies
varies
varies
varies
varies
4,360.00
$
157,864.00
Documentation
of
Compliance
for
Ignitable,
Reactive,
or
Incompatible
Wastes
(
264.17)

Read
the
regulations
346
N/
A
0.00
0.25
0.75
0.00
$
69.00
$
0.00
$
0.00
345.60
$
23,846.40
Collect
and
document
data
346
N/
A
0.00
1.00
40.00
1.00
$
2,680.00
$
0.00
$
0.00
14,515.20
$
926,208.00
Maintain
documentation
at
the
facility
346
N/
A
0.00
0.00
0.00
1.00
$
36.00
$
0.00
$
0.00
345.60
$
12,441.60
Subtotal
346
N/
A
0.00
1.25
40.75
2.00
$
2,785.00
$
0.00
$
0.00
15,206.40
$
962,496.00
Construction
Quality
Assurance
Plan
(
265.19)

Read
the
regulations
N/
A
0
0.00
0.00
1.00
0.00
$
64.00
$
0.00
$
0.00
0.00
$
0.00
Complete
the
data
items
of
265.19(
b),
and,

if
applicable,
an
alternative
demonstration
N/
A
0
0.00
0.00
15.00
5.00
1140
$
0.00
$
0.00
0.00
$
0.00
Obtain
a
certification
from
CQA
officer
N/
A
0
0.00
0.00
1.00
0.00
$
64.00
$
0.00
$
0.00
0.00
$
0.00
Submit
materials
to
EPA
N/
A
0
0.00
0.00
0.00
0.50
$
18.00
$
0.00
$
3.20
0.00
$
0.00
Maintain
records
of
materials
N/
A
0
0.00
0.00
0.00
1.00
$
36.00
$
0.00
$
0.00
0.00
$
0.00
Subtotal
N/
A
0
0.00
0.00
17.00
6.50
$
1,322.00
$
0.00
$
3.20
0.00
$
0.00
TOTAL
varies
varies
varies
varies
varies
varies
varies
varies
varies
475,561.45
$
36,993,896.19
70
RECORDKEEPING
REQUIREMENTS
(
1)
Operating
Record
Excluding
the
inspection
information
requirement,
only
operating
facilities
are
required
to
comply
with
the
operating
record
recordkeeping
requirements.
EPA
estimates
that
864
permitted
and
58
interim
status
facilities
must
maintain
operating
records.
There
are
sixteen
information
components
of
the
operating
record
requirements
contained
in
40
CFR
§
§
264.73(
b)(
1)­(
16)
and
265.73(
b)(
1)­(
16).
Some
of
the
requirements
apply
only
to
certain
types
of
facilities:

C
Facilities
must
document
any
refusal
of
State
and
local
agencies
to
enter
into
arrangements
to
address
emergency
situations
(
§
264.37(
b)).
EPA
estimates
that
only
one
percent
of
all
operating
facilities
(
9
permitted
and
1
interim
status
facilities)
will
be
required
to
comply
with
this
regulation.

C
Facilities
that
have
emergency
incidents
requiring
implementation
of
the
contingency
plan
must
maintain
(
i.
e.,
photocopy
and
file)
written
documentation
of
the
incident
(
§
§
264.73(
b)(
4)
and
265.73(
b)(
4)).
EPA
estimates
that
only
one
percent
of
all
operating
facilities
(
9
permitted
and
1
interim
status
facilities)
will
be
required
to
comply
with
this
regulation.

C
Both
operating
and
post­
closure
facilities
(
1,333
permitted
and
198
interim
status
facilities)
are
required
to
maintain
updated
inspection
information
in
the
operating
record
(
264.73(
b)(
5)
and
265.73(
b)(
5)).

C
Only
land
disposal
facilities
and
incinerator
facilities
are
required
to
collect
and
record
monitoring
data
(
§
§
264.73(
b)(
6))
in
the
operating
record.
EPA
estimates
that,
during
the
three­
year
period
covered
by
this
ICR,
the
number
of
land
disposal
facilities
and
incinerators
subject
to
this
requirement
will
average
168
permitted
and
11
interim
status
facilities
per
year.

C
Only
facilities
that
receive
hazardous
waste
from
an
off­
site
source
(
except
where
the
owner
or
operator
is
also
the
generator)
are
required
to
maintain
(
i.
e.,
photocopy
and
file)
notices
for
generators
verifying
that
they
have
a
permit
to
handle
the
hazardous
waste
they
are
receiving
(
§
§
264.73(
b)(
7)
and
265.73(
b)(
7)).
Thus,
EPA
has
determined
that
12
percent
of
the
operating
universe
(
104
permitted
and
7
interim
status
facilities),
including
noncommercial
facilities,
will
need
to
maintain,
in
the
operating
record,
the
notice
to
generators.

C
All
facilities
must
maintain
updated
information
in
the
operating
record
closure
cost
estimates.
However,
only
land
disposal
facilities
must
maintain
post­
closure
cost
estimates
(
§
§
264.73(
b)(
8)
and
265.73(
b)(
8)).
EPA
estimates
that
all
1,333
permitted
and
198
interim
status
facilities
will
have
to
maintain
closure
cost
estimates
and
87
permitted
and
7
interim
status
operating
land
disposal
facilities
will
need
to
maintain
post­
closure
cost
estimates.

C
All
operating
land
disposal
facilities
(
87
permitted
and
7
interim
status
facilities)
must
also
maintain
records
of
the
quantities
(
and
date
of
placement)
for
each
shipment
of
hazardous
waste
placed
in
land
disposal
units
under
an
extension
to
the
effective
date
of
any
land
71
disposal
restriction,
or
a
certification,
and
the
applicable
notice
required
by
the
generator
(
§
§
264.73(
b)(
10)
and
265.73(
b)(
10)).

C
Only
off­
site
TSDFs
are
required
to
maintain
(
i.
e.,
photocopy
and
file)
a
copy
of
the
notice,
and
the
certification
and
demonstration,
if
applicable,
required
by
the
generator
or
owner
or
operator
in
the
operating
record
(
§
§
264.73(
b)(
11),
(
13),
and
(
15)
and
265.73(
b)(
11),
(
13),
and
(
15)).
Thus,
EPA
has
determined
that
five
percent
of
the
operating
universe
(
43
permitted
and
3
interim
status
facilities)
will
need
to
maintain
(
i.
e.,
photocopy
and
file)
this
information
in
the
operating
record.

C
Only
on­
site
TSDFs
are
required
to
maintain
(
i.
e.,
photocopy
and
file)
the
information
contained
in
the
notice
(
except
the
manifest
number),
and
the
certification
and
demonstration
if
applicable,
required
by
the
generator
or
owner
or
operator
(
§
§
264.73(
b)(
12),
(
14),
and
(
16)
and
265.73(
b)(
12),
(
14),
and
(
16)).
EPA
has
determined
that
95
percent
of
the
operating
universe
(
821
permitted
and
55
interim
status
facilities)
will
need
to
maintain
(
i.
e.,
photocopy
and
file)
this
information
in
the
operating
record.

The
remaining
requirements
(
§
§
264.73(
b)(
1)­(
3),
and
(
9)
and
265.73(
b)(
1)­(
3),
and
(
9))
apply
to
the
entire
universe
of
operating
facilities.
The
average
annual
number
of
facilities
subject
to
these
requirements
will
be
864
permitted
and
58
interim
status
facilities
over
the
three­
year
period
covered
by
this
ICR.
72
EXHIBIT
2
ANNUAL
ESTIMATED
RESPONDENT
BURDEN
AND
COST
OPERATING
RECORD
Number
of
Respondents
Hours
and
Costs
per
Respondent
or
Activity
Total
Hours
and
Costs
Legal
Manager
Technical
Clerical
Labor
Capital/
Total
Total
Interim
$
116.00/
$
84.00/
$
64.00/
$
36.00/
Cost
Startup
O&
M
Hours
per
Cost
per
INFORMATION
COLLECTION
ACTIVITY
Permitted
Status
hour
hour
hour
hour
$/
Year
Cost
Cost
Year
Year
Arrangements
with
Local
Authorities
(
264.37(
b)
and
265.37(
b))

Document
refusal
of
State
or
local
authorities
to
enter
into
arrangements
9
1
0.00
0.25
1.00
0.50
$
103.00
$
0.00
$
0.00
16.14
$
949.66
Determine
Quantity
of
Waste
(
264.73
and
265.73(
b)(
1)
&
(
b)(
2))

Maintain
updated
information
in
operating
record
864
58
0.00
0.00
40.00
40.00
$
4,000.00
$
0.00
$
0.00
73,760
$
3,688,000.00
Records
and
Results
of
Waste
Analysis
(
264.73
and
265.73(
b)(
3))

Maintain
updated
information
in
operating
record
864
58
0.00
0.00
0.00
20.00
$
720.00
$
0.00
$
0.00
18,440
$
663,840.00
Emergency
Reports
(
264.73
and
265.73(
b)(
4))

Maintain
updated
information
in
operating
record
9
1
0.00
0.00
0.00
4.00
$
144.00
$
0.00
$
0.00
36.88
$
1,327.68
Inspections
(
264.73
and
265.73(
b)(
5))

Maintain
updated
information
in
operating
record
1,437
182
0.00
0.00
4.00
20.00
$
976.00
$
0.00
$
0.00
38,856
$
1,580,144.00
Monitoring,
Testing,
or
Analytical
Data
and
Corrective
Action
(
264.73
and
265.73(
b)(
6))

Maintain
updated
information
in
operating
record
654
115
0.00
0.00
2.00
10.00
$
488.00
$
0.00
$
0.00
9,228
$
375,272.00
Notices
to
Generators
(
264.73
and
265.73(
b)(
7))

Maintain
updated
information
in
operating
record
104
7
0.00
0.00
0.00
2.00
$
72.00
$
0.00
$
0.00
221.28
$
7,966.08
Closure
Cost
Estimates
(
264.73
and
265.73(
b)(
8))

Maintain
updated
information
in
operating
record
1,333
198
0.00
0.00
0.00
0.25
$
9.00
$
0.00
$
0.00
382.75
$
13,779.00
Post­
Closure
Cost
Estimates
(
264.73
and
265.73(
b)(
8))

Maintain
updated
information
in
operating
record
87
7
0.00
0.00
0.00
0.25
$
9.00
$
0.00
$
0.00
23.5
$
846.00
Certification
(
264.73
and
265.73(
b)(
9))

Maintain
updated
information
in
operating
record
864
58
0.00
0.00
0.00
2.00
$
72.00
$
0.00
$
0.00
1,844
$
66,384.00
Records
of
waste
disposed
under
an
extension
to
effective
date
of
the
LDRs
and
notice
required
by
generator
under
268.7(
a)
(
264.73
and
265.73(
b)(
10))

Maintain
updated
information
in
operating
record
87
7
0.00
0.00
1.00
2.00
$
136.00
$
0.00
$
0.00
282
$
12,784.00
Copy
of
notice,
certification,
and
demonstration
required
by
generator:
Off­
site
treatment,
storage,
and
disposal
facilities
(
264.73
and
265.73(
b)(
11),
(
b)(
13),
and
(
b)(
15))

Maintain
updated
information
in
operating
record
43
3
0.00
0.00
0.00
2.00
$
72.00
$
0.00
$
0.00
92.2
$
3,319.20
Information
in
the
notice,
certification
and
demonstraton
required
by
generator
or
owner
or
operator:
On­
site
treatment,
storage,
and
disposal
facilities
(
264.73
and
265.73(
b)(
12),
(
b)(
14),
and
(
b)(
16))

Maintain
updated
information
in
operating
record
821
55
0.00
0.00
0.00
2.00
$
72.00
$
0.00
$
0.00
1,751.8
$
63,064.80
File
Storage
Systems
for
Recordkeeping
Purchase
file
cabinets
1,333
198
0.00
0.00
0.00
0.00
$
0.00
$
180.83
$
0.00
0.00
$
276,853.83
TOTAL
varies
varies
varies
varies
varies
varies
varies
varies
varies
144,934.55
$
6,754,530.25
73
CONTINGENCY
PLAN
AND
EMERGENCY
REPORTING
REQUIREMENTS
(
1)
Contingency
Plan
For
this
ICR,
the
Agency
assumes
that
existing
interim
status
and
permitted
facilities
have
already
prepared
contingency
plans.
Therefore,
only
new
interim
status
facilities
will
be
required
to
prepare
a
contingency
plan.
(
Modifications
to
contingency
plans
of
permitted
facilities
are
covered
under
the
Hazardous
Waste
Part
B
Permit
Applications,
Special
Permits,
and
Permit
Modifications
ICR
(#
1573)).
EPA
estimates
that
no
new
facilities
will
obtain
interim
status
during
the
period
covered
by
this
ICR
(#
1571),
or
submit
the
contingency
plan
to
all
local
police
and
fire
departments,
hospitals,
and
State
and
local
response
teams.

(
2)
Emergency
Reporting
And
Recordkeeping
Based
on
program
experience,
the
Agency
estimates
that
one
percent
of
all
facilities
will
experience
an
emergency
situation
each
year
that
will
require
the
help
of
State
or
local
authorities
with
designated
response
roles.
Therefore,
approximately
15
emergency
coordinators
(
13
at
permitted
facilities
and
2
at
interim
status
facilities)
will
be
required
to
notify
these
authorities
of
an
actual
or
imminent
emergency
situation
(
§
§
264.56(
a)(
2)
and
265.56(
a)(
2)).

EPA
estimates
that
one
percent
of
those
facilities
experiencing
an
emergency
situation
(
approximately
one
permitted
status
facility)
will
have
a
release,
fire,
or
explosion
for
which
the
emergency
coordinator
determines
that
it
may
be
advisable
to
evacuate
local
areas.

EPA
estimates
that
one
percent
of
facilities
will
notify
either
a
government
official
designated
as
the
on­
scene
coordinator
or
the
National
Response
Center
of
a
release,
fire,
or
explosion
(
§
§
264.56(
d)(
2)
and
265.56(
d)(
2)).
EPA
estimates
that
only
one
percent
of
all
facilities
will
have
emergency
incidents
requiring
implementation
of
the
contingency
plan.
Therefore,
approximately
15
facilities
(
13
at
permitted
and
2
at
interim
status
facilities)
will
be
required
to
prepare
an
emergency
report.

All
owners
and
operators
experiencing
an
emergency
situation
are
required
to
notify
the
Regional
Administrator
that
the
facility
is
in
compliance
with
§
265.56(
h)
before
resuming
operation
in
the
affected
areas.
The
owner
or
operator
must
also
submit
a
written
report
to
the
Regional
Administrator
15
days
after
the
incident
(
§
§
264.56(
j)
and
265.56(
j)).
The
respondent
burden
for
recording
emergency
details
in
the
operating
record
is
covered
in
the
operating
record
section.
74
EXHIBIT
3
ANNUAL
ESTIMATED
RESPONDENT
BURDEN
AND
COST
CONTINGENCY
PLAN
AND
EMERGENCY
PROCEDURES
Number
of
Respondents
Hours
and
Costs
per
Respondent
or
Acitivity
Total
Hours
and
Costs
Legal
Manager
Technical
Clerical
Labor
Capital/
Total
Total
Interim
$
116.00/
$
84.00/
$
64.00/
$
36.00/
Cost
Startup
O&
M
Hours
per
Cost
per
INFORMATION
COLLECTION
ACTIVITY
Permitted
Status
hour
hour
hour
hour
$/
Year
Cost
Cost
Year
Year
Prepare
and
Submit
Contingency
Plan
(
265.50
­
.54)

Read
the
regulations
N/
A
0
0.00
0.25
0.75
0.00
$
69.00
$
0.00
$
0.00
0.00
$
0.00
Collect
information
required
to
develop
or
modify
the
contingency
plan
N/
A
0
0.00
0.00
12.00
3.00
$
876.00
$
0.00
$
0.00
0.00
$
0.00
Develop
the
contingency
plan
N/
A
0
0.00
1.00
60.00
4.00
$
4,068.00
$
0.00
$
0.00
0.00
$
0.00
Submit
contingency
plan
to
local
authorities
0
0
0.00
0.00
0.00
0.50
$
18.00
$
0.00
$
3.20
0.00
$
0.00
Maintain
the
contingency
plan
0
0
0.00
0.00
0.00
1.00
$
36.00
$
0.00
$
0.00
0.00
$
0.00
Subtotal
0
0
0.00
1.25
72.75
8.50
$
5,067.00
$
0.00
$
3.20
0.00
$
0.00
Emergency
Coordinator
Reports
(
264.56(
a)(
2),
(
d)(
1),
and
(
d)(
2)),
and
265.56(
a)(
2),
(
d)(
1),
and
(
d)(
2))

Notify
State
and
local
authorities
of
an
imminent
or
actual
emergency
situation
13
2
0.00
0.50
0.00
0.00
$
42.00
$
0.00
$
0.00
7.66
$
643.02
Collect
information
required
for
an
emergency
report
13
2
0.00
0.00
2.50
0.50
$
178.00
$
0.00
$
0.00
45.93
$
2,725.18
Notify
local
authorities
of
the
need
to
evacuate
local
areas
0
0
0.00
1.00
0.00
0.00
$
84.00
$
0.00
$
0.00
0.15
$
12.86
Submit
an
emergency
report
to
the
on­
scene
coordinator
or
the
National
Response
Center
13
2
0.00
1.00
0.00
0.00
$
84.00
$
0.00
$
3.20
15.31
$
1,335.03
Subtotal
varies
varies
varies
varies
varies
varies
varies
varies
varies
69.05
$
4,716.09
Notify
Regional
Administrator
that
facility
is
in
compliance
with
264.56(
h)
or
265.56(
h)
before
resuming
operations
in
the
affected
area
(
264.56(
i)
and
265.56(
i))

Compile
information
that
demonstrates
that
all
affected
areas
are
in
compliance
with
264.56(
h)
or
265.56(
h)
13
2
0.00
0.00
2.50
0.50
$
178.00
$
0.00
$
0.00
45.93
$
2,725.18
Prepare
and
submit
notification
letter
13
2
0.00
0.25
1.50
0.25
$
126.00
$
0.00
$
0.33
30.62
$
1,934.11
Subtotal
13
2
0.00
0.25
4.00
0.75
$
304.00
$
0.00
$
0.33
76.55
$
4,659.29
Prepare
an
Owner/
Operator's
Emergency
Report
(
264.56(
j)
and
265.56(
j))

Read
the
regulations
13
2
0.00
0.25
0.75
0.00
$
69.00
$
0.00
$
0.00
15.31
$
1,056.39
Collect
information
required
in
the
emergency
report
13
2
0.00
0.00
8.00
0.50
$
530.00
$
0.00
$
0.00
130.14
$
8,114.30
Prepare
and
submit
the
emergency
report
13
2
0.00
0.25
4.00
0.50
$
295.00
$
0.00
$
3.20
72.72
$
4,565.44
Subtotal
13
2
0.00
0.50
12.75
1.00
$
894.00
$
0.00
$
3.20
218.17
$
13,736.13
TOTAL
varies
varies
varies
varies
varies
varies
varies
varies
varies
363.77
$
23,111.52
75
RELEASES
FROM
SOLID
WASTE
MANAGEMENT
UNITS
EPA
expects
that
no
facilities
will
be
required
to
demonstrate
that
the
ground­
water
protection
standard
of
§
264.92
has
not
been
exceeded
for
three
consecutive
years
(
§
264.96(
c)).
EPA
also
expects
all
facilities
submitting
a
Part
B
permit
application
(
13
facilities)
to
develop
and
submit
sampling
procedures
to
EPA
(
§
264.97(
g)).

CLOSURE
AND
POST­
CLOSURE
REQUIREMENTS
(
1)
Reading
the
Regulations
The
only
facilities
that
are
expected
to
read
the
closure
regulations
will
be
the
newly
permitted
facilities.
13
land
disposal
facilities
are
expected
to
read
the
post­
closure
regulations.

(
2)
Closure
Plans
Since
existing
interim
status
and
permitted
facilities
have
already
developed
closure
and
post­
closure
plans,
activities
associated
with
developing
closure/
post­
closure
plans
apply
to
newly
interim
status
facilities
only.
EPA
expects
no
new
facilities
to
develop
and
submit
closure
plans.

(
3)
Closure
Plan
Amendment
Based
on
previous
experience,
EPA
estimates
that
five
percent
of
operating
or
closing
interim
status
facilities
(
6
facilities),
such
as
facilities
converting
waste
piles
to
containment
buildings,
will
amend
their
closure
plans
annually
and
will
submit
a
request
to
the
Regional
Administrator
to
authorize
a
change
in
the
closure
plan.
Since
closure
plan
amendments
for
permitted
facilities
are
associated
with
permit
modifications,
amendments
are
discussed
in
the
Hazardous
Waste
Part
B
Permit
Applications,
Special
Permits,
and
Permit
Modifications
ICR,
#
1573.

(
4)
Partial
Closure
and
Final
Closure
Notification
Owners
and
operators
of
all
19
permitted
and
9
interim
status
facilities
who
intend
to
close
their
facility
annually
must
notify
EPA
of
closure.
In
addition,
owners
and
operators
of
the
9
interim
status
facilities
must
also
submit
their
closure
plans
to
EPA.

(
5)
Extensions
and
Allowances
During
the
Closure
Period
Of
the
total
number
of
facilities
that
will
be
closing,
EPA
estimates
that
20
percent
annually,
or
4
permitted
and
2
interim
status
facilities,
will
request
an
extension
for
the
treatment,
storage,
or
removal
of
hazardous
waste
(
§
§
264.113(
a)
and
265.113(
a)).
EPA
estimates
that
an
additional
20
percent
(
4
permitted
and
2
interim
status
facilities)
will
request
an
extension
for
completing
closure
activities.
EPA
also
estimates
that
an
additional
five
percent
of
all
closing
facilities
(
approximately
1
permitted
and
0
interim
facilities)
will
request
an
allowance
to
receive
non­
hazardous
wastes
in
a
land­
based
unit
after
the
final
receipt
of
hazardous
waste
(
§
§
264.113(
d)
and
265.113(
d)).
76
(
6)
Closure
Certification
EPA
estimates
that
all
of
the
19
permitted
and
9
interim
status
facilities
that
will
be
closing
annually
will
complete
a
certification
of
closure.

(
7)
Survey
Plat
EPA
estimates
that
50
percent
of
the
nine
land
disposal
facilities
that
will
be
closing
annually
(
1
permitted
and
4
interim
status
facilities)
will
submit
a
survey
plat
to
the
Regional
Administrator.

(
8)
Post­
Closure
Plan
Existing
permitted
land
disposal
facilities
already
have
approved
post­
closure
plans.
Therefore,
only
new
interim
status
land
disposal
facilities
will
develop
post­
closure
plans.
EPA
estimates
that
no
new
interim
status
land
disposal
facilities
(
no
new
facilities)
will
prepare
a
post­
closure
plan
annually.
In
addition
to
preparing
a
post­
closure
plan,
all
permitted
and
interim
status
land
disposal
facilities
(
102
permitted
and
12
interim
status
facilities)
must
also
maintain
(
i.
e.,
photocopy,
file,
and
update)
the
postclosure
plan
at
the
facility.

(
9)
Notification
and
Amendment
of
Post­
Closure
Plan
Under
265.118(
d)

Since
respondent
activities
associated
with
permit
modifications
are
discussed
in
the
Hazardous
Waste
Part
B
Permit
Applications,
Special
Permits,
and
Permit
Modifications
ICR
(#
1573),
this
ICR
focuses
on
interim
status
facilities'
activities
associated
with
notification
of
a
post­
closure
amendment.
EPA
estimates
that
20
percent
of
interim
status
facilities
that
will
be
undergoing
post­
closure,
or
two
facilities,
will
amend
their
post­
closure
plans
and
submit
written
notification
of
a
change
in
the
approved
post­
closure
plans.

(
10)
Amendment
of
Post­
Closure
Plan
Under
265.118(
d)(
4),
(
f),
and
(
g)(
1)

In
some
cases,
the
Regional
Administrator
will
require
owners
or
operators
of
surface
impoundments
or
waste
piles
who
intend
to
remove
all
hazardous
wastes
at
closure
to
modify
their
postclosure
plans.
EPA
expects
that
ten
percent
of
interim
status
facilities
that
are
undergoing
post­
closure
(
approximately
one
facility)
will
be
required
to
modify
their
post­
closure
plan.
EPA
estimates
that
the
Agency
will
reject
ten
percent
of
these
plans,
which
will
require
approximately
no
facilities
to
modify
its
plan
or
submit
a
new
plan.

In
some
cases,
facilities
will
request
that
the
Agency
extend
or
reduce
the
post­
closure
period
applicable
to
a
hazardous
waste
management
unit
or
facility,
or
to
alter
the
requirements
of
the
post­
closure
care
period.
EPA
estimates
that
20
percent
of
interim
status
facilities
that
are
undergoing
post­
closure
(
two
facilities),
will
prepare
and
submit
such
a
request.

(
11)
Hazardous
Waste
Disposal
Records
All
nine
owners
and
operators
who
close
their
land
disposal
facilities
annually
(
2
permitted
and
7
interim
status
facilities)
must
submit
hazardous
waste
disposal
records.

(
12)
Hazardous
Waste
Notation
Certification
77
All
nine
owners
and
operators
who
close
their
land
disposal
facilities
annually
(
2
permitted
and
7
interim
status
facilities)
must
submit
a
certification
that
they
have
recorded
the
notation
required
in
§
§
264.119(
b)(
2)
and
265.119(
b)(
2).

(
13)
Post­
Closure
Plan
Modifications
EPA
does
not
expect
that
any
interim
status
facilities
will
subject
to
section
265.119(
c)
during
the
effective
period
of
this
ICR.

(
14)
Post­
Closure
Care
Certification
Since
the
post­
closure
care
period
lasts
for
30
years,
except
for
those
facilities
that
qualify
for
"
early
outs,"
EPA
does
not
expect
many
owners/
operators
to
submit
certifications
of
post­
closure
care
during
the
period
covered
by
this
ICR.
Based
on
previous
experience,
EPA
estimates
that
no
facilities
will
complete
post­
closure
care
and
be
required
to
submit
certifications.
78
EXHIBIT
4
ANNUAL
ESTIMATED
RESPONDENT
BURDEN
AND
COST
RELEASES
FROM
SOLID
WASTE
MANAGEMENT
UNITS
Number
of
Respondents
Hours
and
Costs
per
Respondent
or
Activity
Total
Hours
and
Costs
Legal
Manager
Technical
Clerical
Labor
Capital/
Total
Total
Interim
$
116.00/
$
84.00/
$
64.00/
$
36.00/
Cost
Startup
O&
M
Hours
per
Cost
per
INFORMATION
COLLECTION
ACTIVITY
Permitted
Status
hour
hour
hour
hour
$/
Year
Cost
Cost
Year
Year
Termination
of
compliance
period
(
264.96(
c))

Read
the
regulations
0
N/
A
0.00
0.25
0.75
0.00
$
69.00
$
0.00
$
0.00
0.00
$
0.00
Prepare
and
submit
demonstration
0
N/
A
0.00
1.00
4.00
1.00
$
376.00
$
0.00
$
3.20
0.00
$
0.00
Subtotal
0
N/
A
0.00
1.25
4.75
1.00
$
445.00
$
0.00
$
3.20
0.00
$
0.00
Proposal
of
sampling
procedure
and
interval
(
264.97(
g))

Read
the
regulations
13
N/
A
0.00
0.25
0.75
0.00
$
69.00
$
0.00
$
0.00
13.00
$
897.00
Develop
and
submit
sampling
procedure
13
N/
A
0.00
20.00
100.00
2.00
$
8,152.00
$
0.00
$
3.20
1586.00
$
106,017.60
Subtotal
62
N/
A
0.00
20.25
100.75
2.00
$
8,221.00
$
0.00
$
3.20
1,599.00
$
106,914.60
Total
varies
varies
varies
varies
varies
varies
varies
varies
varies
1,599.00
$
106,914.60
79
EXHIBIT
5
ANNUAL
ESTIMATED
RESPONDENT
BURDEN
AND
COST
CLOSURE
AND
POST­
CLOSURE
REQUIREMENTS
Number
of
Respondents
Hours
and
Costs
per
Respondent
or
Activity
Total
Hours
and
Costs
Legal
Manager
Technical
Clerical
Labor
Capital/
Total
Total
Interim
$
116.00/
$
84.00/
$
64.00/
$
36.00/
Cost
Startup
O&
M
Hours
per
Cost
per
INFORMATION
COLLECTION
ACTIVITY
Permitted
Status
hour
hour
hour
hour
$/
Year
Cost
Cost
Year
Year
Closure
Plan
(
265.112(
a))

Read
the
regulations
N/
A
0
0.00
0.50
3.00
0.00
$
234.00
$
0.00
$
0.00
0.00
$
0.00
Conduct
an
inventory
of
hazardous
waste
N/
A
0
0.00
0.00
8.00
0.00
$
512.00
$
0.00
$
0.00
0.00
$
0.00
Record
results
of
inventory
N/
A
0
0.00
0.00
2.00
0.50
$
146.00
$
0.00
$
0.00
0.00
$
0.00
Write
descriptions
for
activities
N/
A
0
0.00
1.00
20.00
3.00
$
1,472.00
$
0.00
$
0.00
0.00
$
0.00
Estimate
final
closure
N/
A
0
0.00
0.25
0.25
0.00
$
37.00
$
0.00
$
0.00
0.00
$
0.00
Write
the
closure
schedule
N/
A
0
0.00
0.50
1.00
0.50
$
124.00
$
0.00
$
0.00
0.00
$
0.00
Subtotal
N/
A
0
0.00
2.25
34.25
4.00
$
2,525.00
$
0.00
$
0.00
0.00
$
0.00
Notification
and
Amendment
of
Closure
Plan
(
265.112(
c))

Prepare
and
submit
notification
of
amendment
N/
A
4
0.00
0.25
1.00
0.25
$
94.00
$
0.00
$
0.33
5.85
$
367.89
Amend
and
submit
closure
plan
N/
A
4
0.00
0.00
8.00
1.00
$
548.00
$
0.00
$
3.20
35.10
$
2,149.68
Subtotal
N/
A
4
0.00
0.25
9.00
1.25
$
642.00
$
0.00
$
3.53
40.95
$
2,517.57
Notification
of
Partial
or
Final
Closure
(
264.112(
d)
and
265.112(
d))

Prepare
and
submit
notification
of
closure
19
9
0.00
0.25
0.50
0.25
$
62.00
$
0.00
$
0.33
28.00
$
1,745.24
Submit
closure
plan
19
9
0.00
0.00
0.00
1.00
$
36.00
$
0.00
$
3.20
28.00
$
1,097.60
Subtotal
19
9
0.00
0.25
0.50
1.25
$
98.00
$
0.00
$
3.53
56.00
$
2,842.84
Extension
and
Allowances
During
the
Closure
Period
(
264.113(
a),
265.113(
a),
264.113(
b),
265.113(
b),
264.113(
d),
and
265.113(
d))

Prepare
and
submit
demonstration
for
extension
for
treatment,
storage,
or
removal
of
hazardous
waste
(
264/
265.113(
a))
4
2
0.00
4.00
80.00
1.00
$
5,492.00
$
0.00
$
3.20
476.00
$
30,773.12
Prepare
and
submit
demonstration
for
extension
of
the
closure
period
(
264/
265.113(
b))
4
2
0.00
4.00
80.00
1.00
$
5,492.00
$
0.00
$
3.20
476.00
$
30,773.12
Prepare
and
submit
demonstration
for
receiving
non­
hazardous
waste
(
264/
265.113(
d))
1
0
0.00
4.00
100.00
1.00
$
6,772.00
$
0.00
$
3.20
147.00
$
9,485.28
Subtotal
varies
varies
varies
varies
varies
varies
varies
varies
varies
1,099.00
$
71,031.52
Certification
of
Closure
(
264.115
and
265.115)

Have
an
independent
registered
professional
engineer
inspect
the
facility
19
9
0.00
0.00
1.00
0.00
$
64.00
$
0.00
$
1,000.00
28.00
$
29,792.00
Collect
documentation
to
support
certification
and
submit
certification
19
9
0.00
0.00
3.00
2.00
$
264.00
$
0.00
$
9.20
140.00
$
7,649.60
Subtotal
19
9
0.00
0.00
4.00
2.00
$
328.00
$
0.00
$
1,009.20
168.00
$
37,441.60
Survey
Plat
(
264.116
and
265.116)

Have
a
professional
land
surveyor
prepare
and
certify
plat,
and
submit
plat
1
4
0.00
0.00
1.00
2.00
$
136.00
$
0.00
$
750.00
13.50
$
3,987.00
Subtotal
1
4
0.00
0.00
1.00
2.00
$
136.00
$
0.00
$
750.00
13.50
$
3,987.00
Post­
Closure
Plan
(
265.118)

Read
the
regulations
N/
A
0
0.00
0.50
3.00
0.00
$
234.00
$
0.00
$
0.00
0.00
$
0.00
Collect
data
N/
A
0
0.00
1.00
12.00
7.00
$
1,104.00
$
0.00
$
0.00
0.00
$
0.00
Write
and
submit
post­
closure
plan
N/
A
0
0.00
1.00
20.00
2.00
$
1,436.00
$
0.00
$
3.20
0.00
$
0.00
Maintain
post­
closure
plan
0
0
0.00
0.00
0.00
1.00
$
36.00
$
0.00
$
0.00
0.00
$
0.00
Subtotal
varies
varies
varies
varies
varies
varies
varies
varies
varies
0.00
$
0.00
80
Notification
and
Amendment
of
Post­
Closure
Plan
Under
265.118(
a)(
1)­(
3)

Prepare
and
submit
notification
of
amendment
N/
A
1
0.00
0.25
1.00
0.25
$
94.00
$
0.00
$
0.33
2.10
$
132.06
Prepare
and
submit
amended
post­
closure
plan
N/
A
1
0.00
0.00
8.00
1.00
$
548.00
$
0.00
$
3.20
12.60
$
771.68
Subtotal
N/
A
1
0.00
0.25
9.00
1.25
$
642.00
$
0.00
$
3.53
14.70
$
903.74
Amendment
of
Post­
Closure
Plan
Under
265.118(
d)(
4),
(
f),
and
(
g)(
1)

Amend
and
submit
post­
closure
plan
as
requested
by
EPA
(
265.118(
d)(
4))
N/
A
1
0.00
0.50
6.00
1.50
$
480.00
$
0.00
$
3.20
5.60
$
338.24
Modify
and
resubmit
plan,
if
not
approved
by
EPA
(
265.118(
f))
N/
A
0
0.00
0.50
6.00
2.00
$
498.00
$
0.00
$
3.20
0.60
$
35.08
Petition
to
extend
or
reduce
the
post­
closure
care
period
(
265.118(
g)(
1))
N/
A
1
0.00
0.50
1.00
0.50
$
124.00
$
0.00
$
3.20
2.80
$
178.08
Subtotal
N/
A
varies
varies
varies
varies
varies
varies
varies
varies
9.00
$
551.40
Hazardous
Waste
Disposal
Records
(
264.119
and
265.119(
a))

Determine
specifications
of
hazardous
waste
activity
2
7
0.00
0.00
2.00
0.00
$
128.00
$
0.00
$
0.00
18.00
$
1,152.00
Establish
and
submit
a
record
of
activity
2
7
0.00
0.00
1.00
0.00
$
64.00
$
0.00
$
3.20
9.00
$
604.80
Maintain
the
record
of
activity
2
7
0.00
0.00
0.00
1.00
$
36.00
$
0.00
$
0.00
9.00
$
324.00
Subtotal
2
7
0.00
0.00
3.00
1.00
$
228.00
$
0.00
$
3.20
36.00
$
2,080.80
Hazardous
Waste
Notation
Certification
Record
notation
on
deed,
and
develop
and
submit
certification
2
7
1.00
0.00
1.00
2.00
$
252.00
$
0.00
$
0.33
36.00
$
2,270.97
Subtotal
2
7
0.00
0.00
1.00
2.00
$
252.00
$
0.00
$
0.33
36.00
$
2,270.97
Post­
Closure
Plan
Modifications
(
265.119(
c))

Prepare
request
for
modification
N/
A
0
0.00
0.50
1.25
0.25
$
131.00
$
0.00
$
0.00
0.00
$
0.00
Demonstrate
compliance
N/
A
0
0.00
0.25
1.75
1.00
$
169.00
$
0.00
$
0.00
0.00
$
0.00
Subtotal
N/
A
0
0.00
0.75
3.00
1.25
$
300.00
$
0.00
$
0.00
0.00
$
0.00
Certification
of
Completion
of
Post­
Closure
Care
(
264.120
and
265.120)

Obtain
certification
of
compliance
from
an
independent
registered
professional
engineer
0
0
0.00
1.00
4.00
0.00
$
340.00
$
0.00
$
1,000.00
0.00
$
0.00
Maintain
a
copy
of
the
certification
0
0
0.00
0.00
0.00
1.00
$
36.00
$
0.00
$
0.00
0.00
$
0.00
Submit
documentation
to
EPA
0
0
0.00
0.00
0.00
1.00
$
36.00
$
0.00
$
3.20
0.00
$
0.00
Subtotal
0
0
0.00
1.00
4.00
2.00
$
412.00
$
0.00
$
1,003.20
0.00
$
0.00
TOTAL
varies
varies
varies
varies
varies
varies
varies
varies
varies
1,473.15
$
123,627.44
EXHIBIT
5
(
continued)

ANNUAL
ESTIMATED
RESPONDENT
BURDEN
AND
COST
CLOSURE
AND
POST­
CLOSURE
REQUIREMENTS
Number
of
Respondents
Hours
and
Costs
per
Respondent
or
Activity
Total
Hours
and
Costs
Legal
Manager
Technical
Clerical
Labor
Capital/
Total
Total
Interim
$
116.00/
$
84.00/
$
64.00/
$
36.00/
Cost
Startup
O&
M
Hours
per
Cost
per
INFORMATION
COLLECTION
ACTIVITY
Permitted
Status
hour
hour
hour
hour
$/
Year
Cost
Cost
Year
Year
81
FINANCIAL
REQUIREMENTS
(
1)
Reading
the
Regulations
All
operating
and
newly
constructed
facilities
(
864
permitted
and
58
interim
status
facilities)
are
expected
to
read
the
financial
requirements
regulations.

(
2)
Financial
Responsibility
for
Corrective
Action
Because
financial
responsibility
for
corrective
action
is
required
under
Part
264,
only
permitted
facilities
are
included
in
the
burden
estimate.
EPA
estimates
that
80
percent
of
permitted
facilities
completed
a
RCRA
Facility
Assessment
(
RFA)
that
indicated
that
further
investigation,
or
a
RCRA
Facility
Investigation
(
RFI),
was
necessary.
Because
such
further
investigation
will
entail
the
submission
of
corrective
action
financial
assurance
documentation,
EPA
concludes
that
80
percent
of
the
1,333
permitted
facilities,
or
1,066
facilities,
will
need
to
meet
corrective
action
financial
responsibility
requirements.
These
facilities
will
need
to
include
this
financial
assurance
documentation
in
their
permit
renewals;
because
most
TSDF
permits
are
valid
for
five
years,
EPA
estimates
that
each
year
approximately
20
percent,
or
213
of
these
1,066
facilities
will
submit
financial
assurance
documentation
for
corrective
action.
EPA
estimates
that
ten
percent
of
these
facilities
per
year
(
21
facilities)
will
need
to
provide
the
additional
demonstration
of
denied
permission
to
implement
corrective
action
beyond
facility
boundaries.

(
3)
Cost
Estimates
for
Closure
and
Post­
Closure
Care
The
burden
for
respondents
to
collect
data,
to
prepare
closure
and
post­
closure
care
cost
estimates,
and
to
maintain
these
estimates
at
the
facility
is
already
calculated
in
Exhibit
5,
Closure
and
Post­
Closure
Care
Requirements.
Therefore,
Exhibit
6
only
determines
the
burden
for
owners
or
operators
to
update
cost
estimates
on
a
yearly
basis
to
reflect
inflation,
and
the
burden
for
amending
cost
estimates
due
to
changes
in
the
closure
or
post­
closure
care
plan.
Except
for
those
facilities
already
closed
or
post­
closed,
all
operating
facilities
(
864
permitted
and
58
interim
status)
will
need
to
adjust
estimates
annually
to
reflect
inflation.
For
amendments
of
cost
estimates
due
to
changes
in
closure
or
post­
closure
plans,
EPA
estimates,
as
shown
in
Exhibit
5,
21
interim
status
facilities
that
are
not
closed
or
post­
closed
will
amend
their
closure
or
postclosure
plans
annually
(
20
closure
plan
amendments
and
1
post­
closure
plan
amendments).
Since
closure
and
post­
closure
plan
amendments
for
permitted
facilities
are
associated
with
permit
modifications,
such
amendments
are
instead
discussed
in
the
Hazardous
Waste
Part
B
Permit
Applications,
Special
Permits,
and
Permit
Modifications
ICR
(#
1573).

(
4)
Financial
Assurance
for
Closure
or
Post­
Closure
Care
Because
evidence
of
establishing
a
financial
instrument
for
closure
or
post­
closure
care
is
submitted
with
the
Part
B
permit
application,
such
activities
for
permitted
facilities
are
discussed
in
the
Hazardous
Waste
Part
B
Permit
Applications,
Special
Permits,
and
Permit
Modifications
ICR
(#
1573).
However,
prior
to
submitting
a
permit
application,
interim
status
facilities
must
present
evidence
of
an
established
financial
instrument
for
closure
or
post­
closure
care
under
§
§
265.143
and
265.145.
Therefore,
preparation
of
the
required
evidence
for
interim
status
facilities
is
discussed
in
Exhibit
6.
In
addition,
the
burden
associated
with
annual
updates
or
modifications
to
financial
instruments
is
calculated
in
this
exhibit
for
both
permitted
and
interim
status
facilities.
82
Only
new
interim
facilities
will
have
to
choose
between
the
financial
test
for
liability
coverage
and
the
other
coverage
options.
EPA
estimates
that
no
new
interim
facilities
will
join
the
universe
in
the
period
this
ICR
covers.

EPA
projects
that
two
percent
of
existing
facilities
amend
closure
and
post­
closure
financial
instruments
due
to
changes
in
the
cost
estimates
or
plans.
Therefore,
EPA
calculates
that
27
permitted
facilities
and
4
interim
status
facilities
will
need
to
engage
in
activities
to
modify
amounts
covered
by
each
financial
instrument.
Finally,
all
facilities
covered
under
the
financial
test
will
need
to
submit
annual
updates;
accordingly,
50
percent
of
existing
facilities
(
667
permitted
and
99
interim
status
facilities)
will
submit
this
update.

(
5)
Liability
Requirements
EPA
calculates
the
number
of
respondents
for
demonstrating
liability
coverage
in
a
manner
similar
to
determining
the
number
of
closure
and
post­
closure
care
respondents.
Because
evidence
of
establishing
a
financial
instrument
for
liability
coverage
is
submitted
with
the
Part
B
permit
application,
such
activities
for
permitted
facilities
are
discussed
in
the
Hazardous
Waste
Part
B
Permit
Applications,
Special
Permits,
and
Permit
Modifications
ICR
(#
1573).
However,
prior
to
submitting
a
permit
application,
interim
status
facilities
must
present
evidence
of
an
established
financial
instrument
for
liability
coverage
under
§
265.147.
Therefore,
preparation
of
the
required
evidence
for
interim
status
facilities
is
shown
in
Exhibit
6
of
this
ICR.
In
addition,
the
burden
associated
with
annual
updates
or
modifications
to
financial
instruments
for
liability
coverage
is
calculated
in
this
exhibit
for
both
permitted
and
interim
status
facilities.

Only
new
interim
facilities
will
have
to
choose
between
the
liability
coverage
options.
EPA
estimates
that
no
new
interim
facilities
will
join
the
universe
in
the
period
this
ICR
covers.

EPA
expects
that
all
existing
TSDFs
using
the
financial
test
or
guarantee
will
submit
the
financial
test
documentation
on
an
annual
basis
for
review.
Using
the
estimate
that
25
percent
of
all
non­
closed
and
non­
post­
closed
facilities
choose
each
of
these
mechanisms,
EPA
estimates
that
333
permitted
and
50
interim
status
facilities
will
submit
this
information
on
an
annual
basis
for
each
option.

EPA
estimates
that
one
percent
of
all
facilities
(
13
permitted
and
2
interim
status)
will
become
bankrupt
and
will
need
to
submit
evidence
of
insurance.
EPA
further
estimates,
based
on
earlier
estimates,
that
10
facilities
will
submit
claim
notifications
(
8
permitted
facilities
and
2
interim
status
facilities,
based
on
the
ratio
of
permitted
facilities
to
interim
status
facilities).

(
6)
Other
Requirements
As
discussed
above,
the
average
bankruptcy
rate
of
one
percent
will
generate
13
permitted
and
2
interim
status
respondents
for
the
incapacity
of
owners
or
operators,
guarantors,
or
financial
institutions
requirements.

For
activities
relating
to
State­
required
mechanisms
and
State
assumption
of
responsibility,
EPA
estimates
that
one
percent
of
interim
status
facilities,
or
2
facilities
(
permitted
facilities
are
included
in
ICR
#
1573),
will
be
included
in
the
respondent
burden
estimate.
EPA
estimates
that
of
these
2
facilities,
only
one
percent
(
approximately
zero
interim
status
facilities)
will
be
required
by
EPA
to
furnish
additional
information
under
the
State
assumption
of
responsibility
requirements.
83
CONDITIONS
APPLICABLE
TO
ALL
PERMITS
EPA
estimates
that
each
year
20
percent
of
permitted
facilities,
or
173
facilities,
will
submit
a
permit
modification
at
the
request
of
the
Agency.
These
permittees
will
be
required
to
furnish
any
relevant
information
requested
by
EPA
to
determine
whether
cause
exists
to
modify,
revoke
and
reissue,
or
terminate
a
permit,
or
to
determine
compliance
with
a
permit.

EPA
estimates
that
15
percent
of
permitted
facilities,
or
130
facilities
will
annually
submit
a
notice
of
physical
alterations
or
additions.
Of
these
facilities,
50
percent
(
65
facilities)
will
submit
a
notice
of
planned
changes
that
may
result
in
noncompliance
with
permit
requirements.
Of
these
65
facilities,
50
percent
(
33
facilities)
will
submit
a
letter
certifying
that
the
facility
has
been
constructed
or
modified
in
compliance
with
the
terms
of
the
permit.

EPA
estimates
that
all
permitted
facilities
with
land­
based
units
and
incinerators
(
168
facilities)
must
submit
monitoring
reports.
EPA
further
estimates
that
one
percent
or
13
facilities
will
be
required
to
prepare
and
submit
reports
of
compliance
and
noncompliance
with
the
compliance
schedule
at
intervals
specified
in
the
permit.

EPA
estimates
that
one
percent
of
all
permitted
facilities,
or
13
facilities,
will
experience
a
release,
fire,
or
explosion
that
may
threaten
drinking
water
supplies,
human
health,
or
the
environment
outside
the
facility.
These
facilities
will
be
required
to
submit
a
report
within
24
hours
of
the
incident
and
a
more
detailed
written
notice
or
report
within
5
or
15
days,
respectively,
of
the
incident.

EPA
estimates
that
two
percent
of
all
permitted
facilities,
or
26
facilities
will
be
required
to
submit
reports
of
other
noncompliance
that
are
not
submitted
with
monitoring
reports,
compliance
schedule
reports,
and
reports
of
releases,
fires,
and
explosions.
An
additional
one
percent,
or
13
facilities,
will
submit
amended
information
that
was
incorrect
or
omitted
during
an
initial
submittal.

TOTAL
RESPONDENT
BURDEN
AND
COST
Exhibit
8
illustrates
the
total
respondent
burden
and
costs
associated
with
all
of
the
information
collection
activities
covered
in
this
ICR.
As
shown
in
Exhibit
8,
EPA
estimates
that
the
total
annual
respondent
burden
for
all
activities
covered
in
the
ICR
is
approximately
652,312
hours,
at
an
annual
cost
of
$
45,906,572.
84
EXHIBIT
6
ANNUAL
ESTIMATED
RESPONDENT
BURDEN
AND
COST
FINANCIAL
REQUIREMENTS
Number
of
Respondents
Hours
and
Costs
per
Respondent
Total
Hours
and
Costs
Legal
Manager
Technical
Clerical
Labor
Capital/
Total
Total
Interim
$
116.00/
$
84.00/
$
64.00/
$
36.00/
Cost
Startup
O&
M
Hours
per
Cost
per
INFORMATION
COLLECTION
ACTIVITY
Permitted
Status
hour
hour
hour
hour
$/
Year
Cost
Cost
Year
Year
Reading
the
Regulations
Read
the
regulations
covering
financial
responsibility
requirements
(
new
facilities)
8
0
8.00
2.00
8.00
0.00
$
1,608.00
$
0.00
$
0.00
144
$
12,864.00
Read
the
regulations
covering
financial
responsibility
requirements
(
existing
facilities)
864
58
4.00
1.00
4.00
0.00
$
804.00
$
0.00
$
0.00
8,298
$
741,288.00
Subtotal
varies
varies
varies
varies
varies
varies
varies
varies
varies
8,298
$
754,152.00
Financial
Responsibility
for
Corrective
Action
(
264.101)

Prepare
and
submit
documented
assurances
of
financial
responsibility
for
corrective
action
216
N/
A
2.00
0.50
5.50
1.00
$
662.00
$
0.00
$
3.20
1,944
$
143,647.28
Demonstrate,
if
applicable,
that
permission
denied
to
implement
correction
action
beyond
facility
boundary
22
N/
A
1.00
0.50
1.25
0.25
$
247.00
$
0.00
$
3.20
65
$
5,402.97
Subtotal
varies
N/
A
varies
varies
varies
varies
varies
varies
varies
2,008
$
149,050.25
Cost
Estimates
for
Closure
and
Post­
Closure
Care
(
264.142,
264.144,
265.142,
and
265.144)

Adjust
estimate
annually
to
reflect
inflation
864
58
0.00
0.00
0.50
0.00
$
32.00
$
0.00
$
0.00
461
$
29,504.00
Amend
cost
estimate
due
to
closure/

post­
closure
plan
changes
0
5
0.00
0.50
6.50
0.50
$
476.00
$
0.00
$
0.00
38
$
2,380.00
Subtotal
varies
varies
varies
varies
varies
varies
varies
varies
varies
499
$
31,884.00
Closure
or
Post­
Closure
Trust
Fund
(
264.143,
265.143,
264.145,
and
265.145)

Establish
a
closure
or
post­
closure
trust
fund
0
0
4.00
1.50
2.00
0.50
$
736.00
$
0.00
$
0.00
0
$
0.00
Submit
orginally
signed
duplicate
of
trust
agreement
0
0
0.00
0.00
0.00
0.50
$
18.00
$
0.00
$
3.20
0
$
0.00
Submit
formal
certification
of
acknowledgement
(
post­
closure
trust
funds
only)
0
0
0.00
0.00
0.00
1.00
$
36.00
$
0.00
$
0.33
0
$
0.00
Submit
receipt
for
first
payment
under
trust
agreement
(
new
facilities)
0
0
0.00
0.00
0.00
1.00
$
36.00
$
0.00
$
0.33
0
$
0.00
Amend
trust
fund
due
to
changes
in
closure/
post­
closure
plan
3
0
2.00
1.00
0.75
0.25
$
373.00
$
0.00
$
0.00
15
$
1,427.66
Subtotal
varies
varies
varies
varies
varies
varies
varies
varies
varies
15
$
1,427.66
Surety
bond
guaranteeing
payment
into
a
closure
or
post­
closure
trust
fund
(
264.143(
b),
265.143(
b),
264.145(
b)
and
265.145(
b)),
or
guaranteeing
performance
of
closure
or
post­
closure
care
(
264.143(
c)
and
264.145(
c))

Establish
surety
bond
and
trust
agreement
0
0
4.00
1.50
2.00
0.50
$
736.00
$
0.00
$
0.00
0
$
0.00
Submit
orginally
signed
duplicates
of
bond/
trust
agreement
0
0
0.00
0.00
0.00
0.50
$
18.00
$
0.00
$
3.20
0
$
0.00
Submit
evidence
of
alternate
financial
mechanisms,
if
bond
cancelled
0
0
0.00
0.00
0.00
1.00
$
36.00
$
0.00
$
3.20
0
$
0.00
Increase
penal
sum
amount,
if
cost
estimate
modified
3
0
2.25
0.75
1.00
0.00
$
388.00
$
0.00
$
0.00
15
$
1,485.07
Submit
evidence
of
increase
in
cost
estimate
3
0
0.00
0.00
0.00
1.00
$
36.00
$
0.00
$
3.20
4
$
150.04
Subtotal
varies
varies
varies
varies
varies
varies
varies
varies
varies
19
$
1,635.11
85
EXHIBIT
6
(
continued)

ANNUAL
ESTIMATED
RESPONDENT
BURDEN
AND
COST
FINANCIAL
REQUIREMENTS
Number
of
Respondents
Hours
and
Costs
per
Respondent
Total
Hours
and
Costs
Legal
Manager
Technical
Clerical
Labor
Capital/
Total
Total
Interim
$
116.00/
$
84.00/
$
64.00/
$
36.00/
Cost
Startup
O&
M
Hours
per
Cost
per
INFORMATION
COLLECTION
ACTIVITY
Permitted
Status
hour
hour
hour
hour
$/
Year
Cost
Cost
Year
Year
Closure
or
Post­
Closure
Letter
of
Credit
(
264.143(
d),
265.143(
c),
264.145(
d),
and
265.145c))

Obtain
and
submit
letter
of
credit
from
issuing
institution
0
0
4.00
1.50
2.00
0.50
$
736.00
$
0.00
$
0.33
0
$
0.00
Write
and
submit
letter
to
accompany
letter
of
credit
0
0
1.25
0.25
0.00
0.50
$
184.00
$
0.00
$
0.33
0
$
0.00
Submit
originally
signed
duplicate
of
the
trust
agreement
0
0
0.00
0.00
0.00
0.50
$
18.00
$
0.00
$
3.20
0
$
0.00
Increase
credit
amount,
if
cost
estimate
modified
3
0
0.75
0.50
0.75
0.00
$
177.00
$
0.00
$
0.00
8
$
677.47
Submit
evidence
of
increase
in
cost
estimate
3
0
0.00
0.00
0.00
1.00
$
36.00
$
0.00
$
3.20
4
$
150.04
Subtotal
varies
varies
varies
varies
varies
varies
varies
varies
varies
11
$
827.51
Closure
or
Post­
Closure
Insurance
(
264.143(
e),
265.143(
d),
264.145(
e),
and
265.145(
d))

Establish
closure
or
post­
closure
insurance
policy
0
0
4.00
1.50
2.00
0.50
$
736.00
$
0.00
$
0.00
0
$
0.00
Submit
insurance
policy
certificate
to
EPA
0
0
0.00
0.00
0.00
0.50
$
18.00
$
0.00
$
0.33
0
$
0.00
Submit
letter
from
insurer
(
for
some
interim
status
facilities
only)
0
0
0.00
0.00
0.00
1.00
$
36.00
$
0.00
$
0.33
0
$
0.00
Increase
insured
amount,
if
cost
estimate
modified
3
0
2.50
0.50
0.00
0.00
$
332.00
$
0.00
$
0.00
11
$
1,270.73
Submit
evidence
of
increase
in
cost
estimate
3
0
0.00
0.00
0.00
1.00
$
36.00
$
0.00
$
3.20
4
$
150.04
Subtotal
varies
varies
varies
varies
varies
varies
varies
varies
varies
15
$
1,420.77
Financial
Test
and
Corporate
Guarantee
(
264.143(
f),
265.143(
e),
264.145(
f),
and
265.145(
e))

Write
and
submit
letter
signed
by
chief
financial
officer
0
0
1.00
0.25
2.00
0.75
$
292.00
$
0.00
$
0.33
0
$
0.00
Submit
copy
of
public
accountant's
report
and
special
report
0
0
0.00
0.00
0.00
1.00
$
36.00
$
0.00
$
3.20
0
$
0.00
Submit
updated
information
annually
667
99
0.00
0.00
0.00
4.00
$
144.00
$
0.00
$
3.20
3,062
$
112,681.60
Write
and
submit
notice
of
intent
to
establish
other
financial
assurance,
if
applicable
13
2
3.25
0.25
0.00
0.50
$
416.00
$
0.00
$
0.33
61
$
6,374.01
Write
and
submit
any
additional
reports
of
financial
condition
13
2
2.25
0.25
1.00
0.50
$
364.00
$
0.00
$
3.20
61
$
5,621.83
Submit
corporate
guarantee
from
parent
corporation
0
0
0.00
0.00
0.00
1.00
$
36.00
$
0.00
$
0.33
0
$
0.00
Subtotal
varies
varies
varies
varies
varies
varies
varies
varies
varies
3,184
$
124,677.44
Coverage
for
Sudden
or
Nonsudden
Accidental
Occurrences
(
264.147(
a),
265.147(
a),
264.147(
b),
and
265.147(
b))

Prepare,
write,
and
submit
a
claim
notification,
if
applicable
7
1
2.50
1.00
0.00
0.50
$
392.00
$
0.00
$
0.33
31
$
3,003.29
Prepare,
write,
and
submit
notification
of
reduction
of
liability
coverage
amount
if
applicable
27
4
2.00
1.00
0.50
0.50
$
366.00
$
0.00
$
0.33
122
$
11,217.02
Subtotal
varies
varies
varies
varies
varies
varies
varies
varies
varies
153
$
14,220.31
86
EXHIBIT
6
(
continued)

ANNUAL
ESTIMATED
RESPONDENT
BURDEN
AND
COST
FINANCIAL
REQUIREMENTS
Number
of
Respondents
Hours
and
Costs
per
Respondent
Total
Hours
and
Costs
Legal
Manager
Technical
Clerical
Labor
Capital/
Total
Total
Interim
$
116.00/
$
84.00/
$
64.00/
$
36.00/
Cost
Startup
O&
M
Hours
per
Cost
per
INFORMATION
COLLECTION
ACTIVITY
Permitted
Status
hour
hour
hour
hour
$/
Year
Cost
Cost
Year
Year
Variance
of
financial
responsibility
regulations
(
265.147(
c))

Prepare
and
submit
petition
for
variance
0
0
0.50
0.50
0.50
0.00
$
132.00
$
0.00
$
3.20
0
$
0.00
Subtotal
0
0
0.50
0.50
0.50
0.00
$
264.00
$
0.00
$
3.20
0
$
0.00
Financial
Test
for
Liability
Coverage
(
264.147(
f)
and
265.147(
f))

Prepare,
write,
and
submit
letter
signed
by
chief
financial
officer
0
0
1.00
0.25
2.00
0.75
$
292.00
$
0.00
$
0.33
0
$
0.00
Submit
copy
of
public
accountant's
report
and
special
report
0
0
0.00
0.00
0.00
1.00
$
36.00
$
0.00
$
3.20
0
$
0.00
Submit
updated
information
annually
333
50
0.00
0.00
0.00
4.00
$
144.00
$
0.00
$
3.20
1,531
$
56,340.80
Submit
evidence
of
insurance
obtained
for
entire
liability
coverage,
if
applicable
13
2
0.00
0.00
0.00
2.00
$
72.00
$
0.00
$
3.20
31
$
1,151.31
Subtotal
varies
varies
varies
varies
varies
varies
varies
varies
varies
1,562
$
57,492.11
Guarantee
for
Liability
Coverage
(
264.147(
g)
and
265.147(
g))

Obtain
and
submit
written
guarantee
from
parent
corporation
0
0
0.50
0.50
0.50
0.50
$
150.00
$
0.00
$
0.33
0
$
0.00
Submit
letter
from
guarantor's
chief
financial
officer
0
0
0.00
0.00
0.00
1.00
$
36.00
$
0.00
$
0.33
0
$
0.00
Submit
updated
information
annually
333
50
0.00
0.00
0.00
4.00
$
144.00
$
0.00
$
3.20
1,531
$
56,340.80
Subtotal
varies
varies
varies
varies
varies
varies
varies
varies
varies
1,531
$
56,340.80
Letter
of
Credit
for
Liability
Coverage
(
264.147(
h)
and
265.147(
h))

Obtain
and
submit
stand­
by
letter
of
credit
0
0
4.00
1.00
2.00
1.00
$
712.00
$
0.00
$
0.33
0
$
0.00
Subtotal
0
0
4.00
1.00
2.00
1.00
$
712.00
$
0.00
$
0.33
0
$
0.00
Liability
Insurance
(
264.147(
a)
and
(
b),
and
265.147(
a)
and
(
b))

Obtain
and
submit
insurance
policy
documentation
0
2
4.00
1.00
2.00
1.00
$
712.00
$
0.00
$
3.20
16
$
1,430.40
Subtotal
0
2
4.00
1.00
2.00
1.00
$
712.00
$
0.00
$
3.20
16
$
1,430.40
Surety
Bond
for
Liability
Coverage
(
264.147(
i)
and
265.147(
i))

Obtain
surety
bond
and
submit
copy
to
EPA
0
2
4.00
1.00
2.00
1.00
$
712.00
$
0.00
$
0.33
16
$
1,424.66
Subtotal
0
2
4.00
1.00
2.00
1.00
$
712.00
$
0.00
$
0.33
16
$
1,424.66
Trust
Fund
for
Liability
Coverage
(
264.147(
j)
and
265.147(
j))

Establish
trust
fund
0
2
4.50
1.50
1.00
1.00
$
748.00
$
0.00
$
0.00
16
$
1,496.00
Submit
originally
signed
duplicate
of
trust
agreement
to
EPA
0
2
0.00
0.00
0.00
1.00
$
36.00
$
0.00
$
3.20
2
$
78.40
Subtotal
0
2
4.50
1.50
1.00
2.00
$
784.00
$
0.00
$
3.20
18
$
1,574.40
Incapacity
of
Owners
or
Operators,
Guarantors,
or
Financial
Institutions
(
264.148
and
265.148)

Submit
notice
indicating
commencement
of
bankruptcy
proceedings
13
2
0.00
0.00
0.00
1.00
$
36.00
$
0.00
$
0.33
15
$
556.21
Subtotal
13
2
0.00
0.00
0.00
1.00
$
36.00
$
0.00
$
0.33
15
$
556.21
87
EXHIBIT
6
(
continued)

ANNUAL
ESTIMATED
RESPONDENT
BURDEN
AND
COST
FINANCIAL
REQUIREMENTS
Number
of
Respondents
Hours
and
Costs
per
Respondent
Total
Hours
and
Costs
Legal
Manager
Technical
Clerical
Labor
Capital/
Total
Total
Interim
$
116.00/
$
84.00/
$
64.00/
$
36.00/
Cost
Startup
O&
M
Hours
per
Cost
per
INFORMATION
COLLECTION
ACTIVITY
Permitted
Status
hour
hour
hour
hour
$/
Year
Cost
Cost
Year
Year
Use
of
State­
Required
Mechanisms
(
264.149)
and
265.149)

Submit
letter
from
owner
or
operator
0
2
0.00
0.00
0.00
4.00
$
144.00
$
0.00
$
0.33
8
$
285.77
Submit
written
evidence
of
establishment
of
State­
required
financial
assurance
mechanism
0
2
0.00
0.00
0.00
2.00
$
72.00
$
0.00
$
3.20
4
$
148.90
Subtotal
0
2
0.00
0.00
0.00
6.00
$
216.00
$
0.00
$
3.53
12
$
434.67
State
Assumption
of
Responsibility
(
264.150
and
265.150)

Prepare
and
submit
letter
from
owner
or
operator
0
2
1.00
5.00
2.00
0.50
$
682.00
$
0.00
$
0.33
17
$
1,351.01
Obtain
and
submit
letter
from
State
describing
assumption
of
responsiblity
0
2
0.00
0.00
0.00
1.00
$
36.00
$
0.00
$
0.33
2
$
71.93
Prepare
and
submit
any
additional
information
requested
by
EPA
0
0.0
0.75
0.25
0.75
0.25
$
165.00
$
0.00
$
3.20
0
$
3.33
Subtotal
varies
varies
varies
varies
varies
varies
varies
varies
varies
19
$
1,426.28
Estimated
decrease
in
Federally­
required
cost
due
to
facilities
using
State­
required
mechanisms
0
2
5.00
3.00
11.00
3.00
$
1,644.00
$
0.00
$
0.00
44
$
3,255.12
Subtotal
0
2
5.00
3.00
11.00
3.00
$
1,644.00
$
0.00
$
0.00
44
$
3,255.12
TOTAL
varies
varies
0.00
varies
varies
varies
varies
varies
varies
17,436
$
1,203,229.69
88
EXHIBIT
7
ANNUAL
ESTIMATED
RESPONDENT
BURDEN
AND
COST
PERMIT
CONDITIONS
Number
of
Respondents
Hours
and
Costs
per
Respondent
Total
Hours
and
Costs
Legal
Manager
Technical
Clerical
Labor
Capital/
Total
Total
Interim
$
116.00/
$
84.00/
$
64.00/
$
36.00/
Cost
Startup
O&
M
Hours
per
Cost
per
INFORMATION
COLLECTION
ACTIVITY
Permitted
Status
hour
hour
hour
hour
$/
Year
Cost
Cost
Year
Year
Conditions
applicable
to
all
permits
(
270.30(
h)
and
(
l))

Prepare
and
submit
information
requested
by
EPA
173
N/
A
0.00
0.25
1.00
0.25
$
94.00
$
0.00
$
3.20
259.50
$
16,815.60
Prepare
and
submit
notice
of
planned
physical
alterations
or
additions
155
N/
A
0.00
0.25
1.00
0.25
$
94.00
$
0.00
$
0.33
232.50
$
14,621.15
Prepare
and
submit
notice
of
planned
changes
or
activities
which
may
result
in
noncompliance
78
N/
A
0.00
0.25
1.00
0.25
$
94.00
$
0.00
$
0.33
117.00
$
7,357.74
Prepare
and
submit
letter
certifying
compliance
39
N/
A
0.00
0.25
1.00
0.25
$
94.00
$
0.00
$
0.33
58.50
$
3,678.87
Prepare
and
submit
monitoring
reports
1171
N/
A
0.00
0.25
8.00
0.25
$
542.00
$
0.00
$
3.20
9953.50
$
638,429.20
Prepare
and
submit
reports
of
compliance
or
noncompliance
with
compliance
schedule
13
N/
A
0.00
0.25
2.00
1.00
$
185.00
$
0.00
$
3.20
43.32
$
2,508.71
Compile
and
submit
information
for
24­
hour
reporting
of
a
release
of
hazardous
waste,
a
fire,

or
an
explosion
13
N/
A
0.00
0.50
8.00
0.50
$
572.00
$
0.00
$
3.20
119.97
$
7,667.42
Prepare
and
submit
notice
of
noncompliance
due
to
a
release,
fire,
or
explosion
13
N/
A
0.00
0.50
4.00
0.50
$
316.00
$
0.00
$
0.33
66.65
$
4,216.68
Prepare
and
submit
a
report
of
other
noncompliance
27
N/
A
0.00
0.50
2.00
0.50
$
188.00
$
0.00
$
3.20
79.98
$
5,097.39
Prepare
and
submit
omitted
or
corrected
information
13
N/
A
0.00
0.25
0.50
0.25
$
62.00
$
0.00
$
3.20
13.33
$
869.12
TOTAL
varies
N/
A
varies
varies
varies
varies
varies
varies
varies
10,944.25
$
701,261.87
89
EXHIBIT
8
TOTAL
ESTIMATED
RESPONDENT
BURDEN
AND
COST
SUMMARY
Total
Total
Total
Total
Total
Hours
per
Capital
per
O&
M
per
Labor
Cost
Cost
per
EXHIBIT
Year
Year
Year
per
Year
Year
Exhibit
1
General
Facility
Standards
475,561
$
0
$
589,008
$
36,404,889
$
36,993,896
Exhibit
2
Recordkeeping
Requirements
144,935
$
12,658
$
0
$
6,741,872
$
6,754,530
Exhibit
3
Contingency
Plan
and
Emergency
Procedures
364
$
0
$
103
$
23,008
$
23,112
Exhibit
4
Ground­
Water
Monitoring
Requirements
1,599
$
0
$
42
$
106,873
$
106,915
Exhibit
5
Closure
and
Post­
Closure
Requirements
1,473
$
0
$
31,829
$
91,798
$
123,627
Exhibit
6
Financial
Requirements
17,436
$
0
$
3,222
$
1,200,007
$
1,203,230
Exhibit
7
Permit
Conditions
10,944
$
0
$
4,608
$
696,654
$
701,262
TOTAL
652,312
12,658
628,812
45,265,102
$
45,906,572
90
EXHIBIT
9
ESTIMATED
ANNUAL
AGENCY
BURDEN
AND
COST
Number
of
Respondents
Hours
and
Costs
per
Respondent
or
Activity
Total
Hours
and
Costs
Legal
Manager
Technical
Clerical
Labor
Capital/
Total
Total
$
60.42/
$
38.35/
$
26.91/
$
16.36/
Cost
Startup
O&
M
Hours
per
Cost
per
INFORMATION
COLLECTION
ACTIVITY
Permitted
Interim
hour
hour
hour
hour
$/
Year
Cost
Cost
Year
Year
GENERAL
FACILITY
OPERATING
REQUIREMENTS
Foreign
Shipment
Import
Report
Review
foreign
shipment
import
report
52
3
0.00
0.00
1.00
0.00
39.44
0.00
0.00
55.32
$
2,181.82
Review
of
records
during
inspections
13
0
0.00
0.00
1.00
0.00
$
39.44
$
0.00
$
0.00
13.00
$
512.72
Subtotal
varies
varies
0.00
0.00
varies
varies
varies
$
0.00
$
0.00
68.32
$
2,694.54
RECORDKEEPING
REQUIREMENTS
Operating
Record
On­
site
review
of
the
operating
record
864
58
0.00
0.00
2.00
0.00
78.88
0.00
0.00
1,844.00
$
72,727.36
Subtotal
864
58
0.00
0.00
2.00
0.00
78.88
0.00
0.00
1,844.00
$
72,727.36
CONTINGENCY
PLAN
AND
EMERGENCY
PROCEDURES
Contingency
Plan
On­
site
review
of
the
contingency
plan
1,333
198
0.00
0.00
0.50
0.00
19.72
0.00
0.00
765.50
$
30,191.32
Emergency
Reporting
Requirements
Review
owner/
operator's
emergency
report
13
2
0.00
0.00
1.00
0.00
$
39.44
$
0.00
$
0.00
15.31
$
603.83
Subtotal
varies
varies
0.00
0.00
varies
varies
varies
$
0.00
$
0.00
780.81
$
30,795.15
RELEASES
FROM
SOLID
WASTE
MANAGEMENT
UNITS
Review
demonstration
to
terminate
compliance
period
0
N/
A
0.00
0.00
4.00
0.10
$
159.64
$
0.00
$
0.00
0.00
$
0.00
Review
and
approve
proposed
sampling
procedures
13
N/
A
0.00
0.00
2.00
0.00
$
78.88
$
0.00
$
0.00
26.00
$
1,025.44
Subtotal
varies
0
0.00
0.00
varies
varies
varies
0.00
0.00
26.00
$
1,025.44
CLOSURE
AND
POST­
CLOSURE
Review
closure
plans
N/
A
0
0.00
0.00
15.00
0.00
$
591.60
$
0.00
$
0.00
0.00
$
0.00
Review
closure
plan
amendment
notifications
N/
A
4
0.00
0.00
2.00
0.00
$
78.88
$
0.00
$
0.00
7.80
$
307.63
Review
partial
or
final
closure
notifications
and
closure
plans
(
interim
status
facilities)
19
9
0.00
0.00
2.00
0.00
$
78.88
$
0.00
$
0.00
56.00
$
2,208.64
Review
demonstration
for
extension
for
treatment
storage,
or
removal
of
hazardous
waste
4
2
0.00
0.00
2.00
0.00
$
78.88
$
0.00
$
0.00
11.20
$
441.73
Review
demonstration
for
extension
of
closure
period
4
2
0.00
0.00
1.00
0.00
$
39.44
$
0.00
$
0.00
5.60
$
220.86
Review
demonstration
for
receiving
non­
hazardous
waste
1
0
0.00
0.00
0.50
0.00
$
19.72
$
0.00
$
0.00
0.70
$
27.61
Review
closure
certifications
19
9
0.00
0.00
4.00
0.00
$
157.76
$
0.00
$
0.00
112.00
$
4,417.28
Review
survey
plat
1
4
0.00
0.00
1.00
0.00
$
39.44
$
0.00
$
0.00
4.50
$
177.48
Review
post­
closure
plan
N/
A
0
0.00
0.00
15.00
0.00
$
591.60
$
0.00
$
0.00
0.00
$
0.00
Review
post­
closure
plan
amendment
notifications
and
amended
plans
N/
A
1
0.00
0.00
2.00
0.00
$
78.88
$
0.00
$
0.00
2.80
$
110.43
Review
post­
closure
plan
modifications
N/
A
1
0.00
0.00
2.00
0.00
$
78.88
$
0.00
$
0.00
1.40
$
55.22
Review
resubmitted
plans
N/
A
0
0.00
0.00
2.00
0.00
$
78.88
$
0.00
$
0.00
0.14
$
5.52
Review
petition
to
extend
or
reduce
the
post­
closure
care
period
N/
A
1
0.00
0.50
1.00
0.00
$
66.34
$
0.00
$
0.00
2.10
$
92.87
Review
hazardous
waste
disposal
records
2
7
0.00
0.00
1.00
0.00
$
39.44
$
0.00
$
0.00
9.00
$
354.96
Review
hazardous
waste
notation
certification
2
7
0.00
0.00
1.00
0.00
$
39.44
$
0.00
$
0.00
9.00
$
354.96
Review
post­
closure
care
certification
0
0
0.00
0.00
4.00
0.00
$
157.76
$
0.00
$
0.00
0.00
$
0.00
Subtotal
varies
varies
0.00
varies
varies
varies
varies
$
0.00
$
0.00
222.24
$
8,775.19
91
EXHIBIT
9
(
continued)

ESTIMATED
ANNUAL
AGENCY
BURDEN
AND
COST
Number
of
Respondents
Hours
and
Costs
per
Respondent
or
Activity
Total
Hours
and
Costs
Legal
Manager
Technical
Clerical
Labor
Capital/
Total
Total
$
60.42/
$
38.35/
$
26.91/
$
16.36/
Cost
Startup
O&
M
Hours
per
Cost
per
INFORMATION
COLLECTION
ACTIVITY
Permitted
Interim
hour
hour
hour
hour
$/
Year
Cost
Cost
Year
Year
FINANCIAL
REQUIREMENTS
Review
increases
in
sum
amounts,
if
cost
estimate
modified,
and
additional
reports
of
financial
conditions
0
0
0.00
0.00
8.00
0.00
$
315.52
$
0.00
$
0.00
0.00
$
0.00
Review
new
estimates
and
instruments
0
0
0.00
0.00
7.50
0.00
$
295.80
$
0.00
$
0.00
0.00
$
0.00
Review
annual
closure
cost
updates
to
reflect
inflation
0
0
0.00
0.00
0.50
0.00
$
19.72
$
0.00
$
0.00
0.00
$
0.00
Review
liability
claim
notifications
0
0
1.00
0.00
2.00
0.00
$
136.40
$
0.00
$
0.00
0.00
$
0.00
Review
and
approve
or
deny
petition
for
variance
0
59
0.00
0.50
1.00
0.00
$
66.34
$
0.00
$
0.00
88.50
$
3,913.77
Review
revisions
due
to
plan
changes
56
274
0.00
0.00
8.00
0.00
$
315.52
$
0.00
$
0.00
2,640.00
$
104,121.60
Review
updated
financial
test
and
corporate
guarantee
information
1,390
3,624
0.00
0.00
8.00
0.00
$
315.52
$
0.00
$
0.00
40,112.00
$
1,582,017.28
Review
bankruptcy
notifications
28
72
1.00
0.00
2.00
0.00
$
136.40
$
0.00
$
0.00
300.00
$
13,640.00
Review
State
assumptions
of
responsibility/

required
mechanism
documentation
0
0
0.00
0.00
2.00
0.00
$
78.88
$
0.00
$
0.00
0.00
$
0.00
Review
corrective
action
financial
assurance
0
0
1.00
0.00
8.00
0.00
$
373.04
$
0.00
$
0.00
0.00
$
0.00
Subtotal
varies
varies
varies
varies
varies
0.00
varies
$
0.00
$
0.00
43,140.50
$
1,703,692.65
PERMIT
CONDITIONS
Review
submitted
information
173
0
0.00
0.25
1.00
0.10
$
54.77
$
0.00
$
0.00
233.55
$
9,475.47
Review
notice
of
planned
physical
alterations
or
additions
155
0
0.00
0.00
0.50
0.10
$
21.60
$
0.00
$
0.00
93.00
$
3,348.62
Review
notice
of
planned
changes
or
activities
78
0
0.00
0.25
0.50
0.10
$
35.05
$
0.00
$
0.00
66.30
$
2,734.02
Review
letter
certifying
compliance
39
0
0.00
0.25
0.50
0.10
$
35.05
$
0.00
$
0.00
33.15
$
1,367.01
Review
monitoring
reports
1171
0
0.00
0.00
5.00
0.00
$
197.20
$
0.00
$
0.00
5,855.00
$
230,921.20
Review
reports
of
compliance
or
noncompliance
13.33
0
0.00
0.00
1.00
0.10
$
41.32
$
0.00
$
0.00
14.66
$
550.85
Review
information
concerning
a
release,

fire,
or
explosion
13
0
0.00
0.00
0.50
0.10
$
21.60
$
0.00
$
0.00
8.00
$
287.98
Review
notices
and
reports
of
noncompliance
13
0
0.00
0.00
0.50
0.10
$
21.60
$
0.00
$
0.00
8.00
$
287.98
Review
reports
of
other
noncompliance
27
0
0.00
0.00
0.50
0.10
$
21.60
$
0.00
$
0.00
16.00
$
575.96
Review
corrected
information
13
0
0.00
0.00
0.50
0.25
$
24.43
$
0.00
$
0.00
10.00
$
325.65
Subtotal
varies
0
0.00
varies
varies
varies
varies
$
0.00
$
0.00
6,337.65
$
249,874.74
TOTAL
varies
varies
varies
varies
varies
varies
varies
varies
varies
52,419.52
$
2,069,585.06
92
EXHIBIT
10
TOTAL
ESTIMATED
AGENCY
BURDEN
AND
COST
SUMMARY
Total
Total
Hours
per
Cost
per
EXHIBIT
Year
Year
General
Facility
Standards
68
2,695
Recordkeeping
Requirements
1,844
72,727
Contingency
Plan
and
Emergency
Procedures
781
30,795
Releases
from
Solid
Waste
Management
Units
26
1,025
Closure
and
Post­
Closure
Requirements
222
8,775
Financial
Requirements
43,141
1,703,693
Permit
Conditions
6,338
249,875
TOTAL
52,420
$
2,069,585
EXHIBIT
11
TOTAL
AVERAGE
RESPONDENT
BURDEN
Average
Average
Reporting
Recordkeeping
Burden
Burden
EXHIBIT
(
Hours)
(
Hours)

Exhibit
1
General
Facility
Standards
113
113
Exhibit
2
Operating
Record
0
140
Exhibit
3
Contingency
Plan
and
Emergency
Procedures
0
0
Exhibit
4
Releases
from
Solid
Waste
Management
Units
1
0
Exhibit
5
Closure
and
Post­
Closure
Requirements
45
0
Exhibit
6
Financial
Requirements
12
0
Exhibit
7
Permit
Conditions
13
0
TOTAL
185
254
93
6(
e)
BOTTOM
LINE
BURDEN
HOURS
AND
COSTS
Exhibits
8
and
10
show
the
aggregate
burden
and
cost
to
respondents
and
the
government,
respectively.
The
bottom
line
burden
to
respondents
over
three
years
is
1,956,936
hours,
with
a
cost
of
$
137,719,716.
The
bottom
line
burden
to
the
Agency
over
three
years
is
157,260
hours,
at
a
cost
of
$
6,208,755.

6(
f)
REASONS
FOR
CHANGE
IN
BURDEN
This
ICR
is
a
comprehensive
description
of
the
total
respondent
burden
for
all
activities
related
to
general
facility
operating
requirements,
recordkeeping
requirements,
contingency
plan
and
emergency
reporting
requirements,
releases
from
solid
waste
management
units,
closure/
post­
closure
requirements,
financial
requirements,
corrective
action
management
unit
requirements,
and
conditions
applicable
to
all
permits.

The
respondent
universe
numbers
in
this
ICR
are
lower
than
those
estimated
for
the
2002
version
of
this
ICR.
Some
of
this
decrease
is
due
to
the
ongoing
consolidation
and
contraction
of
the
hazardous
waste
treatment,
storage,
and
disposal
industry,
and
some
is
due
to
more
accurate
RCRAInfo
data.

Because
of
these
revisions,
the
total
bottom­
line
burden
to
respondents
has
decreased
over
the
previous
ICR.
Whereas
the
previous
ICR
estimated
a
total
annual
respondent
burden
of
719,059
hours,
this
ICR
estimates
a
total
annual
respondent
burden
of
652,312.
EPA
believes
that
this
lower
burden
reflects
a
more
accurate
portrait
of
the
existing
burden
on
the
regulated
community.

6(
g)
BURDEN
STATEMENT
The
annual
public
reporting
burden
for
this
collection
of
information
is
estimated
to
average
185
hours
per
respondent,
and
the
annual
public
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
254
hours
per
respondent
(
see
Exhibit
11).
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
Number
EPA­
HQRCRA
2005­
0014,
which
is
available
for
online
viewing
at
www.
regulations.
gov,
or
in
person
viewing
at
the
RCRA
docket
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Avenue,
NW,
Washington,
D.
C.
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
is
(
202)
566­
0270.
An
electronic
version
of
the
94
public
docket
is
available
at
www.
regulations.
gov.
This
site
can
be
used
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,
D.
C.
20503,
Attention:
Desk
Officer
for
EPA.
Please
include
the
EPA
Docket
ID
Number
EPA­
HQ­
RCRA­
2005­
0014
and
OMB
Control
Number
2050­
0120
in
any
correspondence.
