SUPPORTING STATEMENT FOR 

INFORMATION COLLECTION REQUEST NUMBER 1189.18

“F019 LISTING AMENDMENT - PROPOSED RULE”

DRAFT

December 2006

Table of Contents

 TOC \f 

1.	IDENTIFICATION OF THE INFORMATION COLLECTION	1

1(a)	Title and Number of the Information Collection	1

1(b)	Short Characterization	1

2.	NEED FOR AND USE OF THE COLLECTION	2

2(a)	Need and Authority for the Collection	2

2(b)	Practical Utility and Users of the Data	2

3.	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA 2 

3(a)	Nonduplication	2

3(b)	Public Notice	3

3(c)	Consultations	3

3(d)	Effects of Less Frequent Collection	3

3(e)	General Guidelines	3

3(f)	Confidentiality	4

3(g)	Sensitive Questions	4

4.	THE RESPONDENTS AND THE INFORMATION REQUESTED	4

4(a)	Respondents and SIC/NAICS Codes	4

4(b)	Information Requested	4

5.	THE INFORMATION COLLECTED(AGENCY ACTIVITIES, COLLECTION METHODOLOGY,
AND INFORMATION MANAGEMENT	5

5(a)	Agency Activities	5

5(b)	Small Entity Flexibility	5

6.	ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION	5

6(a)	Estimating Respondent Burden	5

6(b)	Estimating Respondent Costs	5

6(c)	Estimating Agency Burden and Costs	6

6(d)	Estimating the Respondent Universe and Total Burden and Costs	6

6(e)	Bottom Line Burden Hours and Costs	9

6(f)	Reasons for Change in Burden	9

6(g)	Burden Statement	9

 

	EXHIBITS

Estimated Annual Respondent (Facility) Burden and Cost (Exhibit
1).........................................11

Estimated Annual Respondent (Facility) Burden for Existing ICRs

(Including Net Impact from F019 Listing amendment
ICR).........................................................12

1.	IDENTIFICATION OF THE INFORMATION COLLECTION tc \l1 "1.
IDENTIFICATION OF THE INFORMATION COLLECTION 

1(a)	Title and Number of the Information Collection tc \l2 "1(a)	Title
and Number of the Information Collection 

This Information Collection Request (ICR) is entitled “F019 Listing
Amendment - Proposed Rule,” EPA ICR Number 1189.18.

1(b)	Short Characterization tc \l2 "1(b)	Short Characterization 

Under Section 3001 of the Resource Conservation and Recovery Act (RCRA),
as amended, EPA is authorized to develop and promulgate regulations
identifying the characteristics of hazardous waste and listing
particular hazardous wastes which should be subject to EPA’s hazardous
waste regulatory system.  Under this authority, EPA promulgated
regulations at 40 CFR Part 261 that identify hazardous characteristics
(Subpart C) and list hazardous wastes (Subpart D).

EPA is proposing to amend the list of hazardous wastes from non-specific
sources under 40 CFR 261.31 by modifying the scope of EPA Hazardous
Waste No. F019, which currently reads: “Wastewater treatment sludges
from the chemical conversion coating of aluminum except from zirconium
phosphating in aluminum can washing when such phosphating is an
exclusive conversion coating process.”  EPA is proposing to amend the
F019 listing to exclude wastewater treatment sludges generated from zinc
phosphating, when zinc phosphating is used in the motor vehicle
manufacturing process, provided that the wastes are disposed in a
landfill unit that meets certain liner design criteria. Under the
proposed rule, the generators of such wastes may exclude these wastes
from the F019 listing provided they meet the conditions for the
exclusion.  In addition, EPA is proposing to require the generators to
keep records showing that their wastes were disposed in a landfill that
meets the specified design requirements. 

 

The motor vehicle manufacturing industry incorporates aluminum into
vehicle parts and bodies for the purpose of making them lighter-weight
and thus more capable of increasing gas mileage.  However, when aluminum
is incorporated into the body of an automobile, the conversion coating
step in the manufacturing process results in the generation of a
RCRA-listed hazardous waste F019 in the form of a wastewater treatment
sludge from the conversion process, while the wastewaters from the
conversion coating of steel in the same industry, does not generate a
listed hazardous waste.  By removing the regulatory controls under RCRA,
EPA is facilitating the use of aluminum in motor vehicles.  EPA believes
that the incorporation of aluminum will be advantageous to the
environment since lighter-weight vehicles are capable of achieving
increased fuel economy and associated decreased exhaust air emissions.  


In Sections 1 through 5 of this ICR, EPA presents a comprehensive
description of the information collection requirements in the proposed
rule.  In Section 6, EPA estimates the total annual incremental hour and
cost burden to respondents and the Agency under these requirements. 

In the following paragraph, EPA briefly describes the information
collection requirement covered in this ICR.

Records of Shipments for Generators

Under proposed 40 CFR 261.31(b)(4)(iii), the generator of wastewater
treatment sludges from the manufacturing of motor vehicles using a zinc
phosphating process must maintain on site for a minimum of three years
documentation and information sufficient to prove that the wastewater
treatment sludges to be exempted from the F019 listing meet the
condition of the listing (i.e., ensure that shipments of such waste are
placed in landfill units that are subject to certain liner design
criteria). 

2.	NEED FOR AND USE OF THE COLLECTION tc \l1 "2.	NEED FOR AND USE OF THE
COLLECTION 

	2(a)	Need and Authority for the Collection tc \l2 "	2(a)	Need and
Authority for the Collection 

EPA is requiring the information collection pursuant to RCRA Section
2002, which authorizes the EPA to prescribe regulations, including
information collection requirements, as are necessary to carry out the
requirements under the RCRA statute. The proposed rule requires
generators to maintain on site for a minimum of three years
documentation demonstrating that each shipment of waste was received by
a landfill unit that is subject to or meets the landfill design criteria
set out in the listing description.  This recordkeeping requirement is
needed in order for the generator to demonstrate to the regulatory
agencies that each shipment of its waste was sent to an appropriate
landfill.

2(b)	Practical Utility and Users of the Data tc \l2 "2(b)	Practical
Utility and Users of the Data 

The recordkeeping requirement will enable regulatory agencies to track
shipments of excluded wastes for compliance and enforcement purposes. 
It is consistent with normal business recordkeeping practices, and is
not expected to impose any additional paperwork burden on generators.

3.	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA tc \l1
"3.	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA 

3(a)	Nonduplication tc \l2 "3(a)	Nonduplication 

None of the information required by the proposed rule would duplicate
information required by existing RCRA regulations.

3(b)	Public Notice tc \l2 "3(b)	Public Notice 

In compliance with the Paperwork Reduction Act of 1995, EPA has issued a
public notice  in the Federal Register ([Insert Notice Date and
Citation]).  The public comment period extends through [Insert Date]. 
To assist the public in commenting on the proposal, EPA raised a few
issues in the preamble to the proposed rule and asked for the public to
comment on them.  At the end of the comment period, EPA will review
public comments received in response to the notice and will address
comments received, as appropriate.

3(c)	Consultations tc \l2 "3(c)	Consultations 

On April 22, 2004, EPA through a posting on EPA’s website, indicated
that the Agency was in the process of considering a possible amendment
to the F019 hazardous waste listing under RCRA.  This possible amendment
would exclude waste water treatment sludges from the zinc phosphating
processes at automotive assembly plants in the motor vehicle
manufacturing industry when concentrations of constituents of concern in
those wastes fell below risk-based exemption levels.  On the F019
webpage, EPA provided waste sampling data and the methodology that the
Agency would use in considering the revision of the F019 listing using a
concentration-based approach.   Interested parties were invited to
review and comment on the information collected to support the possible
amendment that EPA was considering.  The comment period for the web
posting closed on June 1, 2005.  Twelve comments were received.   All
commenters supported a revision to the F019 listing, although some
expressed concerns regarding testing conditions for potential chemicals
of concern in the waste and how the concentration-based exemption would
be structured. 

3(d)	Effects of Less Frequent Collection tc \l2 "3(d)	Effects of Less
Frequent Collection 

EPA has carefully considered the burden imposed upon the regulated
community by the proposed rule.  EPA is confident that those activities
required of respondents are necessary, and to the extent possible, the
Agency has attempted to minimize the burden imposed.  EPA believes
strongly that, if the minimum information collection requirements of the
proposed rule are not met, neither the industry nor EPA will be able to
ensure compliance with the requirements for demonstrating that the
wastes are nonhazardous.

3(e)	General Guidelines tc \l2 "3(e)	General Guidelines 

This ICR adheres to the guidelines stated in the Paperwork Reduction Act
of 1995, OMB’s implementing regulations, EPA’s ICR Handbook, and
other applicable OMB guidance.

3(f)	Confidentiality tc \l2 "3(f)	Confidentiality 

Section 3007(b) of RCRA and 40 CFR Part 2, Subpart B, which defines
EPA’s general policy on public disclosure of information, contain
provisions for confidentiality.  However, the Agency does not anticipate
that businesses will assert a claim of confidentiality covering all or
part of the proposed rule.  If such a claim were asserted, EPA must and
will treat the information in accordance with the regulations cited
above.  EPA also will assure that this information collection complies
with the Privacy Act of 1974 and OMB Circular 108.

3(g)	Sensitive Questions tc \l2 "3(g)	Sensitive Questions 

No questions of a sensitive nature are included in the information
collection requirements associated with the proposed rule.

4.	THE RESPONDENTS AND THE INFORMATION REQUESTED tc \l1 "4.	THE
RESPONDENTS AND THE INFORMATION REQUESTED 

4(a)	Respondents and SIC/NAICS Codes tc \l2 "4(a)	Respondents and
SIC/NAICS Codes 

The following is a list of North American Industrial Classification
System (NAICS) codes associated with the facilities most likely to be
affected by the information collection requirements covered in this ICR.

NAICS Code			Industrial Sector

336111			Automobile Manufacturing

336112			Light Trucks & Utility Vehicle Manufacturing

4(b)	Information Requested

Under proposed 40 CFR 261.31(b)(4)(iii), generators must maintain on
site for a minimum of three years documentation and information
sufficient to prove that the wastewater treatment sludges to be
exem瑰摥映潲⁭桴⁥う㤱氠獩楴杮洠敥⁴桴⁥潣摮瑩潩
⁮景琠敨氠獩楴杮‮吠敨猠楨灰湩⁧敲潣摲⁳潷汵⁤瑡
愠洠湩浩浵挠湯慴湩琠敨映汯潬楷杮椠普牯慭楴湯ഺ

●          Name and address of the generating facility;

●          Brief description of the industrial process that generated
the wastes;

●         Quantity of wastes that were shipped to a landfill 

●         Name of transporter and date the wastes were shipped;

●        Name of landfill receiving the wastes, quantity of wastes
received; by the               landfill, and date the wastes were
received by the landfill.

5.	THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, COLLECTION
METHODOLOGY, AND INFORMATION MANAGEMENT

5(a)	Agency Activities

The Agency is not requiring waste generators to submit any information
for its review and approval under the proposed rule.  As specified
earlier, the Agency is instead proposing that the waste generators
maintain on site for a minimum of three years documentation and
information sufficient to prove that the wastewater treatment sludges to
be exempted from the F019 listing meet the condition of the listing. 
Therefore, the Agency activities associated with the proposed rule
relate to ensuring compliance with the recordkeeping requirements.	

5(b)	Small Entity Flexibility

The conditional exclusion is intended to be de-regulatory, and would
relieve both small and large waste generators from the RCRA hazardous
waste program requirements, as specified. In addition, EPA has kept the
paperwork requirements under the conditional exclusion as streamlined
and as consistent with standard industry practices as possible, to
thereby minimize the burden on both large and small entities.

 tc \l1 "5.	THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, COLLECTION
METHODOLOGY, AND INFORMATION MANAGEMENT5(a)	Agency ActivitiesThe Agency
is not requiring waste generators to submit any information for its
review and approval under the proposed rule.  As specified earlier, the
Agency is instead proposing that the waste generators maintain on site
for a minimum of three years documentation and information sufficient to
prove that the wastewater treatment sludges to be exempted from the F019
listing meet the condition of the listing.  Therefore, the Agency
activities associated with the proposed rule relate to ensuring
compliance with the recordkeeping requirements.	5(b)	Small Entity
FlexibilityThe conditional exclusion is intended to be de-regulatory,
and would relieve both small and large waste generators from the RCRA
hazardous waste program requirements, as specified.  In addition, EPA
has kept the paperwork requirements under the conditional exclusion as
streamlined and as consistent with standard industry practices as
possible, to thereby minimize the burden on both large and small
entities. 

6.	ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION tc \l1 "6.
ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION 

6(a)	Estimating Respondent Burden

In Exhibit 1, EPA estimates the respondent burden associated with the
new paperwork requirements in the proposed rule.  As shown in the
exhibit, EPA estimates that the total annual respondent burden for the
new paperwork requirements in the rule is approximately 35 hours per
year.

6(b)	Estimating Respondent Costs

EPA estimates that the total annual respondent cost for the new
paperwork requirements in the rule is approximately $2,600.  This cost
includes annual labor, capital, and operation and maintenance (O&M)
costs to be incurred by respondents affected by the information
collection requirements covered in this ICR.  Specific data and/or
assumptions used in developing these costs are described below.

Labor Costs 

For purposes of this analysis, EPA estimates an average hourly
respondent labor cost of $114 for legal staff, $89 for managerial staff,
$59 for technical staff, and $31 for clerical staff.  These estimates
include overhead and fringe costs and are based on the 2004 labor wage
rate data used in the “Supporting Statement for Information Collection
Request Nr. 801.15: Requirements for Generators, Transporters, & Waste
Management Facilities Under the RCRA Hazardous Waste Manifest System.”

Annual Capital and Operation & Maintenance Costs

Capital costs usually include any produced physical good needed to
provide the needed information, such as machinery, computers, and other
equipment.  EPA does not anticipate that respondents will incur capital
costs in carrying out the information collection requirements of the
proposed rule.

O&M costs are those costs associated with paperwork requirements
incurred continually over the life of the ICR.  They are defined by the
EPA as “the recurring dollar amount of costs associated with O&M or
purchasing services.” EPA does not anticipate that respondents will
incur O&M costs in carrying out the information collection requirements
of the proposed rule.

6(c)	Estimating Agency Burden and Costs

The annual burden and costs to the Agency for collecting information
under the rule would be negligible.  This is because the Agency is not
requiring waste generators to submit any information for its review and
approval under the proposed rule.

6(d)	Estimating the Respondent Universe and Total Burden and Costs

	

	In Exhibit 1, EPA provides estimates of the annual number of
respondents that will be required to comply with the new paperwork
requirements in the proposed rule.  In the same exhibit, EPA estimates
respondent burden and costs associated with these requirements.  Table 1
presents the number of respondents that are expected to participate
under the rule.  As of year-end 2005, EPA estimated that there are 68
facilities that are generating or have the potential to generate
wastewater treatment sludges using the zinc 

phosphating process.  The universe of 68 facilities includes 15
facilities that are delisted for F019, 14 facilities that have not been
delisted for F019, and 39 facilities which could also choose to
conversion coat aluminum in the future.



Table 1

	Number of Motor Vehicle Manufacturers Potentially 

	Affected by the Proposed F019 Listing Amendment

Type of manufacturer	

Number of Facilities	

Number of Facilities

Potentially Affected (F019 Generators not  Delisted)*



Automobiles 	

	26	

	6



Light Trucks & Utility Vehicles	

	42	

	8



Total Number of Facilities	

	68	

	14

       * The remaining facilities are either delisted or do not generate
a F019 hazardous waste.

	

	Respondent Burden and Cost

In the following paragraphs, EPA discusses the universe assumptions of
Table 1 in regard to the paperwork requirements in the proposed rule.  

Reading the Regulations

As shown in Exhibit 1, EPA estimates that 68 F019 sludge generators and
potential generators will read the rule amending the F019 listing to
exclude wastewater treatment sludges from zinc phosphating each year. 
EPA estimates the incremental labor hour burden for reading the
regulation to average 30 minutes per respondent. 

Record of Shipments for Generators	

Under 40 CFR 261.31(b)(4)(iii), generators must maintain on site for a
minimum of three years documentation and information sufficient to prove
that the wastewater treatment sludges to be exempted from the F019
listing meet the condition of the listing.  EPA expects that the
generators would incur negligible burden for this activity since they
would most likely keep such records as a standard business practice
(e.g., invoices or shipping papers).

	Total Respondent Burden and Cost

In Exhibit 2, EPA presents a summary of the total annual respondent
burden and costs associated with both new and existing paperwork
requirements.  The specific information collection activities of the new
paperwork requirements are described throughout this ICR, and the total
annual burden and cost estimates associated with them are calculated in
Exhibit 1, summarized in Exhibit 2, and briefly described below.  The
existing paperwork requirements are those that are contained in the
current RCRA regulations and that apply to generators of F019 sludge
using the zinc phosphating process.  These existing requirements, the
existing ICRs with which they are associated, and the total annual
burden and cost associated with them also are summarized in Exhibit 2
and briefly described below.

New Paperwork Requirements

Using the per respondent burden estimated in Section 6(a), the per
respondent costs estimated in Section 6(b), and the respondent universe
estimated in this section, Exhibit 1 illustrates the total respondent
burden and costs associated with all of the new information collection
activities in the proposed rule.  As noted above, this exhibit presents
the annual burden and costs over the three-year effective life of the
ICR.  The exhibit calculates the burden and cost of one-time activities
by dividing the total number of respondents by three.  In Exhibit 2, EPA
summarizes the total annual respondent burden and cost of these new
paperwork requirements derived in Exhibit 1.

Existing Paperwork Requirements

In addition to the new paperwork requirements in the proposed rule, EPA
also estimated the burden and cost savings that generators and
manufacturers would expect for no longer following the existing RCRA
information collection requirements for the excluded materials.  In
Exhibit 2, EPA presents the total annual respondent burden and cost
savings under the existing paperwork requirements, broken out by the two
existing EPA ICRs that are affected by the rule.  In developing Exhibit
2, EPA reviewed each of the affected ICRs to identify the existing
information collection activities that are currently undertaken by
generators and manufacturers, calculated the associated burden and costs
(or savings), and presented the totals in the exhibit.

The total costs in Exhibit 2 are broken down into labor and operation
and maintenance (O&M) costs.  In Section 6(b), EPA presents a discussion
of the capital and O&M costs associated with new paperwork requirements
from the rule.  In the following paragraph, EPA presents a brief
discussion of the O&M costs associated with each of the existing ICRs
that are affected by the rule.  

For the Biennial Report ICR (ICR No. 976), O&M costs are associated with
maintaining copies of Waste Generation and Management (GM) and Waste
Received from Off-Site (WR) forms.  For the Manifest ICR (ICR No. 801),
the O&M costs are associated with postage for sending and returning
copies of the manifest form.

6(e)	Bottom Line Burden Hours and Costs

Respondent Tally

In Exhibit 2, EPA presents the total annual respondent burden and cost
for both new and existing paperwork requirements associated with the
rule.  As described specifically in Section 6(d) above, these new and
existing paperwork requirements apply to generators of F019 sludge using
the zinc phosphating process.  As shown in Exhibit 2, the total annual
respondent burden for these new paperwork requirements is approximately
35 hours, at an annual cost of approximately $2,600.  As also shown in
Exhibit 2, the total annual respondent burden savings under the existing
paperwork requirements, which are associated with two existing EPA ICRs,
is approximately 960 hours, at annual cost savings of approximately
$69,900.  In the same Exhibit 2, EPA then combines the burden and cost
impacts under both new and existing paperwork requirements and estimates
the total annual respondent burden savings for all information
collection activities at approximately 920 hours and an annual cost
savings of approximately $67,300.

The bottom line respondent burden hours saved over the three-year period
covered by this ICR is approximately 2,760 hours, at a total cost
savings of $201,900.

6(f)	Reasons for Change in Burden 

In finalizing the conditional exclusion for the F019 listing at 40 CFR
261.31, EPA will relieve generators of F019 sludge using the zinc
phosphating process from existing RCRA Subtitle C regulations for that
waste.  These generators will only need to comply with the landfill
disposal conditions contained in the F019 listing description in order
to manage these wastes.

6(g)	Burden Statement

The annual public reporting and recordkeeping burden for this
collection of information is estimated to average 0.6 hours per
response.  However, in addition to the new paperwork requirements in the
rule, the Agency also estimated the annual respondent burden savings
that generators could expect as a result of no longer having to follow
information collection requirements under two existing EPA ICRs
(Biennial Report ICR and Manifest ICR).  Taking both the new proposed
and existing RCRA information collection requirements into account, EPA
expects the rule would result in a net reduction in annual reporting and
recordkeeping burden of 68 hours per response.  Burden means the total
time, effort, or financial resources expended by persons to generate,
maintain, retain, or disclose or provide information to or for a Federal
agency.  This includes the time needed to review instructions; develop,
acquire, install, and utilize technology and systems for the purposes of
collecting, validating, and verifying information, processing and
maintaining information, and disclosing and providing information;
adjust existing systems to comply with any previously applicable
instructions and requirements; train personnel to be able to respond to
a collection of information; search data sources; complete and review
the collection of information; and transmit or otherwise disclose the
information.  An Agency may not conduct or sponsor, and a person is not
required to respond to a collection of information unless it displays a
currently valid OMB control number.  The OMB control numbers for EPA's
regulations are listed in 40 CFR Part 9 and 48 CFR chapter 15.

To comment on the Agency’s need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID No.
EPA-HQ-RCRA-2004-0019, which is available for online viewing at
www.regulations.gov, or in person viewing at the OSWER Docket in the EPA
Docket Center (EPA/DC), EPA West, Room 3334, 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 OSWER Docket is (202) 566-0270.  An
electronic version of the 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, DC  20503, Attention: Desk
Officer for EPA.  Please include the EPA Docket ID Number
EPA-HQ-RCRA-2004-0019 and OMB Control Number 2050-0053 in any
correspondence. 



	Exhibit 1 - Estimated Annual Respondent (Facility) Burden and Cost



                                                           Hours and
Costs per Respondent (per Facility)                                     
                                             Total Hours and Costs



INFORMATION ACTIVITY	

Leg.

$114/Hr	

Mgr.

$89/Hr	

Tech.

$59/Hr	

Cler.

$31/Hr	

Respon. Hours/Yr	

Labor Cost/Yr	

Capital/

Startup Cost	

O & M 

Cost	

Number of Respondents

(Facilities)	

Total Hours/Yr	

Total Cost/Yr



Understanding the F019 Listing Amendment



Read the rule	

0.10	

0.10	

0.30	

0.00	

0.50	

$38.00	

$0.00	

$0.00	

68	

34	

$2,584.00



Facilities Claiming Conditional Exclusion from the F019 Listing 



Keep Records of 

Shipments	

0	

0	

0	

0.1	

0.1	

$3.10	

$0.00	

$0.00	

14	

1.4	

$43.40



Total	

0.10	

0.10	

0.30	

0.1	

0.60	

$41.10	

$0.00	

$0.00	

Varies	

35.4	

$2,627.40



Agency Data Sources:

Wage Rate Data:		“Economics Background Document - Estimate of
Potential Economic Impacts for USEPA’s Proposed Amendment to the RCRA
Hazardous Wastecode F019 to Exclude Motor Vehicle Manufacturing
Industries.”

“Supporting Statement for Information Collection Request Nr. 801.15:
Requirements for Generators, Transporters, & Waste Management Facilities
Under the RCRA Hazardous Waste Manifest System.”

Labor Hours:		“Supporting Statement for EPA Information Collection
Request 1189.17: Revision of RCRA Wastewater Treatment Exclusions for
Hazardous Waste Mixtures.”

“Supporting Statement for Information Collection Request Number
1189.11: Zinc Fertilizers Made from Recycled Hazardous Secondary
Materials.”



	Exhibit 2 - Estimated Annual Respondent (Facility) Burden for Existing
ICRS (Including Net Impact from F019 Listing Amendment ICR)



ICR Name	

ICR Number	

Respondents

(Facilities)	

Total Labor Hours	

Total Labor Cost	

Total O&M Cost	

Total Annual Cost



Biennial Report ICR	

976	

14	

# Facilities x Hours/Yr per Facility

14 x (0.3) = -4.2	

-$307.00	

# Facilities x O&M Cost/Yr per Facility

14 x ($0.02) = -$0.28	

     -$307.28



Manifest ICR	

801	

14	

# Facilities x Hours/Yr per Facility

14 x (68) = -952	

-$69,615.00	

# Facilities x O&M Cost/Yr per Facility

14 x ($0.06) = -$0.84	

-$69,615.84



	Subtotal Other ICRs 	

-956.2	

-$69,922.00	

-$1.12	

-$69,923.12



F019 Listing Amendment ICR	

1189.18	

Varies	

 35.4	

   $2,627.40	

 $0.00	

   $2,627.40 



	                                 Net Impact (F019 ICR + Other ICRs) =  
                                      	

-920.8	

-$67,294.60	

-$1.12	

-$67,295.72



 tc \l2 "6(a)	Estimating Respondent BurdenIn Exhibit 1, EPA estimates
the respondent burden associated with the new paperwork requirements in
the proposed rule.  As shown in the exhibit, EPA estimates that the
total annual respondent burden for the new paperwork requirements in the
rule is approximately 35 hours per year.6(b)	Estimating Respondent
CostsEPA estimates that the total annual respondent cost for the new
paperwork requirements in the rule is approximately $2,600.  This cost
includes annual labor, capital, and operation and maintenance (O&M)
costs to be incurred by respondents affected by the information
collection requirements covered in this ICR.  Specific data and/or
assumptions used in developing these costs are described below.Labor
Costs For purposes of this analysis, EPA estimates an average hourly
respondent labor cost of $114 for legal staff, $89 for managerial staff,
$59 for technical staff, and $31 for clerical staff.  These estimates
include overhead and fringe costs and are based on the 2004 labor wage
rate data used in the Supporting Statement for Information Collection
Request Nr. 801.15: Requirements for Generators, Transporters, & Waste
Management Facilities Under the RCRA Hazardous Waste Manifest
System.Annual Capital and Operation & Maintenance CostsCapital costs
usually include any produced physical good needed to provide the needed
information, such as machinery, computers, and other equipment.  EPA
does not anticipate that respondents will incur capital costs in
carrying out the information collection requirements of the proposed
rule.O&M costs are those costs associated with paperwork requirements
incurred continually over the life of the ICR.  They are defined by the
EPA as the recurring dollar amount of costs associated with O&M or
purchasing services. EPA does not anticipate that respondents will incur
O&M costs in carrying out the information collection requirements of the
proposed rule.6(c)	Estimating Agency Burden and CostsThe annual burden
and costs to the Agency for collecting information under the rule would
be negligible.  This is because the Agency is not requiring waste
generators to submit any information for its review and approval under
the proposed rule.6(d)	Estimating the Respondent Universe and Total
Burden and CostRespondent UniverseIn Exhibit 1, EPA provides estimates
of the annual number of respondents that will be required to comply with
the new paperwork requirements in the proposed rule.  In the same
exhibit, EPA estimates respondent burden and costs associated with these
requirements.  Table 1 presents the number of respondents that are
expected to participate under the rule.  As of year-end 2005, EPA
estimated that there are 68 facilities that are generating or have the
potential to generate wastewater treatment sludges using the zinc
phosphating process.  The universe of 68 facilities includes 15
facilities that are delisted for F019, 14 facilities that have not been
delisted for F019, and 39 facilities which could also choose to
conversion coat aluminum in the future.Table 1	Number of Motor Vehicle
Manufacturers Potentially 	Affected by the Proposed F019 Listing
AmendmentType of manufacturerNumber of FacilitiesNumber of
FacilitiesPotentially Affected (F019 Generators not 
Delisted)*Automobiles 	26	6Light Trucks & Utility Vehicles	42	8Total
Number of Facilities	68	14       * The remaining facilities are either
delisted or do not generate a F019 hazardous waste.	Respondent Burden
and CostIn the following paragraphs, EPA discusses the universe
assumptions of Table 1 in regard to the paperwork requirements in the
proposed rule.  Reading the RegulationsAs shown in Exhibit 1, EPA
estimates that 68 F019 sludge generators and potential generators will
read the rule amending the F019 listing to exclude wastewater treatment
sludges from zinc phosphating each year.  EPA estimates the incremental
labor hour burden for reading the regulation to average 30 minutes per
respondent. Record of Shipments for Generators	Under 40 CFR
261.31(b)(4)(iii), generators must maintain on site for a minimum of
three years documentation and information sufficient to prove that the
wastewater treatment sludges to be exempted from the F019 listing meet
the condition of the listing.  EPA expects that the generators would
incur negligible burden for this activity since they would most likely
keep such records as a standard business practice (e.g., invoices or
shipping papers).Total Respondent Burden and CostIn Exhibit 2, EPA
presents a summary of the total annual respondent burden and costs
associated with both new and existing paperwork requirements.  The
specific information collection activities of the new paperwork
requirements are described throughout this ICR, and the total annual
burden and cost estimates associated with them are calculated in Exhibit
1, summarized in Exhibit 2, and briefly described below.  The existing
paperwork requirements are those that are contained in the current RCRA
regulations and that apply to generators of F019 sludge using the zinc
phosphating process.  These existing requirements, the existing ICRs
with which they are associated, and the total annual burden and cost
associated with them also are summarized in Exhibit 2 and briefly
described below.New Paperwork RequirementsUsing the per respondent
burden estimated in Section 6(a), the per respondent costs estimated in
Section 6(b), and the respondent universe estimated in this section,
Exhibit 1 illustrates the total respondent burden and costs associated
with all of the new information collection activities in the proposed
rule.  As noted above, this exhibit presents the annual burden and costs
over the three-year effective life of the ICR.  The exhibit calculates
the burden and cost of one-time activities by dividing the total number
of respondents by three.  In Exhibit 2, EPA summarizes the total annual
respondent burden and cost of these new paperwork requirements derived
in Exhibit 1.Existing Paperwork RequirementsIn addition to the new
paperwork requirements in the proposed rule, EPA also estimated the
burden and cost savings that generators and manufacturers would expect
for no longer following the existing RCRA information collection
requirements for the excluded materials.  In Exhibit 2, EPA presents the
total annual respondent burden and cost savings under the existing
paperwork requirements, broken out by the two existing EPA ICRs that are
affected by the rule.  In developing Exhibit 2, EPA reviewed each of the
affected ICRs to identify the existing information collection activities
that are currently undertaken by generators and manufacturers,
calculated the associated burden and costs (or savings), and presented
the totals in the exhibit.The total costs in Exhibit 2 are broken down
into labor and operation and maintenance (O&M) costs.  In Section 6(b),
EPA presents a discussion of the capital and O&M costs associated with
new paperwork requirements from the rule.  In the following paragraph,
EPA presents a brief discussion of the O&M costs associated with each of
the existing ICRs that are affected by the rule.  For the Biennial
Report ICR (ICR No. 976), O&M costs are associated with maintaining
copies of Waste Generation and Management (GM) and Waste Received from
Off-Site (WR) forms.  For the Manifest ICR (ICR No. 801), the O&M costs
are associated with postage for sending and returning copies of the
manifest form.6(e)	Bottom Line Burden Hours and CostsRespondent TallyIn
Exhibit 2, EPA presents the total annual respondent burden and cost for
both new and existing paperwork requirements associated with the rule. 
As described specifically in Section 6(d) above, these new and existing
paperwork requirements apply to generators of F019 sludge using the zinc
phosphating process.  As shown in Exhibit 2, the total annual respondent
burden for these new paperwork requirements is approximately 35 hours,
at an annual cost of approximately $2,600.  As also shown in Exhibit 2,
the total annual respondent burden savings under the existing paperwork
requirements, which are associated with two existing EPA ICRs, is
approximately 960 hours, at annual cost savings of approximately
$69,900.  In the same Exhibit 2, EPA then combines the burden and cost
impacts under both new and existing paperwork requirements and estimates
the total annual respondent burden savings for all information
collection activities at approximately 920 hours and an annual cost
savings of approximately $67,300.The bottom line respondent burden hours
saved over the three-year period covered by this ICR is approximately
2,760 hours, at a total cost savings of $201,900.6(f)	Reasons for Change
In Burden In finalizing the conditional exclusion for the F019 listing
at 40 CFR 261.31, EPA will relieve generators of F019 sludge using the
zinc phosphating process from existing RCRA Subtitle C regulations for
that waste.  These generators will only need to comply with the landfill
disposal conditions contained in the F019 listing description in order
to manage these wastes.6(g)	Burden StatementThe annual public reporting
and recordkeeping burden for this collection of information is estimated
to average 0.6 hours per response.  However, in addition to the new
paperwork requirements in the rule, the Agency also estimated the annual
respondent burden savings that  generators could expect as a result of
no longer having to follow information collection requirements under two
existing EPA ICRs (Biennial Report ICR and Manifest ICR).  Taking both
the new proposed and existing RCRA information collection requirements
into account, EPA expects the rule would result in a net reduction in
annual reporting and recordkeeping burden of 68 hours per response. 
Burden means the total time, effort, or financial resources expended by
persons to generate, maintain, retain, or disclose or provide
information to or for a Federal agency.  This includes the time needed
to review instructions; develop, acquire, install, and utilize
technology and systems for the purposes of collecting, validating, and
verifying information, processing and maintaining information, and
disclosing and providing information; adjust existing systems 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 Agencys
need for this information, the accuracy of the provided burden
estimates, and any suggested methods for minimizing respondent burden,
including the use of automated collection techniques, EPA has
established a public docket for this ICR under  Docket ID No.
EPA-HQ-RCRA-2004-0019, which is available for online viewing at
www.regulations.gov, or in person viewing at the OSWER 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 OSWER Docket is (202) 566-0270.  An
electronic version of the 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, DC  20503, Attention: Desk
Officer for EPA.  Please include the EPA Docket ID Number
EPA-HQ-RCRA-2004-0019 and OMB Control Number 2050-0053 in any
correspondence. 	Exhibit 1 - Estimated Annual Respondent (Facility)
Burden and Cost                                                         
 Hours and Costs per Respondent (per Facility)                          
                                                        Total Hours and
CostsINFORMATION
ACTIVITYLeg.$114/HrMgr.$89/HrTech.$59/HrCler.$31/HrRespon. Hours/YrLabor
Cost/YrCapital/Startup CostO & M CostNumber of
Respondents(Facilities)Total Hours/YrTotal Cost/YrUnderstanding the F019
Listing AmendmentRead the
rule0.100.100.300.000.50$38.00$0.00$0.006834$2,584.00Facilities Claiming
Conditional Exclusion from the F019 Listing Keep Records of
Shipments0000.10.1$3.10$0.00$0.00141.4$43.40Total0.100.100.300.10.60$41.
10$0.00$0.00Varies35.4$2,627.40Agency Data Sources:Wage Rate Data:	
Economics Background Document - Estimate of Potential Economic Impacts
for USEPAs Proposed Amendment to the RCRA Hazardous Wastecode F019 to
Exclude Motor Vehicle Manufacturing Industries.Supporting Statement for
Information Collection Request Nr. 801.15: Requirements for Generators,
Transporters, & Waste Management Facilities Under the RCRA Hazardous
Waste Manifest System.Labor Hours:		Supporting Statement for EPA
Information Collection Request 1189.17: Revision of RCRA Wastewater
Treatment Exclusions for Hazardous Waste Mixtures.Supporting Statement
for Information Collection Request Number 1189.11: Zinc Fertilizers Made
from Recycled Hazardous Secondary Materials.	Exhibit 2 - Estimated
Annual Respondent (Facility) Burden for Existing ICRS (Including Net
Impact from F019 Listing Amendment ICR)ICR NameICR
NumberRespondents(Facilities)Total Labor HoursTotal Labor CostTotal O&M
CostTotal Annual CostBiennial Report ICR97614# Facilities x Hours/Yr per
Facility14 x (0.3) = -4.2-$307.00# Facilities x O&M Cost/Yr per
Facility14 x ($0.02) = -$0.28     -$307.28Manifest ICR80114# Facilities
x Hours/Yr per Facility14 x (68) = -952-$69,615.00# Facilities x O&M
Cost/Yr per Facility14 x ($0.06) = -$0.84-$69,615.84	Subtotal Other ICRs
-956.2-$69,922.00-$1.12-$69,923.12F019 Listing Amendment
ICR1189.18Varies 35.4   $2,627.40 $0.00   $2,627.40 	                   
             Net Impact (F019 ICR + Other ICRs) =                       
                 -920.8-$67,294.60-$1.12-$67,295.72 Agency Data Sources:

Labor Hours & Cost:	“Economics Background Document - Estimate of
Potential Economic Impacts for USEPA’s Proposed Amendment to the RCRA
Hazardous Wastecode F019 to Exclude Motor Vehicle Manufacturing
Industries.”

O&M Cost:		“Supporting Statement for EPA Information Collection
Request 1189.17: Revision of RCRA Wastewater Treatment Exclusions for
Hazardous Waste Mixtures.”



 

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