SUPPORTING STATEMENT FOR

EPA INFORMATION COLLECTION REQUEST NUMBER 0976.13

“2007 Hazardous Waste Report” 

	September 18, 2007

	TABLE OF CONTENTS

1.	IDENTIFICATION OF THE INFORMATION COLLECTION	1

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

1(b)	Characterization of the Information Collection	1

2.	NEED FOR AND USE OF THE COLLECTION	2

2(a)	Need and Authority for the Collection	2

2(b)	Use and Users of the Data	4

3.	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA	4

3(a)	Nonduplication	4

3(b)	Public Notice 	4

3(c)	Consultations 	6

3(d)	Effects of Less Frequent Collection	7

3(e)	General Guidelines	7

3(f)	Confidentiality	7

3(g)	Sensitive Questions	7

4.	THE RESPONDENTS AND THE INFORMATION REQUESTED	7

4(a)	Respondents and North American Industry Classification

System (NAICS) Codes  	  7

4(b)	Information Requested	8

5.	THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, COLLECTION
METHODOLOGY, AND INFORMATION MANAGEMENT	9

5(a)	Agency Activities	9

5(b)	Collection Methodology and Management	12

5(c)	Small Entity Flexibility	13

5(d)	Collection Schedule	14

6.	ESTIMATING THE BURDEN AND COST OF THE COLLECTION	14

6(a)	Estimating Respondent Burden	14

6(b)	Estimating Respondent Costs	17

6(c)	Estimating Federal Agency Burden and Cost	18

6(d)	Estimating State Agency Burden and Cost	18

6(e)	Estimating the Respondent Universe and Total Burden and Cost	19

6(f)	Reasons For Change In Burden	21

6(g)	Burden Statement	22

Exhibits 1a and 1b	23

Exhibits 2 and 3	24

1.	IDENTIFICATION OF THE INFORMATION COLLECTION

1(a)	Title and Number of the Information Collection

This Information Collection Request (ICR) is entitled the “2007
Hazardous Waste Report”, also known as the Biennial Report.  EPA ICR
No. 0976.13.

1(b)	Characterization of the Information Collection

This ICR is a renewal of an ongoing information collection request for
reporting by hazardous waste generators and treatment, storage, or
disposal facilities (TSDFs) required by the Resource Conservation and
Recovery Act of 1976 (RCRA).  RCRA Sections 3002 and 3004, as amended by
the Hazardous and Solid Waste Amendments of 1984 (HSWA), require
reporting to the Environmental Protection Agency or to authorized States
at least every two years.  The 2007 Hazardous Waste Report [EPA Form
8700-13 Form A/B], or comparable State report, is used by generators and
TSDFs to satisfy this requirement.

Hazardous waste generators and TSDFs report information on the
quantities, type, and management method of generated hazardous wastes
and hazardous wastes received from off-site.  The data collected are
used by EPA’s Office of Solid Waste (OSW) to prepare a national report
that is made available to Congress and the public, summarizing hazardous
waste generation and management activities.  The data also are used by
EPA and the States for programmatic and regulatory needs. 

Data are collected from respondents on Biennial Report forms, or
comparable State forms, either on paper or in electronic media, and
entered into an electronic database by State and Regional environmental
authorities.  States coordinate with EPA Regions and Headquarters to
supply EPA with the data for inclusion in a national database, RCRAInfo.
 EPA maintains the Biennial Report data in RCRAInfo.

 Once an initial version of the national database is compiled, EPA
coordinates a national data quality review process with States and EPA
Regions to identify cases where the State or EPA Region may wish to
confirm that data were correctly entered; or to contact a regulated
entity to confirm what they reported and to provide them with the
opportunity to submit an updated report if the original contained
errors.   Following submittal of final data from States and EPA Regions,
EPA prepares a National Biennial Hazardous Waste Report based on data
for the specific year.  EPA’s Information Quality Guidelines specify
procedures for correcting data; EPA updates data in RCRAInfo when errors
are found and posts notes in the published information and data files
available through the EPA Internet page.  (See information about the
Hazardous Waste Report at -
http://www.epa.gov/epaoswer/hazwaste/data/biennialreport/index.htm)



For the 2007 cycle, we will use the same booklet as for the 2005
Biennial Report with some minor editorial changes to the instructions,
and one change to the form itself as discussed below.

On August 5, 2005 EPA published a final rule which, among other things,
amended the list of federal Universal Wastes to include all
mercury-containing equipment, and not just thermostats (see 70 FR
45508).  The August 5th rule also amended the notification regulations
found at §273.32 by removing the requirement for large quantity
handlers of Universal Waste to list the types of Universal Waste they
are accumulating.  EPA felt it was unnecessarily burdensome for large
quantity handlers of Universal Waste to list separately the types of
Universal Waste they are generating and the types of Universal Waste
they are accumulating.  Now large quantity handlers of Universal Waste
need only list the types of Universal Waste they are managing,
regardless if it was generated by them or is being sent to and
accumulated by them.

To accommodate these changes to the Universal Wastes rule, EPA has
changed block 10.B. of the Site ID form for the 2007 Hazardous Waste
Report.  The old block 10.B. and the revised block 10.B. are shown in
the table below, with the affected language in italics:

OLD	REVISED (2007)

B. Universal Waste Activities

Y( N(   1.	Large Quantity Handler of Universal Waste (accumulate 5,000
kg or more) [refer to your State regulations to determine what is
regulated]. Indicate types of universal waste generated and/or
accumulated at your site. If “Yes”, mark all boxes that apply:

                                                            Generate    
  Accumulate

       a. Batteries		                (	       (

       b. Pesticides		                (	       (

       c. Thermostats		                (	       (

       d. Lamps		                (	       (

       e. Other (specify) _____________   (	       (

       f. Other (specify) _____________    (	       (

       g. Other (specify) _____________   (	       (

Y( N(   2.	Destination Facility for Universal Waste

Note: A hazardous waste permit may be required for this activity.

	B. Universal Waste Activities

Y( N(   1.	Large Quantity Handler of Universal Waste (accumulate 5,000
kg or more) [refer to your State regulations to determine what is
regulated]. Indicate the types of universal waste managed at your site. 
 Mark all boxes that apply:

                                                           Managed

     a. Batteries			(

     b. Pesticides			(

     c. Mercury-containing equipment	(

     d. Lamps			(

     e. Other (specify) _____________	(

     f. Other (specify) _____________	(

     g. Other (specify) _____________	(

Y( N(   2.	Destination Facility for Universal Waste

Note: A hazardous waste permit may be required for this activity.





2.	NEED FOR AND USE OF THE COLLECTION

2(a)	Need and Authority for the Collection

This subsection establishes the need and legal authority for the
information collection. 

Need for the Information Collection

RCRA requires EPA to establish standards for generators and TSDFs to
protect human health and the environment.  Specifically included are
provisions requiring the submission of data on waste generation and
management. 

There are a number of uses of Biennial Report data.  EPA uses Biennial
Report data 

for planning and developing regulations.  Also, Biennial Report data
allows the Agency to 

determine whether its regulations are having the desired effect on the
generation and management of hazardous waste.   For example, Biennial
Report data provides information 

on whether wastes have shifted from one method of disposal to another. 
Some State uses of 

Report data include support of planning, fee assessment, compliance
monitoring, and enforcement.  See more details in Section 2(b).

Legal Authority for the Information Collection

RCRA Sections 3002 and 3004 authorize the Hazardous Waste Report.  Both
sections require EPA to establish standards for recordkeeping and
reporting of hazardous waste.  Section 3002 applies to hazardous waste
generators and Section 3004 applies to hazardous waste treatment,
storage, and disposal facilities.  The implementing regulations are
found at 40 CFR parts 262.40(b) and (d); 262.41(a)(1)-(5), (a)(8), and
(b); 264.75(a)-(e) and (j); 265.75(a)-(e) and (j); and 270.30(l)(9). 
This is mandatory reporting by the respondents.

Section 3002(a)(6) requires submission of reports to EPA or the States
at least every two years on the:

Quantities and nature of hazardous wastes that have been generated
during the year, and 

Disposition of these hazardous wastes.

Section 3004(a) requires EPA to issue regulations establishing
performance standards applicable to owners and operators of facilities
for the treatment, storage, or disposal of hazardous waste that include:

Reporting and maintaining records of all hazardous wastes treated,
stored, or disposed and the manner in which such wastes were treated,
stored, or disposed.



2(b)	Use and Users of the Data

Implementation of the RCRA program requires the collection of
information on the characteristics of the regulated community generally
(e.g., number of generators and TSDFs), as well as the specific
characteristics of individual sites (e.g., waste handling activities
undertaken).  This information is used for waste activity monitoring,
compliance monitoring, technical assistance, program planning, waste
minimization, and other program activities taken by EPA and the States. 
The information is also used by public interest groups (such as the
Right-to-Know Network) and industry.  

The Biennial Report also provides information to States for tracking
shipments of waste.  Many States do not collect or track manifests,
which provide, information on off-site shipments of hazardous waste;
therefore, the Biennial Report serves as the only source of this
information. 

EPA compiles and publishes the National Biennial RCRA Hazardous Waste
Report 

based on the data for each odd number reporting year.  (The reports for
1989 to 2005 are available on the Internet.)  EPA and states have many
uses for Hazardous Waste Report information, including: 

describing the various source activities that generate hazardous waste
and the generated waste types and quantities;

describing the management methods by which the waste is treated,
disposed, or recycled and the quantities managed by each method;

providing information for analysis of trends in waste generation, waste
treatment and disposal, recycling, and source reduction;

understanding how much waste a state receives from out of state or sends
out of   state; and

estimating available capacity for treating, recycling, and disposing
hazardous wastes.

Additionally, EPA utilizes the Biennial Report information for planning
and developing regulations; regulation development depends on
descriptions and quantities of generated hazardous waste and management
methods used for treatment, recycling, and disposal.  The information
allows the Agency to determine whether regulations are having the
desired effect on the generation and management of hazardous waste; for
example, the report provides information on whether the treatment of
wastes has shifted from one method to another.  EPA also uses the
information for conducting technical assistance, planning facility
inspections, and carrying out regulatory enforcement.  States use the
information for many of the same purposes as EPA; other state uses
include planning, setting waste minimization goals, assessing fees,
monitoring compliance, and carrying out enforcement.

EPA and states receive requests for the information from many public and
private organizations including government agencies, businesses, public
interest groups, and interested citizens.  Many requests come from
businesses that supply chemicals, equipment, and services to hazardous
waste generators and TSDFs.

3.	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a)	Nonduplication

No other federal agency collection satisfies the statutory requirements
of RCRA Sections 3002 and 3004 for reporting of hazardous waste
generation and management.  None of this information duplicates
information collected by other EPA program offices or other federal
agencies.  The RCRA site identification information is collected on one
common form - the RCRA Subtitle C Site Identification Form - for the
Hazardous Waste Report, Notification of Regulated Waste Activity, and
the RCRA Hazardous Waste Part A Permit Application; a respondent may
submit a copy of a previously reported Site Identification Form and note
any changes; this verifies and updates the site identification
information.

The hazardous waste generation information is collected on Form GM; the
hazardous waste management information for on-site is collected on From
GM and for waste from off site is collected on Form WR.  The respondent
submits the information for the specific reporting year.

3(b)      Public Notice

EPA published a notice in the Federal Register for this data collection
on April 17, 2007 (72 FR 19194).  The public comment period extended
through June 18, 2007.  EPA received one comment on this ICR in response
to the Federal Register notice.

The Occidental Chemical Corporation (OCC) submitted comments on June 22,
2007.  The commenter had identified two specific concerns for this ICR. 
The first concern was that the GM form (Form 8700-13A) does not have a
section that requires the name of each transporter used during the
reporting year for shipments, even though the regulations at 40 CFR
262.41(a)(4) say that this information is required.  Initially, Form
8700-13A did have space for the name of each transporter; however, EPA
subsequently determined that the EPA identification number of each
transporter would suffice.  

OCC’s second concern was that Form 8700-13A does not have space for
the DOT hazard class of each waste, even though the regulations at 40
CFR 262.41(a)(5) say that this information is required.  Again, Form
8700-13A used to ask for this information; however, EPA determined that
since the DOT hazard class is required on the Manifest form, it was
unnecessary to ask for it in the Biennial Report.  With this and any
ICR, EPA has to balance the need to collect the information with the
requirements of the Paperwork Reduction Act, which mandates the Federal
Government to reduce burden wherever possible.

3(c)	Consultations

EPA consulted with generators, TSDF, and two States to obtain input on
the assumptions used in this ICR.   We consulted with the same two
states and one respondent that supplied information for 2007 Hazardous
Waste Report ICR; we contacted four additional respondents.   We asked
for information about how much effort it took to complete their 2007
Hazardous Waste Report (Biennial Report).  The contacts and their
responses are listed in Table 1 below.

EPA asked states:

1.  How long did it take for you to complete your state’s 2007
Biennial Report from the 

     respondent reports and send the data files to EPA?

2.  How many respondents submitted reports for your state?

3.  How many GM forms were submitted?  How many were submitted
electronically?

4.  How many WR forms were submitted?  How many were submitted
electronically?

EPA asked respondents:

1.  How long did it take for you to fill out the 2007 Biennial Report?

2   How many GM forms did you fill out?

3.  How many WR forms did you fill out?

4.  Did you file your report electronically or on paper?

Table 1

Consultations with States and Respondents

State and Contact	

Phone Number	

Date of Contact



Florida DEP - Jack Griffith	

850-245-8748	

4/12/07

Ohio EPA - Paula Canter	

614-644-2923	

4/12/07



Respondent and Contact	

Phone Number	

Date of Contact



CRS Corp. (Florida) - Edward Underfinger	

850-302-3599	

4/5/07



Solutia Inc. (Florida) - Amy Dyer	

850-968-8257	

4/5/07



PPG Chemicals  (Ohio) - Maura LaGreca	740-420-6612	

4/5/07



Innovene Corp. (Ohio) - Joe Bianco	

419-226-1351 	

4/5/07



3(d)	Effects of Less Frequent Collection

The two-year cycle is statutorily required.  Though some States collect
information on an annual or quarterly basis, EPA does not require more
frequent data collection.

3(e)	General Guidelines

This ICR adheres to the guidelines stated in the Paperwork Reduction Act
of 1995, OMB’s implementing regulations, and OMB’s Information
Collection Review Handbook.  This information collection complies with
EPA’s Data Standards and Information Quality Guidelines.

3(f)	Confidentiality

The 2007 Biennial Report requires businesses to provide information on
various aspects of hazardous waste generation and management.  Some
businesses consider some of their hazardous waste information to be
Confidential Business Information (CBI).  A business may, if it desires,
protect its Biennial Report information from public disclosure by
asserting a claim of confidentiality covering all or part of its
information.  When a claim is made EPA will treat the information in
accordance with the confidentiality regulations in 40 CFR part 2,
subpart B.  EPA also ensures that the information collection procedures
comply with the Privacy Act of 1974 and the OMB Circular 108.

3(g)	Sensitive Questions

There are no sensitive questions asked in the 2007 Hazardous Waste
Report.

4.	THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a)	Respondents and NAICS Codes 

Beginning with the 2001 Hazardous Waste Report, respondents are required
to report their business activities using the North American Industry
Classification System (NAICS) codes.  Based on prior reported data, the
respondents are represented by the NAICS codes listed below.    



NAICS Code Description	

NAICS Code



Agriculture, Forestry, Fishing and Hunting	

11



Mining	

21



Utilities	

22



Construction 	

23



Manufacturing	

31-33



Wholesale Trade	

42



Retail Trade	

44-45



Transportation and Warehousing	

48-49



Information	

51



Waste Mgt and Remediation Services	

562



Public Administration	

92



4(b)	Information Requested

The Hazardous Waste Report consists of four forms: RCRA Subtitle Site
Identification Form, Waste Generation and Management (Form GM), Waste
Received from Off-Site (Form WR), and Off-Site Identification (Form OI;
used only by states).  Only Large Quantity Generators and Treatment,
Storage, and Disposal Facilities are required to complete the Hazardous
Waste Report.

(i)	Data Items:

RCRA Subtitle C Site Identification Form.  The Site Identification Form
must be submitted by all sites required to file the 2007 Hazardous Waste
Report.  This form collects information such as site name, EPA
Identification Number, address, contact, and type of hazardous waste
generation and management activities taking place at the site; it
verifies their information, especially the site’s generator status as
the date of submission of the report in 2008.  It requires a
certification signature for the submission of the report.

Form GM - Waste Generation and Management.  Form GM must be submitted by
all respondents that generated or shipped large quantity generator
amounts of RCRA hazardous waste during 2007.  This form collects
information on each generated waste, including a narrative waste
description, a waste characterization

(waste codes, source, and form), quantity generated, and the method of

waste management (whether managed on site or shipped off site).

Form WR - Waste Received From Off-Site.  Form WR must be submitted by
all sites that received RCRA hazardous waste from off-site during 2007. 
This form collects information on each waste received from off-site,
including a narrative description of the waste, a brief waste
characterization (e.g., waste codes), the EPA Identification Number of
the off-site generator, the quantity of waste received, and the method
of waste management.

Form OI - Off-Site Identification.  Form OI is not required by EPA;
rather, it is provided as an option for States to collect the names and
addresses of transporters, generators that ship waste, and receivers of
waste reported on Forms GM and WR where only the EPA Identification
Number is listed.

 

(ii)	Respondent Activities:

Respondents must perform the following activities:

Read the 2007 Biennial Report instructions;

Gather information and complete Site Identification Form;

Gather information and complete Form GM;

Gather information and complete Form WR;

Gather information and complete Form OI if required by the State
(State-optional form, not a Federal form);

Submit the report to the State (or EPA Regional Office for some states
and territories); and

Maintain a copy of each form for three years.

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

5(a)	Agency Activities

As with most of the RCRA program, the Biennial Report data collection
process is delegated to the States.  Briefly, the process is as follows.

States (or EPA Regions where the Region implements the RCRA hazardous
waste program for a State) provide respondents with either the Federal
form or a State equivalent, collect the responses, contact
non-respondents, enter the data (or load files if the State employs
electronic methods for preparation and submittal of reports by regulated
entities) into a database using off-the-shelf software packages which
have been developed to support the collection of Biennial Report data,
assure data quality, and forward the data to EPA.

	States have discretion on the methods used to identify entities to whom
they distribute forms and the subsequent tracking of reports received. 
Most States generate mailing lists based on previous report submittals,
augmented by recent notifications of regulated activity.  Many States
levy fees based on the nature and extent of regulated activity
identified in the report.  EPA makes all reported data (except any that
may be claimed as CBI) available to the public on the Internet.  This
provides further incentive for sites (and also for States and EPA) to
ensure the information is complete and accurate because the public
regularly accesses this information.

The Regions support States in data gathering and data quality
assessment.  Regions may also provide technical support to States for
the transfer of their files to EPA for incorporation into the national
database.  All files are submitted to the Agency through EPA’s Central
Data Exchange.

EPA Headquarters produces and distributes the Federal forms and related
guidance, defines the data and file format for data, establishes the
schedule for submitting data, manages the incorporation of State data
into the national database, coordinates national data quality review,
maintains the national database, and prepares a national report listing
major facts about the national picture of hazardous waste generation and
management for the reporting year.

In practice, this distribution of activities does not always follow this
path.  In some cases, the Region performs all of the State roles.  In
others,
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	Develop 2007 Biennial Report forms and instructions.  Print paper
and CD copies.

	Distribute Biennial Report forms and instructions.  EPA Headquarters
distributes the form and instruction booklets to the States and Regions.
 States (or Regions) prepare mailing lists, mail forms and instructions,
record receipt of completed forms, and contact sites that fail to
respond within the specified time period.  Some States may pre-populate
Site Identification Forms prior to distribution to reduce the effort
needed by respondents as well as to ensure accuracy.

	Develop computer capabilities required to compile national data. 
EPA Headquarters develops the computer capabilities required to load
data into the national database, the reports which support data quality
assessment and other programmatic use of the data, and preparation of
the national report.

	Assist respondents.  States, Regions, and Headquarters provide
assistance to respondents.  States are, however, the first point of
contact for answering respondent questions and assistance.

	Enter report submissions.  States or EPA Regions, and the regulated
entities, key enter or electronically load the data into a database they
select and maintain.  The

data entry function was privatized for the 1999 Hazardous Waste Report
process.  Many States, Regions, and the regulated community use one of
the private vendor’s software packages for data entry and
recordkeeping.  Some reports are entered directly on state or vendor
hosted Internet sites and some are submitted on diskettes.

	Perform quality assurance.  States, Regions, and Headquarters all
perform data quality assurance.  This includes: follow-up to
non-respondents, detection and correction of unacceptable responses
(e.g., in cases where the respondent misunderstood the instructions);
verification of exceptional responses (e.g., data reported by a
respondent that differ significantly from data reported by the rest of
the respondent universe) and identification of significant response
changes between reporting years.  The national software supports these
activities with a variety of data editing functions.

Once reports are received, the QA/QC procedures include a hierarchy of
assessments.  First, system procedures ensure the data has fundamental
internal consistency (e.g., required data fields are populated and the
values are of the correct data type and within allowed ranges).

Second, the information content of the data for individual sites is
evaluated to identify any potential over or under reporting (exception
reports support identification of extremes and significant variance from
one cycle to another).

Third, assessment reports support evaluation of intra-State and
inter-State shipments of wastes to identify potential discrepancies
between reports submitted by generators and the TSDF’s who were
identified by the generator as receivers of the waste.

Based on the assessments, States identify cases where accuracy may be
questionable.  For those cases, they generally contact the site to
review the information received; and
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	Prepare the national report.  EPA will prepare The National Biennial
RCRA Hazardous Waste Report (Based on 2007 Data) that will be made
available to the Congress and the public.

	Store the data.  The 2007 Biennial Reports will be stored by the
States or Regions for three years and an electronic database may be
maintained by each State or Region.  The national database is maintained
by EPA Headquarters in RCRAInfo.

5(b)	Collection Methodology and Management

To ensure that the Biennial Report data collected are accurate,
complete, and retrievable, EPA has employed a variety of user support,
automatic data processing, and process management techniques.

User Support.  EPA publishes the list of State and EPA Regional contacts
on the Agency’s publicly available Internet.  This list refers
respondents to a State or EPA Regional contact for assistance with their
report.

Automatic Data Processing.  The Biennial Report data collection effort
is delegated to the States and is therefore decentralized. EPA has
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	acceptance of the data in a standard electronic format;

	quality assurance of the data;

	storage of national data; and

	use of the data.

EPA developed documentation necessary to produce submissions according
to EPA’s electronic reporting standards for the Central Data Exchange.
 The standards used for respondents to submit electronically will depend
on which software package the State or Region uses.

EPA provides reports to support the national data quality assessment
process.  The reports highlight outlying data values (e.g., data
reported by one or more respondents that differ significantly from data
reported by the rest of the respondent universe), significant changes
from one report cycle to another for a facility, and significant
differences between waste reported as shipped by one facility and the
corresponding waste reported as received by the receiving facility.  EPA
also provides reports to support the loading of files into RCRAInfo. 
These reports facilitate the identification and resolution of incorrect
or incomplete data or file formats.

To protect the data from unauthorized alteration, EPA implements
security controls on the national database which limit file loading and
update privileges to authorized database administrators, and prevents
anything other than read access on the part of State and EPA users. 
Because of information security procedures, EPA does not allow direct
public access to the RCRAInfo.  On-line public access is supported by an
extract of the data which is then made available through EPA's
Internet-accessible Envirofacts database.  

          

	Any information claimed as CBI is submitted on diskettes by the State
and kept separate from other data.  For compilation of the national
report, data is submitted to the OSW CBI office where it is logged by
the same process used for other CBI documents.  The information on
quantities of waste claimed as CBI are tabulated to include in the
quantity data for the national report without references that would
allow derivation of the specific components of the original report or
who sent it.

Process Management.  To implement Biennial Report, EPA has established a
data collection process, assigned responsibilities in the process, and
established a schedule for the implementation of the process.    

States (and EPA as the implementer of the program for the states of
Alaska and Iowa) track and monitor initial responses from the regulated
community.  As implementation proceeds, headquarters staff communicate
with Regions and their States to confirm progress and identify emerging
problems (e.g. significant delays on the part of a given State). 
Periodic status reports are sent by EPA Headquarters staff to EPA
Regional and State management and staff outlining progress towards
meeting milestones.   

In addition to routine status updates for management, Headquarters staff
use the information obtained from their regular discussions with States
and Regions to identify cases which may require senior management
action.  Where necessary, senior Headquarters managers consult with
their counterparts in the Regions to review problem areas and determine
approaches to overcoming them.  

(5c)	Small Entity Flexibility

EPA uses the quantity of waste generated per month to determine the
extent to which a firm should be regulated.  EPA categorizes generators
of less than 1,000 kilograms of non-acute hazardous waste per month as
small quantity generators (SQGs) and relieves them of specific
requirements.

SQGs are not required to file the 2007 Biennial Report.  A SQG who is
sent the 2007 Biennial Report due to a change in generator status or
error need not respond.  They must return a completed RCRA Subtitle C
Site Identification Form to update their generator status to ensure they
are not subject to follow-up contact for biennial reporting.

5(d)	Collection Schedule

EPA's 2007 Biennial Report implementation schedule is outlined Table 2
below.

Table 2

Reporting and Implementation Schedule

Activity	

Lead 	

Start Date	

End Date



Print 2007 Booklets	

EPA HQ	

	

October 2007



Distribute 2007 Booklets to States	

EPA HQ	

November 2007	

December 2007



Distribute 2007 Booklets

to Respondents	

States	

December 2007	

January 2008



Provide Biennial Report Help Line	

States	

January 2008	

April 2008



Receive 2007 Reports from Respondents	

States	

January 1, 2008	

March 1, 2008



Submit Final State/Regional Data to EPA HQ 	

States and 

EPA Regions	

January 2008	

February 2008



Develop 2007 National Biennial RCRA Hazardous Waste Report 	

EPA HQ	

March 2008	

July 2008



Publish 2007 National Biennial RCRA Hazardous Waste Report and Data
Files on Internet	

EPA HQ	

	

September 2008



6.	ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a)	Estimating Respondent Burden

EPA presents estimates for the respondent burden hours associated with
the information collection requirements covered in this ICR in Exhibits
1a and 1b.  These exhibits list all of the respondent activities
associated with the 2007 Hazardous Waste Report and present burden and
cost estimates for each.  The burden estimates are broken down by labor
category (legal, managerial, technical, and clerical) and totaled on a
per activity basis.  These burden estimates are then multiplied by the
estimated number of respondents and the estimated number of activities
per respondent to obtain an estimate of the overall burden to the
regulated universe for each activity.

Source of Burden Estimates

The burden estimates for each activity are based on the estimates
contained in the previous version of this ICR and have been validated
through consultation with States and members of the regulated community
(see Section 3(c)).

Methodology for Accounting for Site Identification Forms Pre-Populated
by States 

In estimating the hourly burden for preparing the Site Identification
Form, EPA assumed that 65 percent of all the Site Identification Forms
would be pre-populated by States prior to distribution to respondents or
by vendor software used by the respondents.  EPA estimates the average
hourly burden for updating the pre-populated Site Identification Form to
be 0.4 hours per respondent, and for completing the Site Identification
Form in its entirety, 0.7 hours per respondent. 

To estimate the average burden per respondent in preparing a Site
Identification Form, EPA used the weighted-average calculation shown in
Table 3 below.  EPA multiplied the percentage of pre-populated Site
Identification Forms by the average burden for updating the information
contained in the form and blank forms by the average burden for
completing the blank form.  Then, EPA added up these two products to
derive an overall weighted-average burden.

Table 3

Assumptions and Weighted-Average Equation 

Used in Estimating Burden to Complete the Site Identification Form

Assumptions	

Weighted-Average Equation



0.4 hours to complete pre-populated form; 65 percent of the forms are
pre-populated	

(0.4 hrs x 0.65) + (0.7 hrs x 0.35) 

= 0.5 hours



0.7 hours to complete blank form;

35 percent of the forms are blank

	

Methodology for Accounting for Electronic Reporting

For the 2007 Biennial Report, EPA held consultations with a few State
and facility representatives to get feedback on the ICR's data and
assumptions.  In these conversations, the representatives indicated that
GM and WR Forms often can be completed from databases that track
manifests or other information for billing purposes.  Based on these and
previous years' consultations, EPA estimated the hourly burden for the
GM and WR Forms submitted electronically to be significantly less than
for forms submitted on paper.			

To estimate the percentage of facilities that submit GM and WR Forms
electronically, EPA used information gained from the consultations and
2005 Biennial Report (BR) data.  For GM submissions, EPA estimated that,
based on consultations and best professional judgment, facilities
submitting five (5) or more GM Forms for the Biennial Report are likely
to do so electronically.  Using 2005 BR data, EPA identified sites
submitting GM Forms, counted their GM Forms submitted, and calculated
the percentage that their GM Forms represented of the total number of GM
Forms.  Based on this methodology, EPA estimates that 85 percent of GM
Forms are submitted electronically, while the remaining 15 percent are
sent manually.  EPA found that over 75 percent of respondents submit 10
or fewer GM Forms.

For WR Forms, EPA believes that TSDFs receiving large numbers of
off-site shipments are more likely to have systems in place to track
waste stream data, and as a consequence, to report Biennial Report data
electronically.  Using the 2005 BR data, EPA reviewed the list of WR
Forms reported to the Biennial Report by facility and, based on its own
professional judgment and consultations, estimates that 100 percent of
WR Forms are submitted electronically.  EPA found that over 45 percent
of respondents submit 100 or fewer WR Forms.

To estimate the average burden per respondent in preparing a Form GM or
WR, EPA used the weighted-average calculations shown in Table 4.  EPA
multiplied the percentage of both forms submitted electronically by
their respective burden for electronic reporting and the percentage of
both forms submitted manually by their respective burden for manual
reporting.  Then, EPA added the two products for each form respectively
to calculate an overall weighted-average burden for both forms.

Table 4

Assumptions and Weighted-Average Equations

Used in Estimating Burden to Complete the GM and WR Forms

Activity	

Assumptions	

Weighted-Average Equation



Complete GM Form	

1.26 hours to complete manually; 

15% of the forms are completed manually

0.08 hours to complete electronically; 

85% of the forms are completed electronically	

(1.26 hrs x 0.15) + (0.08 hrs x 0.85)

= 0.28 hours



Complete WR Form	

0.13 hours to complete electronically; 

100% of the forms are completed electronically	

0.13 hrs x 1= 0.13 hours



6(b)	Estimating Respondent Costs

Estimating Labor Costs

EPA estimates respondent costs for all activities covered in this ICR in
Exhibits 1a and 1b.  Exhibit 1a represents the privately-owned
facilities, Exhibit 1b represents State-owned facilities.

For purposes of this analysis, EPA estimates an average hourly
respondent labor cost (including fringe and overhead) of $81.13 for
legal staff, $65.61 for managerial staff, $36.34 for technical staff,
and $17.99 for clerical staff.  These respondent labor costs were
generated from data obtained from the US Bureau of Labor Statistics
(BLS) Occupational Employment Statistics (OES) for May 2006 National
Occupational Employment and Wage Estimates (averages across all NAICS
codes):   HYPERLINK "http://www.bls.gov/oes/current/oes_nat.htm" 
http://www.bls.gov/oes/current/oes_nat.htm .

  Loaded wage rates estimated by multiplying the BLS unloaded wage rates
by 1.4845, which represents addition of two cost factors (i.e., Federal
government civilian wage full fringe benefit cost factor of 36.45%, plus
12% overhead cost factors) from Figure C1 of the 29 May 2003 OMB
Circular A-76:  Performance of Commercial Activities:   HYPERLINK
"http://www.whitehouse.gov/omb/circulars/a076/a76_incl_tech_correction.h
tml" 
http://www.whitehouse.gov/omb/circulars/a076/a76_incl_tech_correction.ht
ml .

For the State respondent labor rates, EPA estimates an average hourly
labor cost (including fringe and overhead) of $55.65 for legal staff,
$52.24 for managerial staff, $31.26 for technical staff, and $19.94 for
clerical staff.  These State respondent labor costs were generated from
data obtained from the US Bureau of Labor Statistics (BLS) Occupational
Employment Statistics (OES) for May 2006 at:    HYPERLINK
"http://www.bls.gov/oes/current/naics4_999200.htm" 
http://www.bls.gov/oes/current/naics4_999200.htm    OMB does not publish
a state government   wage rate loading cost factor; thus the same OMB
cost factor for Federal government labor is applied in this table above.
The loaded wage rates above were calculated by multiplying the BLS
unloaded wage rates by 1.4845, which represents addition of two cost
factors (i.e., civilian position full fringe benefit cost factor of
36.45%, plus 12% overhead cost factor) from Figure C1 of OMB Circular
A-76 to be used to reflect the full cost of government employees:   
HYPERLINK
"http://www.whitehouse.gov/omb/circulars/a076/a76_incl_tech_correction.h
tml" 
http://www.whitehouse.gov/omb/circulars/a076/a76_incl_tech_correction.ht
ml .

	Estimating Capital and O&M Costs 

To submit the Biennial Report, EPA estimates that facilities will incur
a one-time postage cost of $2.00 each year for the two-year period of
the ICR.  This estimate is based on the mailing cost of $4.00 for a
certified mail package.

EPA estimates that facilities will incur annual operation and
maintenance (O&M) costs associated with maintaining a copy of each form
for three years.  For respondents that submit paper versions of the
forms, EPA estimates that to maintain files, facilities will purchase
file cabinets and make photocopies.  For respondents that submit the
information electronically, EPA estimates that to maintain files,
facilities will purchase disk storage space (e.g., floppy disks).  EPA
estimates that file storage, whether paper or electronic, will cost
$0.01 per form and that photocopying charges will cost $0.11 per form
submitted for the two-year period of the ICR.  As with burden hours, the
costs for electronic reporting are incorporated into the cost estimates
for the GM and WR Forms by multiplying the proportion electronically
reporting by the O&M cost for electronic reporting ($0.01) plus the
proportion using manual reporting multiplied by the O&M costs for
respondents that submit the paper forms ($0.01+$0.11).

6(c)	Estimating Federal Agency Burden and Cost

EPA estimates the Federal Agency hour and cost burden associated with
all information collection requirements covered in this ICR in Exhibit
2.  EPA is responsible for developing the forms, developing computer
capabilities required to compile national data, storing the data, and
preparing the National Report and other analyses.  EPA is also
responsible for distributing the forms to the States, as will as
collecting and entering the data in Alaska, Iowa, and the Virgin
Islands.

As shown in the exhibit, EPA estimates an average hourly labor cost of
$83.28 for legal staff, $70.01 for managerial staff, $29.42 for
technical staff, and $23.50 for clerical staff.  

To derive these hourly estimates, EPA referred to the US Bureau of Labor
Statistics (BLS) Occupational Employment Statistics (OES) for May 2006
at:    HYPERLINK "http://www.bls.gov/oes/current/naics4_999100.htm" 
http://www.bls.gov/oes/current/naics4_999100.htm  

The loaded wage rates above were calculated by multiplying the BLS
unloaded wage rates by 1.4845, which represents addition of two cost
factors (i.e., civilian position full fringe benefit cost factor of
36.45%, plus 12% overhead cost factor) from Figure C1 of OMB Circular
A-76 to be used to reflect the full cost of government employees:   
HYPERLINK
"http://www.whitehouse.gov/omb/circulars/a076/a76_incl_tech_correction.h
tml" 
http://www.whitehouse.gov/omb/circulars/a076/a76_incl_tech_correction.ht
ml .

As shown in Exhibit 2, depending on the type of Agency activity, some of
the total burden per Agency activity is based on the number of
respondents or the number of forms.  Burden hours for entering report
submissions for each labor category account for electronic reporting;
burden for key entry is multiplied by the proportion of total forms
submitted on paper and added to the burden for electronically loading
the data (estimated to be one-tenth the burden for key entry) multiplied
by the proportion of forms expected to be submitted electronically (see
Section 6(a)).  

6(d)	Estimating State Agency Burden and Cost

EPA estimates the State Agency hour and cost burden associated with all
information collection requirements covered in this ICR in Exhibit 3. 
All U.S. States and Territories, with the exception of Alaska, Iowa, and
the Virgin Islands, are responsible for distributing the forms to
respondents, assisting respondents with any questions, collecting
completed forms and entering the data, as well as quality assurance of
the data.

As shown in the exhibit, EPA estimates an average hourly labor cost of
$55.65 for legal staff, $52.24 for managerial staff, $31.26 for
technical staff, and $19.94 for clerical staff.  

	These State government employee unloaded average (mean) wage rates were
generated from the US Bureau of Labor Statistics (BLS) Occupational
Employment Statistics (OES) for May 2006 at:   HYPERLINK
"http://www.bls.gov/oes/current/naics4_999200.htm" 
http://www.bls.gov/oes/current/naics4_999200.htm . 

	OMB does not publish a state government wage rate loading cost factor;
thus the same OMB cost factor for Federal government labor is applied in
this table above.  The loaded wage rates above were calculated by
multiplying the BLS unloaded wage rates by 1.4845, which represents
addition of two cost factors (i.e., civilian position full fringe
benefit cost factor of 36.45%, plus 12% overhead cost factor) from
Figure C1 of OMB Circular A-76 to be used to reflect the full cost of
government employees:
http://www.whitehouse.gov/omb/circulars/a076/a76_incl_tech_correction.ht
ml.

	6(e)	Estimating the Respondent Universe and Total Burden and Cost

EPA estimates that the total number of respondents to the 2007 Biennial
Report will be approximately 25,238, which annualized over the two-year
report cycle equals 12,619 per year (25,238/2).  See Table 5 for the
Respondent Universe breakdown.

Table 5

Respondent Universe

Respondent Type	Number of Respondents	Number of Site ID Forms	Number of
GM Forms	Number of WR Forms

Privately-owned facilities	

23,686	

23,686	

250,560	

851,380

State-owned facilities	

1,370	

1,370	

4,100	

160



Total	

25,238	

25,238	

254,660	

851,540



The number of respondents and forms for each respondent activity is
presented below.  These estimates assume that all questions and forms
are submitted in accordance with the Biennial Report instructions. 
Exhibits 1a and 1b calculate the annual respondent burden and cost for
the activities examined.

Read the Instructions

EPA estimates that all 25,238 respondents will read the instructions to
the 2007 Biennial Report.  Annualized over the two-year report cycle,
this results in 12,619 facilities reading the instructions each year.

Gather Information and Complete Site Identification Form

EPA estimates that all 25,238 respondents will complete and submit a
Site Identification Form with the 2007 Biennial Report.  Annualized over
the two-year report cycle, this results in 12,619 respondents preparing
and submitting a Site Identification Form each year.  EPA further
assumes that 65 percent of forms will be pre-populated by States, in
which case respondents need only review and update the data. 
Respondents receiving blank forms will need to complete the form.  EPA
estimates that, on average, a pre-populated Site Identification Form
will take about 0.4 hours to update and a blank Site Identification Form
will take about 0.7 hours to complete.  Thus, on average, EPA assumes
each respondent will take about 0.5 hours (weighted-average) to
update/complete a Site Identification Form.  See Table 3 above.

Gather Information and Complete Form GM

EPA anticipates that each year 12,619 respondents will submit 127,330 GM
Forms to EPA (254,660/2).  EPA estimates that, on average, a Form GM
will take about 1.26 hours to complete manually and 0.08 hours to
complete electronically.  EPA further assumes that 15 percent of forms
will be completed manually and 85 percent will be completed
electronically.  Thus, on average, EPA assumes each respondent will take
about 0.28 hours (weighted-average) to complete each Form GM.  See Table
4 above.

Gather Information and Complete Form WR

EPA expects that each year 12,619 respondents will each submit a total
of 425,770 WR Forms to EPA (851,540/2).  Note that the number of WR
Forms represents the number of blocks on Form WR that have been
completed; the paper form actually contains three blocks of the same WR
information (i.e., the same questions, repeated three times on the same
page).  EPA estimates that a Form WR will take, on average, about 0.13
hours to complete electronically.  EPA further assumes that 100 percent
of forms will be completed electronically.  Thus, on average, EPA
assumes each respondent will take about 0.13 hours (weighted-average) to
complete each Form WR.  See Table 4 above.

Gather Information and Complete Form OI

Because this form is a State-optional form, EPA does not expect any
facilities to submit Form OI and therefore does not calculate the burden
for this form.

Submit the Biennial Report to State/Region

EPA expects each respondent, 12,619 facilities per year, to submit the
report to the appropriate State or Region.

Maintain a Copy of Each Form 

EPA expects facilities to retain an estimated 565,719 (12,619 + 127,330
+ 425,770) forms each year.

Bottom Line Burden and Cost for Respondents

Table 6 presents the bottom line respondent burden and costs associated
with the 2007 Hazardous Waste Report.  EPA estimates that respondents
will incur an annual burden of 267,974 hours and a cost of $9,113,628. 
These tallies come from Exhibits 1a and 1b.

Table 6

Total Respondent Hour and Cost Burden

	Annual Hour Burden	Annual Labor Cost	Annual Capital/Start-up Cost
Annual O&M Cost	Total Annual Cost

Privately-Owned	265,032	$8,960,807	$0	$46,145	$9,006,952

State-Owned	2,942	$105,108	$0	$1,568	$106,676

Total	267,974	$9,065,915	$0	$47,713	$9,113,628



Bottom Line Burden and Cost for Federal and State Agencies

EPA estimates the annual Federal Agency burden for the 2007 Hazardous
Waste Report will be 823 hours and a total cost of $379,277 ($24,127 for
labor + $355,150 for capital/start-up and O&M costs).  These totals come
from Exhibit 2.  

	

EPA estimates the annual State Agency burden for the 2007 Hazardous
Waste Report will be 417,222 hours and a total cost of $11,023,863
($11,004,934 for labor + $18,929 for capital/start-up and O&M costs). 
These totals come from Exhibit 3.

	6(f)	Reasons For Change In Burden

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8l/start-up and O&M.  This represents an increase of 519,944 hours and
$37,045 total cost for capital/start-up and O&M.  

	This increase in burden has occurred for two reasons.  First, there is
an increase in the number of respondents, from 9,106 in 2005 to 12,619
projected for 2007.  Second, and most importantly, EPA is counting the
State Agency burden in the overall burden for this ICR for the first
time with this renewal.  Historically, EPA calculated State Agency
burden with the Federal Agency burden, so the State Agency burden was
not reflected in the bottom line burden for the ICR.

	6(g)	Burden Statement

	The reporting burden is estimated to average 16.4 hours per respondent,
and includes time for reviewing instructions, gathering data, completing
and reviewing the forms, and submitting the report.  The record keeping
requirement is estimated to average 2.3 hours per response and includes
the time for filing and storing the Biennial Report submission for three
years.

Burden means the total time, effort, and financial resources expended by
persons to generate, maintain, retain, 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. 

 



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