                                       

                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                           SUPPORTING STATEMENT FOR 
                 INFORMATION COLLECTION REQUEST NUMBER 1688.08
                                       
                   "RCRA EXPANDED PUBLIC PARTICIPATION" 
                                       
                                   May 2015

                               TABLE OF CONTENTS

1.	IDENTIFICATION OF THE INFORMATION COLLECTION	4
1(a)	Title of the Information Collection	4
1(b)	Short Characterization	4
2.	NEED FOR AND USE OF THE COLLECTION	5
2(a)	Need/Authority for the Collection	5
2(b)	Practical Utility/Users of the Data	5
3.	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA	5
3(a)	Nonduplication	5
3(b)  	Public Notice	6
3(c)	Consultations	6
3(d)	Effects of Less Frequent Collection	6
3(e)	General Guidelines	6
3(f)	Confidentiality	6
3(g)	Sensitive Questions	6
4.	THE RESPONDENTS AND THE INFORMATION REQUESTED	7
4(a)	Respondents/NAICS Codes	7
4(b)	Information Requested	8
5.	THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT	10
5(a)	Agency Activities	11
5(b)	Collection Methodology and Management	11
5(c)	Small Entity Flexibility	11
5(d)	Collection Schedule	12
6.	ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION	12
6(a)	Estimating Respondent Hours	12
6(b)	Estimating Respondent Costs	12
Labor Costs	12
Capital/Start-Up Costs	13
6(c)	Estimating Agency Hour and Cost Burden	14
6(d)	Estimating the Respondent Universe and Total Hour and Cost Burden	16
6(e)	Bottom Line Hour and Cost Burden	17
6(f)	Reasons for Change in Burden	21
6(g)	Burden Statement	17

                                       
                                  SUPPORTING STATEMENT
                            ENVIRONMENTAL PROTECTION AGENCY
         
IDENTIFICATION OF THE INFORMATION COLLECTION

1(a)	Title of the Information Collection

RCRA Expanded Public Participation (Renewal), EPA ICR number 1688.08, OMB control number 2050-0149.

1(b)	Short Characterization

      The Resource Conservation and Recovery Act (RCRA) of 1976, as amended by the Hazardous and Solid Waste Amendments (HSWA) of 1984, requires EPA to establish a national regulatory program to ensure that hazardous wastes are managed in a manner protective of human health and the environment. EPA has a statutory obligation, under Section 7004(b) of RCRA, to provide for, encourage, and assist public participation in the development, revision, implementation, and enforcement of any regulation, guideline, information, or program under the Act. The regulations implementing these requirements are codified at 40 CFR 124 and 40 CFR 270.
	EPA promulgated requirements for providing additional opportunities for the public to be involved in the RCRA permitting process at 40 CFR 124.31 through 124.33 and at 40 CFR 270.62 and 270.66. The 40 CFR 124 requirements apply to all types of hazardous waste treatment, storage, and disposal facilities, unless exempted under a specific section; the 40 CFR270 requirements apply only to hazardous waste combustors planning trial burns. 

	Under 40 CFR 124.31(a) and (b), facilities applying for an initial Part B permit or a Part B permit renewal, where the renewal application is proposing a change that would qualify as a Class 3 permit modification under 40 CFR 270.42, are required to hold at least one meeting with the public prior to submitting the Part B permit application to the permitting agency. The applicant must submit a summary of the meeting, along with the list of attendees and their addresses, and copies of any written comments or materials submitted at the meeting, to the permitting agency as part of the Part B application (§124.31(c)). 

	Under 40 CFR 124.31(d), applicants must provide public notice (i.e., newspaper advertisement, visible and accessible sign, and broadcast media announcement) of the pre-application meeting at least 30 days prior to the meeting. The applicant also must provide a copy of the notice to the permitting agency and to the appropriate units of State and local government.
	The required activities and information are needed to help assure timely and effective public participation in the permitting process. The requirements are intended to provide equal access to information to all stakeholders in the permitting process: the permitting agency, the permit applicant, and the community where a facility is located. EPA believes that these regulations encourage people to become involved in the permitting process and increase understanding of hazardous waste facilities.

NEED FOR AND USE OF THE COLLECTION

2(a)	Need/Authority for the Collection
      
      Section 7004(b) of RCRA gives EPA broad authority to provide for, encourage, and assist public participation in the development, revision, implementation, and enforcement of any regulation, guideline, information, or program under RCRA. In addition, the statute specifies certain public notices (i.e., radio, newspaper, and a letter to relevant agencies) that EPA must provide before issuing any RCRA permit. The statute also establishes a process by which the public can dispute a permit and request a public hearing to discuss it. EPA carries out much of its RCRA public involvement at 40 CFR Parts 124 and 270.

      In 1995, EPA expanded the public participation requirements under the RCRA program by promulgating the RCRA Expanded Public Participation Rule (60 FR 63417; December 11, 1995).  The rule responded to calls by the Administration and stakeholders (e.g., States and private citizens) to provide earlier and better public participation in EPA's permitting programs, including procedures for more timely information sharing.  In particular, the rule required earlier public involvement in the permitting process (e.g., pre-application meetings), expanded public notice for significant events (e.g., notices of upcoming trial burns), and more opportunities for the exchange of permitting information (e.g., information repository).

      In May of 2003, EPA finalized the Public Involvement Policy. The policy updates an earlier policy issued in 1981. Among other things, the policy calls for a strengthened commitment to meaningful public involvement, greater attention to the specific concerns and interests of affected people and entities, and use of a wider variety of public involvement techniques. In this regard, the RCRA Expanded Public Participation Rule can serve as an example to the EPA programs of how to achieve many of the goals of the policy.

2(b)	Practical Utility/Users of the Data

      The required activities and information are needed to help assure timely and effective public participation in the permitting process. The requirements are intended to provide equal access to information to all stakeholders in the permitting process: the permitting agency, the permit applicant, and the community where a facility is located. Some facilities may be required to develop information repositories to allow for expanded public participation and access to detailed facility information as part of the permitting process.







NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a)	Nonduplication

      The information collections covered in this ICR are not available from sources other than the respondents. EPA's Office of Solid Waste is the only office within the Agency collecting this information, and no other Federal agency or department collects this information. 

3(b)  	Public Notice

      In compliance with the Paperwork Reduction Act of 1995, EPA issued a public notice in the Federal Register on March 13, 2015. EPA announced in the Federal Register (80 FR 13375) that it intended to this ICR. The comment period ended on May 12, 2015. No comments were received. 

3(c)	Consultations

      EPA consulted with two facilities that have recently submitted Part B permit applications and thus were subject to these information submission requirements. EPA specifically inquired about the requirements regarding the pre-application public meeting. Ed Krise of Safety-Kleen Systems, Inc., in Nashville Tennessee (615-230-6882) said the estimate of 89.1 hours was a little high. Richie Haddock of Precious Metals Recovery LLC, Crescent Valley, Nevada (801-990-3373), however, felt the estimate was too low, and suggested 150 hours. Based on these consultations, plus the consultations conducted for the previous ICR, which indicated the 89.1 hour estimate was accurate, the Agency has raised the estimate from 89.1 hours to 90 hours.

3(d)	Effects of Less Frequent Collection

      EPA sought to reduce the reporting frequency to the minimum that is necessary to ensure compliance with the rule. It would not be possible to collect this information less frequently and still assure that the requirements of permit and public involvement regulations are met by owners or operators. The reporting frequency is essential to assure that any changes in the trial burn plans or in the anticipated permit application contents are made known to EPA and to the public.

3(e)	General Guidelines

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

3(f)		Confidentiality

      Section 3007(b) of RCRA and 40 CFR Part 2, Subpart B, which define EPA's general policy on the public disclosure of information, contain provisions for confidentiality. If the Agency receives any confidential information, it will manage that information according to the protocols established by the Agency, as appropriate.

3(g)	Sensitive Questions

      No questions of a sensitive nature are included in any of the information collection requirements.
            
THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a)	Respondents/NAICS Codes

      The following is a list of North American Industrial Classification System (NAICS) codes associated with the facilities most likely to be affected by the expanded public participation requirements analyzed under this ICR:

      22132		Sewage Treatment Facilities
      32411		Petroleum Refineries
      32511		Petrochemical Manufacturing
      32512		Industrial Gas Manufacturing
      32551		Paint and Coating Manufacturing
      33271		Machine Shops
      33422		Radio and Television Broadcasting and Wireless Communications Equipment Manufacturing
      33633		Motor Vehicle Steering and Suspension Components (except Spring) Manufacturing
      33634		Motor Vehicle Brake System Manufacturing
      33635		Motor Vehicle Transmission and Power Train Parts Manufacturing
      42271		Petroleum Bulk Stations and Terminals
      44111		New Car Dealers
      44711		Gasoline Stations with Convenience Store
      44719		Other Gasoline Stations
      48411		General Freight Trucking, Local
      48421		Used Household and Office Goods Moving
      48422		Specialized Freight (except Used Goods) Trucking, Local
      56292		Materials Recovery Facilities
      221111	Hydroelectric Power Generation
      221112	Fossil Fuel Electric Power Generation
      221113	Nuclear Electric Power Generation
      221119	Other Electric Power Generation
      221121	Electric Bulk Power Transmission and Control
      221122	Electric Power Distribution
      311942	Spice and Extract Manufacturing
      323110	Commercial Lithographic Printing
      323114	Quick Printing
      325131	Inorganic Dye and Pigment Manufacturing
      325188	All Other Basic Inorganic Chemical Manufacturing
      325193	Ethyl Alcohol Manufacturing
      325199	All Other Basic Organic Chemical Manufacturing
      325211	Plastics Material and Resin Manufacturing
      325998	All Other Miscellaneous Chemical Product Manufacturing
      331311	Alumina Refining
      332813	Electroplating, Plating, Polishing, Anodizing, and Coloring
      332999	Other Miscellaneous Fabricated Metal Product Manufacturing
      333319	Other Commercial and Service Industry Machinery Manufacturing
      333999	All Other General Purpose Machinery Manufacturing
      334418	Printed Circuit/Electronics Assembly Manufacturing
      334419	Other Electronic Component Manufacturing
      336211	Motor Vehicle Body Manufacturing
      336312	Gasoline Engine and Engine Parts Manufacturing
      336322	Other Motor Vehicle Electrical and Electronic Equipment Manufacturing
      336399	All Other Motor Vehicle Part Manufacturing
      454311	Heating Oil Dealers
      454312	Liquefied Petroleum Gas (Bottled Gas) Dealers
      562111	Solid Waste Collection
      562112	Hazardous Waste Collection
      562119	Other Waste Collection
      562211	Hazardous Waste Treatment and Disposal
      562212	Solid Waste Landfills
      562213	Solid Waste Combustors and Incinerators
      562219	Other Nonhazardous Waste Treatment and Disposal
      811111	General Automotive Repair
            
4(b)	Information Requested

      Pre-application Public Meeting and Notice  
      
      Under 40 CFR 124.31(a) and (b), facilities applying for an initial Part B permit or a Part B permit renewal, where the renewal application is proposing a change that would qualify as a Class 3 permit modification under 40 CFR 270.42, are required to hold at least one meeting with the public prior to submitting the Part B permit application to the permitting agency. The applicant must submit a summary of the meeting, along with the list of attendees and their addresses, and copies of any written comments or materials submitted at the meeting, to the permitting agency as part of the Part B application (§124.31(c)). Under 40 CFR 124.31(d), applicants must provide public notice (i.e., newspaper advertisement, visible and accessible sign, and broadcast media announcement) of the pre-application meeting at least 30 days prior to the meeting. The applicant also must provide a copy of the notice to the permitting agency and to the appropriate units of State and local government. (Note: In regard to 40 CFR 124.31(c), this ICR addresses the respondent activities associated with collecting the required information.  Submittal of this information to the permitting agency is addressed in Supporting Statement for EPA Information Collection Request Number 1573, "Part B Permit Application, Permit Modifications, and Special Permits."

      (i)	Data Items:
               
 A public notice that includes:

--			The date, time, and location of the meeting;
      
--			A brief description of the purpose of the meeting;
      
--			A brief description of the facility and proposed operations, including the address or a map (e.g., a sketched or copied street map) of the facility location;
      
--			A statement encouraging people to contact the facility at least 72 hours before the meeting if they need special access to participate in the meeting; and
      
--			The name, address, and telephone number of a contact person for the applicant.

 Information to be submitted to the permitting agency as part of the Part B permit application:

--			Copy of newspaper notice announcing the pre-application meeting;
      
--			A summary of a pre-application meeting with the public;
      
--			A list of attendees and their addresses; and
      
--			Copies of any written comments or materials distributed at the meeting.

      (ii)	Respondent Activities:

      To comply with the requirements in Section 124.31, applicants must perform the following activities:

 Read the regulations;

 Prepare notice of pre-application meeting;

 Prepare a multilingual notice of pre-application meeting, if appropriate;

 Provide for publication/posting/broadcasting of notice;

 Provide copy of pre-application meeting notice to the permitting agency and appropriate units of State and local government;

 Retain documentation of the notice;

 Prepare for and conduct the meeting;

 Prepare a meeting summary; and

 Copy the list of attendees with their addresses.

      Information Repository

      Under 40 CFR 124.33, the Agency Director has the authority to require certain applicants/facilities to establish and maintain an information repository. Applicants/facilities instructed by the Agency Director to establish an information repository must, at a minimum, provide a written notice about the information repository to all individuals on the facility mailing list. The Agency Director will determine the information to be placed in the information repository.

Data Items:
      
 Written notice about the information repository; and

 Information in the repository, e.g.:

--			A summary of the pre-application public meeting;
      
--			A copy of the Part B permit application; and
      
--			Any other information the Agency Director determines to be relevant to public understanding of permitting activities at the facility.
      
      (ii)	Respondent Activities: 

      To comply with the requirements in section 124.33, applicants must conduct the following activities:

 Read the regulations;

 Arrange with a local building for space to establish the information repository;

 Provide notice of the repository to individuals on the facility mailing list;

 Provide a multilingual notice of the repository to individuals on the facility mailing list, if appropriate;

 Establish the information repository; and

 Maintain the information repository. 

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

5(a)	Agency Activities

      Notice at Application Submittal

      40 CFR 124.32 requires the Agency to provide public notice, as set forth in sections 124.10(c)(1)(ix) and (x), at the application submittal stage.

      Information Repository

      40 CFR 124.33 provides discretionary authority for the Agency to require, on a case-by-case basis, the owner or operator of a facility to set up an information repository, and to provide a notice to the facility mailing list about the repository. Section 124.33(d) requires the Agency Director to specify the contents of the repository and establish requirements for informing the public about the establishment of the repository (at a minimum, the Agency Director will require the facility to provide written notice to the facility mailing list). 

      Trial Burn Notice

      40 CFR 270.62(b)(6), 40 CFR 270.62(d), 40 CFR 270.66(d)(3), and 40 CFR 270.66(g) require the Agency to provide public notice, as set forth in sections 124.10(c)(1)(ix) and (x), of an impending trial burn at a permitted hazardous waste combustion facility, or at a hazardous waste combustion facility operating under interim status.
	5(b)	Collection Methodology and Management

      In collecting and analyzing the information required by the expanded public participation activities, EPA uses equipment such as personal computers and applicable data base software, when appropriate. The public will receive information through newspaper announcements and other media, and, in some cases, will have access to additional data through an information repository as specified by the Agency under 40 CFR 124.33.

5(c)	Small Entity Flexibility

      In developing the regulations for expanding public involvement in the RCRA permitting process, EPA was sensitive to the needs and concerns of small businesses. Therefore, the regulations describe the minimum efforts necessary to fulfill the public involvement requirements. EPA avoided including narrow, prescriptive requirements in the final RCRA Expanded Public Participation Rule, in order to provide as much flexibility as possible -- for the facility, the community, and the Agency -- in implementing the requirements. Furthermore, EPA conducted a small entity impact screening analysis for the proposed rule and determined that there were no small entities significantly impacted (see 59 FR 28680; June 2, 1994). Because there were no substantive changes to the public participation requirements since the proposal, EPA determined that the requirements do not significantly impact small entities.

      EPA's intent in developing the requirements was to provide flexibility for a facility, in cooperation with local agencies or community groups, to determine the most effective communication mechanisms for a particular situation. EPA recognizes that, in some situations, an information repository could become resource-intensive for a facility or for the local community. EPA addressed this concern by providing discretion to the Director to determine whether to require a repository, rather than requiring it for all facilities.

5(d)	Collection Schedule

      Many of the requirements do not have specific schedules governing the submittal of the information. Requirements that have specific time frames associated with them are described below.

      Pre-application Public Meeting and Notice

      40 CFR 124.31(d) requires the applicant to provide public notice of the pre-application meeting at least 30 days before the meeting is scheduled.

      Notice at Application Submittal

      40 CFR 124.32(b)(2) requires the Agency Director to publish the notice "within a reasonable period of time after the application is received."

      Trial Burn Notice

      40 CFR 270.62(b)(6)(i), 270.62(d), 270.66(d)(3)(i), and 270.66(g) require the Agency Director to provide notice to the mailing list and to appropriate units of State and local government "within a reasonable time period before the scheduled trial burn." 

ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION

6(a)	Estimating Respondent Hours

      EPA estimates respondent burden hours for the information collection requirements associated with the pre-application meeting and the information repository requirements in Exhibit 1. The burden estimates for each activity presented in Exhibit 1 include the burden hours (total and by labor type) per facility, as well as the overall burden hours associated with the given activities.
               
6(b)	Estimating Respondent Costs
            
Labor Costs

      EPA estimates an average hourly respondent labor cost of $128.72 for legal staff, $93.22 for managerial staff, $71.02 for technical staff, and $39.95 for clerical staff. These respondent labor costs were obtained from the previously approved ICR (i.e., EPA ICR Number 1688.07), and updated to 2015 levels using Employment Cost Indexes developed by the U.S. Bureau of Labor Statistics.
      

Capital/Start-Up Costs

      Capital costs usually include any produced physical good needed to provide the needed information, such as machinery, computers, and other equipment. For this ICR, capital costs include the purchase of file cabinets for an information repository.

      In complying with the requirements covered in this ICR, facilities may be required to maintain an information repository. The information repository will require file cabinet space to retain the information required. EPA took the following steps to estimate the cost of the file cabinets:
      
      ::	Estimate the number of file cabinets per facility required for the information repository.  Given that the standard-size, five-drawer, lateral file cabinet is expected to hold approximately 16,000 pages of material, EPA estimates that each facility would need to purchase only one file cabinet to retain copies of the applications and other required documentation within the time period of this ICR. The approximate cost of purchasing a file cabinet is estimated at $830.

      ::	Calculate the annualized cost.  EPA used the following formula to calculate the annual cost to facilities for acquiring the file cabinets:
                              
            Annualized Net Present Value  =  $830 x [1/(∑1/(1+k)[t])]
                                                
               where	k = discount rate of 7 percent; and		
                        t = life of permit (10 years).

      EPA estimates that each facility will pay an annual cost of $118 for its file cabinet. This capital cost is shown in Exhibit 3.

      Operation and Maintenance Costs		

      Operation and maintenance (O&M) costs are those costs associated with a paperwork requirement incurred continually over the life of the ICR. They are defined by the Paperwork Reduction Act of 1995 as "the recurring dollar amount of costs associated with O&M or purchasing services."  For this ICR, O&M costs include:

Newspaper advertisement: EPA estimates that a permit applicant will incur a cost of $28 for one inch of column space in a newspaper of general circulation in the county or equivalent jurisdiction that hosts the proposed location of the facility.  

Broadcast media announcement: EPA assumes that the radio broadcast will be a public service. Therefore, the applicant will incur no costs for the radio announcement.

Meeting materials: EPA estimates that a permit applicant will incur a cost of $30 for 100 copies of a three-piece handout (i.e., 300 pages @ $0.10/page).

Space rental: EPA assumes that a permit applicant will conduct the pre-application public meeting in a community center. Thus, the applicant will incur no space rental costs.

Mailing costs: EPA estimates that a permit applicant will incur a cost of $3.48 to mail the pre-application notice to the permitting agency and the appropriate units of State and local government (i.e., 6 government agencies @ $0.58/agency ($0.49 for stamp and $0.09 for envelope)). EPA also estimates a cost of $145 for mailing a written notice about the information repository to all individuals on the facility mailing list (i.e., 250 individuals on the facility mailing list @ $0.58/individual).

These O&M costs are shown in Exhibit 1. The total estimated O&M costs are $5,681.00.

6(c)	Estimating Agency Hour and Cost Burden

      EPA estimates the Agency hour and cost burden associated with all of the requirements covered in this ICR in Exhibit 2.

      Describing Agency Activities

      Notice at Application Submittal. To estimate the number of facilities for which the Agency will have to provide public notice at application submittal in each year covered by the ICR, EPA referred to RCRAInfo.,   Based on RCRAInfo data, EPA estimated the average annual number of Part B permit applications to be received over a three year period for initial permits and permit renewals.  By adding these two estimates, EPA ascertained the number of application submittals for which the Agency will have to provide public notice during the three-year period covered in the ICR. Based on RCRAInfo data, EPA estimates that 4 initial Part B permit applications, on average, will be received annually over a three year period and 55 permits, on average, will be renewed annually over a three year period.  

      Based on the above assumptions, EPA estimates that the Agency will have to provide public notice at application submittal for 59 facilities per year (i.e., 4 + 55 = 59).  

      Information Repository.  The Agency Director may require facilities to establish information repositories at any point during the permit application process, or during the life of the permit. EPA anticipates that information repositories will be required in a limited number of situations. Unlike the pre-application meeting requirements, facilities submitting post-closure permit applications or modification requests (e.g., a Class 3 modification to add a combustion unit or to begin burning dioxin) could also potentially be required to establish a repository. 

      EPA is assuming that 15 percent of the estimated 59 annual respondents subject to the pre-application meeting requirements (i.e., 0.15 x 59 = 9 facilities) will be required to set up a repository (see Section 6(d) for a description of the respondent universe estimate for the pre-application requirements).  

      Trial Burn Notice.  In estimating the number of facilities for which the Agency will have to provide public notice of an upcoming trial burn, EPA again referred to RCRAInfo.  RCRAInfo indicates that only one trial burn plan was approved over a three year period.  For purposes of this ICR, EPA assumes that the same number will be approved annually over a three year period. 

      Estimating Agency Hour and Cost Burden 

	EPA estimates Agency burden hours for the information collection requirements associated with the application submittal notice, the information repository, and the trial burn notice requirements in Exhibit 2. The burden estimates for each activity presented in Exhibit 2 include the burden hours (total and by labor type) per respondent, as well as the overall burden hours associated with the given activities.

	EPA estimates an average hourly labor cost (labor plus overhead) of $77.92 for legal staff, $72.86 for managerial staff, $53.42 for technical staff, and $21.46 for clerical staff. To derive these estimates, EPA used the General Schedule (GS) Salary Table 2015. For purposes of this ICR, EPA assigned staff the following government service levels:

       Legal Staff		GS-15, Step 1
       Managerial Staff	GS-14, Step 4
       Technical Staff	GS-12, Step 5
       Clerical Staff		GS-5, Step 1

      To derive hourly estimates, EPA divided annual compensation estimates by 2,080, which is the number of hours in the Federal work-year. EPA then multiplied hourly rates by the standard government overhead factor of 1.6.

      Capital/Start-Up Costs.  The Agency is not expected to incur capital costs in conducting the activities covered in this ICR. 

      Operation and Maintenance Costs. For this ICR, O&M costs to the Agency include the costs associated with a public notice announcing that a Part B permit application has been received or that a trial burn will take place. For the announcement of receipt of a RCRA permit application, EPA estimates the total cost of each public notice to be $150.50. This cost includes the cost of a newspaper announcement and mailing costs for providing a written notice to all individuals on the facility mailing list. EPA assumes that the radio announcement will be a public service. Thus, the Agency will incur no cost for a radio announcement. For the announcement of a trial burn, EPA estimates the total O&M cost of each notice to be $122.50.  These O&M costs are shown in Exhibit 2. The total O&M cost is $5,681.00.

6(d)	Estimating the Respondent Universe and Total Hour and Cost Burden

      Pre-application Public Meeting and Notice

      The pre-application meeting requirements apply to all facilities applying for an initial RCRA permit, and to already permitted facilities proposing a significant change in facility operations (i.e., changes equivalent to a Class 3 modification) at renewal. These requirements do not apply to other renewal applications (i.e., those that do not include significant changes), post-closure applications, or routine permit modification requests.

      To estimate the number of initial RCRA permits, EPA referred to RCRAInfo. Based on RCRAInfo data, EPA estimates that 4 initial Part B permit applications, on average, will be received annually over a three year period.

      To estimate the number of permit renewals involving a significant change in facility operations, EPA again relied on RCRAInfo. RCRAInfo indicates that 55 RCRA permits, on average, will be renewed annually over a three year period. EPA assumes that only ten percent (i.e., 55 x 0.10 = 5 permits) will involve significant changes to facility operations and thus be subject to the pre-application meeting requirements.  

      Based on the above assumptions, EPA estimates that 9 facilities (i.e., 4 + 5 = 9), on average, will be subject to the pre-application requirements each year. 

      Information Repository

      EPA estimates that, each year, seven facilities will incur the costs associated with the information repository. (See Section 6(c) for a description of the universe estimate for the information repository requirements.)



6(e)	Bottom Line Hour and Cost Burden

      Respondent Tally

      Exhibit 3 shows the aggregate annual hour and cost burden to respondents. As shown in the exhibit, EPA estimates the annual respondent burden to be 5,614 hours.
      
      Agency Tally

      Exhibit 4 shows the aggregate annual hour and cost burden to the Agency. As shown in the exhibit, EPA estimates the annual Agency burden to be 472 hours, at a cost of $29,379.

	6(f) 	Reasons for Change in Burden


	There is increase of 2,609 hours in the total estimated respondent burden compared with the ICR currently approved by OMB. This increase is due to the adjustment in the respondent universe from 33 to 59. 

6(g)	Burden Statement
                                          
      The annual public reporting burden for this collection of information is estimated to average 90 hours per response. The estimated recordkeeping burden for this collection of information is estimated to average 5 hours per response. The overall annual public reporting and recordkeeping burden for this collection of information is estimated to average 95 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 the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15.  

      To comment on EPA 's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number EPA-HQ-RCRA-2015-0108, which is available for online viewing at www.regulations.gov, or in person viewing at the RCRA Docket in the EPA Docket Center (EPA/DC), WJC 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 RCRA 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, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-RCRA-2015-0108 and OMB Control Number 2050-0149 in any correspondence.




 
--------------------------------------------------------------------------------


--------------------------------------------------------------------------------
 
--------------------------------------------------------------------------------

--------------------------------------------------------------------------------

--------------------------------------------------------------------------------

--------------------------------------------------------------------------------

--------------------------------------------------------------------------------

--------------------------------------------------------------------------------


--------------------------------------------------------------------------------



                  
--------------------------------------------------------------------------------








