                             Supporting Statement 
for
Collection of Information on Anaerobic Digestion Facilities Processing Wasted Food
            to Support EPA's Sustainable Food Management Program

               EPA Information Collection Request Number 2533.01
                                       
                                       
                                       
                                       

                                       
                                       
                               February 16, 2016
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Contents
1.	IDENTIFICATION OF THE INFORMATION COLLECTION	1
1(a)	Title of the Information Collection	1
1(b)	Short Characterization/Abstract	1
2. NEED FOR AND USE OF THIS COLLECTION	3
2(a)	Need/Authority for the Collection	3
2(b)	Practical Utility/Users of the Data	3
3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA	4
3(a) Nonduplication	4
3(b)	Public Notice Required Prior to ICR Submission to OMB	5
4. THE RESPONDENTS AND THE INFORMATION REQUESTED	6
4(a)	Respondent NAICS Codes	6
4(b)	Information Requested	9
5. THE INFORMATION COLLECTED - AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT	11
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 BURDEN AND COST OF THE COLLECTION	12
6(a)	Estimating Respondent Burden	12
6(b)	Estimating Respondent Costs	13
6(c)	Estimating Agency Burden and Costs	16
6(d)	Estimating the Respondent Universe	18
6(e)	Bottom Line Burden Hours and Costs	19
6(f)	Reasons for Change in Burden	19
6(g)	Burden Statement	19



                                       
 IDENTIFICATION OF THE INFORMATION COLLECTION
Title of the Information Collection
      This new information collection is entitled "Collection of Information on Anaerobic Digestion Facilities Processing Wasted Food to support EPA's Sustainable Food Management Program," ICR number 2533.01, OMB control number 2050-NEW.
Short Characterization/Abstract

      EPA's Office of Land and Emergency Management Sustainable Food Management (SFM) program is designed to advance sustainable food management practices throughout the United States by preventing and diverting wasted food from landfills.  The focal point of the SFM program is the Food Recovery Challenge in which organizations pledge to improve their sustainable food management practices.  The success of the SFM program efforts to divert wasted food from landfills requires sufficient capacity to process the diverted materials which includes composting and anaerobic digestion operations.  In addition to increasing opportunity to process wasted food diverted from the municipal solid waste stream, anaerobic digesters achieve social, environmental and economic benefits, such as generation of renewable energy, reduction of methane emissions, and opportunities to improve soil health through the production of soil amendments.  The SFM program supports these efforts by educating state and local governments and communities about the benefits of wasted food diversion.  The SFM program also builds partnerships with state agencies and other strategic partners interested in developing organics recycling capacity and provides tools to assist organizations in developing anaerobic digestion (AD) projects.   
      The SFM Program informally tracks data on anaerobic digesters to quantify and monitor the capacity for processing diverted wasted food in the United States at AD facilities. This AD data consists of information compiled from publicly available sources only.  The information requested by this ICR is being formally collected for the first time and would exceed 10 non-Federal respondents. This information collection would allow the SFM program to document the capacity for processing wasted food at AD facilities, track the growth of this capacity and provide a better understanding of the factors affecting this growth.  This knowledge will also help develop future activities designed to further increase capacity.  Increasing capacity for digestion of wasted food will spur growth in the biogas sector as a whole, advance federal goals to reduce methane emissions, increase production of renewable energy and assist state and local governments with their solid waste diversion goals.
      This information collection consists of a data collection request to gather details regarding AD facilities for enhancement of the existing data into an AD facility inventory for the SFM program (SFM AD Facility Inventory).  This information collection will include annual updates to the data set.  Respondents will be requested to complete a questionnaire for this effort. 
      A key objective of the SFM program is to support beneficial use of wasted food by decreasing barriers to diversion.  Providing information on the location and capacity of AD facilities in the United States to receive wasted food and other organic materials can assist with this issue.  In order to ensure that the existing AD data is complete and accurate, the SFM program needs to gather information from all stakeholders involved in the development and management of AD facilities accepting organic wastes.  This includes state and local regulatory officials as well as industry representatives.  Annual updates to the SFM AD Facility Inventory will be necessary to maintain accuracy over time.  This information will allow EPA to estimate and communicate the total capacity and environmental benefits of these projects and enable the SFM program to strategically plan future activities to support sustainable food management practices.  Additionally, stakeholders can use this information to encourage the diversion of wasted food and justify funding resources for AD projects.  Respondents for this ICR are: 1) State Liaisons, 2) Industry Representatives, 3) Project Owners/Operators, and 4) Other Stakeholders (e.g. non-profits). 
      This ICR provides a comprehensive description of information collection efforts to support EPA's SFM program.  Sections 1 through 5 describe the information collection with respect to need, use and respondent activities. Section 6 estimates the annual hour and cost burden to respondents and the Agency under this collection.

2. NEED FOR AND USE OF THIS COLLECTION
          2(a)	Need/Authority for the Collection
      Information collected from respondents will allow EPA to track, facilitate and measure the increase in capacity to process wasted food (organics) via anaerobic digestion throughout the United States.   The success of the Sustainable Food Management Program's Food Recovery Challenge is dependent on a steady increase of processing capacity over time.  At this time, EPA does not have the necessary data to demonstrate this growth or to document the current baseline processing capacity.  As the practice of organics diversion gains momentum, the rate at which wasted food is diverted from landfills will rapidly increase.  This data is essential for EPA to evaluate agency activities designed to build such capacity and to make adjustments to the overall Sustainable Materials Management (SMM) program, as needed.  The importance of this type of data was recently emphasized in EPA's SMM Strategic Plan (Fiscal Year 2017-2022).
          2(b)	Practical Utility/Users of the Data
EPA will use information submitted by respondents to update and expand its inventory of AD facilities.  Data on processing capacity and end uses of AD products will be collected as part of the inventory expansion.  Data on AD projects will serve as a source of information to inform the public and lawmakers about the environmental benefits, such as renewable energy, derived from anaerobic digesters.  The quantitative and qualitative data captured will assist the SFM program with future resource planning. EPA will use information provided by state contacts involved in the review and approval of new or ongoing projects to update the inventory and to identify barriers and opportunities within the AD sector. Information from industry representatives, project owner/operators, and other stakeholders will increase EPA's ability to provide technical assistance to states and municipalities related to project design, implementation, cost effectiveness, return on investment and successful business models.

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA
    3(a) Nonduplication
For non-federal respondents, the information to be collected has not been collected previously by EPA or any other federal agency from more than 9 respondents. Comprehensive information about existing and new AD projects is not available through any other mechanism. To avoid requesting information that has already been compiled, respondents will receive a spreadsheet, pre-populated with existing AD data. Respondents will be asked to review the information and to provide updates as well as missing or additional information. 
The AD community often announces the planning or installation of digester operations, so some of the necessary data are available in publications.  The information collection process will allow EPA to collect information from respondents related to the unpublished details of AD projects and projects not covered by existing publications.
       3(b)	Public Notice Required Prior to ICR Submission to OMB
      This Supporting Statement is associated with the initial Federal Register notice for this ICR.  Any comments received during the first 60-day public comment period will be documented prior to submittal of the ICR package to OMB.  
  3(c) 	Consultations
      SFM staff contacted three respondents to request information on the estimated amount of time required to respond to the SFM AD Facility Inventory questionnaire.
Table 1: List of Respondent Consultations for the SFM AD Facility Inventory Update
                         Contact Person, Organization 
                                     Role
                                 Email Address
Brian Langolf, Director of Biogas Systems and Research Development, University of Wisconsin  -  Oshkosh
                                  AD Operator
langolfb@uwosh.edu 
Dana Kirk, Assistant professor in Biosystems and Agricultural Engineering, Michigan State University 
                                  AD Operator
Kirkdana@anr.msu.edu

Dave Baran, Quasar Energy Group, Project Development
                             AD Vendor/Consultant
dbaran@quasareg.com
      
      3(d)	Effects of Less Frequent Collection
      The SFM AD Facility Inventory and questionnaire will be distributed to potential respondents annually.  Any reduction in the frequency of this information collection would impede efforts to facilitate anaerobic digestion implementation and track the increased diversion of wasted food and expanded infrastructure capacity in the organics recycling sector. 

      3(e)	General Guidelines
      Information collections performed under this clearance will follow all of OMB's General Guidelines regarding federal data collection.
      3(f) 	Confidentiality
Participation in this data collection effort is voluntary.  Respondents are not required to reveal confidential business information. Additionally, respondents will be given specific instructions to not provide any information that they consider confidential.
      3(g) 	Sensitive Questions
      No questions of a sensitive nature are asked as part of this collection effort or included within the pre-populated project data spreadsheet.  
4. THE RESPONDENTS AND THE INFORMATION REQUESTED
       4(a)	Respondent NAICS Codes
      This information collection will encompass a wide variety of respondents. State liaisons include staff from state agencies involved in energy, environment and solid waste management. Industry representatives include engineering firms, construction companies, environmental consultants, and other companies involved in the logistics of developing anaerobic digesters.  Other stakeholders include non-profit groups or non-governmental organizations (NGOs), as well as universities that provide information or other support to the project owners or industry representatives. Table 4 provides a summary of the applicable North American Industry Classification System (NAICS) codes and relevant descriptions for each type of respondent.  The NAICS description is followed by the relevant sector and Standard Occupational Classification (SOC) code.  The SOC code will be used to determine the applicable labor rate for each type of respondent. 
      
                Table 4: Respondents to Information Collection
                                Respondent Type
                                  NAICS Code
                    NAICS Description (Sector and SOC code)
State Liaison
                                    999200
Public Administration; State Managers (Sector 99: Federal, State and Local government; SOC code 11-9041  -  Architectural and Engineering Managers)
Industry Representatives
                                    221100
Electric Power Generation, Transmission and Distribution (Sector 22: Utilities; SOC code 17-2081  -  Environmental Engineers)

                                    333100
Agriculture, Construction, and Mining Machinery Manufacturing  (Sector 33: Manufacturing; SOC code 11-9041  -  Architectural and Engineering Managers)

                                    541300
Engineering Services (Sector 54: Professional, Scientific, and Technical Services; SOC code 17-2081  -  Environmental Engineers)
Project Owners or Operators
                                    541300
Engineering Services (Sector 54: Professional, Scientific, and Technical Services; SOC code 17-2081  -  Environmental Engineers)

                                    221300
SOC Code 51-8031:  Water and Wastewater Treatment Plant and System Operators

                                    611300
Colleges, Universities, and Professional Schools (Sector 61: Educational Services; SOC code 17-2081  -  Environmental Engineers)
Other Stakeholders
                                    813900
Business, Professional, Labor, Political, and Similar Organizations (Sector 81: Other Services; SOC codes 19-4091  -  Environmental Science and Protection Technicians (for Conservation non-profit staff; university researchers) 

 		
		Table 5 below provides example respondents under each respondent type, the applicable NAICS codes, and the number of potential respondents for the program covered by this ICR. This table shows the number of potential respondents for each NAICS. 
                   Table 5: Number of Potential Respondents
                                Respondent Type
                                  NAICS Code
                             Example Respondent(s)
                                       
                               SFM AD Inventory
State Liaison
999200
State energy or natural resources official
                                      60
Industry Representatives
221100
Electric cooperative engineer; Energy service providers
                                      10

333100
Manufacturers or distributors of AD systems
                                      20

541300
Consultants and system developers
                                      25
                                       

541300
AD facility operator
                                      75
Project Owners or Operators
221300
Water and Wastewater Treatment Plant and System Operator
                                       
                                      200
                                       

611300
University digester operator
                                      15
Other Stakeholders
813900
Conservation non-profits; University researchers
                                      10
TOTAL (Year 1)
                                      415

TOTAL (Year 2)
                                      458

TOTAL (Year 3)
                                      508


       4(b)	Information Requested
      (i)	Data Items, Including Recordkeeping Requirements
Information will be collected annually for the SFM AD Facility Inventory.  Questionnaires specific to respondent type and a pre-populated electronic spreadsheets will be used to collect information and track updates.  As stated above in Section 1(b), collection of information on anaerobic digesters for the SFM AD Facility Inventory is intended to provide information on the capacity for recycling of food-based materials and the growth of this capacity over time.  During the first year of data collection, respondents will be requested to respond to a questionnaire designed to obtain the following information on the facilities that are within their purview:
 Project name, type, location, and operational status;
 Feedstock type and volume processed;
 Digester characteristics and capacity, including design specifications; and
 Information on the end-use of by-products produced.
This information is needed to effectively track existing AD projects and their capacity for processing food and other organic wastes and to gain a better understanding of the market for AD by-products.   Respondents will also be requested to review a spreadsheet of existing information and identify any additional facilities that they might be aware of or have information about.  This information will assist EPA in identifying facilities that are not currently part of the data set.  To date, the SFM program has compiled preliminary AD facility data based on publicly available information.  
During subsequent year requests, respondents associated with the facilities that are already part of the SFM AD Facility Inventory, will receive a pre-populated electronic spreadsheet with the previous years' data set.  These respondents will be requested to review this data and provide new or revised information where appropriate.  The number of respondents is expected to increase by 10% each year.  For data collection during years 2 and 3 of this ICR, completion of the questionnaire will only be necessary for respondents associated with newly identified facilities not previously represented in the data set.  
Project owners and operators may choose to provide information to EPA more frequently than annually if there are changes to project status, capacity, processing rates etc.  However, the SFM program will update information made available to the public on all projects on an annual basis. Participation does not require that any records be kept, although respondents will likely maintain file copies of updates submitted to EPA. 
 (ii)	Respondent Activities
      Respondents will provide detailed information only on the projects in which they are involved. 
For the initial data request respondents will:
          complete the questionnaire (provided by EPA);
          review the pre-populated spreadsheet (provided by EPA);
          identify additional facilities, if known;
          email information on new facilities and/or the completed questionnaire to EPA; and
          maintain a filed copy of the information submitted electronically (optional).
To provide annual updates to the SFM AD Facility Inventory respondents will:
          review the spreadsheet with the pre-populated data set;
          provide updated information on the projects under the respondents' purview in a separate un-populated spreadsheet (provided by EPA); 
          identify additional facilities, if known;
          email information on new facilities and/or newly populated spreadsheet to EPA; and
          maintain a filed copy of the information submitted electronically (optional)
5. THE INFORMATION COLLECTED - AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT
       5(a)	Agency Activities
In requesting and receiving information under this ICR for development and maintenance of the SFM AD Facility Inventory, EPA will complete the following tasks:
 Collect updates/questionnaires from respondents and maintain copy of all submitted data;
 Review information provided and follow up with respondent, if necessary;
 Use information collected to enhance the existing data into the SFM AD Facility Inventory (Year 1);
 Enter information into the SFM AD Facility Inventory file (Years 2 and 3); and
 Post facility information on the EPA website
       5(b)	Collection Methodology and Management
      EPA selected the methods for collecting this information to optimize efficiency and minimize the burden for respondents and EPA. The SFM program will notify respondents by email with an attached spreadsheet and questionnaire. All information received from respondents will be reviewed by EPA before being finalized and posted on the EPA website.
       5(c)	Small Entity Flexibility
      The respondent type identified as "Other Stakeholders" are not classified as small entities due to the non-profit nature of these respondents.   Many of the project owner/operators are municipalities or cities.  Both municipalities and cities as well as state liaisons are considered government entities.  According to the United States Small Business Administration (SBA), government entities are not permitted to be classified as small businesses for the purposes of this analysis.  
      Based on the applicable thresholds for the remaining NAICS codes as established by the SBA (see: https://www.sba.gov/content/small-business-size-standards) some industry representatives may be considered small entities.  In particular, manufacturers or distributors of AD systems and consultants and system developers could be classified as small entities.  
      However, the average annual burden and cost per respondent requested under this ICR is estimated to be 30 minutes and $74, respectively.   The response burden does not require any capital investments, only a small amount of labor and EPA ensures that the process for responding to the AD inventory questionnaires and updates is as efficient as possible by providing a pre-populated spreadsheet that respondents can simply review and provide the requested information or updates.  This annual burden and cost is not expected to pose a significant burden on small entities.  In addition, a response is requested by EPA, but not required and respondents may choose not to respond.  
       5(d)	Collection Schedule
      EPA will collect information annually for the SFM AD Facility Inventory through the use of questionnaires and pre-populated spreadsheets which respondents can review, complete and update.
6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION 
       6(a)	Estimating Respondent Burden
      In order to obtain accurate hourly burden and cost estimates, EPA consulted with three stakeholders regarding burden and cost assumptions for this ICR. The total hourly burden estimates for the program (for the entire 3-year ICR time period) are summarized in Table 7 below. 
   Table 7: Total Burden Hours for SFM AD Inventory Updates (3 Year Period)
                                Respondent Type
                                  NAICS Code
                             Total Burden (hours) 
                        October 2016  -  September 2019
State Liaisons
                                    999200
                                      100
Industry Representatives
                                    221100
                                      17

                                    333100
                                      34

                                    541300
                                      42
Project Owners or Operators
                                    541300
                                      125

                                    221300
                                      331

                                    611300
                                      26
Other Stakeholders
                                    813900
                                      17
TOTAL
                                      692

 		
      The burden hours listed in the table above are based on the following assumption:  each annual inventory update for the SFM AD Facility Inventory requires 30 minutes. The burden hour estimates displayed in Table 7 are rounded to the nearest hour. The respondent costs, including wage rate assumptions, are described below. Table 9 presents the estimated total respondent costs during the 3-year ICR period for each type of respondent, using the wage rates outlined in Table 8.
       6(b)	Estimating Respondent Costs
             Estimating Labor Costs
      For each respondent type and NAICS code, EPA used the mean hourly wage for the applicable SOC codes, which are listed in Table 8 below. Labor rates were not divided into clerical, legal, or other labor sub-categories for a specific NAICS code since respondents subject to the information collection effort will be primarily engineers/scientists. Rates were obtained from the Bureau of Labor Statistics' May 2014 National Industry-Specific Occupational Employment and Wage Estimates (see: http://www.bls.gov/oes/current/oessrci.htm#11). The total labor rate used to calculate cost was obtained by applying an overhead rate of 110 percent.   
          Table 8: Mean Hourly Wages by Respondent Type and SOC Code
                                Respondent Type
                                  NAICS Code
                                   SOC code
                                   May 2014
                             Mean Hourly Wage ($)
                                   May 2014
                             Mean Hourly Wage ($)
                               (+110% overhead)
                                   May 2016
                             Mean Hourly Wage ($) 
                             (+ 2% annual growth)
State Liaisons
                                    999200
SOC code 11-9041: Architectural and Engineering Managers
                                     45.20
                                     94.92
                                     98.75
Industry Representatives
                                    221100
SOC code 17-2081: Environmental Engineers
                                     40.43
                                     84.90
                                     88.33

                                    333100
SOC code 11-9041: Architectural and Engineering Managers
                                     64.51
                                    135.47
                                    140.94

                                    541300
SOC code 17-2081: Environmental Engineers
                                     42.35
                                     88.94
                                     92.53
Project Owners or Operators
                                    541300
SOC code 17-2081: Environmental Engineers
                                     42.35
                                     88.94
                                     92.53

                                    221300
SOC Code 51-8031:  Water and Wastewater Treatment Plant and System Operators
                                     21.25
                                     44.63
                                     46.43

                                    611300
SOC code 17-2081: Environmental Engineers
                                     37.76
                                     79.30
                                     82.50
Other Stakeholders
                                    813900
SOC code 19-4091: Environmental Science and Protection Technicians (For Conservation Non-profit staff, university researchers 
                                     25.26
                                     53.05
                                     55.19

                                       

                                       
                                       
                                       
 	
      

      To ensure that the rates accurately reflect the expected rates at the start of this ICR, May 2016 labor rates were estimated by applying an annualized 2% growth factor from the Employment Cost Index to account for increases in wages from May 2014 to May 2016.  This is based on the fact that for both private industry and civilian workers, the Employment Cost Index increased by 2.0 percent in 2015 (see: http://www.bls.gov/news.release/eci.t04.htm). Labor costs across the 3-year time period for this ICR are calculated using labor rates that assume an average 2% increase each year using the May 2016 rates as a starting point. 
             Estimating Capital and Operations and Maintenance Costs
      Because this information collection requires respondents only to report information that is already available to them, there are no capital costs. EPA does not expect that the operations and maintenance (O&M) costs of this program will be significant.  The total costs for this information collection are summarized in Table 9 below and are rounded to the nearest dollar.  The total cost values are based on the fully loaded rates that include overhead and growth as shown in Table 8 (and then increased by 2% each year during the 3-year time period for this ICR) and the total burden hours in Table 7.

Table 9: Summary of Respondent Burden  -  Total Cost for SFM AD Inventory (3 Year Period)

                                Respondent Type
                                  NAICS Code
                            Total Burden Cost ($): 
                            May 2016  -  April 2019
State Liaison
                                    999200
                                                                        10,024 
Industry Representatives
                                    221100
                                                                         1,532 

                                    333100
                                                                         4,817 

                                    541300
                                                                         3,964 
Project Owners or Operators
                                    541300
                                                                        11,799 

                                    221300
                                                                        15,676 

                                    611300
                                                                         2,146 
Other Stakeholders
                                    813900
                                                                           957 
TOTAL
                                                                        $50,915
 

	The total cost for the entire 3-year ICR time period is $50,915.  This represents the total overall cost for the respondent portion of this ICR since there are no capital expenditures or O&M costs.
       6(c)	Estimating Agency Burden and Costs  
Following is a summary of the Agency burden associated with each activity, as described in Section 5(a).  
 Collect updates/questionnaires and maintain copy of all submitted data
   Clerical: 1 hour per update (updates are annual; 1 hour per year)
 Review the information provided and follow up with respondent if necessary
   Technical: 40 hours per update (updates are annual; 40 hours per year)
 Develop an updated inventory (Year 1) 
   Technical: 80 hours (Year 1 only)
 Enter data into the SFM AD Facility Inventory file (Years 2 and 3 only)
   Clerical: 8 hours per update (8 hour per year; Years 2 and 3 only)
 Post SFM AD Facility Inventory data on the EPA website
Technical: 0.25 hours per update (updates are annual; 0.25 hour per year) 

Tables 9a and 9b present the estimated total agency burden hours and costs, respectively, for the information collection activities associated with this ICR. The burden hours in Table 9a reflect the entire 3-year time period covered by this ICR. The totals are rounded to the nearest hour.  To obtain an hourly burden estimate for the entire ICR time period, annual time estimates for each relevant labor category as described above were multiplied by the appropriate factor depending on whether the activity will be conducted for one, two or all three years. The totals in Table 9b reflect the associated cost by labor category based on the total burden hours presented in Table 9a.  
EPA estimates an average hourly cost using set EPA salary rates for labor plus an additional 60% for overhead.  To derive these estimates, EPA used the "Salary Table 2016 - GS" from the Department of Personnel Management (see: http://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2016/GS_h.pdf).  For purposes of this ICR, EPA assigned staff the following government service levels: 1) Technical Staff - GS-12, Step 5; and 2) Clerical Staff - GS-5, Step 1.  The corresponding salary rates are $33.72 for technical staff and $13.54 for clerical staff. When the 60% overhead is included the corresponding rates are $53.95 for technical staff and $21.66 for clerical staff.  No managerial hours will be spent on implementation of this ICR.  




                     Table 9a: Total Agency Burden Hours 

Labor Category
                         Total Agency Burden (hours): 
                            May 2016  -  April 2019
Technical (GS-12, step 5)
                                      216
Clerical (GS-5, step 1)
                                       4
TOTAL
                                      220
 		
                         Table 9b: Total Agency Cost 

Labor Category
                            Total Agency Cost ($): 
                            May 2016  -  April 2019
                                       
                    Total Agency Cost + 60% Overhead ($): 
                            May 2016  -  April 2019
Technical (GS-12, step 5)
                                     7,284
                                    11,654
Clerical (GS-5, step 1)
                                      54
                                      87
TOTAL ($)
                                     7,338
                                    11,741
 		
Table 9b presents the total cost to the Agency as described in Section 5(a). The total agency burden for the relevant ICR time period is 220 hours and the total cost is $11,741.

       6(d)	Estimating the Respondent Universe
The number of respondents for each year of this ICR is expected to gradually increase over time. It is anticipated that the entire number of facilities will increase by approximately 10% per year over the three years of the ICR. Tables 10a and 10b present a summary of the respondent universe by category for the next 3-year ICR period for total hours and total costs, respectively. The burden estimates are based on the total respondent universe.
                    Table 10a: Total Hours (3 Year Period)

                                 Total Hours: 
                            May 2016  -  April 2019
AGENCY BURDEN 
                                      220
RESPONDENT BURDEN
                                      691
TOTAL BURDEN 
                                      911
 		
                                       
                    Table 10b: Total Costs (3 Year Period)


                               Total Cost ($): 
                            May 2016  -  April 2019
AGENCY COST
                                    11,740
RESPONDENT COST
                                    52,038
O&M/Capital Costs
                                       0
TOTAL COST ($)
                                    63,778
 		
       6(e)	Bottom Line Burden Hours and Costs
Over the 3-year period covered by this ICR, EPA estimates the total respondent burden to be 691 hours and $50,915.  There are no O&M or capital costs. EPA estimates the total Agency burden to be 220 hours and $11,741. The annual respondent burden and cost, averaged over the three-year period, is 231 hours and $16,972, respectively.  There are no O&M or capital costs. The annual Agency burden and cost, averaged over the three-year period, is 73 hours and $3,914.  The total estimated burden and cost is 304 hours and $20,886 per year. 
       6(f)	Reasons for Change in Burden
The change in burden is not applicable in this case since this is a new ICR.
       6(g)	Burden Statement
The overall annual public reporting and recordkeeping burden for this collection of information is estimated to average approximately 30 minutes and $74 per respondent.  
Burden means the total time, effort or financial resources expended by persons to generate, maintain, retain and disclose or provide information to or for a federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.
      To comment on the agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID EPA-HQ RCRA-2015-0836, which is available for online viewing at www.regulations.gov, or in person viewing at the Resource Conservation and Recovery Act Docket in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave. NW, Washington, DC. The EPA/DC Public Reading Room is open from 8 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is 202-566-1744, and the telephone number for the Resource Conservation and Recovery Act 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 access those documents in the public docket that are available electronically. In the system, select "search," then key in the Docket ID Number identified above. Alternatively, send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Office for EPA. Please include the EPA Docket ID No. EPA-HQ RCRA-2015-0836 in any correspondence.


















