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OMB Control No: 2050-0035	ICR Reference No: 201810-2050-006
Status: Historical Active	Previous ICR Reference No: 201409-2050-001
Agency/Subagency: EPA/OLEM	Agency Tracking No: 0820.14
Title: Hazardous Waste Generator Standards (Renewal)
Type of Information Collection: Revision of a currently approved collection	Common Form ICR: No
Type of Review Request: Regular
OIRA Conclusion Action: Approved without change	Conclusion Date: 01/29/2020
	Date Received in OIRA: 10/31/2018
Terms of Clearance: Approval is for one year due to four month delay in response to OMB comments.

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	01/31/2023	36 Months From Approved	01/31/2020
Responses	644,345	0	80,746
Time Burden (Hours)	526,989	0	253,519
Cost Burden (Dollars)	63,345	0	40,040

Abstract: Under the Resource Conservation and Recovery Act (RCRA), as amended, Congress directed EPA to implement a comprehensive program for the safe management of hazardous waste. The core of the national waste management program is the regulation of hazardous waste from generation to transport to treatment and eventual disposal, or from "cradle to grave." Section 3001(d) of RCRA requires EPA to develop standards for small quantity generators. Section 3002 of RCRA states, among other things, that EPA shall establish requirements for hazardous waste generators regarding recordkeeping practices. Section 3002 also requires EPA to establish standards on appropriate use of containers by generators. Finally, Section 3017 of RCRA specifies requirements for individuals exporting hazardous waste from the United States, including a notification of the intent to export, and an annual report summarizing the types, quantities, frequency, and ultimate destination of all exported hazardous waste.

Authorizing Statute(s): US Code: 42 USC 3002 Name of Law: Solid Waste Disposal Act

Citations for New Statutory Requirements: None

Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	83 FR 31140	07/03/2018
30-day Notice:	Federal Register Citation:	Citation Date:
	83 FR 54344	10/29/2018
Did the Agency receive public comments on this ICR? No

Number of Information Collection (IC) in this ICR: 1

IC Title	Form No.	Form Name
Hazardous Waste Generator Standards

ICR Summary of Burden

	Total Approved	Previously Approved	Change Due to Adjustment in Estimate
Annual Number of Responses	644,345	80,746	563,599
Annual Time Burden (Hours)	526,989	253,519	273,470
Annual Cost Burden (Dollars)	63,345	40,040	23,305

Burden increases because of Program Change due to Agency Discretion: No

Burden Increase Due to:

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: Three factors explain the overall change in the total estimated burden. First, there was an increase in the number of SQGs and LQGs. In estimating the hourly burden for the 2010 ICR, the Agency estimated both a low and high-end estimate for SQGs but provided a high end for purposes of estimated hourly burden. In the 2014, the Agency estimated of the SQG universe by taking the average of both the low and high end SQG universes. In this ICR, the Agency went back to using the high-end estimated hourly burden to ensure that all possible burden is captured. Second, this ICR incorporates the applicable burden from the 2016 Hazardous Waste Generator Improvements Rule, which added requirements such as LQG contingency plans, LQG closure, and intra-organizational transfers, for example. Some of the added burden associated with the new flexibilities for SQGs and VSQGs (intra-organizational transfers and episodic generation) is likely overstated, because EPA expects them to be cost and burden savings measures as a whole. The methodology used was initially developed to estimate the number of SQGs for the “Hazardous Waste Generator Improvements Rule." To derive an estimate of the number of SQGs, EPA relied on information in the 2007, 2009, 2011 and 2013 BR and RCRAInfo databases. Specifically, EPA used the WR form in the BR database to identify all facilities that shipped hazardous waste off-site and compared this list against the Site ID form in RCRAInfo to identify active SQGs. This analysis was conducted to exclude inactive SQGs in the RCRAInfo database. SQGs that sent multiple hazardous waste shipments to a single TSDF, or more than one TSDF, were only counted once. Furthermore, as part of EPA’s data collection effort, several states provided information on the number of SQGs statewide. These states include Alabama, California, Florida, Illinois, Massachusetts, Maine, Minnesota, New Hampshire, New Jersey, Ohio, Rhode Island, and Wisconsin. Therefore, where state-level data were provided, EPA relied on this information rather than estimates derived from the BR and RCRAInfo databases. Third, the number of generators exporting and importing hazardous waste increased between 2016 and 2018 as a result of the Export-Import rule that became effective in D of 2010 – too late to impact the 2010 ICR. Between 2011 and 2014, the number of generators either importing or exporting hazardous waste increased from 1,293 to 3,256 for an increase of 152 percent. As noted, this ICR incorporates new regulations from two recently promulgated rules: The Hazardous Waste Generator Improvements rule of 2016 (OMB Control No. 2050-0213) and the Hazardous Waste Export-Import Revisions rule of 2016 (OMB Control No. 2050-0214). The hours and costs incorporated from the rule ICRs into this ICRs is less than the total hours and cost reported in those ICRs because the notification and biennial reporting requirements associated with those rules were incorporates into a separate ICR (OMB Control No. 2050-0024).

Annual Cost to Federal Government: $855,027

Does this IC contain surveys, censuses, or employ statistical methods? No

Does this ICR request any personally identifiable information (see OMB Circular No. A-130 for an explanation of this term)? Please consult with your agency's privacy program when making this determination. No

Does this ICR include a form that requires a Privacy Act Statement (see 5 U.S.C. §552a(e)(3))? Please consult with your agency's privacy program when making this determination. No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Uncollected

Agency Contact: Peggy Vyas 703 308-5477 vyas.peggy@epa.gov

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