SUPPORTING STATEMENT FOR CONTINUING EPA INFORMATION COLLECTION REQUEST 1745.02 CRITERIA FOR CLASSIFICATION OF SOLID WASTE DISPOSAL FACILITIES AND PRACTICE (RCRA PART 257) February 22, 1999 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. . . . . . . . . . 2 3. THE RESPONDENTS AND THE INFORMATION REQUESTED . . . 2 3(a) Respondents/SIC codes. . . . . . . . . . . . 2 3(b) Information Requested. . . . . . . . . . . . 3 4. THE INFORMATION COLLECTED-- AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT. 7 4(a) Agency Activities. . . . . . . . . . . . . . 7 4(b) Collection Methodology and Management. . . . 7 4(c) Small Entity Flexibility . . . . . . . . . . 7 4(d) Collection Schedule. . . . . . . . . . . . . 7 5. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA. . . . . . . . . . . . . . . . . . . . . . 8 5(a) Nonduplication . . . . . . . . . . . . . . . 8 5(b) Consultations. . . . . . . . . . . . . . . . 9 5(c) Effect of Less Frequent Collection . . . . . 9 5(d) General Guidelines . . . . . . . . . . . . . 9 5(e) Confidentiality. . . . . . . . . . . . . . . 9 5(f) Sensitive Questions. . . . . . . . . . . . . 9 6. ESTIMATING THE BURDEN HOURS AND COST OF THE COLLECTION. . . . . . . . . . . . . . . . . . . . . 9 6(a) Estimating the Respondent Burden Hours - Original ICR . . . . . . . . . . . . . . . . 9 6(b) Estimating the respondent Burden Hours - Continuing ICR . . . . . . . . . . . . . . . 11 6(c) Estimating Respondent Burden Hours and Costs 15 6(d) Estimating Agency Burden Hours and Cost. . . 15 6(e) Estimating State Burden Hours and Cost . . . 16 6(f) Bottom Line Burden Hours and Costs/Master Tables . . . . . . . . . . . . . . . . . . . 16 6(g) Reasons for Change in Burden . . . . . . . . 17 6(h) Burden Statement . . . . . . . . . . . . . . 17 EXHIBITS Estimated Respondent Wage Rates (Exhibit 1) . . . . . . . 15 Estimated Agency/State Wage Rates (Exhibit 2) . . . . . . 15 Estimated State Recordkeeping/Reporting Burden and Cost (Exhibit 3) . . . . . . . . . . . . . . . . . . . . . . . 16 Estimated Annual Respondent Recordkeeping Burden and Cost (Exhibit 4) . . . . . . . . . . . . . . . . . . . . . . . 18 Estimated One-Time Respondent Recordkeeping Burden and Cost (Exhibit 5) . . . . . . . . . . . . . . . . . . . . . . . 19 Estimated Annual Respondent Reporting Burden and Cost (Exhibit 6) . . . . . . . . . . . . . . . . . . . . . . . 20 Estimated One-Time Respondent Reporting Burden and Cost (Exhibit 7) . . . . . . . . . . . . . . . . . . . . . . . 21 Total Estimated Annual and One-Time Burden Hours and Cost (Exhibit 8) . . . . . . . . . . . . . . . . . . . . . . . 22 1. IDENTIFICATION OF THE INFORMATION COLLECTION 1(a) TITLE AND NUMBER OF THE INFORMATION COLLECTION This continuing ICR is entitled "Criteria for Classification of Solid Waste Disposal Facilities and Practices" (RCRA Part 257), ICR 1745.02. 1(b) CHARACTERIZATION OF THE INFORMATION COLLECTION The 1984 Hazardous and Solid Waste Amendments (HSWA) to the Resource Conservation and Recovery Act (RCRA), as amended, mandated that the U.S. Environmental Protection Agency (EPA) revise the Criteria for Solid Waste Disposal Facilities that may receive household hazardous wastes and conditionally exempt small quantity generator (CESQG) wastes. EPA submitted a Report to Congress in October 1988 that assessed the impacts on human health and the environment associated with Subtitle D (non-hazardous waste) units. While this study found that the revised Criteria for municipal solid waste disposal units were necessary to protect human health and the environment, the report failed to draw a conclusion relating to industrial Subtitle D units. The limited data on such units indicated that there might be a basis for concern and further study was needed. The proposed "Solid Waste Disposal Facility Criteria" were published on August 30, 1988. On October 9, 1991 EPA promulgated revised Criteria for Solid Waste Disposal Facilities (56 FR 50978) accepting household hazardous wastes. These revisions fulfilled the part of the statutory mandate in RCRA Section 4010 for all units that receive household and CESQG hazardous wastes (i.e., municipal solid waste landfills (MSWLFs)). Revisions to the Part 257 Criteria for other Subtitle D disposal units that may receive CESQG hazardous wastes were delayed as the Agency had little information concerning the potential or actual impacts that these types of units had on human health and the environment. On October 21, 1993, the Sierra Club filed suit against EPA in the United States District Court for the District of Columbia to compel EPA to promulgate revised Criteria for non-municipal units that may receive small quantity generator hazardous waste. As a result of the October 21, 1993 lawsuit, EPA and the Sierra Club reached agreement on a schedule concerning revised Criteria for non-municipal units that may receive CESQG wastes. This schedule required that the EPA Administrator sign a proposal by May 15, 1995 and a final rule by July 1, 1996. The proposal was signed on May 15, 1995 and the Agency promulgated the final rule on July 1, 1996. The attached supporting statement provides continued justification for the information collection requirements included in the final rulemaking for non-municipal units that may receive CESQG wastes. In general, the final Criteria require that the following information be recorded in the facility operating record as it becomes available, and that this information be retained by the owner and made available to the State upon request: (1) Any location restriction demonstration required in Sections 257.8-257.9; and (2) Any monitoring, testing, or analytical data required in Sections 257.21- 257.28. A brief summary of the information collection requirements associated with these areas is provided in Section 3. A more detailed discussion of each data element and the respondent activities associated with each of the information collection requirements is presented in Section 6. 2. NEED FOR AND USE OF THE COLLECTION 2(a) NEED AND AUTHORITY FOR THE COLLECTION The final revisions to the Criteria for Classification of Solid Waste Disposal Facilities and Practices and Identification and Listing of Hazardous Waste set forth in 40 CFR Part 257 - Subpart B and revisions to 40 CFR 261 were developed in response to Sections 4010(c) and 3001(d) (4) of RCRA, which were added to the statute in the 1984 Hazardous and Solid Waste Amendments. The final revisions to Part 257 - Subpart B established specific standards and reporting and recordkeeping requirements for owners and operators of new, existing, and lateral expansions of existing non-municipal non-hazardous waste disposal units that receive conditionally exempt small quantity generator (CESQG) hazardous wastes. The final revisions to Part 261 involved no new reporting or recordkeeping requirements. These regulations were finalized under the authority of Sections 1008, 2002 (general rulemaking authority), 3001(d)(4), 4004 and 4010 of RCRA, as amended. 2(b) USE AND USERS OF THE DATA The information collected is used by the States to regulate and ensure that non-municipal non-hazardous waste disposal units that receive CESQG hazardous wastes, and CESQGs, are complying with the final revisions to the Part 257 - Subpart B Criteria and the revisions to Part 261. The information collected is used by the State Director to confirm owner and operator compliance, and CESQG compliance, with the final regulations under the revised Part 257 - Subpart B and the revised Part 261. 3. THE RESPONDENTS AND THE INFORMATION REQUESTED 3(a) RESPONDENTS/SIC CODES The groups affected by the final revisions to Part 257 - Subpart B and Part 261 include both the generators of CESQG wastes and owners or operators of new, existing, or lateral expansions of existing non-municipal non-hazardous waste disposal units that receive CESQG wastes. This continuing information request covers the period from September 30, 1999 through September 30, 2002. As the rule affects generators of CESQG waste as well as the units where the waste is disposed, a relevant list of SIC codes would potentially include most business areas contained in the SIC document. Therefore, it is not practical to include such a comprehensive list in this continuing supporting statement. However, the final revision to 261.5 did not impose any new reporting or recordkeeping requirement on CESQGs; therefore, the rest of the analysis will address only new reporting and recordkeeping requirements for disposal units. 3(b) INFORMATION REQUESTED The following subsections describe the recordkeeping requirements and reporting (notification) required in the final rule. EPA deliberately did not use design standards to prescribe specific activities, conditions, or components. This allowed owners and operators maximum flexibility in developing site-specific procedures that satisfy State requirements and provisions of the revised Criteria. LOCATION RESTRICTIONS Section 257.8 - Floodplains Owners and operators of new non-municipal non-hazardous waste disposal units that receive CESQG wastes, existing non-municipal non-hazardous waste disposal units that receive CESQG wastes, and lateral expansions of existing units must document (record) in their operating record demonstrations that the unit meets the location restrictions regarding floodplains (Section 257.8). The owner or operator must notify the State Director when an exemption demonstration is recorded in the operating record. Section 257.9 - Wetlands Owners and operators of new non-municipal non-hazardous waste disposal units that receive CESQG waste and lateral expansions of existing units must demonstrate (report) to the Director of an approved State that the unit meets the requirements addressing wetlands (Section 257.9). GROUND-WATER MONITORING AND CORRECTIVE ACTION Section 257.21(b) - No Migration Petition In an approved State, owners and operators of non- municipal non-hazardous waste disposal units that receive CESQG wastes may demonstrate (document) that there is no potential for migration of hazardous constituents from the unit. The demonstration is to be based on site-specific data and fate and transport modelling as presented in Section 257.21(b)(1)-(2). Section 257.21(h) and (i) - Small and Arid or Remote Non- Municipal Non-Hazardous Waste Disposal Units Directors of approved States may allow owners and operators of new, existing, or lateral expansions of existing non-municipal non-hazardous waste disposal units that receive CESQG wastes to use alternative ground-water monitoring techniques and alternative indicator lists as presented in Section 257.21(i)(1) and (2) for units meeting the criteria defined in Section 257.21(h). The Director of the approved State should consider the factors in Section 257.21(i)(3) when authorizing and considering these alternatives. Owners and operators of these qualifying small and arid or remote non-municipal non-hazardous waste disposal units must place in their operating record documentation demonstrating that they meet the criteria in Section 257.21(h). Section 257.21(h) allows units to use the flexibility provided in Section 257.21(i) if the non-municipal non-hazardous waste disposal units receive less than 20 tons of waste per day, have no evidence of ground-water contamination, and are either in a remote area or an arid area of the country. A remote area is defined at Section 257.21(h)(3) as "a community that experiences an annual interruption of at least three consecutive months of surface transportation that prevents access to a regional waste management facility." An arid area is defined at Section 257.21(h)(4) as "an area that annually receives less than or equal to 25 inches of precipitation" and "has no practicable waste management alternative." Section 257.21(i)(2) - Small and Arid or Remote Non- Municipal Non-Hazardous Waste Disposal Units Owners and operators of new, existing, or lateral expansions of existing non-municipal non-hazardous waste disposal units that detect contamination through the use of any alternative ground-water monitoring technique must perform expanded monitoring to show the nature and extent of the contamination and submit those results to (notify) the Director of the approved State of the contamination as required by Section 257.21(i)(2). If the contamination has reached the saturated zone, then the owner or operator must comply with the requirements of Section 257.21 (i)(2)(i). If the contamination is present in the vadose zone, on the surface, or anywhere else but the saturated zone, then the owner or operator must comply with the requirements of Section 257.21(i)(2)(ii). Section 257.21 - Section 257.23 - Establish Ground-Water Monitoring Systems Owners and operators must notify the State Director that documentation pertaining to measurement, sampling, and analytical devices has been placed in the operating record. The numbering, spacing, and depth of monitoring systems shall be certified by a qualified ground-water scientist or approved by the Director of an approved State. Within 14 days of the certification, the owner or operator must notify the State Director that certification has been placed in the operating record. Owners or operators must notify the State Director that the description of the sampling and analysis program documentation has been placed in the operating record. The owner or operator must specify in the operating record a statistical method from Section 257.23(g) to be used in evaluating ground-water monitoring data for each hazardous constituent. If another statistical method that meets the performance standards of Section 257.23(h) is used, the owner or operator must place justification for this alternative in the operating record and notify the State Director of use of this alternative test. Section 257.24 - Detection Monitoring Program If the owner or operator determines that there is a statistically significant increase over background for one or more of the constituents in Appendix I (Appendix I of Part 258), the owner or operator must, within 14 days of this finding, place a notice in the operating record and notify the State Director indicating which constituents have shown statistically significant changes from the background levels. The owner or operator may demonstrate pursuant to Section 257.24(c)(3) that a source other than the non-municipal non-hazardous waste disposal unit or an error has caused the statistically significant changes in background levels of one or more of the constituents. This demonstration must be certified by a qualified ground-water scientist or approved by the Director of an approved State and be placed in the operating record. Section 257.25 - Assessment Monitoring Program If the sampling results indicate that Appendix II (Appendix II of Part 258) constituents have been detected, the owner or operator must, within 14 days after obtaining the results, place a notice in the operating record identifying the Appendix II (Appendix II of Part 258) constituents that have been detected and notify the State Director that this notice has been placed in the operating record. Within 90 days, and at least on a semiannual basis thereafter, the owner or operator must resample and record the concentrations of the detected Appendix II (Appendix II of Part 258) constituents. If the concentrations of all Appendix II (Appendix II of Part 258) constituents are shown to be at or below background values for two consecutive sampling events, the owner or operator must notify the State Director of this finding. If one or more of the Appendix II (Appendix II of Part 258) constituents are detected at statistically significant levels above the ground-water protection standard established under Section 257.25 (h) or (i) in any sampling event, the owner or operator must, within 14 days of this finding, place a notice in the operating record identifying the Appendix II (Appendix II of Part 258) constituents that have exceeded the ground-water protection standard and notify the State Director and all appropriate local government officials that the notice has been placed in the operating record. The owner or operator must also notify all persons who own the land or reside on the land that directly overlies any part of the plume of contamination if contaminants have migrated off site, if indicated by sampling wells in accordance with Section 257.25(g)(1). Section 257.25(g)(2) - "False Positives" The owner or operator may voluntarily attempt to demonstrate that a source other that the non-municipal non- hazardous waste disposal unit that may receive CESQG wastes caused the contamination or that a sampling error occurred and that it is not required to move into remedy selection under the corrective action requirements. Section 257.27 - Selection of Remedy The owner or operator must discuss the results of the corrective measure assessment, prior to the selection of remedy, in a public meeting with interested and affected parties. The owner or operator must notify the State Director, within 14 days of selecting a remedy, that a report describing the selected remedy and specifying a schedule for initiating and completing remedial activities has been placed in the operating record, and how it meets the standards in Section 257.27(b). The owner or operator may document in the operating record that no clean-up is required if the conditions of Section 257.27(e) are met and the State Director is notified. Section 257.28 - Implementation of Corrective Action Program The owner or operator may determine that corrective action cannot be achieved with any currently available remedy. If so, the owner or operator must document in the operating record that a report justifying alternative corrective action measures has been placed in the operating record in compliance with the requirements of Section 257.28 (c)(4) and notify the State Director. Upon completion of the requirements of Section 257.28(e), the owner or operator must document in the operating record that the remedy has been completed in compliance with the requirements of Section 257.28(e) and notify the State Director. RECORDKEEPING REQUIREMENT Section 257.30 - Recordkeeping Requirements The owner and operator must record and retain near the unit in an operating record, information as it becomes available on any location restriction demonstration required under Sections 257.7 through 257.12 or any demonstration, certification, finding, monitoring, testing, or analytical data required in Sections 257.21 through 257.28. The owner and operator must notify the State Director when the information has been placed in the operating record or alternative location as approved by the Director of an approved State. The Director of approved State can set alternative schedules for the recordkeeping and notification requirements specified under Section 257.30, except for the notification requirement in Section 257.25(g)(1)(iii). 4. THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT The following subsections discuss how the information will be collected. State agencies will not be responsible for collecting information. Rather, the owners or operators of non-municipal non-hazardous waste disposal units that receive CESQG wastes are required to collect the information, compile it in an operating record, and notify the State Director when the documentation is placed in the operating record. The operating record is intended to be equivalent to a permit file that is routinely kept by the State permitting agency. The Agency did not intend for the final rule to create additional recordkeeping except when the rule imposed more stringent Federal standards in addition to State requirements. 4(a) AGENCY ACTIVITIES This program is implemented by approved States and all information will be reported to the States or kept in an operating record; in unapproved States, the "Criteria for Classification of Solid Waste Disposal Facilities and Practices" (40 CFR Part 257) are self implementing, meaning that the owner/operator documents compliance with the Criteria and places the documentation in the operating record. EPA will not collect information from individual non-municipal non-hazardous waste disposal units. EPA does have enforcement authority in States where EPA has made a formal determination that the State permit program is not adequate. In enforcement situations, EPA may request information from the owner or operator. 4(b) COLLECTION METHODOLOGY AND MANAGEMENT EPA has not specified how these records are to be developed and maintained. This ensures the maximum flexibility and minimum burden in meeting the final requirements. 4(c) SMALL ENTITY FLEXIBILITY Respondents may include small businesses; all data requested are essential for both large and small businesses. The information burden was minimized to the extent possible for all potential respondents through the final rule's self- implementing format. 4(d) COLLECTION SCHEDULE All collection requirements discussed in this ICR are for the period of time starting September 30,1999 until September 30, 2002. The final Part 257 - Subpart B language established a schedule for the establishment of a ground-water monitoring program. Owners and operators of existing non-municipal non- hazardous waste disposal units that receive CESQG waste and lateral expansions of existing units were to comply with the ground-water requirements of Sections 257.22 - 257.25 according to the schedule established in the regulations unless an alternative schedule was specified by the Director of an approved State under Section 257.21(d): 1. Existing non-municipal non-hazardous waste disposal units that received CESQG wastes and lateral expansions of existing units were to be in compliance by July 1, 1998. 2. New non-municipal non-hazardous waste disposal units were to be in compliance before waste was placed in the unit. 3. Under Section 257.21(d), the Director of an approved State could specify an alternative schedule for owners and operators of existing units and lateral expansions of existing units to comply with the ground-water requirements specified in Sections 257.22 - 257.25. The alternative schedule was to ensure that 50 percent of all existing units were in compliance by July 1, 1998 and all existing units were in compliance by July 1, 1999. Once established at a unit, ground-water monitoring is to be conducted throughout the active life of the unit plus 30 years. The Director of an approved State may decrease the 30-year period if the owner/operator demonstrates that a shorter period of time is adequate to protect human health and the environment and the Director approves that demonstration. The records and reports are to be maintained on an ongoing basis in the unit operating record; however, the Part 257 - Subpart B Criteria allow approved States the discretion to establish alternative schedules for recordkeeping and notification requirements. 5. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA 5(a) NONDUPLICATION EPA took steps to minimize duplication of information collection. The Part 257 - Subpart B final rule included minimum recordkeeping and reporting necessary to document compliance with the rule's provisions. EPA deliberately did not prescribe specific recordkeeping procedures or formats. This would allow States and owners or operators maximum flexibility in developing site-specific procedures that satisfy existing State requirements and the provisions of the Criteria for Classification of Solid Waste Disposal Facilities and Practices. Furthermore, Part 257 - Subpart B provides additional flexibility to approved States: approved States have flexibility in establishing the location of the operating record and establishing alternative schedules for recordkeeping and notification requirements. 5(b) CONSULTATIONS This continuing ICR is based on the data collected for the original and the revised ICR for Part 258 (municipal landfills - ICR #1381). The Part 258 ICR developed estimates in consultation with owners and operators of MSWLFs, State personnel, EPA personnel (Headquarters and Regional), and consultants working for EPA on the hazardous and solid waste programs. Individuals from these organizations were interviewed to characterize the time an owner or operator (as well as the State) would need to spend on each separate requirement. Since the minimum statutory requirements finalized in Part 257 - Subpart B are almost identical to the corresponding sections of Part 258, the Agency has prepared similar time estimates for the activities required under Part 257 - Subpart B, making reasonable alterations and allowances to correspond with those sections where the requirements differ. 5(c) EFFECT OF LESS FREQUENT COLLECTION The Agency believes that less frequent recordkeeping and reporting could hamper State enforcement and compliance efforts, especially in States that have not been approved, since these States may not establish requirements more stringent than the Federal minimum. However, the Part 257 - Subpart B Criteria allow approved States the discretion to establish alternative schedules for recordkeeping and notification requirements. 5(d) GENERAL GUIDELINES This collection does not violate any of the Paperwork Reduction Act (50 CFR 1320.6) general guidelines. 5(e)(f) CONFIDENTIALITY AND SENSITIVE QUESTIONS No data requested are believed to be confidential. The Agency is not requesting any trade secret information and believes that the information collection complies with the Privacy Act of 1974 and OMB Circular A-108. The recordkeeping and reporting requirements do not request information that is of a sensitive nature. 6. ESTIMATING THE BURDEN HOURS AND COST OF THE COLLECTION 6(a) ESTIMATING THE RESPONDENT BURDEN HOURS - Original ICR The total universe of non-municipal non-hazardous waste disposal units that may receive CESQG waste includes two types of units: (1) units where CESQG waste is co-disposed with industrial waste on site; and (2) Subtitle D units receiving CESQG waste from off site (including construction and demolition waste disposal units and commercial industrial solid waste disposal units). EPA originally assumed, and continues to assume, that units that co-disposed industrial non-hazardous waste and CESQG waste on site have ceased that practice to avoid the cost of compliance with Part 257 - Subpart B. The commercial (off-site) industrial waste disposal units currently operating are subject to stringent environmental controls, imposed by States and corporate policy, therefore, EPA continues to believe, that these off-site units will incur a negligible burden from the revisions to Part 257 - Subpart B. Therefore, the primary type of unit that continues to be affected by the Part 257 - Subpart B rule is construction and demolition waste disposal units. Consequently, the only units that will incur burdens under the Part 257 - Subpart B rule continue to be construction and demolition landfills that receive CESQG waste from off site generators. EPA currently estimates that there are approximately 1,300 construction and demolition landfills in the United States as of 1997 as reported in the April 1998 issue of BioCycle (down from the original estimate of 1900). Construction and demolition waste landfills that were not in compliance with the Part 257 - Subpart B revisions in 1996 would have responded to the regulation in one of two ways: (1) elected not to upgrade and decided to accept only construction and demolition waste that does not contain CESQG hazardous waste (these units would not be affected by the recordkeeping or reporting requirements of Part 257 - Subpart B; or (2) upgraded and accepted CESQG waste (become subject to the recordkeeping and reporting requirements of the revisions to Part 257 - Subpart B). The Agency's Regulatory Impact Analysis (RIA) (June 1996) for the final Part 257 - subpart B rule, indicated that 162 construction and demolition waste landfills in 18 affected States would have elected to upgrade and thus become subject to the reporting and recordkeeping requirements of Part 257 - Subpart B. The RIA also accounted for the number of small/dry/remote non-municipal units that would have opted to use alternative ground-water monitoring techniques. As a result of this added flexibility, EPA believed that more units would have opted to upgrade. For the purpose of the original ICR, EPA assumed that 50% of the construction and demolition units that were eligible to use alternative ground-water monitoring techniques would have chosen to upgrade. This included half of the 21 landfills in Alaska (remote) and half of the 109 small landfills that were located in affected States with low precipitation. Overall, EPA estimated that 65 additional landfills would upgrade and use alternative ground-water monitoring techniques. Additional, EPA assumed that none of these 65 additional landfills would require expanded ground-water monitoring as discussed in the original ICR. Thus, the total number of upgrades of existing units was estimated to be 227. In the original ICR, 227 existing facilities were used to calculate burdens. In addition, EPA projected, in the original ICR, that 11 new and lateral expansions of existing units will be activated per year as construction and demolition waste units accepting CESQG waste became subject to this final rule. 6(b) ESTIMATING THE RESPONDENT BURDEN HOURS - Continuing ICR For this continuing ICR, EPA has developed new recordkeeping and reporting burden estimates. EPA has revised its original estimate (162) of the number of construction and demolition waste landfills in the 18 affected States that would have elected to upgrade. EPA has revised the original estimate down from 162 landfills to 146. This reduction is based on a decrease in the overall number of construction and demolition waste landfills that exist in the original 18 affected States. This reduction equates to a 10% reduction in the number of construction and demolition landfills that would continue to have annual reporting and recordkeeping burdens during the period of time from September 30, 1999 until September 30, 2002. This same 10% reduction has been used to reduce the number of existing construction and demolition waste landfills that continue to be subject to the reporting and recordkeeping burdens associated with corrective action (23 facilities in the original ICR vs. 21 in this continuing ICR). Small/arid/remote construction and demolition facilities incurred reporting and recordkeeping burdens in the original ICR, but, this continuing ICR does not contain any burdens because small/arid/remote construction and demolition wastes facilities incurred only one-time burdens during the time period between September 30, 1996 and September 30, 1999. The Agencyþs original assumption that none of the existing small/arid/remote facilities would need to undergo expanded ground-water monitoring and corrective action continues to be assumed in this ICR for the reasons discussed in the original ICR. In this continuing ICR, one-time reporting and recordkeeping burden hours for existing construction and demolition waste facilities have also been reduced because these one-time burdens occurred during the period of time between September 30, 1996 and September 30, 1999. These one-time burdens are associated with the floodplain provision, the small/arid/remote demonstration, and the establishment of the ground-water monitoring system. For this continuing ICR, like the original ICR, the Agency assumed 11 new and lateral expansions of existing units will be activated per year as construction and demolition waste units accepting CESQG waste become subject to the Part 257 - Subpart B rule. LOCATION RESTRICTIONS Section 257.8 - Floodplains No existing facilities incur any one-time or annual burdens in this continuing ICR. For the 11 new non-municipal non-hazardous waste disposal units that may receive CESQG waste and lateral expansions of existing units that are affected by this requirement, approximately 20% are expected to be within a 100-year floodplain. EPA has estimated a one-time recordkeeping requirement for this location restriction of 10 hours per unit. There is a one-time reporting burden of two hours per unit. Section 257.9 - Wetlands The requirement for the wetlands location restriction comes from the Clean Water Act (CWA) and incorporates EPA guidelines developed pursuant to the CWA. Any recordkeeping requirement is attributable to implementing the CWA and not the Criteria for Classification of Solid Waste Disposal Facilities and Practices. Therefore, in order to avoid double counting, no recordkeeping requirements for this location provision are included in this estimate. The reporting and recordkeeping requirements are reported under OMB Control Number 2040-0086. Section 257.13 - Deadline for Making Demonstrations This section does not include any recordkeeping or reporting requirements. GROUND-WATER MONITORING AND CORRECTIVE ACTION Section 257.21(b) - No Migration Petition Owners and operators of non-municipal non-hazardous waste disposal units that may receive CESQG wastes may demonstrate (document) that there is no potential for migration of hazardous constituents from the unit. The demonstration is to be based on site-specific data and fate and transport modelling. EPA estimates that no more than 1 owner/operator out of the 11 new facilities will attempt this demonstration. EPA assumes that the required documentation would result in a one-time reporting requirement of 100 hours per unit. Section 257.21(b) does not contain recordkeeping requirements; however, the one- time recordkeeping requirements of two hours per unit that are contained in Section 257.23 have been included for simplicity. Section 257.21(h) and (i) - Small and Arid or Remote Non- municipal Non-hazardous Waste Disposal Units One-time burden hours are incurred under this provision for 3 of the 11 new small/arid/remote facilities that are eligible to use alternative ground-water monitoring and choose to upgrade. The Agency assumes that 3 of the total 11 new units will be located in small/arid/remote locations. The requirement is for owners and operators of these small/arid/remote non-municipal non-hazardous waste disposal units to make the determination that they meet the criteria in Section 257.21(h). There is a one-time recordkeeping burden of 10 hours per unit and a one-time reporting burden of two hours per unit. Section 257.21(i)(2) - Small and Arid or Remote Non- municipal Non-hazardous waste disposal Units EPA has assumed that none of the 3 new or lateral expansions of existing non-municipal non-hazardous waste disposal units that are eligible to use alternative ground- water monitoring techniques and choose to upgrade will detect contamination requiring expanded ground-water monitoring. First, because these disposal units are small and located in dry or generally frozen climates, they are less likely to have contamination. Moreover, the economics are such that upgrading will be cost-effective for the small units only if expanded monitoring will not be necessary. Therefore, EPA assumes that none of these units will have to incur the reporting or recordkeeping requirements associated with expanded ground-water monitoring. Section 257.21 - Section 257.23 - Establish Ground-Water Monitoring Systems EPA estimates 8 new or lateral expansions of existing construction and demolition landfills will choose to upgrade and will not be eligible to use alternative ground-water monitoring techniques. The Agency assumes the one-time reporting requirement of 20 hours per unit would result for these 8 new or lateral expansions of existing units. There are one-time recordkeeping requirements at Sections 257.22(d)(2), 257.23(a), and 257.23(g). Each of these three sections has a two-hour per unit recordkeeping requirement for a total of six hours per unit. Section 257.24 - Detection Monitoring Program EPA estimates the total annual reporting burden for detection monitoring to be 32 hours per year for the 146 existing units and the 8 new or lateral expansions of existing units per year. The annual recordkeeping requirement burden is two hours for each unit. This burden does not apply to existing, new or lateral expansions of existing units meeting the criteria for small units located in remote or arid regions as defined in Section 257.21(h). Section 257.25 - Assessment Monitoring Program EPA assumes that only existing units may need to establish an assessment monitoring program within the time frame covered by this ICR. None of the new units are expected to require assessment monitoring prior to September 30, 2002. For assessment monitoring, EPA estimates that this rule would impose a annual reporting burden of 32 hours per occurrence per year. EPA assumes that 21 units are included in the recordkeeping estimate. This estimate includes the units that voluntarily chose to make the "false positives" demonstration at Section 257.25(g)(2). There is an annual recordkeeping requirement of two hours for each unit. Section 257.25(g)(2) - "False Positives" See the discussion for Section 257.25 - Assessment Monitoring Program. Section 257.27 - Selection of Remedy For corrective action, EPA estimated an annual reporting burden of 200 hours per year to document progress in clean-up activities. The Agency assumes 21 units are included in the recordkeeping estimate and would have increased burdens. The estimated reporting burden includes consideration of Section 257.27(d), the requirement to establish a schedule for implementing and completing remedial measures. The estimated burden also includes consideration of Section 257.27(e), the conditions that would allow no ground-water clean-up. If the owner or operator determines that compliance with Section 257.27(b) cannot be practically achieved, then the owner or operator must comply with the requirements of Section 257.28(c)(4). There are annual recordkeeping burdens at Sections 257.27(b), 257.28(c)(4) and 257.28(e)(2). Each of these annual recordkeeping burdens requires two hours per unit, for a total of six hours. Section 257.28 - Implementation of Corrective Action Program EPA assumes that no owner or operator will have completed corrective action and, therefore, be required to comply with Section 257.28(f) prior to September 30, 2002. Section 257.28(e) requires 3 consecutive years of data to demonstrate compliance with the ground-water protection standard. Assuming existing facilities entered into assessment monitoring in 1999, it is highly unlikely that any existing facility would have burdens associated with Section 257.28. This section, therefore, contains no reporting requirements. RECORDKEEPING REQUIREMENT Section 257.30 - Recordkeeping Requirements EPA estimates that the recordkeeping requirement at Section 257.30 to place notifications in the operating record will impose a one-time recordkeeping burden of 10 hours on 1 new or lateral expansion of an existing unit per year. 6(c) ESTIMATING RESPONDENT BURDEN HOURS AND COSTS For a summary of the estimated respondent annual and one-time recordkeeping and reporting requirements burdens and costs, see Exhibits 4 through 7. For the purpose of preparing cost and burden estimates for this continuing ICR, EPA used the estimates prepared in the original ICR and ICRs for similar programs that have been approved by OMB. The primary ICR used as a guideline was the ICR for Part 258, which contains similar reporting and recordkeeping requirements. Additional ICRs reviewed included the Underground Storage Tanks (UST) program (Subtitle I) and the Subtitle C program. Costs for respondents were estimated based on the wage rates presented in Exhibit 1. EXHIBIT 1 ***************************************************** Estimated Respondent Wage Rates ===================================================== Legal $ 86.00 ----------------------------------------------------- Managerial $ 65.00 ----------------------------------------------------- Technical $ 43.00 ----------------------------------------------------- Clerical $ 22.00 ***************************************************** 6(d) ESTIMATING AGENCY BURDEN HOURS AND COST All information is submitted to the States; therefore, Agency burden and cost are negligible. The State burden for recordkeeping will be for processing notifications sent by the owners or operators of units that elect to continue receiving CESQG wastes, review of the unit demonstrations, and certification of requirements. States will be notified as specified previously under 3(b). Exhibit 2 presents the wage rates used to estimate the cost to the Agency and States. EXHIBIT 2 ***************************************************** Estimated Agency/State Wage Rates ===================================================== Legal $ 56.00 ----------------------------------------------------- Managerial $ 36.00 ----------------------------------------------------- Technical $ 25.00 ---------------------------------------------------- Clerical $ 15.00 ***************************************************** 6(e) ESTIMATING STATE BURDEN HOURS AND COST The annual and one-time recordkeeping and reporting burden for State agencies is summarized in Exhibit 3 below. Based on the information in the recently revised ICR for Part 258 (ICR #1381), the total estimated recordkeeping and reporting burden for clerical staff is 2.5 hours per notification and the total estimated burden for technical staff is one hour per notification. For both recordkeeping and reporting estimates, the Agency assumes that neither the legal nor the managerial staff will be responsible for any additional burden or cost. EXHIBIT 3 Estimated State Recordkeeping/Reporting Burden and Cost ************************************************************ No. Legal Manager Technical Clerical Total Total of $56.00 $36.00 $25.00 $15.00 Hours Cost $ Notifi- Per Per cations Year Year ============================================================ LOCATION RESTRICTIONS ------------------------------------------------------------ Annual 0 0 0 1 2.5 0.0 0 ------------------------------------------------------------ One-Time 2 0 0 1 2.5 7.0 125 ============================================================ GROUND-WATER MONITORING AND CORRECTIVE ACTION ------------------------------------------------------------ Annual 196 0 0 1 2.5 686.0 12,250 ------------------------------------------------------------ One-Time 12 0 0 1 2.5 42.0 750 ************************************************************ 6(f) BOTTOM LINE BURDEN HOURS AND COST/MASTER TABLES Exhibits 4 and 6 present the estimated annual respondent burden hours and cost for reporting and recordkeeping requirements. The total annual burden for respondents is 10,276 hours and the estimated cost is $381,178. Exhibits 5 and 7 present the estimated one-time respondent burden hours and cost for reporting and recordkeeping requirements. The total one-time burden for respondents is 380 hours and the estimated cost is $16,982. Exhibit 8 presents a summary of the total burden hours and cost incurred by both the States and owners and operators as a result of this final rule. The total annual burden for reporting and recordkeeping requirements is 10,962 hours and the estimated cost is $393,428. The total one-time burden for reporting and recordkeeping requirements is 429 hours and the estimated cost is $17,857. 6(g) REASONS FOR CHANGE IN BURDEN This is a continuing ICR. Primary reasons for changes in the burden are the reduction in the number of existing facilities that has occurred and the elimination of one-time reporting and recordkeeping burdens that were previously incurred during the period of time from September 30, 1996 until September 30, 1999. 6(h) BURDEN STATEMENT The annual public reporting and recordkeeping burden for this collection of information per is estimated to average 66.84 hours respondent. 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 bases; complete and review the collection of information; and transmit or otherwise disclose 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. A record has been established for this action under docket number F-1999-DFIP-FFFFF. A public version of this record, included printed, paper versions of electronic comments, which does not include any information claimed as CBI, is available for inspection from 8:00 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The public record is located in the RCRA Information Center (RIC), located at Crystal Gateway I, first Floor, 1235 Jefferson Davis Highway, Arlington, VA. EXHIBIT 4 ESTIMATED ANNUAL RESPONDENT RECORDKEEPING BURDEN AND COST ************************************************************ REQUIREMENT NUMBER OF RESPONDENTS - ACTIVITY EXISTING NEW ============================================================ Floodplains - 257.8 0 0 ------------------------------------------------------------ Wetlands - 257.9 0 0 ------------------------------------------------------------ No Migration Petition 257.21(b) 0 0 ------------------------------------------------------------ Small and Remote Facilities - 257.21(h) 0 0 ------------------------------------------------------------ Small and Remote Facilities - 257.21(i) 0 0 ------------------------------------------------------------ Establish GWM System - 257.23 0 0 ------------------------------------------------------------ Detection Monitoring Program - 257.24 146 8 ------------------------------------------------------------ Assessment Monitoring Program - 257.25 21 0 ------------------------------------------------------------ Selection of Remedy 257.27 21 0 ------------------------------------------------------------ Recordkeeping Requirements - 257.30 0 0 ------------------------------------------------------------ TOTAL ANNUAL RECORDKEEPING BURDEN AND COST 188 8 ============================================================ HOURS PER RESPONDENT - ACTIVITY LEGAL MANAGER TECHNICAL CLERICAL $86/HR $65/HR $43/HR $22/HR ============================================================ Floodplains - 257.8 0 0 0 0 ------------------------------------------------------------ Wetlands - 257.9 0 0 0 0 ------------------------------------------------------------ No Migration Petition 257.21(b) 0 0 0 0 ------------------------------------------------------------ Small and Remote Facilities - 257.21(h) 0 0 0 0 ------------------------------------------------------------ Small and Remote Facilities - 257.21(i) 0 0 0 0 ------------------------------------------------------------ Establish GWM System - 257.23 0 0 0 0 ------------------------------------------------------------ Detection Monitoring Program - 257.24 0 0 1 1 ------------------------------------------------------------ Assessment Monitoring Program - 257.25 0 0 1 1 ------------------------------------------------------------ Selection of Remedy 257.27 0 0 3 3 ------------------------------------------------------------ Recordkeeping Requirements - 257.30 0 0 0 0 ============================================================ TOTAL HOURS PER YEAR TOTAL COST PER YEAR ============================================================ Floodplains - 257.8 0 0 ------------------------------------------------------------ Wetlands - 257.9 0 0 ------------------------------------------------------------ No Migration Petition 257.21(b) 0 0 ------------------------------------------------------------ Small and Remote Facilities - 257.21(h) 0 0 ------------------------------------------------------------ Small and Remote Facilities - 257.21(i) 0 0 ------------------------------------------------------------ Establish GWM System - 257.23 0 0 ------------------------------------------------------------ Detection Monitoring Program - 257.24 308 10,010 ------------------------------------------------------------ Assessment Monitoring Program - 257.25 42 1,365 ------------------------------------------------------------ Selection of Remedy 257.27 126 4,095 ------------------------------------------------------------ Recordkeeping Requirements - 257.30 0 0 ------------------------------------------------------------ TOTAL ANNUAL RECORDKEEPING BURDEN AND COST 476 15,470 ************************************************************ EXHIBIT 5 ESTIMATED ONE-TIME RESPONDENT RECORDKEEPING BURDEN AND COST REQUIREMENT NUMBER OF RESPONDENTS - ACTIVITY EXISTING NEW ============================================================ Floodplains - 257.8 0 0 ------------------------------------------------------------ Wetlands - 257.9 0 0 ------------------------------------------------------------ No Migration Petition 257.21(b) 0 1 ------------------------------------------------------------ Small and Remote Facilities - 257.21(h) 0 3 ------------------------------------------------------------ Small and Remote Facilities - 257.21(i) 0 0 ------------------------------------------------------------ Establish GWM System - 257.23 0 8 ------------------------------------------------------------ Detection Monitoring Program - 257.24 0 0 ------------------------------------------------------------ Assessment Monitoring Program - 257.25 0 0 ------------------------------------------------------------ Selection of Remedy 257.27 0 0 ------------------------------------------------------------ Recordkeeping Requirements - 257.30 0 1 ------------------------------------------------------------ TOTAL ANNUAL RECORDKEEPING BURDEN AND COST 0 15 ============================================================ HOURS PER RESPONDENT - ACTIVITY LEGAL MANAGER TECHNICAL CLERICAL $86/HR $65/HR $43/HR $22/HR ============================================================ Floodplains - 257.8 0 2 4 4 ------------------------------------------------------------ Wetlands - 257.9 0 0 0 0 ------------------------------------------------------------ No Migration Petition 257.21(b) 0 0 1 1 ------------------------------------------------------------ Small and Remote Facilities - 257.21(h) 0 2 3 5 ------------------------------------------------------------ Small and Remote Facilities - 257.21(i) 0 0 0 0 ------------------------------------------------------------ Establish GWM System - 257.23 0 0 3 3 ------------------------------------------------------------ Detection Monitoring Program - 257.24 0 0 0 0 ------------------------------------------------------------ Assessment Monitoring Program - 257.25 0 0 1 1 ------------------------------------------------------------ Selection of Remedy 257.27 0 0 0 0 ------------------------------------------------------------ Recordkeeping Requirements - 257.30 0 2 4 4 ============================================================ TOTAL HOURS PER YEAR TOTAL COST PER YEAR ============================================================ Floodplains - 257.8 20 780 ------------------------------------------------------------ Wetlands - 257.9 0 0 ------------------------------------------------------------ No Migration Petition 257.21(b) 2 65 ------------------------------------------------------------ Small and Remote Facilities - 257.21(h) 30 1,107 ------------------------------------------------------------ Small and Remote Facilities - 257.21(i) 0 0 ------------------------------------------------------------ Establish GWM System - 257.23 48 1,560 ------------------------------------------------------------ Detection Monitoring Program - 257.24 0 0 ------------------------------------------------------------ Assessment Monitoring Program - 257.25 0 0 ------------------------------------------------------------ Selection of Remedy 257.27 0 0 ------------------------------------------------------------ Recordkeeping Requirements - 257.30 10 390 ------------------------------------------------------------ TOTAL ANNUAL RECORDKEEPING BURDEN AND COST 110 3,902 ************************************************************ Exhibit 6 ESTIMATED ANNUAL RESPONDENT RECORDKEEPING BURDEN AND COST REQUIREMENT NUMBER OF RESPONDENTS - ACTIVITY EXISTING NEW ============================================================ Floodplains - 257.8 0 0 ------------------------------------------------------------ Wetlands - 257.9 0 0 ------------------------------------------------------------ No Migration Petition 257.21(b) 0 0 ------------------------------------------------------------ Small and Remote Facilities - 257.21(h) 0 0 ------------------------------------------------------------ Small and Remote Facilities - 257.21(i) 0 0 ------------------------------------------------------------ Establish GWM System - 257.23 0 0 ------------------------------------------------------------ Detection Monitoring Program - 257.24 146 8 ------------------------------------------------------------ Assessment Monitoring Program - 257.25 21 0 ------------------------------------------------------------ Selection of Remedy 257.27 21 0 ------------------------------------------------------------ Recordkeeping Requirements - 257.30 0 0 ------------------------------------------------------------ TOTAL ANNUAL RECORDKEEPING BURDEN AND COST 188 8 ============================================================ HOURS PER RESPONDENT - ACTIVITY LEGAL MANAGER TECHNICAL CLERICAL $86/HR $65/HR $43/HR $22/HR ============================================================ Floodplains - 257.8 0 0 0 0 ------------------------------------------------------------ Wetlands - 257.9 0 0 0 0 ------------------------------------------------------------ No Migration Petition 257.21(b) 0 0 0 0 ------------------------------------------------------------ Small and Remote Facilities - 257.21(h) 0 0 0 0 ------------------------------------------------------------ Small and Remote Facilities - 257.21(i) 0 0 0 0 ------------------------------------------------------------ Establish GWM System - 257.23 0 0 0 0 ------------------------------------------------------------ Detection Monitoring Program - 257.24 0 6 12 14 ------------------------------------------------------------ Assessment Monitoring Program - 257.25 2 6 12 12 ------------------------------------------------------------ Selection of Remedy 257.27 10 30 40 120 ------------------------------------------------------------ Recordkeeping Requirements - 257.30 0 0 0 0 ============================================================ TOTAL HOURS PER YEAR TOTAL COST PER YEAR ============================================================ Floodplains - 257.8 0 0 ------------------------------------------------------------ Wetlands - 257.9 0 0 ------------------------------------------------------------ No Migration Petition 257.21(b) 0 0 ------------------------------------------------------------ Small and Remote Facilities - 257.21(h) 0 0 ------------------------------------------------------------ Small and Remote Facilities - 257.21(i) 0 0 ------------------------------------------------------------ Establish GWM System - 257.23 0 0 ------------------------------------------------------------ Detection Monitoring Program - 257.24 4,928 186,956 ------------------------------------------------------------ Assessment Monitoring Program - 257.25 672 28,182 ------------------------------------------------------------ Selection of Remedy 257.27 4,200 150,570 ------------------------------------------------------------ Recordkeeping Requirements - 257.30 0 0 ------------------------------------------------------------ TOTAL ANNUAL RECORDKEEPING BURDEN AND COST 9,800 365,708 ************************************************************ EXHIBIT 7 ESTIMATED ONE-TIME RESPONDENT REPORTING BURDEN AND COST REQUIREMENT NUMBER OF RESPONDENTS - ACTIVITY EXISTING NEW ============================================================ Floodplains - 257.8 0 2 ------------------------------------------------------------ Wetlands - 257.9 0 0 ------------------------------------------------------------ No Migration Petition 257.21(b) 0 1 ------------------------------------------------------------ Small and Remote Facilities - 257.21(h) 0 3 ------------------------------------------------------------ Small and Remote Facilities - 257.21(i) 0 0 ------------------------------------------------------------ Establish GWM System - 257.23 0 8 ------------------------------------------------------------ Detection Monitoring Program - 257.24 0 0 ------------------------------------------------------------ Assessment Monitoring Program - 257.25 0 0 ------------------------------------------------------------ Selection of Remedy 257.27 0 0 ------------------------------------------------------------ Recordkeeping Requirements - 257.30 0 0 ------------------------------------------------------------ TOTAL ANNUAL RECORDKEEPING BURDEN AND COST 0 14 ============================================================ HOURS PER RESPONDENT - ACTIVITY LEGAL MANAGER TECHNICAL CLERICAL $86/HR $65/HR $43/HR $22/HR ============================================================ Floodplains - 257.8 0 0 1 1 ------------------------------------------------------------ Wetlands - 257.9 0 0 0 0 ------------------------------------------------------------ No Migration Petition 257.21(b) 5 20 60 15 ------------------------------------------------------------ Small and Remote Facilities - 257.21(h) 0 0 1 1 ------------------------------------------------------------ Small and Remote Facilities - 257.21(i) 0 0 0 0 ------------------------------------------------------------ Establish GWM System - 257.23 2 5 11 2 ------------------------------------------------------------ Detection Monitoring Program - 257.24 0 0 0 0 ------------------------------------------------------------ Assessment Monitoring Program - 257.25 0 0 0 0 ------------------------------------------------------------ Selection of Remedy 257.27 0 0 0 0 ------------------------------------------------------------ Recordkeeping Requirements - 257.30 0 0 0 0 ============================================================ TOTAL HOURS PER YEAR TOTAL COST PER YEAR ============================================================ Floodplains - 257.8 4 130 ------------------------------------------------------------ Wetlands - 257.9 0 0 ------------------------------------------------------------ No Migration Petition 257.21(b) 100 4,640 ------------------------------------------------------------ Small and Remote Facilities - 257.21(h) 6 198 ------------------------------------------------------------ Small and Remote Facilities - 257.21(i) 0 0 ------------------------------------------------------------ Establish GWM System - 257.23 160 8.112 ------------------------------------------------------------ Detection Monitoring Program - 257.24 0 0 ------------------------------------------------------------ Assessment Monitoring Program - 257.25 0 0 ------------------------------------------------------------ Selection of Remedy 257.27 0 0 ------------------------------------------------------------ Recordkeeping Requirements - 257.30 0 0 ------------------------------------------------------------ TOTAL ANNUAL RECORDKEEPING BURDEN AND COST 270 13,080 ************************************************************ EXHIBIT 8 TOTAL ESTIMATED ANNUAL AND ONE-TIME BURDEN HOURS AND COSTS ************************************************************ ANNUAL BURDEN ONE-TIME BURDEN ======================================= Hours Costs Hours Costs ======================================= State Reporting and Recordkeeping Burden 686 $12,250 49 $875 ------------------------------------------------------------ Respondent Reporting and Recordkeeping Burden 10,276 $381,178 380 $16,982 ------------------------------------------------------------ TOTAL ESTIMATED BURDEN 10,962 $393,428 429 $17,857 ************************************************************