STATEMENT
SUPPORTING
THE
FINAL
RULE
ON
DISTRIBUTION
OF
OFFSITE
CONSEQUENCE
ANALYSIS
INFORMATION
UNDER
SECTION
112(
r)(
7)(
H)
OF
THE
CLEAN
AIR
ACT
EPA
#
1981.01
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
of
the
Information
Collection
Request
Distribution
of
offsite
consequence
analysis
information
under
section
112(
r)(
7)(
H)
of
the
Clean
Air
Act
(
CAA),
as
amended
B
EPA
No.
1981.01
The
ICR
for
the
proposed
rule
was
listed
as
ICR
1656.08.
To
avoid
confusion
with
the
ICR
for
the
full
RMP
program
(
i.
e.,
Risk
Management
Program
Requirements
and
Petitions
to
Modify
the
List
of
Regulated
Substances
under
Section
112(
r)
of
the
Clean
Air
Act),
the
ICR
number
has
been
changed
for
the
final
rule.

1(
b)
Short
Characterization
This
information
collection
request
(
ICR)
supports
the
final
rule,
Accidental
Release
Prevention
Requirements;
Risk
Management
Programs
Under
the
Clean
Air
Act
Section
112(
r)(
7);
Distribution
of
Off­
Site
Consequence
Analysis
Information,
under
CAA
section
112(
r)
as
amended
by
the
Chemical
Safety
Information,
Site
Security,
and
Fuels
Regulatory
Relief
Act
(
P.
L.
106­
40).
CAA
section
112(
r)(
7)
required
EPA
to
promulgate
reasonable
regulations
and
appropriate
guidance
to
provide
for
the
prevention
and
detection
of
accidental
releases
and
for
responses
to
such
releases.
The
regulations
include
requirements
for
submittal
of
a
risk
management
plan
(
RMP)
to
EPA.
The
RMP
includes
information
on
offsite
consequence
analyses
(
OCA)
as
well
as
other
elements
of
the
risk
management
program.
EPA
has
made
all
RMP
data
except
the
OCA
information
available
to
the
public
on
the
Internet
through
a
system
called
RMP*
Info.

On
August
5,
1999,
the
President
signed
the
Chemical
Safety
Information,
Site
Security,
and
Fuels
Regulatory
Relief
Act
(
CSISSFRRA).
This
Act
requires
the
President
to
promulgate
regulations
on
the
distribution
of
OCA
information
(
CAA
section
112(
r)(
7)(
H)(
ii)).
The
President
delegated
to
EPA
and
the
Department
of
Justice
(
DOJ)
the
responsibility
to
promulgate
regulations
to
govern
the
dissemination
of
OCA
information
to
the
public.

The
final
rule
will
impose
minimal
information
collection
requirements
and
record
keeping.
The
federal
government
would
ensure
that
reading
rooms
are
established
at
federal
facilities
geographically
distributed
across
the
United
States
and
its
territories.
At
these
reading
rooms,
members
of
the
public
will
be
able
to
read,
but
not
mechanically
copy
or
remove
paper
copies
of
OCA
information
for
up
to
10
stationary
sources
per
calendar
month.
Any
person
will
also
receive
access
at
a
federal
reading
room
to
OCA
information
that
the
Local
Emergency
Planning
Committee
(
LEPC)
in
which
he
or
she
lives
or
works
is
authorized
to
provide.

At
some
reading
rooms,
access
will
be
available
on
a
walk­
in
basis,
because
the
OCA
data
will
be
maintained
at
the
reading
room.
At
other
reading
rooms,
however,
the
OCA
data
will
not
be
maintained
2
on­
site,
and
therefore
a
person
wishing
to
view
OCA
data
at
those
reading
rooms
will
contact
a
central
office
at
a
toll­
free
number
at
least
three
days
prior
to
the
date
on
which
the
person
will
like
to
view
the
OCA
data
at
the
reading
room.
During
the
toll­
free
call,
the
requestor
will
be
asked
to
provide
his
or
her
name,
telephone
number,
and
the
names
of
the
facilities
for
which
OCA
information
is
being
requested.
At
the
reading
rooms,
the
requestor
will
need
to
display
photo
identification
issued
by
a
federal,
state,
or
local
government
agency,
sign
a
sign­
in­
sheet,
and
certify
that
the
individual
has
not
received
access
to
OCA
information
for
more
than
10
stationary
sources
for
that
calendar
month.
Persons
requesting
access
to
local
facilities
OCA
information
will
also
be
asked
to
sign­
in
and
to
display
documentation
demonstrating
that
he
or
she
lives
or
works
in
the
LEPC
jurisdiction
for
which
the
OCA
information
has
been
requested.
Requestors
will
be
limited
to
access
to
paper
copies
of
OCA
information
for
a
total
of
10
facilities
during
a
calendar
month,
regardless
of
how
many
reading
rooms
they
visit
during
a
single
month.

EPA
will
also
establish
an
indicator,
Vulnerable
Zone
Indicator
System
(
VZIS),
that
will
inform
any
person
located
in
any
state
whether
an
address
specified
by
that
person
might
be
within
the
vulnerable
zone
of
one
or
more
stationary
sources,
according
to
the
data
reported
in
RMPs.
The
indicator
will
be
available
on
the
Internet.
Members
of
the
public
who
do
not
have
access
to
the
Internet
would
be
able
to
obtain
the
same
information
by
calling
an
EPA
toll­
free
number
or
by
regular
mail
request
to
the
Administrator
of
EPA.

The
final
rule
also
authorizes
and
encourages
LEPCs
and
related
local
government
agencies
(
such
as
police,
fire,
emergency
management
and
planning
departments)
to
provide
read­
only
access
to
OCA
sections
of
RMP
for
sources
located
within
the
jurisdiction
of
the
LEPC
and
for
any
other
stationary
sources
that
has
a
vulnerability
zone
that
extends
into
the
LEPC's
jurisdiction.
These
local
agencies
would
receive
OCA
information
upon
request
for
all
the
sources
in
the
LEPC
jurisdiction
and
for
any
sources
whose
vulnerable
zones
extend
into
the
LEPC's
jurisdiction.
They
are
authorized
to
make
the
OCA
information
available
for
reading,
but
not
copying
mechanically,
to
members
of
the
public.
These
agencies
that
provide
read­
only
access
are
not
required
to
limit
the
number
of
stationary
sources
for
which
a
person
can
gain
access,
ascertain
a
person's
identity
or
place
of
residence
or
work,
or
keep
records
of
public
access
provided.
Local
agencies
are
authorized
and
encouraged,
but
are
not
required
to
provide
public
access
to
OCA
sections
of
RMPs.

State
agencies
and
related
state
government
agencies
(
such
as
emergency
management,
environmental
protection,
health,
and
natural
resources
departments)
would
also
receive
OCA
data
upon
request
for
all
facilities
in
the
state.
They
are
authorized
to
make
the
OCA
information
available
for
reading,
but
not
copying
mechanically,
to
members
of
the
public
for
the
same
stationary
sources
as
the
LEPC
in
whose
jurisdiction
the
person
lives
or
works.
If
the
states
choose
to
give
this
information,
they
would
need
to
verify
the
person's
address
or
place
of
employment.
State
agencies
are
not
required
to
provide
public
access
to
OCA
information.

The
final
rule
also
codifies
the
statutory
provisions
of
CSISSFRRA
that
allow
any
member
of
an
LEPC,
SERC
and
any
other
state
or
local
government
official
to
convey
to
the
public
any
OCA
data
elements
orally
or
in
writing,
provided
that
the
data
elements
are
not
conveyed
in
the
format
of
sections
2
through
5
of
an
RMP
or
any
electronic
database
that
EPA
has
developed
that
includes
OCA
data
elements.

State
and
local
government
officials
will
also
have
access
to
OCA
information
for
their
official
use.
These
officials
must
send
a
request
on
their
official
letterhead
to
certify
that
they
are
covered
persons
under
P.
L.
106­
40,
and
that
they
will
use
the
data
for
official
use
only.
3
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
The
information
collection
for
disseminating
OCA
information
is
authorized
under
the
Chemical
Safety
Information,
Site
Security,
and
Fuels
Regulatory
Relief
Act
(
CSISSFRRA).
From
the
members
of
the
public
wishing
to
view
OCA
information
at
federal
reading
rooms,
this
ICR
collects
signature
and
a
certification
stating
that
the
requestor
has
not
received
access
to
OCA
information
for
more
than
10
facilities
during
that
calendar
month.
The
federal
reading
room
staff
will
view
photo
identification
of
the
requestor
and
view
documentation
demonstrating
where
he
or
she
lives
(
for
those
who
are
requesting
local
facilities
at
federal
reading
rooms.)
Members
of
the
public
contacting
the
central
office
will
be
asked
to
give
their
name,
telephone
number,
residential
address,
and
names
of
the
facilities
they
wish
to
view
the
OCA
information.
This
ICR
also
covers
the
collection
of
written
request
from
state
and
local
officials
for
OCA
information.
In
addition,
it
governs
the
maintenance
and
disclosure
of
the
OCA
information
by
state
and
local
entities
for
public
use,
as
authorized
and
encouraged
by
CSISSFRRA
and
codified
in
40
CFR
Part
1400.

2(
b)
Practical
Utility/
Users
of
the
Information
The
information
collected
from
the
public
under
40
CFR
Part
1400
will
be
collected
to
assure
compliance
with
40
CFR
1400.3
("
Public
access
to
paper
copies
of
off­
site
consequence
analysis
information").
Signature
and
certification
will
be
collected
to
ensure
that
members
of
the
public
are
in
compliance
with
40
CFR
1400.3(
c),
which
provides
that
a
reading
room
may
not
provide
a
person
access
to
OCA
information
for
more
than
10
stationary
sources
in
a
calendar
month.
This
limitation
on
access
is
consistent
with
CSISSFRRA
section
3(
a),
which
states
in
relevant
part
that
the
regulations
promulgated
thereunder
"[
allow]
access
by
any
member
of
the
public
to
paper
copies
of
[
OCA]
information
for
a
limited
number
of
stationary
sources
located
anywhere
in
the
United
States
.
.
."
[
emphasis
added].

The
person
wishing
to
view
OCA
information
at
federal
reading
rooms
must
show
a
photo
identification
to
the
reading
room
staff
prior
to
obtaining
OCA
information.
This
requirement
is
a
reasonable
means
of
accomplishing
the
statutory
requirement
that
individuals
have
access
"
to
a
limited
number"
of
paper
copies
of
OCA
information.
The
requirement
to
show
identification
will
also
decrease
the
likelihood
that
OCA
information
would
be
obtained
by
individuals
seeking
it
for
criminal
purposes,
because
such
individuals
prefer
to
conceal
their
activities.
The
photo
identification
will
significantly
reduce
the
risk
that
someone
will
attempt
to
use
identification
that
is
not
his
or
her
own.

At
federal
reading
rooms,
the
members
of
the
public
will
also
have
access
to
OCA
information
that
the
LEPC
in
whose
jurisdiction
the
person
lives
or
works
is
authorized
to
provide.
These
individuals
will
be
asked
to
sign­
in
and
to
display
documentation
demonstrating
that
he
or
she
lives
or
works
in
the
LEPC
whose
jurisdiction
for
which
the
OCA
information
has
been
requested.
This
requirement
is
to
assure
that
the
individual
will
only
get
the
OCA
information
to
which
he
is
entitled.

If
an
individual
calls
the
central
office
to
obtain
OCA
data,
will
be
asked
to
give
his/
her
name,
telephone
number,
and
the
names
of
the
facilities
for
which
OCA
information
is
being
requested.
This
information
will
enable
the
central
office
to
schedule
an
appointment
for
the
requestor
at
a
reading
room,
4
relay
the
requested
copies
of
OCA
information
to
that
reading
room,
and,
if
necessary,
contact
the
requestor.

This
collection
also
covers
the
letters
of
request
sent
by
state
and
local
agencies
for
OCA
information
either
for
their
own
use
such
as
emergency
planning
and/
or
to
provide
read­
only
access
to
the
public.
State
and
local
officials
who
decide
to
obtain
OCA
information
for
their
official
use
must
send
a
request
on
their
official
letterhead
to
EPA
certifying
that
they
are
covered
persons
under
P.
L.
106­
40
and
that
they
will
use
the
information
for
official
use
only.

3.
NON­
DUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Non­
Duplication
The
information
being
collected
under
this
rule
are
signature,
certification
and
personal
identification
data
and
names
of
the
facilities
the
individuals
would
like
to
view
OCA
data
(
for
those
who
calls
the
central
office
to
view
OCA
data).
Also,
the
letters
from
state
or
local
officials
to
EPA
requesting
OCA
information
are
also
collected.
This
information
does
not
duplicate
any
other
federal
collection
as
it
is
specific
to
this
rule
and
necessary
to
ensure
that
the
rule
can
be
implemented.

3(
b)
Consultations
EPA
has
consulted
with
State
and
local
representatives
of
a
FACA
subcommittee
about
the
implementation
of
the
OCA
provisions
of
CSISSFRRA.
In
addition,
EPA
have
consulted
with
seven
organizations
that
represent
State
and
local
elected
officials,
and
two
tribal
organizations
that
represent
tribal
environmental
officials,
in
developing
the
final
rule.

3(
c)
Public
Notice
In
compliance
with
the
Paperwork
Reduction
Act
(
44
U.
S.
C.
3501
et
seq.),
the
Agency
notified
the
public
through
the
Federal
Register
notice
on
the
submission
of
the
ICR
to
OMB
in
the
proposed
rule
on
April
27,
2000
(
65
FR
24834).
We
received
comments
on
the
ICR
from
one
person.
The
commenter
made
a
number
of
objections
to
the
ICR
and
the
information
being
collected.

$
The
commenter
stated
that
the
agencies
have
not
provided
justification
for
the
information
being
collected
and
tracked
in
violation
of
the
Paperwork
Reduction
Act
and
the
Privacy
Act.

$
The
commenter
stated
that
the
agencies,
in
the
ICR
,
had
failed
to
list
the
public
as
one
of
primarily
affected
parties,
had
not
described
in
detail
the
information
that
would
be
collected
and
tracked,
and
had
failed
to
include
annual
public
costs.

$
The
commenter
stated
that
the
burden
to
the
public
listed
in
the
initial
ICR
was
unrealistic
because
the
public
will
need
time
to
travel
to
a
reading
room.

$
The
commenter
stated
that
the
cost
for
federal
reading
rooms
was
excessive.

The
final
rule
establishes
at
least
50
federal
reading
rooms
located
in
each
state,
the
U.
S.
territories
and
the
District
of
Columbia.
EPA
anticipates
that
there
will
be
56
reading
rooms.
The
rule
and
also
encourages
and
authorizes
state
and
local
agencies
to
provide
read­
only
public
access.
Therefore,
an
5
individual
does
not
have
to
drive
a
great
distance
to
view
OCA
information.
The
Agency
is
not
required
under
the
paperwork
reduction
act
to
include
the
drive
time,
transportation
costs,
etc.
when
calculating
burden.

During
the
time
of
the
proposed
rule,
the
Agencies
assumed
that
there
would
be
at
least
50
reading
rooms,
10
of
those
would
be
in
EPA
regional
offices
and
the
remaining
40
would
be
located
in
non­
federal
offices,
independently
operated
by
EPA
staff,
requiring
at
least
2
FTE.
Therefore,
the
cost
of
the
federal
reading
rooms
was
excessive.
At
present,
it
is
assumed
that
all
federal
reading
rooms
(
walk­
ins
and
others),
will
be
at
existing
federal
offices.
Therefore,
no
additional
staff
is
required
and
cost
for
operating
the
reading
rooms
is
much
lower
than
what
was
stated
in
the
proposed
rule
ICR.

The
proposed
rule
indicated
that
the
reading
room
personnel
will
keep
daily
sign­
in
sheets
to
record
the
name
of
the
person,
address
of
the
user
and
the
names
of
the
facilities
that
they
would
view
during
a
calendar
month
and
that
the
federal
government
will
keep
these
records.
EPA
and
DOJ
recognize
that
privacy
concerns
are
raised
whenever
government
collects
information
about
individuals.
Since
we
do
need
to
limit
the
number
of
facilities
for
which
individuals
can
access
OCA
information,
we
intend
to
keep
the
sign­
in
sheet
system,
as
stated
in
the
proposed
rule,
but
to
keep
the
sign­
in
sheets
in
a
manner
that
will
minimize
privacy
concerns
and
that
will
not
entail
the
creation
of
a
system
of
record
under
the
privacy
act.
We
will
not
be
creating
an
elaborate
tracking
system
according
to
individuals'
names
to
enforce
the
limit
on
access
to
paper
copies.
Rather,
the
reading
room
staff
will
visually
inspect
the
sign­
in
sheet(
s),
which
will
be
organized
chronologically,
for
the
month
in
which
an
individual
seeks
access
to
paper
copies
to
see
if
that
individual's
name
appears
on
the
sign­
in
sheet(
s)
for
dates
earlier
in
the
month
and,
if
so,
if
that
individual
has
already
received
OCA
information
for
more
than
10
facilities.
The
final
rule
establishes
that
the
federal
reading
room
personnel
shall
keep
records
of
reading
room
use
and
certifications,
which
will
be
retained
for
three
years.
EPA
and
DOJ
believe
that
the
sign­
in
sheets
with
self­
certification
should
provide
assurance
that
the
monthly
limit
on
OCA
information
will
not
be
exceeded.
It
should
also
be
noted
that
the
information
recorded
on
sign­
in
sheets
may
be
used
by
law
enforcement
in
the
event
of
a
duly
authorized
investigation
of
a
violation
of
civil
or
criminal
law.
For
this
reason,
these
sign­
in
sheets
will
be
retained
for
three
years.

The
information
collected
(
name,
telephone
number,
and
the
names
of
the
facilities
for
which
OCA
information
is
being
requested)
by
the
central
office
reading
room
staff
will
enable
the
central
office
to
schedule
an
appointment
for
the
requestor
at
a
reading
room,
relay
the
requested
copies
of
OCA
information
to
that
reading
room,
and
if
necessary,
contact
the
requestor.
This
information
would
not
be
retained
beyond
the
requestor's
appointment
date.

3(
d)
Effects
of
Less
Frequent
Collection
This
section
is
not
applicable.
The
only
data
being
collected
are
the
signatures
and
selfcertification
these
are
only
collected
at
the
time
of
visit.

3(
e)
General
Guidelines
This
section
is
not
applicable.

3(
f)
Confidentiality
6
The
only
data
being
collected
are
signatures
and
self
certification,
neither
of
which
are
confidential.

3(
g)
Sensitive
Questions
This
section
is
not
applicable.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents/
NAICS
Codes
The
respondent
universe
for
this
rule
is
state
and
local
officials
and
members
of
the
public.
The
most
significant
users
are
likely
to
be
state
and
local
agencies
(
NAICS
code
92111).

4(
b)
Information
Requested
Members
of
the
public
are
required
to
give
their
names,
telephone
number,
and
the
names
of
the
facilities
for
which
OCA
information
is
being
requested,
when
they
contact
the
central
office
to
schedule
an
appointment
to
view
OCA
information.
Individuals
visiting
the
reading
rooms
are
required
to
sign­
in
and
self
certify
that
they
have
not
viewed
OCA
information
for
more
than
10
facilities
during
that
calendar
month.
Individuals
wishing
to
view
OCA
information
that
the
LEPC
in
whose
jurisdiction
the
person
lives
or
works
is
authorized
to
provide,
will
also
be
asked
to
sign­
in
and
display
documentation
demonstrating
that
he
or
she
lives
or
works
in
the
LEPC
jurisdiction
for
which
the
OCA
information
has
been
requested.

State
and
local
agencies
are
required
to
send
a
written
request
to
EPA
for
OCA
information.
State
and
local
officials
must
send
the
request
on
their
official
letterhead
certifying
that
they
are
covered
persons
under
P.
L.
106­
40
and
that
they
will
use
the
data
for
official
use
only.

(
i)
Data
Elements
Members
of
the
public
requesting
to
view
OCA
information
at
federal
reading
rooms
would
be
required
to
sign
in
and
self
certify.
If
asking
for
OCA
information
from
federal
reading
rooms
for
the
facilities
in
the
area
where
they
live
or
work,
they
would
be
required
to
provide
proof
that
they
live
or
work
in
that
area.
Members
of
the
public
are
required
to
give
their
names,
telephone
number,
and
the
names
of
the
facilities
for
which
OCA
information
is
being
requested,
when
they
contact
the
central
office
to
schedule
an
appointment
to
view
OCA
information.

(
ii)
Respondent
Activities
The
respondent
activities
for
state
and
local
agencies
include:

$
Reading
and
understanding
the
Security
Notice
to
Federal,
state,
and
local
officials
and
researchers;

$
Submitting
a
written
request
to
EPA
for
OCA
information;

$
Providing
a
location
for
the
public
to
review
OCA
information
for
local
facilities;

$
Ensuring
that
members
of
the
public
do
not
remove
or
copy
OCA
information
they
review;

$
Operate
the
VZIS
indicator
system,
and
7
$
Making
OCA
information
available
in
formats
other
than
sections
2
through
5
of
the
RMP.

The
respondent
activities
for
members
of
the
public
include
the
following:

$
Calling
the
central
office
to
make
an
appointment
at
a
reading
room,
provide
name,
address,
phone
number,
and
the
names
of
the
facilities
for
which
OCA
information
is
requested;

$
Displaying
a
photo
identification
(
e.
g.,
driver's
license)
at
reading
rooms
and
proof
of
place
of
residence
or
employment
(
when
seeking
to
view
OCA
information
for
facilities
located
near
place
of
residence
or
employment);
sign­
in
and
certify
that
they
have
not
viewed
OCA
information
for
more
than
10
facilities
during
that
calendar
month.

$
Submitting
a
request
for
information
from
the
vulnerable
zone
indicator
system
(
VZIS)
(
by
Internet,
phone,
or
mail);
and
$
Making
follow­
up
calls
or
contacts
to
obtain
additional
information
on
facilities
that
may
affect
them.

Members
of
the
public
will
be
permitted
to
read
and
take
notes
from
the
OCA
information,
but
not
to
remove
or
mechanically
reproduce
it.
The
rule
imposes
no
limit
on
the
number
of
local
facilities
(
within
the
LEPC
district
or
affecting
the
LEPC
district)
for
which
members
of
the
public
may
review
paper
copies
of
OCA
information
made
available
by
local
agencies.
The
rule
does
not
require
local
agencies
to
ask
members
of
the
public
to
show
any
identification
to
gain
access
to
the
information.
State
agencies
are
permitted
to
provide
a
person
the
same
access
to
paper
copies
of
OCA
information
to
a
member
of
the
public
as
that
person
would
receive
at
his
or
her
local
agency.
State
agencies
will
need
to
verify
that
a
person
seeking
information
for
an
area
lives
or
works
in
the
area.

The
burden
estimates
for
documentation
and
reporting
are
discussed
in
section
6
of
this
ICR.

5.
THE
INFORMATION
COLLECTED
C
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Federal,
State,
and
Local
Government
Activities
Burden
to
State
and
Local
Agencies
and
Others
State
and
local
officials
who
decide
to
obtain
OCA
information
must
send
a
written
request
on
their
official
letterhead
to
EPA
certifying
that
they
are
covered
persons
under
P.
L.
106­
40,
and
that
they
will
use
the
information
for
official
use
only.
EPA
will
also
provide
paper
copies
of
RMPs
to
these
agencies
on
request.

The
rule
authorizes
and
encourages
state
and
local
agencies
to
set
up
public
reading
rooms.
The
local
reading
rooms
would
provide
read­
only
access
to
OCA
information
for
all
the
sources
in
the
LEPC's
jurisdiction
and
for
any
source
where
the
vulnerable
zone
extends
into
the
LEPC's
jurisdiction.

These
agencies
are
not
required
to
carry
out
these
activities,
however
the
costs
and
burden
are
detailed
in
section
6.
8
Burden
to
the
Federal
Government
The
federal
government
will
provide
reading
rooms.
The
federal
government
will
also
need
to
develop
and
maintain
the
VZIS
software.
The
federal
government
will
also
need
to
supply
the
state
and
local
agencies
with
OCA
information,
VZIS
software
and
provide
technical
support.
The
government
may
also
engage
in
other
activities
to
provide
access
to
OCA
information.

5(
b)
Collection
Methodology
and
Management
The
federal
reading
rooms
will
maintain
records
of
reading
room
use
and
certifications
in
accordance
with
procedures
established
by
the
Administrator
and
the
Attorney
General.
These
records
shall
be
retained
for
no
more
than
three
years.

The
federal
reading
room
staff
will
view
the
photo
identification
of
requestors
to
ensure
that
the
identification
belongs
to
the
person
requesting
OCA
information.
Requiring
an
individual
to
show
identification
will
also
decrease
the
likelihood
that
OCA
information
would
be
obtained
by
individuals
seeking
it
for
criminal
purposes.

The
reading
room
staff
will
also
view
proof
of
residence
and
employment
to
ensure
that
the
requestor
only
receives
access
to
the
local
OCA
information
to
which
he
or
she
is
entitled.
The
requirement
for
signature
and
self­
certification
is
to
prevent
individuals
from
obtaining
OCA
information
more
than
their
limit
(
10
facilities
per
calendar
month
national
limit).
To
further
deter
individuals
from
attempting
to
exceed
their
allotment
by
visiting
more
than
federal
reading
room
in
a
month,
reading
room
personnel
will
be
instructed
to
provide
access
to
OCA
information
only
to
individuals
who
have
signed
a
certification
that
they
have
not
exceeded
their
allotment.
The
certification
will
inform
members
of
the
public
that
they
may
be
subject
to
criminal
penalties
under
federal
law
for
falsely
certifying
that
they
have
not
received
OCA
information
for
more
than
10
facilities
that
month.
The
information
recorded
on
sign­
in
sheets
may
be
used
by
law
enforcement
in
the
event
of
a
duly
authorized
investigation
of
a
violation
of
civil
or
criminal
law.
Therefore,
these
sign­
in
sheets
will
be
retained
for
three
years.

The
information
collected
during
telephone
call
received
by
the
central
office
from
a
requestor
of
OCA
information
will
enable
the
central
office
to
schedule
an
appointment
for
the
requestor
at
a
reading
room,
relay
the
requested
copies
of
OCA
information
to
that
reading
room,
and,
if
necessary,
contact
the
requestor.
This
information
would
not
be
retained
beyond
the
requestor's
appointment
date.

The
requests
from
state
and
local
officials
for
OCA
information
would
also
be
retained
for
three
years.

5(
c)
Small
Entity
Flexibility
The
rule
does
not
require
small
entities,
such
as
local
emergency
planning
committees
or
related
local
government
agencies,
to
provide
public
access
to
OCA
information,
hence
no
special
requirements
are
needed
for
small
entities.
5(
d)
Collection
Schedule
The
information
collected
at
the
federal
reading
rooms
are
only
when
an
individual
request
OCA
information.
9
1
The
number
of
counties
is
from
the
Statistical
Abstract
of
the
United
States,
Department
of
Commerce,
U.
S.
Census
Bureau.
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Respondent
Burden
State/
Local
Agencies
The
number
of
respondents
undertaking
the
activities
listed
in
section
4(
b)(
ii)
is
estimated
to
be
at
least
one
agency
in
each
of
the
50
states,
D.
C.
and
the
U.
S.
territories.
These
agencies
are
assumed
to
be
members
of
the
State
Emergency
Response
Commission
(
SERC),
environmental
protection
agencies,
emergency
management
agencies,
etc.
In
the
ICR
for
the
proposed
rule,
it
was
assumed
that
at
least
one
agency
in
each
of
the
3,043
U.
S.
counties
(
each
county
is
assumed
to
have
1
LEPC)
would
request
OCA
information1.
Based
on
a
recent
survey,
EPA
estimates
that
there
are
1,500
active
LEPCs
(
in
compliance
with
Emergency
Planning
and
Community
Right­
to­
Know
Act),
which
will
request
OCA
information
from
EPA
for
their
own
use
such
as
emergency
planning
and
some
of
these
LEPCs
may
also
provide
public
read­
only
access.
Based
on
the
comments
we
received
on
the
proposed
rule,
it
is
assumed
that
in
the
first
year
covered
by
this
ICR,
only
300
out
of
the
1500
LEPCs
may
provide
read­
only
access.
By
the
end
of
the
second
year,
it
is
assumed
600
will
provide
read­
only
access,
by
the
end
of
the
third
year,
a
total
of
1000
will
provide
read­
only
access.

The
state
and
local
agencies
are
assumed
to
spend
two
hours
a
week
providing
information
to
the
public
(
providing
read­
only
access
and
operate
the
VZIS).
The
local
agencies
are
assumed
to
hold
3
public
meetings,
in
the
three
years
covered
by
this
ICR,
which
would
take
8
hrs
each
for
preparation
and
to
hold
the
meeting.
The
state
and
local
official
will
take
will
take
approximately
one
hour
per
official
to
prepare
the
letter
to
request
OCA
information.
State
and
local
agencies
are
assumed
to
take
2
hrs
training
on
the
VZIS
and
1
hr
training
on
the
security
of
OCA
information
(
one­
time
burden).
The
total
burden
hours
for
state
and
local
agencies
are
estimated
to
be
86,000
hours
annually
(
258,000
hours
for
three
years)
at
a
cost
of
$
2.4
million
annually
($
7.2
million
for
three
years).

Public
It
is
assumed
that
the
members
of
the
public
would
take
approximately
one
hour
to
sign­
in
and
certify;
call
the
central
office
to
give
name,
address,
telephone
number,
names
of
the
facilities
for
which
OCA
information
is
requested;
and
to
display
documentation
demonstrating
proof
of
residence
and
employment
to
view
local
facilities
at
federal
reading
room.
Based
on
a
survey,
it
was
estimated
that
3,500
people
visited
LEPCs/
state
agencies
to
view
information
filed
under
Section
312
of
EPCRA.
Based
on
this,
EPA
assumes
that
the
federal
reading
rooms
will
also
be
visited
by
at
least
3,500
individuals
for
OCA
information.
The
local
reading
rooms
will
most
likely
attract
more
people
than
the
federal
rooms
since
they
may
be
easily
accessible.
Therefore,
EPA
assumes
that
at
least
2
people
from
each
of
the
3,043
counties
will
visit
state
and
local
reading
rooms
since
the
OCA
information
contains
consequences
of
accidental
releases
that
affect
their
community
(
home,
school
etc.)
than
the
EPCRA
312
information
which
contains
amounts
of
chemicals
stored
at
a
facility.
EPCRA
312
information
does
not
give
details
on
the
consequences
of
releases,
what
facilities
are
doing
to
prevent
accidents
or
the
facilities
emergency
response
programs,
which
is
what
a
facility's
RMP
plan
contains.
10
Additionally,
it
is
assumed
that
the
public
will
use
the
vulnerable
zone
indicator
system
(
VZIS).
EPA
estimates
that
approximately
20,000
people
will
use
the
VZIS
system
each
year
and
5,000
of
those
will
seek
additional
information.
Those
individuals
that
do
not
have
access
to
the
Internet
will
be
able
to
call
an
EPA
toll­
free
number
or
send
the
request
by
mail.
These
estimates
are
based
on
queries
into
RMP*
Info.
Out
of
the
20,000,
EPA
estimates
that
10,000
people
will
send
an
email
request,
10,000
will
call
an
EPA
toll­
free
number
for
request
and
about
20
people
will
mail
letters
requesting
information.
It
is
assumed
to
take
three
minutes
for
an
email,
15
minutes
for
a
call
to
the
hotline
and
follow­
up
call,
and
30
minutes
to
write
a
letter
and
mail
it.
The
total
burden
to
the
public
is
estimated
to
be
14,000
hours
annually
(
42,000
hours
over
three
years)
at
a
cost
of
$
293,000
annually
($
879,000
over
three
years).

6(
b)
Estimating
Respondent
Costs
To
estimate
costs
for
state
and
local
agencies
to
provide
the
OCA
information
to
the
public
and
monitor
its
use,
operate
the
VZIS,
prepare
for
the
public
meetings,
training
on
the
security
of
OCA
information,
the
public
administration
hourly
rate
for
state
and
local
government
employees
of
$
26.26
(
wages
plus
benefits)
was
used
(
Bureau
of
Labor
Statistics
data,
March
2000,
Table
4).

To
estimate
costs
for
state
and
local
officials
to
submit
a
written
request
to
EPA
for
OCA
information,
and
to
hold
public
meetings,
the
executive/
managerial
average
hourly
rate
for
state
and
local
government
employees
of
$
36.20
(
wage
plus
benefits)
was
used
(
Bureau
of
Labor
Statistics
data,
March
2000,
Table
4).

The
value
of
the
public
time
is
estimated
to
be
at
$
21.16
per
hour,
the
average
compensation
for
all
U.
S.
civilian
employees
(
Bureau
of
Labor
Statistics
data,
March
2000,
Table
1).

6(
c)
Estimating
Annual
Respondent
Cost
Burden
Capital
and
O&
M
Costs
­
State,
local
agencies
and
the
public
The
state
and
local
agencies
capital
costs
are
estimated
to
be
$
125,000
for
purchasing
computer
equipment
to
operate
the
VZIS.
The
cost
is
annualized
assuming
the
equipment
is
depreciated
over
five
years.
The
total
annual
O&
M
cost
for
state,
local
agencies
to
mail
letters
to
EPA
requesting
OCA
information
is
approximately
$
260.00.
The
annual
O&
M
cost
for
the
public
to
mail
letters
to
EPA
requesting
information
from
the
VZIS
is
$
10.00.

6(
d)
Estimating
Costs
for
the
Federal
Government
EPA
and
DOJ
will
maintain
at
least
56
federal
reading
rooms
located
at
federal
buildings.
At
least
one
federal
reading
room
will
be
located
in
each
state,
the
District
of
Columbia,
and
each
of
the
U.
S.
territories.
EPA
anticipates
that
approximately
28
out
of
the
56
reading
rooms
will
operate
the
VZIS.
There
will
be
approximately
15
walk­
in
reading
rooms,
and
the
remaining
will
be
by
appointments
only.

Federal
costs
were
estimated
based
on
activity
and
the
FY
2000
GS
wage
schedule.
Copying
time
(
to
make
paper
copies
of
OCA
information
for
state
and
local
agencies
if
requested)
was
estimated
using
a
GS­
4;
reading
room
activities
were
estimated
using
a
GS­
9,
step
5;
VZIS
operation
was
estimated
at
GS­
13
step
5;
and
software
development
and
maintenance
was
estimated
at
a
GS­
14
rate.
The
wages
for
these
staff
were
loaded
with
fringe,
but
no
overhead.
11
The
reading
room
activities
may
vary
depending
on
whether
it
is
a
reading
room
with
walk­
in
access,
phone­
in
access
or
operating
the
VZIS.
The
reading
room
staff
are
expected
to
take
phone
calls
from
the
public,
schedule
appointments
for
use
of
the
reading
rooms,
print
the
requested
RMPs,
review
the
identification
presented,
monitor
the
use
of
the
RMPs
to
ensure
that
they
are
not
mechanically
copied,
and
shred
them
when
the
user
is
finished.
Reading
room
staff
will
spend
one
hour
learning
how
to
handle
OCA
information
securely.
Reading
room
staff
(
those
that
will
operate
VZIS)
are
also
assumed
to
take
a
onehour
training
course
to
use
the
software
needed
to
identify
facilities
whose
vulnerable
zone
affects
a
specific
address.
Reading
room
activity
and
VZIS
operation
was
estimated
to
require
the
one
tenth
of
the
time
of
a
federal
employee
for
each
of
the
appropriate
reading
room.

The
VZIS
development,
maintenance,
providing
technical
support,
creating
the
disks
for
each
state
and
LEPC
(
each
disk
will
have
its
OCA
data
for
their
jurisdiction)
are
estimated
to
take
1,470
hours.
EPA
will
also
have
to
operate
the
VZIS
system
and
respond
to
queries.
It
was
estimated
that
EPA
would
spend
15
minutes
responding
to
each
query
and
an
equal
amount
of
time
answering
follow
up
calls.

EPA
will
have
to
make
paper
copies,
compile
binders,
and
mail
them
to
state
and
local
agencies
if
requested.
Making
two
complete
sets
of
RMPs
(
one
for
states,
one
for
local
agencies)
was
estimated
to
take
158
hours
to
copy
(
570,000
pages
at
60
pages
per
second).
It
was
assumed
that
compiling
the
binders
would
take
0.5
each
to
sort
the
RMPs
by
LEPC,
check
the
completeness
of
the
binder,
and
prepare
the
mailing.
In
addition,
as
RMPs
are
updated,
it
was
assumed
that
EPA
would
send
the
state
and
local
agencies
updated
copies
of
specific
RMPs;
1,000
RMPs
were
assumed
to
updated
each
year.

The
total
burden
on
the
federal
government
is
estimated
to
be
30,000
hrs
annually
(
90,000
hrs
for
three
years)
at
a
cost
of
$
1,000,000
annually
($
3,000,000
for
three
years).

O&
M
Costs
Reading
rooms
were
assumed
to
need
a
computer,
monitor,
printer,
and
shredder.
All
15
walk­
in
reading
rooms
are
estimated
to
have
computer/
monitor/
printer.
All
56
reading
rooms
will
have
shredders.
Reading
rooms
that
operate
VZIS
may
have
to
have
upgraded
computer
system
to
run
the
VZIS
software.
Based
on
current
list
prices
for
the
equipment
from
retail
outlets,
the
equipment
was
assumed
to
cost
the
following:

Computer
$
1,000
(
having
capability
of
VZIS
software)
Monitor
$
200
Printer
$
200
Shredder
$
250
Recycled
paper
$
4.79/
ream
Depreciated
over
five
years,
the
total
annualized
equipment
cost
for
the
56
federal
reading
rooms
is
$
9,000.
The
annual
cost
for
VZIS
software
is
$
5,400.
In
addition,
reading
rooms
were
assumed
to
print
out
copies.
Using
a
cost
of
$
4.79
for
a
ream
of
recycled
copy
paper,
EPA
estimates
that
its
annual
paper
cost
is
$
10,000,
assuming
each
person
visiting
a
reading
room
looks
at
20
RMPs
(
10
local
and
10
outside
the
area).
The
annual
mailing
cost
is
$
45,000,
for
sending
copies
of
OCA
information
to
the
reading
rooms
from
the
central
office
and
mailing
VZIS
software
and
OCA
information
to
state
and
local
agencies.

6(
e)
Bottom
Line
Burden
Hours
and
Costs
12
The
total
burden
hours
presented
on
Form
OMB­
83i
were
derived
in
the
following
manner:

13.
a
The
universe
of
reporting
or
disclosure
respondents
is
equal
to
the
total
number
of
state
and
local
entities
expected
to
request
OCA
information
from
EPA
and
providing
access
to
OCA
information
to
the
public,
the
public
visiting
the
reading
rooms
and
requesting
information
from
the
VZIS
(
31,140),
number
of
annual
respondents
is
10,380.

13.
b
The
number
of
responses
per
respondent
is
one.

14.
The
annualized
cost
burden
for
respondents
during
the
time
period
covered
by
this
ICR
is
estimated
to
be
100,000
hours
and
$
2.8
million
(
300,000
hours
and
$
8.4
million
for
the
three­
year
period).

6(
f)
Reasons
for
Change
in
Burden
This
section
is
not
applicable.

6(
g)
Burden
Statement
The
public
reporting
and
record
keeping
burden
is
estimated
to
be
100,000
hours
and
$
2.8
million
annually
(
300,000
hours
and
$
8.4
million
for
the
three­
year
period).

Send
comments
regarding
this
burden
estimate
or
any
other
aspect
of
this
collection
of
information,
including
suggestions
for
reducing
the
burden,
to:
Director,
Office
of
Environmental
Information,
Collection
Strategies
Division
(
2822),
U.
S.
Environmental
Protection
Agency,
1200
Pennsylvania
Ave,
NW,
Washington
D.
C.
20460;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
Washington,
D.
C.
20503,
"
Attn:
Desk
Officer
for
the
EPA."
13
Exhibit
1
LOCAL
AGENCIES
BURDEN
AND
COSTS
Annualized
Three­
Year
Hours
Dollars
Hours
Dollars
Reading
Room
67,000
$
1.8
million
201,000
$
5.3
million
Covered
Person
Request
500
$
18,000
1,500
$
54,000
Public
Meeting
12,000
$
375,000
36,000
$
1.1
million
Equipment
$
113,000
$
339,000
Mailing
$
250
$
750
Total
80,000
$
2.3
million
238,500
$
6.9
million
14
Exhibit
2
STATE
AGENCIES
COST
AND
BURDEN
Annualized
Three­
Year
Hours
Dollars
Hours
Dollars
Reading
Room
5,900
$
154,000
18,000
$
463,000
VZIS
Training
200
$
5,900
700
$
18,000
Covered
Person
Request
18
$
700
50
$
2,000
Equipment
$
12,000
$
35,000
Mailing
$
8
$
25
Total
6,000
$
173,000
18,000
$
519,000
15
Exhibit
3
FEDERAL
GOVERNMENT
BURDEN
AND
COSTS
Annualized
Annualized
Hours
Dollars
Hours
Dollars
Reading
Room
22,000
900,000
67,000
$
2.1
million
Supplying
OCA
Data
to
State/
Local
500
$
24,000
1,500
$
71,000
VZIS
7,000
$
307,000
21,000
$
923,000
Total
30,000
$
1
million
90,000
$
3.1
million
16
Exhibit
4
PUBLIC
BURDEN
AND
COSTS
Annual
3
Year
Hours
Dollars
Hours
Dollars
Reading
Rm.
9,600
$
203,000
29,000
$
608,000
VZIS
4,300
$
90,000
13,000
$
270,000
Total
14,000
$
293,000
42,000
$
879,000
