INFORMATION
COLLECTION
REQUEST
SUPPORTING
STATEMENT
FOR
COMPLIANCE
ASSISTANCE
SURVEYS
FOR
THE
MARINA,
METAL
FINISHING,
CONSTRUCTION
SITE,
AND
AUTO
SALVAGE
YARD
SECTORS
May
31,
2001
U.
S.
Environmental
Protection
Agency
Office
of
Compliance
2
TABLE
OF
CONTENTS
Part
A
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
of
the
Information
Collection
1(
b)
Short
Characterization/
Abstract
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
2(
b)
Practical
Utility/
Users
of
the
Data
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
3(
c)
Consultations
3(
d)
Effects
of
Less
Frequent
Data
Collection
3(
e)
General
Guidelines
3(
f)
Confidentiality
3(
g)
Sensitive
Questions
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents/
SIC
Codes
4(
b)
Information
Requested
5.
THE
INFORMATION
COLLECTED:
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
5(
b)
Collection
Methodology
and
Management
5(
c)
Small
Entity
Flexibility
5(
d)
Collection
Schedule
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
6(
b)
Estimating
Government
Burden
6(
c)
Bottom
Line
Burden
and
Cost
Table
6(
d)
Reasons
for
Change
of
Burden
6(
e)
Burden
Statement
3
Part
B
1.
SURVEY
OBJECTIVES,
KEY
VARIABLES,
AND
OTHER
PRELIMINARIES
1(
a)
Survey
Objectives
1(
b)
Key
Variables
1(
c)
Statistical
Approach
1(
d)
Feasibility
2.
SURVEY
DESIGN
2(
a)
Target
Population
and
Coverage
2(
b)
Sample
Design
2(
c)
Precision
Requirements
2(
d)
Questionnaire
Design
3.
PRETESTS
AND
PILOT
TESTS
4.
COLLECTION
METHODS
AND
FOLLOW­
UP
4(
a)
Collection
Methods
4(
b)
Survey
Response
and
Follow­
up
5.
ANALYZING
AND
REPORTING
SURVEY
RESULTS
5(
a)
Data
Preparation
5(
b)
Analysis
5(
c)
Reporting
Results
4
Part
A
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
of
the
Information
Collection
ICR:
Compliance
Assistance
Surveys
for
the
Marina,
Metal
Finishing,
Construction
Site,
and
Auto
Salvage
Yard
Sectors
(
EPA
ICR
Number
2021.01)
OMB
Control
Number:

"
Compliance
Assistance
Surveys
for
the
Marina,
Metal
Finishing,
Construction
Site,
and
Auto
Salvage
Yard
Sectors"

1(
b)
Short
Characterization/
Abstract
EPA's
Office
of
Compliance
(
OC)
is
interested
in
testing
methods
for
collecting
outcome
data
from
their
compliance
assistance
efforts.
OC
is
planning
to
conduct
surveys
to
three
sectors
to
compare
two
survey
methodologies:
mailed
surveys
using
the
"
total
design
method"
and
surveys
conducted
as
on­
site
visits.
EPA
will
also
use
the
survey
results
to
evaluate
the
impact
of
compliance
assistance
activities
on
facilities
in
these
sectors.
These
surveys
will
support
OC
in
collecting
statistically
valid
compliance
assistance
outcome
data
needed
to
present
the
impacts
of
compliance
assistance
for
Government
Performance
and
Results
Act
(
GPRA)
reporting
purposes.
OC
is
interested
in
conducting
the
surveys
for
sectors
in
three
stages
of
analysis/
activity:
1)
a
sector
for
which
OC
is
beginning
a
compliance
assistance
effort
(
marinas);
2)
a
sector
for
which
OC/
EPA
have
conducted
several
compliance
assistance
activities
(
metal
finishing);
and
3)
a
sector
for
which
OC
doesn't
have
sufficient
information
to
determine
compliance
assistance
needs
(
either
construction
sites
or
auto
salvage
yards).

EPA
Region
1
is
planning
a
marinas
initiative
to
provide
marinas
with
basic
regulatory
information
and
to
encourage
"
beyond
compliance"
behavior
through
the
dissemination
of
a
wide
variety
of
tools.
EPA
Region
1
would
like
to
conduct
statistically
valid
voluntary
mail
and
sitevisit
surveys
on
a
subset
of
the
approximate
1,200
marinas
in
Region
1.
These
surveys
will
be
used
to
1)
determine
to
what
degree
key
environmental
practices
are
currently
in
use
at
Region
1
marinas
and
2)
get
a
better
sense
of
the
compliance
challenges
faced
by
this
sector.
The
results
of
the
survey
will
be
used
to
establish
a
performance
baseline
at
the
start
of
this
initiative.
After
implementation
of
the
compliance
assistance,
a
follow­
up
survey
will
be
conducted
to
determine
progress
against
the
baseline.

OC
has
adopted
a
sector
approach
for
many
of
its
compliance
assistance
activities.
The
metal
finishing
industry
is
an
example
of
a
sector
for
which
EPA
has
focused
many
of
its
compliance
assistance
activities.
There
is
considerable
debate
as
to
the
extent
of
environmental
releases,
environmental
impacts
associated
with
these
releases,
compliance
rates,
the
need
for
compliance
assistance,
and
the
effectiveness
of
compliance
assistance
tools
developed
for
this
industry.
5
OC
would
like
to
conduct
statistically
valid
voluntary
mail
and
site­
visit
surveys
on
a
subset
of
metal
finishing
facilities
in
EPA
Regions
1
and
5
to
1)
determine
a
performance
snapshot
of
this
sector
which
reflects
current
facility
performance
with
respect
to
key
federal
regulations
and
2)
compare
the
performance
of
facilities
that
have
received
compliance
assistance
to
those
that
have
not.
The
surveys
will
be
conducted
as
a
voluntary
blind
sample
(
i.
e.,
the
facility's
identity
will
be
unknown
to
the
Agency
and
the
facilities
will
participate
voluntarily).
The
results
of
the
survey
will
provide
OC
with
information
on
compliance
assistance
topics
applicable
to
this
sector
and
information
from
which
to
measure
the
success
of
OC's
compliance
assistance
programs
for
Government
Performance
and
Results
Act
(
GPRA)
reporting
purposes.

OC
is
also
planning
to
conduct
a
compliance
assistance
needs
assessment
for
two
additional
sectors:
construction
sites
and
auto
salvage
yards.
OC
identified
these
sectors
based
on
anecdotal
information
from
states
and
EPA
regions;
however,
sufficient
data
are
not
available
in
EPA's
databases
to
evaluate
the
current
state
of
compliance
in
these
sectors.
Therefore,
OC
is
interested
in
determining:


The
level
of
regulatory
awareness
in
each
sector;


A
snapshot
of
environmental
performance
for
each
sector;


The
need
for
compliance
assistance
tools
for
each
sector;
and

The
tools
that
would
be
most
accessible
and
useful
for
each
sector.

OC
is
soliciting
comment
whether
to
conduct
statistically
valid
voluntary
mail
and
site­
visit
surveys
of
facilities
in
one
of
these
sectors
using
the
same
approach
as
described
above
for
the
marina
and
metal
finishing
sectors.
Since
the
population
for
construction
sites
and
auto
salvage
yards
is
not
known,
OC
will
conduct
double
stage
cluster
sampling
as
described
in
Part
B
of
this
supporting
statement.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
There
are
three
main
purposes
for
these
compliance
assistance
surveys:


To
collect
data
to
compare
the
cost
(
for
both
respondents
and
EPA)
and
the
utility
of
mailed
surveys
versus
site
visit
surveys.
Site
visit
surveys
are
believed
to
require
more
respondent
time
but
should
result
in
an
improved
response
rate
and
more
complete
and
accurate
data
when
compared
to
a
mailed
survey.
OC
would
like
to
test
this
hypothesis
by
conducting
parallel
mailed
and
site
visit
surveys
to
two
or
more
industry
sectors.


To
determine
a
current
level
of
regulatory
awareness
and
environmental
performance
from
which
to
measure
the
success
of
the
Agency's
compliance
outreach
efforts
for
reporting
under
the
Government
Performance
and
Results
Act
(
GPRA).
For
each
sector
for
which
EPA
is
planning
to
initiate
compliance
assistance,
a
baseline
level
of
performance
and
6
regulatory
awareness
is
needed
to
measure
future
progress.


To
identify
areas
of
regulatory
confusion
for
each
sector
studied
so
that
compliance
assistance
outreach
resources
can
be
targeted
to
address
those
areas.

The
compliance
assistance
outcome
data
requested
by
these
surveys
is
not
currently
in
EPA's
databases.
These
surveys
will
help
OC
to
evaluate
the
effectiveness
of
outreach
projects
and
will
enable
OC
to
report
compliance
assistance
outcome
data
that
is
statistically
valid
and
can
be
used
for
GPRA
reporting
purposes.

The
Agency
is
permitted
to
collect
the
information
under
the
following
statutes:


The
Clean
Air
Act.
The
Act
refers
to
activities
involving
the
discharge
of
hazardous
air
pollutants
and
criteria
pollutants
from
emission
sources.
At
§
114,
the
Agency
may
require
any
person
who
owns
or
operates
any
emission
source
to
establish
and
maintain
such
records,
...
make
such
reports,
...
install,
use,
and
maintain
such
monitoring
equipment
or
methods,
...
sample
such
emissions,
...
and
provide
such
other
information
as
he/
she
may
reasonably
require.
(
Note
that
no
additional
monitoring
or
sampling
will
be
required
by
this
ICR).


The
Solid
Waste
Disposal
Act.
The
Act
refers
to
activities
at
companies
that
generate
hazardous
waste.
At
§
3007,
the
Agency
is
permitted
to
have
access
to
and
request
records
regarding
hazardous
waste
generating
activities.


The
Clean
Water
Act.
The
Act
refers
to
activities
involving
the
discharge
of
materials
into
waters
of
the
United
States.
At
§
308,
the
Agency
is
permitted
to
review
records
to
determine
compliance
with
effluent
limitations
or
treatment
performance
standards.

The
information
collected
through
this
ICR
will
aid
the
Agency
in
achieving
EPA's
Strategic
Plan
goal
of
protecting
the
environment
through
sector­
based
approaches.
This
goal
was
developed
in
response
to
the
1993
Government
Performance
and
Results
Act
and
is
described
in
EPA's
2000
Strategic
Plan,
Chapter
2,
Protecting
the
Environment
Through
the
Sector­
Based
Approach.

2(
b)
Practical
Utility/
Users
of
the
Data
EPA
Region
1
and
the
EPA
Office
of
Compliance
will
be
the
users
of
the
data
collected
by
the
surveys
covered
under
this
Information
Collection
Request
(
ICR).
EPA
Region
1
will
use
the
data
collected
on
the
marina
sector
to
make
potential
adjustments
to
the
compliance
assistance
projects
planned
for
this
sector.
EPA
will
use
the
marinas
data
to
determine
a
baseline
and
follow­
up
level
of
regulatory
awareness
and
environmental
performance
which
EPA
cannot
determine
using
existing
databases.
This
information
will
then
be
used
to
measure
if
compliance
assistance
efforts
undertaken
by
Region
1
in
their
marina
initiative
have
improved
the
level
of
regulatory
awareness
and
environmental
performance
for
this
sector.
This
information
will
be
of
7
sufficient
quality
for
reporting
under
the
GPRA.

EPA
OC
will
use
the
information
collected
on
the
metal
finishing
sector
to
evaluate
the
impact
of
compliance
assistance
to
date
on
this
sector
by
comparing
those
facilities
which
have
received
compliance
assistance
against
those
that
have
not.
EPA
will
also
use
this
information
to
identify
compliance
assistance
mechanisms
effective
for
this
sector.

Information
collected
on
the
Construction
Site
or
Auto
Salvage
Yard
sectors
will
determine
the
level
of
regulatory
awareness
and
environmental
performance
exhibited
by
these
sectors,
which
EPA
cannot
determine
using
existing
databases.
This
information
will
allow
EPA
to
conduct
a
compliance
assistance
needs
assessment
and
will
also
provide
a
baseline
of
environmental
performance
from
which
to
measure
the
success
of
future
sector
compliance
assistance
projects.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
The
information
to
be
obtained
under
this
ICR
has
not
been
collected
by
EPA
or
any
other
federal
agency.
In
general,
the
sectors
to
be
studied
using
this
ICR
comprise:


mostly
small
facilities;


facilities
potentially
impacted
by
the
CAA,
CWA,
HSWA,
TSCA;
and

facilities
that
have
not
been
a
focus
for
EPA
inspection
and
enforcement
activities.

The
Agency
has
reviewed
its
databases
to
identify
information
for
evaluating
environmental
performance
for
these
sectors.
Currently,
the
Agency
does
not
have
sufficient
information
for
this
evaluation,
since
these
sectors
have
not
been
a
high
priority
for
inspection
and
enforcement
activity.

The
majority
of
facilities
in
these
sectors
are
small
indirect
dischargers
and
typically
do
not
fall
into
EPA's
reporting
requirements.
Therefore,
these
sectors
are
not
well­
represented
in
EPA's
media­
specific
and
program­
specific
databases.
An
exception
is
that
a
subset
of
metal
finishers
and
electroplaters
have
reporting
requirements
under
40
CFR
Parts
433
and
413
as
part
of
the
NPDES
program.
However,
reporting
under
this
program
is
site
specific
addressing
only
one
media
for
the
metal
finishing
sector
and
does
not
supply
information
on
the
sector's
performance
with
other
media
requirements.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
On
March
23,
2001,
EPA
published
a
pre­
ICR
Federal
Register
Notice
announcing
its
intent
to
submit
an
ICR
to
OMB
regarding
compliance
assistance
surveys
for
the
Marina,
Metal
Finishing,
Construction
Site,
and
Auto
Salvage
Yard
sectors.
Attachment
A
includes
a
copy
of
this
Federal
Register
Notice.
EPA
received
two
comments
in
response
to
this
Federal
Register
Notice.
The
8
first
comment
was
from
the
Automobile
Recyclers
Association
(
ARA).
This
association
represents
a
portion
of
the
auto
salvage
yard
industry.
The
comment
requested
clarification
on
how
EPA
will
ensure
complete
coverage
of
the
auto
salvage
yard
sector
in
its
survey
efforts.
EPA
addressed
this
comment
by
using
the
double
stage
cluster
sampling
technique.
The
auto
salvage
yards
will
be
identified
using
all
available
information,
not
just
EPA
databases
or
trade
association
member
lists.
The
second
comment
was
from
the
Institute
of
Scrap
Recycling
Industries
(
ISRI).
This
association
represents
scrap
metal
recyclers.
The
comment
requested
clarification
on
the
"
salvage
yard"
sector.
EPA
addressed
this
comment
by
clarifying
that
the
survey
is
intended
for
the
auto
salvage
yard
sector,
SIC
5015.
EPA
removed
references
to
SIC
5093,
which
covers
scrap
metal
recyclers.

3(
c)
Consultations
EPA
Region
1
conducted
marina
stakeholder
planning
meetings
in
each
of
the
region's
states.
At
these
meetings,
EPA
Region
1
discussed
their
marina
assistance
strategy
including
consultation
on
their
information
collection
plans.
Attendees
at
the
meetings
included
staff
from
state
Coastal
Zone
Management
program
offices,
staff
from
various
state
program
offices
that
provide
assistance
to
marinas,
four
State
Marina
Trade
Association
presidents,
several
marina
owners,
and
two
Small
Business
Development
Center
staff
members.
In
addition,
EPA
Region
1
consulted
with
a
variety
of
state
environmental
assistance
provider
stakeholders
at
a
workshop
session
of
the
Northeast
Waste
Management
Official's
(
NEWMOA)
2000
Fall
Technology
Training
Conference.

For
the
metal
finishing
survey,
EPA
OC
consulted
with
members
of
EPA's
Sector
Programs
Division,
EPA
Regions
1
and
5,
and
state
compliance
assistance
staff
on
the
survey
instrument.
EPA
OC
also
consulted
with
representatives
of
the
metal
finishing
industry,
including
George
Cushnie
of
CAI,
Inc.,
Paul
Chalmer
of
the
National
Center
for
Manufacturing
Sciences,
and
Christian
Richter
of
The
Policy
Group,
which
represents
the
Association
of
Electroplaters
and
Surface
Finishers,
the
National
Association
of
Metal
Finishers,
and
the
Metal
Finishers
Suppliers
Association.
EPA
Region
1
also
consulted
with
five
members
of
the
metal
finishing
community.
In
addition,
OC
consulted
with
a
variety
of
state
environmental
assistance
provider
stakeholders
at
a
breakout
session
of
the
2001
Compliance
Assistance
Forum
about
this
survey
project.
As
a
result
of
these
consultations,
EPA
made
several
revisions
to
the
survey
to
clarify
questions,
simplify
the
flow
pattern,
and
lessen
the
"
self­
incrimination"
aspect
of
the
survey.

3(
d)
Effects
of
Less
Frequent
Data
Collection
The
survey
and
site
visit
program
for
the
metal
finishing
and
construction
site/
auto
salvage
yard
sectors
are
one­
time
data
gathering
efforts.
The
survey
and
site
visit
program
for
the
marina
sector
includes
a
baseline
and
follow­
up
survey.
The
follow­
up
survey,
which
will
occur
at
randomly
selected
facilities,
results
in
a
slight
chance
that
a
facility
could
be
in
both
the
baseline
and
follow­
up
sample
but
EPA
assumes
that
it
isn't
likely
to
occur.
Therefore,
this
data
collection
request
does
not
require
periodic
reporting
or
record
keeping.
9
3(
e)
General
Guidelines
This
information
collection
is
consistent
with
OMB
guidelines
contained
in
5
CFR
1320.5(
d)(
2).

3(
f)
Confidentiality
EPA
does
not
expect
that
any
confidential
business
information
or
trade
secrets
will
be
required
from
the
marinas,
metal
finishing,
construction
site,
or
auto
salvage
yard
sectors.
In
addition,
the
metal
finishing
survey
is
to
be
conducted
as
a
blind
voluntary
sample
such
that
the
identity
of
the
facility
submitting
survey
information
will
be
unknown
to
the
Agency.

3(
g)
Sensitive
Questions
The
surveys
and
site
visits
addressed
in
this
ICR
do
not
contain
any
sensitive
questions.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents
and
SIC
Codes
The
respondents
for
this
ICR
will
be
the
following:


Approximately
300
of
the
1,200
marinas
located
in
EPA
Region
1.
These
facilities
fall
under
SIC
code
4493.


Approximately
300
of
the
2,060
metal
finishers
located
in
EPA
Regions
1
and
5.
These
facilities
fall
under
SIC
code
347.


Approximately
300
construction
site
or
auto
salvage
yard
facilities
located
nationally.
Facilities
in
the
construction
site
sector
are
covered
by
SIC
codes
15­
17,
facilities
in
the
auto
salvage
yard
sector
are
covered
by
SIC
code
5015.

4(
b)
Information
Requested
The
marinas
mail
survey
and
site
visit
program
will
request
information
related
to
maintenance
practices
and
environmental
practices
conducted
at
marina
facilities.
The
metal
finishing,
construction
site,
and
auto
salvage
yard
mail
survey
and
site
visit
programs
will
obtain
information
required
to
assess
awareness
of
applicable
environmental
regulations
and
performance
with
respect
to
those
regulations.

Prior
to
conducting
the
surveys/
visits,
EPA
will
develop
a
sector­
specific
survey
instrument
to
be
used
to
identify
the
applicable
regulations
for
the
sector.
The
survey
instrument
will
address
the
following
types
of
topics,
depending
on
the
sector
selected:
10

Compliance
with
wastewater
discharge
permits
(
including
respondent's
wastewater
segregation
practices
and
wastewater
treatment
control);


Compliance
with
RCRA
requirements
(
including
respondent's
awareness
of
and
compliance
with
solid
and
hazardous
waste
requirements);


Compliance
with
air
regulations
(
respondent's
knowledge
of
and
compliance
with
air
requirements
for
their
facility);


Compliance
with
TRI
reporting
(
including
respondent's
understanding
of
how
to
identify
chemicals
or
estimate
releases
of
specific
chemicals);
and

Respondent's
awareness
of
compliance
assistance
tools
and
programs.

See
Part
B,
Section
2(
d)
for
the
specific
survey
instruments
developed
for
the
marina
and
metal
finishing
sectors.

4(
c)
Respondent
Activities
Mail
survey
respondent
activities
include
reviewing
the
mailed
survey
instructions
and
completing
the
mail
survey.
The
site
visit
respondent
activities
include
participating
in
an
estimated
four­
hour
site
visit
and
providing
sufficient
data
to
complete
the
survey/
checklist.

5.
THE
INFORMATION
COLLECTED:
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
Upon
approval
of
this
ICR,
EPA
(
or
its
contractor)
will
mail
out
the
marina
survey
to
approximately
200
marinas
in
Region
1
and
will
also
conduct
site
visits
to
collect
the
survey
information
from
approximately
100
additional
marinas.
EPA
will
create
a
database
to
track
survey
form
responses.
The
information
will
be
used
to
prepare
a
report
which
will
summarize
the
findings
and
make
recommendations
to
Regional
Managers
on
how
to
improve
compliance
assistance
activities
for
this
sector.
Following
compliance
assistance
projects,
EPA
Region
1
will
again
conduct
site
visits
to
collect
survey
information
from
approximately
100
marinas
to
assess
compliance
assistance
effectiveness.

Upon
approval
of
this
ICR,
EPA
OC
will
provide
management
oversight
for
contractor
staff
to
conduct
survey
mail­
outs
and
site
visits
to
approximately
300
metal
finishing
facilities
and
approximately
300
construction
site
or
auto
salvage
yard
facilities.
EPA's
contractor
will
create
a
database
to
track
survey
form
responses
and
will
prepare
a
final
report
to
present
the
findings
of
the
studies
and
evaluate
the
effectiveness
of
the
data­
gathering
approaches.
11
5(
b)
Collection
Methodology
and
Management
For
the
mail
and
site
visit
surveys,
information
will
be
collected
on
survey
forms
and
entered
into
a
database.
Data
entry
will
be
double
checked
to
ensure
accurate
data
transcription.
If
possible
for
the
site
visit
programs,
portable
electronic
devices
(
e.
g.,
laptop
computers
or
hand
held
devices)
will
be
used
to
enter
the
data
directly
into
a
database.

The
sector
databases
created
from
these
surveys
will
be
accessible
to
EPA
staff
and
will
be
made
publicly
available.

The
site
visit
survey
will
be
used
to
assess
the
quality
of
the
information
provided.
A
comparison
of
the
results
between
the
mailed
and
site
visit
surveys
will
give
EPA
a
sense
of
whether
respondents
are
providing
accurate
information
in
their
mailed
surveys
based
on
what
the
staff
conducting
the
site
visit
surveys
observe.

5(
c)
Small
Entity
Flexibility
The
marina,
metal
finishing,
and
construction
site/
auto
salvage
yard
surveys
should
have
minimal
impact
on
the
small
facilities
in
these
sectors
since
the
surveys
are
one­
time
information
requests
for
any
given
facility.
The
mailed
surveys
will
require
on
average
one
hour
per
facility
to
respond
and
the
site
visit
surveys
will
require
no
more
than
four
hours
per
facility
for
their
participation.

The
site
visit
program
is
designed
to
evaluate
environmental
performance
at
sectors
that
are
not
well­
represented
in
EPA's
databases.
One
of
the
reasons
that
the
sectors
are
not
well­
represented
is
that
they
comprise
small
facilities.
While
not
all
of
the
facilities
in
the
sectors
will
be
considered
small
businesses,
many
of
the
facilities
visited
will
be
small
businesses.
The
site
visit
program
will
therefore
be
conducted
to
account
for
the
size
of
the
facility.
EPA
anticipates
that
small
facilities
will
not
require
a
full
four
hours
for
the
site
visit,
but
instead
will
likely
require
only
one
to
two
hours
for
survey
completion.
Therefore,
EPA
has
built
small
entity
flexibility
into
the
site
visit
program
by
adapting
the
length
of
the
visit,
and
the
burden
on
the
facility,
to
the
size
of
the
facility.

5(
d)
Collection
Schedule
The
information
collection
activities
included
in
this
ICR
are
anticipated
to
occur
under
the
following
schedule
for
each
sector
covered:

Marina
Sector
Survey
to
be
mailed
out
within
one
month
of
ICR
approval
by
OMB.
Site
visits
to
be
conducted
within
three
months
of
ICR
approval
by
OMB.

Metal
Finishing
Sector
Survey
to
be
mailed
out
within
one
month
of
ICR
approval
by
OMB.
Site
visits
to
be
conducted
within
three
months
of
ICR
approval
by
OMB.
12
Construction
Site/
Auto
Salvage
Yard
Sector
Survey
to
be
mailed
out
within
six
months
of
ICR
approval
by
OMB.
Site
visits
to
be
conducted
within
six
months
of
ICR
approval
by
OMB.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
and
Costs
Table
1
presents
estimates
of
the
initial
respondent
burden
for
labor
hours
and
costs
associated
with
this
ICR.
There
is
no
recurring
respondent
burden
associated
with
this
ICR.
For
the
marina
survey,
which
includes
the
baseline
and
follow­
up
surveys,
the
facilities
will
be
selected
at
random.
For
this
sector,
there
is
a
chance
that
a
facility
may
be
randomly
selected
for
both
the
baseline
and
follow­
up
surveys.
The
assumptions
made
for
determining
the
respondent
burden
and
costs
are
footnoted
in
the
table.
No
capital
or
operations
and
maintenance
costs
are
incurred
by
respondents
under
this
ICR.

6(
b)
Estimating
Agency
Burden
Table
2
presents
estimates
of
the
initial
Agency
burden
(
including
contractor
support)
associated
with
this
ICR.
There
is
no
recurring
Agency
burden
associated
with
this
ICR.

6(
c)
Bottom
Line
Burden
and
Cost
Table
Table
3
presents
the
bottom
line
burden
hours
and
costs
for
respondents
and
EPA.
13
Table
1.
Initial
Respondent
Burden
and
Costs
Activity
Burden
Hours
and
Cost
Per
Recipient
Total
Burden
Hours
and
Cost
For
All
Recipients
(
b)

Labor
Hours
Costs
(
a)
Labor
Hours
Costs
(
a)

Marina
baseline
mailed
survey
completion
1
$
69.3
100
$
6,930
Marina
participation
in
baseline
site
visit
survey
4
$
277.2
400
$
27,720
Marina
participation
in
follow­
up
site
visit
survey
4
$
277.2
400
$
27,720
Metal
Finishing
facility
mailed
survey
completion
1
$
69.3
100
$
6,930
Metal
Finishing
facility
participation
in
site
visit
survey
4
$
277.2
400
$
27,720
Construction
Site/
Auto
Salvage
Yard
facility
mailed
survey
completion
1
$
69.3
100
$
6,930
Construction
Site/
Auto
Salvage
Yard
facility
participation
in
site
visit
survey
4
$
277.2
400
$
27,720
Total
1,900
$
131,670
(
a)
Assumes
a
$
69.3/
hr
rate
based
on
the
Bureau
of
Labor
Statistics
"
Employer
Costs
for
Employment
Compensation."
($
33/
hr
+
110%
overhead
=
$
69.3/
hr)
No
other
direct
costs
(
ODCs)
are
anticipated
for
the
sector
surveys.

(
b)
For
the
mailed
surveys
assumes
a
minimum
50%
response
rate
or
100
responses
out
of
200
sent
surveys.
(
See
Section
4(
b)
of
Part
B
for
the
basis
of
this
assumption)
For
the
site
visits,
assumes
that
a
maximum
of
100
visits
will
be
performed.
14
Table
2.
Initial
Agency
Burden
and
Costs
Sector
Activity
Costs
Labor
Other
Direct
Costs(
c)
Total
Costs
Hours
(
a)
Costs
(
b)

Marinas
Baseline
Survey
mailout
(
conducted
by
a
contractor)
268
$
12,700
$
880
$
13,580
Baseline
Survey
site
visits
600
$
21,000
$
21,000
Follow­
up
Survey
site
visits
600
$
21,000
$
21,000
Response
database
development
150
$
5,250
$
5,250
Data
analysis
and
report
100
$
3,500
$
3,500
Metal
Finishing
Sector
Agency
Management
80
$
2,800
$
2,800
Contractor
­
Survey
mailout(
d)
368
$
17,356
$
880
$
18,235
Contractor
­
Survey
site
visits
600
$
28,000
$
28,000
Contractor
­
database
development
150
$
6,150
$
6,150
Contractor
­
Final
Report
of
survey
responses
238
$
11,100
$
11,100
Construction
Site/
Auto
Salvage
Yard
Sector
Agency
Management
80
$
2,800
$
2,800
Contractor
­
Survey
mailout
268
$
12,700
$
880
$
13,580
Contractor
­
Survey
site
visits
600
$
28,000
$
28,000
Contractor
­
database
development
150
$
6,150
$
6,150
Contractor
­
Final
Report
of
survey
responses
100
$
4,650
$
4,650
Totals
4,352
$
185,795
(
a)
The
survey
mailout
estimate
assumes
labor
hours
for
a
five­
contact
approach
(
including
pre­
notice
letter,
mailed
survey,
post
mailout
reminder
card,
replacement
surveys,
and
a
final
contact
by
phone
for
nonresponders).
The
site
visit
estimate
assumes
100
visits,
4
hours
per
person
per
visit,
and
one
person
per
visit
for
50
trips
and
two
people
per
visit
for
50
trips.

(
b)
Agency
$/
hr
rate
is
based
on
a
1998
GS
13/
01
salary
of
$
55,969
or
$
26.91/
hr
with
a
30%
overhead.
The
resulting
hourly
rate
is
$
34.98/
hr.
The
contractor
labor
rates
are
based
on
contract
approved
labor
category
rates.

(
c)
Mailout
ODCs
include
copying
charges
and
postage
(
including
first
class
and
certified
mail
for
surveys
and
Federal
Express
charges
for
replacement
surveys).
Site
visit
costs
do
not
include
travel
costs.

(
d)
Includes
100
hours
for
a
survey
help
line
to
support
the
metal
finishers
mailed
survey.
15
Table
3.
Summary
of
Burden
and
Costs
to
Respondents
and
EPA
Category
Total
Labor
Hours
Total
Costs
($)

Initial
Respondent
Burden
1,900
$
131,670
Initial
Agency
Burden
1,610
$
56,350
Initial
Contractor
Burden
2,742
$
129,445
Total
6,252
$
317,465
6(
d)
Reasons
for
Changes
in
Burden
Since
this
is
a
new
information
collection,
there
is
no
change
in
burden
for
this
collection.

6(
e)
Burden
Statement
The
public
burden
is
estimated
to
average
1
hour
per
response
for
the
mailed
survey
and
4
hours
per
response
for
the
site
visit
survey.
This
estimate
includes
the
time
required
to
complete
the
surveys,
either
by
filling
them
out
and
returning
them
by
mail
or
by
participating
in
a
half
day
site
visit
to
answer
survey
questions
during
that
time.

Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
Agency.
This
includes
the
time
needed
to:


review
instructions;


develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;


adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;


train
personnel
to
be
able
to
respond
to
a
collection
of
information;


search
data
sources;


complete
and
review
the
collection
of
information;
and

transmit
or
otherwise
disclose
the
information.

An
Agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.

Send
comments
on
the
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques,
to
the
Director,
OEI
Collection
Strategies
Division,
U.
S.
16
Environmental
Protection
Agency
(
Mail
Code
2822),
401
M
Street,
S.
W.,
Washington,
D.
C.
20460;
and
to
the
Office
of
Management
and
Budget,
725
17th
Street,
N.
W.,
Washington,
D.
C.
20503,
Attention:
Desk
Officer
of
EPA.
Include
the
EPA
ICR
Number
(
2021.01)
in
any
correspondence.
17
Part
B
1.
OBJECTIVES,
KEY
VARIABLES,
AND
OTHER
PRELIMINARIES
1(
a)
Survey
Objectives
The
goals
for
each
of
the
surveys
covered
by
this
information
collection
request
are
summarized
below
by
sector:

Marina
Sector
To
determine
to
what
degree
key
environmental
practices
are
currently
in
use
at
Region
1
marinas
and
to
get
a
better
sense
of
the
compliance
challenges
faced
by
this
sector.
The
results
of
the
survey
will
be
used
to
establish
a
performance
baseline
at
the
start
of
the
marina
initiative
and
after
implementation
of
compliance
assistance,
the
follow­
up
survey
will
determine
progress
against
the
baseline.

Metal
Finishing
Sector
To
determine
a
performance
snapshot
of
this
sector
that
reflects
current
facility
performance
with
respect
to
key
federal
regulations
and
to
determine
the
compliance
assistance
tools
that
are
used
by
facilities
in
this
sector.

Construction
Site/
Auto
Salvage
Yard
Sector
To
determine
the
level
of
regulatory
awareness
of
the
sector
and
to
establish
a
performance
baseline
with
respect
to
key
federal
regulations.
Also
to
determine
the
need
for
compliance
assistance
tools
and
which
tools
are
most
accessible
and
useful.

1(
b)
Key
Variables
The
key
variables
in
each
survey
will
be
the
facility's
environmental
performance
with
respect
to
key
federal
regulations.
This
performance
measurement
will
be
determined
as
a
percentage
of
facilities
within
the
sector
with
good
environmental
performance
with
respect
to
each
key
federal
regulation.

1(
c)
Statistical
Approach
The
population
of
marinas
in
EPA
Region
1
is
approximately
1,200.
The
size
of
the
target
population
and
EPA
budget
constraints
require
a
statistical
analysis
using
a
subset
of
facilities
in
this
sector.
Section
2
describes
the
statistical
approach
in
detail.
EPA
OC
intends
to
use
contractor
support
for
the
baseline
survey
mailout
and
will
use
Region
1
personnel
for
the
site
visit
surveys,
database
development,
mail
survey
evaluation,
and
final
report
preparation
activities.
The
contractor
to
be
used
for
the
baseline
survey
mailout
is
Eastern
Research
Group
located
at
14555
Avion
Parkway,
Chantilly,
VA
20151.

The
population
of
metal
finishers
in
EPA
Regions
1
and
5
is
approximately
3,100.
The
size
of
the
18
target
population
and
EPA
budget
constraints
require
a
statistical
analysis
using
a
subset
of
facilities
in
this
sector.
Section
2
describes
the
statistical
approach
in
detail.
EPA
OC
intends
to
use
contractor
support
for
the
survey
mailout,
the
site
visit
surveys,
database
development,
and
final
report
preparation
activities.
The
contractor
to
be
used
for
these
activities
is
Eastern
Research
Group
located
at
14555
Avion
Parkway,
Chantilly,
VA
20151.

The
national
population
sizes
for
construction
sites
and
auto
salvage
yards
is
undetermined
but
will
number
in
the
thousands.
The
size
of
these
target
populations
and
EPA
budget
constraints
require
a
statistical
analysis
of
a
subset
of
facilities
in
either
of
these
sectors.
Section
2
describes
the
statistical
approach
in
detail.
EPA
OC
intends
to
use
contractor
support
for
the
survey
mailout
and
site
visit
surveys
that
might
be
conducted
for
one
of
these
sectors.
The
contractor
to
be
used
has
not
been
determined.

1(
d)
Feasibility
What
obstacles
might
the
respondent
face
in
completing
the
survey?

A
goal
of
the
surveys
is
to
assess,
for
each
sector,
environmental
regulatory
awareness
and
performance
with
respect
to
key
federal
regulations.
The
questions
have
been
structured
in
a
yes/
no
or
checklist
format
and
the
data
being
requested
should
be
readily
known
by
the
respondents.
In
some
cases
a
respondent
may
need
to
review
chemical
purchase
records
to
determine
whether
they
have
met
a
chemical
amount
threshold.
However,
these
types
of
questions
have
been
minimized
as
much
as
possible.

Are
sufficient
funds
available
to
complete
the
surveys
as
designed?

EPA
Region
1
has
indicated
that
regional
funds
are
available
for
the
site
visits
and
assessment
of
data
from
the
marinas
sector.
EPA
OC
has
already
funded
a
task
order
for
the
marina
and
metal
finishing
mailouts,
metal
finishing
site
visit
program,
and
final
report
preparation
tasks.
Funding
for
a
survey
of
the
construction
site
or
auto
salvage
yard
sectors
has
not
yet
been
appropriated.

Will
the
survey
results
be
ready
in
time
to
serve
the
program's
decision­
making
needs?

Assuming
OMB
approval
of
this
data
collection
within
six
months
of
the
first
FRN
notice
results
in
data
collection
from
the
marina's
sector
in
the
fall
of
2001.
Survey
results
from
that
work
will
then
be
available
for
potential
adjustments
to
compliance
assistance
projects
for
the
sector
scheduled
for
fourth
quarter
2001
and
2002.
For
the
metal
finishing
sector
and
the
construction
site/
auto
salvage
yard
sectors,
survey
results
are
required
for
EPA/
OECA
compliance
assistance
decisions
for
the
2002
and
beyond
time
frame.
19
2.
SURVEY
DESIGN
2(
a)
Target
Population
and
Coverage
A
discussion
of
the
target
populations
and
coverage
are
provided
by
sector
below:

Marina
Sector
For
the
marina
sector,
the
target
population
is
marinas
and
the
coverage
is
marinas
located
in
EPA
Region
1
states
(
CT,
ME,
MA,
NH,
RI,
VT).
This
subset
of
marinas
has
been
chosen
for
coverage
since
the
ICR
input
will
be
used
by
EPA
Region
1
in
their
marinas
initiative.

Metal
Finishing
Sector
For
the
metal
finishing
sector,
the
target
population
is
metal
finishing
facilities
covered
by
SIC
code
347.
The
coverage
will
be
focused
on
metal
finishing
facilities
located
in
EPA
Region
1
states
(
CT,
ME,
MA,
NH,
RI,
VT)
and
EPA
Region
5
states
(
IL,
IN,
MI,
MN,
OH,
WI).
This
subset
of
the
metal
finishing
population
has
been
chosen
for
coverage
since
EPA
OC
has
insufficient
funds
to
evaluate
facilities
nationally
and
focusing
on
a
few
EPA
regions
allows
for
economies
in
travel
costs
under
the
site
visit
survey
program.

Construction
Site/
Auto
Salvage
Yard
Sector
EPA
is
soliciting
comment
on
whether
compliance
assistance
needs
exist
for
either
the
construction
site
or
auto
salvage
yard
sectors.
Currently,
EPA
intends
to
evaluate
one
of
these
populations
on
a
national
basis
to
identify
those
regulatory
areas
that
are
problems
for
the
industry
sector.
Therefore,
the
coverage
would
be
all
facilities
in
the
sector
located
within
the
US.

2(
b)
Sample
Design
The
sampling
design
by
sector
to
be
surveyed
is
presented
below:

Marina
Sector
Sampling
Frame:
The
sampling
frame
for
this
sector
is
the
EPA
Region
1
marinas
which
have
been
identified
through
contacts
with
each
state's
coastal
zone
management
or
pollution
prevention
office.
Most
state
offices
maintain
marina
lists.
The
population
list
has
also
been
checked
against
marinas
identified
in
applicable
trade
journals.

Sample
Size:
Based
on
standard
statistical
sampling
techniques,
EPA
has
estimated
that
a
sample
size
of
between
88
and
92
facilities
will
be
required
to
estimate
a
performance
rate
for
Marinas.
To
arrive
at
this
range,
EPA
began
by
determining
the
appropriate
equation
for
determining
the
sample
size
for
estimating
a
sample
proportion.
EPA's
equation
can
be
written
as
1
This
equation
is
derived
by
first
setting
up
a
hypothesis
test
that
a
sampled
value
is
within
a
specified
confidence
interval
around
the
population
mean
and
then
solving
the
test
equation
for
n,
the
sample
size.

20
n
z
S
e
z
S
N
n
1
n
N
a
2
2
2
2
a
2
2
2
0
0
=
+
=
+
/

/

where
n
0
=
(
z2
 /
2)
S2/
e2,
n
is
the
sample
size,
N
is
the
population
size,
e
is
the
tolerable
error
(
precision),
z
 /
2
is
the
z­
score
for
 /
2
from
the
standard
normal
distribution,
(
1­
 )
is
the
confidence
level,
and
S2
is
the
variance
of
the
sample
proportion
we
are
estimating.
1
EPA
has
information
that
the
population
size
for
this
sector
could
be
between
1,000
and
2,000
facilities.
EPA
has
specified
a
confidence
level
of
95
percent
(
 
=
0.05),
implying
a
z
score
of
approximately
1.96,
and
a
tolerable
error
of
10
percent
age
points
(
e
=
0.1).
The
population
variance
of
a
proportion
mean
is
equal
to
p(
1­
p)
where
p
is
the
mean
value.
EPA
does
not
have
enough
information
to
assume
a
value
other
than
0.5
for
p.
This
assumption
produces
the
largest
estimate
of
S2
and
hence
of
the
sample
size.
EPA
used
each
of
these
assumptions
to
calculate
sample
sizes
for
a
population
of
1,000
facilities
and
a
population
of
2,000
facilities.
The
result
is
a
sample
size
range
of
88
to
92
facilities.

Stratification
Variables:
In
drawing
the
random
sample,
EPA
will
stratify
the
sample
size
among
the
New
England
states
based
on
the
proportion
of
facilities
in
each
state.
EPA
is
not
intending
to
make
comparisons
between
the
states
using
a
set
precision
or
calculate
a
valid
performance
rate
by
state
(
i.
e.,
EPA
is
not
drawing
a
valid
random
sample
for
each
state).
Rather,
EPA
is
stratifying
the
sample
to
ensure
representation
among
all
of
the
New
England
states.
EPA
has
not
yet
determined
the
specific
percentages
that
will
be
applied
to
each
state.
However,
EPA
does
have
a
list
of
marinas
in
New
England
from
which
this
determination
can
be
made.

Since
EPA
is
comparing
two
methodologies
(
mail
surveys
versus
site
visits),
EPA
will
draw
two
samples,
one
for
each
methodology.
In
this
manner,
EPA
will
be
able
to
calculate
valid
performance
rates
of
known
precision
for
each
method.

Sampling
Method:
EPA
will
conduct
the
surveys
on
this
sector
as
a
voluntary
random
sample.
EPA
will
assign
each
facility
a
random
number
(
using
a
random
number
generator
such
as
the
one
available
in
Microsoft
Excel)
and
then
sort
the
list
using
the
random
number.
The
first
x
facilities
in
this
sorted
list
will
constitute
the
random
sample,
where
x
is
derived
from
the
original
estimate
of
88
to
92
facilities
and
is
specified
below.

EPA
anticipates
at
least
a
50%
response
rate
on
the
mailed
surveys
using
a
five
step
contact
process
and
therefore
intends
to
mail
surveys
to
twice
as
many
facilities
as
are
required
by
the
statistically
valid
sample
size.
EPA
anticipates
that
each
facility
visited
in
the
site
visit
survey
will
2
It
should
be
remembered
that
EPA
will
draw
two
times
the
specified
range
to
cover
nonresponse
for
the
mail
survey.

21
result
in
a
completed
survey.
To
ensure
that
no
facility
appears
in
both
the
mailed
and
visited
samples,
EPA
will
draw
both
samples
simultaneously.
In
other
words,
EPA
will
draw
a
random
sample
of
between
264
and
276
facilities
(
i.
e.,
three
times
the
range
specified
above),
randomly
assigning
two­
thirds
of
the
sample
to
the
mail
survey
and
one­
third
to
the
site
visits.
2
In
the
event
that
some
marinas
do
not
agree
to
participate
in
the
site
visit
program,
EPA
will
continue
to
pull
facilities
from
the
sorted
list
of
facilities
until
the
desired
sample
size
is
attained
(
i.
e.,
88
to
92
facilities).
EPA
will
track
which
facilities
declined
to
participate
and
use
available
information
on
these
facilities
(
e.
g.,
size,
location,
etc.)
to
determine
if
some
nonresponse
bias
exists.

Metal
Finishing
Sector
Sampling
Frame:
The
sampling
frame
for
this
sector
is
EPA
Regions
1
and
5
metal
finishers
which
have
been
identified
through
The
Harris
Directory
and
listings
of
metal
finishing
indirect
dischargers
obtained
from
area
Publicly
Owned
Treatment
Works
(
POTW)
managers.

Sample
Size:
EPA
followed
the
same
methodology
and
assumptions
as
described
above
for
marinas
in
choosing
a
sample
size
for
the
metal
finishing
sector.
That
is,
EPA
used
the
equation
for
sample
size
above
and
specified
95
percent
confidence
and
ten
percentage
points
in
precision
and
then
assumed
that
the
default
compliance
rate
(
i.
e.,
null)
is
50
percent
(
p
=
0.5).
The
population
for
this
sector
ranges
from
2,000
to
4,000
facilities,
implying
a
sample
size
range
of
92
to
94
facilities.

As
with
the
marinas
sectors,
EPA
will
be
evaluating
two
different
methodologies.
Thus,
EPA's
contractor
will
draw
two
random
samples.
(
i.
e.,
one
for
each
methodology).

Stratification
Variables:
EPA
will
stratify
the
random
sample
by
both
state
and
size
(
e.
g.,
number
of
employees)
for
the
mail
survey
and
by
size
for
the
on­
site
survey.
For
the
mail
survey,
EPA
will
ensure
that
each
of
the
states
in
EPA
Region
1
(
CT,
ME,
MA,
NH,
RI,
VT)
and
EPA
Region
5
(
IL,
IN,
MI,
MN,
OH,
and
WI)
are
represented
in
the
mail
survey.
EPA
will
use
the
information
contained
in
the
sampling
frame
to
determine
the
percentages
for
each
state.
As
with
the
method
for
marinas,
EPA
is
not
intending
to
make
comparisons
between
states
or
size
ranges
with
known
precision,
but
is
only
concerned
with
ensuring
representation
for
all
metal
finishers
in
Regions
1
and
5.

EPA
will
stratify
only
by
size
for
the
on­
site
visits.
EPA
expects
to
make
two
size
classes
from
the
sample
frame:
"
large"
and
"
small"
facilities.
A
number
of
factors
may
be
relevant
for
the
size
of
these
facilities
and
EPA
will
perform
background
research
to
make
the
appropriate
size
class
distinction.
For
example,
the
number
of
employees
may
be
an
appropriate,
and
easily
determined,
3
That
is,
some
states
may
have
such
a
small
number
of
facilities
in
the
random
sample
making
the
site
visits
somewhat
costly
on
a
per­
site
basis.

22
size
distinction.
EPA
does
not
intend
to
make
statistical
comparisons
of
known
precision
between
the
size
classes,
rather
EPA
wants
to
ensure
that
both
size
classes
are
represented
in
the
site
visits.
EPA
is
not
stratifying
by
state
for
site
visits
under
this
sector
due
to
resource
constraints.
3
Sampling
Method:
EPA
will
conduct
the
surveys
on
this
sector
as
a
voluntary
random
sample.
EPA's
contractor
will
assign
each
facility
a
random
number
(
using
a
random
number
generator
such
as
the
one
available
in
Microsoft
Excel)
and
then
sort
the
list
using
the
random
number.
The
first
x
facilities
in
this
sorted
list
will
constitute
the
random
sample,
where
x
is
derived
from
the
original
estimate
of
92
to
94
facilities
and
is
specified
below.

EPA
anticipates
at
least
a
50%
response
rate
on
the
mailed
surveys
using
a
five
step
contact
process
and
therefore
intends
to
mail
surveys
to
twice
as
many
facilities
as
are
required
by
the
statistically
valid
sample
size.
EPA
anticipates
that
each
facility
visited
in
the
site
visit
survey
will
result
in
a
completed
survey.
To
ensure
that
no
facility
appears
in
both
the
mailed
and
visited
samples,
EPA's
contractor
will
draw
both
samples
simultaneously.

In
the
event
that
some
metal
finishers
do
not
agree
to
participate
in
the
site
visit
program,
EPA's
contractor
will
continue
to
pull
facilities
from
the
sorted
list
of
facilities
until
the
desired
sample
size
is
attained
(
i.
e.,
92
to
94
facilities).
EPA's
contractor
will
track
which
facilities
declined
to
participate
and
will
use
available
information
on
these
facilities
(
e.
g.,
size,
location,
etc.)
to
determine
if
some
nonresponse
bias
exists.

Construction
Site
or
Auto
Salvage
Yard
Sector
Sampling
Frame:
The
sampling
frame
for
these
sectors
will
be
construction
sites
or
auto
salvage
yards
located
nationally.
The
populations
for
these
sectors
are
currently
unknown
and
EPA
intends
to
use
double­
stage
cluster
sampling
to
assess
these
sectors.

Sample
Size:
EPA
will
follow
the
same
methodology
and
assumptions
as
described
above
for
marinas
in
choosing
a
sample
size
for
the
construction
site
or
auto
salvage
yard
sector.
That
is,
EPA
will
use
the
equation
for
sample
size
specified
above
and
specify
95
percent
confidence
and
ten
percentage
points
in
precision.
Furthermore,
EPA
expects
to
assume
that
the
default
compliance
rate
(
i.
e.,
null)
is
50
percent
(
p
=
0.5).
EPA
does
not
have
an
estimate
of
the
population
for
either
of
these
sectors,
but
since
10,000
facilities
would
require
a
sample
size
of
only
95
facilities
using
the
above
assumptions,
EPA
expects
to
have
a
sample
size
of
less
than
100
facilities
for
either
sector.

As
with
the
other
two
sectors,
EPA
will
be
evaluating
two
different
methodologies.
Thus,
EPA
will
draw
two
random
samples
of
the
same
size
(
i.
e.,
one
for
each
methodology).
4
EPA
will
do
this
by
drawing
both
set
of
clusters
simultaneously.

5
Based
on
resource
constraints,
EPA
has
determined
that
site
visits
should
occur
during
one
work
week
(
i.
e.,
five
days).
EPA
further
assumes
that
site
visits
will
require
four
hours
each.
Thus,
10
visits
can
be
performed
over
one
five
day
work
week.

6
Although
the
estimate
of
10
clusters
is
based
on
the
requirements
of
the
site
visits,
EPA
will
use
the
same
criteria
in
developing
the
sample
for
the
mail
survey.

23
Stratification
Variables:
EPA
does
not
have
sufficient
information
about
these
sectors
at
this
time
to
stratify
these
sector
populations
further
for
survey
purposes.

Sampling
Method:
EPA
will
choose
the
sample
for
the
construction
site
or
auto
salvage
yard
sectors
using
a
two­
stage
cluster
sampling
procedure.
EPA
is
using
this
method
since
the
populations
for
these
sectors
are
unknown.
Using
a
two­
stage
cluster
sample
will
allow
EPA
to
pull
a
valid
random
sample
from
the
target
population
while
decreasing
the
cost
associated
with
conducting
the
site
visits
and
mailing
surveys,
and
will
allow
the
Agency
to
efficiently
develop
a
sampling
frame
for
the
project.

To
do
this,
EPA
will
follow
statistical
guidelines
for
constructing
a
two­
stage
cluster
sample.
EPA
will
divide
the
United
States
into
distinct
geographic
clusters
(
e.
g.,
counties),
labeling
each
cluster
with
a
unique
identifier
code.
EPA
will
randomly
select
one
set
of
clusters
for
the
mail
survey
and
one
set
for
the
on­
site
visits,
assuring
no
repetition
between
the
two
surveys.
4
EPA
will
then
access
information
on
these
clusters
from
EPA
sources
(
e.
g.,
Regional
offices),
state
sources
(
e.
g.,
state
departments
of
environmental
protection),
or
local
records
(
e.
g.,
building
permits,
phone
directories,
The
Harris
Directory)
to
develop
a
sampling
frame
for
each
cluster.
EPA
will
then
select
a
random
sample
from
each
cluster.

EPA
has
determined
that
10
site
visits
can
be
conducted
during
one
trip
to
a
specific
area.
5
Thus,
assuming
an
upper­
bound
of
100
facilities
in
the
sample,
EPA
will
need
to
randomly
pull
10
clusters.
6
After
developing
the
sampling
frame
for
each
cluster,
EPA
will
pull
a
random
sample
from
each
cluster
following
the
procedures
outlined
under
both
the
marinas
and
metal
finishing
sectors.
That
is,
EPA
will
assign
each
facility
a
random
number
and
sort
by
that
random
number.
The
first
20
facilities
in
each
cluster
for
the
mail
survey
and
the
first
10
facilities
in
each
cluster
for
the
site
visits
will
constitute
the
random
sample
for
each
cluster.
As
with
the
marinas
and
metal
finishing
sectors,
if
some
facilities
decline
to
participate
in
the
site
visit
survey,
EPA
will
continue
to
pull
from
the
list
for
each
cluster
until
the
desired
sample
size
is
attained.
24
Sector
Required
Sample
Size
Number
of
Respondents
(
assuming
50%
response):
Mailed
Survey
Number
of
Respondents:
Site­
visit
Survey
Metal
Finishing
(
92­
94)
@
100
100
100
Marina
(
92­
94)
@
100
100
200
Construction
site/
Auto
Salvage
Yard
(
92­
94)
@
100
100
100
Total
300
400
2(
c)
Precision
Requirements
Precision
EPA's
sample
size
estimates
are
based
on
ten
percentage
points
in
precision
and
a
95
percent
confidence
level.
That
is,
EPA
will
be
95
percent
certain
that
the
estimated
results
will
be
within
plus
or
minus
10
percentage
points
of
the
actual
(
population)
results.
This
precision
will
allow
for
the
identification
of
trends
in
the
results.
Greater
precision
in
the
results
is
not
practical
since
the
required
sample
sizes
for
a
smaller
sampling
error
are
significantly
greater
and
beyond
the
budget
available
to
EPA
for
these
studies.

Nonresponse
Plan
EPA's
belief
is
that
nonresponse
is
best
handled
at
the
design
stage
of
a
survey,
rather
than
after
the
data
have
been
collected.
Despite
efforts
to
design
an
effective
survey
instrument,
however,
EPA
expects
some
level
of
nonresponse.
EPA's
strategy
to
reduce
nonresponse
for
this
survey
is
to
use
a
survey
design
that
will
minimize
the
incidence
of
nonresponse
and
to
use
a
follow­
up
strategy
to
collect
data
from
nonresponders.
Finally,
EPA
will
analyze
the
data
collected
under
the
survey
and
analyze
the
extent
to
which
nonresponse
may
bias
the
results.
This
nonresponse
plan
summarizes
EPA's
approach
to
dealing
with
two
forms
of
nonresponse:
unit
nonresponse
(
i.
e.,
when
a
survey
is
not
returned
from
a
sampled
facility)
and
item
nonresponse
(
i.
e.,
when
a
survey
is
returned,
but
some
data
elements
are
missing).
For
purposes
of
this
survey,
EPA
expects
that
unit
nonresponse
is
a
more
important
concern.

There
are
a
number
of
reasons
why
selected
facilities
may
not
respond
(
unit
or
item)
to
the
25
survey,
some
of
which
may
result
in
significant
biases
in
the
data
if
EPA
does
not
minimize
nonresponse
at
the
outset.
EPA
anticipates
five
major
reasons
for
potential
nonresponse:

1.
Strategic
nonresponse
 
Given
the
nature
of
the
questions
(
i.
e.,
evaluating
issues
related
to
compliance),
facilities
may
be
hesitant
to
return
surveys
or
to
complete
all
aspects
of
the
survey.
Thus,
facilities
may
elect
to
not
return
the
survey
if
they
believe
that
they
are
noncompliant.
Furthermore,
it
seems
reasonable
to
think
that
facilities
that
believe
they
are
compliant
would
be
more
likely
to
return
the
survey.
This
type
of
nonresponse
would
result
in
an
upward
bias
in
any
calculated
performance
measure.

2.
Mistrust
of
regulatory
agencies
 
Some
facilities
(
or
individuals
at
facilities)
may
have
an
inherent
mistrust
of
regulatory
agencies
regardless
of
their
compliance
status.
This
type
of
nonresponse
may
bias
results
if
compliance
is
correlated
with
facilities'
mistrust
of
regulatory
agencies.

3.
Burden
 
EPA
recognizes
facility
contact
persons
have
limited
time
to
complete
surveys.
In
most
cases,
the
respondent
will
need
to
make
time
to
respond
to
the
survey.
Thus,
some
unit
nonresponse
may
occur
because
the
facility
contact
does
not
have
the
time
to
respond.
Additionally,
some
item
nonresponse
may
occur
if
the
contact
does
not
have
time
to
complete
all
of
the
survey
questions.
This
type
of
nonresponse
may
bias
the
results
if
compliance
is
correlated
with
facilities'
willingness
to
make
time
to
respond.

4.
Lost
survey
instruments
 
Some
facilities
may
intend
on
completing
the
survey,
but
may
misplace
or
lose
it
before
they
are
able
to
find
the
time
to
complete
it.
This
type
of
nonresponse
may
bias
the
results
if
compliance
is
correlated
with
the
type
of
facilities
that
lose
the
survey
instrument.

5.
Out
of
business
 
Although
EPA
has
made
every
effort
to
develop
an
accurate
sampling
frame,
some
facilities
may
no
longer
be
in
business
and
therefore
cannot
respond.
These
facilities
would
no
longer
be
in
the
target
population
and
nonresponse
from
them
would
not
bias
the
estimates.

With
these
factors
in
mind,
EPA
has
designed
a
strategy
that
will
(
1)
reduce
the
number
of
initial
nonresponders
(
i.
e.,
those
that
do
not
respond
to
the
initial
survey
mailing)
and
(
2)
encompass
an
effective
follow­
up
strategy
to
obtain
information
from
initial
nonresponders.

To
reduce
the
number
of
nonresponders,
EPA
will
(
1)
focus
on
designing
a
survey
instrument
that
reduces
nonresponse
and
(
2)
use
a
multi­
staged
respondent
contact
process.
In
designing
the
survey
instrument,
EPA
will
focus
on
reducing
the
burden
to
the
respondents.
EPA
expects
that
the
data
requested
should
be
readily
available
to
the
respondents,
requiring
little
additional
research
on
their
part.
Additionally,
EPA
will
pre­
test
the
survey
on
a
subsample
of
no
more
than
26
nine
respondents.
EPA
will
use
feedback
from
the
pre­
test
to
revise
the
survey
instrument.

EPA
will
use
the
following
multi­
staged
respondent
contact
process
(
developed
by
Dillman).
This
process
encompasses
the
following
stages
(
Note
that
several
of
these
activities
will
be
performed
by
EPA's
contractor):

Stage
1
 
Prenotification.
At
this
stage,
EPA
will
send
the
contacts
a
letter
that
notifies
them
that
a
survey
will
be
sent
to
them.
The
letter
will
be
short
(
one
page)
and
will
explain
the
type
of
data
that
EPA
is
collecting,
why
EPA
is
collecting
the
data,
how
the
facilities
will
benefit
from
the
information
(
i.
e.,
better
targeted
compliance
assistance
strategy),
and
a
statement
of
EPA's
appreciation
if
they
participate
in
the
survey.
Additionally,
the
letter
will
attempt
to
assure
the
contacts
that
the
data
are
not
being
collected
for
enforcement
purposes.

Stage
2
 
Survey
Mail­
out.
EPA
will
mail
the
survey
to
respondents
one
week
following
the
prenotification
letter.
The
survey
packet
will
contain
a
cover
letter
reiterating
the
information
in
the
prenotification
letter,
the
survey
instrument,
contact
information
for
technical
support,
and
an
addressed
stamped
envelope
to
reduce
the
burden
of
returning
the
survey.

Stage
3
 
Reminder
Postcard.
EPA
will
mail
a
reminder
postcard
to
facilities
that
have
not
returned
a
survey
2
weeks
following
the
survey
mail­
out.
This
postcard
will
contain
contact
information
on
obtaining
a
replacement
survey.

Stage
4
 
Re­
mail
the
Survey.
EPA
will
re­
mail
copies
of
the
survey
to
facilities
that
have
not
returned
a
survey
2
weeks
following
the
reminder
postcard
mailing.
EPA
will
remail
the
same
components
as
the
initial
survey
mail­
out.

Stage
5
 
Follow­
up
Phone
Calls.
EPA
expects
that
the
instrument
design
combined
with
the
first
four
stages
of
this
contact
process
will
result
in
a
high
response
rate.
To
obtain
information
from
persistent
nonresponders,
EPA
will
attempt
to
make
telephone
contact
with
these
facilities
2
weeks
following
the
re­
mailing
of
the
survey.

As
a
final
stage
in
the
nonresponse
plan,
EPA
will
analyze
the
data
for
potential
nonresponse
biases.
EPA
will
stratify
the
responses
based
on
the
point
at
which
the
surveys
were
received
(
e.
g.,
initial
survey,
following
postcard,
following
re­
mail
of
survey,
following
phone
call).
EPA
will
then
analyze
the
key
data
elements
for
statistically
significant
differences
(
in
mean
and
variances)
among
these
response
groups.
Significant
differences
may
imply
some
degree
of
nonresponse
bias
in
the
data.
If
EPA
detects
differences,
EPA
will
use
an
acceptable
statistical
procedure
to
adjust
the
data
such
as
calculating
weighted
averages
and
variances
(
Lohr,
Sharon,
1999.
Sampling:
Design
and
Analysis,
Pacific
Grove,
CA:
Duxbury
Press.
Section
8.5)
to
reduce
the
influence
of
nonresponse
bias
on
the
estimated
statistics.
27
2(
d)
Questionnaire
Design
Marina
Survey
EPA
Region
1'
s
survey
for
the
marina
sector
is
included
here
as
Attachment
B.
The
marina
survey
is
designed
to
provide
general
information
on
performance
towards
key
environmental
regulations.
The
survey
requests
information
on
practices
related
to
stormwater
control,
oil
and
fuel
handling,
and
waste
management.

The
following
sections
provide
a
detailed
description
of
the
rationale
for
the
questions
in
the
survey.
The
first
two
questions
of
the
survey
request
general
information
about
the
marina's
size
and
whether
maintenance
and/
or
repair
operations
are
performed
at
the
facility.

Stormwater
Control
Questions
9
and
13
request
information
about
stormwater
control
at
marinas.
Stormwater
can
be
contaminated
with
pollutants
discharged
from
marina
operations
and
stormwater
flow,
through
both
point
and
nonpoint
sources
into
New
England
water
bodies.
Nonpoint
source
runoff
is
primarily
addressed
by
encouraging
Best
Management
Practices
(
BMP)
through
assistance
provided
to
marinas
in
each
coastal
state's
Coastal
Zone
Management
Program
(
CZMP).
Point
source
pollution
is
addressed
through
the
National
Pollutant
Discharge
Elimination
System
(
NPDES)
permit
program's
Stormwater
General
Permit
(
SGP)
which
requires
many
marinas,
primarily
those
with
vehicle
maintenance
and
repair
shops,
to
obtain
a
permit
and
develop
and
implement
a
pollution
prevention
plan
based
on
BMPs.
Not
many
marinas
in
New
England's
nondelegated
states
(
MA,
ME,
and
VT)
have
obtained
this
permit
and
there
is
concern
regarding
the
degree
to
which
marinas
understand
and
implement
NPDES
requirements
and
CZMP
guidance.

Oil
and
Fuel
Handling
Questions
4,
5,
and
6
relate
to
oil
and
fuel
handling.
The
primary
fuel
and
oil
spill
sources
are
boaters
who
may
spill
fuel
when
refueling
boats
and
marina
spills
from
boating
accidents,
tank/
pipe
leaks,
and
weather
events.
Marina
spills
are
primarily
addressed
through
boater
education,
the
Oil
Spill
and
Prevention
Regulations
(
OSPR)
associated
with
the
federal
Clean
Water
Act,
and
the
Resource
Conservation
and
Recovery
Act
(
RCRA)
.
Thus,
in
addition
to
conducting
boater
training,
many
facilities
have
regulatory
oil
and
fuel
requirements
to
meet.
For
example,
many
of
those
with
aboveground
tanks
(
i.
e.,
660
gallons
or
more)
must
prepare
and
implement
a
BMP­
based
Spill
Prevention
Control
and
Countermeasure
Plan
(
SPCC)
under
OSPR,
and
all
of
those
with
underground
storage
tanks
must
conduct
testing
and
monitoring
under
RCRA.
EPA
Region
1
will
assess
the
degree
to
which
marinas
and
boaters
know
and
implement
regulatory
requirements
and
BMPs
through
these
questions
of
the
survey.

Waste
Management
28
Questions
3,
7,
8,10,
11,
and
12
address
waste
management
activities
at
marinas.
On
aggregate,
marinas
generate
significant
amounts
of
hazardous
waste.
This
is
primarily
from
boat
maintenance
activities
and
marina
customers
who
dispose
hazardous
waste
at
the
marina.
The
primary
pollutants
are
paints,
cleaning
products,
heavy
metals,
solvents,
oils,
and
fuels.
Improper
handling
may
cause
these
products
to
be
improperly
disposed
adversely
affecting
landfills,
stormwater,
air,
and
soil.
Hazardous
waste
is
addressed
primarily
through
the
RCRA
regulations,
and
other
requirements
including:
NPDES,
SPCC,
and
CZMP.
EPA
Region
1
will
assess
the
degree
to
which
marina
owners
understand
hazardous
waste
regulations
and
guidance
through
these
questions
of
the
survey.

Metal
Finishing
Survey
EPA/
OC's
survey
for
the
metal
finishing
sector
is
included
here
as
Attachment
C.
This
survey
consists
of
two
components.
The
first
is
the
mailed
survey,
that
will
also
be
used
during
the
site
visits.
This
survey
will
be
used
to
obtain
the
information
to
evaluate
performance
towards
key
federal
regulations
and
to
evaluate
the
impacts
of
compliance
assistance.
The
second
component
is
a
checklist
that
will
be
used
during
the
site
visit
to
verify
information
obtained
through
the
survey.
This
checklist
will
expand
on
certain
elements
of
the
survey
that
can
be
confirmed
via
visual
inspection.

The
metal
finishing
survey
is
designed
to
provide
general
information
on
performance
towards
key
environmental
regulations.
The
survey
requests
information
on
wastewater
generation
and
treatment,
hazardous
waste
handling,
control
of
air
emissions,
and
Toxic
Release
Inventory
(
TRI)
reporting
requirements.
In
addition,
the
survey
asks
general
questions
about
how
compliance
information
is
obtained
by
metal
finishers.

The
survey
is
broken
into
the
following
sections:


Section
1
­
Wastewater
Treatment:
This
section
asks
questions
about
the
type
of
wastewaters
generated
and
wastewater
treatment
used
to
evaluate
performance
towards
wastewater
discharge
limits.
This
section
also
asks
questions
about
the
site's
wastewater
monitoring
and
reporting,
as
well
as
compliance
assistance
received
by
the
site
regarding
wastewater
generation
and
treatment.


Section
2
­
Hazardous
Waste
Handling:
The
hazardous
waste
handling
section
requests
information
to
evaluate
performance
towards
requirements
of
the
Resource
Conservation
and
Recovery
Act
(
RCRA).
This
section
also
asks
questions
about
compliance
assistance
received
by
the
site
regarding
hazardous
waste
handling.


Section
3
­
Air
Emissions:
This
section
requests
information
to
evaluate
performance
towards
the
chromium
electroplating
MACT
standards
and
the
solvent
degreasing
NESHAP
standards.
This
section
also
asks
questions
about
29
compliance
assistance
received
by
the
site
regarding
air
emission
regulations.


Section
4
­
TRI:
This
section
requests
information
to
evaluate
performance
towards
the
Toxic
Release
Inventory
reporting
requirements.
This
section
also
asks
questions
about
compliance
assistance
received
by
the
site
regarding
TRI
reporting.


Section
5
­
General
Information:
This
section
asks
about
resources
used
to
obtain
compliance
information,
what
types
of
sources
would
be
most
helpful,
and
the
number
of
employees
on
site.

The
following
sections
provide
a
detailed
description
of
the
rationale
for
the
questions
in
the
survey.

Question
1
­
Environmental
Awards
Question
1
starts
the
survey
by
asking
the
site
to
identify
if
they
have
received
any
awards
for
environmental
performance.
This
question
will
be
used
to
evaluate
if
there
is
a
connection
between
recognized
"
good
performers"
and
compliance
assistance
received
by
those
performers.

Section
1
­
Wastewater
Treatment
Questions
2
through
4
ask
about
the
types
of
wastewater
generated
on­
site.
This
information
will
be
used
to
determine
which
types
of
treatment
are
applicable
to
the
site.
Question
5
asks
the
site
to
check
all
types
of
wastewater
treatment
used.
Question
6
asks
if
the
site
has
a
wastewater
discharge
permit,
while
Question
7
asks
if
the
site
conducts
monitoring,
sampling,
and
reporting
of
their
wastewater
discharges.
These
questions
assess
whether
the
site
has
the
necessary
permits
and
appears
to
be
monitoring
and
reporting
as
required
by
the
applicable
effluent
guidelines
regulations.
Questions
8
and
9
ask
if
the
site
has
received
compliance
assistance
regarding
wastewater
generation
and
treatment.
Question
10
asks
if
there
are
wastewater
regulations
for
which
the
site
would
like
additional
compliance
assistance,
while
Question
11
asks
the
site
to
identify
the
sources
it
uses
to
obtain
information
on
wastewater
regulations
and
pollution
prevention.
Questions
8
through
11
will
help
determine
how
to
assist
sites
in
complying
with
wastewater
regulations.

Section
2
­
Hazardous
Waste
Handling
Questions
12
through
26
request
information
on
hazardous
waste
handling
practices
to
evaluate
the
site's
performance
towards
key
RCRA
requirements.
Question
12
asks
if
the
site
generates
hazardous
waste,
such
as
F006
wastewater
treatment
sludge.
Question
13
asks
if
the
amount
of
hazardous
waste
generated
exceeds
100
kilograms
per
month.
Compliance
requirements
depend
on
the
amount
of
waste
generated.
Question
14
asks
how
long
the
hazardous
waste
is
maintained
on
site,
to
evaluate
compliance
with
RCRA
storage
requirements.
Questions
15
through
17
ask
if
30
the
site
is
aware
of
hazardous
waste
labeling
requirements
for
drums,
and
if
these
apply
to
the
site.
Questions
18
and
19
ask
if
the
site
is
aware
of
hazardous
waste
manifest
records
requirements,
and
if
these
apply
to
the
site.
Questions
20
and
21
asks
if
the
site
inspects
their
hazardous
waste
storage
area,
and
if
so,
how
often.
Question
22
asks
if
the
site
has
a
hazardous
waste
contingency
plan.
Questions
14
through
22
are
intended
to
obtain
information
to
evaluate
performance
towards
key
RCRA
requirements.
Questions
23
and
24
ask
if
the
site
has
received
compliance
assistance
regarding
RCRA
requirements.
Question
25
asks
if
there
are
hazardous
waste
regulations
for
which
the
site
would
like
additional
compliance
assistance,
while
Question
26
asks
the
site
to
identify
the
sources
it
uses
to
obtain
information
on
hazardous
waste
regulations
and
pollution
prevention.
Questions
23
through
26
will
help
determine
how
to
assist
sites
in
complying
with
hazardous
waste
regulations.

Section
3
­
Air
Emissions
Questions
27
through
34
ask
questions
about
the
chromium
electroplating
and
anodizing
maximum
achievable
control
technology
(
MACT)
standards.
These
questions
will
identify
whether
the
site
is
impacted
by
the
MACT
standards
and
what
emission
controls
are
used
on
site.
Question
27
asks
if
the
site
performs
chromium
electroplating
or
chromic
acid
anodizing.
Question
28
asks
how
many
chromium
electroplating
and
anodizing
tanks
are
on
site.
Question
29
asks
if
site
personnel
are
aware
of
EPA
emission
control
requirements,
while
Question
30
asks
how
many
tanks
use
some
type
of
emission
control.
Question
31
asks
the
site
to
identify
the
types
of
control
technologies,
as
well
as
the
technologies
for
which
the
site
monitors
performance.
Questions
32
through
34
ask
the
site
to
identify
the
types
of
compliance
assistance
received
regarding
the
chromium
MACT
standard.
This
will
help
determine
how
to
assist
sites
in
complying
with
the
MACT
standard.

Questions
35
through
46
focus
on
the
national
emission
standards
for
hazardous
air
pollutants
(
NESHAP)
for
halogenated
solvent
cleaning
(
59
FR
61801)
and
what
the
site
has
done
to
comply
with
this
standard.
The
NESHAP
applies
to
individual
machines
rather
than
to
an
entire
site.
Question
35
asks
the
site
if
they
own
or
operate
any
solvent
cleaning
machines.
This
question
will
identify
sites
that
fall
under
this
rule.
Question
36
asks
for
further
details
about
the
types
of
solvents
used
on­
site.
The
halogenated
solvent
cleaning
rule
applies
only
to
cleaning
machines
that
contain
a
solvent
containing
5%
or
more
by
weight
of
any
one
or
combination
of
these
solvents:
carbon
tetrachloride,
chloroform,
perchloroethylene,
1,1,1­
trichloroethane,
trichloroethylene,
and
methylene
chloride.
Question
37
asks
for
the
types
of
solvent
cleaning
machines
used
on
site.
Question
38
asks
if
site
personnel
are
aware
of
EPA
emission
standards,
while
Question
39
asks
if
these
standards
apply
to
the
site's
solvent
degreasing
machines.
Question
40
asks
which
methods
the
site
uses
to
comply
with
the
solvent
cleaning
NESHAP.
Since
the
NESHAP
is
on
a
machine
basis
rather
than
a
site
basis,
the
site
may
use
more
than
one
method
of
complying
with
the
NESHAP.
Several
sources
of
information
are
available
on
the
solvent
degreasing
NESHAP.
Questions
41
through
44
ask
what
sources
of
information
the
site
has
used
to
obtain
compliance
assistance.
Question
45
asks
if
there
are
air
regulations
with
which
the
site
would
like
additional
assistance,
and
question
46
asks
what
sources
of
information
on
air
31
regulations
and
pollution
prevention
the
site
uses.
Questions
41
through
46
will
help
determine
how
to
assist
sites
in
complying
with
the
NESHAP.

Section
4
­
TRI
Reporting
Requirements
Question
47
asks
if
the
site
is
aware
of
TRI
reporting
requirements,
while
Question
48
asks
if
the
site
is
exempt
from
TRI
reporting.
These
questions
will
assess
the
site's
understanding
of
the
reporting
requirements.
Questions
49
and
50
ask
if
the
site
has
received
compliance
assistance
regarding
TRI
reporting.
Question
51
asks
if
there
are
TRI
reporting
requirements
for
which
the
site
would
like
additional
compliance
assistance,
while
Question
52
asks
the
site
to
identify
the
sources
it
uses
to
obtain
information
on
TRI
reporting
requirements.
Questions
49
through
52
will
help
determine
how
to
assist
sites
in
complying
with
TRI
reporting
requirements.

Section
5
­
General
This
section
asks
general
questions
about
the
types
of
compliance
information
that
is
used
by
the
site
or
that
would
be
helpful
to
the
site.
These
questions
will
allow
EPA
OC
to
determine
which
facilities
have
received
compliance
assistance
and
which
have
not.
Question
53
asks
if
the
site
has
Internet
access.
This
question
will
determine
if
web­
based
assistance
would
be
available
to
the
site.
Questions
54
through
57
ask
about
the
National
Metal
Finishing
Resource
Center.
Responses
to
these
questions
will
help
to
identify
if
facilities
are
aware
of
this
compliance
assistance
tool.
The
questions
ask
for
the
type
of
information
obtained
from
the
center
and
whether
it
was
useful.
Question
58
asks
the
site
to
identify
types
of
compliance
assistance
tools
that
are
helpful
in
order
to
assist
EPA
in
identifying
appropriate
tools
for
this
sector.
Question
59
asks
whether
the
site
is
aware
of
the
National
Metal
Finishing
Strategic
Goals
Program.
Question
60
asks
for
the
number
of
employees
working
at
the
site.
This
question
will
be
used
to
evaluate
trends
by
size
(
as
defined
by
number
of
employees)
in
compliance
assistance
received
and
performance
towards
key
federal
regulations.

The
site
visit
checklist,
also
included
in
Attachment
C,
will
provide
additional
information
regarding
hazardous
waste
handling
and
wastewater
treatment
operations.
This
information
will
be
used
to
confirm,
via
visual
inspection,
information
provided
in
the
survey.
During
the
site
visit,
the
on­
site
personnel
will
check
those
items
on
the
checklist
that
are
true.
Section
1
of
the
checklist
contains
15
items
that
will
be
evaluated
by
the
on­
site
personnel
related
to
hazardous
waste
handling
procedures
(
e.
g.,
drum
labeling,
waste
storage,
storage
area
inspection).
Section
2
of
the
checklist
contains
three
items
that
will
be
evaluated
by
the
on­
site
personnel
related
to
wastewater
generation
and
treatment
(
e.
g.,
condition
of
wastewater
conveyance
systems,
handling
of
wastewater
treatment
sludge).

Construction
Site/
Auto
Salvage
Yard
Survey
The
construction
site
or
auto
salvage
yard
survey
will
be
designed
after
EPA
makes
a
determination
on
which
sector
to
survey.
The
survey
will
be
designed
to
provide
general
32
information
on
performance
towards
key
environmental
regulations.
The
survey
will
request
information
on
topics
such
as
stormwater
control
measures,
waste
management
including
hazardous
waste
handling
practices,
and
Emergency
Planning
and
Community
Response
Act
(
EPCRA)
requirements.
In
addition,
the
survey
will
ask
general
questions
about
how
compliance
assistance
information
is
obtained
by
operators
in
these
sectors.

3.
PRETESTS
AND
PILOT
TESTS
EPA
Region
1
(
for
the
marina
survey)
will
conduct
a
pre­
test
of
their
survey
on
no
more
than
nine
facilities
within
the
marina
sector.

EPA
Region
1
and
OC
conducted
a
pretest
of
the
metal
finishing
survey
to
four
metal
finishing
sites
in
Region
1.
All
pretest
respondents
stated
that
the
survey
was
easy
to
follow
and
to
complete,
with
one
respondent
stating
that
the
survey
required
20
minutes
to
complete.
One
respondent
felt
that
some
of
the
questions
related
to
hazardous
waste
handling
were
"
self
incriminating"
and
that
recipients
may
not
complete
these
questions.
This
concern
was
consistent
with
issues
raised
during
consultation
with
metal
finishing
industry
representatives;
OC
modified
the
survey
to
address
this
issue
by
focusing
more
on
awareness
of
regulations.

EPA
will
conduct
a
pre­
test
of
the
construction
site
or
auto
salvage
yard
surveys
on
no
more
than
nine
facilities
within
the
selected
sectors.

4.
COLLECTION
METHODS
AND
FOLLOW­
UP
4(
a)
Collection
Methods
For
each
sector
survey,
EPA
intends
to
conduct
two
types
of
collection
methods.
The
first
is
a
mailed
survey
method
which
includes
a
five­
stage
contact
process
described
in
Section
2(
c)
above.
In
addition,
for
each
sector
EPA
intends
to
also
conduct
survey
collection
through
a
site
visit
program.
These
collection
methods
have
been
chosen
to
address
one
of
EPA's
goals
in
the
ICR,
which
is
to
compare
the
burden
and
response
rates
typical
by
each
method
for
multiple
industrial
sectors.

4(
b)
Survey
Response
and
Follow­
up
For
the
mailed
surveys,
EPA
expects
a
minimum
response
rate
of
50%.
This
minimum
response
rate
is
based
on
an
average
"
total
design
method"
response
rate
of
approximately
75%
(
How
to
Conduct
Your
Own
Survey,
Salant,
P.,
and
Dillman,
D.,
John
Wiley
&
Sons,
Inc.,
1994,
pg.
27)
and
conservatively
adjusting
this
rate
down
to
take
into
account
the
nature
of
the
survey
(
related
to
regulatory
compliance)
and
the
administering
entity
(
EPA).
The
mailed
survey
approach
will
include
a
five­
stage
contact
process
and
will
use
multiple
contact
mechanisms
(
e.
g.,
first
class
mail
for
the
initial
surveys
sent
out,
federal
express
shipping
for
replacement
surveys,
and
phone
contacts
as
a
final
contact
attempt).
This
approach
has
been
well
studied
and
has
been
shown
to
33
increase
response
rates.
In
addition
EPA's
contractor
will
attempt
to
call
back
facilities
that
have
supplied
incomplete
or
illegible
data
to
minimize
unit
nonresponse.

For
the
site
visit
survey,
EPA
expects
to
achieve
a
completed
survey
for
each
site
visited.
Survey
data
will
be
recorded
on
paper
survey
forms.
In
the
case
of
the
metal
finishing
site
survey,
EPA
intends
to
evaluate
the
use
of
laptops
or
hand­
held
electronic
devices
for
electronic
recording
of
survey
results.

5.
ANALYZING
AND
REPORTING
SURVEY
RESULTS
5(
a)
Data
Preparation
For
each
survey,
EPA
or
their
contractor
will
enter
the
survey
results
into
an
electronic
database
using
off­
the­
shelf
software
(
e.
g.,
Microsoft
Access).
The
data
entry
will
be
double
checked
to
ensure
that
data
were
entered
accurately
and
missing
data
items
will
be
flagged.
EPA
or
their
contractor
will
attempt
to
collect
any
missing
data
items
through
phone
contacts
with
the
facilities
(
in
the
case
of
the
metal
finishing
sector
this
phone
contact
will
occur
through
EPA's
contractor
since
it
will
be
a
blind
survey).

5(
b)
Analysis
The
survey
results
will
be
analyzed
to
determine:


Each
site's
performance
against
key
environmental
regulations.
(
For
example,
based
on
chemical
usage
and
tank
sizes,
EPA
will
be
able
to
assess
how
many
of
the
facilities
sampled
within
a
sector
should
have
a
spill
prevention
and
control
plan
versus
how
many
of
these
facilities
indicated
that
they
did
have
such
a
plan.)


Trends
within
a
sector
based
on
an
evaluation
of
results
across
various
parameters
(
such
as
number
of
employees
or
processes
performed).
For
the
metal
finshing
sector,
EPA
OC
intends
to
evaluate
environmental
performance
on
key
regulations
between
facilities
that
have
received
compliance
assistance
and
those
which
have
not.


Key
environmental
problem
areas
where
a
majority
of
facilities
sampled
appear
to
be
unaware
of
or
potentially
noncompliant
with
a
particular
requirement.


Compliance
assistance
outreach
methods
preferred
by
the
facilities.

To
look
at
these
issues,
EPA
will
employ
a
variety
of
statistical
techniques,
including
Equivalency
testing
 
EPA
will
use
standard
hypothesis
tests
for
the
equivalency
between
two
means
to
test
for
differences
in
the
results
between
different
characteristics
(
e.
g.,
strata)
in
each
sample
and
to
test
for
differences
between
the
mailed
and
site
visit
surveys.
34
Analysis
of
variance
 
EPA
will
use
analysis
of
variance
(
ANOVA)
techniques
to
explore
the
sources
of
variation
in
the
data.
For
example,
the
metal
finishing
sector
will
produce
a
set
of
facilities
that
use
different
processes.
EPA
will
use
a
standard
one­
way
ANOVA
to
look
for
significant
differences
in
results
among
the
various
processes.
Additionally,
EPA
may
employ
a
multiple
factor
ANOVA
to
look
for
significant
differences
across
both
the
process
types
and
survey
methods
(
i.
e.,
did
the
survey
method
contribute
to
finding
significant
differences
among
the
process
types).

Other
 
EPA
will
explore
the
use
of
other
techniques
such
as
correlation
analysis
or
regression
analysis.
One
potentially
fruitful
analysis
may
be
discriminant
analysis
which
attempts
to
derive
reliable
predictors
for
a
certain
variable.
For
example,
EPA
may
be
able
to
use
discriminant
analysis
to
determine
that
a
set
of
four
factors,
when
combined
in
a
certain
way,
almost
always
lead
to
environmental
performance
problems
for
facilities.
This
would
be
particularly
useful
if
the
four
factors
are
easily
observable
since
environmental
performance
is
generally
not
easily
observable.

One
purpose
of
this
sampling
will
be
to
compare
the
mailed
surveys
with
the
site
visit
surveys.
EPA
will
have
greater
confidence
in
the
site
visit
survey
responses
since
the
survey
takers
will
be
able
to
verify
that
the
responses
given
are
correct.
Thus,
some
of
EPA's
analysis
will
be
a
comparison
between
the
two
survey
methods.
This
portion
of
the
analysis
will
assume
that
the
site
visit
surveys
are
more
accurate
than
the
mailed
surveys
and
will
benchmark
the
mailed
surveys
against
the
site
visit
surveys.
EPA
will
able
to
assess
the
quality
and
accuracy
of
the
information
collected
using
mailed
surveys.
This
information
can
be
used
to
(
1)
redesign
future
mailed
surveys,
(
2)
provide
justification
for
use
of
one
method
over
another,
and
(
3)
determine
the
probable
error
(
if
any)
in
other
mailed
surveys
(
e.
g.,
if
EPA
finds
that
mailed
surveys
consistently
over­
state
compliance
by
20
percent,
then
the
Agency
has
some
information
on
the
potential
overestimate
from
similar
mailed
surveys).

In
addition,
EPA
will
assess
the
actual
burden
(
respondent
and
agency)
required
to
solicit,
respond,
and
review
surveys
by
each
collection
method
(
mailed
versus
site
visit).
EPA
will
be
able
to
use
this
information
in
preparing
more
accurate
future
ICRs
or
in
re­
designing
future
surveys
to
reduce
burden.

5(
c)
Reporting
Results
Each
set
of
survey
results
will
be
summarized
and
documented
in
a
sector­
based
report.
The
reports
will
be
made
available
to
other
Agency
personnel
and
to
the
public.
The
databases
developed
under
these
survey
activities
will
be
publicly
available
upon
request.
35
Attachment
A
ICR
First
Federal
Register
Notice
Burden
Statement
The
public
burden
is
estimated
to
average
1
hour
per
response
for
the
mailed
survey
and
4
hours
per
response
for
the
site
visit
survey.
This
estimate
includes
the
time
required
to
complete
the
surveys,
either
by
filling
them
out
and
returning
them
by
mail
or
by
participating
in
a
half
day
site
visit
to
answer
survey
questions
during
that
time.

Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
Agency.
This
includes
the
time
needed
to:


review
instructions;


develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;


adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;


train
personnel
to
be
able
to
respond
to
a
collection
of
information;


search
data
sources;


complete
and
review
the
collection
of
information;
and

transmit
or
otherwise
disclose
the
information.

An
Agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.

Send
comments
on
the
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques,
to
the
Director,
OEI
Collection
Strategies
Division,
U.
S.
Environmental
Protection
Agency
(
Mail
Code
2822),
401
M
Street,
S.
W.,
Washington,
D.
C.
20460;
and
to
the
Office
of
Management
and
Budget,
725
17th
Street,
N.
W.,
Washington,
D.
C.
20503,
Attention:
Desk
Officer
of
EPA.
Include
the
EPA
ICR
Number
(
2021.01)
in
any
correspondence.
36
37
Attachment
B
EPA
Region
1
Marina
Survey
Burden
Statement
The
public
burden
is
estimated
to
average
1
hour
per
response
for
the
mailed
survey
and
4
hours
per
response
for
the
site
visit
survey.
This
estimate
includes
the
time
required
to
complete
the
surveys,
either
by
filling
them
out
and
returning
them
by
mail
or
by
participating
in
a
half
day
site
visit
to
answer
survey
questions
during
that
time.

Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
Agency.
This
includes
the
time
needed
to:


review
instructions;


develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;


adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;


train
personnel
to
be
able
to
respond
to
a
collection
of
information;


search
data
sources;


complete
and
review
the
collection
of
information;
and

transmit
or
otherwise
disclose
the
information.

An
Agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.

Send
comments
on
the
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques,
to
the
Director,
OEI
Collection
Strategies
Division,
U.
S.
Environmental
Protection
Agency
(
Mail
Code
2822),
401
M
Street,
S.
W.,
Washington,
D.
C.
20460;
and
to
the
Office
of
Management
and
Budget,
725
17th
Street,
N.
W.,
Washington,
D.
C.
20503,
Attention:
Desk
Officer
of
EPA.
Include
the
EPA
ICR
Number
(
2021.01)
in
any
correspondence.
38
United
States
Environmental
Protection
Agency,
Region
One
New
England
DRAFT
Environmentally
Responsible
Marina
Checklist
This
is
a
checklist
of
important
environmental
practices.
It
is
designed
to
help
marinas
improve
environmental
performance.
It
does
not
cover
everything:
it
is
a
screening
checklist
to
highlight
selected
areas
pertaining
to
recreational
boating.

FOR
ALL
QUESTIONS,
PLEASE
USE:
Y
for
Yes
N
for
No
DK
for
Don't
Know
NA
for
Not
Applicable
1.
a.
How
many
employees
work
at
the
facility?
Full­
time
___
Part­
time
___
b.
How
many
boats
are
moored
at
the
facility?
___
Docked?
___
Stored
on
land?
___

2.
a.
Are
maintenance
and/
or
repair
operations
performed
at
the
facility?
___
b.
If
yes,
are
these
primarily
customer
do­
it­
yourself
repair
and
maintenance?
___

Some
of
the
practices
referred
to
in
the
following
questions
are
requirements
of
law.
For
further
information,
see
EPA
Region
One's
"
Marina
Environmental
Performance
Guide".

3.
a.
Quantities
of
hazardous
waste
generated
by
the
marina
each
month
are
calculated,
to
determine
whether
the
marina
is
a
large
or
small
generator.
____
b.
All
hazardous
wastes
are
in
labeled
containers
in
a
dedicated
storage
area.
____
c.
The
storage
area
has
an
impervious
surface
and
spill
containment
(
such
as
berms).
____
d.
All
hazardous
wastes
are
shipped
with
a
properly
licensed
transporter.
___
e.
Manifests
documenting
hazardous
waste
shipments
are
kept,
going
back
at
least
3
years.
____
f.
The
facility
has
an
active,
ongoing
effort
to
reduce
the
generation
of
hazardous
waste.
____
g.
Employees
receive
training
in
proper
handling
of
wastes
and
in
emergency
procedures.____
h.
Used
antifreeze
and
oil
are
sent
for
recycling,
not
disposal.
____

4.
Oil
(
including
motor
fuel)
is
stored
above
ground
in
any
single
tank
over
660
gallons?
____
Above
ground
in
total
aggregate
volume
over
1320
gallons?
____
below
ground
in
total
aggregate
volume
of
42000
gallons?
____

5.
a.
Oil
storage
has
containment
____
b.
Spill
prevention
procedures
are
in
place
for:
receiving
oil
from
a
supplier
____
transferring
oil
within
the
facility
____
waste
oil
disposal
_____
c.
A
Spill
Prevention,
Control
and
Countermeasure
plan
(
SPCC),
signed
by
a
registered
professional
engineer,
is
on
site
and
posted
in
plain
view
at
oil
storage
locations.
____

6.
Does
the
facility
have
spill
prevention
procedures
in
place
for
fuel
dispensing?
____
Do
fuel
dispensing
operations
have
spill
protection?
____
system
has
overfill
alarm
___
containment
is
in
place
in
case
of
a
spill
___
other
_________________________________
b.
If
boaters
operate
the
facility's
fuel
dispensing
equipment,
is
this
monitored
at
all
times?
___

7.
a.
Has
the
amount
of
each
hazardous
material
stored
onsite
been
calculated,
to
determine
if
reporting
to
39
the
Local
Emergency
Planning
Committee
is
necessary?
____
8.
Are
Material
Safety
Data
Sheets
for
all
hazardous
chemicals
kept
on
file,
and
used
for
training
all
employees
handling
hazardous
chemicals?
_____

9.
Is
a
storm
water
discharge
permit
required
of
this
facility?
______

10.
a.
When
pressure
washing
boats
coated
with
"
sloughing"
paints,
is
removed
material
collected
to
prevent
releases
to
water?
___
b.
Are
blasting,
other
paint
preparation
and
painting
activities
contained
to
prevent
abrasives,
paint
chips,
and
overspray
from
being
released
to
the
water
or
land?
____
c.
Are
parts
with
fluids,
including
used
oil
filters,
drained
before
disposing
or
recycling?
____
d.
Are
cracked
batteries
stored
in
non­
leaking
secondary
containers?
____

11.
a.
Does
the
marina
provide
collection
of
wastes
generated
by
boaters?
Contaminated
bilgewater
or
absorbents
____
paint,
sealers,
and
varnishes,
including
scrapings
____
solvents
____
cleaners
____
antifreeze
____
septage
____
waste
fuel
____
used
oil
____
other
____________________________
b.
Are
boaters
notified
how
to
properly
handle
these
wastes
in
tenant
contracts,
posted
signs
or
pamphlets?
_____
Contaminated
bilgewater
or
absorbents
____
paint,
sealers,
and
varnishes,
including
scrapings
____
solvents
____
cleaners
____
antifreeze
____
septage
____
waste
fuel
____
used
oil
____
other
____________________________________

12.
Has
the
facility
switched
to
alternative
materials
or
products
to
reduce
toxicity
or
other
hazards
to
health,
safety
or
the
environment?
____
Safer
paint
stripping
____
safer
painting
_____
safer
MSD
odor
chemicals
____
dust
collection
____
phosphate
free
cleaners
____
biodegradable
cleaners
____
safer
antifreeze
____
other
________________________

13.
Has
the
marina
made
structural
changes
to
minimize
surface
water
runoff?
____
Berming
____
vegetation
____
riprap
____
drains
____
other
______________________________

14.
Has
the
marina
taken
any
action
to
improve
environmental
performance
not
included
above?
Please
explain_______________________________________________________________________
_____________________________________________________________________________

Matters
relating
to
compliance
are
explained
in
the
Performance
Guide.
Or,
call
EPA
at
617
918
1836
for
assistance.
You
will
also
find
resources
for
assistance
in
Section
4
of
the
Performance
Guide.
40
Attachment
C
EPA
OC
Metal
Finishing
Survey
Burden
Statement
The
public
burden
is
estimated
to
average
1
hour
per
response
for
the
mailed
survey
and
4
hours
per
response
for
the
site
visit
survey.
This
estimate
includes
the
time
required
to
complete
the
surveys,
either
by
filling
them
out
and
returning
them
by
mail
or
by
participating
in
a
half
day
site
visit
to
answer
survey
questions
during
that
time.

Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
Agency.
This
includes
the
time
needed
to:


review
instructions;


develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;


adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;


train
personnel
to
be
able
to
respond
to
a
collection
of
information;


search
data
sources;


complete
and
review
the
collection
of
information;
and

transmit
or
otherwise
disclose
the
information.

An
Agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.

Send
comments
on
the
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques,
to
the
Director,
OEI
Collection
Strategies
Division,
U.
S.
Environmental
Protection
Agency
(
Mail
Code
2822),
401
M
Street,
S.
W.,
Washington,
D.
C.
20460;
and
to
the
Office
of
Management
and
Budget,
725
17th
Street,
N.
W.,
Washington,
D.
C.
20503,
Attention:
Desk
Officer
of
EPA.
Include
the
EPA
ICR
Number
(
2021.01)
in
any
correspondence.
41
Metal
Finishing
Performance
Evaluation
Survey
1.
Have
you
won
any
awards
for
your
environmental
performance?
If
so,
please
list
them
here.

Section
1:
Wastewater
Treatment
2.
Does
your
site
generate
chromium­
bearing
wastewater?
GYes
GNo
3.
Does
your
site
generate
cyanide­
bearing
wastewater?
GYes
GNo
4.
Does
your
site
generate
metal­
bearing
wastewater?
GYes
GNo
5.
Which
types
of
wastewater
treatment
are
used
on
site
(
check
all
that
apply):

None
G
Equalization/
Neutralization
G
Chromium
Reduction
G
Cyanide
Destruction
G
Oil
Skimming/
Chemical
Emulsion
Breaking
G
Chemical
Precipitation
and
Sedimentation
G
Complex/
Chelated
Metals
Treatment
G
Sand/
Multimedia
Filtration
G
Membrane
Filtration
(
Microfiltration,
Ultrafiltration)
G
Ion
Exchange
G
Sludge
Dewatering
G
Other:

6.
Do
you
have
a
wastewater
discharge
permit?
GYes
GNo
7.
Which
activities
listed
below
do
you
perform
for
your
wastewater
discharge?

Monitoring
(
e.
g.,
flow,
pH,
ORP)
G
Sampling
of
wastewater
for
specific
pollutant
parameters
G
Reporting
G
8.
Have
you
received
any
compliance
assistance
to
reduce
the
amount
of
wastewater
your
facility
produces
or
to
reduce
the
amount
of
metals
in
your
wastewater?
GYes
GNo
42
9.
If
yes,
from
whom?
And
was
it
helpful?_________________________________

10.
Are
there
any
wastewater
regulations
that
you
feel
you
would
like
additional
assistance
with?
If
so,
what
are
they?_____________________________________________

11.
What
sources
do
you
use
for
information
on
wastewater
environmental
regulations
and
pollution
prevention?
(
Check
all
that
apply)

Internet
G
Trade/
professional
organizations
G
Industry/
professional
journals
G
Environmental
consultants
G
Colleagues/
supervisor
G
Government
environmental
agencies
G
Section
2:
Hazardous
Waste
Handling
12.
Does
your
facility
generate
hazardous
waste
(
e.
g.
F006
wastewater
treatment
sludge)?
GYes
GNo
If
answer
to
Question
12
is
no,
skip
to
Question
27.

13.
Is
hazardous
waste
generated
in
excess
of
100
kg/
month?
GYes
GNo
14.
How
long
is
the
hazardous
waste
maintained
on­
site?
days
15.
Are
you
aware
of
the
hazardous
waste
labelling
requirements
for
drums?
GYes
GNo
16.
Do
they
apply
to
your
drums?
GYes
GNo
17.
If
not,
why
not?____________________________________________________

18.
Are
you
aware
of
the
hazardous
waste
manifest
records
requirements?
GYes
GNo
19.
If
yes,
do
these
hazardous
waste
manifest
records
apply
to
your
facility?
GYes
GNo
20.
Do
you
perform
inspections
of
your
hazardous
waste
storage
area?
GYes
GNo
21.
If
yes,
how
often
are
inspections
performed:
43
22.
Do
you
have
a
hazardous
waste
contingency
plan?
GYes
GNo
23.
Have
you
received
any
compliance
assistance
to
help
you
with
the
identification
and/
or
handling
of
hazardous
waste
treatment
sludge?
GYes
GNo
24.
If
yes,
from
whom?
And
was
it
helpful?_________________________________

25.
Are
there
any
hazardous
waste
handling
regulations
that
you
feel
you
would
like
additional
assistance
with?
If
so,
what
are
they?______________________________

26.
What
sources
do
you
use
for
hazardous
waste
information
on
environmental
regulations
and
pollution
prevention?
(
Check
all
that
apply)

Internet
G
Trade/
professional
organizations
G
Industry/
professional
journals
G
Environmental
consultants
G
Colleagues/
supervisor
G
Government
environmental
agencies
G
Section
3:
Air
Emissions
27.
Does
your
site
perform
chromium
electroplating
or
chromic
acid
anodizing
operations?
GYes
GNo
If
answer
to
Question
27
is
`
NO',
skip
to
Question
35.

28.
How
many
chromium
electroplating
or
chromic
acid
anodizing
tanks
do
you
operate
(
excluding
rinses)?
tanks
29.
Are
you
aware
of
emissions
control
requirements
for
your
tanks?
GYes
GNo
30.
If
yes,
how
many
of
your
tanks
use
some
type
of
emission
control?
tanks
31.
Do
you
use
and
monitor
any
of
the
following
technologies
on
your
chromium
electroplating
or
chromic
acid
anodizing
solutions
(
check
all
that
apply):

Use
Monitor
Composite
mesh­
pad
system
G
G
Fiber­
bed
mist
eliminator
G
G
Packed­
bed
scrubber
G
G
Chemical
fume
suppressant
in
plating
baths
G
G
Other:
44
32.
Do
you
have
a
copy
of
the
EPA
Guidebook
on
How
to
Comply
with
the
Chromium
Electroplating
and
Anodizing
NESHAP?
GYes
GNo
33.
Have
you
ever
received
any
assistance
to
help
you
comply
with
EPA's
Chromium
MACT
standards?
GYes
GNo
34.
If
yes,
from
whom?
And
was
it
helpful?_____________________________

35.
Do
you
own
or
operate
a
solvent
cleaning
machine?
GYes
GNo
If
answer
to
Question
35
is
`
NO',
skip
to
Question
45.

36.
Does
the
solvent
cleaning
machine
use
a
solvent
containing
5
%
or
more
by
weight
of
any
one
or
combination
of
the
following
halogenated
solvents
(
check
all
solvents
that
are
used):

Methylene
Chloride
G
1,1,1­
trichloroethane
G
Perchloroethylene
G
Carbon
tetrachloride
G
Trichloroethylene
G
Chloroform
G
37.
Which
of
the
following
solvent
cleaning
machines
are
used?

Batch
Cold
Machine
G
In­
line
Cold
Machine
G
Batch
Vapor
Machine
G
In­
line
Vapor
Machine
G
38.
Are
you
aware
of
the
EPA
emissions
standards
for
solvent
cleaning
machines?
GYes
GNo
39.
If
yes,
do
these
standards
apply
to
your
machines?
GYes
GNo
(
Why
not?_______________________________________)

40.
If
these
standards
apply,
what
method
does
your
site
use
to
comply
with
emission
standards
for
solvent
cleaning
machines?

Equipment
compliance
option
G
Overall
emission
limit
G
Not
certain
G
41.
Do
you
have
a
copy
of
the
EPA
Guidance
Document
for
Halogenated
Solvent
Cleaner
NESHAP?
GYes
GNo
45
42.
Have
you
used
the
EPA's
Halogenated
Solvent
Cleaner
Rule
Assistance
Website?
GYes
GNo
43.
Have
you
ever
received
any
assistance
to
help
you
comply
with
EPA's
Solvent
MACT
standards?
GYes
GNo
44.
If
yes,
from
whom?
And
was
it
helpful?_________________________________

45.
Are
there
any
air
regulations
that
you
feel
you
would
like
additional
assistance
with?
If
so,
what
are
they?______________________________________________

46.
What
sources
do
you
use
for
information
on
air
environmental
regulations
and
pollution
prevention?
(
Check
all
that
apply)

Internet
G
Trade/
professional
organizations
G
Industry/
professional
journals
G
Environmental
consultants
G
Colleagues/
supervisor
G
Government
environmental
agencies
G
Section
4:
Toxics
Release
Inventory
(
TRI)
Reporting
47.
Are
you
aware
of
the
EPA
Form
R
(
TRI)
for
Toxic
Chemical
Release
Reporting?
GYes
GNo
48.
Is
your
facility
exempt
from
TRI
reporting?
GYes
GNo
If
yes,
why?
______________________________________

49.
Have
you
ever
received
any
assistance
to
help
you
complete
your
TRI
reporting?
GYes
GNo
50.
If
yes,
from
whom?
And
was
it
helpful?_________________________________

51.
Are
there
any
TRI
reporting
requirements
that
you
feel
you
would
like
additional
assistance
with?
If
so,
what
are
they?______________________________________

52.
What
sources
do
you
use
for
information
on
TRI
Reporting?
(
Check
all
that
apply)

Internet
G
Trade/
professional
organizations
G
Industry/
professional
journals
G
Environmental
consultants
G
Colleagues/
supervisor
G
Government
environmental
agencies
G
Section
5:
General
53.
Do
you
have
internet
access?
GYes
GNo
46
54.
Have
you
used
the
National
Metal
Finishing
Resource
Center
internet
site
(
nmfrc.
org)?
GYes
GNo
If
answer
to
Question
54
is
no,
skip
to
question
58.

55.
If
yes,
how
do
you
rate
the
usefulness
of
the
assistance
provided?
GVery
Good
GGood
GFair
GPoor
56.
What
type
of
information
have
you
obtained
from
the
NMFRC
(
check
all
that
apply)?

Compliance
Information
G
Environmental
Regulations
G
Process
information
G
57.
What
types
of
actions
have
you
taken
as
a
result
of
information
you
obtained
on
NMFRC
(
check
all
that
apply)?

Changed
process
G
Modified
reporting
procedures
G
Implemented
pollution
prevention
practices
G
None
G
Implemented
pollution
control
G
Other:
Obtained
permit
G
58.
Would
you
find
the
following
types
of
compliance
assistance
helpful?

Yes
No
Internet
based
training/
guidance
G
G
Workshops/
Training
G
G
CD
ROM
G
G
Onsite
Technical
Assistance
Visits
G
G
Inspections
G
G
Mailed
Fact
Sheets/
Guidance
G
G
59.
Are
you
aware
of
the
National
Metal
Finishing
Stategic
Goals
Program?
GYes
GNo
60.
What
is
the
number
of
full­
time
equivalent
employees
working
at
your
site?
_____
47
Checklist
for
Metal
Finishing
Shops
1)
Materials
and
Waste
Storage
&
Management
(
Does
the
Facility
have
good
control
over
Chemicals
and
Waste?)

__
Flammable
and
Hazardous
liquids
are
stored
in
containers
that
are
either
approved
by
the
U.
S.
Department
of
Transportation
(
DOT)
or
by
the
State
Fire
Marshall,
or
listed
and
labeled
by
the
National
Registration
and
Testing
Laboratory
(
UL
Listed)

__
Lids
are
tight
fitting
and
sealed,
and
bungs
are
closed
__
Containers,
tanks,
and
flammable
cabinets
are
labeled
with
the
name
of
the
material
they
hold,
and
the
type
of
hazard
they
present.
(
e.
g.,
flammable)

__
Flammables
are
stored
in
an
area
(
such
as
an
airtight
metal
cabinet,
metal
cabinet
vented
to
the
outside,
or
flammables
storage
room)
approved
by
the
local
fire
department.

__
Hazardous
Waste
storage
area
is
labeled
and
limits
of
area
are
marked.

__
Hazardous
Waste
storage
area
has
a
communication
device
for
emergencies.

__
Drums
are
stored
in
rows
with
sufficient
aisle
space
for
a
person
to
walk
between,
and
all
labels
are
visible.

__
Hazardous
Waste
drums
are
clearly
labeled
with
"
Hazardous
Waste",
the
date
on
which
the
drum
began
accumulating
waste,
name
of
waste
and
type
of
hazard
(
flammable,
toxic,
etc.).

__
Drums
are
palletized
and
stacked
no
more
than
two
containers
high.

__
Containers
in
"
Satellite
accumulation
areas"
are
labeled
with
"
Hazardous
Waste",
name
of
waste,
type
of
hazard,
and
are
kept
closed
except
when
waste
is
being
added.

__
Trash
is
not
mixed
in
with
hazardous
waste.

__
Drums
of
materials
and
waste
stored
outside
are
in
a
covered
area
with
secondary
containment.

__
There
are
no
leaks
or
spillage
in
chemical
or
waste
storage
areas.

__
A
log
is
kept
of
weekly
inspections
of
hazardous
waste
storage
areas.

__
Facility
has
a
RCRA
ID
number,
and
is
using
a
licensed
waste
hauler
for
hazardous
waste.
48
2)
Wastewater
Discharge
(
Is
water
from
this
facility
harming
the
environment?)

__
Direct
Dischargers
have
an
National
Pollution
Discharge
Elimination
System
(
NPDES
)
Permit
issued
by
EPA
and
the
state.

__
Indirect
Dischargers
have
a
Permit
from
the
local
Publicly
Owned
Treatment
Works
(
POTW)
or
EPA,
if
there
is
no
local
pretreatment
authority.

__
Floor
of
facility
is
made
of
impervious
material,
and
is
in
good
condition.

__
Floor
trenches
lead
to
sump
area
that
is
pumped
out
on
a
regular
basis
and
run
through
waste
treatment
system.
Floor
trenches
are
covered.

__
All
sludge
from
a
waste
treatment
system
is
disposed
of
as
hazardous
waste.

Burden
Statement
The
public
burden
is
estimated
to
average
1
hour
per
response
for
the
mailed
survey
and
4
hours
per
response
for
the
site
visit
survey.
This
estimate
includes
the
time
required
to
complete
the
surveys,
either
by
filling
them
out
and
returning
them
by
mail
or
by
participating
in
a
half
day
site
visit
to
answer
survey
questions
during
that
time.

Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
Agency.
This
includes
the
time
needed
to:


review
instructions;


develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;


adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;


train
personnel
to
be
able
to
respond
to
a
collection
of
information;


search
data
sources;


complete
and
review
the
collection
of
information;
and

transmit
or
otherwise
disclose
the
information.

An
Agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.

Send
comments
on
the
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques,
to
the
Director,
OEI
Collection
Strategies
Division,
U.
S.
Environmental
Protection
Agency
(
Mail
Code
2822),
401
M
Street,
S.
W.,
Washington,
D.
C.
20460;
and
to
the
Office
of
Management
and
Budget,
725
17th
Street,
N.
W.,
Washington,
D.
C.
20503,
Attention:
Desk
Officer
of
EPA.
Include
the
EPA
ICR
Number
(
2021.01)
in
any
correspondence.
49
