1
INFORMATION
COLLECTION
REQUEST
SUPPORTING
STATEMENT
FOR
State
Review
Framework
July
11,
2005
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
Part
B
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
3
Part
A
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
of
the
Information
Collection
ICR:
State
Review
Framework
(
EPA
ICR
Number
2185.01)
OMB
Control
Number:
N/
A
"
State
Review
Framework"

1(
b)
Short
Characterization/
Abstract
The
State
Review
Framework
("
Framework")
is
an
oversight
tool
designed
to
assess
state
performance
in
enforcement
and
compliance
assurance.
The
Framework's
goal
is
to
evaluate
state
performance
by
examining
existing
data
to
provide
a
consistent
level
of
oversight
and
develop
a
uniform
mechanism
by
which
EPA
Regions,
working
collaboratively
with
their
states,
can
ensure
that
state
environmental
agencies
are
consistently
implementing
the
national
compliance
and
enforcement
program
in
order
to
meet
agreed­
upon
goals
and
standards.
Furthermore,
the
Framework
is
designed
to
foster
dialogue
on
enforcement
and
compliance
performance
between
the
states
that
will
enhance
relationships
and
increase
feedback,
which
will
in
turn
lead
to
consistent
program
management
and
improved
environmental
results.
Specifically,
the
Framework
is
a
structured
process
that
provides
critical
information
on
a
state's
(
or
Region's,
for
states
with
EPA­
implemented
programs)
core
enforcement
and
compliance
assurance
performance
by
employing
existing
data
available
in
EPA's
existing
national
databases
and
presented
in
management
reports
for
each
state.
By
the
end
of
calendar
year
2005
EPA
expects
to
automate
the
management
reports
and
make
them
available
to
the
Regions
and
states.
No
new
data
collection
is
required
for
the
national
databases.
Data
from
national
databases
will
be
complimented
by
data
obtained
through
file
reviews
of
a
state
environmental
agency's
compliance
and
enforcement
files.
No
new
data
is
required
in
these
files;
however,
they
will
be
reviewed
to
ensure
proper
and
adequate
documentation.
The
Framework
process
asks
regions,
states
and
local
governments
to
examine
the
existing
data
described
above
in
three
core
programs:
Clean
Air
Act
("
CAA"),
Stationary
Sources;
Clean
Water
Act
("
CWA"),
National
Pollutant
Discharge
Elimination
System
("
NPDES");
and
Resource
Conservation
and
Recovery
Act
("
RCRA"),
Subtitle
C.
The
Framework
process
looks
at
thirteen
(
13)
elements.
The
EPA
evaluates
the
twelve
(
12)
primary
elements,
and
a
thirteenth
optional
element,
using
data
and
file
review
metrics
that
require
no
new
reporting
burden.
The
utility
of
the
Framework's
metrics
and
the
Implementation
Guide
are
a
direct
result
of
the
collaboration
between
states,
Regions,
Headquarters,
and
environmental
leaders
over
the
previous
two
years.
These
stakeholders
provided
extensive
input
and
comments
prior
to
the
pilot
phase
of
the
project,
which
helped
to
shape
the
Framework.
OECA
recently
completed
an
evaluation
of
pilot
implementation,
which
includes
input
from
the
pilot
states.
The
results
of
the
evaluation
of
the
Framework's
pilot
program
have
been
used
to
improve
the
Framework
and
further
ensure
that
it
is
narrowly
crafted
and
only
collects
information
that
satisfies
the
Agency's
needs.
4
The
thirteen
(
13)
elements
mentioned
above
are:
(
1)
The
degree
to
which
a
state
program
has
completed
the
universe
of
planned
inspections
(
addressing
core
requirements
and
Federal,
state,
and
regional
priorities);
(
2)
The
degree
to
which
inspection
reports
and
compliance
reviews
document
inspection
findings,
including
accurate
descriptions
of
what
was
observed
to
sufficiently
identify
violation(
s);
(
3)
The
degree
to
which
inspection
reports
are
completed
in
a
timely
manner,
including
timely
identification
of
violations;
(
4)
The
degree
to
which
significant
violations
(
e.
g.,
significant
noncompliance
and
high­
priority
violations)
and
supporting
information
are
accurately
identified
and
reported
to
EPA's
national
databases
in
a
timely
manner;
(
5)
The
degree
to
which
state
enforcement
actions
include
required
corrective
or
complying
actions
(
i.
e.,
injunctive
relief)
that
will
return
facilities
to
compliance
in
a
specific
time
frame;
(
6)
The
degree
to
which
a
state
takes
timely
and
appropriate
enforcement
actions,
in
accordance
with
policy
relating
to
specific
media;
(
7)
The
degree
to
which
a
state
includes
both
gravity
and
economic
benefit
calculations
for
all
penalties,
appropriately
using
the
BEN
model
or
similar
state
model
(
where
in
use
and
consistent
with
national
policy);
(
8)
The
degree
to
which
penalties
in
final
enforcement
actions
collect
appropriate
economic
benefit
and
gravity
in
accordance
with
applicable
penalty
procedures;
(
9)
The
degree
to
which
enforcement
commitments
in
the
PPA/
PPG/
categorical
grants
(
i.
e.,
written
agreements
to
deliver
a
product/
project
at
a
specified
time),
if
they
exist,
are
met
and
any
products
or
projects
are
completed;
(
10)
The
degree
to
which
the
minimum
data
requirements
are
timely;
(
11)
The
degree
to
which
the
minimum
data
requirements
are
accurate;
(
12)
The
degree
to
which
the
minimum
data
requirements
are
complete,
unless
otherwise
negotiated
by
the
region
and
state
or
prescribed
by
a
national
initiative;
and
(
13)
(
Optional)
Other
program
activities
(
e.
g.,
using
outcome
data,
compliance
assistance,
self­
disclosure
programs,
innovative
approaches,
etc.).
In
the
interest
of
accuracy
and
efficiency,
the
Framework
also
includes
a
five­
step
protocol
for
managing
the
process:
(
1)
pre­
review;
(
2)
offsite
review;
(
3)
onsite
review;
(
4)
drafting
of
the
report;
and
(
5)
composing
the
final
report
and
follow­
up.
After
reviewing
the
level
of
performance
based
on
the
metrics
developed
under
the
12
required
performance
elements,
and
other
information
collected
in
the
review
process,
EPA
will
determine
if
a
state
or
Region
meets
minimum
performance
levels.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
The
purpose
of
this
collection
is
to
assess
state
performance
in
core
enforcement
and
compliance
assurance
programs.
The
goals
are
to
provide
a
consistent
level
of
oversight
and
develop
a
uniform
mechanism
by
which
EPA
Regions,
working
collaboratively
with
their
states,
can
ensure
that
state
environmental
agencies
are
meeting
agreed­
upon
goals.
It
is
important
to
note
that
all
data
requested
by
this
collection
is
currently
in
EPA's
or
the
state's
databases
and
enforcement
and
compliance
files.
No
additional
monitoring
or
sampling
will
be
required
by
this
ICR.

While
the
data
that
the
Agency
will
collect
is
pre­
existing,
the
Agency
is
permitted
to
review
the
states'
Clean
Air
Act,
Stationary
Source
program,
the
Solid
Waste
Disposal
Act,
Subtitle
C
program,
and
the
Clean
Water
Act,
National
Pollutant
Discharge
Elimination
System
permit
5
program
to
ensure
adequate
performance.
The
Agency's
oversight
authority
for
the
aforementioned
programs
are:

(
1)
Clean
Air
Act,
Stationary
Source
program:

Section
114
allows
collection
of
information
from
states.
Specifically,
the
collection
of
the
requested
information
is
authorized
by
40
CFR
70.4(
j)(
1),
which
states
that
"[
a]
ny
information
obtained
or
used
in
the
administration
of
a
State
program
shall
be
available
to
EPA
upon
request
without
restriction
and
in
a
form
specified
by
the
Administrator,
including
computer­
readable
files
to
the
extent
practicable,"
and
40
CFR
70.10(
c)(
1)(
iii),
which
addresses
EPA
oversight
of
State
and
local
agencies'
compliance
and
enforcement
efforts
for
major
sources
under
Title
V
operating
permit
programs.

(
2)
Solid
Waste
Disposal
Act,
Subtitle
C
program:

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.
Additionally,
40
CFR
271.17(
a)
authorizes
EPA,
upon
request
without
restriction,
access
to
"[
a]
ny
information
obtained
or
used
in
the
administration
of
a
State
program."

(
3)
Clean
Water
Act,
NPDES
program:

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.
Further,
the
NPDES
state
program
regulations
provide
that
"[
a]
ny
information
obtained
or
used
in
the
administration
of
a
State
program
shall
be
available
to
EPA
upon
request
without
restriction."
40
CFR
123.41.
Also,
40
CFR
123.43
requires
states
to
provide
EPA
with
information
on
NPDES
program
implementation.

The
information
collected
through
this
ICR
will
aid
the
Agency
in
achieving
EPA's
Strategic
Plan
goal
to
increase
compliance
and
environmental
stewardship.
This
goal
was
developed
in
response
to
the
1993
Government
Performance
and
Results
Act
and
is
described
in
EPA's
2003
Strategic
Plan,
Goal
5,
"
Compliance
and
Environmental
Stewardship."

2(
b)
Practical
Utility/
Users
of
the
Data
EPA
will
use
the
data
obtained
from
the
collection
to
determine
if
a
state
or
Region
meets
minimum
performance
levels.
Such
a
determination
is
necessary
to
reward
states
that
are
performing
adequately
and
provide
assistance
to
states
that
are
not
meeting
minimum
performance
levels.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
6
3(
a)
Nonduplication
The
information
to
be
obtained
under
this
ICR
has
not
been
collected
by
EPA
or
any
other
federal
agency.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
On
April
26,
2005,
EPA
published
a
pre­
ICR
Federal
Register
Notice
announcing
its
intent
to
submit
an
ICR
to
OMB
regarding
the
State
Review
Framework.
Attachment
A
includes
a
copy
of
this
Federal
Register
Notice.
EPA
received
only
one
set
of
comments
to
the
Federal
Register
Notice.
These
comments
came
from
the
Texas
Commission
for
Environmental
Quality.

Below
are
comments
and
our
responses
thereto:

Response
to
comments
submitted
by
the
Texas
Commission
for
Environmental
Quality:

Comment
1:
Additional
state
data
may
need
to
be
created
for
the
review,
which
would
create
a
burden
for
the
state.
Response
1:
The
State
Review
Framework
is
based
on
three
sources
of
data:
1)
Data
from
the
national
media
databases;
2)
Data
from
a
state's
inspection
and
enforcement
files;
3)
negotiated
compliance
and
enforcement
commitments
in
grant
work
plans.
The
Framework
does
provide
for
the
inclusion
of
other
data
the
state
believes
are
important
for
EPA
to
consider
during
the
review.
This
last
category
of
data
is
voluntary
and
may
be
provided
to
EPA
at
the
discretion
of
the
state.
If
it
chooses
to
share
additional
information,
a
state
may
use
some
level
of
resources
in
pulling
already
existing
state
data,
but
this
review
process
does
not
envision
a
state
creating
any
new
data.

The
Framework
was
pilot­
tested
in
ten
states
before
being
made
final
at
the
beginning
of
July
2005.
These
pilots
were
evaluated
and
the
recommendations
from
the
evaluation
incorporated
into
the
process
and
documents
of
the
State
Review
Framework.
The
burden
hours
calculated
for
this
ICR
are
based
on
information
obtained
from
the
pilot
states
and
reflect
the
time
required
to
collect
and
provide
the
data
from
state
files.
The
burden
for
reporting
media­
specific
enforcement
information
is
covered
by
separate
program
ICRs.

As
the
Review
is
carried
out
in
all
50
states
over
the
next
few
years,
OECA
is
committed
to
monitoring
and
evaluating
various
aspects
of
the
review
process,
in
order
to
take
advantage
of
lessons
learned
and
make
the
review
process
as
efficient
as
possible.
This
monitoring
will
include
tracking
the
resource
burden
that
the
review
requires
of
states.
The
media­
specific
Discussion
Guides
that
OECA
has
provided
to
the
Regional
Offices
to
use
when
reviewing
the
state
programs
already
asks
that
regions
and
states
discuss
the
burden
required
by
the
review
and
to
note
it
in
their
final
reports.
OECA
encourages
the
states
to
track
the
resources
used
during
the
review
and
provide
that
data
to
us
as
we
conduct
further
evaluation
of
the
project.
7
Comment
2:
A
state
should
not
be
held
accountable
for
future
program
data
requirements
that
are
not
in
effect
at
the
time
of
the
review.
Response
2:
The
Framework
documentation
point
out
that
the
standards
used
to
evaluate
state
performance
are
national
policy
and
guidance,
consistent
state
policy
and
guidance,
and/
or
negotiated
commitments.
The
Framework
is
designed
to
only
use
existing
program
data
and
not
be
the
driver
for
new
or
additional
program
data
requirements.
A
state
will
be
reviewed
based
on
the
policy
and
guidance
in
place
during
the
review
period.
For
example,
if
the
review
period
is
FY
2004,
only
the
policies
and
guidance
in
place
at
that
time
will
be
used
to
assess
state
performance.
To
make
sure
that
this
is
clear
to
those
implementing
the
Framework,
we
have
added
a
phrase
to
this
effect
in
the
"
Overview"
document.

3(
c)
Consultations
EPA
consulted
with
several
key
state
and
media
associations
in
the
course
of
developing
the
State
Review
Framework.
The
leadership
and
membership
of
these
organizations
were
instrumental
in
helping
OECA
develop
the
initial
concept
for
the
State
Review
Framework,
in
working
to
develop
the
main
components
and
metrics,
completing
pilot
projects
and
providing
input
into
the
evaluation.
These
associations
are:

ECOS
ASIWPCA
ASTSWMO
STAPPA/
ALAPCO
The
main
contacts
with
these
organizations
are:

Environmental
Council
of
States
(
ECOS)

Steve
Thompson
Executive
Director
Oklahoma
Department
of
Environmental
Quality
405­
702­
7163
President
of
ECOS
Bob
King
Deputy
Commissioner
South
Carolina
Department
of
Health
and
Environmental
Control
803­
896­
8940
Secretary
of
ECOS
Howard
Roitman
Director,
Environment
Programs
Colorado
Department
of
Health
and
Environment
303­
692­
3475
Chair,
Compliance
Committee
8
Mary
Blakeslee
Senior
Deputy
ECOS
202­
624­
3665
Association
of
State
and
Interstate
Water
Pollution
Control
Administrators
(
ASIWPCA)

Roberta
Savage
Executive
Director
ASIWPCA
Washington,
DC
202­
642­
898­
0905
Association
of
State
and
Territorial
Solid
Waste
Management
Officials
(
ASTSWMO)
Steve
Cobb
Alabama
Department
of
Environmental
Management
sac@
adem.
state.
al.
us
Chair,
Hazardous
Waste
Subcommittee
(
ASTSWMO)

Cheryl
Coleman
Land
and
Waste
Management
Bureau
South
Carolina
Department
of
Health
and
Environmental
Control
colemact@
dhec.
sc.
gov
Vice­
Chair,
Hazardous
Waste
Subcommittee
(
ASTSWMO)

Barbara
Simco
Deputy
Director
ASTSWMO
202­
624­
5824
State
and
Territorial
Air
Pollution
Program
Administrators/
Association
of
Local
Air
Pollution
Control
Officers
(
STAPPA/
ALAPCO)

Eddie
Terrill
Oklahoma
Department
of
Environmental
Quality
405­
7024100
Vice­
President,
STAPPA/
ALAPCO
Mary
Stewart
Douglas
Senior
Staff
Associate
Washington,
DC
202­
624­
7864
9
3(
d)
Effects
of
Less
Frequent
Data
Collection
Each
respondent
will
report
only
one
time
every
three
years.

3(
e)
General
Guidelines
This
information
collection
is
consistent
with
OMB
guidelines
contained
in
5
CFR
1320.5(
d)(
2).

3(
f)
Confidentiality
Any
information
submitted
to
the
Agency
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
Agency
policies
set
forth
in
Title
40,
chapter
1,
part
2,
subpart
B
­
Confidentiality
of
Business
Information
(
see
40
CFR
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
40000,
September
8,
1978;
43
FR
42251,
September
20,
1978;
44
FR
17674,
March
23,
1979).

3(
g)
Sensitive
Questions
The
collection
in
this
ICR
does
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:
Forty
(
40)
of
the
fifty
(
50)
states
and
six
(
6)
territories/
commonwealths.
There
are
no
SIC
codes
for
the
Respondents.

4(
b)
Information
Requested
(
i)
Data
items,
including
recordkeeping
requirements
The
State
Review
Framework
requests
information
on
the
contribution
of
state
enforcement
activities
to
federally
delegated
programs.
There
are
no
recordkeeping
requirements
associated
with
this
collection.

The
collection
process
will
compile
information
on
the
state's
enforcement
and
compliance
activities,
including
inspection
coverage,
enforcement
timeliness
and
appropriateness,
penalty
calculations
and
fines
collected,
and
data
quality,
accuracy
and
completeness.

(
ii)
Respondent
Activities
Respondent
will
engage
in
the
following
activities
during
the
Framework
process:

1.
Pre­
Review
and
Offsite
Review
Review
elements
and
metrics
10
Train/
brief
state
staff
&
managers
on
review
substance
and
process.
Collect
files,
policies,
data
sets,
reports
etc.

2.
Onsite
Review
Participate
in
kick­
off
meeting.
Assist/
facilitate
EPA
review
of
files
and
data
sets
Participate
in
discussion
of
program
with
EPA
3.
Report
Drafting
Review
and
comment
on
draft
report
4.
Coordination
of
Parts
1,
2
&
3
Coordination
of
review
with
the
state
agency
Coordination
of
the
review
within
EPA
5.
THE
INFORMATION
COLLECTED:
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
Agency
activities
associated
with
the
State
Review
Framework
consist
of
the
following:

(
1)
Review
elements
and
metrics
(
2)
Train/
brief
state
staff
&
managers
on
review
substance
and
process
(
3)
Collect
files,
policies,
data
sets,
reports
etc.
(
4)
Participate
in
kick­
off
meeting.
(
5)
Assist/
facilitate
EPA
review
of
files
and
data
sets
(
6)
Participate
in
discussion
of
program
with
EPA
(
7)
Review
and
comment
on
draft
report
(
8)
Coordination
of
review
with
the
state
agency
(
9)
Coordination
of
the
review
within
EPA
5(
b)
Collection
Methodology
and
Management
The
Agency
will
provide
respondents
with
guidelines
for
conducting
the
review
and
will
provide
a
model
report
to
aid
the
respondents
and
encourage
consistent
responses.
Over
the
course
of
the
review
process
the
Agency
will
work
with
the
states
and
provide
assistance
as
necessary.
All
of
the
state
reports
will
be
submitted
electronically.
National
data
used
to
assess
state
performance
already
resides
in
various
EPA
databases.
These
data
are
covered
by
other
Information
Collection
Requests
or
regulatory
language.
Additional
data
will
come
from
the
review
of
state
inspection
and
enforcement
files,
which
is
the
data
that
are
to
be
collected
based
on
this
request.

5(
c)
Small
Entity
Flexibility
11
Small
entities
will
not
be
affected
as
the
collection
will
only
be
completed
by
EPA
Regions,
States
and
territories.

5(
d)
Collection
Schedule
Each
Respondent
will
complete
the
four­
step
protocol
for
managing
the
process
one
time
every
three
years:
(
1)
pre­
review
and
offsite
review;
(
3)
onsite
review;
(
4)
drafting
of
the
report;
and
(
5)
composing
the
final
report
and
follow­
up.
In
the
initial
year,
twenty
(
20)
states
are
scheduled
to
complete
the
review
process.
In
the
second
year
another
twenty
(
20)
states
are
scheduled
with
the
remaining
ten
states
completing
the
review
process
in
year
three.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
and
Costs
The
estimated
total
hour
burden
for
response
is
384
hours
per
respondent.
This
burden
hour
estimate
translates
to
a
cost
of
$
12,678
per
entity
that
voluntarily
completes
the
survey
resulting
in
the
total
of
$
633,880.
There
is
no
recurring
respondent
burden
associated
with
this
ICR.
No
capital
or
operations
and
maintenance
costs
are
incurred
by
respondents
under
this
ICR.

The
labor
costs
in
the
following
table
are
based
on
the
following
average
labor
rates:

Legal:
$
45.64
(
Lawyers)
Managerial:
$
37.22
(
General
and
operations
managers)
Technical:
$
31.96
(
Environmental
engineers)
Clerical:
$
16.81
(
Executive
secretaries
and
administrative
assistants)

These
rates
are
from
the
United
States
Department
of
Labor's,
Bureau
of
Labor
Statistics,
"
Table
1.
National
employment
and
wage
data
from
the
Occupational
Employment
Statistics
survey
by
occupation,
May
2004,"
http://
www.
bls.
gov/
news.
release/
ocwage.
t01.
htm.

Table
1.
Respondents'
Burden
and
Costs
Information
Collection
Activity
Legal
$
45.64/
hour
Mang.
$
37.22/
hour
Tech.
$
31.96/
hour
Cler.
$
16.81/
hour
Cap./

Startup
cost
Oper.
and
Maint.
(
O&
M
cost)

1.
Pre­
Review
and
Offsite
Review
Review
elements
and
metrics
5.2
14.8
31
2.0
$
0.0
$
0.0
Train/
brief
state
staff
&
managers
on
review
substance
and
process.
4.4
11.2
23
8.0
$
0.0
$
0.0
12
Information
Collection
Activity
Legal
$
45.64/
hour
Mang.
$
37.22/
hour
Tech.
$
31.96/
hour
Cler.
$
16.81/
hour
Cap./

Startup
cost
Oper.
and
Maint.
(
O&
M
cost)

Collect
files,
policies,
data
sets,
reports
etc.
3.8
10.8
75.8
4.0
$
0.0
$
0.0
2.
Onsite
Review
Participate
in
kick­
off
meeting.
2.8
9.6
12.66
1.0
$
0.0
$
0.0
Assist/
facilitate
EPA
review
of
files
and
data
sets
2
16.4
22.06
16.0
$
0.0
$
0.0
Participate
in
discussion
of
program
with
EPA
1.8
14.8
18.06
2.0
$
0.0
$
0.0
3.
Report
Drafting
Review
and
comment
on
draft
report
1.8
17.6
11
1.0
$
0.0
$
0.0
4.
Coordination
of
Parts
1,
2
&
3
Coordination
of
review
with
the
state
agency
0.8
14.4
5.2
2.0
$
0.0
$
0.0
Coordination
of
the
review
within
EPA
0.4
13
2.8
1.0
$
0.0
$
0.0
TOTAL
HOURS/
Respondent
23.00
($
45.65)
122.6
($
37.22)
201.58
($
31.96)
37.0
($
16.81)

LABOR
COST/
Respondent
$
1,049.95
$
4,563.17
$
6,442.50
$
621.97
No.
of
Respondents:
40
Total
hours:
384.18/
Respondent
x
40
Respondents
=
15,367
Total
Cost:
$
12,677.59/
Respondent
x
40
respondents
=
$
507,104
6(
b)
Estimating
Agency
Burden
EPA
Regions
I
through
X
will
participate
in
the
State
Review
Framework
process
and
the
following
table
details
the
hour
and
cost
burden
per
region.
These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2005
General
Schedule"
which
excludes
locality
rates
of
pay.

The
cost
for
the
Regional
table
(
Table
2)
is
based
on
the
average
hourly
labor
rate
as
follows:
13
Legal
$
41.38
(
GS­
14,
Step
5)
Managerial
$
35.01
(
GS­
13,
Step
5)
Technical
$
25.98
(
GS­
12,
Step
1)
Clerical
$
14.06
(
GS­
6,
Step
3)

The
cost
for
the
Headquarters
table
(
Table
3)
is
based
on
the
average
hourly
labor
rate
as
follows:

Legal
$
47.99
(
GS­
14,
Step
5)
Managerial
$
40.61
(
GS­
13,
Step
5)
Technical
$
30.13
(
GS­
12,
Step
1)
Clerical
$
16.31
(
GS­
6,
Step
3)

These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2005
General
Schedule"
and
includes
the
locality
payment
for
the
Washington
D.
C.
area.

Table
2.
Agency
Burden
and
Cost
(
per
Region)

Information
Collection
Activity
legal
$
41.38/
hour
man.
$
35.01/
hour
tech.
$
25.98
/
hour
cler.
$
14.06/
hour
Capit
al/

Startup
cost
(
O&
M
cost)

1.
Pre­
Review
and
Offsite
Review
Review
elements
and
metrics
0
9.5
1
0
0
0
Train/
brief
state
staff
&
managers
on
review
substance
and
process.
0
4.5
13
0
0
0
Collect
files,
policies,
data
sets,
reports
etc.
0
1.5
6
0
0
0
2.
Onsite
Review
Participate
in
kick­
off
meeting.
0
0
42
3.5
0
0
Assist/
facilitate
on­
site
review
of
files
and
data
sets
0
24
60
1.75
0
0
Participate
in
discussion
of
program
with
state
0
1.5
37.5
1.75
0
0
3.
Report
Drafting
Review
and
comment
on
draft
report
0
13
48
0
0
0
14
Information
Collection
Activity
legal
$
41.38/
hour
man.
$
35.01/
hour
tech.
$
25.98
/
hour
cler.
$
14.06/
hour
Capit
al/

Startup
cost
(
O&
M
cost)

4.
Coordination
of
Parts
1,
2
&
3
Coordination
of
review
with
the
state
agency
0
1.5
40
0.5
0
0
Coordination
of
the
review
within
EPA
0
0
40
0
0
0
Total
Agency
hours
0.0
55.5
287.5
7.5
0.0
0.0
Total
Agency
costs
0.0
$
1943.1
$
7,469.2
5
$
105.45
TOTAL
REGIONAL
AGENCY
HOURS:
350.50
(
x
10
Regions
=
3,505.
0)
TOTAL
REGIONAL
AGENCY
COST:
$
9,517.80
x
10
Regions
=
$
95,178.00)

Table
3.
Agency
Burden
and
Cost
(
Headquarters)

Information
Collection
Activity
legal
$
47.99/
hour
man.
$
40.61/
hour
tech.
$
30.13
/
hour
cler.
$
16.31/
hour
Capital/
Start­
up
cost
(
O&
M
cost)

1.
Pre­
Review
and
Offsite
Review
Train/
brief
state
and
region
staff
&
managers
on
review
substance
and
process.
2
6
3
15
0
0
Collect
files,
policies,
data
sets,
reports
etc.
0
10
15
25
0
0
2.
Onsite
Review
Participate
in
kick­
off
meeting.
0
2
2
5
0
0
Participate
in
discussion
of
the
program
with
the
Regions
0
30
20
10
0
0
3.
Report
Drafting
Review
and
comment
on
draft
report
1
10
15
5
0
0
4.
Coordination
of
Parts
1,
2
&
3
Coordination
of
the
review
within
EPA
0
15
2
0
0
0
15
Information
Collection
Activity
legal
$
47.99/
hour
man.
$
40.61/
hour
tech.
$
30.13
/
hour
cler.
$
16.31/
hour
Capital/
Start­
up
cost
(
O&
M
cost)

TOTAL
3
73
57
60
0
0
TOTAL
COST
$
143.97
$
2964.53
$
1717.41
$
978.60
TOTALS
Hours:
193
Labor
Cost:
$
5804.50
6(
c)
Bottom
Line
Burden
Hours
and
Cost
Tables
Table
3.
Total
Estimated
Respondent
Burden
and
Cost
Summary
No.
of
Respondent
s
No.
of
Activities
Total
hours
Total
Labor
Costs
Total
Capital
and
Start­
up
costs
Total
Annual
O&
M
costs
Respondent
40
9
15,367.20
$
507,103.60
$
0.0
$
0.0
Table
4.
Total
Estimated
Agency
Burden
and
Cost
Summary
No.
of
Activities
Total
hours
Total
Labor
Costs
Total
Capital
and
Start­
up
costs
Total
Annual
O&
M
costs
Regions
9
3505.00
(
for
all
ten
regions)
$
95,178.00
(
for
all
ten
regions)
$
0.0
$
0.0
Headquarters
6
193
$
5804.50
$
0.0
$
0.0
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
average
annual
respondent
burden
for
each
state
is
384.18
hours.
This
estimate
includes
time
for
(
1)
reviewing
elements
and
metrics;
(
2)
training
and
briefing
state
staff
&
16
managers
on
review
substance
and
process;
(
3)
collecting
files,
policies,
data
sets,
reports
etc.;
(
4)
participating
in
kick­
off
meetings;
(
5)
assisting/
facilitating
EPA
review
of
files
and
data
sets;
(
6)
participating
in
discussion
of
program
with
EPA;
(
7)
reviewing
and
commenting
on
draft
report;
(
8)
coordinating
of
review
with
the
state
agency;
and
(
9)
coordinating
of
the
review
within
EPA.
There
is
no
record
keeping
burden
for
this
collection
as
the
State
Review
Framework
does
not
include
record
keeping
requirements.
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
valid
OMB
Control
Number.
The
OMB
Control
Numbers
for
EPA's
regulations
are
listed
at
40
CFR
part
9
and
48
CFR
chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
Number
OECA­
2005­
0014,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Avenue,
N.
W.,
Washington,
D.
C.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
OECA
Docket
is
(
202)
566­
1752.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
to
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
When
in
the
system,
select
"
search,"
then
key
in
the
Docket
ID
Number
identified
above.
You
can
also
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
N.
W.,
Washington,
D.
C.
20503,
Attention:
Desk
Officer
for
EPA.
Please
include
the
EPA
Docket
ID
Number
OECA­
2005­
0014
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
