RENEWAL
OF
INFORMATION
COLLECTION
REQUEST
(
No.
1463.05)
FOR
THE
NATIONAL
OIL
AND
HAZARDOUS
SUBSTANCES
POLLUTION
CONTINGENCY
PLAN
(
40
CFR
PART
300)

1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
l(
a)
Title
of
the
Information
Collection
Record
keeping
and
reporting
requirements
of
the
Superfund
remedial
program
as
specified
in
the
National
Oil
and
Hazardous
Substances
Pollution
Contingency
Plan
(
NCP;
40
CFR
Part
300).

l(
b)
Short
Characterization
The
Comprehensive
Environmental
Response,
Compensation,
and
Liability
Act
of
1980
(
CERCLA
or
Superfund;
42
USC
9601
et
seq.),
as
amended,
establishes
broad
Federal
authority
to
undertake
removal
and
remedial
actions
in
response
to
releases
or
threats
of
releases
of
hazardous
substances
and
certain
pollutants
and
contaminants
into
the
environment.
The
NCP
sets
forth
requirements
for
carrying
out
the
response
authorities
established
under
CERCLA.

For
states,
this
ICR
addresses
the
record
keeping
and
reporting
provisions
of
the
NCP
that
affect
those
states
that
voluntarily
participate
in
the
remedial
action
phase
of
the
Superfund
program.
(
Record
keeping
and
reporting
requirements
of
the
pre­
remedial
action
phase­­
except
those
tied
to
community
involvement­­
have
been
addressed
in
the
ICR
prepared
for
the
revisions
to
the
Hazard
Ranking
System
(
HRS)
(
OMB
Control
No.
2050­
0095).
Record
keeping
and
reporting
provisions
for
the
removal
program­­
except,
again,
those
tied
to
community
involvement­­
also
are
not
included
in
this
ICR
because
the
Federal
government
has
the
lead
for
removal
actions.)
Remedial
responses
under
the
Superfund
program
fall
into
the
pre­
remedial
action
phase
(
during
which
the
extent
of
site
contamination
is
assessed)
and
the
remedial
action
phase
(
during
which
investigations
are
conducted
to
identify
and
characterize
contaminants
present
and
to
determine
viable
remedies
for
a
site,
the
remedy
is
chosen
and
the
cleanup
or
construction
is
completed).
The
NCP
includes
the
following
reporting
and
record
keeping
provisions
for
the
remedial
phase
of
the
Superfund
program:

(
1)
States
that
voluntarily
take
the
lead
in
remedial
activities
at
Superfund
sites
must
conduct
the
activities
in
a
manner
consistent
with
CERCLA
(
40
CFR
300.515(
a)).
Therefore,
at
a
state­
lead
site,
the
state
must:
develop
a
Remedial
Investigation
and
Feasibility
Study
(
RI/
FS);
prepare
a
Proposed
Plan;
issue
a
Record
of
Decision
(
ROD);
complete
community
interviews;
prepare
a
Community
Involvement
Plan
(
CIP),
and
provide
information
to
the
public;
and
(
2)
States
must
identify
and
communicate
potential
state
applicable
or
relevant
and
appropriate
requirements
(
ARARs)
at
all
Superfund
sites
within
the
state
(
40
CFR
300.400(
g)).

In
addition,
this
ICR
addresses
the
record
keeping
and
reporting
provisions
of
the
NCP
that
affect
communities
voluntarily
providing
their
concerns
to
the
lead
agency
about
the
Superfund
process.
This
ICR
also
addresses
the
record
keeping
and
reporting
provisions
imposed
2
on
communities
when
those
communities
voluntarily
provide
feedback
on
community
involvement
activities.
Community
involvement
related
to
NCP
requirements
and
community
feedback
may
occur
during
all
phases
of
the
Superfund
process
including,
pre­
remedial,
remedial,
removal
(
short­
term
response
actions),
and
operation
and
maintenance
(
which
may
include
such
activities
as
ground
water
and
air
monitoring,
inspection
and
maintenance
of
the
treatment
equipment
remaining
on
site,
and
maintenance
of
any
security
measures
or
institutional
controls.)
Specifically,
members
of
the
community
surrounding
a
Superfund
site
may
participate
in
community
interviews
(
40
CFR
300.43(
c))
conducted
by
EPA
in
order
to
prepare
a
CIP
or
serve
on
Technical
Assistance
Grant
(
TAG)
groups,
as
provided
for
in
Superfund
Amendments
and
Reauthorization
Act
of
1986
(
SARA),
as
well
as
in
Community
Advisory
Groups
(
CAGs),
as
provided
in
Superfund
Administrative
Reforms.
Community
groups
focused
on
the
technical
assistance
provided
through
the
Technical
Outreach
Services
for
Communities
(
TOSC)
program
may
also
participate.
Participation
may
also
take
the
form
of
attending
formal
and
informal
meetings,
open
houses
and
public
availability
sessions,
responding
to
telephone
interviews,
and/
or
participation
in
focus
groups.

The
purpose
of
these
community
involvement
activities
is
to
provide
a
process
for
engaging
in
dialogue
and
collaboration
with
communities
affected
by
Superfund
sites.
EPA
community
involvement
is
founded
on
the
belief
that
people
have
a
right
to
know
what
the
Agency
is
doing
in
their
community
and
to
have
a
say
in
it.
Its
purpose
is
to
give
people
the
opportunity
to
become
involved
in
the
Agency's
activities
and
to
help
shape
the
decisions
that
are
made.
Remedies
that
have
community
concerns
and
interests
factored
into
them
are
less
controversial
and
more
likely
to
be
accepted.
Community
involvement
is
the
vehicle
EPA
uses
to
get
community
concerns
and
interests
to
the
decision­
making
table.

The
Office
of
Emergency
and
Remedial
Response,
Office
of
Solid
Waste
and
Emergency
Response
within
the
U.
S.
Environmental
Protection
Agency
(
EPA)
is
responsible
for
implementing
the
Superfund
program.
EPA
regions
are
responsible
for
oversight
of
State
and
local
organizations'
compliance
with
CERCLA
and
the
NCP,
including
reporting
and
record
keeping
requirements.

EPA
funds
state
activity
at
90%
from
the
CERCLA
Hazardous
Substances
Response
Trust
Fund
(
the
Fund)
for
state­
lead
activities
via
cooperative
agreements
with
EPA
as
provided
in
CERCLA
§
104(
d)(
1)(
42
USC
9604(
d)(
1)).
States
are
not
reimbursed
from
the
Fund
for
identification
of
state
sites
and
community
members
are
not
reimbursed
for
participation
in
community
involvement
activities.
Despite
the
fact
that
community
members
are
not
reimbursed
for
their
time,
this
ICR
estimates
the
time
costs
imposed
on
community
members
who
voluntarily
participate
in
community
activities
tied
to
the
Superfund
process.

During
the
three­
year
period
covered
by
this
ICR,
EPA
estimates
that
states
will
have
the
lead
role
at
30
sites
that
are
in
various
stages
of
the
remedial
phase
and
that
states
will
identify
state
ARARs
at
120
sites.
The
total
burden
on
state
governments
for
the
three­
year
information
collection
period
is
estimated
to
be
503,730
hours
at
an
estimated
cost
of
$
149,160
(
not
including
the
costs
reimbursed
by
the
Federal
government).
EPA
further
estimates
that
community
members
will
voluntarily
incur
a
burden
for
participation
activities
equaling
53,850
hours
at
an
estimated
cost
of
$
2,027,940
over
the
three­
year
period
of
this
ICR.
3
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
OF
INFORMATION
2(
a)
Need/
Authority
for
the
Collection
of
Information
CERCLA
authorizes
the
President
to
undertake
removal
and
remedial
actions
in
response
to
releases
or
threats
of
releases
of
hazardous
substances
and
certain
pollutants
and
contaminants
into
the
environment.
Revisions
were
made
to
the
NCP
in
1982
to
incorporate
the
provisions
of
CERCLA.
These
revisions
to
the
NCP
established
procedures
for
data
collection,
analysis,
and
reporting
to
be
conducted
during
remedial
and
removal
responses
at
Superfund
sites.
Subsequent
revisions
to
the
NCP
in
1985
added
additional
procedures.
Finally,
the
Superfund
Amendments
and
Reauthorization
Act
of
1986
(
SARA)
amended
CERCLA
and
mandated,
among
other
provisions,
that
the
NCP
be
revised
within
18
months
of
the
date
of
enactment
of
SARA
to
incorporate
provisions
of
the
new
law
(
42
USC
9605(
b)).
The
revised
NCP,
published
in
March
1990,
included
new
reporting
and
record
keeping
provisions
for
Superfund
remedial
responses.

EPA
uses
the
information
provided
by
the
states
to
ensure
state
actions
are
consistent
with
the
provisions
of
CERCLA
and
SARA
and
that
their
decisions
are
protective
of
human
health
and
the
environment.
EPA
uses
the
information
gathered
from
private
citizens
to
plan
activities
geared
to
educating
them
where
necessary,
keeping
them
informed
of
activities
within
the
community,
and
ensuring
they
have
had
an
opportunity
to
assume
an
active
role
in
the
decision
making
process
that
affects
their
community.
EPA
also
uses
information
from
private
citizens
to
measure
the
effectiveness
of
community
involvement
activities
and
to
improve
those
activities
as
needed.
EPA
believes
involvement
of
the
members
of
the
community
surrounding
a
Superfund
site
is
critical
to
ensuring
effective
site
cleanups.

There
have
been
no
statutory
or
regulatory
revisions
to
applicable
sections
of
the
NCP
since
the
previous
ICR
(
OMB
Control
No.
2050­
0096).
However,
the
previous
information
collection
request
for
the
NCP
included
estimates
for
the
burden
imposed
on
community
members
when
providing
feedback
to
EPA
for
purposes
of
the
Government
Performance
and
Results
Act
of
1993
(
GPRA).
For
the
purposes
of
this
ICR,
however,
EPA
is
not
including
an
estimate
for
GPRA­
related
reporting
activities.
This
change
emanates
from
the
fact
that
community
involvement
activities
are
not
part
of
the
EPA's
GPRA
reporting
requirements.
Also,
resources
and
time
limits
have
shifted
EPA's
focus
from
GPRA
evaluation
activities
to
a
focus
on
timely
feedback
of
community
involvement
activities
at
specific
sites.
Therefore,
this
ICR
contains
an
estimate
for
the
burden
imposed
on
community
members
when
they
provide
feedback
to
EPA
on
community
involvement
activities
but
excludes
a
burden
estimate
for
community
involvementrelated
GPRA
reporting.

Most
of
the
estimated
burden
in
this
ICR
is
for
the
information
collection
and
record
keeping
required
of
states
when
they
take
the
lead
in
remedial
activities
at
Superfund
sites.
States,
however,
are
not
required
to
take
on
the
role
of
the
lead
agency
in
remedial
responses;
rather,
they
choose
to
take
on
this
responsibility
and
receive
federal
funding
at
90%
to
compensate
their
efforts.
A
state
may
take
the
lead
when
EPA
determines
that
a
state's
technical
and
oversight
capabilities
are
adequate
to
ensure
compliance
with
Federal
standards
(
42
USC
9604(
d)(
1)(
A)).
Furthermore,
when
states
do
take
the
lead
role
at
NPL
sites,
they
are
reimbursed
by
the
Fund
for
their
work.
The
burden
hours
estimated
in
this
ICR
for
state­
lead
sites,
therefore,
represent
responsibilities
that
states
accept
voluntarily
and
for
which
they
are
compensated.
4
The
reporting
and
record
keeping
requirements
imposed
on
states
when
taking
a
lead
role
is
necessary
to
ensure
that
states
perform
remedial
responses
in
a
manner
consistent
with
CERCLA
and
the
NCP
(
42
USC
9604(
d)(
1)(
A)).
States
must
identify
state
ARARs
for
each
site
in
order
to
ensure
that
standards
that
are
more
stringent
than
Federal
requirements
are
considered
when
selecting
a
remedy
(
42
USC
9621(
d)).
Community
interviews
are
needed
to
prepare,
and
revise
as
necessary,
a
Community
Involvement
Plan
(
CIP)
for
a
site
in
order
to
ensure
public
involvement
in
site­
related
decisions
and
provide
appropriate
opportunities
for
the
community
to
learn
about
the
site
and
to
develop
community
groups
to
participate
in
site
activities
(
42
USC
9617).
Focus
groups
are
needed
to
establish
baselines
and
measure
the
results
of
various
community
involvement
activities.

2(
b)
Use/
Users
of
the
Data
The
lead
agency,
whether
EPA
or
the
state,
conducts
many
data­
gathering
activities,
including
development
of
the
RI/
FS
and
the
preparation
of
the
Proposed
Plan
and
the
ROD.
This
data
is
used
by
the
lead
agency
to
make
informed
decisions
regarding
remedial
responses.
When
states
assume
the
lead
responsibility,
EPA
Regions
use
the
information
collected
to
oversee
states
in
the
conduct
of
remedial
responses
at
hazardous
waste
sites.
Specifically,
this
information
is
used
to
ensure
that
remedies
are
selected
in
accordance
with
CERCLA
and
the
NCP,
that
cleanup
standards
are
attained,
and
that
community
concerns
are
appropriately
addressed.
The
data
are
also
made
available
to
the
public
and
may
help
community
members
understand
health
risks
and
participate
in
site­
related
decisions.

States
also
identify
state
ARARs
at
all
state­
and
Federal­
lead
sites
during
the
RI/
FS.
The
ARARs
are
used
to
determine
cleanup
levels
and
to
select
the
remedy
to
be
used
at
a
site.

Community
interviews
and
information
provided
by
community
groups
are
used
by
the
lead
agency
to
ensure
public
involvement
in
site­
related
decisions,
as
required
by
CERCLA
and
SARA,
and
provide
appropriate
opportunities
for
the
community
to
learn
about
the
site.
EPA
uses
the
information
gathered
through
research
instruments
to
obtain
timely
feedback
on
the
community
involvement
process
at
the
site
level.

3.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
3(
a)
Respondents
The
two
categories
of
respondents
for
the
activities
addressed
in
this
ICR
are
state
governments
and
individuals
(
i.
e.,
community
members
surrounding
Superfund
sites).
States
are
the
only
appropriate
source
for
collecting,
reporting,
and
maintaining
data
when
they
have
the
lead
at
NPL
sites;
community
members
are
the
only
appropriate
source
for
site­
specific
public
input,
and
for
advising
on
whether
EPA
community
involvement
activities
have
been
successful
in
providing
understandable
information
and
meaningful
opportunities
to
participate
in
the
process.

3(
b)
Information
Requested
(
I)
Data
Items
This
section
describes
the
data
items
that
must
be
reported
or
maintained
by:
(
1)
states
at
state­
lead
sites;
(
2)
states
at
all
other
sites;
and
(
3)
community
members
at
all
sites.
5
(
1)
State
Activities
at
State­
Lead
Sites
At
a
state­
lead
site,
the
state
must
conduct
the
following
activities
in
order
to
be
consistent
with
CERCLA:


Develop
an
RI/
FS;


Prepare
a
Proposed
Plan;


Develop
a
ROD;


Prepare
and
update
a
CIP;


Prepare
an
engineering
design
fact
sheet;
and

Establish
information
repositories.

The
Remedial
Investigation
and
Feasibility
Study
The
first
step
in
conducting
the
RI/
FS,
which
is
authorized
under
CERCLA
§
104
(
42
USC
9604(
a)(
1);
40
CFR
300.430),
is
the
development
of
a
project
plan,
which
describes
the
scope
and
content
of
the
RI/
FS
and
includes
work
plans.
Work
plans
are
developed
as
part
of
the
project
plan
and
detail
the
site
management
strategy.
The
work
plans
identify
initial
boundaries
of
the
study
area,
likely
remedial
response
objectives,
operable
units
(
if
any),
and
the
procedures
that
will
be
followed
to
satisfy
the
strategy.
In
addition,
an
initial
site
evaluation
is
presented
in
the
typical
work
plan.
This
evaluation
includes:


Site
description;


Preliminary
definition
of
the
contamination
problems;


Likely
contaminant
migration
pathways;


Environmental
and
health
effects
associated
with
migration;
and

Description
of
any
initial
remedial
measures
for
the
site.

A
preliminary
assessment
of
remedial
alternatives
may
be
included
in
the
work
plan.
The
data
requirements
necessary
to
support
the
selection
of
a
remedy
also
are
discussed.

Based
on
preliminary
site
information,
the
objectives
and
the
scope
of
work
for
the
RI
and
FS
are
developed.
The
scope
of
work
for
the
RI
includes
many
components,
including
plans
for
project
operations
that
will
be
followed
in
conducting
a
survey
of
the
study
area,
in
characterizing
the
source
of
contamination,
and
in
identifying
Federal
and
state
ARARs.
The
work
plan
also
includes
procedures
that
will
be
followed
in
evaluating
contamination
pathway
and
transport,
and
in
evaluating
the
potential
risk
to
public
health
posed
by
the
site.
Plans
for
testing
the
feasibility
of
remedial
technologies
also
may
be
included.
Initial
data
quality
objectives,
quality
assurance
procedures
that
will
be
followed,
procedures
to
be
followed
in
preparing
the
RI
report,
and
information
on
the
technical
and
financial
management
of
the
RI
project
also
are
discussed
in
the
RI
scope
of
work
section
of
a
site
work
plan.

The
sampling
and
analysis
plan
for
a
site
also
is
developed
during
the
scoping
phase
of
the
RI.
This
plan
describes
the
sampling,
calibration,
and
analytical
procedures
that
will
be
followed
in
collecting
air,
water,
soil,
and
source
samples.
Quality
assurance
objectives
to
be
met
throughout
the
sampling
task
also
are
discussed.
These
objectives
include
procedures
that
will
be
followed
to
ensure
the
accuracy
and
precision
of
the
analysis,
as
well
as
the
completeness,
representativeness,
and
comparability
of
the
sampling.
Hundreds
of
samples
are
taken
during
the
typical
RI,
and
the
analysis
of
the
site
samples
provides
basic
information
on
the
concentration,
source,
and
potential
6
paths
of
migration
of
contaminants
at
a
site.
Sampling
and
analysis
plans
generally
include
a
project
description
that
summarizes
the
site
history,
environmental
setting,
and
project
objectives
such
as
the
media
to
be
sampled,
sampling
locations
on
the
site,
and
sampling
schedule.
A
health
and
safety
plan
also
is
drafted
that
identifies
potentially
hazardous
operations
and
exposures,
and
prescribes
appropriate
protective
measures.

In
the
scope
of
work
for
the
FS,
procedures
are
established
for
developing
remedial
alternatives
for
the
site.
Alternative
screening
and
analysis
procedures,
methods
for
conducting
a
comparative
evaluation
of
acceptable
alternatives,
and
details
on
preparing
the
FS
report
also
are
included.

Concurrent
with
the
preparation
of
the
RI
work
plan,
EPA
conducts
community
interviews,
as
required
by
the
NCP,
in
preparation
for
the
required
Community
Involvement
Plan,
which
must
be
finalized
before
any
RI
field
work
begins.

Upon
completion
and
approval
of
the
work
plans
and
sampling
and
analysis
plans,
the
RI/
FS
can
begin.
The
RI/
FS
includes
site
work,
analysis
of
data,
and
preparation
of
the
RI
report.
Drilling
and
sampling
detailed
in
the
sample
and
analysis
plan
requires
not
only
time
spent
at
the
site
boring
holes
in
the
earth
and
taking
air
and
water
samples,
but
also
time
to
mobilize
drilling
equipment
and
to
train
personnel
in
the
sampling
and
decontamination
techniques
to
be
used
at
the
site.
Upon
completion
of
the
site
work,
the
samples
are
sent
to
a
laboratory
for
evaluation,
and
the
results
of
the
analyses
are
verified.
Standard
evaluation
techniques
include
analyzing
samples
for
organics,
metals,
and
cyanide.

The
RI
serves
as
the
mechanism
for
collecting
data
for
site
and
waste
characterization
and
for
conducting
treatability
testing
as
necessary
to:
(
1)
evaluate
the
performance
and
cost
of
the
treatment
technologies
considered
for
use
at
a
site;
and
(
2)
support
the
design
of
selected
remedies.
The
FS
serves
as
the
mechanism
for
the
development,
screening,
and
detailed
evaluation
of
potential
remedial
alternatives.
The
RI
and
FS
are
conducted
concurrently.
Data
collected
in
the
RI
influence
the
development
of
remedial
alternatives
in
the
FS,
which
in
turn
affects
the
data
needs
and
scope
of
treatability
studies
and
additional
field
investigations.
The
site
characterization
developed
during
the
RI
provides
the
data
necessary
to
estimate
the
risks
to
human
health
and
the
environment
posed
by
a
site,
to
establish
cleanup
goals
or
ranges,
and
to
identify
viable
cleanup
alternatives.
The
FS
draws
upon
the
data
collected
and
analyzed
during
the
RI
in
the
process
of
developing
alternatives
and
conducting
a
detailed
analysis
of
the
most
viable
alternatives.
Because
of
the
interactive
nature
of
this
process,
the
sequence
of
the
various
phases
and
associated
activities
frequently
will
not
be
distinct
in
practice.

A
risk
assessment
is
conducted
during
the
RI
to
estimate
the
health
consequences
of
exposure
to
contaminants
at
a
site.
In
this
assessment,
the
physical
and
chemical
properties
of
hazardous
substances
and
their
toxicological
effects
are
studied
to
determine
the
potential
for
the
substances
to
cause
adverse
health
effects,
and
the
likely
pathways
and
magnitude
of
exposure
of
populations
and/
or
individuals
near
the
site.
An
evaluation
of
dose­
response
information
also
is
completed
to
estimate
the
health
effects
(
e.
g.,
incident
of
certain
diseases)
that
may
result
from
exposure
to
the
hazardous
or
toxic
substances
at
a
site.

A
risk
characterization
brings
together
the
exposure
and
the
dose­
response
information
to
predict
the
likely
range
and
severity
of
health
effects
that
may
occur
as
a
result
of
the
substances
at
a
site,
and
the
number
of
people
affected.
Included
as
an
integral
part
of
the
risk
assessment
7
process
is
the
uncertainty
evaluation,
which
identifies
the
degree
of
uncertainty
associated
with
the
final
risk
estimates
by
identifying
uncertainties
related
to
the
data
and
the
assumptions.
This
evaluation
of
uncertainties
places
bounds
on
the
final
estimate
and
targets
areas
needing
improvement.

The
FS
process
includes
the
initial
evaluation
and
screening
of
a
number
of
potential
alternatives.
Alternatives
are
eliminated
from
further
evaluation
for
a
number
of
reasons,
including
technical
problems,
lack
of
effectiveness
in
the
long
term
or
short
term,
failure
to
protect
human
health
and
the
environment,
cost,
or
implementation
time.
The
universe
of
potential
remedies
is
reduced
to
a
reasonable
number
(
usually
between
three
and
five)
of
good
alternatives
on
which
detailed
analyses
are
conducted.
If
existing
site
and
treatment
data
are
insufficient
to
evaluate
the
alternatives
adequately,
treatability
tests
may
be
necessary
to
evaluate
a
particular
technology
or
specific
site
wastes.
Treatability
tests
generally
involve
bench­
scale
testing
to
assess
the
feasibility
of
a
technology,
although
a
pilot­
scale
study
may
be
required
in
a
few
situations.

Once
sufficient
data
are
available,
alternatives
are
evaluated
in
detail
with
respect
to
nine
evaluation
criteria:
protection
of
human
health
and
the
environment;
compliance
with
ARARs;
long­
term
effectiveness
and
permanence;
reduction
of
toxicity,
mobility,
or
volume;
short­
term
effectiveness;
implementability;
cost;
support
agency
acceptance;
and
community
acceptance.
The
alternatives
are
evaluated
individually
against
each
criterion
and
then
relative
to
other
alternatives
to
understand
completely
the
strengths
and
weaknesses
of
each
alternative.
At
the
end
of
this
analysis
process,
the
RI/
FS
report
is
prepared.

For
purposes
of
this
analysis,
EPA
estimates
that
there
will
be,
on
average,
40
RI/
FS
starts
per
year.
It
is
estimated
that
a
state
will
take
the
lead
on
ten
new
sites
per
year,
on
average,
over
the
three­
year
ICR
period,
and
that
the
Federal
government
will
take
the
lead
on
the
remaining
30
sites
per
year.
In
this
analysis,
it
is
assumed
that,
for
any
given
year,
ten
state­
lead
sites
will
be
in
the
first
year
of
the
RI/
FS
process,
ten
will
be
in
the
second
year,
and
ten
will
be
in
the
final
year,
for
a
total
of
30
state­
led
sites
per
year
in
the
RI/
FS
process.
This
ICR
does
not
address
the
burden
on
the
Federal
government
for
Federal­
lead
activities
in
the
RI/
FS
process
(
except
to
the
extent
that
community
activities
are
conducted).
The
cost
to
the
Federal
government
of
reviewing
state­
lead
site
activities
is
addressed,
and
the
full
costs
to
the
states
are
discussed.

The
Proposed
Plan
The
requirement
to
issue
a
Proposed
Plan
was
added
to
the
remedial
process
by
SARA,
(
42
USC
9617(
a);
40
CFR
300.430(
f)(
2)).
This
document
is
to
be
prepared
by
the
lead
agency,
in
consultation
with
the
support
agency,
at
a
site
after
completion
of
the
RI/
FS
report
and
prior
to
selection
of
a
response
action.
The
lead
agency's
primary
objective
in
preparing
and
releasing
the
Proposed
Plan
is
to
seek
public
comment
on
the
preferred
alternative
for
addressing
a
problem
at
a
site,
and
on
the
other
alternatives
discussed
in
the
detailed
analysis
section
of
the
RI/
FS.

The
Proposed
Plan
is
written
using
information
from
the
RI/
FS
report.
The
purpose
of
the
Proposed
Plan
is
to
highlight
the
RI/
FS
report,
provide
a
brief
analysis
of
remedial
alternatives
under
consideration,
identify
a
preferred
alternative,
and
provide
the
public
with
information
on
how
they
can
participate
in
the
remedy
selection
process.

In
developing
the
Proposed
Plan,
the
lead
and
support
agencies
first
review
the
RI/
FS
8
report
prepared
for
a
site,
identify
an
initial
preferred
alternative,
and
prepare
a
draft
Proposed
Plan.
The
lead
agency's
management
is
briefed
on
the
draft
Proposed
Plan,
which
is
then
forwarded
to
the
support
agency
for
comments.
At
the
end
of
the
support
agency
review
period,
the
Proposed
Plan
is
finalized
and
released
to
the
public
for
comment.

CERCLA,
as
amended,
also
requires
the
lead
agency
to
publish
a
brief
notice
and
description
of
the
Proposed
Plan
in
a
local
newspaper
of
general
circulation.
As
required
by
CERCLA
§
117(
a)
(
42
USC
9617(
a)),
this
notice
includes
information
sufficient
to
provide
a
reasonable
explanation
of
the
preferred
alternative
and
the
other
alternatives
studied.
This
notice
will
also
announce
the
availability
of
the
RI/
FS
report
and
any
planned
public
participation
activities,
especially
the
required
Proposed
Plan
Public
Meeting
and
30­
day
comment
period.

Finally,
CERCLA
§
l17
requires
the
lead
agency
to
offer
the
opportunity
for
a
public
meeting
to
discuss
and
answer
questions
and
to
obtain
feedback
about
the
RI/
FS
report
and
the
Proposed
Plan.
The
lead
agency
establishes
a
date
and
time
for
the
meeting,
reserves
a
facility,
and
arranges
for
any
special
needs.
The
lead
agency
also
designs
the
meeting
program,
including
identifying
specific
issues
and
tasks
to
be
addressed,
preparing
an
agenda,
identifying
presenters,
and
rehearsing
presentations.
Printed
materials,
visual
aids
or
graphics,
and
other
materials
are
prepared
and
special
arrangements
made,
such
as
hiring
a
court
reporter.
Finally,
the
meeting
is
held,
and
a
transcript
of
the
meeting
notes
is
prepared
by
the
lead
agency.
The
transcript
is
made
available
to
the
public
as
required
by
CERCLA
§
117.

In
preparing
the
Proposed
Plan,
states
are
the
lead
agency
for
an
estimated
ten
new
sites
per
year
and
the
Federal
government
is
the
lead
agency
for
an
estimated
30
sites
per
year.
Only
the
full
costs
to
the
states,
of
conducting
community
activities
and
preparing
a
proposed
plan,
are
discussed.

The
Record
of
Decision
The
lead
agency
prepares
a
ROD
in
response
to
the
statutory
requirements
in
CERCLA
§
l13
(
42
USC
9613)
for
a
statement
of
basis
and
purpose
of
the
selected
remedy
at
a
site
and
in
CERCLA
§
117
(
42
USC
9617),
which
calls
for
a
remedial
action
plan
to
be
adopted
and
released
to
the
public.
The
ROD
is
prepared
by
the
lead
agency
in
consultation
with
the
support
agency
for
a
site.
It
is
the
decision
document
used
to
describe
the
selected
remedy
for
a
site
or
a
particular
component
of
a
site
(
e.
g.,
geographic
area,
pathway,
or
source
control),
and
to
explain
the
rationale
for
the
selected
remedy.
In
addition,
RODs
demonstrate
the
lead
agency's
decisionmaking
process
has
been
carried
out
in
accordance
with
CERCLA
and
the
NCP.
RODs
typically
have
three
major
sections:
the
Declaration,
the
Decision
Summary,
and
the
Responsiveness
Summary.
All
RODs
are
signed
by
EPA
Regional
Administrators
or
the
Assistant
Administrator
for
OSWER.
In
addition,
a
representative
from
a
state
may
sign
a
ROD.

The
Declaration
is
the
formal
statement
(
signed
by
the
EPA
Regional
Administrator
or
the
Assistant
Administrator
of
OSWER)
which
affirms
that
the
selected
remedy
for
a
site
is
selected
in
accordance
with
CERCLA
and
is
consistent,
to
the
extent
practicable,
with
the
NCP.
It
provides
a
brief
description
of
the
selected
remedy.

The
Decision
Summary
is
the
focus
of
the
ROD.
The
Summary
begins
with
a
brief
discussion
of
the
site
history
and
a
detailed
site
description,
including:
9

Site
area
and
topography,


Adjacent
land
uses;


Natural
resource
uses;


Distance
to
nearby
populations;


General
water
resources,
and

Surface
and
subsurface
features.

Next,
the
history
of
state
and
Federal
site
investigations
and
CERCLA
enforcement
actions
at
the
site
are
summarized.
This
historical
summary
is
followed
by
a
discussion
of
the
community
involvement
activities
that
have
been
conducted
for
the
site.

The
Decision
Summary
then
summarizes
the
scope
of
the
response
action
and
the
site
characteristics.
The
site
characteristics
section
draws
on
information
presented
in
the
RI/
FS
report
and
includes
details
on:


Types,
quantity,
and
concentration
of
hazardous
substances
at
a
site:


All
known
or
suspected
sources
of
contamination;


All
known
or
potential
routes
of
migration,
including
the
mobility,
toxicity,
and
volume
of
waste;


Lateral
and
vertical
extent
of
contamination
at
the
site;
and

Potential
surface
and
subsurface
pathways
of
migration.

Maps
illustrating
the
location
of
units
or
contaminants
and
charts
of
contaminant
types
and
concentrations
often
are
used
in
the
site
characterization
section
of
the
Decision
Summary.
In
addition,
the
results
of
the
site
risk
assessment
and
any
significant
changes
made
to
the
preferred
alternative
in
the
Proposed
Plan
are
summarized.

Another
major
component
of
the
Decision
Summary
is
the
evaluation
of
the
remedial
alternatives
considered
for
the
site
and
identification
of
the
selected
remedy.
The
evaluation
of
alternatives
section
first
presents
a
brief
description
of
each
of
the
remedial
alternatives.
Each
alternative
for
which
a
detailed
analysis
was
completed
(
typically
five)
is
discussed.
These
discussions
include:


Summaries
of
the
technology
considered,
such
as
in­
situ
treatment,
clean
closure,
or
thermal
treatment;


The
type
and
quantity
of
waste
to
be
contained
or
treated;
and

The
major
ARARs
and
standards
being
met
or
utilized
for
specific
components
of
the
waste
management
process.

The
estimated
capital
and
O&
M
costs,
as
well
as
estimated
implementation
time
of
alternatives,
also
are
presented.
A
comparative
analysis
is
presented
in
which
the
remedial
alternatives
are
evaluated
based
on
the
nine
criteria
described
under
the
RI/
FS
process
and
comments
on
the
proposed
plan.
At
the
end
of
this
analysis,
the
selected
remedy
is
highlighted
as
a
remedy
that
meets
the
statutory
requirements
of
CERCLA
and
provides
the
best
balance
among
the
evaluation
criteria.

The
Decision
Summary
concludes
with
a
detailed
discussion
of
the
selected
remedy.
The
summary
presents
the
risk
levels
to
be
attained
after
implementation
of
the
remedy
and
summarizes
the
cleanup
objectives
for
the
different
media
at
the
site.
Finally,
the
selected
remedy
10
section
of
the
Decision
Summary
demonstrates
that
the
selected
remedy
complies
with
the
statutory
requirements
in
CERCLA
§
121
(
42
USC
9621),
that
is,
the
remedy
will
protect
human
health
and
the
environment,
attain
Federal
and
state
ARARs,
be
cost­
effective,
and
utilize
permanent
solutions
and
alternative
treatment
technologies
or
resource
recovery
technologies
to
the
maximum
extent
practicable.
A
discussion
of
the
extent
to
which
the
selected
remedy
fulfills
the
statutory
preference
for
treatment
that
reduces
the
mobility,
toxicity,
or
volume
of
the
principal
threats
at
a
site
also
is
presented
in
this
section.

The
final
component
of
the
ROD
is
the
Responsiveness
Summary,
which
is
a
requirement
in
CERCLA
§
117
(
42
USC
9617).
This
part
summarizes
the
written
and
oral
public
comments
received
on
the
RI/
FS
report,
the
Proposed
Plan,
and
the
administrative
record
and
the
lead
agency's
responses
to
each
major
category
of
comments.
The
Responsiveness
Summary
not
only
provides
decision
makers
with
information
about
community
preferences
regarding
the
remedial
alternatives
considered
for
a
site,
but
also
demonstrates
to
the
public
how
their
comments
were
taken
into
account
as
an
integral
part
of
the
decision
making
process.

In
preparing
the
Responsiveness
Summary,
background
research
is
done
to
identify
citizen
input
and
concerns.
In
this
process,
transcripts
of
the
public
meeting
on
the
RI/
FS
report
and
the
Proposed
Plan
are
reviewed,
major
public
comments
are
organized
and
summarized,
and
the
lead
agency's
responses
to
these
comments
are
prepared.
The
level
of
effort
to
be
devoted
to
this
section
of
the
ROD
varies,
depending
in
part
on
the
number,
length,
and
complexity
of
comments
and
the
number
of
policy
issues
outstanding
at
a
site.

EPA
estimates
as
many
as
45
sites,
on
average,
will
issue
a
ROD
each
year
and
conduct
the
required
community
activities.
It
is
estimated
that
ten
of
the
sites
issuing
RODs
each
year
will
be
state­
lead
sites
and
that
the
remaining
35
sites
will
be
Federal­
lead
sites.
It
must
also
be
noted
here
that,
although
CERCLA
and
SARA
require
only
two
community
involvement
activities
in
the
post­
ROD
stages
of
remedial
design
and
construction,
EPA's
experience
is
that
this
is
the
most
disruptive
part
of
the
process
for
the
affected
community
and,
therefore,
the
one
most
likely
to
draw
intense
public
interest.
EPA
has
found
that
it
is
in
the
Agency's
best
interests,
as
well
as
the
public's,
to
continue
its
community
involvement
activities
at
the
same
level,
if
not
at
a
higher
level,
as
during
the
RI/
FS
stage.
Only
the
full
costs
to
the
states
associated
with
conducting
community
activities
and
preparing
the
ROD
are
discussed.

Community
Involvement
Plan
(
CIP)

Community
Involvement
Plans
are
developed
at
remedial
sites
to
identify
community
concerns
and
to
select
techniques
and
approaches
to
use
in
addressing
these
concerns.
The
initial
CIP
developed
for
a
site
presents
the
community
involvement
program
that
is
to
be
followed
during
the
RI/
FS
stage
of
the
remedial
phase.
The
NCP
requires
the
CIP
be
completed
and
in
place
before
field
work
begins
for
the
RI.
However,
as
the
Agency
seeks
to
accomplish
RI
field
work
during
pre­
remedial
actions
to
expedite
cleanups,
EPA
is
finding
it
necessary
to
begin
its
community
involvement
activity,
including
preparation
of
the
CIP,
very
early
in
the
pre­
remedial
phase.
The
NCP
also
requires
that
EPA
review
its
CIP
prior
to
the
Remedial
Design/
Remedial
Action
phase,
and
make
any
changes
necessary
to
accommodate
changes
in
the
community.

The
initial
steps
in
the
preparation
of
CIPs
involve
conducting
a
review
of
the
site
and
the
surrounding
community.
Lead
agency
technical
personnel
summarize
the
problems
at
a
site,
the
origins
of
those
problems,
and
potential
steps
for
addressing
the
problems.
As
part
of
this
11
process,
lead
agency
files
on
the
site
are
reviewed
and
local
newspaper
files
are
searched.
Once
a
basic
understanding
of
the
site
and
previously
performed
activities
is
established,
community
involvement
personnel
from
the
lead
agency
conduct
interviews
with
local
community
members
to
better
determine
community
concerns
and
the
level
of
community
knowledge
of
site
activities.
In
this
process,
a
contact
list
is
prepared,
interviews
are
scheduled
and
conducted,
and
the
results
of
the
interviews
are
summarized.
This
process
also
includes
the
use
of
interviews
for
the
purpose
of
establishing
baseline
measures
of
citizen
concerns
and
attitudes
from
which
changes
can
be
measured,
as
well
as
to
gain
additional
information
that
will
help
in
the
preparation
of
the
CIP.

Once
the
background
research
is
completed,
a
community
involvement
program
is
designed.
This
program
may
recommend
such
activities
as
distributing
information
brochures
and
fact
sheets
that
explain
Superfund
program
activities
and
the
role
of
the
lead
agency
in
remediating
Superfund
sites.
Small
group
meetings
between
lead
agency
staff,
citizens,
and
local
officials
may
be
held
to
promote
an
informal
exchange
of
ideas.
To
maximize
the
potential
to
bring
about
improvement
in
government
services,
EPA
will
utilize
telephone
interviews
of
fact
sheet
recipients
and
meeting
attendees
to
assess
the
effectiveness
of
specific
outreach
products.
EPA
may
also
use
focus
groups
to
gather
citizen
input.
At
some
sites,
formal
community
groups
are
established
that
provide
regular
involvement
and
input
to
site
activities.

Prior
to
commencement
of
the
Remedial
Design/
Remedial
Action
stage,
the
CIP
is
reviewed
to
determine
whether
it
should
be
revised
to
address
the
community
concerns
at
that
time.
In
addition,
GPRA
requires
that
government
plans
be
written
as
5­
year
plans
that
are
renewed
every
three
years;
this
cycle
will
be
followed
at
all
active
sites
throughout
the
duration
of
remedial
activities.
The
process
for
preparing
the
revised
CIP
is
essentially
the
same
as
that
followed
in
preparing
the
initial
CIP:


Background
research
is
conducted
on
activities
that
have
occurred
since
the
Plan
was
first
written
or
last
revised;


Community
interviews
are
planned
and
conducted;


The
community
involvement
program
is
revised
to
address
the
current
citizen
concerns;
and

The
CIP
document
is
revised.

It
is
estimated
that
a
CIP
will
be
developed
and/
or
revised
at
not
more
than
120
sites
each
year,
on
average.
It
is
estimated
that
ten
of
the
sites
developing
new
CIPs
each
year
will
be
statelead
sites,
30
sites
developing
new
CIPs
will
be
Federal­
lead
sites,
and
the
remaining
80
sites
revising
CIPs
will
be
Federal­
lead
sites.
For
the
Federal
government,
only
the
costs
of
conducting
the
community
activities
and
reviewing
state­
lead
site
activities
are
addressed
in
this
ICR.
The
full
cost
to
the
states,
of
conducting
community
activities
and
preparing
and
revising
the
CIP,
as
well
as
the
costs
to
the
public
for
participating
in
the
process
are
discussed.
12
Engineering
Fact
Sheets
In
addition
to
developing
a
CIP,
lead
agencies
must
distribute
a
fact
sheet
explaining
the
final
engineering
design
to
the
community
and
other
interested
parties.
The
fact
sheet
serves
to
inform
the
public
about
activities
related
to
the
final
design,
including
the
schedule
for
implementing
the
remedy,
physical
changes
that
may
result
in
the
site's
appearance,
and
an
explanation
of
the
various
agency
roles.
Site
health
and
safety
plans,
emergency
procedures,
and
any
potential
inconveniences
that
may
occur
also
are
explained.
With
the
increasing
number
of
sites
moving
into
this
stage
of
Superfund,
EPA
is
experiencing
an
increase
in
public
interest
in
the
design
and
construction
stages
not
previously
anticipated.
As
the
number
of
constructions
increase,
EPA
anticipates
a
corresponding
shift
in
the
community
involvement
workload
(
including
fact
sheets,
etc.)
from
the
pre­
ROD
stages
to
the
post­
ROD
stages
of
design
and
construction.

It
is
estimated
that
175
sites
per
year,
on
average,
will
distribute
a
fact
sheet.
It
is
estimated
that
ten
of
these
sites
will
be
state­
lead
sites
and
that
the
remaining
165
sites
will
be
Federal­
lead
sites.
Only
the
full
costs
to
the
states
are
discussed.

Information
Repositories
SARA
amended
CERCLA
§
113
to
require
that
an
administrative
record
for
the
selection
of
remedy
process
be
maintained
in
an
information
repository
near
each
site
and
be
made
available
to
the
public
(
42
USC
9613(
l)).
As
a
result,
two
records
are
compiled
and
maintained
for
each
remedial
response
 
one
near
the
site
and
one
in
the
offices
of
the
lead
agency
or
EPA
region.
Information
repositories
near
a
site
include
all
publicly
disclosed,
site­
related
documents.
In
developing
the
repositories,
an
appropriate
location
for
the
repository
must
be
identified.
This
location
must
be
publicly
accessible.
Then,
documents
to
include
in
the
repository
must
be
maintained
by
updating
information
as
necessary,
and
verifying
the
information
is
available
that
should
be
included
in
the
repository.
The
information
repository
will
be
maintained
as
long
as
site
remediation
continues
and
for
as
long
as
is
needed
in
the
event
there
is
litigation.
Because
remedial
responses
often
last
longer
than
three
years,
the
record
keeping
associated
with
remedial
responses
typically
will
be
maintained
for
more
than
three
years.

EPA
estimates
40
sites
per
year,
on
average,
will
set
up
an
information
repository.
Ten
of
these
sites
are
estimated
to
be
state­
lead
sites
and
the
remaining
30
sites
to
be
Federal­
lead
sites.
Only
the
full
costs
to
the
states
are
discussed.

(
2)
States
at
All
Other
Sites
SARA
added
a
requirement
to
CERCLA
§
121(
d)
(
42
USC
9621(
d))
that
all
remedial
actions
must
be
in
compliance
with
promulgated
state
ARARs
that
are
more
stringent
than
Federal
ARARs.
To
this
end,
the
current
revisions
to
the
NCP
require
states
to
identify
potential
state
ARARs
for
all
Fund­
financed
remedial
actions
(
i.
e.,
an
estimated
40
Federal­
and
state
lead
sites).
Potential
state
ARARs
are
to
be
identified
as
early
in
the
RI/
FS
process
as
possible.

(
3)
Community
Members
at
All
Sites
Section
300.430(
c)(
I)
of
the
NCP
requires
the
lead
agency
to
conduct
interviews
with
local
officials,
community
residents,
public
interest
groups,
or
other
interested
or
affected
parties
13
to
solicit
their
concerns
and
information
needs.
The
information
gained
during
these
interviews
is
used
to
develop
the
CIP,
or
to
revise
an
existing
one.
Community
members
who
elect
to
participate
in
interviews
do
not
have
to
submit
any
particular
data
items,
but
may
voluntarily
disclose
information
and
concerns.
In
addition,
community
members
at
some
sites
will
form
community
groups
that
meet
periodically
and
voluntarily
provide
advice
and
comment
to
the
lead
agency.
EPA
has
learned
that
informal
open
houses
and
public
information
availability
sessions
are
effective
methods
of
providing
information
to
the
public
and
soliciting
comments
on
site
activities.
For
purposes
of
this
analysis,
EPA
envisions
that
some
degree
of
community
participation
will
occur
at
as
many
as
175
different
Federal­
and
state­
lead
sites
annually.
1
This
estimate
allows
for
the
combined
effect
of
new
sites
(
40),
sites
where
formal
community
group
activities
take
place
(
35),
sites
where
community
interviews
are
conducted
for
CIP
revisions
(
80)
and
the
additional
sites
where
focus
groups
are
held
(
20).

(
II)
Respondent
Activities
(
1)
State
Activities
at
State­
Lead
Sites
In
complying
with
reporting
and
Record
keeping
requirements
at
state­
lead
sites,
state
employees
may
need
to:


Read
instructions;


Plan
activities;


Receive
training;


Gather
information;


Conduct
tests,
investigations,
and
studies;


Write
documents;


Process,
compile,
and
review
information
for
accuracy
and
appropriateness;


Complete
written
forms
or
other
paperwork;


Substantiate
claims
of
confidential
business
information;


Record
and
disclose
information;
and

Store,
file,
and
maintain
the
information.

(
2)
State
Activities
at
All
Other
Sites
In
identifying
ARARs,
state
employees
may
need
to:


Gather
information
on
new
state
laws
and
regulations;


Process,
compile,
and
review
information
for
accuracy
and
appropriateness;


Record
and
disclose
information;
and

Store,
file,
and
maintain
information.

(
3)
Community
Members
at
All
Sites
In
participating
in
the
remedial
phase,
community
members
may
disclose
information
to
Agency
personnel
during
interviews.
Community
members
may
perform
any
or
all
of
the
following
activities:
14

Participate
in
interviews;


Provide
comments;


Attend
informal
and
formal
meetings,
open
houses,
and
public
information
availability
sessions;


Participate
in
community
groups;


Participate
in
focus
groups;
and

Respond
to
surveys.

4.
INFORMATION
COLLECTED
­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
4(
a)
Agency
Activities
The
Agency
must
provide
oversight
for
all
state
activities
when
states
have
the
lead
in
conducting
Fund­
financed
remedial
activities.
As
part
of
its
oversight
role,
the
Agency
may
obtain,
review,
and
maintain
the
information
gathered
by
states.
The
Agency
also
reviews
state
ARARs
at
all
Superfund
sites.
At
Federal­
lead
sites,
the
Agency
conducts
interviews,
convenes
formal
and
informal
meetings,
open
houses,
and
public
information
availability
sessions,
distributes
surveys
and
reviews
results,
and,
in
some
cases,
provides
support
to
community
groups.

4(
b)
Collection
Methodology
and
Management
Currently,
states
provide
copies
of
documents
relating
to
site
activities
at
state­
lead
sites
and
to
ARARs
for
all
sites
to
EPA
Regional
offices.
EPA
Regions
review
the
documents
to
ensure
that
activities
undertaken
at
state­
lead
sites
are
consistent
with
the
NCP.
The
regions
also
conduct
public
interviews
and
convene
meetings
for
Federal­
lead
sites.
Regions
develop
written
summaries
from
the
interviews
and
meetings
for
use
in
developing
the
CIP.
The
summaries
are
stored
in
a
case
file
maintained
at
the
Regional
office.
For
site­
specific
feedback,
EPA
will
use
a
combination
of
telephone
interviews
and
focus
groups.

The
activities
reflected
in
this
ICR
do
not
lend
themselves
to
automation
because
of
the
decentralized
nature
of
each
remedial
activity.
These
activities
are
site­
specific
and,
therefore,
are
not
conducive
to
mass
data
collection
efforts.
The
NCP
does
not
specify
a
particular
method
of
accomplishing
information
collection;
the
use
of
improved
information
technology
is
not
prohibited
in
any
way.

4(
c)
Small
Entity
Flexibility
The
reporting
and
record
keeping
activities
addressed
in
this
ICR
do
not
affect
small
businesses.
The
remedial
phase
of
the
NCP
does
not
impose
any
general
information
collection
or
Record
keeping
requirements
on
small
businesses.
The
NCP
does
impose
burdens
on
community
members,
but
it
is
important
to
note
the
burden
to
individual
community
members
is
voluntarily
accepted
and,
therefore,
highly
flexible.

4(
d)
Collection
Schedule
Information
is
not
collected
at
any
specified
frequency,
other
than
that
already
addressed;
rather,
it
is
collected
as
needed
to
assure
the
site
action
progresses
in
a
timely
fashion.
15
5.
NON­
DUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
5(
a)
Non­
duplication
To
the
extent
information
already
exists
for
a
site,
the
lead
agency
is
encouraged
to
use
that
information
in
conducting
the
RI/
FS
and
in
developing
RODs
or
Proposed
Plans.
In
the
past,
there
has
been
duplication
of
effort
in
collection
of
some
site
samples
during
the
Site
Investigation
and
during
the
subsequent
RI.
Duplication
with
other
Federal
data
collection
activities
is
expected
to
be
minimal.

5(
b)
Consultations
In
addition
to
EPA
regional
offices,
state
representatives
participated
in
the
NCP
workgroup
meetings
leading
to
the
1990
NCP
revisions.
State
representatives
provided
guidance
on
how
to
avoid
problems
associated
with
implementation
of
the
NCP
requirements.
The
public
and
other
Federal
and
state
agencies
also
had
the
opportunity
to
submit
comments
on
the
proposed
revisions
to
the
NCP
(
53
FR
51394;
December
21,
1988).
These
comments
are
addressed
in
the
preamble
to
the
final
rule
and
in
the
Response
to
Comments
document
supporting
the
final
rule.

Agency
experience
in
addressing
community
issues
has
included
semi­
annual
or
annual
meetings
with
Regional
community
involvement
staff,
meetings
with
groups
of
states,
and
meetings
with
citizen
groups.

5(
c)
Effects
of
Less
Frequent
Collection
Other
than
noted
above,
information
is
not
collected
at
any
specified
frequency,
rather
it
is
collected
as
needed
to
assure
that
site
action
progresses
in
a
timely
manner.
The
information
collection
frequencies
in
the
NCP
are
the
minimum
amount
necessary
to
have
a
remedial
or
removal
program;
information
collection
frequencies
for
community
involvement
feedback
are
the
minimum
required
to
gather
meaningful
information.
Anything
less
would
render
the
program
ineffective
and
in
violation
of
CERCLA.

5(
d)
General
Guidelines
States
have
at
least
30
days
in
which
to
respond
to
any
information
requests
specified
in
the
NCP.
This
time
frame
is
in
compliance
with
the
Paperwork
Reduction
Act
guidelines.
The
record
retention
period
for
information
repositories
and
administrative
records
are
not
specified
explicitly
in
the
NCP;
rather,
these
records
and
repositories
are
to
be
maintained
as
long
as
necessary
for
litigation
purposes
and
for
the
duration
of
remedial
response
at
a
site.
Because
remedial
responses
typically
last
longer
than
three
years,
records
often
will
be
maintained
for
more
than
three
years.

5(
e)
Confidentiality
and
Sensitive
Questions
(
I)
Confidentiality
The
nature
of
the
data
being
gathered
as
part
of
this
information
collection
is
not
16
confidential.
Information
may
be
gathered
from
Potentially
Responsible
Parties
(
PRPs)
that
the
PRP
considers
to
be
Confidential
Business
Information
(
CBI).
When
information
is
designated
as
CBI
by
a
PRP,
EPA
follows
restricted
access
procedures
in
handling
the
information.
These
procedures
include
keeping
the
information
in
locked
areas
and
only
allowing
CBI­
cleared
personnel
access
to
the
information.
PRP
information
is
gathered
in
anticipation
of
litigation.
EPA,
therefore,
does
not
have
to
grant
Freedom
of
Information
Act
requests
for
this
information.

Lists
of
participants
in
community
interviews
and
lists
of
attendees
of
public
meetings
are
not
confidential.
Some
data
gathered
during
community
interviews
may
not
be
releasable,
however,
due
to
privacy
concerns.

(
ii)
Sensitive
Questions
The
information
gathering
activities
discussed
in
this
ICR
generally
do
not
involve
any
sensitive
questions.
The
Agency
has
found,
however,
that
some
information
gathered
during
community
interviews
may
be
sensitive
information
with
respect
to
privacy
concerns.

6.
ESTIMATED
BURDEN
AND
COST
OF
THE
COLLECTION
OF
INFORMATION
6(
a)
Respondent
Unit
Burdens
(
Hours)

This
section
presents
the
burden
of
the
NCP
remedial
program
requirements
to
respondents
in
terms
of
the
time
(
in
hours)
spent
to
comply
with
the
reporting
and
record
keeping
requirements.
Respondents
include
states
and
the
public.
States
incur
an
annual
burden
at
a
limited
number
of
hazardous
waste
sites
where
they
have
responsibility
for
implementing
remedial
activities
(
i.
e.,
ten
out
of
30
sites).
States
also
incur
a
burden
for
providing
information
on
state
ARARs
at
all
40
NPL
sites
where
RI/
FSs
are
started.
The
public
is
also
expected
to
incur
an
annual
burden
for
community
interviews
and
other
community
activities
conducted
in
conjunction
with
the
preparation
of
a
CIP
and
other
activities
at
each
of
the
up
to
175
sites,
including
the
40
NPL
sites
added
to
the
remedial
process
on
an
annual
basis
(
i.
e.,
both
Federal­
and
state­
lead
sites).
The
annual
burden
to
the
Federal
government
to
conduct
community
involvement
activities
at
an
estimated
175
Federal­
lead
sites
is
also
discussed.

The
burden
data
in
this
section
are
based
on
estimates
by
EPA
personnel
knowledgeable
of
the
remedial
program's
record
keeping
and
reporting
requirements
and
the
costs
and
level
of
effort
required
to
meet
the
requirements.

Estimated
Unit
Burdens
to
State
Governments
A
"
unit"
burden
is
the
burden
incurred
by
a
respondent
for
performing
an
individual
sitespecific
activity.
States
incur
burdens
at:
(
1)
an
estimated
ten
new
state­
lead
sites
per
year
for
several
reporting
and
record
keeping
activities;
and
(
2)
all
of
the
estimated
40
NPL
sites
on
an
annual
basis
with
RI/
FS
starts
for
identifying
and
reporting
ARARs.
At
a
state­
lead
site,
states
incur
a
burden
for
the
following
activities:


Development
of
the
RI/
FS;


Development
of
the
Proposed
Plan;


Preparation
of
the
ROD;


Development
of
the
CIP
and
17

Providing
information
to
the
public.

The
estimated
average
burden
associated
with
each
activity
is
discussed
below
and
summarized
in
Exhibit
1.

The
estimated
burden
associated
with
the
RI/
FS
process
represents
the
number
of
hours
that
are
spent
conducting
the
data
collection
and
analysis
for
the
RI/
FS
and
for
preparing
the
RI/
FS
report.
The
RI/
FS
process
presently
takes
anywhere
from
18
to
36
months,
depending
on
the
complexity
of
the
site
and
the
scope
of
the
remedial
activities
being
considered.
It
is
estimated
that
the
RI/
FS
process
takes
an
average
of
33
months.
EPA
estimates
that
an
average
of
5,200
hours
per
year
are
necessary
for
a
three­
year
period
(
i.
e.,
a
total
of
15,600
hours)
to
complete
the
RI/
FS
process.
(
See
Row
1
of
Exhibit
1)
For
purposes
of
this
analysis,
it
is
assumed
that
these
hours
are
incurred
equally
over
the
three­
year
ICR
period.
The
distribution
of
hours
over
the
33­
month
period
may
vary,
and
a
burden
will
be
incurred,
on
average,
for
a
shorter
period
of
time
in
the
third
year.
However,
this
analysis
assumes
that,
in
any
given
year,
ten
state­
lead
sites
are
in
the
first
year
of
the
RI/
FS
process,
ten
in
the
second
year,
and
ten
in
the
third,
and
final,
year,
for
a
total
of
30
state­
lead
sites
in
the
RI/
FS
process
over
the
three
years
covered
by
this
ICR.
Therefore,
the
distribution
of
hours
over
the
33­
month
RI/
FS
period
will
not
affect
the
total
annual
burden
for
all
sites.
Because
the
RI/
FS
burden
is
averaged
over
a
three­
year
duration
of
the
activity,
the
unit
burden
shown
in
Exhibit
1
is
incurred
annually
at
the
30
sites
at
which
an
RI/
FS
is
being
conducted.

Other
activities
at
state­
lead
sites
are
incurred
during
a
one­
year
period
at
each
site,
and
therefore
are
only
performed
at
ten
new
sites
annually.
These
activities
include
preparing
the
Proposed
Plan,
developing
the
ROD,
preparing
the
initial
CIP,
revising
the
CIP,
preparing
an
engineering
design
fact
sheet,
and
establishing
information
repositories.

The
Agency
estimates
that
preparation
of
the
Proposed
Plan
and
related
activities,
including
the
newspaper
notification,
will
require
a
total
of
80
hours
per
site
per
year.
(
See
Row
2
of
Exhibit
1)
EPA
estimates
that
preparing
the
Proposed
Plan
itself
will
require
70
hours.
This
estimate
is
based
on
program
experience
in
preparing
fact
sheets
for
remedial
sites,
and
is
applicable
to
the
Proposed
Plan
because
it
may
be
released
in
fact
sheet
format.
The
Agency
estimates
that
ten
hours
will
be
necessary
to
prepare
the
newspaper
notification
on
the
Proposed
Plan
required
by
CERCLA.
This
estimate
is
based
on
program
experience
in
preparing
such
notifications.

EPA
estimates
that
it
will
require
360
hours
to
prepare
a
ROD
and
provide
public
notification.
(
See
Row
3
of
Exhibit
1)
Historical
program
experience
indicates
that
approximately
350
hours
are
devoted
to
preparing
a
ROD.
An
additional
ten
hours
are
estimated
to
be
necessary
for
preparing
the
newspaper
notification
of
the
ROD
required
by
statute.

EPA
estimates
that
an
average
of
150
hours
is
required
to
prepare
the
initial
CIP
and
150
hours
are
required
to
revise
it
later
in
the
remedial
process.
(
See
Rows
4
and
5
of
Exhibit
1)
These
estimates
are
based
on
program
experience.
The
estimate
includes
time
to
conduct
initial
background
reviews
of
the
site
and
community
activities,
plan
and
conduct
community
interviews,
prepare
for
and
attend
community
meetings
as
necessary,
and
prepare
the
initial
CIP
and
revised
CIP.
EPA
estimates
the
preparation
and
subsequent
revision
of
the
CIP
occurs
over
a
three­
year
period,
with
the
initial
CIP
prepared
during
the
first
year,
and
the
revised
CIP
prepared
during
the
third
year.
18
Other
community
involvement
activities
include
two
additional
requirements
for
providing
information
to
the
public:
(
1)
preparing
an
engineering
design
fact
sheet
and
(
2)
creating
information
repositories.
Preparation
of
the
engineering
design
fact
sheet
is
estimated
to
require
70
hours
of
time
per
site.
(
See
Row
6
of
Exhibit
1)
Based
on
program
experience,
EPA
estimates
that
40
hours
will
be
required
to
maintain
both
of
the
administrative
records
(
i.
e.,
one
record
at
the
site
and
one
at
the
lead
agency).
(
See
Row
8
of
Exhibit
1)
These
hours
include
time
necessary
to
determine
an
appropriate
location
for
the
on­
site
record,
to
identify,
reproduce
and
deposit
documents,
and
to
maintain
the
records.

States
incur
a
burden
at
all
Superfund
sites,
both
state­
lead
(
ten
per
year)
and
Federal­
lead
EXHIBIT
1
ESTIMATED
ANNUAL
BURDEN
AND
COST
TO
STATES
Activity
Unit
Burden
(
Hours)
Unit
Labor
Cost1
(
Dollars)
Other
Unit
Costs2
(
Dollars)
Total
Unit
Cost
(
Dollars)
Average
Number
of
Units
per
Year3
Total
Burden
(
Hours)
Total
Cost
(
Dollars)

RI/
FS
5,200
[
255,060]
[
50,231]
[
305,291]
30
156,000
[
9,158,730]

Proposed
plan
80
[
3,013]
[
1,552]
[
4,565]
10
800
[
45,650]

ROD
360
[
13,558]
[
463]
[
14,021]
10
3,600
[
140,210]

Initial
CIP
150
[
5,649]
0
[
5,649]
10
1,500
[
56,490]

Revised
CIP
150
[
5,649]
0
[
5,649]
10
1,500
[
56,490]

Participation
in
community
group
activities
112
[
4,230]
0
[
4,230]
10
1,120
[
4,724]

Participation
in
focus
groups
17
[
640]
0
[
640]
10
170
[
6,402]

Fact
sheets
70
[
2,636]
[
2,112]
[
4,748]
10
700
[
47,480]

Public
briefing
80
[
3,013]
[
371]
[
3,384]
10
800
[
33,840]

Information
repositories
40
[
1,506
]
[
1,256]
[
2,762]
10
400
[
27,620
ARARs
33
1,243
0
1,243
40
1,320
49,720
Subtotal
167,910
9,627,356
Reimbursement
from
Federal
Government
n/
a
[
9,577,636]

TOTAL
(
includes
record
keeping
activities)
167,910
49,720
[
]
Brackets
indicate
costs
that
are
reimbursed
by
the
Federal
government.
Because
the
costs
are
reimbursed,
they
are
not
incurred
by
the
State
government.
The
reimbursed
costs
are
indicated
here
to
help
determine
the
costs
incurred
by
the
federal
government
for
Site
activities
at
Statelead
sites.

(
30
per
year),
for
identification
of
state
ARARs.
EPA
estimates
that
site­
specific
determinations
of
potential
state
ARARs
will
require
33
hours
per
site.
(
See
Row
9
of
Exhibit
1)
19
For
purposes
of
this
analysis,
it
is
estimated
that
10
percent
of
the
total
burden
to
states
is
attributed
to
record
keeping
activities
and
90
percent
is
attributed
to
reporting
activities.

Estimated
Unit
Burdens
to
Community
Members
The
estimated
unit
burden
for
community
members
is
summarized
in
Exhibit
2.
As
discussed
above,
there
are
several
levels
of
activity
that
may
be
associated
with
community
involvement
at
a
Superfund
site.
For
all
Superfund
sites,
there
is
a
voluntary
burden
associated
with
initial
community
interviews,
review
of
and
comment
on
various
EPA
documents,
participation
in
focus
groups,
and
additional
community
interviews
associated
with
revisions
to
the
CIP.
These
activities
are
conducted
to
identify
major
community
concerns
and
to
provide
community
members
with
meaningful
opportunities
to
participate
in
decisions
that
affect
them.
The
burden
of
these
activities
is
the
same
for
both
state­
lead
and
Federal­
lead
sites.
The
burden,
which
is
voluntarily
accepted
by
community
members,
is
estimated
based
on
the
number
of
participants
and
the
estimated
number,
and
frequency,
of
the
community
activities
or
meetings:


Completion
of
written
questionnaires
regarding
community
involvement
effectiveness
at
specific
sites
 
15
minutes
each,
an
estimated
300
completed
questionnaires
for
a
total
burden
of
75
hours
per
site;


Initial
community
interviews
 
20
people
per
site
multiplied
by
2
hour
per
interview
for
a
total
burden
of
40
hours
per
site.


Community
interviews
for
revision
to
CIP
 
20
people
per
site
multiplied
by
2
hour
per
interview,
for
a
total
burden
of
40
hours.


Participation
in
focus
groups
 
15
people
per
site
multiplied
by
2
hours
per
group
session
for
a
total
burden
of
30
hours
per
participating
site.

This
results
in
a
total
annual
burden
to
community
members
for
most
Superfund
sites
ranging
from
155
(
75+
40+
40)
to
185
(
155+
30)
hours
of
citizen
time
per
year,
with
an
average
of
170
hours
(
155+
185/
2).
However,
for
certain
Superfund
sites,
there
is
an
additional
burden
associated
with
participation
in
formal
community
group
activities
(
e.
g.,
participation
in
Community
Advisory
Groups
(
CAGs)
or
in
obtaining
technical
assistance).
These
efforts
are
estimated
to
involve,
on
average,
20
people
per
meeting
multiplied
by
4
meetings
per
year
multiplied
by
2
hours
per
meeting
for
a
total
unit
burden
to
community
members
for
this
activity
of
160
hours.
Thus,
for
approximately
10
percent
of
Superfund
sites,
with
study,
design
or
construction
underway,
the
total
annual
burden
to
community
members
is
315
(
75+
40+
40+
160)
to
345
(
75+
40+
40+
160+
30)
hours
with
the
average
being
330
hours
(
315+
345/
2)
per
site.
20
EXHIBIT
2
ESTIMATED
ANNUAL
BURDEN
AND
COST
TO
COMMUNITY
MEMBERS
Activity
Unit
Burden
(
Hours)
Unit
Labor
Cost4
(
Dollars)
Other
Unit
Costs
(
Dollars)
Total
Unit
Cost
(
Dollars)
Average
Number
of
Units
per
Year5
Total
Burden
(
Hours)
Total
Cost6
(
Dollars)

Completion
of
questionnaires
75
2,825
0
2,825
10
750
28,250
Initial
community
interviews
40
1,506
0
1,506
40
1,600
60,256
Community
interviews
for
revision
to
CIP
40
1,506
0
1,506
80
3,200
120,480
Participation
in
focus
groups
30
1,130
0
1,130
40
1,200
45,200
Participation
in
community
group
activities
160
6,025
0
6,025
70
11,200
421,792
TOTAL
17,950
675,980
6(
b)
Respondent
Unit
Costs
A
"
unit"
cost
is
the
cost
incurred
by
a
respondent
in
performing
an
individual,
site­
specific
activity.
In
developing
estimates
of
the
costs
to
state
governments
and
to
respondents,
a
weighted
hourly
wage
rate
is
used.
This
wage
rate
reflects
the
assumption
that
the
total
number
of
hours
necessary
for
completing
any
of
the
record
keeping
or
reporting
activities
analyzed
here
are
divided
among
three
labor
categories
as
follows:
ten
percent
of
total
hours
are
allocated
to
managerial
staff
for
their
direction
of
and
review
of
activities;
80
percent
of
the
total
hours
are
allocated
to
technical
staff
for
conducting
the
majority
of
the
preparation
activities;
and
the
remaining
10
percent
of
the
total
labor
hours
are
allocated
to
support
staff
for
their
preparation
of
documents.

For
all
of
the
activities
covered
by
this
ICR
except
RI/
FS
activity,
wage
rates
for
state
government
personnel
are
estimated
to
be
comparable
to
those
for
Federal
government
personnel.
Labor
rates
for
government
workers
reflect
the
median
GS
level
salaries
for
managerial,
technical,
and
clerical
positions.
These
rates
include
direct
salary
and
fringe
benefits
(
calculated
at
60
percent
of
direct
salary).
The
hourly
rates,
as
of
January
2001,
are:

Management
(
GS
13,
Step
5)
$
49.82/
hour;
Technical
(
GS
11,
Step
5):
$
34.96/
hour;
and
Clerical
(
GS
7,
Step
5)
$
23.61/
hour.

Based
on
the
above,
the
weighted
hourly
wage
rate
for
state
and
Federal
personnel
is
$
37.66
[(
0.1)*($
49.82)
+
(
0.8)*($
34.96)
+
(
0.1)*($
23.61)]
dd
21
For
RI/
FS
activity,
a
higher
weighted
hourly
wage
is
used,
$
49.05.
The
basis
for
this
higher
rate
is
that
a
substantial
amount
of
RI/
FS
work
is
performed
by
contractual
labor
which
commands
a
higher
hourly
rate
reflecting
the
direct
labor,
labor
overhead,
other
direct
costs,
provisional
hourly
fees
and
other
fees.
The
weighted
hourly
wage
rate
for
RI/
FS
work
is
$
49.05
[(
0.1)*($
37.66)
state
oversight
+
(
0.9)*(
50.32)
average
hourly
contractual
rate].

For
purposes
of
this
analysis,
the
same
wage
rate
is
used
when
valuing
the
time
of
community
members
who
participate
in
community
outreach
activities.

The
annual
unit
cost
of
labor
for
each
activity
is
presented
in
Exhibits
1
and
2.
The
labor
unit
cost
of
any
activity
for
state
governments
or
community
members
is
determined
by
multiplying
the
unit
burden
estimate
by
the
appropriate
wage
rates.
For
example,
it
is
estimated
that
a
state
will
incur
an
average
burden
of
5,200
hours
annually
at
a
state­
lead
site
for
development
of
the
RI/
FS.
Therefore,
the
annual
labor
cost
of
preparing
the
RI/
FS
is
$
255,060
[(
5,200
hours)*($
49.05)].

Many
activities
include
costs
other
than
labor
costs.
These
other
costs
are
displayed
in
Column
3
of
Exhibit
1.
EPA
estimates
that
the
following
capital
and
other
costs
are
necessary
to
complete
each
activity:


$
150,695
to
develop
the
RI/
FS,
at
an
average
annual
cost
of
$
50,231
(
includes
the
cost
of
equipment
purchased
to
conduct
site
work,
such
as
drill
casings,
and
the
cost
of
sampling
and
analysis);


$
1,552
to
prepare
the
Proposed
Plan
(
includes
costs
specific
to
printing,
distribution,
and
purchasing
newspaper
advertising
space);


$
463
to
develop
a
ROD
(
includes
the
costs
of
producing
and
printing
documents
and
purchasing
newspaper
advertising
space);


$
2,112
to
prepare
fact
sheets
describing
the
final
engineering
design
(
includes
the
costs
of
printing
and
distributing
the
document);
and

$
1,256
to
establish
information
repositories
(
for
copying
and
obtaining
storage
space).

The
total
unit
cost
is
determined
by
adding
the
unit
labor
cost
to
the
unit
capital
cost.
For
example,
the
total
unit
cost
to
develop
the
RI/
FS
is
$
305,291
[($
255,060)
in
labor
costs)
+
($
50,231
in
annual
capital
and­
other
costs)].

Although
states
conduct
the
activities
at
state­
lead
sites,
they
are
reimbursed
by
the
Federal
government
for
certain
activities
and,
therefore,
do
not
incur
any
costs
for
these
activities
at
these
sites.
However,
the
Federal
government
will
incur
the
costs
of
state
activities,
and
these
costs
are
analyzed
later
in
this
ICR.
Consequently,
the
estimated
costs
of
state
activities
are
included
in
brackets
in
Exhibit
1
in
order
to
establish
the
basis
for
determining
the
cost
to
the
Federal
government
in
the
next
section
of
this
ICR.

It
is
estimated
that
identification
of
ARARs
by
a
state
at
any
Superfund
site,
which
is
not
reimbursed
by
the
Federal
government,
costs
a
state
$
1,243
per
site.
The
cost
of
identifying
state
ARARs
represents
labor
costs
only,
it
does
not
include
any
capital
or
other
costs.

The
estimated
cost
for
community
member
participation
in
a
combination
of
activities
relating
to
a
remedial
decision
at
a
Superfund
site
is
$
7,043
per
site
for
most
sites
($
2,825
for
answering
written
questionnaires;
$
1,544
for
initial
community
interviews;
and
$
1,544
for
22
interviews
associated
with
revisions
to
the
CIP;
$
1,130
for
participation
in
focus
groups);
and
$
11,900
for
those
sites
where
a
community
group
is
formed
(
including
$
4,857
for
participation
in
community
group
activities).
Community
members
are
not
expected
to
incur
any
capital
or
other
costs
to
participate
in
community
activities.
The
unit
costs
for
the
community
member
activities
are
presented
in
Exhibit
2.

6(
c)
Estimated
Agency
Unit
Burdens
and
Costs
This
section
estimates
the
unit
burdens
and
costs
to
the
Federal
government
for
overseeing
the
NCP
reporting
and
record
keeping
activities.
The
annual
costs
to
the
Federal
government
estimated
here
are
the
costs
of
obtaining,
reviewing,
and
maintaining
the
information
gathered
from
states
when
they
have
the
lead
in
conducting
Fund­
financed
remedial
activities
or
are
fulfilling
other
reporting
or
record
keeping
requirements
under
the
NCP.
Specifically,
the
Agency
incurs
costs
associated
with:
(
1)
conducting
community
involvement
activities
at
Federallead
sites;
(
2)
overseeing
states'
remedial
activities
at
state­
lead
sites;
and
(
3)
reviewing
ARARs
at
all
NPL
sites
with
RI/
FS
starts.

The
unit
burdens
and
costs
for
the
Agency
are
presented
in
Exhibits
3
and
4.
Exhibit
3
presents
the
unit
burden
and
costs
associated
with
conducting
community
involvement
activities
at
Federal­
lead
sites.
As
for
the
burden
to
community
members,
the
burden
to
the
Federal
government
is
estimated
based
on
the
number
of
EPA
participants
and
the
estimated
number,
and
frequency,
of
the
community
activities
or
meetings:


Preparation
and
analysis
of
written
questionnaires
 
requiring
an
estimated
800
surveys
to
receive
300
completed
questionnaires:
800
mailings
prepared
(
i.
e.,
folded
and
placed
in
envelopes)
@
1
min
each
(
13
hours)
plus
40
hours
to
compile
and
analyze
data
and
prepare
reports
for
a
total
of
53
hours.


Initial
community
interviews
­
20
interviews
per
site
multiplied
by
2
EPA/
contractor
personnel
multiplied
by
2
hour
per
interview
(
80
hours)
plus
1
hour
of
preparation/
follow
up
time
per
EPA/
contractor
personnel
per
interview
(
40
hours)
for
a
total
burden
of
120
hours
per
site.


Community
interviews
for
revision
to
CIP­
20
completed
interviews
per
site
multiplied
by
2
EPA/
contractor
personnel
multiplied
by
2
hour
per
interview
and
one
hour
for
preparation
for
a
total
burden
of
120
hours.


Participation
in
focus
groups
 
5
hours
for
preparation
+
12
hours
(
2
people
multiplied
by
2
hours
per
session
multiplied
by
3
sessions)
for
a
total
of
17
hours.

These
activities
result
in
a
total
annual
burden
for
community
activities
at
most
Federallead
sites
of
310
hours
(
120+
53+
120+
17)
per
year
per
site.
For
those
Federal­
lead
sites
with
formal
community
group
activities,
however,
the
total
annual
burden
per
site
is
estimated
to
be
422
hours
(
310+
112).
The
additional
burden
associated
with
participating
in
community
group
activities
is
based
on
the
expectation
that,
on
average,
2
Federal
personnel
attend
4
activities
per
year
each
requiring
4
hours
(
i.
e.,
2
hours
of
meeting
time
and
2
hours
of
preparation
time).
In
addition,
the
4
meetings
are
estimated
to
require
an
additional
20
hours
of
planning
time
each.
This
results
in
an
additional
burden
of
112
hours
per
site
for
those
Federal­
lead
sites
with
formal
community
group
activities.
23
EXHIBIT
3
ESTIMATED
ANNUAL
BURDEN
AND
COST
TO
FEDERAL
GOVERNMENT
FOR
COMMUNITY
INVOLVEMENT
ACTIVITIES
AT
FEDERAL­
LEAD
SITES
Activity
Unit
Burden
(
Hours)
Unit
Labor
Cost7
(
Dollars)
Other
Unit
Costs
(
Dollars)
Total
Unit
Cost
(
Dollars)
Average
Number
of
Units
per
Year8
Total
Burden
(
Hours)
Total
Cost9
(
Dollars)

Preparation
and
analysis
of
written
questionnaires
53
2,000
0
2,000
10
530
20,000
Initial
community
interviews
120
4,519
0
4,519
40
3,600
135,576
Community
interviews
for
revision
of
CIP
120
3,013
0
3,013
80
6,400
241,040
Participation
in
focus
groups
17
640
0
640
40
1,360
51,218
Participation
in
community
group
activities
112
4,217
0
4,217
70
7,840
295,254
TOTAL
19,730
743,032
Unit
costs
are
arrived
at
by
multiplying
the
unit
burden
estimate
by
the
weighted
wage
rate
of
$
37.66/
hour.
The
total
unit
cost
to
the
Federal
government
of
conducting
community
activities
is
$
9,151
for
most
sites
($
4,519
for
initial
community
interviews;
$
979
for
telephone
interviews
of
fact
sheet
recipients;
$
640
for
participation
in
focus
groups
and
$
3,013
for
interviews
associated
with
revisions
to
the
CIP
and
$
13,369
for
those
sites
where
a
community
group
is
formed
(
including
$
4,218
for
participation
in
community
group
activities).

Exhibit
4
presents
the
unit
burden
and
cost
to
the
Federal
government
associated
with
Federal
oversight
of
state­
lead
sites
and
with
review
of
state
ARAR
determinations.
Federal
oversight
of
state
activities
is
assumed
to
require
10
percent
of
the
total
annual
burden
hours
for
states
to
perform
each
activity.
Therefore,
the
unit
burdens
are
determined
by
multiplying
the
state
burdens
for
each
activity
by
a
factor
of
10
percent.
Unit
costs
are
determined
by
multiplying
the
unit
burdens
by
the
weighted
wage
rate
of
$
37.66/
hour.
For
example,
it
is
estimated
that
a
state
government
will
spend
an
average
of
5,200
hours
annually
to
conduct
the
RI/
FS
at
a
state­­
lead
site.
The
Agency,
therefore,
is
estimated
to
spend
an
average
of
520
hours
[(
5,200
hours)*(
0.1)]
overseeing
the
state's
RI/
FS
process
and
reports
at
an
average
annual
cost
of
$
19,583
per
site
[(
520
hours)*($
37.66/
hour)].
24
EXHIBIT
4
ESTIMATED
ANNUAL
BURDEN
AND
COST
TO
FEDERAL
GOVERNMENT
FOR
OVERSIGHT
OF
STATE­
LEAD
SITES
Activity
Unit
Burden10
(
Hours)
Unit
Labor
Cost11
(
Dollars)
Other
Unit
Costs
(
Dollars)
Total
Unit
Cost
(
Dollars)
Average
Number
of
Units
per
Year12
Reimbursement
Cost
(
Dollars)
Total
Burden
(
Hours)
Total
Cost13
(
Dollars)

Federal
oversight
of
Activities
at
State­
Lead
Sites
RI/
FS
520
19,583
0
19,583
30
9,158,730
15,600
9,746,226
Proposed
plan
8
301
0
301
10
45,650
80
48,663
ROD
36
1,356
0
1,356
10
140,210
360
153,768
Initial
CIP
15
565
0
565
10
56,490
150
32,259
Revised
CIP
15
565
0
565
10
56,490
150
32,259
Participation
in
community
group
activities
11
414
0
414
10
4,140
110
4,142
Participation
in
focus
groups
2
75
0
75
10
750
20
753
Fact
sheets
7
264
0
264
10
47,480
70
50,116
Information
repositories
4
151
0
151
10
27,620
40
29,126
Review
of
State
ARARs
Determination
3
113
0
113
40
0
120
4,520
Community
Activities
at
Federal­
lead
Sites
0
19,730
743,032
TOTAL
9,537,560
36,430
10,844,864
25
6(
d)
Total
Burden
for
Respondents
and
the
Agency
Total
Estimated
Burden
and
Cost
to
State
Governments
The
total
estimated
burden
and
cost
to
state
governments
for
reporting
and
record
keeping
activities
at
all
applicable
sites
depend
on
the
number
of
such
activities
that
are
performed
annually.
The
burden
estimated
here
is
based
on
the
assumption
that
the
new
average
of
six
statelead
RI/
FS
starts
each
year
will
be
maintained
over
the
period
of
this
ICR.
Furthermore,
because
this
ICR
is
a
renewal
of
a
previously
estimated
burden,
it
is
further
assumed
that
several
state­
lead
RI/
FSs
are
already
in
process
as
of
the
start
of
this
ICR
period
(
i.
e.,
some
RI/
FSs
are
in
their
second
year
and
others
in
their
third
and
final
year).
Thus,
as
discussed
above,
for
each
year
of
this
ICR,
it
is
estimated
that
there
are
30
state­
lead
sites
that
are
in
the
RI/
FS
stage:
ten
state­
lead
starts,
ten
sites
where
RI/
FS
activities
are
in
their
second
year,
and
ten
sites
where
RI/
FS
activities
are
in
their
third
and
final
year.
Because
the
RI/
FS
burden
is
averaged
over
a
three­
year
duration
of
the
activity,
the
unit
burden
shown
in
Exhibit
1
is
incurred
annually
at
the
30
sites
at
which
an
RI/
FS
is
being
conducted.
As
mentioned
above,
other
activities
at
state­
lead
sites
are
incurred
during
a
one­
year
period
at
each
site,
and
therefore
are
only
performed
at
ten
sites
annually.
These
activities
include
preparing
the
Proposed
Plan,
developing
the
ROD,
preparing
the
initial
CIP,
revising
the
CIP,
preparing
an
engineering
design
fact
sheet,
and
establishing
information
repositories.

The
total
estimated
burden
to
state
governments
is
determined
by
multiplying
the
unit
burden
estimate,
(
shown
in
Exhibit
1)
by
the
number
of
units
(
i.
e.,
the
number
of
times
an
activity
is
performed
each
year).
For
example,
the
annual
unit
burden
for
a
state
to
develop
an
RI/
FS
is
5,200
hours.
As
discussed
above,
it
is
estimated
that
states
are
developing
an
RI/
FS
at
30
sites
during
any
given
year.
Consequently,
the
total
annual
burden
to
all
states
for
the
RI/
FS
process
is
156,000
hours
[(
5,200
hours/
site)*(
30
sites)].
For
purposes
of
this
analysis,
it
is
estimated
that
10
percent
of
the
total
burden
is
attributed
to
record
keeping
activities
and
90
percent
is
attributed
to
reporting
activities.

The
total
estimated
cost
to
state
governments
is
determined
by
multiplying
the
total
unit
cost
estimate
(
shown
in
Exhibit
1)
by
the
number
of
units.
The
only
cost
that
is
incurred
by
a
state
is
identification
of
ARARs
because
that
cost
is
not
reimbursed
by
the
Federal
government.
However,
the
estimated
total
costs
of
reimbursable
state
activities
are
included
in
brackets
in
Exhibit
1
in
order
to
establish
the
basis
for
determining
the
cost
to
the
Federal
government.
For
example,
the
total
unit
cost
for
a
state
to
develop
an
RI/
FS
is
estimated
to
be
$
305,291.
As
discussed
above,
it
is
estimated
that
states
are
developing
an
RI/
FS
at
30
sites
during
any
given
year.
Consequently,
the
total
annual
cost
to
all
states
for
the
RI/
FS
process
is
$
9,158,730
[($
305,291/
site)*(
30
sites)].
This
amount
is
an
estimate
that
must
be
annually
reimbursed
to
state
governments
from
the
Fund
for
RI/
FS
activities.
This
cost
is
included
as
a
cost
to
the
Federal
government
in
Exhibit
4.

The
total
annual
cost
to
all
states
for
identifying
state
ARARs
at
40
sites
is
estimated
to
be
$
49,711
[($
37.66/
hour)*(
33
hours/
site)*(
40
sites)].

Total
Estimated
Burden
and
Cost
to
Community
Members
The
total
estimated
burden
and
cost
to
community
members
for
reporting
activities
(
i.
e.,
participating
in
interviews,
formal
community
groups,
and
the
phone
interviews
and
focus
groups
26
associated
with
site­
specific
program
evaluation
efforts)
depend
on
the
number
of
such
activities
that
are
performed
annually.
There
are
no
record
keeping
activities
for
community
members.

The
total
burden
and
cost
to
community
members
are
shown
in
Exhibit
2.
As
discussed
above,
EPA
estimates
that
initial
community
interviews
take
place
at
40
sites,
interviews
associated
with
revisions
to
the
CIP
take
place
at
all
80
sites
and
activities
associated
with
participation
in
community
groups
occur
at
70
sites.
These
figures
include
an
assumption
that
the
site­
specific
feedback
activities
of
telephone
interviews
and
focus
groups
will
take
place
at
up
to
10
sites.
The
total
annual
burden
to
community
members
is
estimated
to
be
1,600
hours
for
initial
interviews;
3,200
hours
for
interviews
associated
with
revisions
to
the
CIP;
and
11,200
hours
for
activities
associated
with
participation
in
community
groups.
The
total
annual
cost
to
community
members
is
$
60,256
for
participating
in
initial
interviews,
$
120,480
for
interviews
associated
with
revisions
to
the
CIP,
and
$
421,792
for
activities
associated
with
participation
in
community
groups,
$
28,250
to
complete
the
written
questionnaires,
and
$
45,200
to
participate
in
the
focus
groups.
The
total
annual
cost
to
the
community
for
all
activities
at
Superfund
sites
is
$
675,980.
It
must
be
noted
that
these
costs
are
an
attempt
to
value
private
citizens'
time;
since
private
citizens
participate
voluntarily
during
their
free
time,
time
costs
are
the
only
costs
incurred;
there
are
no
out­
of­
pocket
expenses
for
citizens.

Total
Estimated
Burden
and
Cost
to
the
Federal
Government
The
total
annual
burden
and
cost
to
the
Federal
government
are
presented
in
Exhibits
3
and
4.
The
Federal
government
incurs
costs
not
only
for
its
labor
in
conducting
community
involvement
at
Federal­
lead
sites,
providing
oversight
at
state­
lead
sites,
and
reviewing
state
ARARS,
but
also
for
reimbursing
state
governments
for
their
activities
at
state­
lead
sites
(
the
reimbursement
costs
are
derived
in
Exhibit
1
under
the
costs
to
state
governments).
Total
annual
burdens
and
costs
are
determined
by
multiplying
the
unit
burdens
and
costs
by
the
number
of
units
performed
each
year.
As
shown
in
Exhibit
3,
the
total
annual
burden
and
cost
to
the
Federal
government
for
community
activities
at
Federal­
lead
sites
are
19,730
hours
and
$
743,032
respectively.

Exhibit
4
shows
the
total
burden
and
total
cost
estimates
for
Federal
oversight
activities.
and
review
of
State
ARARs.
Because
EPA
is
providing
oversight
for
state­
lead
actions,
the
number
of
units
is
identical
to
the
number
of
units
performed
by
the
states.
The
total
annual
burden
to
the
Agency
for
oversight
activities
and
review
of
state
ARARs
is
16,700
hours.
The
total
annual
cost
to
the
Agency
for
this
oversight
is
$
628,922
[(
16,700
hours)
*
($
37.66/
hours)].
The
total
annual
cost
to
the
Fund
for
reimbursing
state
governments
is
estimated
to
be
$
9,577,636.

The
total
annual
burden
and
cost
to
the
Federal
government
for
conducting
community
involvement
at
Federal­
lead
sites
($
743,032),
oversight
at
state­
lead
sites
($
10,097,312),
review
of
state
ARARs
($
4,520),
and
reimbursing
state
governments
for
their
activities
at
state­
lead
sites
($
9,577,636)
are
$
20,422,500.
27
Total
Estimated
Burden
and
Cost
to
All
Respondents
and
the
Federal
Government
The
estimated
total
annual
burden
and
cost
to
all
respondents
are
presented
in
Exhibit
5.
The
total
burden
to
all
respondents
over
the
three­
year
ICR
period
is
557,580
hours.
The
total
cost
to
all
respondents
over
the
three­
year
ICR
period
is
$
2,177,100.

EXHIBIT
5
TOTAL
ANNUAL
COST
AND
BURDEN
Respondents
Cost
Burden
(
Hours)

States
$
49,720
167,910
Community
Members
$
675,980
17,950
Total
$
725,700
185,860
Federal
Government
$
20,422,500
36,430
6(
e)
Reasons
for
the
Change
in
Burden
The
estimated
annual
to
respondents
(
i.
e.,
state
governments
and
community
members)
increased
by
72,370
hours
from
the
previous
ICR
(
from
113,490
hours
to
185,860
hours).
This
increase
is
primarily
attributable
to
the
increase
in
the
number
of
sites
to
be
added
to
the
NPL
over
the
three­
year
period
of
this
ICR
as
compared
to
the
number
of
NPL
sites
covered
by
the
previous
ICR
and
revisions
to
the
community
involvement
estimates
based
on
an
update
of
the
activities
conducted
and
the
burden
imposed
by
those
activities.

6(
f)
Burden
Statement
The
average
public
reporting
burden
for
a
state
government
that
has
the
lead
at
a
Superfund
site
is
estimated
to
be
5,474
hours
per
site.
This
reporting
burden
includes
the
time
required
to
review
instructions,
search
existing
data
sources,
gather
and
maintain
the
data
needed,
estimate
the
information
required,
and
complete
and
review
the
collection
of
information.
The
average
record
keeping
burden
for
a
state
government
that
has
the
lead
at
a
Superfund
site
is
estimated
to
be
609
hours
per
site.

The
average
public
reporting
burden
for
community
members
is
estimated
to
range
from,
155
hours
to
345
hours,
with
an
average
burden
of
250
hours
per
site.
This
reporting
burden
includes
time
required
to
participate
in
community
group
activities
and
participate
in
community
interviews.
There
is
no
record
keeping
burden
for
community
members.

An
announcement
was
published
in
the
Federal
Register
on
March
9,
2001,
informing
the
public
that
EPA
was
planning
to
seek
renewal
of
this
ICR
from
the
Office
of
Management
and
Budget.
The
announcement
solicited
comments
on
specific
aspects
of
the
proposed
information
collection;
EPA
received
no
comments
from
the
public.

These
reporting
and
record
keeping
burden
estimates
are
based
on
the
average
burden
for
28
1.
Labor
costs
for
all
activities
except
RI/
FS
are
based
on
a
weighted
hourly
wage
rate
of
$
37.66.
The
labor
rate
for
RI/
FS
activity
is
a
weighted
hourly
wage
rate
of
$
49.05.
This
higher
rate
reflects
the
cost
of
contractual
labor
and
state
oversight
costs.
(
See
p.
20.)

2.
Other
costs
may
include
capital
costs
and
other
direct
costs
such
as:
equipment
purchased
to
conduct
site
work,
printing,
copying,
storage
space,
and
newspaper
advertising
space.

3.
The
average
number
of
units
represents
the
number
of
times
an
activity
is
performed
by
state
governments
each
year.
The
annual
estimate
used
in
this
analysis
is
an
average
number
for
the
three­
year
ICR
period
and
may
not
represent
the
actual
distribution
of
activities
over
the
three­
year
period.
In
this
analysis,
it
is
assumed
that,
for
any
given
year,
ten
State­
lead
sites
will
be
in
the
first
year
of
the
RI/
FS
process,
ten
will
be
in
the
second
year,
and
ten
will
be
in
the
final
year,
for
a
total
of
30
sites
per
year.

4.
Labor
costs
are
based
on
a
weighted
hourly
wage
rate
of
$
37.66.
(
See
p.
20.)

5.
The
average
number
of
units
represents
the
number
of
sites
at
which
an
activity
is
performed
by
community
members
each
year.
The
annual
estimate
used
in
this
analysis
is
an
average
number
for
the
three­
year
ICR
period
and
may
not
represent
the
actual
distribution
of
activities
over
the
three­
year
period.

6.
Totals
may
not
add
exactly
due
to
rounding.

7.
Labor
costs
are
based
on
a
weighted
hourly
wage
rate
of
$
37.66.
(
See
p.
20.)

8.
The
average
number
of
units
represents
the
number
of
times
an
activity
is
performed
by
community
members
each
year.
The
annual
estimate
used
in
this
analysis
is
an
average
number
for
the
three­
year
ICR
period
and
may
not
represent
the
actual
distribution
of
activities
over
the
three­
year
periods.

9.
Totals
may
not
add
exactly
due
to
rounding.

10.
Unit
burden
estimates
for
each
activity
are
based
on
an
annual
average
burden.
Some
activities
are
performed
over
a
period
of
greater
than
one
year
and
the
burdens
associated
with
such
activities
are
not
necessarily
uniform
over
the
duration
of
the
activity.

11.
Labor
costs
are
based
on
a
weighted
hourly
wage
of
$
37.66.
(
See
p.
20.)

12.
The
average
number
of
units
represents
the
number
of
times
an
activity
is
performed
by
the
Agency
each
year.
The
annual
estimate
used
in
this
analysis
is
an
average
number
for
the
three­
year
ICR
period
and
may
not
represent
the
actual
distribution
of
activities
over
the
three­
year
period.

13.
Total
may
not
add
exactly
due
to
rounding.
the
3­
year
period
covered
by
this
ICR.
Send
comments
regarding
this
collection
of
information,
including
suggestions
for
reducing
the
burden,
to:
Director,
Collection
Strategies
Division,
U.
S.
Environmental
Protection
Agency
(
2822),
1200
Pennsylvania
Ave.,
NW,
Washington,
D.
C.
20460.
Include
the
OMB
control
number
in
any
correspondence.

End
Notes
