                                 ATTACHMENT A

                         Part A  -  Consultation Notes

1. Keitu Response
 The interviewee indicated that her firm provides engineering or technical support to facilities subject to SPCC regulation.
 The interviewee is a managing director/senior project engineer at Keitu.
 The interviewee did not need to be reminded of what the SPCC regulation was.
 The interviewee works on about 100 SPCC Plans per year.
 Keitu develops and certifies plans for all types of facilities. About 90 percent of plans are for oil production pads. Most amendments are due to adding to plans for oil production facilities. For storage facilities with over a million gallons, they work on about one per year. Keitu has also worked on plans for asphalt terminals, pipeline terminals, wind farms, electric co-ops, manufacturing, tractors, rail ports for crude oil, and farms.
 Keitu prices about 90 percent of their plans on a fixed price structure because the work is repetitive. For plans for very large facilities, they price by T&M (time and materials).
 STORAGE FACILITIES -  Hours estimates provided by EPA were mostly higher than what Keitu provided.
 The interviewee had prepared a new Plan for a new facility.
 See Table 2 for total hours estimates.
 See Table 2 for hours estimates by labor category.
            
Table 2: Hours for preparation of new SPCC Plan for new facilities



                                  Management
                                   Technical
                                    Drafter
                                   Clerical 
                                     Total
Storage
Category I
             2
No estimate  
No estimate      
                                          2
                                        24

Category II
             2
No estimate   
No estimate    
                                          2
                                        24

Category III
             2
No estimate 
No estimate      
                                          2
                                       60

Category IV
                                      12
                                      135
                                         40 
                                         20
                                      207 

 The interviewee had prepared technical amendments to an existing SPCC Plan.
 See Table 3 for total hours estimates.
 In general, EPA's number of hours were high.
            
Table 3: Hours for Plan amendment for new and existing facilities

 
 
                                  Management
                                   Technical
                                    Drafter
                                   Clerical
                                     Total
Storage
Category I
                               No estimate     
                                 No estimate  
                                          -   
                                 No estimate  
                                     12-14

Category II
                                No estimate    
                                 No estimate  
                                          -   
                                 No estimate 
                                     12-14

Category III
                                 No estimate  
                                 No estimate  
                                          -   
                                 No estimate  
                                      20

Category IV
                                 No estimate  
                                 No estimate  
                                          -   
                                 No estimate  
                                      24

 The interviewee had prepared a five-year review of an existing Plan.
 See Table 4 for total hours estimates.
 No hours estimates provided for labor categories.




Table 4: Hours for five-year review for existing Plan

 
 
                                  Management
                                   Technical
                                    Drafter
                                   Clerical
                                     Total
Storage
Category I
                               No estimate     
                                 No estimate  
                                          -   
                                  No estimate
                                        4

Category II
                                No estimate    
                                 No estimate  
                                          -   
                                 No estimate 
                                        4

Category III
                                 No estimate  
                                 No estimate  
                                          -   
                                 No estimate  
                                        4

Category IV
                                 No estimate  
                                 No estimate  
                                          -   
                                 No estimate  
                                        4
            
 The interviewee had developed a SPCC facility diagram.
 See Table 5 for total hours estimates.
 See Table 5 for hours estimates by labor category.
            
Table 5: Hours for creating facility diagram


 
                              Annual Hours Burden
                                       

                                  Management
                                   Technical
                                    Drafter
                                   Clerical
                                     Total
Storage
Category I
                                       1
                                       4
                                       4
                                                                           -   
                                       9

Category II
                                       1
                                       4
                                       4
                                                                           -   
                                       9

Category III
                                       1
                                       8
                                      12
                                                                           -   
                                      21

Category IV
                                       1
                                       8
                                      20
                                                                           -   
                                      29

 PRODUCTION FACILITIES -  Hours estimates provided by EPA were mostly higher than what Keitu provided.
 The interviewee had prepared a Plan for a new facility.
 See Table 6 for total hours estimates.
 See Table 6 for hours estimates by labor category.
            
Table 6: Hours for preparation of new Plan for new facilities



                                  Management
                                   Technical
                                    Drafter
                                   Clerical
                                     Total
Production
Category I
No estimate
                                  No estimate
No estimate
No estimate
                                  No estimate

Category II
             3 
                                      16
                                         15 
                                       2
                                      36

Category III
             5 
                                      16
                                         30 
                                       2
                                      53

Category IV
             8 
                                      40
                                         45 
                                       4
                                      97

 The interviewee had prepared technical amendments to an existing SPCC Plan.
 See Table 7 for total hours estimates.
 Same number of hours as for storage facility
            
            
            
            
            
Table 7: Hours for Plan amendment for new and existing facilities

 
 
                                  Management
                                   Technical
                                    Drafter
                                   Clerical
                                     Total
Production
Category I
                               No estimate     
                                 No estimate  
                                          -   
                                 No estimate  
                                     12-14

Category II
                                No estimate    
                                 No estimate  
                                          -   
                                 No estimate 
                                     12-14

Category III
                                 No estimate  
                                 No estimate  
                                          -   
                                 No estimate  
                                      20

Category IV
                                 No estimate  
                                 No estimate  
                                          -   
                                 No estimate  
                                      24

 The interviewee had prepared a five-year review of an existing Plan
 See Table 8 for total hours estimates.
 Same number of hours as for storage facility
            
Table 8: Hours for five-year review for existing Plan

 
 
                                  Management
                                   Technical
                                    Drafter
                                   Clerical
                                     Total
Production
Category I
                               No estimate     
                                 No estimate  
                                          -   
                                  No estimate
                                        4

Category II
                                No estimate    
                                 No estimate  
                                          -   
                                 No estimate 
                                        4

Category III
                                 No estimate  
                                 No estimate  
                                          -   
                                 No estimate  
                                        4

Category IV
                                 No estimate  
                                 No estimate  
                                          -   
                                 No estimate  
                                        4
            
 The interviewee had developed a SPCC facility diagram.
 See Table 9 for total hours estimates.
 See Table 9 for hours estimates by labor category. Management hours same as for storage facilities.
            
Table 9: Hours for creating facility diagram


 
                              Annual Hours Burden
                                       

                                  Management
                                   Technical
                                    Drafter
                                   Clerical
                                     Total
Production
Category I
                                                               No estimate     
                                                               No estimate     
                                                               No estimate     
                                                                           -   
                               No estimate     

Category II
                                       1
                                       4
                                       8
                                                                           -   
                                      13

Category III
                                       1
                                       4
                                       8
                                                                           -   
                                      13

Category IV
                                       1
                                       8
                                      40
                                                                           -   
                                      49

2.  RSB Environmental Response
 The interviewee indicated that his firm provides engineering or technical support to facilities subject to SPCC regulation.
 The interviewee is a Project Manager at RSB Environmental.
 The interviewee did not need to be reminded of what the SPCC regulation was.
 The interviewee has worked on more than 200 SPCC Plans over the last five years.
 The interviewee has worked on a variety of facilities except for oil production. He has worked on distribution facilities, farms, small to mid-size manufacturing facilities. The maximum size facility he has worked on was a quarter million gallons.
 RSB Environmental prices most of its SPCC services by fixed price. For some large facilities, they price by T&M.
 STORAGE FACILITIES -  Hours estimates provided by EPA were mostly higher than what RSB Environmental provided.
 The interviewee had prepared a new Plan for a new facility.
 See Table 2 for total hours estimates.
 About 30-50% of time goes to report preparation for technical, drafter, and clerical. The interviewee has worked on only a few Category IV projects.
         
Table 2: Hours for preparation of new SPCC Plan for new facilities



                                  Management
                                   Technical
                                    Drafter
                                   Clerical
                                     Total
Storage
Category I
                           50-70% of total          
                                30-50% of total
                                      40

Category II
                           50-70% of total          
                                30-50% of total
                                       40

Category III
                           50-70% of total          
                                30-50% of total
                                     60-80

Category IV
                           50-70% of total          
                                30-50% of total
                                      120
         
 The interviewee had prepared technical amendments to an existing SPCC Plan.
 See Table 3 for total hours estimates.
 About 50-60% of time goes to management and technical.
            
Table 3: Hours for Plan amendment for new and existing facilities

 
 
                                  Management
                                   Technical
                                    Drafter
                                   Clerical
                                     Total
Storage
Category I
                           50-60% of total          
                                          -   
    40-50% of total     
                                      20 

Category II
                           50-60% of total          
                                          -   
    40-50% of total     
                                      30

Category III
                           50-60% of total          
                                          -   
    40-50% of total            
                                      59

Category IV
                           50-60% of total          
                                          -   
    40-50% of total            
                                      88

 The interviewee had prepared a five-year review of an existing Plan
 See Table 4 for total hours estimates. E 
 About 50-60% of hours goes to management and technical.





Table 4: Hours for five-year review for existing Plan

 
 
                                  Management
                                   Technical
                                    Drafter
                                   Clerical
                                     Total
Storage
Category I
                           50-60% of total          
                                          -   
                                40-50% of total
                                      10-15

Category II
                           50-60% of total          
                                          -   
                                40-50% of total
                                      10-15

Category III
                           50-60% of total          
                                          -   
                                40-50% of total
                                      15-20

Category IV
                           50-60% of total          
                                          -   
                                40-50% of total
                                      20-25
            
 The interviewee had developed a SPCC facility diagram.
 See Table 5 for total hours estimates.
 About 70-80% of hours go to technical and drafter, 10-20% for management and clerical.
            
Table 5: Hours for creating facility diagram


 
                              Annual Hours Burden
                                       

                                  Management
                                   Technical
                                    Drafter
                                   Clerical
                                     Total
Storage
Category I
                                                          20% or less of total 
                                70-80% of total
                                                           20% or less of total
                                     12-15

Category II
                                                           20% or less of total
                                70-80% of total
                                                        20% or less of total   
                                      25

Category III
                                                          20% or less of total 
                                70-80% of total
                                                        20% or less of total   
                                     25-30

Category IV
                                                          20% or less of total 
                                70-80% of total
                                                        20% or less of total   
                                     25-30

 The interviewee had not worked on any production facilities.

3.  InterSpec Response
 The interviewee indicated that his firm provides engineering or technical support to facilities subject to SPCC regulation.
 The interviewee is president and owner of InterSpec.
 The interviewee did not need to be reminded of what the SPCC regulation was.
 In the last year, the interview had worked on five SPCC Plans. He had reviewed well over 100 plans in the past five years because when the firm does inspections, they often find that the facility is not in compliance with federal code.
 The types of facilities InterSpec develops SPCC Plans for include oil storage and distribution facilities, oil production facilities, manufacturing facilities, and animal fat and vegetable oil facilities.
 InterSpec prices SPCC Plan development as fixed price.
 STORAGE FACILITIES - Hours estimates provided by EPA were higher or the same as what Interspec provided.
 The interviewee had prepared a new Plan for a new facility.
 The total number of hours required to prepare a new Plan are 38 (Category I), 60 (Category II), 124 (Category III), and 156 (Category IV).
 See Table 2 for total hours estimates by labor category.




Table 2: Hours for preparation of new SPCC Plan for new facilities



                                  Management
                                   Technical
                                    Drafter
                                   Clerical
                                     Total
Storage
Category I
                                             2 
                                         24
                                          8
                                           4 
                                       38 

Category II
                                             4 
                                         32
                                         16
                                           8 
                                        60

Category III
                                             8
                                         80
                                         24
                                         12 
                                      124

Category IV
                                           12 
                                        96
                                         32
                                         16
                                      156
            
 The interviewee had done technical amendments to an existing SPCC Plan.
 The total number of hours required to amend an existing SPCC Plan are 12 (Category I), 24 (Category II), 38 (Category III), and 50 (Category IV).
 See Table 3 for hours estimates by labor category.
            
Table 3: Hours for Plan amendment for new and existing facilities

 
 
                                  Management
                                   Technical
                                    Drafter
                                   Clerical
                                     Total
Storage
Category I
                                            2
                                           8
                                          -   
                                            2 
                                      12

Category II
                                            4
                                           16
                                          -   
                                            4 
                                      24

Category III
                                           8
                                           24
                                          -   
                                            6 
                                      38

Category IV
                                         10
                                          32
                                          -   
                                            8
                                      50
            
 The interviewee had prepared a five-year review of an existing Plan.
 The total number of hours required to conduct a five-year review are 12 (Category I), 20 (Category II), 31 (Category III), and 41 (Category IV).
 See Table 4 for hours estimates by labor category.
            
Table 4: Hours for five-year review for existing Plan

 
 
                                  Management
                                   Technical
                                    Drafter
                                   Clerical
                                     Total
Storage
Category I
                                            2 
                                           8
                                          -   
                                            2 
                                        12

Category II
                                            2 
                                          16
                                          -   
                                            2 
                                        20

Category III
                                            3 
                                           24
                                          -   
                                            4
                                        31

Category IV
                                            5 
                                           32
                                          -   
                                            4
                                        41

 The interviewee had developed a SPCC facility diagram.
 See Table 5 for hours estimates by labor category.
            
Table 5: Hours for creating facility diagram


 
                              Annual Hours Burden
                                       

                                  Management
                                   Technical
                                    Drafter
                                   Clerical
                                     Total
Storage
Category I
                                                                              1
                                                                             4 
                                                                            12 
                                                                           -   
                                      17

Category II
                                                                             1 
                                                                             8 
                                                                            24 
                                                                           -   
                                      33

Category III
                                                                             2 
                                                                            12 
                                                                            30 
                                                                           -   
                                      44

Category IV
                                                                              2
                                                                            18 
                                                                            40 
                                                                           -   
                                      60

 PRODUCTION FACILITIES  -  For services for Category I facilities and sometimes Category II facilities, hours estimates provided by EPA were lower than what Interspec provided. For Category III and IV facilities, hours estimates provided by EPA were higher than what Interspec provided.
 The interviewee had prepared a new Plan for a new facility. He specifically mentioned developing a new Plan for a refinery that was expanding to contain new tanks.
 The total number of hours required to prepare a new plan are 46 (Category I), 60 (Category II), 102 (Category III), and 161 (Category IV).
 See Table 6 for hours estimates by labor category. Interspec's hours were higher than EPA's estimates for all labor categories for Category I facilities, and management and drafter for Category II. All other hours were similar to EPA's estimates.
            
Table 6: Hours for preparation of new Plan for new facilities



                                  Management
                                   Technical
                                    Drafter
                                   Clerical
                                     Total
Production
Category I
                                             4
                                         24
                                         16
                                           2 
                                        46

Category II
                                            4  
                                         32 
                                         20
                                           4 
                                        60

Category III
                                             6
                                         64 
                                         24
                                           8 
                                      102

Category IV
                                             8 
                                         96 
                                         45 
                                         12 
                                      161 
            
 The interviewee had done technical amendments to an existing SPCC Plan.
 The total number of hours required to amend an existing SPCC Plan are 14 (Category I), 18 (Category II), 30 (Category III), and 44 (Category IV).
 See Table 7 for hours estimates by labor category. Category I hours were higher than EPA estimates, and all other size category hours were lower than EPA estimates.
            
Table 7: Hours for Plan amendment for new and existing facilities

 
 
                                  Management
                                   Technical
                                    Drafter
                                   Clerical
                                     Total
Production
Category I
                                            4
                                           8
                                          -   
                                          2
                                       14

Category II
                                            4
                                           12
                                          -   
                                         2 
                                        18

Category III
                                            6
                                           20
                                          -   
                                         4 
                                        30

Category IV
                                            8 
                                           30
                                          -   
                                         6 
                                        44

 The interviewee had prepared a five-year review of an existing Plan.
 The total number of hours required to prepare a five-year review are 12 (Category I), 14 (Category II), 20 (Category III), and 30 (Category IV).
 See Table 8 for hours estimates by labor category. Category I hours were higher than EPA estimates, and all other size category hours were lower than EPA estimates.
            
            
            
Table 8: Hours for five-year review for existing facilities

 
 
                                  Management
                                   Technical
                                    Drafter
                                   Clerical
                                     Total
Production
Category I
                                            2
                                           8
                                          -   
                                          2
                                         12

Category II
                                            2
                                           10
                                          -   
                                          2
                                        14

Category III
                                            2 
                                           16
                                          -   
                                         2 
                                       20 

Category IV
                                            2
                                           24
                                          -   
                                          4
                                       30 

 The interviewee had created an SPCC facility diagram.
 See Table 9 for hours estimates by labor category. Category I and II hours were higher than EPA estimates, and the other size category hours were lower than EPA estimates.
            
Table 9: Hours for creating facility diagram


 
                              Annual Hours Burden
                                       

                                  Management
                                   Technical
                                    Drafter
                                   Clerical
                                     Total
Production
Category I
                                                                              2
                                                                             4 
                                                                             8 
                                                                           -   
                                      14

Category II
                                                                              2
                                                                             6 
                                                                             16
                                                                           -   
                                      24

Category III
                                                                             2 
                                                                            12 
                                                                            24 
                                                                           -   
                                      38

Category IV
                                                                              4
                                                                            18 
                                                                            32 
                                                                           -   
                                      54


4.  ECCI Response
 The interviewee indicated that his firm provides engineering or technical support to facilities subject to SPCC regulation.
 The interviewee is a Senior environmental scientist at ECCI.
 The interviewee did not need to be reminded of what the SPCC regulation was.
 The interviewee personally had worked on five or six SPCC Plans per year and estimated that the firm had worked on 30 per year.
 The types of facilities ECCI develops SPCC Plans for include mostly manufacturing facilities and a few oil storage facilities. They have not worked with farms in the past five years but developed about 100 Plans back then. They do not work with production facilities.
 ECCI prices SPCC Plan development as mostly time and materials but sometime as fixed price.
 STORAGE FACILITIES - Hours estimates provided by EPA were mostly higher than what ECCI provided.
 The interviewee had prepared a new Plan for a new facility (only Categories I and II).
 The total number of hours required to prepare a new Plan are 48 (Category I) and 48 (Category II).
 See Table 2 for hours estimates by labor category.
            
            
Table 2: Hours for preparation of new SPCC Plan for new facilities



                                  Management
                                   Technical
                                    Drafter
                                   Clerical
                                     Total
Storage
Category I
            2
                                         30 
                                       4 to 8
         2
                                    38 to 42 

Category II
            2
                                         30 
                                       4 to 8
         2
                                    38 to 42 

Category III
                                     n/a 
                                        n/a
                                       n/a
                                      n/a
                                      n/a

Category IV
                                      n/a
                                        n/a
                                        n/a
                                      n/a
                                      n/a

 The interviewee had done technical amendments to an existing SPCC Plan.
 The total number of hours required to amend an existing Plan are 22 (Category I) and 22 (Category II).
 See Table 3 for hours estimates by labor category.
            
Table 3: Hours for Plan amendment for new and existing facilities

 
 
                                  Management
                                   Technical
                                    Drafter
                                   Clerical
                                     Total
Storage
Category I
           2
                                          15 
                                    1 to 2
                                            2 
                                   20 to 21

Category II 
           2 
                                          15 
                              1 to 2            
                                            2 
                                   20 to 21

Category III
                                      n/a
                                          n/a
                                          -   
                                           n/a 
                                      n/a

Category IV
                                      n/a
                                          n/a
                                          -   
                                           n/a
                                      n/a

 The interviewee had prepared a five-year review of an existing Plan.
 The total number of hours required to conduct a five-year review are 28 (Category I) and 28 (Category II).
 See Table 4 for hours estimates by labor category.
            
Table 4: Hours for five-year review for existing Plan

 
 
                                  Management
                                   Technical
                                    Drafter
                                   Clerical
                                     Total
Storage
Category I
                                            2 
                                           23
                                            1
                                            2 
                                        28

Category II
                                            2 
                                           23
                                            1
                                            2 
                                       28 

Category III
                                           n/a 
                                          n/a
                                          -   
                                           n/a
                                       n/a

Category IV
                                           n/a 
                                          n/a
                                          -   
                                           n/a
                                       n/a
            
 The interviewee had developed an SPCC facility diagram.
 See Table 5 for hours estimates by labor category.
            
Table 5: Hours for creating facility diagram


 
                              Annual Hours Burden
                                       

                                  Management
                                   Technical
                                    Drafter
                                   Clerical
                                     Total
Storage
Category I
                                       1
                                       2
                                    4 to 8
                                                                           -   
                                    7 to 11

Category II
                                       1
                                       2
                                    4 to 8
                                                                           -   
                                    7 to 11

Category III
                                      n/a
                                      n/a
                                      n/a
                                                                           -   
                                      n/a

Category IV
                                      n/a
                                      n/a
                                      n/a
                                                                           -   
                                      n/a


                         Part B  -  Record of Contacts

1. Contact with Keitu:

From: Kathleen Spilman <kspilman@keitu.com> 
Sent: Wednesday, August 14, 2019 12:51 PM
To: Kung, Megan <Megan.Kung@icf.com>
Subject: RE: SPCC Information Request for U.S. EPA

(701) 667-1808 x100 which will ring on my desk -K.


From: Kung, Megan <Megan.Kung@icf.com> 
Sent: Wednesday, August 14, 2019 9:42 AM
To: kspilman@keitu.com
Subject: RE: SPCC Information Request for U.S. EPA

Great, that works for me. What phone number would be best to reach you at?

-Megan

From: Kathleen Spilman <kspilman@keitu.com> 
Sent: Tuesday, August 13, 2019 6:00 PM
To: Kung, Megan <Megan.Kung@icf.com>
Subject: RE: SPCC Information Request for U.S. EPA

Let's do Thursday afternoon at 2 pm Central 3 pm Eastern.  Kathye

From: Kung, Megan <Megan.Kung@icf.com> 
Sent: Tuesday, August 13, 2019 3:54 PM
To: kspilman@keitu.com
Subject: RE: SPCC Information Request for U.S. EPA

Hi Kathleen,

Your knowledge of the preparation of SPCC plans is exactly what we are looking for! Attached is a copy of our questions. What date and time work best for you to talk over the phone? Except for Wednesday and Friday mornings, my schedule is pretty flexible.

Thanks,
Megan

From: Kathleen Spilman <kspilman@keitu.com> 
Sent: Tuesday, August 13, 2019 4:03 PM
To: Kung, Megan <Megan.Kung@icf.com>
Subject: RE: SPCC Information Request for U.S. EPA

Since we are consulting engineers and do not have any of the operational aspects of SPCC compliance, I don't know we would be of much help.  Our responses are going to be limited to coordination and preparation of the actual SPCC plan itself. n.

But go ahead and send the questionnaire.  I'll do what I can.  The incorporation of state required drainage controls / secondary containment requirements into the Federal rules should have required SPCC plan changes every two years for the last 10 years in North Dakota for all the oil and gas production.  Less so in Montana. 

Kathleen M. Spilman, P.E.
Managing Director

Keitu Engineers & Consultants, Inc.
1403 27th St. NW; PO Box 98
Mandan, ND 58554
(701) 667-1808 x.100
(701) 527-0277 iPhone

From: Kung, Megan <Megan.Kung@icf.com> 
Sent: Tuesday, August 13, 2019 2:43 PM
To: info@keitu.com
Subject: SPCC Information Request for U.S. EPA

To Whom It May Concern at Keitu Engineers & Consultants: 

My name is Megan Kung, and I work for ICF. We are a contractor for the U.S. Environmental Protection Agency. Every three years, EPA updates its estimates for paperwork-related burden for implementing the Spill Prevention Control and Countermeasure (SPCC) regulation. Would you have time in the next week or so to speak with us and answer some questions about the number of burden hours required for completing SPCC paperwork? If so, I will send over our questions in advance to facilitate our conversation. The phone call should take about 15 minutes. Your responses will help EPA determine reasonable burden hours required for completing SPCC paperwork. 

Thanks,
Megan



 MEGAN KUNG | Economics Specialist | +1.202.862.1122 | megan.kung@icf.com | icf.com
 ICF | 1725 I Street NW, Washington, D.C 20006 USA 




2. Contact with RSB Environmental:

Subject: RE: SPCC Information Request for U.S. EPA
From: Kung, Megan <Megan.Kung@icf.com>
Date: 8/19/19 9:51 am
To: nirav@rsbenv.com <nirav@rsbenv.com>
Attached are the questions. 

-Megan

From: nirav@rsbenv.com <nirav@rsbenv.com> 
Sent: Monday, August 19, 2019 9:48 AM
To: Kung, Megan <Megan.Kung@icf.com>
Subject: RE: SPCC Information Request for U.S. EPA

Megan,
 
Tuesday 2:30 Central works. If you can email me a copy of the questions that would be great.
 
Thanks
Nirav
 
--------- Original Message --------- 
Subject: RE: SPCC Information Request for U.S. EPA
From: Kung, Megan <Megan.Kung@icf.com>
Date: 8/19/19 8:42 am
To: nirav@rsbenv.com <nirav@rsbenv.com>
Hi Nirav,
 
Tuesday 2:30 Central/3:30 Eastern works for me. Let me know if you need a copy of the questions. Looking forward to it!
 
Thanks,
Megan
 
From: nirav@rsbenv.com <nirav@rsbenv.com> 
Sent: Monday, August 19, 2019 9:31 AM
To: Kung, Megan <Megan.Kung@icf.com>
Cc: Nilay Prajapati <nilay@rsbenv.com>
Subject: RE: SPCC Information Request for U.S. EPA
 
Megan,
 
Tuesday around 2:30 works. 
 
You can contact me on 281-725-3177.
 
Hope that works.
 
Regards,
 
Nirav Patel
Project Manager
RSB Environmental 
Cell: 281-725-3177
www.rsbenv.com
 
--------- Original Message ---------
Subject: RE: SPCC Information Request for U.S. EPA
From: Kung, Megan <Megan.Kung@icf.com>
Date: 8/19/19 8:26 am
To: Nilay Prajapati <nilay@rsbenv.com>, nirav@rsbenv.com <nirav@rsbenv.com>
Hi Nilay and Nirav,
 
Hope you had a nice weekend. Would either of you be available this week for a phone call to answer the questions from EPA? Tuesday or Wednesday would work best for me, but my schedule is pretty flexible this week.
 
Thanks,
Megan
 
From: sachin@rsbenv.com <sachin@rsbenv.com> 
Sent: Friday, August 16, 2019 1:22 PM
To: Kung, Megan <Megan.Kung@icf.com>
Cc: 'Nilay Prajapati' <nilay@rsbenv.com>; nirav@rsbenv.com
Subject: RE: SPCC Information Request for U.S. EPA
 
Please work with Nilay and Nirav to do this.
 
Regards,
Sachin Butala, PE
President

Corporate Office: 6001 Savoy Dr., Ste. 110
Houston, Texas 77036 
Cell: 713.444.6316
www.rsbenv.com 
 
From: Kung, Megan <Megan.Kung@icf.com> 
Sent: Friday, August 16, 2019 11:51 AM
To: sachin@rsbenv.com
Subject: RE: SPCC Information Request for U.S. EPA
 
Hi Sachin,
 
Just following up on setting up a phone call for the information request. Would Monday or Wednesday afternoon work for you?
 
Thanks,
Megan
 
From: Kung, Megan 
Sent: Tuesday, August 13, 2019 4:57 PM
To: 'sachin@rsbenv.com' <sachin@rsbenv.com>
Subject: RE: SPCC Information Request for U.S. EPA
 
Hi Sachin,
 
Great! Attached is a copy of our questions. Could we schedule for Monday Aug. 19 at 2pm?
 
Thanks,
Megan
 
From: sachin@rsbenv.com <sachin@rsbenv.com> 
Sent: Tuesday, August 13, 2019 4:05 PM
To: Kung, Megan <Megan.Kung@icf.com>; info@rsbenv.com
Subject: RE: SPCC Information Request for U.S. EPA
 
Megan:
 
Thanks for contacting us. Yes, we are happy to discuss this opportunity with you. Please send over questions. Next week any day after 1 pm is fine for a phone call.
 
Regards,
Sachin Butala, PE
President

Corporate Office: 6001 Savoy Dr., Ste. 110
Houston, Texas 77036 
Cell: 713.444.6316
www.rsbenv.com 
 
From: Kung, Megan <Megan.Kung@icf.com> 
Sent: Tuesday, August 13, 2019 2:41 PM
To: info@rsbenv.com
Subject: SPCC Information Request for U.S. EPA
 
To Whom It May Concern at RSB Environmental:
 
My name is Megan Kung, and I work for ICF. We are a contractor for the U.S. Environmental Protection Agency. Every three years, EPA updates its estimates for paperwork-related burden for implementing the Spill Prevention Control and Countermeasure (SPCC) regulation. Would you have time in the next week or so to speak with us and answer some questions about the number of burden hours required for completing SPCC paperwork? If so, I will send over our questions in advance to facilitate our conversation. The phone call should take about 15 minutes. Your responses will help EPA determine reasonable burden hours required for completing SPCC paperwork.
 
Thanks,
Megan
 
 

 MEGAN KUNG | Economics Specialist | +1.202.862.1122 | megan.kung@icf.com | icf.com
 ICF | 1725 I Street NW, Washington, D.C 20006 USA 


3. Contact with InterSpec:
From: Gary Boley <BoleyG@interspecllc.net>
Sent: Tuesday, August 20, 2019 5:13 PM
To: Ahronian, Amber <Amber.Ahronian@icf.com>
Subject: Re: SPCC hours

2:30 is fine

Gary Boley
Sr. Engineer/ Sr. Inspector

Environmental Inspection Services
American Indian / Veteran Owned Small Business, Seaport-E
464 S Independence Blvd, C-104
Virginia Beach, VA 23452
757-622-6299 Office
757-622-9103 Fax
757-434-6402 Cell
www.interspecllc.net

-----Original Appointment-----
From: Ahronian, Amber <Amber.Ahronian@icf.com> 
Sent: Tuesday, August 20, 2019 4:46 PM
To: Gary Boley
Subject: SPCC hours
When: Wednesday, August 21, 2019 2:30 PM-3:00 PM (UTC-05:00) Eastern Time (US & Canada).
Where: phone call

Hi Gary,

Hopefully you have seen the email I sent this earlier today. I wanted to follow up on the timing change. If 2:30 pm EST does not work for you, please let me know a few times that would work, and I will update our meeting on Outlook.

Thank you,
Amber

From: Ahronian, Amber <Amber.Ahronian@icf.com> 
Sent: Tuesday, August 20, 2019 2:44 PM
To: Gary Boley <BoleyG@interspecllc.net>
Subject: RE: SPCC hours

Gary,

I am terribly sorry to shift things around, but would you be able to move our discussion to either 12 pm EST or any time 2 pm EST or later? If so, I will send you an updated calendar invitation. I apologize if this creates an inconvenience for you or your schedule.

Thank you,
Amber

Amber Ahronian | Environmental Scientist | +1 (617) 218-3564 
amber.ahronian@icf.com | icf.com
ICF | 100 Cambridgepark Dr, Cambridge, MA 02140 USA  



From: Gary Boley <BoleyG@interspecllc.net> 
Sent: Tuesday, August 20, 2019 10:52 AM
To: Ahronian, Amber <Amber.Ahronian@icf.com>
Subject: Re: SPCC hours

757-622-6299 or 757-434-6402  


Gary,

Could you please share the best phone number for me to reach you tomorrow?

Looking forward to our discussion tomorrow at 9:30 am EST.

Thank you,
Amber

_____________________________________________
From: Gary Boley <BoleyG@interspecllc.net> 
Sent: Tuesday, August 20, 2019 10:46 AM
To: Ahronian, Amber <Amber.Ahronian@icf.com>
Cc: Michelle O. Morris <MorrisO@interspecllc.net>
Subject: Re: SPCC hours

Let's do 9:30 tomorrow. 

From: Ahronian, Amber <Amber.Ahronian@icf.com>
Sent: Tuesday, August 20, 2019 10:26:58 AM
To: Gary Boley <BoleyG@interspecllc.net>
Subject: RE: SPCC hours 

Gary,

Thank you very much for getting back to me. I've attached the questions. Please let me know if tomorrow at 9:30 am EST works for our quick (~15 minute) discussion. Otherwise, I am available to talk between 12 and 1pm or after 2pm. I will send you a calendar invitation for whichever time works best with your schedule.

Best,
Amber

Amber Ahronian | Environmental Scientist | +1 (617) 218-3564 
amber.ahronian@icf.com | icf.com
ICF | 100 Cambridgepark Dr, Cambridge, MA 02140 USA  



From: Gary Boley <BoleyG@interspecllc.net> 
Sent: Tuesday, August 20, 2019 10:17 AM
To: Ahronian, Amber <Amber.Ahronian@icf.com>
Cc: Michelle O. Morris <MorrisO@interspecllc.net>
Subject: SPCC hours

Amber, I will be in my office tomorrow, Thursday and Friday. Please send me the questions you have. I will be prepared to discuss. 

Gary

Get Outlook for iOS

From: Ahronian, Amber <Amber.Ahronian@icf.com>
Sent: Tuesday, August 20, 2019 9:14 AM
To: Gary Boley <BoleyG@interspecllc.net>
Subject: SPCC Consultation

Good morning,

My name is Amber Ahronian, and I work for ICF. We are a contractor for the U.S. Environmental Protection Agency. Every three years, EPA updates its estimates for paperwork-related burden for implementing the Spill Prevention Control and Countermeasure (SPCC) regulation. Would you have time in the next couple of days to speak with us and answer some questions about the number of burden hours required for completing SPCC paperwork? If so, I will send over our questions in advance to facilitate our conversation. The phone call should take about 15 minutes. Your responses will help EPA determine reasonable burden hours required for completing SPCC paperwork. 

Thank you,
Amber


Amber Ahronian | Environmental Scientist | +1 (617) 218-3564 
amber.ahronian@icf.com | icf.com
ICF | 100 Cambridgepark Dr, Cambridge, MA 02140 USA  

4.  Contact with ECCI:

From: Ahronian, Amber <Amber.Ahronian@icf.com>
Sent: Tuesday, August 20, 2019 9:43 AM
To: Jeremy Stehle <JStehle@ecci.com>
Subject: RE: SPCC Questions


Jeremy,

Thank you for your flexibility on timing. I very much appreciate it.

Looking forward to our conversation.

Best,
Amber

From: Jeremy Stehle <JStehle@ecci.com>
Sent: Tuesday, August 20, 2019 9:38 AM
To: Ahronian, Amber <Amber.Ahronian@icf.com> 
Subject: RE: SPCC Questions


Amber,

Good morning,  I am flexible 2 pm eastern works for me.  

Thanks,

Jeremy 

From: Ahronian, Amber <Amber.Ahronian@icf.com> 
Sent: Tuesday, August 20, 2019 8:37 AM
To: Jeremy Stehle <JStehle@ecci.com>
Subject: RE: SPCC Questions

Good morning Jeremy,

I know we had settled on speaking at 11 am EST. Would it be possible to shift that to 2pm EST (or any other time today)? If so, I will send you a new meeting invitation. I apologize for shifting things around, and I hope it doesn't inconvenience you or your schedule today.

Thank you,
Amber

Amber Ahronian | Environmental Scientist | +1 (617) 218-3564 
amber.ahronian@icf.com | icf.com
ICF | 100 Cambridgepark Dr, Cambridge, MA 02140 USA  



From: Jeremy Stehle <JStehle@ecci.com> 
Sent: Monday, August 19, 2019 4:45 PM
To: Ahronian, Amber <Amber.Ahronian@icf.com>
Subject: RE: SPCC Questions

Amber,

Talk to you tomorrow.

Thanks,

Jeremy 


Jeremy,
From: Ahronian, Amber <Amber.Ahronian@icf.com> 
Sent: Monday, August 19, 2019 3:47 PM
To: Jeremy Stehle <JStehle@ecci.com>
Subject: RE: SPCC Questions

Correct -- eastern time. My mistake for not specifying.

Thanks,
Amber

Amber Ahronian | Environmental Scientist | +1 (617) 218-3564 
amber.ahronian@icf.com | icf.com
ICF | 100 Cambridgepark Dr, Cambridge, MA 02140 USA  



-----Original Appointment-----
From: Jeremy Stehle <JStehle@ecci.com> 
Sent: Monday, August 19, 2019 4:41 PM
To: Ahronian, Amber
Subject: Accepted: SPCC Questions
When: Tuesday, August 20, 2019 11:00 AM-11:30 AM (UTC-05:00) Eastern Time (US & Canada).
Where: phone call

Amber,

In your email you have the time as 11 am. Is that eastern time?

Thanks,

Jeremy

 From: Ahronian, Amber <Amber.Ahronian@icf.com> 
Sent: Monday, August 19, 2019 4:36 PM
To: Jeremy Stehle <JStehle@ecci.com>
Subject: RE: SPCC Questions

Jeremy,

Please feel free to propose a different time, if 11 am is not best. I see that your email signature lists your phone number as 501-975-8100, so I will call you tomorrow at that number.

Looking forward to speaking with you,
Amber
From: Jeremy Stehle <JStehle@ecci.com> 
Sent: Monday, August 19, 2019 4:28 PM
To: Ahronian, Amber <Amber.Ahronian@icf.com>
Subject: RE: SPCC Questions


Amber,

I am available anytime tomorrow.

Thanks,

Jeremy

From: Ahronian, Amber <Amber.Ahronian@icf.com> 
Sent: Monday, August 19, 2019 3:25 PM
To: Jeremy Stehle <JStehle@ecci.com>
Subject: RE: SPCC Questions

Hi Jeremy,

Thank you for getting back to me. Are you available any time tomorrow to answer the SPCC questions (see attached)? If not, I am available after 2pm on Wednesday.

Thanks again,
Amber

Amber Ahronian | Environmental Scientist | +1 (617) 218-3564 
amber.ahronian@icf.com | icf.com
ICF | 100 Cambridgepark Dr, Cambridge, MA 02140 USA  

From: Jeremy Stehle <JStehle@ecci.com> 
Sent: Monday, August 19, 2019 4:10 PM
To: Ahronian, Amber <Amber.Ahronian@icf.com>
Subject: SPCC Questions

Amber,

I work on SPCC Plans for ECCI.  If you would like to schedule a call to answer your questions I am free this week to do so. 

Thanks,

Jeremy Stehle
Senior Environmental Scientist
ECCI
13000 Cantrell Road
Little Rock, Arkansas
501-975-8100
jstehle@ecci.com
ECCI.com

Dear Amber Ahronian,
Thank you!  Your contact email to ECCI has been received. Here is a summary of the information you submitted to ECCI:
-------------------------------
Attention: Engineering Group
Company Name: ICF
Your Full Name: Amber Ahronian
E-mail: amber.ahronian@icf.com
Telephone: 6172183564
Comments:
Good morning,

Last week, I submitted this form to the Administration group and have not yet received a response. I'm thinking your group (Engineering) may be the more appropriate contact. 

My name is Amber Ahronian, and I work for ICF. We are a contractor for the U.S. Environmental Protection Agency. Every three years, EPA updates its estimates for paperwork-related burden for implementing the Spill Prevention Control and Countermeasure (SPCC) regulation. Would you have time in the next couple of days to speak with us and answer some questions about the number of burden hours required for completing SPCC paperwork? If so, I will send over our questions in advance to facilitate our conversation. The phone call should take about 15 minutes. Your responses will help EPA determine reasonable burden hours required for completing SPCC paperwork. 

Thank you,
Amber
-------------------------------
Thank you for your interest in ECCI.
Sincerely,
ECCI

Dear Amber Ahronian,
Thank you!  Your contact email to ECCI has been received. Here is a summary of the information you submitted to ECCI:
-------------------------------
Attention: Administration
Company Name: ICF
Your Full Name: Amber Ahronian
E-mail: amber.ahronian@icf.com
Telephone: 6172183564
Comments:
My name is Amber Ahronian, and I work for ICF. We are a contractor for the U.S. Environmental Protection Agency. Every three years, EPA updates its estimates for paperwork-related burden for implementing the Spill Prevention Control and Countermeasure (SPCC) regulation. Would you have time in the next week or so to speak with us and answer some questions about the number of burden hours required for completing SPCC paperwork? If so, I will send over our questions in advance to facilitate our conversation. The phone call should take about 15 minutes. Your responses will help EPA determine reasonable burden hours required for completing SPCC paperwork. Thank you.
-------------------------------
Thank you for your interest in ECCI.
Sincerely,
ECCI


                  Part C  -  Record of Unsuccessful Contacts

1. Contact with Spence Environmental Consulting, Inc.:

From: Ahronian, Amber <Amber.Ahronian@icf.com>
Sent: Thursday, August 22, 2019 9:18 AM
To: John Mills <john.mills@spenceenv.com> 
Subject: RE: SPCC paperwork burden

Good morning John,

Thanks for getting back to me. I've attached the questions. If you do have a chance to answer them this week, we'd greatly appreciate your input. After some background questions, there are two main sections of the document -- one about storage facilities (questions 7a-7k) and the other about production facilities (8a-8k). If your firm only serves one of these types of facilities (storage or production), please feel free to only answer the questions associated with that facility type. Otherwise, we'd like to get your input on both sections. And feel free to type right into the tables, if any of the numbers we provided seem unreasonable to you.

Please reach out to me with any questions.

Best,
Amber

Amber Ahronian | Environmental Scientist | +1 (617) 218-3564 
amber.ahronian@icf.com | icf.com
ICF | 100 Cambridgepark Dr, Cambridge, MA 02140 USA  



From: John Mills <john.mills@spenceenv.com> 
Sent: Thursday, August 22, 2019 8:36 AM
To: Ahronian, Amber <Amber.Ahronian@icf.com>
Subject: RE: SPCC paperwork burden

Good morning Amber,

Sorry for the delay in getting back to you.  I've been in the field for the last few days, it might be easier to send the questions via email as I'll be out a few days next week too.  Let me know your thoughts, thanks.

John Mills
Spence Environmental Consulting, Inc.
70 West Columbus Street
Pickerington, Ohio 43147
Office: (614) 837-4750
Fax: (614) 837-4755
Mobile: (614) 813-1332

From: Ahronian, Amber <Amber.Ahronian@icf.com>
Sent: Monday, August 19, 2019 10:50 AM
To: John Mills <john.mills@spenceenv.com> 
Subject: RE: SPCC paperwork burden

Hi John,

I wanted to follow up with you. Would someone from Spence Environmental Consulting have time in the next couple of days to answer these questions? If it would be easier to answer the questions over email/in the document I attached, rather than over the phone, that is another option.

Thank you,
Amber

Amber Ahronian | Environmental Scientist | +1 (617) 218-3564 
amber.ahronian@icf.com | icf.com
ICF | 100 Cambridgepark Dr, Cambridge, MA 02140 USA  
From: Ahronian, Amber <Amber.Ahronian@icf.com>
Sent: Wednesday, August 14, 2019 10:34 AM
To: John Mills <john.mills@spenceenv.com> 
Subject: SPCC paperwork burden

Hi John,

Thank you for speaking with me this morning. As I mentioned on the phone, I work for ICF. We are a contractor for the U.S. Environmental Protection Agency. Every three years, EPA updates its estimates for paperwork-related burden for implementing the Spill Prevention Control and Countermeasure (SPCC) regulation. Would you or someone else at Spence Environmental Consulting, Inc. have time in the next week or so to speak with us and answer some questions about the number of burden hours required for completing SPCC paperwork? I have attached our questions in advance to facilitate our conversation. The phone call should take about 15 minutes. Your responses will help EPA determine reasonable burden hours required for completing SPCC paperwork. 

Thank you very much,
Amber


Amber Ahronian | Environmental Scientist | +1 (617) 218-3564 
amber.ahronian@icf.com | icf.com
ICF | 100 Cambridgepark Dr, Cambridge, MA 02140 USA  


Called Spence Environmental Consulting, Inc. 8/14/19




2. Contact with Partner Engineering and Science:

Outlook invitation sent by David Dumond and accepted on Aug. 22, 2019 at 2:03 p.m. Called three times during the agreed time, between 11:00-11:30 a.m. on Aug. 23 but received no response.


_____________________________________________
From: Kung, Megan <Megan.Kung@icf.com> 
Sent: Thursday, August 22, 2019 1:00 PM
To: Dumond, David <ddumond@partneresi.com>
Cc: Javier, Kelly <kjavier@partneresi.com>
Subject: RE: SPCC Information Request for U.S. EPA

Hi David,

Sorry we couldn't speak yesterday. Would it be possible to speak today or tomorrow? We're hoping to get responses by the end of the day tomorrow. If you're too busy, the questions can be answered in the Word doc and emailed back. And if you can't answer everything, that's fine too.

Thanks,
Megan

From: Kung, Megan 
Sent: Monday, August 19, 2019 11:10 AM
To: 'Dumond, David' <ddumond@partneresi.com>
Cc: Javier, Kelly <kjavier@partneresi.com>
Subject: RE: SPCC Information Request for U.S. EPA

Hi David,

Wednesday works for me. How's 10:00 Central/11:00 Eastern? My schedule is flexible that day if that doesn't work.

-Megan

From: Dumond, David <ddumond@partneresi.com> 
Sent: Monday, August 19, 2019 11:05 AM
To: Kung, Megan <Megan.Kung@icf.com>
Cc: Javier, Kelly <kjavier@partneresi.com>
Subject: RE: SPCC Information Request for U.S. EPA

Megan:

I will have this reviewed and can do a call this Wednesday.

Is that sufficient?

Regards.

David Dumond
National Client Manager  -  Multi Sector Markets

Partner Engineering and Science, Inc.
12012 Wickchester Lane
Houston, Texas 77079 
O: 713.892.5515 | F: 713.714.5828 | D: 346.978.3409
                                       
Engineers who understand your business
Environmental Consulting & Remediation | Industrial Hygiene | Health, Safety & Regulatory Consulting |
Building Assessments & Engineering | Energy & Sustainability Consulting | Site Civil Engineering | Land Surveying | Construction Services

More Than Just Assessments. Solutions  -  For a complete list of services, click here

From: Kung, Megan <Megan.Kung@icf.com> 
Sent: Monday, August 19, 2019 9:47 AM
To: Dumond, David <ddumond@partneresi.com>
Cc: Javier, Kelly <kjavier@partneresi.com>; Geiger, Bob <BGeiger@partneresi.com>
Subject: RE: SPCC Information Request for U.S. EPA

Hi David,

Attached are the questions. Thanks!

-Megan

From: Dumond, David <ddumond@partneresi.com> 
Sent: Monday, August 19, 2019 10:29 AM
To: Kung, Megan <Megan.Kung@icf.com>
Cc: Javier, Kelly <kjavier@partneresi.com>; Geiger, Bob <BGeiger@partneresi.com>
Subject: RE: SPCC Information Request for U.S. EPA

Hi Megan:

Please send me your proposed questions so that we can assess our ability to effectively support.

Regards.

David Dumond
National Client Manager  -  Multi Sector Markets

Partner Engineering and Science, Inc.
12012 Wickchester Lane
Houston, Texas 77079 
O: 713.892.5515 | F: 713.714.5828 | D: 346.978.3409
                                       
Engineers who understand your business
Environmental Consulting & Remediation | Industrial Hygiene | Health, Safety & Regulatory Consulting |
Building Assessments & Engineering | Energy & Sustainability Consulting | Site Civil Engineering | Land Surveying | Construction Services

More Than Just Assessments. Solutions  -  For a complete list of services, click here

From: Javier, Kelly 
Sent: Monday, August 19, 2019 9:21 AM
To: Geiger, Bob <BGeiger@partneresi.com>; Dumond, David <ddumond@partneresi.com>
Subject: FW: SPCC Information Request for U.S. EPA



Kelly Javier (McMicken)
Principal
Digital Marketing and Events Manager

Partner Engineering and Science, Inc.
2154 Torrance Boulevard, Torrance, CA 90501
C: 310-612-6195 | D: 310-765-7274 | F: 310-615-4544

More Than Just Assessments. Solutions  -  For a complete list of services, click here

From: Kung, Megan <Megan.Kung@icf.com> 
Sent: Monday, August 19, 2019 6:35 AM
To: Info - PAC <info@partneresi.com>
Subject: RE: SPCC Information Request for U.S. EPA

Hello,

I would just like to follow up on my email from last week. Would someone be available to answer some questions from EPA this week? If it's easier, the questions can also be answered by email.

Thanks,
Megan

From: Kung, Megan 
Sent: Tuesday, August 13, 2019 3:45 PM
To: 'info@partneresi.com' <info@partneresi.com>
Subject: SPCC Information Request for U.S. EPA

To Whom It May Concern at Partner Engineering and Science: 

My name is Megan Kung, and I work for ICF. We are a contractor for the U.S. Environmental Protection Agency. Every three years, EPA updates its estimates for paperwork-related burden for implementing the Spill Prevention Control and Countermeasure (SPCC) regulation. Would you have time in the next week or so to speak with us and answer some questions about the number of burden hours required for completing SPCC paperwork? If so, I will send over our questions in advance to facilitate our conversation. The phone call should take about 15 minutes. Your responses will help EPA determine reasonable burden hours required for completing SPCC paperwork. 

Thanks,
Megan



 MEGAN KUNG | Economics Specialist | +1.202.862.1122 | megan.kung@icf.com | icf.com
 ICF | 1725 I Street NW, Washington, D.C 20006 USA 


3. Contact with Broadbent & Associates, Inc.:

From: Ahronian, Amber <Amber.Ahronian@icf.com>
Sent: Monday, August 19, 2019 11:00 AM
To: <aricm@broadbentinc.com>

Subject: RE: SPCC paperwork burden



Good morning,

I wanted to follow up with you. Would someone from Broadbent & Associates, Inc. have time in the next couple of days to answer these questions? If it would be easier to answer the questions over email, rather than over the phone, that is another option.

Thank you,
Amber


Amber Ahronian | Environmental Scientist | +1 (617) 218-3564 
amber.ahronian@icf.com | icf.com
ICF | 100 Cambridgepark Dr, Cambridge, MA 02140 USA  
From: Ahronian, Amber <Amber.Ahronian@icf.com>
Sent: Wednesday, August 14, 2019 9:57 AM
To: <aricm@broadbentinc.com>

Subject: SPCC paperwork burden

Good morning,

My name is Amber Ahronian, and I work for ICF. We are a contractor for the U.S. Environmental Protection Agency. Every three years, EPA updates its estimates for paperwork-related burden for implementing the Spill Prevention Control and Countermeasure (SPCC) regulation. Would you have time in the next week or so to speak with us and answer some questions about the number of burden hours required for completing SPCC paperwork? If so, I will send over our questions in advance to facilitate our conversation. The phone call should take about 15 minutes. Your responses will help EPA determine reasonable burden hours required for completing SPCC paperwork. 

Thank you,
Amber

Amber Ahronian | Environmental Scientist | +1 (617) 218-3564 
amber.ahronian@icf.com | icf.com
ICF | 100 Cambridgepark Dr, Cambridge, MA 02140 USA  

4. Contact with ATC Group Services LLC:

From: Ahronian, Amber 
Sent: Monday, August 19, 2019 11:01 AM
To: 'atc@atcassociates.com' <atc@atcassociates.com>
Subject: RE: SPCC paperwork burden


Good morning,

I wanted to follow up with you. Would someone from ATC Group Services have time in the next couple of days to answer these questions? If it would be easier to answer the questions over email, rather than over the phone, that is another option.

Thank you,
Amber


Amber Ahronian | Environmental Scientist | +1 (617) 218-3564 
amber.ahronian@icf.com | icf.com
ICF | 100 Cambridgepark Dr, Cambridge, MA 02140 USA  
From: Ahronian, Amber 
Sent: Wednesday, August 14, 2019 9:58 AM
To: 'atc@atcassociates.com' <atc@atcassociates.com>
Subject: SPCC paperwork burden

Good morning,

My name is Amber Ahronian, and I work for ICF. We are a contractor for the U.S. Environmental Protection Agency. Every three years, EPA updates its estimates for paperwork-related burden for implementing the Spill Prevention Control and Countermeasure (SPCC) regulation. Would you have time in the next week or so to speak with us and answer some questions about the number of burden hours required for completing SPCC paperwork? If so, I will send over our questions in advance to facilitate our conversation. The phone call should take about 15 minutes. Your responses will help EPA determine reasonable burden hours required for completing SPCC paperwork. 

Thank you,
Amber

Amber Ahronian | Environmental Scientist | +1 (617) 218-3564 
amber.ahronian@icf.com | icf.com
ICF | 100 Cambridgepark Dr, Cambridge, MA 02140 USA  

5. Contact with EMS Environmental, Inc.:

From: Ahronian, Amber 
Sent: Tuesday, August 20, 2019 2:30 AM
To: 'info@emsenv.com' <info@emsenv.com>
Subject: RE: SPCC consultation

Good afternoon,

I wanted to follow up on this consultation request. If it is easier to answer the questions over email, rather than over the phone, that is an option as well.

Thank you,
Amber

Amber Ahronian | Environmental Scientist | +1 (617) 218-3564 
amber.ahronian@icf.com | icf.com
ICF | 100 Cambridgepark Dr, Cambridge, MA 02140 USA  
From: Ahronian, Amber 
Sent: Tuesday, August 20, 2019 9:12 AM
To: 'info@emsenv.com' <info@emsenv.com>
Subject: SPCC consultation

Good morning,

My name is Amber Ahronian, and I work for ICF. We are a contractor for the U.S. Environmental Protection Agency. Every three years, EPA updates its estimates for paperwork-related burden for implementing the Spill Prevention Control and Countermeasure (SPCC) regulation. Would you have time in the next couple of days to speak with us and answer some questions about the number of burden hours required for completing SPCC paperwork? If so, I will send over our questions in advance to facilitate our conversation. The phone call should take about 15 minutes. Your responses will help EPA determine reasonable burden hours required for completing SPCC paperwork. 

Thank you,
Amber


Amber Ahronian | Environmental Scientist | +1 (617) 218-3564 
amber.ahronian@icf.com | icf.com
ICF | 100 Cambridgepark Dr, Cambridge, MA 02140 USA  

6.  Contact with Martin Resource Management:
Submitted request (same text as to all other PE firms) twice through form on website: http://staging.themartincompanies.com/contact-us/?recipient=Altec%20Environmental%20Consultants,%20Inc.
                                       

