SUPPORTING
STATEMENT
FOR
INFORMATION
COLLECTION
REQUEST
NUMBER
2076.02
"
REPORTING
REQUIREMENTS
UNDER
EPA'S
NATIONAL
PARTNERSHIP
FOR
ENVIRONMENTAL
PRIORITIES"

April
18,
2006
CONTENTS
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
REQUEST
1(
a)
Title
and
Number
of
the
Information
Collection
Request
......................................
1
1(
b)
Short
Characterization
.........................................................................................
1
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need
and
Authority
for
the
Collection..................................................................
2
2(
b)
Practical
Utility/
Users
of
the
Data
........................................................................
2
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
....................................................................................................
3
3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB....................................
3
3(
c)
Consultations
.......................................................................................................
3
3(
d)
Effects
of
Less
Frequent
Collection......................................................................
4
3(
e)
General
Guidelines...............................................................................................
4
3(
f)
Confidentiality
.....................................................................................................
4
3(
g)
Sensitive
Questions
..............................................................................................
4
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents
and
SIC
Codes
................................................................................
4
4(
b)
Information
Requested.........................................................................................
5
5.
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities.................................................................................................
7
5(
b)
Collection
Methodology
and
Management
...........................................................
8
5(
c)
Small
Entity
Flexibility
.........................................................................................
8
5(
d)
Collection
Schedule
.............................................................................................
8
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
COLLECTION
6(
a)
Estimating
Respondent
Burden
............................................................................
9
6(
b)
Estimating
Respondent
Costs...............................................................................
9
6(
c)
Estimating
Agency
Burden
and
Costs.................................................................
10
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
.....................
10
6(
e)
Bottom
Line
Burden
Hours
and
Costs................................................................
11
6(
f)
Reasons
for
Change
in
Burden
...........................................................................
11
Burden
Exhibits........................................................................................................
12­
14
6(
g)
Burden
Statement
..............................................................................................
15
Enrollment
Form.............................................................................................
ATTACHMENT
A
Success
Story
Outline
.....................................................................................
ATTACHMENT
B
1
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
REQUEST
1(
a)
Title
and
Number
of
the
Information
Collection
Request
This
Information
Collection
Request
(
ICR)
is
entitled
"
Reporting
Requirements
Under
EPA's
National
Partnership
for
Environmental
Priorities
(
Renewal)",
EPA
ICR
number
2076.02,
OMB
Control
number
2050­
0190.
This
ICR
renews
the
previous
ICR
entitled
A
Reporting
and
Recordkeeping
Requirements
Under
EPA's
National
Waste
Minimization
Partnership
Program
@.

1(
b)
Short
Characterization
The
U.
S.
Environmental
Protection
Agency
(
EPA)
has
established
a
national
program
to
encourage
the
minimization
of
waste
through
source
reduction
and
recycling.
An
organization
=

s
decision
to
participate
in
the
program
is
completely
voluntary.
The
primary
purpose
of
the
program
is
to
serve
as
a
"
clearing
house"
of
information
on
the
availability
of
technical
assistance,
technical
training,
and
production­
related
success
stories.
Through
the
dissemination
of
this
information,
EPA
hopes
to
further
stimulate
additional
waste
minimization
activities
and
to
present
innovative
technologies
and
production
success
stories
to
a
currently
unserved
public.
EPA
uses
two
forms
to
collect
information
from
partners.
These
forms
can
be
prepared
and
submitted
by
hard
copy
or
electronically.
Participation
begins
when
an
Enrollment
Form
(
see
Attachment
A)
is
submitted
and
received
by
EPA.
The
form
asks
for
basic
site
identification
information
as
well
as
information
on
the
company's
waste
minimization
goal(
s)
under
the
program.
This
form
also
serves
as
an
Additional
NPEP
Goals
Form
for
partners
interested
in
submitting
additional
partnership
goals.

Once
in
the
program,
partners
have
an
opportunity
to
complete
and
submit
a
Success
Story
(
see
Attachment
B),
formerly
known
as
an
Accomplishments
Form,
when
they
have
accomplished
steps
toward
reaching
the
goal(
s)
established
during
their
enrollment
in
the
program.
The
Success
Story
also
serves
as
the
application
for
the
NPEP
Achievement
Award.
These
Success
Stories
are
made
available
on
EPA's
National
Waste
Minimization
Program
website.
Each
success
story
describes
a
partner's
waste
minimization
techniques,
implementation
problems,
lessons
learned,
benefits,
and
relevant
implications.
The
Success
Stories
assist
the
Agency
in
better
understanding
waste
minimization
approaches
and
technologies.
The
information
also
helps
the
Agency
in
sharing
lessons
learned
and
effective
strategies
among
potential
partners,
in
order
to
promote
continued
and
effective
waste
minimization
efforts.
Sharing
effective
waste
reduction
strategies
with
others
is
a
fundamental
objective
of
the
partnership
program.
EPA
estimates
that
each
partner
will
submit
at
least
one
of
these
forms
over
three
years.
These
forms
will
enable
the
Agency
to
establish
a
partner's
progress
and
the
overall
success
of
the
program.
They
will
also
allow
the
Agency
to
recognize
partner
accomplishments
in
a
formal
manner,
if
appropriate
(
e.
g.,
at
a
recognition
ceremony
or
by
congratulatory
letter).
Recognizing
partner
achievements
is
important
to
help
EPA
spur
other
partners
on
to
reduce
more
waste.
These
success
stories
will
also
act
as
a
"
feedstock"
for
the
further
development
of
the
Success
Stories
Data
Base,
which
is
available
electronically.
2
The
previous
ICR
also
allowed
partners
to
submit
an
optional,
one­
time
Case
Study
describing
their
waste
minimization
techniques,
implementation
problems,
lessons
learned,
benefits,
and
relevant
implications.
OMB
had
a
concern
with
the
Agency's
ability
to
verify
claims
made
in
the
Case
Studies,
particularly
in
terms
of
any
data
submitted.
In
response
to
this,
EPA
revised
the
former
Accomplishments
Form
to
include,
not
only
numeric
data
supporting
accomplishments,
but
also
the
more
anecdotal
information
from
the
Case
Study
and
renamed
it
the
Success
Story
outline.
In
addition,
EPA
has
added
a
question
to
the
Enrollment
Form
asking
if
potential
partners
have
a
Quality
Assurance/
Quality
Control
(
QA/
QC)
plan
for
data,
and
on
the
Success
Story
outline
we
ask
them
to
attach
their
QA/
QC
plan
for
any
data
they
submit.
The
Agency
does
not
expect
partners
to
generate
a
QA/
QC
plan
for
data
associated
with
this
voluntary
program;
rather,
we
assume
that
they
have
an
existing
plan
for
the
generation
of
any
data,
and
that
they
will
follow
such
a
plan
for
data
generated
for
their
Success
Stories.
Existing
Success
Stories
from
current
partners
all
contain
numeric
chemical
reduction
data,
and
the
change
to
the
Success
Story
outline
will
insure
that
all
future
Success
Stories
submitted
will
contain
numeric
data
that
supports
partner
accomplishments.

Because
the
program
is
voluntary,
EPA
expects
that
companies
would
enroll
only
if
their
benefits
under
the
program
outweigh
the
costs.
Although
EPA
expects
partners
to
experience
a
minor
burden
under
the
paperwork
requirements
of
the
program,
the
Agency
fully
expects
many
organizations
to
realize
substantial
cost
savings
(
typically
more
than
enough
to
offset
their
paperwork
costs)
through
implementation
of
their
waste
reduction
initiatives.

This
ICR
describes
the
information
collection
procedures
under
EPA's
waste
minimization
partnership
program,
known
as
the
National
Partnership
for
Environmental
Priorities.
In
Sections
1
through
5
of
this
ICR,
EPA
describes
the
forms
and
procedures
in
detail
(
e.
g.,
the
need,
use,
and
data
elements
of
the
forms).
In
Section
6,
EPA
estimates
the
total
annual
hour
and
cost
burden
to
respondents
and
the
Agency
associated
with
these
activities.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need
and
Authority
for
the
Collection
Section
1003
of
the
Resource
Conservation
and
Recovery
Act
states,
as
one
of
the
statutes'
objectives,
"
minimizing
the
generation
of
hazardous
waste
and
the
land
disposal
of
hazardous
waste
by
encouraging
process
substitution,
materials
recovery,
properly
conducted
recycling
and
reuse..."
(
42
U.
S.
C.
321).
The
Pollution
Prevention
Act
of
1990
directs
the
EPA
Administrator
to
"
facilitate
the
adoption
of
source
reduction
techniques
by
businesses
...,
foster
the
exchange
of
information
regarding
source
reduction
techniques
...,
and
[
foster]
the
provision
of
technical
assistance
to
businesses"
(
42
U.
S.
C.
13101).
The
National
Partnership
for
Environmental
Priorities
and
associated
information
collection
activities
assists
the
Agency
in
meeting
the
above
stated
goals
by
facilitating
the
prevention
and
recycling
of
wastes
by
participating
businesses.
Additionally,
stated
by
Congress
(
42
U.
S.
C.
13101)
and
EPA
(
The
Solid
Waste
Dilemma:
An
Agenda
for
Action),
there
are
significant
opportunities
for
businesses
to
reduce
or
prevent
pollution
at
the
source
through
cost
3
effective
changes
in
production,
operation,
and
raw
material
use.
The
Agency
has
developed
a
hierarchy
asserting
that
waste
should
be
prevented
or
reduced
at
the
source
whenever
feasible;
waste
that
cannot
be
prevented
should
be
recycled
where
possible.

2(
b)
Practical
Utility/
Users
of
the
Data
The
information
collected
by
the
partnership
program
is
not
designed
or
intended
to
support
regulatory
decision­
making
by
the
Office
of
Solid
Waste
(
OSW)
or
other
EPA
offices.
EPA
uses
the
information
collected
in
the
Enrollment
Form
to:

 
Formally
establish
each
partner's
participation
in
the
program;
 
Obtain
general
information
on
new
partners,
including
their
waste
minimization
goal(
s);
 
Initiate
contact
with
the
primary
person
in
charge
of
the
member's
waste
minimization
initiatives,
and
assist
each
partner's
efforts;
 
Establish
future
Agency
targets;
and
 
Evaluate
Regional
progress
toward
GPRA
goals.

EPA
uses
each
Success
Story
to:

 
Identify
and
track
a
partner's
accomplishments
in
relation
to
the
goal(
s)
established
under
the
program;
 
Learn
about
the
partner's
waste
minimization
techniques
and
strategies,
particularly
as
they
relate
to
successes
and
problems
and
the
specific
circumstances
of
a
partner's
waste
minimization
challenges,
accomplishments,
and
relevant
implications
(
e.
g.,
techniques,
problems
and
lessons
learned);
 
Share
this
information
with
the
rest
of
the
regulated
community;
 
Modify
and
improve
the
Agency's
programs
for
encouraging
waste
minimization
(
e.
g.,
via
the
development
and
distribution
of
guidances
on
best
practices);
 
Recognize
a
partner's
accomplishments
in
a
formal
manner
(
e.
g.,
by
congratulatory
letter);
 
Determine
progress
toward
established
Agency
goals;
 
Establish
future
Agency
targets;
and
 
Evaluate
Regional
progress
toward
GPRA
goals.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
The
information
on
waste
minimization
efforts
to
be
obtained
under
this
ICR
is
not
collected
by
EPA
or
any
other
federal
agency.
Other
non­
federal
organizations
sponsor
voluntary
programs
that
promote
source
reduction,
recycling,
or
the
purchase
of
recycled
products,
but
do
not
offer
a
4
comprehensive
waste
reduction
program
that
emphasizes
the
cost
savings
and
other
benefits
of
waste
prevention.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
In
compliance
with
the
Paperwork
Reduction
Act
of
1995,
EPA
issued
a
public
notice
in
the
Federal
Register
on
December
20,
2005
(
70
FR
75457).
The
comment
period
ended
on
February
21,
2006.
The
Agency
received
no
comments
to
that
notice.

3(
c)
Consultations
In
evaluating
the
partnership
program
forms,
OSW
staff
conducted
personal
interviews
with
less
than
nine
program
partners
to
discuss
techniques
for
measuring
waste
minimization.
Among
other
things,
EPA
gained
an
understanding
of
the
number
of
likely
participants
in
the
program,
as
well
as
their
potential
burden
under
the
reporting
procedures.
Interviews
were
conducted
with
the
following
eight
partners:

Name
of
Contact
Person
Phone
Number
Company
Name
James
Riner
(
865)
354­
4206
Chase
Scientific
Robert
Romano
(
973)
777­
6900
Comus
International
Kevin
Hildreth
(
732)
727­
2225
Old
Bridge
Chemical
John
Spomar
(
708)
841­
6220
Norco
Cleaners
Felice
Janelle
(
603)
464­
7171
Osram
Sylvania
Michelle
Eaglin
(
225)
242­
5590
Rubicon
Fred
Goodson
(
504)
465­
7609
Shell
Oil
Terry
Grover
(
518)
464­
7435
US
Postal
Service
NE
Area
3(
d)
Effects
of
Less
Frequent
Collection
Each
form
under
the
program
is
submitted
on
a
one­
time
basis.
Submission
of
additional
goals
and
success
stories
are
fully
optional
and
need
not
be
submitted
unless
desired
by
the
partner.
Hence,
EPA
has
minimized
the
frequency
of
information
collection
to
the
greatest
extent
practicable.

3(
e)
General
Guidelines
This
ICR
adheres
to
the
guidelines
stated
in
the
Paperwork
Reduction
Act
of
1995,
OMB's
implementing
regulations,
EPA's
Information
Collection
Review
Handbook,
and
other
applicable
OMB
guidance.

3(
f)
Confidentiality
5
Section
3007(
b)
of
RCRA
and
40
CFR
Part
2,
Subpart
B,
which
defines
EPA's
general
policy
on
public
disclosure
of
information,
contain
provisions
for
confidentiality.
However,
the
Agency
does
not
anticipate
that
businesses
will
assert
a
claim
of
confidentiality
under
the
program.
If
such
a
claim
were
asserted,
EPA
must
and
will
treat
the
information
in
accordance
with
the
regulations
cited
above.
EPA
also
will
assure
that
this
information
collection
complies
with
the
Privacy
Act
of
1974
and
OMB
Circular
108.

3(
g)
Sensitive
Questions
No
questions
of
a
sensitive
nature
are
asked
in
either
the
Enrollment,
or
the
Success
Story.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents
and
SIC
Codes
Following
are
the
North
American
Industrial
Classification
System
(
NAICS)
codes
associated
with
companies
eligible
for
enrollment
in
the
program;
however,
EPA
does
not
expect
that
companies
from
all
industry
sectors
in
the
list
will
necessarily
sign
up
during
the
three­
year
period
covered
by
this
ICR.

NAICS
Title
NAICS
Code
Agriculture,
Forestry,
Fishing,
and
Hunting
111­
115
Mining
211­
213
Construction
233­
235
Manufacturing
311­
339
Wholesale
Trade
421­
422
Retail
Trade
441­
4540
Transportation
and
Warehousing
481­
493
Information
513
4(
b)
Information
Requested
This
section
discusses
the
forms
and
associated
Respondent
activities
under
EPA's
National
Partnership
for
Environmental
Priorities.

Enrollment
Form
Prospective
companies
complete
and
submit
to
EPA
a
one­
time,
one­
page
Enrollment
Form
that
provides
basic
organization
information,
as
well
as
their
waste
minimization
goal(
s)
for
a
6
selected
chemical(
s)
in
their
waste
stream.
Companies
can
use
supplemental
sheets
of
the
Enrollment
Form
if
they
want
to
set
goals
for
additional
chemicals.
They
also
can
update/
modify
their
goals
after
initial
submittal
if
they
so
desire.

(
i)
Data
items
An
Enrollment
Form
consists
of
the
following
elements:

 
General
information:
o
Company
name;
o
Facility
name;
o
Principal
contact;
o
Authorizing
Official;
o
Facility
location;
o
Mailing
address;
o
Email
address;
o
Phone/
Fax
number;
o
EPA
RCRA
ID
Number;
and
o
Date.

 
Information
on
one
or
more
chemical
in
partner
=

s
waste
streams
that
is
targeted
for
reduction,
including:
o
Chemical
name;
and
o
CASRN.

 
Description
of
the
proposed
project,
including:
o
Narrative
description;
o
Amount
of
waste
source
reduction
expected
and
time
frame;
o
Amount
of
waste
recycling
and
time
frame;
o
Identification
of
methods
for
achieving
these
goals
i.
e.
source
reduction
or
recycling
options;
and
o
If
there
is
a
QA/
QC
plan
for
data.

 
Printed
name,
signature,
and
title
of
the
company
official
and
date
of
signature.

(
ii)
Respondent
activities
Each
partner
is
expected
to
conduct
the
following
activities
in
completing
the
Enrollment
Form:

 
Review
the
partnership
brochure
and
related
materials;
and
 
Complete
and
submit
the
Enrollment
Form.
7
A
partner
may,
at
its
discretion,
update
its
waste
minimization
goal(
s)
as
the
project
proceeds.
To
do
so,
the
partner
would
submit
an
Enrollment
Form
with
the
updated
information
to
EPA.

Success
Story
A
partner
is
expected
to
prepare
and
submit
to
EPA
a
Success
Story
when
the
stated
goal(
s)
in
the
Enrollment
Form
is
achieved.
EPA
estimates
that
all
existing
partners
will
submit
at
least
one
of
these
forms
to
receive
their
recognition
for
their
waste
minimization
efforts.
Partners
also
have
the
option
of
submitting
Success
Stories
documenting
accomplishments
related
to
their
established
goals
under
the
program.
Progress
toward
reaching
the
waste
minimization
goal(
s)
will
be
indicated
on
the
website,
which
should
provide
incentive
for
partners
to
show
that
progress
is
being
made,
and
therefore
submit
a
success
story
annually.
EPA
provides
a
template
for
the
partners
to
follow
when
preparing
their
Success
Story.
Success
Stories
describe
the
waste
minimization
efforts,
techniques
used,
problems,
and
other
relevant
issues.
Partners
may
use
supplemental
sheets
if
they
want
to
report
additional
chemicals.
If
partners
have
a
Quality
Assurance/
Quality
Control
Plan
for
any
data
submitted,
they
are
asked
to
attach
it
to
their
Success
Story.

(
i)
Data
items
The
Success
Story
consists
of
the
following
elements:

 
Name
of
company;
 
Name
of
Facility;
 
Principal
Contact;
 
Plant
address;
 
Phone
and
fax
number;
 
Email
address;
 
EPA
RCRA
ID
No;
 
Enrollment
Date
and
Application
date;
 
Organization
background;
 
What
chemical
or
suite
of
chemicals
were
reduced;
 
What
source
reduction
or
recylcing
alternatives
were
considered;
 
What
the
reductions
were
based
on
(
percent
weight,
volume,
mass);
 
What
was
the
driver
for
identifying
this
project
(
i.
e.,
cost
savings,
liability,
etc.);
 
What
activity
was
used
to
realize
the
reductions;
 
What
training
was
required;
 
Description
of
on­
going
and
future
waste
minimization
efforts;
 
How
the
changes
have
reduced
the
company
=

s
impact
on
the
environment;
 
How
much
money
was
spent
to
implement
the
waste
minimization
goal(
s);
 
How
much
was
saved
in
raw
materials,
energy,
water
consumption;
8
 
Problems
faced
in
applying
waste
minimization
goal(
s);
 
Lessons
learned
by
the
company
including
advice
to
help
others
when
considering
waste
minimization
initiatives.

(
ii)
Respondent
activities
A
partner
submitting
the
Success
Story
is
expected
to
perform
the
following
activities:

 
Review
plant
documentation
on
waste
management
and
minimization
efforts
and
accomplishments
during
the
project
period;
and
 
Follow
template
provided
by
EPA;
 
Complete
and
submit
the
form.

5.
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
This
section
discusses
the
forms
and
associated
Agency
activities
under
EPA's
National
Partnership
for
Environmental
Priorities.

Enrollment
Form
 
Mail
out
member
packets
to
potential
participants.
 
Contact
and
share
information
with
interested
partners
on
possible
goals
for
their
organization.
 
Record
and
enter
information
into
a
database
and
post
online.

Success
Story
 
Develop
and
maintain
tracking
system.
 
Record
and
enter
information
into
the
database.
 
Conduct
QA/
QC
on
data
entry.
 
Develop
and
publish
an
annual
summary
of
overall
program
progress.
 
Develop
and
publish
a
summary
of
success
stories
of
highly
successful
programs.

5(
b)
Collection
Methodology
and
Management
In
collecting
and
analyzing
the
information
associated
with
this
ICR,
EPA
uses
a
telephone
system,
personal
computers,
and
database
software.
EPA
ensures
the
accuracy
and
completeness
of
collected
information
by
reviewing
each
submittal.
EPA
enters
the
information
obtained
from
the
three
forms
into
a
database
and
summarizes
the
data.
The
data
is
used
to
identify
prominent
waste
reduction
strategies
and
to
develop
and
publish
an
annual
summary
of
overall
partner
progress
and
9
stories
of
highly
successful
waste
reduction
activities.
EPA
currently
offers
all
forms
in
hard
copy
and
electronically.

5(
c)
Small
Entity
Flexibility
EPA
expects
that
some
of
the
participants
in
the
partnership
program
will
be
small
entities.
EPA
has
designed
its
reporting
forms
to
minimize
respondent
burden
while
obtaining
sufficient
and
accurate
information.
The
partnership
program
was
designed
to
be
highly
flexible.
Organizations
can
choose
the
number
of
facilities
to
include
in
the
program
and
set
their
own
goals
based
on
individual
organization
resources.
In
addition,
the
partnership
is
voluntary.
As
such,
companies
will
participate
in
the
program
only
if
they
expect
it
to
be
cost­
effective
for
them.

5(
d)
Collection
Schedule
Organizations
can
submit
an
Enrollment
Form
to
join
the
partnership
program
at
any
time.
The
Success
Story
is
submitted
when
the
partner
achieves
steps
toward
its
waste
minimization
goal(
s)
or
after
the
final
waste
minimization
goal(
s)
are
achieved.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Hours
EPA
estimates
respondent
hourly
burden
for
all
of
the
information
collection
requirements
covered
in
this
ICR
in
Exhibits
1
and
3.
The
burden
estimates
for
each
activity
presented
in
Exhibit
1
include
the
burden
hours
(
total
and
by
labor
type)
per
respondent,
as
well
as
the
overall
burden
hours
for
all
respondents.

6(
b)
Estimating
Respondent
Costs
Exhibits
1
and
3
estimate
the
annual
costs
to
respondents
based
on
the
cost
of
labor
and
related
costs,
as
discussed
below.

(
1)
Labor
Costs
EPA
estimates
an
average
hourly
respondent
labor
cost
(
including
overhead)
of
$
116
for
legal
staff,
$
84.00
for
managerial
staff,
$
64.00
for
technical
staff,
and
$
36.00
for
clerical
staff.
To
arrive
at
these
estimates,
EPA
consulted
the
May
2004
Occupational
Employment
Statistics
(
OES)
Survey
from
the
Bureau
of
Labor
Statistics,
Department
of
Labor;
this
survey
summarizes
the
unloaded
factor
of
2.3
for
non­
legal
staff
and
3.0
for
legal
staff
to
derive
their
loaded
hourly
rates.
Using
the
burden
hours
discussed
in
Section
6(
a)
and
the
wage
rates
outlined
in
this
section,
Exhibit
1
illustrates
the
labor
costs
associated
with
all
the
information
collection
requirements
covered
in
this
ICR.
10
(
2)
Capital
Costs
Capital
costs
usually
include
any
produced
physical
good
needed
to
provide
the
needed
information,
such
as
machinery,
computers,
and
other
equipment.
EPA
does
not
anticipate
that
respondents
will
incur
capital
costs
in
carrying
out
the
information
collection
requirements
covered
in
this
ICR.

(
3)
Operations
and
Maintenance
(
O&
M)
Costs
O&
M
costs
are
those
costs
associated
with
a
paperwork
requirement
incurred
continually
over
the
life
of
the
ICR.
They
are
defined
by
the
Paperwork
Reduction
Act
of
1995
as
"
the
recurring
dollar
amount
of
cost
associated
with
O&
M
or
purchasing
services."
For
this
ICR,
O&
M
costs
cover
mailing
costs
($
0.42
for
a
letter,
envelope,
and
postage).

6(
c)
Estimating
Agency
Hour
and
Cost
Burden
EPA
estimates
the
Agency
hour
and
cost
burden
associated
with
all
of
the
requirements
covered
in
this
ICR
in
Exhibit
2.
Based
on
the
"
General
Schedule
(
GS)
Salary
Table
2006,"
EPA
estimates
an
average
hourly
labor
rate
of
$
70.16
for
legal
staff
(
GS­
15,
Step
1),
$
54.00
for
managerial
staff
(
GS­
14,
Step
3),
$
39.00
for
technical
staff
(
GS­
11,
Step
10),
and
$
18.00
for
clerical
staff
(
GS­
5,
Step
4).
To
derive
these
hourly
estimates,
EPA
multiplied
the
basic
hourly
rates
by
the
standard
government
overhead
factor
of
1.6.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Hour
and
Cost
Burden
(
1)
Respondent
Universe
Table
1
presents
the
number
of
companies
expected
to
participate
in
the
program
over
the
three­
year
period
of
this
ICR.
EPA
currently
has
73
enrolled
partners.
For
purposes
of
the
ICR's
burden
calculations,
EPA
has
averaged
the
number
of
new
and
existing
partners
over
the
three­
year
period,
and
factored
in
an
apparent
acceleration
in
enrollment
over
the
last
twelve
months,
to
conclude
that
there
will
be,
on
average,
30
new
partners
per
year
for
each
of
the
three
years
of
this
ICR.
We
anticipate
that
this
will
result
in
a
total
enrollment
163
partners
by
the
end
ICR
year
three.
EPA
derived
these
universe
estimates
based
on
consultations
with
less
than
ten
prospective
partners.
(
See
Section
3(
c)
of
this
ICR
for
additional
information
on
the
consultations.)

Table
1
Number
of
Respondents
Expected
to
Participate
in
the
National
Partnership
for
Environmental
Priorities
Program
Over
the
Three­
Year
Period
of
the
ICR
Type
of
Respondent
Year
1
Year
2
Year
3
Average
Existing
(
at
beginning
of
year)
73
103
133
103
11
New
(
during
year)
30
30
30
30
Existing
(
at
end
of
year)
103
133
163
133
In
the
following
paragraphs,
EPA
uses
these
universe
estimates
in
its
respondent
hour
and
cost
burden
calculations.
(
2)
Annual
Respondent
Hour
and
Cost
Burden
Based
on
the
universe
data
presented
in
Table
1,
EPA
estimates
respondent
burden
associated
with
all
of
the
requirements
covered
in
this
ICR
in
Exhibits
1
and
3.
A
discussion
of
the
assumptions
used
in
developing
these
burden
estimates
follows.

(
a)
Enrollment
Form
Organizations
wanting
to
become
partners
of
the
National
Partnership
for
Environmental
Priorities
program
are
required
to
complete
and
submit
to
EPA
an
Enrollment
Form.
EPA
estimates
that,
on
average,
27
new
organizations
wanting
to
become
partners
of
the
program
will
have
to
conduct
this
activity
each
year.

EPA
further
estimates
that
five
percent
of
existing
partners
will
notify
EPA
to
modify
their
waste
minimization
goals
each
year
(
i.
e.,
5%
x
133
=
9
partners
per
year).

(
b)
Success
Story
Partners
will
complete
and
submit
to
EPA
a
Success
Story
once
they
achieve
steps
toward
meeting
their
waste
minimization
goal(
s).
EPA
estimates
that
50
percent
of
all
the
partners
in
the
program
during
the
three­
year
period
of
this
ICR
will
submit
at
least
one
success
story
over
3
years
(
i.
e.,
(
50%
x
133)/
3
=
22)).

6(
e)
Bottom
Line
Hour
and
Cost
Burden
(
1)
Respondent
Tally
Exhibit
3
shows
the
aggregate
annual
hour
and
cost
burden
to
respondents.
As
shown
in
the
exhibit,
EPA
estimates
the
annual
respondent
burden
to
be
642
hours
and
$
41,668.

(
2)
Agency
Tally
As
is
shown
in
Exhibit
2,
the
annual
Agency
hour
and
cost
burden
associated
with
all
the
requirements
covered
in
this
ICR
is
estimated
to
be
191
hours
and
$
7,409.

6(
f)
Reasons
for
Change
in
Burden
12
The
previously
approved
ICR,
Number
2076.01,
estimated
the
annual
hourly
burden
for
respondents
to
be
3,235
and
the
annual
cost
for
respondents
to
be
$
200,633.
This
renewal
estimates
the
annual
hourly
burden
for
respondents
to
be
642
hours
and
the
annual
cost
for
respondents
to
be
$
41,668.
This
is
a
difference
of
2,593
hours
and
$
158,965.
The
reason
for
the
decrease
is
because
in
the
original
ICR
EPA
overestimated
how
many
partners
would
be
enrolled
in
the
program.
EPA
also
overestimated
the
amount
of
time
it
would
take
an
enrollee
to
fill
out
and
submit
the
enrollment
form.
For
this
renewal,
EPA
was
able
to
canvas
partners
(
see
section
3(
c)
Consultations)
for
more
realistic
burden
estimates.
13
Exhibit
1
Estimated
annual
respondent
hour
and
cost
burden
Legal
Managerial
Technical
Clerical
INFORMATION
COLLECTION
ACTIVITY
$
116.00/
Hr
$
84.00/
Hr
$
64.00/
Hr
$
36.00/
Hr
Rev
iew
partnership
package
0.75
1.00
2.00
0.00
3.75
$
299.00
$
0.00
$
0.00
30
113
$
8,970
$
0
$
0
$
8,970
Complete
and
submit
Enrollment
Form
0.00
4.00
4.00
2.00
10.00
$
664.00
$
0.00
$
0.42
30
300
$
19,920
$
0
$
13
$
19,933
Prepare
and
submit
modif
ication
if
desired
0.00
0.25
1.50
0.50
2.25
$
135.00
$
0.00
$
0.42
9
20
$
1,215
$
0
$
4
$
1,219
Subtotal
0.75
5.25
7.50
2.50
16.00
$
1,098.00
0.00
$
0.84
Varies
433
$
30,105
$
0
$
17
$
30,122
Success
Stories
Rev
iew
Project
and
Results
0.00
0.50
1.00
0.00
1.50
$
106.00
$
0.00
$
0.00
22
33
$
2,332
$
0
$
0
$
2,332
Prepare
and
Submit
Success
Story
0.00
1.50
4.00
0.50
6.00
$
400.00
$
0.00
$
0.42
22
132
$
8,800
$
0
$
9
$
8,809
Prepare
and
Submit
Clarif
ications
0.00
0.50
1.00
0.50
2.00
$
124.00
$
0.00
$
0.42
22
44
$
2,728
$
0
$
9
$
2,737
Subtotal
0.00
2.00
5.00
1.00
9.50
$
630.00
$
0.00
$
0.84
22
209
$
13,860
$
0
$
18
$
13,878
TOTAL
Varies
642
$
43,965
$
0
$
35
$
44,000
Number
of
Respondents
/
Activ
ity
Total
Cost/
Year
Respondent
Hours
Labor
Cost
Capital/

Startup
Costs
O&
M
Costs
Total
Hours/

Year
Reporting
and
Recordkeeping
Requirements
Under
EPA's
National
Partnership
for
Environmental
Priorities
Hours
and
Costs
per
Respondent
Total
Hours
and
Costs
Enrollment
Form
Total
Labor
Costs/
Year
Total
Capital
Cost/
Year
Total
O&
M
Costs/
Year
14
Exhibit
2
Estimated
Annual
Agency
Hour
and
Cost
Burden
Legal
Managerial
Technical
Clerical
INFORMATION
COLLECTION
ACTIVITY
$
63.31/
Hr
$
54.00/
Hr
$
39.00/
Hr
$
18.00/
Hr
Mail
out
member
packets
0.00
0.00
0.25
0.00
0.25
$
10.00
$
0.00
$
0.42
30
8
$
300
$
0
$
13
$
313
Share
information
with
interested
partners
0.00
0.25
0.50
0.00
0.75
$
33.00
$
0.00
$
0.00
30
23
$
990
$
0
$
0
$
990
Record/
enter
information
from
forms
0.00
0.00
0.50
0.00
0.50
$
20.00
$
0.00
$
0.00
30
15
$
600
$
0
$
0
$
600
Subtotal
varies
varies
varies
varies
varies
varies
varies
varies
varies
46
$
1,890
$
0
$
13
$
1,903
Record
and
enter
information
into
the
database
0.00
0.00
0.00
0.25
0.25
$
5.00
$
0.00
$
0.00
22
6
$
110
$
0
$
0
$
110
Maintain
tracking
system
0.00
0.00
0.25
0.00
0.25
$
10.00
$
0.00
$
0.00
22
6
$
220
$
0
$
0
$
220
QA/
QC
of
data
0.00
0.50
1.00
0.00
1.50
$
66.00
$
0.00
$
0.00
22
33
$
1,452
$
0
$
0
$
1,452
Develop
summary
of
highly
successful
programs
0.00
0.25
0.25
0.25
0.75
$
28.00
$
0.00
$
0.00
133
100
$
3,724
$
0
$
0
$
3,724
Subtotal
varies
varies
varies
varies
varies
varies
varies
varies
varies
145
$
5,506
$
0
$
0
$
5,506
TOTAL
varies
191
$
7,396
$
0
$
13
$
7,409
Total
Hours
and
Costs
Requirements
Regarding
EPA's
Waste
Minimization
Program
Agency
Hours
and
Costs
Total
Labor
Costs/
Year
Total
Capital
Cost/
Year
Total
O&
M
Costs/
Year
Agency
Hours
Labor
Cost
Capital
Startup
Costs
O&
M
Costs
Number
of
Respondents/

Activity
Total
Hours/

Year
Success
Stories
Enrollment
Form
Total
Cost/
Year
15
Exhibit
3
Total
Annual
Respondent
Hour
and
Cost
Burden
INFORMATION
COLLECTION
ACTIVITY
Total
Hours
Total
Labor
Costs
Total
Capital
Cost
Total
O&
M
Costs
Total
Costs
Enrollment
Form
433
$
30,105
$
0
$
17
$
30,122
Success
Stories
209
$
13,860
$
0
$
18
$
13,878
TOTAL
642
$
43,965
$
0
$
35
$
44,000
Reporting
and
Recordkeeping
Requirements
Under
EPA's
National
Partnership
for
Environmental
Priorities
16
6(
g)
Burden
Statement
Burden
Statement:
The
annual
burden
for
the
enrollment
form
is
estimated
to
average
16
hours
per
response;
the
annual
burden
for
the
success
stories
is
expected
to
average
9
hours
per
response.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
and
48
CFR
chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
Number
EPA­
HQ­
RCRA­
2005­
0016,
which
is
available
for
online
viewing
at
www.
regulations.
gov,
or
in
person
viewing
at
the
RCRA
Docket
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Avenue,
NW,
Washington,
D.
C.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
RCRA
Docket
is
(
202)
566­
0270.
An
electronic
version
of
the
public
docket
is
available
at
www.
regulations.
gov.
This
site
can
be
used
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
When
in
the
system,
select
"
search,"
then
key
in
the
Docket
ID
Number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
D.
C.
20503,
Attention:
Desk
Officer
for
EPA.
Please
include
the
EPA
Docket
ID
Number
EPA­
HQ­
RCRA­
2005­
0016
and
OMB
Control
Number
2050­
0190
in
any
correspondence.
ATTACHMENT
A
ENROLLMENT
FORM
ENROLL
US!

We
Want
to
Be
a
Partner
in
EPA
=

s
National
Partnership
for
Environmental
Priorities
GENERAL
INFORMATION
Name
of
Organization:
Facility
Name:
Principal
Contact:
Title:

Authorizing
Official:
Title:
Address:
City/
State/
Zip:
Phone/
Fax:
Email:
EPA
RCRA
ID
Number:
Date:

PARTNER
AGREEMENT
Our
organization
is
choosing
to
become
a
partner
in
EPA's
National
Partnership
for
Environmental
Priorities.
Our
goal
is
to
reduce
the
quantity
of
one
or
more
Priority
Chemicals
currently
found
in
our
products,
processes,
or
releases
using
techniques
such
as
source
reduction,
recycling,
or
other
materials
management
practices.
In
this
enrollment
application,
we
identify
one
or
more
voluntary
goals
that
we
believe
we
can
achieve
as
partners
in
this
program.
The
voluntary
goal(
s)
provided
below
is
an
initial
estimate
and
may
change
over
time.
We
may
revise
our
goal(
s)
or
withdraw
from
the
program
at
any
time.
If/
when
we
choose
to
revise
our
goals
or
withdraw
from
the
program,
we
will
notify
EPA.

GOAL
#
1.
Chemical
Name:
CASRN:
Narrative
description
of
proposed
project:

How
we
will
measure
success:

1a.
Our
voluntary
source
reduction
goal
for
Chemical
#
1
is
to
reduce
the
amount
of
this
chemical
generated/
used
from
a
baseline
amount
of
pounds
in
(
month/
year)
to
a
reduced
amount
of
pounds
generated/
used
by
(
month/
year).

1b.
To
accomplish
this
goal,
we
will
use
the
following
source
reduction
options
(
check
all
that
apply):
Equipment
or
technology
modifications.
Process
or
procedure
modifications.
Reformulation
or
redesign
of
products.
Substitution
of
less
toxic
raw
materials.
Improvements
in
inventory
control.
Improvements
in
maintenance/
housekeeping
practices.
Other
(
describe):
.

1c.
We
have
a
Quality
Assurance/
Quality
Control
Plan
for
data
(
check
which
applies)
Yes
No
2a.
In
addition
to,
or
in
lieu
of
using
source
reduction
methods,
our
voluntary
recycling
or
recovery
goal
for
Chemical
#
1
is
to
increase
the
recycled
or
recovered
quantity
of
this
chemical
from
a
baseline
amount
of
pounds
in
(
month/
year)
to
an
increased
quantity
of
pounds
by
(
month/
year).

2b.
To
accomplish
this
recycling
or
recovery
goal,
we
will
use
the
following
options
(
check
all
that
apply):
Direct
use/
reuse
in
a
process
to
make
a
product.
Processing
the
waste
to
recover
or
regenerate
a
usable
product.
Using/
reusing
waste
as
a
substitute
for
a
commercial
product.
Other
(
describe):
.

Please
use
supplemental
sheets
for
additional
goals.
Page
of
.
ATTACHMENT
B
SUCCESS
STORY
OUTLINE
National
Partnership
for
Environmental
Priorities
(
NPEP)
Success
Story
Outline
The
outline
provided
below
offers
a
framework
for
making
your
Success
Story
clear
and
understandable
to
the
many
readers
that
visit
the
NPEP
website.
The
outline
makes
recommendations
for
approximate
length,
but
you
can
make
your
Success
Story
as
detailed
as
you
wish.
If
you
have
a
QA/
AC
Plan
for
any
data
you
submit,
would
you
please
attach
it
to
your
Success
Story.
Please
see
the
example
NPEP
Success
Story
(
page
3).
If
you
have
any
questions,
return
to
epa.
gov/
minimize/
achieve.
htm
for
links
to
more
information.

Section
1:
Identifying
Information.
(
As
entered
on
your
enrollment
form.)
Organization:
___________________________
Facility:
Principal
Contact:
Title:
Address:
City/
State/
Zip:
Phone:
Fax:
Email:
EPA
RCRA
ID
No:
Enrollment
Date:
Today's
Date:

Check
one
of
the
following
options:
____
We
have
achieved
one
or
more
of
the
goals
identified
in
our
enrollment
form
and
would
like
to
apply
for
an
Achievement
Award.
____
We
are
not
applying
for
an
Achievement
Award
at
this
time.
However,
we
have
made
important
progress
and
would
like
to
submit
a
Success
Story
to
post
on
the
NPEP
website.

Section
2:
Background.
(
About
100
words.)

 
How
large
is
your
organization?
 
How
long
has
your
organization
been
in
operation?
 
What
do
you
produce,
and
what
is
the
product
used
for?
 
How
would
you
describe
your
customer
base?
 
How
do
you
produce
this
product?
 
How
much
do
you
produce
in
a
year?
 
What
other
environmental
or
partnership
programs
do
you
participate
in?

Section
3:
What
NPEP
partnership
program
goal
did
you
set
and
how
did
you
achieve
it?
(
About
250
words.)
 
What
chemical/
waste(
s)
did
you
choose
to
reduce?
 
Why
did
you
pick
this
chemical/
waste(
s)
to
reduce?
 
What
source
reduction,
recycling,
materials
recovery
and/
or
energy
recovery
goal(
s)
did
you
set?

Section
4:
What
source
reduction,
recycling,
materials
recovery,
and/
or
energy
recovery
alternatives
did
you
consider?
(
About
250
words.)

 
Source
Reduction:

o
Equipment
or
technology
modifications;

o
Reformulation
or
redesign
of
products;

o
Improvements
in
inventory
control;

o
Process
or
procedure
modifications;

o
Substitution
of
less
toxic
raw
materials;

o
Improvements
in
maintenance/
housekeeping
practices;

o
Other
(
please
describe)
o
Recycling/
Recovery:

o
Direct
use/
reuse
in
a
process
to
make
a
product;

o
Processing
the
waste
to
recover
or
regenerate
a
usable
product;

o
Using/
reusing
waste
as
a
substitute
for
a
commercial
product;

o
Other
(
please
describe).
 
What
method
did
you
use
to
achieve
your
goal?
 
What
prior
successes,
if
any,
helped
you
achieve
this
goal?

Section
5:
What
hurdles
did
you
face?
(
About
150
words.)
 
Material
substitution
issues.
 
Product
quality
issues.
 
Process
change
issues.
 
Equipment
issues.
 
Financial
issues.
 
Customer
issues.
 
Senior
management
commitment
and
support
issues.
 
Training
and/
or
departmental
coordination
issues.
 
Other
(
please
describe).

Section
6:
Results.
(
About
250
words.)
 
Describe
and
quantify
any
changes
in
product
content,
energy
use,
and/
or
environmental
releases
that
resulted
from
accomplishing
your
goal.
 
Describe
cost
savings
and/
or
increases,
including
changes
in
capital,
production,
operations
and
maintenance,
raw
material
purchases,
waste
management,
and
worker
health
and
safety
costs.
 
What
was
the
payback
period
for
this
project?
 
Describe
any
changes
in
company
policy,
management
and/
or
worker
involvement,
and/
or
customer
satisfaction
that
resulted
directly
or
indirectly
from
this
achievement.

Section
7:
Lessons
Learned.
(
About
100
words.)
 
What
lessons
learned
from
this
project
would
you
like
to
share
with
others?
 
What
lessons
learned
extend
to
other
operations
or
projects
in
your
organization?

Delivery
Information
U.
S.
Mail
Delivery
Service
U.
S.
EPA
U.
S.
EPA
National
Partnership
for
Environmental
National
Partnership
for
Environmental
Priorities
(
NPEP)
Coordinator
Priorities
(
NPEP)
Coordinator
Waste
Minimization
Branch,
5302W
Waste
Minimization
Branch,
6th
floor
1200
Pennsylvania
Avenue,
NW
2800
Crystal
Drive
Washington,
D.
C.
20460
Arlington,
VA
22202
