CONTINUOUS
RELEASE
REPORTING
REGULATIONS
UNDER
CERCLA
1980
(
RENEWAL)
October
1,
2004
i
TABLE
OF
CONTENTS
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
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1
l(
a)
Title
and
Number
of
the
Information
Collection
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1
l(
b)
Short
Characterization
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1
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
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3
2(
a)
Need
and
Authority
for
the
Collection
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3
2(
b)
Practical
Utility
and
Users
of
the
Data
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3
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
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4
3(
a)
Nonduplication
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4
3(
b)
Public
Notice
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5
3(
c)
Consultations
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5
3(
d)
Effects
of
Less
Frequent
Collection
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6
3(
e)
General
Guidelines
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6
3(
f)
Confidentiality
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6
3(
g)
Sensitive
Questions
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6
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
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6
4(
a)
Respondents
and
SIC
Codes
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6
4(
b)
Information
Requested
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6
(
i)
Data
Items,
Including
Record
keeping
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7
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ii)
Respondent
Activities
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5.
THE
INFORMATION
COLLECTED
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AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
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12
5(
a)
Agency
Activities
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12
5(
b)
Collection
Methodology
and
Management
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12
5(
c)
Small
Entity
Flexibility
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13
5(
d)
Collection
Schedule
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13
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
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14
6(
a)
Estimating
Respondent
Burden
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14
6(
b)
Estimating
Respondent
Costs
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20
6(
c)
Estimating
Agency
Burden
and
Costs
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26
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Cost
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29
6(
e)
Bottom
Line
Burden
Hours
and
Costs
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31
6(
f)
Reasons
for
Change
in
Burden
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31
6(
g)
Burden
Statement
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31
APPENDIX
A
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36
ii
LIST
OF
EXHIBITS
Exhibit
1
Unit
Burden
Hours
per
Respondent
Information
Collection
Activity
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19
Exhibit
2
Burden
Hours
for
a
Typical
Facility
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20
Exhibit
3
Unit
Labor
Cost
per
Respondent
Information
Collection
Activity
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22
Exhibit
4
Annual
Labor
Costs
for
a
Typical
Facility
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23
Exhibit
5
Unit
Operating
and
Maintenance
Costs
per
Respondent
Information
Collection
Activity
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24
Exhibit
6
Operating
and
Maintenance
Costs
for
a
Typical
Facility
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25
Exhibit
7
Unit
Labor
and
Operating
and
Maintenance
Costs
per
Respondent
Information
Collection
Activity
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25
Exhibit
8
Labor
and
Operating
and
Maintenance
Costs
for
a
Typical
Facility
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26
Exhibit
9
Unit
Burden
Hours
and
Costs
Incurred
by
the
Government
per
Information
Collection
Activity
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29
Exhibit
10
Number
of
Facilities
and
Hazardous
Substance
Releases
Already
Affected
by
the
CRRR
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30
Exhibit
12
Annual
Burden
Hours
and
Costs
Incurred
by
Industry
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33
Exhibit
13
Annual
Burden
Hours
and
Costs
Incurred
by
Government
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34
Exhibit
14
Summary
of
Burden
Hours
and
Costs
Incurred
by
Industry
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35
iii
Exhibit
15
Summary
of
Burden
Hours
and
Costs
Incurred
by
Government
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35
1Responsibility
for
information
collection
activities
of
the
CRRR
now
resides
in
the
Office
of
Emergency
Management
(
OEM)
in
the
Office
of
Solid
Waste
and
Emergency
Response
(
OSWER).

1
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
l(
a)
Title
and
Number
of
the
Information
Collection
Continuous
Release
Reporting
Regulations
(
CRRR)
under
CERCLA
1980
(
Renewal)
­
EPA
No.
1445.06.

l(
b)
Short
Characterization
This
information
collection
request
(
ICR)
addresses
the
reporting
and
record
keeping
activities
required
to
comply
with
EPA's
continuous
release
reporting
regulation
(
CRRR;
40
CFR
302.8)
implementing
section
103(
f)(
2)
of
the
Comprehensive
Environmental
Response,
Compensation,
and
Liability
Act
of
1980
(
CERCLA).
The
CRRR,
developed
by
EPA's
Office
of
Emergency
and
Remedial
Response1
in
the
Office
of
Solid
Waste
and
Emergency
Response,
clarifies
the
types
of
releases
that
qualify
for
reporting
under
CERCLA
section
103(
f)(
2)
and
establishes
the
reporting
requirements
applicable
to
qualifying
releases.
This
ICR
renews
the
collection
activity
previously
approved
under
OMB
No.
2050­
0086
and
applies
to
the
period
December
1,
2004
through
November
30,
2007.
Estimates
of
the
burden
placed
on
industry
and
the
government
to
comply
with
the
release
notification
requirements
are
presented
on
an
annual
basis.

CERCLA
section
103(
a)
requires
persons
in
charge
of
a
facility
or
vessel
to
immediately
notify
the
National
Response
Center
(
NRC)
of
any
hazardous
substance
release
that
equals
or
exceeds
its
reportable
quantity
(
RQ)
and
is
not
federally
permitted.
Notification
under
CERCLA
is
intended
to
ensure
that
Federal
authorities
receive
prompt
notification
of
hazardous
substance
releases
for
which
a
timely
response
may
be
necessary
to
protect
public
health
or
welfare
or
the
environment
from
any
adverse
effects
that
may
be
associated
with
the
release.
Section
103(
f)(
2)
of
CERCLA
provides
relief
from
the
per­
occurrence
notification
requirements
of
section
103(
a)
for
hazardous
substance
releases
that
are
"
continuous,"
and
"
stable
in
quantity
and
rate,"
provided
that
such
releases
are
reported
"
annually,
or
at
such
time
as
there
is
any
statistically
significant
increase"
in
the
quantity
of
the
release.
Section
103(
f)(
2)
contemplates
that,
in
the
case
of
certain
"
continuous"
and
"
stable"
releases,
the
notification
objectives
of
CERCLA
can
be
achieved
with
less
frequent
reporting.
The
regulated
community
is
expected
to:


Gather
necessary
release
data,
such
as
the
time,
quantity,
and
source
of
the
release;


Notify
the
facility
manager
of
the
release;


Consult
with
the
environmental
compliance
expert
regarding
the
release;
2That
data
base
is
available
at:
http://
www.
nrc.
uscg.
mil/
incident97­
02.
html.

2

Make
an
initial
report
of
the
release
to
the
NRC;


Submit
an
initial
written
notification
to
the
appropriate
EPA
Regional
Office
for
the
geographical
area
where
the
releasing
facility
or
vessel
is
located;


Provide
follow­
up
notification
within
30
days
of
the
first
anniversary
date
of
the
initial
written
notification;


Make
notifications
to
the
NRC
if
there
is
a
change
in
the
release,
including
a
statistically
significant
increase
in
a
release;


Make
an
annual
evaluation
of
releases
to
determine
if
changes
have
occured
in
the
information
submitted
in
the
initial
written
notification,
the
followup
notification
and/
or
in
a
previous
change
notification
­
if
there
are
no
changes,
submittal
of
a
report
is
not
required.


Keep
all
supporting
documents,
materials,
and
other
information
on
file
for
a
period
of
one
year
to
substantiate
the
reported
normal
range
of
releases,
the
basis
for
stating
that
the
release
is
continuous
and
stable
in
quantity
and
rate,
and
the
other
information
in
the
initial
written
report,
the
followup
report,
and
the
annual
evaluations.

The
continuous
release
final
rule
has
been
in
effect
since
September
24,
1990.
This
ICR
utilizes
historical
data
on
the
number
of
continuous
release
reports
submitted
to
the
Federal
government
to
estimate
the
number
of
burden
hours
attributable
to
the
CRRR.
The
statistics
on
the
number
of
continuous
release
reports
submitted
to
the
Federal
government
are
available
through
the
National
Response
Center's
incident
data
base.
2
In
the
first
year
of
the
three­
year
period
covered
by
this
ICR,
it
is
estimated
the
3,207
facilities
will
be
affected
by
the
CRRR.
Of
the
3,207
facilities
affected
in
the
first
year,
it
is
assumed
that
62
will
be
reporting
continuous
releases
for
the
first
time
and
the
remaining
3,145
will
be
meeting
information
collection
requirements
for
ongoing
releases.
In
the
second
and
third
years,
it
is
estimated
that
67
and
72
additional
facilities,
respectively,
will
generate
reportable
continuous
releases.
When
calculating
the
burdens
and
costs
in
this
ICR
it
has
been
assumed
that
the
typical
facility
participates
in
information
collection
activities
for
each
release.
For
example,
the
typical
facility
will
provide
an
initial
telephone
notification
and
written
report
for
each
of
its
continuous
releases.
In
fact,
it
is
likely
that
many
facility
operators
will
consolidate
collection
activities
for
releases
at
their
facilities
(
e.
g.,
provide
one
telephone
notification
for
several
releases).
Assuming
eight
releases
per
facility
per
year,
and
thus
8
information
collection
activities
per
facility
per
year,
the
total
number
of
continuous
release
information
collection
activities
in
the
first
year
of
the
three­
year
period
covered
by
this
ICR
is
estimated
to
be
25,657
3
(
497
initial
notification
activities
and
25,160
ongoing
notification
activities).
In
the
second
and
third
years
of
the
period
covered
by
this
ICR,
it
is
estimated
that
534
and
574
information
collection
activities,
respectively,
will
take
place.
The
total
estimated
burden
to
respondents
is
approximately
277,862,
284,000
and
290,600
hours
in
years
1,2,
and
3,
respectively.
For
the
regulated
community,
the
estimated
information
collection
activity
costs
(
including
labor
and
O&
M
costs)
are
$
9,879,894,
$
10,094,310
and
$
10,328,892
in
years
1,2,
and
3,
respectively.
The
total
estimated
burden
to
the
government
is
approximately
26,329,
25,190,
and
25,837
hours
in
years
1,2,
and
3,
respectively.
The
estimated
total
cost
to
the
government
is
$
1,067,899,
$
1,021,687,
and
$
1,047,939,
in
years
1,2,
and
3,
respectively.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need
and
Authority
for
the
Collection
The
information
collection
required
in
the
CRRR
(
40
CFR
302.8)
is
fully
authorized
under
CERCLA
section
103(
f)(
2)
and
section
104(
e).
CERCLA
section
103(
f)(
2)
provides
relief
from
the
notification
requirements
of
CERCLA
section
103(
a)
for
hazardous
substance
releases
that
are
"
continuous,"
"
stable
in
quantity
and
rate,"
and
for
which
notification
has
been
given
under
CERCLA
section
103(
a)
"
for
a
period
sufficient
to
establish
the
continuity,
quantity,
and
regularity"
of
the
release.
Further,
CERCLA
section
103(
f)(
2)
requires
that
notification
of
releases
qualified
as
continuous
under
the
CRRR
must
be
provided
"
annually,
or
at
such
time
as
there
is
any
statistically
significant
increase"
in
the
quantity
of
the
release.
The
specific
information
provided
in
the
required
notifications
is
authorized
under
CERCLA
section
104(
e).
CERCLA
section
104(
e)
authorizes
the
collection
of
information,
entry,
and
inspection
and
sampling
activities
for
the
purposes
of
determining
the
need
for
a
response,
or
choosing
or
taking
any
response
action
under
CERCLA.
In
addition,
CERCLA
section
103(
f)(
2)
establishes
a
notification
system
that
documents
information
provided
in
the
respondent
notifications.
The
information
collection
and
management
requirements
of
the
CRRR
are
necessary
to
determine
if
a
response
action
is
needed
to
control
or
mitigate
any
potential
adverse
effects
associated
with
a
reported
hazardous
substance
release.

2(
b)
Practical
Utility
and
Users
of
the
Data
The
information
collected
under
the
CRRR
is
used
to
evaluate
the
acute
and
chronic
effects
of
the
continuous
release
to
determine
if
a
response
action
is
necessary
to
prevent
or
mitigate
any
adverse
effects.
Any
hazardous
substance
release
that
equals
or
exceeds
its
RQ
warrants
a
timely
evaluation
of
its
source,
emission
rate,
and
chemical
form,
the
proximity
of
sensitive
populations
or
ecosystems,
and
the
ambient
conditions,
to
ensure
the
protection
of
public
health
and
welfare
and
the
environment.
Agency
responses
to
continuous
hazardous
substance
release
notifications
may
take
a
number
of
forms
ranging
from
requests
for
more
detailed
information
(
to
allow
for
a
more
detailed
risk
assessment),
to
the
imposition
of
more
stringent
emissions
limitations,
to
removal
and/
or
remedial
actions.
Finally,
the
release
notification
information
is
used
by
State
and
local
government
emergency
planners
to
conduct
4
State
and
local
emergency
response
planning.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
The
hazardous
substance
release
information
requested
under
the
CRRR
in
the
initial
written
and
follow­
up
reports
is
the
minimum
information
necessary
to
properly
evaluate
a
hazardous
substance
release.
EPA
analyzed
possible
areas
of
overlap
with
other
regulations,
concluding
that
there
are
limited
areas
of
overlap
with
reporting
requirements
under
other
statutes
and
provisions.
In
particular,
some
facilities
may
need
to
provide
similar
hazardous
substance
release
information
to
satisfy
reporting
requirements
for
the
Toxic
Release
Inventory
(
TRI)
report
under
SARA
section
313.
The
level
of
duplication,
however,
is
limited
because
of
differences
in
the
list
of
chemicals,
and
the
SIC
and
facility
sizes
affected
by
SARA
section
313.
Sara
section
313
requirements
only
apply
to
facilities
in
certain
SIC
categories
whose
inventory
quantities
exceed
10,000
pounds;
CERCLA
section
103
affects
facilities
in
all
SIC
codes
regardless
of
inventory
amounts.
In
addition,
the
SARA
section
313
list
of
toxic
chemicals
includes
only
about
one­
fourth
of
the
listed
CERCLA
hazardous
substances.
Further,
the
SARA
section
313
list
includes
some
substances
that
are
not
on
the
CERCLA
list
at
all.
See
Exhibit
A­
1
in
Appendix
A
for
the
list
of
facility
SIC
codes
affected
by
SARA
section
313.

To
minimize
any
duplication
in
reporting,
EPA
allows
facilities
that
are
subject
to
the
reporting
requirements
of
both
regulations
to
submit
the
SARA
section
313
report
(
otherwise
known
as
the
TRI
report)
as
a
substitute
for
the
written
reports
required
under
the
CRRR,
provided
that
certain
additional
continuous
release
information
is
included
as
an
addendum
to
the
TRI
report.
If
the
TRI
report
is
submitted
in
lieu
of
the
continuous
release
written
report,
based
on
each
source
release,
the
following
continuous
release
information
must
also
be
included
in
the
TRI
report:
(
1)
the
upper
and
lower
bounds
(
normal
range)
of
the
release
over
a
24­
hour
period
of
each
hazardous
substance;
(
2)
the
frequency
of
the
release
from
each
release
source;
(
3)
a
signed
statement
describing
the
basis
for
asserting
that
the
release
is
continuous
and
stable
in
quantity
and
rate;
(
4)
the
population
density
within
a
one­
mile
radius;
and
(
5)
the
identity
and
location
of
any
sensitive
populations
and
ecosystems
within
a
one­
mile
radius.
These
additions
will
provide
EPA
with
information
that
is
not
available
from
the
TRI
report,
but
is
required
to
properly
evaluate
the
need
for
a
government
response.

Additionally,
continuous
release
reporting
under
CERCLA
section
103(
f)(
2)
eliminates
frequent
and
repetitive
reporting
under
CERCLA
section
103(
a).
If
a
facility
with
continuous
releases
were
to
report
on
a
per­
occurrence
basis
under
section
103(
a),
the
facility
could
be
notifying
the
NRC
daily.
Respondents
with
continuous
releases
may
be
unnecessarily
reporting
under
CERCLA
section
103(
a)
because
they:
(
1)
may
not
be
familiar
with
the
reduced
reporting
option
under
section
103(
f)(
2),
or
(
2)
may
not
realize
that
there
is
a
reduced
burden
associated
with
a
one­
time
initial
telephone
notification
and
submission
of
an
initial
written
report
and
one
5
follow­
up
report
under
the
CRRR.
EPA's
outreach
efforts
to
increase
industry
awareness
are
described
in
Section
5(
b).
As
respondents
become
more
aware
of
the
CRRR
and
the
ability
to
simplify
and
reduce
expenses
associated
with
continuous
release
reporting,
it
is
possible
that
some
reports
could
be
redirected
from
CERCLA
section
103(
a)
(
ERNS)
to
CERCLA
section
103(
f)(
2)
(
CR­
ERNS).

3(
b)
Public
Notice
In
compliance
with
the
Paperwork
Reduction
Act
(
PRA)
(
44
U.
S.
C.
3501
et
seq.),
EPA
has
notified
the
public
through
the
Federal
Register
notice
on
the
renewal
of
this
ICR
(
69
FR
41472,
July
9,
2004).
EPA
received
no
comments
in
response
to
this
notice.

3(
c)
Consultations
EPA
consulted
with
a
number
of
Federal
and
State
government
agencies
in
the
development
of
the
information
collection
activities
described
in
this
ICR.
To
develop
the
CRRR,
EPA
formed
a
Workgroup
to
address
the
comments
received
on
the
Notice
of
Proposed
Rulemaking
(
NPRM)
published
on
April
19,
1988
(
53
FR
12868).
The
Workgroup
consisted
of
representatives
from
various
EPA
program
offices,
the
ten
EPA
Regions,
and
the
NRC.
EPA
Regional
offices
were
responsible
for
the
implementation
of
the
final
rule.
Participation
by
these
parties
in
the
Workgroup
was
sufficient
to
address
and
resolve
all
outstanding
issues.
The
comments
received
on
the
NPRM
are
addressed
in
the
Response
to
Comments
Document
and
in
the
preamble
to
the
final
rule.

EPA
sponsored
several
workshops
throughout
the
country
for
industry
and
Federal,
State,
and
local
government
officials
on
the
release
notification
requirements
under
CERCLA
and
SARA
Title
III,
including
the
requirements
under
the
CRRR.
The
workshops
were
held
to
educate
the
regulated
community
as
well
as
those
Federal
and
State
agencies
required
to
implement
the
regulations.
In
addition,
the
workshops
provided
an
opportunity
for
the
public
to
comment
on
the
implementation
of
the
regulation.
No
workshops
were
conducted
or
planned
during
the
period
covered
by
ICR
1445.05
(
November
2001
through
November
2004).
For
this
renewal,
several
individuals
(
fewer
than
9)
responsible
for
making
notifications
to
the
NRC
and
submitting
written
follow­
up
reports,
were
consulted
regarding
the
burden
this
collection
imposes.
Brief
summaries
of
those
consultations
are
contained
in
Appendix
A
to
this
renewal
supporting
statement.

3(
d)
Effects
of
Less
Frequent
Collection
The
frequency
of
information
collection
established
in
the
CRRR
is
the
minimum
level
necessary
for
proper
evaluation
of
continuous
releases.
If
the
information
collected
under
the
CRRR,
such
as
the
source,
frequency,
and
composition
of
the
release,
the
environmental
media
affected,
and
the
identity
and
location
of
any
sensitive
populations
or
ecosystems,
were
collected
less
frequently
than
stipulated
under
the
CRRR,
the
Federal
government's
ability
to
properly
6
evaluate
the
threat
posed
by
the
release
and
the
need
for
a
response
action
would
be
jeopardized.

3(
e)
General
Guidelines
The
regulations
imposed
by
CERCLA
section
103(
f)(
2)
adhere
fully
to
OMB's
general
guidelines
concerning
the
collection
of
information
and
the
control
of
paperwork
burdens
on
the
public.

3(
f)
Confidentiality
The
regulations
implementing
CRRR
do
not
require
the
submittal
of
any
proprietary,
trade
secret,
or
other
confidential
information.

3(
g)
Sensitive
Questions
The
regulations
implementing
CRRR
do
not
require
the
submission
of
any
sensitive
business
information.
In
addition,
the
information
collection
requested
under
these
regulations
is
in
compliance
with
the
Privacy
Act
of
1974
and
OMB
Circular
A­
108.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents
and
SIC
Codes
This
section
is
not
applicable.
The
usage
and
release
of
hazardous
substances
are
pervasive
throughout
industry.
EPA
expects
a
number
of
different
industrial
categories
to
report
hazardous
substance
releases
under
the
provisions
of
the
CRRR.
No
one
industry
sector
or
group
of
sectors
is
disproportionately
affected
by
the
information
collection
burden.

4(
b)
Information
Requested
(
i)
Data
Items,
Including
Record
keeping
To
ensure
that
government
authorities
receive
timely
and
sufficient
information
to
evaluate
potentially
dangerous
hazardous
substance
releases
reported
under
CERCLA
section
103(
f)(
2),
the
CRRR
requires
seven
types
of
information
collection
activities:

°
An
initial
telephone
call
to
the
NRC;
°
An
initial
written
report
to
the
EPA
Region;
°
A
one­
time
follow­
up
written
report
to
the
EPA
Region
on
or
before
the
first­
year
anniversary
of
the
submission
of
an
initial
written
report;
°
An
annual
evaluation
of
a
release
beginning
the
year
after
the
submission
of
the
one­
time
follow­
up
written
report;
°
Notification
to
the
NRC
and
EPA
Regions
of
a
change
in
the
sources,
composition,
or
3Docket
Number
103(
f)
CR
is
now
SFUND­
1990­
0005
(
edocket
identifier);
however,
none
of
the
original
documents
are
available
electronically
through
edocket.

7
frequency
of
a
release;
°
Notification
to
the
EPA
Region
of
a
change
in
other
information
previously
submitted;
and
°
Immediate
notification
to
the
NRC
of
any
statistically
significant
increase
(
SSI)
in
the
quantity
of
a
release.

The
time
required
by
a
facility
to
complete
the
seven
information
collection
activities
varies
and
is
largely
contingent
on
the
nature
of
the
reported
releases
and
the
facility's
information
collection
procedures.
However,
EPA
estimated
the
average
amount
of
time
that
is
needed
to
perform
these
seven
information
collection
activities
and
the
average
unit
burden
hours.
The
estimates
are
presented
in
section
6(
a).
The
unit
burden
hours
used
in
this
ICR
are
based
upon
estimates
from
the
CRRR
economic
analysis.
The
CRRR
Economic
Impact
is
available
in
rulemaking
Docket
Number
103(
f)
CR
­
4­
8.3
Reporting
continuous
releases
represents
a
reduction
in
burden
for
facilities
that
would
otherwise
report
releases
on
a
per­
occurrence
basis.
EPA
believes
that
the
notification
system
developed
under
the
CRRR
represents
the
minimum
level
of
reporting
necessary
for
the
Federal
On­
Scene
Coordinator
(
OSC)
to
evaluate
whether
a
response
action
is
needed
to
prevent
or
mitigate
any
hazards
to
public
health
and
welfare
and
the
environment.
The
following
paragraphs
briefly
describe
the
purpose
and
timing
of
each
information
collection
activity
and
list
the
data
items
that
comprise
each
notification.

Initial
Telephone
Notification
to
the
NRC
 
The
initial
telephone
call
to
the
NRC
serves
to
notify
government
authorities
of
the
facility's
intent
to
report
a
hazardous
substance
release
under
CERCLA
section
103(
f)(
2).
All
such
releases
must
be
released
in
a
continuous
and
stable
manner.
The
initial
telephone
call,
in
conjunction
with
the
initial
written
report,
fulfills
the
statutory
requirement
that
the
release
be
reported
under
CERCLA
section
103(
a)
for
a
period
sufficient
to
establish
the
continuity,
quantity,
and
regularity
of
the
release.
The
information
provided
in
the
initial
telephone
notification
must
include:

°
The
name
and
location
of
the
facility;
and
°
The
name(
s)
and
identity(
ies)
of
the
hazardous
substance(
s)
being
released.

Initial
Written
Report
and
the
Follow­
up
Written
Report
 
The
initial
written
report
and
the
follow­
up
written
report,
which
are
sent
to
the
EPA
Region,
provide
a
full
description
of
the
release.
The
initial
written
report
and
follow­
up
written
report
serve
as
the
basis
for
a
comprehensive
evaluation
of
the
hazards
posed
by
the
release.
Based
on
this
comprehensive
evaluation,
government
authorities
determine
if
a
response
action
is
necessary
to
prevent
or
mitigate
any
adverse
effects.
The
initial
written
report
must
be
submitted
within
30
days
of
the
initial
telephone
call.
This
30­
day
period
does
not
necessarily
provide
enough
time
to
collect
all
relevant
and
appropriate
data,
but
does
allow
for
an
initial
evaluation
of
the
release.
The
follow­
8
up
written
report,
due
one
year
after
submission
of
the
initial
written
report,
serves
to
verify
the
information
provided
on
the
initial
written
report
(
NOTE:
there
cannot
be
any
form
of
change
in
source,
composition,
or
frequency
of
release
without
going
through
the
process
again).
The
follow­
up
written
report
helps
ensure
that
the
information
used
to
evaluate
the
hazards
posed
by
the
release
is
current
and
provides
accurate
information.

The
data
elements
requested
in
the
initial
written
and
follow­
up
report
are
identical
and
consist
of:

°
The
name
of
the
facility
or
vessel;
the
location,
including
the
longitude
and
latitude;
the
case
number
assigned
by
the
National
Response
Center
or
Environmental
Protection
Agency;
the
Dun
and
Bradstreet
number
of
the
facility
(
if
available);
the
port
of
registration
of
the
vessel
(
if
applicable);
and
the
name
and
telephone
number
of
the
person
in
charge
of
the
facility
or
vessel.
[
40
CFR
302.8(
e)(
1)(
i)]

°
A
signed
statement
that
the
hazardous
substance
release
described
is
continuous
and
stable
in
quantity
and
rate
under
the
definitions
of
40
CFR
302.8(
b)
and
that
all
reported
information
is
accurate
and
current
to
the
best
knowledge
of
the
person
in
charge.
[
40
CFR
302.8(
e)(
1)(
iv)(
H)]

°
The
population
density
within
a
one­
mile
radius
of
the
facility
or
vessel,
described
in
terms
of
the
following
ranges:
0­
50
persons,
51­
100
persons,
101­
500
persons,
501­
1,000
persons,
and
more
than
1,000
persons.
[
40
CFR
302.8(
e)(
1)(
ii)]

°
The
identity
and
location
of
sensitive
populations
and
ecosystems
within
a
one­
mile
radius
of
the
facility
or
vessel
(
e.
g.,
elementary
schools,
hospitals,
retirement
communities,
or
wetlands).
[
40
CFR
302.8(
e)(
1)(
iii)]

In
addition,
facilities
must
provide
the
following
substance­
specific
information
for
each
continuous
release:

°
The
sources
of
the
release,
including
specific
source
information
(
e.
g.,
valves,
pump
seals,
storage
tank
vents,
stacks).
[
40
CFR
302.8(
e)(
1)(
iv)(
C)]

°
The
environmental
medium(
a)
affected
by
the
release:
if
air,
provide
stack
height
or
surface
area
affected;
if
surface
water,
the
name
of
the
surface
water
body;
if
a
stream,
the
stream
order
or
average
flowrate
and
designated
use;
if
a
lake,
the
surface
area
and
average
depth;
if
on
or
under
ground,
the
location
of
public
water
supply
wells
within
two
miles.
[
40
CFR
302.8(
e)(
1)(
iv)(
G)(
1­
4)]

°
The
frequency
of
the
release
and
the
fraction
of
the
release
from
each
release
source
and
the
period
over
which
it
occurs.
[
40
CFR
302.8(
e)(
1)(
iv)(
D)]
9
°
A
brief
statement
describing
the
basis
for
stating
that
the
release
is
continuous
and
stable
in
quantity
and
rate.
[
40
CFR
302.8(
e)(
1)(
iv)(
E)]

°
The
name
and
identity
of
the
hazardous
substance;
and
the
Chemical
Abstracts
Service
Registry
Number
for
the
substance.
If
the
release
is
a
mixture,
the
hazardous
substance
components
of
the
mixture
and
their
approximate
concentrations
and
quantities,
by
weight.
[
40
CFR
302.8(
e)(
1)(
iv)(
A)]

°
The
upper
and
lower
bounds
of
the
normal
range
of
the
release
over
the
previous
year.
[
40
CFR
302.8(
e)(
1)(
iv)(
B)]

°
An
estimate
of
the
total
annual
amount
of
the
hazardous
substance
released
in
the
previous
year
(
in
pounds
or
kilograms).
[
40
CFR
302.8(
e)(
1)(
iv)(
F)]

Annual
Evaluation
of
a
Release
 
Although
a
reporting
facility
is
no
longer
required
to
submit
a
written
report
on
its
continuous
releases
after
submitting
a
one­
time
written
follow­
up
report
verifying
the
information
provided
on
the
initial
written
report
remained
the
same,
the
reporting
facility
must
conduct
and
document
an
annual
assessment
of
its
continuous
releases
beginning
the
year
after
the
submission
of
the
follow­
up
written
report.
The
purpose
of
the
annual
evaluation
is
to
identify
any
changes
that
may
have
occurred
in
the
release
situation
over
the
preceding
year.
The
annual
evaluation
of
a
continuous
release
helps
ensure
that
the
information
used
to
evaluate
the
hazards
posed
by
the
release
is
current
and
accurate
information.

Change
in
the
Source,
Composition,
or
Frequency
of
a
Release
Report
 
If
there
is
a
change
in
the
source,
composition,
or
frequency
of
a
release,
the
release
must
be
reported
and
treated
as
a
new
continuous
release.
An
initial
telephone
notification
and
written
change
report
must
be
provided
as
described
above.
The
person
in
charge
also
must
submit
a
follow­
up
report
within
one
year
of
the
change
report.

Other
Changes
in
Information
 
Facilities
experiencing
a
change
in
a
continuous
release
that
invalidates
information
previously
submitted
on
the
continuous
release
must
notify
the
appropriate
EPA
Region
by
letter
within
30
days
of
the
change.
The
letter
regarding
the
change
in
the
release
should
explicitly
identify
the
new
(
or
changed)
information
and
include
an
explanation
for
the
change.
For
example,
a
facility
must
notify
EPA
if
any
schools,
hospitals,
retirement
homes,
or
other
developments
housing
sensitive
populations
are
open
within
one
mile
of
the
facility.

Statistically
Significant
Increase
Report
 
The
CRRR
defines
a
SSI
as
a
release
of
a
hazardous
substance
that
exceeds
the
upper
bound
of
the
normal
range
of
the
release
as
established
by
the
facility.
The
normal
range
of
a
release
is
defined
by
the
range
of
release
weights
(
in
pounds
or
kilograms)
recorded
during
the
preceding
year
under
normal
operating
conditions
(
that
is,
conditions
that
prevail
during
the
period
establishing
the
predictability
and
regularity
of
the
release).
Therefore,
a
SSI
does
not
include
releases
within
the
reported
normal
10
range
of
release.
An
SSI
release
is
considered
an
episodic
release
because
it
is
a
release
above
the
RQ.
Thus,
SSIs
must
be
immediately
reported
to
the
NRC
by
telephone
pursuant
to
the
notification
requirements
of
CERCLA
section
103(
a).
The
information
collected
by
the
NRC
in
a
SSI
report
includes
the
same
information
supplied
when
reporting
any
other
episodic
release
(
e.
g.,
quantity
of
the
release,
source
of
the
release,
and
a
description
of
any
response
actions
taken).

The
person
in
charge
of
a
facility
with
a
SSI
may
modify
the
previously
established
normal
range
as
an
alternative
to
reporting
multiple
SSIs.
To
modify
the
normal
range
of
the
release
over
a
24­
hour
period
under
normal
operating
procedures,
the
person
in
charge
of
the
facility
must
report
at
least
one
SSI
to
the
NRC
as
an
episodic
release
(
to
facilitate
immediate
evaluation),
and
then
must
submit
a
written
change
report
of
the
release
information
to
the
appropriate
EPA
Region
describing
the
new
normal
range
and
reasons
for
the
change;
thus
treating
the
SSI
as
a
new
release.
Thus,
for
example,
if
a
facility
doubles
its
production
level
thereby
doubling
its
release
level,
the
facility
may
want
to
double
its
reported
normal
range
of
the
continuous
release,
rather
than
reporting
multiple
SSIs.
The
person
in
charge
also
must
submit
a
follow­
up
report
within
one
year
of
the
submission
of
the
change
report
Record
keeping
 
Facilities
may
maintain
a
log
or
some
other
record
of
each
hazardous
substance
release
reported
under
CERCLA
section
103(
f)(
2).
The
information
documented
in
the
record
can
be
used
to
demonstrate
compliance
with
the
provisions
of
the
CRRR,
including
the
requirement
to
demonstrate
the
continuity
and
stability
of
the
release
and
the
requirement
to
conduct
an
annual
evaluation
of
the
release.
Additionally,
facilities
may
find
it
useful
to
document
daily
release
quantities
for
use
in
substantiating
and
modifying
the
normal
range
of
the
release.

(
ii)
Respondent
Activities
To
comply
with
the
provisions
of
the
CRRR,
the
regulated
community
performs
the
following
information
collection
activities:

°
Provides
an
initial
telephone
call
to
the
NRC;
°
Provides
an
initial
written
report
to
the
EPA
Region;
°
Prepares
a
one­
time
follow­
up
written
report
for
the
EPA
Region
on
or
before
the
firstyear
anniversary
of
the
submission
of
an
initial
written
report;
°
Conducts
an
annual
evaluation
of
a
release
beginning
the
year
after
the
submission
of
the
one­
time
follow­
up
written
report;
°
Prepares
change
in
the
sources,
composition,
or
frequency
of
a
release
reports;
°
Prepares
change
in
other
information
reports;
°
Provides
immediate
notifications
of
SSIs;
and
°
Maintains
a
log
or
other
formal
record
to
document
compliance
with
the
CRRR.

Each
of
these
notification
and
record
keeping
activities
is
listed
and
described
in
detail
in
section
4(
b)(
i),
above.
In
addition
to
these
activities,
persons
in
charge
of
a
facility
may
be
required
to
perform
supplemental
collection
activities
in
response
to
the
Federal
government's
11
evaluation
of
the
facility's
continuous
release
reports.
In
situations
where
EPA's
evaluation
of
release
reports
engenders
concern
over
potential
adverse
effects,
EPA
may
require
the
person
in
charge
of
the
facility
in
question
to
submit
the
additional
information
or
clarify
and
refine
information
previously
submitted.
EPA
may
use
this
additional
information
to
better
assess
the
risks
associated
with
the
release.
Finally,
in
response
to
a
release
report
or
additional
information,
EPA
may
conduct
a
site
inspection.
Industry
personnel
accompany
EPA
personnel
during
the
site
inspection
to
address
any
questions,
concerns,
or
information
requests
that
may
arise.
Thus,
the
following
other
activities
are
included
within
the
information
collection
activities
performed
by
the
regulated
community:

°
Provision
of
additional
information;
and
°
Site
inspection.

Estimates
of
the
burden
hours
incurred
by
industry
as
a
result
of
reporting
continuous
releases
were
developed
based
on
estimates
of
the
time
expended
in
providing
a
specific
report
(
e.
g.,
the
initial
telephone
call,
the
initial
written
report,
the
follow­
up
written
report)
as
opposed
to
developing
estimates
for
each
work
element
(
e.
g.,
gathering
information,
reviewing
report
formats,
completing
reports)
involved
in
completing
all
of
the
required
activities.
The
burden
estimates
for
each
information
collection
and
record
keeping
activity
performed
by
the
regulated
community
under
the
CRRR
are
presented
in
Section
6(
a)
of
this
ICR.

5.
THE
INFORMATION
COLLECTED
­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
Each
of
the
notification
reports
submitted
by
industry
is
processed
and
evaluated
by
Federal
authorities.
For
some
continuous
releases
evaluated
under
the
CRRR,
EPA
may
request
additional
(
supplemental)
information
or
clarification
of
information
previously
submitted
by
a
facility.
EPA
may
use
this
information
to
conduct
a
more
in­
depth
risk
assessment
of
the
release.
In
some
extreme
cases,
the
in­
depth
risk
assessment
may
not
allay
EPA's
concerns
and
EPA
may
decide
to
conduct
a
site
inspection
to
review
the
circumstances
associated
with
the
release
firsthand
Additionally,
site
inspections
may
be
conducted
periodically
as
a
compliance
and
enforcement
measure.
Thus,
the
Agency
performs
the
following
other
activities
as
a
result
of
continuous
releases
reported
under
CERCLA
section
103(
f)(
2):


Request
additional
information;
and

Conduct
site
inspections.

Estimates
of
the
burden
hours
incurred
by
the
Federal
government
are
developed
based
on
estimates
of
the
time
expended
in
processing
the
notification
reports
required
under
the
CRRR
(
e.
g.,
the
initial
written
report,
SSI
notification)
or
completing
another
activity
(
e.
g,
additional
12
information,
site
inspection)
as
opposed
to
developing
estimates
for
each
work
element
(
e.
g.,
reviewing
data,
entering
data,
filing,
evaluating
a
release,
storing
evaluation
results)
involved
in
completing
all
of
the
required
activities.
The
burden
estimates
developed
for
each
of
the
processing,
evaluating,
and
other
activities
performed
by
the
Federal
government
are
presented
in
Section
6(
c.)
of
this
ICR.

5(
b)
Collection
Methodology
and
Management
To
facilitate
collection
and
storage
of
information
on
continuous
releases,
EPA
developed
CR­
ERNS.
CR­
ERNS
is
an
information
management
system
that
serves
as
the
depository
for
continuous
release
information
received
by
the
EPA
Regions.
CR­
ERNS
is
designed
to
assist
EPA
Regional
personnel
in
managing
continuous
release
information
and
establishing
priorities
with
respect
to
the
review
and
evaluation
of
continuous
release
reports.
The
reports
submitted
to
the
EPA
Regions
include
the
initial
written
report,
the
follow­
up
report,
and
changes
in
release
reports.
Additionally,
the
NRC
immediately
notifies
the
appropriate
EPA
Region
of
any
SSI
reports.

A
publication
entitled,
"
Reporting
Requirements
for
Continuous
Releases
of
Hazardous
Substances,
A
Guide
for
Facilities
on
Compliance,"
is
available
on
EPA's
internet
at:
http://
www.
epa.
gov/
superfund/
resources/
release/
faciliti.
htm.
The
publication
provides
information
for
respondents
regarding
how
to
comply
with
the
CRRR
and
includes
suggested
reporting
formats
(
pdf
files)
to
assist
respondents.
Feedback
from
industry
representatives
with
experience
in
using
these
files
suggested
that
converting
the
pdf
files
to
an
advanced
pdf
format
that
would
allow
direct
population
of
information
fields
before
printing
would
be
helpful.
EPA
will
work
to
develop
such
improved
formats.

5(
c)
Small
Entity
Flexibility
The
notification
requirements
under
section
103(
a)
of
CERCLA
and
the
reporting
relief
available
under
section
103(
f)(
2)
apply
equally
to
all
firms
regardless
of
size.
There
are
no
special
information
collection
or
record
keeping
requirements
on
small
businesses.
EPA
believes
that
the
notification
system
developed
under
the
CRRR
represents
the
minimum
level
of
reporting
necessary
for
the
Federal
OSC
to
evaluate
whether
a
response
action
is
needed
to
prevent
or
mitigate
any
hazards
to
public
health
and
welfare
and
the
environment.
A
reduction
in
the
reporting
requirements
facing
small
businesses
is
not
possible
without
jeopardizing
the
quality
of
the
information
needed
to
evaluate
the
threat
posed
by
the
release
and
the
need
for
a
Federal
response.

5(
d)
Collection
Schedule
The
facility
must
provide
an
initial
telephone
call
to
the
NRC
as
soon
as
the
person
in
charge
has
knowledge
of
a
hazardous
substance
release
that
equals
or
exceeds
its
RQ.
The
caller
must
decide
whether
to
report
the
release
under
CERCLA
section
103(
a)
(
i.
e.,
as
an
episodic
13
release)
or
CERCLA
section
103(
f)(
2)
(
i.
e.,
as
a
continuous
release).
The
reporting
and
record
keeping
activities
associated
with
reporting
an
episodic
release
under
CERCLA
section
103(
a)
are
presented
in
EPA
ICR
No.
1049.10.
If
the
caller
reports
a
continuous
release,
the
initial
written
report
required
by
CERCLA
section
103(
f)(
2)
must
be
provided
within
30
days
of
the
initial
telephone
call.
In
the
second
year
of
reporting,
the
facility
must
submit
a
written
follow­
up
report
to
the
EPA
Region
within
30
days
of
the
anniversary
date
of
submission
of
the
initial
written
report.
This
report
is
sometimes
called
the
First
Anniversary
Report.
Thereafter,
the
reporting
facility
is
responsible
for
reevaluating
the
release
annually,
but
no
reports
are
required
unless
there
is
a
change
in
the
sources
or
composition
of
a
release,
a
change
in
release
information
previously
submitted,
or
an
SSI
in
the
release.

SSIs
in
a
release
are
considered
to
be
episodic
releases
and
must
be
reported
as
soon
as
the
person
in
charge
is
aware
that
an
SSI
has
occurred.
If
there
is
a
change
in
the
information
submitted
in
the
initial
written
or
follow­
up
report,
other
than
a
change
in
sources,
composition,
or
frequency
of
the
release,
the
person
in
charge
must
submit
a
letter
detailing
the
change
to
the
EPA
Region
within
30
days
of
determining
that
a
change
has
occurred.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
To
report
a
continuous
release,
the
regulated
community
performs
the
following
activities
(
outlined
in
Section
4(
b)
of
this
ICR):
(
1)
provides
an
initial
telephone
notification
to
the
NRC;
(
2)
prepares
an
initial
written
report
for
the
EPA
Region;
(
3)
prepares
follow­
up
written
report
for
the
EPA
Region
on
the
first­
year
anniversary
of
the
submission
of
the
initial
written
report;
(
4)
conducts
an
annual
evaluation
of
the
release
beginning
the
year
after
the
submission
of
the
onetime
follow­
up
written
report;
(
5)
reports
a
change
in
the
sources,
composition,
or
frequency
of
the
release;
(
6)
reports
a
change
in
other
information;
(
7)
reports
SSIs
in
the
release;
(
8)
complies
with
other
activities;
and
(
9)
keeps
records
on
the
release,
including
documentation
of
the
annual
evaluation.
Activities
(
5),
(
6),
(
7),
and
(
8)
are
conditional
activities
and
are
necessary
for
only
a
small
fraction
of
all
the
continuous
releases
reported
each
year.
For
example,
SSIs
are
defined
in
the
CRRR
as
hazardous
substance
releases
whose
quantity
exceeds
the
upper
bound
of
the
normal
range,
where
the
normal
range
includes
all
releases
of
the
hazardous
substance
reported
or
occurring
during
the
previous
year.
Thus,
only
a
small
fraction
of
facilities
experience
SSIs
in
their
continuous
releases
in
a
given
year.

When
calculating
the
burden
and
costs
in
this
ICR
it
is
assumed
that
the
typical
facility
participates
in
all
the
necessary
information
collection
activities
for
each
release.
For
example,
the
typical
facility
will
provide
an
initial
telephone
notification
and
written
report
for
each
of
its
continuous
releases.
In
fact,
it
is
likely
that
many
facility
operators
will
consolidate
collection
activities
for
releases
at
their
facility
(
e.
g.,
provide
one
telephone
notification
for
several
releases).
14
The
estimated
burden
hours
for
each
of
the
activities
listed
in
the
paragraph
above
are
presented
in
Exhibit
1.
The
burden
estimates
are
taken
from
the
CRRR
economic
impact
analysis
and
are
based
on
CERCLA
reporting
experience,
SARA
section
313
reporting
experience,
and
professional
judgment.
A
description
of
the
basis
for
each
burden
estimate,
as
well
as
the
percentage
of
continuous
releases
for
which
the
burden
is
expected
to
be
incurred,
is
provided
in
the
remainder
of
this
section.

Providing
an
Initial
Telephone
Notification
to
the
NRC
 
In
providing
the
initial
telephone
notification,
facilities
incur
a
one­
time,
first­
year
burden
of
notifying
the
NRC
that
a
hazardous
substance
release
is
reported
under
CERCLA
section
103(
f)(
2).
Providing
the
required
information
by
telephone
to
the
NRC
is
estimated
to
require
15
minutes
(
0.25
hours)
of
management
time.
Prior
to
the
telephone
call,
however,
the
facility
must
determine
if
the
release
is
continuous
and
stable
in
quantity
and
rate
as
defined
in
the
CRRR.
This
determination
is
estimated
to
require
45
minutes
(
0.75
hours)
of
management
time
and
two
hours
of
technical
time.
Forty­
five
minutes
(
0.75
hours)
of
management
time
and
two
hours
of
technical
time
should
be
sufficient
to
determine
if
a
release
is
continuous
because
facilities
likely
to
be
affected
by
the
CRRR
should
be
familiar
with
the
reporting
requirements
of
CERCLA
section
103.
In
total,
the
burden
associated
with
the
initial
telephone
call
is
three
hours.

Preparing
an
Initial
Written
Report
 
The
burden
associated
with
providing
the
initial
written
report
is
also
a
one­
time,
first­
year
cost.
Much
of
the
information
required
for
the
initial
written
report
(
e.
g.,
facility
identification,
hazardous
substance
identification,
frequency
and
source
of
the
release)
is
readily
available
to
the
facility.
Information
such
as
the
composition
of
the
release
and
the
environmental
media
affected,
however,
may
require
more
extensive
consideration
and
analysis.
In
addition,
some
time
is
needed
to
organize
and
format
the
required
information
into
a
report
suitable
for
submission
to
the
government.
It
is
assumed
that
many
facilities
will
use
EPA's
prepared
report
format
to
minimize
report
organization
and
formatting
efforts.
Reporting
Requirements
and
sample
forms
are
available
in
pdf
format
on
EPA's
internet:
http://
www.
epa.
gov/
superfund/
resources/
release/
faciliti.
htm.
Preparation
of
the
initial
written
report
that
uses
EPA's
prepared
report
format
is
estimated
to
require
three
hours
of
managerial
time,
three
hours
of
technical
time,
and
one
hour
of
clerical
time.
To
account
for
the
burden
experienced
by
the
facilities
that
do
not
use
EPA's
prepared
report
format,
EPA
has
increased
the
technical
burden
to
four
hours.
The
costs
of
photocopying
and
mailing
this
report
and
all
other
reports
to
the
appropriate
EPA
Region
are
computed
in
Section
6(
b).
Preparation
of
the
initial
written
report
is
estimated
to
require
three
hours
of
managerial
time
(
including
one­
hour
of
legal
review),
four
hours
of
technical
time,
and
one
hour
of
clerical
time.
Thus,
the
total
burden
associated
with
the
initial
written
report
is
eight
hours.

Preparing
a
Follow­
up
Written
Report
 
Within
one
year
of
submitting
the
initial
written
report,
facilities
must
submit
a
one­
time
follow­
up
written
report
to
the
appropriate
EPA
Region.
The
follow­
up
report
requires
the
same
information
as
the
initial
written
report
but
serves
to
confirm,
update,
and
refine
the
information
provided
in
the
initial
report
based
on
release
data
from
the
previous
operating
year.
Because
some
of
the
technical
information
gathered
for
15
preparation
of
the
initial
written
report,
such
as
the
source
of
the
release
and
specific
information
describing
the
environmental
media
affected,
remains
unchanged,
preparation
of
the
follow­
up
report
requires
less
technical
time
than
preparation
of
the
initial
written
report.
EPA
estimates
that
preparation
of
the
follow­
up
report
requires
three
hours
of
managerial
time,
one
hour
of
technical
time,
and
one
hour
of
clerical
time.
In
total,
the
burden
associated
with
the
follow­
up
written
report
is
five
hours.
The
burden
associated
with
the
follow­
up
written
report
is
incurred
in
the
second
year
of
reporting.

Conducting
an
Annual
Evaluation
of
the
Release
 
Although
the
written
follow­
up
report
is
prepared
and
submitted
only
once,
facilities
are
required
to
conduct
and
document
an
annual
evaluation
of
each
hazardous
substance
release
reported
under
section
103(
f)(
2)
beginning
the
year
after
submitting
the
follow­
up
written
report.
This
annual
evaluation
is
comparable
to
the
review
and
information
collection
necessary
for
preparation
of
the
follow­
up
report.
The
burden
associated
with
the
annual
evaluation,
therefore,
is
assumed
to
be
the
same
as
the
burden
of
preparing
the
written
follow­
up
report
(
five
hours).
The
burden
associated
with
the
annual
evaluation
is
incurred
in
the
third
and
all
subsequent
years.

Reporting
a
Change
in
the
Sources,
Composition,
or
Frequency
of
the
Release
 
When
a
facility
experiences
a
change
in
the
sources,
composition,
or
frequency
of
a
release,
the
release
is
considered
a
new
release
because
the
associated
hazard
may
have
changed
significantly.
Changes
in
the
sources,
composition,
or
frequency
of
a
release
are
expected
to
result
only
from
significant
changes
in
the
production
process,
such
as
the
installation
of
new
equipment
or
a
change
in
the
chemical
nature
of
the
process.
While
such
significant
changes
are
expected
over
the
long­
term,
the
likelihood
of
such
a
change
occurring
in
a
particular
year
is
small.
EPA
estimates
that
the
number
of
already
reported
continuous
releases
that
experience
a
change
in
sources,
composition,
or
frequency
is
equal
to
5
percent
of
the
total
number
of
hazardous
substance
releases
being
reported
under
the
CRRR
in
any
given
year.

Facilities
experiencing
a
change
in
the
sources,
composition,
or
frequency
of
a
continuous
release
must
complete
the
initial
notification
process
for
the
release
(
i.
e.,
an
initial
telephone
call
to
the
NRC
and
an
initial
written
report
and
follow­
up
report
to
the
EPA
Region).
For
facilities
experiencing
a
change
in
the
sources,
composition,
or
frequency
of
a
continuous
release,
much
of
the
information
from
the
previous
initial
written
report
(
e.
g.,
facility
identifiers,
the
media
affected)
should
not
have
changed.
It
is
assumed
that
the
technical
time
required
to
evaluate
the
release,
determine
whether
it
is
stable
in
quantity
and
rate,
and
accurately
document
the
composition
of
the
release
and
the
environmental
media
affected
would
take
four
hours.
The
number
of
management
and
clerical
hours
required
to
report
a
new
continuous
release
are
assumed
to
be
four
hours
and
one
hour
respectively.
Thus,
the
total
burden
associated
with
reporting
a
change
in
the
sources,
composition,
or
frequency
of
a
continuous
release
is
nine
hours.

Reporting
Other
Changes
in
Information
 
For
changes
other
than
a
change
in
the
sources,
composition,
or
frequency
of
a
release,
the
person
in
charge
must
notify
the
EPA
Region
16
by
letter
that
the
information
previously
submitted
in
support
of
a
continuous
release
notification
is
no
longer
valid.
For
example,
the
population
density
in
the
vicinity
of
the
facility
would
be
reported
by
submitting
a
letter
detailing
the
change
and
its
cause.
Such
changes
in
information
previously
submitted
are
likely
to
occur
over
an
extended
period
of
time,
but
are
much
less
likely
to
occur
every
year.
EPA
estimates
that,
on
an
annual
basis,
approximately
10
percent
of
the
releases
reported
under
CERCLA
section
103(
f)(
2)
will
experience
a
change
that
requires
submission
of
a
letter
to
the
EPA
Region.
Gathering
and
reporting
the
change
in
the
release
by
a
letter
to
the
EPA
Region
is
estimated
to
require
one
hour
of
managerial
time,
one
hour
of
technical
time,
and
one­
half
hour
of
clerical
time
for
a
total
burden
of
2
and
one­
half
hours.

Reporting
a
Statistically
Significant
Increase
in
the
Release
 
As
soon
as
the
person
in
charge
of
a
facility
has
knowledge
that
the
quantity
of
a
continuous
release
being
reported
under
CERCLA
section
103(
f)(
2)
exceeds
the
upper
bound
of
its
previously
established
normal
range
of
release
weights,
the
person
in
charge
must
notify
the
NRC.
SSIs
are
episodic
release
events
because
the
release
has
not
been
previously
reported
or
evaluated.
To
avoid
underestimating
the
burden,
this
ICR
includes
the
burden
for
reporting
an
SSI,
even
though
the
burden
may
be
captured
in
the
ICR
for
episodic
releases
(
EPA
1409.10).
The
estimated
burden
of
reporting
an
SSI
is
based
on
interviews
with
chemical
industry
personnel
and
the
burden
associated
with
reporting
similar
episodic
releases
under
CERCLA
section
103(
a).
EPA
estimates
that
reporting
of
an
SSI
requires
one
hour
of
managerial
time
and
one
hour
of
technical
time
for
a
total
burden
of
two
hours.
The
technical
time
consists
of
determining
if
the
release
is
reportable,
briefing
management,
and
collecting
the
information
required
for
NRC
reporting.
The
managerial
time
includes
alerting
appropriate
personnel
and
transmitting
the
information
required
in
the
telephone
call.

Because
SSIs
are
defined
as
releases
that
exceed
the
normal
range,
and
the
normal
range
is
defined
to
include
all
release
quantities
recorded
during
the
previous
operating
year,
EPA
estimates
that
no
more
than
5
percent
of
the
hazardous
substance
releases
reported
under
the
CRRR
will
experience
an
SSI
in
a
given
year.

Other
Activities
 
In
response
to
the
government's
processing
and
evaluating
the
initial
and
follow­
up
reports,
persons
in
charge
of
facilities
may
be
required
to:
(
1)
provide
additional
information
or
clarify
information
previously
submitted;
and
(
2)
accompany
EPA
personnel
during
a
site
inspection.

(
1)
Providing
Additional
Information
 
For
some
percentage
of
the
continuous
releases
reported
under
the
CRRR,
the
information
provided
in
the
initial
and/
or
follow­
up
reports
will
be
incomplete,
incorrect,
or
worrisome,
prompting
EPA
to
request
additional
information
regarding
the
nature
and
extent
of
the
release.
For
example,
EPA
may
seek
additional
information
concerning
release
activity
in
order
to
better
assess
the
risk
posed
by
the
release.
EPA
estimates
that
approximately
30
percent
of
the
initial/
follow­
up
reports
could
require
submission
of
additional
information
or
some
level
of
interaction
with
EPA
in
the
first
and
second
years
of
reporting.
Beginning
in
the
third
year
of
reporting,
requests
for
additional
information
and
further
17
clarification
of
release
information
are
assumed
to
be
necessary
only
for
newly
reported
releases.
However,
this
analysis
conservatively
assumes
that
the
percentage
of
reportable
releases
for
which
additional
information
is
necessary
will
remain
at
30
percent
for
all
years
of
reporting.
For
each
hazardous
substance
report
that
requires
additional
communication
with
EPA,
industry
is
estimated
to
expend
four
hours
of
managerial
time.

(
2)
Facilitating
a
Site
Inspection
 
In
extreme
cases,
the
preliminary
risk
assessment
of
a
release
will
indicate
the
need
for
a
site
inspection,
allowing
EPA
to
directly
assess
and
evaluate
the
circumstances
of
a
release
and
the
population
and
environment
potentially
affected
by
the
release.
In
addition,
site
inspections
are
conducted
periodically
as
a
compliance
and
enforcement
measure.
Site
inspections
are
estimated
to
be
necessary
for
no
more
that
one
percent
of
the
reported
continuous
releases.
EPA
estimates
that
facility
participation
in
a
site
inspection
requires
four
hours
of
managerial
time
and
four
hours
of
technical
time
for
a
total
burden
of
eight
hours.

Record
keeping
 
EPA
assumes
many
facilities
maintain
a
log
or
some
other
record
of
each
hazardous
substance
release
reported
under
the
CRRR.
Facilities
may
find
it
useful
to
collect
and
record
the
following
information
for
use
in
demonstrating
compliance
with
the
provisions
of
CERCLA
section
103(
f)(
2):
(
1)
estimates
of
daily
release
quantities
to
demonstrate
the
continuity
and
stability
of
the
release,
and
to
establish
and
modify
the
normal
range
of
the
release;
(
2)
documentation
of
the
methodology
and
calculations
used
in
estimating
required
information;
and
(
3)
documentation
of
the
annual
assessment
required
each
year
subsequent
to
submission
of
the
follow­
up
written
report.
Much
of
the
time
necessary
to
gather
these
records
has
already
been
attributed
to
the
preparation
of
the
initial
and
follow­
up
reports,
however,
it
is
estimated
that
an
additional
four
hours
of
technical
time
is
necessary
for
keeping
records
on
each
hazardous
substance
release
reported
under
the
CRRR.
18
Exhibit
1
Unit
Burden
Hours
per
Respondent
Information
Collection
Activity
Collection
Activity
When
Collection
Activity
is
Performed
Percentage
of
Continuous
Releases
that
Will
Require
a
Collection
Activity
Unit
Burden
Hours
Mgt
Tech
Clerical
Total
Providing
an
Initial
Telephone
Notification
When
first
reporting
a
release
100%
of
new
releases
1.0
2.0
0.0
3.0
Preparing
an
Initial
Written
Report
Within
30
days
of
an
initial
telephone
notification
100%
of
new
releases
3.0
4.0
1.0
8.0
Preparing
a
Follow­
up
Written
Report
A
year
after
the
submission
of
an
initial
written
report
100%
of
all
second
year
releases
3.0
1.0
1.0
5.0
Conducting
an
Annual
Evaluation
of
a
Release
Each
year
beginning
the
year
after
the
submission
of
a
written
follow­
up
report
100%
of
all
third
year
and
subsequent
year
releases
3.0
1.0
1.0
5.0
Reporting
a
Change
in
the
Sources,
Composition,
or
Frequency
of
a
Release
When
the
sources,
composition,
or
frequency
of
a
release
changes
5%
each
year
of
all
new
and
current
releases
4.0
4.0
1.0
9.0
Reporting
Other
Changes
in
Information
Changes
in
other
information
10%
each
year
of
all
new
and
current
releases
1.0
1.0
0.5
2.5
Reporting
an
SSI
in
a
Release
Immediately
after
an
SSI
event
is
noticed
5%
each
year
of
all
new
and
current
releases
1.0
1.0
0.0
2.0
Other
Activities
 
Providing
Additional
Information
Upon
EPA
request
30%
each
year
of
all
new
and
current
releases
4.0
0.0
0.0
4.0
Other
Activities
 
Facilitating
a
Site
Inspection
Upon
EPA
request
1%
each
year
of
all
new
and
current
releases
4.0
4.0
0.0
8.0
Record
keeping
Each
year
of
a
release
100%
of
all
new
and
current
releases
0.0
4.0
0.0
4.0
The
estimated
annual
burden
hours
incurred
by
a
"
typical"
facility
are
presented
in
Exhibit
2.
A
typical
respondent
is
assumed
to
report
eight
continuous
hazardous
substance
releases
in
year
one
and
to
experience
a
change
in
one
release
in
the
second
and
third
years
of
reporting
(
e.
g.,
the
frequency
of
the
release
increases
from
three
to
five
times
a
week,
causing
a
modification
in
the
estimated
annual
release
amount).
No
other
conditional
activities
(
e.
g.,
SSI
reporting
and
facilitating
a
site
inspection)
are
assumed
to
be
required
of
the
typical
respondent;
the
inclusion
of
19
burden
estimates
associated
with
any
additional
conditional
activities
may
result
in
a
significant
overestimation
of
the
burden
incurred
by
a
typical
facility.

Exhibit
2
Burden
Hours
for
a
Typical
Facility*

Collection
Activity
First
Year
Burden
Hours
Second
Year
Burden
Hours
Third
Year
Burden
Hours
Mgt
Tec
h
Clerical
Total
Mgt
Tec
h
Clerical
Total
Mgt
Tech
Clerical
Total
Providing
an
Initial
Telephone
Notification
8.0
16.0
0.0
24.0
NA
NA
NA
NA
NA
NA
NA
NA
Preparing
an
Initial
Written
Report
24.0
32.0
8.0
64.0
NA
NA
NA
NA
NA
NA
NA
NA
Preparing
a
Follow
 
up
Written
Report
NA
NA
NA
NA
24.0
8.0
8.0
40.0
NA
NA
NA
NA
Conducting
an
Annual
Evaluation
of
a
Release
NA
NA
NA
NA
NA
NA
NA
NA
24.0
8.0
8.0
40.0
Reporting
Other
Changes
in
Information
NA
NA
NA
NA
1.0
1.0
0.5
2.5
1.0
1.0
0.5
2.5
Record
keeping
0.0
32.0
0.0
32.0
0.0
32.0
0.0
32.0
0.0
32.0
0.0
32.0
Total
Burden
Hours
for
a
Typical
Facility
32.0
80.0
8.0
120.0
25.0
41.0
8.5
74.5
25.0
41.0
8.5
74.5
*
A
"
typical"
respondent
is
assumed
to
report
eight
continuous
hazardous
substance
releases
in
year
one
and
to
experience
a
change
in
one
release
in
the
second
and
third
years
(
e.
g.,
the
frequency
of
the
release
per
week
changes
each
year,
causing
a
modification
in
the
estimated
annual
release
amount).
No
other
conditional
activities
are
assumed
to
be
required
of
the
typical
respondent.

NA
=
Not
Applicable
6(
b)
Estimating
Respondent
Costs
Labor
Costs
The
estimated
cost
to
complete
various
continuous
release
reports
required
under
the
CRRR
is
a
function
of
the
time
expended
by
industry
personnel
(
i.
e.,
the
burden
estimates
presented
in
section
6(
a)),
and
the
hourly
wage
rates
for
the
appropriate
categories
of
labor.
The
hourly
wage
rates
used
for
industry
in
this
ICR
are
from
December
2003
and
were
obtained
from
4
Bureau
of
Labor
Statistics'
news
release
dated,
February
26,
2004,
entitled
"
Employer
Costs
for
Employer
Compensation
­
December
2003"
listed
hourly
compensation
(
wages
and
salaries
plus
fringe
benefits)
rates
for
civilian
managerial,
technical,
and
clerical
workers.
Therefore,
the
wage
rates
used
in
this
ICR
include
salaries,
fringe
benefits,
overhead
costs
and
general
and
administrative
costs
as
of
December
2003.

20
the
Bureau
of
Labor
Statistics.
4
For
purposes
of
this
analysis,
EPA
estimates
an
average
hourly
respondent
labor
cost
of
$
44.76
for
managerial
staff,
$
30.52
for
technical
staff,
and
$
19.50
for
clerical
staff.

These
rates
reflect
employer
cost
for
employee
compensation
in
the
United
States
as
of
December
2003
and
include
both
employer
costs
for
legally
required
benefits
(
e.
g.,
social
security,
worker's
compensation,
and
unemployment
insurance),
other
important
fringe
benefit
categories
(
e.
g.,
insurance,
paid
leave,
retirement,
and
savings),
and
overhead
and
general
and
administrative
costs.
Costs
associated
with
the
burden
hours
presented
in
Section
6(
a)
of
this
ICR
are
shown
in
Exhibit
3.

Exhibit
3
presents
the
unit
costs
to
industry
of
performing
the
notification,
record
keeping,
and
other
activities
that
may
be
required
in
reporting
a
continuous
release.
The
unit
cost
of
each
collection
activity
is
calculated
by
multiplying
the
annual
burden
hour
estimates
in
Exhibit
2
by
the
hourly
wage
rate
for
the
appropriate
labor
category
(
listed
above).
Exhibit
4
presents
the
annual
labor
cost
estimated
to
be
incurred
by
a
typical
facility.
(
The
reporting
pattern
assumed
for
a
typical
facility
is
discussed
in
Section
6(
a)
above.)
21
Exhibit
3
Unit
Labor
Cost
per
Respondent
Information
Collection
Activity
Collection
Activity
Burden
Hours
Unit
Labor
Cost
Managerial
$
44.76/
hr
Technical
$
30.52/
hr
Clerical
$
19.50/
hr
Providing
an
Initial
Telephone
Notification
1.0
2.0
0.0
$
105.80
Preparing
an
Initial
Written
Report
3.0
4.0
1.0
$
275.86
Preparing
a
Follow­
up
Written
Report
3.0
1.0
1.0
$
184.30
Conducting
an
Annual
Evaluation
of
a
Release
3.0
1.0
1.0
$
184.30
Reporting
a
Change
in
the
Sources,
Composition,
or
Frequency
of
a
Release
4.0
4.0
1.0
$
320.62
Reporting
Other
Changes
in
Information
1.0
1.0
0.5
$
85.03
Reporting
an
SSI
in
a
Release
1.0
1.0
0.0
$
75.28
Other
Activities
 
Providing
Additional
Information
4.0
0.0
0.0
$
179.04
Other
Activities
 
Facilitating
a
Site
Inspection
4.0
4.0
0.0
$
301.12
Record
keeping
0.0
4.0
0.0
$
122.08
22
Exhibit
4
Annual
Labor
Costs
for
a
Typical
Facility*

Collection
Activity
Annual
Burden
Hours
Annual
Labor
Costs
Managerial
$
44.76hr
Technica
l
$
30.52/
hr
Clerical
$
19.50/
hr
First
Year
Second
Year
Third
Year
Providing
an
Initial
Telephone
Notification
8.0
16.0
0.0
$
846.40
NA
NA
Preparing
an
Initial
Written
Report
24.0
32.0
8.0
$
2,206.88
NA
NA
Preparing
a
Follow­
up
Written
Report
24.0
8.0
8.0
NA
$
1,474.40
NA
Conducting
an
Annual
Evaluation
of
a
Release
24.0
8.0
8.0
NA
NA
$
1,474.40
Reporting
Other
Changes
in
Information
1.0
1.0
0.5
NA
$
85.03
$
85.03
Record
keeping
0.0
32.0
0.0
$
976.64
$
976.64
$
976.64
Total
Labor
Costs
for
a
Typical
Facility
$
4,029.92
$
2,536.07
$
2,536.07
*
A
"
typical"
respondent
is
assumed
to
report
eight
continuous
hazardous
substance
releases
in
year
one
and
to
experience
a
change
in
one
release
in
the
second
and
third
years
(
e.
g.,
the
frequency
of
the
release
per
week
changes
each
year,
causing
a
modification
in
the
estimated
annual
release
amount).
No
other
conditional
activities
are
assumed
to
be
required
of
the
typical
respondent.

NA
=
Not
Applicable
Annual
Capital
and
Operating
and
Maintenance
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
of
the
CRRR.

Operating
and
Maintenance
(
O&
M)
costs
are
those
costs
associated
with
a
paperwork
requirement
incurred
continually
over
the
life
of
the
ICR.
They
are
defined
by
the
PRA
as
"
the
recurring
dollar
amount
of
cost
associated
with
O&
M
or
purchasing
services."
The
O&
M
costs
that
are
incurred
by
industries
are
shown
in
Exhibit
5.
For
this
ICR,
O&
M
costs
cover
photocopying
of
report
templates
to
be
filled
out
for
each
release
source
(
25
cents
per
page)
and
postage
and
an
envelope
for
reports
sent
to
the
Agency.
There
are
no
O&
M
costs
associated
with
providing
the
initial
telephone
notification
to
the
Agency
or
reporting
an
SSI
under
the
CRRR.
Each
written
report,
the
initial
written
report,
the
follow­
up
written
report,
changes
in
sources,
composition,
or
frequency
of
release
report,
and
other
changes
in
information
report,
are
assumed
to
require
five
pages.
Requests
for
additional
information
by
the
Agency
will
vary
23
considerably
in
scope
and
length,
depending
on
the
nature
of
the
request,
however,
it
is
estimated
that
it
will
take
industry
approximately
10
pages
to
complete
the
Agency's
request.
The
postage
and
mailing
costs
are
assumed
to
be
equal
for
all
documents,
and
are
calculated
as
$
1.70
postage
and
$
0.30
per
envelope,
totaling
$
2.00
per
report.
In
Exhibit
6,
O&
M
costs
for
a
typical
facility
are
presented.

Exhibit
5
Unit
Operating
and
Maintenance
Costs
per
Respondent
Information
Collection
Activity
Collection
Activity
Unit
O&
M
Costs
Total
Unit
O&
M
Cost
Photocopying
($
0.25/
page)
Mailing
($
2/
report)

Providing
an
Initial
Telephone
Notification
$
0.00
$
0.00
$
0.00
Preparing
an
Initial
Written
Report
(
5pgs/
1rpt)
$
1.25
$
2.00
$
3.25
Preparing
a
Follow­
up
Written
Report
(
5pgs/
1rpt)
$
1.25
$
2.00
$
3.25
Conducting
an
Annual
Evaluation
of
a
Release
$
0.00
$
0.00
$
0.00
Reporting
a
Change
in
the
Sources,
Composition,
or
Frequency
of
a
Release
(
5pgs/
1rpt)
$
1.25
$
2.00
$
3.25
Reporting
Other
Changes
in
Information
(
5pgs/
1rpt)
$
1.25
$
2.00
$
3.25
Reporting
an
SSI
$
0.00
$
0.00
$
0.00
Other
Activities
 
Providing
Additional
Information
(
10pgs/
1rpt)
$
2.50
$
2.00
$
4.50
Other
Activities
 
Facilitating
a
Site
Inspection
$
0.00
$
0.00
$
0.00
Record
keeping
(
5pgs)
$
1.25
$
0.00
$
1.25
24
Exhibit
6
Operating
and
Maintenance
Costs
for
a
Typical
Facility*

Collection
Activity
Unit
O&
M
Costs
Total
Unit
Cost
Photocopying
($
0.25/
page)
Mailing
($
2/
report)
First
Year
Second
Year
Third
Year
Providing
an
Initial
Telephone
Notification
$
0.00
$
0.00
NA
NA
NA
Preparing
an
Initial
Written
Report
­
8
rpts
@
(
5pgs/
1rpt)
$
1.25
$
2.00
$
26.00
NA
NA
Preparing
a
Follow­
up
Written
Report
­
8
rpts
@
(
5pgs/
1rpt)
$
1.25
$
2.00
NA
$
26.00
NA
Reporting
Other
Changes
in
Information
­
8
rpts
@
(
5pgs/
1rpt)
$
1.25
$
2.00
NA
$
3.25
$
3.25
Record
keeping
­
8
rpts
@
(
5pgs)
$
1.25
$
0.00
$
10.00
$
10.00
$
10.00
Total
O&
M
Costs
for
a
Typical
Facility
$
36.00
$
39.25
$
13.25
*
A
"
typical"
respondent
is
assumed
to
report
eight
continuous
hazardous
substance
releases
in
year
one
and
to
experience
a
change
in
one
release
in
the
second
and
third
years
(
e.
g.,
the
frequency
of
the
release
per
week
changes
each
year,
causing
a
modification
in
the
estimated
annual
release
amount).
No
other
conditional
activities
are
assumed
to
be
required
of
the
typical
respondent.

NA
=
Not
Applicable
Annual
labor
and
O&
M
costs
incurred
by
the
regulated
community
are
summarized
in
Exhibit
7.

Exhibit
7
Unit
Labor
and
Operating
and
Maintenance
Costs
per
Respondent
Information
Collection
Activity
Collection
Activity
Unit
Labor
Cost
Unit
O&
M
Cost
Total
Unit
Costs
Providing
an
Initial
Telephone
Notification
$
105.80
$
0.00
$
105.80
Preparing
an
Initial
Written
Report
$
275.86
$
3.25
$
279.11
Preparing
a
Follow­
up
Written
Report
$
184.30
$
3.25
$
187.55
Conducting
an
Annual
Evaluation
of
a
Release
$
184.30
$
0.00
$
184.30
Reporting
a
Change
in
the
Sources,
Composition,
or
Frequency
of
a
Release
$
320.62
$
3.25
$
323.87
Reporting
Other
Changes
in
Information
$
85.03
$
3.25
$
88.28
Reporting
an
SSI
in
a
Release
$
75.28
$
0.00
$
75.28
Other
Activities
 
Providing
Additional
Information
$
179.04
$
4.50
$
183.54
Other
Activities
 
Facilitating
a
Site
Inspection
$
301.12
$
0.00
$
301.12
Record
keeping
$
122.08
$
1.25
$
123.33
5
Exhibit
8
does
not
include
capital
costs
because
there
are
no
capital
costs
associated
with
implementing
the
regulations
of
the
CRRR.

25
In
Exhibit
85,
annual
labor
and
O&
M
costs
for
a
typical
facility
are
presented.

Exhibit
8
Labor
and
Operating
and
Maintenance
Costs
for
a
Typical
Facility*

Collection
Activity
Total
Labor
Costs
Total
O&
M
Costs
Total
Costs
First
Year
Second
Year
Third
Year
First
Year
Second
Year
Third
Year
First
Year
Second
Year
Third
Year
Providing
an
Initial
Telephone
Notification
$
846.40
NA
NA
NA
NA
NA
$
846.40
NA
NA
Preparing
an
Initial
Written
Report
$
2,206.88
NA
NA
$
26.00
NA
NA
$
2,232.88
NA
NA
Preparing
a
Follow­
up
Written
Report
NA
$
1,474.40
NA
NA
$
26.00
NA
NA
$
1,500.40
NA
Conducting
Annual
Evaluations
NA
NA
$
1,474.40
NA
NA
NA
NA
NA
$
1,474.40
Reporting
Other
Changes
in
Information
NA
$
85.03
$
85.03
NA
$
3.25
$
3.25
NA
$
176.56
$
176.56
Record
keeping
$
976.64
$
976.64
$
976.64
$
10.00
$
10.00
$
10.00
$
2,959.92
$
2,959.92
$
2,959.92
Total
Costs
for
a
Typical
Facility
$
4,029.92
$
2,536.07
$
2,536.07
$
36.00
$
39.25
$
13.25
$
6,039.20
$
4,636.88
$
4,610.88
*
A
"
typical"
respondent
is
assumed
to
report
eight
continuous
hazardous
substance
releases
in
year
one
and
to
experience
a
change
in
one
release
in
the
second
and
third
years
(
e.
g.,
the
frequency
of
the
release
per
week
changes
each
year,
causing
a
modification
in
the
estimated
annual
release
amount).
No
other
conditional
activities
are
assumed
to
be
required
of
the
typical
respondent.

NA
=
Not
Applicable
6(
c)
Estimating
Agency
Burden
and
Costs
To
comply
with
the
provisions
of
the
CRRR,
Federal
government
authorities
perform
the
following
activities
(
see
also
Section
5(
a)
of
this
ICR):
(
1)
process
initial
telephone
notification;
(
2)
process
initial
written
report;
(
3)
process
follow­
up
written
report;
(
4)
process
change
in
the
sources,
composition
or
frequency
of
release
reports;
(
5)
process
other
changes
in
information;
(
6)
process
SSI
reports;
and
(
7)
conduct
other
necessary
activities
(
obtain
additional
information,
conduct
site
inspection).
The
estimated
burden
to
the
Federal
government
for
completing
each
of
6
This
hourly
wage
estimate
was
calculated
by
summing
the
basic
hourly
wage
rate
for
a
GS­
12
step
1
government
employee
in
2004
($
25.35)
and
the
hourly
monetary
value
of
the
representative
employee's
fringe
benefits
(
assumed
to
be
the
basic
hourly
wage
rate
multiplied
by
60
percent).

26
these
CRRR­
mandated
activities
is
based
on
the
CRRR
economic
impact
analysis.
The
CRRR
Economic
Impact
is
available
in
rule
making
Docket
Number
103(
f)
CR
­
4­
8.

Exhibit
9
presents
the
estimated
burden­
hours
and
unit
cost
associated
with
the
Federal
government's
processing
and
evaluation
of
the
various
continuous
release
reports,
as
well
as
the
burden
and
cost
associated
with
any
other
government
initiated
activities
that
may
involve
the
collection
of
information.
The
unit
cost
estimates
presented
in
Exhibit
9
are
derived
by
multiplying
the
applicable
burden
estimates
by
the
average
hourly
wage
rate
for
government
employees.
Based
on
the
2004
GS
pay
schedule,
EPA
estimates
an
average
hourly
labor
cost
of
$
40.56
for
the
average
Federal
government
employee.
6
A
full
description
of
the
basis
for
each
government
burden
estimate
is
provided
in
the
remainder
of
this
section.

Process
Initial
Telephone
Notification
 
EPA
estimates
that
the
NRC
requires
30
minutes
(
0.5
hours)
to
process
the
information
provided
in
the
initial
telephone
call.
The
first
year
unit
cost
associated
with
processing
the
initial
telephone
call
is
$
20.28.

Process
Initial
Written
Report
 
Government
authorities
review
initial
written
and
follow­
up
reports
to
become
familiar
with
the
nature
and
extent
of
the
release,
to
determine
if
the
release
qualifies
for
reduced
reporting
under
CERCLA
section
103(
f)(
2),
and
to
assess
the
hazards
to
public
health
and
welfare
and
the
environment.
EPA
estimates
that
the
preliminary
evaluation
of
the
release
requires
on
average,
one
and
one
half
hour
of
government
time.
The
costs
of
processing
and
evaluating
the
initial
written
report
are
incurred
in
the
first
year
of
reporting.
Therefore,
the
unit
cost
for
processing
and
evaluating
the
initial
written
report
is
$
60.84.

Process
Follow­
up
Written
Report
­­
Within
one
year
of
submitting
the
initial
written
report,
facilities
must
submit
a
written
follow­
up
report
to
update
and
confirm
previously
submitted
information.
The
follow­
up
report
provides
EPA
with
a
more
accurate
baseline
against
which
to
evaluate
both
the
threat
posed
by
the
release
and
the
impact
that
SSIs
in
the
release
may
have
on
public
health
and
welfare
and
the
environment.
The
activities
necessary
to
reevaluate
the
continuous
release
with
the
newly
submitted
follow­
up
report
are
assumed
to
be
identical
to
those
required
to
process
and
evaluate
the
initial
written
report,
one
and
a
half
hour.
The
costs
associated
with
the
follow­
up
written
report,
however,
are
incurred
in
the
second
year
of
reporting.
Therefore,
the
unit
cost
for
processing
and
evaluating
the
follow­
up
written
report
is
$
60.84.

Process
a
Change
in
the
Sources,
Composition,
or
Frequency
of
a
Release
Report
 
After
initial
notification
reports
have
been
submitted
for
a
release
and
reporting
under
section
103(
f)(
2)
has
commenced,
EPA
must
be
notified
of
any
changes
in
release
information
previously
27
submitted.
Any
change
in
the
sources,
composition,
or
frequency
of
a
hazardous
substance
release
constitutes
a
new
release.
Thus,
any
facility
experiencing
a
change
in
the
sources,
composition,
or
frequency
of
a
continuous
release
must
complete
the
initial
notification
process
for
the
new
release.
Government
activities
associated
with
new
release
reports
consist
of
the
processing
and
evaluation
of
the
initial
telephone
and
initial
written
reports,
2
hours.
The
applicable
unit
cost
is
$
81.12
per
new
continuous
release
report.

Process
Other
Changes
in
Information
 
For
changes
in
a
release
other
than
a
change
in
the
sources,
composition,
or
frequency,
the
person
in
charge
must
notify
the
EPA
Region
by
submitting
a
letter
presenting
the
updated
information
and
explaining
the
reasons
for
the
change.
EPA
estimates
that
processing
a
letter
of
changed
information
requires
approximately
30
minutes
(
i.
e.,
0.50
hours)
of
government
time.
This
estimate
consists
of
the
time
necessary
evaluate
the
release
in
light
of
the
changed
information.
The
shorter
evaluation
time
is
assumed
because
it
is
necessary
to
evaluate
only
the
incremental
change
in
the
risk
using
previous
assessments
of
the
release
(
assumed
to
be
on
file)
as
a
baseline.
The
applicable
unit
cost
is
$
20.28
per
changes
in
a
release
report.

Process
an
SSI
(
Statistically
Significant
Increase)
Report
 
SSIs
are
episodic
releases
and
must
be
reported
immediately
to
the
NRC.
Release
quantities
in
excess
of
the
normal
range
have
not
been
previously
reported
and
evaluated
and,
thus,
warrant
immediate
reporting.
Upon
receiving
notification
of
an
SSI,
the
NRC
will
record
the
SSI
information
in
the
NRC
data
base
(
15
minutes)
and
notify
the
appropriate
EPA
Region
of
the
SSI
report
(
15
minutes).
Upon
notification
from
the
NRC
(
15
minutes),
EPA
will
evaluate
the
potential
hazard
posed
by
the
release
in
light
of
the
SSI
(
30
minutes).
Thus,
the
Federal
government
is
estimated
to
require
one
hour
and
fifteen
minutes
(
1.25
hours)
of
government
time
to
process
and
evaluate
each
SSI
reported
under
the
CRRR.
The
applicable
cost
is
$
50.70
per
SSI
Report.

Other
Activities
 
For
some
percentage
of
continuous
releases,
the
information
provided
in
the
initial
and/
or
follow­
up
reports
will
be
incomplete,
incorrect,
or
worrisome,
prompting
EPA
to
request
additional
information
concerning
the
release
and
its
associated
hazard.
For
example,
additional
information
may
be
necessary
to
confirm
the
continuity
and
stability
of
the
release
or
to
better
assess
the
risk
posed
by
the
release.
EPA
estimates
that
the
process
of
requesting
and
reviewing
additional
information
concerning
a
continuous
release
requires
2.0
hours
of
government
time.
The
applicable
unit
cost
is
$
81.12
per
request
and
review
of
additional
information.

In
extreme
cases,
the
preliminary
risk
assessment
of
a
release
will
suggest
the
need
for
a
site
inspection,
allowing
EPA
to
directly
assess
and
evaluate
the
circumstances
of
a
release
and
the
population
and
environment
potentially
affected
by
the
release.
In
addition,
site
inspections
are
conducted
periodically
as
a
compliance
and
enforcement
measure.
EPA
estimates
that
site
inspections
will
require
eight
hours
of
government
time,
including
one
hour
allocated
for
the
EPA
Region
to
communicate
its
concerns
and
findings
to
the
appropriate
SERC
and
LEPC,
and
will
cost
$
324.48.
28
Exhibit
9
Unit
Burden
Hours
and
Costs
Incurred
by
the
Government
per
Information
Collection
Activity
Collection
Activity
Burden
Hours
($
40.56/
hr)
Unit
Cost
Process
Initial
Telephone
Notification
0.50
$
20.28
Process
Initial
Written
Report
1.50
$
60.84
Process
Follow­
up
Written
Report
1.50
$
60.84
Process
a
Change
in
the
Sources,
Composition,
or
Frequency
of
a
Release
Report
2.00
$
81.12
Process
Other
Changes
in
Information
0.50
$
20.28
Process
an
SSI
Report
1.25
$
50.70
Other
Activities
 
Obtaining
Additional
Information
2.00
$
81.12
Other
Activities
 
Conducting
a
Site
Inspection
8.00
$
324.48
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Cost
The
estimates
presented
in
this
ICR
regarding
the
number
of
facilities
and
hazardous
substance
releases
affected
by
the
CRRR
were
computed
using
the
number
of
CR­
ERNS
notifications
made
by
the
NRC
to
each
respective
region
over
the
years
2001,
2002,
and
2003
as
reported
by
the
NRC.
The
number
of
reports
to
be
filed
in
the
next
three
years
is
computed
from
the
total
number
of
reports
already
filed
and
reflects
the
number
of
annual
reports
in
recent
years.
EPA
has
estimated
that
each
affected
facility
has
8
continuous
releases
above
the
releases'
RQs.
Exhibit
10
summarizes
the
estimated
number
of
facilities
and
hazardous
substance
releases
already
affected
by
the
CRRR.
The
change
report
adjustment
reflects
10%
of
the
total
number
of
facilities
and
reports
for
all
regions.
Exhibit
11
presents
the
estimate
for
the
number
of
facilities
and
hazardous
substance
releases
that
will
be
affected
by
the
CRRR
in
the
next
three
years.
The
estimate
is
based
on
an
expected
7.5%
average
annual
percent
increase
in
facilities
(
see
6(
f))
adjusted
from
the
number
of
continuous
release
notifications
reported
by
the
NRC
for
2003.
29
Exhibit
10
Number
of
Facilities
and
Hazardous
Substance
Releases
Already
Affected
by
the
CRRR
Total
Estimated
Number
of
Facilities
with
Continuous
Releases
Estimated
Number
of
Reportable
Continuous
Releases
(
3
years)

EPA
Region
1
138
1,104
EPA
Region
2
150
1,200
EPA
Region
3
259
2,072
EPA
Region
4
747
5,976
EPA
Region
5
565
4,520
EPA
Region
6
703
5,624
EPA
Region
7
415
3,320
EPA
Region
8
190
1,520
EPA
Region
9
163
1,304
EPA
Region
10
165
1,320
Minus
Change
Reports
(
10%)
(
350)
(
2,800)

Total
in
CR­
ERNS
3,145
25,160
Exhibit
11
Number
of
Facilities
and
Hazardous
Substance
Releases
That
Will
Be
Affected
by
the
CRRR
in
the
Next
Three
Years
Total
Estimated
Number
of
Facilities
with
Continuous
Releases
Estimated
Number
of
Reportable
Continuous
Releases
Estimated
New
Releases
in
the
First
Year
62
497
Estimated
New
Releases
in
the
Second
Year
67
534
Estimated
New
Releases
in
the
Third
Year
72
574
Total
Over
Next
Three
Years
201
1,604
Total
in
CR­
ERNS
After
Three
Years
3,346
26,264
30
6(
e)
Bottom
Line
Burden
Hours
and
Costs
The
total
estimated
and
annual
burden
hours
and
costs
incurred
by
industry
affected
by
the
CRRR
are
presented
in
Exhibit
12.
The
total
and
annual
hours
and
costs
incurred
by
industry
are
calculated
over
a
three
year
period.
Exhibit
13
presents
the
total
and
annual
estimated
burden
hours
and
costs
incurred
by
government
authorities
as
a
result
of
the
CRRR
over
a
three
year
period.
Exhibit
14
summarizes
the
estimated
burden
hours
and
costs
incurred
by
industry.
The
bottom
line
burden
to
industry
is
approximately
277,862
hours
for
the
first
year
and
284,000,
and
290,600
hours
for
the
second
and
third
years,
respectively.
The
bottom
line
industry
labor
costs
are
approximately
$
9,793,785,
$
10,010,095,
and
$
10,242,654
for
the
first,
second,
and
third
years,
respectively.
The
bottom
line
industry
O&
M
costs
are
approximately
$
86,109,
$
84,215,
and
$
86,238
for
the
first,
second,
and
third
years,
respectively.
The
average
burden
hours
for
industry
over
a
three
year
period
is
284,154
with
an
average
labor
cost
of
$
10,015,511
and
O&
M
cost
of
$
85,521.

Exhibit
15
summarizes
the
estimated
burden
hours
and
costs
incurred
by
government.
The
bottom
line
burden
to
the
government
is
approximately
26,329
hours
for
the
first
year,
25,190
for
the
second,
and
25,837
for
the
third
year.
The
bottom
line
cost
to
the
government
is
approximately
$
1,067,899,
$
1,021,665,
and
$
1,047,939,
respectively.
The
average
hours
burden
for
the
government
over
a
three
year
period
is
25,785
hours,
at
an
average
annual
cost
of
$
1,045,842.

6(
f)
Reasons
for
Change
in
Burden
This
ICR
increases
the
burden
incurred
by
industry,
as
a
result
of
compliance
with
the
CRRR,
from
249,451
to
284,154
estimated
average
burden
hours.
This
increase
in
burden
results
primarily
from
the
use
of
data
on
the
actual
number
of
continuous
release
reports
from
several
regions
and
applying
a
growth
rate
consistent
with
prior
years
reporting.
The
average
annual
percent
increase
in
facilities
in
the
previous
ICR
was
approximately
7.5%.
The
same
percent
increase
was
assumed
for
this
ICR.
The
unit
burden
hours
per
respondent
information
collection
activity
(
Exhibit
1)
remains
the
same
as
the
previous
ICR.

6(
g)
Burden
Statement
The
reporting
and
record
keeping
burden
for
this
collection
of
information
is
estimated
to
average
approximately
87
hours
per
affected
facility
(
284,154
total
burden
hours/
3,276
affected
facilities).
With
an
average
of
8
responses
for
each
of
the
facilities,
there
is
an
average
of
11.1
hours
per
response,
including
determining
if
the
hazardous
substance
release
qualifies
for
reporting
under
the
CRRR,
gathering
and
maintaining
the
required
information,
and
completing
and
reviewing
the
written
reports.
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
31
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
No.
SFUND­
2000­
0008,
which
is
available
for
public
viewing
at
the
Office
of
Solid
Waste
and
Emergency
Response
Docket
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
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
Office
of
Solid
Waste
and
Emergency
Response
Docket
is
(
202)
566­
0276.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
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,
DC
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
(
SFUND­
2000­
0008)
and
OMB
control
number
(
2050­
0086)
in
any
correspondence.
32
Exhibit
12
Annual
Burden
Hours
and
Costs
Incurred
by
Industry
Collection
Activity
#
of
Reported
Releases
that
Require
the
Collection
Activity
Over
Three
Years
Unit
Burden
Hours
Unit
Labor
Costs*
Unit
O&
M
Costs*
Burden
Hours
Over
Three
Years
Labor
Cost
Over
Three
Years
O&
M
Costs
Over
Three
Years
1st
Year
2nd
Year
3rd
Year
1st
Year
2nd
Year
3rd
Year
1st
Year
2nd
Year
3rd
Year
1st
Year
2nd
Year
3rd
Year
Providing
Initial
Telephone
Notification
497
534
574
3.00
$
105.80
$
0.00
1,491
1,602
1,722
$
52,583
$
56,497
$
60,729
$
0
$
0
$
0
Preparing
Initial
Written
Report
497
534
574
8.00
$
275.86
$
3.25
3,976
4,272
4,592
$
137,102
$
147,309
$
158,344
$
1,615
$
1,736
$
1,866
Preparing
Follow­
up
Written
Report
1,624
497
534
5.00
$
184.30
$
3.25
8,120
2,485
2,670
$
299,303
$
91,597
$
98,416
$
5,278
$
1,615
$
1,736
Conducting
Annual
Evaluations
21,656
23,280
23,777
5.00
$
184.30
$
0.00
108,280
116,400
118,885
$
3,991,201
$
4,290,504
$
4,382,101
$
0
$
0
$
0
Reporting
a
Change
in
the
Sources,
Composition,
or
Frequency
of
a
Release
1,283
1,310
1,338
9.00
$
320.62
$
3.25
11,546
11,786
12,044
$
411,307
$
419,868
$
429,070
$
4,169
$
4,256
$
4,349
Reporting
Changes
in
Other
Information
2,566
2,619
2,677
2.50
$
85.03
$
3.25
6,414
6,548
6,691
$
218,161
$
222,702
$
227,583
$
8,339
$
8,512
$
8,699
Reporting
an
SSI
1,283
1,310
1,338
2.00
$
75.28
$
0.00
2,566
2,619
2,677
$
96,573
$
98,583
$
100,743
$
0
$
0
$
0
Other
Activities
 
 
Additional
Information
7,697
7,857
8,030
4.00
$
179.04
$
4.50
30,788
31,429
32,118
$
1,378,089
$
1,406,771
$
1,437,602
$
34,637
$
35,358
$
36,133
Other
Activities
 
 
Site
Inspection
257
262
268
8.00
$
301.12
$
0.00
2,053
2,095
2,141
$
77,258
$
78,866
$
80,595
$
0
$
0
$
0
Record
keeping
25,657
26,191
26,765
4.00
$
122.08
$
1.25
102,628
104,764
107,060
$
3,132,207
$
3,197,397
$
3,267,471
$
32,071
$
32,739
$
33,456
Total
277,862
284,000
290,600
$
9,793,785
$
10,010,095
$
10,242,654
$
86,109
$
84,215
$
86,238
33
Exhibit
13
Annual
Burden
Hours
and
Costs
Incurred
by
Government
Collection
Activity
#
of
Reported
Releases
Estimated
to
Require
the
Collection
Activity
Over
Three
Years
Unit
Burden
Hours
Unit
Cost
Burden
Hours
Over
Three
Years
Cost
Over
Three
Years
1st
Year
2nd
Year
3rd
Year
1st
Year
2nd
Year
3rd
Year
1st
Year
2nd
Year
3rd
Year
Processing
Initial
Telephone
Notification
497
534
574
0.50
$
20.28
249
267
287
$
10,079
$
10,830
$
11,641
Processing
Initial
Written
Report
497
534
574
1.50
$
60.84
746
801
861
$
30,237
$
32,489
$
34,922
Processing
Follow­
up
Written
Report
1,624
497
534
1.50
$
60.84
2,436
746
801
$
98,804
$
30,237
$
32,489
Processing
a
Change
in
the
Sources,
Composition,
or
Frequency
of
a
Release
Report
1,283
1,310
1,338
2.00
$
81.12
2,566
2,619
2,677
$
104,065
$
106,231
$
108,559
Processing
Other
Change
in
Information
2,566
2,619
2,677
0.50
$
20.28
1,283
1,310
1,338
$
52,032
$
53,115
$
54,279
Processing
an
SSI
Report
1,283
1,310
1,338
1.25
$
50.70
1,604
1,638
1,673
$
65,040
$
66,417
$
67,849
Other
Activities
 
 
Obtaining
Additional
Information
7,697
7,857
8,030
2.00
$
81.12
15,394
15,715
16,059
$
624,389
$
637,384
$
651,353
Other
Activities
 
 
Site
Inspection
257
262
268
8.00
$
324.48
2,053
2,095
2,141
$
83,252
$
84,985
$
86,847
Total
26,329
25,190
25,837
$
1,067,899
$
1,021,687
$
1,047,939
34
Exhibit
14
Summary
of
Burden
Hours
and
Costs
Incurred
by
Industry
First
Year
Second
Year
Third
Year
Average
(
over
a
three
year
period)

Total
Number
of
Respondents
3,207
3,274
3,346
3,276
Total
Burden
Hours
277,862
284,000
290,600
284,154
Total
Labor
Costs
(
thousand
$)
$
9,794
$
10,010
$
10,243
$
10,016
Total
O&
M
Costs
(
thousand
$)
$
86
$
84
$
86
$
85
Exhibit
15
Summary
of
Burden
Hours
and
Costs
Incurred
by
Government
First
Year
Second
Year
Third
Year
Annual
Average
Total
Burden
Hours
26,329
25,190
25,837
25,785
Total
Cost
(
thousand
$)
$
1,068
$
1,022
$
1,048
$
1,046
35
APPENDIX
A
Phone­
Log
Summaries
The
following
calls
were
made
between
August
20,
2004
and
September
2,
2004.
The
companies
were
selected
from
the
universe
of
facilities
for
which
a
continuous
release
notification
was
made.
Persons
responsible
for
making
notifications
were
queried
about
the
internal
process
and
procedures
taken
at
the
facility
between
the
time
a
release
is
observed
and
a
call
is
made
to
the
NRC
and
through
the
30
day
follow­
up
report,
one
year
anniversary
report
and
any
additional
reports
required
that
resulted
from
changes
to
the
continuous
release.

Eastman
Kodak
Private
Enterprise
Rochester,
NY
Incident
Report
#
647410
On
June
10,
2003
Eastman
Kodak
called
the
NRC
to
report
a
continuous
release
of
material
from
a
cooling
tank.
On
August
20,
2004,
the
HQ
EPA
CR­
ERNS
analyst
spoke
with
the
person
responsible
for
developing
procedures
for
reporting
releases.
The
facility
has
procedures
that
have
been
in
place
for
a
while.
The
incident
was
also
reported
to
state
officials.
The
release
includes
fugitives
that
occur
during
the
year.
The
company
spokesperson
did
not
have
any
questions
about
the
reporting
process.

Kraft
Foods
North
America
Private
Enterprise
North
Field,
IL
Incident
Report
#
653094
On
August
6,
2003,
Kraft
Foods
called
the
NRC
to
report
a
continuous
release
of
material
from
oven
stacks
(
power
stack).
On
August
20,
2004,
the
HQ
EPA
CR­
ERNS
analyst
spoke
with
the
person
responsible
for
reporting
releases.
The
company
representative
indicated
that
the
sample
forms
that
EPA
has
posted
on
the
internet
were
straight
forward.
Also
reported
to
the
state
and
county.
The
company
representative
commented
that
the
exact
address
to
send
the
written
followup
reports
is
not
provided.
The
written
report
was
sent
to
the
general
Region
3
address
(
the
incident
took
place
in
Richmond,
VA).
Felt
that
it
would
be
helpful
if
a
better,
more
direct
address
is
easier
to
find.
EPA
will
update
its
internet
site
to
provide
appropriate
addresses
for
each
region.

Armstrong
World
Industries
Private
Enterprise
Jackson,
MS
Incident
Report
#
722572
36
On
May
21,
2004,
Armstrong
World
Industries
called
the
NRC
to
make
an
initial
report
for
the
continuous
release
of
residual
vinyl
chloride.
On
August
20,
2004,
the
HQ
EPA
CR­
ERNS
analyst
spoke
with
the
person
responsible
for
reporting
releases.
The
company
representatitve
indicated
that
the
reporting
process
is
fairly
well
defined
by
EPA
regulations.
The
individual
did
not
have
any
other
comments
­
he
is
actually
no
longer
with
company
and
he
gave
me
a
name
and
contact
information
for
an
individual
at
corporate
headquarters
in
Lancaster,
PA
responsible
for
overall
corporate
coordination
of
environmental
reporting.
The
HQ
EPA
CR­
ERNS
analyst
called
the
person.
This
individual
did
not
have
any
comments
at
the
time,
but
offered
to
call
back
if
after
review
of
his
files
had
any
comment.
As
of
September
3,
2004,
there
has
not
been
further
communication.

Goodyear
Tire
and
Rubber
Private
Enterprise
Houston,
TX
Incident
Report
#
648038
On
June
16,
2003,
Goodyear
Tire
and
Rubber
called
the
NRC
to
make
an
report
of
a
statistically
significant
increase
for
an
existing
continuous
release
report
of
ammonia
from
closed
loop
refrigeration
system.
On
September
2,
2004,
the
HQ
EPA
CR­
ERNS
analyst
spoke
with
the
person
responsible
for
reporting
releases.
The
individual
did
not
have
any
questions
about
the
reporting
process.
The
individual
indicated
that
the
company
spends
about
1.5
days
evaluating
their
release
each
year.
They
have
only
one
chemical
covered
under
the
Continuous
Release
Reporting
Regulations.

Ft.
James
Operating
Co.
Private
Enterprise
Green
Bay,
WI
Incident
Report
#
728498
On
July
16,
2004,
Ft.
James
Operating
Co.
called
the
NRC
to
make
an
report
of
a
change
to
the
upper
bounds
for
three
chemicals
or
a
statistically
significant
increase
(
SSI)
for
an
existing
continuous
release
report
of
hydrogen
flouride,
chloroform
and
biphenyl.
On
September
2,
2004,
the
HQ
EPA
CR­
ERNS
analyst
spoke
with
the
person
responsible
for
reporting
releases.
The
individual
provided
some
valuable
feedback
on
the
reporting
process.
The
individual
indicated
that
when
she
made
her
initial
report
to
the
NRC
in
2002
she
had
problems
conveying
the
information
to
the
individual
at
the
NRC
who
answered
the
call.
Apparently
the
NRC
staff
person
did
not
understand
what
an
initial
report
to
the
NRC
on
continuous
releases
was.
This
time
there
was
some
confusion
as
to
which
numbers
should
be
used
for
reporting
­
the
original
incident
number
or
the
new
number
assigned
for
the
SSI
report.
The
HQ
EPA
CR­
ERNS
analyst
answered
that
both
numbers
should
be
used
so
that
the
region
can
pair
the
reports.
The
company
representative
would
also
like
to
see
interactive
forms
on
the
internet
for
CR­
ERNS
reporting.
This
will
be
explored
further
now
that
Adobe
(
pdf
formatting)
has
advanced.
37
