RENEWAL
OF
INFORMATION
COLLECTION
REQUEST
FOR
NOTIFICATION
OF
EPISODIC
RELEASES
OF
OIL
AND
HAZARDOUS
SUBSTANCES
February
23,
2001
OMB
SUBMITTAL
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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2
2(
a)
Need
and
Authority
for
the
Collection
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2
2(
b)
Practical
Utility
and
Users
of
the
Data
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3
3.
NON­
DUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
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3
3(
a)
Non­
duplication
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3
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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5
3(
e)
General
Guidelines
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5
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
Recordkeeping
Requirements
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6
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ii)
Respondent
Activities
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7
5.
THE
INFORMATION
COLLECTED
 
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
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8
5(
a)
Agency
Activities
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8
5(
b)
Collection
Methodology
and
Management
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8
5(
c)
Small
Entity
Flexibility
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9
5(
d)
Collection
Schedule
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9
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
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9
6(
a)
Estimating
Respondent
Burden
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9
6(
b)
Estimating
Respondent
Costs
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11
6(
c)
Estimating
Agency
Burden
and
Cost
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12
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
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13
6(
e)
Bottom
Line
Burden
Hours
and
Costs
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14
6(
f)
Reasons
for
Change
in
Burden
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15
6(
g)
Burden
Statement
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15
EXHIBITS
Exhibit
1
Unit
Burden
Hours
for
Reporting
a
Typical
Release
to
the
NRC
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10
Exhibit
2
Unit
Cost
for
Reporting
a
Typical
Release
to
the
NRC
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12
Exhibit
3
Agency
Burden
Hours
and
Costs
for
Processing
a
Telephone
Notification
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13
Exhibit
4
Estimated
Annual
Burden
Hours
and
Costs
Incurred
by
Industry
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14
Exhibit
5
Estimated
Annual
Burden
Hours
and
Costs
for
Information
Collection
Under
CERCLA
Section
103(
a)
and
CWA
Section
311
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14
Exhibit
6
Summary
of
Total
Burden
Hour
Change
Between
This
ICR
and
the
Previous
ICR
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15
OMB
SUBMITTAL***
February
23,
2001
Page
1
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
l(
a)
Title
and
Number
of
the
Information
Collection
Notification
of
Episodic
Releases
of
Oil
and
Hazardous
Substances
­
EPA
No.
1049.09.

l(
b)
Short
Characterization
This
information
collection
request
(
ICR)
addresses
the
reporting
and
recordkeeping
activities
required
to
comply
with
the
release
notification
requirements
for
hazardous
substances
and
oil
specified
in
section
103(
a)
of
the
Comprehensive
Environmental
Response,
Compensation,
and
Liability
Act
of
1980
(
CERCLA),
as
amended,
and
section
311
of
the
Clean
Water
Act
(
CWA),
as
amended.
These
reporting
requirements
are
codified
at
40
CFR
parts
110,
117,
and
302.
This
ICR
renews
the
collection
activity
previously
approved
under
OMB
No.
2050­
0046
and
applies
to
the
period
September
1,
2000
through
August
31,
2003.
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)
and
CWA
section
311
require
the
person
in
charge
of
a
facility
or
vessel
to
immediately
notify
the
National
Response
Center
(
NRC)
of
a
hazardous
substance
release
into
the
environment
if
the
release
quantity
equals
or
exceeds
the
substance's
reportable
quantity
(
RQ)
level
and
an
oil
discharge
into
U.
S.
waters.
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;


Report
the
release
to
the
NRC;
and

Keep
a
log
of
release
data
such
as
the
time,
date,
and
circumstances
of
the
release.
(
This
information
is
expected,
but
not
required
under
the
regulations.)

There
are
no
recordkeeping
requirements
specified
under
CERCLA
section
103(
a),
CWA
section
311,
or
their
implementing
regulations.
The
person
in
charge
of
the
facility
or
vessel,
however,
may
elect
to
maintain
a
log
detailing
the
time,
date,
and
circumstances
associated
with
the
reported
release.
The
purpose
of
maintaining
a
log
of
reported
releases
is
to
track
correspondence
with
response
authorities
and
to
document
compliance
with
release
notification
requirements
under
CERCLA
and
the
CWA.
Because
it
is
assumed
the
respondent
will
maintain
a
log
of
reported
releases,
burden
and
cost
estimates
associated
with
recordkeeping
are
included
in
the
ICR.
1
The
estimate
for
the
number
of
release
notifications
received
by
the
NRC
per
annum
is
based
on
the
number
of
notifications
received
by
the
NRC
in
the
years
1997,
1998,
and
1999.
The
NRC
received
24,001
release
notifications
in
1997,
23,653
in
1998,
and
23,524
in
1999.
Therefore,
assuming
the
years
1997,
1998,
and
1999
are
representative
of
the
period
covered
by
this
ICR,
the
NRC
is
estimated
to
receive,
on
average,
23,726
release
notifications
per
annum
between
September
1,
2000
through
August
31,
2003.
In
the
previous
ICR
the
per
annum
estimate
for
the
number
of
release
notifications
received
by
the
NRC
was
29,204.

OMB
SUBMITTAL***
February
23,
2001
Page
2
During
the
three­
year
period
covered
by
this
ICR,
it
is
estimated
that
the
NRC
will
receive
23,726
release
notifications
(
i.
e.,
hazardous
substance
release
and
oil
discharge
notifications)
per
annum.
1
Assuming
23,726
release
notifications
per
annum,
the
total
annual
burden
to
respondents
is
estimated
to
be
approximately
97,277
hours,
at
a
cost
of
$
3,962,005.
The
total
annual
burden
to
the
government
associated
with
23,726
release
notifications
is
estimated
to
be
approximately
23,726
hours,
at
a
cost
of
$
854,136.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need
and
Authority
for
the
Collection
The
reporting
activity
required
under
40
CFR
parts
110,
117,
and
302
is
authorized
under
CERCLA
sections
103(
a)
and
104(
e),
and
CWA
sections
311
and
308.
The
regulations
implementing
CERCLA
section
103(
a)
(
40
CFR
part
302)
require
the
person
in
charge
of
a
facility
or
vessel
to
immediately
notify
the
NRC
of
a
hazardous
substance
release
if
the
release
quantity
equals
or
exceeds
the
substance's
RQ.
The
specific
information
provided
in
the
notification
required
under
CERCLA
section
103(
a)
is
authorized
under
CERCLA
section
104(
e).
Section
104(
e)
authorizes
the
collection
of
release
information,
entry
and
inspection
of
the
release
site,
and
sampling
activities
at
the
release
site
for
the
purposes
of
"
determining
the
need
for
response,
or
choosing
or
taking
any
response
action
under
[
CERCLA]."
The
release
information
collected
is
the
minimum
information
needed
to
determine
if
a
Federal
response
action
is
required
to
control
or
mitigate
any
potential
adverse
effects
associated
with
a
release.

In
addition
to
the
CERCLA
notification
requirements,
the
regulations
implementing
CWA
section
311
(
40
CFR
part
110)
require
immediate
notification
to
the
NRC
of
any
release
of
oil
into
U.
S.
navigable
waters
that
causes
a
sheen,
violates
applicable
water
quality
standards,
or
causes
a
sludge
or
emulsion
to
be
deposited
beneath
the
surface
of
the
water
or
upon
adjoining
shorelines.
The
information
required
to
be
provided
under
CWA
section
311
is
authorized
by
CWA
section
308,
which
allows
for
the
collection
of
release
information
and
entry,
monitoring,
inspection
and
sampling
activities
at
the
release
site
for
the
purpose
of
ensuring
that
the
objectives
of
the
CWA
are
satisfied.
The
Federal
government
needs
to
be
notified
of
releases
of
oil
in
order
to
determine
if
a
response
action
is
necessary
to
mitigate
or
prevent
damage
to
public
health
or
welfare
or
the
environment.
OMB
SUBMITTAL***
February
23,
2001
Page
3
2(
b)
Practical
Utility
and
Users
of
the
Data
The
hazardous
substance
and
oil
release
information
collected
pursuant
to
CERCLA
section
103(
a)
and
CWA
section
311
has
a
variety
of
different
uses.
Federal
response
authorities,
such
as
EPA
and
United
States
Coast
Guard
On­
Scene
Coordinators
(
OSCs),
use
the
information
to
evaluate
the
environmental
and
human
health
risks
attributable
to
a
reported
release
and
to
determine
if
a
Federal
response
action
is
necessary
to
mitigate
or
prevent
any
adverse
effects
associated
with
the
release.
Any
reportable
hazardous
substance
release
or
discharge
of
oil
into
the
environment
warrants
a
timely
evaluation
of
its
source,
emission
rate,
chemical
form,
media
affected,
and
quantity
released
to
ensure
the
proper
protection
of
public
health
and
welfare
and
the
environment.
Responses
to
hazardous
substance
and
oil
release
notifications
by
Federal
authorities
may
take
a
variety
of
forms,
including
monitoring
and
overseeing
cleanup
activities
conducted
by
the
responsible
party,
evacuating
surrounding
populations,
and
directing
the
actual
cleanup
operation.

The
hazardous
substance
and
oil
release
information
collected
under
CERCLA
section
103
and
CWA
section
311
also
is
used
by
EPA
program
offices
and
other
Federal
agencies
to
evaluate
the
potential
need
for
additional
regulations,
new
permitting
requirements
for
specific
substances
or
sources,
or
improved
emergency
response
planning.

In
addition,
release
notification
information,
which
is
stored
in
the
national
Emergency
Response
Notification
System
(
ERNS)
data
base,
is
used
by
State
and
local
government
authorities,
the
regulated
community,
and
the
general
public.
State
and
local
government
authorities
and
the
regulated
community
use
release
information
to
help
inform
local
emergency
response
planning.
The
public
use
release
information
to
become
aware
of
the
releases
that
have
occurred
in
their
communities
and
throughout
the
nation
and
to
learn
of
actions,
if
any,
that
are
being
taken
to
protect
public
health
and
welfare
and
the
environment.
The
public
has
access
to
release
information,
statistics,
and
fact
sheets
through
the
Freedom
of
Information
Act
and
several
websites,
including
the
U.
S.
EPA's
ERNS
website
(
http://
www.
epa.
gov/
ERNS/
index.
html)
and
the
NRC's
website
(
http://
www.
nrc.
uscg.
mil/
index.
html).

3.
NON­
DUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Non­
duplication
The
information
required
to
be
provided
in
the
telephone
call
to
the
NRC
is
the
minimum
information
necessary
to
evaluate
a
hazardous
substance
release
or
discharge
of
oil.
Direct
notification
to
the
NRC,
as
opposed
to
notification
to
multiple
Federal
response
authorities,
helps
to
ensure
a
coordinated
Federal
response
effort
and
that
unnecessary
delays
in
requesting
assistance
do
not
occur.
One
call
to
the
NRC
fulfills
the
requirement
to
report
releases
of
hazardous
substances
under
CERCLA
and
several
other
regulatory
programs,
including
the
CWA,
the
Resource
Conservation
and
Recovery
Act,
and
the
Hazardous
Materials
OMB
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February
23,
2001
Page
4
Transportation
Act.
When
the
NRC
receives
a
notification,
the
NRC
watchstander
immediately
notifies
the
appropriate
Federal
OSC,
who
evaluates
the
circumstances
surrounding
the
release
and
determines
the
need
for
a
government
response
action.
The
Federal
government
has
extensive
resources,
expertise,
and
authority
under
CERCLA
to
formulate
response
actions,
ensuring
a
timely
and
coordinated
field
response
with
State,
local,
and
private
organizations,
if
needed.

EPA
analyzed
possible
areas
of
overlap
with
other
regulations,
and
concluded
that
there
are
limited
areas
of
overlap
with
reporting
requirements
under
other
statutes
and
provisions.
For
example,
there
may
be
limited
duplication
with
the
reporting
requirements
specified
in
CERCLA
section
103(
a)
and
in
certain
permitting
regulations.
Often,
permitting
regulations
require
reports
if
the
permit
level
is
exceeded.
Thus,
if
a
release
of
a
hazardous
substance
exceeds
its
permit
level
and
the
substance's
RQ,
the
release
may
be
reported
to
both
the
applicable
Federal
or
State
permitting
authority
and
NRC.
The
purpose
and
timing
of
the
two
reports,
however,
often
differ.
Federal
officials
use
release
information
provided
to
the
NRC
to
evaluate
the
release
situation
and
determine
if
a
government
response
is
necessary.
In
contrast,
violations
of
permit
regulations
are
reported
to
EPA
Regional
permitting
offices
or
to
State
permitting
authorities
in
order
to
maintain
proper
permit
enforcement
records
or
to
evaluate
ambient
conditions
over
time.
Further,
notification
of
permit
exceedances
is
often
provided
in
monthly
monitoring
reports;
such
periodic
notification
is
not
timely
for
response
purposes.

In
addition
to
a
possible
overlap
between
CERCLA
reporting
and
certain
permitting
regulations,
there
may
be
some
overlap
with
respect
to
the
reporting
requirements
specified
in
section
304
of
the
Emergency
Planning
and
Community
Right­
to­
Know
Act
(
EPCRA),
which
requires
immediate
reporting
of
releases
of
CERCLA
hazardous
substances
equal
to
or
above
an
RQ
to
State
and
local
response
officials.
Reporting
to
the
NRC
as
well
as
to
the
appropriate
State
Emergency
Response
Commission
(
SERC)
and
Local
Emergency
Planning
Committee
(
LEPC),
as
required
under
EPCRA
section
304,
is
appropriate,
however,
because
it
ensures
that
the
Federal
government
is
alerted
to
releases
that
may
require
a
Federal
field
response.
Although
the
SERCs
and
LEPCs
are
notified
of
the
releases
under
EPCRA
section
304,
some
SERCs
and
LEPCs
may
not
possess
the
resources
necessary
for
a
proper
response
action.
Notification
to
the
NRC
allows
for
a
timely
response
in
the
event
of
an
emergency.
Furthermore,
reporting
to
the
NRC,
SERC,
and
LEPC
provides
for
a
coordinated
effort
among
Federal,
State,
and
local
response
officials,
which
helps
ensure
that
an
efficient
response
action
is
taken.
When
Congress
enacted
EPCRA
section
304,
it
was
aware
that
releases
of
hazardous
substances
were
already
reported
to
the
NRC;
Congress
determined
that
it
was
necessary
and
appropriate
for
such
potentially
hazardous
releases
to
be
reported
immediately
to
all
potentially
affected
government
jurisdictions.
The
requirements
under
EPCRA,
however,
are
separate
from
those
under
CERCLA,
and
are
outside
the
scope
of
this
ICR.
The
statutory
requirements
under
CERCLA
and
EPCRA
are
clear
and
distinct;
the
Federal
response
system,
as
well
as
the
State
and
local
response
systems,
must
be
alerted
immediately
to
potentially
dangerous
releases
of
hazardous
substances
that
may
pose
a
threat
to
public
health
or
welfare
or
the
environment.

3(
b)
Public
Notice
OMB
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February
23,
2001
Page
5
In
compliance
with
the
Paperwork
Reduction
Act
(
44
U.
S.
C.
3501
et
seq.),
EPA
has
notified
the
public
through
the
Federal
Register
notice
on
the
renewal
of
this
ICR
(
See
65
FR
37128,
June
13,
2000).
EPA
received
three
comment
responses
to
the
June
2000
notice.
The
notice
however;
was
withdrawn
on
August
22,
2000
(
65
FR
50985)
so
that
additional
information
could
be
considered
in
this
Information
Collection
Request
support
document.
A
second
notice
was
published
in
the
Federal
Register
(
65
FR
75930,
December
5,
2000)
allowing
for
another
60
days
of
public
comment.
Comments
were
received
from
two
of
the
original
three
commenters.

3(
c)
Consultations
EPA
has
consulted
with
a
number
of
Federal
and
State
government
agencies
in
the
development
of
the
information
collection
activities
described
in
this
ICR.
Workgroups
have
been
developed
for
all
RQ
adjustment
regulations
as
well
as
the
oil
discharge
regulation.
These
Workgroups
consisted
of
representatives
from
various
EPA
program
offices,
the
ten
EPA
Regions,
and
the
NRC.
Participation
of
these
parties
in
the
Workgroups
was
sufficient
to
address
and
resolve
all
outstanding
issues.
The
comments
received
on
the
proposed
rules
are
addressed
in
the
relevant
Response
to
Comments
Documents
and
in
the
preambles
to
the
final
rules.

In
addition
to
the
Workgroup
activities,
EPA
has
sponsored
many
workshops
and
training
sessions
throughout
the
country
for
industry
and
Federal,
State,
and
local
government
response
officials
on
the
release
notification
requirements
under
CERCLA
and
the
CWA.
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
ask
questions
about,
and
comment
on,
the
implementation
of
the
reporting
regulations
under
CERCLA
and
the
CWA.

3(
d)
Effects
of
Less
Frequent
Collection
The
information
required
under
the
regulations
implementing
CERCLA
section
103(
a)
and
CWA
section
311
is
not
collected
at
any
specified
frequency;
rather,
it
is
collected
when
reportable
releases
occur.
The
information
collected
under
the
regulations,
such
as
the
source,
quantity,
and
type
of
material
released
and
the
environmental
medium
affected,
is
critical
to
evaluating
the
threat
posed
by
the
release
and
the
need
for
a
response
action.
The
regulatory
requirements
evaluated
in
this
ICR
represent
EPA's
efforts
to
ensure
that
the
NRC
is
notified
immediately
of
those
hazardous
substance
and
oil
releases
for
which
a
Federal
response
action
may
be
necessary
to
protect
public
health
and
welfare
and
the
environment.

3(
e)
General
Guidelines
The
regulations
implementing
CERCLA
section
103(
a)
and
CWA
section
311
adhere
fully
to
OMB's
general
guidelines
concerning
the
collection
of
information
and
the
control
of
paperwork
burdens
on
the
public.
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February
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2001
Page
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3(
f)
Confidentiality
The
regulations
implementing
CERCLA
section
103(
a)
and
CWA
section
311
do
not
require
the
submittal
of
any
proprietary,
trade
secret,
or
other
confidential
information.

3(
g)
Sensitive
Questions
The
regulations
implementing
CERCLA
section
103(
a)
and
CWA
section
311
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
use
and
release
of
hazardous
substances
and
oil
are
pervasive
throughout
industry.
EPA
expects
a
number
of
different
industrial
categories
to
report
hazardous
substance
and
oil
releases
pursuant
to
the
requirements
specified
in
CERCLA
section
103(
a)
and
CWA
section
311.
No
one
industry
sector
or
group
of
sectors
or
size
of
facility
is
affected
disproportionately
by
the
information
collection
burden.

4(
b)
Information
Requested
(
i)
Data
Items,
Including
Recordkeeping
Requirements
Notification
under
CERCLA
section
103(
a)
and
CWA
section
311
is
intended
to
ensure
that
Federal
authorities
receive
prompt
notification
of
hazardous
substance
and
oil
releases
for
which
a
timely
response
may
be
necessary
to
protect
public
health
or
welfare
or
the
environment.
The
information
provided
in
the
telephone
call
to
the
NRC
serves
to
notify
government
authorities
of
the
release
and
provides
them
with
a
description
of
the
circumstances
surrounding
the
release.
The
following
information
is
requested
from
all
callers:


The
name
and
location
of
the
individual
reporting
the
release,
the
name
and
type
of
organization
(
e.
g.,
general
public,
industrial
facility,
or
Federal,
State,
or
local
government)
with
which
the
individual
reporting
the
release
is
affiliated,
and
the
telephone
number
of
the
person
reporting
the
release;


The
name
and
location
of
the
releaser,
the
type
of
organization
responsible
for
the
release,
and
the
telephone
number
of
the
releaser;


The
location
of
the
release;
OMB
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February
23,
2001
Page
7

The
date
and
time
of
the
release;


The
name
and
type
of
material
involved
in
the
release,
and
the
quantity
of
the
substance
released;


The
source
of
the
release,
the
vehicle
identification
or
carrier
number,
if
applicable,
and
a
brief
description
of
the
source;


The
environmental
medium
affected
by
the
release
(
e.
g.,
air,
land,
water,
or
ground
water);


The
cause
of
the
incident
(
e.
g.,
transportation
accident,
operational
error,
natural
phenomenon),
and
a
brief
description
of
the
release
scenario
denoting
any
unusual
circumstances
associated
with
the
release;


Information
on
damages
that
occurred
as
a
result
of
the
release,
including
the
number
of
injuries,
number
of
deaths,
and
any
property
damage;


A
description
of
the
response
actions
taken
at
the
release
site,
if
any;


The
name(
s)
and
type
of
organization(
s)
that
the
caller
has
already
notified;
and

Any
additional
comments
or
information
regarding
the
release.

As
mentioned
previously,
there
are
no
recordkeeping
requirements
specified
under
CERCLA
section
103(
a),
CWA
section
311,
or
their
implementing
regulations.
The
person
in
charge
of
the
facility
or
vessel,
however,
may
elect
to
maintain
a
log
detailing
the
time,
date,
and
circumstances
associated
with
the
reported
release.
The
purpose
of
maintaining
a
log
of
reported
releases
is
to
track
correspondence
with
response
authorities
and
to
document
compliance
with
release
notification
requirements
under
CERCLA
and
the
CWA.
Because
the
respondent
will
in
all
likelihood
maintain
a
reported
release
log,
burden
and
cost
estimates
associated
with
recordkeeping
are
included
in
this
ICR.

(
ii)
Respondent
Activities
To
comply
with
the
notification
requirements
specified
in
the
regulations
implementing
CERCLA
section
103(
a)
and
CWA
section
311,
the
regulated
community
is
expected
to
perform
the
following
activities:


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;
OMB
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February
23,
2001
Page
8

Report
the
release
by
telephone
to
the
NRC;
and

Keep
a
log
of
release
data
such
as
the
time,
date,
and
circumstances
of
the
release.
(
This
information
is
expected
but
not
required
under
the
regulations.)

These
five
general
steps
have
been
verified
through
conversations
with
environmental
compliance
experts
at
facilities
that
reported
releases
of
hazardous
substances
to
the
NRC
during
1992,
1993,
and
1994.
Each
environmental
compliance
manager
at
these
facilities
was
asked
about
the
internal
activities
that
are
likely
to
occur
between
the
time
a
release
of
a
hazardous
substance
is
discovered
and
the
time
a
call
is
made
to
the
NRC.
The
burden
hours
associated
with
reporting
a
release
were
in
part
based
upon
these
findings.

5.
THE
INFORMATION
COLLECTED
 
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
Every
hazardous
substance
and
oil
release
reported
by
the
regulated
community
to
the
NRC
must
be
evaluated
by
Federal
authorities.
The
appropriate
Federal
On­
Scene
Coordinator
(
OSC)
is
notified
of
a
release
by
a
telephone
call
from
the
NRC.
The
NRC
conveys
all
the
relevant
information
regarding
the
release
to
the
OSC,
including
whether
the
release
is
to
air,
soil,
water,
etc.,
the
source
of
the
release,
and
the
type
of
substance
released.
The
telephone
call
from
the
NRC
to
the
OSC
must
occur
within
15
minutes
of
the
original
release
notification.
The
OSC
is
responsible
for
evaluating
the
circumstances
surrounding
the
release
to
determine
whether
government
monitoring
and/
or
a
Federal
response
action
may
be
necessary.

NRC
personnel
are
also
responsible
for
entering
release
information
into
the
NRC
data
base.
The
release
data
are
stored
in
the
NRC
data
base,
ERNS,
a
national
data
base
that
stores
release
information
by
facility.
The
data
can
be
accessed
through
the
NRC
web
site:
http://
www.
nrc.
uscg.
mil/
foia.
htm.
The
primary
activity
of
the
Federal
government
under
the
regulations
implementing
CERCLA
section
103(
a)
and
CWA
section
311
is
processing
and
recording
the
reported
release
information,
and
responding
to
releases
that
may
pose
a
significant
hazard
to
public
health
or
welfare
or
the
environment.

5(
b)
Collection
Methodology
and
Management
For
purposes
of
reporting
releases
under
the
regulations
implementing
CERCLA
section
103(
a)
and
CWA
section
311,
a
person
in
charge
of
a
facility
or
vessel
that
experiences
a
reportable
release
must
telephone
the
NRC.
The
NRC
notifies
the
appropriate
EPA
Region
or
United
States
Coast
Guard
Office,
the
affected
State,
and
any
other
Federal
agency
that
may
be
able
to
lend
support
to
a
potential
response
action.
OMB
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2001
Page
9
To
manage
the
hazardous
substance
and
oil
release
information
submitted
in
accordance
with
CERCLA
section
103(
a)
and
CWA
section
311,
EPA
uses
the
ERNS
data
base.
When
a
hazardous
substance
or
oil
release
is
reported
to
the
NRC,
it
is
immediately
entered
into
the
NRC
data
base.
The
ERNS
data
base
allows
EPA
to
document,
analyze,
and
maintain
data
gathered
under
the
CERCLA
and
CWA
notification
process.

For
Federal
response
authorities,
the
ERNS
data
base
reduces
the
cost
and
time
associated
with
processing
and
documenting
release
reports.
For
other
EPA
program
offices,
State
and
local
response
officials,
and
the
public,
ERNS
provides
for
easy
access
to
release
data.

5(
c)
Small
Entity
Flexibility
The
notification
requirements
apply
equally
to
all
facilities
or
vessels,
regardless
of
size,
that
have
reportable
releases
of
CERCLA
hazardous
substances
or
oil.
The
regulations
do
not
impose
any
general
information
collection
or
recordkeeping
requirements
on
small
businesses.
EPA
believes
that
the
notification
requirements
specified
under
these
regulations
represent
the
minimum
level
of
information
necessary
for
Federal
response
officials
to
determine
if
a
government
response
action
is
needed
to
prevent
or
mitigate
any
damage
to
public
health
or
welfare
or
the
environment.
The
regulatory
requirements
are
satisfied
by
a
toll­
free
telephone
call
to
the
NRC.
A
reduction
in
these
reporting
requirements
for
small
businesses
is
not
possible
without
jeopardizing
the
Federal
government's
ability
to
evaluate
the
threat
posed
by
a
release
and
determine
if
a
Federal
response
is
necessary.

5(
d)
Collection
Schedule
Information
is
not
collected
at
any
specified
frequency;
rather,
it
is
collected
when
reportable
releases
occur.
Under
CERCLA
section
103(
a),
a
release
of
a
hazardous
substance
is
reportable
when
it
equals
or
exceeds
its
RQ.
Pursuant
to
CWA
section
311,
a
discharge
of
oil
into
navigable
waters
is
reportable
whenever
the
discharge
causes
a
sheen,
violates
applicable
water
quality
standards,
or
causes
a
sludge
or
emulsion
to
be
deposited
beneath
the
surface
of
the
water
or
upon
adjoining
shorelines.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
Under
CERCLA
section
103(
a)
and
CWA
section
311,
the
person
in
charge
of
a
facility
or
vessel
that
experiences
a
reportable
release
is
expected
to
perform
the
following
activities:
(
1)
gather
necessary
release
data,
such
as
the
time,
date,
quantity,
and
source
of
the
release;
(
2)
notify
the
facility
manager
of
the
release;
(
3)
consult
with
the
environmental
compliance
expert
regarding
the
release;
(
4)
report
the
release
by
telephone
to
the
NRC;
and
(
5)
keep
a
log
of
release
data
such
as
time,
date,
and
circumstance
of
the
release.
(
A
respondent
is
not
required
to
keep
a
log
of
release
data
under
the
episodic
release
notification
regulation,
however
EPA
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February
23,
2001
Page
10
assumes
respondents
will
keep
a
log
of
release
data.)
Cost
and
burden
estimates
associated
with
completing
these
activities
assume
that
respondents
will
telephone
the
NRC
with
23,726
release
notifications
per
annum
between
September
1,
2000
through
August
31,
2003.

Exhibit
1
presents
a
summary
of
the
unit
burden
hours
associated
with
reporting
a
typical
release
to
the
NRC.
The
burden
associated
with
the
first
collection
activity
in
Exhibit
1,
"
Initial
Telephone
Call
to
the
NRC,"
includes
the
burden
of
gathering
of
data
on
the
release,
notifying
the
facility
manager
of
the
release,
and
consulting
with
an
environmental
compliance
expert
regarding
the
release.
EPA
has
estimated
that
the
respondent's
burden
hours
for
reporting
a
typical
release
is
4.1
hours.

Exhibit
1
Unit
Burden
Hours
for
Reporting
a
Typical
Release
to
the
NRC
Collection
Activity
Burden
Hours
Total
Burden
Hours
Managerial
Technical
Clerical
Initial
Telephone
Call
to
the
NRC
1.0
1.0
0.0
2.0
Recordkeeping
0.1
1.0
1.0
2.1
Total
1.1
2.0
1.0
4.1
Initial
Telephone
Notification
In
estimating
the
burden
to
industry
that
the
regulations
implementing
CERCLA
section
103(
a)
and
CWA
section
311
may
impose,
EPA
has
assumed
that
the
respondent's
initial
telephone
notification
to
the
NRC
regarding
a
release
requires
approximately
one
hour
of
technical
personnel
time
and
one
hour
of
managerial
time.
Therefore,
in
this
ICR,
as
in
the
previous
ICR,
EPA
assumes
two
burden
hours
for
the
initial
telephone
notification.
This
burdenhour
estimate
was
confirmed
through
telephone
conversations
with
facilities
that
reported
releases
to
the
NRC.
Facilities
generally
agreed
that
the
time
required
to
evaluate
a
release
will
vary,
depending
on
the
nature
of
the
release.
Most
of
the
facilities
stated
that
the
evaluation
was
relatively
straightforward,
requiring
well
under
one
hour.
One
facility
stated
that
evaluating
a
release
and
determining
if
the
release
should
be
reported
to
the
NRC
could
require
as
many
as
four
hours
of
a
single
technical
expert's
time.
Other
facilities
responded
that
it
would
probably
take
15
minutes
to
½
hour
of
managerial
time
to
determine
whether
a
call
to
the
NRC
was
required.
In
general,
most
facilities
agreed
that,
on
average,
two
to
three
person­
hours
was
a
reasonable
estimate
for
the
time
required
to
determine
the
need
to
report
the
release
to
the
NRC.
Therefore,
in
this
ICR,
as
in
the
previous
ICR,
the
assumption
is
made
that
the
burden
of
the
telephone
call
for
each
reportable
release
is
two
hours
(
composed
of
one
hour
of
management's
time
and
one
hour
of
technician's
time),
regardless
of
the
environmental
medium
affected
and
the
substance
released.

Recordkeeping
2
Two
Bureau
of
Labor
Statistics'
news
releases
were
used
to
calculate
March
2000
hourly
wage
rates
for
civilian
managerial,
technical,
and
clerical
workers.
A
Bureau
of
Labor
Statistics'
news
release
from
June
24,
1999
entitled
"
Employer
Costs
for
Employer
Compensation
­
March
1999"
listed
hourly
compensation
(
wages
and
salaries
plus
fringe
benefits)
rates
for
civilian
managerial,
technical,
and
clerical
workers
for
March
1999.
The
Employment
Cost
Index
for
March
2000,
which
allowed
for
the
conversion
of
March
1999
hourly
wage
rates
to
March
2000
hourly
wage
rates,
was
found
in
a
Bureau
of
Labor
Statistics'
news
release
entitled
"
Employment
Cost
Index
­
March
2000"
from
April
27,
2000.

The
conversion
of
March
1999
hourly
compensation
rates
for
civilian
managerial,
technical,
and
clerical
workers
to
March
2000
hourly
wage
rates
required
two
steps.
First,
March
1999
hourly
compensation
rates
for
civilian
managerial,
technical,
and
clerical
workers
were
multiplied
by
a
factor
of
1.5
to
account
for
overhead
and
general
and
administrative
costs.
Second,
the
March
1999
hourly
wage
rates
(
wages
and
salaries
plus
fringe
benefits
plus
overhead
costs
plus
general
and
administrative
costs)
were
inflated
to
March
2000
hourly
wage
rates
by
using
the
March
2000
Employment
Cost
Index.
Therefore
the
wage
rates
used
in
this
ICR
include
salaries,
fringe
benefits,
overhead
costs
and
general
and
administrative
costs
as
of
March
2000.

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2001
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Although
neither
CERCLA
nor
the
CWA
requires
that
records
of
releases
be
kept,
EPA
assumes
that
a
facility
would
keep
a
log
of
any
calls
made
to
government
organizations.
Such
a
log
would
be
useful
for
managers
in
establishing
that
the
notification
requirements
of
CERCLA
section
103(
a)
and
CWA
section
311
have
been
met.
The
log
might
include
a
description
of
the
incident
and
its
cause,
the
NRC/
ERNS
report
number,
a
brief
account
of
any
conversations
with
Federal
officials,
and
a
description
of
the
outcome
of
the
incident,
including
any
cleanup
action
taken.
The
burden
associated
with
internal
recordkeeping
is
estimated
at
one
technical
hour
and
one
clerical
hour
per
release.
Further,
a
ratio
of
one­
tenth
managerial
hour
to
each
hour
of
clerical
time
is
also
assumed.
Therefore,
in
this
ICR,
as
in
the
previous
ICR,
EPA
assumes
2.1
burden
hours
per
release
for
recordkeeping.

Response
Actions
Under
section
103(
a)
of
CERCLA
and
section
311
of
CWA
facilities
and
vessels
responsible
for
a
release
are
required
to
take
appropriate
action
to
clean
up
the
release.
However,
because
there
is
no
paperwork
burden
associated
with
these
response
actions,
the
capital
and
labor
costs
associated
with
response
actions
are
not
within
the
scope
of
this
ICR.

6(
b)
Estimating
Respondent
Costs
Labor
Costs
The
estimated
cost
to
a
respondent
for
evaluating
a
release
and
calling
the
NRC
regarding
the
release
are
a
function
of
the
time
expended
by
respondent
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
March
2000
and
were
obtained
from
the
Bureau
of
Labor
Statistics.
2
For
purposes
of
this
analysis,
EPA
estimates
an
average
hourly
respondent
labor
cost
of
$
55.34
for
managerial
staff,
$
40.05
for
technical
staff,
and
$
26.02
for
OMB
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February
23,
2001
Page
12
clerical
staff.

These
rates
reflect
employer
cost
for
employee
compensation
in
the
United
States
as
of
March
2000
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.

Annual
Capital
and
Operation
&
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
this
regulation.

Operation
and
Maintenance
(
O&
M)
costs
are
those
costs
associated
with
paperwork
requirements
incurred
continually
over
the
life
of
the
ICR.
EPA
does
not
anticipate
that
respondents
will
incur
O&
M
costs
in
carrying
out
the
information
collection
requirements
of
the
proposed
rule.

Costs
associated
with
the
burden
hours
presented
in
section
6(
a)
of
this
ICR
are
shown
in
Exhibit
2.

Exhibit
2
Unit
Cost
for
Reporting
a
Typical
Release
to
the
NRC
Collection
Activity
Burden
Hours
Unit
Capital/
Start
Up
Cost
Unit
O&
M
Cost
Total
Unit
Cost
Managerial
($
55.34/
Hour)
Technical
($
40.05/
Hour)
Clerical
($
26.02/
Hour)

Initial
Telephone
Notification
to
the
NRC
1.0
1.0
0.0
$
0.00
$
0.00
$
95.39
Recordkeeping
0.1
1.0
1.0
$
0.00
$
0.00
$
71.60
Total
1.1
2.0
1.0
$
0.00
$
0.00
$
166.99
For
a
typical
release,
EPA
has
estimated
that
it
costs
the
respondent
$
166.99
to
report
the
release
to
the
NRC
and
record
the
release
data
in
the
respondent's
log.

6(
c)
Estimating
Agency
Burden
and
Cost
Federal
government
authorities
are
expected
to
perform
the
following
activities
under
the
episodic
release
notification
regulation:
(
1)
process
respondent
telephone
notifications
of
a
release;
(
2)
monitor
cleanup
activities;
and
(
3)
conduct
field
response
actions.
EPA
estimates
that
3
This
hourly
wage
estimate
was
calculated
by
summing
the
basic
hourly
wage
rate
for
a
GS­
12
step
1
government
employee
in
2000
($
22.50)
and
the
hourly
monetary
value
of
the
representative
employee's
fringe
benefits
(
assumed
to
be
the
basic
hourly
wage
rate
multiplied
by
60
percent).

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February
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2001
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13
only
the
first
Federal
government
activity
listed
above,
"
process
telephone
notifications,"
will
involve
the
processing
of
submitted
paperwork.
Estimated
unit
burden
hours
and
costs
and
total
annual
burden
hours
and
costs
for
the
"
process
telephone
notifications"
activity
are
presented
in
Exhibit
3.
For
the
period
covered
by
this
ICR,
EPA
has
assumed
that
the
Federal
government
average
hourly
labor
cost
is
$
36.00.3
Exhibit
3
Agency
Burden
Hours
and
Costs
for
Processing
a
Telephone
Notification
Collection
Activity
Number
of
Reportable
Releases/
Year
Unit
Burden
Hours
Unit
Capital/
Start
Up
Cost
Unit
O&
M
Cost
Total
Unit
Cost
Total
Annual
Burden
Hours
Total
Annual
Cost
Processing
Telephone
Notification
23,726
1.0
$
0.00
$
0.00
$
36.00
23,726
$
854,136
Processing
Telephone
Notification
The
total
burden
of
processing
a
telephone
notification
of
a
release
consists
of
the
time
the
NRC
uses
to
(
1)
communicate
with
the
respondent,
(
2)
record
and
enter
the
information
provided
in
the
telephone
call
into
the
NRC
data
base,
and
(
3)
contact
the
predesignated
EPA
or
Coast
Guard
OSC
or
other
parties
by
telephone.
EPA
has
estimated
that
one
hour
is
needed
to
complete
all
the
activities
associated
with
processing
an
initial
telephone
notification.
Therefore,
the
unit
cost
associated
with
processing
an
initial
telephone
call
is
$
36.00
(
1
hour
x
$
36.00
per
hour
=
$
36.00).

Response
Activities
For
some
percentage
of
releases,
the
information
provided
in
the
telephone
notification
will
prompt
EPA
to
monitor
cleanup
activities.
Monitoring
a
cleanup
will
allow
EPA
to
directly
assess
and
evaluate
the
circumstances
surrounding
the
release,
and
the
population
and
environment
potentially
affected
by
the
release.
In
a
small
percentage
of
cases,
the
owner/
operator
will
be
unable
to
respond
to
the
release
or
cleanup
activities
will
appear
unsatisfactory,
requiring
EPA
to
conduct
its
own
field
response
actions
to
ensure
that
all
potential
hazards
have
been
addressed
and
that
the
release
has
been
thoroughly
cleaned
up.
However,
as
these
actions
are
not
directly
related
to
the
processing
of
submitted
paperwork,
the
costs
and
burden
hours
associated
with
these
actions
are
not
covered
under
this
ICR.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
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February
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2001
Page
14
ERNS
data
from
1997,
1998,
and
1999
were
used
to
estimate
the
number
of
releases
that
will
be
reported
to
the
NRC
during
the
period
of
September
1,
2000
through
August
31,
2003.
The
exhibits
in
this
section
show
projected
annual
release
reports,
burden
hours,
and
costs.

The
total
cost
and
total
burden
estimates
presented
in
this
ICR
are
the
aggregate
annual
costs
and
burden
hours
associated
with
reporting
all
hazardous
substances
and
oil
releases
pursuant
to
CERCLA
section
103(
a)
and
CWA
section
311.

Annual
respondent
burden
hours
are
equal
to
the
number
of
releases
reported
to
the
NRC
in
a
year
multiplied
by
the
unit
burden
hours
associated
with
reporting
a
release.
Annual
cost
is
equal
to
the
number
of
releases
reported
to
the
NRC
in
a
year
multiplied
by
the
unit
cost
of
reporting
a
release.
Exhibit
4
presents
the
annual
total
annual
burden
hour
and
cost
estimates
for
respondents.

Exhibit
4
Estimated
Annual
Burden
Hours
and
Costs
Incurred
by
Industry
Collection
Activity
Number
of
Reportable
Releases
/
Year
Unit
Burden
Hours
Unit
Cost
Burden
Hours
Annual
Cost
Telephone
Notification
23,726
2.0
$
95.39
47,452
$
2,263,223
Recordkeeping
23,726
2.1
$
71.60
49,825
$
1,698,782
Total
23,726
4.1
$
166.99
97,277
$
3,962,005
6(
e)
Bottom
Line
Burden
Hours
and
Costs
Exhibits
3
and
4
present
the
annual
burden
hours
and
costs
incurred
by
the
government
and
respondents,
respectively,
for
all
information
collection
requirements
covered
in
this
ICR.
Exhibit
5
summarizes
the
bottom­
line
burdens
and
costs
incurred
by
both
respondents
and
government.
The
bottom­
line
burden
to
respondents
is
approximately
97,277
hours
per
year,
at
a
cost
of
$
3,962,005.
The
bottom
line
burden
to
the
government
is
approximately
23,726
hours
per
year,
at
a
cost
of
$
854,136.

Exhibit
5
Estimated
Annual
Burden
Hours
and
Costs
for
Information
Collection
Under
CERCLA
Section
103(
a)
and
CWA
Section
311
Economic
Sector
Burden
Hours
Cost
Industry
97,277
$
3,962,005
Government
23,726
$
854,136
Total
121,003
$
4,816,141
OMB
SUBMITTAL***
February
23,
2001
Page
15
6(
f)
Reasons
for
Change
in
Burden
Compared
to
the
previous
ICR,
unit
burden
hours
for
industry
and
the
government
have
not
changed
in
this
ICR.
However,
total
annual
burden
hours
for
industry
and
government
have
decreased
in
this
ICR
because
the
projected
number
of
release
notifications
per
annum
is
this
ICR
is
lower
than
the
projected
number
of
release
notifications
per
annum
in
the
previous
ICR.
The
previous
ICR
projected
29,204
releases
would
be
reported
to
the
NRC
annually,
while
this
renewal
ICR
projects
23,726
releases
will
be
reported
to
the
NRC
annually.
Therefore,
total
annual
burden
hours
for
industry
and
EPA
is
25,083
and
5,478
hours
lower,
respectively,
in
this
ICR
when
compared
to
the
previous
ICR.

Exhibit
6
Summary
of
Total
Burden
Hour
Change
Between
This
ICR
and
the
Previous
ICR
This
ICR
Previous
ICR
Difference
Number
of
Releases
Projected
to
be
Reported
to
NRC
Over
Three­
Year
Period
23,726
29,204
(
5,478)

Annual
Industry
Burden
Hours
97,277
122,360
(
25,083)

Annual
Government
Burden
Hours
23,726
29,204
(
5,478)

6(
g)
Burden
Statement
The
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
approximately
4.1
hours
per
release,
which
includes
2.0
hours
of
reporting
and
2.1
hours
of
recordkeeping
per
release.
This
estimate
includes
the
time
for
gathering
the
required
release
information,
contacting
the
NRC
about
the
release,
and
keeping
a
log.

Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Director,
Collection
Strategies
Division,
U.
S.
OMB
SUBMITTAL***
February
23,
2001
Page
16
Environmental
Protection
Agency
(
2822),
1200
Pennsylvania
Ave.,
NW,
Washington,
D.
C.
20460;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
and
OMB
control
number
in
any
correspondence.
