RENEWAL
OF
INFORMATION
COLLECTION
REQUEST
FOR
NOTIFICATION
OF
EPISODIC
RELEASES
OF
OIL
AND
HAZARDOUS
SUBSTANCES
May
13,
2004
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
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b)
Short
Characterization
and
Abstract
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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
Required
Prior
to
ICR
Submission
to
OMB
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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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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
(
ii)
Respondent
Activities
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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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16
APPENDIX
A
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Phone­
Log
Summaries
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18
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
4a
Estimated
Annual
Burden
Hours
and
Costs
Incurred
by
Industry
(
Exhibit
4
from
ICR
supporting
statement
1049.09)
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14
Exhibit
4b
Estimated
Annual
Burden
Hours
and
Costs
Incurred
by
Industry
(
Corrected
Exhibit
4
from
ICR
supporting
statement
1049.09)
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15
Exhibit
5
Estimated
Annual
Burden
Hours
and
Costs
for
Information
Collection
Under
CERCLA
Section
103(
a)
and
CWA
Section
311
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15
Exhibit
6
Summary
of
Total
Burden
Hour
Change
Between
This
ICR
and
the
Previous
ICR
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16
OMB
SUBMITTAL***
May
13,
2004
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.
1049.10.

l(
b)
Short
Characterization
and
Abstract
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,
2003
through
August
31,
2006.
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
2000,
2001,
and
2002.
The
source
of
the
number
of
NRC
release
notifications
is,
NRC
Statistics
­
Incident
Types,
and
can
be
found
at:
http://
www.
nrc.
uscg.
mil/
incident97­
02.
html.
For
the
purposes
of
this
ICR
(
1049.10),
the
following
incident
types
are
included
in
the
totals
for
release
notifications:
fixed,
unknown
sheen,
vessel,
storage
tank,
railroad,
aircraft,
and
unknown.
The
NRC
received
22,817
release
notifications
in
2000,
25,644
in
2001,
and
23,784
in
2002.
Therefore,
assuming
the
years
2000,
2001,
and
2002
are
representative
of
the
period
covered
by
this
ICR
(
1049.10),
the
NRC
is
estimated
to
receive,
on
average,
24,082
release
notifications
per
annum
between
September
1,
2003
through
August
31,
2006.
In
the
previous
ICR
(
1049.09)
the
per
annum
estimate
for
the
number
of
release
notifications
received
by
the
NRC
was
23,726.

OMB
SUBMITTAL***
May
13,
2004
Page
2
During
the
three­
year
period
covered
by
this
ICR
(
1049.10),
it
is
estimated
that
the
NRC
will
receive
24,082
release
notifications
(
i.
e.,
hazardous
substance
release
and
oil
discharge
notifications)
per
annum.
1
Assuming
24,082
release
notifications
per
annum,
the
total
annual
burden
to
respondents
is
estimated
to
be
approximately
98,736
hours,
at
a
cost
of
$
7,230,537.
The
total
annual
burden
to
the
government
associated
with
24,082
release
notifications
is
estimated
to
be
approximately
24,082
hours,
at
a
cost
of
$
950,998.

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.
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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
the
NRC's
website
(
http://
www.
nrc.
uscg.
mil/
nrchp.
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
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2004
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.
Permitting
regulations
often
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
must
be
reported
to
both
the
applicable
Federal
or
State
permitting
authority
and
NRC.
However,
the
purpose
and
timing
of
the
two
reports
often
differ.
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.
In
contrast,
Federal
officials
use
release
information
provided
to
the
NRC
to
evaluate
the
release
situation
and
determine
if
a
government
response
is
necessary.
Thus,
the
notification
in
monthly
monitoring
reports
that
a
permit
is
exceeded
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
(
1049.10).
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
immediately
alerted
to
potentially
dangerous
releases
of
hazardous
substances
that
may
pose
a
threat
to
public
health
or
welfare
or
the
environment.
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2004
Page
5
3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
In
compliance
with
the
Paperwork
Reduction
Act
(
44
U.
S.
C.
3501
et
seq.),
EPA
requested
comment
from
the
public
through
the
Federal
Register
notice
on
the
renewal
of
this
ICR
(
1049.10).
The
public
EDocket
Number
for
the
notice
is
SFUND­
2000­
0009,
and
can
be
accessed
at
(
http://
www.
epa.
gov/
edocket/).
On
December
12,
2003
(
68
FR
69397),
EPA
sought
comments
on
this
ICR.
There
were
no
comments
received.

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
(
1049.10).
Workgroups
were
used
to
develop
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
were
addressed
in
the
relevant
Response
to
Comments
Documents
and
in
the
preambles
to
the
respective
final
rules.

In
addition
to
Workgroup
activities,
EPA
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.

For
this
renewal,
several
individuals
(
fewer
than
9)
responsible
for
making
notifications
to
the
NRC
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
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
(
1049.10)
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
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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.

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
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May
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2004
Page
7
release,
and
the
telephone
number
of
the
releaser;


The
location
of
the
release;


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
(
1049.10).

(
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;
2This
verification
was
not
repeated
for
this
ICR.
It
is
assumed
to
remain
the
same.

OMB
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2004
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8

Notify
the
facility
manager
of
the
release;


Consult
with
the
environmental
compliance
expert
regarding
the
release;


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
19942.
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.
html.
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.

With
respect
to
OMB's
Terms
of
Clearance
(
ICR
1049.09),
EPA
was
directed
to
promptly
make
any
necessary
adjustments
to
the
ICR
if
and
when
any
changes
are
made
to
the
OMB
SUBMITTAL***
May
13,
2004
Page
9
definition
of
"
federally
permitted
releases."
No
changes
to
that
definition
were
made
by
EPA.

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.

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
OMB
SUBMITTAL***
May
13,
2004
Page
10
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
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
24,082
release
notifications
per
annum
between
September
1,
2003
through
August
31,
2006.

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
(
1049.10),
as
in
the
previous
ICR
(
1049.09),
EPA
assumes
two
burden
hours
for
the
initial
telephone
notification.
This
burden­
hour
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
3
Bureau
of
Labor
Statistics'
news
release
dated,
August
26,
2003,
entitled,
"
Employer
Costs
for
Employee
Compensation
­
June
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
(
1049.10)
include
salaries,
fringe
benefits,
overhead
costs
and
general
and
administrative
costs
as
of
June
2003.

OMB
SUBMITTAL***
May
13,
2004
Page
11
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
(
1049.10),
as
in
the
previous
ICR
(
1049.09),
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
Although
neither
CERCLA
nor
the
CWA
requires
that
records
of
releases
be
kept,
EPA
assumes
that
a
facility
will
keep
a
log
of
any
calls
made
to
government
organizations.
Such
a
log
will
be
useful
for
managers
in
establishing
that
the
notification
requirements
of
CERCLA
section
103(
a)
and
CWA
section
311
have
been
met.
The
log
may
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
(
1049.10),
as
in
the
previous
ICR
(
1049.09),
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
(
1049.10).

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
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
June
2003
and
were
obtained
from
the
Bureau
of
Labor
Statistics.
3
For
purposes
of
this
analysis,
EPA
estimates
an
average
hourly
respondent
labor
cost
of
$
43.74
for
managerial
staff,
$
30.18
for
technical
staff,
and
$
19.22
for
clerical
staff.
OMB
SUBMITTAL***
May
13,
2004
Page
12
These
rates
reflect
employer
cost
for
employee
compensation
in
the
United
States
as
of
June
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.

(
ii)
Estimating
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
(
1049.10)
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
($
43.74/
Hour)
Technical
($
30.18/
Hour)
Clerical
($
19.22/
Hour)

Initial
Telephone
Notification
to
the
NRC
1.0
1.0
0.0
$
0.00
$
0.00
$
73.92
Recordkeeping
0.1
1.0
1.0
$
0.00
$
0.00
$
53.77
Total
1.1
2.0
1.0
$
0.00
$
0.00
$
127.69
For
a
typical
release,
EPA
has
estimated
that
it
costs
the
respondent
$
127.69
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
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
4
This
hourly
wage
estimate
was
calculated
by
summing
the
basic
hourly
wage
rate
for
a
GS­
12
step
1
government
employee
in
2003
($
24.68)
and
the
hourly
monetary
value
of
the
representative
employee's
fringe
benefits
(
assumed
to
be
the
basic
hourly
wage
rate
multiplied
by
60
percent).

OMB
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May
13,
2004
Page
13
Exhibit
3.
For
the
period
covered
by
this
ICR
(
1049.10),
EPA
has
assumed
that
the
Federal
government
average
hourly
labor
cost
is
$
39.49.4
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
24,082
1.0
$
0.00
$
0.00
$
39.49
24,082
$
950,998
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
$
39.49
(
1
hour
x
$
39.49
per
hour
=
$
39.49).

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
(
1049.10).

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
ERNS
data
from
2000,
2001,
and
2002
were
used
to
estimate
the
number
of
releases
that
will
be
reported
to
the
NRC
during
the
period
of
September
1,
2003
through
August
31,
2006.
The
exhibits
in
this
section
show
projected
annual
release
reports,
burden
hours,
and
costs.
OMB
SUBMITTAL***
May
13,
2004
Page
14
The
total
cost
and
total
burden
estimates
presented
in
this
ICR
(
1049.10)
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
24,082
2.0
$
73.92
48,164
$
3,560,283
Recordkeeping
24,082
2.1
$
53.77
50,572
$
2,719,256
Total
24,082
4.1
$
127.69
98,736
$
6,279,539
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
(
1049.10).
Exhibit
5
summarizes
the
bottom­
line
burdens
and
costs
incurred
by
both
respondents
and
government.
The
bottom­
line
burden
to
respondents
is
approximately
98,736
hours
per
year,
at
a
cost
of
$
6,279,539.
The
bottom
line
burden
to
the
government
is
approximately
24,082
hours
per
year,
at
a
cost
of
$
950,998.

It
appears
that
there
is
a
significant
increase
in
the
bottom­
line
cost
burden
to
respondents
from
the
previous
ICR
(
1049.09).
In
that
ICR
(
1049.09),
the
bottom­
line
cost
to
respondents
was
estimated
at,
$
3,962,005.
Unfortunately
there
was
a
calculation
error
in
that
estimate
that
was
identified
and
corrected
for
this
ICR
(
1049.10).
The
following
Exhibit
4a
is
a
reprint
from
the
previous
ICR
(
1049.09):

Exhibit
4a
Estimated
Annual
Burden
Hours
and
Costs
Incurred
by
Industry
(
Exhibit
4
from
ICR
supporting
statement
1049.09)

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
OMB
SUBMITTAL***
May
13,
2004
Page
15
Total
23,726
4.1
$
166.99
97,277
$
3,962,005
Note
that
the
calculation
for
annual
cost
multiplied
the
"
Number
of
Reportable
Releases/
Year"
by
the
"
Unit
Cost"
instead
of
"
Unit
Cost"
by
"
Burden
Hours."
The
corrected
Exhibit
4b
appears
below:

Exhibit
4b
Estimated
Annual
Burden
Hours
and
Costs
Incurred
by
Industry
(
Corrected
Exhibit
4
from
ICR
supporting
statement
1049.09)

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
$
4,526,446
Recordkeeping
23,726
2.1
$
71.60
49,825
$
3,567,470
Total
23,726
4.1
$
166.99
97,277
$
8,093,916
The
estimated
annual
burden
cost
should
have
been
reported
as
$
8,093,916,
rather
than
the
$
3,962,005
actually
reported
for
the
previous
ICR
(
1049.09).

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
98,736
$
6,279,539
Government
24,082
$
950,998
Total
122,818
$
7,230,537
6(
f)
Reasons
for
Change
in
Burden
Compared
to
the
previous
ICR
(
1049.09),
unit
burden
hours
for
industry
and
the
government
have
not
changed
in
this
ICR
(
1049.10).
However,
total
annual
burden
hours
for
industry
and
government
have
increased
in
this
ICR
(
1049.10)
because
the
projected
number
of
release
notifications
per
annum
in
this
ICR
(
1049.10)
is
higher
than
the
projected
number
of
release
notifications
per
annum
in
the
previous
ICR
(
1049.09).
The
previous
ICR
(
1049.09)
projected
23,726
releases
would
be
reported
to
the
NRC
annually,
while
this
renewal
ICR
(
1049.10)
projects
24,082
releases
will
be
reported
to
the
NRC
annually.
Therefore,
comparing
this
ICR
(
1049.10)
to
the
previous
ICR
(
1049.09),
total
annual
burden
hours
for
industry
increase
by
1,459
hours
and
for
EPA
by
356
hours.

Although
this
ICR
(
1049.10)
projects
an
increase
in
the
number
of
releases
reported
to
the
NRC
annually,
decreases
in
the
unit
costs
to
responders
for
managerial,
technical
and
clerical
labor
categories
results
in
an
overall
reduced
cost
burden
for
industry.
The
previous
ICR
5See
corrected
calculation
in
Exhibit
4b.

OMB
SUBMITTAL***
May
13,
2004
Page
16
(
1049.09)
estimated
the
cost­
burden
to
industry
as
$
8,093,9165,
this
renewal
estimates
the
costburden
to
industry
will
be
$
7,230,537
or
$
863,379
less
than
the
previous
estimate.
The
estimated
government
unit
cost
increased
and
therefore
the
cost
burden
for
government
is
projected
to
increase,
from
$
854,136
to
$
950,998
an
increase
of
$
96,862.

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
72,246
71,178
1,068
Annual
Industry
Burden
Hours
98,736
97,277
1,459
Annual
Government
Burden
Hours
24,082
23,726
356
6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
approximately
4.1
hours
per
response,
which
includes
2.0
hours
of
reporting
and
2.1
hours
per
response.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
and
48
CFR
chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
SFUND­
2000­
0009,
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
OMB
SUBMITTAL***
May
13,
2004
Page
17
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
0009)
and
OMB
control
number
(
2050­
0046)
in
any
correspondence.
OMB
SUBMITTAL***
May
13,
2004
Page
18
APPENDIX
A
­
Phone­
Log
Summaries
The
following
calls
were
made
between
April
27,
2004
and
May
12,
2004.
The
companies
were
selected
from
the
universe
of
facilities
for
which
a
release
of
a
hazardous
substance
at
or
above
an
RQ
to
the
NRC
was
reported.
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.
Because
the
reporting
party
is
not
public
information,
the
information
summarized
below
is
about
the
suspected
responsible
party.
Additional
information
about
the
reported
incident
can
be
obtained
through
the
NRC's
web
site,
specifically
at:
http://
www.
nrc.
uscg.
mil/
wdbcgi/
wdbcgi.
exe/
WWWUSER/
WEBDB.
foia_
query.
show_
parms.

BP
Chemicals
Private
Enterprise
Lima,
OH
Incident
Report
#
712468
On
February
5,
2004,
BP
Chemicals
accidentally
released
100
pounds
of
acrylonitrile.
On
May
13,
2004,
spoke
with
the
person
responsible
for
developing
procedures
for
reporting
releases.
The
facility
has
procedures
in
place
and
believes
EPA's
burden
estimates
are
reasonable.
The
company
spokesperson
did
not
have
any
questions
about
the
reporting
process.

Wayne
Farms
LLC
Private
Enterprise
Jack,
AL
Incident
Report
#
716028
On
March
15,
2004,
Wayne
Farms,
LLC
accidentally
released
an
unknown
amount
of
anhydrous
ammonia
due
to
equipment
failure
(
power
failure).
As
soon
as
the
actual
amount
(
later
that
day)
of
the
substance
was
known,
that
information
was
sent
via
written
report.
On
May
11,
2004,
spoke
with
the
person
responsible
for
consolidating
communications
for
the
company.
The
company
has
a
crisis
action
system
in
place
to
address
regulatory
requirements.
The
company
keeps
records
of
who
they
talk
to
with
regard
to
submitting
reports.
The
company
spokesperson
confirmed
that
EPA's
burden
estimates
were
reasonable.

Sarah
Lee
Bakery
Private
Enterprise
Tarboro,
NC
Incident
Report
#
715999
Left
message,
call
returned
April
28,
2004
OMB
SUBMITTAL***
May
13,
2004
Page
19
On
March
15,
2004,
Sarah
Lee
Bakery
accidentally
released
20
pounds
of
anhydrous
ammonia
due
to
a
faulty
gasket
on
a
3
way
valve.
On
April
28,
2004,
spoke
with
the
person
responsible
for
making
the
report
to
the
NRC.
Generally,
most
plants
are
running
as
trim
as
possible.
When
there
is
a
leak
or
release,
the
first
priority
is
to
stop
it.
Having
to
stop
to
report
the
release
is
an
issue.
Little
nuisance
leaks
are
problematic
because
they
have
to
report.
Responder
said
that
he
reports
releases
within
15
minutes.

Westlake
Vinyls,
Inc
Private
Enterprise
Calvert
City,
KY
Incident
Report
#
716614
On
March
21,
2004,
a
release
of
an
unknown
amount
of
ethylene
dichloride
was
reported
from
the
facility.
On
May
11,
2004,
spoke
with
the
individual
responsible
for
making
the
notification
regarding
notification
procedures
and
burden
estimates.
Burden
estimates
are
reasonable.
The
facility
has
plans
in
place
to
report
episodic
releases
to
the
NRC
with
followup
reports
to
the
state
and
local
authorities.
The
individual
did
not
have
any
questions.
