SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
Cooperative
Agreements
and
Superfund
State
Contracts
for
Superfund
Response
Actions
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
Cooperative
Agreements
and
Superfund
State
Contracts
for
Superfund
Response
Actions
1(
b)
Short
Characterization/
Abstract
This
is
a
request
for
a
renewal
of
an
existing
Information
Collection
Request
(
ICR)
due
to
expire
on
September
30,
2004.
The
title
of
this
submission
is:
"
Cooperative
Agreements
and
Superfund
State
Contracts
for
Superfund
Response
Actions."
This
ICR
authorizes
the
collection
of
information
under
EPA's
Superfund
Rule
at
40
CFR
35,
Subpart
O,
that
establishes
the
administrative
requirements
for
CERCLA­
funded
cooperative
agreements
for
State,
political
subdivisions,
and
Federally­
recognized
Indian
Tribes
and
Tribal
Consortia
response
actions.
The
regulation
includes
only
those
provisions
mandated
by
CERCLA,
required
by
OMB
circulars,
or
added
by
EPA
to
ensure
sound
and
effective
financial
assistance
management
under
this
regulation.
The
information
is
collected
from
applicants
and/
or
recipients
of
EPA
assistance
and
is
used
to
make
awards,
pay
recipients,
and
collect
information
on
how
Federal
funds
are
being
utilized.
EPA
requires
this
information
to
meet
its
Federal
stewardship
responsibilities.
Recipient
responses
are
required
to
obtain
a
benefit
(
Federal
funds)
under
40
CFR
Part
31,
"
Uniform
Administrative
Requirements
for
Grants
and
Cooperative
Agreements
to
State
and
Local
Governments"
and
under
40
CFR
Part
35,
"
State
and
Local
Assistance."

It
is
estimated
that
the
information
collection
will
involve
581
respondents
and
impose
a
burden
of
6,062.5
hours
and
$
215,340.
The
previously
approved
ICR
was
approved
without
any
terms
of
clearance.

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
This
ICR
is
necessary
due
to
the
information
collection
and
reporting
requirements
in
the
Superfund
rule
40
CFR
Part
35,
Subpart
O,
"
Cooperative
Agreements
and
Superfund
State
Contracts
for
Superfund
Response
Actions."
Due
to
the
statutory
cost
recovery
requirements
in
CERCLA
and
the
need
to
carefully
track
all
costs,
Superfund
recipients
must
comply
with
administrative
requirements
sufficient
to
meet
these
provisions
of
the
law.
The
regulation
sets
2
forth
the
pre­
award,
post­
award,
and
post­
cooperative
agreement
requirements
which
are
conditions
for
receiving/
managing
a
Superfund
cooperative
agreement
(
CA)
or
a
Superfund
State
Contract
(
SSC).
This
information
is
needed
by
EPA
project
officers,
grant
specialists,
and
finance
officials
to
manage/
oversee
the
funding
activities
and
cleanup
activities
at
Superfund
sites.
EPA
also
uses
the
information
to
update
the
Comprehensive
Environmental
Response,
Compensation,
and
Liability
Information
System
(
CERCLIS)
which
tracks
progress
made
at
Superfund
sites,
and
to
update
IFMS,
EPA's
database
for
tracking
financial
management.

2(
b)
Practical
Utility/
Users
of
the
Data
The
information
collected
is
used
by
EPA
to
manage
and
administer
cooperative
agreements
and
Superfund
State
Contracts
for
Superfund
response
actions.
The
pre­
award
information
is
used
to
qualify
cooperative
agreement
applicants
and
award
cooperative
agreements.
The
post­
award
information
is
used
to
meet
the
statutory
and
regulatory
requirements
and
monitor
recipient
performance.
The
closeout
information
is
used
to
meet
reporting
and
record
keeping
requirements
necessary
for
cost
recovery
purposes
and
for
closing
out
awards.
The
information
is
necessary
to
ensure
minimum
fiscal
control
and
accountability
for
Superfund
money
to
deter
waste,
fraud,
and
abuse.

40
CFR
Part
35,
Subpart
O,
also
supplements
EPA's
general
assistance
regulation,
40
CFR
Part
31,
"
Uniform
Administrative
Requirements
for
Grants
and
Cooperative
Agreements
to
State
and
Local
Governments."
Part
31,
which
implements
the
requirements
of
OMB
Circular
A­
102,
became
effective
for
awards
made
on
or
after
October
1,
1988.
The
Part
31
rule
(
common
rule)
established
uniformity
among
Federal
agencies
that
award
Federal
grants
and
cooperative
agreements
to
States,
political
subdivisions
thereof,
and
Federally­
recognized
Indian
Tribes
and
Tribal
Consortia.
Many
of
the
information
collection
requirements
for
Superfund
cooperative
agreements
were
approved
under
the
OMB
Paperwork
Clearance
#
2030­
0020
associated
with
40
CFR
Part
31
prior
to
this
ICR.

Due
to
statutory
cost
recovery
requirements,
and
the
need
to
carefully
track
costs
by
site
and
activity,
Superfund
recipients
must
comply
with
all
administrative
requirements
to
satisfy
the
provisions
of
the
law.
There
are
additional
requirements
in
this
regulation,
which
supplements
Part
31,
and
are
necessary
for
effective
cost
recovery
from
potentially
responsible
parties.
States
may
be
able
to
follow
their
own
rules
for
certain
aspects
of
the
program,
such
as
in
procurement,
if
their
administrative
requirements
and
financial
management
capabilities
are
sufficient.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
3(
a)
Nonduplication
All
information
collected
is
used
to
continue
administering
cooperative
agreements
and
Superfund
State
Contracts
for
Superfund
response
actions.
This
data
is
not
available
from
other
sources,
as
it
is
specifically
related
to
the
requirements
of
40
CFR
Part
35,
Subpart
O,
and
the
3
award,
management,
and
closeout
of
cooperative
agreements
and
Superfund
State
Contracts
within
this
program.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
An
announcement
of
a
public
comment
period
for
the
renewal
of
this
ICR
was
published
in
the
Federal
Register
(
69
FR
40369)
on
July
4,
2004.
One
comment
was
received
on
the
burden
published
in
the
Federal
Register.
The
substance
of
this
comment
follows:

"
This
info
collection
should
be
on
an
every
3
year
schedule,
not
every
year,
which
overburdens
taxpayers
to
pay
for
this
wasteful
process.
why
collect
paper
mountains
of
the
same
darn
thing
year
after
year.
especially
when
there
is
no
money
to
fix
them,
with
u.
s.
spending
all
of
its
money
on
2
wars."

EPA
responded
to
this
comment
as
follows:

"
The
paperwork
burden
provided
in
the
ICR
is
only
to
states,
tribes
and
political
subdivisions
of
states,
applying
for
financial
assistance
through
Superfund
to
investigate,
assess
and
clean
up
hazardous
waste
sites.

The
paperwork
burden
for
states,
tribes,
and
political
subdivisions
of
states,
in
the
ICR
consists
exclusively
of
the
time
cost
of
putting
together
a
cooperative
agreement
application
for
a
Superfund
cleanup
activity
and
complying
with
the
requirements
during
the
life
of
the
application
to
ensure
that
Federal
monies
awarded
to
the
recipient
are
used
for
only
regulated
activites
under
40
CFR
Part
35
Subpart
O.
These
monies
are
awarded
based
on
a
number
of
factors
at
90%
Federal
funding
with
a
10%
matching
share
from
the
recipient."

3(
c)
Consultations
This
is
a
request
for
renewal
of
an
information
collection
request,
and
in
addition
to
the
initial
Federal
Register
notice,
the
following
persons
were
contacted
to
provide
additional
input
towards
the
calculation
of
burden
imposed
by
this
ICR:

Jay
Naparstek
­
Chair
State/
Federal
Superfund
Coordinator
&
Section
Chief
Bureau
of
Waste
Site
Cleanup
MA
Dept.
of
Environmental
Protection
One
Winter
St.
Boston,
MA
02108
Terry
Ayers
Division
of
Remediation
Management
4
Illinois
Environmental
Protection
Agency
1021
North
Grand
Avenue
East
P.
O.
Box
19276
Springfield,
IL
62794­
9276
Bob
Soboleski
Site
Remediation
and
Solid
Waste
Program
Div.
of
Remedial
Management
&
Response
NJ
Dept.
of
Environmental
Protection
CN
413
Trenton,
NJ
08625
Hal
Cantwell
Waste
Management
Division
OK
Dept.
of
Environmental
Quality
707
N.
Robinson
Street
P.
O.
Box
1677
(
Mailing
Address)
Oklahoma
City,
OK
73101­
1677
Tom
Gainer
Cleanup
/
Portland
Harbor
Northwest
Region
OR
Department
of
Environmental
Quality
2020
SW
Fourth
Ave.,
Suite
400
Portland,
OR
97201
Andrew
Shivas
Manager,
Voluntary
Cleanup
Program
Division
of
Superfund
TN
Dept.
of
Environment
&
Conservation
401
Church
St.,
L&
C
Annex,
4th
Fl.
Nashville,
TN
37243­
1538
Kevin
Greene
Office
of
Remediation
Programs
VA
Dept.
of
Environmental
Quality
P.
O.
Box
10009
629
E.
Main
St.,
10th
Fl.
Richmond,
VA
23240­
0009
Brent
Everett
CERCLA
Branch
Manager
UT
Dept.
of
Environmental
Quality
5
168
North
1950
West
Salt
Lake
City,
Utah
84116
Sara
Amir
Chief,
Southern
Cleanup
Operations
Site
Remediation
and
Brownfields
Program
CA
Dept.
of
Toxic
Substances
Control
1011
N.
Grandview
Glendale,
CA
91201
Kirby
Biggs
U.
S.
Environmental
Protection
Agency
(
EPA)
Washington,
DC
20460
Carol
Cowgill
U.
S.
Environmental
Protection
Agency
(
EPA)
Washington,
DC
20460
Three
of
the
persons
contacted
responded,
two
of
which
commented
on
the
burdens
presented
in
the
burden
table.
The
remaining
respondent
provided
information
relating
to
application
materials,
rather
than
reporting
and
recordkeeping.
Reviewers
responses
resulted
in
revisions
to
the
burden
calculation
from
the
currently
published
ICR.

3(
d)
Effects
of
Less
Frequent
Collection
There
is
no
fixed
schedule
for
the
collection
of
this
information.
It
is
required
on
an
as
needed
basis
as
stated
in
the
rule
at
40
CFR
Part
35,
Subpart
O,
"
Cooperative
Agreements
and
Superfund
State
Contracts
for
Superfund
Response
Actions."
Therefore,
there
is
no
possibility
that
the
information
can
be
collected
less
frequently
than
required
by
the
regulation.

3(
e)
General
Guidelines
The
information
collection
is
consistent
with
the
guidelines
set
forth
in
5
CFR
1320.5
of
the
Paperwork
Reduction
Act
Guidelines.

3(
f)
Confidentiality
No
sensitive
information
is
expected
to
be
collected
under
this
ICR.
However,
any
information
submitted
to
the
Agency
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
Agency
policies
set
forth
in
Title
40,
Chapter
1,
Part
2,
Subpart
B
­
Confidentiality
of
Business
Information
(
see
40
CFR
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
40000,
September
8,
1978;
43
FR
42251,
September
20,
1978;
44
FR
17674,
March
23,
1979).
6
3(
g)
Sensitive
Questions
None
of
the
information
being
collected
will
contain
sensitive
questions
or
require
collecting
sensitive
information.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
to
the
recordkeeping
and
reporting
requirements
are:

SIC
Codes
NAICS
Codes
Other
General
Government
Support
9119
921190
American
Indian
and
Alaska
Native
Tribal
Governments
8641
92115
4(
b)
Information
Requested
(
i)
Data
Items
Information
requested
 
Information
relating
to
the
following
cooperative
agreement
types
and
Superfund
State
Contracts
will
be
collected
to
ensure
sound
and
effective
financial
assistance
management
and
to
help
EPA
meet
its
Federal
stewardship
responsibilities
under
this
program:

°
Pre­
remedial
cooperative
agreements;
°
Remedial
Response
cooperative
agreements;
°
Enforcement
cooperative
agreements;
°
Removal
cooperative
agreements;
°
Core
Program
cooperative
agreements;
°
Support
Agency
cooperative
agreements;
°
Records
Retention;
°
Superfund
State
Contracts;
°
Conclusion
of
Superfund
State
Contracts;
and
°
Consolidated
Funding.

This
information
will
also
be
used
to
update
and
maintain
both
the
CERCLIS
database,
and
the
IFMS
database.

(
ii)
Respondent
Activities
7
Respondents
will:

°
Prepare
and
submit
cooperative
agreements/
Superfund
State
Contract
application
materials;

°
Conduct
research
and
gather
data
as
needed;
°
Prepare
and
submit
quarterly/
bi­
annual
reports;
°
Prepare
other
standardized
reports;
°
Perform
required
recordkeeping
activities;
°
Respond
to
EPA
requests
for
additional
information;
and
°
Perform
other
activities
as
necessary
as
required
by
40
CFR
Part
35,
Subpart
O.

5.
The
Information
Collected:
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
EPA
will
collect
the
requested
information
using
standardized
reports
and
record
keeping
appropriate
to
support
cost
recovery.
The
grants
information
is
entered
into
GICS,
the
Agency's
database
for
tracking
the
status
of
grant/
cooperative
agreement
actions.
The
technical
(
programmatic)
information
is
entered
into
CERCLIS
the
Agency's
database
for
tracking
the
status
of
all
response
activities
at
Superfund
sites,
and
financial
information
is
entered
into
IFMS,
the
Agency's
database
for
tracking
financial
management.

5(
b)
Collection
Methodology
and
Management
EPA
will
conduct
activities
in
connection
with
the
acquisition,
analysis,
storage,
and
utilization
of
the
requested
cooperative
agreement
and
Superfund
State
Contract­
related
information
and
financial
data.
This
information
and
financial
date
are
reviewed
in
accordance
with
the
requirements
of
40
CFR
Part
35,
Subpart
O.

Superfund
recipients
must
retain
records
for
10
years
following
the
submission
of
the
final
Financial
Status
Report,
and
must
retain
those
records
longer
if
an
enforcement
action
is
ongoing.
This
ensures
that
response
action
information
will
be
available
to
support
EPA
litigation
efforts
to
recover
Superfund
costs
from
responsible
parties.
The
Agency
also
conducts
periodic
on­
site
reviews
to
ensure
recipient
compliance
with
applicable
requirements.

5(
c)
Small
Entity
Flexibility
There
are
no
small
businesses
affected
by
this
information
collection.
Small
Governmental
Jurisdictions
are
affected,
but
the
burden
is
minimal,
and
steps
have
been
taken
to
reduce
the
burden
imposed
by
this
information
collection.
As
40
CFR
Part
35,
Subpart
O
is
a
fully­
funded
8
regulation,
all
burden
imposed
by
the
regulation
is
required
in
order
for
recipients
to
obtain
and
manage
financial
awards.

5(
d)
Collection
Schedule
The
collection
schedule
for
this
information
relating
to
cooperative
agreements
and
Superfund
State
Contracts
is
variable
depending
on
such
factors
as:
date
of
applications,
magnitude
of
efforts,
and
project
periods,
etc.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
1,
"
Total
Respondent
Burden,"
documents
the
computation
of
individual
burdens
for
providing
the
information
required
for
the
application
and
administration
of
each
type
of
cooperative
agreement
and
each
Superfund
State
Contract
included
in
this
ICR.
The
individual
burden
is
expressed
under
a
heading
believed
to
be
consistent
with
the
concept
of
burden
under
the
Paperwork
Reduction
Act.
Responses
to
this
information
collection
are
mandatory,
as
they
are
required
to
property
manage
and
administer
the
funds
awarded
under
cooperative
agreements
and
Superfund
State
Contracts.

The
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.

6(
a)
Estimating
Respondent
Burden
A
"
unit"
burden
is
the
burden
incurred
by
a
respondent
for
performing
a
cooperative
agreement
specific
activity.
States
incur
burdens
under
an
estimated
581
cooperative
agreement
and
Superfund
State
Contract
activities
per
year
for
reporting,
certifications,
schedules,
notifications,
assurances,
and
record
keeping
activities.
The
estimated
burden
is
incurred
by
activities
under
the
following
types
of
cooperative
agreements/
Superfund
State
Contracts
and
other
requirements:

°
Pre­
remedial
cooperative
agreements;
°
Remedial
Response
cooperative
agreements;
°
Enforcement
cooperative
agreements;
°
Removal
cooperative
agreements;
°
Core
Program
cooperative
agreements;
°
Support
Agency
cooperative
agreements;
°
Records
Retention;
°
Superfund
State
Contract;
°
Conclusion
of
Superfund
State
Contracts;
and
°
Consolidated
Funding.
9
The
estimated
average
burden
associated
with
each
cooperative
agreement/
Superfund
State
Contract/
Other
requirement
is
discussed
below
and
summarized
in
Table
1,
"
Total
Respondent
Burden."

The
estimated
burden
associated
with
Pre­
remedial
cooperative
agreements
represents
the
number
of
hours
that
are
spent
in
research,
data
collection,
analysis,
negotiation,
and
preparation
of
the
Pre­
remedial
cooperative
agreement.
EPA
estimates
that
approximately
33
Pre­
remedial
cooperative
agreements
involving
States,
Tribes,
or
political
subdivisions,
will
be
in
place
each
year.
EPA
estimates
that
an
average
of
7
hours
are
necessary
to
prepare
all
the
plans,
compliance
documents,
lists
and
schedules
required
in
the
application
for
this
type
of
cooperative
agreement
within
Subpart
O.

The
estimated
burden
associated
with
Remedial
Response
cooperative
agreements
represents
the
number
of
hours
that
are
spent
in
research,
plan
preparation,
data
collection,
analysis,
and
negotiation
in
preparing
the
materials
required
for
a
Remedial
Response
cooperative
agreements.
EPA
estimates
that
approximately
30
Remedial
Response
cooperative
agreements,
which
involve
States,
Tribes,
and
political
subdivisions,
will
be
in
place
each
year.
EPA
estimates
that
an
average
of
20
hours
are
necessary
to
prepare
all
the
materials
required
in
an
application
for
this
type
of
cooperative
agreements.
Those
materials
include:
a
project
narrative,
which
includes
much
more
site­
specific
information
than
a
project
narrative
for
a
Pre­
remedial
cooperative
agreement;
compliance
documents
and
certifications;
CERCLA
assurances;
and
notifications.
The
majority
of
the
burden
under
this
cooperative
agreement
is
associated
with
the
preparation
of
the
schedule
of
deliverables.
Though
the
format
of
that
schedule
is
fairly
standard,
the
planning
and
negotiation
involved
can
be
time
consuming.

The
estimated
burden
associated
with
Enforcement
cooperative
agreements
represents
the
number
of
hours
that
are
spent
in
research,
plan
and
certification
documentation
preparation,
such
as
the
quality
assurance
plan,
data
collection,
and
analysis
in
the
preparation
of
materials
involved
in
acquiring
and
operating
within
an
Enforcement
cooperative
agreement.
EPA
estimates
that
an
average
of
1
Enforcement
cooperative
agreement
will
be
in
place
each
year.
EPA
also
estimates
that
approximately
43
hours
are
needed
to
fulfill
the
requirements
imposed
by
this
type
of
cooperative
agreement.
Those
requirements
include:
creating
the
site
description;
creating
the
site
specific
statement
of
work;
producing
the
statement
designating
lead
site
project
manager;
creating
the
site
specific
health
and
safety
plan;
producing
the
quality
assurance
plan;
developing
the
schedule
of
deliverables;
and
producing
a
copy
of
the
applicable
state,
local,
or
tribal
statutes.
The
majority
of
the
burden
is
imposed
by
the
creation
of
the
site
specific
statement
of
work,
the
quality
assurance
plan,
and
the
schedule
of
deliverables.

The
estimated
burden
associated
with
Removal
Response
cooperative
agreements
represents
the
number
of
hours
that
are
spent
in
research,
plan
preparation,
data
collection,
analysis,
and
negotiation
in
preparing
the
materials
required
for
a
Removal
Response
cooperative
agreement
EPA
estimates
that
approximately
21
Removal
Response
cooperative
agreements,
which
involve
States,
Tribes,
and
political
subdivisions,
will
be
in
place
each
year.
EPA
estimates
that
an
average
10
of
42
hours
are
necessary
to
prepare
all
the
materials
required
for
this
type
of
cooperative
agreement.
Those
required
materials
include:
a
site
description;
a
site
specific
statement
of
work;
a
statement
designating
lead
site
project
manager;
a
site
specific
community
relations
plan;
a
site
specific
health
and
safety
plan;
a
quality
assurance
plan;
a
schedule
of
deliverables.
Program
experience
has
shown
that
the
majority
of
the
burden
imposed
under
the
requirements
for
this
type
of
cooperative
agreement
can
be
attributed
to
the
development
of
the
schedule
of
deliverables
and
the
quality
assurance
plan.

The
estimated
burden
associated
with
Core
Program
cooperative
agreements
represents
the
number
of
hours
that
are
spent
in
research,
data
collection,
analysis,
and
negotiation
in
preparing
the
materials
required
for
a
Core
Program
cooperative
agreement.
EPA
estimates
that
22
Core
Program
cooperative
agreements,
which
involve
States,
Tribes,
and
political
subdivisions,
will
be
in
place
each
year.
Superfund
program
experience
indicates
that
8
hours
are
needed
to
fulfill
the
requirements
imposed
by
this
type
of
cooperative
agreement.
Those
requirements
include
preparing
a
statement
of
work,
and
a
background
statement.
Those
two
requirements
are
responsible
for
the
majority
of
burden
attributed
to
Core
Program
cooperative
agreements.

The
estimated
burden
associated
with
Support
Agency
cooperative
agreements
represents
the
number
of
hours
that
are
spent
in
research,
data
collection,
analysis,
and
negotiation
in
preparing
the
materials
required
for
a
Support
Agency
cooperative
agreement.
EPA
estimates
that
approximately
45
Support
Agency
cooperative
agreements,
which
involve
States,
Tribes,
and
political
subdivisions,
will
be
in
place
each
year.
EPA
estimates
that
an
average
of
8
hours
are
needed
to
prepare
all
the
materials
required
for
this
type
of
cooperative
agreement.
The
majority
of
the
burden
imposed
by
a
Support
Agency
cooperative
agreement
can
attributed
to
the
development
of
the
required
statement
of
work.
This
burden
has
been
reduced
from
the
last
ICR
due
to
recent
rule
revisions
eliminating
Support
Agency
cost
sharing
for
Federally­
recognized
Indian
Tribes
and
Tribal
Consortia.

The
estimated
burden
associated
with
the
Records
Retention
requirements
represents
the
number
of
hours
that
are
spent
each
year
beyond
the
10
year
(
Superfund)
retention
requirement
for
record
maintenance,
storage,
and
any
document
requests
that
would
be
made
throughout
the
year.
All
cooperative
agreements
must
meet
these
Records
Retention
requirements,
and
incur
the
resulting
burden.
EPA
estimates
that
approximately
375
cooperative
agreements
will
be
in
place
each
year.
Superfund
program
experience
indicates
that
an
average
of
5.5
hours
will
be
required
each
year
to
meet
the
burden
imposed
by
this
regulation's
Records
Retention
requirements.

The
estimated
burden
associated
with
the
contents
of
an
Superfund
State
Contract
represents
the
number
of
hours
that
are
spent
in
research,
data
collection,
analysis,
negotiation,
and
preparation
of
the
Superfund
State
Contract
each
year.
EPA
estimates
that
approximately
52
Superfund
State
Contracts
are
in
place
each
year.
The
Superfund
grants
program
workgroup
estimates
that
30
hours
are
needed
to
meet
the
burden
imposed
by
the
requirements
under
a
Superfund
State
Contract.
Those
requirements
include:
General
Authorities;
Purpose
statement;
site
description;
statement
to
follow
guidance;
statement
of
work;
schedule
of
deliverables;
SPOC;
11
CERCLA
assurances;
list
of
Support
Agency
cooperative
agreements;
sanctions
for
failure
to
comply
with
the
terms
of
the
Superfund
State
Contract;
site
access;
joint
inspection
of
the
remedy;
exclusion
of
third
party
benefits;
State
review;
and
a
list
of
responsible
party
activities.

The
estimated
burden
associated
with
Consolidated
Funding
represents
the
number
of
hours
that
are
spent
in
research,
data
collection,
analysis,
negotiation,
and
preparation
of
Consolidated
Funding
agreements
each
year.
EPA
estimates
that
approximately
2
Consolidated
Funding
agreements
are
in
place
each
year.
EPA
estimates
that
approximately
74
hours
a
year
are
necessary
to
meet
the
requirements
of
a
Consolidated
Funding
agreement.
The
majority
of
the
burden
complying
with
the
requirements
of
this
type
of
agreement
are
due
to
the
fact
that
one
Consolidated
Funding
cooperative
agreement
imposes
the
same
burden
as
three
regular
cooperative
agreements.
This
three­
fold
burden
can
be
attributed
to
the
three­
fold
increase
in
the
paperwork
needed
to
document,
track,
and
respond
to
the
requirements
of
this
type
of
cooperative
agreement.
12
6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
For
all
activities
covered
by
this
ICR,
wage
rates
for
State,
Tribal,
and
political
subdivision
personnel
are
estimated
to
be
comparable
to
those
of
Federal
government
personnel.
These
wage
rates
were
estimated
based
upon
corresponding
Federal
GS
wage
rates
as
of
January
2004.
The
rates,
as
outlined
below
are
multiplied
by
a
1.6
benefits
multiplication
factor
to
account
for
government
overhead
expenses.

Management
GS
13,
step
1
$
48.22/
hour
Technical
GS
11,
step
1
$
33.84/
hour
Clerical
GS
7,
step
1
$
22.86/
hour
These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.
These
rates
can
be
obtained
from
the
OPM
website,
http://
www.
opm.
gov/
oca/
04tables/
html/
gs.
asp.
It
is
further
estimated
that
approximately
20%
of
the
respondent
activity
is
Managerial,
70%
is
Technical,
and
10%
is
Clerical
in
nature.
Based
upon
the
above,
the
weighted
average
is
$
35.52/
hour
[(
48.22*
0.2)+(
33.84*
0.7)+(
22.86*
0.1)].

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
only
type
of
costs
associated
with
this
information
collection
activity
are
labor
costs.
There
is
no
estimated
Capital/
Startup
and
Operation
and
Maintenance
Costs
associated
with
this
collection
of
information.

(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
The
total
capital/
startup
costs
for
this
ICR
are
$
0.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
a),
Total
annualized
capital/
startup
costs.

The
total
operation
and
maintenance
(
O&
M)
costs
for
this
ICR
are
$
0.
This
is
the
total
of
column
G.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
b),
Total
annual
costs
(
O&
M).

The
total
respondent
costs
in
block
14
have
been
calculated
as
the
addition
of
the
capital/
startup
costs,
and
the
annual
operation
and
maintenance
costs.
The
average
annual
cost
for
capital/
startup
and
operation
and
maintenance
costs
to
respondents
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
0.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.
13
6(
c)
Estimating
Agency
Burden
and
Cost
The
only
costs
to
the
Agency
are
those
costs
associated
with
maintenance,
analysis,
and
utilization
of
the
collected
information.

The
average
Agency
cost
for
the
collection
and
administration
of
the
information
required
by
this
ICR
is
estimated
to
be
$
262,017
[
see
Table
2].
This
cost
is
based
on
the
average
hourly
labor
rate
at
a
GS­
12,
Step
1,
times
a
1.6
benefits
multiplication
factor
to
account
for
government
overhead
expenses
for
a
total
hourly
rate
of
$
40.56.

These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.
These
rates
can
be
obtained
from
the
OPM
website,
http://
www.
opm.
gov/
oca/
04tables/
html/
gs.
asp.
Details
upon
which
this
estimate
is
based
appear
in
Table
2,
"
Total
Agency
Burden,"
below.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
our
research
for
this
ICR,
approximately
581
respondents
will
provide
the
information
required
under
40
CFR
Part
35,
Subpart
O
each
year.

The
number
of
Total
Annual
Responses
is
581.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13(
b),
Total
annual
responses.

The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
215,340.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1.
(
Total
Respondent
Burden).

Note
that
the
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
0.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
These
costs
are
detailed
in
Section
6(
b)(
iii),
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs.

6(
e)
Bottom
Line
Burden
Hours
Burden
Hours
And
Cost
Tables
The
bottom
line
burden
hours
and
cost
tables
for
both
the
Agency
and
the
respondents
appear
below.
The
annual
respondent
burden
for
this
collection
of
information
is
estimated
to
average
10.5
hours
per
response.

6(
f)
Reasons
for
Change
in
Burden
The
increase
in
burden
from
the
most
recently
approved
ICR
reflects
the
correction
of
several
calculation
errors
in
the
last
ICR
and
revised
input
from
the
Regions.
The
cost
per
burden
hour
has
increased
due
to
an
increase
in
labor
rates
since
approval
of
the
last
ICR.
14
6(
g)
Burden
Statement
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
valid
OMB
Control
Number.
The
OMB
Control
Numbers
for
EPA's
regulations
are
listed
at
40
CFR
Part
9
and
48
CFR
Chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
Number
SFUND­
2004­
0008,
which
is
available
for
public
viewing
at
the
OSWER
Docket
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Avenue.,
N.
W.,
Washington,
D.
C.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
OSWER
Docket
is
(
202)
566­
0276.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
Docket
ID
Number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
N.
W.,
Washington,
D.
C.
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
Number
SFUND­
2004­
0008
and
OMB
Control
Number
2050­
0179
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
15
Table
1:
Total
Respondent
Burden
Activity
Unit
Burden
(
Hours)
Unit
Labor
Cost
(
Dollars)
Total
Unit
Cost
(
Dollars)
Average
number
of
respondents
per
Year
(
Full)
Total
Burden
(
Hours)
Total
Cost
(
Dollars)

Pre­
remedial
CA
7
$
35.52
$
248.64
33
231
$
8,205.12
Remedial
response
CA
20
$
35.52
$
710.40
30
600
$
21,312.00
Enforcement
CA
43
$
35.52
$
1,527.36
1
43
$
1,527.36
Removal
response
CA
42
$
35.52
$
1,491.84
21
882
$
31,328.64
Core
program
CA
8
$
35.52
$
284.16
22
176
$
6,251.52
Support
agency
CA
8
$
35.52
$
284.16
45
360
$
12,787.20
Records
retention
5.5
$
35.52
$
195.36
375
2,062.5
$
73,260.00
Superfund
State
Contract
30
$
35.52
$
1,065.60
52
1,560
$
55,411.20
Conclusion
of
Superfund
State
Contract
5
$
35.52
$
177.60
0
0
0
Consolidated
funding
74
$
35.52
$
2,628.48
2
148
$
5,256.96
TOTAL
581
6,062.5
$
215,340
TOTAL
NUMBER
OF
RESPONDENTS
581*

TOTAL
BURDEN
HOURS*
6,062.5*

AVERAGE
BURDEN
HOURS
PER
RESPONDENT*
10.5*

TOTAL
COST
$
215,340*

*
Amendment
respondents
are
assumed
to
have
only
1/
3
of
the
burden
imposed
as
Full
respondents,
since
the
process
of
amending
is
not
as
extensive
as
it
is
for
a
new
application
for
a
CA.
Current
Subpart
O
language
does
not
address
amendments
/
changes
to
CAs,
which
are
covered
under
Part
31,
so
neither
the
number
of
recipients,
nor
the
respective
burden
hours,
are
included
in
this
calculation.
16
Table
2:
Total
Agency
Burden
Activity
Unit
Burden
(
Hours)
Unit
Labor
Cost
(
Dollars)
Total
Unit
Cost
(
Dollars)
Average
number
of
respondents
per
Year
(
Full)
Total
Burden
(
Hours)
Total
Cost
(
Dollars)

Pre­
remedial
CA
23
$
40.56
$
932.88
33
759
$,
30785.04
Remedial
response
CA
36
$
40.56
$
1,460.16
30
1,080
$
43,804.80
Enforcement
CA
35
$
40.56
$
1,419.60
1
35
$
1,419.60
Removal
response
CA
36
$
40.56
$
1,460.16
21
756
$
30,663.36
Core
program
CA
15
$
40.56
$
608.40
22
330
$
13,384.80
Support
agency
CA
14
$
40.56
$
567.84
45
630
$
25,552.80
Records
retention
2
$
40.56
$
81.12
375
750
$
3,0420
Superfund
State
Contract
40
$
40.56
$
1,622.40
52
2,080
$
84,364.80
Conclusion
of
Superfund
State
Contract
13
$
40.56
$
527.28
0
0
Consolidated
funding
20
$
40.56
$
811.20
2
40
$
1,622.40
TOTAL
581
6,460
$
262,017.60
TOTAL
NUMBER
OF
RESPONDENTS
581*

TOTAL
BURDEN
HOURS
6,460
AVERAGE
BURDEN
HOURS
PER
RESPONDENT*
11.1
TOTAL
COST
$
262,017.60
*
Amendment
respondents
are
assumed
to
have
only
1/
3
of
the
burden
imposed
as
Full
respondents,
since
the
process
of
amending
is
not
as
extensive
as
it
is
for
a
new
application
for
a
CA.
Current
Subpart
O
language
does
not
address
amendments
/
changes
to
CAs,
which
are
covered
under
Part
31,
so
neither
the
number
of
recipients,
nor
the
respective
burden
hours,
are
included
in
this
calculation.
