                              SUPPORTING STATEMENT
	ENVIRONMENTAL PROTECTION AGENCY
                                       
                                       
Cooperative Agreements and Superfund State Contracts for Superfund Response Actions (Final Rule)


1.  Identification of the Information Collection

	1(a) Title of the Information Collection

      Cooperative Agreements and Superfund State Contracts for Superfund Response Actions (Final Rule).  OMB Control Number 2050-0179, EPA ICR Number 1487.09.
			
	1(b) Short Characterization/Abstract

	This is a request for an updated Information Collection Request (ICR) accompanying the issuance of a revised regulation.  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 Part 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 316 new respondents and 338 
amendments to existing agreements with recipients impose a burden of 5073 hours and $149,687.04.  Previous Information Collection burdens were approved under OMB control number 2050-0179. This prior 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 forth the pre-award, post-award, and closeout 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 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.  Non duplication, Consultations, and Other Collection Criteria

	3(a) Non duplication
	
	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 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
	
      This information collection request will accompany 40 CFR Part 35 Subpart O in the reissuance process for that regulation.

	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 organizations were contacted to provide additional input towards the calculation of burden imposed by this ICR:

Bureau of Waste Site Cleanup
MA Dept. of Environmental Protection
One Winter St.
Boston, MA 02108

Illinois Environmental Protection Agency
1021 North Grand Avenue East 
P.O. Box 19276
Springfield, IL 62794-9276

NJ Dept. of Environmental Protection 
CN 413
Trenton, NJ 08625

OK Dept. of Environmental Quality
707 N. Robinson Street
P.O. Box 1677 (Mailing Address)
Oklahoma City, OK 73101-1677

OR Department of Environmental Quality
2020 SW Fourth Ave., Suite 400
Portland, OR 97201						

TN Dept. of Environment & Conservation
401 Church St., L&C Annex, 4th Fl.
Nashville, TN 37243-1538

VA Dept. of Environmental Quality
P.O. Box 10009 
629 E. Main St., 10th Fl.
Richmond, VA 23240-0009

UT Dept. of Environmental Quality
168 North 1950 West
Salt Lake City, Utah 84116

CA Dept. of Toxic Substances Control
1011 N. Grandview
Glendale, CA 91201

	One of the organizations contacted responded. That respondent commented on the burdens presented in the burden table, stating that the Record Retention burden appeared to be undervalued due to increased new requirements for the provision of documentation and additional cases entering cost recovery. EPA agrees with this comment and has consequently increased the burden estimate by 0.5 hours to 6.0 hours per Cooperative Agreement. 

	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).
	
	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
921150
  
	4(b) Information Requested
			
	(i)  Data Items (Including recordkeeping requirements)

	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;
*      Consolidated Funding Cooperative Agreements;
* 	Conclusion of the Cooperative Agreement; 
*      Superfund State Contract; 
* Conclusion of Superfund State Contracts; and
* Records Retention.

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

		(ii)  Respondent Activities

		Respondents will:

* 	Prepare and submit cooperative agreements/Superfund State Contract application materials
	including work plans; 
* 	Conduct research and gather data as needed; 
* Prepare and submit quarterly/or bi-annual/or annual reports that contain: (1) An explanation of work accomplished during the reporting period, delays, or other problems, if any, and a description of the corrective measures that are planned. For Pre-remedial Cooperative Agreements, the report must include a list of the site-specific products completed and the estimated number of technical hours spent to complete each product. (2) A comparison of the percentage of the project completed to the project schedule, and an explanation of significant discrepancies. (3) A comparison of the estimated funds spent to date to planned expenditures and an explanation of significant discrepancies. For remedial, enforcement, and removal reports, the comparison must be on a per task basis. (4) An estimate of the time and funds needed to complete the work required in the Cooperative Agreement, a comparison of that estimate to the time and funds remaining, and a justification for any increase.
* Prepare other standardized non-construction assurances referenced and covered under 40 CFR Part 31 and OMB Circular A-102;
* 	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 IGMS, the Agency's database for tracking the status of grant/cooperative agreement actions.  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 data 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 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 properly 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 654 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;
*      Consolidated Funding Cooperative Agreements;
* 	Conclusion of the Cooperative Agreements; 
*      Superfund State Contract; 
*      Conclusion of Superfund State Contracts; and 
*      Records Retention.

		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 identification of environmental results, research, data collection, analysis, negotiation, preparation, and post-award monitoring of the Pre-Remedial Cooperative Agreement.  EPA estimates that approximately 47 (14 new respondent CAs and 33 amended respondent CAs) Pre-Remedial Cooperative Agreements involving States, Tribes, or political subdivisions, will be in place each year.  EPA estimates that an average of 9 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 identification of environmental results, research, plan preparation, data collection, analysis, negotiation in preparing the materials required for, and post-award monitoring of Remedial Response Cooperative Agreements.  EPA estimates that approximately 55 (20 new respondent CAs and 35 amended respondent CAs) Remedial Response Cooperative Agreements, which involve States, Tribes, and political subdivisions, will be in place each year.  EPA estimates that an average of 18 hours is 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 identification of environmental results, research, plan and certification documentation preparation, such as the quality assurance plan, data collection, analysis in the preparation of materials involved in acquiring and operating within an Enforcement cooperative agreement.  EPA estimates that an average of 20 (11 new respondent CAs and 9 amended respondent CAs) Enforcement Cooperative Agreements will be in place each year.  EPA also estimates that approximately 29 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 identification of environmental results, research, plan preparation, data collection, analysis, negotiation in preparing the materials required for, and post-award monitoring of a Removal Response Cooperative Agreement EPA estimates that approximately 4 (2 new respondent CAs and 2 amended respondent CAs) Removal Response Cooperative Agreements, which involve States, Tribes, and political subdivisions, will be in place each year.  EPA estimates that an average of 29 hours is 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 identification of environmental results, research, data collection, analysis, negotiation in preparing the materials required for, and post-award monitoring of a Core Program Cooperative Agreement.  EPA estimates that 54 (17 new respondent CAs and 37 amended respondent CAs) Core Program Cooperative Agreements, which involve States, Tribes, and political subdivisions, will be in place each year.  Superfund program experience indicates that 29 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 identification of environmental results, research, data collection, analysis, negotiation in preparing the materials required for, and post-award monitoring of a Support Agency Cooperative Agreement. EPA estimates that approximately 63 (19 new respondent CAs and 44 amended respondent CAs) 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 Consolidated Funding Cooperative Agreements represents the number of hours that are spent in identification of environmental results, research, data collection, analysis, negotiation, and preparation of Consolidated Funding Cooperative Agreements each year.  EPA estimates that approximately 5 (1 new respondent CAs and 4 amended respondent CAs) Consolidated Funding Cooperative Agreements are in place each year.  EPA estimates that approximately 42 hours a year are necessary to meet the requirements of a Consolidated Funding Cooperative Agreement.  A Consolidated Funding Cooperative Agreement is composed of a Pre-Remedial, Core Program, and Support Agency Cooperative Agreement. The potential three-fold burden from this type of Cooperative Agreement can be attributed to the increase in the paperwork needed to document, track, and respond to the requirements for each cooperative agreement type.   However, a savings in burden is expected from Consolidated Funding Cooperative Agreements due to consolidated administration and reporting requirements, and other common elements, thus, Consolidated Funding Cooperative Agreements have a cost that is smaller than the sum of each of the three Cooperative Agreement types.  While a savings does occur, considering the burden of each type of combined Cooperative Agreement, the current estimate of 20 hours for the Consolidated Funding Cooperative Agreement appears to be too low. Averaging the estimate of 52 hours (the sum of the three types of Cooperative Agreements) with the 20 hour prior ICR burden estimate yields the more realistic estimate of 36 hours used in the present burden tables.

		The estimated burden associated with the Conclusion of a Cooperative Agreement represents the number of hours that are spent in assembling and reconciling financial data, identifying any outstanding contractual issues, assembling relevant Cooperative Agreement data deliverables and other documentation, coordinating with USEPA personnel in the disposition of equipment and other acquisitions under the cooperative agreement, determining final cost shares and preparing the site for the operation and maintenance phase of the Superfund State Contract each year.  EPA estimates that approximately 30 (30 new respondent CAs and 0 amended respondent CAs) Superfund State Contracts are concluded each year.  The Superfund Subpart O Workgroup estimates that 11 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; 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 the contents of a Superfund State Contract represents the number of hours that are spent in identification of environmental results, research, data collection, analysis, negotiation, and preparation of the Superfund State Contract each year.  EPA estimates that approximately 9 (4 new respondent CAs and 5 amended respondent CAs) Superfund State Contracts are in place each year.  The Superfund grants program workgroup estimates that 24 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; 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 the Conclusion of a Superfund State Contract represents the number of hours that are spent in assembling and reconciling financial data, identifying any outstanding contractual issues, assembling relevant Cooperative Agreement data deliverables and other documentation, coordinating with USEPA personnel in the disposition of equipment and other acquisitions under the Cooperative Agreement, determining final cost shares and preparing the site for the operation and maintenance phase of the Superfund State Contract each year.  EPA estimates that approximately 42 (42 new respondent CAs and 0 amended respondent CAs) Superfund State Contracts are concluded each year.  The Superfund Subpart O Workgroup estimates that 7 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; 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 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 327 (158 new respondent CAs and 169 amended respondent CAs) Cooperative Agreements will be in place each year.  Superfund program experience indicates that an average of 3 hours will be required each year to meet the burden imposed by this regulation's Records Retention requirements.  

		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 2006. 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			$50.46/hour
						Technical			GS 11, step 1			$35.41/hour
						Clerical			GS 7, step 1			$23.92/hour

		These rates are from the Office of Personnel Management (OPM) "2006 General Schedule" which excludes locality rates of pay.  These rates can be obtained from the OPM website, http://www.opm.gov/oca/06tables/html/gs_h.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 $37.27 per hour [(50.46*0.2)+(35.41*0.7)+(23.92*0.1)].

		(ii) Estimating Capital and Operation and Maintenance Costs

		The only type of costs associated with this information collection activity is 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.  

		The total operation and maintenance (O&M) costs for this ICR are $0.  

		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.  

		(iv) Annualizing Capital Costs

		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 $207,347.25 [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 $42.45.
				
		These rates are from the Office of Personnel Management (OPM) "2006 General Schedule" which excludes locality rates of pay.  These rates can be obtained from the OPM website, http://www.opm.gov/oca/06tables/html/gs_h.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 654 respondents will provide the information required under 40 CFR Part 35, Subpart O each year.

		The number of Total Annual Responses is 654.  

		The total annual labor costs are $149,687.04.  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.  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 in Table 1.  The annual respondent burden for this collection of information is estimated to average 8 hours per response.  Variations in the Annual Bottom Line?
                                       
		6(f) Reasons for Change in Burden

		The decrease in burden from the most recently approved ICR of $65,653 and 990 hours reflects a change in methodology from the prior ICR.  In the prior ICR, burden was assigned on "full respondent" basis and an average number of respondents per year.  In this revised ICR burden is now computed using a five year average of the actual number of new cooperative agreements awarded and the actual number of amendments to those cooperative agreements. This more sophisticated method revealed that the "full (new)" respondent population has decreased, but there is an increased number of total respondents due to the addition of "amendments".   Revisions to pricing factors from the Regions and States modified some prior burden estimates.  New cooperative agreement policies such as the Environmental Results under EPA Assistance Agreements, and the Post Award Monitoring Policy have added a significant burden to annual CA burden hours, therefore 3 hours per CA type (1 hour for amendment CAs) have been added to account for this increased monitoring need.  

		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 EPA-HQ-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 at www.regulations.gov.  This site can be used to submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronically.  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 EPA-HQ-SFUND-2004-0008 and OMB Control Number 2050-0179 in any correspondence. 

NOTE:  The EPA Docket Center suffered damage due to flooding during the last week of June 2006.  The Docket Center is continuing to operate.  However, during the cleanup, there will be temporary changes to Docket Center telephone numbers, addresses, and hours of operation for people who wish to make hand deliveries or visit the Public Reading Room to view documents.  Consult EPA's Federal Register notice at 71 FR 38147 (July 5, 2006) or the EPA website at http://www.epa.gov/epahome/dockets.htm for current information on docket operations, locations and telephone numbers.  The Docket Center's mailing address for U.S. mail and the procedure for submitting comments to www.regulations.gov are not affected by the flooding and will remain the same.

Part B of the Supporting Statement

		This part is not applicable because no statistical methods were used in collecting this information.
Table 1: Total Respondent Burden 
                                       
                                   Activity 
                                       
                                       
                    Average number of respondents per Year
                                  (Full) 2006
                              Unit Burden (Hours)
                           Unit Labor Cost (Dollars)
                                       
                                       
                           Total Unit Cost (Dollars)
                                       
                             Total Burden (Hours)
                                       
                             Total Cost (Dollars)
Pre-Remedial CA 
                                      New
                                     13.8
                                      10
                                    $37.27 
                                    $372.70
                                      138
                                   $5,143.26

                                   Amendment
                                     32.8
                                      8.7
                                    $12.30 
                                    $107.01
                                    285.36
                                   $3,509.93
Remedial response CA
                                      New
                                     19.6
                                      23
                                    $37.27 
                                    $857.21
                                     450.8
                                  $16,801.32

                                   Amendment
                                      35
                                      13
                                    $12.30 
                                    $159.90
                                      455
                                   $5,596.50
Enforcement CA 
                                      New
                                     10.8
                                      46
                                    $37.27 
                                   $1,714.42
                                     496.8
                                  $18,515.74

                                   Amendment
                                      9.4
                                     12.7
                                    $12.30 
                                    $156.21
                                    119.38
                                   $1,468.37
Removal response CA 
                                      New
                                      1.8
                                      45
                                    $37.27 
                                   $1,677.15
                                      81
                                   $3,018.87

                                   Amendment
                                      1.6
                                      13
                                    $12.30 
                                    $159.90
                                     20.8
                                    $255.84
Core program CA 
                                      New
                                     17.4
                                      11
                                    $37.27 
                                    $409.97
                                     191.4
                                   $7,133.48

                                   Amendment
                                     36.6
                                       6
                                    $12.30 
                                    $73.80
                                     219.6
                                   $2,701.08
Support agency CA 
                                      New
                                     18.8
                                      11
                                    $37.27 
                                    $409.97
                                     206.8
                                   $7,707.44

                                   Amendment
                                      44
                                      5.7
                                    $12.30 
                                    $70.11
                                     250.8
                                   $3,084.84
Superfund State Contract 
                                      New
                                      4.2
                                      33
                                    $37.27 
                                   $1,229.91
                                     138.6
                                   $5,165.62

                                   Amendment
                                      5.4
                                     14.3
                                    $12.30 
                                    $175.89
                                     77.22
                                    $949.81
Conclusion of Superfund State Contract 
                                      New
                                     41.8
                                       8
                                    $37.27 
                                    $298.16
                                     334.4
                                  $12,463.09

                                   Amendment
                                       0
                                      5.3
                                    $12.30 
                                    $65.19
                                       0
                                     $0.00
Consolidated funding CA 
                                      New
                                      0.4
                                      77
                                    $37.27 
                                   $2,869.79
                                     30.8
                                   $1,147.92

                                   Amendment
                                       4
                                      7.7
                                    $12.30 
                                    $94.71
                                     30.8
                                    $378.84
Conclusion of CA 
                                      New
                                     29.8
                                      16
                                    $37.27 
                                    $596.32
                                     476.8
                                  $17,770.34

                                   Amendment
                                       0
                                      5.3
                                    $12.30 
                                    $65.19
                                       0
                                     $0.00
Records retention 
                                      New
                                     158.4
                                       6
                                    $37.27 
                                    $223.62
                                     950.4
                                  $35,421.41

                                   Amendment
                                     168.8
                                      0.7
                                    $12.30 
                                     $8.61
                                    118.16
                                   $1,453.37
TOTAL
                                       
                                       
                                  $149,687.04
TOTAL NUMBER OF RESPONDENTS 
                                       *
                                      654
TOTAL BURDEN HOURS*
                                       *
                                   5,072.92
AVERAGE BURDEN HOURS PER RESPONDENT*
                                       *
                                     7.75
TOTAL COST
                                       
                                  $149,687.04

	*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.Table 2: Total Agency Burden
                                       
                                   Activity 
                                       
                                       
                    Average number of respondents per Year
                                  (Full) 2006
                              Unit Burden (Hours)
                           Unit Labor Cost (Dollars)
                                       
                                       
                           Total Unit Cost (Dollars)
                                       
                             Total Burden (Hours)
                                       
                             Total Cost (Dollars)
Pre-Remedial CA 
                                      New
                                     13.8
                                      26
                                    $42.45 
                                   $1,103.70
                                     358.8
                                  $15,231.06

                                   Amendment
                                     32.8
                                      8.7
                                    $14.01 
                                    $121.89
                                    285.36
                                   $3,997.89
Remedial response CA
                                      New
                                     19.6
                                      39
                                    $42.45 
                                   $1,655.55
                                     764.4
                                  $32,448.78

                                   Amendment
                                      35
                                      13
                                    $14.01 
                                    $182.13
                                      455
                                   $6,374.55
Enforcement CA 
                                      New
                                     10.8
                                      38
                                    $42.45 
                                   $1,613.10
                                     410.4
                                  $17,421.48

                                   Amendment
                                      9.4
                                     12.7
                                    $14.01 
                                    $177.93
                                    119.38
                                   $1,672.51
Removal response CA 
                                      New
                                      1.8
                                      39
                                    $42.45 
                                   $1,655.55
                                     70.2
                                   $2,979.99

                                   Amendment
                                      1.6
                                      13
                                    $14.01 
                                    $182.13
                                     20.8
                                    $291.41
Core program CA 
                                      New
                                     17.4
                                      18
                                    $42.45 
                                    $764.10
                                     313.2
                                  $13,295.34

                                   Amendment
                                     36.6
                                       6
                                    $14.01 
                                    $84.06
                                     219.6
                                   $3,076.60
Support agency CA 
                                      New
                                     18.8
                                      17
                                    $42.45 
                                    $721.65
                                     319.6
                                  $13,567.02

                                   Amendment
                                      44
                                      5.7
                                    $14.01 
                                    $79.86
                                     250.8
                                   $3,513.71
Superfund State Contract 
                                      New
                                      4.2
                                      43
                                    $42.45 
                                   $1,825.35
                                     180.6
                                   $7,666.47

                                   Amendment
                                      5.4
                                     14.3
                                    $14.01 
                                    $200.34
                                     77.22
                                   $1,081.85
Conclusion of Superfund State Contract 
                                      New
                                     41.8
                                      16
                                    $42.45 
                                    $679.20
                                     668.8
                                  $28,390.56

                                   Amendment
                                       0
                                      5.3
                                    $14.01 
                                    $74.25
                                       0
                                     $0.00
Consolidated funding CA 
                                      New
                                      0.4
                                      23
                                    $42.45 
                                    $976.35
                                      9.2
                                    $390.54

                                   Amendment
                                       4
                                      7.7
                                    $14.01 
                                    $107.88
                                     30.8
                                    $431.51
Conclusion of CA 
                                      New
                                     29.8
                                      16
                                    $42.45 
                                    $679.20
                                     476.8
                                  $20,240.16

                                   Amendment
                                       0
                                      5.3
                                    $14.01 
                                    $74.25
                                       0
                                     $0.00
Records retention 
                                      New
                                     158.4
                                       5
                                    $42.45 
                                    $212.25
                                      792
                                  $33,620.40

                                   Amendment
                                     168.8
                                      0.7
                                    $14.01 
                                     $9.81
                                    118.16
                                   $1,655.42
TOTAL
                                       
                                       
                                  $207,347.25
TOTAL NUMBER OF RESPONDENTS 
                                       *
                                      654
TOTAL BURDEN HOURS*
                                       *
                                   5,941.12
AVERAGE BURDEN HOURS PER RESPONDENT*
                                       *
                                     9.07
TOTAL COST
                                       
                                  $207,347.25

	*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.  
