  SEQ CHAPTER \h \r 1  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.  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 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  TC \l3 " 

MA Dept. of Environmental Protection

One Winter St.

Boston, MA 02108

  TC \l2 " 

Illinois Environmental Protection Agency

1021 North Grand Avenue East 

P.O. Box 19276

Springfield, IL 62794-9276

  TC \l2 " 

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						  TC \l3 " 

TN Dept. of Environment & Conservation

401 Church St., L&C Annex, 4th Fl.

Nashville, TN 37243-1538

  TC \l4 " 

VA Dept. of Environmental Quality  TC \l3 " 

P.O. Box 10009 

629 E. Main St., 10th Fl.

Richmond, VA 23240-0009

  TC \l4 " 

UT Dept. of Environmental Quality

168 North 1950 West

Salt Lake City, Utah 84116  TC \l3 " 

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,   HYPERLINK
"http://www.opm.gov/oca/06tables/html/gs_h.asp." 
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.  

		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,   HYPERLINK
"http://www.opm.gov/oca/06tables/html/gs_h.asp." 
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.  The annual respondent burden for this
collection of information is estimated to average 8 hours per response.

		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 3334,
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. 

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.  

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