RENEWAL OF INFORMATION COLLECTION REQUEST FOR THE CONTINUOUS RELEASE
REPORTING REQUIREMENT

October 1, 2004

SFUND-2000-0008

OMB Submission

TABLE OF CONTENTS

  TOC \w \x \t "TCHeading 1,1, TCHeading 2,2, TCHeading 1 NoNumbering,1"
 1.	IDENTIFICATION OF THE INFORMATION COLLECTION	  PAGEREF _Toc162862791
\h  2 

	l(a)	Title and Number of the Information Collection	  PAGEREF
_Toc162862792 \h  2 

	l(b)	Short Characterization	  PAGEREF _Toc162862793 \h  2 

2.	NEED FOR AND USE OF THE COLLECTION	  PAGEREF _Toc162862794 \h  3 

	2(a)	Need and Authority for the Collection	  PAGEREF _Toc162862795 \h 
3 

	2(b)	Practical Utility and Users of the Data	  PAGEREF _Toc162862796 \h
 3 

3.	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA	 
PAGEREF _Toc162862797 \h  4 

	3(a)	Nonduplication	  PAGEREF _Toc162862798 \h  4 

	3(b)	Public Notice	  PAGEREF _Toc162862799 \h  5 

	3(c)	Consultations	  PAGEREF _Toc162862800 \h  5 

	3(d)	Effects of Less Frequent Collection	  PAGEREF _Toc162862801 \h  5 

	3(e)	General Guidelines	  PAGEREF _Toc162862802 \h  7 

	3(f)	Confidentiality	  PAGEREF _Toc162862803 \h  7 

	3(g)	Sensitive Questions	  PAGEREF _Toc162862804 \h  7 

4.	THE RESPONDENTS AND THE INFORMATION REQUESTED	  PAGEREF _Toc162862805
\h  7 

	4(a)	Respondents and SIC Codes	  PAGEREF _Toc162862806 \h  7 

	4(b)	Information Requested	  PAGEREF _Toc162862807 \h  7 

5.	THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, COLLECTION
METHODOLOGY, AND INFORMATION MANAGEMENT	  PAGEREF _Toc162862808 \h  12 

	5(a)	Agency Activities	  PAGEREF _Toc162862809 \h  12 

	5(b)	Collection Methodology and Management	  PAGEREF _Toc162862810 \h 
12 

	5(c)	Small Entity Flexibility	  PAGEREF _Toc162862811 \h  13 

	5(d)	Collection Schedule	  PAGEREF _Toc162862812 \h  14 

6.	ESTIMATING THE BURDEN AND COST OF THE COLLECTION	  PAGEREF
_Toc162862813 \h  14 

	6(a)	Estimating Respondent Burden	  PAGEREF _Toc162862814 \h  14 

	6(b)	Estimating Respondent Costs	  PAGEREF _Toc162862815 \h  22 

	6(c)	Estimating Agency Burden and Costs	  PAGEREF _Toc162862816 \h  27 

	6(d)	Estimating the Respondent Universe and Total Burden and Cost	 
PAGEREF _Toc162862817 \h  30 

	6(e)	Bottom Line Burden Hours and Costs	  PAGEREF _Toc162862818 \h  31 

	6(f)	Reasons for Change in Burden	  PAGEREF _Toc162862819 \h  31 

	6(g)	Burden Statement	  PAGEREF _Toc162862820 \h  32 

APPENDIX A	  PAGEREF _Toc162862821 \h  36 

 

LIST OF EXHIBITS

Exhibit 1

Unit Burden Hours per Respondent Information Collection Activity	19

Exhibit 2

Burden Hours for a Typical Facility	20

Exhibit 3

Unit Labor Cost per Respondent Information Collection Activity	22

Exhibit 4

Annual Labor Costs for a Typical Facility	23

Exhibit 5

Unit Operating and Maintenance Costs per Respondent Information
Collection Activity	24

Exhibit 6

Operating and Maintenance Costs for a Typical Facility	25

Exhibit 7

Unit Labor and Operating and Maintenance Costs per

Respondent Information Collection Activity	25

Exhibit 8

Labor and Operating and Maintenance Costs for a Typical Facility	26

Exhibit 9

Unit Burden Hours and Costs Incurred by the

Government per Information Collection Activity	29

Exhibit 10

Number of Facilities and Hazardous Substance Releases Already Affected
by the CRRR	30

Exhibit 12

Annual Burden Hours and Costs Incurred by Industry	33

Exhibit 13

Annual Burden Hours and Costs Incurred by Government	34

Exhibit 14

Summary of Burden Hours and Costs Incurred by Industry	35

Exhibit 15

Summary of Burden Hours and Costs Incurred by Government	35

IDENTIFICATION OF THE INFORMATION COLLECTION

	l(a)	Title and Number of the Information Collection

Continuous Release Reporting Regulations (CRRR) under the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980 (CERCLA)
- EPA No. 1445.06.

	l(b)	Short Characterization

This information collection request (ICR) addresses the reporting and
record keeping activities required to comply with EPA’s continuous
release reporting regulation (CRRR; 40 CFR 302.8) implementing section
103(f)(2) of the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA).  The CRRR, developed by EPA’s Office
of Emergency and Remedial Response in the Office of Solid Waste and
Emergency Response, clarifies the types of releases that qualify for
reporting under CERCLA section 103(f)(2) and establishes the reporting
requirements applicable to qualifying releases.  This ICR renews the
collection activity previously approved under OMB No. 2050-0086 and
applies to the period December 1, 2004 through November 30, 2007. 
Estimates of the burden placed on industry and the government to comply
with the release notification requirements are presented on an annual
basis.

CERCLA section 103(a) requires persons in charge of a facility or vessel
to immediately notify the National Response Center (NRC) of any
hazardous substance release that equals or exceeds its reportable
quantity (RQ) and is not federally permitted.  Notification under CERCLA
is intended to ensure that Federal authorities receive prompt
notification of hazardous substance releases for which a timely response
may be necessary to protect public health or welfare or the environment
from any adverse effects that may be associated with the release. 
Section 103(f)(2) of CERCLA provides relief from the per-occurrence
notification requirements of section 103(a) for hazardous substance
releases that are “continuous,” and “stable in quantity and
rate,” provided that such releases are reported “annually, or at
such time as there is any statistically significant increase” in the
quantity of the release.  Section 103(f)(2) contemplates that, in the
case of certain “continuous” and “stable” releases, the
notification objectives of CERCLA can be achieved with less frequent
reporting.  The regulated community is expected to:

•	Gather necessary release data, such as the time, quantity, and
source of the release;

•	Notify the facility manager of the release;

•	Consult with the environmental compliance expert regarding the
release;

•	Make an initial report of the release to the NRC; 

•	Submit an initial written notification to the appropriate EPA
Regional Office for the geographical area where the releasing facility
or vessel is located;

•	Provide follow-up notification within 30 days of the first
anniversary date of the initial written notification;

•	Make notifications to the NRC if there is a change in the release,
including a statistically significant increase in a release;

•	Make an annual evaluation of releases to determine if changes have
occured in the information submitted in the initial written
notification, the followup notification and/or in a previous change
notification - if there are no changes, submittal of a report is not
required.

•	Keep all supporting documents, materials, and other information on
file for a period of one year to substantiate the reported normal range
of releases, the basis for stating that the release is continuous and
stable in quantity and rate, and the other information in the initial
written report, the followup report, and the annual evaluations. 

The continuous release final rule has been in effect since September 24,
1990.  This ICR utilizes historical data on the number of continuous
release reports submitted to the Federal government to estimate the
number of burden hours attributable to the CRRR.  The statistics on the
number of continuous release reports submitted to the Federal government
are available through the National Response Center’s incident data
base.

In the first year of the three-year period covered by this ICR, it is
estimated the 3,207 facilities will be affected by the CRRR.  Of the
3,207 facilities affected in the first year, it is assumed that 62 will
be reporting continuous releases for the first time and the remaining
3,145 will be meeting information collection requirements for ongoing
releases.  In the second and third years, it is estimated that 67 and 72
additional facilities, respectively, will generate reportable continuous
releases.  When calculating the burdens and costs in this ICR it has
been assumed that the typical facility participates in information
collection activities for each release.  For example, the typical
facility will provide an initial telephone notification and written
report for each of its continuous releases.  In fact, it is likely that
many facility operators will consolidate collection activities for
releases at their facilities (e.g., provide one telephone notification
for several releases).  Assuming eight releases per facility per year,
and thus 8 information collection activities per facility per year, the
total number of continuous release information collection activities in
the first year of the three-year period covered by this ICR is estimated
to be 25,657 (497 initial notification activities and 25,160 ongoing
notification activities).  In the second and third years of the period
covered by this ICR, it is estimated that 534 and 574 information
collection activities, respectively, will take place.  The total
estimated burden to respondents is approximately 277,862, 284,000 and
290,600 hours in years 1,2, and 3, respectively.  For the regulated
community, the estimated information collection activity costs
(including labor and O&M costs) are $9,879,894, $10,094,310 and
$10,328,892 in years 1,2, and 3, respectively.  The total estimated
burden to the government is approximately 26,329, 25,190, and 25,837
hours in years 1,2, and 3, respectively.  The estimated total cost to
the government is $1,067,899, $1,021,687, and $1,047,939, in years 1,2,
and 3, respectively.	

NEED FOR AND USE OF THE COLLECTION

	2(a)	Need and Authority for the Collection

The information collection required in the CRRR (40 CFR 302.8) is fully
authorized under CERCLA section 103(f)(2) and section 104(e).  CERCLA
section 103(f)(2) provides relief from the notification requirements of
CERCLA section 103(a) for hazardous substance releases that are
“continuous,” “stable in quantity and rate,” and for which
notification has been given under CERCLA section 103(a) “for a period
sufficient to establish the continuity, quantity, and regularity” of
the release.  Further, CERCLA section 103(f)(2) requires that
notification of releases qualified as continuous under the CRRR must be
provided “annually, or at such time as there is any statistically
significant increase” in the quantity of the release.  The specific
information provided in the required notifications is authorized under
CERCLA section 104(e).  CERCLA section 104(e) authorizes the collection
of information, entry, and inspection and sampling activities for the
purposes of determining the need for a response, or choosing or taking
any response action under CERCLA.  In addition, CERCLA section 103(f)(2)
establishes a notification system that documents information provided in
the respondent notifications.  The information collection and management
requirements of the CRRR are necessary to determine if a response action
is needed to control or mitigate any potential adverse effects
associated with a reported hazardous substance release.

	2(b)	Practical Utility and Users of the Data

The information collected under the CRRR is used to evaluate the acute
and chronic effects of the continuous release to determine if a response
action is necessary to prevent or mitigate any adverse effects.  Any
hazardous substance release that equals or exceeds its RQ warrants a
timely evaluation of its source, emission rate, and chemical form, the
proximity of sensitive populations or ecosystems, and the ambient
conditions, to ensure the protection of public health and welfare and
the environment.  Agency responses to continuous hazardous substance
release notifications may take a number of forms ranging from requests
for more detailed information (to allow for a more detailed risk
assessment), to the imposition of more stringent emissions limitations,
to removal and/or remedial actions.  Finally, the release notification
information is used by State and local government emergency planners to
conduct State and local emergency response planning.

NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

	3(a)	Nonduplication

The hazardous substance release information requested under the CRRR in
the initial written and follow-up reports is the minimum information
necessary to properly evaluate a hazardous substance release.  EPA
analyzed possible areas of overlap with other regulations, concluding
that there are limited areas of overlap with reporting requirements
under other statutes and provisions.  In particular, some facilities may
need to provide similar hazardous substance release information to
satisfy reporting requirements for the Toxic Release Inventory (TRI)
report under SARA section 313.  The level of duplication, however, is
limited because of differences in the list of chemicals, and the SIC and
facility sizes affected by SARA section 313.  Sara section 313
requirements only apply to facilities in certain SIC categories whose
inventory quantities exceed 10,000 pounds; CERCLA section 103 affects
facilities in all SIC codes regardless of inventory amounts.  In
addition, the SARA section 313 list of toxic chemicals includes only
about one-fourth of the listed CERCLA hazardous substances.  Further,
the SARA section 313 list includes some substances that are not on the
CERCLA list at all.  See Exhibit A-1 in Appendix A for the list of
facility SIC codes affected by SARA section 313.

To minimize any duplication in reporting, EPA allows facilities that are
subject to the reporting requirements of both regulations to submit the
SARA section 313 report (otherwise known as the TRI report) as a
substitute for the written reports required under the CRRR, provided
that certain additional continuous release information is included as an
addendum to the TRI report.  If the TRI report is submitted in lieu of
the continuous release written report, based on each source release, the
following continuous release information must also be included in the
TRI report: (1) the upper and lower bounds (normal range) of the release
over a 24-hour period of each hazardous substance; (2) the frequency of
the release from each release source; (3) a signed statement describing
the basis for asserting that the release is continuous and stable in
quantity and rate; (4) the population density within a one-mile radius;
and (5) the identity and location of any sensitive populations and
ecosystems within a one-mile radius.  These additions will provide EPA
with information that is not available from the TRI report, but is
required to properly evaluate the need for a government response.

Additionally, continuous release reporting under CERCLA section
103(f)(2) eliminates frequent and repetitive reporting under CERCLA
section 103(a).  If a facility with continuous releases were to report
on a per-occurrence basis under section 103(a), the facility could be
notifying the NRC daily.  Respondents with continuous releases may be
unnecessarily reporting under CERCLA section 103(a) because they: (1)
may not be familiar with the reduced reporting option under section
103(f)(2), or (2) may not realize that there is a reduced burden
associated with a one-time initial telephone notification and submission
of an initial written report and one follow-up report under the CRRR. 
EPA’s outreach efforts to increase industry awareness are described in
Section 5(b).  As respondents become more aware of the CRRR and the
ability to simplify and reduce expenses associated with continuous
release reporting, it is possible that some reports could be redirected
from CERCLA section 103(a) (ERNS) to CERCLA section 103(f)(2) (CR-ERNS).

	3(b)	Public Notice

In compliance with the Paperwork Reduction Act (PRA) (44 U.S.C. 3501 et
seq.), EPA has notified the public through the Federal Register notice
on the renewal of this ICR (See 69 FR 41472, July 9, 2004).  EPA
received no comments in response to this notice.

	3(c)	Consultations

EPA consulted with a number of Federal and State government agencies in
the development of the information collection activities described in
this ICR.  To develop the CRRR, EPA formed a Workgroup to address the
comments received on the Notice of Proposed Rulemaking (NPRM) published
on April 19, 1988 (53 FR 12868).  The Workgroup consisted of
representatives from various EPA program offices, the ten EPA Regions,
and the NRC.  EPA Regional offices were responsible for the
implementation of the final rule.  Participation by these parties in the
Workgroup was sufficient to address and resolve all outstanding issues. 
The comments received on the NPRM are addressed in the Response to
Comments Document and in the preamble to the final rule.  

EPA sponsored several workshops throughout the country for industry and
Federal, State, and local government officials on the release
notification requirements under CERCLA and SARA Title III, including the
requirements under the CRRR.  The workshops were held to educate the
regulated community as well as those Federal and State agencies required
to implement the regulations.  In addition, the workshops provided an
opportunity for the public to comment on the implementation of the
regulation.  No workshops were conducted or planned during the period
covered by ICR 1445.05 (November 2001 through November 2004).

For this renewal, several individuals (fewer than 9) responsible for
making notifications to the NRC and submitting written follow-up
reports, were consulted regarding the burden this collection imposes. 
Brief summaries of those consultations are contained in Appendix A to
this renewal supporting statement.

	3(d)	Effects of Less Frequent Collection

The frequency of information collection established in the CRRR is the
minimum level necessary for proper evaluation of continuous releases. 
If the information collected under the CRRR, such as the source,
frequency, and composition of the release, the environmental media
affected, and the identity and location of any sensitive populations or
ecosystems, were collected less frequently than stipulated under the
CRRR, the Federal government’s ability to properly evaluate the threat
posed by the release and the need for a response action would be
jeopardized.

	3(e)	General Guidelines

The regulations imposed by CERCLA section 103(f)(2) adhere fully to
OMB’s general guidelines concerning the collection of information and
the control of paperwork burdens on the public.

	3(f)	Confidentiality

The regulations implementing CRRR do not require the submittal of any
proprietary, trade secret, or other confidential information.

	3(g)	Sensitive Questions

The regulations implementing CRRR do not require the submission of any
sensitive business information.  In addition, the information collection
requested under these regulations is in compliance with the Privacy Act
of 1974 and OMB Circular A-108.

THE RESPONDENTS AND THE INFORMATION REQUESTED

	4(a)	Respondents and SIC Codes

This section is not applicable.  The usage and release of hazardous
substances are pervasive throughout industry.  EPA expects a number of
different industrial categories to report hazardous substance releases
under the provisions of the CRRR.  No one industry sector or group of
sectors is disproportionately affected by the information collection
burden.

	4(b)	Information Requested

Data Items, Including Record keeping

To ensure that government authorities receive timely and sufficient
information to evaluate potentially dangerous hazardous substance
releases reported under CERCLA section 103(f)(2), the CRRR requires
seven types of information collection activities:

An initial telephone call to the NRC;

An initial written report to the EPA Region;

A one-time follow-up written report to the EPA Region on or before the
first-year anniversary of the submission of an initial written report;

An annual evaluation of a release beginning the year after the
submission of the one-time follow-up written report;

Notification to the NRC and EPA Regions of a change in the sources,
composition, or frequency of a release;

Notification to the EPA Region of a change in other information
previously submitted; and

Immediate notification to the NRC of any statistically significant
increase (SSI) in the quantity of a release.

The time required by a facility to complete the seven information
collection activities varies and is largely contingent on the nature of
the reported releases and the facility’s information collection
procedures.  However, EPA estimated the average amount of time that is
needed to perform these seven information collection activities and the
average unit burden hours. The estimates are presented in section 6(a). 
The unit burden hours used in this ICR are based upon estimates from the
CRRR economic analysis.  The CRRR Economic Impact is available in
rulemaking Docket Number 103(f)CR - 4-8.

Reporting continuous releases represents a reduction in burden for
facilities that would otherwise report releases on a per-occurrence
basis.  EPA believes that the notification system developed under the
CRRR represents the minimum level of reporting necessary for the Federal
On-Scene Coordinator (OSC) to evaluate whether a response action is
needed to prevent or mitigate any hazards to public health and welfare
and the environment.  The following paragraphs briefly describe the
purpose and timing of each information collection activity and list the
data items that comprise each notification.

Initial Telephone Notification to the NRC – The initial telephone call
to the NRC serves to notify government authorities of the facility’s
intent to report a hazardous substance release under CERCLA section
103(f)(2).  All such releases must be released in a continuous and
stable manner.  The initial telephone call, in conjunction with the
initial written report, fulfills the statutory requirement that the
release be reported under CERCLA section 103(a) for a period sufficient
to establish the continuity, quantity, and regularity of the release. 
The information provided in the initial telephone notification must
include:

The name and location of the facility; and

The name(s) and identity(ies) of the hazardous substance(s) being
released.

Initial Written Report and the Follow-up Written Report – The initial
written report and the follow-up written report, which are sent to the
EPA Region, provide a full description of the release.  The initial
written report and follow-up written report serve as the basis for a
comprehensive evaluation of the hazards posed by the release.  Based on
this comprehensive evaluation, government authorities determine if a
response action is necessary to prevent or mitigate any adverse effects.
 The initial written report must be submitted within 30 days of the
initial telephone call.  This 30-day period does not necessarily provide
enough time to collect all relevant and appropriate data, but does allow
for an initial evaluation of the release.  The follow-up written report,
due one year after submission of the initial written report, serves to
verify the information provided on the initial written report (NOTE:
there cannot be any form of change in source, composition, or frequency
of release without going through the process again).  The follow-up
written report helps ensure that the information used to evaluate the
hazards posed by the release is current and provides accurate
information.

The data elements requested in the initial written and follow-up report
are identical and consist of:

The name of the facility or vessel; the location, including the
longitude and latitude; the case number assigned by the National
Response Center or Environmental Protection Agency; the Dun and
Bradstreet number of the facility (if available); the port of
registration of the vessel (if applicable); and the name and telephone
number of the person in charge of the facility or vessel. [40 CFR
302.8(e)(1)(i)]

A signed statement that the hazardous substance release described is
continuous and stable in quantity and rate under the definitions of 40
CFR 302.8(b) and that all reported information is accurate and current
to the best knowledge of the person in charge. [40 CFR
302.8(e)(1)(iv)(H)]

The population density within a one-mile radius of the facility or
vessel, described in terms of the following ranges: 0-50 persons, 51-100
persons, 101-500 persons, 501-1,000 persons, and more than 1,000
persons. [40 CFR 302.8(e)(1)(ii)]

The identity and location of sensitive populations and ecosystems within
a one-mile radius of the facility or vessel (e.g., elementary schools,
hospitals, retirement communities, or wetlands). [40 CFR
302.8(e)(1)(iii)]

In addition, facilities must provide the following substance-specific
information for each continuous release:

The sources of the release, including specific source information (e.g.,
valves, pump seals, storage tank vents, stacks). [40 CFR
302.8(e)(1)(iv)(C)]

The environmental medium(a) affected by the release: if air, provide
stack height or surface area affected; if surface water, the name of the
surface water body; if a stream, the stream order or average flowrate
and designated use; if a lake, the surface area and average depth; if on
or under ground, the location of public water supply wells within two
miles. [40 CFR 302.8(e)(1)(iv)(G)(1-4)]

The frequency of the release and the fraction of the release from each
release source and the period over which it occurs. [40 CFR
302.8(e)(1)(iv)(D)]

A brief statement describing the basis for stating that the release is
continuous and stable in quantity and rate. [40 CFR 302.8(e)(1)(iv)(E)]

The name and identity of the hazardous substance; and the Chemical
Abstracts Service Registry Number for the substance.  If the release is
a mixture, the hazardous substance components of the mixture and their
approximate concentrations and quantities, by weight. [40 CFR
302.8(e)(1)(iv)(A)]

The upper and lower bounds of the normal range of the release over the
previous year. [40 CFR 302.8(e)(1)(iv)(B)]

An estimate of the total annual amount of the hazardous substance
released in the previous year (in pounds or kilograms). [40 CFR
302.8(e)(1)(iv)(F)]

Annual Evaluation of a Release – Although a reporting facility is no
longer required to submit a written report on its continuous releases
after submitting a one-time written follow-up report verifying the
information provided on the initial written report remained the same,
the reporting facility must conduct and document an annual assessment of
its continuous releases beginning the year after the submission of the
follow-up written report.  The purpose of the annual evaluation is to
identify any changes that may have occurred in the release situation
over the preceding year.  The annual evaluation of a continuous release
helps ensure that the information used to evaluate the hazards posed by
the release is current and accurate information.

Change in the Source, Composition, or Frequency of a Release Report –
If there is a change in the source, composition, or frequency of a
release, the release must be reported and treated as a new continuous
release.  An initial telephone notification and written change report
must be provided as described above.  The person in charge also must
submit a follow-up report within one year of the change report.  

Other Changes in Information – Facilities experiencing a change in a
continuous release that invalidates information previously submitted on
the continuous release must notify the appropriate EPA Region by letter
within 30 days of the change.  The letter regarding the change in the
release should explicitly identify the new (or changed) information and
include an explanation for the change.  For example, a facility must
notify EPA if any schools, hospitals, retirement homes, or other
developments housing sensitive populations are open within one mile of
the facility.

Statistically Significant Increase Report – The CRRR defines a SSI as
a release of a hazardous substance that exceeds the upper bound of the
normal range of the release as established by the facility.  The normal
range of a release is defined by the range of release weights (in pounds
or kilograms) recorded during the preceding year under normal operating
conditions (that is, conditions that prevail during the period
establishing the predictability and regularity of the release). 
Therefore, a SSI does not include releases within the reported normal
range of release.  An SSI release is considered an episodic release
because it is a release above the RQ.  Thus, SSIs must be immediately
reported to the NRC by telephone pursuant to the notification
requirements of CERCLA section 103(a).  The information collected by the
NRC in a SSI report includes the same information supplied when
reporting any other episodic release (e.g., quantity of the release,
source of the release, and a description of any response actions taken).

The person in charge of a facility with a SSI may modify the previously
established normal range as an alternative to reporting multiple SSIs. 
To modify the normal range of the release over a 24-hour period under
normal operating procedures, the person in charge of the facility must
report at least one SSI to the NRC as an episodic release (to facilitate
immediate evaluation), and then must submit a written change report of
the release information to the appropriate EPA Region describing the new
normal range and reasons for the change; thus treating the SSI as a new
release.  Thus, for example, if a facility doubles its production level
thereby doubling its release level, the facility may want to double its
reported normal range of the continuous release, rather than reporting
multiple SSIs.  The person in charge also must submit a follow-up report
within one year of the submission of the change report

Record keeping – Facilities may maintain a log or some other record of
each hazardous substance release reported under CERCLA section
103(f)(2).  The information documented in the record can be used to
demonstrate compliance with the provisions of the CRRR, including the
requirement to demonstrate the continuity and stability of the release
and the requirement to conduct an annual evaluation of the release. 
Additionally, facilities may find it useful to document daily release
quantities for use in substantiating and modifying the normal range of
the release.

Respondent Activities  TC \l3 "Respondent Activities"  

To comply with the provisions of the CRRR, the regulated community
performs the following information collection activities:

Provides an initial telephone call to the NRC;

Provides an initial written report to the EPA Region;

Prepares a one-time follow-up written report for the EPA Region on or
before the first-year anniversary of the submission of an initial
written report;

Conducts an annual evaluation of a release beginning the year after the
submission of the one-time follow-up written report;

Prepares change in the sources, composition, or frequency of a release
reports;

Prepares change in other information reports;

Provides immediate notifications of SSIs; and 

Maintains a log or other formal record to document compliance with the
CRRR.

Each of these notification and record keeping activities is listed and
described in detail in section 4(b)(i), above.  In addition to these
activities, persons in charge of a facility may be required to perform
supplemental collection activities in response to the Federal
government’s evaluation of the facility’s continuous release
reports.  In situations where EPA’s evaluation of release reports
engenders concern over potential adverse effects, EPA may require the
person in charge of the facility in question to submit the additional
information or clarify and refine information previously submitted.  EPA
may use this additional information to better assess the risks
associated with the release.  Finally, in response to a release report
or additional information, EPA may conduct a site inspection.  Industry
personnel accompany EPA personnel during the site inspection to address
any questions, concerns, or information requests that may arise.  Thus,
the following other activities are included within the information
collection activities performed by the regulated community:

Provision of additional information; and

Site inspection.

Estimates of the burden hours incurred by industry as a result of
reporting continuous releases were developed based on estimates of the
time expended in providing a specific report (e.g., the initial
telephone call, the initial written report, the follow-up written
report) as opposed to developing estimates for each work element (e.g.,
gathering information, reviewing report formats, completing reports)
involved in completing all of the required activities.  The burden
estimates for each information collection and record keeping activity
performed by the regulated community under the CRRR are presented in
Section 6(a) of this ICR.

THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, COLLECTION METHODOLOGY,
AND INFORMATION MANAGEMENT

	5(a)	Agency Activities

Each of the notification reports submitted by industry is processed and
evaluated by Federal authorities.  For some continuous releases
evaluated under the CRRR, EPA may request additional (supplemental)
information or clarification of information previously submitted by a
facility.  EPA may use this information to conduct a more in-depth risk
assessment of the release.  In some extreme cases, the in-depth risk
assessment may not allay EPA’s concerns and EPA may decide to conduct
a site inspection to review the circumstances associated with the
release first-hand.  Additionally, site inspections may be conducted
periodically as a compliance and enforcement measure.  Thus, the Agency
performs the following other activities as a result of continuous
releases reported under CERCLA section 103(f)(2):

•	Request additional information; and 

•	Conduct site inspections.

Estimates of the burden hours incurred by the Federal government are
developed based on estimates of the time expended in processing the
notification reports required under the CRRR (e.g., the initial written
report, SSI notification) or completing another activity (e.g,
additional information, site inspection) as opposed to developing
estimates for each work element (e.g., reviewing data, entering data,
filing, evaluating a release, storing evaluation results) involved in
completing all of the required activities.  The burden estimates
developed for each of the processing, evaluating, and other activities
performed by the Federal government are presented in Section 6(c.) of
this ICR.

	5(b)	Collection Methodology and Management

To facilitate collection and storage of information on continuous
releases, EPA developed CR-ERNS.  CR-ERNS is an information management
system that serves as the depository for continuous release information
received by the EPA Regions.  CR-ERNS is designed to assist EPA Regional
personnel in managing continuous release information and establishing
priorities with respect to the review and evaluation of continuous
release reports.  The reports submitted to the EPA Regions include the
initial written report, the follow-up report, and changes in release
reports.  Additionally, the NRC immediately notifies the appropriate EPA
Region of any SSI reports.

A publication entitled, “Reporting Requirements for Continuous
Releases of Hazardous Substances, A Guide for Facilities on
Compliance,” is available on EPA’s internet at:    HYPERLINK
"http://www.epa.gov/superfund/resources/release/faciliti.htm" 
http://www.epa.gov/superfund/resources/release/faciliti.htm .  The
publication provides information for respondents regarding how to comply
with the CRRR and includes suggested reporting formats (pdf files) to
assist respondents.  Feedback from industry representatives with
experience in using these files suggested that converting the pdf files
to an advanced pdf format that would allow direct population of
information fields before printing would be helpful.  EPA will work to
develop such improved formats. 

	5(c)	Small Entity Flexibility

The notification requirements under section 103(a) of CERCLA and the
reporting relief available under section 103(f)(2) apply equally to all
firms regardless of size.  There are no special information collection
or record keeping requirements on small businesses.  EPA believes that
the notification system developed under the CRRR represents the minimum
level of reporting necessary for the Federal OSC to evaluate whether a
response action is needed to prevent or mitigate any hazards to public
health and welfare and the environment.  A reduction in the reporting
requirements facing small businesses is not possible without
jeopardizing the quality of the information needed to evaluate the
threat posed by the release and the need for a Federal response.

	5(d)	Collection Schedule

The facility must provide an initial telephone call to the NRC as soon
as the person in charge has knowledge of a hazardous substance release
that equals or exceeds its RQ.  The caller must decide whether to report
the release under CERCLA section 103(a) (i.e., as an episodic release)
or CERCLA section 103(f)(2) (i.e., as a continuous release).  The
reporting and record keeping activities associated with reporting an
episodic release under CERCLA section 103(a) are presented in EPA ICR
No. 1049.10.  If the caller reports a continuous release, the initial
written report required by CERCLA section 103(f)(2) must be provided
within 30 days of the initial telephone call.  In the second year of
reporting, the facility must submit a written follow-up report to the
EPA Region within 30 days of the anniversary date of submission of the
initial written report.  This report is sometimes called the First
Anniversary Report.  Thereafter, the reporting facility is responsible
for reevaluating the release annually, but no reports are required
unless there is a change in the sources or composition of a release, a
change in release information previously submitted, or an  SSI in the
release.

SSIs in a release are considered to be episodic releases and must be
reported as soon as the person in charge is aware that an SSI has
occurred.  If there is a change in the information submitted in the
initial written or follow-up report, other than a change in sources,
composition, or frequency of the release, the person in charge must
submit a letter detailing the change to the EPA Region within 30 days of
determining that a change has occurred.

ESTIMATING THE BURDEN AND COST OF THE COLLECTION

	6(a)	Estimating Respondent Burden

To report a continuous release, the regulated community performs the
following activities (outlined in Section 4(b) of this ICR): (1)
provides an initial telephone notification to the NRC; (2) prepares an
initial written report for the EPA Region; (3) prepares follow-up
written report for the EPA Region on the first-year anniversary of the
submission of the initial written report; (4) conducts an annual
evaluation of the release beginning the year after the submission of the
one-time follow-up written report; (5) reports a change in the sources,
composition, or frequency of the release; (6) reports a change in other
information; (7) reports SSIs in the release; (8) complies with other
activities; and (9) keeps records on the release, including
documentation of the annual evaluation.  Activities (5), (6), (7), and
(8) are conditional activities and are necessary for only a small
fraction of all the continuous releases reported each year.  For
example, SSIs are defined in the CRRR as hazardous substance releases
whose quantity exceeds the upper bound of the normal range, where the
normal range includes all releases of the hazardous substance reported
or occurring during the previous year.  Thus, only a small fraction of
facilities experience SSIs in their continuous releases in a given year.

When calculating the burden and costs in this ICR it is assumed that the
typical facility participates in all the necessary information
collection activities for each release.  For example, the typical
facility will provide an initial telephone notification and written
report for each of its continuous releases.  In fact, it is likely that
many facility operators will consolidate collection activities for
releases at their facility (e.g., provide one telephone notification for
several releases).

The estimated burden hours for each of the activities listed in the
paragraph above are presented in Exhibit 1.  The burden estimates are
taken from the CRRR economic impact analysis and are based on CERCLA
reporting experience, SARA section 313 reporting experience, and
professional judgment.  A description of the basis for each burden
estimate, as well as the percentage of continuous releases for which the
burden is expected to be incurred, is provided in the remainder of this
section.

Providing an Initial Telephone Notification to the NRC – In providing
the initial telephone notification, facilities incur a one-time,
first-year burden of notifying the NRC that a hazardous substance
release is reported under CERCLA section 103(f)(2).  Providing the
required information by telephone to the NRC is estimated to require 15
minutes (0.25 hours) of management time.  Prior to the telephone call,
however, the facility must determine if the release is continuous and
stable in quantity and rate as defined in the CRRR.  This determination
is estimated to require 45 minutes (0.75 hours) of management time and
two hours of technical time.  Forty-five minutes (0.75 hours) of
management time and two hours of technical time should be sufficient to
determine if a release is continuous because facilities likely to be
affected by the CRRR should be familiar with the reporting requirements
of CERCLA section 103.  In total, the burden associated with the initial
telephone call is three hours.

Preparing an Initial Written Report – The burden associated with
providing the initial written report is also a one-time, first-year
cost.  Much of the information required for the initial written report
(e.g., facility identification, hazardous substance identification,
frequency and source of the release) is readily available to the
facility.  Information such as the composition of the release and the
environmental media affected, however, may require more extensive
consideration and analysis.  In addition, some time is needed to
organize and format the required information into a report suitable for
submission to the government.  It is assumed that many facilities will
use EPA’s prepared report format to minimize report organization and
formatting efforts.  Reporting Requirements and sample forms are
available in pdf format on EPA’s internet:   HYPERLINK
"http://www.epa.gov/superfund/resources/release/faciliti.htm." 
http://www.epa.gov/superfund/resources/release/faciliti.htm.  
Preparation of the initial written report that uses EPA’s prepared
report format is estimated to require three hours of managerial time,
three hours of technical time, and one hour of clerical time.  To
account for the burden experienced by the facilities that do not use
EPA’s prepared report format, EPA has increased the technical burden
to four hours.  The costs of photocopying and mailing this report and
all other reports to the appropriate EPA Region are computed in Section
6(b).  Preparation of the initial written report is estimated to require
three hours of managerial time (including one-hour of legal review),
four hours of technical time, and one hour of clerical time.  Thus, the
total burden associated with the initial written report is eight hours.

Preparing a Follow-up Written Report – Within one year of submitting
the initial written report, facilities must submit a one-time follow-up
written report to the appropriate EPA Region.  The follow-up report
requires the same information as the initial written report but serves
to confirm, update, and refine the information provided in the initial
report based on release data from the previous operating year.  Because
some of the technical information gathered for preparation of the
initial written report, such as the source of the release and specific
information describing the environmental media affected, remains
unchanged, preparation of the follow-up report requires less technical
time than preparation of the initial written report.  EPA estimates that
preparation of the follow-up report requires three hours of managerial
time, one hour of technical time, and one hour of clerical time.  In
total, the burden associated with the follow-up written report is five
hours.  The burden associated with the follow-up written report is
incurred in the second year of reporting.

Conducting an Annual Evaluation of the Release – Although the written
follow-up report is prepared and submitted only once, facilities are
required to conduct and document an annual evaluation of each hazardous
substance release reported under section 103(f)(2) beginning the year
after submitting the follow-up written report.  This annual evaluation
is comparable to the review and information collection necessary for
preparation of the follow-up report.  The burden associated with the
annual evaluation, therefore, is assumed to be the same as the burden of
preparing the written follow-up report (five hours).  The burden
associated with the annual evaluation is incurred in the third and all
subsequent years.

Reporting a Change in the Sources, Composition, or Frequency of the
Release – When a facility experiences a change in the sources,
composition, or frequency of a release, the release is considered a new
release because the associated hazard may have changed significantly. 
Changes in the sources, composition, or frequency of a release are
expected to result only from significant changes in the production
process, such as the installation of new equipment or a change in the
chemical nature of the process.  While such significant changes are
expected over the long-term, the likelihood of such a change occurring
in a particular year is small.  EPA estimates that the number of already
reported continuous releases that experience a change in sources,
composition, or frequency is equal to 5 percent of the total number of
hazardous substance releases being reported under the CRRR in any given
year.

          Facilities experiencing a change in the sources, composition,
or frequency of a continuous release must complete the initial
notification process for the release (i.e., an initial telephone call to
the NRC and an initial written report and follow-up report to the EPA
Region).  For facilities experiencing a change in the sources,
composition, or frequency of a continuous release, much of the
information from the previous initial written report (e.g., facility
identifiers, the media affected) should not have changed.  It is assumed
that the technical time required to evaluate the release, determine
whether it is stable in quantity and rate, and accurately document the
composition of the release and the environmental media affected would
take four hours.  The number of management and clerical hours required
to report a new continuous release are assumed to be four hours and one
hour respectively.  Thus, the total burden associated with reporting a
change in the sources, composition, or frequency of a continuous release
is nine hours.

Reporting Other Changes in Information – For changes other than a
change in the sources, composition, or frequency of a release, the
person in charge must notify the EPA Region by letter that the
information previously submitted in support of a continuous release
notification is no longer valid.  For example, the population density in
the vicinity of the facility would be reported by submitting a letter
detailing the change and its cause.  Such changes in information
previously submitted are likely to occur over an extended period of
time, but are much less likely to occur every year.  EPA estimates that,
on an annual basis, approximately 10 percent of the releases reported
under CERCLA section 103(f)(2) will experience a change that requires
submission of a letter to the EPA Region.  Gathering and reporting the
change in the release by a letter to the EPA Region is estimated to
require one hour of managerial time, one hour of technical time, and
one-half hour of clerical time for a total burden of 2 and one-half
hours.

Reporting a Statistically Significant Increase in the Release  – As
soon as the person in charge of a facility has knowledge that the
quantity of a continuous release being reported under CERCLA section
103(f)(2) exceeds the upper bound of its previously established normal
range of release weights, the person in charge must notify the NRC. 
SSIs are episodic release events because the release has not been
previously reported or evaluated.  To avoid underestimating the burden,
this ICR includes the burden for reporting an SSI, even though the
burden may be captured in the ICR for episodic releases (EPA 1409.10). 
The estimated burden of reporting an SSI is based on interviews with
chemical industry personnel and the burden associated with reporting
similar episodic releases under CERCLA section 103(a).  EPA estimates
that reporting of an SSI requires one hour of managerial time and one
hour of technical time for a total burden of two hours.  The technical
time consists of determining if the release is reportable, briefing
management, and collecting the information required for NRC reporting. 
The managerial time includes alerting appropriate personnel and
transmitting the information required in the telephone call.

Because SSIs are defined as releases that exceed the normal range, and
the normal range is defined to include all release quantities recorded
during the previous operating year, EPA estimates that no more than 5
percent of the hazardous substance releases reported under the CRRR will
experience an SSI in a given year.

Other Activities – In response to the government’s processing and
evaluating the initial and follow-up reports, persons in charge of
facilities may be required to: (1) provide additional information or
clarify information previously submitted; and (2) accompany EPA
personnel during a site inspection.

(1)	Providing Additional Information – For some percentage of the
continuous releases reported under the CRRR, the information provided in
the initial and/or follow-up reports will be incomplete, incorrect, or
worrisome, prompting EPA to request additional information regarding the
nature and extent of the release.  For example, EPA may seek additional
information concerning release activity in order to better assess the
risk posed by the release.  EPA estimates that approximately 30 percent
of the initial/follow-up reports could require submission of additional
information or some level of interaction with EPA in the first and
second years of reporting.  Beginning in the third year of reporting,
requests for additional information and further clarification of release
information are assumed to be necessary only for newly reported
releases.  However, this analysis conservatively assumes that the
percentage of reportable releases for which additional information is
necessary will remain at 30 percent for all years of reporting.  For
each hazardous substance report that requires additional communication
with EPA, industry is estimated to expend four hours of managerial time.

(2)	Facilitating a Site Inspection –  In extreme cases, the
preliminary risk assessment of a release will indicate the need for a
site inspection, allowing EPA to directly assess and evaluate the
circumstances of a release and the population and environment
potentially affected by the release.  In addition, site inspections are
conducted periodically as a compliance and enforcement measure.  Site
inspections are estimated to be necessary for no more that one percent
of the reported continuous releases.  EPA estimates that facility
participation in a site inspection requires four hours of managerial
time and four hours of technical time for a total burden of eight hours.

Record keeping – EPA assumes many facilities maintain a log or some
other record of each hazardous substance release reported under the
CRRR.  Facilities may find it useful to collect and record the following
information for use in demonstrating compliance with the provisions of
CERCLA section 103(f)(2): (1) estimates of daily release quantities to
demonstrate the continuity and stability of the release, and to
establish and modify the normal range of the release; (2) documentation
of the methodology and calculations used in estimating required
information; and (3) documentation of the annual assessment required
each year subsequent to submission of the follow-up written report. 
Much of the time necessary to gather these records has already been
attributed to the preparation of the initial and follow-up reports,
however, it is estimated that an additional four hours of technical time
is necessary for keeping records on each hazardous substance release
reported under the CRRR.

Exhibit 1

Unit Burden Hours per Respondent Information Collection Activity

Collection Activity	

When Collection Activity is Performed	

Percentage of Continuous Releases that Will Require a Collection
Activity	

Unit Burden Hours



	

Mgt	

Tech	

Clerical	

Total



Providing an Initial Telephone Notification	

When first reporting a release	

100% of new releases	

1.0	

2.0	

0.0	

3.0



Preparing an Initial Written Report	

 Within 30 days of an initial telephone notification	

100% of new releases	

3.0	

4.0	

1.0	

8.0



Preparing a Follow-up Written Report	

A year after the submission of an initial written report	

100% of all second year releases	

3.0	

1.0	

1.0	

5.0



Conducting an Annual Evaluation of a Release	

Each year beginning the year after the submission of a written follow-up
report	

100% of all third year and subsequent year releases	

3.0	

1.0	

1.0	

5.0



Reporting a Change in the Sources, Composition, or Frequency of a
Release	

When the sources, composition, or frequency of a release changes 	

5% each year of all new and current releases	

4.0	

4.0	

1.0	

9.0



Reporting Other Changes in Information	

Changes in other information 	

10% each year of all new and current releases	

1.0	

1.0	

0.5	

2.5



Reporting an SSI in a Release	

Immediately after an SSI event is noticed 	

5% each year of all new and current releases	

1.0	

1.0	

0.0	

2.0



Other Activities – Providing Additional Information	

Upon EPA request	

30% each year of all new and current releases	

4.0	

0.0	

0.0	

4.0



Other Activities – Facilitating a Site Inspection	

Upon EPA request	

1% each year of all new and current releases	

4.0	

4.0	

0.0	

8.0



Record keeping	

Each year of a release	

100% of all new and current releases	

0.0	

4.0	

0.0	

4.0



The estimated annual burden hours incurred by a “typical” facility
are presented in Exhibit 2.  A typical respondent is assumed to report
eight continuous hazardous substance releases in year one and to
experience a change in one release in the second and third years of
reporting (e.g., the frequency of the release increases from three to
five times a week, causing a modification in the estimated annual
release amount).  No other conditional activities (e.g., SSI reporting
and facilitating a site inspection) are assumed to be required of the
typical respondent; the inclusion of burden estimates associated with
any additional conditional activities may result in a significant
overestimation of the burden incurred by a typical facility. 

Exhibit 2

Burden Hours for a Typical Facility*

Collection Activity	

First Year Burden Hours	

Second Year Burden Hours	

Third Year Burden Hours

	

Mgt	

Tech	

Clerical	

Total	

Mgt	

Tech	

Clerical	

Total	

Mgt	

Tech	

Clerical	

Total



Providing an Initial Telephone Notification	

8.0	

16.0	

0.0	

24.0	

NA	

NA	

NA	

NA	

NA	

NA	

NA	

NA



Preparing an Initial Written Report	

24.0	

32.0	

8.0	

64.0	

NA	

NA	

NA	

NA	

NA	

NA	

NA	

NA



Preparing a Follow–up Written Report	

NA	

NA	

NA	

NA	

24.0	

8.0	

8.0	

40.0	

NA	

NA	

NA	

NA



Conducting an Annual Evaluation of a Release	

NA	

NA	

NA	

NA	

NA	

NA	

NA	

NA	

24.0	

8.0	

8.0	

40.0



Reporting Other Changes in Information	

NA	

NA	

NA	

NA	

1.0	

1.0	

0.5	

2.5	

1.0	

1.0	

0.5	

2.5



Record keeping	

0.0	

32.0	

0.0	

32.0	

0.0	

32.0	

0.0	

32.0	

0.0	

32.0	

0.0	

32.0



Total Burden Hours for a Typical Facility	

32.0	

80.0	

8.0	

120.0	

25.0	

41.0	

8.5	

74.5	

25.0	

41.0	

8.5	

74.5

* A “typical” respondent is assumed to report eight continuous
hazardous substance releases in year one and to experience a change in
one release in the second and third years (e.g., the frequency of the
release per week changes each year, causing a modification in the
estimated annual release amount).  No other conditional activities are
assumed to be required of the typical respondent.

NA = Not Applicable

	6(b)	Estimating Respondent Costs

Labor Costs

The estimated cost to complete various continuous release reports
required under the CRRR is a function of the time expended by industry
personnel (i.e., the burden estimates presented in section 6(a)), and
the hourly wage rates for the appropriate categories of labor.  The
hourly wage rates used for industry in this ICR are from December 2003
and were obtained from the Bureau of Labor Statistics.  For purposes of
this analysis, EPA estimates an average hourly respondent labor cost of
$44.76 for managerial staff, $30.52 for technical staff, and $19.50 for
clerical staff.

These rates reflect employer cost for employee compensation in the
United States as of December 2003 and include both employer costs for
legally required benefits (e.g., social security, worker’s
compensation, and unemployment insurance), other important fringe
benefit categories (e.g., insurance, paid leave, retirement, and
savings), and overhead and general and administrative costs.  Costs
associated with the burden hours presented in Section 6(a) of this ICR
are shown in Exhibit 3.	

Exhibit 3 presents the unit costs to industry of performing the
notification, record keeping, and other activities that may be required
in reporting a continuous release.  The unit cost of each collection
activity is calculated by multiplying the annual burden hour estimates
in Exhibit 2 by the hourly wage rate for the appropriate labor category
(listed above).  Exhibit 4 presents the annual labor cost estimated to
be incurred by a typical facility.  (The reporting pattern assumed for a
typical facility is discussed in Section 6(a) above.)

Exhibit 3

Unit Labor Cost per Respondent Information Collection Activity

Collection Activity	

Burden Hours	

Unit Labor Cost

	

Managerial

$44.76/hr	

Technical

$30.52/hr	

Clerical

$19.50/hr

	

Providing an Initial Telephone Notification	

1.0	

2.0	

0.0	

$105.80



Preparing an Initial Written Report	

3.0	

4.0	

1.0	

$275.86



Preparing a Follow-up Written Report	

3.0	

1.0	

1.0	

$184.30



Conducting an Annual Evaluation of a Release	

3.0	

1.0	

1.0	

$184.30



Reporting a Change in the Sources, Composition, or Frequency of a
Release	

4.0	

4.0	

1.0	

$320.62



Reporting Other Changes in Information	

1.0	

1.0	

0.5	

$85.03



Reporting an SSI in a Release	

1.0	

1.0	

0.0	

$75.28



Other Activities – Providing Additional Information	

4.0	

0.0	

0.0	

$179.04



Other Activities – Facilitating a Site Inspection	

4.0	

4.0	

0.0	

$301.12



Record keeping	

0.0	

4.0	

0.0	

$122.08



Exhibit 4

Annual Labor Costs for a Typical Facility*

Collection Activity	

Annual Burden Hours	

Annual Labor Costs

	

Managerial

$44.76hr	

Technical

$30.52/hr	

Clerical

$19.50/hr	

First Year	

Second Year	

Third Year



Providing an Initial Telephone Notification	

8.0	

16.0	

0.0	

$846.40	

NA	

NA



Preparing an Initial Written Report	

24.0	

32.0	

8.0	

$2,206.88	

NA	

NA



Preparing a Follow-up Written Report	

24.0	

8.0	

8.0	

NA	

$1,474.40	

NA



Conducting an Annual Evaluation of a Release	

24.0	

8.0	

8.0	

NA	

NA	

$1,474.40



Reporting Other Changes in Information	

1.0	

1.0	

0.5	

NA	

$85.03	

$85.03



Record keeping	

0.0	

32.0	

0.0	

$976.64	

$976.64	

$976.64



Total Labor Costs for a Typical Facility	

	

	

	

$4,029.92	

$2,536.07	

$2,536.07

* A “typical” respondent is assumed to report eight continuous
hazardous substance releases in year one and to experience a change in
one release in the second and third years (e.g., the frequency of the
release per week changes each year, causing a modification in the
estimated annual release amount).  No other conditional activities are
assumed to be required of the typical respondent.

NA = Not Applicable

 Annual Capital and Operating and Maintenance Costs

Capital costs usually include any produced physical good needed to
provide the needed information, such as machinery, computers, and other
equipment.  EPA does not anticipate that respondents will incur capital
costs in carrying out the information collection requirements of the
CRRR.

Operating and Maintenance (O&M) costs are those costs associated with a
paperwork requirement incurred continually over the life of the ICR. 
They are defined by the PRA as “the recurring dollar amount of cost
associated with O&M or purchasing services.”  The O&M costs that are
incurred by industries are shown in Exhibit 5.  For this ICR, O&M costs
cover photocopying of report templates to be filled out for each release
source (25 cents per page) and postage and an envelope for reports sent
to the Agency.  There are no O&M costs associated with providing the
initial telephone notification to the Agency or reporting an SSI under
the CRRR.  Each written report, the initial written report, the
follow-up written report, changes in sources, composition, or frequency
of release report, and other changes in information report, are assumed
to require five pages.  Requests for additional information by the
Agency will vary considerably in scope and length, depending on the
nature of the request, however, it is estimated that it will take
industry approximately 10 pages to complete the Agency’s request.  The
postage and mailing costs are assumed to be equal for all documents, and
are calculated as $1.70 postage and $0.30 per envelope, totaling $2.00
per report.  In Exhibit 6, O&M costs for a typical facility are
presented.

Exhibit 5

Unit Operating and Maintenance Costs per Respondent Information
Collection Activity

Collection Activity	

Unit O&M Costs 	

Total Unit O&M Cost

	

Photocopying

($0.25/page)	

Mailing

($2/report)

	

Providing an Initial Telephone Notification	

$0.00	

$0.00	

$0.00



Preparing an Initial Written Report (5pgs/1rpt)	

$1.25	

$2.00	

$3.25



Preparing a Follow-up Written Report (5pgs/1rpt)	

$1.25	

$2.00	

$3.25



Conducting an Annual Evaluation of a Release	

$0.00	

$0.00	

$0.00



Reporting a Change in the Sources, Composition, or Frequency of a
Release (5pgs/1rpt)	

$1.25	

$2.00	

$3.25



Reporting Other Changes in Information (5pgs/1rpt)	

$1.25	

$2.00	

$3.25



Reporting an SSI	

$0.00	

$0.00	

$0.00



Other Activities – Providing Additional Information (10pgs/1rpt)	

$2.50	

$2.00	

$4.50



Other Activities – Facilitating a Site Inspection	

$0.00	

$0.00	

$0.00



Record keeping (5pgs)	

$1.25	

$0.00	

$1.25



Exhibit 6

Operating and Maintenance Costs for a Typical Facility*

Collection Activity	

Unit O&M Costs	

Total Unit Cost

	

Photocopying

($0.25/page)	

Mailing

($2/report)	

First Year	

Second Year	

Third Year 



Providing an Initial Telephone Notification	

$0.00	

$0.00	

NA	

NA	

NA



Preparing an Initial Written Report - 8 rpts @ (5pgs/1rpt)	

$1.25	

$2.00	

$26.00	

NA	

NA



Preparing a Follow-up Written Report - 8 rpts @ (5pgs/1rpt)	

$1.25	

$2.00	

NA	

$26.00	

NA



Reporting Other Changes in Information - 8 rpts @ (5pgs/1rpt)	

$1.25	

$2.00	

NA	

$3.25	

$3.25



Record keeping - 8 rpts @ (5pgs)	

$1.25	

$0.00	

$10.00	

$10.00	

$10.00



Total O&M Costs for a Typical Facility	

	

	

$36.00	

$39.25	

$13.25

* A “typical” respondent is assumed to report eight continuous
hazardous substance releases in year one and to experience a change in
one release in the second and third years (e.g., the frequency of the
release per week changes each year, causing a modification in the
estimated annual release amount).  No other conditional activities are
assumed to be required of the typical respondent.

NA = Not Applicable

Annual labor and O&M costs incurred by the regulated community are
summarized in Exhibit 7.

Exhibit 7

Unit Labor and Operating and Maintenance Costs per

Respondent Information Collection Activity

Collection Activity	

Unit Labor Cost	

Unit O&M Cost	

Total Unit Costs



Providing an Initial Telephone Notification	

$105.80	

$0.00	

$105.80



Preparing an Initial Written Report	

$275.86	

$3.25	

$279.11



Preparing a Follow-up Written Report	

$184.30	

$3.25	

$187.55



Conducting an Annual Evaluation of a Release	

$184.30	

$0.00	

$184.30



Reporting a Change in the Sources, Composition, or Frequency of a
Release	

$320.62	

$3.25	

$323.87



Reporting Other Changes in Information	

$85.03	

$3.25	

$88.28



Reporting an SSI in a Release	

$75.28	

$0.00	

$75.28



Other Activities – Providing Additional Information	

$179.04	

$4.50	

$183.54



Other Activities – Facilitating a Site Inspection	

$301.12	

$0.00	

$301.12



Record keeping	

$122.08	

$1.25	

$123.33



In Exhibit 8, annual labor and O&M costs for a typical facility are
presented.

Exhibit 8

Labor and Operating and Maintenance Costs for a Typical Facility*

Collection Activity	

Total Labor Costs	

Total O&M Costs	

Total Costs

	

First Year	

Second Year	

Third Year	

First Year	

Second Year	

Third Year	

First Year	

Second Year	

 Third Year



Providing an Initial Telephone Notification	

$846.40	

NA	

NA	

NA	

NA	

NA	

$846.40	

NA	

NA



Preparing an Initial Written Report	

$2,206.88	

NA	

NA	

$26.00	

NA	

NA	

$2,232.88	

NA	

NA



Preparing a Follow-up Written Report	

NA	

$1,474.40	

NA	

NA	

$26.00	

NA	

NA	

$1,500.40	

NA



Conducting Annual Evaluations	

NA	

NA	

$1,474.40	

NA	

NA	

NA	

NA	

NA	

$1,474.40



Reporting Other Changes in Information	

NA	

$85.03	

$85.03	

NA	

$3.25	

$3.25	

NA	

$176.56	

$176.56



Record keeping	

$976.64	

$976.64	

$976.64	

$10.00	

$10.00	

$10.00	

$2,959.92	

$2,959.92	

$2,959.92



Total Costs for a Typical Facility	

$4,029.92	

$2,536.07	

$2,536.07	

$36.00	

$39.25	

$13.25	

$6,039.20	

$4,636.88	

$4,610.88

* A “typical” respondent is assumed to report eight continuous
hazardous substance releases in year one and to experience a change in
one release in the second and third years (e.g., the frequency of the
release per week changes each year, causing a modification in the
estimated annual release amount).  No other conditional activities are
assumed to be required of the typical respondent.

NA = Not Applicable

	6(c)	Estimating Agency Burden and Costs

To comply with the provisions of the CRRR, Federal government
authorities perform the following activities (see also Section 5(a) of
this ICR):  (1) process initial telephone notification; (2) process
initial written report; (3) process follow-up written report; (4)
process change in the sources, composition or frequency of release
reports; (5) process other changes in information; (6) process SSI 
reports; and (7) conduct other necessary activities (obtain additional
information, conduct site inspection).  The estimated burden to the
Federal government for completing each of these CRRR-mandated activities
is based on the CRRR economic impact analysis.  The CRRR Economic Impact
is available in rule making Docket Number 103(f)CR - 4-8.

Exhibit 9 presents the estimated burden-hours and unit cost associated
with the Federal government’s processing and evaluation of the various
continuous release reports, as well as the burden and cost associated
with any other government initiated activities that may involve the
collection of information.  The unit cost estimates presented in Exhibit
9 are derived by multiplying the applicable burden estimates by the
average hourly wage rate for government employees.  Based on the 2004 GS
pay schedule, EPA estimates an average hourly labor cost of $40.56 for
the average Federal government employee.  A full description of the
basis for each government burden estimate is provided in the remainder
of this section.

 Process Initial Telephone Notification – EPA estimates that the NRC
requires 30 minutes (0.5 hours) to process the information provided in
the initial telephone call.  The first year unit cost associated with
processing the initial telephone call is $20.28.

Process Initial Written Report – Government authorities review initial
written and follow-up reports to become familiar with the nature and
extent of the release, to determine if the release qualifies for reduced
reporting under CERCLA section 103(f)(2), and to assess the hazards to
public health and welfare and the environment.  EPA estimates that the
preliminary evaluation of the release requires on average, one and one
half hour of government time.  The costs of processing and evaluating
the initial written report are incurred in the first year of reporting. 
Therefore, the unit cost for processing and evaluating the initial
written report is $60.84.

Process Follow-up Written Report -- Within one year of submitting the
initial written report, facilities must submit a written follow-up
report to update and confirm previously submitted information.  The
follow-up report provides EPA with a more accurate baseline against
which to evaluate both the threat posed by the release and the impact
that SSIs in the

release may have on public health and welfare and the environment.  The
activities necessary to reevaluate the continuous release with the newly
submitted follow-up report are assumed to be identical to those required
to process and evaluate the initial written report, one and a half hour.
 The costs associated with the follow-up written report, however, are
incurred in the second year of reporting.  Therefore, the unit cost for
processing and evaluating the follow-up written report is $60.84.

Process a Change in the Sources, Composition, or Frequency of a Release
Report – After initial notification reports have been submitted for a
release and reporting under section 103(f)(2) has commenced, EPA must be
notified of any changes in release information previously submitted. 
Any change in the sources, composition, or frequency of a hazardous
substance release constitutes a new release.  Thus, any facility
experiencing a change in the sources, composition, or frequency of a
continuous release must complete the initial notification process for
the new release.  Government activities associated with new release
reports consist of the processing and evaluation of the initial
telephone and initial written reports, 2 hours.  The applicable unit
cost is $81.12 per new continuous release report.

Process Other Changes in Information – For changes in a release other
than a change in the sources, composition, or frequency, the person in
charge must notify the EPA Region by submitting a letter presenting the
updated information and explaining the reasons for the change.  EPA
estimates that processing a letter of changed information requires
approximately 30 minutes (i.e., 0.50 hours) of government time.  This
estimate consists of the time necessary evaluate the release in light of
the changed information.  The shorter evaluation time is assumed because
it is necessary to evaluate only the incremental change in the risk
using previous assessments of the release (assumed to be on file) as a
baseline.  The applicable unit cost is $20.28 per changes in a release
report.

Process an SSI (Statistically Significant Increase) Report – SSIs are
episodic releases and must be reported immediately to the NRC.  Release
quantities in excess of the normal range have not been previously
reported and evaluated and, thus, warrant immediate reporting.  Upon
receiving notification of an SSI, the NRC will record the SSI
information in the NRC data base (15 minutes) and notify the appropriate
EPA Region of the SSI report (15 minutes).  Upon notification from the
NRC (15 minutes), EPA will evaluate the potential hazard posed by the
release in light of the SSI (30 minutes).  Thus, the Federal government
is estimated to require one hour and fifteen minutes (1.25 hours) of
government time to process and evaluate each SSI reported under the
CRRR.  The applicable cost is $50.70 per SSI Report.

Other Activities – For some percentage of continuous releases, the
information provided in the initial and/or follow-up reports will be
incomplete, incorrect, or worrisome, prompting EPA to request additional
information concerning the release and its associated hazard.  For
example, additional information may be necessary to confirm the
continuity and stability of the release or to better assess the risk
posed by the release.  EPA estimates that the process of requesting and
reviewing additional information concerning a continuous release
requires 2.0 hours of government time.  The applicable unit cost is
$81.12 per request and review of additional information.

In extreme cases, the preliminary risk assessment of a release will
suggest the need for a site inspection, allowing EPA to directly assess
and evaluate the circumstances of a release and the population and
environment potentially affected by the release.  In addition, site
inspections are conducted periodically as a compliance and enforcement
measure.  EPA estimates that site inspections will require eight hours
of government time, including one hour allocated for the EPA Region to
communicate its concerns and findings to the appropriate SERC and LEPC,
and will cost $324.48.

Exhibit 9

Unit Burden Hours and Costs Incurred by the

Government per Information Collection Activity

Collection Activity	

Burden Hours ($40.56/hr)	

Unit Cost



Process Initial Telephone Notification	

0.50	

$20.28



Process Initial Written Report	

1.50	

$60.84



Process Follow-up Written Report	

1.50	

$60.84



Process a Change in the Sources, Composition, or Frequency of a Release
Report	

2.00	

$81.12



Process Other Changes in Information	

0.50	

$20.28



Process an SSI Report	

1.25	

$50.70



Other Activities – Obtaining Additional Information	

2.00	

$81.12



Other Activities – Conducting a Site Inspection	

8.00	

$324.48



	6(d)	Estimating the Respondent Universe and Total Burden and Cost

The estimates presented in this ICR regarding the number of facilities
and hazardous substance releases affected by the CRRR were computed
using the number of CR-ERNS notifications made by the NRC to each
respective region over the years 2001, 2002, and 2003 as reported by the
NRC.  The number of reports to be filed in the next three years is
computed from the total number of reports already filed and reflects the
number of annual reports in recent years.  EPA has estimated that each
affected facility has 8 continuous releases above the releases’ RQs. 
Exhibit 10 summarizes the estimated number of facilities and hazardous
substance releases already affected by the CRRR.  The change report
adjustment reflects 10% of the total number of facilities and reports
for all regions.  Exhibit 11 presents the estimate for the number of
facilities and hazardous substance releases that will be affected by the
CRRR in the next three years.  The estimate is based on an expected 7.5%
average annual percent increase in facilities (see 6(f)) adjusted from
the number of continuous release notifications reported by the NRC for
2003.

Exhibit 10

Number of Facilities and Hazardous Substance Releases Already Affected
by the CRRR

	

Total Estimated Number of Facilities with Continuous Releases	

Estimated Number of Reportable Continuous Releases (3 years)



EPA Region 1	

138	

1,104



EPA Region 2	

150	

1,200



EPA Region 3	

259	

2,072



EPA Region 4	

747	

5,976



EPA Region 5	

565	

4,520



EPA Region 6	

703	

5,624



EPA Region 7	

415	

3,320



EPA Region 8	

190	

1,520



EPA Region 9	

163	

1,304



EPA Region 10	

165	

1,320



Minus Change Reports (10%)	

(350)	

(2,800)



Total in CR-ERNS 	

3,145	

25,160



Exhibit 11

Number of Facilities and Hazardous Substance Releases

That Will Be Affected by the CRRR in the Next Three Years

	

Total Estimated Number of Facilities with Continuous Releases	

Estimated Number of Reportable Continuous Releases



Estimated New Releases in the First Year	

62	

497



Estimated New Releases in the Second Year	

67	

534



Estimated New Releases in the Third Year	

72	

574



Total Over Next Three Years	

201	

1,604



Total in CR-ERNS After Three Years 	

3,346	

26,264



	6(e)	Bottom Line Burden Hours and Costs

The total estimated and annual burden hours and costs incurred by
industry affected by the CRRR are presented in Exhibit 12.  The total
and annual hours and costs incurred by industry are calculated over a
three year period.  Exhibit 13 presents the total and annual estimated
burden hours and costs incurred by government authorities as a result of
the CRRR over a three year period.  Exhibit 14 summarizes the estimated
burden hours and costs incurred by industry.  The bottom line burden to
industry is approximately 277,862 hours for the first year and 284,000,
and 290,600 hours for the second and third years, respectively.  The
bottom line industry labor costs are approximately $9,793,785,
$10,010,095, and $10,242,654 for the first, second, and third years,
respectively.  The bottom line industry O&M costs are approximately
$86,109, $84,215, and $86,238 for the first, second, and third years,
respectively.   The average burden hours for industry over a three year
period is 284,154 at an average labor cost of $10,015,511 and O&M cost
of $85,521.   Exhibit 15 summarizes the estimated burden hours and costs
incurred by government.  The bottom line burden to the government is
approximately 26,329 hours for the first year, 25,189 for the second,
and 25,837 for the third year.  The bottom line cost to the government
is approximately $1,067,899, $1,021,687, and $1,047,939, respectively. 
The average burden hours for the government over a three year period is
25,785 hours, at an average annual costs of $1,045,842.  

	6(f)	Reasons for Change in Burden

This ICR increases the burden incurred by industry, as a result of
compliance with the CRRR, from 249,451 to 284,154 estimated average
burden hours.  This increase in burden results primarily from the use of
data on the actual number of continuous release reports from several
regions and applying a growth rate consistent with prior years
reporting.  The average annual percent increase in facilities in the
previous ICR was approximately 7.5%.  The same percent increase was
assumed for this ICR.  The unit burden hours per respondent information
collection activity (Exhibit 1) remains the same as the previous ICR.  

	6(g)	Burden Statement

The reporting and record keeping burden for this collection of
information is estimated to average approximately 87 hours per affected
facility (284,154 total burden hours/3,276 affected facilities), or 10.9
hours per response (where we estimate 8 responses/facility - see note to
Exhibit 6), including determining if the hazardous substance release
qualifies for reporting under the CRRR, gathering and maintaining the
required information, and completing and reviewing the written reports. 
Burden means the total time, effort, or financial resources expended by
persons to generate, maintain, retain, or disclose or provide
information to or for a Federal agency.  This includes the time needed
to review instructions; develop, acquire, install, and utilize
technology and systems for the purposes of collecting, validating, and
verifying information, processing and maintaining information, and
disclosing and providing information; adjust the existing ways to comply
with any previously applicable instructions and requirements; train
personnel to be able to respond to a collection of information; search
data sources; complete and review the collection of information; and
transmit or otherwise disclose the information.  An agency may not
conduct or sponsor, and a person is not required to respond to, a
collection of information unless it displays a currently valid OMB
control number.  The OMB control numbers for EPA’s regulations are
listed in 40 CFR part 9 and 48 CFR chapter 15.     

To comment on the Agency’s need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID No.
SFUND-2000-0008, which is available for public viewing at the Office of
Solid Waste and Emergency Response Docket in the EPA Docket Center
(EPA/DC), EPA West, Room B102, 1301 Constitution Ave., NW, Washington,
DC. The EPA Docket Center Public Reading Room  is open from 8:30 a.m. to
4:30 p.m., Monday through Friday, excluding legal holidays.  The
telephone number for the Reading Room is (202) 566-1744, and the
telephone number for the Office of Solid Waste and Emergency Response
Docket is (202) 566-0276.  An electronic version of the public docket is
available through EPA Dockets (EDOCKET) at   HYPERLINK
"http://www.epa.gov/edocket."  http://www.epa.gov/edocket.    Use
EDOCKET to submit or view public comments, access the index listing of
the contents of the public docket, and to access those documents in the
public docket that are available electronically.  Once in the system,
select “search,” then key in the docket ID number identified above. 
Also, you can send comments to the Office of Information and Regulatory
Affairs, Office of Management and Budget, 725 17th Street, NW,
Washington, DC 20503, Attention: Desk Office for EPA.  Please include
the EPA Docket ID No.  (SFUND-2000-0008) and OMB control number
(2050-0086) in any correspondence. 

Exhibit 12

Annual Burden Hours and Costs Incurred by Industry





Collection Activity

	

# of Reported Releases that Require the Collection Activity Over Three
Years	

Unit Burden Hours	

Unit Labor Costs*	

Unit O&M Costs*	

Burden Hours 

Over Three Years	

Labor Cost 

Over Three Years	

O&M Costs 

Over Three Years

	

1st Year	

2nd Year	

3rd Year





1st Year	

2nd Year	

3rd Year	

1st 

Year	

2nd 

Year	

3rd 

Year	

1st 

Year	

2nd 

Year	

3rd 

Year



Providing Initial Telephone Notification	

497	

534	

574	

3.00	

$105.80	

$0.00	

1,491	

1,602	

1,722	

$52,583	

$56,497	

$60,729	

$0	

$0	

$0



Preparing Initial Written Report	

497	

534	

574	

8.00	

$275.86	

$3.25	

3,976	

4,272	

4,592	

$137,102	

$147,309	

$158,344	

$1,615	

$1,736	

$1,866



Preparing Follow-up Written Report	

1,624	

497	

534	

5.00	

$184.30	

$3.25	

8,120	

2,485	

2,670	

$299,303	

$91,597	

$98,416	

$5,278	

$1,615	

$1,736



Conducting Annual Evaluations	

21,656	

23,280	

23,777	

5.00	

$184.30	

$0.00	

108,280	

116,400	

118,885	

$3,991,201	

$4,290,504	

$4,382,101	

$0	

$0	

$0



Reporting a Change in the Sources, Composition, or Frequency of a
Release	

1,283	

1,310	

1,338	

9.00	

$320.62	

$3.25	

11,546	

11,786	

12,044	

$411,307	

$419,868	

$429,070	

$4,169	

$4,256	

$4,349



Reporting Changes in Other Information	

2,566	

2,619	

2,677	

2.50	

$85.03	

$3.25	

6,414	

6,548	

6,691	

$218,161	

$222,702	

$227,583	

$8,339	

$8,512	

$8,699



Reporting an SSI	

1,283	

1,310	

1,338	

2.00	

$75.28	

$0.00	

2,566	

2,619	

2,677	

$96,573	

$98,583	

$100,743	

$0	

$0	

$0



Other Activities–– Additional Information	

7,697	

7,857	

8,030	

4.00	

$179.04	

$4.50	

30,788	

31,429	

32,118	

$1,378,089	

$1,406,771	

$1,437,602	

$34,637	

$35,358	

$36,133



Other Activities–– Site Inspection	

257	

262	

268	

8.00	

$301.12	

$0.00	

2,053	

2,095	

2,141	

$77,258	

$78,866	

$80,595	

$0	

$0	

$0



Record keeping	

25,657	

26,191	

26,765	

4.00	

$122.08	

$1.25	

102,628	

104,764	

107,060	

$3,132,207	

$3,197,397	

$3,267,471	

$32,071	

$32,739	

$33,456



Total	

	

	

	

	

	

	

277,862	

284,000	

290,600	

$9,793,785	

$10,010,095	

$10,242,654	

$86,109	

$84,215	

$86,238



Exhibit 13

Annual Burden Hours and Costs Incurred by Government

Collection Activity

	

# of Reported Releases Estimated to Require the Collection Activity Over
Three Years	

Unit Burden Hours	

Unit Cost	

Burden Hours Over Three Years	

Cost Over Three Years

	

1st Year	

2nd Year	

3rd Year

	

1st Year	

2nd Year	

3rd Year	

1st Year	

2nd Year	

3rd Year



Processing Initial Telephone Notification	

497	

534	

574	

0.50	

$20.28	

249	

267	

287	

$10,079	

$10,830	

$11,641



Processing Initial Written Report	

497	

534	

574	

1.50	

$60.84	

746	

801	

861	

$30,237	

$32,489	

$34,922



Processing Follow-up Written Report	

1,624	

497	

534	

1.50	

$60.84	

2,436	

746	

801	

$98,804	

$30,237	

$32,489



Processing a Change in the Sources, Composition, or Frequency of a
Release Report	

1,283	

1,310	

1,338	

2.00	

$81.12	

2,566	

2,619	

2,677	

$104,065	

$106,231	

$108,559



Processing Other Change in Information	

2,566	

2,619	

2,677	

0.50	

$20.28	

1,283	

1,310	

1,338	

$52,032	

$53,115	

$54,279



Processing an SSI Report	

1,283	

1,310	

1,338	

1.25	

$50.70	

1,604	

1,638	

1,673	

$65,040	

$66,417	

$67,849



Other Activities–– Obtaining Additional Information	

7,697	

7,857	

8,030	

2.00	

$81.12	

15,394	

15,715	

16,059	

$624,389	

$637,384	

$651,353



Other Activities–– Site Inspection	

257	

262	

268	

8.00	

$324.48	

2,053	

2,095	

2,141	

$83,252	

$84,985	

$86,847



Total	

	

	

	

	

	

26,329	

25,190	

25,837	

$1,067,899	

$1,021,687	

$1,047,939



Exhibit 14

Summary of Burden Hours and Costs Incurred by Industry

	

First Year	

Second Year	

Third Year	

Average (over a three year period)



Total Number of Respondents	

3,207	

3,274	

3,346	

3,276



Total Burden Hours	

277,862	

284,000	

290,600	

284,154



Total Labor Costs   (thousand $)	

$9,794	

$10,010	

$10,243	

$10,016



Total O&M Costs   (thousand $)	

$86	

$84	

$86	

$85



Exhibit 15

Summary of Burden Hours and Costs Incurred by Government

	

First Year	

Second Year	

Third Year	

Annual Average



Total Burden Hours	

26,329	

25,190	

25,837	

25,785



Total Cost (thousand $)	

$1,068	

$1,022	

$1,048	

$1,046



APPENDIX A

Phone-Log Summaries

The following calls were made between August 20, 2004 and September 2,
2004.  The companies were selected from the universe of facilities for
which a continuous release notification was made.  Persons responsible
for making notifications were queried about the internal process and
procedures taken at the facility between the time a release is observed
and a call is made to the NRC and through the 30 day follow-up report,
one year anniversary report and any additional reports required that
resulted from changes to the continuous release. 

Eastman Kodak

Private Enterprise

Rochester, NY

Incident Report #647410

On June 10, 2003 Eastman Kodak called the NRC to report a continuous
release of material from a cooling tank.  On August 20, 2004, the HQ EPA
CR-ERNS analyst spoke with the person responsible for developing
procedures for reporting releases.  The facility has procedures that
have been in place for a while.  The incident was also reported to state
officials.  The release includes fugitives that occur during the year. 
The company spokesperson did not have any questions about the reporting
process.

Kraft Foods North America

Private Enterprise

North Field, IL

Incident Report #653094

On August 6, 2003, Kraft Foods called the NRC to report a continuous
release of material from oven stacks (power stack).  On August 20, 2004,
the HQ EPA CR-ERNS analyst spoke with the person responsible for
reporting releases.  The company representative indicated that the
sample forms that EPA has posted on the internet were straight forward. 
Also reported to the state and county.  The company representative
commented that the exact address to send the written follow-up reports
is not provided.  The written report was sent to the general Region 3
address (the incident took place in Richmond, VA).  Felt that it would
be helpful if a better, more direct address is easier to find.  EPA will
update its internet site to provide appropriate addresses for each
region.

Armstrong World Industries

Private Enterprise

Jackson, MS

Incident Report #722572

On May 21, 2004, Armstrong World Industries called the NRC to make an
initial report for the continuous release of residual vinyl chloride. 
On August 20, 2004, the HQ EPA CR-ERNS analyst spoke with the person
responsible for reporting releases. The company representatitve
indicated that the reporting process is fairly well defined by EPA
regulations.  The individual did not have any other comments - he is
actually no longer with company and he gave me a name and contact
information for an individual at corporate headquarters in Lancaster, PA
responsible for overall corporate coordination of environmental
reporting.  The HQ EPA CR-ERNS analyst called the person.  This
individual did not have any comments at the time, but offered to call
back if after review of his files had any comment.  As of September 3,
2004, there has not been further communication.

Goodyear Tire and Rubber

Private Enterprise 

Houston, TX

Incident Report #648038

On June 16, 2003, Goodyear Tire and Rubber called the NRC to make an
report of a statistically significant increase for an existing
continuous release report of ammonia from closed loop refrigeration
system.  On September 2, 2004, the HQ EPA CR-ERNS analyst spoke with the
person responsible for reporting releases. The individual did not have
any questions about the reporting process.  The individual indicated
that the company spends about 1.5 days evaluating their release each
year.  They have only one chemical covered under the Continuous Release
Reporting Regulations.

Ft. James Operating Co.

Private Enterprise 

Green Bay, WI

Incident Report #728498

On July 16, 2004, Ft. James Operating Co. called the NRC to make an
report of a change to the upper bounds for three chemicals or a
statistically significant increase (SSI) for an existing continuous
release report of hydrogen flouride, chloroform and biphenyl.  On
September 2, 2004, the HQ EPA CR-ERNS analyst spoke with the person
responsible for reporting releases. The individual provided some
valuable feedback on the reporting process.  The individual indicated
that when she made her initial report to the NRC in 2002 she had
problems conveying the information to the individual at the NRC who
answered the call.  Apparently the NRC staff person did not understand
what an initial report to the NRC on continuous releases was.  This time
there was some confusion as to which numbers should be used for
reporting - the original incident number or the new number assigned for
the SSI report.  The HQ EPA CR-ERNS analyst answered that both numbers
should be used so that the region can pair the reports.  The company
representative would also like to see interactive forms on the internet
for CR-ERNS reporting.  This will be explored further now that Adobe
(pdf formatting) has advanced.

Responsibility for information collection activities of the CRRR now
resides in the Office of Emergency Management (OEM) in the Office of
Solid Waste and Emergency Response (OSWER).

That data base is available at: 
http://www.nrc.uscg.mil/incident97-02.html.

Docket Number 103(f)CR is now SFUND-1990-0005 (edocket identifier);
however, none of the original documents are available electronically
through edocket.

 Bureau of Labor Statistics’ news release dated, February 26, 2004,
entitled “Employer Costs for Employer Compensation - December 2003”
listed hourly compensation (wages and salaries plus fringe benefits)
rates for civilian managerial, technical, and clerical workers. 
Therefore, the wage rates used in this ICR include salaries, fringe
benefits, overhead costs and general and administrative costs as of
December 2003.

 Exhibit 8 does not include capital costs because there are no capital
costs associated with implementing the regulations of the CRRR.

 This hourly wage estimate was calculated by summing the basic hourly
wage rate for a GS-12 step 1 government employee in 2004 ($25.35) and
the hourly monetary value of the representative employee’s fringe
benefits (assumed to be the basic hourly wage rate multiplied by 60
percent).

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OMB Submission****OMB No. 2050-0086****October 1, 2004

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OMB Submission****OMB No. 2050-0086****October 1, 2004

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