  SEQ CHAPTER \h \r 1 Supporting Statement for ICR 1463.07

Part A.										

1. Identification of the Information Collection

1(a) Title:  

National Oil and Hazardous Substances Pollution Contingency Plan
(NCP)(Renewal), EPA ICR 1463.07, OMB Control Number 2050-0096

	

1(b) Abstract:  

ICR 1463.07 is a renewal of ICR 1463.06; the renewal is due January 31,
2008.  ICR 1463.07 addresses the portion of the NCP that details the
requirements for remedial activities at sites on the National Priority
List (Superfund Sites).  The NCP is the rule that stipulates
requirements for fulfilling the legislative mandates of the
Comprehensive Environmental Response, Compensation, and Liability Act of
1980 as amended (CERCLA or Superfund).  This ICR covers remedial
activities conducted at State-lead sites, participation by community
members at all Superfund sites, Federally-conducted community
involvement activities, and Federal oversight of State activities.  The
information collected via these activities is critical to characterizing
contamination at sites, determining appropriate remedies and goals for
cleanup, and involving the community in the process.  All of these steps
help ensure that some of the nation’s worst hazardous waste sites are
cleaned up in a manner that is protective of human health and the
environment, and, where practical, returned to productive use.

2. Need for and use of the Information Collection

	

2(a) Need/Authority for Collection:

		

CERCLA authorizes the President to undertake removal and remedial
actions in response to releases, or threats of releases, of hazardous
substances and certain pollutants and contaminants into the environment.
 Revisions were made to the NCP in 1982 to incorporate the provisions of
CERCLA. These revisions to the NCP established procedures for data
collection, analysis, and reporting to be conducted during remedial and
removal responses at Superfund sites.  Subsequent revisions to the NCP
in 1985 added additional procedures.  Finally, the Superfund Amendments
and Reauthorization Act of 1986 (SARA) amended CERCLA and mandated,
among other provisions, that the NCP be revised within 18 months of the
date of enactment of SARA to incorporate provisions of the new law (42
USC 9605(b)).  The revised NCP, published in March 1990, included new
reporting and record keeping provisions for Superfund remedial responses
as described in 40 CFR 300.430 and 300.435.  

		

EPA uses the information provided by the States to ensure State actions
are consistent with the provisions of CERCLA and SARA and that their
decisions are protective of human health and the environment. EPA uses
the information gathered from private citizens to plan activities geared
to educating them where necessary, keeping them informed of activities
within the community, and ensuring they have had an opportunity to
assume an active role in the decision making process that affects their
community.  EPA also uses information from private citizens to measure
the effectiveness of community involvement activities and to improve
those activities as needed.  EPA believes involvement of the members of
the community surrounding a Superfund site is critical to ensuring
effective site cleanups.			

	

2(b) Practical Utility/Users of the Data

		

The lead agency, whether EPA or the State, conducts many data-gathering
activities, including development of the Remedial
Investigation/Feasibility Study (RI/FS) and the preparation of the
Proposed Plan and the Record of Decision (ROD).  This data is used by
the lead agency to make informed decisions regarding remedial responses.
When States assume the lead agency responsibilities, EPA Regions use the
information collected to oversee States in the conduct of remedial
responses at hazardous waste sites.  Specifically, this information is
used to ensure that remedies are selected in accordance with CERCLA and
the NCP, that cleanup standards are attained, and that community
concerns are appropriately addressed.  The data are also made available
to the public and may help community members understand health risks and
participate in site-related decisions. 

		

States also identify all potential applicable, relevant, and appropriate
requirements (ARARs) at all State- and Federal-lead sites during the
RI/FS.  The ARARs are used to determine cleanup levels and to select the
remedy to be used at a site.  ARARs include chemical-specific,
location-specific, and action-specific levels that may need to be met at
a site for it be determined protective of human health and the
environment.  These levels may be contained in federal statues, such as
the Safe Drinking Water Act or the Endangered Species Act, or in State
laws, which must be used if the levels are more stringent than those
promulgated in a corresponding federal statute.

		

Community interviews and information provided by community groups are
used by the lead agency to ensure public involvement in site-related
decisions, as required by CERCLA and SARA, and provide appropriate
opportunities for the community to learn about the site.  EPA uses the
information gathered through research instruments, such as satisfaction
surveys, to obtain timely feedback on the community involvement process
at the site level.  Communities are viewed as integral participants in
the Superfund cleanup process and their early and often involvement can
often expedite cleanup and result in future reuse that meets the
communities’ needs. 

3. Non-duplication, consultations, and other ICR criteria

	

3(a) Non-duplication

	

Duplication of other Federal data collection efforts is expected to be
minimal.  Site information is gathered cumulatively from identification
through remedial action.  To the extent practicable, respondents are
encouraged to use information in the site file to inform other
subsequent activities at the site.

3(b) Public Notice Required Prior to ICR submission to OMB

		

The Paperwork Reduction Act requires that ICRs be made available to the
public for comment prior to submission to OMB.  This is done through two
notices to the Federal Register.  The first Federal Register Notice,
which describes the ICR and provides numbers for burden hours and costs
and solicits public comment, was published on August 22, 2007.  A 60-day
comment period was given; no comments were received.  The second Federal
Register Notice will be published at the same time the ICR is submitted
to OMB.  This notice states that the ICR has been submitted and provides
an abstract and final burden numbers.

3(c) Consultations

In addition to EPA Regional offices, State representatives participated
in NCP workgroup meetings leading to the 1990 NCP revisions.  State
representatives provided guidance on avoiding problems associated with
implementation of the NCP requirements.  The public and other Federal
and 

State agencies also had the opportunity to submit comments on the
proposed revisions to the NCP (53 

FR 51394; December 21, 1988).  These comments are addressed in the
preamble to the final rule and 

in the Response to Comments document supporting the final rule. 

An EPA Superfund database which is updated daily and contract records
from the past eight years provide a basis for some estimates in this
ICR.  Estimates are also informed by specific consultation with subject
matter experts in both EPA Headquarters and Regional offices. 
Discussions with these experts involved feedback on the accuracy of
burden and cost estimates.  Agency experience in addressing community
issues has included semi-annual or annual meetings with Regional
community involvement staff, meetings with groups of States, and
meetings with citizen groups. 

		

3(d) Effects of Less Frequent Collection

Information is collected as appropriate to the remedial stage of the
Superfund process.  The frequency of these collections vary depending on
several factors at the site, such as complexity of issues, cleanup
technology used, level of community interest, and duration of cleanup. 
Information collection frequencies outlined in the NCP are the minimal
amount necessary to ensure cleanup of NPL sites and the proper
implementation of CERCLA.

3(e) General Guidelines

States have at least 30 days in which to respond to any information
requests specified in the NCP.  This time frame is in compliance with
the Paperwork Reduction Act guidelines.  The record retention period for
administrative records is not specified in the NCP.  The site records
are to be maintained for the duration of remedial responses at sites and
for as long as necessary for litigation purposes.  Responsibility for
these files will continue beyond the 3 year ICR period as cleanups
typically take more than 3 years.

 						

3(f) Confidentiality

The nature of the data being gathered as part of this information
collection is not confidential. 

Information may be gathered from Potentially Responsible Parties (PRPs)
that the PRP considers to be 

Confidential Business Information (CBI).  When information is designated
as CBI by a PRP, EPA 

follows restricted access procedures in handling the information.  These
procedures include keeping the 

information in locked areas and only allowing CBI-cleared personnel
access to the information.  PRP 

information is gathered in anticipation of litigation.  EPA, therefore,
does not have to grant Freedom of 

Information Act requests for this information. 

Lists of participants in community interviews and lists of attendees of
public meetings are not 

confidential.  Some data gathered during community interviews may not be
releasable, however, due to 

privacy concerns. 

3(g) Sensitive Questions

The information gathering activities discussed in this ICR generally do
not involve any sensitive 

questions. 

4. Respondents and Information requested

4(a) Respondents/SIC Codes

		

Respondents to this ICR are State/Tribal governments and individual
community members who voluntarily participate in the remedial phase of
the Superfund program and in associated community involvement activities
throughout the Superfund process.  SIC Codes are OSHA’s Standard
Industrial Classification System used to identify different groups. 
State/Tribal governments are categorized as Division J: Public
Administration, Major Group 95: Administration of Environmental Quality
and Housing Programs, Industry Group 951: Administration of
Environmental Quality, subgroup 9511: Air and Water Resource and Solid
Waste Management.  The other respondents, community members, do not have
a SIC Code as they do not constitute an industry.

	

4(b) Information requested

This ICR requests information from States at State-lead sites as it
relates to CERCLA activities.  Each of the following categories will be
addressed in detail in this section: RI/FS, Proposed Plans, RODs, ARARs,
Administrative Record, initial and revised Community Involvement Plans
(CIP), Fact Sheets, focus groups, and workshops.  Information is also
requested on a voluntary basis from community members at all active
Federal and State lead sites.  The following community activities will
be addressed in detail in this section: initial and revised CIP
interviews, focus group participation, workgroup participation, TAG
application, TAG management, and satisfaction surveys. Federal
activities will be discussed in a subsequent section of this document.

(i) Data items, including record-keeping requirements

Remedial Investigation/Feasibility Study

The first step in conducting the RI/FS, which is authorized under CERCLA
§104 (42 USC 

9604(a)(1); 40 CFR 300.430), is the development of a project plan, which
describes the scope and content of the RI/FS and includes work plans. 
Work plans are developed as part of the project plan and detail the site
management strategy.  The work plans identify initial boundaries of the
study area, likely remedial response objectives, operable units (if
any), and the procedures that will be followed to satisfy the strategy.
In addition, an initial site evaluation is presented in the typical work
plan.  This evaluation includes:

	- Site description;

	- Preliminary definition of the contamination problems;

	- Likely contaminant migration pathways;

	- Environmental and health effects associated with migration; and

	- Description of any initial remedial measures for the site.

A preliminary assessment of remedial alternatives may be included in the
work plan.  The data requirements necessary to support the selection of
a remedy are also discussed.  

Based on preliminary site information, the objectives and the scope of
work for the RI and FS are developed.  The scope of work for the RI
includes many components, including plans for project operations that
will be followed in conducting a survey of the study area, in
characterizing the source of contamination, and in identifying Federal
and State ARARs.  The work plan also includes procedures that will be
followed in evaluating contamination pathway and transport, and in
evaluating the potential risk to public health posed by the site.  Plans
for testing the feasibility of remedial technologies may also  be
included.  Initial data quality objectives, quality assurance procedures
that will be followed, procedures to be followed in preparing the RI
report, and information on the technical and financial management of the
RI project also are discussed in the RI scope of work section of a site
work plan. 

The sampling and analysis plan for a site  is developed during the
scoping phase of the RI. 

 This plan describes the sampling, calibration, and analytical
procedures that will be followed in 

collecting air, water, soil, and source samples.  Additionally, quality
assurance objectives to be met throughout the sampling task are
discussed.  These objectives include procedures that will be followed to
ensure the accuracy and precision of the analysis, as well as the
completeness, representativeness, and 

comparability of the sampling.  Hundreds of samples are taken during the
typical RI, and the analysis of 

the site samples provides basic information on the concentration,
source, and potential paths of 

migration of contaminants at a site.  Sampling and analysis plans
generally include a project description 

that summarizes the site history, environmental setting, and project
objectives such as the media to be 

sampled, sampling locations on the site, and sampling schedule.  A
health and safety plan is drafted 

that identifies potentially hazardous operations and exposures, and
prescribes appropriate protective 

measures. 

In the scope of work for the FS, procedures are established for
developing remedial 

alternatives for the site.  Alternative screening and analysis
procedures, methods for conducting a 

comparative evaluation of acceptable alternatives, and details on
preparing the FS report are 

included. 

Concurrent with the preparation of the RI work plan, EPA conducts
community interviews, as 

required by the NCP, in preparation for the required Community
Involvement Plan, which must be 

finalized before any RI field work begins. 

Upon completion and approval of the work plans and sampling and analysis
plans, the RI/FS 

can begin.  The RI/FS includes site work, analysis of data, and
preparation of the RI report.  Drilling 

and sampling detailed in the sample and analysis plan requires not only
time spent at the site boring 

holes in the earth and taking air and water samples, but also time to
mobilize drilling equipment and to 

train personnel in the sampling and decontamination techniques to be
used at the site.  Upon completion 

of the site work, the samples are sent to a laboratory for evaluation,
and the results of the analyses are 

verified.  Standard evaluation techniques include analyzing samples for
organics, metals, and cyanide. 



The RI serves as the mechanism for collecting data for site and waste
characterization and for 

conducting treatability testing as necessary to: (1) evaluate the
performance and cost of the treatment 

technologies considered for use at a site; and (2) support the design of
selected potential remedies.  The FS serves as the mechanism for the
development, screening, and detailed evaluation of potential remedial 

alternatives.  The RI and FS are conducted concurrently.  Data collected
in the RI influence the 

development of remedial alternatives in the FS, which in turn affects
the data needs and scope of 

treatability studies and additional field investigations.  The site
characterization developed during the RI 

provides the data necessary to estimate the risks to human health and
the environment posed by a site, 

to establish cleanup goals or ranges, and to identify viable cleanup
alternatives.  The FS draws upon the 

data collected and analyzed during the RI in the process of developing
alternatives and conducting a 

detailed analysis of the most viable alternatives.  Because of the
interactive nature of this process, the 

sequence of the various phases and associated activities frequently will
not be distinct in practice. 

A risk assessment is conducted during the RI to estimate the health
consequences of exposure 

to contaminants at a site.  In this assessment, the physical and
chemical properties of hazardous 

substances and their toxicological effects are studied to determine the
potential for the substances to cause adverse health effects, and the
likely pathways and magnitude of exposure of populations and/or 

individuals near the site.  An evaluation of dose-response information
is completed to estimate the 

health effects (e.g., incident of certain diseases) that may result from
exposure to the hazardous or 

toxic substances at a site. 

A risk characterization brings together the exposure and the
dose-response information to 

predict the likely range and severity of health effects that may occur
as a result of the substances at a 

site, and the number of people affected.  Included as an integral part
of the risk assessment process is 

the uncertainty evaluation, which identifies the degree of uncertainty
associated with the final risk 

estimates by identifying uncertainties related to the data and the
assumptions.  This evaluation of 

uncertainties places bounds on the final estimate and target areas
needing improvement.  The FS process includes the initial evaluation and
screening of a number of potential alternatives.  Alternatives are
eliminated from further evaluation for a number of reasons, including
technical problems, lack of effectiveness in the long term or short
term, failure to protect human health and the environment, cost, or
implementation time.  The universe of potential remedies is reduced to a
reasonable number (usually between three and five) of good alternatives
on which detailed analyses are conducted.  If existing site and
treatment data are insufficient to evaluate the alternatives adequately,
treatability tests may be necessary to evaluate a particular technology
or specific site wastes.  Treatability tests generally involve
bench-scale testing to assess the feasibility of a technology, although
a pilot-scale study may be required in a few situations. 

Once sufficient data are available, alternatives are evaluated in detail
with respect to nine 

evaluation criteria: protection of human health and the environment;
compliance with ARARs; long-term 

effectiveness and permanence; reduction of toxicity, mobility, or
volume; short-term effectiveness; 

implementability; cost; support agency acceptance; and community
acceptance.  The alternatives are 

evaluated individually against each criterion and then relative to other
alternatives to understand 

the strengths and weaknesses of each alternative.  At the end of this
analysis process, the 

RI/FS report is prepared. 

For the purposes of this analysis, EPA estimates that there will be an
average of 12 RI/FS per year.  This estimate includes new and on-going
RI/FS.  The State-lead portion of these RI/FS is estimated to be 2 RI/FS
per year over the three-year ICR period.  The Federal government will
have the lead on the 10 remaining sites per year.  These estimates are
based on data obtained from a Superfund database concerning new sites
entering the remedial phase of the Superfund process.  The average
represents actual numbers from the previous ICR period and planned data
for the renewal ICR period. On average, 90% of RI/FS are completed
within 2-5 years (13-60 mos.) of the start date.  This average
represents an analysis of actual and planned date from Fiscal Year (FY)
2001 to FY 2006, grouped both by 3 year ICR periods and across the
years.  The number of RI/FS that EPA expects at both Federal and State
lead sites represents an average taken across each three year grouping
for number of starts and for total time to completion.

	

Proposed Plans

The requirement to issue a Proposed Plan was added to the remedial
process by SARA, (42 

USC 9617(a); 40 CFR 300.430(f)(2)).  This document is to be prepared by
the lead agency, in 

consultation with the support agency, at a site after completion of the
RI/FS report and prior to 

selection of a response action.  The lead agency's primary objective in
preparing and releasing the Proposed Plan is to seek public comment on
the preferred alternative for addressing a problem at a 

site, and on the other alternatives discussed in the detailed analysis
section of the RI/FS.  The Proposed Plan serves as a precursor to the
Record of Decision (ROD), which details the remedial action to be
conducted at the site.  The ROD is usually is draft form while the
Proposed Plan is finalized and released for public comment.

The Proposed Plan is written using information from the RI/FS report. 
The purpose of the 

Proposed Plan is to highlight the RI/FS report, provide a brief analysis
of remedial alternatives under 

consideration, identify a preferred alternative, and provide the public
with information on how they can 

participate in the remedy selection process. 

In developing the Proposed Plan, the lead and support agencies first
review the RI/FS report 

prepared for a site, identify an initial preferred alternative, and
prepare a draft Proposed Plan.  The lead 

agency's management is briefed on the draft Proposed Plan, which is then
forwarded to the support 

agency for comments.  At the end of the support agency review period,
the Proposed Plan is finalized 

and released to the public for comment. 

CERCLA, as amended, also requires the lead agency to publish a brief
notice and description 

of the Proposed Plan in a local newspaper of general circulation.  As
required by CERCLA §117(a) 

(42 USC 9617(a)), this notice includes information sufficient to provide
a reasonable explanation of the 

preferred alternative and the other alternatives studied.  This notice
will also announce the availability of 

the RI/FS report and any planned public participation activities,
especially the required Proposed Plan 

Public Meeting and 30-day comment period. 



Finally, CERCLA §l17 requires the lead agency to offer the opportunity
for a public meeting to discuss and answer questions and to obtain
feedback about the RI/FS report and the Proposed Plan.  The lead agency
establishes a date and time for the meeting, reserves a facility, and
arranges for any special needs.  The lead agency also designs the
meeting program, including identifying specific issues and tasks to be
addressed, preparing an agenda, identifying presenters, and rehearsing
presentations.  Printed materials, visual aids or graphics, and other
materials are prepared and special arrangements made, such as hiring a
court reporter.  Finally, the meeting is held, and a transcript of the
meeting notes is prepared by the lead agency.  The transcript is made
available to the public as required by CERCLA §117. 

Because the Proposed Plan typically is followed closely in time by the
ROD, the total number estimated to be written annually at State-lead
sites is based on data collected for RODs.  Proposed Plans are completed
in a discrete amount of time and are assumed not to extend beyond one
year.  The ROD data comes from the Superfund database and will be
discussed in detail in the following section.  EPA estimates that
Proposed Plans will be finalized at 4 State-lead sites in each year of
the 3 years covered by this ICR.

Records of Decision

The lead agency prepares a ROD in response to the statutory requirements
in CERCLA §l13 

(42 USC 9613) for a statement of basis and purpose of the selected
remedy at a site and in CERCLA 

§117 (42 USC 9617), which calls for a remedial action plan to be
adopted and released to the public. 

 The ROD is prepared by the lead agency in consultation with the support
agency for a site.  It is the 

decision document used to describe the selected remedy for a site or a
particular component of a site 

(e.g., geographic area, pathway, or source control), and to explain the
rationale for the selected 

remedy.  In addition, RODs demonstrate the lead agency's decision-making
process has been carried 

out in accordance with CERCLA and the NCP. RODs typically have three
major sections: the 

Declaration, the Decision Summary, and the Responsiveness Summary.  All
RODs are signed by EPA Regional Administrators or the Assistant
Administrator for OSWER.  In addition, a representative from 

a State may sign a ROD. 

The Declaration is the formal statement (signed by the EPA Regional
Administrator or the 

Assistant Administrator of OSWER) which affirms that the selected remedy
for a site is selected in 

accordance with CERCLA and is consistent, to the extent practicable,
with the NCP.  It provides a 

brief description of the selected remedy.  The Decision Summary is the
focus of the ROD. The Summary begins with a brief discussion of the site
history and a detailed site description, including: 

	-Site area and topography, 

	-Adjacent land uses; 

	-Natural resource uses; 

	-Distance to nearby populations; 

	-General water resources, and 

	-Surface and subsurface features. 

Next, the history of State and Federal site investigations and CERCLA
enforcement actions at the site 

are summarized.  This historical summary is followed by a discussion of
the community involvement 

activities that have been conducted for the site. 

The Decision Summary summarizes the scope of the response action and the
site characteristics.  The site characteristics section draws on
information presented in the RI/FS report and includes details on: 

	-Types, quantity, and concentration of hazardous substances at a site: 

	-All known or suspected sources of contamination;

	-All known or potential routes of migration, including the mobility,
toxicity, and volume of waste;

	-Lateral and vertical extent of contamination at the site; and 

	-Potential surface and subsurface pathways of migration.

Maps illustrating the location of units or contaminants and charts of
contaminant types and

concentrations often are used in the site characterization section of
the Decision Summary.  In addition,

the results of the site risk assessment and any significant changes made
to the preferred alternative in the

Proposed Plan are summarized.

Another major component of the Decision Summary is the evaluation of the
remedial alternatives considered for the site and identification of the
selected remedy.  The evaluation of alternatives section first presents
a brief description of each of the remedial alternatives.  Each
alternative for which a detailed analysis was completed (typically five)
is discussed.  These discussions include: 

	-Summaries of the technology considered, such as in-situ treatment,
clean closure, or thermal 

treatment; 

	-The type and quantity of waste to be contained or treated; and 

	-The major ARARs and standards being met or utilized for specific
components of the waste 

management process. 

The estimated capital and O&M costs, as well as estimated implementation
time of alternatives, also 

are presented.  A comparative analysis is presented in which the
remedial alternatives are evaluated 

based on the nine criteria described under the RI/FS process and
comments on the Proposed Plan.  At 

the end of this analysis, the selected remedy is highlighted as a remedy
that meets the statutory 

requirements of CERCLA and provides the best balance among the
evaluation criteria. 

The Decision Summary concludes with a detailed discussion of the
selected remedy.  The 

summary presents the risk levels to be attained after implementation of
the remedy and summarizes the 

cleanup objectives for the different media at the site.  Finally, the
selected remedy section of the 

Decision Summary demonstrates that the selected remedy complies with the
statutory requirements in 

CERCLA §121 (42 USC 9621), that is, the remedy will protect human
health and the environment, 

attain Federal and State ARARs, be cost-effective, and utilize permanent
solutions and alternative 

treatment technologies or resource recovery technologies to the maximum
extent practicable.  A 

discussion of the extent to which the selected remedy fulfills the
statutory preference for treatment that 

reduces the mobility, toxicity, or volume of the principal threats at a
site is presented in this section. 

 

The final component of the ROD is the Responsiveness Summary, which is a
requirement in 

CERCLA §117 (42 USC 9617).  This part summarizes the written and oral
public comments received 

on the RI/FS report, the Proposed Plan, and the Administrative Record
and the lead agency's responses 

to each major category of comments.  The Responsiveness Summary not only
provides decision 

makers with information about community preferences regarding the
remedial alternatives considered 

for a site, but also demonstrates to the public how their comments were
taken into account as an 

integral part of the decision making process. 

In preparing the Responsiveness Summary, background research is done to
identify citizen 

input and concerns.  In this process, transcripts of the public meeting
on the RI/FS report and the 

Proposed Plan are reviewed, major public comments are organized and
summarized, and the lead 

agency's responses to these comments are prepared.  The level of effort
to be devoted to this section of 

the ROD varies, depending in part on the number, length, and complexity
of comments and the number 

of policy issues outstanding at a site.

For the purposes of this ICR, it is estimated that 4 RODs will be
completed annually at State-lead sites over the three-year ICR period,
while 46 RODs will be completed annually by the Federal government. 
This average is based on data in a Superfund database concerning the
actual number of RODs issued each year since 1995 and those planned
through 2007.  The average takes into account that planned numbers
routinely are higher than actual numbers.  The averages from the
database match well with a 2001 EPA ROD Accomplishment Report.

Applicable or Relevant and Appropriate Requirements

SARA added a requirement to CERCLA §121(d) (42 USC 9621(d)) that all
remedial actions 

must be in compliance with promulgated State ARARs that are more
stringent than Federal ARARs. 

To this end, the current revisions to the NCP require States to identify
potential State ARARs for all 

Federal, State, or Federal facility lead sites.  States are not
reimbursed for any costs associated with researching and identifying
ARARs for a site.

Potential State ARARs are to be identified as early in the RI/FS process
as possible.  Therefore, the estimate of sites where ARAR identification
is necessary is based on RI/FS start data from a Superfund database. 
The average for each type of site is taken across actual and planned
dates for RI/FS starts.  It is estimated that a total of 45 sites (10
Federal-lead, 2 State-lead, 33 Federal facilities) will require ARAR
identification each year.

Administrative Records

SARA amended CERCLA §113 to require that an Administrative Record be
established to document the basis for selection of response action.  The
record must be made available to the public at a location near the site
(42 USC  9613 (1)).  As a result, two records, one near the site and one
at the lead agency office, are compiled and maintained at each remedial
site.  In developing the records, an appropriate location for the record
must be identified.  This location must be publicly accessible.  Then,
documents included in the record must be maintained by updating
information as necessary, and verifying the information is available
that should be included in the record.  The information record will be
maintained as long as site remediation continues and for as long as is
needed in the event there is litigation.  Because remedial responses
often last longer than three years, the record keeping associated with
remedial responses typically will be maintained for more than three
years. 



The Administrative Record must be maintained at all active Superfund
sites each year.  For the purposes of this ICR, active sites are those
that have not yet achieve the Construction Complete milestone.  These
sites may have studies pending, design and study underway, or
construction underway.    Based on historical program data, EPA
estimates there to be approximately 550 active Federal and State lead
Superfund sites.  For State-lead action of RI/FS, RD, and RA, States
have historically had the lead on 20% of sites.  This percentage of
active sites also is applicable for the revised CIP, fact sheets, and
focus groups.  Therefore, it is estimated that the State will maintain
the administrative record at 100 sites each year.

Initial Community Involvement Plan(CIP)/Revised CIP

Community Involvement Plans are developed at remedial sites to identify
community concerns 

and to select techniques and approaches to use in addressing these
concerns.  The initial CIP 

developed for a site presents the community involvement program that is
to be followed during the 

RI/FS stage of the remedial phase.  The NCP requires the CIP be
completed and in place before field 

work begins for the RI.  However, as the Agency seeks to accomplish RI
field work during preremedial 

actions to expedite cleanups, EPA is finding it necessary to begin its
community involvement 

activity, including preparation of the CIP, very early in the
pre-remedial phase.  The NCP also requires 

that EPA review its CIP prior to the Remedial Design/Remedial Action
phase, and make any changes 

necessary to accommodate changes in the community. 

The initial steps in the preparation of CIPs involve conducting a review
of the site and the 

surrounding community.  Lead agency technical personnel summarize the
problems at a site, the origins 

of those problems, and potential steps for addressing the problems.  As
part of this process, lead 

agency files on the site are reviewed and local newspaper files are
searched.  Once a basic 

understanding of the site and previously performed activities is
established, community involvement 

personnel from the lead agency conduct interviews with local community
members to better determine 

community concerns and the level of community knowledge of site
activities.  In this process, a contact 

list is prepared, interviews are scheduled and conducted, and the
results of the interviews are 

summarized.  This process also includes the use of interviews for the
purpose of establishing baseline 

measures of citizen concerns and attitudes from which changes can be
measured, as well as to gain 

additional information that will help in the preparation of the CIP. 

Once the background research is completed, a community involvement
program is designed. 

 This program may recommend such activities as distributing information
brochures and fact sheets that 

explain Superfund program activities and the role of the lead agency in
the remediation of Superfund sites.  Small group meetings between lead
agency staff, citizens, and local officials may be held to promote an
informal exchange of ideas.  To maximize the potential to bring about
improvement in government services, EPA will utilize telephone
interviews of fact sheet recipients and meeting attendees to assess the
effectiveness of specific outreach products.  EPA may also use focus
groups to gather citizen input.  At some sites, formal community groups
may be established that provide regular involvement and input to site
activities. 



Prior to commencement of the Remedial Design/Remedial Action stage, the
CIP is reviewed to determine whether it should be revised to address the
community concerns at that time. These plans are written as 5-year plans
that are renewed every three years.  This cycle will be followed at all
active sites throughout the duration of remedial activities.  The
process for preparing the revised CIP is essentially the same as that
followed in preparing the initial CIP: 

	-Background research is conducted on activities that have occurred
since the CIP was first 

written or last revised; 

	-Community interviews are planned and conducted; 

	-The community involvement program is revised to address the current
citizen 

concerns; and 

	-The CIP document is revised. 

Since the Initial CIP is developed concurrent with the RI/FS, the
estimated number of sites at which the State will conduct an RI/FS each
year is applied to the Initial CIP.  Therefore, EPA expects 2 CIPs to be
completed by States each year of the three-year ICR period. 
Federal-lead sites are expected to complete 10 initial CIPs each year. 
CIPs are revised every 5 years for all active Superfund sites. 
Superfund data indicates that States have the lead on approximately 100
active Superfund sites.  Therefore, a rough estimate is that each year
20 of these sites will require a CIP revision.  EPA estimates that CIPs
will be revised at 80 active Federal-lead Superfund sites each year. 

Fact Sheets

The lead agency provides fact sheets to communities at various points,
both pre and post Construction Completion, in the Superfund remedial
process.  The number and frequency of fact sheets developed varies
depending on community interest, complexity of remedial technologies,
PRP/enforcement issues, and the extent of relocation and reuse
potentials.  Fact sheets may describe the details of a specific
technology used, the physical changes that may occur at the site, the
extent of contamination and health risks, the status of enforcement
actions and negotiations with PRPs, etc.  The lead agency develops fact
sheets on an “as needed” basis.  These fact sheets may be mailed to
a list of interested community members.  

EPA estimates that the States are the lead agency for 100 active
Superfund sites and, thus, are expected to write fact sheets for these
sites.  A group of experienced EPA Headquarters and Regional Community
Involvement staff estimate that an average of 4 fact sheets will be
completed at each active Superfund site.  Because of the site-specific
need for fact sheets, it is anticipated that some sites will generate
far more than 4 fact sheets in a single year and other sites will
require the writing of hardly any.

Focus Groups

	

For this ICR, focus groups are defined as meetings or sessions the
purpose of which is to obtain community input and in which the lead
agency asks the community specific questions.  These groups typically
involved a small select group of community members who are gathered to
provide feedback from the community perspective on particular on-going
issues and concerns.  A group of EPA Headquarters and Regional Community
Involvement staff provided information and estimates for this analysis. 
EPA estimates that focus groups will be conducted an average of 4 times
per year at 1% of active sites (1 at State-lead sites, 4 at Federal-lead
sites).

Workshops

	

This ICR defines workshops as meetings or sessions that are open to the
general public and whose subject matter is broad in scope.  These
workshops are often used as planning tools in which specific broad
overview questions are asked of the community to gather ideas about
their visions for the site and potential future uses.  EPA Headquarters
and Regional Community Involvement staff estimate that a workshop is
conducted at 2% (currently ~10 sites) of all active sites each year. 
Since the State has the lead on 20% of active sites, EPA estimates that
the State will prepare and conduct a workshop at 2 sites annually.  EPA
estimates that it will conduct a workshop at 8 Federal-lead sites each
year.

Technical Assistance Grant Application/TAG Management

SARA amended CERCLA §117(e) to provide for Technical Assistance Grants
(TAGs) to eligible community groups for an initial grant up to $50,000. 
The purpose of these grants is to give communities that are affected by
Superfund sites the opportunity to obtain expert information and
consultation about the site.  The TAG allows community groups to hire an
independent advisor who can help them understand various technical
aspects of the site, such as characteristics of the contamination, the
proposed remedies, the remedial design, the technical aspects of the
remedy, the health risk and analysis, and site construction.  TAGs may
be renewed to facilitate public participation throughout the Superfund
remedial process.  Community groups apply for TAGs and manage those that
they already have.  TAGs are processed and granted by the Federal
government.  There is no State burden or cost for TAGs.  EPA Community
Involvement staff estimate that 15 TAG applications will be filed and
120 maintained each year.

	

Satisfaction Surveys

	

Satisfaction surveys are used by EPA to gather community input about
EPA’s community involvement efforts.  These surveys consist of up to
ten questions asking community members to provide opinions and to rank
EPA’s community interactions, the level of knowledge citizens have
gained about the site and issues, how citizens learned information about
the site, and the desires of the community for how they would like to
interact with EPA.  The information gathered in these satisfaction
surveys help EPA improve it’s community involvement activities and
relationships with communities at Superfund sites.  EPA estimates that
these surveys will be completed at 5 active Superfund Federal-lead sites
each year.  Information and estimates about these surveys are provided
by EPA Headquarters Community Involvement staff who are involved in
administering these surveys.



(ii)Respondent Activities

In complying with reporting and record-keeping requirements at
State-lead sites, State 

employees may need to: 

	-Read instructions; 

	-Plan activities; 

	-Receive training; 

	-Gather information; 

	-Conduct tests, investigations, and studies; 

	-Write documents; 

	-Process, compile, and review information for accuracy and
appropriateness; 

	-Complete written forms or other paperwork; 

	-Substantiate claims of confidential business information; 

	-Record and disclose information; and 

	-Store, file, and maintain the information. 

 

In identifying ARARs at Federal, State, and Federal facility lead sites,
State employees may need to: 

	-Gather information on new state laws and regulations; 

	-Process, compile, and review information for accuracy and
appropriateness; 

	-Record and disclose information; and 

	-Store, file, and maintain information. 

In participating in the remedial phase, community members may disclose
information to State and EPA

personnel during interviews.  Community members may perform any or all
of the following activities: 

	-Participate in interviews;

	-Participate in focus groups;

	-Participate in workshops;

	-Apply for a Technical Assistance Grant (TAG)

	-Manage a TAG; and

	-Respond to surveys. 

5. Information collected: Agency activities, collection methodology,
information management

5(a) Agency activities

Agency activities that relate to the information gathered from States
are predominantly oversight functions at State-lead sites to ensure that
the Superfund sites are being addressed according to CERCLA and to
EPA’s current policies.  In this role, the Agency may obtain, review,
and maintain the information gathered by States.  The Agency also
reviews the State ARARs at all Superfund sites.  A standard 10% of
annual hours is applied to Federal oversight of the following State
activities: RI/FS, Proposed Plans, RODs, ARAR evaluation, and initial
and revised CIPs.  A group of experienced EPA Headquarters and Regional
Community Involvement employees provided the oversight hours estimates
for all other activities: Administrative Record, fact sheets, focus
groups, and workshops.

At all Federal-lead sites, the Agency conducts the following activities:
maintaining the Administrative Record, initial CIP, revised CIP, fact
sheets, focus groups, workshops, TAG applications, TAG management, and
satisfaction surveys.

5(b) Collection methodology and management

	

The information collection methodology varies depending on the type of
activity being conducted.  For example, an RI/FS requires many more
hours than other activities because it involves field work and 
sampling.  In contrast, evaluation of ARARs involves systematic and
routine research.  A large component of Proposed Plans and RODs is the
actual preparing and finalizing of the document.

States provide information to EPA Regional Offices in the form of
document copies.  Regions review the documents to ensure consistency
with the NCP.  Regions and States use various media avenues (e.g., 
local newspaper announcements, mailings, etc.) to notify the public
about meetings, focus groups, and workshops.  The Regions and States may
also communicate with Community Advisory Groups (CAGs) and other
involved citizen groups.  Phone calls and office hours are other means
by which the governments communicate with communities.

The activities reflected in this ICR do not lend themselves to
automation because of the 

decentralized nature of each remedial activity.  These activities are
site-specific and, therefore, are not 

conducive to mass data collection efforts.  The NCP does not specify a
particular method of accomplishing information collection; the use of
improved information technology is not prohibited in 

any way.  

5(c) Small entity flexibility

		

Information collection from small entities (individual community
members, community organizations, etc.) is primarily done on a voluntary
basis.  Since these respondents are providing information voluntarily,
the Federal government is not placing any undue burden on small entities
and does provide plenty of flexibility.

5(d) Collection schedule

	

Information is collected according to the sequence of remedial
activities at Superfund sites: RI/FS, ARAR evaluation, Proposed Plan,
ROD, and initial Community Involvement Plan (CIP).  Other activities are
conducted throughout the remedial process as needed.  These include
maintenance of the Administrative Record, revising the CIP, issuing fact
sheets, processing Technical Assistance Grants (TAGs), gathering
community satisfaction surveys, and conducting focus groups and
workshops with community members.  The frequency of these activities
will depend on many site-specific factors such as complexity of clean-up
technologies, level of community interest, and duration of each of the
remedial stages.



6. Estimating the burden and cost of the Information Collection

6(a) Estimating respondent burden

Respondent burden estimates are calculated from a combination of
sources: historic and projected data from Superfund databases, contract
records, consultation with EPA Headquarters and Regional staff, and
information contained in the 2004 version of this ICR.  Burden hours are
estimated for the number of hours expected annually for each activity. 
The annual hours per activity figure is multiplied by the number of
sites expected to be engaging in the activity every year.  This
calculation gives the total annual hours for all sites by activity.  All
burden hours, with the exception of ARARS, placed on States refer to
only activities conducted at State-lead sites.  All burden hours placed
on communities refer to activities that are conducted at all Federal and
State-lead sites.

The estimated number of respondents reported for this information
collection is 7,970.  This number is the sum of all State-lead
activities, 280, and people participating in community activities at all
sites, 7690.  The estimated number of responses is 8,498.  This is the
sum of State responses, 583 State-lead activities at all sites each
year, and community responses, 7,915 people participating in all
activities at all sites.  

(i) State Burden Hours

		

The total hours for an RI/FS is assumed to consist of 80% contractor
work and 20% government work.  The total contractor hours for an RI/FS
project, 4200 hours, is calculated from Office of Superfund Remediation
and Technology Innovation (OSRTI) contract records from 1996 through
2006.  Data for costs billed as direct labor across all projects and
years provides information about the number of hours spent on an average
RI/FS.  Burden hours can be divided among different labor categories
based on contract records: 62% professional labor, 30% direct labor, 4%
clerical labor, and 4% technical labor.  Total contractor hours per
RI/FS is estimated to be 4,200 hours per year, which is estimated to
account for 80% of the hours for an RI/FS.  The remaining 20% of RI/FS
work, 1,050 hours, is done by the State government.  Therefore, the
total annual time devoted to a single RI/FS is estimated to be 5,250
hours.  This ICR estimates that 2 State-lead sites will be in the
process of conducting an RI/FS every year.  The total annual burden
hours is 10,500 (Table 1).

					

Total burden hours for each Proposed Plan is estimated to be 80 hours. 
This figure covers the time taken for writing, printing, notification,
and distribution of the Proposed Plan.  This estimate remains the same
from the previous ICR renewal.  Since Proposed Plans are expected to be
completed at 4 State-lead sites each year, a total annual estimate of
burden is 320 hours.  These estimates are confirmed by EPA Headquarters
and Regional management.

The hours required to complete a ROD are highly variable across the
Superfund program given site complexity and enforcement issues.  The
burden hours for a ROD are assumed to include the time needed for
writing, reviewing, negotiating, and obtaining concurrence.  The ROD
finalization process is one that takes quite a lot of time and energy. 
The estimates are based on consultation with EPA staff experienced in
writing RODs and involved in writing the ROD guidance document (“A
Guide to Preparing Superfund Proposed Plans, Records of Decision, and
Other Remedy Selection Decision Documents,” EPA 540-R-98-031, OSWER
9200.1-23.P, July 1999).  Experience with very complex and more
straight-forward RODs was used in calculating an average value for ROD
burden hours.  For the purpose of this ICR it is estimated that the
average ROD requires a total of 1,300 hours.  This estimate is based on
a 9 month time frame in which one full-time employee dedicates 50% of
work time to the ROD for a total of 720 hours, and, two full-time
employees dedicate 20% of work time for a total of 576 hours.  The
former employee is typically the Remedial Project Manager (RPM) for the
site and the latter two employees consist of policy analysts, attorneys,
and managers.  This ICR estimates that RODs will be completed at 4
State-lead sites each year; thus, the estimated total annual ROD burden
to States is 5,200 hours.

The total estimated annual burden for identification of ARARs is 33
hours at each Federal, State, or Federal facility lead site.  This
estimate is the same as the ARAR estimate in the previous version of
this ICR.  The figure is also confirmed by EPA staff experienced in
evaluating ARARs.  ARARs are expected to be evaluated at 45 sites
annually, resulting in an estimated burden of 1,485 hours.

											

The establishment and maintenance of one site’s Administrative Record
is estimated to take 40 hours annually.  Since States are estimated to
have the lead on 100 active Superfund sites, EPA expects States to spend
4,000 total hours on Administrative Records.  This estimate is provided
by a group of experienced EPA Headquarters and Regional staff.

Total estimated annual burden hours for each initial and revised CIP are
200 and 100, respectively.  Initial CIPs are estimated to be completed
at 2 State-lead sites each year for a total annual burden of 400 hours. 
Revised CIPs are estimated to be completed at 20 State-lead sites each
year for a total annual burden of 2,000 hours.  These hours are
estimated by a group of EPA Headquarters and Regional staff experienced
in the development and revisions of CIPs.

EPA estimates that each fact sheet will require an average of 40 hours
of work per year.  This estimate is the result of discussion by a group
of experienced EPA Headquarters and Regional Community Involvement
staff.  An average of 4 fact sheets are expected at each of the 100
estimated State-lead active sites.  Therefore, fact sheets will require
a total annual estimate of 160 burden hours at each site.  EPA estimates
that States will issue fact sheets at 100 active sites per year.  Thus,
the total estimated annual burden hours for fact sheets is 16,000.

The estimated time that each focus group session will require of the
State is 30 hours.  This includes preparation for the meeting and
attendance.  EPA expects the State to conduct 4 focus group sessions at
one site in each year, resulting in a total annual estimated burden of
120 hours.  These estimates are provided by a group of experienced EPA
Community Involvement staff.

The estimated annual burden for each workshop is 80 hours.  EPA
estimates that the State will be conducting 1 workshop at 2 sites in the
course of one year and will, thus, devote 160 hours to workshop efforts.
 These estimates are based on the knowledge of EPA Community Involvement
staff experienced in preparing and conducting workshops at Superfund
sites.

Table 1:  Estimated Burden Hours placed on States

Activity	 # of Sites with State-lead Activities/yr	 # of Activities at
each site/yr.	Hrs. per Activity/yr	Annual Hrs. for Activity at a Site
Total Annual Hrs. for all Sites

RI/FS	2	1	5,250	5,250	10,500

Proposed Plans	4	1	80	80	320

RODs	4	1	1,300	1,300	5,200

ARARs	45	1	33	33	1,485

Administrative Record	100	1	40	40	4,000

Initial CIP	2	1	200	200	400

Revised CIP	20	1	100	100	2,000

Fact Sheets	100	4	40	160	16,000

Focus Groups	1	4	30	120	120

Workshops	2	1	80	80	160











	TOTAL	40,185







	

(ii) Community Burden Hours

	

All community burden hours are due to voluntary participation in
activities at Superfund sites.  The Paperwork Reduction Act (PRA)
requires the inclusion of information gathering activities in which the
community participates.  These activities are those for which
information is expressly collected from community members.  The PRA (5
CFR part 1320, “Controlling Paperwork Burdens on the Public,  FRN
8/29/1995, Sect. 1320.3 (h)(8)) excludes the following activities from
the definition of information for the purpose of Information Collection
Requests: attendance at public informational meetings or briefings,
response to comments on EPA documents, participation in community groups
for which EPA is not a sponsor, reading fact sheets, and making use of
EPA open office hours.  This ICR records estimated burden hours for
community members for initial and revised CIP interviews, participation
in focus groups and workshops, TAG application and management, and
completion of satisfaction surveys.  All estimates are provided by a
group of experienced EPA Headquarters and Regional Community Involvement
Staff.

EPA estimates that 40 people will be interviewed for 1 hour each at 12
Federal and State lead Superfund sites each year for initial CIPs.  The
total annual estimated burden for initial CIP interviews at all sites is
480 hours.  It is estimated that 25 people will be interviewed for 1
hour each at 100 active Superfund sites each year for the purpose of
revising the CIPs.  Therefore, the total estimated annual burden is
2,500 hours (Table 2).

EPA estimates that an average of 15 people will participate in a 2 hour
focus group 4 times a year at 5 active Superfund sites.  The total
estimated burden for all sites for each year is 600 hours.  

An average of 50 people are expected to participate in a 3 hour workshop
session once a year at 10 active Superfund sites.  The total estimated
annual burden for all sites is 1,500 hours.

EPA estimates that community groups will apply for available TAGs at 15
Superfund sites.  The application process is estimated to take
approximately 60 hours.  The total estimated annual burden for all sites
is 900 hours.  Management of TAGs takes place each year at an estimated
120 sites.  This requires approximately 200 hours per year.  The total
estimated annual burden for all sites is 24,000 hours.

EPA expects to distribute satisfaction surveys at 5 sites each year.  It
is estimated that 800 people will spend 0.25 hours (15 minutes)
completing each survey.  The total estimated annual burden hours at all
sites is 1,000.

Table 2:  Estimated Burden Hours placed on Communities

	

Activity	 # Federal and State-lead Sites/ yr.	 # of Activities at each
site	 # of People involved	Hrs. per Activity/yr.	Annual Hrs. for
Activity at a Site 	Total Annual Hrs. for all Sites 

Initial CIP Interview	12	1	40	1	40	480

Revised CIP Interviews	100	1	25	1	25	2,500

Focus Group Participation	5	4	15	2	120	600

Workshop Participation	10	1	50	3	150	1,500

TAG application	15	1	N/A	60	60	900

TAG management	120	1	N/A	200	200	24,000

Satisfaction Surveys	5	1	800	0.25	200	1,000













	TOTAL	30,980

								



6(b) Estimating respondent costs

Respondent costs are divided into labor costs and other costs, which
includes all operation and maintenance, non-labor, and capital costs. 
The methodology for calculating these costs for the three year ICR
period is addressed in detail below. 

All costs the State incurs, with the exception of the ARARs analysis, is
ultimately paid for by the Federal government through any one of two
relevant cooperative agreements (CAs) as stipulated in Subpart O of the
NCP.  These cooperative agreements are CORE agreements which provide
fund for infrastructure work and are non-site-specific in nature, and
Remedial CAs that provide site-specific money for remedial process
actions in Superfund.

(i) Estimating labor costs

Labor rates for government employees are estimated using the Office of
Personnel Management’s General Schedule pay tables for 2007.  For the
purposes of this ICR, State government salaries are assumed to be the
same as Federal pay scales.  It is assumed that the average unit of
remedial work is comprised of 10% managerial, 80% technical, and 10%
support staff effort.  Thus, a weighted average is used to represent the
hourly labor rate of government work.  Step 5 of each GS-13, GS-11, and
GS-7 is used to provide a median value for each grade level of employee.
 Total salary for each includes the direct salary plus 60% of direct
salary to account for benefits.  As of February 2007, the hourly labor
salaries are:

		-GS-13, Step 5: $58.18

		-GS-11, Step 5: $40.82

		-GS-7, Step 5:   $27.58

The average governmental hourly labor rate is $41.23, calculated by:
[0.1(58.18)+0.8(40.82)+0.1(27.58)].  This average hourly labor rate
applies to the following activities conducted by State agencies for the
Superfund remedial program: Proposed Plans, RODs, ARARs, Administrative
Records, initial CIPs, revised CIPs, fact sheets, focus groups, and
workshops.  The same hourly labor rate applies to all Federal
activities.

The hourly labor rate for the RI/FS activity is calculated as 20%
government and 80% contractor effort.  These assessments involve a great
deal of field work and typically involve lots of contractor support. 
The labor value is calculated from RI/FS contract records from OSRTI
dating from 1996 through 2006.  Direct labor costs from over 1,000
projects are used to arrive at an average contractor hourly labor rate
of $25.86.  The average government hourly labor rate of $41.23 is used
for the government’s 20%.  Therefore, the average hourly labor rate
for RI/FS work is $28.93, calculated by: [0.2(41.23) + 0.8 (25.86)].

								

The hourly labor rate for community members who participate in Superfund
remedial activities on a voluntary, and non-paid, basis is $16.50.  The
value is based on Bureau of Labor Statistics data, which reports an
average hourly wage of $16.50 for “production, non-supervisory on
private non farm payrolls, seasonally-adjusted” employees.  The recent
trend in this category of BLS data is for the rate to increase
approximately $0.50 per year.  Therefore, $16.50 is the average rate
over the 3 year period of this ICR for all activities in which the
community may participate.  Labor costs for community activities
represent hypothetical costs only.

(ii) Estimating capital, operations and maintenance, and other costs

Capital, operation and maintenance (O&M), and non-labor costs to States
apply for the following Superfund remedial activities: RI/FS, Proposed
Plans, RODs, Administrative Records, and fact sheets.  The Federal
government incurs none of these costs for oversight of State activities.
 The Federal government does incur non-labor costs for the
Administrative Records, fact sheets, and satisfaction surveys. 
Community members have no O&M,  non-labor, or capital costs.  States,
communities, and the Federal government do not incur any capital costs
in these Superfund remedial activities as no new equipment is purchased
for their purposes.

All O&M and non-labor costs for RI/FS conducted at State-lead sites are
calculated from OSRTI contracts records from 1996-2006.  Contractor
non-labor costs for RI/FS includes $80,429 in fees and profits, $115,730
for equipment, and $77,100 for indirect costs such as travel and
reports.  The costs for equipment reflects charges for the use of
equipment, such as computers and sampling instruments, that the
contractor already owns.  The total non-labor costs for each RI/FS in a
single year is, therefore, estimated at $273,259 (Table 3).  

Operation and maintenance is defined as activities that are required to
keep projects supported and moving forward.  For the RI/FS it is
estimated that contractors incur approximately $40,029 in a single year
for each project.  These costs include charges for mail, supplies, and
faxes.  O&M costs incurred by the Agency are discussed in the following
paragraph.

The bulk of O&M costs associated with Proposed Plans, RODs,
Administrative Records, and fact sheets are those costs that are
required for printing, document distribution, newspaper announcements,
and records management.  Costs for mailing and data collection with
contractor support also apply to the satisfaction survey.  Annual
non-labor costs for satisfaction surveys is estimated by EPA staff
conducting the survey to be $6,000.  For all other activities with O&M
costs, the values from the 2004 version of this ICR are used and
adjusted for inflation.  Inflation is calculated by using a percent of
cost change value of 3.14.  This value is estimated for the 3 year
period of the ICR based on calculations from the National Aeronautics
and Space Administration’s “Gross Domestic Product Deflator
Inflation Calculator.”  This number represents an average of the
percent of cost change from three 3-year periods (2002-2005; 2003-2006;
2004-2007).  Using 3.14 as an inflation value, the following O&M annual
costs for each activity are:

		-Proposed Plan: 	$1,687

		-RODs: 		$1,817

		-Administrative Record:$1,366

		-Fact Sheets:		$1,638

(iii) Annualizing capital costs

No significant capital costs are incurred during the activities
described in this ICR.

		

	Table 3:  Estimated Cost to States























	Activity	Total State-lead Activities at Sites per year	Hours per
Activity per year	Hourly Labor Rate	Labor Costs per Activity *	Capital
Costs per Activity per year	Contractor Related Non-labor Costs per
Activity per year *	O&M Costs per Activity per year *	Total Annual Costs
per Activity	Total Annual Labor Costs for all Sites	Total Annual Capital
Costs for all sites	Contractor Related Total Annual Non-labor Costs for
all sites	Total Annual O&M Costs for all Sites	Total Annual Costs for
all Sites

RI/FS	2	5250	$28.93 	151,883	$0 	$273,259 	$40,029 	465,171	303,766	$0 
$546,518 	$80,058 	930,342

Proposed Plans	4	80	$41.23 	3,298	$0 	$0 	1687	4,985	13,192	$0 	$0 
$6,748 	19,940

RODs	4	1300	$41.23 	53,599	$0 	$0 	1817	55,416	214,396	$0 	$0 	$7,268 
221,664

ARARs	45	33	$41.23 	1,361	$0 	$0 	$0 	1,361	61,245	$0 	$0 	$0 	61,245

Admin Record	100	40	$41.23 	1,649	$0 	$0 	1366	3,015	164,900	$0 	$0 
$136,600 	301,500

Initial CIP	2	200	$41.23 	8,246	$0 	$0 	$0 	8,246	16,492	$0 	$0 	$0 
16,492

Revised CIP	20	100	$41.23 	4,123	$0 	$0 	$0 	4,123	82,460	$0 	$0 	$0 
82,460

Fact Sheets	400	40	$41.23 	1,649	$0 	$0 	1638	3,287	659,600	$0 	$0 
$655,200 	1,314,800

Focus Groups	4	30	$41.23 	1,237	$0 	$0 	$0 	1,237	4,948	$0 	$0 	$0 
4,948

Workshops	2	80	$41.23 	3,298	$0 	$0 	$0 	3,298	6,596	$0 	$0 	$0 	6,596



























TOTAL $	885,874	2,959,987











	Federal Funds Used $	885,874	2,898,742











	State Funds Used $	0	61,245

	* Rounded to the nearest whole dollar









	

Table 4:  Estimated Costs to Communities (Voluntary activities, not
actually expended costs)











	Activity	Total Activities at Federal and State-lead Sites/yr	Hours per
Activity per year	Hourly Labor Rate	Annual Labor Costs per Activity *
Capital, O&M, Non-labor Costs per Activity per year	Total Annual Costs
per Activity	Total Annual Labor Costs for all Sites *	Total Annual
Capital, O&M, Non-labor Costs for all Sites	Total Annual Costs for all
Sites

Initial CIP Interview	480	1	$16.50 	$16.50 	$0 	$16.50 	$7,920.00 	$0 
$7,920.00 

Revised CIP Interviews	2500	1	$16.50 	$16.50 	$0 	$16.50 	$41,250.00 	$0
	$41,250.00 

Focus Group Participation	300	2	$16.50 	$33.00 	$0 	$33.00 	$9,900.00 
$0 	$9,900.00 

Workshop Participation	500	3	$16.50 	$49.50 	$0 	$49.50 	$24,750.00 	$0 
$24,750.00 

TAG application	15	60	$16.50 	$990.00 	$0 	$990.00 	$14,850.00 	$0 
$14,850.00 

TAG management	120	200	$16.50 	$3,300.00 	$0 	$3,300.00 	$396,000.00 	$0
	$396,000.00 

Satisfaction Surveys	4000	0.25	$16.50 	$4.13 	$0 	$4.13 	$16,500.00 	$0 
$16,500.00 



















	TOTAL	$511,170.00 

	* Rounded to nearest whole dollar





















6(c) Estimating Agency burden and cost

		

Burden on the Environmental Protection Agency covered in the ICR
includes those hours and costs incurred in overseeing State activities. 
For the RI/FS, Proposed Plans, ARARs, initial and revised CIPs, the
assumption is that Federal oversight hours are 10% of the State’s
burden hours for respective activities. For the Administrative Record,
fact sheets, focus groups, and workshops the assumption is that Federal
oversight hours are 5% of the State’s burden hours.  These assumptions
were provided by a group of Headquarters and Regional Community
Involvement EPA employees with the experience to estimate the average
Federal oversight hours for these activities.  The total estimated
annual burden hours placed on EPA for oversight of State activities is
3,005 (Table 5). 

Table 5:  Estimated Burden Hours for Federal Oversight of State
Activities







	Activity	 # of Sites with State-lead Activities/yr	 # of Activities at
each site	Hrs. per Activity/yr	Annual Hrs. for Activity at a Site 	Total
Annual Hrs. for all Sites 

RI/FS	2	1	525	525	1,050

Proposed Plans	4	1	8	8	32

RODs	4	1	130	130	520

ARARs	45	1	3.3	3.3	149

Administrative Record	100	1	2	2	200

Initial CIP	2	1	20	20	40

Revised CIP	20	1	10	10	200

Fact Sheets	100	4	2	8	800

Focus Groups	1	4	1.5	6	6

Workshops	2	1	4	4	8











	TOTAL	3,005

	

Burden on EPA covered in the ICR also includes those hours and costs
incurred in the implementation of Community Involvement activities. 
These activities include initial and revised CIPs, fact sheets, focus
groups, workshops, satisfaction surveys, and TAGs.  For these activities
that are also conducted by States at State-lead sites, the average hours
required per activity is the same as the burden hours placed on the
States.  Total number of activities and the Federal hours required to
complete them are estimated by a group of Headquarters and Regional
Community Involvement EPA employees.  EPA is also  responsible for
maintaining the Administrative Record at all active Federal-lead sites
at all stages of the cleanup process.  It is estimated that these sites
comprise about 80% of all active sites.  At the time of this writing
there are approximately 550 active NPL sites (EPA database).  Therefore,
EPA is responsible for maintaining the AR at 450 sites.  The total
estimated annual burden hours placed on EPA for Community Involvement
activities is 107,920 (Table 6). 

Table 6:  Estimated Burden Hours for Federal Community Activities 

Activity	 # Federal-lead Sites/ yr.	 # of Activities at each site	Hrs.
per Activity/yr.	Annual Hrs. for Activity at a Site 	Total Annual Hrs.
for all Sites

Administrative Record	400	1	40	40	16,000

Initial CIP	10	1	200	200	2,000

Revised CIP	80	1	100	100	8,000

Fact Sheets	450	4	40	160	72,000

Focus Group	4	4	30	120	480

Workshop	8	1	80	80	640

TAG application	15	1	120	120	1,800

TAG management	120	1	50	50	6,000

Satisfaction Surveys	5	1	200	200	1,000











	TOTAL	107920

 					

Labor costs to EPA were calculated using a weighted average hourly rate
for government employees.  The assumption is made that the typical
division of labor for these activities is 10% managerial, 80% technical,
and 10% support.  These values are used to calculate a weighted hourly
labor rate based on the current GS Schedule using values for GS-13,
GS-11, GS-7, all Step 5, plus 60% of each salary to account for
benefits.  The average hourly rate is $41.23.  The annual labor cost for
each activity that involves use of Federal hours is calculated using
this labor rate.  Labor costs to EPA are the only Federal costs
accounted for oversight of State activities.  The total estimated annual
costs incurred by EPA for oversight of State activities is $123,640
(Table 7).  The total estimated annual costs EPA incurs for Community
Involvement activities is $7,964,366 (Table 8).

 

Table 7:  Estimated Costs for Federal Oversight of State Activities













	Activity	Total State-lead Activities at Sites per year	Hours per
Activity per year	Hourly Labor Rate	Annual Labor Costs per Activity *
Annual Capital, O&M, Non-labor Costs per Activity	Total Annual Costs per
Activity	Total Annual Labor Costs for all Sites *	Total Annual Capital,
O&M, Non-labor Costs for all Sites	Total Annual Costs for all Sites

RI/FS	2	525	$41.23 	21646	$0 	21646	43292	$0 	43292

Proposed Plans	4	8	$41.23 	330	$0 	330	1320	$0 	1320

RODs	4	130	$41.23 	5360	$0 	5360	21440	$0 	21440

ARARs	45	3.3	$41.23 	136	$0 	136	6120	$0 	6120

Administrative Record	100	2	$41.23 	82	$0 	82	8200	$0 	8200

Initial CIP	2	20	$41.23 	825	$0 	825	1650	$0 	1650

Revised CIP	20	10	$41.23 	412	$0 	412	8240	$0 	8240

Fact Sheets	400	2	$41.23 	82	$0 	82	32800	$0 	32800

Focus Groups	4	1.5	$41.23 	62	$0 	62	248	$0 	248

Workshop	2	4	$41.23 	165	$0 	165	330	$0 	330

 

















	SUBTOTAL	123,640





Cooperative Agreement Federal $ to States (Table 3)	2,898,742

* Rounded to the nearest whole dollar



	TOTAL $	3,022,382





Table 8:  Estimated Costs to the Federal Government for Community
Activities























Activity	Total Activities at Federal lead Sites/yr	Hours per Activity
per year	Hourly Labor Rate	Annual Labor Costs per Activity *	Annual
Capital Costs per Activity	Annual Non-labor Cost per Activity	Annual O&M
Costs per Activity	Total Annual Costs per Activity	Total Annual Labor
Costs for all Sites *	Total Annual Capital Costs for all sites	Total
Annual Non-labor Costs for all sites	Total Annual O&M Costs for all
Sites	Total Annual Costs for all Sites

Admin. Record	440	40	$41.23 	1,649	$0 	$0 	1366	3,015	725,560	$0 	$0 
601040	1,326,600

Initial CIP	10	200	$41.23 	8,246	$0 	$0 	$0 	8,246	82,460	$0 	$0 	0
82,460

Revised CIP	80	100	$41.23 	4,123	$0 	$0 	$0 	4,123	329,840	$0 	$0 	0
329,840

Fact Sheets	1760	40	$41.23 	1,649	$0 	$0 	$1,638 	3,287	2,902,240	$0 	$0
	2882880	5,785,120

Focus Group	16	30	$41.23 	1,237	$0 	$0 	$0 	1,237	19,792	$0 	$0 	0
19,792

Workshop	8	80	$41.23 	3,298	$0 	$0 	$0 	3,298	26,384	$0 	$0 	0	26,384

TAG application	15	120	$41.23 	4,948	$0 	$0 	$0 	4,948	74,220	$0 	$0 	0
74,220

TAG management	120	50	$41.23 	2,062	$0 	$0 	$0 	2,062	247,440	$0 	$0 	0
247,440

Satisfaction Surveys	5	200	$41.23 	8,246	$0 	$0 	$6,256 	14,502	41,230
$0 	$0 	31280	72,510



























	TOTAL	7,964,366





* Rounded to the nearest whole dollar







	

		

		

   

(d) Estimating the respondent universe and total burden and cost

		

The respondent universe is based on the number of State-lead and active
Superfund sites predicted for the three year period of the ICR.  These
numbers come from Superfund data about past activities and scheduled
plans for future activities.  The number of community members involved
at each site clearly varies and this respondent universe is based on
past program averages.  The total burden and cost to each respondent is
a summation of all activities described in detail in previous sections
of this document.	

	

6(e) Bottom-line burden hours and cost tables

(i) Respondent tally

The total burden hours and costs displayed in the table below reflects
the combined burden and costs on both categories of respondents: States
at State-lead sites and individual community members participating
voluntarily at Superfund sites.  Community costs of $511,170 (Table 4)
are all hypothetical and do not represent the actual expenditure of
dollars because all participation is voluntary. The majority of State
costs may be paid through various grants from the Federal government. 
The actual costs to States is $61,245 (Table 3) for the ARAR analysis.

	

     Table 9:  Total Respondent Burden Hours and Costs

Respondent	Annual Burden	Annual Cost	Total 3 yr. Burden	Total 3 yr. Cost

States	40,185	$61,245	120,555	$183,735

Communities	30,980	$511,170	92,940	$1,533,510

Total	71,165	$572,415	213,495	$1,717,245

	



(ii) Agency tally

The total burden and costs represented in the following table is the
amount EPA expects to spend directly in oversight of State activities
and the information gathering activities EPA conducts with communities
at Superfund sites.

	

     Table 10:  Total Federal Agency Burden Hours and Costs

Agency	Annual Burden	Annual Cost	Total 3 yr. Burden	Total 3 yr. Cost

Federal Oversight-States	3,005	$3,022,382	9,015	$9,067,146

Federal-Community Activities	107,920	$7,964,366	323,760	$23,893,098

Federal Total 	110,925	$10,986,748	332,775	$32,960,244



(iii) Variations in the annual bottom line

Variations to the annual bottom line numbers may occur as sites enter
different phases of the remedial process in different years. 
Additional, activities that depend almost exclusively on the need at the
site, such as fact sheet, are likely to vary year to year.  However, EPA
expects the relative number of annual activities to be similar in each
year of the ICR period.

6(f) Reasons for change in burden

		

There is no change in the burden for this ICR. Cost models were updated
to reflect wage inflation. While currently approved O&M costs are listed
as $850,000, and are updated in the current ICR, they have been removed
from the cost estimate listed above because they are reimbursed in full
by the Federal government, and thus effectively impose no burden on
state governments.

The total estimated annual burden hours for respondents are the same as
the previous ICR (71,165 hours).  The total estimated annual costs to
respondents increased by $19,206.  State burden hours for identification
of ARARs is estimated to be the same (33 hours) and costs increased by
$3,716.  This increase is due to adjustment for hourly labor rate from
$38.74 to $41.23.  The estimated amount that will actually be funded
with State monies is $61,245.  Community member burden hours is
estimated to be the same (30,980 hours) and costs increased by $15,490
due to adjustment for hourly labor rate from $16 to $16.50.

6(g) Burden statement

		

The total estimated annual burden hours placed on State governments for
all remedial activities is 40,185.  The total estimated annual burden
hours placed on communities is 30,980.  Total burden hours placed on
7,970 respondents through 8,498 responses is 71,165 hours.  The annual
public reporting and recordkeeping burden for this collection of
information is estimated to average 8.4 hours per response.  

The ICR covers an array of activities that may occur at various discrete
points in time or periodically throughout the entire Superfund remedial
process.  Therefore, the number of likely respondents per Superfund site
in both the State and community categories will vary by site depending
on its position in the remedial process, the lead agency, and the level
of community involvement warranted.  Additionally, the frequency of
response to all activities covered by the ICR can only be described as
occurring when required to meet CERCLA requirements and the needs of the
Superfund site and the community. 

		

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.
EPA-HQ-SFUND-2007-0707.  This docket is available for public viewing at
the Superfund Docket in the EPA Docket Center (EPA/DC),  EPA West, Room
3334, 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 Superfund
Docket is (202) 566-0276.  An electronic version of the public docket is
available at http://www.regulations.gov.  Use www.regulations.gov to
submit or view public comments, access the index listing of the contents
of the public docket, and 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.  Comments can also be sent 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. 
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