INFORMATION COLLECTION REQUEST

SUPERFUND SITE EVALUATION AND HAZARD RANKING SYSTEM (RENEWAL)

U.S. Environmental Protection Agency

Office of Solid Waste and Emergency Response

Office of Superfund Remediation and Technology Innovation

State, Tribe, and Site Identification Branch

1200 Pennsylvania Avenue, N.W.

Washington, DC 20460

TABLE OF CONTENTS

 TOC \f 

1.	IDENTIFICATION OF THE INFORMATION COLLECTION	1

1(a)	Title of the Information Collection	1

1(b)	Short Characterization/Abstract	1

2.	NEED FOR AND USE OF THE COLLECTION	2

2(a)	Need/Authority for the Collection	2

2(b)	Practical Utility/Users Of The Data	4

3.	NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA	5

3(a)	Non-duplication	5

3(b)	Public Notice Required Prior to ICR Submission to OMB	5

3(c)	Consultations	6

3(d)	Effects of Less Frequent Collection	6

3(e)	General Guidelines	6

3(f)	Confidentiality	6

3(g)	Sensitive Questions	7

4.	THE RESPONDENTS AND THE INFORMATION REQUESTED	7

4(a)	Respondents Standard Industrial Classification (SIC) Codes	7

4(b)	Information Requested	7

5.	THE INFORMATION COLLECTED - AGENCY ACTIVITIES, COLLECTION
METHODOLOGY, AND INFORMATION MANAGEMENT	11

5(a)	Agency Activities	11

5(b)	Collection Methodology and Management	11

5(c)	Small Entity Flexibility	13

5(d)	Collection Schedule	13

6.	ESTIMATING THE BURDEN AND COST OF THE COLLECTION	14

6(a)	Estimating Respondent Burden	14

6(b)	Estimating Respondent Costs	15

6(c)	Estimating Agency Burden and Costs	16

6(d)	Estimating Respondent Universe and Total Burden and Costs	17

6(e)	Bottom Line Burden Hours and Costs	17

6(f)	Reasons for Change in Burden	17

6(g)	Burden Statement	17

7.	REFERENCES	19

 

LIST OF EXHIBITS

Exhibit 1. Major Components of EPA’s Superfund Site Assessment Process
1

Exhibit 2. Use and Users of the Site Assessment Data	5

Exhibit 3. Detailed Site Assessment Activities and Data Collected	8

Exhibit 4. EPA’s Integrated Assessment Process	13

Exhibit 5. Annual Respondent Burden	14

Exhibit 6. Site Assessment Screening Process	15

Exhibit 7. Annual Respondent Burden and Costs	16

Exhibit 8. Annual Agency Burden and Cost	16

Exhibit 9. Total Estimated Respondent Burden and Cost Summary	17

IDENTIFICATION OF THE INFORMATION COLLECTION tc \l1 "IDENTIFICATION OF
THE INFORMATION COLLECTION 

1(a)	Title of the Information Collection tc \l2 "1(a)	Title of the
Information Collection 

This Information Collection Request (ICR) is number 1488.07 (OMB control
number 2050-0095) and is titled, “Superfund Site Evaluation and Hazard
Ranking System (Renewal).”  It is a revised version of the current ICR
for the Superfund site assessment process.

1(b)	Short Characterization/Abstract tc \l2 "1(b)	Short
Characterization/Abstract 

In 1980, Congress enacted the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) to address threats posed to
human health and the environment by uncontrolled releases of hazardous
substances into the environment.  Section 105 of CERCLA required EPA to
establish criteria for determining priorities among releases or
threatened releases of hazardous substances for the purpose of taking
remedial action.  In response, EPA developed a model to systematically
rank hazardous waste sites with regard to their relative threat to human
health and the environment.  This model, the Hazard Ranking System
(HRS), was adopted by EPA in 1982 and later revised in December 1990. 
The HRS criteria take into account the population at risk, the hazard
potential of the substances, as well as the potential for contamination
of drinking water supplies, direct human contact, destruction of
sensitive ecosystems, damage to natural resources affecting the human
food chain, contamination of surface water used for recreation or
potable water consumption, and contamination of ambient air. 

The Superfund site evaluation process uses a series of progressively
more complex site assessment phases to determine and implement the
appropriate responses to releases of hazardous substances to the
environment.  Exhibit 1 outlines the major components of the site
assessment process.

At the conclusion of each phase of the site assessment process, the HRS
model is applied to derive a preliminary site HRS score.  The HRS score
is crucial since it is the primary mechanism used to determine whether a
site is eligible to be included on the National Priorities List (NPL). 
The NPL is a list of those sites that are priorities for long-term
evaluation and remedial response.  Sites with HRS scores of 28.50 or
greater are eligible for placement on the NPL. Only sites on the NPL are
eligible for Superfund-financed remedial actions.  Sites with HRS scores
below 28.5 generally require no further Superfund site evaluation. 
Uniform application of the HRS by the EPA, States and Tribes enables EPA
to identify and prioritize hazardous waste sites that warrant further
investigation.

Under this ICR, the States (including U.S. Territories) and Tribes will
apply the HRS by collecting and documenting HRS data needs required for
each site assessment phase conducted.  EPA Regions work with States and
Tribes to determine which sites will receive each type of assessment. 
The HRS data collected by States and Tribes during site assessment
activities are derived from the sources described in this information
collection, including conducting field reconnaissance, taking samples at
the site, and reviewing available reports and documents.  States and
Tribes conclude each site assessment phase by completing and submitting
the appropriate site assessment report to EPA.  The number and type of
assessment reports to be conducted by States and Tribes is a function of
available funding, site assessment backlogs, Superfund site assessment
goals, and site assessment priorities; therefore, the type of
information collected under this ICR is considered to be a periodic
report.  The States and Tribes are reimbursed 100 percent of their costs
to develop these reports, except for record maintenance. 

EPA Regions review each site assessment report submitted by States and
Tribes for accuracy and completeness, and to ensure conformance with
Superfund site assessment guidance.  EPA Regions then use this
information to make a decision regarding next Superfund steps for a
site.  EPA Regions also enter summary information about each report and
the associated decision on next steps into the Comprehensive
Environmental Response, Compensation and Liability Information System
(CERCLIS).  EPA maintains reports submitted by States and Tribes in site
files. 

The annual burden incurred by States and Tribes for collecting
information necessary to move a site through the site assessment process
is a function of the average estimated hours and dollars per site
assessment activity, the estimated number of assessment activities
completed per year, and State/Tribal infrastructure costs supporting
these assessment activities.  In order to calculate the burden for this
ICR, EPA Regions provided annual average estimates of site assessment
activities to be completed by States and Tribes from FY08 through FY10. 
EPA Regions also provided estimated average hours and dollars incurred
by States and Tribes to complete each type of site assessment activity,
along with estimated infrastructure costs used by States and Tribes to
perform Superfund work.  

Projected FY08-FY10 data provided by EPA regions show that the estimated
annual hour and cost burden to State and Tribal respondents for
performing site assessment activities is approximately 148,873 hours and
$11,740,260, respectively.  However, one hundred percent of the
respondent cost ($11,740,260) is reimbursed by the EPA through
cooperative agreements (CAs) as set forth by Section 104(d) of CERCLA,
thus state and tribal respondents do not effectively bear any cost
burden.  Section 6.0 of this document, Estimating the Burden and Cost of
Collection, provides a more detailed discussion of the burden to
respondents.

This ICR is prepared using the guidance contained in EPA’s ICR
Handbook revised November, 2005.  This document is the most recent
document for preparing an ICR and follows the provisions of the
Paperwork Reduction Act (44 U.S.C. §1320) and the Office of Management
and Budget (OMB) guidelines.  It can be found on the EPA website at
www.epa.gov/icr.

NEED FOR AND USE OF THE COLLECTION tc \l1 "NEED FOR AND USE OF THE
COLLECTION 

2(a)	Need/Authority for the Collection tc \l2 "2(a)	Need/Authority for
the Collection 

CERCLA’s passage in 1980 launched the Superfund program that provided
EPA the authority needed to respond to threats posed by the uncontrolled
releases of hazardous substances into the environment.  The fundamental
purpose of the Superfund program is to address threats and protect human
health and the environment from releases or potential releases of
hazardous substances from abandoned or uncontrolled hazardous waste
sites.  The HRS is a crucial part of EPA’s Superfund program because
its application enables EPA to evaluate the relative threats of
hazardous waste sites.  Collecting uniform information during the site
assessment process enables EPA to consistently apply the HRS model. 
Consistent application of HRS by respondents enables EPA to identify and
classify those releases or threatened releases of hazardous substances
that warrant further investigation in anticipation of corrective
actions.

EPA submitted the Agency's 2006 - 2011 Strategic Plan  to Congress on
September 29, 2006, as required under the Government Performance and
Results Act (GPRA) of 1993.  EPA’s strategic plan includes a target
for making a cumulative total of 40,491 final Superfund site assessment
decisions by the end of FY 2011.  The site assessment reports submitted
by States and Tribes as described under this ICR are used to assist EPA
in determining whether a final Superfund site assessment decision has
been made. 

CERCLA establishes the legal authority to perform site assessment and
NPL listing activities.  Specifically:

Section 105 of CERCLA required that the National Oil and Hazardous
Substance Pollution Contingency Plan (NCP) be amended to include the
following:

“[C]riteria for determining priorities among releases throughout the
United States for the purpose of taking remedial action... Criteria and
priorities... shall be based upon relative risk or danger to public
health, welfare, or the environment... taking into account... the
population at risk, the hazard potential of the hazardous substances...
the potential for contamination of drinking water supplies, the
potential for direct human contact, the potential for destruction of
sensitive ecosystems... and other appropriate factors.”

To meet these requirements, the HRS was adopted and enacted as part of
the revised NCP in July 1982.  Section 105(8)(B) of CERCLA requires the
NCP to include a “list.... of national priorities among the known
releases or threatened releases throughout the United States...”
Application of the HRS determines whether an uncontrolled hazardous
waste site may be eligible for inclusion on the NPL.  Each State is also
required to “establish and submit for consideration by the President
priorities for remedial action among known releases and potential
releases in that State based upon the criteria” in Section 105(8)(A).

In 1986, CERCLA was amended by the Superfund Amendments and
Reauthorization Act (SARA).  EPA modified the HRS in 1990 so that, “to
the maximum extent feasible, [it] accurately assesses the relative
degree of risk to human health and the environment posed by sites and
facilities subject to review.”  Section 105 of SARA mandates that the
HRS take into account, to the extent possible, the following:

(	Human health risks associated with the contamination or potential
contamination of surface water that is or can be used for recreation or
potable water consumption;

(	Damage to natural resources that may affect the food chain; and

(	Contamination or potential contamination of the ambient air, which is
associated with the release or threatened release.

Section 118 of CERCLA requires that a high priority be given to
facilities where the release of hazardous substances or pollutants has
resulted in the closing of drinking water wells or a principal drinking
water supply.

Section 125 of CERCLA requires the HRS to assess sites containing a
substantial volume of waste as described in Section 3001(b)(3)(A)(I) of
the Solid Waste Disposal Act.  These wastes include fly ash wastes,
bottom ash wastes, slag wastes, and flue gas emission control wastes
generated primarily from the combustion of coal or other fossil fuels. 
Section 125 of CERCLA requires EPA to consider each of the following
site-specific characteristics:

Degree of risk to human health and the environment;

(	Quantity, toxicity, and concentrations of hazardous constituents; and

(	Extent of and the potential for the release of hazardous constituents
into the environment.

The specific sections of CERCLA cited above can be found at   HYPERLINK
"http://www.access.gpo.gov/uscode/title42/chapter103_subchapteri_.html" 
http://www.access.gpo.gov/uscode/title42/chapter103_subchapteri_.html . 


2(b)	Practical Utility/Users of the Data tc \l2 "2(b)	Practical
Utility/Users Of The Data 

The data collected through the site assessment process described in this
ICR are used to support a site decision regarding the need for further
Superfund action.  The various data elements gathered, which relate to
the HRS criteria, are used to complete the HRS score.  All of this
information is used within the Superfund program to:

(	Identify sites that pose a potential threat to human health and the
environment;

(	Determine if sites pose a potential hazard and whether further action
is necessary;

(	Refer sites to EPA’s removal program if removal actions may be
needed;

(	Develop preliminary and final HRS scores;

(	Set priorities for further assessment work;

(	Allocate resources (e.g., money, staff); and

(	Evaluate Superfund program performance.

In addition, EPA Headquarters’ staff use the information collected to
aid in the general management and oversight of the Superfund program. 
Currently, EPA uses the information to assess resource needs; allocate
funds; prepare site assessment guidance materials; list NPL sites;
conduct quality assurance (QA) reviews of HRS packages; and track
Regional and State Superfund performance.  Headquarters also uses the
information to respond to information requests, and perform analyses for
EPA management, OMB, Congress, and the general public.

Staff at the ten EPA Regions use Superfund site assessment data for
purposes similar to Headquarters, including: developing operating
budgets and program plans; allocating resources; tracking State-by-State
performance; responding to information inquiries under the Freedom of
Information Act (FOIA); and supplying input to CERCLIS.  Regions must
also respond to inquiries from EPA Headquarters.  As a function of their
program authority, EPA Regions also have the responsibility for
overseeing site assessments and generating HRS scores.

State and Tribal use of site assessment data is more site-specific. 
These authorities use the data to perform site assessments; generate HRS
scores; maintain site files; track site status; and respond to
information inquiries under FOIA.  They also use the information
gathered to maintain their own site files.  Exhibit 2 summarizes the use
and users of site assessment and HRS information.

Exhibit 2: Use and Users of the Site Assessment Data



EPA HEADQUARTERS



List NPL sites

QA HRS packages

Prepare site assessment guidance manuals

Establish national Superfund budget

Track Regional and State Superfund performance

Respond to Congress

Respond to information inquiries (FOIA)



EPA REGIONS



Oversee site assessment

Review HRS scores

Supply input to Congress

Track site status

Coordinate with other programs

Maintain site files

Respond to information inquiries (FOIA)



STATES/TRIBES



Perform site assessment

Generate HRS scores

Track site status

Coordinate with other environmental programs

Maintain site files

Respond to information inquiries (FOIA)



3.	NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA tc \l1
"3.	NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 		CRITERIA 

3(a)	Non-duplication tc \l2 "3(a)	Non-duplication 

The primary sources of data required to complete site assessments and
prepare HRS packages are Federal, State, and local government agencies
and private parties.  Data are gathered through the performance of
actual on-site investigations (e.g., samples, on-site measurements). 
Much of the information (i.e., site history, population surrounding the
site, location of drinking water supplies) is collected from readily
available public information sources, thereby minimizing the amount of
collection of this primary information.  The field data gathered during
the site assessment activities covered under this ICR are not generally
collected by any other Federal agency.

Through pre-CERCLIS screening, EPA screens out sites being addressed by
other parties to prevent duplication of assessment activities. 
Generally, the SI is the first investigation to collect and analyze
waste and environmental samples.  In instances where prior sampling has
been completed and analytical data has been collected, performance of
additional sampling may not be necessary.

3(b)	Public Notice Required Prior to Submission to OMB tc \l2 "3(b)
Public Notice 

A notice stating this ICR was up for renewal was published in the
Federal Register on September 4, 2007 (72 FR 50679).  This initiated a
60-day comment period which closed on November 5, 2007.  No comments
were received during the comment period.

3(c)	Consultations tc \l2 "3(c)	Consultations 

In order to calculate the burden of site assessment activities on the
States and Tribes and present the results in this report, State and
Tribal burden information was based on average annual site assessment
activity projections for FY 2008 through FY 2010.  As part of obtaining
the State and Tribal burden information, EPA Regions were contacted to
determine the nature of site assessment activities performed by States
and Tribes in each respective Region and the costs (dollars and hours)
associated with these activities.  EPA Regions reviewed cooperative
agreement progress reports submitted by States and Tribes as necessary
to gather the State and Tribal data for this ICR. 

3(d)	Effects of Less Frequent Collection tc \l2 "3(d)	Effects of Less
Frequent Collection 

Site assessment information collection does not occur on a regularly
scheduled basis.  Yearly collection activities associated with the site
assessment process are based on the number of sites discovered, the
number of sites in the CERCLIS inventory needing assessment work, the
amount of available Superfund funding, and Superfund site assessment
goals and priorities.  The frequency of collection is driven by the
schedule established in Section 116(b) of CERCLA.  Section 116(b)
requires an HRS evaluation (if warranted) within four years of the
site's entry into CERCLIS.  For sites brought to EPA’s attention via a
citizen’s petition, Section 105(d) of CERCLA requires completion of a
Preliminary Assessment (PA), or an explanation of why a PA is not
appropriate, within one year after receiving the petition.  Less
frequent collection of site assessment reports may compromise EPA’s
ability to comply with statutory schedules and could negatively impact
EPA’s progress towards achieving the strategic target for making final
site assessment decisions.  

3(e)	General Guidelines tc \l2 "3(e)	General Guidelines 

The reporting frequency guideline set forth in 5 CFR 1320.6 of the
Paperwork Reduction Act Guidelines may not be met depending on the
nature of new sites discovered and urgency of assessment work needed. 
Collection of information occurs continually as new sites are
identified.  EPA is currently operating NPL development activities so
that as sites with higher priorities are identified, the information is
forwarded to the appropriate office for review and validation.

States and Tribes 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
National Contingency Plan.  The site records are to be maintained for
the duration of the assessment and any subsequent remediation at sites
and for as long as necessary for litigation purposes.  Responsibility
for these files will continue beyond the three year ICR period, as
assessment and, if necessary, remediation may take more than three
years.

3(f)	Confidentiality tc \l2 "3(f)	Confidentiality 

Application of the HRS does not typically require collection of
information that is considered confidential.  EPA handles instances
where confidentiality claims are asserted by private parties on a
case-by-case basis.  States and Tribes (the respondents) have been
informed that any confidential information submitted to document an HRS
score must be marked clearly as such and sent under separate cover so
that it is properly handled.

3(g)	Sensitive Questions tc \l2 "3(g)	Sensitive Questions 

Sensitive questions are not associated with the information collection
activities performed during site assessment and HRS score preparation.

4.	THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a)	Respondents Standard Industrial Classification (SIC) Codes tc \l2
"4(a)	Respondents Standard Industrial Classification (SIC) Codes 

Activities conducted as part of the Superfund site assessment process
require that information be gathered from Federal, State, and local
government agencies.  While the performance of the various phases of
site assessment will require the involvement of State and local
agencies, identification of the particular State or local agency
involved is not possible until a site has been identified.  SIC codes
associated with environmental protection agencies (governmental) are
classified in Division J, Public Administration; Major Group 95,
Administration of Environmental Quality and Housing Programs; Industry
Group 951, Administration of Environmental Quality; and 9511 Air and
Water Resource and Solid Waste Management.  The corresponding North
American Industry Classification System (NAICS) code is 924110:
Administration of Air and Water Resource and Solid Waste Management
Programs.

4(b)	Information Requested tc \l2 "4(b)	Information Requested 

The data collection requirements associated with the various phases of
the site assessment process are designed to enable the consistent
application of the HRS.  Information gathering activities are intended
to help EPA determine whether hazardous substances are present at the
site, and whether they are migrating to the surrounding environment. 
Data required for the site assessment process and HRS score preparation
are often collected from readily available public information sources
such as State and local government offices, Regional EPA offices, and
potentially responsible parties (PRPs).  The amount of data collected
during the site assessment process and the activities associated with
collection vary from site to site depending on the level of proposed
threat.  Data collection activities also vary from phase to phase of the
site assessment process based on the type of information needed to
satisfy the HRS requirements such as waste characterization and target
assessments.  Although reporting activities (e.g., data collection,
report preparation) comprise the majority of the site assessment effort,
approximately 13 percent of the total effort can be attributed to
recordkeeping activities (e.g., developing and maintaining databases,
entering data, and filing).

This section provides a detailed description of the type of data that
needs to be collected to complete a site assessment and the activities
associated with this collection process.    It also provides estimates
of the average annual projections of number of respondent activities
from FY 2008 through FY 2010.  State and Tribal respondents submit a
site assessment report to EPA for each activity conducted.   EPA enters
key information contained in these reports into CERCLIS.  

Collection activities are discussed for the major phases of site
assessment including: Pre-CERCLIS Screening, Preliminary Assessment,
Site Inspection, and HRS Package Preparation.  Other assessment
activities are also described, including: Integrated Removal/Remedial
Evaluation (Integrated Assessment), Expanded Site Inspection and Site
Reassessment.

Exhibit 3 provides an overview of the activities performed and data
items collected for the various phases of site assessment.  It also
illustrates where the sub-phases may be utilized and the various
outcomes that can occur.  Section 6.0, Estimating the Burden and Cost of
Collection, provides the estimated average hours associated with each of
the phases of the site assessment process.

Pre-CERCLIS Screening

Pre-CERCLIS screening is the process of reviewing data on a potential
hazardous waste site brought to EPA’s attention to determine whether
it should be entered into CERCLIS for further evaluation or response
action.   Pre-CERCLIS screening is intended to be a low-cost effort to
ensure uncontaminated or lightly contaminated sites are not arbitrarily
entered into CERCLIS for Superfund-financed evaluation, cleanup, or
oversight activities.  The process can be initiated through the use of
several mechanisms, such as a phone call or referral by a State or other
Federal agency.  Following notification of a potential site to EPA,
Regions generally contact State, Tribal, or other appropriate Federal
staff to determine whether the site is already being addressed by
another party and to define EPA’s role at the site.  From FY 2008
through FY 2010, EPA projects an annual average of 342 Pre-CERCLIS
screenings will be performed by States or Tribes.

Preliminary Assessment

The preliminary assessment (PA) is a relatively rapid, low-cost
compilation of readily available information pertaining to the site and
its surroundings.  From FY 2008 through FY 2010, EPA projects an annual
average of 111 PAs will be performed by States or Tribes to identify
target populations and other targets that may be affected by
contamination at sites.  The scope of the PA must be sufficient to
complete several activities, including:

Reviewing existing information about the site;

Conducting a site and environmental reconnaissance;

(	Collecting information about the site, with the emphasis on target
information;

(	Evaluating all information and developing a preliminary HRS score; and

(	Preparing a brief site summary report and site characteristics form.

Data collected during PA activities include: site-specific data,
historical site information, potential contamination sources, types of
hazardous waste, target information, and location of drinking water
supplies.  Sampling activities are not performed during this phase of
site assessment.

In certain situations, an Abbreviated PA (APA) may be conducted in lieu
of a full PA.   APAs are appropriate when the following conditions
exist:

A site has been inappropriately listed in CERCLIS because it is either
not eligible or it could be deferred to another response program; 

A site can be addressed as part of another site already in CERCLIS;

Available information allows EPA to make an early decision to undertake
a Site Inspection (SI); or 

A NFRAP designation can be made without completing a full PA.

For such sites, the typical PA reporting requirements are abbreviated.

Site Inspection

SIs build upon and supplement the information collected during the PA.
The primary purpose of the SI is to gather enough information to
determine whether further Superfund action is warranted as a result of a
significant threat to human health and the environment.  From FY 2008
through FY 2010, EPA projects an annual average of 75 SIs will be
performed by States or Tribes.  During the SI, the respondent will
collect data to determine whether the site is an NPL candidate or if it
should receive a NFRAP or other decision (i.e., deferral to RCRA,
further assessment needed).  The SI consists of five major activities:

(	Reviewing available information including analytical data;

(	Organizing the project team and developing an SI work plan, sample
plan, health and safety plan, and investigation-derived wastes (IDW)
plan;

(	Performing field work to visually inspect the site and collect
samples;

(	Evaluating all information and developing a site score based on the
HRS; and

(	Preparing a site summary report.

Data collected during the SI could include additional non-sampling data
(e.g., field observations, site-specific information) and sampling data
collected during the on-site reconnaissance.

Integrated Removal/Remedial Evaluations (Integrated Assessments)

Site assessment and removal assessment activities may be combined into a
single Integrated Assessment activity if the appropriate site conditions
exist.  Integrated Assessments further reduce repetitive tasks and costs
on site characterization.  The two most common types of Integrated
Assessments include: Integrated Removal Assessment & PA; and Integrated
Removal Assessment & SI.  From FY 2008 through FY 2010, EPA projects an
annual average of 7 Integrated Assessments will be performed by States
or Tribes.  The stand-alone requirements from the site assessment and
removal assessment activities must be met even though the data will be
integrated.

Expanded Site Inspection

The ESI further investigates critical hypotheses proposed in the SI
regarding the nature and extent of contamination at a site.  ESIs
typically include additional site sampling, which in some cases, may
require specialized techniques or equipment (e.g., installation of
monitoring wells, geophysical surveys).  Data generated are used to
modify the preliminary HRS score developed during the SI.  An ESI report
is the final product of this phase.  ESI activities should include:

(	Organizing the project team and developing ESI work plan, sample plan,
health and safety plan, and IDW plan;

(	Investigating and documenting critical new hypotheses or assumptions;

(	Collecting samples to attribute hazardous substances to site
operations;

(	Collecting samples to establish representative background levels;

(	Collecting other missing non-sampling data for pathways of concern;
and

(	Preparing a site summary report.

The data collected during the ESI may be used to support previous
documentation or references, and fulfill remaining HRS data requirements
for pathways of concern.  From FY 2008 through FY 2010, EPA projects an
annual average of 30 ESIs will be performed by States or Tribes.

Site Reassessment

The Site Reassessment represents the gathering and evaluation of new
information on a site previously assessed under the Federal Superfund
program to determine whether further Superfund attention is needed.  The
scope of work for a Site Reassessment activity is flexible, but will
usually represent a component of PA or SI activities.  As such, it
serves as a supplement to previous assessment work, and not as a
substitute for an initial PA or SI.  From FY 2008 through FY 2010, EPA
projects an annual average of 84 site reassessments will be performed by
States or Tribes.

HRS Package Preparation

The final phase in the site assessment process is HRS package
preparation.  The primary activities associated with this phase of site
assessment are:

(	File review;

(	Determining site score;

(	Revising site score; and

(	Preparing the documentation record and supporting information.

After completion of the site evaluation, compiled data are used to score
a site using scoresheets based on the HRS model.  Under the HRS,
numerical values are assigned to a site based on various aspects of the
site and its immediate surroundings through the evaluation of four
pathways: (1) ground water migration; (2) surface water migration; (3)
soil exposure; and (4) air migration.  The scoring system for each
pathway is based on a number of individual factors grouped into three
factor categories:  (1) likelihood of release or, for the soil exposure
pathway, likelihood of exposure; (2) waste characteristics; and (3)
targets (i.e., potentially affected populations, etc.).  Individual
factors are evaluated and the factor values are calculated to produce
four category values.  An example of the scoresheets used during HRS
package preparation can be found at   HYPERLINK
"http://www.epa.gov/superfund/training/hrstrain/htmain/3path.htm" 
http://www.epa.gov/superfund/training/hrstrain/htmain/3path.htm .  

From FY 2008 through FY 2010, EPA projects an annual average of 7 HRS
packages will be performed by States or Tribes.

THE INFORMATION COLLECTED - AGENCY ACTIVITIES, COLLECTION METHODOLOGY,
AND INFORMATION MANAGEMENT tc \l1 "THE INFORMATION COLLECTED - AGENCY
ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT 

5(a)	EPA Activities tc \l2 "5(a)	EPA Activities 

EPA region offices review and manage sites assessed under Superfund by
States and Tribes, and provide oversight for State and Tribal site
assessment cooperative agreements.  EPA generally performs the following
duties for each of the site assessment activities covered under this
ICR:

Coordinate site specific work and review draft documents and reports;

Prepare summary reports and decision documents;

Identify stakeholders and communicate site assessment plans and
progress;

Respond to information requests; and

Perform data management activities to record and track assessments.

5(b)	Collection Methodology and Management tc \l2 "5(b)	Collection
Methodology and Management 

Data gathered during the site assessment process fall into three main
categories:  historical; field related; and HRS related.  At each phase
of assessment, data from these broad categories are collected and
analyzed in order to screen out sites that do not need to be addressed
by the Superfund program.  As a site moves from one phase to another in
the site assessment process, it must satisfy an increasing number of
data requirements for the HRS model.  Sites may be screened out of the
site assessment process based on a Pre-CERCLIS screening to determine
whether a potential hazardous waste site should be added into CERCLIS
for further evaluation or response.  In addition, sites may also be
screened out based on the HRS score generated; a referral to other
Federal and State programs; or a referral to the removal program.

Following entry of a site discovery into CERCLIS, the PA process is
initiated.  During the PA, professional judgment is used to make
assumptions for unavailable data.  Information collection at this phase
is accomplished mostly from the desktop by reviewing historical
documents and conducting telephone interviews.  The majority of the data
collected is historical information and target information for the HRS
model.  A site drive-by may also be conducted to verify the site
location and status.  During the PA, the HRS is applied through
development of a preliminary HRS score.  A PA report is the final
product of this phase.  Information collected during the PA is
incorporated into subsequent work.

A site that is recommended for continued Superfund evaluation after PA
completion proceeds to the SI phase.  Data collection goals for this
phase are similar in scope to the PA with the addition of detailed field
data (e.g., site samples).  During this phase, a field team conducts an
on-site visit and sampling.  Site sampling is limited in scope;
generally, about 15 samples are collected per site.  The media selected
for sampling depends on the perceived threat and may include all or some
of the following: ground water, surface water, sediment, soil, and air. 
Source samples may also be taken when deemed necessary.  Detailed
chemical analysis and data validation is performed on each sample taken.
 During the SI, the HRS model is applied by revising the preliminary HRS
score developed during the PA.  An SI report is the final product of
this phase.  Information collected during the SI is incorporated into
subsequent assessment work.

A site that is recommended for continued investigation may have an ESI
performed.  At this stage, specific information is usually gathered for
the pathway of greatest concern.  The goal of this investigation is to
test remaining theories about the nature and extent of contamination
proposed in the SI.  Additional field data that are collected usually
require specialized techniques or equipment (e.g., installation of
monitoring wells, geophysical surveys).  Data generated are used to
modify the preliminary HRS score developed during the SI.  An ESI report
is the final product of this phase.  Information collected during the
ESI is incorporated into subsequent assessment work.

A site that generates a preliminary HRS score of 28.50 or greater after
all assessment work is complete is eligible for proposal to the NPL,
although additional factors are considered before EPA moves forward with
proposing a site.  To propose a site, a detailed and defensible HRS
Scoring Package must be prepared.  This phase of data collection brings
together all of the information collected during the site assessment
process.  The HRS Package is thoroughly and meticulously referenced. 
The final product of this phase is the final HRS score.  A public docket
for a proposed site is maintained by EPA to provide an opportunity for
all interested parties to examine and comment on the HRS Package before
it is finalized in the Federal Register.

In order to expedite the data management effort and minimize the burden,
EPA developed “Quickscore” software for use as an automated site
scoring tool under the revised HRS.  Quickscore includes a user’s
manual, help screens, HRS score sheet calculation package, and a
computerized option for site score generation.    

In addition, EPA has sought to minimize the burden of data collection
requirements by making substantial resources available to the
respondents through the use of EPA contractors.  EPA will continue to
provide training to States and Tribes on a yearly basis through a
national training program.  To facilitate the HRS scoring effort, EPA
has, wherever possible, included tables to minimize the level of effort
necessary for data collection.  

EPA’s assessment process allows for the integration of traditional
site assessment activities to facilitate continuous assessment for
high-priority sites until all the necessary data are collected. 
Combining some phases of the site assessment process will often reduce
the level of effort expended on the duplication of similar
data-gathering activities.  Exhibit 4 presents EPA’s Integrated
Assessment process.  This integrated approach provides:

(	Prompt risk reduction through early action (removal or cleanup
activities);

(	Continuous process for assessing site-specific conditions and the need
for action;

(	Appropriate cleanup of long-term environmental problems;

(	Cross-program coordination of response planning;

(	Early initiation of enforcement activities; and

(	Early public notification and participation.

The Site Reassessment represents the gathering and evaluation of new
information on a site previously assessed under the Federal Superfund
Program to determine whether further Superfund attention is needed.  The
scope of work for a Site Reassessment activity is flexible, but will
usually represent a component of a traditional site assessment action. 
As such, it serves as a supplement to previous assessment work, and not
as a replacement for traditional assessment activities (e.g., PA, SI).

All data collection activities require the maintenance of file
information.  The final report for each phase of the site assessment
process is only part of the documentation of a site.  All relevant site
information collected or generated during the investigations should be
securely stored and accurately tracked for future reference.  This
information is critical for the preparation of any final HRS packages
and for future site disposition.  Each agency performing site
assessments or involved in the decision-making process of a site should
maintain a file of site data.

5(c)	Small Entity Flexibility tc \l2 "5(c)	Small Entity Flexibility 

Except in circumstances where a small business is a potentially
responsible party (PRP) or may provide some original information about a
specific site, small businesses are not burdened by the collection of
data for this program.

5(d)	Collection Schedule tc \l2 "5(d)	Collection Schedule 

	The site assessment process is intended to be a flexible method for
determining priorities among releases or threatened releases of
hazardous substances for the purpose of determining if further
investigation is necessary.  Site assessment information collection does
not occur on a regularly scheduled basis.  The frequency of collection
is driven by the schedule established in Section 116(b) of CERCLA. 
Section 116(b) requires an HRS evaluation (if warranted) within four
years of the site's entry into CERCLIS.  For sites brought to EPA’s
attention via a citizen’s petition, Section 105(d) of CERCLA requires
completion of a PA, or an explanation of why a PA is not appropriate,
within one year after receiving the petition.

6.	ESTIMATING THE BURDEN AND COST OF THE COLLECTION tc \l1 "6.
ESTIMATING THE BURDEN AND COST OF THE COLLECTION 

6(a)	Estimating Respondent Burden tc \l2 "6(a)	Estimating Respondent
Burden 

EPA estimates an annual average of 60 States and Tribes will conduct the
site assessment activities described in this ICR.  The annual burden for
respondents is a function of the number of State- and Tribal-lead
activities performed each year.  The estimated total annual burden for
State and Tribal authorities to conduct these activities is
approximately 148,873 hours.  This estimate was calculated by
multiplying the estimated average annual number of State- and
Tribal-lead activities projected from FY 2008 through FY 2011 by the
average hours needed to perform each activity.  Exhibit 5 provides
detailed information on the estimated annual respondent burden
(calculated as a weighted average based on information provided by EPA
regions).

Exhibit 5: Annual Respondent Burden



Respondent Activities	

Estimated Hours 

Per Activity1 	Estimated Annual Number of State/Tribal Activities1	Total
Annual National Hours by Activity



Pre-CERCLIS Screening	

99.08	

342	

33,885



Preliminary Assessment (PA)	

200.34	

111	

22,238



Site Inspection (SI)	

596.40	

75	

44,730



Integrated Assessment (IA)	

565.14	

7	

3,956



Expanded Site Inspection (ESI)	

702.56	

30	

21,077



Site Reassessment	

214.25	

84	

17,997



HRS Package	

712.86	

7	

4,990



TOTAL	

	

656	

148,873

1 Weighted average based on activity hours provided by the EPA Regions



To reduce the burden on respondents, EPA has streamlined the process of
screening sites to ensure that sites are assessed as efficiently and
inexpensively as conditions allow.  Sites not requiring Federal action
are screened out of the process early, thus avoiding lengthy and more
expensive evaluations.  For example, only about four percent of the
sites in the site assessment process have been listed on the NPL.  

Exhibit 6 provides an illustration of the site assessment screening
process.  The process is portrayed as a funnel to show how the number of
respondent activities performed generally decreases as sites progress
down the funnel and are screened out of the process.  Depending upon how
far a particular site progresses through the site assessment process,
the burden per site may range on average from 99 hours (average for
conducting pre-CERCLIS screening and no other work) to 2,311 hours
(cumulative average for conducting pre-CERCLIS screening, PA, SI, ESI,
and HRS package work).

Exhibit 6: Site Assessment Screening Process

*Historically includes about four percent of all sites in the CERCLIS
site assessment inventory.

6(b)	Estimating Respondent Costs tc \l2 "6(b)	Estimating Respondent
Costs 

The costs incurred by State and Tribal respondents for conducting site
assessment activities equals the estimated average cost per activity
(including laboratory costs) multiplied by the number of State/Tribal
lead activities.  In addition to activity-specific costs, the States and
Tribes incur infrastructure costs associated with developing and
maintaining a State or Tribal site assessment program.  These
infrastructure costs include such items as training, developing standard
operating procedures, administrative support, and computers and
automated data processing (ADP) support.

The total estimated annual respondent cost is $11,740,260, however both
activity-specific costs and infrastructure costs are reimbursed by the
EPA, thus the effective respondent cost is $0.

Exhibit 7 provides detailed information on the estimated annual
respondent burden and costs as calculated based on projected FY 2008
through FY 2010 activity data.  Depending upon how far a particular site
progresses through the site assessment process, the respondent cost per
site may range from $5,226 (average for conducting pre-CERCLIS screening
and no other work) to $152,848 (cumulative average for conducting
pre-CERCLIS screening, PA, SI, ESI and HRS package work).

Exhibit 7: Annual Respondent Burden and Costs



Respondent

Activities	

Estimated

Cost per

Activity1	

Estimated Annual Number of State/Tribal Activities1	

Total Annual

National Cost 

by Activity



Pre-CERCLIS Screening	

$5,226	

342	

$1,787,385



Preliminary Assessment (PA)	

$8,938	

111	

$992,084



Site Inspection (SI)	

$36,214	

75	

$2,716,035



Integrated Assessment (IA)	

$25,043	

7	

$175,300



Expanded Site Inspection (ESI)	

$52,521	

30	

$1,575,635



Site Reassessment	

$14,072	

84	

$1,182,066



HRS Package	

$49,949	

7	

$349,642

State/Tribal Infrastructure

	$2,962,113



SUBTOTAL	

 	

656	

$11,740,260

Less Federal Reimbursement

	-$11,740,260



TOTAL	

 	

656	$0



1 Weighted average based on activity costs provided by the EPA Regions



6(c)	Estimating Agency Burden and Costs tc \l2 "6(c)	Estimating Agency
Burden and Costs 

The EPA Regional offices review and manage sites assessed under
Superfund by States and Tribes, and provide oversight for State and
Tribal site assessment cooperative agreements.  Based on average annual
projections from FY 2008 through FY 2010, the estimated average annual
burden to the EPA for reviewing and managing site assessment activities
conducted by States and Tribes under Superfund is 49,669 hours at an
estimated cost of $4,529,813. Reimbursement of state costs brings the
total Agency cost to $16,270,073. Exhibit 8 provides detailed
information on the estimated annual Agency burden and costs as
calculated based on projected FY 2008 through FY 2010 activity data. 
Based on the 2007 GS pay schedule, EPA estimates an average hourly
Regional labor cost of $57, excluding the impact of benefits, to review
and manage the work covered under this ICR.  To derive hourly estimates,
EPA divided annual compensation estimates by 2,080 which is the number
of hours in the Federal work year.  EPA uses a multiplication factor of
1.6 to derive hourly estimates inclusive of benefits.  Taking into
account benefits, the average hourly rate is $91.20 ($57 x 1.6).

Exhibit 8: Annual Agency Burden and Cost

Respondent Activity	Estimated Hours per Activity 1	Estimated Cost per
Activity	Estimated No. Activities	Total Hours by Activity	Total Costs by
Activity

Review/Manage Pre-CERCLIS Screening	23	$2,098 	106	7,805	$711,816 

Review/Manage Preliminary Assessment	58	$5,290 	94	6,469	$589,973 

Review/Manage Site Inspection	274	$24,989 	61	20,556	$1,874,707 

Review/Manage Integrated Assessment 	98	$8,938 	3	684	$62,381 

Review/Manage Expanded Site Inspection	138	$12,586 	38	4,138	$377,386 

Review/Manage Site Reassessment 	92	$8,390 	76	7,767	$708,350 

Review/Manage HRS Package	321	$29,275 	25	2,250	$205,200 

SUBTOTAL	 	 	656	49,669	$4,529,813 

Reimbursement of State Costs	 	 	 	 	$11,740,260 

TOTAL	 	 	656	49,669	$16,270,073 

1 Weighted average based on activity hours provided by the EPA Regions

Approximately 61 regional EPA staff review and manage the Superfund site
assessment work carried out by states and tribes.  In addition to
reviewing site assessment reports submitted by states and tribes, EPA
staff conduct site management, oversight and quality assurance
activities.  Oversight activities include: reporting and recordkeeping
activities such as establishing and maintaining a master database;
answering respondent questions; auditing and reviewing data submissions;
recording and entering data submissions; analyzing requests for
confidentiality and providing confidentiality protection; reformatting
and distributing data; and storing data.

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

EPA estimates that an annual average of 60 States (including U.S.
Territories) and Tribes will perform the site assessment activities
described in this ICR.  The estimated annual burden to these respondents
for performing these activities is approximately 148,873 hours at a cost
of approximately $11,740,260.  One hundred percent of the respondent
cost ($11,740,260) is reimbursed by the EPA through cooperative
agreements.  On average, EPA estimates each respondent will complete and
submit approximately 11 assessment reports per year.

6(e)	Bottom Line Burden Hours and Costs

Total annual average estimated respondent burden hours and costs are
shown in Exhibit 9 below.  Exhibit 9 combines information in Exhibit 5
(respondent hours burden) and Exhibit 7 (respondent cost burden) into a
single table.   Total Agency burden hours and costs are shown in Exhibit
8 above.

Exhibit 9: Total Estimated Respondent Burden and Cost Summary

Respondent Activity	Estimated Hours per Activity	Estimated Cost per
Activity	Estimated No. Activities	Total Hours by Activity	Total Costs by
Activity

Review/Manage Pre-CERCLIS Screening	99.08	$5,226 	342	33,885	$1,787,385 

Review/Manage Preliminary Assessment	200.34	$8,938 	111	22,238	$992,084 

Review/Manage Site Inspection	596.4	$36,214 	75	44,730	$2,716,035 

Review/Manage Integrated Assessment 	565.14	$25,043 	7	3,956	$175,300 

Review/Manage Expanded Site Inspection	702.56	$52,521 	30	21,077
$1,575,635 

Review/Manage Site Reassessment 	214.25	$14,072 	84	17,997	$1,182,066 

Review/Manage HRS Package	712.86	$49,949 	7	4,990	$349,642 

State/Tribal Infrastructure 	 	 	 	 	$2,962,113 

SUBTOTAL	 	 	656	148,873	$11,740,260 

Less Federal Reimbursement	 	 	 	 	-$11,740,260

TOTAL	 	 	656	148,873	$0 



6(f)	Reasons for Change in Burden tc \l2 "6(f)	Burden Statement 

The estimated respondent burden presented in this ICR represents an
adjustment from the burden estimates of the previous ICR.  Respondent
burden is estimated to decline by 1,412 hours and by $1,840,115.  This
decrease is primarily due to a 28 percent decline in the number of total
activities to be performed by respondents combined with a 21 percent
decline in State/Tribal infrastructure costs.  The total hour burden
will decline by only one percent as respondents are expected to perform
a greater number of the more labor intensive ESI and HRS package
activities.  

6(g)	Burden Statement tc \l2 "6(f)	Burden Statement 

Depending on the number and type of activities performed, average burden
per Response is estimated as 226.9 hours.  Burden ranges from 99 to
2,311 hours per site.  The number of hours required to assess a
particular site depends on how far a site progresses through the site
assessment process.  Sites where only a pre-CERCLIS screening is
performed will on average  require approximately 99 hours (average for
conducting pre-CERCLIS screening and no other work), while sites that
progress to NPL listing may require approximately 2,311 hours
(cumulative average for conducting pre-CERCLIS screening, PA, SI, ESI
and HRS package work).  This burden estimate includes reporting
activities and minimal recordkeeping activities.

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 number
EPA-HQ-SFUND-2007-0888, which is available online viewing at   HYPERLINK
"http://www.regulations.gov"  www.regulations.gov , or in person viewing
at the Superfund Docket in the EPA Docket enter (EPA/DC) EPA West, Room
3334, 1301 Constitution Ave., NW, Washington, D.C.  The EPA Docket
Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday
through Friday, excluding legal holidays.  The telephone number for the
Reading Room is (202) 566-1744, and the telephone number for the
Superfund Docket is (202) 566-0276.  An electronic version of the public
docket is available at   HYPERLINK "http://www.regulations.gov" 
www.regulations.gov .  This site can be used to submit or view public
comments, access the index listing of the contents of the public docket,
and to access those documents in the public docket that are available
electronically.  When 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, D.C. 20503, Attention: Desk
Officer for EPA.  Please include the EPA Docket ID Number
EPA-HQ-SFUND-2007-0888 and OMB Control Number2050-0095 in any
correspondence. 

7.	REFERENCES tc \l1 "7.	REFERENCES 

United States Environmental Protection Agency. Office of Superfund
Remediation and Technology Innovation. Guidance for Performing
Preliminary Assessments Under CERCLA. OSWER 9345.0-01A.

EPA/540/G-91/013.  September 1991.

(http://www.epa.gov/superfund/sites/npl/hrsres)

http://www.epa.gov/superfund/)

United States Environmental Protection Agency.  Office of Superfund
Remediation and Technology Innovation.  Guidance for Performing Site
Inspections Under CERCLA,  Interim Final. OSWER 9345.1-05. EPA
540-R-92-021.  September 1992.

(http://www.epa.gov/superfund/sites/npl/hrsres)

United States Environmental Protection Agency.  Office of Solid Waste
and Emergency Response.  Hazard Ranking System Guidance Manual.  Interim
Final. Publication 9345.1-07. PB92-963377.  EPA 540-R-92-026.  November
1992.

(http://www.epa.gov/superfund/sites/npl/hrsres)

United States Environmental Protection Agency.  Office of Solid Waste
and Emergency Response.  USEPA, Superfund Program Implementation Manual
Fiscal Year 2008/2009, EPA 9200.3-14-1G-S, April 2007.

(http://www.epa.gov/superfund/action/process/spim08.htm)

42 US Code, Chapter 103, Comprehensive Environmental Response,
Compensation, and Liability.  January 1999.
(http://www.access.gpo.gov/uscode/title42/chapter103_subchapteri_.html)

United States Environmental Protection Agency.  Office of Solid Waste
and Emergency Response.  Improving Site Assessment: Pre-CERCLIS
Screening Assessments.  9375.2-11FS, October 1999.
(http://www.epa.gov/superfund/sites/npl/hrsres/fact/sascreen.pdf)

United States Environmental Protection Agency.  Office of Solid Waste
and Emergency Response.  Improving Site Assessment: Abbreviated
Preliminary Assessments.  9375.2-09FS, October 1999.
(http://www.epa.gov/superfund/sites/npl/hrsres/fact/apa.pdf)

United States Environmental Protection Agency.  Office of Solid Waste
and Emergency Response.  Improving Site Assessment: Integrating Removal
and Remedial Site Evaluations.  9330.0-39FS, April 2000.
(http://www.epa.gov/superfund/sites/npl/hrsres/fact/r&reval.pdf)

 

1  55 Federal Register 51532 (12/14/90) as codified in 40 CFR Part 300
at http://www.access.gpo.gov/nara/cfr/waisidx_03/40cfr300_03.html.

  Section 104 of CERCLA can be found at
http://www.access.gpo.gov/uscode/title42/chapter103_subchapteri_.html

  EPA’s 2006-2011 Strategic Plan can be found at
http://www.epa.gov/ocfo/plan/2006/entire_report.pdf

  Section 116 of CERCLA as amended by SARA can be found at
http://www.access.gpo.gov/uscode/title42/chapter103_subchapteri_.html.

  As stated in EPA’s ICR Handbook, revised November 2005, sensitive
questions are those concerning sexual behavior, attitudes, religious
beliefs, or matters usually considered private.

6  USEPA, Improving Site Assessment: Pre-CERCLIS Screening Assessments,
OSWER 9375.2-11FS, October 1999. 

  USEPA, Guidance for Performing Preliminary Assessments Under CERCLA,
OSWER 9345.0-01A, September 1991.

  USEPA, Improving Site Assessment: Abbreviated Preliminary Assessments,
OSWER 9375.2-09FS, October 1999	

9  USEPA, Guidance for Performing Site Inspections Under CERCLA, Interim
Final, OSWER 9345.1-05, September 1992.

  USEPA, Improving Site Assessment: Integrating Removal and Remedial
Site Evaluations, OSWER-9360.0-39FS, April 2000.

  USEPA, Superfund Program Implementation Manual Fiscal Year 2008/2009,
EPA 9200.3-14-1G-S, April 2007.

  USEPA, Guidance for Performing Site Inspections Under CERCLA, Interim
Final, OSWER 9345.1-05, September 1992.

  USEPA, Superfund Program Implementation Manual Fiscal Year 2008/2009,
EPA 9200.3-14-1G-S, April 2007. 

  Section 116 of CERCLA as amended by SARA can be found at
http://www.access.gpo.gov/uscode/title42/chapter103_subchapteri_.html.

  Figure provided by EPA Headquarters.

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