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> May 28, 2008

**[MEMORANDUM]{.underline}**

**TO:** Cyndy Merse

**CC:** Kristina Meson, Eileen Naples, and Rhonda Minnick

**FROM:** Earl Harris, Boris Rachev and Jennifer Agopsowicz

**SUBJECT:** Draft Burden Estimates for Schools Chemical Cleanout
Campaign (SC3) Survey; Work Assignment No. 1-50, Contract No.
EP-W-07-003

Attached is a document that estimates the annual burden of the SC3
Survey. It is submitted under Task 3 of the work assignment referenced
above. Please do not hesitate to contact us with questions or comments.

**Draft Burden Estimates for Draft Survey Form to be used under Schools
Chemical Cleanout Campaign (SC3)**

**1.0 Introduction**

The U.S. Environmental Protection Agency (EPA) is developing a survey to
collect information from its Partners under the Schools Chemical
Cleanout Campaign (SC3). Before the survey can be distributed to 10 or
more organizations, EPA must obtain clearance from the U.S. Office of
Management and Budget (OMB) pursuant to the 1995 Paperwork Reduction Act
(PRA). To request OMB clearance, EPA must submit an Information
Collection Request (ICR) that describes and justifies the proposed
survey and estimates the annual hour and cost burden to respondents
(i.e., Partners) and the Agency.

This document presents EPA's draft burden estimates for respondents and
the Agency to carry out the survey. Section 2.0 of this document briefly
describes the SC3 Program and draft survey instrument. Section 3.0
presents EPA's draft burden estimates.

Over the coming months, EPA will continue to refine its survey and
burden estimates as it prepares the ICR. Among other things, EPA will
conduct a pre-test of the survey. EPA will ask participants of the
pre-test for feedback on the survey (e.g., its clarity and
effectiveness) and their burden to complete it. In addition, EPA will
review the public's comments received in response to the notice in the
[Federal Register]{.underline} announcing its intent to forward an ICR
to OMB. EPA will modify the survey and ICR to reflect this feedback as
appropriate before forwarding them to OMB.

**2.0 Background of SC3 and Proposed Survey**

The Schools Chemical Cleanout Campaign (SC3) was created in 2004,
building on regional, state, tribal, and local SC3 programs across the
nation. The National SC3 program was launched in March of 2007. The
National SC3 program uses a variety of innovative approaches to achieve
three goals: (1) removal of outdated and dangerous chemicals from K-12
schools; (2) prevention of future accumulations of chemicals and
reduction of accidents by establishing prevention activities such as
good purchasing and management practices; and, (3) raising national
awareness of the problem.

One of the ways that EPA accomplishes its goals is by partnering with
organizations that volunteer to assist schools in the management of the
schools' chemicals and the removal of schools' chemical waste. There are
currently eleven Partners.

To evaluate the current state of the program and determine what the
future direction should be, EPA intends to conduct a voluntary survey of
its Partners to gather information on their activities and the results
of their work under the program. To this end, EPA has prepared a draft
survey form with four main goals:

-   Collect general information about the Partners (e.g., reasons for
    joining the SC3 Program, future plans, etc.);

-   Identify the accomplishments of Partners under the SC3 Program and
    how many schools/school districts, students and school personnel are
    involved/impacted;

-   Identify additional resources needed by Partners to accomplish SC3
    goals; and

-   Collect lessons learned from Partners on what has worked and what
    has not worked under the Program, so this information can be shared
    with others.

EPA intends to ask Partners to complete and submit the survey while the
partnership is in effect. The survey will be available to Partners in an
electronic format. They can submit completed surveys by email, postal
mail, or fax.

**3.0 Hour and Cost Burden of the Collection**

This section describes EPA's burden estimates for respondents and the
Agency to carry out the survey. Sections 3.1 and 3.2 describe the
Agency's assumptions used in calculating the annual bottom-line burden
to respondents and Agency, respectively. Section 3.3 presents the
estimated bottom-line annual burden to respondents and the Agency.

> **3.1 Respondent Burden Assumptions**

The following paragraphs describe the assumptions used to derive the
annual respondent burden estimates. Exhibit 1, presented in Section 3.3,
provides an estimate of the bottom-line annual burden to respondents
under the survey.

**[Respondent Universe and Burden Hour Assumptions]{.underline}**

There are currently eleven Partners in the SC3 Program. In addition, EPA
expects that eleven new Partners will join SC3 each year. Each Partner
will be asked to complete and submit the survey annually.

EPA estimates that it will take a Partner one hour, on average, to
complete and submit a survey for the first time. EPA estimates that a
Partner will take less time to complete and submit a survey in each
subsequent year. This is because these Partners will be able to build
from their previously submitted survey. For example, some of the
survey's questions ask a Partner to provide general information about
its organization (e.g., how it became aware of SC3, why it joined SC3,
etc.). Partners would not need to provide new responses to such
questions if their previous responses are still valid. In addition, they
will be more familiar with the instructions and information needs than
the first time. Because of these reasons, EPA estimates that it will
take a Partner 45 minutes, on average, to update and submit a survey in
each subsequent year.

The table below shows the number of Partners expected to complete the
survey in each of the three years of the ICR.[^1] It shows that:

-   In the first year of the ICR, EPA estimates that the eleven existing
    Partners, as well as the eleven new Partners expected to join the
    Program during the year, will complete the survey for their first
    time.

-   In the second year, EPA estimates that the 22 existing Partners will
    update their previously completed survey. In addition, eleven new
    Partners will complete the survey for their first time.

-   In the third year, EPA estimates that the 33 existing Partners will
    update their previously completed survey. In addition, eleven new
    Partners will complete the survey for their first time.

Based on these assumptions, the table shows the *average* annual number
of Partners estimated to complete the survey during the three-year life
of this ICR (i.e., the total number of Partners divided by three years).
Specifically, it shows that, on average each year, 15 Partners will
prepare a survey for their first time and 18 Partners will update a
survey that had been completed in a previous year.

+-------------------------------+-------+-------+------+--------------+
| **Partners**                  | **A   |       |      | **Average    |
|                               | nnual |       |      | Annual**     |
|                               | N     |       |      |              |
|                               | umber |       |      | **Number of  |
|                               | of    |       |      | Partners\*** |
|                               | Partn |       |      |              |
|                               | ers** |       |      |              |
+===============================+=======+=======+======+==============+
|                               | *     | *     | **   |              |
|                               | *Year | *Year | Year |              |
|                               | 1**   | 2**   | 3**  |              |
+-------------------------------+-------+-------+------+--------------+
| Partners that complete survey | 22    | 11    | 11   | 15           |
| for the first time            |       |       |      |              |
+-------------------------------+-------+-------+------+--------------+
| Partners that update survey   | 0     | 22    | 33   | 18           |
| that had been completed in a  |       |       |      |              |
| previous year                 |       |       |      |              |
+-------------------------------+-------+-------+------+--------------+
| Total                         | 22    | 33    | 44   | 33           |
+-------------------------------+-------+-------+------+--------------+

\* Total number of Partners in Years 1-3 divided by three years
(includes rounding).

EPA used the average annual number of respondents, along with the burden
estimates described above, to estimate the average annual burden to
respondents. Specifically, EPA estimates that 15 Partners will take one
hour to prepare a survey for the first time and 18 Partners will take 45
minutes to update their survey on average each year. These assumptions
are reflected in Exhibit 1.

> **[Respondent Cost Assumptions]{.underline}**
>
> Exhibit 1 reflects the following cost assumptions:

-   Labor costs -- The respondent labor costs in Exhibit 1 were obtained
    from the "May 2006 National Occupational Employment and Wage
    Estimates." The estimates can be found in the Occupational
    Employment Statistics, U.S. Department of Labor, U.S. Bureau of
    Labor Statistics. EPA updated the 2006 wage estimates to 2008 wage
    levels using the employment cost index. EPA then multiplied the
    rates by the labor cost fringe benefits and overhead factor of
    1.4845.[^2] Based on this, EPA estimates an average loaded
    respondent hourly labor rate of \$64.63 for legal staff, \$69.61 for
    managerial staff, \$45.44 for technical staff, and \$22.99 for
    clerical staff.

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-   Operation and maintenance (O&M) costs -- O&M costs are defined by
    the PRA as the recurring costs associated with a collection of
    information (e.g., postage, photocopying, etc.). EPA expects all
    Partners to use their existing email capabilities to submit
    completed surveys to EPA. EPA does not expect any O&M costs to
    respondents in carrying out the survey.

-   Capital costs -- Capital costs usually include any produced physical
    good needed to provide the needed information, such as machinery,
    computers, and other equipment. EPA does not expect any capital
    costs to respondents in completing the survey.

> **3.2 Agency Burden Assumptions**

The following paragraphs describe the assumptions used to derive the
annual Agency burden estimates. Exhibit 2, presented in Section 3.3,
provides an estimate of the bottom-line annual burden to the Agency
under the survey.

> **[Agency Burden Hour Assumptions]{.underline}**

EPA estimates that Agency personnel will take 15 minutes on average to
review and keep records of each completed survey collected from
Partners. This is reflected in Exhibit 2.

> **[Agency Cost Assumptions]{.underline}**

Exhibit 2 reflects the following cost assumptions:

-   Labor costs -- Unloaded hourly wage rates for EPAs' activities were
    taken from the 2008 General Schedule and Locality Pay Tables from
    the U.S. Office of Personnel Management. EPA then multiplied the
    rates by the labor cost fringe benefits and overhead factor of 1.6.
    Based on this, EPA applied the following average loaded hourly wage
    rates for government labor: \$76.67 per hour for legal staff,
    \$70.46 per hour for managerial staff, \$59.63 per hour for
    technical staff, and \$22.82 per hour for clerical staff.

-   Operation and maintenance (O&M) costs -- EPA does not expect any O&M
    costs to the Agency in carrying out the survey.

-   Capital costs -- EPA does not expect any capital costs to the Agency
    in administering the survey.

> **3.3 Bottom-line Annual Respondent and Agency Burden**
>
> Exhibit 1 shows that the bottom-line annual respondent hour and cost
> burden is estimated to be 28 hours and \$1, 247.
>
> Exhibit 2 shows that the bottom-line annual Agency hour and cost
> burden is estimated to be 8 hours and \$388.

  --------------- ------------ ------------ ----------- ---------- ---------------- ---------------- --------- -------- ------------ ------------ ------------
  **Exhibit 1\*                                                                                                                                   
  Estimated                                                                                                                                       
  Annual                                                                                                                                          
  Respondent Hour                                                                                                                                 
  and Cost                                                                                                                                        
  Burden - SC3                                                                                                                                    
  Survey**                                                                                                                                        

                                                                                                                                                  

                                                                                                                                                  

                  **Hours and                                                                                           **Total                   
                  Costs Per                                                                                             Hours and                 
                  Respondent                                                                                            Costs**                   
                  Activity**                                                                                                                      

  **Information   Legal        Managerial   Technical   Clerical   Labor            Labor            Capital   O&M      No. of       Total        Total
  Collection                                                       Hours/Activity   Costs/Activity   Costs     Costs    Respond./    Hours/Year   Cost/Year
  Activity**                                                                                                            Activities                

                  \$64.63      \$69.61      \$45.44     \$22.99                                                                                   

  **Survey                                                                                                                                        
  Instrument**                                                                                                                                    

  Partners        0.00         0.10         0.70        0.20       1.00             \$43.37          \$0.00    \$0.00   15           15           \$650.55
  complete survey                                                                                                                                 
  for the first                                                                                                                                   
  time                                                                                                                                            

  Partners update 0.00         0.10         0.50        0.15       0.75             \$33.13          \$0.00    \$0.00   18           14           \$596.34
  survey that was                                                                                                                                 
  previously                                                                                                                                      
  completed                                                                                                                                       

  Total           0.00         varies       varies      varies     varies           varies           \$0.00    \$0.00   33           29           \$1,246.89

  \* Exhibit                                                                                                                                      
  includes                                                                                                                                        
  rounding.                                                                                                                                       
  --------------- ------------ ------------ ----------- ---------- ---------------- ---------------- --------- -------- ------------ ------------ ------------

  ---------------- ------------ ------------ ----------- ---------- ---------- ---------- --------- -------- ------------ -------- ----------
  **Exhibit 2\*                                                                                                                    
  Estimated Annual                                                                                                                 
  Agency Hour and                                                                                                                  
  Cost Burden -                                                                                                                    
  SC3 Survey**                                                                                                                     

                                                                                                                                   

                                                                                                                                   

                   **Hours and                                                                               **Total               
                   Costs Per                                                                                 Hours and             
                   Agency                                                                                    Costs**               
                   Activity**                                                                                                      

  **Information    Legal        Managerial   Technical   Clerical   Labor      Labor      Capital   O&M      No. of       Total    Total
  Collection                                                        Hours/     Costs/     Costs     Costs    Agency       Hours/   Cost/ Year
  Activity**                                                        Activity   Activity                      Activities   Year     

                   \$76.67      \$70.46      \$59.63     \$22.82                                                                   

  **Survey                                                                                                                         
  Instrument**                                                                                                                     

  Review and keep  0.00         0.05         0.10        0.10       0.25       \$11.77    \$0.00    \$0.00   33           8        \$388.41
  records of                                                                                                                       
  completed                                                                                                                        
  surveys                                                                                                                          

  Total            0.00         0.05         0.10        0.10       0.25       \$11.77    \$0.00    \$0.00   33           8        \$388.41

  \* Exhibit                                                                                                                       
  includes                                                                                                                         
  rounding.                                                                                                                        
  ---------------- ------------ ------------ ----------- ---------- ---------- ---------- --------- -------- ------------ -------- ----------

[^1]: An ICR is normally effective for three years from the date of OMB
    approval. After three years, the ICR must be updated and submitted
    to OMB for renewal.

[^2]: Source: The 1.4845 fringe and overhead multiplier factor
    represents 36.45% full fringe benefits factor plus 12% overhead cost
    factor. For the 12% overhead estimate see OMB Circular No. A-76,
    Attachment C, May 29, 2003: Calculating Public-Private Competition
    Costs, Figure C1 Table of Standard A-76 Costing Factors. The
    document can be found at:
    <http://www.whitehouse.gov/omb/circulars/a076/a76_incl_tech_correction.pdf>.
    For the 36.45% fringe benefits estimate see the Update to Civilian
    Position Full Fringe Benefit Cost Factor, Federal Pay Raise
    Assumptions, Inflation Factors, and Tax Rates used in OMB Circular
    No. A-76, "Performance of Commercial Activities,\" October 31, 2006.
    The document can be found at:
    http://www.whitehouse.gov/omb/memoranda/fy2007/m07-02.pdf.