RENEWAL OF INFORMATION COLLECTION REQUEST FOR THE CONTINUOUS RELEASE
REPORTING REQUIREMENT

[1. IDENTIFICATION OF THE INFORMATION COLLECTION
3](#identification-of-the-information-collection)

[1a. Title of the Information Collection
3](#title-of-the-information-collection)

[1b. Short Characterization/Abstract 3](#short-characterizationabstract)

[2. NEED FOR AND USE OF THE COLLECTION
5](#need-for-and-use-of-the-collection)

[2a. Need and Authority for the Collection
5](#need-and-authority-for-the-collection)

[2b. Practical Utility and Users of the Data
5](#practical-utility-and-users-of-the-data)

[3. NON DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA
6](#non-duplication-consultations-and-other-collection-criteria)

[3a. Non Duplication 6](#non-duplication)

[3b. Public Notice Required Prior to ICR Submission to OMB
7](#public-notice-required-prior-to-icr-submission-to-omb)

[3c. Consultations 7](#consultations)

[3d. Effects of Less Frequent Collection
7](#effects-of-less-frequent-collection)

[3e. General Guidelines 8](#general-guidelines)

[3f. Confidentiality 8](#confidentiality)

[3g. Sensitive Questions 8](#sensitive-questions)

[4. THE RESPONDENTS AND THE INFORMATION REQUESTED
8](#the-respondents-and-the-information-requested)

[4a. Respondents and SIC Codes 8](#respondents-and-naics-codes)

[4b. Information Requested 8](#information-requested)

[i. Data items, including record keeping requirements
8](#data-items-including-record-keeping-requirements)

[ii. Respondent Activities 12](#respondent-activities)

[5. THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, COLLECTION
METHODOLOGY, AND INFORMATION MANAGEMENT
13](#the-information-collected-agency-activities-collection-methodology-and-information-management)

[5a. Agency Activities 13](#agency-activities)

[5b. Collection Methodology and Management
14](#collection-methodology-and-management)

[5c. Small Entity Flexibility 14](#small-entity-flexibility)

[5d. Collection Schedule 14](#collection-schedule)

[6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION
15](#estimating-the-burden-and-cost-of-the-collection)

[6a. Estimating Respondent Burden 15](#estimating-respondent-burden)

[6b. Estimating Respondent Costs 21](#estimating-respondent-costs)

[i. Estimating Labor Costs 21](#estimating-labor-costs)

[ii. Estimating Capital and Operations and Maintenance Costs
23](#estimating-capital-and-operations-and-maintenance-costs)

[6c. Estimating Agency Burden and Cost
26](#estimating-agency-burden-and-cost)

[6d. Estimating the Respondent Universe and Total Burden and Cost
29](#estimating-the-respondent-universe-and-total-burden-and-cost)

[6e. Bottom Line Burden Hours and Cost Tables
30](#bottom-line-burden-hours-and-cost-tables)

[i. Respondent Tally 31](#respondent-tally)

[ii. The Agency Tally 33](#the-agency-tally)

[iii. Variations in the Annual Bottom Line
35](#variations-in-the-annual-bottom-line)

[6f. Reasons for Change in Burden 36](#reasons-for-change-in-burden)

[6g. Burden Statement 36](#burden-statement)

[APPENDIX A 38](#__RefHeading___Toc188347120)

#   {#section .unnumbered}

# IDENTIFICATION OF THE INFORMATION COLLECTION

## Title of the Information Collection

Continuous Release Reporting Regulations (CRRR) under the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980
(CERCLA)(Renewal) - EPA No. 1445.07.

## Short Characterization/Abstract 

This information collection request (ICR) addresses the reporting and
record keeping activities required to comply with EPA's continuous
release reporting regulation (CRRR; 40 CFR 302.8) implementing section
103(f)(2) of the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA). The CRRR clarifies the types of releases
that qualify for reporting under CERCLA section 103(f)(2) and
establishes the reporting requirements applicable to qualifying
releases. Responsibility for information collection activities of the
CRRR reside in the Office of Emergency Management (OEM) in the Office of
Solid Waste and Emergency Response (OSWER). This ICR renews the
collection activity previously approved under OMB No. 2050-0086 and
applies to the period February 29, 2008 through February 28, 2010.
Estimates of the burden placed on industry and the government to comply
with the release notification requirements are presented on an annual
basis.

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

> • Gather necessary release data, such as the time, quantity, and
> source of the release;
>
> • Notify the facility manager of the release;
>
> • Consult with the environmental compliance expert regarding the
> release;
>
> • Make an initial report of the release to the NRC;
>
> • Submit an initial written notification to the appropriate EPA
> Regional Office for the geographical area where the releasing facility
> or vessel is located;
>
> • Provide follow-up notification within 30 days of the first
> anniversary date of the initial written notification;
>
> • Make notifications to the NRC if there is a change in the release,
> including a statistically significant increase in a release;
>
> • Make an annual evaluation of releases to determine if changes have
> occurred in the information submitted in the initial written
> notification, the follow-up notification and/or in a previous change
> notification - if there are no changes, submittal of a report is not
> required.
>
> • Keep all supporting documents, materials, and other information on
> file for a period of one year to substantiate the reported normal
> range of releases, the basis for stating that the release is
> continuous and stable in quantity and rate, and the other information
> in the initial written report, the follow-up report, and the annual
> evaluations.

The continuous release final rule has been in effect since September 24,
1990. This ICR utilizes historical data on the number of continuous
release reports submitted to the Federal government to estimate the
number of burden hours attributable to the CRRR. The statistics on the
number of continuous release reports submitted to the Federal government
are available through the National Response Center's incident data
base.[^1]

In the first year of the three-year period covered by this ICR, it is
estimated the 3,565 facilities will be affected by the CRRR. Of the
3,565 facilities affected in the first year, it is assumed that 19 will
be reporting continuous releases for the first time and the remaining
3,546 will be meeting information collection requirements for ongoing
releases. In the second and third years, it is estimated that 21 and 22
additional facilities, respectively, will generate reportable continuous
releases. When calculating the burdens and costs in this ICR it has been
assumed that the typical facility participates in information collection
activities for each release. For example, the typical facility will
provide an initial telephone notification and written report for each of
its continuous releases. In fact, it is likely that many facility
operators will consolidate collection activities for releases at their
facilities (e.g., provide one telephone notification for several
releases). Assuming eight releases per facility per year, and thus 8
information collection activities per facility per year, the total
number of continuous release information collection activities in the
first year of the three-year period covered by this ICR is estimated to
be 28,523 (155 initial notification activities and 28,368 ongoing
notification activities). In the second and third years of the period
covered by this ICR, it is estimated that 166 and 179 information
collection activities, respectively, will take place. The total
estimated burden to respondents is approximately 299,546, 301,460, and
303,517 hours in years 1, 2, and 3, respectively. For the regulated
community, the estimated information collection activity costs
(including labor and O&M costs) are \$10,224,985, \$10,287,614, and
10,358,023 in years 1, 2, and 3, respectively. The total estimated
burden to the government is approximately 26,627, 26,170, and 26,372
hours in years 1, 2, and 3, respectively. The estimated total cost to
the government is \$1,149,443, \$1,129,713, and \$1,138,434, in years 1,
2, and 3, respectively.

# NEED FOR AND USE OF THE COLLECTION

## Need and Authority for the Collection

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

## Practical Utility and Users of the Data

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

# NON DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

## Non Duplication

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

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

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

## Public Notice Required Prior to ICR Submission to OMB

In compliance with the Paperwork Reduction Act (PRA) (44 U.S.C. 3501 [et
seq]{.underline}.), EPA has notified the public through the [Federal
Register]{.underline} notice on the renewal of this ICR (See 72
[FR]{.underline} 55197, Sept. 28, 2007). The Docket ID No. for the
notice is EPA-HQ-SFUND-2007-0278, and can be accessed at
[www.regulations.gov](http://www.regulations.gov/). There were no
comments received.

## Consultations

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

EPA sponsored several workshops throughout the country for industry and
Federal, State, and local government officials on the release
notification requirements under CERCLA and SARA Title III, including the
requirements under the CRRR. The workshops were held to educate the
regulated community as well as those Federal and State agencies required
to implement the regulations. In addition, the workshops provided an
opportunity for the public to comment on the implementation of the
regulation. No workshops were conducted or planned during the period
covered by ICR 1445.06 (November 2004 through November 2007).

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

## Effects of Less Frequent Collection

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

## General Guidelines

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

## Confidentiality

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

## Sensitive Questions

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

# THE RESPONDENTS AND THE INFORMATION REQUESTED

## Respondents and NAICS Codes

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

## Information Requested

### Data items, including record keeping requirements

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

(1) An initial telephone call to the NRC;

(2) An initial written report to the EPA Region;

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

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

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

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

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

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

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

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

(8) The name and location of the facility; and

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

### Respondent Activities

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

(1) Provides an initial telephone call to the NRC;

(2) Provides an initial written report to the EPA Region;

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

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

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

(6) Prepares change in other information reports;

(7) Provides immediate notifications of SSIs; and

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

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

(9) Provision of additional information; and

(10) Site inspection.

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

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

## Agency Activities

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

> • Request additional information; and
>
> • Conduct site inspections.

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

## Collection Methodology and Management

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

## Small Entity Flexibility

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

## Collection Schedule

The facility must provide an initial telephone call to the NRC as soon
as the person in charge has knowledge of a hazardous substance release
that equals or exceeds its RQ. The caller must decide whether to report
the release under CERCLA section 103(a) (i.e., as an episodic release)
or CERCLA section 103(f)(2) (i.e., as a continuous release). The
reporting and record keeping activities associated with reporting an
episodic release under CERCLA section 103(a) are presented in EPA ICR
No. 1049.11. If the caller reports a continuous release, the initial
written report required by CERCLA section 103(f)(2) must be provided
within 30 days of the initial telephone call. In the second year of
reporting, the facility must submit a written follow-up report to the
EPA Region within 30 days of the anniversary date of submission of the
initial written report. This report is sometimes called the First
Anniversary Report. Thereafter, the reporting facility is responsible
for reevaluating the release annually, but no reports are required
unless there is a change in the sources or composition of a release, a
change in release information previously submitted, or an SSI in the
release.

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

# ESTIMATING THE BURDEN AND COST OF THE COLLECTION

## Estimating Respondent Burden

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

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

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

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

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

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

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

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

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

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

**Reporting a Statistically Significant Increase in the Release** -- As
soon as the person in charge of a facility has knowledge that the
quantity of a continuous release being reported under CERCLA section
103(f)(2) exceeds the upper bound of its previously established normal
range of release weights, the person in charge must notify the NRC. SSIs
are episodic release events because the release has not been previously
reported or evaluated. To avoid underestimating the burden, this ICR
includes the burden for reporting an SSI, even though the burden may be
captured in the ICR for episodic releases (EPA 1409.11). The estimated
burden of reporting an SSI is based on interviews with chemical industry
personnel and the burden associated with reporting similar episodic
releases under CERCLA section 103(a). EPA estimates that reporting of an
SSI requires one hour of managerial time and one hour of technical time
for a total burden of *two hours*. The technical time consists of
determining if the release is reportable, briefing management, and
collecting the information required for NRC reporting. The managerial
time includes alerting appropriate personnel and transmitting the
information required in the telephone call.

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

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

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

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

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

**Exhibit 1**

**Unit Burden Hours per Respondent Information Collection Activity**

  ------------------------------------------------------------------------------------------------------
  **Collection        **When Collection   **Percentage   **Unit                              
  Activity**          Activity is         of Continuous  Burden                              
                      Performed**         Releases that  Hours**                             
                                          Will Require a                                     
                                          Collection                                         
                                          Activity**                                         
  ------------------- ------------------- -------------- --------- ---------- -------------- -----------
                                                         **Mgt**   **Tech**   **Clerical**   **Total**

  Providing an        When first          100% of new    1.0       2.0        0.0            **3.0**
  Initial Telephone   reporting a release releases                                           
  Notification                                                                               

  Preparing an        Within 30 days of   100% of new    3.0       4.0        1.0            **8.0**
  Initial Written     an initial          releases                                           
  Report              telephone                                                              
                      notification                                                           

  Preparing a         A year after the    100% of all    3.0       1.0        1.0            **5.0**
  Follow-up Written   submission of an    second year                                        
  Report              initial written     releases                                           
                      report                                                                 

  Conducting an       Each year beginning 100% of all    3.0       1.0        1.0            **5.0**
  Annual Evaluation   the year after the  third year and                                     
  of a Release        submission of a     subsequent                                         
                      written follow-up   year releases                                      
                      report                                                                 

  Reporting a Change  When the sources,   5% each year   4.0       4.0        1.0            **9.0**
  in the Sources,     composition, or     of all new and                                     
  Composition, or     frequency of a      current                                            
  Frequency of a      release changes     releases                                           
  Release                                                                                    

  Reporting Other     Changes in other    10% each year  1.0       1.0        0.5            **2.5**
  Changes in          information         of all new and                                     
  Information                             current                                            
                                          releases                                           

  Reporting an SSI in Immediately after   5% each year   1.0       1.0        0.0            **2.0**
  a Release           an SSI event is     of all new and                                     
                      noticed             current                                            
                                          releases                                           

  Other Activities -- Upon EPA request    30% each year  4.0       0.0        0.0            **4.0**
  Providing                               of all new and                                     
  Additional                              current                                            
  Information                             releases                                           

  Other Activities -- Upon EPA request    1% each year   4.0       4.0        0.0            **8.0**
  Facilitating a Site                     of all new and                                     
  Inspection                              current                                            
                                          releases                                           

  Record keeping      Each year of a      100% of all    0.0       4.0        0.0            **4.0**
                      release             new and                                            
                                          current                                            
                                          releases                                           
  ------------------------------------------------------------------------------------------------------

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

  -------------- ---------- ---------- -------------- ----------- ---------- ---------- -------------- ----------- ---------- ---------- -------------- -----------
  **Exhibit 2**                                                                                                                                         

  **Burden Hours                                                                                                                                        
  for a Typical                                                                                                                                         
  Facility\***                                                                                                                                          

  **Collection   **First                                          **Second                                         **Third                              
  Activity**     Year                                             Year                                             Year                                 
                 Burden                                           Burden                                           Burden                               
                 Hours**                                          Hours**                                          Hours**                              

                 **Mgt**    **Tech**   **Clerical**   **Total**   **Mgt**    **Tech**   **Clerical**   **Total**   **Mgt**    **Tech**   **Clerical**   **Total**

  Providing an   8.0        16.0       0.0            **24.0**    NA         NA         NA             **0.0**     NA         NA         NA             **0.0**
  Initial                                                                                                                                               
  Telephone                                                                                                                                             
  Notification                                                                                                                                          

  Preparing an   24.0       32.0       8.0            **64.0**    NA         NA         NA             **0.0**     NA         NA         NA             **0.0**
  Initial                                                                                                                                               
  Written Report                                                                                                                                        

  Preparing a    NA         NA         NA             **0.0**     24.0       8.0        8.0            **40.0**    NA         NA         NA             **0.0**
  Follow--up                                                                                                                                            
  Written Report                                                                                                                                        

  Conducting an  NA         NA         NA             **0.0**     NA         NA         NA             **0.0**     24.0       8.0        8.0            **40.0**
  Annual                                                                                                                                                
  Evaluation of                                                                                                                                         
  a Release                                                                                                                                             

  Reporting      NA         NA         NA             **0.0**     1.0        1.0        0.5            **2.5**     1.0        1.0        0.5            **2.5**
  Other Changes                                                                                                                                         
  in Information                                                                                                                                        

  Record keeping 0.0        32.0       0.0            **32.0**    0.0        32.0       0.0            **32.0**    0.0        32.0       0.0            **32.0**

  **Total Burden **32.0**   **80.0**   **8.0**        **120.0**   **25.0**   **41.0**   **8.5**        **74.5**    **25.0**   **41.0**   **8.5**        **74.5**
  Hours for a                                                                                                                                           
  Typical                                                                                                                                               
  Facility**                                                                                                                                            

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

NA = Not Applicable

## Estimating Respondent Costs

### Estimating Labor Costs

The estimated cost to complete various continuous release reports
required under the CRRR is a function of the time expended by industry
personnel (i.e., the burden estimates presented in section 6(a)), and
the hourly wage rates for the appropriate categories of labor. The
hourly wage rates used for industry in this ICR are from December 2006
and were obtained from the Bureau of Labor Statistics.[^2] For purposes
of this analysis, EPA estimates an average hourly respondent labor cost
of \$50.41 for managerial staff, \$22.60 for technical staff, and
\$21.58 for clerical staff.

These rates reflect the employer costs for employee compensation in the
United States as of December 2006 and include both employer costs for
legally required benefits (e.g., social security, worker's compensation,
and unemployment insurance), other important fringe benefit categories
(e.g., insurance, paid leave, retirement, and savings), and overhead and
general and administrative costs. Costs associated with the burden hours
presented in Section 6(a) of this ICR are shown in Exhibit 3.

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

[]{.mark}

  ------------------ ------------------- ------------------ ----------------- ----------
  **Exhibit 3**                                                               

  **Unit Labor Cost                                                           
  per Respondent                                                              
  Information                                                                 
  Collection                                                                  
  Activity**                                                                  

  **Collection       **Burden Hours**                                         **Unit
  Activity**                                                                  Labor
                                                                              Cost**

                     **Managerial/hr**   **Technical/hr**   **Clerical/hr**   

                     **\$50.41**         **\$22.60**        **\$21.58**       

  Providing an       1.0                 2.0                0.0               \$95.61
  Initial Telephone                                                           
  Notification                                                                

  Preparing an       3.0                 4.0                1.0               \$263.21
  Initial Written                                                             
  Report                                                                      

  Preparing a        3.0                 1.0                1.0               \$195.41
  Follow-up Written                                                           
  Report                                                                      

  Conducting an      3.0                 1.0                1.0               \$195.41
  Annual Evaluation                                                           
  of a Release                                                                

  Reporting a Change 4.0                 4.0                1.0               \$313.62
  in the Sources,                                                             
  Composition, or                                                             
  Frequency of a                                                              
  Release                                                                     

  Reporting Other    1.0                 1.0                0.5               \$83.80
  Changes in                                                                  
  Information                                                                 

  Reporting an SSI   1.0                 1.0                0.0               \$73.01
  in a Release                                                                

  Other Activities   4.0                 0.0                0.0               \$201.64
  -- Providing                                                                
  Additional                                                                  
  Information                                                                 

  Other Activities   4.0                 4.0                0.0               \$292.04
  -- Facilitating a                                                           
  Site Inspection                                                             

  Record keeping     0.0                 4.0                0.0               \$90.40
  ------------------ ------------------- ------------------ ----------------- ----------

[]{.mark}

[]{.mark}

  --------------------------- ------------------- ------------------ ----------------- ---------------- ---------------- ----------------
  **Exhibit 4**                                                                                                          

  **Annual Labor Costs for a                                                                                             
  Typical Facility**\*                                                                                                   

  **Collection Activity**     **Annual Burden                                          **Annual Labor                    
                              Hours**                                                  Costs**                           

                              **Managerial/hr**   **Technical/hr**   **Clerical/hr**   **First Year**   **Second Year**  **Third Year**

                              **\$50.41**         **\$22.60**        **\$21.58**                                         

  Providing an Initial        8                   16                 0                 \$764.88         NA               NA
  Telephone Notification                                                                                                 

  Preparing an Initial        24                  32                 8                 \$2,105.68       NA               NA
  Written Report                                                                                                         

  Preparing a Follow-up       24                  8                  8                 NA               \$1,563.28       NA
  Written Report                                                                                                         

  Conducting an Annual        24                  8                  8                 NA               NA               \$1,563.28
  Evaluation of a Release                                                                                                

  Reporting Other Changes in  1                   1                  0.5               NA               \$83.80          \$83.80
  Information                                                                                                            

  Record keeping              0                   32                 0                 \$723.20         \$723.20         \$723.20

  **Total Labor Costs for a   ** **               ** **              ** **             **\$3,593.76**   **\$2,370.28**   **\$2,370.28**
  Typical Facility**                                                                                                     

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

NA = Not Applicable

### Estimating Capital and Operations and Maintenance Costs

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

Operating and Maintenance (O&M) costs are those costs associated with a
paperwork requirement incurred continually over the life of the ICR.
They are defined by the PRA as "the recurring dollar amount of cost
associated with O&M or purchasing services." The O&M costs that are
incurred by industries are shown in Exhibit 5. For this ICR, O&M costs
cover photocopying of report templates to be filled out for each release
source (25 cents per page) and postage and an envelope for reports sent
to the Agency. There are no O&M costs associated with providing the
initial telephone notification to the Agency or reporting an SSI under
the CRRR. Each written report, the initial written report, the follow-up
written report, changes in sources, composition, or frequency of release
report, and other changes in information report, are assumed to require
five pages. Requests for additional information by the Agency will vary
considerably in scope and length, depending on the nature of the
request, however, it is estimated that it will take industry
approximately 10 pages to complete the Agency's request. The postage and
mailing costs are assumed to be equal for all documents, and are
calculated as \$5.12 postage and \$0.30 per envelope, totaling \$5.42
per report.[^3]

  -------------------------------- ---------------- --------------- ----------
  **Exhibit 5**                                                     

  **Unit Operating and Maintenance                                  
  Costs per Respondent Information                                  
  Collection Activity**                                             

  **Collection Activity**          **Unit O&M                       **Total
                                   Costs**                          Unit O&M
                                                                    Cost per
                                                                    Report**

                                   **Photocopying   **Mailing       
                                   (\$/pg)**        (\$/report)**   

                                   **\$0.25**       **\$5**         

  Providing an Initial Telephone   \$0.00           \$0.00          \$0.00
  Notification                                                      

  Preparing an Initial Written     \$1.25           \$5.42          \$6.67
  Report (5pgs/1rpt)                                                

  Preparing a Follow-up Written    \$1.25           \$5.42          \$6.67
  Report (5pgs/1rpt)                                                

  Conducting an Annual Evaluation  \$0.00           \$0.00          \$0.00
  of a Release                                                      

  Reporting a Change in the        \$1.25           \$0.00          \$1.25
  Sources, Composition, or                                          
  Frequency of a Release                                            
  (5pgs/1rpt)                                                       

  Reporting Other Changes in       \$1.25           \$5.42          \$6.67
  Information (5pgs/1rpt)                                           

  Reporting an SSI                 \$0.00           \$0.00          \$0.00

  Other Activities -- Providing    \$2.50           \$5.42          \$7.92
  Additional Information                                            
  (10pgs/1rpt)                                                      

  Other Activities -- Facilitating \$0.00           \$0.00          \$0.00
  a Site Inspection                                                 

  Record keeping (5pgs)            \$1.25           \$0.00          \$1.25
  -------------------------------- ---------------- --------------- ----------

In Exhibit 6, O&M costs for a typical facility are presented.

  --------------------------- ---------------- ------------ ------------- ------------- -------------
  **Exhibit 6**                                                                         

  **Operating and Maintenance                                                           
  Costs for a Typical                                                                   
  Facility**\*                                                                          

  **Collection Activity**     **Unit O&M                    **Total Unit                
                              Costs**                       Cost**                      

                              **Photocopying   **Mailing    **First       **Second      **Third
                              (\$/pg)**        (\$/rpt)**   Year**        Year**        Year**

                              **\$0.25**       **\$5**                                  

  Providing an Initial        \$0.00           \$0.00       NA            NA            NA
  Telephone Notification                                                                

  Preparing an Initial        \$1.25           \$5.42       \$53.36       NA            NA
  Written Report - 8 rpts @                                                             
  (5pgs/1rpt)                                                                           

  Preparing a Follow-up       \$1.25           \$5.42       NA            \$53.36       NA
  Written Report - 8 rpts @                                                             
  (5pgs/1rpt)                                                                           

  Reporting Other Changes in  \$1.25           \$5.42       NA            \$6.67        \$6.67
  Information - 1 rpt @                                                                 
  (5pgs/1rpt)                                                                           

  Record keeping - 8 rpts @   \$1.25           \$0.00       \$10.00       \$10.00       \$10.00
  (5pgs/1 rpt)                                                                          

  **Total O&M Costs for a     ** **            ** **        **\$63.36**   **\$70.03**   **\$16.67**
  Typical Facility**                                                                    

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

NA = Not Applicable

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

  ------------------------------ ------------- ------------ --------------
  **Exhibit 7**                                             

  **Unit Labor and Operating and                            
  Maintenance Costs per**                                   

  **Respondent Information                                  
  Collection Activity**                                     

  **Collection Activity**        **Unit Labor  **Unit O&M   **Total Unit
                                 Cost**        Cost**       Costs**

  Providing an Initial Telephone \$95.61       \$0.00       \$95.61
  Notification                                              

  Preparing an Initial Written   \$263.21      \$6.67       \$269.88
  Report                                                    

  Preparing a Follow-up Written  \$195.41      \$6.67       \$202.08
  Report                                                    

  Conducting an Annual           \$195.41      \$0.00       \$195.41
  Evaluation of a Release                                   

  Reporting a Change in the      \$313.62      \$1.25       \$314.87
  Sources, Composition, or                                  
  Frequency of a Release                                    

  Reporting Other Changes in     \$83.80       \$6.67       \$90.47
  Information                                               

  Reporting an SSI in a Release  \$73.01       \$0.00       \$73.01

  Other Activities -- Providing  \$201.64      \$7.92       \$209.56
  Additional Information                                    

  Other Activities --            \$292.04      \$0.00       \$292.04
  Facilitating a Site Inspection                            

  Record keeping                 \$90.40       \$1.25       \$91.65
  ------------------------------ ------------- ------------ --------------

In Exhibit 8[^4], annual labor and O&M costs for a typical facility are
presented.

[]{.mark}

  --------------------------- ---------------- ---------------- ---------------- ------------- ------------- ------------- ---------------- ---------------- ----------------
  **Exhibit 8**                                                                                                                                              

  **Labor and Operating and                                                                                                                                  
  Maintenance Costs for a                                                                                                                                    
  Typical Facility\***                                                                                                                                       

  **Collection Activity**     **Total Labor                                      **Total O&M                               **Total Costs**                   
                              Costs**                                            Costs**                                                                     

                              **First Year**   **Second Year**  **Third Year**   **First       **Second      **Third       **First Year**   **Second Year**  **Third Year**
                                                                                 Year**        Year**        Year**                                          

  Providing an Initial        \$764.88         NA               NA               NA            NA            NA            \$764.88         NA               NA
  Telephone Notification                                                                                                                                     

  Preparing an Initial        \$2,105.68       NA               NA               \$53.36       NA            NA            \$2,159.04       NA               NA
  Written Report                                                                                                                                             

  Preparing a Follow-up       NA               \$1,563.28       NA               NA            \$53.36       NA            NA               \$1,616.64       NA
  Written Report                                                                                                                                             

  Conducting Annual           NA               NA               \$1,563.28       NA            NA            NA            NA               NA               \$1,563.28
  Evaluations                                                                                                                                                

  Reporting Other Changes in  NA               \$83.80          \$83.80          NA            \$6.67        \$6.67        NA               \$90.47          \$90.47
  Information                                                                                                                                                

  Record keeping              \$723.20         \$723.20         \$723.20         \$10.00       \$10.00       \$10.00       \$733.20         \$733.20         \$733.20

  **Total Costs for a Typical **\$3,593.76**   **\$2,370.28**   **\$2,370.28**   **\$63.36**   **\$70.03**   **\$16.67**   **\$3,657.12**   **\$2,440.31**   **\$2,386.95**
  Facility**                                                                                                                                                 

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

[]{.mark}

NA = Not Applicable

## Estimating Agency Burden and Cost

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

Exhibit 9 presents the estimated burden-hours and unit cost associated
with the Federal government's processing and evaluation of the various
continuous release reports, as well as the burden and cost associated
with any other government initiated activities that may involve the
collection of information. The unit cost estimates presented in Exhibit
9 are derived by multiplying the applicable burden estimates by the
average hourly wage rate for government employees. Based on the 2007 GS
pay schedule, EPA estimates an average hourly labor cost of \$43.17 for
the average Federal government employee.[^5] A full description of the
basis for each government burden estimate is provided in the remainder
of this section.

**Process Initial Telephone Notification** -- EPA estimates that the NRC
requires *30 minutes (0.5 hours)* to process the information provided in
the initial telephone call. The first year unit cost associated with
*processing the initial telephone call is \$21.58*.

**Process Initial Written Report** -- Government authorities review
initial written and follow-up reports to become familiar with the nature
and extent of the release, to determine if the release qualifies for
reduced reporting under CERCLA section 103(f)(2), and to assess the
hazards to public health and welfare and the environment. EPA estimates
that the preliminary evaluation of the release requires on average, *one
and one half hour* of government time. The costs of processing and
evaluating the initial written report are incurred in the first year of
reporting. Therefore, the *unit cost for processing and evaluating the
initial written report is \$64.75*.

**Process Follow-up Written Report** \-- Within one year of submitting
the initial written report, facilities must submit a written follow-up
report to update and confirm previously submitted information. The
follow-up report provides EPA with a more accurate baseline against
which to evaluate both the threat posed by the release and the impact
that SSIs in the release may have on public health and welfare and the
environment. The activities necessary to re­evaluate the continuous
release with the newly submitted follow-up report are assumed to be
identical to those required to process and evaluate the initial written
report, *one and a half hour*. The costs associated with the follow-up
written report, however, are incurred in the second year of reporting.
Therefore, the *unit cost for processing and evaluating the follow-up
written report is \$64.75*.

**Process a Change in the Sources, Composition, or Frequency of a
Release Report** -- After initial notification reports have been
submitted for a release and reporting under section 103(f)(2) has
commenced, EPA must be notified of any changes in release information
previously submitted. Any change in the sources, composition, or
frequency of a hazardous substance release constitutes a new release.
Thus, any facility experiencing a change in the sources, composition, or
frequency of a continuous release must complete the initial notification
process for the new release. Government activities associated with new
release reports consist of the processing and evaluation of the initial
telephone and initial written reports, *2 hours*. The applicable unit
cost is *\$86.34 per new continuous release report*.

**Process Other Changes in Information** -- For changes in a release
other than a change in the sources, composition, or frequency, the
person in charge must notify the EPA Region by submitting a letter
presenting the updated information and explaining the reasons for the
change. EPA estimates that processing a letter of changed information
requires approximately *30 minutes (i.e., 0.50 hours)* of government
time. This estimate consists of the time necessary evaluate the release
in light of the changed information. The shorter evaluation time is
assumed because it is necessary to evaluate only the incremental change
in the risk using previous assessments of the release (assumed to be on
file) as a baseline. The applicable unit cost is *\$21.58 per changes*
in a release report.

**Process an SSI (Statistically Significant Increase) Report** -- SSIs
are episodic releases and must be reported immediately to the NRC.
Release quantities in excess of the normal range have not been
previously reported and evaluated and, thus, warrant immediate
reporting. Upon receiving notification of an SSI, the NRC will record
the SSI information in the NRC data base (15 minutes) and notify the
appropriate EPA Region of the SSI report (15 minutes). Upon notification
from the NRC (15 minutes), EPA will evaluate the potential hazard posed
by the release in light of the SSI (30 minutes). Thus, the Federal
government is estimated to require *one hour and fifteen minutes (1.25
hours)* of government time to process and evaluate each SSI reported
under the CRRR. The applicable cost is *\$53.96 per SSI Report*.

**Other Activities** -- For some percentage of continuous releases, the
information provided in the initial and/or follow-up reports will be
incomplete, incorrect, or worrisome, prompting EPA to request
*additional information* concerning the release and its associated
hazard. For example, additional information may be necessary to confirm
the continuity and stability of the release or to better assess the risk
posed by the release. EPA estimates that the process of requesting and
reviewing additional information concerning a continuous release
requires *2.0 hours* of government time. The applicable unit cost is
*\$86.34 per request and review* of additional information.

In extreme cases, the preliminary risk assessment of a release will
suggest the need for a *site inspection*, allowing EPA to directly
assess and evaluate the circumstances of a release and the population
and environment potentially affected by the release. In addition, site
inspections are conducted periodically as a compliance and enforcement
measure. EPA estimates that site inspections will require *eight hours*
of government time, including one hour allocated for the EPA Region to
communicate its concerns and findings to the appropriate SERC and LEPC,
and will *cost \$345.34*.

  ------------------------------------ ---------------- -----------------
  **Exhibit 9**                                         

  **Unit Burden Hours and Costs                         
  Incurred by the**                                     

  **Government per Information                          
  Collection Activity**                                 

  **Collection Activity**              **Burden Hours   **Unit Cost**
                                       (\$/hr)**        

                                       **\$43.17**      

  Process Initial Telephone            0.50             \$21.58
  Notification                                          

  Process Initial Written Report       1.50             \$64.75

  Process Follow-up Written Report     1.50             \$64.75

  Process a Change in the Sources,     2.00             \$86.34
  Composition, or Frequency of a                        
  Release Report                                        

  Process Other Changes in Information 0.50             \$21.58

  Process an SSI Report                1.25             \$53.96

  Other Activities -- Obtaining        2.00             \$86.34
  Additional Information                                

  Other Activities -- Conducting a     8.00             \$345.34
  Site Inspection                                       
  ------------------------------------ ---------------- -----------------

## Estimating the Respondent Universe and Total Burden and Cost

The estimates presented in this ICR regarding the number of facilities
and hazardous substance releases affected by the CRRR were computed
using the number of CR-ERNS notifications made by the NRC to each
respective region over the years 2004, 2005, and 2006 as reported by the
NRC. The number of reports to be filed in the next three years is
computed from the total number of reports already filed and reflects the
number of annual reports in recent years. EPA has estimated that each
affected facility has 8 continuous releases above the releases' RQs.
Exhibit 10 summarizes the estimated number of facilities and hazardous
substance releases already affected by the CRRR. The change report
adjustment reflects 10% of the total number of facilities and reports
for all regions.

  ------------------- -------------------------- ------------------------
  **Exhibit 10**                                 

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

                      **Total Estimated Number   **Estimated Number of
                      of Facilities with         Reportable Continuous
                      Continuous Releases**      Releases (3 years)**

  EPA Region 1        148                        1,184

  EPA Region 2        158                        1,264

  EPA Region 3        271                        2,168

  EPA Region 4        833                        6,664

  EPA Region 5        619                        4,952

  EPA Region 6        766                        6,128

  EPA Region 7        544                        4,352

  EPA Region 8        233                        1,864

  EPA Region 9        181                        1,448

  EPA Region 10       187                        1,496

  Minus Change        -394                       -3,152
  Reports (10%)                                  

  **Total in          **3,546**                  **28,368**
  CR-ERNS**                                      
  ------------------- -------------------------- ------------------------

Exhibit 11 presents the estimate for the number of facilities and
hazardous substance releases that will be affected by the CRRR in the
next three years. The estimate is based on an expected 7.5% average
annual percent increase in facilities (see 6(f)) adjusted from the
number of continuous release notifications reported by the NRC for 2006.

  ------------------------- ---------------------- -----------------------
  **Exhibit 11**                                   

  **Number of Facilities                           
  and Hazardous Substance                          
  Releases**                                       

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

                            **Total Estimated      **Estimated Number of
                            Number of Facilities   Reportable Continuous
                            with Continuous        Releases**
                            Releases**             

  Estimated New Releases in 19                     155
  the First Year                                   

  Estimated New Releases in 21                     166
  the Second Year                                  

  Estimated New Releases in 22                     179
  the Third Year                                   

  Total Over Next Three     63                     500
  Years                                            

  **Total in CR-ERNS After  **3,609**              **28,868**
  Three Years**                                    
  ------------------------- ---------------------- -----------------------

## Bottom Line Burden Hours and Cost Tables

### Respondent Tally

The total estimated and annual burden hours and costs incurred by
industry affected by the CRRR are presented in Exhibit 12. The total and
annual hours and costs incurred by industry are calculated over a three
year period.

  ---------------- ------------ -------- -------- ---------- ---------- --------- ---------- --------- --------- -------------- -------------- -------------- ----------- ----------- -----------
  **Exhibit 12**                                                                                                                                                                      

  **Annual Burden                                                                                                                                                                     
  Hours and Costs                                                                                                                                                                     
  Incurred by                                                                                                                                                                         
  Industry**                                                                                                                                                                          

  **Collection     **\# of                        **Unit     **Unit     **Unit    **Burden                       **Labor Cost\                                **O&M                   
  Activity**       Reported                       Burden     Labor      O&M       Hours\                         Over Three                                   Costs\                  
                   Releases\                      Hours**    Costs**    Costs**   Over Three                     Years**                                      Over Three              
                   that Require                                                   Years**                                                                     Years**                 
                   the                                                                                                                                                                
                   Collection                                                                                                                                                         
                   Activity\                                                                                                                                                          
                   Over Three                                                                                                                                                         
                   Years**                                                                                                                                                            

                   **1st\       **2nd\   **3rd\                                   **1st\     **2nd\    **3rd\    **1st\         **2nd\         **3rd\         **1st\      **2nd\      **3rd\
                   Year**       Year**   Year**                                   Year**     Year**    Year**    Year**         Year**         Year**         Year**      Year**      Year**

  Providing        155          166      179      **3.00**   \$95.61    \$0.00    464        499       537       \$14,800       \$15,910       \$17,104       \$0         \$0         \$0
  Initial                                                                                                                                                                             
  Telephone                                                                                                                                                                           
  Notification                                                                                                                                                                        

  Preparing        155          166      179      **8.00**   \$263.21   \$6.67    1,238      1,331     1,431     \$40,745       \$43,801       \$47,086       \$1,033     \$1,110     \$1,193
  Initial Written                                                                                                                                                                     
  Report                                                                                                                                                                              

  Preparing        574          155      166      **5.00**   \$195.41   \$6.67    2,870      774       832       \$112,165      \$30,249       \$32,518       \$3,829     \$1,033     \$1,110
  Follow-up                                                                                                                                                                           
  Written Report                                                                                                                                                                      

  Conducting       24,311       24,885   25,040   **5.00**   \$195.41   \$0.00    121,555    124,425   125,199   \$4,750,613    \$4,862,778    \$4,893,027    \$0         \$0         \$0
  Annual                                                                                                                                                                              
  Evaluations                                                                                                                                                                         

  Reporting a      1,426        1,434    1,443    **9.00**   \$313.62   \$1.25    12,835     12,910    12,991    \$447,266      \$449,876      \$452,681      \$1,783     \$1,793     \$1,804
  Change in the                                                                                                                                                                       
  Sources,                                                                                                                                                                            
  Composition, or                                                                                                                                                                     
  Frequency of a                                                                                                                                                                      
  Release                                                                                                                                                                             

  Reporting        2,852        2,869    2,887    **2.50**   \$83.80    \$6.67    7,131      7,172     7,217     \$239,021      \$240,416      \$241,915      \$19,025    \$19,136    \$19,255
  Changes in Other                                                                                                                                                                    
  Information                                                                                                                                                                         

  Reporting an SSI 1,426        1,434    1,443    **2.00**   \$73.01    \$0.00    2,852      2,869     2,887     \$104,122      \$104,730      \$105,383      \$0         \$0         \$0

  Other            8,557        8,607    8,660    **4.00**   \$201.64   \$7.92    34,227     34,427    34,642    \$1,725,401    \$1,735,468    \$1,746,289    \$67,770    \$68,166    \$68,591
  Activities----                                                                                                                                                                      
  Additional                                                                                                                                                                          
  Information                                                                                                                                                                         

  Other            285          287      289      **8.00**   \$292.04   \$0.00    2,282      2,295     2,309     \$83,298       \$83,784       \$84,306       \$0         \$0         \$0
  Activities----                                                                                                                                                                      
  Site Inspection                                                                                                                                                                     

  Record keeping   28,523       28,689   28,868   **4.00**   \$90.40    \$1.25    114,091    114,757   115,472   \$2,578,461    \$2,593,505    \$2,609,676    \$35,654    \$35,862    \$36,085

  **Total**        ** **                                                          299,546    301,460   303,517   \$10,095,893   \$10,160,516   \$10,229,985   \$129,092   \$127,098   \$128,038
  ---------------- ------------ -------- -------- ---------- ---------- --------- ---------- --------- --------- -------------- -------------- -------------- ----------- ----------- -----------

###  The Agency Tally

Exhibit 13 presents the total and annual estimated burden hours and
costs incurred by government authorities as a result of the CRRR over a
three year period.

  ---------------- ------------ -------- -------- --------- ---------- ---------- -------- -------- ------------- ------------- -------------
  **Exhibit 13**                                                                                                                

  **Annual Burden                                                                                                               
  Hours and Costs                                                                                                               
  Incurred by                                                                                                                   
  Government**                                                                                                                  

  **Collection     **\# of                        **Unit    **Unit     **Burden                     **Cost\                     
  Activity**       Reported                       Burden    Cost**     Hours\                       Over Three                  
                   Releases                       Hours**              Over Three                   Years**                     
                   Estimated to                                        Years**                                                  
                   Require the                                                                                                  
                   Collection                                                                                                   
                   Activity\                                                                                                    
                   Over Three                                                                                                   
                   Years**                                                                                                      

                   **1st\       **2nd\   **3rd\                        **1st\     **2nd\   **3rd\   **1st\        **2nd\        **3rd\
                   Year**       Year**   Year**                        Year**     Year**   Year**   Year**        Year**        Year**

  Processing       155          166      179      0.50      \$21.58    77         83       89       \$3,341       \$3,592       \$3,861
  Initial                                                                                                                       
  Telephone                                                                                                                     
  Notification                                                                                                                  

  Processing       155          166      179      1.50      \$64.75    232        250      268      \$10,024      \$10,775      \$11,584
  Initial Written                                                                                                               
  Report                                                                                                                        

  Processing       574          155      166      1.50      \$64.75    861        232      250      \$37,168      \$10,024      \$10,775
  Follow-up                                                                                                                     
  Written Report                                                                                                                

  Processing a     1,426        1,434    1,443    2.00      \$86.34    2,852      2,869    2,887    \$123,127     \$123,846     \$124,618
  Change in the                                                                                                                 
  Sources,                                                                                                                      
  Composition, or                                                                                                               
  Frequency of a                                                                                                                
  Release Report                                                                                                                

  Processing Other 2,852        2,869    2,887    0.50      \$21.58    1,426      1,434    1,443    \$61,564      \$61,923      \$62,309
  Change in                                                                                                                     
  Information                                                                                                                   

  Processing an    1,426        1,434    1,443    1.25      \$53.96    1,783      1,793    1,804    \$76,955      \$77,403      \$77,886
  SSI Report                                                                                                                    

  Other            8,557        8,607    8,660    2.00      \$86.34    17,114     17,214   17,321   \$738,763     \$743,073     \$747,707
  Activities----                                                                                                                
  Obtaining                                                                                                                     
  Additional                                                                                                                    
  Information                                                                                                                   

  Other            285          287      289      8.00      \$345.34   2,282      2,295    2,309    \$98,502      \$99,076      \$99,694
  Activities----                                                                                                                
  Site Inspection                                                                                                               

  **Total**                                                            26,627     26,170   26,372   \$1,149,443   \$1,129,713   \$1,138,434
  ---------------- ------------ -------- -------- --------- ---------- ---------- -------- -------- ------------- ------------- -------------

### Variations in the Annual Bottom Line 

Exhibit 14 summarizes the estimated burden hours and costs incurred by
industry. The bottom line burden to industry is approximately 299,546
hours for the first year and 301,460, and 303,517 hours for the second
and third years, respectively. The bottom line industry labor costs are
approximately \$10,095,893, \$10,160,516, and \$10,229,985 for the
first, second, and third years, respectively. The bottom line industry
O&M costs are approximately \$129,092, \$127,098, and \$128, 038 for the
first, second, and third years, respectively. The average burden hour
for industry over a three year period is 301,508, an average labor cost
of \$10,162,131 and O&M cost of \$128,076.

  ----------------------- ---------- ------------ ----------- -------------
  **Exhibit 14**                                              

  **Summary of Burden                                         
  Hours and Costs                                             
  Incurred by Industry**                                      

                          **First    **Second     **Third     **Average
                          Year**     Year**       Year**      (over a three
                                                              year
                                                              period)**

  **Total Number of       3,565      3,586        3,609       3,587
  Respondents**                                               

  **Reporting Burden      185,455    186,703      188,044     186,734
  Hours**                                                     

  **Record Keeping Burden 114,091    114,757      115,472     114,773
  Hours**                                                     

  **Total Burden Hours**  299,546    301,460      303,517     301,508

  **Total Labor Costs     \$10,096   \$10,161     \$10,230    \$10,162
  (thousand \$)**                                             

  **O&M Costs Reporting   \$93       \$91         \$92        \$92
  (thousand \$)**                                             

  **O&M Costs Record      \$36       \$36         \$36        \$36
  Keeping (thousand \$)**                                     

  **Total O&M Costs       \$129      \$127        \$128       \$128
  (thousand \$)**                                             
  ----------------------- ---------- ------------ ----------- -------------

Exhibit 15 summarizes the estimated burden hours and costs incurred by
government. The bottom line burden to the government is approximately
26,627 hours for the first year, 26,170 for the second, and 26,372 for
the third year. The bottom line cost to the government is approximately
\$1,149,443, \$1,129,713, and \$1,138,434, respectively. The average
burden hour for the government over a three year period is 26,390 hours,
at an average annual cost of \$1,139,197.

  ------------------- ------------ ------------ ------------ -------------
  **Exhibit 15**                                             

  **Summary of Burden                                        
  Hours and Costs                                            
  Incurred by                                                
  Government**                                               

                      **First      **Second     **Third      **Annual
                      Year**       Year**       Year**       Average**

  **Total Burden      26,627       26,170       26,372       26,390
  Hours**                                                    

  **Total Cost        \$1,149      \$1,130      \$1,138      \$1,139
  (thousand \$)**                                            
  ------------------- ------------ ------------ ------------ -------------

## Reasons for Change in Burden

This ICR estimates an **increase** in the burden incurred by industry,
as a result of compliance with the CRRR, from 284,154 to 301,508
estimated average burden hours. This **increase** in burden results
primarily from the use of data on the actual number of continuous
release reports from several regions and applying a growth rate
consistent with prior years reporting. The average annual percent
increase in facilities in the previous ICR was approximately 7.5%. The
same percent increase was assumed for this ICR. The unit burden hours
per respondent information collection activity (Exhibit 1) remains the
same as the previous ICR.

## Burden Statement

The reporting and record keeping burden for this collection of
information is estimated to average approximately 84[^6] hours per
affected facility (301,508 total burden hours/3,587 affected
facilities), or 10.5[^7] hours per response (where we estimate 8
responses/facility - see note to Exhibit 6), including determining if
the hazardous substance release qualifies for reporting under the CRRR,
gathering and maintaining the required information, and completing and
reviewing the written reports. Burden means the total time, effort, or
financial resources expended by persons to generate, maintain, retain,
or disclose or provide information to or for a Federal agency. This
includes the time needed to review instructions; develop, acquire,
install, and utilize technology and systems for the purposes of
collecting, validating, and verifying information, processing and
maintaining information, and disclosing and providing information;
adjust the existing ways to comply with any previously applicable
instructions and requirements; train personnel to be able to respond to
a collection of information; search data sources; complete and review
the collection of information; and transmit or otherwise disclose the
information. An agency may not conduct or sponsor, and a person is not
required to respond to, a collection of information unless it displays a
currently valid OMB control number. The OMB control numbers for EPA's
regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.

To comment on the Agency's need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID No.
EPA-HQ-SFUND-2007-0278, which 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/DC 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
[www.regulations.gov](http://www.regulations.gov/). Use
[www.regulations.gov](http://www.regulations.gov/) to obtain a copy of
the draft collection of information, submit or view public comments,
access the index listing of the contents of the docket, and to access
those documents in the public docket that are available electronically.
Once in the system, select "search," then key in the docket ID number
identified above. Also, you can send comments to the Office of
Information and Regulatory Affairs, Office of Management and Budget, 725
17th Street, NW, Washington, DC 20503, Attention: Desk Office for EPA.
Please include the EPA Docket ID No. EPA-HQ-SFUND-2007-0278 and OMB
control number 2050-0086 in any correspondence.

[]{#__RefHeading___Toc188347120 .anchor}APPENDIX A

Phone-Log Summaries

The following calls were made between November 20, 2007 and January 10,
2008. The companies were selected from the universe of facilities for
which a continuous release notification was made. Persons responsible
for making notifications were queried about the internal process and
procedures taken at the facility between the time a release is observed
and a call is made to the NRC and through the 30 day follow-up report,
one year anniversary report and any additional reports required that
resulted from changes to the continuous release. Although the some of
the representatives indicated longer periods of time to complete their
reporting obligations, EPA did not receive any comments from the public
that our burden estimates are substantially out of line and needing
adjustment. Therefore, EPA concludes that these phone interviews were
outliers and will not change the burden estimates for this renewal.

International Paper

Private Enterprise

Ticonderoga, NY

Incident Report #848399

On September 10, 2007 a representative from International Paper (IP)
called the NRC to report a continuous release of acrolein. The IP
representative indicated that EPA\'s CERCLA website is excellent and she
simply \"drills\" down to find the report that she needs. She uses
optional EPA forms to report to the State of New York, which has
different trigger points than EPA. She indicated that CERCLA reporting
is a little difficult because CERCLA has different reporting schedules.

The IP representative indicated that IP has an internal compliance
calendar and reporting system, so the resources are already in place for
reporting purposes, She indicated for the September 10th report that
they spent an additional (incremental) 2-5 hours of technical time for
the report. For the compliance calendar and reporting system,
management, technical and clerical time is required.

We would emphasize that the discussion focused on one chemical at one IP
facility.

Doswell Ltd. Partnership

Power Plant

Ashland, VA

Incident Report #853424

On November 2, 2007 a representative from Doswell Ltd. Partnership
reported an initial continuous release of nitrogen oxides to the NRC. In
a telephone interview with two representatives from Doswell, the
representatives commented that the reporting was much simpler than in
2001 when they reported on ammonia releases. The process is much more
efficient and user friendly.

For the initial call, they estimated the burden at 4 hours; the ICR
estimates 3 hours. They estimated 4 - 5 hours for the initial written
report; the ICR estimates 8 hours. Their concern is that they are
spending one hour per week to manage data, total 52 hours annually in
addition to the initial contact and initial report. They indicated that
they would not otherwise collect and manage these data except for CERCLA
/ CRRR.

Although the contact process with NRC is more efficient, the total
burden is much greater when considering weekly data compilation and
management.

Bowen Steam Electric Generating Plant

Facility of the Southern Company

Private Enterprise

Cartersville, GA

Incident Report #848088

On September 7, 2007 a representative from Bowen Steam Electric
Generating Plant called the NRC and reported a statistically significant
increase and a change in the normal range (when ammonia flu gas
conditioning was added) that is releasing into the air due to normal
operating procedures.

The representative estimated that three different people were involved
in the report, one at the Southern Company. She estimated that the total
effort was at least 5 hours. The representative indicated that she
personally spent 2 hours on the report, 2 hours for the individual at HQ
Southern Company, another individual at the facility spent at least 1
hour. The ICR estimates 2 hours for this report.

National Co-Op Refinery Association

Private Enterprise

McPherson, KS

Incident Report #854014

On November 8, 2007 a representative from National Co-Op Refinery
Association called the NRC to report, an update to their continuous
release as there is a change in source / composition. The estimated
burden is 9 hours for reporting a change in sources, composition, or
frequency of the release. The representative indicated that the actual
burden level is a multiple of this estimate. For this particular report,
the representative estimates that this report required 4 work days at 8
hours per day or about 32 hours of management / technical plus an hour
of clerical time.

[^1]: That data base is available at:
    <http://www.nrc.uscg.mil/incident97-02.html>.

[^2]: Bureau of Labor Statistics' news release dated, March 27, 2007,
    entitled, "Employer Costs for Employee Compensation - December 2006"
    listed hourly compensation (wages and salaries plus fringe benefits)
    rates for civilian managerial, technical, and clerical workers.
    Therefore the wage rates used in this ICR (1049.11) include
    salaries, fringe benefits, overhead costs and general and
    administrative costs as of December 2006.

[^3]: This assumption was revised for this renewal. The prior assumption
    was \$1.70 postage and \$0.30 per envelop. The new costs assume
    increases (\$.87) in postage and that, although not required, most
    respondents will mail the reports using certified (\$2.40) and
    return receipt (\$1.85) postal services.

[^4]: Exhibit 8 does not include capital costs because there is no
    capital costs associated with implementing the regulations of the
    CRRR.

[^5]: This hourly wage estimate was calculated by summing the basic
    hourly wage rate for a GS-12 step 1 government employee in 2007
    (\$26.98) and the hourly monetary value of the representative
    employee's fringe benefits (assumed to be the basic hourly wage rate
    multiplied by 60 percent).

[^6]: 84 hrs/facility is further broken out to 52 hours for reporting
    (186,734 reporting burden hours/3,587 affected facilities) and 32
    hours for record keeping (114,773 record keeping hours/3,587
    affected facilities)

[^7]: 6.5 hours for reporting and 4 for record keeping.