1 

## Supporting Statement for **EPA ICR [2470.01]** 
**Part A.**
**1. Identification of the Information Collection**  1(a) Title : Technical Assistance Needs Assessments (TANAs) at Superfund Remedial or Removal Sites (NEW) , EPA ICR [2470.01] , OMB Control Number 2050

-NEW

. 1(b) Abstract : ICR [2470.01] addresses Federally

- conducted c ommunity involvement for remedial activities at sites on the National Priority List (Superfund sites) or for removal actions lasting 120 days or longer. This ICR covers specifically the usage of TANAs with members of the impacted community in order to determine how the community is receiving technical information about a site; whether the community needs additional assistance in order to understand and respond to site

-related technical information; and whether there are organizations in the community that are interested or involved in site related issues and capable of acting as an appropriate conduit for technical assistance services to the affected community. The TANA will help ensure the community’s needs for technical assistance are defined as early in the remedial/ removal process as possible and enable meaningful community involvement in the Superfund decision

-making process. Additionally, the TANA process produces a blueprint for designing a coordinated effort to meet the community’s needs for additional technical assistance while minimizing the overlap of services provided.
**2. Need for and Use of the Information Collection**  2(a) Need/ Authority for Collection:
TANAs are not required by statute or regulation, however, they are strongly recommended when ever an impacted community may require additional technical assistance. EPA believes involvement of the me mbers of the community surrounding a Superfund site is critical to ensuring effective site cleanups. What information will be collected? The TANA will identify unaddressed technical assistance needs relating to the remedial/ removal activities occurring at a given site, including non

- advocacy information assistance and expertise; community education needs; organizational capacity

-building a ssistance; and mediation or conflict resolution services. From whom will the information be collected? When the TANA is being conducted concurrently with the Community Involvement Plan ( CIP ) community interviews, the Community Involvement Coordinator ( CIC ) should identify interviewees by using the Community Interviews tool and conduct the TANA interviews with a smaller number of individuals who can help define the community’s specific needs. TANA interviewees may include state and local government offic ials, a Potentially Responsible Party (PRP) representative (if applicable), and community members who have expressed a specific interest in, or knowledge of, the community’s technical assistance needs (including but not limited to those participating in th e site’s Technical Assistance Grant (TAG), Community Advisory Group (CAG), or Technical Assistance Services for Communities (TASC)). The CIC should make every effort to ensure all affected stakeholder groups are represented in the TANA interview s and give a voice to those who have not had the opportunity to fully engage in the Superfund cleanup process.2

If the TANA is being conducted after the CIP community interviews have been completed, the CIC may select interviewees from those participating in the ori ginal community interviews and include others who may be able to define the community’s potential technical assistance needs. Given the specific nature of the TANA, eight to ten persons will be interviewed. If the TANA is conducted concurrently with the CIP community interviews, this number may b e greater. The interviews will be targeted towards those individuals requesting additional support on technical issues (e.g., inquiring about site documents to review.) How will the information be collected? The i nterviews associated with the TANA may be one of the first opportunities the EPA has to engage with community members one

- on - one. Remedial Project Managers (RPMs) and On

- Scene Coordinators (OSCs) are required to accompany the CIC to learn firsthand about t he community member’s concerns. It is strongly suggested that EPA employees conduct the TANA interviews. Whenever a contractor conducts the TANA interviews, E PA personnel will be present. The interviewer will ask each stakeholder a series of questions , wit

h the responses being documented. The stakeholder interview process should incorporate additional questions or request supplemental information as needed. The TANA interviews may be conducted either in

-person or over the phone.
CI Cs can use contractor support to prepare for and conduct the TANA. The contractor support will be utilized judiciously and may be useful for documenting the interviews and summarizing notes from individual interviews. The CIC usually is responsible for summarizing the interviews into a final TANA summary (succinct, 4

- 6 page document). How frequently will the information be collected? The TANA can be conducted concurrently with the initial Community Interviews administered for development of a CIP or at a later date if the technical assistance needs of the community cannot be adequately defined by community members at that time. Conducting the TANA concurrently with the CIP community interviews can help minimize EPA staff time, defray costs and reduce the administrative/ time burden placed on community members. The CIC can conduct a TANA at any time during the Superfund remedial process if it becomes evident that the technical assistance needs of the community are not being effectively addressed through existing technical assistance mechanisms. TANAs will only be conducted at sites where communities have unaddressed technical assistance needs and most frequently once during the remedial/ removal process. 2(b) Practical Utility/Users of the Data : What will the information be used for? A TANA will aid the CIC an d the RPM or OSC in determining the technical assistance needs of a community affected by a given site. This assessment will provide the Agency with a detailed record of potentially unmet technical assistance needs and provide a working document from which the most appropriate forms of informal and formal technical assistance can be identified and provided to the community. One of the additional objectives for conducting a TANA is to avoid unnecessary duplication of technical assistance provided to a community through EPA funding vehicles and via university and nonprofit partners.
Wi ll the information be shared with any other organizations inside or outside EPA? The TANA will enhance opportunities for EPA to cooperate with other organizations (e.g., National Institute of Environmental Health Sciences (NIEHS) Superfund Research Program grantees, nonprofits providing capacity building assistance) with the shared goal of addressing a community’s technical assistance needs. If appropriate, the TANA summary document may be shared with universities and3

nonprofits currently enrolled in the Partners in Technical Assistance Program (PTAP). Upon receipt of the TANA summary document, any PTAP members interested in providing non

- advocacy technical assistance will contact the CIC responsible for the TANA in order to determine if collaborative technical assistance services are possible.

**3. Non duplication, consultations, and other ICR criteria**  3 (a) Non duplication : There is no duplication as there are no other sources available to collect this information. In addition, the Community Interviews conducted for a CIP have been revised to incorporate questions in regards to whether a formal TANA should be conducted. Only those community members able to define the community’s potential technical assistance needs will be interviewed. The generation of this technical assistance needs assessment was completed concurrently with a revision of the Community Interviews tool to ensure question s asked of community members were not duplicative.
3 (b) Public Notice Required Prior to ICR submission to OMB: The Paperwork Reduction Act requires that ICRs be made available to the public for comment prior to submission to OMB. This is done through two notices to the Federal Register . The first Federal Register N otice , which describes the ICR and provides numbers for burden hours and costs and solicits public comment, was published on __________. A 60 day comment period was given; ____ comments were received. The second Federal Register Notice will be published at the same time the ICR is submitted to OMB. This notice states that the ICR has been submitted and provides an abstract and final burden numbers.
3 (c) Consultations : The TANA is a new tool not previously utilized by EPA community involvement staff and as such all burden and cost projections are estimates. These estimates are informed by specific consultation with subject matter experts in both EPA Headquarters and Regional off ices. Burden and cost estimates were additionally confirmed through review of needs assessments conducted by EPA contractors with communities impacted by Superfund sites. Agency experience in addressing technical assistance for communities has included annual meetings with community involvement staff and meetings with local community organizations.
3 (d) Effects of Less Frequent Collection : The TANA was written to specifically dovetail with interviews conducted to develop or revis e a CIP

. Definitive qu estions have been added to the Community Interviews tool guiding the CIC to only conduct a formalized TANA when an impacted community has unaddres sed technical assistance needs and those needs could not be effectively addressed through informal technical a ssistance provided directly by EPA staff (e.g., fact sheets, workshops, availability sessions, etc.) For the majority of sites, informal technical assistance will be sufficient to meet the needs of the community. Information collection through TANAs will b e conducted the minimal amount necessary to ensure the technical assistance needs of impacted communities are appropriately assessed and addressed.4

3 (e) General Guidelines : The final TANA and resulting summary documents will be included in the official site file in the information repository. The site records are to be maintained for the duration of remedial responses at sites and for as long as necessary for litigation purposes. Responsib ility for these files will continue beyond the three

-year ICR period as cleanups typically take more than three years.
3 (f) Confidentiality : The nature of the data being gathered as part of this information collection is not confidential. Lists of participants in community interviews and lists of attendees of public meetings are not confidential. Some data gathered during community interviews may not be releasable, however, due to privacy concerns.
3 (g) Sensitive Questions : The information gathering activities discussed in this ICR generally do not involve any sensitive questions.

**4. Respondents and Information requested**  4(a) Respondents/SIC Codes Respondents to this ICR are local/ state government officials and individual community members who may be impacted by a Superfund site or a removal action lasting 120 days or longer. These community me mbers voluntarily participate in community involvement activities throughout the remedial phase of the Superfund process. SIC Codes are OSHA’s Standard In dustrial Classification System used to identify different groups. Local/state governments are categorized as Division J: Public Administration , Major Group 95: Administration of Environmental Quality, subgroup 9511: Air and Water Resource and Solid Waste M anagement. The other respondents, community members, do not have a SIC Code as they do not constitute an industry.
4(b) Information requested This ICR voluntarily requests information from community members at sites where the impacted community may have unaddressed technical assistance needs including but not limited to: non

- advocacy information assistance and expertise; community education needs; organizational capacity

-building assistance; and mediation or conflict resolution services.
(i) Data items, including record

- keeping requirements Technical Assistance Needs Assessments
TANAs will be conducted by CI Cs when it is determined that a community impacted by a remedial or removal (activity lasting 120 days or longer) site has unaddressed technical assistance needs. TANAs are5

not required by statute or regulation and for most sites informal technical assistanc e (e.g., fact sheets, availability sessions, workshops, trainings, etc.) will be sufficient to meet the technical needs of a community and a formal TANA will not be necessary. The interviews associated with the TANA may be one of the first opportunities the EPA has to engage with community members one

- on - one. RPMs and OSCs are required to accompany the CIC to learn firsthand about the community member’s concerns. When the preliminary questions in the community interviews suggest the need to conduct a TANA , the CIC may conduct the TANA interviews with a smaller number of individuals who can help define the community’s specific needs. TANA interviewees may include state and local government officials, a PRP representative (if applicable), and community me mbe rs who have expressed a specific interest in, or knowledge of, the community’s technical assistance needs. The CIC will make every effort to ensure all affected stakeholder groups are represented in the TANA interviews and give a voice to those who have no t had the opportunity to fully engage in the Superfund cleanup process. If the TANA is being conducted after the CIP community interviews have been completed, eight to ten persons should be interviewed given the specific nature of the needs assessment. The interviewer will ask each stakeholder a series of questions, with the responses being documented. The stakeholder interview process will incorporate additional questions or request supplemental information as needed. The interviews will be summarized into a succinct (4

- 6 page) summary document detailing the unaddressed technical assistance needs of the community. The CIC, RPM/OSC, and appropriate members of the Site Team will review the content of the summary document and distribute the final document t o the community. The CIC will explore additional informal and formal (e.g. TAG grants, TASC contracts, or assistance provided by external universities and nonprofits) technical assistance options. The TANA summary document may be shared with external colle ges, universities and nonprofits curr ently enrolled in the PTAP , if appropriate. The final TANA summary documents will be available at the site’s information repository. EPA expects approximately twenty

- five TANAs to be completed at either remedial or removal sites in a given year. This estimate is based upon an informal survey of CICs and community involvement managers in regards to the number of active sites where the impacted community has unaddressed technical assistance needs and may potentially benef it from additional informal or formal technical assistance.
(ii) Respondent Activities In participating in the remedial phase, community members may disclose information to EPA personnel during interviews. Community members may perform any or all of the following activities:

 Participate in interviews;

 Review the final TANA summary document;

 Meet with technical assistance providers (i.e., T AG coordinators, TASC work assignment managers, nonprofit staff, university technical assistance provider, etc.)
**5. In**  **formation collected: Agency activities, collection methodology, information management** 5(a) Agency activities At any remedial or removal site where the impacted community may have unaddres sed technical assistance needs, the Agency may conduct the following activities: TANA interviews, TANA summary document generation, coordinating technical assistance between the community and assistance providers.6

5(b ) Collection methodology and management The information collection methodology depends on the type of activity being conducted. TANAs will not require an extensive number of hours as the number of sites where they would be conducted are limited to those where informal technical assistance provided by the EPA has been insufficient to meet the needs of the community. Additionally, the interviewees will be limited to eight to ten persons given the specific nature of the TANA. It is preferable for the interviews to be conducted in person; howe ver, phone interviews are advisable when travel funds or time are restrictive. The activities reflected in this ICR do not lend themselves to automation because of the decentralized nature of each remedial/ removal activity. These activities are site

- spe cific and, therefore, are not conducive to mass data collection efforts. The use of improved information technology is not prohibited in any way.
5(c) Small entity flexibility Information collection from small entities (individual community members, community organizations, etc.) is primarily done on a voluntary basis. Since these respondents are providing information voluntarily, the Federal government is not placing any undue burden on small entities and does provide plenty of flexibility.
5(d) Collection schedule TANAs can be conducted concurrently with the initial Community Interviews administered for the development of a CIP or at a later date if the technical assistance needs of the community cannot be adequately defined by community members at that time . A TANA can be conducted at any time during the Superfund cleanup process if it becomes evident that the technical assistance needs of the community are not being effectively addressed through existing technical assistance mechanisms. A TANA is most effectively utilized when conducted as early as possible in the community engagement process.

**6. Estimating the burden and cost of the Information Collection**  6(a) Estimati ng respondent burden Respondent burden estimates are calculated from an informal survey of CICs and EPA community involvement managers regarding the potential number of remedial/ removal sites where the impacted community has unaddressed technical assistance needs which cannot be effectively addressed through informal technical assistance provided by the Agency. Additionally, TANAs conducted by Skeo Solutions (current TASC contractor) were reviewed for estimating the time burden for community me mbers and A gency personnel. The annual hours per activity figure is multiplied by the number of sites expected to be engaging in the activity every year. This calculation gives the total annual hours for all sites by activity. The estimated number of respondents reported for this information collection is 25 0. This number is estimated based upon approximately twenty

- five remedial/ removal sites requiring a TANA in a given year with ten interviewees per site. The estimated number of responses is 250

.7

(i) Community Burden Hours All community burden hours are due to voluntary participation in the TANA interviews. The Paperwork Reduction Act (PRA) requires the inclusion of information gathering activities in which the community participates. These activities are those for which information is expressly collected from community me mbers. The PRA (5 CFR part 1320, “Controlling Paperwork Burdens on the Public, FRN 8/29/1995, Sect. 1320.3 (h) ( 8)) excludes the following activities from the definition of information for the pu rpose of Information Collection Requests: attendance at public informational meetings or briefings, response to comments on EPA documents, participation in community groups for which EPA is not a sponsor, reading fact sheets, and making use of EPA open o ffice hours. This ICR records estimated burden hours for community members to participate in TANA interviews. EPA estimates that 10 people will be interviewed for one hour each at 25 remedial or removal (action lasting 120 days or longer) sites each year in the process of conducting TANAs. The total annual estimated burden for TANA interviews is 25 0 hours.
6(b) Estimating respondent costs Respondent costs are divided into labor costs and other costs, which includes all operation and maintenance, non

- lab or, and capital costs. The methodology for calculating these costs for the three year ICR period is addressed in detail below.
(i) Estimating labor costs The hourly rate for community members who participate in Superfund remedial activities on a voluntary, and non

-paid, basis is $19.20. The value is based on the Bureau of Labor Statistics January 2010 data, which reports an average hourly wage of $18.80 for “production, non

- supervisory on private non farm payrolls, seasonally

- adjusted” employees. The recent trend in this category of BLS data is for the rate to increase approximately $0.40 per year. Therefore, $19.60 is the average rate over the three

-year pe riod of this ICR for all activities in which the community may participate. Labor costs for community activities represent hypothetical costs only.
(ii) Estimating capital, operations and maintenance, and other costs Community members have no O&M, non

- labo r or capital costs.
(iii) Annualizing capital costs No capital costs are incurred during the activities described in this ICR.89



## Table 1: **Estimated Costs to Communities (Voluntary Activities, not actually expended costs) Activity**  **Total**

**Activities at Sites/**  **Year Hours per** 

**Activity per year**  **Hourly**

**Labor Rate Annual** 

**Labor Costs per**  **Activity Capital,** 

**O&M, Non** 
**- labor**  **Costs per Activity**  **per Year Total** 

**Annual Costs per**  **Activity Total** 

**Annual Labor**  **Costs for all Sites** * **Total**

**Annual Capital,**  **O&M, Non** 
**- labor**  **Costs for all Sites**  **Total**

**Annual Costs for**  **all Sites**

TANA Interviews 25 0 1 $19.60 $19.60 $0 $19.60 $ 4,900 $0 $ 4,90010

6(c) Estimating Agency burden and cost Burden on EPA covered in the ICR includes those hours and costs incurred in the implementation of Co mmunity Involvement activities. These activities include preparing for and conducting TANAs with community members impacte d by a remedial or removal site. Total number of activities and the Federal hours required to complete them are estimated by a group of Headquarters and Regional Community Involvement EPA employees . The total estimated annual burden hours placed on EPA for the TANA process is 700 (Table 2).

**Table 2: Estimated Burden Hours fo**  **r Federal TANA process Activity**  **# of Sites # of Activities**  **at each Site Hrs. per** 

**Activity/ yr. Annual Hrs.** 

**for Activity at a Site**  **Total Annual**

**Hrs. for all Sites**  Preparing for TANA Interviews 25 1 3 3 75 Conducting TANA interviews 25 10 1 10 250 Creating TANA Summary Document 25 1 5 5 125 Coordinating Technical Assistance to Community 25 1 10 10 250
**TOTAL 700** 
Labor costs to EPA were calculated using the assumption that 100 percent of the labor of these activities would be conducted through technical staff. To determine the hourly wage, 50 percent of the value of a Step 5, GS

- 12 ($32.73) and GS

- 13 ($38.92) are s umme d ($71.65) and then adjusted for locality pay using a factor of 1.20, which results in $43. To further adjust for overhead, $43 is multiplied by 1.6, which results in $68.80. The annual labor cost for each activity that involves use of Federal hours is calculated using this labor rate. The total estimated annual costs EPA incurs for the TANA process is $48,200 (Table 3).11



## Table 3: Estimated Costs to the Federal Government for the TANA Process **Activity Total** 

**Activities at Sites**  **Hours**

**per Activity**  **per Year**  **Hourly**

**Labor Rate**  **Annual**

**Labor Costs**  **per Activity** * **Annual**

**Capital Costs**  **per Activity**  **Annual**

**Non**
  ** Labor** **Cost per**  **Activity Annual** 

**O&M Costs**  **per Activity**  **Total**

**Annual Costs**  **per Activity**  **Total**

**Annual Labor**  **Costs for all**  **Sites*** **Total**

**Annual Capital**  **Costs for**  **all Sites**  **Total Annual**  **Non**
  ** Labor** **Costs for all**  **Sites Total** 

**Annual O&M**  **Costs for all**  **Sites Total** 

**Annual Costs**  **for all Sites** 
Preparing for TANA Interviews 25 3 $68.80 $206 $0 $0 $0 $206 $ 5,150 $0 $0 $0 $ 5,150 Conducting TA NA interviews 25 0 1 $68.80 $69 $0 $0 $0 $69 $ 17,250 $0 $0 $0 $ 17,250 Creating TA NA Summary Document 25 5 $68.80 $344 $0 $0 $0 $344 $ 8,600 $0 $0 $0 $ 8,600 Coordinating Technical Assistance to Community 25 10 $68.80 $688 $0 $0 $0 $688 $ 17,200 $0 $0 $0 $ 17,200 **TOTAL $**  **48,200** ***** Rounded to the nearest whole dollar.12

6 (d) Estimating the respondent universe and total burden and cost The number of sites where a TANA may be conducted over the three year period of the ICR is based upon interest expressed by Regional Community Involvement staff over the past year. The number of community members involved at each will site vary between eight to ten individuals. The total burden and cost to each respondent is a summation of all activities described in detail in previous sections of this document.

6(e) Bottom

- line burden hours and cost tables (i) Respondent tally The total burden hours and costs displayed in the table below reflect the community members participating voluntarily at Superfund sites. Community costs of $4,900 (Table 1) are all hypothetical and do not represent the actual expenditure of dollars becaus e all participation is voluntary. **Table 4: Total respondent Burden Hours and Costs**
**Respondent Annual Burden**  **Annual Cost Total 3 yr.**  **Burden Total 3 yr. Cost**  Communities 250 $ 4,900 750 $ 14,700 **Total 250**  **$ 4,900**  **750 $**  **14,700**

(ii) Agency tally The total burden and costs represented in the following table is the amount EPA expects to spend directly in preparing for and conducting TANAs with communities at Superfund sites. **Table 5: Total Federal Agency Burden Hours and Costs**
**Respondent Annual Bur**  **den Annual Cost**  **Total 3 yr. Burden**  **Total 3 yr. Cost** Federal

Community Activities 700 $ 48,200 2100 $ 144,600 **Total 700**  **$ 48,200**  **2100 $**  **144,600**

(iii) Variations in the annual bottom line Variations to the annual bottom line numbers may occur as TANA activities depend almost exclusively on the community need s at the site. EPA expects the relative number of annual activities to be similar in each year of the ICR period.13

6(f) Reasons for c hange in burden This is the initial ICR supporting statement for TANAs conducted with communities impacted by Superfund sites. In result, there is no applicable change in burden.

6(g) Burden statement The total estimated annual burden h ours placed on communities is 250

. Total burden hours placed on 250 respondents through 250 responses is 250 hours. The annual public reporting and recordkeeping burden for this collection of information is estimated to average 1 hour per response. The ICR covers the TA

NA process which may occur either concurrently with the Community Interviews conducted for the generation of a CIP or at a later stage in the Superfund remedial process. Itis estimated that approximately ten community members will pa rticipate in TANA proc ess at twenty

- five sites per year. 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; 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.

**Part B .**  This part is not applicable because no statistical methods were used in collecting this information.