Note: This is the supporting statement for ICR 1463.07 and will be revised for ICR 1463.08

during the 60 day comment period for the first Federal Register notice. This supporting statement 

provides an excellent framework for ICR 1463.08 and the same structure will be used. Any 

comments on this statement will be incorporated into the supporting statement for ICR 1463.08.

Supporting Statement for ICR 1463.07

Part A.

1. Identification of the Information Collection

1(a) Title: 

National Oil and Hazardous Substances Pollution Contingency Plan (NCP)(Renewal), EPA ICR 1463.07, 

OMB Control Number 2050-0096

1(b) Abstract: 

ICR 1463.07 is a renewal of ICR 1463.06; the renewal is due January 31, 2008. ICR 1463.07 addresses 

the portion of the NCP that details the requirements for remedial activities at sites on the National Priority 

List (Superfund Sites). The NCP is the rule that stipulates requirements for fulfilling the legislative 

mandates of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 as 

amended (CERCLA or Superfund). This ICR covers remedial activities conducted at State-lead sites, 

participation by community members at all Superfund sites, Federally-conducted community involvement 

activities, and Federal oversight of State activities. The information collected via these activities is 

critical to characterizing contamination at sites, determining appropriate remedies and goals for cleanup, 

and involving the community in the process. All of these steps help ensure that some of the nation’s 

worst hazardous waste sites are cleaned up in a manner that is protective of human health and the 

environment, and, where practical, returned to productive use.

2. Need for and use of the Information Collection

2(a) Need/Authority for Collection:

CERCLA authorizes the President to undertake removal and remedial actions in response to releases, or 

threats of releases, of hazardous substances and certain pollutants and contaminants into the environment. 

Revisions were made to the NCP in 1982 to incorporate the provisions of CERCLA. These revisions to 

the NCP established procedures for data collection, analysis, and reporting to be conducted during 

remedial and removal responses at Superfund sites. Subsequent revisions to the NCP in 1985 added 

additional procedures. Finally, the Superfund Amendments and Reauthorization Act of 1986 (SARA) 

amended CERCLA and mandated, among other provisions, that the NCP be revised within 18 months of 

the date of enactment of SARA to incorporate provisions of the new law (42 USC 9605(b)). The revised 

NCP, published in March 1990, included new reporting and record keeping provisions for Superfund 

remedial responses as described in 40 CFR 300.430 and 300.435. 

EPA uses the information provided by the States to ensure State actions are consistent with the provisions 

of CERCLA and SARA and that their decisions are protective of human health and the environment. EPA 

uses the information gathered from private citizens to plan activities geared to educating them where 
necessary, keeping them informed of activities within the community, and ensuring they have had an 

opportunity to assume an active role in the decision making process that affects their community. EPA 

also uses information from private citizens to measure the effectiveness of community involvement 

activities and to improve those activities as needed. EPA believes involvement of the members of the 

community surrounding a Superfund site is critical to ensuring effective site cleanups.

2(b) Practical Utility/Users of the Data

The lead agency, whether EPA or the State, conducts many data-gathering activities, including 

development of the Remedial Investigation/Feasibility Study (RI/FS) and the preparation of the Proposed 

Plan and the Record of Decision (ROD). This data is used by the lead agency to make informed decisions 

regarding remedial responses. When States assume the lead agency responsibilities, EPA Regions use the 

information collected to oversee States in the conduct of remedial responses at hazardous waste sites. 

Specifically, this information is used to ensure that remedies are selected in accordance with CERCLA 

and the NCP, that cleanup standards are attained, and that community concerns are appropriately 

addressed. The data are also made available to the public and may help community members understand 

health risks and participate in site-related decisions. 

States also identify all potential applicable, relevant, and appropriate requirements (ARARs) at all Stateand Federal-lead sites during the RI/FS. The ARARs are used to determine cleanup levels and to select 

the remedy to be used at a site. ARARs include chemical-specific, location-specific, and action-specific 

levels that may need to be met at a site for it be determined protective of human health and the 

environment. These levels may be contained in federal statues, such as the Safe Drinking Water Act or 

the Endangered Species Act, or in State laws, which must be used if the levels are more stringent than 

those promulgated in a corresponding federal statute.

Community interviews and information provided by community groups are used by the lead agency to 

ensure public involvement in site-related decisions, as required by CERCLA and SARA, and provide 

appropriate opportunities for the community to learn about the site. EPA uses the information gathered 

through research instruments, such as satisfaction surveys, to obtain timely feedback on the community 

involvement process at the site level. Communities are viewed as integral participants in the Superfund 

cleanup process and their early and often involvement can often expedite cleanup and result in future 

reuse that meets the communities’ needs. 

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

3(a) Non-duplication

Duplication of other Federal data collection efforts is expected to be minimal. Site information is 

gathered cumulatively from identification through remedial action. To the extent practicable, respondents 

are encouraged to use information in the site file to inform other subsequent activities at the site.

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

The Paperwork Reduction Act requires that ICRs be made available to the public for comment prior to 

submission to OMB. This is done through two notices to the Federal Register. The first Federal Register

Notice, which describes the ICR and provides numbers for burden hours and costs and solicits public 
comment, was published on August 22, 2007. A 60-day comment period was given; no comments were 

received. The second Federal Register Notice will be published at the same time the ICR is submitted to 

OMB. This notice states that the ICR has been submitted and provides an abstract and final burden 

numbers.

3(c) Consultations

In addition to EPA Regional offices, State representatives participated in NCP workgroup meetings 

leading to the 1990 NCP revisions. State representatives provided guidance on avoiding problems 

associated with implementation of the NCP requirements. The public and other Federal and 

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

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

in the Response to Comments document supporting the final rule. 

An EPA Superfund database which is updated daily and contract records from the past eight years provide 

a basis for some estimates in this ICR. Estimates are also informed by specific consultation with subject 

matter experts in both EPA Headquarters and Regional offices. Discussions with these experts involved 

feedback on the accuracy of burden and cost estimates. Agency experience in addressing community 

issues has included semi-annual or annual meetings with Regional community involvement staff, 

meetings with groups of States, and meetings with citizen groups.

3(d) Effects of Less Frequent Collection

Information is collected as appropriate to the remedial stage of the Superfund process. The frequency of 

these collections vary depending on several factors at the site, such as complexity of issues, cleanup 

technology used, level of community interest, and duration of cleanup. Information collection 

frequencies outlined in the NCP are the minimal amount necessary to ensure cleanup of NPL sites and the 

proper implementation of CERCLA.

3(e) General Guidelines

States have at least 30 days in which to respond to any information requests specified in the NCP. This 

time frame is in compliance with the Paperwork Reduction Act guidelines. The record retention period 

for administrative records is not specified in the NCP. The site records are to be maintained for the 

duration of remedial responses at sites and for as long as necessary for litigation purposes. Responsibility 

for these files will continue beyond the 3 year ICR period as cleanups typically take more than 3 years.

3(f) Confidentiality

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

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

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

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

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

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

Information Act requests for this information. 
Lists of participants in community interviews and lists of attendees of public meetings are not 

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

privacy concerns. 

3(g) Sensitive Questions

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

questions.

4. Respondents and Information requested

4(a) Respondents/SIC Codes

Respondents to this ICR are State/Tribal governments and individual community members who 

voluntarily participate in the remedial phase of the Superfund program and in associated community 

involvement activities throughout the Superfund process. SIC Codes are OSHA’s Standard Industrial 

Classification System used to identify different groups. State/Tribal governments are categorized as 

Division J: Public Administration, Major Group 95: Administration of Environmental Quality and 

Housing Programs, Industry Group 951: Administration of Environmental Quality, subgroup 9511: Air 

and Water Resource and Solid Waste Management. The other respondents, community members, do not 

have a SIC Code as they do not constitute an industry.

4(b) Information requested

This ICR requests information from States at State-lead sites as it relates to CERCLA activities. Each of 

the following categories will be addressed in detail in this section: RI/FS, Proposed Plans, RODs, 

ARARs, Administrative Record, initial and revised Community Involvement Plans (CIP), Fact Sheets, 

focus groups, and workshops. Information is also requested on a voluntary basis from community 

members at all active Federal and State lead sites. The following community activities will be addressed 

in detail in this section: initial and revised CIP interviews, focus group participation, workgroup 

participation, TAG application, TAG management, and satisfaction surveys. Federal activities will be 

discussed in a subsequent section of this document.

(i) Data items, including record-keeping requirements

Remedial Investigation/Feasibility Study

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

9604(a)(1); 40 CFR 300.430), is the development of a project plan, which describes the scope and content 

of the RI/FS and includes work plans. Work plans are developed as part of the project plan and detail the 

site management strategy. The work plans identify initial boundaries of the study area, likely remedial 

response objectives, operable units (if any), and the procedures that will be followed to satisfy the 

strategy. In addition, an initial site evaluation is presented in the typical work plan. This evaluation 

includes:

- Site description;

- Preliminary definition of the contamination problems;
- Likely contaminant migration pathways;

- Environmental and health effects associated with migration; and

- Description of any initial remedial measures for the site.

A preliminary assessment of remedial alternatives may be included in the work plan. The data

requirements necessary to support the selection of a remedy are also discussed. 

Based on preliminary site information, the objectives and the scope of work for the RI and FS are 

developed. The scope of work for the RI includes many components, including plans for project 

operations that will be followed in conducting a survey of the study area, in characterizing the source of 

contamination, and in identifying Federal and State ARARs. The work plan also includes procedures that 

will be followed in evaluating contamination pathway and transport, and in evaluating the potential risk to 

public health posed by the site. Plans for testing the feasibility of remedial technologies may also be 

included. Initial data quality objectives, quality assurance procedures that will be followed, procedures to 

be followed in preparing the RI report, and information on the technical and financial management of the 

RI project also are discussed in the RI scope of work section of a site work plan. 

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

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

collecting air, water, soil, and source samples. Additionally, quality assurance objectives to be met 

throughout the sampling task are discussed. These objectives include procedures that will be followed to 

ensure the accuracy and precision of the analysis, as well as the completeness, representativeness, and 

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

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

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

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

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

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

measures. 

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

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

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

included. 

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

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

finalized before any RI field work begins. 

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

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

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

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

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

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

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

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

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

technologies considered for use at a site; and (2) support the design of selected potential remedies. The 

FS serves as the mechanism for the development, screening, and detailed evaluation of potential remedial 

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

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

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

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

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

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

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

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

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

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

substances and their toxicological effects are studied to determine the potential for the substances to cause 

adverse health effects, and the likely pathways and magnitude of exposure of populations and/or 

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

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

toxic substances at a site. 

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

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

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

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

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

uncertainties places bounds on the final estimate and target areas needing improvement. The FS process 

includes the initial evaluation and screening of a number of potential alternatives. Alternatives are 

eliminated from further evaluation for a number of reasons, including technical problems, lack of 

effectiveness in the long term or short term, failure to protect human health and the environment, cost, or 

implementation time. The universe of potential remedies is reduced to a reasonable number (usually 

between three and five) of good alternatives on which detailed analyses are conducted. If existing site 

and treatment data are insufficient to evaluate the alternatives adequately, treatability tests may be 

necessary to evaluate a particular technology or specific site wastes. Treatability tests generally involve 

bench-scale testing to assess the feasibility of a technology, although a pilot-scale study may be required 

in a few situations. 

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

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

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

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

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

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

RI/FS report is prepared. 

For the purposes of this analysis, EPA estimates that there will be an average of 12 RI/FS per year. This 

estimate includes new and on-going RI/FS. The State-lead portion of these RI/FS is estimated to be 2 
RI/FS per year over the three-year ICR period. The Federal government will have the lead on the 10 

remaining sites per year. These estimates are based on data obtained from a Superfund database 

concerning new sites entering the remedial phase of the Superfund process. The average represents actual 

numbers from the previous ICR period and planned data for the renewal ICR period. On average, 90% of 

RI/FS are completed within 2-5 years (13-60 mos.) of the start date. This average represents an analysis 

of actual and planned date from Fiscal Year (FY) 2001 to FY 2006, grouped both by 3 year ICR periods 

and across the years. The number of RI/FS that EPA expects at both Federal and State lead sites 

represents an average taken across each three year grouping for number of starts and for total time to 

completion.

Proposed Plans

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

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

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

selection of a response action. The lead agency's primary objective in preparing and releasing the 

Proposed Plan is to seek public comment on the preferred alternative for addressing a problem at a 

site, and on the other alternatives discussed in the detailed analysis section of the RI/FS. The Proposed 

Plan serves as a precursor to the Record of Decision (ROD), which details the remedial action to be 

conducted at the site. The ROD is usually is draft form while the Proposed Plan is finalized and released 

for public comment.

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

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

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

participate in the remedy selection process. 

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

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

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

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

and released to the public for comment. 

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

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

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

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

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

Public Meeting and 30-day comment period. 
Finally, CERCLA §l17 requires the lead agency to offer the opportunity for a public meeting to discuss 

and answer questions and to obtain feedback about the RI/FS report and the Proposed Plan. The lead 

agency establishes a date and time for the meeting, reserves a facility, and arranges for any special needs. 

The lead agency also designs the meeting program, including identifying specific issues and tasks to be 

addressed, preparing an agenda, identifying presenters, and rehearsing presentations. Printed materials, 

visual aids or graphics, and other materials are prepared and special arrangements made, such as hiring a 

court reporter. Finally, the meeting is held, and a transcript of the meeting notes is prepared by the lead 

agency. The transcript is made available to the public as required by CERCLA §117. 

Because the Proposed Plan typically is followed closely in time by the ROD, the total number estimated 

to be written annually at State-lead sites is based on data collected for RODs. Proposed Plans are 

completed in a discrete amount of time and are assumed not to extend beyond one year. The ROD data 

comes from the Superfund database and will be discussed in detail in the following section. EPA 

estimates that Proposed Plans will be finalized at 4 State-lead sites in each year of the 3 years covered by 

this ICR.

Records of Decision

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

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

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

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

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

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

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

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

Declaration, the Decision Summary, and the Responsiveness Summary. All RODs are signed by EPA 

Regional Administrators or the Assistant Administrator for OSWER. In addition, a representative from 

a State may sign a ROD. 

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

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

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

brief description of the selected remedy. The Decision Summary is the focus of the ROD. The Summary 

begins with a brief discussion of the site history and a detailed site description, including: 

-Site area and topography, 

-Adjacent land uses; 

-Natural resource uses; 

-Distance to nearby populations; 

-General water resources, and 

-Surface and subsurface features. 

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

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

activities that have been conducted for the site. 
The Decision Summary summarizes the scope of the response action and the site characteristics. The site 

characteristics section draws on information presented in the RI/FS report and includes details on: 

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

-All known or suspected sources of contamination;

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

waste;

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

-Potential surface and subsurface pathways of migration.

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

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

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

Proposed Plan are summarized.

Another major component of the Decision Summary is the evaluation of the remedial alternatives 

considered for the site and identification of the selected remedy. The evaluation of alternatives section 

first presents a brief description of each of the remedial alternatives. Each alternative for which a detailed 

analysis was completed (typically five) is discussed. These discussions include: 

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

treatment; 

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

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

management process. 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

makers with information about community preferences regarding the remedial alternatives considered 

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

integral part of the decision making process. 
In preparing the Responsiveness Summary, background research is done to identify citizen 

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

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

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

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

of policy issues outstanding at a site.

For the purposes of this ICR, it is estimated that 4 RODs will be completed annually at State-lead sites 

over the three-year ICR period, while 46 RODs will be completed annually by the Federal government. 

This average is based on data in a Superfund database concerning the actual number of RODs issued each 

year since 1995 and those planned through 2007. The average takes into account that planned numbers 

routinely are higher than actual numbers. The averages from the database match well with a 2001 EPA 

ROD Accomplishment Report.

Applicable or Relevant and Appropriate Requirements

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

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

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

Federal, State, or Federal facility lead sites. States are not reimbursed for any costs associated with 

researching and identifying ARARs for a site.

Potential State ARARs are to be identified as early in the RI/FS process as possible. Therefore, the 

estimate of sites where ARAR identification is necessary is based on RI/FS start data from a Superfund 

database. The average for each type of site is taken across actual and planned dates for RI/FS starts. It is 

estimated that a total of 45 sites (10 Federal-lead, 2 State-lead, 33 Federal facilities) will require ARAR 

identification each year.

Administrative Records

SARA amended CERCLA §113 to require that an Administrative Record be established to document the 

basis for selection of response action. The record must be made available to the public at a location near 

the site (42 USC 9613 (1)). As a result, two records, one near the site and one at the lead agency office, 

are compiled and maintained at each remedial site. In developing the records, an appropriate location for 

the record must be identified. This location must be publicly accessible. Then, documents included in the 

record must be maintained by updating information as necessary, and verifying the information is 

available that should be included in the record. The information record will be maintained as long as site 

remediation continues and for as long as is needed in the event there is litigation. Because remedial 

responses often last longer than three years, the record keeping associated with remedial responses 

typically will be maintained for more than three years. 
The Administrative Record must be maintained at all active Superfund sites each year. For the purposes 

of this ICR, active sites are those that have not yet achieve the Construction Complete milestone. These 

sites may have studies pending, design and study underway, or construction underway. Based on 

historical program data, EPA estimates there to be approximately 550 active Federal and State lead 

Superfund sites. For State-lead action of RI/FS, RD, and RA, States have historically had the lead on 

20% of sites. This percentage of active sites also is applicable for the revised CIP, fact sheets, and focus 

groups. Therefore, it is estimated that the State will maintain the administrative record at 100 sites each 

year.

Initial Community Involvement Plan(CIP)/Revised CIP

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

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

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

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

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

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

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

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

necessary to accommodate changes in the community. 

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

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

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

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

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

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

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

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

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

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

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

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

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

explain Superfund program activities and the role of the lead agency in the remediation of Superfund 

sites. Small group meetings between lead agency staff, citizens, and local officials may be held to 

promote an informal exchange of ideas. To maximize the potential to bring about improvement in 

government services, EPA will utilize telephone interviews of fact sheet recipients and meeting attendees 

to assess the effectiveness of specific outreach products. EPA may also use focus groups to gather citizen 

input. At some sites, formal community groups may be established that provide regular involvement and 

input to site activities. 
Prior to commencement of the Remedial Design/Remedial Action stage, the CIP is reviewed to determine 

whether it should be revised to address the community concerns at that time. These plans are written as 5-

year plans that are renewed every three years. This cycle will be followed at all active sites throughout 

the duration of remedial activities. The process for preparing the revised CIP is essentially the same as 

that followed in preparing the initial CIP: 

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

written or last revised; 

-Community interviews are planned and conducted; 

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

concerns; and 

-The CIP document is revised. 

Since the Initial CIP is developed concurrent with the RI/FS, the estimated number of sites at which the 

State will conduct an RI/FS each year is applied to the Initial CIP. Therefore, EPA expects 2 CIPs to be 

completed by States each year of the three-year ICR period. Federal-lead sites are expected to complete 

10 initial CIPs each year. CIPs are revised every 5 years for all active Superfund sites. Superfund data 

indicates that States have the lead on approximately 100 active Superfund sites. Therefore, a rough 

estimate is that each year 20 of these sites will require a CIP revision. EPA estimates that CIPs will be 

revised at 80 active Federal-lead Superfund sites each year. 

Fact Sheets

The lead agency provides fact sheets to communities at various points, both pre and post Construction 

Completion, in the Superfund remedial process. The number and frequency of fact sheets developed 

varies depending on community interest, complexity of remedial technologies, PRP/enforcement issues, 

and the extent of relocation and reuse potentials. Fact sheets may describe the details of a specific 

technology used, the physical changes that may occur at the site, the extent of contamination and health 

risks, the status of enforcement actions and negotiations with PRPs, etc. The lead agency develops fact 

sheets on an “as needed” basis. These fact sheets may be mailed to a list of interested community 

members. 

EPA estimates that the States are the lead agency for 100 active Superfund sites and, thus, are expected to 

write fact sheets for these sites. A group of experienced EPA Headquarters and Regional Community 

Involvement staff estimate that an average of 4 fact sheets will be completed at each active Superfund 

site. Because of the site-specific need for fact sheets, it is anticipated that some sites will generate far 

more than 4 fact sheets in a single year and other sites will require the writing of hardly any.

Focus Groups

For this ICR, focus groups are defined as meetings or sessions the purpose of which is to obtain 

community input and in which the lead agency asks the community specific questions. These groups 

typically involved a small select group of community members who are gathered to provide feedback 

from the community perspective on particular on-going issues and concerns. A group of EPA 

Headquarters and Regional Community Involvement staff provided information and estimates for this 

analysis. EPA estimates that focus groups will be conducted an average of 4 times per year at 1% of 

active sites (1 at State-lead sites, 4 at Federal-lead sites).

Workshops
This ICR defines workshops as meetings or sessions that are open to the general public and whose subject 

matter is broad in scope. These workshops are often used as planning tools in which specific broad 

overview questions are asked of the community to gather ideas about their visions for the site and 

potential future uses. EPA Headquarters and Regional Community Involvement staff estimate that a 

workshop is conducted at 2% (currently ~10 sites) of all active sites each year. Since the State has the 

lead on 20% of active sites, EPA estimates that the State will prepare and conduct a workshop at 2 sites 

annually. EPA estimates that it will conduct a workshop at 8 Federal-lead sites each year.

Technical Assistance Grant Application/TAG Management

SARA amended CERCLA §117(e) to provide for Technical Assistance Grants (TAGs) to eligible 

community groups for an initial grant up to $50,000. The purpose of these grants is to give communities 

that are affected by Superfund sites the opportunity to obtain expert information and consultation about 

the site. The TAG allows community groups to hire an independent advisor who can help them 

understand various technical aspects of the site, such as characteristics of the contamination, the proposed 

remedies, the remedial design, the technical aspects of the remedy, the health risk and analysis, and site 

construction. TAGs may be renewed to facilitate public participation throughout the Superfund remedial 

process. Community groups apply for TAGs and manage those that they already have. TAGs are 

processed and granted by the Federal government. There is no State burden or cost for TAGs. EPA 

Community Involvement staff estimate that 15 TAG applications will be filed and 120 maintained each 

year.

Satisfaction Surveys

Satisfaction surveys are used by EPA to gather community input about EPA’s community involvement 

efforts. These surveys consist of up to ten questions asking community members to provide opinions and 

to rank EPA’s community interactions, the level of knowledge citizens have gained about the site and 

issues, how citizens learned information about the site, and the desires of the community for how they 

would like to interact with EPA. The information gathered in these satisfaction surveys help EPA 

improve it’s community involvement activities and relationships with communities at Superfund sites. 

EPA estimates that these surveys will be completed at 5 active Superfund Federal-lead sites each year. 

Information and estimates about these surveys are provided by EPA Headquarters Community 

Involvement staff who are involved in administering these surveys.
(ii)Respondent Activities

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

employees may need to: 

-Read instructions; 

-Plan activities; 

-Receive training; 

-Gather information; 

-Conduct tests, investigations, and studies; 

-Write documents; 

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

-Complete written forms or other paperwork; 

-Substantiate claims of confidential business information; 

-Record and disclose information; and 

-Store, file, and maintain the information. 

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

-Gather information on new state laws and regulations; 

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

-Record and disclose information; and 

-Store, file, and maintain information. 

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

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

-Participate in interviews;

-Participate in focus groups;

-Participate in workshops;

-Apply for a Technical Assistance Grant (TAG)

-Manage a TAG; and

-Respond to surveys. 

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

5(a) Agency activities

Agency activities that relate to the information gathered from States are predominantly oversight 

functions at State-lead sites to ensure that the Superfund sites are being addressed according to CERCLA 

and to EPA’s current policies. In this role, the Agency may obtain, review, and maintain the information 

gathered by States. The Agency also reviews the State ARARs at all Superfund sites. A standard 10% of 

annual hours is applied to Federal oversight of the following State activities: RI/FS, Proposed Plans, 

RODs, ARAR evaluation, and initial and revised CIPs. A group of experienced EPA Headquarters and 

Regional Community Involvement employees provided the oversight hours estimates for all other 

activities: Administrative Record, fact sheets, focus groups, and workshops.

At all Federal-lead sites, the Agency conducts the following activities: maintaining the Administrative 

Record, initial CIP, revised CIP, fact sheets, focus groups, workshops, TAG applications, TAG 

management, and satisfaction surveys.
5(b) Collection methodology and management

The information collection methodology varies depending on the type of activity being conducted. For 

example, an RI/FS requires many more hours than other activities because it involves field work and 

sampling. In contrast, evaluation of ARARs involves systematic and routine research. A large 

component of Proposed Plans and RODs is the actual preparing and finalizing of the document.

States provide information to EPA Regional Offices in the form of document copies. Regions review the 

documents to ensure consistency with the NCP. Regions and States use various media avenues (e.g., 

local newspaper announcements, mailings, etc.) to notify the public about meetings, focus groups, and 

workshops. The Regions and States may also communicate with Community Advisory Groups (CAGs) 

and other involved citizen groups. Phone calls and office hours are other means by which the 

governments communicate with communities.

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

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

conducive to mass data collection efforts. The NCP does not specify a particular method of 

accomplishing information collection; the use of improved information technology is not prohibited in 

any way. 

5(c) Small entity flexibility

Information collection from small entities (individual community members, community organizations, 

etc.) is primarily done on a voluntary basis. Since these respondents are providing information 

voluntarily, the Federal government is not placing any undue burden on small entities and does provide 

plenty of flexibility.

5(d) Collection schedule

Information is collected according to the sequence of remedial activities at Superfund sites: RI/FS, ARAR 

evaluation, Proposed Plan, ROD, and initial Community Involvement Plan (CIP). Other activities are 

conducted throughout the remedial process as needed. These include maintenance of the Administrative 

Record, revising the CIP, issuing fact sheets, processing Technical Assistance Grants (TAGs), gathering 

community satisfaction surveys, and conducting focus groups and workshops with community members. 

The frequency of these activities will depend on many site-specific factors such as complexity of clean-up 

technologies, level of community interest, and duration of each of the remedial stages.
6. Estimating the burden and cost of the Information Collection

6(a) Estimating respondent burden

Respondent burden estimates are calculated from a combination of sources: historic and projected data 

from Superfund databases, contract records, consultation with EPA Headquarters and Regional staff, and 

information contained in the 2004 version of this ICR. Burden hours are estimated for the number of 

hours expected annually for each activity. The annual hours per activity figure is multiplied by the 

number of sites expected to be engaging in the activity every year. This calculation gives the total annual 

hours for all sites by activity. All burden hours, with the exception of ARARS, placed on States refer to 

only activities conducted at State-lead sites. All burden hours placed on communities refer to activities 

that are conducted at all Federal and State-lead sites.

The estimated number of respondents reported for this information collection is 7,970. This number is 

the sum of all State-lead activities, 280, and people participating in community activities at all sites, 7690. 

The estimated number of responses is 8,498. This is the sum of State responses, 583 State-lead activities 

at all sites each year, and community responses, 7,915 people participating in all activities at all sites. 

(i) State Burden Hours

The total hours for an RI/FS is assumed to consist of 80% contractor work and 20% government work. 

The total contractor hours for an RI/FS project, 4200 hours, is calculated from Office of Superfund 

Remediation and Technology Innovation (OSRTI) contract records from 1996 through 2006. Data for 

costs billed as direct labor across all projects and years provides information about the number of hours 

spent on an average RI/FS. Burden hours can be divided among different labor categories based on 

contract records: 62% professional labor, 30% direct labor, 4% clerical labor, and 4% technical labor. 

Total contractor hours per RI/FS is estimated to be 4,200 hours per year, which is estimated to account for 

80% of the hours for an RI/FS. The remaining 20% of RI/FS work, 1,050 hours, is done by the State 

government. Therefore, the total annual time devoted to a single RI/FS is estimated to be 5,250 hours. 

This ICR estimates that 2 State-lead sites will be in the process of conducting an RI/FS every year. The 

total annual burden hours is 10,500 (Table 1).

Total burden hours for each Proposed Plan is estimated to be 80 hours. This figure covers the time taken 

for writing, printing, notification, and distribution of the Proposed Plan. This estimate remains the same 

from the previous ICR renewal. Since Proposed Plans are expected to be completed at 4 State-lead sites 

each year, a total annual estimate of burden is 320 hours. These estimates are confirmed by EPA 

Headquarters and Regional management.
The hours required to complete a ROD are highly variable across the Superfund program given site 

complexity and enforcement issues. The burden hours for a ROD are assumed to include the time needed 

for writing, reviewing, negotiating, and obtaining concurrence. The ROD finalization process is one that 

takes quite a lot of time and energy. The estimates are based on consultation with EPA staff experienced 

in writing RODs and involved in writing the ROD guidance document (“A Guide to Preparing Superfund 

Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents,” EPA 540-R98-031, OSWER 9200.1-23.P, July 1999). Experience with very complex and more straight-forward 

RODs was used in calculating an average value for ROD burden hours. For the purpose of this ICR it is 

estimated that the average ROD requires a total of 1,300 hours. This estimate is based on a 9 month time 

frame in which one full-time employee dedicates 50% of work time to the ROD for a total of 720 hours, 

and, two full-time employees dedicate 20% of work time for a total of 576 hours. The former employee 

is typically the Remedial Project Manager (RPM) for the site and the latter two employees consist of 

policy analysts, attorneys, and managers. This ICR estimates that RODs will be completed at 4 State-lead 

sites each year; thus, the estimated total annual ROD burden to States is 5,200 hours.

The total estimated annual burden for identification of ARARs is 33 hours at each Federal, State, or 

Federal facility lead site. This estimate is the same as the ARAR estimate in the previous version of this 

ICR. The figure is also confirmed by EPA staff experienced in evaluating ARARs. ARARs are expected 

to be evaluated at 45 sites annually, resulting in an estimated burden of 1,485 hours.

The establishment and maintenance of one site’s Administrative Record is estimated to take 40 hours 

annually. Since States are estimated to have the lead on 100 active Superfund sites, EPA expects States to 

spend 4,000 total hours on Administrative Records. This estimate is provided by a group of experienced 

EPA Headquarters and Regional staff.

Total estimated annual burden hours for each initial and revised CIP are 200 and 100, respectively. Initial 

CIPs are estimated to be completed at 2 State-lead sites each year for a total annual burden of 400 hours. 

Revised CIPs are estimated to be completed at 20 State-lead sites each year for a total annual burden of 

2,000 hours. These hours are estimated by a group of EPA Headquarters and Regional staff experienced 

in the development and revisions of CIPs.

EPA estimates that each fact sheet will require an average of 40 hours of work per year. This estimate is 

the result of discussion by a group of experienced EPA Headquarters and Regional Community 

Involvement staff. An average of 4 fact sheets are expected at each of the 100 estimated State-lead active 

sites. Therefore, fact sheets will require a total annual estimate of 160 burden hours at each site. EPA 

estimates that States will issue fact sheets at 100 active sites per year. Thus, the total estimated annual 

burden hours for fact sheets is 16,000.

The estimated time that each focus group session will require of the State is 30 hours. This includes 

preparation for the meeting and attendance. EPA expects the State to conduct 4 focus group sessions at 

one site in each year, resulting in a total annual estimated burden of 120 hours. These estimates are 

provided by a group of experienced EPA Community Involvement staff.

The estimated annual burden for each workshop is 80 hours. EPA estimates that the State will be 

conducting 1 workshop at 2 sites in the course of one year and will, thus, devote 160 hours to workshop 

efforts. These estimates are based on the knowledge of EPA Community Involvement staff experienced 

in preparing and conducting workshops at Superfund sites.
Table 1: Estimated Burden Hours placed on States

Activity # of Sites 

with Statelead 

Activities/yr

# of 

Activities at 

each site/yr.

Hrs. per 

Activity/yr

Annual Hrs. 

for Activity at 

a Site

Total Annual Hrs. 

for all Sites

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

Proposed Plans 4 1 80 80 320

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

ARARs 45 1 33 33 1,485

Administrative 

Record

100 1 40 40 4,000

Initial CIP 2 1 200 200 400

Revised CIP 20 1 100 100 2,000

Fact Sheets 100 4 40 160 16,000

Focus Groups 1 4 30 120 120

Workshops 2 1 80 80 160

TOTAL 40,185

(ii) Community Burden Hours

All community burden hours are due to voluntary participation in activities at Superfund sites. The 

Paperwork Reduction Act (PRA) requires the inclusion of information gathering activities in which the 

community participates. These activities are those for which information is expressly collected from 

community members. The PRA (5 CFR part 1320, “Controlling Paperwork Burdens on the Public, FRN 

8/29/1995, Sect. 1320.3 (h)(8)) excludes the following activities from the definition of information for the 

purpose of Information Collection Requests: attendance at public informational meetings or briefings, 

response to comments on EPA documents, participation in community groups for which EPA is not a 

sponsor, reading fact sheets, and making use of EPA open office hours. This ICR records estimated 

burden hours for community members for initial and revised CIP interviews, participation in focus groups

and workshops, TAG application and management, and completion of satisfaction surveys. All estimates 

are provided by a group of experienced EPA Headquarters and Regional Community Involvement Staff.

EPA estimates that 40 people will be interviewed for 1 hour each at 12 Federal and State lead Superfund 

sites each year for initial CIPs. The total annual estimated burden for initial CIP interviews at all sites is 

480 hours. It is estimated that 25 people will be interviewed for 1 hour each at 100 active Superfund sites 

each year for the purpose of revising the CIPs. Therefore, the total estimated annual burden is 2,500 

hours (Table 2).
EPA estimates that an average of 15 people will participate in a 2 hour focus group 4 times a year at 5 

active Superfund sites. The total estimated burden for all sites for each year is 600 hours. 

An average of 50 people are expected to participate in a 3 hour workshop session once a year at 10 active 

Superfund sites. The total estimated annual burden for all sites is 1,500 hours.

EPA estimates that community groups will apply for available TAGs at 15 Superfund sites. The 

application process is estimated to take approximately 60 hours. The total estimated annual burden for all 

sites is 900 hours. Management of TAGs takes place each year at an estimated 120 sites. This requires 

approximately 200 hours per year. The total estimated annual burden for all sites is 24,000 hours.

EPA expects to distribute satisfaction surveys at 5 sites each year. It is estimated that 800 people will 

spend 0.25 hours (15 minutes) completing each survey. The total estimated annual burden hours at all 

sites is 1,000.

Table 2: Estimated Burden Hours placed on Communities

Activity # Federal 

and Statelead Sites/ 

yr.

# of 

Activities at 

each site

# of 

People 

involved

Hrs. per 

Activity/yr.

Annual Hrs. 

for Activity 

at a Site 

Total Annual Hrs. 

for all Sites 

Initial CIP 

Interview

12 1 40 1 40 480

Revised CIP 

Interviews

100 1 25 1 25 2,500

Focus Group 

Participation

5 4 15 2 120 600

Workshop 

Participation

10 1 50 3 150 1,500

TAG 

application

15 1 N/A 60 60 900

TAG 

management

120 1 N/A 200 200 24,000

Satisfaction 

Surveys

5 1 800 0.25 200 1,000

TOTAL 30,980
6(b) Estimating respondent costs

Respondent costs are divided into labor costs and other costs, which includes all operation and 

maintenance, non-labor, and capital costs. The methodology for calculating these costs for the three year 

ICR period is addressed in detail below. 

All costs the State incurs, with the exception of the ARARs analysis, is ultimately paid for by the Federal 

government through any one of two relevant cooperative agreements (CAs) as stipulated in Subpart O of 

the NCP. These cooperative agreements are CORE agreements which provide fund for infrastructure 

work and are non-site-specific in nature, and Remedial CAs that provide site-specific money for remedial 

process actions in Superfund.

(i) Estimating labor costs

Labor rates for government employees are estimated using the Office of Personnel Management’s 

General Schedule pay tables for 2007. For the purposes of this ICR, State government salaries are 

assumed to be the same as Federal pay scales. It is assumed that the average unit of remedial work is 

comprised of 10% managerial, 80% technical, and 10% support staff effort. Thus, a weighted average is 

used to represent the hourly labor rate of government work. Step 5 of each GS-13, GS-11, and GS-7 is 

used to provide a median value for each grade level of employee. Total salary for each includes the direct 

salary plus 60% of direct salary to account for benefits. As of February 2007, the hourly labor salaries 

are:

-GS-13, Step 5: $58.18

-GS-11, Step 5: $40.82

-GS-7, Step 5: $27.58

The average governmental hourly labor rate is $41.23, calculated by: [0.1(58.18)+0.8(40.82)+0.1(27.58)]. 

This average hourly labor rate applies to the following activities conducted by State agencies for the 

Superfund remedial program: Proposed Plans, RODs, ARARs, Administrative Records, initial CIPs, 

revised CIPs, fact sheets, focus groups, and workshops. The same hourly labor rate applies to all Federal 

activities.

The hourly labor rate for the RI/FS activity is calculated as 20% government and 80% contractor effort. 

These assessments involve a great deal of field work and typically involve lots of contractor support. The 

labor value is calculated from RI/FS contract records from OSRTI dating from 1996 through 2006. 

Direct labor costs from over 1,000 projects are used to arrive at an average contractor hourly labor rate of 

$25.86. The average government hourly labor rate of $41.23 is used for the government’s 20%. 

Therefore, the average hourly labor rate for RI/FS work is $28.93, calculated by: [0.2(41.23) + 0.8 

(25.86)].

The hourly labor rate for community members who participate in Superfund remedial activities on a 

voluntary, and non-paid, basis is $16.50. The value is based on Bureau of Labor Statistics data, which 

reports an average hourly wage of $16.50 for “production, non-supervisory on private non farm payrolls, 

seasonally-adjusted” employees. The recent trend in this category of BLS data is for the rate to increase 

approximately $0.50 per year. Therefore, $16.50 is the average rate over the 3 year period of this ICR for 

all activities in which the community may participate. Labor costs for community activities represent 

hypothetical costs only.
(ii) Estimating capital, operations and maintenance, and other costs

Capital, operation and maintenance (O&M), and non-labor costs to States apply for the following 

Superfund remedial activities: RI/FS, Proposed Plans, RODs, Administrative Records, and fact sheets. 

The Federal government incurs none of these costs for oversight of State activities. The Federal 

government does incur non-labor costs for the Administrative Records, fact sheets, and satisfaction 

surveys. Community members have no O&M, non-labor, or capital costs. States, communities, and the 

Federal government do not incur any capital costs in these Superfund remedial activities as no new 

equipment is purchased for their purposes.

All O&M and non-labor costs for RI/FS conducted at State-lead sites are calculated from OSRTI 

contracts records from 1996-2006. Contractor non-labor costs for RI/FS includes $80,429 in fees and 

profits, $115,730 for equipment, and $77,100 for indirect costs such as travel and reports. The costs for 

equipment reflects charges for the use of equipment, such as computers and sampling instruments, that 

the contractor already owns. The total non-labor costs for each RI/FS in a single year is, therefore, 

estimated at $273,259 (Table 3). 

Operation and maintenance is defined as activities that are required to keep projects supported and 

moving forward. For the RI/FS it is estimated that contractors incur approximately $40,029 in a single 

year for each project. These costs include charges for mail, supplies, and faxes. O&M costs incurred by 

the Agency are discussed in the following paragraph.

The bulk of O&M costs associated with Proposed Plans, RODs, Administrative Records, and fact sheets 

are those costs that are required for printing, document distribution, newspaper announcements, and 

records management. Costs for mailing and data collection with contractor support also apply to the 

satisfaction survey. Annual non-labor costs for satisfaction surveys is estimated by EPA staff conducting 

the survey to be $6,000. For all other activities with O&M costs, the values from the 2004 version of this 

ICR are used and adjusted for inflation. Inflation is calculated by using a percent of cost change value of 

3.14. This value is estimated for the 3 year period of the ICR based on calculations from the National 

Aeronautics and Space Administration’s “Gross Domestic Product Deflator Inflation Calculator.” This 

number represents an average of the percent of cost change from three 3-year periods (2002-2005; 2003-

2006; 2004-2007). Using 3.14 as an inflation value, the following O&M annual costs for each activity 

are:

-Proposed Plan: $1,687

-RODs: $1,817

-Administrative Record:$1,366

-Fact Sheets: $1,638

(iii) Annualizing capital costs

No significant capital costs are incurred during the activities described in this ICR.
Table 3: Estimated Cost to States

Activity

Total 

Statelead 

Activities 

at Sites 

per year

Hours 

per 

Activity 

per year

Hourly 

Labor 

Rate

Labor 

Costs 

per 

Activity 

*

Capital 

Costs 

per 

Activity 

per 

year

Contractor 

Related 

Non-labor 

Costs per 

Activity 

per year *

O&M 

Costs 

per 

Activity 

per 

year *

Total 

Annual 

Costs 

per 

Activity

Total 

Annual 

Labor 

Costs 

for all 

Sites

Total 

Annual 

Capital 

Costs 

for all 

sites

Contractor 

Related 

Total 

Annual 

Non-labor 

Costs for 

all sites

Total 

Annual 

O&M 

Costs for 

all Sites

Total 

Annual 

Costs for 

all Sites

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

Proposed 

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

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

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

Admin 

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

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

Revised 

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

Fact 

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

Focus 

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

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

TOTAL $ 885,874 2,959,987

Federal 

Funds 

Used $ 885,874 2,898,742

State 

Funds 

Used $ 0 61,245

* Rounded to the nearest whole dollar
Table 4: Estimated Costs to Communities (Voluntary activities, not actually expended costs)

Activity

Total 

Activities 

at 

Federal 

and 

Statelead 

Sites/yr

Hours 

per 

Activity 

per 

year

Hourly 

Labor 

Rate

Annual 

Labor 

Costs per 

Activity *

Capital, 

O&M, 

Nonlabor 

Costs 

per 

Activity 

per 

year

Total 

Annual 

Costs per 

Activity

Total 

Annual 

Labor 

Costs for 

all Sites *

Total 

Annual 

Capital, 

O&M, 

Nonlabor 

Costs 

for all 

Sites

Total 

Annual 

Costs for 

all Sites

Initial CIP 

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

Revised CIP 

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

Focus Group 

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

Workshop 

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

TAG 

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

TAG 

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

Satisfaction 

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

TOTAL $511,170.00 

* Rounded to nearest whole dollar
6(c) Estimating Agency burden and cost

Burden on the Environmental Protection Agency covered in the ICR includes those hours and costs 

incurred in overseeing State activities. For the RI/FS, Proposed Plans, ARARs, initial and revised 

CIPs, the assumption is that Federal oversight hours are 10% of the State’s burden hours for respective 

activities. For the Administrative Record, fact sheets, focus groups, and workshops the assumption is 

that Federal oversight hours are 5% of the State’s burden hours. These assumptions were provided by 

a group of Headquarters and Regional Community Involvement EPA employees with the experience 

to estimate the average Federal oversight hours for these activities. The total estimated annual burden 

hours placed on EPA for oversight of State activities is 3,005 (Table 5). 

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

Activity # of Sites 

with Statelead 

Activities/yr

# of 

Activities at 

each site

Hrs. per 

Activity/yr

Annual Hrs. 

for Activity at 

a Site 

Total Annual Hrs. 

for all Sites 

RI/FS 2 1 525 525 1,050

Proposed Plans 4 1 8 8 32

RODs 4 1 130 130 520

ARARs 45 1 3.3 3.3 149

Administrative 

Record

100 1 2 2 200

Initial CIP 2 1 20 20 40

Revised CIP 20 1 10 10 200

Fact Sheets 100 4 2 8 800

Focus Groups 1 4 1.5 6 6

Workshops 2 1 4 4 8

TOTAL 3,005

Burden on EPA covered in the ICR also includes those hours and costs incurred in the implementation 

of Community Involvement activities. These activities include initial and revised CIPs, fact sheets, 

focus groups, workshops, satisfaction surveys, and TAGs. For these activities that are also conducted 

by States at State-lead sites, the average hours required per activity is the same as the burden hours 

placed on the States. Total number of activities and the Federal hours required to complete them are 

estimated by a group of Headquarters and Regional Community Involvement EPA employees. EPA is 

also responsible for maintaining the Administrative Record at all active Federal-lead sites at all stages 

of the cleanup process. It is estimated that these sites comprise about 80% of all active sites. At the 

time of this writing there are approximately 550 active NPL sites (EPA database). Therefore, EPA is 

responsible for maintaining the AR at 450 sites. The total estimated annual burden hours placed on 

EPA for Community Involvement activities is 107,920 (Table 6). 
Table 6: Estimated Burden Hours for Federal Community Activities

Activity # Federallead Sites/ 

yr.

# of Activities 

at each site

Hrs. per 

Activity/yr.

Annual Hrs. 

for Activity at 

a Site 

Total Annual 

Hrs. for all Sites

Administrative Record 400 1 40 40 16,000

Initial CIP 10 1 200 200 2,000

Revised CIP 80 1 100 100 8,000

Fact Sheets 450 4 40 160 72,000

Focus Group 4 4 30 120 480

Workshop 8 1 80 80 640

TAG application 15 1 120 120 1,800

TAG management 120 1 50 50 6,000

Satisfaction Surveys 5 1 200 200 1,000

TOTAL 107920

Labor costs to EPA were calculated using a weighted average hourly rate for government employees. 

The assumption is made that the typical division of labor for these activities is 10% managerial, 80% 

technical, and 10% support. These values are used to calculate a weighted hourly labor rate based on 

the current GS Schedule using values for GS-13, GS-11, GS-7, all Step 5, plus 60% of each salary to 

account for benefits. The average hourly rate is $41.23. The annual labor cost for each activity that 

involves use of Federal hours is calculated using this labor rate. Labor costs to EPA are the only 

Federal costs accounted for oversight of State activities. The total estimated annual costs incurred by 

EPA for oversight of State activities is $123,640 (Table 7). The total estimated annual costs EPA 

incurs for Community Involvement activities is $7,964,366 (Table 8).
Table 7: Estimated Costs for Federal Oversight of State Activities

Activity

Total 

Statelead 

Activities 

at Sites 

per year

Hours 

per 

Activity 

per 

year

Hourly 

Labor 

Rate

Annual 

Labor 

Costs 

per 

Activity 

*

Annual 

Capital, 

O&M, 

Nonlabor 

Costs 

per 

Activity

Total 

Annual

Costs 

per 

Activity

Total 

Annual 

Labor 

Costs 

for all 

Sites *

Total 

Annual 

Capital, 

O&M, Nonlabor 

Costs for 

all Sites

Total 

Annual 

Costs for 

all Sites

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

Proposed 

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

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

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

Administrative 

Record

100 2 $41.23 82 $0 82 8200 $0 8200

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

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

Fact Sheets

400 2 $41.23 82 $0 82 32800 $0 32800

Focus 

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

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

SUBTOTAL 123,640

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

* Rounded to the nearest whole dollar TOTAL $ 3,022,382
Table 8: Estimated Costs to the Federal Government for Community Activities

Activity

Total 

Activities 

at 

Federal 

lead 

Sites/yr

Hours per 

Activity 

per year

Hourly 

Labor 

Rate

Annual 

Labor 

Costs per 

Activity *

Annual 

Capital 

Costs per 

Activity

Annual 

Non-labor 

Cost per 

Activity

Annual 

O&M 

Costs per 

Activity

Total 

Annual 

Costs per

Activity

Total 

Annual 

Labor 

Costs for 

all Sites *

Admin. 

Record 440 40 $41.23 1,649 $0 $0 1366 3,015 725,560 

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

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

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

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

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

TAG 

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

TAG 

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

Satisfaction 

Surveys 5 200 $41.23 8,246 $0 $0 $6,256 14,502 41,230 

* Rounded to the nearest whole dollar

 

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

The respondent universe is based on the number of State-lead and active Superfund sites predicted for 

the three year period of the ICR. These numbers come from Superfund data about past activities and 

scheduled plans for future activities. The number of community members involved at each site clearly 

varies and this respondent universe is based on past program averages. The total burden and cost to 

each respondent is a summation of all activities described in detail in previous sections of this 

document.

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

(i) Respondent tally
The total burden hours and costs displayed in the table below reflects the combined burden and costs 

on both categories of respondents: States at State-lead sites and individual community members 

participating voluntarily at Superfund sites. Community costs of $511,170 (Table 4) are all 

hypothetical and do not represent the actual expenditure of dollars because all participation is 

voluntary. The majority of State costs may be paid through various grants from the Federal 

government. The actual costs to States is $61,245 (Table 3) for the ARAR analysis.

 Table 9: Total Respondent Burden Hours and Costs

Respondent Annual 

Burden

Annual Cost Total 3 yr. 

Burden

Total 3 yr. 

Cost

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

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

Total 71,165 $572,415 213,495 $1,717,245
(ii) Agency tally

The total burden and costs represented in the following table is the amount EPA expects to spend 

directly in oversight of State activities and the information gathering activities EPA conducts with 

communities at Superfund sites.

 Table 10: Total Federal Agency Burden Hours and Costs

Agency Annual 

Burden

Annual Cost Total 3 yr. 

Burden

Total 3 yr. 

Cost

Federal OversightStates3,005 $3,022,382 9,015 $9,067,146

FederalCommunity 

Activities

107,920 $7,964,366 323,760 $23,893,098

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

(iii) Variations in the annual bottom line

Variations to the annual bottom line numbers may occur as sites enter different phases of the remedial 

process in different years. Additional, activities that depend almost exclusively on the need at the site, 

such as fact sheet, are likely to vary year to year. However, EPA expects the relative number of annual 

activities to be similar in each year of the ICR period.

6(f) Reasons for change in burden

There is no change in the burden for this ICR. Cost models were updated to reflect wage inflation. 

While currently approved O&M costs are listed as $850,000, and are updated in the current ICR, they 

have been removed from the cost estimate listed above because they are reimbursed in full by the 

Federal government, and thus effectively impose no burden on state governments.

The total estimated annual burden hours for respondents are the same as the previous ICR (71,165 

hours). The total estimated annual costs to respondents increased by $19,206. State burden hours for 

identification of ARARs is estimated to be the same (33 hours) and costs increased by $3,716. This 

increase is due to adjustment for hourly labor rate from $38.74 to $41.23. The estimated amount that 

will actually be funded with State monies is $61,245. Community member burden hours is estimated 

to be the same (30,980 hours) and costs increased by $15,490 due to adjustment for hourly labor rate 

from $16 to $16.50.
6(g) Burden statement

The total estimated annual burden hours placed on State governments for all remedial activities is 

40,185. The total estimated annual burden hours placed on communities is 30,980. Total burden 

hours placed on 7,970 respondents through 8,498 responses is 71,165 hours. The annual public 

reporting and recordkeeping burden for this collection of information is estimated to average 8.4 hours 

per response. 

The ICR covers an array of activities that may occur at various discrete points in time or periodically 

throughout the entire Superfund remedial process. Therefore, the number of likely respondents per 

Superfund site in both the State and community categories will vary by site depending on its position 

in the remedial process, the lead agency, and the level of community involvement warranted. 

Additionally, the frequency of response to all activities covered by the ICR can only be described as 

occurring when required to meet CERCLA requirements and the needs of the Superfund site and the 

community. 

Burden means the total time, effort, or financial resources expended by persons to generate, maintain, 

retain, or disclose or provide information to or for a Federal agency. This includes the time needed to 

review instructions; develop, acquire, install, and utilize technology and systems for the purposes of 

collecting, validating, and verifying information, processing and maintaining information, and 

disclosing and providing information; adjust the existing ways to comply with any previously 

applicable instructions and requirements; train personnel to be able to respond to a collection of 

information; search data sources; complete and review the collection of information; and transmit or 

otherwise disclose the information. An agency may not conduct or sponsor, and a person is not 

required to respond to, a collection of information unless it displays a currently valid OMB control 

number. The OMB control numbers for EPA's regulations are listed in 40 CFR part 9 and 48 CFR 

chapter 15. 

To comment on the Agency's need for this information, the accuracy of the provided burden estimates, 

and any suggested methods for minimizing respondent burden, including the use of automated 

collection techniques, EPA has established a public docket for this ICR under Docket ID No. EPAHQ-SFUND-2007-0707. This docket is available for public viewing at the Superfund Docket in the 

EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW, Washington, 

DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday 

through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-

1744, and the telephone number for the Superfund Docket is (202) 566-0276. An electronic version of 

the public docket is available at http://www.regulations.gov. Use www.regulations.gov to submit or 

view public comments, access the index listing of the contents of the public docket, and access those 

documents in the public docket that are available electronically. 

Once in the system, select “search,” then key in the docket ID number identified above. Comments 

can also be sent to the Office of Information and Regulatory Affairs, Office of Management and 

Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Office for EPA. Please 

include the EPA Docket ID No. EPA-HQ-SFUND-2007-0707 and OMB control number 2050-0096 in 

any correspondence. 
Part B.

This part is not applicable because no statistical methods were used in collecting this 

information.