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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 community 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 whenever an 

impacted community may require additional technical assistance. EPA believes involvement of the 

members 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 assistance; 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 officials, 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 the 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 interviews and give a voice to those who have not had the opportunity to fully 

engage in the Superfund cleanup process. 
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If the TANA is being conducted after the CIP community interviews have been completed, the CIC may 

select interviewees from those participating in the original 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 be 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 interviews 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 the community member’s concerns. It

is strongly suggested that EPA employees conduct the TANA interviews. Whenever a contractor conducts 

the TANA interviews, EPA personnel will be present. The interviewer will ask each stakeholder a series 

of questions, with 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. 

CICs 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 and 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. 

Will 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 and 
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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 questions 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 

Notice, which describes the ICR and provides numbers for burden hours and costs and solicits public 

comment, was published on December 12, 2012. A 60 day comment period was given; 0 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. 

A notice seeking public comment for this information collection was posted on Dec 12, 2012 under 77 FR 

74002. The comment period closed on Feb 11, 2013 and no comments were received. 

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 offices. 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 revise a CIP. 

Definitive questions have been added to the Community Interviews tool guiding the CIC to only conduct a 

formalized TANA when an impacted community has unaddressed technical assistance needs and those 

needs could not be effectively addressed through informal technical assistance provided directly by EPA 

staff (e.g., fact sheets, workshops, availability sessions, etc.) For the majority of sites, informal technical 
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assistance will be sufficient to meet the needs of the community. Information collection through TANAs 

will be conducted the minimal amount necessary to ensure the technical assistance needs of impacted 

communities are appropriately assessed and addressed.

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. Responsibility 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 

members voluntarily participate in community involvement activities throughout the remedial phase of 

the Superfund process. SIC Codes are OSHA’s Standard Industrial 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 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 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
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TANAs will be conducted by CICs 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 are 

not required by statute or regulation and for most sites informal technical assistance (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 

members 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 not 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 to 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 colleges, universities and 

nonprofits currently 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 benefit 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., TAG coordinators, TASC work assignment 

managers, nonprofit staff, university technical assistance provider, etc.) 

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

5(a) Agency activities
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At any remedial or removal site where the impacted community may have unaddressed 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. 

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; however, 

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-specific 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) Estimating 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 

members and Agency 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. 
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The estimated number of respondents reported for this information collection is 250. 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.

(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 

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 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 250 hours.

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.

(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 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

Community members have no O&M, non-labor or capital costs. 

(iii)Annualizing capital costs

No capital costs are incurred during the activities described in this ICR.
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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

250 1 $19.60 $19.60 $0 $19.60 $4,900 $0 $4,900
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6(c) Estimating Agency burden and cost

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

Community Involvement activities. These activities include preparing for and conducting TANAs with 

community members impacted 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 for 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 summed ($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).
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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 

NonLabor 

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 

NonLabor 

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 

TANA 

interviews 250 1 $68.80 $69 $0 $0 $0 $69 $17,250 $0 $0 $0 $17,250

Creating 

TANA 

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.
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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 because 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 Burden Annual Cost

Total 3 yr. 

Burden Total 3 yr. Cost

FederalCommunity 

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 needs at the site. EPA expects the relative number of annual activities to be similar in 

each year of the ICR period. 
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6(f) Reasons for change 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

Burden Statement: The annual public reporting and recordkeeping burden for this collection of 

information is estimated to average one hour per response. 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.

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

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

collection techniques, EPA has established a public docket for this ICR under Docket ID Number EPAHQ-SFUND-2012-0578, which is available for online viewing at www.regulations.gov, or in person 

viewing at the Superfund Docket in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 

Constitution Avenue, NW, Washington, D.C. The EPA Docket Center Public Reading Room is open 

from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for 

the Reading Room is (202) 566-1744, and the telephone number for the Superfund Docket is (202) 566-

0276. An electronic version of the public docket is available at www.regulations.gov. This site can be 

used to submit or view public comments, access the index listing of the contents of the public docket, and 

to access those documents in the public docket that are available electronically. When in the system, 

select “search,” then key in the Docket ID Number identified above. Also, you can send comments to the 

Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 

Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number 

EPA-HQ-SFUND-2012-0578 and OMB Control Number 2050-NEW in any correspondence.

Part B.

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