SUPPORTING STATEMENT FOR EPA’s 

INFORMATION COLLECTION REQUEST (ICR) 

UNDER TITLE I OF THE MARINE PROTECTION, RESEARCH, AND 

SANCTUARIES ACT

Prepared by 

Environmental Protection Agency 

Oceans and Coastal Protection Division 

Washington, D.C.

Published Draft 

March, 2016

Prepared by Oceans and Coastal Protection Division of the Office of Wetlands, Oceans, 

and Watersheds
2 

SUPPORTING STATEMENT FOR THE COLLECTION OF INFORMATION 

UNDER TITLE I OF THE MARINE PROTECTION, RESEARCH, AND 

SANCTUARIES ACT

ICR # 0824.06 

OMB Control # 2040-0008 

Introduction 

This document supports EPA’s compliance with requirements of the Paperwork Reduction Act 

for the Marine Protection, Research, and Sanctuaries Act (MPRSA). The purposes of the 

Paperwork Reduction Act of 1980 (PRA) (P. L. 96-511) and implementing regulations 

(44 U.S.C. Chapter 35) are to: 1) minimize the federal paperwork burden for small businesses, 

state and local governments, and other individuals; 2) minimize the Federal government's cost of 

collecting, maintaining, using, and disseminating information; and 3) maximize the usefulness of 

information collected by federal agencies. 

This Information Collection Request (ICR) is made by the Oceans and Coastal Protection 

Division in the Office of Water, EPA Headquarters. The proposed information collection 

activities are accomplished by the least burdensome and least costly means and are not 

duplicated by other sources. 

EPA administers the MPRSA, as amended. The MPRSA is also referred to as the Ocean 

Dumping Act. The MPRSA regulates the dumping and transportation for the purpose of dumping 

of material into ocean waters. The collections of information described in this document derive 

from EPA's authorities under and responsibilities in implementing the MPRSA. 

EPA plays a primary role in protecting and preserving our ocean and coastal resources from 

dumping at sea. The Ocean and Coastal Protection Division in the Office of Water at EPA 

Headquarters and the seven coastal EPA Regional Offices (Regions 1, 2, 3, 4, 6, 9 and 10) jointly 

administer EPA’s Ocean Dumping Management Program. Ocean dumping cannot occur unless a 

permit is issued under the MPRSA. EPA is responsible for issuing ocean dumping permits for all 

materials except dredged material. The U.S. Army Corps of Engineers (USACE) is responsible 

for issuing ocean dumping permits for dredged material using EPA’s ocean dumping criteria. 

Ocean dumping permits for dredged material (and federal projects involving ocean dumping of 

dredged material) are subject to EPA review and concurrence. EPA is also responsible for 

designating and managing ocean disposal sites for the disposal of wastes and other materials, and 

establishing Site Management and Monitoring Plans (SMMPs) for ocean disposal sites. 

EPA regulations establish ocean dumping criteria (hereinafter the “Ocean Dumping Criteria”) for 

the evaluation of MPRSA permit applications. The Ocean Dumping Criteria consider, among 

other things: the environmental impact of the dumping; the need for the dumping; the effect of 

the dumping on aesthetic, recreational, or economic values; land-based alternatives to ocean 

dumping; and the adverse effects of the dumping on other uses of the ocean. The Ocean 

Dumping Criteria are codified in 40 CFR parts 227-228. 

 

Congress vested EPA with the authority and discretion to issue ocean dumping permits for all 
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materials except dredged material. The other materials for which EPA issues permits, and that 

are currently dumped in the ocean include human remains, vessels, and fish processing wastes. 

Section 101 of the MPRSA (33 U.S.C. 1411) prohibits all ocean dumping activities except those 

activities authorized by a permit. Dumping of some materials is prohibited by the statute and 

may not be permitted. Under MPRSA section 102, EPA can issue various types of permits: 

special, general, research (including incineration at sea),1

 or emergency permits. EPA may issue 

special permits to applicants seeking to dispose of materials in the ocean. EPA may issue a 

general permit for materials that will have a minimal adverse environmental impact and are 

generally disposed of in small quantities. EPA may issue research permits for the dumping of 

materials as part of a research project when it is determined that the scientific merit of the 

proposed project outweighs the potential environmental or other damage that may result 

from dumping. EPA may issue emergency permits only in situations where the material to be 

disposed poses “an unacceptable risk relating to human health and admits of no other feasible 

solution.” “Emergency” refers to situations requiring action with a marked sense of urgency, but 

is not limited to circumstances requiring immediate action. 

While not relevant to this ICR, USACE issues ocean dumping permits for dredged material (and 

conducts federal projects associated with ocean dumping of dredged material) using the Ocean 

Dumping Criteria, and dumping under those permits and federal projects are subject to EPA 

review and concurrence. 

The United States is a Contracting Party to the London Convention on the Prevention of Marine 

Pollution by Dumping of Wastes and Other Matter, 1972. The United States implements the 

London Convention through the MPRSA. In compliance with treaty obligations, the United 

States (through EPA and USACE) provides annual reports to the treaty organization regarding 

the ocean dumping of materials authorized over the preceding year. 

Lastly, EPA works closely with USACE and the U.S. Coast Guard to implement the MPRSA. 

Compliance and enforcement of the MPRSA are the responsibilities of EPA, USACE, and the 

U.S. Coast Guard. EPA also works with the other federal agencies, as needed, on particular 

issues (e.g., the National Oceanic and Atmospheric Administration (NOAA) in mapping vessels 

disposed under the vessel disposal general permit). 

Organization of Information Collection Request Statement 

This document follows the format for ICR outlined in the Information Collection Review 

Handbook (Office of Management and Budget, 1989) and the Instructions for Standard Form 83 

(revised version dated September 1983). No exceptions to this format are taken. Those topics 

identified in the Information Collection Review Handbook, which are not relevant to this 

application, are noted and the basis for this determination stated. EPA's Information Resources 

Management Policy Manual (July 1987), Regulation Development in EPA (September 1992), 

 

1 For the purposes of this ICR, incineration at sea permits are included in the “research permit” category of MPRSA permits. 

Under 40 CFR 220.3(f), “permits for incineration of wastes at sea will be issued only as research permits until specific criteria to 

regulate this type of disposal are promulgated, except in those cases where studies on the waste, the incineration method and 

vessel, and the site have been conducted and the site has been designated for incineration at sea in accordance with the 

procedures of § 228.4(b) of this chapter. In all other respects the requirements of parts 220 through 228 apply.” The opportunity 

for research permits for incineration at sea excludes the incineration of industrial wastes, which may not be ocean dumped as a 

result of the Ocean Dumping Ban Act amendments to the MPRSA. 
4 

and EPA's Instructions for Preparing Information Collection Requests (June 1992) also guided 

the development of this document. 

This ICR is organized into two chapters. Both chapters address activities that are subject to the 

requirements of the PRA. Chapters 1 and 2 address ocean dumping activities for materials other 

than dredged material. 

• Chapter 1 analyzes activities associated with new MPRSA special, general, research, and 

emergency permits. In addition to the permits themselves, this chapter also includes 

reporting requirements associated with dumping of material for an emergency to 

safeguard life at sea, where no permit is required. 

• Chapter 2 analyzes activities associated with the two existing general permits that have 

applicable collections of information within the meaning of the Paper Work Reduction 

Act. Currently, there are two existing general permits with applicable collections of 

information within the meaning of the Paperwork Reduction Act: 1) burial at 

sea general permit, and 2) transportation and disposal of vessels general permit. 

EPA has taken a conservative approach, specifically to overstate potential burden and costs, 

throughout this analysis, and all information collection and record keeping requirements are 

included in this analysis. 

This ICR was developed based on program office knowledge of the process, a review of 

collections of information similar to those being called for under this ICR, a review of EPA 

regional practices in collecting information, a review of the literature on the ocean dumping 

program and, ultimately, by an independent review by four likely respondents. 

Chapter 1. Supporting Statement for the Collection of Information for 

Special, General, Research, and Emergency Ocean Dumping Permits. 

SECTION 1: Identification of the Information Collection 

1(a): Title of the Information Collection 

Collection of Information for Special, Research, Emergency, and new General (other than for 

Burial at Sea and for Vessel Disposal) Ocean Dumping Permits 

1(b): Short Characterization/Abstract 

Chapter 1 of this ICR covers collections of information associated with new ocean dumping 

permits. This chapter is organized by each category of ocean dumping permit according to EPA's 

regulations: 

• Special 

• General (other than for burial at sea and for vessel disposal) 

• Research 

• Emergency 
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In addition to these permits, this chapter includes the following reporting requirements where no 

permit is required: 

• Emergency to Safeguard Life at Sea 

SECTION 2: Need for and Use of the Collection 

2(a): Need/Authority for the Collection 

Section 104(e) of the MPRSA authorizes EPA to collect permit application information. The 

information collected is codified in 40 CFR 221.1 based on the category of permit sought 

(special, general, research, and emergency). EPA collects this information to ensure that ocean 

dumping is appropriately regulated and will not harm human health or the marine environment, 

based on applying the Ocean Dumping Criteria. To meet United States’ reporting obligation 

under the London Convention, EPA also reports some of this information in the annual United 

States Ocean Dumping Report. 

2(b): Practical Utility/Users of the Data 

EPA uses ocean dumping information to make decisions regarding whether to issue or deny a 

permit. This information is also used to develop the conditions in ocean dumping permits issued 

by EPA in order to ensure consistency with the Ocean Dumping Criteria. EPA uses monitoring 

and reporting data to assess compliance with ocean dumping permits, including associated 

monitoring activities. 

SECTION 3: Non-duplication, Public Notice, Consultations, and Other 

Collection Criteria 

3(a): Non-duplication 

All information requested from respondents under this ICR is required to ensure that material 

proposed for ocean dumping is appropriately regulated and does not harm human health or the 

marine environment, based on applying the Ocean Dumping Criteria. The information is not 

generally available from other sources. 

3(b): Public Notice Required Prior to ICR Submission to the Office of Management and 

Budget (OMB) 

Public comments were previously requested via the Federal Register (81 FR 484) on January 06, 

2016 during a 60-day comment period. No Comments were received. 

3(c): Consultations 

The permits in this chapter occur infrequently and are on a case-by-case basis. No entities were 

identified for this chapter of the ICR. Burden estimates for this chapter are based on best 

professional judgement. 

3(d): Effects of Less Frequent Collection 

 The application is only filed once in order to obtain the benefit of a permit and less frequent 

filing (i.e., no application) would preclude EPA from providing the benefit. 

3(e): General Guidelines 

The information collection activities discussed in this chapter of the ICR are fully consistent with 
6 

all guidelines in 5 CFR § 1320.5(d)(2). 

3(f): Confidentiality 

To the extent that information collection activities discussed in this chapter of the ICR require 

the submission of any confidential information, EPA ensures compliance with the Agency's 

confidentiality regulations. 40 CFR 2.201 et seq. 

3(g): Sensitive Questions 

The information collection activities discussed in this chapter of the ICR do not require the 

submission of any sensitive information. 

SECTION 4: The Respondents and the Information Requested 

4(a): Respondents/SIC Codes 

Any private person or entity, or any officer, employee, agent, department, agency, or 

instrumentality of the federal government, of any state or local unit of government, or of any 

foreign government may apply for an MPRSA permit. This broad range of potential respondents 

precludes EPA from identifying particular respondents based on SIC/NAICS Codes. 

4(b): Information Requested 

As described above, EPA seeks information necessary to evaluate a permit application, including 

reporting requirements such as records, reports, and monitoring information that may be 

prescribed as part of an ocean dumping permit. 

Permit Application: 

Pursuant to 40 CFR 221.1-221.2, and as part of the initial application, EPA requires all ocean 

dumping permit applicants to supply the following information: 

• Name and address of applicant. 

• Name of the person or firm transporting the material for dumping, the name of the 

person(s) or firm(s) producing or processing all materials to be transported for dumping, 

and the name or other identification, and usual location, of the conveyance to be used in 

the transportation and dumping of the material to be dumped, including information on 

the transporting vessel's communications and navigation equipment. 

• Adequate physical and chemical description of material to be dumped, including results 

of tests necessary to apply the Ocean Dumping Criteria, and the number, size, and 

physical configuration of any containers to be dumped. 

• Quantity of material to be dumped. 

• Proposed dates and times of dumping. 

• Proposed dump site, and, in the event the proposed dump site is not designated in 

subchapter H, detailed physical, chemical and biological information relating to the 

proposed dump site and sufficient to support its designation as a site according to part 

228 of subchapter H. 

• Proposed method of releasing the material at the dump site and means by which the 

disposal rate can be controlled, as required. 

• Identification of the specific process or activity producing the material, 
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• Description of the manner in which the type of material proposed to be dumped has been 

previously disposed of by or on behalf of the person(s) or firm(s) producing such 

material. 

• A statement of the need for the proposed dumping and an evaluation of short- and longterm alternative means of disposal, treatment or recycle of the material. Means of 

disposal shall include but is not limited to: landfill, well injection, incineration, spread of 

material over open ground; biological, chemical or physical treatment; recovery and 

recycle of material, and storage. The statement shall also include an analysis of the 

availability and environmental impact of such alternatives. 

• An assessment of the anticipated environmental impact of the proposed dumping, 

including but not limited to: the relative duration of the effect of the proposed dumping 

on the marine environment, navigation, living and non-living marine resource 

exploitation, scientific study, recreation and other uses of the ocean. 

Under 40 CFR 222.2, after EPA notifies an applicant that its permit application is complete, EPA 

makes a tentative determination whether the proposed ocean dumping activity meets the Ocean 

Dumping Criteria. A final determination is made after the opportunity for a public hearing or 

after a hearing is conducted. 

EPA manages each ocean dumping permit over the term of the permit. EPA’s management role 

may involve reviewing periodic reports, site visits, and other measures on a permit-by-permit 

basis in compliance with 40 CFR part 224. 

Each permittee must maintain complete records of the following information in compliance with 

40 CFR 224.1: 

• The physical and chemical characteristics of the material dumped pursuant to the permit. 

• The precise times and locations of the dumping. 

• Any other information required as a condition of the permit by EPA. 

Emergency to Safeguard Life at Sea: Situations involving an emergency to safeguard life at 

sea are excluded from the ocean dumping regulations under 40 CFR 220.1(c). The exclusion, 

however, is subject to the reporting requirement contained in 40 CFR 224.2(b). The owner or 

operator of the vessel or aircraft from which ocean dumping occurred under 40 CFR 220.1(c)(4) 

must, as soon as feasible: 

• Inform the Administrator, Regional Administrator, or nearest Coast Guard district of the 

incident.

• Within 10 days, file a written report to the Administrator or Regional Administrator with 

the following information. 

o The physical and chemical characteristics of the material dumped. 

o The precise times and locations of dumping. 

o Any other information required by the Administrator or the Regional 

Administrator.

o A complete description of the circumstances under which the dumping occurred, 

including how human life at sea was in danger and how the emergency dumping 

reduced that danger. 
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• If the material dumped included containers, the vessel owner or operator shall 

immediately request the U.S. Coast Guard to publish in the local Notice to Mariners the 

dumping location, the type of container, and whether the contents are toxic or explosive. 

• Notify the Food and Drug Administration, Shellfish Sanitation Branch, Washington, DC 

20204, as soon as possible. 

SECTION 5: The Information Collected — Agency Activities, Collection 

Methodology and Information Management 

5(a): Agency Activities 

EPA collects the information submitted by applicants as part of an initial ocean dumping permit 

application under 40 CFR 221.1-221.2. After EPA issues an ocean dumping permit, EPA collects 

records and reports as described in 40 CFR 224.1-224.2. 

5(b): Collection Methodology and Information Management 

EPA’s collection activities begin with the receipt of an ocean dumping permit application. 

Applicants for general2, special, emergency, and research permits under section 102 of the 

MPRSA submit a formal application to either EPA Headquarters or to the appropriate Regional 

Office, authorized by 40 CFR 220.4 to act on the application. Under 40 CFR 222.2(a), upon 

receipt of an initial application, the Administrator or the Regional Administrator, has 30 days to 

notify the applicant in writing whether or not the application is complete or whether additional 

information is needed. 

Pursuant to 40 CFR 222.2(b), and after EPA provides notice that an application is complete, EPA 

makes a tentative determination to issue or to deny the permit. If EPA proposes to issue the 

permit, it also provides notice of: 

• proposed time limitations, if any; 

• proposed rate of discharge from the barge or vessel transporting the material; 

• proposed dumping site; and 

• a brief description of any other proposed conditions determined to be appropriate for 

inclusion in the permit. 

EPA then develops the terms and conditions of the permit consistent with the ocean dumping 

regulations and finalizes the permit. Notice of tentative determination is required for every 

complete application for a general, special, and research permit. In the case of an emergency 

permit, the Administrator determines that the emergency poses an unacceptable risk relating to 

human health, that no other feasible solution exists, and that the public interest requires the 

issuance of an emergency permit as soon as possible. Notice of issuance of the emergency permit 

is published as soon as practicable after issuance. Upon receipt, and until a final determination to 

grant or deny a general, special, research or emergency permit, EPA may collect additional 

information from the applicant to make its decision. 

EPA collects information related to ocean dumping permits and monitoring information to 

determine compliance with permit conditions and to evaluate the impact of the disposal on the 

 

2 EPA may issue a general permit upon application by an interested person or may be issue without such an application. 40 CFR 

220.3(a).
9 

marine environment. These permits require the permittee to submit the information to the 

Administrator or the Regional Administrator. This information also helps EPA manage the dump 

site. All of the information pertaining to a permit will be stored in a database. 

5(c): Small Entity Flexibility 

The collections of information described in this chapter of the ICR will only affect a de minimis

number of small entities. Since enactment of the Ocean Dumping Ban Act, amendment 

prohibiting the ocean dumping of industrial wastes, EPA has received very few ocean dumping 

permit applications from small entities. The small entities that do dump materials in the ocean 

are, for the most part, authorized under the general permits for vessel disposal and for burial at 

sea, neither of which requires an individual application, but instead mere notice. Burial at sea and 

vessel disposal permits are specifically discussed in chapter 2. Given the lack of interest and 

inquiries regarding ocean dumping permits from small entities, this ICR is not excessively 

burdensome on small entities. 

5(d): Collection Schedule 

Permit applications for MPRSA special, general, research, and emergency permits occur on 

infrequent intervals, approximately 1 to 3 of each per every 10 years. The requirements for a 

permit application are described in 40 CFR part 222. If a permit is issued, or material is dumped 

for an emergency to safeguard life at sea, records and reporting are required according to 40 CFR 

224.1-224.2. 

SECTION 6: Estimating the Burden Hours and Cost of the Collection 

6(a): Estimating Respondent Burden 

This section estimates the relative annual burden (time in hours) and burden per response for 

each permit category, as well as for emergencies to safeguard life at sea. 

Information collection burden hours were reviewed by respondents who had previously 

participated in the permit application process. The estimated burden hours reflect the burden 

(time in hours) that an individual respondent will require to complete an activity needed for an 

ocean dumping permit application. The level of effort estimates presented for these tables were 

reviewed by EPA staff and managers, all of whom have experience in assessing information 

collection work similar to that described in this chapter of this ICR. An effort has been made to 

consistently use conservative estimates. 

In summary, the estimated burden per respondent to complete an application and reporting 

requirements is 1374.0 hours for a special permit, 542.0 hours for a new general permit, 1374.0 

hours for a research permit and 597 hours for an emergency permit. The estimated burden per 

respondent to complete the necessary reporting requirements for an emergency to safeguard life 

at sea is 70 hours. The total burden per year was calculated by multiplying the burden hours per 

response by the number of respondents, which corresponds to the number of permit applications 

the EPA expects per year. This analysis is shown in Tables 2 through 6. See section 6(d) of 

chapter 1 of this supporting statement for a description of how the respondent numbers (i.e., 

respondent universe) were estimated. 
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6(b): Estimating Respondent Costs 

To estimate the labor costs, EPA used labor and cost-rate data listed on the U.S. Bureau of Labor 

Statistics (BLS) Compensation Cost Trends homepage.3

 The BLS homepage includes links to 

publications and reports related to labor costs by category. Given the broad range of potential 

respondents, EPA used average rates for the following three general respondent occupation 

categories to derive its burden and cost estimates:

• Management occupations4 (Management)

• Environmental scientists5

 (Technical)

• Office and administrative support occupations6 (Clerical)

EPA used the hourly figures listed by BLS to approximate the labor burdened hourly rates for the 

occupational categories contained in this chapter of the ICR. These are listed in Table 1.7

Table 1. Respondent Labor Costs: Hourly Loaded Wage Estimate of Affected Industry 

BLS: 

Occupational 

Earnings (May, 

2014) 

ICR Respondent 

Job Classification 

Titles 

Hourly 

Rate 

(USD) Benefits Factor 

Loaded Hourly 

Rate (USD) 

Management 

Occupations 

Management $54.08/hr × 1.3 $70.30/hr 

Environmental 

Scientists 

Technical $34.64/hr × 1.3 $45.03/hr 

Office and 

administrative 

support 

occupations 

Clerical $17.08/hr × 1.3 $22.20/hr 

EPA predicts no respondent capital or start-up costs associated with the activities described in 

this chapter of the ICR. Non-labor operations and maintenance (O&M) include the cost of 

contracted services expected to be needed, where the cost is not tied to labor hours for the 

respondent or EPA. These costs in include costs for photocopying, postage, telephone charges, as 

well as major activities associated with ocean monitoring or laboratory analyses. O&M expenses 

listed in Tables 2 through 6 are predominantly internet (including email), printing, photocopy, 

 

3 The BLS webpage is available on-line at: http://www.bls.gov/ncs/ect/.

4

 For management labor costs, EPA used the website titled Occupational Employment and Wages, May 2014, 

available online at: http://www.bls.gov/oes/current/oes110000.htm. 

5

 For technical labor costs, EPA used the website titled Occupational Employment and Wages, May 2014, available 

online at: http://www.bls.gov/oes/current/oes192041.htm. 

6

 For office and administrative support occupations, EPA used the website titled Occupational Employment and 

Wages, May 2014, available online at: http://www.bls.gov/oes/current/oes430000.htm.

7 The above labor rate data are “fully burdened” or “hourly loaded” and include wages/salaries, and overhead and 

fringe benefits of the affected industry. EPA added 30 percent to the indicated average hourly wage to allow for 

overhead and fringe benefits. Only fully burdened BLS labor cost data are used in the analysis described in all 

chapters of the ICR.
11 

postage, and related paperwork distribution expenses, as well as contracted services. 

Respondent costs are compiled in Tables 2 through 6 for each ocean dumping permit category 

and for emergencies to safeguard life at sea. In summary, the estimated labor cost per respondent 

to complete an application and its corresponding reporting requirements is $59,532.12 for special 

permits, $23,755.35 for a new general permit, $59,532.12 for research permits, and $26,263.72 

for emergency permits. The estimated cost per respondent to complete the reporting 

requirements for an emergency to safeguard life at sea is $3,168.31. Annualized costs are based 

on the number of permits expected per year and include both labor costs and non-labor O&M 

costs. 
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Table 2. Respondent Burden and Cost for Special Permits 

Special Permit - 

Information 

Collection 

Activity 

Hours and Costs Per Response Total Hours and Costs Per 

Year 

Mgmt. 

$70.03/

hr 

Technical 

$45.03/ 

hr 

Clerical 

$22.20/ 

hr 

Total 

Hours/ 

Response 

Labor 

Cost/ 

Response 

O & M 

Cost 

($) 

Number 

Responses/ 

Year 

Total 

Hours/ 

Year 

Total 

Cost/ 

Year ($) 

1. Application (40 

CFR 221.1) 

 

a. Read 

regulations/ 

guidance 1.00 7.00 2.00 10.00 $429.91 $0.00 0.30 3.00 $128.97

b. Plan Activities 

20.00 100.00 20.00 140.00 $6,353.00 $0.00 0.30 42.00 $1,905.90

c. Create/obtain 

new information 20.00 500.00 18.00 538.00 $24,320.60 $300,000.00* 0.30 161.40 $97,296.18

d. Gather existing 

information 20.00 120.00 40.00 180.00 $7,697.60 $0.00 0.30 54.00 $2,309.28

e. Complete 

application 16.00 100.00 60.00 176.00 $6,959.80 $10.00 0.30 52.80 $2,090.94

2. Reporting 

Requirements (40 

CFR 224.1-224.2) 

a. Read permit/ 

regulations/ 

guidance 1.00 7.00 2.00 10.00 $429.91 $0.00 0.30 3.00 $128.97

b. Record 

dumping and 

monitoring 

activity 

information 20.00 150.00 40.00 210.00 $9,048.50 $0.00 0.30 63.00 $2,714.55

c. Submit 

dumping and 

monitoring reports 10.00 60.00 40.00 110.00 $4,292.80 $10.00 0.30 33.00 $1,290.84

Subtotal (hours 

and costs) 

108.00 1044.00 222.00 1374.00 $59,532.12 $300,020.00 0.30* 412.20 $107,865.64

*Assumes the cost for five samples of material proposed for dumping to be collected and analyzed based

on the ocean dumping regulations (bioassays for toxicity and bioaccumulation, chemical analyses for 

water quality) procedures in the ocean dumping testing manual. 

 
13 

Table 3. Respondent Burden and Cost for General Permits 

General Permit - 

Information Collection 

Activity

Hours and Costs Per Response Total Hours and Costs 

Per Year 

Mgmt. 

$70.03/ 

hr 

Technical 

$45.03/ 

hr 

Clerical 

$22.20/ 

hr 

Total 

 Hours/ 

Response 

Labor 

Cost/ 

Response 

O & M 

Cost ($) 

Number 

Responses/ 

Year 

Total 

Hours/

Year 

Total Cost/ 

Year ($) 

1. Application (40 CFR 

221.1) 

 

a. Read regulations/ 

guidance 1.00 1.00 2.00 10.00 $429.91 $0.00 0.10 1.00 $42.99

b. Plan Activities 

1.00 50.00 10.00 70.00 $3,176.50 $0.00 0.10 7.00 $317.65

c. Create/obtain new 

information 

10.00 250.00 9.00 269.00 $12,160.30 $0.00 0.10 26.90 $1,216.03

d. Gather existing 

information 10.00 60.00 20.00 90.00 $3,848.80 $0.00 0.10 9.00 $384.88

e. Complete application 

8.00 50.00 30.00 88.0 $3,479.90 $10.00 0.10 8.80 $348.99

2. Reporting 

Requirements (40 CFR 

224.1-224.2) 

a. Read permit/ 

regulations/ guidance 

1.00 2.00 0.00 3.00 $160.36 $0.00 0.10 0.30 $16.04

b. Record dumping and 

monitoring activity 

information 2.00 5.00 3.00 10.00 $432.35 $0.00 0.10 1.00 $43.24

c. Submit dumping and 

monitoring report(s) 

0.00 1.00 1.00 2.00 $67.23 $10.00 0.10 0.20 $7.72

Subtotal (hours and 

costs) 

42.00 425.00 75.00 542.00 $23,755.35 $20.00 0.10 54.20 $2,377.54

 
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Table 4. Respondent Burden and Cost for Research Permits 

Research Permit - 

Information 

Collection Activity

Hours and Costs Per Response Total Hours and Costs Per 

Year 

Mgmt. 

$70.03/ 

hr

Technical 

$45.03/ 

hr

Clerical 

$22.20/ 

hr

Total 

Hours/ 

Response 

Labor 

Cost/ 

Response 

O & M 

Cost 

 ($) 

Number 

Responses/

 Year 

Total 

Hours/

Year 

Total Cost/

Year ($) 

1. Application (40 

CFR 221.1) 

 

 

a. Read regulations/ 

guidance 

1.00 7.00 2.00 10.00 $429.91 $0.00 0.10 1.00 $42.99

b. Plan Activities 

20.00 100.00 20.00 140.00 $6,353.00 $0.00 0.10 14.00 $635.30

c. Create/obtain new 

information 

20.00 500.00 18.00 538.00 $24,320.60 $1,000,000.00* 0.10 53.80 $102,432.06

d. Gather existing 

information 

20.00 120.00 40.00 180.00 $7,697.60 $0.00 0.10 18.00 $769.76

e. Complete 

application 

16.00 100.00 60.00 176.00 $6,959.80 $10.00 0.10 17.60 $696.98

2. Reporting 

Requirements (40 

CFR 224.1-224.2) 

a. Read permit/ 

regulations/ 

guidance 1.00 7.00 2.00 10.00 $429.91 $0.00 0.10 1.00 $42.99

b. Record dumping 

and monitoring 

activity information 

20.00 150.00 40.00 210.00 $9,048.50 $0.00 0.10 21.00 $904.85

c. Submit dumping 

and monitoring 

reports 10.00 60.00 40.00 110.00 $4,292.80 $10.00 0.10 11.00 $430.28

Subtotal (hours 

and costs) 

108.00 1044.00 222.00 1374.00 $59,532.12 $1,000,020.00 0.10 137.40 $105,955.21

* Assumes the cost for five samples of material proposed for dumping to be collected and analyzed 

based on the ocean dumping regulations (bioassays for toxicity and bioaccumulation, chemical analyses 

for water quality) procedures in the ocean dumping testing manual. This also includes assumed 

environmental oceanographic monitoring during research, including water and sediment sampling with 

associated chemical and biological testing. 

 
15 

Table 5. Respondent Burden and Cost for Emergency Permits 

Emergency 

Permit - 

Information 

Collection 

Activity 

Hours and Costs Per Response Total Hours and Costs Per 

Year 

Mgmt. 

$70.03/ 

hr 

Technical

$45.03/ 

hr 

Clerical 

$22.20/ 

hr 

Total 

Hours/ 

Response 

Labor 

Cost/ 

Response 

O & M 

Cost ($) 

Number 

Responses/

Year 

Total 

Hours/ 

Year 

Total 

Cost/ 

Year ($) 

1. Application (40 

CFR 221.1) 

 

a. Read regulations/ 

guidance 

1.00 7.00 2.00 10.00 $429.91 $0.00 0.30 3.00 $128.97

b. Plan Activities 10.00 50.00 10.00 70.00 $3,176.50 $0.00 0.30 21.00 $952.95

c. Create/obtain new 

information 

10.00 250.00 10.00 269.00 $12,160.30 $0.00 0.30 80.70 $3,648.09

d. Gather existing 

information 

10.00 60.00 20.00 90.00 $3,848.80 $0.00 0.30 27.00 $1,154.64

e. Complete 

application 

8.00 50.00 30.00 88.00 $3,479.90 $10.00 0.30 26.40 $1,046.97

2. Reporting 

Requirements (40 

CFR 224.1-224.2) 

a. Read permit/ 

regulations/ guidance

1.00 7.00 2.00 10.00 $429.91 $0.00 0.30 3.00 $128.97

b. Record dumping 

and monitoring 

activity information 

10.00 20.00 10.00 40.00 $1,825.60 $0.00 0.30 12.00 $547.68

c. Submit dumping 

and monitoring 

reports 

5.00 10.00 5.00 20.00 $912.80 $10.00 0.30 6.00 $276.84

Subtotal (hours and 

costs) 

55.00 454.00 88.00 597.00 $26,263.72 $20.00 0.30 179.10 $7,885.12

 
16 

Table 6. Respondent Burden and Cost for Emergencies to Safeguard Life at Sea

Emergency to 

Safeguard 

Life at Sea - 

Information 

Collection 

Activity 

Hours and Costs Per Response Total Hours and Costs Per 

Year 

Mgmt. 

$70.03/ 

hr 

Technical 

$45.03/ 

hr 

Clerical 

$22.20/ 

hr 

Total 

Hours/ 

Response 

Labor 

Cost/ 

Response 

O & M 

Cost 

($) 

Number 

Responses/ 

Year 

Total 

Hours/ 

Year 

Total Cost/ 

Year ($) 

1. Reporting 

Requirements 

 a. Read 

regulations/ 

guidance 1.00 7.00 2.00 10.00 $429.91 $0.00 0.10 1.00 $42.99

b. Record 

dumping and 

monitoring 

activity 

information 

according to 40 

CFR 224.1 

10.00 20.00 10.00 40.00 $1,825.60 $0.00 0.10 4.00 $182.56

c. Submit report to 

EPA under 40 

CFR 224.2(b) 

5.00 10.00 5.00 20.00 $912.80 $10.00 0.10 2.00 $92.28

Subtotal (hours 

and costs) 

16.00 37.00 17.00 70.00 $3,168.31 $10.00 0.10 7.00 $317.83

 
17 

6(c): Estimating Agency Burden and Cost 

EPA’s labor costs data associated with this chapter of the ICR reflect the pay scale rates for GS9, GS-12, and GS-14 employees.8

 The salary rates for EPA’s labor costs apply to the Agency job 

classifications listed in Table 2 below for: 

• GS-14 (Management)

• GS-12 (Technical)

• GS-9 (Clerical)

To arrive at the loaded hourly rates listed in Table 7, hourly rates were multiplied by 160% to 

reflect a fully loaded (wages + benefits) hourly rate. 

Table 7. Agency Labor Costs: Hourly Loaded Agency Wage Estimate 

ICR Agency Job 

Classification 

January 2015 

Annual GS Salary 

(Step 1) 

Work Hours 

Per Year 

Factor 

Benefits 

Factor 

Loaded Hourly 

Rate 

Management GS-14, $107,325 ÷ 2,080 × 1.6 $82.56/hr 

Technical GS-12, $76,378 ÷ 2,080 × 1.6 $58.75/hr 

Clerical GS-9, $52,668 ÷ 2,080 × 1.6 $40.51/hr 

In summary, the estimated EPA burden per respondent for a special permit is 1,100 hours with a 

labor cost per respondent of $63,775.75. The estimated burden per respondent for a general 

permit is 500 hours with a labor cost per respondent of $29,932.00. The estimated burden per 

respondent for a research permit is 930 hours with a labor cost per respondent of $52,653.45. 

The estimated burden per respondent for an emergency permit is 164 hours with a labor cost per 

respondent of $9,863.37. The estimated burden per respondent to complete the requirements for 

an emergency to safeguard life at sea is 24 hours with a labor cost per respondent of $1,443.42. 

Annualized burden and costs are based on the number of permits expected per year. This analysis 

is shown in Tables 8 through 12. 

 

8 http://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/2015/generalschedule/. The salary scales contained in Table 2 were effective January 2015; EPA used Step 1 of the General 

Schedule (GS) salaries for the ICR analysis. The 2015 GS Locality Pay Tables can be found at 

http://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/15Tables/html/DCB.aspx. The 

annual GS salary rates were converted to hourly rates according to instructions in Section 6(c) if the EPA ICR 

Handbook (12/96 version). Total salaries were divided by 2,080, which represent the average number of hours work 

in a calendar year, and then multiplied by a factor of 1.6. The benefits factor “multiplier” represents the standard 

government benefits multiplication factor. The loaded hourly rate listed in Table 2 reflects the true cost to the federal 

government to employ a federal worker for one hour. 
18 

Table 8. Agency (EPA) Burden and Cost for Special Permits 

Special Permit - 

Information 

Collection 

Activity 

Hours and Costs Per Response Total Hours and Costs Per 

Year 

Mgmt. 

$82.56/ 

hour 

Technical 

$ 58.75/ 

hour 

Clerical 

$40.51/ 

hour 

Total 

Hours/ 

Response 

Labor 

Cost/ 

Response 

O & M 

Cost 

 ($) 

Number 

Responses/

Year 

Total 

Hours/ 

Year 

Total Cost/ 

Year ($) 

1. Application 

a. Receive and 

review application 

information under 

40 CFR 221.1 and 

issue of permit 100.00 500.00 100.00 700.0 $41,682.00 $10.00 0.30 210.00 $12,507.60

b. Maintain records 

throughout the 

application process 

under 40 CFR Part 

222 50.00 100.00 150.00 300.0 $16,079.50 $0.00 0.30 90.00 $4,823.85

2. Reporting 

Requirements 

a. Collect reported 

information and 

review for 

consistency with 

permit / MPRSA 

requirements 

20.00 40.00 20.00 80.0 $4,811.40 $10.00 0.30 24.00 $1,446.42

b. Maintain reports 

and monitoring 

information for 

future reviews 

5.00 10.00 5.00 20.0 $1,202.85 $0.00 0.30 6.00 $360.86

 Subtotal (hours 

and costs) 175.0 650.0 275.0 1100.0 $63,775.75 $20.00 0.30 330.00 $19,138.73

 
19 

Table 9. Agency (EPA) Burden and Cost for General Permits 

General Permit -

Information 

Collection 

Activity 

Hours and Costs Per Response Total Hours and Costs Per 

Year 

Mgmt. 

$82.56/ 

hour 

Technical 

$ 58.75/ 

hour 

Clerical 

$40.51/ 

hour 

Total 

Hours/ 

Response

Labor 

Cost/ 

Response 

O & M 

Cost 

($)* 

Number 

Responses/ 

Year 

Total 

Hours/ 

Year 

Total 

Cost/ 

Year ($) 

1. Application 

a. Receive and 

review application 

information under 

40 CFR 221.1 and 

issue permit 50.00 200.00 50.00 300.00 $17,903.50 $10.00 0.10 30.00 $1,791.35

b. Maintain records 

throughout the 

application process 

under 40 CFR Part 

222 

25.00 50.00 25.00 100.00 $6,014.25 $0.00 0.10 10.00 $601.43

2. Reporting 

Requirements 

a. Collect reported 

information and 

review for 

consistency with 

permit / MPRSA 

requirements 

20.00 40.00 20.00 80.00 $4,811.40 $10.00 0.10 8.00 $482.14

b. Maintain reports 

and monitoring 

information for 

future reviews 5.00 10.00 5.00 20.00 $1,202.85 $0.00 0.10 2.00 $120.29

Subtotal (hours 

and costs) 100.00 300.00 100.00 500.00 $29,932.00 $20.00 0.10 50.00 $2,995.20
20 

Table 10. Agency (EPA) Burden and Cost for Research Permits 

Research Permit 

- Information 

Collection 

Activity 

Hours and Costs Per Response Total Hours and Costs Per 

Year 

Mgmt. 

$82.56/ 

hr 

Technical 

$ 58.75/ 

hr 

Clerical 

$40.51/ 

hr 

Total 

Hours/ 

Response 

Labor 

Cost/ 

Response 

O & M 

Cost 

($)* 

Number 

Responses/ 

Year 

Total 

Hours/ 

Year 

Total Cost/ 

Year ($) 

1. Application 

a. Receive and 

review application 

information under 

40 CFR 221.1 and 

issue permit 80.00 300.00 100.00 480.00 $28,280.80 $10.00 0.10 48.00 $2,829.08

b. Maintain records 

throughout the 

application process 

under 40 CFR Part 

222 

25.00 150.00 150.00 325.00 $16,953.00 $0.00 0.10 32.50 $1,695.30

2. Reporting 

Requirements 

a. Collect reported 

information and 

review for 

consistency with 

permit / MPRSA 

requirements 

25.00 50.00 30.00 105.00 $6,216.80 $10.00 0.10 10.50 $622.68

b. Maintain reports 

and monitoring 

information for 

future reviews 

5.00 10.00 5.00 20.00 $1,202.85 $0.00 0.10 2.00 $120.29

Subtotal (hours 

and costs) 

135.00 510.00 285.00 930.00 $52,653.45 $20.00 0.10 93.00 $5,267.35

 
21 

Table 11. Agency (EPA) Burden and Cost for Emergency Permits 

Emergency 

Permit - 

Information 

Collection 

Activity 

Hours and Costs Per Response Total Hours and Costs Per 

Year 

Mgmt. 

$82.56/ 

hr 

Technical 

$ 58.75/ 

hr 

Clerical 

$40.51/ 

hr 

Total 

Hours/ 

Response 

Labor 

Cost/ 

Response 

O & M 

Cost 

 ($) 

Number 

Responses/ 

Year 

Total 

Hours/

Year 

Total 

Cost/ 

Year ($) 

1. Application 

a. Receive and 

review application 

information under 

40 CFR 221.1 and 

issue permit 25.00 50.00 25.00 100.00 $6,014.25 $10.00 0.3 30.00 $1,807.28

b. Maintain records 

throughout the 

application process 

under 40 CFR Part 

222 10.00 20.00 10.00 40.00 $2,405.70 $0.00 0.3 12.00 $721.71

2. Reporting 

Requirements 

a. Collect reported 

information and 

review for 

consistency with 

permit / MPRSA 

requirements 5.00 10.00 5.00 20.00 $1,202.85 $10.00 0.3 6.00 $363.86

b. Maintain reports 

and monitoring 

information for 

future reviews 1.00 2.00 1.00 4.00 $240.57 $0.00 0.3 1.20 $72.17

Subtotal (hours 

and costs) 41.00 82.00 41.00 164.00 $9,863.37 $20.00 0.3 49.20 $2,965.01

 
22 

Table 12. Agency (EPA) Burden and Cost for Emergency to Safeguard Life at Sea 

Emergency to 

Safeguard Life at 

Sea - Information 

Collection Activity

Hours and Costs Per Response Total Hours and Costs Per 

Year 

Mgmt. 

$82.56/ 

hr 

Technical 

$ 58.75/ 

hr 

Clerical 

$40.51/ 

hr 

Total 

Hours/ 

Response 

Labor 

Cost/ 

Response 

O & M 

Cost 

 ($) 

Number 

Responses/

Year 

Total 

Hours/ 

Year 

Total 

Cost/ 

Year ($) 

1. Reporting 

Requirements 

a. Collect reported 

information and 

review for 

consistency with 

permit / MPRSA 

requirements 

5.00 10.00 5.00 20.00 $1,202.85 $10.00 0.10 2.00 $121.29

b. Maintain reports 

and monitoring 

information for 

future reviews 

1.00 2.00 1.00 4.00 $240.57 $0.00 0.10 0.40 $24.06

Subtotal (hours and 

costs) 6.00 12.00 6.00 24.00 $1,443.42 $10.00 0.10 2.40 $145.34

6(d): Estimating the Respondent Universe 

The potential respondent universe consists of any “person,” as defined by the MPRSA, interested 

in applying for a new permit. The estimated number of respondents for the special, general (other 

than burial at sea and vessel disposal), research, and emergency permits, as well as the reporting 

requirements for an emergency to safeguard life at sea are based on historical data. Applications 

for these permits occur infrequently (< 1 per year) and in order for burdens and costs to be 

annualized, the respondent numbers are represented as a decimal. 

The number of respondents for these permits was based on an estimate of permit applications 

expected per year, based on an average number of each permit issued during a previous ten year 

time frame (2004-2013) in which data is available. The burden and cost for the general permit 

for the transportation and disposal of vessels and general permit for the burial as sea are not 

included in this section, as they are accounted for separately in chapter 2. There were no other 

new general permits issued during the time frame of interest; therefore, we will assume 1 new 

general permit will be issued per every 10 years or 0.1 per year. The same assumption is made 

for emergencies to safeguard life at sea. Three special and emergency permits were issued during 

the time frame of interest, creating a frequency of 3 per 10 years or 0.30 per year. One research 

permit was issued creating a frequency of 1 per 10 years or 0.10 per year. 
23 

6(e): Total Burden Hours and Cost Tables 

The total estimated ocean dumping burdens and costs associated with chapter 1 of the ICR are as 

follows: 

1) Respondent 

• Respondents per year: 0.90 

• Total hours per year: 789.90 

• Total labor cost per year: $34,384.33 

• Total annual O&M costs: $190,017.00 

• Total annual cost: $224,401.33 

1) Agency 

• Respondents per year: 0.90 

• Total hours per year: 524.60 

• Total labor cost per year: $30,494.62 

• Total annual O&M costs: $17.00 

• Total annual cost: $30,511.62 

The total estimated ocean dumping burdens associated with chapter 1 are summarized in Tables 

13 and 14 for respondents and agencies, respectively. 

 
24 

Table 13. Total Estimated Respondent Burden and Cost* Summary 

Permit: Respondents Per 

Year 

Total Hours 

Per Year 

Total Labor 

Cost Per Year 

($) 

Total Annual 

O&M Costs 

($) 

Total Annual 

Cost ($) 

Special 0.30 412.2 $17,859.64 $90,006.00 $107,865.64

General (other than 

burial at sea and 

vessel disposal) 0.10 54.2 $2,375.54 $2.00 $2,377.54

Research 0.10 137.40 $5,953.21 $100,002.00 $105,955.21

Emergency Permit 

Dumping 0.30 179.10 $7,879.12 $6.00 $7,885.12

Emergency 

Dumping 0.10 7.00 $316.83 $1.00 $317.83

Total 0.90 789.90 $34,384.33 $190,017.00 $224,401.33

* These data are from Tables 2 through 6 of this ICR 

Table 14: Total Estimated Agency (EPA) Burden and Cost* Summary 

Permit: Respondents Per 

Year 

Total Hours 

Per Year 

Total Labor 

Cost Per 

Year ($) 

Total Annual 

O&M Costs 

($) 

Total Annual 

Cost ($) 

Special 0.30 330.00 $19,132.73 $6.00 $19,138.73

General (other than 

burial at sea and 

vessel disposal) 0.10 50.00 $2,993.20 $2.00 $2,995.20

Research 0.10 93.00 $5,265.35 $2.00 $5,267.35

Emergency Permit 

Dumping 0.30 49.20 $2,959.01 $6.00 $2,965.01

Emergency 

Dumping 0.10 2.40 $144.34 $1.00 $145.34

Total 0.90 524.60 $30,494.62 $17.00 $30,511.62

* These data are from Tables 8 through 12 of this ICR 
25 

6(f): Burden Statement 

The annual public reporting and record keeping burden for this collection of information is 

1374.0 hours for a special permit, 542.0 hours for a new general permit, 1374.0 hours for a 

research permit, and 597 hours for an emergency permit, per response. The estimated burden per 

respondent to complete the necessary reporting requirements for an emergency to safeguard life 

at sea is 70 hours per response. EPA is estimated to average 1100 hours for a special permit, 500 

hours for a general permit, 930 hours for a research permit, and 164 hours for an emergency 

permit, per response. EPA estimates an average of 24 hours to complete the requirements for an 

emergency to safeguard life at sea 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, 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 request for 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 request for 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 EPA's need for this information, the accuracy of the burden estimates, and 

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. OW-2015-

0613, which is available for public viewing at the Water 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 8:00 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 Water Docket is (202) 566-2426. An electronic version 

of the public docket is available at 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 to access 

those documents in the public docket that are available electronically. Once in the system, select 

“search,” then key in the docket ID number identified above. Also, you can send comments to 

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

Street, NW, Washington, DC 20503, Attention: Desk Office for EPA. Please include the EPA 

Docket ID Number (OW-2015-0613) and OMB control number (2040-0008) in any 

correspondence. 
26 

Chapter 2. Supporting Statement for the Collection of Information for 

General Permits: Burial at Sea and Transportation and Disposal of Vessels 

SECTION 1: Identification of the Information Collection 

1(a): Title of the Information Collection 

Collection of Information for General Permits: Burial at Sea and Transportation and Disposal of 

Vessels 

1(b): Short Characterization/Abstract 

Chapter 2 of this ICR covers collections of information associated with two general permits. 

Specifically, this chapter addresses information collections associated with the general permits 

for (1) burial at sea and (2) transportation and disposal of vessels, which are published in the 

Code of Federal Regulations. 

SECTION 2: Need for and Use of the Collection 

2(a): Need/Authority for the Collection 

Section 104(b) of the MPRSA authorizes the Administrator to prescribe reporting requirements 

for permits “as he [EPA] deems appropriate.” The information that EPA collects in the general 

permits for burial at sea and for vessel disposal ensures that ocean dumping is appropriately 

regulated and will not harm human health or the marine environment, based on applying the 

Ocean Dumping Criteria. To meet United States’ reporting obligation under the London 

Convention, EPA also reports some of this information in the annual United States Ocean 

Dumping Report. 

2(b): Practical Utility/Users of the Data 

EPA uses monitoring and reporting data from permittees to assess compliance with ocean 

dumping permits, including associated monitoring activities. 

SECTION 3: Non-duplication, Public Notice, Consultations, and Other 

Collection Criteria 

3(a): Non-duplication 

All information requested from respondents under this ICR is required to ensure that material 

proposed for ocean dumping is appropriately regulated and does not harm human health or the 

marine environment, based on applying the Ocean Dumping Criteria. The information is not 

generally available from other sources. 

3(b): Public Notice Required Prior to ICR Submission to OMB 

Public comments were previously requested via the Federal Register (81 FR 484) on January 06, 

2016 during a 60-day comment period. No Comments were received. 

3(c): Consultations 

EPA consulted with four respondents to obtain input on the burden associated with the burial at 

sea and transportation and disposal of vessels general permits. The consultations for burial at sea 

were conducted with one representative from the New England Burials at Sea, LLC and one 
27 

representative from the U.S Coast Guard Auxiliary. Both contacts provided estimates of the 

hourly burden. During the consultations, respondents were also asked to comment on the 

accuracy of the respondent wage rates. EPA received feedback on the labor rate of the funeral 

director and, based on the response, increased its initial labor rate estimate accordingly. For the 

transportation and vessel disposal general permit, EPA consulted with a representative from 

Cape Cod Bay Scallop Fisheries, Inc. and a boat owner in Gloucester, MA who has disposed of a 

vessel under this general permit. 

 

3(d): Effects of Less Frequent Collection 

The collection of information described in this chapter of the ICR occurs only once per 

authorization: once after the burial has been conducted under the burial at sea general permit and 

once each time a general permittee seeks authorization under the general permit for 

transportation and disposal of vessels. Thus, collections cannot occur on a less frequent basis. 

The notification required under the burial at sea general permit is necessary to track burials at sea 

and enable EPA to evaluate impacts on human health or the marine environment. Information 

collected under the transportation and disposal of vessels general permit is necessary to ensure 

the dumping does not unreasonably endanger human health or the marine environment, or other 

uses of the ocean (such as fisheries and navigation), and to ensure the disposal is conducted in a 

safe manner. Collection of this information less frequently (i.e., not at all) would preclude EPA 

from accomplishing these purposes. 

3(e): General Guidelines 

The information collection activities discussed in this chapter of the ICR are fully consistent with 

all guidelines in 5 CFR § 1320.5(d)(2). 

3(f): Confidentiality 

To the extent that information collection activities discussed in this chapter of the ICR do require 

the submission of any confidential information, EPA ensures compliance with the Agency's 

confidentiality regulations 40 CFR 2.201 et seq. 

3(g): Sensitive Questions 

The information collection activities discussed in this chapter of the ICR do not require the 

submission of any sensitive information. 

SECTION 4: The Respondents and the Information Requested 

4(a): Respondents/SIC Codes 

1) Burial at Sea 

Any private person or entity, or any officer, employee, agent, department, agency, or 

instrumentality of the federal government, of any state or local unit of government, or of any 

foreign government is eligible to use the burial at sea and transportation and disposal of vessels 

general permits. Funeral homes, mortuaries, cemeteries, and crematories (SIC 7261/NAICS 

812200), and deep sea passenger transportation (SIC 4481/NAICS 483112) are likely 

respondents for activities relevant to this chapter of the ICR related to burials at sea. 
28 

2) Vessel Disposal 

Navigational services related to shipping (includes cargo salvaging, marine docking and 

undocking marine vessel services, marine salvaging services, marine vessel traffic reporting 

services (NAICS 488330)) and towing and tugboat services (SIC 4492/NAICS 488330) are 

potential respondents for collections of information as described in this chapter of the ICR 

related to vessel disposals. 

4(b): Information Requested: 

1) Burial at Sea 

Information collected by EPA related to the burial at sea general permit includes the following: 

(i) Name of the deceased: 

• Full name of the deceased. 

(ii) Date of the burial/scatter: 

• Date of the burial/scattering of the remains of the deceased. 

 (iii) Type of remains (cremated or whole body): 

• Describe whether the remains of the deceased were either cremated or whole body. 

(iv) Latitude of burial/scatter: 

• The approximate latitude of the site at which the burial or scatter took place. 

 (v) Longitude of burial/scatter: 

• The approximate longitude of the site at which the burial/scatter took place. 

(vi) Distance from land: 

• Confirm that the burial at sea was conducted at least 3 nautical miles (nm) from the baseline. 

(vii) Depth of water: 

• The approximate depth of water at which the burial/scatter took place. 

(viii) Vessel point of contact, name/address/phone/email: 

• At least one vessel point of contact, including the contact’s name, address, phone number, and 

e-mail. 

(ix) Port of departure: 

• The port of departure from which the vessel carrying the remains departed. 

(x) Director or person(s) responsible for burial arrangements, name/address/phone/email: 

• Director or responsible person for the burial arrangements (if applicable), including at least one 

method of contacting this person. 

(xi) Whether the remains appear to rapidly sink below the surface: 

• Describe whether the remains of the deceased appeared to rapidly sink below the surface. 
29 

(xii) EPA Region from which the vessel carrying the remains departed: 

• Report the EPA Region from which the vessel carrying the remains departed. 

2) Transportation and Disposal of Vessels 

There are five collections of information in sequential time intervals contained in the 

transportation and disposal of vessels general permit, though the timing requirement of each need 

not apply in emergency situations: 

(1) No later than 1 month prior to the proposed disposal date, provide written notification to the EPA

Regional Administrator of the following under 40 CFR 229.3(a)(1): 

i. A statement detailing the need for the disposal of the vessel. 

ii. Type and description of vessel to be disposed of and type of cargo normally 

carried. 

iii. Detailed description of the proposed disposal procedures. 

iv. Information on the potential effect of the vessel disposal on the marine 

environment. 

v. Documentation of an adequate evaluation of alternatives to ocean disposal (i.e., 

scrap, salvage, and reclamation). 

(2) Notify EPA and U.S. Coast Guard that the vessel has been cleaned and is available for inspection no 

later than 10 days prior to the proposed disposal date under § 229.3(a)(4). 

(3) Notify EPA, U.S. Coast Guard, and Captain-of-the-Port no later than 48 hours in advance of 

proposed disposal under § 229.3(a)(8). 

(4) Notify EPA and Captain-of-the-Port no later than 12 hours before the vessel’s departure from port 

under § 229.3(a)(8) with such details as: 

i. the proposed departure time and place; 

ii. disposal site location; 

iii. estimated time of arrival on site; and 

iv. the name and communication capability of the towing vessel. 

(5) Notify NOAA in writing within one week of the disposal with the exact coordinates where the vessel

disposal took place so that it may be marked on appropriate charts as required by 40 CFR 229.3(a)(9). 

SECTION 5: The Information Collected — Agency Activities, Collection 

Methodology and Information Management 

5(a): Agency Activities 

1) Burial at Sea 

EPA collects information from persons who dispose of human remains pursuant to the burial at 

sea general permit. The information is not required to be reported until after the burial has been 

conducted, specifically, within 30 days of the burial. 

2) Transportation and Disposal of Vessels 

EPA sponsors collections of information as specified in the vessel disposal general permit. The 

collection process is codified in 40 CFR 229.3. 
30 

5(b): Collection Methodology and Information Management

1) Burial at Sea 

Burials conducted under the burial at sea general permit are to be reported within 30 days to the 

EPA Regional Administrator of the EPA Region from which the vessel carrying the remains 

departed. EPA Regions keep record of all reports, including: faxes, emails, mail, and other online 

submissions. The total number of burials at sea for each Region is reported to EPA Headquarters 

and is stored in a database 

EPA is developing an online reporting tool for persons to report burials at sea. This tool would 

create consistency, facilitate compliance with 40 CFR 229.1(d), and reduce burdens on 

respondents by allowing for online reporting. Once this goes into effect, EPA will be updating its 

website to include the number of burials at sea each year, so the public has easy access to the 

information. 

2) Transportation and Disposal of Vessels 

Under the general permit for transportation and disposal of vessels, information is collected and 

managed by EPA, U.S. Coast Guard (USCG), including the relevant USCG Captain-of-the-Port 

(COTP), and NOAA. Each of the following collections of information assists EPA in ensuring 

that material proposed for ocean dumping is appropriately regulated by relevant federal entities, 

and does not harm human health or the marine environment. 

The corresponding EPA Region collects all information pertaining to a vessel disposal and 

submits it to EPA Headquarters, where it is stored in a database. EPA submits an annual ocean 

dumping report to the International Maritime Organization. The new EPA ocean dumping 

website includes an interactive map, which includes location and basic information of all vessels 

disposals which occurred from 2006-2014. 

5(c): Small Entity Flexibility 

EPA certifies that this chapter of the ICR will not have a significant economic impact on a 

substantial number of small entities. While the two general permits described in this chapter of 

the ICR are available to any private person or entity, or any officer, employee, agent, department, 

agency, or instrumentality of the federal government, of any state or local unit of government, or 

of any foreign government, the transportation and disposal of vessels general permit is used 

much more infrequently than the burial at sea general permit. 

5(d): Collection Schedule 

Reporting for each of the general permits depends on how many respondents choose to use the 

general permit. For burials at sea, EPA assumes an average of 2,762.5 events per year. For vessel 

disposals, EPA assumes an average of 3.5 events per year. See Section 6 below for information 

on how these values were determined. 

1) Burial at Sea 

Under 40 CFR 229.1(d), a burial conducted under the burial at sea general permit must be 
31 

reported within 30 days to the Regional Administrator of the EPA Region from which the vessel 

carrying the deceased’s remains departed. 

2) Vessel Disposal 

The collection schedule for the transportation and disposal of vessels general permit is described 

in 40 CFR 229.3(a)(1-9). 

EPA collects information at four sequential time intervals under the transportation and disposal 

of vessels general permit, though the timing requirement of each need not apply in emergency 

situations. 

EPA 

EPA receives the following notifications: 

• One month prior to disposal (40 CFR 229.3(a)(1)). 

• Ten days prior to disposal – notification that vessel has been cleaned (40 CFR 

229.3(a)(4). 

• Forty-eight (48) hours prior to disposal (40 CFR 229.3(a)(8)). 

• Twelve (12) hours prior to departure (40 CFR 229.3(a)(8)). 

USCG

Under 40 CFR 229.3(a)(4) and 229.3(a)(8), USCG receives notification no later than 10 days 

prior to the proposed disposal date that the vessel has been cleaned and is available for 

inspection. The COTP at USCG also receives confirmatory notification. Under 40 CFR 

229.3(a)(8), the COTP receives notification 48 hours prior to the proposed disposal and 

telephonic notification 12 hours prior to the vessel’s departure from port. 

NOAA 

Under 40 CFR 229.3(a)(9), NOAA receives notification in writing within one week after the 

disposal with the exact coordinates of the disposal site so that it may be marked on appropriate 

charts. 

SECTION 6: Estimating the Burden and Cost of the Collection 

6(a): Estimating Respondent Burden 

This section estimates the annual burden for the burial at sea and transportation and disposal of 

vessels general permits information collection burden hours/costs. The estimates were reviewed 

by respondents who had previously participated in burials at sea and/or vessel disposals. The 

estimated burden hours reflect the time taken to assemble and submit written information needed 

for a burial at sea or vessel disposal. 

In summary, the estimated burden per respondent to complete reporting requirements for the 

burial at sea general permit is 0.83 hours. The activities required to complete notification 

requirements for a vessel disposal under the transportation and disposal of vessels general permit 

is broken down into four main categories. The estimated burden per respondent is 15.0 hours to 

complete activities related to a one month notification, 10.0 hours for the notification of vessel 

cleaning and inspection, 9.5 hours for a 12 and 48 hour notification and 1.0 hour for the 

submission of coordinates. The EPA estimates a total of 35.5 hours per respondent to complete 

all activities pertaining to a vessel disposal under the general permit. The total burden per year 
32 

was calculated by multiplying the burden hours per response by the number of respondents, 

which corresponds to the number of respondents expected to use the permit per year. This 

analysis is shown in Tables 17 through 21. See section 6(d) of chapter 2 of this supporting 

statement for a description of how the respondent numbers (i.e., respondent universe) were 

estimated. 

6(b): Estimating Respondent Costs 

To estimate the labor costs, EPA used labor and cost-rate data listed on the U.S. Bureau of Labor 

Statistics (BLS) Compensation Cost Trends homepage.9 EPA used the following labor categories 

for the burial at sea and transportation and disposal of vessels general permits, respectively: 

1) Burial at Sea 

• Office and administrative support occupations10 (Clerical )

• Average rate: Funeral home director11 and ship boat captain12 (Management Avg.) 

 

2) Vessel Disposal 

• Ship and boat captains and operators16 (Management) 

• Compliance officers13 (Technical) 

• Office and administrative support occupations14 (Clerical) 

EPA used the mean hourly figures listed by BLS to approximate the labor burdened hourly rates 

for the occupational categories contained in this chapter of the ICR. EPA used the 90 percentile 

hourly wage for the funeral home director’s hourly wage. These are listed below in Tables 15 

and 16. 

 

 

9

 The BLS homepage is available on-line at: http://www.bls.gov/ncs/ect/. 

10 For clerical hourly rates, EPA used the website titled Occupational Employment and Wages, May 2014, available 

online at: http://www.bls.gov/oes/current/oes430000.htm. 

11 For management (funeral director) hourly rate, EPA used the website titles Occupational Employment and 

Wages, 11-9061 Funeral Service Manages, May 2014, available online at: 

http://www.bls.gov/oes/current/oes119061.htm. 

12 For management hourly rate, EPA used the website titled Occupational Employment and Wages, 53-5021 

Captains, Mates, and Pilots of Water Vessels, May 2014, available online at: 

http://www.bls.gov/oes/current/oes535021.htm. 

13 For technical hourly rate, EPA used the website titled Occupational Employment and Wages, 13-1041 

Compliance Officers, May 2014, available online at: http://www.bls.gov/oes/current/oes131041.htm. 

14 For clerical hourly rate, EPA used the website titled Occupational Employment and Wages, May 2014, available 

online at: http://www.bls.gov/oes/current/oes430000.htm. 
33 

Table 15. Respondent Labor Costs: Burial at Sea Hourly Loaded Wage Estimate of 

Affected Industry [40 CFR 229.1] 

BLS: 

Occupational 

Earnings 2014 

ICR Agency 

Job 

Classification Hourly Rate 

Benefits 

Factor 

Loaded Hourly 

rate 

Funeral Home 

Director Management $66.06/hr × 1.3 $85.87/hr 

Ship and boat 

captains and 

operators 

Management $38.07/hr × 1.3 $49.49/hr 

Average rate (ship 

and boat captains 

and operators and 

funeral home 

director) 

Management 

(Avg.) $52.06/hr × 1.3 $67.68/hr 

Office and 

administrative 

support 

occupations 

Clerical $17.08/hr × 1.3 $22.20/hr 

Table 16. Respondent Labor Costs: Vessel Disposal Hourly Loaded Wage Estimate of 

Affected Industry [40 CFR 229.3] 

BLS: 

Occupational 

Earnings May, 

2014 

ICR Agency 

Job 

Classification Hourly Rate 

Benefits 

Factor 

Loaded Hourly 

Rate 

Ship and boat 

captains and 

operators 

Management 

$38.07/hr × 1.3 $49.49/hr 

Compliance 

officers Technical $32.69/hr × 1.3 $42.50/hr 

Office and 

administrative 

support 

occupations 

Clerical 

$17.08/hr × 1.3 $22.20/hr 

Non-labor O&M includes costs for photocopying, postage, telephone charges, expenses, and 

contracted services. Contracted services costs include costs for vessel cleaning before a vessel 

disposal as required by the general permit. 
34 

In summary, the estimated labor cost per respondent to complete all activities required under the 

burial at sea general permit is $41.17. 

The activities required to complete the reporting requirements of a vessel disposal under the 

transportation and disposal of vessels general permit is broken down into four main categories. 

The estimated labor cost per respondent is $604.56 to complete activities related to a one month 

notification, $442.48 for the notification of vessel cleaning and inspection, $391.11 for a 12 and 

48 hour notification, and $46.00 for the submission of coordinates. EPA estimates a total labor 

cost of $1,484.15 per respondent to complete all activities pertaining to the reporting 

requirements for a vessel disposal under the general permit. Annualized costs are based on the 

number of respondents expected to use the permit per year and include both labor costs and nonlabor O&M costs. 

Table 17. Respondent Burden and Cost for Burial at Sea General Permit [40 CFR 229.1] 

Information 

Collection Activity

Hours and Costs Per Response Total Hours and Costs Per 

Year 

Mgmt. 

(Avg.) 

$67.68/hr 

Clerical

$22.20/ 

hr 

Total 

 Hours/ 

Response 

Labor 

Cost/ 

Response 

O & M 

Cost 

($) 

Number 

Responses/ 

Year 

Total 

 Hours/ 

Year 

Total 

Cost/ 

Year ($)

1. Respondent 

conducts Burial at Sea

 

a. Prepare and review 

information necessary 

to complete reporting 

questions 

0.50 0.00 0.50 $33.84 $1.00 2762.50 1381.25 $96,245.50 

b. Submit information 

to EPA 

0.00 0.33 0.33 $7.33 $1.00 2762.50 911.63 $23,000.58 

Subtotal (hours and 

costs) 

0.50 0.33 0.83 $41.17 $2.00 2762.50 2292.88 $119,246.08 

 
35 

Table 18. Vessel Disposal General Permit Respondent Burden and Cost under 40 CFR 

229.3(a)(1) – 1 Month Notification to EPA 

Information 

Collection Activity

Hours and Costs Per Response Total Hours and Costs Per 

Year 

Mgmt. 

$49.49/ 

hr 

Technical 

$42.50/ 

hr 

Clerical 

$22.20/ 

hr 

Total 

Hours/ 

Response 

Labor 

Cost/ 

Response 

O & M 

Cost 

 ($) 

Number 

Responses/ 

Year 

Total 

Hours/ 

Year 

Total 

Cost/ 

Year ($) 

1. Preparation 

a. Read regulations 0.50 0.50 0.00 1.00 $70.74 $0.00 3.5 5.25 $247.59

2. Prepare information: 

a. Need for the disposal of 

the vessel 

0.50 0.00 0.00 0.50 $24.75 $0.00 3.5 1.75 $86.61

 b. Type and description 

of vessel to be disposed of 

and type of cargo 

normally carried 0.00 0.50 0.00 0.50 $21.25 $0.00 3.5 1.75 $74.38

 c. Detailed description of 

the proposed disposal 

procedures 

0.00 1.00 0.00 1.00 $42.50 $0.00 3.5 3.50 $148.75

d. Information on the 

potential effect of the 

vessel disposal on the 

marine environment 

0.50 2.00 0.00 2.50 $109.75 $0.00 3.5 8.75 $384.11

 e. Documentation of an 

adequate evaluation of 

alternatives to ocean 

disposal 

1.00 3.00 0.00 4.00 $176.99 $0.00 3.5 14.00 $619.47

3. Review and edit 

information for 

accuracy 1.00 0.00 2.00 3.00 $93.89 $0.00 3.5 10.50 $328.62

4. Provide written 

information to EPA 0.00 1.00 1.00 2.00 $64.70 $10.00 3.5 7.00 $261.45

 Subtotal (hours and costs) 

4.00 8.00 3.00 15.00 $604.56 $10.00 3.5 52.50 $2,150.96

 
36 

Table 19. Vessel Disposal General Permit Respondent Burden and Cost under 40 CFR 

229.3(a)(4) – 10 days Notification that the Vessel has been Cleaned and is Available for 

Inspection 

Information 

Collection Activity

Hours and Costs Per Response Total Hours and Costs Per 

Year 

Mgmt. 

$49.49/

hr 

Technical 

$42.50/ 

hr 

Clerical

$22.20/

hr 

Total 

Hours/ 

Response 

Labor 

Cost/ 

Response 

O & M 

Cost 

 ($) 

Number 

Responses/ 

Year 

Total 

Hours/ 

Year 

Total 

 Cost/ 

Year ($) 

1. Preparation 

a. Read regulations 

0.00 0.50 0.00 0.50 $21.25 $0.00 3.5 1.75 $74.38

b. Ensure that the 

requirements listed in 

40 CFR 229.3(a)(3) 

are met 

0.50 5.00 0.00 5.50 $237.25 $0.00 3.5 19.25 $830.36

2. Notify Coast Guard 

that the vessel has 

been cleaned and is 

ready for inspection 

1.00 1.00 0.00 2.00 $91.99 $5.00 3.5 7.00 $339.47

3. Notify EPA that the 

vessel has been 

cleaned and is ready 

for inspection 

1.00 1.00 0.00 2.00 $91.99 $5.00 3.5 7.00 $339.47

Subtotal (hours and 

costs) 2.50 7.50 0.00 10.00 $442.48 $10.00 3.5 35.00 $1,583.66
37 

Table 20. Vessel Disposal General Permit Respondent Burden and Cost under 40 CFR 

229.3(a)(8) – 12 and 48 Hour Notifications 

Information 

Collection Activity 

Hours and Costs Per Response Total Hours and Costs Per 

Year 

Mgmt. 

$49.49/ 

hr 

Technical 

$42.50/ 

hr 

Clerical 

$22.20/ 

hr 

Total 

Hours/ 

Response 

Labor 

Cost/ 

Response 

O & M 

Cost 

 ($) 

Number 

Responses/ 

Year 

Total 

Hours/ 

Year 

Total 

 Cost/ 

Year ($) 

1. Read regulations 0.00 0.00 0.00 0.00 $0.00 $5.00 3.5 0.00 $17.50

2. Prepare the 

following information 

for notification per 40 

CFR 229.3(a)(8) 

Proposed departure 

time and place 0.00 0.50 0.00 0.50 $21.25 $5.00 3.5 1.75 $91.88

Proposed disposal site 

location 0.00 0.50 0.00 0.50 $21.25 $5.00 3.5 1.75 $91.88

c. Estimated time of 

arrival on site 0.00 0.50 0.00 0.50 $21.25 $5.00 3.5 1.75 $91.88

d. Name and 

communication 

capability of the towing 

vessel 0.00 1.00 0.00 1.00 $42.50 $5.00 3.5 3.50 $166.25

3. Review and edit 

information for 

accuracy 1.00 1.00 2.00 4.00 $136.39 $5.00 3.5 14.00 $494.87

4. Notify EPA 48 hours 

prior to disposal 0.50 0.00 0.00 0.50 $24.75 $5.00 3.5 1.75 $104.11

5. Notify Coast Guard 

48 hours prior to 

disposal 0.50 0.00 0.00 0.50 $24.75 $5.00 3.5 1.75 $104.11

6. Notify COTP 48 

hours prior to disposal 0.50 0.00 0.00 0.50 $24.75 $5.00 3.5 1.75 $104.11

7. Telephonically 

notify EPA 12 hours 

prior to vessel’s 

departure 0.50 0.00 0.00 0.50 $24.75 $5.00 3.5 1.75 $104.11

8. Telephonically 

notify Coast Guard 12 

hours prior to vessel’s 

departure 0.50 0.00 0.00 0.50 $24.75 $5.00 3.5 1.75 $104.11

9. Telephonically 

notify COTP 12 hours 

prior to vessel’s 

departure 0.50 0.00 0.00 0.50 $24.75 $5.00 3.5 1.75 $104.11

Subtotal (hours and 

costs) 4.00 3.50 2.00 9.50 $391.11 $60.00 3.5 33.25 $1,578.89

 
38 

Table 21. Vessel Disposal General Permit Respondent Burden and Cost under 40 CFR 

229.3(a)(9) – Submission of Exact Coordinates of Disposal to NOAA 

Information 

Collection Activity

Total Hours and Costs Per Response Total Hours and Costs Per 

Year 

Mgmt. 

$49.49/ 

hr 

Technical 

$42.50/ 

hr 

Clerical

$22.20/

hr 

Total 

Hours/ 

Response 

Labor 

Cost/ 

Response

O & M 

Cost 

 ($) 

Number 

Responses/

Year 

Total 

Hours/ 

Year 

 Total 

 Cost/ 

 Year ($) 

1. Preparation 

a. Read regulations 

0.00 0.00 0.00 0.00 $0.00 $0.00 3.5 0.00 $0.00

b. Prepare and verify 

coordinates of 

disposal 0.00 0.50 0.00 0.50 $21.25 $0.00 3.5 1.75 $74.38

2. Submit coordinates 

of disposal to NOAA 

0.50 0.00 0.00 0.50 $24.75 $10.00 3.5 1.75 $121.61

Subtotal (hours and 

costs) 

0.50 0.50 0.00 1.00 $46.00 $10.00 3.5 3.50 $195.98

6(c): Estimating Agency Burden and Cost 

EPA’s labor costs data associated with this chapter of the ICR reflect the pay scale rates for GS9, GS-12, and GS-14 employees. EPA’s labor costs apply to the Agency job classifications listed 

in Table 15 (below) for: 

• GS-14 (Management) 

• GS-12 (Technical) 

• GS-9 (Clerical) 

To arrive at the loaded hourly rates listed in Table 22, hourly rates were multiplied by 160% to 

reflect a fully loaded (wages + benefits) hourly rate. 

 
39 

Table 22. Agency Labor Costs [40 CFR 229.1, 229.3] Hourly Loaded Agency Wage 

Estimate 

ICR Agency Job 

Classification 

January 2015 

Annual GS 

Salary (Step 1) 

Work Hours 

Per Year 

Factor Benefits Factor 

Loaded Hourly 

Rate 

Management GS-14, $107,325 ÷ 2,080 × 1.6 $ 82.56/hr

Technical GS-12, $76,328 ÷ 2,080 × 1.6 $ 58.75/hr

Clerical GS-9, $52,668 ÷ 2,080 × 1.6 $40.51/hr

In summary, the estimated EPA burden per respondent to complete activities related to the burial 

at sea general permit is .11 hours with a labor cost per respondent of $6.46. The estimated EPA 

burden per respondent to complete activities related to the vessel disposal general permit is 9.0 

hours with a labor cost per respondent of $623.99. Annualized burden and costs are based on the 

number of permits expected per year. This analysis is shown in Tables 23 and 24. 

 
40 

Table 23. Burial at Sea General Permit Agency (EPA) Burden and Cost [40 CFR 229.1] 

Information Collection 

Activity 

Hours and Costs Per Response Total Hours and Costs Per 

Year 

Mgmt. 

$82.56/ 

hour 

Technical 

$ 58.75/ 

hour 

Clerical 

$40.51/ 

hour 

Total 

Hours/ 

Response 

Labor 

Cost/ 

Response 

O & M 

Cost 

($)* 

Number 

Responses/ 

Year 

Total 

Hours/ 

Year 

Total 

 Cost/ 

 Year ($)

1. Respondent conducts 

Burial at Sea and submits 

information to EPA 

 

a. Review recorded 

information as submitted 

and verify the information 

for accuracy and 

completeness 

0.00 .10 0.00 0.10 $5.88 $0.10 2762.5 276.25 $16,505.94

 b. Organize and maintain 

submissions 

0.00 .01 0.00 0.01 $0.59 $0.10 2762.5 27.625 $1,899.22

Subtotal (hours and costs) 

0.00 .11 0.00 0.11 $6.46 $0.20 2762.5 303.875 $18,405.16

 
41 

Table 24. Vessel Disposal General Permit Agency (EPA) Burden and Cost under 40 CFR 

229.3(a)(1)-(a)(8) 

Information 

Collection Activity

 Total Hours and Costs Per Response 

Total Hours and Costs Per Year 

Mgmt. 

$82.56/ 

hr 

Technical

$ 58.75/ 

hr 

Clerical 

$40.51/ 

hr 

Total 

Hours/ 

Response

 Labor 

 Cost/ 

R Response

O & M 

Cost 

($) 

Number 

Responses/ 

Year 

 Total 

Hours/ 

 Year 

Total 

Cost/ 

Year 

1. EPA receives notice 

no later than 1 month 

prior to vessel disposal 

date, recording and 

reviewing the required 

information 0.50 1.00 0.00 1.50 $100.03 $5.00 3.5 5.25 $367.61

2. No later than 10 days 

prior to the proposed 

disposal date under 40 

CFR 229.3(a)(4), EPA 

receives notification 

that the vessel has been 

cleaned and is available 

for inspection 

1.00 1.00 0.00 2.00 $141.31 $5.00 3.5 7.00 $512.09

3. EPA reviews the 

information provided, 

coordinating with Coast 

Guard, in determining 

whether the 

requirements of 40 CFR 

229.3(a)(3) are met 1.00 1.00 0.00 2.00 $141.31 $5.00 3.5 7.00 $512.09

3. 4. Under 40 CFR 

229.3(a)(8), EPA 

receives notification no 

later than 48 hours prior 

to the proposed disposal 

date 0.50 0.00 0.00 0.50 $41.28 $5.00 3.5 1.75 $161.98

. 5. Under 40 CFR 

229.3(a)(8), EPA 

receives telephonic 

notification at least 12 

hours in advance of the 

vessel’s departure from 

port, recording and 

reviewing the 

information required 1.00 2.00 0.00 3.00 $200.06 $10.00 3.5 10.50 $735.21

Subtotal (hours and 

costs) 4.00 5.00 0.00 9.00 $623.99 $30.00 3.5 31.50 $2,288.97
42 

6(d): Estimating the Respondent Universe 

The potential respondent universe for the burial at sea general permit is any person who disposes 

of human remains pursuant to the permit. The number of respondents was based on historical 

data. The number of respondents used for burial at sea is the average of the number of persons 

who have used this permit during a previous six year time frame (2005-2010) in which data was 

available. EPA expects 2,762.5 responses per year. The potential respondent universe for the 

transportation and disposal of vessels general permit is all persons subject to title I of the 

MPRSA who dispose of the vessel pursuant to the permit. The number of respondents used for 

vessel disposals is the average number of vessels disposed of under this general permit during a 

previous 10 year time frame (2004-2013) as reported in the Ocean Dumping Reports. EPA 

expects 3.5 vessel disposals per year. 

6(e): Bottom Line Burden Hours and Cost Tables 

The total estimated ocean dumping burdens and costs associated with chapter 2 of the ICR are as 

follows: 

1) Respondent 

• Respondents per year: 2,766 

• Total hours per year: 2,417.13 

• Total labor cost per year: $118,915.57 

• Total annual O&M costs: $5,840.00 

• Total annual cost: $124,755.57 

1) Agency 

• Respondents per year: 2,766 

• Total hours per year: 335.38 

• Total labor cost per year: $20,036.62 

• Total annual O&M costs: $657.50 

• Total annual cost: $20,694.12 

The total estimated ocean dumping burdens associated with chapter 2 are summarized in Tables 

25 and 26 for respondents and agencies, respectively. 

Table 25. Total Vessel Disposal and Burial at Sea General Permits Respondent Burden and 

Costs* under 40 CFR 229.3 

Respondent 

Total 

Number of 

Respondents 

Per Year 

Total Number 

of Hours Per 

Year 

Total Labor 

Cost Per 

Year ($) 

Total Annual 

O&M Costs 

($)

Total Cost 

Burden ($) 

Burial at Sea 2762.5 2,292.88 $113,721.08 $5,525.00 $119,246.08

Vessel Disposal 

3.5 124.25 $5,194.49 $315.00 $5,509.49

TOTAL 2766 2,417.13 $118,915.57 $5,840.00 $124,755.57

* These data are from Tables 17 through 21. 

 
43 

Table 26. Total Burial at Sea and Vessel Disposal General Permit Agency (EPA) Burden 

and Costs* under 40 CFR 229.3 

Agency Total 

Number of 

Respondents 

Per Year 

Total Number 

of Hours Per 

Year 

Total Labor 

Cost Per 

Year ($)

Total Annual 

O&M Costs 

($)

Total Cost 

Burden ($) 

Burial at Sea 2762.5 303.88 $17,852.66 $552.50 $18,405.16

 Vessel Disposal 3.5 31.50 $2,183.97 $105.00 $2,288.97

TOTAL 2766 335.38 $20,036.62 $657.50 $20,694.12

* These data are from Tables 23 and 24. 

6(f): Burden Statement 
44 

1) Burial at Sea 

The annual public reporting and record keeping burden for this collection of information is 

estimated to average .11 hours per response. EPA has an estimated average of .83 hours per 

response to review and record keep the information collected. 

2) Vessel Disposal 

The annual public reporting and record keeping burden for this collection of information is 

estimated to average 35.5 hours per response. EPA has an estimated average of 9.0 hours per 

response to review and record keep the information collected. 

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 EPA's need for this information, the accuracy of the burden estimates, and 

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. OW-2015-

0613, which is available for public viewing at the Water 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 8:00 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 Water Docket is (202) 566-2426. An electronic version 

of the public docket is available at 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 to access 

those documents in the public docket that are available electronically. Once in the system, select 

“search,” then key in the docket ID number identified above. Also, you can send comments to 

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

Street, NW, Washington, DC 20503, Attention: Desk Office for EPA. Please include the EPA 

Docket ID Number (OW-2015-0613) and OMB control number (2040-0008) in any 

correspondence.