Supporting Statement for ICR 1463.08

Part A.

1. Identification of the Information Collection

1(a) Title: 

National Oil and Hazardous Substances Pollution Contingency Plan (NCP)(Renewal), EPA ICR 1463.08, 

OMB Control Number 2050-0096.

1(b) Abstract: 

ICR 1463.08 is a renewal of ICR 1463.07; the renewal is due July 31, 2011. ICR 1463.08 addresses the 

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

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

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

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

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

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

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

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

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

and, where practical, returned to productive use.

2. Need for and use of the Information Collection

2(a) Need/Authority for Collection:

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

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

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

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

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

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

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

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

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

remedial responses as described in 40 CFR 300.430 and 300.435. 

EPA uses the information provided by the states to ensure state actions are consistent with the provisions 

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

uses the information gathered from private citizens to plan activities geared to educating them where 

necessary, keeping them informed of activities within the community, and ensuring they have had an 

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

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

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

community surrounding a Superfund site is critical to ensuring effective site cleanups.
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2(b) Practical Utility/Users of the Data

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

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

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

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

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

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

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

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

health risks and participate in site-related decisions. 

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

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

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

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

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

those promulgated in a corresponding federal statute.

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

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

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

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

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

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

reuse that meets the communities’ needs. 

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

3(a) Non-duplication

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

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

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

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

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

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

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

comment, was published on May 4, 2011. A 60-day comment period was given; no comments were 

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

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

numbers.
3(c) Consultations

An EPA Superfund database that is updated daily provide the basis for the actual (for the time period FY 

2008-2010) and planned number of proposed plans, RODs and active NPL sites in this ICR. These 

numbers, in conjunction with best professional judgment, serve as the foundation from which estimates of 

the number of activities (e.g., RI/FS, Community Involvement Plans, etc.) were developed in consultation 

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

experts involved feedback on the accuracy of burden and cost estimates. Agency experience in 

addressing community issues has included semi-annual or annual meetings with Regional community 

involvement staff, meetings with groups of states, and meetings with citizen groups. Finally, 

information from actual historical contract activity inform the estimates of the number of hours 

to perform an RI/FS as well as the breakout of labor type when developing an RI/FS.

3(d) Effects of Less Frequent Collection

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

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

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

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

proper implementation of CERCLA.

3(e) General Guidelines

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

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

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

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

for these files will continue beyond the 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. 

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

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

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

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

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

Information Act requests for this information. 

Lists of participants in community interviews and lists of attendees of public meetings are not 

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

privacy concerns. 

3(g) Sensitive Questions

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

4. Respondents and Information requested

4(a) Respondents/SIC Codes

Respondents to this ICR are state/tribal governments and individual community members who voluntarily 

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

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

System used to identify different groups. State/tribal governments are categorized as Division J: Public 

Administration, Major Group 95: Administration of Environmental Quality and Housing Programs, 

Industry Group 951: Administration of Environmental Quality, subgroup 9511: Air and Water Resource 

and Solid Waste Management. The other respondents, community members, do not have a SIC Code as 

they do not constitute an industry.

4(b) Information requested

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

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

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

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

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

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

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

discussed in a subsequent section of this document.

(i) Data items, including record-keeping requirements

Remedial Investigation/Feasibility Study

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

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

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

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

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

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

includes:

- Site description;

- Preliminary definition of the contamination problems;

- Likely contaminant migration pathways;

- Environmental and health effects associated with migration; and

- Description of any initial remedial measures for the site.

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

requirements necessary to support the selection of a remedy are also discussed. 
Based on preliminary site information, the objectives and the scope of work for the RI and FS are 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

identifies potentially hazardous operations and exposures, and prescribes appropriate protective measures. 

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

site. Alternative screening and analysis procedures, methods for conducting a comparative evaluation of 

acceptable alternatives, and details on preparing the FS report are included. 

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

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

any RI field work begins. 

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

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

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

and taking air and water samples, but also time to mobilize drilling equipment and to train personnel in 

the sampling and decontamination techniques to be used at the site. Upon completion of the site work, 

the samples are sent to a laboratory for evaluation, and the results of the analyses are verified. Standard 

evaluation techniques include analyzing samples for organics, metals, and cyanide. 
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The RI serves as the mechanism for collecting data for site and waste characterization and for conducting 

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

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

the mechanism for the development, screening, and detailed evaluation of potential remedial alternatives. 

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

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

additional field investigations. The site characterization developed during the RI provides the data 

necessary to estimate the risks to human health and the environment posed by a site, to establish cleanup 

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

analyzed during the RI in the process of developing alternatives and conducting a detailed analysis of the 

most viable alternatives. Because of the interactive nature of this process, the sequence of the various 

phases and associated activities frequently will not be distinct in practice. 

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

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

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

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

the site. An evaluation of dose-response information is completed to estimate the health effects (e.g., 

incident of certain diseases) that may result from exposure to the hazardous or toxic substances at a site. 

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

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

number of people affected. The uncertainty evaluation is an integral part of the risk assessment process; it 

identifies the degree of uncertainty associated with the final risk estimates by identifying uncertainties 

related to the data and the assumptions. This uncertainties evaluation places bounds on the final estimate 

and target areas needing improvement. The FS process includes the initial evaluation and screening of a 

number of potential alternatives. Alternatives are eliminated from further evaluation for a number of 

reasons, including technical problems, lack of effectiveness in the long term or short term, failure to 

protect human health and the environment, cost, or implementation time. The universe of potential 

remedies is reduced to a reasonable number (usually between three and five) of good alternatives on 

which detailed analyses are conducted. If existing site and treatment data are insufficient to evaluate the 

alternatives adequately, treatability tests may be necessary to evaluate a particular technology or specific 

site wastes. Treatability tests generally involve bench-scale testing to assess the feasibility of a 

technology, although a pilot-scale study may be required in a few situations. 

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

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

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

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

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

strengths and weaknesses of each alternative. At the end of this analysis process, the RI/FS report is 

prepared. 

For the purposes of this analysis, EPA estimates that there will be an average of 95 RI/FS per year. This 

estimate includes new and on-going RI/FS. The state-lead portion of these RI/FS is estimated to be 19

RI/FS per year over the three-year ICR period. The Federal government will have the lead on the 76

remaining sites per year. These estimates are based on historical and planned data obtained from a 
Superfund database. On average, 90 percent of RI/FS are completed within 2-5 years (13-60 mos.) of the 

start date. This average represents an analysis of actual and planned date from Fiscal Year (FY) 2001 to 

FY 2006, grouped both by three-year ICR periods and across the years. The number of RI/FS that EPA 

expects at both Federal and state lead sites represents an average taken across each three-year grouping 

for number of starts and for total time to completion.

Proposed Plans

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

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

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

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

to seek public comment on the preferred alternative for addressing a problem at a site, and on the other 

alternatives discussed in the detailed analysis section of the RI/FS. The Proposed Plan serves as a 

precursor to the Record of Decision (ROD), which details the remedial action to be conducted at the site. 

The ROD is usually is draft form while the Proposed Plan is finalized and released for public comment.

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

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

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

remedy selection process. 

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

a site, identify an initial preferred alternative, and prepare a draft Proposed Plan. The lead agency's 

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

comments. At the end of the support agency review period, the Proposed Plan is finalized and released to 

the public for comment. 

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

Proposed Plan in a local newspaper of general circulation. As required by CERCLA §117(a) (42 USC 

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

alternative and the other alternatives studied. This notice will also announce the availability of the RI/FS 

report and any planned public participation activities, especially the required Proposed Plan Public 

Meeting and 30-day comment period. 

Finally, CERCLA §l17 requires the lead agency to offer the opportunity for a public meeting to discuss 

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

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

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

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

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

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

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

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

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

completed in a discrete amount of time and are assumed not to extend beyond one year. The ROD data 
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comes from the Superfund database and will be discussed in detail in the following section. EPA 

estimates that Proposed Plans will be finalized at 10 state-lead sites in each year of the three years 

covered by this ICR.

Records of Decision

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

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

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

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

decision document used to describe the selected remedy for a site or a particular component of a site (e.g., 

geographic area, pathway, or source control), and to explain the rationale for the selected remedy. In 

addition, RODs demonstrate the lead agency's decision-making process has been carried out in 

accordance with CERCLA and the NCP. RODs typically have three major sections: the Declaration, the 

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

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

sign a ROD. 

The Declaration is the formal statement (signed by the EPA regional administrator or the OSWER 

assistant administrator) that affirms the selected remedy for a site is selected in accordance with CERCLA 

and is consistent, to the extent practicable, with the NCP. It provides a brief description of the selected 

remedy. The Decision Summary is the focus of the ROD. The Summary begins with a brief discussion of 

the site history and a detailed site description, including: 

-Site area and topography, 

-Adjacent land uses; 

-Natural resource uses; 

-Distance to nearby populations; 

-General water resources, and 

-Surface and subsurface features. 

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

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

activities that have been conducted for the site. 

The Decision Summary summarizes the scope of the response action and the site characteristics. The site 

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

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

-All known or suspected sources of contamination;

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

waste;

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

-Potential surface and subsurface pathways of migration.

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

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

site risk assessment and any significant changes made to the preferred alternative in the Proposed Plan are 

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

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

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

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

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

treatment; 

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

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

management process. 

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

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

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

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

CERCLA and provides the best balance among the evaluation criteria. 

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

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

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

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

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

and state ARARs, be cost-effective, and utilize permanent solutions and alternative treatment 

technologies or resource recovery technologies to the maximum extent practicable. A discussion of the 

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

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

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

§117 (42 USC 9617). This part summarizes the written and oral public comments received on the RI/FS 

report, the Proposed Plan, and the Administrative Record and the lead agency's responses to each major 

category of comments. The Responsiveness Summary not only provides decision makers with 

information about community preferences regarding the remedial alternatives considered for a site, but 

also demonstrates to the public how their comments were taken into account as an integral part of the 

decision making process. 

In preparing the Responsiveness Summary, background research is done to identify citizen input and 

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

reviewed, major public comments are organized and summarized, and the lead agency's responses to 

these comments are prepared. The level of effort to be devoted to this section of the ROD varies, 

depending in part on the number, length, and complexity of comments and the number of policy issues 

outstanding at a site.

For the purposes of this ICR, it is estimated that 20 RODs will be completed annually at state-lead sites 

over the three-year ICR period, while 80 RODs will be completed annually by the Federal government. 

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

between FY 2007-2010 and those planned through 2015. The average takes into account that planned 

numbers routinely are higher than actual numbers. 
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Applicable or Relevant and Appropriate Requirements

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

compliance with promulgated state ARARs that are more stringent than Federal ARARs. To this end, the 

current revisions to the NCP require states to identify potential state ARARs for all Federal, state or 

Federal facility-lead sites. States are not reimbursed for any costs associated with researching and 

identifying ARARs for a site.

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

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

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

estimated that a total of 95 sites will require ARAR identification each year.

Administrative Records

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

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

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

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

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

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

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

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

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

typically will be maintained for more than three years. 

The Administrative Record must be maintained at all active Superfund sites each year. For the purposes 

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

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

historical program data, EPA estimates there to be approximately 530 active Federal and state-lead 

Superfund sites. For RI/FS, RD, and RA activities, states have historically had the lead on 20 percent of 

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

Therefore, it is estimated that the state will maintain the administrative record at 106 sites each year.
Initial Community Involvement Plan (CIP)/Revised CIP

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

select techniques and approaches to use in addressing these concerns. The initial CIP developed for a site 

presents the community involvement program that is to be followed during the RI/FS stage of the 

remedial phase. The NCP requires the CIP be completed and in place before field work begins for the RI. 

However, as the Agency seeks to accomplish RI field work during pre-remedial actions to expedite 

cleanups, EPA is finding it necessary to begin its community involvement activity, including preparation 

of the CIP, very early in the pre-remedial phase. The NCP also requires that EPA review its CIP prior to 

the Remedial Design/Remedial Action phase, and make any changes necessary to accommodate changes 

in the community. 

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

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

problems, and potential steps for addressing the problems. As part of this process, lead agency files on 

the site are reviewed and local newspaper files are searched. Once a basic understanding of the site and 

previously performed activities is established, community involvement personnel from the lead agency 

conduct interviews with local community members to better determine community concerns and the level 

of community knowledge of site activities. In this process, a contact list is prepared, interviews are 

scheduled and conducted, and the results of the interviews are summarized. This process also includes 

the use of interviews for the purpose of establishing baseline measures of citizen concerns and attitudes 

from which changes can be measured, as well as to gain additional information that will help in the 

preparation of the CIP. 

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

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

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

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

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

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

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

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

input to site activities. 

In some cases, updates or comprehensive CIP revisions are undertaken at specific benchmarks in the 

Superfund cleanup process, such as after a record of decision (ROD) is signed, at Explanations of 

Significant Differences or ROD amendments, when the remedial action has begun, or at the time of the 

five-year review. Others are updated or revised according to a timetable, such as every three or five years. 

The decision to undertake a comprehensive revision of the CIP sometimes is made based on a change in 

the level or nature of community interest. When there is a high level of interest at a site, the CIP should be 

revised regularly so that the document continues to reflect current conditions and community interests. On 

the other hand, it may be time to conduct a comprehensive CIP revision when community interest has 

waned over a long period of time. It also may be appropriate to revise a CIP after demographic, 

economic, or political change in the community. A CIP revision is in order when CICs believe that a 

change their strategy on involving communities may be necessary.
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Since the Initial CIP is generally developed concurrent with the RI/FS, the estimated number of sites at 

which the state will conduct an RI/FS each year is applied to the Initial CIP. Therefore, EPA expects 19

CIPs to be completed by states each year of the three-year ICR period. Federal-lead sites are expected to 

complete 76 initial CIPs each year. Assuming CIPs are revised every five years for all active Superfund 

sites, Superfund data indicates that states have the lead on approximately 106 active Superfund sites; 

therefore, a rough estimate is that each year 21 of these sites will require a CIP revision. EPA estimates 

that CIPs will be revised at 85 active Federal-lead Superfund sites each year. 

Fact Sheets

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

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

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

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

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

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

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

members. 

EPA estimates that the states are the lead agency for 106 active Superfund sites and, thus, are expected to 

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

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

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

generate far more than four (4) fact sheets in a single year and other sites will require far fewer.

Focus Groups

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

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

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

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

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

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

percent of active sites (one [1] at state-lead sites, four [4] at Federal-lead sites).

Workshops

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

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

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

potential future uses. EPA headquarters and regional Community Involvement staff estimates that a 

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

the lead on 20 percent of active sites, EPA estimates that the state will prepare and conduct a workshop at 

two (2) sites annually. EPA estimates that it will conduct a workshop at eight (8) Federal-lead sites each 

year.
Technical Assistance Grant Application/TAG Management

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

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

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

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

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

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

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

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

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

Community Involvement staff estimate that 10 TAG applications will be filed and 75 maintained each 

year.

Satisfaction Surveys

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

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

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

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

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

improve its community involvement activities and relationships with communities at Superfund sites. 

EPA estimates that these surveys will be completed at five (5) active Superfund Federal-lead sites each 

year. 

(ii)Respondent Activities

In complying with reporting and record-keeping requirements at state-lead sites, state employees may 

need to: 

-Read instructions; 

-Plan activities; 

-Receive training; 

-Gather information; 

-Conduct tests, investigations, and studies; 

-Write documents; 

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

-Complete written forms or other paperwork; 

-Substantiate claims of confidential business information; 

-Record and disclose information; and 

-Store, file, and maintain the information. 

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

-Gather information on new state laws and regulations; 

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

-Record and disclose information; and 

-Store, file, and maintain information. 
14

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

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

-Participate in interviews;

-Participate in focus groups;

-Participate in workshops;

-Apply for a Technical Assistance Grant (TAG)

-Manage a TAG; and

-Respond to surveys. 

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

5(a) Agency activities

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

at state-lead sites to ensure that the Superfund sites are being addressed according to CERCLA and to 

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

gathered by states. The Agency also reviews the state ARARs at all Superfund sites. A standard 10

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

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

and regional Community Involvement employees provided the oversight hours estimates for all other 

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

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

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

management, and satisfaction surveys.

5(b) Collection methodology and management

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

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

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

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

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

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

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

workshops. The regions and states may also communicate with Community Advisory Groups (CAGs) 

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

governments communicate with communities.

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

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

mass data collection efforts. The NCP does not specify a particular method of accomplishing information 

collection; the use of improved information technology is not prohibited in any way. 
5(c) Small entity flexibility

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

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

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

plenty of flexibility.

5(d) Collection schedule

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

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

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

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

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

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

technologies, level of community interest, and duration of each of the remedial stages.

6. Estimating the burden and cost of the Information Collection

6(a) Estimating respondent burden

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

from Superfund databases, contract records, consultation with EPA headquarters and regional staff, and 

information contained in the 2007 version of this ICR. Burden hours are estimated for the number of 

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

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

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

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

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

The estimated number of respondents reported for this information collection is 11,659 This number is 

the sum of all state-lead activities, 409, and people participating in community activities at all sites, 

11,250. The estimated number of responses is 12,977. This is the sum of state responses, 727 state-lead 

activities at all sites each year, and community responses, 12,635 people participating in all activities at 

all sites. 

(i) State Burden Hours

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

government work. The total contractor hours for an RI/FS project, 4,200 hours, is calculated from Office

of Superfund Remediation and Technology Innovation (OSRTI) contract records from 1996 through 

2006. Data for costs billed as direct labor across all projects and years provides information about the 

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

categories based on contract records: 62 percent professional labor, 30 percent direct labor, 4 percent

clerical labor, and 4 percent technical labor. Total contractor hours per RI/FS is estimated to be 4,200 

hours per year, which is estimated to account for 80 percent of the hours for an RI/FS. The remaining 20
16

percent of RI/FS work, 1,050 hours, is done by the state government. Therefore, the total annual time

devoted to a single RI/FS is estimated to be 5,250 hours. This ICR estimates that 19 state-lead sites will 

be in the process of conducting an RI/FS every year. The total annual burden hours is 19,950 (Table 1).

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

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

from the previous ICR renewal. Since Proposed Plans are expected to be completed at 20 state-lead sites 

each year, a total annual estimate of burden is 1,600 hours. 

The hours required to complete a ROD are highly variable across the Superfund program given site 

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

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

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

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

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

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

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

time frame in which one full-time employee dedicates 50 percent of work time to the ROD for a total of 

720 hours, and, two full-time employees dedicate 20 percent of work time for a total of 576 hours. The 

former employee is typically the Remedial Project Manager (RPM) for the site and the latter two 

employees consist of policy analysts, attorneys and managers. This ICR estimates that RODs will be 

completed at 20 state-lead sites each year; thus, the estimated total annual ROD burden to states is 26,000 

hours.

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

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

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

to be evaluated at 95 sites annually, resulting in an estimated burden of 3,135 hours.

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

annually. Since states are estimated to have the lead on 106 active Superfund sites, EPA expects states to 

spend 4,240 total hours on Administrative Records. This estimate is provided by a group of experienced 

EPA headquarters and regional staff.

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

CIPs are estimated to be completed at 19 state-lead sites each year for a total annual burden of 3,800

hours. Revised CIPs are estimated to be completed at 21 state-lead sites each year for a total annual 

burden of 2,100 hours. These hours are estimated by a group of EPA headquarters and regional staff 

experienced in the development and revisions of CIPs.

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

the result of discussion by a group of experienced EPA headquarters and regional Community 

Involvement staff. An average of four (4) fact sheets are expected at each of the 106 estimated state-lead 

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

EPA estimates that states will issue fact sheets at 106 active sites per year. Thus, the total estimated 

annual burden hours for fact sheets is 16,960.
The estimated time that each focus group session will require of the state is 30 hours. This includes 

preparation for the meeting and attendance. EPA expects the state to conduct four (4) focus group 

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

estimates are provided by a group of experienced EPA Community Involvement staff.

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

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

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

experienced in preparing and conducting workshops at Superfund sites.

Table 1: Estimated Burden Hours placed on States

Activity # of Sites 

with Statelead 

Activities/yr

# of 

Activities at 

each site/yr.

Hrs. per 

Activity/yr

Annual Hrs. 

for Activity at 

a Site

Total Annual Hrs. 

for all Sites

RI/FS 19 1 5,250 5,250 99,750

Proposed Plans 20 1 80 80 1,600

RODs 20 1 1,300 1,300 26,000

ARARs 95 1 33 33 3,135

Administrative 

Record

106 1 40 40 4,240

Initial CIP 19 1 200 200 400

Revised CIP 21 1 100 100 2,100

Fact Sheets 106 4 40 160 16,960

Focus Groups 1 4 30 120 120

Workshops 2 1 80 80 160

TOTAL 154,465

(ii) Community Burden Hours

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

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

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

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

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

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

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

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

burden hours for community members for initial and revised CIP interviews, participation in focus groups 
18

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

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

EPA estimates that 40 people will be interviewed for one hour each at 95 Federal and State lead 

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

all sites is 3,800 hours. It is estimated that 25 people will be interviewed for 1 hour each at 106 active 

Superfund sites each year for the purpose of revising the CIPs. Therefore, the total estimated annual 

burden is 2,650 hours (Table 2).

EPA estimates that an average of 15 people will participate in a two-hour focus group 4 times a year at 5 

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

An average of 50 people is expected to participate in a three-hour workshop session once a year at 10 

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

EPA estimates that community groups will apply for available TAGs at 10 Superfund sites. The 

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

sites is 600 hours. Management of TAGs takes place each year at an estimated 75 sites. This requires 

approximately 200 hours per year. The total estimated annual burden for all sites is 15,000 hours.

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

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

all sites is 1,000.
Table 2: Estimated Burden Hours placed on Communities

Activity # Federal 

and Statelead Sites/ 

yr.

# of 

Activities at 

each site

# of 

People 

involved

Hrs. per 

Activity/yr.

Annual Hrs. 

for Activity 

at a Site 

Total Annual Hrs. 

for all Sites 

Initial CIP 

Interview

95 1 40 1 40 3,800

Revised CIP 

Interviews

106 1 25 1 25 2,650

Focus Group 

Participation

5 4 15 2 120 600

Workshop 

Participation

10 1 50 3 150 1,500

TAG 

application

10 1 N/A 60 60 600

TAG 

management

75 1 N/A 200 200 15,000

Satisfaction 

Surveys

5 1 800 0.25 200 1,000

TOTAL 25,150
20

6(b) Estimating respondent costs

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

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

ICR period is addressed in detail below. 

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

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

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

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

process actions in Superfund.

(i) Estimating labor costs

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

General Schedule pay tables for 2011. For the purposes of this ICR, state government salaries are 

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

comprised of 10 percent managerial, 80 percent technical, and 10 percent support staff effort. Thus, a 

weighted average is used to represent the hourly labor rate of government work. To determine the hourly 

wage, 50 percent of the value of a Step 5, GS-12 ($32.73) and GS-13, ($38.72) are summed ($71.65) and 

then adjusted for locality pay using a factor of 1.20, which results in $43.00. To further adjust for 

overhead, $43 is multiplied by 1.6, which results in $68.80, the governmental hourly labor rate applied to 

the following activities conducted by state agencies for the Superfund remedial program: Proposed Plans, 

RODs, ARARs, Administrative Records, initial CIPs, revised CIPs, fact sheets, focus groups, and 

workshops. The same hourly labor rate applies to all Federal activities.

The hourly labor rate for the RI/FS activity is calculated as 20 percent government and 80 percent

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

contractor support. Using past historical rates, the average contractor hourly labor rate is estimated to be 

approximately 62 percent of the average government hourly labor rate. Therefore, the average contractor 

hourly labor rate is estimated to be $42.65. The average government hourly labor rate of $68.80 is used 

for the government’s 20 percent. Therefore, the average hourly labor rate for RI/FS work is $47.88, 

calculated by: [0.2(68.80) + 0.8 (42.65)].

The hourly labor 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 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, $19.20 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

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

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

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

government does incur non-labor costs for the Administrative Records, fact sheets, and satisfaction 
surveys. Community members have no O&M, non-labor or capital costs. States, communities, and the 

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

equipment is purchased for their purposes.

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

records from 1996-2006, adjusted for inflation, using a factor of 2.37, which is the average inflation rate 

in the United States from 2000-2010, based on the Bureau of Labor Statistics’ Consumer Price Index. 

The RI/FS contractor non-labor cost includes $84,301 in fees and profits, $121,301 for equipment, and 

$80,812 for indirect costs such as travel and reports. The equipment costs reflect charges for the use of 

equipment, such as computers and sampling instruments, which the contractor already owns. The total 

non-labor cost for each RI/FS in a single year is, therefore, estimated at $286,413 (Table 3). 

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

moving forward. For the RI/FS it is estimated that contractors incur approximately $40,977 in a single 

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

the Agency are discussed in the following paragraph.

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

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

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

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

conducting the survey to be $6,142. For all other activities with O&M costs, the values from the 2007

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

change value of 2.37. This value is estimated for the three-year period of the ICR based on calculations 

from the Bureau of Labor Statistics’ Consumer Price Index. This number represents an average of the 

percent of cost change from three 3-year periods (2002-2005; 2003-2006; 2007-2010). Using 2.37 as an 

inflation value, the following O&M annual costs for each activity are:

-Proposed Plan: $1,726

-RODs: $1,860

-Administrative Record: $1,398

-Fact Sheets: $1,676

(iii) Annualizing capital costs

No significant capital costs are incurred during the activities described in this ICR.
22

Table 3: Estimated Cost to States

Activity Total 

State-lead 

Activities 

at Sites 

per year

Hours 

per 

Activity

per 

year

Hourly

Labor 

Rate

Labor 

Costs 

per 

Activity

*

Capital 

Costs 

per 

Activity

per year

Contractor 

Related 

Non-labor 

Costs per 

Activity per 

year *

O&M 

Costs 

per 

Activity

per 

year *

Total 

Annual 

Costs 

per 

Activity

Total 

Annual 

Labor 

Costs 

for all 

Sites

Total 

Annual 

Capital 

Costs 

for all 

sites

Contractor 

Related 

Total 

Annual 

Non-labor 

Costs for 

all sites

Total Annual O&M 

Costs for all Sites

Total 

Annual 

Costs 

for all 

Sites

RI/FS 19 5,250 $47.88 $251,370 $0 $286,143 $40,977 $578,490 $4,776,030 $0 $5,436,717 $778,563 $10,991,310

Proposed 

Plans 20 80 $68.80 $5,504 $0 $0 $1,726 $7,230 $110,080 $0 $0 $34,520 $144,600

RODs 20 1,300 $68.80 $89,440 $0 $0 $1,860 $91,300 $1,788,800 $0 $0 $37,200 $1,826,000

ARARs 95 33 $68.80 $2,270 $0 $0 $0 $2,270 $261,440 $0 $0 $0 $261,440

Admin 

Record 106 40 $68.80 $2,752 $0 $0 $1,398 $4,150 $291,712 $0 $0 $148,188 $439,900

Initial CIP 19 200 $68.80 $13,760 $0 $0 $0 $13,760 $261,440 $0 $0 $0 $261,440

Revised 

CIP 21 100 $68.80 $6,880 $0 $0 $0 $6,880 $144,480 $0 $0 $0 $144,480

Fact 

Sheets 424 40 $68.80 $2,752 $0 $0 $1,676 $4,428 $699,176 $0 $0 $710,624 $1,409,800

Focus 

Groups 1 30 $68.80 $2,064 $0 $0 $0 $2,064 $2,064 $0 $0 $0 $2,064

Workshops 2 80 $68.80 $5,504 $0 $0 $0 $5,504 $11,008 $0 $0 $0 $11,008

TOTAL $ 1,709,095 15,492,042

Federal Funds 

Used $

1,709,095 15,230,602

State Funds 

Used $

0 261,440

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

Activity

Total 

Activities 

at 

Federal 

and 

Statelead 

Sites/yr

Hours 

per 

Activity 

per 

year

Hourly 

Labor 

Rate

Annual 

Labor 

Costs per 

Activity 

Capital, 

O&M, 

Nonlabor 

Costs 

per 

Activity 

per 

year

Total 

Annual 

Costs per 

Activity

Total 

Annual 

Labor 

Costs for 

all Sites *

Total 

Annual 

Capital, 

O&M, 

Nonlabor 

Costs 

for all 

Sites

Total 

Annual 

Costs for 

all Sites

Initial CIP 

Interview 3,800 1 $19.20 $19.20 $0 $19.20 $72,960 $0 $72,960 

Revised CIP 

Interviews 2,650 1 $19.20 $19.20 $0 $19.20 $50,880 $0 $50,880

Focus Group 

Participation 600 2 $19.20 $38.40 $0 $38.40 $23,040 $0 $23,040

Workshop 

Participation 1,500 3 $19.20 $57.60 $0 $57.60 $86,400 $0 $86,400

TAG 

application 10 60 $19.20 $1,152.00 $0 $1,152.00 $11,520 $0 $11,520

TAG 

management 75 200 $19.20 $3,840.00 $0 $3,840.00 $288,000 $0 $288,000 

Satisfaction 

Surveys 4,000 0.25 $19.20 $4.80 $0 $4.80 $19,200 $0 $19,200 

TOTAL $552,000 
24

6(c) Estimating Agency burden and cost

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

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

CIPs, the assumption is that Federal oversight hours are 10 percent of the state’s burden hours for 

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

assumption is that Federal oversight hours are 5 percent of the state’s burden hours. These 

assumptions were provided by a group of Headquarters and Regional Community Involvement EPA 

employees with the experience to estimate the average Federal oversight hours for these activities. 

The total estimated annual burden hours placed on EPA for oversight of state activities is 14,713

(Table 5). 

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

Activity # of Sites 

with Statelead 

Activities/yr

# of 

Activities at 

each site

Hrs. per 

Activity/yr

Annual Hrs. 

for Activity at 

a Site 

Total Annual Hrs. 

for all Sites 

RI/FS 19 1 525 525 9,975

Proposed Plans 20 1 8 8 160

RODs 20 1 130 130 2,600

ARARs 95 1 3.3 3.3 314

Administrative 

Record

106 1 2 2 212

Initial CIP 19 1 20 20 380

Revised CIP 21 1 10 10 210

Fact Sheets 106 4 2 8 848

Focus Groups 1 4 1.5 6 6

Workshops 2 1 4 4 8

TOTAL 14,713

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

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

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

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

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

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

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

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

the time of this writing there are approximately 530 active NPL sites (EPA database). Therefore, EPA 

is responsible for maintaining the AR at 424 sites. The total estimated annual burden hours placed on

EPA for Community Involvement activities is 119,730 (Table 6). 
Table 6: Estimated Burden Hours for Federal Community Activities

Activity # Federallead Sites/ 

yr.

# of Activities 

at each site

Hrs. per 

Activity/yr.

Annual Hrs. 

for Activity at 

a Site 

Total Annual 

Hrs. for all Sites

Administrative Record 424 1 40 40 16,960

Initial CIP 76 1 200 200 15,200

Revised CIP 85 1 100 100 8,500

Fact Sheets 450 4 40 160 72,000

Focus Group 4 4 30 120 480

Workshop 8 1 80 80 640

TAG application 10 1 120 120 1,200

TAG management 75 1 50 50 3,750

Satisfaction Surveys 5 1 200 200 1,000

TOTAL 119,730

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

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

80 percent technical, and 10 percent support. To determine the hourly wage, 50 percent of the value of 

a Step 5, GS-12 ($32.73) and GS-13, ($38.72) 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. Labor costs to EPA are the only Federal costs accounted for oversight 

of state activities. The total estimated annual costs incurred by EPA for oversight of state activities is 

$1,012,254 (Table 7). The total estimated annual costs EPA incurs for Community Involvement 

activities is $11,846,976 (Table 8).
26

Table 7: Estimated Costs for Federal Oversight of State Activities

Activity

Total 

Statelead 

Activities 

at Sites 

per year

Hours 

per 

Activity 

per 

year

Hourly 

Labor 

Rate

Annual 

Labor 

Costs 

per 

Activity 

*

Annual 

Capital, 

O&M, 

Nonlabor 

Costs 

per 

Activity

Total 

Annual 

Costs 

per 

Activity

Total 

Annual 

Labor 

Costs 

for all 

Sites *

Total 

Annual 

Capital, 

O&M, 

Nonlabor 

Costs for 

all Sites

Total 

Annual 

Costs 

for all 

Sites

RI/FS 19 525 $68.80 36,120 $0 36,120 686,280 $0 686,280

Proposed 

Plans 20 8 $68.80 550 $0 550 11,000 $0 11,000

RODs 20 130 $68.80 8,944 $0 8,944 178,880 $0 178,880

ARARs 95 3.3 $68.80 227 $0 227 21,568 $0 21,568

Administrative 

Record

106 2 $68.80 138 $0 138 14,586 $0 14,586

Initial CIP 19 20 $68.80 1,376 $0 1,376 26,144 $0 26,144

Revised CIP

21 10 $68.80 689 $0 689 14,469 $0 14,469

Fact Sheets

424 2 $68.80 138 $0 138 58,512 $0 58,512

Focus 

Groups 4 1.5 $68.80 103 $0 103 413 $0 413

Workshop 2 4 $68.80 275 $0 275 550 $0 550

SUBTOTAL 1,012,402

Cooperative Agreement Federal $ to States (Table 3) 15,230,602

* Rounded to the nearest whole dollar TOTAL $ 16,243,004
Table 8: Estimated Costs to the Federal Government for Community Activities

Activity

Total 

Activities 

at 

Federal 

lead 

Sites/yr

Hours per 

Activity 

per year

Hourly 

Labor 

Rate

Annual 

Labor 

Costs per 

Activity *

Annual 

Capital 

Costs per 

Activity

Annual 

Non-labor 

Cost per 

Activity

Annual 

O&M 

Costs per 

Activity

Total 

Annual 

Costs per 

Activity

Total 

Annual 

Labor 

Costs for 

all Sites *

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

Admin. 

Record 424 40 $68.80 2,752 $0 $0 1,398 4,150 1,166,848 $0 $0 592,752 1,759,600

Initial CIP 76 200 $68.80 13,760 $0 $0 $0 13,760 1,045,760 $0 $0 0 1,045,760

Revised CIP 85 100 $68.80 6,880 $0 $0 $0 6,880 584,800 $0 $0 0 584,800

Fact Sheets 1800 40 $68.80 2,752 $0 $0 $1,676 4,428 4,953,600 $0 $0 3,016,800 7,970,400

Focus Group 16 30 $68.80 2,064 $0 $0 $0 2,064 33,024 $0 $0 0 33,024

Workshop 8 80 $68.80 5,504 $0 $0 $0 5,504 44,032 $0 $0 0 44,032

TAG 

application 10 120 $68.80 8,256 $0 $0 $0 8,256 82,560 $0 $0 0 82,560

TAG 

management 75 50 $68.80 3,440 $0 $0 $0 3,440 258,000 $0 $0 0 258,000

Satisfaction 

Surveys 5 200 $68.80 13,760 $0 $0 $ 13,760 68,800 $0 $0 0 68,800

TOTAL 11,846,976

* Rounded to the nearest whole dollar
28

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

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

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

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

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

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

document.

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

(i) Respondent tally

The total burden hours and costs displayed in the table below reflects the combined burden and costs 

on both categories of respondents: states at state-lead sites and individual community members 

participating voluntarily at Superfund sites. Community costs of $552,000 (Table 4) are all 

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

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

government. The actual cost to states is $261,440 (Table 3) for the ARAR analysis.

 Table 9: Total Respondent Burden Hours and Costs

Respondent Annual 

Burden

Annual Cost Total 3 yr. 

Burden

Total 3 yr. 

Cost

States 154,465 $261,440 463,395 $784,320

Communities 25,150 $552,000 76,530 $1,656,000

Total 179,615 $813,440 539,925 $2,440,320
30

(ii) Agency tally

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

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

communities at Superfund sites.

 Table 10: Total Federal Agency Burden Hours and Costs

Agency Annual 

Burden

Annual Cost Total 3 yr. 

Burden

Total 3 yr. 

Cost

Federal OversightStates14,713 $16,243,004 44,139 $48,729,012

FederalCommunity 

Activities

119,730 $11,846,976 359,190 $35,540,928

Federal Total 134,443 $28,089,980 403,329 $84,269,940

(iii) Variations in the annual bottom line

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

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

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

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

6(f) Reasons for change in burden

The burden in terms of cost and hours for this ICR has increased, There is an increase of 108,000 

hours in the total estimated burden currently identified in the OMB Inventory of Approved 

ICR Burdens. This increase is primarily due to an adjustment in estimates attributable to the 

increase in the number of sites estimated to have RI/FS starts and ongoing RI/FS activity as well as an 

the increase in the number of sites expected to have Proposed Plans developed. In addition, cost 

models were updated to reflect wage inflation. 

The net total estimated annual burden hours for respondents has increased by approximately 108,000 

hours. This increase affects states whose annual estimated burden has increased from 40,185 hours to 

154,465 hours. Again, this increase is attributable to a greater number of state-lead RI/FS and 

Proposed Plans. On the other hand, the estimated community-related annual burden hours has 

decreased from 30,980 hours to 25,150 due to fewer TAG applications and the number of ongoing 

TAGs. The total estimated annual costs to respondents has increased for both communities (by 

$40,830) and states (by $200,195); these increases are attributable to wage inflation for both and, for 

states, is also due to the increase in the number of sites for which the identification of ARARs is 

estimated to be required (an additional 50 sites). The estimated amount that will actually be funded 

with state monies is $261,440. 
6(g) Burden statement

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

154,465. The total estimated annual burden hours placed on communities is 25,510. Total burden 

hours placed on 11,659 respondents through 12,977 responses is 179,615 hours. The annual public 

reporting and recordkeeping burden for this collection of information is estimated to average 13.84

hours per response. 

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

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

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

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

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

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

community. 

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

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

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

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

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

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

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

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

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

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

chapter 15. 

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

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

collection techniques, EPA has established a public docket for this ICR under Docket ID No. EPAHQ-SFUND-2011-0177. This docket is available for public viewing at the Superfund Docket in the 

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

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

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

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

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

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

documents in the public docket that are available electronically. 

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

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

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

include the EPA Docket ID No. EPA-HQ-SFUND-2011-0177 and OMB control number 2050-0096 in 

any correspondence. 
32

Part B.

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

information.