Final 11/01/2006

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

Cooperative Agreements and Superfund State Contracts for Superfund Response Actions

(Final Rule)

1. Identification of the Information Collection

1(a) Title of the Information Collection

Cooperative Agreements and Superfund State Contracts for Superfund Response Actions

(Final Rule). OMB Control Number 2050-0179, EPA ICR Number 1487.09.

1(b) Short Characterization/Abstract

This is a request for an updated Information Collection Request (ICR) accompanying the 

issuance of a revised regulation. The title of this submission is: “Cooperative Agreements and 

Superfund State Contracts for Superfund Response Actions.” This ICR authorizes the collection 

of information under EPA’s Superfund Rule at 40 CFR Part 35, Subpart O, that establishes the

administrative requirements for CERCLA-funded cooperative agreements for State, political 

subdivisions, and Federally-recognized Indian Tribes and Tribal Consortia response actions. The 

regulation includes only those provisions mandated by CERCLA, required by OMB circulars, or 

added by EPA to ensure sound and effective financial assistance management under this 

regulation. The information is collected from applicants and/or recipients of EPA assistance and 

is used to make awards, pay recipients, and collect information on how Federal funds are being 

utilized. EPA requires this information to meet its Federal stewardship responsibilities. 

Recipient responses are required to obtain a benefit (Federal funds) under 40 CFR Part 31, 

“Uniform Administrative Requirements for Grants and Cooperative Agreements to State and 

Local Governments” and under 40 CFR Part 35,

“State and Local Assistance.”

It is estimated that the information collection will involve 316 new respondents and 338

amendments to existing agreements with recipients impose a burden of 5073 hours and 

$149,687.04. Previous Information Collection burdens were approved under OMB control 

number 2050-0179. This prior ICR was approved without any terms of clearance.

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

This ICR is necessary due to the information collection and reporting requirements in the 

Superfund rule 40 CFR Part 35, Subpart O, “Cooperative Agreements and Superfund State 

Contracts for Superfund Response Actions.” Due to the statutory cost recovery requirements in 
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CERCLA and the need to carefully track all costs, Superfund recipients must comply with 

administrative requirements sufficient to meet these provisions of the law. The regulation sets 

forth the pre-award, post-award, and closeout cooperative agreement requirements which are 

conditions for receiving/managing a Superfund Cooperative Agreement (CA) or a Superfund 

State Contract (SSC). This information is needed by EPA project officers, grant specialists, and 

finance officials to manage/oversee the funding activities and cleanup activities at Superfund 

sites. EPA also uses the information to update the Comprehensive Environmental Response, 

Compensation, and Liability Information System (CERCLIS) which tracks progress made at 

Superfund sites, and to update IFMS, EPA’s database for tracking financial management.

2(b) Practical Utility/Users of the Data

The information collected is used by EPA to manage and administer cooperative 

agreements and Superfund State Contracts for Superfund response actions. The pre-award 

information is used to qualify cooperative agreement applicants and award cooperative 

agreements. The post-award information is used to meet the statutory and regulatory

requirements and monitor recipient performance. The closeout information is used to meet 

reporting and record keeping requirements necessary for cost recovery purposes and for closing 

out awards. The information is necessary to ensure fiscal control and accountability for 

Superfund money to deter waste, fraud, and abuse.

40 CFR Part 35, Subpart O, also supplements EPA’s general assistance regulation, 

40 CFR Part 31, “Uniform Administrative Requirements for Grants and Cooperative Agreements 

to State and Local Governments.” Part 31, which implements the requirements of OMB Circular 

A-102, became effective for awards made on or after October 1, 1988. The Part 31 rule (common 

rule) established uniformity among Federal agencies that award Federal grants and cooperative 

agreements to States, political subdivisions thereof, and Federally-recognized Indian Tribes and 

Tribal Consortia. Many of the information collection requirements for Superfund cooperative 

agreements were approved under the OMB Paperwork Clearance #2030-0020 associated with 40 

CFR Part 31 prior to this ICR.

Due to statutory cost recovery requirements, and the need to carefully track costs by site 

and activity, Superfund recipients must comply with all administrative requirements to satisfy the 

provisions of the law. There are additional requirements in this regulation, which supplements 

Part 31, and are necessary for effective cost recovery from potentially responsible parties. States 

may be able to follow their own rules for certain aspects of the program, such as in procurement, 

if their administrative requirements and financial management capabilities are sufficient.

3. Non duplication, Consultations, and Other Collection Criteria

3(a) Non duplication
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All information collected is used to continue administering cooperative agreements and 

Superfund State Contracts for Superfund response actions. This data is not available from other 

sources, as it is specifically related to the requirements of 40 CFR Part 35, Subpart O, and the 

award, management, and closeout of cooperative agreements and Superfund State Contracts 

within this program.

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

This information collection request will accompany 40 CFR Part 35 Subpart O in the 

reissuance process for that regulation.

3(c) Consultations

This is a request for renewal of an information collection request, and in addition to the 

initial Federal Register notice, the following organizations were contacted to provide additional 

input towards the calculation of burden imposed by this ICR:

Bureau of Waste Site Cleanup

MA Dept. of Environmental Protection

One Winter St.

Boston, MA 02108

Illinois Environmental Protection Agency

1021 North Grand Avenue East 

P.O. Box 19276

Springfield, IL 62794-9276

NJ Dept. of Environmental Protection 

CN 413

Trenton, NJ 08625

OK Dept. of Environmental Quality

707 N. Robinson Street

P.O. Box 1677 (Mailing Address)

Oklahoma City, OK 73101-1677

OR Department of Environmental Quality

2020 SW Fourth Ave., Suite 400

Portland, OR 97201

TN Dept. of Environment & Conservation

401 Church St., L&C Annex, 4th Fl.

Nashville, TN 37243-1538
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VA Dept. of Environmental Quality

P.O. Box 10009 

629 E. Main St., 10th Fl.

Richmond, VA 23240-0009

UT Dept. of Environmental Quality

168 North 1950 West

Salt Lake City, Utah 84116

CA Dept. of Toxic Substances Control

1011 N. Grandview

Glendale, CA 91201

One of the organizations contacted responded. That respondent commented on the burdens 

presented in the burden table, stating that the Record Retention burden appeared to be 

undervalued due to increased new requirements for the provision of documentation and additional 

cases entering cost recovery. EPA agrees with this comment and has consequently increased the 

burden estimate by 0.5 hours to 6.0 hours per Cooperative Agreement. 

3(d) Effects of Less Frequent Collection

There is no fixed schedule for the collection of this information. It is required on an as 

needed basis as stated in the rule at 40 CFR Part 35, Subpart O, “Cooperative Agreements and 

Superfund State Contracts for Superfund Response Actions.” Therefore, there is no possibility

that the information can be collected less frequently than required by the regulation. 

3(e) General Guidelines

The information collection is consistent with the guidelines set forth in 5 CFR 1320.5 of 

the Paperwork Reduction Act Guidelines.

3(f) Confidentiality

No sensitive information is expected to be collected under this ICR. However, any

information submitted to the Agency for which a claim of confidentiality is made will be 

safeguarded according to the Agency policies set forth in Title 40, Chapter 1, Part 2, Subpart B -

Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 1976; 

amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, 

March 23, 1979).

3(g) Sensitive Questions
Final 5 11/01/2006

None of the information being collected will contain sensitive questions or require 

collecting sensitive information.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are:

SIC Codes NAICS Codes

Other General Government 

Support

9119 921190 

American Indian and Alaska 

Native Tribal Governments

8641 921150

 

4(b) Information Requested

(i) Data Items (Including recordkeeping requirements)

Information requested – Information relating to the following cooperative agreement types 

and Superfund State Contracts will be collected to ensure sound and effective financial assistance 

management and to help EPA meet its Federal stewardship responsibilities under this program:

 Pre-Remedial Cooperative Agreements;

 Remedial Response Cooperative Agreements;

 Enforcement Cooperative Agreements;

 Removal Cooperative Agreements;

 Core Program Cooperative Agreements;

 Support Agency Cooperative Agreements;

 Consolidated Funding Cooperative Agreements;

 Conclusion of the Cooperative Agreement; 

 Superfund State Contract; 

 Conclusion of Superfund State Contracts; and

 Records Retention.

This information will also be used to update and maintain the IFMS database.

(ii) Respondent Activities

Respondents will:
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 Prepare and submit cooperative agreements/Superfund State Contract application materials

including work plans; 

 Conduct research and gather data as needed; 

 Prepare and submit quarterly/or bi-annual/or annual reports that contain: (1) An

explanation of work accomplished during the reporting period, delays, or other problems, 

if any, and a description of the corrective measures that are planned. For Pre-remedial 

Cooperative Agreements, the report must include a list of the site-specific products 

completed and the estimated number of technical hours spent to complete each product.

(2) A comparison of the percentage of the project completed to the project schedule, and 

an explanation of significant discrepancies. (3) A comparison of the estimated funds spent 

to date to planned expenditures and an explanation of significant discrepancies. For 

remedial, enforcement, and removal reports, the comparison must be on a per task basis.

(4) An estimate of the time and funds needed to complete the work required in the 

Cooperative Agreement, a comparison of that estimate to the time and funds remaining, 

and a justification for any increase.

 Prepare other standardized non-construction assurances referenced and covered under 40 

CFR Part 31 and OMB Circular A-102;

 Perform required recordkeeping activities; 

 Respond to EPA requests for additional information; and

 Perform other activities as necessary as required by 40 CFR Part 35, Subpart O.

5. The Information Collected: Agency Activities, Collection Methodology, and Information 

Management

5(a) Agency Activities

EPA will collect the requested information using standardized reports and record keeping 

appropriate to support cost recovery. The grants information is entered into IGMS, the Agency’s 

database for tracking the status of grant/cooperative agreement actions. Financial information is 

entered into IFMS, the Agency’s database for tracking financial management.

5(b) Collection Methodology and Management

EPA will conduct activities in connection with the acquisition, analysis, storage, and 

utilization of the requested cooperative agreement and Superfund State Contract-related 

information and financial data. This information and financial data are reviewed in accordance 

with the requirements of 40 CFR Part 35, Subpart O. 

Superfund recipients must retain records for 10 years following the submission of the final 

Financial Status Report, and must retain those records longer if an enforcement action is ongoing. 

This ensures that response action information will be available to support EPA litigation efforts to 

recover Superfund costs from responsible parties. The Agency also conducts periodic on-site 

reviews to ensure recipient compliance with applicable requirements.
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5(c) Small Entity Flexibility

There are no small businesses affected by this information collection. Small Governmental 

Jurisdictions are affected, but the burden is minimal, and steps have been taken to reduce the 

burden imposed by this information collection. As 40 CFR Part 35, Subpart O is a fully-funded 

regulation, all burden imposed by the regulation is required in order for recipients to obtain and 

manage financial awards. 

5(d) Collection Schedule

The collection schedule for this information relating to cooperative agreements and 

Superfund State Contracts is variable depending on such factors as: date of applications, 

magnitude of efforts, and project periods, etc. 

6. Estimating the Burden and Cost of the Collection

Table 1, “Total Respondent Burden,” documents the computation of individual burdens for 

providing the information required for the application and administration of each type of 

cooperative agreement and each Superfund State Contract included in this ICR. The individual 

burden is expressed under a heading believed to be consistent with the concept of burden under 

the Paperwork Reduction Act. Responses to this information collection are mandatory, as they

are required to properly manage and administer the funds awarded under cooperative agreements 

and Superfund State Contracts.

The 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.

6(a) Estimating Respondent Burden

A “unit” burden is the burden incurred by a respondent for performing a cooperative 

agreement specific activity. States incur burdens under an estimated 654 cooperative agreement 

and Superfund State Contract activities per year for reporting, certifications, schedules, 

notifications, assurances, and record keeping activities. The estimated burden is incurred by

activities under the following types of Cooperative Agreements/Superfund State Contracts and 

other requirements:

 Pre-Remedial Cooperative Agreements;

 Remedial Response Cooperative Agreements;

 Enforcement Cooperative Agreements;

 Removal Cooperative Agreements;

 Core Program Cooperative Agreements;

 Support Agency Cooperative Agreements;
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 Consolidated Funding Cooperative Agreements;

 Conclusion of the Cooperative Agreements; 

 Superfund State Contract; 

 Conclusion of Superfund State Contracts; and 

 Records Retention.

The estimated average burden associated with each Cooperative Agreement/Superfund 

State Contract/Other requirement is discussed below and summarized in Table 1, “Total 

Respondent Burden.” 

The estimated burden associated with Pre-Remedial Cooperative Agreements represents 

the number of hours that are spent in identification of environmental results, research, data 

collection, analysis, negotiation, preparation, and post-award monitoring of the Pre-Remedial 

Cooperative Agreement. EPA estimates that approximately 47 (14 new respondent CAs and 33

amended respondent CAs) Pre-Remedial Cooperative Agreements involving States, Tribes, or 

political subdivisions, will be in place each year. EPA estimates that an average of 9 hours are 

necessary to prepare all the plans, compliance documents, lists and schedules required in the 

application for this type of Cooperative Agreement within Subpart O. 

The estimated burden associated with Remedial Response Cooperative Agreements 

represents the number of hours that are spent in identification of environmental results, research, 

plan preparation, data collection, analysis, negotiation in preparing the materials required for, and 

post-award monitoring of Remedial Response Cooperative Agreements. EPA estimates that 

approximately 55 (20 new respondent CAs and 35 amended respondent CAs) Remedial Response 

Cooperative Agreements, which involve States, Tribes, and political subdivisions, will be in place 

each year. EPA estimates that an average of 18 hours is necessary to prepare all the materials 

required in an application for this type of Cooperative Agreements. Those materials include: a 

project narrative, which includes much more site-specific information than a project narrative for 

a Pre-Remedial Cooperative Agreement; compliance documents and certifications; CERCLA 

assurances; and notifications. The majority of the burden under this Cooperative Agreement is 

associated with the preparation of the schedule of deliverables. Though the format of that 

schedule is fairly standard, the planning and negotiation involved can be time consuming. 

The estimated burden associated with Enforcement Cooperative Agreements represents the 

number of hours that are spent in identification of environmental results, research, plan and 

certification documentation preparation, such as the quality assurance plan, data collection, 

analysis in the preparation of materials involved in acquiring and operating within an 

Enforcement cooperative agreement. EPA estimates that an average of 20 (11 new respondent 

CAs and 9 amended respondent CAs) Enforcement Cooperative Agreements will be in place each 

year. EPA also estimates that approximately 29 hours are needed to fulfill the requirements 

imposed by this type of Cooperative Agreement. Those requirements include: creating the site 

description; creating the site specific statement of work; producing the statement designating lead 

site project manager; creating the site specific health and safety plan; producing the quality 
Final 9 11/01/2006

assurance plan; developing the schedule of deliverables; and producing a copy of the applicable 

state, local, or tribal statutes. The majority of the burden is imposed by the creation of the site 

specific statement of work, the quality assurance plan, and the schedule of deliverables.

The estimated burden associated with Removal Response Cooperative Agreements 

represents the number of hours that are spent in identification of environmental results, research, 

plan preparation, data collection, analysis, negotiation in preparing the materials required for, and 

post-award monitoring of a Removal Response Cooperative Agreement EPA estimates that 

approximately 4 (2 new respondent CAs and 2 amended respondent CAs) Removal Response 

Cooperative Agreements, which involve States, Tribes, and political subdivisions, will be in place 

each year. EPA estimates that an average of 29 hours is necessary to prepare all the materials 

required for this type of Cooperative Agreement. Those required materials include: a site 

description; a site specific statement of work; a statement designating lead site project manager; a 

site specific community relations plan; a site specific health and safety plan; a quality assurance 

plan; a schedule of deliverables. Program experience has shown that the majority of the burden 

imposed under the requirements for this type of Cooperative Agreement can be attributed to the 

development of the schedule of deliverables and the quality assurance plan. 

The estimated burden associated with Core Program Cooperative Agreements represents 

the number of hours that are spent in identification of environmental results, research, data 

collection, analysis, negotiation in preparing the materials required for, and post-award 

monitoring of a Core Program Cooperative Agreement. EPA estimates that 54 (17 new 

respondent CAs and 37 amended respondent CAs) Core Program Cooperative Agreements, which 

involve States, Tribes, and political subdivisions, will be in place each year. Superfund program 

experience indicates that 29 hours are needed to fulfill the requirements imposed by this type of 

Cooperative Agreement. Those requirements include preparing a statement of work, and a 

background statement. Those two requirements are responsible for the majority of burden 

attributed to Core Program Cooperative Agreements.

The estimated burden associated with Support Agency Cooperative Agreements represents 

the number of hours that are spent in identification of environmental results, research, data 

collection, analysis, negotiation in preparing the materials required for, and post-award 

monitoring of a Support Agency Cooperative Agreement. EPA estimates that approximately 63

(19 new respondent CAs and 44 amended respondent CAs) Support Agency Cooperative 

Agreements, which involve States, Tribes, and political subdivisions, will be in place each year. 

EPA estimates that an average of 8 hours are needed to prepare all the materials required for this 

type of Cooperative Agreement. The majority of the burden imposed by a Support Agency 

Cooperative Agreement can attributed to the development of the required statement of work. This 

burden has been reduced from the last ICR due to recent rule revisions eliminating Support 

Agency cost sharing for Federally-recognized Indian Tribes and Tribal Consortia.

The estimated burden associated with Consolidated Funding Cooperative Agreements 

represents the number of hours that are spent in identification of environmental results, research, 
Final 10 11/01/2006

data collection, analysis, negotiation, and preparation of Consolidated Funding Cooperative 

Agreements each year. EPA estimates that approximately 5 (1 new respondent CAs and 4

amended respondent CAs) Consolidated Funding Cooperative Agreements are in place each year. 

EPA estimates that approximately 42 hours a year are necessary to meet the requirements of a 

Consolidated Funding Cooperative Agreement. A Consolidated Funding Cooperative Agreement 

is composed of a Pre-Remedial, Core Program, and Support Agency Cooperative Agreement. The 

potential three-fold burden from this type of Cooperative Agreement can be attributed to the 

increase in the paperwork needed to document, track, and respond to the requirements for each 

cooperative agreement type. However, a savings in burden is expected from Consolidated 

Funding Cooperative Agreements due to consolidated administration and reporting requirements, 

and other common elements, thus, Consolidated Funding Cooperative Agreements have a cost 

that is smaller than the sum of each of the three Cooperative Agreement types. While a savings 

does occur, considering the burden of each type of combined Cooperative Agreement, the current 

estimate of 20 hours for the Consolidated Funding Cooperative Agreement appears to be too low. 

Averaging the estimate of 52 hours (the sum of the three types of Cooperative Agreements) with 

the 20 hour prior ICR burden estimate yields the more realistic estimate of 36 hours used in the 

present burden tables.

The estimated burden associated with the Conclusion of a Cooperative Agreement 

represents the number of hours that are spent in assembling and reconciling financial data, 

identifying any outstanding contractual issues, assembling relevant Cooperative Agreement data 

deliverables and other documentation, coordinating with USEPA personnel in the disposition of 

equipment and other acquisitions under the cooperative agreement, determining final cost shares 

and preparing the site for the operation and maintenance phase of the Superfund State Contract 

each year. EPA estimates that approximately 30 (30 new respondent CAs and 0 amended 

respondent CAs) Superfund State Contracts are concluded each year. The Superfund Subpart O 

Workgroup estimates that 11 hours are needed to meet the burden imposed by the requirements 

under a Superfund State Contract. Those requirements include: General Authorities; Purpose 

statement; site description; statement to follow guidance; statement of work; schedule of 

deliverables; SPOC; CERCLA assurances; list of Support Agency Cooperative Agreements; 

sanctions for failure to comply with the terms of the Superfund State Contract; site access; joint 

inspection of the remedy; exclusion of third party benefits; State review; and a list of responsible 

party activities.

The estimated burden associated with the contents of a Superfund State Contract 

represents the number of hours that are spent in identification of environmental results, research, 

data collection, analysis, negotiation, and preparation of the Superfund State Contract each year. 

EPA estimates that approximately 9 (4 new respondent CAs and 5 amended respondent CAs) 

Superfund State Contracts are in place each year. The Superfund grants program workgroup 

estimates that 24 hours are needed to meet the burden imposed by the requirements under a 

Superfund State Contract. Those requirements include: General Authorities; Purpose statement; 

site description; statement to follow guidance; statement of work; schedule of deliverables; 

SPOC; CERCLA assurances; list of Support Agency Cooperative Agreements; sanctions for 
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failure to comply with the terms of the Superfund State Contract; site access; joint inspection of 

the remedy; exclusion of third party benefits; State review; and a list of responsible party

activities.

The estimated burden associated with the Conclusion of a Superfund State Contract 

represents the number of hours that are spent in assembling and reconciling financial data, 

identifying any outstanding contractual issues, assembling relevant Cooperative Agreement data 

deliverables and other documentation, coordinating with USEPA personnel in the disposition of 

equipment and other acquisitions under the Cooperative Agreement, determining final cost shares 

and preparing the site for the operation and maintenance phase of the Superfund State Contract 

each year. EPA estimates that approximately 42 (42 new respondent CAs and 0 amended 

respondent CAs) Superfund State Contracts are concluded each year. The Superfund Subpart O 

Workgroup estimates that 7 hours are needed to meet the burden imposed by the requirements 

under a Superfund State Contract. Those requirements include: General Authorities; Purpose 

statement; site description; statement to follow guidance; statement of work; schedule of 

deliverables; SPOC; CERCLA assurances; list of Support Agency Cooperative Agreements; 

sanctions for failure to comply with the terms of the Superfund State Contract; site access; joint 

inspection of the remedy; exclusion of third party benefits; State review; and a list of responsible 

party activities.

The estimated burden associated with the Records Retention requirements represents the 

number of hours that are spent each year beyond the 10-year (Superfund) retention requirement 

for record maintenance, storage, and any document requests that would be made throughout the 

year. All cooperative agreements must meet these Records Retention requirements, and incur the 

resulting burden. EPA estimates that approximately 327 (158 new respondent CAs and 169

amended respondent CAs) Cooperative Agreements will be in place each year. Superfund 

program experience indicates that an average of 3 hours will be required each year to meet the 

burden imposed by this regulation’s Records Retention requirements. 

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

For all activities covered by this ICR, wage rates for State, Tribal, and political subdivision 

personnel are estimated to be comparable to those of Federal government personnel. These wage 

rates were estimated based upon corresponding Federal GS wage rates as of January 2006. The 

rates, as outlined below are multiplied by a 1.6 benefits multiplication factor to account for 

government overhead expenses. 

Management GS 13, step 1 $50.46/hour

Technical GS 11, step 1 $35.41/hour

Clerical GS 7, step 1 $23.92/hour
Final 12 11/01/2006

These rates are from the Office of Personnel Management (OPM) “2006 General 

Schedule” which excludes locality rates of pay. These rates can be obtained from the OPM 

website, http://www.opm.gov/oca/06tables/html/gs_h.asp. It is further estimated that 

approximately 20% of the respondent activity is Managerial, 70% is Technical, and 10% is 

Clerical in nature. Based upon the above, the weighted average is $37.27 per hour 

[(50.46*0.2)+(35.41*0.7)+(23.92*0.1)].

(ii) Estimating Capital and Operation and Maintenance Costs

The only type of costs associated with this information collection activity is labor costs. 

There is no estimated Capital/Startup and Operation and Maintenance Costs associated with this 

collection of information.

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs

The total capital/startup costs for this ICR are $0. 

The total operation and maintenance (O&M) costs for this ICR are $0. 

The total respondent costs in block 14 have been calculated as the addition of the 

capital/startup costs, and the annual operation and maintenance costs. The average annual cost for 

capital/startup and operation and maintenance costs to respondents over the next three years of the 

ICR is estimated to be $0. 

(iv) Annualizing Capital Costs

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with maintenance, analysis, and 

utilization of the collected information. 

The average Agency cost for the collection and administration of the information required 

by this ICR is estimated to be $207,347.25 [see Table 2]. This cost is based on the average hourly 

labor rate at a GS-12, Step 1, times a 1.6 benefits multiplication factor to account for government 

overhead expenses for a total hourly rate of $42.45.

These rates are from the Office of Personnel Management (OPM) “2006 General 

Schedule” which excludes locality rates of pay. These rates can be obtained from the OPM 

website, http://www.opm.gov/oca/06tables/html/gs_h.asp. Details upon which this estimate is 

based appear in Table 2, “Total Agency Burden,” below.

6(d) Estimating the Respondent Universe and Total Burden and Costs
Final 13 11/01/2006

Based on our research for this ICR, approximately 654 respondents will provide the 

information required under 40 CFR Part 35, Subpart O each year.

The number of Total Annual Responses is 654. 

The total annual labor costs are $149,687.04. Details regarding these estimates may be 

found in Table 1. (Total Respondent Burden).

Note that the total annual capital and O&M costs to the regulated entity are $0. These 

costs are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) 

Costs.

6(e) Bottom Line Burden Hours Burden Hours And Cost Tables

The bottom line burden hours and cost tables for both the Agency and the respondents 

appear below in Table 1. The annual respondent burden for this collection of information is 

estimated to average 8 hours per response. Variations in the Annual Bottom Line?

6(f) Reasons for Change in Burden

The decrease in burden from the most recently approved ICR of $65,653 and 990 hours

reflects a change in methodology from the prior ICR. In the prior ICR, burden was assigned on 

“full respondent” basis and an average number of respondents per year. In this revised ICR 

burden is now computed using a five year average of the actual number of new cooperative 

agreements awarded and the actual number of amendments to those cooperative agreements. This 

more sophisticated method revealed that the “full (new)” respondent population has decreased, 

but there is an increased number of total respondents due to the addition of “amendments”. 

Revisions to pricing factors from the Regions and States modified some prior burden estimates. 

New cooperative agreement policies such as the Environmental Results under EPA Assistance 

Agreements, and the Post Award Monitoring Policy have added a significant burden to annual CA 

burden hours, therefore 3 hours per CA type (1 hour for amendment CAs) have been added to 

account for this increased monitoring need. 

6(g) Burden Statement

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 
Final 14 11/01/2006

valid OMB Control Number. The OMB Control Numbers for EPA’s regulations are listed at 40 

CFR Part 9 and 48 CFR Chapter 15.

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

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

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID Number EPA-HQ-SFUND-2004-0008, which is available for public viewing at the 

OSWER Docket in the EPA Docket Center (EPA/DC), EPA West, Room B102, 1301 

Constitution Avenue., N.W., Washington, D.C. The EPA Docket Center Public Reading Room is 

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

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

OSWER Docket is (202) 566-0276. An electronic version of the public docket is available at 

www.regulations.gov. This site can be used to submit or view public comments, access the index 

listing of the contents of the public docket, and to access those documents in the public docket 

that are available electronically. 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, N.W., Washington, D.C. 

20503, Attention: Desk Office for EPA. Please include the EPA Docket ID Number EPA-HQSFUND-2004-0008 and OMB Control Number 2050-0179 in any correspondence. 

NOTE: The EPA Docket Center suffered damage due to flooding during the last week of June 

2006. The Docket Center is continuing to operate. However, during the cleanup, there will be 

temporary changes to Docket Center telephone numbers, addresses, and hours of operation for 

people who wish to make hand deliveries or visit the Public Reading Room to view documents.

Consult EPA's Federal Register notice at 71 FR 38147 (July 5, 2006) or the EPA website at 

http://www.epa.gov/epahome/dockets.htm for current information on docket operations, locations 

and telephone numbers. The Docket Center’s mailing address for U.S. mail and the procedure for 

submitting comments to www.regulations.gov are not affected by the flooding and will remain the 

same.

Part B of the Supporting Statement

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

information.
Final 15 11/01/2006

Table 1: Total Respondent Burden

Activity 

Average 

number of 

respondents 

per Year

(Full) 2006

Unit 

Burden 

(Hours)

Unit Labor 

Cost 

(Dollars)

Total Unit 

Cost 

(Dollars)

Total Burden 

(Hours)

Total Cost 

(Dollars)

Pre-Remedial CA New 13.8 10 $37.27 $372.70 138 $5,143.26

Amendment 32.8 8.7 $12.30 $107.01 285.36 $3,509.93

Remedial 

response CA

New 19.6 23 $37.27 $857.21 450.8 $16,801.32

Amendment 35 13 $12.30 $159.90 455 $5,596.50

Enforcement CA New 10.8 46 $37.27 $1,714.42 496.8 $18,515.74

Amendment 9.4 12.7 $12.30 $156.21 119.38 $1,468.37

Removal 

response CA 

New 1.8 45 $37.27 $1,677.15 81 $3,018.87

Amendment 1.6 13 $12.30 $159.90 20.8 $255.84

Core program 

CA 

New 17.4 11 $37.27 $409.97 191.4 $7,133.48

Amendment 36.6 6 $12.30 $73.80 219.6 $2,701.08

Support agency 

CA 

New 18.8 11 $37.27 $409.97 206.8 $7,707.44

Amendment 44 5.7 $12.30 $70.11 250.8 $3,084.84

Superfund State 

Contract 

New 4.2 33 $37.27 $1,229.91 138.6 $5,165.62

Amendment 5.4 14.3 $12.30 $175.89 77.22 $949.81

Conclusion of 

Superfund State 

Contract 

New 41.8 8 $37.27 $298.16 334.4 $12,463.09

Amendment 0 5.3 $12.30 $65.19 0 $0.00

Consolidated 

funding CA 

New 0.4 77 $37.27 $2,869.79 30.8 $1,147.92

Amendment 4 7.7 $12.30 $94.71 30.8 $378.84

Conclusion of 

CA 

New 29.8 16 $37.27 $596.32 476.8 $17,770.34

Amendment 0 5.3 $12.30 $65.19 0 $0.00

Records retention New 158.4 6 $37.27 $223.62 950.4 $35,421.41

Amendment 168.8 0.7 $12.30 $8.61 118.16 $1,453.37

TOTAL $149,687.04

TOTAL NUMBER OF RESPONDENTS * 654

TOTAL BURDEN HOURS* * 5,072.92

AVERAGE BURDEN HOURS PER RESPONDENT* * 7.75

TOTAL COST $149,687.04

*Amendment respondents are assumed to have only 1/3 of the burden imposed as Full respondents, since the 

process of amending is not as extensive as it is for a new application for a CA.
Final 16 11/01/2006

Table 2: Total Agency Burden

Activity 

Average 

number of 

respondents 

per Year

(Full) 2006

Unit 

Burden 

(Hours)

Unit Labor 

Cost 

(Dollars)

Total Unit 

Cost 

(Dollars)

Total Burden 

(Hours)

Total Cost 

(Dollars)

Pre-Remedial CA New 13.8 26 $42.45 $1,103.70 358.8 $15,231.06

Amendment 32.8 8.7 $14.01 $121.89 285.36 $3,997.89

Remedial 

response CA

New 19.6 39 $42.45 $1,655.55 764.4 $32,448.78

Amendment 35 13 $14.01 $182.13 455 $6,374.55

Enforcement CA New 10.8 38 $42.45 $1,613.10 410.4 $17,421.48

Amendment 9.4 12.7 $14.01 $177.93 119.38 $1,672.51

Removal

response CA 

New 1.8 39 $42.45 $1,655.55 70.2 $2,979.99

Amendment 1.6 13 $14.01 $182.13 20.8 $291.41

Core program 

CA 

New 17.4 18 $42.45 $764.10 313.2 $13,295.34

Amendment 36.6 6 $14.01 $84.06 219.6 $3,076.60

Support agency 

CA 

New 18.8 17 $42.45 $721.65 319.6 $13,567.02

Amendment 44 5.7 $14.01 $79.86 250.8 $3,513.71

Superfund State 

Contract 

New 4.2 43 $42.45 $1,825.35 180.6 $7,666.47

Amendment 5.4 14.3 $14.01 $200.34 77.22 $1,081.85

Conclusion of 

Superfund State 

Contract 

New 41.8 16 $42.45 $679.20 668.8 $28,390.56

Amendment 0 5.3 $14.01 $74.25 0 $0.00

Consolidated 

funding CA 

New 0.4 23 $42.45 $976.35 9.2 $390.54

Amendment 4 7.7 $14.01 $107.88 30.8 $431.51

Conclusion of 

CA 

New 29.8 16 $42.45 $679.20 476.8 $20,240.16

Amendment 0 5.3 $14.01 $74.25 0 $0.00

Records retention New 158.4 5 $42.45 $212.25 792 $33,620.40

Amendment 168.8 0.7 $14.01 $9.81 118.16 $1,655.42

TOTAL $207,347.25

TOTAL NUMBER OF RESPONDENTS * 654

TOTAL BURDEN HOURS* * 5,941.12

AVERAGE BURDEN HOURS PER RESPONDENT* * 9.07

TOTAL COST $207,347.25

*Amendment respondents are assumed to have only 1/3 of the burden imposed as Full respondents, since the 

process of amending is not as extensive as it is for a new application for a CA.