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June 2011 Page 1 of 60 

## RENEWAL OF INFORMATION COLLECTION REQUEST FOR THE CONTINUOUS RELEASE REPORTING REQUIREMENT Including Analysis for Use of Continuous Release Reporting Forms

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Page 2 of 60 1. ID ENTIFICATION OF THE INFORMATION COLLECTION ................................ ................... 4 1a. Title of the Information Collection ................................ ................................ .......................... 4 1b. Short Characterization/Abstract ................................ ................................ ............................... 4 2. NEED FOR AND USE OF THE COLLECTION ................................ ................................ .......... 6 2a. Need and Authority

for the Collection ................................ ................................ .................... 6 2b. Practical Utility

and Users of the Data ................................ ................................ .................... 7 3. NON DUPLICATION, CONSUL TAT IONS, AND OTHER COLLECTION CRI TERIA .......... 7 3a. Non Duplication ................................ ................................ ................................ ....................... 7 3b. Public Notice Required Prior to I CR Submission to OMB ................................ ..................... 8 3c. Consultations ................................ ................................ ................................ ........................... 8 3d. Effects of Less Frequent Collection ................................ ................................ ........................ 9 3e. General Guidelines ................................ ................................ ................................ .................. 9 3f. Confidentiality ................................ ................................ ................................ ......................... 9 3g. Sensitive Questions ................................ ................................ ................................ .................. 9 4. THE RESPONDENTS AND THE INFORMATION REQUESTED ................................ ............ 9 4a. Respondents and SI C Codes ................................ ................................ ................................ .... 9 4b. In formation Requested ................................ ................................ ................................ ............. 9 i. Data items, including record keeping requirements ................................ ........................... 9 ii. Respondent Activities ................................ ................................ ................................ ....... 13 5. THE INFORMATION COLLECTED

– AGENCY ACTIVITIES, COLLECTI ON METHODOLOGY, AND INFORMATION MANAGEMENT ................................ .................. 14 5a. Agency

Activities ................................ ................................ ................................ .................. 14 5b. Collection Methodology and Management ................................ ................................ ........... 15 5c. Small Entity

Flexibility ................................ ................................ ................................ .......... 15 5d. Collection Schedule ................................ ................................ ................................ ............... 15 6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION ................................ ...... 16 6a. Estimating Respondent Burden ................................ ................................ ............................. 16 Exhibit 1 – Unit Burden Hours per Respondent Information Collection Activity ... 17 Exhibit 1 (With Forms) – Unit Burden Hours per Respondent Information Collection Activity ................................ ................................ ............................... 18 Exhibit 2 – Burden Hours for a Typical Facility ................................ ......................... 23 Exhibit 2 (With Forms) – Burden Hours for a Typical Facility ................................ . 24 6b. Estimating Respondent Costs ................................ ................................ ................................ 24 i. Estimating Labor Costs ................................ ................................ ................................ ..... 24 Exhibit 3 – Unit Labor Cost per Respondent Information Collection Activity ........ 25 Exhibit 3 (With Forms) – Unit Labor Cost per Respondent Information Collection Activity ................................ ................................ ................................ ................. 26 Exhibit 4 – Annual Labor Costs for a Typical Facility ................................ ............... 26 Exhibit 4 (With Fo rms) – Annual Labor Costs for a Typical Facility ....................... 27 ii. Estimating Capital and Operations and Maintenance Costs ................................ ............. 27 Exhibit 5 – Unit Operating and Maintenance Costs per Respondent Information Collection Activity ................................ ................................ ............................... 28 Exhibit 5 (With Forms) – Unit Operating and Maintenance Costs per Respondent Information Collection Activity ................................ ................................ ......... 29

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Page 3 of 60 Exhibit 6 – Operating and Maintenance Costs for a Typical Facility ....................... 29 Exhibit 6 (With Forms) – Operating and Maintenance Costs for a Typical Facility 30 Exhibit 8 – Labor and Operating and Maintenance Costs for a Typical Facility .... 31 Exhi bit 8 (With Forms) – Labor and Operating and Maintenance Costs for a Typical Facility ................................ ................................ ................................ .... 32 6c. Estimating Agency

Burden and Cost ................................ ................................ ..................... 33 Exhibit 9 – Unit Burden Hours and Costs Incurred by the Government per Information Collection Activity ................................ ................................ ......... 33 Exhibit 9 (With Forms) – Unit Burden Hours and Costs Incurred by the Government per Information Collection Activity ................................ ........... 34 6d. Estimating the Respondent Universe and Total Burden and Cost ................................ ......... 36 Exhibit 10 – Number of Facilities and Hazardous Substance Releases Already Affected by the CRRR ................................ ................................ ........................ 37 Exhi bit 11 – Number of Facilities and Hazardous Substance Releases That Will Be Affected by the CRRR in the Next Three Years ................................ .............. 37 6e. Bott om L ine Burden Hours and Cost Tables ................................ ................................ ......... 38 i. Respondent Tally ................................ ................................ ................................ .............. 38 Exhibit 12 – Annual Burden Hours and Costs Incurred by Industry ....................... 39 Exhibit 12 (With Forms) – Annual Burden Hours and Costs Incurred by Industry 40 ii. The Agency

Tall y ................................ ................................ ................................ ............. 41 Exhibit 13 – Annual Burden Hours and Costs Incurred by Government ................. 42 Exhibit 13 (With Forms) – Annual Burden Hours and Costs Incurred by Government ................................ ................................ ................................ ......... 43 iii. Variations in the Annual Bottom L ine ................................ ................................ .............. 44 Exhibit 14 – Summary of Burden Hours and Costs Incurred by Industry ............... 44 Exhibit 14 (With Forms) – Summary of Burden Hours and Costs Incurred by Industry ................................ ................................ ................................ ................ 45 Exhibit 15 – Summary of Burden Hours and Costs Incurred by Government ........ 45 Exhibit 15 (With Forms) – Summary of Burden Hours and Costs Incurred by Government ................................ ................................ ................................ ......... 45 6f. Reasons for Change in Burden ................................ ................................ .............................. 46 6g. Burden Statement ................................ ................................ ................................ ................... 46 ATTACHMENT A – Continuous Release Reporting Forms ................................ ....................... 48

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Page 4 of 60 1. ID ENTIFICATION OF THE INFORMATION COL LECT ION 1a. Title of the Information Collection Continuous Release Reporting Regulations (CRRR) under the Comprehensive Environmental Response, Compensation, and L iability Act o f 1980 (CERCLA) - EPA No. 1445.11 . 1b. Short Characterization/Abstract This infor mation collection request (ICR) addresses the reporting and record keeping activities required to comply with EPA ’ s continuous release reporting regulation (CRRR; 40 CFR 302.8) implementing section 103(f)(2) of the Comprehensive Environmental Response, Compensation, and L iability Act of 1980 (CERCLA). The CRRR clarifies the ty pes of releases that qualify for reporting under CERCLA section 103(f)(2) and establishes the reporting requirements applicable to qualifying releases. Responsibility for information collection activities of the CRRR reside in the Office of Emergency Management (OEM) in the Office of Solid Waste and Emergency Response (OSWER). This I CR renews the collection activity previousl y approved under OMB No. 2050 - 0086 and applies to the perio d January 1, 2012 through December 31, 2014 . 1 

## Estimates of the burden placed on industry and the government to comply with the release notification requirements are presented on an annual basis. The anal ys is also includes estimates for the burden and cos t impacts of using continuous release reporting forms on both the industry and government in order to comply with the release notification requirements. Information pertaining to the use of continuous release reporting forms appears in “green” type. CERC LA section 103(a) requires persons in charge of a facility or vessel to immediately notify the National Response Center (NRC) of any hazardous substance release that equals or exceeds its reportable quantity (RQ) and is not federall y permitted. Notificati on under CERCLA is intended to ensure that Federal authorities receive prompt notification of hazardous substance releases for which a timely response may

be necessary

to protect public health or welfare or the environment from an y adverse effects that may be associated with the release. Section 103(f)(2) of CERCLA provides relief from the per - occurrence notification requirements of section 103(a) for hazardous substance releases that are “ continuous, ” and “ stable in quantity and rate, ” provided that such releases are reported “ annuall y, or at such time as there is any statistically significant increase ” in the quantity

of the release. Section 103(f)(2) contemplates that, in the case of certain “ continuous ” and “ stable ” releases, the no tification objectives of CERCLA can be achieved with less frequent reporting. The regulated community is expected to:

1 2050 - 0086 (EPA No. 1445.07) was approved without change on December 31, 2008 and expires on December 31, 2011. 2050 - 0086 (EPA No. 1445.08, 1445.09, and 1445.10) are associated with the OMB approval of the Continuous Release Reporting Form (EPA Form Number 6100 - 10) that expires 12/31/2011. The forms are contained in Attachment A to this document and also availabl e at: www.epa.gov/emergencies/content/reporting/rqover.htm#con .

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Page 5 of 60 • Gather necessary

release data, such as the time, quantity , and source of the release;

• Notify

the facility manager of the release;

• Consult with the environmental compliance expert regarding the release;

• Make an initial report of the release to the NRC;

• Submit an initial written notification to the appropriate EPA Regional Office for the geographical area where the releasing f acility or vessel is located;

• Provide follow - up notification within 30 day s of the first anniversary date of the initial written notification;

• Make notifications to the NRC if there is a change in the release, including a statistically

significant in crease in a release;

• Make an annual evaluation of releases to determine if changes have occurred in the information submitted in the initial written notification, the follow - up notification and/or in a previous change notification - if there are no chan ges, submittal of a report is not required.

• Keep all supporting documents, materials, and other information on file for a period of one year to substantiate the reported normal range of releases, the basis for stating that the release is continuous and stable in quantity and rate, and the other information in the initial written report, the follow - up report, and the annual evaluations. The continuous release final rule has been in effect since September 24, 1990. This I CR utilizes historical data on the number of continuous release reports submitted to the Federal government to estimate the number of burden hours attributable to the CRRR. The statistics on the number of continuous release reports submitted to the Federal government are available throu gh the National Response Center ’ s incident data base. 2 

## In the first year of the three - ye ar period covered by this ICR, it is estimated th at 3,856 facilities will be affected b y the CRRR. Of the 3,856 facilities affected in the first year, it is assumed that 8 will be reporting continuous releases for the first time and the remaining 3,848 will be meeting information collection requirements for ongoing releases. In the second and third years, it is estimated that 8 and 9 additional facilities, respectivel y, will generate reportable continuous releases. When calculating the burdens and costs in this I CR it has been assumed that the ty pical facility

participates in information collection activities for each release. For example, the typical facility will p rovide an 2 

### That data base is available at: http://www .nrc.uscg.mil/incident_type_2000up.html

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Page 6 of 60 initial telephone notification and written report for each of its continuous releases. In fact, it is likely that many facility operators will consolidate collection activities for releases at their facilities (e.g., provide one telephone notifi cation for several releases). Assuming eight releases per facility per ye ar, and thus 8 information collection activities per facility per year, the total number of continuous release information collection activities in the first year of the three - ye ar p eriod covered by this I CR is estimated to be 30,850 ( 62 initial notification activities and 30,787 ongoing notification activities). In the second and third years of the period covered by this ICR, it is estimated that 67 and 72 i nformation collection activities, respectively , will take place. The total estimated burden to respondents is approximately 315,176 , 315,947 , and 316,775 hours in years 1 , 2 , and 3, respectivel y. For the regulated community , the estimated information col lection activity costs (including labor and O&M costs) are $15,418,910 , $15,455,690 , and $15,496,208 in years 1, 2, and 3, respectivel y . The total estimated burden to the government is approximately 27,926 , 27,821 , and 27,902 hours in years 1, 2, and 3, respectivel y. The estimated total cost to the government is $1,290,424 , $1,285,535 , and $1,289,296 , in years 1, 2, and 3 , respectivel y. We estimate that the use of continuous release reporting forms will reduce overall burden to respondents b y approximately 62 , 67 , and 72 hours in years 1, 2, and 3, respectivel y. 3 

## For the regulated community, the we estimate that the information collection activity costs (including labor and O&M costs) will be reduced b y $2,903 , $3,121 , and $3,355 in years 1, 2, and 3, respectivel y. The estimated burden reduction to the government is approximately 6,676 , 6,634 , and 6,655 hours in ye ars 1, 2, and 3, respectively . The estimated reduction in cost to the government is $308,494 , $306,565 , and $307,49 7 , in years 1, 2, and 3, respectively . 2. NEED FOR AND USE OF THE COLLECTION 2a. Need and Authority

for the Collection The information collection required in the CRRR (40 CFR 302.8) is fully authorized under CERCLA section 103(f)( 2) and section 104(e). CERCLA section 103(f)(2) provides relief from the notification requirements of CERCLA section 103(a) for hazardous substance releases that are “ continuous, ” “ stable in quantity and rate, ” and for which notification has been given un der CERCLA section 103(a) “ for a period sufficient to establish the continuity , quantity , and regularity” of the release. Further, CERCLA section 103(f)(2) requires that notification of releases qualified as continuous under the CRRR must be provided “ annually , or at such time as there is any statistically significant increase ” in the quantity of the release. The specific information provided in the required notifications is authorized under CERCLA section 104(e). CERCLA section 104(e) authorizes the col lection of information, entry , and inspection and sampling activities for the purposes of determining the need for a response, or choosing or taking any response action under CERCLA. In addition, CERCLA section 103(f)(2) establishes a notification sy stem that documents information provided in the respondent notifications. The information collection and management requirements 3 

### The burden reduction is estimated to be one hour/initial notification activity and information collection activity which is wh y these numbers are the same as the paragraph above.

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Page 7 of 60 of the CRRR are necessary to determine if a response action is needed to control or mitigate any potential adverse effects associat ed with a reported hazardous substance release. 2b. Practical Utility

and Users of the Data The information collected under the CRRR is used to evaluate the acute and chronic effects of the continuous release to determine if a response action is necessary to prevent or mitigate any adverse effects. An y hazardous substance release that equals or exceeds its RQ warrants a timely evaluation of its source, emission rate, and chemical form, the proximity of sensitive populations or ecos ys tems, and the ambient conditions, to ensure the protection of public health and welfare and the environment. Agency

responses to continuous hazardous substance release notifications may take a number of forms ranging from requests for more detailed information (to allow for a more detailed risk assessment), to the imposition of more stringent emissions limitations, to removal and/or remedial actions. Finally, the release notification information is used by State and local government emergency

planners to conduct State and local em ergency response planning. 3. NON DUPLICATION, CONSUL TAT IONS, AND OTHER COLLECTION CRI TERIA 3a. Non Duplication The hazardous substance release information requested under the CRRR in the initial written and follow - up reports is the minimum information necessary to properly

evaluate a hazardous substance release. EPA anal yz ed possible areas of overlap with other regulations, concluding that there are limited areas of overlap with reporting requirements under other statutes and provisions. In particular, some facilities may need to provide similar hazardous substance release information to satisfy reporting requirements for the Toxic Release Inventory (TRI) report under SARA section 313. The level of duplication, however, is limited because of differences in the list of chemicals, and the SI C and facility

sizes affected by

SARA section 313. SARA section 313 requirements onl y apply to facilities in certain SI C categories whose inventory quantities exceed 10,000 pounds; CERCLA section 103 affects facilities in all SI C codes regardless of inventory amounts. In addition, the SARA section 313 list of toxic chemicals includes only about one - fourth of the listed CERCLA hazardous substances. Further, the SARA section 313 list includes some substances that are not on the CERCLA list at all. To minimize any

duplication in reporting, EPA allows facilities that are subject to the reporting requirements of both regulations to submit the SARA section 313 report (otherwise known as the TRI report) as a substitute for the written reports required under the CRRR, provided that certain additional continuous release information is included as an addendum to the TRI report. If the TRIreport is submitted in lieu of the continuous release written report, based on each source rel ease, the following continuous release information must also be included in the TRIreport: (1) the upper and lower bounds (normal range) of the release over a 24 - hour period of each hazardous substance; (2) the frequency of the release from each release s ource; (3) a signed statement

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Page 8 of 60 describing the basis for asserting that the release is continuous and stable in quantity and rate; (4) the population density

within a one - mile radius; and (5) the identity and location of any

sensitive populations and ecos ys t ems within a one - mile radius. These additions will provide EPA with information that is not available from the TRI report, but is required to properly evaluate the need for a government response. Additionally , continuous release reporting under CERCLA se ction 103(f)(2) eliminates frequent and repetitive reporting under CERCLA section 103(a). If a facility with continuous releases were to report on a per - occurrence basis under section 103(a), the facility could be notifying the NRC daily . Respondents with continuous releases may be unnecessarily

reporting under CERCLA section 103(a) because they : (1) may not be familiar with the reduced reporting option under section 103(f)(2), or (2) may not realize that there is a reduced burden associated with a one ti me initial telephone notification and submission of an initial written report and one follow - up report under the CRRR. EPA ’ s outreach efforts to increase industry awareness are described in Section 5(b). As respondents become more aware of the CRRR and the ability to simplify

and reduce expenses associated with continuous release reporting, it is possible that some reports could be redirected from CERCLA section 103(a) (ERNS) to CERCLA section 103(f)(2) (CR - ERNS). 3b. Public Notice Required Prior to I CR Submi ssion to OMB In compliance with the Paperwork Reduction Act (PRA) (44 U.S.C. 3501 et seq .), EPA has notified the public through the Federal Register notice on the renewal of this I CR (See TBD ). [ This section will be completed for the Final OMB Submission , based on the results of public comment. ] 3c. Consultations EPA consulted with a number of Federal and State government agencies in the development of the information collection activities described in this I CR. To develop the CRRR, EPA formed a Workgroup t o address the comments received on the Notice of Proposed Rulemaking (NPRM) published on April 19, 1988 (53 FR 12868). The Workgroup consisted of representatives from various EPA program offices, the ten EPA Regions, and the NRC. EPA Regional offices were responsible for the implementation of the final rule. Participation by these parties in the Workgroup was sufficient to address and resolve all outstanding issues. The comments received on the NPRM are addressed in the Response to Comments Document and in the preamble to the final rule. EPA sponsored several workshops throughout the country for industry

and Federal, State, and local government officials on the release notification requirements under CERCLA and SARA Title III, including the requirements under the CRRR. The workshops were held to educate the regulated community as well as those Federal and State agencies required to implement the regulations. In addition, the workshops provided an opportunity for the public to comment on the implementation of the regulation. No workshops were conducted or planned during the period covered b y IC R 1445.0 7 ( January 2009 through December 2011 ). ICR 1445.08, 1445.09, and 1445.10 are associated with the OMB approval of the Continuous Release Repo rting Form (EPA

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Page 9 of 60 Form Number 6100 - 10) that expires December 31.2011. The forms are contained in Attachment A to this document and are also available at www.epa.gov/emergencies/content/reporting/rqover.htm#con . 3d. Effects of Less Frequent Collection The frequency

of information collection established in the CRRR is the minimum level necessary for proper evaluation of continuous releases. If the information collected under the CRRR, such as the source, frequency , and composition of the release, the environmental media affected, and the identity

and location of an y s ensitive populations or ecos ys tems, were collected less frequentl y than stipulated under the C RRR, the Federal government ’ s ability to properl y evaluate the threat posed b y the release and the need for a response action would be jeopardized. 3e. General Guidelines The regulations imposed by CERCLA section 103(f)(2) adhere full y to OMB ’ s general guidel ines concerning the collection of information and the control of paperwork burdens on the public. 3f. Confidentiality The regulations implementing CRRR do not require the submittal of any proprietary , trade secret, or other confidential information. 3g. Sensitive Questions The regulations implementing CRRR do not require the submission of any sensitive business information. In addition, the information collection requested under these regulations is in compliance with the Privacy Act of 1974 and OMB Circular A - 1 08. 4. THE RESPONDENTS AND THE INFORMATION REQUESTED 4a. Respondents and SI C Codes This section is not applicable. The usage and release of hazardous substances are pervasive throughout industry . EPA expects a number of different industrial categories to repor t hazardous substance releases under the provisions of the CRRR. No one industry sector or group of sectors is disproportionately

affected by

the information collection burden. 4b. In formation Requested i. Data items, including record keeping requirements

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Page 10 of 60 To en sure that government authorities receive timely and sufficient information to evaluate potentially

dangerous hazardous substance releases reported under CERCLA section 103(f)(2), the CRRR requires seven ty

pes of information collection activities: (1) An initial telephone call to the NRC; (2) An initial written report to the EPA Region; (3) A one - time follow - up written report to the EPA Region on or before the first - ye ar anniversary

of the submission of an initial written report; (4) An annual evaluation of a release beginning the year after the submission of the one time follow - up written report; (5) Notification to the NRC and EPA Regions of a change in the sources, composition, or frequency of a release; (6) Notification to the EPA Region of a change in other information pr eviously submitted; and (7) Immediate notification to the NRC of any statistically significant increase (SSI) in the quantity of a release. The time required b y a facility to complete the seven information collection activities varies and is largel y contingent on the nature of the reported releases and the facility ’ s information collection procedures. However, EPA estimated the average amount of time that is needed to perform these seven information collection activities and the average unit burden hours. The estimates are presented in section 6(a). The unit burden hours used in this I CR are based upon estimates from the CRRR economic anal ys is. The CRRR Economic Impact is available in rulemaking Superfund Docket Number 103(f)CR - 4 - 8. Reporting continuous r eleases represents a reduction in burden for facilities that would otherwise report releases on a per - occurrence basis. EPA believes that the notification sy stem developed under the CRRR represents the minimum level of reporting necessary for the Federal On Scene Coordinator (OSC) to evaluate whether a response action is needed to prevent or mitigate any hazards to public health and welfare and the environment. The following paragraphs briefl y describe the purpose and timing of each information collection activity and list the data items that comprise each notification. Initial Telephone Notification to the NRC

– The initial telephone call to the NRC serves to notify government authorities of the facility ’ s intent to report a hazardous substance release under CERCLA section 103(f)(2). All such releases must be released in a continuous and stable manner. The initial telephone call, in conjunction with the initial written report, fulfills the statutory requirement that the release be reported under CERCLA section 103(a) for a period sufficient to establish the continuity , quantity , and regularity of the release. The information provided in the initial telephone notification must include: (8) The name and location of the facility ; and (9) The name(s) and identity( ies) of the hazardous substance(s) being released.

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Page 11 of 60 Initial Written Report and the Follow - up Written Report

– The initial written report and the follow - up written report, which are sent to the EPA Region, provide a full description of the release. The ini tial written report and follow - up written report serve as the basis for a comprehensive evaluation of the hazards posed b y the release. Based on this comprehensive evaluation, government authorities determine if a response action is necessary to prevent o r mitigate any adverse effects. The initial written report must be submitted within 30 day s of the initial telephone call. This 30 - day period does not necessarily provide enough time to collect all relevant and appropriate data, but does allow for an ini tial evaluation of the release. The follow - up written report, due one year after submission of the initial written report, serves to verify the information provided on the initial written report (NOTE: there cannot be any form of change in source, composi tion, or frequency of release without going through the process again). The follow - up written report helps ensure that the information used to evaluate the hazards posed by the release is current and provides accurate information. The data elements reque sted in the initial written and follow - up report are identical and consist of: (10) The name of the facility or vessel; the location, including the longitude and latitude; the case number assigned by the National Response Center or Environmental Protection Age ncy ; the Dun and Bradstreet number of the facility (if available); the port of registration of the vessel (if applicable); and the name and telephone number of the person in charge of the facility or vessel. [40 CFR 302.8(e)(1)(i)] (11) A signed statement that the hazardous substance release described is continuous and stable in quantity

and rate under the definitions of 40 CFR 302.8(b) and that all reported information is accurate and current to the best knowledge of the person in charge. [40 CFR 302.8(e)(1)(i v)(H)] (12) The population density within a one - mile radius of the facility or vessel, described in terms of the following ranges: 0 - 50 persons, 51 - 100 persons, 101 - 500 persons, 501 - 1,000 persons, and more than 1,000 persons. [40 CFR 302.8(e)(1)(ii)] (13) The identity

and location of sensitive populations and ecos ys tems within a one - mile radius of the facility

or vessel (e.g., elementary schools, hospitals, retirement communities, or wetlands). [40 CFR 302.8(e)(1)(iii)] In addition, facilities must provide the following substance - specific information for each continuous release: (14) The sources of the release, including specific source information (e.g., valves, pump seals, storage tank vents, stacks). [40 CFR 302.8(e)(1)(iv)(C)] (15) The environmental medium(a) affec ted b y the release: if air, provide stack height or surface area affected; if surface water, the name of the surface water body; if a

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Page 12 of 60 stream, the stream order or average flow rate and designated use; if a lake, the surface area and average depth; if on or under ground, the location of public water supply wells within two miles. [40 CFR 302.8(e)(1)(iv)(G)(1 - 4)] (16) The frequency

of the release and the fraction of the release from each release source and the period over which it occurs. [40 CFR 302.8(e)(1)(iv)(D )] (17) A brief statement describing the basis for stating that the release is continuous and stable in quantity

and rate. [40 CFR 302.8(e)(1)(iv)(E)] (18) The name and identity of the hazardous substance; and the Chemical Abstracts Service Registry

Number for the substance. If the release is a mixture, the hazardous substance components of the mixture and their approximate concentrations and quantities, by

weight. [40 CFR 302.8(e)(1)(iv)(A)] (19) The upper and lower bounds of the normal range of the release over the previous ye ar. [40 CFR 302.8(e)(1)(iv)(B)] (20) An estimate of the total annual amount of the hazardous substance released in the previous year (in pounds or kilograms). [40 CFR 302.8(e)(1)(iv)(F)] Annual Evaluation of a Release

– Although a reporting facility is no longer required to submit a written report on its continuous releases after submitting a one - time written follow - up report verifying the information provided on the initial written report remained the same, the reporting facility

must conduct and d ocument an annual assessment of its continuous releases beginning the ye ar after the submission of the follow - up written report. The purpose of the annual evaluation is to identify

any changes that may

have occurred in the release situation over the prece ding year. The annual evaluation of a continuous release helps ensure that the information used to evaluate the hazards posed by the release is current and accurate information. Change in the Source, Composition, or Frequency of a Release Report

– If the re is a change in the source, composition, or frequency of a release, the release must be reported and treated as a new continuous release. An initial telephone notification and written change report must be provided as described above. The person in charge also must submit a follow - up report within one ye ar of the change report. Other Changes in Information

– Facilities experiencing a change in a continuous release that invalidates information previously submitted on the continuous release must notify the appropriate EPA Region by letter within 30 day s of the change. The letter regarding the change in the rel ease should explicitly identify the new (or changed) information and include an explanation for the change. For example, a facility must notify EPA if an y schools, hospitals, retirement homes, or other developments housing sensitive populations are open w ithin one mile of the facility . Statistically Significant Increase Report

– The CRRR defines a SSIas a release of a

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Page 13 of 60 hazardous substance that exceeds the upper bound of the normal range of the release as established by the facility . The normal range of a release is defined by the range of release weights (in pounds or kilograms) recorded during the preceding year under normal operating conditions (that is, conditions that prevail during the period establishing the predictability and regularity of the rele ase). Therefore, a SSIdoes not include releases within the reported normal range of release. An SSI release is considered an episodic release because it is a release above the RQ. Thus, SSI s must be immediately

reported to the NRC by

telephone pursuant to the notification requirements of CERCLA section 103(a). The information collected by the NRC in a SSIreport includes the same information supplied when reporting an y other episodic release (e.g., quantity of the release, source of the release, and a description of any response actions taken). The person in charge of a facility with a SSI may

modify the previously

established normal range as an alternative to reporting multiple SSI s. To modify the normal range of the release over a 24 - hour period und er normal operating procedures, the person in charge of the facility must report at least one SSIto the NRC as an episodic release (to facilitate immediate evaluation), and then must submit a written change report of the release information to the appropriate EPA Region describing the new normal range and reasons for the change; thus treating the SSI as a new release. Thus, for example, if a facility

doubles its production level thereby doubling its release level, the facility may want to double its repor

ted normal range of the continuous release, rather than reporting multiple SSI s. The person in charge also must submit a follow - up report within one year of the submission of the change report . Record keeping

– Facilities may maintain a log or some other record of each hazardous substance release reported under CERCLA section 103(f)(2). The information documented in the record can be used to demonstrate compliance with the provisions of the CRRR, including the requirement to demonstrate the continuity an d stability

of the release and the requirement to conduct an annual evaluation of the release. Additionall y, facilities may find it useful to document daily release quantities for use in substantiating and modifying the normal range of the release.

ii. R espon dent Activities To comply

with the provisions of the CRRR, the regulated community performs the following information collection activities: (1) Provides an initial telephone call to the NRC; (2) Provides an initial written report to the EPA Region; (3) Prepares a o ne - time follow - up written report for the EPA Region on or before the first - ye ar anniversary

of the submission of an initial written report; (4) Conducts an annual evaluation of a release beginning the ye ar after the submission of the one - time follow - up written report; (5) Prepares change in the sources, composition, or frequency of a release reports; (6) Prepares change in other information reports; (7) Provides immediate notifications of SSI s; and

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Page 14 of 60 (8) Maintains a log or other formal record to document compliance with the CRRR. Each of these notification and record keeping activities is listed and described in detail in section 4(b)(i), above. In addition to these activities, persons in charge of a facility may be required to perform supplemental collection activities in res ponse to the Federal government’s evaluation of the facility ’s continuous release reports. In situations where EPA’s evaluation of release reports engenders concern over potential adverse effects, EPA may require the person in charge of the facility in qu estion to submit the additional information or clarify and refine information previously submitted. EPA may

use this additional information to better assess the risks associated with the release. Finall y, in response to a release report or additional inf ormation, EPA may

conduct a site inspection. Industry

personnel accompany

EPA personnel during the site inspection to address any questions, concerns, or information requests that may arise. Thus, the following other activities are included within the in formation collection activities performed by the regulated community : (9) Provision of additional information; and (10) Site inspection. Estimates of the burden hours incurred b y industry as a result of reporting continuous releases were developed based on estimates of the time expended in providing a specific report (e.g., the initial telephone call, the initial written report, the follow - up written report) as opposed to developing estimates for each work element (e.g., gathering information, reviewing repo rt formats, completing reports) involved in completing all of the required activities. The burden estimates for each information collection and record keeping activity performed by

the regulated community under the CRRR are presented in Section 6(a) of th is I CR. 5. THE INFORMATION COLLECTED

– AGENCY ACTIVITIES, COLLECTI ON METHODOLOGY, AND INFORMATION MANAGEMENT 5a. Agency

Activities Each of the notification reports submitted by industry is processed and evaluated by Federal authorities. For some continuous rele ases evaluated under the CRRR, EPA may request additional (supplemental) information or clarification of information previously submitted by

a facility . EPA may use this information to conduct a more in - depth risk assessment of the release. In some extre me cases, the in - depth risk assessment may not allay EPA’s concerns and EPA may decide to conduct a site inspection to review the circumstances associated with the release first - hand. Additionally , site inspections may

be conducted periodically as a compl iance and enforcement measure. Thus, the Agency performs the following other activities as a result of continuous releases reported under CERCLA section 103(f)(2):

• Request additional information; and • Conduct site inspections. Estimates of the burden hours incurred b y the Federal government are developed based on

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Page 15 of 60 estimates of the time expended in processing the notification reports required under the CRRR (e.g., the initial written report, SSInotification) or completing another activity (e.g., addit ional information, site inspection) as opposed to developing estimates for each work element (e.g., reviewing data, entering data, filing, evaluating a release, storing evaluation results) involved in completing all of the required activities. The burden estimates developed for each of the processing, evaluating, and other activities performed b y the Federal government are presented in Section 6(c) of this I CR. 5b. Collection Methodology and Management To facilitate collection and storage of information on c ontinuous releases, EPA developed CR - ERNS. CR - ERNS is an information management sy stem that serves as the depository for continuous release information received b y the EPA Regions. CR - ERNS is designed to assist EPA Regional personnel in managing continuo us release information and establishing priorities with respect to the review and evaluation of continuous release reports. The reports submitted to the EPA Regions include the initial written report, the follow - up report, and changes in release reports. Additionally , the NRC immediately notifies the appropriate EPA Region of any SSIreports. 5c. Small Entity

Flexibility The notification requirements under section 103(a) of CERCLA and the reporting relief available under section 103(f)(2) appl y equally to al l firms regardless of size. There are no special information collection or record keeping requirements on small businesses. EPA believes that the notification sy stem developed under the CRRR represents the minimum level of reporting necessary for the Fed eral OSC to evaluate whether a response action is needed to prevent or mitigate any hazards to public health and welfare and the environment. A reduction in the reporting requirements facing small businesses is not possible without jeopardizing the quality of the information needed to evaluate the threat posed by the release and the need for a Federal response. 5d. Collection Schedule The facility

must provide an initial telephone call to the NRC as soon as the person in charge has knowledge of a hazardous substance release that equals or exceeds its RQ. The caller must decide whether to report the release under CERCLA section 103(a) (i.e., as an episodic release) or CERCLA section 103(f)(2) (i.e., as a continuous release). The reporting and record keeping activities associated with reporting an episodic release under CERCLA section 103(a) are presented in EPA I CR No. 1049.11 . If the caller reports a continuous release, the initial written report required by CERCLA section 103(f)(2) must be provided within 30 day s of the initial telephone call. In the second year of reporting, the facility must submit a written follow - up report to the EPA Region within 30 day s of the anniversary date of submission of the initial written report. This report is sometimes called the First Anniversary Report. Thereafter, the reporting facility is responsible for reevaluating the release annually , but no reports are required unless there is a change in the sources

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Page 16 of 60 or composition of a release, a change in release information previousl y submitted, or an SSIin the release. SSI s in a release are considered to be episodic releases and must be reported as soon as the person in charge is aware that an SSIhas occurred. If there is a change in the information submitted in the initial written or follow - up report, other than a change in sources, composition, or frequency of the release, the person in charge must submit a letter detailing the change to the EPA Region within 30 day s of determining that a change has occurred. 6. ESTIMATING T HE BURDEN AND COST OF THE COLLECTION 6a. Estimating Respondent Burden To report a continuous release, the regulated community performs the following activities (outlined in Section 4(b) of this I CR): (1) provides an initial telephone notification to the NRC; (2) prepares an initial written report for the EPA Region; (3) prepares follow - up written report for the EPA Region on the first - ye ar anniversary of the submission of the initial written report; (4) conducts an annual evaluation of the release beginning th e year after the submission of the one - time follow - up written report; (5) reports a change in the sources, composition, or frequency of the release; (6) reports a change in other information; (7) reports SSI s in the release; (8) complies with other activit ies; and (9) keeps records on the release, including documentation of the annual evaluation. Activities (5), (6), (7), and (8) are conditional activities and are necessary for only a small fraction of all the continuous releases reported each ye ar. For e xample, SSI s are defined in the CRRR as hazardous substance releases whose quantity exceeds the upper bound of the normal range, where the normal range includes all releases of the hazardous substance reported or occurring during the previous year. Thus, only a small fraction of facilities experience SSI s in their continuous releases in a given ye ar. When calculating the burden and costs in this I CR it is assumed that the ty pical facility participates in all the necessary information collection activities for each release. For example, the ty pical facility

will provide an initial telephone notification and written report for each of its continuous releases. In fact, it is likely that man y facility

operators will consolidate collection activities for rele ases at their facility (e.g., provide one telephone notification for several releases). The estimated burden hours for each of the activities listed in the paragraph above are presented in Exhibit 1. The burden estimates are taken from the CRRR economic impact anal ys is and are based on CERCLA reporting experience, SARA section 313 reporting experience, and professional judgment. A description of the basis for each burden estimate, as well as the percentage of continuous releases for which the burden is e xpected to be incurred, is provided in the remainder of this section.

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Page 17 of 60 Exhibit 1 – Unit Burden Hours per Respondent Information Collection Activity

Mg t Te ch Cl erical Total Pro vidi ng an In it ia l Te le phone No tific ation Whe n firs t re por ti ng a re le as e 100% o f n ew re le as es 1.0 2.0 0.0 3. 0 Pre pari ng an In it ia l Wr it ten Re por

t W it hi

n 30 d ays o f a n in it ia l telephone notific ation 100% o f n ew re le as es 3.0 4.0 1.0 8. 0 Pre pari ng a Fo llo w-u p Wr it ten Re por

t A year a ft er t he su bm is sion of a n in it ia l writ ten re por

t 100% o f a ll s econd

year re le as es 3.0 1.0 1.0 5. 0 Co nduc ti

ng an A nnua l Ev al uation of aR eleas e Ea ch ye ar

b eg in ni ng the year a ft er t he s ubm

is sion of awrit ten fo llo w-u p re por t 100% o f a ll thi rd ye ar a nd su bs equent year re le as es 3.0 1.0 1.0 5. 0 Re por ti ng a Ch ange in t he So urces , Co mp os it io n, o r Fre que ncy of

aR eleas e Whe n the so urces ,

co mp os it io n, o r fre quency of a re le as e ch an ge s 5% e ach ye ar o f a ll new a nd cu rre nt re le as es 4.0 4.0 1.0 9. 0 Re por ti ng Ot he r Ch an ge s in In fo rm ation Ch anges i n other in fo rm ation 10% e ach y ear o f a ll new a nd cu rre nt re le as es 1.0 1.0 0.5 2. 5 Re por ti ng an SSI i

n a Re le as e Im me diatel y af ter a n SSI event is n oticed 5% e ach ye ar o f a ll new a nd cu rre nt re le as es 1.0 1.0 0.0 2. 0 Ot he r A cti

vi ties – Pro vidi ng Addi tional In fo rm ation Up on EPA re que st 30% e ach y ear o f a ll new a nd cu rre nt re le as es 4.0 0.0 0.0 4. 0 Ot he r A cti

vi ties – Fa cilit ati ng a Si te In sp ection Up on EPA re que st 1% e ach ye ar o f a ll new a nd cu rre nt re le as es 4.0 4.0 0.0 8. 0 Re co rd k eepi ng Ea ch y ear o f are le as e 100% o f a ll ne w and

cu rre nt re le as es 0.0 4.0 0.0 4. 0 Col lectio n Ac ti vi ty Whe n Col lectio n Ac ti vi ty is Pe rf or me d Pe rcentage o f

Conti nuo us Re lease s tha

t Wi ll Re qu ire a Col lectio n Ac ti vi ty Un it B ur de n H

our s



## The estimated burden hours for each of the activities listed in the paragraph above are presented in Exhibit 1 (With Forms) . The burden estimates are taken from the CRRR economic impact anal ys is and are based on CERCLA reporting experience, SARA section 313 reporting experience, and professional judgment. A description of the basis for each burden estimate (including where there might be some savings due to the use of the continuous release reporting forms) , as well as the percentage of continuou s releases for which the burden is expected to be incurred, is provided in the remainder of this section.

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Page 18 of 60 Exhibit 1 (With Forms) – Unit Burden Hours per Respondent Information Collection Activity Mg t Te ch Cl erica l Total Pro vidi ng an In it ia l Te le phone No tific ation Whe n firs t re por ti ng a re le as e 100% o f n ew re le as es 1.0 2.0 0.0 3. 0 Pre pari ng an In it ia l Wr it ten Re por

t W ithi

n 30 d ays o f a n in it ia l tel ephone notific ati on 100% o f n ew

re le as es 3.0 3.0 1.0 7. 0 Pre pari ng a Fo llo w-u p Wr it ten Re por

t A year a ft er the subm is si on of an in it ia l writ ten re por

t 100% o f a ll s econd

year re le as es 3.0 1.0 1.0 5. 0 Co nduc ti

ng an A nnua l Ev al uation of aR el eas e Ea ch ye ar

b eg in ni ng the year a ft er the s ubm

is si on of awrit ten fo llo w-u p re por t 100% o f a ll thi rd ye ar and su bs equent year re le as es 3.0 1.0 1.0 5. 0 Re por ti ng a Ch ange in the So urces , Co mp os it io n, o r Fre que ncy of

aR el eas e Whe n the so ur ces , co mp os it io n, o r fre quency of are le as e ch an ge s 5% e ach ye ar o f a ll new and cu rre nt re le as es 4.0 4.0 1.0 9. 0 Re por ti ng Othe r Ch an ge s in In fo rm ation Ch anges i n other in fo rm ation 10% e ach y ear o f a ll new and cu rre nt re le as es 1.0 1.0 0.5 2. 5 Re por ti ng an SSI i

n a Re le as e Im me diatel y af ter an SSI event is n oticed 5% e ach ye ar o f a ll new and cu rre nt re le as es 1.0 1.0 0.0 2. 0 Othe r A cti

vi ti es – Pro vidi ng Addi ti onal In fo rm ati on Up on EPA re que st 30% e ach y ear o f a ll new and cu rre nt re le as es 4.0 0.0 0.0 4. 0 Othe r A cti

vi ti es – Fa cilit ati ng a Si te In sp ection Up on EPA re que st 1% e ach ye ar o f a ll new and cu rre nt re le as es 4.0 4.0 0.0 8. 0 Re co rd k eepi ng Ea ch y ear o f are le as e 100% o f a ll ne w and

cu rre nt re le as es 0.0 4.0 0.0 4. 0 Col lectio n Ac ti vi ty Whe n Col lectio n Ac ti vi ty is Pe rf or me d Pe rcentage of

Conti nuous Re lease s tha

t Wi ll Un it

B ur de n H

our s



## Providing an Initial Telephone Notification to the NRC

– In providing the initial telephone notification, facilities incur a one - time, first - ye ar burden of notifyingthe NRC that a hazardous substance release is reported under CERCLA section 103(f)(2). Providing the required information by

telephone to the N RC is estimated to require 15 minutes (0.25 hours) of management time. Prior to the telephone call, however, the facility must determine if the release is continuous and stable in quantity

and rate as defined in the CRRR. This determination is estimated to require 45 minutes (0.75 hours) of management time and two hours of technical time. Forty- five minutes (0.75 hours) of management time and two hours of technical time should be sufficient to determine if a release is continuous because facilities likel y to be affected b y the CRRR should be familiar with the reporting requirements of CERCLA section 103. In total, the burden associated with the initial telephone call is three hours .

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Page 19 of 60 We do not expect that use of the continuous release reporting forms will reduce the total burden associated with the initial tel ephone notification to the NRC. Preparing an Initial Written Report

– The burden associated with providing the initial written report is also a one - time, first - ye ar cost. Much of the info rmation required for the initial written report (e.g., facility identification, hazardous substance identification, frequency and source of the release) is readil y available to the facility . Information such as the composition of the release and the environmental media affected, however, may require more extensive consideration and anal ys is. In addition, some time is needed to organize and format the required information into a report suitable for submission to the government. It is assumed that many fac ilities will use EPA’s prepared report format to minimize report organization and formatting efforts. Preparation of the initial written report that uses EPA’s prepared report format is estimated to require three hours of managerial time, three hours of t echnical time, and one hour of clerical time. To account for the burden experienced b y the facilities that do not use EPA’s prepared report format, EPA has increased the technical burden to four hours. The costs of photocopying and mailing this report an d all other reports to the appropriate EPA Region are computed in Section 6(b). Preparation of the initial written report is estimated to require three hours of managerial time (including one - hour of legal review), four hours of technical time, and one ho ur of clerical time. Thus, the total burden associated with the initial written report is eight hours . Estimated s avings for use of c ontinuous release r eporting f orms is found in the reduction of technical time from four hours to three hours, thus the total burden associated with the initial written report is seven hours . Preparing a Follow - up Written Report

– Within one year of submitting the initial written report, facilities must submit a one - time follow - up written report to the appropriate EPA Regi on. The follow - up report requires the same information as the initial written report but serves to confirm, update, and refine the information provided in the initial report based on release data from the previous operating ye ar. Because some of the technical information gathered for preparation of the initial written report, such as the source of the release and specific information describing the environmental media affected remains unchanged, preparation of the follow - up report requires less technical time than preparation of the initial written report. EPA estimates that preparation of the follow - up report requires three hours of managerial time, one hour of technical time, and one hour of clerical time. In total, the burden associated with the follo w - up written report is five hours . The burden associated with the follow - up written report is incurred in the second year of reporting. We do not expect that use of the continuous release reporting forms will reduce the total burden associated with the follow - up written report. Conducting an Annual Evaluation of the Release

– Although the written follow - up report is prepared and submitted only once, facilities are required to conduct and document an annual evaluation of each hazardous substance release reported under section 103(f)(2) beginning the year after submitting the follow - up written report. This annual evaluation is comparable to the review

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Page 20 of 60 and information collection necessary for preparation of the follow - up report. The burden associated with the annual evaluation, therefore, is assumed to be the same as the burde n of preparing the written follow - up report ( five hours ). The burden associated with the annual evaluation is incurred in the third and all subsequent years. We do not expect that use of the continuous release reporting forms will reduce the total burd en associated with the annual evaluation of the release. Reporting a Change in the Sources, Composition, or Frequency of the Release

– When a facility experiences a change in the sources, composition, or frequency of a release, the release is considered a new release because the associated hazard may have changed significantl y. Changes in the sources, composition, or frequency of a release are expected to result only from significant changes in the production process, such as the installation of new equip ment or a change in the chemical nature of the process. While such significant changes are expected over the long - term, the likelihood of such a change occurring in a particular year is small. EPA estimates that the number of already reported continuous releases that experience a change in sources, composition, or frequency is equal to 5 percent of the total number of hazardous substance releases being reported under the CRRR in any

given ye ar. Facilities experiencing a change in the sources, c omposition, or frequency of a continuous release must complete the initial notification process for the release (i.e., an initial telephone call to the NRC and an initial written report and follow - up report to the EPA Region). For facilities experiencing a change in the sources, composition, or frequency of a continuous release, much of the information from the previous initial written report (e.g., facility identifiers, the media affected) should not have changed. It is assumed that the technical time re quired evaluating the release, determining whether it is stable in quantity and rate, and accuratel y document the composition of the release and the environmental media affected would take four hours. The number of management and clerical hours required t o report a new continuous release are assumed to be four hours and one hour respectively . Thus, the total burden associated with reporting a change in the sources, composition, or frequency of a continuous release is nine hours . We do not expect that u se of the continuous release reporting forms will reduce the total burden associated with reporting a change in the sources, composition, or frequency of a total continuous release. Reporting Other Changes in Information – For changes other than a change in the sources, composition, or frequency of a release, the person in charge must notify the EPA Region by

letter that the information previously submitted in support of a continuous release notification is no longer valid. For example, the population den sity in the vicinity

of the facility

would be reported b y submitting a letter detailing the change and its cause. Such changes in information previously submitted are likely

to occur over an extended period of time, but are much less likely to occur every ye ar. EPA estimates that, on an annual basis, approximately 10 percent of the releases reported under CERCLA section 103(f)(2) will experience a change that requires submission of a letter to the EPA Region. Gathering and reporting the change in the rel ease b y a letter to the EPA Region is

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Page 21 of 60 estimated to require one hour of managerial time, one hour of technical time, and one - half hour of clerical time for a total burden of 2 and one - half hours . We do not expect that use of the continuous release report ing forms will reduce the total burden associated with reporting other changes in information. Reporting a Statistically Significant Increase in the Release

– As soon as the person in charge of a facility

has knowledge that the quantity of a continuous release being reported under CERCLA section 103(f)(2) exceeds the upper bound of its previously established normal range of release weights, the person in char ge must notify the NRC. SSI s are episodic release events because the release has not been previously reported or evaluated. To avoid underestimating the burden, this ICR includes the burden for reporting an SSI , even though the burden may be captured in the ICR fo r episodic releases (EPA 1409.11 ). The estimated burden of reporting an SSIis based on interviews with chemical industry personnel and the burden associated with reporting similar episodic releases under CERCLA section 103(a). EPA estimates th at reporting of an SSI requires one hour of managerial time and one hour of technical time for a total burden of two hours . The technical time consists of determining if the release is reportable, briefing management, and collecting the information required for NRC reporting. The managerial time includes alerting appropriate personnel and transmitting the information required in the telephone call. Because SSIs are defined as releases that exceed the normal range, and the normal range is defined to inclu de all release quantities recorded during the previous operating year, EPA estimates that no more than 5 percent of the hazardous substance releases reported under the CRRR will experience an SSI in a given year. We do not expect that use of the continuou s release reporting forms will reduce the total burden associated with reporting a statisticall y significant increase in the release. Other Activities

– In response to the government’s processing and evaluating the initial and follow - up reports, persons i n charge of facilities may be required to: (1) provide additional information or clarify

information previously

submitted; and (2) accompany EPA personnel during a site inspection. (1) Providing Additional Information

– For some percentage of the continuous releases reported under the CRRR, the information provided in the initial and/or follow - up reports will be incomplete, incorrect, or worrisome, prompting EPA to request additional information regarding the nature an d extent of the release. For example, EPA may seek additional information concerning release activity

in order to better assess the risk posed by the release. EPA estimates that approximately

30 percent of the initial/follow - up reports could require subm ission of additional information or some level of interaction with EPA in the first and second years of reporting. Beginning in the third ye ar of reporting, requests for additional information and further clarification of release information are assumed t o be necessary only for newl y reported releases. However, this anal ys is conservatively

assumes that the percentage of reportable releases for which additional

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Page 22 of 60 information is necessary

will remain at 30 percent for all years of reporting. For each hazardo us substance report that requires additional communication with EPA, industry is estimated to expend four hours of managerial time. We do not expect that use of the continuous release reporting forms will reduce the total burden associated with reporting other activities. (2) Facilitating a Site Inspection

– In extreme cases, the preliminary risk assessment of a release will indicate the need for a site inspection, allowing EPA to directly assess and evaluate the circumstances of a release and the population and environment potentially affected by

the release. In addition, site inspections are conducted periodically as a compliance and enforcement measure. Site inspections are estimated to be necessary for no more that one percent of the reported continu ous releases. EPA estimates that facility participation in a site inspection requires four hours of managerial time and four hours of technical time for a total burden of eight hours . We do not expect that use of the continuous release reporting forms wi ll reduce the total burden associated with facilitating a site inspection. Record keeping

– EPA assumes man y facilities maintain a log or some other record of each hazardous substance release reported under the CRRR. Facilities may find it useful to coll ect and record the following information for use in demonstrating compliance with the provisions of CERCLA section 103(f)(2): (1) estimates of daily release quantities to demonstrate the continuity and stability

of the release, and to establish and modify the normal range of the release; (2) documentation of the methodology and calculations used in estimating required information; and (3) documentation of the annual assessment required each ye ar subsequent to submission of the follow up written report. Muc h of the time necessary to gather these records has already been attributed to the preparation of the initial and follow - up reports, however, it is estimated that an additional four hours of technical time is necessary for keeping records on each hazardous substance release reported under the CRRR. We do not expect that use of the continuous release reporting forms will reduce the total burden associated with record keeping. The estimated annual burden hours incurred b y a “ ty pical ” facility

are presented in Exhibit 2. A ty pical respondent is assumed to report eight continuous hazardous substance releases in year one and to experience a change in one release in the second and third ye ars of reporting (e.g., the frequency of the release increases from three to five times a week, causing a modification in the estimated annual release amount). No other conditional activities (e.g., SSI reporting and facilitating a site inspection) are assumed to be required of the ty pical respondent; the inclusion of burden e stimates associated with any additional conditional activities may result in a significant overestimation of the burden incurred b y a typical facility.

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Page 23 of 60 Exhibit 2 – Burden Hours for a Typical Facility Collection Activity First Year Burden Hours Second Year Burden Hours Third Year Burden Hours

Mgt Tech Clerical Total Mgt Tech Clerical Total Mgt Tech Clerical Total 

### Providing an Initial Telephone Notification 8.0 16.0 0.0 24.0 NA NA NA 0.0 NA NA NA 0.0 Preparing an Initial Written Report 24.0 32.0 8.0 64.0 NA NA NA 0.0 NA NA NA 0.0 Preparing a Follow

–up Written Report NA NA NA 0.0 24.0 8.0 8.0 40.0 NA NA NA 0.0 Conducting an Annual Evaluation of a Release NA NA NA 0.0 NA NA NA 0.0 24.0 8.0 8.0 40.0 Reporting Other Changes in Information NA NA NA 0.0 1.0 1.0 0.5 2.5 1.0 1.0 0.5 2.5 Record keeping 0.0 32.0 0.0 32.0 0.0 32.0 0.0 32.0 0.0 32.0 0.0 32.0 Total Burden Hours for a Typical Facility 32.0 80.0 8.0 120.0 25.0 41.0 8.5 74.5 25.0 41.0 8.5 74.5 A “typical” respondent is assumed to report eight continuous hazardous substance releases in year one and to experience a change in one release in the second and third years (e.g., the frequency of the release per week changes each year, causing a modification in the estimated annual release amount). No other conditional activities are assumed to be required of the typical respondent. NA = Not Applicable 

## The estimated annual burden hours incurred b y a “ty pical” facility

are presented in Exhibit 2 (With Forms) . A typical respondent is assumed to report eight continuous hazardous substance releases in ye ar one and to experience a change in one release in the second and third years of reporting (e.g., the frequency

of the release increases from three to five times a week, causing a modification in the estimated annual release amount). No other conditional activities (e.g., SSI reporting and facilitating a site inspection) are assumed to be required of the ty pical respondent; the inclusion of burden estimates associated with any additional conditional activities may result in a significant overestimation of the burden incurred b y a typical facility .

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Page 24 of 60 Exhibit 2 (With Forms) – Burden Hours for a Typical Facility Collection Activity First Year Burden Hours Second Year Burden Hours Third Year Burden Hours

Mgt Tech Clerical Total Mgt Tech Clerical Total Mgt Tech Clerical Total 

### Providing an Initial Telephone Notification 8.0 16.0 0.0 24.0 NA NA NA 0.0 NA NA NA 0.0 Preparing an Initial Written Report 24.0 24.0 8.0 56.0 NA NA NA 0.0 NA NA NA 0.0 Preparing a Follow

–up Written Report NA NA NA 0.0 24.0 8.0 8.0 40.0 NA NA NA 0.0 Conducting an Annual Evaluation of a Release NA NA NA 0.0 NA NA NA 0.0 24.0 8.0 8.0 40.0 Reporting Other Changes in Information NA NA NA 0.0 1.0 1.0 0.5 2.5 1.0 1.0 0.5 2.5 Record keeping 0.0 32.0 0.0 32.0 0.0 32.0 0.0 32.0 0.0 32.0 0.0 32.0 Total Burden Hours for a Typical Facility 32.0 72.0 8.0 112.0 25.0 41.0 8.5 74.5 25.0 41.0 8.5 74.5 A “typical” respondent is assumed to report eight continuous hazardous substance releases in year one and to experience a change in one release in the second and third years (e.g., the frequency of the release per week changes each year, causing a modification in the estimated annual release amount). No other conditional activities are assumed to be required of the typical respondent. N/A

– Not Applicable 

## 6b. Estimating Respondent Costs i. Estimating Labor Costs The estimated cost to complete various continuous release reports required under the CRRR is a function of the time expended by industry personnel (i.e., the burden estimates presented in section 6(a)), and the hourl y wage rates for the appropriate categories of labor. The hourly wage rates used for industry

in this ICR are from December 20 1 0 and were obtained from the Bureau of Labor Statistics. 4 

## For purposes of this analy sis, EPA estimates an average hourl y respondent labor cost of $56.63 for managerial staff, $46.56 for technical staff, and $23.22 for clerical staff.

4 

### Bureau of Labor Statistics’ news release dated, March 9, 2011 , entitled, “Employer Costs for Employee Com pensation - December 20 10 ” listed hourly compensation (wages and salaries plus fringe benefits) rates for civilian managerial, technical, and clerical wo rkers. Therefore the wage rates used in this ICR (1049.11) include salaries, fringe benefits, overhead costs and general and administrative co sts as of December 2010.

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Page 25 of 60 These rates reflect the employer cost s for employee compensation in the United Stat es as of December 20 1 0 and include both employer costs for legall y required benefits (e.g., social security, worker ’ s compensation, and unemploy ment insurance), other important fringe benefit categories (e.g., insurance, paid leave, retirement, and savings), and overhead and ge neral and administrative costs. Costs associated with the burden hours presented in Section 6(a) of this I CR are shown in Exhibit 3. Exhibit 3 presents the unit costs to industry of performing the notification, record keeping, and other activities that may be required in reporting a continuous release. The unit cost of each collection activity

is calculated by

multiplying the annual burden hour estimates in Exhibit 2 by the hourly wage rate for the appropriate labor category (listed above). Exhibit 3 – Unit Labor Cost per Respondent Information Collection Activity Manage ria

l/h r Te ch ni ca

l/h r Cl erical/h r $56. 63 $46. 56 $23. 22 Pro vidi ng an In it ia l Te le phone No tifi cation 1.0 2. 0 0. 0 $149.75 Pre pari ng an In it ia l W ri

tten Re por t 3.0 4. 0 1. 0 $379.35 Pre pari ng a Fo llo w-u p Wr

it ten Re por t 3.0 1. 0 1. 0 $239.67 Co nduc ti

ng an A nnua l Ev al uation of aR eleas e 3.0 1. 0 1. 0 $239.67 Re por ti ng a Ch ange in t he So urces , Co mp os it io n, o r Fre que ncy of

aR eleas e 4.0 4. 0 1. 0 $435.98 Re por ti ng Ot her Ch an ge s in In fo rm ation 1.0 1. 0 0. 5 $114.80 Re por ti ng an SSI i

n a Re le as e 1.0 1. 0 0. 0 $103.19 Ot he r A cti

vi ties – Pro vidi

ng Addi tiona l In fo rm

ation 4.0 0. 0 0. 0 $226.52 Ot he r A cti

vi ties – Fa cilit ati

ng a Si te In sp ection 4.0 4. 0 0. 0 $412.76 Re co rd k eepi ng 0.0 4. 0 0. 0 $186.24 Col lectio n Ac ti vi ty Un it L ab or Cos t Bu rd en H our s



## Exhibit 3 (With Forms) presents the unit costs to industry of performin g the notification, record keeping, and other activities that may be required in reporting a continuous release. The unit cost of each collection activity is calculated by

multiplying the annual burden hour estimates in Exhibit 2 (With Forms) by the hourl y wage rate for the appropriate labor category (listed above).

## EPA - HQ - SFUND - 2011 - 0523

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Page 26 of 60 Exhibit 3 (With Forms) – Unit Labor Cost per Respondent Information Collection Activity Manage ria

l/h r Te ch ni ca

l/h r Cl erical/h r $56. 63 $46. 56 $23. 22 Pro vidi ng an In it ia l Te le phone No tifi cation 1.0 2. 0 0. 0 $149.75 Pre pari ng an In it ia l W ri

tten Re por t 3.0 3. 0 1. 0 $332.79 Pre pari ng a Fo llo w-u p Wr

it ten Re por t 3.0 1. 0 1. 0 $239.67 Co nduc ti

ng an A nnua l Ev al uation of aR eleas e 3.0 1. 0 1. 0 $239.67 Re por ti ng a Ch ange in t he So urces , Co mp os it io n, o r Fre que ncy of

aR eleas e 4.0 4. 0 1. 0 $435.98 Re por ti ng Ot her Ch an ge s in In fo rm ation 1.0 1. 0 0. 5 $114.80 Re por ti ng an SSI i

n a Re le as e 1.0 1. 0 0. 0 $103.19 Ot he r A cti

vi ties – Pro vidi

ng Addi tiona l In fo rm

ation 4.0 0. 0 0. 0 $226.52 Ot he r A cti

vi ties – Fa cilit ati

ng a Si te In sp ection 4.0 4. 0 0. 0 $412.76 Re co rd k eepi ng 0.0 4. 0 0. 0 $186.24 Col lectio n Ac ti vi ty Bu rd en H our s Un it L ab or Cos t



## Exhibit 4 presents the annual labor cost estimated to be incurred b y a typical facility. (The reporting pattern assumed for a typical facility is discussed in Section 6(a) above.)

Exhibit 4 – Annual Labor Costs for a Typical Facility Collection Activity Annual Burden Hours Annual Labor Costs Managerial/hr Technical/hr Clerical/hr First Year Second

Year Third

Year $56.63 $46.56 $23.22 Providing an Initial Telephone Notification 8 16 0 $1,198.00 NA NA Preparing an Initial Written Report 24 32 8 $3,034.80 NA NA Preparing a Follow - up Written Report 24 8 8 NA $1,917.36 NA Conducting an Annual Evaluation of a Release 24 8 8 NA NA $1,917.36 Reporting Other Changes in Information 1 1 0.5 NA $114.80 $114.80 Record keeping 0 32 0 $1,489.92 $1,489.92 $1,489.92 Total Labor Costs for a Typical Facility $5,722.72 $3,522.08 $3,522.08

## EPA - HQ - SFUND - 2011 - 0523

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Page 27 of 60 A “typical” respondent is assumed to report eight continuous hazardous substance releases in year one and to experience a change in one release in the second and third years (e.g., the frequency of the release per week changes each year, causing a modification in the estimated annual release amount). No other conditional activities are assumed to be required of the typical respondent. N/A = Not Applicable 

## Exhibit 4 (With Forms) presents the annual labor cost estimated to be incurred by a typical facility using the continuous release reporting forms (The reporting pattern assumed for a typical facility is discussed in Section 6(a) abo ve.) Exhibit 4 (With Forms) – Annual Labor Costs for a Typical Facility Collection Activity Annual Burden Hours Annual Labor Costs Managerial/hr Technical/hr Clerical/hr First Year Second

Year Third

Year $56.63 $46.56 $23.22 Providing an Initial Telephone Notification 8 16 0 $1,198.00 NA NA Preparing an Initial Written Report 24 24 8 $2,662.32 NA NA Preparing a Follow - up Written Report 24 8 8 NA $1,917.36 NA Conducting an Annual Evaluation of a Release 24 8 8 NA NA $1,917.36 Reporting Other Changes in Information 1 1 0.5 NA $114.80 $114.80 Record keeping 0 32 0 $1,489.92 $1,489.92 $1,489.92 Total Labor Costs for a Typical Facility $5,350.24 $3,522.08 $3,522.08 A “typical” respondent is assumed to report eight continuous hazardous substance releases in year one and to experience a change in one release in the second and third years (e.g., the frequency of the release per week changes each year, causing a modification in the estimated annual release amount). No other conditional activities are assumed to be required of the typical respondent. N/A = Not Applicable



## ii. Estimating Capital and Operations and Maintenance Costs Capital costs usually

include any

produced ph ys ical good needed to provide the needed information, such as machinery , computers, and other equipment. EPA does not anticipate that respondents will incur capital costs in carrying out the information collection requirements of the CRRR. Operating and Maintenance (O&M) costs are those costs a ssociated with a paperwork requirement incurred continually

over the life of the ICR. They are defined by the PRA as “ the recurring dollar amount of cost associated with O&M or purchasing services. ” The O&M costs that are incurred b y

## EPA - HQ - SFUND - 2011 - 0523

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Page 28 of 60 industries are shown in Exhibit 5. For this I CR, O&M costs cover photocopying of report templates to be filled out for each release source (25 cents per page) and postage and an envelope for reports sent to the Agency . There are no O&M costs associated with providing the in itial telephone notification to the Agency or reporting an SSI under the CRRR. Each written report, the initial written report, the follow - up written report, changes in sources, composition, or frequency of release report, and other changes in information report, are assumed to require five (5) pages. Requests for additional information by the Agency will vary considerabl y in scope and length, depending on the nature of the request, however, it is estimated that it will take industry approximately

10 page s to complete the Agency ’ s request. The postage and mailing costs are assumed to be equal for all documents, and are calculated as $5.99 postage and $0.30 per envelope, totaling $6.29 per report . 5 

## Exhibit 5 – Unit Operating and Maintenance Costs per Re spondent Information Collection Activity Photoc op

yi ng ($ /p g) Ma

ilin g ($ /rep or t) $0. 25 $6 Pro vidi ng an In it ia l Te le phone No tific ation $0. 00 $0.00 $0.00 Pre par in g an In it ia l W rit ten Re por t (5p gs /1 rp t) $1. 25 $6.29 $7.54 Pre par in g a Fo llo w-u p Writ ten Re por t (5pgs /1 rp t) $1. 25 $6.29 $7.54 Co nducti

ng an Annua l Ev al

ua tion of

aR eleas e $0. 00 $0.00 $0.00 Re por ti ng a Ch ange in t he So urces , Co mp os it io n, o r Fre quency of

aR eleas e (5p gs /1 rp t) $1. 25 $0.00 $1.25 Re por ti ng Ot he r Ch an ges i

n In fo rm ation (5pgs /1 rp t) $1. 25 $6.29 $7.54 Re por ti ng an SSI $0. 00 $0.00 $0.00 Ot her A cti vi ties – Pro vidi

ng Addi tional In fo rm at io n (10p gs /1 rp t) $2. 50 $6.29 $8.79 Ot her A cti vi ties – Fa cilit ati

ng a Si te In sp ect io n $0. 00 $0.00 $0.00 Re co rd k eepi ng (5p gs ) $1. 25 $0.00 $1.25 Col lection Ac ti vi ty Total U ni t O& M Cos t p

er Re po rt Un it O& M Cos ts



## Exhibit 5 (With Forms) shows the O& M costs that are incurred b y industries that are using the continuous release reporting forms. We are not making changes to the assumption that each written report, the initial written report, and other changes in information report will require five pages ; however, this assumption will be reviewed during the next renewal. There is no difference realized in O&M unit costs when the continuous release reporting forms are used.

5 

### Postage includes $.84 (3oz), certified $2.85, and return receipt $2.30. Certified and return receipt are not required, however, we expect most respondents to incur these costs.

## EPA - HQ - SFUND - 2011 - 0523

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Page 29 of 60 Exhibit 5 (With Forms) – Unit Operating and Maintenance Costs per Respondent Information Collection Activity

Photoc op

yi ng ($ /p g) Ma

ilin g ($ /rep or t) $0. 25 $6 Pro vidi ng an In it ia l Te le phone No tific ation $0. 00 $0.00 $0.00 Pre par in g an In it ia l W rit ten Re por t (5p gs /1 rp t) $1. 25 $6.29 $7.54 Pre par in g a Fo llo w-u p Writ ten Re por t (5pgs /1 rp t) $1. 25 $6.29 $7.54 Co nducti

ng an Annua l Ev al

ua tion of

aR eleas e $0. 00 $0.00 $0.00 Re por ti ng a Ch ange in t he So urces , Co mp os it io n, o r Fre quency of

aR eleas e (5p gs /1 rp t) $1. 25 $0.00 $1.25 Re por ti ng Ot he r Ch an ges i

n In fo rm ation (5pgs /1 rp t) $1. 25 $6.29 $7.54 Re por ti ng an SSI $0. 00 $0.00 $0.00 Ot her A cti vi ties – Pro vidi

ng Addi tional In fo rm at io n (10p gs /1 rp t) $2. 50 $6.29 $8.79 Ot her A cti vi ties – Fa cilit ati

ng a Si te In sp ect io n $0. 00 $0.00 $0.00 Re co rd k eepi ng (5p gs ) $1. 25 $0.00 $1.25 Col lection Ac ti vi ty Un it O& M Cos ts Total U ni t O& M Cos t p

er Re po rt



## In Exhibit 6, O&M costs for a typical facility are presented. Exhibit 6 – Operating and Maintenance Cos ts for a Typical Facility

Collection Activity Unit O&M Costs Total Unit Cost Photocopying ($/pg) Mailing

($/rpt) First Year Second Year Third

Year $0.25 $6 Providing an Initial Telephone Notification $0.00 $0.00 NA NA NA Preparing an Initial Written Report - 8 rpts @ (5pgs/1rpt) $1.25 $6.29 $60.32 NA NA Preparing a Follow - up Written Report - 8 rpts @ (5pgs/1rpt) $1.25 $6.29 NA $60.32 NA Reporting Other Changes in Information - 1 rpt @ (5pgs/1rpt) $1.25 $6.29 NA $7.54 $7.54 Record keeping - 8 rpts @ (5pgs/1 rpt) $1.25 $0.00 $10.00 $10.00 $10.00 Total O&M Costs for a Typical Facility $70.32 $77.86 $17.54 A “typical” respondent is assumed to report eight continuous hazardous substance releases in year one and to experience a change in one release in the second and third years (e.g., the frequency of the release per week changes each year, causing a modification in the estimated annual release amount). No other conditional activities are assumed to be required of the typical respondent. NA = Not Applicable 

## In Exhibit 6 (With Forms) , O&M costs for a typical facility that will use continuous release reporting forms are presented. There is no difference in O&M unit costs for a ty pical facility .

## EPA - HQ - SFUND - 2011 - 0523

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Page 30 of 60 Exhibit 6 (With Forms) – Operating and Maintenance Costs for a Typical Facility

Collection Activity Unit O&M Costs Total Unit Cost Photocopying ($/pg) Mailing

($/rpt) First Year Second Year Third

Year $0.25 $6 Providing an Initial Telephone Notification $0.00 $0.00 NA NA NA Preparing an Initial Written Report - 8 rpts @ (5pgs/1rpt) $1.25 $6.29 $60.32 NA NA Preparing a Follow - up Written Report - 8 rpts @ (5pgs/1rpt) $1.25 $6.29 NA $60.32 NA Reporting Other Changes in Information - 1 rpt @ (5pgs/1rpt) $1.25 $6.29 NA $7.54 $7.54 Record keeping - 8 rpts @ (5pgs/1 rpt) $1.25 $0.00 $10.00 $10.00 $10.00 Total O&M Costs for a Typical Facility $70.32 $77.86 $17.54 A “typical” respondent is assumed to report eight continuous hazardous substance releases in year one and to experience a change in one release in the second and third years (e.g., the frequency of the release per week changes each year, causing a modification in the estimated annual release amount). No other conditional activities are assumed to be required of the typical respondent. 

## Annual labor and O&M costs incurred b y the regulated community are summarized in Exhibit 7. Exhibit 7 – Unit Labor and Operating and Maintenance Costs per Respondent Information Collection Activity Col lectio n Ac ti vi ty Un it Lab orCos t Un it

O& M Cos t Total U ni t Cos ts Pro vi di ng an In it ia l T elep hone No tification $149.75 $0. 00 $149.75 Pre pari ng an In it ia l Wr

it ten Re por

t $379.35 $7. 54 $386.89 Pre pari ng a Fo llo w-u p Wr

it ten Re por

t $239.67 $7. 54 $247.21 Co nduc ti

ng an Annual

E va lu ation of

a Re le as e $239.67 $0. 00 $239.67 Re por ti ng a Ch an ge in t he So urces , Com pos it io n, or Fre que nc y of

aR eleas e $435.98 $1. 25 $437.23 Re por ti ng Ot he r Ch anges i

n In fo rm ation $114.80 $7. 54 $122.34 Re por ti ng an SSI in aR

eleas e $103.19 $0. 00 $103.19 Ot he r A cti

vi ties –Pro vidi

ng Addi tional In fo rm ation $226.52 $8. 79 $235.31 Ot he r A cti

vi ties –Fa cilit ati

ng a Sit e In sp ection $412.76 $0. 00 $412.76 Re cord ke ep in g $186.24 $1. 25 $187.49 

## Annual labor and O& M costs incurred b y the regulated community that will use continuous

## EPA - HQ - SFUND - 2011 - 0523

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Page 31 of 60 release reporting forms are summarized in Exhibit 7 (With Forms) . Exhibit 7 (With Forms) – Unit Labor and Operating and Maintenance Costs per Respondent Information Collection Activity Col lectio n Ac ti vi ty Un it Lab or Cos t Un it

O& M Cos t Total U ni t Cos ts Pro vidi ng an In it ia l T elep hone No tifi cation $149.75 $0. 00 $149.75 Pre pari ng an In it ia l Wr

it ten Re por

t $332.79 $7. 54 $340.33 Pre pari ng a Fo llo w-u p Wr

it ten Re por

t $239.67 $7. 54 $247.21 Co nduc ti

ng an Annual

E va lu ation of

aRe le as e $239.67 $0. 00 $239.67 Re por ti ng a Ch an ge in t he So ur ces , Com pos it io n, or Fre que nc y of

aR eleas e $435.98 $1. 25 $437.23 Re por ti ng Ot he r Ch anges i

n In fo rm ation $114.80 $7. 54 $122.34 Re por ti ng an SSI in aR

eleas e $103.19 $0. 00 $103.19 Ot he r A cti

vi ties –Pro vidi

ng Addi tional In fo rm ati on $226.52 $8. 79 $235.31 Ot he r A cti

vi ties –Fa ci

lit ati ng a Sit e In sp ecti

on $412.76 $0. 00 $412.76 Re cor d ke ep in g $186.24 $1. 25 $187.49 

## In Exhibit 8 6 

## , annual labor and O&M costs for a typical facility are presented. Exhibit 8 – Labor and Operating and Maintenance Costs for a Typical Facility Collection Activity Total Labor Costs Total O&M Costs Total Costs

First Year Second

Year Third

Year First

Year Second Year Third Year First

Year Second

Year Third

Year Providing an Initial Telephone Notification $1,198.00 NA NA NA NA NA $1,198.00 NA NA 

### Preparing an Initial Written Report $3,034.80 NA NA $60.32 NA NA $3,095.12 NA NA 

### Preparing a Follow - up Written Report NA $1,917.36 NA NA $60.32 NA NA $1,977.68 NA 

### Conducting Annual Evaluations NA NA $1,917.36 NA NA NA NA NA $1,917.36 

### Reporting Other Changes in Information NA $114.80 $114.80 NA $7.54 $7.54 NA $122.34 $122.34 

### Record $1,489.92 $1,489.92 $1,489.92 $10.00 $10.00 $10.00 $1,499.92 $1,499.92 $1,499.92

6 

### Exhibit 8 does not include capital costs because there is no capital costs associated with implementing the regulations of the CRRR.

## EPA - HQ - SFUND - 2011 - 0523

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Page 32 of 60 keeping Total Costs for a Typical Facility $5,722.72 $3,522.08 $3,522.08 $70.32 $77.86 $17.54 $5,793.04 $3,599.94 $3,539.62 

### A “typical” respondent is assumed to report eight continuous hazardous substance releases in year one and to experience a change in one release in the second and third years (e.g., the frequency of the release per week changes each year, causing a modification in the estimated annual release amount). No other conditional activities are assumed to be required of the typical respondent. NA = Not Applicable 

## In Exhibit 8 (With Forms) 7 

## , annual labor and O&M costs for a typical facility are presented. Exhibit 8 (With Forms) – Labor and Operating and Maintenance Costs for a Typical Facility Collection Activity Total Labor Costs Total O&M Costs Total Costs

First Year Second

Year Third

Year First

Year Second Year Third Year First

Year Second

Year Third

Year Providing an Initial Telephone Notification $1,198.00 NA NA NA NA NA $1,198.00 NA NA 

### Preparing an Initial Written Report $2,662.32 NA NA $60.32 NA NA $2,722.64 NA NA 

### Preparing a Follow - up Written Report NA $1,917.36 NA NA $60.32 NA NA $1,977.68 NA 

### Conducting Annual Evaluations NA NA $1,917.36 NA NA NA NA NA $1,917.36 

### Reporting Other Changes in Information NA $114.80 $114.80 NA $7.54 $7.54 NA $122.34 $122.34 

### Record keeping $1,489.92 $1,489.92 $1,489.92 $10.00 $10.00 $10.00 $1,499.92 $1,499.92 $1,499.92 

### Total Costs for a Typical Facility $5,350.24 $3,522.08 $3,522.08 $70.32 $77.86 $17.54 $5,420.56 $3,599.94 $3,539.62 

### A “typical” respondent is assumed to report eight continuous hazardous substance releases in year one and to experience a change in one release in the second and third years (e.g., the frequency of the release per week changes each year, causing a modification in the estimated annual release amount). No other conditional activities are assumed to be required of the typical respondent. N/A = Not Applicable

7 

### Exhibit 8 (With Forms) d oes not include capital costs because there is no capital costs associated with im plementing the regulations of the CRRR.

## EPA - HQ - SFUND - 2011 - 0523

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Page 33 of 60 6c. Estimating Agency

Burden and Cost To comply

with the provisions of the CRRR, Federal government auth orities perform the following activities (see also Section 5(a) of this ICR): (1) process initial telephone notification; (2) process initial written report; (3) process follow - up written report; (4) process change in the sources, composition or frequency of release reports; (5) process other changes in information; (6) process SSIreports; and (7) conduct other necessary activities (obtain additional information, conduct site inspection). The estimated burden to the Federal government for completing each of these CRRR mandated activities is based on the CRRR economic impact anal ys is. The CRRR Economic Impact is available in rule making Superfund Docket Number 103(f)CR - 4 - 8. Exhibit 9 presents the estimated burden - hours and unit cost associated with th e Federal government ’ s processing and evaluation of the various continuous release reports, as well as the burden and cost associated with any other government initiated activities that may involve the collection of information. The unit cost estimates presented in Exhibit 9 are derived b y multiplying the applicable burden estimates by the average hourly

wage rate for government employees. Based on the 20 11 GS pay

schedule, EPA estimates an average hourl y labor cost of $46.21 for the average Federal gover

nment employee. 8 

## A full description of the basis for each government burden estimate is provided in the remainder of this section. Exhibit 9 – Unit Burden Hours and Costs Incurred by the Government per Information Collection Activity

Bu rd enH ou rs ($ /h r) $46. 21 Pro ces s In it ia l T elep hone No tific ation 0. 50 $23.10 Pro ces s In it ia l W rit ten Re por t 1. 50 $69.31 Pro ces s Fo llo w-u p Writ ten Re por t 1. 50 $69.31 Pro ces s a Ch ange in the So ur ces , Co mp os it io n, o r Fre que nc y of aR el eas e Re por t 2. 00 $92.42 Pro ces s Other

Ch an ges i

n In fo rm ation 0. 50 $23.10 Pro ces s an SSI R

epor t 1. 25 $57.76 Othe r A cti

vi ties – Ob tai

ni ng Addi ti ona l In fo rm ation 2. 00 $92.42 Othe r A cti

vi ties – Conduc ti

ng a Si te In sp ection 8. 00 $369.66

Col lectio n Ac ti vi ty Un it Cos t



## We believe that submission of continuous release reporting forms will increase efficiencies in processing reports by

the Federal government. For the purposes of this analy sis, we are assuming that processing forms will save approximately 1/3 rd 

## of estimate d average times for each activity that 8 

### This hourly wage estimate was calculated by summing the basic hourly wage rate for a GS - 12 step 1 government em ployee in 2011 ($28.8 8) and the hourly monetary value of the representative employee’s fringe benefits (assumed to be the basic hourly wage rate multiplied by 60 percent).

## EPA - HQ - SFUND - 2011 - 0523

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Page 34 of 60 requires processing a report . This assumption will be reviewed during the next renewal. Exhibit 9 (With Forms) presents the estimated burden - hours and unit cost associated with the Federal government’s processing an d evaluation of the various continuous release reports, as well as the burden and cost associated with any other government initiated activities that may involve the collection of information when continuous release reporting forms are submitted by industries. Exhibit 9 (With Forms) – Unit Burden Hours and Costs Incurred by the Government per Information Collection Activity Bu rd enH ou rs ($ /h r) $46. 21 Pro ces s In it ia l T elep hone No tific ation 0. 50 $23.10 Pro ces s In it ia l W rit ten Re por t 1. 00 $46.21 Pro ces s Fo llo w-u p Writ ten Re por t 1. 00 $46.21 Pro ces s a Ch ange in the So ur ces , Co mp os it io n, o r Fre que nc y of aR el eas e Re por t 1. 50 $69.31 Pro ces s Other

Ch an ges i

n In fo rm ation 0. 25 $11.55 Pro ces s an SSI R

epor t 1. 00 $46.21 Othe r A cti

vi ties – Ob tai

ni ng Addi ti ona l In fo rm ation 1. 50 $69.31 Othe r A cti

vi ties – Conduc ti

ng a Si te In sp ection 8. 00 $369.66

Col lectio n Ac ti vi ty Un it Cos t



## Process Initial Telephone Notification

– EPA estimates that the NRC requires 30 minutes (0.5 hours) to process the information provided in the initial telephone call. The first year unit cost associated with processing the initial telephone call is $23.1 0 . We do not expect that the use of the continuous release reporting forms will reduce the burden associated with processing the initial telephone call. Process Initial Written Report

– Government authorities review initial written and follow - up reports to become familiar with the nature and extent of the release, to determine if the release qualifies for reduced reporting under CERCLA section 103(f)(2), and to assess the hazards to publ ic health and welfare and the environment. EPA estimates that the preliminary evaluation of the release requires on average, one and one half hour of government time. The costs of processing and evaluating the initial written report are incurred in the f irst year of reporting. Therefore, the unit cost for processing and evaluating the initial written report is $69.31 . We estimate that the preliminary evaluation of the release will require on average, one hour of government time to process continuous rel ease forms. Thus the unit cost for processing and evaluating the initial written report forms is $46.21 . Process Follow - up Written Report -- Within one year of submitting the initial written report,

## EPA - HQ - SFUND - 2011 - 0523

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Page 35 of 60 facilities must submit a written follow - up report to up date and confirm previously submitted information. The follow - up report provides EPA with a more accurate baseline against which to evaluate both the threat posed by the release and the impact that SSI s in the release may have on public health and welfare and the environment. The activities necessary to re evaluate the continuous release with the newl y submitted follow - up report are assumed to be identical to those required to process and evaluate the initial written report, one and a half hour . The cost s associated with the follow - up written report, however, are incurred in the second ye ar of reporting. Therefore, the unit cost for processing and evaluating the follow - up written report is $69.31 . We estimate that the activities necessary to reevaluate the continuous release with the newl y submitted follow - up report of the release will require on average, one hour of government time to process continuous release forms. Thus the unit cost for processing and evaluating the follow - up written report forms is $46.21 . Process a Change in the Sources, Composition, or Frequency of a Release Report

– After initial notification reports have been submitted for a release and reporting under section 103(f)(2) has commenced, EPA must be notified of any changes in release information previously submitted. Any change in the sources, composition, or frequenc y of a hazardous substance release constitutes a new release. Thus, an y facility experiencing a change in the sources, composition, or frequency of a continuous release must complete the initial notification process for the new release. Government activi ties associated with new release reports consist of the processing and evaluation of the initial telephone and initial written reports, 2 hours . The applicable unit cost is $92.42 per new continuous release report . We estimate that the government activi ties associated with new release reports to process a change in the sources, composition, or frequency of a release report will be reduced to one and one half hours . The applicable unit cost is $69.31 per new continuous release report using the continuous release reporting forms. Process Other Changes in Information

– For changes in a release other than a change in the sources, composition, or frequency , the person in charge must notify the EPA Region by

submitting a letter presenting the updated information and explaining the reasons for the change. EPA estimates that processing a letter of changed information requires approximately 30 minutes (i.e., 0.50 hours) of government time. This estimate consists of the time necessary evaluate the release in light of the changed information. The shorter evaluation time is assumed because it is necessary to evaluate only the incremental change in the risk using previous assessments of the release (assumed to be on file) as a baseline. The applicable unit cost is $23.10 per changes in a release report. We estimate that the government activities associated with processing other changes in information will be reduced to fifteen minutes . The applicable unit cost is $11.55 per report of changed information. Process an SSI (Statistically Significant Increase) Report

– SSI s are episodic releases and must be reported immediately

to the NRC. Release quantities in excess of the normal range have not been

## EPA - HQ - SFUND - 2011 - 0523

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Page 36 of 60 previously

reported and evaluated and, thus, warrant immediate reporting. Upon receiving notification of an SSI , the NRC will record the SSI information in the NRC data base (15 minutes) and notify

the appropriate EPA Region of the SSIreport (15 minutes) . Upon notification from the NRC (15 minutes), EPA will evaluate the potential hazard posed b y the release in light of the SSI (30 minutes). Thus, the Federal government is estimated to require one hour and fifteen minutes (1.25 hours) of government time to process and evaluate each SSIreported under the CRRR. The applicable cost is $57.76 per SSI Report . We estimate that EPA’s activities associated with processing an SSI report will be reduced to fifteen minutes . This will reduce the overall Federal government’s time to process and evaluate each SSI reported under the CRRR to one hour . The applicable unit cost is $46.21 per SSI Report . Other Activities

– For some percentage of continuous releases, the information provided in the initial and/or follo w - up reports will be incomplete, incorrect, or worrisome, prompting EPA to request additional information concerning the release and its associated hazard. For example, additional information may be necessary

to confirm the continuity and stability

of the release or to better assess the risk posed by the release. EPA estimates that the process of requesting and reviewing additional information concerning a continuous release requires 2.0 hours of government time. The applicable unit cost is $92.42 per re quest and review o f additional information. We estimate that the government activities associated with reviewing additional information concerning a continuous release will be reduced to one and one half hours of government time. The applicable unit cos t is $69.31 per request and review of additional information. In extreme cases, the preliminary risk assessment of a release will suggest the need for a site inspection , allowing EPA to directly a ss e s s and evaluate the circumstances of a release and the population and environment potentially affected by

the release. In addition, site inspections are conducted periodicall y as a compliance and enforcement measure. EPA estimates that site inspections wil l require eight hours of government time, including one hour allocated for the EPA Region to communicate its concerns and findings to the appropriate SERC and LEPC, and will cost $369.66 . We do not believe that submission of continuous release reporting f orms will change the estimate for government time for site inspections. 6d. Estimating the Respondent Universe and Total Burden and Cost The estimates presented in this I CR regarding the number of facilities and hazardous substance releases affected by the CRRR were computed using the number of CR - ERNS notifications made b y the NRC to each respective region over the ye ars 2008, 2009, and 2010 as reported b y the NRC. The number of reports to be filed i n the next three years is computed from the total number of reports already filed and reflects the number of annual reports in recent ye ars. EPA has estimated that each affected facility has 8 continuous releases above the releases ’ RQs. Exhibit

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Page 3 7 of 60 10 summarizes the estimated number of facilities and hazardous subs tance releases already affected by the CRRR. The change report adjustment reflects 10% of the total number of facilities and reports for all regions. The same number of facilities is assumed for use of continuous release reporting forms. Exhibit 10 – Nu mber of Facilities and Hazardous Substance Releases Already Affected by the CRRR Total E stimate d Num

be r of Fac ilities w

ith Conti nuous Re lease s Es ti mate d Num be r of Re po rtab

le Conti nuo us Re lease s (3 years ) EPA Re gion 1 149 1, 192 EPA Re gion 2 162 1, 296 EPA Re gion 3 283 2, 264 EPA Re gion 4 874 6, 992 EPA Re gion 5 653 5, 224 EPA Re gion 6 790 6, 320 EPA Re gion 7 597 4, 776 EPA Re gion 8 252 2, 016 EPA Re gion 9 320 2, 560 EPA Re gion 10 196 1, 568 Mi nus C hange Re por

ts (10% ) -427.6 -3,421 Total i n CR-E

RNS 3, 848 30, 787 

## Exhibit 11 presents the estimate for the number of faci lities and hazardous substance releases that will be affected b y the CRRR in the next three years. The estimate is based on an expected 7.5% average annual percent increase in facilities (see 6(f)) adjusted from the number of continuous release notificati ons reported by the NRC for 200 6 . The same estimate is assumed for the use of continuous release reporting forms. Exhibit 11 – Number of Facilities and Hazardous Substance Releases That Will Be Affected by the CRRR in the Next Three Years

Total E st imate d Num

be r of Fa cilities w

ith Conti nuo us Re lease s Es ti mate d Num be r of Re po rtab

le Conti nuous Re lease s Es ti ma ted Ne w Re le as es in t he Firs t Ye ar 8 62 Es ti ma ted Ne w Re le as es in t he Se cond Ye ar 8 67 Es ti ma ted Ne w Re le as es in t he T hi rd Y ear 9 72 To tal Ove r Ne xt Th re e Ye ars 25 201 Total i n CR-E

RNS Afte r Th ree Ye ar s 3, 874 30, 989

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Page 38 of 60 6e. Bottom L ine Burden Hours and Cost Tables i. Respondent Tally The total estimated and annual burden hours and costs incurred b y industry affected by

the CRRR are presented in Exhibit 12. The total and annual hours and costs incurred b y industry are calculated over a three ye ar period.

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Page 39 of 60 Exhibit 12 – Annual Burden Hours and Costs Incurred by Industry

1st Ye ar 2nd

Ye ar 3rd Ye ar 1st Ye ar 2n d

Ye ar 3rd

Ye ar 1st

Ye ar 2n d

Ye ar 3rd

Ye ar 1s t

Ye ar 2n d

Ye ar 3rd

Ye ar Provi ding Initi al Te lep hone N ot if

icat io n 62 67 72 3.00 $149.75 $0.00 187 201 216 $9,337 $10,037 $10,790 $0 $0 $0 Prep ar in g Initi al Writ ten Rep ort 62 67 72 8.00 $379.35 $7.54 499 536 576 $23,652 $25,426 $27,333 $470 $505 $543 Prep ar in g Fo llo w- up Writ ten Re

po rt 179 62 67 5.00 $239.67 $7.54 895 312 335 $42,901 $14,943 $16,064 $1,350 $470 $505 Conducting

A nnual Evaluat io ns 25,206 25,385 25,447 5.00 $239.67 $0.00 126,030 126,925 127,237 $6,041,122 $6,084,023 $6,098,966 $0 $0 $0 Rep ort in g a Cha

ng e in th e So urces , Comp ositi on, or Frequency of a Releas e 1,542 1,546 1,549 9.00 $435.98 $1.25 13,882 13,912 13,945 $672,489 $673,950 $675,521 $1,928 $1,932 $1,937 Rep ort in g Cha

ng es i n Ot he r Informat io n 3,085 3,092 3,099 2.50 $114.80 $7.54 7,712 7,729 7,747 $354,153 $354,922 $355,749 $23,261 $23,311 $23,365 Rep ort in g anS SI 1,542 1,546 1,549 2.00 $103.19 $0.00 3,085 3,092 3,099 $159,168 $159,514 $159,886 $0 $0 $0 Ot he r A ct iv it ies –– Ad diti onal Informat io n 9,255 9,275 9,297 4.00 $226.52 $8.79 37,019 37,100 37,186 $2,096,412 $2,100,967 $2,105,863 $81,350 $81,527 $81,717 Ot he r A ct iv it ies –– Sit e Insp ect io n 308 309 310 8.00 $412.76 $0.00 2,468 2,473 2,479 $127,335 $127,611 $127,909 $0 $0 $0 Record keep in g 30,850 30,917 30,989 4.00 $186.24 $1.25 123,398 123,666 123,955 $5,745,420 $5,757,903 $5,771,322 $38,562 $38,646 $38,736 Total 315,176 315,947 316,775 $15,271,990 $15,309,298 $15,349,405 $146,921 $146,392 $146,804 Un it Bu rde n Hou rs Un it La bo r Co sts Un it O& M Co sts Co llec ti on A

ct iv ity O& M Co sts Ov er Th re e Ye ars # of R epor te d Re lea ses that R equi re the C ol lecti on Acti vi ty Ov er Th re e Ye ars La bo r C os t Ov er Thre e Ye ars Bur de n Hou rs Ov er Th re e Ye ars

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Page 40 of 60 Exhibit 12 (With Forms) – Annual Burden Hours and Costs Incurred by Industry

1st Ye ar 2n d

Ye ar 3rd Ye ar 1s t Ye ar 2nd

Ye ar 3rd

Ye ar 1st

Ye ar 2nd

Ye ar 3rd

Ye ar 1st

Ye ar 2nd

Ye ar 3rd

Ye ar Provi ding Init ial Te lep hone N ot ificat io n 62 67 72 3.00 $149.75 $0.00 187 201 216 $9,337 $10,037 $10,790 $0 $0 $0 Pre pa ring Init ial Writ ten Re po rt 62 67 72 7.00 $332.79 $7.54 436 469 504 $20,749 $22,306 $23,979 $470 $505 $543 Pre pa ring F ollow -up Writ ten Re

po rt 179 62 67 5.00 $239.67 $7.54 895 312 335 $42,901 $14,943 $16,064 $1,350 $470 $505 Conducting

Annual Ev alu at io ns 25,206 25,385 25,447 5.00 $239.67 $0.00 126,030 126,925 127,237 $6,041,122 $6,084,023 $6,098,966 $0 $0 $0 Re po rt in g a Chang

e in th e Sourc es , Com po sition, or Frequency of a

Releas e 1,542 1,546 1,549 9.00 $435.98 $1.25 13,882 13,912 13,945 $672,489 $673,950 $675,521 $1,928 $1,932 $1,937

Re po rt in g Cha

ng es in Ot her Informat io n 3,085 3,092 3,099 2.50 $114.80 $7.54 7,712 7,729 7,747 $354,153 $354,922 $355,749 $23,261 $23,311 $23,365 Re po rt in g an S SI 1,542 1,546 1,549 2.00 $103.19 $0.00 3,085 3,092 3,099 $159,168 $159,514 $159,886 $0 $0 $0 Ot her A ct iv it ies –– Additi onal Informat io n 9,255 9,275 9,297 4.00 $226.52 $8.79 37,019 37,100 37,186 $2,096,412 $2,100,967 $2,105,863 $81,350 $81,527 $81,717 Ot her A ct iv it ies –– Sit e Insp ect io n 308 309 310 8.00 $412.76 $0.00 2,468 2,473 2,479 $127,335 $127,611 $127,909 $0 $0 $0 Re co rd ke ep in g 30,850 30,917 30,989 4.00 $186.24 $1.25 123,398 123,666 123,955 $5,745,420 $5,757,903 $5,771,322 $38,562 $38,646 $38,736 Total 315,114 315,880 316,703 $15,269,087 $15,306,177 $15,346,050 $146,921 $146,392 $146,804 Un it Bu rd en Ho ur s Col lecti on A

cti vi ty # of R

eporte d Re lea se s that R eq uire th e Co llecti on Act iv ity Ov er Three Ye ars Un it La bo r Costs Bu rde n Ho urs

Ov er Th re e Ye ars O& M Co st s Ov er Th re e Ye ars Un it O& M Co sts La bo r C ost Ov er Thre e Ye ars

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Page 41 of 60 ii. The Agency Tall y Exhibit 13 presents the total and annual estimated burden hours and costs incurred b y gover nment authorities as a result of the CRRR over a three year period.

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Page 42 of 60 Exhibit 13 – Annual Burden Hours and Costs Incurred by Government

1s t Ye ar 2n d

Ye ar 3r d

Ye ar 1s t Ye ar 2n d

Ye ar 3rd

Ye ar 1s t

Ye ar 2n d

Ye ar 3rd

Ye ar Pro ces si ng In it ia l Te le phone No tification 62 67 72 0.50 $23.10 31 34 36 $1,441 $1,549 $1,665 Pro ces si ng In it ia l Wr it ten Re por

t 62 67 72 1.50 $69.31 94 101 108 $4,322 $4,646 $4,994 Pro ces si ng Fo llo w-u p Wr it ten Re por

t 179 62 67 1.50 $69.31 269 94 101 $12,407 $4,322 $4,646 Pro ces si ng a Ch an ge in the So urces , Co mp os it io n, o r Fre quency of

a Re le as e Re por t 1,542 1, 546 1, 549 2.00 $92.42 3,085 3,092 3,099 $142,550 $142,859 $143,192

Pro ces si ng Ot he r Ch ange in In fo rm

ation 3,085 3, 092 3, 099 0.50 $23.10 1,542 1,546 1,549 $71,275 $71,430 $71,596 Pro ces si ng an SSI Re por t 1,542 1, 546 1, 549 1.25 $57.76 1,928 1,932 1,937 $89,094 $89,287 $89,495 Ot he r A ct iv it ie s–– Ob tai ni ng Addi tional In fo rm ation 9,255 9, 275 9, 297 2.00 $92.42 18,510 18,550 18,593 $855,298 $857,156 $859,154 Ot he r A ct iv it ie s–– Si

te In sp ection 308 309 310 8.00 $369.66 2,468 2,473 2,479 $114,040 $114,287 $114,554 Total 27,926 27,821 27,902 $1,290,424 $1,285,535 $1,289,296 Col lectio n Ac ti vi ty Un it Bu rd en Ho ur s Un it

Cos t Cos t Ov er Th ree Ye ar s # of Re po rted

Re lease s Es ti mate d to

Re qu ir e the Col le ction Ac ti vi ty Ov er Th ree Ye ar s Bu rd enH our s Ov er Th ree Ye ar s

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Page 43 of 60 Exhibit 13 (With Forms) – Annual Burden Hours and Costs Incurred by Government

1s t Ye ar 2n d

Ye ar 3r d

Ye ar 1s t Ye ar 2n d

Ye ar 3rd

Ye ar 1s t

Ye ar 2n d

Ye ar 3rd

Ye ar Pro ces si ng In it ia l Te le phone No tification 62 67 72 0.50 $23.10 31 34 36 $1,441 $1,549 $1,665 Pro ces si ng In it ia l Wr it ten Re por

t 62 67 72 1.00 $46.21 62 67 72 $2,881 $3,097 $3,329 Pro ces si ng Fo llo w-u p Wr it ten Re por

t 179 62 67 1.00 $46.21 179 62 67 $8,271 $2,881 $3,097 Pro ces si ng a Ch an ge in the So urces , Co mp os it io n, o r Fre quency of

a Re le as e Re por t 1,542 1, 546 1, 549 1.50 $69.31 2,314 2,319 2,324 $106,912 $107,144 $107,394

Pro ces si ng Ot he r Ch ange in In fo rm

ation 3,085 3, 092 3, 099 0.25 $11.55 771 773 775 $35,637 $35,715 $35,798 Pro ces si ng an SSI Re por t 1,542 1, 546 1, 549 1.00 $46.21 1,542 1,546 1,549 $71,275 $71,430 $71,596 Ot he r A ct iv it ie s–– Ob tai ni ng Addi tional In fo rm ation 9,255 9, 275 9, 297 1.50 $69.31 13,882 13,912 13,945 $641,473 $642,867 $644,365 Ot he r A ct iv it ie s–– Si

te In sp ection 308 309 310 8.00 $369.66 2,468 2,473 2,479 $114,040 $114,287 $114,554 Total 21,250 21,186 21,247 $981,930 $978,970 $981,799 Col lectio n Ac ti vi ty # of Re po rted Re lease s Es ti mate d to

Re qu ir e the Col le ction Ac ti vi ty Ov er Th ree Ye ar s Un it Bu rd en Ho ur s Un it

Cos t Bu rd enH our s Ov er Th ree Ye ar s Cos t Ov er Th ree Ye ar s

## EPA - HQ - SFUND - 2011 - 0523

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June 2011 Page 44 of 60 iii. Variations in the Annual Bottom L ine Exhibit 14 summarizes the estimated burden hours and costs incurred by industry . The bottom line burden to industry is approximately 315,176 hours for the first year and 315,947 , and 316,775 hours for the second and third year s, respectively . The bottom line industry labor costs are approximately $15,271,990 , $15,309,298 , and $15,349,405 for the first, second, and third years, respectivel y. The bottom line industry O&M cost s are approximately $146,921 , $146,392 , and $146,804 f or the first, second, and third years, respectivel y. The average burden hour for industry over a three ye ar period is 315,966 , an average labor cost of $15,310,231 and O&M cost of $146,705 . Exhibit 14 – Summary of Burden Hours and Costs Incurred by Indu stry

Fi rs t Ye ar Se co nd Y ear Third

Y ear Av

erage (ov er a thr ee ye arp

erio d) Total Num

be r of Re sp

on de nts 3,856 3, 865 3, 874 3,865 Re po rtin g Bu rd

enH ou rs 191, 778 192,281 192,821 192,293 Re co rd K eep in g Burd en Hours 123, 398 123,666 123,955 123,673 Total B ur de n H

our s 315, 176 315,947 316,775 315,966 Total Lab or Cos ts (thous and

$ ) $15, 272 $15,309 $15,349 $15,310 O& M Cos ts R

ep or ti ng (thous and $ ) $108 $108 $108 $108 O& M Cos ts R

ecord K eep in g (thous and $ ) $39 $39 $39 $39 Total O&M

Cos ts (thous and

$ ) $147 $146 $147 $147 

## Exhibit 14 (With Forms) summarizes the estimate burden hours and costs incurred b y industry . The revised bottom line burden to industry is approximately $315,114 hours for the first year and $315,880 , and $316,703 hours for the second and third years, respectivel y. The revised bottom line industry labor costs are approximately $15,269,087 , $15,306,177 , and $15,346,050 for the first, second, and third years, respectivel y. The bottom line industry O&M cost s remain the same . The revised average burden hour for industry over a three ye ar period is $146,921 , a revised average labor cost of $146,392 . The O&M average cost of $146,804 remains unchanged . The average burden hour for industry over a three year period is 315,899 , an average labor cost of $15,307,105 and O&M cost of $146,705 .

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June 2011 Page 45 of 60 Exhibit 14 (With Forms) – Summary of Burden Hours and Costs Incurred by Industry Fi rs t Y ear Se co nd

Y ear Third

Y ear Av

erage (ov er a thr ee ye arp

erio d) TotalNum

be r of Re sp

ond ents 3,856 3,865 3, 874 3, 865 Re portin g Bu rd

enH our s 191,716 192,213 192,749 192, 226 Re cord K eep in g Bu rd enH our s 123,398 123,666 123,955 123, 673 TotalB ur de n H

our s 315,114 315,880 316,703 315, 899 TotalLab or Cos ts (thous and

$ ) $15,269 $15,306 $15,346 $15, 307 O&M C os ts Re po rtin g (thous and $ ) $108 $108 $108 $108 O&M Cos ts Re cord

K eep in g (thous and $ ) $39 $39 $39 $39 TotalO& M Cos ts (thous and $ ) $147 $146 $147 $147 

## Exhibit 15 summarizes the estimated burden hours and costs incurred by government. The bottom line burden to the government is approximately 27,926 hours for the first ye ar, 27,821 for the second, and 27,902 for the third year. The bottom line cost to the government is approximately $1,290, 424 , $1,285,535 , and $1,289,296 , respectivel y. The average burden hour for the government over a three year period is 27,883 hours, at an average annual cost of $1,288,418 . Exhibit 15 – Summary of Burden Hours and Costs Incurred by Government Fi rs t Y ear Se cond

Y ear Third

Y ear Annual Av

erage Tot al B ur de n H

our s 27, 926 27,821 27,902 27,883 Tot al Cos t (thous and

$ ) $1, 290 $1,286 $1,289 $1,288 

## Exhibit 15 (With Forms) summarizes the estimated burden hours and costs incurred b y government. The revised bottom line burden to the gov ernment is approximately 21,250 hours for the first ye ar, 21,186 for second, and 21,247 for the third ye ar. The revised bottom line cost to the government is approximately $981,930 , $978,970 , and $981,799 , respectivel y. The revised average burden hour for the government over a three year period is 21,228 hours, at an average annual cost of $980,900 . Exhibit 15 (With Forms) – Summary of Burden Hours and Costs Incurred by Government Fi rs t Y ear Se cond

Y ear Thi rd

Y ear Annual Av

erage Total B ur de n H

our s 21,250 21,186 21,247 21,228 Total Cos t (thous and

$ ) $982 $979 $982 $981

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June 2011 Page 46 of 60 6f. Reasons for Change in Burden This I CR increases the burden incurred by industry , as a result of compliance with the CRRR, from 301,508 to 315,966 estimated average burden hours. This increase in burden results primaril y from use of data on the actual number of continuous release reports from several regions and appl yi ng a growth rate consistent with prior years reporting. The average annual percent increase in facilities in the previous ICR was approximately

7.5%. The same percent increase was assumed for this I CR. The unit burden hours p er respondent information collection activity (Exhibit 1) remains the same as the previous ICR. We estimate that the use of the continuous release reporting forms will reduce the estimated average burden hours for industry from 315,966 to 315,899 , an overall estimated savings of 67 hours. 6g. Burden Statement The reporting and record keeping burden for this collec tion of information is estim ated to average approximately 82 9 

## hours per affected facility ( 315,966 total burden hours/ 3,865 affected facilities), or 10.2 10 

## hours per response (where we estimate 8 responses/facility - see note to Exhibit 6), including determining if the hazardous substance release qualifies for reporting under the CRRR, gathering and maintaining the req uired information, and completing and reviewing the written reports. Burden means the total time, effort, or financial resources expend ed 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 s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to comply with an y 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. We estimate that the revised reporting and record keeping burden for this collectio n of 9 

### 82 

## hrs/facility

is further broken out to 50 

## hours for reporting ( 192,293 

## reporting burden hours/ 3,865 

## a ffected facilities) and 32 

## hours for record keeping ( 123,673 

## record keeping hours/ 3,865 

## affected facilities) 10 

### 6. 2 

## hours for reporting and 4.0 

## for record keeping.

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June 2011 Page 47 of 60 information is estimated to average approximately 8 2 11 

## per affected facility ( 31 5 , 8 99 revised total burden hours/ 3,865 affected facilities), or 10. 2 12 

## hours per response (where we estimate 8 response/facility

– see note to Exhibit 6), including determini ng if the hazardous substance release qualifies for reporting under the CRRR, gathering and maintaining the required information, and completing and reviewing the written reports. To comment on the Agency ’s need for this information, the accuracy of the provided burden estimates, and an y 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. EPA - HQ - SFUND - 2011 - 0523 , which 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/DC Public Reading Room is open from 8 a.m. to 4:30 p.m., Mond ay through Friday , excluding legal holiday s. The telephone number for the Reading Room is 202 - 566 - 1744, and the telephone number for the Superfund Docket is 202 - 566 - 0276. An electronic version of the public docket is available at www.regulations.gov . Use www.regulations.gov to obtain a copy of the draft collection of information, submit or view public comments, access the index listing of the contents of the docket, and to a ccess those documents in the public docket that are available electronically . Once in the sy stem, select “search,” then key in the docket ID number identified above. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Office for EPA. Please include the EPA Docket ID No. (EPA - HQ - SFUND - 20 10 - 0523 ) 

## and OMB control number (2050 - 00 8 6) in an y correspondence.

11 

### 8 2 

## hrs/facility

is further broken out to 50 hours for reporting ( 1 92 , 226 

## reporting burden hours/ 3,865 

## affected facilities) and 32 

## hours for record keeping ( 123,673 

## record keeping hours/ 3,865 

## affected facilities). 12 

### 6. 2 

## hours for reporting and 4.0 

## for record keeping.

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June 2011 Page 48 of 60 ATTACHMENT A – Continuous Rel ease Reporting Forms The following pages contain the Continuous Release Reporting Forms that are also available at: http://www.epa.gov/emergencies/content/reporting/rqover .htm#con .

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