INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT FOR COMPLIANCE ASSISTANCE SURVEYS FOR THE MARINA, METAL FINISHING, CONSTRUCTION SITE, AND AUTO SALVAGE YARD SECTORS May 31, 2001 U. S. Environmental Protection Agency Office of Compliance 2 TABLE OF CONTENTS Part A 1. IDENTIFICATION OF THE INFORMATION COLLECTION 1( a) Title of the Information Collection 1( b) Short Characterization/ Abstract 2. NEED FOR AND USE OF THE COLLECTION 2( a) Need/ Authority for the Collection 2( b) Practical Utility/ Users of the Data 3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA 3( a) Nonduplication 3( b) Public Notice Required Prior to ICR Submission to OMB 3( c) Consultations 3( d) Effects of Less Frequent Data Collection 3( e) General Guidelines 3( f) Confidentiality 3( g) Sensitive Questions 4. THE RESPONDENTS AND THE INFORMATION REQUESTED 4( a) Respondents/ SIC Codes 4( b) Information Requested 5. THE INFORMATION COLLECTED: AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT 5( a) Agency Activities 5( b) Collection Methodology and Management 5( c) Small Entity Flexibility 5( d) Collection Schedule 6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION 6( a) Estimating Respondent Burden 6( b) Estimating Government Burden 6( c) Bottom Line Burden and Cost Table 6( d) Reasons for Change of Burden 6( e) Burden Statement 3 Part B 1. SURVEY OBJECTIVES, KEY VARIABLES, AND OTHER PRELIMINARIES 1( a) Survey Objectives 1( b) Key Variables 1( c) Statistical Approach 1( d) Feasibility 2. SURVEY DESIGN 2( a) Target Population and Coverage 2( b) Sample Design 2( c) Precision Requirements 2( d) Questionnaire Design 3. PRETESTS AND PILOT TESTS 4. COLLECTION METHODS AND FOLLOW UP 4( a) Collection Methods 4( b) Survey Response and Follow up 5. ANALYZING AND REPORTING SURVEY RESULTS 5( a) Data Preparation 5( b) Analysis 5( c) Reporting Results 4 Part A 1. IDENTIFICATION OF THE INFORMATION COLLECTION 1( a) Title of the Information Collection ICR: Compliance Assistance Surveys for the Marina, Metal Finishing, Construction Site, and Auto Salvage Yard Sectors ( EPA ICR Number 2021.01) OMB Control Number:

" Compliance Assistance Surveys for the Marina, Metal Finishing, Construction Site, and Auto Salvage Yard Sectors"

1( b) Short Characterization/ Abstract EPA's Office of Compliance ( OC) is interested in testing methods for collecting outcome data from their compliance assistance efforts. OC is planning to conduct surveys to three sectors to compare two survey methodologies: mailed surveys using the " total design method" and surveys conducted as on site visits. EPA will also use the survey results to evaluate the impact of compliance assistance activities on facilities in these sectors. These surveys will support OC in collecting statistically valid compliance assistance outcome data needed to present the impacts of compliance assistance for Government Performance and Results Act ( GPRA) reporting purposes. OC is interested in conducting the surveys for sectors in three stages of analysis/ activity: 1) a sector for which OC is beginning a compliance assistance effort ( marinas); 2) a sector for which OC/ EPA have conducted several compliance assistance activities ( metal finishing); and 3) a sector for which OC doesn't have sufficient information to determine compliance assistance needs ( either construction sites or auto salvage yards).

EPA Region 1 is planning a marinas initiative to provide marinas with basic regulatory information and to encourage " beyond compliance" behavior through the dissemination of a wide variety of tools. EPA Region 1 would like to conduct statistically valid voluntary mail and sitevisit surveys on a subset of the approximate 1,200 marinas in Region 1. These surveys will be used to 1) determine to what degree key environmental practices are currently in use at Region 1 marinas and 2) get a better sense of the compliance challenges faced by this sector. The results of the survey will be used to establish a performance baseline at the start of this initiative. After implementation of the compliance assistance, a follow up survey will be conducted to determine progress against the baseline.

OC has adopted a sector approach for many of its compliance assistance activities. The metal finishing industry is an example of a sector for which EPA has focused many of its compliance assistance activities. There is considerable debate as to the extent of environmental releases, environmental impacts associated with these releases, compliance rates, the need for compliance assistance, and the effectiveness of compliance assistance tools developed for this industry. 5 OC would like to conduct statistically valid voluntary mail and site visit surveys on a subset of metal finishing facilities in EPA Regions 1 and 5 to 1) determine a performance snapshot of this sector which reflects current facility performance with respect to key federal regulations and 2) compare the performance of facilities that have received compliance assistance to those that have not. The surveys will be conducted as a voluntary blind sample ( i. e., the facility's identity will be unknown to the Agency and the facilities will participate voluntarily). The results of the survey will provide OC with information on compliance assistance topics applicable to this sector and information from which to measure the success of OC's compliance assistance programs for Government Performance and Results Act ( GPRA) reporting purposes.

OC is also planning to conduct a compliance assistance needs assessment for two additional sectors: construction sites and auto salvage yards. OC identified these sectors based on anecdotal information from states and EPA regions; however, sufficient data are not available in EPA's databases to evaluate the current state of compliance in these sectors. Therefore, OC is interested in determining:

The level of regulatory awareness in each sector;

A snapshot of environmental performance for each sector;

The need for compliance assistance tools for each sector; and

The tools that would be most accessible and useful for each sector.

OC is soliciting comment whether to conduct statistically valid voluntary mail and site visit surveys of facilities in one of these sectors using the same approach as described above for the marina and metal finishing sectors. Since the population for construction sites and auto salvage yards is not known, OC will conduct double stage cluster sampling as described in Part B of this supporting statement.

2. NEED FOR AND USE OF THE COLLECTION 2( a) Need/ Authority for the Collection There are three main purposes for these compliance assistance surveys:

To collect data to compare the cost ( for both respondents and EPA) and the utility of mailed surveys versus site visit surveys. Site visit surveys are believed to require more respondent time but should result in an improved response rate and more complete and accurate data when compared to a mailed survey. OC would like to test this hypothesis by conducting parallel mailed and site visit surveys to two or more industry sectors.

To determine a current level of regulatory awareness and environmental performance from which to measure the success of the Agency's compliance outreach efforts for reporting under the Government Performance and Results Act ( GPRA). For each sector for which EPA is planning to initiate compliance assistance, a baseline level of performance and 6 regulatory awareness is needed to measure future progress.

To identify areas of regulatory confusion for each sector studied so that compliance assistance outreach resources can be targeted to address those areas.

The compliance assistance outcome data requested by these surveys is not currently in EPA's databases. These surveys will help OC to evaluate the effectiveness of outreach projects and will enable OC to report compliance assistance outcome data that is statistically valid and can be used for GPRA reporting purposes.

The Agency is permitted to collect the information under the following statutes:

The Clean Air Act. The Act refers to activities involving the discharge of hazardous air pollutants and criteria pollutants from emission sources. At § 114, the Agency may require any person who owns or operates any emission source to establish and maintain such records, ... make such reports, ... install, use, and maintain such monitoring equipment or methods, ... sample such emissions, ... and provide such other information as he/ she may reasonably require. ( Note that no additional monitoring or sampling will be required by this ICR).

The Solid Waste Disposal Act. The Act refers to activities at companies that generate hazardous waste. At § 3007, the Agency is permitted to have access to and request records regarding hazardous waste generating activities.

The Clean Water Act. The Act refers to activities involving the discharge of materials into waters of the United States. At § 308, the Agency is permitted to review records to determine compliance with effluent limitations or treatment performance standards.

The information collected through this ICR will aid the Agency in achieving EPA's Strategic Plan goal of protecting the environment through sector based approaches. This goal was developed in response to the 1993 Government Performance and Results Act and is described in EPA's 2000 Strategic Plan, Chapter 2, Protecting the Environment Through the Sector Based Approach.

2( b) Practical Utility/ Users of the Data EPA Region 1 and the EPA Office of Compliance will be the users of the data collected by the surveys covered under this Information Collection Request ( ICR). EPA Region 1 will use the data collected on the marina sector to make potential adjustments to the compliance assistance projects planned for this sector. EPA will use the marinas data to determine a baseline and follow up level of regulatory awareness and environmental performance which EPA cannot determine using existing databases. This information will then be used to measure if compliance assistance efforts undertaken by Region 1 in their marina initiative have improved the level of regulatory awareness and environmental performance for this sector. This information will be of 7 sufficient quality for reporting under the GPRA.

EPA OC will use the information collected on the metal finishing sector to evaluate the impact of compliance assistance to date on this sector by comparing those facilities which have received compliance assistance against those that have not. EPA will also use this information to identify compliance assistance mechanisms effective for this sector.

Information collected on the Construction Site or Auto Salvage Yard sectors will determine the level of regulatory awareness and environmental performance exhibited by these sectors, which EPA cannot determine using existing databases. This information will allow EPA to conduct a compliance assistance needs assessment and will also provide a baseline of environmental performance from which to measure the success of future sector compliance assistance projects.

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA 3( a) Nonduplication The information to be obtained under this ICR has not been collected by EPA or any other federal agency. In general, the sectors to be studied using this ICR comprise:

mostly small facilities;

facilities potentially impacted by the CAA, CWA, HSWA, TSCA; and

facilities that have not been a focus for EPA inspection and enforcement activities.

The Agency has reviewed its databases to identify information for evaluating environmental performance for these sectors. Currently, the Agency does not have sufficient information for this evaluation, since these sectors have not been a high priority for inspection and enforcement activity.

The majority of facilities in these sectors are small indirect dischargers and typically do not fall into EPA's reporting requirements. Therefore, these sectors are not well represented in EPA's media specific and program specific databases. An exception is that a subset of metal finishers and electroplaters have reporting requirements under 40 CFR Parts 433 and 413 as part of the NPDES program. However, reporting under this program is site specific addressing only one media for the metal finishing sector and does not supply information on the sector's performance with other media requirements.

3( b) Public Notice Required Prior to ICR Submission On March 23, 2001, EPA published a pre ICR Federal Register Notice announcing its intent to submit an ICR to OMB regarding compliance assistance surveys for the Marina, Metal Finishing, Construction Site, and Auto Salvage Yard sectors. Attachment A includes a copy of this Federal Register Notice. EPA received two comments in response to this Federal Register Notice. The 8 first comment was from the Automobile Recyclers Association ( ARA). This association represents a portion of the auto salvage yard industry. The comment requested clarification on how EPA will ensure complete coverage of the auto salvage yard sector in its survey efforts. EPA addressed this comment by using the double stage cluster sampling technique. The auto salvage yards will be identified using all available information, not just EPA databases or trade association member lists. The second comment was from the Institute of Scrap Recycling Industries ( ISRI). This association represents scrap metal recyclers. The comment requested clarification on the " salvage yard" sector. EPA addressed this comment by clarifying that the survey is intended for the auto salvage yard sector, SIC 5015. EPA removed references to SIC 5093, which covers scrap metal recyclers.

3( c) Consultations EPA Region 1 conducted marina stakeholder planning meetings in each of the region's states. At these meetings, EPA Region 1 discussed their marina assistance strategy including consultation on their information collection plans. Attendees at the meetings included staff from state Coastal Zone Management program offices, staff from various state program offices that provide assistance to marinas, four State Marina Trade Association presidents, several marina owners, and two Small Business Development Center staff members. In addition, EPA Region 1 consulted with a variety of state environmental assistance provider stakeholders at a workshop session of the Northeast Waste Management Official's ( NEWMOA) 2000 Fall Technology Training Conference.

For the metal finishing survey, EPA OC consulted with members of EPA's Sector Programs Division, EPA Regions 1 and 5, and state compliance assistance staff on the survey instrument. EPA OC also consulted with representatives of the metal finishing industry, including George Cushnie of CAI, Inc., Paul Chalmer of the National Center for Manufacturing Sciences, and Christian Richter of The Policy Group, which represents the Association of Electroplaters and Surface Finishers, the National Association of Metal Finishers, and the Metal Finishers Suppliers Association. EPA Region 1 also consulted with five members of the metal finishing community. In addition, OC consulted with a variety of state environmental assistance provider stakeholders at a breakout session of the 2001 Compliance Assistance Forum about this survey project. As a result of these consultations, EPA made several revisions to the survey to clarify questions, simplify the flow pattern, and lessen the " self incrimination" aspect of the survey.

3( d) Effects of Less Frequent Data Collection The survey and site visit program for the metal finishing and construction site/ auto salvage yard sectors are one time data gathering efforts. The survey and site visit program for the marina sector includes a baseline and follow up survey. The follow up survey, which will occur at randomly selected facilities, results in a slight chance that a facility could be in both the baseline and follow up sample but EPA assumes that it isn't likely to occur. Therefore, this data collection request does not require periodic reporting or record keeping. 9 3( e) General Guidelines This information collection is consistent with OMB guidelines contained in 5 CFR 1320.5( d)( 2).

3( f) Confidentiality EPA does not expect that any confidential business information or trade secrets will be required from the marinas, metal finishing, construction site, or auto salvage yard sectors. In addition, the metal finishing survey is to be conducted as a blind voluntary sample such that the identity of the facility submitting survey information will be unknown to the Agency.

3( g) Sensitive Questions The surveys and site visits addressed in this ICR do not contain any sensitive questions.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED 4( a) Respondents and SIC Codes The respondents for this ICR will be the following:

Approximately 300 of the 1,200 marinas located in EPA Region 1. These facilities fall under SIC code 4493.

Approximately 300 of the 2,060 metal finishers located in EPA Regions 1 and 5. These facilities fall under SIC code 347.

Approximately 300 construction site or auto salvage yard facilities located nationally. Facilities in the construction site sector are covered by SIC codes 15 17, facilities in the auto salvage yard sector are covered by SIC code 5015.

4( b) Information Requested The marinas mail survey and site visit program will request information related to maintenance practices and environmental practices conducted at marina facilities. The metal finishing, construction site, and auto salvage yard mail survey and site visit programs will obtain information required to assess awareness of applicable environmental regulations and performance with respect to those regulations.

Prior to conducting the surveys/ visits, EPA will develop a sector specific survey instrument to be used to identify the applicable regulations for the sector. The survey instrument will address the following types of topics, depending on the sector selected: 10

Compliance with wastewater discharge permits ( including respondent's wastewater segregation practices and wastewater treatment control);

Compliance with RCRA requirements ( including respondent's awareness of and compliance with solid and hazardous waste requirements);

Compliance with air regulations ( respondent's knowledge of and compliance with air requirements for their facility);

Compliance with TRI reporting ( including respondent's understanding of how to identify chemicals or estimate releases of specific chemicals); and

Respondent's awareness of compliance assistance tools and programs.

See Part B, Section 2( d) for the specific survey instruments developed for the marina and metal finishing sectors.

4( c) Respondent Activities Mail survey respondent activities include reviewing the mailed survey instructions and completing the mail survey. The site visit respondent activities include participating in an estimated four hour site visit and providing sufficient data to complete the survey/ checklist.

5. THE INFORMATION COLLECTED: AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT 5( a) Agency Activities Upon approval of this ICR, EPA ( or its contractor) will mail out the marina survey to approximately 200 marinas in Region 1 and will also conduct site visits to collect the survey information from approximately 100 additional marinas. EPA will create a database to track survey form responses. The information will be used to prepare a report which will summarize the findings and make recommendations to Regional Managers on how to improve compliance assistance activities for this sector. Following compliance assistance projects, EPA Region 1 will again conduct site visits to collect survey information from approximately 100 marinas to assess compliance assistance effectiveness.

Upon approval of this ICR, EPA OC will provide management oversight for contractor staff to conduct survey mail outs and site visits to approximately 300 metal finishing facilities and approximately 300 construction site or auto salvage yard facilities. EPA's contractor will create a database to track survey form responses and will prepare a final report to present the findings of the studies and evaluate the effectiveness of the data gathering approaches. 11 5( b) Collection Methodology and Management For the mail and site visit surveys, information will be collected on survey forms and entered into a database. Data entry will be double checked to ensure accurate data transcription. If possible for the site visit programs, portable electronic devices ( e. g., laptop computers or hand held devices) will be used to enter the data directly into a database.

The sector databases created from these surveys will be accessible to EPA staff and will be made publicly available.

The site visit survey will be used to assess the quality of the information provided. A comparison of the results between the mailed and site visit surveys will give EPA a sense of whether respondents are providing accurate information in their mailed surveys based on what the staff conducting the site visit surveys observe.

5( c) Small Entity Flexibility The marina, metal finishing, and construction site/ auto salvage yard surveys should have minimal impact on the small facilities in these sectors since the surveys are one time information requests for any given facility. The mailed surveys will require on average one hour per facility to respond and the site visit surveys will require no more than four hours per facility for their participation.

The site visit program is designed to evaluate environmental performance at sectors that are not well represented in EPA's databases. One of the reasons that the sectors are not well represented is that they comprise small facilities. While not all of the facilities in the sectors will be considered small businesses, many of the facilities visited will be small businesses. The site visit program will therefore be conducted to account for the size of the facility. EPA anticipates that small facilities will not require a full four hours for the site visit, but instead will likely require only one to two hours for survey completion. Therefore, EPA has built small entity flexibility into the site visit program by adapting the length of the visit, and the burden on the facility, to the size of the facility.

5( d) Collection Schedule The information collection activities included in this ICR are anticipated to occur under the following schedule for each sector covered:

Marina Sector Survey to be mailed out within one month of ICR approval by OMB. Site visits to be conducted within three months of ICR approval by OMB.

Metal Finishing Sector Survey to be mailed out within one month of ICR approval by OMB. Site visits to be conducted within three months of ICR approval by OMB. 12 Construction Site/ Auto Salvage Yard Sector Survey to be mailed out within six months of ICR approval by OMB. Site visits to be conducted within six months of ICR approval by OMB.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION 6( a) Estimating Respondent Burden and Costs Table 1 presents estimates of the initial respondent burden for labor hours and costs associated with this ICR. There is no recurring respondent burden associated with this ICR. For the marina survey, which includes the baseline and follow up surveys, the facilities will be selected at random. For this sector, there is a chance that a facility may be randomly selected for both the baseline and follow up surveys. The assumptions made for determining the respondent burden and costs are footnoted in the table. No capital or operations and maintenance costs are incurred by respondents under this ICR.

6( b) Estimating Agency Burden Table 2 presents estimates of the initial Agency burden ( including contractor support) associated with this ICR. There is no recurring Agency burden associated with this ICR.

6( c) Bottom Line Burden and Cost Table Table 3 presents the bottom line burden hours and costs for respondents and EPA. 13 Table 1. Initial Respondent Burden and Costs Activity Burden Hours and Cost Per Recipient Total Burden Hours and Cost For All Recipients ( b)

Labor Hours Costs ( a) Labor Hours Costs ( a)

Marina baseline mailed survey completion 1 $ 69.3 100 $ 6,930 Marina participation in baseline site visit survey 4 $ 277.2 400 $ 27,720 Marina participation in follow up site visit survey 4 $ 277.2 400 $ 27,720 Metal Finishing facility mailed survey completion 1 $ 69.3 100 $ 6,930 Metal Finishing facility participation in site visit survey 4 $ 277.2 400 $ 27,720 Construction Site/ Auto Salvage Yard facility mailed survey completion 1 $ 69.3 100 $ 6,930 Construction Site/ Auto Salvage Yard facility participation in site visit survey 4 $ 277.2 400 $ 27,720 Total 1,900 $ 131,670 ( a) Assumes a $ 69.3/ hr rate based on the Bureau of Labor Statistics " Employer Costs for Employment Compensation." ($ 33/ hr + 110% overhead = $ 69.3/ hr) No other direct costs ( ODCs) are anticipated for the sector surveys.

( b) For the mailed surveys assumes a minimum 50% response rate or 100 responses out of 200 sent surveys. ( See Section 4( b) of Part B for the basis of this assumption) For the site visits, assumes that a maximum of 100 visits will be performed. 14 Table 2. Initial Agency Burden and Costs Sector Activity Costs Labor Other Direct Costs( c) Total Costs Hours ( a) Costs ( b)

Marinas Baseline Survey mailout ( conducted by a contractor) 268 $ 12,700 $ 880 $ 13,580 Baseline Survey site visits 600 $ 21,000 $ 21,000 Follow up Survey site visits 600 $ 21,000 $ 21,000 Response database development 150 $ 5,250 $ 5,250 Data analysis and report 100 $ 3,500 $ 3,500 Metal Finishing Sector Agency Management 80 $ 2,800 $ 2,800 Contractor  Survey mailout( d) 368 $ 17,356 $ 880 $ 18,235 Contractor  Survey site visits 600 $ 28,000 $ 28,000 Contractor  database development 150 $ 6,150 $ 6,150 Contractor  Final Report of survey responses 238 $ 11,100 $ 11,100 Construction Site/ Auto Salvage Yard Sector Agency Management 80 $ 2,800 $ 2,800 Contractor  Survey mailout 268 $ 12,700 $ 880 $ 13,580 Contractor  Survey site visits 600 $ 28,000 $ 28,000 Contractor  database development 150 $ 6,150 $ 6,150 Contractor  Final Report of survey responses 100 $ 4,650 $ 4,650 Totals 4,352 $ 185,795 ( a) The survey mailout estimate assumes labor hours for a five contact approach ( including pre notice letter, mailed survey, post mailout reminder card, replacement surveys, and a final contact by phone for nonresponders). The site visit estimate assumes 100 visits, 4 hours per person per visit, and one person per visit for 50 trips and two people per visit for 50 trips.

( b) Agency $/ hr rate is based on a 1998 GS 13/ 01 salary of $ 55,969 or $ 26.91/ hr with a 30% overhead. The resulting hourly rate is $ 34.98/ hr. The contractor labor rates are based on contract approved labor category rates.

( c) Mailout ODCs include copying charges and postage ( including first class and certified mail for surveys and Federal Express charges for replacement surveys). Site visit costs do not include travel costs.

( d) Includes 100 hours for a survey help line to support the metal finishers mailed survey. 15 Table 3. Summary of Burden and Costs to Respondents and EPA Category Total Labor Hours Total Costs ($)

Initial Respondent Burden 1,900 $ 131,670 Initial Agency Burden 1,610 $ 56,350 Initial Contractor Burden 2,742 $ 129,445 Total 6,252 $ 317,465 6( d) Reasons for Changes in Burden Since this is a new information collection, there is no change in burden for this collection.

6( e) Burden Statement The public burden is estimated to average 1 hour per response for the mailed survey and 4 hours per response for the site visit survey. This estimate includes the time required to complete the surveys, either by filling them out and returning them by mail or by participating in a half day site visit to answer survey questions during that time.

Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal Agency. This includes the time needed to:

review instructions;

develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information;

adjust the existing ways to comply with any previously applicable instructions and requirements;

train personnel to be able to respond to a collection of information;

search data sources;

complete and review the collection of information; and

transmit or otherwise disclose the information.

An Agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number.

Send comments on the need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including through the use of automated collection techniques, to the Director, OEI Collection Strategies Division, U. S. 16 Environmental Protection Agency ( Mail Code 2822), 401 M Street, S. W., Washington, D. C. 20460; and to the Office of Management and Budget, 725 17th Street, N. W., Washington, D. C. 20503, Attention: Desk Officer of EPA. Include the EPA ICR Number ( 2021.01) in any correspondence. 17 Part B 1. OBJECTIVES, KEY VARIABLES, AND OTHER PRELIMINARIES 1( a) Survey Objectives The goals for each of the surveys covered by this information collection request are summarized below by sector:

Marina Sector To determine to what degree key environmental practices are currently in use at Region 1 marinas and to get a better sense of the compliance challenges faced by this sector. The results of the survey will be used to establish a performance baseline at the start of the marina initiative and after implementation of compliance assistance, the follow up survey will determine progress against the baseline.

Metal Finishing Sector To determine a performance snapshot of this sector that reflects current facility performance with respect to key federal regulations and to determine the compliance assistance tools that are used by facilities in this sector.

Construction Site/ Auto Salvage Yard Sector To determine the level of regulatory awareness of the sector and to establish a performance baseline with respect to key federal regulations. Also to determine the need for compliance assistance tools and which tools are most accessible and useful.

1( b) Key Variables The key variables in each survey will be the facility's environmental performance with respect to key federal regulations. This performance measurement will be determined as a percentage of facilities within the sector with good environmental performance with respect to each key federal regulation.

1( c) Statistical Approach The population of marinas in EPA Region 1 is approximately 1,200. The size of the target population and EPA budget constraints require a statistical analysis using a subset of facilities in this sector. Section 2 describes the statistical approach in detail. EPA OC intends to use contractor support for the baseline survey mailout and will use Region 1 personnel for the site visit surveys, database development, mail survey evaluation, and final report preparation activities. The contractor to be used for the baseline survey mailout is Eastern Research Group located at 14555 Avion Parkway, Chantilly, VA 20151.

The population of metal finishers in EPA Regions 1 and 5 is approximately 3,100. The size of the 18 target population and EPA budget constraints require a statistical analysis using a subset of facilities in this sector. Section 2 describes the statistical approach in detail. EPA OC intends to use contractor support for the survey mailout, the site visit surveys, database development, and final report preparation activities. The contractor to be used for these activities is Eastern Research Group located at 14555 Avion Parkway, Chantilly, VA 20151.

The national population sizes for construction sites and auto salvage yards is undetermined but will number in the thousands. The size of these target populations and EPA budget constraints require a statistical analysis of a subset of facilities in either of these sectors. Section 2 describes the statistical approach in detail. EPA OC intends to use contractor support for the survey mailout and site visit surveys that might be conducted for one of these sectors. The contractor to be used has not been determined.

1( d) Feasibility What obstacles might the respondent face in completing the survey?

A goal of the surveys is to assess, for each sector, environmental regulatory awareness and performance with respect to key federal regulations. The questions have been structured in a yes/ no or checklist format and the data being requested should be readily known by the respondents. In some cases a respondent may need to review chemical purchase records to determine whether they have met a chemical amount threshold. However, these types of questions have been minimized as much as possible.

Are sufficient funds available to complete the surveys as designed?

EPA Region 1 has indicated that regional funds are available for the site visits and assessment of data from the marinas sector. EPA OC has already funded a task order for the marina and metal finishing mailouts, metal finishing site visit program, and final report preparation tasks. Funding for a survey of the construction site or auto salvage yard sectors has not yet been appropriated.

Will the survey results be ready in time to serve the program's decision making needs?

Assuming OMB approval of this data collection within six months of the first FRN notice results in data collection from the marina's sector in the fall of 2001. Survey results from that work will then be available for potential adjustments to compliance assistance projects for the sector scheduled for fourth quarter 2001 and 2002. For the metal finishing sector and the construction site/ auto salvage yard sectors, survey results are required for EPA/ OECA compliance assistance decisions for the 2002 and beyond time frame. 19 2. SURVEY DESIGN 2( a) Target Population and Coverage A discussion of the target populations and coverage are provided by sector below:

Marina Sector For the marina sector, the target population is marinas and the coverage is marinas located in EPA Region 1 states ( CT, ME, MA, NH, RI, VT). This subset of marinas has been chosen for coverage since the ICR input will be used by EPA Region 1 in their marinas initiative.

Metal Finishing Sector For the metal finishing sector, the target population is metal finishing facilities covered by SIC code 347. The coverage will be focused on metal finishing facilities located in EPA Region 1 states ( CT, ME, MA, NH, RI, VT) and EPA Region 5 states ( IL, IN, MI, MN, OH, WI). This subset of the metal finishing population has been chosen for coverage since EPA OC has insufficient funds to evaluate facilities nationally and focusing on a few EPA regions allows for economies in travel costs under the site visit survey program.

Construction Site/ Auto Salvage Yard Sector EPA is soliciting comment on whether compliance assistance needs exist for either the construction site or auto salvage yard sectors. Currently, EPA intends to evaluate one of these populations on a national basis to identify those regulatory areas that are problems for the industry sector. Therefore, the coverage would be all facilities in the sector located within the US.

2( b) Sample Design The sampling design by sector to be surveyed is presented below:

Marina Sector Sampling Frame: The sampling frame for this sector is the EPA Region 1 marinas which have been identified through contacts with each state's coastal zone management or pollution prevention office. Most state offices maintain marina lists. The population list has also been checked against marinas identified in applicable trade journals.

Sample Size: Based on standard statistical sampling techniques, EPA has estimated that a sample size of between 88 and 92 facilities will be required to estimate a performance rate for Marinas. To arrive at this range, EPA began by determining the appropriate equation for determining the sample size for estimating a sample proportion. EPA's equation can be written as 1 This equation is derived by first setting up a hypothesis test that a sampled value is within a specified confidence interval around the population mean and then solving the test equation for n, the sample size.

20 n z S e z S N n 1 n N a 2 2 2 2 a 2 2 2 0 0 = + = + /

/

where n 0 = ( z2  / 2) S2/ e2, n is the sample size, N is the population size, e is the tolerable error ( precision), z  / 2 is the z score for  / 2 from the standard normal distribution, ( 1  ) is the confidence level, and S2 is the variance of the sample proportion we are estimating. 1 EPA has information that the population size for this sector could be between 1,000 and 2,000 facilities. EPA has specified a confidence level of 95 percent (   = 0.05), implying a z score of approximately 1.96, and a tolerable error of 10 percent age points ( e = 0.1). The population variance of a proportion mean is equal to p( 1 p) where p is the mean value. EPA does not have enough information to assume a value other than 0.5 for p. This assumption produces the largest estimate of S2 and hence of the sample size. EPA used each of these assumptions to calculate sample sizes for a population of 1,000 facilities and a population of 2,000 facilities. The result is a sample size range of 88 to 92 facilities.

Stratification Variables: In drawing the random sample, EPA will stratify the sample size among the New England states based on the proportion of facilities in each state. EPA is not intending to make comparisons between the states using a set precision or calculate a valid performance rate by state ( i. e., EPA is not drawing a valid random sample for each state). Rather, EPA is stratifying the sample to ensure representation among all of the New England states. EPA has not yet determined the specific percentages that will be applied to each state. However, EPA does have a list of marinas in New England from which this determination can be made.

Since EPA is comparing two methodologies ( mail surveys versus site visits), EPA will draw two samples, one for each methodology. In this manner, EPA will be able to calculate valid performance rates of known precision for each method.

Sampling Method: EPA will conduct the surveys on this sector as a voluntary random sample. EPA will assign each facility a random number ( using a random number generator such as the one available in Microsoft Excel) and then sort the list using the random number. The first x facilities in this sorted list will constitute the random sample, where x is derived from the original estimate of 88 to 92 facilities and is specified below.

EPA anticipates at least a 50% response rate on the mailed surveys using a five step contact process and therefore intends to mail surveys to twice as many facilities as are required by the statistically valid sample size. EPA anticipates that each facility visited in the site visit survey will 2 It should be remembered that EPA will draw two times the specified range to cover nonresponse for the mail survey.

21 result in a completed survey. To ensure that no facility appears in both the mailed and visited samples, EPA will draw both samples simultaneously. In other words, EPA will draw a random sample of between 264 and 276 facilities ( i. e., three times the range specified above), randomly assigning two thirds of the sample to the mail survey and one third to the site visits. 2 In the event that some marinas do not agree to participate in the site visit program, EPA will continue to pull facilities from the sorted list of facilities until the desired sample size is attained ( i. e., 88 to 92 facilities). EPA will track which facilities declined to participate and use available information on these facilities ( e. g., size, location, etc.) to determine if some nonresponse bias exists.

Metal Finishing Sector Sampling Frame: The sampling frame for this sector is EPA Regions 1 and 5 metal finishers which have been identified through The Harris Directory and listings of metal finishing indirect dischargers obtained from area Publicly Owned Treatment Works ( POTW) managers.

Sample Size: EPA followed the same methodology and assumptions as described above for marinas in choosing a sample size for the metal finishing sector. That is, EPA used the equation for sample size above and specified 95 percent confidence and ten percentage points in precision and then assumed that the default compliance rate ( i. e., null) is 50 percent ( p = 0.5). The population for this sector ranges from 2,000 to 4,000 facilities, implying a sample size range of 92 to 94 facilities.

As with the marinas sectors, EPA will be evaluating two different methodologies. Thus, EPA's contractor will draw two random samples. ( i. e., one for each methodology).

Stratification Variables: EPA will stratify the random sample by both state and size ( e. g., number of employees) for the mail survey and by size for the on site survey. For the mail survey, EPA will ensure that each of the states in EPA Region 1 ( CT, ME, MA, NH, RI, VT) and EPA Region 5 ( IL, IN, MI, MN, OH, and WI) are represented in the mail survey. EPA will use the information contained in the sampling frame to determine the percentages for each state. As with the method for marinas, EPA is not intending to make comparisons between states or size ranges with known precision, but is only concerned with ensuring representation for all metal finishers in Regions 1 and 5.

EPA will stratify only by size for the on site visits. EPA expects to make two size classes from the sample frame: " large" and " small" facilities. A number of factors may be relevant for the size of these facilities and EPA will perform background research to make the appropriate size class distinction. For example, the number of employees may be an appropriate, and easily determined, 3 That is, some states may have such a small number of facilities in the random sample making the site visits somewhat costly on a per site basis.

22 size distinction. EPA does not intend to make statistical comparisons of known precision between the size classes, rather EPA wants to ensure that both size classes are represented in the site visits. EPA is not stratifying by state for site visits under this sector due to resource constraints. 3 Sampling Method: EPA will conduct the surveys on this sector as a voluntary random sample. EPA's contractor will assign each facility a random number ( using a random number generator such as the one available in Microsoft Excel) and then sort the list using the random number. The first x facilities in this sorted list will constitute the random sample, where x is derived from the original estimate of 92 to 94 facilities and is specified below.

EPA anticipates at least a 50% response rate on the mailed surveys using a five step contact process and therefore intends to mail surveys to twice as many facilities as are required by the statistically valid sample size. EPA anticipates that each facility visited in the site visit survey will result in a completed survey. To ensure that no facility appears in both the mailed and visited samples, EPA's contractor will draw both samples simultaneously.

In the event that some metal finishers do not agree to participate in the site visit program, EPA's contractor will continue to pull facilities from the sorted list of facilities until the desired sample size is attained ( i. e., 92 to 94 facilities). EPA's contractor will track which facilities declined to participate and will use available information on these facilities ( e. g., size, location, etc.) to determine if some nonresponse bias exists.

Construction Site or Auto Salvage Yard Sector Sampling Frame: The sampling frame for these sectors will be construction sites or auto salvage yards located nationally. The populations for these sectors are currently unknown and EPA intends to use double stage cluster sampling to assess these sectors.

Sample Size: EPA will follow the same methodology and assumptions as described above for marinas in choosing a sample size for the construction site or auto salvage yard sector. That is, EPA will use the equation for sample size specified above and specify 95 percent confidence and ten percentage points in precision. Furthermore, EPA expects to assume that the default compliance rate ( i. e., null) is 50 percent ( p = 0.5). EPA does not have an estimate of the population for either of these sectors, but since 10,000 facilities would require a sample size of only 95 facilities using the above assumptions, EPA expects to have a sample size of less than 100 facilities for either sector.

As with the other two sectors, EPA will be evaluating two different methodologies. Thus, EPA will draw two random samples of the same size ( i. e., one for each methodology). 4 EPA will do this by drawing both set of clusters simultaneously.

5 Based on resource constraints, EPA has determined that site visits should occur during one work week ( i. e., five days). EPA further assumes that site visits will require four hours each. Thus, 10 visits can be performed over one five day work week.

6 Although the estimate of 10 clusters is based on the requirements of the site visits, EPA will use the same criteria in developing the sample for the mail survey.

23 Stratification Variables: EPA does not have sufficient information about these sectors at this time to stratify these sector populations further for survey purposes.

Sampling Method: EPA will choose the sample for the construction site or auto salvage yard sectors using a two stage cluster sampling procedure. EPA is using this method since the populations for these sectors are unknown. Using a two stage cluster sample will allow EPA to pull a valid random sample from the target population while decreasing the cost associated with conducting the site visits and mailing surveys, and will allow the Agency to efficiently develop a sampling frame for the project.

To do this, EPA will follow statistical guidelines for constructing a two stage cluster sample. EPA will divide the United States into distinct geographic clusters ( e. g., counties), labeling each cluster with a unique identifier code. EPA will randomly select one set of clusters for the mail survey and one set for the on site visits, assuring no repetition between the two surveys. 4 EPA will then access information on these clusters from EPA sources ( e. g., Regional offices), state sources ( e. g., state departments of environmental protection), or local records ( e. g., building permits, phone directories, The Harris Directory) to develop a sampling frame for each cluster. EPA will then select a random sample from each cluster.

EPA has determined that 10 site visits can be conducted during one trip to a specific area. 5 Thus, assuming an upper bound of 100 facilities in the sample, EPA will need to randomly pull 10 clusters. 6 After developing the sampling frame for each cluster, EPA will pull a random sample from each cluster following the procedures outlined under both the marinas and metal finishing sectors. That is, EPA will assign each facility a random number and sort by that random number. The first 20 facilities in each cluster for the mail survey and the first 10 facilities in each cluster for the site visits will constitute the random sample for each cluster. As with the marinas and metal finishing sectors, if some facilities decline to participate in the site visit survey, EPA will continue to pull from the list for each cluster until the desired sample size is attained. 24 Sector Required Sample Size Number of Respondents ( assuming 50% response): Mailed Survey Number of Respondents: Site visit Survey Metal Finishing ( 92 94) @ 100 100 100 Marina ( 92 94) @ 100 100 200 Construction site/ Auto Salvage Yard ( 92 94) @ 100 100 100 Total 300 400 2( c) Precision Requirements Precision EPA's sample size estimates are based on ten percentage points in precision and a 95 percent confidence level. That is, EPA will be 95 percent certain that the estimated results will be within plus or minus 10 percentage points of the actual ( population) results. This precision will allow for the identification of trends in the results. Greater precision in the results is not practical since the required sample sizes for a smaller sampling error are significantly greater and beyond the budget available to EPA for these studies.

Nonresponse Plan EPA's belief is that nonresponse is best handled at the design stage of a survey, rather than after the data have been collected. Despite efforts to design an effective survey instrument, however, EPA expects some level of nonresponse. EPA's strategy to reduce nonresponse for this survey is to use a survey design that will minimize the incidence of nonresponse and to use a follow up strategy to collect data from nonresponders. Finally, EPA will analyze the data collected under the survey and analyze the extent to which nonresponse may bias the results. This nonresponse plan summarizes EPA's approach to dealing with two forms of nonresponse: unit nonresponse ( i. e., when a survey is not returned from a sampled facility) and item nonresponse ( i. e., when a survey is returned, but some data elements are missing). For purposes of this survey, EPA expects that unit nonresponse is a more important concern.

There are a number of reasons why selected facilities may not respond ( unit or item) to the 25 survey, some of which may result in significant biases in the data if EPA does not minimize nonresponse at the outset. EPA anticipates five major reasons for potential nonresponse:

1. Strategic nonresponse   Given the nature of the questions ( i. e., evaluating issues related to compliance), facilities may be hesitant to return surveys or to complete all aspects of the survey. Thus, facilities may elect to not return the survey if they believe that they are noncompliant. Furthermore, it seems reasonable to think that facilities that believe they are compliant would be more likely to return the survey. This type of nonresponse would result in an upward bias in any calculated performance measure.

2. Mistrust of regulatory agencies   Some facilities ( or individuals at facilities) may have an inherent mistrust of regulatory agencies regardless of their compliance status. This type of nonresponse may bias results if compliance is correlated with facilities' mistrust of regulatory agencies.

3. Burden   EPA recognizes facility contact persons have limited time to complete surveys. In most cases, the respondent will need to make time to respond to the survey. Thus, some unit nonresponse may occur because the facility contact does not have the time to respond. Additionally, some item nonresponse may occur if the contact does not have time to complete all of the survey questions. This type of nonresponse may bias the results if compliance is correlated with facilities' willingness to make time to respond.

4. Lost survey instruments   Some facilities may intend on completing the survey, but may misplace or lose it before they are able to find the time to complete it. This type of nonresponse may bias the results if compliance is correlated with the type of facilities that lose the survey instrument.

5. Out of business   Although EPA has made every effort to develop an accurate sampling frame, some facilities may no longer be in business and therefore cannot respond. These facilities would no longer be in the target population and nonresponse from them would not bias the estimates.

With these factors in mind, EPA has designed a strategy that will ( 1) reduce the number of initial nonresponders ( i. e., those that do not respond to the initial survey mailing) and ( 2) encompass an effective follow up strategy to obtain information from initial nonresponders.

To reduce the number of nonresponders, EPA will ( 1) focus on designing a survey instrument that reduces nonresponse and ( 2) use a multi staged respondent contact process. In designing the survey instrument, EPA will focus on reducing the burden to the respondents. EPA expects that the data requested should be readily available to the respondents, requiring little additional research on their part. Additionally, EPA will pre test the survey on a subsample of no more than 26 nine respondents. EPA will use feedback from the pre test to revise the survey instrument.

EPA will use the following multi staged respondent contact process ( developed by Dillman). This process encompasses the following stages ( Note that several of these activities will be performed by EPA's contractor):

Stage 1   Prenotification. At this stage, EPA will send the contacts a letter that notifies them that a survey will be sent to them. The letter will be short ( one page) and will explain the type of data that EPA is collecting, why EPA is collecting the data, how the facilities will benefit from the information ( i. e., better targeted compliance assistance strategy), and a statement of EPA's appreciation if they participate in the survey. Additionally, the letter will attempt to assure the contacts that the data are not being collected for enforcement purposes.

Stage 2   Survey Mail out. EPA will mail the survey to respondents one week following the prenotification letter. The survey packet will contain a cover letter reiterating the information in the prenotification letter, the survey instrument, contact information for technical support, and an addressed stamped envelope to reduce the burden of returning the survey.

Stage 3   Reminder Postcard. EPA will mail a reminder postcard to facilities that have not returned a survey 2 weeks following the survey mail out. This postcard will contain contact information on obtaining a replacement survey.

Stage 4   Re mail the Survey. EPA will re mail copies of the survey to facilities that have not returned a survey 2 weeks following the reminder postcard mailing. EPA will remail the same components as the initial survey mail out.

Stage 5   Follow up Phone Calls. EPA expects that the instrument design combined with the first four stages of this contact process will result in a high response rate. To obtain information from persistent nonresponders, EPA will attempt to make telephone contact with these facilities 2 weeks following the re mailing of the survey.

As a final stage in the nonresponse plan, EPA will analyze the data for potential nonresponse biases. EPA will stratify the responses based on the point at which the surveys were received ( e. g., initial survey, following postcard, following re mail of survey, following phone call). EPA will then analyze the key data elements for statistically significant differences ( in mean and variances) among these response groups. Significant differences may imply some degree of nonresponse bias in the data. If EPA detects differences, EPA will use an acceptable statistical procedure to adjust the data such as calculating weighted averages and variances ( Lohr, Sharon, 1999. Sampling: Design and Analysis, Pacific Grove, CA: Duxbury Press. Section 8.5) to reduce the influence of nonresponse bias on the estimated statistics. 27 2( d) Questionnaire Design Marina Survey EPA Region 1' s survey for the marina sector is included here as Attachment B. The marina survey is designed to provide general information on performance towards key environmental regulations. The survey requests information on practices related to stormwater control, oil and fuel handling, and waste management.

The following sections provide a detailed description of the rationale for the questions in the survey. The first two questions of the survey request general information about the marina's size and whether maintenance and/ or repair operations are performed at the facility.

Stormwater Control Questions 9 and 13 request information about stormwater control at marinas. Stormwater can be contaminated with pollutants discharged from marina operations and stormwater flow, through both point and nonpoint sources into New England water bodies. Nonpoint source runoff is primarily addressed by encouraging Best Management Practices ( BMP) through assistance provided to marinas in each coastal state's Coastal Zone Management Program ( CZMP). Point source pollution is addressed through the National Pollutant Discharge Elimination System ( NPDES) permit program's Stormwater General Permit ( SGP) which requires many marinas, primarily those with vehicle maintenance and repair shops, to obtain a permit and develop and implement a pollution prevention plan based on BMPs. Not many marinas in New England's nondelegated states ( MA, ME, and VT) have obtained this permit and there is concern regarding the degree to which marinas understand and implement NPDES requirements and CZMP guidance.

Oil and Fuel Handling Questions 4, 5, and 6 relate to oil and fuel handling. The primary fuel and oil spill sources are boaters who may spill fuel when refueling boats and marina spills from boating accidents, tank/ pipe leaks, and weather events. Marina spills are primarily addressed through boater education, the Oil Spill and Prevention Regulations ( OSPR) associated with the federal Clean Water Act, and the Resource Conservation and Recovery Act ( RCRA) . Thus, in addition to conducting boater training, many facilities have regulatory oil and fuel requirements to meet. For example, many of those with aboveground tanks ( i. e., 660 gallons or more) must prepare and implement a BMP based Spill Prevention Control and Countermeasure Plan ( SPCC) under OSPR, and all of those with underground storage tanks must conduct testing and monitoring under RCRA. EPA Region 1 will assess the degree to which marinas and boaters know and implement regulatory requirements and BMPs through these questions of the survey.

Waste Management 28 Questions 3, 7, 8,10, 11, and 12 address waste management activities at marinas. On aggregate, marinas generate significant amounts of hazardous waste. This is primarily from boat maintenance activities and marina customers who dispose hazardous waste at the marina. The primary pollutants are paints, cleaning products, heavy metals, solvents, oils, and fuels. Improper handling may cause these products to be improperly disposed adversely affecting landfills, stormwater, air, and soil. Hazardous waste is addressed primarily through the RCRA regulations, and other requirements including: NPDES, SPCC, and CZMP. EPA Region 1 will assess the degree to which marina owners understand hazardous waste regulations and guidance through these questions of the survey.

Metal Finishing Survey EPA/ OC's survey for the metal finishing sector is included here as Attachment C. This survey consists of two components. The first is the mailed survey, that will also be used during the site visits. This survey will be used to obtain the information to evaluate performance towards key federal regulations and to evaluate the impacts of compliance assistance. The second component is a checklist that will be used during the site visit to verify information obtained through the survey. This checklist will expand on certain elements of the survey that can be confirmed via visual inspection.

The metal finishing survey is designed to provide general information on performance towards key environmental regulations. The survey requests information on wastewater generation and treatment, hazardous waste handling, control of air emissions, and Toxic Release Inventory ( TRI) reporting requirements. In addition, the survey asks general questions about how compliance information is obtained by metal finishers.

The survey is broken into the following sections:

Section 1  Wastewater Treatment: This section asks questions about the type of wastewaters generated and wastewater treatment used to evaluate performance towards wastewater discharge limits. This section also asks questions about the site's wastewater monitoring and reporting, as well as compliance assistance received by the site regarding wastewater generation and treatment.

Section 2  Hazardous Waste Handling: The hazardous waste handling section requests information to evaluate performance towards requirements of the Resource Conservation and Recovery Act ( RCRA). This section also asks questions about compliance assistance received by the site regarding hazardous waste handling.

Section 3  Air Emissions: This section requests information to evaluate performance towards the chromium electroplating MACT standards and the solvent degreasing NESHAP standards. This section also asks questions about 29 compliance assistance received by the site regarding air emission regulations.

Section 4  TRI: This section requests information to evaluate performance towards the Toxic Release Inventory reporting requirements. This section also asks questions about compliance assistance received by the site regarding TRI reporting.

Section 5  General Information: This section asks about resources used to obtain compliance information, what types of sources would be most helpful, and the number of employees on site.

The following sections provide a detailed description of the rationale for the questions in the survey.

Question 1  Environmental Awards Question 1 starts the survey by asking the site to identify if they have received any awards for environmental performance. This question will be used to evaluate if there is a connection between recognized " good performers" and compliance assistance received by those performers.

Section 1  Wastewater Treatment Questions 2 through 4 ask about the types of wastewater generated on site. This information will be used to determine which types of treatment are applicable to the site. Question 5 asks the site to check all types of wastewater treatment used. Question 6 asks if the site has a wastewater discharge permit, while Question 7 asks if the site conducts monitoring, sampling, and reporting of their wastewater discharges. These questions assess whether the site has the necessary permits and appears to be monitoring and reporting as required by the applicable effluent guidelines regulations. Questions 8 and 9 ask if the site has received compliance assistance regarding wastewater generation and treatment. Question 10 asks if there are wastewater regulations for which the site would like additional compliance assistance, while Question 11 asks the site to identify the sources it uses to obtain information on wastewater regulations and pollution prevention. Questions 8 through 11 will help determine how to assist sites in complying with wastewater regulations.

Section 2  Hazardous Waste Handling Questions 12 through 26 request information on hazardous waste handling practices to evaluate the site's performance towards key RCRA requirements. Question 12 asks if the site generates hazardous waste, such as F006 wastewater treatment sludge. Question 13 asks if the amount of hazardous waste generated exceeds 100 kilograms per month. Compliance requirements depend on the amount of waste generated. Question 14 asks how long the hazardous waste is maintained on site, to evaluate compliance with RCRA storage requirements. Questions 15 through 17 ask if 30 the site is aware of hazardous waste labeling requirements for drums, and if these apply to the site. Questions 18 and 19 ask if the site is aware of hazardous waste manifest records requirements, and if these apply to the site. Questions 20 and 21 asks if the site inspects their hazardous waste storage area, and if so, how often. Question 22 asks if the site has a hazardous waste contingency plan. Questions 14 through 22 are intended to obtain information to evaluate performance towards key RCRA requirements. Questions 23 and 24 ask if the site has received compliance assistance regarding RCRA requirements. Question 25 asks if there are hazardous waste regulations for which the site would like additional compliance assistance, while Question 26 asks the site to identify the sources it uses to obtain information on hazardous waste regulations and pollution prevention. Questions 23 through 26 will help determine how to assist sites in complying with hazardous waste regulations.

Section 3  Air Emissions Questions 27 through 34 ask questions about the chromium electroplating and anodizing maximum achievable control technology ( MACT) standards. These questions will identify whether the site is impacted by the MACT standards and what emission controls are used on site. Question 27 asks if the site performs chromium electroplating or chromic acid anodizing. Question 28 asks how many chromium electroplating and anodizing tanks are on site. Question 29 asks if site personnel are aware of EPA emission control requirements, while Question 30 asks how many tanks use some type of emission control. Question 31 asks the site to identify the types of control technologies, as well as the technologies for which the site monitors performance. Questions 32 through 34 ask the site to identify the types of compliance assistance received regarding the chromium MACT standard. This will help determine how to assist sites in complying with the MACT standard.

Questions 35 through 46 focus on the national emission standards for hazardous air pollutants ( NESHAP) for halogenated solvent cleaning ( 59 FR 61801) and what the site has done to comply with this standard. The NESHAP applies to individual machines rather than to an entire site. Question 35 asks the site if they own or operate any solvent cleaning machines. This question will identify sites that fall under this rule. Question 36 asks for further details about the types of solvents used on site. The halogenated solvent cleaning rule applies only to cleaning machines that contain a solvent containing 5% or more by weight of any one or combination of these solvents: carbon tetrachloride, chloroform, perchloroethylene, 1,1,1 trichloroethane, trichloroethylene, and methylene chloride. Question 37 asks for the types of solvent cleaning machines used on site. Question 38 asks if site personnel are aware of EPA emission standards, while Question 39 asks if these standards apply to the site's solvent degreasing machines. Question 40 asks which methods the site uses to comply with the solvent cleaning NESHAP. Since the NESHAP is on a machine basis rather than a site basis, the site may use more than one method of complying with the NESHAP. Several sources of information are available on the solvent degreasing NESHAP. Questions 41 through 44 ask what sources of information the site has used to obtain compliance assistance. Question 45 asks if there are air regulations with which the site would like additional assistance, and question 46 asks what sources of information on air 31 regulations and pollution prevention the site uses. Questions 41 through 46 will help determine how to assist sites in complying with the NESHAP.

Section 4  TRI Reporting Requirements Question 47 asks if the site is aware of TRI reporting requirements, while Question 48 asks if the site is exempt from TRI reporting. These questions will assess the site's understanding of the reporting requirements. Questions 49 and 50 ask if the site has received compliance assistance regarding TRI reporting. Question 51 asks if there are TRI reporting requirements for which the site would like additional compliance assistance, while Question 52 asks the site to identify the sources it uses to obtain information on TRI reporting requirements. Questions 49 through 52 will help determine how to assist sites in complying with TRI reporting requirements.

Section 5  General This section asks general questions about the types of compliance information that is used by the site or that would be helpful to the site. These questions will allow EPA OC to determine which facilities have received compliance assistance and which have not. Question 53 asks if the site has Internet access. This question will determine if web based assistance would be available to the site. Questions 54 through 57 ask about the National Metal Finishing Resource Center. Responses to these questions will help to identify if facilities are aware of this compliance assistance tool. The questions ask for the type of information obtained from the center and whether it was useful. Question 58 asks the site to identify types of compliance assistance tools that are helpful in order to assist EPA in identifying appropriate tools for this sector. Question 59 asks whether the site is aware of the National Metal Finishing Strategic Goals Program. Question 60 asks for the number of employees working at the site. This question will be used to evaluate trends by size ( as defined by number of employees) in compliance assistance received and performance towards key federal regulations.

The site visit checklist, also included in Attachment C, will provide additional information regarding hazardous waste handling and wastewater treatment operations. This information will be used to confirm, via visual inspection, information provided in the survey. During the site visit, the on site personnel will check those items on the checklist that are true. Section 1 of the checklist contains 15 items that will be evaluated by the on site personnel related to hazardous waste handling procedures ( e. g., drum labeling, waste storage, storage area inspection). Section 2 of the checklist contains three items that will be evaluated by the on site personnel related to wastewater generation and treatment ( e. g., condition of wastewater conveyance systems, handling of wastewater treatment sludge).

Construction Site/ Auto Salvage Yard Survey The construction site or auto salvage yard survey will be designed after EPA makes a determination on which sector to survey. The survey will be designed to provide general 32 information on performance towards key environmental regulations. The survey will request information on topics such as stormwater control measures, waste management including hazardous waste handling practices, and Emergency Planning and Community Response Act ( EPCRA) requirements. In addition, the survey will ask general questions about how compliance assistance information is obtained by operators in these sectors.

3. PRETESTS AND PILOT TESTS EPA Region 1 ( for the marina survey) will conduct a pre test of their survey on no more than nine facilities within the marina sector.

EPA Region 1 and OC conducted a pretest of the metal finishing survey to four metal finishing sites in Region 1. All pretest respondents stated that the survey was easy to follow and to complete, with one respondent stating that the survey required 20 minutes to complete. One respondent felt that some of the questions related to hazardous waste handling were " self incriminating" and that recipients may not complete these questions. This concern was consistent with issues raised during consultation with metal finishing industry representatives; OC modified the survey to address this issue by focusing more on awareness of regulations.

EPA will conduct a pre test of the construction site or auto salvage yard surveys on no more than nine facilities within the selected sectors.

4. COLLECTION METHODS AND FOLLOW UP 4( a) Collection Methods For each sector survey, EPA intends to conduct two types of collection methods. The first is a mailed survey method which includes a five stage contact process described in Section 2( c) above. In addition, for each sector EPA intends to also conduct survey collection through a site visit program. These collection methods have been chosen to address one of EPA's goals in the ICR, which is to compare the burden and response rates typical by each method for multiple industrial sectors.

4( b) Survey Response and Follow up For the mailed surveys, EPA expects a minimum response rate of 50%. This minimum response rate is based on an average " total design method" response rate of approximately 75% ( How to Conduct Your Own Survey, Salant, P., and Dillman, D., John Wiley & Sons, Inc., 1994, pg. 27) and conservatively adjusting this rate down to take into account the nature of the survey ( related to regulatory compliance) and the administering entity ( EPA). The mailed survey approach will include a five stage contact process and will use multiple contact mechanisms ( e. g., first class mail for the initial surveys sent out, federal express shipping for replacement surveys, and phone contacts as a final contact attempt). This approach has been well studied and has been shown to 33 increase response rates. In addition EPA's contractor will attempt to call back facilities that have supplied incomplete or illegible data to minimize unit nonresponse.

For the site visit survey, EPA expects to achieve a completed survey for each site visited. Survey data will be recorded on paper survey forms. In the case of the metal finishing site survey, EPA intends to evaluate the use of laptops or hand held electronic devices for electronic recording of survey results.

5. ANALYZING AND REPORTING SURVEY RESULTS 5( a) Data Preparation For each survey, EPA or their contractor will enter the survey results into an electronic database using off the shelf software ( e. g., Microsoft Access). The data entry will be double checked to ensure that data were entered accurately and missing data items will be flagged. EPA or their contractor will attempt to collect any missing data items through phone contacts with the facilities ( in the case of the metal finishing sector this phone contact will occur through EPA's contractor since it will be a blind survey).

5( b) Analysis The survey results will be analyzed to determine:

Each site's performance against key environmental regulations. ( For example, based on chemical usage and tank sizes, EPA will be able to assess how many of the facilities sampled within a sector should have a spill prevention and control plan versus how many of these facilities indicated that they did have such a plan.)

Trends within a sector based on an evaluation of results across various parameters ( such as number of employees or processes performed). For the metal finshing sector, EPA OC intends to evaluate environmental performance on key regulations between facilities that have received compliance assistance and those which have not.

Key environmental problem areas where a majority of facilities sampled appear to be unaware of or potentially noncompliant with a particular requirement.

Compliance assistance outreach methods preferred by the facilities.

To look at these issues, EPA will employ a variety of statistical techniques, including Equivalency testing   EPA will use standard hypothesis tests for the equivalency between two means to test for differences in the results between different characteristics ( e. g., strata) in each sample and to test for differences between the mailed and site visit surveys. 34 Analysis of variance   EPA will use analysis of variance ( ANOVA) techniques to explore the sources of variation in the data. For example, the metal finishing sector will produce a set of facilities that use different processes. EPA will use a standard one way ANOVA to look for significant differences in results among the various processes. Additionally, EPA may employ a multiple factor ANOVA to look for significant differences across both the process types and survey methods ( i. e., did the survey method contribute to finding significant differences among the process types).

Other   EPA will explore the use of other techniques such as correlation analysis or regression analysis. One potentially fruitful analysis may be discriminant analysis which attempts to derive reliable predictors for a certain variable. For example, EPA may be able to use discriminant analysis to determine that a set of four factors, when combined in a certain way, almost always lead to environmental performance problems for facilities. This would be particularly useful if the four factors are easily observable since environmental performance is generally not easily observable.

One purpose of this sampling will be to compare the mailed surveys with the site visit surveys. EPA will have greater confidence in the site visit survey responses since the survey takers will be able to verify that the responses given are correct. Thus, some of EPA's analysis will be a comparison between the two survey methods. This portion of the analysis will assume that the site visit surveys are more accurate than the mailed surveys and will benchmark the mailed surveys against the site visit surveys. EPA will able to assess the quality and accuracy of the information collected using mailed surveys. This information can be used to ( 1) redesign future mailed surveys, ( 2) provide justification for use of one method over another, and ( 3) determine the probable error ( if any) in other mailed surveys ( e. g., if EPA finds that mailed surveys consistently over state compliance by 20 percent, then the Agency has some information on the potential overestimate from similar mailed surveys).

In addition, EPA will assess the actual burden ( respondent and agency) required to solicit, respond, and review surveys by each collection method ( mailed versus site visit). EPA will be able to use this information in preparing more accurate future ICRs or in re designing future surveys to reduce burden.

5( c) Reporting Results Each set of survey results will be summarized and documented in a sector based report. The reports will be made available to other Agency personnel and to the public. The databases developed under these survey activities will be publicly available upon request. 35 Attachment A ICR First Federal Register Notice Burden Statement The public burden is estimated to average 1 hour per response for the mailed survey and 4 hours per response for the site visit survey. This estimate includes the time required to complete the surveys, either by filling them out and returning them by mail or by participating in a half day site visit to answer survey questions during that time.

Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal Agency. This includes the time needed to:

review instructions;

develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information;

adjust the existing ways to comply with any previously applicable instructions and requirements;

train personnel to be able to respond to a collection of information;

search data sources;

complete and review the collection of information; and

transmit or otherwise disclose the information.

An Agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number.

Send comments on the need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including through the use of automated collection techniques, to the Director, OEI Collection Strategies Division, U. S. Environmental Protection Agency ( Mail Code 2822), 401 M Street, S. W., Washington, D. C. 20460; and to the Office of Management and Budget, 725 17th Street, N. W., Washington, D. C. 20503, Attention: Desk Officer of EPA. Include the EPA ICR Number ( 2021.01) in any correspondence. 36 37 Attachment B EPA Region 1 Marina Survey Burden Statement The public burden is estimated to average 1 hour per response for the mailed survey and 4 hours per response for the site visit survey. This estimate includes the time required to complete the surveys, either by filling them out and returning them by mail or by participating in a half day site visit to answer survey questions during that time.

Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal Agency. This includes the time needed to:

review instructions;

develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information;

adjust the existing ways to comply with any previously applicable instructions and requirements;

train personnel to be able to respond to a collection of information;

search data sources;

complete and review the collection of information; and

transmit or otherwise disclose the information.

An Agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number.

Send comments on the need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including through the use of automated collection techniques, to the Director, OEI Collection Strategies Division, U. S. Environmental Protection Agency ( Mail Code 2822), 401 M Street, S. W., Washington, D. C. 20460; and to the Office of Management and Budget, 725 17th Street, N. W., Washington, D. C. 20503, Attention: Desk Officer of EPA. Include the EPA ICR Number ( 2021.01) in any correspondence. 38 United States Environmental Protection Agency, Region One New England DRAFT Environmentally Responsible Marina Checklist This is a checklist of important environmental practices. It is designed to help marinas improve environmental performance. It does not cover everything: it is a screening checklist to highlight selected areas pertaining to recreational boating.

FOR ALL QUESTIONS, PLEASE USE: Y for Yes N for No DK for Don't Know NA for Not Applicable 1. a. How many employees work at the facility? Full time ___ Part time ___ b. How many boats are moored at the facility? ___ Docked? ___ Stored on land? ___

2. a. Are maintenance and/ or repair operations performed at the facility? ___ b. If yes, are these primarily customer do it yourself repair and maintenance? ___

Some of the practices referred to in the following questions are requirements of law. For further information, see EPA Region One's " Marina Environmental Performance Guide".

3. a. Quantities of hazardous waste generated by the marina each month are calculated, to determine whether the marina is a large or small generator. ____ b. All hazardous wastes are in labeled containers in a dedicated storage area. ____ c. The storage area has an impervious surface and spill containment ( such as berms). ____ d. All hazardous wastes are shipped with a properly licensed transporter. ___ e. Manifests documenting hazardous waste shipments are kept, going back at least 3 years. ____ f. The facility has an active, ongoing effort to reduce the generation of hazardous waste. ____ g. Employees receive training in proper handling of wastes and in emergency procedures.____ h. Used antifreeze and oil are sent for recycling, not disposal. ____

4. Oil ( including motor fuel) is stored above ground in any single tank over 660 gallons? ____ Above ground in total aggregate volume over 1320 gallons? ____ below ground in total aggregate volume of 42000 gallons? ____

5. a. Oil storage has containment ____ b. Spill prevention procedures are in place for: receiving oil from a supplier ____ transferring oil within the facility ____ waste oil disposal _____ c. A Spill Prevention, Control and Countermeasure plan ( SPCC), signed by a registered professional engineer, is on site and posted in plain view at oil storage locations. ____

6. Does the facility have spill prevention procedures in place for fuel dispensing? ____ Do fuel dispensing operations have spill protection? ____ system has overfill alarm ___ containment is in place in case of a spill ___ other _________________________________ b. If boaters operate the facility's fuel dispensing equipment, is this monitored at all times? ___

7. a. Has the amount of each hazardous material stored onsite been calculated, to determine if reporting to 39 the Local Emergency Planning Committee is necessary? ____ 8. Are Material Safety Data Sheets for all hazardous chemicals kept on file, and used for training all employees handling hazardous chemicals? _____

9. Is a storm water discharge permit required of this facility? ______

10. a. When pressure washing boats coated with " sloughing" paints, is removed material collected to prevent releases to water? ___ b. Are blasting, other paint preparation and painting activities contained to prevent abrasives, paint chips, and overspray from being released to the water or land? ____ c. Are parts with fluids, including used oil filters, drained before disposing or recycling? ____ d. Are cracked batteries stored in non leaking secondary containers? ____

11. a. Does the marina provide collection of wastes generated by boaters? Contaminated bilgewater or absorbents ____ paint, sealers, and varnishes, including scrapings ____ solvents ____ cleaners ____ antifreeze ____ septage ____ waste fuel ____ used oil ____ other ____________________________ b. Are boaters notified how to properly handle these wastes in tenant contracts, posted signs or pamphlets? _____ Contaminated bilgewater or absorbents ____ paint, sealers, and varnishes, including scrapings ____ solvents ____ cleaners ____ antifreeze ____ septage ____ waste fuel ____ used oil ____ other ____________________________________

12. Has the facility switched to alternative materials or products to reduce toxicity or other hazards to health, safety or the environment? ____ Safer paint stripping ____ safer painting _____ safer MSD odor chemicals ____ dust collection ____ phosphate free cleaners ____ biodegradable cleaners ____ safer antifreeze ____ other ________________________

13. Has the marina made structural changes to minimize surface water runoff? ____ Berming ____ vegetation ____ riprap ____ drains ____ other ______________________________

14. Has the marina taken any action to improve environmental performance not included above? Please explain_______________________________________________________________________ _____________________________________________________________________________

Matters relating to compliance are explained in the Performance Guide. Or, call EPA at 617 918 1836 for assistance. You will also find resources for assistance in Section 4 of the Performance Guide. 40 Attachment C EPA OC Metal Finishing Survey Burden Statement The public burden is estimated to average 1 hour per response for the mailed survey and 4 hours per response for the site visit survey. This estimate includes the time required to complete the surveys, either by filling them out and returning them by mail or by participating in a half day site visit to answer survey questions during that time.

Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal Agency. This includes the time needed to:

review instructions;

develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information;

adjust the existing ways to comply with any previously applicable instructions and requirements;

train personnel to be able to respond to a collection of information;

search data sources;

complete and review the collection of information; and

transmit or otherwise disclose the information.

An Agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number.

Send comments on the need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including through the use of automated collection techniques, to the Director, OEI Collection Strategies Division, U. S. Environmental Protection Agency ( Mail Code 2822), 401 M Street, S. W., Washington, D. C. 20460; and to the Office of Management and Budget, 725 17th Street, N. W., Washington, D. C. 20503, Attention: Desk Officer of EPA. Include the EPA ICR Number ( 2021.01) in any correspondence. 41 Metal Finishing Performance Evaluation Survey 1. Have you won any awards for your environmental performance? If so, please list them here.

Section 1: Wastewater Treatment 2. Does your site generate chromium bearing wastewater? GYes GNo 3. Does your site generate cyanide bearing wastewater? GYes GNo 4. Does your site generate metal bearing wastewater? GYes GNo 5. Which types of wastewater treatment are used on site ( check all that apply):

None G Equalization/ Neutralization G Chromium Reduction G Cyanide Destruction G Oil Skimming/ Chemical Emulsion Breaking G Chemical Precipitation and Sedimentation G Complex/ Chelated Metals Treatment G Sand/ Multimedia Filtration G Membrane Filtration ( Microfiltration, Ultrafiltration) G Ion Exchange G Sludge Dewatering G Other:

6. Do you have a wastewater discharge permit? GYes GNo 7. Which activities listed below do you perform for your wastewater discharge?

Monitoring ( e. g., flow, pH, ORP) G Sampling of wastewater for specific pollutant parameters G Reporting G 8. Have you received any compliance assistance to reduce the amount of wastewater your facility produces or to reduce the amount of metals in your wastewater? GYes GNo 42 9. If yes, from whom? And was it helpful?_________________________________

10. Are there any wastewater regulations that you feel you would like additional assistance with? If so, what are they?_____________________________________________

11. What sources do you use for information on wastewater environmental regulations and pollution prevention? ( Check all that apply)

Internet G Trade/ professional organizations G Industry/ professional journals G Environmental consultants G Colleagues/ supervisor G Government environmental agencies G Section 2: Hazardous Waste Handling 12. Does your facility generate hazardous waste ( e. g. F006 wastewater treatment sludge)? GYes GNo If answer to Question 12 is no, skip to Question 27.

13. Is hazardous waste generated in excess of 100 kg/ month? GYes GNo 14. How long is the hazardous waste maintained on site? days 15. Are you aware of the hazardous waste labelling requirements for drums? GYes GNo 16. Do they apply to your drums? GYes GNo 17. If not, why not?____________________________________________________

18. Are you aware of the hazardous waste manifest records requirements? GYes GNo 19. If yes, do these hazardous waste manifest records apply to your facility? GYes GNo 20. Do you perform inspections of your hazardous waste storage area? GYes GNo 21. If yes, how often are inspections performed: 43 22. Do you have a hazardous waste contingency plan? GYes GNo 23. Have you received any compliance assistance to help you with the identification and/ or handling of hazardous waste treatment sludge? GYes GNo 24. If yes, from whom? And was it helpful?_________________________________

25. Are there any hazardous waste handling regulations that you feel you would like additional assistance with? If so, what are they?______________________________

26. What sources do you use for hazardous waste information on environmental regulations and pollution prevention? ( Check all that apply)

Internet G Trade/ professional organizations G Industry/ professional journals G Environmental consultants G Colleagues/ supervisor G Government environmental agencies G Section 3: Air Emissions 27. Does your site perform chromium electroplating or chromic acid anodizing operations? GYes GNo If answer to Question 27 is ` NO', skip to Question 35.

28. How many chromium electroplating or chromic acid anodizing tanks do you operate ( excluding rinses)? tanks 29. Are you aware of emissions control requirements for your tanks? GYes GNo 30. If yes, how many of your tanks use some type of emission control? tanks 31. Do you use and monitor any of the following technologies on your chromium electroplating or chromic acid anodizing solutions ( check all that apply):

Use Monitor Composite mesh pad system G G Fiber bed mist eliminator G G Packed bed scrubber G G Chemical fume suppressant in plating baths G G Other: 44 32. Do you have a copy of the EPA Guidebook on How to Comply with the Chromium Electroplating and Anodizing NESHAP? GYes GNo 33. Have you ever received any assistance to help you comply with EPA's Chromium MACT standards? GYes GNo 34. If yes, from whom? And was it helpful?_____________________________

35. Do you own or operate a solvent cleaning machine? GYes GNo If answer to Question 35 is ` NO', skip to Question 45.

36. Does the solvent cleaning machine use a solvent containing 5 % or more by weight of any one or combination of the following halogenated solvents ( check all solvents that are used):

Methylene Chloride G 1,1,1 trichloroethane G Perchloroethylene G Carbon tetrachloride G Trichloroethylene G Chloroform G 37. Which of the following solvent cleaning machines are used?

Batch Cold Machine G In line Cold Machine G Batch Vapor Machine G In line Vapor Machine G 38. Are you aware of the EPA emissions standards for solvent cleaning machines? GYes GNo 39. If yes, do these standards apply to your machines? GYes GNo ( Why not?_______________________________________)

40. If these standards apply, what method does your site use to comply with emission standards for solvent cleaning machines?

Equipment compliance option G Overall emission limit G Not certain G 41. Do you have a copy of the EPA Guidance Document for Halogenated Solvent Cleaner NESHAP? GYes GNo 45 42. Have you used the EPA's Halogenated Solvent Cleaner Rule Assistance Website? GYes GNo 43. Have you ever received any assistance to help you comply with EPA's Solvent MACT standards? GYes GNo 44. If yes, from whom? And was it helpful?_________________________________

45. Are there any air regulations that you feel you would like additional assistance with? If so, what are they?______________________________________________

46. What sources do you use for information on air environmental regulations and pollution prevention? ( Check all that apply)

Internet G Trade/ professional organizations G Industry/ professional journals G Environmental consultants G Colleagues/ supervisor G Government environmental agencies G Section 4: Toxics Release Inventory ( TRI) Reporting 47. Are you aware of the EPA Form R ( TRI) for Toxic Chemical Release Reporting? GYes GNo 48. Is your facility exempt from TRI reporting? GYes GNo If yes, why? ______________________________________

49. Have you ever received any assistance to help you complete your TRI reporting? GYes GNo 50. If yes, from whom? And was it helpful?_________________________________

51. Are there any TRI reporting requirements that you feel you would like additional assistance with? If so, what are they?______________________________________

52. What sources do you use for information on TRI Reporting? ( Check all that apply)

Internet G Trade/ professional organizations G Industry/ professional journals G Environmental consultants G Colleagues/ supervisor G Government environmental agencies G Section 5: General 53. Do you have internet access? GYes GNo 46 54. Have you used the National Metal Finishing Resource Center internet site ( nmfrc. org)? GYes GNo If answer to Question 54 is no, skip to question 58.

55. If yes, how do you rate the usefulness of the assistance provided? GVery Good GGood GFair GPoor 56. What type of information have you obtained from the NMFRC ( check all that apply)?

Compliance Information G Environmental Regulations G Process information G 57. What types of actions have you taken as a result of information you obtained on NMFRC ( check all that apply)?

Changed process G Modified reporting procedures G Implemented pollution prevention practices G None G Implemented pollution control G Other: Obtained permit G 58. Would you find the following types of compliance assistance helpful?

Yes No Internet based training/ guidance G G Workshops/ Training G G CD ROM G G Onsite Technical Assistance Visits G G Inspections G G Mailed Fact Sheets/ Guidance G G 59. Are you aware of the National Metal Finishing Stategic Goals Program? GYes GNo 60. What is the number of full time equivalent employees working at your site? _____ 47 Checklist for Metal Finishing Shops 1) Materials and Waste Storage & Management ( Does the Facility have good control over Chemicals and Waste?)

__ Flammable and Hazardous liquids are stored in containers that are either approved by the U. S. Department of Transportation ( DOT) or by the State Fire Marshall, or listed and labeled by the National Registration and Testing Laboratory ( UL Listed)

__ Lids are tight fitting and sealed, and bungs are closed __ Containers, tanks, and flammable cabinets are labeled with the name of the material they hold, and the type of hazard they present. ( e. g., flammable)

__ Flammables are stored in an area ( such as an airtight metal cabinet, metal cabinet vented to the outside, or flammables storage room) approved by the local fire department.

__ Hazardous Waste storage area is labeled and limits of area are marked.

__ Hazardous Waste storage area has a communication device for emergencies.

__ Drums are stored in rows with sufficient aisle space for a person to walk between, and all labels are visible.

__ Hazardous Waste drums are clearly labeled with " Hazardous Waste", the date on which the drum began accumulating waste, name of waste and type of hazard ( flammable, toxic, etc.).

__ Drums are palletized and stacked no more than two containers high.

__ Containers in " Satellite accumulation areas" are labeled with " Hazardous Waste", name of waste, type of hazard, and are kept closed except when waste is being added.

__ Trash is not mixed in with hazardous waste.

__ Drums of materials and waste stored outside are in a covered area with secondary containment.

__ There are no leaks or spillage in chemical or waste storage areas.

__ A log is kept of weekly inspections of hazardous waste storage areas.

__ Facility has a RCRA ID number, and is using a licensed waste hauler for hazardous waste. 48 2) Wastewater Discharge ( Is water from this facility harming the environment?)

__ Direct Dischargers have an National Pollution Discharge Elimination System ( NPDES ) Permit issued by EPA and the state.

__ Indirect Dischargers have a Permit from the local Publicly Owned Treatment Works ( POTW) or EPA, if there is no local pretreatment authority.

__ Floor of facility is made of impervious material, and is in good condition.

__ Floor trenches lead to sump area that is pumped out on a regular basis and run through waste treatment system. Floor trenches are covered.

__ All sludge from a waste treatment system is disposed of as hazardous waste.

Burden Statement The public burden is estimated to average 1 hour per response for the mailed survey and 4 hours per response for the site visit survey. This estimate includes the time required to complete the surveys, either by filling them out and returning them by mail or by participating in a half day site visit to answer survey questions during that time.

Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal Agency. This includes the time needed to:

review instructions;

develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information;

adjust the existing ways to comply with any previously applicable instructions and requirements;

train personnel to be able to respond to a collection of information;

search data sources;

complete and review the collection of information; and

transmit or otherwise disclose the information.

An Agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number.

Send comments on the need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including through the use of automated collection techniques, to the Director, OEI Collection Strategies Division, U. S. Environmental Protection Agency ( Mail Code 2822), 401 M Street, S. W., Washington, D. C. 20460; and to the Office of Management and Budget, 725 17th Street, N. W., Washington, D. C. 20503, Attention: Desk Officer of EPA. Include the EPA ICR Number ( 2021.01) in any correspondence. 49