The estimated burden associated with Consolidated Funding Cooperative Agreements represents the number of hours that are spent in identification of environmental results, research, data collection, analysis, negotiation, and preparation of Consolidated Funding Cooperative Agreements each year.  EPA estimates that approximately 14 (3 new respondent CA and 11 amended respondent CAs) Consolidated Funding Cooperative Agreements are in place each year.  EPA estimates that approximately 48 hours a year are necessary to meet the requirements of a Consolidated Funding Cooperative Agreement.  This type of agreement is composed of a Pre-Remedial, Core Program, and Support Agency Cooperative Agreement.

		The estimated burden associated with the Conclusion of a Cooperative Agreement represents the number of hours that are spent in assembling and reconciling financial data, identifying any outstanding contractual issues, assembling relevant data deliverables and other documentation, coordinating with USEPA personnel in the disposition of equipment and other acquisitions under the agreement, determining final cost shares and preparing the site for the operation and maintenance.  EPA estimates that approximately 6 (6 new respondent CAs and 0 amended respondent CAs) Cooperative Agreements are concluded each year.  The Superfund Subpart O Workgroup estimates an average of 15 hours are needed to meet the burden imposed by the requirements under a Cooperative Agreement.  Those requirements include: general authorities; purpose statement; site description; statement to follow guidance; statement of work; schedule of deliverables; SPOC; CERCLA assurances; list of Support Agency Cooperative Agreements; sanctions for failure to comply with the terms of the Cooperative Agreement; site access; joint inspection of the remedy; exclusion of third party benefits; State review; and a list of responsible party activities.

		The estimated burden associated with the Records Retention requirements represents the number of hours that are spent each year beyond the 10-year (Superfund) retention requirement for record maintenance, storage, and any document requests that would be made throughout the year.  All cooperative agreements must meet these Records Retention requirements, and incur the resulting burden.  EPA estimates that approximately 423 (171 new respondent CAs and 252 amended respondent CAs) Cooperative Agreements will be in place each year.  Superfund program experience indicates that an average of 7 hours will be required each year to meet the burden imposed by this regulation's Records Retention requirements.

 National Oil and Hazardous Substances Pollution Contingency Plan (NCP)
      Respondent burden estimates are calculated from a combination of sources: historic and projected data from Superfund databases, contract records, consultation with EPA headquarters and regional staff, and information contained in the previous version of this ICR.  Burden hours are estimated for the number of hours expected annually for each activity.  The annual hours per activity figure is multiplied by the number of sites expected to be engaging in the activity every year.  This calculation gives the total annual hours for all sites by activity.  All burden hours, with the exception of ARARS, placed on states refer to only activities conducted at state-lead sites.  All burden hours placed on communities refer to activities that are conducted at all Federal and state-lead sites.

      The estimated number of respondents reported for this information collection is 12,283. The total of all sites with state-lead activities is 198 (Exhibit 6). The number of all people participating in community activities at all sites is 12,085 people (Exhibit 7).  The estimated number of responses is 12,728.  This number of responses was calculated by summing the state responses for all activities at all sites per year of 418 (Exhibit 6) and community (or individual) responses of 12,310 (Exhibit 7) for all activities at all sites.

(i) State Burden Hours
      The total hours for an RI/FS is assumed to consist of 80 percent contractor work and 20 percent government work.  The total contractor hours for an RI/FS project, 10,000 hours, is calculated based on recent contract records from the Office of Superfund Remediation and Technology Innovation (OSRTI) and recent discussions with Superfund contract experts.  Data for costs billed as direct labor across all projects and years provides information about the number of hours spent on an average RI/FS.  Burden hours can be divided among different labor categories based on contract records: 62 percent professional labor, 30 percent direct labor, 4 percent clerical labor, and 4 percent technical labor.  Total contractor hours per RI/FS is estimated to be 10,000 hours per year, which is estimated to account for 80 percent of the hours for an RI/FS.  The remaining 20 percent of RI/FS work, 2,500 hours, is done by the state government.  Therefore, the total annual time devoted to a single RI/FS is estimated to be 12,500 hours.  This ICR estimates that 5 state-lead sites will be in the process of conducting an RI/FS every year.  The total annual burden hours is 62,500 (Exhibit 6).

      Total burden hours for each Proposed Plan is estimated to be 80 hours.  This figure covers the time taken for writing, printing, notification, and distribution of the Proposed Plan.  This estimate remains the same from the previous ICR renewal.  Since Proposed Plans are expected to be completed at 2 state-lead sites each year, a total annual estimate of burden is 160 hours.

      The hours required to complete a ROD are highly variable across the Superfund program given site complexity and enforcement issues.  The burden hours for a ROD are assumed to include the time needed for writing, reviewing, negotiating, and obtaining concurrence.  The ROD finalization process is one that takes quite a lot of time and energy.  The estimates are based on consultation with EPA staff experienced in writing RODs and involved in writing the ROD guidance document ("A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents," EPA 540-R-98-031, OLEM 9200.1-23.P, July 1999).  Experience with very complex and more straight-forward RODs was used in calculating an average value for ROD burden hours.  For the purpose of this ICR it is estimated that the average ROD requires a total of 1,300 hours.  This ICR estimates that RODs will be completed at 2 state-lead sites each year; thus, the estimated total annual ROD burden to states is 2,600 hours.

      The total estimated annual burden for identification of ARARs is 33 hours at each Federal, state or Federal facility-lead site.  This estimate is the same as the ARAR estimate in the previous version of this ICR.  The figure is also confirmed by EPA staff experienced in evaluating ARARs.  ARARs are expected to be evaluated at 34 sites annually, resulting in an estimated burden of 1,122 hours.

      The establishment and maintenance of one site's Administrative Record is estimated to take 40 hours annually.  Since states are estimated to have the lead on 70 active Superfund sites, EPA expects states to spend 2,800 total hours on Administrative Records.  This estimate is provided by a group of experienced EPA headquarters and regional staff.

      Total estimated annual burden hours for each initial and revised CIP are 200 and 100, respectively.  Initial CIPs are estimated to be completed at no state-lead sites each year for a total annual burden of 800 hours.  Revised CIPs are estimated to be completed at 12 state-lead sites each year for a total annual burden of 2,300 hours.  These hours are estimated by a group of EPA headquarters and regional staff experienced in the development and revisions of CIPs.

      EPA estimates that each fact sheet will require an average of 40 hours of work per year.  This estimate is the result of discussion by a group of experienced EPA headquarters and regional Community Involvement staff.  An average of four (4) fact sheets are expected at each of the 70 estimated state-lead active sites.  Therefore, fact sheets will require a total annual estimate of 160 burden hours at each site.  EPA estimates that states will issue fact sheets at 70 active sites per year.  Thus, the total estimated annual burden hours for fact sheets is 12,200.

      The estimated time that each focus group session will require of the state is 30 hours.  This includes preparation for the meeting and attendance.  EPA expects the state to conduct four (4) focus group sessions at one site in each year, resulting in a total annual estimated burden of 120 hours.  These estimates are provided by a group of experienced EPA Community Involvement staff.

      The estimated annual burden for each workshop is 80 hours.  EPA estimates that the state will be conducting one (1) workshop at one (1) sites in the course of one year and will, thus, devote 80 hours to workshop efforts.  These estimates are based on the knowledge of EPA Community Involvement staff experienced in preparing and conducting workshops at Superfund sites.

         Exhibit 6:  Estimated Burden Hours Placed on States for National Oil and Hazardous Substances Pollution Contingency Plan (NCP)
                                   Activity
                    # of Sites with State-lead Activities/yr
                        # of Activities at each site/yr.
                             Hrs. per Activity/yr
                      Annual Hrs. for Activity at a Site
                        Total Annual Hrs. for all Sites
                                     RI/FS
                                       5
                                       1
                                    12,500
                                    12,500
                                    62,500
                                Proposed Plans
                                       2
                                       1
                                      80
                                      80
                                      160
                                     RODs
                                       2
                                       1
                                     1,300
                                     1,300
                                     2,600
                                     ARARs
                                      34
                                       1
                                      33
                                      33
                                     1,122
                             Administrative Record
                                      70
                                       1
                                      40
                                      40
                                     2,800
                                  Initial CIP
                                       0
                                       1
                                      200
                                      200
                                       0
                                  Revised CIP
                                      13
                                       1
                                      100
                                      100
                                     1,300
                                  Fact Sheets
                                      70
                                       4
                                      40
                                      160
                                    11,200
                                 Focus Groups
                                       1
                                       4
                                      30
                                      120
                                      120
                                   Workshops
                                       1
                                       8
                                      80
                                      80
                                      640
                                          Subtotal

                                      198

                                     TOTAL
                                    82,442

(ii) Community Burden Hours
      All community burden hours are due to voluntary participation in activities at Superfund sites.  The Paperwork Reduction Act (PRA) requires the inclusion of information gathering activities in which the community participates.  These activities are those for which information is expressly collected from community members.  The PRA (5 CFR part 1320, "Controlling Paperwork Burdens on the Public, FRN 8/29/1995, Sect. 1320.3 (h)(8)) excludes the following activities from the definition of information for the purpose of Information Collection Requests: attendance at public informational meetings or briefings, response to comments on EPA documents, participation in community groups for which EPA is not a sponsor, reading fact sheets, and making use of EPA open office hours.  This ICR records estimated burden hours for community members for initial and revised CIP interviews, participation in focus groups and workshops, TAG application and management, and completion of satisfaction surveys.  All estimates are provided by a group of experienced EPA Headquarters and Regional Community Involvement Staff.

      EPA estimates that 40 people will be interviewed for one hour each at 29 Federal and State lead Superfund sites each year for initial CIPs.  The total annual estimated burden for initial CIP interviews at all sites is 1,160 hours.  It is estimated that 25 people will be interviewed for 1 hour each at 94 active Superfund sites each year (13 state-lead and 81 Federal-lead) for the purpose of revising the CIPs.  Therefore, the total estimated annual burden is 2,350 hours (Exhibit 7).

      EPA estimates that an average of 15 people will participate in a two-hour focus group 4 times a year at 5 active Superfund sites.  The total estimated burden for all sites for each year is 600 hours.

      An average of 50 people is expected to participate in a three-hour workshop session once a year at 10 active Superfund sites.  The total estimated annual burden for all sites is 1,500 hours.

      EPA estimates that community groups will apply for available TAGs at 2 Superfund sites.  The application process is estimated to take approximately 80 hours.  The total estimated annual burden for new TAGs 160 hours.  Management of TAGs takes place each year at an estimated 40 sites.  EPA staff estimate that management of these TAGs and the application for supplemental funding requires about 1,260 hours per year for existing agreements (this excludes initial TAGs).

      EPA expects to distribute satisfaction surveys at ten (10) sites each year.  It is estimated that 800 people will spend 0.25 hours (15 minutes) completing each survey.  The total estimated annual burden hours at all sites is 2,000.

      Exhibit 7:  Estimated Burden Hours Placed on Communities for National Oil and Hazardous Substances Pollution Contingency Plan (NCP)
                                   Activity
                      # Federal and State-lead Sites/ yr.
                          # of Activities at each site
                              # of People involved
                             Hrs. per Activity/yr.
                      Annual Hrs. for Activity at a Site
                       Total Annual Hrs. for all Sites
                             Initial CIP Interview
                                      29
                                       1
                                      40
                                       1
                                      40
                                     1,160
                            Revised CIP Interviews
                                      94
                                       1
                                      25
                                       1
                                      25
                                     2,350
                           Focus Group Participation
                                       5
                                       4
                                      15
                                       2
                                      30
                                      150
                            Workshop Participation
                                      10
                                       1
                                      50
                                       3
                                      150
                                     1,500
                                TAG application
                                       2
                                       1
                                      N/A
                                      80
                                      80
                                      160
                                TAG management
                                      40
                                       1
                                      N/A
                                     31.5
                                     31.5
                                     1,260
                             Satisfaction Surveys
                                      10
                                       1
                                      800
                                     0.25
                                      200
                                     2,000

              Subtotal of people at Federal and State-lead sites
                                    12,085

                                     TOTAL
                                     8,580

6(b)	Estimating Respondent Costs

 Superfund Site Evaluation and Hazard Ranking System
      The costs incurred by State and Tribal respondents for conducting site assessment activities equals the estimated average cost per activity multiplied by the number of State/Tribal lead activities.  In addition to activity-specific costs, the States and Tribes incur infrastructure costs associated with developing and maintaining a State or Tribal site assessment program.  These infrastructure costs include such items as training, developing standard operating procedures, administrative support, and computers and automated data processing (ADP) support.

      The total estimated annual respondent cost is $10,099,537, however both activity-specific costs and infrastructure costs are reimbursed by the EPA, thus the effective respondent cost is $0.

      Exhibit 8 provides detailed information on the estimated annual respondent burden and costs as calculated based on projected FY 2019 through FY 2021 activity data.  Depending upon how far a particular site progresses through the site assessment process, the respondent cost per site may range from $9,073.26 (average for conducting pre-CERCLA screening and no other work) to $194,410.73 (cumulative average for conducting pre-CERCLA screening, PA, SI, ESI and HRS package work).

Exhibit 8: Total Annual Respondent Burden and Costs of Superfund Site Evaluation and HRS

                                  Respondent
                                  Activities

                                   Estimated
                                   Cost per
                                  Activity[1]

             Estimated Annual Number of State/Tribal Activities[1]

                                 Total Annual
                                National Cost
                                  by Activity

                             Pre-CERCLA Screening

                                   $9,073.26

                                      262

                                  $2,377,194

                          Preliminary Assessment (PA)

                                  $13,163.84
                                      112

                                  $1,474,350

                             Site Inspection (SI)

                                  $45,934.65

                                      52

                                  $2,388,602

                        Expanded Site Inspection (ESI)

                                  $67,144.97
                                      17

                                  $1,141,465

                               Site Reassessment

                                  $18,404.71

                                      38

                                   $699,379

                                  HRS Package

                                  $59,094.00

                                       4

                                   $236,376
                          State/Tribal Infrastructure

                                 $1,782,171.00

                                   SUBTOTAL

                                      485

                                  $10,099,537
                          Less Federal Reimbursement

                                 -$10,099,537

                                     TOTAL

                                      485
                                      $0

 Weighted average based on activity costs provided by the EPA Regions.

 Cooperative Agreements and Superfund State Contracts for Superfund Response Action
      	(i)  Estimating Labor Costs

      		For all activities covered by this ICR, wage rates for State, Tribal, and political subdivision personnel are estimated to be comparable to those of Federal government personnel.  These wage rates were estimated based upon corresponding Federal GS wage rates as of January 2019. The rates, as outlined below are multiplied by a 1.6 benefits multiplication factor to account for government overhead expenses.

      						Management		GS 13, step 1			$57.99/hour
      						Technical			GS 11, step 1			$40.69/hour
      						Clerical				GS 7, step 1				$27.49/hour

      	These rates are from the Office of Personnel Management (OPM) "2019 General Schedule" which excludes locality rates of pay.  These rates can be obtained from the OPM website,  https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/2019/general-schedule.  It is further estimated that approximately 20 percent of the respondent activity is Managerial, 70 percent is technical, and 10 percent is clerical in nature.  Based upon the above, the weighted average is $42.83 per hour [(57.99*0.2)+(40.69*0.7)+(27.49*0.1)].

      		(ii)  Estimating Capital and Operation and Maintenance Costs

      		The only type of costs associated with this information collection activity is labor costs. There is no estimated Capital/Startup and Operation and Maintenance Costs associated with this collection of information.

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

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

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

      		The total respondent costs have been calculated as the addition of the capital/startup costs, and the annual operation and maintenance costs.  The average annual cost for capital/startup and operation and maintenance costs to respondents over the next three years of the ICR is estimated to be $0.

 National Oil and Hazardous Substances Pollution Contingency Plan (NCP)
      Respondent costs are divided into labor costs and other costs, which includes all operation and maintenance, non-labor, and capital costs.  The methodology for calculating these costs for the three year ICR period is addressed in detail below.

      All costs the state incurs, with the exception of the ARARs analysis, is ultimately paid for by the Federal government through any one of two relevant cooperative agreements (CAs) as stipulated in Subpart O of the NCP.  These cooperative agreements are CORE agreements, which provide fund for infrastructure work and are non-site-specific in nature, and Remedial CAs that provide site-specific money for remedial process actions in Superfund.

(i) Estimating labor costs
      Labor rates for government employees are estimated using the Office of Personnel Management's General Schedule pay tables as of January 2019.  For the purposes of this ICR, state government salaries are assumed to be the same as Federal pay scales.  It is assumed that the average unit of remedial work is comprised of 10 percent managerial, 80 percent technical, and 10 percent support staff effort.  Thus, a weighted average is used to represent the hourly labor rate of government work. To determine the hourly wage, 50 percent of the value of a Step 5, GS-12 ($34.54) and GS-13, ($41.07) are summed and averaged ($37.81) and then adjusted for locality pay using a factor of 1.20, which results in $45.37.  To further adjust for overhead, $45.37 is multiplied by 1.6, which results in $72.59, the governmental hourly labor rate applied to the following activities conducted by state agencies for the Superfund remedial program: Proposed Plans, RODs, ARARs, Administrative Records, initial CIPs, revised CIPs, fact sheets, focus groups, and workshops.  The same hourly labor rate applies to all Federal activities.

      The hourly labor rate for the RI/FS activity is calculated as 20 percent government and 80 percent contractor effort.  These assessments involve a great deal of field work and typically involve lots of contractor support.  Using past historical rates, the average contractor hourly labor rate is estimated to be approximately 62 percent of the average government hourly labor rate.  Therefore, the average contractor hourly labor rate is estimated to be $45.01.  The average government hourly labor rate of $72.59 is used for the government's 20 percent.  Therefore, the average hourly labor rate for RI/FS work is $50.53, calculated by: [0.2(72.59) + 0.8 (45.01)].

      The hourly labor rate for community members who participate in Superfund remedial activities on a voluntary, and non-paid, basis is $28.13.  The value is based on Bureau of Labor Statistics November 2018 data, which reports an average hourly wage of $27.43 for "employees on private nonfarm payrolls by industry sector, seasonally adjusted."  The recent trend in this category of BLS data is for the rate to increase approximately $0.70 per year.  Therefore, $28.13 is the average rate over the three-year period of this ICR for all activities in which the community may participate.  Labor costs for community activities represent hypothetical costs only.

(ii) Estimating capital, operations and maintenance, and other costs
      Capital, operation and maintenance (O&M), and non-labor costs to states apply for the following Superfund remedial activities: RI/FS, Proposed Plans, RODs, Administrative Records, and fact sheets.  The Federal government incurs none of these costs for oversight of state activities.  The Federal government does incur non-labor costs for the Administrative Records, fact sheets, and satisfaction surveys.  Community members have no O&M, non-labor or capital costs.  States, communities, and the Federal government do not incur any capital costs in these Superfund remedial activities as no new equipment is purchased for their purposes.

      All O&M and non-labor costs for RI/FS conducted at state-lead sites are calculated from OSRTI contracts records from the previous version of this ICR, adjusted for inflation, using a value of 1.9 percent, which is the average inflation rate in the United States for 2018, based on the Bureau of Labor Statistics' Consumer Price Index.  The RI/FS contractor non-labor cost includes $87,792.58 in fees and profits, $126,325.04 for equipment, and $84,159.07 for indirect costs such as travel and reports.  The equipment costs reflect charges for the use of equipment, such as computers and sampling instruments, which the contractor already owns.  The total non-labor cost for each RI/FS in a single year is, therefore, estimated at $292,715.10 (Exhibit 9).

      Operation and maintenance is defined as activities that are required to keep projects supported and moving forward.  For the RI/FS it is estimated that contractors incur approximately $42,674.18 in a single year for each project.  These costs include charges for mail, supplies, and faxes.  O&M costs incurred by the Agency are discussed in the following paragraph.

      The bulk of O&M costs associated with Proposed Plans, RODs, Administrative Records, and fact sheets are those costs that are required for printing, document distribution, newspaper announcements, and records management.  Costs for mailing and data collection with contractor support also apply to the satisfaction survey.  Annual non-labor costs for satisfaction surveys are estimated by EPA staff conducting the survey to be $6,396.39.  For all other activities with O&M costs, the values from the previous version of this ICR are used and adjusted for inflation.  Inflation is calculated by using a value of 1.9 percent, which is the average inflation rate in the United States for 2018, based on the Bureau of Labor Statistics' Consumer Price Index. Using 1.9 percent as an inflation value, the following O&M annual costs for each activity are:
         	-Proposed Plan: 		$1,797.49
         	-RODs: 			$1,937.04
         	-Administrative Record:	$1,450.70
         	-Fact Sheets:		$1,745.41

(iii) Annualizing capital costs
      No significant capital costs are incurred during the activities described in this ICR.

Exhibit 9:  Estimated Cost to States for the National Oil and Hazardous Substances Pollution Contingency Plan (NCP)

                                   Activity
                 Total State-lead Activities at Sites per year
                          Hours per Activity per year
                               Hourly Labor Rate
                           Labor costs per Activity
                      Capital Costs per Activity per year
           Contractor Related non-labor Costs per Activity per year
                      O&M Costs per Activity per year
                        Total Annual Costs per Activity
                    Total Annual Labor Costs for all sites
                   Total Annual Capital Costs for all sites
         Contractor Related Total Annual Non-labor Costs for all sites
                   Total Annual O&M Costs for all sites
                       Total Annual Costs for all sites
                                     RI/FS
                                                                              5
                                                                          12500
                                                                         $50.53
                                                                    $631,625.00
                                                                          $0.00
                                                                    $292,715.10
                                                                     $41,878.49
                                                                    $966,218.59
                                                                  $3,158,125.00
                                                                          $0.00
                                                                  $1,463,575.50
                                                                    $209,392.45
                                                                  $4,831,092.95
                                Proposed Plans
                                                                              2
                                                                             80
                                                                         $72.59
                                                                      $5,807.20
                                                                          $0.00
                                                                          $0.00
                                                                      $1,763.97
                                                                      $7,571.17
                                                                     $11,614.40
                                                                          $0.00
                                                                          $0.00
                                                                      $3,527.94
                                                                     $15,142.34
                                     RODs
                                                                              2
                                                                           1300
                                                                         $72.59
                                                                     $94,367.00
                                                                          $0.00
                                                                          $0.00
                                                                      $1,900.92
                                                                     $96,267.92
                                                                    $188,734.00
                                                                          $0.00
                                                                          $0.00
                                                                      $3,801.84
                                                                    $192,535.84
                                     ARARs
                                                                             34
                                                                             33
                                                                         $72.59
                                                                      $2,395.47
                                                                          $0.00
                                                                          $0.00
                                                                          $0.00
                                                                      $2,395.47
                                                                     $81,445.98
                                                                          $0.00
                                                                          $0.00
                                                                          $0.00
                                                                     $81,445.98
                             Administrative Record
                                                                             70
                                                                             40
                                                                         $72.59
                                                                      $2,903.60
                                                                          $0.00
                                                                          $0.00
                                                                      $1,450.70
                                                                      $4,354.30
                                                                    $203,252.00
                                                                          $0.00
                                                                          $0.00
                                                                    $101,549.00
                                                                    $304,801.00
                                  Initial CIP
                                                                              0
                                                                            200
                                                                         $72.59
                                                                     $14,518.00
                                                                          $0.00
                                                                          $0.00
                                                                          $0.00
                                                                     $14,518.00
                                                                          $0.00
                                                                          $0.00
                                                                          $0.00
                                                                          $0.00
                                                                          $0.00
                                  Revised CIP
                                                                             13
                                                                            100
                                                                         $72.59
                                                                      $7,259.00
                                                                          $0.00
                                                                          $0.00
                                                                          $0.00
                                                                      $7,259.00
                                                                     $94,367.00
                                                                          $0.00
                                                                          $0.00
                                                                          $0.00
                                                                     $94,367.00
                                  Fact Sheets
                                                                             70
                                                                             40
                                                                         $72.59
                                                                      $2,903.60
                                                                          $0.00
                                                                          $0.00
                                                                      $1,745.41
                                                                      $4,649.01
                                                                    $203,252.00
                                                                          $0.00
                                                                          $0.00
                                                                    $122,178.70
                                                                    $325,430.70
                                 Focus Groups
                                                                              1
                                                                             30
                                                                         $72.59
                                                                      $2,177.70
                                                                          $0.00
                                                                          $0.00
                                                                          $0.00
                                                                      $2,177.70
                                                                      $2,177.70
                                                                          $0.00
                                                                          $0.00
                                                                          $0.00
                                                                      $2,177.70
                                   Workshops
                                                                              1
                                                                             80
                                                                         $72.59
                                                                      $5,807.20
                                                                          $0.00
                                                                          $0.00
                                                                          $0.00
                                                                      $5,807.20
                                                                      $5,807.20
                                                                          $0.00
                                                                          $0.00
                                                                          $0.00
                                                                      $5,807.20

Totals
                                                                    $440,449.93
                                                                  $5,852,800.71

Federal Funds Used
                                                                    $440,449.93
                                                                  $5,771,354.73

State Funds Used
                                                                              0
                                                                     $81,445.98

         Exhibit 10:  Estimated Costs to Communities (Voluntary activities, not actually expended costs) for the National Oil and Hazardous Substances Pollution Contingency Plan (NCP)
Activity
Total Hours for Activities for All People Involved at Federal and State-lead Sites/yr
Hours per Activity per year
Hourly Labor Rate
Annual Labor Costs per Activity
Capital, O&M, Non-labor Costs per Activity per year
Total Annual Costs per Activity
Total Annual Labor Costs for all Sites *
Total Annual Capital, O&M, Non-labor Costs for all Sites
Total Annual Costs for all Sites
Initial CIP Interview
                                                                       1,160.00
                                                                              1
                                                                         $28.13
                                                                         $28.13
                                                                          $0.00
                                                                         $28.13
                                                                     $32,630.80
                                                                          $0.00
                                                                     $32,630.80
Revised CIP Interviews
                                                                       2,350.00
                                                                              1
                                                                         $28.13
                                                                         $28.13
                                                                          $0.00
                                                                         $28.13
                                                                     $66,105.50
                                                                          $0.00
                                                                     $66,105.50
Focus Group Participation
                                                                         150.00
                                                                              2
                                                                         $28.13
                                                                         $56.26
                                                                          $0.00
                                                                         $56.26
                                                                      $8,439.00
                                                                          $0.00
                                                                      $8,439.00
Workshop Participation
                                                                       1,500.00
                                                                              3
                                                                         $28.13
                                                                         $84.39
                                                                          $0.00
                                                                         $84.39
                                                                    $126,585.00
                                                                          $0.00
                                                                    $126,585.00
TAG application
                                                                         160.00
                                                                             80
                                                                         $28.13
                                                                      $2,250.40
                                                                          $0.00
                                                                      $2,250.40
                                                                    $360,064.00
                                                                          $0.00
                                                                    $360,064.00
TAG management
                                                                       1,260.00
                                                                           31.5
                                                                         $28.13
                                                                        $886.10
                                                                          $0.00
                                                                        $886.10
                                                                  $1,116,479.70
                                                                          $0.00
                                                                  $1,116,479.70
Satisfaction Surveys
                                                                       2,000.00
                                                                           0.25
                                                                         $28.13
                                                                          $7.03
                                                                          $0.00
                                                                          $7.03
                                                                     $14,065.00
                                                                          $0.00
                                                                     $14,065.00

TOTAL
                                                                  $1,724,369.00

6(c)	Estimating Agency Burden and Costs

 Superfund Site Evaluation and Hazard Ranking System
      The EPA Regional offices review and manage sites assessed under Superfund by States and Tribes, and provide oversight for State and Tribal site assessment cooperative agreements.  Based on average annual projections from FY 2019 through FY 2021, the estimated average annual burden to the EPA for reviewing and managing site assessment activities conducted by States and Tribes under Superfund is 18,534 hours at an estimated cost of $1,347,792. Reimbursement of state costs brings the total Agency cost to $11,447,330. Exhibit 11 provides detailed information on the estimated annual Agency burden and costs as calculated based on projected FY 2019 through FY 2021 activity data.  Based on the 2019 GS pay schedule, EPA estimates an average hourly Regional labor cost of $45.45, excluding the impact of benefits, to review and manage the work covered under this ICR.  To derive hourly estimates, EPA divided annual compensation estimates by 2,080 which is the number of hours in the Federal work year.  EPA uses a multiplication factor of 1.6 to derive hourly estimates inclusive of benefits.  Taking into account benefits, the average hourly rate is $72.72 ($45.45 x 1.6).

Exhibit 11: Annual Agency Burden and Cost for Superfund Site Evaluation & HRS
                              Respondent Activity
                       Estimated Hours per Activity [1]
                          Estimated Cost per Activity
                           Estimated No. Activities
                            Total Hours by Activity
                            Total Costs by Activity
Review/Manage Pre-CERCLA Screening
                                                                          15.16
                                                                     $1,102.73
                                                                            262
                                                                          3,973
                                                                      $288,917
Review/Manage Preliminary Assessment
                                                                          30.46
                                                                     $2,214.71
                                                                            112
                                                                          3,411
                                                                      $248,048
Review/Manage Site Inspection
                                                                          90.96
                                                                     $6,614.72
                                                                             52
                                                                          4,730
                                                                      $343,966
Review/Manage Expanded Site Inspection
                                                                         135.88
                                                                     $9,881.36
                                                                             17
                                                                          2,310
                                                                      $167,983
Review/Manage Site Reassessment
                                                                          71.05
                                                                     $5,166.95
                                                                             38
                                                                          2,700
                                                                      $196,344
Review/Manage HRS Package
                                                                         352.50
                                                                    $25,633.80
                                                                              4
                                                                          1,410
                                                                      $102,535
SUBTOTAL

                                                                            485
                                                                         18,534
                                                                    $1,347,792
Reimbursement of State Costs

                                                                  $ 10,099,537
TOTAL

                                                                            485
                                                                         18,534
                                                                  $ 11,447,330
1 Weighted average based on activity hours provided by the EPA Regions

      Approximately 61 regional EPA staff review and manage the Superfund site assessment work carried out by states and tribes.  In addition to reviewing site assessment reports submitted by states and tribes, EPA staff conduct site management, oversight and quality assurance activities.  Oversight activities include: reporting and recordkeeping activities such as establishing and maintaining a master database; answering respondent questions; auditing and reviewing data submissions; recording and entering data submissions; analyzing requests for confidentiality and providing confidentiality protection; reformatting and distributing data; and storing data.

 Cooperative Agreements and Superfund State Contracts for Superfund Response Actions
	The only costs to the Agency are those costs associated with maintenance, analysis, and utilization of the collected information.

		The average Agency cost for the collection and administration of the information required by this ICR is estimated to be $385,688.22.  This cost is based on the average hourly labor rate at a GS-12, Step 1, times a 1.6 benefits multiplication factor to account for government overhead expenses for a total hourly rate of $48.76.

		These rates are from the Office of Personnel Management (OPM) "2019 General Schedule" which excludes locality rates of pay.  These rates can be obtained from the OPM website, https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/2019/general-schedule. Details upon which this estimate is based appear in Exhibit 12, "Total Agency Burden," below.

Data was extracted from Compass Financials and SEMS to obtain a five year average of the number of respondents.
                        Exhibit 12: Total Agency Burden

                                   Activity

                    Average number of respondents per Year
                                     2018
                              Unit Burden (Hours)
                           Unit Labor Cost (Dollars)

                           Total Unit Cost (Dollars)

                             Total Burden (Hours)

                             Total Cost (Dollars)
                                Pre-Remedial CA
                                      New
                                     14.8
                                     29.75
                                    $48.76
                                   $1,450.61
                                    440.30
                                  $21,469.03

                                   Amendment
                                     30.6
                                     14.46
                                    $16.25
                                    $235.02
                                    442.48
                                   $7,191.71
                             Remedial response CA
                                      New
                                     29.8
                                     36.40
                                    $48.76
                                   $1,774.86
                                    1084.72
                                  $52,890.95

                                   Amendment
                                     58.6
                                     22.71
                                    $16.25
                                    $369.09
                                    1330.71
                                  $21,628.45
                                Enforcement CA
                                      New
                                     11.2
                                     39.50
                                    $48.76
                                   $1,926.02
                                    442.40
                                  $21,571.42

                                   Amendment
                                     26.6
                                     15.40
                                    $16.25
                                    $250.30
                                    409.64
                                   $6,658.02
                              Removal response CA
                                      New
                                      4.4
                                     40.50
                                    $48.76
                                   $1,974.78
                                    178.20
                                   $8,689.03

                                   Amendment
                                      3.8
                                     14.50
                                    $16.25
                                    $235.67
                                     55.10
                                    $895.56
                                Core program CA
                                      New
                                     16.4
                                     22.30
                                    $48.76
                                   $1,087.35
                                    365.72
                                  $17,832.51

                                   Amendment
                                     27.4
                                     9.70
                                    $16.25
                                    $157.66
                                    265.78
                                   $4,319.81
                               Support agency CA
                                      New
                                     46.4
                                     26.45
                                    $48.76
                                   $1,289.70
                                    1227.28
                                  $59,842.17

                                   Amendment
                                     70.6
                                     10.58
                                    $16.25
                                    $171.96
                                    746.95
                                  $12,140.39
                           Superfund State Contract
                                      New
                                     28.2
                                     33.00
                                    $48.76
                                   $1,609.08
                                    930.60
                                  $45,376.06

                                   Amendment
                                      24
                                     23.93
                                    $16.25
                                    $389.00
                                    574.40
                                   $9,335.91
                    Conclusion of Superfund State Contract
                                      New
                                      9.8
                                     14.75
                                    $48.76
                                    $719.21
                                    144.55
                                   $7,048.26

                                   Amendment
                                       0
                                     6.80
                                    $16.25
                                    $110.52
                                     0.00
                                     $0.00
                            Consolidated funding CA
                                      New
                                      3.2
                                     24.50
                                    $48.76
                                   $1,194.62
                                     78.40
                                   $3,822.78

                                   Amendment
                                     10.8
                                     9.20
                                    $16.25
                                    $149.53
                                     99.36
                                   $1,614.93
                               Conclusion of CA
                                      New
                                      6.2
                                     19.15
                                    $48.76
                                    $933.75
                                    118.73
                                   $5,789.27

                                   Amendment
                                       0
                                     6.80
                                    $16.25
                                    $110.52
                                     0.00
                                     $0.00
                               Records retention
                                      New
                                     170.4
                                     8.25
                                    $48.76
                                    $402.27
                                    1405.80
                                  $68,546.81

                                   Amendment
                                     252.4
                                     2.20
                                    $16.25
                                    $35.76
                                    555.28
                                   $9,025.15
                                     TOTAL

                                  $385,688.22
                          TOTAL NUMBER OF RESPONDENTS
                                       *
                                      846
                              TOTAL BURDEN HOURS*
                                       *
                                   10,896.39
                     AVERAGE BURDEN HOURS PER RESPONDENT*
                                       *
                                     12.89
                                  TOTAL COST

                                  $385,688.22

*Amendment respondents are assumed to have only 1/3 of the burden imposed as Full respondents, since the process of amending is not as extensive as it is for a new application for a CA.

 National Oil and Hazardous Substances Pollution Contingency Plan (NCP)
      Burden on the Environmental Protection Agency covered in the ICR includes those hours and costs incurred in overseeing state activities.  For the RI/FS, Proposed Plans, ARARs, initial and revised CIPs, the assumption is that Federal oversight hours are 10 percent of the state's burden hours for respective activities. For the Administrative Record, fact sheets, focus groups, and workshops the assumption is that Federal oversight hours are 5 percent of the state's burden hours.  These assumptions were provided by a group of Headquarters and Regional Community Involvement EPA employees with the experience to estimate the average Federal oversight hours for these activities.  The total estimated annual burden hours placed on EPA for oversight of state activities is 7,506.20 (Exhibit 13).

         Exhibit 13:  Estimated Burden Hours for Federal Oversight of State Activities for the National Oil and Hazardous Substances Pollution Contingency Plan (NCP)

                                   Activity
                    # of Sites with State-lead Activities/yr
                          # of Activities at each site
                             Hrs. per Activity/yr
                      Annual Hrs. for Activity at a Site
                       Total Annual Hrs. for all Sites
                                     RI/FS
                                       5
                                       1
                                     1,250
                                     1,250
                                     6,250
                                Proposed Plans
                                       2
                                       1
                                       8
                                       8
                                      16
                                     RODs
                                       2
                                       1
                                      130
                                      130
                                      260
                                     ARARs
                                      34
                                       1
                                      3.3
                                      3.3
                                     112.2
                             Administrative Record
                                      70
                                       1
                                       2
                                       2
                                      140
                                  Initial CIP
                                       0
                                       1
                                      20
                                      20
                                       0
                                  Revised CIP
                                      13
                                       1
                                      10
                                      10
                                      130
                                  Fact Sheets
                                      70
                                       4
                                       2
                                       8
                                      560
                                 Focus Groups
                                       1
                                       4
                                      1.5
                                       6
                                       6
                                   Workshops
                                       1
                                       8
                                       4
                                      32
                                      32

                                     TOTAL
                                   7,506.20

      Burden on EPA covered in the ICR also includes those hours and costs incurred in the implementation of Community Involvement activities.  These activities include initial and revised CIPs, fact sheets, focus groups, workshops, satisfaction surveys, and TAGs.  For these activities that are also conducted by states at state-lead sites, the average hours required per activity is the same as the burden hours placed on the states.  Total number of activities and the Federal hours required to complete them are estimated by a group of Headquarters and Regional Community Involvement EPA employees.  EPA is also responsible for maintaining the Administrative Record at all active Federal-lead sites at all stages of the cleanup process.  At the time of this writing there are approximately 430 active Federal-lead NPL sites (EPA database).  Therefore, EPA is responsible for maintaining the AR at 430 sites.  The total estimated annual burden hours placed on EPA for Community Involvement activities is 105,260 (Exhibit 14).

         Exhibit 14:  Estimated Burden Hours for Federal Community Activities for the National Oil and Hazardous Substances Pollution Contingency Plan (NCP)
                                   Activity
                           # Federal-lead Sites/ yr.
                          # of Activities at each site
                             Hrs. per Activity/yr.
                      Annual Hrs. for Activity at a Site
                        Total Annual Hrs. for all Sites
                             Administrative Record
                                      430
                                       1
                                      40
                                      40
                                    17,200
                                  Initial CIP
                                      29
                                       1
                                      200
                                      200
                                     5,800
                                  Revised CIP
                                      81
                                       1
                                      100
                                      100
                                     8,100
                                  Fact Sheets
                                      430
                                       4
                                      40
                                      160
                                    68,800
                                  Focus Group
                                       4
                                       4
                                      30
                                      120
                                      480
                                   Workshop
                                       8
                                       1
                                      80
                                      80
                                      640
                                TAG application
                                       2
                                       1
                                      120
                                      120
                                      240
                                TAG management
                                      40
                                       1
                                      50
                                      50
                                     2,000
                             Satisfaction Surveys
                                      10
                                       1
                                      200
                                      200
                                     2,000

                                     TOTAL
                                    105,260

      Labor costs to EPA were calculated using a weighted average hourly rate for government employees.  The assumption is made that the typical division of labor for these activities is 10 percent managerial, 80 percent technical, and 10 percent support.  To determine the hourly wage, 50 percent of the value of a Step 5, GS-12 ($34.54) and GS-13, ($41.07) are summed and averaged ($37.81) and then adjusted for locality pay using a factor of 1.20, which results in $45.37.  To further adjust for overhead, $45.37 is multiplied by 1.6, which results in $72.59.  The annual labor cost for each activity that involves use of Federal hours is calculated using this labor rate.  Labor costs to EPA are the only Federal costs accounted for oversight of state activities.  The total estimated annual costs incurred by EPA for oversight of state activities is $544,875.06 (Exhibit 15).  The total estimated annual costs EPA incurs for Community Involvement activities is $11,361,096.60 (Exhibit 16).

Exhibit 15. Estimated Costs for Federal Oversight of State Activities for the National Oil and Hazardous Substances Pollution Contingency Plan (NCP)
                                   Activity
                 Total State-lead Activities at Sites per year
                          Hours per Activity per year
                               Hourly Labor Rate
                        Annual Labor Costs per Activity
             Annual Capital, O&M, Non-labor Costs per Activity
                        Total Annual Costs per Activity
                    Total Annual Labor Costs for all Sites
         Total Annual Capital, O&M, Non-labor Costs for all Sites
                       Total Annual Costs for all Sites
                                     RI/FS
                                                                              5
                                                                          1,250
                                                                         $72.59
                                                                     $90,737.50
                                                                          $0.00
                                                                     $90,737.50
                                                                    $453,687.50
                                                                          $0.00
                                                                    $453,687.50
                                Proposed Plans
                                                                              2
                                                                              8
                                                                         $72.59
                                                                        $580.72
                                                                          $0.00
                                                                        $580.72
                                                                      $1,161.44
                                                                          $0.00
                                                                      $1,161.44
                                     RODs
                                                                              2
                                                                            130
                                                                         $72.59
                                                                      $9,436.70
                                                                          $0.00
                                                                      $9,436.70
                                                                     $18,873.40
                                                                          $0.00
                                                                     $18,873.40
                                     ARARs
                                                                             34
                                                                            3.3
                                                                         $72.59
                                                                        $239.55
                                                                          $0.00
                                                                        $239.55
                                                                      $8,144.60
                                                                          $0.00
                                                                      $8,144.60
                             Administrative Record
                                                                             70
                                                                              2
                                                                         $72.59
                                                                        $145.18
                                                                          $0.00
                                                                        $145.18
                                                                     $10,162.60
                                                                          $0.00
                                                                     $10,162.60
                                  Initial CIP
                                                                              0
                                                                             20
                                                                         $72.59
                                                                      $1,451.80
                                                                              0
                                                                      $1,451.80
                                                                          $0.00
                                                                          $0.00
                                                                          $0.00
                                  Revised CIP
                                                                             13
                                                                             10
                                                                         $72.59
                                                                        $725.90
                                                                              0
                                                                        $725.90
                                                                      $9,436.70
                                                                          $0.00
                                                                      $9,436.70
                                  Fact Sheets
                                                                            280
                                                                              2
                                                                         $72.59
                                                                        $145.18
                                                                              0
                                                                        $145.18
                                                                     $40,650.40
                                                                          $0.00
                                                                     $40,650.40
                                 Focus Groups
                                                                              4
                                                                            1.5
                                                                         $72.59
                                                                        $108.89
                                                                              0
                                                                        $108.89
                                                                        $435.54
                                                                          $0.00
                                                                        $435.54
                                   Workshops
                                                                              8
                                                                              4
                                                                         $72.59
                                                                        $290.36
                                                                              0
                                                                        $290.36
                                                                      $2,322.88
                                                                          $0.00
                                                                      $2,322.88

SUBTOTAL
$544,875.06

Cooperative Agreement Federal $ to States (Exhibit 9)
$5,771,354.73

TOTAL
$6,316,229.79

         Exhibit 16:  Estimated Costs to the Federal Government for Community Activities for the National Oil and Hazardous Substances Pollution Contingency Plan (NCP)
Activity
Total Activities at Federal lead Sites/yr
Hours per Activity per year
Hourly Labor Rate
Annual Labor Costs per Activity
Annual Capital Costs per Activity
Annual Non-labor Cost per Activity
Annual O&M Costs per Activity
Total Annual Costs per Activity
Total Annual Labor Costs for all Sites
Total Annual Capital Costs for all sites
Total Annual Non-labor costs for all sites
Total Annual O&M costs for all sites
Total Annual Costs for all sites
Admin. Record
                                                                            430
                                                                             40
                                                                         $72.59
                                                                      $2,903.60
                                                                          $0.00
                                                                          $0.00
                                                                      $1,450.70
                                                                      $4,354.30
                                                                  $1,248,548.00
                                                                          $0.00
                                                                          $0.00
                                                                    $623,801.00
                                                                  $1,872,349.00
Initial CIP
                                                                             29
                                                                            200
                                                                         $72.59
                                                                     $14,518.00
                                                                          $0.00
                                                                          $0.00
                                                                          $0.00
                                                                     $14,518.00
                                                                    $421,022.00
                                                                          $0.00
                                                                          $0.00
                                                                          $0.00
                                                                    $421,022.00
Revised CIP
                                                                             94
                                                                            100
                                                                         $72.59
                                                                      $7,259.00
                                                                          $0.00
                                                                          $0.00
                                                                          $0.00
                                                                      $7,259.00
                                                                    $682,346.00
                                                                          $0.00
                                                                          $0.00
                                                                          $0.00
                                                                    $682,346.00
Fact Sheets
                                                                          1,720
                                                                             40
                                                                         $72.59
                                                                      $2,903.60
                                                                          $0.00
                                                                          $0.00
                                                                      $1,745.41
                                                                      $4,649.01
                                                                  $4,994,192.00
                                                                          $0.00
                                                                          $0.00
                                                                  $3,002,105.20
                                                                  $7,996,297.20
Focus Group
                                                                             16
                                                                             30
                                                                         $72.59
                                                                      $2,177.70
                                                                          $0.00
                                                                          $0.00
                                                                          $0.00
                                                                      $2,177.70
                                                                     $34,843.20
                                                                          $0.00
                                                                          $0.00
                                                                          $0.00
                                                                     $34,843.20
Workshop
                                                                              8
                                                                             80
                                                                         $72.59
                                                                      $5,807.20
                                                                          $0.00
                                                                          $0.00
                                                                          $0.00
                                                                      $5,807.20
                                                                     $46,457.60
                                                                          $0.00
                                                                          $0.00
                                                                          $0.00
                                                                     $46,457.60
TAG application
                                                                              2
                                                                            120
                                                                         $72.59
                                                                      $8,710.80
                                                                          $0.00
                                                                          $0.00
                                                                          $0.00
                                                                      $8,710.80
                                                                     $17,421.60
                                                                          $0.00
                                                                          $0.00
                                                                          $0.00
                                                                     $17,421.60
TAG management
                                                                             40
                                                                             50
                                                                         $72.59
                                                                      $3,629.50
                                                                          $0.00
                                                                          $0.00
                                                                          $0.00
                                                                      $3,629.50
                                                                    $145,180.00
                                                                          $0.00
                                                                          $0.00
                                                                          $0.00
                                                                    $145,180.00
Satisfaction surveys
                                                                             10
                                                                            200
                                                                         $72.59
                                                                     $14,518.00
                                                                          $0.00
                                                                          $0.00
                                                                          $0.00
                                                                     $14,518.00
                                                                    $145,180.00
                                                                          $0.00
                                                                          $0.00
                                                                          $0.00
                                                                    $145,180.00

TOTAL
                                                                 $11,361,096.60

National Oil and Hazardous Substances Pollution Contingency Plan (NCP)

(i) Respondent tally
      The total burden hours and costs displayed in the table below reflects the combined burden and costs on both categories of respondents: states at state-lead sites and individual community members participating voluntarily at Superfund sites.  Community costs of $6,977,949.00 (Exhibit 17) are all hypothetical and do not represent the actual expenditure of dollars because all participation is voluntary. The majority of state costs may be paid through various grants from the Federal government.  The actual cost to states is $81,445.98 (Exhibit 17) for the ARAR analysis.

Exhibit 17:  Total Respondent Burden Hours and Costs for the National Oil and Hazardous Substances Pollution Contingency Plan (NCP)
                                  Respondent
                                 Annual Burden
                                  Annual Cost
                              Total 3 yr. Burden
                               Total 3 yr. Cost
                                    States
                                    82,442
$81,445.98
                                    247,326
                                 $244,337.94
                                  Communities
                                     8,580
                                $6,977,949.00
                                    25,740
                                $20,933,847.00
                                     Total
                                    91,022
                                $7,059,394.98
                                    273,066
                                $21,178,184.94

 (ii) Agency tally
      The total burden and costs represented in the following exhibit is the amount EPA expects to spend directly in oversight of state activities and the information gathering activities EPA conducts with communities at Superfund sites.

         Exhibit 18:  Total Federal Agency Burden Hours and Costs for the National Oil and Hazardous Substances Pollution Contingency Plan (NCP)
                                    Agency
                                 Annual Burden
                                  Annual Cost
                              Total 3 yr. Burden
                               Total 3 yr. Cost
                           Federal Oversight-States
                                   7,506.20
                                $6,316,229.79
                                   22,518.60
                                $18,948,689.37
                         Federal-Community Activities
                                    105,260
                                $11,361,096.60
                                  315,780.00
                                $34,083,289.80
                                Federal Total
                                  112,766.20
                                $17,677,326.39
                                  338,298.60
                                $53,031,979.17

(iii) Variations in the annual bottom line
      Variations to the annual bottom line numbers may occur as sites enter different phases of the remedial process in different years.  Additional, activities that depend almost exclusively on the need at the site, such as fact sheet, are likely to vary year to year.  However, EPA expects the relative number of annual activities to be similar in each year of the ICR period.

6(d)	Estimating the Respondent Universe and Total Burden and Costs

 Superfund Site Evaluation and Hazard Ranking System
      EPA estimates that an annual average of 53 States (including U.S. Territories) and Tribes will perform the site assessment activities described in this ICR.  The estimated annual burden to these respondents for performing these activities is approximately 94,253hours at a cost of approximately $10,099,537.  One hundred percent of the respondent cost ($10,099,537) is reimbursed by the EPA through cooperative agreements.  On average, EPA estimates each respondent will complete and submit approximately 9 assessment reports per year.

Exhibit 19: Total Estimated Respondent Burden and Cost Summary for the Superfund Site Evaluation and Hazard Ranking System
                              Respondent Activity
                         Estimated Hours per Activity
                          Estimated Cost per Activity
                           Estimated No. Activities
                            Total Hours by Activity
                            Total Costs by Activity
Pre-CERCLA Screening
                                                                          93.32
                                                                      $9,073.26
                                                                            262
                                                                         24,449
                                                                     $2,377,194
Preliminary Assessment
                                                                         151.73
                                                                     $13,163.84
                                                                            112
                                                                         16,994
                                                                     $1,474,350
Site Inspection
                                                                         513.81
                                                                     $45,934.65
                                                                             52
                                                                         26,718
                                                                     $2,388,602
Expanded Site Inspection
                                                                         642.94
                                                                     $67,144.97
                                                                             17
                                                                         10,930
                                                                    $1,141,465
Site Reassessment
                                                                         330.37
                                                                     $18,404.71
                                                                             38
                                                                         12,554
                                                                       $699,379
HRS Package
                                                                         652.00
                                                                     $59,094.00
                                                                              4
                                                                          2,608
                                                                       $236,376
State/Tribal Infrastructure

                                                                  $1,782,171.00
SUBTOTAL

                                                                            485
                                                                         94,253
                                                                    $10,099,537
Less Federal Reimbursement

                                                                   -$10,099,537
TOTAL

                                                                            485
                                                                         94,253
                                                                            $0

 Cooperative Agreements and Superfund State Contracts for Superfund Response Actions
	Based on our research for this ICR, approximately 846 respondents will provide the information required under 40 CFR Part 35, Subpart O each year.

	The number of Total Annual Responses is 846.

	The total annual labor costs are $367,678.08.  Details regarding these estimates may be found in Exhibit 5 (Total Respondent Burden of Cooperative Agreements and Superfund State Contracts for Superfund).

Note that the total annual capital and O&M costs to the regulated entity are $0.  These costs are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs.

The total annual burden is 11,282 hours.

 National Oil and Hazardous Substances Pollution Contingency Plan (NCP)
The estimated number of respondents reported for this information collection is 12,283. This number is the sum of all sites with state-lead activities, 198 (Exhibit 6), and people participating in community activities at all sites, 12,085 (Exhibit 7).  The estimated number of responses is 12,728.  This number of responses was calculated by summing the state responses for all activities at all sites per year of 418 (Exhibit 6) and community (or individual) responses of 12,310 (Exhibit 7) for all activities at all sites.

6(e)	Bottom Line Burden Hours and Costs
Consolidated ICRs Respondent Burden:

                                  Respondents
                                   Responses
                               Respondent Hours
                                 O&M Cost
                             Total Respondent Cost
Hazard Ranking System*
                                                                             53
                                                                            485
                                                                         94,253
                                                                          $0.00
                                                                          $0.00
Coop Agree/SSC
                                                                            846
                                                                            846
                                                                         11,282
                                                                          $0.00
                                                                    $367,678.08
NCP**
                                                                         12,283
                                 (198 for States & 12,085  for Communities)
                                                                         12,728
                                  (418 for States & 12,310 for Communities)
                                                                         91,022
                                                    (Sum of exhibits 7 & 8)
                                                                          $0.00
                                                                     $81,445.98
Total
                                                                         13,182
                                                                         14,055
                                                                        196,557
                                                                          $0.00
                                                                       $463,497

* The total cost is $11,447,330, includes $1,782,171.00 annualized capital or O&M costs, however all these costs are reimbursed by the Federal Government through cooperative agreements, resulting in no net cost to respondents for this component of the ICR.

**The total cost is $5,852,800.71, including $440,449.93 annualized capital or O&M costs, however, Federal funds will cover $5,771,354.73 and State Funds will cover $81,445.98 (see Exhibit 9:  Estimated Cost to States for the National Oil and Hazardous Substances Pollution Contingency Plan).

Consolidated ICRs Annual Agency Burden

Agency Hours
Agency Cost
Hazard Ranking System
                                                                         18,534
                                                                    $11,447,330
Coop Agree/SSC
                                                                      10,896.39
                                                                    $385,688.22
NCP
                                                                     112,766.20
                                                                 $17,677,326.39
Total
                                                                     142,196.59
                                                                 $29,510,344.61

6(f)	Reasons for Change in Burden
 Superfund Site Evaluation and Hazard Ranking System
      The decrease of 62,273 hours in respondent burden for the Superfund Site Evaluation and Hazard Ranking System for from the previous ICR is primarily due to a 33 percent decrease in the number of assessment reports estimated to be completed by respondents during FY 2019-2021.

 Cooperative Agreements and Superfund State Contracts for Superfund Response Actions
      The decrease of 2,966 hours in respondent burden for the Cooperative Agreements and Superfund State Contracts for Superfund Response Actions from the previous ICR reflects a decrease in the estimated number of respondents from the previous ICR.  The burden hours were increased as respondents and the agency directed.

 National Oil and Hazardous Substances Pollution Contingency Plan (NCP)
The decrease of 614,733 hours in respondent burden cost for the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) from the previous ICR is partially due to a decrease in total contractor hours for an RI/FS project from the previous ICR. The decrease is also due to a reduction in the number of Technical Assistance Grants (TAGs) and reduction of hours needed for a TAG. The number of TAGs has dropped because EPA provides more contract support through the Technical Assistance Support for Communities (TASC) program as it is less administratively burdensome to communities.  There is also decrease in total respondent cost because the number of state-lead actives that were estimated per year decreased.

6(g)	Burden Statement
Superfund Site Evaluation and Hazard Ranking System
      Depending on the number and type of activities performed, average burden per Response is estimated as 194.34 hours.  Burden ranges from 93 to 2,054 hours per site.  The number of hours required to assess a particular site depends on how far a site progresses through the site assessment process.  Sites where only a pre-CERCLA screening is performed will on average  require approximately 93 hours (average for conducting pre-CERCLA screening and no other work), while sites that progress to NPL listing may require approximately 2,054 hours (cumulative average for conducting pre-CERCLA screening, PA, SI, ESI and HRS package work).  This burden estimate includes reporting activities and minimal recordkeeping activities.

 Cooperative Agreements and Superfund State Contracts for Superfund Response Actions
	The annual public reporting and recordkeeping burden for this collection of information is estimated to average 13 hours per response.

 	National Oil and Hazardous Substances Pollution Contingency Plan (NCP)
      The total estimated annual burden hours placed on state governments for all remedial activities is 82,442.  The total estimated annual burden hours placed on communities is 8,580.  Total burden hours placed on 12,283 respondents through 12,728 responses is 91,022 hours.  The annual public reporting and recordkeeping burden for this collection of information is estimated to average 7.15 hours per response.

      The ICR covers an array of activities that may occur at various discrete points in time or periodically throughout the entire Superfund remedial process.  Therefore, the number of likely respondents per Superfund site in both the state and community categories will vary by site depending on its position in the remedial process, the lead agency, and the level of community involvement warranted.  Additionally, the frequency of response to all activities covered by the ICR can only be described as occurring when required to meet CERCLA requirements and the needs of the Superfund site and the community.

      Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency.  This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information.  An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number.  The OMB control numbers for EPA's regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.
      To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number EPA-HQ-SFUND-2004-0008, which is available for online viewing at www.regulations.gov, or in person viewing at the Superfund Docket in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C.  The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays.  The telephone number for the Reading Room is<PHONE_NUMBER>, and the telephone number for the Superfund Docket is<PHONE_NUMBER>.  An electronic version of the public docket is available at www.regulations.gov.  This site can be used to submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronically.  When in the system, select "search," then key in the Docket ID Number identified above.  Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA.  Please include the EPA Docket ID Number EPA-HQ-SFUND-2004-0008 and OMB Control Number 2050-0179 in any correspondence.

 7.	REFERENCES

United States Environmental Protection Agency. Office of Superfund Remediation and Technology Innovation. Guidance for Performing Preliminary Assessments Under CERCLA. OLEM 9345.0-01A.
EPA/540/G-91/013.  September 1991.
(https://semspub.epa.gov/work/11/157081.pdf)

United States Environmental Protection Agency.  Office of Superfund Remediation and Technology Innovation.  Guidance for Performing Site Inspections Under CERCLA,  Interim Final. OLEM 9345.1-05. EPA 540-R-92-021.  September 1992.
(https://semspub.epa.gov/work/HQ/174029.pdf)

United States Environmental Protection Agency.  Office of Solid Waste and Emergency Response.  Hazard Ranking System Guidance Manual.  Interim Final. Publication 9345.1-07. PB92-963377.  EPA 540-R-92-026.  November 1992.
(https://semspub.epa.gov/work/HQ/189159.pdf)

United States Environmental Protection Agency.  Office of Land and Emergency Management.  USEPA, Superfund Program Implementation Manual Fiscal Year 2019, OLEM 9200.3-154, December 14, 2018.
(https://semspub.epa.gov/work/HQ/100001805.pdf)

42 US Code, Chapter 103, Comprehensive Environmental Response, Compensation, and Liability.  January 1999. (http://uscode.house.gov/view.xhtml?path=/prelim@title42/chapter103&edition=prelim)

United States Environmental Protection Agency.  Office of Land and Emergency Management.  Pre-CERCLA Screening Guidance.  OLEM Directive 9200.3-107, December 2016. (https://semspub.epa.gov/work/HQ/196807.pdf)

United States Environmental Protection Agency.  Office of Solid Waste and Emergency Response.  Improving Site Assessment: Abbreviated Preliminary Assessments.  9375.2-09FS, October 1999. (http://semspub.epa.gov/work/11/174004.pdf)

United States Environmental Protection Agency.  Office of Solid Waste and Emergency Response.  Improving Site Assessment: Integrating Removal and Remedial Site Evaluations.  9330.0-39FS, April 2000. (http://semspub.epa.gov/work/11/174013.pdf)