1445ss08 - Justification for Change

Change Request for Renewal of Information Collection Request for the Continuous Release Reporting Requirement

OMB No. 2050-0086, EPA No. 1445.08

The purpose of this change request is to adjust the currently approved Information Collection Request (ICR), OMB No. 2050-0086, EPA No. 1445.07 to account for use of Continuous Release Reporting Forms.

Although the Agency has had “forms” as part of guidance on how to report continuous releases, the forms were not approved by OMB for use in submitting information. During the course of renewals, some respondents have either requested or suggested that continuous release reporting forms be made available. Recipients of the continuous release reporting reports have also suggested that forms would make processing information easier.

We expect that once the forms are approved and available for “downloading” from EPA’s web site that we will have close to 100 percent use of the forms for reporting continuous releases.

We estimate that there will be an overall estimated savings of 167 hours for industry.

We have also developed forms for use by farms that are required to report releases of hazardous substances to the air from animal waste. We estimate that there will be an overall estimated savings of 5,375 hours for farms. The greater savings for farms is due to the greater number of respondents (farms) that are required to report.

Attached are copies of the continuous release reporting forms (usable for all industries), and continuous release reporting forms for farms (custom-designed for farms because the reporting requirements for farms are less than for other industries.

Also attached is a revised supporting statement that explains in detail the estimated savings expected to be realized by using the forms.