INFORMATION
COLLECTION
REQUEST:
NATIONAL
POLLUTANT
DISCHARGE
ELIMINATION
SYSTEM
MODIFICATION
AND
VARIANCE
REQUESTS
EPA
ICR
Number:
0029.08
OMB
Control
Number:
2040­
0068
March
2003
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
March
2003
Page
i
TABLE
OF
CONTENTS
Section
Page
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
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1
1(
a)
Title
of
the
Information
Collection
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1
1(
b)
Short
Characterization/
Abstract
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1
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
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4
2(
a)
Need/
Authority
of
the
Collection
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4
2(
b)
Practical
Utility/
Users
of
the
Data
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6
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
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8
3(
a)
Nonduplication
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8
3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
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8
3(
c)
Consultations
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8
3(
d)
Effects
of
Less
Frequent
Collection
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8
3(
e)
General
Guidelines
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8
3(
f)
Confidentiality
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9
3(
g)
Sensitive
Questions
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9
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
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10
4(
a)
Respondents/
SIC
Codes
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10
4(
b)
Information
Requested
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11
5.
THE
INFORMATION
COLLECTED
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AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
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14
5(
a)
Agency
Activities
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14
5(
b)
Collection
Methodology
and
Management
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15
5(
c)
Small
Entity
Flexibility
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15
5(
d)
Collection
Schedule
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15
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
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16
6(
a)
Estimating
Respondent
Burden
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16
6(
b)
Estimating
Respondent
Costs
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19
6(
c)
Estimating
Labor
Costs
(
2002
Dollars)
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19
6(
d)
Estimating
Agency
Burden
and
Cost
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19
6(
e)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
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21
6(
f)
Bottom
Line
Burden
Hours
and
Cost
Tables
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21
6(
g)
Reasons
for
Change
in
Burden
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21
6(
h)
Burden
Statement
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21
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
March
2003
Page
ii
LIST
OF
EXHIBITS
Section
Page
Exhibit
1.1
Summary
of
Burden
and
Costs,
Information
Collection
Request
for
Permittees
and
Government
for
NPDES
Modification
and
Variance
Requests
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3
Exhibit
2.1
Authority
for
Information
Collection
Items
Regarding
Requests
for
NPDES
Modifications
and
Variances
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5
Exhibit
4.1
Number
of
Permittees
in
the
NPDES
and
Sludge1
Programs
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11
Exhibit
6.1
Global
Information
and
Assumptions
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23
Exhibit
6.2
Annual
Number
of
Respondents
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24
Exhibit
6.3
Annual
Respondent
Burden
and
Costs
(
not
including
State
or
Federal
Burden)
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26
Exhibit
6.4
Annual
Respondent
Burden
and
Costs
(
including
State
Burden)
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28
Exhibit
6.5
Annual
Government
Burden
and
Costs
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29
Exhibit
6.6
Bottom
Line
Tallies
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31
Exhibit
6.7
Burden
Comparison:
2000
vs.
2002
ICR
for
NPDES
Modification
and
Variance
Requests
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32
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
March
2003
Page
1
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
of
the
Information
Collection
Title:
National
Pollutant
Discharge
Elimination
System
Modification
and
Variance
Requests
EPA
ICR
Number:
0029.08
OMB
Control
Number:
2040­
0068
1(
b)
Short
Characterization/
Abstract
This
Information
Collection
Request
(
ICR)
revises
the
2000
ICR
for
National
Pollutant
Discharge
Elimination
System
Modification
and
Variance
Requests,
OMB
No.
2040­
0068.
This
ICR
renews
monitoring,
reporting,
and
record
keeping
burden
and
costs
associated
with
modifications
and
variances
made
to
National
Pollutant
Discharge
Elimination
System
(
NPDES)
permits
and
to
National
Sewage
Sludge
management
program
permit
requirements.

In
the
Clean
Water
Act
(
CWA)
of
1972,
Congress
authorized
the
Environmental
Protection
Agency
(
EPA)
to
develop
the
NPDES
program.
The
NPDES
program
regulates
the
discharge
of
pollutants
to
waters
of
the
United
States.
Municipal
and
non­
municipal
facilities
that
wish
to
discharge
domestic
wastewater,
industrial
wastewater,
and
other
pollutants
into
waters
of
the
U.
S.
must
apply
for
permits
under
the
NPDES
program.
Such
permits
contain
limits
on
the
amount
of
pollutants
that
these
facilities
may
discharge
and
also
impose
other
conditions
on
dischargers.
The
Sewage
Sludge
Management
program
regulates
public
and
private
treatment
works
that
treat
domestic
sewage.
These
regulations
are
implemented
through
sludge
conditions
incorporated
into
treatment
works'
NPDES
permits.

Modifications
Once
a
NPDES
permit
is
issued,
a
facility
is
subject
to
the
permit
limits
and
conditions
for
the
life
of
the
permit
(
usually
five
years).
However,
events
may
occur
during
this
period
that
would
render
the
permit
limits
or
conditions
inappropriate.
Some
of
these
events
are
beyond
the
permittee's
control;
others
may
be
directly
related
to
the
permittee's
actions.
For
example,
State
water
quality
standards
may
by
revised
and
so
affect
the
effluent
limitations
established
in
the
permit.
Alternatively,
a
permittee
may
expand
its
operation
procedures
or
change
its
raw
materials,
altering
the
character
of
its
discharge
or
the
quality
of
the
sewage
sludge
it
generates.
Responding
to
such
events
may
require
a
modification
of
the
NPDES
or
sewage
sludge
management
permit
conditions.

The
causes
that
can
lead
to
permit
modifications
are
established
in
40
CFR
122.62
and
122.63.
In
addition,
the
regulations
specify
information
a
facility
must
report
in
order
for
EPA
to
determine
whether
a
permit
modification
is
warranted.
Each
provision
requires
similar
information;
only
the
triggering
requirement(
s)
are
different.

Variances
Prior
to
permit
issuance,
a
NPDES
permit
applicant
may
request
a
variance
from
the
conditions
that
would
normally
be
imposed
on
the
applicant's
discharge.
Although
any
interested
party
may
request
a
variance,
such
requests
are
usually
made
by
the
applicant.
An
applicant
must
submit
information
so
the
permitting
authority
can
assess
whether
the
facility
is
eligible
for
a
variance,
and
what
deviation
from
CWA
provisions
is
necessary.
Permit
limitations
established
in
response
to
a
variance
request
may
be
more
or
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
March
2003
Page
2
less
stringent
than
those
set
by
the
CWA.
The
variances
which
an
applicant
may
seek
are
discussed
in
Section
4.
b
of
this
ICR.

The
permitting
authority
collects
modification
and
variance
requests
submitted
by
NPDES
permittees
and
uses
the
information
from
these
requests
to
determine
whether
the
conditions
or
requirements
that
would
warrant
a
modification
or
variance
exist.
Other
uses
of
modification
and
variance
request
information
are
discussed
further
in
Section
2.
b.
The
information
required
of
NPDES
and
sewage
sludge
facilities
represents
the
minimum
information
necessary
to
achieve
the
Agency's
goals
and
satisfy
regulatory
standards.

Exhibit
1.1
presents
a
summary
of
the
time
and
financial
resources
(
burden)
for
NPDES
facilities
for
submitting
modification
and
variance
requests.
These
resources
will
be
expended
by
NPDES
(
and
sludge)
facilities
for
preparing
modification
and
variance
requests
under
the
terms
and
conditions
of
their
discharge
permits
and
existing
NPDES
regulations.
Exhibit
1.1
also
presents
a
summary
of
the
time
that
States
and
the
Federal
Government
will
spend
in
reviewing,
analyzing,
and
processing
the
data
submitted
by
NPDES
permittees
requesting
modifications
or
variances.

In
summary,
this
ICR
estimates
a
burden
of
57,051
hours
annually
for
NPDES
facilities
at
a
cost
of
$
3,099,138.
Burden
for
the
State
governments
is
246,946
hours
annually
at
a
cost
of
$
7,852,870.
Burden
for
the
Federal
government
is
27,438
hours
annually
at
a
cost
of
$
872,541.
Total
respondent
burden
is
303,997
hours
and
total
cost
is
$
10,952,021.
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
March
2003
Page
3
Exhibit
1.1
Summary
of
Burden
and
Costs,
Information
Collection
Request
for
Permittees
and
State
Government
for
NPDES
Modification
and
Variance
Requests
Information
Item
Permittee
Burden
(
hours)
State
Burden
(
hours)
Permittee
Cost
($)
State
Cost
($)

Request
for
Water
Quality
Related
Effluent
Limitations
Modification
0
0
$
0
0
Permittee
Report
of
Planned
Facility
Changes
5,600
25,200
$
244,895
$
801,360
Permittee
Report
of
Anticipated
Non­
compliance
9,250
16,650
$
477,029
$
529,470
Facility
and
Permit
Transfer
Report
3,333
4,000
$
189,181
$
127,187
Permittee
Report
of
Inaccurate
Previous
Information
2,262
4,072
$
110,278
$
129,477
Excessive
Discharge
Report
4,736
4,262
$
268,815
$
135,544
Permittee
Notice
of
Regulated
Discharge
Cessation
1,495
5,382
$
84,856
$
171,148
Request
for
Modification,
Revocation
and
Reissuance,
or
Termination
24,265
174,708
$
1,377,281
$
5,555,714
Variance
Report
for
Fundamentally
Different
Factors
1280
3,744
$
72,652
$
119,059
Variance
Request
for
Non­
conventional
Pollutants
1,350
4,212
$
76,626
$
133,942
Variance
Request
for
Innovative
Pollution
Control
Technology
120
936
$
6,811
$
29,765
Variance
Request
Regarding
Thermal
Discharges
(
new)
3,200
3,744
$
181,632
$
119,059
Variance
Request
Regarding
Thermal
Discharges
(
renewal)
160
36
$
9,082
$
1,145
Variance
Request
Regarding
Discharge
into
Marine
Waters
0
0
$
0
0
TOTAL
57051
246946
3099138
7852870
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
March
2003
Page
4
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
of
the
Collection
Section
301
of
the
CWA
authorizes
EPA
and
States
with
NPDES
authority
to
establish
and
modify
NPDES
permit
conditions
or
to
vary
the
effluent
limitations
established
in
NPDES
permits.
Section
405
of
the
Act
allows
States
with
sludge
management
authority
to
issue
and
modify
permits
that
regulate
the
use
and
disposal
of
sewage
sludge.
This
information
collection
request
covers
the
data
requirements
necessary
for
a
permitting
authority
to
determine
(
1)
whether
NPDES
or
sewage
sludge
management
permit
conditions
should
be
modified
or
(
2)
whether
a
request
for
a
variance
from
certain
NPDES
permit
conditions
should
be
granted.

Modifications
change
the
limits
and
conditions
of
existing
permits
without
affecting
the
permit's
term.
Information
supporting
modification
requests
is
collected
during
the
effective
term
of
the
permit.
On
the
other
hand,
variances
allow
the
effluent
limitation
requirements
or
time
deadlines
established
by
the
CWA
to
be
modified
or
waived.
During
the
permit
development
process,
the
permitting
authority
collects
information
from
facilities
to
evaluate
variance
requests.
In
each
case,
the
information
collected
is
used
to
update
or
supplement
permit
application
data.

Exhibit
2.1
displays
the
citations
in
the
CWA
and/
or
the
Code
of
Federal
Regulations
(
CFR)
that
correspond
to
conditions
that
may
warrant
a
permit
modification
or
variance.
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
March
2003
Page
5
Exhibit
2.1
Authority
for
Information
Collection
Items
Regarding
Requests
for
NPDES
Modifications
and
Variances
Information
Item
CWA
Citation
CFR
Citation
Request
for
Water
Quality
Related
Effluent
Limitations
Modification
Section
302(
b)
40
CFR
122.21(
m)(
5),
122.21(
n)(
3)

Permittee
Report
of
Planned
Facility
Changes
40
CFR
122.41(
l)(
1),
501.15(
b)(
12)

Permittee
Report
of
Anticipated
Non­
compliance
40
CFR
122.24(
l)(
2)

Facility
and
Permit
Transfer
Report
40
CFR
122.41(
l)(
3)

Permittee
Report
of
Inaccurate
Previous
Information
40
CFR
122.41(
l)(
8)

Excessive
Discharge
Report
40
CFR
122.42
Permittee
Notice
of
Regulated
Discharge
Cessation
40
CFR
122.47(
b)(
4)

Request
for
Modification,
Revocation
and
Reissuance,
or
Termination
40
CFR
122.41(
h),
122.62,
122.64,
122.63,
124.5,
501.15(
b)(
8),
501.15(
c)(
2)

Variance
Report
for
Fundamentally
Different
Factors
Section
301(
n)
40
CFR
122.21(
m)(
1),
125.30
Variance
Request
for
Non­
conventional
Pollutants
Section
301(
c)
and
(
g)
40
CFR
122.21(
m)(
2)

Variance
Request
for
Innovative
Pollution
Control
Technology
Section
301(
k)
40
CFR
122.21(
m)(
4)

Variance
Request
Regarding
Thermal
Discharges
(
new)
Section
316(
a)
40
CFR
122.21(
m)(
6)

Variance
Request
Regarding
Thermal
Discharges
(
renewal)
40
CFR
122.21(
m)(
6)

Variance
Request
Regarding
Discharge
into
Marine
Waters
Section
301(
h)
40
CFR
122.21(
n)(
1)
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
March
2003
Page
6
Congress
intended
the
CWA
"
to
restore
and
maintain
the
chemical,
physical
and
biological
integrity
of
the
nation's
waters."
To
reach
this
goal,
Congress
established
the
NPDES
program
under
Section
402
of
the
Act.
In
addition,
Congress
established
the
Sewage
Sludge
Management
Program
under
Section
405
of
the
Act.

The
modification
and
variance
requests
discussed
in
this
ICR
provide
some
latitude
in
how
permittees
meet
the
CWA
goals
by
taking
into
account
individual
financial
and
technical
capabilities.
For
example,
the
request
for
water
quality
related
effluent
limitation
modifications
and
the
variance
request
for
nonconventional
pollutants
are
attempts
to
balance
the
economic
and
social
costs
of
pollution
abatement
with
its
social
benefits.
However,
progress
toward
meeting
the
CWA
goals
must
be
maintained
even
if
such
modifications
or
variances
are
granted.

Similarly,
technically
advanced
permittees
may
seek
variances
that
enable
them
to
(
1)
develop
innovative
technologies
to
reduce
pollutant
concentrations
beyond
the
current
Best
Available
Technology
Economically
Achievable
(
BAT)
limits
or
(
2)
experiment
with
changes
to
their
physical
plant
that
reduce
the
cost
of
attaining
BAT
limits.
These
variances
promote
the
goals
of
the
CWA
by
helping
facilities
develop
more
cost­
effective
pollution
abatement
techniques
that
other
permittees
may
adopt
in
the
future.

The
modification
and
variance
provisions
of
the
CWA
and
40
CFR
122.21,
122.62,
122.63,
124.5,
and
501.5
also
give
authorized
States
with
NPDES
or
sewage
sludge
management
program
authority
and
EPA
the
flexibility
to
respond
quickly
and
efficiently
to:

°
Advances
in
pollution
control
technology,

°
Legislative
demands
for
more
pollution
control,

°
Changes
in
the
operations
of
permitted
facilities,
and
°
Corrections
of
inaccurate
information
provided
in
applications
or
routine
reports.

For
example,
the
wastewater
permittee
report
of
planned
facility
changes
gives
the
permitting
authority
advance
notice
of
scheduled
plant
alterations,
so
that
permit
conditions
can
be
rewritten
to
take
into
account
the
effect(
s)
of
those
changes.
Modification
provisions
also
enable
the
permitting
authority
to
rewrite
permit
effluent
limitations
to
incorporate
changes
in
State
water
quality
standards.

Most
modification
requests
pertain
to
day­
to­
day
changes
at
a
permitted
facility.
The
permitting
authority
uses
the
information
provided
in
these
requests
to
determine
whether
the
applicant
meets
the
statutory
and
regulatory
requirements
for
a
permit
modification.
Decisions
on
permit
modifications
are
typically
made
at
the
EPA
Region
or
delegated
State
level.

On
the
other
hand,
variance
requests
relate
to
exceptional
or
major
changes
to
permit
requirements.
Therefore,
they
are
scrutinized
closely
by
the
permitting
authority.
Often,
they
are
reviewed
at
EPA
Headquarters,
as
well
as
at
the
EPA
Regions.
Even
if
variances
are
approved
by
the
Regions
or
States,
EPA
Headquarters'
concurrence
is
usually
necessary
before
a
variance
may
be
granted.

2(
b)
Practical
Utility/
Users
of
the
Data
Use
of
the
data
provided
in
each
type
of
modification
or
variance
request
varies
greatly
because
the
information
requirements
of
these
items
are
so
diverse.
In
general,
EPA
and
delegated
States
use
the
information
to
determine
whether:

°
The
conditions
or
requirements
that
would
warrant
a
modification
or
variance
exist,
and
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
March
2003
Page
7
°
The
progress
toward
achieving
the
goals
of
the
CWA
will
continue
if
the
modification
or
variance
is
granted.

Other
uses
for
the
information
provided
in
these
reporting
items
include:

°
Updating
records
on
permitted
facilities,

°
Supporting
enforcement
actions,
and
°
Overall
program
management,
including
policy
and
budget
development
and
responding
to
Congressional
inquiries.
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
March
2003
Page
8
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
EPA
has
examined
all
other
reporting
requirements
contained
in
the
Clean
Water
Act
and
40
CFR
Parts
122,
123,
124,
125,
403,
501,
and
503.
The
Agency
also
has
consulted
the
following
sources
of
information
to
determine
if
similar
or
duplicate
information
is
available
elsewhere:

°
the
EPA
Information
Systems
Inventory;

°
the
EPA
Inventory
of
Information
Collection
Requests;
and
°
the
Federal
Information
Locator
System.

Examination
of
these
databases
revealed
no
duplicate
requirements.
EPA
has
concluded
that
it
has
no
other
way
to
obtain
the
information
addressed
in
this
ICR.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
In
compliance
with
the
1995
Paperwork
Reduction
Act,
EPA
is
soliciting
comments
for
a
30­
day
period
prior
to
submission
of
the
ICR
to
OMB.
Comments
from
the
public
on
the
burden
and
cost
estimates
for
collecting
and
submitting
modification
and
variance
information
will
be
addressed
following
the
comment
period
and
a
copy
of
the
Federal
Register
Notice
soliciting
public
comments
will
be
submitted
to
OMB.

3(
c)
Consultations
EPA
finalized
the
requirements
addressed
in
this
ICR
after
receiving
comments
from
the
public
and
the
regulated
community.
No
formal
consultations
with
persons
outside
EPA
have
occurred
since
the
original
consolidated
modifications/
variances
ICR
was
written
in
1985.
However,
the
Agency
does
consider,
and
act
on,
the
comments
it
receives
in
its
daily
dealings
with
the
public
and
with
the
regulated
community.

3(
d)
Effects
of
Less
Frequent
Collection
The
information
required
is
specific
to
the
modifications
and
variances
which
permittees
request
and
would
not
be
supplied
in
any
other
report
or
application.
The
information
collection
and
reporting
requirements
associated
with
NPDES
permit
modifications
and
variances
are
submitted
as
needed.
In
most
cases,
the
decision
to
submit
information
is
made
by
the
NPDES
permittee
or
permit
applicant.
The
exceptions
are
(
1)
when
outside
events
trigger
the
need
for
a
permit
modification,
and
(
2)
when
the
Administrator
decides
to
invoke
a
reporting
requirement
such
as
a
request
for
permit
revocation
and
reissuance.
Because
information
is
submitted
only
when
needed,
less
frequent
data
collection
would
not
provide
the
permitting
authority
and
EPA
Headquarters
with
sufficient
information
to
meet
their
responsibilities
under
the
CWA.

3(
e)
General
Guidelines
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
March
2003
Page
9
This
information
collection
complies
with
PRA
guidelines
[
5
CFR
1320.5(
d)(
2)].
Requests
for
supplemental
information
for
the
purposes
of
emergency
response
or
enforcement
activities
are
exempt
from
the
PRA
requirements.

3(
f)
Confidentiality
Permit
modification
and
variance
requests
may
contain
confidential
business
information.
If
this
is
the
case,
the
respondent
may
request
that
such
information
be
treated
as
confidential.
All
confidential
data
will
be
handled
in
accordance
with
40
CFR
§
122.7,
40
CFR
Part
2.
Any
claim
of
confidentiality
must
be
asserted
at
the
time
of
submission.
However,
CWA
§
308(
b)
specifically
states
that
effluent
data
may
not
be
treated
as
confidential.

3(
g)
Sensitive
Questions
Reporting
requirements
addressed
in
this
ICR
do
not
include
sensitive
questions.
Sensitive
questions
are
defined
in
EPA's
ICR
Handbook,
"
Guide
to
Writing
Information
Collection
Requests
Under
the
Paperwork
Reduction
Act
of
1995"
as
"
questions
concerning
sexual
behavior
or
attitudes,
religious
beliefs,
or
other
matters
usually
considered
private."
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
March
2003
Page
10
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents/
SIC
Codes
NPDES
permits
are
required
any
time
there
is
a
discharge
of
pollutants
from
a
point
source
to
the
waters
of
the
United
States,
regardless
of
a
discharger's
industrial
category.
Consequently,
industries
of
almost
any
category
may
apply
for
NPDES
permits.
A
relatively
large
portion
of
permitted
facilities,
including
municipal
dischargers,
are
classified
in
the
sanitary
service
[
Standard
Industrial
Code
(
SIC)
495]
industrial
category.
Other
industrial
categories
covered
by
NPDES
permits
include,
but
are
not
limited
to,
the
electric
services
(
SIC
491),
bituminous
coal
(
SIC
121),
industrial
organic
(
SIC
286),
petroleum
refining
(
SIC
291),
and
gold
ores
(
SIC
104).
If
needed,
EPA
may
request
supplemental
information
from
any
permittee.
The
Agency
may
also
request
supplemental
information
from
non­
municipal
facilities
that
discharge
wastewater
to
POTWs.

Permit
conditions
related
to
sewage
sludge
use
or
disposal
practices
are
required
for
any
treatment
works
treating
domestic
sewage.
These
include
publicly
owned
treatment
works
(
POTWs),
privately
owned
treatment
works,
and
any
other
facility
that
treats
or
disposes
of
domestic
sewage,
as
defined
in
40
CFR
Parts
501
and
503.
Many
treatment
works
covered
by
the
sewage
sludge
regulations
are
classified
in
the
sanitary
service
(
SIC
495)
industrial
category.

Forty
five
States
and
one
Territory
have
received
authorization
from
EPA
to
act
as
the
NPDES
permitting
authority
in
those
respective
areas.
Five
States
have
approved
sludge
management
programs.
Because
they
incur
burden
in
administering
the
program,
permitting
authorities
are
considered
respondents
for
the
purposes
of
this
ICR.

Exhibit
4.1
summarizes
the
number
of
permittees
in
the
NPDES
program.
This
information
was
obtained
from
EPA's
Permit
Compliance
System
(
PCS)
database,
the
NOI
Center,
the
previous
ICR,
and
consultations
with
EPA
staff
and
contractors.
These
estimates
are
valid
as
of
December
2002.

Exhibit
4.1
Number
of
Permittees
in
the
NPDES
and
Sludge1
Programs
Facility
Type
Number
of
Permittees
Major
Dischargers
Municipal
Non­
municipal
4,107
2,445
Minor
Dischargers
Municipal
Non­
municipal
10,662
35,385
General
Permittees
116,295
Sludge
Facilities
Municipal1
Non­
municipal1
Permittee
Reports
of
Inaccurate
Previous
Information2
153
10
30
1
The
number
of
sludge
facilities
does
not
represent
the
entire
universe
of
sludge
facilities.
The
numbers
of
municipal
and
non­
municipal
facilities
represent
the
number
of
facilities
required
under
their
sewage
sludge
permit
conditions
to
submit
Permittee
Reports
of
Planned
Facility
Changes
and
Anticipated
Non­
compliance.
2
This
number
represents
the
number
of
sludge
facilities
required
to
submit
Permittee
Reports
of
Inaccurate
Previous
Information
under
sewage
sludge
use
or
disposal
conditions.
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
March
2003
Page
11
4(
b)
Information
Requested
The
estimated
number
of
respondents
and
associated
burden
estimates
for
each
of
the
modification
and
variances
options
available
are
discussed
below.
The
number
of
respondents
and
burden
estimates
are
based
on
discussions
with
EPA
staff
and
information
from
EPA
databases.

Request
for
Water
Quality
Related
Effluent
Limitations
Modification
(
40
CFR
122.21(
m)(
5),
122.21(
n)(
3))

Under
CWA
Section
302(
b),
POTWs
with
NPDES
permits
may
seek
modification
of
the
effluent
limitations
required
by
CWA
Section
302(
a)
for
pollutants
other
than
toxic
pollutants.
To
do
that,
a
POTW
must
show
that
there
is
no
reasonable
relationship
between
the
economic
and
social
costs
of
the
limitation
and
the
benefits
obtained
from
achieving
it.
POTWs
may
also
seek
this
type
of
modification
by
showing
that
the
modified
effluent
limitations
for
toxic
pollutants
represent
further
progress
toward
achieving
the
goals
of
the
CWA
Section
302(
a).
However,
EPA
notes
that
it
has
never
received
a
request
for
this
type
of
modification,
and
does
not
anticipate
receiving
such
a
request.
Consequently,
it
is
noted
here
only
to
ensure
completeness.

Permittee
Report
of
Planned
Facility
Changes
(
40
CFR
122.41(
l)(
1))

Any
planned
alteration
or
addition
to
a
permitted
facility
must
be
reported
to
the
permitting
authority
when:

°
The
change
may
meet
one
of
the
criteria
at
40
CFR
122.29(
b)
for
determining
whether
a
facility
is
a
new
source;

°
The
alteration
or
addition
to
the
facility
may
significantly
change
the
nature
or
quantity
of
discharged
pollutants
that
are
not
subject
to
effluent
limitations
in
the
existing
permit;
or
°
The
alteration
significantly
changes
the
sewage
sludge
use
or
disposal
practices.

A
Permittee
Report
of
Planned
Facility
Changes
applies
to
a
change
in
the
discharge
of
pollutants
that
are
not
already
subject
to
the
facility's
permit
requirements.
When
reporting
planned
facility
changes,
a
permittee
must
provide
a
description
of
the
planned
alterations
or
additions
and
a
statement
outlining
the
anticipated
effects
of
the
changes
on
the
facility's
discharge.
The
permitting
authority
may
use
the
information
submitted
by
the
discharger
to
modify
the
NPDES
permit
before
the
planned
facility
changes
are
made.

Permittee
Report
of
Anticipated
Non­
Compliance
(
40
CFR
122.24(
l)(
2))

The
Permittee
Report
of
Anticipated
Non­
Compliance
applies
to
a
change
in
the
discharge
of
pollutants
that
may
result
in
non­
compliance
with
existing
permit
limits.
Changes
in
production
or
process
are
examples
of
activities
that
permittees
must
report.
Permittees
typically
make
this
sort
of
report
by
a
letter
that
explains
the
reasons
for
the
anticipated
non­
compliance.
The
advance
notice
provided
by
this
reporting
requirement
enables
the
permitting
authority
to
modify
a
permit
or
help
a
permittee
mitigate
the
effects
of
anticipated
noncompliance
on
the
receiving
waters,
or
on
the
site
or
facility
on
which
the
sewage
sludge
is
used
or
disposed.

Facility
and
Permit
Transfer
Report
(
40
CFR
122.41(
l)(
3))

When
a
facility's
ownership
changes,
it
must
notify
the
permitting
authority
in
a
letter
stating
the
date
of
the
transfer
and
the
name
of
the
new
permit
holder.
If
the
new
owner
agrees
to
abide
by
the
conditions
of
the
old
permit,
the
notice
of
transfer
must
include
a
written
and
signed
agreement
containing
a
specific
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
March
2003
Page
12
date
for
transferring
responsibility,
coverage,
and
liability
between
the
new
and
former
owners.
The
permitting
authority
uses
this
information
to
update
permit
records,
evaluate
the
new
discharge
situation,
and
determine
whether
public
notification
and
opportunity
for
comment
are
necessary.

Permittee
Report
of
Inaccurate
Previous
Information
(
40
CFR
122.41(
l)(
8))

Permittees
must
correct
inaccurate
information
that
has
been
submitted
in
a
permit
application
or
permit
report
as
soon
as
the
permittee
learns
of
the
error(
s).
Usually,
permittees
notify
the
permitting
authority
by
letter.
The
permitting
authority
uses
this
information
to
set
or
modify
permit
conditions
or
to
execute
appropriate
enforcement
actions.
The
information
is
also
used
to
update
permit
records.

Excessive
Discharge
Report
(
40
CFR
122.42
(
a)(
1)
and
(
2))

The
Excessive
Discharge
Report
requires
that
all
manufacturing,
commercial,
mining,
and
silvicultural
dischargers
must
notify
EPA
when
they
know
or
have
reason
to
believe:
(
1)
that
any
activity
has
occurred
or
will
occur
that
would
result
in
discharge
on
a
routine
or
frequent
basis,
of
any
toxic
pollutant
which
is
not
limited
in
the
permit,
if
the
discharge
exceeds
certain
defined
notification
levels
for
pollutants;
or
(
2)
that
any
activity
has
occurred
or
will
occur
that
would
result
in
any
discharge
on
a
non­
routine
or
infrequent
basis
of
a
toxic
pollutant
which
is
not
limited
in
the
permit
,
if
that
discharge
will
exceed
notification
levels.
This
report
provides
up­
to­
date,
plant­
specific
information
to
the
permitting
authority,
which
uses
it
to
decide
whether
permit
modification
or
revocation
and
reissuance
are
necessary.
Since
NPDES
permits
are
usually
in
effect
for
5
years,
reports
of
new
toxic
discharges
enable
the
permitting
authority
to
decide
whether
permit
modification
or
revocation
and
reissuance
is
necessary
in
the
interim.

Permittee
Notice
of
Regulated
Discharge
Cessation
(
40
CFR
122.47(
b)(
4))

A
permittee's
decision
to
cease
its
regulated
discharge
must
be
reported
in
writing
to
the
permitting
authority.
The
notification
must
be
accompanied
by
evidence
of
a
firm
public
commitment,
such
as
a
resolution
passed
by
a
corporation's
Board
of
Directors.
The
permitting
authority
will
establish
and
enforce
a
compliance
schedule
to
accommodate
the
discharge
termination
based
on
information
received
in
the
notice.

Permit
Modification,
Revocation,
and
Reissuance,
or
Termination
(
40
CFR
124.5,
122.41(
h),
122.62,
122.64)

Permitting
authorities
may
require
permit
modification,
revocation
and
reissuance,
or
termination
for
several
reasons.
For
example,
national
effluent
standards
may
change,
State
water
quality
standards
may
change,
or
a
facility
may
begin
discharging
significant
amounts
of
a
pollutant
that
is
not
limited
by
the
permit.
When
permitting
authorities
consider
making
modifications,
they
request
dischargers
to
submit
information.

Variance
Request
Due
to
Fundamentally
Different
Factors
(
40
CFR
122.21(
m)(
1)
and
125.30)

This
item
gives
dischargers
the
opportunity
to
seek
a
variance
from
otherwise
applicable
effluent
limits
if
they
can
show
that
their
plants
contain
factors
fundamentally
different
from
those
EPA
considered
when
establishing
national
effluent
limits.
Applicants
must
request
this
type
of
variance
in
writing
on
or
before
the
close
of
the
public
comment
period
on
the
draft
permit
for
BPT
standards,
or
within
180
days
of
the
establishment
of
the
effluent
limitation
or
pretreatment
standards
for
BAT,
Best
Conventional
Pollutant
Control
Technology
(
BCT),
New
Source
Performance
Standard
(
NSPS),
Pretreatment
Standards
for
Existing
Sources
(
PSES),
and
Pretreatment
Standards
for
New
Sources
(
PSNS).
This
request
may
take
any
number
of
forms,
but
is
usually
a
letter.
EPA
has
final
approval
authority
for
Fundamentally
Different
Factors
(
FDF)
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
March
2003
Page
13
variances,
although
FDF
variance
requests
denied
at
the
State
level
in
NPDES
States
are
not
forwarded
to
EPA
for
review.

Variance
Request
for
Non­
conventional
Pollutants
(
40
CFR
122.21(
m)(
2))

Dischargers
may
request
variances
from
effluent
limits
for
non­
conventional
pollutants
(
Section
301(
c)
of
the
CWA).
They
must
prove
that
discharging
non­
conventional
pollutants
at
levels
less
stringent
than
BAT
limits
represents
the
maximum
control
that
the
facility
owner
or
operator
can
afford.
A
request
for
such
a
variance
must
include
documents,
such
as
a
financial
statement,
that
show
an
easing
of
requirements
will
represent
the
best
use
of
technology
within
the
economic
capability
of
the
facility
owner
or
operator.

Facility
owners
or
operators
may
apply
for
a
CWA
Section
301(
g)
variance
if
they
can
show
that
discharging
non­
conventional
pollutants
at
limits
less
stringent
than
BAT
limits
will
not
interfere
with
the
attainment
or
maintenance
of
water
quality.
This
request
must
include
such
information
as
the
permit
number,
the
number
of
outfalls,
applicable
effluent(
s),
and
water
quality
data
that
shows
the
modification
will
not
impede
improvements
in,
or
hinder
maintenance
of,
water
quality.

EPA
must
approve
all
Section
301(
c)
and
(
g)
variances.
However,
these
variance
requests
may
be
denied
by
the
States
with
authority
for
the
NPDES
program.

Variance
Request
for
Innovative
Pollution
Control
Technology
(
40
CFR
122.21(
m)(
4))

Non­
municipal
dischargers
apply
for
this
variance,
which
extends
the
compliance
schedule
for
BAT
up
to
2
years.
The
variance
gives
dischargers
an
opportunity
(
1)
to
develop
innovative
technologies
that
will
reduce
pollutant
concentrations
beyond
BAT
levels,
or
(
2)
to
experiment
with
in­
plant
changes
to
reduce
the
costs
associated
with
attaining
BAT
limits.
Requests
for
this
variance
must
be
filed
in
conjunction
with
NPDES
permit
applications.
To
qualify
for
this
type
of
variance,
the
innovative
pollution
control
system
to
be
tested
must
have
the
potential
for
industry­
wide
application.
The
permitting
authority,
after
consultation
with
EPA,
decides
whether
to
grant
this
variance
request.

Variance
Request
Regarding
Thermal
Discharges
(
40
CFR
122.21
(
m)(
6))

Dischargers
seeking
this
variance
must
demonstrate
that
the
existing
limitations
on
the
thermal
component
of
their
discharges
are
more
stringent
than
necessary
to
ensure
the
protection
and
propagation
of
indigenous
fish,
shellfish,
and
wildlife
in
the
receiving
water.
The
application
of
this
variance
includes
a
description
of
the
studies
performed
and
the
results
of
biological,
hydrological,
and
physical
data
gathered
in
support
of
the
request.
The
permitting
authority
uses
this
information
to
evaluate
alternative
limits.

Application
for
Variance
Regarding
Discharge
Into
Marine
Waters
(
40
CFR
122.21(
n)(
1))

POTWs
may
request
a
variance
under
CWA
Section
301(
h)
from
the
requirements
of
CWA
Section
301(
b)
1(
B)
for
discharges
into
marine
waters.
This
variance
is
administered
by
the
Office
of
Marine
and
Estuarine
Protection
and
is
the
subject
of
a
separate
ICR.
Therefore,
no
respondent
burden
or
cost
associated
with
this
requirement
is
reported
in
this
ICR.
This
information
collection
and
reporting
requirement
is
noted
here
only
in
the
interest
of
completeness.
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
March
2003
Page
14
5.
THE
INFORMATION
COLLECTED
­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
When
permitting
authorities
receive
modification
and
variance
requests,
they
must
review
them
for
completeness.
If
a
request
is
incomplete,
the
authorities
must
notify
the
applicant
and
request
the
missing
information.
Completed
requests
must
be
assigned
to
permit
writers,
who
review
the
information
in
more
detail
as
they
develop
permit
conditions.
Permitting
authorities
must
also
enter
permit
data
into
Permit
Compliance
System
(
PCS)
and
Storage
and
Retrieval
of
U.
S.
Waterways
Parametric
Data
(
STORET),
the
Agency's
databases.

EPA
directly
reviews
and
processes
modification
and
variance
requests
in
non­
authorized
States.
In
addition,
the
Agency
assists
authorized
States
with
some
requests.
In
some
cases,
EPA
also
reviews
Stateapproved
variances.
The
Agency
estimates
that
federal
assistance
or
approval
will
be
required
as
follows:

1.
NPDES­
authorized
States
will
request
assistance
from
EPA
on
5
percent
of
reports
submitted
to
them
for
each
item
below:

°
Requests
for
Modification,
Revocation
and
Reissuance,
or
Termination
of
Permits,

°
Wastewater
Permittee
Report
of
Planned
Facility
Changes
°
Wastewater
Permittee
Report
of
Anticipated
Noncompliance
°
Facility
and
Permit
Transfer
Report
°
Wastewater
Permittee
Report
of
Inaccurate
Previous
Information
°
Excessive
Discharge
Report
°
Permittee
Notice
of
Regulated
Discharge
Cessation
2.
NPDES
States
review
and
recommend
denial
or
approval
of
variance
requests
for
FDF
and
Non­
Conventional
Pollutants.
EPA
is
required
to
review
each
of
these
requests.
Where
the
State
is
the
permitting
authority,
the
State
may
perform
a
voluntary
initial
review
and
make
recommendations
to
EPA
regarding
the
issuance
of
a
variance.
If
a
NPDES
State
recommends
approval
of
either
type
of
request,
EPA
will
then
review
it
and
issue
a
final
decision.

3.
EPA
oversees
and
provides
assistance
to
authorized
States
who
receive
variance
requests
for
Innovative
Pollution
Controls
or
Thermal
Discharges.
EPA
estimates
that
the
government
effort
incurred
in
this
capacity
will
be
400
hours
(
50
work
days)
as
compared
to
520
hours
(
65
work
days)
for
the
evaluation
of
a
request
submitted
directly
to
EPA
in
non­
authorized
States.
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
March
2003
Page
15
5(
b)
Collection
Methodology
and
Management
Improved
information
technology
does
not
appear
to
provide
opportunities
to
minimize
respondent
burden
because
there
are
no
standard
formats
for
the
information,
which
respondents
must
submit
as
needed.

5(
c)
Small
Entity
Flexibility
The
NPDES
regulations
do
not
specify
different
modification
and
variance
requirements
for
small
entities.
All
permittees,
regardless
of
the
size
of
their
facilities,
must
submit
modifications
or
variances
if
they
are
required
for
their
industrial
activity
and
facility
operations.

The
burden
incurred
as
a
result
of
variance
requests
is
voluntary.
A
small
business
that
decides
to
request
a
variance
from
effluent
limitations
does
so
based
on
its
assessment
that
the
benefits
of
receiving
such
a
variance
outweigh
the
burdens
associated
with
preparing
the
request.
In
addition,
small
businesses
interested
in
submitting
variance
requests
may
be
less
complex
than
larger
facilities.
Consequently,
the
time
and
effort
required
to
prepare
a
small
facility's
variance
request
may
be
less
than
that
required
to
prepare
a
similar
request
for
a
more
complex
facility.

5(
d)
Collection
Schedule
The
data
items
covered
by
this
ICR
must
be
provided
only
when
a
permittee
decides
to
seek
a
modification
or
variance,
or
when
an
outside
event
beyond
the
permittee's
control
triggers
a
need
for
the
information.
In
any
event,
the
data
items
are
submitted
only
when
needed.
Therefore,
frequency
of
information
collection
is
not
an
issue
for
the
data
items
covered
by
this
ICR.
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
March
2003
Page
16
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
The
burden
on
respondents
for
the
preparation
of
modification
and
variance
requests
is
generally
the
sum
of
the
time
required
to
read
and
understand
the
regulation,
the
time
to
plan
the
report,
and
the
time
to
write
the
report.
Some
types
of
requests
require
additional
information,
such
as
the
compilation
of
data,
documentation,
model
analysis,
legal
briefs,
and
other
requirements.
Each
of
these
requirements
are
described
in
this
section.
All
assumptions
of
the
percentages
of
permittees
responding
to
each
type
of
modification
or
variance
request
and
time
required
to
respond
to
each
request
are
based
on
the
assumptions
of
the
previous
ICR.
Exhibit
6.1
lists
the
global
information
and
assumptions
used
in
this
analysis
including
2002
labor
rates,
numbers
of
facilities,
etc.
Exhibit
6.2
summarizes
the
annual
number
of
permittees
estimated
to
respond
to
each
type
of
modification
or
variance
request.
A
summary
of
the
respondent
burden
(
hours
and
costs),
not
including
State
government
burden,
for
each
type
of
modification
or
variance
request
is
presented
in
Exhibit
6.3.

State
government
burden
is
also
included
under
respondent
burden
for
this
ICR.
Exhibit
6.4
shows
the
burden
for
respondents,
including
State
government,
for
each
type
of
modification
or
variance
request.
The
State
and
Federal
government
burden
for
each
type
of
modification
or
variance
request
is
shown
in
Exhibit
6.5.

The
government
burden
and
cost
was
calculated
by
multiplying
the
estimated
burden
hours
required
for
each
modification
and
variance
response
by
the
estimated
average
federal
and
State
hourly
labor
rate.
The
State
burden
was
assumed
to
be
90
percent
of
the
total
government
burden,
and
the
federal
burden
was
assumed
to
be
10
percent
of
the
total
government
burden,
based
on
the
assumptions
used
in
the
previous
ICR.

Request
for
Water
Quality
Related
Effluent
Limitations
Modification
(
40
CFR
122.21(
m)(
5),
122.21(
n)(
3))

EPA
has
never
received
a
request
for
this
type
of
modification,
and
these
requests
are
not
anticipated
in
the
future.
Therefore,
there
is
no
burden
associated
with
this
type
of
modification.
It
is
noted
only
to
ensure
completeness.

Permittee
Report
of
Planned
Facility
Changes
(
40
CFR
122.41(
l)(
1))

Respondents
will
use
an
estimated
average
of
4
hours
to
complete
their
notification
of
planned
alterations
and
additions.
This
burden
estimate
includes
1
hour
to
read
and
understand
the
regulation,
1
hour
to
plan
the
report,
and
2
hours
to
write
the
report.
Based
on
recent
discussion
with
EPA
Headquarters
and
Regional
staff,
the
annual
number
of
respondents
includes
5
percent
of
all
major
permittees
and
2
percent
of
all
minor
permittees
for
a
total
of
1,247
annual
NPDES
respondents.
An
additional
153
treatment
works
will
be
required
to
respond
to
this
information
collection
item
because
of
their
sewage
sludge
permit
requirements.
Thus,
the
total
number
of
respondents
to
this
information
item
equals
1,400.

Permittee
Report
of
Anticipated
Non­
Compliance
(
40
CFR
122.41(
l)(
2))

Respondents
will
use
an
estimated
average
of
5
hours
of
labor
for
each
report
of
anticipated
noncompliance.
This
burden
is
divided
as
follows:
1
hour
to
read
and
understand
the
regulation,
1
hour
of
planning,
1
hour
of
information
collection,
and
2
hours
for
writing
and
submitting
the
report.
The
annual
number
of
NPDES
respondents
is
estimated
to
include
1
percent
of
all
major
permittees,
1
percent
of
all
minor
permittees
and
1
percent
of
all
general
permittees
for
a
total
of
1,687
annual
NPDES
respondents.
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
March
2003
Page
17
An
additional
153
municipal
treatment
works
and
10
non­
municipal
permit
works
will
be
required
to
respond
to
this
item
because
of
their
sewage
sludge
permit
conditions.
Thus,
the
total
number
of
respondents
equals
1,850.

Facility
and
Permit
Transfer
Report
(
40
CFR
122.41(
l)(
3))

EPA
estimates
that
the
average
respondent
burden
of
this
requirement
is
3
hours
for
each
report.
Necessary
reporting
activities
include
the
writing,
typing,
and
mailing
of
the
cover
letter
and
official
notice.
The
annual
number
of
respondents
includes
approximately
2
percent
of
all
major
non­
municipals
and
3
percent
of
all
minor
non­
municipals
for
a
total
of
1,111
respondents.

Permittee
Report
of
Inaccurate
Previous
Information
(
40
CFR
122.41(
l)(
8))

The
respondent's
burden
associated
with
this
reporting
requirement
includes
the
time
needed
to
verify
the
reporting
error
or
omission,
to
prepare
the
revised
form
that
details
the
reporting
corrections,
and
to
mail
the
information
to
the
permitting
authority.
The
time
required
under
this
regulation
will
vary
depending
on
the
size
of
the
facility
and
the
extent
of
the
error
or
omission.
EPA
estimates
a
typical
report
requires
2
hours
to
prepare.
The
annual
number
of
respondents
is
estimated
to
be
1
percent
of
all
major
municipal
and
non­
municipals,
2
percent
of
all
minor
municipal
and
non­
municipals,
and
0.1
percent
of
all
general
permittees,
for
a
total
of
1,101
respondents
annually.
An
additional
30
facilities
will
be
required
to
submit
this
information
because
of
their
sewage
sludge
use
or
disposal
permit
conditions.
Thus,
the
total
number
of
respondents
to
this
information
item
equals
1,131.

Excessive
Discharge
Report
(
40
CFR
122.42
(
a)(
1)
and
(
2))

The
respondent
burden
associated
with
this
requirement
is
4
hours,
including
1
hour
to
read
and
understand
the
regulation,
1
hour
to
plan
and
gather
information
for
the
report,
and
2
hours
to
write
and
prepare
the
report.
No
quantitative
sampling
and
analysis
is
required
to
complete
the
Excessive
Discharge
Report.
The
annual
number
of
1,184
respondents
is
composed
of
5
percent
of
all
major
non­
municipals
plus
3
percent
of
all
minor
non­
municipals.

Permittee
Notice
of
Regulated
Discharge
Cessation
(
40
CFR
122.47(
b)(
4))

When
notifying
the
permitting
authority
of
a
facility's
decision
to
cease
regulated
discharges,
the
respondent
incurs
1
hour
of
burden
to
prepare,
type
and
mail
a
letter
of
intent.
The
annual
number
of
respondents
includes
2
percent
of
all
major
non­
municipals,
0.8
percent
of
all
minor
non­
municipals,
and
1
percent
of
all
general
permittees,
or
1,495
respondents.

Permit
Modification,
Revocation,
and
Reissuance,
or
Termination
(
40
CFR
124.5,
122.41(
h),
122.62,
122.64)

The
total
annual
number
of
permittees
expected
to
request
a
modification
of
their
effluent
limitations
is
9,287
or
5.5
percent
of
NPDES
permittees.
However,
many
of
these
are
counted
in
other
sections
of
this
ICR.
The
total
annual
number
of
NPDES
permittees
expected
to
request
a
modification
due
to
planned
facility
changes
(
1,400),
excessive
discharge
reports
(
1,184),
and
reports
of
anticipated
noncompliance
(
1,850)
is
4,434.
The
total
number
of
annual
respondents
reporting
under
40
CFR
124.5
(
those
requesting
modifications
for
permit
modification,
revocation,
and
reissuance)
is
estimated
as
4,853
(
9,287
minus
4,434).
The
burden
associated
with
permit
modification,
revocation,
and
reissuance
applies
only
to
the
4,853
facilities.

An
estimated
5
hours
of
respondent
time
is
necessary
to
provide
the
information
requested
by
the
permitting
authority.
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
March
2003
Page
18
Variance
Request
Due
to
Fundamentally
Different
Factors
(
40
CFR
122.21(
m)(
1)
and
125.30)

The
estimate
of
8
annual
respondents
is
based
on
the
number
of
previously
received
requests.
Each
variance
request
requires
a
total
of
160
hours:
20
hours
to
prepare
a
letter
requesting
a
variance,
60
hours
to
develop
a
legal
brief,
and
80
hours
to
prepare
attachments
describing
the
processes,
technologies,
and
equipment
of
the
individual
plant.
There
have
been
cases
where
many
more
FDF
variance
requests
were
submitted
(
e.
g.,
in
response
to
a
recently
promulgated
effluent
guideline),
however,
the
burden
associated
with
such
a
multitude
of
similar
requests
is
much
lower
than
160
hours.
An
association
or
other
organized
group
of
respondents
usually
prepares
a
boiler
plate
for
member
facilities
to
use
in
such
cases.
As
such,
EPA
believes
that
the
total
burden
of
1,280
hours
reflects
these
cases.

The
burden
for
this
type
of
variance
request
is
high
due
to
the
level
of
detail
required
for
this
variance.
Facilities
that
submit
this
request
are
often
very
complex,
and
the
writing
and
review
of
this
variance
requires
a
detailed
examination
of
the
facility's
operations.

Variance
Request
for
Non­
Conventional
Pollutants
(
40
CFR
122.21(
m)(
2))

Permittees
seeking
this
type
of
variance
incur
a
burden
of
150
hours
for
each
variance
request.
For
a
CWA
Section
301(
c)
request,
the
permittee
must
submit
economic
data
that
will
demonstrate
that
the
variance
represents
the
best
use
of
technology
available
to
the
permittee.
A
typical
breakdown
of
the
burden
was
determined
for
both
the
301(
c)
and
(
g)
variance
requests.
The
150­
hour
burden
includes
30
hours
to
prepare
a
letter
stating
the
request
and
providing
the
appropriate
documentation,
40
hours
addressing
a
response
to
each
one
of
the
statutory
factors,
40
hours
analyzing
a
computer
dilution
model,
and
40
hours
analyzing
the
requested
variance's
impact
on
water
quality
criteria.
The
annual
number
of
9
respondents
is
based
on
numbers
of
previously
received
requests.

Variance
Request
for
Innovative
Pollution
Control
Technology
(
40
CFR
122.21(
m)(
4))

Non­
municipal
dischargers
seeking
an
extension
under
CWA
Section
301(
k)
have
an
estimated
burden
of
60
hours.
Of
the
60
hours,
15
hours
are
required
to
write
a
letter
of
request
and
45
hours
are
necessary
to
document
the
permittee's
claim.
The
annual
number
of
respondents
is
based
on
the
number
of
previously
received
301(
k)
requests.
It
is
estimated
that
2
respondents
will
make
this
request
per
year.

Variance
Request
Regarding
Thermal
Discharges
(
40
CFR
122.21
(
m)(
6))

The
respondent's
burden
associated
with
the
316(
a)
request
for
variance
includes
20
hours
planning
the
request,
160
hours
collecting
biological
data,
80
hours
collecting
hydrological
data,
120
hours
collecting
physical
data,
and
20
hours
preparing
the
request
for
submission
to
EPA.
This
burden
estimate
of
400
hours
represents
a
typical
request;
however,
EPA
recognizes
that
the
burden
will
vary
depending
on
the
complexity
of
the
request.
It
is
estimated
that
8
thermal
variance
requests
will
be
received
each
year.
In
addition,
approximately
40
previously­
issued
thermal
discharge
variances
are
renewed
each
year.
The
respondent
burden
for
a
reissued
variance
is
estimated
to
be
4
hours.

Application
for
Variance
Regarding
Discharge
Into
Marine
Waters
(
40
CFR
122.21(
n)(
1))

This
variance
is
administered
by
the
Office
of
Wetlands,
Oceans,
and
Watersheds
and
is
the
subject
of
a
separate
ICR.
Therefore,
no
respondent
burden
or
cost
associated
with
this
requirement
is
reported
in
this
ICR.
This
information
collection
and
reporting
requirement
is
noted
here
only
in
the
interest
of
completeness.
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
March
2003
Page
19
6(
b)
Estimating
Respondent
Costs
The
total
cost
for
each
respondent
activity
consists
of
the
labor
rate
required
for
each
modification
and
variance
multiplied
by
the
average
hours
necessary
to
prepare
the
modification
or
variance.
Labor
rates
are
discussed
in
Section
6.
c.
Respondent
costs
for
each
type
of
modification
and
variance
request
are
presented
in
Exhibit
6.3.

6(
c)
Estimating
Labor
Costs
(
2002
Dollars)

When
estimating
the
labor
costs
to
respondents
and
the
Agency,
the
following
labor
rates
were
used:

°
Based
on
the
US
Department
of
Labor,
Bureau
of
Labor
Statistics
the
average
hourly
rate
for
Federal
employees
is
$
32.39
(
including
overhead).
This
is
equivalent
to
the
salary
of
a
GS­
9,
Step
10
Federal
employee.
Based
on
the
US
Department
of
Labor,
Bureau
of
Labor
Statistics
the
average
hourly
rate
for
State
employees
is
$
31.20
(
including
overhead).
The
average
of
these
rates
is
$
31.80
which
is
used
to
estimate
State
and
federal
government
costs.

°
As
in
the
previous
ICR
the
average
hourly
rate
for
the
private
sector
is
assumed
to
be
14
percent
higher
than
Federal
and
State
salaries,
or
$
56.76
This
rate
is
used
for
non­
municipals,
non­
municipal
sludge
facilities,
and
general
permittees.
This
hourly
rate
includes
fringe,
overhead,
and
profit.

°
The
average
hourly
rate
of
$
24.76
(
including
overhead)
for
a
municipal
public
sector
employee
is
based
on
the
average
hourly
wage
for
occupations
within
State
and
local
governments
as
determined
by
the
U.
S.
Department
of
Labor
This
rate
is
used
for
municipals,
municipal
sludge
facilities,
and,
for
the
Permittee
Report
of
Inaccurate
Previous
Information,
the
facilities
required
to
report
because
of
use
or
disposal
permit
conditions.

6(
d)
Estimating
Agency
Burden
and
Cost
The
government
burden
and
cost
was
calculated
by
multiplying
the
estimated
burden
hours
required
for
each
modification
and
variance
response
by
the
estimated
average
federal
and
State
hourly
labor
rate.
The
State
burden
was
assumed
to
be
90
percent
of
the
total
government
burden,
and
the
federal
burden
was
assumed
to
be
10
percent
of
the
total
government
burden,
based
on
the
assumptions
from
the
previous
ICR.
The
time
required
for
the
handling
and
review
of
each
request
is
also
based
on
the
assumptions
from
the
previous
ICR.
State
burden
is
included
with
Respondent
burden
and
cost
(
see
Exhibit
6.4).
A
summary
of
the
government
cost
and
burden
for
each
type
of
modification
and
variance
request
is
presented
in
Exhibit
6.5.

Request
for
Water
Quality
Related
Effluent
Limitations
Modification
(
40
CFR
122.21(
m)(
5),
122.21(
n)(
3))

EPA
has
never
received,
and
does
not
expect
to
receive
a
request
for
this
type
of
modification.
Therefore,
there
is
no
burden
associated
with
this
type
of
modification.
It
is
noted
only
to
ensure
completeness.

Permittee
Report
of
Planned
Facility
Changes
(
40
CFR
122.41(
l)(
1))

An
estimated
20
hours
is
necessary
for
the
handling
and
reviewing
of
each
Permittee
Report
of
Planned
Facility
Changes.
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
March
2003
Page
20
Permittee
Report
of
Anticipated
Non­
compliance
(
40
CFR
122.41(
l)(
2))

An
estimated
10
hours
is
necessary
for
the
handling
and
reviewing
of
each
Permittee
Report
of
Anticipated
Non­
compliance.

Facility
and
Permit
Transfer
Report
(
40
CFR
122.41(
l)(
3))

An
estimated
4
hours
are
necessary
for
the
handling
and
reviewing
of
each
Facility
and
Permit
Transfer
Report.

Permittee
Report
of
Inaccurate
Previous
Information
(
40
CFR
122.41(
l)(
8))

An
estimated
4
hours
are
necessary
for
the
handling
and
reviewing
of
each
Permittee
Report
of
Inaccurate
Previous
Information.

Excessive
Discharge
Report
(
40
CFR
122.42
(
a)(
1)
and
(
2))

An
estimated
4
hours
is
necessary
for
the
handling
and
reviewing
of
each
Excessive
Discharge
Report.

Permittee
Notice
of
Regulated
Discharge
Cessation
(
40
CFR
122.47(
b)(
4))

An
estimated
4
hours
are
necessary
for
the
handling
and
reviewing
of
each
Permittee
Notice
of
Regulated
Discharge
Cessation.

Permit
Modification,
Revocation,
and
Reissuance,
or
Termination
"
Miscellaneous"
(
40
CFR
124.5,
122.41(
h),
122.62,
122.64)

An
estimated
40
hours
is
necessary
for
the
handling
and
reviewing
of
each
Permit
Modification,
Revocation
and
Reissuance,
or
Termination
"
Miscellaneous".

Variance
Request
Due
to
Fundamentally
Different
Factors
(
40
CFR
122.21(
m)(
1)
and
125.30)

An
estimated
520
hours
is
necessary
for
the
handling
and
reviewing
of
each
Variance
Request
for
Fundamentally
Different
Factors.

Variance
Request
for
Non­
Conventional
Pollutants
(
40
CFR
122.21(
m)(
2))

An
estimated
520
hours
is
necessary
for
the
handling
and
reviewing
of
each
Variance
Request
for
Non­
Conventional
Pollutants.

Variance
Request
for
Innovative
Pollution
Control
Technology
(
40
CFR
122.21(
m)(
4))

EPA
oversees
and
provides
assistance
to
delegated
States
who
receive
Variance
Requests
for
Innovative
Pollution
Controls.
EPA
estimates
that
the
government
effort
incurred
in
this
capacity
will
be
400
hours
(
50
work
days)
as
compared
to
520
hours
(
65
work
days)
for
the
evaluation
of
a
request
submitted
directly
to
EPA
in
non­
delegated
States.

Variance
Request
Regarding
Thermal
Discharges
(
40
CFR
122.21
(
m)(
6))

EPA
oversees
and
provides
assistance
to
delegated
States
who
receive
Variance
Requests
for
Thermal
Discharges.
EPA
estimates
that
the
government
effort
incurred
in
this
capacity
will
be
400
hours
(
50
work
days)
as
compared
to
520
hours
(
65
work
days)
for
the
evaluation
of
a
request
submitted
directly
to
EPA
in
non­
delegated
States.
In
addition,
an
estimated
1
hour
is
necessary
for
the
handling
and
review
of
each
variance
reissue.
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
March
2003
Page
21
Application
for
Variance
Regarding
Discharge
Into
Marine
Waters
(
40
CFR
122.21(
n)(
1))

This
variance
is
administered
by
the
Office
of
Marine
and
Estuarine
Protection
and
is
the
subject
of
a
separate
ICR.
Therefore,
no
respondent
burden
or
cost
associated
with
this
requirement
is
reported
in
this
ICR.
This
information
collection
and
reporting
requirement
is
noted
here
only
in
the
interest
of
completeness.

6(
e)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
respondent
universe
for
NPDES
permittees
was
updated
from
the
current
ICR
by
using
EPA's
Permit
Compliance
System
database,
the
existing
ICR,
EPA's
NOI
Processing
Center,
and
consultations
with
EPA
staff
and
contractors.
Exhibit
6.2
represents
the
universe
of
NPDES
and
sludge
facilities.
Total
respondent
burden
and
costs
for
each
type
of
modification
and
variance
request
are
summarized
in
Exhibit
6.3
and
combined
with
State
burden
and
cost
in
Exhibit
6.4.

6(
f)
Bottom
Line
Burden
Hours
and
Cost
Tables
The
bottom
line
burden
hours
and
cost
tables
for
respondents
are
the
summaries
of
all
the
hours
and
costs
incurred
for
all
activities
are
shown
in
Exhibit
6.6.
The
burden
and
cost
estimates
are
not
expected
to
vary
from
year
to
year
over
the
collection
period
for
this
ICR.
That
is,
the
bottom
line
tallies
presented
in
Exhibit
6.6
are
not
expected
to
change
over
the
course
of
the
next
3
years.

6(
g)
Reasons
for
Change
in
Burden
The
currently
approved
ICR
for
Modification
and
Variance
Requests
was
developed
in
2000
and
contained
line­
by­
line
estimates
of
burden
hours
similar
to
the
estimates
presented
in
this
document.
The
main
reason
for
the
change
in
burden
since
the
previous
ICR
is
the
decrease
in
estimated
number
of
permittees
as
a
result
of
an
effort
to
clean
up
data
records
in
PCS.

The
labor
rates
have
increased
since
the
previous
ICR.
The
2000
ICR
estimated
the
average
federal
and
State
employee
salary
to
be
$
30.26
per
hour,
the
average
private
sector
salary
to
be
$
54.01
per
hour,
and
the
average
municipal
sector
salary
to
be
$
17.84
per
hour.
This
ICR
estimates
the
average
federal
and
State
employee
salary
to
be
$
31.80
per
hour,
the
average
private
sector
salary
to
be
$
56.76
per
hour,
and
the
average
municipal
sector
salary
to
be
$
24.76
per
hour.
Section
6.
c
of
this
ICR
describes
the
method
by
which
average
salaries
were
estimated
for
this
ICR.

The
2000
ICR
estimated
a
total
respondent
burden
of
292,837
hours
and
a
total
cost
of
$
10,217,068.
This
ICR
estimates
a
total
respondent
burden
of
303,997
hours
and
a
total
cost
of
$
10,952,021.
Exhibit
6.7
gives
a
line­
by­
line
comparison
of
burden
between
the
2000
and
2002
ICRs
for
NPDES
Modification
and
Variance
Requests.

6(
h)
Burden
Statement
EPA
estimates
that
a
total
of
13,091
NPDES
permittees
will
submit
Modification
and
Variance
Requests
each
year.
A
breakdown
of
the
number
of
permittees
for
each
type
of
request
is
shown
in
Exhibit
6.2.

Nationally,
NPDES
permittees
will
spend
57,051
hours
collecting
information
for
and
preparing
these
requests.
Each
permittee
submitting
a
request
will
spend
an
average
of
4.36
hours
preparing
a
request
(
57,051
burden
hours
divided
by
13,091
permittees).
However,
there
is
a
wide
range
in
the
actual
time
spent
on
the
preparation
of
modification
and
variance
requests.
The
preparation
of
these
requests
will
cost
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
March
2003
Page
22
permittees
$
3,099,138
per
year.
There
is
no
record
keeping
burden
associated
with
modification
and
variance
requests.

State
government
burden
is
included
in
respondent
burden
for
this
ICR.
Total
State
government
burden
hours
are
estimated
to
be
246,946
and
total
State
government
costs
are
estimated
to
be
$
7,852,870.

The
total
respondent
burden
hours
are
303,997
and
total
respondent
costs
are
$
10,952,021.

The
Federal
government
will
spend
a
total
of
27,438
hours
and
$
872,541
reviewing
these
requests.

Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
prepare,
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
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
No.
OW­
2002­
0064,
which
is
available
for
public
viewing
at
the
Water
Docket
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Water
Docket
is
(
202)
566­
2426.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
(
OW­
2002­
0064)
and
OMB
control
number
(
2040­
0068)
in
any
correspondence.
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
March
2003
Page
23
Exhibit
6.1
Global
Information
and
Assumptions
LABOR
RATES
Information
Sources:

Average
Federal
and
State
employee
salary:
$
31.80
2002
Labor
Rates
according
to
OPM
(
GS
9
Step
10)
1
Average
private
sector
salary:
$
56.76
Based
on
rate
14%
higher
than
State/
Federal,
fringe
rate
50%,
67%
overhead
and
profit
(
based
on
2000
ICR)

Average
municipal
sector
salary:
$
24.76
2002
Labor
Rates
according
to
OPM
(
GS
7
Step
1)
2
FACILITY
NUMBERS
Information
Sources:

Major
Dischargers
Municipal
Non­
municipal
4,107
2,445
EPA's
Permit
Compliance
System
(
PCS)
EPA's
Permit
Compliance
System
(
PCS)

Minor
Dischargers
Municipal
Non­
municipal
10,622
35,385
EPA's
Permit
Compliance
System
(
PCS)
EPA's
Permit
Compliance
System
(
PCS)

General
Permittees
116,295
EPA's
Permit
Compliance
System
(
PCS)

Municipal
Sludge
Facilities
153
2000
ICR
estimate
Nonmunicipal
Sludge
Facilities
10
2000
ICR
estimate
Use
or
Disposal
Conditions
(
PRIPI)
30
2000
ICR
estimate
1.
U.
S.
Department
of
Labor
Statistics.
Employer
Costs
for
Employee
Compensation,
Table
3­
Employer
costs
per
hour
worked
for
employee
compensation
and
coasts
as
a
percent
of
total
compensation:
State
and
local
government,
by
selected
characteristics,
June
2002.
2.
U.
S.
Department
of
Labor
Statistics.
Employer
Costs
for
Employee
Compensation,
Table
4­
Employer
costs
per
hour
worked
for
employee
compensation
and
coasts
as
a
percent
of
total
compensation:
State
and
local
government,
by
selected
characteristics,
June
2002.
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
March
2003
Page
24
Exhibit
6.2
Annual
Number
of
Respondents
Item/
Type
of
Respondent
Existing
Number
of
Permittees
Percentage
of
Permittees
Responding
per
Year
Total
Number
of
Respondents
Request
for
Water
Quality
Related
Effluent
Limitations
Modification
n/
a
n/
a
0
Permittee
Report
of
Planned
Facility
Changes
Major
Municipals
4107
5.0%
205
Minor
Municipals
10622
2.0%
212
Major
Nonmunicipals
2445
5.0%
122
Minor
Nonmunicipals
35385
2.0%
708
Municipals
Sludge
Facilities
153
100.0%
153
Subtotal
1,400
Permittee
Report
of
Anticipated
Non­
compliance
Major
Municipals
4107
1.0%
41
Minor
Municipals
10622
1.0%
106
Major
Nonmunicipals
2445
1.0%
24
Minor
Nonmunicipals
35385
1.0%
353
Municipals
Sludge
Facilities
153
100.0%
153
Nonmunicipals
Sludge
Facilities
10
100.0%
10
General
Permittees
116295
1.0%
1163
Subtotal
1,850
Facility
and
Permit
Transfer
Report
Major
Nonmunicipals
2445
2.0%
49
Minor
Nonmunicipals
35385
3.0%
1062
Subtotal
1,111
Permittee
Report
of
Inaccurate
Previous
Information
Major
Municipals
4107
1.0%
41
Minor
Municipals
10622
2.0%
212
Major
Nonmunicipals
2445
1.0%
24
Minor
Nonmunicipals
35385
2.0%
708
Required
by
sludge
use
or
disposal
permit
conditions
30
100.00%
30
General
Permittees
116295
0.1%
116
Subtotal
1,131
Excessive
Discharge
Report
Major
Nonmunicipals
2445
5.0%
122
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
March
2003
Item/
Type
of
Respondent
Existing
Number
of
Permittees
Percentage
of
Permittees
Responding
per
Year
Total
Number
of
Respondents
Page
25
Minor
Nonmunicipals
35385
3.0%
1062
Subtotal
1,184
Permittee
Notice
of
Regulated
Discharge
Cessation
Major
Nonmunicipals
2445
2.0%
49
Minor
Nonmunicipals
35385
0.8%
283
General
Permittees
116295
1.0%
1,163
Subtotal
1,495
Request
for
Modification,
Revocation
and
Reissuance,
or
Termination
n/
a
4,853
Variance
Request
for
Fundamentally
Different
Factors
n/
a
8
Variance
Request
for
Non­
conventional
Pollutants
n/
a
9
Variance
Request
for
Innovative
Pollution
Control
Technology
Requests
in
Non­
delegated
States
n/
a
2
Requests
in
Delegated
States
n/
a
0
Variance
Requests
Regarding
Thermal
Discharges
(
New)

Requests
in
Non­
delegated
States
n/
a
8
Requests
in
Delegated
States
n/
a
0
Variance
Requests
Regarding
Thermal
Discharges
(
Renewal)
n/
a
40
Variance
Requests
Regarding
Discharges
into
Marine
Waters
n/
a
0
TOTAL
NUMBER
OF
NON­
STATE
RESPONDENTS
13,091
TOTAL
NUMBER
OF
STATE
RESPONDENTS
46
TOTAL
NUMBER
OF
RESPONDENTS
13,137
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
March
2003
Page
26
Exhibit
6.3
Annual
Respondent
Burden
and
Costs
(
not
including
State
or
Federal
Burden)

Item/
Type
of
Respondent
Number
of
Respondents
per
Year
Burden
Hours
per
Respondent
Total
Hours
Responde
nt
per
hour
Labor
Cost
Total
Respondent
Costs
Request
for
Water
Quality
Related
Effluent
Limitations
Modification
0
n/
a
0
n/
a
$
0
Permittee
Report
of
Planned
Facility
Changes
Major
Municipals
205
4.0
820
24.76
$
20,303
Minor
Municipals
212
4.0
848
24.76
$
20,996
Major
Nonmunicipals
122
4.0
488
56.76
$
27,699
Minor
Nonmunicipals
708
4.0
2832
56.76
$
160,744
Municipal
Sludge
Facilities
153
4.0
612
24.76
$
15,153
Subtotal
1,400
5,600
$
244,895
Permittee
Report
of
Anticipated
Noncompliance
Major
Municipals
41
5.0
205
24.76
$
5,076
Minor
Municipals
106
5.0
530
24.76
$
13,123
Major
Nonmunicipals
24
5.0
120
56.76
$
6,811
Minor
Nonmunicipals
353
5.0
1765
56.76
$
100,181
Municipal
Sludge
Facilities
153
5.0
765
24.76
$
18,941
Nonmunicipal
Sludge
Facilities
10
5.0
50
56.76
$
2,838
General
Permittees
1163
5.0
5815
56.76
$
330,059
Subtotal
1,850
9,250
$
477,029
Facility
and
Permit
Transfer
Report
Major
Nonmunicipals
49
3.0
147
56.76
$
8,344
Minor
Nonmunicipals
1062
3.0
3186
56.76
$
180,837
Subtotal
1,111
3,333
$
189,181
Permittee
Report
of
Inaccurate
Previous
Information
Major
Municipals
41
2.0
82
24.76
$
2,030
Minor
Municipals
212
2.0
424
24.76
$
10,498
Major
Nonmunicipals
24
2.0
48
56.76
$
2,724
Minor
Nonmunicipals
708
2.0
1416
56.76
$
80,372
Required
by
sludge
use
or
disposal
permit
conditions
30
2.0
60
24.76
$
1,486
General
Permittee
116
2.0
232
56.76
$
13,168
Subtotal
1,131
2.0
2,262
$
110,278
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
March
2003
Item/
Type
of
Respondent
Number
of
Respondents
per
Year
Burden
Hours
per
Respondent
Total
Hours
Responde
nt
per
hour
Labor
Cost
Total
Respondent
Costs
Page
27
Excessive
Discharge
Report
Major
Nonmunicipals
122
4.0
488
56.76
$
27,699
Minor
Nonmunicipals
1062
4.0
4248
56.76
$
241,116
Subtotal
1,184
4,736
$
268,815
Permittee
Notice
of
Regulated
Discharge
Cessation
Major
Nonmunicipals
49
1.0
49
56.76
$
2,281
Minor
Nonmunicipals
283
1.0
283
56.76
$
16,063
General
Permittees
1163
1.0
1163
56.76
$
66,012
Subtotal
1,495
1,495
$
84,856
Request
for
Modification,
Revocation
and
Reissuance,
or
Termination
4,853
5.0
24,265
56.76
$
1,377,281
Variance
Request
for
Fundamentally
Different
Factors
8
160.0
1280
56.76
$
72,652
Variance
Requests
for
Non­
Conventional
Pollutants
9
150
1350
56.76
$
76,626
Variance
Request
for
Innovative
Pollution
Control
Technology
Requests
in
Non­
delegated
States
2
60.0
120
56.76
$
6,811
Requests
in
Delegated
States
0
60.0
0
56.76
$
0
Variance
Request
Regarding
Thermal
Discharges
(
new)

Requests
in
Non­
delegated
States
8
400.0
3,200
56.76
$
181,632
Requests
in
Delegated
States
0
400.0
0
56.76
$
0
Variance
Request
Regarding
Thermal
Discharges
(
renewal)
40
4.0
160
56.76
$
9,082
Variance
Request
Regarding
Discharge
into
Marine
Waters
0
n/
a
0
n/
a
$
0
TOTAL
57,051
$
3,099,138
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
March
2003
Page
28
Exhibit
6.4
Annual
Respondent
Burden
and
Costs
(
including
State
Burden)

Item/
Type
of
Respondent
Respondent
Burden
State
Gov't
Burden
Respondent
Costs
State
Gov't
Costs
Total
Burden
Hours
Total
Costs
Request
for
Water
Quality
Related
Effluent
Limitations
Modifications
0
0
$
0
$
0
0
$
0
Permittee
Report
of
Planned
Facility
Changes
5,600
25,200
$
244,895
$
801,360
30,800
$
1,046,255
Permittee
Report
of
Anticipated
Non­
compliance
9,250
16,650
$
477,029
$
529,470
25,900
$
1,006,499
Facility
and
Permit
Transfer
Report
3,333
4,000
$
189,181
$
127,200
7,333
$
316,381
Permittee
Report
of
Inaccurate
Previous
2,262
4,072
$
110,278
$
129,490
6,334
$
239,768
Excessive
Discharge
Report
4,736
4,262
$
268,815
$
135,532
8,998
$
404,347
Permittee
Notice
of
Regulated
Discharge
Cessation
1,495
5,382
$
84,856
$
171,148
6,877
$
256,004
Request
for
Modification,
Revocation
and
Reissuance,
or
Termination
24,265
174,708
$
1,377,281
$
5,555,714
198,973
$
6,932,995
Variance
Request
for
Fundamentally
Different
Factors
1280
3,744
$
72,652
$
119,059
5,024
$
191,711
Variance
Request
for
Nonconventional
Pollutants
1350
4,212
$
76,626
$
133,942
5,562
$
210,568
Variance
Request
for
Innovative
Pollution
Control
Technology
120
936
$
6,811
$
29,765
1,056
$
36,576
Variance
Request
Regarding
Thermal
Discharges
(
new)
3,200
3,744
$
181,632
$
119,059
6,944
$
300,691
Variance
Request
Regarding
Thermal
Discharges
(
renewal)
160
36
$
9,082
$
1,145
196
$
10,227
Variance
Request
Regarding
Discharge
into
Marine
Waters
0
0
$
0
$
0
0
$
0
TOTAL
BURDEN
AND
COSTS
57,051
246,946
$
3,099,138
$
7,852,870
303,997
$
10,952,021
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
March
2003
Page
29
Exhibit
6.5
Annual
Government
Burden
and
Costs
Item/
Type
of
Respondent
(
A)
Number
of
Respondents
per
Year
(
B)
Burden
Hours
per
Response
C
=
(
A
*
B)
Gov't
Burden
D
=
(
C
*
90%)
State
Burden
E
=
(
C
*
10%)
Federal
Burden
F
Gov't
per
hour
Labor
Cost
G
=
(
D
*
F)
State
Cost
H
=
(
E
*
F)
Federal
Cost
I
=
(
G
+
H)
Total
Costs
Request
for
Water
Quality
Related
Effluent
Limitations
Modification
0
n/
a
0
0
0
$
31.80
$
0
$
0
$
0
Permittee
Report
of
Planned
Facility
Changes
Major
Municipals
205
20.0
4,100
3,280
820
$
31.80
$
104,304
$
26,076
$
130,380
Minor
Municipals
212
20.0
4,240
3,392
848
$
31.80
$
107,866
$
26,966
$
134,832
Major
Nonmunicipals
122
20.0
2,440
1,952
488
$
31.80
$
62,074
$
15,518
$
77,592
Minor
Nonmunicipals
708
20.0
14,160
11,328
2,832
$
31.80
$
360,230
$
90,058
$
450,228
Municipal
Sludge
Facilities
153
20.0
3,060
2,448
612
$
77,846
$
19,462
$
97,308
Subtotal
1,400
28,000
22,400
5,600
$
712,320
$
178,080
$
890,400
Permittee
Report
of
Anticipated
Non­
compliance
Major
Municipals
41
10.0
410
328
82
$
31.80
$
10,430
$
2,608
$
13,038
Minor
Municipals
106
10.0
1,060
848
212
$
31.80
$
26,996
$
6,742
$
33,708
Major
Nonmunicipals
24
10.0
240
192
48
$
31.80
$
6,106
$
1,526
$
7,632
Minor
Nonmunicipals
353
10.0
3,530
2,824
706
$
31.80
$
89,803
$
22,451
$
112,254
Municipal
Sludge
Facilities
153
10.0
1,530
1,224
306
$
31.80
$
38,923
$
9,731
$
48,654
Nonmunicipal
Sludge
Facilities
10
10.0
100
80
20
$
31.80
$
2,544
$
636
$
3,180
General
Permittees
1,163
10.0
11,630
9,304
2,326
$
31.80
$
295,867
$
73,967
$
369,834
Subtotal
1,850
18,500
14,800
3,700
$
470,640
$
117,660
$
588,300
Facility
and
Permit
Transfer
Report
Major
Nonmunicipals
49
4.0
196
157
39
$
31.80
$
4,993
$
1,246
$
6,239
Minor
Nonmunicipals
1,062
4.0
4,248
3,398
850
$
31.80
$
108,069
$
27,017
$
135,086
Subtotal
1,111
4,444
3,555
889
$
113,062
$
28,263
$
141,325
Permittee
Report
of
Inaccurate
Previous
Information
Major
Municipals
41
4.0
164
131
33
$
31.80
$
4,166
$
1,049
$
5,215
Minor
Municipals
212
4.0
848
678
170
$
31.80
$
21,560
$
5,406
$
26,966
Major
Nonmunicipals
24
4.0
96
77
19
$
31.80
$
2,449
$
604
$
3,053
Minor
Nonmunicipals
708
4.0
2,832
2,266
566
$
31.80
$
72,059
$
17,999
$
90,058
Required
by
sludge
use
or
disposal
conditions
30
4.0
120
96
24
$
31.80
$
3,053
$
763
$
3,816
General
Permittees
116
4.0
464
371
93
$
31.80
$
11,798
$
2,957
$
14,755
Subtotal
1,131
4,524
3,619
905
$
115,084
$
28,779
$
143,863
Excessive
Discharge
Report
Major
Nonmunicipals
122
4.0
488
390
98
$
31.80
$
12,402
$
3,116
$
15,518
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
March
2003
Item/
Type
of
Respondent
(
A)
Number
of
Respondents
per
Year
(
B)
Burden
Hours
per
Response
C
=
(
A
*
B)
Gov't
Burden
D
=
(
C
*
90%)
State
Burden
E
=
(
C
*
10%)
Federal
Burden
F
Gov't
per
hour
Labor
Cost
G
=
(
D
*
F)
State
Cost
H
=
(
E
*
F)
Federal
Cost
I
=
(
G
+
H)
Total
Costs
Page
30
Minor
Nonmunicipals
1,062
4.0
4,248
3,398
850
$
31.80
$
108,056
$
27,030
$
135,086
Subtotal
1,184
4,737
3,789
947
$
120,490
$
30,115
$
150,605
Permittee
Notice
of
Regulated
Discharge
Cessation
Major
Nonmunicipals
49
4.0
196
157
39
$
31.80
$
4,993
$
1,240
$
6,233
Minor
Nonmunicipals
283
4.0
1,132
906
226
$
31.80
$
28,811
$
7,187
$
35,998
General
Permittees
1,163
4.0
4,652
3,722
930
$
31.80
$
118,360
$
29,574
$
147,934
Subtotal
1,495
5,980
4,785
1,195
$
152,163
$
38,001
$
190,164
Request
for
Modification,
Revocation
and
Reissuance,
or
Termination
4,853
40.0
194,120
155,296
38,824
$
31.80
$
4,938,413
$
1,234,603
$
6,173,016
Variance
Request
for
Fundamentally
Different
Factors
8
520.0
4,160
3,328
832
$
31.80
$
105,830
$
26,458
$
132,288
Variance
Request
for
Non­
Conventional
Pollutants
9
520
4,680
3,744
936
$
31.80
$
119,059
$
29,764
$
148,824
Variance
Request
for
Innovative
Pollution
Control
Technology
Requests
in
Non­
delegated
States
2
520.0
1,040
832
208
$
31.80
$
26,458
$
6,614
$
33,072
Requests
in
Delegated
States
0
400.0
0
0
0
$
31.80
$
0
$
0
$
0
Variance
Request
Regarding
Thermal
Discharges
(
new)

Requests
in
Nondelegated
States
8
520.0
4,160
3,328
832
$
31.80
$
105,830
$
26,458
$
132,288
Request
in
Delegated
States
0
400.0
0
0
0
$
31.80
$
0
$
0
$
0
Variance
Request
Regarding
Thermal
Discharges
(
renewal)

40
1.0
40
32
8
$
31.80
$
1,018
$
254
$
1,272
Variance
Request
Regarding
Discharge
into
Marine
Waters
0
n/
a
0
0
0
$
31.80
$
0
$
0
$
0
TOTAL
GOVERNMENT
BURDEN
AND
COST
274,385
246,946
27,438
$
7,852,870
$
872,541
$
8,725,411
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
March
2003
Page
31
Exhibit
6.6
Bottom
Line
Tallies
Respondent
Burden
and
Cost
(
not
including
State
Burden
and
Cost)

Total
Annual
Number
of
Respondents:
13,091
Total
Respondent
Burden
Hours:
57,051
Average
Burden
Hours
per
Respondent:
4.36
Total
Respondent
Costs:
$
3,099,138
State
Government
Burden
and
Cost
Total
State
Burden
Hours
246,946
Total
State
Costs
$
7,852,870
Respondent
Burden
and
Cost
(
including
State
Burden
and
Cost)

Total
Burden
Hours
303,997
Total
Costs
$
10,952,021
Federal
Government
Burden
and
Cost
Total
Federal
Government
Burden
Hours
27,438
Total
Federal
Government
Costs
$
872,541
Total
Burden
and
Cost
TOTAL
BURDEN
HOURS
331,435
TOTAL
COSTS
$
11,824,562
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
March
2003
Page
32
Exhibit
6.7
Burden
Comparison:
2000
vs.
2002
ICR
for
NPDES
Modification
and
Variance
Requests
ITEM
2000
BURDEN
(
hours)
2000
COST(
S)
2002
BURDEN
(
hours)
2002
COST(
S)
%
BURDEN
CHANGE
%
COST
CHANGE
Request
for
Water
Quality
Related
Effluent
Limitations
Modification
0
$
0
0
$
0
n/
a
n/
a
Permittee
Report
of
Planned
Facility
Changes
46,536
$
1,497,328
33,600
$
1,135,295
­
27.80%
­
24.18%

Permittee
Report
of
Anticipated
Non­
compliance
30,990
$
1,120,703
27,750
$
1,065,329
­
10.45%
­
4.94%

Facility
and
Permit
Transfer
Report
12,425
$
502,450
7,777
$
330,512
­
37.40%
­
34.22%

Permittee
Report
of
Inaccurate
Previous
Information
9,948
$
352,724
6,787
$
254,141
­
31.78%
­
27.94%

Excessive
Discharge
Report
14,848
$
625,620
9,472
$
419,420
­
36.21%
­
32.96%

Permittee
Notice
of
Regulated
Discharge
Cessation
8,125
$
284,456
7,475
$
275,020
­
8.00%
­
3.31%

Request
for
Modification,
Revocation
and
Reissuance,
or
Termination
207,360
$
6,821,914
218,385
$
7,550,297
5.31%
9.64%

Variance
Request
for
Fundamentally
Different
Factors
10,880
$
390,030
5,440
$
204,940
­
50.00%
­
47.45%

Variance
Request
for
Non­
conventional
Pollutants
6,230
$
231,810
n/
a1
Variance
Request
for
Innovative
Pollution
Control
Technology
1,160
$
37,951
1,160
$
39,883
0.00%
4.84%

Variance
Request
Regarding
Thermal
Discharges
(
new)
7,360
$
298,713
7,360
$
313,920
0.00%
4.84%

Variance
Request
Regarding
Thermal
Discharges
(
renewal)
200
$
9,852
200
$
10,354
0.00%
4.84%

Variance
Request
Regarding
Discharge
into
Marine
Waters
0
$
0
0
$
0
n/
a
n/
a
TOTALS
349,832
$
11,941,741
331,435
$
11,824,562
­
5.26%
­
0.98%
1
This
item
was
not
included
in
this
summary
in
the
2000
ICR
