Information
Collection
Request
for
National
Pretreatment
Program
DRAFT
March
21,
2003
Prepared
by:

The
Cadmus
Group,
Inc.
1901
North
Fort
Myer
Drive
Suite
900
Arlington,
Virginia
22209
Prepared
for:

Mr.
Ronald
Coleman,
Project
Officer
Ms.
Lisa
Hammond,
Work
Assignment
Manager
U.
S.
Environmental
Protection
Agency
Office
of
Wastewater
Management
EPA
East,
7th
Floor
1200
Pennsylvania
Avenue,
NW
Washington,
DC
20460
US
EPA
CONTRACT
68­
C­
99­
250
Work
Assignment
3­
08
National
Pretreatment
Program
ICR
March
21,
2003
i
TABLE
OF
CONTENTS
1
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
and
Number
of
the
Information
Collection
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1
1(
b)
Short
Characterization
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1
2
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
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3
2(
b)
Use/
Users
of
the
Data
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7
3
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Non­
duplication
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13
3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
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13
3(
c)
Consultations
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13
3(
d)
Effects
of
Less
Frequent
Collection
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16
3(
e)
General
Guidelines
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16
3(
f)
Confidentiality
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17
3(
g)
Sensitive
Questions
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17
4
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents/
NAICS
Codes
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18
4(
b)
Information
Requested
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22
4(
b)(
i)
Data
Items
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22
4(
b)(
ii)
Respondent
Activities
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27
5
INFORMATION
COLLECTED
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AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
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42
5(
b)
Collection
Methodology
and
Management
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42
5(
c)
Small
Entity
Flexibility
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42
5(
d)
Collection
Schedule
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43
6
ESTIMATING
BURDEN
AND
COST
OF
COLLECTION
6(
a)
Estimating
Respondent
Burden
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44
6(
b)
Estimating
Respondent
Costs
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48
6(
c)
Estimating
Agency
Burden
and
Cost
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49
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
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49
6(
e)
Bottom
Line
Burden
Hours
And
Cost
Tables
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49
6(
f)
Reasons
For
Change
In
Burden
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50
6(
g)
Burden
Statement
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51
i
LIST
OF
EXHIBITS
Exhibit
1:
Authority
Under
the
Pretreatment
Program
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5
Exhibit
2:
Responsibilities
for
Each
Authority
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6
Exhibit
3a:
Uses
of
Data
Collected
for
Program
Development
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9
Exhibit
3b:
Uses
of
Data
Collected
for
Program
Implementation
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10
Exhibit
3c:
Uses
of
Data
Collected
for
Program/
Categorical
Determination
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12
Exhibit
4:
Affected
Industries
and
Industrial
Codes
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18
Exhibit
5:
Reporting
and
Recordkeeping
Requirements
for
the
Pretreatment
Program
.
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22
Exhibit
6:
Summary
of
Total
Annual
Average
Respondent
Burden
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44
Exhibit
7:
Average
Annual
Respondent
Costs
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48
Exhibit
8:
Total
Average
Annual
Respondent
Burden
and
Costs
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50
APPENDICES
APPENDIX
A
2000
Information
Collection
Request
for
the
National
Pretreatment
Program
APPENDIX
B
Federal
Register
Notices
Associated
with
the
Pretreatment
Program
ICR
APPENDIX
C
Assumptions
for
Developing
Burden
and
Cost
Estimates
APPENDIX
D
Burden
and
Cost
Spreadsheets
i
ACRONYMS
AA
Approval
Authority
AMSA
Association
of
Metropolitan
Sewerage
Agencies
ANPR
Advanced
Notice
of
Proposed
Rulemaking
BMR
Baseline
Monitoring
Report
CA
Control
Authority
CFR
Code
of
Federal
Regulations
CWA
Clean
Water
Act
CWT
Centralized
Waste
Treatment
DSS
Domestic
Sewage
Study
ELG
Effluent
Limitation
Guideline
EPA
Environmental
Protection
Agency
FDF
Fundamentally
Different
Factors
FR
Federal
Register
ICR
Information
Collection
Request
IU
Industrial
User
IWS
Industrial
Waste
Survey
MGD
Million
Gallons
per
Day
MP&
M
Metal
Products
and
Machinery
NAICS
North
American
Industry
Classification
System
NPDES
National
Pollutant
Discharge
Elimination
System
NRDC
Natural
Resources
Defense
Council
O&
M
Operations
and
Maintenance
OA
Oversight
Authority
OH
Overhead
OMB
Office
of
Management
and
Budget
OST
EPA's
Office
of
Science
and
Technology
OW
Office
of
Water
OWM
Office
of
Wastewater
Management
P2
Pollution
Prevention
PFPR
Pesticide
Formulating,
Packaging,
and
Repackaging
PIPES
Point
Source
Information
Provision
Exchange
System
PIRT
Pretreatment
Implementation
Review
Task
Force
POTW
Publicly
Owned
Treatment
Works
QNCR
Quarterly
Noncompliance
Report
RCRA
Resource
Conservation
and
Recovery
Act
SCP
Slug
Control
Plan
SIC
Standard
Industrial
Classification
SIU
Significant
Industrial
User
SNC
Significant
Noncompliance
TEC
Transportation
Equipment
Cleaning
WEF
Water
Environment
Federation
National
Pretreatment
Program
ICR
March
21,
2003
1
1
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
and
Number
of
the
Information
Collection
Title:
Information
Collection
Request
for
the
National
Pretreatment
Program
OMB
Control
Number:
2040­
0009
EPA
Tracking
Number:
0002.11
1(
b)
Short
Characterization
This
Information
Collection
Request
(
ICR)
calculates
the
burden
and
costs
associated
with
managing
the
National
Pretreatment
Program
mandated
by
Sections
402(
a)
and
(
b)
and
307(
b)
of
the
Clean
Water
Act
(
CWA
or
the
Act).
This
ICR
is
a
renewal
of
the
Revision
of
the
Information
Collection
Request
for
the
National
Pretreatment
Program
(
OMB
Control
No.
2040­
0009,
ICR
No.
0002.09),
previously
submitted
to
the
Office
of
Management
and
Budget
on
September
27,
2000.

Management
of
the
National
Pretreatment
Program
is
the
responsibility
of
the
Office
of
Wastewater
Management
(
OWM)
in
the
Office
of
Water
(
OW),
Environmental
Protection
Agency
(
EPA).
The
CWA
requires
EPA
to
develop
national
pretreatment
standards
to
control
discharges
from
Industrial
Users
(
IUs)
into
sewage
systems
or
publicly
owned
treatment
works
(
POTWs).
These
standards
restrict
the
levels
of
certain
pollutants
in
IU
discharges.
EPA
administers
the
pretreatment
program
through
the
National
Pollutant
Discharge
Elimination
System
(
NPDES)
permit
program.
Under
the
NPDES
Permit
Program,
EPA
can
delegate
authority
for
monitoring
and
enforcement
of
the
pretreatment
standards
to
approved
States
or
individual
POTWs.
OWM
uses
the
data
collected
under
the
pretreatment
program
to
monitor
and
enforce
compliance
with
the
regulations,
as
well
as
to
authorize
program
administration
at
the
State
or
local
(
POTW)
level.
The
data
collected
from
IUs
include
the
mass,
frequency,
and
content
of
their
discharges,
their
schedules
for
installing
pretreatment
equipment,
and
actual
or
anticipated
discharges
of
wastes
that
violate
pretreatment
standards,
have
the
potential
to
cause
problems
at
the
POTW,
or
are
considered
hazardous
under
the
Resource
Conservation
and
Recovery
Act
(
RCRA).
States
and
POTWs
applying
for
approval
of
a
pretreatment
program
submit
data
concerning
their
legal,
procedural,
and
administrative
bases
for
establishing
such
a
program.
For
example,
data
from
POTWs
applying
for
approval
of
their
pretreatment
programs
are
surveys
of
IUs,
local
limits
for
pollutant
concentration,
and
proposed
schedules
for
completing
major
project
requirements.
IUs
and
POTWs
submit
written
reports,
and
either
States
with
approved
pretreatment
programs
or
EPA
Regions
enter
data
into
the
NPDES
database.

This
Information
Collection
Request
(
ICR)
was
prepared
in
accordance
with
the
February
1999
version
of
EPA's
Guide
to
Writing
Information
Collection
Requests
Under
the
Paperwork
Reduction
Act
(
PRA)
of
1995
(
or
"
ICR
Handbook")
prepared
by
EPA's
Office
of
Environmental
Information,
Office
of
Information
Collection,
Collection
Strategies
Division.
The
ICR
Handbook
provides
the
most
current
instructions
for
ICR
preparation
to
ensure
National
Pretreatment
Program
ICR
March
21,
2003
2
compliance
with
the
1995
PRA
amendments
and
Office
of
Management
and
Budget's
(
OMB's)
implementing
guidelines.

This
ICR
updates
the
burden
and
cost
estimates
provided
in
the
ICR
for
the
National
Pretreatment
Program,
dated
September
27,
2000,
which
expires
on
September
30,
2003
(
see
Appendix
A).
Section
6(
f)
summarizes
the
change
in
burden
between
the
previous
ICR
and
this
ICR.
Section
2(
a)
details
the
recordkeeping
and
reporting
requirements
associated
with
the
National
Pretreatment
Program.
This
ICR
estimates
program
burden
and
costs
for
October
1,
2003
through
September
30,
2006.

The
total
annual
respondent
burden
associated
with
this
ICR
is
estimated
to
be
approximately
2.47
million
hours
per
year.
The
total
annual
respondent
costs
associated
with
this
ICR
are
estimated
to
be
approximately
$
99.0
million.
The
estimated
annual
costs
and
burden
are
distributed
as
follows:
0.12
million
hours
and
$
3.8
million
for
States,
1.20
million
hours
and
$
29.7
million
for
POTWs,
and
1.16
million
hours
and
$
65.6
million
for
industrial
users
(
IUs).

The
Agency
burden
for
this
ICR
totals
11,262
hours
annually
or
approximately
$
0.36
million.

The
total
number
of
respondents
for
this
ICR
is
32,675;
34
of
these
respondents
are
States,
1,469
are
POTWs,
and
31,172
are
IUs.
The
total
annual
number
of
responses
for
these
respondents
is
248,539.
National
Pretreatment
Program
ICR
March
21,
2003
3
2
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
For
The
Collection
Section
402(
b)
of
CWA
requires
EPA
to
develop
national
pretreatment
standards
to
control
industrial
discharges
into
sewage
systems.
The
purpose
of
these
standards
is
to
prevent
contaminant
pass
through
or
interference
with
treatment
plant
operations
that
may
result
in
either
damage
to
the
environment
or
a
threat
to
public
health.
As
detailed
below,
several
serious
problems
can
occur
when
industrial
wastes
are
discharged
into
sewage
systems.

°
Pass
through
of
toxic
pollutants
into
receiving
waters.
Industrial
pollutants
that
pass
through
treatment
systems
into
receiving
waters
can
cause
fish
kills,
destroy
aquatic
habitat,
increase
the
risk
of
cancer
in
humans,
and
render
receiving
waters
unsuitable
for
drinking
or
recreation.

°
Interference
with
treatment
plant
operations.
Municipal
wastewater
treatment
systems
are
designed
to
handle
typical
household
wastes
and
biodegradable
commercial
and
industrial
wastes.
Toxic
industrial
compounds
that
do
not
pass
directly
through
the
system
may
interfere
with
plant
operations.

°
Contamination
of
sewage
sludge.
Toxic
compounds
remaining
in
sewage
sludge
may
render
it
unsuitable
for
certain
disposal
methods,
such
as
land
application,
placement
on
a
surface
disposal
site,
or
incineration.

°
Corrosion
of
pipes
and
equipment.
Industrial
discharges
with
extremely
high
or
low
pH
values
can
cause
corrosion
in
the
sewage
collection
system
or
the
treatment
plant,
resulting
in
the
need
for
premature
repair
or
replacement
of
pipes
and
equipment.

°
Explosion
of
highly
volatile
wastes.
Industrial
wastes
can
explode
during
treatment
operations
as
a
result
of
inadvertent
mixing
of
highly
volatile
compounds,
causing
widespread
damage
to
treatment
facilities
and
posing
a
serious
risk
to
plant
operators.

°
Interaction
of
wastes
to
produce
toxic
gases.
Industrial
discharges
such
as
highly
acidic
wastes
can
interact
with
other
wastes
in
the
collection
system,
resulting
in
the
release
of
toxic
gases.

EPA
has
developed
national
pretreatment
program
standards
for
circumstances
common
to
all
sewage
systems,
as
well
as
those
served
by
specific
industries.
National
standards
apply
regardless
of
whether
the
source
is
subject
to
other
Federal,
State,
or
local
pretreatment
standards.
The
regulations
establish
general
and
specific
discharge
standards
(
40
CFR
403.5(
a)
and
(
b))
that
apply
to
all
IUs.
The
general
prohibitions
forbid
the
addition
of
untreated
or
National
Pretreatment
Program
ICR
March
21,
2003
4
inadequately
treated
wastes
and
forbid
the
discharge
of
pollutants
that
may
interfere
with
or
pass
through
the
treatment
works,
thereby
causing
upset
of
treatment
capability.
The
specific
prohibitions
forbid
the
discharge
of
pollutants
that:

°
Create
a
fire
or
explosion
hazard.
°
Are
highly
corrosive.
°
Obstruct
the
treatment
processes
or
system
flows.
°
Cause
interference
or
pass
through.
°
Increase
the
temperature
of
wastewater
entering
the
plant
to
above
104
°
F.
°
Cause
worker
health
or
safety
problems.
°
Are
trucked
or
hauled
to
the
POTW
(
except
as
allowed
by
the
POTW).

In
addition
to
the
national
pretreatment
standards,
standards
have
been
developed
for
specific
industrial
categories
and
are
called
categorical
pretreatment
standards.
These
categorical
standards
specify
quantities
or
concentrations
of
certain
pollutants
or
pollutant
properties
that
IUs
in
certain
industrial
categories
may
discharge
to
a
POTW,
or
the
categorical
standards
specify
other
steps
that
these
IUs
must
take
to
protect
POTWs.
EPA
develops
these
categorical
standards
to
restrict
the
discharge
of
certain
toxic
pollutants
that
EPA
has
identified
as
posing
the
greatest
threat
to
human
health
or
the
environment.
Facilities
subject
to
categorical
pretreatment
standards
must
also
comply
with
national
pretreatment
standards.

Lastly,
EPA
requires
the
Control
Authority
(
CA),
which
is
usually
the
POTW,
to
develop
and
enforce
limits
according
to
local,
site­
specific
situations
to
ensure
that
IUs
meet
general
and
specific
prohibitions
detailed
in
40
CFR
403.5(
c).
These
local
limits
are
federally
enforceable
pretreatment
standards,
as
defined
in
Section
307(
d)
of
CWA.
If
local
limits
are
more
stringent
than
categorical
standards,
the
more
stringent
limit
applies
and
is
enforceable
as
a
Federal
standard.
The
monitoring,
recordkeeping,
and
reporting
requirements
for
these
three
types
of
pretreatment
standards
are
summarized
in
Exhibit
5
and
are
explained
in
more
detail
in
Section
4.

EPA,
together
with
the
various
Approval
and
Control
Authorities,
implements
these
standards
through
the
National
Pretreatment
Program.
The
information
collected
under
this
program
is
needed
to:

°
Authorize
State
and
local
programs.
°
Monitor
and
enforce
compliance
with
the
national
standards.
°
Determine
applicability
of
the
categorical
standards.
°
Develop
and
enforce
local
limits.
°
Administer
the
awards
program.

The
information
collection
requirements
discussed
in
this
ICR
are
authorized
by
Section
402(
b)
of
the
CWA.
This
section
provides
for
State
administration
of
the
NPDES
Program,
which
controls
point
source
discharges
of
pollutants
to
waters
of
the
United
States.
According
to
the
Act,
States
must
also
develop
a
program
to
ensure
POTW
compliance
with
the
requirements
of
the
General
Pretreatment
Regulations.
Under
the
same
authority,
certain
POTWs
must
identify
all
IUs
that
discharge
pollutants
subject
to
categorical
standards
under
Section
307(
b)
of
the
Act,
and
to
develop
a
pretreatment
program
to
ensure
compliance
with
these
standards.
National
Pretreatment
Program
ICR
March
21,
2003
5
The
administration
of
the
National
Pretreatment
Program
involves
three
levels
of
authority,
as
described
below.

°
Oversight
Authority
(
OA).
EPA
Regional
Offices
oversee
State
pretreatment
programs.
They
can
also
assume
the
responsibilities
of
the
Approval
Authority
(
AA)
or
CA
if
States
or
POTWs
do
not
have
authorized
pretreatment
programs.

°
Approval
Authority.
A
State
with
an
approved
NPDES
program
must
obtain
Approval
Authority
for
its
pretreatment
program.
The
Approval
Authority
grants
pretreatment
program
approval
to
POTWs,
oversees
POTW
program
implementation,
and
assumes
the
responsibility
of
the
Control
Authority
for
those
POTWs
that
do
not
have
a
pretreatment
program.

°
Control
Authority.
The
Control
Authority
is
responsible
for
implementing
the
pretreatment
program,
including
establishment
of
control
mechanisms
for
compliance
assessment
and
enforcement
of
the
national
standards,
categorical
standards,
and
local
limits.
A
POTW
with
a
pretreatment
program
that
is
approved
by
the
Approval
Authority
becomes
the
Control
Authority.
If
the
POTW
does
not
obtain
such
approval,
either
the
State
or
the
EPA
Region
becomes
the
Control
Authority.

Exhibit
1
indicates
the
possible
combinations
of
authority.
Exhibit
2
outlines
the
responsibilities
of
each
authority.

Exhibit
1
Authority
Under
the
Pretreatment
Program
POTW
with
Approved
Pretreatment
Program
State
with
Approved
Pretreatment
Program
Control
Authority
Approval
Authority
Oversight
Authority
Yes
Yes
POTW
State
EPA
Yes
No
POTW
EPA
EPA
No
Yes
State
State
EPA
No
No
EPA
EPA
EPA
National
Pretreatment
Program
ICR
March
21,
2003
6
Exhibit
2
Responsibilities
for
Each
Authority
Oversight
Authority
(
EPA)
°
Evaluates
pretreatment
program
on
a
national
basis
and
oversees
State
programs
to
ensure
that
they
meet
Federal
requirements.
°
Approves
State
Program
requests.
°
Acts
as
Approval
or
Control
Authority
in
cases
where
States
or
POTWs
do
not
have
pretreatment
programs.

Approval
Authority
(
States
or
EPA
Regions)
°
Reviews
POTW
program
to
determine
adequacy.
°
Assists
POTWs
in
ensuring
compliance
with
pretreatment
requirements.
°
Audits/
inspects
approved
POTWs
to
assess
compliance
(
may
also
inspect
IUs).
°
Takes
appropriate
action
against
POTWs
that
fail
to
implement
or
enforce
pretreatment
standards
at
IUs
not
in
compliance
(
where
POTW
does
not
take
action).
°
Acts
as
Control
Authority
in
cases
where
the
POTW
does
not
have
a
pretreatment
program.

Control
Authority
(
Approved
POTWs,
States,
or
EPA
Regions)
°
Has
primary
responsibility
for
implementing
the
pretreatment
program.
°
Ensures
that
IUs
comply
with
discharge
limitations
and
reporting
requirements.
°
Inspects
or
reviews
self­
monitoring
reports
from
IUs.
°
Enforces
against
non­
complying
IUs.

The
pretreatment
program
procedures
and
requirements
are
established
in
40
CFR
Part
403
as
follows:

403.1
Purpose
and
Applicability
403.2
Objectives
of
General
Pretreatment
Regulations
403.3
Definitions
403.4
State
or
Local
Law
403.5
National
Pretreatment
Standards:
Prohibited
Discharges
403.6
National
Pretreatment
Standards:
Categorical
Standards
403.7
Removal
Credits
403.8
Pretreatment
Program
Requirements:
Development
and
Implementation
by
POTW
403.9
POTW
Pretreatment
Programs
and/
or
Authorization
to
Revise
Pretreatment
Standards:
Submission
for
Approval
403.10
Development
and
Submission
of
NPDES
State
Pretreatment
Programs
403.11
Approval
Procedures
for
POTW
Pretreatment
Programs
and
POTW
Revision
of
Categorical
Pretreatment
Standards
403.12
Reporting
Requirements
for
POTWs
and
Industrial
Users
403.13
Variances
from
Categorical
Pretreatment
Standards
for
Fundamentally
Different
Factors
National
Pretreatment
Program
ICR
March
21,
2003
1
Project
XL
is
covered
by
a
separate
ICR,
the
"
Regulatory
Reinvention
Pilot
Projects
under
Project
XL:
Pretreatment
Program,"
OMB
Control
Number
2010­
0026,
EPA
ICR
Number
1755.05.

7
403.14
Confidentiality
403.15
Net/
Gross
Calculation
403.16
Upset
Provision
403.17
Bypass
403.18
Modification
of
POTW
Pretreatment
Programs
403.19
Provisions
of
Specific
Applicability
to
the
Owatanna
Waste
Water
Treatment
Facility
403.20
Pretreatment
Program
Reinvention
Pilot
Projects
Under
Project
XL1
2(
b)
Practical
Utility/
Users
Of
The
Data
In
general,
the
information
collected
for
the
pretreatment
program
is
used
for
program
development,
program
implementation,
or
program
or
categorical
determination.
Exhibits
3A,
3B,
and
3C
summarize
the
information
collected
for
program
development,
program
implementation,
and
program/
categorical
determination
and
the
uses
of
this
information.
Users
of
the
information
include
Oversight
Authorities,
Approval
Authorities,
Control
Authorities,
POTWs,
IUs,
and
the
public.

Oversight
Authorities
evaluate
State
pretreatment
programs
based
on
information
about
the
programs'
legal
authority,
procedural
requirements,
and
staff
and
funding
appropriateness.
In
addition,
Oversight
Authorities
use
information
about
an
IU
to
determine
whether
a
particular
categorical
standard
or
subcategory
applies
to
the
IU.

Approval
Authorities
use
information
collected
for
the
pretreatment
program
to
identify
and
locate
IUs
that
may
be
subject
to
national
pretreatment
standards.
Approval
Authorities
also
use
information
about
IUs
to
protect
the
POTW
and
its
workers
by
prohibiting
ignitable,
obstructive,
or
reactive
discharges
from
IUs.
These
authorities
also
use
the
data
to
determine
whether
a
POTW's
pretreatment
program
development
is
on
schedule
and
adequate.
In
addition,
the
information
is
needed
as
the
Approval
Authority
oversees
a
POTW's
pretreatment
program,
monitors
POTW's
compliance
with
their
pretreatment
program
requirements,
and
considers
the
advisability
of
proposed
changes
in
this
program.

Control
Authorities
use
data
from
IUs
to
establish
and
verify
the
type
and
amount
of
pollutants
contributed
to
the
POTW,
to
inform
the
POTW
about
these
substances,
and
to
track
compliance
with
installation
schedules
for
pretreatment
equipment.
Control
Authorities
also
monitor
compliance
with
the
pretreatment
standards,
enforce
these
standards,
inform
POTWs
of
changes
in
the
volume
or
nature
of
pollutants,
and
evaluate
the
effects
of
an
anticipated
bypass.
In
addition,
Control
Authorities
use
information
about
IUs
to
determine
whether
they
need
to
reduce
the
risk
of
slug,
spill,
and
batch
discharges.

POTWs
use
information
received
from
Control
and
Approval
Authorities
to
understand
their
obligations
toward
complying
with
the
pretreatment
program,
including
maintenance,
monitoring,
reporting,
and
planning
and
carrying
out
protective
action
following
any
change
in
the
volume
or
contents
of
the
discharge.
Such
changes
may
include
the
discharge
of
hazardous
substances
subject
to
control
under
RCRA.
National
Pretreatment
Program
ICR
March
21,
2003
8
IUs
use
information
received
from
Control
Authorities
to
understand
substances
that
cannot
be
discharged
and
to
understand
their
additional
obligations
under
the
pretreatment
program.

When
informed
(
through
public
notification)
of
instances
of
significant
noncompliance,
the
public
are
also
users
of
information
related
to
this
program.
Such
information
allows
the
public
to
participate
in
program
approval
decisions.
National
Pretreatment
Program
ICR
March
21,
2003
9
Exhibit
3A
Uses
of
Data
Collected
for
Program
Development
Type
of
Data
Collected
From
To
Authority/

Citation
(
40
CFR)
Use
of
the
Data
State
Pretreatment
Program
Approval
Request
State
OA
403.10
To
evaluate
the
adequacy
of
the
State's
pretreatment
program,
in
terms
of
legal
authority,
procedural
requirements,
and
appropriate
staff
and
funding.

POTW
Pretreatment
Compliance
Schedule
Progress
Report
POTW
AA
403.8,
403.9,

403.12(
k)
To
determine
if
the
POTW
is
on
schedule
in
developing
its
program
so
that
the
Approval
Authority
can
either
provide
assistance
or
take
enforcement
action,
if
necessary.

POTW
Pretreatment
Program
Approval
Request
POTW
AA
403.8(
b)

403.9
To
evaluate
the
adequacy
of
the
POTW's
pretreatment
program,
in
terms
of
legal
authority,
justification
of
local
limits,
compliance
monitoring,
administrative
procedures,
and
appropriate
staff
and
funding.

Maintenance
of
Pretreatment
Program
Information*
Administr
ator/
POTW
Stored
on
site
403.11(
f),

403.14
To
provide
public
access
to
information
characterizing
the
Pretreatment
Program
(
e.
g.,
information
about
POTW
program
approval
submissions).

*
This
is
a
recordkeeping
requirement,
not
a
reporting
requirement.
Exhibit
3a:
Uses
of
the
Data
Collected
for
Program
Development
National
Pretreatment
Program
ICR
March
21,
2003
10
Exhibit
3B
Uses
of
Data
Collected
for
Program
Implementation
(
Page
1
of
2)

Type
of
Data
Collected
From
To
Authority/

Citation
(
40
CFR)
Use
of
the
Data
Baseline
Monitoring
Report
IU
CA
403.12(
b)
To
ensure
compliance
with
the
standards
by
each
source,
to
determine
whether
schedules
for
compliance
are
reasonable,
and
to
establish,

verify,
or
expand
records
on
the
type
and
extent
of
industrial
contributions
to
POTWs.

IU
Compliance
Schedule
Progress
Report
IU
CA
403.12(
c)
To
determine
adherence
to
scheduled
deadlines
for
installation
of
pretreatment
technology
to
ensure
compliance
with
the
categorical
standard
before
the
deadline.

IU
Compliance
Attainment
Report
IU
CA
403.12(
d)
To
determine
if
the
IU
is
in
compliance
with
final
applicable
pretreatment
standards,
and
whether
additional
O&
M
or
pretreatment
is
needed
to
attain
the
standard.

IU
Compliance
Reports
(
Resampling
Requirements)
IU
CA
403.12(
g)
To
allow
CA
to
detect
patterns
of
continuing
IU
noncompliance
(
as
opposed
to
single
events).

IU/
Significant
Industrial
User
(
SIU)

Self­
Monitoring
Report
IU
CA
403.12(
e),

403.12(
h)
To
assure
continued
IU
compliance
with
the
standards,
and
to
determine
whether
enforcement
action
is
needed.

Pollution
Prevention
Alternative
IU
CA
455.41
To
ensure
that
IUs
covered
by
the
pesticides
formulating,
packaging,

and
repackaging
effluent
guidelines
have
prepared
a
pollution
prevention
plan
as
an
alterative
to
zero
discharge.

CWT
Multiple
Waste
Subcategories
IU
CA
437.41
To
ensure
that
CWTs
seeking
to
accept
waste
in
multiple
subcategories
comply
with
certification
requirements
similar
to
the
PFPR
P2
requirements.

POTW
Maintenance
of
Monitoring
Records*
POTW
Stored
on
site
403.12(
o),

403.14(
c)
To
allow
AA
to
verify
POTW
compliance
with
the
national
standards.

IU
Maintenance
of
Monitoring
Records*
IU
Stored
on
site
403.12(
o)
To
allow
AA
to
verify
IU
compliance
with
the
national
standards.

Annual
POTW
Reports
POTW
AA
403.12(
i)
To
adequately
oversee
POTW
pretreatment
programs
and
resulting
national
implementation
status.
Also,
to
ensure
compliance
with
pretreatment
standards.

*
This
is
a
recordkeeping
requirement,
not
a
reporting
requirement.
Exhibit
3b:
Uses
of
the
Data
Collected
for
Program
Implementation
National
Pretreatment
Program
ICR
March
21,
2003
11
Exhibit
3B
Uses
of
Data
Collected
for
Program
Implementation
(
Page
2
of
2)

Type
of
Data
Collected
From
To
Authority/

Citation
(
40
CFR)
Use
of
the
Data
POTW
Program
Modifications
POTW
AA
403.18
To
modify
pretreatment
programs
based
on
local
conditions,
and
to
provide
AAs
with
opportunities
to
accept
or
deny
such
requests.

IU
Slug
Load
Notification
IU
CA
403.12(
f)
To
enable
the
POTW
to
plan
and
carry
out
protective
actions
immediately
after
a
change
in
volume
or
character
of
pollutants.

Notification
of
Changed
Discharge
IU
CA
403.12(
j)
To
ensure
that
the
CA
has
the
necessary
information
to
adequately
notify
the
NPDES
permitting
authority
of
substantial
changes
in
discharge.

Bypass
Notification
IU
CA
403.17
To
inform
the
CA
of
the
intentional
diversion
of
wastestreams
from
any
portion
of
an
IU's
treatment
facility.

Notification
of
Changed
Monitoring
Location
IU
CA
403.6(
e)
To
inform
the
CA
of
any
change
in
location
of
an
IU's
monitoring
point(
s)
in
order
to
carry
out
its
compliance
monitoring
and
enforcement
responsibilities.

Issuance
of
Discharge
Permits
or
Other
Control
Mechanisms
for
SIUs
CA
SIU
403.8(
f)
To
give
SIUs
notice
of
all
pretreatment
requirements
and
to
improve
enforcement.

Inspection
and
Sampling
of
IU
and
SIU
Effluent
CA
AA
403.8(
f)
To
monitor
industrial
discharges
into
POTW
treatment
facilities.

Public
Notification
of
Significant
Noncompliance
CA
Public
403.8(
f)
To
inform
the
public
of
instances
of
significant
noncompliance.

Prevention
and
Control
Plan
for
Spills
and
Batch
Discharges
CA
SIU
403.8(
f)
To
notify
SIUs
that
they
need
to
plan
to
minimize
the
risk
of
slug,
spill,

and
batch
discharges.

Evaluation
of
the
Need
to
Revise
Local
Limits
CA
AA
403.5(
c)
To
evaluate
whether
CAs
have
developed
appropriate
local
limits
to
control
toxic
and
hazardous
pollutants.

POTW
Enforcement
Response
Plan
POTW
AA
403.8(
f)
To
help
decide
whether
CAs
have
effective
enforcement
programs.

SIU
Notification
CA
SIU
403.8(
f)
To
notify
certain
IUs
of
their
status
as
SIUs
and
of
the
regulations
concerning
SIUs.
National
Pretreatment
Program
ICR
March
21,
2003
12
Exhibit
3C
Uses
of
Data
Collected
for
Program/
Categorical
Determination
Type
of
Data
Collected
From
To
Authority/

Citation
(
40
CFR)
Use
of
the
Data
Notification
of
RCRA
Discharge
IU
POTW,

EPA,
State
403.12(
p)
To
inform
POTWs
of
RCRA
hazardous
wastes
discharges
and
to
carry
out
protective
action
if
needed.

Excellence
Award
Program
Information
POTW,

AA
AA/
OA
105
To
recognize
CAs
with
outstanding
pretreatment
programs.

Categorical
Determination
Request
IU,
CA
AA/
OA
403.6(
a)
To
determine
the
applicability
of
a
particular
categorical
standard
or
subcategory
to
an
IU.

Alternative
Limits
Modification
IU
CA
403.6(
e)
To
notify
the
CA
of
any
material
or
significant
change
in
the
values
used
to
calculate
an
alternative
limit.

Fundamentally
Different
Factors
Variance
Request
IU,
CA
OA
403.13
To
provide
plant­
specific
data
needed
to
determine
whether
an
IU's
production
process
or
technologies
are
fundamentally
different
from
the
representative
facilities
used
to
determine
the
limits
specified
in
a
categorical
standard.
This
helps
support
evaluation
of
national
standards
using
empirical
data.

Net/
Gross
Adjustment
Request
IU
CA
403.15
To
determine
whether
an
applicable
pretreatment
standard
should
be
revised
so
that
an
IU
is
not
required
to
remove
a
greater
amount
of
pollutants
than
are
already
present
in
its
intake
water.

Removal
Credit
Approval
Request
CA
AA
403.7
To
authorize
a
POTW
to
calculate
a
revised
categorical
standard(
s)

reflecting
pollutant
removal
already
resulting
from
specific
POTW
design
capabilities.

Removal
Credit
Self­
Monitoring
Report
CA
AA
403.7
To
monitor
ongoing
POTW
pollutant
removal
that
is
the
basis
for
revised
categorical
standards
for
that
POTW's
users.

*
This
is
a
recordkeeping,
not
a
reporting,
requirement.
Exhibit
3d:
Uses
of
the
Data
Collected
for
Program/
Categorical
Determination
National
Pretreatment
Program
ICR
March
21,
2003
13
3
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
EPA
has
examined
all
other
reporting
requirements
contained
in
the
CWA
and
40
CFR
403.
In
addition,
the
following
sources
of
information
have
been
examined
or
consulted
to
determine
whether
similar
or
duplicative
information
is
available
elsewhere:

°
Permit
Compliance
System,
°
Management
Information
and
Data
Systems
Division
Inventory
of
Automated
Systems,
°
Environmental
Information
Clearinghouse,
°
Inventory
of
Information
Collection
Requests.

No
similar
or
duplicative
reporting
requirements
were
found.
No
other
mechanism
for
obtaining
information
on
continued
compliance
with
pretreatment
standards
is
available.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
To
comply
with
the
1995
Amendments
to
the
PRA,
EPA
will
solicit
public
comment
on
this
ICR
for
a
60­
day
period
before
it
is
submitted
to
OMB.
Specifically,
EPA
will
publish
a
notice
in
the
Federal
Register
requesting
comment
on
the
estimated
respondent
burden
and
other
aspects
of
this
ICR
(
to
be
included
as
Appendix
B).
EPA
will
review
and
prepare
responses
to
any
public
comment
received
during
the
60­
day
comment
period.
The
comments
and
responses
will
be
included
as
an
Appendix.
An
additional
Federal
Register
notice
will
be
published
prior
to
submission
of
this
ICR
to
OMB.
The
public
comment
period
for
this
additional
notice
is
30
days.

3(
c)
Consultations
On
June
26,
1978,
EPA
promulgated
the
General
Pretreatment
Regulations
(
43
FR
27736).
Between
February
1977
and
June
1978,
four
public
hearings
and
16
public
meetings
were
held
concerning
the
proposed
regulations;
in
addition,
more
than
400
individual
comments
were
received
by
EPA.
As
a
result
of
the
comments
received,
EPA
modified
reporting
requirements
in
the
final
General
Pretreatment
Regulations
to
minimize
the
burden
to
POTWs.

On
October
29,
1979,
EPA
proposed
amendments
to
the
General
Pretreatment
Regulations
(
44
FR
62260).
After
considering
numerous
comments
submitted
on
the
proposed
amendments,
EPA
developed
and
published
the
amended
General
Pretreatment
Regulations
on
January
28,
1981
(
46
FR
9404).
These
amendments
were
originally
scheduled
to
take
effect
on
March
13,
1981.
Their
effective
date
was
temporarily
deferred
until
March
30,
1981,
by
a
Presidential
memorandum
(
46
FR
11972).
On
March
27,
1981,
EPA
indefinitely
postponed
the
amendments'
effective
date.

After
EPA's
indefinite
deferral
of
the
effective
date
of
the
general
pretreatment
amendments
in
1981,
a
suit
was
brought
by
the
Natural
Resources
Defense
Council
(
NRDC)
challenging
EPA's
deferral
of
these
amendments
without
notice
and
comment.
Additionally,
two
groups
that
are
directly
and
substantially
affected
by
the
National
Pretreatment
Program
recommended
that
portions
of
the
amended
regulation
go
into
effect.
After
considering
all
public
comments
received
in
response
to
the
postponement,
EPA
put
most
of
the
amendments
into
effect.
On
July
8,
1982,
a
decision
was
reached
on
NRDC's
suit
(
NRDC
v.
EPA,
No.
National
Pretreatment
Program
ICR
March
21,
2003
2
For
a
detailed
summary
of
PIRT's
recommendations,
see
the
January
30,
1985,
EPA
publication
Pretreatment
Review
Task
Force:
Final
Report
to
the
Administrator.

14
81­
2068).
The
court
held
that
EPA's
suspension
violated
the
Administrative
Procedure
Act,
and
ordered
EPA
to
reinstate
all
pretreatment
amendments
retroactive
to
March
30,
1981.

On
February
3,
1984,
EPA
established
the
Pretreatment
Implementation
Review
Task
Force
(
PIRT),
to
provide
the
Agency
with
recommendations
on
the
day­
to­
day
problems
faced
by
POTWs,
States
and
industry
in
implementing
the
Agency's
pretreatment
program.
PIRT
was
composed
of
17
representatives
of
POTWs,
States,
industry,
environmental
groups
and
EPA
Regions.
Out
of
this
effort
came
a
set
of
recommendations
to
the
Agency
summarized
in
a
final
report
to
the
Administrator2.
The
General
Pretreatment
and
NPDES
regulations
(
40
CFR
Parts
122
and
403)
were
revised
on
October
17,
1988
(
53
FR
40610)
in
response
to
PIRT's
recommendations.

The
1984
Hazardous
and
Solid
Waste
Amendments
to
RCRA
required
EPA
to
prepare
a
report
for
Congress
on
wastes
passing
through
POTWs
which
fall
under
the
domestic
sewage
exclusion
(
Section
1004(
27)
of
RCRA).
EPA
also
had
to
promulgate
new
regulations
or
modifications
to
existing
regulations
to
ensure
that
such
discharges
did
not
present
a
threat
to
human
health
or
the
environment.
Under
the
domestic
sewage
exclusion,
solid
or
dissolved
materials
within
domestic
sewage
are
not
regulated
under
RCRA
as
solid
or
hazardous
waste
and
are
not
required
to
meet
RCRA
standards
for
hazardous
waste
treatment,
storage,
or
disposal.

To
comply
with
the
1984
RCRA
Amendments,
EPA
submitted
the
Domestic
Sewage
Study
(
DSS)
to
Congress
on
February
7,
1986.
The
report
contained
information
on
160,000
waste
dischargers
from
47
industrial
categories
and
the
residential
sector.
The
report
also
provided
information
on
the
effectiveness
of
existing
government
controls
for
wastewater
discharges,
especially
federal
and
local
pretreatment
programs
and
categorical
pretreatment
standards.
The
DSS
concluded
that
the
domestic
sewage
exclusion
should
be
retained,
but
that
CWA
authorities
should
be
more
broadly
and
effectively
applied
to
regulate
hazardous
waste
discharges.
Several
initiatives
were
proposed
in
the
report
for
increased
effectiveness
of
controls.

As
a
result,
EPA
published
an
Advance
Notice
of
Proposed
Rulemaking
(
ANPR)
on
August
22,
1986
(
51
FR
30166)
for
modifications
to
the
General
Pretreatment
and
NPDES
regulations
(
40
CFR
Parts
122
and
403).
To
solicit
comments
on
the
ANPR,
three
public
meetings
were
held
in
the
District
of
Columbia,
Chicago,
and
San
Francisco.
Comments
on
the
ANPR
were
summarized
and
published
in
the
Federal
Register
on
June
22,
1987.
Most
comments
on
the
DSS
and
the
ANPR,
which
primarily
addressed
methods
of
improving
pretreatment
programs
to
more
effectively
control
hazardous
waste
discharges
to
POTWs,
were
incorporated
into
the
proposed
regulatory
changes
published
in
the
Federal
Register
on
November
23,
1988
(
53
FR
47632).
The
final
rule
to
implement
the
proposed
revisions
to
the
Pretreatment
and
NPDES
regulations
and
to
ensure
the
control
of
hazardous
wastes
passing
through
POTWs
was
issued
on
July
24,
1990
(
55
FR
30082).

On
November
25,
1992,
pursuant
to
Section
405
of
the
CWA,
EPA
promulgated
a
regulation
(
40
CFR
Part
503)
to
protect
public
health
and
the
environment
from
reasonably
National
Pretreatment
Program
ICR
March
21,
2003
15
anticipated
adverse
effects
of
certain
pollutants
in
sewage
sludge
(
58
FR
9248,
February
19,
1993).
This
regulation
established
requirements
for
the
following
final
uses
or
disposal
of
sewage
sludge:

°
Land
application
either
to
condition
the
soil
or
to
fertilize
crops
grown
in
the
soil.
°
Final
disposal
on
the
land.
°
Incineration.

Also
on
November
25,
1992,
EPA
amended
the
Part
403
General
Pretreatment
Regulations
to
add
a
new
Appendix
G
that
includes
two
tables
of
pollutants
that
would
be
eligible
for
a
removal
credit
if
the
other
procedural
and
substantive
requirements
of
40
CFR
part
503
and
40
CFR
403.7
are
met.
The
first
table
(
Appendix
G
 
Section
I)
lists,
by
use
or
disposal
practice,
the
pollutants
regulated
in
Part
503
and
eligible
for
removal
credit
authorization.
The
second
table
(
Appendix
G
 
Section
II)
lists,
by
use
or
disposal
practice,
additional
pollutants
that
are
eligible
for
a
removal
credit
if
the
concentration
of
the
pollutant
in
sewage
sludge
does
not
exceed
a
prescribed
concentration.
The
pollutants
in
Appendix
G
 
Section
II
are
the
pollutants
that
EPA
evaluated
and
decided
not
to
regulate
during
development
of
the
Part
503
regulation.
(
58
FR
9381
 
5).

On
March
5,
1993,
the
Leather
Industries
of
America,
Inc.
filed
a
petition
with
the
U.
S.
Circuit
Court
of
Appeals
for
the
District
of
Columbia
Circuit
seeking
review
of
the
pollutant
limits
for
chromium
found
in
Tables
1
 
4
of
40
CFR
503.13(
b).
On
June
17,
1993,
the
City
of
Pueblo,
Colorado,
filed
a
petition
for
review
with
the
U.
S.
Court
of
Appeals
for
the
Tenth
Circuit
challenging
the
selenium
pollutant
limits
in
Tables
1
 
3
of
40
CFR
503.13(
b).
This
case
was
subsequently
transferred
to
the
D.
C.
Circuit.
On
November
15,
1994,
the
D.
C.
Circuit
remanded
the
cumulative
pollutant
loading
rate
for
chromium
in
Table
2
and
the
pollutant
concentration
limit
for
chromium
and
selenium
in
Table
3
to
the
Agency
for
modification
or
additional
justification
(
Leather
Industries
of
America,
Inc.
v.
Environmental
Protection
Agency,
40
F.
3d
392,
D.
C.
Cir.,
1994).

Effective
October
25,
1995,
and
as
a
result
of
EPA's
reconsideration
of
certain
issues
remanded
by
the
U.
S.
Court
of
Appeals
for
additional
justification
or
modification,
the
Agency
amended
40
CFR
503
to
delete
the
land
application
pollutant
limits
for
chromium
and
to
change
the
land
application
pollutant
concentration
limit
for
selenium.
Accordingly,
EPA
also
amended
the
list
of
pollutants
(
in
Appendix
G
of
40
CFR
403)
for
which
a
removal
credit
may
be
available
(
60
FR
54764­
70).

The
President's
Report
on
"
Reinventing
Environmental
Regulations"
(
March
1995)
pledged
to
provide
"
more
common
sense
and
fairness
in
our
regulations."
The
goal
of
this
initiative
was
to
provide
greater
flexibility,
reduce
burdens,
and
achieve
greater
environmental
results
at
less
cost.
To
this
end,
EPA
committed
to
streamlining
the
National
Pretreatment
Program
to
reduce
the
burden
of
technical
and
administrative
requirements
that
affect
industrial
users
and
POTW
and
State
Control
Authorities.
In
1995,
EPA's
Office
of
Wastewater
Management
initiated
an
evaluation
of
all
of
the
General
Pretreatment
Regulations
in
40
CFR
Part
403
in
order
to
identify
streamlining
opportunities.
Ultimately,
the
regulation
"
streamlining"
process
was
conducted
in
two
phases.

The
first
phase
simplified
the
process
for
modifying
the
pretreatment
program
requirements
included
in
POTW
NPDES
permits.
EPA
solicited
preliminary
input
on
a
``
straw
proposal''
from
various
stakeholders,
including
States,
POTWs,
trade
associations
and
environmental
groups,
which
shaped
the
proposal
published
in
the
Federal
Register
on
July
30,
National
Pretreatment
Program
ICR
March
21,
2003
16
1996
(
61
FR
39804­
10).
The
proposal
solicited
additional
information
and
comment
on
several
issues,
and
the
final
regulation
was
adopted
July
17,
1997
(
62
FR
38406­
15).

The
second
phase
of
streamlining
was
inspired
by
issue
papers
in
which
EPA
summarized
11
areas
in
which
the
Pretreatment
Regulations
might
be
streamlined.
In
May
1996,
the
issue
papers
were
distributed
to
a
broad
base
of
external
stakeholders
(
States,
cities,
trade
associations,
professional
organizations,
and
environmental
interest
groups),
and
were
also
publicly
available
on
an
EPA
electronic
bulletin
board
(
Point
Source
Information
Provision
Exchange
System,
or
"
PIPES")
that
was
accessible
through
the
Agency's
Internet
website
at
"
http://
www.
epa.
gov/
owm."
Synopses
of
the
outreach
effort
were
published
in
several
trade
association
newsletters.
Thirty­
five
outside
stakeholders
provided
written
comments
on
the
proposed
issues.
The
Agency
also
considered
the
recommendations
of
the
joint
Water
Environment
Federation
and
Association
of
Metropolitan
Sewage
Agencies
Workshop
(
the
WEF/
AMSA
Workshop).
The
Agency
next
prepared
a
draft
proposal
and
preamble,
which
discussed
13
issues
or
changes
to
the
regulations.
This
draft
was
circulated
to
outside
stakeholders
in
May
1997.
After
reviewing
comments
received
from
70
outside
stakeholders,
the
Agency
proposed
to
revise
the
regulations
on
July
22,
1999
(
64
FR
39563).
These
provisions
address
restrictions
on
and
oversight
of
industrial
users
who
introduce
pollutants
into
POTWs,
make
changes
to
certain
program
requirements
to
be
consistent
with
NPDES
requirements,
and
correct
some
typographical
errors.
The
proposals
would
reduce
the
regulatory
burden
on
both
industrial
users
and
State
and
POTW
Control
Authorities
without
affecting
environmental
protection.
The
comment
period
for
these
proposed
revisions
ended
on
November
19,
1999
(
64
FR
47755).
Since
that
time,
EPA
continues
to
work
closely
with
stakeholders
to
develop
a
final
Streamlining
Rule.

3(
d)
Effects
of
Less
Frequent
Collection
EPA
considers
the
reporting
requirements
associated
with
the
pretreatment
program
(
both
the
one­
time
and
ongoing
monitoring
and
reporting
requirements)
to
be
the
absolute
minimum
necessary
for
effective
administration
of
the
program.
EPA
also
considers
the
reporting
requirements
to
be
the
absolute
minimum
necessary
for
effective
control
of
hazardous
wastes
to
implement
RCRA
section
3018(
b).
Any
alternative
to
the
present
set
of
minimal
requirements
would
entail
an
increase
in
reporting
burden
to
respondents.
The
Agency
has
thus
endeavored
to
minimize
respondent
burden
for
the
program.

In
addition,
EPA
considers
the
specific
requirements
for
SIUs
and
for
reporting
the
discharge
of
RCRA
hazardous
substances
preferable
to
repealing
the
domestic
sewage
exclusion.
Such
an
action
would
help
ensure
that
hazardous
wastes
are
disposed
of
safely
without
necessitating
regulating
POTWs
and
IUs
under
RCRA.

3(
e)
General
Guidelines
This
ICR
was
prepared
in
accordance
with
the
February
1999
version
of
EPA's
Guide
to
Writing
Information
Collection
Requests
Under
the
Paperwork
Reduction
Act
(
PRA)
of
1995
(
or
"
ICR
Handbook")
prepared
by
EPA's
Office
of
Environmental
Information,
Office
of
Information
Collection,
Collection
Strategies
Division.
The
ICR
Handbook
provides
the
most
current
instructions
for
ICR
preparation
to
ensure
compliance
with
the
1995
PRA
amendments
and
OMB's
implementing
guidelines.

Only
one
provision
of
the
pretreatment
program
requirements
exceeds
the
OMB
guidelines
contained
in
5
CFR
1320.5(
d)(
2).
According
to
40
CFR
403.12(
f),
IUs
must
notify
the
POTW
immediately
of
any
slug
loading
by
the
IU.
The
report
is
typically
made
by
National
Pretreatment
Program
ICR
March
21,
2003
17
telephone.
This
is
an
emergency
provision
that
enables
the
POTW
to
take
timely
and
appropriate
protective
action.

3(
f)
Confidentiality
The
following
reporting
requirements
may
contain
confidential
business
information,
proprietary
information,
or
information
containing
compromising
trade
secrets:

°
Pretreatment
Baseline
Monitoring
Report
°
IU
Compliance
Schedule
Report
°
POTW
and
IU
Maintenance
of
Monitoring
Records
(
though
not
a
required
submission,
burden
is
incurred)
°
Pretreatment
Categorical
Determination
Request
°
Pretreatment
Fundamentally
Different
Factors
Variance
Request.

In
such
cases,
the
respondent
has
the
right
to
request
that
the
information
be
treated
as
confidential
business
information.
All
data
so
designated
will
be
handled
pursuant
to
40
CFR
403.14(
a),
which
provides
the
following
guidelines
regarding
such
information:

In
accordance
with
40
CFR
Part
2,
any
information
submitted
to
EPA
pursuant
to
these
regulations
may
be
claimed
as
confidential
by
the
submitter.
Any
such
claim
must
be
asserted
at
the
time
of
submission
in
the
manner
prescribed
on
the
application
form
or
instructions,
or,
in
the
case
of
other
submissions,
by
the
words
"
confidential
business
information"
on
each
page
containing
such
information.
If
no
claim
is
made
at
the
time
of
submission,
EPA
may
make
the
information
available
to
the
public
without
further
notice.
If
a
claim
is
asserted,
the
information
will
be
treated
in
accordance
with
the
procedures
in
40
CFR
Part
2
(
Public
Information).

Industrial
effluent
data,
however,
"
shall
be
made
available
to
the
public
without
restriction"
[
40
CFR
403.14(
b)].

3(
g)
Sensitive
Questions
Reporting
requirements
for
the
pretreatment
program
do
not
contain
questions
of
a
sensitive
nature.
National
Pretreatment
Program
ICR
March
21,
2003
18
4
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents/
NAICS
Codes
Data
associated
with
this
ICR
are
collected
and
maintained
at
the
IU,
POTW,
State,
and
Federal
levels.
Respondents
include
POTWs,
certain
classifications
of
IUs,
and
States
submitting
requests
for
program
approval.

The
Standard
Industrial
Classification
(
SIC)
code
for
sewerage
systems
(
i.
e.,
POTWs)
is
4952.
The
SIC
code
for
State
agencies
is
9511
(
Air
and
Water
Resources
and
Solid
Waste
Management).
The
North
American
Industry
Classification
System
(
NAICS)
code
for
State
agencies
that
include
pretreatment
programs
is
92411
(
Administration
of
Air
and
Water
Resources
and
Solid
Waste
Management
Programs).
POTWSs
are
classified
as
NAICS
code
22132
(
Sewage
Treatment
Facilities).

Ancillary
systems
(
i.
e.,
those
that
supplement
the
function
of
other
establishments
like
factories,
power
plants,
mobile
home
parks,
etc.)
cannot
be
categorized
in
a
single
NAICS
or
SIC
code.
For
ancillary
systems,
the
NAICS
or
SIC
code
is
that
of
the
primary
establishment
or
industry.
IUs
potentially
affected
by
the
pretreatment
regulations
include
the
following
categories
of
industries:

Exhibit
4
Affected
Industries
and
Industrial
Classifications
Affected
Industry
SIC
Code(
s)*
NAICS
Codes**

Adhesive/
sealant
2891
32552
Aluminum
Forming
33
331315,
331316,
331319
Asbestos
Manufacturing
3292
33634,
327999
Battery
Manufacturing
369
335911,
335912
Builder's
Paper
and
Board
Mills
267
322222,
322299
Carbon
Black
Manufacturing
2895
325182
Cement
Manufacturing
327
327331,
327332,
327999
Coal
Mining
12
212111,
212112,
212113
Coil
Coating
367
334416
Copper
Forming
3351
331421
National
Pretreatment
Program
ICR
March
21,
2003
Affected
Industry
SIC
Code(
s)*
NAICS
Codes**

19
Dairy
Products
Processing
202
311511,
311512,
311513,
311514,
31152
Electrical
and
Electronic
Components
36
335311,
335312,
335313,
335314,
335999
Electroplating
3471
332813
Explosives
Manufacturing
2892
32592
Feedlots
0211
112112
Ferroalloy
Manufacturing
106
212234,
212299
Fertilizer
Manufacturing
147
212391,
212392,
212393
Foundries
332,
3365,
3366
331511,
331512,
331513,
331524,
331525
Fruits
and
Vegetables
Processing
Manufacturing
203
311411,
311412,
311421,
311422,
311423,
311999
Glass
Manufacturing
32
327211,
327212,
327213,
327215
Grain
Mills
Manufacturing
204
311211,
311212
Gum
and
Wood
Chemicals
2861
325191
Ink
Formulating
2893
32591
Inorganic
Chemicals
281
325188
Iron
and
Steel
Manufacturing
332
331111,
331511,
331512,
331513
Leather
Tanning
and
Finishing
3111
31611
Meat
Processing
201
311611,
311612,
311613,
311615
National
Pretreatment
Program
ICR
March
21,
2003
Affected
Industry
SIC
Code(
s)*
NAICS
Codes**

20
Metal
Finishing
346,
3449,
347
332111,
332112,
332114,
332115,
332116,
332312,
332321,
339911
Metal
Molding
and
Casting
34
332439,
332212,
332213,
332999,
332913,
332312,
332313,
332311
Non­
Ferrous
Metals
Forming
and
Metal
Powders
33
331419,
331492,
331491,
331522,
331528,
331492
Ore
Mining
and
Dressing
1081
213114
Organic
Chemicals,
Plastics,
and
Synthetic
Fibers
286
325132,
325211,
325192,
32511,
32512,
325193,
325212,
325199
Paint
and
Ink
Formulation
286,
289
32591,
32551
Paving
and
Roofing
(
Tars
and
Asphalt)
295
324121,
324122
Pesticides
Formulating,
Packaging,
and
Repackaging
287
325314
Pesticides
Manufacturing
287
325311,
325312,
32532
Petroleum
Refining
2911
32411
Pharmaceuticals
Manufacturing
2834
325412
Phosphate
Manufacturing
1475
212392
Photographic
Supplies
3861
333315,
325992
Plastics
and
Synthetics
308
326113,
326119,
32613,
326121,
32615,
32616
Porcelain
Enameling
3479
332812
Printing
and
Publishing
2731
51223,
51113,
323117
National
Pretreatment
Program
ICR
March
21,
2003
Affected
Industry
SIC
Code(
s)*
NAICS
Codes**

21
Pulp,
Paper,
and
Paperboard
26
32211,
322121,
322122,
32213
Rubber
Processing
30
315999,
326211,
32622,
339991,
326291,
31332
Seafood
Processing
2091,
2092
311711,
311712
Soaps
and
Detergents
Manufacturing
284
325611,
325312,
325613
Steam
Electric
Power
Generation
4911
22119
Textile
Mills
22
31321,
313311,
313221,
315111,
313249,
313113,
31411,
314999
Timber
Products
and
Processing
24
321912,
321113,
11331,
321918,
321999
Transportation
Equipment
Cleaning
4491,
4741,
7699
81131,
48821,
48831,
48832
*
Note
that
some
industry
sectors
are
categorized
by
only
two­
or
three­
digit
SICs.
**
Note
that
this
table
may
not
include
all
applicable
NAICS
codes
for
certain
industries
with
many
applicable
codes.

Among
the
IUs
that
are
respondents,
some
are
considered
to
be
SIUs
based
on
certain
criteria.
SIUs
are
defined
in
40
CFR
403.3(
t)
as
any
of
the
following
types
of
facilities:

°
All
IUs
subject
to
categorical
pretreatment
standards.

°
All
IUs
not
subject
to
categorical
pretreatment
standards
that:

 
discharge
an
average
of
25,000
gallons
per
day
or
more
of
process
wastewater.

 
contribute
a
process
wastestream
equal
to
or
greater
than
5
percent
of
the
receiving
treatment
plant's
average
dry
weather
hydraulic
or
organic
capacity,
or
 
have
a
reasonable
potential
to
adversely
affect
the
POTW's
operation
or
violate
any
pretreatment
standard
or
requirement
as
determined
by
the
Control
Authority.
National
Pretreatment
Program
ICR
March
21,
2003
22
4(
b)
Information
Requested
4(
b)(
i)
Data
Items
This
section
describes
the
information
required
for
the
pretreatment
program
and
the
frequency
of
the
collections.
Exhibit
5
summarizes
these
reporting
requirements.
In
conjunction
with
describing
respondent
activities,
Section
4(
b)(
ii)
provides
additional
details
about
the
information
requested.

Most
of
the
information
requirements,
particularly
those
associated
with
program
development
and
program/
categorical
determination,
are
one­
time
requirements
that
have
already
been
met
by
most
States,
POTWs,
and
IUs.
Approximately
27.2
percent
of
NPDES
States
have
not
obtained
Approval
Authority.
Approximately
3.1
percent
of
affected
POTWs
are
currently
required
to
develop
pretreatment
programs.
Over
time,
the
latter
estimate
will
fluctuate
as
additional
POTWs
are
identified
as
needing
pretreatment
programs,
and
as
such
programs
are
approved.

Exhibit
5
Reporting
and
Recodkeeping
Requirements
for
the
Pretreatment
Program
Information
Type
Requirement
Regulatory
Citation
(
40
CFR)
From
To
Frequency/
Retention
Program
Development
POTW
Pretreatment
Program
Approval
Request
403.8(
b)
POTW
AA
One
time
POTW
Pretreatment
Compliance
Schedule
Progress
Report
403.8,
403.9,
403.12(
k)
POTW
AA
One
time
State
Pretreatment
Program
Approval
Request
403.10
State
OA
One
time
Maintain
Pretreatment
Program
Information
403.11(
f),
403.14(
c)
AA
Stored
on
site
For
minimum
of
3
years
Program
Implementation
Evaluation
of
the
Need
to
Revise
Local
Limits
403.5(
c)
CA
AA
Once
every
5
years
Notification
of
Changed
Monitoring
Location
403.6(
e)
IU
CA
Once
per
occurrence
Issuance
of
Discharge
Permits
of
Other
Control
Mechanisms
for
SIUs
403.8(
f)
CA
IU
Once
every
5
years
Inspection
and
Sampling
of
IU
Effluent:

403.8(
f)
CA
AA
Random
Sampling
and
Analysis
of
IUs,
Surveillance
Intermittent
Inspection
and
Sampling
of
SIUs
Annually
Evaluation
of
SIUs
Every
2
years
Public
Notification
of
SNC
403.8(
f)
CA
Public
Annually
Prevention
and
Control
Plan
for
Spills
and
Batch
Discharges
403.8(
f)
IU
CA
One
time,
as
required
National
Pretreatment
Program
ICR
March
21,
2003
Information
Type
Requirement
Regulatory
Citation
(
40
CFR)
From
To
Frequency/
Retention
23
POTW
Enforcement
Response
Plan
403.8(
f)
CA
AA
One
time
SIU
Notification
403.8(
f)
CA
IU
As
needed
Baseline
Monitoring
Report
403.12(
b)
IU
CA
One
time
IU
Compliance
Schedule
Progress
Report
403.12(
c)
IU
CA
One
time
IU
Compliance
Attainment
Report
403.12(
d)
IU
CA
One
time
IU
Self­
Monitoring
Report
403.12(
e),
403.12(
h)
IU
CA
Every
6
months
or
as
requested
by
CA
IU
Slug
Load
Notification
403.12(
f)
IU
CA
As
needed
Program
Implementation
(
continued)
IU
Compliance
Report
(
Resampling
Requirements)
403.12(
g)
IU
CA
Once
per
effluent
violation
Annual
POTW
Reports
403.12(
i)
POTW
AA
Annually
Notification
of
Changed
Discharge
403.12(
j)
IU
CA
Once
per
occurrence
Maintain
POTW
and
IU
Monitoring
Records
403.12(
o),
403.14(
c)
POTW,
IU
Stored
on
site
For
minimum
of
3
years
Notification
of
RCRA
Discharge
403.12(
p)
IU
CA,
EPA,
State
One
time
Bypass
Notification
403.17
IU
CA
Once
per
occurrence
POTW
Program
Modifications
403.18
POTW
AA
Once
per
occurrence
CWT
Multiple
Waste
Subcategories
437.41
IU
CA
One
time;
annually*

Pollution
Prevention
Alternative
455.41
IU
CA
One
time;

semiannually

Excellence
Award
Program
Information
105
POTW
OA
Annually
(
voluntary)

Program/
Categorical
Determination
Categorical
Determination
Request
403.6(
a)
IU,
POTW
OA
One
time
(
voluntary)

Alternative
Limits
Request
403.6(
e)
IU
CA
One
time
per
occurrence
Removal
Credit
Approval
Request
403.7
POTW
AA
Intermittent
National
Pretreatment
Program
ICR
March
21,
2003
Information
Type
Requirement
Regulatory
Citation
(
40
CFR)
From
To
Frequency/
Retention
24
Removal
Credit
Self­
Monitoring
Report
403.7
POTW
AA
Annually
or
as
specified
by
AA
Fundamentally
Different
Factors
Variance
Request
403.13
IU,
POTW
OA
One
time
(
voluntary)

Net/
Gross
Request
403.15
IU
OA
Intermittent
*
The
IU
submits
the
P2
Alternative
Certification
once,
then
submits
semi­
annual
certifications
or
requests
for
modifications
to
the
P2
alternative.
**
The
IU
submits
the
initial
certification
statement
once,
then
submits
annual
certification
statements
thereafter.

Program
Development
The
reporting
requirements
for
program
development
apply
to
States
and
POTWs,
and
include
the
State
Pretreatment
Program
Approval
Request,
the
POTW
Compliance
Schedule
Progress
Report,
and
the
POTW
Pretreatment
Program
Approval
Request.

The
regulations
at
40
CFR
403.10
require
States
to
develop
a
State
pretreatment
program
if
they
were
granted
NPDES
authority
before
the
National
Pretreatment
Program
was
established.
All
other
States
are
required
to
apply
for
pretreatment
approval
at
the
time
they
apply
for
NPDES
program
approval.
A
request
for
State
pretreatment
program
approval
must
demonstrate
that
the
State
has
developed
the
legal,
procedural,
and
administrative
bases
for
the
program
and
that
it
has
obtained
the
necessary
funding
and
staff
to
operate
the
program.
Once
a
State
has
met
these
requirements
and
received
program
approval
from
EPA,
the
State
becomes
the
Approval
Authority
for
its
pretreatment
program.
In
cases
where
a
State
has
not
obtained
approval
authority,
the
EPA
Regional
Office
administers
the
State
pretreatment
program.
Currently,
34
States
have
approved
pretreatment
programs.

All
POTWs
with
design
flows
of
more
than
5
million
gallons
per
day
must
develop
pretreatment
programs
that
will
reduce,
eliminate,
or
alter
harmful
industrial
pollutants
prior
to
discharge
to
the
POTW
sewage
system.
This
requirement
also
applies
to
smaller
POTWs
that
receive
discharges
from
SIUs.
POTWs
located
in
States
that
act
as
the
Control
Authority
for
all
POTWs
in
the
State
(
the
403.10(
e)
States)
are
exempt
from
this
requirement.
Currently,
97
percent
(
1,497)
of
the
approximately
1,515
POTWs
required
to
develop
programs
have
done
so.
(
In
cases
where
POTWs
do
not
have
a
pretreatment
program,
approved
pretreatment
States
or
EPA
Regional
Offices
assume
the
responsibility
of
the
Control
Authority.)

To
obtain
an
approved
pretreatment
program,
a
POTW
is
required
by
40
CFR
403.8
to
conduct
an
extensive
survey
of
its
IUs,
establish
the
legal
authority
and
procedures
for
compliance
monitoring
and
enforcement,
develop
local
limits
for
pollutant
concentrations,
and
secure
the
necessary
staff
and
funding
for
the
program.
As
part
of
its
program
development,
the
POTW
must
submit
a
schedule
with
the
expected
date
of
completion
for
each
major
program
requirement.
Before
obtaining
final
approval,
the
POTW
must
certify
that
all
of
the
above
requirements
have
been
met.
National
Pretreatment
Program
ICR
March
21,
2003
25
The
Approval
Authority
must
retain
all
pretreatment
program
submissions
and
removal
credit
request
submissions,
as
well
as
any
comments
related
to
these
submissions.
This
information
must
be
available
to
the
public
upon
request.

Program
Implementation
Once
it
receives
program
approval,
the
POTW
or
the
agency
responsible
for
administering
the
pretreatment
program
is
required
under
Section
402(
b)
of
the
CWA
to
ensure
IU
compliance
with
the
National
Pretreatment
Standards.
This
includes
the
following
POTW
requirements:

°
Annual
POTW
Reports
including
updated
SIU
inventories
and
the
results
of
inspection
and
sampling
of
SIU
effluent.
°
POTW
Program
Modifications.
°
Issuance
of
Discharge
Permits
for
SIUs.
°
Public
Notification
of
Significant
Violation/
Noncompliance.
°
Prevention
and
Control
Plan
for
Spills
and
Batch
Discharges.
°
POTW
Enforcement
Response
Plan.
°
SIU
Notification.
°
Evaluation
of
the
Need
to
Revise
Local
Limits.
°
Excellence
Awards
Program.

Many
of
the
other
reporting
requirements
for
this
phase
of
the
program
apply
to
IUs
and
include
the
following:

°
Baseline
Monitoring
Report.
°
Industrial
User
Compliance
Schedule
Progress
Report.
°
Industrial
User
Compliance
Attainment
Report.
°
Industrial
User
Compliance
Reports
(
Resampling
Requirements).
°
Industrial
User
and
Significant
Industrial
User
Self­
Monitoring
Reports
(
and
associated
recordkeeping
requirements).
°
Pollution
Prevention
Alternative.
°
CWT
Multiple
Waste
Categories.
°
Industrial
User
Slug
Load
Notification
(
includes
40
CFR
403.5(
b)
and
40
CFR
403.8(
f)(
2)(
v)(
C)).
°
Notification
of
Changed
Discharge.
°
Bypass
Notification.
°
Notification
of
Changed
Monitoring
Location.
°
Notification
of
RCRA
Discharge.

Within
180
days
after
the
effective
date
of
a
categorical
standard,
affected
industries
must
submit
a
Baseline
Monitoring
Report
(
BMR),
giving
the
pollutant
concentrations
of
their
wastestreams.
If
the
IU
is
not
in
compliance
with
the
standards,
it
has
up
to
three
years
to
finance,
construct,
and
operate
any
pollution
control
equipment
or
facilities
needed
to
bring
the
IU
into
compliance.
The
BMR
includes
a
schedule
indicating
when
they
will
be
in
compliance
with
the
standards.

Additionally,
IUs
must
submit
Compliance
Schedule
Progress
Reports
for
each
deadline
contained
in
the
schedule
indicating
if
it
has
achieved
that
milestone.
The
IU
must
provide
a
reason
if
it
did
not
achieve
a
milestone.
The
Compliance
Attainment
Report
is
the
final
report
on
National
Pretreatment
Program
ICR
March
21,
2003
26
the
status
of
pretreatment
construction;
it
indicates
that
the
system
is
operating
and
that
the
IU
is
in
compliance
with
the
appropriate
standard.

Once
an
IU
has
achieved
compliance,
it
must
monitor
and
report
the
results
of
its
analysis
to
the
Control
Authority
at
least
once
every
six
months.
(
This
is
the
IU
or
SIU
Self­
Monitoring
Report.)
The
Control
Authority
has
the
discretion
to
require
more
frequent
monitoring
or
reporting
if
necessary.
In
addition,
both
the
IU
and
the
POTW
must
maintain
records
of
these
analyses
for
a
minimum
of
three
years.
The
IU
must
notify
the
Control
Authority
of
any
pollutant
released
at
a
flow
rate
and/
or
pollutant
concentration
that
will
cause
interference
with
the
POTW
or
will
violate
a
general
or
specific
prohibition
of
the
permit.
Such
an
occurrence,
known
as
slug
loading,
must
be
reported
"
immediately"
to
enable
the
POTW
to
take
appropriate
protective
actions
(
40
CFR
403.12(
f)).
The
IU
must
also
notify
the
POTW,
the
State,
and
EPA
of
the
discharge
of
a
substance
defined
as
hazardous
under
RCRA.

Program/
Categorical
Determination
These
reporting
requirements
are
used
to
determine
the
applicability
of
or
to
revise
specific
requirements
imposed
on
IUs.
They
include
the
following:

°
Categorical
Determination
Request.
°
Alternative
Limits
Request.
°
Fundamentally
Different
Factors
Variance
Request.
°
Net/
Gross
Adjustment
Request.
°
Removal
Credit
Approval
Request.
°
Removal
Credit
Self­
Monitoring
Report.

Although
the
information
is
required
once
a
request
is
made,
the
decision
to
make
such
a
request
is
voluntarily
made
by
the
IU,
the
POTW,
or
an
interested
third
party
during
the
implementation
phase
of
a
particular
categorical
standard.

An
IU
or
POTW
may
request
that
the
Oversight
Authority
determine
whether
it
is
subject
to
a
particular
categorical
standard.
If
the
IU
can
demonstrate
that
its
process
effluent
is
mixed
with
other
wastewater
prior
to
treatment,
it
may
request
alternative
discharge
limits.
If
the
IU
(
or
the
interested
party)
can
demonstrate
that
circumstances
exist
that
were
not
considered
when
that
standard
was
developed,
it
may
request
a
Fundamentally
Different
Factors
Variance.
If
an
IU
can
certify
that
its
intake
waters
are
already
contaminated
with
a
restricted
pollutant,
it
may
request
a
Net/
Gross
Adjustment
to
obtain
credit
for
the
amount
of
pollutant
in
its
intake
waters.
(
This
request
is
restricted
to
those
cases
where
the
intake
and
the
discharge
from
the
POTW
are
in
the
same
body
of
water.)

Lastly,
a
POTW
may
apply
to
the
Approval
Authority
at
any
time
for
authorization
to
grant
removal
credits.
To
qualify,
the
POTW
must
certify
that
the
pollutant(
s)
being
controlled
by
the
categorical
standard
is
(
are)
being
treated
and
removed
at
the
POTW,
thereby
rendering
additional
treatment
by
the
IU
unnecessary.
In
such
cases,
the
Approval
Authority
may
revise
the
applicable
numerical
standard(
s)
for
IUs
discharging
to
that
facility.
If
a
POTW
is
granted
removal
credits,
it
must
monitor
and
report
the
results
of
its
analysis
to
certify
that
pollutant
removal
is
ongoing.
National
Pretreatment
Program
ICR
March
21,
2003
27
4(
b)(
ii)
Respondent
Activities
This
section
describes
the
activities
undertaken
by
respondents
to
obtain
the
necessary
information
to
fulfill
their
obligations
to
the
pretreatment
program.
As
in
the
previous
section,
respondent
activities
are
described
with
respect
to
program
development,
program
implementation,
and
program/
categorical
determination.

Program
Development
State
Pretreatment
Program
Approval
Request
States
seeking
approval
for
their
pretreatment
program
must
demonstrate
that
they
have
established
the
necessary
legal,
administrative
and
procedural
bases
for
effective
monitoring
and
oversight
of
POTW
programs.
Requests
are
submitted
to
the
Regional
Administrator,
who
determines
whether
they
meet
the
requirements
of
40
CFR
403.10
and
Section
402(
b)
of
the
CWA.
State
requests
must
include
three
copies
of
the
following
components:

°
A
statement
by
the
Attorney
General
(
or
the
Attorney
for
those
State
Agencies
that
have
independent
counsel)
that
the
laws
of
the
State
provide
adequate
authority
to
implement
the
program,
together
with
copies
of
all
relevant
State
statutes
and
regulations.

°
A
description
of
the
funding
levels
and
full­
time
and
part­
time
personnel
available
to
implement
the
program.

°
Any
modifications
or
additions
to
the
Memorandum
of
Agreement
(
required
by
40
CFR
123.24)
that
may
be
necessary
for
EPA
and
the
State
to
implement
the
program.

The
EPA
Regional
Administrator
will
notify
the
State
that
the
submission
has
been
received
and
is
under
review,
according
to
the
process
set
out
in
40
CFR
123.62.
If
the
State
submission
is
approved,
the
State
will
base
its
pretreatment
program
on
information
in
that
submission.

POTW
Pretreatment
Compliance
Schedule
Progress
Report
Certain
POTWs
must
establish
a
pretreatment
program,
as
stated
in
40
CFR
403.8(
a).
These
are
POTWs
with
one
or
more
of
the
following
characteristics:

°
A
total
design
flow
greater
than
5
million
gallons
per
day
(
mgd),
and
°
Receive
industrial
pollutants
that
pass
through
or
interfere
with
POTW
operations,
or
°
Are
otherwise
subject
to
pretreatment
standards.

The
Administrator
may
require
other
POTWs
develop
a
Program
if
circumstances
warrant
such
action.
POTWs
located
in
States
that
act
as
the
Control
Authority
for
all
POTWs
in
the
State
(
403.10(
e)
States)
are
exempt
from
the
requirement
to
develop
a
Program.
The
compliance
schedule
contains
suggested
dates
to
begin
and
complete
major
program
components
leading
to
the
development
and
implementation
of
a
POTW
pretreatment
program.
Items
such
as
legal
authority,
technical
information,
program
procedures,
and
organizational
and
funding
mechanisms
should
be
included.
The
number
of
activities
specified
in
the
compliance
schedule
National
Pretreatment
Program
ICR
March
21,
2003
28
varies
among
the
States
and
Regions.
The
time
increment
between
each
major
event
specified
in
the
compliance
schedule
may
be
no
more
than
nine
months.

Within
14
days
of
the
deadline
for
each
major
event
in
the
compliance
schedule,
and
within
14
days
of
the
final
compliance
date
for
completing
the
program,
the
POTW
must
submit
a
progress
report
to
the
appropriate
Approval
Authority
stating
whether
the
deadline
has
been
met.
If
the
deadline
was
not
met,
the
report
must
include
the
date
compliance
is
expected,
the
reason
for
the
delay,
and
the
steps
taken
by
the
POTW
to
return
to
the
established
schedule.

POTW
Pretreatment
Program
Approval
Request
POTWs
applying
for
program
approval
must
include
documentation
of
the
following
seven
general
program
elements
in
their
final
submission:

(
1)
Industrial
Waste
Survey
(
IWS).
The
POTW
must
identify
and
evaluate
the
nondomestic
dischargers
to
its
treatment
system.
To
conduct
the
IWS,
the
POTW
must:

°
Compile
a
master
list
of
potential
IUs
in
the
service
area,

°
Identify
and
locate
each
IU
and
collect
information
relating
to
the
type
of
industry
and
the
quality
and
quantity
of
discharge,

°
Summarize
the
data
collected
for
use
in
developing
the
program.

(
2)
Legal
Authority.
The
POTW
must
have
adequate
legal
authority
to
apply
and
enforce
the
requirements
of
the
general
pretreatment
regulations
and
any
other
State
or
local
rules
needed
to
control
nondomestic
discharges.

(
3)
Technical
Elements/
Local
Limits.
The
POTW
must
analyze
discharges
to
its
treatment
system
and
establish
local
effluent
limits
to
protect
the
operation
of
its
treatment
plant,
the
quality
of
its
receiving
water,
and
the
quality
of
its
sewage
sludge.

(
4)
Compliance
Monitoring.
The
POTW
must
develop
procedures
for
monitoring
its
IUs
to
determine
compliance
and
noncompliance.

(
5)
Procedures.
The
POTW
must
develop
administrative
procedures
to
implement
its
pretreatment
program.

(
6)
Resources.
The
POTW
must
have
sufficient
resources
(
funds,
equipment,
and
personnel)
to
operate
an
effective
and
ongoing
program.

(
7)
Enforcement
Response
Plan.
The
POTW
must
develop
a
plan
that
contains
detailed
procedures
indicating
how
it
will
investigate
and
respond
to
instances
of
IU
noncompliance.

The
Approval
Authority
reviews
the
submission
and
determines
its
adequacy,
according
to
the
requirements
of
40
CFR
403.8(
f).
If
the
Approval
Authority
determines
that
the
submission
is
inadequate,
it
notifies
the
POTW
of
any
defects
and
provides
information
on
how
the
POTW
can
comply
with
the
requirements.
National
Pretreatment
Program
ICR
March
21,
2003
29
Record
Maintenance
of
Submission
and
Comments
for
Program
Approval
and
Removal
Credits
The
Approval
Authority
must
retain
and
make
available
to
the
public
for
inspection
and
copying
the
submissions
by
POTWs
of
their
pretreatment
programs
(
for
program
approval)
and
of
any
requests
for
removal
credits.
The
Approval
Authority
must
also
keep
with
these
submissions
any
comments
received
pursuant
to
the
submissions.

Program
Implementation
Baseline
Monitoring
Report
According
to
40
CFR
403.12(
b),
all
IUs
subject
to
categorical
standards
must
submit
a
Baseline
Monitoring
Report
(
BMR)
to
the
Control
Authority
within
180
days
after
the
effective
date
of
the
applicable
standard,
or,
in
the
case
of
new
sources,
at
least
90
days
prior
to
commencement
of
discharge.
The
BMR
must
include:

°
Identifying
information,
°
Environmental
control
permits,
°
Description
of
operations,
°
Flow
measurement
data,
°
Pollutant
measurement
for
regulated
pollutants,
°
Certification
(
or
non­
certification)
of
compliance
with
the
standard,
and
°
Compliance
schedule.

This
information
is
submitted
only
once,
after
promulgation
of
a
categorical
standard.
If
an
IU
has
already
submitted
this
information
during
the
Industrial
Waste
Survey
or
in
a
permit
application,
it
is
not
required
to
resubmit
new
information
to
the
Director
or
Regional
Administrator
in
the
BMR.
The
Control
Authority
may
also
require
noncategorical
IUs
to
submit
a
similar
report
if
it
deems
necessary.

Industrial
User
Compliance
Schedule
Progress
Report
As
part
of
its
BMR,
an
IU
that
cannot
currently
meet
all
effluent
standards
must
submit
a
compliance
schedule
indicating
the
shortest
time
by
which
any
additional
pretreatment
technology
or
operation
and
maintenance
processes
can
be
implemented.
The
schedule
contains
progress
dates
for
commencement
and
completion
of
major
events
leading
to
the
construction
and
operation
of
additional
pretreatment
required
for
the
IU
to
meet
the
categorical
pretreatment
standard.
The
completion
date
in
the
schedule
can
be
no
later
than
the
compliance
date
established
for
that
pretreatment
standard.

In
addition
to
the
compliance
schedule
(
submitted
with
the
BMR),
periodic
reporting
is
required
within
14
days
after
each
date
in
the
schedule.
This
ensures
progress
toward
categorical
standard
compliance.
The
report
must
indicate
whether
the
IU
complied
with
the
scheduled
increment
of
progress
for
that
particular
deadline
and,
if
not,
the
date
on
which
it
expects
to
comply,
the
reason
for
the
delay,
and
the
steps
being
taken
to
return
the
construction
to
the
National
Pretreatment
Program
ICR
March
21,
2003
30
established
schedule.
The
frequency
of
these
reports
is
determined
by
the
planned
stages
of
installation.
In
no
case,
however,
may
more
than
nine
months
elapse
between
submission
of
progress
reports
to
the
Control
Authority.

Industrial
User
Compliance
Attainment
Report
IUs
subject
to
categorical
standards
must
submit
a
report
to
the
Control
Authority
within
90
days
following
the
date
for
final
compliance
with
the
standard.
The
report
must
state
whether
compliance
has
been
attained.
New
sources
(
defined
at
40
CFR
403.3(
k)(
1))
must
also
submit
this
report
after
they
begin
to
discharge
wastewater
into
the
POTW.
The
BMR
must
include:

°
Sampling
data
indicating
the
nature
and
concentration
of
all
pollutants
from
regulated
processes
limited
by
categorical
pretreatment
standards;

°
Average
and
maximum
daily
flow
measurements
for
regulated
wastewater;
and
°
A
statement
signed
by
an
authorized
company
representative
that
declares
whether
pretreatment
standards
are
being
met
on
a
consistent
basis
and,
if
not,
what
additional
operation
and
maintenance
or
pretreatment
is
necessary
to
obtain
compliance.

If
the
Control
Authority
determines
that
the
IU
must
perform
additional
operation
and
maintenance
or
pretreatment
to
attain
the
standard,
it
can
then
assist
the
IU
to
obtain
compliance
or
take
an
enforcement
action
against
the
IU.

Industrial
User
Compliance
Report
(
Resampling
Requirements)

All
IUs
are
required
to:

°
Include
sampling
results
in
compliance
reports,

°
Perform
repeat
monitoring,
when
necessary,
and
°
Notify
the
Control
Authority
immediately
of
all
discharges
that
could
cause
problems
to
the
POTW.

All
monitoring
performed
by
the
IU
must
be
reported
to
the
Control
Authority
to
prevent
IUs
from
selecting
the
most
favorable
sampling
results
to
include
in
the
report.
If
the
sampling
indicates
a
violation,
the
IU
must
notify
the
Control
Authority
within
24
hours
of
becoming
aware
of
the
violation
and
perform
repeat
sampling
for
the
parameter
for
which
the
violation
is
found
and
submit
results
within
30
days.
Finally,
the
IU
must
notify
the
Control
Authority
immediately
of
all
discharges
that
could
cause
problems
to
the
POTW,
including
any
slug
loadings.

In
addition,
the
POTW
may
perform
discharge
monitoring
in
lieu
of
self­
monitoring
by
the
industrial
users.
POTWs
choosing
to
perform
their
own
sampling
and
analysis
must
perform
at
least
the
same
amount
of
sampling
as
is
required
of
industrial
users.

Industrial
User
and
Significant
Industrial
User
Self­
Monitoring
Report
National
Pretreatment
Program
ICR
March
21,
2003
31
Section
403.12
of
the
General
Pretreatment
Regulations
requires
that
categorical
and
non­
categorical
SIUs
report
to
the
Control
Authority
at
least
semiannually
on
their
continuing
compliance
with
the
standard.
The
reports
must
be
submitted
in
June
and
December
of
each
year,
unless
otherwise
specified
in
a
Pretreatment
Standard
or
agreed
upon
by
the
Control
Authority.
New
sources
must
also
submit
these
reports
after
they
begin
to
introduce
wastewater
into
the
POTW.

The
Control
Authority
must
have
authority
to
require
"
appropriate"
reporting
from
non­
categorical
IUs
in
order
to
assess
and
assure
compliance
with
applicable
pretreatment
standards
and
requirements.
The
regulations
specify
that
the
following
information
be
included
in
the
report:

°
Wastewater
pollutant
sampling
and
analysis
data,
including
all
regulated
pollutants,
concentrations,
and
sampling
dates;

°
A
record
of
measured
or
estimated
average
and
maximum
daily
flow
for
the
reporting
period;

In
addition,
the
Control
Authority
may
request
other
information
relating
to
noncompliance,
violations
and
corrective
actions,
sampling
and
analytical
methods,
and
other
topics.

The
regulations
do
not
specify
how
the
data
for
these
reports
are
to
be
developed.
Monitoring
can
be
performed
by
the
Control
Authority,
the
IU,
or
a
combination
of
both.
However,
most
Control
Authorities
require
the
IU
to
self­
monitor
(
in
addition
to
Control
Authority
monitoring).

Pollution
Prevention
Alternative
The
Pesticides
Formulating,
Packaging,
and
Repackaging
regulations
(
40
CFR
§
455.41)
contain
a
provision
that
allows
facilities
to
submit
a
pollution
prevention
alternative
certification
in
lieu
of
complying
with
the
zero
discharge
requirement.
The
paperwork
required
for
compliance
with
the
P2
Alternative
includes
the
following:

°
One­
time
initial
certification
statement
with
required
descriptions
of
products/
processes,
P2
practices
and
treatment
systems,

°
Periodic
(
semi­
annual)
certification
statement
with
description
of
any
changes
since
last
report,

°
Requests
for
approval
of
non­
listed
modifications
to
the
listed
practices
along
with
justifications
for
such
changes,
and
°
On­
site
Compliance
Paperwork
(
i.
e.,
supporting
documentation).

CWT
Multiple
Waste
Subcategories
In
addition,
Subcategory
D
of
the
CWT
regulations
(
40
CFR
§
437)
sets
requirements
which
are
available
to
CWT
facilities
that
accept
waste
in
multiple
subcategories.
These
facilities
must
certify
as
well
as
demonstrate
that
their
treatment
systems
obtain
equivalent
removals
to
those
which
are
the
basis
for
the
separate
subcategory
limits.
According
to
the
CWT
preamble,
National
Pretreatment
Program
ICR
March
21,
2003
32
"
The
new
information
reporting
requirements
under
this
subcategory,
described
at
Sec.
437.41,
include
submission
of
an
initial
certification
statement,
and
annual
certification
statements
thereafter,
and
maintenance
of
on­
site
compliance
paperwork.
These
requirements
are
the
same
as
those
previously
approved
by
OMB
for
facilities
in
the
pesticide
formulating,
packaging,
and
repackaging
category
that
choose
to
comply
with
the
pollution
prevention
alternative.
OMB
is
in
the
process
of
approving
the
extension
of
these
requirements
to
multiple
wastestream
facilities
in
the
CWT
category,
as
part
of
the
revisions
to
the
ICRs
listed
above."

POTW
and
Industrial
User
Maintenance
of
Monitoring
Records
POTWs
and
IUs
must
maintain
records
of
any
monitoring
activity
as
required
by
40
CFR
403.12(
o).
The
records,
which
must
be
kept
by
POTWs
and
IUs,
consist
of
the
sampling
and
analysis
methods
used
by
the
facility
and
the
results
of
both
activities.
Specifically,
the
following
information
must
be
retained
in
the
record:

°
Date,
place,
method,
and
time
of
sampling,
°
Names
of
persons
taking
samples,
°
Dates
of
analysis,
°
Analytical
techniques
used
in
analysis,
and
°
Results
of
analysis.

In
addition,
POTWs
must
retain
copies
of
all
BMRs,
Compliance
Attainment
Reports,
and
periodic
IU
Self­
Monitoring
Reports.
These
records
must
be
kept
for
a
minimum
of
3
years,
and
must
be
available
to
the
State
Director,
the
Regional
Administrator,
or
the
POTW,
as
appropriate,
for
inspection.

Annual
POTW
Reports
The
POTW
is
required
to
submit
an
annual
report
to
the
Approval
Authority.
The
report
must
contain
an
updated
list
of
the
IUs
discharging
to
the
POTW,
specifically
identifying
SIUs.
The
updated
list
must
show
the
categorical
pretreatment
standards
and/
or
local
limits
applicable
to
each
IU.
The
Annual
POTW
Report
should
include
a
summary
of
the
compliance
status
of
each
IU
over
the
period
covered
by
the
report,
a
summary
of
compliance
monitoring
and
enforcement
activities
(
including
inspections
conducted
by
the
POTW),
and
any
other
information
requested
by
the
Approval
Authority,
as
appropriate.

POTW
Program
Modifications
The
POTW
may
request
program
modifications
at
any
time.
All
such
requests
must
be
submitted
to
the
Approval
Authority
for
review.
The
Approval
Authority
determines
whether
the
POTW
request
is
a
substantial
modification.
The
definition
of
a
substantial
modification
is
specified
in
the
requirements
and
includes:

°
Changes
to
POTW
legal
authority
(
except
for
modifications
that
directly
reflect
a
revision
to
40
CFR
Part
403
or
40
CFR
Chapter
I,
subchapter
N),
°
Changes
that
relax
POTW's
local
limits,
except
for
the
modifications
to
local
limits
for
pH
and
reallocations
of
the
Maximum
Allowable
Industrial
Loading
of
a
pollutant
that
do
not
increase
the
total
industrial
loadings
for
the
pollutant,
which
are
reported
pursuant
to
paragraph
(
d)
of
403.18.
Maximum
Allowable
Industrial
Loading
means
the
total
mass
of
a
pollutant
that
all
IUs
of
a
POTW
(
or
a
subgroup
of
IUs
identified
by
the
POTW)
may
discharge
pursuant
to
limits
developed
under
§
403.5(
c),
National
Pretreatment
Program
ICR
March
21,
2003
33
°
Changes
to
POTW
control
mechanisms,
°
Changes
to
POTW
methods
for
implementing
categorical
pretreatment
standards,
°
Decreases
in
the
frequency
of
self­
monitoring
or
reporting
required
of
IUs,
°
Decreases
in
the
frequency
of
POTW
inspection
and
sampling
of
IUs,
°
Changes
to
POTW
confidentiality
procedures
If
the
Approval
Authority
approves
the
substantial
modification,
the
change
is
written
into
the
POTW's
NPDES
permit.
In
addition,
notice
of
approval
must
be
published
in
the
same
newspaper
as
was
the
original
request
for
modification.
The
POTW
is
also
required
to
notify
the
Approval
Authority
of
any
nonsubstantial
modifications
30
days
prior
to
implementation
of
the
modification.

Industrial
User
Slug
Load
Notification
Under
40
CFR
403.8(
f)(
2)(
v)(
C),
IUs
are
required
to
notify
the
POTW
of
any
slug
discharges,
including
any
discharge
that
would
violate
one
of
the
specific
prohibitions
listed
at
403.5(
b).
This
provision
is
intended
to
protect
a
POTW's
operations
and
physical
integrity.
The
prohibitions
listed
at
40
CFR
403.5(
b)
include
the
following:

°
Pollutants
that
create
a
fire
or
explosion
hazard
in
the
POTW,
including
wastestreams
with
a
closed
cup
flashpoint
of
less
than
140
°
F
(
40
CFR
403.5(
b)(
1)),
°
Discharges
with
a
pH
lower
than
5.0,
unless
the
POTW
is
specially
designed
to
accommodate
such
discharges,
and
pollutants
that
will
cause
corrosive,
structural
damage
to
the
POTW
(
40
CFR
403.5(
b)(
2)),

°
Solid
or
viscous
pollutants
in
amounts
that
will
cause
obstruction
to
the
flow
in
the
POTW
resulting
in
interference
(
40
CFR
403.5(
b)(
3)),

°
Any
pollutant,
including
oxygen
demanding
pollutants
(
BOD,
etc.),
released
in
a
discharge
at
a
flow
rate
and/
or
pollutant
concentration
that
will
cause
interference
(
40
CFR
403.5(
b)(
4)),

°
Heat
in
amounts
that
will
inhibit
biological
activity
in
the
POTW,
resulting
in
interference,
heat
in
such
quantities
that
the
temperature
at
the
POTW
exceeds
40
°
C
(
104
°
F)
unless
the
Approval
Authority,
upon
request
of
the
POTW,
approves
alternate
temperature
limits
(
40
CFR
403.5(
b)(
5)),

°
Petroleum
oil,
nonbiodegradable
cutting
oil,
or
products
of
mineral
oil
origin
in
amounts
that
will
cause
interference
or
pass
through
(
40
CFR
403.5(
b)(
6)),

°
Pollutants
which
result
in
the
presence
of
toxic
gases,
vapors,
or
fumes
within
the
POTW
in
a
quality
that
may
cause
acute
worker
health
and
safety
problems
(
40
CFR
403.5(
b)(
7)),
or
°
Any
trucked
or
hauled
pollutants,
except
at
discharge
points
designated
by
the
POTW
(
40
CFR
403.5(
b)(
8)).
National
Pretreatment
Program
ICR
March
21,
2003
34
The
regulations
define
"
interference"
as
a
discharge
that
inhibits
or
disrupts
the
POTW,
its
treatment
process
or
operations;
or
its
sludge
processes,
use,
or
disposal,
and
is
therefore
a
cause
of
a
violation
of
the
POTW's
NPDES
permit
or
prevents
sewage
sludge
use
or
disposal.

All
IUs
are
required
to
notify
the
POTW
immediately
of
any
slug
loading
so
that
the
POTW
can
take
protective
actions.
This
notification
is
typically
a
telephone
call
from
the
IU
to
the
POTW,
with
a
written
notification
often
required
by
the
POTW
to
verify
the
date
and
time
of
the
event,
the
approximate
volume
of
the
concentration
of
the
slug
load,
the
cause
of
the
event,
and
corrective
actions
taken
to
avoid
future
events.

Notification
of
Changed
Discharge
The
regulations
require
all
IUs
to
notify
receiving
POTWs
promptly
of
any
substantial
change
in
the
volume
and
character
of
pollutants
in
the
user's
discharge.
This
notification
enables
POTWs
to
meet
their
obligations
under
40
CFR
122.42(
b)(
2)
to
notify
the
permitting
authority
of
resulting
changes
in
the
POTW
discharge.

Bypass
Notification
The
regulations
require
notification
of
bypass,
which
is
defined
as
the
intentional
diversion
of
wastestreams
from
any
portion
of
a
discharger's
treatment
facility
(
40
CFR
403.17(
a)).
The
regulation
requires
all
IUs
to
give
prior
notice
of
an
anticipated
bypass
to
the
Control
Authority
10
days
before
the
bypass
is
to
occur.
For
an
unanticipated
bypass,
IUs
must
notify
the
Control
Authority
orally
within
24
hours
and,
if
required
by
the
Control
Authority,
follow
up
in
writing
within
five
days.

Notification
of
Changed
Monitoring
Location
This
requirement
affects
IUs
that
treat
wastes
from
multiple
processes.
It
enables
the
IU
to
change
monitoring
locations
from
segregated
wastestreams
to
the
combined
wastestream.
All
categorical
IUs
are
required
to
inform
the
Control
Authority
in
advance
of
any
change
in
the
monitoring
location.

Issuance
of
Discharge
Permits
for
SIUs
The
regulations
require
the
Control
Authority
to
issue
discharge
permits
or
equivalent
individual
control
mechanisms
to
SIUs.
These
discharge
permits
must
include,
at
a
minimum,
the
following:

°
A
statement
of
duration
of
the
permit
(
in
no
case
more
than
five
years),
°
A
statement
of
non­
transferability
without
prior
POTW
approval,
°
Effluent
limits
based
on
applicable
categorical
standards
and
local
limits,
°
Applicable
monitoring,
sampling,
and
reporting
requirements,
and
°
Statements
of
applicable
civil
and
criminal
penalties.

Inspection
and
Sampling
of
IU
and
SIU
Effluent
Control
Authorities
must
randomly
sample
and
analyze
the
effluent
from
IUs
and
conduct
surveillance
activities
to
identify
noncompliance
with
pretreatment
standards.
Control
Authorities
must
also
inspect
and
sample
the
effluent
from
all
SIUs
annually.
This
requirement
establishes
a
clear
minimum
standard
for
how
often
Control
Authorities
must
inspect
and
sample
National
Pretreatment
Program
ICR
March
21,
2003
35
the
effluent
of
SIUs
and
enables
POTWs
to
keep
track
of
toxic
and
hazardous
pollutants
entering
their
systems.

Public
Notification
of
Significant
Noncompliance
The
regulations
require
Control
Authorities
to
publish
in
a
daily
newspaper
a
list
of
IUs
that
were
in
"
significant
noncompliance"
(
violations
of
high
frequency
or
magnitude,
as
defined
in
40
CFR
403.8(
f)(
2))
during
the
previous
12
months.
This
allows
the
public
to
be
aware
of
such
violations.

Prevention
and
Control
Plan
for
Slug
(
Spills
and
Non­
Routine
Batch)
Discharges
Through
inspection
and
sampling
of
IU
and
SIU
effluent
(
see
above),
Control
Authorities
must
evaluate
SIUs
to
determine
whether
they
should
have
prevention
and
control
plans
for
slug
(
spill
and
non­
routine
batch)
discharges.
If
selected,
the
SIU
must
submit
a
plan
which
includes,
at
a
minimum:

°
A
description
of
discharge
practices,
including
non­
routine
batch
discharges,

°
A
description
of
stored
chemicals,

°
Procedures
for
immediately
notifying
the
Control
Authority
of
slug
discharges,
including
any
discharge
that
would
violate
a
prohibition
under
40
CFR
403.5(
b),
with
procedures
for
follow­
up
written
notification
within
five
days,

°
If
necessary,
procedures
to
prevent
impact
from
accidental
spills,
including
inspection
and
maintenance
of
storage
areas,
handling
and
transfer
of
materials,
loading
and
unloading
operations,
control
of
plant
site
run­
off,
and
worker
training,

°
If
necessary,
procedures
for
building
any
necessary
containment
structures
or
equipment,

°
If
necessary,
measures
for
controlling
toxic
organics
(
including
solvents),
and
°
If
necessary,
measures
and
equipment
for
emergency
response.

The
purpose
of
this
requirement
is
to
help
prevent
the
accidental
or
sudden
discharge
of
toxic
or
hazardous
pollutants.

Evaluation
of
the
Need
to
Revise
Local
Limits
POTWs
must
report
to
the
Approval
Authority
every
five
years
on
the
need
to
revise
local
limits.
This
information
is
necessary
for
the
Approval
Authority
to
evaluate
whether
POTWs
have
developed
appropriate
local
limits
to
control
toxic
and
hazardous
pollutants.

POTW
Enforcement
Response
Plan
The
regulations
require
all
approved
POTWs
to
develop
and
implement
Enforcement
Response
Plans
describing
how
they
will
investigate
and
respond
to
IU
noncompliance.
This
provision
enables
EPA
to
determine
the
adequacy
of
POTW
response
to
IU
noncompliance.
National
Pretreatment
Program
ICR
March
21,
2003
36
SIU
Notification
Within
30
days
of
preparing
or
updating
the
inventory
of
SIUs,
the
Control
Authority
must
inform
its
SIUs
in
writing
of
their
status
and
of
all
applicable
requirements.
This
gives
SIUs
notice
of
all
requirements
pertaining
to
them.

Notification
of
RCRA
Discharge
All
IUs
must
notify
POTWs
and
Federal
and
State
hazardous
waste
permitting
authorities
of
any
discharge
into
the
POTW
of
a
substance
that
is
a
listed
or
characteristic
waste
under
Section
3001
of
RCRA.
In
addition,
the
IU
must
estimate
the
volume
of
hazardous
waste
expected
to
be
discharged
during
the
following
12
months.
This
reporting
requirement
applies
to
all
IUs
including
small
quantity
generators
(
less
than
100
kg
RCRA
waste
per
calendar
month).
This
requirement
implements
Section
3018(
d)
of
RCRA.

Excellence
Award
Program
Information
The
National
Pretreatment
Program
Excellence
Awards
is
sponsored
by
EPA
Headquarters.
The
program
allows
exemplary
POTWs
to
be
publicly
and
locally
recognized.
The
program
is
intended
to
heighten
overall
public
awareness
of
industrial
wastewater
control
measures
and
to
encourage
public
support
of
programs
aimed
at
protecting
the
operations
of
treatment
facilities,
the
health
and
safety
of
municipal
employees,
the
quality
of
receiving
waters
and
the
reuse
and
recycling
of
effluents
and
sludges.

States
and
Regions
nominate
POTWs
that
demonstrate
their
commitment
to
protecting
and
improving
the
quality
of
the
nation's
waters
through
outstanding
implementation
and
enforcement
of
local
pretreatment
programs.
Each
nomination
is
screened
using
Quarterly
Noncompliance
Reports
(
QNCRs)
and
other
sources
such
as
the
Permit
Compliance
System
(
PCS).
Nominated
POTWs
should
exhibit
the
following
criteria:

°
The
POTW
should
be
operating
an
exemplary
pretreatment
program.

°
The
POTW
should
be
in
compliance
with
all
pretreatment
requirements
of
40
CFR
Part
403,
its
approved
program,
and
its
NPDES
permit.

°
The
POTW
must
not
be
operating
under
any
enforcement
order
issued
for
any
pretreatment
violation.

°
The
POTW
must
not
have
been
listed
on
any
QNCRs
during
the
previous
four
quarters
for
violations
of
its
approved
pretreatment
program
or
its
NPDES
permit.

States
and
EPA
Regions
typically
nominate
up
to
four
POTWs
each
year
for
an
award.
EPA
requests
an
award
application
from
each
nominated
POTW
that
passes
a
screening
test.
Based
on
a
review
of
the
award
applications
received,
EPA
determines
and
names
award
winners.
National
Pretreatment
Program
ICR
March
21,
2003
37
Program/
Categorical
Determination
Categorical
Determination
Request
When
promulgating
a
pretreatment
standard
under
Section
307(
b)
of
the
CWA,
the
Administrator
designates
a
category
or
categories
of
sources
to
which
the
standards
apply.
IUs
may
be
designated
under
more
than
one
code
or
categorical
standard
subcategory.
If
an
IU
or
POTW
is
uncertain
about
the
applicability
of
a
particular
categorical
standard
or
subcategory
designation,
they
may
request
that
the
EPA
Administrator
(
or
corollary
State
officer
in
approved
Pretreatment
States)
provide
written
certification
that
the
IU
falls
within
that
category
or
subcategory.

The
request
must
be
submitted
within
60
days
after
the
effective
date
of
a
categorical
pretreatment
standard.
A
new
source
must
request
this
certification
before
it
begins
to
discharge
into
the
POTW.
Where
the
POTW
submits
a
request,
it
must
notify
the
affected
IU
of
the
submission.

The
application
for
program/
categorical
determination
must
contain
a
list
of
subcategories
that
may
be
appropriate
for
the
facility,
and
must
cite
evidence
to
support
the
respondent's
contention
of
the
applicability
of
a
particular
subcategory/
category
designation.
In
addition,
all
statements
contained
in
the
application
must
be
certified,
as
described
in
40
CFR
403.6(
a)(
2)(
ii).

Either
the
State
Director
or
the
EPA
Director
may
make
a
categorical
determination.
However,
the
latter
retains
the
right
to
a
final
decision.
If
the
submission
is
found
to
be
incomplete,
an
extension
of
30
days
is
given
to
the
requester
to
correct
the
deficiency.
The
request
is
denied
if
the
deficiency
is
not
corrected
within
this
time
period.
If
the
State
Director
makes
the
determination,
the
EPA
Administrator
is
notified
of
the
decision
and
may
modify
the
decision
within
60
days
after
receipt
of
it.
The
decision
is
sent
to
the
requester,
who
may
request
a
hearing
to
contest
the
decision
to
the
EPA
Administrator
(
or
designee)
within
30
days
after
receipt
of
the
decision.

Alternative
Limits
Modification
When
a
facility's
process
effluent
is
mixed
prior
to
treatment
with
wastewater
that
is
not
from
the
regulated
process,
the
Control
Authority
may
establish
fixed
alternative
discharge
limits.
The
Control
Authority
may
also
approve
such
an
alternative
limit
developed
by
the
IU.
If
there
is
any
material
or
significant
change
in
the
values
used
in
the
calculation
to
fix
the
alternatives
limits,
the
IU
must
immediately
report
such
a
change
to
the
Control
Authority.

Fundamentally
Different
Factors
Variance
Request
Section
40
CFR
403.13
provides
for
a
variance
from
the
limits
specified
in
a
categorical
pretreatment
standard
due
to
"
fundamentally
different
factors"
(
FDF).
In
certain
cases,
an
individual
discharger's
production
processes
or
technologies
may
be
fundamentally
different
from
the
representative
facilities
used
to
determine
those
limits.
A
specific
program/
categorical
pretreatment
standard
variance
request
may
be
submitted
by
an
IU
when
the
user
believes
that
factors
relating
to
its
discharge
are
fundamentally
different
from
those
considered
by
the
Agency
in
establishing
that
standard.
An
FDF
variance
request
may
also
be
submitted
by
a
POTW
or
other
interested
party.
The
IU
or
POTW
submits
the
variance
request
and
supporting
information
to
the
State
Director
or
EPA
Administrator
(
or
designee).
National
Pretreatment
Program
ICR
March
21,
2003
38
Factors
considered
fundamentally
different
are
outlined
in
40
CFR
403.13(
d)
and
include:

°
The
nature
or
quality
of
pollutants
contained
in
the
raw
waste
load
of
the
User's
process
wastewater,

°
The
volume
of
the
User's
process
wastewater
and
effluent
discharged,

°
Non­
water
quality
environmental
impact
of
control
and
treatment
of
the
User's
raw
waste
load,

°
Energy
requirements
of
the
application
of
control
and
treatment
technology,

°
Age,
size,
land
availability,
and
configuration
as
they
relate
to
the
User's
equipment
or
facilities,
processes
employed,
process
changes,
and
engineering
aspects
of
the
application
of
control
technology,
and
°
Cost
of
compliance
with
the
required
control
technology.

The
FDF
variance
request
must
contain
the
following
data:

°
The
name
and
address
of
the
person
making
the
request.

°
Identification
of
the
interest
of
the
requester
affected
by
the
categorical
pretreatment
standard
for
which
the
variance
is
requested.

°
Identification
of
the
POTW
currently
receiving
the
waste
from
the
IU
for
which
alternative
discharge
limits
are
requested.

°
Identification
of
the
categorical
pretreatment
standards
that
are
applicable
to
the
IU.

°
A
list
of
each
pollutant
or
pollutant
parameter
for
which
an
alternative
discharge
limit
is
sought.

°
The
alternative
discharge
limits
proposed
by
the
requester
for
each
pollutant
or
pollutant
parameter
for
which
an
alternative
discharge
limit
is
sought.

°
A
description
of
the
IU's
existing
water
pollution
control
facilities.

°
A
schematic
flow
representation
of
the
IU's
water
system
including
water
supply,
process
wastewater
systems,
and
points
of
discharge.

°
A
statement
of
facts
clearly
establishing
why
the
variance
request
should
be
approved,
including
detailed
supporting
data,
documentation,
and
evidence
(
e.
g.,
technical
and
economic
data
collected
by
EPA
and
used
in
developing
each
pollutant
discharge
limit
in
the
pretreatment
standard).

As
provided
by
40
CFR
403.13(
g)(
2),
the
variance
must
be
submitted
within
180
days
after
the
date
on
which
a
categorical
pretreatment
standards
is
published
in
the
Federal
Register
unless
the
IU
has
requested
a
program/
categorical
determination
as
provided
by
40
CFR
National
Pretreatment
Program
ICR
March
21,
2003
39
403.6(
a),
in
which
case
the
request
must
be
submitted
within
30
days
after
the
categorical
determination.
The
variance
request
is
circulated
to
all
interested
parties
for
public
review.
Following
this
public
comment
period
of
not
less
than
30
days,
the
Director
will
deny
or
approve
the
variance.

Net/
Gross
Adjustment
Request
Section
40
CFR
403.15
details
the
procedures
whereby
an
industry
discharging
to
a
POTW
may
obtain
an
adjustment
to
an
applicable
categorical
pretreatment
standard
based
on
the
presence
of
pollutants
in
the
IU's
intake
water.
These
adjustments
are
known
as
net/
gross
credits.
If
the
adjustment
is
granted,
the
applicable
pretreatment
standard
is
revised
for
those
pollutants
already
present
in
the
IU's
intake
water.
However,
if
an
industry
has
treatment
technology
in
place,
which
will
either
partially
or
entirely
remove
a
certain
pollutant,
the
standard
will
be
adjusted
only
to
the
extent
that
the
pollutant
is
not
removed
by
the
IU's
treatment
technology.

To
obtain
net/
gross
credit,
the
IU
must
submit
a
request
to
the
POTW.
In
the
request,
the
IU
must
demonstrate
the
following:

°
The
intake
water
is
the
same
body
of
water
into
which
the
effluent
from
the
POTW
is
discharged,

°
The
proposed
control
system
(
or
system
in
use)
would,
if
properly
installed
and
operated,
meet
the
Standards
in
the
absence
of
pollutants
in
the
intake
waters.

°
The
pollutants
in
the
intake
water
do
not
vary
chemically
or
biologically
from
the
pollutants
limited
by
the
applicable
standard,
and
°
The
concentration
of
pollutants
in
the
effluent
is
not
significantly
greater
than
the
concentration
in
the
intake
water.

After
the
net/
gross
credit
is
granted,
the
IU
must
notify
the
POTW
of
any
changes
in
the
quantity
of
pollutants
in
the
intake
water
or
the
level
of
IU
treatment.
Additionally,
the
IU
will
be
required
to
conduct
special
monitoring
to
determine
continued
eligibility
for
and
compliance
with
the
adjustments.

Removal
Credit
Approval
Request
The
Removal
Credit
Approval
Request
provides
specific
POTW
data
necessary
for
the
Approval
Authority
to
review
and
approve
a
revised
categorical
pretreatment
standard
reflecting
POTW
pollutant
removal.
Revisions
will
be
made
only
when
the
POTW
demonstrates
consistent
removal
of
each
pollutant
for
which
the
discharge
limit
in
a
categorical
standard
is
to
be
revised,
at
a
level
which
justifies
the
amount
of
revision.
A
removal
credit
benefits
the
POTW's
IUs
that
are
subject
to
the
categorical
standard
that
has
been
revised.
These
users
may
not
have
to
install
additional
pretreatment
or
operation
and
maintenance
technology
in
order
to
comply
with
the
revised
pretreatment
standard.
Application
requirements
and
procedures
for
POTWs
wishing
to
obtain
removal
allowances
are
contained
in
40
CFR
403.7.

To
obtain
a
removal
credit,
the
POTW
must
have
an
approved
pretreatment
program
or
have
such
approval
pending.
It
submits
the
removal
credit
request
and
supporting
information
to
National
Pretreatment
Program
ICR
March
21,
2003
40
the
Approval
Authority,
either
the
EPA
or
the
State
with
delegated
pretreatment
program
authority.
According
to
40
CFR
403.7,
the
POTW's
request
must
include:

°
A
list
of
pollutants
for
which
discharge
limit
revisions
are
proposed.

°
POTW
influent
and
effluent
data
demonstrating
consistent
pollutant
removal.

°
A
description
of
the
POTW's
analytical
methods
used
in
sampling.

°
The
calculations
involved
in
determining
the
POTW's
consistent
pollutant
removal.

°
A
list
of
the
industrial
subcategories
for
which
discharge
limits
will
be
revised.

°
The
calculations
used
to
determine
revised
categorical
standards.

°
A
certification
that
the
POTW
has
an
approved
pretreatment
program
or
qualifies
for
the
exemption
to
this
requirement.

°
A
description
of
the
POTW's
current
sludge
management
practices
and
a
certification
that
the
granting
removal
credits
will
not
cause
a
violation
of
an
applicable
sludge
requirement.

°
A
certification
that
granting
removal
credits
will
not
cause
a
violation
of
the
POTW's
NPDES
permit.

Within
five
days
after
determining
that
the
request
is
complete,
the
Approval
Authority
issues
a
public
notice
that
the
request
has
been
received.
Notices
of
the
request
are
mailed
to
the
agencies
responsible
for
developing
plans
under
CWA
Section
208,
Federal
and
State
fish
and
wildlife
resource
agencies,
and
to
any
other
interested
persons
who
have
requested
notification.
The
public
notice
period
lasts
at
least
30
days,
during
which
time
all
written
comments
are
submitted
to
the
Approval
Authority.
In
addition,
the
Approval
Authority
publishes
the
request
in
the
largest
daily
newspaper
within
the
POTW's
jurisdiction.
To
consider
the
POTW's
removal
allowance
request,
the
Director
must
hold
a
public
hearing
if
there
is
significant
public
interest
in
the
issues
involving
the
POTW's
request
for
removal
authority.
After
the
30­
day
notice,
but
within
180
days,
the
Director
denies
or
approves
the
removal
allowance
request
and
notifies
the
POTW
of
this
decision.

Removal
Credit
Self­
Monitoring
Report
The
Removal
Credit
Self
Monitoring
Report
provides
EPA
with
up­
to­
date,
POTW­
specific
data
necessary
to
ensure
compliance
with
the
categorical
pretreatment
standard.
The
reporting
requirements
are
described
in
detail
in
40
CFR
403.7.

A
POTW
that
has
obtained
removal
credit
approval
must
submit
to
the
Approval
Authority
an
initial
report
demonstrating
consistent
pollutant
removal
and
sludge
quality
maintenance.
Thereafter,
the
POTW
must
continue
to
substantiate
its
removal
credit
with
periodic
reports
to
be
submitted
no
less
than
once
per
year
(
or
as
specified
by
the
AA).

These
reports
are
needed
to
establish
the
POTW's
rate
of
consistent
removal
and,
as
specified
in
Section
307(
b)(
1)
of
the
Act,
to
demonstrate
that
the
POTW's
sludge
use
and
National
Pretreatment
Program
ICR
March
21,
2003
41
disposal
practices
will
not
be
adversely
affected.
According
to
40
CFR
403.7,
each
report
must
include
POTW
influent
and
effluent
data
demonstrating
consistent
pollutant
removal.
The
Approval
Authority
evaluates
each
report
to
determine
whether
the
POTW's
pollutant
removal
and
sewage
sludge
quality
maintenance
have
continued
to
justify
the
approved
removal
credit.
If
the
POTW
has
not
justified
the
removal
credit,
the
Approval
Authority
may
rescind
the
removal
credit
after
notifying
the
POTW.
National
Pretreatment
Program
ICR
March
21,
2003
3
These
definitions
are
taken
from
section
601
of
the
Regulatory
Flexibility
Act.

42
5
THE
INFORMATION
COLLECTED
­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
EPA
personnel
complete
many
different
tasks
in
order
to
implement
the
National
Pretreatment
Program.
Burden
and
costs
for
these
tasks
are
detailed
in
Section
6(
c).

As
Oversight
Authority,
EPA
Regional
Offices
oversee
State
pretreatment
programs.
This
activity
includes
reviewing
certain
requests,
such
as
the
Pretreatment
Categorical
Determination
Request
and
the
Fundamentally
Different
Factors
Request.
Oversight
Authorities
also
receive
requests
from
States
seeking
approval
for
their
pretreatment
programs.
Oversight
Authorities
must
then
review
these
requests
for
completeness.

EPA
Regional
Offices
act
as
Approval
Authority
in
States
that
do
not
have
approved
pretreatment
programs.
As
the
Approval
Authority,
a
Regional
Office
reviews
POTW
pretreatment
programs
for
adequacy,
audits
and
inspects
approved
POTWs,
enforces
against
POTWs
for
failure
to
implement
pretreatment
regulations,
and
enforces
pretreatment
standards
for
IUs
not
in
compliance
(
where
the
POTW
does
not
take
action).
An
Approval
Authority
may
also
inspect
IUs
to
assess
compliance.

EPA
Regional
Offices
also
act
as
Control
Authority
in
instances
where
neither
the
State
nor
the
POTW
has
an
approved
pretreatment
program.
As
Control
Authority,
a
Regional
Office
has
primary
responsibility
for
implementing
the
pretreatment
program.
The
Regional
Office,
acting
as
Control
Authority,
would
notify
SIUs
of
their
status
and
obligations,
review
applications
for
discharge
permits,
and
determine
which
IUs
need
to
take
action
to
reduce
the
risk
of
spills
or
batch
discharges.
The
Control
Authority
also
ensures
that
IUs
comply
with
discharge
limitations
and
reporting
requirements,
inspects
and/
or
reviews
self­
monitoring
reports
from
IUs,
enforces
against
non­
complying
IUs,
and
notifies
the
public
of
significant
violations
and
violators.

5(
b)
Collection
Methodology
And
Management
Reports
and
requests
from
IUs
and
POTWs
are
written.
EPA
makes
use
of
the
PCS
database
to
store,
track,
and
access
information.

5(
c)
Small
Entity
Flexibility
In
developing
this
ICR,
EPA
considered
the
requirement
of
the
Small
Business
Regulatory
Enforcement
Fairness
Act
(
SBREFA)
to
minimize
the
burden
of
information
collections
on
small
entities.
Small
entities
include
"
small
businesses,"
"
small
organizations,"
and
"
small
government
jurisdictions."
These
terms
are
defined
below.
3
°
A
small
business
is
any
business
that
is
independently
owned
and
operated
and
not
dominant
in
its
field,
as
defined
by
the
Small
Business
Administration
(
SBA)
regulations
under
Section
3
of
the
Small
Business
Act.
National
Pretreatment
Program
ICR
March
21,
2003
43
°
A
small
organization
is
any
non­
profit
enterprise
that
is
independently
owned
and
operated
and
not
dominant
in
its
field.

°
A
small
governmental
jurisdiction
is
the
government
of
a
city,
county,
town,
township,
village,
school
district
or
special
district
that
has
a
population
of
fewer
than
50,000.
This
definition
may
also
include
Indian
tribes.

The
major
requirement
under
SBREFA
is
a
regulatory
flexibility
analysis
of
all
rules
that
have
a
"
significant
economic
impact
on
a
substantial
number
of
small
entities."
Since
EPA
is
not
promulgating
a
rule,
this
ICR
is
not
subject
to
SBREFA.

The
reporting
requirements
for
pretreatment
program
development
affect
only
State
and
municipal
governments
(
POTWs).
Requirements
for
both
pretreatment
program
implementation
and
program/
categorical
determination
involve
some
small
businesses.
This
information
is
not
available
from
any
other
source
and
is
essential
for
implementation
of
the
pretreatment
program.
In
most
cases,
the
reporting
burden
for
small
businesses
cannot
be
specifically
reduced.
However,
the
burden
for
small
industries
may
be
inherently
smaller
because
their
facilities
are
likely
to
be
less
complex.
Also,
such
businesses
are
less
likely
to
be
classified
as
SIUs.

The
Agency's
guidance
for
setting
frequencies
for
periodic
self­
monitoring
is
based
in
part
on
flow
volume.
Those
IUs
with
lower
flow
volumes
are
likely
to
be
required
by
the
Control
Authority
to
monitor
less
frequently
than
larger
IUs.

5(
d)
Collection
Schedule
Many
reporting
requirements
associated
with
this
program
are
one­
time
only
requirements.
Therefore,
frequency
of
data
collection
is
relevant
only
to
the
following
requirements:

°
IU
and
SIU
Self­
Monitoring
Reports.
°
Annual
POTW
Reports,
including
updating
the
SIU
List.
°
Issuance
of
Discharge
Permits
for
SIUs.
°
Inspection
and
Sampling
the
Effluent
of
IUs
and
SIUs.
°
Public
Notification
of
Significant
Noncompliance.
°
Evaluation
of
the
Need
to
Revise
Local
Limits.
°
Prevention
and
Control
Plan
for
Spills
and
Batch
Discharges.
°
Excellence
Award
Program
Information.
°
Removal
Credit
Self­
Monitoring
Reports.

Exhibit
5
summarizes
reporting
requirements
for
the
Pretreatment
Program.
National
Pretreatment
Program
ICR
March
21,
2003
44
6
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
This
section
estimates
the
burden
and
cost
to
POTWs,
States,
and
IUs
for
complying
with
the
National
Pretreatment
Program
requirements
detailed
in
Section
4.
This
section
also
discusses
the
assumptions
used
to
estimate
costs
and
burden
in
addition
to
describing
the
change
in
burden,
as
compared
with
the
2000
National
Pretreatment
Program
ICR.

6(
a)
Estimating
Respondent
Burden
Respondents
for
the
pretreatment
program
include
States,
POTWs,
and
IUs.
As
shown
in
Exhibit
6,
the
number
of
respondents
to
this
information
collection
is
32,675.
The
total
burden
attributed
to
States,
POTWs
and
IUs
responding
to
reporting
and
recordkeeping
requirements
for
the
pretreatment
program
is
2,329,802
hours
per
year,
as
summarized
in
Exhibit
6
below.
The
burden
for
each
type
of
respondent
is
detailed
in
Appendix
D,
Tables
2,
3,
and
4.
Table
6
in
Appendix
D
shows
the
average
annual
number
of
responses
per
respondent
for
each
reporting
requirement.
In
addition,
a
discussion
of
data
sources
and
assumptions
is
provided
in
Appendix
C.

In
addition
to
reporting
requirements,
the
pretreatment
regulations
require
IUs,
POTWs,
and
State
Approval
Authorities
to
maintain
records
for
a
minimum
of
three
(
3)
of
years.
IUs
must
also
maintain
records
for
any
monitoring
that
they
conduct.
POTWs
must
also
maintain
any
monitoring
records
that
they
receive.
Lastly,
Approval
Authorities
must
maintain
records
of
any
pretreatment
program
information
that
they
receive
from
POTWs.
The
burden
associated
with
these
recordkeeping
requirements
is
222,217
hours
(
see
Table
5
in
Appendix
D).

Exhibit
6
Summary
of
Total
Annual
Average
Respondent
Burden
Respondent
Number
of
Respondents
Burden
(
hours/
year)
Average
Burden
per
Respondent
Reporting
and
Analysis
Burden:

States
34
59,128
1,739.06
POTWs
1,469
955,279
650.29
IUs
31,172
1,093,178
35.07
Subtotal
32,675
2,107,586
64.50
Recordkeeping:

States
34
12,973
381.56
POTWs
1,469
146,900
100.00
IUs
31,172
62,344
2.00
Subtotal
32,675
222,217
6.80
TOTAL
32,675
2,329,802
71.30
National
Pretreatment
Program
ICR
March
21,
2003
45
6(
a)(
i)
Burden
to
States
As
respondents,
States
submit
the
State
Pretreatment
Program
Approval
Requests.
After
States
have
obtained
approval
authority,
they
may
incur
burden
for
nominating
POTWs
for
excellence
awards.
In
addition,
States
with
approved
programs
must
act
as
Control
Authority
if
the
POTWs
do
not
have
an
approved
program.
As
Control
Authority,
States
must
notify
SIUs
of
their
status
and
all
consequent
requirements
and
must
issue
discharge
permits
to
SIUs.
The
Agency
estimates
a
State
reporting
burden
of
59,128
hours
(
see
Table
2
in
Appendix
D)
and
a
State
recordkeeping
burden
of
12,973
hours
(
see
Table
5
in
Appendix
D).

Approved
Pretreatment
States
(
or
EPA
Regions
in
non­
approved
States),
in
their
role
as
Approval
Authority,
are
users
of
the
following
types
of
information:

°
POTW
Compliance
Schedule
Progress
Reports,
°
POTW
Program
Approval
Requests,
°
Annual
POTW
Reports,
including
update
of
SIU
List
and
inspection
and
sampling
of
IU
and
SIU
effluents,
°
POTW
Program
Modifications,
°
POTW
Enforcement
Response
Plans,
°
Removal
Credit
Approval
Requests,
and
°
Removal
Credit
Self­
Monitoring
Reports.

In
cases
where
the
POTW
does
not
have
an
approved
pretreatment
program
(
e.
g.,
SIUs
in
403.10(
e)
States
and
SIUs
in
non­
pretreatment
cities),
the
Approval
Authority
acts
as
the
Control
Authority.
Based
on
Agency
data,
this
occurs
primarily
where
States
are
the
Approval
Authority.
States,
therefore,
incur
a
burden
as
users
of
the
following
types
of
information:

°
Baseline
Monitoring
Reports
°
IU
Compliance
Schedule
Progress
Reports
°
IU
Compliance
Attainment
Reports
°
IU
Compliance
Reports
(
Resampling
Requirements)
°
IU
and
SIU
Self­
Monitoring
Reports
°
Pollution
Prevention
Alternative
°
Slug
Load
Notification
°
Notifications
of
Changed
Discharge
°
Prevention
and
Control
Plans
for
Spills
and
Batch
Discharges
°
Notifications
of
RCRA
Discharge
°
Alternative
Limits
Requests.

Based
on
information
provided
by
EPA
Regions,
approximately
6.17
percent
of
all
IU
reports
are
submitted
directly
to
Approved
States
acting
as
the
Control
Authority.
Data
also
indicate
that
States
act
as
Approval
Authorities
for
72.84
percent
of
all
POTW
programs.
Appendix
D,
Table
8
outlines
the
hours
per
response,
number
of
responses
per
year,
and
total
number
of
hours
per
year
expended
by
Approved
States
for
review
of
reports
generated
by
both
POTWs
and
SIUs.
(
These
estimates
are
based
on
the
Agency's
past
administration
of
the
Pretreatment
Program,
together
with
assumptions
for
administration
of
the
Pretreatment
Program
over
the
three­
year
ICR
period.)
The
total
number
of
hours
expended
annually
by
Approved
Pretreatment
States
as
users
of
the
data
is
estimated
to
be
48,622.
Based
on
an
average
of
$
31.20
per
hour
for
a
State
employee,
the
total
cost
to
Approved
States
for
administration
of
the
program
is
$
1,517,006.
46
6(
a)(
ii)
Burden
to
POTWs
POTWs
submit
the
following
types
of
information
as
respondents:

°
POTW
Compliance
Schedule
Progress
Reports
°
POTW
Program
Approval
Requests
°
POTW
Pretreatment
Program
Modification
Requests
°
POTW
Maintenance
of
Monitoring
Requirements
(
not
an
actual
submission,
though
burden
is
incurred)
°
Removal
Credit
Requests,
°
Removal
Credit
Self­
Monitoring
Reports
°
Annual
POTW
Reports
°
Issuance
of
Discharge
Permits
°
Updating
Index
of
IUs
°
Inspection
and
Sampling
Effluent
of
IUs
and
SIUs
°
Public
Notification
of
Significant
Noncompliance
°
SIU
Notification
°
Excellence
Award
Program.

As
shown
in
Appendix
D,
Table
3,
the
Agency
estimates
that
the
total
number
of
hours
expended
by
POTWs
as
respondents
to
these
reporting
requirements
is
955,279.
The
annual
POTW
recordkeeping
burden
is
estimated
at
146,900
hours
(
see
Appendix
D,
Table
5).

Approved
POTWs,
when
they
function
as
Control
Authority,
are
users
of
the
following
types
of
information:

°
Baseline
Monitoring
Reports
°
IU
Compliance
Schedule
Progress
Reports
°
IU
Compliance
Attainment
Reports
°
IU
Compliance
Reports
(
Resampling
Requirements)
°
IU
and
SIU
Self­
Monitoring
Reports
°
Pollution
Prevention
Alternative
°
IU
Slug
Load
Notification
Reports
°
Notifications
of
Changed
Discharge
°
Prevention
and
Control
Plans
for
Spills
and
Batch
Discharges
°
Notifications
of
RCRA
Discharge
°
Alternative
Limits
Requests
Based
on
information
provided
by
EPA
Regions,
approximately
93.83
percent
of
all
IU
submissions
go
to
POTWs
with
approved
pretreatment
programs,
with
the
remainder
submitted
to
EPA
Regions
or
Approved
States.
Appendix
D,
Table
9
outlines
the
hours
per
response,
number
of
responses
per
year,
and
total
number
of
hours
per
year
expended
by
POTWs
for
review
of
each
of
these
reports.
(
These
are
Agency
estimates
based
on
past
administration
of
the
pretreatment
program,
together
with
assumptions
for
administration
of
the
pretreatment
program
over
the
three­
year
ICR
period.)
The
total
number
of
hours
expended
annually
by
POTWs
as
users
of
the
data
is
estimated
to
be
96,084.
Based
on
an
average
of
$
24.76
per
hour,
the
total
annual
average
cost
to
POTWs
acting
as
users
of
the
data
for
administration
of
the
pretreatment
program
is
$
2,379,040.
National
Pretreatment
Program
ICR
March
21,
2003
47
6(
a)(
iii)
Industrial
Users
IUs
submit
the
following
types
of
information
as
respondents:

°
Baseline
Monitoring
Reports
°
IU
Compliance
Schedule
Progress
Reports
°
IU
Compliance
Attainment
Reports
°
IU
Compliance
Reports
(
Resampling
Requirements)
°
IU
Self­
Monitoring
Reports
°
Pollution
Prevention
Alternatives
°
IU
Maintenance
of
Monitoring
Records
°
IU
Slug
Load
Notifications
°
Notifications
of
Changed
Discharge
°
Bypass
Notifications
°
Notifications
of
Changed
Monitoring
Location
°
Prevention
and
Control
Plan
for
Slug
(
spills
and
non­
routine
batch)
Discharges
°
Notification
of
RCRA
Discharges
°
Categorical
Determination
Requests
°
Alternative
Limits
Requests
°
FDF
Variance
Requests
°
Net/
Gross
Adjustment
Requests.

Estimates
of
the
numbers
of
indirect
dischargers
in
each
of
the
ELG
categories
that
are
scheduled
to
be
finalized
during
the
three­
year
ICR
period
were
obtained
directly
from
EPA
Office
of
Science
and
Technology
contacts
for
the
respective
categories.
Since
the
previous
ICR,
the
BMRs
and
compliance
attainment
reports
have
been
completed
for
Pesticide
Formulating,
Packaging,
and
Repackaging,
Pharmaceutical
Manufacturing,
and
Pulp,
Paper,
and
Paperboard
Facilities.
Therefore,
for
this
ICR,
no
burden
is
associated
with
these
two
ELG
categories.
Several
other
rulemakings
have
been
abandoned
(
e.
g.,
Industrial
Laundries).
This
ICR
estimates
burden
for
new
source
CIUs
and
the
compliance
attainment
reports
for
Centralized
Waste
Treatment
facilities.

Baseline
Monitoring
Reports
are
required
of
IUs
subject
to
new
categorical
standards
at
the
time
of
promulgation
and
"
new
source"
CIUs
covered
by
existing
categorical
standards.
For
the
three­
year
ICR
period,
no
new
effluent
guidelines
are
expected
to
require
BMRs.
However,
the
ICR
assumes
that
there
will
be
approximately
299
new
source
CIUs
(
2
percent
of
current
CIUs)
that
will
complete
BMRs
each
year.

IU
Compliance
Schedule
reports
are
required
of
existing
facilities
for
which
a
new
categorical
standard
has
been
established,
which
project
that
they
will
be
unable
to
meet
the
pretreatment
compliance
date
for
that
new
categorical
standard.
For
the
burden
estimate,
this
ICR
assumes
that
25
percent
of
the
facilities
required
to
complete
BMRs
will
require
a
compliance
schedule.

All
IUs
submitting
BMRs
must
submit
Compliance
Attainment
reports
within
90
days
following
the
date
for
final
compliance
with
the
standard.
Therefore,
the
number
of
respondents
for
this
requirement
is
the
same
as
for
BMRs.

The
number
of
IUs
performing
Self­
Monitoring
reports
and
the
number
of
IUs
submitting
Certifications,
Notifications,
Categorical
Determinations,
Alternative
Limits,
FDF
Variances,
National
Pretreatment
Program
ICR
March
21,
2003
48
and
Net/
Gross
Requests
is
based
on
current
agency
estimates.
See
Appendix
C
for
a
discussion
of
data
sources
and
assumptions.

As
shown
in
Appendix
E,
Table
4,
the
total
number
of
respondent
reporting
hours
for
IUs
is
1,093,178.
The
annual
IU
recordkeeping
burden
is
estimated
at
62,344
hours
(
see
Appendix
D,
Table
5).

6(
b)
Estimating
Respondent
Costs
Exhibit
7
summarizes
the
costs
to
respondents.
The
following
sections
describe
in
greater
detail
how
these
costs
were
determined
for
States,
POTWs,
and
IUs
Exhibit
7
Average
Annual
Respondent
Costs
Respondent
Burden
Hours
per
Year
Labor
Rate
Cost
State
POTWs
IUs
72,101
1,102,179
1,155,522
$
31.20
$
24.76
$
56.76
$
2,249,550
$
27,289,953
$
65,587,450
TOTAL
2,329,802
$
95,126,953
The
following
assumptions
are
used
to
calculate
the
total
cost
to
States,
POTWs,
and
IUs
acting
as
respondents:

°
This
ICR
uses
a
labor
rate
of
$
31.20
per
hour
for
all
State
activities,
which
is
consistent
with
other
recent
OWM
ICR
submittals.
This
rate
is
based
on
the
average
hourly
wage
for
State
employees,
as
determined
by
the
U.
S.
Department
of
Labor,
and
includes
benefits.
It
is
derived
from
the
U.
S.
Department
of
Labor,
Bureau
of
Labor
Statistics
information
found
at
http://
stats.
bls.
gov,
specifically
the
Employer
Costs
for
Employee
Compensation,
Table
3­
Employer
costs
per
hour
worked
for
employee
compensation
and
costs
as
a
percent
of
total
compensation:
State
and
local
government,
by
selected
characteristics,
June
2002.
As
in
previous
ICRs,
50
percent
overhead
costs
were
added
to
the
average
State
rate.

°
This
ICR
uses
a
labor
rate
of
$
24.76
per
hour
for
all
POTW
activities,
which
is
consistent
with
other
recent
OWM
ICR
submittals.
This
rate
is
based
on
the
average
hourly
wage
for
municipal
public
sector
employess,
as
determined
by
the
U.
S.
Department
of
Labor,
and
includes
benefits.
It
is
derived
from
the
U.
S.
Department
of
Labor,
Bureau
of
Labor
Statistics
information
found
at
http://
stats.
bls.
gov,
specifically
the
Employer
Costs
for
Employee
Compensation,
Table
3­
Employer
costs
per
hour
worked
for
employee
compensation
and
costs
as
a
percent
of
total
compensation:
State
and
local
government,
by
selected
characteristics,
June
2002.
As
in
previous
ICRs,
50
percent
overhead
costs
were
added
to
the
average
State
rate.
National
Pretreatment
Program
ICR
March
21,
2003
49
°
This
ICR
uses
a
labor
rate
of
$
56.76
per
hour
for
all
IU
activities.
The
is
the
rate
used
for
private
sector
employees
in
other
recent
OWM
ICR
submittals.

No
capital
or
O&
M
costs
are
associated
with
the
National
Pretreatment
Program
ICR.

6(
c)
Estimating
Agency
Burden
And
Cost
Appendix
D,
Tables
8
and
10
provide
detailed
information
about
the
burden
to
the
Agency
as
users
of
the
information.
Total
burden
to
the
Agency
is
11,262
hours
per
year.

Cost
to
EPA
includes
costs
incurred
by
EPA
Regions
and
Headquarters
to
process,
analyze,
and
maintain
the
information
collected.
EPA
Regions,
in
their
role
as
Oversight
Authority,
are
users
of
the
following
types
of
information:

°
State
Program
Approval
Request,
°
Categorical
Determination
Request,
°
FDF
Variance
Request,
and
°
Net/
Gross
Adjustment
Request.

EPA
is
the
Federal
Oversight
Authority
for
States
that
act
as
Approval
Authorities.
In
addition,
where
States
are
not
approved
to
administer
the
Pretreatment
Program,
EPA
Regions
act
as
the
Approval
Authority
for
POTWs.
Data
indicate
that
27.16
percent
of
the
1,469
programs
have
EPA
as
the
Approval
Authority.
Appendix
D,
Table
10
outlines
the
hours
per
response,
number
of
responses
per
year,
and
the
total
number
of
hours
per
year
expended
by
the
Federal
Government
(
EPA)
for
review
of
State
and
POTW
reports.
The
annual
average
number
of
hours
expended
by
EPA
as
user
of
the
data
is
11,262.
Based
on
an
average
salary
of
$
32.39
per
hour
for
a
Federal
employee,
the
estimated
annual
cost
to
EPA
$
364,776.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Respondents
for
this
ICR
include
IUs,
POTWs,
and
States,
for
a
total
of
32,675
respondents.
This
ICR
estimates
the
number
of
IUs
at
31,172.
In
addition
to
the
IU
respondents,
this
ICR
assumes
34
States
(
29
States
with
approved
pretreatment
programs
and
five
40
CFR
403.10(
e)
States),
and
1,469
POTWs
with
approved
pretreatment
programs.

The
total
costs
and
burden
for
these
respondents
are
summarized
in
Exhibits
6,
7,
and
8,
as
well
as
in
Appendix
D.
Agency
costs
and
burden
are
detailed
in
Section
6(
c)
and
in
Appendix
D.

6(
e)
Bottom
Line
Burden
Hours
And
Cost
Tables
The
bottom
line
burden
hours
and
costs
appear
in
Exhibit
8.
This
exhibit
summarizes
the
burden
and
cost
calculations
from
Exhibits
6
and
7,
as
well
as
Appendix
D.
The
total
annual
respondent
burden
associated
with
this
ICR
is
estimated
to
be
approximately
2.47
million
burden
hours.
The
corresponding
total
annual
respondent
costs
are
estimated
to
be
$
99.0
million.
The
total
national
burden,
including
respondent
burden
and
Agency
burden,
is
estimated
to
be
2.49
million
hours
annually.
The
total
national
cost,
for
respondents
and
EPA,
is
estimated
to
be
$
99.4
million
annually.
National
Pretreatment
Program
ICR
March
21,
2003
50
Exhibit
8
Total
Average
Annual
Respondent
Burden
and
Costs
Burden
Type
Annual
Burden
Hours
Annual
Costs
Respondent
Reporting
Burden
2,107,586
$
87,546,313
Respondent
Recordkeeping
Burden
222,217
$
7,580,640
State
and
POTW
Burden
as
Users
of
the
Data
144,706
$
3,896,046
Total
2,474,508
$
99,022,998
Note:
The
Federal
government
(
the
Agency)
incurs
a
burden
of
11,262
as
a
user
of
the
data
(
see
Table
10
in
Appendix
D).

6(
f)
Reasons
For
Change
In
Burden
Appendix
D
compares
the
estimated
pretreatment
program
reporting
and
recordkeeping
burden
for
this
ICR
and
for
the
2000
ICR.
The
total
annual
average
respondent
burden
in
the
2000
ICR
is
2,847,167
hours.
This
ICR
estimates
a
total
annual
average
respondent
burden
of
2,474,508
hours.
The
decrease
in
burden
from
2000
to
2003
is
372,659
hours.

Most
of
the
burden
decrease
is
attributable
to
the
number
of
effluent
guidelines
for
which
the
pretreatment
program
assumes
reporting
and
recordkeeping
burden.
In
particular,
several
effluent
guidelines
for
which
the
2000
ICR
estimated
burden
either
have
not
been
promulgated
or
have
been
finalized
with
no
requirements
for
indirect
dischargers.
Additionally,
compliance
requirements
for
other
effluent
guidelines
have
been
completed.
Consequently,
no
pretreatment
burden
or
cost
is
assumed
for
these
effluent
guidelines,
which
include
the
following:

°
Pesticide
Formulating,
Packaging,
and
Repackaging
°
Metal
Products
and
Machinery
°
Industrial
Laundries
°
Pharmaceutical
Manufacturers
°
Transportation
Equipment
Cleaners
For
Centralized
Waste
Treatment
Facilities,
the
burden
increases
slightly
due
to
revised
estimates
of
the
number
of
indirect
dischargers
in
this
category.
This
increase
in
facilities
is
due
to
activities
associated
with
the
new
Centralized
Waste
Treatment
Rule.
This
ICR
estimates
burden
for
compliance
attainment
reports
for
Centralized
Waste
Treatment
Facilities.

Other
factors
that
have
contributed
to
the
change
in
burden
include
updated
data
for
the
number
of
SIUs
(
including
CIUs
and
non­
categorical
SIUs),
POTWs
with
approved
pretreatment
programs,
and
States
with
approved
pretreatment
programs.
For
this
ICR,
labor
rates
have
been
updated
to
correspond
with
the
rates
used
in
other
recent
OWM
ICR
submittals.
These
changes
affect
the
estimated
costs
of
reporting
and
recordkeeping
requirements
of
the
National
Pretreatment
Program.
Table
C­
1
in
Appendix
C
details
the
assumptions
used
in
this
ICR
and
the
2000
ICR,
including
the
updated
numbers
used
for
calculating
burden
and
cost
estimates
National
Pretreatment
Program
ICR
March
21,
2003
51
6(
g)
Burden
Statement
The
public
reporting
and
recordkeeping
burden
for
collections
included
in
this
ICR
is
detailed
in
Exhibit
6
above.
The
annual
respondent
reporting
burden
is
estimated
to
average
64.5
hours
per
respondent
per
year,
and
annual
respondent
recordkeeping
burden
is
estimated
to
average
6.8
hours
per
respondent
per
year.
This
burden
is
attributed
to
POTWs,
industrial
users,
and
States.

Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
people
to
generate,
maintain,
retain,
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
request
for
information
collection
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
2003­
0009,
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
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,
to
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
2003­
0009)
in
any
correspondence.
Appendix
A
2000
Information
Collection
Request
for
the
National
Pretreatment
Program
1For
consistency,
EPA
is
retaining
the
hourly
rates
used
in
the
1996
ICR
($
28.79
for
States,
$
18.10
for
POTWs,
and
$
43.76
for
private
sector
employees.
Costs
associated
with
laboratory
analyses
by
outside
laboratories
are
converted
to
hours
using
the
private­
sector
wage
rate,
because
the
workers
are
private­
sector
employees.

OMB
Control
No.
2040­
0009
Draft
for
OMB
Review
EPA
ICR
No.
0002.08
September
27,
2000
INFORMATION
COLLECTION
REQUEST
FOR
THE
NATIONAL
PRETREATMENT
PROGRAM
(
40
CRF
PART
403)
RESUBMISSION
The
U.
S.
Environmental
Protection
Agency
(
EPA)
is
resubmitting
the
Information
Collection
Request
(
ICR)
for
the
National
Pretreatment
Program,
which
was
approved
by
the
Office
of
Management
and
Budget
(
OMB)
on
October
18,
1996.
This
ICR
estimates
the
recordkeeping
and
reporting
burden
associated
with
the
National
Pretreatment
Program.
In
response
to
questions
raised
by
the
General
Accounting
Office
(
GAO)
in
a
March
2000
report,
this
resubmission
presents
an
alternative
approach
for
estimating
this
burden.

This
resubmission
addresses
the
way
in
which
EPA
presents
the
burden
associated
with
analyses
of
chemical
samples
by
independent
laboratories.
Prior
to
1996,
EPA
had
presented
these
costs
as
hour
burden.
In
1996,
EPA
continued
to
present
analysis
burden
as
hour
burden
for
respondents
that
conducted
laboratory
analysis
"
in­
house."
However,
fees
paid
by
respondents
to
independent
laboratories
were
presented
as
cost
burden
and
included
on
Form
I­
83
under
Item
No.
14b,
"
Total
Annual
Cost
(
O&
M)."

The
burden
associated
with
laboratory
is
converted
to
burden
hours
by
dividing
the
cost
burden
by
the
appropriate
hourly
rate.
1
As
the
table
below
shows,
this
revised
approach
increases
the
burden
hour
estimate
by
1,082,011
hours
(
from
1,765,156
hours
in
the
1996
submission
to
2,847,167
in
this
resubmission).

Type
of
Respondent
Burden
Hr.
Estimted,
per
1996
ICR
Burden
Hr.
Estimate,
Revised
Change
in
Burden
Cost
Average
Hourly
Rate
Hours
States
40,753
(
Exh.
6A)
1,173,266
(
Exh.
8B)
$
28.79
40,753
0
POTWs,
inhouse
labs
305,407
(
Exh.
6B)
5,527,861
(
Exh.
8C)
$
18.10
305,407
0
POTWs,
outside
labs
0
10,552,781
(
Exh.
8C)
$
43.76
241,151
241,151
SIUs
0
34,354,231
(
Exh.
8D)
$
43.76
785,060
785,060
CIUs
in
new
ELGs
0
2,441,824
(
Exh.
8E)
$
43.76
55,800
55,800
Total
1,082,011
Pretreatment
ICR
page
E­
2
2For
1993,
Exhibit
6B
of
the
1996
ICR,
under
Follow­
Up,
reports
136,50
hours
for
metals
and
99,000
hours
for
organics,
for
a
total
of
235,500.
For
1996,
the
table
on
the
previous
page
of
this
resubmission
summary
reports
a
burden
of
305,407
hours
for
in­
house
laboratories
and
241,151
for
outside
labs,
for
a
total
of
546,558
hours.
The
difference
between
1993
and
1996
is
311,058.

3Exhibit
8C
of
the
1996
ICR
shows
an
in­
house
lab
cost
of
$
2,001,377
+
$
662,883
=
$
2,664,260
for
conventional
and
non­
conventional
pollutants.
This
is
equivalent
to
147,197
hours
($
2,664,260/$
18.10
per
hour).
For
contracted
laboratories,
Exhibit
8C
shows
a
lab
cost
of
$
500,344
+
$
662,883
=
$
1,163,227.
This
is
equivalent
to
26,582
hours
($
1,163,227/$
43.76).
In
total,
147,197
hours
+
26,582
hours
=
173,779
hours.

4Exhibit
8C
of
the
1996
ICR
shows
an
in­
house
lab
cost
of
$
315,291
+
$
1,565,027
=
$
1,880,318.
This
is
equivalent
to
103,885
hours
($
1,880,318/$
18.10).
For
contracted
laboratories,
Exhibit
8C
shows
a
total
cost
of
$
640,137
+
$
3,177,479
=
$
3,817,616,
which
is
equivalent
to
87,240
hours
($
3,817,616/$
43.76).
In
1993,
the
Burden
for
metals
was
136,500
(
Exhibit
6B
of
the
1996
ICR).
The
difference
is
54,625
hours.

5Exhibit
8C
of
the
1996
ICR
shows
an
in­
house
lab
cost
of
$
327,761
+
$
655,522
=
$
983,283.
This
is
equivalent
to
54,325
hours
($
983,283/$
18.10).
For
contracted
laboratories,
Exhibit
8C
shows
a
total
cost
of
$
1,857,313
+
$
3,714,626
=
$
5,517,939,
which
is
equivalent
to
127,330
hours
($
5,571,939/$
43.76).
In
1993,
the
Burden
for
organics
was
99,000
(
Exhibit
6B
of
the
1996
ICR).
The
difference
is
82,655
hours.

6The
analysis
burden
in
1996
is
actually
slightly
less
than
the
analysis
burden
in
1993.
Exhibit
6C
of
the
1996
ICR
shows
1993
estimates
of
624,400
for
categorical
users,
360,000
hours
for
metals,
and
237,600
hours
for
organics,
for
a
total
of
898,000
hours.
The
table
in
the
front
shows
a
total
of
785,060
hours.
However,
the
1996
estimate
also
include
estimates
for
sample
collection
and
reporting,
which
appear
to
be
omitted
from
the
1993
estimates.
These
estimates
total
149,280
(
119,424+
29,856).
The
net
difference
is
(
785,060
+
149,280)
­
898,000
=
36,340.

OMB
Control
No.
2040­
0009
Draft
for
OMB
Review
EPA
ICR
No.
0002.08
September
27,
2000
The
revised
1996
burden
estimate
(
2,847,167
hours)
is
significantly
higher
than
the
burden
that
had
been
estimated
in
the
1993
ICR
(
2,322,688
hours).
The
following
summarizes
the
major
reasons
for
this
increase:

C
When
all
analysis
activities
are
reflected
as
burden
hours,
the
burden
associated
with
POTWs'
monitoring
of
SIUs
rises
by
311,058
(
from
235,500
in
1993
to
546,558
in
1996).
2
This
occurs
because:

­­
The
1996
ICR
(
as
resubmitted)
reflected
the
Agency's
revised
focus
on
including
conventional
and
non­
conventional
parameters
in
local
limits.
(
Conventional
and
non­
conventional
parameters
had
not
been
considered
in
the
1993
ICR.).
This
accounts
for
about
173,779
hours.
3
­­
The
1996
ICR
(
as
resubmitted)
shows
an
increase
of
54,625
hours
in
POTWs'
burden
for
metals
testing.
4
Although
the
1996
ICR
uses
a
lower
cost
per
analysis,
the
1993
ICR
underestimated
the
number
of
samples
required.

­­
The
1996
ICR
(
as
resubmitted)
shows
an
increase
of
82,655
hours
in
POTWs'
burden
for
organics
testing.
5
C
The
burden
associated
with
industrial
users'
self­
monitoring
also
increase,
but
only
by
36,340.6
Pretreatment
ICR
page
E­
3
7In
Exhibit
6C
of
the
1996
ICR,
the
sum
of
the
change
in
burden
from
1993
to
1996
for
Baseline
Monitoring
Reports,
IU
Compliance
Schedule
Reports,
and
IU
Compliance
Attainment
Reports
is
156,092
hours.
As
shown
on
the
table
in
the
front
of
this
resubmission
summary,
the
analysis
burden
associated
with
these
reports
is
55,800.
This
totals
211,892.

OMB
Control
No.
2040­
0009
Draft
for
OMB
Review
EPA
ICR
No.
0002.08
September
27,
2000
C
The
1996
ICR
reflects
burden
associated
with
effluent
guidelines
that
EPA
had
expected
to
promulgate
during
the
three­
year
ICR
cycle
(
i.
e.,
10/
1/
96
­
9/
30/
99).
Most
of
this
burden
was
associated
with
Baseline
Monitoring
Reports
(
BMRs)
and
compliance
attainment
reports,
which
reflect
a
net
increase
of
approximately
211,892
hours.
7
C
Other
changes
that
occurred
between
1993
and
1996
account
for
the
remainder
of
the
difference.
For
example,
there
were
more
SIUs
in
1996
compared
with
1993,
which
increased
the
burden
for
many
activities.
On
the
other
hand,
some
one­
time
activities
had
been
completed
between
1993
and
1996,
which
offset
part
of
the
increase
in
burden.

EPA
is
currently
evaluating
the
burden
estimates
discussed
here.
The
Agency
believes
that
the
estimates
presented
in
the
ICR
significantly
overestimate
the
burden
associated
with
the
Pretreatment
Program.
because
of
program
changes
that
have
occurred
since
1996.
In
addition,
EPA
is
currently
finalizing
amendments
to
the
Pretreatment
Streamlining
Rule
(
proposed
July
22,
1999,
64
FR
39564
­
39605).
The
amendments
will
result
in
further
burden
reductions.
Appendix
B
Federal
Register
Notices
Associated
with
the
National
Pretreatment
Program
ICR
Appendix
C
Assumptions
for
Developing
Burden
and
Cost
Estimates
C­
1
Appendix
C
­
Assumptions
for
Developing
Burden
and
Cost
Estimates
Table
C­
1
provides
a
list
of
the
key
data
input
variables
used
to
determine
burden
hours
and
costs
for
the
pretreatment
ICR.
This
appendix
provides
a
description
of
the
source
of
these
data
elements.
In
addition,
the
ICR
relied
on
several
assumptions
regarding
the
relative
percentages
of
respondents
performing
various
tasks.
The
appendix
also
summarizes
these
key
assumptions.

Table
C­
1
Data
and
Assumptions
Used
in
Pretreatment
ICR
Pretreatment
Program
Data
2000
ICR
2003
ICR
1.
Total
Number
of
SIUs
31,962
31,172
2.
Number
of
CIUs
14,928
14,954
3.
Number
of
noncategorical­
SIUs
17,034
16,218
4.
Number
of
State
Run
POTW
Pretreatment
Programs
in
40
CFR
§
403.10(
e)
States
112
97
5.
Total
Number
of
Approved
Programs
1,535
1,469
6.
Number
of
40
CFR
§
403.10(
e)
States
5
5
7.
Number
of
States
eligible
for
Excellence
Awards
submissions
24
29
8.
Number
of
States
with
approved
Pretreatment
Programs
29
34
9.
Number
of
SIUs
with
POTWs
as
Control
Authority
29,797
29,249
10.
Percentage
of
SIUs
with
POTWs
as
Control
Authority
93.2%
93.83%
11.
Number
of
SIUs
with
State/
EPA
as
Control
Authority
2,165
1,923
12.
Percentage
of
SIUs
with
State/
EPA
as
Control
Authority
6.8%
6.17%
13.
Percentage
of
SIUs
Resampling
(
for
violations)
10%
10%
14.
Hourly
Rate
for
Federal
employees
(
50%
Overhead
(
OH))
28.79
32.39
15.
Hourly
Rate
for
State
employees
(
50%
OH)
18.10
31.20
16.
Hourly
Rate
for
POTW
employees
(
50%
OH)
18.10
24.76
17.
Hourly
Rate
for
Private
Industry
employees
(
100%
OH)
43.76
56.76
18.
Number
of
New
Source
CIUs
299
299
19.
Number
of
Pesticide
Formulating,
Packaging,
and
Repackaging
Facilities
1500
0
20.
Number
of
MP&
M
Facilities
(
Phase
I
&
II)
2,000
0
21.
Number
of
CWT
Facilities
56
151
22.
Number
of
Industrial
Laundries
1,700
0
23.
Number
of
Pharmaceutical
Manufacturers
286
0
24.
Number
of
Transportation
Equipment
Cleaning
1,800
0
Pretreatment
Program
Data
2000
ICR
2003
ICR
C­
2
25.
Number
of
POTWs
with
EPA
as
Approval
Authority
567
399
26.
Percentage
of
POTWs
with
EPA
as
Approval
Authority
36.9%
27.16%
27.
Number
of
POTWs
with
State
as
Approval
Authority
968
1,070
28.
Percentage
of
POTWs
with
State
as
Approval
Authority
63.1%
72.84%
29.
Number
of
POTWs
projected
to
develop
a
pretreatment
program
during
the
three­
year
ICR
period
43
46
ICR
Input
Data
1.
Total
Number
of
Significant
Industrial
Users
(
SIUs)
­
Data
collected
from
a
Permit
Compliance
System
(
PCS)
query
conducted
in
February
2003,
as
amended
by
Regional
EPA
personnel.

2.
Number
of
Categorical
Industrial
Users
(
CIU)
­
Data
collected
from
a
PCS
query
conducted
in
February
2003,
as
amended
by
Regional
EPA
personnel.

3.
Number
of
Non­
Categorical
SIUs
­
The
mathematical
difference
between
1
and
2.
above.

4.
Number
of
State­
Run
POTW
Pretreatment
Program
in
40
CFR
§
403.10(
e)
States
­
This
number
was
estimated
by
dividing
the
total
number
of
SIUs
regulated
by
States/
EPA
by
the
average
number
of
SIUs
per
approved
pretreatment
program.
This
assumption
was
carried
over
from
the
previous
ICR.

5.
Total
Number
of
Approved
Programs
­
Data
collected
from
a
PCS
query
conducted
in
February
2003,
as
amended
by
Regional
EPA
personnel.

6.
Number
of
40
CFR
§
403.10(
e)
States
­
Five:
Alabama,
Connecticut,
Mississippi,
Nebraska,
and
Vermont.

7.
Number
of
States
eligible
for
Excellence
Award
submissions
­
Total
number
of
approved,
delegated
state
pretreatment
programs
(
34)
minus
the
five
40
CFR
§
403.10(
e)
states.
Since
these
five
states
cannot
nominate
themselves,
they
are
not
eligible
for
Excellence
Award
submission.

8.
Number
of
States
with
Approved
Pretreatment
Programs
­
Currently
at
34,
per
EPA
Headquarters.

9.
Number
of
SIUs
with
POTWs
as
Control
Authority
­
Data
collected
from
a
PCS
query
conducted
in
February
2003,
as
amended
by
Regional
EPA
personnel.
C­
3
10.
Percentage
of
SIUs
with
POTWs
as
Control
Authority
­
Percentage
calculated
from
data
collected
from
a
PCS
query
conducted
in
February
2003,
as
amended
by
Regional
EPA
personnel.

11.
Number
of
SIUs
with
State/
EPA
as
Control
Authority
­
Data
collected
from
a
PCS
query
conducted
in
February
2003,
as
amended
by
Regional
EPA
personnel.
Includes
SIUs
in
40
CFR
§
403.10(
e)
States
as
well
as
SIUs
regulated
by
States/
EPA
in
nonpretreatment
cities.

Note:
Based
on
Regional
data,
the
vast
majority
of
SIUs
regulated
directly
by
Approval
Authorities
are
in
Approved
States.
Therefore,
the
entire
burden
for
SIUs
in
nonpretreatment
POTWs
is
attributed
to
States
(
and
not
EPA
Regions).
This
assumption
was
carried
over
from
the
previous
ICR.

12.
Percentage
of
SIUs
with
State/
EPA
as
Control
Authority
­
Includes
SIUs
in
40
CFR
§
403.10(
e)
States
as
well
as
SIUs
regulated
by
States/
EPA
in
non­
pretreatment
cities.
The
data
were
collected
from
a
PCS
query
conducted
in
February
2003,
as
amended
by
Regional
EPA
personnel.

13.
Percentage
of
SIUs
Resampling
­
The
previous
ICR
assumed
that
10
percent
of
all
SIUs
would
identify
violations
and,
hence,
resample.
This
assumption
remains
unchanged.

14.
Hourly
Rate
for
Federal
Employees
­
The
hourly
labor
rate
for
the
Federal
government
is
based
on
an
average
annual
salary
for
Federal
employees
of
$
44,738,
which
is
equivalent
to
the
salary
of
a
GS­
9,
Step
10
Federal
employee
(
Office
of
Personnel
Management,
1998
schedule).
At
2,080
hours
per
year,
the
hourly
rate
is
$
21.53.
Overhead
costs
for
Federal
employees
are
estimated
to
be
50
percent
(
i.
e.,
$
10.76
per
hour)
yielding
a
fully
loaded
rate
of
$
32.39
per
hour.

15.
Hourly
Rate
for
State
Employees
­
This
hourly
rate
was
based
on
the
average
hourly
wage
for
State
employees
as
determined
by
the
U.
S.
Department
of
Labor.
It
is
based
on
U.
S.
Department
of
Labor,
Bureau
of
Labor
Statistics.
Employer
Costs
for
Employee
Compensation,
Table
3­
Employer
costs
per
hour
worked
for
employee
compensation
and
costs
as
a
percent
of
total
compensation:
State
and
local
government,
by
selected
characteristics,
June
2002.

16.
Hourly
Rate
for
POTW
Employees
­
The
average
hourly
rate
for
municipal
employees
as
determined
by
the
U.
S.
Department
of
Labor,
Bureau
of
Labor
Statistics
is
$
24.76.
Updated
rates
are
derived
from
Employer
Costs
for
Employee
Compensation,
Table
3
­
Employer
costs
per
hour
worked
for
employee
compensation
and
costs
as
a
percent
of
total
compensation:
State
and
local
government,
by
occupational
and
industry
group,
June
2002.
C­
4
17.
Hourly
Rate
for
Private
Sector
Employees
­
This
average
hourly
rate
for
private
sector
employees
is
consistent
with
rates
used
in
other
recent
OWM
ICR
submittals
and
represents
the
labor
rate
for
IUs.

18.
Number
of
New
Source
CIUs
­
Assumed
a
gross
increase
of
2
percent
of
total
CIUs
will
begin
operation
each
year.
This
assumption
is
unchanged
from
the
previous
ICR.

19­
24.
Number
of
New
Effluent
Limit
Guideline
(
ELG)
Facilities
­
Estimates
of
the
numbers
of
indirect
dischargers
in
each
of
the
ELG
categories
that
are
scheduled
to
be
finalized
during
the
three­
year
ICR
period
were
obtained
directly
from
EPA
Office
of
Science
and
Technology
contacts
for
the
respective
categories.
Since
the
previous
ICR,
the
BMRs
and
compliance
attainment
reports
have
been
completed
for
Pesticide
Formulating,
Packaging,
and
Repackaging
(
PFPR),
Pharmaceutical
Manufacturing,
and
Pulp,
Paper,
and
Paperboard
Facilities.
Therefore,
for
this
ICR,
no
burden
is
associated
with
these
two
ELG
categories.
Other
rulemakings
have
been
abandoned
(
e.
g.,
Industrial
Laundries),
or
were
promulgated
without
pretreatment
standards
(
e.
g.,
Metal
Products
and
Machinery
or
MP&
M).
This
ICR
estimates
burden
for
new
source
CIUs
and
the
compliance
attainment
reports
for
Centralized
Waste
Treatment
facilities.

25­
26.
Number
and
Percentage
of
POTWs
with
EPA
as
Approval
Authority
­
Data
collected
from
a
PCS
query
conducted
in
February
2003,
as
amended
by
Regional
EPA
personnel.

27­
28.
Number
and
Percentage
of
POTWs
with
State
as
Approval
Authority
­
Data
collected
from
a
PCS
query
conducted
in
February
2003,
as
amended
by
Regional
EPA
personnel.

29.
Number
of
POTWs
projected
to
develop
a
Pretreatment
Program
during
the
life
of
this
ICR
­
Data
collected
from
a
PCS
query
conducted
in
February
2003,
as
amended
by
Regional
EPA
personnel.

Burden
Hour
and
Respondent
Assumptions
The
tables
references
below
are
included
as
Appendix
D
and
show
the
burden
and
cost
calculations
for
the
National
Pretreatment
Program
ICR.

Table
2:
Respondent
Burden
for
States
C
State
Pretreatment
Program
Approval
Request
­
Pursuant
to
consultation
with
the
National
Pretreatment
Coordinator,
one
state
may
seek
pretreatment
program
authority
during
the
three­
year
ICR
period.
C­
5
C
Issuance
of
SIU
Discharge
Permits
­
Assumes
all
approved
pretreatment
states
(
34)
issue
some
permits
to
SIUs.
As
such,
the
number
of
responses
per
year
is
calculated
based
on
the
assumption
that
6.17
percent
of
all
SIUs
receive
a
permit
once
every
five
years.
This
assumption
was
carried
over
from
the
previous
ICR.

C
Inspection
and
Sampling
of
SIUs
­

­
Inspection
­
Assumes
all
pretreatment
States
perform
oversight
of
some
SIUs.
Assumes
8
hour
burden
to
perform
one
inspection
per
year
for
6.17
percent
of
all
SIUs.
This
includes
the
time
necessary
to
collect
an
effluent
sample.

­
Sampling
and
Analysis
­
Assumes
all
pretreatment
States
perform
oversight
of
some
SIUs
and
assumes
that
all
analyses
performed
by
States
are
performed
inhouse
The
burden
hours
estimate
is
carried
over
from
the
previous
ICR.
PFPR
facilities
opting
for
the
pollution
prevention
option
are
excluded
because
there
are
no
monitoring
requirements.
Though
other
CIUs
may
reduce
sampling
burden
by
submitting
similar
certifications,
for
simplification,
this
ICR
assumes
that
all
other
CIUs
conduct
monitoring.
This
results
in
a
burden
overestimate
of
unknown
magnitude.

C
Evaluation
of
SIUs
for
Slug
Control
Plan
(
SCP)
­
Assumes
all
pretreatment
States
perform
oversight
of
some
SIUs.
Assumes
0.5
hour
burden
to
assess
whether
an
SIU
needs
an
SCP.
This
assessment
occurs
once
every
two
years
for
6.17
percent
of
all
SIUs.

C
Public
Notification
of
Significant
Noncompliance
­
Assumes
that
only
40
CFR
§
403.10(
e)
States
will
be
required
to
publish
SNC
for
their
POTWs.
One­
third
of
the
POTWs
for
these
States
(
i.
e.,
97
total)
are
estimated
to
have
SIUs
in
SNC
in
a
given
year.
This
assumption
was
carried
forward
from
the
previous
ICR.

C
Evaluation
of
the
Need
to
Revise
Local
Limits
­
Assumes
that
only
40
CFR
§
403.10(
e)
States
will
be
required
to
develop
local
limits
for
their
POTWs.
Each
POTW
for
which
the
State
has
assumed
Control
Authority
responsibility
(
i.
e.,
97
total),
will
require
local
limits
development
once
every
five
years.
This
assumption
was
carried
forward
from
the
previous
ICR.

C
Excellence
Award
Program
Information
­
Assumes
that
40
POTWs
per
year
will
submit
pretreatment
excellence
awards
packages.
Assumes
that
all
34
pretreatment
States
minus
the
five
40
CFR
403.10(
e)
States
that
are
not
eligible
(
29
States
total),
will
receive,
on
average,
1.5
(
i.
e.,
40
packages/
29
States)
excellence
awards
packages
per
State
from
pretreatment
POTWs.
The
previous
ICR
miscalculated
the
average
excellence
award
packages
per
State.
The
basic
assumptions
have
been
carried
forward
from
the
previous
ICR.

Table
3:
Respondent
Burden
for
POTWs
C­
6
C
POTW
Pretreatment
Compliance
Schedule
Reports
­
Based
on
PCS
data,
assumes
that
46
POTWs
per
year
will
be
under
pretreatment­
related
compliance
schedules.
The
schedules
are
anticipated
to
require
3
reports
(
responses)
per
year.
This
assumption
is
carried
forward
from
the
previous
ICR.

C
POTW
Pretreatment
Program
Approval
Requests
­
The
number
of
respondents
is
based
on
information
provided
by
EPA
Regions
regarding
the
total
number
of
new
programs
(
i.
e.,
46)
that
they
anticipate
over
the
next
three
years.
This
burden
has
been
averaged
over
the
three­
year
ICR
period.

C
Annual
Pretreatment
Program
Reports
­
Assumes
one
report
per
program
per
year.
This
assumption
was
carried
forward
from
the
previous
ICR.

C
POTW
Program
Modifications
Approval
Request
­
Assumes
25
percent
of
approved
programs
will
request
program
modifications
of
some
type
each
year.
This
assumption
was
carried
forward
from
the
previous
ICR.

C
Issuance
of
Discharge
Permits
­
Assumes
that
all
Control
Authority
POTWs
will
issue
permits
to
20
percent
of
all
SIUs
that
are
regulated
by
POTWs
(
93.83
percent
of
all
SIUs).

C
Inspection
and
Sampling
of
SIUs
­
Inspection
­
Assumes
8
burden
hours
to
perform
one
inspection
per
year
for
93.83
percent
of
all
SIUs.
This
includes
the
time
necessary
to
collect
an
effluent
sample.
This
assumption
was
carried
forward
from
the
previous
ICR.

­
Sampling
and
Analysis
­
The
burden
hours
estimate
is
carried
forward
from
the
previous
ICR.
PFPR
facilities
opting
for
the
pollution
prevention
option
are
excluded
because
there
are
no
monitoring
requirements.

C
Evaluation
of
SIUs
for
SCP
­
Assumes
0.5
burden
hours
to
assess
whether
an
SIU
needs
an
SCP;
this
burden
is
assumed
once
every
two
years
for
93.83
percent
of
all
SIUs.
This
assumption
was
carried
forward
from
the
previous
ICR.

C
Public
Notification
of
Significant
Noncompliance
­
Assumes
3
burden
hours
for
public
notification.
Additionally
assumes
that
one­
third
of
the
POTWs
with
pretreatment
programs
will
have
SIUs
in
SNC
in
a
given
year.
This
assumption
was
carried
foward
from
the
previous
ICR.

C
Evaluation
of
the
Need
to
Revise
Local
Limits
­
Assumes
that
all
pretreatment
programs
will
reevaluate
the
need
to
develop
local
limits
once
every
five
years.
This
assumption
was
carried
forward
from
the
previous
ICR.
C­
7
C
Excellence
Award
Program
Information
­
Assumes
that
40
POTWs
per
year
will
submit
pretreatment
program
excellence
awards
packages.
This
is
a
voluntary
activity.
This
assumptions
was
carried
forward
from
the
previous
ICR.

C
Removal
Credit
Approval
Requests
­
The
number
of
respondents
is
based
on
estimates
provided
by
EPA
Regions.

C
Removal
Credit
Self­
Monitoring
Reports
­
The
number
of
respondents
is
based
on
the
number
of
POTWs
with
approved
removal
credit
variances,
as
reported
by
EPA
Regions.

Table
4:
Respondent
Burden
for
Industrial
Users
C
Baseline
Monitoring
Reports
­
For
New
Sources
(
pre­
existing
categorical
industries),
assumes
a
2
percent
gross
annual
growth
in
the
number
of
CIUs.
This
assumption
was
carried
forward
from
the
previous
ICR.
For
ELG
categories,
respondents
are
based
on
number
of
indirect
dischargers
in
each
category
(
only
for
ELGs
expected
to
be
finalized
during
the
three­
year
ICR
period).
The
burden
for
each
category
is
annualized
over
the
three­
year
ICR
period.
Pharmaceutical
Manufacturing,
PFPR,
CWT,
and
TEC
have
completed
these
activities
since
the
previous
ICR.
The
deadlines
for
submission
of
BMRs
for
these
categories
have
passed.
EPA
withdrew
the
proposed
rule
for
Industrial
Laundries
in
June
1999;
the
newly
promulgated
MP&
M
category
does
not
apply
to
indirect
discharges.
Therefore,
this
ICR
has
no
burden
associated
with
the
Industrial
Laundry
or
MP&
M
categories.
In
Exhibit
6C,
Baseline
Monitoring
Reports
have
been
divided
into
activities
associated
with
reporting
and
activities
associated
with
analysis.
The
analysis
burden
for
these
reports
is
listed
as
a
separate
line
item;
it
is
distinct
from
the
paperwork
reporting
burden.

C
IU
Compliance
Schedule
Reports
­
For
New
Sources,
assumes
a
2
percent
gross
annual
growth
in
the
number
of
CIUs.
For
ELG
categories,
respondents
are
based
on
number
of
indirect
dischargers
in
each
category
(
only
for
ELGs
expected
to
be
finalized
during
the
three­
year
ICR
period).
EAD
provides
estimates
for
the
number
of
facilities
expected
to
require
compliance
schedules.
The
previous
ICR
assumed
that
25
percent
of
facilities
will
require
compliance
schedules.
The
analysis
burden
for
these
reports
is
listed
as
a
separate
line
item;
it
is
distinct
from
the
paperwork
reporting
burden.

C
IU
Compliance
Attainment
Reports
­
Existing
CIUs
must
complete
a
Final
Compliance
Report
within
90
days
following
the
date
for
final
compliance
with
a
categorical
pretreatment
standard.
New
source
CIUs
must
provide
such
a
report
within
90
days
of
1
CIUs
that
must
submit
compliance
attainment
reports
are
already
submitting
periodic
compliance
reports
with
the
same
information.

C­
8
commencing
discharge
of
the
categorically
regulated
waste
stream
to
the
POTW.
The
burden
for
new
sources
and
CWTs
is
annualized
over
the
three­
year
ICR
period.
1
C
IU
Compliance
Reports
(
Resampling
requirements)
­
Assumes
10
percent
of
all
SIUs
will
identify
violations
and
will
be
required
to
resample
their
effluent.
Assumes
4
labor
hours
to
collect
samples
and
1
hour
labor
to
complete
the
report.
This
assumption
was
carried
forward
from
the
previous
ICR.
The
labor
burden
assumption
for
analysis
has
also
been
carried
forward
from
the
previous
ICR.

C
IU
Self­
Monitoring
Report
­

­
Categorical
SIUs.
PFPR
facilities
opting
for
the
pollution
prevention
option
are
excluded
because
there
are
no
monitoring
requirements.

<
Sampling
­
Assumes
all
CIUs
will
require
4
labor
hours
to
collect
effluent
samples
twice
per
year.
This
assumption
was
carried
forward
from
the
previous
ICR.
<
Reporting
­
Assumes
all
CIUs
will
require
1
labor
hour
to
complete
the
report
twice
per
year.
This
assumption
was
carried
forward
from
the
previous
ICR.

­
Non­
Categorical
SIUs
<
Sampling
­
Assumes
all
NC­
SIUs
will
require
4
labor
hours
to
collect
effluent
samples
twice
per
year.
This
assumption
was
carried
forward
from
the
previous
ICR.
<
Reporting
­
Assumes
all
NC­
SIUs
will
require
1
labor
hour
to
complete
the
report
twice
per
year.
This
assumption
was
carried
forward
from
the
previous
ICR.

NOTE:
Burden
hour
assumptions
for
analysis
are
carried
forward
from
the
previous
ICR.

°
PFPR
P2
Alternatives
­
The
previous
ICR
assumed
that
10
percent
(
150)
of
the
1500
PFPR
facilities
completed
the
P2
alternative
prior
to
the
regulatory
deadline
(
i.
e.,
during
the
period
covered
by
the
previous
ICR).
This
ICR
assumes
that
the
remaining
facilities
(
90
percent,
or
1350
facilities)
have
prepared
and
submitted
an
initial
certification
for
the
P2
alternative.
For
periodic
reports,
this
ICR
assumes
that
all
of
the
indirect
dischargers
will
choose
the
P2
alternative
and
will
prepare
the
periodic
certifications.
For
the
C­
9
modifications,
this
ICR
assumes
that
10
percent
of
the
facilities
that
are
implementing
a
P2
alternative
plan
will
submit
modifications.

°
CWT
Multiple
Wastestream
Category
­
According
to
the
CWT
preamble
(
65
FR
81267),
37
facilities
"
accept
wastes
from
multiple
subcategories
and
could
be
subject
to
the
multiple
wastestream
subcategory."
EPA
assumes
that
91.5
percent
of
these
facilities
are
indirect
discharges
based
on
the
percentage
of
all
CWT
facilities
that
are
indirect
dischargers.
Thus,
34
facilities
(
91.5
percent
of
37)
complete
initial
certification
over
the
three­
year
ICR
period,
and
all
34
submit
annual
certifications
throughout
the
three­
year
period.

C
IU
Slug
Load
Notification
(
Categorical)
­
Assumes
100
respondents
per
year
will
be
required
to
provide
a
slug
load
notification.
This
assumption
was
carried
forward
from
the
previous
ICR.

C
IU
Slug
Load
Notification
(
Non­
Categorical)
­
Assumes
450
respondents
per
year
will
be
required
to
provide
a
slug
load
notification.
The
average
burden
per
response
is
estimated
to
be
0.25
hours.
This
assumption
was
carried
forward
from
the
previous
ICR.

C
Notification
of
Changed
Discharge
­
Assumes
1,000
SIUs
per
year
will
provide
notification
of
a
changed
discharge.
This
assumption
was
carried
forward
from
the
previous
ICR.

C
Bypass
Notification
­
Assumes
1,427
SIUs
per
year
will
report
bypasses.
This
assumption
was
carried
forward
from
the
previous
ICR.

C
Notification
of
Changed
Monitoring
Location
­
Assumes
50
SIUs
per
year
will
provide
notification
of
a
changed
monitoring
location.
This
assumption
was
carried
forward
from
the
previous
ICR.

C
Prevention
and
Control
Plan
for
Spills
and
Batch
Discharges
­
Assumes
that
10
percent
of
all
new
SIUs
will
be
required
to
develop
a
slug
control
plan.
Number
of
"
new"
SIUs
is
based
on
an
assumption
of
a
2
percent
growth
rate
of
existing
SIUs,
plus
all
facilities
that
will
be
covered
under
new
categorical
standards.
This
assumption
was
carried
forward
from
the
previous
ICR.

C
Categorical
Determination
Request
­
Assumes
that
no
formal
categorical
determination
requests
are
generated
during
the
three­
year
ICR
period
because
the
deadline
has
passed.

C
Alternative
Limits
Requests
­
Assumes
that
10
percent
of
all
new
CIUs
will
request
alternative
limits
(
i.
e.,
use
the
combined
wastestream
formula).
This
assumption
was
carried
forward
from
the
previous
ICR.
C­
10
C
Fundamentally
Different
Factors
Variance
Request
­
Assumes
that
no
FDF
requests
will
be
submitted
during
this
three­
year
ICR
period.
This
is
based
on
information
provided
by
OST.

C
Net/
Gross
Adjustment
Request
­
Assumes
2
net/
gross
adjustment
requests
will
be
submitted
each
year.
This
is
based
on
information
provided
by
EPA
Regional
Pretreatment
Coordinators.

Table
5:
Recordkeeping
Burden
for
IUs,
POTWs,
and
States
C
IU
Maintenance
of
Monitoring
Records
­
Assumes
that
all
SIUs
must
maintain
records.
Assumes
2
hours
per
SIU
per
year
to
maintain
pretreatment
records.

C
POTW
Maintenance
of
Monitoring
Records
­
Assumes
that
each
Pretreatment
POTW
spends
100
hours
per
year
to
maintain
SIU
monitoring
records.
This
assumption
was
carried
forward
from
previous
ICR.

C
Approval
Authority
Maintenance
of
Pretreatment
Program
Information
­
Assumes
each
Pretreatment
State
(
as
the
Approval
Authority)
spends
50
hours
per
year
maintaining
records
from
POTW
pretreatment
programs.
Additionally,
States
act
as
Control
Authorities
for
6.17
percent
of
SIUs.
An
additional
burden
of
5
hours
per
SIU
per
year
is
included
for
States
acting
as
Control
Authorities.
This
assumption
was
carried
forward
from
the
previous
ICR.

Table
6:
Annual
Average
Responses
per
Respondent
Each
of
the
activities
identified
in
Table
6
corresponds
directly
to
an
activity
in
Tables
2,
3,
or
4.
The
cell
references
in
the
Exhibit
6E
spreadsheet
link
to
the
corresponding
cell
in
the
appropriate
exhibit.

Table
7:
Average
Annual
Respondent
Costs
Table
7
calculates
the
total
annual
average
cost
to
each
of
the
respondent
categories.

C
State
Cost
­
The
State
cost
is
calculated
by
multiplying
the
total
State
burden
for
reporting
(
Table
2)
and
record
keeping
(
Table
6)
by
the
hourly
rate
for
State
employees.

C
POTW
Cost
­
The
POTW
cost
is
calculated
by
multiplying
the
total
POTW
burden
for
reporting
(
Table
3)
and
record
keeping
(
Table
6)
by
the
hourly
rate
for
POTW
employees.

C
IU
Cost
­
The
IU
cost
is
calculated
by
multiplying
the
total
IU
hourly
burden
for
reporting
(
Table
4)
and
record
keeping
(
Table
6)
by
the
hourly
rate
for
private
sector
employees.
C­
11
Table
8:
Labor
Hours
for
State
Government
as
Users
of
the
Data
Most
of
the
respondent
activities
described
in
Tables
3
and
4,
generate
reports,
information,
or
data
that
must
be
received,
reviewed,
and
stored
by
an
oversight
authority.
Table
8
calculates
the
burden
to
State
Agencies
as
users
of
these
data.
Where
States
are
the
Approval
Authority
(
i.
e.,
72.84
percent
of
POTWs),
reports
generated
by
pretreatment
POTWs
are
reviewed
by
States.
Therefore,
the
associated
"
review"
burden
for
activities
described
in
Table
3
for
which
reports
or
data
are
submitted
to
States
(
as
Approval
Authorities),
has
been
apportioned
accordingly.
The
numbers
of
respondents
and
responses
are
linked
directly
to
the
corresponding
item
on
Table
3.

In
addition
to
Approval
Authority
activities,
States
are
the
Control
Authorities
for
approximately
6.17
percent
of
SIUs.
As
Control
Authority,
the
States
are
responsible
for
receipt
and
review
of
6.17
percent
of
all
reports
and
data
submitted
by
SIUs.
Table
8,
therefore,
includes
burden
for
these
activities.

Table
9:
Labor
Hours
for
POTWs
as
Users
of
the
Data
Most
of
the
respondent
activities
described
in
Table
4
generate
reports,
information,
or
data
that
must
be
received,
reviewed,
and
stored
by
the
Control
Authority.
Table
9
calculates
the
burden
to
POTWs
as
users
of
these
data.
As
Control
Authorities,
POTWs
are
responsible
for
receipt
and
review
of
93.83
percent
of
all
reports
and
data
submitted
by
SIUs.
Therefore,
the
associated
"
review"
burden
for
reports
or
data
submitted
by
SIUs
to
POTWs
(
as
Control
Authorities)
has
been
apportioned
accordingly.
The
numbers
of
respondents
and
responses
are
linked
directly
to
the
corresponding
items
in
Table
4.

Table
10:
Labor
Hours
for
Federal
Government
as
Users
of
the
Data
Most
of
the
respondent
activities
described
in
Tables
2
and
3
generate
reports,
information,
or
data,
that
must
be
received,
reviewed,
and
stored
by
an
oversight
authority.
Table
10
calculates
the
burden
to
Federal
Agencies
(
primarily
EPA
Regions)
as
users
of
these
data.
Where
EPA
is
the
Approval
Authority
(
i.
e.,
27.16
percent
of
POTWs),
reports
generated
by
pretreatment
POTWs
are
reviewed
by
EPA.
Therefore,
the
associated
"
review"
burden
for
the
activities
described
on
Table
3,
for
which
reports
or
data
are
submitted
to
Federal
Agencies
(
as
Approval
Authorities)
has
been
apportioned
accordingly.
The
numbers
of
respondents
and
responses
are
linked
directly
to
the
corresponding
items
in
Table
3.

In
addition,
EPA
is
the
Oversight
Authority
for
States
acting
as
Approval
Authorities.
Data
or
reports,
generated
by
activities
listed
in
Table
2,
will
be
sent
to
EPA
Regions
for
review.
Burden
for
these
review
activities
are
included
in
Table
10.
C­
12
Table
11:
Total
Average
Annual
Respondent
Burden
and
Costs
Table
11
shows
the
total
annual
average
burden
hours
and
annual
average
costs
for
the
pretreatment
program
ICR
by
respondent
category.
These
data
are
each
linked
to
the
originating
exhibit.
Please
note
that
Federal
Government
burden
is
not
included
in
this
exhibit.
Appendix
D
Burden
and
Cost
Spreadsheets
National
Pretreatment
Program
ICR
March
21,
2003
Table
1.
Summary
of
Total
Annual
Average
Respondent
Burden
Reporting
and
Analysis
Burden:

States
34
59,128
1739.06
POTWs
1,469
955,279
650.29
IUs
31,172
1,093,178
35.07
Subtotal
32,675
2,107,586
64.50
Recordkeeping:

States
34
12,973
381.55
POTWs
1,469
146,900
100.00
IUs
31,172
62,344
2.00
Subtotal
32,675
222,217
6.80
TOTAL
32,675
2,329,802
71.30
Respondent
Number
of
Respondents
Burden
(
hours/
year)
Average
Burden
per
Respondent
D­
1
National
Pretreatment
Program
ICR
March
21,
2003
Previous
Calculations
(
2000):
Current
Calculations
(
2003):
Difference:
Reason
for
Change:

(
2)
(
3)
(
4)
(
6)
(
7)
(
8)
(
10)=(
9)­(
5)

Annual
Annual
Hours
Responses
Hours
Responses
Per
Number
of
Per
Hours
Per
Number
of
Per
Hours
Hours
Item
Response
Respondents
Respondent
Per
Year
Response
Respondents
Respondent
Per
Year
Per
Year
State
Pretreatment
300
1
1
300
300
0.3
1
100
­
200
Program
Approval
Request
Issuance
of
SIU
20
29
15
8,694
20
34
11
7,692
­
1,002
Fewer
SIUs
in
PCS
Discharge
Permits
Inspection
and
Sampling
of
SIUs
­
Inspection
8
29
75
17,387
8
34
57
15,384
­
2,003
Fewer
SIUs
in
PCS
­
Sampling
and
Analysis
19
29
75
40,753
19
34
54
34,322
­
6,430
Fewer
SIUs
in
PCS
Evaluation
of
SIUs
for
SCP
0.5
29
37
543
0.5
34
28
481
­
63
Fewer
SIUs
in
PCS
Public
Notification
3
5
7
112
3
5
6
97
­
15
Fewer
POTWs
in
PCS
of
Significant
Noncompliance
Evaluation
of
the
Need
50
5
4
1,120
50
5
4
966
­
154
to
Revise
Local
Limits*

Excellence
Award
2
29
1.8
104
2
29
1.5
87
­
17
Program
Information
TOTAL
ALL
ITEMS
69,013
59,128
­
9,885
Most
states
have
completed;
fewer
respondents
expected
Note:
Values
in
spreadsheet
generally
do
not
display
decimals,
however
decimals
are
carried
through
in
all
calculations.
Fewer
PT
programs
in
PCS
*
States
that
implement
pretreatment
programs
for
their
POTWs
must
evaluate
the
need
to
revise
local
limits
once
every
five
years.
Therefore,
the
number
of
respondents
is
equal
to
the
number
of
States
that
implement
pretreatment
programs
for
their
POTWs
(
5).
The
number
of
evaluations/
responses
per
year
is
equal
to
the
average
number
of
pretreatment
programs
in
each
State
divided
by
five
to
obtain
a
number
of
average
annual
responses.
Table2.
Respondent
Burden
for
States
(
5)=

(
2)*(
3)*(
4)
(
9)=

(
6)*(
7)*(
8)
Fewer
responses
per
respondent
D­
2
National
Pretreatment
Program
ICR
March
21,
2003
Previous
Calculations
(
2000):
Current
Calculations
(
2003):
Difference:
Reason
for
Change:

(
2)
(
3)
(
4)
(
6)
(
7)
(
8)
(
10)=(
9)­(
5)

Annual
Annual
Hours
Responses
Hours
Responses
Per
Number
of
Per
Hours
Per
Number
of
Per
Hours
Hours
Item
Response
Respondents
Respondent
Per
Year
Response
Respondents
Respondent
Per
Year
per
Year
POTW
Pretreatment
Compliance
5
65
3
975
5
46
3
690
­
285
Schedule
Progress
Report*

POTW
Pretreatment
Program
250
14
1
3,575
250
15
1
3,833
258
Approval
Request*

Annual
POTW
Reports
40
1,535
1
61,400
40
1,469
1
58,760
­
2,640
Fewer
PT
programs
in
PCS
POTW
Program
Modification
40
307
1
12,280
40
294
1
11,752
­
528
Fewer
PT
programs
in
PCS
Approval
Request**

Issuance
of
Discharge
20
1,535
4
119,154
20
1,469
4
116,996
­
2,158
Fewer
PT
programs
in
PCS
Permits
for
SIUs
Inspection
and
Sampling
of
SIUs***

­
Inspection
8
1,535
19
238,309
8
1,469
20
233,992
­
4,317
­
Sampling
and
Analysis,
In­
ho
10
1,535
19
305,407
10
1,469
19
278,415
­
26,991
­
Sampling
and
Analysis,
Cont
8
1,535
19
241,151
8
1,469
19
225,389
­
15,762
Evaluation
of
SIUs
for
SCPs
0.5
1,535
10
7,447
0.5
1,469
10
7,312
­
135
Fewer
PT
programs
in
PCS
Public
Notification
of
3
512
1
1,535
3
490
1
1,469
­
66
Fewer
PT
programs
in
PCS
Significant
Noncompliance
Evaluation
of
the
Need
to
50
307
1
15,350
50
294
1
14,690
­
660
Fewer
PT
programs
in
PCS
Revise
Local
Limits
Excellence
Award
Program
12
40
1
480
12
40
1
480
0
Information
(
voluntary)

Removal
Credit
125
4
1
513
125
4
1
500
­
13
Correcting
calculation
error
Approval
Request*
(
voluntary)

Removal
Credit
Self­
40
25
1
1,000
40
25
1
1,000
0
Monitoring
Report
(
voluntary)

TOTAL
ALL
ITEMS
1,008,575
955,279
­
53,297
Note:
Values
in
spreadsheet
generally
do
not
display
decimals,
however
decimals
are
carried
through
in
all
calculations.

*
These
are
one­
time
only
reporting
requirements.
The
total
number
of
respondents
anticipated
over
the
next
three
years
has
been
spread
out
over
the
three­
year
time
span
for
calculation
of
av
**
This
reporting
requirement
is
based
on
an
event
which
occurs
sporadically.
A
single
response
is
all
that
is
required
for
each
occurrence
Table
3.
Respondent
Burden
for
POTWs
***
2000
ICR
derived
total
sampling
and
analysis
burden
for
POTWs
conducting
in­
house
analysis
by
dividing
those
sampling
and
analysis
costs
attributed
to
in­
house
laboratories
by
the
POTW
labor
rate
($
18.10),
and
total
sampling
and
analysis
burden
for
POTWs
conducting
commercial
analysis
by
dividing
those
sampling
and
analysis
costs
attributed
to
commercial
laboratories
by
th
private
sector
labor
rate
($
43.76).
These
are
the
totals
represented
in
(
5).
The
burden
hours
for
contracted
sampling
and
analysis
were
added
in
the
September
27,
2000
submission.

More
expected
PT
program
approval
requests
(
5)=

(
2)*(
3)*(
4)
(
9)=

(
6)*(
7)*(
8)
Fewer
POTWs
on
completion
schedule
Fewer
SIUs
and
PT
programs
in
PCS
D­
3
National
Pretreatment
Program
ICR
March
21,
2003
Previous
Calculations
(
2000):
Current
Calculations
(
2003):
Difference:
Reason
for
Change:

(
1)
(
2)
(
3)
(
5)
(
6)
(
7)
(
9)=(
8)­(
4)

Annual
Annual
Hours
Responses
Hours
Responses
Per
Number
of
Per
Hours
Per
Number
of
Per
Hours
Hours
Item
Response
Respondents
Respondent
Per
Year
Response
Respondents
Respondent
Per
Year
Per
Year
Baseline
Monitoring
Report/
Reporting*

­
New
Sources
28
299
1
8,360
28
299
1
8,372
12
Slightly
more
new
sources
estimated
­
Metal
Products
and
Machinery
28
667
1
18,667
­
0
­
0
­
18,667
No
PT
standards
promulgated
­
PFPR
28
500
1
14,000
­
0
­
0
­
14,000
BMRs/
compliance
completed
­
Centralized
Waste
Treaters
28
19
1
523
­
0
­
0
­
523
BMRs
completed
­
Pharmaceutical
Manufacturing
28
95
1
2,669
­
0
­
0
­
2,669
BMRs/
compliance
completed
­
Industrial
Laundries
28
567
1
15,867
­
0
­
0
­
15,867
No
longer
pursuing
rule
­
Transportation
Equipment
Cleaning
28
600
1
16,800
­
0
­
0
­
16,800
BMRs/
compliance
completed
Baseline
Monitoring
Report/
Analysis*

­
New
Sources
14
299
1
4,256
14
299
1
4,264
8
Slightly
more
new
sources
estimated
­
Metal
Products
and
Machinery
7
667
1
4,569
­
0
­
0
­
4,569
No
PT
standards
promulgated
­
PFPR
14
500
1
7,130
­
0
­
0
­
7,130
BMRs/
compliance
completed
­
Centralized
Waste
Treaters
14
19
1
265
­
0
­
0
­
265
BMRs
completed
­
Pharmaceutical
Manufacturing
23
95
1
2,177
­
0
­
0
­
2,177
BMRs/
compliance
completed
­
Industrial
Laundries
14
567
1
8,079
­
0
­
0
­
8,079
No
longer
pursuing
rule
­
Transportation
Equipment
Cleaning
14
600
1
8,554
­
0
­
0
­
8,554
BMRs/
compliance
completed
IU
Compliance
Schedule
Report
­
New
Sources
4
75
1
299
4
75
1
299
0
Slightly
more
new
sources
estimated
­
Metal
Products
and
Machinery
4
167
1
667
­
0
1
0
­
667
No
PT
standards
promulgated
­
PFPR
4
125
1
500
­
0
1
0
­
500
BMRs/
compliance
completed
­
Centralized
Waste
Treaters
4
5
1
19
­
0
1
0
­
19
BMRs
completed
­
Pharmaceutical
Manufacturing
4
24
1
95
­
0
1
0
­
95
BMRs/
compliance
completed
­
Industrial
Laundries
4
142
1
567
­
0
1
0
­
567
No
longer
pursuing
rule
­
Transportation
Equipment
Cleaning
4
150
1
600
­
0
1
0
­
600
BMRs/
compliance
completed
IU
Compliance
Attainment
Report/
Reporting*

­
New
Sources
20
299
1
5,971
20
299
1
5,980
9
More
CIUs
in
PCS
­
Metal
Products
and
Machinery
20
667
1
13,333
­
0
1
0
­
13,333
No
PT
standards
promulgated
­
PFPR
20
500
1
10,000
­
0
1
0
­
10,000
BMRs/
compliance
completed
­
Centralized
Waste
Treaters
20
19
1
373
20
50
1
1,007
633
Estimate
of
CWT
from
65
FR
81267
­
Pharmaceutical
Manufacturing
20
95
1
1,907
­
0
1
0
­
1,907
BMRs/
compliance
completed
­
Industrial
Laundries
20
567
1
11,333
­
0
1
0
­
11,333
No
longer
pursuing
rule
­
Transportation
Equipment
Cleaning
20
600
1
12,000
­
0
1
0
­
12,000
BMRs/
compliance
completed
IU
Compliance
Attainment
Report/
Analysis*

­
New
Sources
14
299
1
4,256
14
299
1
4,264
8
More
CIUs
in
PCS
­
Metal
Products
and
Machinery
7
667
1
4,569
­
0
1
0
­
4,569
No
PT
standards
promulgated
­
PFPR
14
500
1
7,130
­
0
1
0
­
7,130
BMRs/
compliance
completed
­
Centralized
Waste
Treaters
14
19
1
265
14
50
1
718
453
Estimate
of
CWT
from
65
FR
81267
­
Pharmaceutical
Manufacturing
23
95
1
2,177
­
0
1
0
­
2,177
BMRs/
compliance
completed
­
Industrial
Laundries
14
567
1
8,079
­
0
1
0
­
8,079
No
longer
pursuing
rule
­
Transportation
Equipment
Cleaning
14
600
1
8,554
­
0
1
0
­
8,554
BMRs/
compliance
completed
Table
4.
Respondent
Burden
for
Inustrial
Users
(
4)=

(
1)*(
2)*(
3)
(
8)=

(
5)*(
6)*(
7)

D­
4
National
Pretreatment
Program
ICR
March
21,
2003
Previous
Calculations
(
2000):
Current
Calculations
(
2003):
Difference:
Reason
for
Change:

(
1)
(
2)
(
3)
(
5)
(
6)
(
7)
(
9)=(
8)­(
4)

Annual
Annual
Hours
Responses
Hours
Responses
Per
Number
of
Per
Hours
Per
Number
of
Per
Hours
Hours
Item
Response
Respondents
Respondent
Per
Year
Response
Respondents
Respondent
Per
Year
Per
Year
(
4)=

(
1)*(
2)*(
3)
(
8)=

(
5)*(
6)*(
7)

IU
Compliance
Reports
(
Resampling
Requirements)

­
Sampling
4
3,196
1
12,785
4
2,967
1
11,869
­
916
Fewer
SIUs
in
PCS,
PFPR
P2
sampling
­
Analysis
12
3,196
1
38,066
12
2,967
1
35,339
­
2,727
Fewer
SIUs
in
PCS,
PFPR
P2
sampling
­
Reporting
1
3,196
1
3,196
1
2,967
1
2,967
­
229
Fewer
SIUs
in
PCS,
PFPR
P2
sampling
IU/
SIU
Self­
Monitoring
Report
Categorical
SIUs
­
Sampling
4
14,928
2
119,424
4
13,454
2
107,632
­
11,792
­
Analysis***
15
14,928
2
439,209
15
13,454
2
395,842
­
43,368
­
Reporting
1
14,928
2
29,856
1
13,454
2
26,908
­
2,948
Non­
Categorical
SIUs
­
Sampling
4
17,034
2
136,272
4
16,218
2
129,744
­
6,528
Fewer
NCSIUs
in
PCS
­
Analysis
9
17,034
2
322,112
9
16,218
2
306,682
­
15,431
Fewer
NCSIUs
in
PCS
­
Reporting
1
17,034
2
34,068
1
16,218
2
32,436
­
1,632
Fewer
NCSIUs
in
PCS
PFPR
P2
Alternative
­
Initial
Certification
60
50
1
3,000
­
0
1
0
­
3,000
Certifications
completed
­
Periodic
Certifications
0.25
150
2
75
0.25
1500
2
750
675
More
PFPR
CIUs
now
participating
­
Modifications
20
15
1
300
20
150
1
3,000
2,700
More
PFPR
CIUs
now
participating
CWT
Multiple
Wastestream
Category
­
Initial
Certification
­
­
­
­
60
11
1
677
677
Estimate
from
65
FR
81267
­
Annual
Certifications
­
­
­
­
0.25
34
1
8
8
Estimate
from
65
FR
81267
IU
Slug
Load
Notification
2
100
1
200
2
100
1
200
0
(
Categorical)

IU
Slug
Load
Notification
0.25
450
1
113
0.25
450
1
113
0
(
Non­
Categorical)

Notification
of
Changed
Discharge
4
1,000
1
4,000
4
1,000
1
4,000
0
Bypass
Notification
5
1,427
1
7,135
5
1,427
1
7,135
0
Follow­
Up
2
1,070
1
2,140
2
1,070
1
2,140
0
Notification
of
Changed
1
50
1
50
1
50
1
50
0
Monitoring
Location
Slug
Control
Plans
2
309
1
617
2
67
1
135
­
482
Fewer
new
SIUs/
categorical
standards
Categorical
Determination
20
18
1
366
­
0
1
0
­
366
Deadline
for
request
has
passed
Request
(
voluntary)

Alternative
Limits
Modification
2
275
1
549
2
35
1
70
­
479
Fewer
new
SIUs/
categorical
standards
Fundamentally
Different
Factors
160
6
1
960
160
3
1
480
­
480
Variance
Request
(
voluntary)

Net/
Gross
Adjustment
Request
50
6
1
310
50
2
1
100
­
210
(
voluntary)

TOTAL
ALL
ITEMS
(
IUs)
1,359,412
1,093,178
­
266,233
Note:
Values
in
spreadsheet
generally
do
not
display
decimals,
however
decimals
are
carried
through
in
all
calculations.

**
These
reporting
requirements
are
based
on
events
which
occur
sporadically.
A
single
response
is
all
that
is
required
for
each
occurrence.

***
Analysis
burden
carried
forward
from
2000
ICR.
More
CIUs
in
PCS,
but
PFPR
IUs
removed
to
prevent
double
counting
Estimate
from
EPA
Regional
PT
Coordinators
Estimate
from
EPA
Regional
PT
Coordinators
*
These
are
one­
time
only
reporting
requirements.
Total
number
of
respondents
anticipated
over
the
next
three
years
has
been
spread
out
over
the
three­
year
time
span
for
calculation
of
annual
burden.
Burden
for
analysis
was
not
included
in
1996
ICR.
D­
4
National
Pretreatment
Program
ICR
March
21,
2003
Previous
Calculations
(
1996):
Current
Calculations
(
1999):
Difference:
Reason
for
Change:

(
2)
(
3)
(
4)=(
2)*(
3)
(
5)
(
6)
(
7)=(
5)*(
6)
(
8)=(
7)­(
4)

Hours
per
Number
of
Hours
Hours
per
Number
of
Hours
Hours
Item
Recordkeeper
Recordkeepers
Per
Year
Recordkeeper
Recordkeepers
Per
Year
Per
Year
IU
Maintenance
of
2
31,962
63,924
2
31,172
62,344
­
1,580
Fewer
SIUs
in
PCS
Monitoring
Records
POTW
Maintenance
of
100
1,535
153,500
100
1,469
146,900
­
6,600
Monitoring
Records
Approval
Authority
50
29
1,450
50
34
1,700
250
Maintenance
of
375
29
10,867
332
34
11,273
406
Pretreatment
Program
Information*

TOTAL
ALL
ITEMS
229,741
222,217
­
7,524
Note:
Values
in
spreadsheet
generally
do
not
display
decimals,
however
decimals
are
carried
through
in
all
calculations.

*
Additional
burden
due
to
States
that
act
as
Control
Authorities.
Assumes
5
hours
per
SIU
per
year.
Fewer
pretreatment
programs
in
PCS
More
states
with
PT
authority
Table
5.
Recordkeeping
Burden
for
Industrial
Users,
POTWs,
and
States
D­
5
National
Pretreatment
Program
ICR
March
21,
2003
(
1)
(
2)
(
3)=(
1)*(
2)

Type
Title
Number
of
Responses
Responses
Respondents
Per
Respondent
Per
Year
Program
Development
State
Pretreatment
Program
Approval
Request
0
1
0
POTW
Pretreatment
Compliance
Schedule
46
3
138
Progress
Report
POTW
Pretreatment
Program
Approval
Request
15
1
15
Program
Implementation
Baseline
Monitoring
Report/
Reporting
­
New
Sources
299
1
299
­
Metal
Products
and
Machinery
0
0
0
­
Pesticide
Formulating,
Packaging,
and
Repackagi
0
0
0
­
Centralized
Waste
Treaters
0
0
0
­
Pharmaceutical
Manufacturing
0
0
0
­
Industrial
Laundries
0
0
0
­
Transportation
Equipment
Cleaning
0
0
0
Baseline
Monitoring
Report/
Analysis
­
New
Sources
299
1
299
­
Metal
Products
and
Machinery
0
0
0
­
Pesticide
Formulating,
Packaging,
and
Repackagi
0
0
0
­
Centralized
Waste
Treaters
0
0
0
­
Pharmaceutical
Manufacturing
0
0
0
­
Industrial
Laundries
0
0
0
­
Transportation
Equipment
Cleaning
0
0
0
IU
Compliance
Schedule
Progress
Report
­
New
Sources
75
1
75
­
Metal
Products
and
Machinery
0
1
0
­
Pesticide
Formulating,
Packaging,
and
Repackagi
0
1
0
­
Centralized
Waste
Treaters
13
1
13
­
Pharmaceutical
Manufacturing
0
1
0
­
Industrial
Laundries
0
1
0
­
Transportation
Equipment
Cleaning
0
1
0
Table
6.
Average
Annual
Responses
per
Respondent
D­
6
National
Pretreatment
Program
ICR
March
21,
2003
(
1)
(
2)
(
3)=(
1)*(
2)

Type
Title
Number
of
Responses
Responses
Respondents
Per
Respondent
Per
Year
Program
Implementation
IU
Compliance
Attainment
Report
(
continued)
­
New
Sources
299
1
299
­
Metal
Products
and
Machinery
0
1
0
­
Pesticide
Formulating,
Packaging,
and
Repackagi
0
1
0
­
Centralized
Waste
Treaters
50
1
50
­
Pharmaceutical
Manufacturing
0
1
0
­
Industrial
Laundries
0
1
0
­
Transportation
Equipment
Cleaning
0
1
0
IU
Compliance
Attainment
Report/
Analysis
­
New
Sources
299
1
299
­
Metal
Products
and
Machinery
0
1
0
­
Pesticide
Formulating,
Packaging,
and
Repackagi
0
1
0
­
Centralized
Waste
Treaters
50
1
50
­
Pharmaceutical
Manufacturing
0
1
0
­
Industrial
Laundries
0
1
0
­
Transportation
Equipment
Cleaning
0
1
0
IU
Compliance
Reports
(
Resampling
Requirements)

­
Sampling
2,967
1
2,967
­
Reporting
2,967
1
2,967
IU/
SIU
Self­
Monitoring
Report
Categorical
SIUs
­
Sampling
13,454
2
26,908
­
Analysis
13,454
2
26,908
­
Reporting
13,454
2
26,908
Non­
Categorical
SIUs
­
Sampling
16,218
2
32,436
­
Analysis
16,218
2
32,436
­
Reporting
16,218
2
32,436
D­
6
National
Pretreatment
Program
ICR
March
21,
2003
(
1)
(
2)
(
3)=(
1)*(
2)

Type
Title
Number
of
Responses
Responses
Respondents
Per
Respondent
Per
Year
Program
Implementation
PFPR
P2
Alternative
(
Continued)
­
Initial
Certification
0
1
0
­
Periodic
Certifications
1,500
2
3,000
­
Modifications
150
1
150
CWT
Multiple
Wastestream
Category
­
Initial
Certification
11
1
11
­
Annual
Certifications
34
1
34
Annual
POTW
Reports
1,469
1
1,469
POTW
Program
Modifications
294
1
294
IU
Slug
Load
Notification
(
Categorical)
100
1
100
IU
Slug
Load
Notification
(
Non­
Categorical)
450
1
450
Notification
of
Changed
Discharge
1,000
1
1,000
Bypass
Notification
1,427
1
1,427
Follow­
up
1,070
1
1,070
Notification
of
Changed
Monitoring
Location
50
1
50
Issuance
of
Discharge
Permits
for
SIUs
States
34
11
385
POTWs
1,469
4
5,850
State
Inspection
and
Sampling
the
Effluent
of
IUs
and
SIUs
Inspection
and
Sampling
of
SIUs
34
57
1,923
Evaluation
of
SIUs
34
28
962
POTW
Inspection
and
Sampling
the
Effluent
of
IUs
and
SIUs
Inspection
and
Sampling
of
SIUs
1,469
20
29,249
Evaluation
of
SIUs
1,469
10
14,625
Public
Notification
of
Significant
Noncompliance
States
5
6
32
POTWs
490
1
490
D­
6
National
Pretreatment
Program
ICR
March
21,
2003
(
1)
(
2)
(
3)=(
1)*(
2)

Type
Title
Number
of
Responses
Responses
Respondents
Per
Respondent
Per
Year
Program
Implementation
Prevention
and
Control
Plan
0
0
0
(
Continued)
for
Spills
and
Batch
Discharges
Evaluation
of
the
Need
to
Revise
Local
Limits
States
5
4
19
POTWs
294
1
294
Excellence
Award
Program
Information
States
29
2
44
POTWs
40
1
40
Program/
Categorical
Categorical
Determination
Request
0
1
0
Determination
Alternative
Limits
Modification
35
1
35
Fundamentally
Different
Factors
3
1
3
Variance
Request
Net/
Gross
Request
2
1
2
Removal
Credit
Approval
Request
4
1
4
Removal
Credit
Self­
Monitoring
Report
25
1
25
Total:
248,539
Number
of
Respondents
Per
Year
(
From
Table
1):
32,675
TOTAL
ANNUAL
AVERAGE
RESPONSES
PER
RESPONDENT:
7.61
D­
6
National
Pretreatment
Program
ICR
March
21,
2003
Respondent
Burden
hours
per
year
Labor
rate
Cost
State
72,101
$
31.20
$
2,249,550
POTWs
1,102,179
$
24.76
$
27,289,953
IUs
1,155,522
$
56.76
$
65,587,450
TOTAL
2,329,802
$
95,126,953
Table
7.
Average
Annual
Respondent
Costs
D­
7
National
Pretreatment
Program
ICR
March
21,
2003
Table
8.
Labor
Hours
for
State
Governments
as
Users
of
the
Data
Previous
Calculations
(
2000):
Current
Calculations
(
2003):
Difference:

(
2)
(
3)
(
4)
(
5)
(
6)
(
7)
(
8)
(
9)
(
10)

Hours
Number
of
Hours
Per
Hours
Number
of
Hours
Per
Hours
per
Number
of
Responses
Year
per
Number
of
Responses
Year
per
Year
Item
Response
Respondents
Per
Year
(
2)*(
3)*(
4)
Response
Respondents
Per
Year
(
6)*(
7)*(
8)
(
9)­(
5)

State
Pretreatment
Program
N/
A
N/
A
N/
A
N/
A
N/
A
N/
A
N/
A
N/
A
0
Approval
Request*

POTW
Pretreatment
Compliance
2
41
1
**
82
2
34
1
**
67
­
15
Schedule
Progress
Report***

POTW
Pretreatment
Program
40
9
1
**
361
40
11
1
**
447
86
Approval
Request***

POTW
Pretreatment
Program
20
194
1
3,874
20
214
1
4,280
406
Modification
Approval
Request***

Baseline
Monitoring
Report
­
New
Sources
24
20
1
**
487
24
18
1
**
443
­
45
­
Metal
Products
and
Machinery
24
45
1
**
1,088
24
0
1
**
0
­
1,088
­
PFPR
24
34
1
**
816
24
0
1
**
0
­
816
­
Centralized
Waste
Treaters
24
1
1
**
30
24
0
1
**
0
­
30
­
Pharmaceutical
Manufacturing
24
6
1
**
156
24
0
1
**
0
­
156
­
Industrial
Laundries
24
39
1
**
925
24
0
1
**
0
­
925
­
Transportation
Equipment
Cleanin
24
41
1
**
979
24
0
1
**
0
­
979
IU
Compliance
Schedule
Progress
Report
­
New
Sources
1
5
1
**
5
1
5
1
**
5
0
­
Metal
Products
and
Machinery
1
11
1
**
11
1
0
1
**
0
­
11
­
PFPR
1
8
1
**
8
1
0
1
**
0
­
8
­
Centralized
Waste
Treaters
1
0
1
**
0
1
0
1
**
0
0
­
Pharmaceutical
Manufacturing
1
2
1
**
2
1
0
1
**
0
­
2
­
Industrial
Laundries
1
10
1
**
10
1
0
1
**
0
­
10
­
Transportation
Equipment
Cleanin
1
10
1
**
10
1
0
1
**
0
­
10
D­
8
National
Pretreatment
Program
ICR
March
21,
2003
Previous
Calculations
(
2000):
Current
Calculations
(
2003):
Difference:

(
2)
(
3)
(
4)
(
5)
(
6)
(
7)
(
8)
(
9)
(
10)

Hours
Number
of
Hours
Per
Hours
Number
of
Hours
Per
Hours
per
Number
of
Responses
Year
per
Number
of
Responses
Year
per
Year
Item
Response
Respondents
Per
Year
(
2)*(
3)*(
4)
Response
Respondents
Per
Year
(
6)*(
7)*(
8)
(
9)­(
5)

IU
Compliance
Attainment
Report
­
New
Sources
2
20
1
**
41
2
18
1
**
37
­
4
­
Metal
Products
and
Machinery
2
45
1
**
91
2
0
1
**
0
­
91
­
PFRP
2
34
1
**
68
2
0
1
**
0
­
68
­
Centralized
Waste
Treaters
2
1
1
**
3
2
3
1
**
6
4
­
Pharmaceutical
Manufacturing
2
6
1
**
13
2
0
1
**
0
­
13
­
Industrial
Laundries
2
39
1
**
77
2
0
1
**
0
­
77
­
Transportation
Equipment
Cleanin
2
41
1
**
82
2
0
1
**
0
­
82
IU
Compliance
Reports
4
0
1
**
0
4
0
1
**
0
0
(
Resampling
Requirements)

IU/
SIU
Self­
Monitoring
Report
Categorical
SIUs
2
1,015
2
4,060
2
923
2
3,690
­
370
Non­
Categorical
SIUs
1
1,158
2
2,317
1
1,000
2
2,001
­
316
PFPR
P2
Alternative
­
Initial
Certification
10
3
1
*
34
10
0
1
*
0
­
34
­
Periodic
Certifications
0.25
10
2
5
0.25
0
2
0
­
5
­
Modifications
3
1
1
3
3
0
1
0
­
3
IU
Slug
Load
Notification
0.25
7
1
#
2
0.25
6
1
#
2
0
(
Categorical)

IU
Slug
Load
Notification
0.25
31
1
#
8
0.25
28
1
#
7
­
1
(
Non­
Categorical)

Notification
of
Changed
2
68
1
#
136
2
62
1
#
123
­
13
Discharge
Annual
POTW
Reports***
20
969
1
19,372
20
1,070
1
21,400
2,028
D­
8
National
Pretreatment
Program
ICR
March
21,
2003
Previous
Calculations
(
2000):
Current
Calculations
(
2003):
Difference:

(
2)
(
3)
(
4)
(
5)
(
6)
(
7)
(
8)
(
9)
(
10)

Hours
Number
of
Hours
Per
Hours
Number
of
Hours
Per
Hours
per
Number
of
Responses
Year
per
Number
of
Responses
Year
per
Year
Item
Response
Respondents
Per
Year
(
2)*(
3)*(
4)
Response
Respondents
Per
Year
(
6)*(
7)*(
8)
(
9)­(
5)

Inspection
and
Sampling
0.5
1,535
21
15,981
0.5
1,469
21
15,586
­
395
of
IU
and
SIU
Effluent
Prevention
and
Control
1
21
1
21
1
4
1
4
­
17
Plan
for
Spills
and
Batch
Discharges
Evaluation
of
the
Need
to
1
194
##
1
194
1
214
##
1
214
20
Revise
Local
Limits***

Excellence
Award
Program
1.2
25
1
30
1.2
29
1
35
5
Information***

Categorical
Determination
N/
A
N/
A
N/
A
N/
A
N/
A
N/
A
N/
A
N/
A
0
Request*
Alternative
Limits
Modification
2
19
1
37
2
2
1
4
­
33
Fundamentally
Different
Factors
N/
A
N/
A
N/
A
N/
A
N/
A
N/
A
N/
A
N/
A
0
Variance
Request*

Net/
Gross
Adjustment
Request
10
6
1
**
62
10
2
1
**
20
­
42
Removal
Credit
80
3
1
**
247
80
3
1
**
233
­
14
Approval
Request***

Removal
Credit
1
16
1
16
1
18
1
18
2
Self­
Monitoring
Report***

TOTAL
ALL
ITEMS
51,702
48,622
­
3,121
Note:
Values
in
spreadsheet
generally
do
not
display
decimals,
however
decimals
are
carried
through
in
all
calculations.

*
All
burden
for
this
activity
will
fall
on
the
Federal
Government.

**
These
are
one­
time
only
reporting
requirements.
The
total
number
of
respondents
anticipated
over
the
next
three
years
has
been
spread
out
over
the
three­
year
time
span
for
calc
of
average
annual
burden.

***
For
these
activities,
burden
is
apportioned
to
the
States
only
where
the
State
is
the
Approval
Authority.

#
These
reporting
requirements
are
based
on
events
that
occur
sporadically,
if
at
all.
A
single
response
is
all
that
is
required
for
each
occurrence.

##
Control
Authorities
evaluate
the
need
to
revise
local
limits
once
every
five
years.
Therefore,
the
number
of
respondents
divided
by
5
to
obtain
the
average
annual
burden.

D­
8
National
Pretreatment
Program
ICR
March
21,
2003
Table
9.
Labor
Hours
for
POTWs
as
Users
of
the
Data
Previous
Calculations
(
2000):
Current
Calculations
(
2003):
Difference:

(
2)
(
3)
(
4)
(
5)
(
6)
(
7)
(
8)
(
9)
(
10)

Hours
Number
of
Hours
Per
Hours
Number
of
Hours
Per
Hours
per
Number
of
Responses
Year
per
Number
of
Responses
Year
per
Year
Item
Response
Respondents
Per
Year
(
2)*(
3)*(
4)
Response
Respondents
Per
Year
(
6)*(
7)*(
8)
(
9)­(
5)

Baseline
Monitoring
Report
­
New
Sources
24
278
1
6,678
24
281
1
6,733
55
­
Metal
Products
and
Machinery
24
621
1
14,912
24
0
1
0
­
14,912
­
PFPR
24
466
1
11,184
24
0
1
0
­
11,184
­
Centralized
Waste
Treaters
24
17
1
418
24
0
1
0
­
418
­
Pharmaceutical
Manufacturing
24
89
1
2,132
24
0
1
0
­
2,132
­
Industrial
Laundries
24
528
1
12,675
24
0
1
0
­
12,675
­
TEC
24
559
1
13,421
24
0
1
0
­
13,421
IU
Compliance
Attainment
Report
­
New
Sources
2
278
1
557
2
281
1
561
5
­
Metal
Products
and
Machinery
2
621
1
1,243
2
0
1
0
­
1,243
­
PFPR
2
466
1
932
2
0
1
0
­
932
­
Centralized
Waste
Treaters
2
17
1
35
2
47
1
94
60
­
Pharmaceutical
Manufacturing
2
89
1
178
2
0
1
0
­
178
­
Industrial
Laundries
2
528
1
1,056
2
0
1
0
­
1,056
­
TEC
2
559
1
1,118
2
0
1
0
­
1,118
IU
Compliance
Reports
4
0
1
*
0
4
0
1
*
0
0
(
Resampling
Requirements)

IU/
SIU
Self­
Monitoring
Report
Categorical
SIUs
2
13,913
2
55,652
2
14,031
2
56,126
474
Non­
Categorical
SIUs
1
15,876
2
31,751
1
15,218
2
30,435
­
1,316
PFPR
P2
Alternative
­
Initial
Certification
10
47
1
*
466
10
0
1
*
0
­
466
­
Periodic
Certifications
0.25
140
2
70
0.25
0
2
0
­
70
­
Modifications
3
14
1
42
3
0
1
0
­
42
IU
Slug
Load
Notification
0.25
93
1
**
23
0.25
94
1
**
23
0
(
Categorical)

IU
Slug
Load
Notification
0.25
419
1
**
105
0.25
422
1
**
106
1
(
Non­
Categorical)

Notification
of
Changed
2
932
1
**
1,864
2
938
1
**
1,877
13
Discharge
Prevention
and
Control
1
288
1
288
1
63
1
63
­
224
Plan
for
Spills
and
Batch
Discharges
Alternative
Limits
Modification
2
256
1
512
2
33
1
66
­
446
TOTAL
ALL
ITEMS
157,311
96,084
­
61,227
Note:
Values
in
spreadsheet
generally
do
not
display
decimals,
however
decimals
are
carried
through
in
all
calculations.

**
These
reporting
requirements
are
based
on
events
which
occur
sporadically,
if
at
all.
A
single
response
is
all
that
is
required
for
each
occurrence.

*
These
are
one­
time
only
reporting
requirements.
The
total
number
of
respondents
anticipated
over
the
next
three
years
has
been
spread
out
over
the
three­
year
time
span
for
calculation
of
average
annual
burden.
D­
9
National
Pretreatment
Program
ICR
March
21,
2003
Table
10.
Labor
Hours
for
Federal
Government
As
Users
of
the
Data
Previous
Calculations
(
2000):
Current
Calculations
(
2003):
Difference:

(
2)
(
3)
(
4)
(
5)
(
6)
(
7)
(
8)
(
9)
(
10)

Hours
Number
of
Hours
Per
Hours
Number
of
Hours
Per
Hours
per
Number
of
Responses
Year
per
Number
of
Responses
Year
per
Year
Item
Response
Respondents
Per
Year
(
2)*(
3)*(
4)
Response
Respondents
Per
Year
(
6)*(
7)*(
8)
(
9)­(
5)

State
Pretreatment
Program
325
1
1
*
325
325
0.3333333
1
*
108
­
217
Approval
Request
POTW
Pretreatment
Compliance
2
24
1
*
48
2
12
1
*
25
­
23
Schedule
Progress
Report**

POTW
Pretreatment
Program
40
5
1
*
211
40
4
1
*
167
­
44
Approval
Request**

POTW
Pretreatment
Program
20
113
1
2,266
20
80
1
1,596
­
670
Modification
Approval
Request**

Annual
POTW
Reports**
20
566
1
11,328
20
399
1
7,980
­
3,348
Evaluation
of
the
Need
to
1
113
1
113
1
80
1
80
­
33
Revise
Local
Limits**

Excellence
Award
Program
1.2
15
1
17
1.2
11
1
13
­
5
Information**

Categorical
Determination
20
18
1
*
366
20
0
1
*
0
­
366
Request
Fundamentally
Different
Factors
400
6
1
*
2,400
400
3
1
*
1,200
­
1,200
Variance
Request
Removal
Credit
80
2
1
*
121
80
1
1
*
87
­
34
Approval
Request**

Removal
Credit
1
9
1
9
1
7
1
7
­
2
Self­
Monitoring
Report**

TOTAL
ALL
ITEMS
17,205
11,262
­
5,943
Note:
Values
in
spreadsheet
generally
do
not
display
decimals,
however
decimals
are
carried
through
in
all
calculations.

*
These
are
one­
time
only
reporting
requirements.
The
total
number
of
respondents
anticipated
over
the
next
three
years
has
been
spread
out
over
the
three­
year
time
span
for
calculation
of
average
annual
burden.

**
For
these
activities,
burden
is
apportioned
to
the
Federal
Government
only
where
the
Federal
Government
is
the
Approval
Authority.

D­
9
National
Pretreatment
Program
ICR
March
21,
2003
Table
11.
Total
Average
Annual
Respondent
Burden
and
Costs
Annual
Burden
Hours
Annual
Costs
Respondent
reporting
burden
2,107,586
$
87,546,313
Respondent
recordkeeping
burden
222,217
$
7,580,640
144,706
$
3,896,046
Total
2,474,508
$
99,022,998
Note:
Federal
Government
incurs
a
burden
of
11,262
hours
as
user
of
the
data
(
see
Table
10)
State
and
Municipal
Government
burden
(
Users
of
the
Data)

D­
11
