FINAL
DRAFT
INFORMATION
COLLECTION
REQUEST
FOR
THE
COMBINED
SEWER
OVERFLOW
CONTROL
POLICY
OMB
No.
2040­
0170;
EPA
ICR
No.
1680.03
November
2000
Prepared
for:

UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
OFFICE
OF
WATER
OFFICE
OF
WASTEWATER
MANAGEMENT
MC
4203M
ARIEL
RIOS
BUILDING
1200
PENNSYLVANIA
AVENUE,
NW
WASHINGTON,
DC
20460
Prepared
by:

Limno­
Tech,
Inc.
1705
De
Sales
Street,
NW
Suite
600
Washington,
DC
20036
EPA
Contract
No.
68­
C­
00­
116
EPA
Work
Assignment
No.
WW­
0­
1
TABLE
OF
CONTENTS
1.0
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
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1
1(
a)
Title
of
the
Information
Collection
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1
1(
b)
Short
Characterization/
Abstract
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1
2.0
NEED
FOR
AND
USE
OF
THE
COLLECTION
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4
2(
a)
Need
For
The
Information
Collection
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4
2(
b)
Use
and
Users
Of
The
Data
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5
3.0
NON­
DUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
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6
3(
a)
Non­
Duplication
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6
3(
b)
Public
Notice
Required
Prior
to
OMB
Submission
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6
3(
c)
Consultations
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6
3(
d)
Minimizing
Burden
and
the
Effects
of
Less
Frequent
Reporting
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7
3(
e)
General
Guidelines
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7
3(
f)
Confidentiality
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8
3(
g)
Sensitive
Questions
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8
4.0
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
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9
4(
a)
Respondents'
Standard
Industrial
Classification
(
SIC)
Codes
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9
4(
b)
Information
Requested
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9
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i)
Nine
Minimum
Controls
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10
(
ii)
Long­
Term
CSO
Control
Plans
and
Supplementary
Information
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10
(
iii)
Compliance
Monitoring
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11
4(
c)
Respondent
Activities
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12
(
i)
Nine
Minimum
Control
Measures
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12
(
ii)
Long­
Term
CSO
Control
Plan
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12
(
iii)
Compliance
Monitoring
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13
4(
d)
Consideration
of
Alternatives
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13
5.0
THE
INFORMATION
COLLECTED
 
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
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14
5(
a)
Agency
And
Approved
NPDES
State
Activities
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14
5(
b)
Review
of
Municipal
Submittals
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14
5(
c)
Collection
Methodology
and
Management
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15
5(
d)
Small
Entity
Flexibility
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15
5(
e)
Collection
Schedule
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15
6.0
ESTIMATING
THE
BURDEN
AND
COST
OF
COLLECTION
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16
6(
a)
Estimated
Respondent
Burden
And
Cost
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16
(
i)
Nine
Minimum
Control
Measures
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16
(
ii)
Long­
Term
CSO
Control
Plan
Burden
and
Cost
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23
(
iii)
Compliance
Monitoring
Burden
and
Cost
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25
6(
b)
Estimated
Government
Burden
And
Costs
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27
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i)
State
and
Federal
Government
Tally
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27
6(
c)
Bottom
Line
Burden
Hours
and
Costs
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29
6(
d)
Reason
for
Change
in
Burden
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29
6(
e)
Burden
Statement
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30
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LIST
OF
EXHIBITS
Exhibit
6­
1.
Estimated
Burden
and
Cost
of
Documenting
the
Nine
Minimum
Control
Measures
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18
Exhibit
6­
2.
Estimated
Burden
Calculation
for
Public
Notification
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22
Exhibit
6­
3.
Estimated
Burden
and
Cost
of
Writing
Long­
Term
CSO
Control
Plans
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23
Exhibit
6­
4.
Estimated
Burden
and
Cost
of
Compliance
Monitoring
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27
Exhibit
6­
5.
Estimated
State
Burden
and
Cost
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32
Exhibit
6­
6.
Estimated
Federal
Burden
and
Cost
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33
Exhibit
6­
7.
Estimated
Bottom
Line
Burden
Hours
and
Costs
Summary
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34
ii
1
1.0
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
of
the
Information
Collection
This
renewal
ICR
is
titled
"
Information
Collection
Request
for
the
Combined
Sewer
Overflow
Control
Policy."

1(
b)
Short
Characterization/
Abstract
The
purpose
of
this
renewal
ICR
estimates
the
information
collection
burden
associated
with
the
Combined
Sewer
Overflow
(
CSO)
Control
Policy.
The
Policy
is
issued
as
a
guidance
to
National
Pollution
Discharge
Elimination
System
(
NPDES)
permitting
and
enforcement
authorities,
State
water
quality
standards
authorities,
municipalities
with
combined
sewer
systems,
and
other
stakeholders.
It
recommends
a
consistent
approach
to
controlling
CSOs
that
is
flexible
enough
to
take
into
account
individual
combined
sewer
system
characteristics,
past
CSO
control
efforts,
and
the
financial
capability
of
the
municipality.
The
Policy
recommends
a
national
framework
for
bringing
CSOs
into
compliance
with
the
CWA
and
for
achieving
compliance
with
applicable
State
water
quality
standards
(
WQS).

The
main
activities
for
municipalities
under
the
Policy
include
(
1)
documentation
of
the
implementation
of
the
nine
minimum
controls,
(
2)
development
and
implementation
of
a
long­
term
Control
Plan
(
LTCP),
and
(
3)
compliance
monitoring
and
reporting
to
demonstrate
the
combined
sewer
system
is
in
continuing
compliance
with
State
WQS
and
NPDES
permit
conditions.

In
most
cases,
the
Policy
envisions
that
municipal
activities
will
be
carried
out
through
the
NPDES
permitting
process.
However,
NPDES
authorities
may
use
other
tools
(
e.
g.,
§
308
information
requests)
to
require
that
municipalities
develop
and
implement
CSO
control
programs
and
to
require
that
municipalities
submit
the
information
necessary
to
determine
that
the
Policy
is
being
implemented.
This
renewal
ICR
estimates
the
total
burden
and
cost
associated
with
information
collection
and
reporting
under
the
CSO
Control
Policy.

According
to
5
CFR
1320,
ICRs
should
include
not
only
the
reporting
burden,
but
also
the
burden
to
gather
any
required
information
necessary
to
meet
information
requests
that
is
not
readily
available.
Gathering
includes
monitoring,
surveying,
testing
and
similar
activities.
2
The
cost
and
burden
for
installing
the
nine
minimum
control
measures
and
for
installing
control
measures
identified
in
the
LTCP
are
beyond
the
scope
of
5
CFR
1320.
The
burden
to
collect
sufficient
information
to
document
the
nine
minimum
control
measures
and
to
evaluate
alternatives
under
the
LTCP
is
included
in
the
renewal
ICR.
Capital
costs
for
CSO
controls
are
estimated
in
EPA's
1996
Needs
Survey.
In
accordance
with
the
Paperwork
Reduction
Act
of
1995,
the
capital
costs
associated
with
public
notification
of
CSO
locations,
events
and
public
health
and
environmental
impacts
are
included.

State
activities
under
the
Policy
include
permit
development
and
reissuance,
and
review
of
NMC
documentation,
LTCPs,
and
CSO
monitoring
data
in
discharge
monitoring
reports
(
DMRs).
Federal
activities
include
the
same
activities
and
the
review
of
State
information
submitted
to
EPA
for
developing
the
performance
reports
under
the
Government
Performance
and
Results
Act.

For
this
ICR,
EPA
estimates
burden
and
costs
associated
for
permittee,
State,
and
federal
authorities
affected
by
the
Combined
Sewer
Overflow
Control
Policy.
This
ICR
estimates
a
total
nationwide
burden
of
1,740,131
hours
and
a
cost
of
$
61,444,026
associated
with
information
collection
burdens,
that
will
be
spread
over
a
three­
year
period.

Nationwide
approximately
900
municipalities
in
30
States
and
9
EPA
Regions
have
CSSs
that
may
have
CSOs
and
are
affected
by
the
Policy.

Combined
sewer
systems
(
CSSs)
are
wastewater
collection
systems
which
convey
sanitary
wastewaters
(
domestic,
commercial,
and
industrial
wastewaters)
and
storm
water
through
a
single
pipe
to
publicly­
owned
treatment
works
(
POTWs).
A
combined
sewer
overflow
is
a
discharge
from
a
CSS
at
a
point
prior
to
the
POTW
treatment
plant.
CSOs
are
classified
as
point
sources
subject
to
National
Pollution
Discharge
Elimination
System
(
NPDES)
permit
requirements.
CSOs
are
not
subject
to
secondary
treatment
requirements
applicable
to
POTWs.

CSOs
often
contain
high
levels
of
suspended
solids,
bacteria
and
other
pathogens,

toxic
pollutants,
floatables,
nutrients,
oxygen
demanding
organic
compounds,
oil
and
grease,

and
other
pollutants.
CSOs
can
cause
exceedances
of
water
quality
standards
(
WQS).
Such
exceedances
may
pose
risks
to
human
health,
threaten
aquatic
life
and
its
habitat,
and
impair
the
use
of
the
nation's
waterways.

In
the
United
States
there
are
approximately
900
CSSs.
The
systems
are
located
primarily
in
the
northeast
and
northern
Midwest
regions;
92
percent
of
the
outfalls
are
in
EPA
3
Regions
1,
2,
3,
and
5.
Approximately
62
percent
of
CSSs
serve
10,000
people
or
less.
Only
seven
percent
of
the
systems
serve
populations
greater
than
100,000.
These
larger
systems,

however,
account
for
approximately
70
percent
of
the
total
population
served
by
CSSs.

In
1989
EPA's
Office
of
Water
established
the
National
Combined
Sewer
Overflow
Control
Strategy
(
54
Federal
Register
37370)
and
in
April
1994
issued
its
National
CSO
Control
Policy
(
59FR
18688).
This
Policy
provides
guidance
to
permittees
with
CSOs,

NPDES
permitting
authorities,
State
water
quality
standards
authorities
and
NPDES
enforcement
authorities.
The
purpose
of
the
Policy
is
to
coordinate
the
planning,
selection,

design,
and
implementation
of
CSO
control
programs
to
meet
the
requirements
of
the
CWA
and
to
involve
the
public
in
the
decision­
making
process.
The
Policy
represents
a
comprehensive
national
strategy
to
ensure
that
municipalities,
permitting
authorities,
WQS
authorities,
and
the
public
engage
in
a
comprehensive
and
coordinated
planning
effort
to
achieve
cost­
effective
CSO
control
programs
that
meet
the
objectives
of
the
CWA.
The
Policy
recognizes
the
site­
specific
nature
of
CSOs
and
their
impacts
and
provides
the
necessary
flexibility
to
develop
a
control
plan
tailored
to
local
situations.

This
ICR
addresses
six
broad
areas
of
information
collection
burdens:

a)
the
information
collection
costs
to
municipalities
to
implement
and
document
implementation
of
the
nine
minimum
controls,

b)
the
information
collection
costs
to
municipalities
to
develop
long
term
CSO
control
plans
(
LTCPs)
consistent
with
the
expectations
in
the
CSO
Control
Policy,

c)
the
information
collection
costs
to
municipalities
to
implement
a
postconstruction
compliance
monitoring
program,

d)
the
burden
on
EPA
and
States
to
review
and
evaluate
the
information
submitted
by
municipalities,

e)
the
burden
on
municipalities
for
third­
party
notification
associated
with
one
of
the
nine
minimum
controls,
and
f)
the
burden
on
States
with
approved
NPDES
programs
to
issue/
reissue
NPDES
permits
or
other
enforceable
mechanisms
requiring
municipalities
to
implement
the
recommendations
in
the
CSO
Policy.
4
Activities
associated
with
costs
a)
and
b)
above
are
one­
time
efforts
and
are
being
completed
largely
through
the
NPDES
permitting
processes.
For
purposes
of
estimating
annual
burden,
EPA
assumes
that
these
one­
time
activities
will
occur
over
a
three­
year
period
consistent
with
the
approval
period
of
this
renewal
ICR.
The
only
burden
for
CSO
requirements
in
the
NPDES
base
ICRs
is
in
the
Discharge
Monitoring
Reports
(
DMR)
ICR
(
2040­
0004)
which
includes
a
burden
of
96
hours
per
combined
sewer
system
per
year
for
monitoring
and
reporting.

2.0
NEED
FOR
AND
USE
OF
THE
COLLECTION
EPA
needs
the
information
described
in
this
ICR
to
ensure
that
municipalities
are
developing
and
implementing
CSO
control
programs
that
are
consistent
with
the
objectives
of
the
CSO
Control
Policy
and
to
determine
whether
the
EPA's
national
CSO
control
program
is
achieving
its
performance
goals
established
under
the
Government
Performance
and
Results
Act.

2(
a)
Need
For
The
Information
Collection
Under
Section
301(
a)
of
the
Clean
Water
Act
(
CWA),
the
discharge
of
any
pollutant
from
a
point
source
into
a
water
of
the
United
States
is
"
unlawful"
unless
in
accordance
with
the
Act.
Section
402
of
the
Clean
Water
Act
as
amended,
33
USC
1342
et
seq.
authorizes
EPA
to
issue
a
permit
for
the
discharge
of
any
pollutant
subject
to
certain
terms
and
conditions,
including
effluent
limitations.

The
information
collection
activities
described
in
this
ICR
provide
the
minimum
data
necessary
for
the
Federal
government
to
assure
that
all
municipalities
with
CSSs
are:

(
1)
developing
and
implementing
CSO
control
programs
that
are
consistent
with
the
CSO
Control
Policy
and
(
2)
that
these
CSO
control
programs
will
meet
the
requirements
of
the
Clean
Water
Act
and
will
achieve
compliance
with
applicable
State
water
quality
standards.

2(
b)
Use
and
Users
Of
The
Data
Information
submitted
by
municipalities
under
the
Policy
will
provide
NPDES
authorities
(
EPA
Regions
and
States
with
approved
NPDES
programs)
with
the
necessary
information
to
determine
whether
a
municipality's
CSO
control
program
is
adequate
to
achieve
compliance
with
CWA
requirements
and
applicable
State
WQS,
to
establish
permit
terms
and
conditions
for
CSOs,
to
track
performance,
to
identify
and
assess
violations,
and
to
5
target
inspection
and
enforcement
actions.
The
information
will
also
be
used
by
Regions
and
States
to
develop
and
evaluate
the
success
of
their
CSO
Control
Strategies.
The
information
may
be
collected
through
the
NPDES
permitting
process,
§
308
information
request,
or
other
enforceable
means.

EPA
will
also
use
this
data
to
measure
its
performance
in
achieving
its
objectives
under
its
Performance
Plan
for
the
CSO
Control
Policy.
The
primary
outcome
of
the
performance
plan
for
the
CSO
control
program
is
measurable
progress
in
implementation
of
the
EPA's
CSO
Control
Policy.
The
information
that
will
be
collected
under
this
renewal
ICR
will
allow
EPA
to
measure
that
progress.
1
Combined
Sewer
Overflow
Work
Group
Policy
Dialogue
­
Final
Report,
RESOLVE,
March
1993.

6
3.0
NON­
DUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Non­
Duplication
This
Policy
and
this
renewal
ICR
address
only
those
municipalities
with
CSSs
that
have
CSOs.
The
information
collected
is
not
available
from
other
sources.
Any
system
that
has
substantially
developed
or
is
implementing
a
CSO
control
program
under
an
existing
enforceable
mechanism
may
not
be
subject
to
most
of
the
Policy's
planning
and
information
submission
requirements.

3(
b)
Public
notice
required
prior
to
ICR
submission
to
OMB.

In
compliance
with
the
1995
Paperwork
Reduction
Act
(
PRA),
any
agency
developing
a
non­
rule­
related
ICR
must
solicit
public
comments
for
a
60­
day
period
prior
to
submitting
the
ICR
to
OMB.
These
comments,
which
are
used
partly
to
determine
realistic
burden
estimates
for
respondents,
must
be
considered
when
completing
the
Supporting
Statement
that
is
submitted
to
OMB.
EPA
first
public
noticed
this
ICR
on
July
3,
2000
(
65
FR
41065
).

No
public
comments
were
received.

3(
c)
Consultations
In
developing
the
Policy,
EPA
arranged
for
a
CSO
Work
Group
under
the
Office
of
Water's
(
OW's)
Management
Advisory
Group
to
discuss
and
recommend
a
CSO
Control
Policy.
The
Work
Group
met
three
times
between
July
23
and
September
9,
1992.
Although
the
Work
Group
did
not
reach
a
complete
consensus
on
the
best
approach
for
the
CSO
Policy,

EPA
had
the
opportunity
to
hear
the
views
of
a
variety
of
interested
parties
and
was
able
to
incorporate
these
views
into
the
Policy1.
Entities
participating
in
the
Work
Group
included:

!
The
American
Public
Works
Association,

!
The
Association
of
Metropolitan
Sewerage
Authorities,

!
The
Association
of
State
and
Interstate
Water
Pollution
Control
Administrators
(
ASIWPCA),

!
The
Center
for
Marine
Conservation,

!
The
Chemical
Manufacturers
Association
(
CMA),
7
!
The
CSO
Partnership,

!
The
Environmental
Defense
Fund,

!
The
Lower
James
River
Association,

!
The
National
League
of
Cities
(
NLC),

!
The
Natural
Resources
Defense
Council
(
NRDC),
and
!
Sewage
Treatment
Out
of
the
Park
(
STOP).

The
Agency
believes
that
the
Policy
is
a
comprehensive
approach
that
is
both
flexible
and
effective.
The
flexibility
means
that
permitting
authorities
will
be
able
to
tailor
permit
conditions
to
each
CSO
municipality's
unique
characteristics.

3(
d)
Minimizing
Burden
and
the
Effects
of
Less
Frequent
Reporting
In
developing
the
Policy,
the
Office
of
Water
(
OW)
carefully
considered
the
need
to
balance
environmental
protection
with
the
resources
of
municipalities.
The
Policy
contains
flexibility
in
the
timing
of
control
installation
based
on
the
financial
capability
of
the
responding
municipality.
In
addition,
NPDES
permitting
authorities
may
reduce
the
reporting
burden
of
small
CSO
municipalities
(
less
than
75,000
persons
served
by
the
CSS).

Less
than
semi­
annual
reporting
of
CSO
compliance
monitoring
data
in
DMRs
will
limit
EPA's
ability
to
prepare
the
reports
that
are
required
to
show
the
progress
that
Agency
is
making
in
achieving
the
annual
GPRA
performance
objectives
established
for
the
CSO
control
program.

3(
e)
General
Guidelines
None
of
the
Policy's
provisions
exceed
Paperwork
Reduction
Act
guidelines
for
response
time.
During
emergencies,
POTW
operators
(
including
those
operating
CSSs)
may
bypass
their
systems
pursuant
to
40
CFR
122.41.
If
such
a
bypass
occurs,
the
system
operator
must
notify
EPA
within
24
hours,
which
exceeds
the
maximum
reporting
frequencies
specified
at
5
CFR
1320.
This
requirement
is
part
of
existing
regulations
addressed
in
the
NPDES
compliance
assessment
ICR
(
OMB
Control
No.
2040­
0110);
it
is
not
addressed
in
this
ICR.
8
3(
f)
Confidentiality
The
information
collected
under
the
Policy
includes
no
confidential
information,
such
as
proprietary
formulas
or
techniques,
because
all
respondents
are
public
entities.
In
addition,

the
information
is
collected
for
the
Agency's
internal
use
and
to
prepare
the
performance
reports
required
by
the
Government
Performance
and
Results
Act.

3(
g)
Sensitive
Questions
There
are
no
sensitive
questions
associated
with
this
renewal
ICR.
9
4.0
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
The
primary
respondents
to
the
Policy
will
be
municipalities
with
CSSs
that
have
CSOs
and
States
with
approved
NPDES
programs
which
have
jurisdiction
over
those
municipalities.

Nationwide,
approximately
900
municipalities
in
nine
EPA
Regions
and
30
States
have
CSSs
and
are
subject
to
the
Policy.
In
the
majority
of
Regions
and
States,
CSO
requirements
are
included
in
NPDES
permits.
In
States
and
EPA
Regions
where
municipalities
are
implementing
or
have
already
implemented
CSO
control
programs,
the
Policy
will
impose
a
reduced
burden.
The
Policy
will
result
in
a
larger
impact
on
municipalities
that
have
not
yet
begun
to
implement
the
CSO
Control
Policy.

The
following
sections
identify
respondents
and
list
the
data
collection
and
other
associated
activities
that
States
and
municipalities
are
subject
to
under
the
Policy.
This
renewal
ICR
updates
the
incremental
burden
and
costs
associated
with
the
CSO
policy,
not
those
associated
with
overall
NPDES
program.
Note
that
the
facilities
potentially
affected
by
the
Policy
are
a
subset
of
the
larger
universe
of
facilities
covered
by
the
Agency's
NPDES
program,
so
it
is
assumed
that
the
universe
of
NPDES
respondents
will
not
increase
by
virtue
of
the
Policy
being
implemented.

4(
a)
Respondents'
Standard
Industrial
Classification
(
SIC)
Codes
The
Policy
will
affect
approximately
900
municipalities
with
CSSs,
and
the
NPDES
authorities
which
are
responsible
for
implementing
the
CSO
Control
Policy.
The
SIC
code
for
municipal
sewerage
systems
is
4952,
within
Industry
Group
495
(
Sanitary
Services)
and
Major
Group
49
(
Electric,
Gas,
and
Sanitary
Services).
Governmental
environmental
agencies
have
an
SIC
code
of
951.

4(
b)
Information
Requested
There
are
two
types
of
information
collections
for
permittees
with
CSSs
described
in
the
Policy:
(
1)
those
associated
with
one­
time
activities,
including
documenting
the
nine
minimum
controls
and
developing
a
LTCP,
and
(
2)
those
associated
with
on­
going
activities,

such
as
compliance
monitoring
and
record
keeping.
10
(
i)
Nine
Minimum
Controls
The
CSO
Control
Policy
recommends
that
municipalities
implement
the
nine
minimum
controls
(
NMC)
and
submit
documentation
demonstrating
their
implementation
activities.

NPDES
permitting
authorities
generally
require
this
activity
as
a
NPDES
permit
condition.

The
Policy
recommended
that
this
documentation
be
submitted
within
two
years
after
this
requirement
is
included
in
a
NPDES
permit
or
other
enforceable
mechanism.
The
NMC
identified
in
the
Policy
are:

1.
Proper
operation
and
regular
maintenance
programs
for
the
collection
system
and
the
CSOs,

2.
Maximum
use
of
the
collection
system
for
storage,

3.
Review
and
modification
of
pretreatment
requirements
to
ensure
that
CSO
impacts
are
minimized,

4.
Maximization
of
flow
to
the
POTW
for
treatment,

5.
Elimination
of
CSOs
during
dry
weather,

6.
Control
of
solid
and
floatable
materials
in
CSOs,

7.
Pollution
prevention
programs
to
reduce
contaminants
in
CSOs,

8.
Public
notification
to
ensure
that
the
public
receives
adequate
notification
of
CSO
occurrences
and
CSO
impacts,
and
9.
Monitoring
to
effectively
characterize
CSO
impacts
and
the
efficacy
of
CSO
controls.

In
May
1995,
EPA
issued
a
guidance
manual
(
Combined
Sewer
Overflows:
Guidance
for
Nine
Minimum
Controls,
EPA
832­
B­
95­
003)
that
provides
municipalities
and
NPDES
permitting
authorities
with
information
relating
to
the
implementation
of
each
of
the
NMC
and
with
examples
of
appropriate
documentation
for
demonstrating
implementation
of
each
NMC.

(
ii)
Long­
Term
CSO
Control
Plans
and
Supplementary
Information
The
CSO
Control
Policy
recommends
to
permit
writers
that
permittees
develop
and
submit
a
LTCP
within
two
years
after
the
inclusion
of
LTCP
requirements
in
a
NPDES
permit
or
other
enforceable
mechanism.
A
LTCP
should
contain
the
following
components:

!
Sewer
System
Characterization,
Monitoring,
and
Modeling
!
Evaluation
of
Alternatives
!
Cost/
Performance
Considerations
!
Consideration
of
Sensitive
Areas
11
!
Maximize
Treatment
at
the
POTW
Treatment
Plant
!
Operational
Plan
!
Public
Participation
!
Implementation
Schedule
!
Post­
Construction
Compliance
Monitoring
Program
In
September
1995,
EPA
issued
a
guidance
document
(
Combined
Sewer
Overflows:

Guidance
for
Long
Term
Control
Plan,
EPA
832­
B­
95­
002)
to
assist
municipalities
with
the
development
of
LTCPs
that
are
consistent
with
the
CSO
Control
Policy
and
to
provide
NPDES
permitting
authorities
with
useful
information
for
reviewing
LTCP
submittals.
LTCPs
should
recognize
the
site­
specific
nature
of
CSOs
and
their
impacts
on
receiving
waters.
The
guidance
document
describes
how
to
develop
a
LTCP
that
includes
technology­
based
and
water
quality­
based
control
measures
that
are
technically
feasible,
affordable,
and
consistent
with
the
Policy.

(
iii)
Compliance
Monitoring
The
Policy
recommends
that
municipalities
develop
compliance
monitoring
programs
to
document
compliance
with
applicable
State
water
quality
standards,
protection
of
designated
uses,
and
to
measure
the
effectiveness
of
CSO
control
programs
after
they
are
implemented.

The
NPDES
permitting
authority
should
approve
the
compliance
monitoring
program
as
part
of
the
LTCP
review
process.
During
the
term
of
this
renewal
ICR,
municipalities
will
collect
and
submit
to
the
NPDES
permitting
authority,
information
on
the
sampling
and
analysis
of
pollutants
in
CSOs
and
the
impacts
of
CSOs
on
the
quality
of
the
recovering
waters.

In
January
1999,
EPA
issued
a
guidance
document
(
Combined
Sewer
Overflows
Guidance
for
Monitoring
and
Modeling,
EPA
832­
B­
99­
002)
to
provide
municipalities
with
a
set
of
general
guidelines
for
developing
a
site­
specific
monitoring
and
modeling
strategy
for
characterizing
combined
sewer
system
operations
and
impacts
and
for
developing
and
implementing
a
LTCP.
The
guidance
document
presents
a
suggested
framework
for
monitoring
and
modeling
but
is
not
a
"
how­
to"
manual
defining
how
many
samples
to
collect
or
which
flow
metering
technologies
to
use.

4(
c)
Respondent
Activities
Sections
(
i),
(
ii),
and
(
iii)
describe
the
activities
outlined
in
the
Policy
as
CSO
permit
requirements.
According
to
5
CFR
1320,
ICRs
should
include
not
only
the
reporting
burden,

but
also
the
burden
to
gather
any
information
that
is
not
readily
available.
Gathering
includes
12
monitoring,
surveying,
testing
and
similar
activities.
Burden
and
cost
estimates
for
Policy
activities
are
provided
in
Section
6.0.

Information
collection
and
activities
that
qualify
as
"
customary
and
usual
business
practice"
are
exempt
from
further
burden
and
cost
analysis.

In
documenting
the
nine
minimum
controls
and
developing
a
LTCP,
the
permittee
will
perform
a
variety
of
activities
including
gathering
and
generating
information,
sampling
discharges
and
receiving
waters,
and
maintaining
records.
In
performing
compliance
monitoring,
the
permittee
will
sample
and
analyze
CSOs
for
pollutants
of
concern.
At
present,

the
pollutants
of
concern
are
assumed
to
be
fecal
coliform,
total
suspended
solids,
and
biochemical
oxygen
demand
(
BOD).

(
i)
Nine
Minimum
Control
Measures
The
burden
associated
with
documenting
the
nine
minimum
controls
will
result
from
recording
and
reporting
on
planned
or
implemented
activities
for
each
NMC.
The
municipality
will
need
to
gather
information
about
the
planned
or
completed
implementation
(
e.
g.,

information
on
how
the
public
is
notified
of
CSO
events),
assemble
that
information
into
a
report
format,
submit
the
information,
and
maintain
a
record
of
the
report
and
supporting
information
for
three
years.
In
most
cases,
and
with
the
exception
of
the
monitoring
measure,

the
record
keeping
requirement
will
result
in
small
burdens,
as
documenting
the
measures
will
not
require
extensive
discharge
or
water
quality
records.
It
is
assumed
that
while
record
keeping
for
the
basic
monitoring
measure
will
require
some
effort,
existing
databases
used
to
keep
track
of
the
POTWs
discharge
records
will
also
be
used
to
keep
track
of
the
basic
CSO
monitoring.
The
additional
record
keeping
burden
is
included
in
the
general
reporting
subsection
of
the
nine
minimum
controls
in
Section
6(
a).

(
ii)
Long­
Term
CSO
Control
Plan
Under
the
Policy,
the
municipality
should
submit
the
information
requested
under
the
LTCP
components,
including
characterizing
the
CSS
and
showing
that
it
considered
a
range
of
control
alternatives
using
either
the
presumption
approach
or
the
demonstration
approach
as
presented
in
the
CSO
control
policy.
The
NPDES
permitting
authority
will
generally
include
in
a
NPDES
permit
or
other
enforceable
mechanism,
a
schedule
for
the
submission
of
interim
deliverables
relating
to
the
LTCP.
Examples
of
interim
deliverables
include
a
report
on
system
characterization
activities,
a
report
on
the
evaluation
of
alternatives,
and
a
compliance
monitoring
program.
13
Ongoing
reporting
activities
associated
with
the
LTCP
allow
the
permittee
and
the
reviewer
to
check
progress
towards
meeting
the
requirements
of
the
CWA
and
complying
with
applicable
State
WQS.
These
activities
include
monitoring,
reporting,
and
record
keeping.

Specific
monitoring
activities
include
effluent
and
ambient
monitoring,
biological
assessments,

whole
effluent
toxicity
testing,
and
sediment
sampling.
These
activities
are
recorded
and
reported
according
to
the
monitoring
protocol
established
in
the
permit.

(
iii)
Compliance
Monitoring
As
municipalities
implement
various
CSO
control
measures
as
part
of
their
CSO
control
program,
they
will
initiate
compliance
monitoring
to
determine
their
progress
in
achieving
compliance
with
CWA
requirements
and
with
applicable
State
WQS.
Municipalities
will
sample
CSOs
and
analyze
the
samples
for
pollutant
concentrations
to
determine
compliance
with
applicable
permit
requirements.
They
will
also
perform
water
quality
monitoring
to
determine
compliance
with
applicable
State
WQS.

4(
d)
Consideration
of
Alternatives
As
discussed
in
greater
detail
in
Section
5(
b),
EPA
worked
closely
with
representatives
of
States,
affected
municipalities,
and
environmental
groups
to
produce
a
Policy
that
would
result
in
better
control
of
CSOs,
clarification
of
the
existing
regulations,
and
sufficient
flexibility
to
adapt
to
limited
municipal
resources
and
characteristics
of
individual
CSSs.
The
Agency
believes
that
the
resulting
Policy
is
a
comprehensive
approach
that
is
both
flexible
and
effective.
Flexibility
is
incorporated
into
the
Policy
so
that
NPDES
authorities
will
be
able
to
tailor
permits
and
other
enforceable
mechanisms
to
each
municipality's
site­
specific
circumstances.
In
the
long
run,
this
should
help
ensure
that
CWA
mandates
are
satisfied
while
minimizing
municipal
burden
and
cost.
14
5.0
THE
INFORMATION
COLLECTED
 
AGENCY
ACTIVITIES,

COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
And
Approved
NPDES
State
Activities
EPA
and
States
with
approved
NPDES
programs
have
authority
to
issue
permits
under
the
NPDES
program.
Of
approximately
900
municipalities
with
CSSs,
EPA
will
issue
approximately
75
CSO
permits,
while
States
are
responsible
for
the
remaining
825
permits.

The
Policy
clarifies
the
requirements
CSO
permits
should
contain.
There
are
four
main
CSO­
related
Agency
activities
discussed
below:
(
l)
issuing
NPDES
permits
or
other
enforceable
mechanism
to
the
remaining
municipalities
that
have
not
yet
received
them,
(
2)

review
of
nine
minimum
control
documentation
and
LTCPs,
(
3)
review
of
DMR
data
from
compliance
monitoring
activities,
and
(
4)
permit
oversight.
In
addition,
EPA
is
responsible
for
compiling
and
reviewing
summary
program
information
submitted
by
the
States.

5(
b)
Review
of
Municipal
Submittals
Review
burden
is
incurred
by
a
NPDES
authority
when
a
permittee
submits
CSO
materials
in
support
of
a
new,
modified
or
revised
permit,
or
in
response
to
other
mechanisms.

Following
is
a
description
of
the
reviews
to
be
performed
by
EPA
and
States:

!
Government
Review
of
Demonstration
of
Implementation
of
the
Nine
Minimum
CSO
Controls:
The
Policy
calls
for
CSO
municipalities
to
implement
the
nine
minimum
controls
and
then
submit
documentation
of
their
implementation
to
the
NPDES
authority.
NPDES
authorities
must
review
the
documentation
to
determine
whether
it
is
complete
and
accurate,
and
whether
the
nine
controls
have
been
implemented
in
accordance
with
NPDES
permit
requirements.

!
Government
Review
of
Long­
Term
CSO
Control
Plans
(
LTCP):
EPA
and
State
permitting
authorities
will
review
LTCPs
to
ascertain
whether
they
are
consistent
with
the
provisions
of
the
CSO
Control
Policy
and
that,
when
they
are
implemented,
the
selected
control
measures
will
achieve
compliance
with
applicable
State
WQS
and
meet
the
objectives
of
the
Clean
Water
Act.
15
!
Review
of
Compliance
Monitoring
Data:
NPDES
permitting
authorities
(
EPA
Regions
and
approved
States)
will
review
monitoring
data
for
CSOs
that
are
submitted
by
municipalities
in
response
to
a
requirement
in
a
NPDES
permit
or
other
enforceable
mechanism.

5(
c)
Collection
Methodology
and
Management
Municipalities
will
submit
NMC
documentation
and
LTCPs
as
one
time
submittals
in
response
to
a
requirement
in
a
NPDES
permit
or
other
enforceable
mechanism.
EPA
assumes
that
compliance
monitoring
data
will
be
submitted
semi­
annually
in
DMRs
in
response
to
a
NPDES
permit
requirement.
EPA
assumes
that
the
collected
compliance
monitoring
data
will
be
stored
in
existing
databases.

5(
d)
Small
Entity
Flexibility
To
assist
communities
with
CSSs
that
serve
populations
less
than
75,000,
EPA
recommends
that
NPDES
authorities
use
discretion
when
requiring
these
communities
to
develop
a
LTCP.
It
is
recommended
in
the
Policy
that
small
systems
be
required
to
document
implementation
of
the
nine
minimum
controls,
prepare
LTCPs
that
give
high
priority
to
controlling
overflows
to
sensitive
areas,
and
employ
public
participation
in
their
decision­
making
process.
The
intent
of
this
provision
is
to
focus
the
limited
resources
of
smaller
communities
on
controlling
CSOs.
Small
entities
will
conduct
compliance
monitoring.

The
extent
of
the
monitoring
should
be
reduced
because
the
systems
are
small
with
few
CSOs.

5(
e)
Collection
Schedule
The
policy
recommends
that
municipalities
have
up
to
two
years
from
issuance
of
permits
or
other
enforceable
mechanism
to
document
the
implementation
of
the
nine
minimum
controls
and
to
develop
and
submit
a
LTCP.
Complex
systems
can
be
provided
more
time
for
the
LTCP.
Generally
it
is
expected
that
these
requirements
will
be
incorporated
into
NPDES
permits
as
the
permits
come
up
for
reissuance.
NPDES
authorities
may
use
other
tools
to
initiate
the
CSO
planning
process
where
appropriate.
16
6.0
ESTIMATING
THE
BURDEN
AND
COST
OF
COLLECTION
6(
a)
Estimated
Respondent
Burden
And
Cost
This
renewal
ICR
assumes
that
the
average
annual
salary
for
a
municipal
employee
likely
to
be
analyzing
the
CSS
is
similar
to
that
of
a
federal
GS­
9,
Step
10
salary:
$
45,900.
At
2,080
hours
per
year,
the
hourly
rate
is
$
22.07.
Overhead
costs
are
assumed
to
add
an
additional
60
percent
to
the
cost,
or
$
13.24
per
hour.
The
assumed
total
hourly
cost
is
$
35.31.

According
to
5
CFR
1320,
ICRs
should
include
not
only
the
reporting
burden,
but
also
the
burden
to
gather
any
required
information
not
readily
available.
"
Gathering"
includes
monitoring,
surveying,
testing
and
similar
activities.

Since
the
renewal
ICR
was
approved
three
years
ago,
the
estimated
number
of
municipalities
with
CSSs
has
been
reduced
to
approximately
900.
This
reduction
is
the
result
of
data
and
information
collected
from
EPA
Regions
and
conversations
with
EPA
Regional
and
State
CSO
program
staff.

For
this
renewal
ICR,
the
percentage
of
small,
medium,
large,
and
very
large
systems
distributed
among
the
estimated
900
municipalities
with
CSSs
is
as
follows:
65%
of
the
communities
will
be
small
(
under
10,000
population),
25%
will
be
medium­
sized
(
populations
between
10,000
and
75,000),
8%
will
be
large
(
populations
between
75,000
and
400,000),

and
the
remaining
2%
will
be
very
large
(
populations
over
400,000)

(
i)
Nine
Minimum
Control
Measures
There
are
two
burdens
associated
with
documenting
implementation
of
the
nine
minimum
controls:
(
1)
the
burden
of
writing
a
report
documenting
the
implementation
of
the
controls,
and
(
2)
the
burden
of
gathering
the
information
necessary
to
document
that
the
controls
have
been
implemented.
The
cost
of
actually
implementing
a
control
measure,
for
example,
purchasing
netting
to
control
floating
debris,
is
not
included
in
the
ICR
because
it
is
not
an
information
collection
activity.

The
burden
of
collecting
information
to
support
the
documentation,
will
vary
widely
among
systems,
since
some
of
the
systems
may
already
have
available
information
and
others
may
not.
17
EPA
estimates
that
over
the
life
of
the
prior
ICRs,
58%
of
the
900
municipalities
with
CSSs
have
submitted
NMC
documentation
to
the
appropriate
NPDES
permitting
authority.

This
estimate
is
supported
by
information
from
EPA
Regional
and
NPDES
State
CSO
program
staff.
As
a
result
of
this
information,
EPA
is
estimating
that
the
remaining
42%
will
submit
the
necessary
documentation
over
the
next
three
years.
EPA
expects
that
378
municipalities
will
submit
this
information.
Of
these
systems,
245
small
communities,
95
medium
communities,
and
30
large
communities
will
need
to
gather
the
information
documenting
that
they
implemented
each
of
the
NMC.
No
very
large
communities
will
need
to
prepare
and
submit
reports
to
the
appropriate
NPDES
permitting
authority.

Exhibit
6­
1
presents
the
estimated
system
and
nation­
wide
costs
of
documenting
the
implementation
of
each
NMC
and
for
reporting
the
information
to
the
appropriate
NPDES
authority.
18
Exhibit
6­
1.
Estimated
Burden
and
Cost
of
Documenting
the
Nine
Minimum
Control
Measures
By
Control
Measure
By
System
Size
Nationwide
Total
Avg.
Per
System
Nationwide
Total
Avg.
Per
System
Hours
Systems
Cost
Burden
Cost
Burden
Cost
Burden
Cost
Burden
Operations
and
Maintenance
$
103,811
2,940
$
281
8
Small
4
245
$
34,604
980
$
141
4
Medium
8
95
$
26,836
760
$
282
8
Large
40
30
$
42,372
1,200
$
1,412
40
Maximize
Storage
of
System
$
207,623
5,880
$
561
16
Small
8
245
$
69,208
1,960
$
282
8
Medium
16
95
$
53,671
1,520
$
565
16
Large
80
30
$
84,744
2,400
$
2,825
80
Pretreatment
Programs
$
103,811
2,940
$
281
8
Small
4
245
$
34,604
980
$
141
4
Medium
8
95
$
26,836
760
$
282
8
Large
40
30
$
42,372
1,200
$
1,412
40
Maximize
Flow
to
the
POTW
$
207,623
5,880
$
561
16
Small
8
245
$
69,208
1,960
$
282
8
Medium
16
95
$
53,671
1,520
$
565
16
Large
80
30
$
84,744
2,400
$
2,825
80
Dry­
weather
Overflows
$
224,925
6,370
$
608
17
Small
18
245
$
155,717
4,410
$
636
18
Medium
8
95
$
26,836
760
$
282
8
Large
40
30
$
42,372
1,200
$
1,412
40
Control
Solids
and
Floatables
$
103,811
2,940
$
281
8
Small
4
245
$
34,604
980
$
141
4
Medium
8
95
$
26,836
760
$
282
8
Large
40
30
$
42,372
1,200
$
1,412
40
Pollution
Prevention
$
103,811
2,940
$
281
8
Small
4
245
$
34,604
980
$
141
4
Medium
8
95
$
26,836
760
$
282
8
Large
40
30
$
42,372
1,200
$
1,412
40
Public
Notification
$
103,811
2,940
$
281
8
Small
4
245
$
34,604
980
$
141
4
Medium
8
95
$
26,836
760
$
282
8
Large
40
30
$
42,372
1,200
$
1,412
40
Monitor
$
234,458
6,640
$
634
18
Small
16
245
$
138,415
3,920
$
565
16
Medium
16
95
$
53,671
1,520
$
565
16
Large
40
30
$
42,372
1,200
$
1,412
40
General
Reporting
$
300,841
8,520
$
813
23
Small
8
245
$
69,208
1,960
$
282
8
Medium
16
95
$
53,671
1,520
$
565
16
Large
80
30
$
84,744
2,400
$
2,825
80
Very
Large
240
11
$
93,218
2,640
$
8,474
240
Record
Keeping
$
269,768
7,640
$
729
21
Small
8
245
$
69,208
1,960
$
282
8
Medium
16
95
$
53,671
1,520
$
565
16
Large
80
30
$
84,744
2,400
$
2,825
80
Very
Large
160
11
$
62,146
1,760
$
5,650
160
Total
Per
System
Small
(
245)
$
743,984
21,070
$
3,037
86
Medium
(
95)
$
429,371
12,160
$
4,520
128
Large
(
30)
$
635,580
18,000
$
21,186
600
Very
Large
(
11)
$
155,364
4,400
$
14,124
400
All
Systems
(
381)
$
1,964,299
55,630
$
5,156
146
19
Cost
And
Burden
of
Third
Party
Notification
Under
the
CSO
Policy,
the
public
notification
provision
of
the
nine
minimum
controls
is
necessary
to
inform
the
public
of
the
location
of
CSO
outfalls,
the
actual
occurrences
of
CSOs,

the
possible
health
and
environmental
effects
of
CSOs,
and
the
recreational
or
commercial
activities
(
e.
g.,
swimming
and
shellfish
harvesting)
curtailed
as
a
result
of
CSOs.
Public
notification
is
of
particular
concern
at
beach
and
recreation
areas
directly
or
indirectly
affected
by
CSOs,
where
public
exposure
is
likely
to
be
significant.

The
CSO
Control
Policy
and
EPA's
guidance
documents
provide
considerable
flexibility
to
municipalities
in
implementing
the
public
notification
provision,
because
the
most
appropriate
mechanism
for
public
notification
will
vary
with
local
circumstances,
such
as
the
character
and
size
of
the
use
area
and
means
of
public
assess.
The
selected
measure
should
be
the
most
costeffective
measure
that
provides
reasonable
assurance
that
the
affected
public
is
informed
in
a
timely
manner.
Municipalities
will
choose
from
measures
that
include
posting
signs
at
affected
use
areas,
posting
signs
at
CSO
outfalls,
and
notices
in
newspapers
or
radio
broadcasts.

The
CSO
Control
Policy
acknowledges
the
resource
constraints
facing
smaller
municipalities
and
provides
relief
to
municipalities
with
populations
under
75,000
from
certain
long­
term
planing
and
evaluation
activities.

Implementation
of
the
nine
minimum
controls
is
expected
to
be
highly
site­
specific.
A
community's
means
of
notifying
the
public
about
CSO
occurrences
and
impacts
will
be
tailored
to
the
use
of
the
receiving
water
and
the
anticipated
level
of
public
exposure.
The
selected
measure
should
be
the
most
cost­
effective
measure
that
provides
reasonable
assurance
that
the
affected
public
is
informed
in
a
timely
manner.

Public
notification
will
be
provided
either
on
a
one­
time
basis
(
e.
g.,
through
posting
of
permanent
signs)
or
on
a
case­
by­
case
basis
(
e.
g.,
through
public
service
announcements)
as
necessary
to
protect
public
health
from
the
impacts
of
CSOs.
The
frequency
of
notification
is
that
necessary
to
provide
prompt
notification
of
CSO
occurrences
and
potential
impacts.

The
public
notification
provision
of
the
nine
minimum
controls
will
not
require
any
of
the
following:

!
Reporting
of
information
to
the
Agency;

!
Preparation
of
a
written
response
by
the
respondent;
20
!
Submittal
of
documentation
to
the
Agency,
other
than
documentation
demonstrating
implementation
of
the
nine
minimum
controls.

This
ICR
renewal
calculates
an
annual
nationwide
burden
of
$
604,963
for
affected
municipalities
to
notify
the
public
of
CSO
occurrences
and
impacts.
As
detailed
in
Exhibit
6­
2,

this
burden
comprises
$
422,838
for
operation
and
maintenance
(
3,992
hours
annually
to
install
and
maintain
notification
signs
and
provide
press
or
radio
advisories
regarding
CSO
occurrences
and
impacts),
and
$
182,125
for
capital
and
start­
up
cost
(
the
capital
cost
for
municipalities
to
purchase
notification
signs).

The
calculations
in
Exhibit
6­
2
reflect
the
following
assumptions:

(
1)
For
purposes
of
calculating
burden,
this
ICR
assumes
that
notification
will
take
either
of
three
forms:
permanent
signs
at
outfalls,
permanent
signs
at
beaches
or
other
public
exposure
areas,
or
press
or
radio
advisories.
Based
on
its
experience
to
date,
EPA
believes
that
the
vast
majority
of
CSO
communities
will
use
either,
or
some
combination
of,
these
methods
of
public
notification.

(
2)
Some
communities
already
have
procedures
in
place
to
warn
the
public
of
health
risks
from
CSOs
and
other
water
pollution
issues.
Many
have
long­
standing
provisions
to
notify
the
public
of
beach
closures
or
shell
fishing
restrictions,
for
example.
This
does
not
address
public
notification
that
is
provided
for
other
reasons,
such
as
local
public
health
ordinances,
that
are
not
attributable
to
the
CSO
Control
Policy.
EPA
believes
that
approximately
50
percent
of
cities
already
provide
notification.
Thus
EPA
estimates
that
50
percent
of
cities
already
provide
notification
directly
as
a
result
of
the
CSO
Policy.

(
3)
All
900
communities
with
combined
sewer
systems
should
have
procedures
in
place
to
notify
the
public
of
CSO
occurrences
and
impacts.
EPA
estimates
that,
of
the
communities
that
are
implementing
public
notification
procedures
as
a
result
of
the
CSO
Policy,
approximately
one­
quarter
will
incur
sign
installation
and/
or
replacement
costs
annually.

(
4)
EPA
assumes
that
communities
posting
CSO
outfalls
will
post
one
sign
per
outfall.
It
also
assumes
that
communities
posting
beaches
and
other
public
exposure
areas
will
post
five
signs
per
community.
21
(
5)
EPA
assumes
that
all
public
notification
activities
are
performed
by
in­
house
staff
and
none
are
contracted
out.
22
Exhibit
6­
2.
Estimated
Burden
Calculation
for
Public
Notification
LABOR
HOURS
LABOR
COST
CAPITAL
COST
TOTAL
COST
1.
Number
of
cities
with
CSOs:
900
2.
Percentage
of
cities
providing
public
notification
per
CSO
Policy
50%

3.
Number
of
respondents
=
(
1)
x
(
2):
450
4.
Labor
cost,
per
hour:
$
35.31
Option
1.
Signs
at
outfalls.

5.
Percentage
of
respondents
using
Option
1:
25%

6.
Number
of
respondents
using
Option
1
=
(
3)
x
(
5):
112.5
7.
Number
of
CSO
outfalls
nationwide:
11,000
8.
Average
number
of
outfalls
per
respondent
­
(
7)
/
(
1):
12.22
9.
Number
of
outfall
signs
nationwide
=
(
6)
x
(
8):
1,375
10.
Installation/
maintenance
burden
per
sign:
2
$
71
$
94
11.
Total
national
burden
for
Option
1
=
(
9)
x
(
10):
2,750
$
97,103
$
129,250
Option
2.
Signs
at
beaches,
other
public
exposure
areas.

12.
Percentage
of
respondents
using
Option
2:
25%

13.
Number
of
respondents
using
Option
2
=
(
3)
x
(
12):
112.5
14.
Number
of
signs
posted
by
each
respondent:
5
15.
Number
of
signs
at
public
exposure
areas
nationwide
(
13)
x
(
14):
562.5
16.
Installation/
maintenance
burden
per
sign:
2
$
71
$
94
17.
Total
national
burden
for
Option
2
=
(
15)
x
16):
1,125
$
39,724
$
52,875
Option
3.
Press
or
radio
advisories.

18.
Percentage
of
respondents
using
Option
3:
20%

19.
Number
of
respondents
using
Option
3
=
(
3)
x
(
18):
90
20.
Number
of
advisories
per
respondent:
30
21.
Total
number
of
advisories
nationwide:
2,700
22.
Burden
per
advisory:
3
$
106
$
0
23.
Total
national
burden
for
Option
3:
8,100
$
286,011
$
0
TOTAL
BURDEN,
OPTIONS
1­
3
11,975
$
422,838
$
182,125
$
604,963
23
Total
Cost
The
total
nationwide
burden
of
the
effort
to
document
the
implementation
of
the
nine
minimum
controls
and
to
provide
public
notification
of
CSO
locations
and
CSO
events
is
67,605
hours,
and
the
cost
is
$
2,569,262.
This
includes
$
182,125
in
capital
costs
for
installing
and
maintaining
the
signs
to
be
posted
under
the
public
notification
element
of
the
NMC.

(
ii)
Long­
Term
CSO
Control
Plan
Burden
and
Cost
Following
are
information
collection
burdens
calculated
for
components
of
the
LTCP.

The
burdens
are
calculated
assuming
that
the
permit
writer
required
in
the
permit
that
the
permittee
develop
the
LTCP
and
that
the
permittee
address
each
component
of
the
LTCP.
The
calculated
burdens
are
adjusted
for
several
factors:
(
1)
a
number
of
CSS
municipalities
have
already
completed
long­
term
plans
that
contain
part
or
all
of
the
LTCP
components
included
in
the
policy,
(
2)
the
small
system
consideration
in
the
Policy
may
potentially
relieve
small
systems
of
some
of
the
burden
in
developing
a
LTCP,
and
(
3)
not
every
component
of
the
LTCP
will
be
applicable
to
every
CSS
and
every
outfall.

Exhibit
6­
3.
Estimated
Burden
and
Cost
of
Writing
Long­
Term
CSO
Control
Plans
By
Control
Measure
By
System
Size
Nationwide
Total
Avg.
Per
System
Nationwide
Total
Avg.
Per
System
Hours
Systems
Cost
Burden
Cost
Burden
Cost
Burden
Cost
Burden
Systems
with
Existing
Studies
$
6,812,711
192,940
$
60,828
1,723
Small
812
31
$
888,823
25,172
$
28,672
812
Medium
1,664
62
$
3,642,862
103,168
$
58,756
1,664
Large
3,400
19
$
2,281,026
64,600
$
120,054
3,400
Systems
without
Existing
Studies
$
39,831,516
1,128,052
$
108,533
3,074
Small
812
285
$
8,171,440
231,420
$
28,672
812
Medium
8,864
63
$
19,718,234
558,432
$
312,988
8,864
Large
17,800
19
$
11,941,842
338,200
$
628,518
17,800
Record
Keeping,
All
Systems
$
1,850,526
52,408
$
3,863
109
Small
88
316
$
981,900
27,808
$
3,107
88
Medium
136
125
$
600,270
17,000
$
4,802
136
Large
200
38
$
268,356
7,600
$
7,062
200
Total
479
$
48,494,753
1,373,400
$
101,242
2,867
Small
316
$
10,042,163
284,400
$
31,779
900
Medium
125
$
23,961,678
678,600
$
191,691
5,429
Large
38
$
14,491,224
410,400
$
381,348
10,800
For
purposes
of
calculating
the
burden
of
developing
a
LTCP,
municipalities
were
divided
into
three
categories:
(
1)
those
serving
greater
than
75,000
persons
(
approximately
38
systems)

termed
"
large,"
(
2)
those
serving
between
10,000
and
75,000
persons
(
approximately
125
systems)
termed
"
medium,"
and
(
3)
those
serving
less
than
10,000
persons
(
approximately
316
systems)
termed
"
small."
24
The
following
was
assumed
in
estimating
LTCP
costs:

!
Estimated
burdens
do
not
account
for
extended
negotiations
or
litigation
and
do
not
include
the
cost
of
legal
counsel.

!
The
estimated
burden
is
based
only
on
the
incremental
effort
resulting
from
the
Policy
at
this
time.
Costs
already
incurred,
and
costs
for
related
issues
such
as
POTW
planning
are
not
included.

!
Very
large
systems
have
already
characterized
their
systems,
and
have
developed
CSO
control
programs.

!
Large
Systems
which
have
not
studied
their
systems
to
date
will,
on
average,

spend
roughly
$
500,000
on
LTCPs.

!
Roughly
half
of
municipalities
with
large­
sized
systems
have
performed
a
formal
study
of
their
CSS.
For
these
systems,
the
LTCP
is
assumed
to
build
upon
these
previous
studies
as
much
as
possible,
and
cost
$
100,000.

!
Medium
Systems:
The
cost
of
LTCPs
for
medium
systems
will
vary
widely
because
some
municipalities
will
use
municipal
personnel
and
others
will
hire
engineering
contractors.
The
estimated
average
cost
is
$
250,000.

!
For
approximately
half
of
municipalities
with
medium­
sized
systems
that
have
performed
some
study
of
their
CSS,
the
LTCP
is
assumed
to
build
upon
these
previous
studies
as
much
as
possible
and
cost
$
50,000.

!
Small
Systems:
The
average
cost
for
small
systems
is
estimated
at
$
25,000.
This
is
based
on
the
following
assumptions:
that
municipal
personnel
will
be
used,

that
cost
saving
measures
are
employed,
and
that
permit
writers
will
use
the
small
system
flexibility
in
the
Policy
to
reduce
the
burden
on
these
municipalities
in
developing
their
LTCPs.

!
It
is
assumed
that
many
municipalities
with
small­
sized
systems
have
not
performed
a
formal
study
of
their
CSS.
25
Total
Nationwide
Cost
to
Prepare
LTCPs:
Over
the
next
three
years
(
the
life
of
this
renewal
ICR),
the
estimated
one­
time
burden
to
develop
LTCPs
is
1,373,400
hours
and
the
estimated
cost
is
$
48,494,753.

Each
CSS
is
unique
in
terms
of
its
condition,
design,
operation,
and
the
extent
that
it
has
been
studied.
Each
of
the
components
of
the
LTCP
overlaps
with
the
other
components
to
a
varying
degree
depending
upon
the
individual
systems
characteristics.
For
example,
for
one
system
consideration
of
sensitive
areas
may
be
tied
closely
with
consideration
of
control
alternatives,
while,
in
another
situation
it
may
be
nearly
a
separate
condition.
In
a
third
situation
no
identifiable
sensitive
area
may
exist.
Finally,
the
amount
of
information
collection
required
to
support
the
LTCP
will
vary
greatly
from
system
to
system.

(
iii)
Compliance
Monitoring
Burden
and
Cost
The
CSO
Control
Policy
recommends
that
CSO
communities
conduct
compliance
monitoring
to
demonstrate
that
their
implemented
CSO
control
plans
do
achieve
compliance
with
CWA
requirements
and
applicable
State
WQS.
Over
the
life
of
this
renewal
ICR,
EPA
estimates
that
65%
of
the
900
CSO
municipalities
(
585)
will
conduct
compliance
monitoring
activities.

EPA,
based
on
discussions
with
State
NPDES
and
EPA
Regional
Office
Staff,
believes
that
communities
will
submit
CSO
monitoring
results
in
their
DMRs
semiannually.
EPA
estimates
that,
during
each
semiannual
reporting
period,
CSO
communities
will
sample
wet
weather
discharges
from
CSOs
during
three
wet
weather
events.
During
each
of
three
storm
events,

municipalities
will
sample
two
CSO
discharge
points,
taking
2
samples
per
outfall.
Each
sample
will
be
analyzed
for
TSS,
BOD
and
fecal
coliform.
Municipalities
may
be
required
as
a
condition
of
their
NPDES
permit,
to
analyze
for
additional
pollutants
based
on
the
site­
specific
circumstances
in
each
case.
EPA
anticipates
that
NPDES
permitting
authorities
will
require
as
a
permit
condition
that
municipalities
estimate
and
report
the
volume,
frequency,
and
duration
of
CSOs
that
they
experience
in
each
reporting
period.

Exhibit
6­
4
provides
the
estimated
burden
and
cost
associated
with
compliance
monitoring.
The
assumptions
used
to
estimate
the
hours
of
sampling,
analysis,
and
reporting
time
per
response
are
taken
from
the
ICR
on
Discharge
Monitoring
Reports.
The
total
burden
and
cost
for
compliance
monitoring
over
the
3­
year
life
of
this
renewal
ICR
is
243,945
hours
and
$
8,613,698.
26
Exhibit
6­
4.
Estimated
Burden
and
Cost
of
Compliance
Monitoring
LABOR
HOURS
LABOR
COST
1.
Number
of
cities
submitting
DMRs
(
65%
of
900)
585
2.
Number
of
DMRs
per
year
per
respondent
2
3.
Number
of
responses
per
year
=
(
1)
x
(
2):
1,170
4.
Number
of
years
for
ICR
3
5.
Number
of
responses
for
ICR
period
=
(
3)
x
(
4)
3,510
6.
Hours
of
sampling
time
per
response
27
7.
Total
hours
of
sampling
time
=
(
5)
x
(
6)
94,770
8.
Total
cost
of
sampling
=
(
7)
x
Average
Hourly
Rate
$
3,346,329
9.
Hours
of
sampling
per
response
18
10.
Total
hours
of
analysis
time
=
(
5)
x
(
9)
63,180
11.
Total
cost
of
analysis
=
(
10)
x
Average
Hourly
Rate
$
2,230,886
12.
Hours
per
response
to
estimate
flow
parameters
20
13.
Total
hours
to
estimate
flow
parameters
=
(
12)
x
(
5)
70,200
14.
Total
cost
to
estimate
flow
parameters
=
(
13)
x
Average
Hourly
Rate
$
2,478,762
15.
Hours
to
prepare
and
submit
DMRs
2
16.
Total
hours
to
prepare
and
submit
DMRs
=
(
15)
x
(
5)
7,020
17.
Total
cost
to
prepare
and
submit
DMRs
=
(
16)
x
Average
Hourly
Rate
$
247,876
18.
Hours
per
response
for
record
keeping
15
19.
Total
hours
for
record
keeping
=
(
1)
x
(
18)
8,775
20.
Total
cost
for
record
keeping
(
19)
x
Average
Hourly
Rate
$
309,845
21.
Total
hours
for
compliance
monitoring
=
(
7)
+
(
10)
+
(
13)
+
(
16)
+

(
19)
243,945
22.
Total
cost
for
compliance
monitoring
=
(
8)
+
(
11)
+
(
14)
+
(
17)
=
(
20)
$
8,613,698
6(
b)
Estimated
Government
Burden
And
Costs
This
ICR
assumes
that
the
average
annual
salary
for
both
a
federal
and
State
employee
is
$
45,900
based
on
a
federal
GS­
9,
Step
10
salary.
At
2,080
hours
per
year,
the
hourly
rate
is
$
22.07.
Overhead
costs
are
assumed
to
add
an
additional
60
percent
to
the
cost
of
the
average
federal
or
State
salary,
or
$
13.24
per
hour.
The
assumed
total
hourly
cost
is
$
35.31.

(
i)
State
and
Federal
Government
Tally
Exhibit
6­
5
summarizes
the
State
burden
and
Exhibit
6­
6
summarizes
the
federal
burden
for
reviewing
documentation
of
the
nine
minimum
controls,
LTCPs,
and
compliance
monitoring
data
submitted
in
semi­
annual
DMRs
and
for
ongoing
permit
oversight.
The
estimated
total
burden
which
will
be
spread
over
three
years
is
60,075
hours.
The
estimated
cost
to
States
is
$
1,948,441
and
the
estimated
cost
to
Regions
is
$
172,807.
Of
the
State
costs,
$
42,372
is
for
27
reporting
data
to
EPA.
The
total
federal
and
State
costs
for
the
review
of
State
and
municipal
submittals
is
$
2,121,248.
21990
Needs
Survey,
Office
of
Wastewater
Management.

28
6(
c)
Bottom
Line
Burden
Hours
and
Costs
Exhibit
6­
7
includes
the
total
burden
hours
and
costs
of
1,684,950
hours
and
$
59,495,584
broken
out
by
reporting
and
recordkeeping
and
by
respondents.
It
provides
the
same
categories
on
an
annual
basis
and
per
respondent.

6(
d)
Reason
for
Change
in
Burden
The
main
activities
for
municipalities
under
the
Policy
include
(
1)
documentation
of
the
implementation
of
the
nine
minimum
controls,
(
2)
development
and
implementation
of
a
longterm
Control
Plan
(
LTCP),
and
(
3)
compliance
monitoring
and
reporting
to
demonstrate
the
combined
sewer
system
is
in
continuing
compliance
with
State
WQS
and
NPDES
permit
conditions.

State
activities
under
the
Policy
include
permit
development
and
reissuance,
and
review
of
NMC
documentation,
LTCPs,
and
CSO
monitoring
data
in
discharge
monitoring
reports
(
DMRs).
Federal
activities
include
the
same
activities
and
the
review
of
State
information
submitted
to
EPA
for
developing
the
performance
reports
under
the
Government
Performance
and
Results
Act.

Both
the
size
of
combined
sewer
systems
(
CSSs)
and
municipalities
with
CSSs
vary
greatly.
Approximately
62
percent
of
CSSs
serve
10,000
people
or
less,
while
only
7
percent
of
the
systems
serve
populations
greater
than
100,000.
These
larger
systems,
however,
account
for
approximately
70
percent
of
the
total
population
served
by
CSSs2.
For
purposes
of
estimating
burdens,
this
renewal
ICR
categorizes
CSSs
as
follows:
"
very
large"
systems
serve
populations
greater
than
400,000,
"
large"
systems
serve
populations
greater
than
75,000,
"
medium"
systems
serve
populations
between
75,000
and
10,000
and
"
small"
systems
serve
populations
less
than
10,000.
Because
the
larger
systems
will
have
significantly
higher
burdens
and
costs
relative
to
the
small
systems,
yet
the
majority
of
systems
are
small,
the
average
system
burden
will
be
well
below
that
experienced
by
systems
located
in
large
cities.

The
total
nationwide
cost
to
municipalities
to
document
the
nine
minimum
controls
is
$
2,146,424,
including
$
182,125
in
capital
costs
for
notifying
the
public
of
CSOs.
This
is
an
annual
cost
of
$
715,475
over
the
next
three
years.
The
total
nationwide
cost
to
develop
LTCPs
is
$
48,494,753,
the
annual
value
is
$
16,164,918.
The
estimated
cost
of
collecting
and
reporting
29
reviewing
CSO
monitoring
data
is
$
8,613,698
over
the
next
three
years.
On
an
annual
basis,
the
cost
is
$
2,871,233.
The
estimated
cost
for
State
and
federal
review
of
documentation
of
the
nine
minimum
controls,
LTCPs,
and
CSO
monitoring
data
is
$
1,638,227
over
the
next
three
years.

On
an
annual
basis,
the
cost
is
$
546,092.

6(
e)
Burden
Statement
The
bottom
line
burdens
and
costs
for
non­
government
respondents
(
municipalities)
and
States
are
displayed
in
Table
6­
7
as
programmatic
totals,
as
annual
totals,
and
as
average
annual
values
per
respondent.
The
total
reporting
burden
and
cost
for
900
municipalities
are
1,616,127
hours
and
$
57,065,444,
respectively.
The
record
keeping
burden
and
cost
are
68,823
hours
and
$
2,430,140,
respectively.
The
reporting
burden
and
cost
for
30
states
are
54,834
hours
and
$
1,936,189,
respectively.
The
record
keeping
burden
and
cost
are
347
hours
and
$
12,253,

respectively.

The
average
burden
for
each
responding
municipality
is
estimated
to
be
1,872
hours;

spread
over
three
years;
this
is
equivalent
to
624
hours
annually.
This
includes
documenting
implementation
of
the
nine
minimum
controls,
third
party
notification
under
the
public
notification
element
of
the
NMC,
developing
a
long­
term
CSO
control
plan,
and
sampling,
analysis,
reporting
and
record
keeping
associated
with
compliance
monitoring.
The
average
annual
burden
and
cost
per
respondent
(
municipalities
and
States)
are
624
hours
and
$
22,023,
respectively.

Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Director,
Collection
Strategies
30
Division,
Office
of
Environmental
Information,
U.
S.
Environmental
Protection
Agency
(
2822),

Ariel
Rios
Building,
1200
Pennsylvania
Avenue,
NW,
Washington,
D.
C.
20460;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
N.
W.,

Washington,
D.
C.
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
and
the
OMB
control
number
in
any
correspondence.
31
Exhibit
6­
5.
Estimated
State
Burden
and
Cost
Respondents
Burden
Hours
Total
Burden
Hourly
Labor
Cost
Total
Cost
Item/
Type
of
Respondent
Review
Discharge
Monitoring
Reports
for
CSO
Data/
Follow­
Up
on
50%
of
DMRs
3218/
1609
0.167/
0.5
537/
804
$
35.31
$
47,351
State
Reporting
to
EPA
30
40
1,200
$
35.31
$
42,372
Review
Nine
Minimum
Control
Documentation
347
40
13,880
$
35.31
$
490,103
Review
LTCPs
Very
Large
Systems
6
319
1,914
$
35.31
$
67,583
Large
Systems
29
159
4,611
$
35.31
$
162,814
Medium
Systems
89
99
8,811
$
35.31
$
311,116
Small
Systems
223
59
13,157
$
35.31
$
464,574
Permit
Reissuance
or
Other
Mechanisms
(
§
308)
248
40
9,920
$
35.31
$
350,275
Record
Keeping
347
1
347
$
35.31
$
12,253
Totals
55,181
$
1,948,441
32
Exhibit
6­
6.
Estimated
Federal
Burden
and
Cost
Respondents
Burden
Hours
Total
Burden
Hourly
Labor
Cost
Total
Cost
Item/
Type
of
Respondent
Review
Discharge
Monitoring
Reports
for
CSO
Data/
Follow­
Up
on
50%
of
DMRs
293/
147
0.167/
0.5
49/
74
$
35.31
$
4,343
Review
Nine
Minimum
Control
Documentation
31
40
1,240
$
35.31
$
43,784
Review
LTCPs
Very
Large
Systems
0
320
­
$
35.31
$
0
Large
Systems
2
160
320
$
35.31
$
11,299
Medium
Systems
10
100
1,000
$
35.31
$
35,310
Small
Systems
21
60
1,260
$
35.31
$
44,491
Permit
Reissuance
or
Other
Mechanisms
(
§
308)
23
40
920
$
35.31
$
32,485
Record
Keeping
31
1
31
$
35.31
$
1,095
Totals
4,894
$
172,807
33
Exhibit
6­
7.
Estimated
Bottom
Line
Burden
Hours
and
Costs
Summary
Nongovernment
States
Total
Number
of
Respondents
900
30
930
Total
Burdens
and
Costs
Reporting
Burden
1,616,127
54,834
1,670,961
Reporting
Cost
$
57,065,444
$
1,936,189
$
59,001,633
Record
Keeping
Burden
68,823
347
69,170
Record
Keeping
Cost
$
2,430,140
$
12,253
$
2,442,393
Total
Burden
1,684,950
55,181
1,740,131
Total
Cost
$
59,495,584
$
1,948,442
$
61,444,026
Total
Annual
Burdens
and
Costs
Reporting
Burden
538,709
18,278
556,987
Reporting
Cost
$
19,021,815
$
645,396
$
19,667,211
Record
Keeping
Burden
22,941
116
23,057
Record
Keeping
Cost
$
810,047
$
4,096
$
814,143
Total
Burden
561,650
18,394
580,044
Total
Cost
$
19,831,862
$
649,492
$
20,481,354
Annual
Burdens
and
Costs
per
Respondent
Reporting
599
609
599
Reporting
Cost
$
21,135
$
21,513
$
21,148
Record
Keeping
Burden
25
4
25
Record
Keeping
Cost
$
900
$
137
$
875
Total
624
613
624
Total
Cost
$
22,035
$
21,650
$
22,023
