INFORMATION
COLLECTION
REQUEST
FOR
GREAT
LAKES
WATER
QUALITY
GUIDANCE
REPORTING
REQUIREMENTS
August
2001
EPA
ICR
Number
1639.04
OMB
Control
Number
2040­
0180
U.
S.
Environmental
Protection
Agency
Office
of
Water/
Office
of
Science
and
Technology
Ariel
Rios
Building
1200
Pennsylvania
Avenue,
NW
Washington,
D.
C.
20460
TABLE
OF
CONTENTS
Page
1.0
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
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1
1.1
TITLE
OF
THE
INFORMATION
COLLECTION
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1
1.2
SHORT
CHARACTERIZATION
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1
2.0
NEED
FOR
AND
USE
OF
THE
COLLECTION
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4
2.1
NEED
AND
AUTHORITY
FOR
THE
COLLECTION
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4
2.2
USE
AND
USERS
OF
INFORMATION
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5
2.2.1
IDENTIFICATION,
LOCATION,
AND
DESCRIPTION
OF
FACILITY
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5
2.2.2
INFORMATION
RELATED
TO
DISCHARGES
INTO
THE
GREAT
LAKES
SYSTEM
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5
3.0
THE
RESPONDENTS
AND
THE
INFORMATION
COLLECTED
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6
3.1
CHARACTERIZATION
OF
RESPONDENTS
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6
3.2
INFORMATION
REQUESTED
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7
3.3
RESPONDENT
ACTIVITIES
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9
4.0
THE
INFORMATION
COLLECTED:
GOVERNMENT
ACTIVITIES,
COLLECTION,
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
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11
4.1
GOVERNMENT
ACTIVITIES
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11
4.2
COLLECTION
METHODOLOGY
AND
MANAGEMENT
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11
4.3
SMALL
ENTITY
FLEXIBILITY
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11
4.4
COLLECTION
SCHEDULE
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12
5.0
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
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13
5.1
NONDUPLICATION
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13
5.2
CONSULTATIONS
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13
5.3
EFFECTS
OF
LESS
FREQUENT
COLLECTION
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14
5.4
GENERAL
GUIDELINES
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15
5.5
CONFIDENTIALITY
AND
SENSITIVE
QUESTIONS
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15
6.0
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
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16
6.1
ESTIMATING
RESPONDENT
BURDEN
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16
6.1.1
APPLICATIONS
BURDEN
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16
6.1.2
DISCHARGE
AND
MONITORING
REPORT
BURDEN
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19
6.1.3
MODIFICATION
AND
VARIANCE
BURDEN
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25
6.2
ESTIMATING
RESPONDENT
COST
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26
6.2.1
APPLICATIONS
COST
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27
6.2.2
MONITORING
COSTS
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32
6.2.3
MODIFICATION
AND
VARIANCE
COSTS
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37
6.3
ESTIMATING
FEDERAL
GOVERNMENT
BURDEN
AND
COSTS
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38
6.3.1
GOVERNMENT
APPLICATIONS
BURDEN
AND
COST
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38
6.3.2
GOVERNMENT
MONITORING
BURDEN
AND
COST
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38
6.3.3
GOVERNMENT
REGULATORY
RELIEF
OPTION
BURDEN
AND
COST
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38
6.4
TOTAL
UPDATED
BURDEN
HOURS
AND
COSTS
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38
Attachment
A
Response
to
comment
from
First
Federal
Register
Notice
Great
Lakes
Guidance
Permit
ICR
1
1.0
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1.1
TITLE
OF
THE
INFORMATION
COLLECTION
The
title
of
this
Information
Collection
Request
(
ICR)
is
Great
Lakes
Water
Quality
Guidance
Reporting
Requirements.
This
ICR
revises
the
existing
estimates
of
burden
and
costs
to
National
Pollutant
Discharge
Elimination
System
(
NPDES)
permittees
and
governments
(
Federal,
State,
local)
presented
in
the
ICR
entitled
National
Pollutant
Discharge
Elimination
System
Great
Lakes
Water
Quality
Guidance
(
OMB
Control
Number
2040­
0180),
which
expires
on
September
30,
2001.
For
purposes
of
the
2001
proposed
collection
notice
and
request
for
public
comments,
the
Environmental
Protection
Agency
(
EPA)
updated
the
1998
costs
shown
in
this
report
to
reflect
increases
in
labor
costs
since
1998,
the
year
of
the
last
update.
The
following
sections
describe
the
information
collected
and
the
cost
of
collection.

1.2
SHORT
CHARACTERIZATION
This
ICR
calculates
the
burden
and
costs
associated
with
the
implementation
of
the
Great
Lakes
Water
Quality
Guidance
(
hereafter
referred
to
as
the
Guidance).
The
Guidance
identifies
minimum
water
quality
criteria,
implementation
procedures,
and
antidegradation
provisions
for
the
Great
Lakes
System.
Implementation
of
these
provisions
is
dependent
upon
future
promulgation
of
provisions
consistent
with
the
final
Guidance
by
State
or
Tribal
agencies
or,
if
necessary,
EPA.
Until
actions
are
taken
to
promulgate
and
implement
these
provisions
(
or
equally
protective
provisions
consistent
with
the
final
Guidance),
there
will
be
no
economic
effect
of
this
rule.

The
Great
Lakes
System
is
comprised
of
eight
States:
New
York,
Pennsylvania,
Ohio,
Indiana,
Illinois,
Minnesota,
Wisconsin,
and
Michigan.
In
the
Great
Lakes
Basin,
there
are
588
major
dischargers
­
316
are
major
municipal
dischargers,
and
272
are
major
industrial
dischargers;
and
3,207
minor
dischargers.
In
sum
there
are
3,795
dischargers
(
588
major,
and
3,207
minor)
that
will
be
affected
by
State,
Tribal,
or
EPA
promulgated
provisions
consistent
with
the
Guidance.

The
Clean
Water
Act
(
CWA)
authorized
EPA
to
issue
permits
for
the
discharge
of
pollutants
or
combinations
of
pollutants
to
the
waters
of
the
United
States.
EPA
and
authorized
States
regulate
discharges
to
waters
of
the
United
States
through
NPDES
programs.
Such
discharges
include
domestic
wastewater,
industrial
wastewater,
storm
water
as
well
as
others.
To
protect
human
health,
aquatic
life,
and
wildlife
in
the
Great
Lakes
System,
Congress
enacted,
on
November
16,
1990,
the
Great
Lakes
Critical
Programs
Act
(
CPA).
Section
101
of
the
CPA
amended
Section
118
of
the
CWA
and
directed
EPA
to
publish
water
quality
guidance
for
the
Great
Lakes
that:

°
conforms
to
the
Great
Lakes
Water
Quality
Agreement
Great
Lakes
Guidance
Permit
ICR
2
°
is
no
less
restrictive
than
the
CWA
and
national
water
quality
criteria
and
guidance
°
specifies
numerical
limits
on
pollutants
in
ambient
Great
Lake
waters
that
protect
human
health,
aquatic
life,
and
wildlife
°
provides
guidance
on
minimum
water
quality
standards,
antidegradation
policies,
and
implementation
procedures
for
the
Great
Lakes
system.

Within
two
years
after
the
final
guidance
is
published,
the
CPA
requires
the
Great
Lakes
States
to
adopt
water
quality
standards,
antidegradation
policies,
and
implementation
procedures
for
waters
within
the
Great
Lakes
System
that
are
consistent
with
the
guidance.
If
a
Great
Lakes
State
fails
to
adopt
necessary
standards,
policies
and
procedures,
EPA
is
required
to
promulgate
them
two
years
after
the
final
guidance
is
published.

Based
on
the
goals
of
the
Great
Lakes
Water
Quality
Initiative
(
GLWQI),
a
new
Part
132
of
Title
40,
Water
Quality
Guidance
for
the
Great
Lakes
System
was
promulgated.
The
Guidance
includes:

°
minimum
methodologies
for
setting
numerical
water
quality
criteria
for
all
pollutants
(
except
for
what
are
referred
to
as
Table
5
pollutants)
to
protect
human
health,
wildlife,
and
aquatic
life
°
minimum
antidegradation
policy
and
procedures
to
maintain
existing
water
quality
°
minimum
implementation
procedures
to
translate
the
criteria
and
antidegradation
policy
into
controls
for
specific
sources
of
pollutants
To
conform
with
future
requirements
promulgated
by
Great
Lakes
States
or
Tribes
consistent
the
final
Guidance,
NPDES
permit
applicants
may
have
to
submit
additional
information
for
future
NPDES
permit
modification,
renewal
or
issuance.
Elements
that
may
result
in
information
collection
or
record
keeping
burden
include
the
following:

°
permit
applicants
may
be
required
to
identify
whether
the
138
pollutants
of
initial
focus
are
present
in
their
discharges
(
numerical
water
quality
criteria
have
been
determined
for
30
of
the
138
pollutants
of
initial
focus)

°
permittees
may
be
required
to
conduct
additional
monitoring
in
cases
where
existing
permits
do
not
address
pollutants
for
which
numeric
water
quality
criteria
have
been
included
in
the
final
Guidance
°
at
facilities
with
water
quality­
based
effluent
limits
(
WQBELs)
that
are
established
below
the
quantification
level
(
as
signified,
for
example,
by
the
most
sensitive
analytical
methods
specified
in
or
approved
under
40
CFR
Part
136
for
a
given
pollutant),
permits
will
establish
an
actual
limit
exactly
as
calculated
and
samples
analyzed
in
accordance
with
the
analytical
method
specified
in
the
permit
and
other
Great
Lakes
Guidance
Permit
ICR
3
application
procedures
that
are
below
the
quantification
level
shall
be
deemed
in
compliance
with
the
WQBEL;
however,
permittees
are
required
to
conduct
pollutant
minimization
programs
to
review
and
monitor
potential
pollutant
sources
and
implement
control
strategies
and
may
also
be
required
to
conduct
a
bio­
uptake
monitoring
program
for
bioaccumulative
chemicals
of
concern
(
BCCs)

The
final
Guidance
includes
two
methodologies
for
developing
numeric
water
quality
criteria
to
protect
human
health
and
aquatic
life,
and
one
methodology
to
protect
wildlife.
The
Tier
I
approach
is
used
when
certain
minimum
data
requirements
are
met.
Under
the
Tier
II
approach,
water
quality
values
can
be
calculated
based
on
fewer
data
than
the
full
minimum
data
required
for
a
Tier
I
calculation.
The
Tier
II
approach
was
designed
to
provide
a
methodology
for
evaluating
pollutants
and
interpreting
narrative
water
quality
criteria
when
there
is
insufficient
data
to
develop
Tier
I
criteria.
To
reflect
the
increased
uncertainty
associated
with
fewer
data
points,
criteria
developed
using
the
Tier
II
approach
will
generally
be
more
stringent
than
criteria
developed
using
the
Tier
I
approach.

This
ICR
presents
the
estimated
burden
and
costs
associated
with
implementation
of
the
Guidance.
The
total
annual
burden
to
all
respondents
is
estimated
to
be
43,395
hours
with
an
associated
cost
of
$
5,011,802.
To
update
this
cost
to
reflect
increases
in
labor
costs
since
1998
(
the
year
of
the
last
update),
EPA
applied
the
increase
in
the
employment
cost
index
(
approximately
a
3.5%
average
annual
increase
between
1998
and
2000)
to
the
three­
year
period
from
1999
to
2001,
to
the
1998
costs
shown
in
this
report
(
see
Section
6.4).
The
following
sections
describe
the
information
collected
and
the
cost
of
collection.
Great
Lakes
Guidance
Permit
ICR
4
2.0
NEED
FOR
AND
USE
OF
THE
COLLECTION
2.1
NEED
AND
AUTHORITY
FOR
THE
COLLECTION
The
primary
objective
of
the
CWA
is
"
to
restore
and
maintain
the
chemical,
physical
and
biological
integrity
of
the
nation's
waters"
(
Section
101(
a)).
CWA
Section
402
establishes
the
NPDES
program
to
regulate
the
discharge
of
any
pollutant
or
combination
of
pollutants
from
point
sources
into
the
waters
of
the
United
States.
CWA
Section
402(
a),
as
amended,
authorizes
the
EPA
Administrator
to
issue
permits
for
the
discharge
of
pollutants
if
those
discharges
meet
the
following
requirements:

°
all
applicable
requirements
of
CWA
Sections
301,
302,
306,
307,
308,
and
403
°
any
conditions
the
Administrator
determines
are
necessary
to
carry
out
the
provisions
and
objectives
of
the
CWA.

Section
101
of
the
CPA
amends
Section
118
of
the
CWA
and
directs
EPA
to
publish
water
quality
guidance
for
the
Great
Lakes
system.
Provisions
of
the
Guidance
are
codified
in
40
CFR
Part
132.
The
Guidance
establishes
minimum
water
quality
criteria,
implementation
procedures,
and
antidegradation
provisions
for
the
Great
Lakes
system.
Under
the
Guidance,
EPA
and
delegated
NPDES
permitting
authorities
may
need
point
source
dischargers
in
the
Great
Lakes
Basin
to
collect
and
submit
information
to:

°
implement
methodologies
for
setting
numerical
water
quality
criteria
and
values
promulgated
by
States
and
Tribes
(
Great
Lakes
States
and
Tribes
will
use
methodologies
consistent
with
the
Guidance
when
revising
existing
or
promulgating
new
water
quality
criteria)

°
evaluate
requests
for
permit
changes
using
antidegradation
policies
and
procedures
consistent
with
the
Guidance
°
further
the
pollution
prevention
policy
that
focuses
on
the
virtual
elimination
of
toxic
discharges
into
the
Great
Lakes
system
°
translate
provisions
consistent
with
the
elements
of
the
Guidance
into
controls
for
point
sources
of
pollutants
°
identify
facilities
that
require
additional
permit
conditions
(
i.
e.,
those
that
are
discharging
pollutants
at
levels
of
concern
into
the
Great
Lakes
system)

°
identify
new
pollutants
in
existing
discharges
°
evaluate
water
quality
in
the
Great
Lakes
°
determine
violations
of
State
and
Tribal
provisions
consistent
with
the
Guidance.
Great
Lakes
Guidance
Permit
ICR
5
2.2
USE
AND
USERS
OF
INFORMATION
Although
permit
applicants
collect
and
submit
many
types
of
information,
this
information
can
be
broadly
categorized
as
identification
details
(
e.
g.,
name,
location,
and
facility
description)
and
as
information
related
to
pollutant
discharges
into
the
Great
Lakes.

2.2.1
IDENTIFICATION,
LOCATION,
AND
DESCRIPTION
OF
FACILITY
Permitting
authorities
currently
require
dischargers
to
provide
information
such
as
the
name,
location,
and
description
of
facilities
to
identify
the
facilities
that
require
permits.
EPA
and
authorized
NPDES
States
store
much
of
this
basic
information
in
the
Permit
Compliance
System
(
PCS)
database.
PCS
provides
EPA
with
a
nationwide
inventory
of
NPDES
permit
holders.
EPA
uses
the
information
contained
in
the
PCS
to
develop
reports
on
permit
issuance,
backlogs,
and
compliance
rates.
The
Agency
also
uses
the
information
to
respond
to
public
and
Congressional
inquiries,
develop
and
guide
its
policies,
formulate
its
budgets,
assist
States
in
acquiring
authority
for
permitting
programs,
and
manage
its
programs
to
ensure
national
consistency
in
permitting.

2.2.2
INFORMATION
RELATED
TO
DISCHARGES
INTO
THE
GREAT
LAKES
SYSTEM
NPDES
permit
applications
and
requests
for
supplemental
information
currently
require
information
about
wastewater
treatment
systems,
pollutants,
discharge
rates
and
volumes,
whole
effluent
toxicity
testing
and
other
data.
To
implement
State,
Tribal,
or
EPA
promulgated
provisions
consistent
with
the
Guidance,
additional
information
may
be
necessary
on
the
following:

°
monitoring
(
pollutant­
specific
and
whole
effluent
toxicity
or
WET)
°
pollutant
minimization
programs
°
bioassays
to
support
the
development
of
water
quality
criteria
°
antidegradation
policy/
demonstrations
°
regulatory
relief
options
(
e.
g.,
variances
from
water
quality
criteria).

This
information
may
be
used
to
ensure
compliance
with
provisions
consistent
with
the
Guidance
and
to
re­
evaluate
existing
permit
conditions
and
monitoring
requirements.
Data
on
discharges
is
entered
into
PCS
and
STORET
(
an
EPA
database
for
ambient
water
quality
data).
Results
of
water
quality
criteria
testing
will
be
entered
into
an
EPA
Information
Clearinghouse
database.
Great
Lakes
Guidance
Permit
ICR
6
EXHIBIT
3­
1
SUMMARY
OF
CATEGORY
OF
DISCHARGERS
POTENTIALLY
IMPACTED
BY
THE
GREAT
LAKES
GUIDANCE
Discharger
Category
SIC
Code
Number
of
Dischargers
Major
Dischargers
Mining
Food
Pulp
and
Paper
Inorganic
Chemical
Man.
Org.
Chemical
Man./
Petroleum
Refining
Metal
Manufacturing
Metal
Finishing
Steam
Electric
Miscellaneous
Municipal
(
POTWs)

Subtotal
10,14
20
26
281
28,29
33
34,35,36,37
4911
4952
14
12
54
19
28
37
31
50
27
316
588
Minor
Dischargers
Non­
Municipal
Municipal
Subtotal
4952
2,280
927
3,207
Total
Dischargers
3,795
3.0
THE
RESPONDENTS
AND
THE
INFORMATION
COLLECTED
3.1
CHARACTERIZATION
OF
RESPONDENTS
NPDES
permits
are
required
any
time
there
is
a
point
source
discharge
of
pollutants
to
waters
of
the
United
States,
regardless
of
the
type
of
discharger.
Consequently,
all
point
source
dischargers
must
apply
for
an
NPDES
permit.
In
addition,
permits
issued
to
point
sources
that
discharge
into
the
Great
Lakes
system
will
be
required
to
include
provisions,
as
applicable,
implementing
State
and
Tribal
requirements
consistent
with
the
final
Guidance.
Based
on
a
review
of
lists
that
States
generated
and
of
permits
issued
since
March
1991,
EPA
determined
that
588
major
and
3,207
minor
point
sources
would
be
affected
(
see
Exhibit
3­
1).
Great
Lakes
Guidance
Permit
ICR
7
EPA
distinguishes
between
major
and
minor
point
sources
under
the
NPDES
permitting
program.
EPA
designates
major
municipal
dischargers
as
those:
serving
at
least
10,000
persons;
having
a
design
flow
in
excess
of
1
million
gallons
per
day;
having
significant
amounts
of
toxics
in
their
effluent;
discharging
into
waters
of
significant
concern;
or
designated
as
such
by
the
permitting
authority.
In
characterizing
major
industrial
dischargers,
EPA
considers
several
factors,
including
the
concentration
of
toxic
pollutants
in
the
discharge
as
well
as
the
volume
discharged.
Major
sources
in
the
Great
Lakes
System
include
316
municipal
(
publicly
owned
treatment
works
or
POTWs)
and
272
industrial
sources.
Minor
dischargers
are
all
those
permittees
that
are
not
designated
as
major
dischargers.
Minor
sources
may
discharge
contaminated
process
wastes
that
could
have
a
significant
toxic
component,
or
have
other
characteristics
addressed
by
the
Guidance.
EPA
determined
that
there
are
3,207
minor
dischargers
in
the
Great
Lakes
System.
Of
these,
927
sources
were
determined
to
be
municipal
dischargers
and
2,280
non­
municipal
dischargers.

3.2
INFORMATION
REQUESTED
Information
collection
associated
with
the
implementation
of
the
Guidance
will
ultimately
affect
the
burden
and
costs
of
program
elements
estimated
in
other
ICRs
that
have
been
developed
under
the
NPDES
program.
This
ICR
will
estimate
the
burdens
and
costs
associated
with
information
collection
activities
that
may
be
over
and
above
those
burdens
and
costs
already
estimated
in
the
other
NPDES
ICRs.
These
other
ICRs
include:

°
Information
Collection
Request
for
Application
for
the
National
Pollutant
Discharge
Elimination
System
Discharge
Permit
and
the
Sewage
Sludge
Management
Permit
(
hereafter,
the
Applications
ICR)
effective
through
August,
1998
(
OMB
No.
2040­
0057)

°
Information
Collection
Request
for
the
National
Pollutant
Discharge
Elimination
System:
Discharge
Monitoring
Reports
(
hereafter,
the
Discharge
and
Monitoring
Report
ICR),
effective
through
May,
1998
(
OMB
No.
2040­
0004)

°
Information
Collection
Request
for
the
National
Pollutant
Discharge
Elimination
System
Modification
and
Variance
Requests
(
hereafter,
the
Modification
and
Variance
ICR),
effective
through
August,
1998
(
OMB
No.
2040­
0068).

Generally,
States
and
Tribes
must
adopt
provisions
consistent
with
the
Guidance.
In
addition,
EPA
has
included
recommendations
or
guidance
on
other
issues
that
permitting
authorities
may
choose
to
incorporate
into
their
water
programs.
This
makes
it
difficult
to
determine
burdens
and
cost
associated
with
implementation
of
provisions
consistent
with
the
Guidance,
however,
EPA
assumes
that
most
States/
Tribes
will
implement
the
recommendations
provided
in
the
Guidance.
As
such,
EPA
has
included
burden
and
costs
associated
with
these
recommendations
throughout
this
ICR.
Burdens
and
costs,
therefore,
may
be
overstated
in
some
places.
Great
Lakes
Guidance
Permit
ICR
8
Applications
ICR
To
collect
information
requested
for
the
NPDES
program,
EPA
has
developed
standard
application
forms
for
most
applicants.
Standard
application
forms
include:
Standard
Form
A;
Short
Form
A;
Forms
1,
2B,
2C,
2D,
2E,
2F;
and
the
Uniform
Federal
Transportation/
Utility
System
Application
Form
(
see
the
Applications
ICR
for
more
detailed
information).

For
some
permits
and
application
requirements,
EPA
has
not
developed
standard
application
forms.
In
some
cases,
standard
forms
are
not
appropriate;
in
others,
EPA
is
currently
developing
appropriate
forms.
This
ICR
calculates
the
burden
to
respondents
for
supplying
information
addressing
implementation
of
State,
Tribal,
or
subsequently
promulgated
Federal
provisions
consistent
with
the
Guidance
that
may
be
in
addition
to
existing
application
requirements
of
the
authorized
NPDES
permitting
program.

Information
collection
requirements
necessitated
by
the
Guidance
that
may
affect
the
overall
burden
and
costs
associated
with
the
Applications
ICR
include:

°
bioassay
tests
to
support
the
development
of
water
quality
criteria
for
the
138
pollutants
of
initial
focus
°
studies
to
identify
and
provide
information
on
antidegradation
control
measures
that
will
guard
against
the
reduction
of
water
quality
in
the
Great
Lakes
system
°
whole
effluent
toxicity
testing
required
to
meet
minimum
data
requirements
to
evaluate
the
need
for
WET
limits.

Discharge
Monitoring
Report
ICR
Discharge
monitoring
information
collection
relates
to
monitoring
and
reporting
requirements
included
in
NPDES
permits
issued
to
point
source
discharges
of
pollutants
to
surface
waters
of
the
United
States.
These
requirements
pertain
to
collection
and
analyses
of
samples
and
the
reporting
of
summary
information
to
the
permitting
authority.
The
permitting
authority
uses
the
data
as
the
primary
source
of
information
to
assess
compliance
with
permit
limitations.
Data
are
also
used
for
modifying
or
adding
new
permit
requirements,
assessing
and/
or
developing
effluent
guidelines,
and
assessing
the
need
for
water
quality­
based
limits
in
a
permit.

Information
collection
requirements
specified
in
the
Guidance
that
will
affect
the
overall
burdens
and
costs
estimated
in
the
Discharge
Monitoring
Report
ICR
include
monitoring,
record
keeping,
and
reporting
requirements
for:

°
WQBEL
compliance
monitoring;
°
WET
limit
compliance
monitoring;
and
°
pollutant
minimization
programs
(
PMPs).
Great
Lakes
Guidance
Permit
ICR
9
Modification
and
Variance
ICR
Section
301
of
the
CWA
authorizes
EPA
and
States
with
the
authority
to
establish
and
modify
NPDES
permit
conditions
or
to
vary
the
effluent
limitations
established
in
NPDES
permits.
Section
405
of
the
CWA
allows
States
with
sludge
management
authority
to
issue
and
modify
permits
that
regulate
the
use
and
disposal
of
sewage
sludge.
The
Modification
and
Variance
ICR
describes
the
data
requirements
necessary
for
a
permitting
authority
to
determine
(
1)
whether
NPDES
or
sewage
sludge
management
permit
conditions
should
be
modified,
or
(
2)
whether
a
request
for
a
variance
from
certain
NPDES
permit
conditions
should
be
granted.

Under
the
Guidance,
several
additional
regulatory
relief
options
are
allowed
if
appropriate
documentation
is
submitted
to
substantiate
and
justify
them.
In
sum,
relief
options
for
dischargers
to
the
Great
Lakes
include
mechanisms
such
as
variances
from
criteria,
alternative
mixing
zones,
phased­
total
maximum
daily
loadings
(
TMDLs),
and
site­
specific
criteria.
All
of
these
mechanisms
are
available
under
the
CWA
and
existing
NPDES
programs.
Therefore,
this
ICR
includes
information
collection
and
record
keeping
activities
associated
with
analyses
and
reporting
to
request
regulatory
relief
from
Guidance
requirements
which
are
in
excess
of
what
would
already
be
covered
under
the
existing
Modification
and
Variance
ICR.

3.3
RESPONDENT
ACTIVITIES
Respondents
may
be
required
to
submit
a
variety
of
different
information
items
for
State,
Tribal
or
subsequent
Federal
implementation
of
the
Guidance.
This
ICR
explains
these
activities
in
detail
for
each
Guidance
provision
that
may
result
in
respondent
information
collection
or
record
keeping
activities
(
see
Section
6.1).
In
general,
respondent
activities
will
include
the
following:

°
Preparing
Basic
Information
­
This
includes
reading
instructions
or
reviewing
regulatory
application
requirements,
gathering
general
information,
typing
or
filling
out
forms,
drafting
letters,
reviewing
applications
or
other
materials,
and
mailing
completed
submissions.

°
Generating
Detailed
Information
­
Detailed
information
may
include
data
on
production
levels,
data
on
effluent
characteristics,
pollutant
minimization
programs,
financial
estimates,
engineering
data,
socio­
economic
data,
or
other
information
required
by
permitting
authorities.

°
Sampling
and
Analyzing
Discharges
­
This
may
involve
pollutant
analyses,
biological
toxicity
testing,
predicting
in­
stream
impacts,
field
monitoring,
bioconcentration
testing,
or
other
scientific
analyses.

°
Maintaining
Records
­
All
NPDES
permittees
must
keep
records
of
the
data
used
to
complete
their
applications
and
to
demonstrate
their
compliance
for
at
least
three
years.
First­
time
applicants
may
need
to
develop
a
record
keeping
system,
Great
Lakes
Guidance
Permit
ICR
10
enter
data,
train
personnel,
and
file
information.
For
existing
facilities,
record
keeping
entails
collecting
and
filing
raw
data.
Great
Lakes
Guidance
Permit
ICR
11
4.0
THE
INFORMATION
COLLECTED:
GOVERNMENT
ACTIVITIES,
COLLECTION,
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
4.1
GOVERNMENT
ACTIVITIES
When
permitting
authorities
receive
NPDES
permit
applications,
they
must
review
them
for
completeness.
If
an
application
is
incomplete,
the
authorities
must
notify
the
applicant
and
request
the
missing
information.
Completed
applications
must
be
assigned
to
permit
writers,
who
then
review
the
applications
in
more
detail
as
they
develop
permit
conditions.
Permit
authorities
must
also
enter
certain
application
data
into
PCS
and
STORET.

Additional
information
may
also
be
requested
by
the
permit
writer
to
assist
in
developing
discharge
limits
or
other
permit
conditions.
These
data
or
special
studies
must
be
reviewed
by
the
permit
writer.
This
information
may
be
submitted
prior
to
issuance
or
during
the
term
of
the
permit.

Specific
Guidance
program
elements
that
may
necessitate
additional
government
review
when
promulgated
by
States/
Tribes
or
EPA
include:

°
bioassays
to
support
the
development
of
water
quality
criteria
°
antidegradation
demonstrations
°
PMPs
°
requests
for
regulatory
relief
(
e.
g.,
variances).

In
addition
to
activities
associated
with
reviewing
respondent
applications,
the
State
permitting
authorities
may
experience
other
information
collection
and
record
keeping
burdens
associated
with
implementation
of
the
Guidance.
However,
in
accordance
with
OMB
guidelines
covering
ICRs,
State
information
collection
and
record
keeping
burdens
not
associated
with
respondent
activities
are
not
included
in
this
ICR.

4.2
COLLECTION
METHODOLOGY
AND
MANAGEMENT
EPA
maintains
some
application
data
in
the
Agency's
databases,
PCS
and
STORET.
This
technology
reduces
the
burden
to
EPA
Headquarters
for
gathering
and
analyzing
national
permit
and
water
quality
data.
Because
each
information
collection
activity
associated
with
implementation
of
the
Guidance
will
contain
unique
information,
and
because
permittees
submit
applications
only
once
every
5
years,
improved
information
technology
may
not
be
effective
in
further
reducing
respondent
burden.

4.3
SMALL
ENTITY
FLEXIBILITY
Great
Lakes
Guidance
Permit
ICR
12
For
many
reasons,
EPA
believes
the
information
collection
and
reporting
requirements
described
in
this
ICR
do
not
place
an
unreasonable
burden
on
small
business.
For
example:

°
the
amount
of
information
required
increases
as
the
size
of
a
facility
increases
°
facilities
submit
permit
applications
infrequently
(
e.
g.,
once
every
five
years)

°
since
many
small
entities
do
not
discharge
any
toxic
pollutants,
or
they
discharge
pollutants
to
a
sewage
treatment
plant,
they
may
not
be
required
to
have
NPDES
permits
and
thus
will
not
experience
an
information
collection
burden
associated
with
the
Guidance.

Note
however,
some
information
collection
and
record
keeping
burdens
associated
with
implementation
of
the
Guidance
cannot
easily
be
reduced
for
small
businesses.
This
is
true
for
two
reasons:

°
NPDES
permitting
authorities
need
certain
basic
information
from
all
permittees
to
make
permitting
decisions
°
the
CWA
requires
all
point
source
dischargers
to
obtain
NPDES
permits,
regardless
of
size.

Therefore,
all
businesses
that
discharge
directly
into
the
waters
of
the
Great
Lakes
system
must
submit
necessary
permitting
information,
including
information
to
satisfy
requirements
ultimately
adopted
consistent
with
the
Guidance.

4.4
COLLECTION
SCHEDULE
The
CWA
requires
permittees
to
reapply
for
permits
at
least
every
five
years,
although
permit
writers
may
issue
permits
with
a
shorter
duration.
Most
respondents
submit
applications
every
five
years.
When
calculating
burden,
this
ICR
assumes
that
all
permit
applicants
affected
by
the
implementation
of
the
Guidance
follow
this
five
year
schedule.

Great
Lakes
States
and
Tribes
must
adopt
monitoring
and
reporting
provisions
consistent
with
those
specified
in
the
Guidance.
These
will
be
determined
on
a
case­
by­
case
basis
by
the
permitting
authority
and
will
be
individually
specified
in
NPDES
permits.
Generally,
monitoring
requirements
will
take
effect
upon
issuance
of
the
permit
and
will
be
in
place
throughout
the
life
of
the
permit.

Information
collection
associated
with
regulatory
relief
requests
based
on
State,
Tribal,
or
Federal
provisions
consistent
with
the
Guidance
will
occur
only
when
a
permittee
decides
to
seek
such
relief.
EPA
presumes
that
the
few
relief
requests
expected
will
continue
to
take
place
at
time
of
permit
reissuance.
Great
Lakes
Guidance
Permit
ICR
13
5.0
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
5.1
NONDUPLICATION
EPA
has
examined
all
the
reporting
requirements
contained
in
the
CWA
and
40
CFR
Parts
122,
123,
124,
125,
403,
501,
and
503.
The
Agency
also
has
consulted
the
following
sources
of
information
to
determine
if
similar
or
duplicate
information
is
available
elsewhere:

°
EPA's
Information
Systems
Inventory
°
EPA's
Inventory
of
Information
Collection
Requests
°
Federal
Information
Locator
System
°
Comprehensive
Assessment
Information
Rule
(
53
CFR
51698)
°
EPA's
Toxics
Release
Inventory.

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

5.2
CONSULTATIONS
The
major
provisions
in
the
proposed
Guidance
were
developed
over
a
two
year
period
by
the
eight
Great
Lakes
States,
the
U.
S.
Fish
and
Wildlife
Service,
the
U.
S.
National
Park
Service,
EPA,
and
members
of
the
public.
On
December
6,
1991,
the
Great
Lakes
States
recommended
that
EPA
publish
the
draft
Guidance
in
the
Federal
Register
for
public
review
and
comment.
EPA
generally
used
the
draft
ratified
by
the
Steering
Committee
as
the
basis
for
preparing
the
proposed
guidance
published
in
the
Federal
Register
on
April
16,
1993
(
58
CFR
20802).
However,
EPA
modified
the
package
to
reflect
statutory
and
regulatory
requirements
and
EPA
policy
considerations,
to
propose
procedures
for
State
and
Tribal
adoption
of
the
final
Guidance,
to
provide
suitable
discussion
of
various
alternative
options,
to
accommodate
necessary
format
changes,
and
to
respond
to
comments
made
by
EPA's
Science
Advisory
Board.
Where
modifications
were
made,
the
preamble
to
the
proposal
described
both
the
modification
and
the
original
Steering
Committee­
approved
guidelines,
and
invited
public
comment
on
both.
All
elements
approved
by
the
Steering
Committee
were
either
incorporated
in
the
proposed
Guidance
or
discussed
in
the
preamble
to
the
proposal.
The
150­
day
public
comment
period
on
the
proposal
closed
on
September
13,
1993.

To
evaluate
the
public
comments
and
prepare
the
final
guidance,
EPA's
Office
of
Water
created
a
Task
Force
to
oversee
21
workgroups
composed
of
EPA
management
and
staff
from
Headquarters
and
Regions
2,
3,
and
5
(
the
Regions
with
Great
Lakes
States).
To
enhance
intergovernmental
partnership
as
part
of
Executive
Order
No.
12875
and
to
stay
abreast
of
public
expectations
for
the
final
Guidance,
the
Agency
directed
the
Task
Force
to
keep
local,
State
and
Tribal
government
officials,
co­
regulators,
the
regulated
community
and
environmental
interests
informed.
During
the
post­
proposal
process,
the
Task
Force
and
workgroups
participated
in
over
Great
Lakes
Guidance
Permit
ICR
14
35
meetings
with
over
500
stakeholder
representatives.
The
comments
and
issues
raised
by
the
stakeholders
were
incorporated
into
the
docket
and
considered
by
the
Agency
in
its
option
selection
process
and
regulatory
impact
analysis
for
developing
the
final
Guidance.
The
Fish
and
Wildlife
Service's
(
FWS)
comments
resulted
in
formal
interagency
consultation
on
two
issues
regarding
endangered
species
and
culminated
in
a
written
Biological
Opinion
form
FWS
in
1994,
which
is
in
the
docket.

These
meetings
kept
EPA
apprised
of
the
most
current
scientific
information
and
data
to
consider
in
developing
the
final
Guidance.
As
a
result,
EPA
provided
notice
of
data
availability
and
opportunity
for
public
comment
on
August
30,
1994
(
59
CFR
44678).
EPA
received
23,000
pages
of
comments,
data,
and
information
from
over
5,700
commenters
in
response
to
these
notices
and
from
meetings
with
members
of
the
public.
In
response
to
the
States'
concerns,
the
final
Guidance
contains
less
detailed
procedures
for
implementation,
providing
maximum
flexibility
for
States
and
Tribes.
EPA
also
considered
comments
regarding
the
relative
contribution
of
pollutants
by
non­
permitted
sources,
discharges
to
polluted
waters,
maintaining
present
water
quality,
the
mercury
criteria,
and
mixing
zones.

5.3
EFFECTS
OF
LESS
FREQUENT
COLLECTION
Requirements
consistent
with
the
Guidance
will
be
promulgated
by
the
States
or
Tribes
or,
if
necessary,
by
EPA,
and
then
implemented
through
the
water
quality
and
permitting
programs.
Permitted
facilities
must
reapply
for
NPDES
permits
before
their
existing
permits
expire,
generally
once
every
five
years.
The
CWA
prohibits
issuance
of
NPDES
permits
with
terms
longer
than
five
years.
Less
frequent
permit
applications
would
not
provide
the
permitting
authority
with
sufficiently
current
data
to
establish
effective
limitations
or
conditions
when
issuing
permits.
Less
frequent
permit
issuance
would
also
hinder
the
ability
of
EPA
and
the
regulated
community
to
take
advantage
of
technological
improvements
as
they
occur.

The
specific
consequences
of
less
frequent
collection
associated
with
monitoring
and
reporting
requirements
implementing
the
provisions
in
the
Guidance
are
no
different
than
the
consequences
for
permittees
not
subject
to
the
Guidance.
A
detailed
discussion
of
these
consequences
are
described
in
the
Discharge
Monitoring
Report
ICR.
However,
note
that:

°
permits
written
based
on
infrequent
monitoring
data
may
not
adequately
represent
peak
release
°
reductions
in
monitoring
frequency
reduce
the
representation
of
discharge
monitoring
data
relative
to
true
waste
discharge
characteristics.

Since
permittees
will
decide
whether
or
not
to
apply
for
regulatory
relief
(
e.
g.,
variances
from
water
quality
criteria)
from
provisions
implementing
the
Guidance,
and
generally
pursuing
relief
is
a
one­
time
effort
for
the
permittee,
less
frequent
information
collection
associated
with
Guidance
regulatory
relief
procedures
is
not
relevant.
Less
frequent
information
collection
would
not
provide
the
permitting
authority
and
EPA
with
sufficient
information
to
meet
their
Great
Lakes
Guidance
Permit
ICR
15
responsibilities
for
review
and
approval
of
regulatory
relief
under
the
under
the
CWA
and
the
Guidance.

5.4
GENERAL
GUIDELINES
This
information
collection
complies
with
the
Paperwork
Reduction
Act
guidelines
(
5
CFR
§
1320.6).

5.5
CONFIDENTIALITY
AND
SENSITIVE
QUESTIONS
Permit
applications
may
contain
confidential
business
information.
If
this
is
the
case,
the
respondent
may
request
that
such
information
be
treated
as
confidential.
All
confidential
data
will
be
handled
in
accordance
with
40
CFR
§
122.7,
40
CFR
Part
2,
and
EPA's
Security
Manual
Part
III,
Chapter
9,
dated
August
9,
1976.
However,
CWA
Section
308(
b)
specifically
states
that
effluent
data
may
not
be
treated
as
confidential.

No
questions
of
a
sensitive
nature
are
associated
with
this
information
collection.
Great
Lakes
Guidance
Permit
ICR
16
EXHIBIT
6­
1
SUMMARY
OF
RESPONDENT
BURDEN
Increase
in
Respondent
Burden
(
Hours
per
Year)

Applications
Burden
8,154
Discharge
Monitoring
Report
Burden
24,607
Modification
and
Variance
Burden
10,634
Total
Burden
43,395
6.0
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6.1
ESTIMATING
RESPONDENT
BURDEN
EPA
has
estimated
the
total
respondent
burden
associated
with
implementation
of
provisions
consistent
with
the
Guidance
to
be
43,395
hours
annually
(
see
Exhibit
6.1).
Burden
hours
have
been
separated
based
on
the
following
existing
NPDES
ICRs
that
would
be
modified
by
the
new
burden
(
see
also
Section
3.2):

°
Applications
ICR
°
Discharge
Monitoring
Report
ICR
°
Modification
and
Variance
ICR.

6.1.1
APPLICATIONS
BURDEN
The
increase
in
respondent
burden
associated
with
NPDES
permit
applications
was
estimated
to
be
approximately
8,154
hours
annually.
The
activities
for
which
burdens
were
estimated
include:

°
bioassays
to
support
the
development
of
water
quality
criteria
for
the
138
pollutants
of
initial
focus
°
studies
to
identify
and
provide
information
on
antidegradation
control
measures
that
will
guard
against
the
reduction
of
water
quality
in
the
Great
Lakes
system
°
whole
effluent
toxicity
testing
required
to
meet
minimum
data
requirements
to
evaluate
the
need
for
WET
limits.
Great
Lakes
Guidance
Permit
ICR
17
Burden
Associated
With
Studies
to
Support
the
Development
of
Water
Quality
Criteria
EPA
assumed
that
dischargers
will
conduct
bioassays
to
support
the
development
of
water
quality
criteria
for
three
human
health
and
11
aquatic
life
criteria
each
year.
This
results
in
14
discharge
responses
per
year.
Based
on
experience
and
the
opinion
of
relevant
EPA
experts,
EPA
determined
that
these
bioassays
would,
in
almost
all
cases,
be
conducted
by
outside
laboratories.
However,
ten
hours
for
directing
the
laboratory's
work,
or
760
hours
of
discharger
burden,
is
also
anticipated.

States
and
Tribes
must
establish
WQBELS
necessary
to
protect
water
quality.
The
Guidance
contains
methodologies
to
calculate
acute
and
chronic
water
quality
criteria
for
the
protection
of
aquatic
life,
water
quality
criteria
for
the
protection
of
human
health,
and
water
quality
criteria
for
the
protection
of
wildlife.
The
Guidance
includes
both
Tier
I
and
Tier
II
methods,
which
differ
primarily
on
the
minimum
data
requirements.
States
and
Tribes
must
adopt
methodologies
consistent
with
the
Guidance.
They
do
not,
however,
have
to
develop
wildlife
values
using
the
Tier
II
methodology.
Tier
I
methods
require
more
data
and
are
therefore
more
precise
and
more
expensive
than
Tier
II
methods.
However,
numerical
values
based
on
Tier
II
methods
are
likely
to
be
more
stringent
than
those
based
on
Tier
I
methods
to
account
for
the
greater
uncertainty
of
the
resulting
values.
For
this
ICR,
EPA
assumed
that
sources
would
request
delay
in
the
compliance
deadlines
in
permits
in
order
to
generate
sufficient
data
to
calculate
Tier
I
criteria,
rather
than
Tier
II
values,
in
order
to
obtain
less
stringent
WQBELS.

EPA
assumed
that
the
14
studies
to
support
the
development
of
water
quality
criteria
would
be
submitted
to
the
States
for
review,
resulting
in
14
state
responses.
EPA
estimated
the
State
application
burden
associated
with
review
and
data
collection
to
support
the
development
of
water
quality
criteria
to
be
2,314
hours.
EPA
estimated
the
following
burden
and
associated
costs
with
the
review
of
Tier
I
criteria
development
(
assuming
that
only
the
minimum
number
of
studies
would
be
submitted
for
review):

°
aquatic
criteria:
1.5
hours/
study
(
8
acute
studies
+
3
chronic
studies)
+
2
hours
to
review
criterion
development
=
18.5
hours
per
pollutant
(
i.
e.,
203.5
hours
for
11
pollutants
[
53
potential
pollutants
divided
by
5
permit
years])

°
human
health
criteria:
2
hours
per
study
*
2
studies
+
2
hours
to
review
criterion
development
=
6
hours
per
pollutant
(
i.
e.,
18
hours
for
3
pollutants
[
14
potential
pollutants
divided
by
5
permit
years]).

States
may
develop
additional
human
health
and
wildlife
criteria
for
some
pollutants
where
data
already
exists.
EPA
has
estimated
an
annual
burden
of
2,092.8
hours
based
on
the
following:

°
search
for
information:
40
hours/
pollutant
(
i.
e.,
872
hours,
considering
the
106
pollutants
and
3
pollutants
over
the
5­
year
permit
term)

°
evaluate
the
literature
and
calculate
the
criterion:
40
hours/
pollutant
(
i.
e.,
872
hours)
Great
Lakes
Guidance
Permit
ICR
18
°
peer
review:
8
hours/
pollutant
(
i.
e.,
174.4
hours)

°
prepare
the
report
and
document
procedures:
8
hours/
pollutant
(
i.
e.,
174.4
hours).

Finally,
EPA
assumed
that
permittees
would
share
information
using
the
EPA
Information
Clearinghouse
of
water
quality
data
to
reduce
costs.
In
effect,
bioassays
to
support
the
development
of
water
quality
criteria
will
be
conducted
only
once
for
each
of
the
pollutants
of
initial
focus
for
which
this
data
is
not
readily
available.
Since
criteria
have
already
been
developed
for
some
of
the
pollutants
of
initial
focus,
bioassays
to
support
the
development
of
additional
water
quality
criteria
will
be
conducted
for
the
remaining
pollutants.
Further,
because
permits
are
renewed
every
five
years,
EPA
assumed
that
one­
fifth
of
the
criteria
would
be
developed
each
year.

Antidegradation
Policy
Burden
The
antidegradation
provisions
in
the
final
Guidance
applies
to
the
discharge
of
nondeminimus
levels
of
pollutants
to
high
quality
waters.
However,
the
criteria
for
when
an
antidegradation
demonstration
must
be
performed
are
different
for
BCCs
and
non­
BCCs.
The
purpose
of
the
demonstration
is
to
confirm
that
the
permittee
has
evaluated
options
to
reduce
the
extent
of
the
need
to
lower
water
quality.
In
general,
an
antidegradation
demonstration
consists
of
first
performing
a
pollution
prevention
alternatives
analysis
to
identify
prudent
and
feasible
alternatives.
If
no
pollution
prevention
alternatives
are
deemed
prudent
and
feasible,
then
the
permittee
must
identify
alternative
or
enhanced
treatment
techniques.
Finally,
a
permittee
must
demonstrate
that
the
lowering
of
water
quality
is
necessary
to
ensure
social
and
economic
development.

Based
on
compliance
cost
analyses
performed
for
the
regulatory
impact
analysis
of
the
final
Guidance,
EPA
expects
that
five
percent
of
the
3,795
permittees
(
approximately
190)
will
discharge
BCCs.
Assuming
that
one­
fifth
of
these
permittees
will
prepare
and
submit
an
antidegradation
demonstration
in
any
given
year
(
given
a
permit
term
of
five
years),
38
demonstrations
will
be
submitted
annually
for
BCCs.
Assuming
that
60
hours
are
required
to
prepare
the
demonstration
for
BCCs,
then
the
permittee
burden
is
estimated
to
be
about
2,280
hours.

EPA
expects
that
another
five
percent
of
the
permittees
(
approximately
190)
are
likely
to
request
an
increase
in
permit
limits
for
non­
BCCs.
Assuming
that
one­
fifth
of
these
permittees
will
prepare
and
submit
an
antidegradation
demonstration
in
any
given
year
(
given
a
permit
term
of
five
years),
38
demonstrations
will
be
submitted
annually
for
non­
BCCs.
Assuming
that
40
hours
are
required
to
prepare
the
demonstration
for
BCCs,
then
the
permittee
burden
is
estimated
to
be
about
1,520
hours.
The
combined
permittee
burden
associated
with
antidegredation
demonstrations
for
BCCs
and
non­
BCCs
is
thus
3,800
hours.
These
estimates
may
be
conservative
since
all
States
are
already
required
to
have
antidegredation
requirements
in
their
programs.
Great
Lakes
Guidance
Permit
ICR
19
EPA
also
determined
that
it
would
take
a
State
about
two
days
to
review
an
antidegradation
demonstration.
Based
on
a
total
of
76
antidegradation
policy
demonstrations
submitted
annually,
the
State
applications
burden
is
1,216
hours.
This
estimate
does
not
include
burden
and
costs
associated
with
implementing
current
antidegradation
requirements.

WET
Data
Collection
Burden
A
minimum
of
one
year
of
quarterly
acute
or
chronic
WET
testing
using
a
fish
and
a
macroinvertebrate
(
e.
g.,
daphnia)
was
assumed
necessary
to
evaluate
the
need
for
WET
limits
in
a
facility's
permit.
If
the
minimum
data
are
not
available,
then
the
data
would
be
collected
during
the
first
year
of
the
permit
term.
Because
this
is
a
one­
time
data
collection
effort,
it
has
been
placed
under
the
application
information
collection
activities.
Because
WET
testing
requires
specific
expertise
and
equipment,
EPA
assumed
it
would
be
done
by
a
contract
laboratory.
EPA
estimates
that
333
dischargers
will
need
to
conduct
WET
testing
and,
therefore,
anticipates
333
responses.

Consistency
Review
Burden
and
Costs
An
additional
burden
that
will
fall
on
State
governments
is
the
preparation
and
review
of
State
regulations
and
criteria
for
consistency
with
the
Guidance
over
the
course
of
the
first
five
years
of
the
program.
EPA
has
estimated
that
preparation
of
the
materials
for
Federal
review
will
require
40
hours
of
burden
per
State
(
i.
e.,
320
hours
for
all
Great
Lakes
States)
or
64
hours
per
year.
State
review
of
regulations
and
criteria
will
yield
eight
responses
(
one
response
per
state).

6.1.2
DISCHARGE
AND
MONITORING
REPORT
BURDEN
The
increase
in
discharge
and
monitoring
report
burden
due
to
Guidance
provisions
addressing
monitoring
and
reporting,
is
estimated
to
be
24,607
hours
annually.
Guidance
activities
that
may
result
in
increased
respondent
burden
include
monitoring
and
reporting
requirements
for:

°
WQBEL
compliance
monitoring
°
WET
limit
compliance
monitoring
°
PMPs
monitoring
and
reporting
°
bioconcentration
studies
for
BCCs
below
analytical
detection
levels.

Since
the
Guidance
does
not
establish
specific
record­
keeping
requirements,
no
additional
burdens
and
costs
are
assumed
for
record
keeping
over
those
estimated
in
the
Discharge
Monitoring
Report
ICR.

Based
on
previous
experience
and
interviews
with
program
personnel,
EPA
determined
that
approximately
30
percent
of
Guidance­
related
monitoring
associated
with
WQBELs
and
PMPs
would
be
conducted
by
outside
laboratories.
Because
monitoring
for
WET
limits
and
performing
bioconcentration
studies
require
more
sophisticated
analyses,
EPA
assumed
all
WET
monitoring
and
bioconcentration
studies
would
be
conducted
by
outside
laboratories.
Great
Lakes
Guidance
Permit
ICR
20
Great
Lakes
Guidance
Permit
ICR
21
WQBEL
Compliance
Monitoring
Burden
Based
on
the
Assessment
of
Compliance
Costs
Resulting
from
Implementation
of
the
Final
Great
Lakes
Water
Quality
Guidance
(
March
13,
1995),
and
the
methodology
for
determining
burden
developed
in
the
Discharge
Monitoring
Report
ICR,
discharger
burden
associated
with
the
Guidance
compliance
monitoring
was
estimated
to
be
153
hours
annually.

Discharger
burden
for
monitoring
was
based
on
the
pollutants
that
were
determined
most
likely
to
need
WQBELs
based
on
implementation
of
methodologies
consistent
with
the
Guidance.
Current
sampling
and
monitoring
frequencies
for
those
Guidance
pollutants
of
initial
focus
that
have
current
permit
limits
or
monitoring
requirements
were
determined
in
the
Assessment
of
Compliance
Costs
Resulting
from
Implementation
of
the
Final
Great
Lakes
Water
Quality
Guidance
(
March
13,
1995).
Based
on
the
potential
for
a
facility's
discharge
to
exceed
a
Guidance­
based
WQBEL,
the
variability
of
the
flow,
the
treatment
employed,
and
the
types
of
pollutants,
the
need
for
more
frequent
monitoring
was
evaluated.
In
most
cases,
existing
monitoring
requirements
in
the
permit
were
deemed
adequate
as
State
policy
often
dictated
the
frequency
of
monitoring
used
in
a
permit.
Also,
if
additional
parameters
were
added,
the
monitoring
frequencies
were
established
at
a
frequency
similar
to
the
existing
monitoring
requirements
of
other
parameters.

The
methodology
for
determining
discharger
monitoring
burden
is
described
in
detail
in
the
Discharge
Monitoring
Report
ICR.
Briefly,
respondent
burden
for
monitoring
was
defined
to
equal
the
sum
of
the
time
required
to
collect
samples,
time
required
to
analyze
pollutants,
and
the
time
required
to
prepare
a
report.
Based
on
the
methodology
described
in
the
Discharge
Monitoring
Report
ICR,
EPA
determined
that
only
the
time
required
to
analyze
pollutants
would
increase
as
a
result
of
WQBEL
monitoring
based
on
implementation
of
the
Guidance.
The
Discharge
Monitoring
Report
ICR
estimated
that
one
half
hour
would
be
required
for
each
monitoring
event
(
i.
e.,
each
pollutant)
per
year.
Thus,
the
time
required
to
analyze
for
pollutants
is
defined
as:

Burden
=
Number
of
Pollutants
*
0.5
Hours/
Pollutant
Based
on
the
results
from
the
Assessment
of
Compliance
Costs
Resulting
from
Implementation
of
the
Final
Great
Lakes
Water
Quality
Guidance
(
March
13,
1995),
EPA
estimated
that
an
additional
176
facilities
will
require
WQBEL
monitoring
for
306
pollutants
as
a
result
of
implementation
of
State,
Tribal,
or
Federal
provisions
consistent
with
the
Guidance
(
see
Exhibit
6­
2).
This
results
in
a
monitoring
burden
of
153
hours
each
year
and
the
responses.

WET
Limit
Compliance
Monitoring
Burden
Similar
to
pollutant­
specific
WQBELs,
if
a
WET
limit
is
established
for
a
facility,
then
periodic
compliance
monitoring
would
be
required.
Based
on
the
Assessment
of
Compliance
Costs
Resulting
from
Implementation
of
the
Final
Great
Lakes
Water
Quality
Guidance
(
March
13,
1995),
existing
State
WET
limits
and
compliance
monitoring
requirements
were
deemed
Great
Lakes
Guidance
Permit
ICR
22
adequate
for
those
facilities
that
required
WET
limits.
Therefore,
no
additional
Guidance
burden
was
estimated
related
to
implementation
of
the
provisions
for
WET
compliance
monitoring.

EXHIBIT
6­
2
SUMMARY
OF
ANNUAL
RESPONDENT
BURDEN
FOR
WQBEL
COMPLIANCE
MONITORING
Discharger
Category
Number
of
Pollutants1
Burden
(
Hours
per
Year)

Major
Dischargers
Food
and
Food
Products
0
0.0
Inorganic
Chemicals
12
6.0
Metal
Finishing
7
3.5
Mining
7
3.5
Metals
Manufacturing
64
32.0
Miscellaneous
8
4.0
Municipals
(
POTWs)
94
47.0
Organic
Chemical
Man./
Petroleum
Refining
15
7.5
Pulp
and
Paper
83
41.5
Steam
Electric
16
8.0
Major
Dischargers
Subtotal
306
153.0
Minor
Dischargers
Municipals
0
0.0
Non­
Municipals
0
0.0
Minor
Dischargers
Subtotal
0
0.0
Total
306
153.0
1.
Numbers
represent
total
number
of
pollutants
within
an
industrial
category.
2.
Based
on
176
discharger
responses
per
year.
Great
Lakes
Guidance
Permit
ICR
23
Pollutant
Minimization
Programs
Burden
After
State,
Tribal,
or
Federal
promulgation
of
provisions
consistent
with
the
Guidance,
permittees
are
required
to
establish
PMPs
for
pollutants
for
which
WQBELs
are
below
quantification
levels.
Total
discharger
burden
associated
with
the
establishment
of
PMPs
was
estimated
to
be
4,031
hours
annually.
Information
collection
activities
associated
with
PMPs
include:

°
annual
review/
semi­
annual
monitoring
of
potential
sources
of
the
pollutants
°
quarterly
influent
monitoring
and
reporting
°
development
and
submittal
of
a
control
strategy,
including
implementation
of
appropriate
practicable
control
measures
°
annual
status
report.

Permittee
burden
associated
with
an
annual
review
and
semi­
annual
monitoring
of
potential
sources,
and
quarterly
influent
monitoring
and
reporting
was
calculated
based
on:

°
numbers
of
potential
sources
of
pollutants
and
number
of
pollutants
with
WQBELs
set
below
the
detection
limit
as
identified
in
the
Assessment
of
Compliance
Costs
Resulting
from
Implementation
of
the
Final
Great
Lakes
Water
Quality
Guidance
(
March
13,
1995)

°
the
Discharge
Monitoring
Report
ICR
methodology
for
determining
time
required
for
analyzing
pollutants
described
above.

The
respondent's
time
required
to
analyze
for
pollutants
under
PMPs
was
calculated
using
the
following
equation:

[(#
Potential
Sources
of
Pollutants
*
2/
yr)
+
(
4/
yr
*
#
WQBELS
Set
Below
MDL)]
*
0.5.

EPA
estimates
that
the
State
government
burden
for
reviewing
an
approvable
control
strategy,
one
component
of
a
permittee's
PMP,
is
about
4
hours
per
facility.
The
Assessment
of
Compliance
Costs
Resulting
From
Implementation
of
the
Final
Great
Lakes
Water
Quality
Guidance
(
March
13,
1995)
states
that
about
137
municipal
and
40
non­
municipal
facilities
would
be
required
to
develop
approvable
control
strategies.
Therefore,
the
annual
State
monitoring
burden
was
estimated
to
be
about
708
hours
to
review
the
177
responses
from
facilities.
State
review
will
yield
177
state
responses.

In
sum,
respondent
burden
associated
with
PMP
monitoring
is
estimated
to
be
about
4,739
hours
annually
(
see
Exhibit
6­
3).
Great
Lakes
Guidance
Permit
ICR
24
EXHIBIT
6­
3
SUMMARY
OF
ANNUAL
RESPONDENT
BURDEN
FOR
IMPLEMENTING
PMPS
Discharger
Category
#
of
Potential
Sources
of
Pollutants
#
WQBELs
Below
Detection
Levels
Burden
(
Hours)

Major
Dischargers
Food
and
Food
Products
0
0
0.00
Inorganic
Chemicals
24
4
32.00
Metal
Finishing
0
0
0.00
Mining
3
3
9.00
Metals
Manufacturing
0
0
0.00
Miscellaneous
8
45
98.00
Municipals
(
POTWs)
2,579
549
3,677.00
Organic
Chemicals
Man./
Petroleum
Refining
15
30
75.00
Pulp
and
Paper
46
47
140.00
Steam
Electric
0
0
0.00
Major
Dischargers
Subtotal
2,675
678
4,031.00
Minor
Dischargers
Municipals
0
0
0
Non­
Municipals
0
0
0
Minor
Dischargers
Subtotal
0
0
0
State
Government
Subtotal
708
Total
2,675
678
4,739
1.
Based
on
177
discharger
responses
and
177
State
responses
per
year.
Great
Lakes
Guidance
Permit
ICR
25
Bioconcentration
Studies
Burden
States
and
Tribes
may,
but
are
not
required
to,
direct
permittees
to
use
fish
monitoring
and
other
bio­
uptake
studies
to
evaluate
PMP
performance
where
WQBELs
are
established
below
analytical
detection
limits.
Such
studies
would
require
sampling
and
laboratory
analysis
of
fish
tissue.
Consistent
with
the
Assessment
of
Compliance
Costs
Resulting
from
Implementation
of
the
Final
Great
Lakes
Water
Quality
Guidance
(
March
13,
1995),
only
analytical
costs
were
estimated.
Because
the
fish
tissue
testing
requires
special
expertise,
EPA
assumed
that
permittees
would
contract
with
laboratories
to
conduct
such
studies.
EPA
estimates
that
170
permittees
will
conduct
bioconcentration
studies
and
submit
responses.

6.1.3
MODIFICATION
AND
VARIANCE
BURDEN
Additional
respondent
burden
associated
with
preparing
requests
for
regulatory
relief
options
available
through
the
Guidance
is
estimated
to
be
10,634
hours.

To
be
granted
relief
from
provisions
adopted
consistent
with
the
Guidance,
it
is
assumed
that
the
permittee
will
need
to
perform
additional
monitoring
or
special
studies,
etc.,
to
support
its
request.
Based
on
EPA's
Assessment
of
Compliance
Costs
Resulting
from
Implementation
of
the
Final
Great
Lakes
Water
Quality
Guidance
(
March
13,
1995),
under
the
low­
end
cost
estimate
EPA
conservatively
estimates
that
regulatory
relief
would
be
requested
for
a
total
of
87
pollutants
(
from
59
facilities).
EPA
assumes
that
one­
fifth
(
or
about
18)
will
be
requested
each
year.
This
will
yield
18
permittee
responses
per
year.
Permittee
burden
to
prepare
and
submit
a
request
for
regulatory
relief
will
vary
depending
upon
the
type
of
relief
being
pursued
(
e.
g.,
criteria
modification,
alternative
mixing
zone,
etc.).
Based
on
a
mid­
range
of
costs
to
pursue
regulatory
relief
provided
by
EPA
Region
and
State
contacts
(
see
Section
6.2.3)
and
dividing
by
the
private
sector
hourly
rate
of
$
56.64,
total
respondent
burden
to
prepare
and
submit
variance
requests
is
estimated
to
be
9,050
hours
annually.

EPA
estimated
the
state
government
burden
associated
with
requests
for
regulatory
regulation
relief
to
be
approximately
1,584
hours.
This
review
of
the
18
permittee
requests
will
result
in
18
state
responses
per
year.
To
determine
the
States'
burden,
EPA
estimated
that
the
governments
would
require:


four
hours
to
review
a
regulatory
relief
request
for
completion,
including
any
contact
with
the
permittee
for
additional
information

four
hours
for
public
notice
and
comment
(
assuming
the
regulatory
relief
mechanism
is
independent
of
regular
permit
public
notice)


ten
days
(
80
hours)
to
analyze
the
regulatory
relief
option
request,
justify
the
decision,
and
prepare
a
permit
modification
if
necessary.

6.2
ESTIMATING
RESPONDENT
COST
Great
Lakes
Guidance
Permit
ICR
26
EXHIBIT
6­
4
SUMMARY
OF
RESPONDENT
COST
Annual
Respondent
Cost
($
1998)

Applications
Cost
$
2,115,522
Monitoring
Cost
$
1,842,087
Modification
and
Variance
Cost
$
562,749
Total
Respondent
Cost
$
4,520,358
Respondent
costs
are
the
sum
of
labor
costs
and
contractor
costs.
Total
respondent
costs
associated
with
the
information
collection
requirements
of
State/
Tribal
or
Federal
provisions
consistent
with
the
Guidance
in1998
were
estimated
to
be
$
4,520,358
annually
(
see
Exhibit
6­
4).
In
calculating
this
cost
in
1998,
EPA
assumed
the
following:

°
the
average
annual
salary
for
Federal
and
State
employees
is
$
41,185;
this
is
equivalent
to
the
salary
of
a
GS­
9,
Step
10
Federal
employee.
At
2,080
labor
hours
per
year,
the
hourly
rate
is
$
19.80.
Overhead
cost
for
Federal
and
State
employees
are
expected
to
be
60
percent,
or
$
11.88
per
hour,
yielding
a
total
hourly
rate
of
$
31.68.

°
the
average
annual
salary
in
the
private
sector
is
14
percent
higher
than
Federal
and
State
salaries,
creating
an
average
annual
salary
of
$
46,951
and
an
hourly
rate
of
$
22.57.
Assuming
a
fringe
rate
of
50
percent
and
a
67
percent
overhead
and
profit
rate,
the
total
private
sector
hourly
rate
is
$
56.64
[$
22.57*
1.5*
1.67].

°
the
average
annual
salary
of
a
POTW
employee
is
equivalent
to
that
of
a
GS­
7,
Step
1
Federal
employee.
The
annual
salary
of
this
worker
is
$
25,348;
the
hourly
rate
is
$
12.19.
Assumed
overhead
costs
add
an
additional
50
percent
to
these
costs.
Thus,
the
average
cost
of
a
POTW
worker
is
$
38,022
per
year,
or
$
18.28
per
hour.

Respondent
costs
estimated
in
this
ICR
are
those
associated
with
the
Guidance
and
are
over
and
above
the
respondent
costs
estimated
in
the
following
ICRs
which
deal
with
similar
costs
and
burdens
for
the
NPDES
permitting
program:

°
Applications
ICR
°
Discharge
Monitoring
Report
ICR
°
Modification
and
Variance
ICR.
Great
Lakes
Guidance
Permit
ICR
27
6.2.1
APPLICATIONS
COST
Due
to
implementation
of
the
Guidance
requirements,
respondent
costs
associated
with
NPDES
permit
applications
are
estimated
to
be
approximately
$
2,115,522
annually.
Respondent
application
costs
are
associated
with:

°
bioassays
to
support
the
development
of
water
quality
criteria
for
the
138
pollutants
of
initial
focus
°
studies
to
identify
and
provide
information
on
antidegradation
control
measures
that
will
guard
against
the
reduction
of
water
quality
in
the
Great
Lakes
system
°
whole
effluent
toxicity
testing
performed
to
meet
minimum
data
requirements
to
evaluate
the
need
for
WET
limits.

Costs
Associated
With
Studies
to
Support
the
Development
of
Water
Quality
Criteria
Annual
respondent
costs
associated
with
developing
Tier
I
numerical
criteria
based
on
water
quality
tests
were
estimated
to
total
approximately
$
1,304,326
(
see
Exhibit
6­
5
and
oversight
costs
below).

Based
on
experience
and
the
opinion
of
relevant
EPA
experts,
EPA
determined
that
bioassays
to
support
the
development
of
water
quality
criteria
would,
in
almost
all
cases,
be
conducted
by
outside
laboratories.
Of
the
138
Guidance
pollutants
of
initial
focus,
Tier
I
human
health
criteria
have
already
been
developed
for
18
pollutants;
Tier
I
wildlife
criteria
have
been
developed
for
four
pollutants;
and
Tier
I
aquatic
life
criteria
have
been
developed
for
16
pollutants.
Review
of
the
literature
indicates
that
human
health
criteria
can
potentially
be
calculated
for
an
additional
106
pollutants,
and
wildlife
criteria
for
an
additional
three
pollutants.
The
Guidance
does
not
require
States
to
adopt
provisions
requiring
development
of
wildlife
toxicity
test
data
for
use
in
the
Tier
I
or
Tier
II
methodologies;
therefore,
respondents
would
not
be
expected
to
conduct
studies
to
support
the
development
of
wildlife
criteria.
Further,
respondents
would
not
be
expected
to
conduct
aquatic
life
bioassays
for
the
52
pollutants
that
have
been
identified
as
carcinogens
because
the
human
health
criteria
for
such
pollutants
would
always
be
more
stringent;
the
eight
pollutants
that
have
been
identified
as
BCCs
due
to
the
associated
high
bioaccumulation
factor;
and
nine
pollutants
for
which
national
criteria
have
been
developed
since
nearly
enough
information
has
already
been
collected
on
such
pollutants.
Therefore,
respondents
are
assumed
to
conduct
bioassays
to
support
the
development
of
water
quality
criteria
for
14
human
health
and
53
aquatic
life
pollutants.
Further,
because
permits
are
renewed
every
five
years,
it
was
assumed
that
one­
fifth
(
i.
e.,
three
human
health
and
11
aquatic
life)
of
the
criteria
would
be
developed
each
year.

For
each
of
the
pollutants
that
may
require
Tier
I
tests,
EPA
assumed
the
following:
Great
Lakes
Guidance
Permit
ICR
28
°
Aquatic
life
acute
tests:
$
2,600
each
for
eight
species
per
pollutant
(
i.
e.,
a
cost
of
$
20,800
per
pollutant
for
11
pollutants)
Criteria
development:
56
hours
per
pollutant
using
an
outside
consultant
(
i.
e.,
a
cost
of
$
3,172
per
pollutant)

°
Aquatic
life
chronic
tests:
$
11,500
each
for
three
species
per
pollutant
(
i.
e.,
a
cost
of
$
34,500
per
pollutant
for
11
pollutants)
Criteria
development:
56
hours
per
pollutant
using
an
outside
consultant
(
i.
e.,
a
cost
of
$
3,172
per
pollutant)

°
Human
health
tests:
$
70,000
for
a
LD
50
test
and
$
100,000
for
a
90­
day
subchronic
study
(
i.
e.,
$
170,000
per
pollutant
for
3
pollutants)
Criteria
development:
56
hours
per
pollutant
using
an
outside
consultant
(
i.
e.,
a
cost
of
$
3,172
per
pollutant).

Costs
of
overseeing
the
outside
laboratories
at
10
hours
a
laboratory
were
$
4,570
for
POTWs
and
$
28,830
for
private
industry,
for
a
total
of
$
33,418
in
discharger
labor
costs.

EPA
estimated
State
costs
of
$
73,308
associated
with
the
review
of
Tier
I
criteria
development
($
6,447
for
review
of
aquatic
criteria,
$
570
for
human
health
criteria,
and
$
66,300
for
additional
human
health
and
wildlife
criteria).
It
was
assumed
that
only
the
minimum
number
of
studies
would
be
submitted
for
review.
Because
the
Guidance
does
not
require
States
to
develop
wildlife
criteria
using
the
Tier
II
methodology,
studies
would
not
be
expected
to
be
submitted
to
support
the
development
of
Tier
I
wildlife
criteria.

The
costs
presented
above
are
conservative
(
i.
e.,
err
on
the
high
side)
in
that
they
do
not
account
for
data
that
has
already
been
collected
and
could
be
used
to
support
the
development
of
criteria
in
conjunction
with
the
new
data.
They
also
do
not
discount
the
costs
attributable
to
existing
requirements
in
State
and
Federal
programs
to
develop
water
quality
criteria
under
specified
circumstances.
In
developing
the
costs,
it
was
also
assumed
that
respondents
would
undertake
the
responsibility
of
collecting
the
supporting
data
even
though
it
is
not
required
by
the
Guidance.
However,
in
estimating
the
costs,
EPA
has
assumed
that
respondents
will
coordinate
perfectly
in
the
data
collection
which
may
not
occur.
Great
Lakes
Guidance
Permit
ICR
29
EXHIBIT
6­
5
ANNUAL
RESPONDENT
COST
FOR
BIOASSAYS
TO
SUPPORT
THE
DEVELOPMENT
OF
WATER
QUALITY
CRITERIA
($
1998)

Cost
per
Pollutant
Number
of
Pollutants
Annual
Discharger
Labor
Cost
Annual
Discharger
O&
M
Cost
Annual
State
Labor
Cost
Aquatic
Life
Acute
Tests
$
23,972
11
$
0
$
263,692
$
6,447
Aquatic
Life
Chronic
Tests
$
37,672
11
$
0
$
414,392
Human
Health
Tests
$
173,172
3
$
0
$
519,516
$
570
Wildlife
Protection
Tests
$
0
0.00
$
0
$
0
Preparation
of
Additional
Human
Health
and
Wildlife
Criteria
$
66,300
Laboratory
Oversight
Costs
0
$
33,418
$
0
Total
64
$
33,418
$
1,197,600
$
73,308
1.
Based
on
14
discharger
and
14
State
responses
per
year.

Antidegradation
Policy
Cost
Exhibit
6­
6
summarizes
the
estimated
discharger's
labor
costs
associated
with
implementation
of
provisions
consistent
with
the
Guidance
antidegradation
provisions.
Based
on
compliance
cost
analyses
performed
for
the
regulatory
impact
analysis
of
the
final
Guidance,
EPA
expects
that
five
percent
of
3,795
permittees
(
approximately
190)
will
discharge
BCCs.
Conservatively
assuming
that
one­
fifth
(
38)
of
these
permittees
will
prepare
and
submit
an
antidegradation
demonstration
each
year,
the
total
permittee
burden
is
estimated
to
be
about
2,280
hours
annually.
Acknowledging
that
one­
third
of
the
permittees
affected
by
antidegradation
provisions
are
POTWs,
the
permittee
cost
is
estimated
to
be
$
99,986.

EPA
expects
that
five
percent
of
the
permittees
(
approximately
190)
are
likely
to
request
an
increase
in
permit
limits
for
non­
BCCs.
Conservatively
assuming
that
one­
fifth
of
these
respondents
will
prepare
and
submit
an
antidegradation
demonstration
each
year,
the
total
respondent
burden
is
estimated
to
be
about
1,520
hours
annually.
Acknowledging
that
one­
third
of
the
permittees
affected
by
the
final
Guidance
are
POTWs,
the
permittee
cost
is
estimated
to
be
$
66,660.
Great
Lakes
Guidance
Permit
ICR
30
EPA
estimated
the
State
costs
associated
with
antidegradation
demonstration
to
be
$
38,523.
This
estimate
does
not
include
costs
associated
with
implementing
current
requirements.
EPA
determined
that
it
would
take
a
state
about
2
days
to
review
an
antidegradation
demonstration.
They
also
determined
that
approximately
76
antidegradation
policy
demonstrations
would
be
submitted
annually.

EXHIBIT
6­
6
SUMMARY
OF
LABOR
COST
FOR
ANTIDEGRADATION
($
1998)

#
of
Facilities
Burden
Estimate
Cost
per
Hour
Estimated
Labor
Cost
Municipal
­
BCCs
13
760
$
18.28
$
13,893
Non­
Municipal
­
BCCs
25
1,520
$
56.64
$
86,093
Municipal
­
non­
BCCs
13
507.5
$
18.28
$
9,261
Non­
Municipal
­
non­
BCCs
25
1,013.5
$
56.64
$
57,399
Permittee
Subtotal
76
3,800
$
166,646
State
Subtotal
76
1,216
$
31.68
$
38,523
Total
76
5,016
$
205,169
1.
Based
on
76
discharger
and
76
State
responses
per
year.

Consistency
Review
Costs
An
additional
burden
that
will
fall
on
State
governments
is
the
preparation
and
review
of
State
regulations
and
criteria
for
consistency
with
the
Guidance
over
the
course
of
the
first
five
years
of
the
program.
The
annual
cost
associated
with
the
preparation
of
the
materials
is
$
2,028
for
all
of
the
Great
Lakes
states.

WET
Data
Collection
Costs
It
was
assumed
that
data
would
be
collected
to
determine
if
WET
limits
should
be
included
in
a
permit.
Because
monitoring
for
WET
limits
requires
more
sophisticated
quarterly
tests
using
a
macroinvertebrate
and
a
fish,
EPA
assumed
all
monitoring
for
WET
limits
would
be
conducted
by
outside
laboratories.
The
costs
of
collecting
data,
and
the
costs
of
monitoring
for
WET
limits
were
estimated
to
be
$
604,000
annually
in
the
Assessment
of
Compliance
Costs
Resulting
from
Implementation
of
the
Final
Great
Lakes
Water
Quality
Initiative
(
March
13,
Great
Lakes
Guidance
Permit
ICR
31
1995)
(
see
Exhibit
6­
7).
These
results
are
based
on
the
assumption
that
acute
WET
tests
on
average
will
cost
$
750
and
chronic
WET
tests
on
average
will
cost
$
1,500.

EXHIBIT
6­
7
SUMMARY
OF
ANNUAL
RESPONDENT
COST
FOR
COLLECTING
DATA
AND
MONITORING
FOR
WET
LIMITS
($
1998)

Discharger
Category
Annual
O
&
M
(
Contractor)
Cost
Major
Dischargers
Mining
Food
Pulp
and
Paper
Inorganic
Chemical
Man.
Org.
Chemical
Man./
Petroleum
Refining
Metal
Manufacturing
Metal
Finishing
Steam
Electric
Miscellaneous
Municipal
(
POTWs)

Subtotal
$
17,000
$
0
$
15,400
$
0
$
138,400
$
0
$
12,000
$
12,000
$
38,400
$
54,000
$
287,200
Minor
Dischargers
Non­
Municipal
Municipal
Subtotal
$
0
$
316,800
$
316,800
Total
$
604,000
1.
Based
on
333
discharger
responses
per
year.

6.2.2
MONITORING
COSTS
Due
to
implementation
of
Guidance
provisions
addressing
monitoring
and
reporting,
respondent
cost
are
estimated
to
be
$
1,842,087
annually.
Guidance
activities
resulting
in
increased
respondent
costs
include
monitoring
and
reporting
requirements
for:

°
WQBEL
compliance
monitoring
°
WET
limit
compliance
monitoring
Great
Lakes
Guidance
Permit
ICR
32
°
PMPs
reporting
and
monitoring
°
bioconcentration
studies
required
when
Guidance­
based
WQBELs
for
BCCs
are
below
analytical
detection
levels.

Based
on
previous
experience
and
interviews
with
program
personnel,
EPA
determined
that
approximately
30
percent
of
Guidance
related
monitoring
associated
with
WQBELs
and
PMPs
would
be
conducted
by
outside
laboratories.
Because
monitoring
for
WET
limits
and
bioconcentration
studies
require
more
sophisticated
tests,
all
related
monitoring
was
assumed
to
be
conducted
by
outside
laboratories.

WQBEL
Compliance
Monitoring
Costs
Respondent
costs,
assuming
approximately
70
percent
of
WQBEL
monitoring
is
conducted
in­
house,
were
estimated
to
be
$
284,120
annually
(
see
Exhibit
6­
8).
These
costs
were
estimated
based
on
the
estimated
analytical
costs
provided
in
the
Assessment
of
Compliance
Costs
Resulting
from
Implementation
of
the
Final
Great
Lakes
Water
Quality
Guidance
(
March
13,
1995)
(
which
were
based
on
a
survey
of
laboratory
costs).

Using
the
labor
rate
established
for
municipal
employees,
the
labor
burden
associated
with
the
cost
of
in­
house
analyses
performed
by
municipal
facilities
($
45,018)
would
be
2,463
hours.
Similarly,
using
the
labor
rate
established
for
private
sector
employees,
the
labor
burden
associated
with
the
cost
of
in­
house
analyses
performed
by
industrial
facilities
($
153,886)
would
be
2,717
hours.

WET
Limit
Compliance
Monitoring
Cost
Similar
to
pollutant­
specific
WQBELs,
if
a
WET
limit
is
established
for
a
facility,
then
periodic
compliance
monitoring
would
be
required.
Based
on
the
Assessment
of
Compliance
Costs
Resulting
from
Implementation
of
the
Final
Great
Lakes
Water
Quality
Guidance
(
March
13,
1995),
existing
State
compliance
monitoring
requirements
were
deemed
adequate
for
those
facilities
that
required
WET
limits.
Therefore,
no
additional
cost
was
estimated
related
to
implementation
of
WET
compliance
monitoring
provisions
consistent
with
the
final
Guidance.
Great
Lakes
Guidance
Permit
ICR
33
EXHIBIT
6­
8
SUMMARY
OF
ANNUAL
RESPONDENT
COST
FOR
WQBEL
COMPLIANCE
MONITORING
Discharger
Category
Annual
Respondent
Cost
($
1998)

In­
house
Labor
Costs
O
&
M
(
Contractor)
Costs
Total
Cost
Major
Dischargers
Food
and
Food
Products
$
0
$
0
$
0
Inorganic
Chemicals
$
12,664
$
5,428
$
18,092
Metal
Finishing
$
1,764
$
756
$
2,520
Mining
$
1,764
$
756
$
2,520
Metals
Manufacturing
$
63,017
$
27,007
$
90,024
Miscellaneous
$
6,526
$
2,797
$
9,323
Municipals
(
POTWs)
$
45,018
$
19,294
$
64,312
Organic
Chemical
Man./
Petroleum
Refining
$
3,780
$
1,620
$
5,400
Pulp
and
Paper
$
54,438
$
23,331
$
77,769
Steam
Electric
$
9,912
$
4,248
$
14,160
Major
Dischargers
Subtotal
$
198,884
$
85,236
$
284,120
Minor
Dischargers
Municipals
$
0
$
0
$
0
Non­
Municipals
$
0
$
0
$
0
Minor
Dischargers
Subtotal
$
0
$
0
$
0
Total
$
198,884
$
85,236
$
284,120
1.
Based
on
176
discharger
responses
per
year.
Great
Lakes
Guidance
Permit
ICR
34
Pollutant
Minimization
Program
Costs
The
Guidance
requires
that
permittees
develop
PMPs
for
pollutants
in
a
discharge
for
which
WQBELs
have
been
established
below
quantification
levels.
Total
respondent
cost
associated
with
the
establishment
of
PMPs
is
estimated
to
be
$
1,013,047
annually
(
see
Exhibit
6­
9).
Information
collection
activities
associated
with
PMPs
include:

°
annual
review
and
semi­
annual
monitoring
of
potential
sources
of
the
pollutants
°
quarterly
influent
monitoring
and
reporting
°
development
and
submittal
of
a
control
strategy,
including
implementation
of
appropriate
practicable
control
measures
°
annual
status
report.

Discharger
cost
associated
with
semi­
annual
monitoring
of
pollutant
sources,
and
quarterly
influent
monitoring
was
estimated
to
be
$
167,324
annually.
It
was
assumed
that
these
sample
analyses
will
be
conducted
by
a
contract
laboratory.

The
one­
time
cost
of
developing
a
control
strategy
was
estimated
to
be
about
$
25,000
per
facility
in
the
Assessment
of
Compliance
Costs
Resulting
from
Implementation
of
the
Final
Great
Lakes
Water
Quality
Guidance
(
March
13,
1995).
It
was
estimated
that
about
137
municipal
and
40
non­
municipal
facilities
would
be
required
to
develop
approvable
control
strategies.
For
this
ICR
it
was
assumed
that
the
one­
time
cost
of
establishment
of
PMPs
would
be
written
off
over
10
years
(
at
an
interest
rate
of
7%).
Therefore,
the
annual
cost
for
developing
the
strategies
was
estimated
to
be
$
681,631.
Based
on
a
private
sector
employee
(
contractor)
labor
rate
of
$
56.64,
this
is
equivalent
to
a
labor
burden
of
12,034
hours.

EPA
estimated
the
State
government
burden
for
reviewing
an
approvable
control
strategy,
which
is
one
component
of
a
permittee's
PMP.
The
estimated
annual
State
government
monitoring
cost
is
$
22,429.

EPA
determined
that
most
permittees
would
use
outside
contractors
to
develop
an
approvable
control
strategy.
Annual
status
reports
were
estimated
in
the
Assessment
of
Compliance
Costs
Resulting
from
Implementation
of
the
Final
Great
Lakes
Water
Quality
Guidance
to
cost
about
$
5,000
per
facility.
EPA
determined
that
annual
status
reports
would
be
prepared
by
outside
contractors.
The
resulting
respondent
O&
M
cost
was
estimated
to
be
approximately
$
141,665
annually
for
177
permittees
expected
to
prepare
and
submit
PMPs
in
the
Assessment
of
Compliance
Costs
Resulting
from
Implementation
of
the
Final
Great
Lakes
Water
Quality
Guidance.
Based
on
a
private
sector
employee
(
contractor)
labor
rate
of
$
56.64,
this
is
equivalent
to
a
labor
burden
of
2,501
hours.
Great
Lakes
Guidance
Permit
ICR
35
EXHIBIT
6­
9
SUMMARY
OF
ANNUAL
RESPONDENT
COST
FOR
POLLUTANT
MINIMIZATION
PROGRAMS
($
1998)

Discharger
Category
PMP
Monitoring
O&
M
(
Contractor)
Costs
for
Approvable
Strategy
O
&
M
(
Contractor)
Costs
for
Annual
Report
Total
Cost
Major
Dischargers
Food
and
Food
Products
$
0
$
0
$
0
$
0
Inorganic
Chemicals
$
529
$
28,476
$
5,695
$
34,699
Metal
Finishing
$
0
$
0
$
0
$
0
Mining
$
103
$
10,678
$
2,136
$
12,916
Metals
Manufacturing
$
0
$
0
$
0
$
0
Miscellaneous
$
2,900
$
26,696
$
5,339
$
34,935
Municipals
(
POTWs)
$
155,033
$
487,641
$
97,528
$
740,202
Organic
Chemical
Man./
Petroleum
Refining
$
1,006
$
26,696
$
5,339
$
33,041
Pulp
and
Paper
$
7753
$
101,444
$
25,628
$
134,825
Steam
Electric
$
0
$
0
$
0
$
0
Major
Dischargers
Subtotal
$
167,324
$
681,631
$
141,665
$
990,618
Minor
Dischargers
Municipals
$
0
$
0
$
0
$
0
Non­
Municipals
$
0
$
0
$
0
$
0
Minor
Dischargers
Subtotal
$
0
$
0
$
0
$
0
State
Governments
$
22,429
$
22,429
Total
$
167,324
$
704,060
$
141,665
$
1,013,047
1.
Based
on
177
discharger
and
177
State
responses
per
year.
Great
Lakes
Guidance
Permit
ICR
36
Bioconcentration
Studies
Permitting
authorities
may
require
bioconcentration
studies
for
WQBELs
included
in
a
permit
that
are
below
detection
limits
based
on
EPA
approved
methods.
EPA
conservatively
assumed
that
such
studies
would
be
required
and
assumed
that
permittees
would
contract
with
laboratories
to
conduct
such
studies.

A
contractor
cost
of
$
5,000
per
pollutant
for
bioconcentration
studies
was
assumed
for
the
costs
estimated
in
the
Assessment
of
Compliance
Costs
Resulting
from
Implementation
of
the
Final
Great
Lakes
Water
Quality
Guidance
(
March
13,
1995).
In
sum,
respondent's
annualized
O&
M
costs
for
bioconcentration
studies
were
estimated
to
be
about
$
450,000.

6.2.3
MODIFICATION
AND
VARIANCE
COSTS
Additional
permittee
cost
associated
with
preparing
requests
for
regulatory
relief
from
provisions
consistent
with
the
Guidance
requirements
is
estimated
to
be
approximately
$
512,568
annually
(
see
Section
6.1.3
for
more
detail).
The
Assessment
of
Compliance
Costs
Resulting
from
Implementation
of
the
Final
Great
Lakes
Water
Quality
Guidance
(
March
13,
1995)
estimates
that
the
cost
to
the
facilities
pursuing
relief
from
Guidance­
based
WQBELS
to
range
between
$
1,000,000
to
$
20,000
per
pollutant
depending
upon
the
type
of
relief
being
pursued.
These
costs
are
based
on
EPA
and
State
experience.
EPA
assumed
a
mid­
range
of
$
200,000
per
pollutant
for
supporting
requests
for
regulatory
relief.
If
18
requests
are
received
per
year
as
assumed
in
Section
6.1.3,
and
assuming
this
one­
time
cost
would
be
annualized
over
a
10
year
period
at
seven
percent
interest,
then
the
annual
costs
associated
with
pursuing
regulatory
relief
options
is
estimated
to
be
$
512,568.

EPA
estimated
the
cost
to
State
government
associated
with
requests
for
regulatory
relief
to
be
$
50,181.

6.3
ESTIMATING
FEDERAL
GOVERNMENT
BURDEN
AND
COSTS
EPA
estimated
annual
Federal
government
burden
to
be
approximately
400
hours
and
cost
$
12,672.
State/
Federal
EPA
estimated
little
additional
Federal
government
applications
burden
or
cost
because
all
the
Great
Lakes
States
are
delegated
NPDES
permitting
authorities.
Great
Lakes
Guidance
Permit
ICR
37
6.3.1
GOVERNMENT
APPLICATIONS
BURDEN
AND
COST
Burden
and
Costs
Associated
With
Studies
to
Support
the
Development
of
Water
Quality
Criteria
EPA
estimated
an
annual
burden
to
the
Federal
government
of
400
hours
to
set­
up
and
maintain
the
water
quality
database
to
serve
as
the
Information
Clearinghouse.
This
results
in
a
cost
of
$
12,672.

Consistency
Review
Burden
and
Costs
The
burden
to
the
Federal
government
is
the
review
of
State
regulations
and
criteria
for
consistency
with
the
Guidance
over
the
course
of
the
first
five
years
of
the
program.
The
review
of
such
materials
will
require
a
burden
of
120
hours
per
State
(
i.
e.,
960
hours
for
all
Great
Lakes
States
or
192
hours
per
year).
The
annual
cost
associated
with
the
preparation
of
the
materials
is
$
6,083.

6.3.2
GOVERNMENT
MONITORING
BURDEN
AND
COST
EPA
estimated
no
additional
Federal
government
monitoring
burden
or
cost.

6.3.3
GOVERNMENT
REGULATORY
RELIEF
OPTION
BURDEN
AND
COST
No
additional
burden
or
cost
was
estimated
for
the
Federal
government.

6.4
TOTAL
UPDATED
BURDEN
HOURS
AND
COSTS
Exhibit
6­
10
presents
the
total
burden
and
costs
to
respondents
and
the
State
government
in
1998
dollars.
To
update
this
cost
to
reflect
increases
in
labor
costs
since
1998,
EPA
applied
the
increase
in
the
employment
cost
index
(
approximately
a
3.5%
average
annual
increase
between
1998
and
2000)
to
the
three­
year
period
from
1999
to
2001.
As
a
result,
the
updated
($
2001
dollar)
burden
and
cost
estimates
from
Exhibit
6­
10
become:

°
Discharger:
37,509
hours,
$
2,028,652
in
labor
costs,
and
$
2,776,407
in
O&
M
(
contractor
costs)

°
State
Government:
5,886
hours,
$
206,742
in
labor
cost
°
Combined:
43,395
hours
and
$
5,011,802
in
total
cost.
Great
Lakes
Guidance
Permit
ICR
38
EXHIBIT
6­
10
SUMMARY
OF
ANNUAL
RESPONDENT
BURDEN
AND
COST
ESTIMATES
FOR
IMPLEMENTATION
OF
GREAT
LAKES
GUIDANCE
($
1998)

Requirement
Discharger
State
Government
Total
Number
of
Responses
Burden
(
Hours)
Labor
Cost
O&
M
Cost
Number
of
Responses
Burden
(
Hours)
Labor
Cost
Number
of
Responses
Burden
(
Hours)
Cost
Applications
Water
Quality
Criteria
Antidegradation
Policy
WET
Data
Collection
Consistency
Review
Applications
Subtotal
141
76
333
NA
423
760
3,800
0
NA
4,560
$
33,418
$
166,645
$
0
NA
$
200,063
$
1,197,600
$
0
$
604,000
NA
$
1,801,600
141
76
NA
8
98
2,314
1,216
NA
64
3,594
$
73,308
$
38,523
NA
$
2,028
$
113,858
28
152
333
8
521
3,074
5,016
0
64
8,154
$
1,304,326
$
205,168
$
604,000
$
2,028
$
2,115,522
Monitoring
WQBELs
WET
Limits
PMPs
BCCs
Monitoring
Subtotal
176
0
177
170
523
5,333
0
18,566
0
23,899
$
206,534
$
0
$
910,563
$
0
$
1,117,097
$
85,236
$
0
$
167,324
$
450,000
$
702,560
NA
NA
177
NA
177
NA
NA
708
NA
708
NA
NA
$
22,430
NA
$
22,430
176
0
354
170
700
5,333
0
19,274
0
24,607
$
291,770
$
0
$
1,100,317
$
450,000
$
1,842,087
Regulatory
Relief
Options
18
9,050
$
512,568
$
0
18
1,584
$
50,181
36
10,634
$
562,749
Total
Guidance
964
37,509
$
1,829,728
$
2,504,160
293
5,886
$
186,469
1,257
43,395
$
4,520,358
NA
=
Not
Applicable
1.
Number
of
responses
is
equal
to
the
number
of
pollutants.
Great
Lakes
Guidance
Permit
ICR
39
Attachment
A
Response
to
comment
from
First
Federal
Register
notice
Great
Lakes
Guidance
Permit
ICR
40
Response
to
Comment:
The
commenter
is
concerned
that
the
information
collection
request
appears
to
seek
only
information
about
the
burdens
and
costs
of
reporting
Guidance
information
to
the
Agency
and
ignores
the
benefits
and
savings
of
providing
such
information.
On
April
16,
1993,
EPA
proposed
the
Water
Quality
Guidance
for
the
Great
Lakes
System
(
58
FR
20802)
as
well
as
the
information
collection
activities
needed
to
implement
it.
As
part
of
its
proposal
EPA
requested
public
comment
on
all
aspects
of
the
Guidance
including
the
collection
of
information.
EPA
carefully
evaluated
these
comments
in
preparing
the
information
collection
requirements
in
the
final
Guidance
that
was
published
on
March
23,
1995
(
60
FR
15366)
and
has
concluded
that
the
benefits
of
collecting
such
information
justify
the
burden
imposed
by
these
activities.
