INFORMATION
COLLECTION
REQUEST
FOR
NATIONAL
POLLUTANT
DISCHARGE
ELIMINATION
SYSTEM
GREAT
LAKES
WATER
QUALITY
GUIDANCE
August
2005
EPA
ICR
Number
1639.05
OMB
Control
Number
2040­
0180
U.
S.
Environmental
Protection
Agency
Office
of
Water/
Office
of
Wastewater
Management
EPA
East
Building
1200
Pennsylvania
Avenue,
NW
Washington,
D.
C.
20460
TABLE
OF
CONTENTS
Page
1.0
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
1
1.1
TITLE
OF
THE
INFORMATION
COLLECTION
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
1
1.2
SHORT
CHARACTERIZATION
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
1
2.0
NEED
FOR
AND
USE
OF
THE
COLLECTION
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4
2.1
NEED
AND
AUTHORITY
FOR
THE
COLLECTION
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4
2.2
USE
AND
USERS
OF
INFORMATION
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5
2.2.1
IDENTIFICATION,
LOCATION,
AND
DESCRIPTION
OF
FACILITY
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5
2.2.2
INFORMATION
RELATED
TO
DISCHARGES
INTO
THE
GREAT
LAKES
SYSTEM
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5
3.0
THE
RESPONDENTS
AND
THE
INFORMATION
COLLECTED
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6
3.1
CHARACTERIZATION
OF
RESPONDENTS
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6
3.2
PUBLIC
NOTICE
REQUIRED
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
7
3.3
INFORMATION
REQUESTED
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
7
3.4
RESPONDENT
ACTIVITIES
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
9
4.0
THE
INFORMATION
COLLECTED:
GOVERNMENT
ACTIVITIES,
COLLECTION,
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
.
.
.
.
.
10
4.1
GOVERNMENT
ACTIVITIES
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
10
4.2
COLLECTION
METHODOLOGY
AND
MANAGEMENT
.
.
.
.
.
.
.
.
.
.
.
.
.
.
10
4.3
SMALL
ENTITY
FLEXIBILITY
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
10
4.4
COLLECTION
SCHEDULE
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
11
5.0
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
12
5.1
NONDUPLICATION
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
12
5.2
CONSULTATIONS
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
12
5.3
EFFECTS
OF
LESS
FREQUENT
COLLECTION
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
13
5.4
GENERAL
GUIDELINES
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
14
5.5
CONFIDENTIALITY
AND
SENSITIVE
QUESTIONS
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
14
6.0
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
15
6.1
ESTIMATING
RESPONDENT
BURDEN
AND
COST
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
15
6.1.1
APPLICATIONS
BURDEN
AND
COST
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
16
6.1.2
DISCHARGE
AND
MONITORING
REPORT
BURDEN
AND
COST
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
20
6.1.3
MODIFICATION
AND
VARIANCE
BURDEN
.
.
.
.
.
.
.
.
.
.
.
.
28
6.2
ESTIMATING
FEDERAL
GOVERNMENT
BURDEN
AND
COSTS
.
.
.
.
.
.
28
6.2.1
GOVERNMENT
APPLICATIONS
BURDEN
AND
COST
.
.
.
29
6.2.2
GOVERNMENT
MONITORING
BURDEN
AND
COST
.
.
.
.
29
6.2.3
GOVERNMENT
REGULATORY
RELIEF
OPTION
BURDEN
AND
COST
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
29
6.3
TOTAL
UPDATED
BURDEN
HOURS
AND
COSTS
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
29
Great
Lakes
Guidance
Permit
ICR
1
Where
EPA
approval
has
not
been
obtained,
EPA
has
specified
by
rule
the
provisions
that
apply.

1
1.0
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1.1
TITLE
OF
THE
INFORMATION
COLLECTION
The
title
of
this
Information
Collection
Request
(
ICR)
is
National
Pollutant
Discharge
Elimination
System
Great
Lakes
Water
Quality
Guidance.
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
prior
ICR
of
the
same
title
(
OMB
Control
Number
2040­
0180),
which
expired
on
September
30,
2004.
For
purposes
of
the
2005
proposed
collection
notice
and
request
for
public
comments,
the
Environmental
Protection
Agency
(
EPA)
updated
the
2004
burden
and
costs
shown
in
this
report
to
reflect
any
relevant
program
changes,
the
transfer
of
some
burden
to
the
Water
Quality
Standards
ICR
(
OMB
Control
Number
2040­
0049),
and
increases
in
labor
costs
since
2001,
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).
Some
of
the
burden
hours
associated
with
applications
and
compliance
in
this
ICR
have
been
placed
in
the
Water
Quality
Standards
(
WQS)
ICR.
The
splitting
of
these
hours
was
done
to
avoid
double
counting
of
the
burden.

The
Guidance
identifies
minimum
water
quality
criteria,
implementation
procedures,
and
antidegradation
provisions
for
the
Great
Lakes
System.
Implementation
of
these
provisions
is
dependent
upon
implementation
of
provisions
consistent
with
the
final
Guidance
by
State
or
Tribal
agencies
or,
if
necessary,
EPA.
Each
of
the
Great
Lakes
System
States
has
developed
and
obtained
EPA
approval1
of
water
quality
standards,
antidegradation
provisions,
and
implementation
procedures
consistent
with
EPA's
Great
Lakes
Guidance.

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
516
major
dischargers
­
319
are
major
municipal
dischargers,
and
197
are
major
industrial
dischargers;
and
2,194
minor
dischargers.
In
sum
there
are
2,710
dischargers
(
516
major,
and
2,194minor)
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
Great
Lakes
Guidance
Permit
ICR
2
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
°
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
publication
the
final
guidance
(
i.
e.,
March
23,
1997),
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
was
required
to
promulgate
them
two
years
after
the
final
guidance
was
published.
Each
of
the
Great
Lakes
System
States
has
developed
and
obtained
EPA
approval
of
water
quality
standards,
antidegradation
provisions,
and
implementation
procedures
consistent
with
EPA's
Great
Lakes
Guidance.
(
See,
65
FR
47864,
Aug.
4,
2000;
65
FR
59732,
Oct.
6,
2000;
65
FR
66502,
Nov.
6,
2000;
65
FR
48517,
Aug.
8,
2000;
65
FR
49573,
Aug.
14,
2000).

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
requirements
promulgated
by
Great
Lakes
States
or
Tribes
consistent
the
final
Guidance,
NPDES
permit
applicants
have
to
submit
additional
information
for
NPDES
permit
modification,
renewal
or
issuance.
Elements
that
may
result
in
information
collection
or
record
keeping
burden
include
the
following:
Great
Lakes
Guidance
Permit
ICR
3
°
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
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
28,797
hours
with
an
associated
cost
of
$
3,070,186.
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
authorized
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
2The
previous
Great
Lakes
ICR
(
EPA
ICR
Number
1639.04)
identified
bioassays
to
support
the
development
of
water
quality
criteria
as
additional
information
that
could
be
needed.
All
burden
hours
associated
with
the
execution
of
bioassays
have
been
transferred
to
the
Water
Quality
Standards
ICR
(
OMB
Control
Number
2040­
0049).

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
following2:

°
monitoring
(
pollutant­
specific
and
whole
effluent
toxicity
or
WET)
°
pollutant
minimization
programs
°
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
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
active
permits
from
PCS,
EPA
determined
that
516
major
and
2,194
minor
point
sources
would
be
affected
(
see
Exhibit
3­
1).
Potentially
affected
facilities
were
determined
based
on
their
discharge
location
(
HUC),
facility
location
(
lat/
long),
zip
code,
or
receiving
water
name.
Unfortunately
PCS
information
lacks
the
quality
and
completeness
to
allow
one
single
parameter
to
be
used,
and
in
the
process
some
assumption
had
to
be
made
(
e.
g.,
if
discharge
location
is
not
available,
when
a
facility
is
located
in
the
Great
Lakes
watershed,
it
is
assumed
that
it
discharges
to
it).

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
10,14
12
Food
20
11
Pulp
and
Paper
26
41
Inorganic
Chemical
Man
281
14
Org.
Chemical
Man./
Petroleum
Refining
28,29
20
Metal
Manufacturing
33
28
Metal
Finishing
34,35,36,37
14
Steam
Electric
4911
54
Miscellaneous
3
Municipal
(
POTWs)
4952
319
Subtotal
516
Minor
Dischargers
Non­
Municipal
969
Municipal
4952
1,225
Subtotal
2,194
Total
Dischargers
2,710
Great
Lakes
Guidance
Permit
ICR
7
The
analysis
from
PCS
shows
a
reduction
in
the
number
of
potentially
affected
facilities
from
the
2001
ICR,
which
had
588
major
and
3,207
minor
facilities.
This
could
be
the
result
of
recent
efforts
to
remove
inactive
or
duplicate
permits
from
PCS,
and
EPA
believes
that
the
new
estimates
are
a
better
representation
of
the
number
of
potentially
affected
facilities.

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
319
municipal
(
publicly
owned
treatment
works
or
POTWs)
and
197
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
2,194
minor
dischargers
in
the
Great
Lakes
System.
Of
these,
1,225
sources
were
determined
to
be
municipal
dischargers
and
969
non­
municipal
dischargers.

3.2
PUBLIC
NOTICE
REQUIRED
PRIOR
TO
ICR
SUBMISSION
TO
OMB
In
compliance
with
the
Paperwork
Reduction
Act
(
44
U.
S.
C.
3501
et
seq),
EPA
solicited
comments
on
the
proposed
information
collection
in
the
Federal
Register
prior
to
submitting
this
renewal
ICR
to
the
Office
of
Management
and
Budget
(
70
FR
30944,
May
31,
2005).
EPA
received
one
comment
that
did
not
pertain
to
this
ICR.

3.3
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
as
codified
in
40
CFR
part
122.
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
June,
2006
(
OMB
No.
2040­
0086)

°
Information
Collection
Request
for
the
National
Pollutant
Discharge
Elimination
System:
Discharge
Monitoring
Reports
(
hereafter,
the
Discharge
and
Monitoring
Report
ICR),
extension
currently
under
review
at
OMB
(
OMB
No.
2040­
0004)
Great
Lakes
Guidance
Permit
ICR
8
°
Information
Collection
Request
for
the
National
Pollutant
Discharge
Elimination
System
Modification
and
Variance
Requests
(
hereafter,
the
Modification
and
Variance
ICR),
effective
through
November,
2006
(
OMB
No.
2040­
0068).

°
Information
Collection
Request
for
the
National
Pollutant
Discharge
Elimination
System
and
Sewage
Sludge
Management
State
Programs,
effective
through
November,
2006
(
OMB
No.
2040­
0057).

Generally,
States
(
and
potentially
Tribes)
have
adopted
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.
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.

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,
2A,
2B,
2C,
2D,
2E,
2F,
2S;
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
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:

°
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
Great
Lakes
Guidance
Permit
ICR
9
authority
uses
the
data
as
the
primary
source
of
information
to
assess
compliance
with
permit
limitations.
Data
also
are
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
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).

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.

3.4
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.
Great
Lakes
Guidance
Permit
ICR
10
°
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,
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
include:

°
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
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:
Great
Lakes
Guidance
Permit
ICR
12
°
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
that
are
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
have
been
promulgated
by
the
States
or
Tribes
or,
where
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
6.0
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6.1
ESTIMATING
RESPONDENT
BURDEN
AND
COST
EPA
has
estimated
the
total
respondent
burden
associated
with
implementation
of
provisions
consistent
with
the
Guidance
to
be
28,797
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.

EXHIBIT
6­
1
SUMMARY
OF
RESPONDENT
BURDEN
Increase
in
Respondent
Burden
(
Hours
per
Year)

Applications
Burden
1,782
Discharge
Monitoring
Report
Burden
16,381
Modification
and
Variance
Burden
10,634
Total
Respondent
Burden
28,797
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
were
estimated
to
be
$
3,070,186
annually
(
see
Exhibit
6­
2).
In
calculating
this
cost,
EPA
assumed
the
following:

Estimates
for
Federal
and
State
labor
rates
were
based
on
the
2003
US
Labor
department
figures
adjusted
to
January
2005
dollars
with
the
Employment
Cost
Index,
whereby
the
average
annual
salary
for
Federal
and
State
employees
is
$
51,126;
this
is
equivalent
to
the
salary
of
a
GS­
9,
Step
10
Federal
employee.
At
2,080
available
labor
hours
per
year,
the
hourly
rate
is
$
24.58.
Overhead
costs
for
Federal
and
State
employees
are
estimated
by
EPA
to
be
60
percent
(
EPA
ICR
Handbook),
or
$
14.75
per
hour,
which
results
in
a
total
hourly
rate
of
$
39.33
($
24.58
+
$
14.75).

The
average
annual
salary
in
the
private
sector
is
14
percent
higher
than
Federal
and
State
salaries,
creating
an
average
annual
salary
of
$
58,284
and
an
hourly
rate
of
$
28.02
in
January
2005
dollars.
Assuming
a
fringe
rate
of
50
percent
and
a
67
percent
overhead
and
profit
rate,
the
Great
Lakes
Guidance
Permit
ICR
3The
previous
Great
Lakes
ICR
(
EPA
ICR
Number
1639.04)
included
in
the
application
burden
and
cost
estimates,
bioassays
to
support
the
development
of
water
quality
criteria.
Those
burden
hours
(
760
burden
hours
from
dischargers
and
2,134
burden
hours
from
state
government)
were
transferred
to
the
water
Quality
Standards
ICR
(
OMB
Control
Number
2040­
0049).

17
total
private
sector
hourly
rate
is
$
70.19
[$
28.02*
1.5*
1.67].

Estimates
for
local
pretreatment
control
authority
employees
(
i.
e.,
POTW
employees)
were
based
on
the
2002
US
Labor
department
figures
for
the
wages
and
salaries
value
for
State
and
local
government
workers
adjusted
to
January
2005
dollars
with
the
Employment
Cost
Index
plus
a
50
percent
overhead
burden;
this
is
equivalent
to
an
hourly
rate
of
$
34.26
($
22.84
+
$
11.42).

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.

EXHIBIT
6­
2
SUMMARY
OF
RESPONDENT
COST
Annual
Respondent
Cost
($
2005)

Applications
Cost
$
797,565
Monitoring
Cost
$
1,575,104
Modification
and
Variance
Cost
$
697,518
Total
Respondent
Cost
$
3,070,186
6.1.1
APPLICATIONS
BURDEN
AND
COST
The
increase
in
respondent
burden
associated
with
NPDES
permit
applications
was
estimated
to
be
approximately
1,782
hours
annually,
costing
respondents
approximately
$
797,565
annually.
Respondent
application
burden
and
costs
are
associated
with:
3
°
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
Great
Lakes
Guidance
Permit
ICR
18
evaluate
the
need
for
WET
limits.

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
bioaccumulative
chemicals
of
concern
(
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
2,710
permittees
(
approximately
136)
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),
27
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
1,620
hours.

EPA
expects
that
another
five
percent
of
the
permittees
(
approximately
136)
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),
27
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
1,080
hours.
The
combined
permittee
burden
associated
with
antidegradation
demonstrations
for
BCCs
and
non­
BCCs
is
thus
2,700
hours.
This
burden
estimate
is
split
equally
between
water
quality
standards
and
permits.
Thus,
the
burden
estimate
for
this
item
in
this
ICR
is
1,350
hours
(
the
remaining
1,350
hours
were
transferred
to
the
Water
Quality
Standards
ICR).
Note
that
these
estimates
may
be
conservative
since
all
States
already
are
required
to
have
antidegredation
requirements
in
their
programs.

EPA
also
determined
that
it
would
take
a
State
about
two
days
to
review
an
antidegradation
demonstration.
Based
on
a
total
of
54
antidegradation
policy
demonstrations
submitted
annually,
the
State
applications
burden
is
864
hours.
This
burden
estimate
also
is
split
equally
between
water
quality
standards
and
permits.
Thus,
the
burden
estimate
for
this
item
in
this
ICR
is
432
hours
(
the
remaining
432
hours
were
transferred
to
the
Water
Quality
Standards
ICR).
This
estimate
does
not
include
burden
and
costs
associated
with
implementing
current
antidegradation
requirements.
Great
Lakes
Guidance
Permit
ICR
19
Overall,
the
antidegradation
policy
burden
in
this
ICR
is
1,782
hours.
As
indicated
above,
within
the
Water
Quality
Standards
ICR,
an
additional
1,782
hours
were
transferred
to
cover
the
antidegradation
policy
burden.

Exhibit
6­
3
summarizes
the
estimated
discharger's
labor
costs
associated
with
implementation
of
provisions
consistent
with
the
Guidance
antidegradation
provisions.
Acknowledging
that
57%
of
the
permittees
affected
by
antidegradation
provisions
are
POTWs,
the
permittee
cost
is
estimated
to
be
$
67,809
EXHIBIT
6­
3
SUMMARY
OF
LABOR
COST
FOR
ANTIDEGRADATION
($
2004)

#
of
Facilities
Burden
Estimate
Cost
per
Hour
Estimated
Labor
Cost
Municipal
­
BCCs
15
450.00
$
34.26
$
15,417
Non­
Municipal
­
BCCs
12
360.00
$
70.19
$
25,268
Municipal
­
non­
BCCs
15
300.00
$
34.26
$
10,278
Non­
Municipal
­
non­
BCCs
12
240.00
$
70.19
$
16,846
Permittee
Subtotal
54
1,350.00
$
67,809
State
Subtotal
54
432.00
$
39.33
$
16,991
Total
54
1,782.00
$
84,800
1.
Based
on
76
discharger
and
76
State
responses
per
year.

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.

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,
1995).
These
results
are
based
on
the
assumption
that
acute
WET
tests
on
average
will
cost
$
750
and
chronic
WET
tests
on
Great
Lakes
Guidance
Permit
ICR
20
average
will
cost
$
1,500.
Exhibit
6­
4
shows
the
updated
costs
to
2005
dollars
using
the
Consumer
Price
Index.

EXHIBIT
6­
4
SUMMARY
OF
ANNUAL
RESPONDENT
COST
FOR
COLLECTING
DATA
AND
MONITORING
FOR
WET
LIMITS
(
2005)

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
$
20,061
$
0
$
18,173
$
0
$
163,322
$
0
$
14,161
$
14,161
$
45,315
$
63,724
$
338,917
Minor
Dischargers
Non­
Municipal
Municipal
Subtotal
$
0
$
373,848
$
373,848
Total
$
712,765
1.
Based
on
333
discharger
responses
per
year.

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.
The
burden
hours
associated
with
these
reviews
are
addressed
in
the
Information
Collection
Request
for
Water
Quality
Standards
(
OMB
Control
Number
2040­
0049)
effective
through
August,
2005.
Therefore,
this
ICR
does
not
include
burden
hours
associated
with
these
activities.
Great
Lakes
Guidance
Permit
ICR
21
6.1.2
DISCHARGE
AND
MONITORING
REPORT
BURDEN
AND
COST
The
increase
in
discharge
and
monitoring
report
burden
due
to
Guidance
provisions
addressing
monitoring
and
reporting,
is
estimated
to
be
24,607
hours
annually.
However,
some
of
these
monitoring
requirement
burden
hours
are
addressed
in
the
Water
Quality
Standards
ICR
and
are
not
included
in
this
ICR
to
avoid
double
counting.
The
Water
Quality
Standards
ICR
covers
8,310
of
the
total
24,607
hours.
Thus,
the
total
burden
estimate
for
monitoring
in
this
ICR
is
16,381
hours
annually.
Due
to
implementation
of
Guidance
provisions
addressing
monitoring
and
reporting,
respondent
cost
are
estimated
to
be
$
1,575,104
annually.

Guidance
activities
that
may
result
in
increased
respondent
burden
and
costs
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.

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
Guidancebased
WQBELs
as
well
as
the
variability
of
the
flow
and
possibly
to
surpass
the
treatment
employed
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,
Great
Lakes
Guidance
Permit
ICR
22
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
5).
This
results
in
a
monitoring
burden
of
153
hours
each
year.

Assuming
approximately
70
percent
of
WQBEL
monitoring
is
conducted
in­
house
and
based
on
the
analytical
costs
provided
in
the
Assessment
of
Compliance
Costs
Resulting
from
Implementation
of
the
Final
Great
Lakes
Water
Quality
Guidance
(
March
13,
1995)
and
the
2001
ICR,
it
is
possible
to
estimate
the
analytical
burden
to
respondent
(
see
Exhibit
6­
5).
However,
some
of
these
monitoring
requirement
burden
hours
are
addressed
in
the
Water
Quality
Standards
ICR
and
are
not
included
in
this
ICR
to
avoid
double
counting.
Exhibit
6­
6
presents
the
total
burden
for
WQBEL
Compliance
Monitoring
and
Analysis
and
the
estimated
costs
after
accounting
for
burden
hours
addressed
in
the
Water
Quality
Standards
ICR.

Using
a
similar
analysis,
the
costs
of
the
analysis
done
by
outside
contractors
were
estimated
to
be
$
105,634.00
(
1,505
hours
contracted
at
$
70.19
per
hour).
Great
Lakes
Guidance
Permit
ICR
23
EXHIBIT
6­
5
SUMMARY
OF
ANNUAL
RESPONDENT
BURDEN
FOR
WQBEL
COMPLIANCE
MONITORING
AND
ANALYSIS
1
Discharger
Category
Number
of
Pollutants2
Monitoring
Burden
(
Hours
per
Year)
Analytical
Burden
(
Hours
per
Year)
Total
Burden
Major
Dischargers
Food
and
Food
Products
0
0.0
0.0
0.0
Inorganic
Chemicals
12
6.0
224.0
230.0
Metal
Finishing
7
3.5
31.0
34.5
Mining
7
3.5
31.0
34.5
Metals
Manufacturing
64
32.0
1,113.0
1,145.0
Miscellaneous
8
4.0
115.0
119.0
Municipals
(
POTWs)
94
47.0
2,463.0
2,510.0
Organic
Chemical
Man./
Petroleum
Refining
15
7.5
67.0
74.5
Pulp
and
Paper
83
41.5
961.0
1,002.5
Steam
Electric
16
8.0
175.0
183.0
Major
Dischargers
Subtotal
306
153.0
5,180.0
5,333.0
Minor
Dischargers
Municipals
0
0.0
0.0
0.0
Non­
Municipals
0
0.0
0.0
0.0
Minor
Dischargers
Subtotal
0
0.0
0.0
0.0
Total
306
153.0
5,180.0
5,333.0
1.
Burden
in
this
table
still
includes
1,678
burden
hours
addressed
in
the
Water
Quality
Standards
ICR.
2.
Numbers
represent
total
number
of
pollutants
within
an
industrial
category.
Based
on
176
discharger
responses
per
year.
Great
Lakes
Guidance
Permit
ICR
24
EXHIBIT
6­
6
SUMMARY
OF
CORRECTED
ANNUAL
RESPONDENT
BURDEN
AND
COSTS
FOR
WQBEL
COMPLIANCE
MONITORING
AND
ANALYSIS
1
Discharger
Category
Total
Corrected
Burden
Total
Corrected
Costs
(
2005)

Major
Dischargers
Food
and
Food
Products
0
$
0
Inorganic
Chemicals
158
$
11,065
Metal
Finishing
24
$
1,660
Mining
24
$
1,660
Metals
Manufacturing
785
$
55,086
Miscellaneous
82
$
5,725
Municipals
(
POTWs)
1,720
$
58,942
Organic
Chemical
Man./
Petroleum
Refining
51
$
3,584
Pulp
and
Paper
687
$
48,230
Steam
Electric
125
$
8,804
Major
Dischargers
Subtotal
3,655
$
194,756
Minor
Dischargers
Municipals
0
0.0
Non­
Municipals
0
0.0
Minor
Dischargers
Subtotal
0
0.0
Total
3,655
$
194,756
1.
Burden
and
cost
in
this
table
account
for
burden
hours
addressed
in
the
Water
Quality
Standards
ICR.

WET
Limit
Compliance
Monitoring
Burden
and
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
WET
limits
and
compliance
monitoring
requirements
were
deemed
adequate
for
those
facilities
that
required
WET
limits.
Therefore,
no
additional
Guidance
burden
Great
Lakes
Guidance
Permit
ICR
25
or
cost
were
estimated
related
to
implementation
of
the
provisions
for
WET
compliance
monitoring.

Pollutant
Minimization
Programs
Burden
and
Cost
Under
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.
The
burden
hours
associated
with
these
reviews
are
addressed
in
the
Information
Collection
Request
for
Water
Quality
Standards
(
OMB
Control
Number
2040­
0049)
effective
through
August,
2005.
Therefore,
this
ICR
does
not
include
burden
hours
associated
with
these
activities.

In
sum,
respondent
burden
associated
with
PMP
monitoring
is
estimated
to
be
about
4,031
hours
annually
(
see
Exhibit
6­
7).
Great
Lakes
Guidance
Permit
ICR
26
EXHIBIT
6­
7
SUMMARY
OF
ANNUAL
RESPONDENT
BURDEN
FOR
IMPLEMENTING
PMPS
Discharger
Category
#
of
Potential
Sources
of
Pollutants
1
#
WQBELs
Below
Detection
Levels
Burden
(
Hours)

Major
Dischargers
Food
and
Food
Products
0
0
0
Inorganic
Chemicals
24
4
32
Metal
Finishing
0
0
0
Mining
3
3
9
Metals
Manufacturing
0
0
0
Miscellaneous
8
45
98
Municipals
(
POTWs)
2,579
549
3,677
Organic
Chemicals
Man./
Petroleum
Refining
15
30
75
Pulp
and
Paper
46
47
140
Steam
Electric
0
0
0
Major
Dischargers
Subtotal
2,675
678
4,031
Minor
Dischargers
Municipals
0
0
0
Non­
Municipals
0
0
0
1.
Based
on
177
discharger
responses
and
177
State
responses
per
year.

Discharger
cost
associated
with
semi­
annual
monitoring
of
pollutant
sources,
and
quarterly
influent
monitoring
was
estimated
to
be
$
197,454.00
annually.
It
was
assumed
that
these
sample
analyses
will
be
conducted
by
a
contract
laboratory.

Based
on
the
costs
for
approval
strategy
and
for
annual
reports
in
the
2001
ICR,
EPA
estimated
the
labor
burden
for
each
of
these
activities.
Exhibits
6­
8
shows
the
final
burden
pollution
minimization
programs.
However,
some
of
these
burden
hours
are
addressed
in
the
Water
Quality
Standards
ICR
and
are
not
included
in
this
ICR
to
avoid
double
counting.
Exhibit
6­
9
presents
the
total
burden
for
Pollutant
Minimization
Programs
and
the
estimated
costs
after
accounting
for
burden
hours
addressed
in
the
Water
Quality
Standards
ICR.
Great
Lakes
Guidance
Permit
ICR
27
EXHIBIT
6­
8
SUMMARY
OF
ANNUAL
RESPONDENT
BURDEN
FOR
POLLUTANT
MINIMIZATION
PROGRAMS
1
Discharger
Category
Burden
for
PMP
Implementation
Burden
for
Approvable
Strategy
Burden
For
Annual
Report
Total
Burden
Major
Dischargers
Food
and
Food
Products
0
0
0
0
Inorganic
Chemicals
32.00
503.00
101.00
636
Metal
Finishing
0
0
0
0
Mining
9.00
189.00
38.00
236
Metals
Manufacturing
0
0
0
0
Miscellaneous
98.00
471.00
94.00
663
Municipals
(
POTWs)
3,677.00
8,609.00
1,722.00
14008
Organic
Chemical
Man./
Petroleum
Refining
75.00
471.00
94.00
640
Pulp
and
Paper
140.00
1,791.00
452.00
2383
Steam
Electric
0
0
0
0
Major
Dischargers
Subtotal
4,031
12,034
2,501
18,566
Minor
Dischargers
Municipals
0
0
0
0
Non­
Municipals
0
0
0
0
Minor
Dischargers
Subtotal
0
0
0
0
Total
4,031
12,034
2,501
18,566
1.
Burden
in
this
table
still
includes
5,840
burden
hours
addressed
in
the
Water
Quality
Standards
ICR.
Great
Lakes
Guidance
Permit
ICR
28
EXHIBIT
6­
9
SUMMARY
OF
CORRECTED
ANNUAL
RESPONDENT
BURDEN
AND
COST
FOR
POLLUTANT
MINIMIZATION
PROGRAMS
1
Discharger
Category
Total
Corrected
Burden
Total
Corrected
Costs
(
2005)

Major
Dischargers
Food
and
Food
Products
0
0
Inorganic
Chemicals
436
$
30,598
Metal
Finishing
0
$
0
Mining
162
$
11,354
Metals
Manufacturing
0
$
0
Miscellaneous
454
$
31,897
Municipals
(
POTWs)
9,601
$
328,946
Organic
Chemical
Man./
Petroleum
Refining
439
$
30,790
Pulp
and
Paper
1,633
$
114,646
Steam
Electric
0
$
0
Major
Dischargers
Subtotal
12,726
$
546,226
Minor
Dischargers
Municipals
0
0
Non­
Municipals
0
0
Minor
Dischargers
Subtotal
0
0
Total
12,726
$
546,226
1.
Burden
and
cost
in
this
table
account
for
burden
hours
addressed
in
the
Water
Quality
Standards
ICR.

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
Great
Lakes
Guidance
Permit
ICR
29
conduct
bioconcentration
studies
and
submit
responses.

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
$
531,033
in
2005
dollars.

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
the
analysis
for
the
2001
ICR,
total
respondent
burden
to
prepare
and
submit
variance
requests
is
estimated
to
be
9,050
hours
annually,
at
a
cost
of
$
635,220
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.

EPA
estimated
the
cost
to
State
government
associated
with
requests
for
regulatory
relief
to
be
$
62,299
6.2
ESTIMATING
FEDERAL
GOVERNMENT
BURDEN
AND
COSTS
EPA
estimated
annual
Federal
government
burden
to
be
approximately
400
hours
and
cost
$
15,732.
State/
Federal
EPA
estimated
little
additional
Federal
government
applications
burden
Great
Lakes
Guidance
Permit
ICR
30
or
cost
because
all
the
Great
Lakes
States
are
authorized
NPDES
permitting
authorities.

6.2.1
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
$
15,732.

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
$
7,551.

6.2.2
GOVERNMENT
MONITORING
BURDEN
AND
COST
EPA
estimated
no
additional
Federal
government
monitoring
burden
or
cost.

6.2.3
GOVERNMENT
REGULATORY
RELIEF
OPTION
BURDEN
AND
COST
No
additional
burden
or
cost
was
estimated
for
the
Federal
government.

6.3
TOTAL
UPDATED
BURDEN
HOURS
AND
COSTS
Exhibit
6­
10
presents
the
total
burden
and
costs
to
respondents
and
the
State
government
in
2005
dollars.
To
update
this
cost
to
reflect
increases
in
labor
costs,
EPA
applied
the
latest
US
Department
of
Labor
reports
on
labor
statistics
adjusted
to
January
2005
using
the
employment
cost
index.
Other
non­
labor
costs
were
adjusted
using
the
Consumer
Price
Index.

The
Great
Lakes
Water
Quality
Guidance
Reporting
Requirements
ICR
approved
by
OMB
in
2001
contains
line­
by­
line
estimates
of
burden
hours
similar
to
the
estimates
presented
in
this
document.
Some
of
the
burden
contemplated
in
the
2001
ICR
has
been
transfer
to
the
Water
Quality
Standards
ICR
(
OMB
Control
Number
2040­
0049).
Exhibit
6.11
presents
a
comparison
of
burden
estimates
between
the
2001
and
the
2005
ICR.
Great
Lakes
Guidance
Permit
ICR
31
To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
Number
OW­
2003­
0030,
which
is
available
for
public
viewing
at
the
EPA
Water
Docket
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
EPA
Water
Docket
is
(
202)
566­
2426.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
When
in
the
system,
select
"
search,"
then
key
in
the
Docket
ID
Number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Please
include
the
EPA
Docket
ID
Number
OW­
2003­
0030
and
OMB
Control
Number
2040­
0180
in
any
correspondence.
Great
Lakes
Guidance
Permit
ICR
32
EXHIBIT
6­
10
SUMMARY
OF
ANNUAL
RESPONDENT
BURDEN
AND
COST
ESTIMATES
FOR
IMPLEMENTATION
OF
GREAT
LAKES
GUIDANCE
($
2005)

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
0
0
$
0
$
0
0
0
$
0
0
0
$
0
Antidegradation
Policy
76
1350
$
67,809
$
0
76
432
$
16,991
152
1,782
$
84,800
WET
Data
Collection
333
0
$
0
$
712,765
0
0
$
0
333
0
$
712,765
Applications
Subtotal
409
1350
$
67,809
$
712,765
76
432
$
16,991
485
1,782
$
797,565
Monitoring
WQBELs
176
3,655
$
194,756
$
105,634
0
0
$
0
176
3,655
$
300,390
WET
Limits
0
0
$
0
$
0
0
0
$
0
0
0
$
0
PMPs
177
12,726
$
546,226
$
197,454
0
0
$
0
177
12,726
$
743,680
BCCs
170
0
$
0
$
531,033
0
0
$
0
170
0
$
531,033
Monitoring
Subtotal
523
16381
$
740,983
$
834,121
0
0
$
0
523
16,381
$
1,575,104
Regulatory
Relief
Options
18
9,050
$
635,220
$
0
18
1,584
$
62,299
36
10,634
$
697,518
Total
Guidance
950
26,781
$
1,444,011
$
1,546,886
94
2,016
$
79,289
1,044
28,797
$
3,070,186
Great
Lakes
Guidance
Permit
ICR
33
EXHIBIT
6­
11
CHANGE
IN
BURDEN
2005
2001
Discharger
Burden
(
Hours)
State
Burden
(
Hours)
Discharger
Burden
(
Hours)
State
Burden
(
Hours)
Reason
Applications
Water
Quality
Criteria
0
0
760
2,314
Transfer
to
the
Water
Quality
Standards
ICR
Antidegradation
Policy
1,350
432
3,800
1,216
Transfer
to
the
Water
Quality
Standards
ICR,

decrease
in
potentially
affected
facilities
WET
Data
Collection
0
0
0
0
Consistency
Review
0
0
0
64
Transfer
to
the
Water
Quality
Standards
ICR
Applications
Subtotal
1,350
432
4,560
3,594
Monitoring
WQBELs
3,655
0
5,333
0
Transfer
to
the
Water
Quality
Standards
ICR
WET
Limits
0
0
0
0
PMPs
12,726
0
18,566
708
Transfer
to
the
Water
Quality
Standards
ICR
BCCs
0
0
0
0
Monitoring
Subtotal
16,381
0
23,899
708
Regulatory
Relief
Options
9,050
1,584
9,050
1,584
Total
Guidance
26,781
2,016
37,509
5,886
