Applications
ICR
8/
5/
99
1
1.
SHORT
CHARACTERIZATION
This
Information
Collection
Request
(
ICR)
calculates
the
burden
and
costs
associated
with
permit
applications
for
National
Pollutant
Discharge
Elimination
System
(
NPDES)
discharges
and
sewage
sludge
management
activities.
It
is
an
update
of
the
Information
Collection
Request
for
Applications
for
the
National
Pollutant
Discharge
Elimination
System
Discharge
Permit
and
the
Sewage
Sludge
Management
Permit
(
OMB
Control
No.
2040­
0086,
ICR
No.
0226).
It
also
integrates
and
updates
application
requirements
discussed
in
one
amendment
ICR
approved
by
OMB:

°
National
Pollutant
Elimination
System
Permit
Application
Requirements
 
Form
2A
and
2S
(
Final
Rule)
(
OMB
Control
No.
2040­
0086,
ICR
No.
0226.14,
approved
January
13,
1999).

The
Clean
Water
Act
(
CWA)
authorizes
the
Environmental
Protection
Agency
(
EPA)
to
issue
permits
for
the
discharge
of
pollutants
to
waters
of
the
United
States.
The
Act
also
authorizes
EPA
to
issue
permits
for
the
use
and
disposal
of
sewage
sludge.
EPA
regulates
discharges
of
pollutants
to
waters
of
the
United
States
under
its
NPDES
program.
Such
discharges
include
domestic
wastewater,
industrial
wastewater,
and
storm
water.
The
Agency
regulates
sewage
sludge
use
and
disposal
activities
under
its
Sludge
Management
program.
EPA
issues
permits
as
a
regulatory
control
mechanism
for
both
types
of
activities.

CWA
Section
402(
b)
allows
States
(
defined
to
include
Indian
Tribes
and
U.
S.
territories)
to
acquire
authority
for
the
NPDES
and
Sludge
Management
programs.
This
authority
enables
them
to
issue
and
administer
NPDES
permits.
As
of
November
1998,
43
States
and
the
Virgin
Islands
have
NPDES
permit
program
authority,
and
3
States
(
Oklahoma,
Utah,
and
Texas)
have
an
approved
sewage
sludge
management
program.
No
Indian
Tribes
have
NPDES
Authority
as
yet.
In
States
that
do
not
have
authority
for
these
programs,
EPA
issues
and
administers
NPDES
permits.
Because
some
permit
applications
are
processed
by
States
and
some
by
EPA,
this
ICR
calculates
government
burden
and
costs
for
States
and
EPA.

For
most
NPDES
permits,
EPA
has
developed
standard
application
forms.
In
some
cases,
such
as
requests
for
additional
information
and
storm
water
applications
from
municipal
separate
sewer
systems,
standard
forms
do
not
exist
either
because
EPA
is
currently
developing
them
or
because
standard
forms
are
not
appropriate
for
the
information
collected.
For
those
application
forms
that
have
been
developed,
each
form
requests
information
necessary
for
issuing
permits
to
the
respective
applicants.
Applicants
include
publicly
owned
treatment
works
(
POTWs),
privately
owned
treatment
works,
new
and
existing
industrial
manufacturing
and
commercial
dischargers,
storm
water
dischargers,
treatment
works
treating
domestic
sewage
(
TWTDS),
and
others.
Depending
on
the
application
form
they
are
using,
applicants
may
be
required
to
supply
information
about
their
facilities,
discharges,
treatment
systems,
sewage
sludge
use
and
disposal
practices,
pollutant
sampling
data,
or
other
relevant
information.

In
addition,
Section
308
of
the
CWA
requires
EPA
to
request
from
dischargers
any
information
that
may
be
reasonably
required
to
carry
out
the
objectives
and
provisions
of
the
Act.
Under
this
authority,
EPA
sometimes
requests
information
supplemental
to
that
contained
in
permit
applications.
In
its
burden
and
cost
calculations,
this
ICR
includes
requests
for
information
supplemental
to
permit
applications.
Applications
ICR
8/
5/
99
2
In
addition
to
Section
308,
other
parts
of
the
CWA
and
federal
regulations
authorize
EPA
to
collect
information
that
supplements
permit
applications.
For
instance,
CWA
Section
403(
c)
requires
that
facilities
discharging
into
the
oceans
provide
more
information
than
other
NPDES
permit
applicants.
This
ICR
calculates
the
burden
and
costs
for
all
information
collection
activities
associated
with
applications
for
NOI
submissions
and
non­
municipal
direct
dischargers'
permits.

EPA
uses
the
data
contained
in
applications
and
supplemental
information
requests
to
set
appropriate
permit
conditions,
issue
permits,
and
assess
permit
compliance.
EPA
maintains
national
applications
information
in
databases,
which
assist
permit
writers
in
determining
permit
conditions.
1
EPA
defines
a
point
source
as
"
any
discernible,
confined,
and
discrete
conveyance,
including
but
not
limited
to,
any
pipe,
ditch,
channel,
tunnel,
conduit,
well,
discrete
fissure,
container,
rolling
stock,
concentrated
animal
feeding
operation,
landfill
leachate
collection
system,
vessel
or
other
floating
craft
from
which
pollutants
are
or
may
be
discharged.
This
term
does
not
include
return
flows
from
irrigated
agriculture
or
agricultural
storm
water
runoff"
(
40
CFR
§
122.2).

Applications
ICR
8/
5/
99
3
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
For
The
Collection
The
purpose
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(
a)
establishes
the
NPDES
program
to
regulate
the
discharge
of
any
pollutant
from
point
sources1
into
waters
of
the
United
States.
Point
source
dischargers
include
POTWs,
privately
owned
treatment
works,
industrial
manufacturing
facilities,
concentrated
animal
feeding
operations,
aquatic
animal
production
facilities,
mining
operations,
and
other
types
of
facilities
or
industries.
Section
402(
a)
of
the
CWA,
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;
and

any
conditions
the
Administrator
determines
are
necessary
to
carry
out
the
provisions
and
objectives
of
the
CWA.

The
CWA
also
establishes
an
administrative
framework
for
this
permitting
program.
Section
402(
b)
authorizes
"
States"
(
which
includes
U.
S.
territories
and
Indian
Tribes
that
have
been
approved
in
the
same
manner
as
a
State)
to
administer
the
NPDES
program
once
the
Agency
has
approved
the
States'
programs
and
is
assured
that
they
meet
minimum
federal
requirements.
As
of
June
1999,
43
States
and
one
territory
(
U.
S.
Virgin
Islands)
(
referred
to
as
"
approved
States")
had
received
approval
from
EPA
to
administer
the
NPDES
program.
Approved
States
are
considered
permitting
authorities
and
are
responsible
for
issuing,
administering,
and
enforcing
permits
for
all
point
source
discharges
within
their
borders.
In
States
without
NPDES
program
approval,
EPA
is
the
permitting
authority
and
undertakes
all
permitting
activities.

Section
405
of
the
Act
requires
EPA
to
regulate
the
use
and
disposal
of
sewage
sludge
produced
by
POTWs
and
other
Treatment
Works
Treating
Domestic
Sewage
(
TWTDS).
In
1987,
Congress
passed
the
Water
Quality
Act
(
WQA),
which
amended
the
CWA
sludge
requirements.
The
WQA
directed
EPA
to
develop
technical
standards
for
sewage
sludge
use
and
disposal.
Section
405(
a)
authorizes
the
Administrator
to
issue
permits
for
the
use
and
disposal
of
sewage
sludge.
Regulations
governing
permit
requirements
for
NPDES
discharges
and
sewage
sludge
management
activities
are
contained
in
40
CFR
Parts
122
and
501
and
503,
respectively.
EPA
has
developed
its
NPDES
discharge
and
sewage
sludge
application
requirements
to
ensure
that
it
obtains
adequate
information
about
permittees
before
it
issues
permits.

CWA
Section
402(
p)
empowers
the
Administrator
to
issues
permits
for
storm
water
discharges.
Under
the
NPDES
program
for
wastewater
discharges,
most
POTW
and
industrial
direct
sources
are
Applications
ICR
8/
5/
99
4
issued
individual
NPDES
permits,
following
the
opportunity
for
public
comment
of
course.
In
the
NPDES
program
for
stormwater
and
on
a
growing
number
of
situations
including
a
class
or
category
of
similar
situated
applicants
 
coverage
of
wastewater/
stormwater
dischargers
may
be
sought
under
a
NPDES
general
permit.
These
applicants
usually
complete
an
Notice
of
Intent
and
submit
their
information
as
directed
under
the
provisions
of
the
general
permit.

Section
308
of
the
Clean
Water
Act
authorizes
the
Administrator
to
require
the
owner
or
operator
of
any
point
source
to
maintain
records,
submit
reports,
conduct
monitoring
and/
or
sampling,
and
provide
any
other
information
reasonably
necessary
to
carry
out
the
objectives
of
the
Act.
Under
this
authority,
the
Agency
occasionally
requests
information
that
supplements
information
it
obtains
from
permit
applications,
termed
a
Section
308
Request,
or
a
request
for
supplemental
information.

The
information
collection
and
reporting
activities
covered
in
this
ICR
can
be
divided
into
two
categories:


Information
routinely
submitted
when
facilities
apply
for
new
or
reissued
permits
or
submit
an
NOI.
Applicants
typically
provide
this
information
on
application
forms
approved
by
the
EPA
Administrator.
For
some
activities,
however,
such
as
the
application
for
a
Municipal
Separate
Storm
Sewer
System
(
MS4)
permit,
EPA
does
not
have
standard
forms.


Information
that
supplements
applications/
NOIs.
In
some
cases,
applicants
must
submit
additional
information
or
develop
materials,
e.
g.,
a
storm
water
pollution
prevention
plan
(
SWPPP)
for
an
NOI
for
discharges
associated
with
industrial
activity
(
NOI­
Stormwater).

EPA
and
permitting
authorities
need
the
information
routinely
collected
in
the
NPDES
and
sludge
application
process
for
the
following
reasons:


to
identify
the
facilities
that
require
permits
(
i.
e.,
those
that
are
operating
and
discharging
into
the
waters
of
the
United
States
or
using
and
disposing
of
sewage
sludge);


to
identify
new
pollutants
in
existing
discharges;


to
issue
NPDES
and
sewage
sludge
permits
with
appropriate
limitations
and
conditions
that
will
protect
human
health
and
the
environment;


to
update
information
in
EPA's
databases
which
permitting
authorities
use
to
determine
permit
conditions;


to
calculate
national
permit
issuance,
backlog,
and
compliance
statistics;


to
evaluate
national
water
quality;


to
assist
EPA
in
program
management
and
other
activities
that
ensure
national
consistency
in
permitting;


to
assist
EPA
in
prioritizing
permit
issuance
activities;


to
assist
EPA
in
policy
development
and
budgeting;
and

to
assist
EPA
in
responding
to
Congressional
and
public
inquiries.

EPA
and
permitting
authorities
need
supplemental
information
for
the
following
reasons:


to
issue
or
modify
permits;


to
assess
compliance
with
permit
requirements;


to
develop
effluent
limitations
or
prohibitions;
Applications
ICR
8/
5/
99
5

to
develop
pretreatment
standards
or
standards
of
performance;


to
determine
violations;


to
assist
States
in
acquiring
authority
for
permitting
programs;


to
issue
NPDES
permits
with
appropriate
permit
conditions
in
special
circumstances
(
such
as
discharges
into
the
oceans);
and

to
identify
measures
to
control
the
discharge
of
pollutants
or
combinations
of
pollutants
to
waters
of
the
United
States
under
Multi­
Sector
Group
Permit
(
MSGP).

The
collection
of
information
by
permittees
may
also
be
useful
for
the
permittees/
applicants,
e.
g.,
to
identify
potential
pollutant
discharges
and
commence
implementation
of
the
SWPPP
control
measures.

2(
b)
Practical
Utility/
Users
of
the
Data
This
ICR
includes
both
information
that
must
be
submitted
to
permitting
authorities
and
that
which
must
be
collected
and
maintained
on­
site
by
the
permittee.
Although
different
applicants
submit
widely
differing
information,
information
can
be
categorized
into
two
sets:
identification
information
and
information
related
to
the
facility's
discharges
or
practices.
Permitting
authorities
use
specific
information
in
the
ways
discussed
below.

Identification
Information
Permitting
authorities
use
information
such
as
the
name,
location,
and
description
of
facilities
to
identify
facilities
that
apply
for
NPDES
permits
or
are
requesting
coverage
under
a
general
permit.
EPA
and
authorized
NPDES
States
store
basic
permit
information
in
EPA's
Permit
Compliance
System
(
PCS)
database.
PCS
is
used
to
track
permit
limits,
permit
expiration
dates,
monitoring
data,
and
other
data,
and
provides
EPA
with
a
nationwide
inventory
of
permit
holders.
EPA
stores
basic
NOI
information
submitted
for
coverage
under
an
NPDES
general
permit
in
the
NOI
database
housed
at
the
NOI
Processing
Center.
This
NOI
database
provides
EPA
with
a
nationwide
inventory
of
storm
water
permit
holders.

EPA
Headquarters
uses
the
information
contained
in
PCS
and
the
NOI
databases
to
develop
reports
on
permit
issuance,
backlog,
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
the
NPDES
program
and
sewage
sludge
use
and
disposal
program
to
ensure
national
consistency
in
permitting.

Information
Related
to
Discharges,
Uses
and
Practices
In
the
applications
and
requests
for
supplemental
information,
permitting
authorities
gather
information
about
treatment
systems,
pollutant
characteristics,
discharge
rates
and
volumes,
sewage
sludge
use
and
disposal
practices,
sewage
sludge
quality,
and
other
data
such
as
pollution
prevention
practices.
They
use
the
information
to
formulate
effluent
limitations,
compliance
schedules,
and
other
routine
and
special
conditions
in
permits.
Discharge
data
are
also
entered
into
EPA's
Storage
and
Retrieval
(
STORET)
database
for
ambient
water
quality
data.
EPA
may
use
these
data
to
re­
evaluate
testing
requirements,
or
to
develop
or
revise
effluent
standards
on
a
national
basis.
EPA
may
also
use
NOI
and
Stormwater
Pollution
Prevention
Plan
(
SWPPP)
data
as
part
of
a
compliance
evaluation
to
ensure
that
the
permittee
adheres
to
conditions
as
stated
in
these
documents.
2
POTWs­­
especially
larger
POTWs­­
often
accept
wastewater
from
industries.
In
order
to
meet
their
NPDES
pollutant
discharge
limitations
and
satisfy
the
sludge
conditions
in
their
permits,
some
of
these
POTWs
administer
pretreatment
programs,
in
which
they
regulate
industrial
wastewater
entering
their
facilities.
POTWs
impose
pollutant
discharge
limitations
on
industries
as
part
of
their
pretreatment
programs.
Information
requirements
associated
with
the
Pretreatment
program
are
included
in
a
separate
ICR
(
OMB
Control
No.
2040­
0009,
ICR
No.
0002.08).

Applications
ICR
8/
5/
99
6
NPDES
permits
may
not
exceed
a
duration
of
five
years.
The
re­
application
process
is
the
primary
mechanism
for
obtaining
up­
to­
date
information
on
discharges
and
sewage
sludge
quality,
particularly
new
pollutant
information.
Although
existing
permittees
provide
pollutant
data
from
self­
monitoring
activities
in
routine
reports,
these
reports
are
usually
limited
to
pollutants
listed
in
existing
permits.
Permitting
authorities
use
re­
application
data
to
identify
new
pollutants
or
other
information
that
could
lead
the
permit
writers
to
take
the
following
actions:


specify
additional
permit
limitations;


assess
compliance
with
applicable
effluent
and
sludge
guidelines;
and

place
appropriate
special
conditions
in
permits.

Permittees
use
discharge
or
sewage
sludge
quality
data
to
perform
routine
operations
at
their
facilities.
Regardless
of
federal
regulatory
requirements,
many
permittees
collect
discharge
and
sewage
sludge
data
as
part
of
their
normal
operations.
In
addition,
they
may
need
to
collect
this
information
to
comply
with
State
specific
program
requirements
or
to
administer
pretreatment
programs.
2
Applications
ICR
8/
5/
99
7
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
EPA
has
examined
all
reporting
requirements
contained
in
the
Clean
Water
Act
and
40
CFR
Parts
122,
123,
124,
125,
403,
501,
and
503.
The
Agency
has
also
consulted
the
EPA
Information
Systems
Inventory,
the
EPA
Inventory
of
Information
Collection
Requests,
and
the
Federal
Information
Locator
System
to
determine
if
similar
or
duplicate
information
is
available
elsewhere.
From
this
effort,
EPA
has
determined
that,
for
the
most
part,
the
information
collection
and
reporting
requirements
considered
in
this
ICR
are
not
contained
or
duplicated
in
other
reports.
Furthermore,
none
of
these
other
sources
is
sufficient
to
enable
the
Agency
to
gather
the
information
it
needs
to
issue
permits.

Except
for
Form
1,
all
of
the
reporting
requirements
in
the
permit
application
forms
involve
original
data
that
facilities
are
not
required,
through
other
regulations,
to
submit
to
EPA
or
other
federal
agencies.
Much
of
Form
1
pertains
to
basic
information
regarding
the
facility
for
identification
purposes.
In
cases
where
similar
or
equivalent
information
has
already
been
collected
or
prepared
by
the
applicant,
the
Agency
provided
that
such
information
can
be
re­
submitted,
i.
e.,
applicants
may
photocopy
and
submit
existing
information
in
lieu
of
new,
equivalent
information.
For
example:


Form
2A
requires
that
certain
POTWs
list
the
results
of
the
whole
effluent
toxicity
tests
in
Section
D.
However,
respondents
may
submit
the
laboratory's
test
results
report
in
lieu
of
completing
Section
D,
as
long
as
the
report
contain
certain
information.


The
individual
industrial
storm
water
application
form
(
Form
2F)
requests
information
on
significant
spills.
EPA
has
already
collected
this
information
from
some
dischargers
under
a
previous
request
for
supplemental
information
authorized
by
OMB
(
Control
No.
2040­
0110).
EPA
will
use
the
existing
information
when
it's
available;
in
other
words,
the
Agency
will
only
require
this
information
from
those
applicants
who
have
not
submitted
this
information
before,
unless
more
detailed
information
is
necessary
from
those
who
have.
Therefore,
there
is
no
duplication
associated
with
spill
information
collection.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
In
compliance
with
the
1995
Paperwork
Reduction
Act
(
PRA),
any
agency
developing
a
non­
rulerelated
ICR
must
solicit
public
comments
prior
to
submitting
the
ICR
to
OMB.
These
comments,
which
are
used
partly
to
determine
realistic
burden
estimates
for
respondents,
must
be
considered
when
completing
the
Supporting
Statement
that
is
submitted
to
OMB.

The
announcement
of
a
60­
day
public
comment
period
for
this
ICR
was
made
on
April
23,
1998
in
Volume
63,
Number
78,
of
the
Federal
Register.
The
Federal
Register
notice
is
attached.
No
public
comments
were
received.
3
No
comments
were
received.

Applications
ICR
8/
5/
99
8
3(
c)
Consultations
EPA
finalized
the
regulations
containing
the
application
requirements
addressed
in
this
ICR
after
receiving
comments
from
the
public
and
the
regulated
community.
In
addition
to
comments
sought
during
the
recent
60­
day
comment
period
for
this
ICR
renewal3,
the
Agency
actively
solicits
comments
when
it
develops
its
regulations.
EPA
holds
public
meetings,
assembles
workgroups
of
experts
and
potential
respondents,
and
consults
government
agencies,
before
finalizing
requirements.
There
is
also
a
formal
OMB
review
process.
It
would
be
impossible
to
discuss
all
consultations
that
affected
the
applications
addressed
in
this
ICR.
This
section,
therefore,
contains
a
discussion
of
consultations
that
led
to
burden
and
cost
reductions.

For
the
newly
finalized
Form
2A
and
Form
2S,
EPA
established
a
workgroup
consisting
of
EPA
Headquarters
and
Regional
representatives
knowledgeable
about
the
NPDES
permitting
process.
The
workgroup
reviewed
and
commented
on
every
draft
of
the
forms
and
the
corresponding
regulations.
Comments
from
these
workgroup
members
have
been
incorporated
into
the
final
forms
presented
in
this
ICR.
The
Agency
also
consulted
permit
writers,
municipalities,
States,
and
organizations
representing
POTWs,
States,
and
municipalities
(
e.
g.,
the
Association
of
Metropolitan
Sewerage
Agencies
(
AMSA),
the
Association
of
State
and
Interstate
Water
Pollution
Control
Administrators
(
ASIWPCA),
and
the
National
League
of
Cities)
about
the
strengths
and
weaknesses
of
draft
versions
of
the
proposed
forms.
Comments
from
these
individuals
are
reflected
in
the
final
version
of
Forms
2A
and
2S.

EPA
finalized
regulations,
in
response
to
comments,
that
reduced
the
costs
to
applicants
completing
Form
2C.
(
For
a
complete
discussion,
see
49
FR
37988,
September
26,
1984.)
The
Agency
established
a
reporting
system
for
applicants
for
NPDES
permits
for
industrial
facilities
that
limits
the
pollutants
for
which
applicants
must
report
on
Form
2C.
Applicants
must
submit
quantitative
data
for
a
pollutant
only
if
the
presence
of
that
pollutant
exceeds
this
threshold.
This
reduces
industry
costs
for
quantitative
testing
and
analysis.

EPA
also
eliminated
several
items
on
Form
2C
in
response
to
comments.
These
items
required
applicants
to
anticipate
pollutants
that
might
be
discharged
at
more
than
twice
the
level
reported
in
the
permit
application
during
the
five­
year
duration
of
the
permit.
Similarly,
the
Agency
modified
the
list
of
toxic
pollutants
expected
to
be
used
or
manufactured
by
the
applicant
during
the
five­
year
period
to
reflect
only
the
current
use
or
production
of
such
pollutants.
The
deletion
of
certain
Gas
Chromatography/
Mass
Spectrometry
(
GC/
MS)
testing
requirements
for
specified
industries
also
reduced
burden
significantly.

In
response
to
comments,
EPA
changed
application
requirements
for
certain
dischargers.
The
Agency
determined
that
new
dischargers
of
non­
process
wastewater
would
be
eligible
to
use
Form
2E
rather
than
Form
2D.
Form
2E
imposes
significantly
less
burden
than
Form
2D.

Early
proposed
regulations
required
applicants
for
ocean
discharge
permits
to
submit
a
wide
range
of
analyses
and
evaluations.
Many
commenters
objected
to
these
requirements.
In
response
to
the
comments,
final
regulations
empowered
permit
authorities
to
request
this
information
from
the
applicants,
but
encouraged
them
to
use
existing
or
alternative
sources
such
as
environmental
impact
statements,
Applications
ICR
8/
5/
99
9
applications
for
variances,
consolidated
permit
applications,
and
EPA
Non­
municipal
and
municipal
waste
surveys.

The
Uniform
Federal
Transportation
and
Utility
System
application
form
was
developed
by
the
Department
of
the
Interior.
Facilities
that
are
required
to
complete
this
form
are
not
required
to
complete
additional
NPDES
application
forms.

In
developing
regulations
for
NPDES
permits
for
storm
water
dischargers,
EPA
met
with
potential
respondents,
industry
and
trade
organizations,
environmental
groups,
and
municipal,
State,
and
public
works
associations.
EPA
made
several
changes
to
its
regulations
based
on
comments
presented
at
meetings.
For
example:


the
National
Homebuilders
Association
pointed
out
during
a
1987
meeting
that
sampling
data
for
construction
sites
would
be
extremely
variable
because
construction
activities
are
continually
changing.
Based
on
this
comment,
EPA
now
requires
general
information
on
construction
activities
rather
than
quantitative
sampling
data,
since
general
information
will
adequately
indicate
any
potential
problems
from
storm
water
runoff
at
construction
sites.


municipalities
suggested
at
a
public
meeting
that
EPA
focus
on
illicit
discharges
through
MS4s
rather
than
storm
water
runoff.
Studies
conducted
in
Fort
Worth,
Texas,
and
Ann
Arbor,
Michigan,
supported
the
position.
Several
inexpensive
methods
for
testing
illicit
discharges
have
been
developed
to
replace
analytical
laboratory
testing.
These
methods
include
observing
outfall
points
during
dry
weather
and
performing
relatively
inexpensive
field
testing.
Because
these
methods
have
been
used
successfully,
EPA
replaced
quantitative
testing
requirements
with
site­
specific
management
plans
for
the
control
of
illicit
discharges.


EPA
discussed
sampling
requirements
for
storm
water
discharges
at
a
public
meeting.
Municipalities
favored
representative
sampling
of
major
outfalls
rather
than
sampling
of
all
municipal
outfalls.
EPA
accepted
their
suggestions
and
incorporated
these
requirements
into
the
regulations.

3(
d)
Effects
of
Less
Frequent
Collection
Permitted
facilities
must
reapply
for
NPDES
and
sewage
sludge
management
permits
before
their
existing
permits
expire,
generally
once
every
five
years.
The
CWA
prohibits
NPDES
permits
to
have
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
reissuing
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.
Permits
must
contain
conditions
that
reflect,
for
example,
the
following
criteria:


new
industrial
processes
and
waste
treatment
technologies;


new
kinds
of
discharges
(
such
as
toxic
chemicals);


new
detection
methods;
and

changes
in
the
quality
of
receiving
waters.

3(
e)
General
Guidelines
Applications
ICR
8/
5/
99
10
This
information
collection
complies
with
Paperwork
Reduction
Act
guidelines
(
5
CFR
§
1320.5(
d)(
2)).
Requests
for
supplemental
information
for
the
purposes
of
emergency
response
or
enforcement
activities
are
exempt
from
the
Paperwork
Reduction
Act
requirements.

3(
f)
Confidentiality
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
Section
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.

3(
g)
Sensitive
Questions
Reporting
requirements
addressed
in
this
ICR
do
not
include
sensitive
questions.
4
Large
municipal
separate
storm
sewer
systems
serve
250,000
people
or
more.
Medium
storm
sewer
systems
serve
100,000
to
250,000
people.

Applications
ICR
8/
5/
99
11
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents/
Standard
Industrial
Classification
(
SIC)
Codes
NPDES
permits
are
required
for
discharges
of
wastewater
or
storm
water
to
the
waters
of
the
United
States,
regardless
of
a
discharger's
industrial
category.
A
relatively
large
portion
of
permitted
facilities,
including
municipal
dischargers,
are
classified
in
the
sanitary
service
(
SIC
495)
industrial
category.
Other
permittees
include,
but
are
not
limited
to,
those
industries
classified
in
the
electric
services
(
SIC
491),
bituminous
coal
(
SIC
121),
industrial
organic
(
SIC
286),
petroleum
refining
(
SIC
291),
and
gold
ores
(
SIC
104)
industrial
categories.

Facilities
subject
to
Form
2S
reporting
requirements,
i.
e.,
POTW
and
privately
owned
treatment
works,
fall
under
the
sanitary
service
(
SIC
495)
category.
Entities
that
may
apply
for
coverage
of
storm
water
discharges
related
to
industrial
activity
under
the
NPDES
Multi­
Sector
Group
Permit
(
MSGP)
include
eleven
categories
of
industrial
activities,
defined
in
40
CFR
§
§
122.26(
b)(
14)
(
i)
­
(
xi).
Five
of
these
categories
are
identified
by
SIC
code,
and
six
provide
narrative
descriptions
of
the
industrial
activity.

4(
b)
Information
Requested
EPA
has
developed
standard
application
forms
for
most
applicants.
Standardized
application
forms
covered
under
this
ICR
include:
Forms
1,
2A,
2B,
2C,
2D,
2E,
2F,
and
2S;
Notice
of
Intent
(
NOI)
for
NPDES
General
Permits;
Uniform
Federal
Transportation/
Utility
System
Application
Form;
and
the
Notice
of
Termination
(
NOT).
This
ICR
does
not
address
permit
application
requirements
for
storm
water
discharges
associated
with
construction
activity.
Those
activities
are
addressed
in
a
separate
ICR,
EPA
ICR
No.
1842.02,
OMB
Control
No.
2040­
0188.
This
section
summarizes
the
information
requested
by
these
forms.

For
some
permits,
EPA
has
not
developed
standard
application
forms.
For
these
permits
standard
forms
are
either
not
appropriate,
or
EPA
is
currently
developing
the
forms.
Whether
or
not
standard
forms
exist,
this
ICR
calculates
the
burden
to
respondents
for
supplying
the
information.
No
forms
exist
for
the
following
facilities
or
information
collection
activities:


requests
for
additional
information
(
Section
308
Requests);


applications
for
MS4
permits
from
either
large
or
medium
municipalities;
4

petitions
for
individual
permits;


permit
consolidation
requests;


notification
of
construction
prior
to
wastewater
permit
issuance;
and

requests
for
ocean
discharge
information.

Permit
requirements
for
particular
facilities
vary
according
to
the
following
factors:


the
type
of
facility;
5
Replaces
Standard
Form
A
and
Short
Form
A,
and
Form
1
for
these
applicants
only;
approved
by
OMB
on
January
13,
1999.

Applications
ICR
8/
5/
99
12

the
manufacturing
process
it
uses;


the
waste
treatment
it
provides;


the
pollutants
it
discharges;


the
pollutants
contained
in
its
sludge;
and

the
quality
of
the
waters
receiving
the
discharge.

Applications
request
information
that
permit
writers
need
to
issue
permits
to
particular
types
of
permittees.
A
facility
that
employs
complex
industrial
processes
and
discharges
several
toxic
pollutants,
for
example,
must
provide
more
information
to
the
permitting
authority
than
a
facility
that
discharges
noncontact
cooling
waters
or
storm
water.
Similarly,
a
facility
that
discharges
into
waters
considered
impaired
may
have
to
submit
more
information
than
a
facility
discharging
into
waters
that
do
not
have
water
quality
problems.

Because
discharges
vary
in
complexity
and
character,
and
because
discharges
and
activities
from
particular
industry
groups
or
treatment
works
are
often
similar,
EPA
has
developed
several
different
NPDES
application
forms.
Exhibit
1
lists
the
application
forms
and
other
application
requirements,
the
length
of
each
application
form
(
where
applicable),
the
respondents
to
the
request,
and
the
ICR
in
which
the
burden
for
the
request
is
currently
estimated.
Copies
of
the
forms
are
contained
in
the
appendix.

Exhibit
1.
Application
Forms
and
Information
Requests
FORM/
REQUEST
RESPONDENT
TYPE
Form
1
Non­
municipal
NPDES
applicants,
general
permit
applicants,
and
applicants
in
Alaska
Form
2A5
All
POTWs.

Additional
NPDES
Application
Requirements
for
Municipal
Dischargers
(
Section
308
Request)
Municipal
facilities
(
i.
e.,
POTWs)

Form
2B
Concentrated
animal
feeding
operations
and
aquatic
animal
production
facilities
Form
2C
Existing
manufacturing,
commercial,
mining,
and
silvicultural
operations
that
discharge
process
wastewater
Form
2D
New
manufacturing
and
commercial
facilities
that
discharge
process
wastewater
Additional
NPDES
Application
Requirements
for
Non­
municipal
Dischargers
(
Section
308
Requests)
Non­
municipal
facilities
Exhibit
1.
Application
Forms
and
Information
Requests
FORM/
REQUEST
RESPONDENT
TYPE
6
Replaces
Interim
Sewage
Sludge
Permit
Application
Form
recently
approved
by
OMB
January
13,
1999.

Applications
ICR
8/
5/
99
13
Form
2E
New
or
existing
Non­
municipal
facilities
that
discharge
nonprocess
wastewater
Form
2F
Industrial
storm
water
dischargers
applying
for
an
individual
permit
Form
2S6
POTWs
and
other
treatment
works
treating
domestic
sewage
(
TWTDS)

Notice
of
Intent
­
Industrial
Activity
(
NOI­
Stormwater)
Industrial
storm
water
dischargers
applying
for
a
Multi­
Sector
General
Permit
(
MSGP)

Uniform
Federal
Transportation/
Utility
Systems
Application
Form
(
Alaskan
Lands
Applications)
Builders
and
operators
of
transportation
and
utility
projects
on
Alaskan
public
lands
(
substitutes
for
Forms
1,
2B,
and
2C)

Application
for
Large
and
Medium
Municipal
Separate
Storm
Sewer
Systems
(
MS4s)
MS4s
Petitions
for
Individual
Permit
MS4
operators
or
any
person
Notice
of
Intent
(
NOI)
Municipal,
Non­
municipal,
and
sewage
sludge
management
facilities
applying
for
general
permit
coverage
Permit
Consolidation
Request
Facilities
with
multiple
permits
Notification
of
Construction
Facilities
classified
as
new
sources
Ocean
Discharge
Information
Ocean
dischargers
Notice
of
Termination
General
permittees
(
stormwater).

Form
1
EPA
originally
developed
Form
1
to
be
used
by
any
facility
applying
for
any
EPA
permit.
On
Form
1,
applicants
provide
basic
information
necessary
to
all
EPA
permit
programs,
including
name,
address
type
of
facility,
SIC
code,
and
number
of
outfalls.
Applicants
must
also
submit
topographic
maps
and
lists
of
all
EPA
and
State
permits
presently
held.
Most
facilities
applying
for
a
NPDES
permit
must
submit
Form
1
along
with
a
second
form
(
Form
2B,
2C,
2D,
2E,
or
2F)
requesting
information
specific
to
the
type
of
applicant.
Facilities
with
more
than
one
type
of
discharge
submit
Form
1
and
several
of
the
other
forms.
7
As
required
under
40
CFR
§
122.21(
j),
all
POTWs
meeting
any
of
the
following
criteria
must
provide
the
results
of
valid
whole
effluent
biological
toxicity
testing
to
the
Director:
those
with
design
influent
flows
equal
or
greater
than
one
million
gallons
per
day,
those
with
an
approved
pretreatment
program,
those
required
to
develop
a
pretreatment
program,
or
those
designated
by
the
Director.

Applications
ICR
8/
5/
99
14
As
EPA
developed
specific
forms,
submission
of
Form
1
was
no
longer
mandatory
since
the
specific
forms
requested
essentially
the
same
data.
Facilities
that
submit
NOIs
for
coverage
under
general
permits
are
exempt
from
completing
Form
1.
They
provide
similar,
but
less
detailed
information
in
the
NOIs
they
prepare
to
request
general
permit
coverage.
Alaskan
applicants
who
submit
the
Uniform
Federal
Transportation/
Utility
System
Application,
discussed
below,
do
not
complete
Form
1.
Large
and
medium
municipal
separate
storm
sewer
systems
also
do
not
submit
this
form.

Form
2A
Previously,
POTWs
were
subject
to
Form
1,
Standard
Form
A
or
Short
Form
A,
and/
or
biological
testing
reporting
requirement7.
Form
2A
consolidates
the
application
requirements
for
POTWs
into
a
3
part
application:
Introductory
Application
Overview,
Basic
Application
Information
and
Supplemental
Application
Information.
The
introductory
section
directs
the
applicant
to
complete
the
basic
section
as
well
as
applicable
portions
of
the
supplemental
section
based
on
the
applicants
responses
to
specific
questions.
As
suggested
by
the
title,
the
Basic
Application
Information
section
collects
elementary
data
for
drafting
a
POTW
NPDES
permit,
e.
g.,
facility
name,
location,
service
area
data,
receiving
stream,
WWTP
design
criteria,
etc.
The
supplement
section
consists
of
four
parts.
Applicants
are
instructed
to
complete
the
section
if
they
meeting
the
following:


Expanded
Effluent
Testing
Data:

1
MGD
treatment
design
capacity,
has
or
is
required
to
have
a
pretreatment
program,
or
is
instructed
by
the
permitting
authority
that
they
must.


Toxicity
Testing
Data:

1
MGD
treatment
design
capacity,
has
or
is
required
to
have
a
pretreatment
program,
or
is
instructed
by
the
permitting
authority
that
they
must.


Industrial
User
Discharges
and
RCRA/
CERCLA
wastes:
accept
IU
process
wastewater
or
receive
RCRA
or
CERCLA
wastes.


Combined
Sewer
Systems:
have
a
combined
sewer
system.

Additional
NPDES
Application
Requirements
for
Municipal
Dischargers
(
Section
308
Requests)

As
explained
above,
municipal
facilities
(
i.
e.,
POTWs)
must
complete
Form
2A
to
apply
for
NPDES
permits.
Often,
permit
writers
require
additional
information
from
municipal
facilities
in
order
to
establish
permit
conditions.
Section
308
grants
permit
authorities
the
power
to
require
the
owner
or
operator
of
any
point
source
to
provide
supplemental
information
reasonably
necessary
to
carry
out
the
objectives
of
the
Act.
Section
308
Requests
vary
in
complexity
and
burden
depending
on
such
factors
as
facility
size
or
effluent
characteristics.
Because
Section
308
Requests
can
vary
substantially,
EPA
has
not
created
standard
forms
for
the
requests.

Form
2B
Applications
ICR
8/
5/
99
15
Concentrated
animal
feeding
operations
and
aquatic
animal
production
facilities
complete
Form
2B.
For
animal
feeding
operations,
the
two­
page
form
requests
specific
information
about
the
types
and
numbers
of
animals
in
open
confinement
and
housed
under
roof
at
the
facility,
the
size
of
the
area
devoted
to
confinement
feeding,
and
the
design
basis
for
the
control
system.
Aquatic
animal
production
facilities
must
provide
data
on
the
flow
rates,
the
number
of
ponds,
raceways,
and
similar
structures,
the
species
held
at
the
facility,
and
the
total
pounds
of
production.

Form
2C
Existing
manufacturing,
commercial,
mining,
and
silvicultural
operations
that
discharge
process
wastewater
complete
Form
2C.
Usually,
privately
owned
treatment
works
also
use
Form
2C
to
apply
for
individual
NPDES
permits.
The
thirteen­
page
form
requests
information
about
a
discharger's
outfall
locations,
flow
rates,
and
treatment.
Respondents
must
also
perform
the
following
tasks:


prepare
a
water
flow
process
line
drawing;


identify
levels
of
production,
wastewater
treatment
plant
construction
or
improvements,
and
effluent
characteristics;
and

sample
and
analyze
wastewater
for
pollutant
characteristics.

Form
2C
requires
comprehensive
monitoring
data,
i.
e.,
all
applicants
must
test
for
and
report
quantitative
data
for
seven
listed
conventional
and
nonconventional
pollutants.
In
addition,
all
applicants
must
provide
information
on
the
presence
of
toxic
pollutants
in
accordance
with
a
scheme
set
forth
in
the
regulations.
In
establishing
testing
requirements
for
toxic
pollutants,
EPA
balances
the
likelihood
of
the
presence
of
the
pollutants
against
the
costs
and
burdens
for
applicants
to
analyze
the
effluent.
In
some
industries
there
is
no
reasonable
expectation
that
certain
pollutants
are
present.
Therefore,
mandatory
testing
for
any
toxic
pollutants
applies
only
where
EPA
data
have
indicated
a
likelihood
that
the
pollutant
will
be
present
in
the
discharge.

Testing
requirements
for
toxic
pollutants
fall
into
two
groups.
First,
all
process
discharges
in
primary
industrial
categories
must
be
tested
for
the
presence
of
metals,
cyanide,
and
total
phenols.
However,
testing
is
not
required
for
all
organic
toxic
pollutants
in
all
primary
industrial
categories.
The
specific
organic
pollutants
for
which
an
industry
must
test
are
listed
by
industry
type
in
the
regulations
[
40
CFR
§
122.21(
g)(
7)].
Second,
in
addition
to
the
mandatory
testing
explained
above,
all
industrial
dischargers
must
report
quantitative
data
for
any
toxic
pollutant,
conventional
pollutant,
listed
nonconventional
pollutant,
or
radioactivity
that
they
know
or
have
reason
to
believe
is
present
in
the
discharge.
8
EPA
classifies
new
facilities
into
two
groups:
new
sources
and
new
dischargers.
Generally,
a
facility
is
considered
a
new
source,
as
opposed
to
a
new
discharger,
if
EPA
has
developed
a
New
Source
Performance
Standard
(
NSPS)
applicable
to
the
new
facility.
If
not
classified
as
a
new
source,
an
applicant
is
classified
as
a
new
discharger.
The
distinction
is
important
because
new
sources
must
prepare
Environmental
Impact
Statements
under
the
National
Environmental
Policy
Act
in
States
where
EPA
is
the
permitting
authority.

Applications
ICR
8/
5/
99
16
Form
2D
New
facilities
applying
for
NPDES
permits
to
discharge
process
wastewater
complete
Form
2D.
The
five­
page
form
requests
information
that
helps
permitting
authorities
determine
if
a
facility
is
a
new
source
of
process
wastewater.
8
Respondents
must
report
the
locations
of
all
outfalls
and
the
names
of
the
receiving
waters,
describe
all
operations
contributing
to
the
wastewater
and
the
treatment
applied
to
it,
and
estimate
the
concentration
and
mass
of
pollutants
to
be
discharged
from
each
outfall.
The
form
also
stipulates
that
applicants
must
submit
sampling
data
no
later
than
two
years
after
they
begin
discharging.
Permittees
must
submit
these
data
to
appraise
permit
authorities
of
discrepancies
between
the
estimated
data
and
the
actual
discharge.
Permitting
authorities
need
this
information
to
evaluate
permit
conditions
and
revise
them
if
necessary.

Additional
NPDES
Application
Requirements
for
Non­
municipal
Dischargers
(
Section
308
Requests)

Permit
authorities
occasionally
request
supplemental
application
information
under
the
authority
of
CWA
Section
308.
Supplemental
information
may
also
be
requested
under
40
CFR
§
122.21(
g)(
13),
which
enables
the
Director
to
request
"
other
information
as
the
Director
may
reasonably
require
to
assess
the
discharges
of
the
facility
and
to
determine
whether
to
issue
a
NPDES
permit."
CWA
Section
308
requires
EPA
and
approved
State
NPDES
programs
to
request
that
the
owner
or
operator
of
any
point
source
maintain
records,
make
reports,
conduct
monitoring
and/
or
sampling,
and
provide
any
other
information
reasonably
necessary
to
carry
out
the
objectives
of
the
Act.

Section
308
Requests
vary
in
complexity
and
burden,
and
permit
authorities
may
issue
Requests
for
a
variety
of
reasons.
Authorities
may
request
simple
narrative
descriptions
or
existing
discharge
information,
for
example.
More
burdensome
requests
include
comprehensive
sampling
and
analyses,
biomonitoring,
fish
tissue
analyses,
wastewater
data
and
related
ambient
water
quality
data,
sewage
sludge
characterization,
or
facility
production
or
process
information.
In
general,
requested
information
relates
to
discharges
or
control
of
particular
pollutants.
EPA
may
issue
Section
308
Requests
to
formulate
permit
limitations,
especially
limitations
necessary
to
protect
the
environment
from
toxic
pollutants
or
the
effects
of
toxicity.
In
addition,
EPA
may
request
information
necessary
to
assess
national
pollutant
limitations
standards,
assess
compliance
with
permit
conditions,
evaluate
permit
modifications,
revise
or
add
permit
standards,
impose
prohibitions
or
other
special
requirements,
revoke
a
permit,
issue
a
permit,
or
renew
a
permit.
Because
Section
308
Requests
vary
substantially,
EPA
has
not
created
standard
forms
for
the
requests.
Applications
ICR
8/
5/
99
17
Form
2E
Applications
ICR
8/
5/
99
18
Facilities
discharging
only
non­
process
wastewater
that
is
not
regulated
by
effluent
limitations
guidelines
or
new
source
performance
standards
submit
this
two­
page
form.
The
primary
respondents
include
dischargers
of
nonprocess
wastewater,
primarily
sanitary
waste
and
non­
contact
cooling
water.
On
Form
2E,
applicants
provide
outfall
locations,
identify
receiving
waters,
specify
effluent
characteristics,
and
describe
treatment
systems.
Form
2E
also
requires
minimal
sampling
for
conventional
pollutants
such
as
BOD.

Form
2F
Dischargers
of
storm
water
associated
with
industrial
activity
wishing
to
obtain
an
individual
permit,
as
opposed
to
a
general
permit,
submit
Form
2F.
This
five­
page
form
requests
information
about
outfall
locations,
scheduled
improvements,
flow
rates,
the
history
of
leaks
and
spills
at
the
facility,
treatment
applied
to
discharges,
the
drainage
and
surface
area
associated
with
discharges,
and
contractors
used
by
the
facility.
It
solicits
narrative
descriptions
of
pollutant
sources,
including
the
materials
present
at
the
site.
It
requires
applicants
to
sample
discharges
for
conventional
pollutants
and
other
pollutants
regulated
in
NPDES
permits
held
by
the
facility.
The
form
also
requests
biological
toxicity
testing
data.

Form
2S
Form
2S
replaces
the
Interim
Sewage
Sludge
Permit
Application
Form
and
is
the
mechanism
by
which
POTWs
and
other
TWTDS
will
apply
for
permits
containing
standards
for
use
and
disposal
of
sewage
sludge.
Form
2S
consists
of
2
main
sections,
"
Limited
Background
Information"
and
"
Permit
Application
Information",
and
a
preliminary
information
section
which
directs
the
applicant
to
complete
either
of
the
2
main
sections.
Facilities
that
are
not
requesting
site­
specific
permit
limitations,
do
not
have
a
currently
effective
NPDES
permit,
and/
or
have
not
been
directed
by
the
permitting
authority
to
apply
for
a
permit,
complete
the
first
part,
i.
e.,
"
Limited
Background
Information".
All
other
applicants
complete
Part
2,
i.
e.,
the
"
Permit
Application
Information".

Notice
of
Intent
for
Storm
Water
Discharge
Associated
with
Industrial
Activity
(
NOI­
Stormwater)

Based
on
fundamental
information
requested
in
the
NOI
for
Storm
Water
Discharges
Associated
with
Industrial
Activity
Under
the
NPDES
Multi­
Sector
Group
Permit
(
MSGP),
it
is
not
necessary
for
the
applicant
to
complete
Form
1.
In
addition
to
basic
information,
this
form
requests
applicant
data
with
regard
to
storm
water
runoff,
storm
water
management
and
Best
Management
Practices
(
BMPs),
monitoring,
spills,
construction,
etc.

All
new
facilities
submitting
an
NOI­
Stormwater
must
develop
a
Stormwater
Pollution
Prevention
Plan
(
SWPPP)
as
part
of
the
MSGP
requirements.
The
two
stated
objectives
of
these
plans
are:
(
1)
to
identify
sources
of
pollution
potentially
affecting
the
quality
of
storm
water
discharges
associated
with
industrial
activity
from
the
facility;
and
(
2)
to
describe
and
ensure
implementation
of
practices
to
minimize
and
control
pollutants
in
storm
water
discharges
associated
with
industrial
activity
from
the
facility
and
to
ensure
compliance
with
the
terms
and
conditions
of
the
permit.
While
this
is
not
a
new
requirement,
it
is
being
evaluated
for
the
first
time
as
part
of
the
ICR
process.

The
development
of
a
SWPPP
is
unique
to
each
facility,
even
to
the
extent
that
the
MSGP
has
sector­
specific
SWPPP
requirements
for
all
30
sectors.
Common
requirements
of
all
SWPPPs
include:
Applications
ICR
8/
5/
99
19
(
1)
Identifying
the
pollution
prevention
team
members
responsible
for
developing
and
implementing
the
SWPPP.

(
2)
Describing
potential
pollution
sources
(
i.
e.,
activities,
materials,
and
physical
features)
of
the
facility
that
may
contribute
significant
amounts
of
pollutants
to
storm
water.
This
should
include
a
drainage
map,
an
inventory
of
exposed
materials,
a
list
of
any
significant
spills
and
leaks,
a
certification
that
discharges
from
the
site
have
been
tested
or
evaluated
for
the
presence
of
non­
storm
water
discharges,
any
existing
sampling
data,
and
a
summary
of
potential
pollutant
sources.

(
3)
Considering
and
implementing
measures
and
controls
to
prevent
or
reduce
the
discharge
of
pollutants
in
storm
water
runoff.
These
measures
and
controls
include
good
housekeeping,
preventative
maintenance,
inspections,
employee
training,
recordkeeping
and
internal
reporting
procedures,
sediment
and
erosion
control,
and
management
of
runoff.

(
4)
Describing
the
scope
and
content
of
the
comprehensive
site
evaluations
that
will
be
conducted
to
evaluate
the
adequacy
and
effectiveness
of
the
SWPPP,
including
with
respect
to
compliance
with
terms
and
conditions
of
the
MSGP.

The
MSGP
regulations
include
additional
special
requirements
for
facilities
that
(
1)
discharge
storm
water
through
large
and
medium
municipal
separate
storm
sewer
systems,
(
2)
are
subject
to
Emergency
Planning
Commission
and
Right­
to­
Know
Act
(
EPCRA)
Section
313
requirements,
and
(
3)
discharge
from
salt
storage
facilities.
However,
information
required
to
address
these
three
areas
have
negligible
impact
on
SWPPP
development
burden
and
costs.
Rather,
these
requirements
primarily
impact
SWPPP
implementation.
As
such,
the
cost
and
burden
to
develop
a
SWPPP
as
presented
in
this
ICR
is
independent
of
whether
or
not
the
facility
meets
any
of
the
three
special
criteria
identified
above.
The
greatest
impact
on
SWPPP
development
burden
and
cost
will
be
the
amount
of
industrial
activities
associated
with
storm
water
discharges
that
is
actually
performed
at
each
facility,
based
primarily
on
facility
size
and
complexity
and
the
extent
to
which
pollution
prevention
measures
are
already
employed
at
the
facility.

Uniform
Federal
Transportation/
Utility
System
Application
Form
(
Alaskan
Lands
Application)

Persons
constructing
or
operating
transportation
and
utility
projects
on
Alaskan
public
lands
submit
Uniform
Federal
Transportation/
Utility
System
Applications
instead
of
application
Forms
1,
2B,
and
2C.
EPA
uses
the
information
on
this
form
to
determine
whether
a
permit
should
be
issued
to
these
dischargers.
The
form
is
also
used
by
the
Forest
Service,
Air
Force,
Bureau
of
Land
Management,
Federal
Aviation
Agency,
Coast
Guard,
NASA,
and
by
EPA
in
its
Resource
Conservation
and
Recovery
Act
and
Underground
Injection
Control
programs.

Respondents
must
do
the
following:


gather
information
demonstrating
the
need
for,
and
economic
feasibility
of,
the
transportation
or
utility
system;


gather
information
indicating
alternative
routes
and
modes
of
access;
Applications
ICR
8/
5/
99
20

gather
information
on
social
and
environmental
impacts;


prepare
a
map
covering
the
project
area;
and

complete
and
transmit
the
application.

Application
for
Large
and
Medium
Municipal
Separate
Storm
Sewer
Systems
(
MS4s)

Municipal
separate
storm
sewer
systems
typically
consist
of
many
outfalls.
Permitting
authorities
issue
one
permit
covering
all
discharges
from
a
system.
To
apply
for
a
system­
wide
permit,
MS4
operators
submit
a
two­
part
application.

Part
1
consists
of
the
following:


general
information
about
the
applicant;


a
statement
of
the
applicant's
legal
authority
to
control
storm
water
discharges
and
a
plan
to
augment
legal
authority
if
necessary;


identification
of
the
industrial
facilities
that
discharge
into
the
system;


information
about
the
historic
use
of
ordinances
or
other
controls
to
prevent
non­
storm
water
discharges
from
entering
the
system;


information
characterizing
discharges
from
the
system,
including
existing
quantitative
data
and
results
of
field
screening
analyses
to
detect
illicit
discharges
and
illegal
dumping
to
the
municipal
system;


a
plan
to
characterize
MS4
discharges
by
estimating
discharge
pollutant
levels,
and
a
plan
to
obtain
limited
representative
sampling
data;
and

a
description
of
existing
structural
and
non­
structural
controls
to
reduce
the
discharge
of
pollutants
from
the
MS4.

Once
permit
authorities
have
received
and
assessed
Part
1
of
the
application,
the
applicant
is
required
to
complete
Part
2.
Part
2
includes
the
following
requirements:


a
demonstration
that
the
applicant's
legal
authority
satisfies
the
regulatory
criteria;


source
identification
information
augmenting
Part
1
and
ensuring
that
all
major
outfalls
are
identified;


additional
quantitative
data;


a
management
program
to
control
the
discharge
of
pollutants
to
the
maximum
extent
practicable;
Applications
ICR
8/
5/
99
21

an
assessment
of
the
performance
of
proposed
controls;
and

a
financial
estimate
of
the
cost
of
implementing
the
proposed
management
programs.
The
estimate
must
identify
sources
of
revenue.

Petitions
for
Individual
Permit
EPA
may
receive
a
petition
requesting
that
a
facility
covered
under
an
NPDES
general
permit
obtain
an
individual
permit.
Depending
on
the
circumstances,
these
petitions
may
come
from
MS4
operators
or
any
other
person.
Federal
regulations
(
55
FR
48072)
allow
MS4
operators
to
petition
EPA
to
require
industrial
facilities
discharging
through
the
MS4
to
obtain
individual
NPDES
permits.
Ordinarily,
dischargers
of
storm
water
associated
with
industrial
activity
who
discharge
through
MS4s
are
eligible
for
coverage
under
general
permits
provided
they
meet
the
eligibility
provisions
of
the
permit.
In
addition,
any
person
may
petition
EPA
to
require
an
individual
permit
for
a
storm
water
discharge
that
contributes
to
a
water
quality
standard
violation
or
is
a
significant
contributor
of
pollutants
to
waters
of
the
United
States.
The
previous
ICR
included
a
discussion
of
petitions
submitted
by
MS4s
to
reduce
the
population
served
by
the
separate
storm
sewer.
As
this
is
a
one­
time
request
and
is
not
available
to
newly
designated
MS4s,
this
element
is
not
included
in
this
ICR.

Notice
of
Intent
to
be
Covered
Under
a
General
Permit
(
NOI)

Permitting
authorities
issue
general
permits
to
cover
multiple
permittees
requiring
similar
permit
conditions
within
a
designated
geographic
area
for
other
types
of
discharges
other
than
storm
water
associated
with
industrial
or
construction
activity.
General
permits
may
cover
certain
NPDES
discharges
and
sewage
sludge
management
facilities.
Rather
than
submitting
an
individual
application,
an
applicant
seeking
coverage
under
a
general
permit
must
submit
a
NOI.
Federal
regulations
require,
at
a
minimum,
that
applicants
provide
the
following
information
in
their
NOI:
the
legal
name
and
address
of
the
owner
or
operator,
the
facility
name
and
address,
the
type
of
facility
or
discharges,
and
the
receiving
stream(
s).
When
they
issue
general
permits,
permitting
authorities
may
impose
additional
information
to
be
submitted
with
the
NOI
that
they
regard
as
necessary
to
ensure
that
facilities
covered
under
the
permits
comply
with
the
objectives
and
provisions
of
the
CWA.

Although
permitting
authorities
may
impose
any
information
requirements
in
NOI,
they
typically
use
general
permits
in
cases
where
they
wish
to
minimize
the
burden
associated
with
reviewing
application
information.
Consequently,
applicants
are
usually
required
to
provide
simple,
easily
obtainable
data
in
their
NOI.

Permit
Consolidation
Request
Facilities
that
are
required
to
obtain
permits
for
more
than
one
EPA
program
may
request
that
their
permit
application
processing
be
consolidated.
This
is
a
voluntary
request,
made
by
submitting
a
letter
to
the
permit
authority.

Notification
of
Construction
Prior
to
Wastewater
Permit
Issuance
Generally,
construction
of
a
new
source
that
requires
an
Environmental
Impact
Statement
(
EIS)
is
prohibited
until
the
permit
authority
issues
a
final
NPDES
permit
that
incorporates
requirements
related
to
Applications
ICR
8/
5/
99
22
the
EIS.
Permit
applicants
who
wish
to
begin
construction
before
the
NPDES
permit
has
been
issued
must
notify
the
permit
authority.

NPDES
Ocean
Discharge
Information
During
the
first
two
years
of
operation,
facilities
that
discharge
into
territorial
seas,
the
contiguous
zone,
and
the
oceans
must
provide
information
that
supplements
the
data
they
provide
in
Form
1.
This
supplemental
information
is
site­
specific
and
highly
variable.
It
ranges
from
routine
water
quality
and
sediment
analyses
to
complex
impact
analyses
that
involve
studies
of
large
magnitude
and
area.
Permitting
authorities
use
the
information
to
modify
permit
conditions
before
a
permit
expires
or
when
dischargers
apply
for
new
permits.
The
permit
authority
reviews
all
other
available
sources
of
information,
including
EISs
and
CWA
Section
301(
h)
variance
requests,
before
requesting
dischargers
to
submit
additional
information

Notice
of
Termination
(
NOT)

Where
all
storm
water
discharges
associated
with
construction
activity
that
are
authorized
by
a
general
permit
are
eliminated,
or
where
the
operator
of
storm
water
discharges
associated
with
construction
activity
at
a
facility
changes,
the
operator
of
the
facility
must
submit
a
Notice
of
Termination
(
NOT).
This
is
also
a
voluntary
requirement
for
MSGPs.
This
one
page
form
requires
basic
facility
information,
operator
information,
permit
number,
reason
for
the
termination,
and
a
certification
statement.
NOTs
are
submitted
to
EPA
and
delegated
states.

4(
c)
Respondent
Activities
Respondent
activities
can
vary
substantially,
depending
on
the
type
of
applicant
and
the
application
used.
This
ICR
explains
these
activities
in
detail
for
each
set
of
application
requirements
(
see
Section
6.1
of
the
ICR,
"
Estimating
Respondent
Burden").
However,
any
particular
respondent
may
engage
in
the
following
types
of
activities:


Preparing
basic
information.
This
includes
reading
instructions
on
application
forms
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
topographic
maps,
water
flow
process
line
drawings,
data
on
production
levels,
data
on
effluent
characteristics,
management
programs,
financial
estimates,
engineering
data,
or
other
information
required
by
permitting
authorities,
to
include
developing
a
SWPPP
for
the
NOI­
Stormwater.


Sampling
and
analyzing
discharges
and
sludge.
This
may
involve
pollutant
scans,
biological
toxicity
testing,
impact
analyses,
field
monitoring,
or
other
scientific
analyses.


Maintaining
records.
All
NPDES
and
sewage
sludge
permit
applicants
must
keep
records
of
the
data
used
to
complete
their
applications
for
at
least
three
years.
SWPPPs
must
be
maintained
on­
site
for
the
duration
of
the
MSGP.
First­
time
applicants
may
need
to
develop
a
recordkeeping
system,
enter
data,
train
personnel,
and
file
information.
For
existing
facilities,
Applications
ICR
8/
5/
99
23
recordkeeping
entails
collecting
and
filing
raw
data.
The
ICR
for
Compliance
Assessment
estimates
the
recordkeeping
burden
for
existing
facilities
in
association
with
monitoring
information
such
as
monitoring
data
and
reports.
The
present
ICR
estimates
recordkeeping
burden
in
association
with
the
application
process.
9
This
ICR
does
not
calculate
the
burden
and
costs
associated
with
issuing
permits.
It
does,
however,
estimate
the
burden
and
costs
associated
with
reviewing
applications
for
permits.

Applications
ICR
8/
5/
99
24
5.
THE
INFORMATION
COLLECTED:
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
When
NPDES
permitting
authorities
receive
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
review
the
applications
in
more
detail
as
they
develop
permit
conditions.
9
Permitting
authorities
must
also
enter
application
data
into
PCS,
STORET,
and/
or
the
NOI
database.

Other
information
requests,
such
as
requests
for
supplemental
information
(
Section
308
Requests),
may
demand
more
extensive
or
immediate
review.

When
a
permitting
authority
issues
a
general
permit,
it
must
notify
those
dischargers
or
facilities
eligible
for
coverage
under
the
permit
(
some
exceptions
apply
to
certain
general
permits).
Notification
may
include
newspaper
announcements,
direct
mailings,
or
other
methods
of
communication.

When
permitting
authorities
receive
applications
for
general
permits,
they
must
determine
which
facilities,
if
any,
would
be
more
appropriately
governed
by
individual
permits.
As
part
of
these
activities,
EPA
may
notify
dischargers
or
sludge
facilities
that
they
need
to
apply
for
individual
permits.

Permittees
are
not
required
to
submit
SWPPPs
to
EPA
for
review.
These
plans
are
to
be
maintained
on­
site
at
the
facility
where
the
industrial
activity
is
taking
place
and
must
be
available
for
EPA
review
as
requested.

5(
b)
Collection
Methodology
And
Management
Because
each
application
or
information
collection
activity
contains
unique
information,
and
because
applicants
submit
applications
infrequently
(
once
every
five
years),
improved
information
technology
would
not
reduce
respondent
burden
in
a
cost­
effective
manner.

EPA
maintains
some
application
data
in
the
Agency's
databases,
PCS,
STORET,
and
NOI
database.
This
technology
reduces
the
burden
to
EPA
Headquarters
for
gathering
and
analyzing
national
permit
and
water
quality
data.

5(
c)
Small
Entity
Flexibility
For
many
reasons,
EPA
believes
the
reporting
requirements
discussed
in
this
ICR
do
not
place
an
unreasonable
burden
on
small
business.
EPA
developed
several
application
forms,
and
it
promulgated
different
application
requirements,
to
tailor
the
information
collection
demands,
considering,
among
other
10See
Editorial
Notes,
40
CFR
§
122.21.

Applications
ICR
8/
5/
99
25
factors,
the
size
and
complexity
of
the
facility.
Generally,
as
the
size
of
a
facility
increases,
the
amount
of
required
information
increases
correspondingly.

Several
of
the
applications
(
including
Form
1
and
NOIs,
for
example)
request
minimal
information,
such
as
the
name
and
location
of
the
facility,
or
merely
direct
the
applicant
to
complete
specific
sections
of
the
application
(
e.
g.,
Forms
2A
and
2S).
Furthermore,
facilities
submit
applications
infrequently,
typically
once
every
five
years.
The
burden
represented
by
these
applications
cannot
be
further
reduced
for
small
businesses.
Permitting
authorities
need
certain
basic
information
to
make
permitting
decisions.
This
basic
information
is
not
dependent
on
a
facility's
size.

Over
the
last
few
years,
EPA
has
reduced
reporting
burdens
on
businesses
of
all
sizes.
The
Agency
developed
general
permit
procedures
to
reduce
burdens
associated
with
the
application
process,
especially
the
burden
associated
with
storm
water
discharges.
Applicants
for
storm
water
general
permits,
for
instance,
do
not
need
to
submit
any
sampling
data.

Some
facilities
that
do
not
have
toxic
pollutants
in
their
effluent
are
not
required
to
provide
as
much
monitoring
information
on
Form
2C
as
those
with
toxic
discharges.
For
example,
coal
mines
with
a
probable
total
annual
production
less
than
100,000
tons
per
year
and
other
applicants
with
gross
total
annual
sales
averaging
less
than
$
100,000
per
year
(
in
second
quarter
1980
dollars)
may
qualify
for
reduced
monitoring
requirements.
10
EPA
also
developed
Form
2E
specifically
to
reduce
the
reporting
burden
for
certain
small
businesses.
These
businesses
are
new
or
existing
manufacturing,
commercial,
mining,
and
silvicultural
NPDES
permit
applicants
that
do
not
discharge
process
wastewater.
This
form
is
easier
to
complete
and
requires
only
routine
sampling
and
analysis.
The
Permit
Consolidation
Request
may
also
affect
small
businesses.
Small
businesses
(
like
all
applicants)
will
request
consolidated
permitting
when
they
determine
that
the
benefits
of
consolidation
outweigh
the
additional
minimal
burden
imposed
by
the
consolidation
request.

Minimizing
burden
to
small
entities
also
comes
in
the
form
of
guidance
materials.
For
example,
to
assist
facilities
of
all
sizes,
but
potentially
most
useful
for
small
businesses,
EPA
has
developed
numerous
guidance
manuals,
fact
sheets,
training
courses,
etc.
that
describe
procedures
for
developing
SWPPPs.

Finally,
many
small
businesses
do
not
discharge
any
pollutants.
Of
the
small
businesses
that
do
discharge,
many
of
them
discharge
pollutants
to
a
sewage
treatment
plant.
These
businesses
are
not
required
to
have
permits
and
thus
are
not
subject
to
the
reporting
requirements
contained
in
this
ICR.

5(
d)
Collection
Schedule
Federal
regulations
require
permittees
to
reapply
for
permits
at
least
every
five
years,
although
the
regulations
also
grant
permit
writers
the
authority
to
impose
more
frequent
reissuance.
Most
respondents
submit
applications
every
five
years.
When
calculating
burden,
this
ICR
assumes
that
all
permit
applicants
follow
this
schedule.
Applications
ICR
8/
5/
99
26
In
addition,
this
ICR
assumes
that
every
five
years,
permittees
will
perform
a
comprehensive
reevaluation
of
the
existing
SWPPP
and
modify
the
plan
as
appropriate.
This
re­
evaluation
is
anticipated
to
require
slightly
less
cost
and
burden
than
the
initial
cost
and
burden
of
developing
the
plan.

With
regard
to
sewage
sludge,
these
permit
applications
were
originally
required
in
three
phases.
The
first
phase,
those
due
within
180
days
after
promulgation
of
40
CFR
part
503
(
by
August
18,
1993),
consisted
of
applications
from
TWTDS
required
to
have
(
or
requesting)
site­
specific
limits.
These
facilities
were
primarily
sewage
sludge
incinerators.
The
second
phase
required
limited
background
information
from
sludge­
only
TWTDS
that
were
not
addressed
in
the
first
phase.
This
information
was
due
within
one
year
of
Part
503
publication
(
by
February
19,
1994).
The
last
phase
required
TWTDS
with
NPDES
permits
(
that
were
not
addressed
in
the
first
phase)
to
submit
sewage
sludge
information
during
the
NPDES
permit
renewal
process
(
i.
e.,
over
the
five­
year
permit
cycle).

Since
the
first
year
of
implementation
of
the
sewage
sludge
permitting
program
(
i.
e.,
from
March
22,
1993
to
March
21,
1994)
has
passed,
EPA
anticipates
three
groups
of
respondents:
1)
one­
fifth
of
the
NPDES
permittees
will
need
to
submit
applications
each
year;
2)
new
sludge­
only
facilities
will
submit
limited
background
information
each
year;
and
3)
some
sludge­
only
facilities
that
have
already
submitted
the
limited
background
information
will
be
required
by
EPA
to
submit
permit
applications
each
year.

Some
information
collection
activities
included
in
this
ICR
do
not
follow
routine
schedules.
For
example,
permittees
request
permit
consolidations
and
permit
authorities
request
supplemental
information
as
needed.
Please
see
Section
6
of
this
ICR
for
detailed
estimates
of
collection
schedules
for
these
activities.
Applications
ICR
8/
5/
99
27
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)(
i)
Estimating
Applicant
Respondent
Burden
EPA
estimates
that
the
total
annual
burden
to
applicant
respondents
is
approximately
1,990,775
hours.

To
calculate
the
total
annual
applicant
respondent
burden,
EPA
first
calculated
the
annual
burden
for
each
permit
application
and
for
each
information
request
associated
with
permit
applications.
The
Agency
then
added
these
together.
Thus,
the
total
annual
burden
is
the
sum
of
the
annual
burdens
for
all
permit
applications
and
associated
information
requests.
In
this
section,
EPA
explains
its
applicant
respondent
burden
estimates
for
each
application
and
information
request.

Exhibit
2
estimates
the
number
of
respondents
that
must
provide
application
information
or
information
associated
with
applications.
EPA
uses
these
figures
to
calculate
burden
and
costs.
Exhibit
18,
at
the
end
of
this
section,
summarizes
burden
estimates
for
all
applications
and
information
requests.
It
also
presents
the
total
annual
burden
to
applicant
respondents.

In
accordance
with
OMB's
instructions,
this
ICR
calculates
burden
and
costs
to
respondents
on
an
annual
basis.
These
calculations
are
somewhat
complicated
because
there
are
two
types
of
respondents
discussed
in
this
ICR:
applicants
renewing
existing
permits,
and
applicants
applying
for
new
permits.
Generally,
existing
permits
must
be
renewed
every
five
years.
For
these
respondents,
the
ICR
assumes
that
the
number
of
applicants
renewing
per
year
equals
one­
fifth
the
total
number
of
existing
permitted
facilities.

For
those
facilities
applying
for
new
permits,
this
ICR
only
calculates
burden
and
cost
for
a
three
year
period.
At
the
end
of
that
period
this
ICR
will
be
revised
with
new
calculations
for
the
following
three
years.
Therefore,
for
the
burden
and
cost
calculations
for
respondents
applying
for
new
permits,
the
estimate
of
the
total
number
of
applicants
expected
over
the
next
three
years
is
divided
by
three
to
obtain
the
estimated
number
of
applicants
per
annum.

OMB
requires
agencies
to
calculate
the
average
burden
per
response.
To
determine
the
average
burden,
EPA
developed
a
cumulative
total
for
each
reporting
item.
The
average
applicant
burden
of
22.6
hours
is
based
on
the
total
annual
burden
estimate
of
1,990,775
hours
divided
by
88,165,
the
total
number
of
applicant
respondents.
It
should
be
noted,
however,
that
the
burden
will
vary
greatly
among
applicants.
For
example,
the
applicant
burden
for
a
large
MS4
equals
4,432
hours,
but
the
applicant
burden
for
a
facility
providing
a
notice
of
termination
equals
only
0.5
hour.
It
should
also
be
noted
that
in
some
cases,
applicant
respondents
may
complete
more
than
one
information
item.

Exhibit
2.
Number
of
Applicants
and
Information
Respondents
Information
Collection
Activity
Respondents
(
Per
Year)

Recordkeeping:

Existing
POTWs
4,284
Existing
Facilities
(
Non­
Municipal)
12,700
Major
New
Non­
Municipal
Facilities
40
MS4s
38
Information
Collection
Activity
Respondents
(
Per
Year)

11
A
query
of
PCS
in
May
1998
indicated
there
were
21,421
municipal
facilities.
The
same
estimate
as
detailed
in
the
Information
Collection
Request
for
National
Pollutant
Discharge
Elimination
System
(
NPDES)
Forms
2A
and
2S,
approved
by
OMB,
indicated
15,954
such
facilities.
While
the
estimate
is
based
on
older
data
obtained
from
PCS
data
in
June
1997
and
November
1993,
the
ICR
contains
a
breakdown
of
POTWs
based
on
size
and
pretreatment
program
status.
These
breakdowns
are
essential
to
properly
assessing
cost
and
burden
for
Form
2A.
For
the
purposes
of
this
consolidated
ICR,
these
"
breakdowns"
have
been
increased
proportionately
by
a
factor
of
1.34
(
21,421/
15,954)
to
reflect
the
overall
increase
in
the
number
of
municipal
facilities
as
indicated
by
the
May
1998
query
of
PCS.

Applications
ICR
8/
5/
99
28
Minor
New
Non­
Municipal
Facilities
and
Individual
SW
Permits
520
Sludge
Only
Facilities
(
Municipal)
434
Sludge
Only
Facilities
(
Non­
Municipal)
29
NOI­
IA's
SWPPP
16,350
Applicant
Recordkeeping
Subtotal
34,395
Form
1:

New
Facilities
520
Existing
Facilities
12,700
Form
2A11:

POTWs

1.0
MGD
981
POTWs
0.1
­
1.0
MGD
1,651
POTWs

0.1
MGD
1,651
POTWs

1.0
MGD
(
with
pretreatment
program
requirements)
421
POTWs
0.1
­
1.0
MGD
(
with
pretreatment
program
requirements)
104
POTWs

0.1
MGD
(
with
pretreatment
program
requirements)
12
POTWs

1.0
MGD
(
with
pretreatment
programs)
295
POTWs
0.1
­
1.0
MGD
(
with
pretreatment
programs)
48
POTWs

0.1
MGD
(
with
pretreatment
programs)
5
Sec.
308
Requests
­
Major
Municipals:

Routine
94
Medium
17
Complex
8
Sec.
308
Requests
­
Minor
Municipals:

Routine
66
Form
2B:
135
Form
2C:
8,167
Form
2D:

Major
New
Facilities
40
Information
Collection
Activity
Respondents
(
Per
Year)

Applications
ICR
8/
5/
99
29
Minor
New
Facilities
322
Sec.
308
Requests
­
Major
Non­
Municipal:

Routine
65
Medium
34
Sec.
308
Requests
­
Minor
Non­
Municipal:

Routine
239
Form
2E:

New
Facilities
138
Existing
Facilities
4,398
Form
2F:
60
Form
2S:

NPDES­
POTWs
3,225
NPDES­
POTWs
221
Sludge
Only­
POTWs
434
Sludge
Only­
POTWs
29
NOI­
Stormwater:
16,350
Alaskan
Lands:
3
MS4s:

Large
19
Medium
19
NOI:
4,217
Petition
for
Individual
Permit:
24
Permit
Consolidation:
100
Notice
of
Construction:
3
Ocean
Discharge:
30
Notice
of
Termination
(
NOT)

Construction
25,348
MSGP
(
Industrial
­
Stormwater)
6,857
Applicant
Respondent
Subtotal
88,165
*
Totals
may
not
add
exactly
due
to
rounding
errors
(
the
data
were
developed
using
spreadsheets).
**
Some
double
counting
of
respondents
may
occur,
e.
g.,
a
MSGP
facility
filing
an
NOI
and
an
NOT
during
the
life
of
this
ICR
Recordkeeping
All
permit
applicants
must
maintain,
for
at
least
three
years,
records
of
all
data
used
to
complete
their
permit
applications.
The
burden
associated
with
recordkeeping
depends
on
the
type
of
permit,
the
size
of
the
facility,
and
whether
the
facility
already
has
a
recordkeeping
system.
EPA
estimates
the
burden
for
this
activity
as
follows:
Applications
ICR
8/
5/
99
30
Exhibit
3.
Applicant
Recordkeeping
Burden
Type
of
Permittee
Activity
Burden
(
hours)

Existing
Facility
Collect
and
file
raw
data
provided
on
application
1
Major
New
Facility;
Large
or
Medium
MS4
Develop
recordkeeping
system;
enter
data;
train
personnel;
and
file
information
5
Minor
New
Facility;
Individual
Storm
Water
Permit
Applicant;
Sludge­
Only
Facility;
NOI­
Stormwater
SWPPP
Develop
recordkeeping
system;
enter
data;
train
personnel;
and
file
information
1.5
Estimates
from
EPA
and
the
Permit
Compliance
System
(
PCS)
lists
a
total
of
84,921
existing
facilities.
These
include
63,500
non­
municipal
facilities
(
3,396
major
and
60,104
minor)
filing
individual
permits
and
21,421
municipal
facilities.
Assuming
that
one­
fifth
of
all
permittees
file
applications
each
year,
the
annual
number
of
existing
facilities
with
recordkeeping
burden
is
16,984
.

EPA
estimates
that
40
major
new
non­
municipal
facilities
will
apply
for
permits
each
year
and
19
large
and
19
medium
MS4s
will
apply
for
separate
storm
sewer
system
permits.
The
Agency
predicts
460
minor
new
non­
municipal
facilities
will
apply
for
permits
and
60
facilities
will
apply
for
individual
storm
water
permits
each
year.
Finally,
EPA
estimates
that
2,317
sludge­
only
facilities
(
2,172
municipal
and
145
nonmunicipal
will
apply
for
sludge
permits
and
81,748
facilities
will
develop
a
SWPPP
as
part
of
the
NOIStormwater
application
over
the
next
5
years.
This
equals
463
sludge
only
facilities
(
434
municipal
and
29
non­
municipal)
filing
applications
and
16,350
facilities
maintaining
a
SWPPP
annually.

Each
of
the
16,984
existing
facilities
applying
for
an
NPDES
permit
are
expected
to
spend
one
(
1)
hour
maintaining
records
each
year,
thus
the
annual
burden
will
be
16,984
hours.
The
40
major
new
facilities
and
38
MS4s
are
expected
to
spend
5
hours
each,
resulting
in
an
annual
burden
of
390
hours.
The
460
new
non­
municipal
minor
facilities,
60
individual
storm
water
permit
applicants,
463
sludge­
only
facilities,
and
16,350
NOI­
Stormwater
are
expected
to
spend
1.5
hours
each,
resulting
in
an
annual
burden
of
25,999
hours.

Taken
together,
the
total
annual
burden
to
respondents
for
recordkeeping
is
estimated
to
be
43,373
hours.

Except
for
SWPPPs
required
by
the
NOI­
Stormwater,
this
ICR
does
not
include
the
recordkeeping
burden
associated
with
NOIs
and
NOTs.
Most
applicants
need
only
provide
the
name
and
address
of
the
owner
or
operator
and
of
the
facility,
the
type
of
facility
or
discharge,
and
the
receiving
water.
As
such,
applicants
will
not
need
to
maintain
any
records
for
this
basic
information.
Applications
ICR
8/
5/
99
31
Form
1
Applications
ICR
8/
5/
99
32
EPA
estimates
that
Form
1
requires
three
(
3)
hours
to
complete
for
the
first
time.
New
respondents
must
read
and
fill
out
the
form,
prepare
a
topographic
map,
and
review
and
mail
the
completed
application.
Applicants
renewing
existing
permits
will
spend
one
(
1)
hour
completing
Form
1
because
these
applicants
need
only
send
a
duplicate
of
the
previously
submitted
form,
updating
material
if
necessary.
This
applies
to
NPDES
applicants
who
have
permits
in
other
EPA
programs;
these
applicants
also
submit
copies
of
existing
forms.

PCS
identifies
63,500
existing
non­
municipal
facilities
that
must
submit
Form
1.
If
one­
fifth
of
these
file
applications
each
year,
the
annual
number
of
respondents
in
this
group
is
12,700.
If
each
respondent
spends
1
hour
submitting
the
form,
the
annual
burden
will
be
12,700
hours.

EPA
estimates
that
460
new
non­
municipal
facilities
and
will
submit
Form
1
each
year.
In
addition,
the
Agency
estimates
that
60
facilities
will
submit
Form
1
each
year
with
their
applications
for
individual
storm
water
permits.
If
each
of
these
respondents
needs
3
hours
to
complete
the
form,
their
annual
burden
will
be
1,559
hours.

Altogether,
the
estimated
annual
burden
to
respondents
of
Form
1
is
14,259
hours.

Form
2A
EPA
estimates
that
POTWS
will
spend
the
following
amount
of
time
completing
the
various
sections
of
Form
2A:

Exhibit
4.
Form
2A
­
Burden
per
Applicant
Respondent
by
Section*

ACTIVITY
BURDEN
(
HOURS)

Basic
a
B
C
D
Major
POTWS
Review
Form
1.5
0.5
0.5
0.5
0.5
Gather
Information
2.5
4.0
2.5
4.0
7.5
Record
Information
2.5
1.5
1.5
0.5
1.0
Subtotal
6.5
6.0
4.5
5.0
9.0
Minor
POTWS
(
0.1
­
1.0
MGD)
Review
Form
1.5
0.5
0.5
0.5
0.5
Gather
Information
1.5
2.0
2.5
1.0
5.5
Record
Information
2.0
1.0
1.5
0.5
1.0
Subtotal
5.0
3.5
4.5
2.0
7.0
Minor
POTWS
(

0.1
MGD)
Review
Form
1.5
0.5
0.5
0.5
0.5
Gather
Information
1.0
2.0
2.5
1.0
5.5
Record
Information
1.5
1.0
1.5
0.5
1.0
Subtotal
4.0
3.5
4.5
2.0
7.0
*
Most
applicants
do
not
complete
every
section.
Applications
ICR
8/
5/
99
33
Of
the
possible
4,284
Form
2A
annual
respondents,
all
majors
and
minors
will
complete
the
basic
application
information
section.
All
major
POTWS
and
all
minor
POTWS
with
pretreatment
programs
will
complete
Sections
a.
and
B.
EPA
assumes
90%
of
major
POTWS,
15%
of
large
minors,
and
1%
of
small
minors
have
SIUs
and
therefore,
will
complete
Section
C.
With
regard
to
Section
D,
EPA
assumes
20%
of
the
major
POTWS
and
3.6%
of
minor
POTWS
have
CSOs.
Exhibit
5
below
details
Form
2A
annual
respondent
burden
based
on
these
assumptions
and
the
burden
per
respondent
by
section
estimates.

Exhibit
5.
Form
2A
Applicant
Respondent
Burden
Section
Major
POTWS
Minor
POTWS
(
0.1­
1.0
MGD)
Minor
POTWS
(

0.1
MGD)

(
a)
Respondent
s
per
year
(
B)
Burden/
respondent
(
hours)
(
C)
Annual
Burden
(
hours)
(
D)
Respondents
per
year
(
E)
Burden/
respondent
(
hours)
(
F)
Annual
Burden
(
hours)
(
G)
Respondents
per
year
(
H)
Burden/
respondent
(
hours)
(
I)
Annual
Burden
(
hours)

Basic
981
6.5
6,378
1,651
5.0
8,257
1,651
4.0
6,606
a
981
6.0
5,887
48
3.5
166
5
3.5
19
B
981
4.5
4,416
48
4.5
214
5
4.5
24
C
883
5.0
4,416
248
2.0
495
17
2.0
33
D
196
9.0
1,766
59
7.0
416
59
7.0
416
Total*
981
22,863
1,651
9,549
1,651
7,098
*
Note,
the
total
respondents
per
year
are
based
on
the
entire
application,
not
the
respondent
per
application
section.

The
estimated
burden
for
the
4,284
respondents
filing
a
Form
2A
application
each
year
is
39,510
hours.

Additional
NPDES
Application
Requirements
for
Municipal
Dischargers
(
Section
308
Request)

Because
requests
for
supplemental
information
vary
in
complexity,
this
ICR
calculates
burden
according
to
the
complexity
of
the
request.
EPA
estimates
that
facilities
spend
5
hours
responding
to
routine
requests.
This
includes
1
hour
to
read
and
understand
the
request,
2
hours
to
obtain
information,
and
2
hours
to
write
a
response.
Requests
of
medium
complexity
require,
on
average,
50
hours.
EPA
estimates
that
complex
requests
demand
1,000
hours.

EPA
may
request
additional
information
from
a
facility
at
any
time.
Generally,
facilities
are
more
likely
to
receive
Section
308
Requests
when
they
apply
or
re­
apply
for
permits
than
at
other
times.
Therefore,
this
ICR
divides
municipal
respondents
into
two
categories:
those
that
are
applying
for
permits
in
a
particular
year,
and
those
that
are
not.
Since
permits
typically
last
5
years,
one­
fifth
of
all
facilities
apply
for
permits
each
year.

Based
on
the
newly
developed
Form
2A,
EPA
estimates
a
significant
reduction
(
i.
e.,
90%)
in
the
number
of
308
requests
made
during
the
application
process.
Previously
EPA
estimated
that
75%
of
the
major
municipal
and
10%
of
the
minor
facilities
receive
Section
308
Requests
in
the
year
they
apply
for
permits.
Applications
ICR
8/
5/
99
34
Therefore,
EPA
currently
estimates
7.5%
major
facilities
and
1%
of
minors
will
receive
a
308
request
as
part
of
the
application
process.

With
regard
to
308
requests
not
made
during
the
application
process,
EPA
previously
estimated
5%
of
the
remaining
major
facilities
will
receive
such
a
request.
This
assumption
remains
unchanged.
For
minor
municipals,
EPA
previously
assumed
1%
of
the
remaining
minor
facilities
receive
them
each
year.
This
assumption
too
remains
unchanged.
The
following
exhibit
summarizes
the
number
of
respondents
for
these
requests.

Exhibit
6.
Annual
Municipal
Applicant
Respondents
For
Section
308
Requests
Respondent
Type
Total
Existing
(
a)
Applying
Annually
(
B)
Not
Applying
(
Annual)
(
a)
+
(
B)
Total
Annual
Major
Facility
4,906
74
45
119
Minor
Facility
16,515
33
33
66
TOTAL
RESPONDENTS:
21,421
185
The
following
table
calculates
the
burden
for
municipal
respondents
based
on
the
complexity
of
the
request,
and
it
calculates
the
total
annual
burden.
It
also
estimates
the
number
of
facilities
responding
to
routine,
medium,
and
complex
requests.

Exhibit
7.
Total
Annual
Applicant
Burden
to
Municipal
Facilities
For
Section
308
Requests
Respondent/
Request
(
a)

Respondents
Per
Year
(
B)
Burden
(
Hrs.)
Per
Respondent
(
a)
*
(
B)

Total
Annual
Burden
(
Hrs.)

Major
Facilities
Routine
requests
94
5
471
Medium
requests
17
50
826
Complex
requests
8
1,000
8,333
Subtotal
119
9,629
Minor
Facilities
Routine
requests
66
5
329
TOTALS:
185
9,958
Applications
ICR
8/
5/
99
35
Based
on
the
calculations
above,
EPA
estimates
that
the
total
annual
burden
to
municipal
facilities
for
Section
308
Requests
is
9,958
hours.
In
addition,
50%
of
POTWS
that
receive
complex
requests
pay
contract
laboratories
to
conduct
the
tests.

Form
2B
EPA
estimates
that
respondents
will
spend
six
(
6)
hours
reading
the
instructions,
gathering
the
necessary
information,
and
completing
and
mailing
Form
2B.
The
Agency
estimates
that
there
are
13,500
concentrated
animal
feeding
or
aquatic
animal
production
facilities.
Ninety­
five
percent
(
0.95)
of
these
facilities
file
for
general
permits.
Of
the
remaining
respondents
(
i.
e.,
675),
on
average
one­
fifth
of
these
facilities
will
file
an
application
annually
(
i.
e.,
135).
At
6
hours
per
respondent,
the
estimated
annual
burden
for
Form
2B
is
810
hours.

Form
2C
Form
2C
requires
approximately
33
hours
to
complete,
EPA
estimates.

PCS
reports
63,500
existing
non­
municipal
facilities.
Of
these,
675
are
animal
feeding
and
aquatic
production
facilities,
which
must
complete
Form
2B.
Therefore,
62,825
facilities
must
submit
either
Form
2C
or
Form
2E.
Those
that
discharge
process
wastewater
use
Form
2C,
and
those
that
discharge
nonprocess
wastewater
use
Form
2E.
EPA
assumes
that
65
percent
of
these
facilities
discharge
process
wastewater,
yielding
40,836
facilities
subject
to
the
requirements
of
Form
2C.
If
one­
fifth
(
0.2)
of
all
permittees
file
applications
each
year,
the
annual
number
of
respondents
is
8,167.
Assuming
that
each
respondent
spends
33
hours
preparing
the
form,
EPA
estimates
the
annual
burden
for
Form
2C
to
be
269,519
hours.

This
ICR
does
not
separate
the
burden
for
major
and
minor
facilities.
The
burden
will
probably
be
lower
for
minor
facilities
because
facilities
monitor
only
for
pollutants
believed
to
be
present.
Minor
facilities
typically
discharge
fewer
pollutants
than
majors.

Form
2D
Applications
ICR
8/
5/
99
36
EPA
estimates
that
major
new
facilities
will
spend
46
hours
completing
Form
2D,
and
minor
facilities
will
spend
32
hours.
The
following
table
summarizes
burden
estimates
for
particular
activities
associated
with
Form
2D.

Exhibit
8.
Form
2D
Applicant
Burden
Activity
Burden
(
Hrs.)
for
Major
New
Facility
Burden
(
Hrs.)
for
Minor
New
Facility
Read
Form
and
Instructions
8
2
Gather
General
File
Information
2
4
Prepare
Graphics
Materials
2
2
Obtain
Engineering
Data
(
estimates)
2
4
Type
the
Information
13
3
Review
by
Management
5
6
Transmit
the
Application
2
3
Sample
and
Analyze
Discharge
After
Operation
Begins
12
8
Total
Burden
per
Respondent:
46
32
The
Agency
estimates
that
40
new
major
non­
municipal
facilities
and
460
new
minor
facilities
will
apply
for
permits
each
year.
Of
the
minor
facilities,
EPA
estimates
that
70
percent
will
discharge
process
wastewater.
This
yields
an
estimated
40
respondents
filing
Form
2D
as
new
major
facilities
and
322
completing
Form
2D
as
new
minor
facilities.
(
The
remaining
138
minor
new
facilities
use
Form
2E.)
The
estimated
annual
burden
for
Form
2D
is
1,840
hours
for
major
new
facilities
and
10,304
hours
for
minor
new
facilities,
or
12,144
hours
altogether.

Additional
NPDES
Application
Requirements
for
Non­
municipal
Dischargers
(
Section
308
Request)

Because
requests
for
supplemental
information
vary
in
complexity,
this
ICR
calculates
burden
according
to
the
complexity
of
the
request.
EPA
estimates
that
facilities
spend
5
hours
responding
to
routine
requests.
This
includes
1
hour
to
read
and
understand
the
request,
2
hours
to
obtain
information,
and
2
hours
to
write
a
response.
Requests
of
medium
complexity
require,
on
average,
50
hours.

EPA
may
request
supplemental
information
from
a
facility
at
any
time.
Generally,
facilities
are
more
likely
to
receive
Section
308
Requests
when
they
apply
or
re­
apply
for
permits
than
at
other
times.
Therefore,
this
ICR
divides
non­
municipal
respondents
into
two
categories:
those
that
are
applying
for
permits
in
a
particular
year,
and
those
that
are
not.
Since
permits
typically
last
5
years,
one­
fifth
of
all
facilities
apply
for
permits
each
year.

The
Agency
assumes
that
5
percent
of
the
major
non­
municipals
receive
requests
when
they
apply
for
permits,
and
10
percent
of
the
remaining
receive
requests
at
other
times.
Of
the
minor
non­
municipals,
1
Applications
ICR
8/
5/
99
37
percent
receive
requests
when
they
apply
for
permits
and
1
percent
of
the
remaining
receive
requests
at
other
times.
The
following
table
summarizes
the
number
of
non­
municipal
respondents
for
these
requests.

Exhibit
9.
Annual
Non­
municipal
Applicant
Respondents
for
Section
308
Requests
Respondent
Type
Total
Existing
(
a)
Applying
Annually
(
B)
Not
Applying
(
Annual)
(
a)
+
(
B)
Total
Annual
Major
Facility
3,396
34
65
98
Minor
Facility
60,104
120
119
239
Total
Respondents:
63,500
338
The
following
table
calculates
the
burden
for
each
group
of
respondents
based
on
the
complexity
of
the
request,
and
it
calculates
the
total
annual
burden.
It
also
estimates
the
number
of
facilities
responding
to
routine
and
medium
requests.

Exhibit
10.
Total
Annual
Applicant
Burden
to
Non­
Municipal
Facilities
for
Section
308
Requests
Respondent/
Request
(
a)

Respondents
Per
Year
(
B)
Burden
(
Hrs.)
Per
Respondent
(
a)
*
(
B)

Total
Annual
Burden
(
Hrs.)

Major
Facilities
Routine
requests
65
5
323
Medium
requests
34
50
1,698
Subtotal
98
2,021
Minor
Facilities
Routine
requests
239
5
1,196
Total:
338
3,217
Based
on
the
calculations
above,
EPA
estimates
that
the
total
annual
burden
to
non­
municipal
facilities
for
Section
308
requests
is
3,217
hours.
In
addition,
25%
percent
of
major
non­
municipal
facilities
that
receive
medium
requests
pay
contract
laboratories
to
conduct
the
tests.
Applications
ICR
8/
5/
99
38
Form
2E
EPA
estimates
that
applicants­­
non­
municipal
facilities
that
discharge
nonprocess
wastewater­­
will
spend
14
hours
completing
Form
2E.
The
table
below
estimates
the
burden
for
specific
activities
associated
with
Form
2E.

Exhibit
11.
Form
2E
Applicant
Respondent
Burden
Activity
Burden
(
Hrs.)

Read
Form
and
Instructions
1
Gather
General
Information
2
Obtain
or
Estimate
Engineering
Data
2
Sample
and
Analyze
or
Estimate
Pollutants
in
Discharge
4
Type
Information
1
Review
by
Management
2
Transmit
Application
2
TOTAL
BURDEN
PER
RESPONDENT:
14
EPA
and
PCS
reports
63,500
existing
non­
municipal
facilities.
Of
these,
675
are
animal
feeding
and
aquatic
production
facilities,
which
must
complete
Form
2B.
Therefore,
62,825
facilities
must
submit
either
Form
2C
or
Form
2E.
Those
that
discharge
process
wastewater
use
Form
2C,
and
those
that
discharge
nonprocess
wastewater
use
Form
2E.
EPA
assumes
that
35
percent
of
these
facilities
discharge
nonprocess
wastewater,
creating
21,989
existing
facilities
subject
to
the
requirements
of
Form
2E.
If
onefifth
of
all
existing
permittees
file
applications
each
year,
the
annual
number
of
respondents
is
4,398.
Assuming
that
each
of
these
respondents
spends
14
hours
preparing
the
form,
EPA
estimates
the
annual
burden
to
existing
facilities
to
be
61,569
hours.

To
this
figure,
the
Agency
adds
new
non­
municipal
facilities
that
discharge
nonprocess
wastewater.
EPA
estimates
that
138
new
non­
municipal
facilities
will
file
Form
2E
each
year.
The
total
annual
burden
to
these
facilities
will
be
1,932
hours.

Adding
the
burden
for
existing
facilities
and
new
facilities,
EPA
calculates
that
the
total
annual
burden
to
Form
2E
respondents
will
be
63,501
hours.

Form
2F
On
average,
respondents
will
spend
28.6
hours
completing
Form
2F.
The
following
table
estimates
the
burden
for
specific
activities
required
by
Form
2F.
Applications
ICR
8/
5/
99
39
Exhibit
12.
Form
2F
Applicant
Respondent
Burden
Activity
Burden
(
Hrs.)

Prepare
Site
Map
1
Describe
Significant
Materials
1
Certify
That
All
Outfalls
Have
Been
Tested
for
Non­
Storm
Water
Discharges
5.6
Gather
Existing
Information
on
Spills
and
Leaks
1
Sample
and
Analyze
Wastewater
for
Pollutants
20
TOTAL
BURDEN
PER
RESPONDENT:
28.6
EPA
estimates
that
122,000
facilities
have
storm
water
discharges
associated
with
industrial
activities
and
must
apply
for
NPDES
permits.
The
Agency
bases
its
estimate
on
the
number
of
NOIs
received
for
storm
water
general
permits
by
EPA
and
the
States,
number
of
group
applicants,
and
the
total
number
of
2Fs
received.

Of
these
122,000
dischargers,
very
few
have
or
will
apply
for
individual
storm
water
permits
due
to
the
availability
of
less
burdensome
options
(
i.
e.,
general
permits).
PCS
indicates
that
only
298
facilities
have
submitted
a
Form
2F
since
the
beginning
of
the
storm
water
program
in
1990.
Dividing
this
number
by
the
five
permit
years,
gives
approximately
60
individual
applicants
per
year.
The
estimated
annual
burden
for
Form
2F
facilities
is
1,705
hours.

Form
2S
EPA
estimates
that
respondents
will
spend
8.7
hours
completing
Form
2S.

The
annual
number
of
respondents
consists
of
POTWS
and
privately
owned
treatment
works
(
POTWs)
renewing
their
NPDES
permits,
new
sludge­
only
facilities
submitting
limited
background
information
(
Part
1
of
Form
2S),
and
sludge­
only
facilities
requested
by
the
permitting
authority
to
submit
a
permit
application
(
Part
2).
The
following
exhibit
details
the
total
number
of
respondents
expected
for
each
respondent
type.
EPA
estimated
in
a
previous
ICR
entitled
Information
Collection
Request
for
National
Pollutant
Discharge
Elimination
System
(
NPDES)
Forms
2A
and
2S
that
existing
sludge­
only
facilities
and
existing
facilities
seeking
or
required
to
have
site­
specific
pollutant
limitations
were
due
by
February
19,
1994
or
earlier
and
therefore,
would
not
resubmit
applications
during
the
life
of
the
ICR.
This
ICR
assumes
that
permits
issued
to
these
respondents
will
be
up
for
renewal
and
that
on
average,
one­
fifth
of
these
total
respondents
will
respond
annually.
EPA
assumes
that
one­
fifth
of
all
other
existing
facilities
will
reapply
annually.
For
new
facilities
anticipated
over
the
life
of
this
ICR,
one­
third
are
anticipated
to
respond
annually.
Applications
ICR
8/
5/
99
40
Exhibit
13.
Annual
Number
of
Form
2S
Applicant
Respondents
Type
of
Applicant
Total
Number
of
Respondents
Average
Annual
Number
of
Respondents
POTWs
POTWs
Sub­
total
POTWs
POTWs
Subtotal
NP
DES
P
E
R
MI
TTEES
Generate
Only
Existing
3,830
254
4,084
766.0
50.8
816.8
New
0
5
5
0.0
1.7
1.7
Generate
&
Land
Apply
Existing
8,470
578
9,048
1,694.0
115.6
1,809.6
New
0
10
10
0.0
3.3
3.3
Generate
&
Surface
Disposal
(
site
specific)
Existing
2
0
2
0.4
0.0
0.4
New
0
0
0
0.0
0.0
0.0
Generate
&
Surface
Disposal
(
not
site
specific)
Existing
3,655
243
3,898
731.0
48.6
779.6
New
0
4
4
0.0
1.3
1.3
Generate
&
Incinerate
Existing
170
0
170
34.0
0.0
34.0
New
0
0
0
0.0
0.0
0.0
Exhibit
13.
Annual
Number
of
Form
2S
Applicant
Respondents
Type
of
Applicant
Total
Number
of
Respondents
Average
Annual
Number
of
Respondents
POTWs
POTWs
Sub­
total
POTWs
POTWs
Subtotal
Applications
ICR
8/
5/
99
41
S
L
UDGE
ONL
Y
Generate
Only
Existing
­
Part
1
only
1,605
105
1,710
321.0
21.0
342.0
Existing
­
Part
2
0
0
0
0.0
0.0
0.0
New
­
Part
1
only
74
6
80
24.7
2.0
26.7
New
­
Part
2
0
0
0
0.0
0.0
0.0
Surface
Disposal
Only
(
site
specific)
Existing
2
2
4
0.4
0.4
0.8
New
0
0
0
0.0
0.0
0.0
Surface
Disposal
Only
(
not
site
specific)
Existing
­
Part
1
only
369
23
392
73.8
4.6
78.4
Existing
­
Part
2
41
3
44
8.2
0.6
8.8
New
­
Part
1
only
13
1
14
4.3
0.3
4.7
New
­
Part
2
6
0
6
2.0
0.0
2.0
Incinerate
Only
Existing
0
0
0
0.0
0.0
0.0
New
0
0
0
0.0
0.0
0.0
Total
18,237
1,234
19,471
3,660
250
3,910
Burden
estimates
for
completing
the
six
sections
of
Form
2S
are
detailed
in
the
exhibit
below.
Utilizing
these
burden
estimates
and
the
estimated
annual
number
of
respondents,
EPA
anticipates
3,910
annual
respondents
with
a
total
annual
burden
for
Form
2S
of
34,070
hours,
or
8.7
hours
per
respondent.

Exhibit
14.
Form
2S
Applicant
Burden
per
Respondent
by
Section
(
Hours)

Activity
Section
Burden
Part
1
Part
2,
a
Part
2,
B
Part
2,
C
Part
2,
D
Part
2,
E
Review
Form
1.0
0.5
1.0
1.5
1.5
1.5
Gather
Information
1.0
1.1
1.3
2.0
2.5
2.5
Record
Information
on
Form
0.5
0.7
1.0
1.5
1.5
1.5
Total
2.5
2.3
3.3
5.0
5.5
5.5
Applications
ICR
8/
5/
99
42
Exhibit
15.
Form
2S
Annual
Applicant
Respondent
Burden
(
Hours)

Type
of
Applicant
Annual
Respondent
Required
Information
Burden/
Response
(
C)
Total
Annual
Burden
POTWS
(
a)
POTWS
(
B)
POTWS
(
a*
C)
POTWS
(
B*
C)
Subtotal
NP
DES
P
E
R
MI
TTEES
Generate
Only
Existing
766.0
50.8
AB
5.6
4,290
284
4,574
New
0.0
1.7
AB
5.6
0
9
9
Generate
&
Land
Apply
Existing
1,694.0
115.6
ABC
10.6
17,956
1,225
19,182
New
0.0
3.3
ABC
10.6
0
35
35
Generate
&
Surface
Disposal
(
site
specific)
Existing
0.4
0.0
ABD
11.1
4
0
4
New
0.0
0.0
ABD
11.1
0
0
0
Generate
&
Surface
Disposal
(
not
site
specific)
Existing
731.0
48.6
ABD
11.1
8,114
539
8,654
New
0.0
1.3
ABD
11.1
0
15
15
Generate
&
Incinerate
Existing
34.0
0.0
ABE
11.1
377
0
377
New
0.0
0.0
ABE
11.1
0
0
0
S
L
UDGE
ONL
Y
Generate
Only
Existing
­
Part
1
only
321.0
21.0
1
2.5
803
53
855
Existing
­
Part
2
0.0
0.0
AB
5.6
0
0
0
New
­
Part
1
only
24.7
2.0
1
2.5
62
5
67
New
­
Part
2
0.0
0.0
AB
5.6
0
0
0
Surface
Disposal
Only
(
site
specific)
Existing
0.4
0.4
AD
7.8
3
3
6
New
0.0
0.0
AD
7.8
0
0
0
Surface
Disposal
Only
(
not
site
specific)
Existing
­
Part
1
only
73.8
4.6
1
2.5
185
12
196
Existing
­
Part
2
8.2
0.6
AD
7.8
64
5
69
New
­
Part
1
only
4.3
0.0
1
2.5
11
0
11
New
­
Part
2
2.0
0.0
AD
7.8
16
0
16
Incinerate
Only
Existing
0.0
0.0
AE
7.8
0
0
0
New
0.0
0.0
AE
7.8
0
0
0
Total
3,660
250
31,884
2,186
34,070
12
The
number
of
new
facilities
submitting
NOIs
per
year
was
estimated
based
on
the
average
number
of
facilities
between
1992
and
1997
that
submitted
NOIs
to
the
NOI
Processing
Center,
which
represents
respondents
for
those
states
and
territories
for
which
EPA
is
the
permitting
authority
for
general
permits
(
see
Appendix
a),
including
the
State
of
Florida
where
EPA
continues
to
administer
the
stormwater
program..

Applications
ICR
8/
5/
99
43
NOI­
Stormwater
EPA
estimates
that
respondents
will
spend
approximately
0.5
hours
completing
the
NOI­
Stormwater
form.
It
is
estimated
from
NOI
Processing
Center
data
that
approximately
3,200
industrial
facilities
will
apply
for
coverage
under
the
modified
MSGP
per
year
in
states
in
which
facilities
subject
to
the
MSGP
are
required
to
submit
NOIs
to
the
NOI
Processing
Center
(
i.
e.,
9
states
and
5
territories).
12
The
National
estimate
of
facilities
that
will
be
required
to
submit
NOIs
is
based
on
a
comparison
of
national
population
figures
with
the
9
states
and
5
territories.
Using
1990
U.
S.
Census
Bureau
estimates
(
see
Appendix
a),
the
total
US
population
is
252,510,216
while
the
population
of
the
9
states
and
5
territories
where
EPA
is
the
permitting
authority
for
general
permits
is
approximately
49,422,373
or
approximately
19.57%
of
the
total
population.
As
such,
scaling­
up
the
3200
industrial
facilities
to
a
national
basis
provides
an
estimate
of
16,350
respondents
per
year,
respondent
burden
for
completing
the
NOI­
Stormwater
form
is
8,175
hours.

Facilities
completing
an
NOI
with
regard
to
industrial
activity
must
develop
a
SWPPP.
Despite
the
fact
that
components
of
a
SWPPP
are
similar,
facility
design,
size
and
function,
as
well
as
the
level
of
effort
involved,
will
vary
for
each
facility.
As
such,
EPA
and
EPA
contractor
staff
identified
a
"
typical"
respondent
and
then
estimated
the
burden
for
that
respondent
to
prepare
a
SWPPP.
Respondent
burden
estimates
for
SWPPP
preparation
activities
are
provided
in
the
exhibit
below.
EPA
estimates
the
average
time
for
a
respondent
to
develop
a
SWPPP
is
80
hours,
and
is
a
one­
time
development
activity.

Exhibit
16.
Burden
for
SWPPP
Read
regulations
8.00
Select
Team
2.00
Describe
Sources
a.
drainage
map
8.00
b.
inventory
of
exposed
materials
4.00
c.
list
of
significant
spills/
leaks
1.00
d.
certification
of
non­
storm
water
2.00
e.
sampling
data
summary
2.00
f.
summary
of
potential
sources
3.00
Measures
and
Controls
a.
good
housekeeping
6.00
b.
preventative
maintenance
8.00
c.
inspections
6.00
d.
employee
training
6.00
e.
sediment
and
erosion
control
8.00
f.
runoff
management
8.00
Comprehensive
Site
Evaluation
a.
determine
scope
and
content
8.00
Applications
ICR
8/
5/
99
44
SWPPP
SUBTOTAL
80.00
At
80
hours
per
respondent
and
an
estimated
16,350
respondents,
the
estimated
annualized
burden
for
SWPPP
is
1,307,963
hours.
Altogether,
the
estimated
annual
burden
for
the
NOI­
Stormwater
and
SWPPP
is
1,316,137
hours.
Note:
this
is
a
newly
covered
area
under
this
ICR
and
represents
the
major
portion
of
the
increase
in
burden.

Uniform
Federal
Transportation/
Utility
System
Application
(
Alaskan
Lands
Application)

EPA
estimates
that
the
average
respondent
can
complete
the
Alaskan
Lands
Application
is
30
hours.
When
preparing
this
estimate,
EPA
considered
the
potential
variation
among
applicants;
depending
on
the
nature
and
location
of
the
proposed
facility,
a
respondent
may
spend
much
longer
preparing
the
form.

The
Agency
further
estimates
that
three
(
3)
respondents
will
file
this
application
each
year,
yielding
90
hours
expected
annual
burden.

Application
for
Large
and
Medium
Municipal
Separate
Storm
Sewer
Systems
(
MS4s)

There
are
a
total
of
267
permits
that
EPA
anticipates
will
be
issued
to
municipal
separate
storm
sewer
systems
(
MS4s).
To
date,
only
180
of
these
have
been
issued,
although
all
but
7
(
4
medium
MS4s,
1
large
MS4,
and
2
special
districts
in
Kansas)
have
submitted
their
applications.
107
of
the
180
permits
issued
(
54
medium
MS4,
53
large
MS4)
are
anticipated
to
expire
during
the
life
of
this
ICR.
Therefore,
it
is
estimated
that
a
total
of
114
MS4
applications
will
be
submitted
over
the
next
3
years,
or
38
per
year
(
19
medium
MS4s,
and
19
large
MS4s).

Large
MS4s
will
spend
more
time
preparing
applications
for
their
storm
water
discharges
than
medium
MS4s.
EPA
estimates
that
an
average
large
system
will
spend
4,432.4
hours
completing
an
application.
a
medium
system
will
spend
2,812.9
hours
completing
one.
The
following
table
estimates
the
burden
for
particular
activities
associated
with
the
application.

Although
these
estimates,
which
were
calculated
prior
to
the
development
of
any
MS4
applications,
did
not
accurately
reflect
the
actual
burden
to
MS4s
during
the
first
round
of
applications,
EPA
now
believes
that
these
estimates
are
reasonable
given
the
experience
of
the
MS4s
at
present.

Based
on
these
figures,
EPA
calculates
that
the
total
annual
burden
for
large
MS4s
is
84,216
hours
and
for
medium
MS4s
is
53,445
hours,
for
an
altogether
MS4
total
annual
burden
of
137,661
hours.

Exhibit
17.
Applicant
Respondent
Burden
for
Applications
for
Municipal
Separate
Storm
Sewer
Systems
Activity
Burden
(
Hrs.)
for
Large
System
Burden
(
Hrs.)
for
Medium
System
Part
1
Provide
General
Information
0.5
0.5
Describe
Legal
Authority
0.5
0.5
Identify
Sources
40
40
Exhibit
17.
Applicant
Respondent
Burden
for
Applications
for
Municipal
Separate
Storm
Sewer
Systems
Activity
Burden
(
Hrs.)
for
Large
System
Burden
(
Hrs.)
for
Medium
System
Applications
ICR
8/
5/
99
45
Characterize
Discharges
40
40
Perform
Field
Screening
Analysis
(
dry
weather
sampling)
430
215
Develop
Characterization
Plan
2.2
2.2
Describe
Existing
Management
Programs
2.2
2.2
Part
1
Subtotal
515.4
300.4
Part
2
Demonstrate
Adequate
Legal
Authority
40
40
Supplement
Source
Identification
Information
80
50
Analyze
Representative
Storm
Sample
1,749
874.5
Estimate
Collective
Annual
Pollutant
Load
from
All
Outfalls
40
40
Propose
a
Schedule
to
Update
Topographic
Map
to
Include
Seasonal
Pollutant
Load
for
Each
Major
Outfall
8
8
Develop
a
Management
Program
2,000
1,500
Part
2
Subtotal
3,917
2,512.5
TOTAL
BURDEN
PER
RESPONDENT:
4,432.4
2,812.9
Notice
of
Intent
(
NOI)

EPA
estimates
that
respondents
will
spend,
on
average,
one
(
1)
hour
to
file
a
Notice
of
Intent
for
general
permit.

PCS
data
indicate
that
21,085
general
permittees
exist.
EPA
assumes
that
none
of
these
general
permits
apply
to
storm
water
discharges.
One­
fifth
of
the
existing
permittees,
or
4,217
respondents,
will
file
NOIs
each
year.
Each
of
these
respondents
will
spend
1
hour
filing
the
NOI,
so
the
estimated
annual
burden
to
these
respondents
is
4,217
hours.

When
calculating
the
burden
to
respondents
for
NOIs,
this
ICR
does
not
include
sludge
management
facilities
seeking
coverage
under
general
permits.
Although
general
permits
may
be
used
to
control
sludge
use
or
disposal,
general
permits
of
this
kind
are
rare.
Consequently,
EPA
does
not
yet
have
sufficient
information
to
determine
the
burden
to
sludge
management
facilities.
When
EPA
is
better
able
to
estimate
the
number
of
facilities
potentially
covered
by
general
permits,
it
may
revise
this
ICR
accordingly.

Petitions
for
Individual
Permit
Based
on
information
supplied
by
contractors,
EPA
estimates
that
an
average
petition
requires
40
hours
to
prepare.

There
are
two
types
of
petitions.
Both
types
may
be
submitted
by
MS4s,
and
one
may
be
submitted
by
anyone.
Municipal
sewer
systems
may
petition
permitting
authorities
to
require
dischargers
Applications
ICR
8/
5/
99
46
using
their
systems
to
obtain
individual
permits.
Anyone
may
petition
authorities
to
require
an
individual
permit
for
a
storm
water
discharge
that
contributes
to
water
quality
violations
or
is
a
significant
contributor
of
pollutants.
For
purposes
of
simplicity,
this
ICR
assumes
that
all
petitions
are
submitted
by
MS4s.

EPA
anticipates
that
it
will
receive
24
petitions
each
year
over
the
next
three
years.
The
Agency
estimates
that
10
of
these
petitions
will
come
from
large
MS4s
each
year,
and
the
remaining
14
will
come
from
medium
MS4s.

Thus,
the
total
annual
burden
is
400
hours
for
large
MS4s
and
560
hours
for
medium
MS4s.
The
estimated
total
annual
burden
to
all
respondents
petitioning
for
an
individual
permit
is
960
hours.

Permit
Consolidation
Request
Facilities
that
must
obtain
permits
for
more
than
one
EPA
program
may
request
that
their
permit
application
processes
be
consolidated.
EPA
estimates
that
a
facility
will
spend
two
(
2)
hours
writing,
typing,
editing,
and
mailing
a
request.
Based
on
past
experience,
the
Agency
anticipates
that
100
facilities
will
file
Permit
Consolidation
Requests
each
year;
hence,
the
total
estimated
annual
burden
for
this
information
collection
is
200
hours.

Notification
of
Construction
EPA
estimates
that
an
average
respondent
will
spend
one
(
1)
hour
reading
regulations
and
preparing
a
letter
notifying
EPA
of
unauthorized
construction.
The
Agency
also
estimates
that
three
(
3)
facilities
will
report
construction
violations
each
year.
Thus,
the
total
estimated
annual
burden
is
3
hours.

Ocean
Discharge
Information
Permittees
generally
hire
environmental
consultants
to
conduct
ocean
discharge
studies.
These
studies
may
include
site
surveys,
effluent
monitoring,
field
monitoring,
and
data
analysis.
Field
monitoring
may
require
scuba
diving
and
the
help
of
a
marine
biologist.
This
ICR
includes
consultant
labor
hours
in
its
estimates
of
respondent
burden.
The
Agency
estimates
that
a
respondent
will
spend
778
hours
supplying
Ocean
Discharge
information.
Burden
estimates
are
based
on
EPA's
experience
with
field
monitoring
programs
in
ocean
dumping
and
NPDES
permit
monitoring.
The
following
table
calculates
the
average
amount
of
time
a
respondent
will
spend
preparing
ocean
discharge
information.

Based
on
permit
issuance
estimates,
EPA
believes
that
approximately
30
permittees
will
be
require
to
submit
ocean
discharge
information
each
year.
Assuming
30
respondents
spend
an
average
of
778
hours
supplying
this
information
each
year,
the
estimated
total
annual
burden
for
this
information
request
is
23,340
hours.

Notice
of
Termination
(
NOT)

EPA
estimates
that
on
average,
general
permittees
will
spend
0.5
hours
on
filing
a
notice
of
termination
(
NOT).

Consultations
with
the
NOI
processing
center
indicate
that
from
1995
through
1998,
19,845
(
4,961
annual
average)
construction
related
NOTs
and
5,368
(
1,342
annual
average)
MSGP
NOTs
had
been
filed.
13
Note
while
Florida
is
delegated
to
issue
general
permits,
EPA
continues
to
administer
the
stormwater
program.

Applications
ICR
8/
5/
99
47
Assuming
that
these
data
represent
NOTs
submitted
permittees
in
nondelegated
states13
only,
EPA
estimates
that
on
average
25,348
construction
related
NOTs
will
be
filed
annually
while
6,857
MSGP
NOTs
will
be
filed
annually.

With
an
estimated
filing
burden
of
0.5
hours,
EPA
estimates
that
12,674
hours
will
be
incurred
by
construction
general
permittees
filing
NOTs
annually
while
3,428
hours
will
be
incurred
by
MSGP
permittees
filing
NOTs
annually.

Exhibit
18.
Annual
Applicant
Respondent
Burden
INFORMATION
COLLECTION
ACTIVITY
RESPONDENTS
(
PER
YEAR)
BURDEN
HOURS
PER
TASK
BURDEN
(
TOTAL
HOURS)

Recordkeeping:

Existing
POTWs
4,284
1.0
4,284
Existing
Facilities
(
Non­
Municipal)
12,700
1.0
12,700
Major
New
Non­
Municipal
Facilities
40
5.0
200
MS4s
38
5.0
190
Minor
New
Non­
Municipal
Facilities
and
Individual
SW
Permits
520
1.5
779
Sludge
Only
Facilities
(
Municipal)
434
1.5
652
Sludge
Only
Facilities
(
Non­
Municipal)
29
1.5
43
NOI­
Stormwater's
SWPPP
16,350
1.5
24,524
Applicant
Recordkeeping
Subtotal
34,395
43,373
Form
1:

New
Facilities
520
3.0
1,559
Existing
Facilities
12,700
1.0
12,700
Form
2A:

POTWs

1.0
MGD
981
23.3
22,863
POTWs
0.1
­
1.0
MGD
1,651
5.8
9,549
POTWs

0.1
MGD
1,651
4.3
7,098
Sec.
308
Requests
­
Major
Municipals:

Routine
94
5.0
471
Medium
17
50.0
826
Complex
8
1,000.0
8,333
Sec.
308
Requests
­
Minor
Municipals:

Routine
66
5.0
329
Form
2B:
135
6.0
810
INFORMATION
COLLECTION
ACTIVITY
RESPONDENTS
(
PER
YEAR)
BURDEN
HOURS
PER
TASK
BURDEN
(
TOTAL
HOURS)

Applications
ICR
8/
5/
99
48
Form
2C:
8,167
33.0
269,519
Form
2D:

Major
New
Facilities
40
46.0
1,840
Minor
New
Facilities
322
32.0
10,304
Sec.
308
Requests
­
Major
Non­
Municipal:

Routine
65
5.0
323
Medium
34
50.0
1,698
Sec.
308
Requests
­
Minor
Non­
Municipal:

Routine
239
5.0
1,196
Form
2E:

New
Facilities
138
14.0
1,932
Existing
Facilities
4,398
14.0
61,569
Form
2F:
60
28.6
1,705
Form
2S:

NPDES­
POTWs
3,225
9.5
30,742
NPDES­
POTWs
221
9.5
2,109
Sludge
Only­
POTWs
434
2.6
1,142
Sludge
Only­
POTWs
29
2.7
77
NOI­
Stormwater:
16,350
80.5
1,316,137
Alaskan
Lands:
3
30.0
90
MS4s:

Large
19
4,432.4
84,216
Medium
19
2,812.9
53,445
NOI
4,217
1.0
4,217
Petition
for
Individual
Permit:
24
40.0
960
Permit
Consolidation:
100
2.0
200
Notice
of
Construction:
3
1.0
3
Ocean
Discharge:
30
778.0
23,340
NOTs
Construction
25,348
0.5
12,674
MSGP
(
Industrial
­
stormwater)
6,857
0.5
3,428
Applicant
Respondent
Subtotal
88,165
1,947,402
14
Utilizing
1990
US
Census
data,
92.32%
(
i.
e.,
233,114,088/
252,510,216)
of
the
population
resides
in
NPDES
states,
i.
e.,
NPDES
delegated
states.
An
estimated
8.66%(
i.
e.,
21,854,945/
252,510,216)
of
the
population
resides
in
sludge
states,
i.
e.,
sludge
delegated
states.
An
estimated
85.55%(
i.
e.,
216,025,769/
252,510,216
)
of
the
population
resides
in
general
permit
states,
i.
e.,
general
permit
delegated
states.
These
population
percentages
have
been
applied
to
the
respondent
values
to
estimate
those
that
report
directly
to
States.
Note:
while
Florida
is
delegated
to
issue
general
permits,
EPA
continues
to
administer
the
stormwater
program.
The
percentage
for
NOI­
Stormwater
and
NOTs
has
been
adjusted
accordingly.

Applications
ICR
8/
5/
99
49
6(
a)(
ii)
Estimating
State
Respondent
Burden
EPA
estimates
that
the
state
government
will
spend
approximately
47,919
hours
reviewing
application
information
each
year.

Exhibit
19
calculates
the
estimated
burden
to
State
governments
for
handling
and
reviewing
application
information
discussed
in
this
ICR.
Because
most
State
governments
have
authority
for
the
NPDES
programs,
State
governments
will
incur
the
majority
of
the
burden
and
costs.
There
are,
however,
some
exceptions
to
this
rule:
the
federal
government
will
always
process
Form
2D,
Part
1
of
Group
Applications,
Alaskan
Lands
Applications,
and
construction
notifications.
As
a
result,
the
burden
and
costs
for
these
activities
will
belong
to
the
federal
government
exclusively.

Estimates
of
the
burden
do
not
include
analysis
of
the
data,
since
this
activity
is
associated
with
preparation
and
issuance
of
the
permit.
As
Exhibit
19
indicates,
the
burden
ranges
from
0.25
hours
(
for
NOI)
to
88
hours
(
for
Ocean
Discharge
Information).

Exhibit
19.
Annual
State
Respondent
Burden14
Information
Collection
Activity
Respondents
per
year
Respondents
to
State
Burden
Per
Response
Total
State
Burden
Form
1:

New
Facilities
520
480
0.5
240
Existing
Facilities
12,700
11,724
0.5
5,862
Form
2A:

POTWs

1.0
MGD
981
906
2
1,812
POTWs
0.1
­
1.0
MGD
1,651
1,525
2
3,049
POTWs

0.1
MGD
1,651
1,525
2
3,049
Sec.
308
Requests
­
Major
Municipals:

Routine
94
87
1
87
Medium
17
15
10
152
Complex
8
8
20
154
Sec.
308
Requests
­
Minor
Municipals:

Routine
66
61
1
61
Form
2B:
135
125
0.5
62
Form
2C:
8,167
7,540
2
15,080
Information
Collection
Activity
Respondents
per
year
Respondents
to
State
Burden
Per
Response
Total
State
Burden
Applications
ICR
8/
5/
99
50
Form
2D:

Major
New
Facilities
40
0
0.5
0
Minor
New
Facilities
322
0
0.5
0
Sec.
308
Requests
­
Major
Non­
Municipal:

Routine
65
60
1
60
Medium
34
31
10
314
Sec.
308
Requests
­
Minor
Non­
Municipal:

Routine
239
221
1
221
Form
2E:

New
Facilities
138
127
0.5
64
Existing
Facilities
4,398
4,060
0.5
2,030
Form
2F:
60
55
2.2
121
Form
2S:

Part
1
only
424
37
0.67
25
Full
application
3,236
280
1.42
398
NOI­
Stormwater:
16,350
13,150
0.25
3,287
Alaskan
Lands:
3
0
0.6
0
MS4s:

Large
19
18
60
1,052
Medium
19
18
40
702
NOI:
4,217
3,608
0.25
902
Petition
for
Individual
Permit:
24
22
8
177
Permit
Consolidation:
100
92
0.5
46
Notice
of
Construction:
3
0
0.6
0
Ocean
Discharge:
30
28
88
2,437
NOT:

Construction
25,348
20,387
0.25
5,097
MSGP
(
Industrial
­
stormwater)
6,857
5,515
0.25
1,379
Total
State
Burden
87,915
71,701
47,919
6(
a)(
iii)
Total
Respondent
Burden
As
detailed
in
Exhibits
18
and
19,
EPA
estimates
the
total
respondent
burden
to
be
2,038,694
hours.

6(
b)(
i)
Estimating
Applicant
Respondent
Cost
Applications
ICR
8/
5/
99
51
Applicant
respondent
costs
are
a
function
of
labor
costs
and
testing/
contractor
costs.
The
testing/
contractor
costs
are
summarized
in
Exhibit
21.
Exhibit
22
shows
the
estimated
cost
to
applicant
respondents
for
providing
all
information
discussed
in
this
ICR.
Based
on
the
calculations
in
Exhibit
22,
EPA
estimates
that
the
total
annual
cost
to
applicant
respondents
is
approximately
$
62,769,756.20.

Most
calculations
in
the
ICR
account
for
labor
costs
only.
Respondents
will
not
be
required
to
pay
for
capital
equipment
to
respond
to
the
information
requests.
The
ICR
does,
however,
account
for
testing/
contractor
costs
incurred
by
respondents
that
must
collect
additional
data.
Note,
respondents
who
already
have
the
required
effluent
testing
information
on
hand,
either
because
they
monitored
for
the
compounds
during
the
term
of
their
permits
or
because
they
are
already
required
by
the
permitting
authority
to
provide
the
information,
are
not
required
to
retest.
Therefore,
this
ICR
does
not
reflect
costs
for
respondents
with
existing
data.
Assumptions
and
estimates
for
these
O&
M
costs
(
i.
e.,
testing/
contractor
costs)
are
detailed
in
Exhibits
20
and
21.

Exhibit
20a.
Estimate
of
Form
2A
Facilities
That
Currently
Do
Not
Test
Annual
#
of
Respondents
Basic
Conventional
And
Nonconventional
Additional
Conventional
and
Nonconventional
Priority
Pollutants
and
State
WQS
Multiple
Species
Biomonitoring
Facility
Type
%
currently
testing
#
not
testing
%
currently
testing
#
not
testing
%
currently
testing
#
not
testing
%
currently
testing
#
not
testing

0.1
MGD,
no
PP
1,646
60
658
0.1­
1.0
MGD,
no
PP
1,604
80
321
80
321
Minors,
with
PP
53
85
8
85
8
50
26
85
8
Majors,
no
PP
686
85
103
85
103
10
617
75
172
Majors,
with
PP
295
90
30
90
30
70
89
85
44
Total
minors
3,303
987
329
26
8
Total
majors
981
132
132
706
216
Exhibit
20b.
Estimate
of
Form
2S
Facilities
That
Currently
Do
Not
Test
Type
Annual
#
of
Respondents
Round
1
Metals
%
currently
testing
#
not
testing
NPDES
POTWs
3,225
95
161
NPDES
POTWs
221
95
11
15
Assumes
priority
pollutant
scan
testing
would
be
required.

16
Assumes
a
relatively
simple
biomonitoring
test
would
be
required.

17
Adjusted
to
1998
dollars
using
the
employment
cost
index
for
State
and
local
governments
wages
and
salaries
as
reported
by
BLS.

Applications
ICR
8/
5/
99
52
Sludge
Only
POTWs
434
50
217
Sludge
Only
POTWs
29
50
14
Exhibit
21.
Testing/
Contractor
Costs
(
O&
M
Costs)

RESPONDENTS
TESTS/
YEAR
COST
PER
TEST
($)
TOTAL
$

Form
2A
Basic
conventional
and
nonconventional
1,120
3
$
100.00
$
335,880.31
Additional
conventional
and
nonconventional
461
3
$
200.00
$
276,692.62
Priority
Pollutants/
state
WQS
732
3
$
1,150.00
$
2,527,061.71
Multiple
Species
Biomonitoring
224
1
$
8,000.00
$
1,789,836.39
Form
2S
NPDES
and
sludge­
only
facilities
404
1
$
200.00
$
80,800.67
Section
308
Requests
Municipal
(
complex)
15
4
1
$
1,150.00
$
4,791.42
Non­
municipal
(
medium)
16
8
1
$
1,000.00
$
8,490.00
Total
$
5,023,553.13
Note:
For
purposes
of
the
OMB
83­
I
form,
O&
M
costs
are
annualized
over
five
years
(
i.
e.,
over
the
5
year
permit
cycle);
the
annualized
costs
are
$
1,004,710.60.

When
calculating
applicant
respondent
costs,
EPA
makes
the
following
assumptions:

!
The
average
hourly
rate
for
municipal
employees
as
determined
by
the
U.
S.
Department
of
Labor
for
State
employees
in
U.
S.
Department
of
Labor
Employment
Cost
Indexes
and
Levels
1975­
1995,
Bulletin
2466,
October
1995,
page
17,
is
$
26.91
(
including
50
percent
for
overhead
expenditures
($
8.97)
compensation
in
1998
dollars.
17
Applications
ICR
8/
5/
99
53
!
The
average
annual
salary
in
the
private
sector
is
assumed
to
be
14
percent
higher
than
the
federal,
State
and
municipal
salary,
creating
an
average
annual
salary
of
$
40,622.60
and
an
hourly
rate
of
$
19.53.
Overhead
costs
for
the
private
sector
are
assumed
to
be
50
percent,
or
$
9.77
per
hour,
yielding
a
total
hourly
cost
of
$
29.30.

Exhibit
22.
Applicant
Respondent
Costs
Information
Collection
Activity
Burden
(
Total
Hours/
Yr.)
Respondent
Labor
Rate
Respondent
Costs
Recordkeeping:

Existing
POTWS
4,284
26.91
$
115,287.82
Existing
Facilities
(
Non­
Municipal)
12,700
29.30
$
372,048.33
Major
New
Non­
Municipal
Facilities
200
29.30
$
5,859.03
MS4s
190
26.91
$
5,112.90
Minor
New
Non­
Municipal
Facilities
and
Individual
SW
Permits
779
29.30
$
22,832.64
Sludge
Only
Facilities
(
Municipal)
652
26.91
$
17,534.56
Sludge
Only
Facilities
(
Non­
Municipal)
43
29.30
$
1,271.41
NOI­
Stormwater's
SWPPP
24,524
29.30
$
718,442.87
Recordkeeping
Subtotal
43,373
$
1,258,389.55
Form
1:

New
Facilities
1,559
26.91
$
41,947.31
Existing
Facilities
12,700
26.91
$
341,757.00
Form
2A:

POTWs

1.0
MGD
22,863
26.91
$
615,231.14
POTWs
0.1
­
1.0
MGD
9,549
26.91
$
256,971.74
POTWs

0.1
MGD
7,098
26.91
$
191,010.40
Testing/
Contract
Costs
$
4,929,471.04
Sec.
308
Requests
­
Major
Municipals:

Routine
471
26.91
$
12,665.12
Medium
826
26.91
$
22,215.75
Complex
8,333
26.91
$
224,238.55
Testing/
Contractor
Costs
$
4,791.42
Sec.
308
Requests
­
Minor
Municipals:

Routine
329
26.91
$
8,843.86
Form
2B:
810
29.30
$
23,729.07
Form
2C:
269,519
29.30
$
7,895,605.30
Form
2D:

Major
New
Facilities
1,840
29.30
$
53,903.07
Minor
New
Facilities
10,304
29.30
$
301,857.17
Information
Collection
Activity
Burden
(
Total
Hours/
Yr.)
Respondent
Labor
Rate
Respondent
Costs
Applications
ICR
8/
5/
99
54
Sec.
308
Requests
­
Major
Non­
Municipal:

Routine
323
29.30
$
9,451.20
Medium
1,698
29.30
$
49,743.15
Testing/
Contractor
Costs
$
8,490.00
Sec.
308
Requests
­
Minor
Non­
Municipal:

Routine
1,196
29.30
$
35,039.03
Form
2E:

New
Facilities
1,932
29.30
$
56,598.22
Existing
Facilities
61,569
29.30
$
1,803,658.09
Form
2F:
1,705
29.30
$
49,935.33
Form
2S:

NPDES­
POTWs
30,742
26.91
$
827,265.61
NPDES­
POTWs
2,109
26.91
$
56,746.91
Sludge
Only­
POTWs
1,142
26.91
$
30,736.06
Sludge
Only­
POTWs
77
26.91
$
2,066.69
Testing/
Contractor
Costs
$
80,800.67
NOI­
Stormwater:
1,316,137
29.30
$
38,556,433.86
Alaskan
Lands:
90
29.30
$
2,636.56
MS4s:

Large
84,216
26.91
$
2,266,241.80
Medium
53,445
26.91
$
1,438,207.64
NOI:
4,217
29.30
$
123,537.62
Petition
for
Individual
Permit:
960
29.30
$
28,123.34
Permit
Consolidation:
200
29.30
$
5,859.03
Notice
of
Construction:
3
29.30
$
87.89
Ocean
Discharge:
23,340
29.30
$
683,748.67
NOT:

Construction
12,674
29.30
$
371,289.03
MSGP
(
Industrial
­
stormwater)
3,428
29.30
$
100,432.33
Respondent
Subtotal
1,947,402
$
61,511,366.65
Total
1,990,775
$
62,769,756.20
6(
b)(
ii)
Estimating
State
Respondent
Costs
State
respondent
costs
are
a
function
of
labor
costs.
When
calculating
State
respondent
costs,
EPA
assumes
the
average
hourly
rate
for
State
employees
as
determined
by
the
U.
S.
Department
of
Labor
for
18
Adjusted
to
1998
dollars
using
the
employment
cost
index
for
State
and
local
governments
wages
and
salaries
as
reported
by
BLS.

Applications
ICR
8/
5/
99
55
State
employees
in
U.
S.
Department
of
Labor
Employment
Cost
Indexes
and
Levels
1975­
1995,
Bulletin
2466,
October
1995,
page
17,
is
$
26.91
(
including
50
percent
for
overhead
expenditures
($
8.97)
compensation
in
1998
dollars.
18
Cost
for
each
information
collection
activity
are
detailed
in
Exhibit
23.
This
Exhibit
utilizes
the
burden
hours
as
detailed
in
Exhibit
19
and
hourly
rate
of
$
26.91.

Exhibit
23.
Annual
State
Respondent
Costs
Information
Collection
Activity
State
Cost
Form
1:

New
Facilities
$
6,454.20
Existing
Facilities
$
157,752.77
Form
2A:

POTWs

1.0
MGD
$
48,753.07
POTWs
0.1
­
1.0
MGD
$
82,055.66
POTWs

0.1
MGD
$
82,055.66
Sec.
308
Requests
­
Major
Municipals:

Routine
$
2,338.45
Medium
$
4,101.86
Complex
$
4,140.28
Sec.
308
Requests
­
Minor
Municipals:

Routine
$
1,632.91
Form
2B:
$
1,676.90
Form
2C:
$
405,797.26
Form
2D:

Major
New
Facilities
$
0.00
Minor
New
Facilities
$
0.00
Sec.
308
Requests
­
Major
Non­
Municipal:

Routine
$
1,602.97
Medium
$
8,436.67
Sec.
308
Requests
­
Minor
Non­
Municipal:

Routine
$
5,942.78
Form
2E:

New
Facilities
$
1,714.16
Existing
Facilities
$
54,626.55
Information
Collection
Activity
State
Cost
Applications
ICR
8/
5/
99
56
Form
2F:
$
3,257.41
Form
2S:

Part
1
only
$
661.33
Full
application
$
10,702.40
NOI­
Stormwater:
$
88,463.48
Alaskan
Lands:
$
0.00
MS4s:

Large
$
28,320.97
Medium
$
18,880.65
NOI:
$
24,270.79
Petition
for
Individual
Permit:
$
4,769.85
Permit
Consolidation:
$
1,242.15
Notice
of
Construction:
$
0.00
Ocean
Discharge:
$
65,585.40
NOI:

Construction
$
137,152.95
MSGP
(
Industrial
­
stormwater)
$
37,099.37
Total
$
1,289,488.89
6(
b)(
iii)
Total
Respondent
Costs
As
detailed
in
Exhibits
22
and
23,
EPA
estimates
the
total
respondent
cost
to
be
$
64,059,245.10.

6(
c)
Estimating
Agency
Burden
And
Cost
EPA
estimates
that
the
federal
government
will
spend
approximately
10,234
hours
reviewing
application
information
each
year
at
a
cost
of
$
324,215.36.

Exhibit
24
calculates
the
estimated
burden
to
federal
governments
for
handling
and
reviewing
application
information
discussed
in
this
ICR.
Because
most
State
governments
have
authority
for
the
NPDES
programs,
governments
will
incur
the
minority
of
the
burden
and
costs.
There
are,
however,
some
exceptions
to
this
rule:
the
federal
government
will
always
process
Form
2D,
Part
1
of
Group
Applications,
Alaskan
Lands
Applications,
and
construction
notifications.
As
a
result,
the
burden
and
costs
for
these
activities
will
belong
to
the
federal
government
exclusively.

When
estimating
costs,
EPA
assumes
the
average
annual
salary
for
federal
employees
is
$
43,930;
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
$
21.12.
Overhead
cost
for
federal
employees
are
expected
to
be
50
percent,
or
$
10.56
per
hour,
yielding
a
total
hourly
rate
of
$
31.68.
19
Utilizing
1990
US
Census
data,
7.68%
(
i.
e.,
19,396,128/
252,510,216)
of
the
population
resides
in
non­
NPDES
states,
i.
e.,
facilities
under
direct
authority
by
EPA.
An
estimated
91.34%(
i.
e.,
230,655,271/
252,510,216)
of
the
population
resides
in
non­
sludge
states,
i.
e.,
facilities
under
direct
authority
by
EPA.
An
estimated
91.34%(
i.
e.,
230,655,271/
252,510,216
)
of
the
population
resides
in
non­
general
permit
states,
i.
e.,
facilities
under
direct
authority
by
EPA.
These
population
percentages
have
been
applied
to
the
respondent
values
to
estimate
those
that
report
directly
to
EPA.
Note:
while
Florida
is
delegated
to
issue
general
permits,
EPA
continues
to
admister
the
stormwater
program.
The
percentage
for
NOI­
Stormwater
and
NOTs
has
been
adjusted
accordingly.

Applications
ICR
8/
5/
99
57
Exhibit
25
uses
the
burden
estimates
in
Exhibit
24
to
calculate
annual
costs
to
federal
governments.
Estimates
of
the
burden
and
costs
do
not
include
analysis
of
the
data,
since
this
activity
is
associated
with
preparation
and
issuance
of
the
permit.
As
Exhibit
24
indicates,
the
burden
ranges
from
0.25
hours
(
for
Notices
of
Intent)
to
88
hours
(
for
Ocean
Discharge
Information).

Exhibit
24.
Annual
Agency
Burden19
Information
Collection
Activity
Respondents
per
year
Federal
Burden
Burden
Per
Response
Total
Federal
Burden
Form
1:

New
Facilities
520
40
0.5
20
Existing
Facilities
12,700
976
0.5
488
Form
2A:

POTWs

1.0
MGD
981
75
2
151
POTWs
0.1
­
1.0
MGD
1,651
127
2
254
POTWs

0.1
MGD
1,651
127
2
254
Sec.
308
Requests
­
Major
Municipals:

Routine
94
7
1
7
Medium
17
1
10
13
Complex
8
1
20
13
Sec.
308
Requests
­
Minor
Municipals:

Routine
66
5
1
5
Form
2B:
135
10
0.5
5
Form
2C:
8,167
627
2
1,255
Form
2D:

Major
New
Facilities
40
40
0.5
20
Minor
New
Facilities
322
322
0.5
161
Sec.
308
Requests
­
Major
Non­
Municipal:

Routine
65
5
1
5
Medium
34
3
10
26
Sec.
308
Requests
­
Minor
Non­
Municipal:

Routine
239
18
1
18
Information
Collection
Activity
Respondents
per
year
Federal
Burden
Burden
Per
Response
Total
Federal
Burden
Applications
ICR
8/
5/
99
58
Form
2E:

New
Facilities
138
11
0.5
5
Existing
Facilities
4,398
338
0.5
169
Form
2F:
60
5
2.2
10
Form
2S:

Part
1
only
424
387
0.67
259
Full
application
3,236
2,956
1.42
4,197
NOI­
Stormwater:
16,350
3,200
0.25
800
Alaskan
Lands:
3
3
0.6
2
MS4s:

Large
19
1
60
88
Medium
19
1
40
58
NOI:
4,217
609
0.25
152
Petition
for
Individual
Permit:
24
2
8
15
Permit
Consolidation:
100
8
0.5
4
Notice
of
Construction:
3
3
0.6
2
Ocean
Discharge:
30
2
88
203
NOI:

Construction
25,348
4,961
0.25
1,240
MSGP
(
Industrial
­
stormwater)
6,857
1,342
0.25
336
Total
87,915
16,214
10,234
Exhibit
25.
Annual
Agency
Costs
INFORMATION
COLLECTION
ACTIVITY
FEDERAL
COST
Form
1:

New
Facilities
$
632.21
Existing
Facilities
$
15,452.37
Form
2A:

POTWs

1.0
MGD
$
4,775.51
POTWs
0.1
­
1.0
MGD
$
8,037.60
POTWs

0.1
MGD
$
8,037.60
Sec.
308
Requests
­
Major
Municipals:

Routine
$
229.06
Medium
$
401.79
INFORMATION
COLLECTION
ACTIVITY
FEDERAL
COST
Applications
ICR
8/
5/
99
59
Complex
$
405.55
Sec.
308
Requests
­
Minor
Municipals:

Routine
$
159.95
Form
2B:
$
164.26
Form
2C:
$
39,749.08
Form
2D:

Major
New
Facilities
$
633.60
Minor
New
Facilities
$
5,100.48
Sec.
308
Requests
­
Major
Non­
Municipal:

Routine
$
157.02
Medium
$
826.40
Sec.
308
Requests
­
Minor
Non­
Municipal:

Routine
$
582.11
Form
2E:

New
Facilities
$
167.91
Existing
Facilities
$
5,350.84
Form
2F:
$
319.07
Form
2S:

Part
1
only
$
8,216.85
Full
application
$
132,973.92
NOI­
Stormwater:
$
25,344.00
Alaskan
Lands:
$
57.02
MS4s:

Large
$
2,774.13
Medium
$
1,849.42
NOI:
$
4,825.67
Petition
for
Individual
Permit:
$
467.22
Permit
Consolidation:
$
121.67
Notice
of
Construction:
$
57.02
Ocean
Discharge:
$
6,424.29
NOI:

Construction
$
39,293.10
MSGP
(
Industrial
­
stormwater)
$
10,628.64
Total
$
324,215.36
6(
d)
Total
Burden
Hours
And
Costs,
Master
Tables
Applications
ICR
8/
5/
99
60
Exhibit
26
presents
the
figures
for
total
annual
burden
and
costs
to
respondents
and
Agency.
It
summarizes
burden
and
cost
calculations
in
Exhibits
18,
19,
20,
22,
23,
24,
and
25.

EPA
does
not
anticipate
the
annual
respondent
burden
and
cost
will
not
vary
significantly
(
more
than
25
percent)
over
the
next
three
years.
Therefore,
this
ICR
does
not
include
a
separate
master
table
for
any
of
the
years
in
particular.

Exhibit
26.
Total
Annual
Burden
for
Respondents
and
Agency
Annual
Burden
(
Hours)
Annual
Costs*

Applicant
Respondents
1,990,775
$
62,769,756.20
State
Government
Respondents
47,919
$
1,289,488.89
Federal
Agency
10,234
$
324,215.36
Totals
2,048,927
$
64,383,460.46
*
Annual
O&
M
costs
are
$
1,004,710.60
(
see
Exhibit
21).
Note:
On
the
OMB
83­
I
form,
the
total
number
of
respondents
is
88,209
(
88,165
applicants
+
43
states
and
1
territory
with
NPDES
permit
program
authority).

6(
e)
Reasons
for
Change
in
Burden
Exhibits
27
and
28
present
the
change
in
the
respondent
burden
for
each
information
item
covered
by
this
ICR.
(
Note
­
Previous
burden
estimates
are
drawn
from
the
previous
applications
ICR
and
National
Pollutant
Elimination
System
Permit
Application
Requirements
 
Form
2A
and
2S
(
Final
Rule)
(
OMB
Control
No.
2040­
0086,
ICR
No.
0226.14,
approved
January
13,
1999).)
As
shown
in
the
following
tables,
this
ICR
estimates
an
increase
in
applicant
respondent
burden
from
520,736
to
1,990,775
which
represents
a
282.3%
increase
in
applicant
respondent
burden.
Similarly,
the
state
respondent
burden
has
increased
from
38,193
to
47,919
which
represents
a
25.5%
increase
in
state
respondent
burden.
The
significant
increase
in
applicant
respondent
burden
is
primarily
due
to
estimating
the
burden
associated
with
SWPPPs.
Exhibit
29
explains
substantial
changes
in
annual
applicant
respondent
burden
by
information
item.

Exhibit
27.
Change
in
Applicant
Respondent
Burden
Information
Collection
Activity
Burden
Current
ICR
Burden
Previous
ICR
Change
(
hours)
Type
of
Change
Recordkeeping:

Existing
Facilities
16,984
14,640
2,344
Adjustment
Major
New
Non­
Municipal
Facilities
200
200
0
­

MS4s
190
55
135
Adjustment
Minor
New
Non­
Municipal
Facilities
and
Individual
SW
Permits
779
780
(
1)
Adjustment
Sludge
Only
Facilities
(
Municipal)
652
585
67
Adjustment
Sludge
Only
Facilities
(
Non­
Municipal)
43
60
(
17)
Adjustment
Information
Collection
Activity
Burden
Current
ICR
Burden
Previous
ICR
Change
(
hours)
Type
of
Change
20
The
SWPPP
is
not
a
new
requirement;
this
ICR
estimates
the
burden
associated
with
it.

21
See
explanation
provided
in
Exhibit
29.

Applications
ICR
8/
5/
99
61
NOI­
Stormwater
SWPPP
24,524
­
20
24,524
Adjustment19
Applicant
Recordkeeping
Subtotal:
43,373
16,320
27,053
Form
1:
14,259
26,921
(
12,662)
Adjustment
Form
2A:

POTWs

1.0
MGD
22,863
17,022
5,841
Adjustment
POTWs
0.1
­
1.0
MGD
9,549
7,452
2,097
Adjustment
POTWS

0.1
MGD
7,098
5,324
1,774
Adjustment
Sec.
308
Requests
­
Major
Municipals:
9,629
515
9,114
Adjustment
Sec.
308
Requests
­
Minor
Municipals:
329
280
49
Adjustment
Form
2B:
810
3,570
(
2,760)
Adjustment
Form
2C:
269,519
232,188
37,331
Adjustment
Form
2D:

Major
New
Facilities
1,840
1,840
0
­

Minor
New
Facilities
10,304
10,304
0
­

Sec.
308
Requests
­
Major
Non­
Municipal:
2,021
2,535
(
514)
Adjustment
Sec.
308
Requests
­
Minor
Non­
Municipal:
1,196
2,710
(
1,514)
Adjustment
Form
2E:
63,501
54,978
8,523
Adjustment
Form
2F:
1,705
1,716
(
11)
Adjustment
Form
2S:

POTWs
31,884
30,509
1,375
Adjustment
POTWs
2,186
2,119
67
Adjustment
NOI­
Stormwater
and
NOI:
20
1,320,354
42,420
21
1,277,934
Adjustment19,
20
Alaskan
Lands:
90
90
0
­

MS4s:

Large
84,216
17,730
66,486
Adjustment
Medium
53,445
19,690
33,755
Adjustment
Petition
for
Individual
Permit:
960
960
0
­

Permit
Consolidation:
200
200
0
­

Notice
of
Construction:
3
3
0
­

Ocean
Discharge:
23,340
23,340
0
­

NOT:
Information
Collection
Activity
Burden
Current
ICR
Burden
Previous
ICR
Change
(
hours)
Type
of
Change
22
Not
estimated
in
the
previous
ICR.
In
1997,
the
construction
general
permit
required
NOTs
be
submitted
where
applicable.
MSGPs'
NOTs
are
optional
(
see
60
FR
51122,
IX.
Termination
of
Coverage).

23
The
previous
2A/
2S
ICR
estimated
a
combined
State
and
Agency
burden.
As
such,
this
table
details
State
burden
as
specified
in
the
1995
applications
ICR
for
Standard
Form
A,
Short
Form
A,
Section
308
Requests,
and
Interim
Sewage
Sludge
Permit
Application
Form.

Applications
ICR
8/
5/
99
62
Construction
12,674
022
12,674
Program
22
MSGP
(
Industrial
­
stormwater)
3,428
022
3,428
Program
22
Applicant
Respondent
Subtotal:
1,947,402
504,416
1,442,986
Applicant
Respondent
Total:
1,990,775
520,736
1,470,039
Exhibit
28.
Change
in
State
Respondent
Burden
Information
Collection
Activity
Burden
Current
ICR
Burden
Previous
ICR
Change
(
hours)
Type
of
Change
Form
1:
6,102
5,625
477
Adjustment
Form
2A:
23
7,910
1,322
6,588
Adjustment
Sec.
308
Requests
­
Municipals:
454
2,346
(
1,892)
Adjustment
Form
2B:
62
223
(
161)
Adjustment
Form
2C:
15,080
9,544
5,536
Adjustment
Form
2D:
0
0
0
­

Sec.
308
Requests
­
Non­
Municipal:
594
787
(
193)
Adjustment
Form
2E:
2,094
1,309
785
Adjustment
Form
2F:
121
112
9
Adjustment
Form
2S:
23
422
5,351
(
4,929)
­

NOI­
Stormwater
and
NOI:
4,189
8,980
(
4,791)
Adjustment
Alaskan
Lands:
0
0
0
­

MS4s:
1,754
380
1,374
Adjustment
Petition
for
Individual
Permit:
177
152
25
Adjustment
Permit
Consolidation:
46
38
8
Adjustment
Notice
of
Construction:
0
0
0
­

Ocean
Discharge:
2,437
2,024
413
Adjustment
NOT:
Information
Collection
Activity
Burden
Current
ICR
Burden
Previous
ICR
Change
(
hours)
Type
of
Change
24
Not
estimated
in
the
previous
ICR.
In
1997,
the
construction
general
permit
required
NOTs
be
submitted
where
applicable.
MSGPs'
NOTs
are
optional
(
see
60
FR
51122,
IX.
Termination
of
Coverage).

Applications
ICR
8/
5/
99
63
Construction
5,097
024
5,097
Program24
MSGP
(
Industrial
­
stormwater)
1,379
024
1,379
Program
24
State
Respondent
Total:
47,918
38,193
9,725
Applications
ICR
8/
5/
99
64
Exhibit
29.
Explanations
for
Substantial
Changes
in
Applicant
Respondent
Burden
Item/
Type
of
Applicant
Respondent
Source
Explanation
Recordkeeping
Existing
Facilities
Applications
ICR
There
has
been
an
increase
in
the
number
of
respondents
reapplying
NOI­
Stormwater's
SWPPP
Applications
ICR
The
previous
ICR
did
not
estimate
the
recordkeeping
burden
associated
with
a
SWPPP.

Form
1
Applications
ICR/
PCS
The
previous
ICR
over­
estimated
(
significantly)
the
number
of
facilities
requesting
an
individual
stormwater
permit.

Form
2A
Applications
ICR/
PCS
There
has
been
an
increase
in
the
number
of
respondents.

Additional
NPDES
Application
Requirements
for
Municipal
Dischargers
(
Section
308
Requests)
Applications
ICR/
PCS
This
ICR
assumes
some
complex
requests
will
be
made.

Form
2B
Applications
ICR/
PCS
There
has
been
an
estimated
decrease
in
the
number
of
respondents.

Form
2C
Applications
ICR/
PCS
There
has
been
an
estimated
increase
in
the
number
of
respondents.

Additional
NPDES
Application
Requirements
for
Non­
Municipal
Dischargers
(
Section
308
Requests)
Applications
ICR
There
has
been
a
estimated
decrease
in
the
number
of
respondents.

Form
2E
Applications
ICR/
PCS
There
has
been
an
estimated
increase
in
number
of
respondents.

Form
2S
Applications
ICR/
Form
2A/
2S
ICR
The
estimate
of
the
number
of
respondents
is
now
more
accurate.

NOI­
Stormwater
and
NOI
Applications
ICR
The
large
increase
is
due
to
estimating
the
burden
associated
with
developing
a
SWPPP.
Note­
the
previous
ICR
also
included
burden
estimates
for
the
construction
NOI
and
baseline
general
permit
for
stormwater
discharges
from
industrial
activities
NOI.
The
construction
NOI
is
now
covered
under
a
separate
ICR
(
OMB
Control
No.
2040­
0188)
while
the
latter
NOI
no
longer
exists.

Application
for
Large
and
Medium
MS4s
Applications
ICR
An
increase
in
the
number
of
respondents
reapplying
are
anticipated
during
the
life
of
this
ICR
Applications
ICR
8/
5/
99
65
6(
f)
Burden
Statement
The
public
reporting
burden
for
collecting
information
is
estimated
to
be
an
average
of
22.1
hours
per
respondent.
This
estimate
includes
the
time
required
to
review
the
instructions,
search
existing
data
sources,
gather
and
maintain
all
necessary
data,
and
complete
and
review
the
information
collection.
The
public
recordkeeping
burden
is
estimated
to
be
an
average
of
1.3
hours
per
respondent.

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

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Director,
OP
Regulatory
Information
Division,
U.
S.
Environmental
Protection
Agency
(
2137),
401
M
St.,
S.
W.,
Washington
D.
C.
20460;
and
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.
Include
the
EPA
ICR
number
and
OMB
control
number
in
any
correspondence.
25
Note
while
Florida
is
delegated
to
issue
general
permits,
EPA
continues
to
administer
the
stormwater
program.

Applications
ICR
8/
5/
99
66
Appendix
a:
1990
Census
Data
and
State
Delegation
of
NPDES,
Sludge,
and
General
Permit
Programs
State
1990
Population
NPDES
Delegation
General
Permit
Delegation
Sludge
Delegation
Alabama
4,040,587


Alaska
550,043
Arizona
3,665,228
Arkansas
2,350,725


California
29,760,021


CNMI
43,345
Colorado
3,294,394


Connecticut
3,287,116


Delaware
666,168


District
of
Columbia
606,900
Florida
12,937,926


25
Georgia
6,478,216


Guam
133,152
Hawaii
1,108,229


Idaho
1,006,749
Illinois
11,430,602


Indiana
5,544,159


Iowa
2,776,755


Kansas
2,477,574


Kentucky
3,685,296


Louisiana
4,219,973


Maine
1,227,928
Maryland
4,781,468


Massachusetts
6,016,425
Michigan
9,295,297


Minnesota
4,375,099


Mississippi
2,573,216


Missouri
5,117,073


Montana
799,065


Nebraska
1,578,385


Nevada
1,201,833


New
Hampshire
1,109,252
New
Jersey
7,730,188


New
Mexico
1,515,069
New
York
17,990,455


North
Carolina
6,628,637


North
Dakota
638,800


Ohio
10,847,115


Oklahoma
3,145,585



Oregon
2,842,321


Pennsylvania
11,881,643


Puerto
Rico
3,522,037
Rhode
Island
1,003,464


South
Carolina
3,486,703


South
Dakota
696,004


Tennessee
4,877,185


Texas
16,986,510


Utah
1,722,850



Vermont
562,758


Virginia
6,187,358


Virgin
Islands
101,809

Washington
4,866,692


West
Virginia
1,793,477


Wisconsin
4,891,769


Wyoming
453,588


Applications
ICR
8/
5/
99
67
Total
252,510,216
233,114,088
216,025,769
21,854,945
