INFORMATION
COLLECTION
REQUEST
FOR
THE
NATIONAL
POLLUTANT
DISCHARGE
ELIMINATION
SYSTEM
(
NPDES)/
COMPLIANCE
ASSESSMENT/
CERTIFICATION
INFORMATION
EPA
ICR
No.
1427.06
OMB
Control
No.
2040­
0110
DRAFT
July
7,
2000
Prepared
for
U.
S.
Environmental
Protection
Agency
Office
of
Wastewater
Management
401
M
Street,
S.
W.
Washington,
D.
C.
20460
Prepared
by
Science
Applications
International
Corporation
11251
Roger
Bacon
Drive
Reston,
Virginia
20190
EPA
Contract
No.
68­
C4­
0034
Work
Assignment
No.
IM­
5­
2
SAIC
Project
No.
01­
0833­
08­
2994­
003
Compliance
Assessment
ICR
Page
ii
July
7,
2000
TABLE
OF
CONTENTS
1.0
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
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1
1.
a
Title
of
the
Information
Collection
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1
1.
b
Short
Characterization/
Abstract
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1
2.0
NEED
FOR
AND
USE
OF
THE
COLLECTION
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3
2.
a
Need
and
Authority
for
the
Collection
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3
2.
a.
1
NPDES
Program
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3
2.
a.
2
Storm
Water
Program
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4
2.
a.
3
Sewage
Sludge
Program
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5
2.
a.
4
Effluent
Limitations
Guidelines
and
Standards
Certifications
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5
2.
b
Practical
Utility
of
the
Data
and
Users
of
the
Data
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6
3.0
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
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3.
a
Nonduplication
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8
3.
b
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
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8
3.
c
Consultations
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8
3.
d
Effects
of
Less
Frequent
Data
Collection
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9
3.
e
General
Guidelines
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9
3.
f
Confidentiality
and
Sensitive
Questions
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10
4.0
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
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11
4.
a
Respondents
and
SIC
Codes
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11
4.
b
Information
Requested
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11
4.
c
Respondent
Activities
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13
5.0
THE
INFORMATION
COLLECTED:
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
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15
5.
a
Agency
Activities
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15
5.
b
Collection
Methodology
and
Management
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15
5.
c
Small
Entity
Flexibility
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15
5.
d
Collection
Schedule
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16
5.
d.
1
Information
Collection
Activities
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16
5.
d.
2
Information
Collection
Schedule
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16
6.0
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
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18
6.
a
Estimating
Respondent
Burden
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18
6.
a.
1
Recordkeeping
of
Monitoring
and
Inspection
Data
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25
6.
a.
2
Compliance
Schedule
Reports
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26
6.
a.
3
Noncompliance
Reports
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26
6.
a.
4
Notice
of
Alternate
Level
of
Actual
Production
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29
6.
a.
5
Section
308(
a)
Letters
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29
Compliance
Assessment
ICR
Page
iii
July
7,
2000
6.
a.
6
Certification
for
Exemption
From
Monitoring
and
Notification
of
Process
Changes
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30
6.
a.
7
SSO
and
Unpermitted
CSO
Reporting
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31
6.
b
Estimating
Respondent
Costs
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32
6.
c
Estimating
Agency
Burden
and
Cost
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34
6.
c.
1
Recordkeeping
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34
6.
c.
2
Compliance
Schedule
Reports
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34
6.
c.
2
Compliance
Schedule
Reports
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41
6.
c.
3
Noncompliance
Reports
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42
6.
c.
4
Notice
of
Alternative
Level
of
Actual
Production
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43
6.
c.
5
Section
308(
a)
Letters
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44
6.
c.
6
Certification
for
Exemption
From
Monitoring
and
Notification
of
Process
Changes
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44
6.
c.
7
SSO
and
Unpermitted
CSO
Reporting
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45
6.
d
Estimating
the
Respondent
Universe
and
Burden
Hours
and
Costs
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45
6.
e
Bottom
Line
Burden
Hours
and
Costs
to
Respondents
and
Government
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45
6.
f
Reasons
for
Change
in
Burden
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46
6.
g
Burden
Statement
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47
LIST
OF
EXHIBITS
Exhibit
1.
Summary
of
Burden
and
Costs
to
Respondents
and
State
Government
.
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2
Exhibit
2.
Number
of
NPDES
Permits
Issued
by
EPA
and
the
States
.
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19
Exhibit
3.
Annual
Respondent
Reporting
and
Recordkeeping
Burden
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21
Exhibit
4.
Annual
Average
Responses
per
Respondent
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23
Exhibit
5.
Respondent
Reporting
Burden
for
Noncompliance
Reports
.
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29
Exhibit
6.
Facilities
with
Certification
Potential
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30
Exhibit
7.
Annual
Respondent
Recordkeeping
and
Reporting
Cost
.
.
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36
Exhibit
8.
Annual
Burden
to
State
and
Federal
Governments
as
Users
of
Data
.
.
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.
38
Exhibit
9.
Annual
Costs
to
State
and
Federal
Governments
as
Users
of
Data
.
.
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.
40
Exhibit
10.
State
and
Federal
Burden
for
Noncompliance
Reports
.
.
.
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44
Exhibit
11.
Respondent
Universe
and
Burden
and
Costs
.
.
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.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.45
Exhibit
12.
Bottom
Line
Burdent
Hours
and
Costs
to
Respondents
and
Government
.
.
.
.
.
.
.
.
.45
Exhibit
13.
Change
in
Annual
Respondent
and
State
Burden
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
46
Compliance
Assessment
ICR
Page
1
July
7,
2000
1.0
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1.
a
Title
of
the
Information
Collection
ICR:
National
Pollutant
Discharge
Elimination
System
(
NPDES)/
Compliance
Assessment/
Certification
Information.

OMB
Control
No.:
2040­
0110.

1.
b
Short
Characterization/
Abstract
This
Information
Collection
Request
(
ICR)
is
entitled
Information
Collection
Request
for
NPDES/
Compliance
Assessment/
Certification
Information
and
its
purpose
is
to
calculate
the
burden
and
costs
associated
with
the
data
requirements
necessary
for
a
permitting
authority
(
either
an
authorized
State
or
EPA)
to
determine
whether
an
existing
National
Pollutant
Discharge
Elimination
System
(
NPDES)
or
sewage
sludge
permittee
is
in
compliance
with
the
conditions
of
its
permit.
This
ICR
updates
the
1996
ICR
entitled
Information
Collection
Request
for
the
National
Pollutant
Discharge
Elimination
System
(
NPDES)/
Compliance
Assessment/
Certification
Information
(
OMB
Control
No.
2040­
0110,
ICR
No.
1427.05).
This
ICR
also
incorporates
a
revised
burden
estimate
approved
by
OMB
on
March
24,
1998
and
developed
to
adjust
the
ICR
to
more
accurately
reflect
sanitary
sewer
overflow
(
SSO)
reporting
and
unpermitted
combined
sewer
overflow
(
CSO)
reporting
requirements.

This
ICR
was
prepared
according
to
the
guidance
contained
in
the
Office
of
Policy's
(
OP)
February
1999
ICR
Handbook.
This
handbook
is
the
Agency's
most
current
guidance
document
for
preparing
an
ICR
and
follows
the
provisions
of
the
Paperwork
Reduction
Act
of
1995
and
the
Office
of
Management
and
Budget
(
OMB)
guidelines.

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

CWA
Section
402(
b)
allows
States
(
including
territories)
to
acquire
authority
for
the
NPDES
and
Sewage
Sludge
Management
programs.
In
addition,
Section
518(
e)
authorizes
Indian
Tribes
to
be
treated
in
the
same
manner
as
States
and
to
obtain
NPDES
authority.
This
authority
enables
States
and
Tribes
to
issue
permits.
At
this
time,
44
States
(
43
States
and
1
U.
S.
territory)
have
obtained
NPDES
authority,
and
13
have
not.
None
of
the
556
Federally
Recognized
American
Indian
Tribes
have
obtained
NPDES
authority.
As
of
February
2000,
three
States
have
obtained
authority
to
operate
a
sewage
sludge
management
program.
In
States
or
Tribes
that
have
not
obtained
authority
for
these
programs,
EPA
issues
permits.
Because
some
Compliance
Assessment
ICR
Page
2
July
7,
2000
permit
applications
are
processed
by
States
and
some
by
EPA,
this
ICR
calculates
government
burden
and
costs
for
both
States
and
EPA.

Information
that
is
necessary
for
a
permitting
authority
to
determine
a
permittee's
compliance
with
its
permit
is
collected
during
the
effective
term
of
the
permit.
Compliance
assessment
reporting
requirements
include
routine
submittals,
for
example
annual
certifications
and
reports
submitted
when
a
compliance
schedule
milestone
is
reached
and
non­
routine
submittals,
which
are
required
when
certain
conditions
occur
(
e.
g.,
an
unanticipated
bypass).
In
addition,
permit
writers
may
use
this
information
to
determine
if
follow­
up
activities
are
necessary.

Exhibit
1
provides
a
summary
of
the
burden
and
costs
to
respondents
and
State
government
associated
with
the
compliance
assessment
recordkeeping
and
reporting
requirement
of
this
ICR.

This
ICR
includes
burden
hours
and
costs
provided
in
the
1998
Summary
of
Revised
Burden
Estimates
for
SSO/
Unpermitted
CSO
reporting,
but
does
not
reflect
the
number
of
responses,
responses
per
respondent,
or
response
time
per
respondent
for
these
SSO
and
CSO
events.
In
addition,
this
ICR
reflects
an
increased
number
of
general
permittees
covered
by
this
ICR
and
required
to
keep
records
for
the
first
time
since
the
previous
ICR.
Recordkeeping
Number
of
Recordkeepers
217,478
All
permittees
except
sludge
facilities.

Annual
Respondent
Burden
(
hrs.)
827,968
Recordkeeping
Time
(
hrs.)
per
Recordkeeper
3.81
Annual
Costs
($)
19,161,763
Reporting
Number
of
Respondents
16,532
Number
of
Responses
35,509
Number
of
Responses
per
Respondent
2.15
Annual
Respondent
Burden
(
hrs.)
147,207
Response
Time
(
hrs.)
per
Response
4.15
Annual
Costs
($)
3,884,689
Total
Annual
Burden
for
Respondents
(
hrs.)
975,175
Total
Annual
Costs
for
Respondents
($)
23,046,452
State
Governments
Annual
Burden
(
hrs.)
51,089
Annual
Costs
($)
1,472,488
Exhibit
1.
Summary
of
Burden
and
Costs
to
Respondents
and
State
Government
Compliance
Assessment
ICR
Page
3
July
7,
2000
2.0
NEED
FOR
AND
USE
OF
THE
COLLECTION
2.
a
Need
and
Authority
for
the
Collection
2.
a.
1
NPDES
Program
Section
402(
a)
of
the
CWA
establishes
the
NPDES
program,
which
requires
issuance
of
a
permit
to
control
the
discharge
of
pollutants,
ensuring
compliance
with
provisions
of
the
CWA.
Section
402(
p)
of
the
CWA
requires
that
these
NPDES
permits
be
issued
for
fixed
terms
not
to
exceed
5
years
and
that
they:

!
Contain
and
ensure
compliance
with
discharge
limitations
based
on
effluent
guidelines
or
water
quality
standards;

!
Provide
for
permit
termination
or
modification
for
cause;

!
Require
discharge
monitoring
and
reporting
to
assess
compliance
with
permit
conditions
or
to
assist
in
development
of
effluent
limitations;
and
!
Require
other
reports
as
necessary
in
order
for
the
permitting
authority
to
ensure
compliance
with
the
objectives
of
the
Act.

The
NPDES
program
procedures
and
requirements
are
established
in
40
Code
of
Federal
Regulations
(
CFR)
Parts
122,
123,
124,
and
125.

Once
the
NPDES
or
sewage
sludge
permit
is
issued,
a
permittee
is
subject
to
certain
conditions
for
the
term
of
the
permit.
Permit
conditions
are
established
in
40
CFR
Part
122
for
NPDES
permits
and
Part
501
for
sewage
sludge
permits.
These
include:

!
Specific
effluent
limitations,
standards,
and/
or
prohibitions
[
§
122.44];

!
Compliance
schedules
which
may
specify
milestones
for
installing
wastewater
treatment
equipment
and
processes
[
§
122.41(
e)(
5)];

!
Monitoring
and
reporting
requirements
[
§
122.41(
j)
and
(
l)];

!
Inspection
and
record
keeping
requirements
[
§
122.44(
i)(
4)(
i)
and
(
ii)];
and
!
Provisions
concerning
events
including
bypass
and
upset
of
treatment
facilities.
Bypass
is
prohibited
in
most
instances
and
upset
can
only
be
used
as
an
affirmative
defense
for
the
permittee
under
specified
conditions
[
§
122.41(
m)
and
(
n)].

The
permitting
authority
must
assess
whether
the
permittee
is
in
compliance
with
these
conditions
on
a
consistent
basis.
Permittee
compliance
is
assessed
through
compliance
inspections,
review
of
Compliance
Assessment
ICR
Page
4
July
7,
2000
permittee
self­
monitoring
data,
keeping
of
records,
and
review
of
other
compliance
assessment
information
required
by
40
CFR
Parts
122
and
501.
The
burden
for
compliance
inspections
is
estimated
in
the
National
Pollutant
Discharge
Elimination
System
(
NPDES)
and
Sewage
Sludge
Management
State
Program
Requirements
ICR
(
OMB
No.
2040­
0057);
and
the
burden
for
the
collection
and
retention
of
permittee
self­
monitoring
data
is
calculated
in
the
NPDES/
Sewage
Sludge
Monitoring
Reports
ICR
(
OMB
No.
2040­
0004).
The
burden
associated
with
sewage
sludge
self­
monitoring
is
estimated
in
the
same
ICR
(
OMB
No.
2040­
0004),
as
amended.
This
ICR
calculates
the
burden
associated
with
compliance
assessment
information
other
than
discharge
monitoring
reports
(
DMRs)
required
by
Parts
122
and
501,
and
certification
or
alternative
requirements
contained
in
the
effluent
limitations
guidelines
and
standards
(
ELGs)
regulations
for
11
point
source
categories
and
1
subcategory.

The
information
that
is
collected
can
lead
the
permitting
authority
to
follow
through
with
one
or
more
of
the
following
actions:
informal
discussions
with
the
permittee
by
telephone
or
letter,
permit
modification,
or
enforcement
action.

The
most
common
way
in
which
a
permittee
informs
the
permitting
authority
about
its
discharge
is
by
using
the
DMR.
The
DMR
lists
all
of
the
results
from
the
permittee's
selfmonitoring
of
required
pollutants.
The
permitting
authority
reviews
this
information
and
compares
it
with
permit
limits
to
determine
compliance
and/
or
the
need
to
develop
additional
limits.
In
addition
to
the
DMR,
permittees
may
be
required
to
submit
reports
on
violations
of
maximum
daily
discharge
limitations
as
specifically
required
in
a
permit.
This
latter
reporting
requirement
is
intended
to
alert
the
permitting
authority
of
potential
health
or
environmental
risks
that
could
require
a
timely
response.
The
data
collected
by
this
requirement
are
more
incident­
specific
than
the
summary
information
provided
on
the
DMR.

2.
a.
2
Storm
Water
Program
In
addition,
in
the
1987
amendments
to
the
CWA,
Congress
established
a
program
to
control
storm
water
discharges
associated
with
industrial
activity.
Permit
compliance
for
storm
water
permittees
with
discharges
associated
with
industrial
activity
is
assessed
on
a
case­
by­
case
basis.
Under
§
122.44(
i)(
4)(
i)
and
(
ii),
the
minimum
compliance
requirement
for
a
storm
water
permittee
with
discharges
associated
with
industrial
activity
is
an
annual
site
inspection
performed
by
the
permittee
that
identifies
any
incidents
of
non­
compliance
and
evaluates
whether
measures
to
reduce
pollutant
loadings
identified
in
the
storm
water
pollution
prevention
plan
are
adequate
and
being
properly
implemented.
Although
the
permittees
are
not
required
to
report
the
inspection
information,
they
are
required
to
retain
records
of
the
inspection
for
at
least
3
years.
All
storm
water
general
permittees
(
industrial
and
construction)
are
required
to
fulfill
this
minimum
requirement.
It
should
be
noted
that
the
numbers
reflected
in
this
ICR
for
general
permits
refer
to
the
individual
notices
of
intent
(
NOIs).
That
is,
it
reflects
the
number
of
permittees
regulated
via
a
general
permit,
not
the
number
of
different
general
permits.

In
addition,
storm
water
permittees
with
discharges
associated
with
industrial
activity
are
required
to
perform
a
periodic
visual
examination
of
their
facilities
and
maintain
records
of
the
Compliance
Assessment
ICR
Page
5
July
7,
2000
visual
examination.
Twenty­
nine
of
the
thirty
industrial
facility
categories
are
required
to
perform
this
visual
examination
on
a
quarterly
basis.

A
portion
of
all
storm
water
general
permittees
may
also
be
required
to
maintain
records
of
monitoring
data.
EPA
estimates
that
approximately
49.5
percent
of
the
storm
water
general
permittees
will
be
required
to
maintain
monitoring
records
in
addition
to
their
annual
site
inspection
recordkeeping
requirements
and
their
visual
examination
requirements.

This
NPDES/
Compliance
Assessment/
Certification
Information
ICR
fully
integrates
the
above
storm
water
requirements
previously
reported
in
the
1996
NPDES/
Compliance
Assessment/
Certification
Information
ICR
and
the
revisions
to
the
NPDES
Storm
Water
Implementation
Requirements
(
modification
of
OMB
No.
2040­
0004).

2.
a.
3
Sewage
Sludge
Program
Section
405
of
the
CWA
requires
EPA
to
regulate
the
use
and
disposal
of
sludge
produced
by
publicly
owned
treatment
works
(
POTWs)
and
other
treatment
works
treating
domestic
sewage.
The
CWA
also
requires
the
development
of
technical
criteria
for
the
control
of
sewage
sludge
disposal
and
use.
EPA
has
promulgated
sewage
sludge
use
or
disposal
standards
at
40
CFR
Part
503.
The
CWA
also
requires
that
any
NPDES
permit
issued
to
a
POTW
or
other
treatment
works
treating
domestic
sewage,
incorporate
appropriate
sludge
controls
in
order
to
protect
public
health
and
the
environment.
As
a
result
of
this
requirement,
permit
conditions
regarding
sewage
sludge
are
included
in
POTW
permits
in
cases
where
sewage
sludge
disposal
is
of
concern.
In
addition,
EPA
issued
a
final
rule
under
40
CFR
Part
501
concerning
State
sewage
sludge
management
program
requirements,
for
which
a
modification
ICR
was
developed
and
approved
by
OMB
in
1989.
Sewage
sludge
permits
include
standards
for
the
use
or
disposal
of
sewage
sludge.
These
may
include
pollutant
limitations,
monitoring
requirements,
and
compliance
schedules.
The
compliance
assessment
requirements
for
sewage
sludge
permits,
like
those
for
NPDES
permits,
allow
the
permitting
authority
to
assess
permit
compliance.
The
burden
for
the
compliance
assessment
components
for
sewage
sludge
requirements
have
since
been
incorporated
into
this
NPDES/
Compliance
Assessment/
Certification
Information
ICR.

2.
a.
4
Effluent
Limitations
Guidelines
and
Standards
Certifications
Effluent
limitations
guidelines
and
standards
are
national
wastewater
limitations
that
apply
to
specific
categories
of
industrial
dischargers.
The
regulations
are
promulgated
by
EPA
under
the
authority
of
sections
301,
304,
306,
and
307
of
the
CWA.
The
limitations
are
implemented
in
direct
discharge
permits
under
the
NPDES
program
by
States
and
EPA.
This
NPDES/
Compliance
Assessment/
Certification
Information
ICR
also
fully
integrates
certifications
for
exemptions
of
monitoring
requirements
for
11
industrial
categories
and
1
subcategory:
electroplating
(
40
CFR
413);
metal
finishing
(
40
CFR
433);
electrical
and
electronic
components
(
40
CFR
469);
pesticides
formulating,
packaging,
and
repackaging
(
40
CFR
455);
aluminum
forming
(
40
CFR
Part
467);
coil
coating
(
40
CFR
465);
can
making
(
a
subpart
of
the
coil
coating
category)
(
40
CFR
465);
pharmaceutical
manufacturing
(
40
CFR
439);
pulp
and
paper
(
40
FR
430);
builders'
paper
and
board
mills
(
40
CFR
431);
porcelain
Compliance
Assessment
ICR
Page
6
July
7,
2000
enameling
(
40
CFR
456);
and
steam
electric
(
40
CFR
423).
The
effluent
limitations
guidelines
and
standards
for
these
11
industrial
categories
allow
permittees
to
provide
certifications
that
reduce
or
eliminate
monitoring
requirements
for
one
or
more
pollutants.
When
the
permittee
chooses
to
certify,
the
effluent
limitations
guidelines
and
standards
may
require
semi­
annual,
annual,
or
once
per
permit
cycle
reports.
For
one
industrial
category,
the
pesticides
formulating,
packaging,
and
repackaging
category,
there
are
no
pollutant­
specific
monitoring
requirements
but
the
facility
may
certify
that
it
is
using
pollution
prevention
measures
stipulated
by
EPA
and
must
maintain
a
pollution
prevention
plan
on­
site.
The
burden
estimate
from
certifications
were
previously
reported
in
the
Certification
for
Exemption
from
Monitoring
and
Notification
of
Process
Changes
in
Effluent
Guidelines
ICR
(
OMB
Control
No.
2040­
0033),
then
in
the
1996
NPDES/
Compliance
Assessment/
Certification
Information
ICR
and
are
now
updated,
integrated,
and
reported
in
this
ICR.

2.
b
Practical
Utility
of
the
Data
and
Users
of
the
Data
Most
compliance
assessment
data
is
generated
by
permittees
and
submitted
to
the
appropriate
permitting
authority.
The
permitting
authority
then
uses
this
information
to
determine
compliance
with
permit
conditions.
If
noncompliance
is
detected,
the
permitting
authority
will
take
the
appropriate
enforcement
action
based
on
the
frequency
and
degree
of
seriousness
of
the
violation.
The
permitting
authority
may
take
one
or
more
of
the
following
actions:

!
Permit
modification.
If
a
permit
violation
occurs
consistently,
the
permitting
authority
may
modify
the
permit,
although
the
permittee
still
must
comply
with
all
appropriate
provisions
of
the
CWA.
For
example,
a
permit
may
be
modified
to
include
a
compliance
schedule
for
installation
of
new
technology.
Such
a
modification
might
enable
the
permittee
to
meet
effluent
limits
or
sewage
sludge
quality
standards
it
was
previously
unable
to
attain.

!
Technical
assistance
to
permittees.
Under
certain
circumstances,
the
permitting
authority
may
provide
technical
assistance
to
the
permittee
to
assist
it
in
attaining
compliance.

!
Informal
enforcement
action.
For
certain
violations,
the
permitting
authority
may
initially
use
telephone
calls,
inspections,
warning
letters,
and
other
such
methods
to
bring
the
permittee
into
compliance.

!
Administrative
enforcement
action.
The
permitting
authority
may
take
more
severe
actions
including
Notices
of
Violations,
administrative
orders,
or
administrative
penalty
orders.

!
Case
referral.
Ultimately,
the
permitting
authority
may
refer
a
permit
violation
to
the
Department
of
Justice
for
further
legal
enforcement
action.
Compliance
Assessment
ICR
Page
7
July
7,
2000
There
are
several
exceptions
to
the
general
flow
of
compliance
assessment
data
from
permittee
to
permitting
authority.
EPA
may
require
additional
information
in
the
form
of
a
Section
308(
a)
letter
(
see
Section
4.
b.
6
for
further
explanation).

Another
exception
to
the
compliance
data
information
flow
from
permittee
to
permitting
authority
occurs
in
the
case
of
the
NPDES
storm
water
permitting
program
where
the
regulatory
requirement
is
for
records
retention
rather
than
reporting.
As
discussed
earlier,
permit
compliance
for
storm
water
permittees
is
assessed
on
a
permit­
by­
permit
basis.
The
minimum
compliance
requirement
for
a
storm
water
permittee
is
an
annual
site
inspection
that
identifies
any
incidents
of
non­
compliance
and
evaluates
whether
measures
to
reduce
pollutant
loadings
identified
in
the
storm
water
pollution
prevention
plan
are
adequate
and
being
properly
implemented.
Although
the
permittees
are
not
required
to
report
the
inspection
information,
they
are
required
to
retain
records
of
these
inspections
for
at
least
3
years.
This
activity
is
reflected
in
this
ICR
as
a
recordkeeping
activity.
As
stated
earlier,
EPA
estimates
that
all
storm
water
permittees
will
be
subject
to
this
minimum
requirement.
Compliance
Assessment
ICR
Page
8
July
7,
2000
3.0
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3.
a
Nonduplication
EPA
has
examined
all
other
reporting
requirements
contained
in
the
Clean
Water
Act
and
40
CFR
Parts
122,
123,
124,
125,
501,
and
503.
The
Agency
also
has
consulted
the
following
sources
of
information
to
determine
if
similar
or
duplicative
information
is
available
elsewhere:

!
EPA
Information
Systems
Inventory,

!
Government
Information
Locator
System
(
GILS),
and
!
Toxic
Chemical
Release
Inventory.

Examination
of
these
databases
revealed
no
duplicative
reporting
requirements.
In
addition,
EPA
prepared
an
ICR
for
the
Part
503
sludge
technical
standards
rule
and
is
preparing
an
ICR
for
Reporting,
Recordkeeping,
and
Public
Notification
for
the
Proposed
Sanitary
Sewer
Overflow
Regulations.
EPA
has
compared
these
ICRs
to
ensure
there
is
no
duplication.

EPA
has
examined
a
similar
reporting
requirement
for
notice
of
spills
under
the
Resource
Conservation
and
Recovery
Act
(
RCRA)
for
duplication
of
the
CWA
requirement.
EPA
believes
that
any
duplication
between
NPDES
and
RCRA
reporting
of
pollutant
releases
is
negligible
because
they
focus
on
different
areas
of
a
facility
(
RCRA
focuses
on
on­
site
activities
and
NPDES
focuses
on
discharge
outfalls).
EPA
has
concluded
that
there
is
no
other
way
to
obtain
the
compliance
assessment
information
addressed
in
this
ICR.

3.
b
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
In
compliance
with
the
1995
Paperwork
Reduction
Act,
any
agency
developing
a
nonrule
related
ICR
must
solicit
public
comments
for
a
60­
day
period
prior
to
submitting
the
ICR
to
OMB.
The
comments,
which
are
used
partly
to
determine
realistic
burden
estimates
for
respondents,
must
be
considered
when
completing
the
Supporting
Statement
that
is
submitted
to
OMB.
EPA
public
noticed
the
first
Federal
Register
for
the
revised
ICR
on
March
23,
2000
(
65
FR
15633).
EPA
received
comments
to
this
notice.
A
summary
of
comments
and
response
to
comments
are
enclosed.

3.
c
Consultations
EPA
solicited
public
comments
on
the
1996
draft
NPDES/
Compliance
Assessment/
Certification
Information
ICR
on
April
9,
1996
(
61
FR
15801).
There
were
no
comments.
In
addition,
EPA
has
solicited
public
comments
on
the
NPDES
issues
contained
in
this
ICR
on
several
occasions.
The
Consolidated
Permit
Regulations
promulgated
in
May
1980
and
the
subsequent
revisions
promulgated
in
September
1984
were
both
subject
to
60­
day
public
Compliance
Assessment
ICR
Page
9
July
7,
2000
comment
periods.
All
comments
received
during
these
time
periods
were
reviewed
and
considered
by
the
Agency.
A
summary
of
these
comments
and
EPA
reactions
to
them
is
presented
in
the
preamble
to
the
final
NPDES
regulations.
Public
comment
regarding
sewage
sludge
permit
conditions
were
solicited
before
EPA
published
the
States
Sludge
Management
regulations
on
May
2,
1989.
More
recently,
the
NPDES
regulations
were
revised
in
April
1995,
March
1997,
and
August
1998.
All
revisions
were
subject
to
a
comment
period
after
they
were
proposed
and
EPA
considered
all
public
comments
received
before
final
promulgation.
A
summary
of
comments
and
EPA's
reaction
to
them
were
presented
in
the
preamble
to
the
final
regulations.

3.
d
Effects
of
Less
Frequent
Data
Collection
The
information
collection
requirements
for
this
NPDES/
Compliance
Assessment/
Certification
Information
ICR
are
generally
required
episodically.
Some
of
the
information
included
in
this
ICR
is
collected
only
when
certain
conditions
occur.
For
example,
compliance
schedule
reports
are
submitted
when
a
milestone
is
reached,
to
determine
the
permittee's
compliance
with
that
milestone.
Also,
alternate
level
reports
are
submitted
only
when
there
is
an
expected
change
in
the
production
level
at
the
facility.

Some
of
the
information
in
this
ICR
that
is
required
to
be
submitted
is
collected
only
after
the
permittee
violates
a
permit
condition.
For
example,
noncompliance
reports
are
submitted
when
the
facility
experiences
a
bypass,
an
upset,
or
a
violation
of
a
daily
maximum
limit.
Section
308(
a)
letters
are
submitted
only
when
requested
by
the
Regional
Administrator,
in
response
to
events
such
as
a
spill
of
oil
or
a
hazardous
substance.
Therefore,
frequency
of
information
collection
is
not
an
issue
for
the
reporting
requirements
in
this
category.

3.
e
General
Guidelines
This
information
collection
is
consistent
with
OMB
guidelines
contained
in
5
CFR
1320.5(
d)(
2)
with
the
exception
of
the
24­
hour
reporting
requirements
for
notice
of
unanticipated
upset
or
bypass
and
notice
of
violation
of
maximum
daily
discharge.
Twenty­
four
hour
reporting
is
required
by
the
NPDES
regulations
at
40
CFR,
§
122.41(
l)(
6)
because
of
the
potential
for
severe
environmental
damage
or
grave
threats
to
public
health
resulting
from
these
circumstances.
The
pollutant
discharge
limits
in
a
NPDES
permit
are
designed
to
be
protective
of
the
environment
and
the
public.
Violation
of
those
limits
whether
by
upset,
bypass,
or
other
violation
is,
therefore,
a
threat
to
the
receiving
stream.
The
permitting
authority
must
be
informed
of
such
violations
quickly
so
that
necessary
remedial
action
can
be
taken
as
soon
as
possible.

3.
f
Confidentiality
and
Sensitive
Questions
Compliance
Assessment
ICR
Page
10
July
7,
2000
Where
information
submitted
in
conjunction
with
this
ICR
contains
trade
secrets
or
similar
confidential
business
information,
the
respondent
has
the
authority
to
request
that
this
information
be
treated
as
confidential
business
information.
All
data
so
designated
will
be
handled
pursuant
to
40
CFR
Part
2.
This
information
will
be
maintained
according
to
procedures
outlined
in
EPA's
Security
Manual
Part
III,
Chapter
9,
dated
August
9,
1976.
Pursuant
to
Section
308(
b)
of
the
CWA,
effluent
data
may
not
be
treated
as
confidential.

The
reporting
requirements
addressed
in
this
ICR
do
not
include
sensitive
questions.
Compliance
Assessment
ICR
Page
11
July
7,
2000
4.0
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4.
a
Respondents
and
SIC
Codes
An
NPDES
permit
is
required
any
time
there
is
a
discharge
of
pollutants
from
a
point
source
to
the
waters
of
the
United
States,
regardless
of
a
discharger's
industrial
category.
Consequently,
industries
of
almost
any
category
may
be
subject
to
compliance
assessment
requirements
for
their
NPDES
permits.
A
relatively
large
portion
of
permitted
facilities,
including
municipal
dischargers,
are
classified
in
the
sanitary
service
(
Standard
Industrial
Code
(
SIC)
number
495)
industrial
category.
Other
common
permittee
classifications
include
the
electric
services
(
SIC
491),
bituminous
coal
(
SIC
121),
industrial
organic
(
SIC
286),
petroleum
refining
(
SIC
291),
and
gold
ores
(
SIC
104)
industrial
categories.
Similarly,
EPA
may
request
supplemental
information
from
any
permittee.

Applicants
requesting
coverage
under
the
Sewage
Sludge
Management
program
include
POTWs
and
privately
owned
treatment
works
(
PrOTWs)
(
SIC
495).
In
most
cases,
these
facilities
will
have
NPDES
permits
and
will
submit
information
about
sewage
sludge
use
and
disposal
practices
as
part
of
their
NPDES
applications.
In
some
cases,
respondents
are
facilities
treating
domestic
sewage
that
do
not
have
a
NPDES
permit
but
must
have
a
permit
for
sewage
sludge
use
and
disposal
activities.
These
respondents
are
called
"
sludge­
only"
applicants.

4.
b
Information
Requested
EPA
requires
permittees
to
maintain
and/
or
submit
certain
information.
The
following
recordkeeping
and
reporting
requirements
are
covered
by
this
ICR
and
are
used
by
the
permitting
authority
to
determine
a
permittee's
compliance
with
its
permit
requirements:

1.
Recordkeeping
of
Monitoring
Data
[
§
122.41(
j)(
2)]:
In
association
with
monitoring
requirements,
NPDES
permittees
including
non
storm
water
general
permittees
and
a
portion
of
the
storm
water
general
permittees
must
keep
records
of
all
monitoring
data
and
reports,
including
copies
of
all
original
monitoring
information,
for
3
years
after
the
date
of
sample,
measurement,
report,
or
application.
Data
that
must
be
retained
include:
date
and
time
of
sampling
and
monitoring,
names
of
individuals
who
performed
sampling
and
monitoring,
analytical
techniques
or
methods
used,
and
results
of
such
analyses.
These
data
must
be
readily
available
to
the
permitting
authority
during
site
inspections
or
at
any
other
time
they
are
needed.
This
recordkeeping
requirement
is
intended
to
ensure
that
permittees
keep
files
on
the
raw
data
used
to
generate
DMR
summary
information.
This
information
would
otherwise
not
be
available
to
the
permitting
authority.
The
recordkeeping
burden
associated
with
sewage
sludge
monitoring
is
calculated
in
the
Part
503
ICR
and
is
not
covered
in
this
ICR.

2.
Recordkeeping
of
Inspection
Data
[
§
122.44(
i)(
4)(
ii)]:
A
storm
water
general
permittee
must
keep
records
of
annual
on­
site
inspection
data
for
3
years
after
the
Compliance
Assessment
ICR
Page
12
July
7,
2000
date
of
inspection.
The
inspection
data
must
summarize
the
results
of
the
inspection,
and
identify
any
incidents
of
noncompliance
and
evaluate
measures
that
reduce
pollutant
loadings
identified
in
the
storm
water
pollution
prevention
plan.
This
data
must
be
readily
available
to
the
permitting
authority
on
request.
This
information
is
the
minimum
compliance
requirement
and
applies
to
all
storm
water
general
permittees.
In
addition,
storm
water
permittees
with
discharges
associated
with
industrial
activity
are
required
to
perform
periodic
visual
examinations
of
their
facilities
and
maintain
records
of
these
visual
examinations.

3.
Compliance
Schedule
Reports
[
§
§
122.41(
l)(
5)
and
501.15(
a)(
6)]:
Adherence
to
an
NPDES
or
sewage
sludge
permittee's
compliance
schedule
is
determined
by
evaluation
of
the
compliance
schedule
reports
submitted
by
the
permittee.
This
information
is
used
to
assess
the
permittee's
progress
in
installing
the
treatment
facilities
(
or
"
milestones")
necessary
to
meet
discharge
limitations
or
sewage
sludge
quality
standards.
Compliance
schedule
reports
must
be
submitted
within
14
days
following
the
schedule
date
of
each
of
the
scheduled
milestones.
A
schedule
violation
could
result
in
an
enforcement
action.

4.
Noncompliance
Reports
[
§
§
122.41(
l)(
6),
122.41(
l)(
7),
and
501.15(
b)(
12)]:
A
permittee
must
provide
24­
hour
oral
reporting
of
any
noncompliance
which
may
endanger
human
health
or
the
environment
(
with
a
written
follow­
up
submission
within
5
days).
The
following
must
be
reported
within
24
hours
to
the
permitting
authority:
1)
any
unanticipated
bypass
which
exceeds
any
effluent
limitation
in
the
permit;
2)
any
upset
which
exceeds
any
effluent
limitation
in
the
permit;
and
3)
violation
of
a
maximum
daily
discharge
limitation
for
any
of
the
pollutants
listed
by
the
Director
in
the
permit.
These
reports
may
include
SSO
events
and
unpermitted
CSO
reporting;
however,
in
this
ICR,
SSO
reporting
and
unpermitted
CSO
reporting
burdens
appear
as
separate
line
items
in
exhibits
that
follow.
In
addition,
§
§
122.41
and
501.15
require
permittees
to
report
instances
of
non­
compliance
with
sewage
sludge
regulations
such
as
noncompliance
with
sewage
sludge
pollution
standards.
Timely
reporting
is
essential
in
these
cases,
and
thus,
separate
reporting
requirements
have
been
established
for
reporting
bypass,
upset,
or
violation
of
a
maximum
daily
discharge.
If
required,
the
written
report
of
the
occurrence
shall
describe
the
event,
its
cause,
its
duration,
and
remedial
actions
taken.
In
addition,
respondents
must
report
other
noncompliance
situations
even
if
they
are
not
covered
under
these
reporting
requirements
as
soon
as
they
occur.

5.
Alternate
Level
Reports
[
§
122.45(
b)(
2)(
B)(
1)]:
The
permitting
authority
may,
at
its
discretion,
apply
tiered
production­
based
effluent
limits
in
an
NPDES
permit.
Tiered
permit
limits
allow
facilities
to
operate
under
different
sets
of
limits
for
pollutants
based
on
varying
production
levels.
In
the
case
of
automotive
factories,
however,
a
reasonable
demonstration
by
the
permittee
for
the
requirement
for
tiered
limits
obligates
the
EPA
(
not
States)
to
grant
tiered
limits
to
the
industry.
Nevertheless,
every
facility
operating
under
tiered
limits
is
required
to
submit
a
notification
to
the
permitting
authority
if
it
intends
to
operate
at
a
production
level
higher
than
the
lowest
production
level
identified
in
the
permit.
Compliance
Assessment
ICR
Page
13
July
7,
2000
6.
Section
308
(
a)
Letters:
Section
308(
a)
of
the
CWA
gives
broad
discretion
to
permitting
authorities
to
request
information
from
a
permittee
above
and
beyond
routine
requirements.
The
burden
on
respondents
from
308(
a)
letters
requesting
information
is
included
under
several
ICRs.
For
example,
a
308(
a)
letter
may
be
sent
out
in
response
to
inadequate
information
contained
in
an
NPDES
permit
application.
Accordingly,
this
burden
is
reflected
in
the
Applications
ICR.
Section
308(
a)
letters
may
also
request
additional
information
on
other
monitoring
activities
under
the
Clean
Water
Act,
including
spills
of
oil
and
hazardous
substances
from
owners
or
operators
of
facilities
or
vessels
spilling
oil
or
hazardous
substances.
They
are,
therefore,
a
compliance­
related
activity
and
the
burden
associated
with
responding
to
this
is
reflected
in
this
NPDES/
Compliance
Assessment/
Certification
Information
ICR.

7.
Certification
for
Exemption
From
Monitoring
and
Notification
of
Process
Changes:
The
effluent
limitations
guidelines
and
standards
regulations
for
11
industrial
categories
(
11
categories
and
1
subcategory)
allow
dischargers
to
submit
a
certification
to
exempt
them
from
monitoring
one
or
more
pollutants.
Of
these
industrial
categories,
two
categories
(
aluminum
forming
and
coil
coating)
may
choose
to
submit
an
annual
certification
requesting
exemption
from
cyanide
monitoring;
one
category
(
pharmaceutical
manufacturing)
may
choose
to
submit
a
certification
requesting
exemption
from
monitoring
once
every
permit
cycle
(
5
years);
one
category
(
porcelain
enameling)
may
choose
to
submit
an
annual
certification
requesting
exemption
from
chromium
monitoring;
certain
facilities
in
the
pulp
and
paper
categories,
which
use
a
totally
chlorine
free
process,
may
choose
an
alternative
monitoring
program
by
certification
once
every
permit
cycle;
one
category
(
steam
electric)
may
choose
to
provide
a
demonstration
and
certification
requesting
exemption
for
monitoring
requirements.
For
one
of
the
subparts
to
the
coil
coating
category
(
can
making),
the
discharger
is
required
to
submit
a
notification
if
the
alloy
used
in
making
cans
contains
less
than
1
percent
manganese.
For
certain
facilities
in
the
electroplating,
metal
finishing,
and
electrical
and
electronic
components
categories,
permittees
may
choose
to
submit
a
Total
Toxic
Organics
(
TTO)
certification
semi­
annually
in
lieu
of
TTO
monitoring,
but
must
also
develop
and
submit
a
toxic
organic
management
plan
.
In
addition,
for
the
pesticide
formulating
and
packaging
category,
the
discharger
may
choose
to
submit
an
annual
certification
to
use
pollution
prevention
alternatives.
Dischargers
submitting
a
certification
for
pollution
prevention
alternative
must
also
develop
a
pollution
prevention
plan.

4.
c
Respondent
Activities
Respondent
activities
can
vary
substantially,
depending
on
the
type
of
permittee
and
its
ability
to
comply
with
its
NPDES
or
sewage
sludge
permit.
This
ICR
explains
these
activities,
in
terms
of
the
type
of
information
submission
they
require,
in
detail
in
Section
4.
b
above.
However,
to
submit
the
required
information,
any
particular
respondent
may
engage
in
the
following
types
of
activities:

!
Preparing
basic
information.
This
includes
reviewing
regulatory
and
permit
requirements,
responding
to
information
requests,
reporting
production
levels
to
the
Compliance
Assessment
ICR
Page
14
July
7,
2000
permitting
authority,
gathering
general
information
for
reports,
preparing
documents
for
submission,
making
telephone
calls
to
the
permitting
authority,
drafting
letters,
reviewing
materials
for
submission,
preparing
certifications,
and
mailing
completed
submissions.

!
Maintaining
records.
All
NPDES
permittees
must
keep
records
of
all
monitoring
information
and
all
reports
required
by
the
permit.
Storm
water
general
permittees
must
retain
records
of
facility
inspections
and
visual
examinations.
New
permittees
need
to
develop
a
recordkeeping
system,
enter
data,
train
personnel,
and
file
information.
Compliance
Assessment
ICR
Page
15
July
7,
2000
5.0
THE
INFORMATION
COLLECTED:
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5.
a
Agency
Activities
The
permitting
authority
retains
all
information
generated
by
the
permittee
as
part
of
the
permittee's
official
file.
The
information
is
reviewed
to
determine
if
the
permittee
is
in
compliance
with
its
permit,
and
to
determine
if
any
noncompliance
poses
a
threat
to
human
health
or
the
environment.
In
some
cases,
follow­
up
actions,
including
enforcement
actions,
may
be
necessary.
In
collecting
and
analyzing
the
information
associated
with
this
ICR,
EPA
enters
all
applicable
data
into
a
national
database,
the
Permit
Compliance
System
(
PCS)
for
all
major
permittees
(
a
POTW
is
considered
a
major
permittee
if
it
discharges
1
million
gallons
per
day
or
more,
or
has
a
service
population
of
10,000
or
more).
The
Agency
uses
PCS
to
develop
statistical
summaries
on
such
things
as
permit
compliance
rates.
The
permitting
authority
analyzes
and
processes
this
information
as
well.
The
permitting
authority's
burden
for
compiling
these
reports
on
compliance
rates
is
estimated
in
the
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
ICR
(
OMB
No.
2040­
0057,
ICR
No.
0168).

5.
b
Collection
Methodology
and
Management
The
permitting
authority
will
ensure
the
accuracy
and
completeness
of
information
collected
by
reviewing
each
submittal
upon
receipt.

Since
EPA
maintains
national
compliance
assessment
data
in
PCS,
there
is
a
reduced
burden
to
the
permitting
authority
for
gathering
and
analyzing
national
permit
and
water
quality
data.

The
use
of
improved
information
technology
does
not
yet
appear
to
provide
additional
opportunities
for
reducing
burden
on
the
respondents.
This
is
due
to
a
non­
standardized
format
for
information
that
is
submitted
on
an
as­
needed
basis.

The
public
may
access
certain
PCS
data
upon
request
to
EPA.

5.
c
Small
Entity
Flexibility
All
permittees,
regardless
of
the
size
of
their
facilities,
are
required
to
report
instances
of
noncompliance
and
keep
records
of
monitoring
data.
In
most
cases,
these
requirements
do
not
impose
a
large
burden
on
small
business
because
the
information
required
is
simple
and
straightforward.
Compliance
Assessment
ICR
Page
16
July
7,
2000
Many
small
businesses
do
not
discharge
any
pollutants,
or
they
discharge
pollutants
to
a
POTW.
These
businesses
are
not
required
to
have
NPDES
permits
and
thus
are
not
subject
to
the
reporting
requirements
of
this
ICR.

5.
d
Collection
Schedule
5.
d.
1
Information
Collection
Activities
With
the
exception
of
the
certifications
allowed
by
the
effluent
limitations
guidelines
and
standards
and
the
storm
water
related
inspections
and
visual
examinations,
the
information
collection
activities
included
in
this
ICR
do
not
follow
routine
schedules;
they
are
submitted
on
an
as­
needed
basis.
The
time
frames
for
collecting
and
submitting
compliance
assessment
information
are
outlined
below:

!
Recordkeeping
is
performed
on
a
continual
basis;

!
General
permittee
facility
self­
inspections
must
occur
annually;

!
Storm
water
permittees
with
discharges
associated
with
industrial
activity
must
perform
quarterly
visual
examinations;

!
Compliance
assessment
reports
are
submitted
within
14
days
of
a
scheduled
milestone;

!
Noncompliance
reports
are
submitted
only
in
cases
where
the
permittee
has
violated
a
permit
condition;

!
Notices
of
alternate
levels
of
production
are
submitted
at
least
2
days
prior
to
a
month
in
which
a
change
in
production
is
anticipated;
and
!
Response
time
to
Section
308(
a)
requests
varies.
These
letters
are
sent
by
the
Regional
Administrator
when
specific
information
is
needed
where
no
enforcement
action
is
contemplated,
or
for
information
from
entities
that
may
need
to
be
regulated
under
the
CWA.

5.
d.
2
Information
Collection
Schedule
The
information
collection
schedules
for
the
11
industrial
categories
(
11
categories
and
1
subcategory)
seeking
exemptions
or
alternative
compliance
reporting
are
as
follows:

!
Facilities
in
the
porcelain
enameling,
aluminum
forming,
coil
coating,
and
pesticides
formulating
and
packaging
industrial
categories
may
submit
certifications
annually
in
lieu
of
routine
monitoring.
Compliance
Assessment
ICR
Page
17
July
7,
2000
!
Facilities
in
the
electroplating,
metal
finishing,
and
electrical
and
electronic
components
industrial
categories
may
submit
semiannual
certifications
in
lieu
of
certain
monitoring.

!
Facilities
in
the
can
making
category,
a
subcategory
of
the
coil
coating
industrial
category,
must
submit
a
notification
only
when
a
process
change
is
anticipated.

!
Facilities
in
the
pharmaceutical
manufacturing,
steam
electric,
and
pulp
and
paper
industrial
categories
must
submit
certifications
once
every
permit
cycle.
Compliance
Assessment
ICR
Page
18
1
SIC
data
in
PCS
were
used
to
categorize
whether
a
facility
was
municipal
or
non­
municipal.
For
approximately
5
percent
of
the
facilities,
these
data
were
not
currently
available
in
PCS
(
e.
g.,
data
field
was
blank).
Therefore,
these
facilities
were
apportioned
to
either
the
municipal
or
non­
municipal
category
based
on
the
relative
numbers
of
municipal
and
non­
municipal
facilities.

2
EPA
estimates
that
over
the
next
6
years
that
it
will
receive
approximately
51,730
NOIs
from
permittees
with
discharges
associated
with
construction
activities
and
that
delegated
States
will
also
receive
approximately
72,700
NOIs
from
these
storm
water
permittees.
Estimating
that
these
permits
will
have
an
average
life
of
1
year
results
in
a
total
of
20,739
permittees
with
discharges
associated
with
construction
activities
as
potential
respondents
to
this
ICR
annually.

July
7,
2000
6.0
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6.
a
Estimating
Respondent
Burden
Exhibit
2
presents
a
summary
of
the
number
of
State­
issued
and
EPA­
issued
permits.
The
major
and
minor
permit
data
were
compiled
from
PCS
data
(
December
1999).
1
Storm
water
general
permittee
estimates
(
discharges
associated
with
industrial
activities
and
construction
activities)
were
based
on
data
from
the
EPA
Notice
of
Intent
(
NOI)
Data
Processing
Center.
Where
State
data
were
not
readily
available
from
the
NOI
Data
Processing
Center,
these
data
were
obtained
from
States
through
discussions
with
EPA
Regions
and
accounted
for
a
total
of
41
States.
For
the
remaining
States
where
no
data
were
available
from
either
of
these
sources,
storm
water
general
permit
numbers
were
extrapolated
based
on
State
industrial
population
information.
2
Other
non
storm
water
general
permittee
estimates
were
based
on
data
submitted
by
EPA
Regions
in
December
1999
and
January
2000.
Total
POTW
and
PrOTW
sludge­
only
permit
numbers
were
taken
from
the
previous
ICR.
Additional
more
accurate
data
were
not
believed
to
be
available
at
the
time
of
revisions
to
this
ICR.
Numbers
were
apportioned
between
State
and
EPA
to
reflect
the
three
States
that
have
received
sludge
program
approval
since
the
previous
ICR.
The
permits
shown
in
Exhibit
2
constitute
major
and
minor
municipal
individual
permittees,
storm
water
and
non­
storm
water
general
permittees,
and
sludge­
only
permittees.
The
facilities
holding
these
permits
are
potential
respondents
in
this
NPDES/
Compliance
Assessment/
Certification
Information
ICR.
Although
this
ICR
includes
Federal
facility
counts
because
of
the
manner
in
which
the
data
were
retrieved
from
PCS,
their
burden
is
believed
to
be
insignificant.
EPA
is
not
required
to
include
burden
estimates
imposed
on
other
Federal
agencies.
State
and
EPA­
issued
permits
have
been
disaggregated
to
allow
separate
reporting
of
burden
and
costs
to
State
and
Federal
governments.

As
shown
in
Exhibit
3,
EPA
estimates
that
the
total
annual
burden
to
respondents
is
approximately
975,175
hours.
Of
this
total,
827,968
of
the
burden
hours
are
for
recordkeeping
and
147,207
of
the
burden
hours
are
for
reporting.
Exhibit
3
provides
a
detailed
breakdown
of
these
hours
for
each
request.
The
information
requirements
in
this
ICR
potentially
affect
219,728
respondents,
or
all
of
the
permittees
identified
in
Exhibit
2.
Of
this
population,
217,478
respondents
will
incur
a
record­
keeping
burden.
This
number
includes
all
State
and
EPA
major,
minor,
and
general
permittees
but
excludes
sludge
permittees
because
the
recordkeeping
burden
for
sludge
permittees
has
been
estimated
in
another
ICR
(
see
Section
4.
b).
Compliance
Assessment
ICR
Page
19
July
7,
2000
Exhibits
2
and
3
also
list
number
of
respondents
for
several
independent
reporting
requirements.
The
number
of
respondents
reporting
one
type
of
information
(
e.
g.,
upset/
bypass
reports)
may
or
may
not
be
the
same
respondents
reporting
another
type
of
information
(
e.
g.,
violation
of
maximum
daily
discharge
report).
Because
of
the
possibility
of
double
counting
respondents,
the
Agency
estimated
the
total
number
of
respondents
required
to
report
compliance
information
based
on
program
experience.
EPA
estimates
that
the
total
number
of
respondents
reporting
to
State
and
Federal
governments
is
16,532
respondents.
This
number
includes
90
percent
(
6,047)
of
all
major
permittees,
15
percent
(
8,168)
of
all
minor
permittees,
5
percent
of
the
49.5
percent
of
the
storm
water
permittees
that
perform
monitoring
(
2,185),
and
132
sludge­
only
permittees.
As
shown
in
Exhibit
4,
the
total
annual
average
responses
per
respondent
is
2.15.

In
accordance
with
OMB's
instructions,
this
ICR
calculates
burden
and
costs
to
respondents
on
an
annual
basis.
To
calculate
the
total
annual
respondent
burden,
the
ICR
first
calculates
the
annual
burden
for
each
compliance
assessment
requirement.
The
ICR
then
adds
these
together.
Thus,
the
total
annual
burden
is
the
sum
of
the
annual
burdens
for
each
individual
compliance
assessment
requirement.
This
section
explains
the
respondent
burden
estimates
for
each
compliance
assessment
requirement.
Type
of
Permit
States
EPA
Total
MAJOR
PERMITS
Municipal
3,740
348
4,088
Non­
Municipal
2,382
249
2,631
SUBTOTAL
6,122
597
6,719
MINOR
PERMITS
Municipal
17,026
539
17,565
Non­
Municipal
35,256
1,631
36,887
SUBTOTAL
52,282
2,170
54,452
GENERAL
PERMITTEES
Storm
Water
Industrial
83,860
4,413
88,273
Construction
12,117
8,622
20,739
Other
29,439
17,856
47,295
SUBTOTAL
125,416
30,891
156,307
SLUDGE­
ONLY
PERMITS
POTWs
111
1,999
2,110
PrOTWs
7
133
140
SUBTOTAL
118
2,132
2,250
TOTAL
183,938
35,790
219,728
Source
of
data:
PCS
(
December
1999),
EPA
Notice
of
Intent
Data
Processing
Center,
previous
ICR.
Exhibit
2.
Number
of
NPDES
Permits
Issued
by
EPA
and
the
States
Compliance
Assessment
ICR
Page
20
July
7,
2000
Exhibit
3.
Annual
Respondent
Reporting
and
Recordkeeping
Burden
Item/
Type
of
Respondent
Respondents
per
Year
(
A)
Burden
(
Hrs.)
per
Respondent
(
B)
Total
Annual
Burden
(
Hrs.)
(
A)
×
(
B)
Recordkeeping
Major
Municipal
Permittees
4,088
6.0
24,528
Major
Non­
Municipal
Permittees
2,631
6.0
15,786
Minor
Municipal
Permittees
17,565
1.2
21,078
Minor
Non­
Municipal
Permittees
36,887
1.2
44,264
Storm
Water
General
Permittees
 
Industrial*
88,273
6.6
582,602
Storm
Water
General
Permittees
 
Construction
20,739
4.0
82,956
Other
General
Permittees
47,295
1.2
56,754
SUBTOTAL
217,478
827,968
Compliance
Schedule
Reports
Major
Municipal
Permittees
3,066
1.125
3,449
Major
Non­
Municipal
Permittees
1,973
1.125
2,220
Minor
Municipal
Permittees
878
1.125
988
Minor
Non­
Municipal
Permittees
1,844
1.125
2,075
Sludge
Permit
Conditions
Compliance
Schedule
Reports
POTWs
100
1.5
150
PrOTWs
32
1.5
48
SUBTOTAL
7,893
8,930
Noncompliance
Reports
Unanticipated
Bypass/
Upset
Report
Verbal
Reports
Major
Municipal
Permittees
613
5
3,065
Major
Non­
Municipal
Permittees
395
5
1,975
Minor
Municipal
Permittees
878
5
4,390
Minor
Non­
Municipal
Permittees
1,844
5
9,220
Written
Reports
Major
Municipal
Permittees
460
2
920
Major
Non­
Municipal
Permittees
296
2
592
Minor
Municipal
Permittees
659
2
1,318
Minor
Non­
Municipal
Permittees
1,383
2
2,766
SUBTOTAL
6,528
24,246
Maximum
Daily
Violation
Report
Verbal
Reports
Major
Municipal
Permittees
613
6
3,678
Major
Non­
Municipal
Permittees
395
6
2,370
Minor
Municipal
Permittees
878
3
2,634
Minor
Non­
Municipal
Permittees
1,844
3
5,532
Storm
Water
Permittees
2,185
3
6,555
Compliance
Assessment
ICR
Page
21
Exhibit
3.
Annual
Respondent
Reporting
and
Recordkeeping
Burden
Item/
Type
of
Respondent
Respondents
per
Year
(
A)
Burden
(
Hrs.)
per
Respondent
(
B)
Total
Annual
Burden
(
Hrs.)
(
A)
×
(
B)

July
7,
2000
Written
Reports
Major
Municipal
Permittees
307
4
1,228
Major
Non­
Municipal
Permittees
198
4
792
Minor
Municipal
Permittees
439
2
878
Minor
Non­
Municipal
Permittees
922
2
1,844
Storm
Water
Permittees
1,093
2
2,186
SUBTOTAL
8,874
27,697
Other
Noncompliance
Reports
Major
Municipal
Permittees
82
5
410
Major
Non­
Municipal
Permittees
53
5
265
Minor
Municipal
Permittees
176
5
880
Minor
Non­
Municipal
Permittees
369
5
1,845
Sludge
Permit
Conditions
 
Noncompliance
Reports
POTWs
31
5.2
161
PrOTWs
10
5.2
52
SUBTOTAL
721
3,613
Notice
of
Alternate
Level
of
Production
0
0
0
Section
308(
a)
Letters
1,200
8
9,600
Pollution
Prevention
Alternative
Pesticides
Packaging
and
Repackaging
54
20
1,080
Certifications
Pesticides
Packaging
and
Repackaging
163
1
163
Aluminum
Forming
57
1
57
Coil
Coating
76
1
76
Can
Making
(
subcategory
of
coil
coating)
14
1
14
Porcelain
Enameling
27
1
27
Pharmaceutical
Manufacturing
39
1
39
Pulp,
Paper,
and
Paperboard
217
0.2
43
Building
Paper
and
Board
Mills
131
1
131
Steam
Electric
1,029
1
1,029
Electroplating
0
2
0
Metal
Finishing
1,524
2
3,048
Electrical
and
Electronic
Components
43
2
86
SUBTOTAL
3,320
4,713
SSO
Reporting
N/
A
N/
A
62,144
Unpermitted
CSO
Reporting
N/
A
N/
A
5,184
TOTAL
246,068
975,175
*
Only
a
portion
(
49.5
percent)
of
these
88,273
industrial
storm
water
permittees
are
estimated
to
be
required
to
maintain
monitoring
data;
thus,
the
average
burden
hours
per
respondent
is
6.6
hours.
**
These
burdens
were
taken
directly
from
the
1998
Summary
of
Revised
Burden
Estimates
and
are
based
on
an
estimated
number
of
events
per
year,
rather
than
the
number
of
respondents.
For
further
explanation
of
these
estimates
see
the
1998
Summary
of
Revised
Burden
Estimates
for
SSO/
Unpermitted
CSO
Reporting.
Compliance
Assessment
ICR
Page
22
July
7,
2000
Exhibit
4.
Annual
Average
Responses
per
Respondent
Item/
Type
of
Respondent
Respondents
per
Year
(
A)
Responses
per
Year
(
B)
Total
Annual
Responses
[(
A)
×
(
B)]

Compliance
Schedule
Reports
Major
Municipal
Permittees
3,066
1.5
4,599
Major
Non­
Municipal
Permittees
1,973
1.5
2,960
Minor
Municipal
Permittees
878
1.5
1,317
Minor
Non­
Municipal
Permittees
1,844
1.5
2,766
Sludge
Permit
Conditions
Compliance
Schedule
Reports
POTWs
100
2
200
PrOTWs
32
2
64
SUBTOTAL
7,893
11,906
Noncompliance
Reports
Unanticipated
Bypass/
Upset
Report
Verbal
Reports
Major
Municipal
Permittees
613
1
613
Major
Non­
Municipal
Permittees
395
1
395
Minor
Municipal
Permittees
878
1
878
Minor
Non­
Municipal
Permittees
1,844
1
1,844
Written
Reports
Major
Municipal
Permittees
460
1
460
Major
Non­
Municipal
Permittees
296
1
296
Minor
Municipal
Permittees
659
1
659
Minor
Non­
Municipal
Permittees
1,383
1
1,383
SUBTOTAL
6,528
6,528
Maximum
Daily
Violation
Report
Verbal
Reports
Major
Municipal
Permittees
613
2
1,226
Major
Non­
Municipal
Permittees
395
2
790
Minor
Municipal
Permittees
878
1
878
Minor
Non­
Municipal
Permittees
1,844
1
1,844
Storm
Water
Permittees
2,185
1
2,185
Written
Reports
Major
Municipal
Permittees
307
2
614
Major
Non­
Municipal
Permittees
198
2
396
Minor
Municipal
Permittees
439
1
439
Minor
Non­
Municipal
Permittees
922
1
922
Storm
Water
Permittees
1,093
1
1,093
SUBTOTAL
8,874
10,387
Compliance
Assessment
ICR
Page
23
Exhibit
4.
Annual
Average
Responses
per
Respondent
Item/
Type
of
Respondent
Respondents
per
Year
(
A)
Responses
per
Year
(
B)
Total
Annual
Responses
[(
A)
×
(
B)]

July
7,
2000
Other
Noncompliance
Reports
Major
Municipal
Permittees
82
1
82
Major
Non­
Municipal
Permittees
53
1
53
Minor
Municipal
Permittees
176
1
176
Minor
Non­
Municipal
Permittees
369
1
369
Sludge
Permit
Conditions
 
Noncompliance
Reports
POTWs
31
1
31
PrOTWs
10
1
10
SUBTOTAL
721
721
Notice
of
Alternate
Level
of
Production
0
0
0
Section
308(
a)
Letters
1,200
1
1,200
Pollution
Prevention
Alternative
Pesticides
Packaging
and
Repackaging
54
1
54
Certifications
Pesticides
Packaging
and
Repackaging
163
1
163
Aluminum
Forming
57
1
57
Coil
Coating
76
1
76
Can
Making
(
subcategory
of
coil
coating)
14
1
14
Porcelain
Enameling
27
1
27
Pharmaceutical
Manufacturing
39
1
39
Pulp,
Paper,
and
Paperboard
217
.2
43
Building
Paper
and
Board
Mills
131
1
131
Steam
Electric
1,029
1
1,029
Electroplating
0
2
0
Metal
Finishing
1,524
2
3,048
Electrical
and
Electronic
Components
43
2
86
SUBTOTAL
3,320
4,713
SSO
Reporting
N/
A
41,087
N/
A
Unpermitted
CSO
Reporting
N/
A
3,840
N/
A
TOTAL
28,590
35,509
Annual
average
number
of
responses
per
respondent
(
Column
C
÷
16,532)*
=
2.15.
This
does
not
include
SSO
and
CSO
events.
*
The
total
number
of
respondents
per
year
is
estimated
to
be
16,532
(
not
the
sum
of
Column
A).
See
Section
6.0.
Compliance
Assessment
ICR
Page
24
July
7,
2000
In
general,
the
larger
the
facility,
the
greater
the
number
of
outfalls,
and
the
greater
the
discharge
of
pollutants
(
particularly
toxics).
Larger
facilities
are
also
likely
to
produce
larger
volumes
of
sewage
sludge.
Because
of
these
factors,
larger
facilities
tend
to
incur
greater
burdens
for
completing
mandatory
reports.
The
more
often
a
facility
violates
its
permit
conditions,
the
larger
the
burden
associated
with
reporting
noncompliance,
explaining
reasons,
and
proposing
solutions.

6.
a.
1
Recordkeeping
of
Monitoring
and
Inspection
Data
The
following
discussion
is
presented
in
table
format
in
Exhibit
3.
EPA
estimates
that
all
NPDES
permittees
(
except
for
certain
storm
water
permittees,
as
discussed
below)
will
incur
an
annual
burden
for
recordkeeping
of
discharge
monitoring
and
other
monitoring
data.
The
burden
associated
with
this
recordkeeping
requirement
depends
on
the
size
of
the
facility.
In
the
previous
NPDES/
Compliance
Assessment/
Certification
Information
ICR,
EPA
estimated
that
6.0
hours
per
year
(
0.5
hours
per
month)
for
major
permittees
and
1.2
hours
per
year
(
0.1
hours
per
month)
for
minor
permittees
are
necessary
to
organize
and
file
the
appropriate
existing
monitoring
data.
These
estimates
are
consistent
with
current
recordkeeping
requirements
and
are
retained
in
this
ICR.
Therefore,
6,719
major
permittees
(
4,088
major
municipal
permittees
plus
2,631
major
non­
municipal
permittees)
will
spend
6.0
hours
per
year
on
recordkeeping
activities,
resulting
in
a
total
annual
burden
of
40,314
hours.
All
54,452
minor
municipal
and
non­
municipal
permittees
will
incur
an
annual
burden
for
record­
keeping
of
monitoring
data.
The
burden
for
keeping
these
records
for
minor
facilities
is
estimated
to
take
1.2
hours
per
year
per
respondent
resulting
in
a
total
annual
burden
of
65,342
hours.

All
109,012
storm
water
general
permittees
will
be
required
to
conduct
and
maintain
records
of
their
annual
site
inspections.
These
activities
are
expected
to
result
in
an
annual
burden
of
4
hours
per
respondent
for
an
annual
burden
of
436,048
hours.

All
of
the
88,273
storm
water
general
permittees
with
discharges
associated
with
industrial
activity
are
required
to
conduct
visual
examinations
quarterly.
EPA
estimates
0.5
hours
for
each
visual
examination
will
be
spent
by
these
permittees
for
a
total
of
2.0
hours
per
year
and
a
total
annual
burden
of
176,546
hours.
A
portion
of
the
storm
water
general
permittees
with
discharges
associated
with
industrial
activity
are
required
to
keep
monitoring
records.
Based
on
information
submitted
by
these
storm
water
permittees
to
the
NOI
Data
Processing
Center
indicating
that
they
perform
monitoring,
this
number
is
estimated
to
be
49.5
percent
of
these
permittees
or
43,695
permittees.
EPA
estimates
that
1.2
hours
will
be
spent
by
these
storm
water
permittees
in
keeping
monitoring
records
resulting
in
a
total
annual
burden
of
52,434
hours.
Note:
Because
only
a
portion
of
the
88,273
storm
water
permittees
with
discharges
associated
with
industrial
activity
are
required
to
maintain
monitoring
data,
the
average
burden
hours
for
these
storm
water
permittees
is
6.6
hours.
In
addition,
all
47,295
non­
storm
water
general
permittees
will
incur
a
recordkeeping
burden
for
maintaining
monitoring
data.
EPA
estimates
these
other
general
permittees
will
spend
1.2
hours
annually
in
keeping
monitoring
records
resulting
in
an
annual
burden
of
56,754
hours.
Compliance
Assessment
ICR
Page
25
July
7,
2000
The
facilities
submitting
certifications
are
a
very
small
subset
of
the
major
and
minor
permittees
and
the
recordkeeping
burden
for
these
certifications
is
believed
to
be
adequately
reflected
in
the
recordkeeping
burden
discussed
above.

The
total
recordkeeping
burden
for
all
respondents
is,
therefore,
estimated
to
be
827,968
hours.
Note
that
recordkeeping
requirements
for
sewage
sludge
permittees
are
accounted
for
in
the
Sewage
Sludge
Use
or
Disposal
Standards
ICR
and
thus
not
included
in
this
ICR.

6.
a.
2
Compliance
Schedule
Reports
Permittees
must
submit
reports
that
state
whether
compliance
schedule
milestones
contained
in
their
permits
have
been
met.
EPA
assumes
that
most
NPDES
permittees
will
engage
a
contractor
to
undertake
the
construction
necessary
to
meet
these
milestones.
The
Agency
further
assumes
that
the
permittee
will
be
receiving
periodic
detailed
progress
reports
from
their
contractor
on
the
status
of
the
construction.
Therefore,
EPA
expects
this
requirement
to
place
very
little
additional
burden
upon
the
respondent.
According
to
the
previous
NPDES/
Compliance
Assessment/
Certification
Information
ICR,
permittees
are
estimated
to
be
required
to
submit
an
average
of
1.5
reports
per
year,
and
the
burden
to
complete
each
report
is
estimated
to
be
0.75
hours.
This
is
equivalent
to
1.125
hours
per
year
for
each
respondent.
This
burden
represents
the
time
required
to
prepare
and
send
the
compliance
schedule
report.

It
is
expected
that
75
percent
of
the
major
facilities
and
5
percent
of
the
minor
facilities
will
be
required
to
submit
compliance
schedule
reports
per
year.
General
permittees
do
not
incur
a
burden
as
they
are
not
required
to
submit
compliance
schedule
reports.
At
1.125
hours
per
year,
this
is
equivalent
to
a
total
annual
burden
of
5,669
hours
for
major
facilities
and
3,063
hours
for
minor
facilities.

In
addition,
the
Agency
anticipates
that
each
year,
100
POTWs
and
32
PrOTWs
will
be
required
to
submit
compliance
schedule
reports
regarding
sewage
sludge
permit
conditions,
and
that
these
facilities
will
be
required
to
submit
and
average
of
2
reports
per
year.
The
Agency
estimates
that
the
burden
to
complete
each
report
is
0.75
hours,
for
a
total
annual
burden
of
198
hours.

The
total
annual
burden
to
respondents,
therefore,
for
compliance
schedule
reports
is
8,930
hours.

6.
a.
3
Noncompliance
Reports
When
a
permittee
violates
a
permit
condition,
it
must
submit
a
noncompliance
report
to
the
permitting
authority.
The
following
estimates
are
for
the
burden
associated
with
these
noncompliance
reports,
except
for
reports
associated
with
SSOs
and
unpermitted
CSOs.
The
burden
associated
with
these
noncompliance
reports
are
included
in
Section
6.
a.
7.
Compliance
Assessment
ICR
Page
26
July
7,
2000
24­
Hour
Report
of
Unanticipated
Bypass
or
Upset
Where
noncompliance
at
a
permittee's
facility
may
endanger
human
health
or
the
environment,
the
permittee
is
required
to
verbally
notify
the
permitting
authority
within
24
hours
of
the
noncompliance.
The
verbal
report
must
be
followed
by
a
written
report,
unless
it
is
waived
by
the
permitting
authority.
EPA
is
assuming
that
permittees
closely
monitor
the
operation
of
their
facilities
so
that
the
occurrence
of
a
bypass
or
upset
of
the
treatment
works
should
be
readily
apparent
to
the
operator.
Because
of
the
potential
for
serious
environmental
damage,
grave
threats
to
public
health,
and
injury
to
facility
employees,
permittees
should
act
quickly
in
the
event
of
such
an
occurrence.
Permittees
must
make
this
report
if
they
wish
to
use
unanticipated
bypass
or
upset
as
an
affirmative
defense
for
violating
their
permit
limits
[
§
122.41(
n)(
3)}.
Thus,
if
proper
procedures
for
reporting
bypass
or
upset
are
followed,
the
permittee
may
use
this
24­
hour
report
as
a
defense
for
violating
its
permit
conditions,
because
it
is
a
timely
report
of
the
occurrence.

EPA
estimates
that
15
percent
(
1,008)
of
the
6,719
major
facilities
and
5
percent
(
2,723)
of
the
54,452
minor
facilities
upset
or
bypass
annually
requiring
a
verbal
notification.
EPA
estimates
that
these
respondents
will
submit
one
report
per
year
and
that
the
burden
associated
with
a
verbal
notification
is
5
hours.
In
addition,
EPA
estimates
75
percent
(
2,798)
of
the
3,730
facilities
submitting
a
verbal
notification
will
also
be
required
to
submit
a
written
report.
The
written
report
is
estimated
by
EPA
to
take
an
additional
2
hours
to
complete
and
submit.
The
burden
represents
the
time
required
to
investigate
the
bypass
or
upset
cause,
the
duration
or
expected
duration,
and
the
corrective
actions
to
be
taken;
to
prepare
the
written
report
(
if
the
requirement
is
not
waived);
and
send
the
report
to
the
permitting
authority.
As
shown
in
Exhibit
3,
the
total
annual
respondent
burden
for
submitting
the
verbal
and
written
notification
is
24,246
hours.

24­
Hour
Report
of
Violation
of
Maximum
Daily
Discharge
When
a
permittee
exceeds
its
maximum
daily
discharge
limitation
for
pollutants
specified
in
its
permit,
the
permittee
is
required
to
verbally
notify
the
permitting
authority
within
24
hours
of
the
violation.
The
verbal
report
must
be
followed
by
a
written
report,
unless
it
is
waived
by
the
permitting
authority.
Permittees
that
have
daily
maximum
discharge
limits
are
already
required
to
monitor
for
that
pollutant
and
report
the
results
of
their
sampling
to
the
permitting
authority
on
a
DMR.
Because
the
permittee's
DMR
requirements
are
already
accounted
for
in
the
Discharge
Monitoring
Report
ICR
(
as
discussed
above),
the
verbal
and
written
notice
requirements
under
this
ICR
adds
only
an
incremental
burden
to
the
permittee's
regular
reporting
requirements.

EPA
assumes
that
the
permittees
required
to
submit
verbal
notices
will
incur
a
burden
of
3
hours
per
notice.
In
addition,
EPA
assumes
that
50
percent
of
these
permittees
giving
notice
will
be
required
to
submit
written
notices
(
the
remaining
50
percent
will
have
this
requirement
waived),
with
an
estimated
burden
of
2
hours
per
written
report.
The
burden
represents
the
time
required
to
gather
information
and
prepare
the
verbal
notice;
prepare
the
written
report,
if
requirement
is
not
waived;
and
submit
the
report
to
the
permitting
authority.
Compliance
Assessment
ICR
Page
27
July
7,
2000
EPA
estimates
that
15
percent
(
1,008)
of
the
6,719
major
facilities
and
5
percent
(
2,723)
of
the
54,452
minor
facilities
will
violate
their
maximum
daily
discharge
limitations
for
which
a
24­
hour
report
is
required.
Of
these
permittees,
EPA
expects
the
written
report
submittal
requirement
to
be
waived
in
50
percent
of
the
cases.
Thus,
307
major
municipals,
198
major
nonmunicipals
439
minor
municipals,
and
922
minor
non­
municipals
are
expected
to
submit
written
reports
of
violations
of
the
maximum
daily
discharge
limit.
EPA
estimates
that
the
major
facilities
will
submit
an
average
of
2
reports
per
year
while
the
minors
will
submit
an
average
of
1
report
annually.
In
addition
to
the
major
and
minor
permittees,
EPA
expects
5
percent
of
the
49.5
storm
water
general
permittees
with
discharges
associated
with
industrial
activities
to
violate
their
maximum
daily
discharge
limits.
This
5
percent
is
expected
to
be
inclusive
of
the
10
percent
of
the
storm
water
general
permittees
with
coal
pile
runoff
effluent
limits
that
were
estimated
in
the
previous
ICR
to
be
expected
to
violate
their
maximum
daily
discharge
limits.
As
a
result,
2,185
such
permittees
will
be
required
to
provide
verbal
notice
of
the
violation,
of
which
50
percent,
or
1,093,
will
be
required
to
submit
written
reports.
As
shown
in
Exhibit
3,
the
total
annual
burden
associated
with
this
requirement
is
27,697
hours.

Other
Noncompliance
When
any
type
of
noncompliance
occurs
that
is
not
covered
by
standard
compliance
assessment
reports
(
i.
e.
DMRs,
compliance
schedule
reports,
24­
hour
reports
or
planned
changes),
the
permittee
is
still
required
to
report
noncompliance.
Usually,
a
permittee
makes
these
types
of
reports
when
conditions
other
than
those
described
above
cause
them
to
violate
the
conditions
of
their
permits.
EPA
estimates
the
average
burden
to
be
5
hours
per
response.
This
burden
represents
the
time
required
to
gather
the
information,
prepare
and
present/
conduct
the
verbal
notice,
and
prepare
and
submit
a
written
report.

Because
most
instances
of
NPDES
noncompliance
reporting
are
covered
by
other
requirements
of
this
ICR
and
by
the
NPDES/
Sewage
Sludge
Monitoring
Reports
ICR,
EPA
expects
very
few
respondents
to
be
affected
annually.
Approximately
2
percent
(
134)
of
the
6,719
major
facilities
and
1
percent
(
545)
of
the
54,452
minor
facilities
are
expected
to
submit
1
report
per
year.
Therefore,
at
5
hours
per
response,
the
total
annual
burden
associated
with
these
reports
is
670
hours
for
major
facilities
and
2,723
hours
for
minor
facilities.

In
addition,
EPA
anticipates
that
each
year
31
POTWs
and
10
PrOTWs
will
be
required
to
submit
an
average
of
one
noncompliance
report
per
year
regarding
sewage
sludge
permit
conditions
(
generally
noncompliance
with
pollutant
limitations).
The
Agency
assumes
that
the
burden
to
complete
these
reports
equals
5
hours
for
a
total
annual
burden
of
213
hours.
The
total
annual
burden
associated
with
other
noncompliance
reports
is
3,613
hours.

The
annual
average
responses
per
respondent
are
presented
in
Exhibit
4
and
the
total
annual
burden
for
all
three
types
of
noncompliance
reports
discussed
above
is
55,556
hours
and
is
summarized
in
Exhibit
5
below.
This
exhibit
does
not
include
the
respondent
burden
associated
with
SSO
and
CSO
reporting
which
can
be
found
in
Exhibit
7.
Compliance
Assessment
ICR
Page
28
July
7,
2000
6.
a.
4
Notice
of
Alternate
Level
of
Actual
Production
The
permitting
authority
may,
at
its
discretion,
apply
tiered
production­
based
effluent
limits
in
an
NPDES
permit.
Tiered
permit
limits
allow
facilities
to
operate
under
different
sets
of
limits
for
pollutants
based
on
varying
production
levels.
In
the
case
of
automotive
factories,
however,
a
reasonable
demonstration
by
the
permittee
for
the
requirement
for
tiered
limits
obligates
the
EPA
(
not
States)
to
grant
tiered
limits
to
the
industry.
Nevertheless,
every
facility
operating
under
tiered
limits
is
required
to
submit
a
notification
to
the
permitting
authority
if
it
intends
to
operate
at
a
production
level
higher
than
the
lowest
production
level
identified
in
the
permit.

No
burden
is
estimated
for
this
requirement
at
this
time
since
it
is
believed
that
there
are
very
few
applicable
facilities
that
change
production
levels
within
a
given
permit
cycle.

6.
a.
5
Section
308(
a)
Letters
As
discussed
in
Section
4.
b,
Section
308(
a)
of
the
CWA
gives
broad
discretion
to
permitting
authorities
to
request
information
from
a
permittee
above
and
beyond
routine
requirements.
This
burden
on
respondents
from
Section
308(
a)
letters
requesting
information
is
included
under
several
ICRs.
For
example,
a
Section
308(
a)
letter
may
be
sent
out
in
response
to
inadequate
information
contained
in
an
NPDES
permit
application.
Accordingly,
this
burden
is
reflected
in
the
Applications
ICR.
Section
308(
a)
letters
requesting
additional
information
pertaining
to
spills
of
oil
and
hazardous
substances,
however,
are
a
compliance­
related
activity
and
the
burden
associated
with
responding
to
this
type
of
Section
308(
a)
letter
is
reflected
in
this
NPDES/
Compliance
Assessment/
Certification
Information
ICR.
Activity/
Facility
Type
Total
Annual
Burden
(
Hrs.)

Unanticipated
Bypass/
Upset
Report
Major
Facilities
6,552
Minor
Facilities
17,694
Maximum
Daily
Violation
Report
Major
Facilities
8,068
Minor
Facilities
10,888
Storm
Water
Permittees
8,741
Other
Noncompliance
Reports
Major
Facilities
675
Minor
Facilities
2,725
Sludge­
only
POTWs
161
Sludge­
only
PrOTWs
52
Total
Annual
Respondent
Burden
55,556
Exhibit
5.
Respondent
Reporting
Burden
for
Noncompliance
Reports
Compliance
Assessment
ICR
Page
29
July
7,
2000
EPA
estimates
the
burden
associated
with
this
collection
to
be
8
hours
per
response.
This
estimate
represents
the
time
required
for
a
permittee
to
gather
existing
information;
consult
engineers,
lawyers,
etc.
and
prepare
a
short,
direct
report.

EPA
estimates
that
1,200
permittees
will
be
required
to
respond
to
a
Section
308(
a)
letter
each
year.
In
the
past,
virtually
all
respondents
have
been
non­
municipal
permittees
with
EPA
as
the
permitting
authority.
At
8
hours
per
response,
as
discussed
above,
this
is
equivalent
to
a
total
annual
respondent
burden
of
9,600
hours.

6.
a.
6
Certification
for
Exemption
From
Monitoring
and
Notification
of
Process
Changes
As
discussed
in
Section
4.
b,
the
effluent
limitations
guidelines
contain
provisions
that
allow
facilities
in
certain
industrial
categories
to
request
exemptions
from
monitoring
requirements.
Also,
the
effluent
limitations
guidelines
contain
provisions
for
one
category
(
pesticides
formulating,
packaging,
and
repackaging)
to
develop
a
pollution
prevention
plan.
Exhibit
6
provides
an
estimate
of
the
number
of
facilities
in
each
of
these
industrial
categories.
These
estimates
were
estimated
using
PCS
and
by
cross­
referencing
facility
SIC
code
data
with
CFR
category.
Each
certification
is
estimated
to
require
1
hour
to
prepare.

EPA
estimates
that
approximately
50
percent
of
the
eligible
electroplating
and
electrical
and
electronic
components
facilities
will
choose
to
submit
a
Total
Toxic
Organic
Certification
(
semi­
annually)
in
lieu
of
TTO
monitoring
and
that
75
percent
of
the
metal
finishing
facilities
will
choose
to
submit
this
(
semi­
annual)
TTO
certification.
Note,
at
this
time
there
are
no
known
electroplating
direct
discharging
facilities.
Type
of
Respondent
State
EPA
Total
Pesticides
Packaging
and
Repackaging
322
4
326
Aluminum
Forming
69
7
76
Coil
Coating
94
7
101
Can
Making
(
subcategory
of
coil
coating)
15
3
18
Porcelain
Enameling*
42
12
54
Pharmaceutical
Manufacturing
117
13
130
Pulp,
Paper,
and
Paperboard
326
35
361
Building
Paper
and
Board
Mills
144
30
174
Steam
Electric
1,221
151
1,372
Electroplating
0
0
0
Metal
Finishing
1,939
93
2,032
Electrical
and
Electronic
Components
79
7
86
TOTAL
4,368
362
4,730
*
Data
were
not
available
in
PCS
and
therefore
taken
from
the
previous
ICR
and
apportioned
between
State
and
EPA
based
on
the
ratio
of
delegated
to
non­
delegated
States.
Exhibit
6.
Facilities
with
Certification
Potential
Compliance
Assessment
ICR
Page
30
July
7,
2000
EPA
estimates
that
approximately
75
percent
of
the
aluminum
forming
facilities
and
coil
coating
facilities
will
choose
to
submit
an
annual
certification
requesting
exemption
from
cyanide
monitoring.

In
addition,
EPA
estimates
that
for
can
making
facilities
(
one
of
the
subcategories
within
coil
coating
category),
that
75
percent
of
the
can
making
facilities
will
choose
to
submit
notification
if
the
alloy
used
in
making
cans
contains
less
than
1
percent
manganese.

Additionally
of
the
eligible
pharmaceutical
facilities,
EPA
estimates
from
effluent
guideline
development
documents
that
approximately
40
percent
of
the
pharmaceutical
facilities
are
in
a
subcategory
that
potentially
use
cyanide
and
of
those
40
percent,
EPA
estimates
that
75
percent
of
those
facilities
will
choose
to
submit
a
certification
once
every
permit
cycle
requesting
exemption
from
monitoring.

EPA
estimates
that
50
percent
of
the
porcelain
enameling
facilities
will
choose
to
submit
an
annual
certification
requesting
exemption
from
chromium
monitoring.

In
the
pulp,
paper,
and
paperboard
category,
EPA
estimates
from
effluent
guideline
development
documents
that
approximately
80
percent
of
the
pulp
and
paper
facilities
use
a
chlorine
free
process
and
are
eligible
to
choose
an
alternative
monitoring
program.
These
facilities
may
certify
once
every
permit
cycle
that
their
process
does
not
use
chlorophenolic
biocides
and
EPA
estimates
that
of
these
80
percent
eligible,
that
75
percent
will
choose
to
certify.
Similarly,
for
the
builders'
paper
and
board
mills
category,
EPA
estimates
that
75
percent
of
the
facilities
will
certify.

EPA
estimates
that
approximately
75
percent
of
the
facilities
in
the
steam
electric
category
will
choose
to
provide
a
demonstration
and
certification
requesting
exemption
from
monitoring
requirements.

Lastly,
in
the
pesticide
formulating
and
packaging
category,
EPA
estimates
that
50
percent
of
the
facilities
will
choose
to
submit
an
annual
certification
to
use
pollution
prevention
alternatives.
As
part
of
this
certification,
each
facility
must
develop
a
pollution
prevention
plan.
As
in
the
previous
ICR,
this
ICR
estimates
that
one
third
of
these
facilities
will
develop
a
pollution
prevention
plan
on
an
annual
basis
and
that
each
plan
will
take
20
hours
to
develop.
EPA
estimates
that
there
will
be
a
total
annual
burden
of
5,793
hours
for
these
activities.

6.
a.
7
SSO
and
Unpermitted
CSO
Reporting
In
1998,
EPA
conducted
an
evaluation
of
SSOs
and
gathered
information
on
the
number
and
frequency
of
SSOs
and
unpermitted
CSOs.
At
that
time,
EPA
developed
a
Summary
of
Revised
Burden
Estimate
for
SSO/
Unpermitted
CSO
Reporting
that
was
approved
by
OMB
in
March
1998.
This
revised
burden
summary
estimates
the
SSO
and
CSO
respondent
burdens
to
be
62,144
hours
and
5,184
hours,
respectively.
The
SSO
burden
is
based
on
an
estimated
41,087
SSO
events
per
year
and
the
associated
DMR,
24­
hour
and
5­
day
reports.
The
CSO
burden
is
based
on
an
estimated
3,840
events
per
year
and
the
associated
DMR,
24­
hour
and
5­
day
reports.
Compliance
Assessment
ICR
Page
31
July
7,
2000
For
further
explanation
of
the
assumptions
used
to
arrive
at
these
burden
estimates,
see
the
1998
Summary
of
Revised
Burden
Estimate
for
SSO/
Unpermitted
CSO
Reporting.
Note:
EPA
is
in
the
process
of
revising
these
burden
estimates
as
part
of
the
SSO
rulemaking
effort
and
associated
ICR.

6.
b
Estimating
Respondent
Costs
The
cost
imposed
on
permittees
to
the
requirements
discussed
in
this
ICR
is
a
function
of
the
burden
placed
on
them
for
recordkeeping
and
reporting
the
information
described
above
and
the
wages
of
a
typical
worker
performing
these
activities.

Estimates
of
government
and
respondent
costs
associated
with
this
information
collection
have
been
prepared
using
the
Federal
Salary
Table
2000­
GS
and
a
link
to
EPA's
ICR
page
on
the
Internet
at
http://
stats.
bls.
gov/
news.
release/
ecec.
toc.
htm.

!
This
ICR
estimates
the
average
annual
salary
for
a
Federal
employee
is
equivalent
to
a
GS­
9,
Step
10
and
a
salary
of
$
42,091.
At
2,080
labor
hours
per
year,
the
hourly
rate
is
$
20.24.
Overhead
costs
for
Federal
employees
are
expected
to
be
50
percent,
or
$
10.12,
yielding
a
total
hourly
rate
of
$
30.36.

!
This
ICR
estimates
the
State
employee
hourly
rate
based
on
wages
and
salary
values
for
State
and
local
government
workers
given
in
"
Table
3.
State
and
local
government,
by
selected
characteristics"
of
the
U.
S.
Department
of
Labor,
Bureau
of
Labor
Statistics,
http://
stats.
bls.
gov/
news.
release/
ecec.
t03.
htm.
This
table
provides
an
hourly
total
compensation
rate
for
all
workers
in
State
and
local
governments
of
$
28.00
per
hour
including
wages
and
salaries
as
well
as
total
benefits.

!
This
ICR
estimates
the
private
industry
hourly
rate
based
on
the
wages
and
salary
values
for
all
workers
in
private
industry
given
in
"
Table
5.
Private
Industry,
by
major
industry
group"
of
the
U.
S.
Department
of
Labor,
Bureau
of
Labor
Statistics
http://
stats.
bls.
gov/
news.
release/
ecec.
t05.
htm.
This
table
provides
an
hourly
compensation
rate
for
all
workers
in
goods
producing
industry
of
$
22.86
per
hour
including
wages
and
salaries
as
well
as
total
benefits.

!
This
ICR
estimates
the
municipal
POTW
employee
hourly
rate
based
on
wages
and
salary
values
for
State
and
local
government
workers
as
noted
in
"
Table
3.
State
and
local
government,
by
selected
characteristics"
of
the
U.
S.
Department
of
Labor,
Bureau
of
Labor
Statistics
http://
stats.
bls.
gov/
news.
release/
ecec.
t03.
htm.
This
table
provides
an
hourly
total
compensation
rate
for
all
workers
in
State
and
local
governments
of
$
28.00
per
hour
including
wages
and
salaries
as
well
as
total
benefits.
Compliance
Assessment
ICR
Page
32
July
7,
2000
Exhibit
7
shows
the
estimated
cost
to
recordkeeping
and
reporting
for
the
compliance
assessment
activities
discussed
in
this
ICR.
EPA
estimates
that
the
total
annual
cost
is
$
19,161,763
for
recordkeeping
and
$
3,884,689
for
reporting
for
a
total
respondent
cost
of
$
23,046,452.

6.
c
Estimating
Agency
Burden
and
Cost
Government
workers
must
enter
the
compliance
assessment
data
into
EPA's
Permit
Compliance
System
(
PCS)
and
file
the
data
in
the
permittee's
official
file.
In
some
cases,
the
government
must
also
perform
substantive
follow­
up.
The
compliance
assessment
requirements
accounted
for
in
this
ICR
affect
the
Federal
government
and
the
State
government,
depending
on
which
is
the
permitting
authority.
Three
States
are
currently
authorized
to
administer
State
sludge
management
programs.
In
addition,
EPA
expects
additional
States
to
obtain
full
or
partial
State
sludge
programs
during
the
life
of
this
ICR
or
an
annual
average
of
six
States
with
sludge
program
approval.
As
this
happens,
the
burden
should
remain
the
same,
but
some
of
it
will
shift
from
the
Federal
to
State
government.
The
costs
to
State
and
Federal
governments
associated
with
processing
and
analyzing
compliance
assessment
information
are
a
function
of
three
factors:
1)
the
number
of
compliance
reports
received
by
State
and
Federal
governments,
2)
the
time
it
takes
to
process
and
analyze
those
reports
and,
3)
the
salary
and
overhead
costs
associated
with
the
time
the
State
and
Federal
workers
spend
processing
and
analyzing
the
reports.

The
estimated
burden
and
costs
to
the
government
(
State
and
Federal)
for
handling
and
reviewing
compliance
assessment
information
discussed
in
this
ICR
are
presented
in
Exhibits
8
and
9.
EPA
estimates
that
the
government
will
spend
approximately
68,768
hours
reviewing
compliance
assessment
information
each
year.
Of
the
total
government
burden,
51,089
hours
will
be
spent
by
State
governments
and
17,679
hours
will
be
spent
by
the
Federal
government.

As
presented
in
Exhibit
9,
the
total
annual
government
cost
is
estimated
to
be
$
2,009,221.
Of
this
total
government
cost,
$
1,472,488
will
be
borne
by
State
governments
while
$
536,733
will
be
borne
by
the
Federal
government.

6.
c.
1
Recordkeeping
Recordkeeping
costs
for
the
government
are
incorporated
into
the
burden
for
each
of
the
components
discussed
below
and
are
not
reported
separately
in
this
ICR.

6.
c.
2
Compliance
Schedule
Reports
EPA
estimates
that
the
government
requires
0.25
hours
to
review
each
compliance
schedule
report
submitted
by
permittees
that
are
in
compliance
with
their
schedule.
See
Section
6
for
discussion
of
how
many
permittees
are
estimated
to
be
required
to
submit
compliance
schedules.
As
shown
in
Exhibit
8,
a
total
of
7,762
respondents
are
expected
to
submit
reports
each
year.
As
explained
in
Section
6,
a
respondent
is
expected
to
submit
an
average
of
1.5
reports
per
year
(
for
1.5
reports
per
year
at
0.25
hours
per
report
this
is
approximately
0.4
hours
per
year
per
respondent).
Of
these
7,762
facilities,
7,206
are
expected
to
report
to
State
governments
while
556
are
expected
to
report
to
the
Federal
government.
Compliance
Assessment
ICR
Page
33
July
7,
2000
Exhibit
7.
Annual
Respondent
Recordkeeping
and
Reporting
Cost
Item/
Type
of
Respondent
Total
Annual
Respondent
Burden
(
Hrs.)
(
A)
Respondent
Labor
Cost
Per
Hour
(
B)
Total
Annual
Respondent
Cost
[(
A)
x
(
B)]

Recordkeeping
Major
Municipal
Permittees
24,528
$
28.00
$
686,784
Major
Non­
Municipal
Permittees
15,786
$
22.86
$
360,868
Minor
Municipal
Permittees
21,078
$
28.00
$
590,184
Minor
Non­
Municipal
Permittees
44,264
$
22.86
$
1,011,875
Storm
Water
General
Permittees
 
Industrial
582,602
$
22.86
$
13,318,282
Storm
Water
General
Permittees
 
Construction
82,956
$
22.86
$
1,896,374
Other
General
Permittees
56,754
$
22.86
$
1,297,396
SUBTOTAL
827,968
$
19,161,763
Compliance
Schedule
Reports
Major
Municipal
Permittees
3,449
$
28.00
$
96,572
Major
Non­
Municipal
Permittees
2,220
$
22.86
$
50,749
Minor
Municipal
Permittees
988
$
28.00
$
27,664
Minor
Non­
Municipal
Permittees
2,075
$
22.86
$
47,435
Sludge
Permit
Conditions
Compliance
Schedule
Reports
POTWs
150
$
28.00
$
4,200
PrOTWs
48
$
22.86
$
1,097
SUBTOTAL
8,930
$
227,717
Noncompliance
Reports
Unanticipated
Bypass/
Upset
Report
Verbal
Reports
Major
Municipal
Permittees
3,065
$
28.00
$
85,820
Major
Non­
Municipal
Permittees
1,975
$
22.86
$
45,149
Minor
Municipal
Permittees
4,390
$
28.00
$
122,920
Minor
Non­
Municipal
Permittees
9,220
$
22.86
$
210,769
Written
Reports
Major
Municipal
Permittees
920
$
28.00
$
25,760
Major
Non­
Municipal
Permittees
592
$
22.86
$
13,533
Minor
Municipal
Permittees
1,318
$
28.00
$
36,904
Minor
Non­
Municipal
Permittees
2,766
$
22.86
$
63,231
SUBTOTAL
24,246
$
604,086
Compliance
Assessment
ICR
Page
34
Exhibit
7.
Annual
Respondent
Recordkeeping
and
Reporting
Cost
Item/
Type
of
Respondent
Total
Annual
Respondent
Burden
(
Hrs.)
(
A)
Respondent
Labor
Cost
Per
Hour
(
B)
Total
Annual
Respondent
Cost
[(
A)
x
(
B)]

July
7,
2000
Maximum
Daily
Violation
Report
Verbal
Reports
Major
Municipal
Permittees
3,678
$
28.00
$
102,984
Major
Non­
Municipal
Permittees
2,370
$
22.86
$
54,178
Minor
Municipal
Permittees
2,634
$
28.00
$
73,752
Minor
Non­
Municipal
Permittees
5,532
$
22.86
$
126,462
Storm
Water
Permittees
6,555
$
22.86
$
149,847
Written
Reports
Major
Municipal
Permittees
1,228
$
28.00
$
34,384
Major
Non­
Municipal
Permittees
792
$
22.86
$
18,105
Minor
Municipal
Permittees
878
$
28.00
$
24,584
Minor
Non­
Municipal
Permittees
1,844
$
22.86
$
42,154
Storm
Water
Permittees
2,186
$
22.86
$
49,972
SUBTOTAL
27,697
$
676,422
Other
Noncompliance
Reports
Major
Municipal
Permittees
410
$
28.00
$
11,480
Major
Non­
Municipal
Permittees
265
$
22.86
$
6,058
Minor
Municipal
Permittees
880
$
28.00
$
24,640
Minor
Non­
Municipal
Permittees
1,845
$
22.86
$
42,177
Sludge
Permit
Conditions
 
Noncompliance
Reports
POTWs
161
$
28.00
$
4,508
PrOTWs
52
$
22.86
$
1,189
SUBTOTAL
3,613
$
90,052
Notice
of
Alternate
Level
of
Production
0
$
22.86
$
0
Section
308(
a)
Letters
9,600
$
28.00
$
268,800
Pollution
Prevention
Alternative
Pesticides
Packaging
and
Repackaging
1,080
$
22.86
$
24,689
Compliance
Assessment
ICR
Page
35
Exhibit
7.
Annual
Respondent
Recordkeeping
and
Reporting
Cost
Item/
Type
of
Respondent
Total
Annual
Respondent
Burden
(
Hrs.)
(
A)
Respondent
Labor
Cost
Per
Hour
(
B)
Total
Annual
Respondent
Cost
[(
A)
x
(
B)]

July
7,
2000
Certifications
Pesticides
Packaging
and
Repackaging
163
$
22.86
$
3,726
Aluminum
Forming
57
$
22.86
$
1,303
Coil
Coating
76
$
22.86
$
1,737
Can
Making
(
subcategory
of
coil
coating)
14
$
22.86
$
320
Porcelain
Enameling
27
$
22.86
$
617
Pharmaceutical
Manufacturing
39
$
22.86
$
892
Pulp,
Paper,
and
Paperboard
43
$
22.86
$
983
Building
Paper
and
Board
Mills
131
$
22.86
$
2,995
Steam
Electric
1,029
$
22.86
$
23,523
Electroplating
0
$
22.86
$
0
Metal
Finishing
3,048
$
22.86
$
69,677
Electrical
and
Electronic
Components
86
$
22.86
$
1,966
SUBTOTAL
4,713
$
107,739
SSO
Reporting
62,144
$
28.00
$
1,740,032
Unpermitted
CSO
Reporting
5,184
$
28.00
$
145,152
TOTAL
975,175
$
23,046,452
Exhibit
8.
Annual
Burden
to
State
and
Federal
Governments
as
Users
of
Data
Item/
Type
of
Respondent
Respondents
per
Year
Hrs.
per
Response
Total
Annual
Burden
(
Hrs.)

State
Federal
State
Federal
Total
Recordkeeping
0
0
0
0
0
0
Compliance
Schedule
Reports
Total
Permittees
7,206
556
0.4
2,882
222
3,104
Noncomplying
Permittees
1,441
111
6.0
8,646
666
9,312
Sludge
Permittees
7
125
0.5
4
63
67
SUBTOTAL
8,654
792
11,532
951
12,483
Noncompliance
Reports
Unanticipated
Bypass/
Upset
Report
Verbal
Notification
3,532
198
1.0
3,532
198
3,730
Written
Report
2,649
149
2.0
5,298
298
5,596
Federal
Assistance
to
States
N/
A
132
2.0
N/
A
264
264
Immediate
Action
883
50
2.0
1,766
100
1,866
Additional
Federal
Review
N/
A
309
2.0
N/
A
618
618
SUBTOTAL
7,064
838
10,596
1,478
12,074
Compliance
Assessment
ICR
Page
36
Exhibit
8.
Annual
Burden
to
State
and
Federal
Governments
as
Users
of
Data
Item/
Type
of
Respondent
Respondents
per
Year
Hrs.
per
Response
Total
Annual
Burden
(
Hrs.)

State
Federal
State
Federal
Total
July
7,
2000
Maximum
Daily
Violation
Report
Verbal
Notification
3,532
198
1.0
3,532
198
3,730
Written
Report
1,766
99
2.0
3,532
198
3,730
Federal
Assistance
to
States
N/
A
88
2.0
N/
A
176
176
Immediate
Action
883
50
2.0
1,766
100
1,866
Additional
Federal
Review
N/
A
265
2.0
N/
A
530
530
SUBTOTAL
6,181
700
8,830
1,202
10,032
Other
Noncompliance
Reports
NPDES
Permittee
Reports
1,168
55
2.0
2,336
110
2,446
Additional
Federal
Review
N/
A
58
1.0
N/
A
58
58
Sludge
Permittee
Reports
2
39
0.3
1
12
13
SUBTOTAL
1,170
152
2,337
180
2,517
Notice
of
Alternate
Level
of
Production
0
0
0.0
0
0
0
Section
308(
a)
Letters
N/
A
1,200
8.0
0
9,600
9,600
Pollution
Prevention
Alternative
Pesticides
Packaging
and
Repackaging
N/
A
N/
A
N/
A
N/
A
N/
A
N/
A
Certifications
Pesticides
Packaging
and
Repackaging
161
2
1.0
161
2
163
Aluminum
Forming
52
5
1.0
52
5
57
Coil
Coating
71
5
1.0
71
5
76
Can
Making
(
subcategory
of
coil
coating)
11
2
1.0
11
2
13
Porcelain
Enameling
21
6
1.0
21
6
27
Pharmaceutical
Manufacturing
35
4
1.0
35
4
39
Pulp,
Paper,
and
Paperboard
196
21
0.2
39
4
43
Building
Paper
and
Board
Mills
108
23
1.0
108
23
131
Steam
Electric
916
113
1.0
916
113
1,029
Electroplating
0
0
2.0
0
0
0
Metal
Finishing
1,454
70
2.0
2,908
140
3,048
Electrical
and
Electronic
Components
40
4
2.0
80
8
88
SUBTOTAL
3,065
255
4,402
312
4,714
SSO
Reporting
N/
A
N/
A
N/
A
9,316
2,752
12,068
Unpermitted
CSO
Reporting
N/
A
N/
A
N/
A
4,076
1,204
5,280
TOTALS
26,134
3,937
51,089
17,679
68,768
Annual
burden
hours
reflect
revised
burden
estimates
for
SSOs
and
CSOs
from
1998
Summary
of
Revised
Burden
Estimates.
Respondent
totals
do
not
reflect
these
revised
burden
estimates.
Compliance
Assessment
ICR
Page
37
July
7,
2000
Exhibit
9.
Annual
Costs
to
State
and
Federal
Governments
as
Users
of
Data
Item/
Type
of
Respondent
Annual
Burden
(
Hrs.)
Agency
Labor
Cost/
Hour
Annual
Cost
State
Federal
State
Federal
State
Federal
Total
Recordkeeping
0
0
$
28.00
$
30.36
0
0
0
Compliance
Schedule
Reports
Total
Permittees
2,882
222
$
28.00
$
30.36
80,696
6,740
87,436
Non­
complying
Permittees
8,646
666
$
28.00
$
30.36
242,088
20,220
262,308
Sludge
Permittees
4
63
$
28.00
$
30.36
112
1,913
2,025
SUBTOTAL
11,532
951
$
28.00
$
30.36
322,896
28,873
351,769
Noncompliance
Reports
Unanticipated
Bypass/
Upset
Report
Verbal
Notification
3,532
198
$
28.00
$
30.36
98,896
6,011
104,907
Written
Report
5,298
298
$
28.00
$
30.36
148,344
9,047
157,391
Federal
Assistance
to
States
N/
A
264
$
28.00
$
30.36
N/
A
8,015
8,015
Immediate
Action
1,766
100
$
28.00
$
30.36
49,448
3,036
52,484
Additional
Federal
Review
N/
A
618
$
28.00
$
30.36
N/
A
18,762
18,762
SUBTOTAL
10,596
1,478
$
28.00
$
30.36
296,688
44,871
341,559
Maximum
Daily
Violation
Report
Verbal
Notification
3,532
198
$
28.00
$
30.36
98,896
6,011
104,907
Written
Report
3,532
198
$
28.00
$
30.36
98,896
6,011
104,907
Federal
Assistance
to
States
N/
A
176
$
28.00
$
30.36
N/
A
5,343
5,343
Immediate
Action
1,766
100
$
28.00
$
30.36
49,448
3,036
52,484
Additional
Federal
Review
N/
A
530
$
28.00
$
30.36
N/
A
16,091
16,091
SUBTOTAL
8,830
1,202
$
28.00
$
30.36
247,240
36,492
283,732
Other
Noncompliance
Reports
NPDES
Permittee
Reports
2,336
110
$
28.00
$
30.36
65,408
3,340
68,748
Additional
Federal
Review
N/
A
58
$
28.00
$
30.36
N/
A
1,761
1,761
Sludge
Permittee
Reports
1
12
$
28.00
$
30.36
28
364
392
SUBTOTAL
2,337
180
$
28.00
$
30.36
65,436
5,465
70,901
Notice
of
Alternate
Level
of
Production
0
0
$
28.00
$
30.36
0
0
0
Section
308(
a)
Letters
N/
A
9,600
$
28.00
$
30.36
0
291,456
291,456
Pollution
Prevention
Alternative
Pesticides
Packaging
and
Repackaging
N/
A
N/
A
$
28.00
$
30.36
N/
A
N/
A
N/
A
Compliance
Assessment
ICR
Page
38
Exhibit
9.
Annual
Costs
to
State
and
Federal
Governments
as
Users
of
Data
Item/
Type
of
Respondent
Annual
Burden
(
Hrs.)
Agency
Labor
Cost/
Hour
Annual
Cost
State
Federal
State
Federal
State
Federal
Total
July
7,
2000
Certifications
Pesticides
Packaging
and
Repackaging
161
2
$
28.00
$
30.36
4,888
61
4,949
Aluminum
Forming
52
5
$
28.00
$
30.36
1,579
152
1,731
Coil
Coating
71
5
$
28.00
$
30.36
2,156
152
2,308
Can
Making
(
subcategory
of
coil
coating)
11
2
$
28.00
$
30.36
334
61
395
Porcelain
Enameling
21
6
$
28.00
$
30.36
638
182
820
Pharmaceutical
Manufacturing
35
4
$
28.00
$
30.36
1,063
121
1,184
Pulp,
Paper,
and
Paperboard
39
4
$
28.00
$
30.36
1,184
121
1,305
Building
Paper
and
Board
Mills
108
23
$
28.00
$
30.36
3,279
698
3,977
Steam
Electric
916
113
$
28.00
$
30.36
27,810
3,431
31,241
Electroplating
0
0
$
28.00
$
30.36
0
0
0
Metal
Finishing
2,908
140
$
28.00
$
30.36
88,287
4,250
92,537
Electrical
and
Electronic
Components
80
8
$
28.00
$
30.36
2,429
243
2,672
SUBTOTAL
4,402
312
133,647
9,472
143,119
SSO
Reporting
9,316
2,752
$
28.00
$
30.36
282,834
83,551
366,385
Unpermitted
CSO
Reporting
4,076
1,204
$
28.00
$
30.36
123,747
36,553
160,300
TOTALS
51,089
17,679
1,472,488
536,733
2,009,221
6.
c.
2
Compliance
Schedule
Reports
EPA
estimates
that
the
government
requires
0.25
hours
to
review
each
compliance
schedule
report
submitted
by
permittees
that
are
in
compliance
with
their
schedule.
See
Section
6
for
discussion
of
how
many
permittees
are
estimated
to
be
required
to
submit
compliance
schedules.
As
shown
in
Exhibit
8,
a
total
of
7,762
respondents
are
expected
to
submit
reports
each
year.
As
explained
in
Section
6,
a
respondent
is
expected
to
submit
an
average
of
1.5
reports
per
year
(
for
1.5
reports
per
year
at
0.25
hours
per
report
this
is
approximately
0.4
hours
per
year
per
respondent).
Of
these
7,762
facilities,
7,206
are
expected
to
report
to
State
governments
while
556
are
expected
to
report
to
the
Federal
government.

According
to
the
Quarterly
Noncompliance
Report
(
QNCR),
approximately
20
percent
of
permittees
that
submit
these
reports
are
not
in
compliance
with
their
scheduled
milestones.
EPA
estimates
that
the
government
requires
4
hours
to
review
and
conduct
follow­
up
activities
(
phone
calls,
letters)
for
each
report
submitted
by
permittees
that
are
not
in
compliance
with
their
schedule
milestones
(
for
1.5
reports
per
year
this
equals
6
hours
per
year
per
respondent).

EPA
expects
100
POTWs
and
32
privately
owned
treatment
works,
for
a
total
of
132
facilities,
to
report
compliance
schedule
progress.
Each
facility
is
expected
to
submit
an
average
Compliance
Assessment
ICR
Page
39
July
7,
2000
of
2
reports
per
year
under
40
CFR
Part
503.
Each
report
is
expected
to
take
0.25
hours
to
review
and
process.

Exhibit
8
shows
that
the
total
annual
burden
to
the
State
government
for
compliance
schedule
reporting
activities
is
11,532
hours
while
the
total
annual
burden
to
the
Federal
government
is
951
hours.
Exhibit
9
shows
that
the
costs
to
State
and
Federal
governments
for
compliance
schedule
activities
are
$
322,896
and
$
28,873,
respectively.

6.
c.
3
Noncompliance
Reports
24­
Hour
Report
of
Unanticipated
Upset
or
Bypass
EPA
estimates
that
1
hour
is
required
for
the
government
to
receive
and
process
each
verbal
noncompliance
notice,
and
2
hours
are
required
for
the
government
to
receive
and
process
each
written
noncompliance
report.
As
discussed
in
Section
6.1,
approximately
75
percent
of
those
permittees
that
must
submit
verbal
reports
are
also
required
to
submit
written
reports.
EPA
anticipates
that
the
remaining
25
percent
will
have
their
written
report
requirement
waived.
In
addition,
it
is
estimated
that
2
hours
are
required
for
immediate
action
to
mitigate
the
problem
for
25
percent
of
the
responses.
Also,
an
additional
Federal
burden
is
calculated
(
estimated
to
be
5
percent
of
the
number
of
written
reports
submitted
to
States)
for
a
portion
of
the
responses
that
are
submitted
to
States
which
need
Federal
assistance.

It
is
estimated
that
5
percent
(
132)
of
the
2,649
written
responses
submitted
to
States
will
incur
an
additional
2
hours
of
Federal
burden
per
response.
In
addition,
5
percent
(
309)
of
the
6,181
verbal
and
written
State
responses
will
need
2
hours
additional
Federal
review
time
after
the
State
response.

As
shown
in
Exhibit
8,
3,532
State
permittees
and
198
Federal
permittees
are
expected
to
submit
one
verbal
report
of
noncompliance
per
year.
Of
these,
75
percent
(
2,649
State
and
149
Federal)
are
expected
to
submit
a
written
report.
In
addition,
933
respondents
(
883
State
and
50
Federal)
are
expected
to
require
immediate
action
to
mitigate
a
problem.

As
shown
in
Exhibit
8,
the
resulting
annual
burden
to
State
and
Federal
governments
are
10,596
and
1,478
hours,
respectively.
As
shown
in
Exhibit
9,
the
annual
costs
to
State
and
Federal
governments
are
$
247,240
and
$
36,492,
respectively.

24­
Hour
Report
of
Violation
of
Maximum
Daily
Discharge
EPA
estimates
that
1
hour
is
required
for
the
government
to
receive
and
process
each
verbal
violation
notice
and
2
hours
are
required
to
receive
and
process
each
written
violation
report.
As
mentioned
earlier,
in
50
percent
of
the
cases
the
requirement
for
the
written
report
is
waived.
In
addition,
2
hours
are
estimated
for
immediate
action
to
mitigate
the
problem
for
25
percent
of
the
verbal
and
written
responses.
Compliance
Assessment
ICR
Page
40
July
7,
2000
As
shown
in
Exhibit
8,
State
governments
and
the
Federal
government
will
handle
verbal
notices
of
violation
from
3,532
and
198
respondents,
respectively.
Fifty
percent
of
the
respondents
submitting
verbal
notices
of
violation
will
be
required
to
submit
written
reports
resulting
in
States
and
the
Federal
government
handling
1,766
and
99
written
responses,
respectively.

In
addition,
a
total
of
883
and
50
respondents
will
require
immediate
action
to
mitigate
a
problem
from
States
or
the
Federal
government,
respectively.
Also,
an
additional
Federal
burden
is
calculated
for
a
portion
of
the
responses
that
are
submitted
to
States
which
need
Federal
assistance.
It
is
estimated
that
5
percent
of
written
responses
submitted
to
States,
or
88
responses,
will
require
an
additional
2
hours
of
Federal
burden
per
response.
In
addition,
265,
or
5
percent
of
the
total
responses
submitted
to
States
(
3,532
verbal
and
1,766
written)
will
result
in
2
hours
of
additional
Federal
review
time
after
the
State
response.

As
shown
in
Exhibit
8,
annual
burden
from
this
activity
to
State
governments
and
Federal
government
is
8,830
and
1,202
hours,
respectively.
As
shown
in
Exhibit
9,
the
annual
costs
to
State
and
Federal
governments
are
$
247,240
and
$
36,492,
respectively.

Other
Noncompliance
It
is
estimated
that
an
average
of
2
hours
is
required
for
the
government
to
receive
and
process
each
report.
EPA
expects
2
percent
(
134)
of
the
6,719
major
permittees
and
1
percent
(
545)
of
the
54,452
minor
permittees
to
submit
1
report
per
year.
As
shown
in
Exhibit
8,
this
results
in
States
and
the
Federal
governments
handling
1,168
and
55
annual
responses,
respectively.
Also,
2
hours
are
required
for
additional
Federal
assistance
to
5
percent
(
58)
of
the
1,168
State
responses.

In
addition,
EPA
estimates
that
21
POTWs
and
1
PrOTW,
or
22
total
facilities,
will
be
required
to
submit
noncompliance
reports
regarding
noncompliance
with
sewage
sludge
regulations.
It
is
estimated
that
these
reports
will
be
submitted
once
per
year.
Each
report
is
expected
to
take
0.25
hours
to
review
and
process
resulting
in
an
annual
burden
of
5.5
hours.

Exhibit
8
shows
that
the
estimated
annual
burden
for
this
activity
for
States
and
Federal
governments
are
2,337
and
180
hours,
respectively.
Exhibit
9
shows
that
the
estimated
annual
costs
to
States
and
the
Federal
governments
for
this
activity
are
$
65,436
and
$
5,465,
respectively.

Exhibit
10
presents
the
total
annual
burden
from
noncompliance
reports
to
the
State
and
Federal
governments.
These
numbers
do
not
include
the
burden
associated
with
SSO
and
CSO
reporting
which
can
be
found
in
Exhibit
8.

6.
c.
4
Notice
of
Alternative
Level
of
Actual
Production
As
discussed
earlier,
EPA
expects
no
burden
to
respondents
from
this
requirement.
Compliance
Assessment
ICR
Page
41
July
7,
2000
6.
c.
5
Section
308(
a)
Letters
The
Federal
government
is
the
sole
recipient
of
each
of
these
responses.
It
is
estimated
that
8
hours
are
required
for
the
Federal
government
to
issue
the
letter,
review
the
response,
and
evaluate
the
need
for
additional
enforcement
action
for
each
response.
It
is
expected
that
1,200
letters
will
be
processed
annually.
This
will
result
in
an
annual
burden
of
9,600
hours
and
$
291,456
in
costs
to
the
Federal
government.

6.
c.
6
Certification
for
Exemption
From
Monitoring
and
Notification
of
Process
Changes
Review
of
certifications
are
estimated
to
take
1
hour
per
certification
and
occur
annually
except
for
pulp,
paper,
and
paperboard
facilities
which
are
required
to
submit
certifications
once
per
permit
cycle
and
electroplating,
metal
finishing,
and
electric
and
electronic
components
facilities
that
must
submit
semiannual
certifications.
The
certification,
pollution
prevention
alternative,
and
process
change
activities
are
estimated
to
involve
3,065
annual
responses
to
States
and
255
annual
responses
to
the
Federal
government
resulting
in
a
total
annual
burden
of
4,402
hours
for
the
States
and
312
hours
for
the
Federal
government.
The
costs
to
State
and
Federal
governments
are
$
133,647
and
$
9,472,
respectively.

6.
c.
7
SSO
and
Unpermitted
CSO
Reporting
The
Summary
of
Revised
Burden
Estimate
for
SSO/
Unpermitted
CSO
Reporting
estimates
the
government
burden
associated
with
SSOs
and
CSOs
to
be
12,068
hours
and
5,280
Activity/
Facility
Type
Total
Annual
Burden
(
Hrs.)

Unanticipated
Bypass/
Upset
Report
NPDES
Facilities
(
State)
10,596
NPDES
Facilities
(
Federal)
1,478
Maximum
Daily
Violation
Report
NPDES
Facilities
(
State)
8,830
NPDES
Facilities
(
Federal)
1,202
Other
Noncompliance
Reports
NPDES
Facilities
(
State)
2,337
NPDES
Facilities
(
Federal)
168
Sludge
Facilities
(
State)
1
Sludge
Facilities
(
Federal)
12
Total
Annual
Government
Burden:

State
Government
21,763
Federal
Government
2,860
TOTAL
24,623
Exhibit
10.
State
and
Federal
Burden
for
Noncompliance
Reports
Compliance
Assessment
ICR
Page
42
July
7,
2000
hours,
respectively.
The
SSO
burden
is
based
on
an
estimated
41,087
SSO
events
per
year
where
95
percent
of
the
reports
are
included
as
part
of
DMR
reporting
and
5
percent
require
24­
hour
verbal
reports.
In
addition,
a
portion
of
these
events
require
written
5­
day
reports,
immediate
action,
and
additional
review.
The
CSO
burden
is
based
on
an
estimated
3,840
events
per
year
potentially
requiring
DMR
reporting,
verbal
and
written
reports,
immediate
actions,
and
additional
review.
Government
burden
hours
have
been
apportioned
in
Exhibit
8
between
the
State
and
Federal
governments
based
on
the
number
of
delegated
(
44)
to
non­
delegated
(
13)
States.

6.
d
Estimating
the
Respondent
Universe
and
Burden
Hours
and
Costs
Exhibit
11
presents
the
figures
for
total
annual
burden
and
costs
to
respondents
and
the
State
government.
It
summarizes
burden
and
cost
calculations
in
Exhibits
2,
4,
7,
8,
9,
and
10.

Exhibit
11
.
Respondent
Universe
and
Burden
and
Costs
Annual
Burden
(
Hrs.)
Annual
Costs
Recordkeeping
827,968
19,161,763
Reporting
147,207
3,884,689
Total
for
Respondents
975,175
23,046,452
State
Governments
51,089
1,472,488
TOTAL
1,026,264
24,518,940
The
annual
burden
for
respondents
is
975,175
hours
and
the
annual
burden
to
State
governments
is
51,089
hours.

6.
e
Bottom
Line
Burden
Hours
and
Costs
The
total
annual
bottom
line
burden
hours
and
costs
for
respondents,
State
and
Federal
governments
are
1,043,943
burden
hours,
and
$
25,055,673
respectively.

Annual
Burden
(
Hrs.)
Annual
Costs
Recordkeeping
827,968
19,161,763
Reporting
147,207
3,884,689
Total
for
Respondents
975,175
23,046,452
State
Governments
51,089
1,472,488
Federal
Governments
17,679
536,733
TOTAL
1,026,264
24,518,940
Exhibit
12.
Bottom
Line
Annual
Burden
and
Costs
to
Respondents
and
Government
Compliance
Assessment
ICR
Page
43
July
7,
2000
6.
f
Reasons
for
Change
in
Burden
Exhibit
13
presents
the
change
in
respondent
burden
for
each
information
item
covered
by
this
ICR.
As
shown
in
Exhibit
13,
the
revised
ICR
estimates
an
increase
in
burden
from
744,865
hours
to
1,026,264
hours,
or
38
percent.
The
primary
reason
for
the
increase
is
due
to
better
estimates
of
and
the
increased
number
of
general
permittees
required
to
keep
records
and
report
compliance
activities.
The
changes
in
respondent
burden
are
described
below
for
each
activity.

!
Recordkeeping.
This
burden
increase
of
27
percent
from
the
previous
ICR
represents
an
increase
in
the
number
of
general
permits,
the
growth
of
the
storm
water
general
permitting
program
and
the
resultant
improvements
in
estimates
of
the
number
of
permittees
subject
to
its
specific
recordkeeping
and
inspection
requirements.
In
addition,
quarterly
examinations
required
to
be
conducted
by
storm
water
general
permittees
with
discharges
associated
with
industrial
activity
were
not
reflected
in
the
previous
ICR.

!
Compliance
Schedule
Reports.
The
burden
associated
with
this
requirement
is
essentially
unchanged
from
the
previous
ICR.

!
Noncompliance
Reports.
The
burden
on
respondents
for
submitting
noncompliance
reports
increased
by
approximately
16
percent.
This
was
due
in
part
to
better
estimates
of
the
number
of
permittees
in
general
and
more
precise
counts
of
the
Item/
Type
of
Respondent
Previous
ICR
(
A)
Current
ICR
(
B)
Change
(
C)
(
B
 
A)
Percent
Change
(
C
÷
A)

Recordkeeping
652,873
827,968
175,095
26.82%

Compliance
Schedule
Reports
8,949
8,930
­
19
­
0.21%

Noncompliance
Reports
Unanticipated
Bypass/
Upset
Report
24,139
24,246
107
0.44%

Maximum
Daily
Violation
Report
18,858
27,697
8,839
46.87%

Other
Noncompliance
Reports
3,596
3,613
17
0.47%

Notice
of
Alternate
Level
of
Production
0
0
0
0.00%

Section
308(
a)
Letters
9,600
9,600
0
0.00%

Pollution
Prevention
Alternative
171
1,080
909
531.58%

Certifications
and
Notice
of
Process
Changes
399
4,713
4,314
1,081.20%

SSO
Reporting*
0
62,144
N/
A
100.00%

Unpermitted
CSO
Reporting*
0
5,184
N/
A
100.00%

Burden
to
State
Governments
as
Users
of
Data
26,280
51,089
24,809
94.40%

TOTAL
744,865
1,026,264
281,399
37.78%

*
Previous
ICR
did
not
separately
account
for
SSO
and
CSO
burden,
which
was
incorporated
in
1998.
Exhibit
13.
Change
in
Annual
Respondent
and
State
Burden
Compliance
Assessment
ICR
Page
44
July
7,
2000
number
of
storm
water
permittees
estimated
to
be
required
to
submit
maximum
daily
violation
reports.

!
Notice
of
Alternate
Level
of
Production.
No
burden
is
associated
with
this
requirement.

!
Section
308(
a)
Letters.
The
burden
associated
with
this
requirement
did
not
change.

!
Pollution
Prevention
Alternative.
A
532
percent
increase
in
the
burden
is
estimated
to
be
associated
with
the
pollution
prevention
alternative
for
exemption
from
monitoring.
This
increase
is
due
to
the
availability
through
PCS
of
better
estimates
of
the
number
of
facilities
for
which
this
option
may
apply.
EPA
estimates,
however,
that
there
is
no
real
change
in
burden
from
this
activity.

!
Certification
for
Exemption
From
Monitoring
and
Notification
of
Process
Changes.
A
1,081
percent
increase
in
burden
is
estimated
to
be
associated
with
certifications
for
exemptions
from
monitoring.
This
increase
is
due
in
part
to
the
inclusion
of
three
industrial
categories
not
previously
included
as
eligible
for
this
certification
option,
as
well
as
the
availability
through
PCS
of
better
estimates
of
the
number
of
facilities
for
which
this
certification
may
apply.
EPA
estimates,
however,
that
there
is
no
real
change
in
burden
from
this
activity.

!
SSO
Reporting
and
Unpermitted
CSO
Reporting.
Changes
reflect
revised
burden
estimates
not
included
in
the
previous
ICR,
but
subsequently
developed
by
EPA
in
Summary
of
Revised
Burden
Estimate
for
SSO/
Unpermitted
CSO
Reporting
and
approved
by
OMB
in
1998.
These
numbers
reflect
information
gathered
at
that
time
about
the
number
and
frequency
of
SSOs
and
unpermitted
CSOs
and
are
currently
being
updated
as
part
of
the
SSO
ICR.

!
Change
in
State
Burden.
The
94
percent
difference
in
State
burden
is
the
result
of
an
increase
in
the
estimated
number
of
permittees
in
delegated
States
as
well
as
the
SSO
and
CSO
burden
not
included
as
part
of
the
previous
ICR.

6.
g
Burden
Statement
The
public
reporting
burden
for
collecting
information
is
estimated
to
be
an
average
of
2.15
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
6.0
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
Compliance
Assessment
ICR
Page
45
July
7,
2000
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.
