INFORMATION
COLLECTION
REQUEST
FOR
THE
NATIONAL
POLLUTANT
DISCHARGE
ELIMINATION
SYSTEM
(
NPDES)/
COMPLIANCE
ASSESSMENT/
CERTIFICATION
INFORMATION
EPA
ICR
No.
1427.07
OMB
Control
No.
2040­
0110
FINAL
May
7,
2004
U.
S.
Environmental
Protection
Agency
Office
of
Wastewater
Management
1200
Pennsylvania
Avenue,
N.
W.
Washington,
D.
C.
20460
DRAFT
FINAL
Compliance
Assessment
ICR
Page
ii
March
26,
2004
TABLE
OF
CONTENTS
1.0
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
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1
1.
a
Title
of
the
Information
Collection
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1
1.
b
Short
Characterization/
Abstract
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1
2.0
NEED
FOR
AND
USE
OF
THE
COLLECTION
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4
2.
a
Need
and
Authority
for
the
Collection
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4
2.
a.
1
NPDES
Program
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4
2.
a.
2
Storm
Water
Program
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5
2.
a.
3
Sewage
Sludge
Program
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6
2.
a.
4
Effluent
Limitations
Guidelines
and
Standards
Certifications
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6
2.
b
Practical
Utility
of
the
Data
and
Users
of
the
Data
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7
3.0
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
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9
3.
a
Nonduplication
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9
3.
b
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
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10
3.
c
Consultations
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10
3.
d
Effects
of
Less
Frequent
Data
Collection
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10
3.
e
General
Guidelines
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11
3.
f
Confidentiality
and
Sensitive
Questions
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11
4.0
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
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12
4.
a
Respondents
and
SIC
Codes
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12
4.
b
Information
Requested
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12
4.
c
Respondent
Activities
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15
5.0
THE
INFORMATION
COLLECTED:
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
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17
5.
a
Agency
Activities
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17
5.
b
Collection
Methodology
and
Management
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17
5.
c
Small
Entity
Flexibility
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18
5.
d
Collection
Schedule
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18
5.
d.
1
Information
Collection
Activities
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18
5.
d.
2
Information
Collection
Schedule
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19
6.0
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
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21
6.
a
Estimating
Respondent
Burden
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21
6.
a.
1
Recordkeeping
of
Monitoring
and
Inspection
Data
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27
6.
a.
2
Compliance
Schedule
Reports
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28
6.
a.
3
Noncompliance
Reports
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28
6.
a.
4
Notice
of
Alternate
Level
of
Actual
Production
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31
6.
a.
5
Section
308(
a)
Letters
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31
6.
a.
6
Certification
for
Exemption
From
Monitoring
and
Notification
of
Process
Changes
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32
DRAFT
FINAL
Compliance
Assessment
ICR
Page
iii
March
26,
2004
6.
a.
7
SSO
and
Unpermitted
CSO
Reporting
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34
6.
a.
8
Certification
and
BMP
Plan
Development
Pursuant
to
40
CFR
Part
435
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34
6.
b
Estimating
Respondent
Costs
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36
6.
c
Estimating
Agency
Burden
and
Cost
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37
6.
c.
1
Recordkeeping
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38
6.
c.
2
Compliance
Schedule
Reports
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38
6.
c.
3
Noncompliance
Reports
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45
6.
c.
4
Notice
of
Alternative
Level
of
Actual
Production
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46
6.
c.
5
Section
308(
a)
Letters
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47
6.
c.
6
Certification
for
Exemption
From
Monitoring
and
Notification
of
Process
Changes
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47
6.
c.
7
SSO
and
Unpermitted
CSO
Reporting
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48
6.
c.
8
Certification
of
BMPs
Under
part
435
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48
6.
d
Estimating
the
Respondent
Universe
Burden
Hours
and
Costs
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48
6.
e
Bottom
Line
Burden
Hours
and
Costs
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49
6.
f
Reasons
for
Change
in
Burden
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49
6.
g
Burden
Statement
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51
LIST
OF
EXHIBITS
Exhibit
1.
Summary
of
Burden
and
Costs
to
Respondents
and
State
Government
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3
Exhibit
2.
Number
of
NPDES
Permits
Issued
by
EPA
and
the
States
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22
Exhibit
3.
Annual
Respondent
Reporting
and
Recordkeeping
Burden
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23
Exhibit
4.
Annual
Average
Responses
per
Respondent
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25
Exhibit
5.
Respondent
Reporting
Burden
for
Noncompliance
Reports
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31
Exhibit
6.
Facilities
with
Certification
Potential
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33
Exhibit
7.
Number
of
SBF
Facilities
Affected
by
ICR
Burden
Estimate
.
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34
Exhibit
8.
Annual
Respondent
Recordkeeping
and
Reporting
Cost
.
.
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39
Exhibit
9.
Annual
Burden
to
State
and
Federal
Governments
as
Users
of
Data
.
.
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41
Exhibit
10.
Annual
Costs
to
State
and
Federal
Governments
as
Users
of
Data
.
.
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43
Exhibit
11.
State
and
Federal
Burden
for
Noncompliance
Reports
.
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47
Exhibit
12
.
Respondent
Universe
and
Burden
and
Costs
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
48
Exhibit
13.
Bottom
Line
Annual
Burden
and
Costs
to
Respondents
and
Government
.
.
.
.
.
.
.
49
Exhibit
14.
Change
in
Annual
Respondent
and
State
Burden
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
50
DRAFT
FINAL
Compliance
Assessment
ICR
Page
1
1
Following
approval
of
this
ICR,
it
is
EPA's
intention
to
ultimately
transfer
the
burden
estimates
for
the
plan
development
and
the
certification
requirements
associated
with
several
effluent
limitations
guidelines
(
e.
g.,
OMB
Control
Nos.:
2040­
0202,
2040­
0207,
2040­
0235,
2040­
0239,
2040­
0242,
and
2040­
0243)
into
this
ICR.
Appropriate
documentation
and
forms
will
be
developed
as
that
incorporation
occurs.

March
26,
2004
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
document
is
entitled
Information
Collection
Request
(
ICR)
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
the
Enviromental
Protection
Agency
(
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
2000
ICR
entitled
Information
Collection
Request
for
the
National
Pollutant
Discharge
Elimination
System
(
NPDES)/
Compliance
Assessment/
Certification
Information
(
OMB
Control
No.
2040­
0110,
ICR
No.
1427.06).
This
ICR
also
incorporates
a
revised
burden
estimate
previously
approved
by
OMB
and
developed
to
adjust
the
ICR
to
more
accurately
reflect
sanitary
sewer
overflow
(
SSO)
reporting
and
unpermitted
combined
sewer
overflow
(
CSO)
reporting
requirements.
Finally,
the
ICR
incorporates
the
burden
estimated
for
plan
development
and
certification
requirements
in
the
ICR
for
Best
Management
Practices
Alternatives,
Effluent
Limitations
Guidelines
and
Standards,
Oil
and
Gas
Extraction
Point
Source
Category
(
40
CFR
Part
435),
EPA
ICR
No.
1953.01,
OMB
Control
No.
2040­
0230.1
This
ICR
was
prepared
according
to
guidance
contained
in
EPA's
February
1999
ICR
Handbook.
This
handbook
is
the
most
current
guidance
available
to
the
Agency
for
preparing
an
ICR,
and
it
follows
the
provisions
of
the
Paperwork
Reduction
Act
of
1995
and
related
Office
of
Management
and
Budget
(
OMB)
guidelines.

The
Clean
Water
Act
(
CWA)
(
33
U.
S.
C.
1251­
1387)
authorizes
EPA
to
issue
permits
for
the
discharge
of
pollutants
to
"
waters
of
the
United
States."
The
Act
also
authorizes
EPA
to
issue
permits
for
the
use
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.
DRAFT
FINAL
Compliance
Assessment
ICR
Page
2
March
26,
2004
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
obtain
NPDES
authority.
This
authority
enables
States
and
Tribes
to
issue
permits.
At
this
time,
46
States
(
45
States
and
1
U.
S.
territory)
have
obtained
NPDES
authority,
while
11
have
not.
None
of
the
556
Federally­
recognized
American
Indian
Tribes
have
obtained
NPDES
authority.
As
of
February
2004,
five
States
have
obtained
authority
to
operate
a
sewage
sludge
management
program
(
OK,
SD,
TX,
UT
and
WI).
In
States
or
Tribes
that
have
not
obtained
authority
for
these
programs,
EPA
issues
the
permits.
Because
some
permit
applications
are
processed
by
States
and
some
by
EPA,
this
ICR
calculates
government
burden
and
costs
for
both
States
and
EPA.

A
permitting
authority,
EPA,
a
State
or
a
Federally
recognized
Tribe,
collects
information
necessary
to
determine
a
permittee's
compliance
with
specific
permit
requirements
during
the
effective
term
of
a
given
permit.
Compliance
assessment
reporting
requirements
include
routine
submittals
(
e.
g.,
annual
certifications
and
reports
submitted
when
a
compliance
schedule
milestone
is
reached)
and
non­
routine
submittals
(
e.
g.,
required
when
certain
conditions
occur,
such
as
an
unanticipated
bypass).
NPDES
staff
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
States
associated
with
the
compliance
assessment
recordkeeping
and
reporting
requirements
of
this
ICR.

This
ICR
includes
burden
hours
and
costs
associated
with
sanitary
sewer
overflows
(
SSOs)
and
unpermitted
combined
sewer
overflows
(
CSOs)
originally
estimated
and
provided
to
OMB
in
the
1998
Summary
of
Revised
Burden
Estimates
for
SSO/
Unpermitted
CSO
Reporting.
This
ICR
does
not,
however,
include
an
estimate
of
the
number
of
respondents
associated
with
these
SSO/
unpermitted
CSO
estimates.
Rather,
the
estimates
are
based
on
a
national
estimate
of
the
number
of
responses
and
the
associated
burden
for
each.
The
numbers
reflect
an
increased
number
of
general
permittees
required
to
keep
records
for
the
first
time.
DRAFT
FINAL
Compliance
Assessment
ICR
Page
3
March
26,
2004
Recordkeeping
Number
of
Recordkeepers
390,352
All
permittees
except
sludge
facilities.

Annual
Respondent
Burden
(
hrs.)
1,568,158
Annual
Costs
($)
$
62,777,658
Reporting
(
w/
o
Part
435)

Number
of
Respondents
26,498
Annual
Respondent
Burden
(
hrs.)
141,122
Annual
Costs
($)
$
5,032,350
Part
435
Certification
(
new
requirement)
Facilities
that
pursue
certification
and
BMP
plan
development
pursuant
to
40
CFR
Part
435
to
control
nonaqueous
joint
fluids.
Number
of
Respondents
68
Annual
Respondent
Burden
(
hrs.)
53,516
Annual
Costs
for
Respondents
($)
$
1,635,944
State
Governments
(
45
States
and
1
Territory)

Annual
Burden
(
hrs.)
46,784
Annual
Costs
($)
$
1,526,226
Exhibit
1.
Summary
of
Burden
and
Costs
to
Respondents
and
State
Government
DRAFT
FINAL
Compliance
Assessment
ICR
Page
4
March
26,
2004
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
Title
40
of
the
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
permit
term.
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
the
above
conditions
on
a
consistent
basis.
Permittee
compliance
is
assessed
through
compliance
DRAFT
FINAL
Compliance
Assessment
ICR
Page
5
March
26,
2004
inspections,
review
of
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
12
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
actions.

A
permittee
generally
informs
the
permitting
authority
about
its
discharge
through
the
DMR.
The
DMR
lists
all
of
the
results
from
the
permittee's
self­
monitoring
of
required
pollutants.
The
permitting
authority
reviews
this
information
and
compares
it
with
permit
limits
to
determine
compliance
and/
or
if
there
is
a
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
their
respective
permits.
This
latter
reporting
requirement
is
intended
to
alert
the
permitting
authority
of
potential
health
or
environmental
risks
that
may
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
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
industrial
discharges
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
are
being
properly
implemented.
Although
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
individual
notices
of
intent
(
NOIs).
That
is,
they
reflect
permittees
regulated
via
general
permit,
rather
than
the
numbers
of
different
general
permits
themselves.

In
addition,
storm
water
permittees
with
discharges
associated
with
industrial
activity
are
required
to
perform
and
maintain
records
of
a
periodic
visual
examination
of
their
facilities.
DRAFT
FINAL
Compliance
Assessment
ICR
Page
6
March
26,
2004
Twenty­
nine
of
the
30
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
are
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,
as
previously
reported
in
the
1996
and
2000
ICRs
for
the
NPDES/
Compliance
Assessment/
Certification
Information
(
ICR
No.
1427.06
&
OMB
No.
2040­
0110)
and
revisions
to
the
1998
ICR
for
the
Standards
for
the
Use
or
Disposal
of
Sewage
Sludge
(
ICR
No.
0229.13
&
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
12
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
DRAFT
FINAL
Compliance
Assessment
ICR
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7
March
26,
2004
(
a
subpart
of
the
coil
coating
category)
(
40
CFR
465);
pharmaceutical
manufacturing
(
40
CFR
439);
pulp
and
paper
(
40
CFR
430);
builders'
paper
and
board
mills
(
40
CFR
431);
porcelain
enameling
(
40
CFR
456);
steam
electric
(
40
CFR
423);
and
oil
and
gas
extraction
(
40
CFR
Part
435).

The
effluent
limitations
guidelines
and
standards
for
these
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
pollutantspecific
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
and
2000
NPDES/
Compliance
Assessment/
Certification
Information
ICRs,
and
are
now
updated,
integrated,
and
reported
again
in
this
ICR.

For
the
Oil
and
Gas
Extraction
Point
Source
Category
(
40
CFR
435),
a
facility
can
elect
to
use
the
Best
Management
Practices
(
BMPs),
including
BMP
plan
development
and
certification
for
controlling
the
discharge
of
non­
aqueous
drilling
fluid
(
NAF)
cuttings
(
pursuant
to
Addendum
B,
Appendix
7,
Subpart
A,
Part
435),
in
lieu
of
the
retort
test
specified
in
Appendix
7
(
see
Appendix
7,
section
4
­
Procedures,
Item
9.)

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
a
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
assist
the
facility
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.
DRAFT
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Assessment
ICR
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March
26,
2004
!
Administrative
enforcement
action.
The
permitting
authority
may
pursue
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.

There
are
several
exceptions
to
the
general
flow
of
compliance
assessment
data
from
the
permittee
to
the
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
are
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
previously,
EPA
estimates
that
all
storm
water
permittees
will
be
subject
to
this
minimum
requirement.
DRAFT
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Compliance
Assessment
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Page
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2
Many
of
the
same
environmental
controls
promoted
as
part
of
a
BMP
Plan
currently
may
be
used
by
industry
in
storm
water
pollution
prevention
plans;
spill
prevention
and
response
plans
(
30
CFR
254);
Occupational
Safety
and
Health
Administration
(
OSHA)
safety
plans;
fire
protection
programs;
insurance
requirements;
federal,
state,
or
local
requirements;
or
standard
operating
procedures.
Additionally,
permittees
may
have
already
developed
pollution
prevention
programs
or
controls
such
as
source
reduction,
recycling,
and
reuse
which
may
be
similar
to
those
promoted
as
part
of
a
BMP
Plan.
When
a
BMP
issue
is
already
addressed
via
a
separate
regulatory
program,
the
BMP
Plan
is
expected
to
reference
those
efforts,
not
duplicate
them.
Where
operating
manuals,
standard
operating
plans,
or
other
documents
have
been
developed
to
address
other
regulatory
requirements
(
e.
g.,
OSHA,
RCRA,
etc.)
these
may
be
cross­
referenced
in
the
BMP
Plan.

March
26,
2004
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.

With
regard
to
use
of
BMPs
under
Part
435
to
control
NAFs,
EPA
has
examined
all
other
reporting
requirements
contained
in
the
Clean
Water
Act
and
40
CFR
Parts
122,
123,
124,
125,
501,
and
503.2
The
Agency
has
also
consulted
other
sources
of
information
to
determine
if
similar
or
duplicative
information
is
available
elsewhere.
There
are
no
additional
duplicative
reporting
requirements
as
the
BMPs
are
an
alternative
to
numeric
limitations
and
standards
and
the
BMP
Plan
format
allows
for
cross­
referencing
(
not
duplication)
of
similar
efforts.

3.
b
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
DRAFT
FINAL
Compliance
Assessment
ICR
Page
10
March
26,
2004
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
submitted
to
OMB.
EPA
issued
the
first
public
notice
for
the
revised
ICR
in
the
Federal
Register
on
December
9,
2003
(
68
FR
68618­
68619).
EPA
received
no
comments
on
this
notice.

3.
c
Consultations
EPA
has
solicited
public
comments
on
the
NPDES
Compliance
Assessment/
Certification
Information
ICR
numerous
times.
Most
recently,
EPA
consulted
with
its
contractor
to
evaluate
the
appropriateness
of
the
estimates
presented
in
this
ICR.
EPA
contractors
are
most
familiar
with
the
information
collected,
routinely
working
with
the
Agency
and
respondents
to
review
the
information
collected
as
part
of
this
ICR.
In
addition,
consistent
with
PRA
requirements,
EPA
has
public
noticed
this
ICR
prior
to
each
renewal.
Most
recently,
EPA
has
public
noticed
this
ICR
on
April
9,
1996,
March
23,
2000,
and
December
9,
2003.

The
Consolidated
Permit
Regulations
promulgated
in
May
1980,
from
which
the
paperwork
burden
of
this
ICR
originates,
and
the
subsequent
revisions
promulgated
in
September
1984
were
both
subject
to
60­
day
public
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.

With
regard
to
use
of
BMPs
under
Part
435
to
control
NAFs,
EPA
has
had
stakeholder
discussions
with
the
following
organizations
regarding
development
of
the
synthetic­
based
fluids
(
SBF)
regulation
and
SBF
BMP
alternative
requirements:
American
Petroleum
Institute
(
API),
National
Ocean
Industries
Association
(
NOIA),
U.
S.
Department
of
Energy
(
DOE),
U.
S.
Department
of
Interior's
Minerals
Management
Service
(
MMS),
Other
States;
and
Industry
Representatives.

3.
d
Effects
of
Less
Frequent
Data
Collection
The
information
collected
for
the
NPDES/
Compliance
Assessment/
Certification
ICR
is
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.
DRAFT
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Assessment
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March
26,
2004
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.

With
regard
to
use
of
BMPs
under
Part
435
to
control
NAFs,
the
Permittee
must
maintain
a
copy
of
the
BMP
Plan
and
related
documentation
(
e.
g.,
training
certifications,
summary
of
the
monitoring
results,
records
of
SBF­
equipment
spills,
repairs,
and
maintenance)
at
the
facility
and
must
make
the
BMP
Plan
and
related
documentation
available
to
the
State
NPDES
Permitting
Authority
and/
or
EPA,
upon
request.
Submission
of
the
BMP
Plan
and
related
documentation
shall
be
at
the
frequency
established
by
the
NPDES
permitting
authority
(
i.
e.,
Permit
monitoring
reports),
but
in
no
case
less
than
once
per
5
years.
As
NPDES
permits
are
normally
revised
every
five
years,
any
less
frequent
submission
of
the
BMP
Plan
and
related
documentation
would
lead
to
outdated
and
ineffective
BMP
Plans.

The
BMP
alternative
requires
re­
fresher
training
to
ensure
the
proper
implementation
of
the
BMP
Plan.
EPA
estimates
that
re­
fresher
training
will
take
place
twice
a
year
with
each
training
course
lasting
4
hours.
Less
frequent
review
of
the
BMP
Plan
will
lead
to
inadequate
implementation
of
the
associated
beneficial
BMPs.

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,
while
not
a
statutory
requirement,
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
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.
DRAFT
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March
26,
2004
4.0
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4.
a
Respondents
and
NAICS/
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,
any
industrial
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
industrial
category
(
North
American
Industry
Classification
System
(
NAICS)
code
221320,
Standard
Industrial
Classification
(
SIC)
code
495).
Other
common
permittee
classifications
include
electric
services
(
NAICS
2211,
SIC
491),
bituminous
coal
(
NAICS
212111
and
212112,
SIC
121),
chemical
manufacturing
(
NAICS
325,
SIC
28),
petroleum
refining
(
NAICS
324110,
SIC
291),
and
gold
ores
(
NAICS
21222,
SIC
104).
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)
(
NAICS
221320,
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.

The
respondents
using
BMPs
under
Part
435
to
control
NAFs
will
be
approximately
67
offshore
SBF
well
drilling
facilities.
These
operations
fall
under
NAICS
codes
211111
and
213111,
SIC
code
13.
Government
respondents
are
expected
to
include
representatives
from
EPA
Regions
4,
6,
9,
and
10,
who
will
revise
NPDES
permits
for
implementation
of
the
BMP
alternative.
The
EPA
Region
10
respondent
will
revise
the
general
NPDES
permit
for
the
coastal
State
waters
of
Cook
Inlet,
Alaska,
as
EPA
has
not
yet
delegated
NPDES
authority
to
the
State
of
Alaska.

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
DRAFT
FINAL
Compliance
Assessment
ICR
Page
13
March
26,
2004
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
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.
DRAFT
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March
26,
2004
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.

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
12
industrial
categories
(
12
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.
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Assessment
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March
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2004
8.
Synthetic­
Based
Fluids
(
SBF)
well
drilling
operations
that
elect
to
control
their
SBF­
cuttings
discharges
through
the
use
of
BMPs
are
required
to
prepare
the
following
information:
(
1)
certification
of
BMP
completion
and
a
copy
of
the
most
current
BMP
Plan;
(
2)
records
demonstrating
periodic
review
of
the
BMP
Plan
(
at
a
minimum
once
every
five
years);
(
3)
monitoring
reports
(
including
the
operation
of
monitoring
systems)
to
establish
equivalence
with
a
numeric
cuttings
retention
limitation
and
to
detect
leaks,
spills,
and
intentional
diversion;
and
(
4)
training
reports
to
document
re­
fresher
training
necessary
to
ensure
the
effectiveness
of
the
BMP
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
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.

!
SBF
well
drilling
operations
that
elect
to
use
BMPs
to
control
their
SBF
discharges
will
be
involved
in
the
following
tasks:

­­
BMP
Plan
Development,
Review,
and
Certification:
The
BMP
Plan
must
be
documented
in
narrative
form,
and
must
include
any
necessary
plot
plans,
drawings
or
maps,
and
must
be
developed
in
accordance
with
good
engineering
practices.
At
a
minimum,
the
BMP
Plan
must
contain
the
planning,
development
and
implementation,
and
evaluation/
reevaluation
components.

­­
Periodic
Review
and
Revision
of
BMP
Plan:
For
those
SBF­
cuttings
discharges
controlled
through
the
BMP
alternative,
the
Permittee
must
amend
the
BMP
Plan
whenever
there
is
a
change
in
the
facility
or
in
the
operation
of
the
facility
which
materially
increases
the
generation
of
SBF­
cuttings
or
their
release
or
potential
DRAFT
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Compliance
Assessment
ICR
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March
26,
2004
release
to
the
receiving
waters.
At
a
minimum
the
BMP
Plan
must
be
reviewed
once
every
five
years
and
amended
within
three
months
if
warranted.

­­
Additional
Monitoring
Reports:
Respondents
that
elect
to
use
the
BMP
alternative
to
control
SBF­
cuttings
discharges
will
be
required
to
document
additional
monitoring
activities.
These
additional
monitoring
activities
and
the
related
documentation
activities
are
required
to
demonstrate
a
well­
ordered
and
working
BMP
program.
Additional
monitoring
activities
include
establishing
equivalence
with
a
numeric
cuttings
retention
limitation
and
detecting
SBFcuttings
leaks,
spills,
and
intentional
diversions.

­­
Re­
fresher
Training:
Such
review
and
endorsement
may
be
performed
by
the
establishment
of
a
program
of
documented
initial
and
annual
refresher
training
of
drilling
equipment
operators,
maintenance
personnel,
and
other
technical
and
supervisory
personnel
who
have
responsibility
for
operating,
maintaining,
or
supervising
the
operation
and
maintenance
of
drilling
equipment.
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Assessment
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March
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2004
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
and
authorized
states
enter
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
manage
the
NPDES
program,
for
example,
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
1999
ICR
for
NPDES
and
Sewage
Sludge
Management
State
Program
Requirements
(
OMB
No.
2040­
0057,
ICR
No.
0168.07).

With
regard
to
use
of
BMPs
under
Part
435
to
control
NAFs,
permittees
must
maintain
records
(
e.
g.,
a
copy
of
the
BMP
Plan
and
related
documentation,
such
as
training
certifications,
summary
of
the
monitoring
results,
records
of
SBF­
cuttings
spills,
repairs,
and
maintenance)
as
described
in
40
CFR
435
at
the
facility
and
must
make
the
BMP
Plan
and
related
documentation
available
to
EPA,
the
NPDES
Permit
controlling
authority,
upon
request.
Submission
of
the
BMP
Plan
and
related
documentation
shall
be
at
the
frequency
established
by
the
NPDES
permit
control
authority
(
i.
e.,
permit
monitoring
reports),
but
in
no
case
less
than
once
per
five
years.
Review
of
monitoring
records
by
EPA,
the
permit
controlling
authority,
may
also
be
helpful
to
permit
writers
in
the
development
of
future
NPDES
permit
conditions.

5.
b
Collection
Methodology
and
Management
The
permitting
authority
will
ensure
the
accuracy
and
completeness
of
information
collected
by
reviewing
each
submittal
upon
receipt
and
is
responsible
for
ensuring
that
applicable
data
are
entered
into
PCS.

The
use
of
improved
information
technology
does
not
yet
appear
to
provide
additional
opportunities
for
reducing
burden
on
respondents
who
submit
information
on
an
as­
needed
basis
using
non­
standardized
formats.

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

With
regard
to
use
of
BMPs
under
Part
435
to
control
NAFs,
the
data
collection
and
management
methodology
for
SBF
well
drilling
operations
that
elect
to
use
BMPs
will
include
the
DRAFT
FINAL
Compliance
Assessment
ICR
Page
18
March
26,
2004
submission
of
the
BMP
Plan
to
the
NPDES
permit
control
authority
at
the
frequency
established
by
the
NPDES
permit
control
authority
(
i.
e.,
permit
monitoring
reports),
but
in
no
case
less
than
once
per
5
years.
The
NPDES
permit
control
authority
may
also
request
BMP
implementation
documentation
(
e.
g.,
training
certifications,
maintenance
records).
The
NPDES
permit
control
authority
will
also
review
cases
where
operators
are
unable
to
demonstrate
compliance
with
numeric
cuttings
retention
limitations.

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.

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.

With
regard
to
use
of
BMPs
under
Part
435
to
control
NAFs,
pursuant
to
section
605(
b)
of
the
Regulatory
Flexibility
Act,
the
EPA
Administrator
certified
that
this
final
regulation
will
not
have
a
significant
economic
impact
on
a
substantial
number
of
small
entities.

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;
DRAFT
FINAL
Compliance
Assessment
ICR
Page
19
March
26,
2004
!
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
12
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.

!
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.

!
Facilities
subject
to
40
CFR
Part
435
and
that
will
use
BMPs
to
control
NAFs
are
anticipated
to
occur
under
the
following
schedule:

­­
The
operator
shall
certify
that
its
BMP
Plan
is
complete,
on­
site,
and
available
upon
request
to
EPA
or
the
NPDES
Permit
controlling
authority.
This
certification
shall
identify
the
NPDES
permit
number
and
be
signed
by
an
authorized
representative
of
the
operator.
This
certification
shall
be
kept
with
the
BMP
Plan.
For
new
or
modified
NPDES
permits,
the
certification
shall
be
made
no
later
than
the
effective
date
of
the
new
or
modified
permit.
For
existing
NPDES
permits,
the
certification
shall
be
made
within
one
year
of
permit
issuance.

­­
Submission
of
records
to
the
permit
control
authority
demonstrating
periodic
review
of
the
BMP
Plan
are
due
at
a
minimum
once
every
5
years.
DRAFT
FINAL
Compliance
Assessment
ICR
Page
20
March
26,
2004
­­
Monitoring
reports
demonstrating
compliance
with
the
BMP
Plan
are
due
to
the
permit
control
authority
at
the
frequency
set
by
the
permit
control
authority
(
e.
g.,
monthly
or
annually)
and
may
be
requested
by
the
permit
control
authority
on
demand.

­­
Re­
fresher
training
certifications
demonstrating
compliance
with
the
BMP
Plan
are
due
to
the
permit
control
authority
at
the
frequency
set
by
the
permit
control
authority
(
e.
g.,
semi­
annually)
and
may
be
requested
by
the
permit
control
authority
on
demand.
DRAFT
FINAL
Compliance
Assessment
ICR
Page
21
3
The
facility
type
indicator
field
was
used
in
PCS
to
categorize
whether
a
facility
was
municipal
or
nonmunicipal
All
facilities
coded
as
"
M"
for
"
Municipal"
were
selected
as
Municipal
facilities.
All
facilities
coded
as
"
I"
for
"
Industrial,"
"
F"
for
"
Federal,"
or
"
O"
for
"
Other"
were
selected
as
Non­
Municipal
facilities.

4
Original
source,
Angelle
and
Scott,
2000.
Update
source,
www.
rigzone.
com
(
2/
23/
04).
EPA
estimates
that
all
42
deep
water
rigs
(
e.
g.,
semi­
submersible,
drill
ships)
will
use
SBFs
and
therefore
be
likely
candidates
to
use
BMPs.
EPA
also
estimates
that
14%
of
the
185
(
or
26)
total
shall
water
rigs
(
e.
g.,
jack­
ups,
platform
rigs)
will
use
SBFs
and
therefore
be
likely
candidates
to
use
BMPs.

March
26,
2004
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
2003).
3
Storm
water
general
permittee
estimates
(
discharges
associated
with
construction
activities)
were
based
on
estimates
from
EPA's
Economic
Analysis
conducted
in
association
with
the
1998
Storm
Water
Phase
II
Rule.
The
breakdown
of
State
versus
EPA
construction
numbers
is
based
on
2000
Census
Bureau
data,
indicating
that
94.7
percent
of
the
U.
S.
population
resides
in
NPDES
States
while
5.3
percent
resides
in
non­
NPDES
States.
This
rationale
was
used
in
the
July
1999
Storm
Water
ICR
(
Notice
of
Intent
for
Storm
Water
Discharges
Associated
with
Construction
Activitiy
under
a
NPDES
General
Permit
(
aka:
Construction
NOI
for
Stormwater),
ICR
#
1842.02,
OMB
#
2040­
0188).
Estimates
of
general
permittees
with
discharges
of
industrial
storm
water
were
pulled
from
the
August
1999
Applications
for
NPDES
Discharge
Permits
and
the
Sewage
Sludge
Management
Permits
ICR
(
ICR
#
2040­
0086,
OMB
#
0226.15)
and
then
scaled
up
to
reflect
likely
increases
in
facilities
over
the
past
five
years.
Census
Bureau
data
from
2000
were
once
again
used
to
determine
the
proportion
of
facilities
that
are
State
versus
EPA.
Finally,
the
number
of
"
other
non
storm
water
general
permittees"
were
obtained
from
PCS
(
December
2003).
Total
POTW
and
PrOTW
sludge­
only
permit
numbers
were
carried
forward
from
the
previous
ICR.
Numbers
have
been
apportioned
between
the
States
and
EPA
to
reflect
the
two
additional
States
(
for
a
total
of
5
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,
their
burden
is
believed
to
be
insignificant
because
of
the
manner
in
which
the
data
were
retrieved
from
PCS.
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.

With
regard
to
use
of
BMPs
under
Part
435
to
control
NAFs,
EPA
estimates
that
68
facilities
annually
will
be
affected
by
this
ICR.
4
These
SBF
wells
are
outlined
in
Exhibit
7.
Appendix
A
presents
all
of
the
input
data
and
assumptions
used
to
develop
the
ICR
burden
estimate.
Appendix
B
presents
eight
tables
of
burden
and
cost
estimates,
organized
into
three
DRAFT
FINAL
Compliance
Assessment
ICR
Page
22
March
26,
2004
categories:
Initial
Burden
and
Costs
(
Tables
1­
3);
Recurring
Annual
Burden
and
Costs
(
Tables
4­
6);
and
Summary
Burden
and
Costs
(
Tables
7­
8).

As
shown
in
Exhibit
3,
EPA
estimates
the
total
annual
burden
to
respondents
to
be
approximately
1,762,796
hours.
Of
this
total,
1,568,158
hours
are
for
recordkeeping,
while
194,638
hours
are
for
reporting.
Exhibit
3
provides
a
detailed
breakdown
of
hours
by
specific
record
or
report.
The
information
requirements
in
this
ICR
potentially
affect
392,602
respondents,
or
all
of
the
permittees
identified
in
Exhibit
2.
Of
this
population,
390,352
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).

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
3,598
527
4,125
Non­
Municipal
2,080
360
2,440
SUBTOTAL
5,678
887
6,565
MINOR
PERMITS
Municipal
9,885
770
10,655
Non­
Municipal
32,587
1,717
34,304
SUBTOTAL
42,472
2,487
44,959
GENERAL
PERMITTEES
0
Storm
Water
0
0
Industrial
87,247
4,883
92,130
Construction
193,026
10,803
203,829
Other
34,229
8,640
42,869
SUBTOTAL
314,502
24,326
338,828
SLUDGE­
ONLY
PERMITS
POTWs
185
1,925
2,110
PrOTWs
12
128
140
SUBTOTAL
197
2,053
2,250
TOTAL
362,849
29,753
392,602
Source
of
data:
PCS
(
December
2003);
1998
Storm
Water
Phase
II
Rule
Economic
Analysis;
ICRs
#
1427.06,
#
1842.02,
and
#
2040­
0086.
Exhibit
2.
Number
of
NPDES
Permits
Issued
by
EPA
and
the
States
DRAFT
FINAL
Compliance
Assessment
ICR
Page
23
March
26,
2004
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
4,125
6.0
24,750
Major
Non­
Municipal
Permittees
2,440
6.0
14,640
Minor
Municipal
Permittees
10,655
1.2
12,786
Minor
Non­
Municipal
Permittees
34,304
1.2
41,165
Storm
Water
General
Permittees
 
Industrial*
92,130
6.6
608,058
Storm
Water
General
Permittees
 
Construction
203,829
4.0
815,316
Other
General
Permittees
42,869
1.2
51,443
SUBTOTAL
390,352
1,568,158
Compliance
Schedule
Reports
Major
Municipal
Permittees
3,094
1.125
3,481
Major
Non­
Municipal
Permittees
1,830
1.125
2,059
Minor
Municipal
Permittees
533
1.125
600
Minor
Non­
Municipal
Permittees
1,715
1.125
1,929
Sludge
Permit
Conditions
Compliance
Schedule
Reports
POTWs
100
1.5
150
PrOTWs
32
1.5
48
SUBTOTAL
7,304
8,267
Noncompliance
Reports
Unanticipated
Bypass/
Upset
Report
Verbal
Reports
Major
Municipal
Permittees
619
5
3,095
Major
Non­
Municipal
Permittees
366
5
1,830
Minor
Municipal
Permittees
533
5
2,665
Minor
Non­
Municipal
Permittees
1,715
5
8,575
Written
Reports
Major
Municipal
Permittees
464
2
928
Major
Non­
Municipal
Permittees
275
2
550
Minor
Municipal
Permittees
400
2
800
Minor
Non­
Municipal
Permittees
1,286
2
2,572
SUBTOTAL
5,658
21,015
Maximum
Daily
Violation
Report
Verbal
Reports
Major
Municipal
Permittees
619
6
3,714
Major
Non­
Municipal
Permittees
366
6
2,196
Minor
Municipal
Permittees
533
3
1,599
Minor
Non­
Municipal
Permittees
1,715
3
5,145
Storm
Water
Permittees
2,280
3
6,840
DRAFT
FINAL
Compliance
Assessment
ICR
Page
24
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)

March
26,
2004
Written
Reports
Major
Municipal
Permittees
310
4
1,240
Major
Non­
Municipal
Permittees
183
4
732
Minor
Municipal
Permittees
267
2
534
Minor
Non­
Municipal
Permittees
858
2
1,716
Storm
Water
Permittees
1,140
2
2,280
SUBTOTAL
8,271
25,996
Other
Noncompliance
Reports
Major
Municipal
Permittees
83
5
415
Major
Non­
Municipal
Permittees
49
5
245
Minor
Municipal
Permittees
107
5
535
Minor
Non­
Municipal
Permittees
343
5
1,715
Sludge
Permit
Conditions
 
Noncompliance
Reports
POTWs
31
5.2
161
PrOTWs
10
5.2
52
SUBTOTAL
623
3,123
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
Part
435
Certification
Oil
and
Gas
Extraction***
68
N/
A
53,516
TOTAL
416,850
1,762,796
*
Only
49.5
percent
of
the
92,130
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
burden
hours
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.
***
Part
435
burden
and
costs
are
presented
in
detail
in
Appendix
B.
DRAFT
FINAL
Compliance
Assessment
ICR
Page
25
March
26,
2004
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
3,094
1.5
4,641
Major
Non­
Municipal
Permittees
1,830
1.5
2,745
Minor
Municipal
Permittees
533
1.5
800
Minor
Non­
Municipal
Permittees
1,715
1.5
2,573
Sludge
Permit
Conditions
Compliance
Schedule
Reports
POTWs
100
2
200
PrOTWs
32
2
64
SUBTOTAL
7,304
11,023
Noncompliance
Reports
Unanticipated
Bypass/
Upset
Report
Verbal
Reports
Major
Municipal
Permittees
619
1
619
Major
Non­
Municipal
Permittees
366
1
366
Minor
Municipal
Permittees
533
1
533
Minor
Non­
Municipal
Permittees
1,715
1
1,715
Written
Reports
Major
Municipal
Permittees
464
1
464
Major
Non­
Municipal
Permittees
275
1
275
Minor
Municipal
Permittees
400
1
400
Minor
Non­
Municipal
Permittees
1,286
1
1,286
SUBTOTAL
5,658
5,658
Maximum
Daily
Violation
Report
Verbal
Reports
Major
Municipal
Permittees
619
2
1,238
Major
Non­
Municipal
Permittees
366
2
732
Minor
Municipal
Permittees
533
1
533
Minor
Non­
Municipal
Permittees
1,715
1
1,715
Storm
Water
Permittees
2,280
1
2,280
Written
Reports
Major
Municipal
Permittees
310
2
620
Major
Non­
Municipal
Permittees
183
2
366
Minor
Municipal
Permittees
267
1
267
Minor
Non­
Municipal
Permittees
858
1
858
Storm
Water
Permittees
1,140
1
1,140
SUBTOTAL
8,271
9,749
DRAFT
FINAL
Compliance
Assessment
ICR
Page
26
Exhibit
4.
Annual
Average
Responses
per
Respondent
Item/
Type
of
Respondent
Respondents
per
Year
(
A)
Responses
per
Year
(
B)
Total
Annual
Responses
[(
A)
×
(
B)]

March
26,
2004
Other
Noncompliance
Reports
Major
Municipal
Permittees
83
1
83
Major
Non­
Municipal
Permittees
49
1
49
Minor
Municipal
Permittees
107
1
107
Minor
Non­
Municipal
Permittees
343
1
343
Sludge
Permit
Conditions
 
Noncompliance
Reports
POTWs
31
1
31
PrOTWs
10
1
10
SUBTOTAL
623
623
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
Part
435
Certification
Oil
&
Gas
Extraction
68
N/
A**
N/
A**

TOTAL
26,498
33,020
*
Estimated
number
of
respondents
in
each
category
is
described
in
Section
6.
a.
6.
**
See
Appendix
B.

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
DRAFT
FINAL
Compliance
Assessment
ICR
Page
27
March
26,
2004
for
completing
mandatory
reports.
The
more
often
a
facility
violates
its
permit
conditions,
the
larger
the
burden
associated
with
reporting
noncompliance
(
i.
e.,
explaining
reasons
and
proposing
solutions).

6.
a.
1
Recordkeeping
of
Monitoring
and
Inspection
Data
The
following
discussion
is
presented
in
table
format
in
Exhibits
2
and
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,
6,565
major
permittees
(
4,125
municipal
plus
2,440
nonmunicipal
will
spend
6.0
hours
per
year
on
recordkeeping
activities,
resulting
in
a
total
annual
burden
of
39,390
hours.
All
44,959
minor
municipal
and
non­
municipal
permittees
(
10,655
and
34,304,
respectively)
will
incur
a
total
annual
burden
of
53,951
hours
for
recordkeeping.

All
295,959
storm
water
general
permittees
are
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
1,183,836
hours.
All
of
the
92,130
storm
water
general
permittees
with
industrial
discharges
are
required
to
conduct
quarterly
visual
examinations.
EPA
estimates
these
permittees
will
spend
0.5
hours
for
each
visual
examination,
for
a
total
of
2.0
hours
per
year
and
a
total
annual
burden
of
184,260
hours.

A
portion
of
the
storm
water
general
permittees
with
industrial
discharges
are
required
to
keep
monitoring
records.
Based
on
information
submitted
by
these
permittees
to
the
NOI
Data
Processing
Center,
this
number
is
estimated
to
be
49.5
percent
or
45,604
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
54,725
hours.
Note:
Because
only
a
portion
of
the
92,130
storm
water
permittees
with
industrial
discharges
are
required
to
maintain
monitoring
data,
the
average
burden
hours
for
these
storm
water
permittees
is
6.6
hours.

EPA
estimates
that
all
42,869
non­
storm
water
general
permittees
will
incur
a
recordkeeping
burden
of
1.2
hours
annually
for
maintaining
monitoring
data.
This
results
in
a
total
annual
burden
of
51,443
hours.

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
1,568,158
hours.
Note
that
recordkeeping
requirements
for
sewage
sludge
permittees
are
accounted
for
in
the
Sewage
Sludge
Use
or
Disposal
Standards
ICR
and,
thus,
are
not
included
in
this
ICR.
DRAFT
FINAL
Compliance
Assessment
ICR
Page
28
March
26,
2004
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
permittees
will
receive
periodic
detailed
progress
reports
from
their
contractors
on
the
status
of
construction.
Therefore,
EPA
expects
this
requirement
to
place
very
little
additional
burden
upon
permittees.
According
to
the
previous
NPDES/
Compliance
Assessment/
Certification
Information
ICR,
it
is
estimated
that
permittees
will
submit
an
average
of
1.5
reports
per
year,
and
the
burden
to
complete
each
report
will
be
0.75
hours.
This
is
equivalent
to
1.125
hours
per
year
for
each
respondent.
This
burden
represents
the
time
required
to
both
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
submit
compliance
schedule
reports
per
year.
General
permittees
will
not
incur
a
burden
as
they
are
not
required
to
submit
compliance
schedule
reports.
At
1.125
hours
per
year,
the
total
annual
burden
to
major
facilities
is
5,540
hours,
while
the
total
annual
burden
to
minor
facilities
is
2,529
hours.

The
Agency
anticipates
that
each
year,
100
POTWs
and
32
PrOTWs
are
required
to
submit
compliance
schedule
reports
regarding
sewage
sludge
permit
conditions
and,
further,
that
these
facilities
are
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
to
prepare
and
file
compliance
schedule
reports
is
therefore
8,267
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
subsections
discuss
the
burden
estimates
associated
with
these
noncompliance
reports,
except
for
those
reports
associated
with
SSOs
and
unpermitted
CSOs.
The
burden
estimates
associated
with
these
noncompliance
reports
are
discussed
in
Section
6.
a.
7.

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
assumes
that
permittees
closely
monitor
the
operation
of
their
facilities
so
that
the
occurrence
of
a
bypass
or
upset
of
the
treatment
works
is
readily
apparent
to
operators.
Because
of
the
potential
for
serious
environmental
damage,
grave
threats
to
public
DRAFT
FINAL
Compliance
Assessment
ICR
Page
29
March
26,
2004
health,
and
injury
to
facility
employees,
permittees
should
act
quickly
in
the
event
of
such
an
occurrence.
Permittees
must
make
these
reports
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
the
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
(
985)
of
the
6,565
major
facilities
and
5
percent
(
2,248)
of
the
44,959
minor
facilities
upset
or
bypass
annually,
thereby
requiring
a
verbal
notification.
EPA
estimates
that
these
respondents
will
submit
one
report
per
year
at
5
hours
of
burden.
In
addition,
EPA
estimates
that
75
percent
(
2,425)
of
the
3,233
facilities
submitting
a
verbal
notification
will
also
be
required
to
submit
a
written
report.
The
written
report
is
expected
to
require
an
additional
2
hours
of
burden.
The
burden
represents
the
time
required
to
investigate
the
bypass
or
cause
of
upset;
determine
the
duration
or
expected
duration
of
the
incident;
determine
the
corrective
actions
to
be
taken;
prepare
the
written
report
(
if
the
requirement
is
not
waived);
and
to
send
the
report
to
the
permitting
authority.
As
illustrated
in
Exhibit
3,
the
total
annual
respondent
burden
for
submitting
the
verbal
and
written
notification
is
21,015
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
limited
pollutants
and
report
sampling
results
to
the
permitting
authority
on
a
Discharge
Monitoring
Report
(
DMR).
Because
the
permittee's
requirements
are
already
accounted
for
in
the
DMR
ICR
(
as
discussed
above),
the
verbal
and
written
notice
requirements
under
this
ICR
add
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
those
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
the
requirement
is
not
waived,
and
submit
the
report
to
the
permitting
authority.

EPA
estimates
that
15
percent
(
985)
of
the
6,565
major
facilities
and
5
percent
(
2,248)
of
the
44,959
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,
310
major
municipals,
183
major
nonmunicipals
267
minor
municipals,
and
858
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
industrial
discharges
to
violate
their
maximum
daily
discharge
limits.
This
5
percent
is
expected
to
be
inclusive
of
the
10
percent
of
storm
water
general
DRAFT
FINAL
Compliance
Assessment
ICR
Page
30
March
26,
2004
permittees
with
coal
pile
runoff
effluent
limits
that
are
expected,
as
estimated
in
the
previous
ICR,
to
violate
their
maximum
daily
discharge
limits.
As
a
result,
2,280
such
permittees
will
be
required
to
provide
verbal
notice
of
the
violation,
of
which
50
percent,
or
1,140,
will
be
required
to
submit
written
reports.
In
summary,
for
all
categories
of
respondents
who
must
submit
reports
for
maximum
daily
violations,
the
associated
total
annual
burden
is
25,996
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
it.
Usually,
a
permittee
makes
these
types
of
reports
when
conditions
other
than
those
described
above
cause
it
to
violate
the
conditions
of
its
permit.
EPA
estimates
the
average
burden
to
be
5
hours
per
response.
This
burden
represents
the
time
required
to
gather
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
(
131)
of
the
6,565
major
facilities
and
1
percent
(
450)
of
the
44,959
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
660
hours
for
major
facilities
and
2,250
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
3,123
hours.

Exhibit
4
shows
the
annual
average
number
of
responses
per
respondent.
The
total
annual
burden
for
all
three
types
of
noncompliance
reports,
as
discussed
above,
is
50,134
hours.
This
is
summarized
in
Exhibit
5.
This
exhibit
does
not
include
the
respondent
burden
associated
with
SSO
and
CSO
reporting.
This
latter
information
can
be
found
in
Exhibit
8.
DRAFT
FINAL
Compliance
Assessment
ICR
Page
31
March
26,
2004
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
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.
Such
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.
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
6,403
Minor
Facilities
14,612
Maximum
Daily
Violation
Report
Major
Facilities
7,882
Minor
Facilities
8,994
Storm
Water
Permittees
9,120
Other
Noncompliance
Reports
Major
Facilities
660
Minor
Facilities
2,250
Sludge­
only
POTWs
161
Sludge­
only
PrOTWs
52
Total
Annual
Respondent
Burden
50,134
Exhibit
5.
Respondent
Reporting
Burden
for
Noncompliance
Reports
DRAFT
FINAL
Compliance
Assessment
ICR
Page
32
March
26,
2004
EPA
estimates
the
burden
associated
with
this
latter
type
of
collection
to
be
8
hours
per
response.
This
estimate
represents
the
time
required
for
the
permittee
to
gather
existing
information,
consult
specialists,
such
as
engineers
and
lawyers,
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,
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
generated
using
data
from
PCS
and
cross­
referencing
it
with
facility
SIC
code
data
by
CFR
category.
Each
certification
is
estimated
to
require
1
hour
to
prepare.

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
[
i.
e.,
(
326)(.
50)
=
(
163
resp./
yr.)(
1
hrs./
resp.)
=
163
hrs./
yr.].
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
[
i.
e.,
163/
3
=
(
54
resp./
yr.)(
20
hr./
resp.)
=
1080
hrs./
yr.].

EPA
estimates
that
approximately
75
percent
of
the
aluminum
forming
facilities
and
coil
coating
facilities
will
choose
to
submit
an
annual
certification
requesting
an
exemption
from
cyanide
monitoring
[
i.
e.,
aluminum
forming:
(
76)(.
75)
=
(
57
resp./
yr.)(
1
hrs./
resp.)
=
57
hrs./
yr.];
[
i.
e.,
coil
coating:
(
101)(.
75)
=
(
76
resp./
yr.)(
1
hrs./
resp.)
=
76
hrs./
yr.];
[
i.
e.,
can
making:
(
18)(.
75)
=
(
14
resp./
yr.)(
1
hrs./
resp.)
=
14
hrs./
yr.].

EPA
estimates
that
50
percent
of
the
porcelain
enameling
facilities
will
choose
to
submit
an
annual
certification
requesting
an
exemption
from
chromium
monitoring
[
i.
e.,
(
54)(.
50)
=
(
27
resp./
yr.)(
1
hrs./
resp.)
=
27
hrs./
yr.].

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.
Of
these,
EPA
estimates
that
75
percent
will
choose
to
submit
a
certification
once
every
permit
cycle
requesting
an
exemption
from
monitoring
[
i.
e.,
(
130)(.
40)(.
75)
=
(
39
resp./
yr.)(
1
hrs./
resp.)
=
39
hrs./
yr.].
DRAFT
FINAL
Compliance
Assessment
ICR
Page
33
March
26,
2004
In
the
pulp,
paper,
and
paperboard
category,
EPA
estimates
from
effluent
guideline
development
documents
that
approximately
80
percent
of
the
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.
EPA
estimates
that
of
these
80
percent
eligible,
that
75
percent
will
choose
to
certify
[
i.
e.,
(
361)(.
80)(.
75)
=
(
217
resp./
yr.)(
0.2
hrs./
resp.)
=
43
hrs./
yr.].
Similarly,
for
the
builders'
paper
and
board
mills
category,
EPA
estimates
that
75
percent
of
the
facilities
will
certify
[
i.
e.,
(
174)(.
75)
=
(
131
resp./
yr.)(
1
hrs./
resp.)
=
131
hrs./
yr.].

EPA
estimates
that
approximately
75
percent
of
the
facilities
in
the
steam
electric
category
will
choose
to
provide
a
demonstration
and
certification
requesting
an
exemption
from
monitoring
requirements
[
i.
e.,
(
1372)(.
75)
=
(
1029
resp./
yr.)(
1
hrs./
resp.)
=
1029
hrs./
yr.].

EPA
estimates
that
approximately
50
percent
of
the
eligible
electrical
and
electronic
components
facilities
will
choose
to
submit
a
Total
Toxic
Organic
(
TTO)
Certification
(
semiannually
in
lieu
of
TTO
monitoring,
and
75
percent
of
the
metal
finishing
facilities
will
choose
to
submit
this
(
semi­
annual)
TTO
certification
[
i.
e.,
electrical
and
electronic
components:
(
86)(.
50)
=
(
43
resp./
yr.)(
2
hrs./
resp.)
=
86
hrs./
yr.];
[
i.
e.,
metal
finishing:
(
2032)(.
75)
=
(
1524
resp./
yr.)(
2
hrs./
resp.)
=
3048
hrs./
yr.].
Note:
At
this
time
there
are
no
known
electroplating
direct
discharging
facilities.

For
these
certification
and
pollution
prevention
activities,
EPA
estimates
a
total
annual
burden
of
5,793
hours
(
see
Exhibit
3).
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
*
Categorical
data
taken
from
the
previous
ICR
and
apportioned
between
State
and
EPA
based
on
the
ratio
of
delegated
to
non­
delegated
States.
**
All
electroplaters
believed
to
be
indirect
dischargers.
Exhibit
6.
Facilities
with
Certification
Potential
DRAFT
FINAL
Compliance
Assessment
ICR
Page
34
March
26,
2004
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.
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
an
SSO
rulemaking
effort.

6.
a.
8
Certification
and
BMP
Plan
Development
Pursuant
to
40
CFR
Part
435
With
regard
to
use
of
Best
Management
Practices
(
BMPs)
under
Part
435
to
control
nonaqueous
drilling
fluids
(
NAFs),
EPA
also
estimates
that
each
SBF
well
drilling
facility
will
drill,
on
average,
three
SBF
wells
per
year
(
Johnston,
2000).
Therefore
the
annual
number
of
SBF
wells
per
year
is
204
[
i.
e.,
(
68
fac./
year)
x
(
3
SBF
wells/
fac.)
=
204
SBF
wells/
year].
The
duration
of
this
ICR
is
three
years.
The
maximum
number
of
potential
respondents
over
the
three
year
time
frame
is
68,
as
operators
may
elect
not
to
use
the
BMP
alternative
to
reduce
SBF­
cuttings
monitoring.
EPA
also
estimates
that
no
drilling
operations
in
offshore
California
will
use
SBFs
(
Henry,
2000).
EPA
is
also
promulgating
a
zero
discharge
requirement
for
SBF­
cuttings
in
Coastal
Cook
Inlet,
Alaska
with
an
exemption
for
those
operators
that
are
technically
unable
to
perform
zero
discharge
operations
for
their
SBF­
cuttings.
EPA
estimates
that
Coastal
Cook
Inlet
operators
will
be
able
to
perform
zero
discharge
based
on
current
technical
capabilities.
Therefore,
EPA
estimates
no
additional
respondents
in
either
offshore
California
or
Cook
Inlet,
Alaska.

Exhibit
7.
Number
of
SBF
Facilities
Affected
by
ICR
Burden
Estimate
Rig
Type
Number
Shallow
Water
Rigs:
Jackup
Rigs
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
Platform
Rigs
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

SUBTOTAL
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

Shallow
Water
Rigs
using
SBFs
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
116
69
185
(
185)(
0.14)
=
26
Deep
Water
Rigs:
Floating
Rigs
(
Semi­
submersible
and
Drill
Ships)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

Deep
Water
Rigs
using
SBFs
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
42
42
TOTAL
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
68
Sources:
Angelle
and
Scott,
2000
and
Rigzone,
February
2004
DRAFT
FINAL
Compliance
Assessment
ICR
Page
35
March
26,
2004
EPA
expects
that
virtually
all
SBF­
cuttings
discharges
will
take
place
in
offshore
areas
(
i.
e.,
Federal
waters).
EPA
estimates
that
SBF­
cuttings
discharges
in
Coastal
Cook
Inlet,
Alaska,
will
be
a
rare
occurrence
due
to
technical
limitations
prohibiting
operators
from
performing
zero
discharge.
EPA
has
not
yet
delegated
NPDES
permitting
authority
to
the
State
of
Alaska.
There
are
four
EPA
Regions
(
i.
e.,
Regions
4,
6,
9
and
10)
estimated
to
be
impacted
by
the
BMP
ICR
requirements.

Operators
are
assumed
to
use
specialty
contractors
to
assist
them
in
developing
their
BMP
Plans.
These
specialty
contractors
are
expected
to
perform
site
screening
analyzes
and
summarize
their
findings
for
operators.
After
consultation
with
operators,
the
contractors
are
expected
to
prepare
a
draft
BMP
Plan
for
operators
to
review,
modify,
and
certify.
Contractor
labor
hours
dedicated
to
the
development,
review,
and
certification
of
the
BMP
Plan
are
estimated
to
be
150
hours
per
facility.
For
all
contractor
hours,
75
percent
is
engineering
labor
($
65/
hr)
and
25
percent
is
senior
management
labor
($
100/
hr).

Facility
engineering
labor
hours
dedicated
to
the
development,
review,
and
certification
of
the
BMP
Plan
are
estimated
to
be
100
hours
per
facility.
For
all
in­
hours
facility
hours,
75
percent
is
engineering
labor
($
65/
hr)
and
25
percent
is
senior
management
labor
($
100/
hr).

The
facility
burden
and
cost
estimates
for
amendment
and
review
of
the
BMP
Plan,
reporting,
monitoring,
record
keeping,
and
training
BMP
requirements
are
detailed
in
this
section.
Tables
4,
5,
and
6
in
Appendix
B
summarize
all
burden
and
cost
estimates
for
the
BMP
Plan
alternative.

Annual
facility
labor
estimates
are
30
hours
per
facility.
For
all
in­
house
facility
hours
for
BMP
Plan
amendment
and
review,
75
percent
is
engineering
labor
($
65/
hr)
and
25
percent
is
senior
management
labor
($
100/
hr).

EPA
estimates
that
there
are
three
SBF
spills
per
SBF
well
and
that
each
spill
requires
4
hours
of
labor
for
reporting
and
documenting
the
spill
details.
Therefore,
the
annual
burden
per
SBF
facility
is
36
hours:
[
i.
e.,
(
3
SBF
spills
/
SBF
well)(
4
hr
/
SBF
spill)(
3
SBF
wells
/
SBF
fac.)
=
36
hours
/
SBF
fac.].
In­
house
engineering
labor
($
65/
hr)
is
expected
to
complete
each
SBF
spill
report.

Two
elements
of
the
SBF
BMPs
require
additional
monitoring
and
reporting.
These
elements
are:

S
The
establishment
of
operating
and
maintenance
procedures
for
solids
control
equipment:
3
hr/
day,
and
S
Daily
retort
analyses:
3
hr/
day.

EPA
assumes
that
equipment
operators
($
20/
hr)
perform
these
additional
monitoring
and
reporting
requirements.
The
total
industry
burden
for
additional
monitoring
and
reporting
requirement
is
36,720
hours:
[
i.
e.,
(
204
SBF
wells
/
yr)(
1
month
/
SBF
well)(
30
days
/
month)(
3
hr
/
day
+
3
hr
/
day)
=
36,720
hr],
where
3
hours
per
day
are
spent
on
identifying,
documenting,
and
repairing
leaking
SBF­
equipment
and
3
hours
per
day
are
spent
on
daily
retort
analyses.
DRAFT
FINAL
Compliance
Assessment
ICR
Page
36
March
26,
2004
Estimates
are
based
on
2
hours
per
month
for
operators/
shift
supervisors
over
current
shift
log
record
keeping
($
20/
hr),
2
hours
per
month
for
engineering
technicians
($
65/
hr),
and
2
hours
per
month
for
clerical
support
($
15/
hr).
Therefore
the
total
burden
is
estimated
at
1,206
hours
per
year:
[
i.
e.,
(
204
SBF
wells/
year)(
1
month/
SBF
well)(
6
hours/
month)
=
1,224
hours/
year].
Applying
the
labor
rates
above,
the
total
cost
across
the
industry
per
year
is
$
40,800
for
this
record
keeping.

EPA
estimates
that
re­
fresher
training
takes
place
twice
a
year
and
each
training
session
is
4
hours
long.
Each
training
session
includes
nine
operators
($
20/
hr)
and
one
consultant
acting
as
trainer
($
65/
hr).
The
total
annual
burden
per
SBF
facility
for
refresher
training
is
72
hours
of
operator
effort
and
8
hours
of
consultant
effort.
Therefore
the
total
burden
across
the
industry
is
5,440
hours
and
$
133,280.

6.
b
Estimating
Respondent
Costs
The
cost
imposed
on
permittees
for
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.

!
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.
The
total
hourly
compensation
rate
for
all
workers
in
the
goods
producing
industry
in
September
2003
dollars
is
$
26.79.
This
rate
is
adjusted
to
account
for
fully
loaded
labor
rates
(
50%)
for
a
per
hour
rate
of
$
40.19.

!
This
ICR
estimates
the
municipal
POTW
employee
hourly
rate
in
September
2003
dollars
to
be
$
33.62
based
on
wages
and
salary
values
provided
in
"
Table
3.
State
and
local
government,
by
selected
characteristics"
of
the
U.
S.
Department
of
Labor,
Bureau
of
Labor
Statistics.

!
This
ICR
estimates
the
State
employee
hourly
rate
based
on
an
overall
wage
and
salary
value
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.
The
total
hourly
compensation
rate
for
all
workers
in
State
and
local
governments
in
September
2003
dollars
is
$
33.62
per
hour.

Labor
costs
for
Part
435
certification
are
in
Appendix
A
due
to
their
distinct
breakout.
Exhibit
8
shows
the
estimated
cost
of
recordkeeping
and
reporting
for
the
compliance
assessment
activities
discussed
in
this
ICR.
EPA
estimates
that
the
total
annual
cost
is
$
62,777,658
for
recordkeeping
and
$
5,032,350
for
reporting
for
a
total
respondent
cost
of
$
67,810,008.

Respondent
costs
associated
with
use
of
BMPs
under
Part
435
to
control
NAFs
are
described
in
section
6.
a.
8
above.
DRAFT
FINAL
Compliance
Assessment
ICR
Page
37
March
26,
2004
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
entity
is
the
permitting
authority.
Forty
five
States
and
one
Territory
are
authorized
currently
to
administer
the
NPDES
program.
Five
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.

!
Estimates
of
government
costs
associated
with
this
ICR
have
been
prepared
using
Federal
Salary
Table
2003­
GS.
The
2003
annual
salary
for
a
Federal
GS­
9,
Step
10
employee
is
$
46,175.
At
2,080
labor
hours
per
year,
the
hourly
rate
is
$
22.20.
Overhead
costs
for
Federal
employees
are
expected
to
be
50
percent,
or
$
11.10,
yielding
a
total
hourly
rate
of
$
33.30.

The
estimated
burden
and
costs
to
the
government
(
State
and
Federal)
for
handling
and
reviewing
compliance
assessment
information,
as
discussed
in
this
ICR,
are
presented
in
Exhibits
9
and
10.
EPA
estimates
that
the
government
will
spend
approximately
64,823
hours
reviewing
compliance
assessment
information
each
year.
Of
the
total
government
burden,
46,784
hours
will
be
spent
by
State
governments
and
18,039
hours
will
be
spent
by
the
Federal
government.

As
presented
in
Exhibit
10,
the
total
annual
government
cost
is
estimated
to
be
$
2,084,306.
Of
this
total
government
cost,
$
1,526,227
will
be
borne
by
State
governments,
while
$
558,079
will
be
borne
by
the
Federal
government.

With
regard
to
use
of
BMPs
under
Part
435
to
control
NAFs,
Appendix
B
presents
eight
tables
of
burden
and
cost
estimates,
organized
into
three
categories:
Initial
Burden
and
Costs
(
Tables
1­
3);
Recurring
Annual
Burden
and
Costs
(
Tables
4­
6);
and
Summary
Burden
and
Costs
(
Tables
7­
8).
EPA
estimates
the
initial
burden
to
EPA
Regional
NPDES
permitting
authorities
to
be
8
hours
per
facility
for
preparation
of
NPDES
permit
provisions
and
an
annual
burden
of
3
hours
for
reviewing
(
e.
g.,
annual
or
semi­
annual)
monitoring
reports
and
conducting
compliance
reviews.
The
cost
of
this
burden
is
estimated
to
be
$
33.30
per
hour
based
on
recent
estimates
of
government
labor
rates.
DRAFT
FINAL
Compliance
Assessment
ICR
Page
38
March
26,
2004
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
who
are
in
compliance.
See
Section
6.
a.
2
for
a
discussion
of
how
many
permittees
are
estimated
to
be
required
to
submit
compliance
schedules.
As
shown
in
Exhibit
9,
a
total
of
7,172
respondents
are
expected
to
submit
reports
each
year.
As
explained
in
Section
6.
a.
2.,
a
respondent
is
expected
to
submit
an
average
of
1.5
reports
per
year.
The
burden
equates
to
approximately
0.4
hours
per
year
per
respondent
(
1.5
reports
per
year
at
0.25
hours
per
report).
Of
the
7,172
reporting
facilities,
6,382
are
expected
to
report
to
State
governments,
while
790
are
expected
to
report
to
the
Federal
government.
DRAFT
FINAL
Compliance
Assessment
ICR
Page
39
March
26,
2004
Exhibit
8.
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
24,750
$
33.62
$
832,095
Major
Non­
Municipal
Permittees
14,640
$
40.19
$
588,382
Minor
Municipal
Permittees
12,786
$
33.62
$
429,865
Minor
Non­
Municipal
Permittees
41,165
$
40.19
$
1,654,421
Storm
Water
General
Permittees
 
Industrial
608,058
$
40.19
$
24,437,851
Storm
Water
General
Permittees
 
Construction
815,316
$
40.19
$
32,767,550
Other
General
Permittees
51,443
$
40.19
$
2,067,494
SUBTOTAL
1,568,158
$
62,777,658
Compliance
Schedule
Reports
Major
Municipal
Permittees
3,481
$
33.62
$
117,031
Major
Non­
Municipal
Permittees
2,059
$
40.19
$
82,751
Minor
Municipal
Permittees
600
$
33.62
$
20,172
Minor
Non­
Municipal
Permittees
1,929
$
40.19
$
77,527
Sludge
Permit
Conditions
Compliance
Schedule
Reports
POTWs
150
$
33.62
$
5,043
PrOTWs
48
$
40.19
$
1,929
SUBTOTAL
8,267
$
304,453
Noncompliance
Reports
Unanticipated
Bypass/
Upset
Report
Verbal
Reports
Major
Municipal
Permittees
3,095
$
33.62
$
104,054
Major
Non­
Municipal
Permittees
1,830
$
40.19
$
73,548
Minor
Municipal
Permittees
2,665
$
33.62
$
89,597
Minor
Non­
Municipal
Permittees
8,575
$
40.19
$
344,629
Written
Reports
Major
Municipal
Permittees
928
$
33.62
$
31,199
Major
Non­
Municipal
Permittees
550
$
40.19
$
22,105
Minor
Municipal
Permittees
800
$
33.62
$
26,896
Minor
Non­
Municipal
Permittees
2,572
$
40.19
$
103,369
SUBTOTAL
21,015
$
795,397
DRAFT
FINAL
Compliance
Assessment
ICR
Page
40
Exhibit
8.
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)]

March
26,
2004
Maximum
Daily
Violation
Report
Verbal
Reports
Major
Municipal
Permittees
3,714
$
33.62
$
124,865
Major
Non­
Municipal
Permittees
2,196
$
40.19
$
88,257
Minor
Municipal
Permittees
1,599
$
33.62
$
53,758
Minor
Non­
Municipal
Permittees
5,145
$
40.19
$
206,778
Storm
Water
Permittees
6,840
$
40.19
$
274,900
Written
Reports
Major
Municipal
Permittees
1,240
$
33.62
$
41,689
Major
Non­
Municipal
Permittees
732
$
40.19
$
29,419
Minor
Municipal
Permittees
534
$
33.62
$
17,953
Minor
Non­
Municipal
Permittees
1,716
$
40.19
$
68,966
Storm
Water
Permittees
2,280
$
40.19
$
91,633
SUBTOTAL
25,996
$
998,218
Other
Noncompliance
Reports
Major
Municipal
Permittees
415
$
33.62
$
13,952
Major
Non­
Municipal
Permittees
245
$
40.19
$
9,847
Minor
Municipal
Permittees
535
$
33.62
$
17,987
Minor
Non­
Municipal
Permittees
1,715
$
40.19
$
68,926
Sludge
Permit
Conditions
 
Noncompliance
Reports
POTWs
161
$
33.62
$
5,413
PrOTWs
52
$
40.19
$
2,090
SUBTOTAL
3,123
$
118,215
Notice
of
Alternate
Level
of
Production
0
$
40.19
$
0
Section
308(
a)
Letters
9,600
$
33.30
$
319,680
Pollution
Prevention
Alternative
Pesticides
Packaging
and
Repackaging
1,080
$
40.19
$
43,405
DRAFT
FINAL
Compliance
Assessment
ICR
Page
41
Exhibit
8.
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)]

March
26,
2004
Certifications
Pesticides
Packaging
and
Repackaging
163
$
40.19
$
6,551
Aluminum
Forming
57
$
40.19
$
2,291
Coil
Coating
76
$
40.19
$
3,054
Can
Making
(
subcategory
of
coil
coating)
14
$
40.19
$
563
Porcelain
Enameling
27
$
40.19
$
1,085
Pharmaceutical
Manufacturing
39
$
40.19
$
1,567
Pulp,
Paper,
and
Paperboard
43
$
40.19
$
1,728
Building
Paper
and
Board
Mills
131
$
40.19
$
5,265
Steam
Electric
1,029
$
40.19
$
41,356
Electroplating
0
$
40.19
$
0
Metal
Finishing
3,048
$
40.19
$
122,499
Electrical
and
Electronic
Components
86
$
40.19
$
3,456
SUBTOTAL
4,713
$
189,415
SSO
Reporting
62,144
$
33.62
$
2,089,281
Unpermitted
CSO
Reporting
5,184
$
33.62
$
174,286
TOTAL
1,709,280
$
67,810,008
*
Part
435
burden
and
costs
are
presented
in
Exhibit
12
detailed
in
Appendix
B.
DRAFT
FINAL
Compliance
Assessment
ICR
Page
42
March
26,
2004
Exhibit
9.
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
6,382
790
0.4
2,553
316
2,869
Noncomplying
Permittees
1,276
158
6.0
7,656
948
8,604
Sludge
Permittees
7
125
0.5
4
63
67
SUBTOTAL
7,665
1,073
10,213
1,327
11,540
Noncompliance
Reports
Unanticipated
Bypass/
Upset
Report
Verbal
Notification
2,975
257
1.0
2,975
257
3,232
Written
Report
2,231
193
2.0
4,462
386
4,848
Federal
Assistance
to
States
N/
A
112
2.0
N/
A
224
224
Immediate
Action
744
64
2.0
1,488
128
1,616
Additional
Federal
Review
N/
A
260
2.0
N/
A
520
520
SUBTOTAL
5,950
886
8,925
1,515
10,440
Maximum
Daily
Violation
Report
Verbal
Notification
2,975
257
1.0
2,975
257
3,232
Written
Report
1,488
129
2.0
2,976
258
3,234
Federal
Assistance
to
States
N/
A
74
2.0
N/
A
148
148
Immediate
Action
744
64
2.0
1,488
128
1,616
Additional
Federal
Review
N/
A
223
2.0
N/
A
446
446
SUBTOTAL
5,207
747
7,439
1,237
8,676
Other
Noncompliance
Reports
NPDES
Permittee
Reports
963
67
2.0
1,926
134
2,060
Additional
Federal
Review
N/
A
48
1.0
N/
A
48
48
Sludge
Permittee
Reports
2
39
0.3
1
12
13
SUBTOTAL
965
154
1,927
194
2,121
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
DRAFT
FINAL
Compliance
Assessment
ICR
Page
43
Exhibit
9.
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
March
26,
2004
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
9,654
2,413
12,067
Unpermitted
CSO
Reporting
N/
A
N/
A
N/
A
4,224
1,056
5,280
Part
435
Certification
Oil
&
Gas
Extraction*
0
68
N/
A
0
385
385
TOTALS
22,852
4,383
46,784
18,039
64,823
Annual
burden
hours
reflect
updated
burden
estimates
for
SSOs
and
unpermitted
CSOs
from
the
1998
Summary
of
Revised
Burden
Estimates.
Total
number
of
respondents
do
not
include
SSO/
unpermitted
CSO
estimates.
*
Initial
and
annual
burden.
DRAFT
FINAL
Compliance
Assessment
ICR
Page
44
March
26,
2004
Exhibit
10.
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
$
33.62
$
33.30
$
0
$
0
$
0
Compliance
Schedule
Reports
Total
Permittees
2,553
316
$
33.62
$
33.30
$
85,832
$
10,523
$
96,355
Non­
complying
Permittees
7,656
948
$
33.62
$
33.30
$
257,395
$
31,568
$
288,963
Sludge
Permittees
4
63
$
33.62
$
33.30
$
134
$
2,098
$
2,232
SUBTOTAL
10,213
1,327
$
33.62
$
33.30
$
343,361
$
44,189
$
387,550
Noncompliance
Reports
Unanticipated
Bypass/
Upset
Report
Verbal
Notification
2,975
257
$
33.62
$
33.30
$
100,019
$
8,558
$
108,578
Written
Report
4,462
386
$
33.62
$
33.30
$
150,012
$
12,854
$
162,866
Federal
Assistance
to
States
N/
A
224
$
33.62
$
33.30
N/
A
$
7,459
$
7,459
Immediate
Action
1,488
128
$
33.62
$
33.30
$
50,027
$
4,262
$
54,289
Additional
Federal
Review
N/
A
520
$
33.62
$
33.30
N/
A
$
17,316
$
17,316
SUBTOTAL
8,925
1,515
$
33.62
$
33.30
$
300,059
$
50,450
$
350,508
Maximum
Daily
Violation
Report
Verbal
Notification
2,975
257
$
33.62
$
30.36
$
100,019
$
7,803
$
107,822
Written
Report
2,976
258
$
33.62
$
30.36
$
100,053
$
7,833
$
107,886
Federal
Assistance
to
States
N/
A
148
$
33.62
$
30.36
N/
A
$
4,493
$
4,493
Immediate
Action
1,488
128
$
33.62
$
30.36
$
50,027
$
3,886
$
53,913
Additional
Federal
Review
N/
A
446
$
33.62
$
30.36
N/
A
$
13,541
$
13,541
SUBTOTAL
7,439
1,237
$
33.62
$
30.36
$
250,099
$
37,555
$
287,655
Other
Noncompliance
Reports
NPDES
Permittee
Reports
1,926
134
$
33.62
$
30.36
$
64,752
$
4,068
$
68,820
Additional
Federal
Review
N/
A
48
$
33.62
$
30.36
N/
A
$
1,457
$
1,457
Sludge
Permittee
Reports
1
12
$
33.62
$
30.36
$
34
$
364
$
398
SUBTOTAL
1,927
194
$
33.62
$
30.36
$
64,786
$
5,890
$
70,676
Notice
of
Alternate
Level
of
Production
0
0
$
33.62
$
30.36
$
0
$
0
$
0
Section
308(
a)
Letters
N/
A
9,600
$
33.62
$
30.36
$
0
$
291,456
$
291,456
Pollution
Prevention
Alternative
Pesticides
Packaging
and
Repackaging
N/
A
N/
A
$
33.62
$
30.36
N/
A
N/
A
N/
A
Certifications
Pesticides
Packaging
and
Repackaging
161
2
$
33.62
$
33.30
$
5,361
$
67
$
5,428
Aluminum
Forming
52
5
$
33.62
$
33.30
$
1,732
$
167
$
1,898
Coil
Coating
71
5
$
33.62
$
33.30
$
2,364
$
167
$
2,531
Can
Making
(
subcategory
of
coil
coating)
11
2
$
33.62
$
33.30
$
366
$
67
$
433
DRAFT
FINAL
Compliance
Assessment
ICR
Page
45
Exhibit
10.
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
March
26,
2004
Porcelain
Enameling
21
6
$
33.62
$
33.30
$
699
$
200
$
899
Pharmaceutical
Manufacturing
35
4
$
33.62
$
33.30
$
1,166
$
133
$
1,299
Pulp,
Paper,
and
Paperboard
39
4
$
33.62
$
33.30
$
1,299
$
133
$
1,432
Building
Paper
and
Board
Mills
108
23
$
33.62
$
33.30
$
3,596
$
766
$
4,362
Steam
Electric
916
113
$
33.62
$
33.30
$
30,503
$
3,763
$
34,266
Electroplating
0
0
$
33.62
$
33.30
$
0
$
0
$
0
Metal
Finishing
2,908
140
$
33.62
$
33.30
$
96,836
$
4,662
$
101,498
Electrical
and
Electronic
Components
80
8
$
33.62
$
33.30
$
2,664
$
266
$
2,930
SUBTOTAL
4,402
312
$
146,587
$
10,390
$
156,976
SSO
Reporting
9,654
2,413
$
33.62
$
30.36
$
293,095
$
73,259
$
366,354
Unpermitted
CSO
Reporting
4,224
1,056
$
33.62
$
30.36
$
128,241
$
32,060
$
160,301
Part
435
Certification
Oil
&
Gas
Extraction*
0
385
$
0
$
12,831
$
12,831
TOTALS
46,784
18,402
$
1,526,227
$
558,079
$
2,084,306
*
Part
435
labor
costs
are
presented
in
Appendix
A.

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
of
these
reports.
At
1.5
reports
per
year,
the
total
burden
per
respondent
is
6
hours.

For
sludge
permits,
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
of
2
reports
per
year
under
40
CFR
Part
503.
Each
report
is
expected
to
take
0.25
hours
to
review
and
process.

Exhibit
9
shows
that
the
total
annual
burden
to
the
State
government
for
compliance
schedule
reporting
activities
is
10,213
hours
while
the
total
annual
burden
to
the
Federal
government
is
1,327
hours.
Exhibit
10
shows
that
the
costs
to
State
and
Federal
governments
for
compliance
schedule
activities
are
$
343,361
and
$
44,189,
respectively.
DRAFT
FINAL
Compliance
Assessment
ICR
Page
46
March
26,
2004
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
(
112)
of
the
2,231
written
responses
submitted
to
States
will
incur
an
additional
2
hours
of
Federal
burden
per
response.
In
addition,
5
percent
(
260)
of
the
5,206
verbal
and
written
State
responses
will
need
2
hours
additional
Federal
review
time
after
the
State
response.

As
shown
in
Exhibit
9,
2,975
State
permittees
and
257
Federal
permittees
are
expected
to
submit
one
verbal
report
of
noncompliance
per
year.
Of
these,
75
percent
(
2,231
State
and
193
Federal)
are
expected
to
submit
a
written
report.
In
addition,
808
respondents
(
744
State
and
64
Federal)
are
expected
to
require
immediate
action
to
mitigate
a
problem.

As
shown
in
Exhibit
9,
the
resulting
annual
burden
for
noncompliance
reports
to
State
and
Federal
governments
are
8,925
and
1,515
hours,
respectively.
As
shown
in
Exhibit
10,
the
annual
costs
to
State
and
Federal
governments
are
$
300,059
and
$
50,450,
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.

As
shown
in
Exhibit
9,
State
governments
and
the
Federal
government
will
handle
verbal
notices
of
violation
from
2,975
and
257
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
1,488
and
129
written
responses,
respectively.

In
addition,
a
total
of
744
and
64
respondents
will
require
immediate
action
to
mitigate
a
problem
from
States
or
the
Federal
government,
respectively.
Also,
an
additional
Federal
DRAFT
FINAL
Compliance
Assessment
ICR
Page
47
March
26,
2004
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
74
responses,
will
require
an
additional
2
hours
of
Federal
burden
per
response.
In
addition,
223,
or
5
percent
of
the
total
responses
submitted
to
States
(
2,975
verbal
and
1,488
written),
will
result
in
2
hours
of
additional
Federal
review
time
after
the
State
response.

As
shown
in
Exhibit
9,
annual
burden
from
this
activity
to
State
governments
and
Federal
government
is
7,439
and
1,237
hours,
respectively.
As
shown
in
Exhibit
10,
the
annual
costs
to
States
and
the
Federal
government
are
$
250,099
and
$
37,555,
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
(
131)
of
the
6,565
major
permittees
and
1
percent
(
450)
of
the
44,959
minor
permittees
to
submit
1
report
per
year.
As
shown
in
Exhibit
9,
this
results
in
States
and
the
Federal
governments
handling
963
and
67
annual
responses,
respectively.
Also,
2
hours
are
required
for
additional
Federal
assistance
to
5
percent
(
48)
of
the
963
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
9
shows
that
the
estimated
annual
burden
to
States
and
the
Federal
government
for
handling
other
noncompliance
reports
are
1,927
and
194
hours,
respectively.
Exhibit
10
shows
that
the
estimated
annual
costs
to
States
and
the
Federal
governments
for
this
activity
are
$
64,786
and
$
5,890,
respectively.

Exhibit
11
presents
the
total
annual
burden
from
noncompliance
reports
to
the
States
and
the
Federal
government.
These
numbers
do
not
include
the
burden
associated
with
SSO
and
CSO
reporting,
which
can
be
found
in
Exhibit
10.

6.
c.
4
Notice
of
Alternative
Level
of
Actual
Production
As
discussed
earlier,
EPA
expects
no
burden
to
respondents
from
this
requirement.
DRAFT
FINAL
Compliance
Assessment
ICR
Page
48
March
26,
2004
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.
As
shown
in
Table
9,
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
(
see
Table
10).

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
those
for
pulp,
paper,
and
paperboard
facilities.
These
facilities
are
required
to
submit
certifications
once
per
permit
cycle.
The
electroplating,
metal
finishing,
and
electric
and
electronic
components
facilities
must
submit
semiannual
certifications.
The
certification,
pollution
prevention
alternative
and
process
change
activities
are
estimated,
as
shown
in
Table
9,
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
(
see
Exhibit
9).
The
annual
costs
to
the
States
and
the
Federal
government
for
these
activities
are
$
146,587
and
$
10,390,
respectively
(
see
Exhibit
10).
Activity/
Facility
Type
Total
Annual
Burden
(
Hrs.)

Unanticipated
Bypass/
Upset
Report
NPDES
Facilities
(
State)
8,925
NPDES
Facilities
(
Federal)
1,515
Maximum
Daily
Violation
Report
NPDES
Facilities
(
State)
7,439
NPDES
Facilities
(
Federal)
1,237
Other
Noncompliance
Reports
NPDES
Facilities
(
State)
1,926
NPDES
Facilities
(
Federal)
182
Sludge
Facilities
(
State)
1
Sludge
Facilities
(
Federal)
12
Total
Annual
Government
Burden:

State
Government
18,291
Federal
Government
2,946
TOTAL
21,237
Exhibit
11.
State
and
Federal
Burden
for
Noncompliance
Reports
DRAFT
FINAL
Compliance
Assessment
ICR
Page
49
March
26,
2004
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
12,067
hours
and
5,280
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
(
45)
to
non­
delegated
(
5)
States.

6.
c.
8
Certification
of
BMPs
Under
part
435
With
regard
to
the
use
of
BMPs
under
Part
435
to
control
NAFs,
EPA
estimates
the
public
reporting
(
i.
e.,
all
information
collection)
burden
for
the
selected
BMP
option
as
787
hours
per
respondent
per
year
[
i.
e.,
(
17,000
initial
hours/
3
years
+
47,872
annual
hours/
year)
/
68
SBF
well
operators].
EPA
also
estimated
the
annual
burden
for
EPA
Regions,
the
NPDES
permit
controlling
authorities,
to
review
BMPs
and
ensure
compliance.
EPA
estimates
that
essentially
all
of
the
SBF
discharges
will
occur
in
Federal
offshore
waters
or
in
Cook
Inlet,
Alaska,
where
EPA
Region
10
retains
NPDES
permit
controlling
authority.
The
EPA
Regional
burden
for
reviewing
BMP
Plans
is
estimated
at
385
hours
per
year
[
i.
e.,
(
544
initial
hours/
3
years
+
204
annual
hours/
year)].

EPA
estimates
the
public
reporting
costs
as
$
24,058
per
respondent
per
year
[
i.
e.,
($
1,253,666
initial
costs/
3
years
+
$
1,218,050
annual
costs/
year)
/
68
SBF
well
operators].
The
EPA
Regional
costs
for
reviewing
BMP
Plans
is
estimated
at
approximately
$
12,831
per
year
[
i.
e.,
($
18,115
initial
costs/
3
years
+
$
6,793
annual
costs/
year)].

6.
d
Estimating
the
Respondent
Universe
Burden
Hours
and
Costs
Exhibit
12
presents
the
total
annual
burden
hours
and
costs
to
respondents
and
the
State
government.
It
summarizes
the
burden
and
cost
calculations
previously
presented
in
Exhibits
2,
4,
7,
8,
9,
and
10.
Exhibit
12
.
Respondent
Burden
and
Costs
Annual
Burden
(
Hrs.)
Annual
Costs
Recordkeeping
1,568,158
$
62,777,658
Reporting
(
w/
o
Part
435)
141,122
$
5,032,350
Part
435
Certification
53,516
$
1,635,944
Total
for
Respondents
1,762,796
$
69,445,952
State
Governments
46,784
$
1,526,227
TOTAL
1,809,580
$
70,972,179
DRAFT
FINAL
Compliance
Assessment
ICR
Page
50
March
26,
2004
The
annual
burden
for
respondents
is
1,809,580
hours
and
the
annual
burden
to
State
governments
is
46,784
hours.

6.
e
Bottom
Line
Burden
Hours
and
Costs
The
total
annual
bottom
line
burden
hours
and
costs
for
respondents,
States
and
the
Federal
government
are
1,827,619
burden
hours
and
$
71,542,335.
This
is
summarized
in
Exhibit
13
below.

Table
8
of
Attachment
B
presents
the
bottom
line
initial
and
recurring
burden
hours
and
costs
for
respondents,
States,
and
EPA
for
the
use
of
BMPs
under
Part
435
to
control
NAFs.

6.
f
Reasons
for
Change
in
Burden
Exhibit
14
presents
the
change
in
respondent
burden
for
each
information
item
covered
by
this
ICR.
As
shown
in
Exhibit
14
the
revised
ICR
estimates
an
increase
in
burden
from
1,422,580
hours
to
1,809,580
hours,
or
27
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.
The
burden
increase
of
33
percent
from
the
previous
ICR
represents
an
increase
in
the
number
of
general
permits,
the
growth
of
the
storm
water
general
permitting
program
(
e.
g.,
storm
water
general
permits
increased
by
186,947
in
this
burden
estimate)
and
the
resultant
improvements
in
estimates
of
the
number
of
permittees
subject
to
its
specific
recordkeeping
and
inspection
requirements.
Annual
Burden
(
Hrs.)
Annual
Costs
Recordkeeping
1,568,158
$
62,777,658
Reporting
(
w/
o
Part
435)
141,122
$
5,032,350
Part
435
Certification
53,516
$
1,635,944
Total
for
Respondents
1,762,796
$
69,445,952
State
Governments
46,784
$
1,526,226
Federal
Governments
18,039
$
570,157
TOTAL
1,827,619
$
71,542,335
Exhibit
13.
Bottom
Line
Annual
Burden
and
Costs
to
Respondents
and
Government
DRAFT
FINAL
Compliance
Assessment
ICR
Page
51
March
26,
2004
!
Compliance
Schedule
Reports.
The
burden
associated
with
this
requirement
is
essentially
unchanged
from
the
previous
ICR.
Slight
reductions
reflect
fewer
permits
identified
in
PCS
that
have
compliance
schedule
report
requirements.

!
Noncompliance
Reports.
The
total
burden
associated
with
this
requirement
decreased
9.7
percent
from
the
previous
ICR.
This
reduction
reflects
a
decrease
in
the
number
of
respondents
subject
to
the
noncompliance
report
requirements.
This
is
likely
due
to
PCS
refinement
resulting
in
fewer
permits
identified.

!
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.
The
burden
associated
with
this
requirement
did
not
change.

!
Certification
for
Exemption
From
Monitoring
and
Notification
of
Process
Changes.
The
burden
associated
with
this
requirement
did
not
change.

!
SSO
Reporting
and
Unpermitted
CSO
Reporting.
No
changes
in
burden
are
estimated
for
this
activity
since
the
previous
ICR.
Item/
Type
of
Respondent
Previous
ICR
(
A)
Current
ICR
(
B)
Change
(
C)
(
B
 
A)
Percent
Change
(
C
÷
A)

Recordkeeping
1,177,116
1,568,158
391,042
33.22%

Compliance
Schedule
Reports
8,930
8,267
­
663
­
7.42%

Noncompliance
Reports
Unanticipated
Bypass/
Upset
Report
24,246
21,015
­
3,231
­
13.33%

Maximum
Daily
Violation
Report
27,697
25,996
­
1,701
­
6.14%

Other
Noncompliance
Reports
3,613
3,123
­
490
­
13.56%

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
1,080
1,080
0
0.00%

Certifications
and
Notice
of
Process
Changes
4,713
4,713
0
0.00%

SSO
Reporting
62,144
62,144
0
0.00%

Unpermitted
CSO
Reporting
5,184
5,184
0
0.00%

Burden
to
State
Governments
as
Users
of
Data
51,089
46,784
­
4,305
­
8.43%

Part
435
Certification
(
former
OMB
ICR
#
2040­
0230)
47,168
53,516
6,348
13.46%

TOTAL
1,422,580
1,809,580
387,000
27.20%
Exhibit
14.
Change
in
Annual
Respondent
and
State
Burden
DRAFT
FINAL
Compliance
Assessment
ICR
Page
52
March
26,
2004
!
Change
in
State
Burden.
The
(
8)
percent
difference
in
State
burden
is
the
result
of
a
fewer
permits
identified
in
PCS
that
have
require
compliance/
assessment
reporting.

6.
g
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
3.76
hours
per
response.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
and
48
CFR
chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
OW­
2003­
0073,
which
is
available
for
public
viewing
at
the
Water
Docket
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Water
Docket
is
(
202)
566­
2426.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
(
OW­
2003­
0073)
and
OMB
control
number
(
2040­
0110)
in
any
correspondence.
DRAFT
FINAL
Compliance
Assessment
ICR
Page
53
March
26,
2004
Appendix
A
­
Input
Parameters
for
Part
435
Burden
Estimate
Input
Parameters
Value*

SBF
Usage
Assumptions:
Total
Number
of
SBF
Wells
(
SBF
wells/
yr.):
204**
Number
of
SBF
Wells
per
SBF
Facility
(
SBF
wells/
fac.):
3
Number
of
SBF
Facilities
per
Year
(
fac./
yr.):
68**
Length
of
SBF
Drilling
Operation
(
months/
SBF­
well):
1
Days
in
month
(
days/
month):
30
Labor
Rate
Assumptions:
Contractor
Engineering
Labor
Rate
($/
hr):
65
Contractor
Senior
Management
Labor
Rate
($/
hr):
100
In­
house
Engineering
Labor
Rate
($/
hr):
65
In­
house
Senior
Management
Labor
Rate
($/
hr):
100
In­
house
Operators/
Shift
Supervisors
Labor
Rate
($/
hr):
20
In­
house
Engineering
Technicians
Labor
Rate
($/
hr):
65
In­
house
Clerical
Support
Labor
Rate
($/
hr):
15
Labor
rate
for
contractor
teaching
Re­
fresher
training
($/
hr):
65
State
NPDES
controlling
authority
labor
rate
($/
hr):
33.6*
EPA
Regional
labor
rate
($/
hr):
33.3*

Labor
Assumptions
(
Development
and
Annual
Review):
Initial
Facility
Contract
Labor
Hours
Required
(
2
SBF
wastestreams)
(
hours):
200
Initial
Facility
Contract
Labor
Hours
Required
(
1
SBF
wastestream)
(
hours):
150
%
of
Initial
Facility
Contract
Labor
Hours
that
are
Engineering
Labor
(%
of
total):
75
%
of
Initial
Facility
Contract
Labor
Hours
that
are
Senior
Management
(%
of
total):
25
Initial
Facility
In­
house
Labor
Hours
Required
(
2
SBF
wastestreams)
(
hours):
150
Initial
Facility
In­
house
Labor
Hours
Required
(
1
SBF
wastestream)
(
hours):
100
%
of
Initial
Facility
In­
house
Labor
Hours
that
are
Engineering
Labor
(%
of
total):
75
%
of
Initial
In­
house
Labor
Hours
that
are
Senior
Management
(%
of
total):
25
Annual
Facility
In­
house
Lab.
Hrs.
for
BMP
Plan
Review
(
2
SBF
wastestreams)
(
hours):
40
Annual
Facility
In­
house
Lab.
Hrs.
for
BMP
Plan
Review
(
1
SBF
wastestream)
(
hours):
30
%
of
Annual
Facility
In­
house
Lab.
Hrs.
for
BMP
Review
that
are
Eng.
Staff
(%
of
total):
75
%
of
Annual
Facility
In­
house
Lab.
Hrs.
for
BMP
Review
that
are
Snr.
Mgmt.
(%
of
total):
25
Labor
Assumptions
(
Spills):
In­
house
Eng.
Lab.
Hrs.
per
SBF
spill
(
hr./
spill):
4
Number
of
SBF
spills
per
SBF
well
(
SBF
spills/
SBF
well):
3
Labor
Assumptions
(
Recordkeeping):
DRAFT
FINAL
Compliance
Assessment
ICR
Page
54
Input
Parameters
Value*

March
26,
2004
Number
of
Recordkeeping
Hours
by
Operators/
Shift
Sup.
per
month
(
hr./
month):
2
Number
of
Recordkeeping
Hours
by
Engineering
Technicians
per
month
(
hr/
month):
2
Number
of
Recordkeeping
Hours
by
Clerical
Staff
per
month
(
hr/
month):
2
Labor
Assumptions
(
Re­
fresher
training):
Number
of
Operators
in
Re­
fresher
training:
9
Number
of
Re­
fresher
training
sessions
per
year:
2
Number
of
hours
per
Re­
fresher
training
session:
4
Number
of
consultants
teaching
re­
fresher
training:
1
Labor
Assumptions
(
Additional
Monitoring
and
Reporting):
Inspection
of
SBF­
Equipment
(
but
not­
solids
control
equipment)
for
spills/
leaks
(
hrs/
day):
3
Inspection
of
SBF­
Equipment
(
but
not­
solids
control
equipment)
for
malfunctions
(
hrs/
day):
3
Inspection
of
solids
control
equipment
for
O&
M
(
hrs/
day):
3
Daily
Retort
analysis
(
hr/
day):
3
Labor
Assumptions
(
State):
Number
of
initial
hours
by
State
NPDES
controlling
authority
(
hr/
yr­
facility):
a
0
Number
of
annual
hours
by
State
NPDES
controlling
authority
(
hr/
yr­
facility):
a
0
Labor
Assumptions
(
EPA
Regions):
Number
of
initial
hours
by
EPA
Region
(
hr/
yr­
facility):
8
Number
of
annual
hours
by
EPA
Region
(
hr/
yr­
facility):
3
*
Source
is
original
ICR
except
for
items
with
**,
which
were
updated
for
inclusion
in
this
document.
a
EPA
has
not
yet
delegated
NPDES
permitting
authority
to
the
State
of
Alaska
where
these
discharges
are
likely
to
occur.
DRAFT
FINAL
Compliance
Assessment
ICR
Page
55
March
26,
2004
Appendix
B
­
Burden
and
Costs
Estimates
(
Part
435)

Table
1:
Facility
Consultant
Burden
and
Costs
for
Development,
Review,
and
Certification
of
BMP
Plans
Labor
Hours
Labor
Costs
Engineering
Management
Total
Engineering
Management
Total
7,650
2,550
10,200
497,217
254,949
752,166
Table
2:
Facility
In­
house
Burden
and
Costs
for
Development,
Review,
and
Certification
of
BMP
Plan
Labor
Hours
Labor
Costs
Engineering
Management
Total
Engineering
Management
Total
5,100
1,700
6,800
331,500
170,000
501,500
Table
3:
Total
Facility
Initial
Burden
and
Costs
Labor
Hours
Labor
Costs
17,000
1,253,666
DRAFT
FINAL
Compliance
Assessment
ICR
Page
56
March
26,
2004
Table
4:
Facility
Labor
Hours
for
Amendment
and
Review
of
BMP
Plan,
Reporting,
Monitoring,
Record
Keeping,
and
Training
Amend.
&
Rvw
BMP
Plan
Reporting
of
Spills
Add'l
Monit.
and
Rpting
Record
Keeping
Refresher
Training
Total
Hours
2,040
2,448
36,720
1,224
5,440
47,872
Table
5:
Facility
Costs
for
Amendment
and
Review
of
BMP
Plan,
Reporting,
Monitoring,
Record
Keeping,
and
Training
Amend.
&
Rvw
BMP
Plan
Reporting
of
Spills
Add'l
Monit.
and
Rpting
Record
Keeping
Refresher
Training
Total
Costs
150,450
159,120
734,400
40,800
133,280
1,218,050
Table
6:
Total
Recurring
Facility
Respondent
Burden
and
Costs
Labor
Hours
Labor
Costs
47,872
1,218,050
DRAFT
FINAL
Compliance
Assessment
ICR
Page
57
March
26,
2004
Table
7:
Summary
of
Burden
Hours
to
Respondents
and
EPA
TOTAL
LABOR
HOURS
Respondents:
Facilities
Respondents:
States
EPA
Initial
Annual
Initial
Annual
Initial
Annual
17,000
47,872
0
0
544
204
Table
8:
Summary
of
Costs
(
2003$)
to
Respondents
and
EPA
TOTAL
COSTS
Respondents:
Facilities
Respondents:
States
EPA
Initial
Annual
Initial
Annual
Initial
Annual
1,235,666
1,218,050
0
0
18,115
6,793
DRAFT
FINAL
Compliance
Assessment
ICR
Page
58
March
26,
2004
References
for
use
of
BMPs
under
Part
435
to
control
NAFs
Angelle,
Richard,
and
Paul
Scott,
2000,
Rig
Survey
Update
Focusing
on
the
Number
of
Rigs/
platforms
Where
Cuttings
Dryers
Could
Not
Be
Installed,
SBF
Rulemaking
Record,
Section
IV.
B.
b.
34,
November
9,
2000.

Henry,
Larry,
Response
to
EPA
Request
for
Additional
Input
Parameter
for
EPA
Modeling,
SBF
Rulemaking
Record,
Section
IV.
B.
a.
9,
September
11,
2000.

Johnston,
Carey
A.,
Initial
Burden
and
Cost
Estimates
for
SBF
BMP
Information
Collection
Request,
SBF
Rulemaking
Record,
Section
III.
H.(
2),
February
28,
2000.

U.
S.
EPA,
Information
Collection
Request
Supporting
Statement
for
Best
Management
Practices
Alternatives,
Effluent
Limitations
Guidelines
and
Standards,
Oil
and
Gas
Extraction
Point
Source
Category
(
40
CFR
Part
435),
EPA
ICR
No.
1953.01,
SBF
Rulemaking
Record,
Section
III.
H.(
5),
April
11,
2000.

U.
S.
EPA,
Development
Document
for
Proposed
Effluent
Limitations
Guidelines
and
Standards
for
Synthetic­
Based
Drilling
Fluids
and
Other
Non­
Aqueous
Drilling
Fluids
in
the
Oil
and
Gas
Extraction
Point
Source
Category,
EPA­
821­
B­
98­
021,
February
1999.

U.
S.
EPA,
Information
Collection
Request
Supporting
Statement
for
Best
Management
Practices
for
the
Bleached
Papergrade
Kraft
and
Soda
Subcategory
and
the
Papergrade
Sulfite
Subcategory
of
the
Pulp,
Paper,
and
Paperboard
Point
Source
Category
(
40
CFR
Part
430),
December
1,
1998.

U.
S.
EPA,
Guidance
Document
for
Developing
Best
Management
Practices
(
BMP),
EPA
833­
BB93B004,
October
1993.
