Appendix A

Appendix A.	Assumptions for Developing Burden and Cost Estimates

Table 1 provides a list of the key data inputs used to determine burden
hours and costs for the National Pretreatment Program ICR.  This
appendix provides a description of the source of these data elements. 
In addition, the ICR relied on several assumptions regarding the
relative percentages of respondents performing various tasks.  The
appendix also summarizes these key assumptions.

Some of the assumptions described in this section are carried forward
from the Pretreatment Streamlining ICR (Revision of the Information
Collection Request for the National Pretreatment Program of September
22, 2005 [EPA ICR No: 0002.12, OMB Control No. 2040-0009,]). The
September 2005 ICR recalculated the entire pretreatment program,
including activities resulting from provisions not modified by the
Streamlining Rule. All burden assumptions were subject to public review,
and EPA did not receive any comments related to them.

Table 1  Data and Assumptions Used in Pretreatment ICR

	Pretreatment Program Data	Numbers

1.	Total Number of SIUs	23,193

2.	Number of CIUs	11,010

3.	Number of noncategorical-SIUs	12,183

4.	Number of Zero-Discharge NSCIUs	633

5.	Number of CIUs that Discharge > 0 and < 100 gpd	1,019

6.	Number of Non-Zero-Discharge NSCIUs	296

7.	Number of NSCIUs	928

8.	Number of Middle Tier CIUs	3,303

9. 	Number of Middle Tier CIUs that reduce monitoring	958

10.	Number of State Run POTW Pretreatment Programs in 40 CFR §403.10(e)
States 	51

11.	Total Number of Approved Programs	1,512

12.	Number of 40 CFR §403.10(e) States	5

13.	Number of States eligible for Excellence Awards submissions	30

14.	Number of States with approved Pretreatment Programs	35

15.	Number of SIUs with POTWs as Control Authority	22,370

16.	Percentage of SIUs with POTWs as Control Authority	96.5%

17.	Number of SIUs with State/EPA as Control Authority	823

18.	Percentage of SIUs with State/EPA as Control Authority	3.5%

19.	Percentage of SIUs Resampling (for violations)	10%

20.	Hourly Rate for Federal employees (50% Overhead (OH))	39.06

21.	Hourly Rate for State employees (50% OH)	38.21

22.	Hourly Rate for POTW employees (50% OH)	25.68

23.	Hourly Rate for Private Industry employees (100% OH)	66.48

24.	Number of New Source CIUs	225

25.	Number of POTWs with EPA as Approval Authority	397

26.	Percentage of POTWs with EPA as Approval Authority	26.26%

27.	Number of POTWs with State as Approval Authority	1,115

28.	Percentage of POTWs with State as Approval Authority	73.74%

29.	Number of POTWs projected to develop a pretreatment program during
the three-year ICR period	64

30.	Removal Credit Approval Requests	3



ICR Input Data

Total Number of Significant Industrial Users (SIUs) - This number is
derived from Permit Compliance System (PCS) data, as obtained from a
February 2007 query, GPRA data from December 2006, and input from EPA
headquarters and regional staff responsible for overseeing the
pretreatment program.

Number of Categorical Industrial Users (CIU) - This number is derived
from Permit Compliance System (PCS) data, as obtained from a February
2007 query and input from EPA headquarters and regional staff
responsible for overseeing the pretreatment program.

Number of Non-Categorical SIUs - The mathematical difference between 1
and 2 above.

Number of Zero-Discharge NSCIUs - The percentage of zero-discharge
NSCIUs (5.75% is derived from data from annual Pretreatment Program
Reports, Pretreatment Excellence Awards applications, and public
comments on the proposed Streamlining Rule. This estimate is carried
forward from the assumptions in the recalculation of the entire
pretreatment program, which was done as part of the Streamlining Rule
ICR (EPA ICR No. 0002.12) and is explained at the beginning of this
section. The percentage is applied to the number of CIUs.  All
zero-discharge CIUs are assumed to be NSCIUs.

Number of CIUs that Discharge > 0 and < 100 gpd - The percentage of CIUs
with flows of less than 100 gpd but greater than zero (9.26%) is derived
from data from annual Pretreatment Program Reports, Pretreatment
Excellence Awards applications, and public comments on the proposed
Streamlining Rule.  This estimate is carried forward from the
assumptions in the recalculation of the entire pretreatment program,
which was done as part of the Streamlining Rule ICR (EPA ICR No.
0002.12) and is explained at the beginning of this section. The
percentage is applied to the number of CIUs.

Number of Non-Zero Discharge NSCIUs - The percentage of dischargers with
flows of less than 100 gpd but greater than zero that will be deemed
non-significant is based on data carried forward from the assumptions in
the recalculation of the entire pretreatment program, which was done as
part of the Streamlining Rule ICR (EPA ICR No. 0002.12) and is explained
at the beginning of this section. on compliance reporting requirements
in eight POTW programs.  These data showed that 71% of small CIUs were
required to monitor more than twice per year.  It was assumed that
compliance reporting requirements continued for these 71%.  Twenty-nine
percent (1 – 71%) were assumed to be NSCIUs.  The percentage is
applied to the number derived in Item 5.

Number of NSCIUs - This number was calculated by adding the number of
zero discharging CIUs to the number of CIUs that discharge between 0 and
100 gallons per day that will be deemed NSCIUs.

Number of Middle-Tier CIUs - The percentage of Middle-Tier CIUs
(approximately 30%) is derived from data from annual Pretreatment
Program Reports combined with data from the Metal Products and Machinery
Database.  This estimate is carried forward from the assumptions in the
recalculation of the entire pretreatment program, which was done as part
of the Streamlining Rule ICR (EPA ICR No. 0002.12) and is explained at
the beginning of this section. The percentage is applied to the number
of CIUs.

Number of Middle-Tier CIUs With Reduced Monitoring - The percentage of
Middle-Tier CIUs that will become subject to reduced compliance
reporting requirements is based on data carried forward from the
assumptions in the recalculation of the entire pretreatment program,
which was done as part of the Streamlining Rule ICR (EPA ICR No.
0002.12) and is explained at the beginning of this section. on
compliance reporting requirements in eight POTW programs.  These data
showed that 71% of small CIUs were required to monitor more than twice
per year.  It was assumed that compliance reporting requirements
continued for these 71%.  Twenty-nine percent (1 – 71%) were assumed
reduce monitoring frequency to once per year.  The percentage is applied
to the number derived in Item 8.

Number of State-Run POTW Pretreatment Programs in 40 CFR 403.10(e)
States - This number was estimated by dividing the total number of SIUs
regulated by States/EPA (and not by approved POTW Pretreatment Programs)
by the average number of SIUs per approved pretreatment program. The
methodology for estimating this number was carried forward from the
Streamlining Rule ICR (EPA ICR No. 0002.12).

Total Number of Approved Programs - This number is derived from Permit
Compliance System (PCS) data, as obtained from a February 2007 query,
GPRA data from December 2006, and input from EPA headquarters and
regional staff responsible for overseeing the pretreatment program.

Number of 40 CFR 403.10(e) States - Five: Alabama, Connecticut,
Mississippi, Nebraska, and Vermont.

Number of States with POTWs that are Eligible to Receive Excellence
Award - 30, which is the total number of approved, authorized state with
pretreatment programs (35) minus the five 40 CFR 403.10(e) states.

Number of States with Approved Pretreatment Programs - 35, per EPA
Headquarters.

15.-16	Number and Percentage of SIUs with POTWs as Control Authority –
These numbers are derived from Permit Compliance System (PCS) data, as
obtained from a February 2007 query, GPRA data from December 2006, and
input from EPA headquarters and regional staff responsible for
overseeing the pretreatment program.

17.-18 	Number and Percent of SIUs with State/EPA as Control Authority -
These number are derived from Permit Compliance System (PCS) data, as
obtained from a February 2007 query, GPRA data from December 2006, and
input from EPA headquarters and regional staff responsible for
overseeing the pretreatment program. It includes SIUs in 40 CFR
403.10(e) States, as well as SIUs regulated by States/EPA in
non-pretreatment cities.

19. 	Percentage of SIUs Resampling - This assumption is carried forward
from the recalculation of the entire pretreatment program, which was
done as part of the Streamlining Rule ICR (EPA ICR No. 0002.12) and is
explained at the beginning of this section.

20. 	Hourly Rate for Federal Employees - The hourly employment cost of
federal employees was determined using methodology established in
previous ICRs. According to the U.S. Office of Personnel Management,
January 2007 General Schedule (2007-GS), the average annual salary of a
government employee at the GS-9, Step 10 level is $54,155. At 2,080
hours per year, the hourly wage would be $26.04. Assuming overhead costs
of 50 percent, or $13.02 per hour, the fully loaded cost of employment
for a federal employee would be $39.06.

21. 	Hourly Rate for State Employees - The average hourly rate for
municipal employees as determined by the Bureau of Labor Statistics in
the Employer Costs for Employee Compensation, Table 3- Employer costs
per hour worked for employee compensation and costs as a percent of
total compensation: state and local government, by selected
characteristics (September 2006), adjusted to a December 2006 dollars
using the December 2006 Employment Cost Index (ECI). A 50 percent
overhead rate was added to this rate to arrive at an hourly rate of
$38.21.

22. 	Hourly Rate for POTW Employees - The average hourly rate for
municipal employees, which account for all POTW costs, as determined by
the U.S. Department of Labor, Bureau of Labor Statistics, is $25.68
(including overhead). Updated rates are derived from the U.S. Department
of Labor, Bureau of Labor Statistics, in a table entitled May 2005
National Industry-Specific Occupational Employment and Wage Estimates
and adjusted to December 2006 dollars using the December 2006 ECI.

23. 	Hourly Rate for Private Sector Employees - This average hourly rate
for private sector employees is consistent with rates used in other
recent OWM ICR submittals and represents the labor rate for IUs. Labor
Rate was updated to 2006 dollars.

24. 	Number of New Source CIUs - Assumed a 2 percent annual increase in
the number of operational CIUs. This assumption is based on US Census
Bureau data and is carried forward from the recalculation of the entire
pretreatment program, which was done as part of the Streamlining Rule
ICR (EPA ICR No. 0002.12) and is explained at the beginning of this
section.

25-26.	Number and Percentage of POTWs with EPA as Approval Authority -
These numbers are derived from Permit Compliance System (PCS) data, as
obtained from a February 2007 query, GPRA data from December 2006, and
input from EPA headquarters and regional staff responsible for
overseeing the pretreatment program. This is based on the number of
POTWs in non-approved states.

27-28.	Number and Percentage of POTWs with State as Approval Authority -
These numbers are derived from Permit Compliance System (PCS) data, as
obtained from a February 2007 query, GPRA data from December 2006, and
input from EPA headquarters and regional staff responsible for
overseeing the pretreatment program. This is the based on the number of
POTWs in approved states.

29. 	Number of POTWs projected to develop a Pretreatment Program during
the life of this ICR – Based on projections from EPA regional offices.

30. 	Removal Credit Approval Requests – EPA estimates four respondents
per year.  Based on projections from EPA regional offices.

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