Overall, EPA
should be commended for the completeness of this ICR for the
proposed Stormwater Rule as well as making the information
requirements flexible, accounting for site-specific variability,
givin critical responsibilities to local governments, limiting
sampling to only what is necessary, allowing for different
management controls, avoiding duplication in spill reporting, and
adopting less burdensome forms for stormwater (Form 2F). However,
OMB is not approving the ICR because there are a few question and
issues outlined below which need to be addressed to demonstrate
that the criteria of 5 CFR 1320 have been met. (1) What is the
basis for the 10 ppb quantitative data reporting cuto (see p. 42)?
Are there alternative criteria for defining diminimus discharges or
runoff that could be used to limit burden yet still cove
significant discharges? (2) Can the permiting scope and burden for
industrial facilities be limited to uncovered storage and/or
transfer areas where chemical releases are more likely to end up in
stormwater? (3) What value does the pesticide distributor list have
in the plans? (4) Shouldn't the discussion of past activities in
the description of significant materials be limited to information
relevant to current an future stormwater runoff? Finally, the use
of Form 2D by new dischargers needs to be estimated. NOTE: THIS
ACTION IS A "DISAPPROVE AND CONTINUE" ACTION.
Inventory as of this Action
Requested
Previously Approved
07/31/1988
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INFORMATION IN PERMIT APPLICATIONS IS
USED TO DRAFT NPDES PERMITS FOR STORM WATER DISCHARGES TO SURFACE
WATERS.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.