Appendix A - Burden Estimates

Table A1. Respondents Activities table (permittees)

Activity Description
NOI preparation & submittal
NOI preparation & submittal
NOI preparation & submittal
NOT Preparation & submittal
Develop PDMP
Update PDMP
Monitoring (large site)
Monitoring (small site)
Monitoring
Annual Report preparation & submittal
Adverse Incident Documentation
Adverse Incident verbal notification
Adverse Incident to Threatened or Endangered Species
Spill, Leaks Documentation
Corrective Action Documentation
Permittee Report of Planned Facility Changes
Permittee Report of Anticipated Noncompliance
Permittee Report of Inaccurate Previous Information
Noncompliance Reports
Recordkeeping (basic)
Recordkeeping
Full Recordkeeping
Recordkeeping (PDEW)

Respondent Type
operators - PGP Table 1-1
operators under PGP - informal ESA
operators under PGP - formal ESA
operators - PGP Table 1-1 (all)
operators - NOI filers (large)
operators - NOI filers (large)
operators - NOI filers (large)
operators - NOI filers (small)
other operators
operators - NOI filers (large & ESA)
all operators
all operators
all operators
all operators
all operators
all operators
all operators
all operators
all operators
all operators
operators - non-NOI filers
operators - NOI filers (large)
operators - NOI filers (small)

Total
capital /
Hours per startup
response cost
O&M Cost
2
$0
$0
6
$0
$0
20
$0
$0
0.5
$0
$0
40
$0
$0
2
$0
$0
0.25
$0
$0
0.25
$0
$0
0.25
$0
$0
8
$0
$0
2
$0
$0
2
$0
$0
2
$0
$0
1
$0
$0
5
$0
$0
4
$0
$0
5
$0
$0
2
$0
$0
5
$0
$0
1
$0
$0
0.5
$0
$0
1
$0
$0
1
$0
$0

Total
Annualized Total Number
Captial and of
O&M Cost
Respondents Year 1
Year 2
$0
9,125
1,825
$0
37
7
$0
18
4
$0
456
91
$0
4,836
967
$0
4,836
1,209
$0
4,836
4,836
$0
4,289
4,289
$0
355,875
355,875
$0
4,892
4,892
$0
365,000
37
$0
365,000
37
$0
365,000
4
$0
365,000
365
$0
365,000
365
$0
365,000
365
$0
365,000
365
$0
365,000
183
$0
365,000
183
$0
365,000
365,000
$0
355,875
355,875
$0
4,836
4,836
$0
4,289
4,289

Year 3
1,825
7
4
91
967
1,209
4,836
4,289
355,875
4,892
37
37
4
365
365
365
365
183
183
365,000
355,875
4,836
4,289

1,825
7
4
91
0
1,209
4,836
4,289
355,875
4,892
37
37
4
365
365
365
365
183
183
365,000
355,875
4,836
4,289

Annual
Average
Number of
Respondents
1,825
7
4
91
645
1,209
4,836
4,289
355,875
4,892
37
37
4
365
365
365
365
183
183
365,000
355,875
4,836
4,289

Frequency of Reporting
once every 5 yrs
once every 5 yrs
once every 5 yrs
once
once
ongoing
ongoing
ongoing
ongoing
yearly
occasionally/As Needed
occasionally/As Needed
occasionally/As Needed
occasionally/As Needed
occasionally/As Needed
occasionally/As Needed
occasionally/As Needed
occasionally/As Needed
occasionally/As Needed
ongoing
ongoing
ongoing
ongoing

Type of
Number of
Activitity OMB
Responses
(Reporting /
/
Recordkeeping
respondent Number of
Total Hours
/ 3rd party
/ yr
Responses Year / Year
Total Labor Cost disclosure)
1
1,825
3,650
$272,235 Reporting
1
7
44
$3,312 Reporting
1
4
73
$5,445 Reporting
1
91
46
$4,907 Reporting
1
645
25,793
$1,157,527 Reporting
1
1,209
2,418
$100,618 Reporting
16
77,380
19,345
$804,945 Reporting
4
17,155
4,289
$178,455 Reporting
1
355,875
88,969
$3,701,990 Reporting
1
4,892
39,132
$1,628,283 Reporting
1
37
73
$3,038 Reporting
1
37
73
$3,038 Reporting
1
4
7
$304 Reporting
1
365
365
$15,188 Reporting
1
365
1,825
$75,938 Reporting
1
365
1,460
$60,751 Reporting
1
365
1,825
$75,938 Reporting
1
183
366
$15,229 Reporting
1
183
915
$38,073 Reporting
1
365,000
365,000
$12,063,250 recordkeeping
1
355,875
177,938
$7,403,979 recordkeeping
16
77,380
77,380
$3,219,782 recordkeeping
4
17,155
17,155
$7,630,458 recordkeeping
TOTAL
1,276,395
828,141
$38,462,682

1. Total hours per response are from the EA or ICR for NPDES Program except for the Update PDMP.
2. Total number of respondents: assumed 2.5% of 365,000 respondents are required to submit NOIs; assumed 0.1% of 36,500 respondent will need to address ESA informally and 0.05% formally; assumed 5% of the respondents required to submit NOIs will file NOT; assumed 47% of the respondents required to submit NOIs are small
entities and 53% are large entities; assumed respondent with ESA issue will submit annual reports.
3. Annual number of respondents: total divide by 5 for NOI, NOT, PDMP (5-year permit cycle): update plans - assumed 25%; adverse incident - assumed 0.01%; adverse incident to TES - assumed 0.001%; report of anticipated noncompliance & inaccurate previous info - assumed 0.05%; others - assumed 0.1%
4. Total Labor rate: used same rate as those in the EA updated to 2013 dollars - average managersial rate $107.56, technical rate $41.61, clerical rate $33.05. NOI (50% managerial, 50% technical); NOT (all managerial); PDMP (2hr managerials, 36hr technical, 2hr clerical); PDEW (0.5hr managerials, 9hr technical, 0.5hr clerical); other
activities (technical rate or clerical rate)
5. This ICR marks a shift from the approval period (years 4 and 5 of the PGP) to the permit implementation and renewal period (year 6 of the PGP) when permittees renewing their coverage in year 3 of this ICR (year 6 of the PGP) would not need to develop a new PDMP. This is the reason why there are no respondents assumed to develop
a PDMP in year 3.

Table A2. Respondents Activities table (States)

Activity Description
NOI processing & review
NOT processing & review
Annual Report processing & review
Adverse Incident report review
Permittee Report of Planned Facility Changes
Permittee Report of anticipated noncompliance
Permittee Report of Inaccurate Previous Information
Noncompliance Reports

Respondent Type
States
States
States
States
States
States
States
States

Total
Total
capital /
Annualized Total Number Annual
Number of
Number of
Hours per startup
Capital and of
Number of
Frequency of
Responses /
Responses
response cost
O&M Cost O&M Cost
Respondents Respondents Reporting
respondent /yr Year
Total Hours / Year
0.5
$0
$0
$0
47
47 every 5 yrs
34.94680851
1,643
0.25
$0
$0
$0
47
47 ongoing
1.747340426
82
1
$0
$0
$0
47
47 yearly
93.45542553
4,392
2
$0
$0
$0
47
47 occasionally/As Needed
0.69893617
33
0.5
$0
$0
$0
47
47 occasionally/As Needed
6.989361702
329
2
$0
$0
$0
47
47 occasionally/As Needed
6.989361702
329
1
$0
$0
$0
47
47 occasionally/As Needed
3.504255319
165
2
$0
$0
$0
47
47 occasionally/As Needed
3.504255319
165
TOTAL
7,136

821
21
4,392
66
164
657
165
329
6,615

Total Labor
Cost
$24,802
$620
$132,651
$1,984
$4,960
$19,841
$4,974
$9,948
$199,780

Type of Activity
OMB (Reporting
/ Recordkeeping
/ 3rd party
disclosure)
Reporting
Reporting
Reporting
Reporting
Reporting
Reporting
Reporting
Reporting

Type of
Activity
Obligation of
(EPA
Response OMB
classificatio (mandatory,
n)
voluntary)
1. Application/NOI
mandatory
1. Application/NOI
mandatory
4. Reporting mandatory
4. Reporting mandatory
4. Reporting mandatory
4. Reporting mandatory
4. Reporting mandatory
4. Reporting mandatory

Affected Public
(OMB)
States
States
States
States
States
States
States
States

Type of Activity
OMB (Reporting
/ Recordkeeping
/ 3rd party
disclosure)
Reporting
Reporting
Reporting
Reporting
Reporting
Reporting
Reporting
Reporting
Reporting
Reporting
Reporting

Type of
Activity
Obligation of
(EPA
Response OMB
classificatio (mandatory,
n)
voluntary)
1. Application/NOI
mandatory
1. Application/NOI
mandatory
1. Application/NOI
mandatory
1. Application/NOI
mandatory
4. Reporting mandatory
4. Reporting mandatory
4. Reporting mandatory
4. Reporting mandatory
4. Reporting mandatory
4. Reporting mandatory
4. Reporting mandatory

Affected Public
(OMB)
EPA
Services
Services
EPA
EPA
EPA
Services
EPA
EPA
EPA
EPA

Table A3. Agency Activities Table

Activity Description
Respondent Type
NOI processing & review
EPA
NOI processing & review (informal)
Services
NOI processing & review (formal)
Services
NOT processing & review
EPA
Annual Report processing & review
EPA
Adverse Incident report review
EPA
Adverse Incident to Threatened or Endangered Species
Services
Permittee Report of Planned Facility Changes
EPA
Permittee Report of anticipated noncompliance
EPA
Permittee Report of Inaccurate Previous Information
EPA
Noncompliance Reports
EPA
1. Total hours per response are from the ICR for NPDES Program.
2. Number of responses/yr - EPA is 10% of permittee's total number of responses/yr
3. Labor Rate for Federal is $41.56 and for State is $30.20

Total
capital /
Hours per startup
response cost
0.5
0.5
5
0.25
1
2
2
0.5
2
1
2

Total
Annualized
Capital and
O&M Cost O&M Cost

Total Number Annual
of
Number of
Respondents Respondents

Number of
Number of
Frequency of
Responses /
Responses
Reporting
respondent /yr Year
Total Hours / Year
once every 5 yrs
183
occasionally/As Needed
7
occasionally/As Needed
4
ongoing
9
yearly
500
occasionally/As Needed
4
occasionally/As Needed
4
occasionally/As Needed
37
occasionally/As Needed
37
occasionally/As Needed
18
occasionally/As Needed
18
TOTAL
820

91
4
18
2
500
7
7
18
73
18
37
776

Total Labor
Cost
$3,792
$154
$758
$95
$20,788
$303
$303
$758
$3,034
$761
$1,521
$32,268