Justification for Nonsubstantice Change

Request for a Non-Substantive Change to an Existing Approved Information Collection
I. Introduction
Why is EPA Requesting a Non-Substantive Change?
On October 24, 2016, all ten EPA Regions reissued the final 2016 National Pollutant Discharge
Elimination System (NPDES) pesticide general permit (PGP) – the “2016 PGP.” The 2016 PGP, which
has an effective date of October 31, 2016, replaces the existing permit (“2011 PGP”) that expires at
midnight on October 31, 2016. EPA published the draft 2016 PGP and accompanying Fact Sheet in the
Federal Register on January 26, 2016 (81 FR 4289), soliciting comments on the draft permit.
EPA is requesting a non-substantive change to update the PGP forms in this ICR. Updates on the forms
are intended to streamline electronic reporting and to address comments from users. However, EPA is
not modifying the information collection requirements or adjusting Agency paperwork burden estimates.
II. Description of Non-Substantive Changes
What Information Collection Request (ICR) is EPA changing?
NPDES Pesticide General Permit for Point Source Discharges from the
ICR Title:
Application of Pesticide
ICR Numbers: EPA ICR No. 2397.02; OMB Control No. 2040-0284
What is the current status of this ICR?
This ICR is currently approved through March 31, 2019.
Will this change impact the annual ICR burden estimate?
No. The changes do not affect the estimated annual burden. Although EPA is updating the forms, the
respondent activities are the same.
What are the changes that EPA is making to this collection of information?
Below is a summary of changes EPA made to the PGP forms:
EPA FORM 6100-22, Notice of Intent (NOI) Form
-Updated waiver language to allow use of a paper form instead of the eNOI system.
-Added examples to Section D.2.g. to clarify what information is requested.
EPA FORM 6100-23, Notice of Termination (NOT) Form
-Updated waiver language to allow use of a paper form instead of the eNOI system.
EPA FORM 6100-26, Pesticide Discharge Evaluation Worksheet (PDEW)
-Added a line for the permittee’s NPDES permit number
EPA FORM 6100-25, Annual Report Template
-Updated waiver language to allow use of a paper form instead of the eNOI system.
-Added an option to provide a map of the treatment areas instead of written description.
-Added “briquette” as an option for quantity applied.
EPA FORM 6100-24, Adverse Incident Report Template
-Updated the EPA’s website link.

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