2397supp01 Appendix A - Burden Estimates

Appendix A: Respondents and Agency Activities Table

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, Leak verbal notification
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
all operators
operators - non-NOI filers
operators - NOI filers (large)
operators - NOI filers (small)

Total
Hours
Total
per
capital /
Annualized Total Number Annual
respons startup O&M Captial and of
Number of
e
cost
Cost O&M Cost Respondents Respondents Frequency of Reporting
2
$0
$0
$0
9,125
1,825 once every 5 yrs
6
$0
$0
$0
37
7 once every 5 yrs
20
$0
$0
$0
18
4 once every 5 yrs
0.5
$0
$0
$0
456
91 once
40
$0
$0
$0
4,836
967 once every 5 yrs
2
$0
$0
$0
4,836
1,209 ongoing
0.25
$0
$0
$0
4,836
4,836 ongoing
0.25
$0
$0
$0
4,289
4,289 ongoing
0.25
$0
$0
$0
355,875
355,875 ongoing
8
$0
$0
$0
4,892
4,892 yearly
2
$0
$0
$0
365,000
37 occasionally/As Needed
2
$0
$0
$0
365,000
37 occasionally/As Needed
2
$0
$0
$0
365,000
4 occasionally/As Needed
0
$0
$0
$0
365,000
365 occasionally/As Needed
1
$0
$0
$0
365,000
365 occasionally/As Needed
5
$0
$0
$0
365,000
365 occasionally/As Needed
4
$0
$0
$0
365,000
365 occasionally/As Needed
5
$0
$0
$0
365,000
365 occasionally/As Needed
2
$0
$0
$0
365,000
183 occasionally/As Needed
5
$0
$0
$0
365,000
183 occasionally/As Needed
1
$0
$0
$0
365,000
365,000 ongoing
0.5
$0
$0
$0
355,875
355,875 ongoing
1
$0
$0
$0
4,836
4,836 ongoing
1
$0
$0
$0
4,289
4,289 ongoing

Number
Type of
of
Activitity OMB
Respon
(Reporting /
ses /
Recordkeepin
respond Number of
Total Hours
g / 3rd party
ent / yr Responses Year / Year
Total Labor Cost disclosure)
1
1,825
3,650
$299,300 Reporting
1
7
44
$3,641 Reporting
1
4
73
$5,986 Reporting
1
91
46
$5,156 Reporting
1
967
38,690
$2,073,784 Reporting
1
1,209
2,418
$123,324 Reporting
16
77,380
19,345
$986,595 Reporting
4
17,155
4,289
$218,726 Reporting
1
355,875
88,969
$4,537,406 Reporting
1
4,892
39,132
$1,995,732 Reporting
1
37
73
$3,723 Reporting
1
37
73
$3,723 Reporting
1
4
7
$372 Reporting
1
365
0
$0 Reporting
1
365
365
$18,615 recordkeeping
1
365
1,825
$93,075 recordkeeping
1
365
1,460
$74,460 Reporting
1
365
1,825
$93,075 Reporting
1
183
366
$18,666 Reporting
1
183
915
$46,665 Reporting
1
365,000
365,000
$14,965,000 recordkeeping
1
355,875
177,938
$9,074,813 recordkeeping
16
77,380
77,380
$3,946,380 recordkeeping
4
17,155
17,155
$9,195,080 recordkeeping
TOTAL
1,277,083
841,037
$47,783,297

Type of Activity (EPA
classification)
1. Application/NOI
1. Application/NOI
1. Application/NOI
1. Application/NOI
2. Plan Development
2. Plan Development
3. Monitoring
3. Monitoring
3. Monitoring
4. Reporting
4. Reporting
4. Reporting
4. Reporting
4. Reporting
5. Recordkeeping
5. Recordkeeping
4. Reporting
4. Reporting
4. Reporting
4. Reporting
5. Recordkeeping
5. Recordkeeping
5. Recordkeeping
5. Recordkeeping

Obligation of
Response
OMB
(mandatory,
voluntary)
mandatory
mandatory
mandatory
mandatory
mandatory
mandatory
mandatory
mandatory
mandatory
mandatory
mandatory
mandatory
mandatory
mandatory
mandatory
mandatory
mandatory
mandatory
mandatory
mandatory
mandatory
mandatory
mandatory
mandatory

Affected Public (OMB)
Business, other for-profit, government
Business, other for-profit, government
Business, other for-profit, government
Business, other for-profit, government
Business, other for-profit, government
Business, other for-profit, government
Business, other for-profit, government
Business, other for-profit, government
Business, other for-profit, government
Business, other for-profit, government
Business, other for-profit, government
Business, other for-profit, government
Business, other for-profit, government
Business, other for-profit, government
Business, other for-profit, government
Business, other for-profit, government
Business, other for-profit, government
Business, other for-profit, government
Business, other for-profit, government
Business, other for-profit, government
Business, other for-profit, government
Business, other for-profit, government
Business, other for-profit, government
Business, other for-profit, government

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 - average managersial rate $113, technical rate $51, clerical rate $41. 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)

September 2011

Appendix A: Respondents and Agency Activities Table

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
Hours
Total
per
capital /
Annualized Total Number Annual
respons startup O&M Captial and of
Number of
e
cost
Cost O&M Cost Respondents Respondents Frequency of Reporting
0.5
$0
$0
$0
45
45 every 5 yrs
0.25
$0
$0
$0
45
45 ongoing
1
$0
$0
$0
45
45 yearly
2
$0
$0
$0
45
45 occasionally/As Needed
0.5
$0
$0
$0
45
45 occasionally/As Needed
2
$0
$0
$0
45
45 occasionally/As Needed
1
$0
$0
$0
45
45 occasionally/As Needed
2
$0
$0
$0
45
45 occasionally/As Needed

Number
of
Respon
ses /
respond Number of
Total Hours
ent /yr
Responses Year / Year
Total Labor Cost
36.5
1,643
821
$31,208
1.825
82
21
$780
97.609
4,392
4,392
$166,911
0.73
33
66
$2,497
7.3
329
164
$6,242
7.3
329
657
$24,966
3.66
165
165
$6,259
3.66
165
329
$12,517
TOTAL
7,136
6,615
$251,379

Type of
Activitity OMB
(Reporting /
Recordkeepin
g / 3rd party
disclosure)
Reporting
Reporting
Reporting
Reporting
Reporting
Reporting
Reporting
Reporting

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

Number
of
Respon
ses /
respond Number of
Total Hours
ent /yr
Responses Year / Year
Total Labor Cost
183
91
$3,737
7
4
$152
4
18
$747
9
2
$93
500
500
$20,483
4
7
$299
4
7
$299
37
18
$747
37
73
$2,989
18
18
$749
18
37
$1,499
TOTAL
820
776
$31,795

Type of
Activitity OMB
(Reporting /
Recordkeepin
g / 3rd party
disclosure)
Reporting
Reporting
Reporting
Reporting
Reporting
Reporting
Reporting
Reporting
Reporting
Reporting
Reporting

Type of Activity (EPA
classification)
1. Application/NOI
1. Application/NOI
4. Reporting
4. Reporting
4. Reporting
4. Reporting
4. Reporting
4. Reporting

Obligation of
Response
OMB
(mandatory,
voluntary)
mandatory
mandatory
mandatory
mandatory
mandatory
mandatory
mandatory
mandatory

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

Type of Activity (EPA
classification)
1. Application/NOI
1. Application/NOI
1. Application/NOI
1. Application/NOI
4. Reporting
4. Reporting
4. Reporting
4. Reporting
4. Reporting
4. Reporting
4. Reporting

Obligation of
Response
OMB
(mandatory,
voluntary)
mandatory
mandatory
mandatory
mandatory
mandatory
mandatory
mandatory
mandatory
mandatory
mandatory
mandatory

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

Table A3. Agency Activities Tabel

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 $40.95 and for State is $38.

September 2011

Total
Annualized
O&M Captial and
Cost O&M Cost

Total Number Annual
of
Number of
Respondents Respondents Frequency of Reporting
once every 5 yrs
occasionally/As Needed
occasionally/As Needed
ongoing
yearly
occasionally/As Needed
occasionally/As Needed
occasionally/As Needed
occasionally/As Needed
occasionally/As Needed
occasionally/As Needed