Burden Tables

Submitted to OMB with Second Federal Register Notice-2018

TABLE A-1. AVERAGE ANNUAL COST TO THE FEDERAL
GOVERNMENT

Activity

Average Annual
Burden Hours
(from Table A-3)

Hourly Cost

2,560

$79.03

a

$202,317

2,288

$37.80

b

$86,486

1,960

$37.80

b

$74,088

160
6,968

$37.80

b

$6,048
$368,939

Technical Review of revised
application & reapplication
Evaluate revised
applications/reapplications
for compliance with 301(h)
criteria/prepare 301(h)
decisions
Evaluate monitoring and
toxic control program
adequacy
Review State
determinations and State
certifications and coordinate
with State
TOTAL

Average Annual Cost

aIt is assumed that the majority of reapplications and additional information submissions are reviewed by a
contractor. It is further assumed that the salary level of a contractor working on the 301(h) program is 15
percent higher than that of a GS-9, Step 10, $71,467 or $82,187/year. Thus, based on 2,080 working
hours/year, the average salary of a contractor is $39.51/hour. Assuming 100 percent overhead costs for the
private sector, the labor cost for contractors is $79.03. (Hourly rate based on 2017 DC-B salary rate table.)
b

It is assumed that the salary level of the typical government employee working on the 301(h) program is a
GS-9, Step 10 salary, or $71,467/year. Based on 2,080 working hours/year, the average hourly salary of a
Federal employee is $34.36/hour. Assuming 10 percent overhead costs, the labor cost for Federal
employees is $37.80/hour. (Hourly rate based on 2017 DC-B salary rate table.)
NOTE: Numbers may not add due to rounding.

Submitted to OMB with Second Federal Register Notice--2018

TABLE A-2. COST TO POTW AND STATE

Activity
COST TO POTW RESPONDENTS
Application Revision
Reapplication
Monitoring Program
Toxics Control Program
TOTAL
COST TO STATE RESPONDENTS
Determination
Certification
TOTAL
TOTAL POTW AND STATE
RESPONDENTS

Average
Annual
Burden Hourly
Cost
Hours

Average
Annual
Cost

1,791
2,641
19,208
15,120
38,760

$79.03
$79.03
$21.11
$21.11

a

960
320
1,280

29.07
29.07

c

40,040

a
b
b

c

$141,543
$208,718
$405,481
$319,183
$1,074,925
$27,907
$9,302
$37,210

$1,112,135

a

It is assumed that much of the reapplication and additional information is prepared by a
contractor with specialized expertise and equipment. It is further assumed that the salary
level of a contractor working on the 301(h) program is 15 percent higher than that of a GS9, Step 10, $71,467, or $82,187/year. Thus, based on 2,080 working hours/year, the
average hourly salary of a contractor is $39.51/hour. Assuming 100 percent overhead
costs for the private sector, the labor cost for contractors is $79.03/hour. (Hourly rate
based on 2017 DC-B salary rate table.)
b

It is assumed that the salary level of a typical local government employee working on the
301(h) program is a GS-5, Step 4, or $39,911. Based on 2,080 working hours/year, the
average hourly salary of a local employee is $19.19/hour. Assuming 10 percent overhead
costs, the labor cost for local government employees is $21.11hour. (Hourly rate based on
2017 DC-B salary rate table.)
c

It is assumed that the salary level of a typical State government employee working on the
301(h) program is a GS-9, Step 1, or $54,972/year. Based on 2,080 working hours/year,
the average hourly salary of a State government employee is $26.43/hour. Assuming 10
percent overhead costs, the labor cost for State government employees is $29.07/hour.
(Hourly rate based on 2017 DC-B salary rate table.)

Submitted to OMB with Second Federal Register Notice--2018

TABLE A-3. FEDERAL GOVERNMENT BURDEN
Number of Permits to be Processed Annuallya
FY 2018
FY 2017
FY 2019

Burden Hours/Activity
Activity
Technical review of
revised application and
reapplication
Evaluate revised
applications and
reapplications for
compliance with 301(h)
criteria
Evaluate monitoring
and toxic control
program adequacy
Review State
determinations and
State certifications and
coordinate with the
State
TOTAL

Federal Burden Hours/Activity for 3
Years of ICR
TOTAL

Average
Annual
Burdenb

S

L

S

L

S

L

S

L

S

L

360

1650

1

2

1

1

1

1

1,080

6,600

7,680

2,560

208

1040

4

2

4

1

5

1

2,704

4,160

6,864

2,288

60

100

21

7

21

7

21

7

3,780

2,100

5,880

1,960

20

20

5

4

5

2

6

2

320
7,884

160
13,020

480
20,904

160
6,968

NOTE: S = small, L = large
Incorporates EPA's estimate of how many permittees are expected to revise applications and apply for reissuance. These numbers are consistent with those used on Tables A-6, A-7, A-8, and A-10.

a
b

Calculated by dividing total by 3.

Submitted to OMB with Second Federal Register Notice--2018

TABLE A-4. ANNUAL, TOTAL AND AVERAGE BURDENS FOR EACH OF THE SIX INFORMATION ACTIVITIES
Activity/Unit Burden

FY 2017
Number Burden
Affected
All

Burden
Hours

Application Revision (POTW)
Sm Facility Hr.
Lg. Facility Hr.
SUBTOTAL
Reapplication (POTW)
Sm Facility Hr.
Lg. Facility Hr.
SUBTOTAL
Monitoring (POTW)
Sm Facility Hr.
Lg. Facility Hr.
SUBTOTAL
Toxics Control
Sm Facility Hr.
Lg. Facility Hr.
SUBTOTAL
TOTAL (POTWs)
Sm Facility Hr.
Lg Facility Hr.
TOTAL (All POTWs)a

FY 2019
Number
Affected Burden All

TOTAL
Number
Affected Burden All

Average
Number
Affected Burden All

255
1,152

1
2
3

255
2,304
2,559

1
1
2

255
1,152
1,407

1
1
2

255
1,152
1,407

3
4
7

765
4,608
5,373

1
1
2

255
1,536
1,791

255
1,152

4
2
6

1,020
2,304
3,324

4
1
5

1,020
1,152
2,172

5
1
6

1,275
1,152
2,427

13
4
17

3,315
4,608
7,923

4
1
6

1,105
1,536
2,641

328
1,760

21
7
28

6,888
12,320
19,208

21
7
28

6,888
12,320
19,208

21
7
28

6,888
12,320
19,208

63
21
84

20,664
36,960
57,624

21
7
28

6,888
12,320
19,208

80
1,920

21
7
28

1,680
13,440
15,120

21
7
28

1,680
13,440
15,120

21
7
28

1,680
13,440
15,120

63
21
84

5,040
40,320
45,360

21
7
28

1,680
13,440
15,120

21
7
28

9,843
30,368
40,211

21
7
28

9,843
28,064
37,907

21
7
28

10,098
28,064
38,162

63
21
84

29,784
86,496
116,280

21
7
28

9,928
28,832
38,760

90
180

5
4
9

450
720
1,170

5
2
7

450
360
810

6
2
8

540
360
900

16
8
24

1,440
1,440
2,880

5
3
8

480
480
960

30
60

5
4
9
6

150
240
390
1,560

5
2
7
6

150
120
270
1,080

6
2
8
6

180
120
300
1,200

16
8
24
6

480
480
960
3,840

5
3
8
6

160
160
320
1,280

34

41,771

34

38,987

34

39,362

34

120,120

34

40,040

Determination (States)
Sm Facility Hr.
Lg Facility Hr.
SUBTOTAL
Certification (States)
Sm Facility Hr.
Lg Facility Hr.
SUBTOTAL
b
Total (States)
GRAND TOTAL(States +
POTWs)
a

There are 28 POTWs in the 301(h) universe.

b

FY 2018
Number
Affected Burden All

There are 6 States in the 301(h) universe.

Submitted to OMB with Second Federal Register Notice-2018

TABLE A-5. APPLICATION REVISION
AND REAPPLICATION ACTIVITIES
AND BURDEN HOURS FOR POTWS

Activities
Read Instructions
Plan Activities
Create Information
Gather Information
Complete Information
TOTAL

Burden Hours
Small
Large
8
16
8
16
80
320
135
320
24
480
255
1,152

Submitted to OMB with Second Federal Register Notice-2018

TABLE A-6. ANNUAL POTW RESPONDENTS AND TOTAL ANNUAL BURDEN OF APPLICATION
REVISION
FY 2017
Number of
Respondents
Burden (burden from
Table A-5 x number
of respondents)
Note: S = small, L = large
a

Calculated by dividing the
total small and large
POTWs for 3 years by 3.

FY 2018

FY 2019

Average
Annuala

TOTAL

S

L

S

L

S

L

S

L

1

2

1

1

1

1

3

4

2

255

2,304

255

1,152

255

1,152

765

4,608

1,791

Submitted to OMB with Second Federal Register Notice--2018

TABLE A-7. ANNUAL POTW RESPONDENTS AND TOTAL ANNUAL BURDEN OF
REAPPLICATION
FY 2017
Number of
Respondents
Burden (burden from
Table A-5 x number
of respondents)
Note: S = small, L = large
a

Calculated by dividing the
total small plus large
POTWs for 3 years by 3.

FY 2018

FY 2019

Average
Annuala

TOTAL

S

L

S

L

S

L

S

L

4

2

4

1

5

1

13

4

6

1,020

2,304

1,020

1,152

1,275

1,152

4,608

2,641

3,315

Submitted to OMB with Second Federal Register Notice-2018

TABLE A-8. ANNUAL POTW RESPONDENTS AND TOTAL ANNUAL BURDEN OF MONITORING AND TOXICS
CONTROL PROGRAM

Monitoring Program
Toxics Control
Program

Number of Respondents
FY 2017
FY 2018
FY 2019
S
L
S
L
S
L
21
7
21
7
21
7
21

7

21

7

21

7

Average
Burden
Annual Burden
Annual Number Hours/Permittee
of
S
L
FY 2017 FY 2018 FY 2019
Respondents
28
328
1,760 19,208
19,208
19,208
28

Note: S = small, L = large
a

Calculated by dividing the total annual burden of small plus large POTWs for 3 years by 3.

80

1,920

15,120

15,120

15,120

Average
Annual
Burdena
TOTAL
57,624

19,208

45,360

15,120

Submitted to OMB with Second Federal Register Notice-2018

TABLE A-9. BURDEN FOR STATE DETERMINATIONS AND
401(A)(1) CERTIFICATIONS
Burden (Hours/Activity)
State Determination
401 Certification
a
a
Small
Large
Activity
Small
Large
Identify Applicable Requirements
8
8
4
4
Analyze Material
69
155
17
43
Review Accuracy
8
10
4
6
5
7
5
7
Report Information
TOTAL
90
180
30
60
a

Burden for application revisions and reapplications.

Submitted to OMB with Second Federal Register Notice-2018

TABLE A-10. ANNUAL RESPONDENTS AND TOTAL ANNUAL BURDEN OF STATE
DETERMINATIONS

Number of Respondents
Burdenb

FY 2017a
S
L
5
4
450
720

FY 2018
S
L
5
2
450
360

FY 2019
S
L
6
2
540
360

Note: S = small, L = large
a

Calculated by dividing the number of respondents and the total burden for 3 years by 3. There are 6 states in the
301(h) universe.
b

Calculated by multiplying burden estimates in Table A-9 by the corresponding number of respondents in each
information submission category.

Average
Annuala
24
8
2,880
960

Total

Submitted to OMB with Second Federal Register Notice-2018

TABLE A-11. ANNUAL RESPONDENTS AND TOTAL ANNUAL BURDEN OF STATE
401(a)(1) CERTIFICATION
Number of Respondentsb
Burdenc

FY 2017
S
L
5
4
150
240

FY 2018
S
5
150

L
2
120

FY 2019
S
6
180

L
2
120

Total
24
960

Average
Annuala
8
320

Note: S = small, L = large
a

Calculated by dividing total burden hours and number of respondents for the 3 years by 3. There are 6 states in the 301(h)
universe.
b

Number derived by assuming 24 permit reapplications and application revisions over 3 years of the ICR; 16 small and 8 large; and will
result in the final approval and preparation of a draft permit, thus requiring State certification. It is assumed that the application review
process takes approximately one year.

c

Calculated by multiplying burden estimates in Table A-9 by number of respondents.

Submitted to OMB with Second Federal Register Notice--2018

TABLE A-12. SUMMARY TABLEa

Respondent/Activity
POTWs
Application Revision
Reapplication
Monitoring Program
Toxics Control Program
TOTAL: POTWs
STATES
Determinations
Certifications
TOTAL: STATES
TOTAL: POTWs AND STATES
a

Average of 3 years divided by 3.
Hours per response were calculated
by dividing the average annual burden
by the number of respondents. Values
have been rounded to the nearest hour.
b

Number of
Respondents/Responses

Hours per
Responseb

2
6
28
28

896
440
686
540

1,791
2,641
19,208
15,120
38,760

8
8

120
40

960
320
1,280
40,040

28

6
34

Average Annual
Burden

Submitted to OMB with Second Federal Register Notice--2018

TABLE A-13. EXPLANATION OF CHANGE IN BURDEN
Activity

Burden from
Previous ICR

Difference

Reason for Change

Application Revision
Reapplication

2,559
3,963

1,791
2,641

-768
-1,322

Fewer respondentsa
Fewer respondentsa

Monitoring Program
Toxics Control
Program
State Determination

27,888

19,208

-8,680

Fewer respondentsa

23,200
1,320

15,120
960

-8,080
-360

Fewer respondentsa
Fewer respondentsab

440

320

-120

Fewer respondentsab

59,370

40,040

-19,330

Fewer respondentsab

State Certification
TOTAL
a

301(h) universe has decreased since the previous ICR

b

Number of States in 301(h) universe has decreased since the previous ICR