Burden Tables

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Overview

TableA1
TableA2
TableA3
TableA4
TableA5
TableA6
TableA7
TableA8
TableA9
TableA10
TableA11
TableA12
TableA13

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Sheet 1: TableA1

TABLE A-1. AVERAGE ANNUAL COST TO THE FEDERAL GOVERNMENT
Activity	Average Annual Burden Hours (from Table A-3)	Hourly Cost		Average Annual Cost
Technical Review of revised application & reapplication	2,560	$85.58	a	$219,085
Evaluate revised applications/reapplications for compliance with 301(h) criteria/prepare 301(h) decisions	2,080	$47.07	b	$97,906
Evaluate monitoring and toxic control program adequacy	1,860	$47.07	b	$87,550
Review State determinations and State certifications and coordinate with State	140	$47.07	b	$6,590
TOTAL	6,640			$411,131
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, $77,396 or $89,005/year. Thus, based on 2,080 working hours/year, the average salary of a contractor is $42.79/hour. Assuming 100 percent overhead costs for the private sector, the labor cost for contractors is $85.58. (Hourly rate based on 2020 DC-B salary rate table.)
bIt is assumed that the salary level of a typical government employee working on the 301(h) program is $77,396/year. Based on 2,080 working hours/year, the average hourly salary of a Federal employee is $42.79/hour. Assuming 10 percent overhead costs, the labor cost for Federal employees is $47.07/hour. (Hourly rate based on 2020 DC-B salary rate table.)
NOTE: Numbers may not add due to rounding.

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Sheet 2: TableA2

TABLE A-2. COST TO POTW AND STATE RESPONDENTS
Activity	Average Annual Burden Hours	Hourly Cost		Average Annual Cost
COST TO POTW RESPONDENTS
Application Revision	1,791	$85.58	a	$153,274
Reapplication	2,386	$85.58	a	$204,194
Monitoring Program	21,088	$22.86	b	$482,072
Toxics Control Program	18,560	$22.86	b	$424,282
TOTAL	43,825			$1,263,822
COST TO STATE RESPONDENTS
Determination	870	31.48	c	$27,388
Certification	290	31.48	c	$9,129
TOTAL	1,160			$36,517
TOTAL POTW AND STATE RESPONDENTS	44,985			$1,300,339
aIt 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 GS-9, Step 10, $77,396, or $89,005/year. Thus, based on 2,080 working hours/year, the average hourly salary of a contractor is $42.79/hour. Assuming 100 percent overhead costs for the private sector, the labor cost for contractors is $85.58/hour. (Hourly rate based on 2020 DC-B salary rate table.)
bIt 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 $43,222. Based on 2,080 working hours/year, the average hourly salary of a local employee is $20.78/hour. Assuming 10 percent overhead costs, the labor cost for local government employees is $22.86/hour. (Hourly rate based on 2020 DC-B salary rate table.)
cIt 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 $59,534/year. Based on 2,080 working hours/year, the average hourly salary of a State government employee is $28.62/hour. Assuming 10 percent overhead costs, the labor cost for State government employees is $31.48/hour. (Hourly rate based on 2020 DC-B salary rate table.)

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Sheet 3: TableA3

TABLE A-3. FEDERAL GOVERNMENT BURDEN
	Burden Hours/Activity		Number of Permits to be Processed Annuallya						Federal Burden Hours/Activity for 3 Years of ICR
			FY 2021		FY 2022		FY 2023					Average Annual Burdenb
Activity	S	L	S	L	S	L	S	L	S	L	TOTAL
Technical review of revised application and reapplication	360	1650	1	2	1	1	1	1	1,080	6,600	7,680	2,560
Evaluate revised applications and reapplications for compliance with 301(h) criteria	208	1040	3	2	3	1	4	1	2,080	4,160	6,240	2,080
Evaluate monitoring and toxic control program adequacy	60	100	16	9	16	9	16	9	2,880	2,700	5,580	1,860
Review State determinations and State certifications and coordinate with the State	20	20	4	4	4	2	5	2	260	160	420	140
TOTAL									6,300	13,620	19,920	6,640
NOTE: S = small, L = large
aIncorporates 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.
bCalculated by dividing total by 3.

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Sheet 4: TableA4

TABLE A-4. ANNUAL, TOTAL AND AVERAGE BURDENS FOR EACH OF THE SIX INFORMATION ACTIVITIES
		FY 2021		FY 2022		FY 2023		TOTAL		Average
Activity/Unit Burden	Burden Hours	Number Affected	Burden All	Number Affected	Burden All	Number Affected	Burden All	Number Affected	Burden All	Number Affected	Burden All
Application Revision (POTW)
Sm Facility Hr.	255	1	255	1	255	1	255	3	765	1	255
Lg. Facility Hr.	1,152	2	2,304	1	1,152	1	1,152	4	4,608	1	1,536
SUBTOTAL		3	2,559	2	1,407	2	1,407	7	5,373	2	1,791
Reapplication (POTW)
Sm Facility Hr.	255	3	765	3	765	4	1,020	10	2,550	3	850
Lg. Facility Hr.	1,152	2	2,304	1	1,152	1	1,152	4	4,608	2	2,304
SUBTOTAL		5	3,069	4	1,917	5	2,172	14	7,158	5	2,386
Monitoring (POTW)
Sm Facility Hr.	328	16	5,248	16	5,248	16	5,248	48	15,744	16	5,248
Lg. Facility Hr.	1,760	9	15,840	9	15,840	9	15,840	27	47,520	9	15,840
SUBTOTAL		25	21,088	25	21,088	25	21,088	75	63,264	25	21,088
Toxics Control
Sm Facility Hr.	80	16	1,280	16	1,280	16	1,280	48	3,840	16	1,280
Lg. Facility Hr.	1,920	9	17,280	9	17,280	9	17,280	27	51,840	9	17,280
SUBTOTAL		25	18,560	25	18,560	25	18,560	75	55,680	25	18,560
TOTAL (POTWs)
Sm Facility Hr.		16	7,548	16	7,548	16	7,803	48	22,899	16	7,633
Lg Facility Hr.		9	37,728	9	35,424	9	35,424	27	108,576	9	36,960
TOTAL (All POTWs)a		25	45,276	25	42,972	25	43,227	75	131,475	25	43,825
Determination (States)
Sm Facility Hr.	90	4	360	4	360	5	450	13	1,170	4	390
Lg Facility Hr.	180	4	720	2	360	2	360	8	1,440	3	480
SUBTOTAL		8	1,080	6	720	7	810	21	2,610	7	870
Certification (States)
Sm Facility Hr.	30	4	120	4	120	5	150	13	390	4	130
Lg Facility Hr.	60	4	240	2	120	2	120	8	480	3	160
SUBTOTAL		8	360	6	240	7	270	21	870	7	290
Total (States)b		6	1,440	6	960	6	1,080	6	3,480	6	1,160
GRAND TOTAL(States + POTWs)		31	46,716	31	43,932	31	44,307	31	134,955	31	44,985	,
aThere are 25 POTWs in the 301(h) universe.
bThere are 6 States in the 301(h) universe.

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Sheet 5: TableA5

TABLE A-5. APPLICATION REVISION AND REAPPLICATION ACTIVITIES AND BURDEN HOURS FOR POTWS
	Burden Hours
Activities	Small	Large
Read Instructions	8	16
Plan Activities	8	16
Create Information	80	320
Gather Information	135	320
Complete Information	24	480
TOTAL	255	1,152

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Sheet 6: TableA6

TABLE A-6. ANNUAL POTW RESPONDENTS AND TOTAL ANNUAL BURDEN OF APPLICATION REVISION
	FY 2021		FY 2022		FY 2023		TOTAL		Average Annuala
	S	L	S	L	S	L	S	L
Number of Respondents	1	2	1	1	1	1	3	4	2
Burden (burden from Table A-5 x number of respondents)	255	2,304	255	1,152	255	1,152	765	4,608	1,791
Note: S = small, L = large
aCalculated by dividing the total small and large POTWs for 3 years by 3.

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Sheet 7: TableA7

TABLE A-7. ANNUAL POTW RESPONDENTS AND TOTAL ANNUAL BURDEN OF REAPPLICATION
	FY 2021		FY 2022		FY 2023		TOTAL		Average Annuala
	S	L	S	L	S	L	S	L
Number of Respondents	3	2	3	1	4	1	10	4	5
Burden (burden from Table A-5 x number of respondents)	765	2,304	765	1,152	1,020	1,152	2,550	4,608	2,386
Note: S = small, L = large
aCalculated by dividing the total small plus large POTWs for 3 years by 3.

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Sheet 8: TableA8

TABLE A-8. ANNUAL POTW RESPONDENTS AND TOTAL ANNUAL BURDEN OF MONITORING AND TOXICS CONTROL PROGRAM
														Average Annual Burdena
	Number of Respondents						Average Annual Number of Respondents	Burden Hours/Permittee		Annual Burden
	2021		FY 2022		FY 2023
	S	L	S	L	S	L		S	L	FY 2021	FY 2022	FY 2023	TOTAL
Monitoring Program	16	9	16	9	16	9	25	328	1,760	21,088	21,088	21,088	63,264	21,088
Toxics Control Program	16	9	16	9	16	9	25	80	1,920	18,560	18,560	18,560	55,680	18,560
Note: S = small, L = large
aCalculated by dividing the total annual burden of small plus large POTWs for 3 years by 3.

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Sheet 9: TableA9

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

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Sheet 10: TableA10

TABLE A-10. ANNUAL RESPONDENTS AND TOTAL ANNUAL BURDEN OF STATE DETERMINATIONS
	FY 2017a		FY 2018		FY 2019		Total	Average Annuala
	S	L	S	L	S	L
Number of Respondents	4	4	4	2	5	2	21	7
Burdenb	360	720	360	360	450	360	2,610	870
Note: S = small, L = large
aCalculated by dividing the number of respondents and the total burden for 3 years by 3. There are 6 states in the 301(h) universe.
bCalculated by multiplying burden estimates in Table A-9 by the corresponding number of respondents in each information submission category.

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Sheet 11: TableA11

TABLE A-11. ANNUAL RESPONDENTS AND TOTAL ANNUAL BURDEN OF STATE 401(a)(1) CERTIFICATION
	FY 2017		FY 2018		FY 2019		Total	Average Annuala
	S	L	S	L	S	L
Number of Respondentsb	4	4	4	2	5	2	21	7
Burdenc	120	240	120	120	150	120	870	290
Note: S = small, L = large
aCalculated by dividing total burden hours and number of respondents for the 3 years by 3. There are 6 states in the 301(h) universe.
bNumber derived by assuming 21 permit reapplications and application revisions over 3 years of the ICR; 13 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.
cCalculated by multiplying burden estimates in Table A-9 by number of respondents.

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Sheet 12: TableA12

TABLE A-12. SUMMARY TABLEa
Respondent/Activity	Number of Respondents/Responses	Hours per Responseb	Average Annual Burden
POTWs
Application Revision	2	896	1,791
Reapplication	5	477	2,386
Monitoring Program	25	844	21,088
Toxics Control Program	25	742	2,386
TOTAL: POTWs	25		43,825
STATES
Determinations	7	145	870
Certifications	7	40	290
TOTAL: STATES	6		1,160
TOTAL: POTWs AND STATES	31		44,985
aAverage of 3 years divided by 3.
b Hours per response were calculated by dividing the average annual burden by the number of respondents. Values have been rounded to the nearest hour.

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Sheet 13: TableA13

TABLE A-13. EXPLANATION OF CHANGE IN BURDEN
Activity	Burden from Previous ICR		Difference	Reason for Change
Application Revision	1,791	1,791	0	No changea
Reapplication	2,641	2,386	-255	Fewer respondentsa
				Changes in Program status and information needs;
Monitoring Program	19,208	21,088	1,880	Fewer respondents a Changes in Program status and information needs; Program adjustmentc
Toxics Control Program	15,120	18,560	3,440	Fewer respondentsa Changes in Program status and information needs; Program adjustmentc
State Determination	960	870	-90	Fewer respondentsab
State Certification	320	290	-30	Fewer respondentsab
TOTAL	40,040	44,985	4,945	Fewer respondents/changes in program status and information needsab; program adjustmentc
a301(h) universe has decreased since the previous ICR
bNumber of States in 301(h) universe has remained the same since the previous ICR
c Program adjustment. 2 POTWs were recategorized from small to large to correct a clerical error.Large POTWs have higher burdens.