| 2022 CGP ICR - Agency Labor Burden |
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Federal: |
Labor rate (2024) |
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$51.15 |
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Hours Per Response |
Number of Annual Reponses |
Annual Hours Burden |
Annual Cost Burden 2 |
| Activity |
2017 NPDES Program ICR 1 |
2022 CGP Incremental Change |
2022 CGP Total Hours per Response |
2022 CGP No. Annual Responses |
2022 CGP Incremental Change in Annual Burden (hrs) |
2022 CGP Annual Burden (hrs) |
2022 CGP Incremental Change in Annual Cost |
2022 CGP Annual Cost |
| NOI review |
1 |
0 |
1 |
3,630 |
0 |
3,630 |
$0 |
$185,675 |
| NOT review |
0.25 |
0 |
0.25 |
3,631 |
0 |
908 |
$0 |
$46,431 |
| Waiver Certification Review |
1 |
0 |
1 |
182 |
0 |
182 |
$0 |
$9,309 |
| SWPPP review |
1 |
0 |
1 |
3,631 |
0 |
3,631 |
$0 |
$185,726 |
| Standard/Other Reports |
12 |
0 |
12 |
176 |
0 |
2,112 |
$0 |
$108,029 |
| Turbidity Monitoring Report Review |
NA |
0.16 |
0.16 |
835 |
134 |
134 |
$6,834 |
$6,834 |
| Turbidity Report Follow-up |
NA |
0.5 |
0.5 |
167 |
84 |
84 |
$4,271 |
$4,271 |
| Total Agency Activities |
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12,252 |
217 |
10,680 |
$11,105 |
$546,275 |
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| Table Endnotes |
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| 1 NA indicates that the 2017 NPDES Programmatic ICR did not account for this new burden item. |
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| 2 In the 2022 CGP ICR, EPA assumed that the fully loaded cost of employment for a federal employee is $46.02. |
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| 2022 CGP ICR - Respondent Burden and Cost Table |
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Labor rate (2024) |
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$73.47 |
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Hours Per Response |
Number of Annual Reponses |
Annual Hours Burden |
Annual Cost Burden |
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| Activity |
2017 NPDES Program ICR 1 |
2022 CGP Incremental Change |
2022 CGP Total |
2022 CGP Number of Respondents |
Number of Occurrences Per Year |
2022 CGP Incremental Change in Annual Responses |
2022 CGP Number of Annual Responses |
2022 CGP Incremental Change in Annual Burden (hrs) |
2022 CGP Total Annual Burden (hrs) |
2022 CGP Incremental Change in Annual Cost 2 |
2022 CGP Total Annual Cost 2 |
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| Reporting Requirements |
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| NOI - Large Sites |
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| With ESA Evaluation and No Consultation |
1.5 |
-0.4 |
1.1 |
980 |
1 |
0 |
980 |
-392 |
1078 |
-$28,800 |
$79,201 |
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| With ESA Evaluation and Informal Consultation |
6 |
-0.4 |
5.6 |
609 |
1 |
0 |
609 |
-244 |
3,410 |
-$17,927 |
$250,533 |
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| With ESA Evaluation and Formal Consultation |
20 |
-0.4 |
19.6 |
44 |
1 |
0 |
44 |
-18 |
862 |
-$1,322 |
$63,331 |
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| NOI - Small Sites with ESA Evaluation and Consultation |
3.7 |
-0.4 |
3.3 |
1997 |
1 |
0 |
1997 |
-799 |
6,590 |
-$58,703 |
$484,167 |
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| Appendix D - Eligibility Procedures Relating to Threatened and Endangered Species Protection |
Included in NOI burden |
- |
- |
- |
- |
- |
- |
- |
- |
- |
- |
|
| Appendix E - Historic Property Screening Step 5 (Contact SHPO/THPO) |
Included in NOI burden |
- |
- |
- |
- |
- |
- |
- |
- |
- |
- |
|
| Appendix L - Request for Chemical Treatment |
Included in NOI burden |
- |
- |
- |
- |
- |
- |
- |
- |
- |
- |
|
| Appendix C - Small Construction Waiver |
1 |
0 |
1 |
182 |
1 |
0 |
182 |
0 |
182 |
$0 |
$13,372 |
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| NOT |
0.5 |
0.7 |
1.2 |
3631 |
1 |
0 |
3631 |
2,542 |
4,357 |
$186,761 |
$320,109 |
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| Turbidity Benchmark Monitoring - Sampling |
NA |
0.5 |
0.5 |
835 |
29 |
24215 |
24215 |
12,108 |
12,108 |
$889,575 |
$889,575 |
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| Turbidity Benchmark Monitoring - Reporting |
NA |
0.75 |
0.75 |
835 |
4 |
3340 |
3340 |
2,505 |
2,505 |
$184,042 |
$184,042 |
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| Standard/Other Reporting |
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| Planned Facility Changes |
4 |
0 |
4 |
18 |
1 |
0 |
18 |
0 |
72 |
$0 |
$5,290 |
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| Anticipated Noncompliance |
5 |
0 |
5 |
4 |
1 |
0 |
4 |
0 |
20 |
$0 |
$1,469 |
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| 24hr reporting - Unanticipated Bypass or Upset (Verbal) |
5 |
0 |
5 |
4 |
1 |
0 |
4 |
0 |
20 |
$0 |
$1,469 |
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| 24hr reporting - Unanticipated Bypass or Upset (Written) |
2 |
0 |
2 |
3 |
1 |
0 |
3 |
0 |
6 |
$0 |
$441 |
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| 24hr reporting - Violation of Maximum Daily Discharge (Verbal) |
3 |
0 |
3 |
73 |
1 |
0 |
73 |
0 |
219 |
$0 |
$16,090 |
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| 24hr reporting - Violation of Maximum Daily Discharge (Written) |
2 |
0 |
2 |
36 |
1 |
0 |
36 |
0 |
72 |
$0 |
$5,290 |
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| Other Noncompliance reporting |
5 |
0 |
5 |
36 |
1 |
0 |
36 |
0 |
180 |
$0 |
$13,225 |
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| Other Info - Permittee Report of Inaccurate Previous Information |
2 |
0 |
2 |
2 |
1 |
0 |
2 |
0 |
4 |
$0 |
$294 |
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| Reporting Subtotal |
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27,555 |
35,174 |
15,702 |
31,685 |
$1,153,626 |
$2,327,898 |
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| Recordkeeping Requirements |
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| Develop New SWPPP - Large Sites |
36.4 |
0 |
36.4 |
1634 |
1 |
0 |
1634 |
0 |
59,478 |
$0 |
$4,369,849 |
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| Develop New SWPPP - Small Sites |
22.7 |
0 |
22.7 |
1997 |
1 |
0 |
1997 |
0 |
45,332 |
$0 |
$3,330,542 |
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| SWPPP Benchmark Monitoring Procedure 3 |
NA |
4 |
4 |
835 |
Part of developing a SWPPP |
3,340 |
3,340 |
$245,390 |
$245,390 |
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| Update SWPPP |
Included in SWPPP development burden |
- |
- |
- |
- |
- |
- |
- |
- |
- |
- |
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| Site Inspections - Large Sites |
0.5 |
0 |
0.5 |
1634 |
26 |
0 |
42,484 |
0 |
21,242 |
$0 |
$1,560,650 |
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| Site Inspections - Small Sites |
0.25 |
0 |
0.25 |
1997 |
26 |
0 |
51,922 |
0 |
12,981 |
$0 |
$953,714 |
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| Dewatering Inspections |
NA |
0.25 |
0.25 |
3631 |
29 |
105299 |
105,299 |
26,325 |
26,325 |
$1,934,098 |
$1,934,098 |
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| Corrective Action Records |
Included in burden estimate for site inspections, dewatering inspections, and turbidity monitoring |
- |
- |
- |
- |
- |
- |
- |
- |
- |
- |
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| Recordkeeping Subtotal |
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105,299 |
203,336 |
29,665 |
168,698 |
$2,179,488 |
$12,394,243 |
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| Total Labor Burden and Cost |
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132,854 |
238,510 |
45,367 |
200,383 |
$3,333,114 |
$14,722,141 |
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| Total Capital and O&M |
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$888,440 |
$888,440 |
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| Grand Total |
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$4,221,554 |
$15,610,581 |
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Hours (respondent + agency) |
211,063 |
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Responses (respondent + agency) |
250,762 |
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| Table Endnotes |
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hours per response |
0.841685941251067 |
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$296,146.67 |
| 1 NA indicates that the 2017 NPDES Programmatic ICR did not account for this new burden item. |
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| 2 In the 2022 CGP ICR, EPA assumed that the fully loaded cost of employment for a private sector employee is $73.47. |
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| 3 A subpopulation of respondents need to document their benchmark monitoring procedures in their SWPPP. This is not considered a new response, as it is included in the overall SWPPP response. The burden is calculated in a separate line because the burden applies to a subset of the respondent population |
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| Calculations for Turbidity Monitoring Requirements |
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| Dewatering Turbidity Monitoring Reports |
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| Activity |
Estimate |
Notes |
| Average data entry time per element 1 (hours) |
0.06 |
This average is based on burden reported in the Economic Analysis of the National Pollutant Discharge Elimination System Electronic Reporting Final Rule (9/2015, Table 4-9 Page 4-14). It is an average of the Hybrid and Batch methods. https://www.epa.gov/sites/production/files/2015-09/documents/npdesea.pdf |
| No. of elements to report per DMR |
13 |
Respondents need to fill in either "no dewatering discharge" or the weekly sampling average for every week in the quarter, which is 13 weeks. |
| Hours per Response |
0.75 |
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| Turbidity Meter Capital and Operation & Maintenance Costs |
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| Monitoring Device |
Capital/ Startup Cost for One Respondent 1 |
Number of Respondents |
Total Capital/ Startup Cost |
Annual O&M Costs for One Respondentb |
Number of Respondents with O&M |
Total O&M |
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| Turbidity Meter |
$1,064 |
835 |
$888,440 |
$0 |
835 |
$0 |
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| a EPA surveyed publicly available price information from a variety of analytical instrument retailers for prices and instrument information. Of the instruments with publicly available prices that were advertised as able to comply with EPA analytical method standards for turbidity, prices ranged from $970 - $1,870 with a median price of $1,043. Further information on this survey can be found in the Incremental Cost Impact Analysis for the 2022 CGP. |
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| b EPA assumes that calibration standards are included with the purchase of a turbidity meter, and thus the O&M cost of purchasing calibration standards is included in the capital cost estimate. |
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$296,146.67 |
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Respondent Percentage |
Proposed 2022 CGP ICR |
Notes |
| # of NOIs (including Idaho) |
- |
NA |
https://permitsearch.epa.gov/epermit-search/ui/search |
| # of NOIs (excluding Idaho) |
- |
3631 |
2022 CGP NOI Data (Years 1 and 2 of 2022 CGP NOI Data) |
| Operators with Large Sites |
45% |
1634 |
37% used in 2017 NPDES Program ICR, updated to 41% using 2017 CGP NOI Data (2017-2020), and updated to 45% using the first two years of the 2022 CGP NOI data for 2022 CGP ICR (sites greater than 5 acres) |
| NOI - Large Sites (ESA Criterion A, B) |
60% |
980 |
Same assumption made in 2017 NPDES Program ICR: 60% of large sites |
| NOI - Large Sites (ESA Criterion C, D, E - Informal Eval) |
37.3% |
609 |
Same assumption made in 2017 NPDES Program ICR: 37.3% of large sites |
| NOI - Large Sites (ESA Criterion F - Formal Eval) |
2.7% |
44 |
Same assumption made in 2017 NPDES Program ICR: 2.7% of large sites |
| Operators with Small Sites |
55% |
1997 |
63% used in 2017 NPDES Program ICR, updated to 59% using 2017 CGP NOI Data (2017-2020). Updated to 55% in 2024 using the first two years of 2022 CGP NOI Data for the 2022 CGP ICR (sites less than 5 acres) |
| Operators that discharge into Sensitive Water |
23% |
835 |
Based on analysis of the first two years of 2022 CGP NOI data , where impairment or TMDL was listed in NOI form based on the following search terms: sediment, turbidity, TSS, solids, or transparency or the water was Tier 2, 2.5, or 3. |
| Waivers (5%) |
5% |
182 |
Same assumption made in 2017 NPDES Program ICR: 5% on top of the total number of NOIs submitted each year |
| # NOTs |
100% |
3631 |
Same number as number of NOIs |
| Planned Facility Changes |
0.50% |
18 |
Same assumption made in 2017 NPDES Program ICR |
| Anticipated Noncompliance |
0.10% |
4 |
Same assumption made in 2017 NPDES Program ICR |
| 24hr reporting - Unanticipated Bypass or Upset (Verbal) |
0.10% |
4 |
Same assumption made in 2017 NPDES Program ICR |
| 24hr reporting - Unanticipated Bypass or Upset (Written) |
0.08% |
3 |
Same assumption made in 2017 NPDES Program ICR |
| 24hr reporting - Violation of Maximum Daily Discharge (Verbal) |
2% |
73 |
Same assumption made in 2017 NPDES Program ICR |
| 24hr reporting - Violation of Maximum Daily Discharge (Written) |
1% |
36 |
Same assumption made in 2017 NPDES Program ICR |
| Other Noncompliance reporting |
1% |
36 |
Same assumption made in 2017 NPDES Program ICR |
| Other Info - Permittee Report of Inaccurate Previous Information |
0.05% |
2 |
Same assumption made in 2017 NPDES Program ICR |