Appendix A
Draft Pretreatment Program Information Collection Request A-1

Appendix A. Assumptions for Developing Burden and Cost 

Estimates

Table 1 provides a list of the key data inputs used to determine burden hours and costs for the National 

Pretreatment Program ICR. This appendix provides a description of the source of these data elements. 

In addition, the ICR relied on several assumptions regarding the relative percentages of respondents 

performing various tasks. The appendix also summarizes these key assumptions.

Table 1 Data and Assumptions Used in Pretreatment ICR

Pretreatment Program Data Numbers

1. Total Number of SIUs 22,827

2. Number of CIUs 9,844

3. Number of noncategorical-SIUs 12,983

4. Number of Zero-Discharge NSCIUs 566

5. Number of CIUs that Discharge > 0 and < 100 gpd 911

6. Number of Non-Zero-Discharge NSCIUs 264

7. Number of NSCIUs 830

8. Number of Middle Tier CIUs 2,953

9. Number of Middle Tier CIUs that reduce monitoring 856

10. Number of State Run POTW Pretreatment Programs in 40 CFR §403.10(e) States 55

11. Total Number of Approved Programs 1,548

12. Number of 40 CFR §403.10(e) States 5

13. Number of States with approved Pretreatment Programs 36

14. Number of SIUs with POTWs as Control Authority 20,630

15. Percentage of SIUs with POTWs as Control Authority 90.38%

16. Number of SIUs with State/EPA as Control Authority 2,197

17. Percentage of SIUs with State/EPA as Control Authority 9.62%

18. Percentage of SIUs Resampling (for violations) 10%

19. Hourly Rate for Federal employees (50% Overhead (OH)) 38.97

20. Hourly Rate for State employees (50% OH) 39.81

21. Hourly Rate for POTW employees (50% OH) 29.44

22. Hourly Rate for Private Industry employees (100% OH) 55.22

23. Number of New Source CIUs 201

24. Number of POTWs with EPA as Approval Authority 405

25. Percentage of POTWs with EPA as Approval Authority 26.15%

26. Number of POTWs with State as Approval Authority 1,143

27. Percentage of POTWs with State as Approval Authority 73.85%

28.

Number of POTWs projected to develop a pretreatment program during the three-year 

ICR period 64

29. Removal Credit Approval Requests 3

ICR Input Data

1. Total Number of Significant Industrial Users (SIUs) - This number is derived from Permit 

Compliance System (PCS) and Integrated Compliance Information System (ICIS) data, as 

obtained from an October 2010 query and updated/corrected through January 2011 with input 

from EPA headquarters and regional staff responsible for overseeing the pretreatment program.
Draft Pretreatment Program Information Collection Request A-2

2. Number of Categorical Industrial Users (CIU) - This number is derived from Permit 

Compliance System (PCS) and Integrated Compliance Information System (ICIS) data, as 

obtained from an October 2010 query and updated/corrected through January 2011 with input 

from EPA headquarters and regional staff responsible for overseeing the pretreatment program.

3. Number of Non-Categorical SIUs - The mathematical difference between 1 and 2 above.

4. Number of Zero-Discharge NSCIUs - The percentage of zero-discharge NSCIUs (5.75% is 

derived from data from annual Pretreatment Program Reports, Pretreatment Excellence Awards 

applications, and public comments on the proposed Streamlining Rule. This estimate is carried 

forward from the assumptions in the recalculation of the entire pretreatment program, which was 

done as part of the Streamlining Rule ICR (EPA ICR No. 0002.12) and is explained at the 

beginning of this section. The percentage is applied to the number of CIUs. All zero-discharge 

CIUs are assumed to be NSCIUs.

5. Number of CIUs that Discharge > 0 and < 100 gpd - The percentage of CIUs with flows of 

less than 100 gpd but greater than zero (9.26%) is derived from data from annual Pretreatment 

Program Reports, Pretreatment Excellence Awards applications, and public comments on the 

proposed Streamlining Rule. This estimate is carried forward from the assumptions in the 

recalculation of the entire pretreatment program, which was done as part of the Streamlining 

Rule ICR (EPA ICR No. 0002.12) and is explained at the beginning of this section. The 

percentage is applied to the number of CIUs.

6. Number of Non-Zero Discharge NSCIUs - The percentage of dischargers with flows of less 

than 100 gpd but greater than zero that will be deemed non-significant is based on data carried 

forward from the assumptions in the recalculation of the entire pretreatment program, which was 

done as part of the Streamlining Rule ICR (EPA ICR No. 0002.12) and is explained at the 

beginning of this section. on compliance reporting requirements in eight POTW programs. 

These data showed that 71% of small CIUs were required to monitor more than twice per year. 

It was assumed that compliance reporting requirements continued for these 71%. Twenty-nine 

percent (1 – 71%) were assumed to be NSCIUs. The percentage is applied to the number derived 

in Item 5.

7. Number of NSCIUs - This number was calculated by adding the number of zero discharging 

CIUs to the number of CIUs that discharge between 0 and 100 gallons per day that will be 

deemed NSCIUs.

8. Number of Middle-Tier CIUs - The percentage of Middle-Tier CIUs (approximately 30%) is 

derived from data from annual Pretreatment Program Reports combined with data from the 

Metal Products and Machinery Database. This estimate is carried forward from the assumptions 

in the recalculation of the entire pretreatment program, which was done as part of the 

Streamlining Rule ICR (EPA ICR No. 0002.12) and is explained at the beginning of this section.

The percentage is applied to the number of CIUs.

9. Number of Middle-Tier CIUs With Reduced Monitoring - The percentage of Middle-Tier 

CIUs that will become subject to reduced compliance reporting requirements is based on data 

carried forward from the assumptions in the recalculation of the entire pretreatment program, 

which was done as part of the Streamlining Rule ICR (EPA ICR No. 0002.12) and is explained 

at the beginning of this section. on compliance reporting requirements in eight POTW programs. 
Draft Pretreatment Program Information Collection Request A-3

These data showed that 71% of small CIUs were required to monitor more than twice per year. 

It was assumed that compliance reporting requirements continued for these 71%. Twenty-nine 

percent (1 – 71%) were assumed reduce monitoring frequency to once per year. The percentage 

is applied to the number derived in Item 8.

10. Number of State-Run POTW Pretreatment Programs in 40 CFR 403.10(e) States - This 

number was estimated by dividing the total number of SIUs regulated by States/EPA (and not by 

approved POTW Pretreatment Programs) by the average number of SIUs per approved 

pretreatment program.

11. Total Number of Approved Programs - This number is derived from Permit Compliance 

System (PCS) and Integrated Compliance Information System (ICIS) data, as obtained from an 

October 2010 query and updated/corrected through January 011 with input from EPA 

headquarters and regional staff responsible for overseeing the pretreatment program.

12. Number of 40 CFR 403.10(e) States - Five: Alabama, Connecticut, Mississippi, Nebraska, and 

Vermont.

13. Number of States with Approved Pretreatment Programs - 36, per EPA Headquarters.

15.-16 Number and Percentage of SIUs with POTWs as Control Authority – This number is 

derived from Permit Compliance System (PCS) and Integrated Compliance Information System 

(ICIS) data, as obtained from an October 2010 query and updated/corrected through January

2011 with input from EPA headquarters and regional staff responsible for overseeing the 

pretreatment program.

17.-18 Number and Percent of SIUs with State/EPA as Control Authority - This number is derived 

from Permit Compliance System (PCS) and Integrated Compliance Information System (ICIS) 

data, as obtained from an October 2010 query and updated/corrected through January 2011 with 

input from EPA headquarters and regional staff responsible for overseeing the pretreatment 

program. It includes SIUs in 40 CFR 403.10(e) States, as well as SIUs regulated by States/EPA 

in non-pretreatment cities.

19. Percentage of SIUs Resampling - This assumption is carried forward from the recalculation of 

the entire pretreatment program, which was done as part of the Streamlining Rule ICR (EPA ICR 

No. 0002.12) and is explained at the beginning of this section.

20. Hourly Rate for Federal Employees - The hourly employment cost of federal employees was 

determined using methodology established in previous ICRs. According to the U.S. Office of 

Personnel Management, January 2010 General Schedule (2007-GS), the average annual salary of 

a government employee at the GS-9, Step 10 level is $54,028. At 2,080 hours per year, the 

hourly wage would be $25.98. Assuming overhead costs of 50 percent, or $12.99 per hour, the 

fully loaded cost of employment for a federal employee would be $38.97.

21. Hourly Rate for State Employees - The average hourly rate for municipal employees as 

determined by the Bureau of Labor Statistics in the Employer Costs for Employee 

Compensation, Table 3- Employer costs per hour worked for employee compensation and costs 

as a percent of total compensation: state and local government, by selected characteristics (June
Draft Pretreatment Program Information Collection Request A-4

2010), adjusted to a March 2010 dollars using the Employment Cost Index (ECI). A 50 percent 

overhead rate was added to this rate to arrive at an hourly rate of $39.81.

22. Hourly Rate for POTW Employees - The average hourly rate for municipal employees, which 

account for all POTW costs, as determined by the U.S. Department of Labor, Bureau of Labor 

Statistics, is $29.44 (including overhead). Updated rates are derived from the U.S. Department of 

Labor, Bureau of Labor Statistics, in a table entitled May 2009 National Industry-Specific 

Occupational Employment and Wage Estimates and adjusted to March 2010 dollars using the 

ECI.

23. Hourly Rate for Private Sector Employees - EPA used the median industrial engineer wage of 

$36.11 per hour. After adjusting this rate for inflation, compensation, and overhead the rate is 

$55.22 per hour.

24. Number of New Source CIUs - Assumed a 2 percent annual increase in the number of 

operational CIUs. This assumption is based on US Census Bureau data and is carried forward 

from the recalculation of the entire pretreatment program, which was done as part of the 

Streamlining Rule ICR (EPA ICR No. 0002.12) and is explained at the beginning of this section.

25-26. Number and Percentage of POTWs with EPA as Approval Authority - These numbers are

derived from Permit Compliance System (PCS) data, as obtained from a October 2010 query, 

GPRA data from October 2010, and input from EPA headquarters and regional staff responsible 

for overseeing the pretreatment program. This is based on the number of POTWs in nonapproved states.

27-28. Number and Percentage of POTWs with State as Approval Authority - These numbers are 

derived from Permit Compliance System (PCS) data, as obtained from a October 2010 query, 

GPRA data from October 2010, and input from EPA headquarters and regional staff responsible 

for overseeing the pretreatment program. This is the based on the number of POTWs in approved 

states.

29. Number of POTWs projected to develop a Pretreatment Program during the life of this 

ICR – Based on projections from EPA regional offices.

30. Removal Credit Approval Requests – EPA estimates four respondents per year. Based on 

projections from EPA regional offices.