Table A1. Respondents Activities table (permittees)

Activity Description Respondent Type

Total

Hours per

response

capital /

startup

cost O&M Cost

Total

Annualized

Captial and

O&M Cost

Total Number

of

Respondents Year 1 Year 2 Year 3

Annual

Average

Number of

Respondents Frequency of Reporting

Number of

Responses

/

respondent

/ yr

Number of

Responses Year

Total Hours

/ Year Total Labor Cost

Type of

Activitity OMB

(Reporting /

Recordkeeping

/ 3rd party

disclosure)

NOI preparation & submittal operators - PGP Table 1-1 2 $0 $0 $0 9,125 1,825 1,825 1,825 1,825 once every 5 yrs 1 1,825 3,650 $272,235 Reporting

NOI preparation & submittal operators under PGP - informal ESA 6 $0 $0 $0 37 7 7 7 7 once every 5 yrs 1 7 44 $3,312 Reporting

NOI preparation & submittal operators under PGP - formal ESA 20 $0 $0 $0 18 4 4 4 4 once every 5 yrs 1 4 73 $5,445 Reporting

NOT Preparation & submittal operators - PGP Table 1-1 (all) 0.5 $0 $0 $0 456 91 91 91 91 once 1 91 46 $4,907 Reporting

Develop PDMP operators - NOI filers (large) 40 $0 $0 $0 4,836 967 967 0 645 once 1 645 25,793 $1,157,527 Reporting

Update PDMP operators - NOI filers (large) 2 $0 $0 $0 4,836 1,209 1,209 1,209 1,209 ongoing 1 1,209 2,418 $100,618 Reporting

Monitoring (large site) operators - NOI filers (large) 0.25 $0 $0 $0 4,836 4,836 4,836 4,836 4,836 ongoing 16 77,380 19,345 $804,945 Reporting

Monitoring (small site) operators - NOI filers (small) 0.25 $0 $0 $0 4,289 4,289 4,289 4,289 4,289 ongoing 4 17,155 4,289 $178,455 Reporting

Monitoring other operators 0.25 $0 $0 $0 355,875 355,875 355,875 355,875 355,875 ongoing 1 355,875 88,969 $3,701,990 Reporting

Annual Report preparation & submittal operators - NOI filers (large & ESA) 8 $0 $0 $0 4,892 4,892 4,892 4,892 4,892 yearly 1 4,892 39,132 $1,628,283 Reporting

Adverse Incident Documentation all operators 2 $0 $0 $0 365,000 37 37 37 37 occasionally/As Needed 1 37 73 $3,038 Reporting

Adverse Incident verbal notification all operators 2 $0 $0 $0 365,000 37 37 37 37 occasionally/As Needed 1 37 73 $3,038 Reporting

Adverse Incident to Threatened or Endangered Species all operators 2 $0 $0 $0 365,000 4 4 4 4 occasionally/As Needed 1 4 7 $304 Reporting

Spill, Leaks Documentation all operators 1 $0 $0 $0 365,000 365 365 365 365 occasionally/As Needed 1 365 365 $15,188 Reporting

Corrective Action Documentation all operators 5 $0 $0 $0 365,000 365 365 365 365 occasionally/As Needed 1 365 1,825 $75,938 Reporting

Permittee Report of Planned Facility Changes all operators 4 $0 $0 $0 365,000 365 365 365 365 occasionally/As Needed 1 365 1,460 $60,751 Reporting

Permittee Report of Anticipated Noncompliance all operators 5 $0 $0 $0 365,000 365 365 365 365 occasionally/As Needed 1 365 1,825 $75,938 Reporting

Permittee Report of Inaccurate Previous Information all operators 2 $0 $0 $0 365,000 183 183 183 183 occasionally/As Needed 1 183 366 $15,229 Reporting

Noncompliance Reports all operators 5 $0 $0 $0 365,000 183 183 183 183 occasionally/As Needed 1 183 915 $38,073 Reporting

Recordkeeping (basic) all operators 1 $0 $0 $0 365,000 365,000 365,000 365,000 365,000 ongoing 1 365,000 365,000 $12,063,250 recordkeeping

Recordkeeping operators - non-NOI filers 0.5 $0 $0 $0 355,875 355,875 355,875 355,875 355,875 ongoing 1 355,875 177,938 $7,403,979 recordkeeping

Full Recordkeeping operators - NOI filers (large) 1 $0 $0 $0 4,836 4,836 4,836 4,836 4,836 ongoing 16 77,380 77,380 $3,219,782 recordkeeping

Recordkeeping (PDEW) operators - NOI filers (small) 1 $0 $0 $0 4,289 4,289 4,289 4,289 4,289 ongoing 4 17,155 17,155 $7,630,458 recordkeeping

TOTAL 1,276,395 828,141 $38,462,682

1. Total hours per response are from the EA or ICR for NPDES Program except for the Update PDMP.

5. This ICR marks a shift from the approval period (years 4 and 5 of the PGP) to the permit implementation and renewal period (year 6 of the PGP) when permittees renewing their coverage in year 3 of this ICR (year 6 of the PGP) would not need to develop a new PDMP. This is the reason why there are no respondents assumed to develop

a PDMP in year 3.

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 updated to 2013 dollars - average managersial rate $107.56, technical rate $41.61, clerical rate $33.05. 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)

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.
Table A2. Respondents Activities table (States)

Activity Description Respondent Type

Total

Hours per

response

capital /

startup

cost O&M Cost

Total

Annualized

Capital and

O&M Cost

Total Number

of

Respondents

Annual

Number of

Respondents

Frequency of

Reporting

Number of

Responses /

respondent /yr

Number of

Responses

Year Total Hours / Year

Total Labor

Cost

Type of Activity

OMB (Reporting

/ Recordkeeping

/ 3rd party

disclosure)

Type of

Activity

(EPA

classificatio

n)

Obligation of

Response OMB

(mandatory,

voluntary)

Affected Public

(OMB)

NOI processing & review States 0.5 $0 $0 $0 47 47 every 5 yrs 34.94680851 1,643 821 $24,802 Reporting 1. Application/NOI mandatory States

NOT processing & review States 0.25 $0 $0 $0 47 47 ongoing 1.747340426 82 21 $620 Reporting 1. Application/NOI mandatory States

Annual Report processing & review States 1 $0 $0 $0 47 47 yearly 93.45542553 4,392 4,392 $132,651 Reporting 4. Reporting mandatory States

Adverse Incident report review States 2 $0 $0 $0 47 47 occasionally/As Needed0.69893617 33 66 $1,984 Reporting 4. Reporting mandatory States

Permittee Report of Planned Facility Changes States 0.5 $0 $0 $0 47 47 occasionally/As Needed 6.989361702 329 164 $4,960 Reporting 4. Reporting mandatory States

Permittee Report of anticipated noncompliance States 2 $0 $0 $0 47 47 occasionally/As Needed 6.989361702 329 657 $19,841 Reporting 4. Reporting mandatory States

Permittee Report of Inaccurate Previous Information States 1 $0 $0 $0 47 47 occasionally/As Needed 3.504255319 165 165 $4,974 Reporting 4. Reporting mandatory States

Noncompliance Reports States 2 $0 $0 $0 47 47 occasionally/As Needed 3.504255319 165 329 $9,948 Reporting 4. Reporting mandatory States

TOTAL 7,136 6,615 $199,780

Table A3. Agency Activities Table

Activity Description Respondent Type

Total

Hours per

response

capital /

startup

cost O&M Cost

Total

Annualized

Capital and

O&M Cost

Total Number

of

Respondents

Annual

Number of

Respondents

Frequency of

Reporting

Number of

Responses /

respondent /yr

Number of

Responses

Year Total Hours / Year

Total Labor

Cost

Type of Activity

OMB (Reporting

/ Recordkeeping

/ 3rd party

disclosure)

Type of

Activity

(EPA

classificatio

n)

Obligation of

Response OMB

(mandatory,

voluntary)

Affected Public

(OMB)

NOI processing & review EPA 0.5 once every 5 yrs 183 91 $3,792 Reporting 1. Application/NOI mandatory EPA

NOI processing & review (informal) Services 0.5 occasionally/As Needed 7 4 $154 Reporting 1. Application/NOI mandatory Services

NOI processing & review (formal) Services 5 occasionally/As Needed 4 18 $758 Reporting 1. Application/NOI mandatory Services

NOT processing & review EPA 0.25 ongoing 9 2 $95 Reporting 1. Application/NOI mandatory EPA

Annual Report processing & review EPA 1 yearly 500 500 $20,788 Reporting 4. Reporting mandatory EPA

Adverse Incident report review EPA 2 occasionally/As Needed 4 7 $303 Reporting 4. Reporting mandatory EPA

Adverse Incident to Threatened or Endangered Species Services 2 occasionally/As Needed 4 7 $303 Reporting 4. Reporting mandatory Services

Permittee Report of Planned Facility Changes EPA 0.5 occasionally/As Needed 37 18 $758 Reporting 4. Reporting mandatory EPA

Permittee Report of anticipated noncompliance EPA 2 occasionally/As Needed 37 73 $3,034 Reporting 4. Reporting mandatory EPA

Permittee Report of Inaccurate Previous Information EPA 1 occasionally/As Needed 18 18 $761 Reporting 4. Reporting mandatory EPA

Noncompliance Reports EPA 2 occasionally/As Needed 18 37 $1,521 Reporting 4. Reporting mandatory EPA

1. Total hours per response are from the ICR for NPDES Program. TOTAL 820 776 $32,268

2. Number of responses/yr - EPA is 10% of permittee's total number of responses/yr

3. Labor Rate for Federal is $41.56 and for State is $30.20