## Ap **pendix A**Draft Pretreatment Program Information Collection Request A - 1 

## Ap **pendix A**  **. As**  **sumptions for Dev eloping 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 I CR. This appendix provides a descriptio n of the source of these data elements. In addition, the I CR relied on several assumptions regarding the relative percentages of respondents performing various tasks. The appendix also summarizes these key assumptions. **Table 1 Data and A ssumptions 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. Nu mb er 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 Num ber 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 POTW s as Control Authority 20,630 15. Percentage of SIUs with POTW s 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. Ho urly

Rate for State employees (50% OH) 39.81 21. Hourly Rate for POTW em plo yees (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 POTW s with EPA as Approval Authority 405 25. Percentage of POTW s with EPA as Approval Authority 26.15% 26. Number of POTW s with State as Approval Authority 1,143 27. Percentage of POTW s with State as Approval Authority 73.85% 28. Number of POTW s projected to develop a pretreatment program during t he 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 Sy stem (PCS) and Integrated Compliance Information System (I CI S) 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 deriv ed from Permit Compliance Sy stem (PCS) and Integrated Compliance Information System (I CI S) data, as obtained from an October 2010 query and updated/corrected through January 2011 with input from EPA headquarters and regional staff responsible for overseein g 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 I CR (EPA ICR No. 0002.12) and is explained at the beginning of this section . The percentage i s 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 I CR (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 pretreatm ent program, which was done as part of the Streamlining Rule I CR (EPA ICR No. 0002.12) and is explained at the beginning of this section. on compliance reporting requirements in eight POTW programs. These data show ed that 71% of small CIUs were required t o monitor more than twice per ye ar. It wa s assumed that compliance reporting requirements continue d 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** - Th is 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%) i s 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 a s part of the Streamlining Rule ICR (EPA I CR 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 I CR No. 0002.12) and is exp lained at the beginning of this section. on compliance reporting requirements in eight POTW programs.Draft Pretreatment Program Information Collection Request A - 3

These data show ed that 71% of small CIUs were required to monitor more than twice per ye ar. It wa s assumed that compliance reporting requirements continue d 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 b y dividing the total number of SIUs regulated b y States/EPA (and not b y approved POTW Pretreatment Programs) b y the average number of SIUs per approved pretreatment program. 11. **Total Number of Approved Programs** - This number is derived from Permit Compliance Sy stem (PCS) and Integrated Compliance Information System (I CI S) 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** - 3 6 , per EPA Headquarters. 15. - 16 **Number and Percentage of SIUs with POTWs as C**  **ontrol Authority**

– This number is derived from Permit Compliance Sy stem (PCS) and Integrated Compliance Information Sy stem (I CI S) 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 Sy stem (PCS) and Integrated Compliance Information System (I CI S) 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 regul ated 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 I CR (EPA ICR No. 0002.12) and is explained at the beginning of this section. 20. **Hourly Rate for Federal Employees** - The hourly employ ment cost of federal employees was determined using methodology established in previous I CRs. According to the U.S. Office of Personnel Management, J anuary 20 10 General Schedule (2007 - GS), the average annual salary of a government emplo ye e at the GS - 9, Step 10 level is $54,028. At 2,080 hours per ye ar, the hourly wage would be $25.98. Assuming overhead costs of 50 percent, or $12.99 per hour, the fully loaded cost of employ ment for a federal employee would be $38.97 . 21. **Hourly Rate for State Employees** - The average hourly rate for municipal employees as determined b y 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 ( JuneDraft Pretreatment Program Information Collection Request A - 4

20 10 ) , adjusted to a March 20 10 dollars using the Employ ment Cost Index (ECI). A 50 pe rcent 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 b y the U.S. Department of Labor, Burea u 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 W age 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. **Nu mber 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 I CR 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 number s are derived from Permit Compliance Sy stem (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 non approved states. 27 - 28 . **Number and Percentage of POTWs wi th State as Approval Authority**  - These number s are derived from Permit Compliance Sy stem (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 Requ ests** 

– EPA estimates four respondents per year. Based on projections from EPA regional offices.