Submitted to OMB with Second Federal Register Notice-2009 Tables to be revised for 2014 ICR

Activity Average Annual Burden Hours (from Table A-3) Hourly Cost Average Annual Cost

Technical Review of revised application & reapplication 3,660 $72.22 a $264,325 Evaluate revised applications/reapplications for compliance with 301(h) criteria/prepare 301(h) decisions 3,467 $34.54 b $119,750 Evaluate monitoring and toxic control program adequacy 2,660 $34.54 b $91,876 Review State determinations and State certifications and coordinate with State 207 $34.54 b $7,150 TOTAL 9,993 $483,101

NOTE: Numbers may not add due to rounding. a It 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, $65,531 or $75,361/year. Thus, based on 2,080 working hours/year, the average salary of a contractor is $36.11/hour. Assuming 100 percent overhead costs for the private sector, the labor cost for contractors is $72.22. (Hourly rate based on 2009 DC-B salary rate table.)

b It is assumed that the salary level of the typical government employee working on the 301(h) program is a GS-9, Step 10 salary, or $65,531/year. Based on 2,080 working hours/year, the average hourly salary of a Federal employee is $31.40/hour. Assuming 10 percent overhead costs, the labor cost for Federal employees is $34.54/hour. (Hourly rate based on 2009 DC-B salary rate table.) 

### TABLE A-1. AVERAGE ANNUAL COST TO THE FEDERAL GOVERNMENTSubmitted to OMB with Second Federal Register Notice--2009

Activity Average Annual Burden Hours Hourly Cost Average Annual

Cost

Application Revision 2,559 $72.22 a $184,811 Reapplication 3,963 $72.22 a $286,208 Monitoring Program 27,888 $19.29 b $537,960 Toxics Control Program 23,200 $19.29 b $447,528 TOTAL 57,610 $1,456,507 COST TO STATE RESPONDENTS Determination 1,320 26.57 c $35,072 Certification 440 26.57 c $11,691 TOTAL 1,760 $46,763

TOTAL POTW AND STATE RESPONDENTS 59,370 $1,503,270

c It 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 $50,408/year. Based on 2,080 working hours/year, the average hourly salary of a State government employee is $24.15/hour. Assuming 10 percent overhead costs, the labor cost for State government employees is $26.57/hour. (Hourly rate based on 2009 DC-B salary rate table.) 

### TABLE A-2. COST TO POTW AND STATE

a It 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 salarylevel of a contractor working on the 301(h) program is 15 percent higher than that of a GS9, Step 10, $65,531, or $75,361/year. Thus, based on 2,080 working hours/year, the average hourly salary of a contractor is $36.11/hour. Assuming 100 percent overhead costs for the private sector, the labor cost for contractors is $72.22/hour. (Hourly rate based on 2009 DC-B salary rate table.)

b It 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 $36,596. Based on 2,080 working hours/year, the average hourly salary of a local employee is $17.54/hour. Assuming 10 percent overhead costs, the labor cost for local government employees is $19.29/hour. (Hourly rate based on 2009 DC-B salary rate table.) COST TO POTW RESPONDENTSSubmitted to OMB with Second Federal Register Notice--2009



### TABLE A-3. FEDERAL GOVERNMENT BURDEN

Number of Permits to be Processed Annuallya FY 2009 FY 2010 FY 2011

Activity S L S L S L S L S L TOTAL Technical review of revised application and reapplication 360 1650 1 2 1 2 1 2 1,080 9,900 10,980 3,660 Evaluate revised applications and reapplications for compliance with 301(h) criteria 208 1040 5 3 5 2 5 2 3,120 7,280 10,400 3,467 Evaluate monitoring and toxic control program adequacy 60 100 26 11 26 11 26 11 4,680 3,300 7,980 2,660 Review State determinations and State certifications and coordinate with the State 20 20 6 5 6 4 6 4 360 260 620 207 TOTAL 9,240 20,740 29,980 9,993

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. Average Annual Burden b Federal Burden Hours/Activity for 3 Years of ICR Burden Hours/ActivitySubmitted to OMB with Second Federal Register Notice--2009



### TABLE A-4. ANNUAL, TOTAL AND AVERAGE BURDENS FOR EACH OF THE SIX INFORMATION ACTIVITIES
FY 2009 FY 2010 FY 2011 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 2 2,304 2 2,304 6 6,912 2 2,304 SUBTOTAL 3 2,559 3 2,559 3 2,559 9 7,677 3 2,559 Reapplication (POTW) Sm Facility Hr. 255 5 1,275 5 1,275 5 1,275 15 3,825 5 1,275 Lg. Facility Hr. 1,152 3 3,456 2 2,304 2 2,304 7 8,064 2 2,688 SUBTOTAL 8 4,731 7 3,579 7 3,579 22 11,889 7 3,963 Monitoring (POTW) Sm Facility Hr. 328 26 8,528 26 8,528 26 8,528 78 25,584 26 8,528 Lg. Facility Hr. 1,760 11 19,360 11 19,360 11 19,360 33 58,080 11 19,360 SUBTOTAL 37 27,888 37 27,888 37 27,888 111 83,664 37 27,888 Toxics Control Sm Facility Hr. 80 26 2,080 26 2,080 26 2,080 78 6,240 26 2,080 Lg. Facility Hr. 1,920 11 21,120 11 21,120 11 21,120 33 63,360 11 21,120 SUBTOTAL 37 23,200 37 23,200 37 23,200 111 69,600 37 23,200 TOTAL (POTWs) Sm Facility Hr. 26 12,138 26 12,138 26 12,138 78 36,414 26 12,138 Lg Facility Hr. 11 46,240 11 45,088 11 45,088 33 136,416 11 45,472 TOTAL (All POTWs) a 37 58,378 37 57,226 37 57,226 111 172,830 37 57,610 Determination (States) Sm Facility Hr. 90 6 540 6 540 6 540 18 1,620 6 540 Lg Facility Hr. 180 5 900 4 720 4 720 13 2,340 4 780 SUBTOTAL 11 1,440 10 1,260 10 1,260 31 3,960 10 1,320 Certification (States) Sm Facility Hr. 30 6 180 6 180 6 180 18 540 6 180 Lg Facility Hr. 60 5 300 4 240 4 240 13 780 4 260 SUBTOTAL 11 480 10 420 10 420 31 1,320 10 440 Total (States) b 8 1,920 8 1,680 8 1,680 8 5,280 8 1,760 GRAND TOTAL(States + POTWs) 45 60,298 45 58,906 45 58,906 45 178,110 45 59,370

aThere are 37 POTWs in the 301(h) universe.

bThere are 8 States in the 301(h) universe.Submitted to OMB with Second Federal Register Notice-2009

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 Burden Hours 

### TABLE A-5. APPLICATION REVISION

AND REAPPLICATION ACTIVITIES AND BURDEN HOURS FOR POTWSSubmitted to OMB with Second Federal Register Notice-2009

FY 2009 FY 2010 FY 2011 TOTAL Average Annual a S L S L S L S L Number of Respondents 1 2 1 2 1 2 3 6 3 Burden (burden from Table A-5 x number of respondents) 255 2,304 255 2,304 255 2,304 765 6,912 2,559 Note: S = small, L = large

aCalculated by dividing the total small and large POTWs for 3 years by 3. 

### TABLE A-6. ANNUAL POTW RESPONDENTS AND TOTAL ANNUAL BURDEN OF APPLICATION REVISIONSubmitted to OMB with Second Federal Register Notice--2009

FY 2009 FY 2010 FY 2011 TOTAL Average Annual a S L S L S L S L Number of Respondents 5 3 5 2 5 2 15 7 7 Burden (burden from Table A-5 x number of respondents) 1,275 3,456 1,275 2,304 1,275 2,304 3,825 8,064 3,963 Note: S = small, L = large

aCalculated by dividing the total small plus large POTWs for 3 years by 3. 

### TABLE A-7. ANNUAL POTW RESPONDENTS AND TOTAL ANNUAL BURDEN OF REAPPLICATIONSubmitted to OMB with Second Federal Register Notice-2009

Burden Hours/Permittee

S L S L S L S L FY 2009 FY 2010 FY 2011 TOTAL Monitoring Program 26 11 26 11 26 11 37 328 1,760 27,888 27,888 27,888 83,664 27,888 Toxics Control Program 26 11 26 11 26 11 37 80 1,920 23,200 23,200 23,200 69,600 23,200 Note: S = small, L = large

aCalculated by dividing the total annual burden of small plus large POTWs for 3 years by 3. Average Annual Burden a Number of Respondents Annual Burden 

### TABLE A-8. ANNUAL POTW RESPONDENTS AND TOTAL ANNUAL BURDEN OF MONITORING AND TOXICS CONTROL PROGRAM

FY 2009 FY 2010 FY 2011 Average Annual Number of RespondentsSubmitted to OMB with Second Federal Register Notice-2009

State Determination 401 Certification Activity Small a 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. 

### TABLE A-9. BURDEN FOR STATE DETERMINATIONS AND 401(A)(1) CERTIFICATIONS Burden (Hours/Activity)Submitted to OMB with Second Federal Register Notice-2009

FY 2009 a FY 2010 FY 2011 S L S L S L Number of Respondents 6 5 6 4 6 4 31 10 Burden b 540 900 540 720 540 720 3,960 1,320 Note: S = small, L = large 

### TABLE A-10. ANNUAL RESPONDENTS AND TOTAL ANNUAL BURDEN OF STATE DETERMINATIONS

aCalculated by dividing the number of respondents and the total burden for 3 years by 3. There are 8 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. Total Average Annual aSubmitted to OMB with Second Federal Register Notice-2009

FY 2009 FY 2010 FY 2011 S L S L S L Number of Respondents b 6 5 6 4 6 4 31 10 Burden c 180 300 180 240 180 240 1320 440 Note: S = small, L = large

cCalculated by multiplying burden estimates in Table A-9 by number of respondents. 

### TABLE A-11. ANNUAL RESPONDENTS AND TOTAL ANNUAL BURDEN OF STATE 401(a)(1) CERTIFICATION

bNumber derived by assuming 31 permit reapplications and application revisions over 3 years of the ICR; 18 small and 13 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. Total Average Annual a

aCalculated by dividing total burden hours and number of respondents for the 3 years by 3. There are 8 states in the 301(h) universe.Submitted to OMB with Second Federal Register Notice-

-2009

Respondent/Activity Number of Respondents/Responses Hours per Response b Average Annual Burden POTWs Application Revision 3 853 2,559 Reapplication 7 566 3,963 Monitoring Program 37 754 27,888 Toxics Control Program 37 627 23,200 TOTAL: POTWs 37 57,610 STATES Determinations 10 132 1,320 Certifications 10 44 440 TOTAL: STATES 8 1,760 TOTAL: POTWs AND STATES 45 59,370

aAverage of 3 years divided by 3. bHours per response were calculated by dividing the average annual burden by the number of respondents. Values have been rounded to the nearest hour. 

### TABLE A-12. SUMMARY TABLEaSubmitted to OMB with Second First Federal Register Notice--2009

Activity Burden from Previous ICR Difference Reason for Change Application Revision 2,559 2,559 0 Reapplication 4,218 3,963 -255 Fewer respondentsa

Monitoring Program 29,200 27,888 -1,312 Fewer respondentsa Toxics Control Program 23,520 23,200 -320 Fewer respondentsa State Determination 1,410 1,320 -90 Fewer respondentsab

State Certification 470 440 -30 Fewer respondentsab

TOTAL 61,377 59,370 -2,007 Fewer respondentsab

a301(h) universe has decreased since the previous ICR

bNumber of States in 301(h) universe has decreased since the previous ICR 

### TABLE A-13. EXPLANATION OF CHANGE IN BURDEN