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 

GOVERNMENT
Submitted 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 salary 

level 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 RESPONDENTS
Submitted 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

a

Incorporates 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.

b

Calculated by dividing total by 3.

Average 

Annual 

Burdenb

Federal Burden Hours/Activity for 3 

Burden Hours/Activity Years of ICR
Submitted 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 a

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

b

There 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 POTWS
Submitted to OMB with Second Federal Register Notice-2009

FY 2009 FY 2010 FY 2011 TOTAL Average 

Annuala

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

a

Calculated 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 REVISION
Submitted to OMB with Second Federal Register Notice--2009

FY 2009 FY 2010 FY 2011 TOTAL Average 

Annuala

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

a

Calculated by dividing the 

total small plus large 

POTWs for 3 years by 3.

TABLE A-7. ANNUAL POTW RESPONDENTS AND TOTAL ANNUAL BURDEN OF 

REAPPLICATION
Submitted 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

a

Calculated by dividing the total annual burden of small plus large POTWs for 3 years by 3.

Average 

Annual 

Burden Number of Respondents Annual Burden a

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 

Respondents
Submitted to OMB with Second Federal Register Notice-2009

State Determination 401 Certification

Activity Smalla 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 a

Burden 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 2009a FY 2010 FY 2011

S L S L S L

Number of Respondents 6 5 6 4 6 4 31 10

Burdenb 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

a

Calculated by dividing the number of respondents and the total burden for 3 years by 3. There are 8 states in the 

301(h) universe.

b

Calculated by multiplying burden estimates in Table A-9 by the corresponding number of respondents in each 

information submission category.

Total Average 

Annuala
Submitted to OMB with Second Federal Register Notice-2009

FY 2009 FY 2010 FY 2011

S L S L S L

Number of Respondentsb 6 5 6 4 6 4 31 10

Burdenc 180 300 180 240 180 240 1320 440

Note: S = small, L = large

c

Calculated 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

b

Number 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 

Annuala

a

Calculated 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 

Responseb

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 a

Average of 3 years divided by 3.

 b Hours 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 TABLEa
Submitted 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

a

301(h) universe has decreased since the previous ICR

b

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

TABLE A-13. EXPLANATION OF CHANGE IN BURDEN