INFORMATION COLLECTION REQUEST FOR NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM ( NPDES) AND SEWAGE SLUDGE MONITORING REPORTS OMB CONTROL NO. 2040 0004; EPA ICR# 0229.16 April 29, 2005 U. S. Environmental Protection Agency Office of Wastewater Management 1200 Pennsylvania Avenue, NW Washington, D. C. 20460 DMR Information Collection Request April 29, 2005 i TABLE OF CONTENTS 1.0 IDENTIFICATION OF THE INFORMATION COLLECTION . . . . . . . . . . . . . . . . . . . . . 1 1. a Title of the Information Collection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1. b Short Characterization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 2.0 NEED FOR AND USE OF THE COLLECTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 2. a Need/ Authority for the Collection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 2. b Practical Utility/ Users of the Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 3.0 NON DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA . 6 3. a Non duplication . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 3. b Public Notice Required Prior to ICR Submission to OMB . . . . . . . . . . . . . . . . . . . . 6 3. c Consultations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 3. d Effects of Less Frequent Collection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 3. e General Guidelines . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 3. f Confidentiality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 3. g Sensitive Questions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 4.0 THE RESPONDENTS AND THE INFORMATION REQUESTED . . . . . . . . . . . . . . . . . 9 4. a Respondents/ SIC Codes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 4. b Information Requested . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 4. b. 1 Data Requirements of NPDES Permittees: Major and Minor Individual Permittees, General Permittees, and MS4s . . . . . . . . . . . . . . . . . . . . . . . . . . 15 4. b. 2 Data Requirements for Sewage Sludge Facilities . . . . . . . . . . . . . . . . . . . . . 15 5.0 THE INFORMATION COLLECTED   AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT . . . . . . . . . . . . . . . . . . 16 5. a EPA Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 5. b Collection Methodology and Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 5. c Small Entity Flexibility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 5. d Collection Schedule . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 6.0 ESTIMATING THE BURDEN AND COST OF THE COLLECTION . . . . . . . . . . . . . . 19 6. a Estimating Respondent Burden . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 6. a. 1 Estimating Respondent Burden   Sampling . . . . . . . . . . . . . . . . . . . . . . . . . 20 6. a. 2 Estimating Respondent Burden   Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . 20 6. a. 3 Estimating Respondent Burden   Reporting/ Record keeping . . . . . . . . . . . . 20 6. b Estimating Respondent Cost . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 6. b. 1 Estimating Labor Costs ( 2004 Dollars) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 6. b. 2 Estimating Capital and Operating and Maintenance Costs . . . . . . . . . . . . . . 21 6. c Estimating Agency Burden and Cost . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 6. d Estimating Respondent Universe and Total Burden . . . . . . . . . . . . . . . . . . . . . . . . 22 6. e Bottom Line Burden Hours and Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 6. e. 1 Variations in the Annual Bottom Line . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 6. f Reasons for Change in Burden . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 6. g Burden Statement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 DMR Information Collection Request April 29, 2005 ii LIST OF EXHIBITS EXHIBIT 6.1a Number of Respondents and Responses ( NPDES Permittees) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 EXHIBIT 6.1b Number of Respondents and Responses ( Biosolids Facilities) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 EXHIBIT 6.2a Annual Sampling Labor Burden and Costs ( NPDES Permittees) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 EXHIBIT 6.2b Annual Sampling Labor Burden ( Biosolids Facilities) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29 EXHIBIT 6.3a Annual Analysis Labor Burden ( For NPDES Facilities) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 EXHIBIT 6.3b Annual Analysis Labor Burden ( for Biosolids Facilities) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 EXHIBIT 6.4a Annual Burden for Reporting and Record keeping* of DMRs ( NPDES Facilities) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32 EXHIBIT 6.4b Annual Burden for Reporting and Record keeping of DMRs ( Biosolids Facilities Required to Report and Record keep) . . . . . . . . . . . . . . . . . . . . . . 33 EXHIBIT 6.4c Annual DMR Record keeping Burden ( Sludge Facilities Required to Record keep Only) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 EXHIBIT 6.5a Total Agency Burden and Cost . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35 EXHIBIT 6.5b Total State Burden and Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36 EXHIBIT 6.6a Total Respondent Burden . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37 EXHIBIT 6.6b Summary ( bottom line) Burden and Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38 EXHIBIT 6.6c Change in Burden . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39 LIST OF TABLES Table 1.1. Summary of Burden and Costs Information Collection Request for Discharge Monitoring Reports for the NPDES Program . . . . . . . . . . . . . . . . . . . . . . 2 Table 4.1. Discharge Monitoring Reports: Respondent Requirements . . . . . . . . . . . . . . . . . . 13 DMR Information Collection Request April 29, 2005 iii Table 5.1. DMR State and Federal Requirements ( As Users of Data) . . . . . . . . . . . . . . . . . . . 17 Table B 1 Estimate of Annual Burden and Costs for MS4s . . . . . . . . . . . . . . . . . . . . . . . . . B 2 Table B 2 Non Storm Water General Permits from ePIFT . . . . . . . . . . . . . . . . . . . . . . . . . . B 4 Table B 3 Number and Distribution of Non Storm Water General Permits by Reporting Frequency from PCS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B 4 Table B 4 Number of Non Storm Water General Permits by Reporting Frequency from ePIFT adjusted using PCS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B 4 Table B 5 EPA Issued Non Storm Water General Permits Data From 2002 ICR ( EPA ICR No. 0229.15) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B 5 Table B 6 EPA Issued Non Storm Water General Permits Data for 2005 ICR . . . . . . . . . . . B 5 Table B 7 State Issued Non Storm Water General Permits Data for 2005 ICR From ePIFT adjusted using PCS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B 5 Table B 8 State Issued Non Storm Water General Permits Data for 2005 ICR From Table B 7 and Appendix B 2005 ICR ( EPA ICR No. 0229.15 . . . . . . . . . . . . . B 5 Table B 9 EPA and State Issued Non Storm Water General Permits Data for 2005 ICR From Table B 6 and Table B . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B 5 APPENDICES Appendix A Input Values and Assumptions Appendix B MS4 and General Permits Burden Appendix C Sample DMR Form Appendix D NPDES/ Sludge Program Status DMR Information Collection Request April 29, 2005 1 1.0 IDENTIFICATION OF THE INFORMATION COLLECTION 1. a Title of the Information Collection ICR: National Pollutant Discharge Elimination System ( NPDES) And Sewage Sludge Monitoring Reports OMB Control Number: 2040 0004 EPA ICR No. 0229.16 1. b Short Characterization/ Abstract This ICR revises the estimates of the 2002 Discharge Monitoring Report ( DMR) ICR monitoring, reporting, and record keeping burden and costs associated with submitting and reviewing DMRs, sewage sludge monitoring reports, and other monitoring reports under the Environmental Protection Agency's ( EPA) NPDES program. It was prepared according to the guidance contained in the Office of Policy ( OP) February 1999 ICR Handbook.

The NPDES program regulations, codified at 40 CFR Parts 122 through 125, require permitted municipal and non municipal point source dischargers to collect, analyze, and submit data on their wastewater discharges. Under these regulations, the permittee is required to collect and analyze wastewater samples or have the analysis performed at an outside laboratory and report the results to the permitting authority ( EPA or an approved NPDES State) primarily through the use of a pre printed DMR form used for reporting pollutant discharge information. Sample monitoring, analysis, and reporting frequencies vary by permit, but typically must be performed at least annually.

Under 40 CFR Part 501 ( State Sewage Sludge Management Program Requirements) and 40 CFR Part 503 ( Sewage Sludge Use or Disposal Standards), EPA also requires similar discharge monitoring and reporting for sewage sludge.

Under the existing NPDES management structure, EPA authorizes States to manage and administer the NPDES Program under State law based on minimum federal requirements. In addition to States, EPA may authorize NPDES program administration by U. S. Territories and Indian tribes that have been approved to be treated in the same manner as a State. In States without NPDES program approval, EPA is the permitting authority and undertakes all permitting activities.

As of February 2005, 45 States and 1 Territory ( i. e., approved States) had received approval from EPA to administer the NPDES permit program within their States; 45 States had received approval for the NPDES General Permits program ( a part of the NPDES Permit Program); and only 6 States had received approval for the NPDES Sewage Sludge Program ( also a part of the NPDES Permit Program). A table of approved programs is provided in Appendix D.

Upon approval of this ICR, the permitting authority will require NPDES and sewage sludge facilities to report pollutant discharge monitoring data. The permitting authority will use the data from these forms to assess permittee compliance, modify/ add new permit requirements, and revise effluent guidelines. The monitoring data required of NPDES and sewage sludge facilities represents the minimum information necessary to achieve the Agency's goals and satisfy regulatory standards. DMR Information Collection Request April 29, 2005 2 Table 1.1 presents a summary of the time and financial resources ( burden) for NPDES facilities for submitting DMRs. These resources will be expended by NPDES ( and sludge) facilities for collecting, analyzing, reporting, and record keeping pollutant monitoring data under the terms and conditions of their discharge permits and existing NPDES regulations. Table 1.1 also presents a summary of the time that States and the Federal Government will spend in reviewing, analyzing, and processing the data submitted by NPDES permittees.

Table 1.1. Summary of Burden and Costs Information Collection Request for Discharge Monitoring Reports for the NPDES Program Category Burden Annual Pollutant Sampling Burden ( hours) ( A) 3,934,507 Annual Pollutant Analysis Burden ( hours) ( B) 8,888,433 Annual DMR Reporting Burden ( hours) ( C) 1,174,626 Annual Record keeping Burden ( hours) ( D) 19,226 Total Annual Response Burden ( hours) ( A + B + C + D) 14,016,791 Annual State Burden ( hours) 147,791 Annual Federal Burden ( hours) 9,886 Annual Number of Responses ( E) 583,987 Average time per response ( hours) ( A + B + C + D)/( E) 24.0 Total Number of Respondents* 81,998 * In addition to permittees, total number of respondents includes the 45 States and 1 Territory that are responsible for NPDES program implementation. Permittees include total respondents identified in Exhibit 6.1. a and the sludge only facilities and domestic septage haulers identified in Exhibit 6.1. b. Sludge/ NPDES Permittees POTWs identified in Exhibit 6.1. b are already accounted for in Exhibit 6.1. a. DMR Information Collection Request April 29, 2005 3 2.0 NEED FOR AND USE OF THE COLLECTION 2. a Need/ Authority for the Collection EPA established the NPDES permit program under the authority of the Clean Water Act ( CWA). The purpose of the CWA is " to restore and maintain the chemical, physical, and biological integrity of the nation's waters" [ Section 101( a)]. Section 402 of the Act established the NPDES program to regulate the discharge of any pollutant, or combination of pollutants, from point sources into waters of the United States. Point source dischargers include publicly owned treatment works ( POTWs), privately owned treatment works ( PrOTWs), manufacturing facilities, concentrated animal feeding operations, aquatic animal production facilities, mining operations, and other types of facilities or industries. Section 402( a) of the CWA, as amended, authorizes the EPA Administrator to issue permits to dischargers of pollutants if the discharge meets:

° All applicable requirements of CWA Sections 301, 302, 306, 307, 308, and 403 ° Any conditions established by the Administrator to ensure that the provisions of the CWA are met.

In particular, Section 402( a)( 2) of the CWA requires EPA to prescribe permit conditions to assure compliance with requirements " including conditions on data and information collection, reporting and such other requirements as [ the Administrator] deems appropriate."

While Section 402 establishes the base NPDES permit program for both technology and water quality based permits, Section 304( l) accelerated the identification and control requirements of certain toxic discharges where water quality was impaired. Where appropriate, States have translated results of whole effluent toxicity and water quality studies into water quality based limits. Where additional data are necessary to assess the need for toxic controls, monitoring requirements have been imposed requiring whole effluent toxicity and/ or chemical specific data. In some cases, stream quality monitoring is necessary to assess the effect of the permitted discharge on stream standards.

In 1987, Congress passed the Water Quality Act ( WQA), which added a provision [ Section 402( p)] that directed EPA to establish final regulations governing storm water discharges under the NPDES program.

Section 405 of the CWA prohibits the discharge of pollutants caused by the disposal of sewage sludge except in accordance with an npdes permit ( or an approved State permit issued to control such disposal of sewage sludge). In addition, this section establishes a comprehensive sewage sludge permitting program and requires EPA to develop technical criteria for controlling sewage sludge disposal and use.

Under Section 308 of the CWA, NPDES and sewage sludge regulated entities must: "( I) establish and maintain such records, ( ii) make such reports, ( iii) install, use, and maintain such monitoring equipment or methods ( including where appropriate, biological monitoring equipment methods), ( iv) sample such effluent ( in accordance with such methods, at such locations, at such intervals, and in such a matter as the Administrator shall prescribe), and ( v) provide such other information as the Administrator may reasonably require."

The specific monitoring, reporting, and record keeping requirements for NPDES and sewage sludge programs included under this information collection request are applicable to EPA and State wastewater DMR Information Collection Request April 29, 2005 1 The information collection requirements associated with this site inspection are addressed in the Compliance Assessment ICR ( OMB No. 2040 0110).

4 management programs, NPDES permittees ( including storm water) and treatment works treating, using or disposing of sewage sludge. The Federal requirements are codified at 40 CFR Parts 122 and 123, 40 CFR Part 501, and 40 CFR Part 503. Each of these requirements is described below:

PART 122   EPA ADMINISTERED PERMIT PROGRAMS: THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM Describes the general NPDES program requirements; establishes permit conditions, including monitoring, reporting, and record keeping requirements to assure compliance with permit limits; specifies monitoring type, interval, and frequency sufficient to yield representative data of the monitored activity; and mandates that reporting frequency be dependent on the nature and effect of the discharge, but, except for storm water discharge, in no case less than annually. Stipulates monitoring requirements for storm water discharges on a case by case basis, with sampling and reporting frequency dependent on the nature and effect of the discharge. At a minimum, storm water permittees must conduct an annual inspection. 1 PART 123   STATE PROGRAM REQUIREMENTS Outlines comparable program requirements for NPDES State permits, including similar monitoring, reporting, and record keeping standards, as outlined above in Part 122.

PART 501   STATE SEWAGE SLUDGE MANAGEMENT PROGRAM REGULATIONS Identifies general State sewage sludge program requirements and establishes application, monitoring, reporting, and record keeping requirements, including monitoring types and frequencies for all treatment works treating domestic sewage.

PART 503   STANDARDS FOR THE USE OR DISPOSAL OF SEWAGE SLUDGE Details the monitoring, reporting, and record keeping and technical criteria and standards for treatment works that land apply, surface dispose, or incinerate sewage sludge.

While the above establishes EPA's authority and requirement to collect pollutant information, EPA has specific needs for collecting the data. These needs include:

° To provide information on pollutant discharge trends ° To provide information to permitting authorities to prioritize permit activities ° To determine whether permittees are in compliance with their permit conditions ° To provide information to the permit writer to determine the need for permit limits.

A summary of the specific monitoring, reporting, and record keeping requirements for affected NPDES and sewage sludge entities is described in Section 4.0 and is outlined in Table 4.1 ( DMR Respondent Requirements). Table 5.1 ( DMR State and Federal Requirements) summarizes the review and oversight requirements for users of DMR data. DMR Information Collection Request April 29, 2005 5 2. b Practical Utility/ Users of the Data As noted above, discharge monitoring data provides EPA and States with approved NPDES and sewage sludge management programs with the necessary information to assess permittee compliance. Selfmonitoring data also helps the permitting authority modify or develop appropriate permit limits. Permitting authorities also may require other types of monitoring data, such as: influent monitoring data to evaluate a plant's operational aspects; ambient stream monitoring data to measure a permit's effectiveness in protecting water quality; internal waste stream data when monitoring at the point of discharge is impractical or infeasible; or visual monitoring ( including underwater surveys) that may be necessary to determine compliance with permit limits.

EPA and States analyze monitoring data when establishing permit conditions. For example, NPDES permit writers may revise permit requirements based on data from monitoring reports. Furthermore EPA and States have referred to DMR data on toxic pollutants when developing lists of waters impaired by toxic pollutants and point source dischargers responsible for damaging the quality of those waters.

Permittees use the monitoring data they collect to evaluate facility performance. For this reason, most permittees collect additional data ( e. g., product quality and production efficiency information) that may or may not be included with monitoring reports. Collection and reporting of data to permitting authorities also provides permittees with an incentive to remain in compliance with their established permit conditions.

As public information, monitoring data are used by public groups for a variety of purposes. Citizen groups review monitoring data to independently assess pollutant discharger compliance and noncompliance In some instances the data forms the basis for citizen suits that are authorized under Section 505 of the CWA. In addition, environmental groups, academicians, and others use monitoring data to estimate toxic pollutant loading to streams, lakes, oceans, and estuaries. DMR Information Collection Request April 29, 2005 6 3.0 NON DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA 3. a Non duplication EPA has examined all other reporting requirements contained in the CWA and 40 CFR Parts 122, 123, 501, and 503. From previous experience, EPA knows that DMR type data are not available from the following sources:

° Permit Application Data ° Sampling Inspections ° Toxic Chemical Release Inventory.

Permit Application Data Data presented with the NPDES permit application represent effluent levels at the time the facility submits its application for a new or re issued permit. EPA uses monitoring data in conjunction with effluent guidelines and water quality standards to establish appropriate permit conditions. Although data submitted with the application may adequately represent effluent quality at the time of the submission, they do not adequately assess compliance with permit limits which are developed after the application is submitted. Also, permittees submit application data only once during the typical 5 year life of a permit. Therefore, permit application data are inadequate for measuring ongoing permittee compliance with effluent limitations.

Sampling Inspections Discharge data are generated from the sampling inspections that permitting authorities are required to conduct. However, permitting authorities conduct these inspections only occasionally. Furthermore, sampling inspections are limited to a portion of major facilities and to a selected number of minor permittees. Although EPA uses monitoring data in conjunction with inspection data to assess permit compliance, inspection data are infrequent and sparse, and therefore, are an inadequate replacement to routine monitoring data.

Toxic Chemical Release Data Toxic chemical release data provide general information on industrial releases to different media. Annual estimates are made of releases to land, air, injection, water, and POTWs. These estimates are derived using methods documented on Form R. Although these data are valuable for estimating annual total pounds of pollutants released, these data cannot be used to assess permittee compliance for two reasons. First, the data are submitted only annually, and second, the forms report pounds per discharge per facility. The toxic chemical release information is not outfall specific. EPA cannot assess permittee compliance with a concentration or daily discharge limitation.

Therefore, permit application, compliance inspection, and toxic chemical release, though similar to DMR data, are insufficient to assess compliance with permit limitations.

3. b Public Notice Required Prior to ICR Submission to OMB In compliance with the 1995 Paperwork Reduction Act, EPA solicited comments for a 60 day period prior to submission of the ICR to OMB. Comments were requested on November 23, 2004 via a DMR Information Collection Request April 29, 2005 7 Federal Register Notice ( 69 FR 68142). One non substantial comment was received in response to this notice, which did not address any of the burden calculations in this ICR.

3. c Consultations EPA regularly consults other interested parties regarding monitoring related information collection activities. In particular, EPA has instituted:

° Public comment opportunities on ICRs and on regulations ° Public notice and comment opportunities prior to permit issuance ° Informal discussions between permittees and permit writers ° Appeal opportunities after permit issuance.

Historically, public comment periods have been associated with DMR related regulatory changes. Since 1973, EPA has solicited public comments on monitoring related issues in conjunction with the promulgation of NPDES rules and regulations. For example, with the promulgation of the Phase II Storm Water Rule, numerous comments were received from private industry, public municipalities, and private interest groups. In all cases, EPA carefully reviewed and considered the comments.

3. d Effects of Less Frequent Collection EPA recognizes the importance of balancing the need for data collection efforts against respondent burden and costs. From the inception of the NPDES program, cost has been one of the major factors considered in setting monitoring requirements and frequencies. In the past ten years, the Executive and Legislative branches of the U. S. Government have stressed the need for evaluating the costs and benefits of regulation and the financial impact on the regulated community, State, and local government. In this new environment, EPA is seeking new opportunities to reduce monitoring and reporting burden on the regulated community.

For example, on April 19, 1996, EPA issued a memorandum entitled, " Interim Guidance for Performance Based Reductions of NPDES Permit Monitoring Frequencies" to reduce reporting, where appropriate, while maintaining a high level of environmental protection for the Nation. The interim guidance allows NPDES authorities to grant relief to permittees that have a good record of compliance and pollutant discharges at levels below permit requirements. In the 1998 ICR, EPA estimated a 26 percent reduction in burden from previous levels for monitoring and reporting requirements would result from the implementation of this initiative. To validate this estimate for the 2002 ICR, EPA evaluated actual implementation of the interim guidance and found a wide range of implementation activities. While some states have implemented the guidance fully, others have not yet implemented any aspects identified in the guidance. EPA found that approximately 25 percent of permittees are expected to be evaluated for the reduced monitoring/ reporting requirements.

EPA strives to minimize monitoring related workloads. For example, EPA developed an automated procedure that pre prints relevant permittee information, such as discharger name and address, pollutants limited, and effluent limitations on the DMR form before sending it to the permittee. Permittees are required only to record their monitoring results and to report any violations.

EPA also has made extensive use of general permits which tend to have less stringent and, therefore, less burdensome monitoring and reporting requirements than individual permits. In fact, the majority of storm water permits discharges from industrial facilities are covered under general permits. DMR Information Collection Request April 29, 2005 8 EPA continues its efforts to minimize permittee burden associated with monitoring data collection and reporting requirements. However, the Agency has determined that the information currently required is at, or near the minimum that is necessary to adequately evaluate permittee compliance.

3. e General Guidelines This information collection request is in compliance with the Paperwork Reduction Act ( PRA) guidelines ( 5 CFR § 1320.5( d)( 2)).

3. f Confidentiality The data required under this information collection request, discharge monitoring data, are not confidential. Section 308( b) of the CWA specifically excludes " effluent data" from protection as confidential information. However, to the extent that issues regarding confidentiality do arise, they will be handled pursuant to 40 CFR Part 2.

3. g Sensitive Questions Sensitive questions are defined in EPA's ICR Handbook, " Guide to Writing Information Collection Requests Under the Paperwork Reduction Act of 1995 " as " questions concerning sexual behavior or attitudes, religious beliefs, or other matters usually considered private." The reporting requirements addressed in this information collection request do not include sensitive questions. DMR Information Collection Request April 29, 2005 2 There are no monitoring and reporting requirements established in the General Permit for Storm Water Discharges from Construction Activities.

9 4.0 THE RESPONDENTS AND THE INFORMATION REQUESTED 4. a Respondents/ SIC Codes The respondents to this information collection request are NPDES permittees including publicly owned treatment works ( POTWs), privately owned treatment works, industrial facilities, and storm water permittees ( Part 122). The sewage sludge record keeping and reporting requirements identified in this ICR apply to treatment works ( public and private) treating domestic sewage and to domestic septage haulers.

NPDES PERMITTEES ( 40 CFR PART 122)

Under 40 CFR § 122.21, any point source discharger of pollutants into waters of the United States must apply for an NPDES permit that establishes effluent limitations and outlines monitoring requirements ( i. e., collecting, analyzing, and reporting sample results to the permitting authority). The following categories of NPDES permittees are required to submit DMRs.

° Major Dischargers ( Individual Permittees): Municipal and Non municipal ° Minor Dischargers ( Individual Permittees): Municipal and Non municipal ° Dischargers Covered by a Non Storm Water General Permit ° Storm Water Discharges Associated with Industrial Activity (" industrial storm water discharges") ° Storm Water Discharges Associated with Construction Activity 2 ° Municipal Separate Storm Sewer Systems ( MS4s) ° Combined Sewer Overflows ( CSOs).

An estimate of the number of permittees within each of these categories is shown in Exhibit 6.1a.

Major Dischargers ( Individual Permittees): Municipal and Non municipal EPA uses discharge volume and the strength of organic waste ( i. e., population equivalent) to distinguish facilities as major or minor dischargers.

A major municipal discharger discharges at least one million gallons of wastewater a day, or serves a population equivalent of 10,000. POTWs are classified under SIC Code 4952 ( Sewerage Systems).

EPA uses a formula based on the following discharge characteristics to classify non municipal dischargers as majors or minors:

° Toxic pollutant potential ° Flow ° Conventional pollutant potential ° Public health impact ° Water quality impact ° Proximity to coastal waters. DMR Information Collection Request April 29, 2005 3 See Appendix B.

10 EPA assigns weighted numerical values to each discharge characteristic based on its environmental risk potential. Each non municipal facility receives a total numerical value which is the sum of the weighted values. EPA categorizes non municipal facilities with values greater than 80 points ( 0 to 265 scale) as major dischargers. Facilities with point totals below this threshold are classified as minor dischargers.

Permittee wastewater characteristics vary greatly among non municipal dischargers. Unlike POTWs, which are described by a single SIC code, non municipal dischargers may be categorized into many SIC codes. Non municipal dischargers are industrial facilities but the materials used, the products manufactured, the production processes, the by products, and the recycling procedures can be very different. Even the combination of waste stream types and treatment systems can vary greatly.

Minor Dischargers ( Individual Permittees): Municipal and Non municipal All facilities that are not majors ( as defined above) are categorized as minor dischargers. However, in some instances, where the receiving water quality is of significant concern, EPA may reclassify some minor dischargers as majors. The SIC codes for minor municipal dischargers are the same as major municipal dischargers ( 4952). Non municipal facilities, as described above, can be categorized into many SIC codes.

Dischargers Covered by a Non Storm Water General Permit3 EPA and authorized States issue general permits to groups of facilities that have similar operating procedures, discharge characteristics, and geographic location ( e. g., States). In this way, permitting authorities can cover a large number of facilities within one permit and establish a common set of limitations monitoring requirements, and permit conditions. For these permittees, the monitoring and reporting requirements tend to be less stringent than those imposed on holders of individual permits. Non storm water general permittees, similar to non municipal permittees, are covered by many SIC codes. For example, general permits have been issued by EPA Regions for the following types of dischargers:

° Oil and Gas Facilities ( e. g., Regions 4, 6, and 10) ° Seafood Processing Facilities ( e. g, Region 10) ° Aquaculture Facilities ( e. g, Region 10) ° Other Facilities with General Permits S Concentrated Animal Feeding Operations ( e. g, Regions 9 and 10)

S Log Transfer Facilities ( e. g, Region 10)

S Suction Dredging ( e. g., Region 10)

S Placer Mining ( e. g., Region 10)

S Petroleum Bulk Stations and Terminal ( e. g., Region 6)

S Cleanups of Petroleum Underground Storage Tank Systems ( e. g., Region 6)

S Concrete Facilities ( e. g., Region 6)

S Beneficial Reuse or Disposal of Municipal Sewage Sludge ( e. g., Region 6)

S Noncontact Cooling Water Dischargers ( e. g., Region 1)

S Water Treatment Facilities ( e. g. Region 1)

Storm Water Discharges Associated with Industrial Activity DMR Information Collection Request April 29, 2005 11 The majority of industrial storm water permittees are covered under storm water general permits. In some instances, permittees are required to monitor their discharge and submit monitoring results to the permitting authority. The following types of facilities and manufacturing operations defined in 40 CFR 122.26( b)( 14) are required to obtain NPDES permit coverage for their industrial storm water discharges and may also be required to monitor and report:

Facilities subject to storm water effluent limitations guidelines, new source performance standards, or toxic pollutant effluent standards ( 40 CFR 122.26( b)( 14)( i)),

Heavy industrial manufacturing ( 40 CFR 122.26( b)( 14)( ii)),

Mineral and metal mining and certain oil and gas exploration, production, processing or treatment, and transmission activities ( 40 CFR 122.26( b)( 14)( iii)),

Hazardous waste treatment, storage, or disposal facilities ( 40 CFR 122.26( b)( 14)( iv)),

Landfills, land application, and open dumps that receive industrial wastes ( 40 CFR 122.26( b)( 14)( v)),

Recycling facilities ( 40 CFR 122.26( b)( 14)( vi)),

Steam electric power generating facilities, including coal handling ( 40 CFR 122.26( b)( 14)( vii)),

Transportation facilities ( 40 CFR 122.26( b)( 14)( viii)),

Treatment works treating domestic sewage, generally with a design flow or 1.0 million gallons per day ( 40 CFR 122.26( b)( 14)( ix)),

Light industrial activity ( 40 CFR 122.26( b)( 14)( xi)).

EPA promulgated Phase II Storm Water Regulations on December 8, 1999, that contain a no exposure certification option for facilities that will provide a waiver from permit coverage ( and monitoring). Estimates of the number of facilities that will be able to claim the no exposure exclusion are based on the economic analysis prepared for that rule.

Storm Water Discharges Associated with Construction Activity The majority of construction storm water permittees are covered under a general permit. There are no monitoring and reporting requirements established for facilities discharging under authority of these general permits.

The Phase II Storm Water Regulations promulgated on December 8, 1999, added construction sites between one and five acres to the list of federally regulated facilities; however, information collection burden and costs for those facilities are included in the Phase II ICR, OMB Control Number 2040 0211.

Municipal Separate Storm Sewer Systems ( MS4s)

MS4s are defined as conveyances or systems of conveyances that are: owned or operated by a State, city, town, borough, county, parish, district, association, or other public body ( created by or pursuant to State law) having jurisdiction over disposal of sewage, industrial wastes, storm water, or other wastes, including special districts under State law such as a sewer district, flood control district or drainage district, or similar entity, or an Indian tribe or an authorized Indian tribal organization, or a designated and approved management agency under section 208 of the Clean Water Act that discharges to waters of the United States; designed or used for collecting or conveying storm water; which is not a combined sewer; and which is not part of a POTW. As part of their permit application, MS4s that serve populations over 100,000 are required to establish monitoring programs. Currently, EPA estimates that 270 MS4 permits, encompassing approximately 1,000 municipalities are affected by this requirement. DMR Information Collection Request April 29, 2005 12 The Phase II Storm Water Regulations promulgated on December 8, 1999, added small MS4s to the list of federally regulated facilities; however, information collection burden and costs for those facilities are included in the Phase II ICR, OMB Control Number 2040 0211.

Combined Sewer Overflows Burden related to Combined Sewer Overflow ( CSO) DMRs is incorporated and presented in the CSO Policy ICR in 1997 ( OMB Control No. 2040 0170).

SEWAGE SLUDGE FACILITIES Under § 122.21( a), all treatment works treating domestic sewage ( TWTDS) or sludge must apply for a sewage sludge management permit. Treatment works are required to report sewage sludge monitoring data according to the parameters set forth in their permits.

Part 503 establishes technical standards for treatment works that land apply, surface dispose, or incinerate sewage sludge. Part 503 details requirements for use or disposal, including monitoring, reporting, and record keeping for the affected entities.

Facilities covered under Part 503 are classified according to how they use or dispose of sewage sludge. Facilities engaging in land application spray or spread sewage sludge onto the land surface, inject sewage sludge below the land surface, or incorporate sewage sludge into soils. Surface disposal involves placement of sewage sludge on an area of land for final disposal ( this excludes land on which sewage sludge is placed for either treatment or storage). Incineration involves combustion of organic matter and inorganic matter in sewage sludge at high temperatures in a sewage sludge incinerator. Each type of facility must meet certain general monitoring, reporting, and record keeping requirements.

4. b Information Requested The following two sections outline the monitoring, reporting, and record keeping requirements for NPDES permittees ( major and minor individual permittees, general permittees, and MS4s) and Sewage Sludge Facilities under 40 CFR Part 503. Table 4.1 outlines the information requirements for each category of respondents. The data requirements are listed by regulation number and are grouped by respondent category. Within each category, the information data requirements are further organized into the following sections:

° Monitoring Requirements: Sample Collection and Analysis ° Reporting and Record keeping Requirements. DMR Information Collection Request April 29, 2005 13 Table 4.1. Discharge Monitoring Reports: Respondent Requirements 40 CFR Citation Regulatory Description Response Frequency NPDES MAJOR AND MINOR INDIVIDUAL PERMITTEES, GENERAL PERMITTEES, AND MS4S Monitoring Requirements: Sample Collection and Analysis § 122.41( j)( 1) Requires the permittee to collect representative samples, take measurements. ( Sample collection requirements [ e. g., collection frequency, sample type] are as listed in the facilities' permit.) Variable/ Permit Specific § 122.41( j)( 1) Requires the permittee to conduct pollutant analysis on the representative samples collected. Variable/ Permit Specific Reporting and Record keeping Requirements § 122.41( l)( 4) Requires the permittee to report all monitoring results to the permitting authority using Discharge Monitoring Reports. Permit Specific/ At Least Annually § 122.41( j)( 2) Requires permittee to retain ongoing monitoring records and copies of all reports for at least 3 years. Permit specific/ At Least Annually SEWAGE SLUDGE FACILITIES Monitoring Requirements: Sample Collection and Analysis § 503.16( a b) § 503.26( a b) § 503.46( a b) Requires permittee to conduct pollutant monitoring of disposed sewage sludge. Sampling frequencies are as follows:

° Greater than 0 but less than 290 metric tons a year ( mt/ yr) Annually ° Greater than or equal to 290 but less than 1,500 mt/ yr Quarterly ° Greater than or equal to 1,500 but less than 15,000 mt/ yr Bi monthly ° Greater than or equal to 15,000 mt/ yr Monthly After 2 years and at the discretion of the permitting authority, the pollutant sampling frequency may be reduced, but in no case will it be less than once a year.

§ 503.16( a b) § 503.26( a b) § 503.46( a b) Requires the permittee to conduct pollutant analysis on all representative samples collected. Variable/ At Least Annually DMR Information Collection Request April 29, 2005 14 Table 4.1. Discharge Monitoring Reports: Respondent Requirements ( Continued)

40 CFR Citation Regulatory Description Response Frequency Reporting and Record keeping Requirements § 503.18( a) § 503.28( a) § 503.48( a) Requires Class I facility to report all pollutant monitoring and analysis results to the permitting authority. Annually § 503.17( a)( 1) § 503.27( a)( 1) § 503.47( a) Requires the facility to retain records of all monitoring data for at least 5 years. The facility also must keep copies of all reports. Ongoing § 501.15( b)( 10)( ii) Requires permitted treatment works to conduct pollutant monitoring. ( Sampling frequency is dependent on its sewage sludge use and disposal practices.) At a minimum, the permittee must follow the monitoring and analysis requirements set forth under Part 503. In no case will the permittee sample less than once a year. Variable/ At Least Annually § 501.15( b)( 10)( ii) Requires the permittee to conduct pollutant analysis on and take measurements of all representative samples collected. Variable/ At Least Annually § 501.15( b)( 10)( i) Requires the permittee to report all pollutant monitoring and analysis results to the permitting authority. Variable/ At Least Annually § 501.15( b)( 10)( iii) Requires the permittee to retain records of all monitoring data and keep copies of all reports for at least 5 years. This period may be extended at the discretion of the Director. All monitoring records must include:

° Sample date, place, and time ° Name of individual who performed testing ° Date analysis was performed ° Name of individual who performed analysis ° Analysis techniques ° Analysis results. Ongoing While monitoring and reporting requirements vary considerably among and within permittee categories, all permits specify sampling and reporting frequency and location as well as other sampling and analysis parameters. Should a facility choose to collect and analyze more samples than specified in its permit, the permittee is required to include all monitoring data in reports. Also, the permittee must collect and analyze representative samples and must conduct all monitoring according to permit specific conditions and/ or approved test procedures as set forth under 40 CFR Part 136 or as specified in Part 503.

To simplify and accelerate State and/ or EPA review, it is essential that monitoring data be reported uniformly. Therefore, the permitting authority requires the permittee to submit most of its effluent monitoring data in DMRs. ( Some approved States use a variant of EPA's form.) A DMR is a pre printed summary form that EPA has developed to minimize respondent burden and standardize NPDES data reporting by permittees. In instances where EPA requires monitoring other than effluent monitoring, the permittee may need to prepare and submit additional or supplemental forms. Permittees submit DMRs, DMR Information Collection Request April 29, 2005 15 and/ or other forms where necessary, to the appropriate permitting authority, which may be either a State with an approved NPDES or sewage sludge management program, or an EPA regional office.

4. b. 1 Data Requirements of NPDES Permittees: Major and Minor Individual Permittees, General Permittees, and MS4s Monitoring Requirements: Sample Collection and Analysis ( § 122.41( j))

NPDES permittees are required to collect representative samples of all monitored activity and to take associated measurements. Permittees are also required to conduct pollutant analysis on all samples collected according to the parameters outlined in the facility's permit. The permit also will specify the frequency with which the permittee must conduct sampling and analysis.

Reporting and Record keeping Requirements ( § 122.41 ( l) and § 122.41( j))

NPDES permittees are required to report all monitoring results to the permitting authority. The frequency with which the permittee must submit these reports is permit specific. Appendix C contains a sample pre printed discharge monitoring form ( i. e., a blank DMR). Permittees reporting monitoring data that is not effluent data may submit the information in other formats, as specified by the permitting authority. NPDES permittees are required to retain monitoring records, copies of all reports required by the permit, and records of all data used to complete the permit application for at least 3 years. The burden associated with the record keeping requirements for NPDES permittees is included in the Compliance Assessment ICR.

4. b. 2 Data Requirements for Sewage Sludge Facilities Monitoring Requirements: Sample Collection and Analysis ( § 503.16, § 503.26, and § 503.46)

The Part 503 rule includes tables listing minimum monitoring frequencies for sludge that will be land applied, placed on a surface disposal site, or incinerated. Frequency of monitoring requirements range from once a year for facilities using or disposing of relatively small amounts of sludge to once a month for facilities disposing of larger amounts of sludge ( see Table 4 1 for specific monitoring frequencies).

Reporting and Record keeping Requirements ( § 503.18, § 503.28, and § 503.48)

Treatment works that land apply, surface dispose, or incinerate sewage sludge are required to report all pollutant monitoring results to the permitting authority. Reporting frequencies are permit specific. The permitting authority requires sewage sludge monitoring reports at least once a year.

Even if the treatment works is not required to report monitoring data, they must be retained for a period of 5 years, or indefinitely for cumulative amounts of pollutants added to any site by Cumulative Pollutant Land Rates ( CPLR) sludge.

Requirements for additional monitoring and reporting are determined according to the permit writer's best professional judgement ( BPJ). These requirements are dependent on the amount of sewage sludge produced, sewage sludge use, the number and types of industrial users discharging to treatment works, and previous sewage sludge quality data. EPA may require more frequent data collection or additional pollutant monitoring to assess permit compliance. DMR Information Collection Request April 29, 2005 16 Part 503 requires Class I sludge management facilities and POTWs with a flow rate equal to or greater than one MGD, or that serve a population of 10,000 or more, to report data at least once a year if they land apply, surface dispose, or incinerate sewage sludge. DMR Information Collection Request April 29, 2005 17 5.0 THE INFORMATION COLLECTED   AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT 5. a EPA Activities Upon approval of this ICR, permittees will submit DMRs, and/ or other forms where necessary, to the appropriate permitting authority. The permitting authority can be either an approved NPDES State, or one of EPA's regional offices.

The permitting authority is required to review data, and where necessary, conduct follow up actions. Table 5.1 summarizes the Agency's oversight responsibilities. The data requirements are listed by regulation number and are grouped by respondent category. Within each category, the information data requirements are further organized into the following sections:

° Discharge Monitoring Report ( DMR) Review ° Reporting and Record keeping Requirements.

Data review varies from region to region and state to state. Generally, the permitting authority routinely screens data to identify permit violations and conducts a more thorough technical review and follow up when violations are detected. Follow up activities may include informal contact with the permittee ( by telephone or letter) requesting prompt corrective action, technical assistance, field inspections to further substantiate violations, or a formal enforcement action such as an Administrative Order or referral to the U. S. Attorney General ( or State Attorney General in the case of NPDES authorized States).

The extent to which EPA reviews data in assessing permit compliance also varies. For example, EPA will conduct a more extensive review of permittees that are, or have been, in violation of their permit requirements, than of permittees who have been in full compliance. In cases of continued non compliance, EPA may use monitoring report data to identify patterns of non compliance and/ or to support Agency enforcement efforts.

EPA limits its review of data submitted by fully compliant permittees to a simple determination of continuing compliance. EPA may reduce monitoring requirements for permittees that consistently demonstrate an ability to reduce pollutants in their discharge below their permit limitations.

The extent to which EPA reviews data also depends on available resources and the specific reviewing procedures of the permitting authority ( State or EPA region). In NPDES States, State environmental agencies generally review permittee data. EPA regions also may review data from permittees in NPDES States while performing program oversight functions ( e. g., during file audits and when compiling statistical compliance summaries).

EPA regions review data in non authorized States. The regional permitting authority places emphasis on data from major permittees and from minor permittees that may cause water quality problems ( i. e, significant minors). EPA reviews data from other minor permittees and general permittees less frequently. In most cases, EPA will forward copies of reports to non authorized States, which routinely review data from minor permittees.

EPA does not require these non authorized States to review data, but several States voluntarily conduct the review and use the results in their own programs. DMR Information Collection Request April 29, 2005 18 Table 5.1. DMR State and Federal Requirements ( As Users of Data)

40 CFR Citation Regulatory Description Response Frequency NPDES PERMITTEES: MAJOR AND MINOR INDIVIDUAL PERMITTEES, GENERAL PERMITTEES, AND MS4S Discharge Monitoring Report ( DMR) Review § 123.26( a) Requires the permitting authority to review DMR submissions, using the reported data to monitor permittee compliance. The permitting authority also will conduct an initial screening. Variable/ Permit Specific § 123.26( e)( 3) When warranted, requires the permitting authority to followup the initial screening with a substantive technical evaluation to determine permittee compliance with permit conditions. As Necessary Reporting and Record keeping Requirements § 123.26( e)( 4) Requires the permitting authority to establish and regularly maintain a management information system. Ongoing SEWAGE SLUDGE FACILITIES ( PART 501) STATE SLUDGE MANAGEMENT PROGRAMS Monitoring Report Review § 501.16 § 123.26( a) Requires State sewage sludge management programs to follow the requirements and procedures for compliance monitoring and evaluation as set forth under § 123.26. Under § 123.26, the permitting authority is required to review DMR submissions, using the reported data to monitor permittee compliance. The permitting authority will conduct an initial screening. Variable/ Permit Specific § 501.16 § 123.26( e)( 3) When warranted, the permitting authority must follow up the initial screening with a substantive technical evaluation to determine permittee compliance with permit conditions. As Necessary Reporting and Record keeping Requirements § 501.16 § 123.26( e)( 4) Requires the permitting authority to establish and regularly maintain a management information system. Ongoing Data reported by major permittees is stored in the Permit Compliance System ( PCS) for use at a later date. Data reported by minor permittees and general permittees may be stored in the PCS. EPA may use this data to evaluate problems resulting from citizen complaints, focus inspection efforts, conduct spot check reviews, and determine appropriate enforcement action.

5. b Collection Methodology and Management EPA has considered using improved information technology to reduce respondent burden . Preprinted DMR forms are one method that EPA has used to improve its collection methodology. EPA is working toward the implementation of electronic submission of DMR data as well. The electronic submission of DMR data are voluntary and will be an alternative to the paper DMR submission. DMR Information Collection Request April 29, 2005 19 5. c Small Entity Flexibility Small businesses that do not discharge wastewater or that discharge wastewater to POTWs are exempt from NPDES permit requirements, and therefore, do not have any DMR monitoring or reporting burdens. Although small business direct dischargers are not treated as a separate class under the NPDES program, efforts to minimize the burdens imposed upon them by NPDES information collection activities are implicit in the existing monitoring/ reporting framework. Most small businesses permitted under NPDES, except those discharging toxic chemicals, are covered either by permits with less rigorous monitoring and reporting requirements or by general permits. This tends to impose lesser DMR related workloads on minor permittees and general permittees than major individual permittees.

In general, monitoring and reporting requirements are based upon many factors, the most important of which are the volume and environmental significance of wastewater discharge. Since small businesses which are subject to NPDES permits usually discharge small volumes of wastewater, their monitoring and reporting burdens tend to be minimal.

5. d Collection Schedule The information collection process includes two distinct collection activities: monitoring ( sample collection and analysis), and reporting and record keeping. Collection frequencies vary for the universe of permittees covered by the NPDES program. However, permittees are required, at a minimum, to monitor their wastewater or biosolids annually. DMR Information Collection Request April 29, 2005 4 Some facilities may only have a record keeping burden ( i. e., they are not required to report monitoring results).

5 This is not necessarily true for MS4s, because many municipalities may have a great number of outfalls discharging stormwater. See Appendix B.

6 The facilities covered by the Region 4 General Permit for the Beneficial Reuse and Disposal of Municipal Sludge in Louisianna are counted in this Exhibit.

20 6.0 ESTIMATING THE BURDEN AND COST OF THE COLLECTION 6. a Estimating Respondent Burden This section describes the methods EPA used to calculate the burden to respondents associated with collecting and reporting or maintaining records of monitoring data. The burden on each respondent is the sum of three activities.

Respondent Burden = Sampling Burden + Analysis Burden + Reporting/ Record keeping Burden4 Respondent burden is a function of factors that are specific to each NPDES permit or, in the case of Part 503 biosolids facilities, specified in the regulations. These factors include, but are not limited to:

° The number of facility outfalls ( a DMR is submitted for each outfall) 5 ° The number of samples collected ° The number of parameters monitored ° The burden associated with analyzing each parameter ° The frequency of sample collection.

EPA has estimated average or typical values for each of the above factors ( i. e., number of outfalls, number of samples, number of hours to collect a sample) to calculate respondent burden. These averages are difficult to estimate because of the variability of monitoring and reporting requirements among regulated facilities. EPA has attempted to categorize DMR respondents by ownership ( public vs. private), major/ minor, effluent flow, and/ or industrial classification; however, burden values vary significantly within these respondent categories. Accordingly, it is not possible to define a " typical" respondent.

However, to develop appropriate burden estimates, for the 2002 ICR EPA tried to determine typical values using information from interviews with EPA staff, data from the PCS database, the NOI Processing Center, the previous DMR ICR, and two prior NPDES Streamlining Rules. Values and assumptions from the previous DMR information collection requests were used, to the best extent that they were considered reasonable estimates or their unequivocal verification would result in excessive expense with no corresponding increase in the accuracy of burden and cost estimates. Except as specified, these values are used for the current estimates.

Exhibit 6.1a shows the number of respondents required to complete DMRs and the number of annual responses ( i. e., number of DMRs submitted). Exhibit 6.1b shows the number of sludge facilities and the number of times sludge management facilities monitor per year. 6 Estimates of the number of major and minor NPDES permittees, sludge facilities, and the frequency at which they are required to submit DMRs are based on current data from EPA's NPDES permit database, Permit Compliance System ( PCS), DMR Information Collection Request April 29, 2005 7 Because MS4s and the general permits for Oil and Gas, Seafood Processing, and Aquaculture have a more involved process of sampling and analysis, a more detailed estimate of these burdens was presented in Appendix B of EPA ICR# 0229.15. For this updated ICR, burden assumptions considered for the 2002 ICR are believed to still be valid.

21 and on the previous ICR. Estimates of the number of non storm water general permittees covered under the EPA issued non storm water general permits are based on EPA's PCS and ePIFT ( see Appendix B).

6. a. 1 Estimating Respondent Burden   Sampling NPDES permittees and sludge facilities have to spend time collecting wastewater and/ or sludge samples. These respondents can collect samples either automatically or manually. The samples can be either grab, or composite ( which involves collecting individual samples and combining them into one sample representative of a daily discharge). Burdens for collecting samples vary depending on the types of samples taken. For example, economies of scale are realized when a single sample can be used for many parameters. The time to collect a sample may vary from a few minutes ( in the case of automatic sampling for some parameters) to three hours for manually collected composite samples. Sample collection burdens also will vary depending on the number of outfalls that must be sampled and the distance between sampling locations. Sampling burden is calculated as follows:

Sampling Burden ( hours) = Avg. Number of Samples x Avg. Hours to Collect a Sample The assumptions ( i. e., number of samples, hours to collect a sample) used to calculate the sampling burden are based on the previous DMR ICR. Exhibit 6.2a and 6.2b present the individual and aggregate sampling burden associated with NPDES permittees and sludge facilities, respectively.

6. a. 2 Estimating Respondent Burden   Analysis Once the facility has collected wastewater or sludge samples, they are analyzed. The assumptions ( i. e., number of parameters analyzed, hours to conduct analysis) used to calculate the analysis burden are based on the previous DMR ICR. The analysis burden ( in hours) is calculated as follows:

Analysis Burden ( Hours) = Avg. No. of Parameters Analyzed × Avg. No. of Samples × Hours per Parameter Exhibits 6.3a and 6.3b present estimates of the time respondents spend conducting pollutant analysis. 7 6. a. 3 Estimating Respondent Burden   Reporting/ Record keeping Reporting of monitoring data involves compilation of data from various pollutant analysis, and calculation of average pollutant concentrations and/ or loadings. The respondent records this information on DMRs. When pre printed DMRs are used, the respondent spends time for reporting only the analytical results ( the general DMR information is already pre printed). Exhibit 6.4a shows the reporting burden for NPDES permittees. EPA estimates the reporting burden per DMR to be two hours.

Sewage sludge facilities that are required to submit monitoring data are also required to maintain records of that information. EPA assumes that the time devoted to record keeping at these facilities generally involves copying and filing DMRs. EPA estimates this burden to be 10 minutes per DMR submitted. EPA estimates the time required to report this information to be two hours ( the same as NPDES DMR Information Collection Request April 29, 2005 22 permittees). Exhibit 6.4b shows the reporting and record keeping burden for biosolids facilities that are required to report and keep records of DMR data.

Some sewage sludge facilities are required to monitor, but are only required to maintain records of their monitoring data ( i. e., monitoring data does not have to be reported). The annual record keeping burden per facility is assumed to be 1.5 hours. Exhibit 6.4c presents the record keeping burden for facilities required to maintain monitoring data.

6. b Estimating Respondent Cost The total cost for each respondent activity is comprised of:

° Labor Cost ° Capital/ Start up Cost ° Operating and Maintenance ( O& M) Costs.

6. b. 1 Estimating Labor Costs ( 2004 Dollars)

When estimating the labor costs to respondents and the Agency, the following labor rates were used:

° Labor rates for the Federal employees are based on the estimated hourly rates of $ 45.97 for technical personnel ( GS 12, Step 5). These values represent the inclusion of a 1.6 multiplier to account for overhead and fringe benefit costs. ( EPA ICR Handbook).

° Labor rates for State and municipal employees ( including MS4s) are based on the estimated total compensation cost ( including benefits) of $ 34.72 per hour ($ 72,218 annually) presented by the Department of Labor for September 2004.

° Labor rates for MS4s were assumed to be $ 42.51 per hour ( wage and overhead). This labor rate from the May 2003 National Industry Specific Occupational Employment and Wage Estimates for NAICS 541330  Engineering Services. The mean hourly wage for Architecture and Engineering Occupations ( SOC Code 17 0000), including 50 percent for overhead and fringe benefits and adjusted to September 2004 dollars with the Employment Cost Index 6. b. 2 Estimating Capital and Operating and Maintenance Costs Capital Costs There are no capital costs associated with this ICR because all monitoring and record keeping are performed using equipment that NPDES facilities already have as a routine part of running their facility or the facilities send their samples to outside sources.

Operating and Maintenance Costs There are no operation and maintenance costs associated with this ICR because all monitoring and record keeping are performed using equipment that NPDES facilities already have as a routine part of running their facility or the facilities send their samples to outside sources. DMR Information Collection Request April 29, 2005 23 6. c Estimating Agency Burden and Cost The costs to Federal and State governments for processing and analyzing monitoring data are a function of three factors: ( 1) the number of DMRs received by the permitting authority, ( 2) the time it takes to process and analyze monitoring data ( including entry into the PCS database), and ( 3) the salary and associated overhead costs of the Federal and State employees who process DMRs. In addition to entering monitoring data into PCS, staff may need to conduct follow up actions in instances of noncompliance This follow up could be a phone conversation or a letter to verify, clarify or substantiate the information reported. For those facilities only required to maintain records, there is no corresponding Federal or State burden.

EPA estimates that it takes about an average of 10 minutes ( 0.17 hrs) to review and enter the data into PCS. EPA also estimates that 20 percent of the DMRs submitted will require some form of follow up action because of non compliance. EPA estimates that this follow up action requires an average of 30 minutes per DMR. The estimates of Agency and State burden and costs are presented in Exhibit 6.5a and 6.5b, respectively.

6. d Estimating Respondent Universe and Total Burden The respondent universe for NPDES facilities was updated from the previous ICR by using EPA's PCS database, the existing ICR, and consultations with EPA staff and contractors. Exhibit 6.1a and Exhibit 6.1b present the universe of NPDES and sludge facilities. Total burden for each category of respondents are summarized in Exhibit 6.6a.

6. e Bottom Line Burden Hours and Costs The bottom line burden hours and cost tables for respondents are the summaries of all the hours and costs incurred for all activities.

( i) Respondent Tally The bottom line respondent tally is presented in Exhibit 6.6b.

( ii) The Agency Tally The bottom line Agency tally is presented in Exhibit 6.6b.

6. e. 1 Variations in the Annual Bottom Line The burden and cost estimates are not expected to vary from year to year over the collection period for this ICR. That is, the bottom line tallies presented in Exhibit 6.6b are not expected to change over the course of the next 3 years.

6. f Reasons for Change in Burden The DMR ICR approved by OMB in 2002 contains line by line estimates of burden hours similar to the estimates presented in this document. Activities contemplated in this ICR have not changed. Exhibit 6.6c presents a comparison of burden estimates between the 2002 and the 2005 ICR.

Major Dichargers DMR Information Collection Request April 29, 2005 24 The 2005 DMR ICR estimates that the hourly burden for major municipal dischargers will increase from the 2002 estimate of 3,884,238 hours to 3,975,932 hours ( an increase of 2.4%). The burden hours for non municipal individual permittees will decrease from 2,899,050 to 2,773,155 ( an decrease of 4.3%). This changes are attributable to the change in the number of major municipal and non municipal dischargers.

Minor Dischargers The burden hours for minor individual permittees will decrease from 5,118,746 to 4,770,869 ( a decrease of 6.8%). This decrease is attributable to the decrease in the number of permitted minor dischargers required to monitor.

Discharges Under Non Stormwater General Permits The burden hours for permittees discharging under non stormwater general permits increased from 635,202 hours to 635,201 ( a 0% increase). This increase in burden is primarily the result of the increase in the number of non stormwater general permitted facilities.

Storm Water Industrial Multisector General Permits The burden hours for storm water industrial general permittees is expected to remain constant at 129,993.

Municipal Separate Storm Sewer Systems ( MS4s)

The burden hours for MS4s is expected to remain constant at 491,392.

Sludge Facilities ( Sludge Only and Part 503)

The burden hours for sludge only facilities is expected to remain constant at 43,056 hours. Similarly, for treatment works treating sludge, the burden hours also are expected to remain constant at 0.

Domestic Septage Haulers The burden hours for domestic septage haulers is expected to remain constant at increase from 14,221,957 6. g Burden Statement EPA estimates that 74,917 NPDES permittees and 24,346 sludge permittees ( of which 17,311 facilities are included in both the NPDES and sludge permittees) will perform sample collection, pollutant analysis, reporting and record keeping as part of their NPDES permit requirements to collect and report discharge monitoring data to permit authorities. These permittees are expected to provide 583,987 responses to State and Federal permit authorities. Nationally, permittees will spend 3,934,507 hours per year collecting samples of their wastewater or sludge. An additional 8,888,433 hours will be spent by permittees for analyzing the samples collected. Permittees will spend 1,174,626 hours for reporting the sampling and analysis information on DMRs. Each permittee will spend an average of 24.0 hours per year to collect, analyze and report discharge monitoring data. EPA also estimates that sludge facilities will spend 19,226 hours keeping records of monitoring records ( the record keeping burden for the remaining NPDES permittees is reported in the Compliance Assessment ICR, OMB Control Number 2040 0110). In DMR Information Collection Request April 29, 2005 25 addition to the permittees, the total number of respondents includes the 45 States and 1 Territory that are responsible for NPDES program implementation. The total State and Territory burden averages 147,791 hours per year.

Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID No. OW 2004 0031, which is available for public viewing at the Water ( OW) Docket in the EPA Docket Center ( EPA/ DC), EPA West, Room B102, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8: 30 a. m. to 4: 30 p. m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is ( 202) 566 1744, and the telephone number for the Water Docket is ( 202) 566 2426. An electronic version of the public docket is available through EPA Dockets ( EDOCKET) at http:// www. epa. gov/ edocket. Use EDOCKET to submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronically. Once in the system, select " search," then key in the docket ID number identified above. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Office for EPA. Please include the EPA Docket ID No. ( OW 2004 0031) and OMB control number ( 2040 0004) in any correspondence. DMR Information Collection Request April 29, 2005 26 EXHIBITS DMR Information Collection Request April 29, 2005 27 EXHIBIT 6.1a Number of Respondents and Responses ( NPDES Permittees)

[ A] [ B] [ C] [ A]*[ B]*[ C]

Facility/ Permit Type No of Respondents No. of Outfalls Per Facility Annual DMR Submissions No. of Responses Major Dischargers Municipal 4,206 1 12 50,472 Non municipal 2,401 3.5 12 100,842 Subtotal ( Majors) 6,607 151,314 Minor Dischargers Monthly 21,514 1 12 258,168 Bimonthly 10 3 6 180 Quarterly 3,543 2 4 28,344 Semi Annually 326 1.4 2 913 Annually 1,873 2 1 3,746 Subtotal ( Minors) ( 1) 27,266 291,351 General Permits  Non Storm Water ( 2) 15,286 88,990 Storm Water Permittees ( Industrial) ( 3) ( Year 2 Only Quarterly) 12,744 1 0.2 2,549 ( Year 2 and Year 4 Quarterly) 12,744 1 0.4 5,098 Subtotal ( General Permits  SW) 25,488 7,646 MS4s ( See Appendix B) 270 1 5,400 Total 74,917 544,701 ( 1) Based on data from EPA's PCS database, an additional 17,430 minor facilities exist that are not required to submit DMRs. ( 2) Based on data from EPA's PCS database, an additional 38,066 general permittees exist that are not required to submit DMRs. ( 3) Presently, EPA estimates 120,000 facilities are permitted under a storm water industrial permit ( EPA Permit Issuance Statistics website). Based on data from the Final Phase II Storm Water Rule Economic Analysis, it is expected that approximately 11.5 percent of those facilities will claim " No Exposure" and be exempt from permit requirements. Of the remaining facilities, EPA estimates that approximately 24 percent of the facilities are required to monitor in Year 2. It is assumed that 50% of facilities that monitored in Year 2 will be required to monitor in Year 4 also. DMR Information Collection Request April 29, 2005 28 EXHIBIT 6.1b Number of Respondents and Responses ( Biosolids Facilities)

[ A] [ B] [ C] [ B]*[ C]

Facility/ Permit Type No. of Facilities Total No. of Monitoring Episodes Percent Reporting No. of Responses*

Sludge Only Facilities Class I Sludge Management Facilities 635 2,411 100% 2,411 Non Class I Sludge Management Facilities 1,616 2,076 10% 208 Sludge ( 40 CFR Part 503)/ NPDES Permittees POTWs Class I Sludge Management Facilities 4,908 25,506 100% 25,506 Non Class I Sludge Management Facilities 12,403 12,898 ** 11,161 Domestic Septage Haulers 4,784 4,784 0% 0 Total 24,346 47,675 39,286 * Number of DMR Submissions. ** Of the 12,403 Non Class I Sludge management facilities, 90 percent of POTWs and 50 percent of PrOTWs are required to both report and record keep. This results in 11,161 responses [ 0.9 times ( 11,781 mon. episodes)] + [ 0.5 times ( 1,117 mon. episodes)]. DMR Information Collection Request April 29, 2005 29 EXHIBIT 6.2a Annual Sampling Labor Burden and Costs ( NPDES Permittees)

[ A] [ B] [ C] [ A]*[ B]*[ C]

Facility/ Permit Type No. of Responses No. of Samples Per Response Hours Per Sample Annual Sampling Burden Major Dischargers Municipal 50,472 8.3 2.25 942,565 Non municipal 100,842 2.0 2.75 554,631 Subtotal ( Majors) 151,314 1,497,196 Minor Dischargers Monthly 258,168 2.3 2.0 1,187,573 Bimonthly 180 2.3 2.0 828 Quarterly 28,344 2.3 2.0 130,382 Semi Annually 913 2.3 2.0 4,199 Annually 3,746 2.3 2.0 17,232 Subtotal ( Minors) 291,351 1,340,214 Non Storm Water General Permits ( 1) 88,990 492,588 Storm Water Permittees ( Industrial) ( 2) ( Year 2 Only Quarterly) 2,549 4 2.25 22,939 ( Year 2 and Year 4 Quarterly) 5,098 4 2.25 45,878 Subtotal ( General Permits  SW) 7,646 68,817 MS4s ( See Appendix B) 5,400 395,059 Total 544,701 3,793,874 ( 1) See Appendix B, Tables B 2 through B 9 for breakdown of hours. ( 2) Under the Storm Water Multi Sector General Permit, monitoring is required quarterly in Year 2 and based on the results, monitoring may also be required in Year 4. It is assumed that 50% of facilities that monitored in Year 2 will be required to monitor in Year 4 also. DMR Information Collection Request April 29, 2005 30 EXHIBIT 6.2b Annual Sampling Labor Burden ( Biosolids Facilities)

[ A] [ B] [ A]*[ B]

Facility/ Permit Type No. of Monitoring Episodes* Hours Per Sample Annual Sampling Burden Sludge Only Facilities Class I Sludge Management Facilities 2,411 3.0 7,233 Non Class I Sludge Management Facilities 2,076 3.0 6,228 Sludge ( 40 CFR Part 503)/ NPDES Permittees POTWs Class I Sludge Management Facilities 25,506 3.0 76,518 Non Class I Sludge Management Facilities 12,898 3.0 38,694 Domestic Septage Haulers 4,784 2.5 11,960 Total 47,675 140,633 * One sample is collected per monitoring episode. DMR Information Collection Request April 29, 2005 31 EXHIBIT 6.3a Annual Analysis Labor Burden ( For NPDES Facilities)

[ A] [ B] [ C] [ D] [ A]*[ B]*[ C]*[ D]

Facility/ Permit Type No. of Responses No. of Parameters Per Sample No. of Samples Per Response Hours Per Parameter Annual Analysis Burden Major Dischargers Municipal 50,472 14 8.3 0.5 2,932,423 Non municipal 100,842 20 2.0 0.5 2,016,840 Subtotal ( Majors) 151,314 4,949,263 Minor Dischargers Monthly 258,168 8.5 2.3 0.5 2,523,592 Bimonthly 180 8.5 2.3 0.5 1,759 Quarterly 28,344 8.5 2.3 0.5 277,063 Semi Annually 913 8.5 2.3 0.5 8,923 Annually 3,746 8.5 2.3 0.5 36,617 Subtotal ( Minors) 291,351 2,847,954 Non Storm Water General Permits 88,990 472,251 Storm Water Permittees ( Industrial)( 1) ( Year 2 Only Quarterly) 2,549 3 4 0.5 15,294 ( Year 2 and Year 4 Quarterly) 5,098 3 4 0.5 30,588 Subtotal ( General Permits  SW) 7,647 45,882 MS4s ( See Appendix B) 5,400 223,040 Total 544,702 8,538,390 ( 1) Under the Storm Water Multi Sector General Permit, monitoring is required quarterly in Year 2 and based on the results, monitoring may also be required in Year 4. It is assumed that 50% of facilities that monitored in Year 2 will be required to monitor in Year 4 also. DMR Information Collection Request April 29, 2005 32 EXHIBIT 6.3b Annual Analysis Labor Burden ( for Biosolids Facilities)

[ A] [ B] [ C] [ A]*[ B]*[ C]

Facility/ Permit Type No. of Monitoring Episodes* No. of Parameters Per Sample Hours Per Parameter Annual Analysis Burden Sludge Only Facilities Class I Sludge Management Facilities 2,411 18 0.5 21,699 Non Class I Sludge Management Facilities 2,076 10 0.5 10,380 Sludge ( 40 CFR Part 503)/ NPDES Permittees POTWs Class I Sludge Management Facilities 25,506 18 0.5 229,554 Non Class I Sludge Management Facilities 12,898 10 0.5 64,490 Domestic Septage Haulers 4,784 10 0.5 23,920 Total 47,675 350,043 * One sample per episode. DMR Information Collection Request April 29, 2005 33 EXHIBIT 6.4a Annual Burden for Reporting and Record keeping* of DMRs ( NPDES Facilities)

[ A] [ B] [ C] [ B]*[ C]

Facility/ Permit Type No. of Respondents No. of Responses Burden Per Response Annual Reporting Burden Major Dischargers Municipal 4,206 50,472 2 100,944 Non municipal 2,401 100,842 2 201,684 Subtotal ( Majors) 6,607 151,314 302,628 Minor Dischargers Monthly 21,514 258,168 2 516,336 Bimonthly 10 180 2 360 Quarterly 3,543 28,344 2 56,688 Semi Annually 326 913 2 1,826 Annually 1,873 3,746 2 7,492 Subtotal ( Minors) 27,266 291,351 582,702 Non Storm Water General Permit 15,286 88,990 178,330 Storm Water Permittees ( Industrial) ( 1) ( Year 2 Only Quarterly) 12,744 2,549 2 5,098 ( Year 2 and Year 4 Quarterly) 12,744 5,098 2 10,195 Subtotal ( General Permits  SW) 25,488 7,646 15,293 MS4s ( See Appendix B) 270 5,400 17,102 Total 74,917 544,701 1,096,054 ( 1) Under the Storm Water Multi Sector General Permit, monitoring is required quarterly in Year 2 and based on the results, monitoring may also be required in Year 4. It is assumed that 50% of facilities that monitored in Year 2 will be required to monitor in Year 4 also.

* Record keeping burden is addressed in the Compliance Assessment ICR. DMR Information Collection Request April 29, 2005 34 EXHIBIT 6.4b Annual Burden for Reporting and Record keeping of DMRs ( Biosolids Facilities Required to Report and Record keep)

[ A] [ B] [ C] [ D] [ A]*[ B]*[ C] [ A]*[ B]*[ D]

Facility/ Permit Type No. of Monitoring Episodes % Required to Report and Recordkeep Reporting Burden Per Report Recordkeeping Burden Per Report Annual Reporting Burden Annual Recordkeeping Burden Sludge Only Facilities Class I Sludge Management Facilities 2,411 100% 2 0.17 4,822 410 Non Class I Sludge Management Facilities 2,076 10% 2 0.17 415 35 Sludge ( 40 CFR Part 503)/ NPDES Permittees POTWs Class I Sludge Management Facilities 25,506 100% 2 0.17 51,012 4,336 Non Class I Sludge Management Facilities 12,898 * 2 0.17 22,322 1,860 Domestic Septage Haulers 4,784 0% 2 0.17 0 0 Total 47,675 78,571 6,641 * Of the 12,403 Non Class I Sludge Management facilities, 90 percent of POTWs and 50 percent of PrOTWs are required to both report and record keep. This results in 11,161 responses [ 0.9 times ( 11,781 mon. episodes)] + [ 0.5 times ( 1,117 mon. episodes)]. DMR Information Collection Request April 29, 2005 35 EXHIBIT 6.4c Annual DMR Record keeping Burden ( Sludge Facilities Required to Record keep Only)

[ A] [ B] [ C] [ A]*[ B]*[ C]

Facility/ Permit Type No. of Monitoring Episodes % Required to Recordkeep Only Record keeping Burden Per Report Annual Recordkeeping Burden Sludge Only Facilities Class I Sludge Management Facilities 2,411 0% NA 0 Non Class I Sludge Management Facilities 2,076 90% 1.5 2,803 Sludge ( 40 CFR Part 503)/ NPDES Permittees POTWs Class I Sludge Management Facilities 25,506 0% NA 0 Non Class I Sludge Management Facilities 12,898 * 1.5 2,606 Domestic Septage Haulers 4,784 100% 1.5 7,176 Total 47,675 12,585 * Of the 12,403 Non Class I Sludge Management facilities, 90 percent of POTWs and 50 percent of PrOTWs are required to both report and record keep. This results in 11,161 responses [ 0.9 times ( 11,781 mon. episodes)] + [ 0.5 times ( 1,117 mon. episodes)]. Thus only 10 percent of POTWs and 50 percent of PrOTWs are required to record keep only. This results in 1,737 [ 0.1 times ( 11,781 mon. episodes)] + [ 0.5 times ( 1,117 mon. episodes)]. DMR Information Collection Request April 29, 2005 36 EXHIBIT 6.5a Total Agency Burden and Cost [ A] [ B] [ C] [ D] = [ A* B]+[ 0.2* A* C] [ E] [ D]*[ E]

Facility/ Permit Type Annual DMR Submissions Total Processing Time Additional Follow up Time Total Agency Burden ( 1) Hourly Labor Rate Total Agency Processing Cost Major Discharger Municipal 3,036 0.17 0.5 820 $ 45.97 $ 37,683 Non Municipal 6,300 0.17 0.5 1,701 $ 45.97 $ 78,195 Minor Dischargers 6,696 0.17 0.5 1,808 $ 45.97 $ 83,110 EPA Non Storm Water General Permits 14,333 0.17 0.5 3,870 $ 40.34 $ 156,112 Storm Water Industrial General Permits 618 0.17 0.5 167 $ 45.97 $ 7,671 Mun. Separate Storm Sewer Systems ( MS4s) 162 0.17 0.5 44 $ 45.97 $ 2,011 Sludge Only Facilities 389 0.17 0.5 105 $ 45.97 $ 4,828 Sludge Facilities ( Under Part 503) 5,079 0.17 0.5 1,371 $ 45.97 $ 63,040 Domestic Septage Haulers 0 0.17 0.5 0 $ 45.97 $ 0 Totals 36,613 9,886 $ 432,649 ( 1) Twenty percent of DMR submissions require additional follow up time of 30 minutes in addition to the standard processing time of 10 minutes. DMR Information Collection Request April 29, 2005 37 EXHIBIT 6.5b Total State Burden and Costs [ A] [ B] [ C] [ D] = [ A* B]+[ 0.2* A* C] [ E] [ D]*[ E]

Facility/ Permit Type Annual DMR Submissions Total Processing Time Additional Follow up Time Total State Burden Hourly Labor Rate Total State Processing Cost Major Discharger Municipal 47,436 0.17 0.5 12,808 $ 34.72 $ 444,684 Non Municipal 94,542 0.17 0.5 25,526 $ 34.72 $ 886,275 Minor Dischargers 284,655 0.17 0.5 76,857 $ 34.72 $ 2,668,470 State Non Storm Water General Permits 74,657 0.17 0.5 20,157 $ 34.72 $ 699,865 Storm Water Industrial General Permits 7,029 0.17 0.5 1,898 $ 34.72 $ 65,893 Municipal Separate Storm Sewer Systems ( MS4s) 5,238 0.17 0.5 1,414 $ 34.72 $ 49,103 Sludge Only Facilities 2,230 0.17 0.5 602 $ 34.72 $ 20,905 Sludge Facilities ( Under Part 503) 31,588 0.17 0.5 8,529 $ 34.72 $ 296,119 Domestic Septage Haulers 0 0 0 0 $ 34.72 $ 0 Totals 547,375 147,791 $ 5,131,312 ( 1) Twenty percent of DMR submissions require additional follow up time of 30 minutes in addition to the standard processing time of 10 minutes. DMR Information Collection Request April 29, 2005 38 EXHIBIT 6.6a Total Respondent Burden ( excluding State burden)

Facility/ Permit Type Annual Burden Major Discharger Municipal 3,975,932 Non Municipal 2,773,155 Minor Dischargers 4,770,869 Non Storm Water General Permits 1,143,169 Storm Water Industrial General Permits 129,992 Municipal Separate Storm Sewer Systems ( MS4s) 635,201 Sludge Only Facilities 54,025 Sludge Facilities ( Under Part 503) 491,392 Domestic Septage Haulers 43,056 Totals 14,016,791 DMR Information Collection Request April 29, 2005 39 EXHIBIT 6.6b Summary ( bottom line) Respondent Burden and Costs ( including State)

Category Costs ($)

Capital $ 0 O& M Costs $ 0 State $ 5,131,312 Federal $ 432,649 Annual Bottomline Burden Hours Annual Sampling Burden 3,934,507 Annual Analysis Burden 8,888,433 Annual Reporting Burden 1,174,626 Annual Record keeping Burden* 19,226 Total Respondent Burden 14,016,791 Total Number of Responses Annual ( Number of DMRs submitted) 583,987 Average Number of Hours/ Responses ( To collect, analyze, and report only) 24.0 Annual State Burden ( To process DMRs) 147,791 * Includes only sludge facilities. Record keeping burden for NPDES permittees is contained in the Compliance Assessment ICR. DMR Information Collection Request April 29, 2005 EXHIBIT 6.6c Change in Burden Facility/ Permit Type 2002 ICR ( hours) 2005 ICR ( Hours) % Difference ( 2002/ 2005) Reason for Changes Major Discharger Municipal 3,884,238 3,975,932 2.4% Adjustment Non Municipal 2,899,050 2,773,155  4.3% Adjustment Minor Dischargers 5,118,746 4,770,869  6.8% Adjustment Combined Sewer Overflows see Combined Sewer Overflow under Section 4. a.

Non Storm Water General Permits 966,255 1,143,169 18.3% Adjustment Storm Water Industrial General Permits 129,993 129,992 0.0% NA Municipal Separate Storm Sewer Systems ( MS4s) 635,202 635,201 0.0% NA Sludge Only Facilities 54,025 54,025 0.0% NA Sludge Facilities ( Under Part 503) 491,392 491,392 0.0% NA Domestic Septage Haulers 43056 43,056 0.0% NA Totals 14,221,957 14,016,791  1.4% DMR Information Collection Request April 29, 2005 41 APPENDIX A INPUT VALUES AND ASSUMPTIONS DMR Information Collection Request April 29, 2005 A 1 Source for Input Values By Discharger Category Category: Major Dischargers Item Source/ Assumption Number of dischargers Updated 2005 from EPA's Permit Compliance System ( PCS) Database.

Number of outfalls per facility 2002 DMR ICR ( EPA No. 0229.15).

Annual DMR submissions. 2002 DMR ICR.

Number of samples per response 2002 DMR ICR.

Number of hours to collect a sample. 2002 DMR ICR.

Number of parameters per sample 2002 DMR ICR.

Hours to analyze a sample 2002 DMR ICR.

Average time it takes to prepare and report a DMR ( excluding sampling and analysis time) 2002 DMR ICR.

Average time it takes to keep records of a DMR. Record keeping burden is already captured in the Compliance Assessment ICR. Not included here. DMR Information Collection Request April 29, 2005 A 2 Source for Input Values By Discharger Category Category: Minor Dischargers Item Source/ Assumption Number of dischargers Updated 2005 from EPA's Permit Compliance System ( PCS) Database.

Number of outfalls per facility 2002 DMR ICR.

Annual DMR submissions. 2002 DMR ICR.

Number of samples per response 2002 DMR ICR.

Number of hours to collect a sample. 2002 DMR ICR.

Number of parameters per sample 2002 DMR ICR.

Hours to analyze a sample 2002 DMR ICR.

Average time it takes to prepare and report a DMR ( excluding sampling and analysis time) 2002 DMR ICR.

Average time it takes to keep records of a DMR. Record keeping burden is already captured in the Compliance Assessment ICR. Not included here. DMR Information Collection Request April 29, 2005 A 3 Source for Input Values By Discharger Category Category: Non Storm Water General Permittees*

Item Source/ Assumption Number of dischargers Number of facilities covered under State issued and EPA issued nonstorm water general permits from 2005 PCS database and additional facilities in Gulf of Mexico.

Number of outfalls per facility 2002 DMR ICR Annual DMR submissions. 2002 DMR ICR Number of samples per response 2002 DMR ICR Number of hours to collect a sample. 2002 DMR ICR Number of parameters per sample 2002 DMR ICR Hours to analyze a sample 2002 DMR ICR Hours to conduct other monitoring requirements  seafloor survey, bark monitoring plan, site inspections, oil sheen or debris observations, toxicity testing, etc. 2002 DMR ICR Average time it takes to prepare and report a DMR ( excluding sampling and analysis time) 2002 DMR ICR Average time it takes to keep records of a DMR. Record keeping burden is already captured in the Compliance Assessment ICR. Not included here. * See Appendix B for explanation of methodology used to update information DMR Information Collection Request April 29, 2005 A 4 Source for Input Values By Discharger Category Category: Storm Water Industrial General Permittees Item Source/ Assumption Number of dischargers 2002 DMR ICR. NOI processing center figures and state estimates ( for permittees in only those categories/ subcategories that will be required to monitor pollutants) for 46 States extrapolated to all 50 states. Assumed 50 percent of industrial facilities would require 4th year permit monitoring.

Number of outfalls per facility 2002 DMR ICR. Permittees can sample one representative outfall for their facility.

Annual DMR submissions. 2002 DMR ICR. Under the multi sector storm water general permit, permittees are required to monitor four times in the 2nd year of their permit and, if pollutant concentrations exceed a benchmark level, they may also be required to monitor an additional four times in the 4th year. Quarterly data is to be compiled and submitted as part of an annual report. Thus, a range of one to two reports need to be completed in a 5 year permit cycle ( 0.2 DMRs per year) for facilities required to monitor.

Number of samples per response 2002 ICR estimated the number of samples based on the multi sector permit's requirements. On average, about 3 parameters will have to be analyzed by specific industrial categories covered by the multi sector permit. The three pollutants are expected to be in three pollutant categories ( 1 conventional; 1 nutrient; 1 toxic metal).

Number of hours to collect a sample. 2002 DMR ICR.

Number of parameters per sample See number of samples per response above.

Hours to analyze a sample 2002 DMR ICR.

Average time it takes to prepare and report a DMR ( excluding sampling and analysis time) 2002 DMR ICR.

Average time it takes to keep records of a DMR. Record keeping burden is already captured in the Compliance Assessment ICR. Not included here. DMR Information Collection Request April 29, 2005 A 5 Source for Input Values By Discharger Category Category: MS4s Item Source/ Assumption See Appendix B DMR Information Collection Request April 29, 2005 A 6 Source for Input Values By Discharger Category Category: Sludge Facilities Item Source/ Assumption Number of dischargers 2002 DMR ICR. Based on consultations with professionals involved in EPA's sludge program, numbers are not expected to have changed from 1995 DMR ICR estimates. Reported categories in current DMR ICR aggregated into two major categories ( sludge only and NPDES permittees) with two sub categories ( Class I and non Class I sludge facilities).

Number of outfalls per facility Not Applicable.

Annual DMR submissions. 2002 DMR ICR.

Number of samples per response 2002 DMR ICR.

Number of hours to collect a sample. 2002 DMR ICR.

Number of parameters per sample 2002 DMR ICR.

Hours to analyze a sample 2002 DMR ICR.

Average time it takes to prepare and report a DMR ( excluding sampling and analysis time) 2002 DMR ICR.

Average time it takes to keep records of a DMR. 2002 DMR ICR. DMR Information Collection Request April 29, 2005 APPENDIX B MS4 BURDEN AND GENERAL PERMITS BURDEN DMR Information Collection Request April 29, 2005 B 1 Estimating Respondent Burden   MS4s MS4s bear a different set of burdens and costs from other respondents. The sampling process for MS4s is more involved and may consist of the mobilization of the sampling crew, the collection of samples, and the transportation of samples from the site to the laboratory for analysis. These steps may be performed by several different crews. Another MS4 burden is that of unsuccessful sampling attempts. If storm event characteristics ( e. g., duration, rainfall accumulation, and inter event period) do not meet the criteria established in the permit, the expanded effort to collect and analyze samples essentially is wasted. Stop start storm events, therefore, significantly increase the number of storm events attempted for sampling. The 1995 ICR reported that the analysis of 23 municipalities' sampling programs indicated that 50 percent of the municipalities had to sample more than 10 events to meet the minimum three storm event requirement.

MS4s are also required to maintain controls over discharges to their system. It is likely, therefore, that some MS4s will conduct special monitoring of certain facilities, including landfills and Superfund Amendments and Reauthorization Act ( SARA) Section 313 facilities. In addition, MS4s conduct field screening of their systems during the permit term. This requirement includes sending out field crews to conduct on site testing of dry weather flows to detect possible illicit connections and illegal dumping. This also includes conducting follow up investigations to ensure that illicit connections have been eliminated. MS4s also bear the burden of submitting estimates of seasonal pollutant loadings for each outfall. In most instances, these estimates will be provided during the permit term and will be based on site specific monitoring results. Since the monitoring is likely to be collected for typically five to 10 outfalls, loading estimates will have to be extrapolated to all major outfalls, of which there may be hundreds, or even thousands. Finally, each MS4 will be required to submit annual reports for its entire program. The reports will include results of all sampling for the year.

Each of these requirements is part of the total burden on MS4s, and each burden incurs a cost. The burdens and costs for MS4s are summarized in Table B 1 below. DMR Information Collection Request April 29, 2005 B 2 Table B 1 Estimate of Annual Burden and Costs for MS4s Line Item No. of MS4 Permittees* %

Conducting No. Conducting Cost Per Event** No. of Events*** Annual Costs Burden Activity Code Sample Analysis 270 100% 270 $ 1,402 20 $ 7,570,800 178,147 A Mobilize/ Collect/ Transport 270 100% 270 $ 1,010 20 $ 5,454,000 128,266 S Adjustment for Start/ Stop Events 270 100% 270 $ 1,010 20 $ 5,454,000 128,266 S Special Monitoring Lab Analysis 270 20% 54 $ 1,402 6 $ 454,248 10,689 A Mobilize/ Collect/ Transport 270 20% 54 $ 1,010 6 $ 327,240 7,696 S Start Stop Events 270 20% 54 $ 1,010 2 $ 109,080 2,565 S Field Screening Program ( 100 outfalls/ yr, 1 hr/ outfall) 270 100% 270 $ 13 100 $ 351,000 8,551 S Illicit Connection Investigation ( 20 investigations/ yr, 5 hrs/ outfall) 270 100% 270 $ 673 20 $ 3,634,200 85,511 S Illicit Connection Follow up ( 20 follow ups/ yr, 2 hrs/ outfall) 270 100% 270 $ 269 20 $ 1,452,600 34,204 S Seasonal Pollutant Loading Estimate ( 20 hrs/ event) 270 100% 270 $ 1,346 4 $ 1,453,680 34,204 A Annual Report Preparation ( DMR only) 270 100% 270 $ 2,693 1 $ 727,110 17,102 R TOTALS $ 26,987,958 635,202 Category Summary Analysis Burden ( hours) 223,040 Sampling Burden ( hours) 395,059 Reporting Burden ( hours) 17,102 Number of Responses 5,400 * There are approximately 1,000 MS4s covered by 270 NPDES permits. The requirements above are permit specific. MS4 labor rate is $ 42.51.

** Costs per event updated from the 2002 ICR using the increase factor for MS4 labor rate ($ 42.51/$ 37.89)

*** MS4 permittees have to sample a minimum of 5 outfalls representative of their systems quarterly.

A = Analysis S = Sampling R = Reporting Estimating Respondent Burden  Non Storm Water DMR Information Collection Request April 29, 2005 8 The electronic Permit Issuance Forecasting Tool ( ePIFT) is a recently developed database used by EPA's Office of Wastewater Management's Water Permits Division to collect information about individual and general permits. Non stormwater general permits data are used in EPA's monthly and quarterly backlog status reports.

9 For example, the 2002 ICR EPA considered general permits for oil and gas facilities, seafood processing facilities, aquaculture facilities, concentrated animal feeding operations, log transfer, suction dredging, placer mining, petroleum bulk stations and terminals, underground storage tank system cleanups, concrete facilities, beneficial reuse or disposal of municipal sewage sludge, noncontact cooling water discharges, and water treatment facilities.

B 3 EPA's estimate of burden associated with non storm water general permits is based on respondent data contained in PCS and ePIFT, 8 and information collection burden data ( for State issued permits) and non reporting permits ( for State and EPA issued permits) obtained from PCS. In addition, for EPA issued permits, burden factors were calculated based on the federally issued non stormwater general permits characterized in the previous ( 2002) ICR. These burden factors are based on Appendix B of the 2002 ICR ( EPA ICR No. 0229.15), which presented a detailed analysis based on actual permits estimating the number of respondents, responses, and burden for EPA issued non stormwater general permits. For this 2005 ICR, those numbers were used to develop burden factors for the sampling, analysis, recordkeeping, reporting and other burden associated with EPA issued, nonstormwater general permits addressed in this ICR. These burden factors were then used in conjunction with current ePIFT and PCS respondent data to estimate the burden for EPA issued, non stormwater general permits. For this ICR, it was assumed that neither the distribution of the EPA issued non stormwater general permits to the different industrial categories nor the level of effort for the required activities has changed relative to the 2002 ICR. EPA believes that the data used in the 2002 ICR is reasonably representative of the burdens imposed under EPA issued non stormwater general permits because the permits characterized in the 2002 ICR address a range of typical activities conducted in various regions and relative burden factors were derived to the extent practicable taking into account each EPA issued permit. 9 Tables B 2 to B 9 below present the data from e PIFT, PCS, and the previous ICR used for the burden estimation analysis and the results. Table B 2 shows the number for non storm water general permits from ePIFT and the total number of EPA and state issued non stormwater general permits. Table B 3 has the distribution of reporting frequency from PCS; these numbers, and the number for non stormwater general permits from Table B 2 are then used to estimate the final number of non reporting and reporting permits in each of the frequencies presented in Table B 4. Table B 5 shows the information from the 2002 ICR ( EPA ICR No. 0229.15) and the burden factors for the sampling, analysis, recordkeeping, reporting and other burden associated with EPA issued, non stormwater general permits; these factors are applied to the number of EPA issued permits to generate the burden used in the 2005 ICR, which is presented in Table B 6.

Tables B 7 and B 8 show the analysis for state issued non stormwater general permits. The first table estimates the number of responses based on the total number of permits from ePIFT and the distribution of reporting frequency from PCS. The second table presented the final burden for the sampling, analysis, recordkeeping, reporting and other burden associated with state issued, non stormwater general permits. For these numbers EPA assumed that the level of effort for the required activities has not changed relative to the 2002 ICR.

The final Table B 9 has the total numbers for EPA and state issued non stormwater general permits used throughout this ICR. DMR Information Collection Request April 29, 2005 B 4 Table B 2 Non Storm Water General Permits from ePIFT Total 53,352 AK 2,153 DC 0 ID 191 MA 219 NH 29 NM 47 Total non authorized States 2,639 EPA/ MOU Permits Region 4 290 EPA/ MOU Permits Region 5 11,197 EPA/ MOU Permits Region 8 213 Total EPA/ MOU Permits 11,700 Total EPA Issued 14,339 Total State Issued 39,013 Table B 3 Number and Distribution of Non Storm Water General Permits by Reporting Frequency from PCS Reporting Frequency ( per year) 0 1 2 4 6 12 TOTALS EPA Issued 2,814 353 0 75 0 241 3,483 State Issued 24,274 1,715 2,739 2,893 3 4,138 35,762 EPA Issued 81% 10% 0% 2% 0% 7% State Issued 68% 5% 8% 8% 0% 12%

Table B 4 Number of Non Storm Water General Permits by Reporting Frequency from ePIFT adjusted using PCS Reporting Frequency ( per year) 0 1 2 4 6 12 EPA Issued 11,585 1,453 0 309 0 992 State Issued 26,481 1,871 2,988 3,156 3 4,514 Totals: Non Reporting 38,065 EPA Issued Reporting 2,754 State Issued Reporting 12,532 DMR Information Collection Request April 29, 2005 B 5 Table B 5 EPA Issued Non Storm Water General Permits Data From 2002 ICR ( EPA ICR No. 0229.15)

Respondents Responses Annual Sample Burden Annual Labor Burden Annual Reporting Burden Agency Burden EPANonSW 1,500 7,039 160,198 250,267 14,078 7,039 Oils& Gas 420 3,735 21,622 41,335 7,470 3,735 Seafood 238 462 76,224 788 981 462 Aquaculture 91 469 7,042 1,813 1,166 469 TOTALS 2,249 11,705 265,086 294,203 23,695 11,705 FACTOR 5.20 117.87 130.82 10.54 5.20 Table B 6 EPA Issued Non Storm Water General Permits Data for 2005 ICR Respondents Responses Annual Sample Burden Annual Labor Burden Annual Reporting Burden Agency Burden TOTALS 2,754 14,333 324,610 360,265 29,016 14,333 Table B 7 State Issued Non Storm Water General Permits Data for 2005 ICR From ePIFT adjusted using PCS ( based on frequency of DMR submission)

No. of Respondents No. of Outfalls per Facility Annual DMR Submissions No. of Responses 1,871 1 1 1,871 2,988 1 2 5,976 3,156 1 4 12,624 3 1 6 18 4,514 1 12 54,168 Total State Issued 12,532 74,657 Table B 8 State Issued Non Storm Water General Permits Data for 2005 ICR From Table B 7 and Appendix B 2005 ICR ( EPA ICR No. 0229.15)

Respondents Responses Annual Sample Burden Annual Labor Burden Annual Reporting Burden Agency Burden TOTALS 12,532 74,657 167,978 111,986 149,314 0 Table B 9 EPA and State Issued Non Storm Water General Permits Data for 2005 ICR From Table B 6 and Table B 8 Respondents Responses Annual Sample Burden Annual Labor Burden Annual Reporting Burden Agency Burden TOTALS 15,286 88,990 492,588 472,251 178,330 14,333 APPENDIX C SAMPLE DMR FORM DMR Information Collection Request April 29, 2005 C 1 DMR Information Collection Request April 29, 2005 C 2 DMR Information Collection Request April 29, 2005 APPENDIX D NPDES/ SLUDGE PROGRAM STATUS DMR Information Collection Request April 29, 2005 D 1 NPDES/ Sludge Program Status Approved NPDES Program Approved General Permits Program Approved Sludge Program Alabama

Alaska American Samoa Arkansas

Arizona

California

Colorado

Connecticut

Delaware

District of Columbia Florida

Georgia

Guam Hawaii

Idaho Illinois

Indiana

Iowa

Kansas

Kentucky

Louisiana

Maine

Maryland

Massachusetts Michigan

Minnesota

Mississippi

Missouri

Montana

Nebraska

Nevada

New Hampshire New Jersey

New Mexico New York

North Carolina

North Dakota

Ohio

Oklahoma

Oregon

Pacific Trust Territories Pennsylvania

Puerto Rico Rhode Island

South Carolina

South Dakota

Tennessee

Texas

Utah

Vermont

Virgin Islands

Virginia

Washington

West Virginia

Wisconsin

Wyoming

Federally Recognized Indian Tribes Totals 46 45 5