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September 6, 2005

EPA Water Docket Center

1200 Pennsylvania Ave., NW

Mail Code 4101 T

Washington, DC 20460

**Attention: Docket ID OW-2004-0035**

**Re: Agency Information Collection Activities: Proposed Collection;
Comment Request: Technical Survey, Drinking Water Treatment Facilities,
EPA ICR Number 2176.01,**

**70 *Federal Register* 38675**

Dear Docket:

As directors and managers of the nation's largest drinking water systems
collectively serving over 110 million people, AMWA appreciates the
opportunity to provide comment on the proposed Screener and Detailed
Surveys related to the development of effluent guidelines for drinking
water treatment facilities.

EPA states the goal of the screener and detailed surveys are to:

"... provide EPA with preliminary, technical, and environmental data
needed to quantify any adverse environmental impacts of the discharges
of residuals and metals from drinking water treatment facilities,
evaluate the effectiveness of treatment technologies, and determine the
incremental pollutant removals and compliance costs for various residual
management options that EPA might consider for the proposed rule."

AMWA believes that in order for EPA to meet its objectives, it should
explain how the data requested of utilities would assist EPA in
achieving its stated goals. Currently, the links between the data
requested in the draft surveys, and the goals described are unclear.
Understanding the context for requests for specific data will help
utilities gather the data EPA needs to understand the composition of
drinking water treatment residuals.

Utilities and states might also be more inclined to provide EPA with
additional data relevant to EPA's goals and overall mission (i.e.,
determining whether to propose effluent guidelines for drinking water
treatment residuals) if they understand what, exactly, the mission is
and what data are necessary to complete it. Previous informal requests
from EPA for residuals data from drinking water treatment plants have
gone largely unanswered because utilities do not have clear information
to help them make decisions about what data would be helpful to the
agency.

In articulating how the survey will inform EPA's effort to address
potential effluent guidelines for drinking water systems, EPA should aim
to only collect data that is relevant to this mission. Collecting data
not directly related to EPA's mission will confuse utilities that are
gathering the data. It will also result in wasted time spent by
utilities in gathering irrelevant data as well as wasted time spent by
EPA in analyzing it.

With regard to collecting information about residuals sent to publicly
owned treatment works (POTWs), AMWA understands that it is necessary for
EPA to collect this data for the purposes of developing a mass balance
of residuals generation and disposal. However, AMWA notes that drinking
water systems work with POTWs to manage drinking water residuals within
the local limits set by municipalities. These local limits, unique to
each municipality, have been successfully worked out and implemented in
communities across the country.

With regard to the specific questions posed by EPA in the *Federal
Register* notice, AMWA offers the following comments:

1\. **Is the collection of information necessary for the proper
performance of the functions of the Agency (i.e., to determine whether
an effluent guidelines regulation for drinking water utilities is
necessary)?**

> AMWA believes that before (and possibly instead of) collecting the
> information detailed in the draft screener and detailed
> questionnaires, EPA should review existing records to identify water
> systems that generate and dispose of residuals.  Much of the
> information EPA seeks is available in the data submitted to the agency
> by large water systems under the **Information Collection Rule
> (ICR)**.

This rule required all water systems serving more than 100,000 people to
electronically submit a sampling plan. This plan included design plant
parameters, general drinking water treatment process schematics, monthly
and quarterly water quality monitoring results, residuals information,
and operational data, such as monthly chemical dosage information.

Albeit water utilities may have altered treatment processes or added new
water sources since the ICR was implemented in July of 1997, an EPA
review and analysis of existing ICR data could provide information to
identify systems that have residuals treatment, their treatment types
and dosage rates.   Such a review and analyses would enable EPA to
identify data gaps and refocus the current survey instruments. (It might
then be possible to combine the two surveys into one, targeted survey
aimed at utilities known to generate and dispose of waste residuals of
concern to EPA.) The result would be a more cost and time efficient
endeavor for both EPA and drinking water utilities that will be required
to complete the survey.

2\. **Is EPA's burden estimate for the questionnaires accurate (7 hours
for the short screener, 48 hours for the longer form), and is their
approach overall valid?**

For large utilities that do manage waste residuals generated at the
facility, EPA has underestimated the time necessary to complete the
surveys. For the screener survey, treatment plants with processes that
generate waste residuals could take several hours just to compile the
information necessary to complete the screener. In addition, adequate
time for QA/QC and management review should be considered. AMWA
estimates it would take *at least* 16 hours for such facilities to
complete the screener questionnaire.

If EPA decides to use the screener survey, AMWA suggests inserting a new
question #7 that allows utilities that do not produce residuals to check
a box indicating there are no residuals generated (and therefore, none
to dispose of) from the facility. If the "no" box is checked for this
question, it should be noted that the treatment facility is finished
with the questionnaire, and does not need to answer more questions.

In terms of the detailed questionnaire, AMWA believes that EPA has
underestimated the time necessary for completion. Utilities will most
likely have to distribute the questionnaire out to different departments
or personnel to obtain information about residuals, chemical consumption
and costs. In terms of costs requested, utilities would also have to
research the categories mentioned across different departments to report
accurate information. For many treatment plants, AMWA estimates at least
twice the amount of time would be required (96 hours).

EPA should also note that most large utilities that will be affected by
these surveys have more than one treatment plant. The estimated burden
time for one utility system could be multiplied two or more times for
those utilities that have multiple plants producing residuals.

3\. **Can the surveys be improved in any way to enhance the quality,
utility and clarity of information to be collected?**

AMWA believes the surveys could be improved in many ways to improve the
quality, utility and clarity of the information EPA proposes to collect.
Below are several suggestions to the agency:

a)  [Clarifying which utilities and drinking water treatment plants are
    required to complete the survey]{.underline}. Both the "Draft" and
    "Detailed" survey instruments are intended for response for
    information for one "facility" and specify one SDWIS ID.  Large
    drinking water systems generally have more than one treatment plant
    affiliated with its individual public water system ID (PWSID, which
    should be the same as the SDWIS ID). In some states, each drinking
    water treatment plant may have its own unique ID.

> EPA needs to specify which treatment plants are required to complete
> the survey for each PWSID/SDWIS ID. Currently the questionnaire is
> clear only for systems with a single surface water treatment plant.
> Does a utility fill out multiple questionnaires if it has multiple
> treatment plants?

b)  [Clarifying what is meant by "facility"]{.underline}. In the
    proposed survey, "facility" is defined as "physical location
    corresponding to the site where industrial and non-industrial
    activities are conducted." EPA says that a questionnaire needs to be
    completed for each facility.

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c)  [Clarification of term "treatment]{.underline}". EPA's definition of
    treatment is specific to waste products. Drinking water utilities
    generally refer to treatment as the means of processing raw water
    for the purpose of meeting federal and state quality regulations and
    distribution to water system customers for their use and
    consumption. AMWA suggests EPA use an adjective to describe what
    sort of "treatment" to which it is referring, i.e., "waste
    treatment", "drinking water treatment" or "residuals treatment".

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d)  [Clarification of term "primary source".]{.underline} The Detailed
    Survey requests water quality information for the primary source.
    For a groundwater system, there is likely to be several sources, but
    no "primary source". EPA should clarify this term. Does EPA intend
    to have the surface water body or groundwater well where the utility
    draws its largest volume of raw water for treatment as its primary
    source?

e)  [Short Screener Survey Questionnaire, Question 3]{.underline}. AMWA
    suggests editing this question for clarity to read, "Did the
    drinking water treatment facility generate residuals that were
    disposed of in any of the following ways: to waters of the United
    States, to a publicly owned treatment works (POTW), on-site (e.g.,
    landfill, irrigation, evaporation), or off-site (e.g., landfill,
    composting, irrigation)?

f)  [Security of schematics submitted.]{.underline} Although detailed
    schematics are not proprietary information as defined in the surveys
    (i.e., CBI), detailed schematics and treatment processes submitted
    to EPA should be protected from public disclosure. Since September
    11, 2001, water utilities have taken many steps to secure
    information that could leave them vulnerable to an intentional
    malevolent act. In the case of the survey instruments, this includes
    detailed schematics and information about treatment chemicals,
    doses, and the location of their application. Additionally,
    requiring the latitude and longitude coordinates for treatment
    plants and intakes is a concern. EPA should ensure that such
    information will not be freely available to others within the Agency
    who do not have a need to know, and should also be able to protect
    it from freedom of information act (FOIA) requests.

4\. **What is the best way for EPA to collect this information to
minimize the burden?**

EPA's draft survey states, "We do not recommend you complete this survey
electronically." AMWA disagrees with this statement and suggests that
electronic reporting be allowed, at least for large systems. AMWA
believes that setting up a system for electronic submission by
developing properly formatted online survey mechanisms (whether
web-based or through submission of pre-formatted spreadsheets) would
reduce the data entry burden for EPA and for utilities. Electronic
submission would also facilitate water system response.  

AMWA encourages EPA to clearly state the expected units of measure for
each data field. This will be very important for proper analysis of the
information collected.

AMWA is committed to advocating environmental priorities based on a
scientific approach to policy making. We appreciate your consideration
of our comments. Should you have any questions, please do not hesitate
to contact Erica Brown, Director of Regulatory Affairs, or me at
202-331-2820.

Sincerely,

![](media/image2.png){width="1.5555555555555556in"
height="0.3736111111111111in"}

Diane VanDe Hei

Executive Director

Cc: Tom Born, EPA

Ahmar Siddiqui, EPA