# Information Collection Request for Title IV of the Public Health Security and Bioterrorism Preparedness and Response Act of 2002: Drinking Water Security

and Safety

November 2014

Prepared for:

Ms. Karen Edwards

, Task Manager U.S. Environmental Protection Agency Office of Ground Water and Drinking Water

EPA East, 2nd Floor 1200 Pennsylvania Avenue, NW (4608T) Washington, DC 20460

US EPA Contract No. EP

- C

- 05

- 045ICR for Drinking Water Security and Safety Nov ember 2014

2 

## TABLE OF CONTENTS

1 IDENTIFICATION OF THE INFORMATION COLLECTION

................................ ... 1

1(a) Title and Number of the Informati on Collection

................................ ............................ 1
1(b) Short Characterization

................................ ................................ ................................ .... 1

2 NEED FOR AND USE OF THE COLLECTION

................................ ............................. 4

2(a) Need/Authority for the Collection

................................ ................................ .................. 4
2(b) Practical Utility/Users of the Data

................................ ................................ .................. 4

3 NON

- DUPLICATION, CONS ULTATIONS, AND OTHER COLLECTION

CRITERIA

................................ ................................ ................................ ................................ ..... 5

3(a) Non

- duplication

................................ ................................ ................................ .............. 5
3(b) Public Notice Required Prior to ICR Submission to OMB

................................ ............ 5
3(c) Consultations

................................ ................................ ................................ ................... 5
3(d) Effects of Less Frequent Collection

................................ ................................ ................ 5

3 (e) General Guidelines

................................ ................................ ................................ .......... 6
3(f) Confidentiality

................................ ................................ ................................ ................ 6 3(g) Sensitive Questions

................................ ................................ ................................ ......... 7

4 THE RESPONDENTS AND THE INFORMATION REQUESTED

.............................. 8

4(a) Respondents and NAICS/SIC Codes

................................ ................................ .............. 8
4(b) Information Needed

................................ ................................ ................................ ........ 8

5 THE INFORMATION COLLECTED

– AGENCY ACTIVITIES, COLLECTION

METHODOLOGY AND INFORMATION MANAGEMENT

................................ .............. 10

5(a) Agency Activities

................................ ................................ ................................ .......... 10
5(b) Collection Methodology and Management

................................ ................................ ... 10
5(c) Small Entity Flexibility

................................ ................................ ................................ . 10
5(d) Collection Schedule

................................ ................................ ................................ ...... 11

6 ESTIMATING THE BURDEN AND COST OF THE COLLECTION

........................ 13

6(a) Estimating Respondent Burden

................................ ................................ ..................... 13
6(b) Estimating Respondent Costs

................................ ................................ ....................... 14
6(c) Estimating Agency Burden and Costs

................................ ................................ .......... 16
6(d) Estimating the Respondent Universe and Total Burden and Costs

.............................. 18
6(e) Bottom Line Burden Hours and Cost Tables

................................ ................................ 18
6(f) BURDEN STATEMENT

................................ ................................ ............................. 19

- APPENDICES

- ................................ ................................ ................................ ...................... A

- 1

APPENDIX A: Analytical Burden Assumptions

................................ ................................ ... A

- 1ICR for Drinking Water Security and Safety Nov ember 2014

3 

## - LIST OF EXHIBITS

Exhibit 6

- 1. Estimated CWS Burden for Emergency Response Plan.

................................ ......... 14

Exhibit 6

- 2. Estim ated Average Annual CWS Burden and Costs.

................................ .............. 15

Exhibit 6

- 3. Estimated Average Annual Agency Burden and Costs.

................................ .......... 17

Exhibit 6

- 4. Es timated Burden and Costs by Year.

................................ ................................ ..... 18

Exhibit 6

- 5. Estimated Bottom Line Average Annual Burden and Costs.

................................ .. 19

Exhibit A

- 1. CWS I nventory.

................................ ................................ ................................ .... A

- 2

Exhibit A

- 2. CWS Unit Cost Assumptions

................................ ................................ ............... A

- 3

Exhibit A

- 3. EPA Unit Cost Assumptions.

................................ ................................ ................ A

- 4

Exhibit A

- 4. CWS Yearly Responses, Burden, and Costs.

................................ ........................ A

- 5 Exhibit A.5. EPA Yearly Responses, Burden, and Costs.

................................ ......................... A

- 6

Exhibit A

- 6. Respondent, Responses, Burden, and Cost Summaries.

................................ ....... A

- 7ICR for Drinking Water Security and Safety Nov ember 2014

4 LIST OF ACRONYMS

BLS Bureau of Labor Statistics

CFR Code of Federal Regulations

CWS Community Water System

EPA En vironmental Protection Agency

ERP Emergency Response Plan

FR Federal Register

ICR Information Collection Request

ICW Information Correction Worksheet

NAICS North American Industry Classification System

O&M Operation and Maintenance

OGWDW Office of G round Water and Drinking Water (US EPA)

OMB Office of Management and Budget

PRA Paperwork Reduction Act

PWS Public Water System

RFA Regulatory Flexibility Act

SBA Small Business Administration

SBREFA Small Business Regulatory Enforcement Fairness Act

SDWA Safe Drinking Water Act

SOC Standard Occupational Classification

VA Vulnerability AssessmentICR for Drinking Water Security and Safety Nov ember 2014

1



### 1 IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Number of the Information Collection

Title IV of the Public Health Security and Bioterr orism Preparedness and Response Act of 2002: Drinking Water Security and Safety

OMB Control Number: 2040

- 0253

EPA Tracking Number: 2103.03

1(b) Short Characterization

This Information Collection Request (ICR) details burden and cost estimates for

re porting and recordkeeping activities required under the Public Health Security and
Bioterrorism Preparedness and Response Act of 2002 (Pub. L. 107

- 188) (the Act). Specifically, this ICR addresses activities applicable to the U.S. Environmental Protection Agency (EPA or the Agency) and certain public water systems (PWSs) as required under Title IV of the Act, which addresses drinking water security and safety.

Title IV of the Public Health Security and Bioterrorism Preparedness and Response

Act of 2002 (Pu b. L. 107

- 188) amends the Safe Drinking Water Act (SDWA). The Act requires each community water system (CWS) 1 serving a population of more than 3,300 people to conduct a vulnerability assessment (VA) of its water system and to prepare or revise an

emergen cy response plan (ERP) that incorporates the results of the vulnerability assessment.

To ensure proper compliance with the Act, EPA will collect and review the following items required to be submitted by CWSs on specified dates:

 Copy of the Vulnerability Assessment (VA)

 Certification that the CWS conducted a VA

 Certification that the CWS prepared or revised an Emergency Response Plan (ERP)

At this time, 100 percent submission has been achieved for Large Utilities (serving a population of 100,000 or more) and Medium Utilities (serving a population of 50,000 or more
but less than 100,000).

As of September 1 6

, 2014 the following documents remain to be collected from a total of 80 small CWSs (serving more than 3,300 people but fewer than 50,000). Some utili ties have

more than one document to be submitted. Below are the documents that remain to be submitted, totaling 117 responses:

1 A community water system is a PWS that serves at least 15 connections used by year

- round residents or regularly

serves at least 25 year

- round residents.ICR for Drinking Water Security and Safety Nov ember 2014

2

 Copy of the Vulnerability Assessment (28)

 Certification that the CWS conducted a Vulnerability Assessment (22)

 Certification th at the CWS prepared or revised an Emergency Response Plan (67)

EPA has been conducting quality assurance reviews of submitted vulnerability assessments to verify receipt of the required information and to ensure that the requirements of

the Act have been met. To address the requirements under Title IV of the Act, EPA has provided baseline information to the CWSs that are required to conduct vulnerability assessments. EPA developed this information in consultation with other departments and agencies of th e federal government and with state and local governments. Information has been provided on the kinds of terrorist attacks or other intentional acts that represent probable threats and that may substantially disrupt the ability of the system to provide a safe and reliable supply of drinking

water.

The collection and storage of information is required to follow the “Protocol to

Secure Vulnerability Assessments Submitted by Community Water Systems to EPA”
(November 30, 2002). The protocol details the manda tory protective measures for shipping, storing, reviewing, discussing, transmitting, copying, and disposing of secure information related to the vulnerability assessments. In addition, the protocol provides procedures for identifying, investigating, train ing, and designating individuals who will have access to the vulnerability

assessments.

Dependent upon further Congressional appropriations, EPA may provide CWSs

with financial or technical assistance for complying with the requirements of this Act. This work, however, is not currently funded.

As explained in Section 2(a), this ICR estimates reporting and recordkeeping burden

and costs to CWSs and EPA in response to Title IV of the Act. This ICR estimates burden and costs for calendar years 20 1 4

, 2015

, and 2016

.

Due to the dramatic reduction in number of expected respondents since the 2003 filing of the ICR for this task, estimated burden hours and costs to CWSs and EPA will be dramatically

lower than in the original Information Collection Request submi tted in August 2003 , but remains

the same as estimates in the 2007 and 2010 renewal s

.

For the 3

- year (2014

- 2016) ICR period, the average annual respondent burden and cost to

CWSs and EPA is estimated at 10

, 029 hours and $8 88,180 2 . The annual burde n and cost to

CWSs is estimated at 8

, 994 hours and $ 803,501

. The estimated annual EPA burden for this ICR

is 1

, 035 hours, at an estimated annual cost of $84, 679

.

NOTE: EPA expects this task will be completed during calendar years 20 1 4 and 20 1 5

, so in the third year of the ICR, there is no expected burden on CWS respondents or on EPA.

2 Note that due to limited data and the use of best professional judgment, these burden and cost estimates are not precise.ICR for Drinking Water Security and Safety Nov ember 2014

3

EPA estimates that $ 33 7 of the annual CWS costs will be spent on operation

and maintenance (O&M) activities. These costs represent postage for delivery of certif ications and copies of vulnerability assessments, as well as postage for delivery of certifications of emergency response plans. This $ 33 7 represents the “cost burden” as reported in the official
Office of Management and Budget (OMB) inventory. Note tha t these costs are for O&M only; there are no capital costs associated with the CWS activities covered by this ICR.

EPA is estimated to incur $0 in annual O&M costs for reimbursing training providers and
for establishing proper security procedures for han dling and storing vulnerability assessments.

EPA is also estimated to incur $19,360 in annual capital costs to complete security enhancements necessary to store and handle vulnerability assessments.

The total estimated number of respondents for this ICR is 80; these respondents are all CWSs serving more than 3,300 but fewer than 50,000 people. The annual number of responses for these respondents is estimated to be 39, which averages to 0.49 responses per respondent annually.

This ICR has been completed in accordance with the February 1999 version of

EPA’s Guide to Writing Information Collection Requests Under the Paperwork Reduction Act
(PRA) of 1995 (hereafter, the “ICR Handbook”). The ICR Handbook was prepared by EPA’s

Office of Environmental Informat ion, Office of Information Collection, Collection Strategies

Division.

The ICR Handbook provides the most current instructions for ICR preparation to

ensure compliance with the 1995 Paperwork Reduction Act Amendments and OMB’s
implementing guidelines.ICR for Drinking Water Security and Safety Nov ember 2014

4



### 2 NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection

EPA derives authority to collect this information from the Public Health Security

and Bioterrorism Preparedness and Response Act of 2002 (Pub. L. 107

- 188). Through this Act,

Con gress conveyed the importance of protecting the nation’s drinking water supply from
intentional attack. The terrorist attacks of September 11, 2001, have resulted in a heightened awareness of the threat faced by the nation’s citizens, its institutions, an d its infrastructure. This includes the threat to the CWSs that supply the nation with safe drinking water. Congress mandated that CWSs assess their vulnerability to terrorist attacks and other intentional acts that would jeopardize a system’s ability to ensure a safe and reliable supply of drinking water. To provide this security, systems must certify to the Agency that they have conducted these assessments and completed emergency response plans.

2(b) Practical Utility/Users of the Data

EPA will use the information collected under this ICR to determine whether CWSs

have completed vulnerability assessments and prepared emergency response plans in compliance with the requirements of the Act. EPA will also use information submitted with the grant applic ations to provide federal financial assistance to CWSs for completing vulnerability assessments and emergency response plans and for complying with the Act.

Primary users of the information collected under this ICR include the EPA Office

of Ground Water a nd Drinking Water (OGWDW), EPA Regional Administrators, and CWSs. Only entities designated by the Administrator may have access to the vulnerability assessments or information contained in or derived from the assessments (except as noted in Section
1433(a )(6)(A), 1433(a)(6)(B), and 1433(a)(7) of the Act).ICR for Drinking Water Security and Safety Nov ember 2014

5



### 3 NON

- DUPLICATION, CONSULTATIONS, AND OTHER

COLLECTION CRITERIA

3(a) Non

- duplication

The information to be collected under this ICR is required by a new federal law. It

does not duplicate any previous work. To the best of the Agency’s knowledge, data requested to
meet the requirements of the Act are not available from any other source.

The requested information will be prepared or compiled by CWSs. If CWSs

have already developed emergency response p lans, they are only required to revise them to include information from the vulnerability assessments that have not been developed or collected previously. Therefore, the information that EPA will collect is not unnecessarily duplicative of

information ot herwise available to the Agency.

3(b) Public Notice Required Prior to ICR Submission to OMB

To comply with the 1995 Amendments to the PRA, EPA solicited public comments on

this ICR for a 60

- day period before it was submitted to OMB. Comments were requ ested on July 16 , 20 14 , via a Federal Register (FR) notice (7 9 FR 4 1547 ). EPA received no comments.

An additional Federal Register notice will be published prior to submission of this ICR to OMB. The public comment period for this additional notice is 3 0 days.

3(c) Consultations

Because of the critical nature of the information to be collected under this ICR (i.e., ensuring safe and reliable drinking water), requirements for collection have been developed quickly. However, EPA has made an effort to c onsult with as many affected entities as possible within the limited time available. EPA worked closely with other federal agencies, state, and local governments, CWSs, and industry organizations to ensure that the program developed is

both effective and efficient. The Agency will continue to work closely with affected entities throughout further development and implementation of these requirements.

3(d) Effects of Less Frequent Collection

Only one response is required for each of three information cat egories (i.e.,

the vulnerability assessment, certification of the vulnerability assessment, and certification of the emergency response plan). These three items are mandated by Congress; to collect less often would be a failure to implement the law.ICR for Drinking Water Security and Safety Nov ember 2014

6

3(e ) General Guidelines

This ICR was developed in accordance with the February 1999 version of the

ICR Handbook prepared by EPA’s Office of Environmental Information, Office of Information
Collection, Collection Strategies Division. The ICR Handbook provide s the most current instructions for ICR preparation to ensure compliance with the 1995 PRA amendments and OMB’s implementing guidelines.

This collection does not violate any of the OMB guidelines for information

collection activities. Specifically, the r espondents are not required to:

 Report information to EPA more than quarterly.

 Prepare a written response to a collection of information in fewer than 30 days after receipt of a request.

 Submit more than an original and two copies of any document.

 Partici pate in a statistical survey that is not designed to produce data that can

be generalized to the universe of the study.

 Use a statistical data classification that has not been reviewed and approved by OMB.

Though OMB guidelines state that respondents are not required to retain records,

other than health, medical, government contract, grant

- in

- aid, or tax records, for more than three years, this collection requires CWSs to retain copies of their emergency response plans for five years after providing certif ication to EPA. The authority to do so is stated directly in the Act: “each community water system shall maintain a copy of the emergency response plan completed
pursuant to subsection (b) for 5 years after such plan has been certified to the Administrato r under this section.” (Pub. L. 107

- 188, Sec. 1433(c))

.

3(f) Confidentiality

Because the Act requires collection of information that must remain confidential,

CWSs will generally ship vulnerability assessments to EPA by courier service directly to a

rec eiving location that secures the information, allowing access only by properly designated individuals. Each CWS is expected to retain a copy of its vulnerability assessment and emergency response plan in accordance with the recordkeeping requirements cont ained in the

Act.

EPA has enacted protocols to secure the vulnerability assessments upon receipt. The collection and storage of information is required to follow the “Protocol to Secure Vulnerability
Assessments Submitted by Community Water Systems to EP A” (November 30, 2002). The
protocol details mandatory protective measures for shipping, storing, reviewing, discussing, transmitting, copying, and disposing of secure information related to the vulnerability assessments. In addition, the protocol provid es procedures for identifying, investigating, training, and designating individuals who will have access to the vulnerability assessments.ICR for Drinking Water Security and Safety Nov ember 2014

7

Only individuals granted access by the EPA Administrator will have authorization to view the vulnerability assessmen ts and any information derived from them (except as noted in Section
1433(a)(6)(A), 1433(a)(6)(B), and 1433(a)(7) of the Act).

3(g) Sensitive Questions

No questions of a sensitive nature are included in any of the information

collection requirements out lined in this ICR.ICR for Drinking Water Security and Safety Nov ember 2014

8



### 4 THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents and NAICS/SIC Codes

Data associated with this ICR are collected and maintained by EPA and by CWSs serving more than 3,300 persons. The 2007 North American Industry C lassification System (NAICS) Code for water supply and irrigation systems is 221310.

4(b) Information Needed

This ICR covers activities outlined by Title IV of the Public Health Security

and Bioterrorism Preparedness and Response Act of 2002 . This ICR summarizes

information collection activities, data items, and respondent activities associated with Title IV of

the Act.

4(b)(i) Data Items

Each CWS serving more than 3,300 people must conduct a vulnerability assessment

of the water system, must certi fy to EPA that it has conducted this assessment, must revise an existing or prepare a new emergency response plan using the information obtained from the vulnerability assessment, and must certify the completion of this plan to EPA. CWSs may apply

for fin ancial assistance to complete the vulnerability assessment but must submit a grant application to do so. 3

Title IV of the Act requires each CWS to submit the following to EPA:

 Copy of vulnerability assessment.

 Certification of vulnerability assessment con duct.

 Certification of completed emergency response plan.

Additionally, the Act requires each CWS to retain a copy of its emergency response plan for a minimum of five years. CWSs may also maintain records of other documents (e.g., copies of grant applic ations, vulnerability assessments, and certifications) as necessary.

4(b)(ii) Respondent Activities

Respondents for this information collection include community water systems serving more than 3,300 people. Because the Bioterrorism Act does not spec ify reporting

or recordkeeping requirements for states, this ICR assumes no state activities associated with the

3 Currently, this ICR includes only descriptions of grant activities and unit burden and costs. If Congress appropriates funds for

the grants, ave rage annual burden and costs for grant applications and review will be added to the ICR through an Information Correction Worksheet (ICW). The appropriation will determine availability and funding levels for new grants.ICR for Drinking Water Security and Safety Nov ember 2014

9

Act. Each CWS is expected to complete the following activities to comply with Title IV of the

Act:

 Read and understand the requirements.

 Compl ete vulnerability assessment training.

 Conduct an assessment of the vulnerability of the system to a terrorist attack or other intentional act intended to disrupt substantially the ability of the system to provide a safe and reliable supply of drinking wat er.

 Certify to EPA that the system has conducted a vulnerability assessment.

 Send the vulnerability assessment to EPA.

 Prepare or revise an emergency response plan that incorporates the results of the vulnerability assessment and includes (but is not li mited to) plans, procedures, and identification of equipment that can be implemented or utilized in the event of a terrorist or other intentional attack on the public water system.

 Certify to EPA that the system has prepared or revised an emergency respons e plan.

 Maintain appropriate records as specified by the Act.

NOTE: The assessment shall include (but is not limited to) a review of the following applicable system parts: pipes and constructed conveyances; physical barriers; water collection,

pretreatme nt, treatment, storage and distribution facilities; electronic, computer, or other automated systems which are utilized by the system; the use, storage, or handling of various chemicals; and the operation and maintenance of the system.

In addition, some CWSs may submit a grant application if funds become available.ICR for Drinking Water Security and Safety Nov ember 2014

10



### 5 THE INFORMATION COLLECTED

– AGENCY ACTIVITIES,

COLLECTION METHODOLOGY AND INFORMATION MANAGEMENT

5(a) Agency Activities

EPA will conduct activities associated with this information colle ction to

meet requirements of Title IV of the Act. These activities are listed below.

 Read and understand the Act.

 Review grant requests, if funding is appropriated.

 Conduct quality assurance reviews of submitted vulnerability assessments to ensure

that r equirements of the Act have been met.

 Conduct quality assurance reviews of vulnerability assessment certifications to ensure that requirements of the Act have been met.

 Conduct quality assurance reviews of emergency response plan certifications

to ensure t hat requirements of the Act have been met.

 Maintain records as specified by the Act.

5(b) Collection Methodology and Management

In collecting the information associated with this ICR, EPA will use the U.S.

Postal Service or overnight delivery services. CWSs should submit their vulnerability assessments, vulnerability assessment certifications, and emergency response plan certifications to EPA by courier service directly to a receiving location that secures the information. EPA

must maintain information related to the vulnerability assessments in such a way as to monitor and limit access to authorized individuals. Access to the information must be limited to properly designated individuals as required by the Agency’s Information Protection Protocol

(Nov ember 30, 2002). EPA will ensure that requirements of the Act have been met by tracking the submission of vulnerability assessments, vulnerability assessment certifications, and emergency response plan certifications. EPA will review a statistically repr esentative sample of the submitted vulnerability assessments to ensure that all applicable requirements of the Act are being met. In addition, EPA will review grant applications, as necessary.

5(c) Small Entity Flexibility

In developing this ICR for the requirements of the Act, EPA considered the requirement of the Small Business Regulatory Enforcement Fairness Act (SBREFA) to minimize

the burden of information collections on small entities. Small entit ies include “smallICR for Drinking Water Security and Safety Nov ember 2014

11

businesses,” “small organizations,” and “small government jurisdictions.” These terms are

defined below. 4

 A small business is any business that is independently owned and operated and not dominant in its field, as defined by the Small Business Administration (SBA) regulations under Section 3 of the Small Business Act.

 A small organization is any non

- profit enterprise that is independently owned and operated and not dominant in its field.

 A small governmental jurisdiction is the governm ent of a city, county, town, township, village, school district or special district that has a population of fewer than 50,000. This definition may also include Indian tribes.

The major requirement under SBREFA is a regulatory flexibility analysis of all rules

that have a “significant economic impact on a substantial number of small entities.” Since EPA
is not promulgating a rule, this ICR is not subject to SBREFA.

EPA will also provide financial assistance to CWSs, as funding is appropriated by
Congres s. However, EPA believes that the burden on small systems will be minimal. In addition, the Act is applicable only to CWSs serving more than 3,300 people. The smallest systems, consequently, are not affected by information collection activities covered in this ICR.

5(d) Collection Schedule

The original schedule for this information collection, as submitted to OMB in August 2003, is detailed below. All large systems (serving a population of 100,000 or more) and

medium

- sized systems (serving a populati on of 50,000 to 99,999) have responded. A total of 80 small systems (from an overall total of 7,613 small systems serving populations greater than 3,300 but smaller than 50,000) have not responded.

Vulnerability Assessments and Certifications

Community water systems must certify and submit to EPA copies of their vulnerability assessments prior to the following dates:

 March 31, 2003, for systems serving a population of 100,000 or more. (All have been
submitted.)

 December 31, 2003, for systems serving a population of 50,000 to 99,999 people.
(All have been submitted.)

 June 30, 2004, for systems serving a population greater than 3,300 but less

than 50,000 people. (A total of 28 vulnerability assessments and 22 vulnerability

assessment certifications rem ain to be submitted.)

Emergency Response Plan Certifications

4 These definitions are taken from section 601 of the Regulatory Flexibility Act.ICR for Drinking Water Security and Safety Nov ember 2014

12

A community water system must certify to EPA that it has prepared or revised

an emergency response plan not later than 6 months after certifying to EPA that the system has

conducted a vulnerabi lity assessment (see section 1433(b) of the Act). (A total of 67 ERP
certifications remain to be submitted.)

Grant Applications

At its discretion and depending on available funding, EPA may develop additional

grant programs to provide CWSs with financia l assistance for conducting vulnerability assessments, preparing emergency response plans, and completing other activities to comply with the Act. Grant availability and funding levels have not yet been determined. If such programs are announced, CWSs ma y submit grant applications in accordance with guidelines established by EPA.ICR for Drinking Water Security and Safety Nov ember 2014

13



### 6 ESTIMATING THE BURDEN AND COST OF THE COLLECTION

This section describes the annual burden and costs for the information

collection activities necessary to meet the requireme nts of Title IV of the Act. The burden and cost estimates for CWSs are discussed in detail in Section 6(a) and (b). The Agency’s burden
and cost estimates are outlined in Section 6(c). Because the Bioterrorism Act does not specify reporting or recordkee ping requirements for States, the States assume no burden or costs for

activities associated with this ICR.

To the extent possible, estimates were based on consultations with individuals who

have already prepared vulnerability assessments and emergency re sponse plans. EPA emphasizes that the per

- respondent estimates represent the average burden and cost over the

three

- year period covered by this ICR (20 1 4 through 20 1 6 ). Some respondents will incur higher costs and some will fall below the average. Also, due to limited data and the use of best professional judgment, these burden and cost estimates are not precise. Detailed burden and cost estimates for CWSs and EPA are provided in Exhibits 6

- 2, 6

- 3, 6

- 4, 6

- 5, and in Appendix A.

6(a) Estimating Responde nt Burden

The average annual respondent burden for CWSs is summarized in Exhibit 6

- 2; Exhibit

6

- 4 shows burden and cost estimates by year. Appendix A provides detail of the annual estimated respondent burden for CWSs to complete the activities described in section 4(b)(ii). EPA estimates a total average annual respondent burden of 8

, 99 4 hours for complying with the requirements of Title IV of the Act. This estimate includes burden hours associated wit h reading and understanding Title IV of the Act, preparing grant applications (if authorized), completing training, conducting vulnerability assessments, certifying the conduct of vulnerability assessments, preparing or revising emergency response plans, c ertifying the conduct of emergency response plans, and recordkeeping. The derivation of estimate s is described below.

Conducting Vulnerability Assessments : The burden associated with conducting vulnerability assessments is estimated based on system size, with burdens averaging 680 hours for the smallest systems

— serving populations of 3,301

- 49,999 persons

— which is the only class of utilities containing any CWSs that have not submitted vulnerability assessments, as required to fulfill the Act’s provisions. EPA based its estimates for vulnerability assessment burden on preliminary consultations with CWSs and EPA Regional personnel and on information from previous grant applications.

Certifying Conduct of Vulnerability Assessments : EPA estimated that CWSs wi ll require 2 hours to prepare a vulnerability assessment certification, based on the Agency’s experience
with similar certification requirements.ICR for Drinking Water Security and Safety Nov ember 2014

14

Preparing or Revising Emergency Response Plans 5 : The estimate for the CWS burden to

prepare an emergency res ponse plan is 1 2 8 hours for systems serving 3,301 to 49,999 people, and 255 hours for systems serving populations of 50,000 or greater. To revise an emergency response plan, the Agency estimated the burden at 28 hours for systems serving 3,301 to 9,999

pe ople, 100 hours for systems serving 10,000 to 49,999 people, and 120 hours for systems serving populations of 50,000 or greater. The Agency used a three

- step process to arrive at these estimates. First, based on its consultations with CWSs and EPA Region al personnel, EPA estimated the burden required both to prepare and to revise an emergency response plan. It then estimated the percentage of these plans related specifically to the security of the system preparing the plan. Finally, multiplying the estim ated unit burden for preparing or revising an emergency response plan by the percentage of the plan related to security yielded the estimated unit burden for emergency response plans under the Act.

Exhibit 6

- 1. Estimated CWS Burden for Emergency Respons e Plan.

System Size ERP Unit Burden

Hours Estimate Security

- Related

Portion ERP Unit Burden

Hours Estimate (Security Only)
Develop ERP

3,301

- 9,999 60 70% 42

10,000

- 49,999 425 50% 212

50,000

- 99,999 850 30% 255

> 100,000 850 30% 255

Revise ERP

3,301

- 9,999 40 70% 28

10,000

- 49,999 200 50% 100

50,000

- 99,999 400 30% 120

> 100,000 400 30% 120

Certifying the Completion of Emergency Response Plans : EPA estimates that CWSs will require 2 hours to prepare an emergency response plan certific ation, based on the Agency’s
experience with similar certification requirements.

Recordkeeping : EPA estimates the CWS burden for recordkeeping to be 0.25 hours per record kept, based on the Agency’s experience with maintaining records. (In Exhibit 6

- 2, w hich shows burden calculations based on responses, the recordkeeping burden is included with each of the three response activities

– develop/submit vulnerability assessment, submit certification of vulnerability assessment, and prepare/revise emergency res ponse plan and submit certification.)

6(b) Estimating Respondent Costs

Exhibit 6

- 2 shows the annual average costs for CWSs over the 3

- year ICR period, and

5 Note that these burden estimates are only for the security portions of the ERPs.ICR for Drinking Water Security and Safety Nov ember 2014

15

Exhibit 6

- 4 shows burden and cost estimates by year.

6(b)(i) Respondent Labor

CWS labor cost s are estimated by applying an hourly labor rate to the burden hour estimates (as explained in 6(a) above ). For purposes of calculating CWS labor costs, EPA assumed a single average hourly wage rate of $ 89.30 . The rate is derived from the rate quoted by the Bureau of Labor Statistics (BLS) for Standard Occupational Classification (SOC) code

11

- 1021 (General and Operations Managers ) 6 . EPA estimates that CWSs will incur an average

annual labor cost of $ 803,164 for these requirements. Appendix A pro vides detailed cost calculations for the information collection activities covered by this ICR.

6(b)(ii) Respondent Operation and Maintenance Costs

CWSs incur no capital costs associated with this ICR. CWSs are estimated to

incur O&M costs ($ 33 7 annu ally) to cover postage for submitting grant applications
(when authorized), vulnerability assessments, vulnerability assessment certifications, and emergency response plan certifications. Given the sensitive nature of these materials, EPA

assumed that eac h CWS will submit the required information by certified, return

- receipt mail or
courier service at a cost of $ 32.10 to ship the vulnerability assessment and associated
certification and $4. 91 to ship the certification of emergency response plan completion.

Exhibit 6

- 2. Estimated Average Annual CWS Burden and Costs.

Activity Responses Burden

Hours Labor

Costs O&M

Costs Total

Annual

Costs

Develop/Submit Vulnerability

Assessment 9 6,120 $546,516 $0 $ 546

, 516

Submit Certification of

Assessment 7 14 $1,25 0 $235 $1,485

Prepare/Revise
Emergency Response

Plan and Submit

Certification 22 2,860 $255,398 $102 $255,500

Total 38 8,994 $803,164 $337 $ 803

, 501

Notes: Detail may not add exactly to total due to independent rounding.

Hours reflect an annual average for all system sizes over the 3

- year ICR period.

A record

- keeping burden of 0.25 hours/record is included in the burden hours for the three activities above.

6 The quoted rate was $ 55.81 in year 20 13 dollars (see http://stats.bls.gov ). In addition, 60 percent overhead was assumed,

b ringing the loaded rate to $ 89.3 0

.ICR for Drinking Water Security and Safety Nov ember 2014

16

6(c) Estimating Agency Burden and Costs

To implement Title IV of the Act, EPA will incur burden and costs. Cost and

burden estimates for EPA’s activities associated with the Act are detailed in Exhibit 6

- 3

and Appendix A.

For the three

- year ICR period, EPA estimated that the averag e annual burden to the Agency will be 1

, 035 hours. This estimate includes burden incurred by EPA staff for the
activities outlined in Section 5(a) above. The derivation of these burden hours follows.

6(c)(i) Reading and Understanding Requirements

Given previous experience with regulations similar complexity, EPA estimated that

its staff will require 40 hours to read and understand the requirements of Title IV of the Act. This estimate assumed that several key staff members will read the requirements.

6(c)(ii) Reviewing Vulnerability Assessments and Certifications

As stated in Section 5(a), EPA will ensure that requirements of the Act are met by tracking submissions of vulnerability assessments and certifications of vulnerability

assessment conduct. E PA will conduct a quality assurance review of a statistically representative sample of the submitted vulnerability assessments to ensure that all applicable requirements of the Act are being met. See paragraph 4(b)(ii) of this document for additional disc ussion of the conduct of a vulnerability assessment.

Based on EPA’s recent experience with vulnerability assessments, the Agency

has estimated an average review time for each CWS size category as follows:

 0.6 hours for systems serving 3,301 to 49,999 peo ple.

 1.1 hours for systems serving 50,000 to 99,999 people.

 1.3 hours for systems serving 100,000 or more people.

These estimates are weighted averages based on the anticipated review time and the number of reviews that EPA will conduct. EPA developed th e weighted averages by estimating the time required to verify receipt of the vulnerability assessments (and the percentage of systems for which EPA will complete this task) and the time necessary for a detailed quality

assurance review of some vulnerabilit y assessments (and the percentage of systems for which EPA will complete this task). The estimated time to verify receipt of the vulnerability assessment is 0.5 hours per system. For the detailed quality assurance reviews, the estimated

burden is 3 hours per vulnerability assessment.

6(c)(iii) Reviewing Emergency Response Plan Certifications

EPA estimated that it will incur 0.25 hours of burden to review each certification

of emergency response plan completion. EPA based this estimate on its experience reviewing

certifications for other EPA

- administered programs.ICR for Drinking Water Security and Safety Nov ember 2014

17

6(c)(iv) Recordkeeping

To both file and secure the records required by Title IV of the Act, EPA estimated that

it will incur a 0.25

- hour burden for each record and an additional 1 ,0 0 0 hours annually for security. The Agency estimated this burden based on its experience with maintaining similar records. The annual security burden is for one staff member devoted full

- time to security of

those records. For the 3 ,1 0 5 burden hours, EPA will in cur annual labor costs of $ 195,957 to implement the Act’s requirements. The following assumptions were used to develop a cost

estimate for EPA activities associated with Title IV of the Act:

The average salary and benefits for EPA staff is at the GS 13, Step 5 level of $ 131,268 7

.

 There are 2,080 hours per person

- year.

 The average hourly rate is $ 63.11

.

In addition to the labor costs incurred for these activities, EPA cost estimates include

the cost of security enhancements designed to protect con tents of the vulnerability assessments. These are considered capital costs, which are estimated at $19,360 annually.

Exhibit 6

- 3. Estimated Average Annual Agency Burden and Costs.

Activity Burden

Hours Labor

Costs O&M

Costs Capital

Costs Total Annual

C osts

Read/Understand Requirements 13 $820 $0 $0 $ 820

Review Vulnerability

Assessments and

Certifications 6 $379 $0 $0 $ 379

Review Emergency Response Plan

Certifications 6 $379 $0 $0 $ 379

Recordkeeping/Security 1,010 $63,741 $0 $ 19,360 $83,101

Total 1,035 $65,319 0 $19,360 $ 84,679

Note: Detail may not add exactly to total due to independent rounding.
Hours reflect an annual average for all system sizes over the three

- year ICR period.

7 According to the Office of Personnel Management January 2013 GS Pay Schedule, the GS

- 13 Step 5 salary is $82,043. By
using the standard government benefits factor of 1.6, the average salary plus benefits is $131,268.ICR for Drinking Water Security and Safety Nov ember 2014

18 Exhibit 6

- 4. Estimated Burden and Costs by Year.

Respondent 2014 (Year 1) 2015 (Year 2) 2016 (Year 3) Total

Burden
(hours) Cost Burden
(hours) Cost Burden
(hours) Cost Burden

(hours) Cost

CWS 13,491 $1,204,746 13,491 $1,204,746 0 $0 26,982 $2,409,493

EPA 1 ,55 2 $ 97,947 1,553 $98,010 0 $0 3,10 5 $ 195,957

Note: Detail may not add exactly to total due to independent rounding.

EPA estimates that one

- half of the responses will be received and processed in 20 1 4 and the remaining one

- half will

b e received and processed in 20 1 5 and all activity associated with this Information Collection Request will be
completed by the end of calendar year 20 1 5

.

6(d) Estimating the Respondent Universe and Total Burden and Costs

The only respondents for this IC R are CWSs serving populations of more than

3,300 people. This ICR estimates the number of such CWSs at 8,487. (At this time, 8,407 of these systems have already responded, based on the Information Collection Request submitted
for this task in 2003.) Th e total costs and burden for these respondents are summarized in

Exhibit 6

- 2. Agency costs and burden are detailed in Section 6(c) and in Exhibit 6

- 3. Exhibit 6

- 4 shows burden and cost by year for both CWSs and EPA.

6(e) Bottom Line Burden Hours and Co st Tables

The bottom line burden hours and costs appear in Exhibit 6

- 5 8 . The total annual

average respondent burden associated with this ICR is estimated to be 8

, 99 4 burden hours. The corresponding total annual average respondent costs are estimated to be $ 803,501 . The total average EPA burden is estimated to be 1,0 35 hours and $ 84,679 annually. The burden and costs by year, and in total, are summarized in Exhibit 6

- 4

.

8 See Appendix A for detailed derivations of these burden and cost estimates.ICR for Drinking Water Security and Safety Nov ember 2014

19 Exhibit 6

- 5. Estimated Bottom Line Average Annual Burden and Cos ts.

Number of Respondents 80 Community water systems

Total Annual Responses 38 Community water system responses

Number of Responses
per Respondent 0.48 = 38

/80 Total annual responses from above Total respondents from above

Total Annual
Respondent

Bur den Hours 8,994 Community water system hours

Hours per Response 237 = 8,994

/38 Total annual hours from above Total responses from above

Annual O&M Costs $33 7 Community water system O&M costs

Total Annual
Respondent Cost $ 803,501 Community w ater system costs

Total Annual Hours (respondent plus Agency) 10,029 = 8,994

+ 1035 Total respondent hours

Total EPA hours

Total Annual Cost (respondent plus Agency) $ 888,180 = $ 803,501
+ $ 84,679 Total respondent cost

Total EPA cost

Note: Detail may not add exactly to total due to independent rounding. Note: Annual O&M costs represent the “cost burden” as reported in the OMB inventory; there are no CWS capital

costs associated with this ICR.

6(f) BURDEN STATEMENT

Burden Statement : The public reporting burden for collections included in this ICR is

detailed in Exhibit 6

- 5 above. The annual respondent burden is estimated to average 2 37 hours per respondent per year, which is attributed to CWSs. This estimate includes time for rea ding and understanding the requirements, completing training, conducting a vulnerability assessment, certifying that the vulnerability assessment was conducted, preparing or revising an emergency response plan, certifying the completion of an emergency res ponse plan, and maintaining the required records.

Burden means the total time, effort, or financial resources expended by people

to generate, maintain, retain, 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 t he information. An agency may not conduct or sponsor, and a person is not required to respond to, a request for information collection

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.ICR for Drinking Water Security and Safety Nov ember 2014

20

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 h as established a public docket for this ICR under Docket

ID No. EPA

- HQ

- OW

- 2003

- 0013, which is available for public viewing at the Water Docket in
the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docke t 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 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 at http://www.regulations.gov. Use regulations.gov to submit or view public comments, to access the index listing of the contents of the public docket, and to access those documents in the public dock et that are available electronically. Once in the system, select “search,” then key in

the docket ID number identified above. Also submit comments to OMB via email to

oira_submission@omb.eop.gov. Address comments to OMB Desk Officer for EPA. P lease include the

EPA Docket ID No. EPA

- HQ

- OW

- 2003

- 0013 in any corresponden ce.

6(f)(i) Reasons For Change In Burden

At this time, 8,407 of the 8,487 CWSs have already responded to this one

- time collection

, based on the Information Collection Request submitted for this task in 2003. This has resulted in total average annual bur den hours for respondents dropping from 2,9 13

, 929 in the original to

8 ,994 hours in the current request. There has been no change in the hours burden from the 2007

ICR. The cost increase is an adjustment to the estimates to account for inflation.ICR for Drinking Water Security and Safety Nov ember 2014

Draft A

- 1 

### - APPENDICES

-

APPENDIX A : Analytical Burden AssumptionsICR for Drinking Water Security and Safety Nov ember 2014

Draft A

- 2 Exhibit A

- 1. CWS Inventory.
System Size
Category (Population Served) Ground Water

CWSs Surface Water

CWSs Wholesale

CWSs All CWSs

Article I. A Article II. B Article III. C A+B+C

3,301

- 9,999 2,567 1,971 38 4,576

10,000

- 49,999 1,256 1,729 52 3,037

50,000

- 99,999 140 322 13 475

>100,000 62 300 37 399

Totals 4,025 4,322 140 8,487

Source: SDWIS FY 2002 Quarter 3 frozen database. Active CWSs in the current inventory o nly.ICR for Drinking Water Security and Safety Nov ember 2014

Draft A

- 3 Exhibit A

- 2. CWS Unit Cost Assumptions

Activities Assumptions
Hrs per Response Labor Cost

(per Hour) Labor Cost

(per Response) Unit O&M

Cost Unit

Capital

Cost

A B C=A*B D E
Read and Understand Requirements

- Systems Serving 3,301

- 9,999

- Syst ems Serving 10,000

- 49,999

- Systems Serving 50,000

- 99,999

- Systems Serving >100,000

Grant Requests (Note 1)

- Systems Serving 3,301

- 9,999

- Systems Serving 10,000

- 49,999

- Systems Serving 50,000

- 99,999

- Systems Serving >100,000

Training

- Systems Servi ng 3,301

- 9,999

- Systems Serving 10,000

- 49,999

- Systems Serving 50,000

- 99,999

- Systems Serving >100,000

Develop Vulnerability Assessments

- Systems Serving 3,301

- 9,999

- Systems Serving 10,000

- 49,999

- Systems Serving 50,000

- 99,999

- Systems Serving >10 0,000

Certify Vulnerability Assessments Developed and Submit Copy to EPA

- Systems Serving 3,301

- 9,999

- Systems Serving 10,000

- 49,999

- Systems Serving 50,000

- 99,999

- Systems Serving >100,000

Prepare Emergency Response Plans

- Systems Serving 3,301

- 9,9 99

- Systems Serving 10,000

- 49,999

- Systems Serving 50,000

- 99,999

- Systems Serving >100,000

Revise Emergency Response Plans

- Systems Serving 3,301

- 9,999

- Systems Serving 10,000

- 49,999

- Systems Serving 50,000

- 99,999

- Systems Serving >100,000

Certify Emergency Response Plans Prepared or

Revised

- Systems Serving 3,301

- 9,999

- Systems Serving 10,000

- 49,999

- Systems Serving 50,000

- 99,999

- Systems Serving >100,000

Recordkeeping

- Systems Serving 3,301

- 9,999

- Systems Serving 10,000

- 49,999

- Systems Se rving 50,000

- 99,999

- Systems Serving >100,000 8

8

8

8

40

40

40

40

8

8

48

48

84.9
1,273.9
1,698.5
6,794.0

2

2

2

2

42

213

255

255

28

100

120

120

2

2

2

2

0.25

0.25

0.25

0.25 $ 78.96

$ 78.96
$ 78.96
$ 78.96

$ 78.96
$ 78.96
$ 78.96
$ 78.96

$ 78.96
$ 78.96
$ 78.96
$ 78.96

$ 78.96
$ 78.96
$ 78.96
$ 78.96

$ 78.96
$ 78.96 $ 78.96
$ 78.96

$ 78.96
$ 78.96
$ 78.96
$ 78.96

$ 78.96
$ 78.96
$ 78.96
$ 78.96

$78.96
$78.96
$78.96
$78.96

$78.96
$78.96
$78.96
$78 .96 $ 631.68

$ 631.68
$ 631.68
$ 631.68

$ 3,158.40 $ 3,158.40 $ 3,158.40 $ 3,158.40

$ 631.68
$ 631.68
$ 3,790.08 $ 3,790.08

$ 6,703.70 $ 100,587.14 $ 134,113.56 $ 536,454.24

$ 157.92
$ 157.92
$ 157.92
$ 157.92

$ 3,316.32
$ 16,818.48 $ 20,134.80 $ 20,134.80

$ 2,210.88 $ 7,896.00 $ 9,475.20 $ 9,475.20

$ 157.92
$ 157.92
$ 157.92
$ 157.92

$ 19.74 $ 19.74
$ 19.74
$ 19.74 $

-

$

- $

- $

-

$ 4.27
$ 4.27
$ 4.27
$ 4.27

$

- $

- $

- $

-

$

- $

- $

- $

-

$ 27.94
$ 27.94
$ 27.94
$ 27.94

$

- $

- $

- $

-

$

- $

- $

- $

-

$ 4.27 $ 4.27
$ 4.27
$ 4.27

$

- $

- $

- $

- $

-

$

- $

- $

-

$

- $

- $

- $

-

$

- $

- $

- $

-

$

- $

- $

- $

-

$

- $

- $

- $

-

$

- $

- $

- $

-

$

- $

- $

- $

-

$

- $

- $

- $

-

$

- $

- $

- $

-

Note 1: Availability and funding levels for new grants have not yet been determined.ICR for Drinking Water Security and Safety Nov ember 2014

Draft A

- 4 Exhibit A

- 3. EPA Unit Cost Assumptions.

Activities Assumptions

Hrs per Response Labor

Cost (per Hour) La bor Cost

(per Response) Unit O&M

Cost Unit Capital

Cost

A B C=A*B D E

Read and Understand Requirements

Review Grant Requests

- Systems Serving 3,301

- 9,999

- Systems Serving 10,000

- 49,999

- Systems Serving 50,000

- 99,999

- Systems Serving >100,000

Rev iew Vulnerability Assessments and

Certifications

- Systems Serving 3,301

- 9,999

- Systems Serving 10,000

- 49,999

- Systems Serving 50,000

- 99,999

- Systems Serving >100,000

Review Emergency Response Plan

Certifications

- Systems Serving 3,301

- 9,999

- Systems Serving 10,000

- 49,999

- Systems Serving 50,000

- 99,999

- Systems Serving >100,000

Recordkeeping

- Filing

- Security 40

20

20

40

40

0.6

0.6

1.1

1.3

0.25

0.25

0.25

0.25

0.25
2,080 $ 58.37

$ 58.37
$ 58.37
$ 58.3 7 $ 58.37

$ 58.37
$ 58.37
$ 58.37
$ 58.37

$ 58.37
$ 58.37
$ 58.37
$ 58.37

$ 58.37
$ 58.37 $ 2,334.80

$ 1,167.40 $ 1,167.40 $ 2,334.80
$ 2,334.80

$ 35.02
$ 35.02
$ 64.21
$ 75.88

$ 14.59
$ 14.59
$ 14.59
$ 14.59

$ 14.59 $ 121,409.60 $

-

$

- $

- $

- $

-

$

- $

- $

- $

-

$

- $

- $

- $

-

$

- $

- $

-

$

- $

- $

- $

-

$

- $

- $

- $

-

$

- $

- $

- $

-

$

- $50,547Draft A

- 5 Exhibit A

- 4. CWS Yearly Responses, Burden, and Costs.

Activities

CWS Responses by

Year CWS Burden by Year CWS Labor Co st by Year CWS O&M Cost by Year CWS Capital Cost by Year

2007 2008 2009 2007 2008 2009 2007 2008 2009 2007 2008 2009 2007 2008 2009
Develop /Submit Vulnerability

Assessments

- Systems Serving 3,301

- 49,999 14 14 - 9

, 520 9

, 520 - $ 751

, 699 $ 751,699 $

- $

- $

- $

- $

- $

- $

-

Certify Vulnerability

Assessments Developed and Submit Copy to EPA

- Systems Serving 3,301

- 49,999 11 11 -

21 21 - $ 1,658 $ 1,658 $

- $ 308 $ 308 $

- $

- $

- $

-

Prepare or Revise Emergency Response

Plans and Submit

Certification

- Systems Serving 3,301

- 49,999 33 33 - 4

, 026 4

, 026 - $ 317

, 893 $ 317

, 893 $

- $

- $

- $

- $

- $

- $

-

Total

- All Activities

58 58 - 13

, 567 13

, 567 - $ 1,071,250 $ 1

, 071,250 $

- $ 442 $ 442 $

- $

- $

- $

-

Note: Detail may not add up exactly due to independent rounding.ICR for Drinking Water Security and Safety Nov ember 2014

Draft A

- 6 Exhibit A.5. EPA Yearly Responses, Burden, and Costs.

Activities EPA Responses by Year EPA Burden by Year EPA Labor Cost by Year EPA O&M Cost by Year EPA Capital Cost by Year

2007 2008 2009 2007 2008 2009 2007 2008 2009 2007 2008 2009 2007 2008 2009

Read and

Understand Requirements 1 1

- 20 20

- $ 1,139 $ 1,139 $

- $

- $

- $

- $

-

Review Vulnerability

Assessments and

Certifications

- Systems Serving

3,301

- 49,999 9 9

- 9 9

- $ 525 $ 525 $

- $

- $

- $

- $

-

Review Emergency Response Plan

Cert ifications

Systems Serving

3,301

- 49,999 9 9

- 9 9

- $ 525 $ 525 $

- $

- $

- $

- $

-

Recordkeeping

- Filing 18 18

- 1

, 5 15 1 ,5 15

- $ 8 8 ,41 5 $ 8 8,415 $

- $

- $

- $

- $

-

- Se curity 1 1

- - - - $

- $

- $

- $

- $

- $

- $ 25,274 $ 25,274 $

-

Total

– All Activities

38 38

- 1

, 553 1

, 553

- $ 90

, 6 0 4 $ 90

, 6 0 4 $

- $

- $

- $

- $ 25,274 $ 25,274 $

-ICR for Drinking Water Security and Safety Nov ember 2014

Draft A

- 7 E xhibit A

- 6. Respondent, Responses, Burden, and Cost Summaries.

Respondent Respondent (count) Annual Response

Estimates Average

Annual Responses Annual Burden

Estimates Average

Annual

Burden

2007 2008 2009 2007 2008 2009

CWSs

- Systems Serving

3,301

- 4 9,999 80 57 57

- 38 1 3

, 49 1 1 3

, 49 1

- 8

, 99 4

CWS Total

80 57 57

- 38 1 3

, 49 1 13

, 49 1

- 8

, 99 4

EPA

1 29 29

- 19 1

, 553 1

, 553

- 1

, 035

Respondent Respondent (count) Annual Labor Cost Average

Annual

Labor

Cost Annual O&M Cost

Burden) Estimates Average

Annual

O&M (Cost Burden) 2007 2008 2009 2007 2008 2009

CWSs

- Systems Serving 3,301

- 4 9,999 80 $ 1,065

, 249 $ 1,065

, 249

- $ 710

, 166 $ 441 $ 441

- $ 294

CWS Total 80 $ 1,065

, 249 $ 1,065

, 249

- $ 710

, 166 $ 441 $ 441

- $ 294

EPA

1 $ 88

, 416 $ 88

, 416

- $ 58

, 944

- - - -ICR for Drinking Water Security and Safety Nov ember 2014

Draft A

- 8

Respondent Respondent (c ount) Annual Capital Cost Average

Annual Capital Cost

2007 2008 2009

CWSs

- Systems Serving

3,301

- 4 9,999 80 $

- $

- $

- $

-

CWS Total 80 $

- $

- $

- $

-

EPA

1 $ 25,274 $ 25,274

- $ 16,849

Respondent Respondent (count) Annual Responses Per Respondent Annual O&M Cost Per Respondent

2007 2008 2009 2007 2008 2009

CWSs

- Systems Serving

3, 301

- 4 9,999 80 0

. 48 0

. 48

- $ 5.51 $ 5.51

-

CWS Total

80 0

. 48 0

. 48

- $ 5.51 $ 5.51

-

EPA

1 2 2

- - - -