ICR for Drinking Water Security and Safety August 2010

Information Collection Request for Title IV of the 

Public Health Security and Bioterrorism Preparedness 

and Response Act of 2002: Drinking Water Security 

and Safety

August 2010

Prepared for:

Nancy Muzzy, Project Officer (Cincinnati)

Ms. Karen Edwards, Work Assignment 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-05-045
ICR for Drinking Water Security and Safety August 2010

TABLE OF CONTENTS

1 IDENTIFICATION OF THE INFORMATION COLLECTION ................................... 1

1(a) Title and Number of the Information 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, CONSULTATIONS, 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.......................................................................................................... 5

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-1
ICR for Drinking Water Security and Safety August 2010

-LIST OF EXHIBITSExhibit 6-1. Estimated CWS Burden for Emergency Response Plan.......................................... 14

Exhibit 6-2. Estimated Average Annual CWS Burden and Costs............................................... 15

Exhibit 6-3. Estimated Average Annual Agency Burden and Costs. .......................................... 17

Exhibit 6-4. Estimated Burden and Costs by Year. ..................................................................... 18

Exhibit 6-5. Estimated Bottom Line Average Annual Burden and Costs. .................................. 19

Exhibit A-1. CWS Inventory. .................................................................................................... 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-7
ICR for Drinking Water Security and Safety August 2010

LIST OF ACRONYMS

BLS Bureau of Labor Statistics

CFR Code of Federal Regulations

CWS Community Water System

EPA Environmental 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 Ground 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 Assessment
ICR for Drinking Water Security and Safety August 2010

1 IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Number of the Information Collection

Title IV of the Public Health Security and Bioterrorism 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 

reporting 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 (Pub. L. 107-188) amends the Safe Drinking Water Act (SDWA). The Act requires 

each community water system (CWS)1serving a population of more than 3,300 people to 

conduct a vulnerability assessment (VA) of its water system and to prepare or revise an 

emergency 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 August 18, 2010, 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 utilities 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 August 2010

Copy of the Vulnerability Assessment (28)

Certification that the CWS conducted a Vulnerability Assessment (22)

Certification that 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 the 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 mandatory 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, training, 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 2010, 2011, and 2012.

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 submitted in August 2003, but remains 

the same as estimates in the 2007 renewal. 

For the 3-year ICR period, the average annual respondent burden and cost to CWSs and 

EPA is estimated at 10,029 hours and $787,712

2

. The annual burden and cost to CWSs is 

estimated at 8,994 hours and $710,460. The estimated annual EPA burden for this ICR is 1,035

hours, at an estimated annual cost of $77,252.

NOTE: EPA expects this task will be completed during calendar years 2010 and 2011, 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 August 2010

EPA estimates that $294 of the annual CWS costs will be spent on operation 

and maintenance (O&M) activities. These costs represent postage for delivery of certifications 

and copies of vulnerability assessments, as well as postage for delivery of certifications of 

emergency response plans. This $294 represents the ―cost burden‖ as reported in the official 

Office of Management and Budget (OMB) inventory. Note that 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 handling and storing vulnerability assessments. 

EPA is also estimated to incur $16,849 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 Information, 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 August 2010

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, 

Congress 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, and 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 

applications 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 and 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 August 2010

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 plans, 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 otherwise 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 requested on 

July 25, 2007, via a Federal Register (FR) notice (72 FR 40851). 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 30 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 consult 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 categories (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.

3(e) General Guidelines
ICR for Drinking Water Security and Safety August 2010

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 provides 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 respondents 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.

Participate 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 certification 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 Administrator 

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 

receiving 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 contained 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 EPA‖ (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 provides procedures for identifying, investigating, 

training, and designating individuals who will have access to the vulnerability assessments. 

Only individuals granted access by the EPA Administrator will have authorization to view the 

vulnerability assessments 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).
ICR for Drinking Water Security and Safety August 2010

3(g) Sensitive Questions

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

collection requirements outlined in this ICR.
ICR for Drinking Water Security and Safety August 2010

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 Classification 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 certify 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 financial 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 conduct.

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 applications, 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 specify reporting 

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

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

Act:

 

3

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

the grants, average 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 August 2010

Read and understand the requirements.

Complete 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 water. 

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 limited 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 response 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, 

pretreatment, 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 August 2010

5 THE INFORMATION COLLECTED – AGENCY ACTIVITIES, 

COLLECTION METHODOLOGY AND INFORMATION MANAGEMENT

5(a) Agency Activities

EPA will conduct activities associated with this information collection 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 requirements 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 that 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 

(November 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 representative 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 entities include ―small 

businesses,‖ ―small organizations,‖ and ―small government jurisdictions.‖ These terms are 

defined below.4

 

4

These definitions are taken from section 601 of the Regulatory Flexibility Act.
ICR for Drinking Water Security and Safety August 2010

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 government 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 

Congress. 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 population 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 remain to be submitted.)

Emergency Response Plan Certifications

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 vulnerability assessment (see section 1433(b) of the Act). (A total of 67 ERP 

certifications remain to be submitted.)
ICR for Drinking Water Security and Safety August 2010

Grant Applications

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

grant programs to provide CWSs with financial 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 may submit grant applications in accordance with guidelines 

established by EPA.
ICR for Drinking Water Security and Safety August 2010

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 requirements 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 recordkeeping 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 response plans. EPA 

emphasizes that the per-respondent estimates represent the average burden and cost over the 

three-year period covered by this ICR (2010 through 2012). 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 Respondent 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 8,994 hours for complying with the

requirements of Title IV of the Act. This estimate includes burden hours associated with 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, certifying the conduct of 

emergency response plans, and recordkeeping. The derivation of estimates 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 will 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 August 2010

Preparing or Revising Emergency Response Plans5: The estimate for the CWS burden to 

prepare an emergency response plan is 128 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 

people, 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 Regional 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 estimated 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 Response 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 certification, 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, which 

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 response 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 August 2010

Exhibit 6-4 shows burden and cost estimates by year. 

6(b)(i) Respondent Labor

CWS labor costs 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 $78.96. 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 $710,166 for these requirements. Appendix A provides 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 ($294 annually) 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 each CWS will submit the required information by certified, return-receipt mail or 

courier service at a cost of $27.94 to ship the vulnerability assessment and associated 

certification and $4.27 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 $483,235 $0 $483,235

Submit 

Certification of 

Assessment

7 14 $1,105 $205 $1,310

Prepare/Revise 

Emergency

Response Plan and 

Submit 

Certification

22 2,860 $,225,826 $89 $225,915

Total 38 8,994 $710,166 $294 $710,460

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 $47.73 in year 2006 dollars (see http://stats.bls.gov). For accuracy, this rate has been adjusted for inflation 

to 2007 dollars using the Employment Cost Index released by the Bureau of Labor Statistics on July 31, 2007, showing that 

wages and salaries for civilian workers rose 3.4 percent between June 30, 2006 and June 30, 2007, bringing the rate in 2007 

dollars to 49.35. In addition, 60 percent overhead was assumed, bringing the loaded rate to $78.96 in 2007 dollars.
ICR for Drinking Water Security and Safety August 2010

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 average 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. EPA 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 discussion 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 people.

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 the 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 vulnerability 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 August 2010

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 1,000 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 3,105 burden hours, EPA will incur annual labor costs of $181,209 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 $121,4067.

There are 2,080 hours per person-year.

The average hourly rate is $58.36.

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

the cost of security enhancements designed to protect contents of the vulnerability assessments. 

These are considered capital costs, which are estimated at $16,849 annually.

Exhibit 6-3. Estimated Average Annual Agency Burden and Costs.

Activity Burden

Hours

Labor

Costs

O&M 

Costs

Capital

Costs

Total 

Annual

Costs

Read/Understand

Requirements

13 $759 $0 $0 $759

Review Vulnerability

Assessments and 

Certifications

6 $350 $0 $0 $350

Review Emergency 

Response

Plan Certifications

6 $350 $0 $0 $350

Recordkeeping/Security 1,010 $58,944 $0 $16,849 $75,793

Total 1,035 $60,403 $0 $16,849 $77,252

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 2007 GS Pay Schedule, the GS-13 Step 5 salary is $75,879. By 

using the standard government benefits factor of 1.6, the average salary plus benefits is $121,406.
ICR for Drinking Water Security and Safety August 2010

Exhibit 6-4. Estimated Burden and Costs by Year.

Respondent 2010 (Year 1) 2011 (Year 2) 2012 (Year 3) Total

Burden

(hours)

Cost Burden

(hours)

Cost Burden

(hours)

Cost Burden

(hours)

Cost

CWS 13,491 $1,065,690 13,491 $1,065,690 0 $0 26,982 $2,131,380

EPA 1,553 $115,878 1,553 $115,878 0 $0 3,106 $231,756

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 2010 and the remaining one-half will 

be received and processed in 2011 and all activity associated with this Information Collection Request will be 

completed by the end of calendar year 2011.

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

The only respondents for this ICR 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.) The 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 Cost 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 8,994 burden hours. The 

corresponding total annual average respondent costs are estimated to be $710,460. The total 

average EPA burden is estimated to be 1,035 hours and $77,252 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 August 2010

Exhibit 6-5. Estimated Bottom Line Average Annual Burden and Costs.

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

Burden 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 $294 Community water system O&M 

costs

Total Annual Respondent 

Cost

$710,460 Community water system costs

Total Annual Hours

(respondent plus Agency)

10,029 = 8,994

+ 1,035

Total respondent hours

Total EPA hours

Total Annual Cost

(respondent plus Agency)

$787,712 = $710,460

+ $77,252

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 237 hours 

per response per year, which is attributed to CWSs. This estimate includes time for reading 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 response 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 the 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.

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 
ICR for Drinking Water Security and Safety August 2010

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 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 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 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. 

EPA-HQ-OW-2003-0013 in any correspondence.

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 resulted in 

total average annual burden hours for respondents dropping from 2,913,929 in the original to 

8,994 hours in the 2007 request. This information remains outstanding, thus there is no change in 

burden from the 2007 ICR.
ICR for Drinking Water Security and Safety August 2010

Draft A-1

- APPENDICES -

APPENDIX A: Analytical Burden Assumptions
ICR for Drinking Water Security and Safety August 2010

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 only.
ICR for Drinking Water Security and Safety August 2010

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

- Systems 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 Serving 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 >100,000

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 3,301-9,999

- 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 Serving 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 August 2010

Draft A-4

Exhibit A-3. EPA 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

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

Review 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

$ 58.37

$ 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

$ -

$ -

$ -

$ -

$ -

$ -

$ -

$ -

$ -

$ -

$ -

$ -

$ -

$ -

$ -

 

$ -

$ -

$ -

$ -

$ -

$ -

$ -

$ -

$ -

$ -

$ -

$ -

$ -

$ -

$50,547
Draft A-5

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

Activities

CWS Responses by 

Year

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

2010 2011 2012 2010 2011 2012 2010 2011 2012 2010 2011 2012 2010 2011 2012

Develop/Submit

Vulnerability 

Assessments

- Systems Serving 3,301-

49,999

14 14

-

 9,180 9,180

-

$ 724,853 $ 724,853 $ - $ - $ - $ - $ - $ - $ -

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

-

4,290 4,290

-

$ 338,739 $ 338,739 $ - $ - $ - $ - $ - $ - $ -

Total - All Activities

58 58

-

13,491 13,491

-

$1,065,250 $1,065,250 $ - $ 442 $ 442 $ - $ - $ - $ -

Note: Detail may not add up exactly due to independent rounding. 
ICR for Drinking Water Security and Safety August 2010

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

2010 2011 2012 2010 2011 2012 2010 2011 2012 2010 2011 2012 2010 2011 2012

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 

CertificationsSystems Serving 

3,301-49,999

 9 9 - 9 9 - $ 525 $ 525 $ - $ - $ - $ - $ -

Recordkeeping

- Filing 18 18 - 1,515 1,515 - $ 88,415 $ 88,415 $ - $ - $ - $ - $ -

- Security 1

 

 1 - - - - $ - $ - $ - $ - $ - $ - $ 25,274 $ 25,274 $ -

Total – All Activities

 38 38 - 1,553 1,553

 

 - $ 90,604 $ 90,604 $ - $ - $ - $ - $ 25,274 $ 25,274 $ -
ICR for Drinking Water Security and Safety August 2010

Draft A-7

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

Respondent Respondent 

(count) Annual Response 

Estimates

Average

Annual

Responses

Annual Burden 

Estimates

Average

Annual

Burden

2010 2011 2012 2010 2011 2012

CWSs

- Systems Serving 

3,301-49,999

80 57 57 - 38

 

13,491 13,491

 

 -

 

 8,994

CWS Total

80 57 57

 

 -

 

 38

 

13,491 13,491 - 8,994

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)

2010 2011 2012 2010 2011 2012

CWSs

- Systems 

Serving 3,301-

49,999

80 $1,065,249

 

$1,065,249

 

 -

 

$710,166 $ 442

 

$ 442

 

 

 

 -

 

$ 294

 

CWS Total 80 $1,065,249 $1,065,249

 

 -

 

$710,166 $ 442

 

$ 442 - $ 294

EPA 

 1 $ 90,604 $ 90,604 - $ 60,403 -

 

 -

 

 - $ 16,849
ICR for Drinking Water Security and Safety August 2010

Draft A-8

 

Respondent Respondent 

(count)

Annual Capital Cost

Average

Annual 

Capital Cost

2010 2011 2012

CWSs

- Systems Serving 

3,301-49,999

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

2010 2011 2012 2010 2011 2012

CWSs

- Systems Serving 

3,301-49,999

80

 

 0.48

 

 0.48

 

 - $ 5.51

 

$ 5.51

 

 

 

 -

CWS Total

80 0.48 0.48

 

 - $ 5.51

 

$ 5.51 -

EPA 

 1 2 2

 

 - -

 

 -

 

 -