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

- 045ICR 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 o f Less Frequent Collection

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

3(e) General Guidelines

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

3(f) Confidentiality

................................ ................................ ................................ ................ 6

3(g) Sensitive Questions

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

4 THE RE SPONDENTS 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 ESTIMA TING 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 August 2010



## - LIST OF EXHIBI TS

Exhibit 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 C osts by Year.

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

Exhibit 6

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

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

Exhibit A

- 1. CWS Inventory.

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

- 2

Ex hibit 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 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 Ad ministration

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 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 Requ est (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 activitie s 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 Biot errorism 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) 1 serving a population of more than 3,300 people to

conduct a vulnerability assessment (VA) of it s 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 U tilities (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 1 8 , 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 en sure 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 consul tation 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‖

(Nov ember 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 co mplying 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 0 , 20 1 1 , and 20 1 2

.

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 t he 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 $7 87 ,71 2 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 ,2 52

.

NOTE: EPA expects this task will be completed during calendar years 20 1 0 and 20 11 , 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 t his 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 co mpleted 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). Throug h 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 i nstitutions, 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 syst em’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 t he 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 duplica te 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 emerg ency 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 comme nts.

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 d evelopment 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 GuidelinesICR 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 amend ments 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 writte n 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 res ponse 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 assess ments 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 ac cordance 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

Asses sments 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 vulnerabili ty 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 a ny 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 a ssessment.

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 le vels 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 syst em 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 activ ities 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, vulnerabil ity 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 m onitor

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 requirement s 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 ―sma ll 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 distric t 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 substanti al 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 wil l 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 s ystems (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 submit ted.)

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, prepari ng 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

esta blished 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 c osts 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 estimate s represent the average burden and cost over the

three

- year period covered by this ICR (20 10 through 20 12 ). 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 a re 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 a nd 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 with reading

and understanding Title IV of the Act, preparing grant applications (if authorized), completing

training, conducting vulnerability assessments, certifying th e conduct of vulnerability

assessments, preparing or revising emergency response plans, certifying the conduct of

emergency response plans, and recordkeeping. The derivation of estimate s is described below.

Conducting Vulnerability Assessments : The burde n 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 ha ve 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 a pplications.

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 Plans 5 : The estimate for the CWS burden to

prepare an emergency response 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

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 p rocess 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 relate d 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 em ergency 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 ho urs 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 vulnerabi lity 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 $ 7 8. 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 n o 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 respons e 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 associat ed 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 3 8 8

, 99 4 $ 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 percen t 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 i ncur 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 Certific ations

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 statistic ally 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.

Bas ed 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 peopl e. 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 ve rify 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

EP A 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 ,0 0 0 hours annually for

security. The Agency estimated this bu rden 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 05 burden hours, EPA will incur annual labor costs of $ 181

, 20 9 to

implement the A ct’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 $12 1

, 406 7

.

There are 2,080 hours per person

- year. The average hourly rate is $5 8

. 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 considere d 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 ,0 10 $ 58 ,9 4 4 $0 $16,849 $ 75

, 79 3

Total 1

, 035 $ 60

, 40 3 $0 $16,849 $ 77

, 25 2

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 20 10 (Year 1) 20 11 (Year 2) 20 12 ( Year 3 ) Total

Burden

(hours) Cost Burden

(hours) Cost Burden

(hours) Cost Burden

(hours) Cost

CWS 13

, 49 1 $ 1,065,690 13

, 49 1 $ 1,065,690 0 $0 26

, 98 2 $ 2, 1 31 ,3 8 0

EPA 1

, 553 $11 5

, 878 1

, 553 $11 5

, 878 0 $0 3

, 106 $23 1

, 75 6

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 10 and the remaining one

- half will

be received and processed in 20 11 and all activity associated with this Information Collection Request will be

completed by the end of calendar year 20 11

.

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 submi tted

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

, 99 4 burden hours. The

corresponding total annual average re spondent costs are estimated to be $ 710

, 460. The total

average EPA burden is estimated to be 1,0 35 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 = 3 8

/80 Total annual responses from above

Total respondents from above

Total Annual Respondent

Burden Hours 8

, 99 4 Community water system hours

Hours per Response 2 37 = 8

, 99 4

/ 3 8 Total annual hours from above

Total responses from above

Annual O&M Costs $294 Community water system O&M

costs Total Annual Respondent

Cost $ 7 1 0

, 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 ,2 52 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 p ublic 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 response per year, which is attributed to CWSs. This estimate includes time for reading and

u nderstanding 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 ins tructions; 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

c omply 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 informa tion. 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 establi shed a public docket forICR 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 P ublic 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 pu blic 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 ar e 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,

Was hington, 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 collect ion

, based on the Information Collection Request submitted for this task in 2003. This resulted in

total average annual burden hours for respondents dropping from 2,9 13

, 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 AssumptionsICR 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 $

-

$

- $

- $

- $

-

$

- $

- $

- $

-

$

- $

- $

- $

-

$

- $

- $

-

$

- $

- $

- $

-

$

- $

- $

- $

-

$

- $

- $

- $

-

$

- $50,547Draft 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 - $ 7 24

, 853 $ 7 24

, 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 - $ 3 38

, 739 $ 3 38

, 739 $

- $

- $

- $

- $

- $

- $

-

Total

- All Activities

58 58 - 13

, 491 13

, 491 - $ 1,0 65 ,250 $ 1

, 0 65 ,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

Certifications

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 $

- $

- $

- $

- $

-

- Security 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 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

- 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)

2010 2011 2012 2010 2011 2012

CWSs

- Systems
Serving 3,301

- 4 9,999 80 $ 1,065

, 249 $ 1,065

, 249

- $ 710

, 166 $ 442 $ 44 2

- $ 294

CWS Total 80 $ 1,065

, 249 $ 1,065

, 249

- $ 710

, 166 $ 442 $ 44 2

- $ 294

EPA

1 $ 90

, 604 $ 90

, 604

- $ 60

, 403

- - - $ 16,849ICR 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

- 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

2010 2011 2012 2010 2011 2012

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

- - - -