i

Information Collection Request for

Performance Evaluation Studies of Wastewater 

Laboratories 

June 2010

Prepared by:

U. S. Environmental Protection Agency

Office of Enforcement and Compliance Assurance

Office of Compliance

Agriculture Division

Agriculture Branch

1200 Pennsylvania Ave., NW

Washington, D.C. 20460
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 ............................................................... 2

2(a) Need/Authority for the Collection............................................................................... 2

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

3 NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA 3

3(a) Non-duplication............................................................................................................. 3

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

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

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

3(e) General Guidelines ...................................................................................................... 4

3(f) Confidentiality ............................................................................................................... 4

3(g) Sensitive Questions ..................................................................................................... 4

4 THE RESPONDENTS AND THE INFORMATION REQUESTED................................ 5

4(a) Respondents and NAICS/SIC Codes ....................................................................... 5

4(b) Information Needed ..................................................................................................... 5

5 THE INFORMATION COLLECTED – AGENCY ACTIVITIES, COLLECTION

METHODOLOGY AND INFORMATION MANAGEMENT .................................................... 7

5(a) Agency Activities .......................................................................................................... 7

5(b) Collection Methodology and Management............................................................... 7

5(c) Small Entity Flexibility.................................................................................................. 7

5(d) Collection Schedule ..................................................................................................... 7

6 ESTIMATING THE BURDEN AND COST OF THE COLLECTION ............................. 8

6(a) Estimating Respondent Burden ................................................................................. 8

6(b) Estimating Respondent Costs.................................................................................... 9

6(c) Estimating Agency Burden and Costs .................................................................... 11

6(d) Estimating the Respondent Universe and Total Burden and Costs................... 11

6(e) Bottom Line Burden Hours and Cost Tables ......................................................... 12

6(f) Reasons for Change in Burden................................................................................ 12

6(g) Burden Statement ...................................................................................................... 12

APPENDIX A: LIST OF CHEMISTRY & MICROBIOLOGY ANALYTES AND WET TEST

METHODS................................................................................................................................... 14

APPENDIX B: LIST OF TOP CHEMISTRY & MICROBIOLOGY ANALYTES AND WET

TEST METHODS AND TIMES FOR ANALYZING ............................................................... 16
1

1 IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Number of the Information Collection

Performance Evaluation Studies of Wastewater Laboratories. OMB Control No. 2080-0021, ICR 

No. 0234.10.

1(b) Short Characterization

This is a request for a new Information Collection Request (ICR) to support the collection of 

Proficiency Testing (PT) data to test the performance of laboratories that conduct discharge 

analyses for the Discharge Monitoring Report – Quality Assurance study program (DMR-QA). 

This request will replace the expiring ICR (Performance Evaluation Studies of Water and 

Wastewater Laboratories (OMB Control No. 2080-0021, EPA ICR No. 0234.09)). This ICR refers 

only to DMR-QA. Therefore, the figures for burdens only support DMR-QA. EPA is requesting a 

standard three-year clearance for this ICR. 

Chemical monitoring data for drinking water and wastewater are submitted from a variety of 

laboratories to the United States Environmental Protection Agency (EPA) every year. These 

results must be relied on by EPA, as they form the primary basis for its regulatory decisions. In 

order to provide an objective demonstration that these laboratories are submitting reliable 

information, the subject Performance Evaluation (PE) studies were developed. Participation in 

the Discharge Monitoring Report - Quality Assurance (DMR-QA) studies is mandatory for major 

wastewater dischargers and selected minor dischargers under the National Pollutant Discharge 

Elimination System (NPDES) permit. Major dischargers are defined as facilities that discharge at 

least 1 million gallons of waste water per day and also those facility(s) servicing at least 10,000 

homes. Minor dischargers are selected to monitor the analytes/toxics discharged by the facility.

EPA originally administered the preparation of test standards for the program as part of the 

Agency’s mandate to assure the quality of environmental monitoring data submitted by NPDES 

permit holders (permittees). Currently, preparation, distribution and grading of the test standards 

for have been privatized to lessen EPA=s burden in carrying out this mandate. Private sector 

companies, known as Proficiency Testing (PT) providers, manufacture and distribute test 

samples to the contract and in-house laboratories. The laboratories submit their analytical results 

to the PT providers for evaluation. The PT providers evaluate the submitted data and send the 

graded results back to the laboratories. These laboratories then forward copies of their graded 

data to their permittee clients, who will review the results and forward the data to their designated 

certifying/enforcement authorities. Providers also send electronic copies of the graded results to 

the designated certifying/enforcement authorities and to EPA. These graded results include the 

names and addresses of the laboratories, the analytes that were tested, the concentration of the 

analyte, and the acceptance criteria and evaluations.

EPA is required to conduct this ICR analysis because more than nine non-Federal entities will be 

asked to respond to these data requests. Because state agencies use the resulting data for their 

own laboratory certification/enforcement programs, and are not reporting any information from the 

PT studies to EPA, they do not incur any burden under this ICR. In addition, cost and burden to 

PT Providers are not considered in this ICR because the vendor costs associated with this 

program are accounted for in the pricing of their standards (i.e., the costs incurred by the 

Providers is factored into the cost of the PT standards).

The total annual burden and labor costs incurred by the 6,589 permittees associated with this ICR 

are estimated to be 41,511 hours and $2,461,426 per year over the 3-year ICR period (2011-13). 

EPA estimates that it takes 6.3 hours and costs $373.57 per year per respondent to comply with 

this requirement. Respondent labor costs are linked with the time it takes to read and understand 

the annual DMR-QA announcement sent by EPA, plan activities, analyze PT standards, report 

information to the PT providers, and maintain records. Respondent operation and maintenance

(O&M) costs are associated with purchasing the PT standards. No costs or burdens to PT 

Providers or state regulatory agencies are associated with this ICR.
2

2 NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection

Laboratory Performance Evaluation (PE) studies are designed to fulfill the need to monitor the 

quality of analytical data for select critical analytes within major point-source discharge samples. 

Results from the PE studies over time have generally shown a slow but regular improvement in 

average performance by the laboratories producing the monitored data. By helping laboratories 

identify and correct analytical problems, the PE studies are also responsible for documented 

improvement in this data.

Public Law 92-500, the Federal Water Pollution Control Act Amendments of 1972, and the related 

regulations in 40 CFR part 136, required extensive analysis of water and wastewater samples by

EPA, state, local government and private laboratories, to maintain ambient water quality and 

control point-source discharges. These monitoring requirements were continued in the Clean 

Water Act of 1987 § 308(a) (Federal Water Pollution Control Act, Public Law 100-4, 33 U.S.C. § 

1318). EPA bases many important decisions upon this data. The data quality depends heavily 

upon the availability of capable laboratory analysis at all levels and reliability must be ensured.

2(b) Practical Utility/Users of the Data

States and laboratory personnel will use the results of these studies to identify problems 

associated with laboratory analysis and substandard facility discharges. This will improve the 

quality of water data in critical monitoring areas and the quality of facility discharge returned to the 

environment. These studies have demonstrated that problems exist and arise periodically with all

dischargers and water testing laboratories; without future studies, many such problems will go 

unrecognized and unresolved. Results from the DMR-QA studies are used to highlight NPDES

facilities and laboratories with apparent analytical problems that should be inspected on-site by

state regulatory personnel. Results from the PT studies are used by State personnel as a major 

part of the basis for certifying laboratories to produce required regulatory data and as a base for 

potential regulatory enforcement. 
3

3 NONDUPLICATION, CONSULTATIONS, AND OTHER 

COLLECTION CRITERIA

3(a) Non-duplication

The DMR-QA accepts data and results from any of the other federally sponsored water quality 

programs, such as the Water Pollution (WP) program, as long as the laboratories meet the 

condition that they perform the PE sample analyses between January 1

st and the last day of the 

DMR-QA study. The DMR-QA study commences on or around March 15th, and concludes on or 

around June 30th of each year. EPA has granted waivers to 5 states to use their state laboratory 

certification program in lieu of their permittees participating in DMR-QA. Four of these waivers 

have been granted since the last ICR was renewed in December 2007. 

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

In compliance with the Paperwork Reduction Act, a notice of this Information Collection Request 

ICR was published in the Federal Register on June 16, 2010 (75 FR 34110),

3(c) Consultations

The DMR-QA has been administered by the EPA for over 30 years. The Office of Research and 

Development initiated and administered the program until the responsibility was assigned to 

Office of Enforcement and Compliance Assurance (OECA). OECA will consider any comments 

received and make appropriate adjustments to the program. The seven PT providers are 

accredited by the American Association for Laboratory Accreditation (A2LA). 

A2LA is a nonprofit, non-governmental, public service, membership society. The mission of A2LA 

is to provide comprehensive services in laboratory accreditation and laboratory-related training. 

The list of PT providers is available at http://a2la.org/dirsearchnew/nelacptproviders.cfm. 

EPA also contacted the PT Providers; three responded, all wish to remain anonymous. The PT 

Providers were asked to give their input on the estimate for time burdens as well as the fees 

which labs need to pay for samples provided by the PT Providers. The three PT Providers that 

responded indicated that it cost on average $280 to $320 per laboratory for samples. An average 

was obtained of $300 per laboratory. It must be kept in mind that this is the cost that in-house 

and contract laboratories pay, and this is passed onto the permittee. Therefore, if a lab is 

contracted by several permittees, then EPA considers that the $300 will be distributed evenly

among the permittees. However, if a permittee employs an in-house laboratory, the permittee is 

burdened with the entire cost of obtaining samples ($300) as well as the labor costs of the 

laboratory. Since the ratio of in-house and contract laboratories is unknown, an average was 

obtained for all laboratories and a ratio of 0.633 permittee per laboratory was used. This ratio is 

the same as used in the 2007 ICR. Therefore, the cost of obtaining samples is estimated to be 

$190 per permittee, using the ratio of 0.633 laboratory per permittee. 

3(d) Effects of Less Frequent Collection

The current frequency for the DMR-QA is judged to be the minimum needed to assess the 

accuracy of data production required by discharge permits. Under DMR-QA, laboratories 

producing data are expected to demonstrate adequate analytical proficiency once each year for 

each analyte they test routinely for their NPDES permittee clients. Collecting water quality data 

less than once per year to measure the accuracy of laboratory work would potentially delay 

corrective actions required by the permittee and therefore compromise discharge water quality. 
4

3(e) General Guidelines

This ICR was prepared in accordance with the October 2009 version of the ICR Handbook 

developed 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 (PRA) Amendments 

and OMB's implementing guidelines. 

EPA believes participation in these studies is a reasonable requirement for all laboratories 

routinely producing data for environmental water regulation. Any public health data on drinking 

waters, ambient waters or effluents under regulation deserve the minimal quality assurance check 

that these studies represent.

3(f) Confidentiality

This information collection does not require respondents to disclose confidential information. 

3(g) Sensitive Questions

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

outlined in this ICR.
5

4 THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents and NAICS/SIC Codes 

Respondents in DMR-QA studies are NPDES permittees designated by the EPA region or state 

with permitting responsibility and the laboratories doing chemical/microbiological analysis and 

whole-effluent toxicity testing for these major dischargers. These respondents are most likely 

from the following SIC Codes:

2011 - through 3999 - Manufacturers

4941 - Water supply systems

4952 - Sewerage systems

8734 - Water testing laboratories

4(b) Information Needed

4(b)(i) Data Items

In all laboratory PE studies, the data result from analyses of synthetic samples that 

contain known amounts of specific compounds, usually dissolved in reagent water. In 

DMR-QA studies, the compounds are those of primary interest with regard to the 

monitoring requirements in the NPDES permits. All studies also collect sufficient data 

to properly identify and characterize the respondents. Each respondent reports only 

data for that portion of the study analytes for which they wish to be certified or as 

directed by the responsible regulatory official.

4(b)(ii) Respondent Activities

The primary burden involves analyzing and reporting results for relevant study samples 

according to instructions. Based on the current DMR-QA study, 6,589 respondents 

participate in certification studies. 

The DMR-QA program requires 6,589 permittees to submit results annually. A

percentage of these permittees do all the work onsite themselves, using in-house 

laboratories. The remaining permittees contract at least some of the analysis to a 

commercial laboratory(s). The commercial laboratory may do work for many

permittees; the DMR-QA results would then be sent to these permittees. Therefore, 

there are fewer labs than permittees. However, EPA does not have data on how many

in-house laboratories and contract laboratories are used. Furthermore, EPA does not 

track how many laboratories participated in one or more studies or how many

permittees participated in only chemistry and microbiology and those that also 

participated in WET testing. EPA is estimating the “maximum” impact of the DMR-QA 

program on the regulated community. EPA will assume that all 6,589 permittees will 

fulfill requirements for the top 10 chemistry & microbiology analytes and the top 10 

WET test methods. EPA believes this ICR may overestimate the burden because not 

all permittees do WET testing. (See Appendix B for a list of the top 10 chemistry & 

microbiology analytes and the top 10 WET test methods).

To calculate the burden incurred on laboratories performing PE samples, EPA used a 

ratio of 0.633 laboratories per NPDES permittee. This ratio was calculated based on 

data procured by 4 PT Providers in 2006. EPA assumes that the ratio of laboratories 

per permittee has not changed significantly since the last ICR was approved. Based on 

this ratio (0.633 laboratories per NPDES permittee) and that there are 6,589 permittees 

participating in the DMR-QA, EPA estimates there are a total of 4,171 laboratories 

performing PE studies under DMR-QA. To provide an estimate of respondent burden

for the WET testing portion of DMR-QA, EPA determined that an average of 4.77% of 

all laboratories participating in DMR-QA perform WET PE tests, or 227 laboratories. 

This percentage is also based on the information from the 4 providers received in 2006. 
6

EPA is not estimating the burden for the PT Providers, because this burden is 

internalized in the cost of obtaining PE samples from the PT Providers. 

Respondents (permittees) will participate in the following activities: 

 Read Instructions: Each of the 6,589 respondents will read the instructions 

provided by EPA. 

 Plan Activities: Each of the 6,589 respondents will incur burden to plan activities 

associated with the PT studies.

 Analyze Chemistry and Microbiology Analytes: EPA assumes that all 6,589

respondents will participate in the PT studies for microbiology, trace metals, 

demands, minerals, nutrients, and miscellaneous analytes as required by 

respondents’ permits. EPA assumes that 4,171 in-house and contract 

laboratories will do the work for the 6,589 permittees. 

 Analyze WET: EPA assumes that all 6,589 permittees will participate in the PT 

studies for WET. It is assumed that 227 in-house and contract laboratories will 

do the work for the 6,589 permittees. 

 Report Results: Each of the 6,589 respondents will incur burden to report its 

study results to the PT provider. 

 Maintain Records: Each of the 6,589 respondents will incur burden to maintain 

records associated with the PT study.
7

5 THE INFORMATION COLLECTED – AGENCY ACTIVITIES, 

COLLECTION METHODOLOGY AND INFORMATION MANAGEMENT

5(a) Agency Activities

EPA has reduced its activity related to this information collection to that of providing general 

guidance and oversight for the PT Providers and the participating laboratories on an as needed 

basis.

5(b) Collection Methodology and Management

EPA will notify the permittee of their requirement to participate in the relevant PE program 

annually. The permittee’s in-house or contract laboratory will then select an accredited private PT 

Provider to provide them with the appropriate samples. The testing facility will then send the 

analysis data of these samples to the PT Provider. The permittee will use the form approved by

OMB to report DMR-QA results. This form will be available in two formats: a hard copy that will 

be part of the announcement which is mailed annually and an online PDF form, available on the 

EPA website. This PDF form can be filled out and then printed for submission. The PT Provider 

will send evaluations of the submitted data back to the permittee and the designated 

certifying/enforcement authority. PT Providers will also send summary data in electronic form to 

EPA for archiving.

5(c) Small Entity Flexibility

The major requirement under Small Business Regulatory Enforcement Fairness Act (SBREFA) is 

a regulatory flexibility analysis of all rules that have a "significant economic impact on a 

substantial number of small entities." Since this data request is not part of a rule, this ICR is not 

subject to SBREFA. 

5(d) Collection Schedule

EPA determines the requirements for the frequency that a permittee must demonstrate 

proficiency by passing a PE study. The study typically starts on or around March 15th and ends on 

or around June 30th. .The participating permittees’ in-house/contract laboratories demonstrate 

their proficiency by passing a PE study conducted by an accredited PT Provider for a fee. The PT 

Provider must submit the results of each study to the state and EPA regional coordinator, as well 

as the EPA National Coordinator. 

In summary: each participating in-house or contract laboratory must report test results to the PT 

Provider once a year. The PT Provider must electronically submit the results of all studies they 

conduct to participating permittees and state and EPA regional coordinators. Participating 

permittees must re-qualify for each analyte it reports one year from the last certification that it 

received.
8

6 ESTIMATING THE BURDEN AND COST OF THE COLLECTION

This section describes the estimated average annual burden and costs for the information 

collection activities for PT studies that will be conducted by laboratories. For this data 

submission, PT providers and state agencies and EPA have no burden and costs; this is 

discussed further in Section 6(a). The Agency's burden and cost estimates are outlined in 

Section 6(c).

To estimate the costs, EPA made assumptions about the burden associated with activities that 

would likely be needed to fulfill the request. EPA emphasizes that the per-respondent estimates 

represent the average burden and cost over the 3-year period covered by this ICR (2011-2013). 

Some respondents may incur higher costs and some will fall below the average. EPA made the 

assumption that all respondents perform all the tests included in this analysis. As a result, the 

time burden may be a bit on the higher end. 

Burden and costs are not distinguished by categorized entities, public (federal, state and local 

government dischargers) and private (commercial, industrial and others) sectors, because EPA 

currently does not track this information. EPA’s best estimate is that from the total of 6,589 

permittees, there are 3,148 state and local government facilities and 3,441 commercial facilities

6(a) Estimating Respondent Burden

The average annual respondent burden (in labor hours) for permittees is shown in Table 6.1. PT 

Providers conduct the studies, removing this burden from EPA. Participating laboratories receive 

samples from the PT Provider, return test results to the PT Providers and the PT Providers 

evaluate the data and send reports to the laboratories, the state accrediting authorities and EPA. 

The total burden on the laboratories is 41,511 hours, with an average of 6.3 hours per respondent 

(41,511 total hours divided by 6,589 permittees). This estimate includes burden for participating 

laboratories to read instructions, plan activities, analyze samples, submit data to the PT vendors, 

and maintain records. 

EPA assumes that the respondent burden will be divided among three labor categories: 

manager, chemist, and records clerk. The labor associated with each of the ICR activities are 

discussed in more detail below. 

 Read Instructions: EPA assumes that each of the 6,589 respondents will require 0.5

hour to read the instructions provided by EPA. The burden will be evenly divided 

between a manager and chemist.

 Plan Activities: EPA assumes that the manager of each laboratory will require 0.5 hours 

to plan activities associated with the PT studies. The burden will be divided between a 

manager and chemist.

 Analyze Chemistry and Microbiology Analytes: A total of 6,589 permittees are expected 

to use a total of 4,171 laboratories (a ratio of 0.633 laboratories for every permittee). 

Analysis is assumed to require approximately 1.8 hours to analyze PT standards for the 

top 10 analytes. All hours will be incurred by a chemist. See Appendix B for these tests 

and the estimated time for an analysis. These estimates assume that the laboratory is 

adding a DMR-QA sample to the normal processing that occurs in the laboratory using an 

already calibrated instrument/process.

 Analyze WET: A biologist or project manager constructs the test chambers and records 

organism mortality (morbidity) of test organisms while a chemist analyzes the water 

chemistry. Biologists and chemists are assumed to require 2.4 hours to analyze PT 

standards for WET. It is assumed that 227 laboratories do this work for all 6,589 

permittees. These estimates assume that the laboratory is adding a DMR-QA sample to 

the normal processing that occurs in the laboratory using an already calibrated 

instrument/process.
9

 Report Results: EPA assumes that each of the 6,589 respondents will require 1.0 hours 

to report the results of the study to the PT Provider. The burden will be divided between 

a manager and records clerk. 

 Maintain Records: EPA assumes that a records clerk in each of the 6,589 laboratories 

will require 0.1 hours to maintain the files from the PT study.

Manager Chemist 2 Record 

Clerk

hours /year hours /year hours /year Per 

Respondent 

All 

Respondents

Read Instructions 6,589 0.2 0.3 0 0.5 3,758

Plan activities 6,589 0.2 0.3 0 0.5 3,758

Analyze Chemistry/Microbiology 6,589 0 1.8 0 1.8 13,529

Analyze WET 6,589 0 2.4 0 2.4 18,038

Report Results 6,589 0.3 0 0.7 1 7,516

Maintain Records 6,589 0 0 0.1 0.1 752

Total 6,589 6.3 41,511

Total Annual # Responses: 6,589 6.3

2

 Refer to Appendix B for analysis times for Chemistry/Microbiology analytes and WET methods.

Avg. Labor (hours) per 

Respondent:

Table 6.1 

Estimated Annual Respondent Burdens for Proficiency Testing

1

 Historic records indicate that 6,589 NPDES permittees particpate in the DMR-QA program. Most of the permittees 

participate in the Chemistry/Microbiology component. A smaller amount also participate in WET analysis. It is estimated 

that 4.77% of all labs participate in the WET analysis.

Collection Activities

Burden

Annual # Total Burden (hours/year)

Respondents1

6(b) Estimating Respondent Costs

Table 6.2 shows the annual average costs for laboratories over the 3-year ICR period. Average 

annual labor costs for all 6,589 permittees are estimated to be $1,209,516. Average annual O&M 

costs are estimated to be $1,251,910. EPA estimates each laboratory will incur an annual 

average labor plus non-labor cost of $373.57 for this data collection effort. (see Table 6.2).

6(b)(i) Respondent Labor

The labor cost was arrived at by estimating the amount of labor required to participate 

on an annual basis in the DMR-QA study. Labor costs are based on information 

provided by the U.S. Department of Labor Statistics, May 2008, National Industry 

Specific Occupational Employment and Wage Estimate. The labor categories include a 

manager at an hourly rate of $51.23, a data entry clerical person at an hourly rate of 

$13.25, and a skilled technician or chemist to conduct the measurements at an hourly 

rate of $28.16. These values were adjusted for inflation using the U.S. Department of

Labor Bureau of Labor Statistics’s CPI calculator (http://data.bls.gov/cgi-bin/cpicalc.pl). 

Table 6.2 lists the estimated burden and costs for labor related to each activity. The 

annual respondent labor cost, for all 6,589 respondents is estimated to be $1,196,910

for 41,511 hours. 
10

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

Operation and Maintenance (O&M) costs for laboratories include all costs related to 

providing personnel with the space, equipment and materials necessary to perform the 

tasks required by this ICR. Since laboratories are driven by their compliance 

monitoring requirements to purchase the analytical instrumentation and computers and 

not by this ICR, no capital costs are be considered associated with this ICR. Only the 

costs associated with purchasing the PT standards is appropriate for consideration in 

this category. 

Permittees may participate in the PT studies for some or all of the chemistry, 

microbiology analytes and WET test methods (refer to Appendix A for a list of 

chemistry and microbiology analytes and WET test methods). The cost of the PE 

samples varies with the costs for the analytes, microbiological and WET testing 

required for each calendar year. This is complicated by the fact that the participants in 

any given study need not analyze all of the samples available for that study, only the 

ones that are required by their permits. EPA estimated a cost of $300 per laboratory 

based on feedback from PT Providers who did an analysis of the average cost of 

buying PE samples. 

Because EPA does not have sufficient information to estimate how many analytes are 

contained in the PT samples sent to each laboratory, EPA assumes that a single PT 

sample contains standards for the top ten analytes for chemistry and microbiology and 

the top 10 WET test methods, based on information from the PT Providers. Therefore, 

laboratories participating in the chemistry and microbiology PT study are assumed to 

receive and run analyses for 10 analytes. Similarly, those participating in the PT study 

for WET would receive samples for each of 10 WET test methods. EPA estimates the 

costs of obtaining PT samples to be $300 per laboratory and $190 per permittee 

(respondent). Average annual O&M costs (fees for PE samples) for the respondents is 

estimated to be $1,251,910.
11

Labor Plus 

Non-Labor

Manager 2 Chemist 3 Record 

Clerk 4

Average Labor plus 

Non-Labor Costs

at 

$51.78/hr

at 

$28.46/hr

at 

$13.39/hr

per 

Respondent

All 

Respondents

(@$300/lab, 

or $190 per 

Respondent)

All 

Respondents All Respondents

Read Instructions $10.36 $8.54 $0.00 $18.89 $124,492.57 $0 $0 $124,493

Plan activities $10.36 $8.54 $0.00 $18.89 $124,492.57 $0 $0 $124,493

Analyze Chemistry 

and Microbiology $0.00 $51.23 $0.00 $51.23 $337,541.29

Analyze WET $0.00 $68.30 $0.00 $68.30 $450,055.06

Report Results $15.53 $0.00 $9.37 $24.91 $164,112.22 $0 $0 $164,112

Maintain Records $0.00 $0.00 $1.34 $1.34 $8,822.67 $0 $0 $8,823

Total $1,209,516 $190 $1,251,910 $2,461,426

Non-Labor Cost

$1,251,910

Cost of Standards per PT 

Analysis

4 U.S. Department of Labor Statistics, Information and Record Clerk 43-4199. ($13.25)

3 U.S. Department of Labor Statistics, Chemist 19-2031. ($28.16)

Table 6.2 

Estimated Annual Respondent Costs for Proficiency Testing

$2,039,506

1 Salaries from U.S. Department of Labor Statistics, May 2008, National Industry Specific 

Occupational Employment and Wage Estimates, adjusted for inflation (http://data.bls.gov/cgibin/cpicalc.pl).

2 U.S. Department of Labor Statistics, Natural Science Manager 11-9121. ($51.23)

Collection 

Activities

Labor Cost 1

Labor Costs

$190

6(b)(iii) Capital/Startup Operating and Maintenance (O&M) Costs

There are no Capital/Startup costs associated with this information collection. The 

annual Operating and Maintenance costs associated with this ICR are estimated to be 

$190 per respondent. 

6(c) Estimating Agency Burden and Costs

Since EPA’s role has been reduced to an advisory level only, there is no longer any burden to the 

Agency, other than the time required to put together the annual announcement and printing and 

mailing costs of the annual announcement. On average, 6,750 announcements are printed 

annually, to send out to permittees, PT Providers, state and regional coordinators as well as 

spare copies. The annual burden is estimated below:

 Maintaining records of active participants in the program: 80 hours 

 Putting together the annual announcement and answering questions: 480 hours (40 

hours/month)

 Cost of printing 6,750announcements: $5,000

 Cost of mailing announcements: $6,000

 Total annual burden and cost to EPA: 560 hours and $11,000

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

The only respondents for this ICR are NPDES permittees. They may use contract laboratories to 

perform the work, but the burden is considered to be upon the permittees, since they bear the 

costs of labor and operations & maintenance. As itemized in section 6(b), the annual respondent 

burden is 6.3 hours and $373.57 per participant. The total annual respondent burden is 41,511 

hours and $2,461,426 for 6,589 participants. Currently, there are 7 PT Providers. PT Providers’ 

burdens are not assessed in this ICR because their cost burden for this ICR is part of the 
12

estimated PE sample cost burden for the laboratories. Burden and costs to EPA is minimal, 

being limited to the drafting of the annual announcement and printing/mailing costs, which come 

to a total of 560 hours and $10,962.21 on an annual basis. 

6(e) Bottom Line Burden Hours and Cost Tables

The bottom line burden hours and costs for this ICR are shown in Table 6.3. This includes the 

burden and costs to the 6,589 laboratories that are affected by this ICR.

Cost / Burden Total Across Three ICR 

Years (2011-2014)

Average Per Year over ICR 

Years (2011-2014)

Number of Respondents (Permittees) 6,589 6,589

Total Responses 19,767 6,589

Number of Responses per Permittee 3 1

Burden Hours per Permittee 18.9 6.3

Total Burden Hours (all 6,589 Permittees) 124,532 41,511

Per Permittee Labor Costs $551 $184 

Total Labor Costs (all 6,589 Permittees) $3,628,548 $1,209,516 

Per Permittee O&M Costs $900 $300 

Total O&M Costs (all 6,589 Permittees) $3,755,730 $1,251,910 

Total Costs (Labor plus O&M costs for all 6,589 

permittees) $7,384,278 $2,461,426 

Table 6.3 

Bottom Line Burden and Costs (for ICR period (2011-14)

6(f) Reasons for Change in Burden

 Participation in the DMR-QA PE study has decreased from an estimated average of 7,516 to 

6,589 since the last renewal of this ICR. This is due to EPA granting a waiver to four 

additional states, allowing them to employ their state laboratory certification program as an 

adequate substitute for the federal DMR-QA program. 

 Labor and Operation & Maintenance costs were updated since the previous renewal of this 

ICR. Operation & Maintenance costs reflect the costs of obtaining PE samples from the PT 

Providers. The estimated average cost of obtaining PE samples increased from $165 per 

respondent (permittee) to $190 per respondent.

6(g) Burden Statement

The average annual respondent burden for each permittee is estimated to be 6.3 hours per 

response. This estimate includes the total time, effort, or financial resources expended by

permittees to gather and report information, and develop and maintain record. 

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

above. The total annual respondent burden (for years 2011 – 2013) imposed by these collections 

is estimated to be 47,351 hours, or 6.3 hours per respondent per year. Estimates include time for 

reading instructions, planning activities, analyzing standards, reporting results, and maintaining 

records.

Burden means the total time, effort, or financial resources expended by persons to generate, 

maintain, retain, or disclose or provide information to or for a Federal agency. This includes the 
13

time needed to review instructions; develop, acquire, install, and utilize technology and systems 

for the purposes of collecting, validating, and verifying information, processing and maintaining 

information, and disclosing and providing information; adjust the existing ways to comply with any 

previously applicable instructions and requirements; train personnel to be able to respond to a 

collection of information; search data sources; complete and review the collection of information; 

and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and 

a person is not required to respond to, a collection of information unless it displays a currently 

valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR 

part 9 and 48 CFR Chapter 15. 

To comment on the Agency's need for this information, the accuracy of the provided burden 

estimates, and any suggested methods for minimizing respondent burden, including the use of 

automated collection techniques, EPA has established a public docket for this ICR under Docket 

ID No. EPA-HQ-OECA-2010-0413, which is available for online viewing at www.regulations.gov, 

or in person viewing at the Enforcement and Compliance Docket in the EPA Docket Center 

(EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA/DC 

Public Reading Room is open from 8 a.m. to 4:30 p.m., Monday through Friday, excluding legal 

holidays. The telephone number for the Reading Room is 202-566-1744, and the telephone 

number for the Enforcement and Compliance Docket is 202-566-1752. 

Use EPA’s electronic docket and comment system at www.regulations.gov, to submit or view 

public comments, access the index listing of the contents of the docket, and to access those 

documents in the docket that are available electronically. Once in the system, select “docket 

search,” then key in the docket ID number identified above. Please note that EPA’s policy is that 

public comments, whether submitted electronically or in paper, will be made available for public 

viewing at www.regulations.gov as EPA receives them and without change, unless the comment 

contains copyrighted material, CBI, or other information whose public disclosure is restricted by

statute. For further information about the electronic docket, go to www.regulations.gov. Also, you 

can send comments by mail 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-OECA-2010-0413 and OMB control 

number 2080-0021 in any correspondence. 
14

APPENDIX A: LIST OF CHEMISTRY & MICROBIOLOGY ANALYTES 

AND WET TEST METHODS

Microbiology Trace Metals

E.coli Aluminum

Fecal Coliform, MF or MPN Antimony

Total Coliform, MF or MPN Arsenic

Minerals Barium

Alkalinity, total (CaCO3) Beryllium

Chloride Cadmium

Fluoride Chromium, total

Hardness, total (CaCO3) Chromium, hexavalent

Specific conductance (25°C) Cobalt

Sulfate Copper

Total Dissolved Solids (180°C) Iron 

Nutrients Lead

Ammonia as N Manganese

Nitrate as N Mercury

Nitrite as N Mercury (Low Level)

Orthophosphate as P Molybdenum

Total Kjeldahl-Nitrogen as N Nickel

Total Phosphorus as P Selenium

Misc. Analytes Silver

Non-Filterable Residue (TSS) Thallium

Oil and Grease Vanadium

pH Zinc

Total Cyanide Demands

Total Phenolics (4-AAP) 5-day BOD

Total Residual Chlorine 5-day Carbonaceous BOD

Total Residual Chlorine (Low COD

 Level) TOC

Settleable Solids

Turbidity

Chemistry and Microbiology Analytes
15

Analyte Number Organisms/Conditions End Points

Test Code 13/EPA Method 2000

754 Fathead minnow (Pimephales promelas ) - MHSF 25OC LC50

Test Code 14/EPA Method 2000

755 Fathead minnow (Pimephales promelas ) - 20% DMW LC50

Test Code 15/EPA Method 1000

756 Fathead minnow (Pimephales promelas ) - MHSF NOEC SURVIVAL

808 Fathead minnow (Pimephales promelas ) - MHSF IC25 (ON) GROWTH

810 Fathead minnow (Pimephales promelas ) - MHSF NOEC (ON) GROWTH

Test Code 16/EPA Method 1000

759 Fathead minnow (Pimephales promelas ) - 20% DMW NOEC SURVIVAL

812 Fathead minnow (Pimephales promelas ) - 20% DMW IC25 (ON) GROWTH

814 Fathead minnow (Pimephales promelas ) - 20% DMW NOEC (ON) GROWTH

Test Code 19/EPA Method 2002

764 Ceriodaphnia dubia - MHSF 25OC LC50

Test Code 20/EPA Method 2002

765 Ceriodaphnia dubia - 20% DMW 25OC LC50

Test Code 21/EPA Method 1002

766 Ceriodaphnia dubia - MHSF NOEC SURVIVAL

767 Ceriodaphnia dubia - MHSF IC 25 REPRODUCTION

768 Ceriodaphnia dubia - MHSF NOEC REPRODUCTION

Test Code 22/EPA Method 1002

769 Ceriodaphnia dubia - 20% DMW NOEC SURVIVAL

770 Ceriodaphnia dubia - 20% DMW IC25 REPRODUCTION

771 Ceriodaphnia dubia - 20% DMW NOEC REPRODUCTION

Test Code 32/EPA Method 2021

788 Daphnia magna - MHSF 25OC LC50

Test Code 38/EPA Method 2021

794 Daphnia pulex - MHSF 25OC LC50

Test Code 42/EPA Method 2007

798 Mysid (Mysidopsis bahia ) 25OC LC50

Test Code 43/EPA Method 1007

799 Mysid (Mysidopsis bahia ) NOEC SURVIVAL

816 Mysid (Mysidopsis bahia ) IC25 (ON) GROWTH

818 Mysid (Mysidopsis bahia ) NOEC (ON) GROWTH

Test Code 44/EPA Method 2006

803 Inland silverside (Menidia berylina ) 25OC LC50

Test Code 45/EPA Method 1006

824 Inland silverside (Menidia berylina ) NOEC SURVIVAL

825 Inland silverside (Menidia berylina ) IC25 (ON) GROWTH

826 Inland silverside (Menidia berylina ) NOEC (ON) GROWTH

Test Code 46/EPA Method 2004

804 Sheepshead minnow (Cyprinodon variegatus ) 25OC LC50

Test Code 47/EPA Method 1004

805 Sheepshead minnow (Cyprinodon variegatus ) NOEC SURVIVAL

820 Sheepshead minnow (Cyprinodon variegatus ) IC25 GROWTH

822 Sheepshead minnow (Cyprinodon variegatus ) NOEC (ON) GROWTH

WET Organisms/Test Conditions/End Points 
16

APPENDIX B: LIST OF TOP CHEMISTRY & MICROBIOLOGY 

ANALYTES AND WET TEST METHODS AND TIMES FOR ANALYZING

1 pH 10

2 Total Suspended Solids 30

3 Ammonia (as N) 5

4 Total Residual Chlorine 3

5 Biochemical Oxygen Demand (BOD) 45

6 Carbonaceous BOD 45

7 Copper 5

8 Total Phosphorous as P 10

9 Zinc 5

10 Oil & Grease 15

TOTAL (minutes) 173

TOTAL (hours) 2.88

1.8 hours per permittee for Chemistry/Microbiology

using ratio of 0.633 labs per permittee

1 Fathead minnow - MHSF - NOEC Survival 10 Chronic

2 Fathead minnow - MHSF - NOEC (ON) Growth 10 Chronic

3 Ceriodaphnia - MHSF - NOEC Survival 10 Chronic

4 Fathead minnow - MHSF 25°C - LC50 3 Acute

5 Fathead minnow - MHSF - IC25 (ON) Growth 10 Chronic

6 Ceriodaphnia - MHSF - NOEC Reproduction 10 Chronic

7 Ceriodaphnia - MHSF - IC25 Reproduction 10 Chronic

8 Ceriodaphnia - MHSF 25°C - LC50 3 Acute

9 Fathead minnow - MHSF 20°C - LC50 3 Acute

10 Mysid - 40 fathoms - NOEC Survival 10 Chronic

TOTAL (hours) 79

*based on set-up, 

maintenance, data 

crunching at conclusion, 

10 hr (chronic) also 

includes daily weighting

50.0 hours for WET analysis per lab

 using ratio of 0.633 labs per permittee

 2.4 hours for WET analysis

because only 4.77% of labs do WET 

analyses, the following number will be used 

for time burden for WET tests:

type of test Time (hours) for one 

analysis* Rank

WET ORGANISMS/TEST CONDITIONS/END POINTS CHECKLIST

CHEMISTRY/MICROBIOLOGY ANALYTE CHECKLIST

Time (in minutes) for 

one analysis

Analyte

Rank Analyte

**These estimates are 

accurate if this is for an 

additional single analyses to 

an already calibrated 

instrument/process. This 

assumes that the laboratory 

is adding a DMR-QA sample 

to the normal processing 

that occurs in the laboratory.