### 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 Penns yl vania 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 AN D 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) Publ ic 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 AN D THE INFORMATION REQUESTED ................................ 5 4(a) Respondents and NAICS/SIC Codes

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

................................ ................................ ................................ ..... 5 5 THE INFORMATION COLLECTED – AG ENCY ACTIVITIES, COLLECTION METHODOLOGY AN D 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 AP PENDIX A: LIST OF CHEMISTRY & MICROBIOLOGY AN ALYTES AND WET TEST METHODS ................................ ................................ ................................ ................................ ... 14 AP PENDIX B: LIST OF TOP CHEMISTRY & MICROBIOLOGY AN ALYTES AND WET TEST METHODS AND TIMES FOR AN ALYZING ................................ ............................... 16

### 1



## 1 IDENTIFICATION OF THE INFORM AT ION 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 Cha racterization 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 fo r the Discharge Monitoring Report

– Quality Assurance study p rogram (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. 0234.0 9 )). This ICR refers only to DMR
-QA. Th erefore, the figures for burdens only s upport DMR
-QA. EPA is requesting a standard three
-ye ar clearance for this ICR. Chemical mo nitoring data for drinking water and wastewater are submitted from a variety of laboratories to the Un ited States Environmental Protection Agency ( EPA) every ye ar. T hese results mu st be relied on by EPA, as they form the primary

basis for its regulatory decisions. I n order to provide an objective dem onstration that these laboratories are submitting relia ble information, the subject Performance Evaluation (PE) studies were developed. Participation in the Discharge Monitoring Report
- Quality Assurance (DMR
-QA) studies is ma ndatory for ma jor wastewater dischargers and selected mi nor dischargers under the N ational Pollutant Discharge Elimination System (NPDES) permit. Major dischargers are defined as facilities that discharge at least 1 mi llion gallons of waste water per day a nd also those facility(s) servicing at least 10,000 hom es. Minor dischargers are selected to monitor the analytes/toxics discharged by the facility. EPA originally adm inistered the preparation of test standards for the program as part of the Agency’ s ma ndate to assure the quality of environmental mo nitoring data submitted by N PDES 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 ma ndate. P rivate sector com panies , known as Proficiency Testing (PT) providers, ma nufactu re and distribute test sam ples to the contract and in
- house laboratories . The laboratories submit their analytical results to the PT providers for evaluation. T he PT providers evaluate the submitted data and send the graded results back to the laboratori es. T hese 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. P roviders also send electronic copies of the graded resul ts to the designated certifying/enforcement authorities and to EPA. These graded results include the nam es and addresses of the laboratories, the analytes that were tested, the concentration of the analyte, and the acceptance criteria and evaluations. E PA is required to conduct this ICR analysis because mo re 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 i nformation from the PT studies to EPA, they d o not incur any

b urden under this ICR. I n 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 t he 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 ye ar over the 3
-ye ar ICR period (2011
- 13). EPA estimates that it takes 6.3 hours and costs $ 373.57 per ye ar per respondent to comply with this requirement . Respondent labor costs are linked with the time it takes to read and understand the a nnual DMR
-QA announcement sent by E PA, plan activities, analyze PT standards, report information to the PT providers, and ma intain records. Respondent operation and ma intenance (O&M) costs are associated with purchasing the PT standards. N o costs or burd ens 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 mo nitor the quality of analytical data for select critical analytes within ma jor point
-source discharge samples. Results from the PE studies over time have generally shown a slow but regular im provement in average per

formance by

t he laboratories producing the mo nitored data. B y helping laboratories identify and correct analytical problems, the PE studies are also responsible for documented im provement in th is data. Public Law 92
-500, the Federal W ater 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 ma intain am bient water quality and control point
-source disc harges. T hese mo nitoring 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 ma ny i mportant decisions upon th is data. T he data quality depends heavily u pon 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. T his will im prove 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, ma ny s uch problems will go unrecognized and unresolved. Results from the D M R
-QA studies are used to highlight N P DES 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 ma jor 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 (W P) 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

. Th e DMR
-QA study commences on or around March 15th, and concludes on or around June 30 th of each year. E PA 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 ye ars. Th e Office of Research and Development initiated and adm in istered the program until the responsibility was assigned to Office of Enforcement and Compliance Assurance (OECA). O ECA will consider any comments received and ma ke appropriate adjustments to the program
. The seven PT providers are accredited by the Ame rican 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 Provide rs were asked to give their input on the estimate for tim e burdens as well as the fees which labs need to pay for samples provided by the PT Providers. T he three PT Providers that responded indicated that it cost on average $280 to $320 per laboratory for sam ples. An average was obtained of $300 per laboratory. I t mu st be kept in mi nd that this is the cost that in
- house and contract laboratories pay, and this is passed onto the permittee. T herefore, if a lab is contracted by

s everal permittees, then EPA considers that the $300 will be distributed evenly am ong the permittees. H owever, if a permittee em ploys 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. S in ce 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. T his ratio is the same as used in the 2007 ICR. T herefore, the cost of obtaining samples i s 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 m inim um n eeded to assess the accuracy of data production required by d ischarge permits. U nder DMR
-QA, l aboratories producing data are expected to dem onstrate adequate analytical proficiency once each ye ar 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 Guideli nes This ICR was prepared in accordance with the October 2009 version of the ICR Handbook developed by

E PA's Office of Environmental Information, Office of Information Collection, Collection Strategies Division. Th e ICR Handbook provides the most current instructions for ICR preparation to ensure compliance with the 1995 Paperwork Reduction Act (PRA) Am endm ents and OMB's implementing guidelines. EPA believes participation in these studies is a reasonable requirement for all laboratories routinely produci ng data for environmental water regulation. Any p ublic 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 collectio n requirements outlined in this ICR.

### 5



## 4 THE RESPONDENTS AND THE INFORM AT ION REQUESTED 4(a) Respondents and NAICS/SIC Codes Respondents in D M R
-QA studies are N P DES permittees designated by the EPA regio n or state with permitting responsibility and the laboratories doing chemical/microbiological analysis and whole
-effluent toxicity testing for these ma jor dischargers. T hese respondents are most likely from the following SIC Codes: 2011
- through 3999
- M anufacturers 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 am ounts of specific compounds, usually dissolved in reagent water. I n D M R
-QA studies, the compounds are those of primary interest with regard to the mo nitoring requirements in the N P DES permits. All studies also collect sufficient data to properly identify

a nd cha racterize the respondents. E ach respondent reports only data for that portion of the study analytes for whic h they wish to be certified or as directed by the responsible regulatory official. 

### 4(b)(ii) Respondent Activities

The primary

b urden 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 6,5 89 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). T he commercial laboratory may d o work for ma ny permittees; the DMR
-QA results would then be sent to these permittees. T herefore, there are fewer labs than permittees. H owever, EPA does not have data on how many in
- house laboratories and contract laboratories are used. F urthermore, EPA does not track how ma ny

l aboratories participated in one or mo re studies or how ma ny permittees participated in only chemistry a nd mi crobiology and those that also participated in WET testing

. EPA is estimating the “maximum” im pact of the DMR
-QA program on the regulated community. E PA will assume that all 6,589 permittees will fulfill requirements for the top 10 chemistry &m icrobiology analytes and the top 10 WET test methods. E PA believes this ICR may overestimate the burden because not al l permittees do WET testing. ( See Appendix B for a list of the top 10 chemistry & mi crobiology 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 N PDES permittee. T his ratio was calculated based on data procured by

4PT Providers in 2006. E PA 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 i nstructions provided by EPA

.

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

.

 Analyze Chemistry

a nd Microbiology Analytes: EPA assumes that all 6,589 respondents will participate in the PT studies for mi crobiology, trace metals, dem ands, mi nerals, nutrients, and mi scellaneous 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 ma intain records associated with the PT study.

### 7



## 5 THE INFORM AT ION COLLECTED – AG ENCY ACTIVITIES, COLLECTION METHODOLOGY AND INFORM AT ION MANAGEMENT 5(a) Ag encyActivities EPA h as 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. T he testing facility will then send the analysis data of these samples to the PT Provider. T he permittee will use the form approved by OMB to report DMR
-QA results. T his form will be available in two formats: a hard copy that will be part of the announcement which is ma iled annually and an online PDF form, available on the EPA website. Th is PDF form can be filled out and then printed for subm ission. Th e 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 im pact on a substantial num ber of s ma ll entities." S ince 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 mu st dem onstrate proficiency by passing a PE study. The study typically starts on or around March 15 th and ends on or around June 30 th

. . The participating permittees’ in
- house/contract laboratories dem onstrate their proficiency by passing a PE study conducted by an accredited PT Provider for a fee. The PT Provider mu st 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 mu st report test results to the PT Provider once a year. The PT Provider mu st electronically submit the results of all studies they conduct to participating permittees and state and EPA regional coordinators

. Participating permittees mu st re-qualify for each analyte it reports one year from the last certification that it received.

### 8



## 6 ESTIM AT ING 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 l aboratories. F or this data submission, PT providers and state agencies and EPA have no burden and costs; this is discussed further in Section 6(a). T he Agency's burden and cost estimates are outlined in Section 6(c). To estimate the costs, EPA made assu mptions about the burden associated with activities that would likely be needed to fulfill the request. E PA em phasizes that the per- respondent estimates represent the average burden and cost over the 3
-ye ar period covered by this ICR (2011
-2013 ). Som e respondents may i ncur 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 tim e 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 d oes not track this information. E PA’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 perm ittees is shown in Table 6.1. PT Providers conduct the studies, removing this burden from EPA . Participating laboratories receive sam ples 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 participatin g 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 am ong three labor categories: ma nager, chemist, and records clerk. T he l abor 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

. T he burden will be evenly divided between a manager and chemist.

 Plan Activities: EPA assumes that the ma nager of each laboratory will require 0.5 hours to plan activities associated with the PT studies. The burden will be divided between a ma nager and chemist.

 Analyze Chemi stry a nd Microbi ology

Analytes : A total of 6,589 permittees are expected to use a total of 4,171 laboratories (a ratio of 0.633 lab oratories for every permittee). Analysis is assumed to require approximately 1.8 hours to analyze PT standards for the top 10 analytes. Al l hours will be incurred by achem ist. See Appendix B for these tests and the estimated time for an analysis. T hese estimates assume that the laboratory is adding a DMR
-QA sample to the normal processing that occurs in the laboratory using an already cal ibrated instrument/process.

 Analyze WET : A biologist or project ma nager constructs the test chambers and records organism mo rtality (morbidity) of test organisms while a chemist analyzes the water chemistry

. B iologists and chem ists 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. T he 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 ma intain 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 W ET 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

2Refer to Appendix B for analy sis times for Chemistry

/Microbiology

analy tes and W ET m ethods. 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 W ETanalysis. It is estimated that 4.77% of all labs participate in the W ET analysis. Collection Activities 

### Burden Total Burden (hours/y ear) Annual # Respondents 1



### 6(b) Estimating Respondent Costs Table 6. 2 shows the an nual average costs for laboratories over the 3
-ye ar 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

. E PA estimates each laboratory will incur an annu al 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 am ount of labor required to participate on an annual basis i n the DMR
-QA study

. Labor costs are based on information provided by

the U.S. Department of Labor Statistics, May 200 8 , National Industry Specific Occupational Em ployme nt and W age Estim ate. The labor categories include a ma nager 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. T he 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

t his ICR. S ince laboratories are driven by t heir compliance mo nitoring 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

p articipate in the PT studies for som e or all of the chemistry, mi crobiology analytes and WET test methods ( refer to Appendix A for a li st of chemistry

a nd mi crobiology analytes and WET test methods). The cost of the PE sam ples vari es with the costs for the analytes, mi crobiological and WET testing required for each calendar ye ar
. This is complicated by the fact that the participants in a ny g iven study

n eed not analyze all of the samples available for that study, only the ones that are required by t heir 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 ma ny a nalytes are contained in the PT sam ples sent to each laboratory, EPA assumes that a single PT sam ple contains standards for the top ten analytes for chemistry a nd mi crob iology and the top 10 W ETtest methods, based on information from the PT Providers. T herefore, laboratories participating in the chemistry a nd mi crobiology PT study a re assumed to receive and run analyses for 10 analytes. Sim ilarly, those participating i n the PT study for W ET would receive samples for each of 10 W ETtest 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 W ET $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 W age 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)(i i i) Capital/Startup Operating and Maintenance (O&M) Costs

T here are no Capital/Startup costs associated with this information collection. T he annual Operating and Maintenance costs associated with this ICR are estimated to be $190 per respondent

. 

### 6(c) Estimating AgencyBurden 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 th e tim e required to put together the annual announcement and printing and ma iling costs of the annual announcement. O n 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: 4 80 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 u se contract laboratories to perform the work, but the burden is considered to be upon the permittees, since they b ear the costs of labor and operations & maintenance. As itemized in sectio n 6(b), the annual respondent burden is 6.3 hours and $373.57 per participant. T he 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 I CR because the ir cost burden for this ICR is part of the

### 12 estimated PE sample cost burden for the laboratories

. B urden and costs to EPA is mi nim al, being lim ited 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. T his includes the bu rden 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 h as decreased from an estimated average of 7,516 to 6,589 since the last renewal of this ICR

. T his is due to EPA granting a waiver to four additional states, allowing them to em ploy 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 ren ewal of this ICR. Operation & Maintenance costs reflect the costs of obtaining PE samples from the PT Providers. T he estimated average cost of obtaining PE samples increased from $165 per respondent (permittee) to $190 per respondent. 

### 6(g ) B urden 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 mainta in record. Burden Statement : T he 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 ma intaining records. Burden means the total time, effort, or financial resources expended by p ersons to generate, ma intai n, retain, or disclose or provide information to or for a Federal agency. T his includes the

### 13 tim e needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and ma intaining information, and disclosing and providing information; adjust the existing ways to com ply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; s earch data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency may n ot 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 mi nim izing 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 , W ashington, DC. T he EPA/DC P ublic 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 num ber 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 d ocket that are available electronically. O nce 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 o r in paper, will be made ava ilable 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 m ail to the Office of Inform ation and Regulatory Affairs, Office of Manageme nt and Budget, 725 17th Street, NW , Washington, DC 20503, Attention: Desk Office for EPA. P lease include the EPA Docket ID No. EPA
- HQ
- OECA
-2010
- 0413 and OMB control num ber 2080
-0021 in any correspondence.

### 14



## AP PENDIX A: L IST OF CHEMISTRY & MICROBIOLOGY ANALYTES AND WET TEST METHODS

Microbiology Trace M etals E.coli Aluminum Fecal Coliform, MF or MPN Antim ony 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) Th allium 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 Tu rb idity 

## Chemistry

and Microbiology

Analy tes

### 15

An alyte 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% DMW25 OC 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 ) 25 OC 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 ) 25 OC 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 ) 25 OC 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



## AP PENDIX B: LIST OF TOP CHEMISTRY & MICROBIOLOGY AN ALYTES 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 Ox

ygen Demand (BOD) 45 6 Carbonaceous BOD 45 7 Copper 5 8 Total Phosphorous as P 10 9 Zinc 5 10 Oil & Grease 15 TOTA L (minutes) 173 TOTAL (hours) 2.88

1.8 hoursper 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 W ET 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 Ti me (hours) for one analy sis* Rank WETORGANISMS/TEST CONDITIONS/END POINTS CHECKLIST CHEMISTRY/MICROBIOLOGY A NALYTE CHECKLIST

Ti me (in minutes) for one analy

sis

An aly te Rank An aly te **T hese 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.