i

Information Collection Request for

Performance Evaluation Studies of 

Wastewater Laboratories 

October 2013

Prepared by:

U. S. Environmental Protection Agency

Office of Enforcement and Compliance Assurance

Office of Compliance

Monitoring, Assistance, and Media Programs Division

Water Branch

1200 Pennsylvania Ave., N.W.

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

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

4(b)(i) Data items, including recordkeeping requirements ..................................................5

4(b)(ii) Respondent Activities.......................................................................................................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(b)(i) Respondent Labor...........................................................................................................10

6(b)(ii) Respondent Operation and Maintenance Costs.......................................................10

6(b)(iii) Capital/Startup Operating and Maintenance (O&M) Costs ..................................11

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

6(d) Estimating the Respondent Universe and Total Burden and Costs............................12

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

6(f) Reasons for Change in Burden..................................................................................13

6(g) Burden Statement......................................................................................................13
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. 0234.11.

1(b) Short Characterization

This is a request to renew an existing Information Collection Request (ICR) to support the 

collection of Proficiency Testing (PT) data on the performance of laboratories that conduct 

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

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

and Wastewater Laboratories (OMB Control No. 2080-0021, EPA ICR No. 0234.10). 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 municipal dischargers are defined as facilities 

designed to discharge at least 1 million gallons of wastewater per day and also those facility(s) 

that serve a population of at least 10,000. Non-municipal major facilities are designated based on 

a numerical rating system that evaluates their significance using criteria such as toxic pollutant 

potential, flow volume and water quality factors. Minor dischargers are selected to monitor the 

analytes/toxics discharged by the facility.

EPA formerly administered and prepared test standards for the DMR-QA program as part of the 

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

permit holders (permittees). Preparation, distribution and grading of the test standards have now 

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

manufacture and distribute test samples to contract and in-house laboratories, and are known as 

Proficiency Testing (PT) providers. 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. Graded results include the names 

and addresses of the laboratories, analytes tested, concentration of the analytes, 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 this data request. 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).
2

The total annual burden and labor costs incurred by the 5,509 permittees associated with this ICR 

are estimated to be 36,361 hours and $4,176,263 per year over the 3-year ICR period (calendar 

years 2014-2016). EPA estimates that it takes 6.6 hours and costs $758.08 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 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 uses this data as the basis for many important decisions, including policy and 

regulation development, compliance and enforcement determinations, and program development. 

The data quality depends heavily upon the availability of capable laboratory analyses 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 discharges 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 onsite 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 

basis for potential regulatory enforcement. 
3

3 NONDUPLICATION, CONSULTATIONS, AND OTHER 

COLLECTION CRITERIA

3(a) Non-duplication

Data and results from other federally sponsored water quality programs, such as the Water 

Pollution (WP) program, can be used to fulfill obligations under the DMR-QA 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 July 1st of each year. As of January 1, 2013, EPA has granted 

waivers to 12 states to use their state laboratory certification program in lieu of their permittees 

participating in DMR-QA. Seven of these waivers have been granted since the last ICR was 

renewed in December 2010. 

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 July12, 2013 (78 FR 41926),

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 the 

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), and ACLASS, a 

brand of the ANSI-ASQ National Accreditation Board.

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://www.nelac-institute.org/ptproviders.php. ACLASS is 

one of three brands of the ANSI-ASQ National Accreditation Board, a non-profit, nongovernmental organization that provides accreditation services to public- and private-sector 

organizations and is jointly owned by the American National Standards Institute and the American 

Society for Quality. ACLASS provides accreditation for ISO/IEC 17043 for proficiency testing 

providers. The list of PT providers is available at http://www.aclasscorp.com/search-accreditedcompanies.aspx. 

EPA contacted the seven PT Providers and three responded. The PT Providers were asked to 

provide input on the estimated time burden for respondents as well as the fees which laboratories 

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

indicated that it costs on average $474 to $620 per laboratory for chemistry/microbiological 

samples. EPA chose to use the conservative high end estimate of $620 per laboratory for the 

purposes of estimating ICR costs to respondents. For Whole Effluent Toxicity (WET) tests, the 

range was $673 to $1,290 per laboratory, and the high end estimate of $1,290 was used. It 

should be noted that this is the cost that both 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 cost 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 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 

laboratories per permittee was used. This ratio is the same as used in the 2010 ICR. Therefore, 
4

the cost of obtaining samples is estimated to be $392 per permittee for chemistry/microbiological 

tests, and $817 for WET tests, using the ratio of 0.633 laboratories 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 per 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. 

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:

CATEGORY SIC NUMBERS NAICS NUMBERS

Manufacturers 2011 through through 3999 311611

Water Supply Systems 4941 22131

Sewerage Systems 4952 22132

Water Testing Laboratories 8734 54194

 

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. 5,509 respondents participated in the 2013 DMR-QA study. We project that this 

number of respondents will remain relatively static for the next ICR period. 

The DMR-QA program requires major permittees to submit results annually, and minor permittees 

are optionally selected for participation by the DMR-QA state coordinators. The fluctuation of

major permit holders and the selection process at the state level causes the exact number of 

permittees to vary each year. 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, as permit holders may choose to have 

commercial or in-house laboratories perform the analyses. 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 
6

the “maximum” impact of the DMR-QA program on the regulated community. EPA will assume 

that all 5,509 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 are required to perform 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 5,509 permittees participating in the DMR-QA, EPA estimates there 

are a total of 3,487 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 166 laboratories. 

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

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: 

1.Read Instructions: Each of the 5,509 respondents will read the instructions provided by EPA. 

2.Plan Activities: Each of the 5,509 respondents will incur burden to plan activities associated 

with the PT studies.

3.Analyze Chemistry and Microbiology Analytes: EPA assumes that all 5,509 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 3,487 

in-house and contract laboratories will do the work for the 5,509 permittees. 

4.Analyze WET: EPA assumes that all 5,509 permittees will participate in the PT studies for 

WET. It is assumed that 166 in-house and contract laboratories will do the work for the 

5,509 permittees. 

5.Report Results: Each of the 5,509 respondents will incur burden to report its study results to 

the PT provider. 

6.Maintain Records: Each of the 5,509 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 provides general program management support, develops guidance and maintains oversight 

of state DMR-QA activities, as well as oversight of the PT Providers and participating laboratories 

on an as-needed basis.

5(b) Collection Methodology and Management

EPA notifies 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 may 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 July 1st. 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 (2014-2016). 

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 is assumed to be a high estimate. 

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. 

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 36,361 hours, with an average of 6.6 hours per respondent 

(36,361 total hours divided by 5,509 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 5,509 respondents will require 0.5

hours to read the instructions provided by EPA. The burden will be divided between a 

manager and chemist. Sample instructions and forms can be found in the attached 

DMR-QA Study 33 package accompanying this ICR.

 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 5,509 permittees are expected 

to use a total of 3,487 laboratories (a ratio of 0.633 laboratories for every permittee). 

Analysis is assumed to require approximately 2.1 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 
9

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

standards for WET. It is assumed that 166 laboratories do this work for all 5,509

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.

 Report Results: EPA assumes that each of the 5,509 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 5,509 laboratories 

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

Table 6.1 

Estimated Annual Respondent Burdens for Proficiency Testing

Collection Activities Annual # 

Respondents1

Burden

Manager Chemist2 Record 

Clerk

Total Burden 

(hours/year)

hours /year hours 

/year

hours 

/year

Per 

Respondent 

All 

Respondents

Read Instructions 5,509 0.2 0.3 0 0.5 2,755

Plan activities 5,509 0.2 0.3 0 0.5 2,755

Analyze 

Chemistry/Microbiology 5,509 0 2.1 0 2.1 11,569

Analyze WET 5,509 0 2.4 0 2.4 13,222

Report Results 5,509 0.3 0 0.7 1 5,509

Maintain Records 5,509 0 0 0.1 0.1 551

Total 5,509 36,361

Total Annual # Responses: 5,509 Avg. Labor (hours) per Respondent: 6.6 

1

In 2013 it is estimated that 5,509 NPDES permittees participated 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.

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

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 5,509 permittees are estimated to be $1,799,625. Average annual O&M 

costs are estimated to be $2,376,638. EPA estimates each laboratory will incur an annual 

average labor plus non-labor cost of $846.78 for this data collection effort. (see Table 6.2).
10

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 2012, National Industry Specific Occupational Employment 

and Wage Estimate. The labor categories include a manager at an hourly rate of $55.64, a data 

entry clerical person at an hourly rate of $17.19, and a skilled technician or chemist to conduct 

the measurements at an hourly rate of $34.50. Table 6.2 lists the estimated burden and costs for 

labor related to each activity. The annual respondent labor cost, for all 5,509 respondents is 

estimated to be $1,799,625 for 36,361 hours. The labor costs take into account benefits/

compensation in addition to salary. EPA estimates the benefits/compensation to be 30% of total 

compensation, or 42.9% of salary.

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 $681.53 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 $681.53 per laboratory and 

$431.41 per permittee (respondent). Average annual O&M costs (fees for PE samples) for the 

respondents is estimated to be $2,376,638.
11

Table 6.2 

Estimated Annual Respondent Costs for Proficiency Testing

Collection 

Activities

Labor Cost 1 Non-Labor Cost Labor Plus NonLabor

Manager 2 Chemist 3 Record 

Clerk 4 Labor Costs Cost of Standards per PT Analysis5

Average Labor plus NonLabor Costs

at 

$55.64/hr

at 

$34.50/hr

at 

$17.19/

hr

per 

Respondent

All 

Respondents

per 

Respondent

All 

Respondents

per 

Respondent

All 

Respondents

Read 

Instructions $15.90 $14.79 $0.00 $30.69 $169,071.21 $0 $0 $30.69 $169,071.21

Plan activities $15.90 $14.79 $0.00 $30.69 $169,071.21 $0 $0 $30.69 $169,071.21

Analyze 

Chemistry and 

Microbiology

$0.00 $103.50 $0.00 $103.50 $570,181.50 $392.46 $2,162,062.14 $495.96 $2,732,243.64

Analyze WET $0.00 $118.29 $0.00 $118.29 $651,659.61 $38.95 $214,577.69 $157.24 $866,237.30

Report Results $23.85 $0.00 $17.19 $41.04 $226,089.36 $0 $0 $41.04 $226,089.36

Maintain 

Records $0.00 $0.00 $2.46 $2.46 $13,552.14 $0 $0 $2.46 $13,552.14

Total $326.67 $1,799,625 $431.41 $2,376,638 $758.08 $4,176,265

1 Median salaries from U.S. Bureau of Labor Statistics (BLS), May 2012, National Industry Specific Occupational Employment 

and Wage Estimates (http://www.bls.gov/oes/). These are loaded rates which include benefits estimated at 30% of total 

compensation, or 42.9% of applicable wages. As a percentage of total compensation, BLS estimates benefits to be 29.8% for 

management positions, 32.2% for natural resource positions and 28.7% for office positions. 

http://www.bls.gov/news.release/ecec.t05.htm.

2 U.S. Department of Labor Statistics, Natural Science Manager 11-9121. ($55.64).

3 U.S. Department of Labor Statistics, Chemist 19-2031. ($34.50).

4 U.S. Department of Labor Statistics, Information and Record Clerk 43-4199. ($17.19).

5 Uses estimated cost of $620 per chem/micro lab and $1,290 per WET lab. Includes a factor of 0.633 labs per respondent. 

WET analysis is multiplied by .0477 since only 4.77% of all labs perform WET tests. Therefore, the average cost spread out 

over all respondents is $1,290 * 0.633 * .0477 = $38.95.

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 $431.41 per 

respondent. 

6(c) Estimating Agency Burden and Costs

EPA’s role is advisory and involves program management only. The burden to the Agency, other 

than the time required to put together the annual announcement and printing and mailing costs of 

the annual announcement is low. On average, 3,750 announcements are printed annually to 

send out to permittees, PT Providers, state and regional coordinators as well as spare copies. 
12

This annual average is also a conservative estimate because in 2013 EPA began distributing 

announcements by e-mail when possible. 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 3,750 announcements: $2,400

 Cost of mailing announcements: $4,200

 Total annual burden and cost to EPA: 560 hours and $6,600

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

The respondents for this ICR are major and select minor NPDES permittees. Some or all 

permittees in states that have received EPA waivers from the DMR-QA program may not be 

required to participate. Permittees who participate 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 6.6

hours and $846.78 per participant. The total annual respondent burden is 36,361 hours and 

$4,176,263 for 5,509 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 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 $6,600 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 5,509 respondents that are affected by this ICR.

Table 6.3 

Bottom Line Burden and Costs for ICR period (2014-16)

Cost / Burden Total Across Three 

ICR Years (2014-2016)

Average Per Year over 

ICR Years (2014-2016)

Number of Respondents (Permittees) 5,509 5,509

Total Responses 16,527 5,509

Number of Responses per Permittee 3 1

Burden Hours per Permittee 19.8 6.6

Total Burden Hours (all 5,509 Permittees) 109,078 36,361

Per Permittee Labor Costs $980.01 $326.67 

Total Labor Costs (all 5,509 Permittees) $5,398,875 $1,799,625 

Per Permittee O&M Costs $1,294.23 $431.41 

Total O&M Costs (all 5,509 Permittees) $7,129,913 $2,376,638 

Total Costs (Labor plus O&M costs for all 5,509 

permittees) $12,528,788 $4,176,263 
13

6(f) Reasons for Change in Burden

Participation in the DMR-QA PE study has decreased from an estimated average of 6,589 to 

5,509 since the last renewal of this ICR. This is due to EPA granting a waiver to seven additional 

states, allowing them to employ their state laboratory certification program as a full or partial 

substitute for the federal DMR-QA program. 

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

Labor costs in the 2010 ICR mentioned but did not include fringe benefits/compensation. The

addition of these costs coupled with inflation resulted in an increase in the labor cost for 2013, 

although the total burden hours decreased by approximately 5,150 hours. Operation & 

Maintenance costs reflect the costs of obtaining PE samples from the PT Providers. The 

estimated average cost of obtaining PE samples increased from $190 per respondent (permittee) 

to $431 per respondent. This increase is due to increased cost and two new analytes added to 

the top ten list of most common analytes. The new analytes are expensive compared to those 

they replaced. 

6(g) Burden Statement

The average annual respondent burden for each permittee is estimated to be 6.6 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 calendar years 2014 – 2016) imposed by these 

collections is estimated to be 36,361 hours, or 6.6 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 

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-2013-0547, 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 
14

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-2013-0547 and OMB control 

number 2080-0021 in any correspondence. 
15

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
16

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 
17

APPENDIX B: LIST OF TOP CHEMISTRY & MICROBIOLOGY 

ANALYTES AND WET TEST METHODS AND TIMES FOR ANALYZING

CHEMISTRY/MICROBIOLOGY ANALYTE CHECKLIST

Rank Analyte Time (in minutes) 

for one analysis

**These estimates 

assume the DMR-QA

sample is being 

added as additional 

single analyses to 

an already calibrated 

instrument/process, 

and to the normal 

processing that 

occurs in the 

laboratory. 

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 Total Phosphorous as P 10

8 Settleable Solids 10

9 Fecal Coliform (MF) 30 -> 24 hours for 

incubation 10 Oil and Grease 15

TOTAL (minutes) 203

TOTAL (hours) 3.38

2.1 hours per permittee for Chemistry/Microbiology

using ratio of 0.633 labs per permittee

WET ORGANISMS/TEST CONDITIONS/END POINTS CHECKLIST

Rank Analyte Time (hours) for 

one analysis*

type of 

test

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

because only 4.77% of labs do WET analyses, the following number 

will be used for time burden for WET tests:

 2.4 hours for WET analysis