# Information Collection **Request for the Public Water Sy** **stem Supervision**  **Program**i **TABLE OF CONTENTS**  1 ID ENTIFICATION OF THE INFORMATION COLLECTION

................................ ........... 1 1(a) Title and Number of the Information Collection

................................ ............................. 1 1(b) Short Characterization

................................ ................................ ................................ ...... 1 2( a) Need/Authority for the Collection

................................ ................................ .................... 4 2(b) Use/Users of the Data

................................ ................................ ................................ ..... 10 3 NON

- DUPLICATION, CONSUL TAT IONS, AND OTHER COLLECTION CRI TERIA 11 3(a) Non
- duplication

................................ ................................ ................................ .............. 11 3(b) Public Notice Required Prior to I CR Submission to OMB

................................ ............ 11 3(c) Consultations

................................ ................................ ................................ .................. 11 3(d) Effects of Less Frequent Collection

................................ ................................ ............... 11 3(e) General Guidelines

................................ ................................ ................................ ......... 11 3(f) Confidentiality

................................ ................................ ................................ ................ 12 3(g) S ensitive Questions

................................ ................................ ................................ ........ 12 4 RESPONDENTS AND INFORMATION REQUESTED

................................ .................... 13 4(a) Respondents/North American Industry Classification System (NAICS) Codes

........... 13 4(b) In formation Requested

................................ ................................ ................................ ... 13 4(b)(i) Data Items

................................ ................................ ................................ ........... 13 4(b)(ii) Respondent Activities

................................ ................................ ........................ 22 5 IN FORMAT ION COLLECTED

-- AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT

................................ .......... 29 5(a) Agency

Activities

................................ ................................ ................................ ........... 29 5(b) Collection Methodology and Management

................................ ................................ .... 31 5(c) Small Entity

Flexibility

................................ ................................ ................................ .. 31 5(d) Collection Schedule

................................ ................................ ................................ ........ 33 6 ESTIMATING BURDEN AND COST OF COLLECTION

................................ ................ 34 6(a) Respondent Burden

................................ ................................ ................................ ........ 34 6(a)(i) Burden to Public Water Sy stems
................................ ................................ ..... 34 6(a)(ii) Burden to Primacy Agencies

................................ ................................ ............. 39 6(a)(iii) Burden to Laboratories

................................ ................................ .................. 42 6(b) Respondent Costs

................................ ................................ ................................ ........... 43 6(b)(i) Cost to Public Water Sy stems
................................ ................................ ........... 43 6(b)(ii) Cost to Primacy

Agencies

................................ ................................ ................ 44 6(b)(iii) Cost to L aboratories

................................ ................................ ........................ 44 6(c) Agency

Burden and Costs

................................ ................................ .............................. 46 6(d) Estimating Respondent Universe and Total Burden and Costs

................................ ...... 48 6(e) Bottom Line Burden Hours and Costs

................................ ................................ ........... 48 6(f) Reasons for Change in Burden

................................ ................................ ....................... 50 6(f)(i) Restructuring Adjustments

................................ ................................ .............. 50 6(f)(ii) Additional Program Adjustments

................................ ................................ .... 51 6(g) Burden Statement

................................ ................................ ................................ ........... 54ii **APPENDICES** Appendix A. Federal Register Notice Soliciting Comment on Information Collection Requests Appendix B. Consumer Confidence R eports Spreadsheets Appendix C. Variances and Exemptions Spreadsheets Appendix D
. Capacity

Development Spreadsheets Appendix E
. General State Primacy Spreadsheets Appendix F
. Public Notification Rule Spreadsheets Appendix G

. Operator Certification Program Spreadsheets Appendix H
. Tribal Drinking Water Operator Certification Program Spreadsheets Appendix I
. Proficien cy Testing Spreadsheetsiii **LIST OF EXHIBITS** Exhibit 1: Structure of OGWDW ICRs

................................ ................................ ................... 6 Exhibit 2: PWS Recordkeeping and Reporting Requirements

................................ .............. 14 Exhibit 3: Primacy

Agency Recordkeeping and Reporting Requirements

............................ 17 Exhibit 4: Laboratories Recordkeeping and Reporting Requirement s ................................ .. 2 3 Exhibit 5: PWSS Program Requirements for EPA Regions and Headquarters

..................... 29 Exhibit 6: Annual PWS Burden and Cost (November 1, 201 5 to October 31, 201 8 )

........... 45 Exhibit 7: Annual State Burden and Cost (November 1, 2015 to October 31, 2018 )

........... 45 Exhibit 8: Annual Laboratory Burden and Cost (November 1, 2015 to October 31, 2018 )

.. 46 Exhibit 9: Bottom Li ne Annual Burden and Cost (November 1, 2015 to October 31, 2018 )

. 49 Exhibit 10: Summary

of Changes in Annual Burden

................................ .............................. 50 Exhibit 11: Restructuring Adjustments to the Annual Burden Inventory

for the PWSS Program ICR

................................ ................................ .................. 50 Exhibit 12: Adjustments to PWS Burden from Previous ICR Estimates

................................ 51 Exhibit 13: Adjustments to Primacy Agency Burden from Previ ous I CR Estimates

.............. 52 Exhibit 14: Adjustments to Laboratory Burden from Previous ICR Estimates

....................... 53 Exhibit 15: Adjustments to Activities Carried Forward from Previous I CRs

......................... 53

Th is imiv **LIST OF FIGURES** Figure 1: Structure of OGWDW ICRs

............................................................... 5v **ACRONYMS** AG Attorney General AMWA Association of Metropolitan Water Agencies ASDWA Association of State Drinking Water Administrators AWWA American Water Works Association CCR Consumer Confidence Report CDC Centers for Disease Control and Prevention CFR Code of Federal Regulations CWS Community Water S ys tem DBP Disinfection By product DBPR Disinfectants and Disinfection By products Rule DDBP/Chem/Rads Disinfectant/Disinfection By products, Chemical, and Radionuclides DWI G TSA Drinking Water Infrastructure Grant Tribal Set Aside DWSRF Drinking Water State Revolving Fund EPA Environmental Protection Agency ERP Enforcement Response Po licy ETT Enforcement Targeting Tool FR Federal Register FTE Full Time Equivalent GWR Ground Water Rule ICR In formation Collection Request IESWTR Interim Enhanced Surface Water Treatment Rule LCR Lead and Copper Rule LT1ESWTR Long Term 1 Enhanced Surface Water Treatment Rule LT2ESWTR Long Term 2 Enhanced Surface Water Treatment Rule MCL Maximum Contaminant Level MCL G Maximum Contaminant Level Goal MRDL Maximum Residual Disinfection Level MRDL G Maximum Residual Disinfection Level Goal NAI CS North American Industry Classification System NAWA Native American Water Association NAWC National Association of Water Companies NCWS Noncommunity Water Sy stem NDWAC National Drinking Water Advisory Council NPDWR National Primary Drinking Water Regulation NRWA National Rural Water Association NTEC National Tribal Environmental Council NTNCWS Nontransient Noncommunity Water Sy stem O&M Operation and Maintenance OGWDW Office of Ground Water and Drinking Water OMB Office of Man agement and Budget PC&B Personnel Compensation and Benefits PN Public Notification PRA Paperwork Reduction Act PT Proficiency Testingvi

PWS Public Water System PWSS Public Water System Supervision RTCR Revised Total Coliform Rule SBREFA Small Business Regulatory Enforcement Fairness Act SDWA Safe Drinking Water Act SDWI S Safe Drinking Water Information Sy stem SMCL Secondary Maximum Contaminant L evel SWAP Source Water Assessment Program SWTR Surface Water Treatment Rule TCR Total Coliform Rule TNCWS Transient Noncommunity Water S ys tem UCMR Unregulated Contaminant Monitoring Rule UI C Underground Injection Control V/E Variance and ExemptionPublic Water Systems Supervision Program ICR October 2015

1 

### 1 **IDENTIFICATION OF THE INFORMATION COLLECTION 1(a)**  **Title and Number of the Information Collection**  Title: Public Water System Supervision Program OMB Control Number: 2040

- 0090 EPA Tracking Number: 0270. 4 6 **1(b) Short Characterization**  The Office of Ground Water and Drinking Water (OGWDW) in the Office of Water at the United States Environmental Protection Agency (EPA ) is responsible for managing the Public Water System Supervision (PWSS) Program, a national program mandated by the Safe Drinking Water Act (SDWA). Section 1412 of the SDWA requires EPA to establish National Primary Drinking Water Regulations (NPDWRs) for contaminants that may adversel y impact human health. The Act requires EPA to monitor and enforce these regulations to ensure that the nation’s drinking water dependabl y complies with the maximum contaminant levels (MCL s) and other requirements stipulated in the Code of Federal Regulations (CFR), 40 CFR Part 141, Subpart B. Section 1445 of the SDWA states that public water systems (PWS) shall conduct monitoring, maintain record s, and provide information as needed for EPA to implement its monitoring and enforcement responsibilities with respect to the Act. Primacy agencies

– EPA and state governments that have assumed primary enforcement responsibility under SDWA s ection 1413

– e nsure that PWSs are complying with these monitoring requirements. In addition, under 40 CFR sections 141.23(k)(3), 141.131(b)(2), 141.28, and 141.24(f)(17), laboratories must successfull y participate in Proficiency Testing (PT) studies each ye ar to be certified to conduct anal ys is of compliance monitoring samples. As part of the PWSS Program, OGWDW uses the Safe Drinking Water Information Sy stem (SDWI S) to record some of the data collected as a result of NPDWR requirements. These data assist EPA in fulfilling its SDWA obligations. SDWI S is a database management sy stem that assists EPA in tracking and interpreting violations data and other program

- related dat a. R evisions are currently being made to SDWIS . EPA expects primacy agencies to full y transition to the revised system , a centralized, cloud

- based s ys tem called SDWI S Prime , in the subsequent I CR period. Many information collection requirements associate d with the SDWA and its implementing regulations are associated with rulemakings that address specific contaminants or groups of contaminants. This I CR examines PWS, primacy agency , laboratory , and EPA burden and costs for “cross

- cutting” recordkeeping and reporting requirements (i.e., the burden and costs for compl yi ng with drinking water information requirements that are not associated with contaminant

- specific rulemakings). These activities are listed below.

1) Consumer Confidence Reports (CCRs)Public Water Systems Supervision Program ICR October 2015

2 2) Variance and Exemption Rule (V/E Rule) 1 3) Capacity

Development Program 4) General State Primacy Activities 5) Public Notification (PN) 6) Operator Certification Program 7) Tribal Drinking Water Operator Certification Program 8) Constructed Conveyances 2 9) Proficiency

Testing (PT) This I CR updates the burden and cost estimates provided in the 2012 PWSS Program ICR, which expires on October 31, 2015

. The IC R estimates costs for November 1, 2015 to October 31, 2018

. The total annual respondent burden associated w ith this I CR is esti mated to be approximately 3.8 million hours per year. T he total annual respondent cost associated with this ICR is estimated to be approximately $ 187.6 million. The distribution of annual burden between PWSs and primacy

agencies is approximately 2. 2 millio n hours and 1. 5 million hours, respectivel y. Laboratories conducting PT incur an annual burden of 42,892 hours. The distribution of annual costs between PWSs and primacy agencies is approximate ly $ 11 3.8 million and $ 70.1 million, respectivel y. The annual costs for laboratories conducting PT are $ 3. 7 million

. The approximate annual operation and maintenance (O&M) costs for respondents are $ 4 2 million , with $ 41 million for PWSs , $ 0. 82 million for laboratories, and no O&M costs for primacy agenc ies

. This represents the “cost burden” as reported in the OMB inventory

. T hese costs are for O&M only

. T here are no capital costs associated with the activities covered b y this ICR. The annual EPA burden for this I CR totals 0.5 2 million hours, at a cost of approximately $2 5.0 million; 0. 09 million hours , approximately $ 5.7 million , is for Headquarters activities and 0. 4 3 million hours , approximately $ 19 million , is for EPA Regional office activities. The Agency also incurs $ 450,000 annually in O&M costs for EPA contractors to manage and maintain the SDWI S database

. 3 The total number of respondents for this I CR is 1 5 1,724 ; 57 of these respondents are primacy agencies , 1 , 902 are laboratories, and the balance , 1 49 , 765 , are PWSs

. The total annual number of responses for these respondents is 1 .0 million ( 3 50 , 773 for PWSs , 1 , 902 for laboratories, and 6 88 , 047 for primacy agencies).

1 No new V/Es are expected in this 3

- year ICR period, therefore EPA estimates PWS and primacy agency burden and costs associated with this rule to be negligible in this 3

- year ICR period. The V/E rule is still included in the PWSS Program, and therefore text and detailed calculations in appendix form that summarize reporting and recordkeeping requirements related to the V/E program are still included in this ICR. 2 No new constructed conveyances are expected to be built going forward, therefore EPA estimate s PWS and primacy agency burden and costs associated with this program to be negligible. The Constructed Conveyances program is still included in the PWSS Program, and therefore text summarizing reporting and recordkeeping requirements related to the Constructed Conveyances program have not been removed from this ICR. However, detailed calculations previously provided in appendix form are no longer included in this ICR. 3 O&M costs incurred by EPA for management of SDWIS by contractors based on office expe nses for FY14.Public Water Systems Supervision Program ICR October 2015

3Public Water Systems Supervision Program ICR October 2015

4 

### 2 **NEED FOR AND USE OF THE COLLECTION 2(a)**  **Need/Authority for the Collection** This section identifies the regulatory authority for the information collection activities covered in this ICR and explains EPA ’s need for the information. Section 4 of the I CR contains a summary of the PWSS Program recordkeeping and reporting requirements covered b y this ICR. To allow the public to better understand the impact of the recordkeeping and reporting requirements ste mming from the SDWA and 40 CFR Parts 141 and 142, OGWDW has organized its I CRs so that related activities are addressed in the s ame IC R. Specificall y, there are three primary

I CRs

—the Microbial Rules I CR, the Disinfectants/Disinfection By products, Chemical and Radionuclides Rules (DDBP/Chem/Rads Rules) I CR, and the PWSS Program ICR. The Microbial Rules I CR includes rules addressing microbial contaminants, such as the Revised Total Coliform Rule ( RTCR), Surface Water Treatment Rule (SWTR), and the Ground Water Rule ( GWR). The DDBP/Chem/Rads Rules I CR includes rules addressing chemical contaminants such as the Stage 2 Disinfectants and Disinfection By product s Rule (Stage 2 DBPR), the Arsenic Rule, and the Lead and Copper Rule (L CR). The PWSS Program ICR includes public notification and rules addressing cross

- cutting requirements that are not associated with contaminant

- specific rule s . Without this information collection, EPA would not be able to effectively

implement the national drinking water program. The specific regulations and programs addressed in this I CR are listed below.

1) Consumer Confidence Reports 2) Variance and Exemption Rule 3) Capacity

Development Program 4) General State Primacy Activities 5) Public Notification 6) Operator Certification Program 7) Tribal Drinking Water Operator Certification Program 8) Constructed Conveyances 9) Proficiency

Testing For a graphical depiction of the structure of the OGWDW I CRs, see Figure 1. A complete itemization of the activities included in the three primary I CRs, as well as other drinking water program ICRs, is included as Exhibit 1.Public Water Systems Supervision Program ICR October 2015

5 Green = Activities rem ain as in current ICR Purple = Future rule to be addressed in stand
- alone ICR 

### Figure 1. Structure of OGWDW **ICRs**

**DDBP/Chem/Rads Rules ICR**

**2040 -**  **0204** Stage 1 Chems LCR 3
Arsenic Stage 2

Rads Lab QA 2040
- 0246 Needs Survey

2040
- 0274 DW S RF 2040
- 0185 SWAP 2040
- 0197 Bioterrorism

2040
- 0253

UCMR 3 2040
- 0270 **UIC Program ICR 2040**  **- 0042**  Classes I
- VI **PWSS Program ICR** 

**2040 -**  **0090**

Cap Dev

V&E’s Proficiency Te sting
PN CCRs State Primacy Activities

Op Cert Tribal

Op Cert Constructed

Conv eyances

1 RTCR burden and costs incurred after April 2016 are being added to TCR. 2 DDBP/Chem/Rads Rules ICR includes disinfectant residual moni toring under SW TR 3 Includes LCR Short
- Te rm Revisions **Microbial Rules ICR** 

**2040 -**  **0205**

IE SW TR SW TR 2
LT 1 FBRR TCR/

RT CR 1

GW R
LT 2 ADW R UCMR 4 2040
- 0270Public Water Systems Supervision Program ICR October 2015

6 **Exhibit 1: Structure of OGWDW ICRs Currently covered**  **To be covered in the future PWSS Program ICR (2040**  **- 0090)**  Consumer Confidence Reports (CCRs) Variances & Exemptions Capacity Development Program General State Primacy Activities Public Notification (PN) Operator Certification Program Tribal Operator Certification Constructed Conveyances Proficienc y T esting **Microbial Rules ICR (2040 -**  **0205)** Surface Wa ter Treatment Rule, except disinfectant residual monitoring and associated activities 4 Total Coliform Rule/ Revised Total Coliform Rule Interim Enhanced Surface W ater Treatm ent Rule (IESW TR) Filter Backwash Recycling Rule Long Term 1 Enhanced Surface Wa ter Treatment Rule (LT1ESW TR) Long Term 2 Enhanced Surface Wa ter Treatment Rule (LT2ESW TR) Ground W ater Rule Aircraft Drinking W ater Rule **Disinfectants/Disinfection Byproducts, Chemical, and Radionuclides Rules ICR (2040 -**  **0204)** Stage 1 Disinfectants and Disinfection By products Rule Lead and Copper Rule Long Term Revisions Disinfectant Residual Monitoring and associated activities under the S WT R Stage 2 Disinfectants and Disinfection Byproducts Rule Chemical Phase Rules Radionuclides Rule Arsenic Rule Lead and Copper Rule **Source Water A ssessment Program (SW**  **AP) ICR (2040 -**  **0197)** SW AP **Underground Injection Control (UIC) Program ICR (2040 -**  **0042)** UIC Base Program Activities Classes I
- VI Rule s Florida Class I Rule **Drinking Water State Revolving Fund (DWSRF) Program ICR (2040**  **- 0185)**  Drinking W ater State Revolving Fund Program

4 Disinfectant residual monitoring and associated activities are included in the DDBP/Chem/Rads Rules ICR.Public Water Systems Supervision Program ICR October 2015

7 **Currently covered To be covered in the future**  **Drinking Water Infrastructure Needs Survey ICR (2040 -**  **0274)** Drinking W ater Infrastructure Needs Survey **Title VI of the Public Health Security and Bioterrorism Preparedness and Response A** **ct of 2002: Drinking Water Security and Safety ICR (2040**  **- 0253)**  Vulnerability Assessments and Emergency Response Plans for community water systems (CWS s). **Unregulated Contaminant Monitoring Rule ICR (2040 -**  **0270)** Monitoring of Unregulated Contaminants (UCMR 3) UCMR 4 **Laboratory Quality A ssurance Evaluation Program for A**  **nalysis of Cryptosporidium ICR (2040 -**  **0246)** Proficienc y T esting Program for Laboratories Analyzing Cryptosporidium Samples 1) Consumer Confidence Reports Section 114 of the 1996 SDWA amends section 1414(c) of the Act. The amendments require CWSs to provide CCRs to their customers annually describing the quality of the finished water. EPA wrote regulations under Subpart O of 40 CFR Part 141 to implement this provision. The initial Federal Register (FR) notice containing CCR requirements was published on August 19, 1998 (63 FR 44512). These initial requirements have since been modified by other rulemaking efforts

. O ther rule makings are assumed to have no effect on the underlying burden. 2) Variance and Exemption Rule The 1996 SDWA Amendments established criteria under which PWSs, especially those serving 10,000 or fewer people, could appl y for a variance or exemption. Variances allow e ligible s ys tems to provide drinking water that does not comply with a NPDWR on the condition that the quality

of the drinking water is still protective of public health. Exemptions allow PWSs additional time beyond that specified in rule requirements to co me into compliance. There are two ty pes of variances: 1) g eneral variances are intended for s ys tems that are not able to compl y with a NPDWR due to the quality of the source water , and 2) small sy stem variances are intended for s ys tems serving 3,300 or few er people that cannot afford to comply with a NPDWR. Small system variances are only allowed if EPA designates a Small Sy stem Variance Technology

. The information required of PWSs seeking general variances, small sy stem variances , or exemptions is needed t o determine if the sy stem satisfies SDWA conditions for variances or exemptions.Public Water Systems Supervision Program ICR October 2015

8 3) Capacity Development Program Through the 1996 SDWA Amendments, Congress conveyed the importance of PWSs to maintain technical, managerial, and financial capacity to compl y with the requirements of the SDWA. To encourage States to establish and maintain a capacity development program, section 1420(a) of the SDWA linked the capacity development program to the Drinking Water State Revolving Fund (DWSRF) by stating that a state is subject to a 20 percent withholding of the funds if the state elects not to implement the program. 4) General State Primacy Activities To implement its compliance oversight and enforcement responsibilities under the SDWA, EPA requires primacy agencies to report a specified subset of PWS monitoring and related information in SDWI S. Additionally , primacy agencies must maintain records of anal ys is results and other related activities (e.g., sanitary survey results). Without comprehensive, up

- to
date inform ation on drinking water contamination), EPA would not be able to en sure “ a supply of drinking water which dependabl y complies with such maximum contaminant levels” (SDWA section 1401(1)(d)). If these reporting requirements were voluntary , EPA would not rec eive timely , comprehensive data on contaminant levels and associated acute and long

- term public health risks. Specificall y, voluntary monitoring would no t:

 Reliably

occur with sufficient frequency

.  Follow uniform national standards on quality of samplin g, collection, and anal ys is.  Ensure that monitoring addresses all contaminants listed in the regulations. 5) Public Notification Section 114 of the 1996 SDWA Amendments required the EPA Administrator to develop and issue new regulations for public notification of PWS failure to comply with applicable national drinking water standards. Regulations mandating the form, manner, frequency , and content of public notification are codified under 40 CFR Part 141, Subpart Q. Sections 1414(c)(2)(C)(ii) and 1414(c)(2)(D )(ii) of the 1996 Amendments require that notices provide a clear and understandable explanation of the violation, the potential adverse health effects, steps that the sy stem is taking to correct the violation, and necessity of seeking alternative water su pplies until the violation is corrected. Without the ability to collect information on public notification, EPA could not ensure that PWSs were notifying the public of violations that could affect their health. 6) Operator Certification Program Through out the 1996 SDWA Amendments, Congress conveyed the importance of properl y trained operators in providing safe drinking water to the public. Congress then established the Operator Certification Program to ensure that PWSs were being operated by properl y train ed and certified personnel

. To underscore the importance of operator certification, the o p erator c ert ification program was linked to the DWSRF through a withholding of 20 percent of the funds that a state is otherwise entitled to if its program does not me et EPA’s guidelines.Public Water Systems Supervision Program ICR October 2015

9 EPA still requires the submission of annual operator certification reports from states. T he information collected under this program will continue to ensure that states are implementing operator certification programs that meet EPA guidelines. 7) Tribal Drinking W ater Operator Certification Program The purpose of the Tribal Drinking Water Operator Certification Program is to improve public health protection by increasing the training and certification opportunities for personnel at drinking water s ys tems in Indian Country

. The program guidelines establish seven baseline standards. The guidelines also list requirements for organizations that wish to obtain EPA approval for their certification programs. EPA regulations require qualifie d operators for all PWSs except transient noncommunity water s ys tems (TNCWSs) served b y ground water (see 40 CFR 141.70(c) and 40 CFR 141.130(c))

. In addition, a public water s ys tems must be have a certified operator to be eligible for D rinking W ater Infrastructure Grants
- T ribal S et
- A side funds

. The tribal public water supervision program and the tribal drinking water operator certification program provide funding for the training and certification of tribal drinking water operators. 8) Constructed Conveyances In the 1996 Amendments to the SDWA, Section 1401(4) broadened the definition of “public water s ys tem” to include sy stems that provide water for human consumption and deliver the water via constructed conveyances. Prior to this change, PWSs include d only piped water sy stems. This new definition affects the rep orting and recordkeeping burden 5 for both PWSs and states. 9) Proficiency Testing T he SDWA requires EPA to specify contaminants that may

adversel y affect public health when present in PWSs, specify MCL s for these contaminants, and publish “ criteria and procedures to assure a supply of drinking water which dependabl y complies with such maximum contaminant levels. ” Participation in the PT studies that relate to drinking water anal ys es is mandate d in 40 CFR sections 141.23(k)(3), 141.24(f)(17), 141.28 , and 141.131(b)(2) for those laboratories that report data to support PWS compliance with the NPDWRs. Under 40 CFR 142.10(b)(3), authority

for certifying drinking water laboratories is provided to s t ates
. In the PT program, private sector companies (i.e., PT vendors) manufacture and distribute samples of regulated contaminants , also called standards, to the participating laboratories . The vendors know the concentrations of the standards but the laboratories do not. The laboratories determine the concentrations of each anal yt e for which they wish to be certified and then submit their results to the vendors. Assuming the laboratories’ results are accurate, PT vendors certify to the s tate that the laboratories have successfull y completed their PT studies. This certification of PT study completion is then used by the states to support the certification of the laboratories to conduct drinking water compliance anal ys es. EPA, state s, and laborat ory personnel will use the

5 Based on EPA best professional judgment and drinking water industry consultation results, no new constructed conveyances are expect ed to be bui lt going forward. Therefore, reporting and recordkeeping burden for PWSs and primacy agencies to comply with the Constructed Conveyances program is assumed to be negligible.Public Water Systems Supervision Program ICR October 2015

10 results of these studies to identify laboratory

problems for resolution, and thereby improve the quality of data used to determine regulatory compliance

. **2(b) Use/Users of the Data**  The information described in the previous se ctions will be collected by EPA and made available to the public upon request, as required by the Freedom of Information Act (40 CFR, Chapter 1, Part 2). In some cases, the SDWA requires that the information be provided to the public or the primacy

agency . Primary

users of the data collected under this I CR are OGWDW, PWS managers, and primacy agencies, which include state regulators, Indian Tribes, and, in some instances, EPA Regional Administrators. Other users include :

 Laboratory

personnel

 Staff from other EPA programs (such as Superfund, the Resource Conservation and Recovery

Act, and the Office of Enforcement and Compliance Assurance (OECA) )

 Federal Emergency

Management Administration

 Centers for Disease Control and Prevention (CDC)

 Military

bases

 Farmers Home Administration

 Department of Interior

 Department of Housing and Urban Development

 U.S. Army

Corps of Engineers

 White House Task Forces

 American Water Works Association (AWWA)

 Association of Metropolitan Water Agencies (AMWA)

 National Rural Water Association (NRWA)

 National Association of Water Companies (NAWC)

 Association of State Drinking Water Administrators (ASDWA)

 Natural Resources Defense Council

 Consumers Federation of America

 News o rganizations

 Native American Water Association (NAWA)

 Asso ciation of American Indian Affairs

 Inter
- tribal Environmental Council

 National Tribal Environmental Council (NTEC)

 Other intertribal groupsPublic Water Systems Supervision Program ICR October 2015

11 

### 3 **NON -**  **DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA**  **3(a) Non**  **- duplication**  EPA has made an effort to ensure that the data collection efforts associated with this I CR are not duplicated. EPA has consulted with s tate environmental programs, other f ederal agencies and regulated entities , such as PWSs and their representative trade associations. To the be st of EPA's knowledge, data currentl y required b y the SDWA , and its implementing regulations codified at 40 CFR Parts 141 and 142 , are not available from any other source. **3(b) Public Notice Required Prior to ICR Submission to OMB**  Public comments were previously requested via the Federal Register (80 FR 17040) on March 31, 2015 for a 60

- day period. Specificall y, EPA published a notice in the Federal Register (FR) requesting comment on the estimated respondent burden and other aspects of this I CR (Appendix A). EPA did not receive any comments during the 60

- day comment period. An additional FR notice will be published prior to submission of this I CR to OMB. The public comment period for this additional notice is 30 day s. **3(c) Consultations**  As part of the revision of the PWSS I CR, in May 2015 EPA consulted with representatives of PWSs and s tates regarding the accuracy of EPA’s burden estimates. The groups consulted were NAWC, NRWA, AWWA, AMWA, and ASDWA. EPA received comments from ASDWA

. ASDWA’s comments were incorporated into this I CR to the extent possible. The end of each appendix to the I CR contains a table summarizing EPA’s previous and revised burden estimates for the relevant rule. **3(d) Effects of Less Frequent Collection**  EPA has co nsidered a wide range of alternatives for frequency of data collection

. The CCR Rule and Capacity

Development Program require annual reporting. Distributing CCRs less frequentl y than annuall y is not allowed under the SDWA. Annual reporting of capacity deve lopment information is essential to enable EPA to make withholding determinations on each fiscal year’s funds. Laboratories producing drinking water compliance monitoring data are expected to demonstrate adequate anal yt ical proficiency once each year for e ach anal yt e they test. Any decrease in frequency

would not adequately

support state laboratory certification/evaluation programs. For other information collection activities, EPA has chosen to require the least frequent collection that remains consistent with overall public health preservation objectives. If data are collected less frequentl y, the primacy agencies may

not identify

in a timel y fashion violations that might threaten the health and safety of drinking water consumers. **3(e) General Guidelin**  **es**Public Water Systems Supervision Program ICR October 2015

12 There are no special circumstances. The collection of information is conducted in a manner consistent with the guidelines in 5 CFR 1320.6

. **3(f) Confidentiality**  No confidential information will be collected as a result of this I CR. **3(g) Sensitive Questions**  No information of a sensitive nature will be collected as a result of this I CR.Public Water Systems Supervision Program ICR October 2015

13 

### 4 **RESPONDENTS AND INFORMATION REQUESTED 4(a)**  **Respondents/ North American Industry Classification System (** **NAICS )**  **Codes** Data associated with this ICR are collected and maintained at the PWS, s tate , and federal levels. Respondents include :

 Owners/operators of PWSs, who must report to the primacy agency .  State/Primacy

agencies , and EPA Regions that act as primacy agencies in Indian lands

.  Laboratories conducting PT to achieve state certification, which permits them to anal yz e samples for compliance with NPDWRs. (PT vendors are not considered respondents because they are paid for their incurred burden and costs via the prices that laboratori es pay for the PT standards). The North American Industry Classification S ys tem (NAICS) code for PWSs is 22131. The NAICS code for state agencies that include drinking water programs is 92411 (Administration of Air and Water Resources and Solid Waste Man agement Programs) or 923312 (Administration of Public Health Programs). Ancillary s ys tems (i.e., those that supplement the function of other establishments like factories, power plants, mobile home parks, etc.) cannot be categorized in a single NAI CS code. For ancillary sy stems, the NAI CS code is that of the primary establishment or industry

. The c ode for laboratories that include environmental testing is 541380 (Testing Laboratories). Data associated with this ICR are collected and maintained by laboratories seeking p rimacy a gency

certification for the anal ys is of drinking water samples. **4(b) Information Requested**  **4(b)(i) Data Items** R espondent information collection requirements covered b y the PWSS Program I CR are summarized in Exhibits 2

- 4 below. These reflect cross

- cutting recordkeeping and reporting requirements under the PWSS Program (i.e., requirements that are not associated with contaminant

- specific rules). The requirements are discussed following Exhibits 2

- 4

.Public Water Systems Supervision Program ICR October 2015

14 **Exhibit 2 PWS Recordkeeping an**  **d Reporting Requirements Requirement**  **Regulatory Citation Frequency/Retention**  **CCRs** Mail copies of CCR to customers. 40 CFR 141.155(a) Annually, unless waived per section 141.155(g) Announce availability of CCR. 40 CFR 141.155(b) Annually Subm it copy of CCR to primacy agenc y. 40 CFR 141.155(c) Annually Subm it copy of CCR to agencies or clearing houses identified by the primacy

agenc y. 40 CFR 141.155(d) Annually, as required Make current year’s CCR available to public. 40 CFR 141.155(e) As requested Post current year’s CCR on the Internet (for systems serving ≥100,000 people). 40 CFR 141.155(f) Annually Publish CCR in local newspaper, if the mailing requirement has been waived. 40 CFR 141.155(g)(1) Annually, except that systems serving ≤500 can foreg o per section 141.155(g)(2) Retain copy of CCR. 40 CFR 141.155(h) For at least 3 years **VA RIA**  **NCES A ND EXEMPTIONS**  Retain records concerning variance or exemption grants. 40 CFR 141.33 Not less than 5 years after variance/exemption expiration Subm it information supporting request for variance. 40 CFR 142.41 One
- tim e, PWS discretion Subm it information supporting request for exemption. 40 CFR 142.51 One
- tim e, PWS discretion Subm it information supporting request for small system variance. 40 CFR 142.306 One
- tim e, PWS discretion Report on compliance with terms and conditions of the small system variance. 40 CFR 142.307 Quarter ly after granting
**CA PA** **CITY DEVELOPMENT** Demonstrate capacity (new CW Ss & NTNCWS s). N/A One
- tim e Cooperate with state to dem onstrate continued capacity. N/A As needed **GENER AL**  **ST AT**  **E PRIM ACY ACTIVITIES**  PW Ss are not involved in general state primacy activities. **PUBLIC NOTIFICA**

**TION RULE** Notify persons served within 24 hours of learning of a violation which requires Tier 1 PN. 40 CFR 141.202(b)(1) As necessary, within 24 hours Consult with the primacy agency within 24 hours of learning of a violation or other situation that requires Tier 1 PN. 40 CFR 141.202(b)(2) As necessary, within 24 hours
Comply with any additional n otification requirements for Tier 1. 40 CFR 141.202(b)(3) As necessaryPublic Water Systems Supervision Program ICR October 2015

15 **Requirement Regulatory Citation**  **Frequency/Retention** Notify persons served within 30 days of a violation that requires Tier 2 public notification. 40 CFR 141.203(b)(1) As necessary, within 30 days Provide repeat notices for unresolved violations every three mo nths, unless the primacy agenc y determines a different frequency. 40 CFR 141.203(b)(2) As necessary, every 3 months

Consult with the primacy agency if a violation of the turbidity MCL or SW TR/IES WT R treatm ent technique requirement s for single exceedances of turbidity limits occurs. 40 CFR 141.203(b)(3) As necessary, within 24 hours

Notify persons served within one ye ar of learning of a violation or situation that requires Tier 3 notification. 40 CFR 141.204(b)(1) As necessary, wi thin 1 year
Provide repeat notices annually for unresolved Tier 3 violations/situations. 40 CFR 141.204(b)(1) As necessary, annually
Notify new customers of ongoing violations/situations prior to or at the time service begins. 40 CFR 141.206 As necessary
Notify persons served of the availability of the results of unregulated contaminant mo nitoring. 40 CFR 141.207 As necessary, within 12 months of receiving results Provide special notice to persons served for an exceedance of the fluoride second ary

MCL (SMCL). 40 CFR 141.208 As necessary, within 12 months of exceedance Provide repeat notice of a fluoride SMCL exceedance, if unresolved. 40 CFR 141.208 As necessary, annually
Notify persons served by noncommunity water systems ( NCW Ss ) if the primacy agency grants permission to exceed the nitrate MCL. 40 CFR 141.209 As necessary, within 24 hours

Subm it to the state a copy of each notice provided (Tiers 1, 2, and 3 and any repeat notices) and a certification that all PN requirements were met. 40 CFR 141.31(d) and 141.201(c)(3) As necessary, within 10 days after completing notification requirements Retain copies of all notices and certifications. 40 CFR 141.33(e) 3 years **OPER AT**  **OR CERTIFICA TION PROGRA**  **M** C ertify operator(s) per state requirements. N/A As necessary Maintain and renew operator certification(s). N/A As necessary **TRIBA L**  **DRINKING W AT**  **ER OPERA**  **TOR CERTIFICATION PROGRA M**  C ertify tribal water system operator(s) per EPA guidelines. N/A As necessary Apply for “grandparent” certificate. N/A One time, if eligible **CONSTRUCTED CONVEYA NCE**  **S**Public Water Systems Supervision Program ICR October 2015

16 **Requirement Regulatory Citation**  **Frequency/Retention** Conduct a house
- by
- house survey of water use practices and document efforts to ascertain water uses. SDW A 1401(4)(B)(i) On
- going
Apply for Other Residential Uses Exclusion. SDW A 1401(4)(B)(i) (I) One time, if eligible Apply for Alternative W ater Exclusion. SDW A 1401(4)(B)(i) (II) One time, if eligible Apply for Treatment Exclusion. SDW A 1401(4)(B)(i) (III) One time, if eligible Apply for Certain Piped Irrigation Di stricts Exclusion SDW A 1401(4)(B)(ii) One time, if eligible **PROFICIENCY TESTING** PW Ss are not involved in proficiency testing Note: Content requirements for public notices are described in 40 CFR 141.205, 141.207, and 141.208.Public Water Systems Supervision Program ICR October 2015

17 **E xhibit 3**  **Primacy A** **gency Recordkeeping and Reporting Requirements**  **Requirement Regulatory Citation**  **Report Frequency/Minimum Retention**  **CCRs** Make CCRs available to public. 40 CFR 142.16(f)(2) As requested Retain copies of CCRs and certifications that CCRs were distributed. 40 CFR 142.16(f)(3) CCRs: 5 years Certifications: 1 year Report violations of CCR provisions. 40 CFR 142.16(f)(4) Quarterly **VA RIA**  **NCES A ND EXEMPTIONS**  Issue variances and exemptions (for other than small system variances). 40 CFR 142.20 At primacy agenc y discretion Consider system V/E requests (for other than small system variances). 40 CFR 142.21 Wi thin 90 days of request
Review V/E requests previously granted. 40 CFR 142.22 Wi thin 18 months of new standards Notify EPA of new variances or exemptions granted. 40 CFR 142.15(a)(3) Quarterly Summarize the status of variances or exemptions currently in effect. 40 CFR 142.15(b)(2) Annually Propose small system variances and provide supporting information and responses to comments. 40 CFR 142.31 1 & 142.312 Wh en s tate proposes to grant a sm all system variance Following notification of EPA’s objections and proposed mo difications to proposed small system variances, respond to EPA. 40 CFR 142.311 Before s tate grants a small community variance to a P WS serving 3,300 or fewer people
Re
- propose small system variances. 40 CFR 142.312 Before s tate grants a small community variance to a PW S serving more than 3,300 and fewer than 10,000 people Review each small system variance to determine if the PWS continues to meet eligibility criteria. 40 CFR 142.307 Not less than 5 years
Notice of public meeting on proposed small system variances, with supporting information. 40 CFR 142.308 At least 30 days prior to public me eting
**CA PA** **CITY DEVELOPMENT** Subm it evidence to EPA that s tate has established and continues to implement a Capacity Development Program. N/A Annually

Subm it report to Governor on the status of the Capacity Development Program. SDW A 1420(c)(3) Every three yearsPublic Water Systems Supervision Program ICR October 2015

18 **Requirement Regulatory Citation**  **Report Frequency/Minimum Retention**  **GENER AL**  **ST AT**  **E PRIM ACY**  **ACT IVITIES**  Retain s tate records for public inspection. 40 CFR 142.14 Varies Retain quarterly SDW IS reports to EPA, make them available for public inspection. 40 CFR 142.15(d) Upon completion and submittal by state Report any new violation data or enforcement actions. 40 CFR 142.15(a)(1)
- (2) Quarterly Report any new data related to SDW IS elem ents or any revisions to existing data. 40 CFR 142.15(b)(1) Annually
Subm it information required for review of s tate programs, including review of monitoring determinations. 40 CFR 142.17
- 142.18 Annually, as requested
Request primacy

treatment for a state or tribal primacy (for Indian tribes). 40 CFR 142.76 One
- tim e
Subm it initial application for primacy

. 40 CFR 142.11 One
- tim e Subm it statutory and regulatory provisions authorizing adm inistrative penalties or dem onstrate that authority does not exist. 40 CFR 142.11(a)(6) One
- tim e

Subm it revised primacy application. 40 CFR 142.12 As needed **PUBLIC NOTIFICA**

**TION** Prim acy agencies may

exercise flexibility in the following areas as long as they establish enforceable procedures

. Requiring PW Ss to notify persons served for violations or situations other than those requiring notice under the PN R ule. 40 CFR 142.16(a) If necessary

Allowing PW Ss to limit distribution of a notice to the portion of the distribution system that is out of compliance. 40 CFR 142.16(a) If necessary
Elevating violations/situations from Tiers 2 or 3 to Tier 1. 40 CFR 142.16(a) If necessary Requiring additional notification for Tier 1 as a result of the 24
- hour consultation. 40 CFR 142.16(a) If necessary Requiring or permitting a different form of deliver y than is required in the PN R ule for Tiers 1, 2, or 3. 40 CFR 142.16(a) If necessary
Elevating monitoring/testing procedure violations f rom Tier 3 to Tier 2. 40 CFR 142.16(a) If necessary Granting extensions for distribution of Tier 2 notices. 40 CFR 142.16(a) If necessary Allowing less frequent repeat notification for Tier 2. 40 CFR 142.16(a) If necessaryPublic Water Systems Supervision Program ICR October 2015

19 **Requirement Regulatory Citation**  **Report Frequency/Minimum Retention**  Consulting with PW S within 24 hours for exceedance of turbidity lim its. 40 CFR 142.16(a) If necessary Determining the need for mu ltilingual content in a notice. 40 CFR 142.16(a) If necessary Consult with PWS s within 24 hours for Tier 1 violations/situations. 40 CFR 141.202(b)(2) As necessary, within 24 hours
Consult with PWS s within 24 hours for exceedances of turbidity MCL or violations of turbidity single exceedance lim its. 40 CFR 141.203(b)(3) As necessary, within 24 hours

May give the required public notice on behalf of the PW S. 40 CFR 141.210 If necessary Report violations of the PN Rule to EPA. 40 CFR 142.15(a)(1) Quarterly Retain copies of certification and notices submitted by PW Ss. Also keep records of determinations of alternative requirements made under 40 CFR 142.16

. 40 CFR 142.14(f) 3 years

**OPER AT**  **OR CERTIFICA TION PROGRA**  **M** Subm it a report to EPA describing ongoing im plem entation activities of the state’s operator certification program. N/A Annually

Subm it to EPA a new Attorney General ( AG ) certification and a copy of the state’s regulations (if the state makes changes to its operator certification program) N/A As necessary

Subm it to EPA a report describing ongoing im plem entation activities of the state’s Expense Reimbursement Grant N/A Not applicable. Expense Reim bursement Grants Program ended in December 2012.
**TRIBA L**  **DRINKING W AT**  **ER OPERA**  **TOR CERTIFICATION PROGRA M**  States are not affected by the Tribal Drinking W ater Operator Certification Program because EPA directly im plem ents this program
. **CONSTRUCTED CONVEYA NCE**  **S** Review data to determine if a constructed conveyance should be considered a PWS

. SDW A 1401(4) As necessary Review applications and make determinations about Other Residential Uses Exclusions. SDW A 1401(4)(B)(i) (I) As necessary Review applications and make determinations about Alternative Wa ter Exclusions. SDW A 1401(4)(B)(i) (II) As necessaryPublic Water Systems Supervision Program ICR October 2015

20 **Requirement Regulatory Citation**  **Report Frequency/Minimum Retention**  Review applications and make determinations about Treatment Exclusions. SDW A 1401(4)(B)(i) (III) As necessary
Review applications and make determinations about Certain Piped Irrigation Districts Exclusions. SDW A 1401(B)(ii) As necessary

**PROFICIENCY TESTING** States are not involved in the proficiency testing program . States are involved in certification, which is addressed under general state primacy activities

. **Exhibit 4**  **Laboratories Recordkeeping and Reporting Requirements Requirement**  **Regulatory Citation Report Frequency/Minimum**  **Retention PROFICIENCY TESTING**  Analyze standards 40 CFR 141.23(k), 141.24(f)(17), 141.132(b)(2) Annually Report results to PT vendor N/A Annually Maintain records N/A Not specified 1) Consumer Confidence Reports CCRs must identify

the source of the water delivered by the CWS, describe whether it is ground water or surface water, and provide the common name and location of bodies of water used as sources. Reports also must define the terms “Maximum Contaminant L evel (MCL),”
“ Maximum Contaminant L evel Goal (MCLG), ” “ Maximum Residual Disinfectant Level (MRDL), ” “ Maximum Residual Disinfectant Level Goal (MRDLG), ” “ variance, ” and
“ exemption. ” Reports must contain a table providing data on contaminant levels detected as well as the MCL G and MCL for these contaminants. If contaminants are detected above the MCL or MRDL , health effects information must also be provided. Reports must indicate any violations of the NPDWRs, including monitoring and reporting, treatment techniques, public notification, recordkeeping, special monitoring requirements, and the terms of a variance , exemption, or administrative or judicial order. If applicable, reports must explain any granted variance or exemption. Reports must contain a brief explanation regarding contaminants that may be found in drinking water. 2) Variance and Exemption Rule To o btain a variance or exemption, systems must submit a request for the variance or exemption that contains supporting information. Sy stems that are granted a variance or exemption must also provide public notice within one year after operating under the vari ance or exemption. They

must also maintain records associated with the granting of the variance or exemption. States must review the information contained in V/E applications

.Public Water Systems Supervision Program ICR October 2015

21 3) Capacity Development Program Under SDWA section 1420, states are required to submit the following information to EPA :

 An annual report that describes ongoing implementation activities for both the

new s ys tems’ programs (SDWA 1420(a)) and the existing sy stems’ strategies (SDWA 1420(c)).

 A triennial report to the Governor on the s tatus of the capacity development program (EPA receives a courtes y cop y of each state report).

 A triennial list of sy stems that are historical significant non

- compliers and, to the extent practicable, the reason(s) for noncompliance. This requirement is currentl y satisfied by

using EPA’s OECA Enforcement Targeting Tool (ETT). The ETT assigns a point value to specific violations for each sy stem to bring attention to drinking water s ys tems with the most serious and unaddressed violations. EPA will utilize th e spreadsheet output generated b y the ETT on a quarterl y basis instead of the triennial list of sy stems referred to as significant non

- compliers. Sy stems must document their financial, technical, and managerial capacity, as required by the state. 4) General State Primacy Activities Section 142.14(a) stipulates, “Each state which has primary enforcement responsibility shall maintain records of tests, measurements, analyses, decisions, and determinations performed on each PWS to determine compliance with appl icable provisions of state primary drinking water regulations.” Further, section 141.14(g) states, “Records required to be kept under this section shall be made available to the Regional Administrator upon request.” Under s ection 142.17, EPA may

request information from a s tate to determine compliance of the s tate w ith requirements of 40 CFR 142 Subpart B. Information requested may include s tate determinations made under section 142.19 and records kept by s tates in accordance with section 142.14. To implement its compliance oversight and enforcement responsibilities under the SDWA, EPA requires primacy agencies to report a specified subset of PWS monitoring information in SDWI S. Additionally , primacy agencies must maintain record s of anal ys is results and other related activities (e.g., sanitary survey results). Sy stems are not required to submit any data under this program. 5) Public Notification Under the PN Rule , s ys tems must notify all s ys tem users of any violation of drinking water regulations. The methods and deadlines for notification are based on a three

- tier s ys tem. Tier 1 violations , which require 24

- hour notice, are those that risk serious health effects from short term exposure. Tier 2 violations , which require 30

- day n otice, are any violations that pose a health risk that are not Tier 1 violations. Tier 3 violations and situations are any not covered under the first two tiers ; they include monitoring violations, exceeding the fluoride secondary standard, operating under a variance or exemption , and announcing the availability of unregulated contaminant monitoring results. Tier 3 public notification must take place within aPublic Water Systems Supervision Program ICR October 2015

22 ye ar of the violation and may be included in the sy stem’s CCR. Sy stems must consult with primacy agencies within 24 hours of a turbidity violation to determine if the violation is Tier 1 or Tier 2. Primacy

agencies must consult with any s ystems with Tier 1 vio lations within 24 hours of the violation. They

may also decide to elevate certain Tier 2 or Tier 3 violations. Primacy agencies must report all violations to EPA and keep records for three ye ars after the violation. 6) Operator Certification Program To satisfy section 1419 of SDWA (regarding EPA’s Operator Certification Guidelines), states are required to submit the following information to EPA :

 An annual report that describes ongoing implementation activities of a state’s operator certification program.
 A new Attorney

General (AG) certification and a copy of the state’s regulations if a state makes changes to its operator certification program. Sy stems must document that they have certified operators, and their operators must maintain certificatio n as required b y the state program. 7) Tribal Drinking W ater Operator Certification Program The Drinking Water Infrastructure Grant Tribal Set Aside (DWIG TSA) Final Guidelines (October 1998) state that after EPA has developed a Tribal Drinking Water Operator Certification Program for operators of s ys tems in Indian Country , “any s ys tem to be assisted with TSA funds must be operated b y an adequately trained and certified operator” in order for a tribe to receive a grant for that sy stem. The program guidelin es establish seven baseline standards and list the certification program requirements that must be met by organizations that certify operators of drinking water s ys tems in Indian Country to receive approval from EPA. EPA is responsible for implementing the EPA Tribal Drinking Water Operator Certification Program in Indian country and for tracking the number of water s ys tems with certified operators. 8) Constructed Conveyances T o comply

with the 1996 SDWA Amendments, systems and states must work together to determine if the s ys tem meets the new definition of “public water s ys tem.” Inaddition, section 1401(4)(B) of the 1996 SDWA Amendments provides several exemption options. If a sy stem is eligible for one of these exemptions, the sy stem must submit an appli cation to the state. The state must then review the exemption applications and make determinations. EPA expects that no new constructed conveyances will be built going forward. 9) Proficiency Testing In all laboratory

PT studies, laboratories submit the res ults of analy ses for all contaminants for which they wish to be certified to conduct drinking water anal ys es . **4(b)(ii) Respondent Activities** PWSs and primacy

agencies must complete the activities described in the sections below. **Public Water Systems**Public Water Systems Supervision Program ICR October 2015

23 1) Consumer Confidence Reports 6 For CCRs, CWSs must conduct the following activities

—

 Compile the report.

 Mail one report to each customer.

 For consumers who do not receive water bills, publish a notice in the news paper indicating how a consumer may obtain a copy

of a CCR.

 Submit one copy

of the completed report to the primacy agency annually and retain one cop y of the report.

 Submit copy

of CCR to agencies or clearinghouses identified by the primacy agency .  Certify

to the primacy

agency that the report h a s been distributed to customers and that the information is correct

.  Publish the report in a local newspaper rather than mail it , if the s tate Governor allows CWSs serving 10,000 or fewer people to do so.

 Post an annual notice for customers rather than pub lishing or mailing a report, i f the s tate Governor allows CWSs serving fewer than 500 people to do so.

 Post the report to a publicly accessible Internet si te, for CWSs serving 100,000 or more people. 2) Variance and Exemption Rule A PWS that elects to appl y for a variance or exemption must either perform the following activities or assist the state in performing these activities :

 Apply for the variance or exemption and submit any information that the state requires. For small s ys tem variances, a sy stem must demonstrate that it cannot afford to compl y with the NPDWR for which the small sy stem variance is sought; that its source water meets the quality standards for installation of the s mall sy stem variance technology ; that it is financiall y and tec hnicall y capable of installing, operating, and maintaining the applicable s mall sy stem variance technology ; and that the terms and conditions of the small sy stem variance would ensure adequate protection of human health.

 Work with the state to hold a publi c hearing on the proposed variance or exemption and provide public notice within one year after operating under the variance or exemption.

 Write and submit a quarterly report on compliance with the terms and conditions of the small sy stem variance.

 Retain records associated with the variance or exemption.

6 In response to a me mo ( http://water.epa.gov/lawsregs/rulesregs/sdwa/ccr/upload/ccrdeliveryoptionsmemo.pdf ) that allows electronic delivery of CCRs in some cases, EPA estimates some systems serving 100,000 or more people will exclusively deliver CCRs electronically.Public Water Systems Supervision Program ICR October 2015

24 Note that EPA estimates that no sy stems will apply for variances or exemptions in this 3

- ye ar ICR period. 3) Capacity Development Program Under the Capacity Development Program for new systems, all CWSs an d NTNCWSs must demonstrate adequate capacity and compl y with all state capacity development requirements. All PWS s are asked to cooperate with the state’s strategy for existing sy stems. This includes achieving, maintaining, and improving capacity

. 4) Genera l State Primacy Activities There are no PWS activities associated with the General State Primacy Activities. 5) Public Notification To comply

with the PN regulations, PWSs must complete the following activities

—

 Prepare the notice (sections 141.201, 141.2 05, 141.206, 141.207, and 141.208).

 Distribute the notice to all persons served within the applicable time frame (sections 141.202, 141.203, and 141.204).

 If the violation or situation requires public notification within 24 hours, consult with primacy

agen cy within the 24

- hour period to determine subsequent actions (section 141.202(b)(2)). Consultation is also required for exceedances of the maximum allowable turbidity level (section 141.203(b)(3)).

 If a violation is unresolved, prepare an updated notice fo r repeat distribution (sections 141.205, 141.206, 141.207, and 141.208).

 Distribute the updated notice (sections 141.202, 141.203, and 141.204).

 Take any additional actions required b y the primacy agency (sections 141.201 and 141.202).

 Submit certification to the primacy agency along with copies of all public notifications that were distributed.

 Retain records of all notices and certifications. 6) Operator Certification Program Sy stems are required to comply with the state requirements for operator certification. Sy stems must :

 Ensure certified operator(s) holding a valid certification equal to or greater than the classification of the system.

 Maintain/renew certification(s) as needed. 7) Tribal Drinking W ater Operator Certification Program For the Tribal Drinking Water Operator Certification Program, tribal water sy stems are expected to have a certified operator

.Public Water Systems Supervision Program ICR October 2015

25 8) Constructed Conveyances In order to adhere to the broadened definition of “public water s ys tem” introduced by the 1996 SDWA Amendments, P WS s may complete the following activities :

 Conduct a house

- by

- house survey of water use practices and document efforts to ascertain water uses.

 Apply for an Other Residential Uses Exclusion.

 Apply for an Alternative Water Exclusion.

 Apply for a Treatment Exclusion.

 Apply for a Certain Piped Irrigation Districts Exclusion Note that EPA expects that no new constructed conveyances will be built going forward. **Primacy Agencies** 1) Consumer Confidence Reports As part of the CCR Rule, primacy agencies must

—

 Review and retain reports and certifications from CWSs.

 Assist in preparation of reports , as needed

.  Report compliance to EPA. 2) Variance and Exemption Rule In addition to helping PWSs meet application requirements, states must :

 Provide EPA with the proposed small sy stem variance, supporting information, and responses to public comments.

 Respond to EPA’s objections to a proposed small sy stem variance for a PWS serving 3,300 or fewer persons, if the state chooses to pursue the variance.

 Revise a proposed small sy stem variance as necessary to reflect EPA’s comments on variance requests for sy stems that serve more than 3,300 people and fewer than 10,000 people, if the state chooses to pursue the variance.

 Submit a quarterly

report on violations of increment s of progress or any other violated term or condition of a small sy stem variance.

 Conduct a public meeting on a small sy stem variance request, provide notice of the public meeting, and provide supporting information to the public.

 Respond to significant public comments on the proposed variance request.

 Retain records associated with a granted variance or exemption not less than five ye ars after its expiration. Note that EPA estimates that no applications will be received for variances or exemptions in thi s 3

- year ICR period.Public Water Systems Supervision Program ICR October 2015

26 3) Capacity Development Program States must :

 Submit an annual report that describes ongoing implementation activities for both the new s ys tems’ programs (SDWA 1420(a)) and the existing sy stems’ strategies (SDWA 1420(c))

.  Submit a triennial report to the Governor on the status of the capacity development program (EPA receives a courtes y copy of each state report). Note that section 1420(b)(1) of the SDWA requires that “... each state shall prepare, periodically update, and submit to the Administrator a list of community water systems and nontransient, noncommunity water systems that have a history of significant noncompliance... and, to the extent practicable, the reasons for noncompliance.” As discussed above, EPA’s OECA replaced the significant non

complier list with the ETT. EPA will utilize the spreadsheet output generated by the ETT on a quarterl y basis. A s part of the ETT implementation, EPA and states meet on a quarterly

basis to discuss the status of PWS s on this list and identi fy steps to enable sy stems to return to compliance. EPA believe s that this approach is more proactive than addressing the reasons for non

- compliance once every three years. 4) General State Primacy Activities As part of their general primacy activities, primacy

agencies must

—

 Prepare grant packages requesting funding to operate the program in a state.

 Maintain state drinking water data s ys tems.
 Review monthly

violations reports to monitor compliance.

 Maintain records submitted by PWSs regarding results of analy tical tests and other milestones, such as treatment decisions.

 Take timely

and appropriate enforcement actions.

 Review PWS projects regarding design, construction, and treatment modifications.

 Conduct routine inspections to supplement information col lected during sanitary survey s.
 Certify

laboratories to analyze drinking water samples for compliance with drinking water regulations. This I CR assumes that no applications for primacy will be submitted during the next three ye ars. However, since a new primacy application is a possibility, the following discussion of possible implications is provided. To obtain primacy , the applicant must :

 Adopt drinking water regulations that are no less stringent than the NPDWRs currentl y in effect. An agency may also be granted primacy

for new or revised EPA regulations if it demonstrate s that its approved program has been updated to include regulations no less stringent than those new or revised EPA regulations.

 Adopt adequate procedures for enforce ment of these regulations.

 Report these procedures according to EPA's requirements.Public Water Systems Supervision Program ICR October 2015

27  Permit variances and exemptions under conditions no less stringent than those specified b y the regulations.

 Adopt and implement an adequate plan for providing safe drinking water under emergency

circumstances. 5) Public Notification The PN Rule requires primacy agencies to consult with the violating PWS to determine appropriate follow up actions. T he primacy agencies must receive and review public notification certifications submitted by PWSs. Primacy agencies must submit quarterly reports of PN Rule violations to EPA. 6) Operator Certification Program A state complying with the program must :

 Submit an annual report that describes ongoing implementation activities of a stat e’s operator certification program.

 Submit a new AG certification and a cop y of the state’s regulations if a state makes changes to its operator certification program. 7) Tribal Drinking W ater Operator Certification Program States are not affected b y the Tribal Drinking Water Operator Certification Program. 8) Constructed Conveyances To comply

with the broadened definition of “public water s ys tem” introduced by the 1996 SDWA Amendments, states may complete the following activities

—

 Review data to determine if a constructed conveyance should be considered a PWS.

 Review applications for Other Residential Uses Exclusions and make determinations about the exemption applications.

 Review applications for Alternative Water Exclusions and make determinations about the exemption applications.

 Review applications for Treatment Exclusions and make determinations about the exemption applications.

 Review applications for Certain Piped Irrigation Districts Exclusions and make determinations about the exemption applications. Note that EPA expects that no new constructed conveyances will be built going forward. **Laboratories** Proficiency Testing The primary

burden involves anal yz ing and reporting results for relevant study samples according to in structions. Samples may be anal yz ed for inorganics, disinfection by products (DBPs) and/or organic chemicals. Respondents will participate in the following activities :Public Water Systems Supervision Program ICR October 2015

28  Read instructions

 Plan activities

 Analyze inorganic chemicals

 Analyze DBPs

 Analyze organ ic chemicals

 Report results to the PT vendor

 Maintain records Laboratories are not subject to any of the other collections covered in this ICR.Public Water Systems Supervision Program ICR October 2015

29 

### 5 **INFORMATION COLLECTED**  **-- AGENCY ACTIVITIES,**  **COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT**  **5(a) Agency**  **Activities** As part of its supervisory responsibility for the PWSS Program, EPA oversees contractors who maintain SDWI S and assist EPA in evaluating the data in SDWI S to determine compliance rates
. EPA instructs contractors to reformat, distribute, and st ore data for a number of uses, including responding to Congressional and public inquiries. EPA also oversees the state programs, provides technical assistance, and develops policies designed to ensure consistent program implementation. EPA also oversees th e tribal drinking water operator certification program. In addition to its management activities, EPA directly implements the Aircraf

t Drinking Water Rule (see the M icrobial Rules IC R for more information). EPA officials serve as respondents when testifying to Congress on the PWSS Program or in the courts for enforcement actions. EPA’s recordkeeping requirements are outlined in Exhibit 5 below

. **Exhibit 5**  **PWSS Program Requirements for EPA**  **Regions and Headquarters Requirement**  **CFR Citation Report F**  **requency/Minimum Retention**  Review initial and revised applications for primacy

. 40 CFR 142.11
- 142.12 As needed Inform primacy

agency of PW S noncompliance with any NPDW Rs in 40 CFR 141 or with any requirement under SDW A sections 1415 and 1416. 40 CFR 142.30, 142.15 Quarterly Review existing s tate primacy programs
. 40 CFR 142.17 Annually Review s tate monitoring determinations

. 40 CFR 142.18 As needed Review s tate implementation of LCR

. 40 CFR 142.19 As needed Inform primacy

agency of substantial abuse of discretion in granting variances and exemptions. 40 CFR 142.23 As needed Provide notice of public hearing for states abusing right to grant variances and exemptions. 40 CFR 142.23 As needed Notify primacy

agencies of failure to prescribe schedul es in accordance with SDW A. 40 CFR 142.23 As needed Notify primacy

agencies of repeal of notice or promulgation of any revisions to schedules or revocation of schedules proposed in notice. 40 CFR 142.23 Wi thin 180 days of first notice given to the state; revised schedule or revocation takes effect 90 days after state is notified.Public Water Systems Supervision Program ICR October 2015

30 **Requirement CFR Citation**  **Report F requency/Minimum**  **Retention** Notify primacy

agencies of objection and proposed mo difications to small system variances proposed by states for PW Ss serving 3,300 or fewer people. 40 CFR 142.311 Wi thin 90 days of receiving proposal
Notify primacy

agencies of deficiencies in state program for granting small system variances. 40 CFR 142.313 As needed Notify PW Ss of noncompliance with any NPDW Rs in 40 CFR 141 or with any requirement under SDW A sections 1415 and 1416. 40 CFR 142.30, 142.15 Quarterly
Provide PW Ss with copies of Federal Register notice about PW S failure to comply. 40 CFR 142.23 Wi thin 30 days of notice Notify PW Ss of denial or grant of variance (for PW Ss in non
primacy states). 40 CFR 142.42 Wi thin 90 days of request Notify PW Ss of denial or grant of exemption (for PWS s in non
primacy states). 40 CFR 142.52 Wi thin 90 days of request Notify PW Ss of denial or grant of sm all system variance (for PWS s in non
- primacy states). 40 CFR 142.311, 142. 312 Wi thin 90 days of request Provide notice to PWS s in non
primacy states that are no longer eligible for small system variances. 40 CFR 142.307 As needed Provide public notice of public me eting on proposed small system variances (in non
primacy states) , with supporting information. 40 CFR 142.308 At least 30 days prior to public me eting Respond to significant public comments. 40 CFR 142.308 Before proposal Notify public of proposed small system variance (in non
- primacy states), with supporting information. 40 CFR 142.309 No later than 15 days after receiving small system variance proposal. Make D WS RF grant withholding decisions with regard to States’ Capacity Development Programs. SDW A section 1420(a), (c) 35 CFR 35.3515(b)ii Annually Make D WS RF grant withholding decisions with regards to States’ Operator Certification Programs. SDW A section 1419(b) Annually Provide state and PW S assistance and training with regard to recordkeeping and reporting requirements covered in this ICR N/A As needed
Maintain SDW IS

. N/A As neededPublic Water Systems Supervision Program ICR October 2015

31 **Requirement CFR Citation**  **Report F requency/Minimum**  **Retention** Review data in SD WI S

. N/A Quarterly Implement T ribal Drinking W ater O perator C ertification P rogram N/A As needed **5(b) Collection Methodology and Management**  Primacy agencies must report data to EPA on a quarterl y basis. These data include any new data and revisions or corrections to existing data. This information is maintained in SDWI S 7 , which contains the following:

 Inventory

data for each PWS.

 Violations.

 Enforcement actions and some follow

- up activity

.  Varian ces and exemptions (where applicable). Primacy agencies primarily

transmit SDWI S data to EPA electronically . In the District of Columbia, Wyoming, and Indian Lands (except for the Navajo Nation, which has primacy), results of sy stem samples are sent dire ctl y to the EPA Region. These data assist EPA in fulfilling its SDWA obligations.
O n a quarterl y basis, EPA uses the ETT to g enerate a list of PWSs considered “priority sy stems
. ” The ETT assist s EPA and the primacy agencies in prioritiz ing and directin g enforcement response to PWS s with the most systemic noncompliance by considering all violations incurred b y a PWS in a comprehensive way

.
**5(c) Small Entity Flexibility**  In developing this I CR, EPA considered the requirement of the Small Business Regulatory

Enforcement Fairness Act (SBREFA) to minimize the burden of information collections on small entities. Small entities include “small businesses,” “small organizations” and “small government jurisdictions.” These terms are defined below. 8

 A **smal l business**  is any business that is independently owned and operated and not dominant in its field as defined b y the Small Business Administration regulations under section 3 of the Small Business Act.

 A **small organization** is any non - profit enterprise that is independently owned and operated and not dominant in its field.

7 The public can access the violation data in SDWIS online at http://water.epa.gov/scitech/datait/databases/drink/s dwisfed/howtoaccessdata.cfm

. 8 These definitions were taken from section 601 of the Regulatory Flexibility Act.Public Water Systems Supervision Program ICR October 2015

32  A **small governmental jurisdiction** is the government of a city, county, town, township, village, school district , or special district that has a population of fewer than 50,000. This definition may also include Indian Tribes. The major requirement under SBREFA is a regulatory flexibility

anal ys is of all new rules that have a “significant economic impact on a substantial number of small entities.” This I CR is not associated with new r ules. Therefore, this ICR is not subject to the SBREFA. However, EPA has made significant efforts to minimize the burden for all respondents, particularl y for small entities. Insetting both MCLs and monitoring requirements, EPA has been able to minimiz e burden for small entities as detailed below. 1) Consumer Confidence Reports EPA’s regulations allow sy stems serving fewer than 10,000 people to publish a newspaper notice in lieu of sending reports to customers. Under 40 CFR 141.155(g)(2), CWSs serving 5 00 or fewer people may forego the notice

- publishing requirement, provided they give notice at least annually

to their customers by

mail, door

- to
- door delivery , or posting in an appropriate location that the CCR is available upon request. 2) Variance and Ex emption Rule The V/E Rule includes procedures and conditions under which the primacy agency may issue variances or exemptions to PWS s. The V/E Rule is intend ed to provide regulatory relief while still protecting public health. These variances generall y allow a sy stem to provide drinking water that may

be above the MCLif the drinking water quality is still protective of public health. Duration of small sy stem variances generall y coincides with the life of the technology

. Exemptions are intended to allow a small sy stem with compelling circumstances additional time to comply

with applicable SDWA requirements. An exemption is generally limited to three ye ars after the initial compliance date stated in the regulations. 3) Capacity Development Program EPA’s gui delines provide states with maximum flexibility in developing and implementing the capacity development program. EPA published a Handbook for Capacity Development: Developing W ater System Capacity Under the Safe Drinking W ater Act Amendments of 1996 and wo rked on several other tools to help small systems comply

. 4) General State Primacy Activities There are no PWS activities associated with the General State Primacy Activities. 5) Public Notification EPA allows sy stems serving fewer than 10,000 persons several options for delivering public notices, such as hand delivery and posting in a prominent location. 6) Operator Certification ProgramPublic Water Systems Supervision Program ICR October 2015

33 EPA’s Guidelines provide states with maximum flexibility in developing an d implementing their operator certification programs. EPA published the Operator Certification Guidelines: Implementation Guidance to assist states in determining whether a state’s operator certification program complies with the requirements of the guidel ines. 7) Tribal Drinking W ater Operator Certification Program Water sy stem operators in Indian Country can decide if they

would like to be certified by an EPA

- approved tribal certification provider or by a state program. EPA continues to subsidize the training and certification of tribal water s ys tem operators in Indian Country via the tribal PWSS and the Drinking Water Operator Certification programs

. 8) Constructed Conveyances The broadened definition of public water s ys tem includes small constructed conveyance sy stems that would now be considered PWSs. Consequently , the 1996 SDWA Amendments provided several exemption options. Examples of these exclusions includ e:

 If water provided b y a supplier is used exclusively for purposes other than residential uses (drinking, bathing, cooking, and similar uses), then a s ys tem may apply for an “ Other T han Residential Uses” e xclusion.

 If a water supplier provides adequate health protection through means specified in section 1401(4)(B)(i)(II) and (III), then the sy stem may apply for an “Alternative Water Treatment” Exclusion.

 If the water suppl y will be used for drinking, cooking, or bathing, then the water must be treated either centrally or at the point

- of

- entry at each connection. To receive a “Treatment” Exclu sion, a sy stem must demonstrate that this treatment is occurring.

 If an irrigation district existed prior to May 18, 1994, and if the district provides primarily agricultural service through piped water sy stems (with incidental residential use), the s ys tem may be eligible for a “Certain Piped Irrigation Districts” Exclusion. Note that EPA expects that no new constructed conveyances will be built going forward. 9) Proficiency Testing The PT program is not part of a rule, so it is not subject to the requirements of SBREFA. The PT program applies only to those laboratories that wish to be certified to conduct drinking water anal ys es. **5(d) Collection Schedule**  Exhibits 2, 3, and 4 of this document contain summaries of the collection schedules for each rule. Additional information may be obtained by

consulting the individual rules for specific collection schedules.Public Water Systems Supervision Program ICR October 2015

34 

### 6 **ESTIMATING BURDEN AND COST OF COLLECTION** This section estimates the burden and cost to PWSs, primacy agencies, and EPA for complying with dri nking water information requirements that are not associated with contaminant

- specific rulemakings. These activities include the following :

1) Consumer Confidence Reports 2) Variance and Exemption Rule 3) Capacity

Development Program 4) General State Primacy Activiti es 5) Public Notification 6) Operator Certification Program 7) Tribal Drinking Water Operator Certification Program 8) Constructed Conveyances 9) Proficiency

Testing This section also discusses the assumptions used to estimate costs and burden and describes the change in burden, as compared with the 2012 PWSS Program I CR. T he burden incorporates the results of consultations with representatives of states and PWSs. **6(a) Respondent Burden**  **6(a)(i) Burden to Public Water Systems**  The annual PWS burden for November 1 , 2015 to October 31, 2018 is estimated to be approximately 2. 2 million hours. Exhibit 6 shows the breakdown of the annual burden hours on an activity

- specific basis. The bases for the burden estimates are detailed below. 1) Consumer Confidence Reports CCR regulations require, at a minimum, that each CWS mail to each of its customers an annual report on the level of contaminants in the drinking water purveyed by that sy stem. EPA estimates that CCR requirements will affect approximately 5 0 ,4 31 PWSs, all of which are CWSs, during the course of this I CR period. Activities associated with the preparation and delivery of CCRs account for 9 55 , 671 burden hours per ye ar , which includes burden for both CCR development and distribution for PWSs

. Appen dix B summarizes the assumptions used to calculate the CCR burden and provides detailed burden and cost calculations. The assumptions used to calculate the CCR burden are based largely

on assumptions from the 2012 PWSS Program ICR. For the PWSS Program ICR renewal, these assumptions have been augmented or supplanted where updated data were available. Section 6(f) describes the reasons for changes in burden and shows the effects of any new assumptions on the CCR burden estimates. Report Development Preparation of a CCR includes assembling data, writing the report, ensuring that the notice meets regulatory

requirements, and printing the document. Burden estimates range from 4 hours for CWSs serving 500 or fewer people to 160 hours for CWSs serving 10 0 ,000 people orPublic Water Systems Supervision Program ICR October 2015

35 more . After completion of CCR preparation activities, all CWSs, regardless of size, are assumed to have the same burden (0. 5 hours) for submitting to the state a cop y of the CCR distributed to customers. Certification that the reports were, distributed is also required along with the report. A ll CWSs, regardless of size, are assumed to have the same burden (0.25 hours) for maintaining a cop y of the CCR and making it publicl y available, if requested. Report Delivery The burden estimate for CCR delivery includes the following activities and assumptions :

 Except for CWSs serving 500 or fewer people, all CWSs incur a burden for publishing a notice about obtaining a CCR. The burden per s ys tem for this activity is 0.25 hours. For s ys tems serving at least 10,000 people, publication is in addition to report delivery

to customers. For sy stems serving fewer than 10,000 people, this I CR assumes that 50 percent of sy stems will publish a notice in lieu of sending reports to customers.

 Under 40 CFR 141.155 (g)(2), CWSs serving 500 or fewer people may forego the notice

- publishing requirement, provided they give notice at least annually to their customers b y mail, door

- to
- door delivery , or posting in an appropriate location that the CCR is available upon reque st. This ICR assumes that 50 percent of these CWSs post the report and 50 percent deliver the report to their customers as part of their standard water bill. Those that post the CCR are estimated to incur a burden of 0.12 hours for this activity

.

 Regardl ess of CWS size category , this ICR assumes a burden of 1 0 hour s per s ys tem for coordinating delivery of the CCR as a bill stuffer. CWSs serving 10,000 or more people must deliver the CCR to all service connections. However, CWSs serving fewer than 10,000 people may apply to the s tate Governor (or Tribal Leader) for a waiver of th e requirement to deliver a CCR to each customer. This I CR assumes that half of such CWSs will receive a waiver. For CWSs serving 500 or fewer people, the 50 percent without a waive r are assumed to include the CCR along with the normal water bill (instead of sending the CCR in a separate mailing). For CWSs serving 501 and 99,999 people, half of the sy stems without a waiver (or 25 percent of the total number of CWSs in this size categ ory) are assumed to include the CCR as a bill stuffer, and the remaining s ys tems will mail the CCR separatel y. Note that in this ICR, in response to an EPA memo (http://water.epa.gov/lawsregs/rulesregs/sdwa/ccr/upload/ccrdeliveryoptionsmemo.pd f ) that allows electronic delivery of CCRs in some cases, EPA estimates some sy stems serving 100,000 or more people will exclusively deliver CCRs electronicall y and there fore will not incur burden to coordinate bill stuffer delivery

.

 Under section 141.155(f), CWSs serving at least 100,000 people must post a cop y of the current CCR on a publicly accessible Internet site. This burden is estimated at 2 hours per s ys tem.Public Water Systems Supervision Program ICR October 2015

36 2) Va riance and Exemption Rule No sy stems are expected to apply for new variances or exemptions in this 3

- ye ar ICR period; therefore, no burden is estimated for PWSs for this rule. Detailed information about assumptions, burden, and calculations is provided in Appendix C. 3) Capacity Development EPA estimates that capacity development will affect approximately 1 3 , 826 PWSs, including CWSs, NTNCWSs, and TNCWSs , during the course of this I CR period , as explained below

. The Capacity

Development Program consists of two major components

— 1) Implementation of a program to ensure that all new CWSs and NTNCWSs demonstrate the capacity to comply with NPDWRs. 2) Implementation of a strategy to assist existing PWSs in acquiring and maintaining capacity to comply with the SDWA. The burden estimate associated with new and existing capacity development efforts is based on expert opinions, including opinions provided by members of the NDWAC Small Sy stems Workgroup, and consultations with drinking water industry repres entatives. Specificall y, the burden estimate includes the following activities and assumptions :

 New s ys tems must demonstrate capacity in order to obtain approval. Each new sy stem appl yi ng for approval will require 40 hours to prepare and submit new s ys tem approval materials to the state. EPA estimates that there will be an average of 8 new sy stems per state per ye ar.

 Some new sy stems must improve capacity in order to obtain approval. An estimated 20 percent of new s ys tems applying for approval will be re quired to submit supplemental materials before approval is granted by the state. To develop and submit these materials, it is estimated that each s ys tem denied initial approval will require an additional 40 hours. As with the approval application, it is es timated that there will be 8 new s ys tems per state per year (20 percent of which will be required to submit supplemental materials) and that the burden estimate does not include the time needed to comply

with technical requirements.

 Some existing sy stems will incur burden for complying with state capacity development strategies. Each ye ar, EPA estimates that 20 percent of CWSs, 7 percent of NTNCWSs, and 2.5 percent of TNCWSs will incur a burden to compl y with state capacity development strategy

efforts. E PA estimates that these s ys tems will spend, on average, 8 hours per year participating in capacity development strategy

activities such as state consultation, training on managerial and financial aspects of operating a public water s ys tem and one on one te chnical assistance. Based on these assumptions, EPA estimates that the average annual burden to PWSs will be approxi mately 1 28 , 851 hours fo r capacity development activities.Public Water Systems Supervision Program ICR October 2015

37 Appendix D summarizes the assumptions used to calculate the Capacity Developm ent Program burden and provides detailed burden and cost calculations. 4) General State Primacy There is no PWS burden associated with general state primacy activities. 5) Public Notification Only PWSs with one or more violation s during the year incur a burden to prepare, copy , mail, submit, or post public notices, as well as to maintain records of public notification activities

. PWSs with no violations have no requirements under this rule. The annual information collection burden for s ys tems that do experience a violation is estimated to be 779,393 hours. Note that RTCR net change burden (i.e., incremental burden over the 1989 Total Coliform Rule ( TCR) ) for public notification has been remov ed from the RTCR standalone I CR , and is now accounted for in this I CR. Due to the elimination of Tier 2 violations for total coliform occurrence under RTCR, PWSs will experience a significant reduction in public notification burden, which is reflected in the annual PWS burden estimate above

. In preparing this ICR, EPA assumed that each PWS will deliver a public notice to persons served. Under the statute, PWSs are required to reach persons served, including those who ordinaril y do not receive water bills (e.g., residents of apartment buildings, students and staff at schools, etc.). Under the PN Rule, CWSs providing a Tier 1 notice are expected either to hand deliver the notice to all residences or to contact all media outlets serving the affected communi ty , including television and radio stations, and submit a press release. Burden for distribution of Tier 1 notices is estimated at 12 hours for posting and hand delivery and/or use of mass media. NCWSs providing a Tier 1 notice are likel y to post the notic e or hand deliver the notice to customers. All water s ys tems are required to take other reasonabl y calculated steps to ensure all the persons served b y the system receive the notice. Although the rule does not specify such actions, PWSs are assumed to plac e telephone calls to centers of sensitive populations, such as hospitals, nursing homes, and schools. Finall y, water s ys tems are expected to prepare a notice suitable for posting in rest areas, government

- owned buildings, libraries, and other facilities se rved b y the water s ys tem. Sy stems providing a Tier 2 or Tier 3 notice must mail or otherwise directly deliver one notice to each billing customer. The PN Rule also permits NCWSs to post the notice in lieu of direct delivery

or mailing. All water s ys tems must also take other reasonably calculated steps to reach other persons not reached by mail, direct delivery , or routine posting. Estimated burden hours for delivering Tier 2 notices are 9 hours for CWSs under 500 in si ze, and 30 hours for larger CWS s. NTN CWS and TNCWS are estimated to incur 9 burden hours per s ys tem. The burden estimate for mailing assumes that half the CWSs bill their customers less frequentl y than every month or use postcards rather than envelopes to send bills. Therefore, if a CWS experiences a violation requiring a Tier 2 notice more than 30 days prior to a regular billing date, that CWS is required to send a separate mailing specificall y for the public notice. Water sy stems that bill on a monthly basis and do not use postcards, or those sending out other mailings to the customers, including annual CCRs, will be able to incorporate the notice as aPublic Water Systems Supervision Program ICR October 2015

38 stuffer in one of the s ys tem’s other mailings. Because the mailing alone will not reach all persons served, the burden estimate includes other methods of information dissemination to ensure all persons served receive the notice. The burden for preparation of these notices was calculated separatel y from the burden for delivering the notices. For Tier 1 notice preparation by sy stems servin g up to 10,000 customers, the burden estimate per sy stem is 15 hours. Sy stems serving more than 10,000 customers incur a burden of 30 hours per sy stem. Systems with T ier 2 notices incur an estimated burden of 3.5 hours, regardless of size, while CWSs with Tier 3 notices have an estimated burden of 3 hour s and NTNCWSs and TNCWSs have an estimated 3.5 burden hours

. If repeated notices are necessary , the estimated PWS respondent burden for developing and distributing repeat public notification is 3 hours per s ys tem. Appendix F summarizes the assumptions used to calculate the PN Rule burden and provides detailed burden and cost calculations. 6) Operator Certification Program EPA estimates that on average, 2 3, 209 PWSs will be affected annuall y b y the Operator Certification Program

. The burden for PWSs involves operators renewing their certifications. The burden is estimated to be 315 , 919 hours annually for PWSs. Appendix G summarizes the assumptions used to calculate the Operator Certification Program burden and provides detailed burden and cost calculations. 7) Tribal Drinking W ater Operator Certification Program Burden for tribal PWSs involves obtaining and renewing certification of their operators. Th e total burden for all three ye ars is estimated to be 30 , 080 hours. Annually that is an average burden of 10 , 027 hours. It is estimated that tribal systems will require 40 hours for new L evel 1 certifications, 26 hours for new L evel 2 certifications and 26 hours for new L evel 3 certifications. Other activities i nclude 40 ho urs for certification renewals. Appendix H summarizes the assumptions used to calculate the Tribal Drinking Water Operator Certification burden and provides detailed burden and cost calculations. 8) Constructed Conveyances EPA estimates that no new constructed conveyances will be built going forward , therefore no PWSs will incur an y reporting and recordkeeping burden to adhere to the broadened definition of “public water s ys tem” introduced by the 1996 SDWA Amendments. EPA historically

assumed that 371 sy stems per ye ar would be involved in the constructed conveyance program . In May 2015, EPA consulted states on its expectation that no constructed conveyances will be built going forward. Consultations confirmed this expectation. Thus, reporting and recordkeeping burden for PWSs to comply with the Constructed Conveyances program going forward is assumed to be negligible. Note that detailed calculations previously provided in appendix form are no longer included in this I CR.Public Water Systems Supervision Program ICR October 2015

39 **6(a)(ii) Bu rden to Primacy Agencies**  The annual burden for state primacy agencies for November 1, 2015 to October 31, 2018 is estimated to be approximately 1. 5 million hours. Exhibit 7 shows the annual burden on an activity

- specific basis. The following briefl y desc ribes the bases for the burden estimates

– 1) Consumer Confidence Reports Primacy agencies are expected to incur burden for information collection activities associated with preparation assistance, review, and filing of CCRs. The total annual state burden is estimated at 7 3 , 912 hours. Assisting in the preparation of reports for small CWSs is estimated at 2 hours per s ys tem. State recordkeeping activities , including receiving and reviewing CWS reports and filing reports , are estimated at 0. 50 hours and 0.10 hours, respectively . Appendix B contains detailed burden and cost assumptions and calculations for primacy agencies. 2) Variance and Exemption Rule The burden for s tates is based on the number of s ystems applying for variances and exemptions. No systems are expected to apply for new variances or exemptions in this 3

- year ICR period; therefore, no burden is estimated for primacy a gencies for this rule. Detailed information about assumptions, burden, and calculations is provided in Appendix C. 3) C apacity Development Program As discussed in section 6(a)(i), the Capacity Development Program, is a state program designed to help drinking water s ys tems achieve and/or maintain technical, managerial and financial capacity to enhance a system ’ s ability to deliver safe drinking water

. The program consists of two major components :

1) Implementation of a program to ensure that all new CWSs and NTNCWSs demonstrate the capacity to comply with NPDWRs. 2) Implementation of a strategy to assist existing PW Ss in acquiring and maintaining capacity to comply with the SDWA. The burden estimate associated with new and existing capacity development efforts is based on expert opinions, including opinions provided by members of the NDWAC Small Sy stems Workgroup , and consultations with drinking water industry representatives. Specificall y, the burden estimate assumes that :

 States must review and approve applications for new s ys tems. This I CR assumes that on average there will be 8 new s ys tems per state per year. It will take state personnel an estimated 100 hours per s ys tem to review new sy stem documentation and information.

 Some applications for new sy stems will require state follow up. Upon initial review, all new s ys tems likely

will not meet states’ capacity criteria. An estimated 20 percent of new s ys tems appl yi ng for approval each year will be required to submitPublic Water Systems Supervision Program ICR October 2015

40 supplemental materials. It is estimated that a state will need 8 hours per s ys tem to review these materials.

 States must provide capacity develop ment assistance to some existing sy stems. One element that states must consider in their capacity development strategies is how to identify and prioritize the PWSs most in need of improving capacity. In estimating this burden, EPA assumed that states will assist 20 percent of CWSs, 7 percent of NTNCWSs, and 2.5 percent of TNCWSs each year. EPA estimates that on average a state will dedicate 4 hours of assistance to each of these existing sy stems.

 Every three years, the primacy

agen cy must submit a report t o the s tate's Governor on the progress and success of its strategy

. Itwill take an estimated 40 hours to coordinate and prepare this report, for an average annual burden of 13.3 hours per state. In total, the average annual state burden for capacity development efforts is 10 2 , 851 hours per ye ar. Appendix D summarizes the assumptions used to calculate the Capacity Development Program burden and provides detailed burden and cost calculations. 4) Gene ral State Primacy Activities As illustrated in Exhibit 7, approximately 81 percent of the state burden

— or 1, 242,199 hours

—is for activities that cannot be associated with specific drinking water rules or programs. These general primacy

activities include :

 Submission of grant applications. Primacy agencies are eligible to receive grants from EPA to implement their PWSS programs. To receive the grants , they must prepare program plans describing their planned activities and use of the grant funds. Primacy agencies must appl y for the grants on an annual basis. This activity is estimated to re quire 1,040 hours annually per s tate.

 Recordkeeping. Each primacy agency is required to maintain records of tests, measurements, anal ys es, decisions, and determination s performed on each PWS to assess compliance with the provisions of the state’s primary drinking water regulations. Recordkeeping is estimated to take 1,040 hours annuall y per s tate.

 Maintenance of data s ys tems is estimated to re quire 1,040 hours annually per s tate. Each primacy

agency must develop a method of storing all PWS inventory , compliance, and enforcement information that it uses to operate its PWSS oversight program. While EPA does not prescribe a storage method, states generally store this infor mation electronically

. States must routinely enter new inventory , compliance, and enforcement data into their data s ys tems. States must also modify their data sy stems as necessary
.

 Submission of ongoing violation reports is estimated to require 1,040 hour s annually per s tate. Each primacy

agency must provide EPA with information regarding all violations of the state drinking water regulations and with other selected water sy stem information that is necessary to determine compliance with the drinking waterPublic Water Systems Supervision Program ICR October 2015

41 requirements. States must also provide new and updated water s ys tem inventory information on an annual basis.

 Laboratory

certifications are estimated to require 728 hours annuall y per s tate. The state PWSS programs require that water sy stems conduct routi ne monitoring of water quality to ensure that the water produced meets all regulatory standards. States must have some method of ensuring that the laboratories conducting these analyses are qualified and capable of performing the tests. As a result, states must establish and maintain a program for certifying laboratories that may conduct the required compliance monitoring for PWSs.

 Plan and project reviews. Primacy agencies must establish and maintain a program that assures the design and construction of n ew or modified water s ys tem facilities that are capable of complyingwith the s tate primary dri nking water regulations. Most s tates achieve this assurance b y requiring state review and approval of plans and specifications for drinking water facility construction. Reviewing plans for major projects for s ys tems with more than 10,000 customers, between 3,301 and 10,000, and less than 3,300 customers is estimated to require 312 , 416, and 5, 200 hours annually per s tate, respectively . Reviewing plans for minor projects for s ys tems greater than 500 customers and fewer than 500 customers is estimated to require 1,040 and 2, 600 hours annually per s tate, respectively . Routine inspections are estimated to require 832 burden hours annually per s tate.

 Over sight of compliance monitoring

. States must ensure that water s ys tems monitor in accordance with the regulations. Where monitoring does not occur, states must take action to ensure that s ys tems monitor so that the quality of water is known and so that any appropriate actions can be taken. Where violations occur and are not expeditiously

corrected, states must take appropriate enforcement foll ow - up actions. States must maintain administrative penalty authority and the right to sue to ensure the effectiveness of their enforcement programs. These programs require an estimated average of 2,309 hours annually per state
.

 Training activities. Primac y agencies conduct rule training for both state staff and for PWS owners and operators. Training is ongoing for all program components

. Training accounts for 338 hours annuall y per state
. Appendix E summarizes the assumptions used to calculate the General State Primacy Activities burden and provides detailed burden and cost calculations. 5) Public Notification The burden to primacy

agencies for the PN Rule results from consulting with PWSs, reviewing the PWS compliance certification and notice copies, preparing quarterl y reports to EPA, and filing and maintaining the public notification records. The burden for primacy agencies for these activities is estimated to be 1 16 , 665 hours annuall y. This amounts to 2 , 047 hours per primacy agency . Note that RTCR net change burden (i.e., incremental burden over the 1989 TCR) related to RTCR public notification has been removed from the RTCR standalone I CR and is now accounted for in this I CR . This corresponds to a reduction in annual primacy agency burden , which is reflected in the annual burden estimate above

. Tier 1 consultation activitiesPublic Water Systems Supervision Program ICR October 2015

42 require an estimated 3.0 hours annuall y per s ys tem in violation , Tier 2 consultation requires an average of 1.1 hours and Tier 3 requires 0. 5 hours. The burden for receiving/rev iewing public notification certification is 0.2 hours and filing reports is 0.1 hours. Appendix F summarizes the assumptions used to calculate the PN Rule burden and provides detailed burden and cost calculations. 6) Operator Certification Program The burden to primacy

agencies for implementing an EPA

- approved Operator Certification Program includes the ongoing certification of operators and tracking fulfillment of operator certification requirements

. Other components of the Operator Certification program continue in this 3

- ye ar ICR period , including submitting a yearly report on the status of implementation , which will require 16 hours per state

. The total annual burden estimated for primacy agencies is 832 hours. Appendix G summarizes the assumptions used to calculate the Operator Certification Program burden and provides detailed burden and cost calculations. 7) Tribal Drinking W ater Operator Certification Program There is no burden to primacy agencies for the Tribal Drinking Water Operator Certification Program. 8) Constructed Conveyances EPA estimates that no new constructed conveyances will be built going forward, therefore no p rimacy

agencies will incur reporting or recordkeeping burden

. EPA historically assumed that 371 sy stems per year would be involved in the constructed conveyance program. In May 2015, EPA consulted states on its expectation that no constructed conveyances will be built going forward. Consultation confirmed this expectation. **6(a)(iii) Burden to Laboratories**  The annual l aboratory

burden for November 1, 2015 to October 31, 2018 is estimated to be approximately 42 , 892 hours. Exhibit 8 shows the annual burden to laboratories associated with PT . The bases for the burden estimate are detailed below (see Appendix Ifor additional de tails

. ) 1) Proficiency Testing This section describes the estimated average annual burden and costs for the information collection activities for PT studies that will be conducted b y drinking water laboratories. There is no burden for PT vendors or p rimacy a gencies. The burden for laboratories for these activities is estimated to be 42 , 892 hours annuall y . This estimate includes burden for participating laboratories to read instructions, plan activities, analyze samples, submit data to the PT vendors, and mai ntain records.Public Water Systems Supervision Program ICR October 2015

43 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 is discussed in more detail below.

 Read i nstructions: EPA assumes that each of the 1 , 902 respondents will require 4 .0 hour s to read the instructions provided by the vendor. The burden will be evenly divided between a manager and chemist.

 Plan a ctivities: EPA assumes that the manager of each laboratory will require 1 .5 hours to plan activities associated with the PT studies.

 Analyze inorganic c hemicals: EPA assumes that 871 laboratories will require approximately 16 hours to anal yz e PT standards for 29 inorganic chemicals. All hours will be incurred b y a chemist.

 An alyze DBPs: Chemists in 701 laboratories are assumed to require 8 .0 hours to anal yz e PT standards for 9 DBPs.

 Analyze organic c hemicals: Chemists in 330 laboratories are assumed to require 16.0 hours to anal yz e PT standards for 52 organic chemicals.

 Report results: EPA assumes that each of the 1 , 902 respondents will require 2 .0 hour s to report the results of the study to the PT vendor. The burden will be divided between a manager and records clerk.

 Maintain records: EPA assumes that a records clerk and manager in each of the 1,902 laboratories will require 1.0 hour each to maintain the files from the PT study

. **6(b) Respondent Costs**  **6(b)(i) Cost to Public Water Systems** Exhibit 6 shows the total costs for PWSs over the 3

- ye ar IC R period. Annual costs are estimated at approximately $ 11 4 million, which consists of $ 7 3 million in labor costs and $ 41 million in O&M costs

. Labor costs are based on the number of burden hours times the average hourly wage rate, including overhead. In addition to the labor costs, there are O&M costs associated with the CCR, the PN Rule, and Operator Certification Program and the Tribal Drinking Water Operator Certification Program. For the CCR, these costs reflect non

- labor costs associated with printing, delivery , posting, and publishing CCRs. These costs were carried forward from the previous ICRs, updated with current cost information (e.g., postage rates), and adjusted for inflation. CCR O&M costs and associated calculations are presented in greater detail in Appendix B. For the PN Rule these costs reflect non

- labor costs to print and distribute notices of violation. These costs were carried forward from the 2012 PWSS Program I CR. Appendix F shows the costs for the PN Rule in more detail. For the Operator Certification Program and Tribal Drinking Water Operator Certification , the expense reimbursement grants program ended in December 2012. Therefore, O&M costs such as fees paid by operators to obtain a new certification or renew their certification , as applicab le , in addition to travel and lodging costs incurred are no longerPublic Water Systems Supervision Program ICR October 2015

44 reimbursed b y the expense reimbursement program

. These costs are shown in more detail in Appendices G and H, respectivel y. There are no capital costs associated with this I CR. **6(b)(ii) Cost to Primacy Agencies**  Exhibit 7 shows that the annual costs to primacy agencies are estimated at approximately $ 70 million. All costs incurred b y primacy agencies are labor costs. Labor costs are based on the number of burden hours times the average hourl y wage rate, including overhead. Labor rates in 2013 dollars are used and are loaded with a 60 percent overhead factor. A loaded labor rate of $45.60 per hour in 2013 dollars was used for state labor. **6(b)(ii i** **) Cost to Laboratories** Exhibit 8 shows the total costs for laboratories over the three

- year ICR period. Annual costs are estimated at approximately $ 3

. 7 million, which consists of $ 0.8 million in O&M costs (fees for PT standards) and $ 2. 9 million in labor costs (numbers may not add due to rounding)

. Labor costs are based on the number of burden hours times the average hourly wage rate, including overhead. Labor rates in 2013 dollars are used and are loaded with a 60 percent overhead factor

. Loaded hourly labor rates in 2013 dollars for the three labor categories include a manager at an hourl y rate of $102.19 , a data entry clerical person at an hourly rate of $28.88 , and a skilled technician or chemist to conduct the measurements at an hourl y rate of $59.79

. O&M costs for laboratories are all costs related to providing personnel with the space, equipment, and materials necessary to perform the tasks required for PT studies. Since laboratories are driven by their compliance monitoring requirements to purchase the anal yt ical instrumentation and computers and not by PT requirements, no capital costs can be considered associated with PT studies. Only the cost associated with purchasing the PT standards is appropriate for consideration in this category

. Laboratories may

participate in the PT studies for some or all of the regulated contaminants. Because EPA does not have sufficient information to estimate how many anal yt es are contained in the PT samples sent to each laboratory , EPA has estimated a "worst case" scenario b y assuming that a sing le PT s et contains standards for each possible regulated anal yt e. Therefore, laboratories participating in the inorganic PT study are assumed to receive and run anal ys es for 29 anal yt es. Similarly, those participating in the PT study for DBPs and/or organic chemicals will receive samples for each of 9 anal ytes and/or each of 52 analy tes, respectivel y. EPA estimates the costs of each PT standard to be $ 1 6

. 81 per analy te.Public Water Systems Supervision Program ICR October 2015

45 **Exhibit 6 An**  **nual PWS Burden and Cost November 1, 2015**  **to October 31, 2018** 

**Exhibit 7 An**  **nual State Burden and Cost November 1, 2015 to October 31, 2018** 

**Annual L** **ab**

**or Cos**  **t ($ K)**  **Annual O&M** 

**Cos t ($**  **K) Total**  **Annual**

**Cos t ($**  **K) Cons**  **um er**  **Confi de**  **nc e**  **Re po**  **rt s**  955,671 $ 33,059 $ 19,616 $ 52,674 206,339 **Var ia** **nc e**  **and**

**E xe**  **mp ti**  **ons** - $ - N/ A $ - - **Cap ac**  **it y De**  **ve lo** **pm**

**en t**  128,851 $ 4,457 N/ A $ 4,457 13,918 **Ge ne**  **ra l**  **St ate**  **P rim** **ac y**  N/ A N/ A N/ A N/ A N/ A **Pub lic**  **Noti fi**  **ca**

**ti on**  779,393 $ 26,961 $ 7,654 $ 34,614 110,520 **Op era**  **tor Ce**  **rt if** 

**ica ti**  **on** 315,919 $ 7,723 $ 13,821 $ 21,545 19,745 **Tr ib**  **al Op**  **era tor**  **Ce rt** **if ica**  **ti on**  10,027 $ 347 $ 194 $ 541 251 **Cons tr**  **uc te**  **d Conv** 

**ey anc**  **es** N/ A N/ A N/ A N/ A N/ A **Pro fi**  **cien cy** 

**Te st** **in g**  N/ A N/ A N/ A N/ A N/ A **TO TAL**  **2 ,1**  **89, 861**  **$ 7**  **2, 547**  **$ 4**  **1, 284**  **$ 1**  **13, 831**  **3 50,**  **773** Not e: D et ail may not add ex act ly t o t ot als due t o roundi ng. **Ac ti**  **vi ty**  **Annual B**  **ur de**  **n Ho** **ur s**  **Annual Re**  **sp ons**  **es Cos**  **t**

**Lab or**  **Co st**  **($ K)**  **O&M**

**Cos t ($**  **K) Total**  **Cos t ($**  **K) Cons**  **um er**  **Confi de**  **nc e**  **Re po**  **rt s**  73,912 $3,37 0 N/ A $ 3,370 122,68 9 **Var ia** **nc e**  **and**

**E xe**  **mp ti**  **on s**  - $- N/ A $ - - **Cap ac**  **it y De**  **ve lo** **pm en**  **t** 102,851 $4,69 0 N/ A $ 4,690 13,91 8 **Ge ne**  **ra l**  **St ate**  **Pr im** **ac y**  1,242,199 $56,644 N/ A $ 5 6,644 149,76 5 **Pub lic**  **Noti fi**  **ca ti**  **on** 116,665 $5,32 0 N/ A $ 5,320 381,93 1 **Op era** **tor Ce**  **rt if** 

**ica ti**  **on** 832 $3 8 N/ A $ 38 19,74 5 **Tr ib**  **al Op**  **era tor**  **Ce rt** **if ica** **ti on**  N/ A N/ A N/ A N/ A N/ A **Cons tr**  **ucte d**  **Conv**

**ey anc**  **es** N/ A N/ A N/ A N/ A N/ A **Pro fi**  **cien cy** 

**T es**  **ti ng**  N/ A N/ A N/ A N/ A N/ A **TO TAL**  **1 ,5**  **36, 459**  **$ 7**  **0, 063**  **N/ A**  **$ 7**  **0, 063**  **6 88,**  **047** No te : D et ail may not add ex act ly t o t ot als due t o rounding

. **Annua l**  **Re sp**  **on se**  **s Ac**  **ti vi**  **ty Annua**  **l Bu**  **rd en**  **Ho ur**  **s Annual**  **Cos t** Public Water Systems Supervision Program ICR October 2015

46 **Exhibit 8 An**  **nual Laboratory Burden and Cost November 1, 2015 to October 31, 2018** 

**6(c) Agency Burden and Costs**  EPA’s drinking water program incurs burden both at Headquart ers and R egion al offices to assist states in implementing drinking water regulations. Inprevious I CRs for the PWSS Program, burden associated with EPA’s enforcement and compliance activities at Headquarters and the Regions w as also included in the Agency ’ s burden and cost estimates. With the implementation of the Government Performance and Results Act in federal fiscal year 1999, it has become difficult to isolate the resources ( full time equivalents ( FTEs ) and dollars) for drinking water enforcement and compliance activities from the overall OECA operating plan. Thus, this section presents only the burden and costs incurred b y EPA’s water program, especiall y drinking water protection, at Headquarters and in Regions. It is important to note that the burden and costs presented below cover ongoing activities for all EPA drinking water programs), including rule development activities. **EPA Headquarters** There are 44.2 Headquarters FTEs dedicated to drinking water protection implementation activities. 9 The following assumptions were used to develop a cost estimate for Headquarters :

 The average salary

and benefits (i.e., personnel compensation and benefits (PC&B)) of th e 44.2 FTEs is at the GS 13, Step 5 level of $ 129,968

. 10

9 FTE figures based on percentage reduction in previous ICR levels due to workforce consolidation. 10 Base salary, United States Office of Personnel Management ( http://www.opm.gov/policy

- data

- oversight/pay

leave/salaries

- wages/2013/general

- schedule/gs.pdf ). 2013 pay schedule (rates frozen at 2010 levels). Loaded with a 60 percent loading factor. **Lab or**  **Co st**  **($ K)**  **O&M**

**Cos t ($**  **K) Total**  **Cos t ($**  **K) Cons**  **um er**  **Confi de**  **nc e**  **Re po**  **rt s**  N/ A N/ A N/ A N/ A N/ A **Var ia** **nc e**  **and**

**E xe**  **mp ti**  **on s**  N/ A N/ A N/ A N/ A N/ A **Cap ac**  **it y De**  **ve lo** **pm en**  **t** N/ A N/ A N/ A N/ A N/ A **Ge ne**  **ra l**  **St ate**  **Pr im** **ac y**  N/ A N/ A N/ A N/ A N/ A **Pub lic**  **Noti fi**  **ca**

**ti on**  N/ A N/ A N/ A N/ A N/ A **Op era**  **tor Ce**  **rt if**  **ica ti**  **on** N/ A N/ A N/ A N/ A N/ A **Tr ib**  **al Op**  **era tor**  **Ce rt** **if ica**  **ti on**  N/ A N/ A N/ A N/ A N/ A **Cons tr**  **ucte d**  **Conv**

**ey anc**  **es** N/ A N/ A N/ A N/ A N/ A **Pro fi**  **cien cy** 

**T es**  **ti ng**  42,892 $2,891 $819 $3,710 1,902 **TO TAL**  **42, 892**  **$2, 891**  **$819 $3,**  **710 1,**  **902** No te : D et ail may not add ex act ly t o t ot als due t o rounding

. **Ac ti**  **vi ty**  **Annua l**  **Bu rd**  **en Ho**  **ur s**  **Annua l**  **Re sp**  **on se**  **s Annual**  **Cos t** Public Water Systems Supervision Program ICR October 2015

47  An FTE is 2,080 hours/year . Given these assumptions, the following calculations yield the annual labor cost for Headquarters :

 The 44.2 FTEs equal 9 2,005 hours ( 44.2 *2,080).

 The labor cost of 44.2 FTEs is $ 5,74 8,875 ( 44.2 *$ 129,968 ). For most of the programs and regulations covered in the PWSS I CR, there are no O&M costs. However, EPA incurs O&M costs for EPA contractors to manage the SDWI S database. These O&M costs are directly related to the coll ection of the information discussed in this I CR and include SDWI S/state and SDWI S/FED maintenance and user support for the sy stem. The SDWI S O&M cost for Headquarters is $450,000. 11 Note that because the EPA burden and labor costs calculated above address burden for all drinking water programs, including tribal operator certification, the EPA burden and labor costs calculated for tribal operator certification in Appendix H were not added to the labor burden discussed in this section. **EPA Regional Offices** There are 206.4 R egional FTEs dedicated to drinking water protection implementation activities

. 12 The following assumptions are used to develop a cost estimate for the Regions

—

 The average salary

and benefits (i.e., PC&B) of the 206.4 FTEs is at the GS 11, Step 5 level of $ 91,186

. 13

 An FTE is 2,080 hours/year. Given these assumptions, the following calculations yield the annual labor cost for the 10 EPA R egional offices

—

 The 206.4 FTEs equal 429, 293 hours ( 206.4 *2,080).

 The labor cost of 206.4 FTEs is $ 18,8 19,887 ( 206.4 *$ 91,186 ). The total cost to the f

ederal government is the sum of the labor cost to Headquarters ($ 5,748,875 ), the labor cost to EPA R egional offices ($ 18,819,887 ) , and O&M cost s to Headquarters ($ 450,000 ), for a total of $ 2 5 , 0 18 , 762

. Note that there are no O&M costs to EPA R egional offices. Similarly , the total burden to the f ederal government (H eadquarters and Regions) is 521,2 9 8 hours for 250.6 FTEs.

11 SDWIS O& M costs based on comments received from EPA WACOR, Kevin Roland (5/12/2015) 12 FTE figures based on e

- ma il correspondence from EPA WA COR, Kevin Roland ( 02/02/2015 ). 13 Base salary, United States Office of Personnel Management ( http://www.opm.gov/policy

- data

- oversight/pay

leave/salaries

- wages/2013/general

- schedule/gs.pdf ). 2013 pay schedule (rates frozen at 2010 levels). L oaded with a 60 percent loading factor.Public Water Systems Supervision Program ICR October 2015

48 **6(d) Estimating Respondent Universe and Total Burden and Costs**  Respondents for this I CR include PWSs, laboratories, and states or other primacy agencies. This ICR estimates the number of PWS respondents at 1 49 , 765

. Not every PWS is necessarily

subject to each of the information collection requirements contained in this I CR. The regul ations associated with each ICR will identify the ty pes of PWSs that are subject to each particular drinking water regulation. In addition to the PWS respondents, this I CR assumes 57 primacy agencies (50 states plus the District of Columbia , U.S. territories, and the Navajo Nation) , 14 and 1 , 902 laboratories. Therefore, the total number of respondents is 15 1 , 724

. The total costs and burden for these respondents are summarized in Exhibits 6

– 8

. Agency costs and burden are detailed in section 6(c). **6(e) Bottom Line Burden Hours and Costs**  The bottom line burden hours and costs are presented in Exhibit 9. The total annual respondent burden associated with this I CR is estimated to be approximately 3.8 million burden hours. The corresponding total annu al respondent costs (labor, capital, and O&M) are estimated to be $ 187.6 million. The total national burden, including respondent burden and EPA burden, is estimated to be 4. 3 million hours annuall y. The total national cost, for respondents and EPA, is est imated to be $ 21 2.6 million annually

.

14 Thi s is a simplifying assumption. Primacy activities for Wyoming and the District of Columbia are actually carried out by the respective EPA Regional offices.Public Water Systems Supervision Program ICR October 2015

49 **Exhibit 9 Bottom Line A**  **nnual Burden and Cost November 1, 2015 to October 31, 2018**  **151, 724**  (=) 149,765 (+) Ex

is ti ng PW Ss 57 (+) Pri

ma cy agencies 1,902 Laborator

ie s **1, 040,**  **722** (=) 350,773 (+) PW S re sp ons es (s ee E xh ib it6) 688,047 (+) Pri

ma cy agency re sp onse s (s ee Ex hi bi t 7) 1,902 Laborator

y res ponses (s ee Ex

hi bi t 8) **6. 9**  (=) 1, 040,722 (/ ) Total

annual re spons es fro m above 151,724 Total

n um be r o f re sp ondents fro m above **3, 769,**  **213** (=) 2, 189,861 (+) PW S h ours (s ee E xh ib it6) 1, 536,459 (+) Pri

ma cy agency hours (s ee Ex hi bi t 7) 42,892 Laborator

y hours (s ee Ex

hi bi t 8) **3. 62**  (=) 3, 769,213 (/ ) Total

annual re sponde nt hours fro m above 1, 040,722 Total

annual re spons es fro m above **$42, 103**  (=) $41,284 (+) Total

PW S O&M co st s (s ee E xh ib it6) N/ A (+) Total

p rim acy agency O&M c os ts (s ee Ex hi bi t 7) $819 Total

laborator y O&M c os ts (s ee Ex

hi bi t 8) **$187, 603**  (=) $113,831 (+) Fo r PW Ss (s ee Ex hi bi t 6) $70,063 (+) Fo r p ri

ma cy ag encies (s ee Ex

hi bi t 7) $3,710 Fo r laborator ie s (s ee Ex

hi bi t 8) **Total Annual**  **H**

**our s**  **(res p.** **p**

**lu s**  **Ag en**  **cy**

**) 4,**  **290, 511**  (=)

3, 769,213 (+) Total

re sponde nt hours 521,298 (+) Total

E PA h ours **Total Annual**  **Cos t (r**  **es p.** **p lu**  **s Ag**  **ency**

**) ($ K)**  **$212, 622**  (=)

$187,603 (+) Total

re sponde nt co st $25,019 Total

E PA Co st No te : D et ail may not add ex act ly t o t ot als due t o rounding

.

1 No c ap it al co sts are ass oc iat ed w it h t hePW SS ICR in t hi s evaluat io n p eriod. To tal annual EP A hours a nd cos ts reflect t hecombined burden and cos t for H eadquart ers st aff (ap prox imat ely 44 F TE s) and reg ional s taff (a pprox imat ely 206 F TE s) . Cost s als o i nc lu deO &M cos ts incurred for EPA c ont ract ors t o man ag e t he SDW

IS dat abas e ($450,000). **Total Annual**  **Re sp** 

**on de**  **nt Co st** 

**(L ab**  **or , Cap**  **it al**  **, and**  **O&M ) ($**  **K) Num**  **be r o** **f Re sp** 

**ond ents** 

**Num be**  **r o f Re**  **sp**

**ons es**  **p er**  **Re sp**  **ond ent** 

**Hou rs**  **p er**  **Res po**  **ns e** 

**Annual Re**  **sp**

**ond en** **t O& M**  **an d**  **Cap**

**it al**  **Co st**  **($ K)**  **1 Total**  **Re sp** 

**ond ent H**  **ou rs**  **Total Annual**  **Re sp** 

**on se**  **s**Public Water Systems Supervision Program ICR October 2015

50 **6(f) Reasons for Change in Burden**  This section presents the change in burden and explains the reasons for the change in burden. The discussion is divided into two parts

—

 Section 6(f)(i) summarizes the differences between the burden estimated in the 2012 PWSS Program ICR and the current OMB inventory for the PWSS Program I CR. See Exhibit 11.

 Section 6(f)(ii) summarizes other adjustments to the annual burden estimates associated with each rule in the PWSS Program ICR. See Exhibits 12

- 14. Exhibit 10 summarizes how each of these changes has affected the overall burden inventory for the PWSS Program I CR. **Exhibit 10**

**Summa ry** 

**of Changes in A nnual Burden**  **(Inclu des PWS,**  **Primacy A** **gency , and Laboratory**  **Burden)**

**6(f)(i) Restructuring Adjustments**  No restructuring adjustments are being made for the addition of new stand

- alone ICRs to the PWSS I CR , as shown in Exhibit 11 . In the next revision to the PWSS ICR , burden from relevant standalone ICRs that have expired will be newly incorporated into the PWSS I CR. **Exhibit 11 Restructuring A** **djustments to the An**  **nual Burden Inventory for the PWSS Program ICR**  **(Includes PWS, Primacy Ag**  **e ncy**  **, and Laboratory Burden)**  **Typ e**  **of Chang e**  **Burd en** **(hour s)**  **Runni ng**  **T otal**  **Comm en** **t** Bu rd en E st im ated i n the 2012 PW SS Pro gram

ICR 4,113,408 4,113,408 Th is b urden se rv es as t he bas el in e fo r t he 2015 PW SS Pro gram ICR. Re st ru ctur

in g Adj ust me nts –s ee Se ction 6(f)(i) 0 4,113,408 2015 P WS S Pro gram ICR is n ot appended wit h burden fro m any new ICRs
. Ot her A dj us tm ents t o Bu rd en –s ee Section 6(f)(ii) (344,195) 3,769,213 Bu rd en fo r wh ic h EPA se eks approva l in t his ICR. Not e: D et ail may not add ex act ly t o t ot als due t o rounding.

**Ac ti**  **on Annual**  **B urd**  **en H our**  **s Brief** 

**E xp**  **la na**  **ti on**  N/ A 4,113,408 In ventor y fo r t he 2 012 PW SS Pro gram ICR car rie d fo rwa rd a s the ba se lin e fo r 2015 PW SS Pro gram

ICR. Add 0 2015 P WS S Pro gram ICR is n ot ap pended wit h burden fro m an y new ICRs
. **Total 4,**  **113, 408**  **PWS S**  **Pro gra** **m IC**  **R i nv**  **ento ry**  **b as**  **ed on c**  **ur rent** 

**b ur**  **de n i**  **nv ento**  **ries .** Public Water Systems Supervision Program ICR October 2015

51 **6(f)(ii) Additional Program Adjustment**  **s** The remaining changes in burden consist of program adjustments for activities that were carried forward from existing ICRs to this PWSS Program I CR renewal. Changes in calculated burden are a result of updating relevant baseline information for each rule with the most current and accurate information on activity compliance. Exhibits 12

- 14 summarize reasons for these changes and quantify

the changes b y activity

. Burden adjustments a ssociated with PWS activities resulted in a burden de crease of 2 27 , 566 hours and are shown in Exhibit 12. Burden adjustments for primacy

agencies resulted in a de c rease of 116,629 hours per ye ar, as shown in Exhibit 13. Burden adjustments for laboratories resulted in no change in burden hours , as shown in Exhibit 14. **Exhibit 12**

**Ad justments to PWS Burden from Previous ICR Estimates** 

**Activity Previous** 

**Annual Burden**  **Estimate (Hours)**  **2015 Annual**

**Burden Estimate**  **(Hours) Annual** 

**Change in Burden**  **(Hours) Reason**  **for Change in Burden**

**Consumer Confidence**  **Reports** 963,561 955,671 (7,890) The net change in the burden is attributed to the adjustments made in the modeling inputs to account for updated PWS inventory, as well as an anticipated increase in the use of electronic CCR delivery. This ICR estimates that approximately 30% of PWSs serving 100,000 or more customers will deliver CCRs electronically. **Variance and Exemptions**  9,066

- (9,066) This ICR assumes that no new variances or exemptions will be issued under this 3 year period. The burden associated with the V&E rule is recordkeeping requirements for issued variances and exemptions. **Capacity Development**  131,114 128,851 (2,263) The net change in the burden is attributed to the decrease in PWS inventory. **General State Prim**  **acy** N/A N/A N/A N/A

**Public Notification** 1,038,435 779,393 (259,042) The net change in the burden is attributed to the adjustments made in the modeling inputs to account for the decrease in the PWS inventory, as well as the decrease in public notifications issued. The burden for the recently promulgated RTCR is now accounted for under the 2015 PWSS Program ICR. The new regulatory requirements established by the RTCR account for a reduction in burden of approximately 93,000 hours.

**Operator Certification**  **Program** 263,018 315,919 52,901 The net change in burden is attributed to the adjustments made in the modeling inputs to account for updated PWS inventory, as well as to acc ount for the burden previously offset by the implementation of the expense reimbursement grants. The expense reimbursement grants provided funding to reimburse the cost of training and certification, including per diem for unsalaried operators, for systems serving less than 3,300.

**Tribal Operator Certification**  **Program** 4,739 10,027 5,288 The net change in burden is attributed to the adjustments made in modeling inputs to account for updated PWS inventory, as well as to account for the burden previously offset by the implementation of the expense reimbursement grants. The expense reimbursem ent grants provided funding to reimburse the cost of training and certification, including per diem for unsalaried operators, for systems serving less than 3,300. **Constructed Conveyances**  7,496 N/A (7,496) This ICR assumes that no new constructed conveyances will be permitted under this 3 year ICR period. The burden associated with the constructed conveyances is recordkeeping requirements. **Proficiency Testing** N/A N/A N/A N/A **TOTAL 2,417,427**  **2,189,861 (227,566)**  **PWS change in burden after adjustments.** Note: Detail may not add exactly to totals due to rounding.Public Water Systems Supervision Program ICR October 2015

52 **Exhibit 13 Ad** **justments to Primacy A** **gency Burden**  **from Previous ICR Estimates**

**Activity Previous**  **Annual Burden**  **Estimate (Hours)**  **2015**

**Annual Burden**  **Estimate (Hours)**  **Annual**

**Change in Burden**  **(Hours) Reason for Change in Burden**  **Consumer Confidence Reports**  75,698 73,912 (1,786) The net change in the burden is attributed to the adjustments made in the modeling inputs to account for the decrease in the PWS inventory.

**Variance and Exemptions**  76,293

- (76,293) This ICR assumes that no new variances or exemptions will be issued under this 3 year period. The rule requires primacy agencies to review each variance to determine if the PWS continues to meet eligibility criteria. **Capacity Development**  103,983 102,851 (1,131) The net change in the burden is attributed to the decrease in PWS inventory. **General State Prim**  **acy** 1,242,199 1,242,199

- N/A

**Public Notification** 107,175 116,665 9,490 The net change in the burden is attributed to the adjustments made in the modeling inputs to account for the decrease in the PWS inventory, as well as the increase in Tier 3 public notificati ons issued. The primacy agency burden for Tier 3 violations is based on the actual number of violations, while the PWS burden for Tier 3 violations is based on the number of PWSs with violations. The burden for the recently promulgated RTCR is now accounted for under the 2015 PWSS Program ICR. The new regulatory requirements established by the RTCR account for a reduction in burden of approximately 8,700 hours. The decrease in burden due to the RTCR helps offset the increase in burden due to the increase in number of Tier 3 public notification violations.

**Operator Certification Program**  3,565 832 (2,733) The net change in burden is attributed to the adjustments made in modeling inputs to account for updated PWS inventory, as well as to account for the burden of implementing the expense reimbursement grant program. The last expense reimbursement grant was c losed December 2012. **Tribal Operator Certification Program**  N/A N/A N/A N/A

**Constructed Conveyances**  44,175 N/A (44,175) This ICR assumes that no new constructed conveyances will be permitted under this 3 year ICR period. The burden associated with the constructed conveyances is reporting and recordkeeping requirements. **Proficiency Testing** N/A N/A N/A N/A **TOTAL 1,653,088**  **1,536,459 (116,629)**  **Adjusted Primacy Agency Burden** Note: Detail may not add exactly to totals due to rounding.Public Water Systems Supervision Program ICR October 2015

53 **Exhibit 14 Ad** **justments to Laboratory Burden**  **from Previous ICR Estimates**

**Activity Previous** 

**Annual Burden Estimate**  **(Hours) 2015 Annual** 

**Burden Estimate**  **(Hours) Annual Change** 

**in Burden (Hours)**  **Reason for Change in Burden**

**Consumer Confidence Reports**  - **- -**  N/A **Variance and Exemptions**  - **- -**  N/A **Capacity Development**
- **- -**  N/A **General State Primacy**
- **- -**  N/A **Public Notification**
- **- -**  N/A **Operator Certification Program**  - **- -**  N/A **Tribal Operator**  **Certification Program** - **- -**  N/A **Constructed Conveyances**  - **- -**  N/A
**Proficiency Testing** 42,892 42,892

- The assumptions from the previous ICR were used because updated information on the number of certified laboratories was not available. **TOTAL 42,892**  **42,892 -**  **Adjusted Laboratory Burden** Note: Detail may not add exactly to totals due to rounding. Exhibit 15 shows the e ffect of these adjustments on the bottom line burden. Subtracting 227,566 hours to account for the adjustment to PWS burden , subtracting 116,629 hours to account for the adjustment to primacy agency burden , and making no change in hours for the adjustment to laboratory

burden yi elds 3,769,213 hours.

**Exhibit 15 Ad** **justments to Ac**  **tivities Carried Forward from Previous ICRs (Includes**  **PWS , Primacy**  **Ag e**  **ncy , and Laboratory**  **Burden) Action**  **Annual Burden Hours Brief Explanation**  N/A 4,113,408 Inventory after restructuring adjustments, and other adjustments to burden as tabulated in Exhibit 11

. Subtract (227,566) Adjustments for PWS activities carried forward from previous ICRs as tabulated in Exhibit 12

. Subtract (116,629) Adjustment for primacy agency activities carried forward from previous ICRs as tabulated in Exhibit 13

. N/A 0 Adjustment for laboratory activities carried forward from previous ICRs as tabulated in Exhibit 14

. **Total 3,769,213**  **Equals hours requested in 2015 PWSS Program ICR**  **as tabulated in**  **Exhibit 9 .**  Note: Detail may not add exactly to totals due to rounding.Public Water Systems Supervision Program ICR October 2015

54 **6(g) Burden Statement**  The public reporting burden for collections included in this I CR is detailed in Exhibit 15 above. The annual respondent burden is estimated to average approximately 3.8 million hours, of which 2. 2 million hours are attributable to PW Ss, 1. 5 million hours to primacy agencies, and 0.0 4 million hours to laboratories. These estimates include time for gathering information as well as developing and maintaining records. Burden means the total time, effort, or financial resources expended b y people to generate, maintain, retain, disclose, or provide information to or for a f ederal agency

. This includes the time needed to review instructions; develop, acquire, install, and utilize technology , and sy stems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to comply with an y previously

applicable instr

uctions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor , and a person is not required to respond to, a request for information collection unless it displays a currentl y valid OMB control number. The OMB control numbers for EPA’s re gulations 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 I CR under Dock et ID Number EPA

- HQ

- OW

- 2011

- 0443 , which is available for online viewing at www.regulations.gov , or in person viewing at the Water Docket in the EPA Docket Center (EPA/DC), WJC West, Room 3334 , 1301 Constitution Av e., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday , excluding legal holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the Water Docket is (202) 566

- 2426. An electronic version of the public docket is available at www.regulations.gov . This site can be used to submit or view public comments, to access the index listing of the contents of the pub lic docket, and to access those documents in the public docket that are available electronicall y. When in the sy stem, select “search,” then key

in the D ocket ID Number identified above. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number ( EPA

- HQ

- OW

- 2011

- 0443 ) and the OMB Control Number 2040

- 0090 in any correspondence.