Information Collection 

Request for the Public 

Water System 

Supervision Program

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TABLE OF CONTENTS

1 IDENTIFICATION OF THE INFORMATION COLLECTION........................................... 1

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

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

2(a) Need/Authority for the Collection.................................................................................... 4

2(b)Use/Users of the Data..................................................................................................... 10

3 NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA 11

3(a) Non-duplication.............................................................................................................. 11

3(b)Public Notice Required Prior to ICR 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)Sensitive Questions........................................................................................................ 12

4 RESPONDENTS AND INFORMATION REQUESTED.................................................... 13

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

4(b)Information Requested ................................................................................................... 13

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

4(b)(ii) Respondent Activities........................................................................................ 22

5 INFORMATION 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 Systems..................................................................... 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 Systems ........................................................................... 43

6(b)(ii) Cost to Primacy Agencies ................................................................................ 44

6(b)(iii) Cost to Laboratories........................................................................................ 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 ........................................................................................................... 54
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APPENDICES

Appendix A. Federal Register Notice Soliciting Comment on Information Collection Requests

Appendix B. Consumer Confidence Reports 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. Proficiency Testing Spreadsheets
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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 Requirements.................................. 23

Exhibit 5: PWSS Program Requirements for EPA Regions and Headquarters..................... 29

Exhibit 6: Annual PWS Burden and Cost (November 1, 2015 to October 31, 2018)........... 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 Line 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 Previous ICR Estimates.............. 52

Exhibit 14: Adjustments to Laboratory Burden from Previous ICR Estimates....................... 53

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

Th

is 

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LIST OF FIGURES

Figure 1: Structure of OGWDW ICRs...............................................................5
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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 System

DBP Disinfection Byproduct

DBPR Disinfectants and Disinfection Byproducts Rule

DDBP/Chem/Rads Disinfectant/Disinfection Byproducts, Chemical, and Radionuclides

DWIG TSA Drinking Water Infrastructure Grant Tribal Set Aside

DWSRF Drinking Water State Revolving Fund

EPA Environmental Protection Agency

ERP Enforcement Response Policy

ETT Enforcement Targeting Tool

FR Federal Register

FTE Full Time Equivalent

GWR Ground Water Rule

ICR Information 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

MCLG Maximum Contaminant Level Goal

MRDL Maximum Residual Disinfection Level

MRDLG Maximum Residual Disinfection Level Goal 

NAICS North American Industry Classification System

NAWA Native American Water Association

NAWC National Association of Water Companies

NCWS Noncommunity Water System

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 System

O&M Operation and Maintenance

OGWDW Office of Ground Water and Drinking Water

OMB Office of Management and Budget

PC&B Personnel Compensation and Benefits

PN Public Notification

PRA Paperwork Reduction Act

PT Proficiency Testing
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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

SDWIS Safe Drinking Water Information System

SMCL Secondary Maximum Contaminant Level

SWAP Source Water Assessment Program

SWTR Surface Water Treatment Rule

TCR Total Coliform Rule

TNCWS Transient Noncommunity Water System

UCMR Unregulated Contaminant Monitoring Rule

UIC Underground Injection Control

V/E Variance and Exemption 
Public Water Systems Supervision Program ICR October 2015

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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: 0270.46

 

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 adversely impact 

human health. The Act requires EPA to monitor and enforce these regulations to ensure that the 

nation’s drinking water dependably complies with the maximum contaminant levels (MCLs) 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 records, 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 

section 1413 – ensure 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 

successfully participate in Proficiency Testing (PT) studies each year to be certified to conduct 

analysis of compliance monitoring samples. 

As part of the PWSS Program, OGWDW uses the Safe Drinking Water Information 

System (SDWIS) to record some of the data collected as a result of NPDWR requirements. 

These data assist EPA in fulfilling its SDWA obligations. SDWIS is a database management 

system that assists EPA in tracking and interpreting violations data and other program-related 

data. Revisions are currently being made to SDWIS. EPA expects primacy agencies to fully 

transition to the revised system, a centralized, cloud-based system called SDWIS Prime, in the 

subsequent ICR period.

Many information collection requirements associated with the SDWA and its 

implementing regulations are associated with rulemakings that address specific contaminants or 

groups of contaminants. This ICR examines PWS, primacy agency, laboratory, and EPA burden 

and costs for “cross-cutting” recordkeeping and reporting requirements (i.e., the burden and costs 

for complying 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

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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 Conveyances2

9) Proficiency Testing (PT)

This ICR updates the burden and cost estimates provided in the 2012 PWSS Program 

ICR, which expires on October 31, 2015. The ICR estimates costs for November 1, 2015 to 

October 31, 2018.

The total annual respondent burden associated with this ICR is estimated to be 

approximately 3.8 million hours per year. The 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 million hours and 1.5 million hours, 

respectively. Laboratories conducting PT incur an annual burden of 42,892 hours. The 

distribution of annual costs between PWSs and primacy agencies is approximately $113.8

million and $70.1 million, respectively. The annual costs for laboratories conducting PT are $3.7

million.

The approximate annual operation and maintenance (O&M) costs for respondents are $42

million, with $41 million for PWSs, $0.82 million for laboratories, and no O&M costs for 

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

costs are for O&M only. There are no capital costs associated with the activities covered by this 

ICR.

The annual EPA burden for this ICR totals 0.52 million hours, at a cost of approximately

$25.0 million; 0.09 million hours, approximately $5.7 million, is for Headquarters activities and 

0.43 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 

SDWIS database.

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The total number of respondents for this ICR is 151,724; 57 of these respondents are 

primacy agencies, 1,902 are laboratories, and the balance, 149,765, are PWSs. The total annual 

number of responses for these respondents is 1.0 million (350,773 for PWSs, 1,902 for 

laboratories, and 688,047 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 estimates 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 expenses for FY14. 
Public Water Systems Supervision Program ICR October 2015

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Public Water Systems Supervision Program ICR October 2015

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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 ICR contains a 

summary of the PWSS Program recordkeeping and reporting requirements covered by this ICR.

To allow the public to better understand the impact of the recordkeeping and reporting 

requirements stemming from the SDWA and 40 CFR Parts 141 and 142, OGWDW has 

organized its ICRs so that related activities are addressed in the same ICR. Specifically, there are 

three primary ICRs—the Microbial Rules ICR, the Disinfectants/Disinfection Byproducts, 

Chemical and Radionuclides Rules (DDBP/Chem/Rads Rules) ICR, and the PWSS Program 

ICR. The Microbial Rules ICR 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 ICR includes rules addressing chemical 

contaminants such as the Stage 2 Disinfectants and Disinfection Byproducts Rule (Stage 2

DBPR), the Arsenic Rule, and the Lead and Copper Rule (LCR). The PWSS Program ICR 

includes public notification and rules addressing cross-cutting requirements that are not 

associated with contaminant-specific rules. 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 ICR 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 ICRs, see Figure 1. A 

complete itemization of the activities included in the three primary ICRs, as well as other 

drinking water program ICRs, is included as Exhibit 1.
Public Water Systems Supervision Program ICR October 2015

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Green = Activities remain 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

Chems LCR Stage 1 3

Arsenic Rads Stage 2

Lab QA

2040-0246

Needs Survey

2040-0274

DW SRF

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

Testing

CCRs PN

State Primacy

Activities

Op Cert Tribal 

Op Cert

Constructed 

Conveyances

1 RTCR burden and costs incurred after April 2016 are being 

added to TCR.

2 DDBP/Chem/Rads Rules ICR includes disinfectant residual 

monitoring under SWTR

3

Includes LCR Short-Term Revisions 

Microbial Rules ICR

2040-0205

IESWTR SWTR2

LT1

FBRR TCR/

RTCR1

GWR

LT2 ADWR

UCMR 4

2040-0270
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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

Proficiency Testing

Microbial Rules ICR (2040-0205)

Surface Water Treatment Rule, except disinfectant 

residual monitoring and associated activities4

Total Coliform Rule/ Revised Total Coliform Rule

Interim Enhanced Surface Water Treatment Rule 

(IESWTR) 

Filter Backwash Recycling Rule

Long Term 1 Enhanced Surface Water Treatment 

Rule (LT1ESWTR)

Long Term 2 Enhanced Surface Water Treatment 

Rule (LT2ESWTR)

Ground Water Rule

Aircraft Drinking Water Rule

Disinfectants/Disinfection Byproducts, Chemical, and Radionuclides Rules ICR (2040-0204)

Stage 1 Disinfectants and Disinfection Byproducts 

Rule Lead and Copper Rule Long Term Revisions

Disinfectant Residual Monitoring and associated 

activities under the SWTR

Stage 2 Disinfectants and Disinfection Byproducts 

Rule

Chemical Phase Rules

Radionuclides Rule 

Arsenic Rule

Lead and Copper Rule

Source Water Assessment Program (SWAP) ICR (2040-0197)

SWAP

Underground Injection Control (UIC) Program ICR (2040-0042) 

UIC Base Program Activities

Classes I-VI Rules

Florida Class I Rule

Drinking Water State Revolving Fund (DWSRF) Program ICR (2040-0185)

Drinking Water 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

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Currently covered To be covered in the future

Drinking Water Infrastructure Needs Survey ICR (2040-0274)

Drinking Water Infrastructure Needs Survey

Title VI of the Public Health Security and Bioterrorism Preparedness and Response Act of 2002: 

Drinking Water Security and Safety ICR (2040-0253)

Vulnerability Assessments and Emergency 

Response Plans for community water systems 

(CWSs).

Unregulated Contaminant Monitoring Rule ICR (2040-0270)

Monitoring of Unregulated Contaminants (UCMR 3) UCMR 4

Laboratory Quality Assurance Evaluation Program for Analysis of Cryptosporidium ICR (2040-

0246)

Proficiency Testing 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. Other rulemakings 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 apply for a variance or exemption. Variances allow 

eligible systems 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 come into compliance. There are

two types of variances: 1) general variances are intended for systems that are not able to comply 

with a NPDWR due to the quality of the source water, and 2) small system variances are 

intended for systems serving 3,300 or fewer people that cannot afford to comply with a NPDWR.

Small system variances are only allowed if EPA designates a Small System Variance 

Technology. The information required of PWSs seeking general variances, small system 

variances, or exemptions is needed to determine if the system satisfies SDWA conditions for 

variances or exemptions. 
Public Water Systems Supervision Program ICR October 2015

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3) Capacity Development Program

Through the 1996 SDWA Amendments, Congress conveyed the importance of PWSs to 

maintain technical, managerial, and financial capacity to comply 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 SDWIS. Additionally, primacy agencies must maintain records of analysis 

results and other related activities (e.g., sanitary survey results). Without comprehensive, up-todate information on drinking water contamination), EPA would not be able to ensure “a supply

of drinking water which dependably complies with such maximum contaminant levels” (SDWA 

section 1401(1)(d)). If these reporting requirements were voluntary, EPA would not receive 

timely, comprehensive data on contaminant levels and associated acute and long-term public 

health risks. Specifically, voluntary monitoring would not: 

 Reliably occur with sufficient frequency.

 Follow uniform national standards on quality of sampling, collection, and

analysis.

 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 system is taking to correct the violation, and necessity of seeking alternative water 

supplies 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

Throughout the 1996 SDWA Amendments, Congress conveyed the importance of 

properly 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

properly trained and certified personnel. To underscore the importance of operator certification, 

the operator certification 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 meet EPA’s guidelines. 
Public Water Systems Supervision Program ICR October 2015

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EPA still requires the submission of annual operator certification reports from states. The 

information collected under this program will continue to ensure that states are implementing 

operator certification programs that meet EPA guidelines.

7) Tribal Drinking Water 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 systems 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 qualified operators for all PWSs except transient noncommunity

water systems (TNCWSs) served by ground water (see 40 CFR 141.70(c) and 40 CFR 

141.130(c)). In addition, a public water systems must be have a certified operator to be eligible 

for Drinking Water Infrastructure Grants-Tribal Set -Aside 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 system” to include systems that provide water for human consumption and deliver 

the water via constructed conveyances. Prior to this change, PWSs included only piped water 

systems. This new definition affects the reporting and recordkeeping burden5for both PWSs and 

states. 

9) Proficiency Testing

The SDWA requires EPA to specify contaminants that may adversely affect public health 

when present in PWSs, specify MCLs for these contaminants, and publish “criteria and 

procedures to assure a supply of drinking water which dependably complies with such maximum 

contaminant levels.” Participation in the PT studies that relate to drinking water analyses is 

mandated 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 states.

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 analyte 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 state that the laboratories have successfully 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 analyses. EPA, states, and laboratory personnel will use the 

 

5 Based on EPA best professional judgment and drinking water industry consultation results, no new constructed 

conveyances are expected to be built 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

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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 sections 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 ICR 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 organizations

 Native American Water Association (NAWA)

 Association of American Indian Affairs

 Inter-tribal Environmental Council

 National Tribal Environmental Council (NTEC)

 Other intertribal groups
Public Water Systems Supervision Program ICR October 2015

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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 ICR 

are not duplicated. EPA has consulted with state environmental programs, other federal agencies 

and regulated entities, such as PWSs and their representative trade associations. To the best of 

EPA's knowledge, data currently required by 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. Specifically, EPA published a notice in the Federal Register 

(FR) requesting comment on the estimated respondent burden and other aspects of this ICR 

(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 ICR to OMB. The 

public comment period for this additional notice is 30 days.

3(c) Consultations

As part of the revision of the PWSS ICR, in May 2015 EPA consulted with 

representatives of PWSs and states 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 ICR to the extent 

possible. The end of each appendix to the ICR contains a table summarizing EPA’s previous and 

revised burden estimates for the relevant rule. 

3(d) Effects of Less Frequent Collection

EPA has considered a wide range of alternatives for frequency of data collection. The 

CCR Rule and Capacity Development Program require annual reporting. Distributing CCRs less 

frequently than annually is not allowed under the SDWA. Annual reporting of capacity 

development 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 analytical proficiency once each year for each analyte 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 frequently, the primacy agencies may not identify in a timely fashion violations

that might threaten the health and safety of drinking water consumers.

3(e) General Guidelines
Public Water Systems Supervision Program ICR October 2015

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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 ICR. 

3(g) Sensitive Questions

No information of a sensitive nature will be collected as a result of this ICR.
Public Water Systems Supervision Program ICR October 2015

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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, state, 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 

analyze 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 laboratories pay for the PT standards).

The North American Industry Classification System (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 Management Programs) or 923312 

(Administration of Public Health Programs). Ancillary systems (i.e., those that supplement the 

function of other establishments like factories, power plants, mobile home parks, etc.) cannot be 

categorized in a single NAICS code. For ancillary systems, the NAICS code is that of the 

primary establishment or industry. The code for laboratories that include environmental testing is 

541380 (Testing Laboratories).

Data associated with this ICR are collected and maintained by laboratories seeking 

primacy agency certification for the analysis of drinking water samples.

4(b) Information Requested

4(b)(i) Data Items

Respondent information collection requirements covered by the PWSS Program ICR 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

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Exhibit 2

PWS Recordkeeping and 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

Submit copy of CCR to primacy

agency.

40 CFR 141.155(c) Annually

Submit copy of CCR to agencies 

or clearing houses identified by 

the primacy agency.

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 forego per 

section 141.155(g)(2)

Retain copy of CCR. 40 CFR 141.155(h) For at least 3 years

VARIANCES AND EXEMPTIONS

Retain records concerning 

variance or exemption grants.

40 CFR 141.33 Not less than 5 years after 

variance/exemption expiration

Submit information supporting 

request for variance.

40 CFR 142.41 One-time, PWS discretion

Submit information supporting 

request for exemption.

40 CFR 142.51 One-time, PWS discretion

Submit information supporting 

request for small system 

variance.

40 CFR 142.306 One-time, PWS discretion

Report on compliance with terms 

and conditions of the small 

system variance.

40 CFR 142.307 Quarterly after granting

CAPACITY DEVELOPMENT

Demonstrate capacity (new 

CWSs & NTNCWSs).

N/A One-time

Cooperate with state to 

demonstrate continued capacity.

N/A As needed

GENERAL STATE PRIMACY ACTIVITIES

PWSs are not involved in general state primacy activities.

PUBLIC NOTIFICATION 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 

notification requirements for Tier 

1.

40 CFR 141.202(b)(3) As necessary
Public Water Systems Supervision Program ICR October 2015

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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 

months, unless the primacy 

agency 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 SWTR/IESWTR treatment 

technique requirements for single 

exceedances of turbidity limits 

occurs.

40 CFR 141.203(b)(3) As necessary, within 24 hours

Notify persons served within one 

year of learning of a violation or 

situation that requires Tier 3 

notification. 

40 CFR 141.204(b)(1) As necessary, within 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 

monitoring.

40 CFR 141.207 As necessary, within 12 months 

of receiving results

Provide special notice to persons 

served for an exceedance of the 

fluoride secondary 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 

(NCWSs) if the primacy agency 

grants permission to exceed the 

nitrate MCL.

40 CFR 141.209 As necessary, within 24 hours

Submit 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

OPERATOR CERTIFICATION PROGRAM

Certify operator(s) per state 

requirements.

N/A As necessary

Maintain and renew operator 

certification(s).

N/A As necessary

TRIBAL DRINKING WATER OPERATOR CERTIFICATION PROGRAM

Certify tribal water system 

operator(s) per EPA guidelines.

N/A As necessary

Apply for “grandparent” 

certificate.

N/A One time, if eligible

CONSTRUCTED CONVEYANCES
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Requirement Regulatory Citation Frequency/Retention

Conduct a house-by-house 

survey of water use practices 

and document efforts to ascertain 

water uses.

SDWA 1401(4)(B)(i) On-going

Apply for Other Residential Uses 

Exclusion.

SDWA 1401(4)(B)(i)(I) One time, if eligible

Apply for Alternative Water 

Exclusion.

SDWA 1401(4)(B)(i)(II) One time, if eligible

Apply for Treatment Exclusion. SDWA 1401(4)(B)(i)(III) One time, if eligible

Apply for Certain Piped Irrigation 

Districts Exclusion

SDWA 1401(4)(B)(ii) One time, if eligible

PROFICIENCY TESTING

PWSs 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

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Exhibit 3

Primacy Agency 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

VARIANCES AND EXEMPTIONS

Issue variances and exemptions 

(for other than small system 

variances).

40 CFR 142.20 At primacy agency discretion

Consider system V/E requests 

(for other than small system 

variances).

40 CFR 142.21 Within 90 days of request

Review V/E requests previously 

granted.

40 CFR 142.22 Within 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 142.311 & 142.312 When state proposes to grant a 

small system variance

Following notification of EPA’s 

objections and proposed 

modifications to proposed small 

system variances, respond to 

EPA.

40 CFR 142.311 Before state grants a small 

community variance to a PWS

serving 3,300 or fewer people

Re-propose small system 

variances.

40 CFR 142.312 Before state grants a small 

community variance to a PWS 

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 

meeting

CAPACITY DEVELOPMENT

Submit evidence to EPA that 

state has established and 

continues to implement a 

Capacity Development Program.

N/A Annually

Submit report to Governor on the 

status of the Capacity 

Development Program.

SDWA 1420(c)(3) Every three years
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Requirement Regulatory Citation Report Frequency/Minimum 

Retention

GENERAL STATE PRIMACY ACTIVITIES

Retain state records for public 

inspection.

40 CFR 142.14 Varies

Retain quarterly SDWIS 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 

SDWIS elements or any 

revisions to existing data.

40 CFR 142.15(b)(1) Annually

Submit information required for 

review of state 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-time

Submit initial application for 

primacy.

40 CFR 142.11 One-time

Submit statutory and regulatory 

provisions authorizing 

administrative penalties or 

demonstrate that authority does 

not exist.

40 CFR 142.11(a)(6) One-time

Submit revised primacy

application.

40 CFR 142.12 As needed

PUBLIC NOTIFICATION

Primacy agencies may exercise flexibility in the following areas as long as they establish enforceable 

procedures.

Requiring PWSs to notify 

persons served for violations or 

situations other than those

requiring notice under the PN 

Rule.

40 CFR 142.16(a) If necessary

Allowing PWSs 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 delivery than is required 

in the PN Rule for Tiers 1, 2, or 

3.

40 CFR 142.16(a) If necessary

Elevating monitoring/testing 

procedure violations from 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 necessary
Public Water Systems Supervision Program ICR October 2015

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Requirement Regulatory Citation Report Frequency/Minimum 

Retention

Consulting with PWS within 24 

hours for exceedance of turbidity 

limits.

40 CFR 142.16(a) If necessary

Determining the need for 

multilingual content in a notice.

40 CFR 142.16(a) If necessary

Consult with PWSs within 24 

hours for Tier 1

violations/situations. 

40 CFR 141.202(b)(2) As necessary, within 24 hours

Consult with PWSs within 24 

hours for exceedances of 

turbidity MCL or violations of 

turbidity single exceedance 

limits.

40 CFR 141.203(b)(3) As necessary, within 24 hours

May give the required public 

notice on behalf of the PWS.

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 PWSs. Also 

keep records of determinations of 

alternative requirements made 

under 40 CFR 142.16.

40 CFR 142.14(f) 3 years

OPERATOR CERTIFICATION PROGRAM

Submit a report to EPA 

describing ongoing 

implementation activities of the 

state’s operator certification 

program.

N/A Annually

Submit 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

Submit to EPA a report 

describing ongoing 

implementation activities of the 

state’s Expense Reimbursement 

Grant

N/A Not applicable. Expense 

Reimbursement Grants Program 

ended in December 2012.

TRIBAL DRINKING WATER OPERATOR CERTIFICATION PROGRAM

States are not affected by the Tribal Drinking Water Operator Certification Program because EPA directly 

implements this program.

CONSTRUCTED CONVEYANCES

Review data to determine if a 

constructed conveyance should 

be considered a PWS.

SDWA 1401(4) As necessary

Review applications and make 

determinations about Other 

Residential Uses Exclusions.

SDWA 1401(4)(B)(i)(I) As necessary

Review applications and make 

determinations about Alternative 

Water Exclusions.

SDWA 1401(4)(B)(i)(II) As necessary
Public Water Systems Supervision Program ICR October 2015

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Requirement Regulatory Citation Report Frequency/Minimum 

Retention

Review applications and make 

determinations about Treatment 

Exclusions.

SDWA 1401(4)(B)(i)(III) As necessary

Review applications and make 

determinations about Certain 

Piped Irrigation Districts 

Exclusions.

SDWA 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 Level (MCL),” 

“Maximum Contaminant Level 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 MCLG 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 obtain a variance or exemption, systems must submit a request for the variance or 

exemption that contains supporting information. Systems that are granted a variance or 

exemption must also provide public notice within one year after operating under the variance 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

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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 systems’ programs (SDWA 1420(a)) and the existing systems’ strategies 

(SDWA 1420(c)).

 A triennial report to the Governor on the status of the capacity development 

program (EPA receives a courtesy copy of each state report).

 A triennial list of systems that are historical significant non-compliers and, to the 

extent practicable, the reason(s) for noncompliance. This requirement is currently 

satisfied by using EPA’s OECA Enforcement Targeting Tool (ETT). The ETT 

assigns a point value to specific violations for each system to bring attention to 

drinking water systems with the most serious and unaddressed violations. EPA 

will utilize the spreadsheet output generated by the ETT on a quarterly basis 

instead of the triennial list of systems referred to as significant non-compliers.

Systems 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 applicable 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 section 

142.17, EPA may request information from a state to determine compliance of the state with 

requirements of 40 CFR 142 Subpart B. Information requested may include state determinations 

made under section 142.19 and records kept by states 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 SDWIS. Additionally, primacy agencies must maintain records of analysis results 

and other related activities (e.g., sanitary survey results).

Systems are not required to submit any data under this program.

5) Public Notification

Under the PN Rule, systems must notify all system users of any violation of drinking

water regulations. The methods and deadlines for notification are based on a three-tier system.

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 notice, 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 a 
Public Water Systems Supervision Program ICR October 2015

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year of the violation and may be included in the system’s CCR. Systems 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 systems with Tier 1 violations 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 years 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.

Systems must document that they have certified operators, and their operators must 

maintain certification as required by the state program.

7) Tribal Drinking Water 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 systems in Indian Country, “any system to be assisted 

with TSA funds must be operated by an adequately trained and certified operator” in order for a 

tribe to receive a grant for that system. The program guidelines establish seven baseline 

standards and list the certification program requirements that must be met by organizations that 

certify operators of drinking water systems 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 systems with certified operators. 

8) Constructed Conveyances

To comply with the 1996 SDWA Amendments, systems and states must work together to

determine if the system meets the new definition of “public water system.” In addition, section 

1401(4)(B) of the 1996 SDWA Amendments provides several exemption options. If a system is 

eligible for one of these exemptions, the system must submit an application 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 results of analyses for all 

contaminants for which they wish to be certified to conduct drinking water analyses.

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

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1) Consumer Confidence Reports6

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 newspaper

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 copy of the report.

 Submit copy of CCR to agencies or clearinghouses identified by the primacy

agency.

 Certify to the primacy agency that the report has been distributed to customers

and that the information is correct.

 Publish the report in a local newspaper rather than mail it, if the state Governor

allows CWSs serving 10,000 or fewer people to do so.

 Post an annual notice for customers rather than publishing or mailing a report, if 

the state Governor allows CWSs serving fewer than 500 people to do so.

 Post the report to a publicly accessible Internet site, for CWSs serving 100,000 or

more people.

2) Variance and Exemption Rule

A PWS that elects to apply 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 system variances, a system must demonstrate that it cannot 

afford to comply with the NPDWR for which the small system variance is sought;

that its source water meets the quality standards for installation of the small 

system variance technology; that it is financially and technically capable of 

installing, operating, and maintaining the applicable small system variance 

technology; and that the terms and conditions of the small system variance would 

ensure adequate protection of human health.

 Work with the state to hold a public 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 system variance. 

 Retain records associated with the variance or exemption.

 

6

In response to a memo (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

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Note that EPA estimates that no systems will apply for variances or exemptions in this 3-

year ICR period.

3) Capacity Development Program

Under the Capacity Development Program for new systems, all CWSs and NTNCWSs 

must demonstrate adequate capacity and comply with all state capacity development 

requirements. All PWSs are asked to cooperate with the state’s strategy for existing systems.

This includes achieving, maintaining, and improving capacity. 

4) General 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, 141.205, 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 agency 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 for 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 by 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

Systems are required to comply with the state requirements for operator certification.

Systems 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 Water Operator Certification Program

For the Tribal Drinking Water Operator Certification Program, tribal water systems are 

expected to have a certified operator.
Public Water Systems Supervision Program ICR October 2015

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8) Constructed Conveyances

In order to adhere to the broadened definition of “public water system” introduced by the 

1996 SDWA Amendments, PWSs 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 system variance, supporting information, 

and responses to public comments.

 Respond to EPA’s objections to a proposed small system variance for a PWS 

serving 3,300 or fewer persons, if the state chooses to pursue the variance.

 Revise a proposed small system variance as necessary to reflect EPA’s comments 

on variance requests for systems 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 increments of progress or any other 

violated term or condition of a small system variance.

 Conduct a public meeting on a small system 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 

years after its expiration.

Note that EPA estimates that no applications will be received for variances or exemptions 

in this 3-year ICR period.
Public Water Systems Supervision Program ICR October 2015

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3) Capacity Development Program

States must:

 Submit an annual report that describes ongoing implementation activities for both 

the new systems’ programs (SDWA 1420(a)) and the existing systems’ strategies 

(SDWA 1420(c)).

 Submit a triennial report to the Governor on the status of the capacity 

development program (EPA receives a courtesy 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 noncomplier list with the ETT. EPA will utilize the spreadsheet output generated by the 

ETT on a quarterly basis. As part of the ETT implementation, EPA and states meet on 

a quarterly basis to discuss the status of PWSs on this list and identify steps to enable 

systems to return to compliance. EPA believes 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 systems.

 Review monthly violations reports to monitor compliance.

 Maintain records submitted by PWSs regarding results of analytical 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 collected during sanitary

surveys.

 Certify laboratories to analyze drinking water samples for compliance with 

drinking water regulations.

This ICR assumes that no applications for primacy will be submitted during the next 

three years. 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 

currently in effect. An agency may also be granted primacy for new or revised 

EPA regulations if it demonstrates that its approved program has been updated to 

include regulations no less stringent than those new or revised EPA regulations.

 Adopt adequate procedures for enforcement of these regulations.

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

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 Permit variances and exemptions under conditions no less stringent than those 

specified by 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. The 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 

state’s operator certification program.

 Submit a new AG certification and a copy of the state’s regulations if a state 

makes changes to its operator certification program.

7) Tribal Drinking Water Operator Certification Program

States are not affected by the Tribal Drinking Water Operator Certification Program.

8) Constructed Conveyances

To comply with the broadened definition of “public water system” 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 analyzing and reporting results for relevant study samples 

according to instructions. Samples may be analyzed for inorganics, disinfection byproducts 

(DBPs) and/or organic chemicals. Respondents will participate in the following activities:
Public Water Systems Supervision Program ICR October 2015

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 Read instructions

 Plan activities

 Analyze inorganic chemicals

 Analyze DBPs

 Analyze organic 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

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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 SDWIS and assist EPA in evaluating the data in SDWIS to determine 

compliance rates. EPA instructs contractors to reformat, distribute, and store 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 the tribal drinking water operator certification 

program. In addition to its management activities, EPA directly implements the Aircraft 

Drinking Water Rule (see the Microbial Rules ICR 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 Frequency/Minimum 

Retention

Review initial and revised 

applications for primacy.

40 CFR 142.11-142.12 As needed

Inform primacy agency of PWS 

noncompliance with any 

NPDWRs in 40 CFR 141 or with 

any requirement under SDWA 

sections 1415 and 1416.

40 CFR 142.30, 142.15 Quarterly

Review existing state primacy

programs.

40 CFR 142.17 Annually

Review state monitoring 

determinations.

40 CFR 142.18 As needed

Review state 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 schedules in 

accordance with SDWA.

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

Within 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

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Requirement CFR Citation Report Frequency/Minimum 

Retention

Notify primacy agencies of 

objection and proposed 

modifications to small system 

variances proposed by states for 

PWSs serving 3,300 or fewer 

people.

40 CFR 142.311 Within 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 PWSs of noncompliance 

with any NPDWRs in 40 CFR 

141 or with any requirement 

under SDWA sections 1415 and 

1416.

40 CFR 142.30, 142.15 Quarterly

Provide PWSs with copies of 

Federal Register notice about 

PWS failure to comply.

40 CFR 142.23 Within 30 days of notice

Notify PWSs of denial or grant of 

variance (for PWSs in nonprimacy states).40 CFR 142.42 Within 90 days of request

Notify PWSs of denial or grant of 

exemption (for PWSs in nonprimacy states).40 CFR 142.52 Within 90 days of request

Notify PWSs of denial or grant of 

small system variance (for PWSs 

in non-primacy states).

40 CFR 142.311, 142.312 Within 90 days of request

Provide notice to PWSs in nonprimacy states that are no longer 

eligible for small system 

variances.

40 CFR 142.307 As needed

Provide public notice of public 

meeting on proposed small 

system variances (in nonprimacy states), with supporting 

information.

40 CFR 142.308 At least 30 days prior to public 

meeting

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 DWSRF grant withholding 

decisions with regard to States’ 

Capacity Development 

Programs.

SDWA section 1420(a), (c)

35 CFR 35.3515(b)ii Annually

Make DWSRF grant withholding 

decisions with regards to States’ 

Operator Certification Programs.

SDWA section 1419(b) Annually

Provide state and PWS 

assistance and training with 

regard to recordkeeping and 

reporting requirements covered 

in this ICR

N/A As needed

Maintain SDWIS. N/A As needed
Public Water Systems Supervision Program ICR October 2015

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Requirement CFR Citation Report Frequency/Minimum 

Retention

Review data in SDWIS. N/A Quarterly

Implement Tribal Drinking Water 

Operator Certification Program

N/A As needed

5(b) Collection Methodology and Management

Primacy agencies must report data to EPA on a quarterly basis. These data include any

new data and revisions or corrections to existing data. This information is maintained in 

SDWIS

7

, which contains the following: 

 Inventory data for each PWS.

 Violations.

 Enforcement actions and some follow-up activity.

 Variances and exemptions (where applicable).

Primacy agencies primarily transmit SDWIS data to EPA electronically. In the District of 

Columbia, Wyoming, and Indian Lands (except for the Navajo Nation, which has primacy), 

results of system samples are sent directly to the EPA Region. These data assist EPA in fulfilling 

its SDWA obligations. 

On a quarterly basis, EPA uses the ETT to generate a list of PWSs considered “priority 

systems.” The ETT assists EPA and the primacy agencies in prioritizing and directing

enforcement response to PWSs with the most systemic noncompliance by considering all 

violations incurred by a PWS in a comprehensive way.

5(c) Small Entity Flexibility

In developing this ICR, 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 small business is any business that is independently owned and operated and 

not dominant in its field as defined by 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/sdwisfed/howtoaccessdata.cfm.

8 These definitions were taken from section 601 of the Regulatory Flexibility Act.
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 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 analysis of all new rules 

that have a “significant economic impact on a substantial number of small entities.” This ICR is 

not associated with new rules. Therefore, this ICR is not subject to the SBREFA. 

However, EPA has made significant efforts to minimize the burden for all respondents, 

particularly for small entities. In setting both MCLs and monitoring requirements, EPA has been 

able to minimize burden for small entities as detailed below. 

1) Consumer Confidence Reports

EPA’s regulations allow systems 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 500 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 Exemption Rule

The V/E Rule includes procedures and conditions under which the primacy agency may

issue variances or exemptions to PWSs. The V/E Rule is intended to provide regulatory relief

while still protecting public health. These variances generally allow a system to provide drinking 

water that may be above the MCL if the drinking water quality is still protective of public health.

Duration of small system variances generally coincides with the life of the technology.

Exemptions are intended to allow a small system with compelling circumstances additional time 

to comply with applicable SDWA requirements. An exemption is generally limited to three years 

after the initial compliance date stated in the regulations. 

3) Capacity Development Program

EPA’s guidelines provide states with maximum flexibility in developing and 

implementing the capacity development program. EPA published a Handbook for Capacity 

Development: Developing Water System Capacity Under the Safe Drinking Water Act 

Amendments of 1996 and worked 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 systems 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 Program
Public Water Systems Supervision Program ICR October 2015

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EPA’s Guidelines provide states with maximum flexibility in developing and 

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 guidelines.

7) Tribal Drinking Water Operator Certification Program

Water system 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 system operators in Indian Country via the tribal 

PWSS and the Drinking Water Operator Certification programs.

8) Constructed Conveyances

The broadened definition of public water system includes small constructed conveyance 

systems that would now be considered PWSs. Consequently, the 1996 SDWA Amendments 

provided several exemption options. Examples of these exclusions include: 

 If water provided by a supplier is used exclusively for purposes other than 

residential uses (drinking, bathing, cooking, and similar uses), then a system may

apply for an “Other Than Residential Uses” exclusion.

 If a water supplier provides adequate health protection through means specified in 

section 1401(4)(B)(i)(II) and (III), then the system may apply for an “Alternative 

Water Treatment” Exclusion.

 If the water supply 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” Exclusion, a system 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 systems (with incidental 

residential use), the system 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 analyses.

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.
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6 ESTIMATING BURDEN AND COST OF COLLECTION

This section estimates the burden and cost to PWSs, primacy agencies, and EPA for 

complying with drinking 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 Activities

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 ICR. The 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 system. EPA 

estimates that CCR requirements will affect approximately 50,431 PWSs, all of which are 

CWSs, during the course of this ICR period. Activities associated with the preparation and 

delivery of CCRs account for 955,671 burden hours per year, which includes burden for both 

CCR development and distribution for PWSs.

Appendix 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 100,000 people or 
Public Water Systems Supervision Program ICR October 2015

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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 copy of the CCR distributed to 

customers. Certification that the reports were, distributed is also required along with the report.

All CWSs, regardless of size, are assumed to have the same burden (0.25 hours) for maintaining 

a copy of the CCR and making it publicly 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 system for this activity is 

0.25 hours. For systems serving at least 10,000 people, publication is in addition to 

report delivery to customers. For systems serving fewer than 10,000 people, this ICR 

assumes that 50 percent of systems 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 by mail, door-to-door delivery, or posting in an appropriate location that 

the CCR is available upon request. 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. 

 Regardless of CWS size category, this ICR assumes a burden of 10 hours per system 

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 state Governor (or Tribal Leader) for a 

waiver of the requirement to deliver a CCR to each customer. This ICR assumes that 

half of such CWSs will receive a waiver. For CWSs serving 500 or fewer people, the 

50 percent without a waiver 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 systems without a waiver (or 25 percent of the total 

number of CWSs in this size category) are assumed to include the CCR as a bill 

stuffer, and the remaining systems will mail the CCR separately. 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 

systems serving 100,000 or more people will exclusively deliver CCRs electronically

and therefore will not incur burden to coordinate bill stuffer delivery.

 Under section 141.155(f), CWSs serving at least 100,000 people must post a copy of 

the current CCR on a publicly accessible Internet site. This burden is estimated at 2

hours per system.
Public Water Systems Supervision Program ICR October 2015

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2) Variance and Exemption Rule 

No systems are expected to apply for new variances or exemptions in this 3-year 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 13,826 PWSs, 

including CWSs, NTNCWSs, and TNCWSs, during the course of this ICR 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 

Systems Workgroup, and consultations with drinking water industry representatives.

Specifically, the burden estimate includes the following activities and assumptions:

 New systems must demonstrate capacity in order to obtain approval. Each new 

system applying for approval will require 40 hours to prepare and submit new system

approval materials to the state. EPA estimates that there will be an average of 8 new 

systems per state per year. 

 Some new systems must improve capacity in order to obtain approval. An estimated 

20 percent of new systems applying for approval will be required to submit 

supplemental materials before approval is granted by the state. To develop and submit 

these materials, it is estimated that each system denied initial approval will require an 

additional 40 hours. As with the approval application, it is estimated that there will be 

8 new systems 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 systems will incur burden for complying with state capacity 

development strategies. Each year, EPA estimates that 20 percent of CWSs, 7 percent 

of NTNCWSs, and 2.5 percent of TNCWSs will incur a burden to comply with state 

capacity development strategy efforts. EPA estimates that these systems 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 system and one on one technical assistance.

Based on these assumptions, EPA estimates that the average annual burden to PWSs will 

be approximately 128,851 hours for capacity development activities.
Public Water Systems Supervision Program ICR October 2015

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Appendix D summarizes the assumptions used to calculate the Capacity Development 

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 violations 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 systems 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 removed from the RTCR standalone ICR, and is now 

accounted for in this ICR. 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 ordinarily 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 community, 

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 likely to post the notice or hand deliver the notice to 

customers. All water systems are required to take other reasonably calculated steps to ensure all 

the persons served by the system receive the notice. Although the rule does not specify such 

actions, PWSs are assumed to place telephone calls to centers of sensitive populations, such as 

hospitals, nursing homes, and schools. Finally, water systems are expected to prepare a notice 

suitable for posting in rest areas, government-owned buildings, libraries, and other facilities 

served by the water system.

Systems 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 systems 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 size, and 30 hours for 

larger CWSs. NTNCWS and TNCWS are estimated to incur 9 burden hours per system.

The burden estimate for mailing assumes that half the CWSs bill their customers less 

frequently 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 specifically for the public notice.

Water systems 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 a 
Public Water Systems Supervision Program ICR October 2015

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stuffer in one of the system’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 separately from the burden for 

delivering the notices. For Tier 1 notice preparation by systems serving up to 10,000 customers,

the burden estimate per system is 15 hours. Systems serving more than 10,000 customers incur a 

burden of 30 hours per system. Systems with Tier 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 hours

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 system. 

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, 23,209 PWSs will be affected annually by 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 Water Operator Certification Program

Burden for tribal PWSs involves obtaining and renewing certification of their operators.

The total burden for all three years 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 Level 1 

certifications, 26 hours for new Level 2 certifications and 26 hours for new Level 3 

certifications. Other activities include 40 hours 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 any reporting and recordkeeping burden to adhere to the broadened 

definition of “public water system” introduced by the 1996 SDWA Amendments. EPA 

historically assumed that 371 systems 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. 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 ICR.
Public Water Systems Supervision Program ICR October 2015

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6(a)(ii) Burden 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 briefly describes 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 73,912 hours. Assisting in the preparation of reports for small CWSs is estimated 

at 2 hours per system. 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 states is based on the number of systems 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 agencies for this rule. Detailed 

information about assumptions, burden, and calculations is provided in Appendix C.

3) Capacity Development Program

As discussed in section 6(a)(i), the Capacity Development Program, is a state program 

designed to help drinking water systems 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 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 

Systems Workgroup, and consultations with drinking water industry representatives.

Specifically, the burden estimate assumes that:

 States must review and approve applications for new systems. This ICR assumes that 

on average there will be 8 new systems per state per year. It will take state personnel 

an estimated 100 hours per system to review new system documentation and 

information.

 Some applications for new systems will require state follow up. Upon initial review, 

all new systems likely will not meet states’ capacity criteria. An estimated 20 percent 

of new systems applying for approval each year will be required to submit 
Public Water Systems Supervision Program ICR October 2015

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supplemental materials. It is estimated that a state will need 8 hours per system to 

review these materials. 

 States must provide capacity development assistance to some existing systems. 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 systems.

 Every three years, the primacy agency must submit a report to the state's Governor on 

the progress and success of its strategy. It will 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 102,851

hours per year. Appendix D summarizes the assumptions used to calculate the Capacity 

Development Program burden and provides detailed burden and cost calculations.

4) General 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 apply for the grants on an annual basis. This activity is estimated to 

require 1,040 hours annually per state. 

 Recordkeeping. Each primacy agency is required to maintain records of tests, 

measurements, analyses, decisions, and determinations 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 annually per state.

 Maintenance of data systems is estimated to require 1,040 hours annually per state. 

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 

information electronically. States must routinely enter new inventory, compliance, 

and enforcement data into their data systems. States must also modify their data 

systems as necessary.

 Submission of ongoing violation reports is estimated to require 1,040 hours annually

per state. Each primacy agency must provide EPA with information regarding all 

violations of the state drinking water regulations and with other selected water system 

information that is necessary to determine compliance with the drinking water 
Public Water Systems Supervision Program ICR October 2015

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requirements. States must also provide new and updated water system inventory

information on an annual basis.

 Laboratory certifications are estimated to require 728 hours annually per state. The 

state PWSS programs require that water systems conduct routine 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 new or modified water system facilities 

that are capable of complying with the state primary drinking water regulations. Most 

states achieve this assurance by requiring state review and approval of plans and 

specifications for drinking water facility construction. Reviewing plans for major 

projects for systems 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 state, respectively. Reviewing plans for minor projects for systems 

greater than 500 customers and fewer than 500 customers is estimated to require 

1,040 and 2,600 hours annually per state, respectively. Routine inspections are 

estimated to require 832 burden hours annually per state.

 Oversight of compliance monitoring. States must ensure that water systems monitor 

in accordance with the regulations. Where monitoring does not occur, states must take 

action to ensure that systems 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 follow-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. Primacy 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 annually 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 quarterly reports to 

EPA, and filing and maintaining the public notification records. The burden for primacy agencies 

for these activities is estimated to be 116,665 hours annually. 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 ICR and 

is now accounted for in this ICR. This corresponds to a reduction in annual primacy agency

burden, which is reflected in the annual burden estimate above. Tier 1 consultation activities 
Public Water Systems Supervision Program ICR October 2015

42

require an estimated 3.0 hours annually per system in violation, Tier 2 consultation requires an 

average of 1.1 hours and Tier 3 requires 0.5 hours. The burden for receiving/reviewing 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-year 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 Water 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 primacy agencies will incur reporting or recordkeeping burden. EPA historically

assumed that 371 systems 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 laboratory 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 I for additional 

details.)

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 by drinking water laboratories. There is 

no burden for PT vendors or primacy agencies. The burden for laboratories for these activities is 

estimated to be 42,892 hours annually. This estimate includes burden for participating 

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

and maintain 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 instructions: EPA assumes that each of the 1,902 respondents will require 4.0 

hours to read the instructions provided by the vendor. The burden will be evenly

divided between a manager and chemist.

 Plan activities: EPA assumes that the manager of each laboratory will require 1.5

hours to plan activities associated with the PT studies.

 Analyze inorganic chemicals: EPA assumes that 871 laboratories will require 

approximately 16 hours to analyze PT standards for 29 inorganic chemicals. All hours 

will be incurred by a chemist.

 Analyze DBPs: Chemists in 701 laboratories are assumed to require 8.0 hours to 

analyze PT standards for 9 DBPs.

 Analyze organic chemicals: Chemists in 330 laboratories are assumed to require 16.0 

hours to analyze PT standards for 52 organic chemicals.

 Report results: EPA assumes that each of the 1,902 respondents will require 2.0 hours

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-year ICR period. Annual costs are 

estimated at approximately $114 million, which consists of $73 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 ICR. 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 applicable, in addition to travel and lodging costs incurred are no longer 
Public Water Systems Supervision Program ICR October 2015

44

reimbursed by the expense reimbursement program. These costs are shown in more detail in 

Appendices G and H, respectively.

There are no capital costs associated with this ICR.

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 by primacy agencies are labor costs. 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. A loaded labor rate of

$45.60 per hour in 2013 dollars was used for state labor.

6(b)(iii) 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 hourly 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 hourly 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 analytical 

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 analytes 

are contained in the PT samples sent to each laboratory, EPA has estimated a "worst case" 

scenario by assuming that a single PT set contains standards for each possible regulated analyte.

Therefore, laboratories participating in the inorganic PT study are assumed to receive and run 

analyses for 29 analytes. Similarly, those participating in the PT study for DBPs and/or organic 

chemicals will receive samples for each of 9 analytes and/or each of 52 analytes, respectively.

EPA estimates the costs of each PT standard to be $16.81 per analyte.
Public Water Systems Supervision Program ICR October 2015

45

Exhibit 6

Annual PWS Burden and Cost

November 1, 2015 to October 31, 2018

Exhibit 7

Annual State Burden and Cost

November 1, 2015 to October 31, 2018

Annual Labor

Cost ($K)

Annual O&M

Cost ($K)

Total Annual

Cost ($K)

Consumer Confidence 

Reports 955,671 $ 33,059 $ 19,616 $ 52,674 206,339 

Variance and Exemptions - $ - N/A $ - - 

Capacity Development 128,851 $ 4,457 N/A $ 4,457 13,918 

General State Primacy N/A N/A N/A N/A N/A 

Public Notification 779,393 $ 26,961 $ 7,654 $ 34,614 110,520 

Operator Certification 315,919 $ 7,723 $ 13,821 $ 21,545 19,745 

Tribal Operator

Certification 10,027 $ 347 $ 194 $ 541 251 

Constructed Conveyances N/A N/A N/A N/A N/A 

Proficiency Testing N/A N/A N/A N/A N/A 

TOTAL 2,189,861 $ 72,547 $ 41,284 $ 113,831 350,773 

Note: Detail may not add exactly to totals due to rounding.

Activity

Annual Burden 

Hours Annual Responses

Cost

Labor Cost ($K) O&M Cost ($K) Total Cost ($K)

Consumer Confidence 

Reports 73,912 $ 3,370 N/A $ 3,370 122,689 

Variance and Exemptions - $ - N/A $ - - 

Capacity Development 102,851 $ 4,690 N/A $ 4,690 13,918 

General State Primacy 1,242,199 $ 56,644 N/A $ 56,644 149,765 

Public Notification 116,665 $ 5,320 N/A $ 5,320 381,931 

Operator Certification 832 $ 38 N/A $ 38 19,745 

Tribal Operator

Certification N/A N/A N/A N/A N/A 

Constructed Conveyances N/A N/A N/A N/A N/A 

Proficiency Testing N/A N/A N/A N/A N/A 

TOTAL 1,536,459 $ 70,063 N/A $ 70,063 688,047 

Note: Detail may not add exactly to totals due to rounding.

Activity Annual Responses

Annual Burden

Hours

Annual Cost
Public Water Systems Supervision Program ICR October 2015

46

Exhibit 8

Annual 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 Headquarters and Regional offices

to assist states in implementing drinking water regulations. In previous ICRs for the PWSS 

Program, burden associated with EPA’s enforcement and compliance activities at Headquarters 

and the Regions was 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 by EPA’s water program, 

especially 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.9The 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 the 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/payleave/salaries-wages/2013/general-schedule/gs.pdf). 2013 pay schedule (rates frozen at 2010 levels). Loaded with a 

60 percent loading factor.

Labor Cost ($K) O&M Cost ($K) Total Cost ($K)

Consumer Confidence 

Reports N/A N/A N/A N/A N/A 

Variance and Exemptions N/A N/A N/A N/A N/A 

Capacity Development N/A N/A N/A N/A N/A 

General State Primacy N/A N/A N/A N/A N/A 

Public Notification N/A N/A N/A N/A N/A 

Operator Certification N/A N/A N/A N/A N/A 

Tribal Operator

Certification N/A N/A N/A N/A N/A 

Constructed Conveyances N/A N/A N/A N/A N/A 

Proficiency Testing 42,892 $2,891 $819 $3,710 1,902

TOTAL 42,892 $2,891 $819 $3,710 1,902

Note: Detail may not add exactly to totals due to rounding.

Activity

Annual Burden

Hours Annual Responses

Annual Cost
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 92,005 hours (44.2*2,080).

 The labor cost of 44.2 FTEs is $5,748,875 (44.2*$129,968).

For most of the programs and regulations covered in the PWSS ICR, there are no O&M 

costs. However, EPA incurs O&M costs for EPA contractors to manage the SDWIS database.

These O&M costs are directly related to the collection of the information discussed in this ICR 

and include SDWIS/state and SDWIS/FED maintenance and user support for the system. The 

SDWIS 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 Regional 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 

Regional offices—

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

 The labor cost of 206.4 FTEs is $18,819,887 (206.4*$91,186).

The total cost to the federal government is the sum of the labor cost to Headquarters 

($5,748,875), the labor cost to EPA Regional offices ($18,819,887), and O&M costs to 

Headquarters ($450,000), for a total of $25,018,762. Note that there are no O&M costs to EPA 

Regional offices. Similarly, the total burden to the federal government (Headquarters and 

Regions) is 521,298 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-mail correspondence from EPA WACOR, Kevin Roland (02/02/2015).

13 Base salary, United States Office of Personnel Management (http://www.opm.gov/policy-data-oversight/payleave/salaries-wages/2013/general-schedule/gs.pdf). 2013 pay schedule (rates frozen at 2010 levels). Loaded 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 ICR include PWSs, laboratories, and states or other primacy

agencies. This ICR estimates the number of PWS respondents at 149,765. Not every PWS is 

necessarily subject to each of the information collection requirements contained in this ICR. The 

regulations associated with each ICR will identify the types of PWSs that are subject to each 

particular drinking water regulation.

In addition to the PWS respondents, this ICR 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 151,724.

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 ICR is estimated to be approximately 3.8 million burden 

hours. The corresponding total annual 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 annually. The total national cost, for respondents and EPA, is 

estimated to be $212.6 million annually.

 

14 This 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 Annual Burden and Cost

November 1, 2015 to October 31, 2018

151,724 (=)

149,765 (+) Existing PWSs

57 (+) Primacy agencies

1,902 Laboratories

1,040,722 (=)

350,773 (+) PWS responses (see Exhibit 6)

688,047 (+) Primacy agency responses (see Exhibit 7)

1,902 Laboratory responses (see Exhibit 8)

6.9 (=)

1,040,722 (/) Total annual responses from above

151,724 Total number of respondents from above

3,769,213 (=)

2,189,861 (+) PWS hours (see Exhibit 6)

1,536,459 (+) Primacy agency hours (see Exhibit 7)

42,892 Laboratory hours (see Exhibit 8)

3.62 (=)

3,769,213 (/) Total annual respondent hours from above

1,040,722 Total annual responses from above

$42,103 (=)

$41,284 (+) Total PWS O&M costs (see Exhibit 6)

N/A (+) Total primacy agency O&M costs (see Exhibit 7)

$819 Total laboratory O&M costs (see Exhibit 8)

$187,603 (=)

$113,831 (+) For PWSs (see Exhibit 6)

$70,063 (+) For primacy agencies (see Exhibit 7)

$3,710 For laboratories (see Exhibit 8)

Total Annual Hours (resp. plus Agency) 4,290,511 (=)

3,769,213 (+) Total respondent hours

521,298 (+) Total EPA hours

Total Annual Cost (resp. plus Agency) ($K) $212,622 (=)

$187,603 (+) Total respondent cost

$25,019 Total EPA Cost

Note: Detail may not add exactly to totals due to rounding.

1No capital costs are associated with the PWSS ICR in this evaluation period.

Total annual EPA hours and costs reflect the combined burden and cost for Headquarters staff (approximately 44 FTEs) and regional staff 

(approximately 206 FTEs). Costs also include O&M costs incurred for EPA contractors to manage the SDWIS database ($450,000).

Total Annual Respondent Cost (Labor, Capital, 

and O&M) ($K)

Number of Respondents

Number of Responses per Respondent

Hours per Response

Annual Respondent O&M and Capital Cost ($K)1

Total Respondent Hours

Total Annual Responses
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 ICR. 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 ICR.

Exhibit 10

Summary of Changes in Annual Burden

(Includes PWS, Primacy Agency, 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 ICR, 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 ICR.

Exhibit 11

Restructuring Adjustments to the 

Annual Burden Inventory for the PWSS Program ICR 

(Includes PWS, Primacy Agency, and Laboratory Burden)

Type of Change Burden (hours) Running Total Comment

Burden Estimated in the 2012 

PWSS Program ICR 4,113,408 4,113,408

This burden serves as the 

baseline for the 2015 PWSS 

Program ICR.

Restructuring 

Adjustments–see Section 

6(f)(i) 0 4,113,408

2015 PWSS Program ICR is not 

appended with burden from any 

new ICRs.

Other Adjustments to 

Burden–see Section 6(f)(ii) (344,195) 3,769,213

Burden for which EPA seeks 

approval in this ICR.

Note: Detail may not add exactly to totals due to rounding.

Action Annual Burden Hours Brief Explanation

N/A 4,113,408 Inventory for the 2012 PWSS Program ICR carried forward as the baseline 

for 2015 PWSS Program ICR.

Add 0 2015 PWSS Program ICR is not appended with burden from any new ICRs.

Total 4,113,408 PWSS Program ICR inventory based on current burden inventories.
Public Water Systems Supervision Program ICR October 2015

51

6(f)(ii) Additional Program Adjustments

The remaining changes in burden consist of program adjustments for activities that were 

carried forward from existing ICRs to this PWSS Program ICR 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 by activity. Burden adjustments associated with PWS activities 

resulted in a burden decrease of 227,566 hours and are shown in Exhibit 12. Burden adjustments 

for primacy agencies resulted in a decrease of 116,629 hours per year, as shown in Exhibit 13.

Burden adjustments for laboratories resulted in no change in burden hours, as shown in Exhibit 

14.

Exhibit 12

Adjustments 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 

Primacy 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 

account 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 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. 

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

Adjustments to Primacy Agency 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 

Primacy

 

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 notifications 

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 closed 

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

Adjustments 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 effect 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 yields 3,769,213 hours.

Exhibit 15

Adjustments to Activities Carried Forward from Previous ICRs

(Includes PWS, Primacy Agency, 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 ICR 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 PWSs, 1.5 million hours to primacy agencies, and 

0.04 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 by people to 

generate, maintain, retain, disclose, or provide information to or for a federal agency. This 

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

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

maintaining information, and disclosing and providing information; adjust the existing ways to 

comply with any previously applicable instructions and requirements; train personnel to be able 

to respond to a collection of information; search data sources; complete and review the collection 

of information; and transmit or otherwise disclose the information. An agency may not conduct 

or sponsor, and a person is not required to respond to, a request for information collection unless 

it displays a currently valid OMB control number. The OMB control numbers for EPA’s 

regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15.

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

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

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

Docket 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 Ave., 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 holidays. 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 public docket, and to access 

those documents in the public docket that are available electronically. When in the system, select 

“search,” then key in the Docket ID Number identified above. Also, you can send comments to 

the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th 

Street, NW, 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.