ENVIRONMENTAL
PROTECTION
AGENCY
ANNUAL
PUBLIC
WATER
SYSTEMS
COMPLIANCE
REPORT
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
Annual
Public
Water
Systems
Compliance
Report,
ICR
Number
1812.03
1(
b)
Short
Characterization/
Abstract
Section
1414
(
c)(
3)(
A)
of
the
Safe
Drinking
Water
Act
requires
that
each
state
(
a
term
that
includes
states,
commonwealths
and
territories)
that
has
primary
enforcement
authority
under
the
Act
shall
prepare,
make
readily
available
to
the
public,
and
submit
to
the
Administrator
of
EPA,
an
annual
report
of
violations
of
national
primary
drinking
water
regulations
in
the
state.

These
Annual
State
Public
Water
System
Compliance
Reports
are
to
include
violations
of
maximum
contaminant
levels,
treatment
requirements,
variances
and
exemptions,
and
monitoring
requirements
determined
to
be
significant
by
the
Administrator
after
consultation
with
the
states.

To
minimize
a
state's
burden
in
preparing
its
annual
statutorily­
required
report,
EPA
issued
guidance
that
explains
what
Section
1414(
c)(
3)(
A)
requires
and
provides
model
language
and
reporting
templates.
EPA
also
annually
makes
available
to
the
states
a
computer
query
that
generates
for
each
state
(
from
information
states
are
already
separately
required
to
submit
to
EPA's
national
database
on
a
quarterly
basis)
the
required
violations
information
in
a
table
consistent
with
the
reporting
template
in
EPA's
guidance.
­
2­
states
(
including
Puerto
Rico,
the
Virgin
Islands,
American
Samoa,
Guam,
and
the
Commonwealth
of
the
Northern
Mariana
Islands,
Navajo
Nation)
currently
have
primary
enforcement
authority
under
the
Safe
Drinking
Water
Act.
The
Navajo
Nation
was
approved
for
primacy
on
December
6,
2000.
The
State
of
Wyoming
and
the
District
of
Columbia
neither
currently
have
primary
enforcement
authority
nor
are
currently
seeking
primary
authority,
so
the
number
of
56
states
is
unlikely
to
change
during
the
next
three
years.
The
cost
of
this
ICR
to
each
state
with
primary
enforcement
authority
will
be
approximately
during
each
year
of
this
ICR.

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
As
stated
above,
Section
1414
(
c)(
3)(
A)
of
the
Safe
Drinking
Water
Act
requires
that
each
state
that
has
primary
enforcement
authority
under
the
Act
shall
prepare,
make
readily
available
to
the
public,
and
submit
to
the
Administrator
of
EPA,
an
annual
report
of
violations
of
national
primary
drinking
water
regulations
in
the
state.
The
states'
reports
are
to
include
violations
of
maximum
contaminant
levels,
treatment
requirements,
variances
and
exemptions,
and
monitoring
requirements
determined
to
be
significant
by
the
Administrator
after
consultation
with
the
states.
Section
1414(
c)(
3)(
B)
of
the
Safe
Drinking
Water
Act
requires
EPA
to
prepare
and
make
available
to
the
public
an
annual
report
that
summarizes
and
evaluates
the
reports
submitted
by
the
states
pursuant
to
subparagraph
(
A).

2(
b)
Practical
Utility/
Users
of
the
Data
EPA
summarizes
the
data
submitted
by
the
states
and
uses
that
information
in
preparing
its
annual
report
that
provides
a
national
overview
of
the
compliance
performance
of
public
­
3­
water
systems.
In
its
annual
national
report,
EPA
must
also
use
the
violations
data
provided
specified
by
the
states
to
make
recommendations
concerning
the
resources
necessary
to
improve
compliance
with
the
Safe
Drinking
Water
Act.
The
information
submitted
by
the
states
also
helps
EPA
identify
and
resolve
discrepancies
between
violations
data
in
the
states'
reports
and
the
violations
data
states
submit
quarterly
to
EPA's
national
database.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
3(
a)
Nonduplication
The
information
to
be
obtained
under
this
ICR
has
not
been
collected
by
EPA
or
any
other
federal
agency.
States
are
required
to
report
public
water
system
violations
to
EPA's
national
database
on
a
quarterly
basis,
but
states
cannot
satisfy
their
obligations
under
Section
1414(
c)(
3)(
A)
simply
by
referring
interested
parties
to
EPA's
Safe
Drinking
Water
Information
System/
Federal
System
(
SDWIS/
FED).
EPA
works
with
states
to
ensure
they
can
efficiently
extract
from
SDWIS/
FED
the
calendar
year
violations
data
they
need
to
prepare
a
report
in
which
the
violations
data
are
readily
available
to
the
public.
Some
states
elect
not
to
use
the
EPAprovided
query
to
extract
the
essential
reporting
data
from
SDWIS/
FED,
and
use
their
own
data
systems
instead.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
An
announcement
of
a
public
comment
period
for
the
renewal
of
this
ICR
was
published
in
the
Federal
Register
on
March
16,
2004.
The
only
comment
recieved
during
the
public
comment
period
concerned
fluoridation
of
public
water
systems.
The
Federal
Register
on
December
24,
1975
(
Volume
40
59566)
addresses
the
comment.
The
commenter
wanted
to
know
why
EPA
required
flouridation
of
the
public
water
supply
systems
while
most
of
Europe
did
­
4­
not.

"
The
flouride
question
has
been
complicated
by
the
flouridation
controversy.
It
was
clearly
the
intent
of
Congress
that
Primary
Drinking
Water
Regulation
not
be
used
as
the
vehicle
for
a
national
fluoridation
program
[
House
Report
p15].
At
the
same
time
Congress
made
it
that
there
was
no
intent
to
prohibit
or
discourage
fluoridation.
As
for
changing
the
MCL's,
either
raising
or
lowering
them,
very
little
data
were
submitted
to
support
the
recommendations."

3(
c)
Consultations
To
obtain
comments
from
actual
respondents
regarding
the
annual
public
water
systems
compliance
report
and
the
corresponding
burden
hour
estimates,
EPA
staff
consulted
with
the
following
individuals:

Name
Telephone
Telephone
Darron
Busch
605
773­
3754
South
Dakota
Department
of
Environment
and
Natural
Resources
Mary
Alvey
503
731­
43810
Oregon
Health
Division
Joanne
Wagner
402
471­
2541
Nebraska
Department
of
Health
As
states
have
now
completed
seven
of
these
annual
reports,
most
now
simply
generate
the
necessary
data
from
SDWIS/
FED,
confirm
the
accuracy
of
the
numbers,
and
update
the
previous
year's
report.
As
a
result,
the
burden
hours
associated
with
preparing
a
report
have
not
­
5­
changed.
EPA's
burden
hour
estimates
reflect
input
from
these
consultations.

3(
d)
Effects
of
Less
Frequent
Collection
Because
Section
1414(
c)(
3)(
A)
requires
the
states
to
prepare
these
reports
annually
and
to
make
the
reports
readily
available
to
the
public,
states
do
not
have
the
option
of
collecting
this
information
less
frequently.

3(
e)
General
Guidelines
All
of
the
collection
activities
described
within
this
ICR
fall
within
OMB's
General
Guidelines.

3(
f)
Confidentiality
The
required
information
consists
of
violations
data
and
other
information
that
are
a
matter
of
public
record.
None
of
the
information
collected
as
part
of
the
states'
annual
public
water
systems
compliance
report
comprises
confidential
business
information.

3(
g)
Sensitive
Questions
No
questions
of
a
sensitive
nature
are
asked
or
answered
in
the
states'
annual
public
water
systems
compliance
report.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
of
the
recordkeeping
and
reporting
requirements
are
states
that
have
received
primary
enforcement
authority
under
the
Safe
Drinking
Water
Act.
The
term
"
state",
in
this
context
can
include
states,
commonwealths,
territories,
and
Indian
Tribes.
Currently,
primary
enforcement
authority
has
been
approved
for
every
state
but
Wyoming,
and
for
the
U.
S.
Virgin
Islands,
Puerto
Rico,
American
Samoa,
Guam,
and
the
Northern
Mariana
Islands.
Primary
­
6­
enforcement
authority
has
not
been
approved
for
the
District
of
Columbia
or
for
Indian
Tribes.

EPA
has
primary
enforcement
authority
in
those
jurisdictions
and
is
likely
to
retain
that
during
the
three
year
duration
of
this
ICR.

4(
b)
INFORMATION
REQUESTED
(
i)
Data
Items
The
reporting
items
as
required
by
section
1414(
c)(
3)(
A)
include:

°
State
name
and
reporting
period
°
Full
report,
including
a
description
of
the
data
in
the
Summary
of
Violations
chart,

specific
information
on
the
violation
categories
for
each
rule
identified
on
the
chart,
a
list
of
the
systems
that
had
maximum
contaminant
level
or
treatment
technique
requirement
violations,
explanations
of
any
aggregated
number
of
violations,
and
a
description
of
systems
that
were
out
of
compliance
during
the
year,
a
discussion
of
variance
or
exemption
violations;

°
Summary
report,
including
a
description
of
the
data
on
violations,
a
list
of
the
systems
that
had
maximum
contaminant
level
or
treatment
technique
requirement
violations,
and
a
discussion
of
variance
or
exemption
violations;
and
°
Reviewed
and
completed
Summary
of
Violations
chart.

In
addition
to
these
items,
States
are
encouraged
to
provide
optional
information
as
outlined
EPA
guidance.
EPA
provided
guidance
to
the
States's
to
assist
them
in
the
development
of
their
statutorily­
mandated
reports.

ii.
Respondent
Activities
States
will
need
to
conduct
the
following
activities
in
order
to
complete
and
submit
their
­
7­
Annual
State
Public
Water
Systems
Compliance
Report.

°
Review
the
instructions
and
other
necessary
materials;

°
Gather
inventory
and
violations
data
from
SDWIS/
FED
and
from
their
own
data
bases;

°
Review
and
analyze
inventory
and
violations
data
from
SDWIS/
FED
and
from
their
own
data
bases;

°
Prepare
summary
of
violations
of
variances
and
exemptions;
and
°
Prepare
report
and
submit
to
EPA
in
hard
copy
or
hard
copy
and
electronic
version,
make
report
readily
available
to
the
public,
prepare
and
distribute
a
summary
of
the
report.

5.
The
Information
Collected
­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
During
the
lifetime
of
this
ICR,
EPA
Headquarters
activities
associated
with
the
Annual
State
Public
Water
Systems
Compliance
Report
consist
of
the
following:

°
Modify
guidance
documents
as
necessary
and
distribute
to
states
and
EPA
Regional
Offices;

°
Prepare
and
distribute
tools
for
states
and
EPA
Regional
Offices
to
use
to
gather
data
from
SDWIS/
FED
(
annual
activity);

°
Answer
questions
from
states
and
EPA
Regional
Offices
(
annual
activity);
­
8­
°
Provide
support
for
Indian
Land
reporting
(
annual
activity);
and
°
Review
Annual
State
Public
Water
System
Compliance
Reports,
and
data
from
SDWIS/
FED,
prepare
the
Annual
National
Public
Water
Systems
Compliance
Report
that
summarized
and
evaluates
the
annual
state
reports,
and
distribute
the
national
report.

EPA
Regional
Offices
will
need
to
complete
the
following
activities
to
prepare
Annual
State
Public
Water
Systems
Compliance
Reports
for
states
that
do
not
have
primary
enforcement
authority,
to
gather
public
water
system
compliance
data
for
Indian
lands,
and
to
assist
the
states
as
they
prepare
their
reports:

°
Assist
EPA
Headquarters
in
the
development
and
distribution
of
any
necessary
guidance
materials;

°
Assist
EPA
Headquarters
in
the
development
and
distribution
of
tools
for
gathering
data
from
SDWIS/
FED
(
annual
activity);

°
Provide
general
guidance
to
all
states
in
the
Region
for
completing
the
Annual
state
Public
Water
Systems
Compliance
Report;

°
Gather
information
from
SDWIS/
FED
for
each
Indian
land
in
the
Region;

°
Prepare
a
summary
of
variances
and
exemptions
violations
in
each
Indian
land
in
the
Region;

°
Gather
and
submit
to
EPA
Headquarters
inventory
and
violations
information
from
SDWIS/
FED
for
each
Indian
land
in
the
Region,
information
about
enforcement
and
compliance
assistance
activities
related
to
the
Safe
Drinking
Water
Act
on
Indian
lands
in
the
Region,
and
information
about
financial
assistance
related
to
­
9­
implementation
of
the
Safe
Drinking
Water
Act
on
Indian
lands
in
the
Region;

°
Prepare
Annual
State
Public
water
Systems
Compliance
Report
for
each
State
in
the
Region
that
does
not
have
primary
enforcement
authority
and
submit
it
to
EPA
Headquarters
in
hard
copy
or
hard
copy
and
electronic
version,
make
report
readily
available
to
the
public,
prepare
and
distribute
a
summary
of
the
report.

5(
b)
Collection
Methodology
and
Management
EPA
asks
States
with
primary
enforcement
authority
to
submit
their
Annual
State
Public
Water
System
Reports
to
in
electronic
(
WordPerfect
compatible)
and
hard­
copy
format.
Section
1414(
c)(
3)(
A)
requires
that
both
the
Annual
State
Public
Water
Systems
Compliance
Reports
and
the
State­
prepared
summaries
be
accessible
to
the
public.
In
its
guidance,
EPA
recommends
that
States
and
EPA
Regions
use
one
or
more
of
the
following
mechanisms
for
making
the
reports
and
summaries
readily
available:

°
Publish
an
official
notice
in
newspapers
regarding
the
availability
of
the
report
or
summary;

°
Conduct
a
press
conference,
issue
a
press
release,
or
incorporate
a
notice
into
standard
press
conferences
to
announce
report
availability;

°
Prepare
notices
for
distribution
in
public
libraries
and
other
public
buildings;

°
Provide
copies
of
the
report
for
review
at
public
offices
and
locations,
libraries,

web
sites,
state/
local
departments
of
health,
etc;
and
°
Include
notices
of
availability
in
local,
state
and
EPA
web
sites.

Additionally,
EPA's
national
report,
which
will
summarize
the
data
collected
from
the
states,
will
be
posted
on
the
Internet.
­
10­
5(
c)
Small
Entity
Flexibility
None
of
the
states,
commonwealths,
or
territories
affected
by
this
ICR
are
small
entities
as
defined
by
the
Regulatory
Flexibility
Act.

5(
d)
Collection
Schedule
Each
Annual
State
Public
Water
Systems
Compliance
Report
covers
violations
that
occurred
in
a
calendar
year.
States
with
primary
enforcement
authority
have
six
months
after
the
end
of
each
calendar
year
to
prepare
their
Reports,
which
are
due
to
EPA
on
the
first
of
July.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
6(
a)
Estimating
Respondent
Burden
Table
1
presents
the
burden
hours
and
costs
per
respondent
as
well
as
for
all
respondents
during
each
year
covered
by
this
ICR.
Preparing
an
Annual
State
Public
Water
Systems
Compliance
Report
involves
reviewing
and
describing
information
on
public
water
systems
violations.
EPA
encourages
states
to
rely
on
SDWIS/
FED
data
for
this
purpose,
as
the
states
are
already
obligated
to
provide
data
to
SDWIS/
FED
on
a
quarterly
basis.
EPA
further
facilitates
this
process
by
providing
a
set
of
computer
queries
to
the
states
every
year
that
extracts
from
SDWIS/
FED
the
violations
data
each
state
needs
to
prepare
its
annual
report.
Some
states
prefer
to
extract
data
from
their
own
databases.
Each
state
must
also
prepare
a
narrative
describing
any
violations
of
variances
or
exemptions.
The
burden
for
each
state
of
preparing
an
Annual
State
Public
Water
System
Compliance
Report
is
estimated
to
be
208
hours.

6(
b)
Estimating
Respondent
Costs
Based
on
responses
from
the
states
contacted,
EPA
estimates
an
average
hourly
labor
rate
(
hourly
rate
plus
overhead)
of
$
95.35
for
managerial
staff,
$
64.60
for
technical
staff,
and
$
40.09
­
11­
for
clerical
staff.
Table
2
presents
a
summary
of
the
estimated
average
annual
cost
to
respondents.
No
capital
or
operations
and
maintenance
costs
are
incurred
by
respondents
under
this
ICR.
This
ICR
does
not
require
continuous
monitoring.

6(
c)
Estimating
Agency
Burden
and
Cost
Table
1
presents
the
estimated
Agency
burden
hours
and
costs
associated
with
the
information
collection
activities
under
this
ICR.
Other
direct
costs
(
copying,
printing,
telephone,

and
mailing
expenses)
are
also
included.

Based
on
the
GSA
pay
schedule,
EPA
estimates
an
average
hourly
labor
rate
(
hourly
rate
plus
the
standard
government
overhead
factor
of
1.6)
of
$
54
for
managerial
staff,
$
40
for
technical
staff,
and
$
21
for
clerical
staff.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Responding
to
this
ICR
by
preparing
an
Annual
State
Public
Water
Systems
Report
is
a
statutory
requirement
for
the
56
states
with
primary
enforcement
authority
and
for
all
10
EPA
Regions.
EPA's
burden
estimate
assumes
all
56
states
and
10
EPA
Regions
will
prepare
reports.

6(
e)
Bottom
Line
Burden
Hours
And
Cost
Tables
See
attached
tables.

6(
f)
Reasons
for
Change
in
Burden
The
increase
in
burden
from
the
most
recently
approved
ICR
is
due
to
the
fact
that
the
Navajo
Nation
was
approved
for
primacy
on
December
6,
2000.
Federal
approval
to
implement
the
drinking
water
program
is
call
primary
enforcement
authority
or
"
primacy."

6(
g)
Burden
Statement:
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
hours
per
response.
Burden
means
the
total
­
12­
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
and
48
CFR
chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,

Room
B102,
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
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
­
13­
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
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
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
OECA­

2004­
0003
and
OMB
control
number
(
2020­
0020)
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
Table
1.
Annual
Respondent
Burden
and
Cost
Annual
Public
Water
Systems
Compliance
Report,
EPA
ICR
Number
1812.03
OMB
Control
Number
2020­
0020
Information
Collection
Activity
Hours
and
Costs
Per
Respondent
Total
Hours
and
Costs
Mgr.
$
95.32/
Hour
Tech.
$
64/
60/
Hour
Cler.
$
40.09/
Hour
Labor
Hours/
Year
Labor
Cost/
Year
($)
Capital/
Startup
Cost
($)*
O
&
M
Cost
($)*
Number
of
Respondent
s
Total,
Hours/
Year
Total,
Cost/
Year
($)**

Review
instructions
and
other
necessary
materials
4
4
258.40
0
0
56
224
14,470.40
Gather
inventory
and
violations
data
from
SDWIS/
FED
and
State
databases
4
4
258.40
0
0
56
224
14,470.40
Review
and
analyze
data
24
24
1550.40
0
0
56
1,344
86,822.40
Prepare
summary
of
violations
of
variences
and
exemptions
4
4
258.40
0
0
56
224
14,470.40
Prepare
report
and
submit
to
EPA
4
28
8
40
2510.80
0
0
56
2,240
$
140,604.80
Make
report
available
to
public
4
4
160.00
0
0
56
224
8,980.16
Total
4
64
12
80
4996.40
0
0
56
4480
279,818.56
*
Same
as
the
Capital/
Startup
and
Operation
&
Maintenance
Costs
addressed
in
Section
6(
b).

**
Includes
Labor
Cost,
Capital/
Startup
and
O&
M
Cost.
Table
2.
Annual
Agency
Burden
and
Cost
Annual
Public
Water
Systems
Compliance
Report,
EPA
ICR
Number
1812.03
OMB
Control
Number
2020­
0020
Information
Collection
Activity
Agency
Hours
and
Costs
Total
Hours
and
Costs
Mgr.
$
54.00/
Hour
Tech.
$
40.00/
Hour
Cler.
$
21.00/
Hour
Agency
Hours/
Year
Labor
Cost/
Year
($)
Capital/
Startup
Cost
($)
O&
M
Cost
($)*
Number
of
Respondent
s
Total
Hours/
Year
Total
Cost/
Year
($)

Modify
guidance
as
necessary
and
distribute
to
states
and
EPA
Regions
1
24
25
1014
1
25
1014
Prepare
and
distribute
tools
for
gathering
data
from
SDWIS/
FED
1
16
17
694
12
204
8,328
Answer
questions
from
states
and
EPA
Regional
Offices
40
40
1600
12
480
19,200
Provide
support
for
Indian
Land
reporting
120
120
4800
9
1080
43,200
Review
state
reports
and
data
from
SDWIS/
FED
40
40
1600
12
480
19,200
Prepare
and
distribute
annual
report
where
EPA
directly
implements
drinking
water
4
80
12
96
3668
2
192
7,336
Prepare
and
distribute
national
summary
report
4
120
16
140
5352
1
140
5352
Total
10
440
28
478
18,728
49
2601
103,630
*
O&
M
costs
include
photocopying,
postage,
and
telephone.
