   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 1812.04
(Reinstatement)

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.

Fifty-five states (including Puerto Rico, the Virgin Islands, American
Samoa, Guam, the Commonwealth of the Northern Mariana Islands, and
Navajo Nation) currently have primary enforcement authority under the
Safe Drinking Water Act. The Navajo Nation was approved for primacy on
December 6, 2000.   Currently the State of Wyoming and the District of
Columbia neither have primary enforcement authority nor are they seeking
primary authority, so the number of 56 states is unlikely to change over
the next three years of this ICR. The cost of this ICR to each state
with primary enforcement authority will be approximately $4,996.40
during each of the three years 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

 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 EPA-provided 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 July 2, 2009 (74 FR 31730)  No
comments were received.

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		Organization 

Robert Bomberger	717-787-0127		Pennsylvania Dept of Environmental
Protection

Nancy Reilman	410-537-3729		Maryland Dept of the Environment

Joan Cockrell		601-576-7518		Mississippi Bureau of Public Water Systems

As states have now completed eleven of these annual reports, most of
them 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
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 (CBI).

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 except
Wyoming, and for the U.S. Virgin Islands, Puerto Rico, American Samoa,
Guam, and the Northern Mariana Islands.  Primary enforcement authority
has not been approved for the District of Columbia or for Indian Tribes
other than the Navajo Nation.  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 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 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);

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 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. 

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 the Bureau of Labor website for State and Local governments
(http//www.bls.gov/ococg/cgs042.htm),  EPA estimates an average hourly
labor rate (hourly rate plus overhead  factor of 1.6) of $68.46 for
managerial staff, $54.69 for technical staff, and $38.01 for clerical
staff.  Table 1: Annual Respondent Burden,  presents a summary of the
estimated respondent average annual cost  associated with this ICR.  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 2: Annual Agency Burden, 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 $60.45 for managerial staff, $46.21 for technical staff, and $25.08
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 55 states with primary
enforcement authority and for all 10 EPA Regions.  EPA’s burden
estimate assumes all  states and 10 EPA Regions will prepare reports.

6(e)	Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculation for the
respondents and the Agency are shown in Tables 1 and 2, respectively and
summarized below.	

6(f)	Reasons for Change in Burden

The decrease in burden from the most recently approved ICR is due to a
miscalculation of the number of states submitting reports.  Wyoming was
counted in the previous ICR as a respondent although it doesn’t have
primacy for the drinking water program and the US EPA submits its annual
report.  The number of respondents should be fifty-five entities, which
includes 49 states, 5 territories and one tribe.  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 80
hours per response.  Burden means the total time, effort, or financial
resources expended by persons to generate, maintain, retain, or disclose
or provide information to or for a Federal agency.  This includes the
time needed to review instructions; develop, acquire, install, and
utilize technology and systems for the purposes of collecting,
validating, and verifying information, processing and maintaining
information, and disclosing and providing information; adjust the
existing ways to comply with any previously applicable instructions and
requirements; train personnel to be able to respond to a collection of
information; search data sources; complete and review the collection of
information; and transmit or otherwise disclose the information.  An
agency may not conduct or sponsor, and a person is not required to
respond to, a collection of information unless it displays a currently
valid OMB control number.  The OMB control numbers for EPA’s
regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.     

To comment on the Agency's need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID Number
EPA-HQ-OECA-2009-0280, which is available for online viewing at
www.regulations.gov, or in person viewing at the Enforcement and
Compliance Docket in the EPA Docket Center (EPA/DC), EPA West, Room
3334, 1301 Constitution Avenue, NW, Washington, D.C.  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
Enforcement and Compliance Docket is (202) 566-1752.  An electronic
version of the public docket is available at www.regulations.gov.  This
site can be used 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.  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, D.C. 20503, Attention: Desk Officer for
EPA.  Please include the EPA Docket ID Number EPA-HQ-OECA-2009-0280 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 1812.04
OMB Control Number 2020-0020

Information Collection Activity	

Hours and Costs Per Respondent	

Total Hours and Costs

	

Mgr. 

$68.46/

Hour	

Tech.

$54.96/

Hour	

Cler.

$38.01/

Hour	

Labor

Hours/

Year	

Labor

Cost/

Year ($)	

Capital/

Startup

Cost ($)*	

O & M 

Cost ($)*	

Number of Respondents

	

Total,

 Hours/

Year	

Total,

 Cost/Year ($)**



Review instructions and other necessary materials	

	

4	

	

4	

218.36	

0	

0	55	

220	12,010



Gather inventory and violations data from SDWIS/FED and State databases	

	

4	

	

4	

218.36	

0	

0	55	

220	12,010



Review and analyze data	

	

24	

	

24	1,310.14	

0	

0	55	

1,320	72,058





Prepare summary of violations of variences and exemptions	

	

4	

	

4	218.36	

0	

0	55	

220	12,010



Prepare report and submit to EPA	

4	

28	

8	

40	2,106.43	

0	

0	55	

2,200	115,854



Make report available to public	

	

	

4	

4	152.04	

0	

0	55	

220	8,362



Total	

4	

64	

12	

80	4,223.69	

0	

0	55	

4400	232,303

*   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 1812.04
OMB Control Number 2020-0020

Information Collection Activity	

Agency Hours and Costs	

Total Hours and Costs

	

Mgr. 

$60.45/

Hour	

Tech.

$46.21/

Hour	

Cler. $25.08/ Hour	

Agency

Hours/

Year	

Labor

Cost/

Year ($)	

Capital/

Startup

Cost ($)	

O& M 

Cost ($)*	

 Number of Respondents	

Total

 Hours/

Year	

Total

 Cost/Year ($)



Modify guidance as necessary and distribute to states and EPA Regions	

1	

24	

	

25	1,164	

	

	

1	

25	1,164



Prepare and distribute tools for gathering data from SDWIS/FED	

1	

16	

	

17	796	

	

	

12	

204	9,552



Answer questions from states and EPA Regional Offices	

	

40	

	

40	1,840	

	

	

12	

480	22,080



Provide support for Indian Land reporting	

	

120	

	

120	5,520	

	

	

9	

1080	49,680



Review state reports and data from SDWIS/FED	

	

40	

	

40	2,080	

	

	

12	

480	24,960



Prepare and distribute annual report where EPA directly implements
drinking water	

4	

80	

12	

96	4,220	

	

	

2	

192	8,440



Prepare and distribute national summary report	

4	

120	

16	

140	6,160	

	

	

1	

140	6,160



Total	

10	

440	

28	

478	15,620

	

	

	

49	

2601	

122,036

* O&M costs include photocopying, postage, and telephone.

 

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