Information
Collection
Request
for
the
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
Program
EPA
ICR
Number
1955.02
OMB
Control
Number
2040­
0236
February
2002
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
ICR
February
2002
CONTENTS
A.
1
Identification
of
the
Information
Collection
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1
A.
1.
a
Title
and
Number
of
the
Information
Collection
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1
A.
1.
b
Short
Characterization
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1
A.
2
Need
for
and
Use
of
the
Collection
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2
A.
2.
a
Authority
and
Need
for
the
Collection
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2
A.
2.
b
Practical
Utility/
Users
of
the
Data
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3
A.
3
Nonduplication,
Consultations
and
Other
Collection
Criteria
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4
A.
3.
a
Nonduplication
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4
A.
3.
b
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
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4
A.
3.
c
Consultations
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4
A.
3.
d
Effects
of
Less
Frequent
Collection
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5
A.
3.
e
General
Guidelines
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5
A.
3.
f
Confidentiality
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6
A.
3.
g
Sensitive
Questions
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6
A.
4
The
Respondents
and
the
Information
Requested
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7
A.
4.
a
Respondents
and
SIC
Codes
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7
A.
4.
b
Information
Requested
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7
A.
5
The
Information
Collected
 
Agency
Activities,
Collection
Methodology
and
Information
Management
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10
A.
5.
a
Agency
Activities
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10
A.
5.
b
Collection
Methodology
and
Management
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10
A.
5.
c
Small
Entity
Flexibility
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10
A.
5.
d
Collection
Schedule
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11
A.
6
Estimating
the
Burden
and
Cost
of
the
Collection
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12
A.
6.
a
Estimating
Burden
and
Cost
to
Public
Water
Systems
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12
A.
6.
b
Estimating
the
Burden
and
Cost
to
States
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16
A.
6.
c
Estimating
Burden
and
Cost
to
EPA
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20
A.
6.
d
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
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22
A.
6.
e
Reasons
For
Change
In
Burden
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23
A.
6.
f
Burden
Statement
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23
APPENDIX
A:
Section
1419
of
the
SDWA
APPENDIX
B:
Burden
and
Cost
Tables
for
States
and
Water
Systems
for
Operator
Certification
APPENDIX
C:
Sample
Checklist
&
Crosswalk
for
Operator
Certification
APPENDIX
D:
Working
Group
Membership
Lists
APPENDIX
E:
Response
to
Comments
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
ICR
February
2002
1Guidelines
for
the
Certification
and
Recertification
of
the
Operators
of
Community
and
Nontransient
Noncommunity
Public
Water
Systems,
Vol.
64,
No.
24
Federal
Register,
5916,
(
February
1999).

2For
purposes
of
this
ICR,
a
state
is
defined
as
the
50
states
and
the
Commonwealth
of
Puerto
Rico.

1
A.
1
Identification
of
the
Information
Collection
A.
1.
a
Title
and
Number
of
the
Information
Collection
Information
Collection
Request
for
the
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
Program.
OMB
Control
Number:
2040­
0236.

A.
1.
b
Short
Characterization
EPA's
Operator
Certification
Guidelines1
require
each
state2
to
provide
documentation
demonstrating
that
it
has
adopted
and
is
implementing
an
enforceable
operator
certification
program
that
requires
all
community
water
systems
(
CWSs)
and
nontransient
noncommunity
water
systems
(
NTNCWSs)
to
have
properly
trained
and
certified
operators.
Any
state
that
does
not
adopt
and
implement
an
operator
certification
program
that
meets
EPA's
Guidelines
is
subject
to
a
20
percent
withholding
of
the
funds
that
it
is
otherwise
entitled
to
receive
under
§
1452
of
1996
Amendments
to
the
Safe
Drinking
Water
Act
(
SDWA).
This
information
collection
will
be
conducted
annually
by
EPA's
Regional
Offices
in
consultation
with
the
Office
of
Ground
Water
and
Drinking
Water
(
OGWDW).
EPA
will
use
the
information
to
determine
whether
20%
of
the
funds
that
the
state
is
otherwise
entitled
to
receive
under
§
1452
of
SDWA
must
be
withheld.
CWSs
and
NTNCWSs
will
incur
an
associated
information
collection
burden
to
apply
for
and
renew
the
certifications
of
their
operators.

Section
1419
of
the
1996
SDWA
Amendments
authorizes
$
30
million
to
be
appropriated
annually
from
fiscal
year
1997
through
fiscal
year
2003
for
the
reimbursement
of
the
training
(
including
an
appropriate
per
diem
for
unsalaried
operators)
and
certification
costs
for
small
system
(
i.
e.,
serving
3,300
persons
or
fewer)
operators.
States
will
be
required
to
submit
a
grant
application
to
EPA
and
an
annual
work
plan
that
describes
how
funds
are
being
spent.
There
will
be
no
information
collection
burden
to
systems
for
expense
reimbursement
grants.

The
cost
and
burden
to
states
for
this
ICR
is
estimated
at
$
0.4
million
and
11,914
hours
over
3
years.
The
estimated
system
burden
is
290,511
hours,
with
an
estimated
cost
of
$
6.5
million.
The
average
annual
cost
and
burden
per
state
is
$
2,696
(
not
in
millions),
78
hours.
On
a
per
system
level,
an
average
annual
cost
and
burden
of
$
32
(
not
in
millions)
and
1
hour
is
estimated.

The
total
respondent
cost
and
burden
for
the
Operator
Certification
Guidelines
and
the
Operator
Certification
Expense
Reimbursement
Grants
program
over
the
3
years
covered
by
this
ICR
is
estimated
at
$
6.9
million
and
302,425
hours.
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
ICR
February
2002
2
A.
2
Need
for
and
Use
of
the
Collection
A.
2.
a
Authority
and
Need
for
the
Collection
Through
the
1996
SDWA
Amendments,
Congress
conveyed
the
importance
of
properly
trained
operators
in
providing
safe
drinking
water
to
the
public.
To
underscore
the
importance
of
operator
certification,
the
program
was
linked
to
the
Drinking
Water
State
Revolving
Fund
(
DWSRF)
program
through
a
withholding
of
20
percent
of
the
funds
that
a
state
is
otherwise
entitled
to
if
its
program
does
not
meet
the
requirements
of
EPA's
Guidelines.
In
addition,
§
1419
authorizes
$
30
million
to
be
appropriated
annually
from
fiscal
year
1997
through
fiscal
year
2003
for
the
reimbursement
of
the
training
and
certification
costs
of
small
system
(
i.
e.,
serving
3,300
persons
or
fewer)
operators.
The
Act
further
stipulates
that
if
sufficient
funds
are
unavailable,
that
this
money
be
taken
from
the
annual
DWSRF
appropriation.

This
information
collection
is
driven
by
the
withholding
provision
and
the
expense
reimbursement
grants
described
above.
EPA
is
required
under
§
1419
to
make
an
annual
determination
on
whether
to
withhold
a
percentage
of
a
state's
DWSRF
allotment,
based
on
whether
a
state
is
implementing
an
operator
certification
program
that
meets
EPA's
Operator
Certification
Guidelines.
In
order
to
make
these
decisions,
EPA
must
collect
information
from
the
states
as
required
by
EPA
guidance.
States,
in
turn,
must
collect
information
from
water
systems
as
required
by
their
respective
operator
certification
programs.
Similarly,
prior
to
awarding
expense
reimbursement
grants
to
states,
EPA
will
need
to
collect
information
from
states
to
ensure
that
the
state
has
a
plan
for
distributing
the
funds
to
small
system
operators.
Any
state
that
does
not
have
an
approved
operator
certification
program
will
be
ineligible
for
an
expense
reimbursement
grant.
All
funds
that
are
withheld
from,
or
unawarded
to
states
will
be
reallotted
to
other
states
that
have
met
the
requirements
of
EPA's
Operator
Certification
Guidelines.

The
1996
Amendments
require
EPA
to
establish
minimum
requirements
for
the
certification
and
recertification
of
operators
of
CWSs
and
NTNCWSs.
Under
§
1419
of
the
SDWA,
states
have
two
years
from
the
date
of
publication
of
the
final
Guidelines
to
adopt
and
begin
implementing
an
operator
certification
program
that
meets
the
requirements
of
the
federal
Guidelines.
Beginning
February
5,
2001,
any
state
that
has
not
done
so
will
receive
a
20
percent
withholding
from
the
amount
it
was
otherwise
entitled
to
receive
for
its
DWSRF
capitalization
grant.

As
the
basis
for
determining
compliance
with
§
1419
of
the
SDWA,
states
are
required
under
EPA's
Guidelines
to
submit
the
following
information
to
EPA:


An
Attorney
General's
certification,
or
certification
from
delegated
counsel,
that
the
state
has
the
legal
authority
to
implement
the
program
and
to
require
that
systems
comply
with
the
appropriate
requirements
of
the
program.

°
A
copy
of
the
state
operator
certification
regulations.

°
A
full
description
and
explanation
of
how
the
state's
operator
certification
program
complies
with,
or
is
substantially
equivalent
to,
the
requirements
of
these
Guidelines.
States
may
use
the
"
Checklist
&
Crosswalk"
as
a
guide
to
ensure
proper
documentation
(
see
Appendix
C).
The
Checklist
&
Crosswalk
is
part
of
EPA's
Implementation
Guidance
for
states
and
is
available
online
at:
http://
www.
epa.
gov/
safewater/
opcert/
stimp.
pdf.
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
ICR
February
2002
3
As
a
prerequisite
to
receiving
Expense
Reimbursement
Grants,
states
will
be
required
to
submit
the
following:

°
A
grant
application.

A.
2.
b
Practical
Utility/
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).
EPA
will
use
the
information
to
determine
whether
states
have
adopted
and
are
implementing
operator
certification
programs
in
accordance
with
the
Guidelines
developed
by
EPA
and
the
relevant
sections
of
SDWA.
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
ICR
February
2002
4
A.
3
Nonduplication,
Consultations
and
Other
Collection
Criteria
The
following
sections
verify
that
this
information
collection
satisfies
the
Office
of
Management
and
Budget's
(
OMB's)
nonduplication
and
consultation
guidelines.

A.
3.
a
Nonduplication
All
of
the
information
that
will
be
requested
from
the
states
under
this
ICR
is
required
by
statute
or
EPA
guidance
and
is
not
available
from
other
sources.
Presently,
drinking
water
information
is
stored
in
EPA's
Safe
Drinking
Water
Information
System
(
SDWIS).
The
database
contains
general
information
on
public
water
systems
(
PWS)
(
e.
g.,
size,
type,
source)
and
their
violations
of
EPA's
regulations
for
safe
drinking
water.
Specifically,
violations
of
the
following
three
types
are
reported:
maximum
contaminant
levels
(
the
maximum
level
of
a
specific
contaminant
that
can
occur
in
drinking
water),
treatment
techniques
(
specific
methods
facilities
must
follow
to
remove
certain
contaminants),
and
monitoring
and
reporting
requirements
(
schedules
utilities
must
follow
to
report
testing
results).
The
1996
SDWA
Amendments
created
the
DWSRF
program,
under
which
EPA
must
begin
to
make
withholding
decisions
for
operator
certification,
also
newly
created
by
these
Amendments.
The
requested
information
will
be
prepared
or
compiled
by
states
based
on
their
newly
developed
Operator
Certification
Guidelines
and
has
never
been
developed
or
collected
previously.
In
addition,
while
state
laws
and
regulations
are
available
to
EPA,
the
most
recent
versions
may
not
always
be
readily
available.
The
information
that
EPA
will
collect,
therefore,
is
not
unnecessarily
duplicative
of
information
otherwise
available
to
the
Agency.

A.
3.
b
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
In
compliance
with
the
requirements
of
the
1995
Paperwork
Reduction
Act,
EPA
published
a
notice
in
the
Federal
Register
on
February
28,
2001
(
66
FR
12776)
to
solicit
public
comment
on
this
ICR.

A.
3.
c
Consultations
The
Operator
Certification
Guidelines
are
the
result
of
a
thorough
stakeholder
consultation
process
under
which
EPA
utilized
the
combined
knowledge
and
expertise
of
two
work
groups.
The
State­
EPA
Work
Group
was
appointed
to
fulfill
EPA's
responsibility
under
section
1419(
a)
to
publish
guidelines
on
operator
certification
"
in
cooperation
with
states."
This
work
group
was
composed
of
seven
state
and
ten
EPA
representatives.
The
other
work
group,
the
Operator
Certification
Work
Group
of
the
National
Drinking
Water
Advisory
Council
(
NDWAC),
also
called
the
Partnership,
was
formed
to
provide
EPA
with
views
in
addition
to
those
of
states.
This
group,
a
subset
of
the
full
NDWAC,
was
composed
of
23
members
representing
PWSs,
environmental
and
public
interest
advocacy
groups,
state
drinking
water
programs,
EPA,
U.
S.
Department
of
Agriculture,
U.
S.
Public
Health
Service,
Indian
Health
Service,
and
other
interest
groups
(
See
Appendix
D
for
a
complete
list
of
members
and
their
affiliations).

Procedurally,
the
two
groups
worked
closely
together.
Throughout
the
process,
the
Partnership
met
on
four
separate
occasions,
and
the
State­
EPA
Work
Group
met
three
times
to
exchange
reviews
of
the
proposed
recommendations
for
minimum
guidelines
for
state
operator
certification
programs.
The
Partnership
then
presented
its
recommendations
to
the
full
NDWAC,
which
in
turn
presented
its
recommendations
to
EPA.
The
draft
Guidelines
were
published
for
public
comment
in
the
Federal
Register
on
March
27,
1998.
During
the
90­
day
public
comment
period,
EPA
held
public
stakeholder
meetings
in
San
Francisco,
California;
Dallas,
Texas;
and
Washington,
DC,
to
brief
interested
parties
on
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
ICR
February
2002
5
the
draft
Guidelines
and
to
accept
public
comments.
Ninety­
eight
parties
responded
to
EPA's
request
for
public
comment.

In
August
1998,
both
work
groups
met
to
consider
the
public
comments
and
to
make
recommendations
for
finalizing
the
Guidelines
based
on
the
public
comments.
The
resulting
recommendations
were
forwarded
to
the
full
NDWAC
for
consideration.
In
November
1998,
the
NDWAC
formally
transmitted
its
recommendations
to
EPA.
The
Agency
made
changes
based
on
public
comment
and
on
the
recommendations
of
the
NDWAC.
These
Guidelines
set
the
minimum
baseline
standards
for
a
state
operator
certification
program
to
meet
the
provisions
of
the
1996
Amendments
to
the
SDWA.

A.
3.
d
Effects
of
Less
Frequent
Collection
Annual
reporting
is
essential
to
enable
EPA
to
make
withholding
determinations
on
each
fiscal
year's
funds.
Furthermore,
the
annual
submittal
of
a
workplan
will
allow
the
Agency
to
ensure
that
states
are
using
the
Expense
Reimbursement
Grant
program
funds
for
training
as
intended
in
the
Act.

A.
3.
e
General
Guidelines
This
collection
does
not
violate
any
of
the
OMB
guidelines
for
information
collection
activities.
Specifically,
the
respondents
are
not
required
to:

°
Report
information
to
EPA
more
than
quarterly;

°
Prepare
a
written
response
to
a
collection
of
information
in
fewer
than
30
days
after
receipt
of
a
request;

°
Submit
more
than
an
original
and
two
copies
of
any
document;

°
Retain
records,
other
than
health,
medical,
government
contract,
grant­
in­
aid
or
tax
records,
for
more
than
three
years;

°
Participate
in
a
statistical
survey
that
is
not
designed
to
produce
data
that
can
be
generalized
to
the
universe
of
the
study;

°
Use
a
statistical
data
classification
that
has
not
been
reviewed
and
approved
by
OMB;

°
Receive
a
pledge
of
confidentiality
that
is
not
supported
by
authority
established
in
statute
or
regulation,
that
is
not
supported
by
disclosure
and
data
security
policies
that
are
consistent
with
the
pledge,
or
which
unnecessarily
impedes
sharing
of
data
with
other
agencies
for
compatible
confidential
use;
or
°
Submit
proprietary,
trade
secret,
or
other
confidential
information
unless
EPA
can
demonstrate
that
it
has
instituted
procedures
to
protect
the
information's
confidentiality
to
the
extent
permitted
by
law.

A.
3.
f
Confidentiality
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
ICR
February
2002
6
This
information
collection
does
not
require
respondents
to
disclose
confidential
information.

A.
3.
g
Sensitive
Questions
This
information
collection
does
not
ask
questions
pertaining
to
sexual
behavior
or
attitudes,
religious
beliefs,
or
other
matters
usually
considered
private.
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
ICR
February
2002
7
A.
4
The
Respondents
and
the
Information
Requested
A.
4.
a
Respondents
and
NAICS
Codes
The
respondents
to
this
information
collection
include
personnel
from
the
state
Drinking
Water
Program
and
PWSs.
The
North
American
Industry
Classification
System
(
NAICS)
code
for
the
state
agencies
that
include
the
Drinking
Water
Programs
are
classified
under
either
92411
 
Air
and
Water
Resources
and
Solid
Waste
Management
or
92312
 
Administration
of
Public
Health
Programs.
State
licensing/
certification
agencies
are
classified
under
92615.
The
NAICS
code
for
PWSs
is
22131.

A.
4.
b
Information
Requested
(
i)
Data
Items,
Including
Recordkeeping
Requirements
To
satisfy
§
1419
of
SDWA
(
regarding
EPA's
Operator
Certification
Guidelines),
states
are
required
to
submit
the
following
information
to
EPA:


An
Attorney
General's
certification,
or
certification
from
delegated
counsel,
that
the
state
has
the
legal
authority
to
implement
the
program
and
to
require
that
systems
comply
with
the
appropriate
requirements
of
the
program.

°
A
copy
of
the
state
operator
certification
regulations.

°
A
full
description
and
explanation
of
how
the
state's
operator
certification
program
complies
with,
or
is
substantially
equivalent
to,
the
requirements
of
these
Guidelines.
This
description
shall
include:

S
A
description
of
the
basis
for
classification
of
treatment
facilities
and/
or
distribution
systems.

S
A
description
of
the
renewal
requirements
for
each
classification
level.

S
A
description
of
the
special
renewal
requirements
for
grandparented
operators,
if
applicable.

S
Documentation
of
the
exam
validation
process.

S
A
description
of
how
the
state
plans
to
track
system
compliance.

S
A
description
of
how
the
state
plans
to
enforce
its
operator
certification
program.

S
A
description
of
program
resources
including:
a.
Staff
b.
Data
management
c.
Testing
d.
Enforcement
e.
Administration
f.
Training
approval
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
ICR
February
2002
8
g.
Fee
System
S
A
description
of
the
state's
internal
and
external
program
review
procedures.

S
A
description
of
the
state's
plan
for
stakeholder
involvement.

S
An
implementation
schedule,
including:
(
a)
The
effective
date
of
the
state's
regulations;
(
b)
The
deadline
for
system
owners
to
apply
for
grandparenting,
if
applicable;
(
c)
The
date
by
which
all
systems
will
have
a
certified
or
grandparented
operator;
and
(
d)
Dates
for
stakeholder
involvement
activities.

Expense
Reimbursement
Grants
Program
°
A
grant
application.

(
ii)
Respondent
Activities
The
activities
involved
in
response
to
the
information
collection
are
listed
below
by
respondent.

States
Operator
Certification
Guidelines

Obtain
an
Attorney
General
(
AG)
certification.


Prepare
an
initial
submittal
consisting
of
all
of
the
data
items
listed
above
for
the
Operator
Certification
Guidelines.


Prepare
an
annual
submittal
that
contains
a
report
on
the
status
of
program
implementation,
documentation
of
any
changes
to
the
program,
and
if
changes
are
made,
a
new
AG's
certification.

Expense
Reimbursement
Grants
Program

Submit
a
grant
application.


Prepare
an
annual
report.

Water
Systems
Community
and
Nontransient
Noncommunity
Systems
For
the
Operator
Certification
Guidelines,
all
CWSs
and
NTNCWSs
must:
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
ICR
February
2002
9

Acquire
certified
operator(
s)
holding
a
valid
certification
equal
to
or
greater
than
the
classification
of
the
system
(
many
states
already
required
this
before
EPA
published
Operator
Certification
Guidelines).


Maintain/
renew
certification(
s)
as
needed.

There
is
no
cost
or
burden
on
water
systems
for
the
Expense
Reimbursement
Grants
Program.
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
ICR
February
2002
3These
definitions
were
taken
from
section
601
of
the
Regulatory
Flexibility
Act
(
RFA).

10
A.
5
The
Information
Collected
 
Agency
Activities,
Collection
Methodology
and
Information
Management
A.
5.
a
Agency
Activities
The
following
EPA
activities
are
associated
with
this
information
collection
for
operator
certification.


Respond
to
questions
from
states
about
the
information
collection;


Review
the
submitted
information
from
states;


Request,
if
necessary,
additional
information
from
states;


Notify
states
of
the
final
determination
on
the
adequacy
of
their
programs;
and

Conduct
an
annual
review
of
state
programs
to
determine
compliance
with
the
Guidelines.

A.
5.
b
Collection
Methodology
and
Management
In
collecting
the
information
associated
with
this
ICR,
EPA
will
use
telephones,
the
mail,
or
electronic
means.
Individual
states
will
have
the
option
of
paper
or
electronic
reporting
(
i.
e.,
e­
mail
or
diskette).
EPA
will
ensure
the
accuracy
and
completeness
of
the
information
by
reviewing
each
submittal.

A.
5.
c
Small
Entity
Flexibility
EPA's
Guidelines
provide
states
with
maximum
flexibility
in
developing
and
implementing
their
operator
certification
program.
EPA
has
also
published
a
document
entitled:
Small
System
Regulatory
Requirements
Under
the
Safe
Drinking
Water
Act
Amendments
of
1996,
and
is
working
on
several
other
tools
to
help
small
systems
comply.
Furthermore,
funding
is
available
for
training
and
certification
expenses
of
small
system
operators
through
the
Expense
Reimbursement
Grants
program,
and
EPA's
Guidelines
permit
the
use
of
circuit
riders
(
certified
operators
who
are
responsible
for
multiple
systems)
as
determined
to
be
appropriate
by
the
state.

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.
3
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
(
SBA)
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.
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
ICR
February
2002
11
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
(
RFA)
of
all
rules
that
have
a
"
significant
economic
impact
on
a
substantial
number
of
small
entities."
Since
EPA
is
not
promulgating
a
rule,
this
ICR
is
not
subject
to
SBREFA.

A.
5.
d
Collection
Schedule
Under
§
1419,
states
have
two
years
from
the
date
of
publication
of
EPA's
Guidelines
to
adopt
and
begin
implementing
an
operator
certification
program.
When
the
final
Guidelines
for
operator
certification
were
published
in
the
Federal
Register
on
February
5,
1999
(
64
FR
5916),
two
sections
were
reserved
for
the
submittal
schedule
and
withholding
process
for
revised
and
equivalent
programs.
EPA
developed
these
sections
and,
after
considering
public
comments,
published
them
in
the
Federal
Register
on
April
18,
2001
(
66
FR
19939).
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
ICR
February
2002
4EPA
obtained
this
figure
from
SDWIS
after
the
July
2000
updates.

12
A.
6
Estimating
the
Burden
and
Cost
of
the
Collection
This
section
describes
the
annual
burden
and
cost
for
the
information
collection
activities
associated
with
the
Operator
Certification
Guidelines
and
the
Expense
Reimbursement
Grants
Program.
The
burden
and
cost
estimates
for
PWSs
are
shown
in
Section
A.
6.
a,
burden
and
costs
to
states
are
shown
in
Section
A.
6.
b,
and
the
Agency's
burden
and
cost
estimates
are
shown
in
Section
A.
6.
c.
Because
operator
certification
is
a
new
provision,
EPA
made
assumptions
for
the
labor
estimates
for
many
of
the
activities
associated
with
it.
To
the
extent
possible,
assumptions
were
based
on
similar
activities
for
other
programs,
and
consultations
with
states
or
individuals
already
involved
with
operator
certification.
EPA
emphasizes
that
the
per
respondent
estimates
represent
the
average
burden
and
cost
over
the
three
year
period
covered
by
this
ICR
(
2001
through
2003).
Some
respondents
will
incur
higher
costs
and
some
will
fall
below
the
average.
Appendix
B
provides
detailed
burden
and
cost
estimates
for
PWSs
and
states.

A.
6.
a
Estimating
Burden
and
Cost
to
Public
Water
Systems
For
purposes
of
calculating
labor
costs,
EPA
assumes
that
systems
serving
more
than
3,300
people
will
have
an
average
hourly
rate
for
system
personnel
of
$
28,
and
systems
serving
3,300
and
fewer
will
have
an
average
rate
for
system
personnel
of
$
14.50
per
hour.
These
hourly
rates
are
consistent
with
rates
used
in
other
drinking
water
ICR
documents
for
PWSs.

There
are
approximately
73,140
public
CWSs
and
NTNCWSs
reported
in
the
SDWIS
database.
4
EPA
estimates
that
over
the
course
of
this
ICR,
68,345
public
CWSs
and
NTNCWSs
will
be
affected
by
Operator
Certification.
The
Agency
assumes
that
a
percentage
of
systems
will
be
unaffected
during
this
ICR
approval
period
due
to
the
grandparenting
provision
and
baseline
standard
number
five,
which
permits
states
to
establish
a
renewal
cycle
of
up
to
3
years.
This
ICR
addresses
EPA's
Guidelines
for
the
Certification
and
Recertification
of
Operators
of
CWSs
and
NTNCWSs,
and
the
Expense
Reimbursement
Grants
Program
to
assist
small
CWSs
and
NTNCWSs
with
training
and
certification
costs.
EPA
estimates
that
during
this
ICR
approval
period,
the
average
annual
burden
for
all
CWSs
and
NTNCWSs
will
be
approximately
96,837
hours.
The
average
annual
cost
to
CWSs
and
NTNCWSs
will
be
$
2.2
million.
Over
the
3­
year
life
span
of
this
ICR,
the
estimated
burden
to
affected
water
systems
will
be
290,511
hours
and
$
6.5
million.
Table
6.1
summarizes
these
burden
estimates.
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
ICR
February
2002
13
Table
6.1:
Total
Burden/
Costs
to
Systems
for
Operator
Certification
Activities
Total
Estimated
Burden
Average
Annual
Burden
Hours
Dollars
Hours
Dollars
Operator
Certification
Guidelines
(
Labor)
290,511
$
3,772,552
96,837
$
1,257,517
Operator
Certification
Guidelines
(
O&
M)
$
2,742,044
$
914,015
Expense
Reimbursement
Grants
Program
0
$
0
0
$
0
Total
Burden
for
Systems
290,511
$
6,514,596
96,837
$
2,171,532
Average
Annual
Burden
and
Cost
per
System
1
$
32
Central
to
the
assumptions
used
to
derive
these
burden
and
cost
estimates
was
the
assumption
that
30
percent
of
operators
of
small
CWSs
and
70
percent
of
operators
of
small
NTNCWSs
are
unpaid.
EPA
assumes
that
all
operators
of
systems
serving
>
3,300
people
will
be
paid.
NTNCWSs
are
comprised
primarily
of
schools,
factories,
and
office
parks,
where
an
existing
employee
will
take
on
the
additional
responsibility
of
running
the
water
system.
Since
it
is
likely
that
this
individual
will
not
be
paid
a
separate
salary
for
the
additional
responsibility
of
running
the
system,
EPA
is
considering
these
individuals
unpaid
for
purposes
of
this
ICR.

The
Agency
also
assumes
that
a
large
portion
of
the
costs
to
small
systems
for
training
and
certification
(
i.
e.,
fees
for
training
courses
and
certification,
travel,
and
per
diem
for
unsalaried
operators)
will
be
absorbed
by
the
Expense
Reimbursement
Grants
Program.

Initial/
Start­
Up
Burden
to
Systems
for
Operator
Certification
Guidelines
Two
possible
scenarios
under
EPA's
Operator
Certification
Guidelines
for
any
CWS
or
NTNCWS
are:

Scenario
A
The
system
already
has
a
certified
operator.

Scenario
B
The
system
is
under
a
new
requirement
to
have
a
certified
operator
and
will
either
apply
to
grandparent
an
operator,
certify
an
operator,
or
hire
a
circuit
rider.

The
assumptions
behind
these
two
scenarios
are
based
on
the
Information
for
States
on
Recommended
Operator
Certification
Requirements
(
EPA
816­
R­
98­
001),
on
discussions
with
states
that
attended
the
Operator
Certification
Implementation
Workshops
held
in
Spring
1999,
and
on
EPA's
review
of
draft
operator
certification
programs
submitted
by
states.
These
assumptions
are
further
described
below.
The
burden
associated
with
each
scenario
is
weighted
by
the
appropriate
percentage
of
systems
that
will
fall
under
each
scenario,
and
then
totaled
to
derive
the
line
item
burden
per
system
for
this
activity.
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
ICR
February
2002
5If
a
state
chooses
to
offer
grandparenting,
only
those
systems
that
are
required
to
have
a
certified
operator
for
the
first
time
as
a
result
of
the
Guidelines
are
eligible
to
apply.

14
Scenario
A:
Already
has
a
certified
operator
Based
on
Chapter
1
of
EPA's
Information
for
States
on
Recommended
Operator
Certification
Requirements,
the
Summary
of
Existing
Operator
Certification
Programs,
an
estimated
50
percent
of
small
systems
and
90
percent
of
medium/
large
systems
(
systems
serving
greater
than
3,300
persons)
already
have
a
certified
operator.
It
is
assumed
that
systems
which
fall
under
Scenario
A
will
bear
no
initial
burden
as
a
result
of
the
Guidelines.

Scenario
B:
Apply
for
grandparenting,
certify
operator,
or
hire
circuit
rider
As
described
above,
EPA
utilized
its
knowledge
of
state
programs
through
the
Summary
of
Existing
Operator
Certification
Programs,
to
estimate
that
50
percent
of
small
systems
and
10
percent
of
medium/
large
systems
would
be
under
a
new
requirement.
5
Through
further
discussions
with
states
and
the
review
of
several
draft
programs,
EPA
estimates
that
30
percent
of
states
will
offer
grandparenting,
and
that
the
vast
majority
of
systems
located
in
these
States
will
apply
to
grandparent
an
operator
(
25
percent
of
small
systems
and
4
percent
of
medium/
large
systems).
Based
on
descriptions
of
grandparenting
applications
provided
by
states,
EPA
estimates
that
it
will
take
systems
approximately
15
minutes
to
complete
a
grandparenting
application.
Based
on
information
from
states
that
attended
the
Operator
Certification
Implementation
Workshops
in
the
Spring
of
1999,
EPA
estimates
that
50
percent
of
state
programs
will
be
effective
in
fiscal
year
2001,
and
that
the
remainder
will
become
effective
in
fiscal
year
2002.
Since
systems
have
two
years
from
the
effective
date
of
their
programs
to
apply
for
grandparenting,
it
is
estimated
that
10
percent
will
apply
in
fiscal
year
2001,
that
30
percent
will
apply
in
fiscal
year
2002,
and
that
the
remaining
systems
will
apply
in
fiscal
year
2003
(
60%).

It
is
estimated
that
13
percent
of
small
systems
and
3
percent
of
medium/
large
systems
will
train
and
certify
an
existing
operator,
and
the
remaining
systems
will
hire
a
circuit
rider
(
12
percent
of
small
systems
and
3
percent
of
medium/
large
systems).

It
is
estimated
that
the
total
3­
year
cost
and
burden
for
CWSs
and
NTNCWSs
to
implement
the
initial
activities
of
the
Operator
Certification
Guidelines
is
$
504,930
and
51,264
hours
in
labor.
There
is
an
additional
cost
of
$
47,952
in
non­
labor
costs
(
O&
M)
for
certification
exam
fees
and
the
application
fees.
Table
6.2
illustrates
the
estimated
total
and
average
annual
cost
and
burden
for
initial
activities
required
by
the
Guidelines.
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
ICR
February
2002
15
Table
6.2:
Initial/
Start­
up
Burden/
Costs
to
Systems
for
Operator
Certification
Guidelines
Activities
Total
Estimated
Burden
Average
Annual
Burden
Hours
Dollars
Hours
Dollars
1
Already
has
a
certified
operator
0
$
0
0
$
0
2
Apply
for
grandparenting
status
from
state,
certify
operator,
or
hire
a
circuit
rider
51,264
$
504,930
17,088
$
168,310
Subtotal
Initial
Burden
(
Labor)
51,264
$
504,930
17,088
$
168,310
O&
M
costs
(
i.
e.,
application
and
exam)
$
47,952
$
15,984
Subtotal
Initial
Burden
(
O&
M)
$
47,952
$
15,984
Total
Initial
Burden
for
Systems
51,264
$
552,882
17,088
$
184,294
Annual/
Recurring
Burden
to
Systems
for
Operator
Certification
Guidelines
°
Maintain
and
renew
certification
The
Agency
used
assumptions
from
the
April
18,
2001
Federal
Register
notice
(
66
FR
19939)
to
estimate
the
information
collection
burden
associated
with
certification
renewal.
Since
all
operators
must
renew
within
a
maximum
of
three
years,
EPA
estimated
that
one
third
of
the
operators
will
seek
renewal
in
a
given
year.
Certification
maintenance
and
renewal
costs
for
the
estimated
12
percent
of
small
systems
that
will
be
covered
by
a
circuit
rider
are
not
included
because
these
costs
will
not
be
absorbed
by
the
system.

It
is
estimated
that
the
total
3­
year
burden
for
CWSs
and
NTNCWSs
to
implement
the
annual
activities
of
the
Operator
Certification
Guidelines
is
$
3.3
million
in
labor
costs
and
239,247
hours.
There
is
an
additional
cost
of
$
2.7
million
in
O&
M
costs
for
non­
labor
related
expenses.
Table
6.3
illustrates
the
total
estimated
burden
and
average
annual
burden
for
annual
activities
required
by
the
Guidelines.

Table
6.3:
Annual/
Recurring
Burden/
Costs
to
Systems
for
Operator
Certification
Guidelines
Activities
Total
Estimated
Burden
Average
Annual
Burden
Hours
Dollars
Hours
Dollars
Maintain
and
renew
certification
(
Labor
only)
239,247
$
3,267,622
79,749
$
1,089,207
Maintain
and
renew
certification
(
O&
M
costs)
(
i.
e.,
renewal
fees)
$
2,694,092
$
898,031
Total
Annual
Burden
for
Systems
239,247
$
5,961,714
79,749
$
1,987,238
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
ICR
February
2002
6This
salary
estimate
is
consistent
with
the
estimate
used
in
the
approved
Unregulated
Contaminant
Monitoring
Regulation
ICR,
EPA
ICR
#
1882.02,
August
1999.

16
Total
System
Burden
for
Operator
Certification
Guidelines
Table
6.4
illustrates
the
total
estimated
burden
and
average
annual
burden
for
initial
and
annual
activities
required
by
EPA's
Guidelines
for
operator
certification.

Table
6.4:
Total
Burden/
Costs
to
Systems
for
Operator
Certification
Guidelines
Activities
Total
Estimated
Burden
Average
Annual
Burden
Hours
Dollars
Hours
Dollars
Initial
Labor
51,264
$
504,930
17,088
$
168,310
Annual
Labor
239,247
$
3,267,622
79,749
$
1,089,207
Total
Labor
290,511
$
3,772,552
96,837
$
1,257,517
Initial
O&
M
(
i.
e.,
application
and
exam)
$
47,952
$
15,984
Annual
O&
M
(
i.
e.,
renewal
fees)
$
2,694,092
$
898,031
Total
O&
M
$
2,742,044
$
914,015
Total
Burden
for
Systems
290,511
$
6,514,596
96,837
$
2,171,532
Average
Annual
Burden
and
Cost
per
System
1
$
32
Total
System
Burden
for
Expense
Reimbursement
Grants
Program
There
is
no
quantifiable
burden
imposed
on
systems
for
the
Expense
Reimbursement
Grants
program.
All
burden
associated
with
this
program
will
be
absorbed
by
states
and
EPA.

A.
6.
b
Estimating
the
Burden
and
Cost
to
States
For
purposes
of
calculating
state
labor
costs,
EPA
assumes
a
fully
loaded
cost
of
$
72,000
to
employ
one
state
full
time
equivalent
(
FTE).
6
Consistent
with
EPA's
February
1999
ICR
Handbook,
it
is
also
assumed
that
one
FTE
is
equivalent
to
2,080
hours
worked
per
year.

EPA
estimates
that
the
total
burden
over
3
years
(
2001­
2003)
for
51
states
to
conduct
the
information
collection
activities
associated
with
this
ICR
will
be
11,914
hours,
with
a
total
cost
of
$
412,449.
State
costs
are
attributed
all
to
labor.
On
average,
the
annual
cost
per
state
is
expected
to
be
$
2,696
with
an
annual
labor
burden
of
78
hours.
Table
6.5
summarizes
these
cost
and
burden
estimates.
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
ICR
February
2002
7EPA
notes
that
the
checklist/
crosswalk
is
not
required,
but
rather
intended
to
assist
states
and
EPA
in
determining
whether
a
program
is
complete
and
meets
the
Guidelines.

17
Table
6.5:
Total
Burden/
Costs
to
States
for
Operator
Certification
Activities
Total
Estimated
Burden
Average
Annual
Burden
Hours
Dollars
Hours
Dollars
Operator
Certification
Guidelines
3,958
$
137,012
1,319
$
45,671
Expense
Reimbursement
Grants
Program
7,956
$
275,437
2,652
$
91,812
Total
Burden
for
States
11,914
$
412,449
3,971
$
137,483
Average
Annual
Burden
per
State
78
$
2,696
Initial/
Start­
up
Burden
to
States
for
Operator
Certification
Guidelines
°
Submit
material
to
EPA
For
the
initial
program
submittal
to
EPA,
states
must
include:

Estimated
time
to
complete
(
hours)

Attorney
General's
certification
8
Checklist/
crosswalk7
16
Program
summary
8
Implementation
schedule
8
Because
EPA
expects
that
all
four
items
will
be
submitted
by
each
state,
the
sum
of
the
estimated
time
to
complete
each
activity,
in
addition
to
an
estimated
four
hours
per
state
to
gather
and
assemble
these
materials
for
submittal,
is
the
estimate
of
burden
associated
with
a
state's
initial
program
submittal
to
EPA
(
i.
e.,
44
hours
per
state).

EPA
estimates
that
the
total
3­
year
cost
and
burden
to
states
for
implementing
the
initial
activities
of
the
Operator
Certification
Guidelines
is
$
77,687
and
2,244
hours.
The
average
annual
burden
is
$
25,896
and
748
hours.
Table
6.6
illustrates
the
total
estimated
burden
and
average
annual
burden
for
the
initial
activities
required
by
the
Guidelines.
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
ICR
February
2002
18
Table
6.6:
Initial/
Start­
up
Burden/
Costs
to
States
for
Operator
Certification
Guidelines
Activity
Total
Estimated
Burden
Average
Annual
Burden
Hours
Dollars
Hours
Dollars
Submit
material
to
EPA
2,244
$
77,687
748
$
25,896
Total
Initial
Burden
for
States
2,244
$
77,687
748
$
25,896
Annual
State
Burden
for
Operator
Certification
Guidelines
°
Submit
material
to
EPA
The
components
of
the
annual
program
submittal
are:


Preparation
of
a
report
documenting
the
status
of
program
implementation
in
each
state.
It
is
assumed
that
this
will
include
a
list
of
statistics
on
the
basis
of
which
EPA
may
measure
progress
(
e.
g.,
the
number
of
systems
with
certified
operators,
system
compliance
information,
etc.).
States
will
also
explain
these
statistics
and
any
other
aspects
of
their
programs
as
needed
within
this
report.


If
changes
were
made
to
a
state's
program,
written
documentation
explaining
the
changes
and
an
Attorney
General's
certification
that
the
program
is
still
enforceable
under
state
law
must
be
submitted.
It
is
estimated
that
on
average,
5
percent
of
states
will
make
changes
to
their
operator
certification
programs.

It
is
estimated
that
it
will
take
16
hours
for
the
average
state
to
prepare
the
status
report.
The
agency
does
not
expect
that
any
states
will
make
programmatic
changes
during
the
3­
year
period
covered
by
this
ICR.

It
is
estimated
that
the
total
3­
year
burden
for
states
to
implement
the
annual
activities
of
the
Operator
Certification
Guidelines
is
$
59,325
and
1,714
hours.
The
average
annual
burden
is
$
19,775
and
571
hours.
Table
6.7
illustrates
the
total
estimated
burden
and
average
annual
burden
for
the
annual
activities
required
by
the
Guidelines.

Table
6.7:
Annual/
Recurring
Burden/
Costs
to
States
for
Operator
Certification
Guidelines
Activity
Total
Estimated
Burden
Average
Annual
Burden
Hours
Dollars
Hours
Dollars
Submit
material
to
EPA
1,714
$
59,325
571
$
19,775
Total
Annual
Burden
for
States
1,714
$
59,325
571
$
19,775
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
ICR
February
2002
19
Table
6.8
illustrates
the
total
estimated
burden
and
average
annual
burden
for
all
state
activities
required
by
the
Guidelines.

Table
6.8:
Total
Burden/
Costs
to
States
for
Operator
Certification
Guidelines
Activities
Total
Estimated
Burden
Average
Annual
Burden
Hours
Dollars
Hours
Dollars
Initial
Labor
Burden
2,244
$
77,687
748
$
25,896
Annual
Labor
Burden
1,714
$
59,325
571
$
19,775
Total
Burden
for
States
3,958
$
137,012
1,319
$
45,671
Average
Annual
Burden
per
State
26
$
896
Initial/
Start­
up
Burden
to
States
for
Expense
Reimbursement
Grants
Program
°
Submit
material
to
EPA
The
initial
submittal
to
EPA
for
the
Expense
Reimbursement
Grants
Program
will
be
a
grant
application
and
a
description
of
the
state's
intended
uses
for
the
funds.
It
is
estimated
that
it
will
take,
on
average,
7
days
for
a
state
to
complete
this
task.

EPA
estimates
that
the
total
3­
year
burden
for
states
to
conduct
the
information
collection
activities
associated
with
the
Expense
Reimbursement
Grants
Program
is
$
98,874
and
2,856
hours.
The
average
annual
burden
is
$
32,958
and
952
hours.
Table
6.9
illustrates
the
total
estimated
burden
and
average
annual
burden
for
initial
activities
required
by
the
Expense
Reimbursement
Grants
Program.

Table
6.9:
Initial/
Start­
up
Burden/
Costs
to
States
for
Expense
Reimbursement
Program
Activity
Total
Estimated
Burden
Average
Annual
Burden
Hours
Dollars
Hours
Dollars
Submit
material
to
EPA
(
i.
e.,
grant
application)
2,856
$
98,875
952
$
32,958
Total
Initial
Burden
for
States
2,856
$
98,875
952
$
32,958
Average
Annual
Burden
per
State
19
$
646
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
ICR
February
2002
8This
figure
was
obtained
from
the
Office
of
Personnel
Management's
2001
GS
pay
schedule.

20
Annual
State
Burden
for
Expense
Reimbursement
Grants
Program
Table
6.10:
Annual/
Recurring
Burden/
Costs
to
States
for
Expense
Reimbursement
Program
Activity
Total
Estimated
Burden
Average
Annual
Burden
Hours
Dollars
Hours
Dollars
Submit
material
to
EPA
(
i.
e.,
annual
report)
5,100
$
176,562
1700
$
58,854
Total
Initial
Burden
for
States
5,100
$
176,562
1,700
$
58,854
Average
Annual
Burden
per
State
33
$
1,154
Total
State
Burden
for
Expense
Reimbursement
Grants
Program
Table
6.11:
Total
Burden/
Costs
to
States
for
Expense
Reimbursement
Program
Activities
Total
Estimated
Burden
Average
Annual
Burden
Hours
Dollars
Hours
Dollars
Initial
Labor
Burden
2,856
$
98,875
952
$
32,958
Annual
Labor
Burden
5,100
$
176,562
1,700
$
58,854
Total
Burden
for
States
7,956
$
275,437
2,652
$
91,812
Average
Annual
Burden
per
State
52
$
1,800
A.
6.
c
Estimating
Burden
and
Cost
to
EPA
EPA
estimates
that
the
total
burden
and
cost
to
the
Agency
will
be
3,741
hours
and
$
147,545
over
3
years.
A
breakdown
of
this
estimate
is
provided
in
Table
6.12.
Costs
were
calculated
by
dividing
annual
compensation
for
GS­
12,
step
5
personnel,
8
by
2,080
hours
in
the
federal
work
year.
The
hourly
rates
were
then
multiplied
by
the
standard
government
benefits
factor
of
1.6.
All
cost
and
burden
estimates
are
based
on
full
participation
from
the
states.
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
ICR
February
2002
21
Table
6.12:
Total
Burden/
Costs
to
Agency
for
Operator
Certification
Activities
Total
Estimated
Burden
Average
Annual
Burden
Hours
Dollars
Hours
Dollars
Operator
Certification
Guidelines
2,058
$
86,517
686
$
28,839
Expense
Reimbursement
Grants
Program
1,683
$
70,752
561
$
23,584
Total
Agency
Burden
3,741
$
157,269
1,247
$
52,423
Operator
Certification
Guidelines
A
general
discussion
of
EPA's
process
for
the
review
of
state
operator
certification
programs
is
provided
below.
Agency
burden
for
the
Expense
Reimbursement
Grants
program
is
discussed
separately
at
the
end
of
this
section.


Review
and
comment
on
initial
submittal
For
purposes
of
this
estimate,
this
activity
includes:
reviewing
submitted
information,
and
corresponding
with
states.
To
derive
the
estimated
burden
per
state
for
each
program,
the
following
assumptions
were
made:

S
It
is
assumed
that
EPA's
review
time
for
each
program
will
decrease
significantly
after
the
initial
submittal.

S
Because
most
states
will
have
several
questions
for
EPA
as
they
develop
and
implement
their
program,
time
was
included
for
the
Agency
to
address
a
few
questions
per
state.
It
is
assumed
that
the
bulk
of
questions
will
occur
in
the
initial
phases
of
the
program.
A
small
amount
of
time
was
also
factored
in
for
EPA's
questions
as
it
reviews
state
programs.
These
may
be
in
the
form
of
a
quick
phone
call
or
e­
mail,
or
they
may
be
a
longer,
more
formal
request
for
clarification
(
i.
e.,
a
letter
or
memo).
Some
time
was
also
factored
in
for
addressing
questions
and
clarifications.
It
is
assumed
that
this
sort
of
correspondence
with
the
states
will
be
handled
by
the
Regions.

S
Upon
completion
of
the
review
of
the
initial
submittal,
EPA
will
generate
a
response
to
the
state.
In
the
event
of
an
unsatisfactory
program,
EPA
must
prepare
a
detailed
response
that
outlines
each
of
the
identified
deficiencies
in
the
program.
If
the
program
is
deemed
to
be
satisfactory
in
meeting
the
Guidelines,
an
approval
letter
will
be
provided.
However,
it
is
assumed
that
most
Regions
will
respond
to
their
states
either
way.
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
ICR
February
2002
22

Final
review
and
notification
of
withholding
determination
EPA's
involvement
with
many
states
will
be
finished
after
reviewing
and
commenting
on
the
initial
submittal.
However,
some
states
will
be
required
to
address
deficiencies
identified
by
the
Agency
during
its
initial
review,
and
resubmit
their
programs
for
approval.
Because
EPA
will
be
looking
for
very
specific
things
that
it
identified
in
a
previous
review,
it
is
assumed
that
the
average
time
per
state
will
be
a
fraction
of
what
it
was
for
the
full
review
of
the
initial
submittal.
It
is
estimated
that
40
percent
of
states
will
fall
into
this
category
during
the
first
year.
The
estimated
burden
for
this
activity
is
5
hours
per
state.


Annual
program
review
EPA
assumes
that
very
few
states
will
make
changes
to
their
approved
programs
in
a
given
year.
Therefore,
for
the
majority
of
states,
the
annual
review
will
consist
of
reviewing
reports
and
updates
on
program
implementation.
EPA
estimates
that
it
will
take
10
hours
per
state
to
conduct
the
annual
review.

Expense
Reimbursement
Grants
Program
EPA's
activities
under
the
Expense
Reimbursement
Grants
program
will
be
similar
to
those
described
above.
EPA
will
review
the
states'
initial
grant
application
and
annual
reports
that
outline
how
they
will
spend
the
money
allotted
to
them.

°
Review
initial
state
grant
application
It
is
assumed
that
states
will
have
questions
as
they
develop
their
expense
reimbursement
programs,
and
that
EPA
will
have
questions
as
they
review
work
plans.
Therefore,
time
has
been
factored
in
for
both
of
these.
Consistent
with
the
program
reviews,
it
is
assumed
that
all
Regions
will
notify
each
of
their
states
to
confirm
the
results
of
the
review.
It
is
estimated
that
this
activity
will
take,
on
average,
13
hours
per
state
to
complete.

°
Annual
report
review
For
the
annual
review
under
the
expense
reimbursement
grants
program,
EPA
will
verify
that
the
state
is
using
its
money
as
indicated
in
the
previous
report.
EPA
estimates
that
it
will
take
10
hours
per
state
to
review
the
annual
reports.

A.
6.
d
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
universe
of
respondents
for
the
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
program
is
clearly
defined.
In
addition
to
51
state
respondents,
EPA
estimates
that
there
will
be
68,345
respondents
from
CWSs
and
NTNCWSs
for
Operator
Certification
during
the
3­
year
period
of
this
ICR.

National
total
burden
and
cost
estimates
for
Operator
Certification
(
including
Expense
Reimbursement)
are
presented
in
Table
6.13.
The
total
estimated
system
and
state
burden
is
4
hours
per
response
and
the
estimated
total
cost
per
response
is
$
101.
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
ICR
February
2002
23
Table
6.13:
Total
Burden
and
Cost
for
Operator
Certification
Respondent
Number
of
Respondents
Total
Burden
(
hours)
Total
Cost
CWS/
NTNCWS
68,345
290,511
$
6,514,596
State
51
11,914
$
412,449
TOTAL
68,396
302,425
$
6,927,045
Burden
per
Response
(
in
hours)
4
Cost
per
Response
(
not
in
millions)
$
101
A.
6.
e
Reasons
For
Change
In
Burden
This
ICR
does
not
modify
an
existing
ICR.

A.
6.
f
Burden
Statement
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.

Burden
statement:
The
average
reporting
burden
for
a
state
government
that
has
primacy
for
the
Public
Water
System
Supervision
program
is
estimated
to
increased
by
520
hours
(
or
173
hours
annually)
as
a
result
of
Operator
Certification.
The
estimate
includes
time
required
to:


Prepare
initial
and
annual
submittals
to
EPA

Obtain
an
Attorney
General
certification

Submit
expense
reimbursement
grant
application
and
annual
work
plans.

The
reporting
burden
for
a
CWSs
and
NTNCWSs
is
estimated
to
increase
by
4
hours
per
system
over
the
3­
year
period
(
or
by
1
hour
annually).
This
estimate
includes
time
required
to:


Acquire
a
certified
operator
holding
a
valid
certification
equal
to
or
greater
than
the
classification
of
the
system.


Maintain/
renew
operator
certification(
s).
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
ICR
February
2002
24
This
information
collection
is
necessary
to
satisfy
the
mandate
of
§
1419
of
the
Safe
Drinking
Water
Act
as
amended,
which
requires
EPA
to
withhold
a
percentage
of
a
state's
DWSRF
allotment
if
the
state
has
not
developed
and
begun
implementing
an
Operator
Certification
program
that
meets
EPA's
Guidelines
by
February
5,
2001.

Respondents:
Any
state
which
has
primacy
for
the
Public
Water
System
Supervision
program
and
all
CWSs
and
NTNCWSs.

Estimated
Number
of
Respondents:
68,396
(
51
states
and
68,345
public
water
systems).

Frequency
of
Collection:
Annually
for
states;
as
required
for
systems
(
e.
g.,
one­
time,
every
six
months,
annually,
triennially,
every
nine
years)
to
demonstrate
compliance.

Estimated
Total
Annual
Burden
on
Respondents:
100,808
hours
Annual
Reporting
and
Recordkeeping
Burden
Hour
Burden
Cost
Burden
Number
of
responses
68,396
Total
annualized
capital/
startup
costs
$
0
Total
annual
responses
22,799
%
collected
electronically
90
Total
annual
costs
(
O&
M)
$
898,031
Total
hours
requested
302,425
Total
annualized
cost
requested
$
898,031
Current
OMB
inventory
0
Current
OMB
inventory
$
0
Difference
302,425
Difference
$
898,031
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
ICR
February
2002
Appendix
A
Section
1419
of
the
SDWA
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
ICR
THIS
PAGE
WAS
INTENTIONALLY
LEFT
BLANK
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
ICR
February
2002
A
­
1
Operator
Certification
Provisions
in
SDWA
(
§
1419)

Sec.
1419.
(
a)
GUIDELINES.­­
Not
later
than
30
months
after
the
date
of
enactment
of
the
Safe
Drinking
Water
Act
Amendments
of
1996
and
in
cooperation
with
the
States,
the
Administrator
shall
publish
guidelines
in
the
Federal
Register,
after
notice
and
opportunity
for
comment
from
interested
persons,
including
States
and
public
water
systems,
specifying
minimum
standards
for
certification
(
and
recertification)
of
the
operators
of
community
and
nontransient
noncommunity
public
water
systems.
Such
guidelines
shall
take
into
account
existing
State
programs,
the
complexity
of
the
system,
and
other
factors
aimed
at
providing
an
effective
program
at
reasonable
cost
to
States
and
public
water
systems,
taking
into
account
the
size
of
the
system.

(
b)
STATE
PROGRAMS.­­
Beginning
2
years
after
the
date
on
which
the
Administrator
publishes
guidelines
under
subsection
(
a),
the
Administrator
shall
withhold
20
percent
of
the
funds
a
State
is
otherwise
entitled
to
receive
under
section
1452
unless
the
State
has
adopted
and
is
implementing
a
program
for
the
certification
of
operators
of
community
and
nontransient
noncommunity
public
water
systems
that
meets
the
requirements
of
the
guidelines
published
pursuant
to
subsection
(
a)
or
that
has
been
submitted
in
compliance
with
subsection
(
c)
and
that
has
not
been
disapproved.

(
c)
EXISTING
PROGRAMS.­­
For
any
State
exercising
primary
enforcement
responsibility
for
public
water
systems
or
any
other
State
which
has
an
operator
certification
program,
the
guidelines
under
subsection
(
a)
shall
allow
the
State
to
enforce
such
program
in
lieu
of
the
guidelines
under
subsection
(
a)
if
the
State
submits
the
program
to
the
Administrator
within
18
months
after
the
publication
of
the
guidelines
unless
the
Administrator
determines
(
within
9
months
after
the
State
submits
the
program
to
the
Administrator)
that
such
program
is
not
substantially
equivalent
to
such
guidelines.
In
making
this
determination,
an
existing
State
program
shall
be
presumed
to
be
substantially
equivalent
to
the
guidelines,
notwithstanding
program
differences,
based
on
the
size
of
systems
or
the
quality
of
source
water,
providing
the
State
program
meets
the
overall
public
health
objectives
of
the
guidelines.
If
disapproved,
the
program
may
be
resubmitted
within
6
months
after
receipt
of
notice
of
disapproval.

(
d)
EXPENSE
REIMBURSEMENT.­­

(
1)
IN
GENERAL.­­
The
Administrator
shall
provide
reimbursement
for
the
costs
of
training,
including
an
appropriate
per
diem
for
unsalaried
operators,
and
certification
for
persons
operating
systems
serving
3,300
persons
or
fewer
that
are
required
to
undergo
training
pursuant
to
this
section.

(
2)
STATE
GRANTS.­­
The
reimbursement
shall
be
provided
through
grants
to
States
with
each
State
receiving
an
amount
sufficient
to
cover
the
reasonable
costs
for
training
all
such
operators
in
the
State,
as
determined
by
the
Administrator,
to
the
extent
required
by
this
section.
Grants
received
by
a
State
pursuant
to
this
paragraph
shall
first
be
used
to
provide
reimbursement
for
training
and
certification
costs
of
persons
operating
systems
serving
3,300
persons
or
fewer.
If
a
State
has
reimbursed
all
such
costs,
the
State
may,
after
notice
to
the
Administrator,
use
any
remaining
funds
from
the
grant
for
any
of
the
other
purposes
authorized
for
grants
under
section
1452.

(
3)
AUTHORIZATION.­­
There
are
authorized
to
be
appropriated
to
the
Administrator
to
provide
grants
for
reimbursement
under
this
section
$
30,000,000
for
each
of
fiscal
years
1997
through
2003.

(
4)
RESERVATION.­­
If
the
appropriation
made
pursuant
to
paragraph
(
3)
for
any
fiscal
year
is
not
sufficient
to
satisfy
the
requirements
of
paragraph
(
1),
the
Administrator
shall,
prior
to
any
other
allocation
or
reservation,
reserve
such
sums
as
necessary
from
the
funds
appropriated
pursuant
to
section
1452(
m)
to
provide
reimbursement
for
the
training
and
certification
costs
mandated
by
this
subsection.
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
ICR
February
2002
Appendix
B
Burden
and
Cost
Tables
for
States
and
Water
Systems
for
Operator
Certification
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
ICR
February
2002
THIS
PAGE
WAS
INTENTIONALLY
LEFT
BLANK
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
ICR
February
2002
B
­
1
INSERT
TABLES
HERE
Operator
Certification
and
Expense
Reimbursement
Grants
ICR
February
2002
Draft
Appendix
C
Sample
Checklist
&
Crosswalk
for
Operator
Certification
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
ICR
February
2002
Draft
THIS
PAGE
WAS
INTENTIONALLY
LEFT
BLANK
CHECKLIST
&
CROSSWALK
FOR
THE
REVIEW
OF
STATE
OPERATOR
CERTIFICATION
PROGRAMS
State:
_________________

Submission
Date:
_______________

Revised
Program
or
Equivalent
Program
(
circle
one)

Prepared
by:

Name:
______________________________________

Title:
________________________________________

Program
Status:
Draft
or
Final
(
circle
one)
CHECKLIST
&
CROSSWALK
FOR
REVIEW
OF
STATE
OPERATOR
CERTIFICATION
PROGRAMS
STATE:
_____

C
­
4
Baseline
Standard
No.
EPA
Guideline
Circle
one
State
Citation
document
title;

page
#;
§
and
¶
Remarks
[
Explain
here
if
different
than
federal
requirement;
use
separate
sheet,
if
necessary]

I.
Authorization
Does
the
State
have
the
legal
authority
to
implement
an
operator
certification
program
for
its:

S
Community
Water
Systems
(
CWSs)?
Y
N
S
Nontransient
Noncommunity
Water
Systems
(
NTNCWSs)?
Y
N
Does
the
State
have
the
legal
authority
to
require
that
systems
comply
with
the
requirements
of
the
operator
certification
program?
Y
N
Did
the
State
submit
its
Attorney
General
Certification?
Y
N
Has
the
Authorization
been
delegated?
Y
N
If
delegated,
to
whom?______________________________________________

Did
the
State
submit
documentation
of
legal
delegation?
Y
N
Does
the
State's
program
meet
the
baseline
standard
for
Authorization?
Y
N
II.
Classification
of
Systems,
Facilities,
and
Operators
Has
the
State
classified
all
CWSs
based
on
indicators
of
potential
public
health
risk,
which
for
example
may
include:
(
a)

complexity,
size,
source
water
for
treatment
facilities,
and
(
b)

complexity,
size
for
distribution
systems?
Explain
in
remarks.
Y
N
CHECKLIST
&
CROSSWALK
FOR
REVIEW
OF
STATE
OPERATOR
CERTIFICATION
PROGRAMS
STATE:
_____

Baseline
Standard
No.
EPA
Guideline
Circle
one
State
Citation
document
title;

page
#;
§
and
¶
Remarks
[
Explain
here
if
different
than
federal
requirement;
use
separate
sheet,
if
necessary]

C
­
5
Has
the
State
classified
all
NTNCWSs
based
on
indicators
of
potential
public
health
risk,
which
for
example
may
include:
(
a)

complexity,
size,
source
water
for
treatment
facilities,
and
(
b)

complexity,
size
for
distribution
systems?
Explain
in
remarks.
Y
N
Has
the
State
developed
specific
operator
certification
and
renewal
requirements
for
each
classification
level?
Y
N
Does
the
State
require
owners
of
all
CWSs
and
NTNCWSs
to
place
the
direct
supervision
of
their
water
system
(
treatment
and/
or
distribution)
under
the
responsible
charge
of
an
operator
holding
a
valid
certification
equal
to
or
greater
than
the
classification
of
the
treatment
facility
or
distribution
system?
Y
N
Are
operator(
s)
in
responsible
charge
required
to
hold
a
valid
certification
equal
to
or
greater
than
the
classification
of
the
treatment
facility
and/
or
distribution
system?
Y
N
Are
all
operating
personnel
making
process
control/
system
integrity
decisions
about
water
quality
or
quantity
that
affect
public
health
required
to
be
certified?
Y
N
Does
the
State
require
that
a
designated
certified
operator
be
available
for
each
operating
shift?
Y
N
Did
the
State
backslide
with
respect
to
any
of
the
requirements
under
Baseline
Standard
No.
II?
If
yes,
explain
in
remarks.
Y
N
Does
the
State's
program
meet
the
baseline
standard
for
Classification
of
Systems,
Facilities
and
Operators?
Y
N
III.
Operator
Qualifications
Does
the
State
require
applicants
to
pass
an
exam?
Y
N
CHECKLIST
&
CROSSWALK
FOR
REVIEW
OF
STATE
OPERATOR
CERTIFICATION
PROGRAMS
STATE:
_____

Baseline
Standard
No.
EPA
Guideline
Circle
one
State
Citation
document
title;

page
#;
§
and
¶
Remarks
[
Explain
here
if
different
than
federal
requirement;
use
separate
sheet,
if
necessary]

C
­
6
Do
exams
demonstrate
that
the
applicant
has
the
necessary
knowledge,
skills,
ability,
and
judgement
as
appropriate
for
the
classification?
Y
N
Are
all
exams
validated
or
in
the
process
of
being
validated?

Please
give
date
that
the
State
expects
to
have
all
exams
validated.

Date
____________________________
Y
N
By
whom?
_______________________________________________________

Explain
validation
process
in
Remarks
Section
To
become
certified,
does
the
State
require
operators
to
have
a
high
school
diploma
or
GED
or
experience
or
relevant
training
that
may
be
substituted?
Y
N
To
become
certified,
does
the
State
require
operators
to
have
onthe
job
experience
or
have
education
that
may
be
substituted
for
experience
for
each
appropriate
level
of
certification?
Y
N
Is
grandparenting
allowed
by
the
State?
If
yes,
answer
the
following:
Y
N
1.
Does
the
State
restrict
grandparenting
to
existing
operator(
s)
in
responsible
charge
of
existing
systems
which,
because
of
State
law
changes
to
meet
these
guidelines,
must
for
the
first
time
have
a
certified
operator?
Y
N
2.
Is
the
system
owner
required
to
apply
for
grandparenting
within
two
years
of
the
effective
date
of
the
State's
regulation?
Y
N
CHECKLIST
&
CROSSWALK
FOR
REVIEW
OF
STATE
OPERATOR
CERTIFICATION
PROGRAMS
STATE:
_____

Baseline
Standard
No.
EPA
Guideline
Circle
one
State
Citation
document
title;

page
#;
§
and
¶
Remarks
[
Explain
here
if
different
than
federal
requirement;
use
separate
sheet,
if
necessary]

C
­
7
3.
What
is
the
effective
date
of
the
State's
regulation?______________________

4.
Is
grandparenting
site­
specific
to
systems
and
nontransferable
to
other
operators?
Y
N
5.
Are
grandparented
operators
required
to
meet
all
the
requirements
to
meet
certification
renewal
within
some
time
period
specified
by
the
State?
(
Three
years
or
less)
Y
N
6.
Does
a
grandparented
certification
become
invalid
if
the
classification
of
the
plant
or
distribution
facility
for
which
the
operator
was
grandparented
changes
to
a
higher
classification?
Y
N
7.
If
a
grandparented
operator
chooses
to
work
for
a
different
water
system,
then
is
he/
she
required
to
meet
the
initial
certification
requirements
for
that
system?
Y
N
8.
On
what
does
the
State
base
its
grandparenting
decisions
(
e.
g.,
system
compliance
history,
operator
experience
and
knowledge,
system
complexity,
lack
of
treatment).
Explain
in
remarks.

Did
the
State
backslide
with
respect
to
any
of
the
requirements
under
Baseline
Standard
No.
III?
If
yes,
explain
in
remarks.
Y
N
Does
the
State's
program
meet
the
baseline
standard
for
Operator
Qualifications?
Y
N
IV.
Enforcement
CHECKLIST
&
CROSSWALK
FOR
REVIEW
OF
STATE
OPERATOR
CERTIFICATION
PROGRAMS
STATE:
_____

Baseline
Standard
No.
EPA
Guideline
Circle
one
State
Citation
document
title;

page
#;
§
and
¶
Remarks
[
Explain
here
if
different
than
federal
requirement;
use
separate
sheet,
if
necessary]

C
­
8
Does
the
State
primacy
agency
have
regulations
requiring
CWSs
and
NTNCWSs
to
comply
with
State
Operator
Certification
requirements?

Name
of
primacy
agency:
_______________________________
Y
N
In
non­
primacy
States,
has
the
Governor
determined
which
State
agency
shall
enforce
operator
certification
requirements?

Name
of
agency:___________________________________
Y
N
What
specific
enforcement
capabilities
does
the
State
have:

1.
Administrative
Orders?
Y
N
2.
Bilateral
Compliance
Agreements?
Y
N
3.
Civil
Administrative
Penalties?
Y
N
4.
Criminal
Administrative
Penalties?
Y
N
5.
Stipulated
Penalties?
Y
N
6.
Other?
_________________________

Does
the
State
have
appropriate
enforcement
capability?
Y
N
Does
the
State
have
the
authority
to
revoke
an
operator's
certification?
Y
N
Does
the
State
have
the
authority
to
suspend
an
operator's
certification
or
take
other
appropriate
enforcement
action
for
operator
misconduct?
Explain
in
remarks.
Y
N
CHECKLIST
&
CROSSWALK
FOR
REVIEW
OF
STATE
OPERATOR
CERTIFICATION
PROGRAMS
STATE:
_____

Baseline
Standard
No.
EPA
Guideline
Circle
one
State
Citation
document
title;

page
#;
§
and
¶
Remarks
[
Explain
here
if
different
than
federal
requirement;
use
separate
sheet,
if
necessary]

C
­
9
Did
the
State
backslide
with
respect
to
any
of
the
requirements
under
Baseline
Standard
No.
IV?
If
yes,
explain
in
remarks.
Y
N
Does
the
State's
program
meet
the
baseline
standard
for
Enforcement?
Y
N
V.
Certification
Renewal
Has
the
State
established
training
requirements
for
renewal
based
on
the
level
of
certification
held
by
operator?
Y
N
Does
the
State
require
all
operators
including
grandparented
operators
to
acquire
necessary
amounts
and
types
of
State
approved
training?
Y
N
Does
the
State
have
a
fixed
cycle
of
renewal
not
exceeding
3
years?
How
long?
_______________________________
Y
N
Does
the
State
require
individuals
to
recertify
if
the
individual
fails
to
renew
or
qualify
for
renewal
within
two
years
of
the
date
that
the
certificate
expired?
Y
N
Does
the
State
identify
specific
renewal
requirements
for
grandparented
operators
to
ensure
that
they
possess
the
knowledge,
skills,
ability
and
judgement
to
properly
operate
the
system?
Y
N
Identify
which
one
or
more
of
the
following
approaches
the
State
uses:

1.
The
State
specifies
renewal
requirements
for
grandparented
operators
on
a
case­
by­
case
basis,
taking
into
consideration
system
compliance
history
and
operator
experience
and
knowledge.
Y
N
CHECKLIST
&
CROSSWALK
FOR
REVIEW
OF
STATE
OPERATOR
CERTIFICATION
PROGRAMS
STATE:
_____

Baseline
Standard
No.
EPA
Guideline
Circle
one
State
Citation
document
title;

page
#;
§
and
¶
Remarks
[
Explain
here
if
different
than
federal
requirement;
use
separate
sheet,
if
necessary]

C
­
10
2.
The
State
requires
specific
training
requirements
for
certification
renewal
at
the
first
renewal
cycle
for
grandparented
operators
including
all
of
the
information
covered
by
the
initial
certification
exam
for
the
system
classification
level
for
which
the
operator
was
grandparented.
Y
N
3.
The
State
requires
operators
with
grandparented
certificates
to
meet
all
of
the
initial
certification
requirements
for
the
classification
level
for
which
the
operator
was
grandparented,
and
thereby
obtain
certification
within
a
reasonable
time
period
specified
by
the
State.
List
the
time
period
Y
N
4.
Does
the
State
use
another
approach
to
ensure
grandparented
operators
possess
the
knowledge,
skills,

ability
and
judgement
to
properly
operate
the
system?

If
yes,
describe.
Y
N
Did
the
State
backslide
with
respect
to
any
of
the
requirements
under
Baseline
Standard
No.
V?
If
yes,
explain
in
remarks.
Y
N
Does
the
State's
program
meet
the
baseline
standard
for
Certification
Renewal?
Y
N
VI.
Resources
Needed
to
Implement
the
Program
Does
the
State
provide
sufficient
resources
to
adequately
fund
and
sustain
its
operator
certification
program
that
must
include
the
following
components:
staff,
data
management,
testing,

enforcement,
administration,
and
training
approval?
Y
N
Does
the
State
have
a
dedicated
fund
that
is
self­
sufficient?
Y
N
CHECKLIST
&
CROSSWALK
FOR
REVIEW
OF
STATE
OPERATOR
CERTIFICATION
PROGRAMS
STATE:
_____

Baseline
Standard
No.
EPA
Guideline
Circle
one
State
Citation
document
title;

page
#;
§
and
¶
Remarks
[
Explain
here
if
different
than
federal
requirement;
use
separate
sheet,
if
necessary]

C
­
11
Did
the
State
backslide
with
respect
to
any
of
the
requirements
under
Baseline
Standard
No.
VI?
If
yes,
explain
in
remarks.
Y
N
Does
the
State's
program
meet
the
baseline
standard
for
Resources
Needed
to
Implement
the
Program?
Y
N
VII.
Recertification
Does
the
State's
program
have
a
process
for
the
recertification
of
operators
whose
certification
has
expired
for
a
period
exceeding
two
years?
Y
N
Does
the
recertification
process
include:

1.
Review
of
the
individual's
experience
and
training?
Y
N
2.
Re­
examination?
Y
N
Does
the
State
have
more
stringent
requirements
for
recertification
of
individuals
whose
certificates
have
expired,

been
revoked,
or
been
suspended?
If
yes,
explain
in
remarks.
Y
N
Did
the
State
backslide
with
respect
to
any
of
the
requirements
under
Baseline
Standard
No.
VII?
If
yes,
explain
in
remarks.
Y
N
Does
the
State's
program
meet
the
baseline
standard
for
Recertification?
Y
N
VIII.
Stakeholder
Involvement
Does
the
State
include
ongoing
stakeholder
involvement
in
the
revision
and
operations
of
its
operator
certification
program?
Y
N
CHECKLIST
&
CROSSWALK
FOR
REVIEW
OF
STATE
OPERATOR
CERTIFICATION
PROGRAMS
STATE:
_____

Baseline
Standard
No.
EPA
Guideline
Circle
one
State
Citation
document
title;

page
#;
§
and
¶
Remarks
[
Explain
here
if
different
than
federal
requirement;
use
separate
sheet,
if
necessary]

C
­
12
Describe
the
State's
stakeholder
involvement
process:

Does
the
State
have
a
stakeholder
board
or
advisory
committee
?
Y
N
Did
the
State
backslide
with
respect
to
any
of
the
requirements
under
Baseline
Standard
No.
VIII?
If
yes,
explain
in
remarks.
Y
N
Does
the
State's
program
meet
the
baseline
standard
for
Stakeholder
Involvement?
Y
N
IX.
Program
Review
Does
the
State
have
a
process
for
reviewing
its
own
program?

Explain
in
remarks.
Y
N
Does
the
State's
process
include
periodic
internal
reviews?

Identify
time
frame
for
review
and
plan
for
review
in
Remarks
section
Y
N
Does
the
State's
process
include
occasional
external/
peer
reviews?
Identify
time
frame
for
review
and
plan
for
review
in
Remarks
section
Y
N
Does
the
State's
program
review
process
include
review
of:

1.
Regulations?
Y
N
2.
Exam
items
for
relevancy
and
validity?
Y
N
3.
Compliance?
Y
N
4.
Enforcement?
Y
N
CHECKLIST
&
CROSSWALK
FOR
REVIEW
OF
STATE
OPERATOR
CERTIFICATION
PROGRAMS
STATE:
_____

Baseline
Standard
No.
EPA
Guideline
Circle
one
State
Citation
document
title;

page
#;
§
and
¶
Remarks
[
Explain
here
if
different
than
federal
requirement;
use
separate
sheet,
if
necessary]

C
­
13
5.
Budget
and
staffing?
Y
N
6.
Training
relevancy?
Y
N
7.
Training
needs
through
exam
performance?
Y
N
8.
Data
management
system?
Y
N
Did
the
State
backslide
with
respect
to
any
of
the
requirements
under
Baseline
Standard
No.
IX?
If
yes,
explain
in
remarks.
Y
N
Does
the
State's
program
meet
the
baseline
standard
for
Program
Review?
Y
N
Initial
Submittal
Contents
Has
the
State
submitted
the
following:

1.
Attorney
General's
certification?
Y
N
2.
Documentation
of
the
delegation
of
authority,
if
AG
statement
is
signed
by
delegated
counsel?
Y
N
3.
A
full
description
and
explanation
of
how
its
operator
certification
program
complies
with
or
is
substantially
equivalent
to
the
requirements
of
these
guidelines?
Y
N
4.
Copy
of
its
operator
certification
statutes
and
regulations?
Y
N
5.
Description
of
the
basis
for
classification
of
treatment
and
/
or
distribution
facilities?
Y
N
6.
Description
of
certification
requirements
for
each
classification
level?
Y
N
CHECKLIST
&
CROSSWALK
FOR
REVIEW
OF
STATE
OPERATOR
CERTIFICATION
PROGRAMS
STATE:
_____

Baseline
Standard
No.
EPA
Guideline
Circle
one
State
Citation
document
title;

page
#;
§
and
¶
Remarks
[
Explain
here
if
different
than
federal
requirement;
use
separate
sheet,
if
necessary]

C
­
14
7.
Description
of
the
renewal
requirements
for
each
classification
level?
Y
N
8.
Description
of
special
renewal
requirements
for
grandparented
operators?
Y
N
9.
Documentation
of
exam
validation
for
all
classification
levels?
Y
N.

10.
Plan
for
tracking
compliance
and
enforcement?
Y
N
11.
Plan
for
enforcing
its
operator
certification
program?
Y
N
12.
Description
of
program
resources?
Y
N
13.
Description
of
internal
program
review
procedures?
Y
N
14.
Description
of
external
program
review
procedures?
Y
N
15.
Plan
for
stakeholder
involvement?
Y
N
16.
Implementation
schedule?
Y
N
Operator
Certification
and
Expense
Reimbursement
Grants
ICR
February
2002
Appendix
D
Working
Group
Membership
List
Operator
Certification
and
Expense
Reimbursement
Grants
ICR
February
2002
THIS
PAGE
WAS
INTENTIONALLY
LEFT
BLANK
Operator
Certification
and
Expense
Reimbursement
Grants
ICR
February
2002
D
­
1
NATIONAL
DRINKING
WATER
ADVISORY
COUNCIL
OPERATOR
CERTIFICATION
WORKING
GROUP
Designated
Federal
Officer
Rick
Naylor
EPA/
OGWDW
(
4606)
401
M
Street
SW
Washington,
D.
C.
20460
National
Drinking
Water
Advisory
Council
Members
assigned
to
Working
Group
James
Cleland
Drinking
Water
and
Radiological
Protection
Division
Michigan
Dept.
Of
Environmental
Quality,
P.
O.
Box
30630
Lansing,
Michigan
48909­
8130
Nina
McClelland,
Ph.
D.
Nina
I.
McClelland,
LLC
P.
O.
Box
3703
Ann
Arbor,
Michigan
48106­
3703
John
Scheltens
City
of
Hot
Springs
303
North
River
Street
Hot
Springs,
South
Dakota
57747
Working
Group
Members
Kenneth
W.
Bauman
Consumers
Pennsylvania
Water
Company
Shenango
Valley
Division
P.
O.
Box
572
Sharon,
Pennsylvania
16146
Cheryl
L.
Bergener
Water
Works
Operation
Certification
Pgrm.
Department
of
Health
P.
O.
Box
47829
Olympia,
Washington
98504­
7822
Bill
Carpenter
Tennessee
Association
of
Utility
Districts
P.
O.
Box
2529
Murfreesboro,
Tennessee
37133­
2529
Brian
Cohen
Environmental
Working
Group
1718
Connecticut
Ave.,
NW,
Suite
600
Washington,
D.
C.
20009
Operator
Certification
and
Expense
Reimbursement
Grants
ICR
February
2002
D
­
2
Tom
Crawford
Native
American
Water
Association
P.
O.
Box
511
Minden,
Nevada
89432
Kevin
Christmas
Fayetteville
Water
Department
P.
O.
Draw
1089
Fayetteville,
North
Carolina
28302
Lisa
B.
Detherage
Division
of
Water
Water
Operator
Certification
Section
14
Riley
Road
Frankfort,
Kentucky
40601
Cindy
Finan
President
Association
Boards
of
Certification
102
Parkwise
Court
Apex,
North
Carolina
27502
Jerry
Higgins
Blacksburg
Christiansburg
VPI
Water
Authority
P.
O.
Box
10006
Blacksburg,
Virginia
24062­
0006
Denise
Kruger
Quality
Assurance
Manager
630
East
Foothill
Boulevard
San
Dimas,
California
91773
Gary
Morgan
Rural
Utilities
Services
U.
S.
Department
of
Agriculture
South
Building
14th
&
Independence
Ave.,
SW
Washington,
D.
C.
20250
Herbert
Pratt
Community
Resource
Group
2100
West
Prien
Lake
Road
Lake
Charles,
Louisiana
70605
Robert
W.
Rivard
Connecticut
Department
of
Public
Health
Water
Supplies
Division
450
Capitol
Avenue
­
MS#
51­
WAT
P.
O.
Box
340308
Hartford,
Connecticut
06134­
0308
Daniel
Rosenberg
Steering
Committee
for
Safe
and
Drinking
Water
U.
S.
Public
Interest
Research
Group
218
D
Street
SE
Washington,
D.
C.
20003
John
Sadzewicz
Ohio
Environmental
Protection
Division
of
Drinking/
Groundwaters
P.
O.
Box
1049
Columbus,
Ohio
43266­
1049
Judy
Sass
Midwest
Assistance
Program
P.
O.
Box
516
Florence,
Montana
59833
Harold
Seifert
Arkansas
Department
of
Health
Division
of
Engineering
4815
West
Markham
Street,
MS#
37
Little
Rock,
Arkansas
72205­
3867
Wayne
Wruble
Indian
Health
Service
5300
Homestead
Road
NE
Albuquerque,
New
Mexico
87110
Operator
Certification
and
Expense
Reimbursement
Grants
ICR
February
2002
Appendix
E
Response
to
Comments
THIS
PAGE
WAS
INTENTIONALLY
LEFT
BLANK
Operator
Certification
and
Expense
Reimbursement
Grants
ICR
February
2002
E
­
2
Response
to
Comments
 
EPA
ICR
#
1955.01
This
document
provides
EPA's
response
to
comments
received
from
one
commenter
on
the
proposed
Information
Collection
Request
(
ICR)
for
the
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
Program
(
EPA
ICR#
1955.01).
Notice
of
a
30­
day
comment
period
on
the
ICR
was
published
in
the
Federal
Register
on
February
28,
2001
(
66
FR
12776).
EPA's
response
to
each
comment
is
provided
in
bold.
Comments
are
provided
in
their
entirety.

We
have
reviewed
the
Information
Collection
Request
(
ICR)
for
the
Operator
Certification
Guidelines
and
Expense
Reimbursement
Grants
Program
as
detailed
in
the
February
28'
Federal
Register
notice.
We
generally
agree
with
the
methodology
used
to
develop
the
costs
in
the
ICR
Supporting
Statement,
however,
we
question
many
of
the
assumptions
used
in
the
Supporting
Statement­
These
assumptions
may
or
may
not
be
correct,
and
there
is
no
way
to
evaluate
them,
as
no
references
are
given.
For
example,
at
the
bottom
of
page
13,
EPA
assumes
that
50%
of
small
systems
and
90%
of
large/
medium
systems
already
have
a
certified
operator.
Surely
some
documentation
on
this
assumption
exists
somewhere,
possibly
in
EPA's
Community
Water
Supply
System
(
CWSS)
Survey
(
based
on
how
many
systems
have
treatment)
or
from
the
Association
of
Boards
of
Certification
(
ABC).
A
similar
assumption
on
the
bottom,
on
page
14
assumes
that
13
%
of
small
systems
and
3
%
of
medium/
large
systems
will
train
and
certify
an
existing
operator
isn't
backed
up
with
any
documentation.
Throughout
the
Supporting
Statement,
assumptions
on
specific
impacts
to
water
systems
are
made
without
any
backup
documentation.

The
examples
that
the
commentor
references
were
derived
based
on
the
Information
for
States
on
Recommended
Operator
Certification
Requirements
(
EPA
816­
R­
98­
001),
on
discussions
with
states
that
attended
the
Spring
1999
Operator
Certification
Implementation
Workshops,
and
on
EPA's
review
of
draft
operator
certification
programs
submitted
by
states.
EPA
has
added
clarification
to
this
section
to
address
the
commentor's
concern.

Additionally,
This
Supporting
Statement
doesn't
take
into
account
that
systems
will
have
to
train
and
certify
their
operators
to
a
higher
classification
due
to
the
installation
of
additional
treatment
to
meet
upcoming
regulations.
For
example,
approximately
3,000
groundwater
systems
will
have
to
install
treatment
to
comply
with
the
arsenic
regulation.
Each
of
these
groundwater
systems
will
go
from,
simple
disinfection
(
or
no
treatment
at
all)
to
extremely
complex
treatment
such
as
ion
exchange,
activated
alumina,
or
coagulation/
microfiltration.
The
increased
need
for
operators
with
increasingly
higher
level
of
certifications
becomes
clear
when
ALL
of
the
regulations
(
arsenic,
radon,
radionuclides,
groundwater
rule,
Stage
2
Disinfectants/
Disinfection
ByProducts,
Long­
Term
1
Enhanced
Surface
Water
Treatment
Rule,
Long­
Term
2
Enhanced
Surface
Water
Treatment
Rule)
axe
compounded,
EPA
needs
to
account
for
this
operator
certification
"
creep"
when
developing
the
final
costs
for
the
operator
certification
expense
reimbursement
grants
program.
AWWA.
recommends
that
EPA
work
closely
with
the
State
primacy
agencies
to
develop
the
cost
impacts
from
the
increased
levels
of
operator
certification
resulting
from
the
upcoming
regulations
and
the
potential
lack
of
certified
operators
available
to
meet
these
increased
needs.
Operator
Certification
and
Expense
Reimbursement
Grants
ICR
February
2002
E
­
3
The
Agency
wishes
to
clarify
that
this
ICR
is
for
paperwork
burden
only.
The
type
of
burden
that
the
commentor
describes
would
be
captured
by
an
Economic
Assessment,
which
is
not
required
for
the
Guidelines
or
the
Expense
Reimbursement
Grants
Program.
The
Economic
Assessments
for
each
of
the
rules
that
the
commentor
mentions
should
capture
the
burden
associated
with
new
requirements.
Furthermore,
given
the
variations
between
state
classification
systems,
EPA
believes
that
it
would
be
impractical
to
try
to
assess
how
operator
certification
levels
could
change
as
a
result
of
future
regulations,
many
of
which
will
not
be
effective
until
after
this
information
collection
expires.

The
burden
tables
for
this
ICR
could
have
used
some
text
to
explain
how
the
spreadsheets
were
developed.
It
took
a
while
to
figure
out
where
the
numbers
in
the
spreadsheets
came
from.

EPA
has
added
some
clarification
by
re­
titling
the
tables.
