Information Collection Request for the National Primary Drinking Water
Regulations: Final Ground Water Rule



	

Office of Water (4606-M)     EPA 815-R-06-011     October 2006    
www.epa.gov/safewater

TABLE OF CONTENTS

 TOC \f 1	Identification of the Information Collection	  PAGEREF
_Toc147934652 \h  1 

1a	Title of the Information Collection	  PAGEREF _Toc147934653 \h  1 

1b	Short Characterization	  PAGEREF _Toc147934654 \h  1 

2	Need for and Use of the Collection	  PAGEREF _Toc147934655 \h  4 

2a	Need/Authority for the Collection	  PAGEREF _Toc147934656 \h  4 

2b	Practical Utility/Users of the Data	  PAGEREF _Toc147934657 \h  4 

3	Nonduplication, Consultations, and Other Collection Criteria	  PAGEREF
_Toc147934658 \h  7 

3a	Nonduplication	  PAGEREF _Toc147934659 \h  7 

3b	Public Notice Required Prior to ICR Submission to OMB	  PAGEREF
_Toc147934660 \h  7 

3c	Consultations	  PAGEREF _Toc147934661 \h  7 

3d	Effects of Less Frequent Collection	  PAGEREF _Toc147934662 \h  9 

3e	General Guidelines	  PAGEREF _Toc147934663 \h  10 

3f	Confidentiality and Sensitive Questions	  PAGEREF _Toc147934664 \h 
10 

4	The Respondents and the Information Requested	  PAGEREF _Toc147934665
\h  11 

4a	Respondent NAICS/SIC Codes	  PAGEREF _Toc147934666 \h  11 

4b	Information Requested	  PAGEREF _Toc147934667 \h  11 

4b(i)	Data Items	  PAGEREF _Toc147934668 \h  11 

4b(ii)	Respondent Activities	  PAGEREF _Toc147934669 \h  14 

4b(ii)a State Activities	  PAGEREF _Toc147934670 \h  14 

4b(ii)b Public Water System Activities	  PAGEREF _Toc147934671 \h  15 

4c	ICR Approval Activities	  PAGEREF _Toc147934672 \h  18 

5	The Information Collection Activities, Collection Methodology, and
Information Management	  PAGEREF _Toc147934673 \h  21 

5a	Agency Activities	  PAGEREF _Toc147934674 \h  21 

5b	Collection Methodology and Management	  PAGEREF _Toc147934675 \h  21 

5c	Small Entity Flexibility	  PAGEREF _Toc147934676 \h  22 

5c(i)	Small Business Advocacy Review Panel Recommendations	  PAGEREF
_Toc147934677 \h  22 

5c(i)a	First Recommendation: Focus on Greatest Risk	  PAGEREF
_Toc147934678 \h  22 

5c(i)b	Second Recommendation: Use Total Coliform Testing over 

Viral Testing	  PAGEREF _Toc147934679 \h  23 

5c(i)c	Third Recommendation: Use Existing Source Water 

Assessments	  PAGEREF _Toc147934680 \h  24 

5c(i)d	Fourth Recommendation: Develop Compliance Requirements 

by System Size	  PAGEREF _Toc147934681 \h  24 

5d	Collection Schedule	  PAGEREF _Toc147934682 \h  24 

6	Estimating the Burden and Cost of the Collection	  PAGEREF
_Toc147934683 \h  25 

6a	Estimating Respondent Burden and Cost	  PAGEREF _Toc147934684 \h  25 

6a(i)	Burden and Cost to PWSs	  PAGEREF _Toc147934685 \h  25 

6a(i)a	Start-Up Activities	  PAGEREF _Toc147934686 \h  26 

6a(i)b	Annual Activities	  PAGEREF _Toc147934687 \h  26 

6a(ii)    Burden and Cost to States	  PAGEREF _Toc147934688 \h  26 

6a(ii)a	Start-Up Activities	  PAGEREF _Toc147934689 \h  26 

6a(ii)b Annual Activities	  PAGEREF _Toc147934690 \h  27 

6b	Time Frame for Cost and Burden Estimates	  PAGEREF _Toc147934691 \h 
27 

6c	Estimating Agency Burden and Cost	  PAGEREF _Toc147934692 \h  28 

6d	Respondent Universe	  PAGEREF _Toc147934693 \h  28 

6e	Bottom Line Burden Hours and Costs	  PAGEREF _Toc147934694 \h  28 

6e(i)	Bottom Line Burden and Cost Estimates for Respondents	  PAGEREF
_Toc147934695 \h  29 

6e(ii)    Bottom Line Estimate for Agency	  PAGEREF _Toc147934696 \h  30


6f	Reasons for Change in Burden	  PAGEREF _Toc147934697 \h  30 

6g	Burden Statement	  PAGEREF _Toc147934698 \h  30 

 

LIST OF EXHIBITS

Figure 4.1  Implementation Schedule	20

Figure 6.1  Average Annual Burden per Response and per Respondent and
Average Annual    

                   Responses per Respondent	25

Figure 6.2  Bottom Line Average Annual Burden and Costs	29

APPENDICES

Appendix A:	 Detailed Burden and Cost Tables

ACRONYM LIST

ASDWA	Association of State Drinking Water Administrators

BLS		Bureau of Labor Statistics

BMP		Best Management Practice

CWS		Community Water System

DBPR		Disinfection Byproducts Rule

EA		Economic Analysis

ECI		Employment Cost Index

EIM		Early Involvement Meeting

EPA		Environmental Protection Agency

FILS		Federal Information Locator System

FOIA		Freedom of Information Act

FTE		Full Time Equivalent

GWR		Ground Water Rule

GWUDI	Ground Water Under the Direct Influence of Surface Water

HSA		Hydrogeologic Sensitivity Assessment

ICR		Information Collection Rule

MCL		Maximum Contaminant Level

NAICS		North American Industry Classification System

NCWS		Noncommunity Water System

NPDWR	National Primary Drinking Water Regulations

OGWDW	Office of Ground Water and Drinking Water

O&M		Operation and Maintenance

OMB		Office of Management and Budget

PRA		Paperwork Reduction Act

PWS		Public Water Systems

PWSS		Public Water System Supervision

RCRA		Resource Conservation and Recovery Act

SBAR		Small Business Advocacy Review

SBREFA	Small Business Regulatory Enforcement Fairness Act

SDWA		Safe Drinking Water Act

SDWIS	Safe Drinking Water Information System

SIC		Standard Industrial Classification

SCO		Standard Occupational Classification

SWAP		Source Water Assessment Program

TCR		Total Coliform Rule

1	Identification of the Information Collection tc \l1 "1	Identification
of the Information Collection 

1a	Title of the Information Collection tc \l2 "1a	Title of the
Information Collection 

TITLE:	National Primary Drinking Water Regulations: Ground Water Rule
(Final Rule)

U.S. EPA ICR NUMBER: 1934.03.

Note: The description of reporting and recordkeeping burden in this
supporting statement covers all that is required for the full rule
implementation, which exceeds the 3-year approval period for the
Information Collection Request (ICR).  For the purposes of the ICR
approval period, the 3-year costs and burden are described in section 6,
with supporting tables for both the 3-year ICR period and the 10-year
full implementation period provided in Appendix A.

1b	Short Characterization tc \l2 "1b	Short Characterization 

The Ground Water Rule (GWR) requires information collection regarding
the integrity of public ground water systems, the effectiveness of
treatment where disinfection or other microbial control treatment is
practiced, and the sensitivity to and presence of microbial
contamination where microbial control treatment is not practiced.  The
public ground water systems included in this information collection are
drinking water systems with sources beneath the surface of the ground,
serving 25 or more people, with more than 15 service connections, and
which operate for atleast 60 days per year.  However, this ICR does not
include public ground water systems with only ground water under the
direct influence of surface water (GWUDI) as a source (40 CFR (141.2). 
The GWR establishes standards for evaluating the risk of microbial
contamination of ground water systems and standards for minimizing those
risks.  The regulatory initiatives discussed in this document are
intended to protect public health and welfare from microbial
contaminants.

Several distinct types of data are being collected under the GWR,
including sanitary survey data, compliance monitoring data, and
microbial monitoring data.  The most extensive data collection effort
involves performing sanitary surveys of all public water systems (PWSs)
covered by this rule.  The GWR requires States, or their authorized
agents, to conduct sanitary surveys of all ground water systems and
provide a summary to the Environmental Protection Agency (EPA or the
Agency) of the systems for which the sanitary surveys have been
completed.  Ground water systems will be required to provide any
pertinent, existing information to the States, or authorized agents, to
prepare the sanitary survey.  The States, or authorized agents, must
conduct sanitary surveys of community water systems (CWSs) once every 3
years and of noncommunity water systems (NCWSs) once every 5 years. 
However, those CWSs that provide 4-log treatment of viruses (using
inactivation, removal, or State-approved combination of these
technologies) before or at the first customer, or have an outstanding
performance record (i.e., no significant deficiencies) and no history of
total coliform maximum contaminant level (MCL) or monitoring violations
under the Total Coliform Rule (TCR) may undergo sanitary surveys every 5
years. EPA estimates that surveys for all PWSs currently average once
every 5 years.  Exceptions to this frequency are NCWSs that may be on a
10 year schedule because they are not subject to the sanitary survey
requirements under TCR.  For those PWSs required to perform more
frequent surveys under the GWR, additional full surveys will be
required.  Other PWSs will only incur additional (incremental) burden if
they do not currently perform all eight elements of a sanitary survey
(see section 4b(ii)b for a description of these elements).

The second type of data collection applies to public ground water
systems that practice disinfection treatment.  These systems are
required to monitor the performance of their treatment systems and
notify the State any time they do not comply with the disinfection
treatment technique.  

The third type of data collection applies to public ground water systems
that do not practice disinfection treatment.  These systems may be
required to monitor their source water through triggered monitoring and,
if the state determines it is necessary, assessment monitoring.  All
undisinfected systems must perform triggered monitoring any time a Total
Coliform Rule (TCR) routine monitoring sample tests positive for total
coliform.  Also, the State may direct  undisinfected systems to perform
assessment monitoring upon any source.  Systems must notify the State
any time a source water sample (triggered or assessment) tests positive
for the presence of a fecal indicator.  

Monitoring, reporting, and recordkeeping are required at both system and
State levels under the National Primary Drinking Water Regulations
(NPDWRs) (40 CFR 141.402, 40 CFR 141.403, 40 CFR 141.404, 40 CFR
141.405, 40 CFR 142.14, 40 CFR 142.15).  All affected PWSs shall
maintain and report to the State information documenting compliance with
the treatment and monitoring requirements under the NPDWRs.  States
shall maintain records essential for program implementation and
oversight.  These records, retained in the Safe Drinking Water
Information System (SDWIS), allow EPA to track PWS compliance with
NPDWRs.

Data collected under the Safe Drinking Water Act (SDWA) are used by the
Agency(s Office of Ground Water and Drinking Water (OGWDW), and other
EPA programs such as Superfund and Resource Conservation and Recovery
Act (RCRA).  The data may also be used by the Farmers Home
Administration, the Department of the Interior, the Department of
Housing and Urban Development, the U.S. Army Corps of Engineers, White
House Task forces, the Federal Emergency Management Agency, the Food and
Drug Administration, public interest groups, and many private companies
and individuals.

For the 3-year ICR period, the average annual respondent burden and cost
to systems and States is estimated at 385,264 hours and $10,091,422. 
The annual burden and cost to PWSs is estimated at 260,244 hours and
$5,890,508.  The estimated annual State burden for this ICR is 125,020
hours, at an estimated annual cost of $4,200,914.  All costs estimated
are labor costs.  There are no operation and maintenance (O&M) or
capital costs for the 3-year period covered by this ICR. 

The total number of respondents for this ICR is 147,387; 147,330
respondents are systems and 57 respondents are States and territories. 
The average annual number of responses for PWSs is 98,220 and averages
2.0 responses per respondent annually.  The average annual number of
responses for States is 57 and averages 1.0 response per respondent
annually.

This ICR has been completed in accordance with the April 2005 version of
EPA(s Guide to Writing Information Collection Requests Under the
Paperwork Reduction Act (PRA) of 1995 (hereafter, the (ICR Handbook(). 
The ICR Handbook was prepared by EPA(s Office of Environmental
Information, Office of Information Collection, Collection Strategies
Division.  The ICR Handbook provides the most current instructions for
ICR preparation to ensure compliance with the 1995 Paperwork Reduction
Act (PRA) Amendments and the Office of Management and Budget(s (OMB)
implementing guidelines.

2	Need for and Use of the Collection tc \l1 "2	Need for and Use of the
Collection 

The following sections describe the need for this information collection
and the legal authority under which this information will be collected.

2a	Need/Authority for the Collection tc \l2 "2a	Need/Authority for the
Collection 

The United States Environmental Protection Agency (EPA or Agency) is
promulgating the Ground Water Rule (GWR) to address microbial
contamination of ground water-supplied drinking water systems in
accordance with the Safe Drinking Water Act (SDWA) of 1974, as amended
in 1986 and again in 1996.  The 1986 SDWA Amendments directed EPA to
establish National Primary Drinking Water Regulations (NPDWRs) requiring
disinfection for the inactivation of microbiological contaminants for
all public water systems (PWSs), including systems supplied by ground
water sources.  The 1996 Amendments included more specific language
regarding ground water disinfection, specifying that the Administrator
must publish NPDWRs requiring disinfection as a treatment technique for
all ground water PWSs only (as necessary.( 

The information collected under this rule is required by EPA to carry
out its monitoring and enforcement responsibilities under the SDWA. 
Without comprehensive, up-to-date information on drinking water
contamination, the Agency would not be able to meet the SDWA statutory
requirements.

2b	Practical Utility/Users of the Data tc \l2 "2b	Practical
Utility/Users of the Data 

Each PWS maintains system-level records on the analytical results of
monitoring actions and of the reports or written communications
regarding sanitary surveys (40 CFR 141.33).  Public ground water systems
will also be required to maintain records of correspondence with the
State regarding monitoring and corrective actions for microbial
contamination and significant deficiencies (40 CFR 141.405).  PWSs will
use the data to:

(	Determine system-specific needs;

(	Ensure the removal targets for viruses are met;

(	Monitor their source water quality in accordance with State
requirements;

(	Correct significant deficiencies;

(	Respond to the presence of fecal indicators in their source water; and

(	Alert the public through notices in the mass media or water bills
when the systems are not in compliance with Federal and State
regulations.

States will maintain records compiled from PWS respondents (40 CFR
142.14).  States can use these records to track PWS monitoring,
compliance violations, and enforcement activities.  States can also
track schedules for PWSs trying to achieve compliance. States will
report the number of violations, which will help them target systems for
compliance and take the necessary remedial action.

States will report information on PWS violations to SDWIS.  This Federal
information system allows EPA and States to store and retrieve
information over time.  Trends in compliance data can be evaluated at
the system level, at the State level, and at the national program level.
Usually, these data are used by the Agency for maintaining oversight and
to support Federal enforcement actions in cases where States fail to
enforce.

The States and EPA have a number of critical questions to answer as part
of their supervision of PWSs.  Some of these are listed below.

At the system level:

(	Does a PWS have a significant deficiency which requires correction?

(	Does a PWS have fecal contamination of its source water which requires
corrective action?

(	For systems not in compliance, why are they not in compliance and how
can compliance be achieved?

(	What is the threat to public health for a system that is not in
compliance?

At the national and State level:

(	What are the national and State compliance trends?

(	What changes in national policy or regulation may be needed to
increase the national compliance rate?

(	Is noncompliance a function of location, size, or other identifiable
variable?

Requests for PWS data and related statistical analyses are frequent. 
The SDWIS often receives requests under the Freedom of Information Act
(FOIA).  Approximately 200 FOIA requests are received per year.  EPA
also maintains an Internet access point for SDWIS data at their
(Envirofacts( Internet site.  Since October 1998, there have been
approximately 150,000 instances of accessing the SDWIS data.3
Nonduplication, Consultations, and Other Collection Criteria tc \l1 "3
Nonduplication, Consultations, and Other Collection Criteria 

The following sections verify and affirm that this ICR satisfies the
Paperwork Reduction Act (PRA) requirements, meets the Office of
Management and Budget (OMB) data-collection guidelines, has public
support, and does not duplicate another collection.

3a	Nonduplication tc \l2 "3a	Nonduplication 

EPA has searched the Federal Information Locator System (FILS) in an
effort to ensure nonduplication of the data collection efforts.  To the
best of the Agency(s knowledge, data currently required by this rule are
not available from any other source.

The information collected under the GWR is needed to determine a
system’s risk of microbial contamination and to evaluate the
system’s compliance.  The information to be collected is not available
from other sources.  There are two instances in which potential
duplication of information have been avoided under this rule.  The first
instance is in the performance of sanitary surveys.  Many States
currently perform sanitary surveys in accordance with the TCR (40 CFR
141.21).  To avoid duplication with this sanitary survey requirement,
EPA has proposed that the sanitary surveys under the GWR would meet the
TCR requirements.  

3b	Public Notice Required Prior to ICR Submission to OMB tc \l2 "3b
Public Notice Required Prior to ICR Submission to OMB 

Agencies developing rule-related ICRs must solicit public comments for a
60-day period prior to submitting the request to OMB.  A notice for
public comment was included in the Federal Register preamble for the
proposed GWR.  Based on public comment received on the proposed rule,
modifications were made to the rule and underlying analyses prior to
promulgation of the final rule.  Where appropriate, these modifications
are also reflected in this ICR.  For a full discussion of public
comments on the proposed GWR, as well as EPA(s responses, see the Public
Comment and Response Document for the Final Ground Water Rule (U.S. EPA,
2006).

3c	Consultations tc \l2 "3c	Consultations 

EPA held a preliminary GWR meeting on December 18 and 19, 1997, in
Washington, DC, for the purpose of engaging all interested stakeholders
in the analysis of data to support the GWR.  The two-day meeting covered
discussions on the implications of the data, solicited further data from
stakeholders, and reviewed EPA(s next steps for rule development, data
analysis, and stakeholder involvement.

Since December 1997, EPA has held GWR stakeholder meetings in Portland,
OR, Madison, WI, Dallas, TX, Lincoln, NE, and Washington, DC, along with
three early involvement meetings with State representatives.  In
addition, EPA has received valuable input from small system operators as
part of an Agency outreach initiative under the Small Business
Regulatory Enforcement Fairness Act (SBREFA).  Finally, as part of the
rule finalization process, EPA convened a workgroup of State and Region
representatives to evaluate final regulatory requirements.  Taken
together, these stakeholder meetings and other consultations have been
crucial, both in obtaining feedback and getting additional information,
as well as in guiding the Agency(s consideration and development of
different regulatory components.  A more detailed discussion of several
of these efforts follows.

Portland, Oregon, GWR Stakeholder Meeting

There were four different regulatory approaches presented in the first
of a series of stakeholder meetings held in Portland, Oregon, in May
1998: the Barrier Assessment Approach, the Existing State Practices
Approach, the Setback Approach, and the Checklist Approach (Stakeholder
Meetings Summary, Resolve, July 27, 1998).  All approaches address, to
varying degrees, three main areas: minimum program requirements or
baseline measures, identification of high risk wells, and corrective
action.  Discussions on the potential approaches centered around what
triggers should place a well in a high priority category and which
minimum set of best management practices (BMPs) should be implemented at
high risk wells. 

Madison, Wisconsin, GWR Stakeholder Meeting

There were three approaches presented in a June 9, 1998, GWR stakeholder
meeting held in Madison, Wisconsin: Status Quo Approach, Baseline
Approach, and Disinfection Approach.  Regulatory approaches were revised
in response to stakeholder input from the earlier GWR stakeholder
meetings on a continuum from Status Quo to mandatory disinfection for
all ground water systems.  EPA emphasized that existing occurrence data
do not appear to support mandatory across-the-board disinfection, but
that they would still appreciate stakeholder input on a range of
options.  The approaches presented were based on monitoring,
inspections, best management practices (BMPs), and disinfection.

Dallas, Texas, GWR Stakeholder Meeting

A third GWR meeting on June 25, 1998, in Dallas, Texas, provided slight
modifications to the regulatory approaches, but for the most part
remained unchanged from the Madison meeting held in early June.  EPA
continued to emphasize the need to identify and strengthen the potential
barriers to contamination.  Among the three approaches (Status Quo,
Progressive, and Universal Disinfection), the Progressive approach was
considered the more viable regulatory option to ensure public health
protection among PWSs.

Early Involvement Meetings

The Association of State Drinking Water Administrators (ASDWA) held
three early involvement meetings (EIMs) on the GWR.  The first EIM
followed the May 5, 1998, stakeholder meeting in Portland, Oregon.  The
second EIM meeting was held in Washington, DC on July 14 and 15, 1998,
and the third meeting was held in Chicago, Illinois, on April 7 and 8,
1999.  Representatives from 12 States, four EPA Regions, ASDWA, and EPA
Headquarters participated in the May 6 and 7, 1998 meeting in Portland,
Oregon.  The second EIM involved ten State representatives, ASDWA, and
EPA Headquarters.  The third EIM included one EPA Region, seven State
representatives, ASDWA, and EPA Headquarters.  The purpose of the
meetings was to review the findings and comments from the stakeholder
meetings and to work together to further refine GWR regulatory options. 
EPA and States discussed a range of issues including risk, exposure,
strategies for identifying high risk systems, occurrence data, and
regulatory implementation barriers.

Review and Comment of Preliminary Draft GWR Preamble

EPA developed a preliminary draft preamble reflecting a wide range of
input from numerous stakeholders across the country.  To facilitate the
rule development process, the preliminary draft preamble was made
available to the public via the Internet through EPA(s website on
February 3, 1999.  Approximately 300 copies were also mailed to
participants of the public meetings or to those who requested a copy. 
EPA welcomed any comments, suggestions, or concerns reviewers had on
either the general direction or the technical basis of the proposal. 
EPA closed the email box on February 23, 1999, and continued to receive
written comments via regular mail through March 17, 1999.  Seventy-nine
individual comments were received.  Commentors included State and Local
government representatives, trade associations, academic institutions,
businesses, and other Federal agencies.  Because this was an informal
process, EPA did not prepare a formal response to the comments. 
Nonetheless, the Agency carefully reviewed and evaluated all comments
and technical suggestions.

3d	Effects of Less Frequent Collection tc \l2 "3d	Effects of Less
Frequent Collection 

EPA has determined that less frequent data collection may fail to
identify, in a timely manner, significant contaminant concentrations
that may threaten the health and safety of drinking water consumers. 
EPA has considered alternatives for a wide range of frequency and burden
estimates for data collection.  It has selected the approach that
requires the least frequent collection possible while maintaining its
public health protection objectives.

3e	General Guidelines tc \l2 "3e	General Guidelines 

The GWR complies with the guidelines (5 CFR 1320. 5(d)(2)) implemented
under the PRA, with one possible exception: records of analyses need to
be maintained for a period of at least ten years.  The GWR does not
alter the record maintenance requirements that are found in 40 CFR
141.33; that section stipulates that records of chemical analyses shall
be kept for not less than ten years, and records of actions taken by a
system to correct violations of primary drinking water regulations shall
be kept for a period of not less than 3 years.

3f	Confidentiality and Sensitive Questions tc \l2 "3f	Confidentiality
and Sensitive Questions 

The data collection proposed does not raise confidentiality issues or
ask any sensitive questions concerning sexual behavior or attitudes,
religious beliefs, or other matters.  

4	The Respondents and the Information Requested tc \l1 "4	The
Respondents and the Information Requested 

The following sections provide information on the respondents and the
information they are requested to provide.

4a	Respondent NAICS/SIC Codes tc \l2 "4a	Respondent NAICS/SIC Codes 

Under this rule, respondents to the monitoring, reporting, and
recordkeeping requirements include the operators and owners of public
ground water systems, which include NCWSs.  The North American Industry
Classification System (NAICS) Code for investor-owned water systems is
22131; the Standard Industrial Classification (SIC) Code is 4941.  The
NAICS Code for both publicly owned water systems and State agencies is
92411 and the SIC Code is 9511.  State officials serve in a role of
respondent when reporting compliance data to EPA.

PWSs are defined as those systems that provide piped water for human
consumption and have at least 15 service connections or regularly serve
at least 25 people at least 60 days per year. A CWS is a PWS that serves
at least 15 connections used by year-round residents or regularly serves
at least 25 year-round residents.  NCWSs, by definition, are all other
PWSs.  NCWSs include transient systems and nontransient systems. 
Nontransient systems serve the same 25 people at least 6 months per year
(40 CFR 141.2). 

4b	Information Requested tc \l2 "4b	Information Requested 

The following sections provide details on data items requested and
associated activities respondents will be required to undertake to
provide this information.

4b(i)	Data Items tc \l3 "4b(i)	Data Items 

EPA is adding several requirements to State recordkeeping as contained
in 40 CFR 142.14.  Currently, EPA requires that States maintain a
current inventory of PWSs and the following items for each PWS in the
State:

Records of tests, measurements, analyses, and decisions performed on
each water system to determine compliance with existing regulations;

(	Reports of sanitary surveys;

(	Records of any State approvals;

(	Records of any enforcement action;



(	A record of the most recent vulnerability determination;

(	A record of all current monitoring requirements and the most recent
monitoring frequency decision pertaining to the contaminant; and

(	Records pertaining to each variance and exemption granted.

For records kept by the States, the additional requirements include (40
CFR 142.14)(d)(17):

Records of written notices of significant deficiencies;

Records of corrective action plans, schedule approvals, and
State-specified interim measures;

Records of confirmations that a significant deficiency has been
corrected or the fecal contamination in the ground water source has been
addressed;

Records of State determinations and records of ground water system’s
documentation for not conducting triggered source water monitoring;

Records of invalidations of fecal indicator-positive ground water source
samples;

Records of State approvals of source water monitoring plans;

Records of notices of the minimum residual disinfections concentration
(when using chemical disinfection) needed to achieve at least 4-log
virus inactivation before or at the first customer;

Records of notices of the State-specified monitoring and compliance
requirements (when using membrane filtration or alternative treatment)
needed to achieve at least 4-log treatment of viruses (using
inactivation, removal, or a State-approved combination of 4-log
inactivation and removal) before or at the first customer;

Records of written notices from the ground water system that it provides
at least 4-log treatment of viruses (using inactivation, removal, or a
State-approved combination of 4-log virus inactivation and removal)
before or at the first customer for each ground water source; and

Records of written determinations that the ground water system may
discontinue 4-log treatment of viruses (using inactivation, removal, or
a State-approved combination of 4-log inactivation and removal).

Additionally, the State must report the following (40 CFR 142.15):

The month and year in which the most recent sanitary survey was
completed or, for a State that used a phased review process, the date
the last element of the applicable eight elements was evaluated for each
ground water system;

The date the system completed the corrective action; and

All ground water systems providing at least 4-log treatment of viruses
(using inactivation, removal, or a State-approved combination of 4-log
virus inactivation and removal) before or at the first customer for any
ground water source(s).

For records kept by PWSs the additional requirements include (40 CFR
141.405)(b):



Documentation of corrective actions shall be kept for a period of not
less than 10 years;

Documentation of notice to the public shall be kept for a period of not
less than 3 years;

Documentation of records of decisions and records of invalidation of
fecal indicator-positive ground water source samples shall be kept for a
period of not less than 5 years;

For consecutive systems, documentation of notification to the wholesale
system(s) of total-coliform positive samples that are not invalidated
shall be kept for a period of not less than 5 years; and

For systems, including wholesale systems, that are required to perform
compliance monitoring, the following additional requirements include:

records of the State-specified minimum disinfectant residual shall be
kept for a period of not less than 10 years;

records of the lowest daily residual disinfectant concentration and
records of the date and duration of any failure to maintain the
State-prescribed minimum residual disinfectant concentration for a
period of more than 4 hours shall be kept for a period of not less than
5 years; and

records of State-specified compliance requirements of membrane
filtration and of parameters specified by the State for State-approved
alternative treatment and records of the date and duration of any
failure to meet the membrane operating, membrane integrity, or
alternative treatment operating requirements for more than 4 hours shall
be kept for period of not less than 5 years. 

Additionally the PWSs must report the following additional information
(40 CFR 141.405)(a):

A PWS conducting compliance monitoring must notify the State any time
the system fails to meet any State-specified requirements including, but
not limited to, minimum residual disinfectant concentration, membrane
operating criteria or membrane integrity, and alternative treatment
operating criteria, if operation in accordance with the criteria or
requirements is not restored within 4 hours.  The PWS must notify the
State as soon as possible, but in not case later than the end of the
next business day;

After completing any corrective action, a PWS must notify the State
within 30 days of completion of the corrective action; and

If a PWS subject to source water monitoring requirements does not
conduct source water monitoring, the system must provide documentation
to the State within 30 days of the total coliform positive sample that
it met the State criteria.

4b(ii)	Respondent Activities tc \l3 "4b(ii)	Respondent Activities 

As mentioned above, respondents include both PWSs and State officials. 
Their information collection activities are described below.

4b(ii)a State Activities tc \l4 "4b(ii)a State Activities 

State officials serve in the role of respondents when reporting
compliance data to EPA. States are required to maintain records of State
verification activities and each determination made and to report to EPA
in accordance with State reporting requirements (40 CFR 142.15) through
the SDWIS.

States with primacy will act as the Agency in ensuring the
implementation of the GWR (40 CFR 142.16).  To meet their
responsibilities successfully, States are anticipated to be involved in
the following activities:

(	Reading and understanding the rule;

(	Mobilizing (including primacy application), planning, and
implementing;

(	Training PWS and consultant staff;

(	Compliance tracking;

(	Analyzing and reviewing PWS data;

(	Making determinations concerning PWS monitoring requirements;

(	Recordkeeping;

(	Conducting sanitary surveys; and 

(	Consulting with PWSs on corrective actions for significant
deficiencies and fecally contaminated source water.

4b(ii)b Public Water System Activities tc \l4 "4b(ii)b Public Water
System Activities 

In general, each PWS will be involved in the following collection
activities:

(	Reading the rule;

(	Planning and training activities, as required by the rule;

(	Gathering information (e.g., source water monitoring);

(	Processing, compiling, and reviewing the information collected;

(	Submitting reports and other documents;

(	Developing and distributing public notices when violations occur; and

(	Recording and maintaining the information.

These activities are needed to complete information collection
requirements under this rule that include monitoring, reporting, and
recordkeeping requirements, as described below.

Sanitary Surveys

A sanitary survey is an onsite review, conducted by the State or
authorized agent, of eight elements of a PWS that evaluates the adequacy
of the source for the production and distribution of safe drinking water
(40 CFR 142.16).  The survey evaluates the following:

(	Water source;

(	Treatment;

(	Distribution system;

(	Finished water storage;

(	Pumps, pump facilities, and controls;

(	Monitoring and reporting data verification;

(	System management and operation; and,

(	Operator compliance with State requirements.

Under the sanitary survey provision of the GWR, CWSs and NCWSs will
undergo sanitary surveys once every 3 and 5 years, respectively, to
address these eight specific components of a PWS.  Those CWSs that
provide 4-log treatment of viruses (using inactivation, removal, or
State-approved combination of these technologies) before or at the first
customer, or have an outstanding performance record (i.e., no
significant deficiencies) and no history of total coliform maximum
contaminant level (MCL) or monitoring violations under the Total
Coliform Rule (TCR) may undergo sanitary surveys every 5 years. EPA
estimates that surveys for all PWSs currently average once every 5
years.  Exceptions to this frequency are NCWSs that may be on a 10 year
schedule because they are not subject to the sanitary survey
requirements under TCR.  For those PWSs required to perform more
frequent surveys under the GWR, additional full surveys will be
required.  Other PWSs will only incur additional (incremental) burden if
they do not currently perform all eight elements of a sanitary survey,
as described above.

For those systems that have notified the State that they provide 4-log
inactivation or removal of viruses in accordance with 40 CFR 141.403,
the State or its authorized agent performing the sanitary survey must
confirm that the system meets the State(s requirements for 4-log
inactivation or removal of viruses.

States must identify and describe any significant deficiencies found in
ground water systems during a sanitary survey.  States must define, in
their primacy application, what constitutes a significant deficiency.  A
significant deficiency includes, but is not limited to, a defect in
design, operation, or maintenance or a failure or malfunction of the
sources, treatment, storage, or distribution system that the State
determines to be causing or has the potential to cause the introduction
of contamination into the water delivered to consumers.

Source Water Monitoring

Ground water systems that do not provide disinfection treatment or
provide treatment which does not achieve 4-log inactivation or removal
of viruses are subject to triggered source water monitoring. 
Nondisinfected and less than 4-log ground water systems that have a
total coliform-positive sample under 40 CFR 141.21(a) must perform
triggered monitoring of their source water in addition to the repeat
monitoring already required by 40 CFR 141.21(b).  Under triggered
monitoring requirements (40 CFR 141.402 ) a system must collect at least
one source water sample and have that sample tested for a fecal
indicator (E. coli, enterococci, or coliphage) specified by the State. 
If a system detects the State-specified fecal indicator at its source,
then the system must take five additional samples within 24 hours unless
the State determines that corrective action must be taken immediately. 
If any of the additional samples is positive, the system must implement
a corrective action.  Corrective actions fall into four categories:
fixing the deficiency leading to contamination, eliminating the source
of the contamination, obtaining a new uncontaminated source, or
installing treatment to reliably achieve 4-log treatment of viruses
(using inactivation, removal, or State-approved combination of these
technologies) before or at the first customer.

	States may require certain systems that do not practice disinfection or
achieve 4-log inactivation or removal of viruses to perform assessment
monitoring.  These systems must collect source water samples as directed
by the State and test the sample for one of three fecal indicators  (E.
coli, enterococci or coliphage) selected by the State. 

Compliance Monitoring

Disinfecting systems must be monitored and maintained to ensure that
they provide reliable removal or inactivation of viruses and other
microorganisms that may be in the source water.  Systems engage in
compliance monitoring of disinfection treatment in place prior to
promulgation of the GWR as well as technology installed as a result of
corrective action required by the GWR.  EPA assumed that systems already
employing chemical disinfection treatment for purposes other than
compliance with the GWR, or prior to the Rule(s promulgation, would
already have the monitoring program and monitoring equipment in place to
monitor the disinfection.  Systems that adopt treatment as a corrective
action for source water contamination must also install monitoring
equipment to perform compliance monitoring.  The monitoring requirements
vary depending upon the disinfection treatment technology.  Systems that
use chemical disinfection will be required to monitor the residual
disinfectant concentration, continuously for systems serving greater
than 3,300 people, and once every day for systems serving 3,300 people
or fewer.  Systems that use membrane filtration will be required to
operate the system in accordance with State-specified criteria and to
ensure that the membrane is intact. Systems that use a State-approved
alternative treatment must monitor the alternative treatment in
accordance with any State-specified monitoring requirements.  

Primacy Requirements

To adopt the GWR States will be required to submit an application for
approval of their State program to implement the rule.  The application
must be submitted to EPA for approval and must address or demonstrate
the following:

That the State regulations are no less stringent than the Federal
requirements;

That the State has authority in statute or regulation to ensure the that
PWSs:

conduct source water monitoring, 

take the appropriate corrective actions including interim measures, if
necessary, needed to address significant deficiencies,

take the appropriate corrective actions including interim measures, if
necessary, needed to address any source water fecal contamination
identified during source water monitoring, and 

Consult with the State regarding corrective actions.

How the State will implement a sanitary survey program that meets the
rule requirements;

That the State has appropriate rules or other authority to require PWSs
to address fecal contamination of their source waters;

How the State will determine the minimum disinfection treatment
requirements to achieve 4-log inactivation or removal of viruses in
systems that disinfect;

The monitoring, compliance and membrane integrity testing requirements
the State will require to demonstrate virus removal for PWSs using
membrane filtration technologies; and

The criteria, including public health-based considerations and
incorporating on-site investigations and source water monitoring
results, the State will use to determine if a PWS may discontinue 4-log
treatment of viruses (including inactivation, removal, or a
State-approved combination of inactivation and removal) before or at the
first customer.

4c	ICR Approval Activities tc \l2 "4c	ICR Approval Activities 

Many of the required regulatory monitoring, reporting, and recordkeeping
activities described above will occur outside the 3-year ICR approval
period.  This section clarifies the activities that will be included in
the ICR burden and cost estimates covering the first 3 years after rule
promulgation.  Figure 4.1 shows the schedule for information collection
and other compliance activities under the GWR.  The only activities that
take place during the 3-year ICR approval period are State primacy
application and start-up activities.

No public notification burden is expected within the first 3 years after
promulgation of the rule (i.e., the period of this ICR).  Public
notification burden is expected for: 1) systems that have not addressed
significant deficiencies; 2) systems that have not addressed source
water contamination; 3) systems which do not maintain 4-log
disinfection; and 4) systems with fecal coliform indicator positive that
are not required to do corrective action. 

EPA anticipates that, during the ICR reporting period, States will
perform start-up activities including:

(	Regulation adoption;

(	Program development;

(	Data management system modifications;

(	Initial laboratory certification and training;

(	Staff training; and

(	System training and technical assistance.



PWSs are expected to perform start-up activities during the first 3
years after promulgation of the rule.  These start-up activities
include:

(	Reading and understanding the rule;

(	Preparing, planning, and mobilizating; and

(	Training for system operators.

Figure 4.1  Implementation Schedule



5	The Information Collection Activities, Collection Methodology, and
Information Management tc \l1 "5	The Information Collection Activities,
Collection Methodology, and Information Management 

The following sections describe the Agency activities related to
analyzing, maintaining, and distributing the information collected.

5a	Agency Activities tc \l2 "5a	Agency Activities 

The Agency will be responsible for promulgating this rule and overseeing
its implementation.  Implementation of monitoring requirements will rely
extensively on State governments in those States that have assumed
primacy under section 1413 of the SDWA and 40 CFR 142.16 of the GWR. 
The Agency will be involved in the following activities:

(	Developing this rule and guidance materials;

(	Reviewing and analyzing data submissions from the States; and

(	Processing and maintaining the SDWIS.

These are all general activities that are covered under the Public Water
Systems Supervision (PWSS) Program ICR; this ICR, therefore, does not
include estimates for EPA burden and costs.

5b	Collection Methodology and Management tc \l2 "5b	Collection
Methodology and Management 

SDWIS will receive records from the States of violations and whether the
system had a sanitary survey.  EPA will modify SDWIS and data
verification procedures to accommodate the new information from the
rule.

EPA will check data quality by doing the following:

(	Developing standard operating procedures for each rule;

(	Editing the data submitted for content and required format in SDWIS;

(	Sending rejected data back to the States for error corrections;

(	Requiring States to resubmit corrected data;

(	Data verification audit of States based on data verification protocol
established by EPA; and 

(	Conducting a review of States annually for corrective actions.



EPA plans to modify its existing data verification process to:

(	Include the number of systems with discrepancies;

(	Include onsite verification in States and water systems, if necessary,
every 2 to 3 years;

(	Train States on data verification procedures so they can conduct
self-audits;

(	Include timeliness reviews;

(	Incorporate GWR-related activities into EPA Regional quarterly/annual
reviews; and

(	Include a regional check with States within six months of the previous
data verification.

SDWIS runs on an IBM ES9000 12 way processor using mainframe edit
programs (in JCL).  EPA defines information requirements and States
update the data in batch file mode in a pre-defined format.  The public
may access the violations data in SDWIS through on the Internet at
www.epa.gov/enviro/html/sdwis/sdwisquery.html.

5c	Small Entity Flexibility tc \l2 "5c	Small Entity Flexibility 

The GWR will primarily impact small systems.  Under the Regulatory
Flexibility Act, 5 U.S.C. 601 et seq. (RFA), as amended by SBREFA, EPA
generally is required to conduct a regulatory flexibility analysis that
describes the impact of a regulatory action on small entities.  To
assess this impact, the Agency convened a Small Business Advocacy Review
(SBAR) Panel.  The recommendations of the panel, with respect to
recordkeeping and reporting requirements, are summarized below, as are
the provisions of the GWR that address these recommendations.

5c(i)	Small Business Advocacy Review Panel Recommendations tc \l3 "5c(i)
Small Business Advocacy Review Panel Recommendations 

5c(i)a	First Recommendation: Focus on Greatest Risk tc \l4 "5c(i)a	First
Recommendation: Focus on Greatest Risk 

Because small systems frequently have minimal staff and resources,
including data on the underlying hydrogeology of the system, the SBAR
Panel recommended that EPA focus the recordkeeping, reporting, and
compliance requirements on those systems at greatest risk of fecal
contamination.  The Panel also recommended that EPA consider tailoring
the requirements based on system size (e.g., smaller systems would not
have to monitor as frequently or perform sanitary surveys on the same
schedule).

Agency Response

The GWR is a risk-targeted regulatory approach.  The monitoring
requirements are based on system characteristics and are not directly
related to system size.  The only across-the-board requirement is for
sanitary surveys, but the implementation schedule is staggered (e.g.,
every 3 or 5 years for CWSs, and every 5 years for NCWSs), which should
provide some relief for small systems.  Because many small systems may
not have easy access to the records that would ideally be available for
a sanitary survey, EPA, after consulting with stakeholders and the SBAR
Panel, has determined that it will not use the lack of adequate well
records, the lack of a cross-connection program, or intermittent
pressure fluctuations as automatic triggers to indicate risk of
potential contamination.  These factors may be considered along with
others that more definitively demonstrate risk.

5c(i)b	Second Recommendation: Use Total Coliform Testing over Viral
Testing tc \l4 "5c(i)b	Second Recommendation: Use Total Coliform Testing
over Viral Testing 

With respect to the potential cost of additional monitoring for small
systems, particularly if the rule requires viral monitoring, the SBAR
Panel offered several recommendations.  First, the Panel suggested that,
to the extent possible, the GWR should build on the existing monitoring
framework in the TCR.  Given the low cost of the total coliform test,
the Panel noted that an increase in the frequency and the locations for
TCR monitoring or additional samples in the source water if the system
has a total coliform-positive sample would be preferable given the
current cost of a viral test.  However, the Panel also recommended that
the EPA continue to develop a less costly, more accurate test to
identify viral and bacterial contamination in drinking water.

Agency Response

The GWR does build on the existing TCR monitoring framework by using the
results of the routine TCR monitoring to determine if triggered source
water monitoring is required.  In the GWR, a system is required to test
for the presence of E.coli, coliphage, or enterococci in the source
water within 24 hours of a routine total coliform-positive sample in the
distribution system.  The State has the option of requiring systems to
conduct the additional assessment monitoring on a case-by-case basis,
but only if they do not already treat their water to 4-log inactivation
or removal of viruses.  In accordance with the TCR, systems that take
only one routine sample per month must collect no fewer than four repeat
samples for each TC-positive sample found.  Systems that choose to
collect the fourth sample at the ground water source may use it to
comply with the triggered monitoring requirement.  In both cases,
however, if the system has an E.coli, coliphage, or fecal
coliform-positive sample, the system is required to conduct the
necessary follow-up actions.

5c(i)c	Third Recommendation: Use Existing Source Water Assessments tc
\l4 "5c(i)c	Third Recommendation: Use Existing Source Water Assessments 

Hydrogeologic sensitivity assessments (HSAs) are no longer required. 
Therefore, the recommendation to use existing source water assessments
no longer applies to the GWR. 

5c(i)d	Fourth Recommendation: Develop Compliance Requirements by System
Size tc \l4 "5c(i)d	Fourth Recommendation: Develop Compliance
Requirements by System Size 

The SBAR Panel suggested that compliance requirements be tailored to the
system size.  In particular, if the minimum monitoring frequency and the
frequency for sanitary surveys for the smallest systems (e.g., those
serving fewer than 500 people) could be reduced, it would reduce both
the resources necessary to comply with the rule and recordkeeping
required by the system.  

Agency Response

EPA has structured the GWR as a risk-targeted approach to reducing fecal
contamination.  The only across-the-board requirement is for sanitary
surveys.  The required frequency for CWSs is every 3 years which may be
changed by the State to every 5 years if the system either treats to
4-log inactivation or removal of virus or has an outstanding performance
record documented in previous inspections and has no history of total
coliform MCL or monitoring violations since the last sanitary survey
under current ownership.  The required frequency for sanitary surveys is
every 5 years for NCWSs.  Since the majority of the small systems are
NCWSs, the majority of systems will only have a sanitary survey every 5
years.  At this frequency, EPA believes that the requirements will not
be burdensome for even the smallest systems.  Similarly, the only
additional monitoring requirements in the rule are for systems that have
a total coliform-positive sample in the distribution system, which would
be an infrequent event.  States also have the option of requiring
certain sensitive systems that achieve less than 4-log inactivation or
removal of viruses to conduct assessment monitoring.  This monitoring
would be on a State-defined schedule.    

5d	Collection Schedule tc \l2 "5d	Collection Schedule 

This rule is scheduled to be promulgated in October 2006, with
compliance monitoring beginning December 2009.  Figure 4.1 illustrates
the information collection periods for compliance with the GWR over the
first 11 years following rule promulgation.

6	Estimating the Burden and Cost of the Collection tc \l1 "6	Estimating
the Burden and Cost of the Collection 

The following sections discuss costs and burden for all information
collection, recordkeeping, and reporting requirements for the GWR.

6a	Estimating Respondent Burden and Cost tc \l2 "6a	Estimating
Respondent Burden and Cost 

The following sections discuss the costs and burden faced by PWSs and
States.  Note that the majority of the monitoring, recordkeeping, and
reporting burden occurs beyond the 3-year period of the ICR. Exhibits
A.12 through A.15, located in Appendix A, include a full ten-year time
frame showing the costs and burden beyond the initial period covered by
the ICR.  This reflects the reality of full rule implementation.  Figure
6.1 presents a summary of estimated responses, burden, and costs for the
3-year window of the ICR.

Figure 6.1

Average Annual Burden per Response and per Respondent and

Average Annual Responses per Respondent

	

Responses	

Burden Hours1	

Labor Costs 	

O&M Costs	

Capital Costs	

Total Annual Costs



PWSs	

98,220	

260,244	

$5,890,508	

$0	

$0	

$5,890,508



States & Territories	

57	

125,020	

$4,200,914	

$0	

$0	

$4,200,914



Total	

98,277	

385,264	

$10,091,422	

$0	

$0	

$10,091,422

Notes:  Detail may not add exactly to total due to independent rounding.

1 Hours reflect an annual average for all system sizes over the 3-year
ICR period.

6a(i)	Burden and Cost to PWSs tc \l3 "6a(i)	Burden and Cost to PWSs 

Information collection activities of PWSs required under this rule will
result in average annual national labor costs of $5.9 million and a
corresponding annual burden of 260,244 person-hours as shown in Figure
6.1 and in Exhibits A.12 through A.15.  The exhibits also include annual
costs and burden up to 10 years following rule promulgation.

The burden and costs are estimated for start-up activities, including
reading the rule and training staff.  The assumptions and methodologies
used in deriving these estimates are discussed in the following section.

6a(i)a	Start-Up Activities tc \l4 "6a(i)a	Start-Up Activities 

Start-up activities are estimated at a one-time expense of $12.6 million
and 375,060 burden hours (Exhibits A.14 and A.15).  Start-up activities
include reading the final rule to become familiar with the requirements
and training staff to perform the required activities.

For costing purposes, EPA estimates the labor needs and hourly labor
rates of systems and States for two labor categories: managerial and
technical.  For PWSs, all analyses use labor rates presented in EPA(s
document, Labor Costs for National Drinking Water Rules.  The technical
and managerial wage rates vary with system size and include fringe
benefits.  The technical wage rates (2003$) are as follows:  $21.44 for
systems serving 25-100 people, $23.09 for systems serving 101-500
people, $24.74 for systems serving 500-3,300 people, $25.34 for systems
serving 3,301-10,000 people, $26.05 for systems serving 10,001-100,000
people, and $31.26 for systems serving greater than 100,000 people. 
Exhibit A.1 displays these technical wage rates.  The managerial wage
rates (2003$) are as follows: $44.36 for systems serving 25-100 people,
$47.78 for systems serving 101-500 people, and $51.20 for systems
serving greater than 500 people.

To account for the composition of staff at PWSs of varying sizes, EPA
uses only the technical rate for systems serving fewer than 3,300
people.  For systems serving 3,300 or more people, EPA uses a ratio of
80 percent technical labor to 20 percent managerial labor to arrive at a
weighted labor rate of $30.51 for systems serving 3,301-10,000 people,
$31.08 for systems serving 10,001-100,000 people, and $35.25 for systems
serving greater than 100,000 people.

6a(i)b	Annual Activities tc \l4 "6a(i)b	Annual Activities 

In the tenth year of rule implementation, total annual activity costs
and burden for PWSs are estimated to be $20.8 million and 0.7 million
burden hours, respectively.  Included in this category are costs and
burden for sanitary surveys, triggered monitoring, sample invalidation
and resampling, and compliance monitoring.  The cost and burden
estimates for PWS annual activities are shown in Exhibits A.14 and A.15.
 These costs are for data collection and review and will occur outside
of the 3-year ICR window.

6a(ii)	Burden and Cost to States tc \l3 "6a(ii)	Burden and Cost to
States 

Total annual average State labor cost is $4.2 million, and the annual
average burden is 125,020 hours for the ICR approval period.

6a(ii)a	Start-Up Activities tc \l4 "6a(ii)a	Start-Up Activities 

States are estimated to incur a one-time cost of $12.6 million and a
one-time burden of 375,060 hours.  Three labor cost estimates exist for
States.  In the first, labor costs attributable to States are estimated
based on an average annual full time equivalent (FTE) labor cost,
including overhead, of $65,255 (2001).  This rate was established based
on data from the 2001 State Drinking Water Needs Analysis.  For use in
GWR analyses, the $62,255 annual rate was updated to a year 2003 price
level ($69,897) and converted to an hourly basis (1 FTE = 2,080 hours)
to establish a State rate of $33.60 per hour.  For sanitary surveys and
corrective action plan review, the year 1998 wage rate of $31.00 for a
field engineer is used.  This rate comes from R.S. Means (1998) and
include a 60 percent loading factor to account for the cost of fringe
benefits.  The wage rate is updated to 2003 dollars, resulting in a
field engineer rate of $37.34 per hour. 

6a(ii)b Annual Activities tc \l4 "6a(ii)b Annual Activities 

In the tenth year after promulgation, the States are expected to spend a
total of 0.4 million burden hours annually performing sanitary surveys,
consulting with systems, and reviewing monitoring data submitted to the
State (Exhibit A.14).

Total annual activity costs are estimated to be $15.1 million when the
rule is in full implementation (Exhibit A.19).  State costs and burden
for monitoring are calculated in the same way as State start-up costs
for the various activities.  The labor rate derived from the State
Drinking Water Needs Analysis $33.60 is used for report review and
consultation activities.  The labor rate for a field engineer $37.34 is
used for sanitary surveys and for significant deficiency, system
modification, and corrective action plan review and approval.  State
activities primarily consist of performing sanitary surveys and
consulting with PWSs.  States must also submit information to SDWIS to
assist both EPA and States in tracking PWS compliance.

6b	Time Frame for Cost and Burden Estimates tc \l2 "6b	Time Frame for
Cost and Burden Estimates 

To provide a coherent understanding of how the burden for the rule will
occur, the time frame for full rule implementation is described below.

In the first 3 years, EPA has estimated that States will adopt
regulations for implementation of the GWR and will apply for program
primacy approval, and that States and PWSs will conduct start-up
activities for implementing the GWR, such as training, data management
system modifications, and laboratory modifications.  

Beginning in the fourth year following promulgation, States will perform
sanitary surveys of CWSs every 3 years and of NCWSs every 5 years.  EPA
has assumed that one-fifth of the CWSs that achieve 4-log inactivation
or removal of viruses will be surveyed each year.  The Agency also
assumed that States will survey one-half of the CWSs that do not achieve
4-log inactivation or removal on a 3 year schedule and one-half on a 5
year schedule.  One-fifth of the NCWSs will be surveyed each year.

Additionally, EPA expects that, beginning in the fourth year, PWSs
found to have significant deficiencies or found to have source waters
with fecal contamination will be required to consult with the State
regarding corrective actions and to notify the State once the corrective
actions are complete.

6c	Estimating Agency Burden and Cost tc \l2 "6c	Estimating Agency Burden
and Cost 

EPA(s costs include those incurred by both regional offices and
headquarters to process, analyze, and maintain SDWIS.  These costs
cannot be derived by rule but are presented as an overall program cost
in the Public Water System Supervision (PWSS) Program ICR.  Headquarters
personnel who design and administer SDWIS believe that the net
additional cost of the regulations proposed here is not significantly
greater than that of the PWSS Program. 

The Agency also performs the role attributed to States and territories,
for those States and territories over which it has primacy.  This cost
is included as part of the total burden and cost for States.

6d	Respondent Universe tc \l2 "6d	Respondent Universe 

There are a total of 147,330 PWSs and 57 States and territories
considered for this Information Collection Request.

6e	Bottom Line Burden Hours and Costs tc \l2 "6e	Bottom Line Burden
Hours and Costs 

This section provides a description of bottom line estimates for
implementation of the rule.  The bottom line burden hours and costs for
systems and States are the summaries of the hours and costs collectively
incurred for all activities.  The first part of this section describes
the estimated average annual costs and hourly burdens for respondents to
the rule.  The second part discusses the potential cost and burden to
EPA.  Figure 6.2 presents a summary of the average annual respondent
burden over 3 years for PWSs and States.  All additional exhibits
relating to this ICR are in Appendix A.

Figure 6.2

Bottom Line Average Annual Burden and Costs

Number of Respondents	

49,167 =49,110

+57	

Public water systems

States 



Total Annual Responses	

98,277 =98,220

+57	

Public water system responses

State responses



Number of Responses per Public Water System	

2.00 =98,220

 /49,110	

Total annual PWS responses from above

Total public water systems from above



Number of Responses per State	

1.00 =57

/57	

Total annual State responses from above

Total States from above



Total Annual Respondent Burden Hours	

385,264 =260,244

+125,020	

Public water system hours

State hours



Hours per Response

for Public Water Systems	

2.6  = 260,244

/98,220	

Total PWS annual hours from above

Total PWS responses from above



Hours per Response for States	

2,193.3 =125,020

/57	

Total State annual hours from above

Total State responses from above



Annual O&M Costs	

$0 = $0

+$0	

Public water system O&M costs

State O&M costs



Total Annual Respondent Cost	

$10,091,422 =$5,890,508

+$4,200,914	

Public water system costs

State costs



Total Annual Hours (respondent plus Agency)	

385,264  =385,264

+0	

Total respondent hours

Total EPA hours



Total Annual Cost (respondent plus Agency)	

$10,091,422 =$10,091,422

+$0	

Total respondent cost

Total EPA cost

Note: Detail may not add exactly to total due to independent rounding. 
EPA burden and cost estimated under PWSS program.

6e(i)	Bottom Line Burden and Cost Estimates for Respondents tc \l3
"6e(i)	Bottom Line Burden and Cost Estimates for Respondents 

The total annual average respondent burden associated with this ICR is
estimated to be 385,264 burden hours.  The corresponding total annual
average respondent labor costs are estimated to be $10.1 million.  There
are neither capital nor O&M costs during the 3-year ICR period.

EPA estimates the annual respondent burden for PWSs to be 260,244 hours.
 Annual respondent costs for PWSs are estimated to be $5.9 million.  The
Agency estimates that the annual respondent burden for States is 125,020
hours.  The corresponding annual average respondent costs for States are
estimated to be $4.2 million.

6e(ii)	Bottom Line Estimate for Agency tc \l3 "6e(ii)	Bottom Line
Estimate for Agency 

As mentioned previously in section 6c, the costs and burden incurred by
EPA to process, analyze, and maintain SDWIS, are presented as part of
the PWSS Program ICR.  Additional costs that are likely to be incurred
by the Agency for Tribes and the State of Wyoming are included in the
tally for the costs and burdens to States and territories because most
costs are estimated on a per system basis and because the number of PWSs
on Tribal land or in Wyoming affected by various provisions of the rule
is uncertain.

6f	Reasons for Change in Burden tc \l2 "6f	Reasons for Change in Burden 

National burden estimates increase primarily because system operation
and ground water source monitoring requirements are being strengthened
under this rule.  The SDWA was amended in August 1996, and as a result
of these amendments, EPA is required to promulgate a Ground Water Rule
requiring the disinfection of ground water sources, as appropriate.  The
purpose of the GWR is to improve control of microbial pathogens in
drinking water from ground water sources.

6g	Burden Statement tc \l2 "6g	Burden Statement 

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 5.3 hours per PWS respondent and
2,193 hours per State respondent per year for the 3-year approval
period.  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-OW-2002-0061, which is available for online viewing at
www.regulations.gov, or in person viewing at the Water Docket in the EPA
Docket Center (EPA/DC), EPA West, Room B102, 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 Water Docket is (202) 566-2426.  An
electronic version of the public docket is available at
www.regulations.gov.  This site can be used to submit or view public
comments, 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-OW-2002-0061 in any correspondence.



Appendix A

Detailed Burden and Cost Tables



































The term (State( in the context of this ICR refers to any State or other
primacy agency that has oversight authority for drinking water programs.

 Enviromail Group/DC/USEPA/US@EPA, Information provided in response to
an information request made on July 19, 1999. 
http://www.epa.gov/enviro/html/sdwis/sdwis_feedback.html

Information Collection Request for 	  PAGE  1 	October 2006

National Primary Drinking Water Regulations:	 

Final Ground Water Rule

Information Collection Request for 	  PAGE  19 	October 2006

National Primary Drinking Water Regulations:

Final Ground Water Rule	

Information Collection Request for 	  PAGE  19 		October 2006

National Primary Drinking Water Regulations:

Final Ground Water Rule	

Information Collection Request for 		  PAGE  20 	October 2006

National Primary Drinking Water Regulations:

Final Ground Water Rule	

Information Collection Request for 	  PAGE  49 		October 2006

National Primary Drinking Water Regulations:

Final Ground Water Rule	

