INFORMATION
COLLECTION
REQUEST
FOR
THE
FILTER
BACKWASH
RECYCLING
RULE
EPA
ICR
No.
1928.02
Prepared
For:
U.
S.
Environmental
Protection
Agency
Office
of
Ground
Water
&
Drinking
Water
Prepared
By:
The
Cadmus
Group,
Inc.
1901
N.
Ft.
Meyer
Drive
Suite
900
Arlington,
Virginia
22209
U.
S.
EPA
Contract:
68­
C­
99­
206
Work
Assignment:
1­
16
August
2,
2000
August
2,
2000
Information
Collection
Request
for
the
FBRR
i
TABLE
OF
CONTENTS
1
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
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1
1a
Title
of
the
Information
Collection
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1
1b
Short
Characterization
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1
2
NEED
FOR
AND
USE
OF
THE
COLLECTION
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3
2a
Need/
Authority
for
the
Collection
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3
2b
Practical
Utility/
Users
of
the
Data
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4
3
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
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6
3a
Nonduplication
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6
3b
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
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6
3c
Consultations
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3d
Effects
of
Less
Frequent
Collection
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8
3e
General
Guidelines
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8
3f
Confidentiality
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3g
Sensitive
Questions
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9
4
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
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10
4a
Respondent/
SIC
Codes
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10
4b
Information
Requested
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10
4b(
i)
Data
Items
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10
4b(
ii)
Respondent
Activities
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11
4b(
ii)(
a)
State
Activities
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11
4b(
ii)(
b)
Public
Water
System
Activities
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11
4b(
ii)(
c)
ICR
Approval
Activity
Schedule
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12
5
THE
INFORMATION
COLLECTION
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
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15
5a
Agency
Activities
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15
5b
Collection
Methodology
and
Management
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15
5c
Small
Entity
Flexibility
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15
5d
Collection
Schedule
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16
6
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
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17
6a
Estimating
Respondent
Burden
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17
6a(
i)
Burden
to
PWSs
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17
6a(
ii)
Burden
to
States
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18
6b
Estimating
Respondent
Cost
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19
6b(
i)
Cost
to
PWSs
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19
6b(
ii)
Cost
to
States
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20
ii
Information
Collection
Request
for
the
FBRR
August
2,
2000
6c
Estimating
Agency
Burden
and
Cost
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21
6d
Respondent
Universe
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22
6d(
i)
PWS
Respondents
per
Provision
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22
6e
Bottom
Line
Burden
Hours
and
Costs
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23
6e(
i)
Bottom
Line
Estimates
for
Respondents
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23
6e(
i)(
a)
Bottom
Line
Burden
Hours
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23
6e(
i)(
b)
Bottom
Line
Costs
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24
6e(
ii)
Bottom
Line
Estimate
for
Agency
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24
6f
Reasons
for
Change
in
Burden
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24
6g
Burden
Statement
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24
List
of
Figures
Figure
1.
FBRR
Information
Collection
Activity
Compliance
Schedule
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14
Figure
2.
Compliance
Dates
for
the
FBRR
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16
Figure
3.
Burden
for
PWSs
 
3­
Year
ICR
Approval
Period
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17
Figure
4.
Burden
for
PWSs
 
Years
4,
5,
and
6
Following
Rule
Promulgation
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18
Figure
5.
Burden
for
States
 
3­
Year
ICR
Approval
Period
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18
Figure
6.
Burden
for
States
 
Years
4,
5,
and
6
Following
Rule
Promulgation
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19
Figure
7.
Cost
for
PWSs
 
3­
Year
ICR
Approval
Period
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20
Figure
8.
Cost
for
PWSs
 
Years
4,
5,
and
6
Following
Rule
Promulgation
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20
Figure
9.
Costs
for
States
 
3­
Year
ICR
Approval
Period
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21
Figure
10.
Costs
for
States
 
Years
4,
5,
and
6
Following
Rule
Promulgation
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21
Figure
11.
Summary
of
Respondents,
Responses,
Burden,
and
Costs
for
PWSs
and
States
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23
Appendices
Appendix
A
Detailed
Burden
and
Cost
Estimates
Appendix
B
Respondent
Universe/
Activity
Schedule
August
2,
2000
Information
Collection
Request
for
the
FBRR
1
INFORMATION
COLLECTION
REQUEST
FOR
THE
NATIONAL
PRIMARY
DRINKING
WATER
REGULATIONS:
FILTER
BACKWASH
RECYCLING
RULE
SUPPORTING
STATEMENT
FOR
RECORDKEEPING
AND
REPORTING
1
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1a
Title
of
the
Information
Collection
TITLE:
Information
Collection
Request
for
the
National
Primary
Drinking
Water
Regulations:
Filter
Backwash
Recycling
Rule
U.
S.
EPA
ICR
NUMBER:
1928.02
Note:
The
description
of
the
recordkeeping
and
reporting
burden
in
this
supporting
statement
covers
all
activities
required
for
full
rule
implementation.
EPA
assumes
that
all
start­
up
costs
(
e.
g.,
reading
and
understanding
the
rule,
and
mobilization
and
planning)
for
States
and
water
systems
will
be
incurred
during
the
ICR
approval
period.
The
Agency
also
assumes
that
all
affected
conventional
and
direct
filtration
systems
will
be
subject
to
reporting
requirements
within
the
3­
year
ICR
approval
period.
However,
to
provide
a
complete
picture
of
the
cost
and
burden
associated
with
the
rule,
costs
and
hourly
burden
estimates
are
provided
for
the
fourth,
fifth,
and
sixth
years
following
rule
promulgation.
These
estimates
are
provided
in
Section
6
of
this
document.
A
series
of
supporting
tables
are
provided
in
Appendices
A
and
B
at
the
end
of
the
document
to
ensure
transparency.

1b
Short
Characterization
The
Filter
Backwash
Recycling
Rule
(
FBRR)
requires
the
collection
of
recycle
practice
information
and
contains
requirements
designed
to
control
the
recycling
of
spent
filter
backwash,
thickener
supernatant,
and
liquids
from
solid/
liquid
separation
processes
within
public
water
systems
(
PWSs)
that
rely
on
either
surface
water
or
ground
water
under
the
direct
influence
of
surface
water
(
GWUDI)
as
their
source
[
Section
1412(
b)(
14)].

Systems
that
return
filter
backwash,
thickener
supernatant,
or
liquids
from
dewatering
processes
to
the
treatment
train
may
reintroduce
large
concentrations
of
contaminants
and
may
increase
the
risk
of
hydraulic
surges
that
may,
in
turn,
allow
some
contaminants
to
pass
through
the
systems'
1This
estimate
includes
seven
respondents
(
four
conventional
filtration
systems
and
three
direct
filtration
systems)
that
serve
greater
than
one
million
people.

2The
term
State,
as
used
in
this
ICR,
refers
to
the
50
States,
the
District
of
Columbia,
Guam,
the
Commonwealth
of
Puerto
Rico,
the
Northern
Mariana
Islands,
the
Virgin
Islands,
American
Samoa,
and
the
Trust
Territory
of
the
Pacific
Islands.

2
Information
Collection
Request
for
the
FBRR
August
2,
2000
filters.
Of
particular
concern
is
the
possibility
of
the
reintroduction
of
microbiological
contaminants
such
as
Cryptosporidium
due
to
recycling
practices
or
the
failure
to
remove
oocysts
during
a
hydraulic
surge.

Cryptosporidium
is
a
protozoan
parasite
that
is
common
in
the
environment
and
widely
found
in
surface
water
supplies
(
see
publications
by
Drs.
Rose,
1998;
LeChevallier
and
Norton,
1995;
Atherholt
et
al.,
1998).
In
the
infected
species,
the
parasite
multiplies
in
the
gastrointestinal
tract
and
is
then
excreted
in
the
form
of
oocysts.
These
oocysts
are
relatively
resistant
in
the
environment
and
are
not
easily
killed
by
commonly
used
disinfectants
such
as
chlorine
and
chloramines
(
in
the
concentrations
that
are
used
in
drinking
water
treatment).
The
only
widely
used
water
treatment
that
removes
or
kills
Cryptosporidium
is
filtration.

The
FBRR
requires
all
Subpart
H
(
PWSs
using
surface
water
or
GWUDI
as
a
source)
that
employ
conventional
or
direct
filtration
to
return
recycled
filter
backwash
water,
sludge
thickener
supernatant,
or
liquids
from
dewatering
processes
to
a
location
where
all
steps
in
a
system's
conventional
or
direct
filtration
are
employed.
Systems
may
apply
to
the
State
to
recycle
to
a
different
location.
However,
all
conventional
and
direct
filtration
systems
practicing
recycle
must
notify
the
State
that
they
are
recycling
filter
backwash
and
provide
detailed
information
on
recycle
flows.
In
addition,
systems
must
collect
and
maintain
information
on
their
recycling
practice
for
review
by
the
State.
States
will,
in
turn,
approve
or
reject
applications
for
alternate
recycle
return
locations
and
review
all
submitted
information
from
systems.

The
required
information
collection
will
involve
a
total
of
4,650
PWS
respondents1
and
56
State
respondents
and
is
expected
to
cost
approximately
$
4.2
million
prior
to
full
implementation.
2
During
this
3­
year
ICR
reporting
period,
an
estimated
4,650
PWSs
will
spend
a
total
of
181,540
hours
and
$
3.8
million
on
required
activities
associated
with
the
rule.
The
average
annual
burden
over
the
3­
year
ICR
reporting
period
is
60,513
hours
and
$
1.3
million.

On
average,
19
States
are
expected
to
respond
each
year
(
512
responses
annually).
The
estimated
annual
State
burden
and
cost
during
this
ICR
approval
period
will
be
5,849
hours
and
$
136,182.
Appendix
A
provides
a
detailed
summary
of
the
annual
burden
and
costs
anticipated
for
PWSs
and
States
for
the
first
3
years
following
promulgation
of
the
rule
as
well
as
the
second
3­
year
implementation
period.
August
2,
2000
Information
Collection
Request
for
the
FBRR
3
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
The
information
collected
under
this
rule
is
required
by
EPA
to
carry
out
its
monitoring
and
enforcement
responsibilities
under
the
Safe
Drinking
Water
Act
(
SDWA).
Without
comprehensive,
up­
to­
date
information
on
drinking
water
contamination,
the
Agency
would
not
be
able
to
meet
the
SDWA
statutory
requirements.

Sections
1401(
1)
and
1412(
a)(
3)
of
the
SDWA,
as
amended
in
1986,
require
that
when
EPA
publishes
a
Maximum
Contaminant
Level
Goal
(
MCLG),
it
must
also
publish
a
NPDWR
that
specifies
either
a
Maximum
Contaminant
Level
(
MCL)
or
treatment
technique.
MCLGs
are
to
be
set
at
a
level
at
which
"
no
known
or
anticipated
adverse
effects
on
the
health
of
persons
occur
and
which
allows
an
adequate
margin
of
safety"
(
Section
1412(
b)(
4)).
The
SDWA
authorizes
EPA
to
promulgate
an
NPDWR
"
that
requires
the
use
of
a
treatment
technique
in
lieu
of
establishing
an
MCL,"
if
the
Agency
finds
that
"
it
is
not
economically
or
technologically
feasible
to
ascertain
the
level
of
the
contaminant."
The
Act
was
again
amended
in
August
1996,
resulting
in
the
addition
of
new
sections
that
establish
new
drinking
water
requirements.
Section
1412(
b)(
14)
requires
the
Administrator
to
promulgate
a
regulation
to
govern
the
recycling
of
filter
backwash
water
within
the
treatment
process
of
a
PWS.
The
amendment
requires
the
Administrator
to
promulgate
such
regulation
no
later
than
4
years
after
the
date
of
the
enactment
of
the
1996
SDWA
amendments,
unless
such
recycling
has
been
addressed
by
the
Administrator's
Enhanced
Surface
Water
Treatment
Rule
(
ESWTR)
prior
to
such
date.

Prior
to
the
1996
Amendments
to
the
SDWA,
EPA
instituted
a
formal
regulatory
negotiation
(
RegNeg)
process
in
1992
with
potentially
affected
parties
(
57
FR
53866;
Nov.
13,
1992).
This
RegNeg
Committee
included
representatives
from
water
utilities
and
other
industries,
State
public
health
and
regulatory
agencies,
environmental
groups,
consumer
groups,
and
EPA.
Following
an
extensive
consensus­
building
effort,
the
RegNeg
Committee
agreed
that
EPA
should
propose
three
rules:

1.
An
Information
Collection
Rule
(
ICR)
(
final
in
1996);

2.
A
staged
ESWTR;
and
3.
A
staged
Disinfectants/
Disinfection
Byproducts
Rule
(
DBPR;
first
stage
to
be
promulgated
concurrently
with
the
first
stage
of
the
ESWTR).

These
rules
formed
the
basis
for
the
provisions
of
the
1996
amendments.
The
1996
amendments
require
EPA
to
promulgate
regulations
to
"
govern"
filter
backwash
recycling
within
the
treatment
process
of
public
utilities
[
Section
1412(
b)(
14)]
and
to
promulgate
regulations
specifying
criteria
for
requiring
disinfection
"
as
necessary"
for
ground
water
systems.
The
Agency
is
promulgating
4
Information
Collection
Request
for
the
FBRR
August
2,
2000
these
recycling
regulations
as
part
of
the
provisions
of
the
FBRR.
The
provisions
of
the
FBRR
require:


That
recycled
filter
backwash
water,
sludge
thickener
supernatant,
and
liquids
from
dewatering
processes
must
be
returned
to
a
location
such
that
all
steps
of
a
system's
conventional
or
direct
filtration
as
defined
in
40
CFR,
Section
141.2
are
employed.
Systems
may
apply
to
the
State
to
recycle
at
an
alternate
location.


That
systems
which
practice
conventional
filtration
and
recycle
spent
filter
backwash,
sludge
thickener
supernatant,
or
liquids
from
dewatering
processes,
must
notify
the
State
in
writing
that
they
practice
recycle.


That
systems
which
practice
direct
filtration
and
recycle
spent
filter
backwash,
sludge
thickener
supernatant,
or
liquids
from
dewatering
processes,
must
notify
the
State
in
writing
that
they
practice
recycle.

Additionally,
both
conventional
and
direct
filtration
systems
must
collect
and
maintain
information
on
recycle
flows
for
review
by
the
State
Since
changes
to
the
Surface
Water
Treatment
Rule
(
SWTR)
were
initially
proposed
in
1994,
Congress
has
mandated
the
promulgation
of
the
"
M/
DBP
Cluster"
of
rules
to
address
microbial
contaminants
and
disinfection
byproducts
(
M/
DBPs)
under
the
1996
Amendments
to
the
SDWA.
An
M/
DBP
Advisory
Committee,
formed
under
the
authority
of
the
Federal
Advisory
Committees
Act
(
FACA),
convened
in
1997
to
review
the
data
and
assumptions
used
to
support
the
1994
proposal
and
data
that
had
subsequently
been
collected.
The
Interim
Enhances
Surface
Water
Treatment
Rule
(
IESWTR)
incorporated
these
data
and
assumptions.
The
burden
analysis
for
the
FBRR
also
relies
on
these
data
and
assumptions,
although
they
have
been
modified
to
reflect
small
system
conditions
and
stakeholder
input.

2b
Practical
Utility/
Users
of
the
Data
The
FBRR
requires
each
PWS
to
maintain
system­
level
records
on
recycling
practices.
These
data
may
be
used
by
PWSs
to:


Determine
system­
specific
needs,
and

Track
progress.

States
are
required
to
maintain
records
submitted
by
PWS
respondents
(
40
CFR,
Section
142.14).
States
could
then
use
these
records
to
track
PWS
monitoring
efforts,
compliance
violations,
and
enforcement
activities.
This
will
help
States
target
systems
for
compliance
and
take
the
necessary
and
appropriate
remedial
action.

As
part
of
their
supervision
of
PWSs,
the
States
and
EPA
have
a
number
of
critical
questions
to
answer.
August
2,
2000
Information
Collection
Request
for
the
FBRR
5
At
the
system
level:


Is
each
PWS
in
compliance
with
the
standards?


For
systems
not
in
compliance,
why
are
they
not
in
compliance
and
how
can
they
achieve
compliance?


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

At
the
State
and
national
level:


What
are
the
State
and
national
trends
in
compliance?


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


Is
noncompliance
a
function
of
location,
size,
or
another
explanatory
characteristic?
6
Information
Collection
Request
for
the
FBRR
August
2,
2000
3
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
The
following
sections
verify
and
affirm
that
this
ICR
satisfies
the
Office
of
Management
and
Budget
(
OMB)
data­
collection
guidelines,
has
public
support,
and
does
not
duplicate
another
collection.

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
that
this
rule
requires
are
not
available
from
any
other
source.

3b
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
EPA
initially
proposed
the
FBRR
in
conjunction
with
the
Long
Term
1
Enhanced
Surface
Water
Treatment
Rule
(
LT1ESWTR)
in
the
Federal
Register
on
Monday,
April
10,
2000
(
Vol
65,
No
69,
19045­
19150)
and
a
60­
day
public
comment
period
was
provided.
EPA
refined
the
proposed
rule
in
response
to
public
comments
about
burden,
which
resulted
in
two
separate
rulemakings.

3c
Consultations
After
consulting
with
regional
offices,
State
drinking
water
programs,
individuals
who
have
attended
stakeholder
meetings,
foundations,
and
the
Small
Business
Administration
(
SBA),
EPA
developed
a
list
of
representatives
of
small
water
utilities.
The
list
included
representatives
from
small
water
utilities;
businesses
such
as
restaurants,
mobile
home
parks,
hotels,
motels,
factories,
and
campgrounds
that
provide
drinking
water
ancillary
to
their
primary
business;
homeowner
associations;
investor­
owned
systems;
purchased
water
systems;
small
local
governments;
churches;
and
individuals
who
do
not
directly
own
systems
but
provide
technical
and
compliance
assistance
to
small
systems.
EPA
invited
24
Small
Entity
Representatives
(
SERs)
to
participate
in
the
FBRR
and
LT1ESWTR
consultation
process.
The
names
and
organizational
affiliations
of
each
of
the
15
SERs
who
agreed
to
participate
in
the
FBRR/
LT1ESWTR
consultation
process
are
provided
in
the
list
below.

SMALL
ENTITY
REPRESENTATIVES
NAME
ORGANIZATION
Dan
Boyce
Water
and
Light
Department,
East
Grand
Fork,
MN
Doug
Evans
Salt
Lake
County
Service
Area
#
3,
UT
Danny
Flemming
Blanding
City
Water
Treatment
Plant,
UT
J.
D.
Hightower
City
of
Escalon,
CA
Charlie
Holbrook
Water
Treatment
Plant,
Allum
Creek,
WV
Michael
Knox
Cherry
Valley
&
Rockdale
Water
District,
MA
Chris
Kramer
Bayfield,
CO
August
2,
2000
Information
Collection
Request
for
the
FBRR
7
Al
Lamm
Thief
River
Falls
Municipal
Utilities,
MN
Tom
McFeron
Nashville
Water
Treatment
Plant,
IL
Albert
Ricksecker
Brooklyn
Tapline
Co.,
Inc.,
UT
Tom
Sakry
International
Falls
Water
Utility,
MN
Jim
Sheldon
Cedar­
Knox
Rural
Water
Project,
NE
Paul
Torok
Seeley
Lake,
Missoula
County
Water
District,
MT
Gary
Walter
Tuolumne
Utilities
District,
CA
Tom
Weathers
Glencoe
Water
Department,
IL
EPA
sponsored
a
SER
teleconference
on
April
28,
1998,
in
Washington,
D.
C.,
with
the
purpose
of
providing
SERs
with
summaries
of
the
data
that
support
rule
development;
engaging
SERs
in
analysis
and
discussion
of
the
implications
of
the
data;
and
soliciting
additional
data,
especially
actual
experience
with
costs.
While
the
meeting
focused
on
the
FBRR
and
the
LT1ESWTR,
the
SERs
also
received
a
brief
overview
of
the
planned
Long
Term
2
Enhanced
Surface
Water
Treatment
Rule
(
LT2ESWTR)
and
Stage
2
DBPR.
During
the
meeting
SERs
raised
many
questions
concerning
the
potential
cost
of
turbidity
monitoring
and
exceptions
reporting.
Comments
on
the
anticipated
labor
rates
were
mixed,
with
some
SERs
considering
them
low
while
others
voiced
their
belief
that
they
were
too
high.

On
August
21,
1998,
EPA
convened
a
Small
Business
Advocacy
Review
Panel
in
accordance
with
Section
609(
b)
of
the
Regulatory
Flexibility
Act
(
RFA),
as
amended
by
the
Small
Business
Regulatory
Enforcement
Flexibility
Act
of
1996
(
SBREFA).
The
Panel
consisted
of:


EPA's
Small
Business
Advocacy
Chairperson;


The
Director
of
the
Standards
and
Risk
Management
Division
(
SRMD)
in
the
Office
of
Ground
Water
and
Drinking
Water
(
OGWDW)
within
EPA's
Office
of
Water;


The
Administrator
for
the
Office
of
Information
and
Regulatory
Affairs
of
OMB;
and

The
Chief
Counsel
for
Advocacy
of
the
SBA.

The
Panel
met
a
total
of
three
times
between
August
21
and
October
19,
1998.

In
September
1998,
the
Small
Business
Advocacy
Review
Panel
distributed
additional
information
on
potential
regulatory
approaches
and
the
anticipated
costs
associated
with
these
approaches
to
the
SERs
for
their
review
and
comment.
On
September
25,
the
Panel
held
a
teleconference
during
which
they
discussed
the
recycling
provisions
of
the
FBRR
with
the
SERs.

During
the
rule
development
process,
EPA
also
organized
a
Small
System
Data
Needs
Working
Group
composed
of
representatives
from:
the
American
Water
Works
Association
(
AWWA),
Association
of
State
Drinking
Water
Administrators
(
ASDWA),
National
League
of
Cities,
National
Resources
Defense
Council
(
NRDC),
and
National
Rural
Water
Association
(
NRWA).
Established
in
the
Spring
of
1997,
the
group
held
six
meetings,
from
March
through
December
of
1997,
to
discuss
the
availability
of
the
water
quality
and
financial
data
for
small
systems
needed
to
support
the
FBRR
and
other
drinking
water
regulations.
8
Information
Collection
Request
for
the
FBRR
August
2,
2000
3d
Effects
of
Less
Frequent
Collection
During
the
development
of
the
FBRR,
EPA
considered
alternatives
for
a
wide
range
of
frequency
and
burden
estimates
for
data
collection.
The
alternatives
that
will
require
the
least
frequent
collection
while
achieving
contaminant
monitoring
objectives
were
selected.
Unless
a
system's
recycling
practices
change,
all
collection
activities
will
occur
one
time
only.

3e
General
Guidelines
This
collection
does
not
violate
any
of
the
guidelines
established
by
OMB
under
the
Paperwork
Reduction
Act
[
5
CFR
1320.5(
d)(
2)]
with
one
possible
exception.
Specifically,
respondents
will
not
be
required
to:

°
Report
information
to
the
Agency
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;

°
Participate
in
a
statistical
survey
that
is
designed
to
produce
data
that
can
be
generalized
to
the
universe
of
the
study;

°
Utilize
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.

However,
the
rule
will
require
retention
of
records
for
more
than
3
years.
As
required
under
40
CFR
142.16
(
b)(
3)(
i),
water
systems
must
maintain
records
until
the
next
sanitary
survey
conducted
by
the
State.
For
noncommunity
water
systems,
sanitary
surveys
must
be
conducted
at
least
every
5
years,
and
therefore,
these
systems
would
have
to
maintain
their
records
until
the
next
sanitary
survey.
August
2,
2000
Information
Collection
Request
for
the
FBRR
9
3f
Confidentiality
This
information
collection
will
not
require
respondents
to
disclose
confidential
information.

3g
Sensitive
Questions
The
information
collection
does
not
ask
any
questions
pertaining
to
sexual
behavior
or
attitudes,
religious
beliefs,
or
other
matters
usually
considered
private.
3
Within
this
ICR,
references
to
the
respondent
category
"
States"
refers
to
both
States
and
territories.

10
Information
Collection
Request
for
the
FBRR
August
2,
2000
4
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
The
following
sections
provide
information
on
the
respondents
and
the
information
the
rule
would
require
them
to
provide.

4a
Respondent/
SIC
Codes
Under
this
rule,
there
are
two
primary
respondent
categories.
The
first
respondent
category
is
composed
of
the
operators
and
owners
of
PWSs
(
including
both
community
water
systems
(
CWSs)
and
noncommunity
water
systems
(
NCWSs)).
The
second
respondent
category
is
composed
of
the
States
and
territories
in
which
the
PWSs
are
located.
3
The
Standard
Industrial
Classification
(
SIC)
Code
for
private
water
systems
is
4941.
The
SIC
Code
for
both
publiclyowned
water
systems
and
for
State
agencies
is
9511.

PWSs
are
defined
as
those
water
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
that
regularly
serves
at
least
25
year­
round
residents.
NCWSs,
by
definition,
are
all
other
PWSs.
NCWSs
include
transient
systems
(
TNCWSs)
and
nontransient
systems
(
NTNCWSs).
NTNCWSs
serve
the
same
25
or
more
people
for
at
least
6
months
per
year,
while
transient
systems
serve
a
constantly
changing
population
(
40
CFR,
Section
141.2).

4b
Information
Requested
The
following
sections
provide
details
about
the
requested
data
items
and
the
activities
that
the
FBRR
requires
respondents
to
undertake
to
provide
this
information.

4b(
i)
Data
Items
EPA
is
adding
new
requirements
to
PWS
reporting
and
recordkeeping
responsibilities.
These
new
requirements,
which
are
itemized
in
Sections
141.75
and
141.76,
include:


A
copy
of
the
recycle
notification
and
information
submitted
to
the
State;


A
list
of
all
recycle
flows
and
the
frequency
with
which
they
are
returned;


The
average
&
maximum
backwash
flow
rate
through
the
filters
and
the
average
and
maximum
duration
of
the
filter
backwash
process
in
minutes;


The
typical
filter
run
length
and
a
written
summary
of
how
filter
run
length
is
determined;


The
type
of
treatment
provided
for
the
recycle
flow;
and
August
2,
2000
Information
Collection
Request
for
the
FBRR
11

Data
on
the
physical
dimensions
of
the
equalization
and/
or
treatment
units,
typical
and
maximum
hydraulic
loading
rates,
type
of
treatment
chemicals
used
and
average
dose
and
frequency
of
use,
and
frequency
at
which
solids
are
removed
if
applicable.

Consequently,
States
will
incur
a
new
recordkeeping
requirement
for:


maintenance
of
data
submitted
by
conventional
and
direct
filtration
PWSs
that
recycle.

4b(
ii)
Respondent
Activities
As
outlined
in
Section
4a
(
above),
respondents
include
both
States
and
PWSs.
Their
respective
information
collection
activities
are
described
below.

4b(
ii)(
a)
State
Activities
States
with
primacy
will
act
as
the
Agency
in
ensuring
the
implementation
of
the
FBRR
(
40
CFR,
Section
142.16).
To
successfully
meet
their
responsibilities,
EPA
anticipates
that
States
will
engage
in
the
following
activities:


Start­
up:

S
New
regulation
adoption
and
program
development
(
includes
primacy
applications);

S
Training
PWS
and
consultant
staff;


Analyzing
and
reviewing
PWS
data;


Making
determinations
concerning
PWSs;


Consulting
with
PWSs
on
changes
in
recycling
practices;


Recordkeeping;


Compliance
tracking;
and

Conducting
follow­
up
inspections.

4b(
ii)(
b)
Public
Water
System
Activities
The
FBRR
requires
each
affected
PWS
to
report
recycle
practice
information
to
the
State
and
maintain
records
on
recycle
flows.
In
general,
PWSs
will
be
involved
in
the
following
collection
activities:


Start­
up:

S
Reading
and
understanding
the
rule;

S
Mobilization
and
planning
activities;


Gathering
information,
(
e.
g.,
system
influent
and
recycle
flow
rates);


Reviewing,
processing,
and
compiling,
the
information
collected;


Submitting
recycle
return
location
information
to
State;


Meeting
with
the
State
regarding
changes
in
recycling
practices;
and

Recording
and
maintaining
the
information.
12
Information
Collection
Request
for
the
FBRR
August
2,
2000
Systems
must
perform
these
activities
to
complete
the
information
collection
requirements
under
this
rule,
which
include
monitoring,
reporting,
and
recordkeeping
requirements
as
described
below.


Recycle
Return
Location.
The
rule
requires
all
Subpart
H
PWSs
that
use
conventional
or
direct
filtration,
and
that
recycle
spent
filter
backwash,
thickener
supernatant,
or
liquids
from
dewatering
processes
to
a
location
other
than
one
that
returns
these
recycle
flows
through
processes
of
a
system's
existing
conventional
or
direct
filtration
system
including
specifically
coagualtion,
flocculation,
sedimentation
(
in
conventional
filtration
only)
and
filtration
to
either
propose
a
schedule
for
making
necessary
capital
improvements
to
recycle
through
the
aforementioned
processes
or
to
request
an
alternate
recycle
location
[
40
CFR,
Section
141.76(
b)].


Conventional
Filtration
Report.
The
rule
requires
all
PWSs
that
use
conventional
filtration,
regardless
of
system
size,
to
submit
a
report
of
their
recycling
practices
to
the
State
[
40
CFR,
Section
141.76(
b)].


Direct
Filtration
Report.
The
rule
requires
all
PWSs
that
use
direct
filtration,
regardless
of
system
size,
to
submit
a
report
of
their
recycling
practices
to
the
State
[
40
CFR,
Section
141.76(
b)].


Primacy
Requirements.
Under
the
FBRR,
individual
States
must
submit
an
application
to
EPA
for
the
approval
of
their
program.
This
application
must
describe
the
criteria
they
will
use
to
grant
systems
approval
to
return
spent
filter
backwash,
thickener
supernatant,
or
liquids
from
dewatering
to
an
alternative
location,
and
describe
how
thy
will
use
Sanitary
Surveys,
CPEs,
other
inspections,
or
existing
State
program
elements
to
evaluate
recycle
practices
and
information
collected
by
the
systems.


Summary
of
Respondent
ICR
Activities.
A
summary
of
the
information
collection
activities
required
by
the
FBRR
is
provided
in
Figure
1.
As
previously
mentioned,
the
number
of
respondents
required
to
undertake
a
given
activity
would
be
contingent
on
the
current
operational
practices
of
the
PWS.

4b(
ii)(
c)
ICR
Approval
Activity
Schedule
For
the
FBRR,
all
compliance
dates
for
regulatory
monitoring,
reporting,
and
recordkeeping
activities
described
above
occur
beyond
the
3­
year
ICR
approval
period.
The
appendices
at
the
end
of
this
document
provide
year­
by­
year
burden
and
cost
estimates.
Exhibits
A2
to
A5
provide
respondent
costs
and
burdens
for
the
3­
year
ICR
approval
period.
Exhibits
A13
to
A16
extend
these
year­
by­
year
cost
and
burden
estimates
out
6
years
following
promulgation,
at
which
point
the
rule
would
be
fully
implemented.
This
information
has
been
included
in
this
document
to
provide
a
complete
picture
of
the
burden
anticipated
from
the
implementation
of
the
rule
requirements.
August
2,
2000
Information
Collection
Request
for
the
FBRR
13
For
the
ICR
approval
period,
public
water
systems
will
undertake
start­
up
acitivities
which
include:
reading
and
understanding
the
rule,
mobilization
and
planning,
and
preparation
to
submit
reports
on
recycling
practices.
The
States
will
also
only
be
involved
in
start­
up
activities
which
include:
regulation
adoption,
program
development
including
primacy
applications,
and
training
of
PWS
and
consultant
staff.

Burden
of
third­
party
activities
is
anticipated
in
public
notification
provisions.
The
public
notification
burden
resulting
from
the
rule
requirements
will
be
included
in
the
renewal
of
the
Public
Notification
Rule
ICR.

Figure
1
provides
the
anticipated
compliance
schedule
for
PWSs
and
States
over
the
ICR
approval
period
and
the
following
3
years
(
6
years
total)
during
which
EPA
anticipates
that
full
implementation
of
the
rule
will
be
achieved.
Refer
to
Exhibit
B2
of
Appendix
B
for
a
more
detailed
compliance
schedule.
The
estimates
presented
in
both
the
FBRR
Regulatory
Impact
14
Information
Collection
Request
for
the
FBRR
August
2,
2000
Figure
1.

FBRR
Information
Collection
Activity
Compliance
Schedule
Activity
First
Three­
Year
Period
Second
Three­
Year
Period
Year
1
Year
2
Year
3
Year
4
Year
5
Year
6
Percent
of
Public
Water
Systems
Performing
Activity
Start­
up1
0%
34%
66%
0%
0%
0%

Request
Alternate
Recycle
Return2
0%
0%
10%
50%
40%
0%

Conventional
Filtration
Reporting3
0%
0%
100%
0%
0%
0%

Direct
Filtration
Reporting4
0%
0%
100%
0%
0%
0%

Percent
of
States
Performing
Activity
Start­
up5
50%
25%
25%
0%
0%
0%

Review
Requests
for
Alternate
Recycle
Return
Location6
0%
0%
10%
50%
40%
0%

Review
Conventional
Filtration7
0%
0%
10%
90%
0%
0%

Review
Direct
Filtration
Reports8
0%
0%
10%
90%
0%
0%

1
reading
and
understanding
the
rule;
mobilization
and
planning
activities
2
submission
of
alternate
recycle
location
request
to
State;
consultation
with
State;
recordkeeping
3
report
recycle
status,
schematic
and
flows;
collect
additional
recycle
data;
recordkeeping
4
report
recycle
status,
schematics
and
flows;
collect
additional
recycle
data;
recordkeeping
5
new
regulation
adoption
and
program
development
(
includes
priamcy
applications);
training
PWS
and
consultant
staff
6
review
recycle
plans,
alternate
location
requests;
consult
with
system;
recordkeeping
7
review
system
submittal;
review
additional
data;
recordkeeping
8
review
system
submittal;
review
additional
data;
recordkeeping
Analysis
and
this
ICR
were
based
on
this
schedule.
August
2,
2000
Information
Collection
Request
for
the
FBRR
15
5
THE
INFORMATION
COLLECTION
AGENCY
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
The
Agency
will
be
responsible
for
promulgating
this
rule
and
overseeing
its
implementation.
The
Agency
will
be
involved
in
the
following
activities:


Developing
this
rule
and
guidance
materials

Reviewing
and
analyzing
data
submissions
from
the
States
In
addition
to
these
activities,
the
Agency
will
also
assume
the
activities
performed
by
the
State
in
those
States
and
territories
that
do
not
have
primacy.
To
ensure
the
implementation
of
the
FBRR
(
40
CFR,
Section
142.16)
for
those
PWSs,
the
Agency
will
be
involved
in
the
following
activities:


Start­
up:

S
Mobilization,
planning,
and
implementation;

S
Training
PWS
and
consultant
staff;


Analyzing
and
reviewing
PWS
data;


Making
determinations
concerning
PWSs;


Meeting
with
PWSs
about
changes
in
recycling
practices;


Compliance
tracking;
and

Recordkeeping.

5b
Collection
Methodology
and
Management
EPA
will
not
be
managing
data
collected
under
the
FBRR,
except
for
data
submitted
by
systems
in
non­
primacy
States.
However,
the
FBRR
does
expect
PWSs
to
be
responsible
for
validating
the
information
collected.
States
are
expected
to
maintain
records
essential
for
program
implementation
and
oversight.

5c
Small
Entity
Flexibility
Throughout
the
1992
 
93
negotiated
rulemaking
process
for
the
Stage
1
DBPR
and
IESWTR
and
the
July
1994
proposals
for
these
rules,
a
small
PWS
was
defined
as
a
system
serving
fewer
than
10,000
people.
This
definition
reflects
the
original
1979
standard
for
total
trihalomethanes
(
TTHMs)
which
applied
only
to
systems
serving
at
least
10,000
people.
The
definition
thus
recognizes
that
the
baseline
conditions
from
which
systems
serving
fewer
than
10,000
people
would
approach
disinfection
byproduct
control
and
simultaneous
control
of
microbial
pathogens
would
be
different
than
those
for
systems
serving
10,000
or
more
people.
Consistent
with
the
1994
proposals,
EPA
is
continuing
to
define
a
"
small
system"
for
the
purposes
of
this
rule
as
a
PWS
that
serves
fewer
than
10,000
people.
Subsequent
to
the
1994
proposals,
EPA
defined
a
"
small
business"
for
purposes
of
Regulatory
Flexibility
Analysis
in
drinking
water
regulations
as
a
16
Information
Collection
Request
for
the
FBRR
August
2,
2000
PWS
serving
10,000
or
fewer
people.
This
definition
is
consistent
with
the
approach
used
herein
and
that
noted
in
the
1996
Congressional
amendments
to
SDWA.

The
FBRR
applies
to
both
large
and
small
systems.
Therefore,
the
rule
will
have
an
effect
on
small
entities.
Accordingly,
as
part
of
the
economic
analysis
for
the
rule,
EPA
is
certifying
that
this
rule
will
not
have
a
significant
impact
on
a
substantial
number
of
small
systems.
As
a
result,
an
Final
Regulatory
Flexibility
Analysis
was
not
required
to
be
conducted.

5d
Collection
Schedule
It
is
anticipated
that
this
rule
will
be
promulgated
by
November
of
2000.
None
of
the
compliance
deadlines
for
the
FBRR
fall
within
the
3­
year
ICR
period.

Figure
2
details
the
compliance
dates
by
which
affected
PWSs
must
be
in
compliance
with
specific
provisions
of
the
FBRR.

Figure
2.
Compliance
Dates
for
the
Filter
Backwash
Recycling
Rule
Request
for
Alternate
Recycle
Return
Location
or
Proposed
Schedule
for
Recycle
Return
Location
Capital
Improvements
36
months
following
rule
promulgation
Approval
of
Alternate
Recycle
Location
or
Completion
of
Modifications
to
recycle
practices
60
months
following
rule
promulgation
Conventional
Filtration
Report
36
months
following
rule
promulgation
Direct
Filtration
Report
36
months
following
rule
promulgation
August
2,
2000
Information
Collection
Request
for
the
FBRR
17
6
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
The
following
sections
discuss
costs
and
burden
for
the
reporting
and
recordkeeping
requirements
for
the
FBRR.
The
cost
and
burden
estimates
presented
in
this
section
are
derived
from
the
exhibits
found
in
Appendix
A.

6a
Estimating
Respondent
Burden
Section
6a
discusses
the
burden
faced
by
PWSs
and
States.
This
section
defines
respondent
burden
as
the
hours
required
to
complete
each
information
collection
and
recordkeeping
activity
required
under
the
three
provisions
of
the
FBRR.
The
activities
have
been
separated
into
those
that
will
occur
during
the
ICR
approval
period
and
those
that
will
occur
in
the
3
years
following
that
period
(
years
4,
5,
and
6
following
rule
promulgation).
As
previously
mentioned,
the
rule
does
not
require
all
respondents
to
complete
all
activities.

6a(
i)
Burden
to
PWSs
The
burdens
estimated
for
start­
up
and
implementation
activities
include
reading
the
rule,
mobilization
and
planning,
and
preliminary
activities
for
conventional
and
direct
filtration
reporting,
and
recordkeeping.
Figures
3
and
4
summarize
the
estimated
system­
level
burdens
for
each
of
the
compliance
activities
that
PWSs
may
undertake.
The
hourly
totals
in
these
two
figures
are
the
sum
of
all
hours
worked
by
managerial
and
technical
staff.
Descriptions
of
burdens
by
occupational
category
are
detailed
in
Exhibit
A11.

Figure
3.
Burden
for
PWSs
 
3­
year
ICR
Approval
Period*

Information
Collection
Activity
Number
of
Systems
(
i.
e.
number
of
responses)
Burden
for
Activity
(
hrs/
system)
Total
Estimated
Burden
(
hours)
Average
Annual
Burden
(
hours)

Start­
up
4,650
24
111,597
37,199
Recycle
Return
Location
9
21
195
65
Conventional
Filtration
Recycle
Reporting
4,321
15
64,813
21,604
Direct
Filtration
Recycle
Reporting
329
15
4,935
1,645
*
Columns
and
rows
may
not
add
to
total
due
to
rounding.
18
Information
Collection
Request
for
the
FBRR
August
2,
2000
Figure
4.
Burden
for
PWSs
 
Years
4,
5,
and
6
Following
Rule
Promulgation*

Information
Collection
Activity
Number
of
Systems
(
i.
e.
number
of
responses)
Burden
for
Activity
(
hrs/
system)
Total
Estimated
Burden
(
hours)
Average
Annual
Burden
(
hours)

Recycle
Return
Location
84
21
1,755
585
Conventional
Filtration
Recycle
Reporting
0
0
0
0
Direct
Filtration
Recycle
Reporting
0
0
0
0
*
Columns
and
rows
may
not
add
to
total
due
to
rounding.

6a(
ii)
Burden
to
States
States
will
complete
only
start­
up
activities
during
the
3­
year
ICR
approval
period.
Start­
up
activities
include:
new
regulation
adoption
and
program
development
(
includes
primacy
applications),
and
training
PWS
and
consultant
staff.
Implementation
activities
will
occur
after
the
3­
year
ICR
approval
period.
Implementation
activities
are
primarily
associated
with
reviewing
data
received
from
the
PWSs.

State
burden
estimates
were
based
on
interviews
with
State
officials,
a
review
of
similar
regulatory
requirements,
and
confirmation
by
the
M­
DBP
Committee.

Figures
5
and
6
illustrate
these
burden
estimates.

Figure
5.
Burden
for
States
 
3­
year
ICR
Approval
Period1
Information
Collection
Activity
Number
of
Responses
Burden
for
Activity
(
hrs/
system)
2
Total
Estimated
Burden
(
hours)
Average
Annual
Burden
(
hours)

Start­
up*
112
260
14,560
4,853
Review
Requests
for
Alternate
Recycle
Return
Location
28
13
121
40
Review
Conventional
Filtration
Reports
1,296
6
2,665
888
Review
Direct
Filtration
Reports
99
6
203
68
1Columns
and
rows
may
not
add
to
total
due
to
rounding.

2The
hourly
burden
for
start­
up
activities
is
presented
on
a
per
State
basis.

Figure
6
presents
State
burden
on
a
per
system
basis
for
activities
that
will
occur
during
the
second
3
years
following
promulgation
of
the
rule.
August
2,
2000
Information
Collection
Request
for
the
FBRR
19
Figure
6.
Burden
for
States
 
Years
4,
5,
and
6
Following
Rule
Promulgation*

Information
Collection
Activity
Number
of
Responses
Burden
for
Activity
(
hrs/
system)
Total
Estimated
Burden
(
hours)
Average
Annual
Burden
(
hours)

Review
Requests
for
Alternate
Recycle
Return
Location
251
13
1,086
362
Review
Conventional
Filtration
Reports
11,666
6
23,981
7,994
Review
Direct
Filtration
Reports
888
6
1,826
609
*
Columns
and
rows
may
not
add
to
total
due
to
rounding.

6b
Estimating
Respondent
Cost
This
section
presents
the
costs
that
are
expected
to
be
incurred
by
PWSs
and
States
as
a
result
of
the
implementation
of
the
FBRR.
Cost
figures
for
each
information
collection
activity
were
calculated
by
multiplying
the
burden
estimates
presented
in
the
previous
section
by
the
appropriate
hourly
labor
rate
[
see
Section
6b(
i)].
For
these
calculations,
EPA
assigned
tasks
between
two
labor
categories
for
PWSs
and
States:
managerial
and
technical.
The
division
of
labor
between
these
categories
is
expected
to
vary
for
systems
of
different
sizes
and
for
different
activities.
As
with
the
burden
estimates
presented
in
the
preceding
section,
cost
estimates
for
both
one­
time,
start­
up
activities,
and
implementation
activities
are
provided.

6b(
i)
Cost
to
PWSs
The
costs
estimated
for
start­
up
and
implementation
activities
include
reading
the
rule,
mobilization
and
planning,
and
preliminary
activities
for
conventional
and
direct
filtration
reporting,
and
recordkeeping.
Figures
7
and
8
provide
estimates
of
the
costs
associated
with
the
various
compliance
activities.
Exhibit
A8.1­
A8.4
provides
the
basis
for
the
derivations
of
costs
in
terms
of
number
of
responses.

The
labor
rates
for
PWSs
used
in
this
analysis
are
based
on
those
used
in
the
RIA
for
this
rule.
A
key
assumption
used
for
the
analysis
is
that
system
operators
will
complete
all
work
for
systems
serving
fewer
than
1,000
customers
since
managerial
staff
are
neither
required
nor
typically
retained
for
the
routine
operation
of
these
systems.

As
mentioned
above,
this
analysis
incorporates
two
labor
categories:
managerial
and
technical.
All
labor
rates
incorporate
a
1.4
load
factor
in
addition
to
a
base
hourly
rate
to
account
for
fringe
benefits,
overhead,
and
general
and
administrative
costs
(
Bureau
of
Labor
Statistics,
1997).
The
loaded
technical
labor
rate
for
affected
PWSs
was
calculated
to
be
$
14.50.
The
management
labor
category
was
assigned
a
loaded
labor
rate
of
$
28.
In
most
instances
for
systems
serving
1,000
or
more
customers,
the
cost
analysis
assumes
that
80
percent
of
anticipated
labor
would
be
4
As
noted
above,
all
labor
for
systems
serving
fewer
than
1,000
customers
was
assumed
to
be
completed
by
system
operators
(
technical
labor).

20
Information
Collection
Request
for
the
FBRR
August
2,
2000
completed
by
technical
workers,
while
20
percent
would
be
completed
by
managerial
workers.
4
The
loaded
labor
rates
for
systems
serving
10,000
or
more
customers
is
$
40.00
for
managerial
workers
and
$
28.00
for
technical
workers.
Exhibit
A11
provides
a
detailed
description
of
labor
burden
assumptions
and
hourly
labor
rates.
All
rates
are
presented
in
January
1999
dollars.

Figure
7.
Cost
for
PWSs
 
3­
year
ICR
Approval
Period*

Information
Collection
Activity
Number
of
Systems
(
i.
e.
number
of
responses)
Average
Cost
for
Activity
($/
system)
Total
Estimated
Cost
($)
Average
Annual
Cost
($)

Start­
up
4,650
530
2,462,589
820,863
Recycle
Return
Location
9
423
3,807
1,269
Conventional
Filtration
Recycle
Reporting
4,321
288
1,246,320
415,440
Direct
Filtration
Recycle
Reporting
329
401
131,818
43,939
*
Columns
and
rows
may
not
add
to
total
due
to
rounding.

Figure
8.
Cost
for
PWSs
 
Years
4,
5,
and
6
Following
Rule
Promulgation*

Information
Collection
Activity
Number
of
Systems
(
i.
e.
number
of
responses)
Average
Cost
for
Activity
($/
system)
Total
Estimated
Cost
($)
Average
Annual
Cost
($)

Recycle
Return
Location
84
408
34,264
11,421
Conventional
Filtration
Recycle
Reporting
0
0
0
0
Direct
Filtration
Recycle
Reporting
0
0
0
0
*
Columns
and
rows
may
not
add
to
total
due
to
rounding.

No
capital
or
O&
M
costs
will
be
incurred
by
PWSs
as
a
result
of
the
collection
activities
associated
with
the
FBRR.

After
full
implementation
of
the
rule,
EPA
estimates
that
total
implementation
activity
costs
for
PWSs
would
be
$
3.9
million
(
derived
from
Exhibit
A13.5).

6b(
ii)
Cost
to
States
Annual
costs
for
States
were
estimated
based
on
the
anticipated
labor
requirements
for
monitoring
those
small
systems
that
would
be
regulated
under
the
LT1ESWTR.
State
labor
rates
were
based
August
2,
2000
Information
Collection
Request
for
the
FBRR
21
on
those
used
in
the
cost
estimates
for
the
IESWTR,
but
were
escalated
to
December
1998
dollars
using
the
quarterly
employment
cost
index
for
State
and
local
employees
(
BLS,
1999)
to
account
for
inflation.
Thus,
for
this
analysis,
the
unloaded
rate
for
State
technical
staff
was
calculated
to
be
$
15.21
per
hour,
and
the
unloaded
rate
for
managerial
staff
was
calculated
to
be
$
22.31
per
hour.
Using
the
same
1.4
load
factor
used
for
the
determination
of
PWS
labor
rates
(
above),
State
labor
rates
were
calculated
to
be
$
21.29
and
$
31.23,
respectively.

To
estimate
the
cost
for
each
activity,
these
labor
rates
were
multiplied
by
the
managerial
and
technical
burden
estimates
(
Exhibit
A11).
The
cost
analysis
assumes
that
80
percent
of
anticipated
labor
would
be
completed
by
technical
workers,
while
20
percent
would
be
completed
by
managerial
workers.
Figures
9
and
10
present
the
cost
estimates,
associated
with
compliance
assurance
activities.
Exhibit
A9
provides
the
basis
for
the
derivations
of
costs
in
terms
of
number
of
responses.

Figure
9.
Costs
for
States
 
3­
year
ICR
Approval
Period1
Information
Collection
Activity
Number
of
Responses
Total
Estimated
Cost
($)
Average
Annual
Cost
($)

Start­
up2
112
338,978
112,993
Review
Requests
for
Alternate
Recycle
Return
Location
28
2,810
937
Review
Conventional
Filtration
Reports
1,296
62,034
20,678
Review
Direct
Filtration
Reports
99
4,723
1,574
1Columns
and
rows
may
not
add
to
total
due
to
rounding.
2The
hourly
burden
for
start­
up
activities
is
presented
on
a
per
State
basis.

Figure
10.
Costs
for
States
 
Years
4,
5,
and
6
Following
Rule
Promulgation*

Information
Collection
Activity
Number
of
Responses
Total
Estimated
Cost
($)
Average
Annual
Cost
($)

Review
Requests
for
Alternate
Recycle
Return
Location
251
25,294
8,431
Review
Conventional
Filtration
Reports
11,666
558,308
186,102
Review
Direct
Filtration
Reports
888
42,511
14,170
*
Columns
and
rows
may
not
add
to
total
due
to
rounding.

The
Agency
estimates
that
total
implementation
activity
costs
for
States
would
be
$
1.0
million
(
Exhibit
A14).

6c
Estimating
Agency
Burden
and
Cost
As
previously
mentioned,
EPA
has
primacy
for
small
PWSs
on
tribal
lands
and
those
in
the
State
of
Wyoming.
For
these
systems,
EPA
will
incur
costs
and
burdens
similar
to
those
incurred
by
5
This
estimate
includes
4,318
small
systems
and
large
systems
serving
fewer
than
one
million
that
are
shown
in
the
RIA
decision
tree
plus
three
plants
serving
between
10,000
and
50,000
that
belong
to
a
system
that
serves
more
than
one
million.
EPA
evaluated
the
systems
in
this
largest
size
category
at
a
plant
level
rather
than
the
system
level
because
EPA
has
plant­
level
data
for
these
systems
and
some
plants
do
not
practice
direct
recycling.
The
cost
analysis
for
the
RIA
and
this
ICR
include
these
three
plants.

6
This
estimate
includes
325
small
systems
and
large
systems
serving
fewer
than
one
million
that
are
shown
in
the
RIA
decision
tree
plus
four
plants
serving
between
50,000
and
one
million
that
belong
to
systems
that
serve
more
than
one
million.
EPA
evaluated
the
systems
in
this
largest
size
category
at
a
plant
level
rather
than
the
system
level
because
EPA
has
plant­
level
data
for
these
systems
and
some
plants
do
not
practice
recycle.
The
cost
analysis
for
the
RIA
and
this
ICR
includes
these
three
plants.

22
Information
Collection
Request
for
the
FBRR
August
2,
2000
States
with
primacy.
Since
these
PWSs
are
potential
respondents
to
the
rule,
the
associated
implementation
costs
and
burden
that
the
EPA
will
incur
have
been
included
as
part
of
the
State
costs
and
burdens.
It
is
possible
that
Wyoming
may
achieve
primacy
again,
and
at
that
point
it
would
assume
the
burden
of
rule
implementation
from
the
Agency.
Given
this
possibility,
and
the
difficulty
of
distinguishing
small
PWSs
on
tribal
lands
from
those
systems
that
are
not
on
tribal
lands,
this
analysis
did
not
attempt
to
distinguish
between
the
implementation
burden
and
costs
that
would
be
incurred
by
States
and
the
small
portion
that
would
be
incurred
by
EPA
(
i.
e.,
the
estimated
EPA
burden
and
costs
under
the
FBRR
have
been
included
in
the
State
burden
and
cost
estimates
presented
above).

6d
Respondent
Universe
An
estimated
4,650
PWSs
and
56
States
will
be
affected
by
the
FBRR
during
this
3­
year
ICR
approval
period
(
Exhibit
A1).
Exhibits
A6,
A7,
A17
and
A18
in
Appendix
A
present
a
detailed
summary
of
anticipated
FBRR
respondents
and
responses.
Exhibits
A8
 
A11
provide
a
more
detailed
description
of
the
responses,
burden
hours,
and
costs
for
each
FBRR
provision,
and
Exhibits
A2
 
A5
present
the
anticipated
temporal
distribution
of
these
responses,
burdens,
and
costs
over
the
ICR
approval
period.
These
same
figures
for
the
fourth,
fifth,
and
sixth
years
following
promulgation
of
FBRR
are
presented
in
Exhibits
A12­
A16.

6d(
i)
PWS
Respondents
per
Provision
EPA
estimated
that
2
percent
or
93
small
and
large
systems
will
apply
for
an
alternate
recycle
location.
These
systems
will
also
be
required
to
meet
either
the
conventional
or
direct
filtration
reporting
requirements.

Approximately
4,321
small
and
large
systems
that
practice
conventional
filtration
will
be
required
to
conduct
start­
up
activities
and
submit
a
report
to
the
State
containing
information
on
recycle
status
and
flow,
and
a
schematic
diagram
of
the
plant.
5
Finally,
approximately
329
small
and
large
systems
that
use
direct
filtration
will
need
to
conduct
start­
up
activities
and
report
their
recycling
practices
to
the
State.
6
August
2,
2000
Information
Collection
Request
for
the
FBRR
23
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
the
EPA.

To
provide
a
coherent
understanding
of
how
the
burden
for
the
rule
would
occur,
the
compliance
schedule
from
Figure
2
is
summarized
below.
Furthermore,
to
provide
a
better
understanding
of
how
the
bottom
line
burden
and
cost
estimates
were
obtained,
the
steps
for
deriving
them
from
the
cost
data
in
Section
6b
are
summarized
below
as
well.

The
average
number
of
respondents
for
each
activity
was
multiplied
by
the
unit
cost
and
burden
estimates
for
each
activity,
which
were
reported
earlier.
Summing
the
burden
across
activities
and
PWSs
and
States
provides
the
bottom
line
burden
estimate.
Similarly,
summing
costs
across
activities
and
PWSs
and
States
gives
bottom
line
costs.

6e(
i)
Bottom
Line
Estimates
for
Respondents
Figure
11
presents
a
summary
of
these
bottom
line
estimates.
Please
refer
to
the
exhibits
found
in
Appendix
A
for
detailed
breakdowns
of
the
preliminary
estimates
derived
for
each
activity.
For
convenience
and
to
ensure
transparency,
Figure
11
lists
the
exhibits
in
Appendix
A
from
which
the
summary
numbers
were
derived.

Figure
11.
Summary
of
Respondents,
Responses,
Burden,
and
Costs
for
PWSs
and
States*

Average
Number
of
Respondents
Average
Number
of
Responses
Average
Annual
Burden
(
hours)
Average
Annual
Labor
Cost
PWSs
1,967
7,430
60,513
$
1,281,512
Exhibit
A6
A7
A4.5
A2.5
States
19
512
5,849
$
136,182
Exhibit
A6
A7
A5
A3
TOTAL
1,986
7,942
66,363
$
1,417,694
*
Columns
and
rows
may
not
add
to
total
due
to
rounding.

6e(
i)(
a)
Bottom
Line
Burden
Hours
Information
collection
activities
required
of
PWSs
under
this
rule
during
the
first
3
years
following
promulgation
will
result
in
an
average
annual
burden
of
60,513
hours.
For
States,
the
average
annual
burden
will
be
5,849
hours.
24
Information
Collection
Request
for
the
FBRR
August
2,
2000
6e(
i)(
b)
Bottom
Line
Costs
Neither
PWSs
nor
the
States
are
expected
to
incur
any
capital
or
O&
M
costs
as
a
result
of
the
information
collection
requirements
for
the
rule.
The
average
annual
cost
to
PWSs
and
States
for
the
recycling
provisions
is
estimated
at
$
1.3
million
and
$
136,182,
respectively.

6e(
ii)
Bottom
Line
Estimate
for
Agency
As
previously
mentioned
(
see
Section
6f),
costs
that
are
likely
to
be
incurred
by
Agency
to
administer
the
FBRR
for
tribal
water
systems
and
the
State
of
Wyoming
were
included
in
the
tally
for
States
and
territories
because
most
costs
were
estimated
on
a
per
system
basis
and
the
portion
of
PWSs
affected
by
this
rule
that
are
located
on
tribal
land
or
in
Wyoming
is
uncertain.

6f
Reasons
for
Change
in
Burden
The
FBRR
is
a
new
regulation
intended
to
work
in
concert
with
the
LT1ESWTR
to
improve
control
of
microbial
pathogens
in
drinking
water,
specifically
the
protozoan
Cryptosporidium,
and
address
risk
trade­
offs
with
disinfection
byproducts.

6g
Burden
Statement
During
the
3­
year
approval
period
of
this
ICR
(
2000
­
2004),
the
estimated
average
annual
per
respondent
burden
for
PWSs
and
States
is
31
hours
and
308
hours,
respectively.
The
estimate
for
PWSs
includes
time
for
start­
up
activities
and
for
all
of
the
subject
conventional
and
direct
filtration
systems
to
complete
reporting
requirements.
These
estimates
are
based
on
annual
average
burdens
and
respondents
in
Figure
11.

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;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instruction
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.

Please
send
comments
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
to
the
Director
Collection
Strategies
Division,
Office
of
Environmental
Information,
U.
S.
Environmental
Protection
Agency
(
2822)
1200
Pennsylvania
Avenue,
NW,
Washington,
DC
20460;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Please
include
the
EPA
ICR
number
(
1928.02)
and
OMB
control
number
in
any
correspondence.
August
2,
2000
Information
Collection
Request
for
the
FBRR
25
Appendix
A
DETAILED
BURDEN
AND
COST
ESTIMATES
Appendix
B
RESPONDENT
UNIVERSE/
ACTIVITY
SCHEDULE
