
i
TABLE
OF
CONTENTS
1
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
and
Number
of
the
Information
Collection
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1
1(
b)
Short
Characterization
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1
2
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
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4
2(
b)
Use/
Users
of
the
Data
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4
3
NON­
DUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Non­
duplication
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6
3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
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6
3(
c)
Consultations
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6
3(
d)
Effects
of
Less
Frequent
Collection
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7
3(
e)
General
Guidelines
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7
3(
f)
Confidentiality
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7
3(
g)
Sensitive
Questions
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7
4
RESPONDENTS
AND
INFORMATION
REQUESTED
4(
a)
Respondents/
NAICS
Codes
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8
4(
b)
Information
Requested
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8
4(
b)(
i)
Data
Items
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11
4(
b)(
ii)
Respondent
Activities
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11
5
INFORMATION
COLLECTED
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AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
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13
5(
b)
Collection
Methodology
and
Management
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13
5(
c)
Small
Entity
Flexibility
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13
5(
d)
Collection
Schedule
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14
6
ESTIMATING
BURDEN
AND
COST
OF
COLLECTION
6(
a)
Respondent
Burden
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15
6(
a)(
i)
Burden
to
Public
Water
Systems
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15
6(
a)(
ii)
Burden
to
Primacy
Agencies
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16
6(
b)
Respondent
Costs
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16
6(
b)(
i)
Cost
to
Public
Water
Systems
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16
6(
b)(
ii)
Cost
to
Primacy
Agencies
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17
6(
c)
Agency
Burden
and
Costs
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19
6(
d)
Estimating
Respondent
Universe
and
Total
Burden
and
Costs
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19
6(
e)
Bottom
Line
Burden
Hours
and
Costs
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20
6(
f)
Reasons
for
Change
in
Burden
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20
6(
g)
Burden
Statement
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24
ii
LIST
OF
EXHIBITS
Exhibit
1:
PN
Requirements
for
PWSs
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9
Exhibit
2:
PN
Requirements
for
Primacy
Agencies
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10
Exhibit
3:
Annual
PWS
Burden
and
Cost
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18
Exhibit
4:
Annual
Primacy
Agency
Burden
and
Cost
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19
Exhibit
5:
Bottom
Line
Annual
Burden
and
Cost
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20
Exhibit
6:
Adjustments
to
Burden
Hours
from
the
2000
PN
ICR
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23
Exhibit
7:
Adjustments
to
Annual
Burden
Hours
for
the
PWSS
Program
ICR
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23
APPENDICES
Appendix
A
2000
Information
Collection
Request
for
the
Public
Water
System
Supervision
Program
Public
Notification
Requirements
Appendix
B
Federal
Register
Notice
Soliciting
Comments
on
the
Public
Notification
Amendment
to
the
PWSS
Program
ICR
Appendix
C
PN
Burden
and
Cost
Spreadsheets
iii
ACRONYMS
ASDWA
Association
of
State
Drinking
Water
Administrators
BLS
Bureau
of
Labor
Statistics
CCR
Consumer
Confidence
Report
CFR
Code
of
Federal
Regulations
CWS
Community
Water
System
DBPR
Disinfectants
and
Disinfection
Byproducts
Rule
EPA
Environmental
Protection
Agency
FBRR
Filter
Backwash
Recycling
Rule
FR
Federal
Register
FTE
Full
Time
Equivalent
FY
Fiscal
Year
ICR
Information
Collection
Request
IESWTR
Interim
Enhanced
Surface
Water
Treatment
Rule
LCR
Lead
and
Copper
Rule
MCL
Maximum
Contaminant
Level
MRDL
Maximum
Residual
Disinfection
Level
NAICS
North
American
Industry
Classification
System
NCWS
Noncommunity
Water
System
NPDWR
National
Primary
Drinking
Water
Regulation
NTNCWS
Nontransient
Noncommunity
Water
System
O&
M
Operation
and
Maintenance
OGWDW
Office
of
Ground
Water
and
Drinking
Water
OMB
Office
of
Management
and
Budget
PN
Public
Notification
PRA
Paperwork
Reduction
Act
PWS
Public
Water
System
PWSS
Public
Water
System
Supervision
SBREFA
Small
Business
Regulatory
Enforcement
Fairness
Act
SDWA
Safe
Drinking
Water
Act
SDWIS
Safe
Drinking
Water
Information
System
SIC
Standard
Industrial
Classification
SMCL
Secondary
Maximum
Contaminant
Level
SWTR
Surface
Water
Treatment
Rule
TNCWS
Transient
Noncommunity
Water
System
TT
Treatment
Technique
V/
E
Variance
and
Exemption
PWSS
Program
ICR:
PN
Amendment
March
14,
2002
1
This
number
is
derived
from
actual
FY2000
SDWIS
violation
data
and
from
violation
estimates
for
Stage
1
DBPR,
IESWTR,
FBRR,
and
the
Radionuclides
Rule.
For
the
new
rules
(
Stage
1
DBPR,
IESWTR,
FBRR,
and
Radionuclides
Rule),

each
violation
was
assumed
to
occur
at
a
different
PWS.

1
1
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
and
Number
of
the
Information
Collection
Title:
Information
Collection
Request
for
the
Public
Water
System
Supervision
Program:
Public
Notification
Amendment
OMB
Control
Number:
2040­
0090
EPA
Tracking
Number:
0270.41
This
Information
Collection
Request
(
ICR)
amends
the
Public
Water
System
Supervision
(
PWSS)
Program
ICR,
which
was
approved
on
November
28,
2001,
by
adding
updated
burden
estimates
for
the
Public
Notification
(
PN)
Rule.

1(
b)
Short
Characterization
Section
114
of
the
Safe
Drinking
Water
Act
(
SDWA)
of
1996,
enacted
on
August
6,
1996,
amends
Section
1414(
c)(
1)
and
(
c)(
2)
of
the
Act.
The
amendments
affect
the
form,
manner,
frequency,
and
content
of
notices
provided
by
public
water
systems
(
PWSs).
Since
1978,
EPA's
drinking
water
regulations
have
required
PWSs
to
notify
the
persons
served
by
those
systems
about
violations
of
applicable
national
drinking
water
standards,
including
maximum
contaminant
levels
(
MCLs),
treatment
technique
(
TT)
requirements,
and
monitoring
and
testing
procedure
requirements.
PWSs
that
have
been
granted
a
variance
or
an
exemption
(
V/
E)
from
the
primary
drinking
water
regulations
are
also
required
to
provide
notice
that
they
are
operating
under
a
variance
or
exemption.
Additionally,
public
notification
is
required
for
any
failure
to
comply
with
a
variance
or
exemption.
The
regulations
are
codified
in
40
Code
of
Federal
Regulations
(
CFR)
141.32
and
Subpart
Q.

The
2000
PN
Rule
revised
the
minimum
requirements
that
PWSs
must
meet
regarding
the
form,
manner,
frequency,
and
content
of
the
public
notification.
Public
water
systems
must
give
notice
to
all
persons
served
for
all
violations
of
National
Primary
Drinking
Water
Regulations
(
NPDWRs)
and
for
other
situations
posing
a
risk
to
public
health
from
the
drinking
water.

Section
141.2
of
40
CFR
defines
a
PWS
as
"
a
system
for
the
provision
to
the
public
of
water
for
human
consumption
through
pipes
or
other
constructed
conveyances,
if
such
system
has
at
least
fifteen
service
connections
or
regularly
serves
at
least
25
individuals
daily
at
least
60
days
out
of
the
year."
For
this
PN
Amendment,
an
estimated
44,262
of
the
168,302
PWSs
will
have
one
or
more
NPDWR
violations.
1
Overall,
the
44,262
PWSs
with
violations
were
estimated
to
commit
96,041
violations
annually.
Though
not
all
violations
require
a
separate
public
notice,
each
violation
requires
the
PWS
to
comply
with
the
PN
requirements.
PWSS
Program
ICR:
PN
Amendment
March
14,
2002
2
The
form,
manner,
and
frequency
of
the
public
notice
is
determined
by
the
tier
to
which
the
violation
or
situation
is
assigned.
EPA
divides
the
public
notice
requirements
into
three
tiers:


Tier
1
Public
Notice,
for
violations
and
situations
with
significant
potential
to
have
serious
adverse
effects
on
human
health
as
a
result
of
short­
term
exposure.
Tier
1
public
notices
are
required
for
the
presence
of
E.
coli
or
fecal
coliform
in
the
distribution
system,
violation
of
the
MCL
for
nitrate,
nitrite,
or
combined
nitrate
and
nitrite,
exceedance
of
the
nitrate
MCL
in
a
noncommunity
water
system
(
NCWS),
violation
of
the
maximum
residual
disinfection
level
(
MRDL)
for
chlorine
dioxide,
violation
of
the
turbidity
MCL,
occurrence
of
waterborne
disease
outbreak
or
other
waterborne
emergency,
and
other
violations
or
situations
as
determined
by
the
primacy
agency.


Tier
2
Public
Notice,
for
other
violations
and
situations
with
potential
to
have
serious
adverse
effects
on
human
health.
Tier
2
public
notices
are
required
for
all
MCL,
MRDL,
and
TT
violations
that
do
not
require
Tier
1
notification,
monitoring
and
testing
procedure
violations
determined
by
the
primacy
agency,
and
noncompliance
with
requirements
of
a
variance
or
exemption.


Tier
3
Public
Notice,
for
all
other
violations
and
situations
requiring
a
public
notice
and
not
included
in
Tier
1
and
Tier
2.
Tier
3
public
notices
are
also
required
for
operation
under
a
variance
or
exemption,
availability
of
unregulated
contaminant
monitoring
results,
and
exceedance
of
the
fluoride
secondary
MCL.

This
ICR
Amendment
was
prepared
in
accordance
with
the
February
1999
version
of
EPA's
Guide
to
Writing
Information
Collection
Requests
Under
the
Paperwork
Reduction
Act
(
PRA)
of
1995
(
hereafter,
the
"
ICR
Handbook")
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
PRA
amendments
and
Office
of
Management
and
Budget's
(
OMB's)
implementing
guidelines.

This
ICR
Amendment
includes
all
information
collection
requirements
contained
in
the
2000
PN
Rule
and
will
become
part
of
the
PWSS
Program
ICR,
which
was
approved
by
OMB
in
November
2001.
Since
the
PWSS
Program
ICR
estimates
burden
for
calendar
years
2002
through
2004,
this
ICR
Amendment
estimates
burden
and
costs
for
the
remainder
of
calendar
year
2002
(
beginning
July
1,
2002)
and
all
of
calendar
years
2003
and
2004.
This
non­
traditional
method
of
estimating
burden
will
help
to
simplify
the
ICR
process
by
synchronizing
the
three­
year
ICR
accounting
periods
for
the
PWSS
Program
ICR
and
the
PN
Amendment.
Future
renewals
of
the
PWSS
Program
ICR
will
include
PN
burden
for
the
entire
three­
year
ICR
renewal
period.

This
ICR
Amendment
updates
the
burden
and
cost
estimates
provided
in
the
2000
PN
ICR,
which
expires
on
June
30,
2002
(
see
Appendix
A).
As
explained
in
Section
2(
a),
this
ICR
Amendment
includes
all
reporting
and
recordkeeping
requirements
of
the
PN
Rule.
PN
burden
estimates
for
several
new
drinking
water
rules
are
included
in
the
burden
estimate
for
this
ICR
Amendment.
These
new
rules
include
the
Filter
Backwash
Recycling
Rule
(
FBRR)
and
the
2000
Radionuclides
Rule.
Section
6(
f)
summarizes
the
changes
in
burden
from
the
2000
PN
ICR.
PWSS
Program
ICR:
PN
Amendment
March
14,
2002
3
The
total
annual
respondent
burden
associated
with
this
ICR
Amendment
is
estimated
to
be
approximately
0.78
million
hours
per
year.
The
total
annual
respondent
cost
associated
with
this
ICR
Amendment
is
estimated
to
be
approximately
$
23.82
million.
The
distribution
of
annual
burden
between
PWSs
and
primacy
agencies
is
approximately
0.74
million
hours
and
0.04
million
hours,
respectively.
The
distribution
of
annual
costs
between
PWSs
and
primacy
agencies
is
approximately
$
22.59
million
and
$
1.23
million,
respectively.
There
are
no
EPA
costs
or
burden
associated
with
this
ICR
Amendment.

Approximately
$
4.73
million
of
the
$
22.59
million
annual
cost
to
PWSs
is
for
operation
and
maintenance
(
O&
M)
activities.
Primacy
agencies
do
not
incur
any
O&
M
costs
associated
with
the
PN
Rule.
This
$
4.73
million
represents
the
"
cost
burden"
as
reported
in
the
OMB
inventory.
Note
that
these
costs
are
for
O&
M
only;
there
are
no
capital
costs
associated
with
the
activities
covered
by
this
ICR
Amendment.

The
total
number
of
respondents
for
this
ICR
Amendment
is
44,319;
57
of
these
respondents
are
primacy
agencies
and
the
balance
are
PWSs
(
44,262).
The
total
annual
number
of
responses
for
these
respondents
is
250,606
(
109,721
for
PWSs
and
140,885
for
primacy
agencies).
PWSS
Program
ICR:
PN
Amendment
March
14,
2002
4
2
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
This
section
identifies
the
regulatory
or
statutory
authority
for
the
information
collection
activities
covered
in
this
ICR
Amendment
and
describes
why
EPA
needs
the
information.
Section
4
contains
a
summary
of
the
public
notification
recordkeeping
and
reporting
requirements
covered
by
this
ICR
Amendment.

Section
114
of
the
1996
SDWA
Amendments
required
the
EPA
Administrator
to
develop
and
issue
new
regulations
for
public
notification
of
PWS
failure
to
comply
with
applicable
national
drinking
water
standards.
Regulations
mandating
the
form,
manner,
frequency,
and
content
of
public
notification
are
codified
under
40
CFR
Part
141,
Subpart
Q.
Sections
1414(
c)(
2)(
C)(
ii)
and
1414(
c)(
2)(
D)(
ii)
of
the
1996
Amendments
require
that
notices
must
provide
a
clear
and
understandable
explanation
of
the
violation,
the
potential
adverse
health
effects,
and
the
steps
that
the
system
is
taking
to
seek
alternative
water
supplies
until
the
violation
is
corrected.
This
ICR
Amendment
presents
burden
and
costs
for
all
aspects
of
the
preparation
and
delivery
of
these
notices.

2(
b)
Use/
Users
of
the
Data
EPA's
public
notification
regulations
require
PWSs
to
give
notice
of
violations
to
"
all
persons
served"
so
that
consumers
are
aware
of
potential
health
risks.
The
PN
information
is
also
used
to
aid
in
understanding
the
quality
of
drinking
water,
to
make
regulatory
enforcement
decisions,
to
oversee
State
programs,
and
to
make
decisions
regarding
EPA
grants.
This
section
summarizes
the
use
and
users
of
the
data
by
activity
 
The
public
notifications
published
or
distributed
under
the
PN
Rule
are
used
for
the
following
purposes:


To
notify
PWS
customers
if
violations
occur.


To
provide
information
for
protecting
human
health.


To
notify
the
primacy
agency
and
EPA
of
violations.


To
update
the
Safe
Drinking
Water
Information
System
(
SDWIS)
and
other
databases
as
well
as
program
reports
with
current
violation
information.

As
specified
in
Section
141
Subpart
Q,
the
PWS
and
primacy
agency
must
maintain
records
of
public
notifications
made.
Subpart
Q
does
not
specify
information
collection
or
maintenance
requirements
for
EPA
.
PWSS
Program
ICR:
PN
Amendment
March
14,
2002
5
Primary
users
of
the
information
collected
under
this
ICR
Amendment
are
persons
served
by
PWSs.
Other
users
include
Office
of
Ground
Water
and
Drinking
Water
(
OGWDW)
staff,
PWS
managers,
and
primacy
agencies,
which
include
State
regulators,
Indian
Tribes,
and,
in
some
instances,
EPA
Regional
Administrators.
Additional
occasional
users
of
PN
information
include
 

Staff
from
other
EPA
programs
(
such
as
Superfund,
the
Resource
Conservation
and
Recovery
Act,
and
the
Office
of
Enforcement
and
Compliance
Assurance)


Federal
Emergency
Management
Administration

Centers
for
Disease
Control
and
Prevention

Military
bases

Farmers
Home
Administration

Department
of
Interior

Department
of
Housing
and
Urban
Development

U.
S.
Army
Corps
of
Engineers

White
House
Task
Forces

American
Water
Works
Association

Association
of
Metropolitan
Water
Agencies

National
Rural
Water
Association

National
Association
of
Water
Companies

Association
of
State
Drinking
Water
Administrators
(
ASDWA)


Natural
Resources
Defense
Council

Consumers
Federation
of
America

News
organizations
PWSS
Program
ICR:
PN
Amendment
March
14,
2002
6
3
NON­
DUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Non­
duplication
When
violations
of
NPDWRs
occur,
the
public
notification
provisions
of
the
1996
SDWA
Amendments
require
specific
information
to
be
distributed
by
PWSs
to
all
persons
served.
Similar
information
(
e.
g.,
violations,
health
effects)
is
made
available
to
persons
served
by
community
water
systems
(
CWSs)
through
the
Consumer
Confidence
Reports
(
CCRs)
required
by
regulations
issued
under
a
related
SDWA
provision
(
40
CFR
Part
141,
Subpart
O).
Violation
information
is
also
made
available
to
consumers
from
SDWIS,
based
on
quarterly
reporting
to
EPA
from
States
under
primacy
regulations
(
40
CFR
Part
142.15).
In
most
cases,
these
other
sources
of
similar
information
are
not
suitable
for
meeting
the
public
notice
requirements
under
the
statute
and
EPA
regulations
because
the
form,
manner,
content,
and
frequency
of
the
information
does
not
meet
the
minimum
statutory
public
notice
obligation.
To
avoid
duplication
with
the
CCR,
however,
EPA
has
included
a
provision
in
the
PN
regulation
to
allow
CWSs
to
use
the
CCR
to
meet
the
PN
requirements
for
specific
situations.
When
estimating
burden,
this
ICR
Amendment
accounts
for
this
contingency
to
avoid
double
counting
of
burden
and
cost.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
To
comply
with
the
1995
Amendments
to
the
PRA,
EPA
has
solicited
public
comment
on
this
ICR
Amendment
for
a
60­
day
period
before
it
was
submitted
to
OMB.
Specifically,
EPA
has
published
a
notice
in
the
Federal
Register
(
FR)
requesting
comment
on
the
estimated
respondent
burden
and
other
aspects
of
this
ICR
Amendment
(
67
FR
585­
586,
January
4,
2002)
(
See
Appendix
B).
An
additional
Federal
Register
notice
will
be
published
prior
to
submission
of
this
ICR
Amendment
to
OMB.
The
public
comment
period
for
this
additional
notice
is
30
days.

3(
c)
Consultations
When
drafting
the
2000
PN
Rule,
EPA
solicited
from
a
variety
of
sources
input
regarding
the
preparation
and
distribution
of
public
notices.
States
were
involved
early
in
the
regulatory
development
process,
through
attendance
at
meetings
held
in
June
1997.
Representatives
of
primacy
agencies
were
included
in
the
PN
Rule
Working
Group
that
developed
the
regulatory
requirements.
Consultations
were
held
with
stakeholders,
drinking
water
primacy
agencies,
ASDWA,
and
private
firms
providing
information
dissemination
services.
The
following
meetings
were
held
during
the
consultation
process:


Stakeholders
meeting
sponsored
by
OGWDW,
EPA
Region
3,
and
ASDWA.


Stakeholders
meeting
sponsored
by
EPA
Region
10
and
the
Washington
State
Department
of
Health.


Stakeholders
meeting
sponsored
by
the
Indiana
Department
of
Environmental
Management.
PWSS
Program
ICR:
PN
Amendment
March
14,
2002
7

Meeting
with
the
Washington
Drinking
Water
Advisory
Committee.


State
drinking
water
staff
"
Early
Involvement"
meeting,
sponsored
by
ASDWA.


Several
EPA
regulatory
workgroup
meetings,
which
included
four
State
representatives.

3(
d)
Effects
of
Less
Frequent
Collection
EPA
has
carefully
considered
the
burden
imposed
upon
the
regulated
community
in
distributing
public
notifications
and
is
confident
that
those
activities
required
of
respondents
are
necessary.
EPA,
to
the
extent
possible,
has
attempted
to
minimize
the
burden
imposed.
Any
less
frequent
reporting
is
not
possible
because
the
1996
SDWA
Amendments
require
public
notice
for
the
most
serious
violations
to
be
distributed
within
24
hours
and
notices
for
all
other
violations
to
be
distributed
as
soon
as
practicable
based
on
the
seriousness
of
the
violation,
but
in
no
case
later
than
one
year
after
the
violation.
The
statute
also
requires
EPA
to
tailor
the
frequency
of
the
notice
to
the
seriousness
of
the
violation.

3(
e)
General
Guidelines
This
ICR
Amendment
was
prepared
in
accordance
with
the
ICR
Handbook
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
PRA
amendments
and
OMB's
implementing
guidelines.

3(
f)
Confidentiality
No
confidential
information
will
be
collected
as
a
result
of
this
ICR
Amendment.

3(
g)
Sensitive
Questions
No
questions
of
a
sensitive
nature
are
included
in
any
of
the
information
collection
requirements.
PWSS
Program
ICR:
PN
Amendment
March
14,
2002
8
4
RESPONDENTS
AND
INFORMATION
REQUESTED
4(
a)
Respondents/
NAICS
Codes
Data
associated
with
this
ICR
Amendment
are
collected
and
maintained
at
the
PWS,
State,
and
Federal
levels.
Respondents
include
 

Owners/
operators
of
PWSs,
who
issue
public
notices
and
consult
with
the
primacy
agency.


Primacy
agencies
that
must
consult
with
PWSs
regarding
violations
and
notifications.

The
North
American
Industry
Classification
System
(
NAICS)
code
for
PWSs
is
22131.
The
NAICS
code
for
State
agencies
that
include
drinking
water
programs
are
classified
as
92411
(
Administration
of
Air
and
Water
Resources
and
Solid
Waste
Management
Programs)
or
923312
(
Administration
of
Public
Health
Programs).
Ancillary
systems
(
i.
e.,
those
that
supplement
the
function
of
other
establishments
like
factories,
power
plants,
mobile
home
parks,
etc.)
cannot
be
categorized
in
a
single
NAICS
code.
For
ancillary
systems,
the
NAICS
code
is
that
of
the
primary
establishment
or
industry.

4(
b)
Information
Requested
This
ICR
Amendment
covers
requirements
set
forth
in
Section
1414(
c)(
1)
and
(
c)(
2)
of
the
1996
SDWA
amendments.
Regulations
under
40
CFR
Part
141,
Subpart
Q
contain
requirements
for
public
notification.
This
ICR
Amendment
summarizes
the
information
collection
requirements
and
associated
data
items
and
respondent
activities
that
are
contained
in
the
PN
Rule.
Exhibits
2
and
3
summarize
the
respondent
information
collection
requirements
covered
by
this
ICR
Amendment.
PWSS
Program
ICR:
PN
Amendment
March
14,
2002
9
Exhibit
1
PN
Requirements
for
PWSs
REQUIREMENT
REGULATORY
CITATION
REPORT
FREQUENCY/
MINIMUM
RETENTION
TIME
Public
Notification
Notify
persons
served
by
a
PWS
if
certain
violations
and
situations
occur.*
40
CFR
141.201(
a)&(
c)
As
necessary
Notify
persons
served
within
24
hours
of
learning
of
a
violation
which
requires
Tier
1
public
notification.
40
CFR
141.202(
b)(
1)
As
necessary,
within
24
hours
Consult
with
the
primacy
agency
within
24
hours
of
learning
of
a
violation
which
requires
Tier
1
public
notification.
40
CFR
141.202(
b)(
2)
As
necessary,
within
24
hours
Comply
with
any
additional
notification
requirements
for
Tier
1.
40
CFR
141.202(
b)(
3)
As
necessary
Notify
persons
served
within
30
days
of
a
violations
that
requires
Tier
2
public
notification.
40
CFR
141.203(
b)(
1)
As
necessary,
within
30
days
Provide
repeat
notices
for
unresolved
violations
every
three
months,
unless
the
primacy
agency
determines
a
different
frequency.
40
CFR
141.203(
b)(
2)
As
necessary,
every
3
months
Consult
with
the
primacy
agency
if
a
violation
of
the
turbidity
MCL
or
SWTR/
IESWTR
TT
requirements
for
single
exceedances
of
turbidity
limits
occurs.
40
CFR
141.203(
b)(
3)
As
necessary,
within
24
hours
Notify
persons
served
within
one
year
of
learning
of
a
violation
or
situation
that
requires
Tier
3
notification.
40
CFR
141.204(
b)(
1)
As
necessary,
within
1
year
Provide
repeat
notices
annually
for
unresolved
Tier
3
violations/
situations.
40
CFR
141.204(
b)(
1)
As
necessary,
annually
Notify
new
customers
of
ongoing
violations/
situations
prior
to
or
at
the
time
service
begins.*
40
CFR
141.206
As
necessary
Notify
persons
served
of
the
availability
of
the
results
of
unregulated
contaminant
monitoring.
40
CFR
141.207
As
necessary,
within
12
months
of
receiving
results
Provide
special
notice
to
persons
served
for
an
exceedance
of
the
fluoride
secondary
MCL
(
SMCL).
40
CFR
141.208
As
necessary,
within
12
months
of
exceedance
Provide
repeat
notice
of
a
fluoride
SMCL
exceedance,
if
unresolved.
40
CFR
141.208
As
necessary,
annually
Notify
persons
served
by
NCWSs
if
the
primacy
agency
grants
permission
to
exceed
the
nitrate
MCL
40
CFR
141.209
As
necessary,
within
24
hours
Reporting
Submit
a
copy
of
each
notice
provided
(
Tiers
1,
2,
and
3
and
any
repeat
notices)
and
a
certification
that
all
PN
requirements
were
met.
40
CFR
141.31(
d)
and
141.201(
c)(
3)
As
necessary,
within
10
days
after
completing
notification
requirements
Recordkeeping
Retain
copies
of
all
notices
and
certifications.
40
CFR
141.33(
e)
3
years
PWSS
Program
ICR:
PN
Amendment
March
14,
2002
10
*
Content
requirements
for
notices
are
described
in
40
CFR
141.205,
141.207,
and
141.208.

Exhibit
2
PN
Requirements
for
Primacy
Agencies
REQUIREMENT
REGULATORY
CITATION
REPORT
FREQUENCY/
MINIMUM
RETENTION
TIME
Public
Notification
Primacy
agencies
may
exercise
flexibility
in
the
following
areas
as
long
as
they
establish
enforceable
procedures:

Requiring
PWSs
to
notify
persons
served
for
violations
or
situations
other
than
those
requiring
notice
under
the
PN
rule.
Allowing
PWSs
to
limit
distribution
of
a
notice
to
the
portion
of
the
distribution
system
that
is
out
of
compliance.
Elevating
violations/
situations
from
Tiers
2
or
3
to
Tier
1.
Requiring
additional
notification
for
Tier
1
as
a
result
of
the
24­
hour
consultation.
Requiring
or
permitting
a
different
form
of
delivery
than
is
required
in
the
PN
rule
for
Tiers
1,
2,
or
3.
Elevating
monitoring/
testing
procedure
violations
from
Tier
3
to
Tier
2.
Granting
extensions
for
distribution
of
Tier
2
notices.
Allowing
less
frequent
repeat
notification
for
Tier
2.
Consulting
with
PWS
within
24
hours
for
exceedance
of
turbidity
limits.
Determining
the
need
for
multilingual
content
in
a
notice.
40
CFR
142.16(
a)
If
necessary
Consult
with
PWSs
within
24
hours
for
Tier
1
violations/
situations.
40
CFR
141.202(
b)(
2)
As
necessary,
within
24
hours
Consult
with
PWSs
within
24
hours
for
exceedances
of
turbidity
MCL
or
violations
of
turbidity
single
exceedance
limits.
40
CFR
141.203(
b)(
3)
As
necessary,
within
24
hours
May
give
the
required
public
notice
on
behalf
of
the
PWS.
40
CFR
141.210
If
necessary
Reporting
Report
violations
of
the
PN
Rule
to
EPA.
40
CFR
142.15(
a)(
1)
Quarterly
Recordkeeping
Retain
copies
of
certification
and
notices
submitted
by
PWSs.
Also
keep
records
of
determinations
of
alternative
requirements
made
under
40
CFR
142.16.
40
CFR
142.14(
f)
3
years
PWSS
Program
ICR:
PN
Amendment
March
14,
2002
11
4(
b)(
i)
Data
Items
Sections
1414(
c)(
2)(
C)(
ii)
and
1414(
c)(
2)(
D)(
ii)
of
the
1996
Amendments
require
notices
that
provide
a
clear
and
understandable
explanation
of
the
violation
or
situation,
the
potential
adverse
health
effects,
and
the
steps
that
the
system
is
taking
to
seek
alternative
water
supplies
until
the
violation
is
corrected.
Under
the
rule,
PWSs
must
include
the
following
information
in
the
notice:


A
description
of
the
violation
or
situation.


When
the
violation
or
situation
occurred.


Potential
health
effects.


Any
at­
risk
populations.


Whether
alternative
water
supplies
should
be
used.


Any
action
consumers
should
take
to
further
protect
their
health.


Steps
the
PWS
is
taking
to
correct
the
violation
or
situation.


When
the
PWS
expects
to
return
to
compliance.


The
PWS
contact
name,
address,
and
phone
number.


Standard
distribution
language.

The
regulation
also
requires
that
part
or
all
of
the
public
notice
be
multilingual,
if
appropriate.

4(
b)(
ii)
Respondent
Activities
Public
Water
Systems
To
comply
with
the
PN
regulations,
PWSs
must
complete
the
following
activities:


Prepare
the
notice
(
§
§
141.201,
141.205,
141.206,
141.207,
and
141.208).


Distribute
the
notice
to
all
persons
served
within
the
applicable
time
frame
(
§
§
141.202,141.203,
and
141.204).


If
the
violation
or
situation
requires
public
notification
within
24
hours,
consult
with
primacy
agency
within
the
24­
hour
period
to
determine
subsequent
actions
(
§
141.202(
b)(
2)).
Consultation
is
also
required
for
exceedances
of
the
maximum
allowable
turbidity
level
(
§
141.203(
b)(
3)).


If
a
violation
is
unresolved,
prepare
an
updated
notice
for
repeat
distribution
(
§
§
141.205,
141.206,
141.207,
and
141.208).


Distribute
the
updated
notice
(
§
§
141.202,141.203,
and
141.204).


Take
any
additional
actions
required
by
the
primacy
agency
(
§
§
141.201
and
141.202).
PWSS
Program
ICR:
PN
Amendment
March
14,
2002
12

Submit
certification
to
the
primacy
agency
along
with
copies
of
all
public
notifications
that
were
distributed.
Primacy
Agencies
The
PN
Rule
requires
primacy
agencies
to
consult
with
the
violating
PWS
to
determine
appropriate
followup
actions.
Additionally,
the
primacy
agencies
must
receive
and
review
PN
certifications
submitted
by
PWSs.
Primacy
agencies
must
submit
quarterly
reports
of
PN
Rule
violations
to
EPA.

Primacy
agencies
may
give
notice
on
behalf
of
a
PWS
(
§
141.210).
However,
no
data
is
available
for
estimating
the
burden
incurred
by
this
practice.
For
the
purposes
of
this
ICR,
the
burden
for
preparing
and
distributing
public
notification
is
assumed
to
be
incurred
by
the
PWS.
PWSS
Program
ICR:
PN
Amendment
March
14,
2002
2
These
definitions
were
taken
from
Section
601
of
the
Regulatory
Flexibility
Act.

13
5
INFORMATION
COLLECTED
 
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
The
following
section
discusses
how
EPA
or
the
implementing
agency
will
collect
and
manage
the
information
received
from
respondents.
This
section
also
includes
a
discussion
of
how
EPA
has
taken
steps
to
ensure
that
the
information
collections
are
not
overly
burdensome
to
small
entities.

5(
a)
Agency
Activities
The
information
required
of
PWSs
is
intended
to
provide
all
persons
served
with
a
notice
of
any
violations
in
a
manner,
form,
content,
and
frequency
which
allows
informed
health­
related
decision
making.
PWSs
are
required
to
send
copies
of
public
notices
to
the
primacy
agency.
Since
there
is
no
requirement
to
send
the
public
notices
to
EPA,
the
Agency
does
not
review
individual
public
notices.

5(
b)
Collection
Methodology
and
Management
EPA
does
not
receive
public
notices
issued
by
the
PWSs
under
the
PN
Rule.
EPA
has
no
role
or
responsibility
in
collecting,
managing,
distributing,
or
storing
the
public
notification
information
required
under
the
PN
Rule.

5(
c)
Small
Entity
Flexibility
In
developing
this
ICR
Amendment,
EPA
considered
the
requirement
of
the
Small
Business
Regulatory
Enforcement
Fairness
Act
(
SBREFA)
to
minimize
the
burden
of
information
collections
on
small
entities.
Small
entities
include
"
small
businesses,"
"
small
organizations"
and
"
small
government
jurisdictions."
These
terms
are
defined
below.
2

A
small
business
is
any
business
that
is
independently
owned
and
operated
and
not
dominant
in
its
field,
as
defined
by
the
Small
Business
Administration
regulations
under
Section
3
of
the
Small
Business
Act.


A
small
organization
is
any
non­
profit
enterprise
that
is
independently
owned
and
operated
and
not
dominant
in
its
field.


A
small
governmental
jurisdiction
is
the
government
of
a
city,
county,
town,
township,
village,
school
district
or
special
district
that
has
a
population
of
fewer
than
50,000.
This
definition
may
also
include
Indian
Tribes.
PWSS
Program
ICR:
PN
Amendment
March
14,
2002
14
The
major
requirement
under
SBREFA
is
a
regulatory
flexibility
analysis
of
all
rules
that
have
a
"
significant
economic
impact
on
a
substantial
number
of
small
entities."
This
ICR
Amendment
is
not
associated
with
new
rules
and,
therefore,
is
not
subject
to
the
SBREFA.
However,
EPA
realizes
that
some
PWSs
are
small
entities;
therefore,
systems
serving
fewer
than
10,000
persons
are
afforded
several
options
for
delivering
public
notices,
such
as
hand
delivery
and
posting
in
a
prominent
location.

5(
d)
Collection
Schedule
PWSs
that
experience
violations
are
required
to
distribute
public
notices
to
all
persons
served
within
one
of
three
schedules
(
tiers).
Notices
for
violations
that
pose
the
greatest
potential
threat
are
required
within
24
hours,
with
repeat
notices
required
as
deemed
appropriate
by
the
primacy
agency.
Notices
for
less
severe,
but
still
serious,
violations
are
required
within
30
days
(
with
extension
to
three
months
if
allowed
by
the
primacy
agency),
with
repeat
notices
required
quarterly.
Notices
of
minor
and
non­
health­
related
violations
must
be
distributed
within
one
year,
with
repeat
notices
annually.
PWSS
Program
ICR:
PN
Amendment
March
14,
2002
15
6
ESTIMATING
BURDEN
AND
COST
OF
COLLECTION
This
ICR
Amendment
includes
all
information
collection
requirements
of
the
2000
PN
Rule
and
will
become
part
of
the
PWSS
Program
ICR,
which
was
approved
by
OMB
in
November
2001.
Since
the
PWSS
Program
ICR
estimates
burden
for
calendar
years
2002
through
2004,
this
ICR
Amendment
estimates
burden
and
costs
for
the
remainder
of
calendar
year
2002
(
beginning
July
1,
2002)
and
all
of
calendar
years
2003
and
2004
to
synchronize
the
threeyear
ICR
accounting
periods
for
the
PWSS
Program
ICR
and
the
PN
Amendment.
All
burden
and
cost
calculations,
on
which
the
estimates
for
this
ICR
Amendment
were
based,
are
for
July
1,
2002,
through
December
31,
2004.

6(
a)
Respondent
Burden
6(
a)(
i)
Burden
to
Public
Water
Systems
The
average
annual
respondent
burden
(
in
labor
hours)
per
PWS
is
summarized
in
Exhibit
3.
Appendix
C
provides
a
detailed
breakout
of
the
annual
estimated
respondent
burden
for
PWSs.
EPA
estimates
that
the
total
respondent
burden
to
PWSs
for
preparation
and
distribution
of
initial
and
repeat
notices
by
systems
experiencing
violations
is
743,140
hours.

Only
PWSs
with
one
or
more
violations
during
the
year
incur
a
burden.
(
PWSs
with
no
violations
have
no
requirements
under
this
rule.)
The
information
collection
burden
for
systems
that
do
experience
a
violation
is
estimated
to
average
16.8
hours
per
respondent
per
year
(
743,140
hours
divided
by
44,262
systems
in
violation).
This
estimate
includes
time
for
preparing,
copying,
mailing,
submitting,
or
posting
public
notices,
as
well
as
time
for
maintaining
records
of
PN
activities.

In
preparing
this
ICR
Amendment,
EPA
assumed
that
each
PWS
will
deliver
a
public
notice
to
persons
served.
A
"
person
served"
is
defined
as
an
individual
who
normally
receives
water
provided
by
the
PWS.
Under
the
statute,
PWSs
are
required
to
reach
persons
served,
including
those
who
ordinarily
do
not
receive
water
bills
(
e.
g.,
residents
of
apartment
buildings,
students
and
staff
at
schools,
etc.).

Under
the
PN
Rule,
CWSs
providing
a
Tier
1
notice
are
expected
either
to
hand
deliver
the
notice
to
all
residences
or
to
contact
all
electronic
media
outlets
serving
the
affected
community,
including
television
and
radio
stations,
and
submit
a
press
release
to
them.
NCWSs
providing
a
Tier
1
notice
are
likely
to
post
the
notice
or
hand
deliver
the
notice
to
customers.
All
water
systems
are
required
to
take
other
reasonably
calculated
steps
to
ensure
all
the
persons
served
by
the
system
receive
the
notice.
Although
the
rule
does
not
specify
such
actions,
PWSs
are
assumed
to
place
telephone
calls
to
centers
of
sensitive
populations,
such
as
hospitals,
nursing
homes,
and
schools.
Finally,
water
systems
are
expected
to
prepare
a
notice
suitable
for
posting
in
rest
areas,
government­
owned
buildings,
libraries,
and
other
facilities
served
by
the
water
system.

Systems
providing
a
Tier
2
or
Tier
3
notice
must
mail
or
otherwise
directly
deliver
one
notice
to
each
customer.
The
PN
Rule
also
permits
NCWSs
to
post
the
notice
in
lieu
of
direct
PWSS
Program
ICR:
PN
Amendment
March
14,
2002
16
delivery
or
mailing.
All
water
systems
must
also
take
other
reasonably
calculated
steps
to
reach
other
persons
not
reached
by
mail,
direct
delivery,
or
routine
posting.

The
burden
estimate
for
mailing
assumes
that
half
the
CWSs
bill
their
customers
less
frequently
than
every
month,
or
use
postcards
rather
than
envelopes
to
send
bills.
Therefore,
if
a
system
experiences
a
violation
requiring
a
Tier
2
notice
more
than
30
days
prior
to
a
regular
billing
date,
these
CWSs
are
required
to
send
a
separate
mailing
specifically
for
the
public
notice.
Water
systems
that
bill
on
a
monthly
basis
and
do
not
use
postcards,
or
those
sending
out
other
mailings
to
the
customers,
including
annual
CCRs,
will
be
able
to
incorporate
the
notice
as
a
stuffer
in
one
of
the
system's
other
mailings.
Because
the
mailing
alone
will
not
reach
all
persons
served,
the
burden
estimate
includes
other
methods
of
information
dissemination
to
ensure
all
persons
served
receive
the
notice.

6(
a)(
ii)
Burden
to
Primacy
Agencies
The
average
annual
respondent
burden
(
in
labor
hours)
for
primacy
agencies
is
detailed
in
Exhibit
4.
EPA
estimates
that
the
annual
burden
incurred
by
primacy
agencies
for
activities
associated
with
the
Subpart
Q
regulation
is
approximately
42,450
hours.
The
information
collection
burden
for
primacy
agencies
is
estimated
to
average
744.7
hours
per
primacy
agency
(
42,450
hours
divided
by
57).
This
estimate
includes
costs
of
consulting
with
PWSs,
costs
of
reviewing
the
PWS
compliance
certification
and
notice
copies,
costs
of
quarterly
reports
to
EPA,
and
costs
of
filing
and
maintaining
the
PN
records.

6(
b)
Respondent
Costs
6(
b)(
i)
Cost
to
Public
Water
Systems
Exhibit
3
shows
the
total
costs
for
PWSs
over
the
ICR
period,
by
size
and
type
of
system.
Appendix
C
provides
the
detailed
costs
for
each
information
collection
activity.
EPA
estimates
that
the
annual
PWS
cost
for
preparation
and
distribution
of
initial
and
repeat
notices
by
systems
experiencing
violations
is
$
22.59
million.
Approximately
$
4.73
million
annually
is
attributed
to
O&
M
costs;
the
remaining
$
17.86
million
is
attributed
to
labor
costs.

Labor
costs
were
calculated
by
multiplying
the
number
of
burden
hours
by
the
average
hourly
wage
rate,
including
overhead.
The
average
hourly
wage
rate
is
the
rate
quoted
by
the
Bureau
of
Labor
Statistics
(
BLS)
for
Standard
Industrial
Classification
(
SIC)
Code
51­
8031,
"
Local
Government
 
Water
and
Liquid
Waste
Treatment
Plant
and
System
Operators."
The
quoted
rate
was
$
14.69
in
1999
dollars
(
see
http://
stats.
bls.
gov).
For
consistency,
this
rate
has
been
inflated
to
September
2000
dollars
using
the
Employment
Cost
Index.
The
inflated
rate
is
$
15.02.
In
addition,
60
percent
overhead
was
assumed,
bringing
the
loaded
rate
to
$
24.03
in
September
2000
dollars.

PWSs
are
not
expected
to
incur
capital
costs
to
meet
the
PN
requirements.
However,
in
addition
to
the
labor
costs,
there
are
O&
M
costs
associated
with
the
PN
Rule.
These
costs
reflect
non­
labor
costs
associated
with
printing,
delivery,
posting,
and
publishing
public
notices
and
vary
depending
on
the
size
of
the
community
served
by
the
system.
No
copying
or
postage
costs
are
assumed
for
the
inclusion
of
a
notice
as
part
of
an
existing
bill.
The
O&
M
costs
were
carried
PWSS
Program
ICR:
PN
Amendment
March
14,
2002
3
According
to
the
ICR
Handbook,
an
employee
works
an
average
of
2,080
hours
in
one
year;
therefore,
the
hourly
rate
is
determined
by
dividing
the
average
FTE
($
60,
086)
by
2,080
hours
per
year.

4
This
model
was
designed
to
estimate
the
resources
needed
to
fund
State
drinking
water
programs.
It
contains
a
comprehensive
list
of
activities
required
to
operate
a
drinking
water
program,
including
estimates
of
the
number
of
systems
impacted.

17
forward
from
the
2000
PN
ICR,
updated
with
current
cost
information
(
e.
g.,
postage
rates),
and
adjusted
for
inflation.
O&
M
costs
and
associated
calculations
are
presented
in
greater
detail
in
Appendix
C.

6(
b)(
ii)
Cost
to
Primacy
Agencies
Exhibit
4
shows
the
annual
costs
to
primacy
agencies,
which
are
estimated
at
approximately
$
1.23
million.
The
costs
are
exclusively
for
the
42,450
labor
hours
estimated
under
this
ICR
Amendment.
There
are
no
capital,
start­
up,
or
O&
M
costs
associated
with
primacy
agency
information
collection.
The
labor
costs
are
based
on
an
average
full
time
equivalent
(
FTE)
cost
of
$
60,086
including
overhead,
which
equates
to
approximately
$
28.89
per
hour.
3
This
rate,
which
has
been
inflated
to
year
2000
dollars,
is
based
on
the
rate
($
55,000)
suggested
by
the
workgroup
that
developed
the
State
Workload
Model
in
1997.4
PWSS
Program
ICR:
PN
Amendment
March
14,
2002
18
Exhibit
3
Annual
PWS
Burden
and
Cost
Information
Collection
Activity
Annual
Responses
Annual
Hours
Annual
Labor
Costs
Annual
O&
M
Costs
CWS
Systems
serving
<
500
36,434
204,755
$
4,920,266
$
70,499
Systems
serving
501­
3,300
11,622
116,246
$
2,793,397
$
446,067
Systems
serving
3,301­
10,000
3,229
33,262
$
799,292
$
506,758
Systems
serving
10,001­
100,000
2,956
32,354
$
777,460
$
1,543,687
Systems
serving
>
100,000
316
3,634
$
87,330
$
2,153,173
TOTAL
CWS
54,557
390,252
$
9,377,745
$
4,720,185
NTNCWS
Systems
serving
<
500
13,906
88,602
$
2,129,098
$
2,190
Systems
serving
501­
3,300
1,944
12,449
$
299,142
$
1,304
Systems
serving
3,301­
10,000
101
645
$
15,500
$
319
Systems
serving
10,001­
100,000
21
129
$
3,090
$
31
Systems
serving
>
100,000
2
14
$
343
$
0
TOTAL
NTNCWS
15,973
101,838
$
2,447,173
$
3,845
TNCWS
Systems
serving
<
500
38,171
244,507
$
5,875,493
$
6,012
Systems
serving
501
­
3,300
945
6,054
$
145,468
$
654
Systems
serving
3,301­
10,000
58
378
$
9,086
$
45
Systems
serving
10,001
­
100,
000
16
112
$
2,684
$
1
Systems
serving
>
100,000
0
0
$
0
$
0
TOTAL
TNCWS
39,190
251,050
$
6,032,731
$
6,713
TOTAL
ALL
PWS
109,721
743,140
$
17,857,649
$
4,730,742
Note:
Detail
may
not
add
to
totals
due
to
independent
rounding.
PWSS
Program
ICR:
PN
Amendment
March
14,
2002
5
This
is
a
simplifying
assumption.
Primacy
activities
for
Wyoming
and
the
District
of
Columbia
are
actually
carried
out
by
the
respective
EPA
Regional
offices.

19
Exhibit
4
Annual
Primacy
Agency
Burden
and
Cost
Information
Collection
Activity
Number
of
Responses
Hours
per
Response
Annual
Labor
Hours
Annual
Labor
Costs
Tier
1
Consultation
2,140
3.0
6,421
$
185,500
Tier
2
Consultation
17,729
1.1
19,502
$
563,402
Tier
3
Consultation
32,492
0.1
3,249
$
93,869
Review
PN
Certification
44,262
0.2
8,852
$
255,746
File
Reports
44,262
0.1
4,426
$
127,873
TOTAL
140,885
0.3
42,450
$
1,226,390
Note:
Detail
may
not
add
to
totals
due
to
independent
rounding.

6(
c)
Agency
Burden
and
Cost
For
this
ICR
Amendment,
the
incremental
burden
and
cost
for
EPA
information
collection
for
implementing
the
PN
Rule
is
assumed
to
be
negligible.
Neither
PWSs
nor
primacy
agencies
send
public
notices
to
EPA.
Agency
burden
and
costs
for
general
activities,
such
as
compliance
monitoring
and
enforcement
and
other
oversight
activities,
are
already
included
in
the
2001
PWSS
Program
ICR.
Agency
burden
and
costs
associated
with
direct
implementation
of
the
PN
Rule
in
non­
primacy
States
(
Wyoming,
Washington,
D.
C.)
and
Indian
lands
are
included
with
the
primacy
agency
estimates
in
section
6(
a)
and
6(
b).

6(
d)
Estimating
Respondent
Universe
and
Total
Burden
and
Costs
Respondents
for
this
ICR
Amendment
include
both
PWSs
and
primacy
agencies.
This
ICR
Amendment
estimates
that
44,262
PWSs
must
meet
information
collection
requirements
associated
with
public
notification.
All
PWSs
are
not
necessarily
subject
to
each
of
the
information
collection
requirements
contained
in
this
ICR
Amendment.
Appendix
C
describes
in
detail
the
total
PWS
universe
that
is
expected
to
be
subject
to
each
requirement
of
the
PN
Rule.

In
addition
to
the
PWS
respondents,
this
ICR
Amendment
assumes
57
primacy
agencies
(
50
States
plus
the
District
of
Columbia,
U.
S.
territories,
and
the
Navajo
Nation).
5
Therefore,
the
total
number
of
respondents
is
44,319.
The
total
costs
and
burden
for
these
respondents
are
summarized
in
Exhibits
3
and
4.
PWSS
Program
ICR:
PN
Amendment
March
14,
2002
6
This
represents
the
"
cost
burden"
as
reported
in
the
OMB
inventory.
Note
that
there
are
no
capital
costs
associated
with
this
ICR
Amendment.

20
6(
e)
Bottom
Line
Burden
Hours
and
Costs
The
bottom
line
burden
hours
and
costs
appear
in
Exhibit
5.
The
annual
bottom
line
information
collection
burden
to
PWSs
and
primacy
agencies
to
meet
the
information
collection
requirements
of
the
PN
Rule
is
approximately
786,000
hours
and
$
23.82
million.
This
includes
approximately
740,000
hours
and
$
22.59
million
for
PWSs
and
approximately
42,450
hours
and
$
1.23
million
for
primacy
agencies.
O&
M
cost
(
for
PWSs
only)
are
estimated
at
approximately
$
4.73
million.
The
costs
to
primacy
agencies
include
labor
costs
only.
These
burden
and
cost
estimates
include
PWS
and
primacy
agency
burden
only
because
EPA
is
not
expected
to
incur
any
PN­
specific
burden
or
cost
for
the
ICR
period.

Exhibit
5
Bottom
Line
Annual
Burden
and
Cost
Number
of
Respondents
44,319
=
44,262
+
57
Existing
PWSs
Primacy
agencies
Total
Annual
Responses
250,606
=
109,721
+
140,885
PWS
responses
Responses
from
primacy
agencies
Number
of
Responses
per
Respondent
5.6
=
250,606
/
44,319
Total
annual
responses
from
above
Total
respondents
from
above
Total
Respondent
Hours
785,590
=
743,140
+
42,450
PWS
hours
Primacy
agency
hours
Hours
per
Response
3.1
=
785,590
/
250,606
Total
annual
hours
from
above
Total
responses
from
above
Annual
O&
M
Costs6
$
4,731k
=
$
4,731k
Total
PWS
O&
M
costs
Total
Respondent
Cost
$
23,815k
=
$
22,588k
+
$
1,226k
For
PWSs
For
primacy
agencies
Note:
Detail
may
not
add
exactly
to
total
due
to
independent
rounding.

6(
f)
Reasons
for
Change
in
Burden
In
response
to
the
PRA
Amendments
that
required
EPA
to
estimate
third­
party
notification
burden,
such
as
the
burden
associated
with
public
notification,
the
PN
ICR
was
prepared
in
1995
as
an
amendment
to
the
1993
PWSS
Program
ICR.
It
added
1,276,735
burden
hours
for
public
notification
activities,
bringing
the
total
inventory
for
the
1993
PWSS
Program
ICR
to
12,491,282
hours.
PWSS
Program
ICR:
PN
Amendment
March
14,
2002
21
A
1999
change
worksheet
associated
with
the
Lead
and
Copper
Rule
(
LCR)
removed
321,544
hours
of
LCR
burden
associated
with
public
notification
and
public
education,
leaving
955,191
hours
for
non­
LCR
PN
burden
in
the
1993
PWSS
ICR
inventory.
In
2000,
the
PN
Rule
was
revised
and
a
new
stand­
alone
PN
ICR
(
OMB
Control
No.
2040­
0209)
was
prepared.
The
2000
PN
ICR
expires
on
June
30,
2002,
and
this
ICR
Amendment
updates
the
PN
burden
and
costs
for
the
current
PWSS
Program
ICR
approval
period.
Since
the
2000
PN
ICR
accounts
for
all
PN
burden,
the
955,191
hours
of
PN
burden
remaining
in
the
1993
PWSS
Program
ICR
were
removed
when
the
2001
PWSS
Program
ICR
was
approved
by
OMB.

All
existing
rules
with
PN
requirements
were
addressed
in
the
2000
PN
ICR.
This
included
the
following
rules
that
had
been
promulgated,
but
not
yet
implemented,
at
the
time
of
ICR
preparation:
Variance
and
Exemption
(
V/
E)
Rule,
Stage
1
Disinfectant/
Disinfection
Byproducts
Rule
(
DBPR),
and
Interim
Enhanced
Surface
Water
Treatment
Rule
(
IESWTR).
Because
these
rules
were
not
yet
being
implemented,
actual
data
on
the
number
of
violations
for
these
new
rules
were
not
available
in
the
SDWIS
database.
The
2000
PN
ICR
estimated
numbers
of
violations
of
these
rules,
based
on
data
from
ICRs
for
the
Stage
1
DBPR
and
IESWTR,
as
well
as
best
professional
judgement.
The
annual
burden
estimated
in
the
2000
PN
ICR
is
748,811
hours
(
the
current
PN
inventory).

No
other
active
ICRs
contained
PN
burden
estimates;
therefore,
the
2000
PN
ICR
does
not
double
count
burden.
However,
there
is
some
overlap
with
other
rules.
The
PN
Rule
was
written
to
encourage
the
combination
of
public
notification
for
minor
violations
with
the
CCR
or
in
an
annual
report;
therefore,
the
burden
for
PN
is
thought
to
be
less
than
if
all
PN
violations
were
reported
separately.

Exhibit
6
details
the
changes
in
burden
and
cost
estimates
(
both
to
primacy
agencies
and
to
PWSs)
from
the
2000
PN
ICR
to
this
ICR
Amendment.
The
following
changes
account
for
the
difference
in
burden
and
cost
estimates
from
the
2000
PN
ICR:


For
this
ICR
Amendment,
burden
and
costs
for
new
regulations
(
i.
e.,
the
2000
Radionuclides
Rule
and
the
2001
FBRR)
were
added.
Other
new
regulations
will
not
be
implemented
until
after
the
December
2004
expiration
of
this
ICR
Amendment.


Updated
SDWIS
data
were
derived
from
fourth
quarter
2000
frozen
inventory
and
violations
tables.
These
data
were
used
to
update
the
number
of
systems
and
the
number
of
violations
for
regulations
that
are
currently
being
implemented.
Overall,
there
were
fewer
violations
in
2000;
however,
large
systems
had
more
violations.
This
shift
in
violations
to
larger
systems
resulted
in
higher
burden
and
costs
for
PN
distribution.

Additionally,
the
average
number
of
households
per
system
was
updated
using
the
2000
SDWIS
data
and
the
2000
Census
data,
which
indicate
the
average
number
of
people
per
household.


For
new
rules,
violation
estimates
were
derived
from
existing
sources.
For
the
2000
Radionuclides
Rule,
uranium
violations
were
estimated
based
on
existing
violation
rates
for
other
radionuclides.
(
For
other
radionuclides,
existing
violation
data
under
the
1976
PWSS
Program
ICR:
PN
Amendment
March
14,
2002
22
Radionuclides
Rule
were
used.)
Violation
rates
for
the
2001
FBRR
were
estimated
in
the
same
manner
that
violation
rates
for
Stage
1
DBPR
and
IESWTR
were
estimated.


One
average
labor
rate
was
used
for
estimating
PWS
labor
costs.
An
hourly
rate
of
$
14.69
in
1999
dollars
was
estimated,
based
on
BLS
statistics
for
water
treatment
plant
and
wastewater
treatment
plant
operators.
For
consistency,
this
rate
was
adjusted
to
$
15.02
in
September
2000
dollars,
then
loaded
by
60
percent
to
account
for
overhead
costs.


One
average
labor
rate
was
used
for
estimating
primacy
agency
labor
costs.
An
hourly
rate
of
$
28.89
in
2000
dollars
was
estimated.
This
rate
is
already
loaded
to
account
for
overhead
costs.


Postage
rates
have
increased
to
$
0.34
for
first
class
mailings
and
to
$
0.322
for
pre­
sorted
mail
of
greater
than
500
pieces.
These
postage
rates
mirror
those
used
to
estimate
the
CCR
burden
in
the
2001
PWSS
Program
ICR.


In
estimating
the
preparation
and
delivery
burden
for
public
notices,
existing
estimates
were
used.
However,
the
2000
PN
ICR
used
midpoint
values
to
estimate
an
average
burden
across
all
categories.
For
this
ICR
Amendment,
corresponding
burdens
were
used
for
each
size
category.

In
addition,
where
applicable,
Tier
3
preparation
and
delivery
burden
was
updated
to
mirror
the
burden
used
for
CCR
requirements
in
the
2001
PWSS
Program
ICR.


No
primacy
agency
burden
was
included
for
primacy
application
activities,
because
those
activities
were
assumed
to
be
completed
under
the
2000
PN
ICR.
PWSS
Program
ICR:
PN
Amendment
March
14,
2002
23
Exhibit
6
Adjustments
to
Burden
Hours
from
the
2000
PN
ICR
PWSs
and
Primacy
Agencies
Activity
2000
Annual
Burden
Hours
2002
Annual
Burden
Hours
Annual
Change
in
Burden
Hours
Reason
for
Change
in
Burden
Hours
PWSs
690,390
743,140
52,750
A
slight
increase
in
burden
results
from
implementation
of
the
2001
FBRR
and
2000
Radionuclides
Rule.
Additionally,
the
updated
SDWIS
data
contributes
to
the
increased
burden.

Primacy
Agencies
58,420
42,450
(
15,970)
Though
primacy
agencies
will
see
a
slight
increase
in
burden
due
to
implementation
of
the
2001
FBRR
and
the
2000
Radionuclides
Rule,
the
overall
decrease
in
burden
results
from
the
completion
of
start­
up
activities
during
the
previous
ICR
period.

TOTAL
748,811
785,590
36,779
Total
burden
and
change
in
burden
after
adjustments.

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

The
burden
and
cost
estimates
for
this
ICR
Amendment
will
be
added
to
the
2001
PWSS
Program
ICR.
The
affect
of
this
is
detailed
in
Exhibit
7
below.

Exhibit
7
Adjustments
to
Annual
Burden
Hours
for
the
PWSS
Program
ICR
PWSs
and
Primacy
Agencies
Action
Annual
Burden
Hours
Brief
Explanation
N/
A
1,836,258
Opening
Inventory
from
2001
PWSS
Program
ICR
(
2002­
2004).

Add
785,590
This
represents
the
estimated
public
notification
annual
burden
that
EPA
proposes
to
add
to
the
current
inventory.

Total
2,621,848
Proposed
PWSS
Program
ICR
inventory
hours,
including
public
notification.
PWSS
Program
ICR:
PN
Amendment
March
14,
2002
24
6(
g)
Burden
Statement
The
public
reporting
burden
for
collections
included
in
this
ICR
Amendment
is
detailed
above.
The
total
annual
respondent
burden
(
for
July
1,
2002
through
December
31,
2004)
imposed
by
these
collections
is
estimated
to
be
0.78
million
hours,
of
which
0.74
million
hours
are
attributable
to
PWSs
and
0.04
million
hours
to
primacy
agencies.
These
estimates
include
time
for
gathering
information,
as
well
as
developing
and
distributing
public
notices.

Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
people
to
generate,
maintain,
retain,
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
instructions
and
requirements,
train
personnel
to
respond
to
the
information
collection
request,
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
request
for
information
collection
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,
accuracy
of
the
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques
to
Director,
Office
of
Environmental
Information,
Collection
Strategies
Division,
U.
S.
Environmental
Protection
Agency
(
2822T),
Ariel
Rios
Building,
1200
Pennsylvania
Ave.,
N.
W.,
Washington,
D.
C.
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
(
0270.41)
and
OMB
control
number
(
2040­
0090)
in
any
correspondence.
