SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

Proficiency Testing Studies for Drinking Water Laboratories

1.  Identification of the Information Collection

1(a)	Title and Number of the Information Collection  TC "1(a)	Title and
Number of the Information Collection" \f C \l "2"   

	

	Proficiency Testing Studies for Drinking Water Laboratories

	

1(b)	Short Characterization  TC "1(b)	Short Characterization" \f C \l
"2"  

This is a request for a new Information Collection Request (ICR) to
support the collection of proficiency testing (PT) data to test the
performance of laboratories that conduct drinking water analyses. Under
40 CFR 141.23(k)(3), 141.131(b)(2), 141.28, and 141.24(f)(17),
laboratories must successfully participate in these PT studies each year
to be certified to conduct analysis of compliance monitoring samples. 
The Primacy Agencies and other certification authorities generally
require annual or more frequent participation in PT studies for other
classes of analytes. 

	Another expiring ICR (Performance Evaluation Studies of Water and
Wastewater Laboratories (OMB Control No. 2080-0021, EPA ICR No.
0234.08)) currently supports not only drinking water PT studies but also
similar studies conducted for wastewater under the Discharge Monitoring
Report – Quality Assurance Study Program (DMRQA).  The United States
Environmental Protection Agency (USEPA or EPA) Office of Ground Water
and Drinking Water (OGWDW) has decided to initiate this new ICR in order
to specifically address the drinking water PT studies.   The ICR for the
DMRQA is being addressed separately. The ICR period is August 2007 –
September 2008.  This ICR period was selected to address these PT –ICR
needs requirements until ICR 2040-0090 is renewed (it expires 9/30/08),
at which point these activities will be incorporated into that renewed
ICR.

	The enforcement of drinking water regulations is conducted by Primacy
Agencies.  These Primacy Agencies are generally the States, but in the
cases where the drinking water utilities are located either in a State
that has not accepted primacy or in a U.S. territory, the EPA Regional
Office for the area serves as the Primacy Agency.  

	Chemical monitoring data for drinking water are submitted by 2,363
laboratories to PT Vendors (9 total) in order to receive certification. 
PT Vendors must certify to the drinking water Primacy Agency that the
laboratories have successfully completed their PT studies.  The
analytical results are stored by the PT providers but are not forwarded
to EPA. This certification of PT study completion is then used by the
Primacy Agencies to support the certification the laboratories to
conduct drinking water compliance analyses.  

EPA initiated this program and originally administered it as part of the
Agency's mandate to assure the quality of environmental monitoring data.
This program has since been privatized.  Private sector companies (i.e.,
PT vendors) manufacture and distribute samples to the participating
laboratories, who then submit their analytical results to these PT
vendors for evaluation.  The PT vendors send evaluations of the
submitted data to the laboratory and the States or other designated
certifying/accrediting authorities.  These data include the names and
addresses of the laboratories, the analytes that were tested, the
concentration of the analyte, and the acceptance criteria and
evaluations.  

EPA is required to conduct this ICR analysis because more than nine
non-Federal entities (i.e., laboratories that conduct drinking water
analyses) will be asked to respond to these data requests.  Because
Primacy Agencies use the resulting data for their own laboratory
certification/ accreditation programs, and are not reporting any
information from the PT studies to EPA, they do not incur any burden
under this ICR.  In addition, cost and burden to PT vendors are not
considered in this ICR because the vendor costs associated with this
program are accounted for in the pricing of their standards (i.e., they
are being paid for their incurred costs via the prices that laboratories
pay for the PT standards).

The total annual burden and labor costs incurred by the 2,363 potential
laboratory respondents associated with this ICR are estimated to be
17,291 hours and $1.80 million per year over the 1.17-year ICR period of
August 2007 – September 2008, or 7.32 hours and $783 per year per
respondent.  Respondent labor costs are associated with the time it
takes to read and understand directions sent by the PT vendors, plan
activities, analyze PT standards, report information to the PT vendors,
and maintain records.  Respondent operating and maintenance (O&M) costs
are associated with purchasing the PT standards.  These non-labor costs
for the PT standards represent the O&M costs of $0.91 million per year
reported in the official Office of Management and Budget (OMB)
inventory.  No costs or burdens to PT vendors or Primacy Agencies are
associated with this ICR. 

2.  Need for and Use of the Collection

2(a)	Need/Authority for the Collection  TC "2(a)	Need/Authority for the
Collection" \f C \l "2"  

Laboratory PT studies are designed to fulfill the need to document and
improve the quality of drinking water analytical data.  Results from the
PT studies over time have generally shown an improvement in average
performance by the laboratories producing these monitoring data.  By
helping laboratories identify and correct analytical problems, the PT
studies are partially responsible for the documented improvement in
these data.

Title XIV of the Public Health Service Act of SDWA requires EPA to
specify contaminants that may adversely affect public health when
present in public water systems (PWSs), specify maximum contaminant
levels for these contaminants, and publish "criteria and procedures to
assure a supply of drinking water which dependably complies with such
maximum contaminant levels."  Section 1413(a) of the SDWA specifies that
the States have the primary enforcement responsibility for PWSs as long
as they have adopted drinking water regulations that are no less
stringent than the National Primary Drinking Water Regulations (NPDWRs).
 Participation in the PT studies that relate to drinking water analyses
is mandated in 40 CFR 141.23(k)(3), 141.24(f)(17), 141.28 and
141.131(b)(2) for those laboratories that report data to support PWS
compliance with the NPDWRs.  Under 40 CFR 142.10(b)(3), authority for
certifying drinking water laboratories is provided to drinking water
Primacy Agencies.

2(b)	Practical Utility/Users of the Data  TC "2(b)	Practical
Utility/Users of the Data" \f C \l "2"   

EPA, States and laboratory personnel will use the results of these
studies to identify laboratory problems for resolution, and thereby
improve the quality of water data in critical monitoring areas.  These
studies have demonstrated that problems exist and arise periodically in
drinking water laboratories; without future studies, many such problems
will go unrecognized and unresolved.  Results from the PT studies are
used by State personnel as a major part of the basis for certifying
laboratories to produce required regulatory data.  

3.  Nonduplication, Consultations, and Other Collection Criteria

3(a)	Nonduplication  TC "3(a)	Non-duplication" \f C \l "2"   

Since there are no other public or private PT programs designed to
evaluate chemical analyses in drinking water there are no other sources
for comparable data.

	

3(b)	Public Notice Required Prior to ICR Submission to OMB  TC "3(b)
Public Notice Required Prior to ICR Submission to OMB" \f C \l "2"  

In compliance with the Paperwork Reduction Act, a notice of this
Information Collection Request ICR was published in the Federal Register
on May 3. 2007. The notice included a request for comments on the
content and impact of these information collection requirements on the
regulated community.  EPA received no comments on this ICR.

3(c)	Consultations

EPA, originally the Office of Research and Development, and now OGWDW,
has over 25 years experience in the overall oversight of these PT
studies.  OGWDW will consider any comments received and make adjustments
that are appropriate.  All nine PT providers are accredited by the
American Association for Laboratory Accreditation (A2LA).  A2LA is a
nonprofit, non-governmental, public service, membership society.  The
mission of A2LA is to provide comprehensive services in laboratory
accreditation and laboratory-related training. 

EPA contacted all nine of the PT providers concerning the cost per
analyte for laboratories participating in their PT studies.  Of the
three vendors that responded, the costs ranged from $10.00 to $22.38,
with an average of $15.46.  EPA used an estimate of $15.00 for the
burden estimates.  While EPA did not specifically request information
from laboratories concerning the costs per analysis used in this burden
effort, EPA is involved in a sufficient number of contracts and other
interactions with laboratories to have reliable estimates for these
routine analysis costs.

3(d)	Effects of Less Frequent Collection  TC "3(d)	Effects of Less
Frequent Collection" \f C \l "2"  

Laboratories producing drinking water compliance monitoring data are
expected to demonstrate adequate analytical proficiency once each year
for each analyte they test.  Several studies are offered each year for
the convenience of the laboratories. This allows the laboratories to
choose the most convenient study in which to participate, or have other
opportunities in the same year to perform successfully in case of any
test failures occurred in the first study they participate in annually. 
Any decrease in frequency would not adequately support the State's
laboratory certification/evaluation programs. 

3(e)	General Guidelines

This ICR was prepared in accordance with the October 2001 version of the
ICR Handbook developed by EPA's Office of Environmental Information,
Office of Information Collection, Collection Strategies Division.  The
ICR Handbook provides the most current instructions for ICR preparation
to ensure compliance with the 1995 Paperwork Reduction Act (PRA)
Amendments and OMB's implementing guidelines. These reporting or
recordkeeping requirements do not violate any of the regulations
promulgated by OMB under 5 CFR part 1320, section 1320.5. 

3(f)	Confidentiality  TC "3(f)	Confidentiality" \f C \l "2"  

This information collection does not require respondents to disclose
confidential information. If a respondent does consider any information
to be of a confidential nature, the respondent may request that such
information be treated as such.  All confidential data will be handled
in accordance with 40 CFR § 122.7, 40 CFR Part 2, and EPA's Security
Manual Part III, Chapter 9, dated August 9, 1976.

3(g)	Sensitive Questions  TC "3(g)	Sensitive Questions" \f C \l "2"  

No questions of a sensitive nature are included in any of the
information collection requirements outlined in this ICR. 

4.  The Respondents and the Information Requested

4(a)	Respondents and NAICS/SIC Codes   TC "4(a)	Respondents and
NAICS/SIC Codes" \f C \l "2"  

Data associated with this ICR are collected and maintained by
laboratories seeking Primacy Agency certification for the analysis of
drinking water samples.  The North American Industry Classification
System (NAICS) designation for laboratories that include environmental
testing is 541380 (Testing Laboratories).  Because Primacy Agencies use
the resulting data for their own laboratory certification programs, and
are not reporting any information from the PT studies to EPA, they do
not incur any burden under this ICR.  In addition, cost and burden to PT
vendors are not considered in this ICR because the vendor costs
associated with this program are accounted for in the pricing of their
standards (i.e., they are being paid for their incurred costs via the
prices that laboratories pay for the PT standards).  Therefore, there is
no cost or burden included for PT vendors or Primacy Agencies because
they are not subject to this ICR. 

4(b)	Information Requested

4(b)(i)   Data Items

In all laboratory PT studies, the data results from the analyses of
synthetic samples that contain known amounts of specific compounds,
usually dissolved in reagent water.  The compounds are those that are
subject to required drinking water monitoring under the NPDWRs.  All
studies also collect sufficient data to properly identify and
characterize the respondents.  Each respondent reports only data for
that portion of the study analytes for which it wishes to be certified.

	The enforcement of drinking water regulations is conducted by Primacy
Agencies.  These Primacy Agencies are generally the States, but in the
cases where the drinking water utilities are located either in a State
that has not accepted primacy or in a U.S. territory, the EPA Regional
Office for the area serves as the Primacy Agency.  Chemical monitoring
data for drinking water are submitted by 2,363 laboratories to PT
Vendors (9 total) in order to receive certification.  PT Vendors must
certify to the drinking water Primacy Agency that the laboratories have
successfully completed their PT studies.  This certification of PT study
completion is then used by the Primacy Agencies to certify the
laboratories to conduct drinking water compliance analyses.  

4(b)(ii)	   Respondent Activities  TC "4(b)(ii)	Respondent Activities"
\f C \l "3"  

The primary burden involves analyzing and reporting results for relevant
study samples according to instructions. Based on information provided
by the Registry of Laboratories Certified for Testing Drinking Water
Parameters, February 1995, the following numbers of laboratories
participated in certification studies:  

1,082 for inorganics; 

871 for disinfectant by-products (DBPs); and 

410 for organic chemicals.  

	Since the PT program has been privatized and since no revisions have
been made to this registry, EPA does not have access to, nor a mechanism
to obtain, more recent data.  EPA did however, contact all nine PT
providers to verify these estimates.  The three PT providers (one third
of the nine providers) that responded to this request for information,
stated that they had a total of 1,090 laboratories participating in PT
studies in 2005.   This information does confirm that EPA’s estimate
of 2,363 laboratories, is reasonable.

	EPA also does not have data on how many of these laboratories
participated in one or more studies.  To provide an estimate of
respondent burden, EPA assumes that a total of 2,363 laboratories will
participate in the PT studies each year during the ICR period of 2007
– 2008.  Some laboratories are assumed to participate in two or three
of these studies (they analyze more than one of the three groups of
analysis; inorganics, DBPs or organics).  This is a conservative
assumption, since it assumes that each group of analytes is tested by an
individual participant, thereby assuming that each participant must
conduct overhead activities (i.e. reading instructions, maintaining
reports, etc.). 

Respondents will participate in the following activities: 

Read Instructions: Each of the 2,363 respondents will read the
instructions provided by the vendor.  

Plan Activities:  Each of the 2,363 respondents will incur burden to
plan activities associated with the PT studies.

Analyze Inorganic Chemicals:  EPA assumes that 1,082 laboratories will
participate in the PT studies for inorganic chemicals.  

Analyze DBPs:  EPA assumes that 871 laboratories will participate in the
PT studies for DBPs.

Analyze Organic Chemicals:  EPA assumes that 410 laboratories will
participate in the PT studies for organic chemicals.  

Report Results:  Each of the 2,363 respondents will incur burden to
report its study results to the PT vendor.  

Maintain Records:  Each of the 2,363 respondents will incur burden to
maintain records associated with the PT study.

5.  The Information Collected – Agency Activities, Collection
Methodology and Information Management

5(a)	Agency Activities  TC "5(a)	Agency Activities" \f C \l "2"  

OGWDW has reduced its activity related to this information collection to
that of providing general guidance and oversight for the Primacy
Agencies, PT vendors and the participating laboratories on an as needed
basis. Three EPA Regional Offices serve as Primacy Agencies for the
certification of drinking water laboratories.  These three EPA Regional
Offices receive the certifications from the PT vendors that laboratories
have or have not passed the vendor supplied PT study which they then use
to determine if these laboratories should be certified to perform
drinking water compliance monitoring.

5(b)	Collection Methodology and Management  TC "5(b)	Collection
Methodology and Management" \f C \l "2"  

The Primacy Agency will notify a laboratory of its requirement to
participate in the relevant PT program annually.  The laboratory will
then select an accredited private PT vendor to provide them with the
appropriate samples.  The laboratory will then send the data obtained
from the analyses of these samples to the vendor, who will then send
evaluations of the submitted data back to the laboratory and to the
Primacy Agency or other designated certifying/accrediting authority.  

	

5(c)	Small Entity Flexibility  TC "5(c)	Small Entity Flexibility" \f C
\l "2"   

The major requirement under Small Business Regulatory Enforcement
Fairness Act (SBREFA) is a regulatory flexibility analysis of all rules
that have a "significant economic impact on a substantial number of
small entities."  Since this data request is not part of a rule, this
ICR is not subject to SBREFA.  

5(d)	Collection Schedule  TC "5(d)	Collection Schedule" \f C \l "2"  

Under 40 CFR 141.23(k)(3), 141.131(b)(2), 141.28, and 141.24(f)(17),
laboratories must successfully participate in these PT studies each year
to be certified to conduct analysis of compliance monitoring samples. 
The Primacy Agencies and other certification authorities generally
require annual or more frequent participation in PT studies for other
classes of analytes.  The participating laboratories demonstrate their
proficiency by passing a PT study conducted by an accredited PT vendor
for a fee.  In order to have sufficient PT studies available, some PT
vendors offer studies quarterly, some less frequently.  The PT vendor
must submit the results of each study, which may be four times per year,
to the Primacy Agency.  

In summary, each participating laboratory must report the results to the
PT vendor once each year during the ICR period of 2007 through 2009. 
The PT vendor must submit the results to the Primacy Agency.  There are
no set calendar dates except that participating laboratories must
successfully participate in an annual PT study for each analyte they
report. 

6.  Estimating the Burden and Cost of the Collection

This section describes the estimated average annual burden and costs for
the information collection activities for PT studies that will be
conducted by drinking water laboratories.  For this data submission,
vendors and Primacy Agencies have no burden and costs; this is discussed
further in Section 6(a).  The burden and cost estimates for drinking
water Primacy Agencies are discussed in detail in Section 6(b).  The
Agency's burden and cost estimates are outlined in Section 6(c).

To estimate the costs, EPA made assumptions about the burden associated
with activities that would likely be needed to fulfill the request.  To
the extent possible, assumptions were based on activities from similar
data collections.  EPA emphasizes that the per-respondent estimates
represent the average burden and cost over the 1.17-year period covered
by this ICR (August 2007-September 2008).  Some respondents may incur
higher costs and some will fall below the average.  Summary burden and
cost estimates for laboratories and EPA are provided in Exhibits 6-1 and
6-2.  Tables that detail the burden estimates to conduct each analysis
are provided in Appendix A. 

6(a)	Estimating Respondent Burden  TC "6(a)	Estimating Respondent
Burden" \f C \l "2"   

The average annual respondent burden (in labor hours) for laboratories
is shown in Exhibit 6-1.  There is no burden for PT vendors or Primacy
Agencies, as discussed in Section 4(a) of this ICR.  Over the ICR years
of August 2007 – September 2008, EPA estimates an average annual
respondent burden (for all respondents in total) of 17,291 hours for
activities associated with this reporting effort; or an average of 7.32
hours per respondent (17,291 hours divided by 2,363 laboratories).  This
estimate includes burden for participating laboratories to read
instructions, plan activities, analyze samples, submit data to the PT
vendors, and maintain records.  

EPA assumes that the respondent burden will be divided among three labor
categories:  manager, chemist, and records clerk.  The labor associated
with each of the ICR activities are discussed in more detail below. 

Read Instructions:  EPA assumes that each of the 2,363 respondents will
require 1.0 hour to read the instructions provided by the vendor.  The
burden will be evenly divided between a manager and chemist.

Plan Activities:  EPA assumes that the manager of each laboratory will
require 0.2 hours to plan activities associated with the PT studies.

Analyze Inorganic Chemicals:  A total of 2,363 laboratories are assumed
to require approximately 3.3 hours to analyze PT standards for 29
inorganic chemicals.  All hours will be incurred by a chemist.

Analyze DBPs:  Chemists in 871 laboratories are assumed to require 2.0
hours to analyze

PT standards for 9 DBPs.  

Analyze Organic Chemicals:  Chemists in 410 laboratories are assumed to
require 16.0 hours to analyze PT standards for 52 organic chemicals.  

Report Results:  EPA assumes that each of the 2,363 respondents will
require 1.0 hours to report the results of the study to the PT vendor. 
The burden will be divided between a manager and records clerk. 

Maintain Records:  EPA assumes that a records clerk in each of the 2,363
laboratories will require 0.1 hours to maintain the files from the PT
study.

6(b)	Estimating Respondent Costs  TC "6(b)	Estimating Respondent Costs"
\f C \l "2"   

Exhibit 6-1 shows the estimated laboratory burden resulting from the
requirement to participate in proficiency testing.  Exhibit 6-2 shows
the annual average costs for laboratories over the ICR period of August
2007 – September 2008.  Average annual labor costs for all 2,363
laboratories are estimated to be $0.895 million.  Average annual O&M
costs are estimated to be $0.91 million.  EPA estimates each laboratory
will incur an annual average labor plus non-labor cost of $763 for this
data collection effort.  Respondent costs are not included for the
Primacy Agencies as their participation in laboratory certification
activities are voluntary.  

6(b)(i)   Respondent Labor

Labor costs are based on information provided by the U.S. Department of
Labor Statistics, May 2005, National Industry Specific Occupational
Employment and Wage Estimate. The labor categories include a manager at
an hourly rate of $52.09, a data entry clerical person at an hourly rate
of $12.71, and a skilled technician or chemist to conduct the
measurements at an hourly rate of $23.65.  The U.S Bureau of Labor
Statistics employer cost for employee compensation (average for 2005) of
$24.36 was added to each of the wage estimates.  Exhibit 6-2 lists the
estimated burden and costs for labor related to each activity.  The
annual respondent labor cost, for all 2,363 respondent/laboratories is
estimated to be $895,288 for 17,291 hours.  

6(b)(ii)   Respondent Operating and Maintenance Costs 

O&M costs for laboratories are all costs related to providing personnel
with the space, equipment, and materials necessary to perform the tasks
required by this ICR.  Since laboratories are driven by their compliance
monitoring requirements to purchase the analytical instrumentation and
computers and not by this ICR, no capital costs can be considered
associated with this ICR.  Only the cost associated with purchasing the
PT standards is appropriate for consideration in this category.  

Laboratories may participate in the PT studies for some or all of the
regulated contaminants.  Because EPA does not does not have sufficient
information to estimate how many analytes are contained in the PT
samples sent to each laboratory, EPA has estimated a "worst case"
scenario by assuming that a single PT sample contains standards for each
possible regulated analyte.  Therefore, laboratories participating in
the inorganic PT study are assumed to receive and run analyses for 29
analytes.  Similarly, those participating in the PT study for DBPs
and/or organic chemicals will receive samples for each of 9 analytes
and/or each of 52 analytes, respectively.  EPA estimates the costs of
each PT standard to be $15 (i.e., $15 per analyte).  Average annual O&M
costs (fees for PT standards) for the respondent laboratories is
estimated to be $908,055.  Refer to Appendix A for a list of inorganic,
DBP, and organic analytes.  

Exhibit 6-  SEQ Exhibit_6- \* ARABIC  1 .  Estimated Laboratory Burden
for Proficiency Testing.

Collection Activities	Manager hours/year	Chemist hours/year	Records
Clerk hours/year	Total hours per Lab	# of Labs 1	Total Average Annual
Burden Hours 

(all respondents)

	(a)	(b)	(c)	(d) =

(a) + (b) + (c)	(e)	(f) = (d)*(e)

Read Instructions	0.5	0.5	0	1.0	2,363	2,363

Plan Activities	0.2	0	0	0.2	2,363	473

Analyze Inorganics	0	3.285	0	3.285	1,082	3,554

Analyze DBPs	0	2.0	0	2.0	871	1,742

Analyze Organics 	0	16.0	0	16.0	410	6,560

Report Results	0.5	0	0.5	1.0	2,363	2,363

Maintain Records	0	0	0.1	0.1	2,363	236

Annual Average Burden	17,291

Annual Average per Respondent Burden	7.32

1 Data from Registry of Laboratories Certified for Testing Drinking
Water Parameters, February 1995.



Exhibit 6-  SEQ Exhibit_6- \* ARABIC  2 .  Estimated Laboratory Cost for
Proficiency Testing.

Collection Activities	Labor Costs	O&M Costs	Total Average Annual Costs

(all respondents)

	Manager at $76.45/hr	Chemist at $48.01/hr	Records Clerk at $37.07/hr
Labor Costs per Respondent	# of Labs	Labor Costs/Year	Standards at
$15/analyte



(a)	(b)	(c)	(d) = (a) + (b) + (c)	(e)	(f) = (d) * (e)	(g) = (e) * $15 *
# of analytes	(h) = (f) + (g)

	hourly rates * labor hours from Exhibit 6-1, columns (a)-(c)





	Read Instructions	$38.23	$24.01	$0.00	$62.23	2,363	$147,050	$0	$147,049

Plan activities	$15.29	$0.00	$0.00	$15.29	2,363	$36,130	$0	$36,130

Analyze Inorganics	$0.00	$157.71	$0.00	$157.71	1,082	$170,645	$470,670
$641,315

Analyze Disinfection Byproducts	$0.00	$96.02	$0.00	$96.02	871	$83,633
$117,585	$201,218

Analyze Organic Chemicals	$0.00	$768.16	$0.00	$768.16	410	$314,946
$319,800	$634,746

Report Results	$38.23	$0.00	$18.54	$56.76	2,363	$134,124	$0	$134,124

Maintain Records	$0.00	$0.00	$3.71	$3.71	2,363	$8,760	$0	$8,760

Average Annual Costs for All Laboratory Respondents	$895,288	$908,055
$1,803,343

Average Annual Costs per Laboratory Respondent	$379	$384	$763

1 Salaries from U.S. Department of Labor Statistics, May 2005, National
Industry Specific Occupational Employment and Wage Estimates. plus U.S.
Department of Labor average estimate of employee compensation for 2005
of $24.36.

2U.S. Department of Labor Statistics, Natural Science Manager 11-9121.

3U.S. Department of Labor Statistics, Chemist 19-2031. 

4U.S. Department of Labor Statistics, Information and Record Clerk
43-4199.

6(c)	Estimating Agency Burden and Costs  TC "6(c)	Estimating Agency
Burden and Costs" \f C \l "2"   

Since EPA's role has been reduced to an advisory level only, there is no
longer any burden to the Agency.

6(d)	Estimating the Respondent Universe and Total Burden and Costs  TC
"6(d)	Estimating the Respondent Universe and Total Burden and Costs" \f
C \l "2"   

	The only respondents for this ICR are laboratories.  This ICR estimates
the number of potential respondents at 2,363.  The total and average
annual burden for these respondents are summarized in Section 6(a) and
Exhibit 6-1.  The total and average annual costs are summarized in
Section 6(b) and Exhibit 6-2.  There are no Agency burden and costs
associated with this ICR. 

6(e)	Bottom Line Burden Hours and Cost Tables  TC "6(e)	Bottom Line
Burden Hours and Cost Tables" \f C \l "2"   

The bottom line burden hours and costs for this ICR are shown in Exhibit
6-3.  This includes the burden and costs to the 2,363 laboratories that
are affected by this ICR. 

Exhibit 6-  SEQ Exhibit_6- \* ARABIC  3 .  Bottom Line Burden and
Costs(for ICR period of 2007-2009).

Cost / Burden	Total Across 1.17 ICR Years

(August 2007-

September 2008)	Average Per Year over

ICR Years

(August 2007-

September 2008)

Number of Respondents (Laboratories)	2,363 	2,363

Total Responses	2,765	2,363

Number of Responses per Lab	1.17 	1

Burden Hours per Lab	8.56	7.32

Total Burden Hours (all 2,363 labs)	23,668	17,291

Hours per Response (Total hours from above/Total responses from above)
8.56	7.32

Per Laboratory Labor Costs	$443	$379

Total Labor Costs (all 2,363 labs)	$1.05 million	$0.895 million

Laboratory O&M Costs	$450	$384

Total O&M Costs (all 2,363 labs)	$1.06 million	$0.908 million

Total Lab Costs (Labor plus O&M costs for all 2,363 labs)	$2.11 million
$1.80 million



		

6(f)	Burden Statement	

The reporting burden for data collections included in this ICR is
detailed above.  The total annual respondent burden (for August 2007 –
September 2008) imposed by these collections is estimated to be 17,291
hours, or 7.32 hours per respondent per year.  Estimates include time
for reading instructions, planning activities, analyzing standards,
reporting results, and maintaining records.

Burden means the total time, effort, or financial resources expended by
persons to generate, maintain, retain, or disclose or provide
information to or for a Federal agency.  This includes the time needed
to review instructions; develop, acquire, install, and utilize
technology and systems for the purposes of collecting, validating, and
verifying information, processing and maintaining information, and
disclosing and providing information; adjust the existing ways to comply
with any previously applicable instructions and requirements; train
personnel to be able to respond to a collection of information; search
data sources; complete and review the collection of information; and
transmit or otherwise disclose the information.  

An agency may not conduct or sponsor, and a person is not required to
respond to, a collection of information unless it displays a currently
valid OMB control number.  The OMB control numbers for EPA's regulations
are listed in 40 CFR part 9 and 48 CFR Chapter 15.   

To comment on the Agency's need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID Number
EPA-HQ-OW-2007-0266, which is available for online viewing at
www.regulations.gov, or in person viewing at the Water Docket in the EPA
Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue,
NW, Washington, D.C.  The EPA Docket Center Public Reading Room is open
from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal
holidays.  The telephone number for the Reading Room is (202) 566-1744,
and the telephone number for the Water Docket is (202) 566-2426.  An
electronic version of the public docket is available at   HYPERLINK
"http://www.regulations.gov"  www.regulations.gov .  This site can be
used to submit or view public comments, access the index listing of the
contents of the public docket, and to access those documents in the
public docket that are available electronically.  When in the system,
select “search,” then key in the Docket ID Number identified above. 
Also, you can send comments to the Office of Information and Regulatory
Affairs, Office of Management and Budget, 725 17th Street, NW,
Washington, D.C. 20503, Attention: Desk Officer for EPA.  Please include
the EPA Docket ID Number EPA-HQ-OW-2007-0266 and OMB Control Number
2040-NEW in any correspondence.

Exhibit A-  SEQ Exhibit_A- \* ARABIC  1 .  Analytical Burden –
Inorganic Chemicals.

Method Type	Analytes	Burden

(in hours for 1 analysis)

Metals (Inductively Coupled Plasma-Mass Spectrometry or Atomic
Absorption)	Aluminum

Antimony 

Arsenic 

Barium

Beryllium

Cadmium 

Chromium 		

Copper 

Lead

Manganese

Mercury 

Nickel 	

Selenium 

Silver

Zinc 			0.33

 (in total)



Ion Chromatography	Fluoride		

Sulfate			

Nitrite-N

Nitrate-N 		0.5

(in total)

	pH

Turbidity 

Alkalinity

Residual Free Chlorine

Total Filterable Residue

Thallium 

Calcium

Sodium	

Total Cyanide	0.083

0.083

0.083

0.05

0.33

0.33

0.083

0.083

0.33

Transmission Electron Microscopy	Asbestos 	1.0

Total	29 Analytes	3.29

Note:  Each PT standard is estimated to be $15.00. Therefore, the cost
to purchase PT standards for all 29 inorganic chemicals would be $435
per laboratory. 



 



Exhibit A-  SEQ Exhibit_A- \* ARABIC  2 .  Analytical Burden –
Disinfectant By-products.

Method Type	Analytes	Burden

(in hours for 1 analysis)

Purge and Trap Mass Spectrometry	Total Trihalomethanes

Chloroform

Bromodichloromethane

Dibromochloromethane

Bromoform

	1.0

Gas Chromatography/

Electron Capture Detector	Haloacetic Acids

Monochloroacetic acid

Dichloroacetic acid

Trichloroacetic acid 

Monobromoacetic acid

Dibromoacetic acid.

	1.0

Total	9 Analytes	2.0

Note:  Each PT standard is estimated to be $15.00. Therefore, the cost
to purchase PT standards for all nine disinfectant by-products would be
$135 per laboratory.



Exhibit A-  SEQ Exhibit_A- \* ARABIC  3 .  Analytical Burden –
Organic Chemicals.

Method Type	Analytes	Burden

(in hours for 1 analysis)

Gas Chromatography/ Mass Spectrometry (GC/MS)

(for synthetic organic chemicals)	Alachlor

Atrazine

Benzo(a)pyrene	

Chlordane

Di(2-ethylhexyl)adipate

Di(2-ethylhexal)phthalate

Endrin

Heptachlor

Heptachlor epoxide	Hexachlorobenzene

Hexachlorocyclobenzene

Hexachlorocyclopentadiene

Lindane

Methoxychlor

Pentachlorbiphenol

Polychlorinated Biphenyls

Simazine

Toxaphene	5.0



High Performance Liquid Chromatography (HPLC) (1)	Carbofuran	Oxamyl	1.0



HPLC (2)	Endothall	1.0



Gas Chromatography/

Electron Capture Detector (GC/ECD) (1)	2,4-D

2,4,5-TP

Dalapon	Dinoseb

Picloram	5.0

GC/ECD (2)	1,2-dibromo-3-chloropropane	Ethylene dibromide	0.5

GC/MS

(for volatile organic compounds)	Benzene

Carbon tetrachloride

Chlorobenzene

1,2-Dichlorobenzene

1,4-Dichlorobenzene

1,2-Dichloroethane

1,1-Dichloroethylene

cis-Dichloroethylene

trans-Dichloroethylene

Dichloromethane

	1,2-Dichloropropane

Ethylbenzene

Styrene

Tetrachloroethylene

Toluene

1,1,1-Trichloroethane

1,1,2-Trichloroethane

Trichloroethylene

1,2,4-Trichlorobenzene

Vinyl chloride

Xylenes	0.5



High Resolution GC/MS	2,3,7,8-TCDD (Dioxin)

1.0

HPLC (3)	Diquat

1.0

HPLC (4)	Glyphosate

1.0

Total	52 Analytes	16.0

Note:  Each PT standard is estimated to be $15.00.  Therefore, the cost
to purchase all 52 organic chemical PT standards would be $780 per
laboratory.



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