


 









                               Information Collection Request for the Microbial Rules



                               TABLE OF CONTENTS

1

 IDENTIFICATION OF THE INFORMATION COLLECTION	1

 1(a)
 Title and Number of the Information Collection	1

 1(b)
 Short Characterization	1
2

 NEED FOR AND USE OF THE COLLECTION	3

 2(a)
 Need/Authority for the Collection	3

 2(b)
 Use/Users of the Data	8
3

 NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION


 CRITERIA	9

 3(a)
 Non-duplication	9

 3(b)
 Public Notice Required Prior to ICR Submission to OMB	9

 3(c)
 Consultations	9

 3(d)
 Effects of Less Frequent Collection	9

 3(e)
 General Guidelines	10

 3(f)
 Confidentiality	10

 3(g)
 Sensitive Questions	10
4

 RESPONDENTS AND INFORMATION REQUESTED	11

 4(a)
 Respondents/NAICS Codes	11

 4(b)
 Information Requested	11
5

 INFORMATION COLLECTED -- AGENCY ACTIVITIES, COLLECTION


 METHODOLOGY, AND INFORMATION MANAGEMENT	44

 5(a)
 Agency Activities	44

 5(b)
 Collection Methodology and Management	47

 5(c)
 Small Entity Flexibility	48

 5(d)
 Collection Schedule	50
6

 ESTIMATING BURDEN AND COST OF COLLECTION	52

 6(a)
 Respondent Burden	53

 6(b)
 Respondent Costs	56

 6(c)
 Agency Burden and Costs	59

 6(d)
 Estimating Respondent Universe and Total Burden and Costs	59

 6(e)
 Bottom Line Burden Hours and Costs	60

 6(f)
 Reasons for Change in Burden	62

 6(g)
 Burden Statement	66

                                APPENDICES

Appendix A.   Federal Register Notice Soliciting Comments on Information Collection Requests
 Appendix B.	Consultation Results

                               LIST OF EXHIBITS
Exhibit 1:  Structure of OGWDW ICRs	5
Exhibit 2:  PWS Recordkeeping and Reporting Requirements	12
Exhibit 3:  Primacy Agency Recordkeeping and Reporting Requirements	20
Exhibit 4:  EPA Requirements	46
Exhibit 5:  Collection Schedule	51
Exhibit 6:  Annual PWS Burden and Cost, May 1, 2019  -  April 30, 2022	58
Exhibit 7:  Annual Air Carrier Burden and Cost, May 1, 2019  -  April 30, 2022	58
Exhibit 8:  Annual Primacy Agency Burden and Cost, May 1, 2019  -  April 30, 2022	59
Exhibit 9:  Bottom Line Annual Burden and Cost, May 1, 2019  -  April 30, 2022	61
Exhibit 10: Summary of Changes in Annual Burden (Includes PWS, Air Carrier, and Primacy Agency Burden)	62
Exhibit 11: Restructuring Adjustments to the Annual Burden Inventory for the Microbial Rules ICR (Includes PWS, Air Carrier, and Primacy Agency Burden)	63
Exhibit 12: Adjustments to PWS Burden from Previous ICR Estimates	64
Exhibit 13: Adjustments to Air Carrier Burden from Previous ICR Estimates	64
Exhibit 14: Adjustments to Primacy Agency Burden from Previous ICR Estimates	65
Exhibit 15: Adjustments to Annual Burden Carried Forward from Previous ICR Estimates (Includes PWS, Air Carrier, and Primacy Agency Burden)	66

                                LIST OF FIGURES
 Figure 1:	Structure of OGWDW ICRs	4

                                ACRONYMS


A4A	Airlines For America
ADWR	Aircraft Drinking Water Rule
AMWA	Association of Metropolitan Water Agencies
ARCS	Aircraft Reporting and Compliance System 
ASDWA	Association of State Drinking Water Administrators 
AWWA	American Water Works Association
BLS	Bureau of Labor Statistics
CCP	Composite Correction Program
CCR	Consumer Confidence Report
CDC	Centers for Disease Control and Prevention
CFE	Combined Filter Effluent
CFR	Code of Federal Regulations
CPE	Comprehensive Performance Evaluation
CWS	Community Water System
CWSS	Community Water Systems Survey
DBPR	Disinfectants and Disinfection Byproducts Rule
DWSRF	Drinking Water State Revolving Fund
EPA	Environmental Protection Agency
ESWTR	Enhanced Surface Water Treatment Rule
ETT	Enforcement Targeting Tool
FAA	Federal Aviation Administration
FBRR	Filter Backwash Recycling Rule
FTE	Full Time Equivalent
GWR	Ground Water Rule
GWUDI	Ground Water Under the Direct Influence of Surface Water 
HAA5	Haloacetic Acids
HPC	Heterotrophic Plate Count
ICR	Information Collection Request
IESWTR	Interim Enhanced Surface Water Treatment Rule 
IFA	Individual Filter Assessment
LCR	Lead and Copper Rule
LT1ESWTR	Long Term 1 Enhanced Surface Water Treatment Rule 
LT2ESWTR	Long Term 2 Enhanced Surface Water Treatment Rule 
MCL	Maximum Contaminant Level
MCLG	Maximum Contaminant Level Goal
M-DBP	Microbial Disinfectants and Disinfection Byproducts 
NAICS	North American Industry Classification System
NAWC	National Association of Water Companies
NCWS	Noncommunity Water System
NPDWRs	National Primary Drinking Water Regulations 
NRDC	Natural Resources Defense Council
NRWA	National Rural Water Association
NTU	Nephelometric Turbidity Unit
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
RCAP	Rural Capacity Assistance Partnership
RegNeg	Regulation Negotiation
RFA	Regulatory Flexibility Analysis
RIA	Regulatory Impact Analysis
RTCR	Revised Total Coliform Rule
SBARP	Small Business Advocacy Review Panel
SBREFA	Small Business Regulatory Enforcement Fairness Act 
SCADA	Supervisory Control and Data Acquisition
SDWA	Safe Drinking Water Act
SDWIS	Safe Drinking Water Information System
SER	Small Entity Representative
SOC	Standard Occupational Classification
SWAP	Source Water Assessment Program
SWTR	Surface Water Treatment Rule
TCR	Total Coliform Rule
TNCWS	Transient Noncommunity Water System
TTHM	Total Trihalomethanes
UCMR	Unregulated Contaminant Monitoring Rule
UIC	Underground Injection Control
V&Es	Variances and Exemptions



1	IDENTIFICATION OF THE INFORMATION COLLECTION

1(a)	Title and Number of the Information Collection
      Title:   Information Collection Request for the Microbial Rules 
      OMB Control Number:	2040-0205
      EPA Tracking Number:	1895.10

1(b)	Short Characterization

The Office of Ground Water and Drinking Water (OGWDW) at the U.S. Environmental Protection Agency (EPA) is responsible for developing National Primary Drinking Water Regulations (NPDWRs) as mandated by the Safe Drinking Water Act (SDWA). Section 1412 of the SDWA requires the EPA to establish NPDWRs for contaminants that may adversely impact human health. In section 1414, the Act further requires the EPA to enforce these regulations to ensure that the nation's public drinking water systems dependably comply with the standards stipulated in the Code of Federal Regulations (CFR), 40 CFR Part 141, Subpart B.

Section 1445 of the SDWA stipulates that every public drinking water system (PWS) supplier must conduct monitoring, maintain records, and provide such information as is needed for the EPA to implement its monitoring and enforcement responsibilities with respect to the Act. Forty-nine states[1] have been given primary enforcement responsibility, or primacy, under the SDWA to ensure that PWSs are complying with the requirements of the NPDWRs. The Safe Drinking Water Information System (SDWIS) federal and state databases contain information in conformance with reporting requirements established by the SDWA and related regulations. These data assist the EPA in fulfilling its SDWA obligations. SDWIS assists the EPA in tracking and interpreting violations data and other program-related data. Revisions are currently being made to this system. The EPA expects primacy agencies to fully transition to the revised system, SDWIS Prime, in this ICR period.


 
 
1 Throughout this document, the terms "state" or "states" are used to refer to all types of primacy agencies. There are currently 57 primacy agencies, including the 50 states, the District of Columbia, U.S. territories (Puerto Rico, U.S. Virgin Islands, Guam, American Samoa, and Northern Marianas), and Navajo Nation. Though Wyoming and the District of Columbia do not have primacy, the EPA burden for these activities is counted as primacy agency burden.




This ICR examines PWS, air carrier, primacy agency, and the EPA burden and costs for recordkeeping and reporting required in support of microbial contaminant-associated rulemakings.  The EPA's microbial rules include:

       Surface Water Treatment Rule (SWTR)2
       Total Coliform Rule (TCR)/Revised Total Coliform Rule (RTCR) 
       Interim Enhanced Surface Water Treatment Rule (IESWTR)
       Filter Backwash Recycling Rule (FBRR)
       Long Term 1 Enhanced Surface Water Treatment Rule (LT1ESWTR)
       Long Term 2 Enhanced Surface Water Treatment Rule (LT2ESWTR)
       Ground Water Rule (GWR)
       Aircraft Drinking Water Rule (ADWR)

This ICR estimates burden and costs starting on May 1, 2019, through April 30, 2022, for the rules listed above. This ICR updates the burden and cost estimates provided in the Microbial Rules ICR dated January 2015, which expires on April 30, 2019. The burden and cost estimates for each rule are discussed in greater detail in section 6 of this document.

Continuing costs and burden for microbial rules listed above are evaluated in this ICR. The total annual burden associated with this ICR is estimated to be approximately 18.1 million hours per year. The total annual cost associated with this ICR is estimated to be approximately $972.1 million. The distribution of annual burden between PWSs, air carriers, and primacy agencies is approximately 14.0 million hours, 0.04 million hours, and 4.2 million hours, respectively. The distribution of annual costs between PWSs, air carriers, and primacy agencies is approximately $752.8 million, $1.6 million, and $217.7 million, respectively. There is no EPA burden or cost for this ICR.3 Section 6 details these burden and cost calculations.

The approximate annual operation and maintenance (O&M) and capital costs are $229.0 million ($195.0 million for O&M and $34.0 million for capital). This represents the "cost burden" as reported in the OMB inventory. These costs are for PWSs and air carriers only; primacy agencies do not have capital or O&M costs associated with the Microbial Rules.

The total number of respondents for this ICR is 146,808; 57 of these respondents are primacy agencies, 36 are air carriers, and the balance are existing PWSs (146,715). The total



2 This Microbial Rules ICR includes all SWTR components except disinfectant residual monitoring and associated activities, which are included in the Disinfectants and Disinfection Byproducts, Chemical, and Radionuclides (DDBP/Chem/Rads) Rules ICR (see section 4(b)(i)).

3 The EPA directly implements the ADWR, but the burden and cost for these activities is accounted for in the PWSS Program ICR.



annual number of responses for these respondents is 29.2 million (27.1 million for PWSs, 0.13 million for air carriers and 2.0 million for primacy agencies).

 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 and describes why the EPA needs the information. Section 4 contains a summary of the major recordkeeping and reporting requirements for rules covered by this ICR.

The Microbial Rules ICR includes the following rules addressing microbial contaminants:

       Surface Water Treatment Rule
       Total Coliform Rule/Revised Total Coliform Rule
       Interim Enhanced Surface Water Treatment Rule
       Filter Backwash Recycling Rule
       Long Term 1 Enhanced Surface Water Treatment Rule
       Long Term 2 Enhanced Surface Water Treatment Rule
       Ground Water Rule
       Aircraft Drinking Water Rule

As the EPA publishes new regulations, the EPA will amend the appropriate ICR to include the new rules. 

For a graphical depiction of the structure of the drinking water program ICRs, see Figure 1. A complete itemization of the activities included in the three primary ICRs, as well as other drinking water program ICRs, is included as Exhibit 1.

The information collected under this Microbial Rules ICR is required by the EPA to enable the Agency to carry out its monitoring and enforcement responsibilities as specified under SDWA. Without comprehensive, up-to-date information on microbial contaminants present in drinking water, the EPA would not be able to meet these statutory requirements.

Section 1412(b) authorizes the EPA to establish NPDWRs to protect public health. Section 1445 of the SDWA establishes record keeping requirements for PWSs.   

Section 1401(1)(D) authorizes the EPA to require systems and laboratories to use Agency-approved methods and quality assurance criteria for collecting and analyzing water samples.

 Lab QA 2040-0246
 Lab QA 2040-0246
 Needs Survey 2040-0274
 Needs Survey 2040-0274
 DW SRF 2040-0185
 DW SRF 2040-0185
 SWAP 2040-0197
 SWAP 2040-0197
 Bioterrorism 2040-0253
 Bioterrorism 2040-0253
  UCMR 3
 2040-0270
  UCMR 3
 2040-0270
  UCMR 4
 2040-0270
  UCMR 4
 2040-0270
 Green = Activities remain as in current ICR
 Purple = Future rule to be addressed in stand-alone ICR
 Green = Activities remain as in current ICR
 Purple = Future rule to be addressed in stand-alone ICR
 1 RTCR burden and costs incurred after April 2016 are being added to TCR.
 2 DDBP/Chem/Rads Rules ICR includes disinfectant residual monitoring under SWTR
 3 Includes LCR Short-Term Revisions
 1 RTCR burden and costs incurred after April 2016 are being added to TCR.
 2 DDBP/Chem/Rads Rules ICR includes disinfectant residual monitoring under SWTR
 3 Includes LCR Short-Term Revisions
                                       
                                UIC Program ICR
                                   2040-0042

                                Classes I - VI

                                UIC Program ICR
                                   2040-0042

                                Classes I - VI
 Lab QA 2040-0246
 Lab QA 2040-0246
 Needs Survey 2040-0274
 Needs Survey 2040-0274
 DW SRF 2040-0185
 DW SRF 2040-0185
 SWAP 2040-0197
 SWAP 2040-0197
 Bioterrorism 2040-0253
 Bioterrorism 2040-0253
  UCMR 3
 2040-0270
  UCMR 3
 2040-0270
  UCMR 4
 2040-0270
  UCMR 4
 2040-0270
 Green = Activities remain as in current ICR
 Purple = Future rule to be addressed in stand-alone ICR
 Green = Activities remain as in current ICR
 Purple = Future rule to be addressed in stand-alone ICR
 1 RTCR burden and costs incurred after April 2016 are being added to TCR.
 2 DDBP/Chem/Rads Rules ICR includes disinfectant residual monitoring under SWTR
 3 Includes LCR Short-Term Revisions
 1 RTCR burden and costs incurred after April 2016 are being added to TCR.
 2 DDBP/Chem/Rads Rules ICR includes disinfectant residual monitoring under SWTR
 3 Includes LCR Short-Term Revisions

                                UIC Program ICR
                                   2040-0042

                                Classes I - VI

                                UIC Program ICR
                                   2040-0042

                                Classes I - VI
Figure 1. Structure of OGWDW ICRs
                                 PWSS Program ICR
                                   2040-0090
                                 State Primacy
                                  Activities
                                  Proficiency
                                    Testing
V&E's
CCRs
PN
Cap Dev
Op Cert
 Tribal
Op Cert
Constructed
Conveyances
                               PWSS Program ICR
                                   2040-0090
                                 State Primacy
                                  Activities
                                  Proficiency
                                    Testing
V&E's
CCRs
PN
Cap Dev
Op Cert
 Tribal
Op Cert
Constructed
Conveyances
                              Microbial Rules ICR
                                   2040-0205
FBRR
 TCR/
RTCR1
IESWTR
SWTR 2
LT1
GWR
LT2
ADWR
                              Microbial Rules ICR
                                   2040-0205
FBRR
 TCR/
RTCR1
IESWTR
SWTR 2
LT1
GWR
LT2
ADWR
    
                           DDBP/Chem/Rads Rules ICR
                                   2040-0204
Chems
LCR 3
Stage 1
Arsenic
Rads
Stage 2
                           DDBP/Chem/Rads Rules ICR
                                   2040-0204
Chems
LCR 3
Stage 1
Arsenic
Rads
Stage 2

                       Exhibit 1: Structure of OGWDW ICRs

                               Currently covered
                          To be covered in the future
 PWSS Program ICR (2040-0090)
 Consumer Confidence Reports (CCRs)

 Variances & Exemptions

 Capacity Development Program

 General State Primacy Activities

 Public Notification (PN)

 Operator Certification Expense Reimbursement Grants Program

 Tribal Operator Certification

 Constructed Conveyances

 Proficiency Testing

 Microbial Rules ICR (2040-0205)
 Surface Water Treatment Rule, except disinfectant residual monitoring and associated activities5

 Total Coliform Rule/ Revised Total Coliform Rule

 Interim Enhanced Surface Water Treatment Rule (IESWTR)

 Filter Backwash Recycling Rule

 Long Term 1 Enhanced Surface Water Treatment Rule (LT1ESWTR)

 Long Term 2 Enhanced Surface Water Treatment Rule (LT2ESWTR)

 Ground Water Rule

 Aircraft Drinking Water Rule

 Disinfectants/Disinfection Byproducts, Chemical, and Radionuclides Rules ICR (2040-0204)
 Stage 1 Disinfectants and Disinfection Byproducts Rule
 
 Disinfectant Residual Monitoring and associated activities under the SWTR

 Stage 2 Disinfectants and Disinfection Byproducts Rule
 

 Chemical Phase Rules

 Radionuclides Rule

 Arsenic Rule

 Lead and Copper Rule
Lead and Copper Rule Long Term Revisions
 Source Water Assessment Program (SWAP) ICR (2040-0197)
 SWAP

 Underground Injection Control (UIC) Program ICR (2040-0042)
 UIC Base Program Activities

 Classes I-VI Rule

 Florida Class I Rule

 Drinking Water State Revolving Fund (DWSRF) Program ICR (2040-0185)
 Drinking Water State Revolving Fund Program



 5 Disinfectant residual monitoring and associated activities are included in the DDBP/Chem/Rads Rules ICR.



            Currently covered
         To be covered in the future
 Drinking Water Infrastructure Needs Survey ICR (2040-0274)
 Needs Survey

 Title VI of the Public Health Security and Bioterrorism Preparedness and Response Act of 2002: Drinking Water Security and Safety ICR (2040-0253)
 Vulnerability Assessments and Emergency Response Plans for community water systems (CWSs).

 Unregulated Contaminant Monitoring Rule ICR (2040-0270)
 Monitoring of Unregulated Contaminants (UCMR 3)
 UCMR 4
 Laboratory Quality Assurance Evaluation Program for Analysis of Cryptosporidium ICR (2040- 0246)
 Proficiency Testing Program for Laboratories Analyzing Cryptosporidium Samples



       Surface Water Treatment Rule (SWTR)

Section 1412 (b)(7)(C)(i)) authorizes the EPA to promulgate a NPDWR specifying criteria under which filtration would be required as a treatment technique for PWSs supplied by surface water sources. The EPA considered source water quality; protection afforded by watershed management programs; treatment techniques, such as disinfection practices and length of water storage; and other factors relevant to protection of public health. The requirements for the SWTR included in this ICR help the EPA promote public health through proper operation of filtration techniques. Additional SWTR requirements, such as monitoring and watershed control programs, promote protection of public health in the absence of filtration.

       Total Coliform Rule (TCR)

The SDWA required the EPA to publish maximum contaminant level goals (MCLGs) and promulgate NPDWRs for the 83 contaminants listed in the Advance Notice of Proposed Rulemaking at 47 FR 45502 (March 4, 1982) and 48 FR 45502 (October 5, 1983). This regulation complied with the statutory requirements for regulating total coliforms in all PWSs.

       Revised Total Coliform Rule (RTCR)

The SDWA requires the EPA to review and revise, as appropriate, each existing NPDWR no less often than every six years (SDWA section 1412(b)(9)). In 2003, the EPA completed its review of the 1989 TCR (68 FR 42908, July 18, 2003) and stated its intent to revise the 1989 TCR. The purpose of the review was to identify new health risk assessments, changes in technology, and other factors that would provide a health-related or technological basis to support a regulatory revision. 



The RTCR achieves the objectives of the 1989 TCR by taking into account the changes in the regulatory framework for implementing the SDWA over the past 20 years and experience with the TCR since it was promulgated in 1989.

       Interim Enhanced Surface Water Treatment Rule (IESWTR)

SDWA section 1412(b)(2)(C) required the EPA to promulgate an Interim Enhanced Surface Water Treatment Rule. The IESWTR set the first drinking water standards to control Cryptosporidium in systems serving 10,000 or more customers.

       Filter Backwash Recycling Rule (FBRR)

SDWA section 1412(b)(14) required the EPA to promulgate a regulation to govern the recycling of filter backwash water within the treatment process of a PWS. The FBRR satisfies this regulatory requirement.

       Long Term 1 Enhanced Surface Water Treatment Rule (LT1ESWTR)

 SDWA section 1412(b)(2)(C) required the EPA to develop rules to balance the risks between microbial pathogens and disinfection byproducts. The provisions in the LT1ESWTR address the concerns covered by the IESWTR as they apply to systems serving fewer than 10,000 customers.
      
       Long Term 2 Enhanced Surface Water Treatment Rule (LT2ESWTR)

 SDWA section 1412(b)(2)(C) required the EPA to develop rules to balance the risks between microbial pathogens and disinfection byproducts. The LT2ESWTR builds upon the SWTR, IESWTR, and LT1ESWTR by supplementing existing microbial treatment requirements for systems where additional public health protection is needed. Collectively, the SWTR, IESWTR, LT1ESWTR, and LT2ESWTR place stringent treatment requirements on systems using surface water as a source.

       Ground Water Rule (GWR)

SDWA section 1412(b)(8) required the EPA to publish a national drinking water regulation requiring disinfection of ground water as necessary. The GWR sets conditions where disinfection of ground water is considered necessary. 

       Aircraft Drinking Water Rule (ADWR)

      SDWA section 1411 excludes from regulation any PWS that receives all of its water from another regulated PWS, does not sell or treat the water, and is not a carrier which conveys passengers in interstate commerce. The classes of interstate carrier conveyances (ICCs) include aircraft, trains, buses, and water vessels. As a result, all ICCs that regularly serve water to an average of at least twenty-five individuals daily, at least 60 days per year, are PWSs and are currently subject to existing NPDWRs regardless of whether they treat or sell the water. Water used for human consumption onboard an aircraft must meet the requirements of the SDWA, as with all other PWSs. The EPA promulgated the ADWR to tailor existing health-based drinking water standards to the unique characteristics of an aircraft.

2(b)	Use/Users of the Data

The information described in section 4 of this ICR will be collected by the EPA and made available to the public upon request, as required by the Freedom of Information Act (40 CFR Chapter 1 Part 2). In some cases, the SDWA requires that the information be provided to the public or the primacy agency. Primary users of the data collected under this ICR are the OGWDW, PWS managers, air carriers, and primacy agencies, which include state regulators, tribes, and in some instances, EPA Regional Administrators. Other users include the following:

       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 Agency
       Centers for Disease Control and Prevention (CDC)
       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 (AWWA)
       Association of Metropolitan Water Agencies (AMWA)
       National Rural Water Association (NRWA)
       National Association of Water Companies (NAWC)
       Association of State Drinking Water Administrators (ASDWA)
       Consumer organizations
       News organizations
       
Primacy agencies maintain records compiled from PWS respondents (40 CFR 142.14) and can use these records to track PWS monitoring and compliance violations, as well as enforcement activities. The primacy agency can also track schedules for PWSs trying to achieve compliance.

Primacy agencies report information on PWS violations to SDWIS. This federal information system allows the EPA and states to store and retrieve information over time. Trends in compliance data can be evaluated at the system, state, and national program levels. Usually, these data are used by the EPA for maintaining oversight and to communicate information about the drinking water program.



 NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a)	Non-duplication

The EPA has made an effort to ensure that the data collection efforts associated with this ICR are not duplicated. The EPA consulted with state environmental programs, other federal agencies (such as the CDC), and regulated entities (such as PWSs and their representative industry associations) during the development of each rule discussed in this document. To the best of EPA's knowledge, data currently required by the SDWA, codified under 40 CFR Parts 141 and 142, are not available from any other source.

3(b)	Public Notice Required Prior to ICR Submission to OMB

The EPA solicited public comment on this ICR for a 60-day period before it was submitted to the OMB. The EPA published a notice in the Federal Register on September 11, 2018 (83 FR 45929) requesting comment on the estimated respondent burden and other aspects of this ICR as outlined in Appendix A. The EPA did not receive any comments during the 60-day comment period.

3(c)	Consultations

In November 2018, as part of the revision of the Microbial Rules ICR, the EPA consulted with representatives of PWSs and states regarding the accuracy of the EPA's burden estimates. The groups consulted were NAWC, NRWA, AWWA, AMWA, ASDWA, RCAP, and A4A. The EPA received comments from ASDWA and A4A. ASDWA's comments were general in nature and did not change the burden estimates in this ICR. Incorporation of A4A's comments is discussed in Appendix B.

3(d)	Effects of Less Frequent Collection

The EPA has considered a wide range of alternatives for frequency of data collection. Where possible, the EPA has chosen to require the least frequent collection that remains consistent with overall public health protection objectives. If data are collected less frequently, the primacy agency may not identify, in a timely fashion, significant contaminant concentrations which might threaten the health and safety of drinking water consumers.

For some microbial contaminant regulations, the primacy agency has discretion in adjusting the monitoring schedules. Monitoring schedules vary based on the number of people served by a system, contaminants likely to be found, and source of raw water supply. The monitoring frequency framework also considers that the number of people served affects exposure to contaminants, as well as the resources available to undertake monitoring activity. Monitoring frequencies have been carefully devised based on the following factors:

          Data quality needed for a representative sample.
          Precision and accuracy needed from the representative sample.
          Number of people served by the system.
          Source of the supply (e.g., surface water or ground water).
          Contaminants likely to be found.
          Historical variability in contaminant occurrence.

3(e)	General Guidelines

	This collection conforms to all the general guidelines at 5 CFR 1320.5(d)(2).

3(f)	Confidentiality

	No confidential information will be collected as a result of this ICR.

3(g)	Sensitive Questions

	No information of a sensitive nature concerning sexual behavior or attitudes, religious beliefs, or other matters usually considered private will be collected as a result of this ICR.



 RESPONDENTS AND INFORMATION REQUESTED
      
4(a)	Respondents/NAICS Codes
      
Data associated with this ICR are collected and maintained at the PWS, air carrier, state, and federal levels. Respondents include:

          Owners/operators of PWSs, who must report to the primacy agency.
          All commercial air carriers that fly routes between two or more locations within the United States and whose aircraft meet the definition of a PWS. Air carriers report to the EPA.6
          Primacy agencies, which must report to the EPA.

The North American Industry Classification System (NAICS) code for PWSs is 22131.
The NAICS code for state agencies that include drinking water programs is 92411 (Administration of Air and Water Resources and Solid Waste Management Programs) or 92312 (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. The NAICS codes for air carriers are 481111 and 481211, the codes for scheduled and unscheduled air transportation industries, respectively.

4(b)	Information Requested

Exhibits 2 and 3 summarize the respondent information collection requirements covered by the Microbial Rules ICR. These requirements are also discussed below.

















 
 
6 Note that technically aircraft are PWSs if they serve 25 or more people at least 60 days each year. However, aircraft water systems are not included in the inventory of PWSs contained in SDWIS. The EPA has developed the Aircraft Reporting and Compliance Systems (ARCS) to capture the reporting of aircraft PWS data, pursuant to the ADWR. Additionally, the ADWR applies only to air carriers that own and operate aircraft water systems. Because many air carriers own or operate more than one aircraft, there is not a one-to-one correspondence between aircraft water systems and respondents. For these reasons, for the ADWR standalone ICR, EPA did not group aircraft water systems with PWS respondents (NAICS code 22131). Instead, EPA determined that air carriers were the appropriate respondents. The EPA decided to carry that designation forward as it incorporated the ADWR ICR into the 2012 OMB-approved Microbial Rules ICR.



           Exhibit 2: PWS Recordkeeping and Reporting Requirements

                                  Requirement
                              Regulatory Citation
                              Frequency/Retention
 General Requirements (apply to all regulations)
 Reporting
 Except where a different period is specified in an individual drinking water regulation, PWSs are required to submit the following to the state:


 Results of any test measurement or analysis required in 40 CFR Part 141.
 40 CFR 141.31(a)
 By the end of the required monitoring period
 Failure to comply with any NPDWR.
 40 CFR 141.31(b) and
 (c)
 As necessary, unless state lab performs analysis and reports results directly to state
 Copies of records required to be maintained under 40 CFR 141.33 and/or copies of documents that the state is entitled to under section 1445 of SDWA or state law.
 40 CFR 141.31(e)
 As requested by the state
 Recordkeeping
 Except where a different period is specified in an individual drinking water regulation, PWSs are required to retain the following information:


 Records of bacteriological or chemical analyses and related information.
 40 CFR 141.33(a)
 5 years for bacteriological data; 10 years for chemical data
 Records of actions taken by the PWS to correct violations of NPDWRs.
 40 CFR 141.33(b)
 3 years after last action taken related to the violation
 Copies of any written reports, summaries or communications relating to sanitary surveys.
 40 CFR 141.33(c)
 10 years
 Records concerning a variance or exemption granted.
 40 CFR 141.33(d)
 5 years following the expiration of the variance or exemption
 SWTR (all requirements except those regarding disinfectant residual monitoring)
 Unfiltered Systems  -  Reporting
 Report source water quality information to the state for each month the system serves water to the public.
 40 CFR 141.75(a)(1)(i)
 through (ix)
 Monthly
 Report to the state a summary of PWS compliance with all watershed control program requirements.
 40 CFR 141.75(a)(3)
 Annually
 Report to the state on-site inspections conducted during that year.
 40 CFR 141.75(a)(4)
 Annually
 Report to the state any waterborne disease outbreak potentially attributable to the water system.
 40 CFR 141.75(a)(5)(i)
 As soon as possible but not later than end of the next business day.
 Report to the state any time turbidity exceeds 5 nephelometric turbidity units (NTU).
 40 CFR
 141.75(a)(5)(ii)
 As soon as practical but no later than 24 hours after learning of the exceedance.
 Filtered Systems  -  Reporting





                                  Requirement
                              Regulatory Citation
                              Frequency/Retention
 Report to the state turbidity measurements and associated information for each month the system serves water to the public.
 40 CFR 141.75(b)(1)(i)
 through (iii)
 Monthly
 Report to the state any time turbidity exceeds 5 NTU the PWS.
 40 CFR
 141.75(b)(3)(ii)
 As soon as practical but no later than 24 hours after learning of the exceedance.
 Report to the state any waterborne disease outbreak potentially attributable to that water system.
 40 CFR 141.75(b)(3)(i)
 As soon as possible but not later than end of the next business day.
 TCR
 Reporting
 Prepare written sample siting plan for state review.
 40 CFR 141.21(a)(1)
 As necessary
 Notify the state if fecal coliforms or E. coli
 are present.
 40 CFR 141.21(e)(1)
 By end of the day in which system receives results, or if state office is closed, by end of next business day.
 Report to the state any exceedance of the maximum contaminant level (MCL) for total coliforms.
 40 CFR 141.21(g)(1)
 By end of next business day.
 Report to the state any failure to comply with coliform monitoring requirements.
 40 CFR 141.21(g)(2)
 Within 10 days after discovering the violation.
 Recordkeeping
 Subject to general requirements as listed above.
 RTCR
 Reporting
 Report an E. coli MCL violation to the state.
 40 CFR
 141.861(a)(1)(i)
 By end of the day in which system learns of the violation, or if state office is closed, by end of next business day.
 Report an E. coli-positive sample to the state.
 40 CFR
 141.861(a)(1)(ii)
 By end of the day in which system receives results, or if state office is closed, by end of next business day.
 Report treatment technique violation for total coliforms to the state.
 40 CFR 141.861(a)(2)
 By end of next business day after the system learns of the violation.
 Submit assessment form to the state.
 40 CFR 141.861(a)(3)
 Within 30 days of triggering an assessment and upon completion of each scheduled corrective action for corrections not completed by the time of submission of the assessment form.
 Report a coliform monitoring violation to the state.
 40 CFR 141.861(a)(4)
 Within 10 days after discovering the violation.
 Certify that the system has complied with the state-approved start-up procedure (for seasonal systems only).
 40 CFR 141.861(a)(5)
 As necessary, prior to serving water to the public.
 Recordkeeping



                                  Requirement
                              Regulatory Citation
                              Frequency/Retention
 Any assessment form, documentation of corrective actions completed as a result of assessments, or other available summary documentation of the sanitary defects found and corrective actions taken.
 40 CFR 141.861(b)(1)
 No less than 5 years
 Any repeat sample taken that meets state criteria for an extension of the 24-hour period for collecting repeat samples.
 40 CFR 141.861(b)(2)
 5 years (as required under 40 CFR 141.33(a))
 IESWTR
 Reporting
 A PWS using alternative filtration technologies must demonstrate to the state that the system achieves required removal/inactivation.
 40 CFR 141.173(b)
 As necessary
 A PWS must report combined filter effluent (CFE) turbidity levels for each month that the system serves water to the public.
 40 CFR 141.175(a)(1)
 through (3)
 Monthly
 A PWS must report that it has conducted individual filter turbidity monitoring for each month that the system serves water to the public.
 40 CFR 141.175(b)
 Monthly
 If certain measurement thresholds are exceeded, a PWS must report individual filter turbidity measurements for each month that the system serves water to the public.
 40 CFR 141.175(b)(1)
 through (4)
 As necessary
 Following certain exceedances, a PWS must report to the state the reason for the exceedance or that it has produced a filter profile.
 40 CFR 141.175(b)(1)
 and (2)
 As necessary
 Following certain exceedances, a PWS must report to the state that it has conducted a filter self-assessment.
 40 CFR 141.175(b)(3)
 As necessary
 Following certain exceedances, a PWS must submit to the state a comprehensive performance evaluation (CPE).
 40 CFR 141.175(b)(4)
 As necessary
 If certain CFE measurement thresholds are exceeded, systems must inform the state.
 40 CFR 141.175(c)(1)
 and (2)
 As soon as possible but no later than the end of the next business day.
 A PWS must submit information to the state as part of the required consultation process when making significant changes to disinfection practices.
 40 CFR 141.172(c)(4)
 As necessary
 Recordkeeping
 Systems must maintain the results of individual filter turbidity monitoring.
 40 CFR 141.175(b)
 3 years
 A PWS must retain disinfection profile data in graphic form, as a spreadsheet, or in some other format acceptable to the state for review as part of sanitary surveys conducted by the state.
 40 CFR 141.172(b)(6)
 As necessary




                                  Requirement
                              Regulatory Citation
                              Frequency/Retention
 FBRR
 Recordkeeping
 Collect and retain on file the following recycle flow information for review and evaluation by the state: 1) Copy of the recycle notification and information previously submitted to the state; 2) List of all recycle flows and the frequency with which they are returned; 3) Average and maximum backwash flow rate through the filters and the average and maximum duration of the filter backwash process in minutes; 4) Typical filter run length and a written summary of how filter run length is determined; 5) The type of treatment provided for the recycle flow; and 6) 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.
 40 CFR 141.76(d)(1)
 through (6), 141.33
 10 years
 LT1ESWTR
 Reporting
 A PWS using alternative filtration technologies must demonstrate to the state that the system achieves required removal/inactivation.
 40 CFR 141.552(a)
 As necessary
 A PWS must report CFE turbidity levels for each month that the system serves water to the public.
 40 CFR 141.570(a),
 141.551
 Monthly
 A PWS must report that it has conducted individual filter turbidity monitoring for each month that the system serves water to the public.
 40 CFR 141.570(b)(1),
 141.560(d)
 Monthly
 If certain measurement thresholds are exceeded, a PWS must report individual filter turbidity measurements for each month that the system serves water to the public.
 40 CFR 141.570(b)(2),
 141.560(d), 141.563(a)
 As necessary
 Following certain exceedances, a PWS must report to the state the reason for the exceedance.
 40 CFR 141.570(b)(2),
 141.563(a)
 As necessary
 Following certain exceedances, a PWS must report to the state that it has conducted a filter self-assessment.
 40 CFR 141.570(b)(3)
 As necessary
 Following certain exceedances, a PWS must report to the state that a CPE was triggered.
 40 CFR 141.570(b)(4)
 As necessary
 Following certain exceedances, a PWS must submit to the state a CPE.
 40 CFR 141.570(b)(5)
 and 141.563(c)
 Within 120 days after the CPE was triggered




                                  Requirement
                              Regulatory Citation
                              Frequency/Retention
 Report a description of the proposed change in disinfection, the system's disinfection profile for Giardia lamblia (and, if necessary, viruses) and disinfection benchmark, and an analysis of how the proposed change will affect the current levels of disinfection.
 40 CFR 141.570(d),
 141.542
 As necessary
 Recordkeeping
 Records of individual filter turbidity monitoring measurements.
 40 CFR 141.571(a),
 141.560(e)
 At least 3 years
 Records of disinfection profiles (including raw data and analysis).
 40 CFR 141.571(b),
 141.536
 Indefinitely
 Records of disinfection benchmarking (including raw data and analysis).
 40 CFR 141.571(c)
 Indefinitely
 LT2ESWTR
 Reporting


 Results of E. coli and Cryptosporidium (and turbidity, if applicable) source water monitoring.
 40 CFR 141.706(a)
 Monthly while monitoring is required
 Bin classification (or mean Cryptosporidium level for unfiltered systems).
 40 CFR 141.710(e)(1)-
 (e)(2), 141.712
 6 months after source water monitoring is complete
 Use of uncovered finished water reservoirs and a schedule for covering or disinfecting them.
 40 CFR 141.714(b)
 One time, by April 1, 2008.
 Systems installing technology must demonstrate compliance with technology based criteria.
 40 CFR 141.715
 Varies
 Systems changing disinfection practices must develop a disinfection profile and benchmark for Giardia and viruses.
 40 CFR 141.708-
 141.709
 As necessary
 Sampling schedule.
 40 CFR 141.702
 Once prior to initial monitoring and once during second round of monitoring
 Recordkeeping


 Records of sample results for
 Cryptosporidium, E. coli and turbidity.
 40 CFR 141.706
 At least 3 years
 Systems changing technologies must complete a disinfection profile for Giardia and viruses.
 40 CFR 141.708
 At least 3 years
 Results of treatment monitoring associated with microbial toolbox and with uncovered finished water reservoirs.
 40 CFR 141.722
 At least 3 years
 Notification that systems will not conduct source water monitoring due to having 5- log treatment in place.
 40 CFR 141.722
 At least 3 years
 GWR
 Reporting





                                  Requirement
                              Regulatory Citation
                              Frequency/Retention
 A PWS conducting compliance monitoring must notify the state any time the system fails to meet any state-specified requirements including, but not limited to, minimum residual disinfectant concentration, membrane operating criteria or membrane integrity, and alternative treatment operating criteria, if operation in accordance with the criteria or requirements is not restored within 4 hours.
 40 CFR 141.405(a)
 As soon as possible but no later than the close of the next business day.
 After completing any corrective action, a PWS must notify the state of completion of the corrective action.
 40 CFR 141.405(a)
 Within 30 days.
 If a PWS with a positive TCR sample does not conduct source water monitoring, the system must provide documentation to the state that it met the state criteria for avoiding monitoring.
 40 CFR 141.405(a)
 Within 30 days
 Recordkeeping


 Records of corrective actions.
 40 CFR 141.405(b)
 At least 10 years
 Reports of public notification.
 40 CFR 141.405(b)
 At least 3 years
 Documentation of records of decisions and records of invalidation of fecal indicator-positive ground water source samples.
 40 CFR 141.405(b)
 At least 5 years
 For consecutive systems, documentation of notification to the wholesale system(s) of total-coliform positive samples that are not invalidated.
 40 CFR 141.405(b)
 At least 5 years
 Records of the state-specified minimum disinfectant residual.
 40 CFR 141.405(b)
 At least 10 years
 Records of the lowest daily residual disinfectant concentration and records of the date and duration of any failure to maintain the state-prescribed minimum residual disinfectant concentration for a period of more than 4 hours.
 40 CFR 141.405(b)
 At least 5 years
 Records of state-specified compliance requirements of membrane filtration and of parameters specified by the state for state-approved alternative treatment and records of the date and duration of any failure to meet the membrane operating, membrane integrity, or alternative treatment operating requirements for more than 4 hours.
 40 CFR 141.405(b)
 At least 5 years




                                  Requirement
                              Regulatory Citation
                              Frequency/Retention
 ADWR7
 Reporting


 Development of a sampling plan.
 40 CFR 141.806(a)(1)
 One time, by April 19, 2011 (or for new aircraft, during the first quarter of operation).
 The coliform sampling frequency listed in the sampling plan.
 40 CFR 141.806(a)(1)
 One time, by April 19, 2011 (or for new aircraft, during the first quarter of operation).
 Development of an operations and maintenance plan.
 40 CFR 141.806(a)(1)
 One time, by April 19, 2011 (or for new aircraft, during the first quarter of operation).
 Frequency for routine disinfection and flushing, cited in the operations and maintenance plan.
 40 CFR 141.806(a)(1)
 One time, by April 19, 2011 (or for new aircraft, during the first quarter of operation).
 Inventory information for each aircraft.
 40 CFR 141.806(b)(1)
 One time, by April 19, 2011
 Changes in aircraft inventory.
 40 CFR 141.806(b)(2)
 10 days after the calendar month in which the changes occurred.
 Coliform sampling results.
 40 CFR 141.806(b)(3)
 According to the frequency established in the sampling plan, within 10 days after the sampling period ends.
 Routine disinfection and flushing events.
 40 CFR 141.806(b)(3)
 According to the frequency established in the operations and maintenance plan, within 10 days of the end of the disinfection and flushing period.
 All events requiring notification to passengers or crew, or non-routine disinfection and flushing, or non-routine sampling.
 40 CFR 141.806(b)(4)
 Within 10 days of the event.
 Failure to comply with the monitoring or disinfection and flushing requirements.
 40 CFR 141.806(b)(5)
 Within 10 calendar days of discovery of the failure.
 Changes in disinfection and flushing and coliform sampling frequencies.
 40 CFR 141.806(b)(6)
 No later than 10 days following the calendar month in which the change occurred.
 Evidence of a self-inspection.
 40 CFR 141.806(c)
 Within 90 days of completion of the inspection.
 Whether a deficiency detected during a self-inspection or compliance audit has been corrected, and a schedule if it has not.
 40 CFR 141.806(c)
 Within 90 days of the detection of the deficiency.
 Recordkeeping


 Records of bacteriological analyses.
 40 CFR 141.807(a)
 At least 5 years
 Records of any disinfection and flushing.
 40 CFR 141.807(b)
 At least 5 years
 Records of self-inspections.
 40 CFR 141.807(c)
 At least 10 years
 Sampling plans, such plans must be available for review by the Administrator upon request, including during compliance audits.
 40 CFR 141.807(d)
 None specified; must be maintained and available for review by EPA.



 7 Respondents for ADWR are determined differently than respondents for other rules in the ICR. See previous footnote.



 Requirement
 Regulatory Citation
 Frequency/Retention
 Aircraft water system operations and maintenance plans.
 40 CFR 141.807(e)
 None specified, must be maintained in accordance with Federal Aviation Administration (FAA) requirements and made available for review by EPA.
 Copies of public notices issued to passengers and crew.
 40 CFR 141.807(f)
 At least 3 years



                                   Exhibit 3
            Primacy Agency Recordkeeping and Reporting Requirements

                                  Requirement
                              Regulatory Citation
                      Minimum Frequency/ Retention Period
 General Requirements (apply to all regulations)
 Reporting
 Submit reports to the Administrator containing new violations incurred by the PWSs and enforcement actions initiated by the state during the previous quarter.  
 40 CFR 142.15(a)(1) and (2)
 Quarterly
 Recordkeeping
 Maintain records of tests, measurements, analyses, decisions, and determinations performed on each PWS to determine compliance with applicable provisions of state primary drinking water regulations.
 40 CFR 142.14(a)
 Varies (not less than one year)
 Retain files, which shall include for each PWS in the state reports of sanitary surveys, records of any state approvals, and records of any enforcement actions.
 40 CFR 142.14(d)(2) and (3)
 12 years
 SWTR (all requirements except those regarding disinfection residual monitoring)
 Reporting
 A list of PWSs that includes the name, identification number and date of the determination by the state that the PWS is not required to provide filtration system.  
 40 CFR 142.15(c)(1)(i)(A)
 As necessary
 A list of PWSs that includes the name and identification number for each PWS that the state has determined has no means of having a sample transported and analyzed for heterotrophic plate count (HPC) by a certified laboratory under the requisite time and temperature conditions and is providing adequate disinfection in the distribution system.
 40 CFR 142.15(c)(1)(i)(B)
 As necessary
 Notification of any determination that a PWS is not required to provide filtration treatment.
 40 CFR 142.15(c)(1)(ii)
 Within 60 days of the end of the calendar quarter.
 Recordkeeping
 Records of microbiological analyses.
 40 CFR 142.14(a)(1)
 1 year
 Records of microbiological analyses of repeat or special samples.
 40 CFR 142.14(a)(2)
 1 year
 Records of turbidity measurements.
 40 CFR 142.14(a)(3)
 1 year
 Records of decisions made on a system- by-system and case-by-case basis under provisions of Part 141, Subpart H, Subpart P, or Subpart T. 
 40 CFR 142.14(a)(4)(ii)
 Varies



                                  Requirement
                              Regulatory Citation
                      Minimum Frequency/ Retention Period
 Records of any decision to allow a PWS to substitute a turbidity limit, sample at alternate locations, use continuous monitoring (for unfiltered systems), or reduce sampling sampling frequency or reporting requirements.
 40 CFR
 142.14(a)(4)(ii)(A)(1)
 through (5),(7),(8)
 40 years or until 1 year after the decision is reversed or revised.
 Records of any decision that a violation of the total coliform MCL was not caused by a deficiency in treatment of the source water.
 40 CFR
 142.14(a)(4)(ii)(B)(3)
 One year after the decision is made.
 Records of any decision that total coliform monitoring otherwise required because the turbidity of the source water exceeds 1 NTU is not feasible, except that if such decision allows a system to avoid monitoring without receiving state approval in each instance.
 40 CFR
 142.14(a)(4)(ii)(B)(4)
 One year after the decision is made.
 Records of any decision that a PWS's watershed control program meets the requirements of 141.71(b)(2).
 40 CFR
 142.14(a)(4)(ii)(C)(3)
 Until the next decision is available and filed.
 Records of any decision that an individual is a qualified operator for a PWS using a surface water source or a ground water source under the direct influence of surface water.
 40 CFR
 142.14(a)(4)(ii)(C)(4)
 Until the qualification is withdrawn.
 Records of any decision that a party other than the state is approved to conduct on-site inspections.
 40 CFR
 142.14(a)(4)(ii)(C)(5)
 Until the decision is withdrawn.
 Records of any decision that an unfiltered PWS has been identified as the source of a waterborne disease outbreak, and, if applicable, deficiencies have been addressed to prevent another such occurrence. A copy of the decision must be provided to the system.
 40 CFR
 142.14(a)(4)(ii)(C)(6)
 Until filtration treatment is installed.
 Records of any decision that certain interim disinfection requirements are necessary for an unfiltered PWS for which the state has determined that filtration is necessary, and a list of those requirements. A copy of the requirements must be provided to the system.
 40 CFR
 142.14(a)(4)(ii)(C)(7)
 Until filtration treatment is installed.
 Records of any decision that automatic shut-off of delivery of water to the distribution system of an unfiltered PWS would cause an unreasonable risk to health or interfere with fire protection.
 40 CFR
 142.14(a)(4)(ii)(C)(8)
 Until rescinded.



                                  Requirement
                              Regulatory Citation
                      Minimum Frequency/ Retention Period
 Records of any decision that a PWS may use alternative filtration technology because it consistently achieves 99.9 percent removal and/or inactivation of Giardia lamblia cysts and 99.99 percent removal and/or inactivation of viruses. A copy of the decision must be provided to the PWS.
 40 CFR
 142.14(a)(4)(ii)(C)(11)
 Until the decision is reversed or revised.
 Records of any decision that a system using a ground water source is under the direct influence of surface water.
 40 CFR
 142.14(a)(4)(ii)(C)(14)
 40 years
 Records of any determination that a PWS supplied by a surface water source or a ground water source under the direct influence of surface water is not required to provide filtration treatment. A copy of the determination must be provided to the system.
 40 CFR
 142.14(a)(4)(ii)(C)(14)(iii)
 40 years or until withdrawn, whichever is earlier.
 Records of analysis for other than microbiological contaminants (including total coliform, fecal coliform, and HPC), residual disinfectant concentration, other parameters necessary to determine disinfection effectiveness.
 40 CFR 142.14(a)(6)
 12 years
 Special Primacy Requirements
 An application for approval of a state program revision that adopts 40 CFR Part 141, Subpart H Filtration and Disinfection.
 40 CFR 142.16(b)
 One time
 TCR
 Reporting
 Reports to the Administrator containing a list of PWSs that the state is allowing to monitor less frequently than once per month for CWSs or less frequently than once per quarter for Noncommunity Water Systems (NCWSs).
 40 CFR 142.15(c)(2)
 One time; update as needed.
 Recordkeeping


 Records of microbiological analyses.
 40 CFR 142.14(a)(1)
 1 year
 Records of microbiological analyses of repeat or special samples.
 40 CFR 142.14(a)(2)
 1 year
 Records of any decision to waive the 24- hour time limit for collecting repeat samples after a total coliform-positive routine sample.
 40 CFR 142.14(a)(5)(i)(A)
 5 years
 Records of any decision to allow a system to waive the requirement for five routine samples the month following a total coliform-positive sample.
 40 CFR 142.14(a)(5)(i)(B)
 5 years
 Records of any decision to invalidate a total coliform-positive sample.
 40 CFR 142.14(a)(5)(i)(C)
 5 years



                                  Requirement
                              Regulatory Citation
                      Minimum Frequency/ Retention Period
 Records of any decision to reduce the total coliform monitoring frequency for certain CWSs to less than once per month. A copy of the reduced frequency decision must be provided to the system.
 40 CFR 142.14(a)(5)(ii)(A)
 Retain in such a manner that a system's current status may be determined.
 Records of any decision to reduce the total coliform monitoring frequency for certain NCWSs to less than once per quarter. A copy of the reduced frequency decision must be provided to the system.
 40 CFR 142.14(a)(5)(ii)(B)
 Retain in such a manner that a system's current status may be determined.
 Records of any decision to reduce the total coliform monitoring frequency for certain NCWSs during any month the system serves 1,000 persons or fewer. A copy of the reduced frequency must be provided to the system.
 40 CFR 142.14(a)(5)(ii)(C)
 Retain in such a manner that a system's current status may be determined.
 Records of any decision to waive the 24- hour limit for taking a total coliform sample for PWSs that do not practice filtration in accordance with Part 141, Subpart H, and that measure a source water turbidity level exceeding 1 NTU near the first service connection.
 40 CFR 142.14(a)(5)(ii)(D)
 Retain in such a manner that a system's current status may be determined.
 Records of any decision that certain NCWSs may reduce the frequency of their sanitary survey to less than once every five years, along with a record of the reduced frequency. A copy of the reduced frequency decision must be provided to the system.
 40 CFR 142.14(a)(5)(ii)(E)
 Retain in such a manner that a system's current status may be determined.
 A list of agents other than the state, if any, approved to conduct sanitary surveys.
 40 CFR 142.14(a)(5)(ii)(F)
 Retain in such a manner that a system's current status may be determined.
 Records of any decision to allow a PWS to forgo fecal coliform or E. coli testing on a total coliform-positive sample if that system assumes that the total coliform- positive sample is fecal coliform-positive or E. coli-positive.
 40 CFR 142.14(a)(5)(ii)(G)
 Retain in such a manner that a system's current status may be determined.
 RTCR
 Reporting
 A list of systems that the state is allowing to monitor under a reduced monitoring frequency.
 40 CFR 142.15(c)(3)
 Not specified
 Recordkeeping
 Any case-by-case decision to waive or extend the 24-hour time limit for collecting repeat samples following a total coliform- positive routine sample, sample invalidation, or (for unfiltered systems) a high turbidity measurement.
 40 CFR
 142.14(a)(10)(i)(A)
 5 years



                                  Requirement
                              Regulatory Citation
                      Minimum Frequency/ Retention Period
 Any decision to allow a system to waive the requirement for three routine samples the month following a total coliform- positive sample.
 40 CFR
 142.14(a)(10)(i)(B)
 5 years
 Any decision to invalidate a total coliform- positive sample.
 40 CFR
 142.14(a)(10)(i)(C)
 5 years
 Completed and approved Level 1 and/or Level 2 assessments, including reports from the system that corrective action has been completed.
 40 CFR
 142.14(a)(10)(i)(D)
 5 years
 Any decision to reduce the total coliform monitoring frequency for a NCWS using only ground water and serving 1,000 or fewer people to less than once per quarter.
 40 CFR
 142.14(a)(10)(ii)(A)
 Retain in such a manner that a system's current status may be determined.
 Any decision to reduce the total coliform monitoring frequency for a CWS serving 1,000 or fewer people to less than once per month.
 40 CFR
 142.14(a)(10)(ii)(B)
 Retain in such a manner that a system's current status may be determined.
 Any decision to reduce the total coliform monitoring frequency for a NCWS using only ground water and serving more than 1,000 people during any month the system serves 1,000 or fewer people
 40 CFR
 142.14(a)(10)(ii)(C)
 Retain in such a manner that a system's current status may be determined.
 Any decision to allow a system to forgo E. coli testing of a total coliform-positive sample if that system assumes that the total coliform-positive sample is E. coli- positive.
 40 CFR
 142.14(a)(10)(ii)(D)
 Retain in such a manner that a system's current status may be determined.
 IESWTR
 Reporting
 A list of Subpart H systems that have had a sanitary survey completed during the previous year and an annual evaluation of the state's program for conducting sanitary surveys.
 40 CFR 142.15(c)(5)
 Annually
 Recordkeeping
 Records of turbidity measurements.
 40 CFR 142.14(a)(3)
 1 year
 Records of decisions made on a system- by-system and case-by-case basis under provisions of Part 141, Subpart H, Subpart P, or Subpart T.
 40 CFR 142.14(a)(4)(ii)
 As necessary



                                  Requirement
                              Regulatory Citation
                      Minimum Frequency/ Retention Period
 Records of systems consulting with the state concerning a significant modification to their disinfection practice (including the status of the consultation).
 40 CFR 142.14(a)(7)(i)
 As necessary
 Records of decisions that a system using alternative filtration technologies can consistently achieve a 2-log (99 percent) removal of Cryptosporidium oocysts, as well as the required levels of removal and/or inactivation of Giardia and viruses for systems using alternative filtration technologies.
 40 CFR 142.14(a)(7)(ii)
 As necessary, kept until decision is reversed or revised.
 Records of systems required to conduct a filter self-assessment, CPE or composite correction program (CCP).
 40 CFR 142.14(a)(7)(iii)
 As necessary
 FBRR
 Reporting
 Subject to general requirements as listed above.
 Recordkeeping
 Records of any decisions made to approve alternate recycle locations.
 40 CFR
 142.14(a)(4)(ii)(A)(9)
 40 years or until 1 year after decision is reversed or revised.
 LT1ESWTR
 Reporting
 Subject to general requirements as listed above.
 Recordkeeping
 Records of turbidity measurements.
 40 CFR 142.14(a)(3)
 Not less than one year.
 Records of decisions made on a system- by-system and case-by-case basis under provisions of Part 141, Subpart H, Subpart P, or Subpart T.
 40 CFR 142.14(a)(4)(ii)
 As necessary
 Records of systems consulting with the state concerning a significant modification to their disinfection practice (including the status of the consultation).
 40 CFR 142.14(a)(7)(i)
 As necessary
 Records of decisions that a system using alternative filtration technologies can consistently achieve a 2-log (99 percent) removal of Cryptosporidium oocysts, as well as the required levels of removal and/or inactivation of Giardia and viruses for systems using alternative filtration technologies.
 40 CFR 142.14(a)(7)(ii)
 As necessary
 Records of those systems required to conduct a filter self-assessment, CPE or CCP.
 40 CFR 142.14(a)(7)(iii)
 As necessary
 LT2ESWTR
 Reporting


 The bin classification after the initial and after the second round of source water monitoring for each filtered system.
 40 CFR 142.15(c)(6)
 After each round of monitoring.
 Any change in treatment requirements for these systems due to watershed assessments during sanitary surveys.
 40 CFR 142.15(c)(6)
 After each round of monitoring.



                                  Requirement
                              Regulatory Citation
                      Minimum Frequency/ Retention Period
 The determination of whether the mean Cryptosporidium level is greater than 0.01 oocysts/L both after the initial and after the second round of source water monitoring for each unfiltered system.
 40 CFR 142.15(c)(6)
 As necessary
 Recordkeeping


 Results of Cryptosporidium and E. coli
 source water monitoring.
 40 CFR 142.14(a)(9)
 As necessary
 Bin classification after the first and second round of monitoring.
 40 CFR 142.14(a)(9)
 As necessary
 Any change in treatment requirements for filtered systems due to watershed assessment during sanitary surveys.
 40 CFR 142.14(a)(9)
 As necessary
 The determination of whether the mean Cryptosporidium level is greater than 0.01 oocysts/L after the initial and after the second round of source water monitoring for each unfiltered system.
 40 CFR 142.14(a)(9)
 As necessary
 The treatment processes or control measures that systems use to meet their Cryptosporidium treatment requirements.
 40 CFR 142.14(a)(9)
 As necessary
 A list of systems required to cover or treat the effluent of an uncovered finished water storage facility.
 40 CFR 142.14(a)(9)
 As necessary
 GWR
 Reporting


 The month and year in which the most recent sanitary survey was completed. For a state that used a phased review process, the date the last element of the applicable eight elements was evaluated for each ground water system.
 40 CFR 142.15(c)(7)
 As necessary
 The date the system completed the corrective action.
 40 CFR 142.15(c)(7)
 As necessary
 All ground water systems providing at least 4-log treatment of viruses (using inactivation, removal, or a state-approved combination of 4-log virus inactivation and removal) before or at the first customer for any ground water source(s).
 40 CFR 142.15(c)(7)
 As necessary
 Recordkeeping


 Records of written notices of significant deficiencies.
 40 CFR 142.14(d)(17)
 At least 12 years
 Records of corrective action plans, schedule approvals, and state-specified interim measures.
 40 CFR 142.14(d)(17)
 At least 12 years
 Records of confirmations that a significant deficiency has been corrected or the fecal contamination in the ground water source has been addressed.
 40 CFR 142.14(d)(17)
 At least 12 years



                                  Requirement
                              Regulatory Citation
                      Minimum Frequency/ Retention Period
 Records of state determinations and records of ground water systems' documentation for not conducting triggered source water monitoring.
 40 CFR 142.14(d)(17)
 At least 12 years
 Records of invalidations of fecal indicator- positive ground water source samples.
 40 CFR 142.14(d)(17)
 At least 12 years
 Records of state approvals of source water monitoring plans.
 40 CFR 142.14(d)(17)
 At least 12 years
 Records of notices of the minimum residual disinfectant concentration (when using chemical disinfection) needed to achieve at least 4-log virus inactivation before or at the first customer.
 40 CFR 142.14(d)(17)
 At least 12 years
 Records of notices of the state-specified monitoring and compliance requirements (when using membrane filtration or alternative treatment) needed to achieve at least 4-log treatment of viruses (using inactivation, removal, or a state-approved combination of 4-log inactivation and removal) before or at the first customer.
 40 CFR 142.14(d)(17)
 At least 12 years
 Records of written notices from the ground water system that it provides at     least 4-log treatment of viruses (using inactivation, removal, or a state-approved combination of 4-log virus inactivation and removal) before or at the first customer for each ground water source.
 40 CFR 142.14(d)(17)
 At least 12 years
 Records of written determinations that the ground water system may discontinue 4- log treatment of viruses (using inactivation, removal, or a state-approved combination of 4-log inactivation and removal).
 40 CFR 142.14(d)(17)
 At least 12 years
 ADWR
 States do not have information collection requirements for the ADWR.

4(b)(i) Data Items

       Surface Water Treatment Rule8

      Provisions of the SWTR require the following data to be collected by PWSs and covered under this ICR:

          Source water coliform data for unfiltered systems.
          CFE turbidity data for filtered systems.

 
 
 8 Includes all rule components except disinfectant residual monitoring and associated activities, which are included in the DDBP/Chem/Rads Rules ICR (see footnote 2 for more information). 


          Source water turbidity for unfiltered systems.
          Annual summaries of watershed control programs for unfiltered systems.
          Annual reports summarizing the results of on-site inspections for unfiltered systems.
          A report to the primacy agency within 48 hours following attribution of any waterborne disease outbreak in filtered and unfiltered systems.

 In addition, primacy agencies must submit special reports as specified in 40 CFR 142.15(c)(1). These reports include:

          List of PWSs not required to provide filtration.
          List of PWSs not required to analyze for HPC.
          Notification of determination that a PWS is not required to provide filtration.

      2a)	Total Coliform Rule

The TCR requires PWSs to collect and report presence or absence of coliform bacteria (as total coliform) in the distribution system and data on the presence or absence of E. coli or fecal coliform. Primacy agencies must maintain results of sanitary surveys conducted under TCR. In addition, primacy agencies must submit special reports as specified in section 142.15(c) and must maintain records as specified in section 142.14(a)(5). These reports include lists of PWSs that have received permission for reduced monitoring or monitoring waivers and the effective dates of these waivers.

      2b)	Revised Total Coliform Rule

In addition to the reporting requirements specified in 40 CFR 141.31, PWSs are required by the RTCR to report the following to the states (see section 141.861(a)):

          E. coli MCL violation by the end of the day the system learns of the violation, or by the end of the next business day if the state office is closed when the system learns of the violation.
          E. coli-positive sample by the end of the day when the system learns of the analytical result, or by the end of the next business day if the state office is closed when the system learns of the result.
          Treatment technique violation for total coliforms by no later than the end of the next business day after the PWS learns of the violation. The PWS must provide public notification.
          Assessment form within 30 days of triggering an assessment and completion of each scheduled corrective action for corrections not completed by the time of submission of the assessment form. A "Level 1" assessment (described further in section 4(b)(ii)) is required in the following situations:
             PWSs taking >=40 samples per month have total coliform bacteria present in more than 5 percent of samples for a given month;
             PWSs taking <40 samples per month have two or more total coliform positive samples in a month; or
             PWSs fail to take all required repeat samples after a single total-coliform positive sample.

          A "Level 2" assessment is required in the following situations:
             A PWS has an E. coli MCL violation; or
             A PWS is triggered into a Level 1 assessment for the second time in 12 months, unless the first Level 1 treatment technique trigger was based on exceeding the allowable number of total coliform-positive samples, the state has determined a likely reason for the positive samples that caused the initial Level 1 treatment technique trigger, and the state establishes that the system has fully corrected the problem; or
             PWSs with approved reduced annual monitoring triggers a Level 1 assessment in two consecutive years.
          Monitoring violation within 10 days after the PWS discovers the violation. The PWS must provide public notification.

In addition to the recordkeeping requirements for PWSs specified in 40 CFR 141.33, PWSs are required by the RTCR to keep records of the following (see section 141.861(b)):

          Any assessment form, documentation of corrective actions completed as a result of assessments, or other available summary documentation of the sanitary defects found and corrective actions taken for state review; and
          Any repeat sample taken that meets state criteria for an extension of the 24-hour period for collecting repeat samples.

      States were required to begin complying with the reporting and recordkeeping requirements described below by April 1, 2016. It is important to note that the burden associated with the development of primacy applications was addressed in the standalone RTCR ICR. 
 
In addition to the reporting requirements specified in 40 CFR 142.15, the RTCR requires states to report the following to EPA (see section 142.15(c)(3)):

          A list of systems that the state is allowing to monitor under a reduced monitoring frequency.

In addition to those items already specified in 40 CFR 142.14, states are required to keep records of the following (see section 142.14(a)(10)):
         
          Any case-by-case decision to waive or extend the 24-hour time limit for collecting samples following either a total coliform-positive routine sample, invalidation, or a high turbidity measurement;
          Any decision to allow a system to waive the requirement for three routine samples the month following a total coliform-positive sample;
          Any decision to invalidate a total coliform-positive sample;
          Completed and approved Level 1 and/or Level 2 assessments, including reports from the system that corrective action has been completed;
          Any decision to reduce the total coliform monitoring frequency for a CWS serving 1,000 or fewer people to less than once per month;
          Any decision to reduce the total coliform monitoring frequency for a NCWS using only ground water and serving 1,000 or fewer people to less than once per quarter;
          Any decision to reduce the total coliform monitoring frequency for a NCWS using only ground water and serving more than 1,000 people during any month the system serves 1,000 or fewer people; and
          Any decision to allow a system to forgo E. coli testing of a total coliform-positive sample if that system assumes that the total coliform-positive sample is E. coli- positive.

       Interim Enhanced Surface Water Treatment Rule

      The EPA must balance the health risks from microbial organisms, such as Giardia lamblia and Cryptosporidium, against risks from compounds formed during water disinfection. The IESWTR and Stage 1 DBPR, which were promulgated concurrently, address complex and interrelated drinking water issues. The IESWTR requires individual filter monitoring and modifies the allowable turbidity levels specified in the SWTR.

Under the IESWTR, PWSs must report the following:

          The total number of CFE turbidity measurements that exceeded their 95th percentile turbidity limit and the number of measurements that exceed their maximum turbidity limit.
          That they have conducted individual filter turbidity monitoring, including the dates, filter number, and turbidities of any measurements that exceed 1.0 NTU.
          Reports of exceptions to turbidity performance for individual filters.
          If a self-assessment is required, the system must report the date that it was triggered and the date that it was completed.
          If a CPE is required, the system must report that the CPE is required and the date that it was triggered.
          If a CPE is required, the system must submit a copy of the completed CPE report.
          When those systems that are required to develop a disinfection profile plan a significant change in disinfection practice, they must submit the profile, along with an analysis of how the proposed change will affect the current disinfection benchmark, to the state for review.

      The IESWTR requires PWSs to keep the following records:

          Individual filter turbidity measurements.

The IESWTR (in section 142.14) requires primacy agencies to maintain the following items:

          Records of turbidity measurements for individual filters.
          Records of disinfectant residual measurements and other parameters necessary to document disinfection effectiveness.
          A list of systems consulting with the state to modify their disinfection practices.
          A record of state decisions regarding the use of alternative filtration technologies that have demonstrated 99 percent removal of Cryptosporidium oocysts by specific water systems.
          Records of any other system-by-system and case-by-case decisions made by the state under provisions of Part 141, Subpart H or Subpart P or Subpart T.
          Records of those systems required to perform filter self-assessments, CPEs, or CCPs.

      Additionally, the primacy agency must report the following (per section 142.15):

          Subpart H systems9 that have had a sanitary survey in the last year.
          Evaluation of the state's program for conducting sanitary surveys for all Subpart H systems.

       Filter Backwash Recycling Rule

 Under the FBRR, PWSs should already have reported the following, but they must keep records of the reported information on file:

          Recycle notification, which includes plant schematic, recycle flow, and plant flow.
          List of all recycle flows and the frequency with which they are returned.
          Average and maximum backwash flow rates through the filters.
          Average and maximum duration of the filter backwash process.
          Typical filter run length and a written summary of how filter run length is determined.
          Type of treatment provided for the recycle flow.
          Data on the physical dimensions of the equalization and/or treatment units, typical and maximum hydraulic loading rates, type of treatment chemicals used, average dose of treatment chemicals, frequency of treatment chemical use, and frequency at which solids are removed, if applicable.
          Primacy agencies must maintain records of decisions regarding alternate recycle locations at PWSs.



 
 
 9 Subpart H systems include all PWSs using surface water or ground water under the direct influence of surface water (GWUDI) as a source (40 CFR section 141.2).


       Long Term 1 Enhanced Surface Water Treatment Rule

      Under the LT1ESWTR, PWSs must report the following:

          The total number of CFE turbidity measurements that exceeded their 95th percentile turbidity limit and the number of measurements that exceed their maximum turbidity limit.
          That they have conducted individual filter turbidity monitoring, including the dates, filter number, and turbidities of any measurements that exceeded 1.0 NTU.
          For systems that exceed 1.0 NTU in two consecutive measurements, the filter number, date, time, and reason for the exceedance at the end of the month.
          Exceptions to turbidity performance for individual filters. 
          If a self-assessment is required, the system must report the date that it was triggered and the date that it was completed.
          Any requirement to conduct a CPE and the date that it was triggered.
          The system must submit a copy of the completed CPE report.
          Results of optional monitoring that show total trihalomethane (TTHM) levels
         <0.064 mg/L and haloacetic acid (HAA5) levels <0.048 mg/L (only if the system wishes to forgo profiling) or report that disinfection profiling has begun. 
          A description of the proposed change in disinfection, the system's disinfection profile for Giardia lamblia (and, if necessary, viruses) and disinfection benchmark, and an analysis of how the proposed change will affect the current levels of disinfection.

      The PWS recordkeeping requirements under the rule include:

          Records of individual filter turbidity measurements.
          Records of disinfection profiles.
          Records of benchmarking.
      
Currently, states are subject to the general reporting requirements under 40 CFR 142.15. There are no additional reporting requirements under this rule.
      
The additional state recordkeeping requirements under the LT1ESWTR include:

          Records of turbidity measurements for individual filters.
          Records of disinfectant residual measurements and other parameters necessary to document disinfection effectiveness.
          A list of systems consulting with the state to modify their disinfection practices.
          A record of state decisions regarding the use of alternative filtration technologies that have demonstrated 99 percent removal of Cryptosporidium oocysts by specific water systems.
         

          Records of any other system-by-system and case-by-case decisions made by the state under provisions of Part 141, Subpart H or Subpart P or Subpart T.
          Records of those systems required to perform filter self-assessments, CPEs, or CCPs.

       Long Term 2 Enhanced Surface Water Treatment Rule

      PWSs must submit the following information:

          Sampling schedules, including sampling location(s) and planned dates for source water sampling (for initial and second round monitoring). Existing systems submitted schedules during previous ICR periods, so this requirement only applies to new systems.

Newly constructed systems that filter and serve 10,000 or more people monitor as follows:

          Monthly E. coli and Cryptosporidium monitoring results, to be taken over a period of 2 years, plus two matrix spike samples for Cryptosporidium.
          Monthly turbidity monitoring results (sampled concurrently with Cryptosporidium and E. coli).

Newly constructed systems that filter and serve fewer than 10,000 people monitor as follows:

          Biweekly E. coli monitoring results, to be taken over a period of 1 year (beginning in this ICR period).
          If system exceeds the Cryptosporidium monitoring trigger based on E. coli monitoring results, then 24 Cryptosporidium samples, plus two matrix spike samples for Cryptosporidium. (Note that Cryptosporidium monitoring will not begin until the next ICR period.)

Large unfiltered systems are required to collect 24 Cryptosporidium samples over a period of 2 years. Small unfiltered systems are required to collect 24 Cryptosporidium samples over a period of 1 or 2 years. Both groups of systems are required to collect two matrix spike samples for Cryptosporidium. 

For filtered systems, sampling plans and bin classifications for the second round of monitoring must be reported to the state. All unfiltered systems must report their mean Cryptosporidium levels to the state. (New systems will incur a burden for this during this ICR period.) 

PWSs of all sizes that propose to make a significant change to their disinfection practice will complete disinfection profiles and benchmarks for Giardia lamblia and viruses and report these, along with a description of the proposed change in disinfection practice and an analysis of how the proposed change will affect the current level of disinfection. Most disinfection changes and profiling associated with the LT2ESWTR (and Stage 2 DBPR) occurred during previous ICR periods, aside from new systems. 


PWSs of all sizes that install new technology as a result of their bin classifications or choose to disinfect the effluent from an uncovered finished water reservoir will be required to demonstrate compliance with certain criteria for each technology. PWSs must keep all monitoring data collected under the LT2ESWTR on file for 3 years. These data must be available for review during sanitary surveys.

States will be required to maintain the following data:

          Results of initial and reassessment source water monitoring for small systems.
          Initial bin classifications for each filtered system and mean Cryptosporidium level for each unfiltered system.
          Records of toolbox treatment technologies that systems choose to meet their treatment technique requirements, plus any changes in toolbox treatment technologies, including all documentation necessary to demonstrate compliance with required design and implementation criteria for receiving log credit for toolbox options.
          Any changes to initial bin classifications based on watershed assessment during sanitary surveys.
          Records of technologies employed by unfiltered systems to meet virus, Giardia, and Cryptosporidium inactivation requirements.
          List of systems required to cover or treat effluent of an uncovered finished water reservoir.

States must report the following to EPA:

          Second round bin classification for each filtered system and any changes in bin classifications. Mean Cryptosporidium level for each unfiltered system. (The second round of monitoring began during the previous ICR period and continues during this ICR period.)
          Any finding that a system is not meeting its required Cryptosporidium treatment level.

       Ground Water Rule

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

          Failure to meet any state-specified requirements including minimum residual disinfectant concentration, membrane operating criteria or membrane integrity, and alternative treatment operating criteria, if operation in accordance with the criteria or requirements is not restored within 4 hours.
          Completion of corrective action (within 30 days of completion).
         
         
          Documentation to the state within 30 days of a total coliform-positive sample that a PWS met the state criteria that exempt the system from source water monitoring requirements.

      PWSs must keep records of the following (40 CFR 141.405(b)):

          Documentation of corrective actions.
          Documentation of notice to the public.
          Documentation of records of decisions and records of invalidation of fecal indicator-positive ground water source samples.
          For consecutive systems, documentation of notification to the wholesale system(s) of total-coliform positive samples that are not invalidated.
          For systems, including wholesale systems, that are required to perform compliance monitoring, the additional requirements include the following:  
             Records of the state-specified minimum disinfectant residual 
             Records of the lowest daily residual disinfectant concentration and records of the date and duration of any failure to maintain the state-prescribed minimum residual disinfectant concentration for a period of more than 4 hours.
             Records of state-specified compliance requirements for membrane filtration and of parameters specified by the state for state-approved alternative treatment, and records of the date and duration of any failure to meet the membrane operating, membrane integrity, or alternative treatment operating requirements for more than 4 hours.

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

          Records of written notices of significant deficiencies.
          Records of corrective action plans, schedule approvals and state-specified interim measures.
          Records of confirmations that a significant deficiency has been corrected or the fecal contamination in the ground water source has been addressed.
          Records of state determinations and records of ground water systems' documentation for not conducting triggered source water monitoring.
          Records of invalidations of fecal indicator-positive ground water source samples.
          Records of state approvals of source water monitoring plans.
          Records of notices of the minimum residual disinfectant concentration (when using chemical disinfection) needed to achieve at least 4-log virus inactivation before or at the first customer.
          Records of notices of the state-specified monitoring and compliance requirements (when using membrane filtration or alternative treatment) needed to achieve at least 4-log treatment of viruses (using inactivation, removal, or a state-approved combination of 4-log inactivation and removal) before or at the first customer.
          Records of written notices from the ground water system that it provides at least 4-log treatment of viruses (using inactivation, removal, or a state-approved combination of 4-log virus inactivation and removal) before or at the first customer for each ground water source.

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

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

          The month and year in which the most recent sanitary survey was completed or, for a state that used a phased review process, the date the last element of the applicable eight elements was evaluated for each ground water system.
          The date the system completed the corrective action.
          All ground water systems providing at least 4-log treatment of viruses (using inactivation, removal, or a state-approved combination of 4-log virus inactivation and removal) before or at the first customer for any ground water source(s).

       Aircraft Drinking Water Rule

Air carriers are required to maintain records and submit the following items to EPA:

          Information on total coliform sampling frequency and disinfection and flushing frequency.
          Water system inventory and any subsequent changes.
          Monitoring results for total coliform bacteria samples taken as part of routine, repeat, and post-disinfection follow-up sampling.
          Analytical results for E. coli, required when total coliform results are positive.
          Evidence of self-inspection of water system components completed every 5 years, including an indication that deficiencies have been corrected; and, if not corrected, a description of the deficiency, an explanation of why it has not been corrected, and a schedule for correction.
          Notification of all events requiring public notice and corrective action.
          Failure to comply with monitoring, disinfection and flushing procedures. 
Air carriers are also required to maintain the following documents:10

          The O&M plan for the aircraft PWS to address ADWR requirements. This plan should be included in the FAA's aircraft O&M program and made available for EPA review upon request.
          The coliform sampling plan that was developed as part of their O&M plan, which must be available for EPA review upon request.
          Any O&M plans and coliform sampling plans that must be developed for any new aircraft the air carrier acquires through purchases, ownership transfers, or any other means. These plans must be made available for the EPA review upon request.

 
 
10 Burden to develop O&M plans and coliform sampling plans for existing aircraft was accounted for under the standalone ADWR ICR and is not included again under the Microbial Rules ICR as it is a one-time activity.
Additionally, the number of aircraft acquired post-ADWR promulgation is assumed to be a very small percentage of the existing ADWR inventory; therefore, the burden to develop new O&M and coliform sampling plans for aircraft acquired post-ADWR promulgation is assumed to be negligible.


4(b)(ii) Respondent Activities
      
PWSs and primacy agencies must complete the activities described in the sections below.
      
Public Water Systems
      
In general, each PWS is involved in the following collection activities:

          Gathering information.
          Processing, compiling, and reviewing the information collected.
          Submitting reports and other documents.
          Recording and maintaining the information.

 For this ICR, these activities are necessary to complete monitoring, reporting and recordkeeping requirements associated with microbial contaminant-related regulations.

      Surface Water Treatment Rule

Requirements for reporting under the SWTR are separated into those for systems that use filtration treatment and those for systems that do not use filtration treatment. The reporting requirements for these types of PWSs are summarized in the paragraphs below.

Unfiltered Systems

          Monitor and report information on the results of source water monitoring for total or fecal coliform and turbidity.
          Submit this information each month that the system is in operation.
          Summarize fecal or total coliform monitoring by including:
             The number of total or fecal coliform samples collected and the values obtained for each measurement; 
             The number of results less than 20/100 milliliters (mL) for fecal coliform or less than 100/100 mL for total coliform during the month; 
             The cumulative number of fecal or total coliform results obtained since the start of the six consecutive month compliance period; 
             And the percent of samples less than the respective performance standard for the six-month compliance period.
          Summarize turbidity information to include:
             The maximum turbidity value obtained each month; 
             The value and date of each measurement that exceeded five NTUs;
             And the date the occurrence was reported to the state.
          Monitor and report disinfectant residual levels (this requirement is addressed under the DDBP/Chem/Rads ICR).
          Submit annual reports on watershed control programs and onsite inspections.


       
      Filtered Systems

          Monitor and report to the state on a monthly basis information regarding CFE turbidity. Turbidity reporting requirements vary according to the filtration technology used.
          Monitor and report disinfectant residual levels (this requirement is addressed under the DDBP/Chem/Rads ICR).

      2a)	Total Coliform Rule

      TCR activities have been replaced by RTCR in this ICR period.

      2b)	Revised Total Coliform Rule

PWSs must conduct the following activities to comply with the RTCR:

          Conducting routine, additional routine, and repeat coliform monitoring and reporting the results as required.
          Completing a Level 1 assessment if the PWS experiences a Level 1 trigger and submitting a form to the state to identify sanitary defects detected, corrective actions completed, and a timetable for any corrective actions not already completed. 
          Completing a Level 2 assessment if the PWS experiences a Level 2 trigger and submitting a form to the state to identify sanitary defects detected, corrective actions completed, and a timetable for any corrective actions not already completed. 
          Correcting sanitary defects found through the performance of Level 1 or Level 2
         assessments and report on completion of corrective actions as required.
             
       Interim Enhanced Surface Water Treatment Rule

Systems serving at least 10,000 people using surface water or ground water under the direct influence of surface water (GWUDI) are required to do the following:

          Conduct continuous monitoring of individual filter turbidity for each filter in the system.
          Report individual filter turbidity monitoring results to the state at frequencies specified in the federal regulations.
          Report exceptions to the state in cases where the monitoring shows exceedances of specific turbidity levels.
          Perform a filter profile and/or filter assessment or obtain a CPE if warranted.
          Provide a CPE report to the state if necessary.

       Filter Backwash Recycling Rule

The rule requires PWSs to collect and retain on file recycle flow information for review and evaluation by the state beginning June 8, 2004 (40 CFR 141.76(d)).

       Long Term 1 Enhanced Surface Water Treatment Rule

Under the LT1ESWTR, systems serving under 10,000 people and using surface water or GWUDI are required to do the following:

          Conduct continuous monitoring of individual filter turbidity for each filter in the system.
          Record individual filter turbidimeter readings at the specified intervals.
          Report individual filter turbidity monitoring results to the state at frequencies specified in the federal regulations.
          Report exceptions to the primacy agency in cases where the monitoring shows exceedances of specific turbidity levels.
          Perform a filter profile and filter assessment or arrange for a CPE if warranted.
          Provide a CPE report to the state, if necessary.
          Develop a disinfection benchmark, if necessary.
          Consult with the state before making significant changes to disinfection practices.

       Long Term 2 Enhanced Surface Water Treatment Rule

      Under the LT2ESWTR systems are required to do the following:

          Submit a sampling plan for the second round of monitoring. This requirement applies to systems serving fewer than 50,000 people.
          Monitor source water for E. coli and Cryptosporidium and calculate a treatment bin classification based on monitoring results. This requirement applies to filtered systems only. Systems serving at least 10,000 people are also required to monitor source water turbidity; the burden for turbidity monitoring is assumed to be negligible. 
          Filtered systems serving less than 10,000 people may monitor for E. coli as a trigger instead. These systems will only sample for Cryptosporidium if their E. coli results exceed certain levels.
          Unfiltered systems are required to monitor source water for Cryptosporidium only and calculate treatment requirements based on monitoring results. 
          If additional treatment was installed in the previous ICR period based on the first round of bin classification, systems must demonstrate to the state that they are complying with the requirements for the technologies they have chosen.
          Prepare disinfection benchmarking reports for Giardia and viruses if disinfection is changed. This activity will be completed during this 3-year ICR period.
          Keep all monitoring data on file for 3 years.

       Ground Water Rule

Under the GWR, systems are required to do the following:

          Conduct triggered source water monitoring if the system tests positive for total coliform in the distribution system under TCR, for systems not providing 4-log treatment of viruses. Under triggered monitoring requirements (40 CFR 141.402) a system must collect at least one source water sample and have that sample tested for a fecal indicator specified by the state. If a system detects the state-specified fecal indicator at its source, then the system must take five additional samples within 24 hours unless the state determines that corrective action must be taken immediately.
          Conduct source water assessment monitoring for fecal indicators if required by the state.
          Comply with treatment technique requirements and any associated reporting requirements if the state identifies a significant deficiency during a sanitary survey or the system has confirmed fecal contamination of its source water.
         
         
          Monitor disinfectant residual for compliance, for systems providing disinfection to achieve 4-log inactivation of viruses.
          Maintain records of GWR information listed in section 4(b)(i).

       Aircraft Drinking Water Rule

Air carriers will need to undertake the following activities to meet reporting requirements under the ADWR:

          Report the development of a new sampling plan; submit new monitoring and disinfection and flushing frequency information for new purchases or transfers of ownership of aircraft; and maintain sampling plans.
          Report changes in aircraft water system inventory within 10 days after the end of the month in which they occurred.
          Take routine and repeat coliform samples and post-disinfection follow-up coliform samples following corrective action.
          Submit routine, repeat, and post-disinfection sampling results to the EPA.
          Record routine, repeat, and post-disinfection coliform sampling activities.
          Record disinfection and flushing activities conducted as part of routine activity or corrective action.
          Prepare and provide public notification to passengers and crew as needed. All public notification instances must be reported to the EPA.
          Conduct a comprehensive self-inspection of aircraft water system components at least every 5 years.
          Submit evidence of self-inspection to the EPA, including report of deficiencies corrected and unresolved deficiencies and their correction schedule.
      
Primacy Agencies
      
In general, primacy agencies conduct the following activities with regard to reporting and recordkeeping:
      
          Maintain an inventory of PWSs.
          Compile results of analyses of drinking water samples.
          Analyze and review PWS data.
          Make determinations concerning compliance with NPDWRs by PWSs.
          Track PWS compliance.
          Report systems not in compliance with drinking water requirements.
          Maintain state approval of plans and specifications, enforcement activities, and variances and exemptions (V&Es) for each PWS.

Some of these activities are covered in the PWSS Program ICR as general primacy activities. Therefore, only microbial contaminant-specific recordkeeping activities have been included in this Microbial Rules ICR.

       Surface Water Treatment Rule

      The SWTR states that primacy agencies must conduct the following:

         
          Collect and maintain information submitted by PWSs.
          Record which systems using surface water are required to provide filtration and which are not. These records must be kept indefinitely.
          Submit a special report to the EPA Administrator listing PWSs that are not required to filter.
          Retain the results of microbiological contaminant analyses of source water samples in the same manner as other microbiological contaminant analytical results.
         
      2a)	Total Coliform Rule

Primacy agencies are required by the TCR to conduct the following activities:
      
          Analyze monitoring results and identify systems not in compliance with either MCL (or performance criteria) or monitoring and reporting frequencies.
          Provide in writing permission for reduced monitoring or monitoring waivers; Primacy agencies are required to maintain this information for five years.
          Submit to the EPA Administrator a special report that lists PWSs that have received permission to reduce monitoring requirements.
          Collect and maintain data regarding the results of sanitary surveys conducted under the TCR.

      2b)	Revised Total Coliform Rule

Primacy agencies are required by the RTCR to conduct the following activities:

          Tracking compliance.
          Analyzing and reviewing PWS data.
          Making determinations concerning PWS monitoring requirements.
          Responding to PWSs with positive samples.
          Recordkeeping.
          Reviewing completed assessment forms and consulting with the PWS about the assessment form.
          Reviewing and coordinating with PWSs to determine the optimal corrective action to be implemented.
          Providing consultation, reviewing the public notification certification, and filing the report of the violation.

       Interim Enhanced Surface Water Treatment Rule

Primacy agencies are required to maintain records of state verification activities and each determination made and to report to the EPA in accordance with state reporting requirements. In addition, primacy agencies ensure that PWSs are implementing the IESWTR properly. To meet these responsibilities, states are involved in the following additional activities:

          Reviewing individual filter turbidity monitoring data.
          Conducting CPEs for PWSs.
          Conducting sanitary surveys.
          Consulting with PWSs on changes in disinfection practice.
          Conducting follow-up inspections.

         
       Filter Backwash Recycling Rule

For the FBRR, primacy agencies incur a recordkeeping requirement for maintaining data submitted by conventional and direct filtration PWSs that recycle. Primacy agencies must also maintain written approval for all PWSs with alternate recycle locations.

       Long Term 1 Enhanced Surface Water Treatment Rule

Primacy agencies have the responsibility for ensuring the implementation of the LT1ESWTR (40 CFR 142.16). The EPA anticipates that states will be involved in the following activities:

          Consulting with PWSs on changes in disinfection practice.
          Conducting CPEs for PWSs (if requested).
          Conducting follow-up inspections.
          Compliance tracking for turbidity.

       Long Term 2 Enhanced Surface Water Treatment Rule

Primacy agencies have the responsibility for ensuring the implementation of the LT2ESWTR. This will include the following activities (most of these activities only impact new water systems):

          Maintaining and updating the data management system.
          Reviewing system sampling schedules and proposed sampling locations.
          Maintaining E. coli and Cryptosporidium monitoring data.
          Responding to systems' inquiries.
          Reviewing and approving bin classifications.
          Reviewing disinfection profiles and benchmarks.
          Reviewing and, in some cases, approving processes to meet bin treatment requirements.
          Reporting the information required in section 4(b)(i).
          Keeping records of the information in section 4(b)(i).

       Ground Water Rule

      States will need to perform the following tasks:
      
          Perform sanitary surveys and reporting and recordkeeping requirements associated with performing sanitary surveys.
          Track and file monitoring results and reviewing any additional reporting.
         
       Aircraft Drinking Water Rule

The EPA is the primacy agency for the ADWR. EPA activities under this rule are described in section 5(a) of this document.


5	INFORMATION COLLECTED -- AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT

5(a)	Agency Activities

As part of its oversight responsibility, the EPA maintains SDWIS11 and evaluates SDWIS data to determine system compliance. EPA personnel also reformat, distribute, and store these data for a number of uses, including responding to Congressional and public inquiries. The EPA also oversees the Agency's regional and state programs, provides technical assistance, and develops policies designed to ensure consistent program implementation. EPA officials serve as respondents when testifying to Congress on the PWSS Program or in the courts for enforcement actions.

The EPA also acts as the enforcement authority for the ADWR. EPA oversees ADWR compliance because aircraft fly in interstate commerce and, therefore, no single state can have primacy over an aircraft PWS, as described in 40 CFR 142.3(b). The burden associated with the 206.4 regional full-time equivalents (FTEs)12 covered under the PWSS Program ICR includes the EPA ADWR burden. The EPA will be responsible for collecting the information generated as air carriers comply with the rule. EPA activities for the ADWR include the following:

          Train EPA staff.
          Provide technical assistance to air carriers.
          Review sampling frequency and disinfection and flushing frequency information.
          Review routine, repeat, and post-disinfection monitoring results.
          Review information on public notification events.
          Review aircraft water system inventory changes.
          Review certifications and reports of air carrier self-inspections.
          Conduct onsite compliance audits, as needed.

Burden and costs for these activities are addressed in the PWSS Program ICR (OMB No.
2040-0090). Section 5(a) of the PWSS Program ICR contains additional detail regarding the activities supported by the collection of SDWIS data described in the first paragraph of this section.
      
In addition to these activities, the EPA assumes the activities performed by the state for those states, territories and tribes that do not have primacy. Specifically, the EPA will be involved in the following activities related to microbial contaminant regulations:
      
          Training PWSs.
          Analyzing and reviewing PWS data.
          Making compliance determinations concerning PWSs.
          Conducting CPEs and sanitary surveys.



11 As mentioned in section 1 of this ICR, revisions are currently being made to SDWIS. The EPA expects the revisions to streamline the reporting and recordkeeping process. Details regarding potential burden and cost reductions in future ICR periods are provided in section 5(b) of the PWSS Program ICR.
12 FTE figures were provided by the OGWDW. 


          Meeting with PWSs about changes in recycling practices.
          Compliance tracking.
          Recordkeeping.

Burden and costs for these activities are accounted for under the primacy agency burden (see section 6). EPA regional offices also conduct general primacy activities for states, territories and tribes that do not have primacy. This burden is addressed in the PWSS ICR and is included in the general primacy burden for primacy agencies.


                                   Exhibit 4
                               EPA Requirements

                                  Requirement
                              Regulatory Citation
                                   Frequency
 General Requirements (apply to all regulations)
 For states and other entities for which the EPA maintains primacy, the Agency must maintain the records and perform the reporting activities required of states. (This burden is addressed under primacy agency burden.)
 40 CFR 142.14 and 142.15
 As necessary
 Review state request for approval of a program revision and notify state of determination regarding request.
 40 CFR 142.12(d)(3)
 One time, as necessary
 SWTR
 Publish a notice of any proposed comprehensive review of state decisions to determine if PWSs must provide filtration.
 40 CFR 142.80(b)
 As necessary
 Notify each state affected by the results of a comprehensive review.
 40 CFR 142.80(c)
 As reviews are completed
 Make the results of comprehensive reviews available to the public.
 40 CFR 142.80(c)
 As reviews are completed
 Notify the state if periodic reviews or other available information indicate that the state has abused its discretion in applying the criteria for avoiding filtration or that the state has failed to prescribe compliance schedules for PWSs that must provide filtration.
 40 CFR 142.81(a)
 As necessary
 Notify the state that a public hearing will be held on the notice provisions.
 40 CFR 142.81(b)
 As necessary
 Publish a notice of the public hearing in the Federal Register and in a newspaper of general circulation in the involved state.
 40 CFR 142.81(c)
 As necessary
 TCR
 Subject to general requirements as listed above.
 RTCR
 Subject to general requirements as listed above.
 IESWTR
 Subject to general requirements as listed above
 FBRR
 Subject to general requirements as listed above.
 LT1ESWTR
 Subject to general requirements as listed above.
 Publish a notice of any proposed comprehensive review of state decisions to determine if PWSs must provide filtration.
 40 CFR 142.80(b)
 As necessary
 Notify each state affected by the results of a comprehensive review.
 40 CFR 142.80(c)
 As reviews are completed
 Make the results of comprehensive reviews available to the public.
 40 CFR 142.80(c)
 As reviews are completed
 Notify the state if periodic reviews or other available information indicate that the state has abused its discretion in applying the criteria for avoiding filtration or that the state has failed to prescribe compliance schedules for PWSs that must provide filtration.
 40 CFR 142.81(a)
 As necessary
 Notify the state that a public hearing will be held on the notice provisions.
 40 CFR 142.81(b)
 As necessary
 Publish a notice of the public hearing in the Federal Register and in a newspaper of general circulation in the involved state.
 40 CFR 142.81(c)
 As necessary
 LT2ESWTR
 Subject to general requirements as listed above.
 Approving laboratories
 40 CFR 141.705
 As necessary
 Collecting and managing sampling location descriptions, sampling schedules, and monitoring data submitted by medium and large systems.
 40 CFR 141.702(a),
 141.703(f), 141.706(b)
 As necessary
 GWR
 Subject to general requirements as listed above.
 ADWR
 No specific EPA requirements are stated in the ADWR; however, EPA will conduct the oversight activities described previously for the ADWR.




5(b)	Collection Methodology and Management

Primacy agencies must report data to the EPA on a quarterly basis. These data include any new data and revisions or corrections to existing data. This information is maintained in SDWIS,13 which contains the following:

          Inventory data for each PWS.
          Violations.
          Enforcement actions and follow-up activities.
          Variances and exemptions (where applicable).

Primacy agencies primarily transmit SDWIS data to the EPA electronically. In the District of Columbia, Wyoming, and tribal lands (except for the Navajo Nation, which has primacy), results of system samples are sent directly to the EPA Region.

SDWIS data support a number of rule implementation and program management activities, which include the following:

          Using data pulled from SDWIS on a quarterly basis, the Office of Enforcement and Compliance Assurance uses the Enforcement Targeting Tool (ETT) to generate a list of PWSs that are considered "priority systems" for enforcement.
          Supporting PWSS program file reviews. During PWSS program file reviews, the EPA compares SDWIS data to primacy agency data to assess the quality of the data. 
          Promoting consistent national program implementation. The process of file reviews provides insights into the primacy agency's interpretation of regulations to ensure consistent SDWA implementation.
         
In addition to SDWIS, the EPA has developed and maintains the web-based Aircraft Reporting and Compliance System (ARCS) for air carriers complying with the ADWR. Air carriers must report all compliance data to ARCS. The burden for developing this system was addressed in the standalone ICR for the ADWR (OMB control number 2040-0277).

All costs for rule-related data management activities are addressed in the PWSS Program ICR (OMB No. 2040-0090). Section 5(b) of the PWSS Program ICR contains additional detail regarding the activities supported by the previously described collection of SDWIS data.




13 The public can access the violation data in SDWIS online at http://water.epa.gov/scitech/datait/databases/drink/sdwisfed/howtoaccessdata.cfm.


5(c)	Small Entity Flexibility

In developing this ICR, the EPA considered the requirement of the Small Business Regulatory Enforcement Fairness Act (SBREFA) to minimize the burden of information collections on small entities. The major requirement under the SBREFA is a regulatory flexibility analysis (RFA) of all rules that have a "significant economic impact on a substantial number of small entities." Since this ICR is not currently associated with new rules, it is not currently subject to the SBREFA.

The EPA has made significant efforts to minimize the burden for all respondents, particularly for small entities.[14] In setting monitoring requirements, the EPA has been able to minimize burden for small entities as detailed below.
 
       Surface Water Treatment Rule

Only a small percentage of small systems use surface water supplies; therefore, this rule does not have a significant economic impact on a substantial number of small entities. Since system size is the key determinant of the monitoring frequency requirements of the SWTR, systems serving fewer than 3,300 people will have the least stringent monitoring requirements.

The EPA will allow a reduction in the frequency of turbidity monitoring from six samples per day to one sample per day for systems using slow sand filtration treatment or other eligible technologies. Systems serving fewer than 500 people may also reduce sampling to once per day regardless of filtration type.

      2a)	Total Coliform Rule

      TCR activities have been replaced by RTCR in this ICR period.

      2b)	Revised Total Coliform Rule

To assess this impact, the EPA conducted outreach to small entities and convened a Small Business Advocacy Review Panel SBARP in February 2008 to obtain recommendations from representatives of the small entities that would be subject to the rule's requirements. The panel recommended using total coliforms as a trigger for investigation and/or corrective action, balancing monitoring requirements and costs with risk, further differentiating requirements from other related rules, and considering reporting and recordkeeping costs when estimating burden.





14 These definitions were taken from section 601 of the Regulatory Flexibility Act.


Several of these recommendations were implemented. The RTCR eliminates the MCLG and MCL for total coliforms and instead uses total coliforms as an indicator of the potential pathway of contamination into the distribution system. PWSs that may be vulnerable to fecal contamination are required to do an assessment and if necessary, take appropriate corrective action. Other provisions of the RTCR that resulted in reduced costs for small PWSs include: 

          Reduced routine monitoring for qualifying PWSs serving 1,000 or fewer people.
          Reduced number of repeat samples required.
          Reduced additional routine monitoring for PWSs serving 4,100 or fewer people.
          Reduced public notification requirements for all systems, including small systems.
          Reductions in corrective actions over time as a result of enhanced system performance for all small systems.

       Interim Enhanced Surface Water Treatment Rule

Except for sanitary survey requirements, which are conducted by the primacy agency, the IESWTR only applies to systems serving at least 10,000 people. The rule does not have a significant impact on small entities.

       Filter Backwash Recycling Rule

The FBRR applies to both large and small systems. As part of the economic analysis for the rule, the EPA certified that this rule would not have a significant impact on a substantial number of small systems and, therefore, an RFA was not required.

       Long Term 1 Enhanced Surface Water Treatment Rule

The LT1ESWTR applies only to Subpart H systems serving fewer than 10,000 people. After considering the economic impacts of the rule on small entities, the EPA certified that this action would not have a significant economic impact on a substantial number of small entities. 

The EPA determined that less than one percent of small entities will experience an impact of one percent or more of their annual revenues or expenditures. No affected small governmental jurisdictions are expected to incur annual costs exceeding three percent of their annual revenue. Accordingly, an RFA was not required.

       Long Term 2 Enhanced Surface Water Treatment Rule

      The LT2ESWTR allows small filtered systems to monitor for E. coli instead of Cryptosporidium. The analysis for E. coli is much less expensive than the one for Cryptosporidium. Small systems are only required to monitor for Cryptosporidium if E. coli concentrations are above a trigger value. In addition, systems with at least 2 years of historical Cryptosporidium data may use that data instead of performing new monitoring.

       Ground Water Rule

The GWR was developed in consultation with the SBARP. Several of the panel's recommendations were incorporated into the rule. These recommendations include:

          Utilizing a risk targeted approach, in which only those systems most at risk are required to monitor or provide corrections.
          Using coliform monitoring instead of more expensive viral monitoring. Monitoring for other organisms is required only if coliform monitoring is positive.
          
       Aircraft Drinking Water Rule

The EPA has developed the ADWR to provide flexibility to all air carriers including small entities or small businesses. For example, where a maintenance frequency is not specified by the water tank manufacturer, air carriers can choose the combination of monitoring and disinfection and flushing that accommodates existing routine aircraft maintenance schedules. The rule permits air carriers to take only one routine sample (instead of two) for certain aircraft with a removable/portable water tank that is drained every day where the aircraft has only one tap.

5(d)	Collection Schedule

The collection schedules for each rule are summarized below. Additional information may be obtained by consulting the individual rules for specific collection schedules.


                         Exhibit 5 Collection Schedule

 Rule
 Collection Commencement Year
 SWTR
 1991/1993 (depending on filtration status)
 TCR
 1991  -  coliform monitoring
 1994  -  sanitary surveys for CWSs, 1999 for NCWSs
 RTCR
 2016  -  coliform monitoring
 IESWTR
 2002  -  turbidity monitoring
 2002/2004 - sanitary surveys (depending on size and source type)
 FBRR
 2004  -  recordkeeping
 LT1ESWTR
 2005  -  turbidity monitoring
 LT2ESWTR
 2006  -  Cryptosporidium and E. coli monitoring first round (depends on system size; all sampling completed by 2011)

 2010  -  disinfection profiling (depends on system size)
 2012  -  reporting for compliance with new technologies
 2015  -  second round of Cryptosporidium and E. coli monitoring
 GWR
 2009  -  sanitary survey, triggered monitoring, corrective action plans, compliance monitoring
 ADWR
 April 2011  -  inventory data, sampling and O&M plan information
 October 2011  -  coliform sampling data, dates routine disinfection and flushing are performed


6	ESTIMATING BURDEN AND COST OF COLLECTION

This section estimates the burden and cost to PWSs, air carriers, and primacy agencies for complying with drinking water information requirements associated with microbial contaminant rulemakings. These include the following:

       Surface Water Treatment Rule15
       Total Coliform Rule/Revised Total Coliform Rule
       Interim Enhanced Surface Water Treatment Rule
       Filter Backwash Recycling Rule
       Long Term 1 Enhanced Surface Water Treatment Rule
       Long Term 2 Enhanced Surface Water Treatment Rule
       Ground Water Rule
       Aircraft Drinking Water Rule

This ICR updates the annual burdens and costs associated with these rulemakings for the three-year ICR period of May 1, 2019, through April 30, 2022. This section also discusses the assumptions used to estimate cost and burden and describes the change in annual burden, as compared with the current OMB annual burden inventory.

The EPA has refined some of the assumptions for calculating the burden and costs associated with implementing the drinking water regulations contained in this ICR in an effort to accurately characterize the burden and costs. Updates are based on program changes and well-documented changes in some data. To provide a comparable basis on which to calculate the requirements addressed by the Microbial Rules ICR, and to address inconsistencies, the EPA applied uniform assumptions to all rules where applicable. The categories of assumptions are listed below.

          A 2018 labor rate of $21.87 was obtained from the Bureau of Labor Statistics (BLS) for PWSs. An overhead rate of 60 percent was applied, resulting in an hourly rate of $34.99. For states, a 2018 labor rate of $37.32 was obtained from the BLS. An overhead rate of 60 percent was applied, resulting in an hourly rate of $59.71.
          PWS inventory figures from the most recent frozen SDWIS database pull (October 2018).
          Number of entry points per system -- data from the 2006 Community Water Systems Survey (CWSS).
          Number of plants per system -- data from the 2006 CWSS.

In addition, the EPA has revised some of the estimates of burden for particular activities (e.g., sampling, developing reports) to reflect consultations with representatives of PWSs and states (see section 3(c)).






15 Includes all rule components except disinfectant residual monitoring and associated activities, which are included in the DDBP/Chem/Rads Rules ICR.


6(a)	Respondent Burden

      6(a)(i) Burden to Public Water Systems and Air Carriers

The annual PWS burden for May 1, 2019, through April 30, 2022, is estimated to be approximately 14.0 million hours. Exhibit 6 shows the breakdown of the annual burden hours on a rule-specific basis. The annual air carrier burden for the same time period is 0.039 million hours (see Exhibit 7). Wherever possible, activity-level burden assumptions were carried forward from previous ICRs or were updated to reflect consultation results. However, if updated data were available (e.g., system inventories), the most recent data were used in burden calculations. The following further describes the bases for the burden estimates for each rule.

       Surface Water Treatment Rule

Activities associated with the SWTR, IESWTR, and LT1ESWTR are modelled together and collectively account for 6.50 million annual burden hours per year. This ICR includes burden estimates for all components of the SWTR except disinfectant residual monitoring and associated activities, which are included in the DDBP/Chem/Rads Rule ICR. For unfiltered systems, burden estimates include raw water sampling for coliform, on-site inspections, watershed management and raw water turbidity monitoring. The burden for filtered systems includes only finished water turbidity monitoring.

       Total Coliform Rule/Revised Total Coliform Rule

       Activities associated with the TCR and RTCR account for a burden of 6.38 million hours per year and represent the RTCR burden associated with full rule implementation. RTCR burden includes that incurred to conduct routine monitoring, additional routine monitoring, and repeat monitoring; to perform Level 1 and Level 2 assessments; and to perform reporting and recordkeeping related to corrective actions. The assumptions used to calculate RTCR burden are based largely on assumptions carried forward from the standalone RTCR ICR for the final rule. The burden associated with public notice recordkeeping and reporting requirements related to the RTCR is accounted for under the PN Rule in the 2019 PWSS Program ICR. Section 6(f) describes the reasons for changes between the burden reported in the 2015 Microbial Rules ICR and this ICR.

       Interim Enhanced Surface Water Treatment Rule
      
Activities associated with the SWTR, IESWTR, and LT1ESWTR are modelled together and collectively account for 6.50 million annual burden hours per year. Included in this burden are individual filter turbidity monitoring, turbidity exceptions reporting, and conducting individual filter assessments (IFAs).

       Filter Backwash Recycling Rule

No burden is estimated for PWSs for this rule. Currently, the rule requires PWSs to maintain records on recycle flow. The burden associated with this recordkeeping is assumed to be negligible.


                                                                               
                                                                               
       Long Term 1 Enhanced Surface Water Treatment Rule

Activities associated with the SWTR, IESWTR, and LT1ESWTR are modelled together and collectively account for 6.50 million annual burden hours per year. The burden estimates for PWSs include turbidity exceptions reporting and turbidity monitoring. 

       Long Term 2 Enhanced Surface Water Treatment Rule

Activities associated with the LT2ESWTR account for a burden of 0.16 million hours per year. The burden estimates include reporting associated with demonstrating compliance with installed treatment. PWS burden estimates also account for some of the burden associated with developing disinfection profiles and benchmarks. The initial and second rounds of monitoring for E. coli and/or Cryptosporidium were completed during a previous ICR period. PWSs conducting monitoring are also expected to complete a sampling plan and bin recalculation.

       Ground Water Rule

Activities associated with the GWR account for a burden of 0.83 million hours per year. For ground water systems providing 4-log treatment of viruses, the burden estimates include compliance monitoring to demonstrate treatment effectiveness and associated reporting, including reports of disinfection failure. In addition, burden estimates for developing corrective action plans are included. For ground water systems that do not provide 4-log treatment of viruses, PWS burden estimates also account for burden associated with conducting triggered source water monitoring if the system tests positive for total coliform in the distribution system under the TCR. PWS burden also includes the burden associated with sanitary surveys.
	
       Aircraft Drinking Water Rule

Activities associated with the ADWR account for an air carrier burden of 0.038 million hours per year. The assumptions used to calculate the ADWR burden are based largely on assumptions carried forward from the standalone ADWR ICR for the final rule, supplemented with industry consultations. Air carrier burden includes sampling, reporting associated with sampling and O&M activities, self-inspection, and public notice.

      6(a)(ii) Burden to Primacy Agencies

The annual burden for primacy agencies for May 1, 2019, through April 30, 2022, is estimated to be approximately 4.21 million hours. Exhibit 8 shows the annual burden hours on a rule-specific basis. Many other primacy agency activities, such as compliance assurance and data management, cannot be divided among specific rules and are included in the PWSS Program ICR as general primacy activities. The bases for burden estimates included in this ICR are detailed below.

       Surface Water Treatment Rule

Activities associated with the SWTR, IESWTR, and LT1ESWTR are modelled together and collectively account for 1.97 million annual burden hours per year. SWTR burden is associated with review of finished water turbidity monitoring results. Estimates for primacy agency burden for the SWTR are based on assumptions carried forward from the 2015 Microbial Rules ICR. 

       Total Coliform Rule/Revised Total Coliform Rule

      Activities associated with the TCR/RTCR account for a burden of 1.09 million hours per year. RTCR burden includes responding to positive sample results; reviewing completed assessment forms required to be filed by PWSs; consulting with PWSs about their assessment form; and reviewing and coordinating with PWSs to determine the appropriate corrective action to be implemented and providing consultation. States must also submit information to SDWIS to assist both the EPA and states in tracking PWS compliance. The assumptions used to calculate RTCR burden are based largely on assumptions carried forward from the standalone RTCR ICR for the final rule. Note that burden related to RTCR PN is accounted for under the PN Rule in the 2019 PWSS Programmatic ICR.

       Interim Enhanced Surface Water Treatment Rule

Activities associated with the SWTR, IESWTR, and LT1ESWTR are modelled together and collectively account for 1.97 million annual burden hours per year. The assumptions used to calculate the IESWTR burden are based largely on assumptions carried forward from the 2015 Microbial Rules ICR. The burden includes estimates for review of turbidity monitoring results and exceptions reports. Additionally, states conduct CPEs as necessary and sanitary surveys for all surface water systems.

       Filter Backwash Recycling Rule

No burden is estimated for states for this rule. The burden associated with the recordkeeping requirements in this rule is assumed to be negligible.

       Long Term 1 Enhanced Surface Water Treatment Rule
      
Activities associated with the SWTR, IESWTR, and LT1ESWTR are modelled together and collectively account for 1.97 million annual burden hours per year. The assumptions used to calculate the LT1ESWTR burden are based largely on assumptions carried forward from the 2015 Microbial Rules ICR. The burden includes estimates for compliance tracking and recordkeeping of turbidity monitoring for small systems, and review of turbidity monitoring and turbidity exceptions reports. Additionally, states conduct turbidity exceptions reporting, which includes CPEs and annual exception reports for systems serving 10,000 or fewer people.

       Long Term 2 Enhanced Surface Water Treatment Rule
      
The annual state burden for the LT2ESWTR is expected to be 0.14 million hours. The assumptions used to calculate the LT2ESWTR burden are based largely on assumptions carried forward from the 2015 Microbial Rules ICR. State burden includes reviewing monitoring results and assisting with and reviewing bin classifications. States will also review disinfection profiles and benchmarks for systems that significantly change their disinfection practices.


       Ground Water Rule

The annual state burden for the GWR is expected to be 1.02 million hours. The assumptions used to calculate the GWR burden are based largely on assumptions carried forward from the standalone GWR ICR for the final rule, which was incorporated into the 2015 Microbial Rules ICR. The burden includes those activities associated with performing sanitary surveys, as well as burden to review initial compliance monitoring notification and compliance monitoring reports submitted by PWSs. In addition, states will ensure PWSs are complying with treatment technique requirements and any associated reporting requirements. For ground water systems that do not provide 4-log treatment of viruses, state burden estimates also account for review of triggered source water monitoring results. Lastly, the burden includes annual administrative activities such as recordkeeping, staff training, and technical assistance to PWSs. 

       Aircraft Drinking Water Rule

The EPA is the primacy agency for the ADWR and has direct oversight for that rule. This burden is captured in PWSS Program ICR.

6(b)	Respondent Costs

      6(b)(i) Cost to Public Water Systems and Air Carriers

Exhibit 6 shows the annual costs for PWSs over the three-year ICR period. Annual costs are estimated at approximately $752.8 million, which consists of $524.6 million in labor costs,
$194.4 million in O&M costs, and $33.8 million in capital costs.

Exhibit 7 shows the annual costs for air carriers over the three-year ICR period. Annual costs are estimated at approximately $1.6 million, which consists of $0.89 million in labor costs, $0.7 million in O&M costs, and $0.004 million in capital costs.

PWS labor costs are based on the number of burden hours times the average hourly wage rate, including overhead. The average hourly wage rate for PWSs is the rate quoted by the BLS for Standard Occupational Classification (SOC) Code 19-4091, "Environmental Science and Protection Technician, Including Health." The quoted rate was $21.87 in 2018 dollars (see https://www.bls.gov/oes/current/oes_nat.htm#11-0000). In addition, 60 percent overhead was assumed, bringing the loaded rate to $34.99 in 2018 dollars. For air carriers, four labor rates are used and are all loaded by approximately 50 percent. All rates are from the BLS in 2018 dollars. The first labor rate is for code 11-3071, "Transportation Managers" at a loaded rate of $66.68. The second labor rate is for code 53-7061, "Equipment and Vehicle Cleaners" at a loaded rate of $16.85. Labor rates for code 53-6051, "Transportation Inspectors" and code 51-9061, "Inspectors, Testers, Sorters, Samplers, and Weighers" were also used at loaded rates of $52.02 and $43.84, respectively.


In addition to the labor costs, there are O&M costs associated with the SWTR, TCR/RTCR, IESWTR, LT1ESWTR, LT2ESWTR, GWR, and ADWR.

          SWTR O&M costs reflect non-labor costs associated with coliform analyses (unfiltered systems) and turbidity analyses (unfiltered and filtered systems). Coliform analysis O&M costs are based on analysis costs as listed in the GWR Economic Analysis. Turbidity analysis O&M costs are based on vendor quotes regarding calibration materials needed to perform turbidity analyses.
          TCR O&M costs reflect non-labor costs associated with coliform and E. coli analysis.
          RTCR O&M costs reflect net change non-labor costs associated with coliform analysis.
          IESWTR O&M costs reflect non-labor costs associated with turbidity analysis for individual filters. For the IESWTR, turbidity analysis costs are based on O&M cost equations for operating an integrated supervisory control and data acquisition (SCADA) system. These cost equations are carried forward from the IESWTR Regulatory Impact Analysis (RIA).
          LT1ESWTR O&M costs reflect non-labor costs associated with turbidity analysis for individual filters.
          LT2ESWTR O&M costs reflect non-labor costs associated with Cryptosporidium and E. coli laboratory analysis.
          GWR O&M costs reflect non-labor costs associated with compliance (disinfection) monitoring (maintenance costs, monthly reagents, charts and recorder pens) and E. coli analysis materials costs from the GWR Economic Analysis.

Additionally, there are capital costs associated with the SWTR, IESWTR, LT1ESWTR, GWR, and ADWR.

          SWTR, IESWTR and LT1ESWTR include capital costs for turbidity monitoring equipment. For these rules, capital costs are estimated based on vendor estimates and costing equations for in-line and bench-top turbidimeters, or SCADA systems needed to comply with turbidity monitoring requirements. Capital costs are distributed evenly across the replacement period for turbidity analysis equipment (estimated to be 7 years).
          The GWR includes capital costs for chlorine monitoring equipment such as chlorine analyzer, power cord and chart recorder).
          The ADWR includes a capital cost for refrigerators purchased by air carriers, which is distributed evenly across the replacement period for the equipment.

      6(b)(ii) Cost to Primacy Agencies

Exhibit 8 shows that the annual costs to primacy agencies are estimated at approximately $217.7 million. All costs incurred by primacy agencies are labor costs. Labor costs are based on the number of burden hours times the average hourly wage rate, including overhead. Labor rates in 2018 dollars are used and are loaded with a 60 percent overhead factor. A loaded labor rate of $59.71 per hour in 2018 dollars was used for state labor. The labor costs are based on best professional judgement and consultation results at $37.32 per hour.  Loaded, this rate comes to $59.71 per hour.
      
There are no O&M or capital costs for primacy agencies under this ICR.
      
                                       
                                       
                                   Exhibit 6
                          Annual PWS Burden and Cost
                        May 1, 2019  -  April 30, 2022
                                   Activity
                              Annual Burden Hours
                                     Cost


                            Annual Labor Cost ($K)
                           Annual O&M Cost ($K)
                           Annual Capital Cost ($K)
                            Total Annual Cost ($K)
SWTR/IESWTR/LT1
                                                                      6,506,443
                                                                      $323,564 
                                                                       $67,525 
                                                                       $33,741 
                                                                      $424,830 
TCR/RTCR
                                                                      6,378,237
                                                                       $165,785
                                                                      $111,403 
                                                                            N/A
                                                                      $277,188 
LT2ESWTR
                                                                        159,416
                                                                        $8,020 
                                                                        $8,898 
                                                                            N/A
                                                                       $16,918 
GWR
                                                                        826,926
                                                                       $27,240 
                                                                        $6,578 
                                                                           $86 
                                                                       $33,904 
TOTAL
                                                                     13,871,021
                                                                       $524,609
                                                                       $194,405
                                                                        $33,826
                                                                       $752,840
Note: Detail may not add exactly to totals due to rounding.





                                   Exhibit 7
                      Annual Air Carrier Burden and Cost
                        May 1, 2019  -  April 30, 2022
                                   Activity
                              Annual Burden Hours
                                     Cost


                            Annual Labor Cost ($K)
                           Annual O&M Cost ($K)
                           Annual Capital Cost ($K)
                            Total Annual Cost ($K)
ADWR
                                                                         38,817
                                                                          $869 
                                                                          $737 
                                                                            $4 
                                                                        $1,610 
TOTAL 
                                                                         38,817
                                                                           $869
                                                                           $737
                                                                             $4
                                                                         $1,610



                                   Exhibit 8
                     Annual Primacy Agency Burden and Cost
                        May 1, 2019  -  April 30, 2022
                                   Activity
                              Annual Burden Hours
                                     Cost


                            Annual Labor Cost ($K)
                           Annual O&M Cost ($K)
                           Annual Capital Cost ($K)
                            Total Annual Cost ($K)
SWTR/IESWTR/LT1
                                                                      1,972,571
                                                                        $97,138
                                                                            N/A
                                                                            N/A
                                                                       $97,138 
TCR/RTCR
                                                                      1,086,858
                                                                        $55,211
                                                                            N/A
                                                                            N/A
                                                                       $55,211 
LT2ESWTR
                                                                        141,151
                                                                         $7,405
                                                                            N/A
                                                                            N/A
                                                                        $7,405 
GWR
                                                                      1,017,164
                                                                        $57,898
                                                                            N/A
                                                                            N/A
                                                                       $57,898 
TOTAL 
                                                                      4,217,744
                                                                       $217,652
                                                                            N/A
                                                                            N/A
                                                                      $217,652 
Note: Detail may not add exactly to totals due to rounding.






6(c)	Agency Burden and Costs

Burden and costs to the federal government are incurred by the EPA's drinking water program at Headquarters and in the Regions to assist primacy agencies in implementing drinking water regulations. The EPA burden and costs for on-going general activities for all the EPA drinking water regulations are accounted for under the PWSS Program ICR. Burden and costs included in the PWSS Program ICR cover all cross-cutting (non-rule specific) regulatory activities associated with compliance tracking, regulatory enforcement, and rule development activities. There are no rule-specific activities expected for the EPA under any of the rules covered by this ICR, except for the EPA's oversight of air carriers for the ADWR. The EPA's burden is not included in the total burden for the ADWR. As explained above and in section 5(a), the EPA ADWR burden is accounted for in the PWSS Program ICR.

6(d)	Estimating Respondent Universe and Total Burden and Costs

Respondents for this ICR include PWSs, air carriers, and primacy agencies. The number of PWS respondents is 146,715,20 the number of active PWSs. All PWSs are subject to the TCR and RTCR but are not necessarily subject to each of the other information collection requirements contained in this ICR. Each rule associated with this ICR identifies the types of PWSs that are subject to that particular requirement. The number of air carrier respondents is 36. Note that air carriers are respondents for the ADWR only.

In addition to the PWS and air carrier respondents, this ICR assumes 57 primacy agencies (50 states plus the District of Columbia, U.S. territories, and the Navajo Nation).21 Therefore, the total number of respondents is 146,808. The total costs and burden for these respondents are summarized in Exhibits 6, 7, and 8.

6(e)	Bottom Line Burden Hours and Costs

The bottom line burden hours and costs for this ICR are presented in Exhibit 9. The total annual respondent burden associated with this ICR, which includes burden for PWSs, air carriers, and primacy agencies, is estimated to be approximately 18.1 million hours. The corresponding total annual respondent costs are estimated to be $972.1 million. The annual capital and O&M costs are approximately $229.0 million.





20 Source: SDWIS/FED Data from October 2018.
21 For several of these entities, primacy activities are actually implemented by the regional offices. However, as a simplifying assumption, they are included with the states for respondent calculations under this ICR.





                                   Exhibit 9
                      Bottom Line Annual Burden and Cost
                        May 1, 2019  -  April 30, 2022
Annual Number of Respondents
                                                                        146,808
                                      (=)
 

                                                                        146,715
                                      (+)
Existing PWSs

                                                                             36
                                      (+)
Existing Air Carriers

                                                                             57
                                       
Primacy agencies
Total Annual Responses
                                                                     29,249,289
                                      (=)
 

                                                                     27,073,725
                                      (+)
PWS responses (see Exhibit 6)

                                                                        133,803
                                      (+)
Air Carrier responses (see Exhibit 7)

                                                                      2,041,762
                                       
Primacy agency responses (see Exhibit 8)
Number of Responses per Respondent
                                                                          199.2
                                      (=)
 

                                                                     29,249,289
                                      (/)
Total annual responses from above

                                                                        146,808
                                       
Total number of respondents from above
Total Annual Respondent Hours
                                                                     18,127,581
                                      (=)
 

                                                                     13,871,021
                                      (+)
PWS hours (see Exhibit 6)

                                                                         38,817
                                      (+)
Air Carrier hours (see Exhibit 7)

                                                                      4,217,744
                                       
Primacy agency hours (see Exhibit 8)

Hours per Response
                                                                           0.62
                                      (=)


                                                                     18,127,581
                                      (/)
                                       
Total annual respondent hours from above

                                                                     29,249,289
                                       
Total annual responses from above

Annual O&M and Capital Cost ($K)[1]
                                                                       $228,972
                                      (=)
 

                                                                       $194,405
                                      (+)
Total PWS O&M costs (see Exhibit 6)

                                                                        $33,826
                                      (+)
Total PWS capital costs (see Exhibit 6)

                                                                           $737
                                      (+)
Total Air Carrier O&M costs (see Exhibit 7)



                                                                             $4
                                       
Total Air Carrier capital costs (see Exhibit 7)


Total Annual Respondent Cost ($K)
                                                                       $972,102
                                      (=)
 

                                                                       $752,840
                                      (+)
For PWSs (see Exhibit 6)

                                                                         $1,610
                                      (+)
For Air Carriers (see Exhibit 7)

                                                                       $217,652
                                       
For primacy agencies (see Exhibit 8)

Total Annual Hours (resp. plus Agency) 
                                                                     18,127,581
                                                                               
                                      (=)



                                                                     18,127,581
                                      (+)
Total annual respondent hours from above

                                                                              0
                                       
Total EPA hours
Total Annual Cost ($K) (resp. plus Agency) 
                                                                       $972,102
                                      (=)
 

                                                                       $972,102
                                      (+)
Total annual respondent cost from above

                                                                             $0
                                       
Total EPA cost

Note: Detail may not add exactly to totals due to rounding.


[1] No Primacy Agency capital or O&M costs are incurred, see Exhibit 8.




6(f)	Reasons for Change in Burden

There is an overall increase of 3,443,983 hours in the total estimated respondent burden compared with the ICR currently approved by OMB. This increase is mostly due to an increase of 1,585,657 hours under the RTCR. In exhibit 12, the reasons for this increase are explained in detail.  
Section 6(f) presents the change in burden and explains the reasons for the change in burden. 
Exhibit 10 summarizes how each of these changes affects the overall burden inventory for the Microbial Rules ICR.

                                  Exhibit 10
                      Summary of Changes in Annual Burden
             (Includes PWS, Air Carrier and Primacy Agency Burden)
                                Type of Change
                                Burden (hours)
                                 Running Total
                                    Comment
Burden Estimated in the 2015 Microbial Rules ICR
                                  14,693,597
                                  14,693,597
This burden serves as the baseline for the 2018 Microbial Rules ICR.
Restructuring Adjustments - see Section 6(f)(i)
                                       0
                                  14,683,598
No restructuring occurred in this ICR.
Other Adjustments to Burden - see Section 6(f)(ii)
                                   3,443,983
                                  18,127,581
Burden for which EPA seeks approval in this ICR.
Notes: 
(1) Detail may not add exactly to totals due to rounding.
(2) Burden requested in the 2015 Microbial Rules ICR (14,683,598) hours is used as a starting point for the 2018 Microbial Rules ICR. 


6(f)(i) Restructuring Adjustments

No restructuring adjustments are associated with this ICR. These adjustments are discussed below and summarized in Exhibit 11.

                                  Exhibit 11
           Restructuring Adjustments to the Annual Burden Inventory
                          for the Microbial Rules ICR
             (Includes PWS, Air Carrier and Primacy Agency Burden)
                                    Action
                              Annual Burden Hours
                               Brief Explanation
N/A
14,693,597
Inventory for the 2015 Microbial Rules ICR[2] carried forward as the baseline for 2018 Microbial Rules ICR (includes PWS, state, and air carrier burden). 
Add
0
No Restructuring occurred in this ICR.
Total
14,693,597
Current opening inventory for the 2018 Microbial Rules ICR (based on current burden inventories.)
Notes: 
(1) Detail may not add exactly to totals due to rounding.
(2) Burden requested in the 2015 Microbial Rules ICR (14,638,598) hours is used as a starting point for the 2018 Microbial Rules ICR. 


6(f)(ii) Other Burden Adjustments

Changes in calculated burden are a result of updating relevant baseline information for each rule with the most current and accurate PWS inventory information available and updating to 2018 labor rates. Where appropriate, estimated violation, waiver, and other associated rates have also been updated to reflect current information on rule compliance. Burden has also changed as a result of consultation with water industry representatives and due to changes in rule requirements, notably full implementation of the RTCR.

      Exhibits 12-14 summarize reasons for these changes and quantify the changes by rule. Burden adjustments associated with PWS activities resulted in a burden increase of 1,843,781 hours and are detailed in Exhibit 12. Burden adjustments associated with air carrier activities resulted in a burden increase of 4,477 hours and are detailed in Exhibit 13. Burden adjustments for primacy agencies result in an increase of 1,585,727 hours per year, as shown in Exhibit 14.
                                       
                                  Exhibit 12
             Adjustments to PWS Burden from Previous ICR Estimates
                                   Activity
                          2015 Annual Burden Estimate
                          2018 Annual Burden Estimate
                               Change in Burden
                          Reason for Change in Burden





SWTR (including IESWTR and LT1ESWTR)
                                                                     6,229,174 
                                                                     6,506,443 
                                                                        277,269
The increase in burden for the SWTR, which includes the IESWTR and LT1SWTR, can be attributed to the increase in the complexity of performing a sanitary survey at surface water systems that are serving an increased population. SDWIS data shows that large surface water systems are serving 3 million people more than in the last reported ICR cycle. is due to increased burden associated with performing sanitary surveys as the population served by large surface water systems increased by 3 million.
TCR/RTCR
                                                                     4,792,580 
                                                                     6,378,237 
                                                                     1,585,657 
The 3-year period covered by the Microbial Rules ICR includes no burden for TCR activities and full implementation of RTCR activities. The increase burden is primarily due to additional routine and repeat monitoring.
LT2ESWTR
                                                                       144,525 
                                                                       159,416 
                                                                        14,891 
In addition to changes in rule-required activities, the change in burden is attributable to the use of updated system population, as the population served by large surface water systems increased by 3 million.
GWR
                                                                       860,961 
                                                                       826,926 
                                                                       (34,035)
The decrease in burden is attributable to a decrease in the number of ground water systems by 3,500. 
TOTAL
                                                                    12,027,240 
                                                                    13,871,022 
                                                                     1,843,782 
Adjusted PWS Burden.
Notes:  
 Detail may not add exactly to total due to independent rounding.
 PWS burden adjustments for all rules in Exhibit 12 take into account burden reductions associated with the anticipated transition from the current SDWIS (the existing compliance database of record) to SDWIS Prime, a cloud-based reporting system.
                                       
                                       
                                       
                                  Exhibit 13
         Adjustments to Air Carrier Burden from Previous ICR Estimates
                                   Activity
                    Previous Annual Burden Estimate (Hours)
                      2018 Annual Burden Estimate (Hours)
                               Change in Burden
                          Reason for Change in Burden





                                     ADWR
                                    34,340
                                    38,817
                                     4,477
The change in burden reflects airline industry consultation results, which increased estimated burden for, compliance audits, inventory changes, sampling and sample analysis.
                                     TOTAL
                                    34,340
                                    38,817
                                     4,477
Adjusted Air Carrier Burden


                                       
                                  Exhibit 14
       Adjustments to Primacy Agency Burden from Previous ICR Estimates
                                   Activity
                      2015 Annual Burden Estimate (Hours)
                      2018 Annual Burden Estimate (Hours)
                               Change in Burden
                          Reason for Change in Burden





SWTR (including IESWTR and LT1ESWTR)
                                                                     1,344,997 
                                                                     1,972,571 
                                                                       627,574 
The increase in burden for SWTR (including IESWTR and LT1SWTR) is due to increased burden associated with performing sanitary surveys as the population served by large surface water systems increased by 3 million.
TCR/RTCR
                                                                       448,931 
                                                                     1,086,858 
                                                                       637,927 
The 3-year period covered by the Microbial Rules ICR includes no burden for TCR activities and full implementation of RTCR activities. The increase burden is primarily due to performing Level 1 and Level 2 assessments; and performing review of additional monitoring and corrective actions. 
LT2ESWTR
                                                                       110,317 
                                                                       141,151 
                                                                        30,834 
In addition to changes in rule-required activities, the change in burden is attributable to the use of updated system population, as the population served by large surface water systems increased by 3 million.
GWR
                                                                       727,772 
                                                                     1,017,164 
                                                                       289,392 
The increase in burden is due to an increase in burden associated with state recordkeeping, compliance tracking, and significant deficiency and corrective action reporting.
TOTAL
                                                                     2,632,017 
                                                                     4,217,744 
                                                                     1,585,727 
Adjusted Primacy Agency Burden
Notes:  
 Detail may not add exactly to total due to independent rounding.
 Primacy agency burden adjustments associated with the anticipated transition from the current SDWIS (the existing compliance database of record) to SDWIS Prime (a cloud-based reporting system) are captured in the PWSS ICR.



Exhibit 15 shows the effects of these adjustments on the bottom line burden. Adding 1,843,782 hours to account for adjustments to PWS burden, 4,477 hours to account for adjustments to air carrier burden, and 1,585,727 hours to account for adjustments to primacy agency burden yields 18,127,583 hours.

                                       
                                  Exhibit 15
   Adjustments to Annual Burden Carried Forward from Previous ICR Estimates
             (Includes PWS, Air Carrier and Primacy Agency Burden)
                                    Action
                              Annual Burden Hours
                               Brief Explanation
None
14,693,597 
2015 Microbial Rules ICR inventory based on current burden inventories (see Exhibit 11).
Add
1,843,782 
Adjustment to the PWS burden carried forward from previous ICRs (see Exhibit 12).
Add
4,477 
Adjustment to Air Carrier burden carried forward from previous ICR (see Exhibit 13)
Add
1,585,727 
Adjustment to the primacy agency burden carried forward from previous ICRs (see Exhibit 14).
Total
18,127,583 
Hours requested in 2018 Microbial Rules ICR (see Exhibit 10).
Note: Detail may not add exactly to totals due to rounding.


6(g)	Burden Statement

The public reporting burden for collections included in this ICR is detailed in Exhibit 15 above. The annual respondent burden is estimated to average approximately 18.13 million hours, of which 13.87 million hours are attributable to PWSs, 0.0388 million hours to air carriers, and 4.22 million hours to primacy agencies (numbers may not add due to rounding). These estimates include time for gathering information as well as developing and maintaining records.

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; 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 request for information collection unless it displays a currently valid OMB control number. The OMB control numbers for the EPA's regulations are listed in 40 CFR Part 9 and 48 CFR Part 15.

To facilitate comment on the EPA'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, the EPA has established a public docket for this ICR under Docket ID Number EPA-HQ-OW-2011-0442, 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), WJC West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566- 1744, and the telephone number for the Water Docket is (202) 566-2426. An electronic version of the public docket is available at www.regulations.gov. This site can be used to submit or view public comments, to 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. Comments can also be sent 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 Docket ID Number (EPA-HQ-OW-2011-0442) and the OMB Control Number 2040-0205 in any correspondence.
