OMB notes that 139,770 hours have been removed to reflect the fact that the WS and WP programs are no longer authorized under this ICR. This ICR now authorizes only the DMR-QA program. The burden estimate for this program has been adjusted upward by 6,786 hrs per year.
table that charts list comparision
Inventory as of this Action
Requested
Previously Approved
12/31/2010
36 Months From Approved
12/31/2007
7,516
0
17,168
47,351
0
180,335
1,240,140
0
3,350,000
Discharge Monitoring Report-Quality Assurance (DMR-QA) participation is mandatory for major and selected minor permit holders under the Clean Water Act's National Pollution Discharge Elimination System (NPDES), Section 308. The DMR-QA study is designed to evaluate the entire process used by permittees to routinely report monitoring results in Discharge Monitoring Reports (DMRs). The study addresses the analytic ability of the laboratories that perform chemical, microbiological and whole effluent toxicity (WET) analyses required in the NPDES permits and the ability to properly report these results in the DMRs. Under DMR-QA, the permit holder is responsible for obtaining un-graded results of analyses of test samples performed by in-house and/or contract laboratories, and submitting these results to the appropriate federal or state NPDES regulatory authority and the commercial proficiency testing (PT) provider that supplies the test samples. Permit holders are responsible for submitting corrective action reports to the appropriate regulatory authority.
The primary reason for change in burden is due to the fact that this ICR no longer includes WS and WP programs - only the DMR-QA program, so it should not be compared exactly with the previous ICR which included all three programs. The WS and WP are being submitted as a separate ICR through the Office of Water (OW).
Other burden changes include:
Participation in the DMR-QA PE study has increased from an estimated average of 6,489 to 7,516 since the last renewal of this ICR, while the list of average analytes done by the average respondent was increased to include WET test methods which were not included in the previous ICR.
Labor and Operation & Maintenance costs were updated since the previous renewal of this ICR.
The average cost of obtaining PE samples from the PT Providers was added to this ICR to reflect the fact that respondents (permittees) have to incur the burden of paying this cost passed on from the PT Providers.
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
Form EPA 6400-01 (OMB 2 Performance Evaluation Studies of Water and Waste Water Laboratories
EPA-HQ-OECA-2006-0931-0005.pdf
0234.09Time Cost Burdens.xls
0234ss09.doc
Performance Evaluation Studies of Water and Waste Water Laboratories