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View ICR - OIRA Conclusion



2040-0090 198712-2040-002
Historical Inactive 198710-2040-002
EPA/OW
PUBLIC WATER SYSTEM PROGRAM INFORMATION (COLIFORM)
Revision of a currently approved collection   No
Regular
Disapproved and continue 01/19/1988
Retrieve Notice of Action (NOA) 12/17/1987
This ICR for the additional burden from the proposed Coliform rule is disapproved pending the consideration and evaluation of the following items. First, the incremantal burden (and cost) imposed on non-community and community water systems serving les than 500 people and using groundwater is potentially severe. The one million estimated incremental burden hours (and $100 M) of taking five coliform samples per month rather than one a month is contrary to the Paperwork Reduction Act's requirements (5CFR 1320.6(h)) to develop separate and simplified requirements for small businesses. Also the incremental value of this information has not been demonstrated. As a result, EPA should consider adopting as minimum requirements the alternative presented in the proposal for states to reduce monitoring to systems serving less than 3,300 people. If states believe addition monitoring is warranted then they always can increase it. Additional analysis of the incremental burden and value of this monitoring should be completed. Second, the costs to the Federal Government and States (item 12) cannot be insignificant when the amount of coliform samples being processed could double or quadruple. Please reevaluate the assumptions and include new cost and burden estimates as appropriate. Finally, the need to retain records of reduced monitoring authoriza for ten years is not adequately justified and should be years to be consistant with 5CFR1320.6(f).Earlier remarks s
  Inventory as of this Action Requested Previously Approved
09/30/1990 09/30/1990 09/30/1990
214,445 0 214,445
1,403,210 0 1,403,210
0 0 0