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2040-0090 198801-2040-001
Historical Inactive 198712-2040-002
EPA/OW
PUBLIC WATER SYSTEM PROGRAM INFORMATION
Revision of a currently approved collection   No
Regular
Disapproved and continue 03/25/1988
Retrieve Notice of Action (NOA) 01/25/1988
This ICR for the additional burden from the proposed Filtration rule i disapproved pending the consideration and evaluation of the following. First, a disproportionate amount of the burden and cost falls on small systems (<3,300 people)--approximately 62% of cost ($16.3M) and burden (718,643). It is unclear from the ICR, especially the discussion of small businesses, whether this is justified, but appears to contradict the PRA requirement (5CFR 1320.6(h)) to simplify requirements for smal businesses. Separate analysis of per system burden and per household cost should be done to evaluate need. Second, the need to retain records of coliform and turbidity sampling for five years and other analytical and evaluation results for at least ten years is not adequately justified, especially the differential treatment and is inconsistant with 5CFR 1320.6(f). Unless necessary, these requirement should be changed to three years. Third, the burden to the estimated 463 systems obtaining exceptions seems excessive when the purpose is t reduce burden and cost. For example, the very small systems' househol costs could still increase by over $250. Fourth, the need to have monthly PWS and quarterly State reporting is not justified (item #7) a the monthly reporting violates the provisions of 5CFR 1320.6(a). Serio consideration should be given to reporting based on compliance or severity of non-compliance. Finally, the cost to Federal government should be estimated and not declared insignificant.Earlier remarks app
  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