United States
Environmental Protection
Agency
Office of Water
4601
EPA/814-F-9 6-001
May 1996
4>EPA ICR Implementation
EPA ICR Fact Sheet Series
#1 - Implementation Requirements
This fact sheet summarizes the implementation requirements for the
Information Collection Requirements (ICR) Rule as promulgated in, May
1996. Monitoring begins in February 1997.
Plant Categories for
DBF and Micro
Monitoring
Systems Affected [§141.141(b)(2)]
The following table lists the Treatment Plant Categories affected by the
ICR:
Treatment Plant Categories
Treatment Plant
Category
A
B
C
D
E
F
G
PWS Combined
Population Serves
a 100,000
i 100,000
i 100,000
i 100,000
i 100,000
i 100,000
50,000-99,999
and 1:50,000
served by
ground water
Treatment Plant
Combined
Population Served
a 100,000
* 100,000
plant serves
< 100,000 and is
largest plant
plant serves
< 100,000 and is
largest plant
plant serves
< 100,000 and is
not largest plant
in PWS
plant serves
< 100,000 and is
not largest plant
in PWS
NA
Treatment Plant
Surface Water
Population Served
il
zero
il
zero
il
zero
NA
Treatment Plant
Ground Water
Population Served
Not Applicable
NA
NA
<100,000
NA
<100,000
largest ground
water plant
PWSs serving 100,000 persons or more with treatment plants in
Categories A, B, C, D, E or F must conduct DBF and related monitoring at
each plant. PWSs serving 100,000 persons or more must conduct
microbiological monitoring at each treatment plant in Categories A, C or
E. In addition, plants in Categories A, B, C, D and G (PWS serves 50,000
to 99,999 and £ 50,000 served by ground water) must conduct treatment
study applicability monitoring.
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Treatment Studies
Applicability Monitoring
DBF and Micro
ICR Sampling
ICR Monitoring lasts
eighteen (18) months
Tables 1 thru 5 define
monthly & quarterly
monitoring
Notice of Applicability
Applicability Letter
Monitoring Required
Beginning 3 months after promulgation, plants in Categories A, B, C, D,
and G must conduct treatment study applicability monitoring under
§141.144. If, based on the results of the applicability monitoring, a plant
cannot be excused from conducting treatment studies they must conduct
either bench- or pilot-scale treatment studies to meet the treatment studies
requirement. Details of this monitoring, the treatment studies themselves,
and other options to meet this requirement will be found in EPA ICR Fact
Sheet Series-#3.
Following Initial Sampling Plan approval, two types of monitoring will be
required under the ICR:
• DBP and Related Monitoring conducted under § 141.142, and
• Microbiological Monitoring conducted under §14.1.143
See Table 2 in the rule [§ 141.141 (b)(2)j.
Sampling Points
Monitoring under the ICR will be conducted monthly for a period of 18
months for a number of different analyte groups, collected at many
locations within the treatment plant and distribution system. Some
samples, such as the DBPs, are only collected quarterly. The frequency
and location of ICR DBP sampling are shown in Tables la and Ib
[§141.142(a)]. Treatment plants using other than free chlorine (ozone,
chlorine dioxide, hypochlorite and chloramines) must also conduct
additional monitoring shown in Tables 2 through 5. Consult the ICR
Sampling Manual [EPA/814-B-96-001] for additional details on sampling
locations and procedures. Before collecting any samples, the PWS must
submit a detailed sampling plan to EPA for approval. This sampling plan
is described below under the heading, "Initial Sampling Plan" while
details for developing the plan are presented in the Users' Guide for the
ICR Water Utility Database System [EPA 814-B-96-004].
Formal Notification by EPA
Following promulgation of the ICR and publication in the Federal
Register, EPA will send "Notice of Applicability" letters to a list of PWSs
for the purpose of formally announcing the ICR and to request that the
affected utilities supply certain information to EPA (within 5 weeks) that
will aid in determining which of their plants must comply with the
monitoring provisions of the ICR. This list was developed by EPA, in
conjunction with the states, and consists of those PWSs that EPA and the
states believe meet ICR applicability criteria. PWSs that do not receive a
Notice of Applicability, but believe that they meet applicability criteria
must contact EPA to request a Notice of Applicability [ §141.141(0(1)}-
After the PWS responds to the Notice of Applicability, it will then receive
an "applicability letter" from EPA stating how each plant will be affected
by the ICR. The utility will then have eight (8) weeks to submit an "Initial
Sampling Plan" to EPA.
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Video and training in
how to develop an
Initial Sampling Plan
The "A-Team"
Start of Sampling
Data Entry Work-
sheets for collect-
ing monthly data
Initial Sampling Plan
The initial sampling plan milst be. developed by the utility for each
treatment plant affected by the ICR and will include the plant design
parameters for each unit process in each process train for each treatment
plant, the location of each sampling point, and the analytical parameters to
be monitored at each sampling point. The Users' Guide for the ICR Water
Utility Database System contains data entry worksheets that will aid in the
collection and entry of the plant design parameters. The data entry
software will be used to develop the plan(s). A video will be provided by
EPA to introduce utility personnel to the software. Training courses will
also be offered by AWWA in September and October of 1996 (see ICR
Training) to provide "hands-on" instruction in the use of the software.
Additional help on the use of the software will also be available from the
AWWA A-Team and through the ICR Data Management System Hotline,
703-908-2155. The sampling plan can only be submitted to EPA on
diskette.
NOTE: The AWWA Assistance Team (A-Team) will provide schematics
showing the unit processes used at each system's treatment plants. Each
schematic will show where monthly and/or quarterly samples are to be
taken. The A-Team will also provide help to utilities in the development
of the Initial Sampling Plan. The A-Team can be reached by phone at:
1-800-200-0984
or by E-Mail at: 103327.2057@compuserve.com
EPA will review the Initial Sampling Plan submitted by the utility and, if
approved, will send an "approval letter" to the PWS. Sampling must
begin in the first month following receipt of this sampling plan approval
letter.
Monthly Sampling
The data entry software should be used to develop sampling plans for each
month that ICR samples are collected throughout the 18-month monitoring
period. This can be done with the data entry software by copying
information from one sampling period to another and then updating the
operational information for the current month. In addition, the Users'
Guide contains a set of Data Entry Worksheets to help in the collection of
information required for monthly sampling. These monthly sampling
plans do not need to be submitted to EPA. Reports generated by the
software will, however, be useful in the collection of operating data and
specific sample collection information. Refer to the database Users'
Guide for specific information on how to prepare the monthly sampling
plans.
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Monthly Reports
ICR Sample Numbers
Micro Sampling
Procedures
Low-level bromate,
cyanogen chloride,
and aldehyde analyses
The ICR Water Utility Database System enables the user to print out a
series of three reports that will aid in the collection of the monthly
samples. One of these reports, Report C.I, Monthly Sample Data
Collection Form, is used by the sample collector to ensure that the
required samples and sampling data are collected. The other data
collection forms are used to collect unit process and chemical data at the
time of sampling.
All samples will have a discrete sampling number assigned by the
software which contains the following information:
• ICR Treatment Plant ID Number - 1 st 3 digits
• Sampling Month - next 2 digits
• Sampling Year - next 2 digits
• Sample Location Number - next 2 digits
• Analyte Group - remaining characters
An example of a ICR sampling number is: 315039703THM
Additional information on sample collection is available in the ICR
Sampling Manual, which is referenced in the rule along with other
manuals. Specific sampling procedures for the chemical parameters are
not covered in detail in the sampling manual since these procedures have
been used by the water systems for some time and should be familiar. The
microbial sampling procedures, however, are new to many of the systems
and are described in detail in a video and companion guide entitled,
Information Collection Requirements Rule - Protozoa and Enteric Virus
Sample Collection Procedures [EPA/814-B-95-001],
EPA Special Analyses
For treatment plants that use chloramines, cyanogen chloride samples
must be collected quarterly and sent to EPA in Cincinnati for analysis.
For treatment plants that use ozone or chlorine dioxide, PWSs must collect
duplicate bromate samples on a monthly basis. The PWS must analyze
one sample and submit the other to EPA for low-level bromate analysis at
their Cincinnati lab. These bromate samples will be collected by utilities
in sample bottles provided by the EPA lab. Aldehyde samples collected.
quarterly by treatment plants that use ozone or chlorine dioxide will also
be analyzed by the Cincinnati EPA lab. It is important to schedule the
analysis of these samples in advance of the date of sample collection.
These samples should be sent to:
ICR DBP Sample Coordinator
US Environmental Protection Agency
26 West Martin Luther King Jr. Drive
Cincinnati, OH 45268
See the ICR Sampling Manual [EPA/814-B-96-001] for details on the
submission of these samples to EPA. EPA will report analytical results
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Data transfer to EPA
Copy and edit Final
Design data from the
Initial Sampling Plan
Lab Approval Fact
Sheet
Treatment Studies Fact
Sheet
EPA Manuals
for cyanogen chloride, low-level bromate, and aldehydes to the PWS once
analysis is complete.
Monthly Sampling Results
Monthly sampling results will be entered by the utility into the ICR Water
Utility Database System as they are received from the laboratories and
reviewed by utility personnel. Data are not to be transferred to EPA until
all of the monthly sampling results for a particular sampling period have
been received, reviewed, and entered into the application. This could take
several months, especially in the case of the virus results. When all of the
sampling results have been received and entered, the utility shall submit a
monthly report (diskette) to EPA that indicates the analytical results of all
samples collected for the sampling period (including quarterly samples
collected in that month), and all of the relevant plant operational data.
These data shall be submitted to EPA on a diskette no later than the fourth
month following the month in which the samples were collected.
Final Design
The last set of treatment plant, process train, and unit process information
to be gathered under the ICR is the Final Design. The Final Design data
may be copied from the Initial Sampling Plan using the database software
and then edited to reflect the status of the treatment plant at the conclusion
of the ICR data collection effort. Again, the Users' Guide should be
consulted for details on the data entry procedures. The Final Design must
be submitted to EPA on a diskette along with a summary report.
Use of Approved Laboratories
Laboratories which intend to conduct analyses under the ICR must receive
specific ICR approval from EPA. See the EPA ICR Fact Sheet Series -
# 2 on lab approval and the appropriate manuals for details.
Treatment Studies
Summary information on meeting the treatment study requirements is
contained In the EPA ICR Fact Sheet Series - # 3 and detailed information
is provided in the Treatment Studies Manual [EPA/814-B-96-003].
Technical Manuals
Four (4) technical manuals have been printed that cover additional ICR
requirements. The manuals are referenced in the rule and, as such, further
specify the details of the rule's requirements and provide additional
guidance on how to comply with the ICR requirements. The manuals are:
• ICR Sampling Manual, EPA/814-B-96-001
• DBP/ICR Analytical Methods Manual, EPA/814-8-96^002
• ICR Manual for Bench- and Pilot-Scale Treatment Studies,
EPA/814-B-96-003
• ICR Microbial Laboratory Manual, EPA/600-R-95-178
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Availability of Users'
Guide
AWWAICR Training
Additional Training
Materials
EPA Assistance
In addition, reprints of EPA chemical analytical methods to be used in the
ICR are included in "Reprints of EPA Methods for Chemical Analyses
under the Information Collection Rule," EPA 814-B-96-006.
These manuals will be provided at no cost to the systems that must comply
with the provisions of the ICR. Additional copies will be available for a
fee from the National Technical Information Service (NTIS), U.S.
Department of Commerce, 5285 Port Royal Road, Springfield, VA 22161.
Cost and ordering information can be obtained from NTIS by calling them
at their toll free number, 1-800-553-6847.
The ICR Water Utility Database System Users' Guide [EPA/814-B-96-
004] will also be provided free along with the software to the affected
utilities. Additional copies of the Users' Guide will be available from
NTIS.
ICR Training
The AWWA will be conducting approximately twenty-four, 2-day ICR
training courses in 9 or 10 locations around the country in September and
October of 1996. Several topics will be covered including "Understanding
the ICR," sampling,'and data handling. The primary emphasis of the
training, however, is the use of the data entry software. Hands-on training
will be provided in the development of an Initial Sampling Plan, entry of
monitoring results, and data reporting. Contact Rick Merrill at AWWA at
303-347-6185 for course offerings and details.
Some "stand-alone" training materials are also being developed by EPA
for the ICR. A 40-minute training video on the sample collection
procedures for microbiological sampling has been produced [EPA/814-V-
95-001] along with a companion guide entitled, "Information Collection
Requirements Rule - Protozoa and Enteric Virus Sample Collection
Procedures," [EPA/814-B-95-001]. A training manual entitled,
"Understanding the ICR," is also being developed for those interested in
learning more about the ICR. This manual should be available in late July
1996. Contact the EPA Safe Drinking Water Hotline at 1-800-426-4791
for ordering information.
Since the ICR is being directly implemented by EPA (rather than States),
inquiries should be directed to EPA. For implementation inquiries contact
the nearest EPA Regional Office (contact people are listed in the rule) or
contact the Safe Drinking Water Hotline at the number above. They will
be able to answer your question(s) or direct you to the appropriate person.
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