EPA to Update Two ICRs

Yesterday, the Environmental Protection Agency published two information collection request renewal (ICR) notices in the Federal Register. These current ICRs deal with chemical inventory reporting requirements under two community-right-to-know rules and the filing of vulnerability assessments and emergency response plans for water treatment facilities. The current Office of Management and Budget (OMB) approval for these ICRs will expire in the near future

Community RTK

The chemical inventory reporting requirement ICR (OMB Control No. 2050-0072) notice is the initial 60-day renewal notice for the requirements under sections 311 and 312 of the Emergency Planning and Community Right-to-Know Act (EPCRA). There is no change in the current reporting requirements and the only change in this ICR submission may be the number of facilities covered; that may be revised based on then currently available information when the ICR is actually submitted to the OMB for approval.

Public comments on this ICR are being solicited by EPA. Comments may be filed through the Federal eRulemaking Portal (http://www.regulations.gov/, Docket # EPA-HQ-SFUND-2004-0006). Comments need to be submitted before April 15, 2011.

Water Facility SVAs

The community water systems security reporting requirements ICR (OMB Control No. 2040-0253) notice is the follow-up 30-day notice for the requirements under Title IV of the Public Health Security and Bioterrorism Preparedness and Response Act of 2002. The 60-day notice was submitted last year on August 25, 2010 (75 FR 52326) and no public comments were submitted.

Public comments on this ICR are being solicited by EPA. Comments may be filed through the Federal eRulemaking Portal (http://www.regulations.gov/, Docket # EPA-HQ-OW-2003-0013). Comments need to be submitted before March 16, 2011.

There is an interesting anomaly associated with this ICR notice. The notice reports (76 FR 8362) that the expected number of respondents to be just 80 Community Water Systems. Now there are certainly more than 80 such systems that serve more than 3,300 people, so why this low number? The answer is that this is a one-time requirement. Congress made no provisions for EPA to require periodic or significant change in system reporting updates. It’s comforting to know that water facility security requirements are so static (SARCASM Warning).