F.PA*
Burden and Cost Calculations
for the
Unregulated Contaminant Monitoring Regulation
(2000-2005)
Supporting Documentation (Appendix B) for
"Information Collection Request for the
Unregulated Contaminant Monitoring Regulation"
March 1999
Prepared By:
The Cadmus Group, Inc.
135 Beaver Street
Waltham, Massachusetts 02154
Prepared For:
EPA Contract No. 68-C5-0061
Work Assignment 1-49
Ms. Rachel Sakata
Work Assignment Manager
U.S. Environmental Protection Agency
Office of Ground Water and Drinking Water
Washington, D.C. 20460
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DRAFT March 31,1999
TABLE OF CONTENTS
A. UCMR Cost and Burden Summary Page 1
B. Public Water Systems Page 17
1. Inventory Specifications Page 17
2. Labor Rates and System Income Assumptions Page 21
3. Assumptions for System Implementation Burden and Labor Cost Page 22
a, Reading the Regulations/State Letter Page 24
b. Monitoring Activities Page 24
c. Reporting and Record Keeping Page 26
d. Public Notification Page 27
4. Assumptions for Non-labor Costs to Public Water Systems Page 27
5. Estimates of Burden and Costs to Public Water Systems Page 32
a. Small Entity Flexibility Page 35
C. States/Primacy Agents Page 45
1. State Coordination with EPA Page 46
2. Data Management and Support Page 47
3. Laboratory Training Page 48
4. Program Implementation Page 48
5. Overhead Page 49
6. Estimating the Burden and Cost to States Page 50
D. Estimating Agency Burden and Cost Page 52
1. Regulatory Support Activities Page 53
a. Laboratory" Capacity and QA/QC Activities Page 53
b. Implementation of Small System Testing Program / Reporting and
Data Review Protocol Page 54
c. Technical Support / Guidance Document Development Page 54
d. Data Quality Review and Analysis Page 54
2. Analytical Costs for Small System Testing Program Page 55
a. Small System Analytical and Shipping Costs Page 55
b. Contractor Costs for Index and Small Pre-Screen Testing System
Site Visits ; Page 55
3. National and Regional Oversight / Data Analysis Page 56
4. Estimated EPA Costs Page 57
E. Change in Burden Page 59
1. Current ICR Page 59
2. "New" UCMR Baseline Page 60
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DRAFT-March 31,1999
TABLE OF TABLES
Table la. Assessment Monitoring Response and Burden Summary Page 4
Table Ib. Screening Surveys and Pre-screen Testing Response and Burden Summary .. Page 6
Table Ic. Total UCMR Response and Burden Summary Page 8
Table 2a. Assessment Monitoring Cost Summary Page 10
Table 2b. Total UCMR Cost Summary1 Page 12
Table 3a. Assessment Monitoring Burden and Cost Summary Page 15
Table 3b. UCMR Burden and Cost Summary Page 16
Table 4: National System Inventory and Average Number of Entry Points and
Water Sources Page 17
Table 5. Number of Index and Non-Index Systems to Conduct Assessment
Monitoring, by Source Water and System Size Page 18
Table 6. Number of Systems to Participate in Screening Survey and Pre-Screen
Testing, by Source Water and System Size Page 18
Table 7. Number of Publicly- and Privately-Owned Small Systems to
Participate in Assessment Monitoring Page 19
Table 8. Number of Publicly- and Privately-Owned Systems to Participate in
Assessment Monitoring, for Limited Funding Program Page 20
Table 9. Median System Revenues and Sales for Publicly- and Privately-Owned
Systems Page 22
Table 10. Schedule Assumptions for Estimating the Cost of System Activities Page 23
Table 11. Monitoring Frequency under Phase II/V Page 25
Table 12a. UCMR Assessment Monitoring /List 1 (1999) Contaminants:
analytical methods and estimated costs per analysis Page 28
Table 12b. UCMR Screening Survey / List 2 (1999) Contaminants: analytical methods
and estimated costs per analysis Page 28
Table 12c. UCMR Pre-Screen Testing / List 3 (1999) Contaminants: analytical
methods and estimated costs per analysis Page 29
Table 13. Multipliers for Coincidence Between UCMR and Phase II/V Analytical
Methods Page 30
Table 14. Shipping Costs Per Contaminant Group for Assessment Monitoring and
Screening Surveys Large Systems Only Page 32
Table 15. Yearly Cost to Systems for Implementation of the Total UCMR Program,
by System Size and by Type of Cost Page 33
Table 16a. Assessment Monitoring Per System and Per Response Costs Page 34
Table 16b. Total UCMR Per System and Per Response Costs Page 35
Table 17. EPA Costs for Smalt Systems under Full Implementation of UCMR Page 37
Table 18a. UCMR Full Implementation Scenario: Analysis for Publicly-Owned
Systems (2001-2005) Page 38
u
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DRAFT -March 31, 1999
Table of Tables, continued
Table 18b. UCMR Full Implementation Scenario: Analysis for Privately-Owned
Systems (2001-2005) Page 39
Table 19. EPA Costs for Small Systems Limited $4 million Program Page 42
Table 21. Schedule of State UCMR Activities Page 45
Table 22. Yearly Total Cost to All States/Primacy Agencies for Implementation of
UCMR, by Type of Cost Page 50
Table 23. UCMR Per State and Per Response Costs s Page 51
Table 24. Schedule of Agency Activities Page 52
Table 25. EPA Contractor Costs Page 56
Table 26. Yearly Cost to EPA for Implementation of the UCMR, by Type of Cost Page 57
Table 27. Summary of EPA Burdens and Costs for UCMR Implementation Page 58
Table 29. Number of Systems Sampling Under Existing Phase II/V Unregulated
Program Page 61
Table 30. Contaminants Required Under the Existing Phase II/V Unregulated
Monitoring Program Page 62
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DRAFT - March 31,1999
A. UCMR Cost and Burden Summary
The universe of respondents for this cost analysis of the proposed Unregulated Contaminant
Monitoring Regulation (UCMR) activities is clearly defined. In total, 3,574 public water systems
(PWSs) will participate in UCMR, monitoring from year 2001 through 2005. The proposed UCMR will
affect all 2,774 non-purchased Community Water Systems (CWSs) and non-purchased, Non-transient,
Non-Community Water Systems (NTNCWSs) which serve more than 10,000 people (large systems); the
800 CWSs and NTNCWSs serving 10,000 and fewer people (small systems) selected through a statistical
sample1; and, the 56 States/Primacy Agencies.
The UCMR program has three components: Assessment Monitoring, Screening Survey, and Pre-
Screen Testing. For all UCMR components, EPA will bear the costs of shipping and analysis for all
small systems included in EPA / State Plans. Assessment Monitoring, the major component of the
program, is comprised of three years of monitoring from 2001 to 2003. During this period
approximately one-third of the affected systems will monitor in each of the three years. These systems
will monitor for ten chemical and one microbiological contaminants which have analytical methods that
are currently available. The Screening Surveys will monitor for a two separate lists of contaminants for
which analytical methods are currently being refined. Two one-year rounds of Screening Survey
monitoring will be conducted on a subset of approximately 600 of the Assessment Monitoring systems
(both small and large), with 300 systems monitoring in each of the two years, 2002 and 2003. Finally, a
set of up to 200 small and large systems will be selected to participate in one year ofPre-Screen Testing
in 2004, which includes contaminants for which analytical methods are being developed. These systems
will be chosen by the States as those most vulnerable to the Pre-Screen Testing microbiological
contaminants. The actual implementation years for Screening Surveys and Pre-Screen Testing may vary
due to method development schedules. The cost calculations presented in this document assume the
UCMR implementation schedule that is described here. An illustration of this schedule is presented
below in Figure 1. Program descriptions and estimation assumptions are presented in detail in this
document.
The majority of regulated systems will only have to monitor during one of the five implementation
years. Frequency of response varies with system source water and by which UCMR program component
is being implemented. Ground water systems will sample and report twice during their year of
Assessment Monitoring. Surface water systems will sample and report four times during their year of
Assessment Monitoring. Systems conducting Screening Surveys are assumed to conduct monitoring and
reporting at the same time as their Assessment Monitoring, thus adding no labor burden or responses.
Respondent and response counts are presented in Table Ib to demonstrate how many respondents will
partake in the Screening Surveys. All systems conducting Pre-Screen Testing will sample twice during
1 In addition to the national representative sample of 800 small systems, up to about 150 small
systems could be selected for Pre-Screen Testing, which may or may not coincide with those in
the original sample. EPA assumes only 800 total small systems for cost estimation because it
presents a "worst-case" per system cost, with maximum total costs divided across the smallest
possible number of systems. This is further explained in Section B.3 of this document.
Cadmus/iPA.Drafi
"UCMR Cost Document Page 1
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DRAFT-March 31,1999
the year of monitoring (2004). This will add further burden and response frequency, since Pre-Screen f'~
Testing occurs after Assessment Monitoring is completed for the majority of respondents.
1999 2000 2001 2002 2003 2004 2005
* I ' 'I II*
; UCMR (1999); IMPLEMENTATION ACTIVITIES -
UCMR Issued: State Plans
Guidance Developed: Assessment Monitoring:
Available Inform EPA ^ List 1 (1999) Contaminants *
and PWSs A,, 2 774 L d goo s pwg
EPA *
Laboratories -4 Index System Monitoring ^
Operational UPto 30 Sml11 PWSs (2001-2005) w
Representative
Sample selected Screening Survey,:
DvtrA < List 2 (1999) Contaminants >
N . 2 Groups of 300 Large and Small PWSs
Contaminant Screening Survey Screening Survey
Occurrence "* Group / ^^ Group 2 *
Database (200 lor 2002) (2003 or 2004)
Operational
Pre-Screen=ng Testing: Pre.Screen Testing:
States Specify > Lis,3(1999)
Vulnerable Systems ^ Contaminants ^
Up to 200 Large
and Small PWSs
(2003 or 2004)
Analyze Results
and Data Quality
Next
Candidate ^ Nwt UCMR
Contaminant
List Issued
Figure 1
Proposed Implementation Timeline of
UCMR and Related Activities
Cadmus / EPA Draft
Or
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DRAFT-March 31,1999.
"' Tables^ 1 a, 1 b, and 1 c present summaries of the number of respondents, response frequency, and
national burden estimates for the UCMR implementation period of 2001-2005, as*well as for the start-up
year 2000 (State and EPA costs only). Table la presents information for Assessment Monitoring only.
Table Ib details the additional burden attributed to the Screening Survey and the Pre-Screen Testing.
Table Ic presents total respondent, response, and burden summaries for the full UCMR program (i.e.,
Assessment Monitoring, Screening Surveys, and Pre-Screen Testing). ~ :- ~
Tables 2a and 2b summarize national costs for the Assessment Monitoring component of the UCMR
and the full UCMR, respectively. The total labor and non-labor costs are presented for each category of
respondent. The total (full UCMR) labor burden to small systems is 4,676 hours, with a cost of $99,310,
and no non-labor costs. The total labor burden to large systems is 28,181 hours, with a labor cost of
$789,050, and non-labor costs for analysis and shipping of $27.1 million. The total burden to States over
the five year implementation period, plus one year of start-up is 54,182 hours, with a labor cost of $2.2
million. Estimated non-labor costs to States is minimal, with a total of $140,000 to fund updating of
State data systems. The EPA total burden over the same timeframe is 81,450 hours, with labor costs of
$3.3 million, and non-labor costs of $16.9 million.
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i&GMRCost Document "Page 3
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DRAFT-March 31,1999
Table la. Assessment Monitoring Response and Burden Summary1
Respondent Type
2000
2001
2002
2003
2004
2005
TOTAL
": Number of Respondents2
Small Systems3
Large Systems
=; States4
EPA
Total with EPA
Total without EPA
0
0
56
1
57
56
287
925
56
1
1,268
1,267
287
925
56
1
1,268
1,267
286
924
56
1
1,267
1,265
30
0
56
1
87
86
30
0
56
1
87
86
800
2,774
56
, 1
3,631
3,630
Frequency of Response5
Small Systems
Large Systems
! States
E EPA
Total with EPA
Total without EPA
0.0
0.0
4.0
1.0
3.9
4.0
2.6
2.9
4.0
1.0
2.9
2.9
2.6
2.9
4.0
1.0
2.9
2.9
2.6
2.9
4.0
1.0
2.9
2.9
2.6
0.0
4.0
1.0
3.5
3.5
2.6
0.0
4.0
1.0
3.5
3.5
3.0
2.9
24.0
1.0
3.3
3.3
" Total Number of Responses
; Small Systems
Large Systems
States
EPA
Total with EPA
i Total without EPA
0
0
224
1
225
224
752
2,727
224
1
3,704
3,703
752
2,727
224
1
3,704
3,703
752
2,727
224
1
3,704
3,703
78
0
224
1
303
302
78
0
224
1
303
302
2,412
8,180
1^44
6
11,942
11,936
dldmus / EPA Draft
(jfcMR Cost Document
-Page 4
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DRAFT - March 31, 1999
Table la. Assessment Monitoring Response and Burden Summary1
Respondent Type
2000
2001
2002
2003
2004
2005
Total Burden (hours) for AH Responses
Small Systems
Large Systems
States
EPA
Total with EPA
Total without EPA
0
0
16,953
15,075
32,028
16,953
1,299
9,252
6,764
12,375
29,690
17,315
1,254
9,252
8,832
12,375
31,713
19,338
1,254
9,252
7,043
16,875
34,424
17,549
113
0
7,295
12,375
19,783
7,408
113
0
7,295
12,375
19,783
J7,408
TOTAL
4,033
27,756
54,182
81,450
167,421
85,971
I. Although EPA is not considered a respondent to the UCMR regulations, Agency burdens are shown here to illustrate the national costs of the
program. National totals are shown with and without the inclusion of Agency costs.
2. Number of respondents does not add across because some respondents participate during more than one year (e.g., States and Index systems).
3. Index systems are a subset of the national representative sample of small systems. These 30 systems will conduct Assessment Monitoring during
each of the five years of the UCMR implementation period (2001-2005).
4. States will run the overall UCMR program each year. Costs will vary with the amount of system activity. During the year 2000, States will be
reviewing and responding to EPA's proposed State plans, as well as completing their primacy applications.
5. Ground water systems must monitor and report at a frequency of two times in the year that they monitor, and surface water systems must monitor
four times in the year that they monitor. States are assumed to have a response frequency of four times per year, since they must submit quarterly
updates to the SDWIS data base. The frequency estimates refer to the frequency of response for only those respondents that have any reporting
requirements during a given year.
Cadmus/EPA Draft
UCMR Cost Document
Page 5
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DRAFT-March 31,1999
Table Ib. Screening Surveys and Pre-screen Testing Response and Burden Summary
Respondent Type
2000
2001
2002
Screening Survey
One1
2003
Screening Survey
Two
2004
Pre-Screen
Testing3
2005
TOTAL
Number of Respondents
Small Systems
Large Systems
States
EPA
Total with EPA
Total without EPA
0
0
n/a
n/a
0
0
0
0
n/a
n/a
0
0
180
120
n/a
n/a
300
300
180
120
n/a
n/a
300
300
158
42
n/a
n/a
200
200
0
0
n/a
n/a
0
0
0
0
n/a
n/a
0
0
Frequency of Response
Small Systems
Large Systems
States
EPA
Total with EPA
Total without EPA
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
2.5
3.3
0.0
0.0
2.8
2.8
2.5
3.3
0.0
0.0
2.8
2.8
2.0
2.0
0.0
0.0
2.0
2.0
0.0
0.0
0.0
0.0
0.0
0.0
2.4
3.1
0.0
0.0
2.6
2.6
Total Number of Responses
Small Systems
Large Systems
States
0
0
0
0
0
0
452
400
0
452
400
0
316
84
0
0
0
0
1,220
884
0
Cadmus / EPA Draft
UCMR Cost Document
Page 6
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DRAFT-March 31,1999
Table Ib. Screening Surveys and Pre-screen Testing Response and Burden Summary
Respondent Type
EPA
Total with EPA
Total without EPA
2000
0
0
0
2001
0
0
0
2002
Screening Survey
One'
0
852
852
2003
Screening Survey
Two
0
852
852
2004
Pre-Screen
Testing3
0
400
400
2005
0
0
0
TOTAL
0
2,104
2,104
Total Burden (hours) for All Responses
Small Systems
Large Systems
States
EPA
Total with EPA
Total without EPA
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
643
424
0
0
1,067
1,067
0
0
0
0
0
0
643
424
0
0
1,067
1,067
1. Number of Screening Survey respondents and responses are presented here in Table Ib, but are not additive into the total UCMR program
(Table Ic), since Screening Survey responses/respondents will coincide with the Assessment Monitoring responses/respondents. The same
respondents will be responding the same number of times, only with more information (e.i., both Assessment Monitoring and Screening
Survey contaminant data are submitted).
2. Pre-Screen Testing responses/respondents do not coincide with Assessment Monitoring. However, it is assumed for the cost estimates that the
Pre-Screen Testing systems are a subset of the Assessment Monitoring systems. This will not be true during actual implementation. Rather,
those systems most vulnerable to the Pre-Screen Testing contaminants will be chosen from each State, regardless of their participation in
Assessment Monitoring. By assuming that all are a subset of those systems already monitoring, the most conservative per system cost and
burden estimates are achieved. Total costs are divided across the fewest possible number of systems.
Cadmus / EPA Draft
UCMR Cost Document
Page?
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DRAFT-March 31,1999
Table Ic. Total UCMR Response and Burden Summary
, Respondent
M Type
2000
2001
2002
2003
2004
2005
TOTAL
Number of Respondents'
'" Small Systems
Large Systems
States
EPA
Total with EPA
Total without
EPA
0
0
56
1
57
56
287
925
56
1
1,268
1,267
287
925
56
1
1,268
1,267
286
924
56
1
1,266
1,265
188
42
56
1
287
286
30
0
56
1
87
86
800
2,774
56
1
3,631
3,630
' Frequency of Response2
Small Systems
Large Systems
States
EPA
Total with EPA
Total without
EPA
0.0
0.0
4.0
1.0
3.9
4.0
2.6
2.9
4.0
1.0
2.9
2.9
2.6
2.9
4.0
1.0
2.9
2.9
2.6
3.0
4.0
1.0
2.9
2.9
2.1
2.0
4.0
1.0
2.4
2.5
2.6
0.0
4.0
1,0
3.5
3,5
3.4
3.0
24.0
6.0
3.4
3.4
Total Number of Responses
Small Systems
Large Systems
States
0
0
224
752
2,727
224
752
2,727
224
752
2,727
224
394
84
224
78
0
224
2,728
8,264
1,344
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UCMR Cost Document
PageS
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DRAFT-March 31,1999
Table Ic. Total UCMR Response and Burden Summary
Respondent
Type
EPA
Total with EPA
Total without
EPA
2000
1
225
224
2001
1
3,704
3,703
2002
1
3,704
3,703
2003
1
3,704
3,703
2004
1
703
702
2005
1
303
302
TOTAL
6
12,342
12,336
Total Burden (hours) for All Responses
Small Systems
Large Systems
States
EPA
Total with EPA
Total without
EPA
0
0
16,953
15,075
32,028
16,953
1,299
9,252
6,764
12,375
29,690
17,315
1,254
9,252
8,832
12,375
31,713
19,338
1,254
9,252
7,043
16,875
34,424
17,549
756
424
7,295
12,375
20,850
8,475
113
0
7,295
12,375
19,783
7,408
4,676
28,180
54,182
81,450
168,488
87,038
1. Number of respondents does not add across because some respondents participate during more than one year (e.g., States, Index Systems, or
systems conducting Pre-Screen Testing).
2. Frequency estimates refer to the frequency of response for only those respondents that have any reporting requirements during a given year.
Cadmus / EPA Draft
UCMR Cost Document
, Page 9,
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DRAFT-March 31, 1999
Table 2a. Assessment Monitoring Cost Summary1
Type of Cost
2000
2001
2002
2003
2004
2005
TOTAL
Small Systems
Labor Cost $0
Non-Labor Cost $0
Total Small System Cost $0
$27,870
$0
$27,870
$26,910
$0
$26,910
$26,910
$0
$26,910
$2,500
$0
$2,500
$2,500
$0
$2,500
$86,690
$0
$86,690
Large Systems
Labor Cost
Non-Labor Cost
Total Large System Cost
$0
$0
$0
$259,060
$7,747,520
$8,006,580
$259,060
$7,747,520
$8,006,580
$259,060
$7,747,520
$8,006,580
$0
$0
$0
$0
$0
$0
$777,180
$23,242,560
$24,019,740
States
Labor Cost
Non-Labor Cost
Total State Cost
$678,130
$140,000
$818,130
$270,550
$0
$270,550
$353,290
$0
$353,290
$281,700
$0
$281,700
$291,800
$0
$291,800
$291,800
$0
$291,800
$2,167,270
$140,000
$2,307,270
EPA '
Labor Cost
Non-Labor Cost
Total EPA Cost
$603,000
$873,460
$1,476,460
$495,000
$3,048,730
$3,543,730
$495,000
$2,992,000
$3,487,000
$675,000
$3,052,000
$3,727,000
$495,000
$1,340,990
$1,835,990
$495,000
$1,152,540
$1,647,540
$3,258,000
$12,459,720
$15,717,720
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UCMR Cost Document
Page 10
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DRAFT -March 31, 1999
Table 2a. Assessment Monitoring Cost Summary1
Type of Cost
2000
2001
2002
2003
2004
2005
f
TOTAL
National Total
i
Assessment Monitoring
Total with EPA
Assessment Monitoring
Total without EPA
$2,294,590
5818,130
$11,848,730
$8,305,000
$11,873,780
$8,386,780
$12,042,190
$8,315,190
$2,130,290
$294,300
$1,941,840
$294,300
$42,131,420
$26,413,700
1. Further detail regarding labor and non-labor costs are found in Sections B-D of this document.
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UCMR Cost Document
Page 11
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DRAFT - March 31, 1999
Table 2b. Total UCMR Cost Summary1
Type of Cost
2000
2001
2002
2003
2004
2005
TOTAL
Small Systems
Labor Cost
Non-Labor Cost
Total Small System Cost
$0
$0
$0
$27,870
$0
$27,870
$26,910
$0
$26,910
$26,910
$0
$26,910
$15,120
$0
$15,120
$2,500
$0
$2,500
$99,310
$0
$99J10
Large Systems
Labor Cost
Non-Labor Cost
Total Large System Cost
$0
$0
$0
$259,060
$7,747,520
$8,006,580
$259,060
$9,168,770
$9.427,830
$259,060
$9,217,310
$9,476,370
$11,870
$983,660
$995.530
$0
$0
SO
$789,050
$27,117,260
$27,906,310
States
Labor Cost
Non-Labor Cost
Total State Cost
$678,130
$140,000
$818,130
$270,550
$0
$270,550
$353,290
$0
$353,290
$281,700
$0
$281,700
$291,800
$0
$291,800
$291,800
$0
$291,800
$2,167,270
$140,000
$2,307,270
EPA
Labor Cost
Non-Labor Cost
Total EPA Cost
$603,000
$873,460
$1.476,460
$495,000
$3,048,730
$3,543,730
$495,000
$3,758,030
$4,253,030
$675,000
$3,843,200
$4,518,200
$495,000
$4,194,610
$4,689,610
$495,000
$1,152,540
$1,647,540
$3,258,000
$16,870,570
$20,128,570
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UCMR Cost Document
Ft-' ' i " \... ?'.* 5(f ! }.-' V
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DRAFT-March 31,1999
ii
1 '
Table 2b. Total UCMR Cost Summary1 '-
~\ "*i
Type of Cost
2000
2001
2002
2003
2004
2005
TOTAL
National Total
UCMR Total with EPA
UCMR Total without EPA
$2,294,590
$818,130
$11,848,730
$8,305,000
$14,061,060
$9,808,030
$14,303,180
$9,784,980
$5,992,060
$1,302,450
$1,941,840
$294,300
$50,441,460
$30,312,890
. Further detail regarding labor and non-labor costs are found in Sections B-D of this document.
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Tables 3a (Assessment Monitoring) and 3b (full UCMR) present per respondent and per response
burdens and costs over the entire implementation period. The tables also present average annual burdens
and costs. System burden includes time required to read the regulation or State letter, participate in
sample collection, report results, and maintain records. The full UCMR average burden for small ,
systems over the 5-year period is estimated to be 5.8 hours per system, or an average annual burden of
1.2 hours per year, with an associated average annual cost of $25. The average burden for large systems
is estimated to be 10.2 hours, or approximately 2.0 hours per year, with an average annual labor cost of
$57. Average annual non-labor cost per large system is estimated to be $1,955.
The average total burden hours (2000-2005) for a State or other primacy agent for the Public Water
System Supervision Program is estimated to be 968 hours over the implementation period, or 194 hours
per year (i.e., approximately 1/10 of an FTE).2 This burden includes tune to read the regulation, inform
systems of their requirements under the regulation, review and respond to EPA's monitoring plan,
provide training for laboratories, review monitoring results, maintain records, report results to EPA's
Safe Drinking Water Information System (SDWIS), and issue enforcement actions. Many of these
activities are conducted in coincidence with current drinking water program requirements. EPA's cost
and burden were discussed above.
2 Burdens and costs for the States and EPA were considered over the period 2000-2005 (i.e., the
UCMR period, plus one start-up year). The 6-year total, however, was averaged over 5 years, to
represent the average annual cost over the implementation period.
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Table 3a. Assessment Monitoring Burden and Cost Summary ~ -
Burden (hours) /
Cost (dollars)
Small
Systems
Large
Systems
States1
EPA1
National
Average with
EPA2
National
Average
without EPA
ASSESSMENT MONITORING ONLY - 5-Year Average Costs
Ave. # of Responses Per
Respondent
Labor Cost Per
Respondent
Non-Labor Cost Per
Respondent
Total Cost (Labor plus
Non-Labor)
Total Cost Per Response
Total Burden Per
Respondent
Total Burden Per
Response
3.0
$108
SO
$108
$36
5.0
1.7
2.9
$280
$8,379
$8,659
$2,936
10.0
3.4
24.0
$38,701
$2,500
$41,201
$1,717
967.5
40.3
6.0
$3,258,000
$12,459,720
$15,717,720
$2,619,620
81,450.0
13,575.0
3.3
$1,732
$9,871
$11,603
$3,528
46.1
14.0
3.3
$835
$6,441
$7,277
$2,213
23.7
7.2
ASSESSMENT MONITORING ONLY -Average Annual Costs
Ave. # of Responses Per
Respondent
Labor Cost Per
Respondent
Non-Labor Cost Per
Respondent
Total Cost (Labor plus
Non-Labor)
Total Cost Per Response
Total Burden Per
Respondent
Total Burden Per
Response
0.6
$22
$0
$22
$7
1.0
0.3
0.6
$56
$1,676
$1,732
$587
2.0
0.7
4.8
$7,740
$500
$8,240
$343
193.5
8.1
1.2
$651,600
$2,491,944
$3,143,544
$523,924
16,290.0
2,715.0
0.7
$346
$1,974
$2,321
$706
9.2
2.8
0.7
$167
$1,288
$1,455
$443
4.7
1.4
1. Burdens and costs for the States and EPA were considered over the period 2000-2005 (i.e., the
UCMR period, plus one start-up year). The 6-year total, however, was averaged over 5 years, in
order to represent the average annual cost over the implementation period.
2. National average burdens and costs vary greatly between the State respondents and the system
respondents. This should be taken into consideration when looking at the national average with
or without EPA.
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Table 3b. UCMR Burden and Cost Summary -. j _
Burden (hours) /
Cost (dollars)
Small
Systems
Large
Systems
States'
EPA'
National
Average with
EPA1
National
Average
without EPA
TOTAL UCMR PROGRAM 5- Year Average Costs
Ave. # of Responses Per
Respondent
Labor Cost Per
Respondent
Non-Labor Cost Per
Respondent
Total Cost (Labor plus
Non-Labor)
Total Cost Per Response
Total Burden Per
Respondent
Total Burden Per
Response
3.4
$124
$0
$124
$36
5.8
1.7
3.0
$284
$9,776
$10,060
$3,377
10.2
3.4
24.0
$38,701
$2,500
$41,201
$1,717
967.5
40.3
6.0
$3,258,000
$16,870,570
$20,128,570
$3,354,762
81,450.0
13,575.0
3.4
$1,739
$12,153
$13,892
$4,087
46.4
13.7
3.4
$842
$7,509
$8,351
$2,457
24.0
7.1
TOTAL UCMR PROGRAM - Average Annual Costs
Ave. # of Responses Per
Respondent
Labor Cost Per
Respondent
Non-Labor Cost Per
Respondent
Total Cost (Labor plus
Non-Labor)
Total Cost Per Response
Total Burden Per
Respondent
Total Burden Per
Response
0.7
$25
$0
$25
$7
1.2
0.3
0.6
$57
$1,955
$2,012
$675
2.0
0.7
4.8
$7,740
$500
$8,240
$343
193.5
8.1
1.2
$651,600
$3,374,114
$4,025,714
$670,952
16,290.0
2,715.0
0.7
$348
$2,431
$2,778
$817
9.3
2.7
0.7
$168
$1,502
$1,670
$491
4.8
1.4
1. Burdens and costs for the States and EPA were considered over the period 2000-2005 (i.e., the
UCMR period, plus one start-up year). The 6-year total, however, was averaged over 5 years, in
order to represent the average annual cost over the implementation period.
2. National average burdens and costs vary greatly between the State respondents and the system
respondents. This should be taken into consideration when looking at the national average with
or without EPA.
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B. Public Water Systems
1. Inventory Specifications
Inventory figures are obtained from SDWIS, January 17,1997. These inventory figures have
oeen used because this particular database query was edited to improve accuracy (e.g.,
eliminating PWSs that were no longer in service, rectifying water source categories, and other
possible discrepancies between SDWIS and actual inventory information). This edited inventory
was used for the recent Revision of Variance and Exemption Regulations (63 FR 43833-43851
(August 14,1998)), as well as other recent drinking water program cost analyses.
Number of entry points are derived from the 1993 Association of State Drinking Water
Administrators (ASDWA) Survey on Public Water System Monitoring Costs and State
Laboratory Capacity.
Regulated systems are limited to non-purchased CWSs and non-purchased NTNCWSs (i.e.,
those systems that are regulated under the UCMR). Transient Non-Community Water Systems
and other systems that primarily use purchased water are excluded from the UCMR requirements
(and the inventory used here).
National inventory figures categorized by size and source, including corresponding average entry
points, are shown in Table 4 below.
Table 4: National System Inventory and Average Number of Entry Points and Water Sources
Size Category
500 and under
501 to 3,300
3,301 to
10,000
10,001 to
50,000
over 50,000
TOTAL
#of
Systems
Average #
of Entry
Points
Average #
of Water
Sources
Ground Water
46,200
12,306
2,404
1,254
204
62,368
1.3
2.1
3.8
7.5
22.7
1.3
2.1
3.8
4.0
4.0
#of
Systems
Average #
of Entry
Points
Average #
of Water
Sources
Surface Water
1,900
1,820
1,006
927
389
6,042
1.5
1.9
1.7
1.9
3.7
1.5
1.9
1.7
1.9
3.7
Total # of
Systems
TOTAL
48,100
14,126
3,410
2,181
593
68,410
All systems serving greater than 10,000 people (large systems) will be required to conduct
Assessment Monitoring under the UCMR. Only a national representative sample of 800 systems
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serving 10,000 or fewer people (small systems) will be required to conduct Assessment
Monitoring. The total numbers of systems that will conduct Assessment Monitoring are listed
below in Table 5.
Table 5. Number of Index and Non-Index Systems to Conduct Assessment Monitoring, by
Source Water and System Size1
Size Category
500 and under
501 to 3,300
3,301 to 10,000
Subtotal
il 0,000
10,001 to 50,000
50,001 and over
Subtotal
>10,000
TOTAL
Ground Water Systems
Non-Index
Systems
96
231
202
529
1,254
204
1,458
1,987
Index Systems
3
9
9
21
n/a
n/a
n/a
21
Surface Water Systems
Non-Index
Systems
11
81
149
241
927
389
1,316
1,557
Index Systems
0
3
6
9
n/a
n/a
n/a
9
Total -All
Systems
110
324
366
800
2,181
593
2,774
3,574
1. Index systems will sample during each of the 5 years, 2001-2005 for the List 1 (1999) Contaminants.
Each Non-Index and large system will sample for the List 1 (1999) Contaminants during one of three
years (2001-2003), with one-third of the total number of systems assumed to sample during each of
these three years.
Approximately 600 of the Assessment Monitoring systems (2 sets of 300 each) will be selected
to conduct Screening Surveys. Another set of up to 200 systems will be chosen from all small
and large systems to participate in Pre-Screen Testing. The numbers of systems participating,
categorized by ownership type, source water, and system size, are presented below in Table 6.
Table 6. Number of Systems to Participate in Screening Survey and Pre-Screen
Testing, by Source Water and System Size1
Size Category
500 and under
Ground Water Systems
Screening
Surveys
(2002 and 2003)2
54
Pre-Screen
Testing
(2004)3
25
Surface Water Systems
Screening
Surveys
(2002 and 2003)
6
Pre-Screen
Testing
(2004)
33
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Table 6. Number of Systems to Participate in Screening Survey and Pre-Screen
Testing, by Source Water and System Size1
Size Category
501 to 3,300
3,301 to 10,000
Subtotal £10,000
10,001 to 50,000
50,001 and over
Subtotal > 10,000
TOTAL
Ground Water Systems
Screening
Surveys
(2002 and2003)2
45
35
134
27
13
40
174
Pre-Screen
Testing
(2004)1
25
25
75
20
5
25
100
Surface Water Systems
Screening
Surveys
(2002 and 2003)
15
25
46
33
47
80
126
Pre-Screen
Testing
(2004)
34
16
83
12
5
17
100
1. Numbers of systems presented here are used for cost estimation purposes only. Actual distribution of
systems will be determined through statistical sampling. For simplification, it was assumed that no
Index systems will be selected to participate in Screening Surveys or Pre-Screen Testing.
2. There will be two Screening Survey years (2002 and 2003). During each Screening Survey year a
representative sub-sample of 300 Assessment Monitoring systems will be chosen to monitor.
3. Pre-Screen Testing will occur during only one year (2004). These systems will be identified by each
State as the most vulnerable to the List 3 (1999) Contaminants.
In implementing the Regulatory Flexibility Act (RFA), EPA suggests that economic impacts be
analyzed separately for privately-owned versus publicly-owned systems, related to the different
economic characteristics of these ownership types. EPA assumes that the distribution of the
national representative sample of small systems will reflect the proportions of publicly- and
privately-owned systems in the national inventory. The estimated distribution of the
representative sample of small systems, categorized by ownership type, source water, and system
size, is presented below in Table 7.
Table 7. Number of Publicly- and Privately-Owned Small Systems to Participate in
Assessment Monitoring
Size Category
Publicly-Owned Systems
Non-Index
Systems
Index Systems
Privately-Owned Systems
Non-Index
Systems
Index Systems
Total - AH
Systems
GROUND WATER SYSTEMS
SOO and under
20
1
76
2
99
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Table 7. Number of Publicly- and Privately-Owned Small Systems to Participate in
Assessment Monitoring
Size Category
501 to 3,300
3,301 to 10,000
Subtotal Ground
Water Systems
Publicly-Owned Systems
Non-Index
Systems
159
158
337
Index Systems
6
7
14
Privately-Owned Systems
Non-Index
Systems
72
44
192
Index Systems
3
2
7
Total - All
Systems
240
211
550
SURFACE WATER SYSTEMS
500 and under
501 to 3,300
3,301 to 10,000
Subtotal Surface
Water Systems
TOTAL
3
56
116
175
512
0
2
5
7
21
8
25
33
66
258
0
1
1
2
9
11
84
155
250
800
To fulfill RFA requirements, EPA has also estimated economic impacts to small systems under a
"worst case" limited funding scenario. Under this worst case, EPA would be limited to the
existing $4 million that is currently set-aside for small system testing. It is estimated that EPA
could fund an Assessment Monitoring testing program for approximately 396 small systems
under these limited funding conditions. The estimated distribution of the small systems in the
limited funding scenario is presented below in Table 8.
Table 8. Number of Publicly- and Privately-Owned Systems to Participate in Assessment
Monitoring, for Limited Funding Program1
Size Category
Publicly-Owned Systems
Non-Index
Systems
Index Systems
Privately-Owned Systems
Non-Index
Systems
Index Systems
Total - All
Systems
GROUND WATER SYSTEMS
500 and under
501 to 3,300
3,301 to 10,000
Subtotal Ground
Water Systems
11
80
79
170
0
2
2
4
38
36
22
96
1
1
1
3
50
119
104
273
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DRAFT - March 31,1999
Table 8. Number of Publicly- and Privately-Owned Systems to Participate in Assessment
Monitoring, for Limited Funding Program1
Size Category
Publicly-Owned Systems
Non-Index
Systems
Index Systems
Privately-Owned Systems
Non-Index
Systems
Index Systems
Total -All
Systems
SURFACE WATER SYSTEMS
500 and under
501 to 3,300
3,301 to 10,000
Subtotal Surface
Water Systems
TOTAL
1
28
58
87
257
0
1
2
3
7
4
13
16
33
129
0
0
0
0
3
5
42
76
123
396
1. The Limited Funding Program assumes that the only funds available to run the program are those that are
currently in hand $4 million of set aside funds from Federal Fiscal Years 1998 and 1999. This is a "worst case"
funding scenario.
2. Labor Rates and System Income Assumptions
An average hourly labor rate of $14.50 is assumed for systems serving 3,300 or fewer people.
An average hourly labor rate of $28 is assumed for systems serving more than 3,300 people.
These rates are taken from the Small Water Systems Byproducts Treatment and Disposal Cost
Document, April 1993, and are the most currently available labor rates which directly correspond
to the drinking water industry. Hourly system labor rates used for this analysis assume that
system UCMR activities are primarily not conducted by engineering staff.
As specified in EPA guidance for implementation of the RFA, different tests are used to analyze
small entity impacts on privately-owned versus publicly-owned entities. For publicly-owned
systems, EPA guidance suggests that a "revenue test" be used, which compares annual system
costs attributed to the rule to the system's annual revenues. Privately-owned systems are
typically submitted to a "sales test", which involves the analogous comparison of UCMR-related
costs to a privately-owned system's sales. The median revenues and sales used for these
comparisons are listed below in Table 9, and are obtained from the 1995 Community Water
System Survey.
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Table 9. Median System Revenues and Sales for Publicly- and
Privately-Owned Systems
Size Category
Median Revenue for
Publicly-Owned
Systems
Median Sales for
Privately-Owned
Systems
Ground Water
500 and under
501 to 3,300
3,301 to 10,000
10,001 to 50,000
50,001 and over
$16,458
$106,706
$479,865
$1,643,510
$6,868,318
$15,696
$111,988
$623,116
$1,649,001
$10,338,454
Surface Water
500 and under
501 to 3,300
3,301 to 10,000
10,001 to 50,000
50,001 and over
$28,037 $22,704
$183,408 $151,263
$708,815 $572,535
$2,252,368 $2,719,214
$12,320,419 $12,611,378
3. Assumptions for System Implementation Burden and Labor Cost
Those systems subject to the UCMR include all large non-purchased CWSs and NTNCWSs, as well
as small systems that are chosen as part of the population-weighted representative sample of systems
serving 10,000 or fewer people. Table 5 and 6, above, list the number of systems assumed to be
participating in Assessment Monitoring, Screening Surveys, and Pre-Screen Testing for each size and
source category.
System implementation requirements are categorized into four major activities, as follows:
Reading regulations and/or requirement letter from States
Monitoring activities
Reporting and Record keeping
Public Notification
Table 10 illustrates the years in which these required system activities are assumed to occur.
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Table 10. Schedule Assumptions for Estimating the Cost of System Activities1
Activity
Reading regulations/
State letter
' ,~|
Monitoring activities2
conducted by systems
serving s 10,000;
except Index systems
Monitoring activities
conducted for Index
systems (serving
s 10,000)*
Monitoring conducted
by all systems serving
> 10,000
Reporting/ Record
keeping
Public Notification
2000
No system activities; monitoring begins in 2001
i
2001
1/3 of Non-Index
systems, plus all Index
systems
Ground water AM3
chemicals at 2x/yr for
1/3 of systems;
Surface water: AM
chemicals at 4x/yr for
1/3 of systems;
All: Aeromonas 2x/yr at
2 distribution points for
1/3 of systems
Ground water: AM at
2x/yr for all Index
systems;
Surface water: AM at
4x/yr for all Index
systems;
All: Aeromonas 2x/yr at
2 distribution points for
all systems
Ground water: AM at
2x/yrforl/3of
systems;
Surface water: AM at
4x/yrforl/3of
systems;
AH: Aeromonas 2x/yr at
2 distribution points for
1/3 of systems
2002
1/3 of Non-
Index
systems
same as in
2001, plus
SSI4 for
subset of
systems, at
same
frequencies
as AM
same as in
2001
same as in
2001, plus
SSI for
subset of
systems, at
same
frequencies
as AM
chemicals
2003
1/3 of Non-
Index
systems
same as in
2002, but
new subset
of systems to
conduct SS24
same as in
2001
same as in
2002, but
new subset
of systems to
conduct SS2
2004
none
PST5 for
approx. ISO
small
systems, at
2x/yr for
both ground
and surface
water
systems
same as in
2001
PST for
approx. 50
systems, at
frequency of
2x/yr for
both ground
and surface
water
systems
2005
none
none
same as in
2001
none
Same as the monitoring schedule. Monitoring data reported to States must be in
electronic format
Part of the annual Consumer Confidence Report and/or other public notice requirements,
thus no burden here
1. The schedule in this table is an approximation of the expected UCMR schedule that has been established
for cost estimation purposes. Actual monitoring dates may vary, but will not impact overall cost
estimations. See Tables la, Ib, and Ic for numbers of systems participating in each component of the
UCMR.
2. Monitoring activities include: receipt of sample kit, reading monitoring instructions, and collecting and
shipping samples.
3. "AM" refers to Assessment Monitoring, the primary monitoring component of the UCMR monitoring
cycle, to be conducted by 3,574 systems for the List 1 (1999) Contaminants.
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4. SS1 and SS2 refer to the 2 rounds of Screening Surveys, to be conducted during 2002 (SS1) and 2003 * ~T
(SS2) by two separate groups of 300 systems (subsets of those conducting Assessment Monitoring). It is ~.l.
assumed that where possible, monitoring will be conducted coincident with Assessment Monitoring.
5. PST refers to Pre-Screen Testing, the third component of UCMR, conducted by up to 200 systems in
2004 that are identified as the most vulnerable to the List 3 (1999) Contaminants.
6. Index Systems are a subset of the national representative sample of small systems. They will conduct
Assessment Monitoring during each of the five years of the UCMR implementation period (2001-2005).
a Reading the Regulations/State Letter
Systems are assumed to read the UCMR regulations and/or a State issued guidance letter at the
beginning of their required monitoring year (i.e., one-third of the systems in each of the three
Assessment Monitoring years). Small systems can rely on the State for information pertaining to the
regulation, rather than reading the regulation. These systems are expected to spend one hour, on average,
reading a letter from the State that outlines the requirements of the UCMR. The 2,774 large systems are
assumed to read both the regulation and information from the State, requiring on average 1/2 day (4
hours). National costs are estimated by multiplying the average burden hours by the average system
labor rate, times the number of systems effected.
b. Monitoring Activities
For the primary component of UCMR implementation Assessment Monitoring the chemical
contaminants will be sampled at each entry point to the distribution system. All systems will sample for
the one Assessment Monitoring microbiological contaminant, Aeromonas hydrophila, at two points in
the distribution system at a frequency of two times during the monitoring year. The number of chemical
samples required varies by primary water source. Ground water systems are required to monitor at a rate
of two times per year. Surface water systems are required to monitor four times per year.
For Assessment Monitoring, it is assumed that one-third of all small Non-Index and large systems
will conduct monitoring activities in each year from 2001 through 2003, with an estimated burden of 0.5
hours per entry point to collect chemical samples for analysis. This monitoring burden includes: receipt
of monitoring kit, reading laboratory instructions, and collection and shipping of samples. These same
systems are assumed to collect samples for Aeromonas hydrophila analysis along with their monitoring
required under the Total Coliform Rule, thus no additional labor burden is allotted. Index systems will
assist an EPA-appointed sample collector to collect Assessment Monitoring samples during each year
from 2001 to 2005. Because Index system cannot choose the timing of their monitoring activities, they
are assumed to require an average of 0.25 hours to assist the sample collector at each monitoring point.
All small systems in the national representative sample (both Index and Non-Index) will also be
required to collect a sample for standard water quality parameters (e.g., basic ions, nitrate) at each
sampling station (i.e., all entry and distribution system sampling points). EPA will also pay for this
testing. No additional labor burden is allotted to systems, since they will already be collecting samples at
each sampling station.
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For the Screening Surveys, systems will be chosen from systems conducting the Assessment
Monitoring. Separate subsets of 300 systems will be chosen for each of the two Screening Surveys, one
to be conducted in 2002 and the other in 2003 (see Table 6). Monitoring frequencies and burdens are
assumed to be the same as those described for the chemical contaminants in the Assessment Monitoring
program.
A targeted sample of up to 200 of the nations most vulnerable systems will participate in Pre-Screen
Testing. For small systems, system staff will assist an EPA contractor with the monitoring for the
microbiological contaminants listed in Table 12c. Both ground and surface water systems conducting
Pre-Screen Testing will sample twice during 2004, at locations related to system water sources (a
maximum of 4 sampling stations is assumed). Because of the complexity associated with the microbial
contaminant monitoring and analysis, EPA contractors will conduct the monitoring and EPA-designated
laboratories will conduct the analyses. Small systems are assumed to spend one hour at each sampling
station to assist in the monitoring effort. EPA will bear the analytical and shipping costs for small
systems. Large systems that are chosen to participate in Pre-Screen Testing will be required to conduct
their own sampling, to use EPA-designated laboratories for sample analysis, and to pay for the analysis
of samples. Frequency and maximum number of sampling stations are the same as specified for small
systems, with 1.5 hours of burden assumed for each sampling station.
For Assessment Monitoring, it is assumed that where possible, systems (except for Index systems)
will coordinate their sampling with the Phase II/V Standard Monitoring Framework (40 CFR Part 141)
for sampling of chemical contaminants. Based on the 1998 draft of "Information Collection Request for
Chemical Monitoring Reform" (CM$(. ICR) (OMB # 2040-0090, EPA # 0270-37), systems are assumed
to be monitoring under the Phase II/V Rule at a rate ranging from one to four times in a given year of a
three-year monitoring cycle. Table 11 illustrates the percentages of systems that are assumed to be
currently monitoring at the various rates under Phase II/V framework. No burden is allotted if the
monitoring event coincides with Phase II/V monitoring. For entry point monitoring, at least one of each
system's required monitoring events is assumed to cause no additional labor burden, since all systems
must monitor annually for nitrate (94.2 percent of ground water systems and 94.7 percent of surface
water surface). Systems on quarterly monitoring (5.6 percent of ground water systems and 4.3 percent of
surface water systems) for either Phase II/V Volatile Organics Compounds (VOCs) or Synthetic Organic
Compounds (SOCs) are assumed to incur no additional labor burden for collecting samples associated
with the UCMR program. Ground water systems are assumed to have zero burden where Phase II/V
monitoring is twice or more per year (0.2 percent). Surface water systems which are monitoring twice
per year under-Phase II/V (1 percent) were assumed to incur a burden for two of their four required
UCMR monitoring events.
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Table 11. Monitoring Frequency under Phase n/V
Minimum Monitoring
Frequency
Once per Year1
Twice per Year
Four times per Year
Source
Ground Water
94.2%
0.2%
5.6%
Surface Water
94.7%
1.0%
4.3%
1. All systems are required to collect nitrate at entry points to the distribution system once a year,
under 40 CFR 141.23.
All Screening Survey monitoring events are assumed to coincide with Assessment Monitoring, since
the Screening Survey systems are a subset of those conducting Assessment Monitoring. No coincident
monitoring is assumed for the Pre-Screen Testing, since it occurs after Assessment Monitoring is
completed, and since samples may be collected at different locations.
Although Pre-Screen Testing systems will be chosen by States from all small and large systems, for
the cost analysis EPA assumes that all Pre-Screen Testing is conducted by systems that were part of the
Assessment Monitoring program. First, States will nominate systems most vulnerable to the List 3
(1999) Contaminants as candidates for Pre-Screen Testing, in addition to the national representative
sample of 800 small systems. EPA will then statistically select up to 200 Pre-Screen Testing systems
from the large and small systems (CWS and NTNCWS) listed. The small systems selected may or may
not coincide with those in the national representative sample. It is possible that up to approximately 150
additional small systems could be selected for Pre-Screen Testing. The number of additional small
systems is unknown because EPA cannot pre-determine how many of the 800 systems in the national
representative sample would be in the States most vulnerable designation. EPA assumes only 800 total
small systems for cost estimation because it presents a "worst-case" per system cost, with maximum total
costs divided across the smallest possible number of systems.
c. Reporting and Record Keeping
Systems are assumed to require on average 0.5 hours per monitoring period to report analytical
results to the State and to maintain their own records of the results. The burden associated with the one-
time reporting of additional required data elements under UCMR is estimated to be 0.5 hours per system
for all systems. This one-time burden is allotted with each system's first reporting period.
EPA considers this burden assumption to be conservative, since much of the UMCR activities will
coincide with Phase II/V and other contaminant reporting and recordkeeping. In addition, for small
systems, electronic reporting to States will be provided by the EPA-designated laboratories.
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"Public Notification ------ - - _ _ _ _-
---- -.
.
j- Systems are required to notify their users of the detection of any unregulated chemicals.
';; Specifically, the results of UCMR monitoring will be reported through the Consumer Confidence ~ --=
-:Reports (63 FR 44512 (August 19, 1998)) and the revised Public Notification Rule (due late 1999). . : "
-Failure to monitor for unregulated contaminants required through the UCMR would be reportable under
the public notification rule. Therefore, no additional public notification burden is assumed under the
UCMR.
4. Assumptions for Non-labor Costs to Public Water Systems
Under the UCMR, no small system will incur non-labor costs. By design of the rule, the EPA
assumes ail laboratory and shipping costs for the systems in the national representative sample of small
systems. For large systems, the most significant cost associated with the implementation of the UCMR
is the cost of laboratory services for contaminant analysis. The estimated laboratory analytical cost
associated with each component of UCMR are shown below in Tables 12a, 12b, and 12c.
UCMR analytical costs are a function of the total number of samples and the cost for all methods.
The national cost of sample analysis is estimated by the following:
Assessment Monitoring
and Screening Survey
Laboratory Analytical Cost = (# of systems) * (# of sampling stations) * (monitoring
frequency) * (analytical cost)
Aeromonas Analytical Cost = (# of systems) * (two points in distribution system) *
(monitoring frequency) * (analytical cost)
Pre-Screen Testing
Analytical Cost = (# of systems) * (# of sampling stations (maximum 4)) *
(monitoring frequency) * (analytical cost)
Note that instead of paying the full analytical cost for Assessment Monitoring, large systems may
pay only the smaller "incremental" analytical costs (listed below in Table 12a) when UCMR monitoring
coincides with ongoing Phase II/V compliance monitoring. In some cases, UCMR monitoring can utilize
the same laboratory analytical methods that are required for ongoing compliance monitoring. Therefore,
when UCMR monitoring and Phase n/V monitoring are conducted concurrently, only incremental fees
are charged for analysis of the additional UCMR compounds. With methods that are not currently in use,
no cost savings can be realized.
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Table 12a. UCMR Assessment Monitoring / List 1 (1999) Contaminants: analytical methods and
estimated costs per analysis1 . . _.
Contaminant Name (Group)
CASRN
Assumed EPA
Analytical Method
Cost
Incremental Cos?
Chemical Contaminants
2,4-dinitrotoluene (SOC)
2,6-dinitrotoluene (SOC)
MTBE (methyl-tert-butyl-ether)
(VOC)
Nitrobenzene (VOC)
DDE (SOC)
EPIC (s-ethyl-
dipropylthiocarbamate) (SOC)
Molinate (SOC)
Terbacil (SOC)
DCPA mono-acid degradate
(SOC)
DCPA di-acid degradate (SOC)
121-14-2
606-20-2
1634-04-4
98-95-3
72-55-9
759-94-4
2212-67-1
5902-51-2
887-54-7
2136-79-0
525.2
525.2
524.2
524.2
508,508.1,525.5
507, 525.2
507, 525.2
507, 525.2
515.1,515.2
515.1,515.2
$160est.
$150 est.
$150(est. for 508)
$160 (est. for 507)
$160 (est for
515.1)
$20 est.
$20 est.
$0 (est. for 508)
$40 (est. for 507)
$20 (est. for 5 15.1)
Microbial Contaminants
Aeromonas hydrophila
n/a
In review
$25
n/a
1. Estimates of laboratory analytical costs were derived from review of recent laboratory price schedules
that were compiled for cost estimations under various drinking water program regulations. In addition,
five national drinking water laboratories and other UCMR stakeholders were consulted for the unique
UCMR contaminants.
2. Instead of paying full analytical cost for Assessment Monitoring, large systems may pay only the
smaller "incremental" analytical costs when UCMR monitoring coincides with ongoing compliance
monitoring. With methods that are not currently in use, no cost savings can be realized.
Table 12b. UCMR Screening Survey / List 2 (1999) Contaminants: analytical methods and
estimated costs per analysis
Contaminant Name (Group)
CASRN
Assumed EPA Analytical
Method
Cost
SCREENING SURVEY YEAR 1 (2002)
Chemical Contaminants
Prometon (SOC)
1610-18-0
507, 525.2, In development
$320 Cest. for 507~»
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Table 12b. UCMR Screening Survey / List 2 (1999) Contaminants: analytical methods and
estimated costs per analysis
Contaminant Name (Group)
Acetochlor (SOC)
Linuron (SOC)
Diuron (SOC)
Alachlor ESA (SOC)
CASRN
34256-82-1
330-55-2
330-54-1
n/a
Assumed EPA Analytical
Method
507, 525.2, In development
NPS-4, 553, In development
NPS-4, 553, In development
To be determined
Cost
SISOest.
$200 est.
SCREENING SURVEY YEAR 2 (2003)
Chemical Contaminants
2,4,6-trichlorophenol (VOC)
2,4-dichlorophenol (VOC)
2,4-dinitrophenol (VOC)
2-methyI-phenol (VOC)
1 ,2-diphenylhydrazine (VOC)
Diazinon (SOC)
Disulfoton (SOC)
Fonofos (SOC)
Terbufos (SOC)
32295
120-83-2
51-28-5
95-48-7
122-66-7
333-41-5
108937
944-22-9
13071-79-9
552, In development
552, In development
In development
In development
In development
In development
In development
In development
In development
$160 est.
$290 est.
Will require special handling
(507, 525.2 modifications)
$275 est.
Table 12c. UCMR Pre-Screen Testing / List 3 (1999) Contaminants: analytical
methods and estimated costs per analysis
Contaminant Name
CASRN
Assumed Analytical Method
Cost
Microbial Contaminants
Cyanobacteria/toxins
Echoviruses
Coxsackieviruses
n/a
n/a
n/a
in review
in review
in review
$420 est.
$1,500 est.
$1,500 est.
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In addition to analytical costs, large systems will incur costs for the shipment of the sample bottles to
the laboratory. Systems are assumed to ship a parcel of sample bottles to laboratories for each entry
point during each monitoring period. Costs are adjusted down for coincident monitoring, allowing
partial cost of shipping to be allotted to the UCMR samples.
For the Assessment Monitoring component of UCMR, calculations assume that cost efficiencies will
be realized by analyzing UCMR contaminants from the same sample using the same methods that are
currently used to test Phase II/V VOCs and SOCs, whenever possible. The Agency assumes that where
unregulated monitoring events coincide with Phase II/V monitoring for a specific contaminant group, the
laboratory would include the additional unregulated contaminants in the multi-residue VOC or SOC
analysis at a minimal additional charge (refer to "Incremental Cost" column in Table 12a). EPA uses the
Phase II/V monitoring frequencies developed for the CMRICR to estimate the number of times that
UCMR monitoring can coincide with the required current monitoring (i.e., where cost efficiencies can be
assumed).
Table 13. Multipliers for Coincidence Between UCMR and Phase UN Analytical Methods .-
Monitoring
Category
Waivers3
Standard Monitoring
(serving >3,300)4
Monitoring Detections,
butR&CXMCL3
Monitoring Detections,
but NOT R&C < MCL
MCL Violation
-
Waivers3
Standard Monitoring
(serving >3,300)4
Monitoring Detections,
but R&C < MCL5
Monitoring Detections,
but NOT R&C < MCL
MCL Violation
VOCs with Current Methods
% Systems
18.00%
65.73%
10.51%
5.60%
0.16%
Average
Frequency
per Year1
# Sample
Periods
Coincident
with
UCMR per
Year1
# Sample
Periods
Not
Coincident
with
UCMR per
Year
SOCs with Current Methods
% Systems
Average
Frequency
per Year1
Ground Water Systems
0.08
0.32
1.20
4.00
2.40
0.00
1.00
1.00
2.00
2.00
2.00
1.00
1.00
0.00
0.00
Surface Water Systems
25.00%
65.60%
5.54%
3.76%
0.10%
0.00
1.00
1.60
4.00
2.40
0.00
1.00
2.00
400
4.00
4.00
3.00
2.00
0.00
0.00
21.00%
78.53%
0.38%
0.07%
0.03%
21.00%
57.60%
16.09%
4.33%
0.98%
0.00
0.67
1.20
5.00
3.40
0.00
0.67
1.60
5.00
3.40
# Sample
Periods
Coincident
with
UCMR per
Year2
0.00
1.00
2.00
2.00
2.00
# Sample
Periods =
Not
Coincident
with
UCMR per ~-
Year
~-
2.00
1.00
0.00
i
0.00 ^
0.00
\
0.00
1.00
2.00
4.00
4.00
4.00
3.00
2.00"
0.00 :
0.00
' , L_:
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1. Average frequencies calculated using the same assumptions as the CMR ICR.
2. In determining the number of coincident and non-coincident monitoring periods, the most likely annual ,
schedule under Phase II/V monitoring was used. T .
3. Waivered systems will incur full cost for analysis, but have excluded labor costs for one UCMR sample
set during the three year period, assuming UCMR monitoring is coincident with current monitoring of
nitrates.
4. Systems serving greater than 3,300 people that are on Standard Monitoring must sample in two
consecutive quarters, with at least one monitoring event conducted during the three year compliance
period (2001-2003). Systems serving 25-3,300 people must sample once during the three year
compliance period.
5. R&C < MCL abbreviates "reliably and consistently below the maximum contaminant level".
Cost efficiencies for analytical laboratory fees are estimated somewhat differently than are the labor
efficiencies in the case of coincident monitoring events. The CMR ICR estimated the proportion of
systems that are currently on the following monitoring regimes for SOCs and VOCs: waivers; standard
monitoring; monitoring detections, but reliably and consistently below the maximum contaminant level
(MCL); monitoring detections, but not reliably and consistently below the MCL; or in MCL violation.
Proportions were estimated separately for surface and ground water systems. An average annual
monitoring frequency was also estimated for each monitoring scenario.
Because it is assumed that large systems will coordinate UCMR monitoring with Phase II/V
monitoring whenever possible, all but waivered systems are able to coordinate at least one Phase II/V
sample event with a UCMR sample event. Table 13 presents the proportions, average annual
frequencies, and multipliers used in estimating large system analytical costs. The following is an
example of how the coincident analytical costs for large systems are estimated:
Scenario: 65.6% of large surface water systems are on a monitoring regime for VOCs
reflecting a Standard Monitoring schedule, with an average annual monitoring
frequency of 1 (see Table 13).
Assumption: 65.6% of large surface water systems will be able to have one monitoring event
that will allow for cost efficiencies for the UCMR VOCs (MTBE and
Nitrobenzene) that have analogous methods under the Phase II/V regulations.
Therefore, 65.6% of surface water systems will incur three "full cost" laboratory
analyses for MTBE and Nitrobenzene at $150 and one "incremental cost"
analysis at $20 during one year of the three year period 2001 to 2003 (see Table
12a).
Calculation: The equation below represents total analytical costs for MTBE and nitrobenzene
for large surface water systems that are on a Standard Monitoring schedule.
[($150) * (65.6% of surface water systems) * (# of entry points) * (3 monitoring
events)] + [($20) * (65.6% of surface water systems) * (# of entry points) * (1
monitoring event)]
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Each monitoring scenario cost is calculated in the same way, and then all are added together to
calculate the nationwide cost for large systems to conduct the Assessment Monitoring. For simplicity, it
is assumed that one-third of the systems conduct monitoring during each of the three monitoring years.
Furthermore, lower costs are also assumed for shipping when UCMR monitoring coincides with current
compliance monitoring; national total cost efficiencies are calculated similarly. See Table 14 for the cost
efficiencies that were assumed for coincident shipping.
Table 14. Shipping Costs Per Contaminant Group for Assessment Monitoring and Screening
Surveys Large Systems Only1
Non-Coincident
VOCs
Non-Coincident
SOCs
Non-Coincident
Micro and
Viruses
Coincident VOCs
Coincident SOCs
Coincident
Micro, and
Viruses
Assessment Monitoring2
$8
$24
$8
$0
$16 . $8
Screening Survey
$8
$32
$16
$0
$32
$16
1. Shipping estimates are based on 1998 quotes from standard US carriers.
2. Lower shipping costs assume coincident mailing, but separate, extra sample bottles. Higher shipping
costs assume all sample bottles are going to contract laboratories separately.
5. Estimates of Burden and Costs to Public Water Systems
UCMR will affect 3,574 public water systems, including non-purchased CWSs and non-purchased
NTNCWSs. The labor burden for water systems consists of three primary activities: (1) reading the
regulations or State letter; (2) monitoring or monitoring assistance; and (3) reporting and record keeping.
Hourly labor rates (including overhead) are estimated at $28 per hour for staff in water systems serving
more than 3,300 people and $14.50 per hour for systems serving less than or equal to 3,300 (see Sections
B.I and B.2 for inventory and rate assumptions).
Table 15 displays labor and non-labor costs by year for the five-year monitoring cycle. As
previously discussed, monitoring under the UCMR will be on a five-year cycle, beginning with the initial
five-year cycle of 2001 to 2005. As noted, small systems incur labor costs only. Large systems will
incur both labor and non-labor costs, as they are responsible for analytical costs. The majority of system
costs are attributed to the Assessment Monitoring component of the UCMR, which is scheduled to take
place from 2001 through 2003. One-third of all participating systems are assumed to sample during each
of the three years (except for the Index systems, which will conduct Assessment Monitoring during each
of 5 years, 2001-2005). Significant analytical costs are also associated with the two Screening Surveys
(2002 and 2003) and Pre-Screen Testing (2004), as shown in Table 15.
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Table 15. Yearly Cost to Systems for Implementation of the Total UCMR Program, by System
Size and by Type of Cost
Cost
Description
2001
2002
2003
2004
2005
Total
800 SMALL SYSTEMS
(serving 10,000 or fewer people)
Assessment Monitoring
Total System Labor Costs (includes cost for reading regulations,
for monitoring and monitoring assistance, and for reporting and record keeping)
$27,870
$26,920
$26,920
$2,500
$2,500
$86,710
System Costs for Laboratory Analysis and Shipping
$0
$0
$0
$0
$0
$0
Screening Surveys and Pre-Screen Testing
Total System Labor Costs (includes annual cost for monitoring and monitoring assistance)
$0
$0
$0
$12,620
$0
$12,620
System Costs for Laboratory Analysis and Shipping
$0
$0
$0
$0
$0
$0
Subtotal
Small System
$27,870
$26,920
$26,920
$15,120
$2,500
$99,330
2,774 LARGE SYSTEMS
(serving greater than 10,000 people)
Assessment Monitoring
Total System Labor Costs (includes cost for reading regulations,
for monitoring, and for reporting and record keeping)
$259,060 | $259,060
$259,060
$0
$0 | $777,180
System Costs for Laboratory Analysis and Shipping
$7,747,520
$7,747,520
$7,747,520
$0
$0 | $23,242,560
Screening Surveys and Pre-Screen Testing
Total System Labor Costs (includes cost for monitoring and monitoring assistance)
$0
$0
$0
$11,870
$0 [ $11,
870
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Table 15. Yearly Cost to Systems for Implementation of the Total UCMR Program, by System
Size and by Type of Cost
Cost
Description
2001
2002
2003
2004
2005
Total
System Costs for Laboratory Analysis and Shipping
Subtotal
Large System
TOTAL - All
System Costs
$0
$8,006,580
$8,034,450
$1,421,250
$9,427,830
$9,454,750
$1,469,790
$9,476,370
$9,503,290
$983,660
$995,530
$1,010,650
$0
$0
$2,500
$3,874,700
$27,906,310
$28,005,640
The nationwide cost to systems for implementing the total UCMR program over the five-year
monitoring period is approximately $28 million. Large systems will incur most of this cost,
approximately $27.9 million. Annual cost per small system for UCMR implementation over the five-
year monitoring cycle is approximately $25 per system, all attributed to labor. Annual cost per large
system is estimated to be $57 for labor plus $1,955 for analytical (non-labor) costs. Details of per
system labor burdens and costs for Assessment Monitoring alone and for the total UCMR program
(Assessment Monitoring, Screening Surveys, and Pre-Screen Testing) are presented below in Tables 16a
and 16b, respectively. In addition, these tables present a summary of burden and cost per response.
"Response" is defined as each required reporting event for the system. All labor and non-labor costs
associated with a reporting event (reading the regulations, monitoring, and the reporting itself) are
included in the per response cost estimate.
Table 16a. Assessment Monitoring Per System and Per Response Costs
Burden / Cost
Number Responses per
Respondent
Total over 2001-2005
Small Systems
3.0
Large Systems
2.9
Annual Average over 2001-2005
Small Systems
0.6
Large Systems
0.6
PER RESPONDENT:
Labor Cost
Non-Labor Cost
$108 ! $280
$0 $8,379
$22
$0
$56
$1,676
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Table 16a. Assessment Monitoring Per System and Per Response Costs
Burden / Cost
Burden (labor hours)
Total over 2001-2005
Small Systems
5.0
Large Systems
10.0
Annual Average over 2001-2005
Small Systems
1.0
Large Systems
2.0
PER RESPONSE:
Labor Cost
Non-Labor Cost
Burden (labor hours)
$36
$0
1.7
$95
$2,841
3.4
$7
$0
0.3
$19
$568
0.7
Table 16b. Total UCMR Per System and Per Response Costs
Burden / Cost
Number Responses per
Respondent
Total over 2001-2005
Small Systems
3.4
Large Systems
3.0
Annual Average over 2001-2005
Small Systems
0.7
Large Systems
0.6
PER RESPONDENT:
Labor Cost
Non-Labor Cost
Burden (labor hours)
$124
$0
5.8
$284
$9,776
10.2
$25
$0
1.2
$57
$1,955
2.0
PER RESPONSE:
Labor Cost
Non-Labor Cost
Burden (labor hours)
$36
$0
1.7
$95
$3,282
3.4
$7
$0
0.3
$19
$656
0.7
a. Small Entity Flexibility
Under the Regulatory Flexibility Act (RFA), as amended by the Small Business Regulatory
Enforcement Fairness Act (SBREFA, or simply RFA), EPA generally is required to conduct a regulatory
flexibility analysis describing the impact of the regulatory action on small entities as part of rulemaking.
However, under section 605(b) of the RFA, if EPA certifies that the rule will not have a significant
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economic impact on a substantial number of small entities, EPA is not required to prepare a regulatory :
flexibility analysis. Pursuant to section 605(b) of the Regulatory Flexibility Act, 5 U.S.C. 605(b) and for"
the reasons set forth below, the Administrator certifies that this rule will not have a significant economic
impact on a substantial number of small entities. ~>
For purposes of RFA analyses for SDWA rulemakings, the Agency defines small entities as systems
serving 10,000 or fewer customers. This is the system size category specified in SDWA as requiring
special consideration with respect to small system flexibility, so EPA has selected it as the criterion for a
small business entity. EPA also consulted with the Small Business Administration regarding this
definition and used it in the Consumer Confidence Reports rulemaking (63 FR 44511-44536 (August 19,
1998)). For further information regarding this definition of small entities, see the referenced Federal
Register notice.
EPA has determined that the UCMR will affect small water utilities, since it is applicable to a subset
of small community and non-transient noncommunity water systems. However, the systems impacted
are limited to a representative sample of approximately 800 small public water systems (i.e., those
serving 10,000 or fewer) or 1.2 percent of systems in that size category. These systems will be required
to conduct monitoring, as specified in the UCMR (i.e., collect and prepare samples for shipping). EPA
will assume all costs for testing of the samples and for shipping the samples from these systems to
specific certified laboratories located throughout the United States. EPA has set aside $2 million from
the State Revolving Fund (SRF) in Fiscal Years 1998 and 1999, and plans to do so into the future with its
authority to set aside SRF monies for the purposes of implementing this provision of SDWA.
EPA has estimated the impact of the proposed rule and concludes that the impact of the rule on small
water systems will not be significant. The rationale for this conclusion is that EPA plans to pay the full
costs of shipping and testing samples for small systems and does not plan, under any scenario, to ask
systems to pay these costs. Thus, the costs to these systems will be limited to the labor hours associated
with collecting a sample and preparing it for shipping. EPA will seek to implement an optimum and
scientifically credible UCMR program that will provide a firm basis for future regulatory decisions.
EPA will aggressively seek the necessary levels of appropriated funds to defray the costs of shipping and
testing for small systems.
System costs under both a "Full Implementation11 and "Limited Implementation" scenario were
estimated to ensure that small systems would not incur significant economic impacts under any
circumstance. Cost summaries for both scenarios are provided below. (It is possible that up to 158
additional small systems could be involved in the unlikely event that all small Pre-Screen Testing
systems selected fall outside of the national representative sample. Using an assumption of only 800
systems involved, however, is a conservative, or worst case, assumption, when estimating the burden and
cost per system; i.e., this allocates the total cost and burden of the full implementation over 800 systems
versus 958 systems. Hence, this assumption is used in the following estimates.)
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Full Implementation Scenario
EPA guidance suggests, in implementing the RFA, that different tests be used to analyze small entity
impacts on privately-owned versus publicly-owned entities, due to the different economic characteristics"
of these ownership types. For publicly-owned systems, EPA guidance suggests that a "revenue test" be
used, which compares annual system costs attributed to the rule to the system's annual revenues.
Privately-owned systems are typically submitted to a "sales test", which involves the analogous
comparison of UCMR-related costs to a privately-owned system's sales. EPA assumes that the
distribution of the national representative sample of small systems will reflect the proportions of
publicly- and privately-owned systems in the national inventory. The estimated distribution of the
representative sample, categorized by ownership type, source water, and system size, is presented in
Table 7.
The basis for the UCMR RFA certification under full UCMR implementation is as follows: the
average annual compliance costs of the rule represent less than one percent of revenues/sales for the 800
small water systems that will be affected. The EPA estimates that Agency and system costs for
implementing small system sampling for the full UCMR program (2001-2005) will be approximately
$15.1 million. Since the Agency specifically structured the rule to avoid a significant impact to small
entities by assuming all costs for laboratory analyses, shipping, and quality control, EPA costs comprise
approximately 99 percent ($15.0 million) of the total. (Note that EPA's contribution to the small system
program is assumed to include all small system analytical and shipping costs, as well as all non-labor
program support costs.) Table 17 presents the annual costs to small systems and to EPA for the small
system sampling program, along with the number of participating small systems during each of the five
years of the program.
Table 17. EPA Costs for Small Systems under Full Implementation of UCMR
Cost
Description1
2001
(AM)
2002
(AM & SSI)
2003
(AM & SS2)
2004
(AM for Index
only & PST)
2005
(AM Index
only)
Total
Costs to EPA for Small System Program (including Assessment Monitoring, Screening Survey, and Pre-
Screen Testing): quality assurance, ongoing coordination, data analysis, analytical costs, shipping costs, and
costs for contractor site visits to small Index and Pre-Screen Testing systems*
$3,392,183
$3,538,029
$3,533,202
$3,814,617
$752,537
$15,030,568
Costs to Small Systems (including Assessment Monitoring, Screening Survey, and Pre-Screen Testing):
additional labor for reading regulations /guidance, sampling activity, and reporting and recordkeeping
$27,871
$26,915
$26,915
$15,116
$2,499
$99,316
Total Costs to EPA and Small Systems for UCMR
$3,420,054
$3,564,944
$3,560,117
$3,829,733
$755,036
$15,129,884
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Table 17. EPA Costs for Small Systems under Full Implementation of UCMR
Cost
Description1
2001
(AM)
2002
(AM & SSI)
2003
(AM & SS2)
2004
(AM for Index
only & PST)
2005
(AM Index
only)
Total ..:,
Number of Systems to Monitor each Year: Non-Index and Index in 2001-2003, Index only in 2004-2005 3
Public
Private
TOTAL
191
96
287
191
96
287
191
95
286
107
81
188
21
9
30
533
267
800
1. AM = Assessment Monitoring; SSI and SS2 = Screening Surveys Years One and Two; PST = Pre-
Screen Testing.
2. EPA costs during the year 2001 include some start-up costs that may be actually be incurred during the
year 2000.
3. Total number of systems is 800. All 30 Index systems sample during each year 2001-2005. One-third
of Non-Index systems sample during each year from 2001-2003. A total of 180 small systems conduct
Screening Surveys during each year, 2002 and 2003. 158 small systems conduct the Pre-Screen Testing
during 2004. The rows do not add across, because the same 30 Index systems sample during every year
of 5-year implementation cycle, and because the Screening Survey systems are a subset of the original
sample of 800 systems (e.g., they are conducting multiple types of sampling). Pre-Screen Testing
Systems may or may not be a subset of the original 800 systems.
System costs are attributed to the additional labor required for reading State letters, monitoring,
reporting, and record keeping. Assuming that systems will efficiently conduct UCMR sampling (e.g.,
coincident with other required monitoring), the estimated average annual per system labor burden for full
UCMR implementation will be: $20 (1.0 hours) for ground water systems; and $35 (1.6 hours) for
surface water systems. In total, ground water and surface water systems average 1.2 hour of burden per
year with an average annual cost of $25. Average annual cost, in all cases, is less than 0.3 percent of
system revenues/sales. Therefore, as stated above, the Administrator certifies that this proposed rule, as
funded by EPA, will not have a significant economic impact on small entities. Tables 18a and 18b below
present the estimated economic impacts in the form of revenue/sales tests for publicly- and privately-
owned systems. Further details of small system burden and cost are presented in Tables I6a and 16b.
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Table 18a. UCMR Full Implementation Scenario: Analysis for Publicly-Owned Systems (2001-
2005)
System
Size
Annual Number
of Systems
Impacted '
Number
%ofUS
Total
Average Annual Hours
per System (2001-
2005)
Non-Index
Index
Average Annual Cost
per System (2001-
2005)
Non-Index
Index
Revenue Test" *
Non-Index
Index
GROUND WATER SYSTEMS
500 and
under
501 to
3,300
3,301 to
10,000
5.8
41.4
42.5
0.01%
0.34%
1.77%
0.8
0.8
1.0
3.0
3.8
4.6
$10.99
$11.44
$29.29
$42.78
$54.38
$128.80
0.07%
0.01%
0.01%
0.26%
0.05%
0.03%
SURFACE WATER SYSTEMS
500 and
under
501 to
3,300
3,301 to
10,000
2.3
17.9
30.5
0.12%
0.98%
3.03%
2.9
1.6
1.3
0.0
5.2
5.0
$42.49
$22.66
$35.28
$0.00
$75.40
$140.00
0.15%
0.01%
0.00%
0.00%
0.04%
0.02%
1. Calculated as 1/5 of the Non-Index sample, plus all Index systems for each year from 2001-2005; actual
sampling for Non-Index systems takes place over three years, while that of Index systems occurs over
each of five years. Since Screening Survey systems are a subset of the Assessment Monitoring systems,
this does not affect the average annual number of systems (e.g., these systems are conducting monitoring
for two components of the UCMR program at the same time).
2. "Revenue Test" was used to evaluate the economic impact of an information collection on small
government entities (i.e., publicly-owned systems). Costs are presented as a percentage of median
annual revenue in each size category.
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Table 18b. UCMR Full Implementation Scenario: Analysis for Privately-Owned Systems (2001-
2005)
System
Size
Annual Number
of Systems
Impacted '
Number
%ofUS
Total
Average Annual Hours
per System (2001-
2005)
Non-Index
Index
Average Annual Cost
per System (2001-
2005)1
Non-Index
Index
Sales Test"2
Non-Index
Index
GROUND WATER SYSTEMS
500 and
under
501 to
3,300
3,301 to
10,000
21.4
18.8
11.9
0.05%
0.15%
0.50%
0.8
0.8
1.0
3.0
3.8
4.6
$10.99
$11.44
$29.29
$42.78
$54.38
$128.80
0.07%
0.01%
0.00%
0.27%
0.05%
0.02%
SURFACE WATER SYSTEMS
500 and
under
501 to
3,300
3,301 to
10,000
6.5
8.1
8.5
0.34%
0.45%
0.85%
2.9
1.6
1.3
0.0
5.2
5.0
$42.49
$22.66
$35.28
$0.00
$75.40
$140.00
0.19%
0.01%
0.01%
0.00%
0.05%
0.02%
1. Calculated as 1/5 of the Non-Index sample, plus all Index systems for each year from 2001-2005; actual
sampling for Non-Index systems takes place over three years, while that of Index systems occurs over
each of five years. Since Screening Survey systems are a subset of the Assessment Monitoring systems,
this does not affect the average annual number of systems (e.g., these systems are conducting monitoring
for two components of the UCMR program at the same time).
2. "Sales Test" was used to evaluate the economic impact of an information collection on small private
entities (i.e., privately-owned systems). Costs are presented as a percentage of median annual sales in
each size category.
Limited Implementation Scenario
Despite the expected $2 million per year budget, EPA recognizes that funding levels vary from year
to year and thus cannot guarantee the precise amount that will ultimately be available to implement its
UCMR program (although a considerable portion of those funds are currently on hand). In the event that
an amount commensurate with funding the optimal UCMR program (in terms of numbers of small
systems sampled and numbers of contaminants analyzed) may not be available, the Agency will adjust
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the UCMR program to accommodate the available funds. This adjustment may necessitate use of ~~j
relatively fewer sample sites, testing of fewer contaminants, or both. EPA would use a random number ~ "
generator select a representative sample of systems that would accommodate the available funds. . ~
t
' While the Agency considers the scenario of no additional funding to be unlikely, EPA also evaluated
the scenario of "current funds only" for purposes of this RFA analysis. This "current available funds"
scenario is the case in which EPA would receive no further funding for small system testing beyond the
$4 million that is currently set aside from the State Revolving Funds from Federal Fiscal Years 1998 and
1999. EPA anticipates funding this program such that no small system would incur testing costs as
intended in the legislation. By analyzing small system impact under such a scenario, EPA can
demonstrate that, regardless of funding levels, no small systems will be significantly impacted by the
UCMR. Given the flexibility of the proposed rule, EPA can ensure defensible results, balanced with
available funding.
In the optimal anticipated program, the sample of 800 systems is derived by applying a 99 percent
confidence level, with 1 percent error tolerance. To accommodate a $4 million budget, the representative
sample of small systems would be reduced to approximately 400 systems. This smaller sample size
would be less rigorous than the anticipated sample of 800 systems; the sample error would be
approximately plus or minus 5 percent, affecting the scope and confidence of the national decisions that
could be derived. These 400 systems would incur only labor costs related to collecting and packing the
samples, while EPA would pay the shipping and testing costs for these samples.
With the currently available $4 million, EPA will be able to fund approximately 48 percent of the
planned Assessment Monitoring program for small systems. To estimate the costs under this scenario, it
is assumed that only the Assessment Monitoring component of UCMR would be implemented. It is
assumed that the smaller representative sample would be allocated across system size categories in the
same proportions as those in the sample of 800 systems, with ten of these systems being Index sites, and
will also reflect the proportions of publicly- and privately-owned systems in the national inventory of
PWSs, as seen in Table 8. Furthermore, EPA preparations for the Screening Surveys, Pre-Screen
Testing, and future UCMR cycles are assumed to be dropped, since with limited funds, current
implementation would take precedence over planning for further monitoring.
The Agency is concerned that a reduced sample size will reduce the statistical likelihood that the
observed contaminant occurrence levels will be representative of actual occurrence across the nation.
Because of this, the Agency will actively pursue funding for the full program described in this Preamble.
Under the limited funding scenario, EPA costs for Assessment Monitoring would primarily be
incurred from 2001 to 2003. Systems are assumed to sample during one year of the three-year period,
with one-third of systems sampling during each year. However, Index systems are assumed to monitor
during each of the three Assessment Monitoring years. The distribution of costs to EPA and small
systems over the entire five years is presented below in Table 19.
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Table 19. EPA Costs for Small Systems Limited $4 million Program
Cost
2001
2002
2003
2004
2005
Total
Costs to EPA for Assessment Monitoring Program: Quality assurance, ongoing coordination, data analysis,
shipping costs, testing costs, reporting and analysis costs, and costs for contractor site visits to Index 'systems
$1,367,947
$1,082,341
$1,082,341
$280,422
$186,948
$3,999,999
Costs to Small Systems (Assessment Monitoring): including additional labor for reading regulations /guidance,
sampling activity, and reporting and recordkeeping
$13,405
$11,756
$11,756
$0
$0
$36,917
Total Costs to EPA and Small Systems for Assessment Monitoring
$1,381,352
$1,094,097 $1,094,097
$280,422
$186,948
$4,036,916
Number of Systems each Year: Assessment Monitoring and Index Systems in 2001-2003'
Public
Private
TOTAL
92
46
138
92
46
138
92
46
138
0
0
0
0
0
0
264
132
396
1. Rows do not add across because the 10 Index systems sample during each year 2001-2003. One-third of
Non-Index systems sample during each year from 2001-2003.
Under this limited $4 million program, EPA costs represent approximately 99 percent of the national
cost for the small system sampling program. As in full UCMR implementation, small system costs are
attributed to the additional labor required for reading State letter, monitoring, reporting, and record
keeping. It is estimated that under the limited program (e.g., Assessment Monitoring only), the average
annual per system labor burden will be: $15 (0.7 hours) for ground water systems; and $27 (1.2 hours)
for surface water systems. In total, ground water and surface water systems average 0.9 hours of burden
per year, with an average annual cost of $19. System burdens here are lower than in the full
implementation scenario primarily because no Screening Surveys or Pre-Screen Testing will occur under
this scenario.
Through revenue and sales tests, determinations of economic impact are presented below in Tables
20a and 20b, respectively. Under this limited $4 million program, systems will be subject to less
required monitoring than in the full UCMR program. For both full UCMR implementation and the
limited funding scenario, average annual cost is in all cases lower than 1 percent of annual
sales/revenues. Thus, even in this worst case, limited implementation scenario, EPA certifies that this
proposed rule would not impose a significant economic impact on small entities.
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Table 20a: UCMR Limited Implementation Scenario: Analysis for Publicly-Owned Systems
(2001-2005)
System
Size
Annual Number
of Systems
Impacted '
Number
%of
US
Total
Average Annual Hours
per System (2001-
2005)
Non-Index
Index
Average Annual Cost
per System (2001-
2005)
Non-Index
Index
"Revenue Test" 1
Non-Index
Index
GROUND WATER SYSTEMS
500 and
under
501to
3,300
3,301 to
10,000
22
17.1
17.2
0.00%
0.14%
0.72%
0.6
0.6
0.8
1.9
2.1
2.6
$8.06
$9.15
$22.16
$27.41
$30.89
$73.92
0.05%
0.01%
0.00%
0.17%
0.03%
0.02%
SURFACE WATER SYSTEMS
500 and
under
501 to
3,300
3,301 to
10,000
0.3
6.0
12.6
0.01%
0.33%
1.25%
1.1
1.2
1.1
0.0
3.2
3.1
$15.41
$17.07
$31.35
$0.00
$46.98
$87.36
0.05%
0.01%
0.00%
0.00%
0.03%
0.01%
1. Calculated as 1/5 of publicly-owned Non-Index sample, plus all public Index systems for each year from
2001-2003; actual sampling for Non-Index takes place over three years, Index over each of three years.
2. "Revenue Test" was used to evaluate the economic impact of an information collection on small
governments (e.g., publicly-owned systems). Costs are presented as a percentage of median annual
revenue in each size category.
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Table 20b: UCMR Limited Implementation Scenario: Analysis for Privately Owned Systems
(2001-2005)
System
Size
Annual Number
of Systems
Impacted '
Number
%of
US
Total
Average Annual Hours
per System (2001-
2005)
Non-Index
Index
Average Annual Cost
per System (2001-
2005)1
Non-Index
Index
"Sales Test"1
Non-Index
Index
GROUND WATER SYSTEMS
500 and
under
501 to
3,300
3,301 to
10,000
8.0
7.8
4.8
0.02%
0.06%
0.20%
0.6
0.6
0.8
1.9
2.1
2.6
$8.06
$9.15
$22.16
$27.41
$30.89
$73.92
0.05%
0.01%
0.00%
0.17%
0.03%
0.01%
SURFACE WATER SYSTEMS
500 and
under
501 to
3,300
3,301 to
10,000
0.8
2.7
3.5
0.04%
0.15%
0.35%
1.1
1.2
1.1
0.0
3.2
3.1
$15.41
$17.07
$31.35
$0.00
$46.98
$87.36
0.07%
0.01%
0.01%
0.00%
0.03%
0.02%
1. Calculated as 1/5 of the Non-Index sample, plus all Index systems for each year from 2001-2005; actual
sampling for Non-Index systems takes place over three years, while that of Index systems occurs over each of
three years.
2. "Sales Test" was used to evaluate the economic impact of an information collection on small private entities
(e.g., privately-owned systems). Costs are presented as a percentage of median annual sales in each size
category.
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C. States/Primacy Agents
State implementation requirements are categorized into four major activities, as follows:
EPA coordination activities
Data management and support
Laboratory training
Program implementation
Table 21 presents the schedule of UCMR-related activities for States/Primacy Agencies. States will
undertake some start-up activities in the year 2000, with the remaining activities occurring during 2001
through 2005. The State Resource Model is used by the Agency in preparing this cost analysis. A
detailed description of the State Resource Model is documented in the Resource Analysis Computer
Program for State Drinking Water Agencies, January 1993. The model was designed by the Office of
Ground Water and Drinking Water to enable primacy agents to estimate the resources needed to fund
their drinking water programs. The model identifies a comprehensive list of activities required to
operate a drinking water program, including technical and training activities, as well as management and
clerical support for these activities. The assumptions used in the model are based on input from a
workgroup of 39 States and the Association of State Drinking Water Administrators (ASDWA). Inputs
to the State Resource Model were scaled in relation to other rules and activities. Also, UCMR activities
are expected to be coordinated with other drinking water program activities (as is the current unregulated
monitoring). Thus, related burdens will generally be incremental additions to program activities.
Table 21. Schedule of State UCMR Activities
Activity
EPA Coordination Activities
Review and Respond to EPA's
proposed State Monitoring
Plan1; Regulation Adoption
Ongoing Coordination with
EPA
2000
X
X
2001
2002
2003
2004
2005
X
X
X
X
X
Data Management and Support
Update Data System
Data Entry, Record Keeping
X
X
X
X
X
X
Laboratory Training
Training for Compliance
Reporting
X
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Table 21. Schedule of State UCMR Activities
Activity
Technical Training
2000
X
2001
2002
2003
2004
2005
Program Implementation
System Schedule Notifications
and ongoing Support2
Data Review and Enforcement
X
X
X
X
X
X
X
X
X
X
Overhead
Overhead Costs (clerical,
management, staff training)
X
X
X
X
X
X
2.
This includes States' requirements to either accept the EPA-proposed State monitoring plan or submit an
alternative plan, as specified in §142.16(g). The States' initial response to EPA must also include
specification of the most vulnerable monitoring period, if it differs from the default May-July period
specified in the rule. States must also submit to EPA their list of systems "most vulnerable" to the Pre-
Screen Testing contaminants.
This includes States' requirements to notify systems in writing of the system monitoring requirements
under UCMR, including the sampling schedule and the vulnerable period during which the system must
sample.
1. State Coordination with EPA
EPA assumes that States will conduct several activities involving coordination with EPA regarding
UCMR rule adoption. Each State will implement the formal steps for regulation adoption and primacy
application necessary to administer the UCMR. States will also review and respond to EPA's nationwide
statistical sampling plan that designates the 800 systems serving 10,000 or fewer people that will be
subject to the requirements of UCMR. The sampling plan review/response includes specification of the
State's most vulnerable period for Assessment Monitoring (if different from the default specified) and
identification of up to 25 vulnerable systems for Pre-Screen Testing. States will also likely require some
time for ongoing coordination with EPA regarding the requirements of UCMR.
Input to the State Resource Model for EPA coordination activities includes:
1. State Monitoring Plan / Regulation Adoption
- 90 hours (0.05 Full Time Equivalent (FTE)) per State in year 2000; includes regulation
adoption and primacy application, review and response to EPA's proposed State
Monitoring Plan, identification of Pre-Screen Testing systems, and identification of
State's "most vulnerable" period (if different from the May-July default), and
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2. Ongoing coordination with EPA
36 hours (0.02 FTE) per State/Primacy Agent per year; includes meetings/discussion
regarding implementation and enforcement issues.
2. Data Management and Support
EPA assumes that each State will incur burdens and costs associated with UCMR-specific data
management and record keeping. The only non-labor cost that any State is expected to incur is the cost
for contractor assistance associated with updating the State drinking water system database. According
to results of an ASDWA survey, over 90 percent of States are able to electronically report results from
the current round of unregulated contaminant monitoring to SDWIS.3 Thus, 10 percent of the States will
need to update their data systems for the UCMR electronic reporting requirements. It is estimated that
during the year 2000, this 10 percent of States will require contractor support to assist them in updating
their systems at an estimated cost of $25,000 per State. (Note, however, that this cost estimate is
conservative, since some system upgrades may be as simple as procuring routine commercial software
and entering the data into a general-use spreadsheet or database.) In addition, all 56 States will need
some adjustment to integrate the new data elements (i.e., modifying data entry fields).
States will require an estimated average of 0.5 hours per system to enter system data into the State
database and to manage the hard copies of system information related to the UCMR. Although systems
will be required to report electronically, States can waive this requirement to relieve system burden.
Thus, the estimate for data management burden per system is also conservative.
States will be responsible for electronic reporting of the results of all unregulated contaminant
monitoring conducted under UCMR, as part of the States' routine reporting to SDWIS. Therefore, other
than the one-time cost of updating State data systems, no State burden is allotted for electronic SDWIS
reporting. (Note: The UCMR data will be reported to SDWIS for electronic routing to the National
Drinking Water Contaminant Occurrence Database (NCOD).)
Input to the State Resource Model for data management and support includes:
1. Update State Data System
18 hours (0.01 FTE) per State are allotted for updating State data systems in the year
2000. With 90 percent of States requiring only minor changes to their databases, EPA
makes a conservative assumption that each State would require 0.01 FTE to update their
systems. The model assumes an additional $25,000 in the year 2000 for contractor
1 assistance to upgrade the database, for 10% of the States, and
3 "Assessment of State and Federal Database Systems (Association of State Drinking Water
Administrators Survey Results)", prepared for USEPA by ISSI, Inc., August, 1997; and
"Assessment of the Status and Availability of Contaminant Occurrence Data", prepared for
USEPA by ISSI, Inc., March 1998.
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2. File Management and Data Entry for Monitoring Results (on a quarterly basis)
0.5 hours per system per year for 2001-2005; includes record keeping and data entry into
State database.
3. Laboratory Training
The Agency allocates approximately 20 hours per State to provide workshops in the year 2000 for
laboratory supervisors to demonstrate the reporting requirements under the UCMR. Workshops will also
cover technical training for new laboratory procedures, including the procedure for analyzing Aeromonas
hydrophila.
Input to the State Resource Model for training for certified labs includes:
1. Training for Compliance Reporting
16 hours (2 days) per State in the year 2000 is allotted for training laboratories how to
properly report data under the UCMR, which includes informing the laboratories of the
list of required data elements, and
2. Technical Training
16 hours (2 days) per State in the year 2000 is allotted for technical training for
laboratories that serve large systems; this training would cover the specific laboratory
procedures that would be required under the UCMR.
4. Program Implementation
The State burden for program implementation activities is assumed to include: sending rule
requirements and monitoring schedules to each system, reviewing of system data, responding to
owner/operator inquiries, and issuance of enforcement notices. States will spend an estimated 2 hours
per regulated system, informing each system of the UCMR requirements, the sampling schedule, and the
system's role in the sample collection. States are assumed to notify all systems at least 90 days prior to
their required sampling schedule. States are assumed to receive phone calls from water systems
regarding the requirements of the UCMR, and are estimated to spend 0.5 hours per system per year
responding to inquiries from systems that are monitoring during that year.
Each State will need to review the system monitoring results which are maintained in their database.
For simplification, it is assumed that one-third of the 3,574 systems monitor in each of three years during
the years 2001 through 2003. States are assumed to spend four days per 100 systems per year in 2002
through 2005 to review each system's UCMR data.
States are assumed to issue a notice of violation to systems incurring a UCMR monitoring and
reporting violation. Based on the assumptions used in the State Resource Model, one percent of systems
serving ^500 people, and 0.8 percent serving more than 500 people are estimated to incur monitoring
and reporting violations for failure to conduct the UCMR monitoring. The State Resource Model also
assumes that a State would require one hour to issue each notice of violation. States are assumed to issue
enforcement actions during the years 2002 through 2005. It is assumed that only half of the systems in
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violation will be issued a notice, and that other half would come into compliance with a brief reminder
phone call. This relatively low rate of enforcement and compliance activity is assumed for two reasons.
First, the UCMR is relatively simple to follow, with compliance assured as long as the system submits
the correct sampling data. Second, the EPA is paying for the sample analysis for those small systems
most likely not to sample because of costs.
States may apply for a statewide waiver from UCMR monitoring for a specific contaminant. A
waiver may be provided contingent upon the provision of "proof that each of these analytes has not been
detected in the source waters or distribution systems, or produced, used, stored, disposed, land applied,
released, or naturally present in the State for a period of at least fifteen years prior to the date of
application." The Agency anticipates, after consulting with States, that States are unlikely to apply for
these waivers; therefore, no costs or burdens have been estimated for this activity.
Input to the State Resource Model for program implementation includes:
1. Notify Systems of Schedule
2 hours per system letter are allotted to each State,
2. Review Monitoring Results
- 32 hours (4 days) per 100 systems per year were allotted from 2002-2005; this includes
compliance determination and review of data for quality control,
3. Issue Public Notice / Notice of Violation
1 hour per system in violation, assuming that 1% of systems serving s500 people and
0.8% of systems serving >500 people would incur monitoring and reporting violations
during 2002-2005; burden would involve sending half of the systems a notice of
violation and briefly phoning half with a reminder of program requirements, and
4. Respond to Owner/Operator Inquires
0.5 hours per system per year (2001-2005); involves responding (via phone) to owner /
operator inquiries regarding compliance with the UCMR.
5. Overhead
Finally, the State Resource Model applies proportional overhead costs to the estimated total program
staffing, as described below:
1. Supervision
1,800 hours (1 FTE) of supervisory staffing for every 10 FTEs; standard State Resource
Model allocation,
- - - 2. Rule Training
- 40 hours (5 days) per FTE in the year 2000; standard State Resource Model allocation
(training only in the initial year of rule adoption, with all technical staff to participate in
rule-specific training),
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3. Clerical ,. ,.'
- 1,800 hours (1 FTE) for clerical staff for every 10 staff; standard State Resource Model
allocation; includes general secretarial assistance (which is over and above the filing and
data entry labor previously accounted), and
4. Ongoing Training
40 hours (5 days) per FTE per year; includes attending professional conferences,
attending classes for skills such as public speaking and computers, and participating in
seminars such as employee health and well being and stress management.
6. Estimating the Burden and Cost to States
EPA estimates that the total burden over 6 years (2000-2005) for 56 States/Primacy Agencies to
implement the UCMR will be 54,180 hours, with a total cost for labor of $2.3 million. Although State
costs will primarily be attributed to labor, it is assumed that some States will incur a one-time non-labor
cost for contractor assistance to update the State database to comply with UCMR electronic reporting
requirements. On a nationwide basis, this one-time non-labor cost is estimated to be $140,000. On
average, the annual cost to each State including labor and non-labor costs for implementing the UCMR
program is expected to be $8,240, with an annual labor burden per State of 194 hours (1/10 FTE). EPA
emphasizes, however, that these are average State costs. Some States may incur annual costs that are
greater than the average, and some may incur little or no costs, depending on the number of systems in
the State Monitoring Plan and upon structure of the State drinking water program. (Note: Many aspects
of State burden are related to the number of systems involved. With the UCMR design, using a
statistical sample of small systems, each State will have very few systems, relative to their normal
program population of systems. For example, nearly 75 percent of all States will have less than 10 small
systems involved.) See Tables 22 and 23 for a detailed summary of estimated State burdens and costs.
As discussed, burdens and costs to the States are estimated using the standard State Resource Model.
The resource model applies standardized overhead labor and costs to the base resources required to run
the UCMR program, including clerical and supervisory staff to support the UCMR, and on-going
training. The average State labor rate applied in estimating State labor costs is $40 per hour, the rate
used for other drinking water program cost analyses. (The specific assumptions used to develop
estimates of the States' activity burdens and costs were discussed previously, in Section C.I through
C.5.)
Table 22. Yearly Total Cost to All States/Primacy Agencies for Implementation of UCMR, by
Type of Cost1
Cost Description 2000
2001
2002
2003 2004 2005 Total
EPA Coordination Activities (review of State Monitoring Plan, identification ofPre-Screen Testing systems,
most vulnerable period, regulation adoption, primacy application, ongoing coordination)
$279,360
$77,760
$89,420
$89,420
$89,420
$89,420
$714,800
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Table 22. Yearly Total Cost to All States/Primacy Agencies for Implementation of UCMR, by
Type of Cost1
Cost Description
2000
2001
2002
2003
2004
2005
Total
Data Management and Support (updating data system, data entry, record keeping)
$260,960
$21,600
$24,840
$24,840
$24,840
$24,840
$381,920
Laboratory Training (for reporting requirements and technical training)
$45,760
$0
$0
$0
$0
$0
$45,760
Program Implementation (system schedule and rule introduction, review of data, system support, enforcement)
$100,800
$122,400
$175,320
$116,640
$124,920
$124,920
$765,000
Overhead Costs (supervision, staff training, clerical)
TOTAL - All
$131,251
$818,131
$48,787
$270,547
$63,708
$353,288
$50,799
$281,699
$52,620
$291,800
$52,620
$291,800
$399,785
$2,307,265
1. Costs include implementation and oversight of the Assessment Monitoring, Screening Survey, and Pre-
Screen Testing components of the UCMR. All costs are attributed to State labor, except for a one time
allowance during the year 2000 for updating of State databases for electronic reporting.
Table 23. UCMR Per State and Per Response Costs
Burden / Cost
Number of Responses per Respondent2
Total for 2000-2005'
24
Annual Average (over 5-year
implementation period)
4.8
PER RESPONDENT:
Labor Cost
Non-Labor Cost
Burden (labor hours)
$38,701
$2,500
967.5
$7,740
$500
193.5
PER RESPONSE:
Labor Cost
Non-Labor Cost
Burden (labor hours)
$1,612
$105
40.3
$322
$21
8.1
1. State costs are estimated over the period 2001 -2005, with some start up costs in the year 2000.
Costs are averaged on a five-year basis to represent average annual costs of the five-year
implementation cycle.
2. States are assumed to have a total of four responses per year, since they are required under the
drinking water program to send data updates to SDWIS on a quarterly basis.
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b.7Estimating Agency Burden and Cost
" -ij
At
-- EPA Headquarters and Regional offices will incur UCMR-related burden and costs to oversee State
public water system programs, and to process and analyze the UCMR data. EPA implementation 7,
.activities are categorized, as follows, into three major categories. , ^
Regulatory support activities: includes non-labor costs for laboratory capacity and QA/QC;
implementation of small system testing program, data reporting and review protocol; general
technical support and guidance documents; data quality review and analysis
Analytical cost for small system testing program: includes non-labor costs for direct analytical
and shipping costs for small systems for all components of the UCMR program; coordinate and
fund on-site monitoring for Index Systems and small Pre-Screen Testing systems; and
National and regional oversight and data analysis: includes EPA labor costs for management
oversight and review and evaluation of data for Assessment Monitoring, Screening Surveys and
Pre-Screen Testing.
Additional activities will be conducted prior to the implementation of the rule and therefore are not
considered as part of this cost analysis. These activities are:
Developing regulations and necessary guidance materials,
Developing guidance documents for all systems,
Providing logistical coordination for laboratory and sampling effort (e.g., preparing request for
proposal, inter-agency agreement), and
Modifying SDWIS to accommodate unregulated contaminants.
Table 24 below presents the schedule for EPA activities, which will primarily occur during 2001
through 2005, with start-up activities occurring during 2000.
Table 24. Schedule of Agency Activities
Activity
2000
2001
2002
2003
2004
2005
REGULATORY SUPPORT ACTIVITIES
Ensuring Laboratory Capacity;
QA/QC Programs
Implementation of Small System
Testing Program; Establishing
Reporting and Data Review Protocol
Technical Support / Guidance
Document Development
Data Quality Review and Analysis
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
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Table 24. Schedule of Agency Activities
Activity
2000
2001
2002
2003
2004
2005
ANALYTICAL COST FOR SMALL SYSTEM TESTING PROGRAM
, Analytical and Shipping Costs for
'.-) Index and Non-Index Systems
Contractor Costs for Index System
Site Visits and Small Pre-Screening
Testing System Site Visits
X
X
X
X
X
X
X
X
X
X
NATIONAL AND REGIONAL OVERSIGHT & DATA ANALYSIS
EPA Direct Labor Costs for Program
Oversight and Data Management
X
X
X
X
X
X
1. Regulatory Support Activities
a. Laboratory Capacity and QA/QC Activities
EPA anticipates incurring various contractor costs related to national laboratory capacity and
laboratory quality assurance and control. Specifically, cost estimates assume the following activities:
QC Audits of Contract Laboratories: EPA or contractor on-site QC audits of laboratories for
small system testing program, includes costs for specific task only, for quality control surveys at
1 to 5 laboratories per year, survey cost assumptions are summarized in Table 25,
Additional Contract Laboratory QC / Screening Survey Testing: additional QA/QC analysis
and recordkeeping, over and above routine analytical costs for small system contaminant testing
(e.g., CERCLA-CLP analogy),
Development of Laboratory Capability: preparation of analytical methods for implementation
of Screening Surveys and Pre-Screen Testing (e.g., testing for List 2 and List 3 contaminants), as
well as preparation of related QC protocols; also, in preparation for round two of the UCMR,
activities will include review and preparation of analytical methods for new contaminant list,
new testing program, further refinement of 1999 contaminant methods for new cycle, preparation
of related QC protocols, for small system testing program, and
Ongoing Refinement of Laboratory Methods: review operations of small systems' contract
laboratory methods, refinement of analytical methods for routine use on a national basis,
particularly for contaminants that are to become regulated.
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__ v
^^Implementation of Small System Testing Program / Reporting and Data Review Protocol ~"~
n,u
~ EPA contractor activities which are assumed for cost estimates of logistical support of the small
system testing program include the following:
?s* -
i. Small System Plan Integration / Field Coordination: logistical planning and implementation
of the Index System and Pre-Screen Testing site selection and field efforts; technical integration'">
of State Monitoring Plans; confirmation of systems in sample, schedules, linking to laboratories,
'?' and
', Establish Reporting System and Protocol for Small System Program: develop electronic
reporting system for routing and reporting of testing results, among labs, small systems, States,
and EPA; accommodate routing of data for QC review and analysis; ensure timely program
performance checks and changes, and timely submission of QC'd data to SDWIS/NCOD.
c. Technical Support / Guidance Document Development
Technical support and guidance document development are all-encompassing activities which cannot
be considered directly attributable to the small system program, but rather, in support of general program
implementation. EPA contractor activities which are assumed for cost estimates include the following:
General External Laboratory QC Program: development of QC Program (certification,
proficiency testing/standards) for general use by laboratories conducting methods (not small
systems); begin development of new guidance documents and methods/QC manuals in
preparation for the second UCMR cycle, and
Technical Support for Rule Amendments / Guidance Documents: technical analysis and
support for development of Screening Surveys, Pre-Screen Testing, Methods and QC Manuals,
and necessary Guidance Documents; as well as a written analysis of program operations, lessons
learned, Index System characteristics; also, to provide technical analysis and support for
development of new contaminants list, methods review, new statistical small system sampling
frame, targeting options in preparation for the second UCMR cycle.
d. Data Quality Review and Analysis
EPA contractor activities which are assumed for data quality review and analysis costs include the
following:
Data Quality Review and Analysis: continuous analysis of lab results; comparison among labs;
Index system results comparison with small system data; and data quality checks and review; to
assess Screening Survey testing performance and quality to ascertain problems before
confirmation and reporting; review of all program data, and NCOD review.
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2. Analytical Costs for Small System Testing Program
a. Small System Analytical and Shipping Costs
The single largest cost to EPA for implementation of the UCMR is for small system sample analyses.
EPA will pay for the analytical and shipping costs for all small systems in the national representative
sample including Assessment Monitoring, Screening Surveys, and Pre-Screen Testing.
Analytical costs are a function of system sampling schedules (see Table 10), the number of systems
and sampling stations (see Tables 4-8), and the cost of the analyses (Tables 12a, 12b, and 12c). The
majority of Assessment Monitoring costs are incurred from 2001 to 2003, with costs for the Index
System testing extended through 2004 and 2005; Screening Survey costs are incurred in 2002 and 2003;
and Pre-Screen Testing in 2004.
EPA expects to incur some quality control costs for the small system testing program that will not be
incurred by the large systems. Specifically, EPA plans to send duplicates often percent of small system
samples to a separate laboratory for analysis, and plans to collect some additional, standard water quality
parameters for each sampling station at both Index and Non-Index systems. The quality control
duplicates are intended to provide standard, real time, QC checks among the different contract
laboratories. Water quality parameters will include some anions, cations, chlorine residuals, nitrate, total
coliform, temperature, hardness, and specific conductance. This information is intended to enhance the
use and interpretation of the UCMR results, providing data on water quality characteristics that may
affect contaminant stability and allow analysis of co-occurrence, for example.
In addition, EPA plans to collect in depth system operation information from the Index Systems.
Contractors will collect detailed observations of system operations that may effect contaminant
occurrence, such as nature of source water (what type of aquifer or source water body), number of wells,
well depth, treatment, configuration of source water intake, treatment, entry points, distribution systems,
and how are sources used (seasonally, blended, etc.). It is assumed that additional costs attributed to this
information collection will be incurred over the first three years of the UCMR, with in depth surveys
conducted at 10 Index Systems per year.
b. Contractor Costs for Index and Small Pre-Screen Testing System Site Visits
EPA also expects to incur significant costs related to contractor site visits to both Index Systems and
small Pre-Screen Testing systems. EPA assumes that it will pay for contractor site visits to conduct
Assessment Monitoring at 30 Index Systems, for each year from 2001 to 2005. In addition, EPA has
estimated costs for contractor site visits to approximately 150 small Pre-Screen Testing systems during
the year 2004. With each of the Assessment Monitoring and Pre-Screen Testing samples, contractors
will collect water quality parameters at both the Index and Pre-Screen Testing Systems. Cost
assumptions for both the Index and Pre-Screen Testing visits are summarized below in Table 25.
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Table 25. EPA Contractor Costs
Contractor Costs for Each Index System Visit
Hourly Labor Cost1
$34.62
How Burden2
22.20
Travel Cost (per
diem plus air and-
ground travel)3
$770.00
Cost Per Visit
$1,538.56
Contractor Costs for Each Pre-Screen Testing System Visit
Hourly Labor Cost1
S34.62
Hour Burden2
22.40
Travel Cost (per
diem plus air and
ground travel)3
$770.00
Cost Per Visit
$1,545.49
Contractor Costs for Laboratory Inspection
Hourly Labor Cost1
$34.62
Hour Burden2
32.00
Travel Cost (per
diem plus air and
ground travel)3
$620.00
Cost per Lab
Inspected
$1,727.84
1. Contractor costs assumes one day of site visit labor at $34.62 per hour.
2. Index Visit Cost: Assumes 1 day of air travel each way, 2 hours for groulfd travel each way and
1/2 hour for each sampling point with an average of 2.4 entry points, and one distribution sample
(for Aeromonas hydrophila) per system; Pre-Screen Testing Visits will differ in that 1 hour is
allotted for each sampling station.
3. Travel includes: $500 round trip flight, $100 for car rental, 2 nights hotel stay, 1 full day food per
diem, and 2 days at the proportional meals rate from the January 1998 Federal rate for the
Continental U.S.
4. Labor includes: 1 day site inspection, 1 full day travel (assume 2 half days), 1 day report writing,
and 1 day for review and response to laboratory response
5. Travel includes: $350 round trip flight, $100 for car rental, 2 nights hotel stay, 1 full day food per
diem, and 2 days at the proportional meals rate from the January 1998 Federal rate for the
Continental U.S.
3. National and Regional Oversight / Data Analysis
While it is has not been determined if some of the UCMR regulatory support activities will be
carried out by the EPA or by its contractors, there are key management and oversight activities that must
be conducted by EPA Headquarters or its Regional offices. These activities are therefore estimated as
labor cost and burden to the Agency.
The UCMR program implementation plans assume that EPA will begin preparing for data analysis in
the year 2000, and will ensure ongoing evaluation of the data during 2001 through 2005. EPA will also
provide management oversight and support at both the Regional and National level to States for
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assistance and guidance with their UCMR implementation. EPA expects to dedicate between 7 and 9
FTEs each year from 2000 through 2005. Rationale for the estimated FTEs includes, for example, the
need for review and approval of the State Plan responses. EPA assumes that it will require 8 hours to
respond to each of 50 percent of the States, 20 hours for each of 40 percent, and 40 hours for each of 10
percent of the States. The average hourly salary rate for this EPA activity is assumed to be $34.62,
which is derived from the average salary plus overhead for a federal GS 13 employee.
4. Estimated EPA Costs
The total EPA cost for the entire UCMR program, including regulatory support activities, analytical
costs for the small system testing program, national and regional program oversight, and analysis of the
data submissions is estimated to be $20.1 million. The average annual cost over the period 2000 to 2005
will be $4.0 million. EPA costs for only the Assessment Monitoring component of the UCMR program
would be $15.7 million, with average annual costs of $3.1 million. EPA costs for UCMR
implementation are show in Table 26; average annual labor and non-labor costs, as well as small system
testing program costs are shown in Table 27.
Table 26. Yearly Cost to EPA for Implementation of the UCMR, by Type of Cost
Cost
Descrip-
tion
2000
2001
2002
2003
2004
2005
Total
Regulatory Support Activities: laboratory capacity, QA/QC; small system testing program implementation,
establishing reporting and data review protocol; technical support, guidance document development; and data
quality review and analysis
$873,456
$970,184
$913,456
$973,456
$1,013,456
$825,000
$5,569,008
Small System Testing for Assessment Monitoring: Analytical and shipping costs for small system Assessment
Monitoring, costs for contractor site visits to Index Systems
$0
$2,078,543
$2,078,543
$2,078,543
$327,537 . $327,537
$6,890,703
Small System Testing for Screening Surveys and Pre-Screen Testing: Analytical and shipping costs for small
system Screening Surveys and Pre-Screen Testing, and costs for contractor site visits to small Pre-Screen Testing
systems
$0
$0
$766,030
$791,203
$2,853,624
$0
$4,410,857
National and Regional Oversight and Data Analysis: UCMR management oversight; review and evaluation of
data from Assessment Monitoring, Screening Surveys, and Pre-Screen Testing
TOTAL
$603,000
$1,476,456
$495,000
$3,543,727
$495,000
$4,253,029
$675,000
$4,518,202
$495,000
$4,689,617
$495,000
$1,647,537
$3,258,000
520,128,568
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Table 27. Summary of EPA Burdens and Costs for UCMR Implementation
Burden / Cost
/
Labor Cost
Non-Labor Cost
Total Cost to EPA for
UCMR Implementation
Small System Testing Program
Cost (subset of non-labor cost)
Burden (labor hours)
Total Cost for 2000-2005
$3,258,000
$16,870,567
$20,128,568
$15,030,570
81,450
Annual Average Cost
over 5-year
Implementation Cycle1
$651,600
$3,374,113
$4,025,714
$3,006,114
16,290
1. Agency costs are estimated over the period 2001 -2005, with some start up costs in the
year 2000. These are averaged on a five-year basis to represent average annual costs of
the five-year implementation cycle.
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E. Change in Burden
1. Current ICR
This background cost document and related ICR, in effect, amend the current drinking water
program ICR (EPA #0270.39, OMB #2040-0090). However, the cost estimates related to the
unregulated contaminant monitoring program within the current ICR are not used as the baseline costs
for this analysis. An itemized listing of the burden and cost estimates provided in the current ICR are
listed below in Table 28. The discussion below summarizes the necessity for developing new baseline
estimates. The new baseline assumptions and estimates are then provided in the remainder of this
section.
Table 28. Unregulated Contaminant Monitoring Burden and Cost Estimates from the Current
Drinking Water ICR
Information Provided in Drinking Water ICR
(#0270.39)
Unregulated contaminants
Inventory of systems subject to regulation
Total Number of Responses
Total Number of Responses per Respondent
Total Burden for All Systems
Burden per Response
Total Cost for All Systems
Average Cost per System
Estimates Derived from Current ICR
Phase II unregulated lOCs and SOCs
78,803
1.1 million in 1996 only
14 responses per system in 1996
29,945 hours
0.03 hours or 2 minutes per response
$38.6 million
$490 per system in 1996
There are several reasons why it was necessary for EPA to develop a baseline for the current
unregulated contaminant monitoring. Chief among them is the fact that the current ICR only deals with
unregulated monitoring through generalities, with limited documentation of how cost estimates are
derived. The current ICR does not include the complete list of contaminants required, rather it notes
only that estimates include the Phase II unregulated lOCs and SOCs. In contrast, the majority of the
currently required compounds are VOCs. Further, few details are given on system assumptions (e.g.,
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which systems are involved, how many have ground or surface water sources), entry points/sampling
stations, monitoring frequencies, analytical costs, or labor burden assumptions. - '-J
The "new" baseline that EPA has developed contains more and newer information regarding system
inventories, and labor and non-labor costs. For UCMR and baseline estimations, EPA used more
detailed information on system entry points, made available through the ASDWA survey. The public
water system inventory used for both the UCMR and the baseline has been specifically edited to correct
discrepancies between SDWIS and actual system inventories (see Section B.I forPWS inventory
specifications). In addition, with information that is now known about the practical implementation of
the chemical monitoring regulations, EPA estimated the additional labor incurred by systems for
unregulated monitoring. Finally, EPA derived baseline analytical costs from more current laboratory
pricing schedules.
2. "New" UCMR Baseline
Baseline costs for the existing Phase II/V unregulated contaminant monitoring are estimated for the
purposes of this cost analysis. The same general framework and approach is used as for the UCMR
Assessment Monitoring program (see Sections B - D of this document). In estimating system and State
costs and burdens, the same standard labor rates and activities are used. The same water system
inventory numbers are used and complete implementation is assumed.
The existing program includes all systems serving more than approximately 500 people, with many
States even collecting data from these smaller systems.4 Although systems serving 500 or fewer were
generally not required to monitor under the existing rule, data in the Unregulated Contaminant
Monitoring Information System (URCIS) show that about one-third of systems serving 500 or fewer
people were none-the-less involved in the monitoring; thus, one-third were included in the estimates.
Table 29 presents the inventory of systems that were used in estimating system and State baseline costs.
4 State collection of unregulated contaminant monitoring data for small systems has been evidenced
in the EPA data verification process, in which the EPA visits the primacy agencies to confirm that
oversight of PWSs is being conducted according to federal regulations.
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Table 30. Contaminants Required Under the Existing Phase n/V Unregulated Monitoring
Program
23
24
25
26
27
28
29
30
31
32
33
34
bromobenzene
bromodichloromethane
bromoform
bromomethane
chlorodibromomethane
chloroethane
chloroform
chloromethane (methyl
chloride)
dibromomethane
m-dichlorobenzene
o-chlorotoluene
p-chlorotoluene
108-86-1
75-27-4
75-25-2
74-83-9
124-48-1
75-00-3
67-66-3
74-87-3
74-95-3
541-73-1
95-49-8
106-43-4
For comparison, it is assumed that if existing (Phase II/V) unregulated contaminant monitoring
continues, all regulated systems would conduct the monitoring over three years within the 2000 to 2005
period; with ground water systems sampling once in one year, and surface water systems sampling four
times during one year. (This period overlaps parts of two cycles of monitoring. However, systems that
had completed the first round before 2000 would need to complete another round if this program was not
replaced by the UCMR.) Total cost to small systems for the existing unregulated monitoring program
are estimated at $35.8 million. As seen in Section B of this document, the estimated cost to small
systems for implementation of the proposed UCMR is $99,310. Thus, under the UCMR, nationwide
savings to small systems is estimated to be just over $35.6 million. Annual per system costs for those
800 small systems that participate in UCMR monitoring will be reduced by approximately $190 per year.
Small systems will realize this savings because under the proposed program, none will be required to
cover the cost of analysis for the unregulated contaminants, as many do under the existing program.
Only those 800 systems that become part of the national representative sample will incur any costs at all,
and those will be attributed to labor only.
Large systems would incur a $13.0 million cost for this monitoring cycle of the existing unregulated
monitoring program. Under the UCMR, large system costs are increased by almost $14.0 million,
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primarily due to the increase in laboratory analytical costs. Annual per system costs are increased by
approximately $ 1,000 per system under the UCMR program.
Baseline cost to the States is estimated to be $7.5 million for the analogous monitoring cycle of 2000
to 2005. Under the UCMR, States are estimated to incur $2.3 million in costs over the same period. ,_
Thus, the total savings to States under the UCMR is estimated to be $5.2 million. This savings is
attributed to a decrease in required labor. States will be collecting and reporting monitoring data from
perhaps 30,000 fewer water systems, because only a representative sample of systems serving 10,000 or
fewer people will be involved in the UCMR.
EPA baseline costs are estimated as a percentage of the overall drinking water program. Agency
costs for running the existing program are estimated at $1.9 million for the analogous period of 2000 to
2005. EPA costs are significantly increased under the UCMR, primarily because, as proposed, the
Agency will fund all small system analytical and shipping costs.
The Agency notes that reductions in costs can also be attributed to the "Suspension of Unregulated
Contaminant Monitoring Requirements for Small Public Water Systems (Direct Final Rule)" (64 FR
1499 (January 8, 1999)), which was issued in conjunction with the UCMR. The Direct Final Rule
cancels the requirements for systems serving less than 10,000 people to monitor for another round of the
existing list of unregulated contaminants, beginning in the first quarter of calendar year 1999. This
cancellation was issued because monitoring for the existing contaminants would overlap with this
revised program. Approximately two-thirds of systems serving between 3,300 and 10,000 will save the
costs of monitoring under the existing program by the action of the Direct Final Rule (e.g., in 1999 and
2000), before the UCMR becomes effective, resulting in an approximate system savings of $5.3 million.
c:\mfd\ucmr\costs\cost doc\ucmr-cost4. wpd
3/31/99
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Table 29. Number of Systems Sampling Under Existing Phase n/V
Unregulated Program
Size Category
500 and under
501 to 3,300
3,301 to 10,000
Subtotal <. 10,000
10,001 to 50,000
50,001 and over
Subtotal >10,000
TOTAL
Ground Water
Systems
15,360
12,306
2,404
30,070
1,254
204
1,458
31,528
Surface Water
Systems
640
1,820
1,006
3,466
927
389
1,316
4,782
Total Systems
16,000
14,126
3,410
33,536
2,181
593
2,774
36,310
One of the primary differences between the existing unregulated monitoring program and the
proposed UCMR is in the list of required contaminants. There are 48 chemical contaminants listed in the
existing unregulated program, 14 of which are "discretionary" contaminants that would not significantly
effect the cost of analysis.5 The 34 required, non-discretionary contaminants and the relevant pricing
assumptions used for these calculations are presented in Table 30 (this includes 13 SOCs (#1-13), 1 IOC
(#14), and 20 VOCs (#15-34)). While there are more contaminants analyzed than under UCMR, they are
derived from fewer analytical methods, and all are derived from standard methods used for routine
compliance samples. Also, the monitoring has almost exclusively been conducted coincident with the
systems' standard monitoring framework, allowing systems to primarily incur incremental analytical
costs instead of full costs.
The 14 discretionary contaminants are all VOCs that would be analyzed from the same sample as
numbers 15 - 34 on Table 30 and generally do not add further cost.
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DRAFT March 31,1999
Table 30. Contaminants Required Under the Existing Phase n/V Unregulate
**"'-* ~ - -^r_.w, u *-.-'«* * \
Program
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
Contaminant Name
aldicarb
aldicarb sulfone
aldicarb sulfoxide
carbaryl
3-hydroxycarbofuran
methomyl
aldrin
dieldrin
propachlor
butacfelor
metolachlor
metribuzin
dicamba
sulfate
1,1,1 ,2-tetrachloroethane
1 , 1 ,2,2-tetrachloroethane
1,1-dichIoroethane
1,1-dichloropropene
1 ,2,3-trichloropropane
1 ,3-dichloropropane
1 ,3-dichloropropene
2,2-dichloropropane
CASRN
116-06-3
1646-88-4
1646-87-3
63-25-2
16655-82-6
16752-77-5
309-00-2
60-57-1
1918-16-7
23184-66-9
51218-45-2
21087-64-9
1918-00-9
14808-79-8
630-20-6
79-34-5
75-34-3
563-58-6
96-18-4
142-28-9
542-75-6
594-20-7
Method
531.1
505,508,508.1
508, 507
507
515.1,515.2
Various
502.2 (for 15-
34)
Cost
$230
$150
no charge
$160
$150
$15
$173 (for 15-34)
d Monitoring
Incremental Cost
$30
$20
no additional charge
$10
no additional charge
$15
$90 (for 15-34)
Cadmus / EPA Draft
UCMR Cost ry.
Page 62
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