:- EPA Do
OMB Control Number: 2040-0090
Information Collection Request
for the
Unregulated Contaminant Monitoring Regulation
DRAFT
April 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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TABLE* OFCQNTENTS"
Page
1 IDENTIFICATION OF THE INFORMATION COLLECTION 1
l(a) Title and Number of the Information Collection 1
l(b) Short Characterization 1
2 NEED FOR AND USE OF THE COLLECTION 5
2(a) Need/Authority for the Collection 5
2(b) Practical Utility/Users of the Data 5
3 NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA 7
3(a) Non-duplication 7
3(b) Public Notice Required Prior to ICR Submission to OMB 7
3(c) Consultations 7
3(d) Effects of Less Frequent Collection 12
3(e) General Guidelines 15
3(0 Confidentiality 16
3(g) Sensitive Questions 16
4 THE RESPONDENTS AND THE INFORMATION REQUESTED 17
4(a) Respondents/SIC Codes 17
4(b) Information Requested 17
4(b)(i) Data Items, Including Reporting and Record Keeping 17
4(b)(i)(a) Public Water System Reporting and Record Keeping 17
4(b)(i)(b) State Reporting and Record Keeping 20
4(b)(ii) Respondent Activities 20
4(b)(ii)(a) Public Water Systems 20
4(b)(ii)(b) States 22
5 THE INFORMATION COLLECTED - AGENCY ACTIVITIES, COLLECTION
METHODOLOGY, AND INFORMATION MANAGEMENT 25
5(a) Agency Activities 25
5(a)(i) Regulatory Support Activities 25
5(a)(i)(a) Laboratory Capacity and QA/QC Activities 25
5(a)(i)(b) Implementation of Small System Testing Program / Reporting
and Data Review Protocol 25
5(a)(i)(c) Technical Support / Guidance Document Development 26
5(a)(i)(d) Data Quality Review and Analysis 26
5(a)(ii) Analytical Costs for Small System Testing Program 26
5(a)(ii)(a) Small System Analytical and Shipping Costs 26
5(a)(ii)(b) Contractor Site Visits to Index and Small Pre-Screen Testing
System 26
5(aXiii) National and Regional Oversight / Data Analysis 27
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Txfatetti Content^ toaliautd
5(b) Information Collection Methodology And Management 27
5(c) Small Entity Flexibility 27
5(d) Collection Schedule 37
6(a) Estimating Burden and Cost to Public Water Systems 40
6(a)(i) Estimates of Burden and Labor Costs to Public Water Systems 42
6(a)(i)(a) Reading the Regulations/State Letter 43
6(a)(i)(b) Monitoring Burden 43
6(a)(i)(c) Reporting and Record Keeping 43
6(a)(i)(d) Public Notification 44
6(a)(ii) Estimates of Non-labor Costs to Public Water Systems 44
6(b) Estimating the Burden and Cost to States 45
6(b)(i) Coordination with EPA 46
6(b)(ii) Data Management and Support 47
6(b)(iii) Laboratory Training 47
6(b)(iv) Program Implementation 47
6(b)(v) Overhead 48
6(c) Estimating Agency Burden and Cost 48
6(d) Estimating the Respondent Universe and Total Burden and Costs 50
6(f) Reasons for Change in Burden 53
6(f)(i) Current ICR 53
6(f)(ii) "New" UCMR Baseline 54
6(g) Burden Statement 58
APPENDIX A: Relevant Authorities in the SDWA 1996 Amendments 61
APPENDIX B: Burden and Cost Calculations for the UCMR 67
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TABLE OF EXHffiFFS
Page
Figure 1. Proposed Approach for the Unregulated Contaminant Monitoring Regulation 4
Table 1. Unregulated Contaminant Monitoring Reporting Requirements 18
Table 2. UCMR Assessment Monitoring / List 1 (1999) Contaminants: analytical
methods and estimated costs per analysis 18
Table 3. Number of Publicly- and Privately-Owned Small Systems to Participate in
Assessment Monitoring 29
Table 4. EPA Costs for Small Systems under Full Implementation of UCMR 30
Table 5a. UCMR Full Implementation Scenario: Analysis for Publicly-Owned
Systems (2001-2005) 31
Table 5b. UCMR Full Implementation Scenario: Analysis for Privately-Owned
Systems (2001-2005) 32
Table 6. Number of Publicly- and Privately-Owned Systems to Participate in Assessment
Monitoring, for Limited Funding Program 33
Table 7. EPA Costs for Small Systems — Limited $4 million Program 34
Figure 2. Cost Calculations for the UCMR ICR 38
Table 9. Yearly Cost to Systems for Implementation of the Assessment Monitoring
Component of the UCMR Program, by System Size and by Type of Cost ... 40
Table 10. Assessment Monitoring Per System and Per Response Costs 41
Table 11. Number of Index and Non-Index Systems to Conduct Assessment Monitoring,
by Source Water and System Size 42
Table 12. Yearly Total Cost to All States/Primacy Agencies for Implementation of UCMR, by
Type of Cost 45
Table 13. UCMR Per State and Per Response Costs 46
Table 14. Yearly Cost to EPA for Implementation of the UCMR, by Type of Cost 49
Table 15. Summary of EPA Burdens and Costs for UCMR Implementation 50
Table 16. Assessment Monitoring Response and Burden Summary 51
Table 17. Assessment Monitoring Cost Summary 52
Table 19. Number of Systems Sampling Under Existing Phase II/V Unregulated Program 54
Table 20. Contaminants Required Under the Existing Phase II/V Unregulated
Monitoring Program 55
Table 21. Assessment Monitoring Burden and Cost Summary 58
ill
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Draft—ICRJbr the UCMR—April 7,. 199*
1 IDENTIFICATION OF THE INFORMATION COLLECTION
l(a) Title and Number of the Information Collection
TITLE: UNREGULATED CONTAMINANT U.S. EPA ICR Number: 0270.42
MONITORING REGULATION OMB Control Number: 2040-0090
l(b) Short Characterization
The Office of Ground Water and Drinking Water in the Office of Water at the United States
Environmental Protection Agency (EPA or Agency) is responsible for managing public drinking water
system programs under the Safe Drinking Water Act (SDWA). The SDWA, as amended in 1996,
requires the Agency to develop an Unregulated Contaminant Monitoring Regulation (UCMR). The
requirements for unregulated contaminant monitoring were first established by the 1986 Amendments to
the SDWA and were included as part of the Phase I chemical regulation under 40 CFR Parts 141.40(a)-
(e). The Phase II regulation superceded the Phase I rule. Some of the Phase I unregulated contaminants
became regulated under Phase II and additional contaminants were added to the list of unregulated
contaminants. The Phase V chemical regulation further modified the list of contaminants as additional,
unregulated contaminants became regulated. The basic monitoring and reporting requirements for
unregulated contaminants are the same under the Phase I, II, and V regulations. Public water systems
(PWSs) are required to report their monitoring results to the States/Primacy Agencies. These data are to
be reported, in turn, to EPA. In addition, only systems serving less than 150 service connections are
exempt from monitoring provided that they make their facilities available for monitoring by the States.
Repeat monitoring is required every 5 years.
Section 125 of the SDWA 1996 Amendments substantially revises unregulated contaminant
monitoring. The new program is to include: (1) a new list of contaminants (i.e., the Unregulated
Contaminant Monitoring Regulation (UCMR) List, developed in coordination with the Contaminant
Candidate List (CCL) process), (2) a representative sample of PWSs serving 10,000 or fewer people, (3)
placement of the monitoring data in the National Contaminant Occurrence Database (NCOD; authorized
under the SDWA Amendments, §126), and (4) notification of consumers of the availability of
monitoring results. The 1996 Amendments limit the number of contaminants that can be on the UCMR
List to 30 or less, require that only a representative number of systems serving a population less than or
equal to 10,000 be required to monitor, and require that, if funds are appropriated, EPA pay the
reasonable cost for sample analysis for this representative sample of systems. The proposed unregulated
contaminant monitoring data will be used in future regulation development. The statistical approach to
be used is one of the cornerstones of the sound science approach to future drinking water regulation,
which is an aim of the SDWA 1996 Amendments.
The proposed UCMR will replace the existing unregulated monitoring program which began in
1989. A companion action to this proposal, the "Suspension of Unregulated Contaminant Monitoring
Requirements for Small Public Water Systems" (64 FR 1499) canceled the unregulated contaminant
monitoring for those small systems serving 10,000 or fewer people which was required under the
existing program.
Pagel
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Draft-iCR foe the UCMR-Aprrt?r 1999
This proposal would affect all 2,774 non-purchased community water systems (CWSs) and non-
purchased, non-transient, non-community water systems (NTNCWSs)1 serving more than 10,000 people
(hereafter referred to as large systems); the 800 CWSs and NTNCWSs, serving 10,000 or fewer people "
(hereafter referred to as small systems) that will comprise the national representative sample; and the 56
States/Primacy Agencies. As illustrated in Figure 1, the proposed UCMR Program will include 3 years
of Assessment Monitoring (2001-2003), with approximately one-third of all the affected systems
monitoring each year for 11 contaminants (10 chemicals and 1 microbiological contaminants). Two
Screening Surveys will be conducted in separate years, with each Screening Survey targeting a different
list of chemical contaminants. A subset of approximately 300 Assessment Monitoring systems will
collect samples for each of the Screening Surveys. Finally, another set of up to 200 systems will be
chosen to participate in 1 year (2004) of Pre-Screen Testing.2
This Information Collection Request (ICR) was prepared in accordance with the December 1996
version of EPA's Guide to Writing Information Collection Requests Under the Paperwork Reduction Act
(PRA) of 1995 (or "ICR Handbook") prepared by EPA's Office of Policy, Planning, and Evaluation. It
serves as an amendment to the current Information Collection Request for the Public Water System
Supply Program (with EPA tracking number 0270.39 and OMB number 2040-0090, hereafter, referred to
as the Drinking Water ICR). This ICR examines the impact of the UCMR program on PWSs and
primacy agencies for the 3-year period 1999-2001. Since the actual implementation period for the
UCMR program is 2001-2005, this ICR only presents the costs of implementation for the year 2001, plus
the costs of some preparatory activities that are assumed to take place prior to implementation. In
addition, since the ICR period coincides with only one of the three primary years of Assessment
Monitoring, only approximately one-third of the water systems that will be regulated under the UCMR
will be impacted during this ICR period. UCMR-related costs and burdens that are expected to occur
after the year 2001 will be addressed in future ICRs.
For the ICR period 1999-2001, the burden for small systems is estimated to be an average of 1.5
hours annually per system, with an annual cost of $32. Total cost for the 287 small systems that are
affected during this ICR period is estimated at $27,870. Large systems are estimated to have a 3.3 hour
CWSs are those PWSs that serve at least 15 service connections used by year-round residents, or
regularly serve at least 25 year-round residents, (eg., cities, townships, district water authorities,
or private water companies serving such communities). NTNCWSs are those PWSs that are not
CWSs and that serve at least 25 of the same persons over six months of the year (eg., schools,
factories or other facilities with their own separate water systems). Non-purchased water systems
are those PWSs that do not buy their primary source of water from another water supplier.
In addition to the national representative sample of 800 small systems, it is possible that as many
as 150 other small systems could be selected for Pre-Screen Testing. The Pre-Screen Testing
systems are to be selected based on vulnerability and it is not possible to pre-determine which •
systems may or may not coincide with those in the original sample. EPA assumes only 800 total
small systems for program cost estimation because it presents a "worst-case" per system cost, with
maximum total costs divided across the smallest possible number of systems. This does not effect
the cost estimates in this ICR, since Pre-Screen Testing will not occur until after 2001. The Pre-
Screen Testing estimates are further explained in Appendix B to this document.
Page 2
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Draft—ICR for the UCMR.—April?, 199*
per system annual burden, with a labor cost of $93 per year. Non-labor costs per year for these systems
is estimated at $2,793 per system. Total cost for the 925 large systems is estimated to be $8.0 million for
the years 1999-2001.
When considering the difference between UCMR costs and the current system costs for the Phase
II/V unregulated contaminant monitoring program, small systems will realize an average savings under
the proposed UCMR program of approximately $324 per year for the ICR period.3 These savings are
realized because under the proposed UCMR, EPA will pay for the testing costs for the national
representative sample of small systems. Large systems that are affected during the ICR period will
realize an average increased cost (primarily attributed to laboratory analytical fees) of $1,215 per year.
On average, it is estimated that each State will incur 141 hours of burden per year, with an annual
labor cost of $5,647 for the ICR period 1999-2001. Non-labor costs for States were assumed to be
minimal, with 10 percent of the States incurring a one-time $25,000 contractor cost for upgrading their
drinking water databases; an average of $833 per year per State for the ICR period. The total cost for all
States for the period 1999-2001 is estimated to be $1.1 million. The average annual cost to all States will
decrease by approximately $0.92 million per year over 1999-2001, compared to implementation of the
current unregulated monitoring program. State costs will decrease under the UCMR because they will
have to oversee many fewer PWSs than under the existing program. The Agency is estimated to incur an
annual burden of 9,150 hours, with an average annual cost for labor of $366,000. Non-labor costs for
EPA, which are primarily comprised of the analytical and shipping costs for representative set of small
systems, and other contractor costs, are estimated at $1.3 million per year over the period 1999-2001.4
The total EPA cost for the ICR period is estimated to be $5.0 million; with an estimated increased cost of
$1.4 million per year compared to the existing program. The Agency cost increase will be primarily
attributed to the cost of the small system testing program.
Per system changes in burden for small systems refer only to those systems that will be part of the
national representative sample. Systems that are not chosen to participate in the UCMR program
will not incur any costs, and will thus have an average annual savings equal to what they would
have been spending under the existing unregulated monitoring program.
Because the actual implementation period of the UCMR does not begin until 2001, most of the
costs presented here occur during that year. Average annual costs reflect the fact that the UCMR
program implementation only overlaps with one of the three ICR years (1999-2001).
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Draft—ICR firthe UCMR - April T, &99
EPA UCMR
List
up to 30
contaminants
i
*.. , .
r
^
7 or more Governors may petition EPA to
add contaminants to list
....
State may
apply to EPA
Assessment Monitoring
List 1 (1999) Contaminants
Quarterly for surface water
systems and 2 times
6
months apart for ground
water systems for 1 year,
during 200 1-2003
All 2,800 large
systems
Representative
Sample of small
systems (800 of
65,600) identified
by EPA
1
''
T/\r
Iwl
contaminant
monitoring
waiver
State may
waive
electronic
reporting for
PWS
^
fe*.
State
Monitoring
Plan
for
Representative
Sample
r , ,
PWS
Reporting
Electronically
20 Data
Elements
t
Two Screening Surveys for
List 2 (1999) Contaminants
300 statistically selected
systems in each of 2 years
(2002 and 2003); same
frequency as Assessment
Monitoring
".. 1
h
Pre-Screen Testing
List 3 (1999) Contaminants
up to 200 most vulnerable
systems, 2 times during
2004
EPA Pays
for Small
Systems in
Plan and in
Pre-Screen
Testing
^
State
Reporting
. Electronically
20 Data
Elements
T '
Public
Notification,
Consumer
Confidence
Report
EPA
National
Contaminant
Occurrence
Database/
SDWIS-FED
Figure 1. Proposed Approach for the Unregulated Contaminant Monitoring
Regulation
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Draft-ICJLfot the. UCMR-April7r 1999
2 NEED FOR AND USE OF THE COLLECTION
The following sections describe the need for this information collection, the legal authority under '
which this information can be collected, and why this information is necessary to support drinking water
program objectives.
2(a) Need/Authority for the Collection
The information collected under this rule is required by EPA to carry out its regulatory development
responsibilities under the SDWA. Without comprehensive, up-to-date information on drinking water
contamination, the Agency will not be able to meet the SDWA statutory requirements.
Section 1412(b)(4) of the SDWA, as amended in 1996, requires EPA to promulgate maximum
contaminant level goals (MCLGs) and promulgate National Primary Drinking Water Regulations
(NPDWRs) for contaminants that may have adverse human health effects, are known to or anticipated to
occur in PWSs, or, in the opinion of the Administrator, present an opportunity for health risk reduction.
The NPDWRs specify maximum contaminant levels (MCLs) or treatment techniques for drinking water
contaminants (42 USC 300g-l). An MCL must be set as close to the MCLG as possible. NPDWRs
apply to PWSs (42 USC 300f(l)(A)). Section 1412(b)(l) requires the Agency to develop a list of
unregulated contaminants for regulatory consideration (i.e., the CCL), to issue regulations which
establish criteria for listing contaminants, and to carry out the UCMR Program. The Agency is required
to finalize the list of contaminants by August 1999, and every 5 years thereafter.
Section 1445(a)(l) of the Act requires each PWS to "establish and maintain such records, make such
reports, conduct such monitoring, and provide such information as the Administrator may reasonably
require by regulation to assist him in establishing regulations, [or]... in evaluating the health risks of
unregulated contaminants ...". This section authorizes EPA to require systems to monitor, provide the
Agency with these data, and to maintain records of this information.
In addition, §1401(l)(d) of the SDWA 1996 Amendments defines NPDWRs to include "criteria and
procedures to assure a supply of drinking water which dependably complies with such maximum
contaminant levels; including accepted methods for quality control and testing procedures ...". This
section authorizes EPA to require systems and laboratories to use Agency-approved methods and quality
assurance criteria for collecting and analyzing water samples.
The sections from the SDWA 1996 Amendments, discussed above, are included as Appendix A of
this document.
2(b) Practical Utility/Users of the Data
The unregulated contaminant monitoring data collected under this proposed rule will be used to
support: (1) the development and interactive evolution of the CCL; (2) the Administrator's determination
of whether to regulate a contaminant; and (3) regulation development. In addition, if the contaminant
has significant occurrence and health effects, EPA will use the results as part of an exposure assessment,
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Draff—ICRfertileUCMR—AprifT; F999
for establishing the baseline for health effects and economic analyses, for contaminant co-occurrence
analysis, and for treatment technology evaluation, including contaminant source management. Further,
the results may suggest that certain contaminants have significant enough occurrence to initiate research
on health effects and treatment technology. Finally, the data may guide future source water protection
efforts.
System level records of the analytical results of monitoring actions will be maintained by each
PWS. Systems will also report these data to the State/Primacy Agency. States will maintain records on
each system's required monitoring and analytical results. States will report these results electronically to
the Safe Drinking Water Information System (SDWIS) database, which will be linked to the National
Contaminant Occurrence Database (NCOD).
The Agency currently uses the information in SDWIS to conduct various program analyses, and to
support the critical Agency function of program oversight. The data are used to characterize compliance
trends at the system, State, and national program levels. Furthermore, States use this information to
maintain and track compliance data for PWSs located within their jurisdiction.
The Agency will use SDWIS in conjunction with NCOD to assess the monitoring data that will be
generated as a result of the UCMR. Historically, reporting of analytical results to SDWIS has been
limited to MCL exceedances or exceedances of the lead or copper action level. UCMR program
reporting will include more complete analytical results on contaminant occurrence.
EPA's Office of Ground Water and Drinking Water, and other EPA offices that implement
regulatory programs mandated by several environmental statutes (e.g., Comprehensive Environmental
Response, Compensation, and Liability Act; Resource Conservation and Recovery Act; and the Toxic
Substances Control Act) use compliance monitoring data to support program implementation. Non-EPA
organizations also use these data, including: the Rural Development Administration (formerly Fanners
Home Administration), the Department of Interior, the Department of Housing and Urban Development,
the U.S. Army Corps of Engineers, the Federal Emergency Management Agency, the Small Business
Administration, White House Task forces, environmental and industry groups, and many private
companies and individuals. In addition, EPA often receives requests for public water system monitoring
data or other information under the Freedom of Information Act (FOIA). Many FOIA requests require
information regarding the-occurrence of regulated contaminants in public water systems in a particular
geographic area. Under the UCMR Program, as more actual contaminant data will be available to the
public through EPA, it is anticipated that requests from these agencies, organizations, and individuals
will increase.
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Doft.—ICJLfot the UCMR — April 7^ 1999-
3 NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA
The following sections verify and affirm that this information collection satisfies the Office of
Management and Budget's (OMB's) collection guidelines, has public support, and does not duplicate
another collection. The EPA has consulted with other federal agencies, State agencies, industry
organizations, water systems, and environmental groups to ensure non-duptication of this information
collection.
3(a) Non-duplication
The data required by the UCMR are not available from any other source and are not duplicative of
information otherwise accessible to EPA. The Agency assessed the results of previous unregulated
contaminant monitoring and information from other data sources to establish the new CCL and in the
ongoing process of development of the NCOD. The CCL identified contaminants of potential concern
that may occur or are likely to occur in drinking water. EPA, in conjunction with the National Drinking
Water Advisory Council's Working Group on Contaminant Occurrence and Selection, developed the
UCMR List by selecting the contaminants from the CCL for which additional occurrence data was
needed to assess potential environmental and health effects. Contaminants of concern that had other
adequate sources of occurrence data were either listed as priorities for regulatory determination or
priorities for health effects and/or treatment research, and were not included on the UCMR List.
3(b) Public Notice Required Prior to ICR Submission to OMB
To comply with the 1995 Amendments to the Paperwork Reduction Act, the Agency will solicit
public comment on this ICR for a 45-day period coincident with the rule comment period and before it is
submitted to OMB. The Agency will publish a notice in the Federal Register requesting comment on the
estimated respondent burden or any other aspect of this information collection. Comments received will
be considered by the Agency and used to determine if any adjustments are needed to the burden/cost
calculations before the ICR is finalized.
3(c) Consultations
Sections 102 and 126 of the SOW A are very specific about input from States, the public and the
scientific community for the CCL and NCOD. Since the UCMR will result in data being placed in
NCOD, and the CCL provides the basis for the UCMR List, public input began during these
developmental stages of the UCMR.
During the development of the UCMR, stakeholders from a wide range of public and private entities
provided key perspectives. Representatives from PWSs, States, industry, and other organizations
attended two stakeholder meetings to discuss options directly related to the UCMR. An additional 17
meetings were held with stakeholders and the public concerning issues related to the UCMR. In total, 21
State health and environmental agencies, 5 water systems, 6 water associations, 6 health associations, 5
industrial associations, 4 environmental organizations, 4 community and consumer organizations, 29
companies, and 7 federal agency offices participated in the development of the proposed regulation.
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Draft - ICR for the UCMR—Ap*7T 19»
As noted above, the CCL identifies contaminants for which EPA may take regulatory action and for
which EPA needs additional data. The UCMR List includes those for which additional data are needed.
The meetings to develop the CCL have included stakeholder meetings to discuss the list broadly and
meetings focused on particular issues conducted through the National Drinking Water Advisory
Council's Working Group on Occurrence and Contaminant Selection, as follows:
December 2-3, 1996 Stakeholders Meeting
April 3-4, 1997 NDWAC Working Group
June 23,1997 NDWAC Working Group
July 17, 1997 NDWAC Working Group
January 7, 1998 NDWAC Conference Call
These meetings resulted in the Drinking Water Contaminant Candidate List, published on March 2,
1998 (63 FR 10274). The proposed UCMR List was derived from the CCL's list of Occurrence
Priorities.
The NCOD development activities have included 10 public meetings on information requirements
that should be considered for inclusion in that database. These meetings were held from October 1997 to
February 1998. The work of the NCOD development team has been incorporated in the preparation of
this proposed unregulated contaminant monitoring regulation as the reporting requirements for sample
testing. Several documents are included in the docket for this rule concerning NCOD development
which were used in the public meetings:5
Options for the National Drinking Water Contaminant Occurrence Database, Background Document
(Working Draft), EPA 815-D-97-001, May 1997;
National Drinking Water Contaminant Occurrence Database - Development Strategy, Background
Document (Working Draft), EPA 815-D-97-005, December 1997; and
Options for Design of the National Drinking Water Contaminant Occurrence Database, Background
Document (Working Draft), EPA 815-D-98-001, January 1998.
EPA held its first stakeholders meeting to discuss options for the development of the UCMR on
December 2-3, 1997, in Washington, DC. A range of stakeholders attended that meeting, including
representatives of PWSs, States, industry, health and laboratory organizations, and the public. EPA
prepared a background document for the meeting, Options for Developing the Unregulated Contaminant
Monitoring Regulation (Working Draft), EPA 815-D-97-003, November 1997. A summary of the
meeting is also available. Prior to preparation of this proposed regulation, EPA held a second
stakeholders meeting on June 3-4, 1998, to obtain input from interested parties on significant issues
evolving from drafting the regulation, which needed further public input. EPA prepared a public review
These documents are available from the EPA Water Docket, (202) 260-3027, Docket Number W:.
98-02. General information on the UCMR and NCOD can also be obtained from the EPA Safe
Drinking Water Hotline, (800) 426-4791, or through the EPA Office of Ground Water and
Drinking Water Internet Home Page at www.epa.gov/ogwdw.
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, Daft- ICR fortbe UCMR - April 7,1999;
document for that meeting, Background Information and Draft Annotated Outline for a Proposed
Unregulated Contaminant Monitoring Regulation, Background Document,' (Working Draft), May 1998.
A meeting summary is available from the EPA Water Docket (Docket Number W-98-02). EPA also sent
special requests for review of stakeholder documents to more than 360 tribes (exclusive of the Alaskan
native villages) and to small system organizations to obtain their input. '' ~--~! " '^ -'-•-
The listing below identifies all the members of the public or organizations that participated in public
meetings that provided input to the development of the UCMR (numbers in parentheses represent the
count of people or organizations listed):
General Public (\}
Howard Fields
States
Arizona Department of Environmental Quality
California Department of Health Services
Colorado Department of Health and Environment
Connecticut Department of Public Health
Florida Department of Environmental Regulation
Indiana Department Of Environmental Management
Illinois Environmental Protection Agency
Kansas Department of Health and Environment
Maryland Department of the Environment
Massachusetts Department of Health
Michigan Department of Environmental Quality
Minnesota Department of Health
Missouri Department of Natural Resources
New Jersey Department of Environmental Protection
New York Department of Health
Oregon Department of Human Resources
Pennsylvania Department of Environmental Protection
South Carolina Department of Health and Environmental Resources
South Dakota Department of Environment and Natural Resources
Texas Natural Resources Conservation Commission
Virginia Department of Health
Water Systems (5)
American Water Works Service Co.
Fairfax County Water Authority
Manchester Water Works
Philadelphia Suburban Water Company
Wichita Water & Sewer Department
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Draft - ICR for the UCMR.—
^-Associations - Local Government (1)
lt National League of Cities
Associations - Water, Related (6)
Association of State Drinking Water Administrators
American Water Works Association.
Association of Metropolitan Water Agencies
National Association of Water Companies
National Rural Water Association
Plumbing Manufacturers Institute
Associations - ffealt/t Related (6)
American Public Health Association
American Society for Microbiology
Association of State and Territorial Public Health Laboratory Directors
Association of State and Territorial Health Officials
Council of State and Territorial Epidemiologists
National Association of City and County Health Officials
Associations - Industrial (5)
American Crop Protection Association
Chemical Manufacturers Association
American Zinc Association
Salt Institute
NSF International
Academic fnstitutipns (3)
Steven Balla, George Washington University
Dan Sklarew, George Mason University
Gary Toranzos, University of Puerto Rico
Environmental Organizations (4)
Clean Water Action
Department of Planet Earth
Environmental Working Group
Natural Resources Defense Council
Community.and Consumer Organizations (4)
Consumer Federation of America
League of Women Voters
Arlington County League of Women Voters
Working Group on Community Right-to-Know
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Draft —ICR forthe UCMR —April 7.199*-'
Companies (29)
3M Company
'Abt Associates
ADI Technology Corporation
Barrick Gold Corporation
BASF Corporation
Black & Veatch
BNA Reporter
Brannon Wilder, Consultant
Capitolink Legislative and Regulatory Services
Cleary, Gottlieb
Designers & Planners Incorporated
DuPont Agricultural Products
Hach & Company
Haglar, Bailly, Incorporated
ICF, Incorporated
ISSI, Incorporated
International Business Services
JD Information Services, Incorporated
Jellinek, Schwartze, and Connolly
Kinetico Incorporated
Kinghorn & Associates
Latham & Watkins
LeBouef, Lamb, Greene & MacRae
Miller Management Group
Novigen Sciences Incorporated
Paul Nelson, Consultant
Paulson Group
Technology Planning & Management Corporation
Weinberg, Bergeson and Newman
Zeneca Agricultural Products
Other Non-Pro fit (1)
National Research Council
Other Federal (7)
National Center for Environmental Health (at the Center for Disease Control and Prevention)
US Department of Agriculture Forest Service
US Department of Agriculture Food Safety & Inspection Service
US Geological Survey
US Army Material Command
US Army Environmental Center
US Marine Corps - Headquarters
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Draft - ICR for the UCMR—April 7. i9»
The Resource Analysis Computer Program for State Drinking Water Agencies (hereafter referred to
as the State Resource Model), which is documented in the Resource Analysis Computer Program for
State Drinking Water Agencies, January 1993, was used by the Agency in preparing this ICR. The model
was designed by EPA's Office of Ground Water and Drinking Water to enable primacy agents to
estimate the resources needed to fund their drinking water programs; it contains a comprehensive list of
activities required to operate a drinking water program, including estimates of the number of systems
affected. The assumptions used in the model are based on input from a Work Group of 39 State
representatives and the Association of State Drinking Water Administrators (ASDWA). In addition, the
average number of entry points for water systems of different size categories was derived from an
ASDWA survey (ASDWA CWS Survey, 1993). Such information is critical in determining costs and
burden because most drinking water rules require monitoring at each entry point.
In preparing this ICR amendment, EPA reviewed analytical costs assembled from recent laboratory
pricing schedules previously compiled to develop consistent values for various program estimates.
These analytical cost data were used to develop estimates in this ICR, as well as other drinking water
program cost evaluations. These data were supplemented by an informal survey of national laboratories
for methods where no price information was available.
3(d) Effects of Less Frequent Collection
The Agency has considered a wide range of alternatives for frequency of collection that would still
allow the Agency to meet its statutory requirements and overall objectives. Less frequent data collection
than proposed would seriously affect the integrity of the data and result in insufficient data to fulfill the
needs envisioned by the 1996 SDWA Amendments, including the continued development of the CCL,
support of the Administrator's regulatory determinations, and overall regulation development. Under the
proposed UCMR, collection of unregulated contaminant occurrence data will be substantially reduced
compared to that which is collected under the existing unregulated monitoring program. The existing
program includes all systems serving more than approximately 500 people, with many States even
collecting data from these smaller systems.6 For the primary component of the UCMR Program —
Assessment Monitoring — data will be collected from a representative sample of 800 small systems,
along with all large systems. This means that data will be collected from perhaps 30,000 fewer systems
across the nation.7 Assessment Monitoring will only cover the UCMR List 1 (1999) contaminants. The
State collection of unregulated contaminant 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.
Based on national inventory estimates, and data from the Unregulated Contaminant Monitoring
Information System, there are currently over 33,000 systems serving 10,000 or fewer people that
may be collecting unregulated contaminant data. Up to 800 of these systems will be sampling
under the UCMR Program.
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burden of data collection is even further reduced for List 2 and 3 contaminants.* With this relatively
small number of participating systems, it is imperative that the data collected is of the highest possible
quality.
Monitoring frequencies were determined based on statutory requirements, which specify that
monitoring be varied based on the number of persons served by a system, contaminants likely to be
found, and source of supply. The monitoring frequency design also considers that the number of persons
served affects exposure to contaminants, as well as the resources available to undertake monitoring
activity. The collection frequencies in this rule are discussed further in Section 5(b). Monitoring
frequencies have been carefully devised based on the following factors:
• data quality needed for a representative sample;
• precision and accuracy needed from the representative sample;
• number of people served by the system;
• source of the supply (e.g., surface water or ground water);
• contaminants likely to be found;
• temporal variability in occurrence; and,
• synchronization with the Standardized Monitoring Framework (SMF) for Phase II/V.9
The Assessment Monitoring component of data collection requires that: all regulated ground water
systems (e.g., all large systems and the representative sample of small systems) monitor for the chemical
contaminants two times during 1 year of the monitoring period (2001-2003) at each entry point to the
distribution system representative of all water sources after treatment or other specified sampling
locations; all regulated surface water systems monitor for the chemical contaminants once each quarter
during 1 year of the monitoring period.10 Multiple samples during a year are necessary to capture the
annual variability in contaminant occurrence to approach an adequate characterization of potential
8 Only a subset of the Assessment Monitoring systems (approximately 600 systems) will participate
in the Screening Surveys for List 2. An even smaller sample of up to 200 systems, selected as
most vulnerable within each State to the List 3 microbiological contaminants, will participate in
Pre-Screen Testing. The Screening Surveys and Pre-Screen Testing do not occur during this ICR
period.
9 The standardized monitoring framework (SMF) was originally promulgated under the Phase II
Rule and revised under Phase IIB and Phase V regulations (CFR §§141.23-141.25). It
standardizes monitoring requirements within chemical contaminant groups and synchronizes
monitoring schedules across chemical contaminant groups into specific 3-year compliance periods
and 9-year compliance cycles.
10 Ground water systems are required to sample only two times per year because they generally
show less seasonal fluctuation. Both surface and ground water systems must ensure that one of
their samples is collected during the most vulnerable period, which the rule specifies by default to
be May - July.
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Draft- ICR for the UCMR- AprftT,
exposure. The required sampling frequencies will help provide the quality and quantity of data that will
be statistically necessary for regulatory determinations. Based on input from States, it is assumed that
State and system discretion will be used such that systems will conduct UCMR sampling coincident with
SMF to the extent possible, reducing the system labor burden for collection, and reducing analytical
costs to large systems.
The one microbiological contaminant on the Assessment Monitoring list will be monitored at two
points in the distribution system, two times during the year that a system is monitoring; once at the most
vulnerable time of the year, and once 6 months later. Each sampling event will include two locations in
the distribution system after treatment: at the first tap below a representative entry point to the
distribution system that are used for taking total coliform samples and at the tap nearest the end of the
longest distribution line that represents the longest residence time.
EPA has considered various statistical needs for accuracy and precision of estimates in design of the
representative sample, and proposes a sample of 800 systems from the universe of 65,636 small systems.
This would provide a confidence level of 99 percent with an allowable error of ±1 percent. The set of
representative systems are distributed among different size categories, but weighted by population
served, to ensure that the sample can provide estimates of exposure (Table 11).
EPA has selected these high standards to ensure the quality of the estimation. Larger sample frames
were considered, because of the many uncertainties involved, but the sample size of 800 was deemed
adequate to meet the needs for the national estimate. Smaller sample sizes (i.e., less frequent collection)
were also considered, but rejected. In general, many population surveys with continuous variables use a
lower level of confidence (95 percent) and/or a larger allowable error. However, the larger possible error
is not considered acceptable for this program. Examination and analysis of current occurrence data show
that many contaminants that are currently regulated, or being considered for regulation occur in one
percent or less of systems on a national basis. For many contaminants, a one percent occurrence
nationally translates into a substantially larger occurrence regionally. Also, even a small percentage of
systems with detections can translate into a significant population affected. With a greater margin of
error, and the resultant smaller sample size, such occurrence might be missed entirely. Also, it is
necessary for EPA to make some judgements about the occurrence of contaminants in relation to source
waters and different size categories of systems. Many statutes and current regulations are differentially
implemented for systems of different size, or for different source water categories. While combining
sampling results from the representative sample of small systems with that from all large systems
provides increased power in the total sample, EPA must be able to evaluate occurrence, and possible
regulatory options, related to the small systems themselves. SDWA and many current rules focus on
burden reduction for small systems when feasible. Also, there are many other uncertainties and sources
of variance in such a sample program. For example, all contaminants have censored distributions (i.e.,
"less than" analytical results) and there are a myriad of factors that affect variability and vulnerability of
ground water systems. It remains unclear how normal sampling theory accommodates these. Hence, the
high confidence level, low allowable error, and larger sample size should help to ensure adequate data to
meet the objectives of the UCMR program.
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Draft- ICR for tht UCMR—
Further, a portion of the sample needs to be distributed among all States, so that all States, and so
that systems in all States, proportionately contribute to the overall results that will be used for decision
making. All States need to share the burden of these programs, as well. EPA wants to ensure a
minimum of two representative systems in each State. With the small sample size, no conclusions may
be drawn about occurrence at the State level, but it is important that all States be represented. Some
contaminants, such as some pesticides, may only be used intensively in select regions of the country.
Some workgroup members have expressed concern that the relatively small number of systems in the
representative sample may miss contaminants with such targeted regional use patterns. Including
systems in every State, in proportion to population served, should ensure that contaminants with regional
use patterns, to the extent they contaminate water supplies, will be proportionately represented by the
national sampling design. These factors were also considered in making the selection of the number of
systems. Reducing the sample size would not accommodate these considerations for State
representation.
EPA has further reduced the number of systems burdened by not requiring purchased water systems
to monitor. The national sample (described above) will exclude systems that purchase their water from
other systems, to avoid redundant sampling of sources. Further, exposure estimates for such
contaminants can be extrapolated to purchased systems from the monitoring data of the original source
systems. In the future, the UCMR list may include other types of contaminants that may necessitate
sampling of purchased systems. The universe of systems from which a representative sample would be
selected for such contaminants would then be revised to include systems using purchased water.
EPA proposes to exclude transient, non-community systems from the unregulated contaminant
monitoring. Including the 97,000 transient systems would be very costly. Furthermore, projecting
exposure from such systems is complex and inconclusive because of the transient nature of the
population served by them. The results from the small CWSs and NTNCWSs can be extrapolated to
these systems.
Since it is possible that certain contaminants are not likely to be found if their associated chemical
use does not occur in a particular State, the proposed UCMR includes a provision for waivers for large
systems on a State-wide, chemical-specific basis. However, for small system, waivers will not be
considered, since this would be contradictory to the data quality and consistency requirements of a
representative sample. Furthermore, since EPA will pay for this testing, it does not place a significant
burden on these small systems. The representative sample must provide adequate information on both
the presence and absence of contaminants for the systems sampled.
3(e) General Guidelines
The proposed UCMR complies with the guidelines published under the Paperwork Reduction Act
and its 1995 amendments. The UCMR does not alter the PWS or State record keeping requirements
under §§141.33 and 142.14, respectively.
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Draft- ICR for the UCMR - April TT1999
3(f) ,: ^Confidentiality ~, ..
-t -r,r ..-.-,. - - ~ , •-
1;( This Information Collection Request does "not raise confidentiality issues.
3(g) Sensitive Questions
This Information Collection Request does not ask sensitive questions.
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Draft—ICR for the UOfflL— April 7r 1999
4 THE RESPONDENTS AND THE INFORMATION REQUESTED
The following sections provide information on the respondents and the information that is requested
of them.
4(a) Respondents/SIC Codes
Under the proposed UCMR, respondents include owners and operators of PWSs (including non-
purchased CWSs and non-purchased NTNCWs) and the States. The Standard Industrial Classification
(SIC) code for investor-owned water systems is 4941. The SIC code for publicly-owned water systems
and State agencies is 9511. Ancillary systems (a system where providing water is ancillary to its primary
business, e.g., a mobile home park) cannot be categorized in a single SIC code.
4(b) Information Requested
The following sections provide detail on the data requested and associated respondent activities
necessary to satisfy UCMR requirements. These sections include a description of the proposed
regulation.
4(b)(i) Data Items, Including Reporting and Record Keeping
A discussion of data and information that are part of the reporting and record keeping requirements
for systems is found below in Section 4(b)(i)(a). The requirements for States are discussed below in
Section 4(b)(i)(b).
4(b)(i)(a) Public Water System Reporting and Record Keeping
The current §141.35 requires all regulated PWSs to report monitoring results for the contaminants
listed in §141.40 to the States. The proposed UCMR will require systems to report some additional data
elements to the States with the sampling results. The UCMR also requires that all systems submit their
data to the State in electronic format (unless the State waives this requirement).
The data elements to be reported are either system identifiers (e.g., system or facility identification)
that the system already reports to the State, or added sample analytical information that the laboratory
would provide. Most of the data elements already exist but will be required to be reported with the
UCMR results. The newly proposed data elements for the UCMR Program are listed below in Table 1.
The contaminants that will be monitored during this ICR period are listed in Table 2.
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Draft - 1CR for theUCMR.—April 7,1999
Table 1. Unregulated Contaminant Monitoring Reporting
Requirements
#
Data Element
Public Water System (PWS) Identification Number
2_
3
Sampling Station Type
Water Source Type
4
5_
6_
7_
L_
9_
1L
11
Sample Identification Number
Sample Collection Date
Contaminant
Analytical Results - Sign
Analytical Result - Value
Analytical Result - Unit of Measure
Analytical Method Number
Public Water System Facility Identification Number - Source
Intake/Well, Treatment Plant and Sampling Station
12
Public Water System Facility Type
13
Latitude of the Public Water System Facility for Source Intake/Well
and Treatment Plant
14
Longitude of the Public Water System Facility for Source
Intake/Well and Treatment Plant
Sample Type
Detection Level
Detection Level Unit of Measure
Analytical Precision
Analytical Accuracy
20
Presence/Absence
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Draft- ICR for the UCMJL—April?,. 1999
Table 2. UCMR Assessment Monitoring / List 1 (1999) Contaminants: analytical methods and
estimated costs per analysis1
Contaminant Name (Group)
CASRN
Assumed EPA
Analytical Method
Cost
Incremental Cost3
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.
$150est
$150(estfor508)
$160(estfor507)
$160 (est. for
515.1)
$20 est.
$20 est.
$0 (est. for 508)
$40 (est. for 507)
$20 (est. for 515.1)
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 "incremental11 analytical costs when UCMR monitoring coincides with ongoing compliance
monitoring. With methods that are not currently in use, no cost savings can be realized.
Section 141.33 requires systems to maintain records of chemical monitoring data for 10 years. No
changes are being made to those record keeping requirements.
SDWA §1445(a)(2)(E) requires notification of the results of the UCMR Program to be made
available to persons served by the system. The results of UCMR monitoring for CWSs will be reported
through the Consumer Confidence Reports (CCR), pursuant to SDWA §1414(c)(4)(B) and the final
regulation recently published in the Federal Register (63 FR 44512). Failure to monitor for unregulated
contaminants required through the UCMR will be reportable under the public notification rule.
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Draft - ICR forthe UCMR:— ApriTT, 1999
**"" 4(b)(i)(b) State Reporting and Record Keeping
**F ""Section 142.15 requires States to provide quarterly reports to the Agency'oiTeach system's " -;
"compliance with monitoring and reporting. Under the UCMR Program, the types of information to be ~
•provided would include the reporting of analytical results and information pertaining to the sample, and
_analytical method. Under the UCMR, these data must be reported electronically. There are no changes
to the types of records required, or the length of time that records must be retained, under §142.14.
States must retain records of monitoring conducted by each system for a period of 12 years.
Stakeholders, including systems and States, supported the idea of electronic reporting. Electronic
data transfer will allow EPA to conduct timely analysis of the data and will facilitate prompt follow up if
necessary.
4(b)(ti) Respondent Activities
Respondents include both PWSs and States. System activities and State activities are discussed
below in Sections 4(b)(ii)(a) and 4(b)(ii)(b), respectively.
4(b)(ii)(a) Public Water Systems
To comply with the requirements in this proposed regulation, systems must conduct the following
activities:
• read regulations and/or letter from State/Primacy Agency which outline requirements;
• monitoring or monitoring assistance (e.g., sample collection and shipping);
• reporting and record keeping; and
• public notification.
Each of these activities are discussed in more detail below.
Read 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. Large systems are assumed
to read both the regulation and information from the State, requiring on average V* 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.
Monitoring or Monitoring Assistance
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Draft—ICR for the UCMR-April 7,1999
Under §141.40 of today's proposal, systems would sample according to schedules specified by the
State, with input from EPA. Monitoring activities that are considered in the system cost and burden '"
estimates include: receipt of sampling kits from the laboratory, reading of sampling instructions, and '
collecting and shipping the sample. The Assessment Monitoring list consists of 11 contaminants: 2
VOCs, 8 SOCs, and 1 microorganism (see Table 2). Again, Screening Surveys and Pre-Screen Testing
will not be conducted until after the ICR period of 1999-2001, and thus are not considered here.
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. Monitoring activities include:
receipt of monitoring kit, reading laboratory instructions, and collection and shipping of samples. It is
assumed that where possible, all 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. Sections B.3 and B.4 of Appendix B explains the coincident sampling assumptions in
further detail. These same systems are assumed to collect samples forAeromonas 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.
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.
Reporting and Record Keeping
All systems will be responsible for submitting monitoring data in electronic format to the State
within 10 days of receipt of the results or the end of the required monitoring period (whichever is
sooner). Section 141.35, as amended by the proposed rule requires electronic reporting, but allows States
to waive the electronic reporting requirement if they so choose. The allowance in the case of small
systems for contract laboratories to facilitate the electronic reporting to the States is also new, and will
help reduce small system burden. The UCMR does not alter the retention periods for maintaining
records under §142.14.
•The National Contaminant Occurrence Database Information Requirements, in conjunction with the
development of the UCMR, have identified additional data elements for reporting with the analytical
results. These data elements are especially important since many of the UCMR list contaminants have
not been routinely tested for and sample test data quality indicators are needed to assure quality and to
appropriately interpret results. These added data elements can be routinely provided by the laboratories
serving the systems. Most of these data elements are already included on laboratory reports but have not
been reported or recorded by the States, or forwarded to EPA.
Other data elements required include items such as a sample location identifier (e.g., PWS
identification number, and latitude and longitude of the sampling station) and are listed above in Table 1.
Since these elements are already on record, there would only be a nominal one-time burden to compile
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Draft- ICR for the UCMR-AprilT; 1999
and report these with the UCMR results. The rationale for proposing the inclusion of these data elements
is that under current reporting, the results reported do not have detailed information concerning sample
precision and accuracy, or location, which would further strengthen the results to be used in making "
regulatory decisions. It is more efficient and effective to transmit these elements with the original
sample test data than to try to collect and collate them at a different point in time. Inclusion of these data
elements is consistent with the SDWA Amendments whjch have expanded the determinations and types
of analyses that need to be conducted to develop a rule.
Public Notification
CWSs are required to notify their users of the detection of any contaminants (including unregulated
contaminants) in their Consumer Confidence Report, pursuant to §141.153(d)(3)(iv). Monitoring and
reporting violations for all systems (CWSs and NTNCWSs) will also be reportable under the public
notification rule.
4(b)(ii)(b) States
In response to the regulation, each State will generally undertake the following activities:
• EPA coordination activities
• Data management and support
• Laboratory training
• Program implementation
In addition to each of these activities, which are discussed in more detail below, States may apply
for a state-wide waiver for a specific contaminant. The State must provide specific reasoning for each
analyte for which a waiver is requested and provide supporting documentation that the contaminants)
"has not been detected in the source waters or distribution systems, or never produced, used, stored,
disposed, released, or naturally present in the State for a period of at least fifteen years prior to the date
of [the waiver] application." The Agency, in consultation with the States, anticipates that States will not
apply for these waivers. Even where waivers might be appropriate, it would only be for an individual
compound that is included in a multi-analyte laboratory method, and thus would not affect the cost or
burden estimates. Operating a PWS program involves many other activities. Only those that are affected
by the UCMR are considered here.
State Coordination with EPA
State activities that involve coordination with EPA include: review of and response to EPA's
proposed State Monitoring Plan, regulation adoption and primacy application, and general ongoing
coordination.
If a State identifies systems on the EPA's original proposed State Monitoring Plan (State Plan) that
it determines are not appropriate for the representative sample (e.g., if systems are inactive, or have
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Draft — ICR for the UCMR — April T, 1999
switched to purchased water), the State can propose an alternative plan by selecting other system(s) from
EPA's alternate list to replace the ineligible system(s). The State response to the national sampling plan
should identify the State's most vulnerable period (if different than the rule-specified default of May -
July). It should also identify the 5-25 systems in the State that are most vulnerable to the microbiological
contaminants on List 3, in Table 12c, Appendix B.
In addition, EPA assumes that it will be necessary for States to maintain ongoing communications
with EPA regarding the requirements of the UCMR. An example of this would be instances when the
States need clarification and guidance regarding a specific requirement of the regulation.
Data Management and Support
Data management and support activities include: updating State databases to accommodate the
UCMR Program, data entry, general record keeping, and reporting to SDWIS.
The results of all unregulated contaminant monitoring conducted under the UCMR must be reported
electronically to SDWIS by each State. Although systems (or their contracted laboratories) are required
to report to States in electronic format, States may choose to enter data as an assistance to systems.
States also need staff to maintain records of all monitoring results and related data. EPA conservatively
estimates State data entry costs, by assuming that all systems that are reporting to them will require data
entry. (Note: The UCMR data will be reported to SDWIS for electronic routing to the National Drinking
Water Contaminant Occurrence Database (NCOD).)
According to EPA reports which analyzed the results of an ASDWA survey, over 90 percent of
States are able to report results from the current round of unregulated contaminant monitoring
electronically to SDWIS." Thus, approximately 10 percent of the States cannot report this information
electronically. These States will need to update their systems to accommodate electronic transfer of
unregulated contaminant data. (Though this could be as simple as entering the data into an MS Excel or
Lotus spreadsheet.) All States will need some adjustment to their data entry fields to accommodate the
new data elements required under this proposal.
Training for Laboratories
For this ICR, it is assumed that States will provide training to laboratory supervisors on the
information required to be reported, and how to report these data. In addition, it is assumed that States
will provide review and training on newly required laboratory quality control methods, including the
procedure for analyzing Aeromonas hydrophila samples.
Program Implementation
"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 JSSI,Inc^ March 1998.
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Draft- ICR for thtUCMR—Apriti;i99*
'"""', Program implementation activities for each State include: notification and guidance letter to
systems, data review, ongoing system support, and enforcement. ~ :
States will initially prepare a letter which describes the requirements of the regulation, the system's
monitoring schedule, and the system's requirements under the regulation. For simplicity, it is assumed
that the notification process will occur during 1 year. It is also assumed that States will receive
telephone calls from water systems asking for clarification and guidance pertaining to the requirements
of UCMR. States will review the unregulated contaminant monitoring results for systems, in part to '
determine whether a system has met its monitoring and reporting requirements. Finally, if systems do
not comply with the UCMR monitoring and reporting requirements, it is assumed that States will issue a
notice of violation.
State Staff Training and Overhead
All technical staff are assumed to participate in rule-specific training designed to assist them in
understanding the regulation, their roles and responsibilities, and to allow the State to better provide
technical assistance to the systems. In addition, general overhead costs, such as clerical and managerial
needs, are allocated proportionately to the UCMR staff requirements in the standard State Resource
Model.
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Draft—rCRfortheUCMR- April 7;i999
5 THE INFORMATION COLLECTED-AGENCY ACTIVITIES, COLLECTION
METHODOLOGY, AND INFORMATION MANAGEMENT
The following sections describe the Agency activities related to analyzing, maintaining, and
distributing the information collected.
5(a) Agency Activities
EPA Headquarters and Regional offices will be responsible for oversight of State public water
system programs, and processing and analysis of the UCMR data. EPA implementation activities are
categorized, as follows, into three major categories.
• Regulatory support activities
• Analytical cost for small system testing program, and
• National and regional oversight and data analysis.
Many of the EPA activities will take place after the period of analysis for this ICR. For instance,
implementation of Screening Surveys and Pre-Screen Testing for the small system testing program, as
well as preparations for the second round of the UCMR. EPA activities are listed below and discussed in
further detail in Section D of Appendix B.
5(a) ft) Regulatory Support Activities
5(a)(i)(a) Laboratory Capacity and QA/QC Activities
EPA anticipates incurring various contractor costs related to national laboratory capacity and
laboratory quality assurance and control, including the following activities:
• QC Audits of Contract Laboratories,
• Additional Contract Laboratory QC / Screening Survey Testing,
• Development of Laboratory Capability, and
• Ongoing Refinement of Laboratory Methods.
5 (a) (i) (b) Implementation of Small System Testing Program / Reporting and Data Review Protocol
EPA contractor activities which are assumed for logistical support of the small system testing
program include the following:
• Small System Plan Integration / Field Coordination, and
• Establish Reporting System and Protocol for Small System Program.
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Draft- ICR for the UCMR— April 7_
5(a)(i)(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 include the following:
• General External Laboratory QC Program, and
• Technical Support for Rule Amendments / Guidance Documents.
5 (a) (i) (d) Data Quality Review and Analysis
EPA contractor activities also include extensive data quality review and analysis.
S(a)(ii) Analytical Costs for Small System Testing Program
5(a) (ii) (a) Small System Analytical and Shipping Costs
The single largest cost to EPA for implementation of the UCMR is for small system sample
analyses. During the ICR period, EPA will pay for the analytical and shipping costs for small systems in
the national representative sample for the first year of Assessment Monitoring, which falls in 2001.
EPA also expects to conduct some quality control activities that will not be required of 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.).
5(a)(ii)(b) Contractor Site Visits to Index and Small Pre-Screen Testing System
EPA also expects to send contractors on site visits to 30 Index Systems to conduct Assessment
Monitoring, each year from 2001 to 2005. In addition, EPA will send contractors 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.
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5(a)(iii) National and Regional Oversight /Data Analysis
While it has not been determined if some of the UCMR 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.
5(b) Information Collection Methodology And Management
States will be required to transmit the UCMR data to EPA electronically, and submission will be
integrated in the existing quarterly SDWIS reporting cycle. For those few States that cannot already
provide an electronic file, this ICR estimates the time and resources necessary for such States to adopt
electronic reporting capabilities. Electronic reporting will account for significant collection efficiencies,
and will reduce the possibility of data input error.
EPA plans to conduct ongoing data analysis which will include checks for anomalies in the data that
may be related to data entry or laboratory errors. Data quality review and analysis will include:
continuous analysis of laboratory results, use of Index system results for comparison with small system
data, review of all program data, and NCOD review.
The UCMR data will be maintained and analyzed in SDWIS in conjunction with the NCOD.
Historically, reporting of analytical results to SDWIS has been limited to MCL exceedances or
exceedances of the lead or copper action level. UCMR marks the expansion of this reporting to include
more complete analytical results on contaminant occurrence, as well as related source information. The
data collected under UCMR will be used for regulation development, to analyze the significance of
occurrence and health effects, and to support the critical Agency function of program oversight. Public
access to the data is required under a separate EPA regulatory action. The public will be able to access
the results of UCMR monitoring through the Consumer Confidence Reports, as well as through the
NCOD. In addition, systems that fail to monitor for unregulated contaminants will be required to notify
the public.
5(c) Small Entity Flexibility
Note: The following SBREFA analysis summary is the same as that provided in the proposed rule
preamble. The RFA analysis is based on the entire UCMR implementation period, rather the
three-year ICR period.
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 §605(b) of the RFA, if EPA certifies that the rule will not have a significant economic
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Draft - ICR for the,UCMR—April T» 19»
impact on a substantial number of small entities, EPA is not required to prepare a regulatory flexibility
analysis. Pursuant to 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. ' 7
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 Implementation" 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^er 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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Draft — ICR far the UCMR—April 7,1999
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 3.
Table 3. 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 -All
Systems
GROUND WATER SYSTEMS
500 and under
501 to 3,300
3,301 to 10,000
Subtotal Ground
Water Systems
20
159
158
337
1
6
7
14
76
72
44
192
2
3
2
7
99
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
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
Tage29
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Draft- ICR foe thtUCMBL- April 7,1999
program support costs.) Table 4 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 4. 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 systems1
$3,392,183
$3,538,029
$3,533,202
$3,814,617
$752,537
$15,030,568
Costs to SmaU Systems (including Assessment Monitoring, Screening Survey, and Pre-Screen Testing):
additional labor for reading regulations 1 guidance, sampling activity, and reporting and record keeping
$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
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; SS1 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
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Draft - ICR fat the UCMR - April 7,1999
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 5a and 5b 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 9 and 10.
Table 5a. 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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Draft—ICR fattheliCMR—Aprff Jr 1999
Table 5b. 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)'
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
1 1.9
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
the UCMR program to accommodate the available funds. This adjustment may necessitate use of
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Doft.-OLfcttbtUCM8.- April?,
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. •"
?*
•j
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 6. 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.
Table 6. 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-lCRfor the UCMR—Aprii 7T1999-
Table 6. 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.
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 7.
Table 7. 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 record keeping
$13,405
$11,756
$11,756
$0
$0
$36,917
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Draft — ICR for the UCMR.— April 7,199*
Table 7. EPA Costs for Small Systems — Limited $4 million Program ~
Cost
2001
2002 .
~ 2003
2004
2005
Total
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 200] -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
8a and 8b, 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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Dca&—bCBJac tb^UCMEL—April 7,19»
Table 8a: 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" *
Non-Index
Index
GROUND WATER SYSTEMS
500 and
under
501 to
3,300
3,301 to
10,000
2.2
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.
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.
*age36
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Draft-iCB. for tfntUCMR-April 7,1999
Table 8b: 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-
200S)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 2001-2003.
2. "Sales Test" was used to evaluate the economic impact of an information collection on small privately-owned
entities. Costs are presented as a percentage of median annual sales in each size category.
S(d) Collection Schedule
As discussed in Section 3(d), EPA has considered various alternatives for the frequency of
monitoring and sample collection and is recommending the one that it considers to be sufficient to gather
necessary information on occurrence of unregulated contaminants, without significantly burdening small
systems. Assessment Monitoring activities are expected to occur in a 3-year period from 2001 through
2003. However, Assessment Monitoring for Index Systems will continue each year through 2005.
Screening Surveys will take place in 2002 and 2003. Pre-Screen Testing will take place in 2004. All
UCMR activities that occur after the year 2001 are not included in this ICR analysis. The activity
schedules for-all respondents can be found in Appendix B: systems — Table 10; States — Table 21; EPA
-Table 24.
P«ge37
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Daft—ICR finteUCMR—Aprit?,
6 ESTIMATING THE BURDEN AND COST OF THE COLLECTION ~~
-<-*. —*•*...- . -.- ~f - _,.._..
* This section describes the respondent burden and cost for activities under the UCMR, as well as for .'
the current unregulated monitoring program (e.g., "baseline" estimates). The burden and cost estimates "
for PWSs are shown in Section 6(a), burden and costs to States are shown in Section 6(b), and the
Agency's burden and cost estimates are shown in Section 6(c). ;
This ICR focuses only on cost of the UCMR data collection over the years 1999 through 2001. Cost
tables that are presented in this section have analogous tables in Appendix B which present costs for the
entire program implementation period (2001-2005). Figure 2, below, illustrates that the ICR average
annual costs include: 1 year of no costs (1999), 1 year of start-up costs for States and EPA (2000), and 1
year of average program implementation costs (2001).
Figure 2. Cost Calculations for the UCMR ICR
2001
Assessment
Monitoring
including Index
Systems (a)
2002
Assessment
Monitoring
including Index
Systems
2003
Assessment
Monitoring
including Index
Systems
2004
2005
Assessment
Monitoring for Index
Systems only
Assessment
Monitoring for Index
Systems only
Screening
Survey 1
Screening
Survey 2
Pre-Screen Testing
1999
No UCMR
Program Costs
2000
UCMR Program
Start-up Costs
2001
Cost of UCMR
Program Year 1
lAverage Annual Cost lor the UCMR ICR Yearsl
I - 1999-2001 (b) I
(a) Index Systems sample during each of the 5 UCMR implementation years (2001-2005). During
2005, it is expected that they will be the only systems conducting sampling in this first round of the
UCMR program.
(b) Since the schedule of the UCMR program implementation begins in the year 2001, the annual
average cost for the ICR years 1999-2001 will include: one year of no costs (1999), one year of
start-up costs for the States and EPA (2000), and one year of program implementation costs (2001).
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Draft—ICR for the UCMR-April T. 1999
There are two primary categories of costs associated with the UCMR: (1) labor costs, such as
program implementation, sample collection, record keeping, reporting, and data analysis; and (2) non-
labor costs, such as laboratory fees for analyses of samples, shipping charges, and other contractor costs.
The majority of costs are attributed to monitoring activities, primarily for purchased laboratory analytical
services. As noted, Assessment Monitoring targets a list of 11 contaminants (2 VOCs, 8 SOCs, and 1
microorganism). Screening Surveys and Pre-Screen Testing will not be conducted until after the
effective period of this ICR (see Figure 2, above).
EPA is committed to accurately characterizing the burden and costs of rules it promulgates. In the
development of various drinking water program rule ICRs, EPA has developed a consistent set of
assumptions to use in calculations. These have been developed and utilized in other drinking water
program evaluations. Pertinent to the UCMR ICR are the standard assumptions for labor rates, system
inventory numbers (the number of water systems in the various size categories by primary water source),
the number of entry points for each system, and analytical services. Some of these assumptions, and
their sources, were introduced in Section 3(c) "Consultations". These assumptions are described below
and in further detail in Section B of Appendix B to this ICR.
Laboratory method is the major determinant of analytical cost. While some of the contaminants are
analyzed individually, many of the EPA-approved analytical methods assess several contaminants
simultaneously. Moreover, some methods that are currently used for the regulated Phase II/V chemical
monitoring also accommodate some chemicals on UCMR List 1, the Assessment Monitoring list. It is
assumed that, whenever possible, large systems will only incur an incremental cost increase over their
current analytical costs for these chemicals. Shown in Appendix B, Tables 12a through 12c are the
common methods assumed for this cost analysis, the contaminants included in each method, the unit cost
for analysis, and the incremental cost (i.e., estimated laboratory fee for an analysis that coincides with
ongoing compliance monitoring). The estimates of method costs are based on current laboratory pricing
schedules.
The baseline in this ICR is considered to be the current Phase II/V unregulated monitoring program.
As noted in Section l(b), the past (and current) unregulated monitoring was integrated with the Phase I,
II/V compliance monitoring. Because of this program integration, past program cost estimates only
provide limited information that is specific to the unregulated contaminant monitoring component of
chemical monitoring. The burden and cost for the UCMR program are compared to baseline estimates
which were calculated for the purposes of this ICR. In some burden/cost categories, substantial
reductions will be realized, compared to the current unregulated contaminant monitoring program. For
example, 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 and large systems will incur increased costs attributed to sample analysis
and shipping. Specific assumptions for the baseline estimates are described below, in Section 6(f):
Reasons for Change in Burden. The common methods assumed for the baseline cost analysis, the
contaminants included in each method, the unit cost for analysis, and the incremental cost (i.e., estimated
costs for analysis that coincides with ongoing compliance monitoring) are shown in Appendix B, Table
30.
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Ekafc—K3t far the UCMR- April?,.
6(a) Estimating Burden and Cost to Public Water Systems
The estimates of system labor burden and labor cost are shown under Section 6(a)(i), and the
estimates of non-labor costs are shown under Section 6(a)(ii).
Table 9 displays labor and non-labor costs by year for the three-year ICR period. 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. The ICR period of 1999-2001 only coincides with one year of the program
implementation. 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.
Table 9. Yearly Cost to Systems for Implementation of the Assessment Monitoring
Component of the UCMR Program, by System Size and by Type of Cost
Cost Description
1999
2000
2001
Total
SMALL SYSTEMS
(serving 10,000 or fewer people)
Total System Labor Costs (includes cost for reading regulations, for monitoring and monitoring assistance, and
for reporting and record keeping)
$0
$0
$27,870
$27,870
System Costs for Laboratory Analysis and Shipping
Subtotal —Small System
Costs
$0
50
$0
$0
$0
$27,870
$0
$27,870
LARGE SYSTEMS
(serving greater than 10,000 people)
Total System Labor Costs (includes cost for reading regulations, for monitoring, and for reporting and record
keeping)
$0
$0
$259,060
$259,060
System Costs for Laboratory Analysis and Shipping
Subtotal —Large System
Costs
$0
$0
$0
$0
$7,747,520
58,006,580
$7,747,520
$8,006,580
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Draft—ICR for tbcUCMR—April!, 1999
Table 9. Yearly Cost to Systems for Implementation of the Assessment Monitoring
Component of the UCMR Program, by System Size and by Type of Cost
Cost Description
TOTAL - ALL SYSTEM
COSTS
1999
$0
2000
$0
2001
S8,034,450
Total
$8,034,450
The nationwide cost to systems for implementing the total UCMR program over the three-year ICR
period is approximately $8.03 million. Large systems will incur most of this cost, approximately $8.01
million. Annual cost per small system for UCMR implementation over the three-year ICR period is
approximately $32 per system, all attributed to labor. Approximately 287 small systems will participate
in the UCMR during the ICR period. Annual cost per large system is estimated to be $93 for labor plus
$2,793 for analytical (non-labor) costs. It is estimated that 925 large systems will participate in UCMR
activities during the ICR period. Details of per system labor burdens and costs for the UCMR program
(Assessment Monitoring only during the ICR period) are presented below in Tables 10. In addition, this
table presents 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 10. Assessment Monitoring Per System and Per Response Costs
Burden / Cost
Number Responses per
Respondent
Total over 1999-2001
Small Systems
2.6
Large Systems
2.9
Annual Average over 1999-2001
Small Systems
0.9
Large Systems
1.0
PER RESPONDENT:
Labor Cost
Non-Labor Cost
Burden (labor hours)
$97
$0
4.5
$280
$8,379
10.0
$32
$0
1.5
$93
$2,793
3.3
PER RESPONSE:
Labor Cost
Non-Labor Cost
Burden (labor hours)
$37
$0
1.7
$95
$2,841
3.4
$12
$0
0.6
$32
$947
1.1
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Dnft-!CRfcrtheUCMR-Apn?7,I999
6(a)(i) Estimates of Burden and Labor Costs to Public Water Systems
The UCMR will affect 3,574 PWSs, including non-purchased CWSs and non-purchased
NTNCWSs. During the ICR years of 1999-2001, it is estimated that approximately one-third of these
will be affected, since monitoring begins in 2001. Table 11 below presents the estimated numbers of
regulated systems, by system size and water source. The water system labor burden 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 3,300
or fewer people.12 See Sections A and B of Appendix B for detailed explanations of the inventory,
numbers of systems affected, and labor cost assumptions.
Table 11. 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
*io,ooo
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
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 one-third of the systems presented here will be impacted during the ICR years of
1999-2001.
12
The small system labor rate was derived from the Engineering News Record(ENR), 1993, and is
comparable to a 1992 survey of regional rural water association officials in Georgia, California,
and the Northeast. The large system labor rate was taken from ENR and Means Cost Data.
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Draft-ICR for the UCMR-April 7,199*
6(a)(i)(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. Large systems are assumed
to read both the regulation and information from the State, requiring on average one-half 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.
6(a)(i)(b) Monitoring Burden
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. It is assumed
that where possible, all 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.
Section B.3 of Appendix B explains the coincident sampling assumptions in further detail.
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 Systems 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.
6(a) (i) (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.
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Draft—KR£or the UCMR-Aprt 7,1999
EPA considers this burden assumption to be conservative, since much of the UCMR activities will
coincide with Phase II/V and other contaminant reporting and record keeping. In addition, for small
systems, electronic reporting to States will be provided by the EPA-designated laboratories.
6(a)(i)(d) Public Notification
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.
6(a)(ii) Estimates of 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 all laboratory and shipping costs for the systems in the national representative sample of small
systems. Tables 9 and 10 summarize non-labor, analytical and shipping costs. For the ICR period of
1999 to 2001, it is estimated that large systems will incur $2.7 million per year in analytical and shipping
costs. The estimated 925 large systems that will participate during the ICR period will incur an average
annual non-labor cost of $2,793 per system.
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 the Assessment Monitoring component of UCMR is shown in Tables 2. Estimated laboratory fees
for the Screening Survey and Pre-Screen Testing components are presented in Section B.4 of Appendix
B, since these components are implemented after the period of analysis for this ICR.
Note that instead of paying the full analytical cost for Assessment Monitoring, large systems may
pay only the smaller "incremental" analytical costs (listed in Table 2) 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 II/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.
In addition, large systems incur costs for shipment of the full sample bottles from the system to the
laboratory. Systems are assumed to ship a parcel of full sample bottles to laboratories for each entry
point during each monitoring period. Cost efficiencies for system shipping charges are also applied,
assuming lower costs where UCMR program sampling coincided with current monitoring schedules. For
detailed explanation of the analytical and shipping cost calculations, see Section B.4 of Appendix B.
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Draft - ICR for the UCMR.- April?, 1999
6(b) Estimating the Burden and Cost to States
EPA estimates that the total burden over 3 years (1999-2001) for 56 States/Primacy Agencies to
implement the UCMR will be 23,717 hours, with a total cost (labor plus non-labor) of $1.1 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 $6,480, with an annual labor burden per State of 141
hours (slightly less than 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 12 and 13 for a detailed summary
of estimated State burdens and costs.
Table 12. Yearly Total Cost to All States/Primacy Agencies for Implementation of UCMR, by
Type of Cost1
Cost Description
1999
2000
2001
Total
EPA Coordination Activities (review of State Monitoring Plan, identification ofPre-Screen Testing systems, most
vulnerable period, regulation adoption, primacy application, ongoing coordination)
$0
$279,360
$77,760
$357,120
Data Management and Support (updating data system, data entry, record keeping)
$0
$260,960
$21,600
$282,560
Laboratory Training (for reporting requirements and technical training)
SO
$45,760
$0
$45,760
Program Implementation (system schedule and rule introduction, review of data, system support, enforcement)
$0
$100,800
$122,400
$223,200
Overhead Costs (supervision, staff training, clerical)
TOTAL -All State
$0
so
$131,251
$818,131
$48,787
$270,547
$180,038
$1,088,678
1. 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.
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Daft—FCR fbrfte UCMR - ApnT 7,1999
Table 13. UCMR Per State and Per Response Costs
Burden / Cost
Number of Responses per Respondent2
Total for 1999-20011
8
Annual Average (over 3-year
ICR period)
2.7
PER RESPONDENT:
Labor Cost
Non-Labor Cost
Burden (labor hours)
$16,941
$2,500
423.5
$5,647
$833
141.2
PER RESPONSE:
Labor Cost
Non-Labor Cost
Burden (labor hours)
$2,116
$314
52.9
$705
$105
17.6
1. State costs are estimated over the period 1999-2001, with some start up costs in the year 2000,
and program implementation beginning in 2001.
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.
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, with 1,800
labor hours representing a "full-time equivalent" (FTE), the rates used for other drinking water program
cost analyses.
The inputs to the State Resource Model (described below) 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. The assumptions and estimates for the entire implementation period of
the UCMR for State burdens and costs are discussed in Section C.I through C.5 of Appendix B.
6(b)(i) Coordination with EPA
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
2. Ongoing coordination with EPA
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Draft - ICR for the UCMR - April 7,
36 hours (0.02 FTE) per State/Primacy Agent per year; includes meetings/discussion
regarding implementation and enforcement issues.
6(b)(ii) Data Management and Support
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
assistance to upgrade the database, for 10% of the States, and
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.
6(b)(iii) Laboratory Training
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.
6(b)(iv) Program Implementation
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
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- ICR for the UCMR —AprftT, 1999
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.
6(b)(v) 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),
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(c) Estimating Agency Burden and Cost
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
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.
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Draft - ICR for the UCMR1— April!, 19»
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.
The EPA cost for the UCMR program during the ICR period 1999-2001, 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 $5.0 million. The average annual cost
over the ICR period is estimated to be $1.7 million. EPA costs for UCMR implementation are shown
in Table 14; average annual labor and non-labor costs, as well as small system testing program costs
are shown in Table 15. Section D of Appendix B provides further discussion of EPA burden and cost
assumptions.
Table 14. Yearly Cost to EPA for Implementation of the UCMR, by Type of Cost
Cost
Description
1999
2000
2001
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
$0
$873,456
$970,184
$1,843,640
Small System Testing for Assessment Monitoring: Analytical and shipping costs for small system Assessment
Monitoring, costs for contractor site visits to Index Systems
$0
SO
$2,078,543
$2,078,543
National and Regional Oversight and Data Analysis: UCMR management oversight; review and evaluation of
data from Assessment Monitoring
TOTAL
$0
$0
$603,000
$1,476,456
$495,000
$3,543,727
$1,098,000
$5,020,183
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Draft - ICR for the UCMR—April?, 199»
Table 15. 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
Burden (labor hours)
Total Cost for
1999-2001
$1,098,000
$3,922,190
$5,020,190
$3,392,182
27,450
Annual Average Cost
over 3-year ICR Period1
$366,000
$1,307,397
$1,673,397
$1,130,727
9,150
1. Agency costs are estimated over the period 1999-2001, with implementation activities in
2001 and some start-up costs in the year 2000.
6(d) Estimating the Respondent Universe and Total Burden and Costs
The universe of respondents for the UCMR is clearly defined. There are 3,574 PWS respondents,
comprised of non-purchased CWSs and non-purchased NTNCWSs, as well as 56 State respondents. The
system universe can be further divided into the 800 systems serving 10,000 and fewer people, and the
2,774 serving more than 10,000 people. However, for the ICR period of 1999-2001, only approximately
one-third of the regulated PWSs are affected; 287 small systems and 925 large systems." The
respondent universe for the ICR is listed below in Table 16. Also summarized in Tables 16 are response
-frequencies and national burden estimates for the UCMR ICR period of 1999-2001.
Tables 17 summarizes national costs for the Assessment Monitoring component of the UCMR
during the period 1999-2001. The total labor and non-labor costs are presented for each category of
respondent. The total labor burden to small systems is 1,299 hours, with a cost of $27,870, and no non-
labor costs. The total labor burden to large systems is 9,252 hours, with a labor cost of $259,060, and
non-labor costs for analysis and shipping of $7.7 million. The total burden to States over the three-year ,
ICR period is 23,717 hours, with a labor cost of $0.9 million. Estimated non-labor costs to States are
minimal, with a total of $ 140,000 to fund updating of State data systems. The EPA total burden over the
same timeframe is 27,450 hours, with labor costs of $1.1 million, and non-labor costs of $3.9 million. -----
13
Small system respondents include more than one-third of 800, because 30 of the 800 are Index
Systems mat will participate during each year of the program. Thus, the assumed respondent
universe far smaR systems Is t^cxtofl^ as: in ofT^
Page 50
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Draft - ICR for the UCMR- April 1,1999
fable 16. Assessment Monitoring Response and Burden Summary1
Respondent Type
1999
2000
2001
TOTAL
Number of Respondents2
Small Systems3
Large Systems
States*
EPA
Total with EPA
Total without EPA
0
0
0
0
0
0
0
0
56
1
57
56
287
925
56
1
1,269
1,268
287
925
56
1
1,269
1,268
Frequency of Response5
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
4.0
1.0
3.9
4.0
2.6
2.9
4.0
1.0
2.9
2.9
2.6
2.9
8.0
2.0
3.1
3.1
Total Number of Responses
Small Systems
Large Systems
States
EPA
Total with EPA
Total without EPA
0
0
0
0
0
0
0
0
224
1
225
224
752
2,727
224
1
3,704
3,703
752
2,727
448
4
3,929
3,927
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
16,953
15,075
32,028
16,953
1,299
9,252
6,764
12,375
29,690
17,315
1,299
9,252
23,717
27,450
61,718
34,268
1. 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.
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Draft.— K3t for the UCMR— April Tt 199?
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 year of the UCMR implementation.
4. State 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 database. The frequency estimates refer to the frequency of response for only
those respondents that have any reporting requirements during a given year.
Table 17. Assessment Monitoring Cost Summary1
Type of Cost
1999
2000
2001
TOTAL
Small Systems
Labor Cost
Non-Labor Cost
Total Small System Cost
$0
SO
$0
$0
so
so
$27,870
$0
527,870
$27,870
$0
$27,870
Large Systems
Labor Cost
Non-Labor Cost
Total Large System Cost
so
so
$0
$0
$0
so
$259,060
$7,747,520
58,006,580
$259,060
$7,747,520
$8,006,580
States
Labor Cost
Non-Labor Cost
Total State Cost
so
$0
so
$678,130
$140,000
$818,130
$270,550
$0
5270,550
$948,680
$140,000
$1,088,680
EPA
Labor Cost
Non-Labor Cost
Total EPA Cost
$0
so
so
$603,000
$873,460
51,476,460
$495,000
$3,048,730
53,543,730
$1,098,000
$3,922,190
55,020,190
National Total
Total with EPA
Total without EPA
$0
$0
$2,294,590
$818,130
$11,848,730
$8305,000
$14,143,320
$9,123,130
1. Further detail regarding labor and non-labor costs are found in Sections B-D of Appendix B to this
document.
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Draft -ICR for the UCMR—April 7,199$
6(f) Reasons for Change in Burden . • • -: •
6(f)(i) Current ICR
This ICR, in effect, amends 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 18. 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 18. 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 n unregulated lOCs and SOCs
78,703
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., which
systems are involved, how many have ground or surface water sources), entry points/sampling stations,
monitoring frequencies, analytical costs, or labor burden assumptions.
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
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Draft - ICR fat the UCMK—ApATr1S99
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 of Appendix B for PWS
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. _
6(f)(u) "New" UCMR Baseline
Baseline costs for the existing Phase II/V unregulated contaminant monitoring are estimated for the
purposes of this ICR cost analysis. The same general framework and approach is used as for the UCMR
Assessment Monitoring program (see Section 4(b) of this document and Sections B - D of Appendix B).
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.14 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 19 presents the inventory of systems that were used in estimating system and State baseline costs.
Table 19. 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
Ground Water
Systems
15,360
12,306
2,404
30,070
1,254
204
1.458
Surface Water
Systems
640
1,820
1,006
3,466
927
389
1,316
Total Systems
16,000
14,126
3,410
33,536
2,181
593
2,774
14
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'heing cntuhxteA «cmrdin£ to federal
Page 54
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Draft—KR forthe UCMR —Aprft 7,199*
Table 19. Number of Systems Sampling Under Existing Phase n/V
Unregulated Program
Size Category
TOTAL
Ground Water
Systems
31,528
Surface Water
Systems
4,782
Total Systems
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.15 The 34 required, non-discretionary contaminants and the relevant pricing
assumptions used for these calculations are presented in Table 20 (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.
Table 20. Contaminants Required Under the Existing Phase n/V Unregulated Monitoring
Program
1
2
3
4
5
6
7
8
Contaminant Name
aldicarb
aldicarb sulfone
aldicarb sulfoxide
carbaryl
3-hydroxycarbofuran
methomyl
aldrin
dieldrin
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
Method
531.1
505, 508, 508.1
Cost
$230
$150
Incremental Cost
$30
$20
15
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-ICR for the UCMR-April?; 1999
Table 20. Contaminants Required Under the Existing Phase n/V JUnregulated Monitoring
Program ~ ' .- - — - _ - _a_, — j-n-i. >.a..-tg<^.-t««ataa^«.««*a^jf,-;.. ..Tur-.rsajli
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
propachlor
•
butachlor
metolachlor
metribuzin
dicamba
suifate
1,1,1 ,2-tetrachloroethane
1 , 1 ^,2-tetrachloroethane
1,1-dichloroethane
1 , 1 -dichloropropene
1 ,2,3-trichloropropane
1 ,3-dichloropropane
1 ,3-dichloropropene
2,2-dichloropropane
bromobenzene
bromodichloromethane
bromoform
bromomethane
chlorodibromomethane
chloroethane
chloroform
chloromethane (methyl
chloride)
dibromomethane
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
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
. 508, 507 ..
507
515.1,515.2
Various
502.2 (for 15-
34)
no charge.
$160
$150
$15
$173 '(for 15-34)
• •' -
i
no additional charge
$10
no additional charge
$15
$90 (for 15-34)
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Draft —ICR fertile UCMR—April 7,1999^ ~
Table 20. Contaminants Required Under the Existing Phase n/V Unregulated Monitoring
Program
32
33
34
m-dichlorobenzene
o-chlorotoluene
p-chlorotolucne
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 five years; 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 over a three-year period to small systems for the existing unregulated monitoring
program are estimated at $21.50 million. When compared to the estimated UCMR ICR-period costs to
small systems of $27,870, the nationwide savings to small systems is estimated to be $21.47 million.
Annual per system costs for those 287 small systems that participate in UCMR monitoring during the
ICR period will be reduced by approximately $324 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 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 $8.3 million cost for a three-year period of the existing unregulated
monitoring program. For the period of the UCMR ICR, nationwide large system costs decrease by
approximately $338,000 compared to the existing program. However, only one-third of the large systems
are incurring the UCMR costs during this period, thus per system costs are actually increased by an
estimated $1,215 per year. Large system cost increases are primarily due to the increase in laboratory
analytical costs.
Baseline cost to the States is estimated to be $3.8 million for a three-year cycle. Under the UCMR,
States are estimated to incur $1.1 million in costs over the ICR period. Thus, the total savings to States
under the UCMR is estimated to be $2.7 million. This savings is attributed to a decrease in required
labor. States will be collecting and reporting monitoring data from many 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 $0.9 million for an analogous three-year period.
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
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Draft- ICR for the UCMR—April T,199*
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.
6(g) Burden Statement
For the ICR period 1999-2001, the average burden for small systems is estimated to be 4.5 hours per
system, or an average annual burden of 1.5 hours per year, with an associated average annual cost of $32.
System burden includes time required to read the regulation or State letter, participate in sample
collection, report results, and maintain records. The average burden for large systems is estimated to be
10.0 hours, or approximately 3.3 hours per year, with an average annual labor cost of $93. Average non-
labor cost per large system is estimated to be $2,793 per year.
The average total burden hours (1999-2001) for a State or other primacy agent for the Public Water
System Supervision Program is estimated to be 424 hours over the implementation period, or 141 hours
per year (i.e., slightly less than 1/10 of an FTE). This burden includes time 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.
Table 21 presents per respondent and per response burdens and costs over the UCMR ICR period of
1999-2001. This table also presents average annual burdens and costs.
Table 21. Assessment Monitoring Burden and Cost Summary
Burden (hours) /
Cost (dollars)
Small
Systems
Large
Systems
States
EPA
National
Average with
EPA1
National
Average
without EPA
ASSESSMENT MONITORING ONLY — 3- 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
2.6
$97
$0
$97
$37
2.9
$280
$8,379
$8,659
$2,936
8.0
$16,941
$2,500
$19,441
$2,430
2.0
$1,098,000
$3,922,190
$5,020,190
$2,510,095
3.1
$1,840
$9,311
Ul.151
$3,600
3.1
$975
$6,224
$7,199
SV23
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Draft—ICR fartne UCMR—Aprft Tr 1999
Table 21. Assessment Monitoring Burden and Cost Summary
Burden (hours) /
Cost (dollars)
Total Burden Per
Respondent
Total Burden Per
Response
Small
Systems
4.5
1.7
Large
Systems
10.0
3.4
States
423.5
52.9
EPA
27,450.0
13,575.0
National
Average with
EPA1
48.7
15.7
National
Average
without EPA
27.0
8.7
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
0.9
$32
$0
$32
$12
1.5
0.6
1.0
$93
$2,793
$2,886
$979
3.3
1.1
2.7
$5,647
$833
$6,480
$810
141.2
17.6
0.7
$366,000
$1,307,397
$1,673,397
$836,698
9,150.0
4,575.0
1.0
S613
$3,104
$3,717
$1,200
16.2
5.2
1.0
$325
$2,075
$2,400
$774
9.0
2.9
1. 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.
This UCMR is necessary for several reasons. Its primary purpose is to support the development of
the CCL, the Administrator's determination of whether to regulate a contaminant, and regulation
development. The data collected under UCMR may also be used as a basis for determining exposure, for
establishing the baseline for health effects and economic analyses, for contaminant co-occurrence
analyses, and for treatment technology evaluation, including contaminant source management. Further,
the data may indicate the need to initiate research on health effects and treatment technology research, if
they suggest that certain contaminants have significant occurrence. Finally, as a secondary use, the data
may guide future source water protection efforts.
Burden means the total time, effort, or financial resources expended by persons to generate,
maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time
needed to review instructions; develop, acquire, install, and utilize technology and systems for the
purposes of collecting, validating, and verifying information, processing and maintaining information,
and disclosing and providing information; adjust the existing ways to comply with any previously
applicable instructions and requirements; train personnel to be able to respond to a collection of
information; search data sources; complete and review the collection of information; and transmit or
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Daft-
otherwise disclose the information. An agency may not conductor sponsor, and a person is not required
to respond to, a collection of information unless it displays a currently valid OMB control number. -The'
OMB control numbers for EPA's regulations are listed in 40 CFRJ'artPJmd 48 CFRChapter15C"'
- Send comments on the Agency's need for this information, the accuracy of the provided burden .
estimates, and any suggested methods for minimizing respondent burden, including through the use of
automated collection techniques to the Director, OP Regulatory Information Division, U.S.:_- - --.
Environmental Protection Agency (2137), 401 M Street, SW, Washington, D.C. 20460; and to the Office
of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, N.W.,
Washington, D.C. 20503, Attention: Desk of Officer for EPA. Include the EPA ICR number and the
OMB control number in any correspondence.
c:\mfd\ucmr\icr\ucmr icrlO v>pd
4/7/99
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Draft- ICR for the UCMR—April 7, 1999
APPENDIX A: Relevant Authorities in the SDWA 1996 Amendments
Section 1401. For purposes of this title:
(1) The term "primary drinking water regulation" means a regulation which-
(A) applies to public water systems;
(B) specifies contaminants which, in the judgement of the Administrator, may have any
adverse effect on the health of persons;
(C) specifies for each such contaminant either-
(i) a maximum contaminant level, if, in the judgment of the Administrator, it is
economically or technologically feasible to ascertain the level of such contaminant in water in public
water systems, or
(ii) if, in the judgment of the Administrator, it is not economically or technologically
feasible to ascertain the level of such contaminant sufficient to satisfy the requirements of section 1412;
and
(D) contains criteria and procedures to assure a supply of drinking water which dependably
complies with such maximum contaminant levels; including accepted methods for quality control and
testing procedures to insure compliance with such levels and to insure proper operation and maintenance
of the system, and requirements as to (i) the minimum quality of water which may be taken into the
system and (ii) siting for new facilities for public water systems. At any time after promulgation of a
regulation referred to in this paragraph, the Administrator may add equally effective quality control and
testing procedures by guidance published in the Federal Register. Such procedures shall be treated as an
alternative for public water systems to the quality control and testing procedures listed in the regulation.
Section 1412(b)(l) Identification of contaminants for listing.-
(A) General authority.- The Administrator shall, in accordance with the procedures
established by this subsection, publish a maximum contaminant level goal and promulgate a national
primary drinking water regulation for a contaminant (other than a contaminant referred to in paragraph
(2) for which a national primary drinking water regulation has been promulgated as of the date of
enactment of the Safe Drinking Water Act Amendments of 1996) if the Administrator determines that-
(i) the contaminant may have an adverse effect on the health of persons;
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Draft.- BCR fin theUCMR.- April?; 199^. v
(ii) the contaminant is known to occur or there is a substantial likelihood that the
contaminant will occur in public water systems with a frequency and at levels of public health concern;
and
(iii) in the sole judgment of the Administrator, regulation of such contaminant presents a
meaningful opportunity for health risk reduction for persons served by public water systems.
(B) Regulation of unregulated contaminants.-
(i) Listing of contaminants for consideration. -
(I) Not later than 18 months after the date of enactment of the Safe Drinking Water
Act Amendments of 1996 and every 5 years thereafter, the Administrator, after consultation with the
scientific community, including the Science Advisory Board, after notice and opportunity for public
comment, and after considering the occurrence data base established under section 1445(g), shall publish
a list of contaminants which, at the time of publication, are not subject to any proposed or promulgated
national primary drinking water regulation, which are known or anticipated to occur in public water
systems, and which may require regulation under this title.
(II) The unregulated contaminants considered under subclause (I) shall include, but
not be limited to, substances referred to in section 101(14) of the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980, and substances registered as pesticides under the
Federal Insecticide, Fungicide, and Rodenticide Act.
(Ill) The Administrator's decision whether or not to select an unregulated
contaminant for a list under this clause shall not be subject to judicial review.
(ii) Determination to regulate.-
(I) Not later than 5 years after the date of enactment of the Safe Drinking Water Act
Amendments of 1996, and every 5 years thereafter, the Administrator shall, after notice of the
preliminary determination and opportunity far public comment, for not fewer than 5 contaminants
included on the list published under clause (i), make determinations of whether or not to regulate such
contaminants.
(II) A determination to regulate a contaminant shall be based on findings that the
criteria of clauses (i), (ii), and (iii) of subparagraph (A) are satisfied. Such findings shall be based on the
best available public health information, including the occurrence data base established under section
1445(g).
(Ill) The Administrator may make a determination to regulate a contaminant that
does not appear on a list under clause (i) if the determination to regulate is made pursuant to subclause
(II).
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Draft—ICR fcr the UCMR —AprB 7r 1999-
(IV) A determination under this clause not to regulate a contaminant shall be
considered final agency action and subject to judicial review.
(iii) Review.- Each document setting forth the determination for a contaminant under
clause (it) shall be available for public comment at such time as the determination is published.
(C) Priorities.- In selecting unregulated contaminants for consideration under subparagraph
(B), the Administrator shall select contaminants that present the greatest public health concern. The
Administrator, in making such selection, shall take into consideration, among other factors of public
health concern, the effect of such contaminants upon subgroups that comprise a meaningful portion of
the general population (such as infants, children, pregnant women, the elderly, individuals with a history
of serious illness, or other subpopulations) that are identifiable as being at greater risk of adverse health
effects due to exposure to contaminants in drinking water than the general population.
(D) Urgent threats to public health.- The Administrator may promulgate an interim national
primary drinking water regulation for a contaminant without making a determination for the contaminant
under paragraph (4)(C), or completing the analysis under paragraph (3)(C), to address an urgent threat to
public health as determined by the Administrator after consultation with and written response to any
comments provided by the Secretary of Health and Human Services, acting through the director of the
Centers for Disease Control and Prevention or the director of the National Institutes of Health. A
determination for any contaminant in accordance with paragraph (4)(C) subject to an interim regulation
under this subparagraph shall be issued, and a completed analysis meeting the requirements of paragraph
(3)(C) shall be published, not later than 3 years after the date on which the regulation is promulgated and
the regulation shall be repromulgated, or revised if appropriate, not later than 5 years after that date.
(E) Regulation.- For each contaminant that the Administrator determines to regulate under
subparagraph (B), the Administrator shall publish maximum contaminant level goals and promulgate, by
rule, national primary drinking water regulations under this subsection. The Administrator shall propose
the maximum contaminant level goal and national primary drinking water regulation for a contaminant
not later than 24 months after the determination to regulate under subparagraph (B), and may publish
such proposed regulation concurrent with the determination to regulate. The Administrator shall publish
a maximum contaminant level goal and promulgate a national primary drinking water regulation within
18 months after the proposal thereof. The Administrator, by notice in the Federal Register, may extend
the deadline for such promulgation for up to 9 months.
(F) Health advisories and other actions.- The Administrator may publish health advisories
(which are not regulations) or take other appropriate actions for contaminants not subject to any national
primary drinking water regulation.
Section 1412(b)(4) Goals and standards.-
(A) Maximum contaminant level goals.- Each maximum contaminant level goal established
under this subsection shall be set at the level at which no known or anticipated adverse effects of health
of persons occur and which allows an adequate margin of safety.
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(B) Maximum contaminant levels.- Except as provided in paragraphs (5) and (6), each
national primary drinking water regulation for a contaminant for which a maximum contaminant level *
goal is established under this subsection shall specify a maximum contaminant level for such a
contaminant which is as close to the maximum contaminant level goal as is feasible.
(C) Determination.- At the time the Administrator proposes a national primary drinking
water regulation under this paragraph, the Administrator shall publish a determination as to whether the
benefits of the maximum contaminant level justify, or do not justify, the costs based on the analysis
conducted under paragraph (3)(C).
(D) Definition of feasible.- For the purposes of this subsection, the term "feasible1 means
feasible with the use of the best technology, treatment techniques, and other means which the
Administrator finds, after examination for efficacy under field conditions and not solely under laboratory
conditions, are available (taking cost into consideration). For the purpose of this paragraph, granular
activated carbon is feasible for the control of synthetic organic chemicals, and any technology, treatment
technique, or other means found to be the best available for the control of synthetic organic chemicals "
must be at least as effective in controlling synthetic organic chemicals as granular activated carbon.
(E) Feasible technologies.-
(i) In general.- Each national primary drinking water regulation which establishes a
maximum contaminant level shall list the technology, treatment techniques, and other means which the
Administrator finds to be feasible for purposes of meeting such maximum contaminant level, but
regulation under this subsection shall not require that any specified technology, treatment technique, or
other means be used for purposes of meeting such maximum contaminant level.
(5i) List of technologies for small systems.- The Administrator shall include in the list
any technology, treatment technique, or other means that is affordable, as determined by the
Administrator in consultation with the States, for small public water systems serving-
(I) a population of 10,000 or fewer but more than 3,300;
(II) a population of 3,300 or fewer but more than 500; and
(III) a population of 500 or fewer but more than 25;
and that achieves compliance with the maximum contaminant level or treatment technique, including
packaged or modular systems and point- of-entry or point-of-use treatment units. Point- of-entry and
point-of-use treatment units shall be owned, controlled and maintained by the public water system or by
a person under contract with the public water system to ensure proper operation and maintenance and --
compliance with the maximum contaminant level or treatment technique and equipped with mechanical
warnings to ensure that customers are automatically notified of operational problems. The Administrator
shall not include in the list any point-of-use treatment technology, treatment technique, or other means to
achieve compliance with a maximum contaminant level or treatment technique requirement for a
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microbial contaminant (or an indicator of a microbial contaminant). If the American National Standards
Institute has issued product standards applicable to a specific type of point-of-entry or point-of-use
treatment unit, individual units of that type shall not be accepted for compliance with a maximum
contaminant level or treatment technique requirement unless they are independently certified in
accordance with such standards. In listing any technology, treatment technique, or other means pursuant
to this clause, the Administrator shall consider the quality of the source water to be treated.
(iii) List of technologies that achieve compliance.- Except as provided in clause (v), not
later than 2 years after the date of enactment of this clause and after consultation with the States, the
Administrator shall issue a list of technologies that achieve compliance with the maximum contaminant
level or treatment technique for each category of public water systems described in subclauses (I), (II),
and (III) of clause (ii) for each national primary drinking water regulation promulgated prior to the date
of enactment of this paragraph.
(iv) Additional technologies.- The Administrator may, at any time after a national
primary drinking water regulation has been promulgated, supplement the list of technologies describing
additional or new or innovative treatment technologies that meet the requirements of this paragraph for
categories of small public water systems described in subclauses (I), (II), and (III) of clause (ii) that are
subject to the regulation.
(v) Technologies that meet surface water treatment rule.- Within one year after the date
of enactment of this clause, the Administrator shall list technologies that meet the Surface Water
Treatment Rule for each category of public water systems described in subclauses (I), (II), and (III) of
clause (ii).
Section 1445 (a)(l)(A) Every person who is subject to any requirement of this title or who is a grantee,
shall establish and maintain such records, make such reports, conduct such monitoring, and provide such
information as the Administrator may reasonably require by regulation to assist the Administrator in
establishing regulations under this title, in determining whether such person has acted or is acting in
compliance with this title, in administering any program of financial assistance under this title, in
evaluating the health risks of unregulated contaminants, or in advising the public of such risks. In
requiring a public water system to monitor under this subsection, the Administrator may take into
consideration the system size and the contaminants likely to be found in the system's drinking water.
(B) Every person who is subject to a national primary drinking water regulation under
section 1412 shall provide such information as the Administrator may reasonably require, after
consultation with the State in which such person is located if such State has primary enforcement
responsibility for public water systems, on a case-by-case basis, to determine whether such person has
acted or is acting in compliance with this title.
(C) Every person who is subject to a national primary drinking water regulation under
section 1412 shall provide such information as the Administrator may reasonably require to assist the
Administrator in establishing regulations under section 1412 of this title, after consultation with States
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and suppliers of water. The Administrator may not require under this subparagraph the installation of rrr
treatment equipment or process changes, the testing of treatment technology, or the analysis or r.^,.,.,r
processing of monitoring samples, except where the Administrator provides the funding for such . , ,',
activities. Before exercising this authority, the Administrator shall first seek to obtain the information by
voluntary submission. . ' *>. - , . ,,
The Administrator shall not later than 2 years after the date of enactment of this
subparagraph, after consultation with public health experts, representatives of the general public, and
officials of State and local governments, review the monitoring requirements for not fewer than 12
contaminants identified by the Administrator, and promulgate any necessary modifications.
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APPENDIX B: Burden and Cost Calculations for the UCMR
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