United States
Environmental Protection
Agency
Economic and Supporting Analyses for the Final
Aircraft Drinking Water Rule
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Office of Water (4606-M)
EPA816-R-09-007
October 2009
www.epa.gov/safewater
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
TABLE OF CONTENTS
Appendices v
Exhibits vi
List of Acronyms viii
Executive Summary x
1. Introduction 1-1
1.1 Need for the Rule 1-1
1.2 Regulatory History 1-4
1.2.1 1989 Total Coliform Rule 1-4
1.2.2 Surface Water Treatment Regulations 1-5
1.2.3 Public Notification Rule 1-5
1.3 Summary of the Final Aircraft Drinking Water Rule 1-5
1.4 Economic Rationale for the Regulation 1-8
1.5 Document Organization 1-8
1.6 Calculations and Citations 1-9
2. Consideration of Regulatory Alternatives 2-1
2.1 Introduction 2-1
2.2 Process for Development of Regulatory Alternatives 2-2
2.3 Regulatory Alternatives Considered 2-4
2.3.1 Alternative 1 - Baseline Alternative: Existing NPDWRs 2-5
2.3.2 Alternative 2 -Regulatory Requirements Similar to the AOCs 2-7
2.3.3 Alternative 3 - Requirements Similar to Water Supply Guidance 29 2-9
2.3.4 Alternative 4 -Hybrid Approach - ADWR 2-10
3. Baseline Analysis 3-1
3.1 Introduction 3-1
3.2 Industry Profile 3-1
3.1.1 Data Sources 3-2
3.1.2 Water System Characterization 3-2
3.1.3 Baseline Number of Aircraft and Population Served by Aircraft per
Year 3-4
3.3 Water Quality Baseline 3-6
3.3.1 2003 Data Collection Effort 3-6
3.3.2 2004 Data Collection Effort 3-7
3.3.3 Administrative Orders on Consent 3-8
3.3.4 Disinfectant and Treatment Characterization for the Baseline 3-10
3.3.5 Contaminant Occurrence for the Baseline 3-11
3.4 Uncertainties in the ADWR Baseline 3-13
4. Benefits Analysis 4-1
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
4.1 Introduction 4-1
4.2 Relative Risks - Qualitative Analysis 4-1
4.2.1 Rule Implementation Activities 4-2
4.2.2 Operator Certification Requirements 4-2
4.2.3 Routine Monitoring - Coliform Bacteria 4-2
4.2.4 Repeat Monitoring - Coliform Bacteria 4-3
4.2.5 Additional Routine Monitoring - Coliform Bacteria 4-3
4.2.6 Post Disinfection Monitoring - Coliform Bacteria 4-4
4.2.7 Routine Monitoring - Disinfectant Residual 4-5
4.2.8 Development and Implementation of an O&MPlan 4-5
4.2.9 Routine Disinfection and Flushing 4-5
4.2.10 Disinfection and Flushing as Corrective Action 4-6
4.2.11 Optional Supplemental Treatment 4-6
4.2.12 Sanitary Surveys/Self-Inspections 4-6
4.2.13 Public Notification 4-7
4.2.14 Overall Relative Risk 4-7
4.3 Assessment of Potential Quantitative Relative Risk Analyses 4-8
4.4 Non-quantified Benefits 4-9
5. Cost Analysis 5-1
5.1 Introduction 5-1
5.2 General Cost Assumptions and Methodology 5-2
5.2.1 Labor Rates 5-3
5.2.2 Laboratory Fees 5-4
5.3 Projecting and Discounting National Costs 5-5
5.4 Derivation of Costs for Air Carriers and the Agency 5-6
5.4.1 Rule Implementation and Annual Administration 5-7
5.4.1.1 Air Carriers 5-7
5.4.1.2 Agency 5-7
5.4.1.3 Annualized Costs for Rule Implementation/Annual
Administration 5-9
5.4.2 Sampling Plan 5-9
5.4.2.1 Air Carriers 5-9
5.4.2.2 Agency 5-10
5.4.2.3 Annualized Costs for Sampling Plan 5-10
5.4.3 O&MPlan 5-11
5.4.3.1 Air Carriers 5-11
5.4.3.2 Agency 5-11
5.4.3.3 Annualized Costs for O&MPlan 5-12
5.4.4 Coliform Monitoring 5-12
5.4.4.1 Air Carriers 5-12
5.4.4.2 Agency 5-15
5.4.4.3 Annualized Costs for Coliform Monitoring 5-15
5.4.5 Routine Disinfection and Flushing 5-16
5.4.5.1 Air Carrier 5-16
5.4.5.2 Agency 5-18
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
5.4.5.3 Annualized Costs for Routine Disinfect!on and Flushing 5-18
5.4.6 Disinfection and Flushing as Corrective Action 5-18
5.4.6.1 Air Carrier 5-18
5.4.6.2 Agency 5-21
5.4.6.3 Annualized Costs for Corrective Action Disinfection and
Flushing 5-21
5.4.7 Self-Inspection and Compliance Audit 5-21
5.4.7.1 Air Carrier 5-21
5.4.7.2 Agency 5-22
5.4.7.3 Annualized Costs for Compliance Audit 5-23
5.5 Estimated Costs to Air Carrier Passengers 5-23
5.6 Non-quantified Costs and Uncertainties in Cost Estimates 5-23
5.6.1 Non-quantified Costs 5-23
5.6.2 Uncertainties in Cost Estimates 5-25
5.7 Total Annualized Implementation and Incremental Costs for the Final ADWR 5-26
5.8 Comparison of Regulatory Alternatives 5-28
5.8.1 Comparison to the final ADWR 5-28
5.8.2 Comparison of the proposed ADWR and final ADWR 5-29
5.9 Comparison of Costs and Benefits 5-33
5.10 Other Economic Measures 5-33
6. Statutory and Administrative Requirements 6-2
6. 1 Introduction 6-2
6. 2 Executive Order 12866: Regulatory Planning and Review 6-3
6. 3 Regulatory Flexibility Act 6-3
6. 4 Small-Air Carrier Affordability 6-5
6. 5 Feasible Treatment Technologies for All Air Carriers 6-5
6. 6 Effect of Compliance with the ADWR on the Technical, Managerial, and
Financial Capacity of Air Carriers 6-5
6.6.1 Requirements of the Final ADWR 6-7
6.6.2 Air Carriers Subject to the Final ADWR 6-7
6.6.3 Impact of the ADWR on Air Carrier Capacity 6-8
6.6.4 Derivation of the ADWR Scores 6-10
6. 7 Paperwork Reduction Act 6-11
6. 8 Unfunded Mandates Reform Act 6-12
6. 9 Impacts on Sensitive Subpopulations 6-15
6.9.1 Protection of Children from Environmental Health Risks and Safety
Risks6-15
6. 10 Environmental Justice 6-16
6.10.1 Federalism 6-16
6.11 Actions Concerning Regulations That Significantly Affect Energy Supply,
Distribution, or Use 6-17
7. References 7-1
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
Appendices
Appendix A: ADWR Aircraft and Population Baseline
Appendix B: Aircraft Drinking Water Sampling Data
Appendix C: Cost Model
Appendix D: Screening Analysis
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
Exhibits
Exhibit ES. 1 Total Annualized Present Value Implementation Costs for the Final ADWR
(SMillions, 2008$) xiv
Exhibit ES.2 Comparison of Total Annualized Present Value Costs by Regulatory Alternative
(SMillions, 2008$) xiv
Exhibit ES.3 Total Annualized Incremental Cost: Existing NPDWRs and the ADWR (SMillions,
2008$) xv
Exhibit 1.1 Aircraft Drinking Water Monitoring Data 1-3
Exhibit 2.1 Aircraft Water System Supply and Transfer Chain 2-2
Exhibit 2.2a Existing FDA Requirements for Watering Points1 and Supplemental Treatment 2-12
Exhibit 2.2b Alternatives Considered for the ADWR - Aircraft Water System 2-13
Exhibit 3.1 ADWR Aircraft and Population Baseline 3-5
Exhibit 3.2 Summary of 2003 ATA Sampling Data 3-7
Exhibit 3.3 Summary of 2004 EPA Sampling Data 3-7
Exhibit 3.4 AOCs Occurrence Baseline Data - Disinfectant Residual Samples (Years 2005-
2008) 3-10
Exhibit 3.5 AOCs Occurrence Baseline Data - Routine Total Coliform Samples (Years 2005-
2008) 3-12
Exhibit 5.1 Loaded Labor Rates by Standard Occupational Classification (SOC) Code (2008$)
5-3
Exhibit 5.2 Laboratory Costs (2008$) 5-5
Exhibit 5.3 ADWR Aircraft and Population Baseline 5-7
Exhibit 5.4 Air Carrier Burden and Cost Estimates for Implementation 5-7
Exhibit 5.5a Agency Burden and Cost Estimates for Implementation 5-8
Exhibit 5.5b Agency Burden and Cost Estimates for Annual Administration 5-9
Exhibit 5.6 Air Carrier and Agency Cost Estimates for Implementation and Annual
Administration ($Millions, 2008$) 5-9
Exhibit 5.7 Air Carrier Burden and Cost Estimates for Sampling Plan 5-10
Exhibit 5.8 Agency Burden and Cost Estimates for Sampling Plan 5-10
Exhibit 5.9 Air Carrier and Agency Cost Estimates for Sampling Plan ($Millions, 2008$).... 5-11
Exhibit 5.10 Air Carrier Burden and Cost Estimates for O&MPlan 5-11
Exhibit 5.11 Agency Burden and Cost Estimates for O&MPlan 5-12
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
Exhibit 5.12 Air Carrier and Agency Cost Estimates for O&M Plan ($Millions, 2008$) 5-12
Exhibit 5.13 Air Carrier Burden and Cost Estimates for Coliform Monitoring 5-14
Exhibit 5.14 Agency Burden and Cost Estimates for Coliform Monitoring 5-15
Exhibit 5.15 Air Carrier and Agency Cost Estimates for Coliform Monitoring ($Millions,
2008$) 5-15
Exhibit 5.16 Air Carrier Burden and Cost Estimates for Routine Disinfection and Flushing.. 5-17
Exhibit 5.17 Air Carrier and Agency Cost Estimates for Routine Disinfection and Flushing
($Millions, 2008$) 5-18
Exhibit 5.18 Air Carrier Burden and Cost Estimates for Corrective Action Disinfection and
Flushing 5-20
Exhibit 5.19 Air Carrier and Agency Cost Estimates for Corrective Action Disinfection and
Flushing ($Millions, 2008$) 5-21
Exhibit 5.20 Air Carrier Burden and Cost Estimates for Compliance Audit and Self-Inspection5-
22
Exhibit 5.21 Agency Burden and Cost Estimates for Compliance Audit 5-22
Exhibit 5.22 Air Carrier and Agency Cost Estimates for Compliance Audit ($Millions, 2008$)
5-23
Exhibit 5.23 Summary of Monitoring and Disinfection and Flushing Events for All Alternatives
5-24
Exhibit 5.24 Total Annualized Present Value Implementation Costs for the Final ADWR
($Millions, 2008$) 5-26
Exhibit 5.25 Total Annualized Incremental Cost: Existing NPDWRs and the ADWR ($Millions,
2008$) 5-27
Exhibit 5.26 Total Annualized Incremental Cost: Requirements Similar to AOCs and the ADWR
($Millions, 2008$) 5-28
Exhibit 5.27 Comparison of Total Annualized Present Value Implementation Costs by
Regulatory Alternative ($Millions, 2008$) 5-29
Exhibit 5.28 Comparison of Proposed and Final ADWR Total Annualized Present Value Costs
($Millions, 2008$) 5-30
Exhibit 6.1 Estimated Impacts of the ADWR on Air Carriers' Technical, Managerial, and
Financial Capacity 6-9
Exhibit 6.2 Average Annual Burden Hours and Costs for the ADWR Information Collection
Request 6-12
Exhibit 6.3 Total Annualized Costs of Regulatory Alternatives ($Millions, 2008$) 6-14
Exhibit 6.4 Number and Percent of Air Carriers and Aircraft by Region 6-14
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
List of Acronyms
ADWR Aircraft Drinking Water Rule
AIDS Acquired Immune Deficiency Syndrome
ANSI American National Standards Institute
AOC Administrative Order on Consent
ATA Air Transport Association
BAT Best Available Technology
BEA Bureau of Economic Analysis
BMP Best Management Practice
BLS Bureau of Labor Statistics
BTS Bureau of Transportation Statistics
CDC U.S. Centers for Disease Control and Prevention
CFR Code of Federal Regulations
CRMP Comprehensive Representative Monitoring Plan
CWS Community Water System
D&B Dun & Bradstreet
DOT U.S. Department of Transportation
EPA U.S. Environmental Protection Agency
FAA U.S. Federal Aviation Administration
FDA U.S. Food and Drug Administration
GDP Gross Domestic Product
GS General Schedule
GWUDI Ground Water Under the Direct Influence of Surface Water
HACCP Hazard Analysis Critical Control Point
HPC Heterotrophic Plate Count
ICC Interstate Carrier Conveyance
ICR Information Collection Request
ICWS Interstate Carrier Water Supply
IESWTR Interim Enhanced Surface Water Treatment Rule
LT1ESWTR Long Term 1 Enhanced Surface Water Treatment Rule
LT2ESWTR Long Term 2 Enhanced Surface Water Treatment Rule
MCL Maximum Contaminant Level
MCLG Maximum Contaminant Level Goal
MRDL Maximum Residual Disinfectant Level
NAICS National American Industry Classification System
NCWS Noncommunity Water System
NPDWR National Primary Drinking Water Regulation
NSF National Science Foundation
NTNCWS Nontransient Noncommunity Water System
O&M Operation and Maintenance
OMB Office of Management and Budget
PN Public Notification
PWS Public Water System
QA/QC Quality Assurance/Quality Control
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
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QAPP Quality Assurance Project Plan
RFA Regulatory Flexibility Act
SAB Science Advisory Board
SBA Small Business Administration
SBREFA Small Business Regulatory Enforcement Fairness Act
SDWA Safe Drinking Water Act
SDWIS Safe Drinking Water Information System
SOC Standard Occupational Classification
SWTR Surface Water Treatment Rule
TCR Total Coliform Rule
TMF Technical, Managerial, and Financial
TNCWS Transient Noncommunity Water System
UMRA Unfunded Mandates Reform Act
USC United States Code
WHO World Health Organization
WSG Water Supply Guidance
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
Executive Summary
The United States Environmental Protection Agency (EPA) finalized National Primary
Drinking Water Regulations (NPDWRs) for aircraft in September 2009. The primary purpose of
the Aircraft Drinking Water Rule (ADWR) is to ensure that safe and reliable drinking water is
provided to aircraft passengers and crew, while enabling air carriers to comply with the Safe
Drinking Water Act (SDWA) and the NPDWRs in a feasible manner. These provisions, once
promulgated, are expected to enhance protection of public health against illnesses attributable to
microbiological contamination.
Under the SDWA, interstate carrier conveyances (ICCs) that regularly serve drinking
water to an average of at least 25 individuals daily, at least 60 days per year, are subject to the
NPDWRs. An ICC is a carrier which conveys passengers in interstate commerce; this includes
aircraft, trains, buses, and water vessels. As with other ICCs, aircraft obtain finished water from
many different sources and have significant physical and operational differences from traditional
public water systems (PWSs), making implementation of the NPDWRs difficult for this class of
PWSs. EPA may decide to tailor existing requirements to other classes of ICCs in the future.
The ADWR applies to all aircraft satisfying the definition of a transient non-community
water system (TNCWS) that fly within the United States. This includes approximately 7,300
aircraft serving routes in the United States, which together have approximately 744 million
passengers and crew that may partake of the water at some time over the course of a year.1
Aircraft in the following categories are not subject to the ADWR because they do not meet the
definition of a PWS, are not under EPA's jurisdiction, or are excluded from regulatory
requirements under SDWA section 14112:
. Aircraft that do not serve 25 or more people for at least 60 days per year
Aircraft without a qualifying lavatory3 or galley
Aircraft solely used for cargo purposes
. Aircraft that fly international routes serving only one U.S. city
. Aircraft owned and operated by the U.S. military if used solely for military
purposes, not conveying passengers in interstate commerce, and meet all of the
other exclusion criteria under SDWA section 1411
1 Since a portion of passengers and crew make multiple trips each year, the actual number of passengers and crew
exposed to aircraft drinking water is less than 744 million.
2 Section 1411 excludes from regulation any public water system that receives all of its water from another regulated
public water system, does not sell or treat the water, and is not a "carrier which conveys passengers in interstate
commerce."
3 A qualifying lavatory is defined as a private room with a flushing toilet and sink. Curtained-off toilet seats without
lavatory sinks (as seen in some small, short-range aircraft) have not been included.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
This Economic and Supporting Analyses document describes the estimated annual costs
to the air carrier industry and EPA for the final provisions. These costs include coliform
monitoring, routine water system disinfection and flushing, reporting and recordkeeping, self-
inspections/compliance audits, and planning processes. EPA has also characterized some of the
non-quantified costs and benefits associated with this final rule.
Summary of the Final ADWR Requirements
In developing the ADWR, EPA evaluated four options: the existing regulations, and three
alternatives. The analysis of several alternatives provided information that enabled the Agency
to consider the economic and health effects of different combinations of regulatory components
to gauge the relative efficiency and effectiveness of the regulatory alternatives. The alternatives
considered are described in Chapter 2 and include the following:
Alternative 1 - Existing Drinking Water Regulations
Alternative 2 - Regulatory Requirements Similar to the Administrative Orders on
Consent (AOCs)
Alternative 3 - Regulatory Requirements Similar to Water Supply Guidance (WSG) 29
Alternative 4 - Hybrid Approach - ADWR
EPA published the proposed ADWR on April 9, 2008 (71 FR 19320). The proposed rule
presented a hybrid approach that combined specific elements of the alternatives considered
during rule development so as to achieve a balance between added health protection and the
economic costs, while also providing administrative and operational flexibility for the air carriers
in how they implement the regulatory requirements. The final rule was revised based on public
comments received on the proposed rule. This final approach consists of regulatory components
that are tailored to meet the unique circumstances of aircraft PWSs. Key components of the final
rule include the following:
. Routine coliform monitoring using one of four monitoring frequency options
determined by the frequency of disinfection and flushing of the aircraft water
system.
Two routine coliform samples are collected at the frequency chosen. If one or
more of the routine samples are total coliform-positive but are Escherichia coli
(E. coli) -negative the aircraft can choose to either perform repeat sampling
(collecting three samples) or corrective action to include disinfection and flushing
and follow-up monitoring. Special consideration is given for aircraft with a single
water tank that is removable and is drained at least once-a-day, and there is one
tap on the aircraft. Those aircraft may collect a single 100 mL routine sample at
the frequency chosen.
Disinfection and flushing as corrective action must occur in the event of an E.
co//'-positive sample or if any repeat samples are total coliform-positive. If
disinfection and flushing as corrective action is required, public access to water
must be restricted and public notice must be posted until the water system is
disinfected and flushed and a complete set of follow-up samples are total
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
coliform-negative. The rule specifies a maximum amount of time that can elapse
before corrective action disinfection and flushing occurs if the water cannot be
physically shut off or the flow of water cannot be prevented through the taps to
prevent use for human consumption.
Disinfectant residual monitoring is not required by the final rule, but may be
recommended in guidance as a means of promoting voluntary measures such as
flushing and refilling with water containing a residual.
. Specific training requirements for all personnel involved with the aircraft water
system operations and maintenance provisions of the ADWR must be included in
the aircraft operations and maintenance (O&M) plan.
. Detailed disinfection and flushing procedures must be included in O&M plans.
Reporting requirements for disinfection and flushing and monitoring results, and
compliance status.
. Water system O&M plans would be incorporated into U.S. Federal Aviation
Administration (FAA)-accepted O&M plans for aircraft.
EPA may perform compliance audits as needed.
Air carriers perform self-inspections of aircraft water systems at least every 5
years and self-certify completion of the inspections.
Summary of National Benefits and Costs of the Final ADWR
National Benefits Summary
This section summarizes the risk (and benefit) tradeoffs between compliance with
existing NPDWRs and the regulatory alternatives considered during the rule development
process. Evaluations include a qualitative analysis of the relative risks of the regulatory
alternatives considered. Potential non-quantified benefits of compliance with the regulatory
options are also discussed.
Relative Risks—Qualitative Analysis
The goal of the ADWR is to tailor existing NPDWRs to the unique characteristics of
aircraft water systems. The requisite data on contaminant occurrence (both frequency and
concentration), health effects, and water consumption are not available to support a quantitative
analysis. Therefore, in consultation with the U.S. Food and Drug Administration (FDA) and
FAA, EPA has used best professional judgment to qualitatively estimate the relative risk of each
regulatory alternative compared to the baseline alternative of existing regulations for transient
non-community PWSs using finished surface water. This assessment was made with
contributions from a diverse group of drinking water and aircraft experts, ranging from scientists
and engineers to administrators and regulatory experts.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
The consensus opinions resulting from the qualitative assessment of risks for each
alternative relative to the Alternative 1 baseline of existing NPDWRs concluded that Alternative
2, which is similar to the AOCs, has an overall lower health risk due to the dominant factor of
periodic disinfection and flushing of the aircraft water system. The overall health risk posed by
Alternative 3, which is similar to Water Supply Guidance 29, is also most likely less than the
Alternative 1 baseline, though the magnitude of the difference is expected to be smaller
compared to Alternative 2 due to the flexibility in choosing between monitoring and an O&M
plan under Alternative 3. The regulatory components of the ADWR allow greater flexibility
than Alternatives 2 and 3 with regard to disinfection and flushing frequencies. Thus, some
aircraft may not perform disinfection and flushing as often as would be required under those
alternatives. However, this is compensated for by requiring more routine monitoring in those
situations. As a result, the expert consensus is that the overall health risk posed by the ADWR is
most likely less than the Alternative 1 baseline, and about the same as Alternatives 2 and 3.
Qualitative Benefits Analysis
Increased routine disinfection and flushing required under the final ADWR is expected to
inactivate pathogens and control biofilm which can harbor pathogens in the aircraft distribution
system that can contribute to endemic disease. Likewise, disinfection and flushing associated
with corrective action is also expected to inactivate or remove any pathogens that may have
entered the distribution system, resulting in increased avoidance of illness and death. By
reducing cases of illness contracted through exposure to aircraft PWSs, the final rule is also
expected to reduce the occurrence of illness passed through secondary spread. EPA expects the
addition of multiple barriers to pathogens through monitoring and disinfection and flushing to
reduce the likelihood of outbreaks associated with aircraft PWSs.
EPA determined that it was not feasible to perform a quantitative risk analysis for the
proposed rule during its development. EPA continued to assess the AOC data and evaluate
whether additional quantitative analyses were possible for the final rule. EPA has used the
AOCs' data to update estimates of the percentage of total coliform-positive and E. co//'-positive
samples for Alternatives 2 through 4 based on the inclusion of disinfection and flushing of the
water systems on a routine basis - a requirement not included in the existing NPDWRs
represented by Alternative 1. EPA determined the AOC data is still not sufficient to support a
quantitative analysis.
National Cost Summary
Exhibit ES. 1 presents the total annualized costs to air carriers and the Agency for
implementing the final ADWR at 3 and 7 percent discount rates. Incremental costs of the final
rule against the baseline (Alternative 1) are also presented. For the purposes of this analysis,
one-time and yearly costs were projected over a 25-year time period to coincide with and allow
comparison with other drinking water regulations. The present values of costs are calculated
using discount rates of 3 and 7 percent based on EPA policy and Office of Information and
Regulatory Affairs of the Office of Management and Budget (OMB) guidance.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
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Exhibit ES.1 Total Annualized Present Value Implementation Costs for the Final
ADWR ($Millions, 2008$)
Implementation
Annual Administration
Sampling Plan
O&M Plan
Coliform Monitoring
Routine Disinfection and
Flushing
Corrective Action
Disinfection and Flushing
Compliance Audit
Total
Air Carriers
Agency
Total
3%
$ 0.002
$
$ 0.002
$ 0.01
$ 4.89
$ 2.08
$ 0.05
$ 0.01
$ 7.04
$ 0.01
$ 0.24
$ 0.001
$ 0.0001
$ 0.04
$
$
$ 0.01
$ 0.30
$ 0.01
$ 0.24
$ 0.002
$ 0.01
$ 4.93
$ 2.08
$ 0.05
$ 0.02
$ 7.34
Air Carriers
Agency
Total
7%
$ 0.004
$
$ 0.002
$ 0.02
$ 4.82
$ 2.05
$ 0.05
$ 0.01
$ 6.95
$ 0.01
$ 0.23
$ 0.001
$ 0.0001
$ 0.04
$
$
$ 0.01
$ 0.30
$ 0.02
$ 0.23
$ 0.003
$ 0.02
$ 4.86
$ 2.05
$ 0.05
$ 0.02
$ 7.25
Exhibit ES.2 presents the total annualized present value cost for each of the regulatory
alternatives considered for this rulemaking.
Exhibit ES.2 Comparison of Total Annualized Present Value Costs by Regulatory
Alternative ($Millions, 2008$)
Implementation
Annual Administration
Monitoring Plan
O&M Plan
Coliform Monitoring
Disinfectant Residual
Monitoring
Routine Disinfection and
Flushing
Corrective Action Disinfection
and Flushing
Sanitary Survey/Compliance
Audit
Turbidity Monitoring
Total
AIM
Alt 2
Alt 3 | Alt 4 (Final Rule)
3%
0.01
0.24
0.002
25.37
3.17
0.70
29.49
0.01
0.24
0.002
1.67
0.67
4.52
0.05
7.16
0.01
0.24
0.001
0.01
2.23
2.97
0.05
12.92
18.43
0.01
0.24
0.002
0.01
4.93
2.08
0.05
0.02
7.34
Alt 1
Alt 2
Alt 3
Alt 4 (Final Rule)
7%
0.02
0.23
0.004
25.02
3.13
0.69
29.08
0.02
0.23
0.004
1.65
0.66
4.46
0.05
7.07
0.02
0.23
0.002
0.01
2.20
2.93
0.05
12.74
18.19
0.02
0.23
0.003
0.02
4.86
2.05
0.05
0.02
7.25
As discussed in Chapter 5, the qualitative analyses suggest that benefits are greater under
the final rule than under Alternative 1, the baseline requirements. Exhibit ES.3 presents the cost
savings associated with the final rule. Although it is not the least costly alternative considered
during rule development, the final rule will likely deliver a level of desired benefits at a cost that
is acceptable to the air carrier industry, which increases the likelihood that real benefits will
accrue. EPA is limited by the purpose, quality, and quantity of data available in developing
meaningful benefits analyses. Any comparison of risk between the alternatives considered for
the final rule requires robust data, which is not currently available (see Chapter 3 for a more
detailed description of available data).
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit ES.3 Total Annualized Incremental Cost: Existing NPDWRs and the ADWR
($Millions, 2008$)
Implementation
Annual Administration
Monitoring Plan
O&M Plan
Coliform Monitoring
Disinfectant Residual
Monitoring
Routine Disinfection and
Flushing
Corrective Action
Disinfection and Flushing
Sanitary
Survey/Compliance Audit
Turbidity Monitoring
Total
AIM
(Existing
NPDWRs)
Alt 4
(Final Rule)
Incremental
Cost
(Alt 4 - Alt 1 )
3%
0.01
0.24
0.002
-
25.37
3.17
-
-
0.7
-
$29.49
0.01
0.24
0.002
0.01
4.93
-
2.08
0.05
0.02
-
$7.34
0
0
0
0.01
(20.44)
(3.17)
2.08
0.05
(0.68)
-
$(22.15)
AIM
(Existing
NPDWRs)
Alt 4
(Final Rule)
Incremental
Cost
(Alt 4 - Alt 1)
7%
0.02
0.23
0.004
-
25.02
3.13
-
-
0.69
-
$29.08
0.02
0.23
0.003
0.02
4.86
-
2.05
0.05
0.02
-
$7.25
0
0
(0.001)
0.02
(20.16)
(3.13)
2.05
0.05
(0.67)
-
$(21.83)
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
1. Introduction
This document presents an analysis of the costs, benefits, and potential impacts of the
final ADWR.
This chapter includes the need for the rule (Section 1.1); a regulatory history of the
ADWR (Section 1.2); a summary of the final ADWR (Section 1.3); the economic rationale for
regulating aircraft PWSs (Section 1.4); an outline of the document (Section 1.5); and information
regarding supporting calculations and citations (Section 1.6).
1.1 Need for the Rule
The primary responsibility for regulating the quality of drinking water lies with EPA.
The SDWA establishes this responsibility and defines the mechanisms at the Agency's disposal
to protect public health. EPA sets standards by identifying which contaminants should be
regulated and by establishing the maximum levels of the contaminants allowed in drinking water.
Under the SDWA, primary enforcement authority for the NPDWRs may be delegated to states
and Indian Tribes; however, due to the interstate nature of aircraft travel, EPA will be
responsible for implementation, including enforcement, of the ADWR.
The primary purpose of the final ADWR is to ensure that safe and reliable drinking water
is provided to aircraft passengers and crew. This entails providing air carriers with a feasible and
effective way to comply with the SDWA and the NPDWRs. Under the SDWA, ICCs, including
aircraft, that regularly serve drinking water to an average of at least 25 individuals daily, at least
60 days per year, are subject to the NPDWRs. An ICC is a carrier that conveys passengers in
interstate commerce. The classes of ICCs include aircraft, trains, buses, and water vessels.
Aircraft obtain potable water from many different sources and have significant physical
and operational differences from traditional, stationary PWSs, making implementation of the
NPDWRs difficult for this class of PWSs. A significant characteristic is that they board water
frequently from a variety of locations, and must use water transfer equipment and temporary
connections. This rule tailors implementation of existing health-based drinking water standards
to the unique characteristics of aircraft PWSs. EPA may address regulations for other ICCs
subsequent to development of the ADWR.
Public Health Concerns Related to Aircraft Drinking Water
EPA assumes that only finished water obtained from another PWS is boarded on aircraft.
This assumption is based on an FDA requirement that only potable water may be provided for
drinking and culinary purposes on ICCs (21 Code of Federal Regulations (CFR) 1240.80).
However, the opportunity exists for microbial contamination to be introduced during the act of
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
transferring the water from the supplier truck or cart to the aircraft water system, or to occur
through a cross connection within the water system itself.
In 1990, EPA's Science Advisory Board (SAB), an independent panel of experts
established by Congressional mandate, cited drinking water contamination as one of the most
important environmental risks. The SAB indicated that disease-causing microbial contaminants
(i.e., bacteria, protozoa, and viruses) pose a particularly high health risk due to the large
populations that are directly exposed to them (SAB and USEPA, 1990). Information on
waterborne disease outbreaks from the U.S. Centers for Disease Control and Prevention (CDC)
underscores this concern. Data collected by CDC indicate that between 1971 and 2002, 757
waterborne disease outbreaks, caused by various types of contamination, were reported (Craun
and Calderon, 1996; Levy et al., 1998; Barwick et al., 2000; Lee et al., 2002; and Blackburn et
al., 2004). Water contamination issues apply to all drinking water systems, and are not unique to
aircraft water systems.
To date, EPA has reviewed four data sources to gain a better understanding of the
drinking water quality on domestic aircraft as represented by total coliform, Escherichia coll (E.
coli)/feca\ coliform, and chlorine residual. These data sources included: 1) a voluntary
monitoring study completed by Air Transport Association (ATA) in Fall 2003; 2) an EPA
compliance activity completed in 2004; 3) an EPA compliance activity under the AOCs covering
monitoring results from 2005-2008; 4) and the Canadian Inspection Program monitoring results
completed in 2006. In comparing the routine sampling data, the highest total coliform-positive
rate of detection was 15 percent, while the AOCs rate observed was 3.6 percent. The data are
discussed further in Chapter 3 and details of the AOCs are provided in Chapter 2. EPA believes
that the mandatory quarterly disinfection and flushing requirements under the AOCs may be a
contributing factor to the reduced total coliform rates observed in the AOCs' data. The data
results are reflected in Exhibit 1.1.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit 1.1 Aircraft Drinking Water Monitoring Data
Samples
Total Coliform-
Positive
E. co///Fecal
Coliform-
Positive
CI2 Residual
Non-Detects
EPA AOCs
(2005 - 2008 - Compliance
Activity) 1
Routine samples only; galley &
lavatory samples
• 3,512 (-58%) aircraft tested
• 16 (-35%) air carriers
tested
3.6% (463 out of 12,794 samples) i
• 1.0% (47 out of 5,695
galley samples)
. 4.4% (41 3 out of 7, 027
lavatory samples)
3.9% (18 out of 463 total coliform-
positive samples)
• 12.8% (6 out of 47 galley
samples)
• 2. 9% (12 out of 41 3
lavatory samples)
14.4% (1,51 7 out of 10,557)
ATA
(Fall 2003 -
Voluntary)
Galley samples
(327 aircraft
tested)
2.7%
0.0%
41%
EPA Study
(2004 -
Compliance
Activity)
Galley & lavatory
samples (327
aircraft tested)
15%
0.6%
(2 out of 49 total
coliform-positive
samples)
(1.3% in summer
samples)
21%
Canadian Study
(2006 -
Inspection
Program)
Galley & lavatory
samples (431
aircraft tested)
15.1%
7.7%
(5 out of 65 total
coliform-positive
samples)
NA
1. Data collected under EPA-approved quality assurance project plans (QAPPs) and comprehensive representative
monitoring plans (CRMPs).
2. One total coliform-positive sample out of seven was a composite sample (of lavatory and galley sources) and two
total coliform-positive samples out of 65 did not have a sample location.
The effects of waterborne disease are usually acute, resulting from a single or small
number of exposures. Most waterborne pathogens cause gastrointestinal illness with diarrhea,
abdominal discomfort, nausea, vomiting, or other symptoms. Most such cases involve a sudden
onset and generally are of short duration in healthy people. Some pathogens (e.g., Giardia and
Cryptosporidium\ however, may cause extended illness, lasting weeks or longer in otherwise
healthy individuals. The infection can prove fatal for members of sensitive populations, such as
the immuno-compromised. Other waterborne pathogens cause, or at least are associated with,
more serious disorders such as hepatitis, particularly hepatitis A (Moore et al., 1993), peptic
ulcers and gastric cancer (Helicobacterpylori) (Park et al., 2001, Sepulveda and Graham, 2002),
myocarditis (group B coxsackievirus) (Kim et al., 2001), meningitis (group B coxsackievirus and
echoviruses) (Lee and Kim, 2002, Amvrosieva et al., 2001), and other diseases.
The final ADWR seeks to protect against contamination that has an acute rather than
cumulative effect because of the short term exposure of consumers to the water and the transient
nature of passengers and the crew on board a particular aircraft. In particular, the final ADWR
seeks to protect against disease-causing microbial contaminants. Although data do not exist on
outbreaks of illness caused by drinking water on aircraft, EPA understands that the population on
board disperses after a flight and that even if passengers develop gastrointestinal symptoms
within hours of deplaning, they are unlikely to contact the air carrier or any government agency
to report the illness.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
1.2 Regulatory History
The SDWA, including the amendments of 1986 and 1996, requires EPA to promulgate
the NPDWRs to protect human health from waterborne contamination. As TNCWSs, aircraft are
subject to certain NPDWRs specific to this category of systems. The Agency published WSG 29
in October 1986 to assist air carriers in complying with these standards (USEPA, 1986). Under
WSG 29, an ICC water system could use an approved operation and maintenance program in lieu
of monitoring requirements. In 2004, EPA found all aircraft water systems to be out of
compliance with the NPDWRs. Since then, the Agency has determined that a new rule
specifically adapted to aircraft water systems would provide a regulatory environment more
conducive to compliance and enforcement. EPA is no longer approving operation and
maintenance programs in lieu of monitoring while the ICC program is being revised. EPA has
signed Administrative Orders on Consent with many air carriers that specify what monitoring
and other activities are required until a new rule is in effect.
Many drinking water rules for systems using surface water or ground water under the
direct influence of surface water (GWUDI) relate to treatment of source water, but because
aircraft must use finished water the responsibility for treating the water is borne by the water
supplier from which aircraft obtain their water. This situation is comparable to the handling of
traditional, stationary PWSs as consecutive systems. The ADWR adapts to aircraft water
systems the applicable requirements from the Total Coliform Rule (TCR), the Surface Water
Treatment Rule (SWTR), and the Public Notification Rule, the relevant sections of which are
summarized in the subsections below.
Monitoring for nitrates/nitrites (under the Phase II Inorganic Contaminant Rule) would
normally apply to TNCWSs. However, aircraft board finished water that the supplier is required
to have monitored for nitrate/nitrites, and to have applied treatment if necessary to meet the
maximum contaminant levels (MCLs) for the contaminants. Therefore, the nitrate rule is not
applicable to aircraft under the final ADWR and is not included in the discussion below.
1.2.1 1989 Total Coliform Rule
TCR (54 FR 27544, June 1989) applies to all PWSs. Because monitoring PWSs for
every possible pathogenic organism is not feasible, coliform organisms are used as indicators of
possible source water and distribution system contamination. Coliforms are easily detected in
water and are used to indicate a water system's source and distribution system vulnerability to
pathogens. In the TCR, EPA sets a Maximum Contaminant Level Goal (MCLG) of zero for total
coliforms. EPA also sets a monthly MCL for total coliforms and requires testing of total
coliform-positive cultures for the presence of E. coli or fecal coliforms. E. coli and fecal
coliforms indicate more immediate health risks from sewage or fecal contamination and are used
as a trigger of an acute MCL violation. Under the TCR, a TNCWS using finished surface water
and serving fewer than 1,000 persons daily would typically be required to collect one routine
total coliform sample per month. Additional samples would be required in the event a routine
sample is total coliform-positive.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
1.2.2 Surface Water Treatment Regulations
EPA has promulgated a suite of regulations to address microbial contamination of surface
water. These regulations include the SWTR, the Interim Enhanced Surface Water Treatment
Rule (IESWTR), the Filter Backwash Recycling Rule, and the Long Term 1 and Long Term 2
Enhanced Surface Water Treatment Rules (LT IESWTR and LT2ESWTR). These rules apply
monitoring and treatment technique requirements, such as turbidity limits, among others, to
protect the public from microbial pathogens in drinking water such as bacteria, viruses, Giardia
lamblia, and Cryptosporidium. The monitoring and treatment technique requirements must be
met prior to water entering the distribution system. Aircraft are not required to provide source
water treatment or to perform monitoring of source water because these are responsibilities of the
PWS from which the aircraft obtains finished water for boarding. However, the SWTR included
provisions for maintaining a detectable distribution system disinfectant residual and for
monitoring distribution system disinfectant residuals at the same time and location as used for
total coliform monitoring. A TNCWS using surface water serving fewer than 1,000 persons
daily would typically be required to take one disinfectant residual sample at the same time and
location as each coliform sample. The IESWTR requires primacy states to conduct sanitary
surveys for all surface water and GWUDI systems regardless of size at a frequency of every 3
years for community water systems and every 5 years for noncommunity water systems.
1.2.3 Public Notification Rule
Public water systems must give notice to persons served for all violations of NPDWRs
and for other situations posing a risk to public health from drinking water. The term "NPDWR
Violations" is used in the public notification regulations to include violations of the MCL,
Maximum Residual Disinfectant Level (MRDL), treatment technique, monitoring, and testing
procedure requirements. Public notice requirements are divided into three tiers to take into
account the seriousness of the violation or situation and of any potential adverse health effects
that may be involved. Due to the transient nature of the public served by TNCWSs, public
notice is typically provided through posting of the notice at locations where the public may
access drinking water from the water system.
1.3 Summary of the Final Aircraft Drinking Water Rule
The ADWR applies to all aircraft under EPA's jurisdiction. Aircraft water systems are
TNCWSs that board finished water from PWSs using primarily surface water supplies or
GWUDI. Although some aircraft board water from PWSs supplied by ground water sources,
these aircraft are also very likely to use surface water supplies at some of their destinations and
are therefore classified as mixed systems. Mixed systems are subject to the same requirements
as surface water and GWUDI systems.
As described in detail in Chapter 2, the baseline of existing regulations for TNCWSs
using finished surface water (i.e., Alternative 1), requirements similar to two previously
implemented approaches to regulating aircraft PWSs, and the final ADWR are presented in this
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
document. These alternatives were considered for development of the ADWR in compliance
with guidelines set out in both EPA's Guidelines for Preparing Economic Analyses (USEPA,
2000) and Office of Management and Budget Circular A-4 (OMB, 2003). Analysis of several
alternatives allows the Agency to consider different combinations of regulatory components in
order to select the most efficient and cost-effective approach to regulation. The alternatives
considered as part of the analysis include:
Alternative 1 - Existing Drinking Water Regulations
Alternative 2 - Regulatory Requirements Similar to the AOCs
Alternative 3 - Regulatory Requirements Similar to Water Supply Guidance 29
Alternative 4 - Hybrid Approach - ADWR
The following discussion briefly summarizes the final rule, while Chapter 2 provides a
more complete description of each of the alternatives considered for the ADWR. Although
aircraft PWSs are not technically considered consecutive water systems4, for the purposes of
each alternative, they are assumed to be boarding finished water obtained from another PWS.
Because aircraft board only finished water, for the purposes of the analyses in this document,
aircraft are treated as equivalent to consecutive water systems. Finished water is defined in 40
CFR 141.2 as water that is introduced into the distribution system of a PWS and is intended for
distribution and consumption without further treatment, except as treatment necessary to
maintain water quality in the distribution system. Prior to boarding the water, compliance with
FDA and FAA requirements5 is expected to ensure that water from the supplier meets NPDWR
standards and that the equipment used in transferring this water to the aircraft is maintained and
operated so as to preserve that level of water quality.
Final ADWR
The final rule is a hybrid approach that combines what EPA believes are the most
practical elements of the other alternatives with flexibility for the air carriers in how they
implement the regulatory requirements. This final approach allows compliance with regulatory
components that are most tailored to the unique circumstances of aircraft PWSs. Development
of this alternative was undertaken based on the input received from stakeholders during the
Agency's outreach efforts, as well as public comments on the proposed rule. The final rule
includes the following regulatory components:
• Aircraft must comply with one of the following combinations of water quality
monitoring, and disinfection and flushing of the aircraft water system in
accordance with the manufacturer's recommendations:
4 A consecutive system is defined as a public water system that receives some or all of its finished water from one
or more wholesale systems. Delivery may be through a direct connection or through the distribution system of one
or more consecutive systems.
5 Compliance with FAA and FDA regulations is required of both aircraft PWSs and water suppliers. Any FAA and
FDA requirements are in addition to those imposed by the ADWR.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
- Annual total coliform monitoring (once every twelfth month) in
combination with routine disinfection and flushing quarterly (at least once
every third month; four times per year).
Semi-annual total coliform monitoring (at least once every sixth month;
two times per year) in combination with routine disinfection and flushing
three times per year (once every fourth month).
- Quarterly total coliform monitoring (once every third month; four times
per year) in combination with semi-annual (once every sixth month; two
times per year) routine disinfection and flushing.
- Monthly total coliform monitoring (once every month; 12 times per year)
in combination with annual or less frequent routine disinfection and
flushing (once every twelfth month or less; one time per year or less).
If not specified by the manufacturer, aircraft select any of the four disinfection and
flushing frequencies.
Analysis of all total coliform-positive culture media for the presence of E. coli.
An option of repeat monitoring or disinfection and flushing with follow-up total
coliform sampling as corrective action after one or more total coliform-positive
routine samples that are E. co//'-negative. The time frame for the corrective action
is specified unless public access to the water is prevented through shut off of the
water system or preventing the flow of water through the taps.
Disinfection and flushing with follow-up total coliform sampling as a corrective
action after one or more total coliform-positive repeat samples or a single E. coli-
positive sample.
Aircraft water system operations and maintenance plans.
Compliance audits at an interval determined by EPA.
Self-inspections conducted by the air carrier.
Public notification for an E .co//'-positive sample, for more than one total coliform-
positive sample if disinfection and flushing as corrective action does not occur
within the prescribed time frame, for failure to collect required routine or repeat
samples, or if water is boarded that is of unknown quality or does not meet the
NPDWRs.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
1.4 Economic Rationale for the Regulation
This section discusses the statutory authority of EPA to regulate aircraft drinking water
systems and the economic rationale for choosing a regulatory approach.
EPA derives its statutory authority to regulate contaminants in drinking water through the
SDWA. Section 1412(b)(l)(A) of the SDWA requires EPA to establish NPDWRs for
contaminants that may have an adverse public health effect; that are known to occur or that
present a substantial likelihood of occurring once in PWSs at a frequency and level of public
concern; and that present a meaningful opportunity for health risk reduction for persons served
by PWSs. As noted above, ICCs are considered PWSs under the SDWA.
Executive Order 12866, Regulatory Planning and Review, directs the Agency to provide
an economic rationale for choosing a regulatory approach. OMB circular A-4 notes that the
rationale for regulation is to correct market failure or other social purposes: "The major types of
market failure include: externality, market power, and inadequate or asymmetric information.
Correcting market failures is a reason for regulation, but it is not the only reason. Other possible
justifications include improving the functioning of government, removing distributional
unfairness, or promoting privacy and personal freedom."
The economic rationale for establishing a regulation specifically designed for aircraft
PWSs is to correct inadequate or asymmetric information. Limited monitoring has led to a lack
of information regarding potential risks associated with consuming water onboard aircraft. As a
result, aircraft passengers do not receive sufficient information on drinking water quality to make
informed decisions about drinking water on aircraft. Federal intervention can be used to close
this gap6.
1.5 Document Organization
The remainder of the document is organized into the following chapters:
• Chapter 2 reviews alternative approaches that EPA considered during rule
development and presents the rationale for the selection of the final rule option.
Chapter 3 characterizes baseline conditions that existed before systems made
changes to meet the AOCs' requirements including aircraft inventory, watering
points, average number of passengers carried, and water boarding practices. The
chapter also includes a summary of the microbiological conditions documented by
air carrier data submitted for compliance with the AOCs. These conditions reflect
aircraft water quality following implementation of routine water system
6 Federal intervention is not the only tool available to address information gaps. Other tools include state or local
intervention and voluntary incentives. However, due to the number of aircraft and carriers covered under this rule,
as well as the interstate nature of the business, federal intervention is deemed the most appropriate tool to use to
address the issue.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
disinfection and flushing practices and corrective actions prompted by coliform
detection in water samples.
Chapter 4 presents a discussion of the risk and benefit tradeoffs between
compliance with existing NPDWRs and the alternatives considered during the
regulatory development process.
Chapter 5 presents an estimate of the incremental costs and thecosts of
implementing the final rule to air carriers and EPA. The costs of the other
regulatory alternatives as well as the proposed rule are also presented.
Chapter 6 discusses distributional analyses performed to evaluate the effects of the
rule on different segments of the population, and considers various executive
orders and requirements, including the Regulatory Flexibility Act (RFA) and
Unfunded Mandates Reform Act (UMRA).
References.
1.6 Calculations and Citations
This Economic and Supporting Analyses document presents results from analyses not
explained in detail in Chapters 1 through 6. To help the reader track the various calculations and
analyses, the following are provided:
• A reference section.
• Appendices.
- Appendix A - ADWR Aircraft and Population Baseline
- Appendix B - Aircraft Drinking Water Sampling Data
Appendix C - Cost Model
Appendix D - Screening Analysis
• Exhibits. Most tabular exhibits include a row that provides the formulas used to
compute the contents of each column.
Sources for information that was used but not calculated within the exhibits.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
2. Consideration of Regulatory Alternatives
2.1 Introduction
The NPDWRs may be promulgated as either MCLs or treatment technique requirements,
and include monitoring and reporting components. The NPDWR promulgation process requires
that each contaminant undergo occurrence, health risk, and cost and benefit analyses. These
analyses describe the contaminants' effects on public health and are used to identify the most
appropriate public health protection measures for each contaminant. Because the goal of the
ADWR is to tailor existing NPDWRs to the unique characteristics of aircraft water systems, EPA
determined that additional risk assessments were not necessary.
In the rule development process, the Water Safety Plan approach, which draws on the
principles of the hazard analysis critical control point (HACCP), and the Multiple Barrier
approach were used to ensure the rule adequately addresses potential contamination issues at
each step in the aircraft water system supply and transfer chain (see Exhibit 2.1).
In addition to the requirements described under EPA regulations, there are also numerous
FDA and FAA regulations pertaining to water onboard aircraft. The FDA and FAA regulations
include requirements affecting design, construction, and maintenance of watering points and
aircraft water systems. FAA regulations address portions of the maintenance plans for aircraft
water systems and provide existing regulatory authority to ensure the plans are implemented.
FDA, operating under 21 CFR 1240 and 21 CFR 1250, has authority and responsibility for the
following:
• Design approval for watering points and sanitation facilities at servicing areas
Ensuring that watering points, water carts, trucks, and hoses are operated in such a
manner as to prevent contamination of the water
• Review and approval of plans and specifications for design and construction of
aircraft water systems
Although applicable to all regulatory alternatives discussed in this document, FDA and
FAA regulatory requirements do not be change under the revised EPA regulations. FDA and
FAA requirements also do not affect the comparison of the regulatory alternatives throughout
this document (i.e., they apply equally under all alternatives). Possible revisions to FDA or FAA
regulations may be considered separately by each agency.
This chapter describes the process used to evaluate regulatory alternatives (Section 2.2),
and the regulatory alternatives that were considered for the development of the ADWR (Section
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
2.3). Exhibit 2.1 provides an overview of the aircraft water system supply and transfer chain,
and identifies potential causes of contamination of the onboard drinking water.
Exhibit 2.1 Aircraft Water System Supply and Transfer Chain
Public Water System
1 Cross connection with backflow
Flight to Next
Airport
Purchased water is contaminated
• Treatment failure
• Distribution system contamination
(e.g., main break, cross connection with
backflow)
Aircraft Water System
_ • Water line break introduces
j I contamination
Airport
• Cross contamination^
from improper
handling
Watering
Points
*
Lavatory Sink
• Boarded water is contaminated
• Backflow prevention device failure
• Water quality degrades/growth of
biofilm
•Improperly designed system allows
contamination
Galley
Sink/
Coffee
• Cross contamination of surfaces
due to hand contact, splash-back,
cleaning rags, aerosols
Water
Truck
Water
•Improperly Cabinet
maintained water
cabinets, carts,
trucks, and hoses
2.2 Process for Development of Regulatory Alternatives
In November 2004, EPA announced it had initiated a rule-making process to develop
regulations for water onboard aircraft. The Agency committed to working collaboratively with
other federal agencies overseeing the air carrier industry, industry representatives, and the
interested public to identify appropriate requirements to ensure safe drinking water onboard
aircraft. As a result, EPA established the ADWR Workgroup (the Workgroup), a multi-
discipline, interagency team to participate in the regulatory development process. The team
included representatives of the following EPA Offices: Water; Research and Development;
General Counsel; Enforcement and Compliance Assurance; Policy, Economics, and Innovation;
EPA Regions 1-7 and 9; as well as representatives of FDA and FAA. EPA also consulted with
CDC on an as-needed basis. The Workgroup worked collaboratively with a broad range of
industry experts and interested stakeholders including air carrier and airport owners and
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operators, pilots, flight attendants, passengers, fixed base operators, and environmental/public
health interests. Although the SDWA does not regulate aircraft water systems operating outside
the U.S., EPA is supporting an international effort led by the World Health Organization (WHO)
to develop international guidelines for aircraft drinking water.
Given the number and complexity of issues associated with a drinking water system
onboard a mobile unit such as an aircraft, EPA undertook an assessment approach to identify rule
alternatives by engaging the full range of stakeholders in the regulatory development process. In
June 2005, EPA held a public information meeting to kick off the rulemaking process. EPA
utilized a third-party facilitator for the meeting and for the development of a stakeholder
assessment report. The stakeholder assessment report included recommendations for a series of
joint education workshops to bring diverse stakeholders together to identify and understand the
issues, and to provide input and comment on various areas of concern. A summary of the public
information meeting can be reviewed at Docket ID No. EPA-HQ-OW-2005-0025. All
documents in the docket are listed on the www.regulations.gov website.
The first stakeholder workshop was held January 18 and 19, 2006, and provided an
opportunity for stakeholders to learn about aircraft water systems and watering points, current
regulations, and other information relevant to the rulemaking. Stakeholders were encouraged to
share their ideas about the issues that should be considered in developing the final rule. EPA
also presented a conceptual approach for the rule framework that draws on the principles of
HACCP, the Multiple Barrier approach used in managing traditional PWSs, and the Water
Safety Plan approach developed and applied by the WHO in their drinking water guidelines. A
detailed workshop summary is available in the docket.
In 2005, EPA began establishing AOCs with 45 air carriers potentially affected by the
ADWR. The AOCs required monitoring of each aircraft and the reporting of information on
existing treatment practices, data collected through previous monitoring, air carrier fleet
information, and O&M procedures.
The second stakeholder workshop was conducted March 28 and 29, 2007. At this
workshop, EPA presented a framework for the Water Safety Plan regulatory development
approach. EPA also presented preliminary monitoring data collected as of mid-March 2007
under the air carrier AOCs. The majority of the workshop was spent soliciting stakeholder input
on topics critical to the development of the ADWR including monitoring strategies, best
management practices, notification to passengers and crew, reporting and recordkeeping, and
program oversight and verification. A detailed workshop summary is available in the docket.
Based on stakeholder input, the information compiled in the framework for the Water
Safety Plan approach, and the preliminary monitoring data provided by the air carriers, the
Workgroup identified and developed four regulatory alternatives. The alternatives were
developed with consideration of several key questions, such as:
What health effects will the ADWR address?
Which contaminants should be regulated?
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
• Should there be monitoring requirements?
• What, if any, onboard treatment options are feasible for air carriers?
• Which best management practices (BMPs) should be included in the rule?
• How can ADWR requirements be integrated with existing air carrier programs
(i.e., maintenance programs for other aircraft components)?
2.3 Regulatory Alternatives Considered
Based on input from the Workgroup and other stakeholders, EPA identified and
developed four regulatory alternatives for consideration:
. Alternative 1 - Existing Drinking Water Regulations
. Alternative 2 - Regulatory Requirements Similar to the AOCs
. Alternative 3 - Regulatory Requirements Similar to WSG 29
. Alternative 4 - Hybrid Approach - ADWR
Each alternative is described below and summarized in the matrix that follows this
chapter (Exhibit 2.2b). The first three alternatives represent key elements of the baseline
scenario of existing NPDWRs and two previous approaches to regulating aircraft PWSs. Each
was carefully considered as a possible option, including evaluation of their strengths and
weaknesses. The proposed rule was developed by combining what were perceived to be
strengths of the other alternatives with additional insight contributed by stakeholders. The first
three alternatives were not proposed by the Agency as rule options.
The proposed rule was published in the Federal Register on April 9, 2008 (73 FR 19320).
The public comment period closed on July 8, 2008, and public input was evaluated by the
Agency during development of the final rule.
Although aircraft PWSs are not technically considered consecutive water systems, for the
purpose of this rule and based on FDA requirements, it is assumed aircraft are boarding potable
(finished) drinking water that meets NPDWR standards and that the equipment used in
transferring this water to the aircraft is maintained and operated so as to preserve that level of
water quality. Descriptions of FDA requirements are included in Exhibit 2.2a at the end of this
chapter to provide a full picture of the regulatory landscape under which aircraft PWSs operate.
Because the FDA requirements are existing regulations and apply in all cases regardless of the
final ADWR, they are not re-stated in the discussion of each alternative. However, each
alternative also assumes that it is possible for contamination to occur during the water transfer
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
process, for water to be boarded that is in violation of a NPDWR of significance to transient
consumers, and that water quality onboard the aircraft may deteriorate over time unless
management of water age is included in aircraft water system operations. In addition, in each
alternative aircraft PWSs are categorized as TNCWSs using finished surface water or finished
ground water under the direct influence of surface water, and serving 25 to 1,000 people per day.
This categorization is also not re-stated in the discussion of each alternative.
2.3.1 Alternative 1 - Baseline Alternative: Existing NPDWRs
The baseline alternative includes the current requirements for aircraft PWSs under the
applicable NPDWRs. Applicable regulations are those relevant to short-term rather than long-
term exposure to the drinking water. Under the baseline alternative, aircraft would be required to
comply with the regulations for coliforms, disinfectant residuals in the distribution system, and
public notification. The subsections below describe each of these requirements.
Coliform Bacteria
Coliform testing of drinking water is required under the TCR and is intended to provide
an indication of possible contamination of the water system by microbes. The existing TCR
would apply the following requirements to aircraft PWSs:
Water from taps in lavatories and galleys would be sampled and analyzed as
follows:
- Routine monitoring: One sample would be collected per month from each
aircraft. The sample location would be adjusted each month according to
a written sample siting plan. Samples would be tested for total coliforms,
and total coliform-positive sample cultures would be analyzed for either
fecal coliform or E. coli.
Repeat monitoring: Four repeat samples would be collected within 24
hours of notification of a total coliform-positive routine sample. The four
sampling sites would include the original test site and three additional taps
distributed throughout the aircraft water system. If fewer than four
sampling sites exist onboard, then 400 mL of sample must be taken from
available sample sites (i.e., if there is only one tap, a 400 mL sample or
four 100 mL samples would be drawn from that tap).
- Additional routine samples: In the month following a positive routine
sample, a minimum of five routine samples must be collected.
- The aircraft PWS is in violation of the monthly MCL if it has more than
one total coliform-positive sample per month. The aircraft triggers an
acute MCL violation if it has a repeat sample that tests positive for fecal
coliform or E. coli, or has a routine sample that tests positive for fecal
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
coliform or E. coll that is followed by a total coliform-positive repeat
sample.
Sanitary surveys would be conducted every 5 years.
No corrective action, such as disinfection and/or flushing the water system, is
specified in the regulation.
Public notification requirements would apply which state the air carrier must
notify the primacy agency within 24 hours of receiving notice of the fecal
coliform or E. co//'-positive result. In the case of a monthly MCL violation, the air
carrier would be required to notify the public within 30 days. In the case of an
acute violation, the air carrier would be required to notify the public within 24
hours as described below for a violation requiring Tier 1 public notice.
Distribution System Disinfectant Residual
The Surface Water Treatment Rule requires systems using surface water or GWUDI to
monitor the disinfectant residual in the distribution system. The distribution system disinfectant
residual is used as an indicator of whether the water is adequately disinfected. The disinfectant
residual in the distribution system is not expected to inactivate disinfectant-resistant pathogens.
Sampling frequency: Disinfectant residuals in the distribution system must be
monitored at the same time and location as coliform samples are monitored. For
aircraft, a single residual would be monitored each month when routine coliform
samples are collected and additional residual measurements would be required for
each repeat coliform sample.
Alternative sampling: The aircraft may monitor for heterotrophic bacteria using
heterotrophic plate counts (HPCs) instead of testing for disinfectant residual.
• Compliance: Disinfectant residual concentration must be detectable in the
distribution system. If conducting a HPC instead of testing for disinfectant
residual, a heterotrophic bacteria concentration of less than or equal to 500
cfu/mL is considered equivalent to a detectable residual. A violation is incurred if
the system fails to have a detectable residual in the samples for two consecutive
months.
Public notification: Failure to meet the requirements for disinfectant residual or
heterotrophic bacteria requires the aircraft to implement the measures of a Tier 2
public notice (see below).
Public Notification for Violations ofNPDWRs
The baseline requirements for coliforms where an acute violation is incurred that are
described above would require implementation of Tier 1 public notice measures. The air carrier
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
must attempt to notify the public served within 24 hours in the form of a Tier 1 notice, which for
TNCWSs typically means posting notice in the area where people are served, hand delivery of a
communication, and/or broadcasting the notice using a public address system. The air carrier
must also initiate consultation with the primacy agency as soon as practical and at least within 24
hours after receiving notification of the test results to determine if further public notification
steps are required. For non-acute coliform violations and for violations of the requirement for a
disinfectant residual in the distribution system, the aircraft would provide Tier 2 public notice.
This is also typically posted or hand delivered to users of the TNCWS, and the regulation allows
30 days for notice to be provided.
2.3.2 Alternative 2 - Regulatory Requirements Similar to the AOCs
An AOC regulatory alternative would require aircraft PWSs to implement monitoring for
coliforms and disinfectant residuals, an operations and maintenance program that includes
routine disinfection and flushing, disinfection and flushing as corrective action, and reporting
procedures consistent with the requirements established under the AOCs. The requirements, or
orders, of the AOCs were based on a finding that the air carriers were not meeting the existing
NPDWR requirements as described in the baseline alternative.
Under the AOCs, air carriers are required to do the following:
• Supply fleet information to EPA in the EPA-specified format.
Provide EPA with a copy of the current policies and practices for boarding
domestic water and foreign-source water using the EPA-specified format.
• Provide EPA with a copy of current O&M practices.
• Provide EPA with data from current or previous drinking water monitoring
programs.
• Continue with the pre-AOC monitoring program if coliform monitoring was
occurring more than once per year.
• Submit a Comprehensive Representative Monitoring Plan (CRMP) to EPA within
30 days of the AOC's effective date.
Submit a Q APP to EPA within 3 0 days of the AOC' s effective date.
• Implement Period I monitoring within 15 days after written approval from EPA of
the CRMP and QAPP.
• Under Period I monitoring, implement the following:
- Disinfect the aircraft water system quarterly.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
- Disinfect the watering points owned by the air carrier monthly and in
accordance with an O&M plan. If the pre-AOC O&M plan required more
frequent disinfection than monthly, continue at that higher frequency.
If the aircraft fleet consists of less than or equal to 20 aircraft, sample all
aircraft for total coliform quarterly; if the aircraft fleet consists of more
than 20 aircraft, sample approximately 25 percent of the fleet of aircraft
quarterly, so that all aircraft are sampled for total coliform at least
annually. Any total coliform-positive sample culture would be tested for
fecal coliform or E. coli.
- Perform disinfection and flushing and follow-up sampling as corrective
action where any routine or follow-up sample is total coliform-positive.
Report monitoring results quarterly.
Submit a self-certification each quarter that affirms that the aircraft water
system and air carrier-owned watering points are disinfected as per the
O&M plan.
After 12 months of Period I monitoring, the air carrier was to consult with EPA
and an agreement made, or a program prescribed by EPA in the absence of
agreement, for a monitoring, disinfection, and reporting frequency and response
procedure which would be implemented in months 12 through 24, or Period II, of
the monitoring program.
During the 24 months of Monitoring Periods I and II, the air carrier was to
conduct a study of potential confounding or contributing sources of contamination
that are external to the aircraft, i.e., watering points. The air carrier was to submit
the study results to EPA within 24 months of the effective date of the AOC.
Under this alternative, all qualifying aircraft would be required to establish a program of
sampling, routine disinfection and flushing, reporting, and a response procedure that is consistent
with the parameters established under Monitoring Period I of the AOCs:
• All personnel responsible for the O&M of aircraft water systems would receive
training. The training would be implemented by the air carrier responsible for the
aircraft.
• Aircraft O&M and monitoring plans must be updated to reflect new schedules,
procedures, and activities.
Aircraft must monitor for total coliforms and disinfectant residual.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
If a system tests positive for total coliforms, it must analyze the total coliform-
positive culture medium for fecal coliform or E. coli.
If a system tests positive for fecal coliform or E. coli, or if it tests positive for total
coliform in any sample, it must notify the primacy agency within 24 hours and
must conduct disinfection and flushing procedures, including follow-up sampling,
and must implement public notification activities.
Copies of O&M plans, monitoring plans, and monitoring data must be
maintained.
Approximately 25 percent of the aircraft fleet must be monitored for coliforms
and disinfectant residual quarterly, so that all aircraft are sampled at least
annually.
Routine disinfection and flushing must be performed at least quarterly.
A self-certification that affirms that the aircraft water system was disinfected and
flushed according to the O&M plan must be submitted each quarter.
Report monitoring results quarterly (within 10 business days of the end of a
quarter of monitoring).
2.3.3 Alternative 3 - Requirements Similar to Water Supply Guidance 29
Upon promulgation of the SDWA in 1974, EPA's responsibilities for ensuring that safe
drinking water was served on ICCs broadened from certifying the PWSs serving ICCs to include
regulation of the water quality onboard the conveyances. WSG 29, signed in 1986, outlined
EPA's role in implementing NPDWRs with respect to Interstate Carrier Water Supplies
(ICWSs), watering points, and ICCs, and established the coordination of this role with the FDA's
responsibilities in the Interstate Travel Sanitation Program. WSG 29 allowed aircraft to choose
between monitoring for turbidity, total coliforms, and disinfectant residuals and the
implementation of an operations and maintenance program that included disinfection and
flushing the aircraft. It is notable that WSG 29 was written prior to promulgation of the TCR,
the SWTR, or Phase II Chemical contaminant rule (which included revised requirements for
nitrate). Therefore, for this alternative, the monitoring requirements have not been revised to
reflect current requirements of the NPDWRS as described in the baseline alternative. The WSG
29 alternative was considered primarily because it recognized the importance of disinfection and
flushing as a treatment technique/best management practice in the operation and maintenance of
aircraft PWSs. It also offered flexibility through a choice between monitoring and implementing
an EPA-approved operation and maintenance program.
Under the alternative based on WSG 29, the following would be included:
• Aircraft would comply either with the monitoring and reporting requirements or
with their EPA-approved O&M plans.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
Monitoring requirements would include daily turbidity monitoring and quarterly
coliform monitoring.
Disinfection and flushing as corrective action would be required following a total
coliform-positive sample.
O&M requirements for quarterly disinfection and flushing of onboard systems.
2.3.4 Alternative 4 - Hybrid Approach - ADWR
EPA developed the proposed regulatory option based on input from the Workgroup,
senior management, and stakeholders. It was developed following the March 2007 workshop
where stakeholders and the Workgroup discussed limitations of the other alternatives and key
provisions of a possible ADWR. EPA reviewed public comments received on the proposed rule
and incorporated specific items during development of the final rule. The final rule addresses
stakeholder and commenter concerns including: (1) the need for operational flexibility by
providing several options for compliance, (2) the need to not conflict with manufacturers'
recommendations, (3) the need to limit the grounding of aircraft based on water system issues to
situations that present an acute public health risk and only when public access to the water
cannot be prevented, and (4) the need to allow for future changes in technology.
EPA is presenting key components of the final rule:
. Routine coliform monitoring using one of four monitoring frequency options
determined by the frequency of disinfection and flushing of the aircraft water
system.
Two routine coliform samples are collected at the frequency chosen. If one or
more of the routine samples are total coliform-positive but are E. co//'-negative, the
aircraft can choose to either perform repeat sampling (collecting 3 samples) or
corrective action to include disinfection and flushing and follow-up monitoring.
Special consideration is given for aircraft with a single water tank and tap if the
tank is removable and drained daily. Those aircraft may collect a single routine
sample at the frequency chosen.
. Disinfection and flushing as corrective action must occur in the event of an E.
co//'-positive sample or if any repeat samples are total coliform-positive. If
disinfection and flushing as corrective action is required, public access to water
must be restricted and public notice must be posted until the water system is
disinfected and flushed and a complete set of follow-up samples are taken. In
cases of total coliform-positive results, aircraft may resume serving water for
human consumption once follow-up samples have been taken. In cases of E. coli-
positive results, the aircraft may not serve water for human consumption until all
follow-up samples are total coliform-negative. The rule specifies a maximum
amount of time that can elapse before corrective action disinfection and flushing
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
occurs if the water cannot be physically shut off or water flow through the taps
cannot be prevented. Allowing more time for corrective action disinfection and
flushing where public access can be prevented provides flexibility to air carriers
for performing the procedure and minimizes the need for unscheduled events for
which the aircraft must be taken out of service.
Disinfectant residual monitoring is not required by the final rule, but may be
recommended in guidance as a means of promoting voluntary measures such as
flushing and refilling with water containing a residual.
Specific training requirements for all personnel involved with the aircraft water
system operations and maintenance provisions of the ADWR must be included in
the aircraft O&M plan.
Detailed disinfection and flushing procedures must be included in O&M plans.
Reporting requirements for disinfection and flushing and monitoring results, and
compliance status.
Water system O&M plans must be incorporated into FAA-accepted O&M plans
for aircraft.
EPA may perform compliance audits as needed.
Aircraft perform self-inspections of the water system at least every 5 years and
self-certify completion of the inspections.
The regulatory requirements under the four alternatives are presented in summary form in
the matrix in Exhibits 2.2a and 2.2b, below. Exhibit 2.2a includes those activities that are
required by FDA regulations. These relate to watering points, or water transfer and delivery
systems, which include the water source, trucks, carts, cabinets, containers, and hoses. These
requirements are not affected by the final rule and will continue to be in effect under all
regulatory alternatives. Exhibit 2.2b summarizes those activities related to onboard water system
operation and maintenance.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit 2.2a Existing FDA Requirements for Watering Points1 and Supplemental
Treatment
Requirement
Design approval for watering
points
Design approval for sanitation
facilities at servicing areas
Disinfect and flush watering
points
Disinfect and flush water carts
and trucks
Inspection of servicing area
Supplemental Treatment Plan
and Specifications Review and
Approval of Design and
Construction
Existing FDA Regulations Applicable to Watering Points
under all ADWR Alternatives
FDA approval of watering points (21 CFR 1240.83) based on
water supply meeting NPDWRs, and the methods/facilities for
water delivery to conveyance are sanitary and satisfactory.
Submit construction plans to FDA for review (21 CFR1250.62)
Operate and maintain servicing area pipes and appurtenances
to prevent contamination of the water per FDA (21
CFR1 250.67)
Operate and maintain servicing area pipes and appurtenances
to prevent contamination of the water per FDA (21
CFR1250.67) [Note: no frequency or minimum criteria specified]
FDA may inspect servicing areas or may approve/disapprove
based on inspections by state health department (21
CFR1250.61) [Note: no inspection frequency specified]
Obtain FDA approval for treatment equipment onboard the
aircraft (21 CFR1 240.90)
1 Watering points include transfer and delivery systems (including the water source, trucks, carts, cabinets,
containers, and hoses)
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit 2.2b Alternatives Considered for the ADWR - Aircraft Water System
Potential
Components
Rule Start-up - aircraft
water systems
Rule Start-up-
primacy agency
Qualified operators
Baseline Alternative:
Current NPDWRs1 and
applicable FDA and FAA
regulations
Assume air carrier
personnel are familiar with
requirements of existing
regulations and have
developed management
systems to implement these
requirements.
Assume primacy agency
has developed necessary
reporting and
recordkeeping systems.
PWSs using surface water
orGWUDI must be
operated by qualified
personnel who meet the
requirements specified by
the state (40 CFR1 41. 70).
Regulatory
Requirements Similar
to the AOCs
Read and understand
regulatory requirements.
Establish new reporting
and recordkeeping
systems.
Personnel to be trained
and training content to
be included in CRMP.
Regulatory
Requirements
Similar to Water
Supply Guidance
29
Read and
understand
regulatory
requirements.
Establish new
reporting and
recordkeeping
systems.
No new
requirements.
Hybrid Approach- ADWR
Read and understand regulatory requirements.
Establish new reporting and recordkeeping systems.
Operator "need-to-know" items and personnel training
requirements to be included in the aircraft O&M plan.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Potential
Components
Baseline Alternative:
Current NPDWRs1 and
applicable FDA and FAA
regulations
Regulatory
Requirements Similar
to the AOCs
Regulatory
Requirements
Similar to Water
Supply Guidance
29
Hybrid Approach- ADWR
Develop and
implement monitoring
plan
Develop sample siting plan
to include sample collection
locations
(40CFR141.21).
Update monitoring plans
to reflect new
schedules, procedures,
and activities.
No monitoring
required if O&M
plan approved by
EPA.
Monitoring frequency to be stated in sampling plan that is
included in the aircraft O&M plan, and is based on
disinfection and flushing frequency.
Routine monitoring -
coliform bacteria
One total coliform sample
monthly at individual
aircraft, in accordance with
sample siting plan (40
CFR141.21). Any total
coliform-positive sample is
analyzed for fecal coliform
or £. co/;.
Air carriers must sample
approximately 25% of
the aircraft fleet
quarterly, so that all
aircraft are sampled at
least annually.
Two samples must be
collected from each
individual aircraft - one
galley and one lavatory
tap sample.
Any total coliform-
positive sample is
analyzed for fecal
coliform or £. co/;.
One sample
quarterly if not
implementing O&M
plan.
Coliform monitoring frequency, requiring two samples, is
selected by the air carrier from 1 of 4 options and is based
on the disinfection and flushing frequency stated in O&M
plan:
(1) annual monitoring (once every twelfth month) if routine
disinfection and flushing conducted at least quarterly (once
every third month);
(2) semi-annual monitoring (once every sixth month) if
routine disinfection and flushing conducted once every 4
months (three times per year);
(3) quarterly monitoring (once every third month) if routine
disinfection and flushing conducted semi-annually (once
every sixth month);
(4) monthly monitoring (once every month) if routine
disinfection and flushing conducted once per year or less
(once every twelfth month or less).
Aircraft with a single sample tap and a water tank that is
removable and drained daily must collect only a single
routine sample each monitoring period.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Potential
Components
Baseline Alternative:
Current NPDWRs1 and
applicable FDA and FAA
regulations
Regulatory
Requirements Similar
to the AOCs
Regulatory
Requirements
Similar to Water
Supply Guidance
29
Hybrid Approach- ADWR
Repeat monitoring
coliform bacteria
Repeat sampling requires 4
samples (one upstream,
one downstream, one at the
same sampling point, and
one at another point if 4
taps are available) within 24
hrs. Any total coliform-
positive sample is analyzed
for fecal coliform or E. coli.
Repeat sampling at 4
taps (tap with positive
coliform sample, 1 other
lavatory tap, 1 other
galley tap, and 1 other
tap; or total of 400 ml
from available taps). If a
sample tests positive for
total conforms in a
routine sample, it must
be analyzed for fecal
coliform or £. coli.
Not specified.
If one or more routine samples are total coliform-positive
but E. coli negative, the air carrier has the option of
collecting a set of 3 repeat samples within 24 hours of
notification. Any total coliform-positive sample is analyzed
for £. coli.
Additional routine
monitoring - coliform
bacteria
If a routine total coliform
sample is positive, systems
taking less than 5 routine
samples per month must
collect 5 routine samples in
the following month per the
sample siting plan or obtain
a waiver (40 CFR 141.21).
Any total coliform- positive
sample is analyzed for fecal
coliform or £. coli.
Not required.
Not required.
Not required.
Post disinfection
monitoring - coliform
bacteria
Not required.
Collect 4 samples (1
galley tap, 1 lavatory
tap, the tap positive for
total coliform, and 1
other tap). Any total
coliform-positive sample
is analyzed for fecal
coliform or £. coli.
Not required.
Two follow-up samples after corrective action disinfection
and flushing, taken at the same locations as used for
routine sample collection.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Potential
Components
Baseline Alternative:
Current NPDWRs1 and
applicable FDA and FAA
regulations
Regulatory
Requirements Similar
to the AOCs
Regulatory
Requirements
Similar to Water
Supply Guidance
29
Hybrid Approach- ADWR
Routine monitoring -
disinfectant residual
One disinfectant residual
sample monthly at
individual aircraft per
SWTR, at same location
and time as coliform
sample (40 CFR
14174(b)(6)(i) and/or
Annual at individual
aircraft at same
locations as routine
coliform samples
Not required.
Not required.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Potential
Components
Baseline Alternative:
Current NPDWRs1 and
applicable FDA and FAA
regulations
Regulatory
Requirements Similar
to the AOCs
Regulatory
Requirements
Similar to Water
Supply Guidance
29
Hybrid Approach- ADWR
Develop and
implement O&M plan
Best Available Technology
(BAT) for TCR MCLs:
Implement proper
maintenance of the
distribution system
including appropriate pipe
replacement and repair
procedures, main flushing
programs, proper operation
and maintenance of storage
tanks, and continual
maintenance of positive
water pressure in all parts
of the distribution system
(40CFR141.63D)
FAA regulations require the
use of manufacturers
recommendations:
- Develop and implement a
maintenance and
inspection program that
guarantees airworthiness of
aircraft (14 CFR 121.367).
- Use BMPs prescribed by
manufacturer's
maintenance manual (14
CFR 43).
- Use maintenance
schedule in accordance
with manufacturer (14 CFR
25.1529 Appendix H).
Update O&M plans to
reflect new schedules,
procedures, and
activities.
O&M plan may be
developed in lieu of
required monitoring.
Plan to be
approved by EPA
regional office with
following elements:
-Cover letter
summarizing water
handling
procedures,
maintenance
schedule, and
description of
annual report data
-Disinfection and
flushing procedure
as outlined in WSG
29, or equivalent
procedure
O&M plans must address watering point selection criteria;
disinfection and flushing procedures and frequency;
procedures for follow-up sampling; staff training
requirements; procedures for self-inspections; procedures
for boarding water; the coliform sampling plan; and whether
the aircraft water system can be shut off or water flow
through the taps can be prevented.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Potential
Components
Baseline Alternative:
Current NPDWRs1 and
applicable FDA and FAA
regulations
Regulatory
Requirements Similar
to the AOCs
Regulatory
Requirements
Similar to Water
Supply Guidance
29
Hybrid Approach- ADWR
Routine disinfect and
flush aircraft water
system
Inspect, disinfect, and
sanitize water system as
needed to prevent spread
of disease per FDA (21
CFR1240.30).
Clean, disinfect and flush
aircraft water system
whenever FDA deems it
necessary (21 CFR
1250.81).
Disinfect the aircraft
water system quarterly
in accordance with AOC
O&M plan; if pre-AOC
O&M plan required
more frequent
disinfection than
monthly, continue at that
higher frequency.
Submit self-certification
quarterly to EPA
indicating that
disinfection process
followed proper
procedures.
Quarterly per O&M
plan and after any
service or repairs;
remove aircraft
from service and
disinfect holding
tanks if aircraft
served by use-
prohibited watering
points.
Aircraft follow 1 of 4 frequencies for routine disinfection and
flushing:
(1) quarterly (once every third month);
(2) 3 times per year (one every fourth month);
(3) 2 times per year (once every sixth month);
(4) once per year or less (once every twelfth month or less).
The air carrier must select a frequency that is in
accordance with manufacturer recommendations. If there
is no such manufacturer recommendation, then the air
carrier selects any on of the four frequencies.
The frequency determines the aircraft's required coliform
monitoring schedule as described above.
Disinfect and flush
aircraft water system
as corrective action
Clean, disinfect and flush
aircraft water system
whenever FDA deems it
necessary (21 CFR
1250.81).
Disinfection after total
coliform-positive
sample.
Required after any
service or repairs or
if the aircraft opts
for monitoring and
has a total coliform-
positive sample; no
monitoring to trigger
corrective action if
choose O&M
option.
Required if any sample is £. co/;-positive, or if one or more
repeat samples or follow-up samples are total coliform-
positive but £. co/;-negative.
Must be conducted prior to resumption of unrestricted
public access to the aircraft water system or no later than
72 hours after notification of the positive result if the water
cannot be physically shut off or flow through the taps
prevented, or when able if the water is physically shut off or
flow is prevented.
Aircraft that fail to conduct disinfection and flushing within
72 hours and do not physically shut off the water or prevent
flow through the taps must implement PN and restrict
access to the water within 24 hours.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Potential
Components
Baseline Alternative:
Current NPDWRs1 and
applicable FDA and FAA
regulations
Regulatory
Requirements Similar
to the AOCs
Regulatory
Requirements
Similar to Water
Supply Guidance
29
Hybrid Approach- ADWR
Supplemental
Treatment
Not specified.
Not specified.
Not specified.
Not specified. (If onboard treatment units are used, they
must be acceptable to FDA and FAA, meet National
Science Foundation (NSF) International/American National
Standards Institute (ANSI) Standards, and be installed,
operated, and maintained in accordance with the
manufacturer's specifications and FAA requirements).
Sanitary survey -
primacy agency
Assume primacy agency
has developed and
implemented a program to
conduct sanitary surveys
(40CFR142.10(b)(2)).
Primacy agency conducts
sanitary surveys for all non-
community systems served
by surface water or GWUDI
every 5 years per IESWTR
(40CFR141.21(d)).
Not specified.
Not specified.
Compliance audits at the discretion of EPA.
Sanitary survey •
water system
Water systems prepare for
sanitary survey every 5
years per IESWTR (40 CFR
Not specified.
Not specified.
Self-inspection performed by aircraft at least every 5 years
and self-certified to EPA.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Potential
Components
Baseline Alternative:
Current NPDWRs1 and
applicable FDA and FAA
regulations
Regulatory
Requirements Similar
to the AOCs
Regulatory
Requirements
Similar to Water
Supply Guidance
29
Hybrid Approach- ADWR
Public Notification
[Note: This element
not costed under this
ruling but covered
under the Information
Collection Request
(ICR) for the final
ADWR and will be
incorporated into the
next revision of the
ICR for the PN Rule]
- Post FDA certificates on
conveyances (21 CFR
1240.20).
-Per 40 CFR 141.201
Subpart Q:
Each owner or operator of a
PWS must give notice of all
NPDWR violations,
operating status under
variances and exemptions,
failure to comply with
schedules established by
variance or an exemption,
and occurrence of a
waterborne disease
outbreak.
PN required when
aircraft cannot cease
serving water to the
public within 24 hours of
receiving a total
coliform-positive or fecal
coliform/E. co/;-positive
result.
Post placards at all
taps when MCL
exceeded.
PN required whenever the restrict public access
requirements are in place.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
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Potential
Components
Baseline Alternative:
Current NPDWRs1 and
applicable FDA and FAA
regulations
Regulatory
Requirements Similar
to the AOCs
Regulatory
Requirements
Similar to Water
Supply Guidance
29
Hybrid Approach- ADWR
Reporting and
Recordkeeping
Per40CFR141 Subpart D:
-Report to State results of
monitoring conducted by
private labs (non-State
labs); failure to comply with
NPDWRs; certification of
compliance with public
notification requirements
including copies of all
public notices; copies of
records maintained on
premises.
-Maintain following records
related to NPDWR
compliance on premises:
bacteriological analyses (5
years), chemical analyses
(10 years), records of
actions taken to correct
compliance issues (3
years), sanitary surveys
and related reports and
communications (10
years), records on any
variance or exemption (5
years), and copies of
public notices (3 years).
Report the monitoring
results quarterly (within
10 business days of the
end of a quarter of
monitoring).
Submit a self-
certification each
quarter that affirms that
the aircraft water
system(s) and watering
points are disinfected as
per the O&M plan.
Air carriers must
maintain copies of their
O&M plan, monitoring
plan, and monitoring
data.
Maintain a
maintenance log for
each aircraft and
submit an annual
summary report of
each aircraft's
maintenance
procedures to EPA.
Maintain records of
O&M procedures
for 5 years.
Air carriers that
choose to conduct
monitoring must
keep a copy of their
monitoring plan and
monitoring results
for at least 5 years,
and report
monitoring results
to EPA on quarterly
basis along with
maintenance
records for any
aircraft with total
coliform-positive
samples.
Report disinfection and flushing events and monitoring
results within 10 days of the end of the monitoring period.
The air carrier must provide evidence of self-inspection
within 90 days of completion and indicate all deficiencies
from self-inspections have been corrected. The air carrier
must report within 90 days that any deficiency identified
during a compliance audit was addressed. If any deficiency
identified during a compliance audit or self-inspection has
not been addressed within 90 days of identification, the
report must explain why and provide a schedule for
addressing them.
Report that a coliform sampling plan was developed, that
an O&M plan was developed and report the coliform
monitoring frequency within 18 months of final rule
promulgation and within the first calendar quarter of adding
additional aircraft to the air carrier fleet.
Changes to the routine coliform sampling frequency must
be reported within 10 days following the calendar month in
which the change occurred.
Report inventory within 18 months of the final rule and
subsequent changes in inventory within 10 days of the end
of the calendar month in which the change was made.
Report all events requiring PN and all failures to comply
with the disinfection and flushing or monitoring
requirements.
Maintain the following records: bacteriological analyses (5
years), disinfection and flushing (5 years), self inspections
(10 years), notices to passengers and crew for compliance
issues (3 years after issuance), and sampling and O&M
plans.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
1 NPDWR requirements for TNCWSs using surface water (serving 1,000 or fewer people). Although aircraft PWSs are not considered to be
consecutive systems, assume the aircraft is boarding water that meets FDA requirements for potable water in compliance with treatment
technique requirements of EPA's regulations (source water treatment provided). Therefore, turbidity and nitrate/nitrite monitoring is not required.
2 As used here, the use of supplemental treatment onboard aircraft such as booster chlorination, ultraviolet disinfection, and onboard filtration
serves as an additional barrier to address water quality deterioration in the aircraft water system. It does not replace the FDA requirement that the
watering point water supplies meet the requirements of the NPDWRs.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
3. Baseline Analysis
3.1 Introduction
This chapter describes the baseline analysis that characterizes the number of aircraft
public water systems and affected air carriers in existence as of January 2007 when the
evaluation of potential regulatory options for aircraft water systems was initiated, as well as the
quality of water onboard aircraft as of December 31, 2008. The baseline analysis consists of the
following processes:
. Creating an industry profile (Section 3.2) - Identifying and collecting
information on aircraft subject to the ADWR and estimating the potentially
affected population.
. Documenting data collection efforts (Section 3.3) - Summarizing results of
aircraft water quality data collection efforts and characterizing aircraft water
quality.
This chapter presents a level of detail and precision appropriate to support subsequent
analyses and regulatory decisions under the ADWR. Uncertainties in the ADWR baseline are
discussed in Section 3.4.
3.2 Industry Profile
This section provides a characterization of aircraft water systems that is used to perform
analyses of ADWR regulatory alternatives. Extensive effort was invested in January 2007 in
establishing the baseline of aircraft water systems for development of the proposed rule.
Although air carriers may have changes in their fleet and consolidations have occurred in the
industry, there has likely not been a significant permanent change in the total number of aircraft
or passengers, or the types of aircraft transporting the majority of passengers, particularly given
the relatively short period of time between the proposal and final rule publications. The aircraft
water system baseline is organized as follows:
. Section 3.2.1 describes the data sources used to characterize the industry baseline.
. Section 3.2.2 is a background section describing the various ways in which water
systems can be classified and identifies distinctions that are important for this
analysis.
. Section 3.2.3 provides the baseline number of aircraft and the estimated
population served by aircraft water systems per year.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
3.1.1 Data Sources
Several data sources were used to characterize the ADWR baseline. Data from the
AOCs, Bureau of Transportation Statistics (BTS), FAA, commercial air carrier web sites, and
aircraft manufacturer web sites were used to create an aircraft water system and population
baseline. BTS is the data collection and analysis arm of the U.S. Department of Transportation
(DOT), and provides data for load factor, flights per year, and passengers per year for a number
of large air carriers. FAA, which regulates all civil aviation in the U.S., requires that the number
of onboard staff be based on the number of onboard passengers (14 CFR 91.533 and 14 CFR
125.269). A number of commercial air carrier web sites provide data on seating configurations,
including carrying capacity and number of lavatories and galleys. Standard seating
configurations provided by aircraft manufacturer web sites were used if the information was not
available through air carrier Web sites. Commercial air carriers are required to make their
annual reports to shareholders available to the public. These reports provide data on load factors,
flights per year, and fleet size.
3.1.2 Water System Characterization
Categorization of water systems is important because system size, ownership, and
consecutive/wholesale relationships affect the way in which regulatory analyses are performed.
This section explains the classifications of water systems, as defined by EPA's NPDWRs, and
describes further subdivisions according to water source, size (population served), and ownership
for regulatory analysis purposes.
Public Water System Type
NPDWRs apply to all PWSs.7 A PWS is defined as a system that provides water for
human consumption through pipes or other constructed conveyances if such a system has at least
15 service connections or regularly serves an average of at least 25 individuals per day for at
least 60 days per year. PWSs are categorized as follows:
. Community Water Systems (CWSs) are PWSs that have at least 15 service
connections used by year-round residents or that regularly serve at least 25 year-
round residents.
. Non-community Water Systems (NCWSs) are PWSs that are not classified as
CWSs.
NCWSs are subdivided into two categories:
Non-transient Non-community Water Systems (NTNCWSs) are NCWSs that
regularly serve at least 25 of the same people more than 6 months per year.
7 Some PWSs that meet specific criteria in 40 CFR 141.3 are exempt from NPDWRs. ICCs are specifically not
exempt from NPDWRs.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
. Transient Non-community Water Systems (TNCWSs) are NCWSs that do not
regularly serve at least 25 of the same people more than 6 months per year.
Most commercial passenger aircraft serve at least 25 individuals per day for at least 60 days per
year. However, it is unlikely that any single aircraft regularly serves the same 25 people for
more than six months per year. Therefore, for the purposes of the ADWR, all aircraft public
water systems are classified as TNCWSs.
Source Water Type
Systems are classified by the type of source from which they draw water. Systems that
use either surface water or GWUDI are classified as surface water systems. Ground water
systems are, by default, systems that draw from ground water sources that are not GWUDI.
Some systems may obtain water from both ground water and surface water sources and are
referred to as "mixed systems." In the Safe Drinking Water Information System (SDWIS) and
the Baseline Handbook, a mixed system is categorized as a surface water system because it
obtains some portion of its flow from surface water (i.e., all mixed systems are considered
surface water systems).
For the purposes of the ADWR baseline and subsequent analyses in this document, all
aircraft are classified as surface water systems. Aircraft board water from a number of different
locations across the U.S. and are likely to be served by many different public water systems,
including surface water systems. Additionally, most large cities and municipalities where
airports are located are served by surface water systems. For the purposes of this document,
EPA is assuming that all aircraft board water from either mixed or surface water systems.
Population Served
The number of passengers per year for any aircraft is estimated by multiplying the
carrying capacity of the aircraft, the loading factor (percentage of seats occupied) for the air
carrier, and its yearly flight frequency. Passenger figures for all aircraft are summed to arrive at
the yearly total number of passengers. The number of onboard staff is estimated based on FAA
requirements (14 CFR 91.533 and 14 CFR 125.269), which provide a relationship between the
number of required pilots and flight attendants and the number of onboard passengers. The total
numbers of passengers and onboard staff represent all people potentially exposed to drinking
water from an onboard water system (population served) at some time during the year. Although
crew and some passengers take more than one flight per year, the total number of passengers and
crew has not been adjusted to account for this difference. For purposes the ADWR, population
figures are presented in the nine categories corresponding to the number of available sampling
points onboard an aircraft (see Exhibit 3.1). Appendix A provides a detailed breakdown of
aircraft data used to develop the population-served figures for onboard staff, passengers, and
total population figures presented in Exhibit 3.1.
Ownership
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
Systems are categorized in SDWIS and in the Baseline Handbook according to three
ownership types: "private," "public," and "other." Private systems are owned by private
corporations or individuals. Public systems are owned by public entities such as municipalities,
counties, or special districts. The "other" category contains systems where ownership is not
reported in SDWIS. Ownership distinctions are important to the analysis because public systems
may have access to capital and other means of financing that may not be available to private
systems.
For the purposes of this document, all aircraft are classified as private ownership.
Consecutive and Wholesale System Types
Typical PWSs are normally categorized according to whether they produce finished
water by monitoring and providing appropriate treatment to their source water, or obtain finished
water from other PWS(s). Finished water is water introduced into the distribution system of a
PWS and is intended for consumption without further treatment, except for treatment necessary
to maintain water quality in the distribution system. Finished water is often referred to as
potable water. A consecutive system is defined as a PWS that receives some or all of its finished
water from one or more wholesale systems. A wholesale system is defined as a PWS that
monitors and treats as appropriate, source water and then sells or otherwise delivers finished
water to another PWS. Treatment applied to finished water by consecutive water systems may
be in the form of booster disinfection or addition of corrosion control chemicals. Costs of
treatment provided by wholesale systems are typically passed on to the consecutive systems in
the form of water rates or fees.
FDA requirements mandate that aircraft provide only potable water that meets EPA
standards for drinking water (21 CFR 1240.80). Because they board only finished water, for the
purposes of ADWR analyses, all aircraft are treated as equivalent to consecutive water systems.
3.1.3 Baseline Number of Aircraft and Population Served by Aircraft per Year
Number of Aircraft
EPA estimated in January 2007 that 7,327 aircraft are subject to the final ADWR. The
aircraft inventory presented in Exhibit 3.1 represents the baseline for rule activities that are
applicable on an individual aircraft level (e.g., monitoring, disinfection and flushing, self-
inspections, and compliance audits). Annual implementation and administration activities, as
well as development of sampling plans and O&M plans, will occur on an individual air carrier
basis.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
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Aircraft in the following categories are not subject to the final ADWR because they do
not meet the definition of a PWS, or are excluded from regulatory requirements under SDWA
section 14II8:
Aircraft that do not serve 25 or more people for at least 60 days per year
. Aircraft without a qualifying lavatory9 or galley
. Aircraft solely used for cargo purposes
Aircraft that fly international routes serving only one U.S. city
. Aircraft owned and operated by the U.S. military if used solely for military
purposes, not conveying passengers in interstate commerce, and meet all of the
other exclusion criteria under SDWA section 1411
Exhibit 3.1 is stratified according to the number of available sampling points per aircraft. For the
purpose of the analysis, each qualifying lavatory and galley on an aircraft is assumed to have
only one sampling tap. The number of available sampling taps is used to characterize some of
the information gathered in developing the baseline. It appears in several of the exhibits in this
document for information display purposes only. The number of available taps is not used as a
parameter in the cost model for the economic analysis for the ADWR.
Exhibit 3.1 ADWR Aircraft and Population Baseline
W or Available sampling
Points
A
1
2
3
4
5
6
7
8
>9
Total
# of Aircraft
B
381
2,080
756
421
956
871
298
809
755
7,327
I otal 5 or Available
Sampling Points
C=B*A
381
4,160
2,268
1,684
4,780
5,226
2,086
6,472
9,354
36,411
# of Onboard Staff/year
D
1,978,974
8,639,938
2,332,151
2,510,833
6,641,598
3,879,569
1,414,970
3,765,459
3,998,054
35,161,545
# of Passengers/year
E
24,980,980
104,430,089
22,935,259
51,846,929
158,813,021
91,360,628
34,239,869
93,648,921
126,176,568
708,432,263
I otal 5 or Potentially
Affected Persons/year
F=D+E
26,959,953
113,070,026
25,267,410
54,357,762
165,454,619
95,240,197
35,654,839
97,414,380
130,174,622
743,593,809
Notes:
(A) Each qualifying lavatory and galley on an aircraft is assumed to have only one sampling point. Therefore, the number of available sampling points is
representative of the number of lavatories and galleys on an aircraft.
(B), (D), (E) Derived from Appendix B.
(C) Average number of sampling points used for >_ 9 sampling points size category.
Section 1411 excludes from regulation any public water system that receives all its water from another regulated
public water system, does not sell or treat the water, and is not a "carrier which conveys passengers in interstate
commerce."
9 A qualifying lavatory is defined as a private room with a flushing toilet and sink. Curtained-off toilet seats without
lavatory sinks (as seen in some small, short-range aircraft) have not been included.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
Population Served by Aircraft PWSs
All onboard passengers and crew can potentially be exposed to lavatory and galley water
on aircraft. Exposure to finished water onboard aircraft can occur via consumption of coffee,
tea, or other beverages made with galley water;10 distributing drinking water that is from galley
or lavatory water taps when bottled water is not available; passengers consuming water from
lavatory taps to take medication, mix infant formula, brush teeth, wash face or hands, or through
any subsequent hand-to-mouth contact. Columns D and E in Exhibit 3.1 present estimates of the
population potentially exposed to drinking water onboard aircraft. These numbers are based on
the number of flights each aircraft takes per year and the estimated number of passengers
onboard each aircraft. These numbers have not been adjusted for passengers and crew who take
more than one flight per year.
3.3 Water Quality Baseline
This section describes data collection efforts reported or processed as of December 31,
2008. In 2003 and 2004, the ATA and EPA randomly sampled aircraft water systems to
determine whether current regulatory efforts were adequately protecting public health. In
addition, data processed under the AOCs from 2005 to 2008 for air carriers with an approved
QAPP and CRMP have been compiled. Collectively, the 2003, 2004, and AOCs' data represent
the Agency's understanding of existing aircraft water quality.
3.3.1 2003 Data Collection Effort
In October and November of 2003, ATA randomly sampled drinking water in 265
passenger aircraft, 89 of which originated from an international airport on the last route flown
prior to sampling. The aircraft were operated by eight U.S. air carriers, and the sampling was
performed under a voluntary program coordinated with EPA. EPA had reviewed the final
sample collection procedures for the study and all samples collected were, therefore, assumed to
be valid samples.
A summary of the ATA sampling data is presented in Exhibit 3.2. All samples met
regulatory requirements for nitrate, nitrite, and turbidity. Of the 265 samples collected, 2.6
percent tested positive for total coliform, but all tested negative for E. coli. A disinfectant
residual was non-detectable in 41 percent of samples. Of the 176 aircraft originating from
domestic locations, four (2.3 percent) samples tested positive for total coliform and 57 (32
percent) had a non-detectable disinfectant residual.11
10 It has not been determined that water heated in a galley coffee maker reaches temperatures high enough to kill all
harmful microorganisms.
11 Sampling downstream of in-line filters may affect sample results. The protocols for the 2003 data collection effort
specified that effort should be made to avoid sampling galley taps with installed filtration devices. However,
sufficient data is not available to determine if all samples were sampled upstream of any filtration device(s).
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit 3.2 Summary of 2003 ATA Sampling Data
Total Coliform-positive
E. co//-positive
Non-detectable Chlorine
Residual
All Samples
N = 265 aircraft
# of Aircraft
A
7
0
108
% Positive
B
2.6%
0%
41%
Samples from Aircraft Originating
from Domestic Location
N = 176
# of Aircraft
C
4
0
57
% Positive
D
2.3%
0%
32%
3.3.2 2004 Data Collection Effort
In 2004, EPA performed two rounds of coliform and disinfectant residual sampling of
aircraft. A total of 327 U.S. and foreign flag passenger aircraft were sampled. Exhibit 3.3
presents a summary of the data from these two rounds of sampling. This section provides further
discussion of these two data collection efforts.
Exhibit 3.3 Summary of 2004 EPA Sampling Data
Total Coliform positive
E. co// positive
Non-detectable Chlorine
Residual
Round 1
(August/September 2004)
N = 158 aircraft
# of Aircraft
A
20
2
39
% Positive
B
12.7%
1 .3%
24.7%
Round 2
(November/December 2004)
N = 169 aircraft
# of Aircraft
C
29
0
30
% Positive
D
17.2%
0.0%
17.8%
Notes:
1) A chlorine residual sample was not taken at one aircraft with total coliform-positive sample results.
The number of aircraft reported with non-detectable chlorine residuals does not include this aircraft.
2) Samples collected in Rounds 1 and 2 were collected in the U.S. from U.S. aircraft traveling both
domestically and internationally.
First Round of 2004 Data Collection Effort
EPA conducted a first-round of aircraft water quality sampling in August and September
2004. EPA sampled water quality at one or more galley water taps, water fountains, and lavatory
faucets on 158 U.S. and foreign flag passenger aircraft at seven U.S. airports.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
All samples in the first round data collection effort met regulatory requirements for
nitrate and nitrite. As shown in Exhibit 3.3, 12.7 percent of aircraft (20 aircraft) tested positive
for total coliform, and 1.3 percent (two aircraft) tested positive for E. coli. Additionally, 24.7
percent of the total number of aircraft sampled had non-detectable disinfectant residuals.12
Second Round of 2004 Data Collection Effort
EPA conducted a second round of aircraft water quality sampling during November and
December 2004. EPA sampled at one or more galley water taps, water fountains, and lavatory
faucets on 169 U.S. and foreign flag passenger aircraft at 12 U.S. airports.
As shown in Exhibit 3.3, in the second round data collection effort, EPA found that 17.2
percent of aircraft (29 aircraft) tested positive for total coliform. No E. coli was detected in the
second round, and 17.8 percent of the total number of aircraft sampled had non-detectable
disinfectant residuals.
3.3.3 Administrative Orders on Consent
Under the AOCs, air carriers have adopted and implemented monitoring and routine
water system disinfection and flushing procedures specified by EPA. Air carriers under AOCs
must implement regular monitoring and disinfection practices for all aircraft in their fleet for two
twelve month monitoring periods from the effective date of the AOC. A detailed discussion of
the requirements of the AOCs is provided in Chapter 2, Section 2.3.2. A summary of the
practices required by the AOCs is provided below:
. Perform coliform and disinfectant residual monitoring of aircraft water systems.
. Perform quarterly disinfection of aircraft water systems and water transfer
equipment owned by the air carrier.
Perform repeat sampling, disinfection and flushing, and follow-up sampling as
corrective action in the event that a routine sample is total coliform-positive.
. Provide public notification or turn off the aircraft's water in response to a total
coliform-positive sample.
Analyze all total coliform-positive sample culture media for the presence of fecal
coliforms or E. coli.
• Conduct a study of possible sources of contamination that exist outside the
aircraft, and supply information to EPA regarding various aspects of water
boarding practices.
12 Sampling downstream of in-line filters may affect sample results and sampling protocols would discourage
sampling downstream of such filters. However, sufficient data is not available to determine if all samples were
sampled upstream of or after the removal of any filtration device(s).
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
Data Collected Under AOCs
Each air carrier that is under an AOC is required to submit a CRMP and a QAPP. The
CRMP describes the air carrier's sampling and disinfection processes and protocols and is
designed to ensure samples are collected properly and within a 12-month period. Air carriers
that have a fleet of fewer than 20 aircraft were directed to sample all aircraft quarterly; air
carriers with a fleet of 20 or more aircraft were directed to sample each aircraft once per year.
The QAPP describes the air carrier's quality assurance and quality control (QA/QC) processes
and describes the methods used to collect and assess data.
Under the AOCs, air carriers collected total coliform and disinfectant residual samples
from at least one galley and lavatory on each aircraft in the first year. Air carriers continued
collecting monitoring data during subsequent years based on the monitoring and reporting
frequency established in their AOCs. As of December 31, 2008, EPA had processed data from
20,156 total coliform samples and 17,267 disinfectant residual samples from 25 air carriers
representing 78 percent of the estimated aircraft fleet under AOCs. These data may be indicative
of the effectiveness of rule requirements as of the date of this document, but data for air carriers
with an approved QAPP and CRMP are only available from two air carriers in 2005, five air
carriers in 2006, eight air carriers in 2007, and 12 air carriers in 2008. Therefore, insufficient
data is currently available to support statistical evaluation of the data. However, the data is used
to provide an observational indication of trends.
Appendix B summarizes the available sampling results from 2005 to 2008 for all air
carriers, and presents the routine and repeat data collected under EPA-approved QAPPs and
CRMPs. Of the QAPP and CRMP-approved data: during 2005, 137 (3.6 percent) of 3,819
samples tested positive for total coliform, and only one of the 137 samples also tested positive
for E. coli; in 2006, 143 (2.6 percent) of 5,570 samples tested positive for total coliform, and
seven of the 143 samples also tested positive for E. coli; in 2007, 266 (4.2 percent) of 6,351
samples tested positive for total coliform, and seven of the 266 samples also tested positive for E.
co//'; and in 2008, 255 (8.5 percent) of 2,984 samples tested positive for total coliform, and seven
of the 255 samples also tested positive for E. coli. See Section 3.3.5 and Appendix B for
additional details.
Historical Data Collected
In addition to ATA's and EPA's sampling efforts, a number of air carriers collected
monitoring data for various contaminants prior to their AOC. Several air carriers submitted data
collected within five years of their AOC to EPA. However, EPA did not analyze these data for
the ADWR since most air carriers did not specify their procedures, analytical methods, or
provide a QAPP.
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3.3.4 Disinfectant and Treatment Characterization for the Baseline
Of the 17,267 disinfectant residual sample events reported under the AOCs, 16,109
disinfectant residual sample results were collected under EPA-approved QAPPs and CRMPs and
comprise the disinfectant residual baseline for the ADWR. Under the AOCs, disinfectant
residual results were reported as either "detect" with the residual value recorded, or "non-detect."
Disinfectant residual data was not provided for 2,615 coliform sample events. Disinfectant
residual baseline data are presented for routine and repeat coliform sample collection events
because repeat samples have no higher or lower probability of having a detectable residual than
routine samples. Exhibit 3.4 presents processed data for disinfectant residual samples collected
under EPA-approved QAPPs and CRMPs during routine and repeat total coliform sampling
events for years 2005-2008.
Exhibit 3.4 AOCs Occurrence Baseline Data - Disinfectant Residual Samples
(Years 2005-2008)
Unknown Calendar Qtr
Calendar Qtr 1
Calendar Qtr 2
Calendar Qtr 3
Calendar Qtr 4
Total
Galley
Lavatory
Composite*
Unknown Sample Site
Total
Percent
Disinfectant
Residual Non-
detect
Total # of
Disinfectant
Residual Non-
detect
Total # of
Disinfectant
Residual
Detect
Total # of
Disinfectant
Residual
Samples
Disinfectant Residual Data by Calendar Quarter
0%
22.8%
9.3%
30.2%
21 .6%
18.2%
0
864
632
813
618
2,927
0
2,933
6,128
1,879
2,242
13,182
0
3,797
6,760
2,692
2,860
16,109
Disinfectant Residual Data by Sample Location
17.3%
18.9%
22.4%
0.0%
18.2%
1,336
1,518
73
0
2,927
6,386
6,530
253
13
13,182
7,722
8,048
326
13
16,109
For air carriers with approved QAPPs and CRMPs, 18.2 percent of the 16,109
disinfectant residual results processed from 2005 to 2008 reported a non-detectable disinfectant
residual. Non-detectable levels were similar in galleys (17.3%) and lavatories (18.9%), while
22.5 percent of the composite samples were non-detects. A sample location was not identified
for 13 samples with a detectable residual. In addition, the occurrence of non-detectable
disinfectant residuals increased in months with warmer weather. Quarter 3 (i.e., July to
September) had the highest percentage of samples with a non-detectable disinfectant residual
(30.2%).
Additional disinfectant residual information is found in Appendix B. Data in Appendix B
indicates that a non-detectable disinfectant residual appears to not be associated with an increase
in total coliform-positive samples. Of the 801 routine and repeat samples that were total
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
coliform-positive, 24 did not include any data on a disinfectant residual. Of the remaining 777
total coliform-positive routine and repeat samples, 584 samples (75%) had a detectable
disinfectant residual and 193 samples (25%) did not have a detectable disinfectant residual.
Twenty-one (3.6%) of the 584 total coliform-positive routine and repeat samples with a
detectable residual (the lowest measuring 0.05 mg/L) also tested positive for E. coli. Only one
(0.5%) of the 193 total coliform-positive samples that did not have a detectable residual tested
positive for E. coli.
Regarding existing onboard water treatment units, seventy three samples had non-
detectable disinfectant residual and were reported to have carbon filters installed on the water
lines to the sample tap; two of those samples were total coliform-positive. For comparison, 364
samples with detectable disinfectant residual were reported to use carbon filters; three of those
samples were total coliform-positive. Aside from charcoal/activated carbon and particle removal
filters in some galleys and lavatories, the majority of aircraft do not provide additional treatment
for boarded water.
3.3.5 Contaminant Occurrence for the Baseline
AOCs' sampling data under EPA-approved QAPPs and CRMPs from 2005 to 2008
analyzed by EPA as of December 31, 2008 show that 801 (4.3 percent) of 18,724 routine and
repeat samples tested positive for total coliform, and 22 (2.7 percent) of the 801 total coliform
positive samples tested positive for E. coli. (An additional E. coli positive sample tested
negative for total coliform and was omitted from the analysis.) Of the 22 samples that tested
positive for both E. coli, 18 were routine samples and four were repeat samples. Also, nine of
the 22 samples that were E. co//'-positive were collected from galleys and 13 were collected from
lavatories. One of the 22 samples was collected in 2005 and seven were collected in 2006, 2007,
and 2008, respectively. The 22 E. co//'-positive samples were collected from 17 different
aircraft; three of the repeat samples were collected from the same aircraft. A disinfectant
residual was detected in 21 of the E. co//'-positive samples; one routine sample did not detect a
disinfectant residual. Finally, last departure cities were provided for 21 of the 22 samples.
Information on whether water was boarded at the last departure city was not reported.
The occurrence of total coliform-positive andE. co//'-positive samples have varied from
year to year. The percent of samples that tested positive for total coliform from 2005 to 2008
were 3.6 percent, 2.6 percent, 4.2 percent, and 8.5 percent, respectively. Of these samples, the
percent that also tested positive for E. coli from 2005 to 2008 were 0.7 percent, 4.9 percent, 2.6
percent, and 2.7 percent, respectively. However, data in 2005 were only available for 745
aircraft from two air carriers (4.4 percent of all air carriers under AOCs), data in 2006 were
available for 1,246 aircraft from five air carriers (11.1 percent of all air carriers under AOCs),
data in 2007 were available for 1,255 aircraft from 8 air carriers (17.8 percent of all air carriers
under AOCs), and data in 2008 were available for 1,026 aircraft from 12 air carriers (26.6
percent of all air carriers under AOCs). All of the air carriers in these analyses were considered
large carriers under the criteria described in the screening analysis presented in Appendix D.
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October 2009
Exhibit 3.5 presents AOC data processed under EPA-approved QAPPs and CRMPs as of
December 31, 2008, for routine samples collected in years 2005-2008. These data comprise the
coliform occurrence baseline for the ADWR. As presented above, not all 25 air carriers
provided data collected under an approved QAPP and CRMP for all four years. Repeat total
coliform samples by nature have a higher probability of being positive since repeat samples are
taken after a routine sample is total coliform-positive. Consequently, the occurrence baseline for
total coliform and E. co//'/fecal coliform occurrence was based on routine samples only. Exhibit
3.5 presents data processed for routine total coliform samples collected under EPA- approved
QAPPs and CRMPs for years 2005-2008.
Exhibit 3.5 AOCs Occurrence Baseline Data - Routine Total Coliform Samples
(Years 2005-2008)
Unknown Calendar Qtr
Calendar Qtr 1
Calendar Qtr 2
Calendar Qtr 3
Calendar Qtr 4
Total
Galley
Lavatory
Composite*
Unknown Sample Site
Total
Percent TC+
Of the TC+
samples,
percent EC+
orFC+
Total # of
TC+
samples
Total # of
TC+
samples
that are
EC+ or FC+
Total # of
TC
Samples
Total Coliform Data by Calendar Quarter
0.0%
3.2%
3.5%
4.1%
4.1%
3.6%
0.0%
4.0%
3.5%
0.0%
8.1%
3.9%
0
100
198
79
86
463
0
4
7
0
7
18
0
3,145
5,641
1,930
2,078
12,794
Total Coliform Data by Sample Location
0.8%
5.9%
14.3%
3.1%
3.6%
12.8%
2.9%
0%
0%
3.9%
47
413
1
2
463
6
12
0
0
18
5,695
7,027
7
65
12,794
"Composite sample of Galley and Lavatory sources
Note: "TC+" means total coliform-positive; "EC+ or FC+" means £. co//-positive or fecal coliform-positive
Of the 20,156 total coliform samples processed, 93 percent or 18,724 samples (12,794
routine and 5,930 repeat samples) were from air carriers with an EPA-approved QAPP and
CRMP. Of the 12,794 routine samples, 3.6 percent (463 samples) were positive for total
coliform and 3.9 percent (18 samples) of the total coliform-positive samples were E. colii'fecal
coliform-positive. Of the 463 total coliform-positive routine samples, 413 were collected in the
lavatory, 47 were collected in the galley, and one was a composite sample of galley and lavatory
sources; the location of the remaining two positive results are unknown. However, although the
lavatory samples had a higher total coliform-positive occurrence rate (5.9%, or 413 of 7,027
lavatory samples) than the galley samples (0.8%, or 47 of 5,695 galley samples), the galley
samples have a higher E. co//'/fecal coliform occurrence of 12.8 percent (6 of 47 total coliform-
positive samples), compared to 2.9 percent (12 of 413 total coliform-positive samples) in the
lavatories.
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3.4 Uncertainties in the ADWR Baseline
Uncertainties in this baseline analysis are due to the limitation of available information.
These uncertainties contribute to uncertainties in the cost estimates presented in Chapter 5. The
most significant uncertainties in the ADWR baseline are related to the number of aircraft per air
carrier that are subject to the ADWR, each aircraft's passenger capacity, and the flight
frequencies of charter aircraft. Where aircraft information was not provided by the air carrier on
their Web site or annual report, or by the aircraft's manufacturer, aircraft capacity was based on
other similar aircraft models. This assumption may under- or over-estimate the number of
passengers per aircraft, as it does not factor in aircraft that are ordered to fit air carriers' specific
requirements. Similarly, when the number of lavatories and galleys was not specified, the
number of lavatories and galleys used was based on similar capacity aircraft. A carrying
capacity of 25 was assumed when aircraft type was not specified and the capacity could not be
obtained from a similar aircraft model. When two different models of an aircraft were used by
an air carrier and the passenger carrying capacity was not differentiated between the two, an
average carrying capacity was used.
Aircraft that clearly did not carry at least 25 passengers, 60 days per year were not
included in the baseline; however, there were some charter aircraft included in the baseline.
Those charter aircraft that exhibited a strong possibility of fitting the definition of a TNCWS
were included in the baseline. A weighted average flight frequency was calculated for the
charter flights included in the baseline based on known flight frequencies of other chartered
aircraft. Lastly, when only a weekly or yearly flight frequency was provided, 365 days per year
and 52 weeks per year were assumed.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
4. Benefits Analysis
4.1 Introduction
Three of the alternatives considered during the ADWR development process were
designed to provide more efficient methods for aircraft to comply with the NPDWRs than are
allowed by the baseline regulations, without compromising public health. The baseline
regulations were considered as the fourth alternative. The regulatory scenarios (i.e., the baseline
and alternatives) that were considered for aircraft to achieve compliance with NPDWRs were
designed to minimize the risk of potential adverse health outcomes from drinking water boarded
on aircraft.
This chapter examines the risk (and benefit) tradeoffs between compliance with existing
NPDWRs and the other alternatives considered during the regulatory development process. This
comparative analysis was presented in the Economic and Supporting Analysis document
developed for the proposed rule; however, EPA has updated this discussion and included the
final rule elements for the reader's convenience. Evaluations include a qualitative analysis that
compares the risks for each regulatory alternative as compared to baseline conditions. The
qualitative analysis uses EPA's best professional judgment, not quantitative data, to establish a
relative risk rating for each regulatory component. Potential additional benefits analyses as well
as non-quantified benefits of compliance with the regulatory alternatives are also discussed.
4.2 Relative Risks - Qualitative Analysis
From a public health perspective, full compliance with current regulations by typical
stationary TNCWS will result in minimal risk to public health. The existing NPDWRs have all
been vetted through separate evaluation processes that determined that the estimated public
health risks following implementation meet or exceed EPA criteria. As part of the evaluation
process for most NPDWRs, a quantified risk assessment is performed and quantified benefits
calculated using traditional risk assessment analyses.
Because aircraft water systems are mobile systems that may board water from multiple
sources over the course of a single day, the opportunity exists for contamination of the water to
occur during the water transfer and boarding process and for water quality in the aircraft water
system to deteriorate due to water age (see Chapter 1 for a discussion of the public health risks
addressed by the ADWR). As a result, some regulatory requirements appropriate for typical
systems (such as monthly monitoring for coliforms and repeat coliform sampling) are not as
useful for aircraft systems, and some voluntary activities (such as routine disinfection and
flushing of a water system) warrant a regulatory requirement for aircraft.
To perform quantified risk and benefits analyses for a regulatory alternative, a large
amount of data are needed for parameters such as contaminant occurrence (both frequency and
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concentration), health effects, and water consumption. Because of their unique characteristics,
the requisite data are not available for aircraft PWSs and the populations they serve: thus EPA
determined that a quantitative risk assessment (and associated benefits analysis) was not feasible.
Furthermore, since the goal of the ADWR is to tailor existing NPDWRs to the unique
characteristics of aircraft water systems, EPA determined that additional quantitative risk
assessments (and thus benefits analyses) were not necessary. Therefore, the discussion and
analysis in this chapter focus on the relative risks between the regulatory alternatives considered
for the ADWR and the baseline conditions.
4.2.1 Rule Implementation Activities
Rule implementation activities are expected to be similar under all regulatory
alternatives. These activities are primarily administrative in nature and include items such as
reading and understanding the rule, training, and development of reporting and recordkeeping
protocols. Because of the similarities in expected implementation activities under all regulatory
alternatives, they are not expected to have an observably different effect on overall risk relative
to current regulations.
4.2.2 Operator Certification Requirements
Because of potential impacts on airworthiness, all aircraft maintenance is required to be
performed by highly trained individuals under FAA oversight. These requirements are the same
for all regulatory alternatives considered, even in the absence of specific operator certification
requirements. Thus, there is no expected difference in risk between the alternatives for this
regulatory component.
4.2.3 Routine Monitoring - Coliform Bacteria
Current regulations require monthly monitoring for coliform bacteria in accordance with
the TCR. Since monitoring PWSs for every possible pathogenic organism is not feasible,
coliform organisms are used as indicators of possible source water and distribution system
contamination. All else being equal, any reduction in the frequency of routine monitoring
performed represents a potential increase in risk for water consumers. Relative to the monthly
coliform sampling in the current regulations, Alternative 2 (requirements similar to the AOCs)
proposes a decrease in routine monitoring frequency to annually, while Alternative 3
(requirements similar to WSG 29) proposes quarterly sampling or no sampling if the air carrier is
operating under an approved O&M plan. Thus, selection of Alternatives 2 or 3 represents a
potential increase in health risk to consumers of water onboard aircraft. For the final rule,
aircraft have four possible monitoring frequencies depending on the manufacturers'
recommended schedule for disinfection and flushing. One option requires monthly monitoring if
disinfection and flushing frequency is once per year or less. The other three options require
quarterly, twice annual, or annual monitoring combined with more frequent disinfection and
flushing frequencies. Under the final rule, those aircraft that monitor monthly will not see any
change in risk relative to current regulations. However, all other aircraft under this alternative
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will see a potential increase in health risk due to reduced monitoring, leading to an overall
potential increase in health risk for the routine monitoring component of the final rule.
When considering the relative risks posed by differences in sampling frequency for
aircraft PWSs, it is important to also consider the efficacy of sampling for these types of systems.
Because of the numerous fill and drain operations across a wide geographic area that are
common for aircraft water systems, the effectiveness of any sampling in identifying and
correcting problems is limited. In many cases, due to the lag times from sampling to getting
results, a positive coliform sample may be representative of water that has already been replaced
(possibly several times) by clean water from a different watering point or the cause of the
positive sample (e.g., biofilm sloughing) has already been cleared from the system. In cases
such as these, identification of the positive sample may result in little to no impact on public
health. On the other hand, sampling more frequently than monthly may be beneficial for
identifying trends for a particular aircraft, airport, or water source that could lead to health risk
reductions for that given entity. However, aircraft rely on the required use of watering points
that meet FDA regulations to board potable (finished) water that meets all of the NPDWRs.
Therefore, monitoring and treatment applied by the PWS supplying the watering point should
address all but aircraft water boarding and system-related health risks.
4.2.4 Repeat Monitoring - Coliform Bacteria
When a PWS receives notification of a total coliform-positive routine sample, it is
required to take repeat coliform samples. Alternatives 1 and 2 require four repeat samples to be
collected, Alternative 3 does not specify any repeat sampling, and the final rule gives aircraft the
option of taking three repeat samples or disinfecting and flushing the system as corrective action.
Unlike routine sampling where more frequent sampling can point to statistical trends,
repeat samples are more specific to identifying the extent of a particular contamination event. In
the absence of repeat monitoring, in the final rule the aircraft would proceed directly to a
corrective action. Within this context, repeat samples help to better define the problem and can
lead to more cost-efficient situational response (e.g., avoiding a potentially expensive corrective
action if repeat samples do not identify an ongoing problem). Because aircraft will either
determine that there is no ongoing problem (all repeat samples are negative) or take corrective
action, no change in risk relative to current regulations is expected for any of the regulatory
alternatives under consideration.
4.2.5 Additional Routine Monitoring - Coliform Bacteria
Because of the small size of the population served by aircraft PWSs, they are included
among other TNCWSs that are only required to take one monthly sample to comply with current
TCR requirements. For any system that has a total coliform-positive sample under the TCR, that
system must collect a minimum of five routine samples in the following month. The TCR allows
for the primacy agency to waive the requirement to collect five routine samples the next month
the system provides water to the public if the primacy agency has determined why the sample
was total coliform-positive and establishes that the system has corrected the problem or will
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correct the problem before the end of the next month the system serves water to the public. The
written documentation must describe the specific cause of the total coliform-positive sample and
what action the system had taken and/or will take to correct the problem.
For aircraft systems, the additional routine monitoring requirement equates to collection
of four additional samples in any month following a positive coliform sample under current
regulations (Alternative 1). Alternatives 2, 3, and the ADWR do not specify any requirements
for this additional routine monitoring. Alternatives 2 and 3 require disinfection and flushing of
the water system immediately following any total coliform-positive sample, thus presumably
meeting the criteria that the system has corrected the problem before the end of the next month
water is served to the public. The final rule gives aircraft the option of disinfecting and flushing
the system with follow-up monitoring, or performing repeat monitoring if one or more routine
sample is total coliform-positive. If any repeat sample is total coliform-positive, the aircraft
must disinfect and flush the system. If all repeat samples are coliform-negative, no corrective
action is required. For Alternatives 2, 3, and the ADWR, EPA is assuming the cause of the
positive coliform sample is either unknowingly boarding contaminated water, contamination
during the water boarding process, or water quality deterioration due to water age. In each case,
the practice of disinfection and flushing as corrective action, combined with frequently boarding
water from different locations minimizes the value of additional routine samples to indicate the
existence of an ongoing problem. This assumption may not capture all contamination problems
coming from the aircraft tap, tank, or distribution system. However, because the final rule
requires aircraft to either disinfect and flush, or collect repeat samples in response to a total
coliform-positive result, any potential increase in public health risk is anticipated to be small.
Thus, EPA assumes the lack of a requirement for additional routine monitoring under
Alternatives 2 and 3 results in minimal change in public health risk, and no more than a potential
slight increase in public health risk for the final rule (depending on whether the system opts to
disinfect and flush the system or collect repeat samples) relative to the current regulations. The
reasoning for and associated limitations on considering the magnitude of this increased risk are
similar to those discussed under routine monitoring in section 4.2.3 above.
4.2.6 Post Disinfection Monitoring - Coliform Bacteria
Under Alternative 1, the existing regulations, aircraft water systems do not have any
requirements for post disinfection coliform monitoring. Alternative 3 also does not require post
disinfection monitoring, thus there is no change in risk relative to Alternative 1. Alternatives 2
and the final rule do require post disinfection monitoring to verify the effectiveness of
disinfection procedures triggered by a total coliform-positive sample result. To the extent that
this verification prevents inadequate disinfection (and subsequent return of a contaminated water
system to service) risks will be reduced under these two alternatives. The reduction of risk
realized by post disinfection monitoring is expected to be valuable where the cause of the
contaminated sample was not mitigated by the disinfection process, such as when certain taps
required replacement, as reported by some air carriers at stakeholder meetings held during the
development of the proposed rule. The reduction of risk realized by post disinfection coliform
monitoring is expected to be minimal for aircraft overall.
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4.2.7 Routine Monitoring - Disinfectant Residual
Under Alternative 1, aircraft water systems are required to take monthly disinfectant
residual samples at the same time and place as routine and repeat coliform samples. Alternative
2 proposes reducing this sampling to annually to correspond with the annual routine coliform
monitoring requirements. Alternative 3 does not require disinfectant residual monitoring if the
system opts for the operations and maintenance program or if it performs coliform monitoring.
The final rule does not include a requirement for routine residual disinfectant monitoring.
As with coliform monitoring, any reduction in sampling frequency for a disinfectant
residual may result in an increased public health risk. Although some pathogens are resistant to
disinfection (e.g., Cryptosporidium), maintenance of a disinfectant residual still provides
important health protection within the water system. By monitoring more frequently for a
disinfectant residual, a typical water system operator can better ensure continuity of this
protection in the system. It is important to note, however, that while monitoring for a
disinfectant residual is not required under the ADWR, all aircraft are required to board finished
water that meets all NPDWRs, including disinfectant residual where applicable. Also, some
aircraft may board water from PWSs that use ground water that may not be required to have a
disinfectant residual. Thus, although there may be an increase in risk under the ADWR in
relation to Alternative 1 since disinfectant residual sampling is not required, the differential in
this risk is expected to be small.
4.2.8 Development and Implementation of an O&M Plan
All alternatives considered require basic O&M in compliance with FAA regulations to
ensure airworthiness of the aircraft. FAA requires O&M practices to follow manufacturers'
guidelines. Any FAA requirements regarding O&M are not changed under any of the
alternatives and will not impact relative risks. Additional O&M requirements imposed under
EPA jurisdiction are related to the proper maintenance and upkeep of equipment and are
consistent for Alternatives 1 and 2. For Alternative 3, aircraft have the option of following a
more prescriptive O&M plan in lieu of monitoring. The final rule requires development of
specific O&M plans. To the degree that more prescriptive O&M plans will better focus
maintenance activities on issues specific to aircraft water systems and help prevent more
problems from arising, Alternatives 3 and the final rule could result in a decrease in risk relative
to the existing regulations captured in Alternative 1. It is expected, however, that this decrease
would be minimal due to the O&M requirements already in place under FAA regulations.
4.2.9 Routine Disinfection and Flushing
The existing regulations composing Alternative 1 address routine disinfection and
flushing of distribution systems as one of several best available technologies (BATs) identified
in the TCR to protect the system from coliform bacteria contamination. As BATs, these are
optional procedures a PWS may or may not implement. Because of the unique nature and
operation of aircraft water systems, it is estimated that next to boarding only finished water that
meets all of the NPDWRs, periodic disinfection and flushing of the water system has the biggest
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effect on maintaining water quality and ensuring public health is protected. Disinfection and
flushing overcomes, to a large extent, the cumulative risks from boarding water from multiple
locations by effectively resetting the system on a regular basis. To the extent that the regulatory
alternatives increase the frequency of disinfection and flushing events, there is expected to be a
decrease in public health risk. Because information reported by air carriers suggests pre-AOCs'
disinfection and flushing frequencies varied greatly from monthly to every few years, a
requirement specifying the frequency for disinfection and flushing, and the preventive nature of
the activity, is expected to have the biggest effect in terms of the magnitude of change in risk.
4.2.10 Disinfection and Flushing as Corrective Action
Alternative 1 does not require specific corrective actions (i.e., disinfection and flushing)
following total coliform-positive samples. However, typical water system operations practices
suggest that aircraft would take some kind of action in response to more than one total coliform-
positive routine sample, or if any sample is E. co//'-positive under Alternative 1, even if the
actions are not specified in the regulations. For Alternatives 2, 3, and the ADWR, aircraft that
experience confirmed positive total coliform samples (one sample for Alternatives 2 and 3) or
one E. coli sample must13 perform corrective action which includes, at a minimum, disinfection
and flushing of the water system. Because disinfection and flushing corrective actions are
mandatory and/or occur at frequencies greater than those typical under Alternative 1, they result
in an overall decrease in risk for this regulatory component relative to Alternative 1.
4.2.11 Optional Supplemental Treatment
All three alternatives and the final rule allow for the use of appropriate supplemental
treatment onboard aircraft. In cases where such treatment is added to an aircraft, an additional
barrier against contamination will be provided and risks will decrease. However, because this is
an existing option that also applies to baseline conditions, there is no change in risk for any of
the alternatives relative to the baseline.
4.2.12 Sanitary Surveys/Self-Inspections
Alternative 1 requires sanitary surveys at least every 5 years. The final rule requires air
carriers to conduct self-inspections every 5 years and certify that they were completed. These
inspections will function in a manner similar to sanitary surveys and are expected to yield
comparable risk reduction. EPA may conduct compliance audits to ensure proper
implementation of rule requirements. Alternatives 2 and 3, however, do not have specific
requirements for sanitary surveys and, to the extent that problems that would normally be
uncovered during a sanitary survey are not found, may result in an increased risk.
13 Corrective action is not mandated under Alternative 3. However, for analysis purposes it is assumed that aircraft
would correct deficiencies in the same manner as under Alternatives 2 and the final ADWR.
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4.2.13 Public Notification
Public notification requirements are similar for all regulatory alternatives considered.
Any differences between the alternatives are minimal and not expected to have a measurable
impact on risk relative to the baseline alternative.
4.2.14 Overall Relative Risk
The discussions above describe relative risks in terms of individual components of the
regulatory alternatives and the ADWR. The overall change in risks from each alternative
relative to the Alternative 1 baseline are a result of the complex interaction of all regulatory
components. Based on the discussions presented above, EPA has used best professional
judgment to qualitatively estimate the relative risk of each regulatory alternative considered.
This assessment was made through collaboration with a wide range of drinking water and aircraft
experts, including public health scientists, engineers, administrators, and regulatory experts. The
consensus opinions resulting from the assessments are presented below for each alternative.
Alternative 2: Requirements Similar to the AOCs
Alternative 2 mirrors the requirements set forth in the AOCs. In consideration of the
regulatory components, the expert consensus is that the dominant factor affecting risk is the
periodic disinfection and flushing of aircraft water systems. This type of periodic maintenance is
important in an operating environment that is as variable as that of aircraft water systems.
Though there is currently no data on how large the marginal effect of increasing disinfection and
flushing frequency is, any increase in periodicity for this activity is expected to yield larger
health risk reductions compared to other regulatory components such as periodic monitoring.
Based on all the considerations discussed above, the expert consensus is that the overall
health risk remaining after Alternative 2 is most likely less than the baseline.
Alternative 3: Requirements Similar to Water Supply Guidance 29
The components of Alternative 3 are generally not as comprehensive as Alternative 2, yet
are similar for those components that are included in both. In particular, the disinfection and
flushing requirements are the same for a subset of aircraft in Alternative 3 (i.e., those that choose
to comply with an O&M plan in lieu of monitoring). Based on the similarities between
Alternatives 2 and 3, the same process and rationale were used to evaluate the two alternatives.
Thus, the expert consensus is similar: the overall health risk posed by Alternative 3 is most likely
less than the Alternative 1 baseline, though the magnitude of the difference is expected to be
smaller compared to Alternative 2 due to the flexibility in choosing between monitoring and an
O&M plan.
ADWR
The regulatory components of the final rule allow greater flexibility than Alternatives 2
and 3 with regard to disinfection and flushing. Thus, some aircraft will not perform disinfection
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and flushing as often as would be required under those alternatives. However, this is
compensated for by requiring more routine coliform monitoring in those situations. As a result,
the expert consensus is that the overall health risk posed by the final rule is most likely less than
the Alternative 1 baseline, and about the same as Alternatives 2 and 3.
4.3 Assessment of Potential Quantitative Relative Risk Analyses
In addition to the qualitative relative risk analysis presented above, EPA has considered
analyses for incorporating quantitative data into a relative risk analysis. However, EPA is
limited by the purpose, quality, and quantity of data available in developing meaningful analyses.
Any comparison of risk between the alternatives considered for the final rule requires robust data
that would support: 1) direct comparisons of the overall baseline conditions with the overall
conditions under each of the alternatives, or 2) comparisons of specific regulatory components
(i.e., disinfection and flushing frequencies) that could be used to compare the baseline and all
alternatives. See Chapter 3 for a more detailed description of available data.
The most recent data available that may represent baseline conditions are those from
EPA's 2004 data collection effort. These data suggest a cumulative total coliform-positive rate
of 15 percent for the aircraft sampled. Additional data that may inform the baseline are from the
2003 ATA data collection effort. These data suggest a 2.3 percent rate of total coliform-positive
samples for aircraft originating from domestic locations. Sufficient accompanying information is
not available for either of these studies to form the basis of more complex modeling and analysis
that could inform a quantitative relative risk estimate. In particular, information on items such as
maintenance histories, especially disinfection and flushing histories, of the sampled aircraft are
not available to inform an analysis. Because disinfection and flushing is a key component to
maintaining water quality, such information is vital for assessing differences in monitoring
results seen between these two data collection efforts as well as differences within each data set.
In addition, each of these data collection efforts represents a small fraction of the total aircraft
inventory, calling into question the representativeness of the data.
The data collected under the AOCs represent all aircraft in each air carrier fleet that
submitted data and are therefore more comprehensive than those collected under the efforts
mentioned above. However, these data are also subject to limitations that currently prevent their
use for a robust quantitative analysis. First, the AOCs' data collection was not developed with
the intent to inform risk analyses. The AOCs' data were intended to be used for assessing
compliance with the AOCs, and as such, the data elements collected may not provide the
parameters necessary for relative risk analyses. However, preliminary analysis of the data
indicates that they are more comprehensive and potentially useful for such purposes than the
2003 and 2004 data. Related to the intent of the AOCs' data collection, and more significant to
the ability to use the data in a meaningful analysis, is the ongoing nature of the data collection.
As of December 31, 2008, data have been received and analyzed for only 16 of the 45 air carriers
currently under AOCs. In addition, as described in Chapter 3, only some of those data were
collected under EPA-approved QAPPs and CRMPs. This small fraction of data processed to date
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under the AOCs, while more representative than the smaller data sets collected under the 2003
and 2004 efforts, is still not sufficient to ensure a representative analysis.
In the absence of rigorous statistical analyses, only general observations of the data can
be made, and only with adequate qualifiers. Because of the differences in conditions under
which AOCs' data were collected compared to the 2003 and 2004 data (i.e., quarterly
disinfection and flushing is being conducted under the AOCs), comparisons of these data sets
may inform the effectiveness of disinfection and flushing as a risk reduction strategy.
Comparison of the total coliform-positive rate of 15 percent from the 2004 EPA data with the
AOCs' rate of 3.6 percent for QAPP and CRMP-approved data may indicate some effectiveness
of the actions, specifically disinfection and flushing, required under the AOCs. However,
consideration of the 2003 ATA data tends to argue against this assumption since the differences
between these data results and those for the AOCs appear to be insignificant. There are many
other factors that could explain differences in the results that need to be considered. In addition
to the obvious uncertainties associated with the small sample sizes for each of the data sets,
influences of items such as water handling procedures, sampling procedures, water retention
times, and overall attentiveness to the water quality issues need to be considered.
Considering all of the issues discussed above, EPA has determined that it is not feasible
to perform a quantitative relative risk analysis at this time.
4.4 Non-quantified Benefits
In addition to the benefits associated with individual components of the ADWR, there
may be other benefits of the final rule that cannot be quantified with the information available.
These potential benefits are described below.
Because EPA has no information on illnesses and subsequent deaths that may have been
caused by drinking water onboard aircraft, it cannot determine the number of illnesses and deaths
that would be avoided. However, increased routine disinfection and flushing required under the
final option is expected to remove pathogens in the aircraft distribution system contributing to
endemic disease. Disinfection and flushing associated with corrective action is also expected to
inactivate or remove pathogens that may have entered the distribution system, resulting in
decreased illness and greater avoidance of death. By reducing cases of illness contracted through
exposure to aircraft water, the final option is also expected to reduce the occurrence of illness
passed through secondary spread. EPA expects that the addition of multiple barriers to
pathogens through monitoring and disinfection and flushing may reduce the likelihood of
waterborne disease outbreaks associated with aircraft PWSs.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
5. Cost Analysis
5.1 Introduction
This chapter presents an estimate of the national implementation and incremental costs of
the final ADWR as well as a brief qualitative discussion comparing costs to the potential
expected benefits of the final rule. The cost estimate, prepared by EPA, is a summation of air
carrier costs for complying with the ADWR components and EPA costs for implementing the
rule. Although existing air carrier industry practice may involve some activities required under
the ADWR, all costs incurred to comply with the final ADWR are considered additional or
incremental costs. Rule components include developing and implementing monitoring and O&M
plans; performing routine monitoring; disinfecting and flushing the aircraft water system; self-
inspections by air carriers with self-certification of their completion; compliance audits by EPA;
and reporting and recordkeeping requirements.
Public notification requirements are included in the ADWR; however, compliance with
those requirements is not included in these cost estimates as it is addressed under the Information
Collection Request for the Public Notification Rule. Because an update to the public notification
information collection request (ICR) was published before the ADWR was final, an estimate of
the burden associated with those costs has been included in the ICR for the final ADWR.
The detailed descriptions and analyses presented in this chapter focus on the final rule.
Overall implementation costs for the final rule are compared to summary costs of the other
alternatives considered during the regulatory development process. A comparison of the final
ADWR and the proposed rule (updated to 2008$) is also provided. Detailed costs for the
alternatives to the ADWR are presented in Appendix C.
Air carrier costs are estimated for different aircraft categories. The aircraft categories are
based on the number of available sampling points on the aircraft, but the number of sampling
points is used for information display purposes only and does not affect the cost estimates. For
purposes of this analysis it is assumed that, on average, all air carriers spend equal time
performing rule activities regardless of aircraft type or category.
EPA implementation costs include staff training on ADWR requirements, providing
technical assistance to air carriers, conducting compliance audits, reviewing monitoring reports,
and recordkeeping. EPA estimated unit costs for these various components using a cost model,
equipment price lists and quotes, wage rates from government sources (Bureau of Labor
Statistics (BLS)), stakeholder input, and other relevant assumptions used in economic analyses
performed for existing drinking water rules (e.g., the recently finalized Ground Water Rule).
The national costs are estimated using a model specifically developed for the ADWR.
The model uses Microsoft Excel software. The main advantage to this modeling approach is that
it effectively captures point estimates of all cost information and presents it in a transparent
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manner. This information forms the basis for examining impacts to air carriers and aircraft
PWSs.
The remainder of this chapter is organized as follows:
. Section 5.2 describes the general costing and compliance assumptions used to
estimate national implementation costs for the final ADWR.
Section 5.3 describes the methodology of projecting costs over a 25-year period
according to the ADWR compliance schedule, estimating the present value of
each cost, and annualizing each cost over a 25-year period.
Section 5.4 describes the methodology for developing costs for all rule activities.
. Section 5.5 presents passenger cost estimates.
Section 5.6 presents a discussion of non-quantified costs and uncertainties in cost
estimates.
Section 5.7 presents the total annualized implementation cost for the final ADWR
as well as the annualized incremental cost for the final rule.
. Section 5.8 presents a comparison of cost estimates for the final ADWR to
estimates for other rule alternatives considered and the proposed rule.
. Section 5.9 qualitatively compares the estimated costs for the final ADWR to the
potential expected benefits.
Section 5.10 discusses other economic measures.
5.2 General Cost Assumptions and Methodology
The ADWR Cost Model incorporates several baseline data elements, including the
numbers, models, and seating capacity of aircraft; number of available sampling points per
aircraft; and the number of flights per aircraft per year. Because many of the assumptions apply
not to air carriers but to aircraft, where appropriate, exhibits in this chapter use aircraft estimates.
Derivations of these baseline assumptions are discussed in Chapter 3. In addition, this section
discusses several additional baseline costing assumptions used as inputs to the ADWR Cost
Model including labor rates (Section 5.2.1) and laboratory fees (Section 5.2.2).
The ADWR cost model uses the air carrier baseline water quality data submitted by air
carriers to EPA for compliance with AOCs as described in Chapter 3, and assumptions regarding
labor hours, laboratory costs, and labor rates to generate point estimates for air carrier costs for
components of the final rule and each alternative. The model also includes Agency costs by rule
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component, which are costs incurred by EPA Headquarters and Regional offices to implement
the rule. Detailed breakouts of costs for the final rule generated by the cost model are presented
in this chapter. See Appendix C for detailed breakouts of costs for the other alternatives that
were considered during rule development.
5.2.1 Labor Rates
For costing purposes, EPA estimates the labor needs and hourly labor rates of air carrier
employees for three labor categories: managerial, clerical, and technical (see Exhibit 5.1). EPA
recognizes that there may be significant variation in labor rates across all air carriers. However,
for purposes of this analysis, EPA used national-level estimates from two resources: 1) the
Bureau of Labor Statistics Occupational Employment Survey (Air Transportation, May 2007)
and, 2) Occupational Employment Wages for Flight Attendants (May 2005). The 2005 document
for flight attendant wages was used because flight attendant wage data for 2006 and 2007 were
not available. To be consistent with other costs used in the cost model, all estimates were
converted to 2008 dollars for the analysis. The costs reflect a load factor of 1.5 to account for
benefits paid to air carrier workers based on the BLS Employer Costs for Employee
Compensation Report, June 2008 (BLS, 2008)14.
Exhibit 5.1 Loaded Labor Rates by Standard Occupational Classification (SOC)
Code (2008$)
SOC Code
Occupation
Mean Hourly Wage
Managerial
SOC 11 -3071
Transportation, Storage, and Distribution
Managers
$65.42
Clerical
SOC 43-601 4
Secretaries, Except Legal, Medical, and Executive
$22.50
Technical
SOC 39-6 031
SOC 53-7061
SOC 53-6 051
SOC 51 -9 061
SOC 53-6099
Flight Attendants
Cleaners of Vehicles and Equipment
Transportation Inspectors
Inspectors, Testers, Sorters, Samplers, and
Weighers
Transportation Workers
$41.72
$20.19
$42.86
$34.27
$28.41
Source: Bureau of Labor Statistics (BLS) Occupational Employment Survey, May 2007, Air Transportation 481000, http://www.bls.gov/data/.
Flight Attendants - Occupational Employment and Wages, May 2005. Flight attendants' wage data for 2006 and 2007 not available.
To estimate costs for many of the rule components, EPA used the transportation inspector
category because it was the highest-paid technical labor category. Various other technical and
managerial rates are also included in the model based on the rule component and related
activities. It should be noted the BLS labor rate for this labor category decreased from that
obtained from BLS and used for cost estimates for the proposed rule.
14 BLS Employer Costs for Employee Compensation Report, Table 9, June 2008. All workers in private industry.
Production, transportation, and material moving. Transportation and material moving subsector.
http://www.bls.gov/ncs/ect/home.htm
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
In developing Agency labor costs, EPA estimates the average hourly labor rate for salary,
overhead, and benefits for Agency staff to be $50.14. To derive this figure, EPA multiplied the
hourly compensation at General Schedule (GS)-12, Step 5 on the 2008 GS pay scale ($31.34) by
a benefits multiplication factor of 1.6 to account for overhead and benefits as specified in the
ICR Handbook (USEPA, 2005).
5.2.2 Laboratory Fees
A laboratory fee, or cost per sample, is associated with total coliform, disinfectant
residual, and turbidity monitoring. EPA estimated the cost of monitoring based on the use of a
commercial laboratory, as shown in Exhibit 5.2. EPA's estimate of the cost per total coliform
sample includes sampling burden, the analysis cost charged by the laboratory, and shipping and
handling. Disinfectant residual sampling and turbidity monitoring are not required under the
final rule but would be required under one or more of the alternatives evaluated. Disinfectant
residual samples and turbidity samples would be analyzed on-site; therefore, the cost per
disinfectant residual sample and turbidity sample includes only the sampling kit purchased by the
air carrier and the sampling and in-house analysis burden. It is estimated that all samples
requiring commercial laboratory analysis for each sampling event (e.g., two routine samples or
three repeat samples) will be shipped together to a laboratory between 20-30 miles from the
airport. The estimated burden required to collect samples reflects a national average. Individual
air carriers may realize collection burden that is either less than or greater than this average
depending on locations of the airports with respect to EPA-or State-certified laboratories, aircraft
schedules, and accessibility of sampling points in a particular aircraft. No additional costs are
assumed for installation of new sampling taps, since EPA assumes all aircraft are equipped with
existing taps for sampling.
Rates may vary due to regional variations in laboratory fees, the number of samples
processed (quantity discounts), and laboratory capacity. Although laboratory costs are often
lower for multiple samples, there are no estimates of the number of air carriers that may be able
to take advantage of this savings. Therefore, the rate used in this analysis may over estimate the
actual cost incurred by aircraft water systems.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
Exhibit 5.2 Laboratory Costs (2008$)
Item
TC Coliform Sample
Disinfectant Residual Sampling Kit
Shipping
Annual Equipment Replacement
One-time Equipment Purchase (3 refrigerators)
Portable 2 100P turbidimeterand accessories
Turbidimeter calibration kit
Turbidimeter secondary standards
Cost
$22.16
$2.96
$107.48
$219.00
$597.00
$858.00
$97.69
$124.00
Notes:
1) Estimated chlorine residual sampling kit costsfrom www.hach.com ($74 for 25 tests).
2) Assume shipping and annual equipment replacement costs are incurred bycoliform monitoring. Disinfectant residual samples will be analyzed
immediately and will not require shipping or refrigeration.
3) Assume 3 coolers ($33/cooler), 9 gel packs ($4/gel pack), and 2 calibrated thermometers ($42/thermometer) purchased per air carrier. Cost of
cooler and gel packfromwww.coleman.com. Cost of thermometer from https://www1.fishersci.com.
4) Assume 3 refrigerators ($199/refrigerator) purchased per air carrier twice in the 25-year evaluation period. Cost of refrigerator from
www.homedepot.com.
5) Sample analysis costs based on average costs from various EPA certified labs across the U.S.
6) Cost of 2100Pturbidimeter, calibration kit, and secondary standards from www.hach.com
5.3 Projecting and Discounting National Costs
Costs must be expressed in common units so they can be added together to calculate total
annual costs. For the ADWR, some activities occur once, such as preparing monitoring plans
and O&M plans. Other activities such as self-inspections are assumed to happen once every five
years. Because these activities do not occur instantly or simultaneously, and to make such values
comparable, the year or years in which all costs are expended must be determined and the costs
must be brought back to their present value. For the purposes of this analysis, one-time and
yearly costs were projected over a 25-year time period to coincide with and allow comparison
with other drinking water regulations. The present values of costs are calculated using discount
rates of 3 and 7 percent based on EPA policy and OMB guidance.15
Several adjustments are made to the cost estimates when costs are being used as part of
the national cost estimate. A summary of these adjustments is as follows:
. Project all undiscounted costs over a 25-year time horizon based on the rule
implementation schedule.
Calculate total present value costs using 3 and 7 percent discount rates.
Annualize the costs over 25 years using the same discount rates.
Appendix C contains results from each step above for the final rule. Exhibits C.12
through C. 14 show the nominal costs projected over the rule schedule and the present value of
15 The choice of an appropriate discount rate is a complex and controversial issue among economists and policy
makers. Therefore, the Agency compares streams of future national level costs and benefits using two alternative
discount rates, 3 and 7 percent. The underlying logic for each discount rate can be found in Guidelines for
Preparing Economic Analyses (USEPA, 2000).
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
each cost calculated to the expected year of rule implementation for the final rule as well as the
results for Alternatives 1, 2, and 3.
5.4 Derivation of Costs for Air Carriers and the Agency
This section presents the methodology and unit costs used to derive national costs for air
carriers and the Agency to perform the final ADWR-related activities, and a brief summary of
each rule component. Chapter 2 contains a detailed summary of the ADWR requirements. This
section is organized by rule component as follows:
5.4.1 Rule Implementation/Annual Administration
5.4.2 Sampling Plan
5.4.3 O&MPlan
5.4.4 Coliform Monitoring
5.4.5 Routine Disinfection and Flushing
5.4.6 Disinfection and Flushing as Corrective Action
5.4.7 Compliance Audit and Self-Inspection
This chapter uses baseline information presented in Chapter 3 as a starting point for
analysis of air carriers/aircraft subject to each rule component. Exhibit 5.3 presents key baseline
information on the number of persons served per year and the number of aircraft that is
referenced throughout this section. These aircraft are assumed to be TNCWSs that board
finished surface water. The aircraft inventory presented in Exhibit 5.3 represents the baseline for
rule activities that are applicable onboard the aircraft (monitoring, and disinfection and flushing).
Implementation and annual administration activities, development of monitoring and O&M
plans, and compliance audits will occur on an air carrier-wide basis. Exhibit 5.3 is stratified
according to the number of available sampling points per aircraft for data display purposes only.
For the purposes of analyses, each qualifying lavatory and galley on an aircraft is assumed to
have only one sampling tap.
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Exhibit 5.3 ADWR Aircraft and Population Baseline
ff ot Available sampling
Points
A
1
2
3
4
5
6
7
8
>9
Total
# of Aircraft
B
381
2,080
756
421
956
871
298
809
755
7,327
Total ff ot Available
Sampling Points
C=B*A
381
4,160
2,268
1,684
4,780
5,226
2,086
6,472
9,354
36,411
# of Onboard Staff/year
D
1,978,974
8,639,938
2,332,151
2,510,833
6,641,598
3,879,569
1,414,970
3,765,459
3,998,054
35,161,545
# of Passengers/year
E
24,980,980
104,430,089
22,935,259
51,846,929
158,813,021
91,360,628
34,239,869
93,648,921
126,176,568
708,432,263
Total ff ot Potentially
Affected Persons/year
F=D+E
26,959,953
113,070,026
25,267,410
54,357,762
165,454,619
95,240,197
35,654,839
97,414,380
130,174,622
743,593,809
Notes:
(A) Each qualifying lavatory and galley on an aircraft is assumed to have only one sampling point.
representative of the number of lavatories and galleys on an aircraft.
(B), (D), (E) Derived from Appendix B.
(C) Average number of sampling points used for > 9 sampling points size category.
Therefore, the number of available sampling points is
5.4.1 Rule Implementation and Annual Administration
5.4.1.1 Air Carriers
All air carriers subject to the ADWR will incur one-time costs that include time for staff
to read the rule and become familiar with its provisions and to train employees on rule
requirements. All 63 air carriers subject to the ADWR will perform implementation activities.
The technical labor rate presented in section 5.2.1 is used along with estimates of labor hours to
generate implementation costs for all air carriers. Based on previous experience with rule
implementation, EPA estimates that each air carrier would require 4 staff persons to spend 2
hours each for a total of 8 hours to read and understand the rule, and a total of 8 hours to train
personnel. These unit costs are presented in Exhibit 5.4.
Exhibit 5.4 Air Carrier Burden and Cost Estimates for Implementation
Compliance Activity
Read and Understand Rule
Train Personnel
Total
Labor Cost
($/hour)
A
$42.86
$42.86
One-time labor burden
(hours/air carrier)
B
8
8
16
Unit Cost
C=A*B
$ 343
$ 343
$ 686
Total Labor Burden
(hours)
D=B*63
504
504
1,008
Total Cost ($)
E=C*63
$ 21,600
$ 21,600
$ 43,201
Notes:
(1) Detail may not add due to independent rounding.
Sources:
(A) Air carrier labor costs from Exhibit 5.1. EPA used the transportation inspector category because it was the highest-paid technical labor category. Transportation
inspectors are assumed to have a technical background, as well as some management or oversight responsibility.
(B) Labor hours for start-up activities reflect EPA estimate.
(D), (E) National totals for all 63 U.S. air carriers subject to ADWR to perform implementation activities. Assumes all air carriers spend equal time performing
implementation activities, regardless of fleet size or aircraft type.
5.4.1.2 Agency
The Agency will incur administrative costs while implementing the ADWR. These
implementation costs are not directly required by specific provisions of ADWR alternatives, but
would be necessary for the Agency to ensure that the provisions of the ADWR are properly
carried out. The Agency will need to allocate time for their staff to establish and then maintain
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October 2009
the programs necessary to comply with the ADWR, including developing and/or modifying data
management systems to track new required air carrier reports. Agency burden estimates include
time for rule-implementation staff to read and understand the rule. The Agency will need to
develop a program to oversee inventory and sampling data submitted by air carriers. To manage
data received by air carriers, the Agency will also need to modify or develop data management
systems. In addition to training Regional staff who will be reviewing data and overseeing the
program, the Agency will need to sponsor administrative training for air carriers, similar to a
train-the-trainer session, to help air carriers understand their responsibilities under the rule.
Finally, the Agency will need to provide technical assistance when air carriers request help
implementing the rule. Time requirements for Agency activities are presented in Exhibit 5.5a
which lists the one-time activities required to start the program following promulgation of the
ADWR along with their respective costs and burden. Agency burden and cost estimates are
presented as distributed evenly between the 10 EPA Regional offices. However, some of these
tasks will be the responsibility of the EPA Headquarters office in Washington, D.C., and some
Regions will incur more costs than others due to the number of air carriers and aircraft based in
each Region.
Exhibit 5.5a Agency Burden and Cost Estimates for Implementation
Compliance Activity
Read and Understand Rule
Program Development
Modify/Develop Data Management Systems
Air Carrier Training and Technical Assistance
Staff Training
Total
Labor Cost
($/hour)
A
$50.14
$50.14
$50.14
$50.14
$50.14
One-time labor burden
(hours/Region)
B
8
40
115
80
40
283
Unit Cost
C=A*B
$ 401
$ 2,006
$ 5,767
$ 4,012
$ 2,006
$ 14,191
Total Labor
Burden (hours)
D=B*10
80
400
1,150
800
400
2,830
Total Cost ($)
E=C*10
$ 4,012
$ 20,058
$ 57,666
$ 40,115
$ 20,058
$ 141,908
Notes:
(1) Detail may not add due to independent rounding.
Sources:
(A) Agency labor costs from Section 5.2.1
(B) Labor hours for start-up activities reflect EPA estimate.
(D), (E) National totals for Agency (EPA Regions) to implement ADWR for 63 U.S. air carriers subject to ADWR. Assumes each region spends equal time performing
implementation activities, regardless of number of air carriers headquartered in their region, air carrier fleet size or aircraft type.
In addition to these one-time costs, the Agency will need to expend resources on
continuing administrative activities. On an annual basis, the Agency will have to provide
ongoing technical assistance to air carriers and to their own staff. The Agency already oversees
laboratory certification programs for the TCR, and it is not anticipated additional costs will be
necessary for this activity. Exhibit 5.5b lists these annual activities with their respective costs
and burden.
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Exhibit 5.5b Agency Burden and Cost Estimates for Annual Administration
Compliance Activity
Lab Certification
Ongoing Technical Assistance
Staff Training
Total
Labor Cost
($/hour)
A
$50.14
$50.14
$50.14
Labor
(hours/Region/year)
B
-
500
16
516
Cost ($/year)
C=A*B
$
$ 25,072
$ 802
$ 25,874
Total Labor
Burden
(hours/year)
D=B*10
-
5,000
160
5,160
Total Cost ($/year)
E=C*10
$
$ 250,720
$ 8,023
$ 258,743
Notes:
(1) Detail may not add due to independent rounding.
(2) No costs are associated with lab certification under the ADWR because it is not anticipated that the Agency will need to oversee lab certification programs in
addition to what is being done for the Total Coliform Rule.
Sources:
(A) Agency labor costs from Section 5.2.1.
(B) Labor hours for start-up activities reflect EPA estimate.
(D), (E) National totals for Agency (EPA Regions) to implement ADWR for 63 U.S. air carriers subject to ADWR. Assumes each region spends equal time performing
implementation activities, regardless of number of air carriers headquartered in their region, air carrier fleet size or aircraft type.
5.4.1.3 Annualized Costs for Rule Implementation/Annual Administration
Annualized costs estimates for air carriers and the Agency to perform implementation
activities for the final rule are presented in Exhibit 5.6.
Exhibit 5.6 Air Carrier and Agency Cost Estimates for Implementation and Annual
Administration ($Millions, 2008$)
Implementation
Annual Administration
Total
Air Carriers
Agency
Total
3%
$ 0.002
$
$ 0.002
$ 0.01
$ 0.24
$ 0.25
$ 0.01
$ 0.24
$ 0.25
Air Carriers
Agency
Total
7%
$ 0.004
$
$ 0.004
$ 0.01
$ 0.23
$ 0.25
$ 0.02
$ 0.23
$ 0.25
5.4.2 Sampling Plan
5.4.2.1 Air Carriers
Under the final rule, all air carriers subject to the ADWR will develop sampling plans to
satisfy rule requirements. The sampling plan will include the air carrier's monitoring frequency
and their disinfection and flushing frequency, and is assumed to include one plan to address the
entire aircraft fleet. EPA has estimated that each air carrier will require a total of 10 hours to
develop sampling plans for all qualifying aircraft in their fleet, regardless of fleet size or aircraft
type. This one-time labor burden also includes the initial submission of air carrier inventory
information. Sampling plans will be developed in years 1 and 2 of the 25-year compliance
period. Exhibit 5.7 presents air carrier burden and costs for sampling plan requirements.
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Exhibit 5.7 Air Carrier Burden and Cost Estimates for Sampling Plan
Com pliance Activity
Develop Sampling Plan per ADWR requirements and
Report Sampling Frequency
Total
Labor Cost
($/hour)
A
$42.86
One-time labor burden
(hours/air carrier)
B
10
10
Unit Cost
C=A*B
$ 429
$ 429
Total Labor Burden
(hours)
D=B*63
630
630
Total Cost ($)
E=C*63
$ 27,001
$ 27,001
Notes:
One-time labor burden for sampling plan includes initial submission of air carrier inventory information.
Sources:
(A) Air carrier labor costs from Exhibit 5.1. EPA used the transportation inspector category because it was the highest-paid technical labor category. Transportation
inspectors are assumed to have a technical background, as well as some management or oversight responsibility.
(B) Labor hours for developing sampling plans and reporting sampling frequency reflect EPA estimate. Assumes both disinfection and flushing frequency and monitoring
frequency will be reported in plan.
(D), (E) Assume all of the 63 U.S. air carriers subject to ADWR will develop sampling plans. Assumes all air carriers spend equal time developing sampling plans,
regardless of fleet size or aircraft type.
5.4.2.2 Agency
Agency costs for the final ADWR sampling plan requirements are assumed to be solely
administrative. The Agency will incur costs to review air carrier sampling frequencies. EPA
assumes the Agency will require a total of 5 hours to review each air carrier sampling frequency,
regardless of fleet size or aircraft type. This one-time labor burden also includes reviewing the
initial submission of air carrier inventory information. The Agency will review the sampling
frequency in years 1 and 2 of the 25-year compliance period, as they are received from air
carriers. Exhibit 5.8 presents Agency burden and costs for sampling plan requirements.
Exhibit 5.8 Agency Burden and Cost Estimates for Sampling Plan
Compliance Activity
Review Air Carrier Sampling Plan and Frequency
Total
Labor Cost
($/hour)
A
$50.14
One-time labor burden
(hours/air carrier)
B
4.5
4.5
Unit Cost
C=A*B
$ 226
$ 226
Total Labor Burden
(hours)
D=B*63
284
284
Total Cost ($)
E=C*63
$ 14,216
$ 14,216
Notes:
One-time labor burden for sampling plan includes reviewing initial submission of air carrier inventory information.
Sources:
(A) Agency labor costs from Section 5.2.1.
(B) Labor hours for reviewing sampling plans and frequency reflect EPA estimate.
(D), (E) Assume all of the 63 U.S. air carriers subject to ADWR will develop sampling plans. Assumes Agency spends equal time reviewing air carrier sampling plans,
regardless of fleet size or aircraft type.
5.4.2.3 Annualized Costs for Sampling Plan
Annualized costs for air carriers and the Agency to develop and review sampling
frequencies for the final rule are presented in Exhibit 5.9.
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Exhibit 5.9 Air Carrier and Agency Cost Estimates for Sampling Plan ($Millions,
2008$)
Sampling Plan
Total
Air Carriers
Agency
Total
3%
$ 0.002
$ 0.002
$ 0.001
$ 0.001
$ 0.002
$ 0.002
Air Carriers
Agency
Total
7%
$ 0.002
$ 0.002
$ 0.001
$ 0.001
$ 0.003
$ 0.003
5.4.3 O&M Plan
5.4.3.1 Air Carriers
Under the final rule, all air carriers subject to the ADWR will need to develop water
system O&M plans and practices with ADWR-specific requirements or update existing plans.
EPA assumes that each air carrier will require a total of 80 hours to develop water system O&M
plans and practices for all qualifying aircraft in their fleet, regardless of fleet size or aircraft type,
and to submit a statement to the Agency indicating that their O&M plan has been completed.
O&M plans and practices will be developed in years 1 and 2 of the 25-year compliance period.
Exhibit 5.10 presents air carrier burden and costs for O&M plan requirements.
Exhibit 5.10 Air Carrier Burden and Cost Estimates for O&M Plan
Compliance Activity
Update existing O&M manual and practices with ADWR
specific requirements and submit statement to Agency
indicating that O&M manual has been updated
Total
Labor Cost
($/hour)
A
$42.86
One-time Labor Burden
(hours/air carrier)
B
80
80
Unit Cost
C=A*B
$ 3,429
$ 3,429
Total Labor Burden
(hou rs)
D=B*63
5,040
5,040
Total Co st($)
E=C*63
$ 216,005
$ 216,005
Sources:
(A) Air carrier labor costs from Exhibit 5.1. EPA used the transportation inspector category because it was the highest-pa id technical labor category. Transportation inspectors are
assumed to have a technical background, as well as some management or oversight responsibility.
(B) Labor hours for developing and implementing O&M plan and submitting verification statement to Agency reflect EPA estimate.
(D), (E) 63 U.S. air carriers subject to ADWR will develop O&M plans. Assumes all air carriers spend equal time developing and implementing O&M plan, regardless of fleet size
or aircraft type.
5.4.3.2 Agency
O&M plans will be reviewed by the Agency as part of compliance audits and will not
require a separate Agency review. Therefore, EPA assumes there will be no additional cost
associated with reviewing O&M plans. However, the Agency will require 0.5 hour per air
carrier to review the statement submitted by the system indicating that the air carriers' O&M
manual has been completed. Exhibit 5.11 presents Agency burden and costs for O&M plan
requirements.
Page 5-11
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit 5.11 Agency Burden and Cost Estimates for O&M Plan
Compliance Activity
Review system submitted statement indicating thatO&M
manual has been updated
Total
Labor Cost
($/hour)
A
$50.14
One-time LaborBurden
(hours/air carrier)
B
0.5
0.5
Unit Cost
C=A*B
$ 25
$ 25
Total Labor Burden
(hours)
D=B*63
32
32
Total Cost($)
E=C*63
$ 1,580
$ 1,580
Sources:
(A) Agency labor costs from Section 5.2.1.
(B) Labor hours for reviewing verification statement reflect EPA estimate. Assumes O&M plan review will be completed as part of compliance audits.
(D), (E) 63 U.S. air carriers subject to ADWR will develop O&M plans. Assumes all Regional Agency offices spend equal time reviewing and approving O&M plan, regardless of
fleet size or aircraft type.
5.4.3.3 Annualized Costs for O&M Plan
Annualized costs estimates for air carriers and the Agency to comply with O&M plan
requirements for the final rule are presented in Exhibit 5.12.
Exhibit 5.12 Air Carrier and Agency Cost Estimates for O&M Plan ($Millions,
2008$)
O&M Plan
Total
Air Carriers
Agency
Total
3%
$ 0.01
$ 0.01
$ 0.0001
$ 0.0001
$ 0.01
$ 0.01
Air Carriers
Agency
Total
7%
$ 0.02
$ 0.02
$ 0.0001
$ 0.0001
$ 0.02
$ 0.02
5.4.4 Coliform Monitoring
5.4.4.1 Air Carriers
Under the final rule, all air carriers subject to the ADWR are required to perform
coliform monitoring for their aircraft. Coliform monitoring begins in year 3 and continues
throughout the 25-year evaluation period. An air carrier's coliform monitoring schedule is
determined by its disinfection and flushing frequency, which should be based on manufacturer's
recommendations. EPA is providing significant flexibility by allowing air carriers to choose
their monitoring frequency if there is no manufacturer's recommended frequency. See Section
5.4.5 for a detailed discussion on routine disinfection and flushing. For modeling purposes, EPA
assumes 30 percent of air carriers will monitor annually, 30 percent twice annually, 30 percent
quarterly, and 10 percent monthly, as shown in column D of Exhibit 5.13. Based on monitoring
data collected under the AOCs for air carriers with approved QAPPs and CRMPs, EPA assumes
that 3.6 percent of samples will be total coliform-positive (column E, Exhibit 5.13). EPA may be
over- or under-estimating the total number of total coliform-positive samples. Appendix B
provides a detailed breakdown of the air carrier monitoring data collected under the AOCs.
Air carriers are assumed to collect routine coliform samples immediately prior to routine
disinfection and flushing procedures whenever possible. This scheduling option allows any
subsequent corrective action disinfection and flushing procedures to be performed when the
aircraft is already out of service for the scheduled routine maintenance. The option also allows
Page 5-12
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
the disinfection and flushing procedure to count toward both the corrective action and routine
efforts as long as two follow-up coliform samples are collected after the disinfection and flushing
procedure to meet the corrective action requirements. EPA evaluated the opportunities aircraft
would have to apply this practice by comparing the frequency of routine coliform sampling to
the associated frequency of routine disinfection and flushing for the same option. Based on this
analysis, EPA assumes that 0 percent of aircraft monitoring annually and twice annually, 50
percent of aircraft monitoring quarterly, and 46 percent of aircraft monitoring monthly with a
total coliform-positive sample will collect three repeat samples within 24 hours of notification of
a total coliform-positive routine sample as an option to immediate corrective action (column G,
Exhibit 5.13); all other aircraft would perform immediate corrective action. Of those aircraft
collecting repeat samples, 5.7 percent are assumed to detect an additional total coliform-positive
(column F, Exhibit 5.13). The two follow-up samples required per aircraft that performs
disinfection and flushing as corrective action is included in the coliform monitoring cost estimate
(column I, Exhibit 5.13).
EPA assumes 0.5 hour for each coliform sample collection, processing, storage, and
shipping (column J, Exhibit 5.13). Therefore, the burden is assumed to be 1 hour for the two
samples collected for routine sampling, 1.5 hours for the three samples collected for repeat
sampling, and 1 hour for the two corrective action disinfection and flushing follow-up samples.
Although the ADWR allows aircraft with a single storage tank that is removed and drained daily
to collect only one routine sample, EPA has no data to determine the number of aircraft
addressed by this provision, and therefore, for this analysis assumed all aircraft will collect two
routine samples. No sample analysis burden is incurred by air carriers, since EPA assumes that
all coliform analysis will be conducted by an outside laboratory (column M, Exhibit 5.13). EPA
assumes each air carrier will purchase three refrigerators to store samples. Refrigerator costs are
assumed to occur twice during the 25-year evaluation period, in years 3 and 13. Additionally,
EPA assumes that each air carrier will purchase three coolers, nine gel packs, and two
thermometers every year to store, transport, and measure samples. Costs for the refrigerator and
shipping (and storage materials purchased for shipping) are solely attributed to coliform
monitoring. Shipping costs are estimated to be approximately $107 per sample set, which
consists of two routine samples, three repeat samples, and two follow-up samples.
Reporting and Recordkeeping for Coliform Monitoring
Under the final rule, air carriers are required to maintain maintenance logs and report
monitoring results to the Agency. The maintenance logs contain information on sampling
locations and results. EPA assumes air carriers will require 15 minutes for each of these
recordkeeping activities per sample set. Air carriers are also required to report their water
system inventory within 18 months of promulgation of the final rule and update that inventory
annually. The initial submission of inventory information is assumed to be submitted as part of
the sampling plan. EPA assumes air carriers will require 1 hour each year for annual inventory
updates.
Page 5-13
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit 5.13 Air Carrier Burden and Cost Estimates for Coliform Monitoring
# of Available
Sampling Points
A
1
2
3
4
5
i
1
1
>9
Total
# of Aircraft
B
38
2,08
75
42
95
87
29
80
75
7,327
Total # of Available
Sampling Points
OB" A
38
4,16
226
1,68
4,78
5,22
2,08
647
9 35
36,41
# of Available
Sampling Points
A
2
5
i
8
>9
otal
# of Available
Sampling Points
A
1
2
3
I
5
i
7
I
>9
"otal
# of Aircraft
B
381
2,080
756
421
956
871
298
809
755
7,327
Total # of Available
Sampling Points
OB'A
381
4,160
2 268
1 684
4,780
5,226
2,086
6,472
9,354
36,411
# of Aircraft
B
38
2,08
75
42
95
87
29
80
755
7,327
Total # of Available
OB'A
381
4 60
2 68
1 84
4 80
5 26
2 86
6/72
9 54
36,411
TC Samples
Routine Coliform
Monitoring
(samples/year)
D
2,515
13,728
4990
2,779
6,310
5,749
1,967
5339
4 983
48,35:
Routine Co iform
Monitor! ngTC+
(samplesfyear)
E=D"0.036
9
49^
180
100
207
7
192
179
1,74
Addtional Routine
Additiona TC+ Repeat Coliform Monitoring
(samplesfyear) (samplesfyear) (samplesfyear)
F G H
5 95 0
30 518 0
11 188 0
6 105 0
14 238 0
2 217 0
4 74 0
11 201 0
11 188 0
104 1,823 0
Corrective Action
Coliform Follow-up
Sample (post-
disinfection sample)
(samplesfyear)
1
129
702
255
142
323
294
101
273
255
2,474
TC Sampling
Samp ng Labor
Burden Tota Sampling
(hoursfsample) Burden (hoursfyear)
J K=J(D+G+H+I)
05 1,369
0 5 7,474
05 2717
05 1,513
05 3,435
05 3,130
05 1,071
05 2907
05 2713
26,328
Analysis
Analysis Labor
Burden
(hours/sample)
M
0
0
c
0
0
0
0
0
0
Periodic
Total Analysis Annual Unit Total Annual Equipment
Burden Unit Shipping Cost Total Shipping Cost Unit Analysis Cost Total Analysis Cost Equipment Cost (Sfair Equipment Cost Cost (Sfair
(hoursfyear) (Sf sample set) (Sfyear) (Sfsample (Sfyear) carrierfyear) (Sfyear) carrier)
N=M(T>G+I-H-|) 0 P=0(Df2+Gf3+hH-|f2) Q R=Q(T>G+I-H-|) S T U
<: 07 <: 145,446 S22 6 <: 60,682 <: 2 9 <: 77'.: 597
'.'• 07 '.'• 794,034 S22 6 '.'• 331,283 '.'• 2 9 '.'• 3,917 '.'• 597
<:'07 <: 288601 <:22'6 <: 120409 <: 2'9 <: 1424 <: 597
<: 07 <: 160716 <:22 6 <: 67053 <: 29 793 <: 597
<: 07 <: 364,950 S22 6 <: 52,263 <: 2 9 <: 1,800 <: 597
<: 07 <: 332,502 S22 6 <: 38,725 <: 2 9 <: 1,640 <: 597
<: 07 <: 113,761 <:22 6 <: 47,463 <: 2 9 <: 561 <: 597
'.', 07 '.', 308,833 S22 6 <: 28,850 <: 2 9 <: 1,523 <: 597
S 07 <: 288,219 S22 6 <: 20,249 <: 2 9 <: 1,422 <: 597
0 2,797,061 1, 66,977 13,797
Total Sampling
Cost (Sfyear)
L=K"AA
$ 46,922
$ 256,164
$ 93 106
$ 51,849
$ 117,737
$ 107,269
$ 36,700
$ 99 633
$ 92 983
902,363
Total Periodic
Equipment Cost
($)
V
$ 1,956
$ 10,677
$ 3881
$ 2 161
$ 4,907
$ 4,471
$ 1,530
$ 4,153
$ 3,876
$ 37,611
Recordkeeping Totals
Maintain
Maintenance Log
(hours/sample set)
W
0 25
0 25
025
Report Monitoring
Results
hoursfsample set)
X
0 25
025
025
025
025
025
025
025
0 25
Report Water System Report Water System Recordkeep ng and
nventoryfChanges Inventory/Changes Labor Cost Reporting Labor Recordkeeping Total Burden Total OSM Cost
(hoursfair carrier) Burden (hoursfyear) (Sfhour) (hoursfyear) Cost (Sfyear) (hoursfyear) (Sfyear)
AB=((W+X)"
Y Z AA (Df2+Gf3+H+ f2))+Z AOAB'AA AD=K+M+AB E=L+P+R+T+AC
00 3 28 S34 27 680 <: 23,303 2,049 <: 277, 07C
00 1788 S3427 3,712 <: 127,217 11,186 <: 1,512,615
00 650 S342 1,349 <: 46, 38 4,066 <: 549,777
00 362 S342 751 <: 25, 49 2,264 <: 306, 15£
00 822 S342 1,706 <: 58/7 5,141 <: 695,22
00 749 S342 1,554 <: 53, 72 4,684 <: 633,407
00 256 S342 532 <: 18, 26 1,603 <: 216,71
00 696 S342 1,444 !: 49/80 4,351 !: 588, 32C
00 649 S3427 347 <: 46 77 4 060 S 549 05C
63 448, 33 39,403 5,328,331
Total Capital
Cost ($)
AF=V
<: 1,956
<: 10,677
<: 3,881
<: 2,161
_ 4,907
<: 4,471
_ 1,530
<: 4,153
<: 3876
37,611
joiy
,ume 3 6% of coliform samples will be TC+ based on AOC data
;ume all analysis conducted by outside lab
), (Y) Based on EPA estimate
Page 5-14
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
5.4.4.2 Agency
Agency costs for the final ADWR coliform monitoring requirements are assumed to be
solely administrative. The Agency would incur costs to review aircraft monitoring results. EPA
assumes the Agency will require 0.5 hours to review each aircraft's coliform-positive monitoring
results. The Agency will review aircraft coliform monitoring results beginning in year 3 of the
25-year compliance period, as they are received electronically from air carriers.
The Agency will need to review all fleet inventory information submitted by air carriers,
which will include new inventory data and changes to the fleets. Air carriers must report their
water system inventory within 18 months of promulgation of the final rule and update that
inventory annually. The initial submission of inventory information is assumed to be reviewed
as part of the sampling plan. EPA assumes the Agency will require 0.5 hours to review each air
carrier's annual inventory updates. Exhibit 5.14 presents Agency burden and costs for coliform
monitoring.
Exhibit 5.14 Agency Burden and Cost Estimates for Coliform Monitoring
Compliance Activity
Review Aircraft Monitoring Results
Review Aircraft Water System Inventory Changes
Total
TC Samples
Labor Cost
($/hour)
A
$50.14
$50.14
Unit labor burden
(hours/TC+ sample or
air carrier)
B
0.5
0.5
1.0
Unit Cost ($/TC+
sample or air
carrier)
C=A*B
$ 25
$ 25
$ 50
Total Labor
Burden (hours)
D
870
32
902
Total Cost ($)
E
$ 43,648
$ 790
$ 44,437
Sources:
(A) Agency labor costs from Section 5.2.1.
(B) Labor hours for reviewing aircraft monitoring results reflect EPA estimate.
(D) Total labor burden for reviewing monitoring results = unit labor burden * total number of TC+ samples (Exhibit 5.13). Total labor burden for reviewing inventory =
unit labor burden * 63 air carriers.
(E) Total cost for reviewing monitoring results = unit cost * total number of TC+ samples (Exhibit 5.13). Total cost for reviewing inventory = unit cost * total burden for
reviewing inventory.
(F) Air carriers must report their water system inventory within 18 months of promulgation of the Final Rule and update that inventory annually. The initial submission
of inventory information is assumed to be reviewed as part of the sampling plan. This burden reflects only review of the annual inventory updates.
5.4.4.3 Annualized Costs for Coliform Monitoring
Annualized cost estimates for air carriers and the Agency to perform coliform monitoring
and review results for the final rule are presented in Exhibit 5.15.
Exhibit 5.15 Air Carrier and Agency Cost Estimates for Coliform Monitoring
($Millions, 2008$)
Coliform Monitoring
Total
Air Carriers
Agency
Total
3%
$ 4.89
$ 489
$ 0.04
$ 0.04
$ 4.93
$ 493
Air Carriers
Agency
Total
7%
$ 4.82
$ 4.82
$ 0.04
$ 0.04
$ 4.86
$ 4.86
Page 5-15
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
5.4.5 Routine Disinfection and Flushing
5.4.5.1 Air Carrier
Under the final rule, all air carriers subject to the ADWR are required to perform routine
disinfection and flushing of their aircraft. EPA is providing air carriers with significant
flexibility by allowing air carriers to choose their routine disinfection and flushing frequency if
there are no manufacturer's recommendations. Based on manufacturer's guidelines, air carriers
perform disinfection and flushing either quarterly, thrice annually, twice annually, or annually,
which will determine their coliform monitoring frequencies. When the frequency is not defined
by the water system manufacturer, air carriers will select the frequency they prefer. Section
5.4.4 provided a detailed discussion of coliform monitoring. For modeling purposes, EPA
assumed 30 percent of air carriers will perform disinfection and flushing quarterly, 30 percent
thrice annually, 30 percent twice annually, and 10 percent annually (column D, Exhibit 5.16).
Based on observation of aircraft disinfection and flushing practices, EPA assumes 5
hours per aircraft for routine disinfection and flushing (column F, Exhibit 5.16). Unit chemical
costs are assumed to be approximately $1.00 per application. EPA assumes air carriers currently
perform at least periodic disinfection and flushing of the aircraft water systems as part of their
maintenance programs; therefore, equipment costs have not been included in the estimated costs
of the ADWR.
Recordkeeping and Reporting
Under the final rule, air carriers are required to record routine disinfection activities.
EPA assumes air carriers will require 15 minutes for this recordkeeping activity per aircraft.
Page 5-16
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit 5.16 Air Carrier Burden and Cost Estimates for Routine Disinfection and Flushing
* of Available
Sampling Points
A
1
2
3
4
5
6
7
8
>9
Total
* of Aircraft
B
381
2,080
756
421
956
871
298
809
755
7,327
Total * of Available
Sampling Points
C=B*A
381
4,160
2,268
1,684
4,780
5,226
2,086
6,472
9,354
36,411
Routine Disinfection and Flushing
Routine Disinfection
and Flushing
(aircraft/year)
D
1,067
5,824
2,117
1,179
2,677
2,439
834
2,265
2,114
20,516
Self-Certification
(aircraft/year)
E
0
0
0
0
0
0
0
0
0
0
Routine Disinfection
and Flushing Labor
Burden
(hours/aircraft)
F
5
5
5
5
5
5
5
5
5
Self Certification Labor
Burden (hours/aircraft)
G
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
Unit Disinfection and
Flushing Cost ($/hour]
H
$20.19
$20.19
$20.19
$20.19
$20.19
$20.19
$20.19
$20.19
$20.19
Unit Self-Certification Cost
($/hour)
I
$65.42
$65.42
$65.42
$65.42
$65.42
$65.42
$65.42
$65.42
$65.42
Unit Chemical Costs
($/application)
J
$ 1
$ 1
$ 1
$ 1
$ 1
$ 1
$ 1
$ 1
$ 1
Total Routine
Disinfection and
Flushing Costs ($/year)
K=(D*F*H)+(D*J)
$108,855
$594,276
$215,997
$120,284
$273,139
$248,853
$85,142
$231,139
$215,711
$2,093,396
# of Available
Sampling Points
A
1
2
3
4
5
6
7
8
>9
Total
# of Aircraft
B
381
2,080
756
421
956
871
298
809
755
7,327
Total # of Available
Sampling Points
C=B*A
381
4,160
2,268
1,684
4,780
5,226
2,086
6,472
9,354
36,411
Recordkeeping
Total Cost for Self
Certification ($/year)
L=E*G*I
$
$
$
$
$
-
$
$
$
$0
Maintain Maintenance
Log for Disinfection
Activities Burden
(hours/aircraft)
M
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Maintain Maintenance
Log for Disinfection
Activities Burden
(hours/year)
N=D*M
267
1,456
529
295
669
610
209
566
529
Recordkeeping
Labor Cost ($/hour)
0
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
Maintain
Maintenance Log
for Disinfection
Activities Costs
($/year)
P=N*0
$ 9,141
$ 49,903
$ 18,138
$ 10,101
$ 22,936
$ 20,897
$ 7,150
$ 19,409
$ 18,114
$ 175,789
Totals
Total Routine
Disinfection/Flushing
Labor Burden
(hours/year)
Q=(D*F)+(E*G) + N
5,601
30,576
11,113
6,189
14,053
12,804
4,381
11,892
11,099
107,707
Total O&M Cost
($/year)
R=K+L+P
$ 117,996
$ 644,180
$ 234,135
$ 130,384
$ 296,075
$ 269,750
$ 92,291
$ 250,549
$ 233,825
$ 2,269,185
Total Capital
Cost ($)
S
$
Notes:
(C) Average number of available sampling points used for > 9 sampling points size category.
(D) Assume 30% of aircraft will perform routine disinfection and flushing quarterly, 30% of aircraft will perform routine disinfection and flushing thrice annually, 30% of aircraft will
perform routine disinfection and flushing twice annually, and 10% of aircraft will perform routine disinfection and flushing annually.
(E) Self-certification submittal not required under Alternative 4 (Final Rule).
(F) EPA estimate based on observation of flushing and disinfection practices.
(G) Labor hours for self-certification reflects EPA estimate.
(H) Based on costs for cleaners of vehicles and equipment from Exhibit 5.1.
(I) Based on costs for transportation, storage, and distribution managers from Exhibit 5.1.
(J) Chemicals used for disinfection cost approximately $1 per application (based on 12.5% chlorine solution from Harcros Chemicals, which costs $12 per 4 gallon jugs).
(M) Based on EPA estimate.
(O) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1.
Page 5-17
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
5.4.5.2 Agency
Under the final rule, the Agency is not required to assist air carriers with or perform
routine disinfection or flushing. Additionally, air carriers are not required to submit their records
to the Agency; the Agency may review these records during a compliance audit. Therefore, the
Agency will not incur costs for routine disinfection and flushing.
5.4.5.3 Annualized Costs for Routine Disinfection and Flushing
Annualized cost estimates for air carriers and the Agency to perform routine disinfection
and flushing for the final rule are presented in Exhibit 5.17.
Exhibit 5.17 Air Carrier and Agency Cost Estimates for Routine Disinfection and
Flushing ($Millions, 2008$)
Routine Disinfection and
Flushing
Total
Air Carriers
Agency
Total
3%
$ 2.08
$ 2.08
$
$
$ 2.08
$ 2.08
Air Carriers
Agency
Total
7%
$ 2.05
$ 2.05
$
$
$ 2.05
$ 2.05
5.4.6 Disinfection and Flushing as Corrective Action
5.4.6.1 Air Carrier
Under the final rule, EPA assumes that 100 percent of aircraft performing annual and
twice annual coliform monitoring, 50 percent of aircraft performing quarterly coliform
monitoring, and 54 percent of aircraft performing monthly coliform monitoring will perform
corrective action disinfection and flushing after a positive routine total coliform sample. As
described in Section 5.4.4, EPA assumes the remainder of aircraft with a total coliform-positive
routine sample will collect three repeat samples within 24 hours of notification of the total
coliform-positive routine sample result (column G, Exhibit 5.13). EPA assumes 5.7 percent of
aircraft performing repeat sampling will have at least one additional positive total coliform
sample and will perform corrective action.
EPA assumes that the corrective action disinfection and flushing procedure will be
conducted during routine disinfection and flushing events whenever possible, and therefore,
would not incur separate costs for corrective action disinfection and flushing events other than
the cost of collection, shipping, and analysis of two follow-up coliform samples required as part
of corrective action.
As a costing assumption, EPA assumes that of the aircraft with a positive routine
coliform sample, 0 percent of the aircraft performing annual, twice annual, and quarterly
monitoring, and 46 percent of aircraft performing monthly monitoring will not coordinate routine
and corrective action disinfection and flushing and will incur the full cost for corrective action
Page 5-18
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
disinfection and flushing. The estimated number of unique corrective action disinfection and
flushing events are shown in column D, Exhibit 5.18.
The estimated number of aircraft performing corrective action disinfection and flushing is
based on the assumption that during routine coliform monitoring no more than one of the two
samples would be total coliform-positive per aircraft. This assumption potentially overestimates
the number of aircraft that need to undergo disinfection and flushing as corrective action in cases
where both routine samples are total coliform-positive for an aircraft (i.e., an aircraft with
positive samples from both routine monitoring sampling points is treated as two corrective
actions in the cost model when only one disinfection and flushing event will be necessary in such
a case).
Based on observation of aircraft disinfection and flushing practices, EPA assumes 5
hours per aircraft for corrective action disinfection and flushing (column F, Exhibit 5.18). Unit
chemical costs are assumed to be approximately $1.00 per application. As noted for routine
disinfection and flushing procedures, equipment costs are not included as they are assumed to be
used for existing aircraft maintenance procedures.
Page 5-19
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit 5.18 Air Carrier Burden and Cost Estimates for Corrective Action Disinfection and Flushing
# of Available
Sampling Points
A
1
2
3
4
5
6
7
8
>9
Total
# of Aircraft
B
381
2,080
756
421
956
871
298
809
755
7,327
Total # of Available
Sampling Points
C=B*A
381
4,160
2,268
1,684
4,780
5,226
2,086
6,472
9,354
36,411
Corrective Action Disinfection and Flushing
Unique Corrective
Action Disinfection
and Flushing
(aircraft/year)
D
21
112
41
23
52
47
16
44
41
395
Repeat Disinfection
and Flushing
(aircraft/year)
E
0
0
0
0
0
0
0
0
0
0
Corrective Action
Disinfection and
Flushing Labor
Burden
(hours/aircraft)
F
5
5
5
5
5
5
5
5
5
Unit Disinfection and
Flushing Cost ($/hour)
G
$20.19
$20.19
$20.19
$20.19
$20.19
$20.19
$20.19
$20.19
$20.19
Unit Chemical Costs
($/application)
H
$ 1
$ 1
$ 1
$ 1
$ 1
$ 1
$ 1
$ 1
$ 1
Total Corrective Action
Disinfection and Flushing
Costs ($/year)
I=((D+E)*(F*G))+(D+E)*H)
$2,097
$11,446
$4,160
$2,317
$5,261
$4,793
$1,640
$4,452
$4,155
$40,318
# of Available
Sampling Points
A
1
2
3
4
5
6
7
8
>9
Total
# of Aircraft
B
381
2,080
756
421
956
871
298
809
755
7,327
Total # of Available
Sampling Points
C=B*A
381
4,160
2,268
1,684
4,780
5,226
2,086
6,472
9,354
36,411
Recordkeeping
Maintain Maintenance
Log for Disinfection
Activities Burden
(hours/aircraft)
J
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Maintain Maintenance
Log for Disinfection
Activities Burden
(hours/year)
K
16
88
32
18
40
37
13
34
32
Recordkeeping
Labor Cost ($/hour)
L
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
Maintain Maintenance
Log for Disinfection
Activities Costs ($/year)
M=K*L
$ 551
$ 3,009
$ 1,094
$ 609
$ 1,383
$ 1,260
$ 431
$ 1,170
$ 1,092
$ 10,600
Totals
Total Corrective Action
Disinfection/Flushing
Labor Burden
(hours/year)
N=((D+E)*F)+K
119
649
236
131
298
272
93
252
235
2,285
Total O&M Cost
($/year)
O=I+M
$ 2,648
$ 14,455
$ 5,254
$ 2,926
$ 6,644
$ 6,053
$ 2,071
$ 5,622
$ 5,247
$ 50,918
Total Capital
Cost ($)
P
$
Notes:
(C) Average number of available sampling points used for > 9 sampling points size category.
(D) Assume 100% of aircraft performing annual routine coliform monitoring, 100% of aircraft performing twice annual routine coliform monitoring, 50% of aircraft performing quarterly routine coliform monitoring, and 54% of aircraft performing monthly routine coliform monitoring will perform corrective action
disinfection and flushing after a positive routine total coliform sample. Assume the remainder of aircraft with a TC+ sample will perform repeat sampling. Assume 5.7% of aircraft performing repeat sampling will have at least one additional TC+ sample and will perform corrective action. Additionally, of the aircraft
with routine coliform monitoring coliform TC+ samples, assume 0% of the 100% of aircraft performing annual routine coliform monitoring coliform, 0% of the 100% of aircraft performing twice annual routine coliform monitoring, 0% of the 50% of aircraft performing quarterly routine coliform monitoring, and 46% of
aircraft performing monthly routine coliform monitoring will incur costs for corrective action disinfection and flushing. Remainder of aircraft performing corrective action disinfection and flushing assumed to coordinate schedule with routine disinfection and flushing schedule, and therefore do not incur separate costs
for corrective action disinfection and flushing. Assume entire aircraft flushed if either lavatory or galley has a positive total coliform sample. Assume no more than one TC+ per aircraft.
(E) Assumes first flushing/disinfecting is successful.
(F) EPA estimate based on observation of flushing and disinfection practices.
(G) Based on costs for cleaners of vehicles and equipment from Exhibit 5.1.
(H) Chemicals used for disinfection cost approximately $1 per application (based on 12.5% chlorine solution from Harcros Chemicals, which costs $12 per 4 gallon jugs).
(J) Based on EPA estimate.
(K), (M) Recordkeeping burden and costs based on total number of corrective action disinfection and flushing events + repeat disinfection and flushing events. Total number of corrective action disinfection and flushing events derived from Exhibit 5.13, column I.
(L) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Recordkeeping and Reporting
Under the final rule, air carriers are required to maintain a maintenance log for corrective
action disinfection activities. EPA assumes air carriers will require 15 minutes for this
recordkeeping activity per event per aircraft.
5.4.6.2 Agency
Under the final rule, the Agency is not required to assist air carriers with or perform
corrective action disinfection or flushing. Additionally, air carriers are not required to submit
their maintenance logs to the Agency. Therefore, the Agency will not incur costs for corrective
action disinfection and flushing but may include review of theses records during compliance
audits.
5.4.6.3 Annualized Costs for Corrective Action Disinfection and Flushing
Annualized cost estimates for air carriers and the Agency to perform disinfection and
flushing as corrective action for the final rule are presented in Exhibit 5.19.
Exhibit 5.19 Air Carrier and Agency Cost Estimates for Corrective Action
Disinfection and Flushing ($Millions, 2008$)
Corrective Action
Disinfection and Flushing
Total
Air Carriers
Agency
Total
3%
$ 0.05
$ 0.05
$
$
$ 0.05
$ 0.05
Air Carriers
Agency
Total
7%
$ 0.05
$ 0.05
$
$
$ 0.05
$ 0.05
5.4.7 Self-Inspection and Compliance Audit
5.4.7.1 Air Carrier
Under the final rule, all air carriers subject to the ADWR will undergo compliance audits
at the Agency's discretion, which is assumed to be once every five years, beginning in year 3 of
the 25-year compliance period. Compliance audits will involve a detailed review of each air
carrier's aircraft records, including their O&M plan. EPA expects that air carriers will incur a
recordkeeping and reporting burden while assisting Agency staff with conducting compliance
audits and in reporting that self-inspections were completed. EPA assumes that each air carrier
will require 24 hours to satisfy recordkeeping and reporting requirements under the compliance
audit and self-inspection rule provision (column E, Exhibit 5.20).
EPA anticipates that the labor burden for self-inspections is already captured under FAA
requirements and, therefore, is not included in the cost estimate for self-inspections. EPA
assumes that air carriers already conduct major maintenance checks, which include components
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
of self-inspections, every five years for each aircraft. Therefore, with the exception of reporting
and recordkeeping burden, no additional costs for self-inspections are incurred by air carriers
under the ADWR (see Exhibit 5.20). The cost model assumes that 20 percent of the air carrier
labor cost is incurred each year, beginning in year 3 of the 25-year compliance period.
Exhibit 5.20 Air Carrier Burden and Cost Estimates for Compliance Audit and
Self-Inspection
# of Available Sampling Points
A
1
2
3
4
5
6
7
8
>9
Total
# of Aircraft
B
381
2,080
756
421
956
871
298
809
755
7,327
Reporting and
Com
Total # of
Available
Sampling Points
C=B*A
381
4,160
2,268
1,684
4,780
5,226
2,086
6,472
9,354
36,411
Recordkeeping Costs Associated with
Dliance Audit of Aircraft PWS
Unit Labor Cost
(Wiour)
D
$42.86
$42.86
$42.86
$42.86
$42.86
$42.86
$42.86
$42.86
$42.86
Unit labor burden
(hours/air carrier)
E
24.0
24.0
24.0
24.0
24.0
24.0
24.0
24.0
24.0
Totals
Total Labor Burden
(hours/audit cycle)
F
78.62
429.23
156.01
86.88
197.28
179.74
61.50
166.95
155.80
1,512
Total O&M Cost (S/audit
cycle)
G=D*F
$ 3,370
$ 18,396
$ 6,686
$ 3,723
$ 8,455
$ 7,703
$ 2,636
$ 7,155
$ 6,677
$ 64,801
Total Capital
Cost ($)
H
$
$
$
$
$
$
$
$
$
$
Sources:
(D) Air carrier labor costs from Exhibit 5.1. EPA used the transportation inspector category because it was the highest-paid technical labor category. Transportation inspectors are assumed to have a technical
background, as well as some management or oversight responsibility.
(E) Labor burden reflects EPA estimate for reporting and recordkeeping only. EPA assumes that air carriers already conduct major maintenance checks, which include sanitary survey components, every 5 years
for each aircraft. Therefore, with the exception of reporting and recordkeeping burden, no additional costs for sanitary surveys are incurred by air carriers under the ADWR.
(F), (G) All aircraft undergo compliance audits once in 5 years. The Agency will review electronic data for all aircraft at the air carrier office site. Fractional costs incurred by aircraft (assuming even distribution
across aircraft of all sizes) are represented in the exhibt for presentation and calculation purposes only.
5.4.7.2 Agency
Under the final rule, the Agency or designated agents of the Agency will perform
compliance audits of air carriers. For purposes of this analysis, it is estimated that the Agency
will conduct compliance audits at least every five years for each air carrier, beginning in year 3
of the 25-year compliance period. EPA assumes that an Agency will require 16 hours to conduct
a compliance audit for each air carrier, regardless of fleet size or aircraft type (column B, Exhibit
5.21). Labor hours for conducting the audit include on-site and Agency recordkeeping efforts.
The cost model assumes that 20 percent of the Agency labor cost in column E of Exhibit 5.21 is
incurred each year, beginning in year 3 of the 25-year compliance period.
Exhibit 5.21 Agency Burden and Cost Estimates for Compliance Audit
Compliance Activity
Conducting Compliance Audit of Aircraft PWSs
Total
Labor Cost
($/hour)
A
$50.14
Unit Labor Burden
(hours/air carrier)
B
16
16
Unit Cost ($/air
carrier)
C=A*B
$ 802
$ 802
Total Labor Burden
(hours/audit cycle)
D=B*63
1,008
1,008
Total Labor Cost ($/audit
cycle)
E=C*63
$ 50,545
$ 50,545
Sources:
(A) Agency labor costs from Section 5.2.1.
(B) Labor hours for conducting compliance audits reflect EPA estimate.
(D), (E) Total burden and O&M costs for conducting compliance audits for 63 U.S. air carriers subject to ADWR. All aircraft undergo compliance audits once in 5 years.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
5.4.7.3 Annualized Costs for Compliance Audit
Annualized cost estimates for air carriers and the Agency to perform compliance audits
for the final rule are presented in Exhibit 5.22.
Exhibit 5.22 Air Carrier and Agency Cost Estimates for Compliance Audit
($Millions, 2008$)
Compliance Audit
Total
Air Carriers
Agency
Total
3%
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.02
$ 0.02
Air Carriers
Agency
Total
7%
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.02
$ 0.02
5.5 Estimated Costs to Air Carrier Passengers
EPA assumes that air carriers will pass on some or all of the costs of a new regulation to
their passengers in the form of ticket price increases. EPA estimates that 708.4 million
passengers travel each year on aircraft that are affected by the ADWR (column E, Exhibit 5.3).
Exhibit 5.24 in Section 5.7 estimates air carriers' total annualized cost of the ADWR to be $7.04
million using a 3 percent discount rate, and $6.95 million using a 7 percent discount rate. The
cost passed on to passengers can be roughly estimated by dividing the air carriers' annualized
costs incurred by the number of passengers traveling each year. Based on this approximation,
EPA estimates that passengers could face a relatively negligible increase of one cent per ticket.
5.6 Non-quantified Costs and Uncertainties in Cost Estimates
5.6.1 Non-quantified Costs
Although EPA has estimated the majority of costs of the final ADWR, there are some
costs that the Agency was not able to quantify, such as:
Air carrier costs due to unanticipated flight interruptions from aircraft water
system corrective action maintenance needs. This includes the direct costs related
to transporting an aircraft to a maintenance facility for the performance of
disinfection and flushing corrective action events and any indirect costs of
schedule disruptions or delays if an aircraft must be unexpectedly taken out of
service.
. Passenger costs due to flight cancellations or delays related to unanticipated
aircraft water system maintenance triggered solely by water quality issues.
Air carrier costs to provide bottled water and any antiseptic hand gels or wipes
due to lack of onboard tap water during an acute coliform violation.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Air carrier customer service response to customer concerns following public
notification that the water onboard an aircraft is not to be used for human
consumption.
EPA has attempted to minimize costs by building flexibility into the ADWR, including
various alternatives from which air carriers select compliance scenarios that best meet their flight
schedules and other routine aircraft operations and maintenance needs. The final rule also
includes provisions that minimize situations in which an aircraft is taken out of service solely
due to drinking water system water quality issues, but which are necessary to protect consumers
from water of unacceptable quality when the system cannot be physically shut-off or the flow
through the taps cannot be prevented.
Exhibit 5.23 presents the number of monitoring and disinfection and flushing events per
year for all of the alternatives considered during rule development and the final ADWR. EPA
assumes coliform monitoring and routine disinfection and flushing of the water system would
not disrupt service because the air carrier would incorporate these tasks into the aircraft
operations and maintenance program. Only the unanticipated corrective action disinfection and
flushing events shown in Column E of the exhibit reflect the events that the Agency anticipates
could result in disruption to air carrier schedules for all regulatory alternatives. Alternative 1
does not have such events because the current regulations to not specify a corrective action for
contaminated water systems, although it is anticipated some action is taken by the air carrier to
correct the problem.
Exhibit 5.23 Summary of Monitoring and Disinfection and Flushing Events for All
Alternatives
Rule Alternative
AIM
Alt 2
Alt3
Alt 4 (Final Rule)
Monitoring
Routing Monitoring
Coliform Sampling
Events/year
A
87,924
7,708
14,654
25,436
Disinfectant Residual
Monitoring Sampling
Events/year
B
87,924
7,708
-
-
Total number of
sampling events/year
C=A+B
175,848
15,416
14,654
25,436
Disinfection and Flushing
Routine Disinfection
and Flushing
Events/year
D
29,308
29,308
20,516
Corrective Action
Disinfection and
Flushing Events/year
E
528
528
395
Total number of
disinfection and
flushing events/year
F=D+E
29,836
29,836
20,911
(E) The number of potential unanticipated corrective action disinfection and flushing events is shown for the
Alternatives, all other disinfection and flushing events, whether based on a routine schedule or in response to
monitoring results, would occur during scheduled water system operations and maintenance.
Of the corrective action disinfection and flushing events noted in Column E, an unknown
percentage will not disrupt service because the aircraft will either prevent public access to the
water by shutting-off the system or preventing water flow through the taps, thereby obtaining
more flexibility with the corrective action disinfection and flushing schedule, or will perform the
action within the maximum time frame specified by the rule. In addition, of the alternatives that
would require disinfection and flushing, Alternative 4 (the final rule) has the least number of
estimated unanticipated disruption events (an estimated maximum of 395 corrective action
disinfection and flushing events/year).
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
EPA does not have sufficient data to quantify the disruption to air carriers; however,
EPA believes that the disruption cost per event would be lower for the final rule compared to
Alternatives 1-3 due to the significant flexibility offered to air carriers in choosing monitoring
frequencies under the final rule. EPA assumes that the increased flexibility of the final rule will
allow air carriers to schedule routine monitoring and disinfection and flushing to coincide with
existing routine maintenance checks. This will in turn decrease potential disruption to air carrier
flight schedules and thus decrease air carrier burden and cost for complying with ADWR
monitoring and disinfection and flushing requirements. Therefore, if disruption costs were
included in the quantified costs of the rule, the costs for the final rule would likely decrease with
respect to other alternatives.
5.6.2 Uncertainties in Cost Estimates
Many factors contribute to uncertainty in the national cost estimates including:
Percent of aircraft that will be subject to each total coliform monitoring option.
. Expected results from total coliform monitoring.
. Estimated time for air carrier management to read, understand, and decide how to
best comply with the ADWR; and to develop a training program, train staff, and
oversee compliance.
. Percent of aircraft that will collect routine total coliform samples while aircraft are
out of service for routine maintenance.
Labor burden necessary for self-inspections above what is necessary for FAA-
related inspections.
. Labor burden and costs associated with correcting significant deficiencies that are
identified during self-inspections above what is necessary for FAA-related
inspections.
For simplicity, EPA assumed for this analysis that all air carriers subject to the final rule
will spend equal management time on ADWR requirements, regardless of fleet size or aircraft
type. Assuming equal burden for all air carriers to comply with these rule management and
oversight requirements could result in an over- or under-estimate of the costs presented.
Regarding the expected results for coliform monitoring, EPA assumed that during routine
coliform monitoring, each total coliform-positive sample would prompt an action by the air
carrier. This assumption potentially over-estimates the number of aircraft that need to undergo
disinfection and flushing as corrective action or repeat monitoring in cases where more than one
routine sample is total coliform-positive in a given monitoring period. For example, an aircraft
with positive samples from both routine sampling points is treated as two corrective actions or
repeat sample collection events in the cost model when only one disinfection and flushing event
would be necessary in such a case. Also, the number of sample results that prompt corrective
action or repeat sampling may decrease over time as air carriers correct problems that lead to
total coliform-positive samples.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
In developing costs for air carriers to comply with the self-inspection requirements, EPA
assumed that with the exception of reporting and record-keeping burden, no additional costs for
self-inspections are incurred by air carriers. Labor burden for self-inspections, which involves a
thorough review and inspection of an aircraft water system as well as addressing any
deficiencies, is already captured under current FAA requirements and therefore is not included in
the cost estimate for this rule. Additionally, EPA has assumed that deficiencies noted during
self-inspections will be addressed during routine maintenance, and so has not accounted for costs
associated with corrective actions stemming from deficiencies noted during self-inspections.
This assumption potentially under-estimates air carrier burden for self-inspections.
5.7 Total Annualized Implementation and Incremental Costs for the Final
ADWR
Exhibit 5.24 presents the itemized and total annualized implementation costs to air
carriers and the Agency for the final ADWR at 3 and 7 percent discount rates. Note that portions
of Exhibit 5.24 have been presented in sections throughout this chapter, but are being repeated
here for convenience.
Exhibit 5.24 Total Annualized Present Value Implementation Costs for the Final
ADWR ($Millions, 2008$)
Implementation
Annual Administration
Sampling Plan
O&M Plan
Coliform Monitoring
Routine Disinfection and
Flushing
Corrective Action
Disinfection and Flushing
Compliance Audit
Total
Air Carriers
Agency
Total
3%
$ 0.002
$
$ 0.002
$ 0.01
$ 4.89
$ 2.08
$ 0.05
$ 0.01
$ 7.04
$ 0.01
$ 0.24
$ 0.001
$ 0.0001
$ 0.04
$
$
$ 0.01
$ 0.30
$ 0.01
$ 0.24
$ 0.002
$ 0.01
$ 4.93
$ 2.08
$ 0.05
$ 0.02
$ 7.34
Air Carriers
Agency
Total
7%
$ 0.004
$
$ 0.002
$ 0.02
$ 4.82
$ 2.05
$ 0.05
$ 0.01
$ 6.95
$ 0.01
$ 0.23
$ 0.001
$ 0.0001
$ 0.04
$
$
$ 0.01
$ 0.30
$ 0.02
$ 0.23
$ 0.003
$ 0.02
$ 4.86
$ 2.05
$ 0.05
$ 0.02
$ 7.25
Exhibit 5.25 presents the annualized incremental costs for the final rule at 3 and 7 percent
discount rates. The incremental costs represent the difference in total costs between the baseline
(i.e., the existing NPDWRs) and the final rule provisions. EPA notes that the cost of the
proposed ADWR was significantly less than the current regulatory requirements of the
NPDWRs. The current NPDWR requirements, considered to be the baseline against which to
compare the set of regulatory requirements of the final ADWR, would continue to apply to the
aircraft water system industry if the requirements of the ADWR were not promulgated. The
reduction in cost (i.e., the incremental savings of the ADWR compared to the regulatory
Page 5-26
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
baseline) is the result of tailoring the current regulations for transient non-community public
water systems to the specific operational characteristics of aircraft drinking water systems.
EPA estimates that the total annualized incremental savings of this ADWR is $22.15
million at a 3 percent discount rate and $21.83 million at a 7 percent discount rate, as presented
in Exhibit 5.25. The incremental savings represent the difference in total annualized
implementation costs between the baseline (i.e., the existing NPDWRs) and the final rule
provisions.
Exhibit 5.25 Total Annualized Incremental Cost: Existing NPDWRs and the ADWR
($Millions, 2008$)
Implementation
Annual Administration
Monitoring Plan
O&M Plan
Coliform Monitoring
Disinfectant Residual
Monitoring
Routine Disinfection and
Flushing
Corrective Action
Disinfection and Flushing
Sanitary
Survey/Compliance Audit
Turbidity Monitoring
Total
AIM
(Existing
NPDWRs)
Alt 4
(Final Rule)
Incremental
Cost
(Alt 4 - Alt 1 )
3%
0.01
0.24
0.002
-
25.37
3.17
-
-
0.7
-
$29.49
0.01
0.24
0.002
0.01
4.93
-
2.08
0.05
0.02
-
$7.34
0
0
0
0.01
(20.44)
(3.17)
2.08
0.05
(0.68)
-
$(22.15)
AIM
(Existing
NPDWRs)
Alt 4
(Final Rule)
Incremental
Cost
(Alt 4 - Alt 1)
7%
0.02
0.23
0.004
-
25.02
3.13
-
-
0.69
-
$29.08
0.02
0.23
0.003
0.02
4.86
-
2.05
0.05
0.02
-
$7.25
0
0
(0.001)
0.02
(20.16)
(3.13)
2.05
0.05
(0.67)
-
$(21.83)
The regulatory baseline does not reflect the AOCs, which are interim enforcement actions
applying to 45 air carriers. As discussed earlier in this document, in 2004, EPA found all aircraft
that were public water systems to be out of compliance with the NPDWRs. EPA subsequently
placed 45 air carriers under Administrative Orders on Consent (AOCs) that will remain in effect
until the tailored aircraft drinking water regulations are final. The air carrier AOCs combine
sampling, best management practices, corrective action, public notification, and reporting and
recordkeeping to ensure public health protection. With respect to sampling under the AOCs, air
carriers with greater than 20 aircraft were required to sample 25 percent of their fleet quarterly,
while air carriers with 20 or fewer aircraft were required to sample the entire fleet quarterly.
Because the majority of the air carriers are currently subject to the requirements of the AOCs,
EPA notes that if the AOCs were considered to be an alternative baseline, the incremental cost of
the final ADWR would be $0.18 million at the 3 percent discount rate and $0.18 million at the 7
percent discount rate, Exhibit 5.26.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit 5.26 Total Annualized Incremental Cost: Requirements Similar to AOCs
and the ADWR ($Millions, 2008$)
Implementation
Annual Administration
Monitoring Plan
O&M Plan
Coliform Monitoring
Disinfectant Residual
Monitoring
Routine Disinfection and
Flushing
Corrective Action
Disinfection and Flushing
Sanitary
Survey/Compliance Audit
Turbidity Monitoring
Total
Alt 2
(AOCs)
Alt 4
(Final Rule)
Incremental
Cost
(Alt 4-Alt 2)
3%
0.01
0.24
0.002
-
1.67
0.67
4.52
0.05
-
-
7.16
0.01
0.24
0.002
0.01
4.93
-
2.08
0.05
0.02
-
7.34
0
0
0
0.01
3.26
(0.67)
(2.44)
0
0.02
-
0.18
Alt 2
(AOCs)
Alt 4
(Final Rule)
Incremental
Cost
(Alt 4-Alt 2)
7%
0.02
0.23
0.004
-
1.65
0.66
4.46
0.05
-
-
7.07
0.02
0.23
0.003
0.02
4.86
-
2.05
0.05
0.02
-
7.25
0
0
(0.001)
0.02
3.21
(0.66)
(2.41)
0
0.02
-
0.18
5.8 Comparison of Regulatory Alternatives
5.8.1 Comparison to the final ADWR
Exhibit 5.27 provides a summary of the annualized present value costs for implementing
each regulatory alternative considered during the regulatory development process at 3 and 7
percent discount rates. EPA used the same process for developing cost estimates for all
regulatory alternatives. Unit costs were multiplied by the number of air carriers or aircraft
performing various components of each alternative, and results were summed for all
components.
The $7.3 million implementation cost for the final rule (which includes both the costs to
air carriers and EPA) lies between the least costly and most costly alternatives. The cost of the
final rule is approximately one-fourth of the costs incurred by air carriers and the Agency under
the baseline. As a result of tailoring NPDWRs to the specific operational characteristics of
aircraft drinking water systems, the costs for the final rule are slightly higher than those under
Alternative 2 - requirements similar to the AOCs; however EPA made several assumptions
about the frequency of disinfection and flushing and monitoring in order to estimate the
implementation costs. If all of the air carriers followed the quarterly disinfection and flushing
frequency, as was required under the AOCs, the difference between the two alternatives would
be negligible.
EPA believes the increased flexibility of the final rule will reduce non-quantified costs
to the air carriers such as for unanticipated disinfection and flushing events, and will provide the
maximum protection with the least disruption to air carriers, thus making it the least costly
alternative.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit 5.27 Comparison of Total Annualized Present Value Implementation
Costs by Regulatory Alternative ($Millions, 2008$)
Implementation
Annual Administration
Monitoring Plan
O&M Plan
Collform Monitoring
Disinfectant Residual
Monitoring
Routine Disinfection and
Flushing
Corrective Action Disinfection
and Flushing
Sanitary Survey/Compliance
Audit
Turbidity Monitoring
Total
Alt 1
Alt 2
Alt 3
Alt 4 (Final Rule)
3%
0.01
0.24
0.002
-
25.37
3.17
0.70
-
29.49
0.01
0.24
0.002
-
1.67
0.67
4.52
0.05
-
7.16
0.01
0.24
0.001
0.01
2.23
.
2.97
0.05
12.92
18.43
0.01
0.24
0.002
0.01
4.93
.
2.08
0.05
0.02
-
7.34
Alt1
Alt 2
Alt 3 | Alt 4 (Final Rule)
7%
0.02
0.23
0.004
-
25.02
3.13
0.69
-
29.08
0.02
0.23
0.004
-
1.65
0.66
4.46
0.05
-
7.07
0.02
0.23
0.002
0.01
2.20
.
2.93
0.05
12.74
18.19
0.02
0.23
0.003
0.02
4.86
.
2.05
0.05
0.02
-
7.25
5.8.2 Comparison of the proposed ADWR and final ADWR
As discussed in Chapter 2 of this document, a collaborative rule development process
was used for the proposed ADWR. This process provided an opportunity for stakeholders to
inform the Agency about existing operations and maintenance practices for aircraft water
systems and to convey concerns regarding existing regulations applicable to aircraft water
systems, public health issues, fleet operations issues that are unique to the air carrier industry,
and potential rule alternatives. Public comment was received on the proposed rule, and
modifications have been incorporated into the final ADWR. This document presents a discussion
of the final ADWR with comparison to the three alternatives considered when developing the
ADWR. Some of the modifications to the proposed rule that are incorporated into the final rule
affected the estimated cost of the regulation; other changes had no net effect on cost but may
have affected non-quantified costs. This section provides a discussion of the cost of the elements
of the final ADWR compared to the proposed rule, and summarizes the assumptions that have
been incorporated into the cost estimates.
The total annualized present value costs at 3 percent and 7 percent discount rates for the
rule provisions are shown in Exhibit 5.28 for the proposed and final rules. The costs reported for
the final rule are from Exhibit 5.24; the costs for the proposed rule include adjustments for the
general cost assumptions and methodology described in Section 5.2, with all costs adjusted to
2008 dollars.
As noted in Section 5.2.1, the labor rate for the technical labor category used for air
carrier cost estimates decreased from that used for cost estimates for the proposed rule - this
affected all cost estimates that apply a labor rate for air carrier technical staff. Because this
decreased labor rate has been incorporated into the cost estimates for all of the alternatives and
the final ADWR, as well as the proposed rule costs presented in Exhibit 5.28, it does not affect
the comparison of the rule options and final rule. It is notable, however, to explain the
approximately $25,000 decreased cost estimate presented for the proposed rule in this document
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
compared to the Economic and Supporting Analysis Document for the Proposed ADWR
(USEPA, 2008a).
The final ADWR includes an extension of the compliance dates to 18 months after rule
promulgation for the coliform sampling plan, operations and maintenance plans, and the aircraft
inventory; the proposed rule specified a six-month timeframe for these requirements. In
addition, the final rule adjusts the timeframe for beginning to conduct sampling and other
compliance requirements to 24 months after final rule promulgation from 12 months specified in
the proposed rule. These delays in compliance dates have a slight effect on the timing of the
costs represented by the 25-year compliance period captured by these estimates.
The discussion below summarizes the other changes made for the final ADWR and the
Agency's assumptions that affected the cost of those changes. Some of the final rule provisions
and cost estimate parameters affected all, or nearly all, aspects of the cost estimates for the
regulation.
Exhibit 5.28 Comparison of Proposed and Final ADWR Total Annualized Present
Value Costs ($Millions, 2008$)
Implementation
Annual Administration
Monitoring Plan
O&M Plan
Coliform Monitoring
Routine Disinfection and Flushing
Corrective Action Disinfection and Flushing
Compliance Audit
Total
Proposed
ADWR*
Final
ADWR
3%
0.01
0.25
0.002
0.01
5.50
2.21
0.13
0.02
8.13
0.01
0.24
0.002
0.01
4.93
2.08
0.05
0.02
7.34
Proposed
ADWR*
Final
ADWR
7%
0.01
0.25
0.004
0.02
5.57
2.23
0.13
0.02
8.24
0.02
0.23
0.003
0.02
4.86
2.05
0.05
0.02
7.25
* For the proposal, the total annualized present value cost at a 3% discount rate is less than at a 7% discount rate by
a small amount. Changes in the implementation schedule (later implementation) for the final rule result in a larger
calculated difference in present value costs, which results in total annualized present value costs slightly greater at a
3% discount rate than at a 7% rate.
Implementation
This category addresses air carrier one-time costs for reading and understanding the rule,
becoming familiar with its provisions, and training employees on the rule. Based on public
comment that air carriers would typically have more than one person responsible for this task,
the final ADWR provides a burden allowance for each air carrier to read and understand the rule
of 8 hours per carrier, increased from 2 hours per carrier in the proposed rule. The Agency
assumes, on average, each air carrier will have four staff persons who will need to read and
understand the rule at 2 hours estimated burden for each person. The 8 hours per air carrier for
staff training is unchanged from the proposed rule.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
The Agency burden estimates for implementation include reading and understanding the
rule, program development, modifying existing database systems, and providing air carrier
training and technical assistance and staff training. The estimate of Agency hourly burden for
each item is unchanged from the proposed rule.
Annual Administration
The Annual Administration category addresses the Agency's rule implementation and
enforcement activities that must occur on an ongoing basis; air carriers do not have costs in this
category. Implementation activity estimates include ongoing technical assistance to air carriers
and staff training events. The assumptions for this category are unchanged from the proposed
rule.
Monitoring Plan
The air carrier coliform monitoring plan will include the selected monitoring frequency
and the respective routine disinfection and flushing frequency. The estimated burden
assumptions applied to the final rule are unchanged from the proposed rule, including the
assumption that air carriers will prepare one plan to address the entire aircraft fleet.
Operations and Maintenance Plan
All air carriers subject to the ADWR will need to develop or update existing O&M plans
and practices with ADWR-specific requirements and submit a statement to the Agency that the
plan is completed. The air carrier operations and maintenance plans are reviewed by the Agency
during compliance audits; Agency review of the statement submitted by the air carrier is
captured in this category. No estimated burden assumptions or requirements have changed that
affect this estimate.
Coliform Monitoring
The coliform monitoring category includes cost estimates for routine sampling and repeat
sampling; follow-up coliform monitoring is captured under corrective action disinfection and
flushing estimates. Each aircraft routine coliform monitoring schedule is determined by the
routine disinfection and flushing frequency that should be based on manufacturer's
recommendations. Several provisions in the final rule and their related assumptions affect the
estimated cost for this category. Those provisions include addition of a fourth routine
disinfection and flushing/coliform monitoring frequency option, reduction of the number of
repeat samples to three in the final rule from four in the proposed rule, and allowing repeat
sampling if more than one routine sample is total coliform-positive butE1. co//'-negative. The
proposed rule limited the option of repeat sampling to situations when more than one routine
sample was total coliform-positive. Assumptions pertaining to the amount of time it would take
to implement each of the items, such as collecting a water sample or Agency oversight, are
unchanged from the proposed rule.
The assumptions of the percentage of aircraft that would select each of the monitoring
frequency options have been adjusted to incorporate the fourth option that is included in the final
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
rule. For the final rule, the Agency assumed 10 percent of the aircraft would select monthly
monitoring with routine disinfection and flushing one time per year or less; 30 percent would
select monitoring quarterly with routine disinfection and flushing twice per year; 30 percent
would select monitoring twice per year with routine disinfection and flushing three times per
year; and 30 percent would select annual monitoring with routine disinfection and flushing on a
quarterly basis. The proposed rule assumed 10 percent of the aircraft would monitor monthly, 45
percent quarterly, and 45 percent annually.
The final ADWR utilized the coliform monitoring findings of the AOCs analyzed as of
December 31, 2008, in the estimates of the percentage of routine and repeat samples that will be
total coliform-positive and E. co//'-positive. A discussion of the AOCs' data is found in Chapter
3 of this document. For the final rule, a routine sample total coliform-positive rate of 3.6 percent
and a repeat sample total coliform-positive rate of 5.7 percent are assumed based on the AOCs
results for data collected under EPA-approved air carrier QAPPs and CRMPs. The proposed
rule applied a routine sample rate of 3.1 percent based on data available at the time, and a repeat
sample rate of 50 percent.
The final ADWR estimates assume that whenever possible, an aircraft will perform
routine coliform monitoring immediately prior to initiating routine disinfection and flushing
procedures while the aircraft is out of service for the later. In such a case, if a routine coliform
sample is total-coliform positive, the Agency assumes the air carrier will perform disinfection
and flushing procedures and collect follow-up samples as a response to the sample results instead
of opting for repeat sampling. As described below, the Agency assumes the disinfection and
flushing event would count toward routine requirements and corrective action requirements as
long as follow-up samples are collected. For example, an aircraft on quarterly routine
disinfection and flushing is assumed to collect the required annual coliform sample during one of
the periods the aircraft is out of service for the quarterly event. Of the routine coliform sample
results that are assumed to occur when routine disinfection and flushing is not immediately
available, the cost estimates assume 50 percent of the aircraft will perform repeat sampling in
lieu of unscheduled disinfection and flushing with follow-up sampling. This assumption of the
percentage of repeat sampling affects both the repeat sample and follow-up sample cost
estimates; although the follow-up sample costs are included in the corrective action disinfection
and flushing category (see Section 5.4.4.1 for details on these assumptions).
Routine Disinfection and Flushing
The addition of the fourth option for routine disinfection and flushing frequencies in the
final rule adjusted the assumptions for the percentage of aircraft that would select each option.
The new twice-yearly routine disinfection and flushing frequency was assigned to 30 percent of
the aircraft, which decreased the number of aircraft assumed to select either thrice-annually or
semi-annually disinfection and flushing from 45 percent under the proposed rule options.
Corrective Action Disinfection and Flushing
As described for coliform monitoring, assumptions pertaining to the number of corrective
action disinfection and flushing events that would be incurred were recalculated based on
whether the aircraft was anticipated to already be scheduled for immediate disinfection and
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
flushing. The Agency assumed, based on comments received during the public comment period
for the proposed rule, that air carriers would seek to minimize the number of times unanticipated
disinfection and flushing events would occur and would take advantage of the ability to perform
this action as part of the routine disinfection and flushing activities. Also, the estimated
reduction in the repeat sample coliform-positive rate to 5.7 percent in the final rule affected the
anticipated costs for this category because fewer events were expected to be triggered by repeat
sample results.
Compliance Audit and Self-Inspections
The final ADWR does not incorporate any changes regarding air carrier or Agency
responsibilities or schedules for the self-inspection and compliance audit provisions over the
proposed rule.
5.9 Comparison of Costs and Benefits
The qualitative analyses suggest that benefits are greater under the final rule than under
the baseline requirements represented by Alternative 1. The final rule will likely deliver a level
of desired benefits at a cost that is acceptable to the air carrier industry, which increases the
likelihood that real benefits will accrue. Additionally, the final rule represents an approach that
accomplishes the goals of the traditional drinking water rules, but is specifically tailored to this
unique industry and setting. As a result, the final rule is expected to have a substantially lower
cost than a less-tailored approach - only about one-fourth the cost of the Alternative 1 (the
baseline).
EPA is limited by the purpose, quality, and quantity of data available in developing
meaningful benefits analyses. In the absence of additional statistical analyses, only general
observations of the data can be made, and only with adequate qualifiers. Any comparison of risk
between the alternatives considered for the final rule requires robust data that would support: 1)
direct comparisons of the overall baseline conditions with the overall conditions under each of
the alternatives, or 2) comparisons of specific regulatory components (i.e., disinfection and
flushing frequencies) that could be used to compare the baseline and all alternatives. See
Chapter 3 for a more detailed description of baseline data.
5.10 Other Economic Measures
The lack of a quantitative risk assessment prevents the use of other economic measures,
specifically, a break-even analysis and measure of cost-effectiveness based on the value of
changes in health conditions.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
6. Statutory and Administrative Requirements
6.1 Introduction
As part of the rulemaking process, EPA is required to address the direct and indirect
burdens that the ADWR may place on certain types of businesses and populations. This chapter
presents the analyses performed by EPA in accordance with the following 12 Federal mandates:
1) Executive Order 12866: Regulatory Planning and Review
2) The Regulatory Flexibility Act
3) Analysis of small air carrier affordability to determine variance technologies in
accordance with Section 1415(e)(l) of the 1996 SDWA Amendments
4) Feasible technologies available to all air carriers as required by Section
1412(b)(4)(E) of the 1996 SDWA Amendments
5) Technical, financial, and managerial capacity assessment as required by Section
1420(d)(3) of the 1996 Amendments to SDWA
6) Paperwork Reduction Act (a separate Information Collection Request document
contains the complete analysis)
7) Unfunded Mandates Reform Act of 1995
8) Impacts on sensitive subpopulations as required by Section 1412(b)(3)(c)(i) of the
1996 SDWA Amendments
9) Executive Order 13045 (Protection of Children from Environmental Health Risks
and Safety Risks)
10) Executive Order 12898 (Federal Actions to Address Environmental Justice in
Minority Populations and Low-Income Populations).
11) Executive Order 13132 (Federalism).
12) Executive Order 13211 (Actions Concerning Regulations That Significantly
Affect Energy Supply, Distribution, or Use)
Many of the requirements and executive orders listed above call for an explanation of
why the rule is necessary, the statutory authority for the rule, and the primary objectives that the
rule is intended to achieve (refer to Chapter 1 for more information regarding the objectives of
the rule). More specifically, they are designed to assess the financial and health effects of the
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
rule on small air carriers and examine how much additional capacity air carriers will need to
meet ADWR requirements.
6. 2 Executive Order 12866: Regulatory Planning and Review
Under Executive Order 12866, [58 Federal Register 51735; October 4, 1993] this action
is a "significant regulatory action" because it raises novel legal or policy issues. Accordingly,
EPA submitted this action to OMB for review under Executive Order 12866 and any changes
made in response to OMB recommendations have been documented in the docket for this action.
This document represents an analysis of potential costs and benefits associated with this
action. An economic rationale for the rule is required by Executive Order 12866, which states:
"[EJach agency shall identify the problem that it intends to address (including, where
applicable, the failures of the private markets or public institutions that warrant new
agency action) as well as assess the significance of that problem." (Section 1, b(l))
Federal regulation of aircraft drinking water systems is necessary as a result of the
information gap that exists with regard to the safety or quality of the drinking water. Because of
limited monitoring, there is a lack of information on the potential risks associated with drinking
and using the water onboard aircraft. As a result, aircraft passengers do not receive sufficient
information on drinking water quality to make informed decisions about drinking water on
aircraft. Federal intervention can be used to close this gap.
6. 3 Regulatory Flexibility Act
The RFA generally requires an agency to prepare a regulatory flexibility analysis for any
rule subject to public notice and comment requirements under the Administrative Procedure Act
or other statute, unless the Agency certifies that the rule will not have a significant economic
impact on a substantial number of small entities (5 United States Code (U.S.C.) 603(a)). Small
entities include small businesses, small organizations, and small governmental jurisdictions. The
RFA provides the following default definitions for each type of small entity: (1) a small business
as defined by the Small Business Administration's (SBA) regulations at 13 CFR 121.201; (2) a
small governmental jurisdiction that is a government of a city, county, town, school district, or
special district with a population of less than 50,000; and (3) a small organization that is any
"not-for-profit enterprise that is independently owned and operated and is not dominant in the
field."
U.S. aircraft subject to the final ADWR may be owned and operated by businesses.
Therefore, the screening analysis for the ADWR uses the following definition for small entities:
A "small business" is any firm that is independently owned and operated and is not dominant in
its field of operation (Small Business Act, 15 U.S.C. 632). The SBA definitions of small
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
businesses use categories are defined by National American Industry Classification System
(NAICS) codes. EPA has determined that the following businesses would be affected by the
ADWR based on the NAICS:
481111 - Scheduled passenger air transportation
481211 - Nonscheduled chartered passenger air transportation
SB A defines a small business for air carriers (NAICS codes 481111 and 481211) as having
fewer than 1,500 employees (13 CFR 121.201). EPA used this SBA standard definition as an
alternative to the definition EPA has used for small stationary PWSs ("a PWS that serves 10,000
of fewer people"). This is because the air carrier is the business entity rather than the individual
aircraft water system. The Agency requested but did not receive comments on the use of this
alternative definition of small entity.
EPA conducted a screening analysis to determine if the ADWR would have a significant
economic impact on a substantial number of small entities. Chapter 3 of this document provides
data on air carriers potentially subject to the ADWR, and Chapter 5 discusses actions that air
carriers would need to take to comply with the rule and their associated costs. Using information
from these two chapters, along with additional information from Dun & Bradstreet (D&B)
reports, EPA conducted a quantitative analysis of small entity impacts resulting from the rule.
Based on EPA's screening level analysis of small entities presented in Appendix D, EPA
has estimated that 30 of the 63 air carriers subject to this final rule are small businesses. These
30 air carriers represent 48 percent of the universe of air carriers subject to the final rule, and all
will be subject to the various provisions. Therefore, EPA has determined that a substantial
number of small entities will be impacted by this rule.
In evaluating whether this rule will have a significant impact on these small entities, EPA
first determined the present value costs of the rule for these air carriers. EPA followed the same
methodology as was used to develop the average annualized costs for the rule overall. EPA
estimates a total annual implementation cost for all small air carriers of $524,380 at a 3 percent
discount rate and $521,110 at a 7 percent discount rate. EPA also determined the average annual
rule cost per small air carrier of $17,543 (annualized at 3 percent).
EPA estimates the average annual incremental rule cost for small entities (the difference
between the final rule and the existing NPDWRs (presented as Alternative 1)) is a reduction of
$258,599 at a 3 percent discount rate for compliance with the ADWR. Because the majority of
the air carriers are currently subject to the requirements of the AOCs, EPA notes that if the
AOCs were considered to be an alternative baseline, the incremental average annual rule cost
between the final rule and requirements similar to those of the AOCs, (presented as Alternative
2) is a reduction of $32,188 (i.e., cost savings).
Recognizing the variation of company sizes within this group, EPA has estimated the
average annual incremental cost for small air carriers with fewer than 500 employees and for
small air carriers with 500 or more employees. For the 17 air carriers with fewer than 500
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
employees, the annual incremental cost between the ADWR and Alternative 1 for each air carrier
is a reduction of $78,042 at a 3 percent discount rate, and the annual incremental average rule
cost between the ADWR and Alternative 2 is a reduction of $7,781 at a 3 percent discount rate.
For the 13 small air carriers with 500 or more employees, the incremental cost between the
ADWR and Alternative 1 for each air carrier is a reduction of $230,712 at a 3 percent discount
rate, and the incremental average rule cost between the ADWR and Alternative 2 is a reduction
of $20,104 at a 3 percent discount rate.
The final rule has been shown to offer a cost reduction over the existing regulations (i.e.,
baseline), and so the annualized incremental costs are negative. Therefore, EPA has not
compared the average annual incremental costs to small entities against the average annual
revenue of the small entities as is normally done for this analysis.
Based on this analysis, EPA certifies that the final ADWR will not have a significant
impact on a substantial number of small entities; therefore, the Agency did not develop an Initial
Regulatory Flexibility Analysis for the rule.
6. 4 Small-Air Carrier Affordability
Section 1415(e)(l) of SDWA does not apply to the final ADWR since small air carriers
are not required to install compliance technologies and, therefore, primacy agencies do not need
to grant variances to small air carriers in lieu of complying with an MCL.
6. 5 Feasible Treatment Technologies for All Air Carriers
Section 1412(b)(4)(E) of the 1996 SDWA Amendments requires that feasible
technologies and treatment techniques are available for entities to comply with a NPDWR. The
only treatment technique required under the ADWR is disinfection and flushing of aircraft water
systems. Because this process is simple, affordable, and well within the existing technical
capabilities of aircraft maintenance technicians it is considered a feasible treatment technique for
all aircraft.
6. 6 Effect of Compliance with the ADWR on the Technical, Managerial, and
Financial Capacity of Air Carriers
Section 1420(d)(3) of SDWA, as amended, requires that, in promulgating a NPDWR, the
Administrator shall include an analysis of the likely effect of compliance with the regulation on
the technical, managerial, and financial (TMF) capacity of regulated entities. The following
analysis fulfills this statutory obligation by identifying the incremental impact that the ADWR
will have on the TMF of regulated air carriers. Analyses presented in this document reflect only
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
the impact of new or revised requirements, as established by the ADWR; the impacts of
previously established requirements are not considered.
Overall capacity is defined in Guidance on Implementing the Capacity Development
Provisions of the Safe Drinking Water Act Amendments of 1996 (USEPA, 1998) as the ability to
plan for, achieve, and maintain compliance with applicable drinking water standards. Capacity
encompasses three components: technical, managerial, and financial. Technical capacity is the
operational ability of an air carrier to meet SDWA requirements. Key issues of technical
capacity include:
• Source water adequacy—Do air carriers have a reliable source of water with
adequate quantity? Is the source generally of good quality and adequately
protected?
• Infrastructure adequacy—Can the air carrier provide water that meets SDWA
standards? What is the condition of its infrastructure, including water fill ports,
storage tanks, and pipes? Does the air carrier have an improvement plan?
• Technical knowledge and implementation—Do the personnel conducting
monitoring and disinfection have sufficient knowledge of applicable standards?
Can the personnel effectively implement this technical knowledge? Do the
personnel understand the air carrier's technical and operational characteristics?
Does the air carrier have an effective O&M program?
Managerial capacity is the ability of an air carrier's managers to make financial,
operating, and staffing decisions that enable the air carrier to achieve and maintain compliance
with SDWA requirements. Key issues include:
Ownership accountability—Are the owners clearly identified? Can they be held
accountable for the air carrier?
• Staffing and organization—Are the operators and managers clearly identified? Is
the air carrier properly organized and staffed? Do personnel understand the
management aspects of regulatory requirements and air carrier operations? Do
they have adequate expertise to manage air carrier drinking water operations (i.e.,
to disinfect and flush aircraft and monitor for total coliform to meet the ADWR
requirements)? Do personnel have the necessary certifications and training?
• Effective external linkages—Does the air carrier interact well with customers,
regulators, and other entities?
Financial capacity is an air carrier's ability to acquire and manage sufficient financial resources
to allow the air carrier to achieve and maintain compliance with SDWA requirements. Key
issues include:
• Revenue sufficiency - Do revenues cover costs?
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
Creditworthiness - Is the air carrier financially healthy? Does it have access to
capital?
Fiscal management and controls - Are adequate books and records maintained?
Are appropriate budgeting, accounting, and financial planning methods used?
Does the air carrier manage its revenues effectively?
6.6.1 Requirements of the Final ADWR
This capacity analysis is presented only for the final rule, although EPA took similar
considerations into account in the selection of the proposed rule option over the other
alternatives. This process led to the incorporation of more flexibility to enable air carriers to
better coordinate rule activities with existing O&M activities.
The final ADWR establishes five requirements that may affect the TMF capacity of
affected air carriers:
1. Developing the aircraft water system O&M manual
2. Developing a coliform sampling plan
3. Monitoring for total coliform
4. Disinfection and flushing of aircraft
5. Taking corrective action for total coliform-positive samples
In addition, personnel from air carriers regulated under the ADWR will need to familiarize
themselves with the rule and its requirements. Air carriers must also perform recordkeeping and
reporting activities related to monitoring, disinfection and flushing, public notification,
inventory, and self-inspections. Where applicable, the impacts of recordkeeping and reporting
are considered as a part of the individual rule components.
6.6.2 Air Carriers Subject to the Final ADWR
The ADWR will apply to all aircraft that serve water to an average of 25 or more people daily for
at least 60 days per year. EPA estimates that the ADWR may affect 7,327 aircraft (see Exhibit 6.5).
While most will not, some air carriers may require increased TMF capacity to comply with the new
requirements for their aircraft, or will need to tailor their compliance approaches to match their capacities.
Refer to section 6.6.4 for a detailed discussion of changes in TMF capacity.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
6.6.3 Impact of the ADWR on Air Carrier Capacity
The estimates presented in Exhibit 6.1 reflect the anticipated impact of the final ADWR
on air carrier capacity based on the expected measures that air carriers will be required to adopt.
The extent of the expected impact of a particular requirement on air carrier capacity is estimated
using a scale of 0-5, where 0 represents a requirement that is not expected to have any impact, 1
represents a requirement that is expected to have a minimal impact, and 5 represents a
requirement that is expected to have a very significant impact on air carrier capacity. Criteria
used to develop the scores and associated impacts are discussed further in section 6.6.4.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit 6.1 Estimated Impacts of the ADWR on Air Carriers' Technical, Managerial, and Financial Capacity
(0 = no impact, 1 = minimal impact, and 5 = very significant impact)
Requirement
Familiarization with requirements of the
rule
Updating O&M plan
Developing a sampling plan
Monitoring for total coliform
Disinfection & flushing of aircraft
Corrective action for total coliform-
positive samples
Number and
Percent of Air
Carriers
63(100%)
63(100%)
63(100%)
63(100%)
63(100%)
10(16%)
Technical Capacity
|J3 >i
§ CO
'o
0) ~
C/3
1
1
0
2
1
1
«
«
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
6.6.4 Derivation of the ADWR Scores
To analyze the impact compliance with all new requirements will have on the technical,
managerial, and financial capacity of air carriers (and assign scores in accordance with the
process described in Section 6.6.3 above), it is necessary to complete the following steps:
1. Determine the type and number of air carriers to which the regulation applies.
2. List all of the requirements of the regulation.
3. Determine the type and number of air carriers to which each requirement applies.
4. Evaluate the impact of each requirement on the capacity of affected air carriers.
The determination of the universe of affected air carriers and the evaluation of the
capacity impact of individual requirements requires the use of cost and technical information
contained in economic analyses developed for other rules, information collection requests, and
other supporting documentation for the rule. These data sources are also used to develop a
qualitative description of the expected response of affected air carriers to each requirement.
Within these sub-categories, a professional with extensive water system experience
reviewed the costs, number of air carriers affected, and complexity of each requirement. After
estimating the technical, managerial, and financial impacts within each sub-category, the
professional assigned the scores using best professional judgment. Costs were considered
cumulatively for each requirement for small and large air carriers. This score reflects the
additional capacity that air carriers will need to develop to comply with each requirement.
These scores were reviewed by the EPA Rule Manager and other EPA staff cognizant of
small air carrier issues to ensure that they accurately reflect the cumulative impact of the rule
requirements on air carrier capacity. Any disagreements over the assignments were discussed.
The EPA Rule Manager and other EPA staff discussed the rationale for the disagreement and
evaluate whether the assignments need to be adjusted. EPA adjusted the assignments only after
review of the rule support documents and an analysis of the expected air carrier response to the
rule requirements.
Most regulated air carriers will likely not face more than a minimal challenge to their
technical, managerial, and financial capacity as a result of efforts to familiarize themselves with
the ADWR requirements (Exhibit 6.1). All air carriers subject to the rule should have existing
O&M plans. EPA expects air carriers to spend 80 hours developing their O&M plans with
ADWR specific requirements. Air carriers will need to develop a sampling plan, which is
expected to take 10 hours. Since the sampling locations are likely to be the similar types of
aircraft and the sampling frequency is either monthly, quarterly, twice annually, or annually, the
sampling plan should be relatively simple to develop and should not require a high technical skill
level.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
EPA is providing air carriers the flexibility of choosing one of four monitoring and
disinfection schedules that can most easily be integrated into air carriers' current O&M
schedules if there are no manufacturer's recommendations specifying a frequency. Air carriers
already have the infrastructure and technical knowledge for disinfecting and flushing aircraft, but
may need to adjust their O&M schedules to accommodate additional disinfection events. While
air carriers are required by existing regulations and AOCs to monitor for total coliform, some
may need to invest in a modest amount of additional monitoring equipment, including
refrigerators, coolers, gel packs, and thermometers.
Aircraft that receive one or more routine total coliform-positive samples followed by a
repeat total coliform-positive sample, or that receive a single E. co//'-positive sample result must
perform corrective action, which consists of disinfection and flushing and follow-up coliform
monitoring. In addition, air carriers must perform recordkeeping activities, assumed to include
the completion of a maintenance log for disinfection and flushing events. Corrective actions do
not require different technical skills and are expected to occur infrequently (i.e., a maximum of
3.6 percent of routine samples). Therefore, corrective actions are expected to have limited
impact on air carriers.
Overall, EPA assumes that air carriers will have the technical, financial, and managerial
capacity to implement ADWR requirements based on the scale and complexity of their
operations. The nature of their operations generally assures that they have access to the technical
and managerial expertise to carry out all activities required by the final ADWR.
6. 7 Paperwork Reduction Act
The information collection requirements for the ADWR have been submitted for
approval to OMB under the Paperwork Reduction Act, 44 U.S.C. 3501 et seq. The information
collected as a result of this rule will allow EPA to determine appropriate requirements for
specific air carriers and evaluate compliance with the rule.
The Paperwork Reduction Act requires EPA to estimate the burden on air carriers and
primacy agencies of complying with the rule. Burden means the total time, effort, and financial
resources required to generate, maintain, retain, disclose, or provide information to or for a
Federal agency. This burden includes the time needed to conduct these activities:
• Review instructions.
• Develop, acquire, install, and employ technology and systems for the purposes of
collecting, validating, verifying, processing, maintaining, and disclosing
information.
• Adjust the existing ways to comply with any previously applicable instructions
and requirements.
Train personnel to respond to information collected.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Search data sources.
Complete and review the collection of information.
Transmit or otherwise disclose the information.
For the first three years after publication of the final ADWR in the Federal Register,
information requirements are associated with implementation activities, sampling and O&M
plans, submittal of fleet inventory, self-inspections, monitoring, and disinfection and flushing
activities. The information collection requirements are mandatory under Part 141 of the
NPDWRs. The calculation of ADWR information collection burden and costs can be found in
the Information Collection Request for the Aircraft Drinking Water Rule (USEPA, 2009).
The total burden associated with ADWR requirements over the three years covered by
the Information Collection Request is 62,291 hours, an average of 20,764 hours per year. The
total cost over the three-year clearance period is $7.54 million, an average of $2.5 million per
year (simple average over three years). The average burden per response (i.e., the amount of
time needed for each activity that requires a collection of information) is 0.3 hours; the average
cost per response is $41.
Exhibit 6.2 provides a summary of the results of the Information Collection Request
calculations.
Exhibit 6.2 Average Annual Burden Hours and Costs for the ADWR Information
Collection Request
Air Carriers
Agency
Total
Average
Annual
Burden
(Hours)
17,583
3,180
20,764
Average
Annual Labor
Costs
$632,262
$159,214
$791,746
Average
Annual O&M
Costs
$1,719,536
-
$1,719,536
Average
Annual
Capital Costs
$1,393
-
$1,393
Average
Annual Costs
$2,353,191
$159,214
$2,512,405
Note: Data represent burden and cost for only the 3-year Information Collection Request clearance period. Data are
based on nominal (or undiscounted) values. Detail may not add due to independent rounding.
Source: Information Collection Request for the Aircraft Drinking Water Rule (USEPA, 2009).
6. 8 Unfunded Mandates Reform Act
The UMRA of 1995, Public Law 104-4, consists of four Titles and numerous sections.
Sections 202 and 205 of Title II, entitled "Regulatory Accountability and Reform," are relevant
to the ADWR and are discussed in this section. Under Section 202 of the UMRA, EPA
generally must prepare a written statement, including a cost-benefit analysis, for proposed and
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
final rules with "Federal mandates" that may result in expenditures by the private sector of $100
million or more in any one year.
Section 205 generally requires EPA to identify and consider a reasonable number of
regulatory alternatives and adopt the least costly, most cost-effective, or least burdensome
alternative that achieves the objectives of the rule before promulgating a rule for which a written
statement is needed under Section 202. The provisions of Section 205 do not apply when they
are inconsistent with applicable law. Moreover, Section 205 allows EPA to adopt an alternative
other than the least costly, most cost-effective, or least burdensome alternative if the
Administrator publishes with the final rule an explanation why that alternative was not adopted.
EPA has determined that this rule does not contain a Federal mandate that may result in
expenditures of $100 million or more for the private sector in any one year. Under the final rule,
the likely compliance scenario is expected to result in total annualized costs to air carriers of
$7.04 million using a 3 percent discount rate, or $6.95 million using a 7 percent discount rate.
Thus, the ADWR is not subject to the requirements of section 202 and 205 of the UMRA.
Social Benefits and Costs
The social benefits are those that are accrued primarily by the public through increased
protection from illness and potential death that would have been caused by exposure to microbial
pathogens in drinking water. Although EPA did not assign a monetary value to the reductions in
illness, a qualitative analysis of the public health benefits is included in Chapter 4. Additional
benefits may include reduced risks to sensitive subpopulations, reduced outbreak risks, and
reduced risk-averting behavior (e.g., purchasing bottled water). In addition, certain non-health-
related benefits may exist, such as enhanced aesthetic water quality.
Measuring the social costs of the final rule requires considering regulatory alternatives,
calculating regulatory compliance costs, and estimating any disproportionate impacts. Chapter 5
of this document details the cost analysis performed for the ADWR. EPA considered several
regulatory alternatives and numerous methods to identify aircraft most at risk to microbial
contamination. Chapter 2 provides a detailed discussion of these alternatives. EPA chose the
final rule because it provided substantial benefits at an acceptable level of costs, and
incorporated significant flexibility for air carriers to comply with the rule. In addition, the
Workgroup (described in Chapter 2) supported the proposed regulatory option, which
incorporated feedback from two stakeholder meetings, and the final rule incorporates several
changes to accommodate suggestions by commenters on the proposed rule. Exhibit 6.3
summarizes the annualized costs estimated for each regulatory alternative evaluated during the
rule development process using a 3 percent and 7 percent discount rate, respectively.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit 6.3 Total Annualized Costs of Regulatory Alternatives ($Millions, 2008$)
Total
AIM
Alt 2
Alt3
Final
Rule
3%
29.49
7.16
18.43
7.34
AIM
Alt 2
Alt3
Final
Rule
7%
29.08
7.07
18.19
7.25
Note: Detail may not add due to independent rounding.
Source: Exhibit 5.25.
Disproportionate Budgetary Effects
After exploring possible disproportionate effects of the ADWR on geographic areas and
groups of customers, EPA determined that the ADWR will not have any disproportionate
budgetary effects. Only one segment of the private economy is directly affected by this rule—
the air carrier industry. All air carriers with aircraft subject to the rule will incur some costs.
As seen in Exhibit 6.4, compliance costs and other effects of the ADWR will be greater
in certain regions, but aircraft owned by private companies do not rely on or impact a region's
financial resources. Also, the ADWR is a national mandate and applies uniformly to all air
carriers that meet the definition of a TNCWS. Regulated air carriers are expected to pass some
or all of the increased costs onto their customers, which are not necessarily from the same region
where the air carrier is based. The final rule is not expected to affect urban and rural customers
di sproporti onately.
Exhibit 6.4 Number and Percent of Air Carriers and Aircraft by Region
EPA
Region
1
2
3
4
5
6
7
8
9
10
Total
Number of Air
Carriers With
Headquarters in
Region
1
3
1
14
16
8
2
2
13
3
63
Percent of Total
Air Carriers
1 .6%
4.8%
1 .6%
22.2%
25.4%
12.7%
3.2%
3.2%
20.6%
4.8%
100%
Number of Aircraft
7
597
36
1,317
1,638
2,457
28
314
741
192
7,327
Percent of Total
Aircraft
0.1%
8.1%
0.5%
18.0%
22.4%
33.5%
0.4%
4.3%
10.1%
2.6%
100%
Source: Air carrier Web sites as of January 2007 and Exhibit 5.3.
Macroeconomic Effects
Under UMRA Section 202, EPA is required to estimate the potential macroeconomic
effects of the regulation. Although, as noted previously, the ADWR is not subject to UMRA
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
requirements, EPA did evaluate these potential effects. These include effects on productivity,
economic growth, full employment, and creation of Gross Domestic Product (GDP) (USEPA,
2000). Macroeconomic effects tend to be measurable in nationwide econometric models only if
the economic impact of the regulation reaches 0.25 percent to 0.5 percent of GDP. In the third
quarter of 2008, real GDP was $14,413 billion (U.S. Department of Commerce Bureau of
Economic Analysis (BEA), 2008); thus, a rule would have to cost at least $36 billion annually to
have a measurable effect. A regulation with a smaller aggregate effect is unlikely to have any
measurable impact, unless it is highly focused on a particular geographic region or economic
sector. The ADWR should not have a measurable effect on the national economy; the total
annualized costs for the final rule range from $7.25 million to $7.34 million using a 3 and 7
percent discount rate, respectively. Using these annualized figures as a measure, the annual costs
of the ADWR is an insignificant fraction of a $36 billion annual cost that would be considered a
measurable macroeconomic impact. Thus, annualized ADWR costs measured as a percentage of
the national GDP will only decline over time as GDP grows.
6. 9 Impacts on Sensitive Subpopulations
EPA's Office of Water has historically considered risks to sensitive subpopulations,
including children, when establishing drinking water assessments, advisories or other guidance,
and standards. Maximizing health protection for sensitive subpopulations requires minimizing
exposure to contaminated drinking water. The health effects of waterborne illnesses on sensitive
subpopulations are much more severe and debilitating than on the general population. These
sensitive subpopulations include pregnant women, the young, the elderly (especially those
weakened by other conditions), the malnourished and disease-impaired (especially those with
diabetes), and a broad category of those with compromised immune systems, such as Acquired
Immune Deficiency Syndrome (AIDS) patients, people with lupus or cystic fibrosis, transplant
recipients, and individuals undergoing chemotherapy (Rose, 1997). Immunocompromised
individuals are a growing proportion of the population with the relatively new and severe
problem magnified by the AIDS epidemic and the escalation in organ and tissue transplantations.
In total, these subgroups represent almost 20 percent of the population of the United States.
The duration, severity, and cost of waterborne illnesses are often much larger in
immunocompromised individuals. Similarly, infectious diseases are a major problem for the
elderly because immune function declines with age. As a result, waterborne diseases may
increase the possibility of significantly higher mortality rates in the elderly than in the general
population. Potential health benefits of the ADWR to both sensitive subpopulations and the
general public are discussed in greater detail in Chapter 4 of this document.
6.9.1 Protection of Children from Environmental Health Risks and Safety Risks
Executive Order 13045 (62 FR 19885, April 23, 1997) applies to any rule initiated after
April 21, 1998, that (1) is determined to be "economically significant" as defined under
Executive Order 12866; and (2) concerns an environmental, health, or safety risk that EPA has
reason to believe may have a disproportionate effect on children. If the regulatory action meets
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
both criteria, EPA must evaluate the environmental, health, or safety effects of the planned rule
on children, and explain why the planned regulation is preferable to other potentially effective
and reasonably feasible alternatives considered by the Agency.
The final ADWR is not subject to the Executive Order because it not is economically
significant as defined in Executive Order 12866. Nevertheless, EPA expects that the ADWR
will provide additional protection to children since they also travel in aircraft and may consume
drinking water onboard planes. Further, young children are more susceptible than adults to some
waterborne illnesses and the risk of mortality resulting from diarrhea is often greatest in the very
young and elderly (Rose, 1997; Gerba et al., 1996). Since viral and bacterial illnesses often
disproportionately affect children, the benefits of the rule accrue disproportionately to children.
6.10 Environmental Justice
Executive Order 12898 (59 FR 7629) establishes a Federal policy for incorporating
environmental justice into Federal agency missions by directing agencies to identify and address
disproportionately high adverse human health or environmental effects of its programs, policies,
and activities on minority and low-income populations. This Executive Order does not apply to
the final ADWR since air carrier customers have a choice whether to board an aircraft and
passengers do not necessarily represent minority or low-income populations. Furthermore, since
the rule applies to all air carriers that meet the definition of a TNCWS, passengers served by
regulated air carriers receive equal protection from contaminated aircraft water systems.
6.10.1 Federalism
Executive Order 13132, "Federalism" (64 FR 43255; August 10, 1999), requires EPA to
develop an accountable process to ensure "meaningful and timely input by State and local
officials in the development of regulatory policies that have Federalism implications." "Policies
that have Federalism implications" are defined in the executive order to include regulations that
have "substantial direct effects on the States, on the relationship between the national
government and the States, or on the distribution of power and responsibilities among the various
levels of government."
The ADWR will be implemented by EPA, in coordination with other federal agencies
including the FDA and FAA. The ADWR will not have Federalism implications because it will
not impose any direct compliance costs on State or local governments.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
6.11 Actions Concerning Regulations That Significantly Affect Energy Supply,
Distribution, or Use
Executive Order 13211, "Actions Concerning Regulations That Significantly Affect
Energy Supply, Distribution, or Use" (66 FR 28355; May 22, 2001), provides that agencies shall
prepare and submit to the Administrator of the Office of Information and Regulatory Affairs,
OMB, a statement of Energy Effects for certain actions identified as "significant energy actions."
Section 4(b) of Executive Order 13211 defines "significant energy actions" as "any action by an
agency (normally published in the Federal Register} that promulgates or is expected to lead to
the promulgation of a final rule or regulation, including notices of inquiry, advance notices of
proposed rulemaking, and notices of proposed rulemaking: (l)(i) that is a significant regulatory
action under Executive Order 12866 or any successor order, and (ii) is likely to have a significant
adverse effect on the supply, distribution, or use of energy; or (2) that is designated by the
Administrator of the Office of Information and Regulatory Affairs as a significant energy
action."
The Executive Order 13211 does not apply to the ADWR since none of the final rule
requirements involve installation of treatment or other components that use a measurable amount
of energy.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
7. References
Amvrosieva, T.V., L.P. Titov, M. Mulders, T. Hovi, O.V. Dyakonova, V.I. Votyakov, Z.B.
Kvacheva, V.F. Eremin, R.M. Sharko, S.V. Orlova, O.N. Kazinets, and Z.F. Bogush.
2001. Viral water contamination as the cause of aseptic meningitis outbreak in Belarus.
Central European J Public Health 9(3): 154-157.
Barwick, R.S., D.A. Levy, G.F. Craun, MJ. Beach, and R.L. Calderon. 2000. Surveillance for
waterborne-disease outbreaks - United States, 1997-1998. Morbidity and Mortality
Weekly Report 49(SS04): 1-35.
Blackburn, E.G., G.F. Craun, J.S. Yoder, V. Hill, R.L. Calderon, N. Chen, S. H. Lee, D.A. Levy,
and M. J. Beach. 2004. Surveillance for waterborne-disease outbreaks associated with
drinking water — United States, 2001—2002. Morbidity and Mortality Weekly Report
53(SS08):23-45.
Bureau of Economic Analysis. 2008. http://www.bea.gov/national/Index.htm.
Bureau of Labor Statistics (BLS). 2007. www.bls.gov/data/.
Craun, G.F. and R. Calderon. 1996. Microbial risks in groundwater systems: epidemiology of
waterborne outbreaks. In: Under the Microscope: Examining Microbes in Groundwater.
Boston: Proceedings of the Groundwater Foundation's 12th Annual Fall Symposium.
Dun & Bradstreet. Small Business Solutions. Company Profile Reports.
www. smallbusiness. dnb. com.
Gerba, C.P., J.B. Rose, and C.N. Haas. 1996. Sensitive subpopulations: who is at the greatest
ri sk? International Journal of Food and Microbiology. 30:113-123.
Kim, K.S., G. Hufnagel, N.M. Chapman, and S. Tracy. 2001. The group B coxsackieviruses
and myocarditis. Rev. Med. Virol. ll(6):355-68.
Lee, S.H. and SJ. Kim. 2002. Detection of infectious enteroviruses and adenoviruses in tap
water in urban areas in Korea. Water Research 36(l):248-256.
Lee, S.H., D.A. Levy, G.F. Craun, MJ. Beach, and R.L. Calderon. 2002. Surveillance for
waterborne disease outbreaks, United States, 1999-2000. Morbidity and Mortality
Weekly Report, Surveillance Summaries 51(SS08):l-28.
Levy, D.A., M.S. Bens, G.F. Craun, R.L. Calderon, and B.L. Herwaldt. 1998. Surveillance for
Waterborne Disease Outbreaks - United States, 1995-1996. MMWR 47(55-5): 1-34.
Page 7-1
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
Moore, A.C., B.L. Herwaldt, G.F. Craun, R.L. Calderon, A.K. Highsmith, and D.D. Juranek.
1993. Surveillance for waterborne disease outbreaks - United States, 1991-1992.
MMWR. 42(SS-5):l-22 (November 19).
Office of Management and Budget, Circular A-4, September 2003.
Park, S.R., W.G. Mackay, and D.C. Reid. 2001. Helicobacter sp. recovered from drinking water
biofilm sampled from a water distribution system. Water Research 35(6): 1624-1626.
Rose, J.B. 1997. Environmental ecology of cryptosporidium and public health implications.
Annual Review of Public Health. 18:135-161.
SAB and USEPA. 1990. Reducing risk: setting priorities and strategies for environmental
protection. Washington, DC: U.S. EPA Science Advisory Board. SAB-EC
Sepulveda, A.R. and D.Y. Graham. 2002. Role of Helicobacter pylori in gastric carcinogenesis.
Gastroenterol. Clin. North America 31(2):517-535.
USEPA. 1986. Water Supply Guidance 29: "Plan for Implementation of the Safe Drinking
Water Act on Interstate Carrier Conveyance"
USEPA. 1993. Executive Order 12866, Regulatory Planning and Review. In Federal Register,
Vol. 58, page 51735, September 30, 1993.
USEPA. 1996. Economic analysis of Federal regulations under Executive Order 12866. Office
of Management and Budget. January 11, 1996.
USEPA. 1998. Guidance on Implementing the Capacity Development Provisions of the Safe
Drinking Water Act Amendments of 1996.
USEPA. 1999. Interim Guidance for EPA Rulewriters for the RFA as amended by the SBREFA.
USEPA. 2000. Guidelines for Preparing Economic Analyses. U.S. EPA Office of the
Administrator. EPA/240-R-00-003. September 2000.
USEPA. 2005. ICR Handbook: EPA's Guide to Writing Information Collection Requests
Under the Paperwork Reduction Act of 1995. Revised November 2005. Office of
Environmental Information, Collection Strategies Division, p. A-36.
USEPA. 2008a. Economic and Supporting Analysis Document for the Proposed Aircraft
Drinking Water Rule. EPA 816-D-08-002. April 2008.
USEPA. 2008b. Elements of the Proposed Aircraft Drinking Water Rule. In Federal Register,
Vol. 73, No. 69, page 19320. April 9, 2008.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
USEPA. 2009. Information Collection Request for the Aircraft Drinking Water Rule. OMB
Draft. March 2009.
US Food and Drug Administration (FDA). 2005. Title 21 - Food and Drugs, Chapter 1 - Food
and Drug Administration, Part 1250 - Interstate Conveyance Sanitation.
www.accessdata.fda.gov/.
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Appendix A
ADWR Aircraft and Population Baseline
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit A.1 Background Calculations for ADWR Aircraft and Population Baseline (as of January 2007)
Code for Airline Nam
Number of Aircraft
Flights/Year/Aircraft
Carrying Capai
(passengers/air<
Estimated # of
) as se n g e rslai re raft
Total # of
assengersfyeai
Total # of Onboard
staff/year
Number of Galleys
Total # of
Available
Sampling Points
Total Available Sampling Points = 1
;AAB 340B JSFS)
Total Available Sampling Points = 2
Beechjet 4QQ A/Hawker 4QOXP
Dash 8Q200 (DH8)
Dash 8 Q400 (DH4)
Total Available Sampling Points = 3
Falcon 2000EX
Page A-2
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Code for Airline Nam
Number of Aircraft
Flights/Year/Aircraft
Carrying Capacity
(p ass e n g e rs/ai re raft)
Total # of
assengers/yeai
Total # of Onboard
staff/year
Number of Galleys
Total # of
Available
Sampling Points
Total Available Sampling Points = 4
Total Available Sampling Points = 5
Total Available Sampling Points = 6
B737-700 (73G)
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Number of Aircraft
Flights/Year/Aircraft
Carrying Capacity
(p ass e n g e rs/ai re raft)
Total # of
assengers/yeai
Total # of Onboard
staff/year
Number of Galleys
Total # of
Available
Sampling Points
Total Available Sampling Points = 7
] (MD-82/M[>83)
Total Available Sampling Points = 8
> 9 Total Available Sampling Points
Total All Sampling Point Categories
Page A-4
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit A.2 ADWR Aircraft and Population Baseline (as of January 2007)
# of Available Sampling
Points
A
1
2
3
4
5
6
7
8
>9
Total
# of Aircraft
B
381
2,080
756
421
956
871
298
809
755
7,327
Total # of Available
Sampling Points
C=B*A
381
4,160
2,268
1,684
4,780
5,226
2,086
6,472
9,354
36,411
# of Onboard Staff/year
D
1,978,974
8,639,938
2,332,151
2,510,833
6,641,598
3,879,569
1,414,970
3,765,459
3,998,054
35,161,545
# of Passengers/year
E
24,980,980
104,430,089
22,935,259
51,846,929
158,813,021
91,360,628
34,239,869
93,648,921
126,176,568
708,432,263
Total # of Potentially
Affected Persons/year
F=D+E
26,959,953
113,070,026
25,267,410
54,357,762
165,454,619
95,240,197
35,654,839
97,414,380
130,174,622
743,593,809
Aircraft and population baseline data as of January 2007.
Source: see Section 3.2.1 for data sources.
Notes:
(A) Each qualifying lavatory and galley on an aircraft is assumed to have only one sampling point.
representative of the number of lavatories and galleys on an aircraft.
(B), (D), (E) Derived from Appendix B.
(C) Average number of sampling points used for > 9 sampling points size category.
Therefore, the number of available sampling points is
Page A-5
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Appendix B
Aircraft Drinking Water Sampling Data
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
Aircraft Drinking Water Sampling Data
Source of Data
Aircraft drinking water sampling data was collected as part of the Administrative Orders on Consent
(AOC). AOCs were established by Office of Enforcement and Compliance Assistance (OECA) with 45
air carriers. EPA has processed sampling data from 25 of the 45 air carriers as of December 31, 2008.
Samples were taken from 2005 to 2008. Data for air carriers with an approved quality assurance
project plan (QAPP) and comprehensive representative monitoring plan (CRMP) are only available for
2 air carriers in 2005, 5 air carriers in 2006, 8 air carriers in 2007, and 12 air carriers in 2008. A
description of the sampling process used and other details can be found in the AOCs. Only data
collected under approved QAPPs and CRMPs was used for the Occurrence Baseline for the final
ADWR.
Features of the Data (based on AOCs)
Total number of airlines under AOCs is 45.
Total estimated number of aircraft is 6,046. Each aircraft is a Transient Non-Community Water System
(TNCWS).
The source of the water is considered to be finished surface water or ground water under the direct
influence of surface water received from a PWS.
Each aircraft system's data covers, in-part or full, 4 quarters (1 year) each for Monitoring Period. Data
represents different years: 2005 to 2008.
Page B-l
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit Number
B.1
B.2
B.3
B.4
B.5
Exhibit Title
Monitoring Period for Year 2005: Sampling Data for All Airlines
Monitoring Period for Year 2006: Sampling Data for All Airlines
Monitoring Period for Year 2007: Sampling Data for All Airlines
Monitoring Period for Year 2008: Sampling Data for All Airlines
Montioring Period for All Years (2005-2008): Sampling Data for All Airlines
Page Number
B-3
B-5
B-7
B-9
B-11
Page B-2
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit B.1 Mentioning Period for Year 2005: Sampling Data for All Airlines
Unknown Calendar Qtr
Calendar Qtr 1
Calendar Qtr 2
Calendar Qtr 3
Calendar Qtr 4
Total
Unknown Calendar Qtr
Calendar Qtr 1
Calendar Qtr 2
Calendar Qtr 3
Calendar Qtr 4
Total
Unknown Calendar Qtr
Calendar Qtr 1
Calendar Qtr 2
Calendar Qtr 3
Calendar Qtr 4
Total
Routine Sam
Percent TC+
pies
Of the TC+
samples,
percent EC+
or FC+
Total * of
TC+
samples
Total * TC+
samples that
are EC+ or
FC+
Total * of TC
Samples
Percent CL2
Residual
Non-detect
Total * of
CL2
Residual
Non-detect
Total * of
Disinfection
Unknown
Total * of
CL2
Residual
Samples
Total Conform and Chlorine Residual Data for All Airlines
0.0%
0.0%
2.7%
0.0%
1.8%
2.5%
0.0%
0.0%
1.5%
0.0%
0.0%
1.3%
0
0
65
0
14
79
0
0
1
0
0
1
0
0
2,402
30
773
3205
0.0%
0.0%
5.5%
0.0%
3.2%
5.0%
0
0
129
0
17
146
0
0
50
0
241
291
0
0
2,352
30
532
2,914
Total Conform and Chlorine Residual Data for Airlines with Approved QAPP & CRMP
0.0%
0.0%
2.7%
0.0%
1.8%
2.5%
0.0%
0.0%
1.5%
0.0%
0.0%
1.3%
0
0
65
0
14
79
0
0
1
0
0
1
0
0
2,402
22
757
3181
0.0%
0.0%
5.5%
0.0%
2.1%
4.8%
0
0
129
0
11
140
0
0
50
0
241
291
0
0
2,352
22
516
2,890
Total Conform and Chlorine Residual Data for Airlines with Unapproved QAPP & CRMP
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
8
16
24
0.0%
0.0%
0.0%
0.0%
37.5%
25.0%
0
0
0
0
6
6
0
0
0
0
0
0
0
0
0
8
16
24
Repeat Samples
Percent TC+
Of the TC+
samples,
percent EC+
or FC+
Total * of
TC+
samples
Total * TC+
samples that
are EC+ or
FC+
Total * of TC
Samples
Percent CL2
Residual
Non-detect
Total * of
CL2
Residual
Non-detect
Total * of
Disinfection
Unknown
Total * of
CL2
Residual
Samples
Total Conform and Chlorine Residual Data for All Airlines
0.0%
0.0%
12.5%
16.7%
1.4%
9.1%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0
0
47
8
3
58
0
0
0
0
0
0
0
0
375
48
215
638
0.0%
0.0%
2.2%
0.0%
7.0%
3.4%
0
0
8
0
12
20
0
0
4
0
43
47
0
0
371
48
172
591
Total Conform and Chlorine Residual Data for Airlines with Approved QAPP & CRMP
0.0%
0.0%
12.5%
16.7%
1.4%
9.1%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0
0
47
8
3
58
0
0
0
0
0
0
0
0
375
48
215
638
0.0%
0.0%
2.2%
0.0%
7.0%
3.4%
0
0
8
0
12
20
0
0
4
0
43
47
0
0
371
48
172
591
Total Conform and Chlorine Residual Data for Airlines with Unapproved QAPP & CRMP
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
8
16
24
0.0%
0.0%
0.0%
0.0%
37.5%
25.0%
0
0
0
0
6
6
0
0
0
0
0
0
0
0
0
8
16
24
Page B-3
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit B.1 Mentioning Period for Year 2005: Sampling Data for All Airlines
Unknown Calendar Qtr
Calendar Qtr 1
Calendar Qtr 2
Calendar Qtr 3
Calendar Qtr 4
Total
Unknown Calendar Qtr
Calendar Qtr 1
Calendar Qtr 2
Calendar Qtr 3
Calendar Qtr 4
Total
Unknown Calendar Qtr
Calendar Qtr 1
Calendar Qtr 2
Calendar Qtr 3
Calendar Qtr 4
Total
All Samples
Percent TC+
Of the TC+
samples,
percent EC+
or FC+
Total * of
TC+
samples
Total * TC+
samples that
are EC+ or
FC+
Total * of TC
Samples
Percent CL2
Residual
Non-detect
Total * of
CL2
Residual
Non-detect
Total * of
Disinfection
Unknown
Total * of
CL2
Residual
Samples
Total Conform and Chlorine Residual Data for All Airlines
0.0%
0.0%
4.0%
10.3%
1.7%
3.6%
0.0%
0.0%
0.9%
0.0%
0.0%
0.7%
0
0
112
8
17
137
0
0
1
0
0
1
0
0
2,777
78
988
3843
0.0%
0.0%
5.0%
0.0%
4.1%
4.7%
0
0
137
0
29
166
0
0
54
0
284
338
0
0
2,723
78
704
3,505
Total Conform and Chlorine Residual Data for Airlines with Approved QAPP & CRMP
0.0%
0.0%
4.0%
11.4%
1.7%
3.6%
0.0%
0.0%
0.9%
0.0%
0.0%
0.7%
0
0
112
8
17
137
0
0
1
0
0
1
0
0
2,777
70
972
3819
0.0%
0.0%
5.0%
0.0%
3.3%
4.6%
0
0
137
0
23
160
0
0
54
0
284
338
0
0
2,723
70
688
3,481
Total Conform and Chlorine Residual Data for Airlines with Unapproved QAPP & CRMP
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Page B-4
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit B.2 Mentioning Period for Year 2006: Sampling Data for All Airlines
Unknown Calendar Qtr
Calendar Qtr 1
Calendar Qtr 2
Calendar Qtr 3
Calendar Qtr 4
Totals
Unknown Calendar Qtr
Calendar Qtr 1
Calendar Qtr 2
Calendar Qtr 3
Calendar Qtr 4
Totals
Unknown Calendar Qtr
Calendar Qtr 1
Calendar Qtr 2
Calendar Qtr 3
Calendar Qtr 4
Total
Routine Sam
Percent TC+
pies
Of the TC+
samples,
percent EC+
or FC+
Total * of
TC+
samples
Total * TC+
samples that
are EC+ or
FC+
Total * of TC
Samples
Percent CL2
Residual
Non-detect
Total * of
CL2
Residual
Non-detect
Total * of
Disinfection
Unknown
Total * of
CL2
Residual
Samples
Total Conform and Chlorine Residual Data for All Airlines
0.0%
2.0%
4.0%
5.5%
2.7%
3.5%
0.0%
0.0%
9.1%
1.9%
0.0%
3.3%
0
21
33
53
15
122
0
0
3
1
0
4
24
1,070
823
969
565
3451
8.3%
5.0%
14.0%
44.4%
45.4%
25.7%
2
38
78
326
206
650
0
308
265
234
111
918
24
762
558
735
454
2,533
Total Conform and Chlorine Residual Data for Airlines with Approved QAPP & CRMP
0.0%
2.0%
3.5%
2.6%
1.9%
2.5%
0.0%
0.0%
12.0%
0.0%
0.0%
4.2%
0
20
25
18
9
72
0
0
3
0
0
3
0
1,024
722
702
484
2932
0.0%
3.8%
12.2%
44.6%
44.9%
22.9%
0
27
56
213
168
464
0
308
263
224
110
905
0
716
459
478
374
2,027
Total Conform and Chlorine Residual Data for Airlines with Unapproved QAPP & CRMP
0.0%
2.2%
7.9%
13.1%
7.4%
9.6%
0.0%
0.0%
0.0%
2.9%
0.0%
2.0%
0
1
8
35
6
50
0
0
0
1
0
1
24
46
101
267
81
519
8.3%
23.9%
22.2%
44.0%
47.5%
36.8%
2
11
22
113
38
186
0
0
2
10
1
13
24
46
99
257
80
506
Repeat Samples
Percent TC+
Of the TC+
samples,
percent EC+
or FC+
Total * of
TC+
samples
Total * TC+
samples that
are EC+ or
FC+
Total * of TC
Samples
Percent CL2
Residual
Non-detect
Total * of
CL2
Residual
Non-detect
Total * of
Disinfection
Unknown
Total * of
CL2
Residual
Samples
Total Conform and Chlorine Residual Data for All Airlines
0.0%
1.5%
4.8%
2.9%
1.7%
3.0%
0.0%
0.0%
9.5%
0.0%
0.0%
4.4%
0
4
42
32
12
90
0
0
4
0
0
4
24
260
880
1,098
714
2976
0.0%
8.8%
5.3%
34.6%
55.7%
28.5%
0
19
46
308
398
771
0
44
16
207
0
267
24
216
864
891
714
2,709
Total Conform and Chlorine Residual Data for Airlines with Approved QAPP & CRMP
0.0%
1.6%
4.8%
1.9%
1.5%
2.7%
0.0%
0.0%
9.8%
0.0%
0.0%
5.6%
0
4
41
16
10
71
0
0
4
0
0
4
0
252
846
864
676
2638
0.0%
7.2%
5.3%
34.6%
57.0%
28.7%
0
15
45
299
385
744
0
44
0
0
0
44
0
208
846
864
676
2,594
Total Conform and Chlorine Residual Data for Airlines with Unapproved QAPP & CRMP
0.0%
0.0%
2.9%
6.8%
5.3%
5.6%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0
0
1
16
2
19
0
0
0
0
0
0
24
8
34
234
38
338
0.0%
50.0%
5.6%
33.3%
34.2%
23.5%
0
4
1
9
13
27
0
0
16
207
0
223
24
8
18
27
38
115
Page B-5
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit B.2 Mentioning Period for Year 2006: Sampling Data for All Airlines
Unknown Calendar Qtr
Calendar Qtr 1
Calendar Qtr 2
Calendar Qtr 3
Calendar Qtr 4
Totals
Unknown Calendar Qtr
Calendar Qtr 1
Calendar Qtr 2
Calendar Qtr 3
Calendar Qtr 4
Totals
Unknown Calendar Qtr
Calendar Qtr 1
Calendar Qtr 2
Calendar Qtr 3
Calendar Qtr 4
Total
All Samples
Percent TC+
Of the TC+
samples,
percent EC+
or FC+
Total # of
TC+
samples
Total # TC+
samples that
are EC+ or
FC+
Total # of TC
Samples
Percent CL2
Residual
Non-detect
Total # of
CL2
Residual
Non-detect
Total # of
Disinfection
Unknown
Total # of
CL2
Residual
Samples
Total Conform and Chlorine Residual Data for All Airlines
0.0%
1.9%
4.4%
4.1%
2.1%
3.3%
0.0%
0.0%
9.3%
1.2%
0.0%
3.8%
0
25
75
85
27
212
0
0
7
1
0
8
48
1,330
1,703
2,067
1,279
6427
4.2%
5.8%
8.7%
39.0%
51.7%
27.1%
2
57
124
634
604
1,421
0
352
281
441
111
1,185
48
978
1,422
1,626
1,168
5,242
Total Conform and Chlorine Residual Data for Airlines with Approved QAPP & CRMP
0.0%
1.9%
4.2%
2.2%
1.6%
2.6%
0.0%
0.0%
10.6%
0.0%
0.0%
4.9%
0
24
66
34
19
143
0
0
7
0
0
7
0
1,276
1,568
1,566
1,160
5570
0.0%
4.5%
7.7%
38.2%
52.7%
26.1%
0
42
101
512
553
1,208
0
352
263
224
110
949
0
924
1,305
1,342
1,050
4,621
Total Conform and Chlorine Residual Data for Airlines with Unapproved QAPP & CRMP
0.0%
1.9%
6.7%
10.2%
6.7%
8.1%
0.0%
0.0%
0.0%
2.0%
0.0%
1.4%
0
1
9
51
8
69
0
0
0
1
0
1
48
54
135
501
119
857
4.2%
27.8%
19.7%
43.0%
43.2%
34.3%
2
15
23
122
51
213
0
0
18
217
1
236
48
54
117
284
118
621
Page B-6
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit B.3 Mentioning Period for Year 2007: Sampling Data for All Airlines
Unknown Calendar Qtr
Calendar Qtr 1
Calendar Qtr 2
Calendar Qtr 3
Calendar Qtr 4
Total
Unknown Calendar Qtr
Calendar Qtr 1
Calendar Qtr 2
Calendar Qtr 3
Calendar Qtr 4
Total
Unknown Calendar Qtr
Calendar Qtr 1
Calendar Qtr 2
Calendar Qtr 3
Calendar Qtr 4
Total
Routine Sam
Percent TC+
pies
OftheTC*
samples,
percent EC+
or FC+
Total * of
TC+
samples
Total * TC+
samples that
are EC+ or
FC+
Total * of TC
Samples
Percent CL2
Residual
Non-detect
Total * of
CL2
Residual
Non-detect
Total * of
Disinfection
Unknown
Total * of
CL2
Residual
Samples
Total Conform and Chlorine Residual Data for All Airlines
0.0%
1.7%
2.7%
3.8%
7.0%
3.4%
0.0%
4.5%
0.0%
2.2%
11.1%
5.1%
0
22
45
45
63
175
0
1
0
1
7
9
44
1,312
1,698
1,177
901
5132
0.0%
29.4%
13.4%
27.1%
11.7%
20.4%
0
310
179
266
89
844
38
258
361
196
141
994
6
1,054
1,337
981
760
4,138
Total Conform and Chlorine Residual Data for Airlines with Approved QAPP & CRMP
0.0%
1.8%
2.7%
3.9%
7.5%
3.7%
0.0%
0.0%
0.0%
0.0%
11.1%
4.1%
0
21
42
43
63
169
0
0
0
0
7
7
0
1,158
1,529
1,105
837
4629
0.0%
19.7%
3.9%
22.1%
5.2%
12.5%
0
177
46
201
36
460
0
258
361
196
141
956
0
900
1,168
909
696
3,673
Total Conform and Chlorine Residual Data for Airlines with Unapproved QAPP & CRMP
0.0%
0.6%
1.8%
2.8%
0.0%
1.2%
0.0%
100.0%
0.0%
50.0%
0.0%
33.3%
0
1
3
2
0
6
0
1
0
1
0
2
44
154
169
72
64
503
0.0%
86.4%
78.7%
90.3%
82.8%
82.6%
0
133
133
65
53
384
38
0
0
0
0
38
6
154
169
72
64
465
Repeat Samples
Percent TC+
OftheTC+
samples,
percent EC+
or FC+
Total * of
TC+
samples
Total * TC+
samples that
are EC+ or
FC+
Total * of TC
Samples
Percent CL2
Residual
Non-detect
Total * of
CL2
Residual
Non-detect
Total * of
Disinfection
Unknown
Total * of
CL2
Residual
Samples
Total Conform and Chlorine Residual Data for All Airlines
0.0%
1.0%
5.0%
12.1%
8.1%
5.6%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0
7
13
36
41
97
0
0
0
0
0
0
0
670
262
297
509
1738
0.0%
49.1%
7.7%
33.1%
1.4%
27.3%
0
322
18
79
6
425
0
14
28
58
83
183
0
656
234
239
426
1,555
Total Conform and Chlorine Residual Data for Airlines with Approved QAPP & CRMP
0.0%
1.1%
5.0%
12.5%
8.1%
5.6%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0
7
13
36
41
97
0
0
0
0
0
0
0
666
258
289
509
1722
0.0%
49.4%
6.1%
30.7%
1.4%
26.8%
0
322
14
71
6
413
0
14
28
58
83
183
0
652
230
231
426
1,539
Total Conform and Chlorine Residual Data for Airlines with Unapproved QAPP & CRMP
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0
0
0
0
0
0
0
0
0
0
0
0
0
4
4
8
0
16
0.0%
0.0%
100.0%
100.0%
0.0%
75.0%
0
0
4
8
0
12
0
0
0
0
0
0
0
4
4
8
0
16
Page B-7
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit B.3 Mentioning Period for Year 2007: Sampling Data for All Airlines
Unknown Calendar Qtr
Calendar Qtr 1
Calendar Qtr 2
Calendar Qtr 3
Calendar Qtr 4
Total
Unknown Calendar Qtr
Calendar Qtr 1
Calendar Qtr 2
Calendar Qtr 3
Calendar Qtr 4
Total
Unknown Calendar Qtr
Calendar Qtr 1
Calendar Qtr 2
Calendar Qtr 3
Calendar Qtr 4
Total
All Samples
Percent TC+
OftheTC*
samples,
percent EC+
or FC+
Total * of
TC+
samples
Total * TC+
samples that
are EC+ or
FC+
Total * of TC
Samples
Percent CL2
Residual
Non-detect
Total * of
CL2
Residual
Non-detect
Total * of
Disinfection
Unknown
Total * of
CL2
Residual
Samples
Total Conform and Chlorine Residual Data for All Airlines
0.0%
1.5%
3.0%
5.5%
7.4%
4.0%
0.0%
3.4%
0.0%
1.2%
6.7%
3.3%
0
29
58
81
104
272
0
1
0
1
7
9
44
1,982
1,960
1,474
1,410
6870
0.0%
37.0%
12.5%
28.3%
8.0%
22.3%
0
632
197
345
95
1,269
38
272
389
254
224
1,177
6
1,710
1,571
1,220
1,186
5,693
Total Conform and Chlorine Residual Data for Airlines with Approved QAPP & CRMP
0.0%
1.5%
3.1%
5.7%
7.7%
4.2%
0.0%
0.0%
0.0%
0.0%
6.7%
2.6%
0
28
55
79
104
266
0
0
0
0
7
7
0
1,824
1,787
1,394
1,346
6351
0.0%
32.2%
4.3%
23.9%
3.7%
16.7%
0
499
60
272
42
873
0
272
389
254
224
1,139
0
1,552
1,398
1,140
1,122
5,212
Total Conform and Chlorine Residual Data for Airlines with Unapproved QAPP & CRMP
0.0%
0.6%
1.7%
2.5%
0.0%
1.2%
0.0%
100.0%
0.0%
50.0%
0.0%
33.3%
0
1
3
2
0
6
0
1
0
1
0
2
44
158
173
80
64
519
0.0%
84.2%
79.2%
91.3%
82.8%
82.3%
0
133
137
73
53
396
38
0
0
0
0
38
6
158
173
80
64
481
Page B-8
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit B.4 Mentioning Period for Year 2008: Sampling Data for All Airlines
Unknown Calendar Qtr
Calendar Qtr 1
Calendar Qtr 2
Calendar Qtr 3
Calendar Qtr 4
Total
Unknown Calendar Qtr
Calendar Qtr 1
Calendar Qtr 2
Calendar Qtr 3
Calendar Qtr 4
Total
Unknown Calendar Qtr
Calendar Qtr 1
Calendar Qtr 2
Calendar Qtr 3
Calendar Qtr 4
Total
Routine Sam
Percent TC+
pies
OftheTC*
samples,
percent EC+
or FC+
Total * of
TC+
samples
Total * TC+
samples that
are EC+ or
FC+
Total * of TC
Samples
Percent CL2
Residual
Non-detect
Total * of
CL2
Residual
Non-detect
Total * of
Disinfection
Unknown
Total * of
CL2
Residual
Samples
Total Conform and Chlorine Residual Data for All Airlines
0.0%
6.0%
6.7%
17.8%
0.0%
6.9%
0.0%
6.7%
4.5%
0.0%
0.0%
4.9%
0
60
66
18
0
144
0
4
3
0
0
7
0
995
988
101
0
2084
0.0%
23.8%
22.7%
24.2%
0.0%
23.3%
0
225
217
24
0
466
0
50
33
2
0
85
0
945
955
99
0
1,999
Total Conform and Chlorine Residual Data for Airlines with Approved QAPP & CRMP
0.0%
6.1%
6.7%
17.8%
0.0%
7.0%
0.0%
6.8%
4.5%
0.0%
0.0%
4.9%
0
59
66
18
0
143
0
4
3
0
0
7
0
963
988
101
0
2052
0.0%
23.2%
22.7%
24.2%
0.0%
23.0%
0
212
217
24
0
453
0
50
33
2
0
85
0
913
955
99
0
1,967
Total Conform and Chlorine Residual Data for Airlines with Unapproved QAPP & CRMP
0.0%
3.1%
0.0%
0.0%
0.0%
3.1%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0
1
0
0
0
1
0
0
0
0
0
0
0
32
0
0
0
32
0.0%
40.6%
0.0%
0.0%
0.0%
40.6%
0
13
0
0
0
13
0
0
0
0
0
0
0
32
0
0
0
32
Repeat Samples
Percent TC+
OftheTCt
samples,
percent EC+
or FC+
Total * of
TC+
samples
Total * TC+
samples that
are EC+ or
FC+
Total * of TC
Samples
Percent CL2
Residual
Non-detect
Total * of
CL2
Residual
Non-detect
Total * of
Disinfection
Unknown
Total * of
CL2
Residual
Samples
Total Conform and Chlorine Residual Data for All Airlines
0.0%
13.7%
10.4%
10.2%
0.0%
12.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0
63
44
5
0
112
0
0
0
0
0
0
0
459
424
49
0
932
0.0%
27.2%
30.9%
12.2%
0.0%
28.1%
0
111
117
5
0
233
0
51
45
8
0
104
0
408
379
41
0
828
Total Conform and Chlorine Residual Data for Airlines with Approved QAPP & CRMP
0.0%
13.7%
10.4%
10.2%
0.0%
12.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0
63
44
5
0
112
0
0
0
0
0
0
0
459
424
49
0
932
0.0%
27.2%
30.9%
12.2%
0.0%
28.1%
0
111
117
5
0
233
0
51
45
8
0
104
0
408
379
41
0
828
Total Conform and Chlorine Residual Data for Airlines with Unapproved QAPP & CRMP
0.0%
3.1%
0.0%
0.0%
0.0%
3.1%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0
1
0
0
0
1
0
0
0
0
0
0
0
32
0
0
0
32
0.0%
40.6%
0.0%
0.0%
0.0%
40.6%
0
13
0
0
0
13
0
0
0
0
0
0
0
32
0
0
0
32
Page B-9
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit B.4 Mentioning Period for Year 2008: Sampling Data for All Airlines
Unknown Calendar Qtr
Calendar Qtr 1
Calendar Qtr 2
Calendar Qtr 3
Calendar Qtr 4
Total
Unknown Calendar Qtr
Calendar Qtr 1
Calendar Qtr 2
Calendar Qtr 3
Calendar Qtr 4
Total
Unknown Calendar Qtr
Calendar Qtr 1
Calendar Qtr 2
Calendar Qtr 3
Calendar Qtr 4
Total
All Samples
Percent TC+
OftheTC*
samples,
percent EC+
or FC+
Total * of
TC+
samples
Total * TC+
samples that
are EC+ or
FC+
Total * of TC
Samples
Percent CL2
Residual
Non-detect
Total * of
CL2
Residual
Non-detect
Total * of
Disinfection
Unknown
Total * of
CL2
Residual
Samples
Total Conform and Chlorine Residual Data for All Airlines
0.0%
8.5%
7.8%
15.3%
0.0%
8.5%
0.0%
3.3%
2.7%
0.0%
0.0%
2.7%
0
123
110
23
0
256
0
4
3
0
0
7
0
1,454
1,412
150
0
3016
0.0%
24.8%
25.0%
20.7%
0.0%
24.7%
0
336
334
29
0
699
0
101
78
10
0
189
0
1,353
1,334
140
0
2,827
Total Conform and Chlorine Residual Data for Airlines with Approved QAPP & CRMP
0.0%
8.6%
7.8%
15.3%
0.0%
8.5%
0.0%
3.3%
2.7%
0.0%
0.0%
2.7%
0
122
110
23
0
255
0
4
3
0
0
7
0
1,422
1,412
150
0
2984
0.0%
24.5%
25.0%
20.7%
0.0%
24.5%
0
323
334
29
0
686
0
101
78
10
0
189
0
1,321
1,334
140
0
2,795
Total Conform and Chlorine Residual Data for Airlines with Unapproved QAPP & CRMP
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Page B-10
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit B.5 Montioring Period for All Years (2005-2008): Sampling Data for All Airlines
Unknown Calendar Qtr
Calendar Qtr 1
Calendar Qtr 2
Calendar Qtr 3
Calendar Qtr 4
Total
Unknown Calendar Qtr
Calendar Qtr 1
Calendar Qtr 2
Calendar Qtr 3
Calendar Qtr 4
Total
Unknown Calendar Qtr
Calendar Qtr 1
Calendar Qtr 2
Calendar Qtr 3
Calendar Qtr 4
Total
Region 2
Region 4
Region 5
Region 6
Region 9
Region 10
Total
Galley
Lavatory
Composite*
Unknown Sample Site
Total
Galley
Lavatory
Composite*
Unknown Sample Site
Total
Routine Samples
Percent TC+
OftheTC+
samples,
percent EC+
or FC+
Total # of
TC+ samples
Total # TC+
samples that
are EC+ or
FC+
Total # of TC
Samples
Percent CL2
Residual Non
detect
Total # of CL2
Residual Non
detect
Total # of
Disinfection
Unknown
Total # of CL2
Residual
Samples
Total Coliform and Chlorine Residual Data for All Airlines
0.0%
3.1%
3.5%
5.1%
4.1%
3.7%
0.0%
4.9%
3.3%
1.7%
7.6%
4.0%
0
103
209
116
92
520
0
5
7
2
7
21
68
3,377
5,911
2,277
2,239
13,872
6.7%
20.8%
11.6%
33.4%
17.9%
18.2%
2
573
603
616
312
2,106
38
616
709
432
493
2,288
30
2,761
5,202
1,845
1,746
11,584
Total Coliform and Chlorine Residual Data for Airlines with Approved QAPP & CRMP
0.0%
3.2%
3.5%
4.1%
4.1%
3.6%
0.0%
4.0%
3.5%
0.0%
8.1%
3.9%
0
100
198
79
86
463
0
4
7
0
7
18
0
3,145
5,641
1,930
2,078
12,794
0.0%
16.4%
9.1%
29.0%
13.6%
14.4%
0
416
448
438
215
1,517
0
616
707
422
492
2,237
0
2,529
4,934
1,508
1,586
10,557
Total Coliform and Chlorine Residual Data for Airlines with Unapproved QAPP & CRMP
0.0%
1 .3%
4.1%
10.7%
3.7%
5.3%
0.0%
33.3%
0.0%
5.4%
0.0%
5.3%
0
3
11
37
6
57
0
1
0
2
0
3
68
232
270
347
161
1,078
6.7%
67.7%
57.8%
52.8%
60.6%
57.4%
2
157
155
178
97
589
38
0
2
10
1
51
30
232
268
337
160
1,027
Total Coliform and Chlorine Residual Data for All Airlines by Region
5.4%
4.6%
1 .8%
6.2%
4.0%
4.2%
3.7%
16.7%
2.1%
1.1%
5.0%
12.8%
0.0%
4.0%
12
189
95
160
47
17
520
2
4
1
8
6
0
21
222
4,119
5,379
2,585
1,166
401
13,872
23.4%
13.6%
4.4%
30.8%
50.5%
0.0%
18.2%
51
553
142
796
564
0
2,106
4
55
2,122
0
49
58
2,288
218
4,064
3,257
2,585
1,117
343
11,584
Total Coliform and Chlorine Residual Data for All Airlines by Sample Location
0.9%
6.1%
14.3%
3.1%
3.7%
12.7%
3.0%
0.0%
0.0%
4.0%
55
462
1
2
520
7
14
0
0
21
6,224
7,576
7
65
13,872
18.3%
18.0%
66.7%
0.0%
18.2%
1,056
1,046
4
0
2,106
451
1,780
1
56
2,288
5,773
5,796
6
9
11,584
Total Coliform and Chlorine Residual Data for Airlines with Approved QAPP & CRMP by Sample Location
0.8%
5.9%
14.3%
3.1%
3.6%
12.8%
2.9%
0.0%
0.0%
3.9%
47
413
1
2
463
6
12
0
0
18
5,695
7,027
7
65
12,794
14.1%
14.6%
66.7%
0.0%
14.4%
743
770
4
0
1,517
425
1,755
1
56
2,237
5,270
5,272
6
9
10,557
"Composite sample of
Galley and Lavatory
sources.
Page B-11
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit B.5 Montioring Period for All Years (2005-2008): Sampling Data for All Airlines
Unknown Calendar Qtr
Calendar Qtr 1
Calendar Qtr 2
Calendar Qtr 3
Calendar Qtr 4
Total
Unknown Calendar Qtr
Calendar Qtr 1
Calendar Qtr 2
Calendar Qtr 3
Calendar Qtr 4
Total
Unknown Calendar Qtr
Calendar Qtr 1
Calendar Qtr 2
Calendar Qtr 3
Calendar Qtr 4
Total
Region 2
Region 4
Region 5
Region 6
Region 9
Region 10
Total
Galley
Lavatory
Composite*
Unknown Sample Site
Total
Galley
Lavatory
Composite*
Unknown Sample Site
Total
Repeat Samples
Percent TC+
OftheTC+
samples,
percent EC+
or FC+
Total # of
TC+ samples
Total # TC+
samples that
are EC+ or
FC+
Total # of TC
Samples
Percent CL2
Residual Non
detect
Total # of CL2
Residual Non
detect
Total # of
Disinfection
Unknown
Total # of CL2
Residual
Samples
Total Coliform and Chlorine Residual Data for All Airlines
0.0%
5.3%
7.5%
5.4%
3.9%
5.7%
0.0%
0.0%
2.7%
0.0%
0.0%
1.1%
0
74
146
81
56
357
0
0
4
0
0
4
24
1,389
1,941
1,492
1,438
6,284
0.0%
35.3%
10.2%
32.2%
31.7%
25.5%
0
452
189
392
416
1,449
0
109
93
273
126
601
24
1,280
1,848
1,219
1,312
5,683
Total Coliform and Chlorine Residual Data for Airlines with Approved QAPP & CRMP
0.0%
5.4%
7.6%
5.2%
3.9%
5.7%
0.0%
0.0%
2.8%
0.0%
0.0%
1.2%
0
74
145
65
54
338
0
0
4
0
0
4
0
1,377
1,903
1,250
1,400
5,930
0.0%
35.3%
10.1%
31.7%
31.6%
25.4%
0
448
184
375
403
1,410
0
109
77
66
126
378
0
1,268
1,826
1,184
1,274
5,552
Total Coliform and Chlorine Residual Data for Airlines with Unapproved QAPP & CRMP
0.0%
0.0%
2.6%
6.6%
5.3%
5.4%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0
0
1
16
2
19
0
0
0
0
0
0
24
12
38
242
38
354
0.0%
33.3%
22.7%
48.6%
34.2%
29.8%
0
4
5
17
13
39
0
0
16
207
0
223
24
12
22
35
38
131
Total Coliform and Chlorine Residual Data for All Airlines by Region
10.3%
14.0%
2.4%
3.7%
9.2%
2.5%
5.7%
0.0%
0.0%
0.0%
3.1%
0.0%
0.0%
1.1%
7
156
18
128
35
13
357
0
0
0
4
0
0
4
68
1,114
742
3,466
381
513
6,284
28.3%
21.4%
9.2%
32.6%
23.8%
0.0%
25.5%
17
233
56
1,057
86
0
1,449
8
23
132
225
20
193
601
60
1,091
610
3,241
361
320
5,683
Total Coliform and Chlorine Residual Data for All Airlines by Sample Location
1.3%
9.0%
9.6%
0.0%
5.7%
8.6%
0.3%
0.0%
0.0%
1.1%
35
290
32
0
357
3
1
0
0
4
2,715
3,227
334
8
6,284
24.4%
26.9%
21.6%
50.0%
25.5%
611
765
69
4
1,449
208
379
14
0
601
2,507
2,848
320
8
5,683
Total Coliform and Chlorine Residual Data for Airlines with Approved QAPP & CRMP by Sample Location
1.1%
9.1%
9.6%
0.0%
5.7%
10.3%
0.4%
0.0%
0.0%
1.2%
29
277
32
0
338
3
1
0
0
4
2,547
3,045
334
4
5,930
24.2%
26.9%
21.6%
0.0%
25.4%
593
748
69
0
1,410
95
269
14
0
378
2,452
2,776
320
4
5,552
"Composite sample of
Galley and Lavatory
sources.
Page B-12
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit B.5 Montioring Period for All Years (2005-2008): Sampling Data for All Airlines
Unknown Calendar Qtr
Calendar Qtr 1
Calendar Qtr 2
Calendar Qtr 3
Calendar Qtr 4
Total
Unknown Calendar Qtr
Calendar Qtr 1
Calendar Qtr 2
Calendar Qtr 3
Calendar Qtr 4
Total
Unknown Calendar Qtr
Calendar Qtr 1
Calendar Qtr 2
Calendar Qtr 3
Calendar Qtr 4
Total
Region 2
Region 4
Region 5
Region 6
Region 9
Region 10
Total
Galley
Lavatory
Composite*
Unknown Sample Site
Total
Galley
Lavatory
Composite*
Unknown Sample Site
Total
All Samples
Percent TC+
OftheTC+
samples,
percent EC+
or FC+
Total # of
TC+ samples
Total # TC+
samples that
are EC+ or
FC+
Total # of TC
Samples
Percent CL2
Residual Non
detect
Total # of CL2
Residual Non
detect
Total # of
Disinfection
Unknown
Total # of CL2
Residual
Samples
Total Coliform and Chlorine Residual Data for All Airlines
0.0%
3.7%
4.5%
5.2%
4.0%
4.4%
0.0%
2.8%
3.1%
1.0%
4.7%
2.9%
0
177
355
197
148
877
0
5
11
2
7
25
92
4,766
7,852
3,769
3,677
20,156
3.7%
25.4%
11.2%
32.9%
23.8%
20.6%
2
1,025
792
1,008
728
3,555
38
725
802
705
619
2,889
54
4,041
7,050
3,064
3,058
17,267
Total Coliform and Chlorine Residual Data for Airlines with Approved QAPP & CRMP
0.0%
3.8%
4.5%
4.5%
4.0%
4.3%
0.0%
2.3%
3.2%
0.0%
5.0%
2.7%
0
174
343
144
140
801
0
4
11
0
7
22
0
4,522
7,544
3,180
3,478
18,724
0.0%
22.8%
9.3%
30.2%
21.6%
18.2%
0
864
632
813
618
2,927
0
725
784
488
618
2,615
0
3,797
6,760
2,692
2,860
16,109
Total Coliform and Chlorine Residual Data for Airlines with Unapproved QAPP & CRMP
0.0%
1.2%
3.9%
9.0%
4.0%
5.3%
0.0%
33.3%
0.0%
3.8%
0.0%
3.9%
0
3
12
53
8
76
0
1
0
2
0
3
92
244
308
589
199
1,432
3.7%
66.0%
55.2%
52.4%
55.6%
54.2%
2
161
160
195
110
628
38
0
18
217
1
274
54
244
290
372
198
1,158
Total Coliform and Chlorine Residual Data for All Airlines by Region
6.6%
6.6%
1 .8%
4.8%
5.3%
3.3%
4.4%
10.5%
1.2%
0.9%
4.2%
7.3%
0.0%
2.9%
19
345
113
288
82
30
877
2
4
1
12
6
0
25
290
5,233
6,121
6,051
1,547
914
20,156
24.5%
15.2%
5.1%
31.8%
44.0%
0.0%
20.6%
68
786
198
1,853
650
0
3,555
12
78
2,254
225
69
251
2,889
278
5,155
3,867
5,826
1,478
663
17,267
Total Coliform and Chlorine Residual Data for All Airlines by Sample Location
1 .0%
7.0%
9.7%
2.7%
4.4%
11.1%
2.0%
0.0%
0.0%
2.9%
90
752
33
2
877
10
15
0
0
25
8,939
10,803
341
73
20,156
20.1%
21.0%
22.4%
23.5%
20.6%
1,667
1,811
73
4
3,555
659
2,159
15
56
2,889
8,280
8,644
326
17
17,267
Total Coliform and Chlorine Residual Data for Airlines with Approved QAPP & CRMP by Sample Location
0.9%
6.9%
9.7%
2.9%
4.3%
11.8%
1.9%
0.0%
0.0%
2.7%
76
690
33
2
801
9
13
0
0
22
8,242
10,072
341
69
18,724
17.3%
18.9%
22.4%
0.0%
18.2%
1,336
1,518
73
0
2,927
520
2,024
15
56
2,615
7,722
8,048
326
13
16,109
"Composite sample of
Galley and Lavatory
sources.
PageB-13
-------
Appendix C
Cost Model
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Section
Number
C.O
C.1
C.2
C.3
C.4
C.5
C.6
C.7
C.8
C.9
C.10
Section Title
Assumptions
Implementation
and Annual
Administration
Monitoring Plan
Coliform
Monitoring
Disinfectant
Residual
Monitoring
Turbidity
Monitoring
Nitrate/Nitrite
Monitoring
O&M Plan
Routine
Disinfection and
Flushing
Corrective
Action
Disinfection and
Flushing
Sanitary
Survey/Complia
nee Audit
Exhibit Title
Assumptions
Air Carrier Burden and Cost Estimates for Implementation (2008$)
Agency Burden and Cost Estimates for Implementation (2008$)
Agency Burden and Cost Estimates for Annual Administrative Activities (2008$)
Air Carrier Burden and Cost Estimates for Monitoring Plan (2008$), Alternative 1
Air Carrier Burden and Cost Estimates for Monitoring Plan (2008$), Alternative 2
Air Carrier Burden and Cost Estimates for Monitoring Plan (2008$), Alternative 3
Agency Burden and Cost Estimates for Monitoring Plan (2008$), Alternative 1
Agency Burden and Cost Estimates for Monitoring Plan (2008$), Alternative 2
Agency Burden and Cost Estimates for Monitoring Plan (2008$), Alternative 3
Air Carrier Burden and Cost Estimates for Coliform Monitoring (2008$), Alternative 1
Air Carrier Burden and Cost Estimates for Coliform Monitoring (2008$), Alternative 2
Air Carrier Burden and Cost Estimates for Coliform Monitoring (2008$), Alternative 3
Agency Burden and Cost Estimates for Coliform Monitoring (2008$), Alternative 1
Agency Burden and Cost Estimates for Coliform Monitoring (2008$), Alternative 2
Agency Burden and Cost Estimates for Coliform Monitoring (2008$), Alternative 3
Air Carrier Burden and Cost Estimates for Disinfectant Residual Monitoring (2008$), Alternative 1
Air Carrier Burden and Cost Estimates for Disinfectant Residual Monitoring (2008$), Alternative 2
Air Carrier Burden and Cost Estimates for Disinfectant Residual Monitoring (2008$), Alternative 3
Agency Burden and Cost Estimates for Disinfectant Residual Monitoring (2008$), Alternative 1
Agency Burden and Cost Estimates for Disinfectant Residual Monitoring (2008$), Alternative 2
Agency Burden and Cost Estimates for Disinfectant Residual Monitoring (2008$), Alternative 3
Air Carrier Burden and Cost Estimates for Turbidity Monitoring (2008$), Alternative 1
Air Carrier Burden and Cost Estimates for Turbidity Monitoring (2008$), Alternative 2
Air Carrier Burden and Cost Estimates for Turbidity Monitoring (2008$), Alternative 3
Agency Burden and Cost Estimates for Turbidity Monitoring (2008$), Alternative 1
Agency Burden and Cost Estimates for Turbidity Monitoring (2008$), Alternative 2
Agency Burden and Cost Estimates for Turbidity Monitoring (2008$), Alternative 3
Air Carrier Burden and Cost Estimates for Nitrate/Nitrite Sampling (2008$), Alternative 1
Air Carrier Burden and Cost Estimates for Nitrate/Nitrite Sampling (2008$), Alternative 2
Air Carrier Burden and Cost Estimates for Nitrate/Nitrite Sampling (2008$), Alternative 3
Agency Burden and Cost Estimates for Nitrate/Nitrite Sampling (2008$), Alternative 1
Agency Burden and Cost Estimates for Nitrate/Nitrite Sampling (2008$), Alternative 2
Agency Burden and Cost Estimates for Nitrate/Nitrite Sampling (2008$), Alternative 3
Air Carrier Burden and Cost Estimates for O&M Plan (2008$), Alternative 1
Air Carrier Burden and Cost Estimates for O&M Plan (2008$), Alternative 2
Air Carrier Burden and Cost Estimates for O&M Plan (2008$), Alternative 3
Agency Burden and Cost Estimates for O&M Plan (2008$), Alternative 1
Agency Burden and Cost Estimates for O&M Plan (2008$), Alternative 2
Agency Burden and Cost Estimates for O&M Plan (2008$), Alternative 3
Air Carrier Burden and Cost Estimates for Routine Disinfection and Flushing (2008$), Alternative 1
Air Carrier Burden and Cost Estimates for Routine Disinfection and Flushing (2008$), Alternative 2
Air Carrier Burden and Cost Estimates for Routine Disinfection and Flushing (2008$), Alternative 3
Agency Burden and Cost Estimates for Routine Disinfection and Flushing (2008$), Alternative 1
Agency Burden and Cost Estimates for Routine Disinfection and Flushing (2008$), Alternative 2
Agency Burden and Cost Estimates for Routine Disinfection and Flushing (2008$), Alternative 3
Air Carrier Burden and Cost Estimates for Corrective Action Disinfection and Flushing (2008$), Alternative
1
Air Carrier Burden and Cost Estimates for Corrective Action Disinfection and Flushing (2008$), Alternative
2
Air Carrier Burden and Cost Estimates for Corrective Action Disinfection and Flushing (2008$), Alternative
3
Air Carrier Burden and Cost Estimates for Sanitary Survey (2008$), Alternative 1
Air Carrier Burden and Cost Estimates for Sanitary Survey (2008$), Alternative 2
Air Carrier Burden and Cost Estimates for Sanitary Survey (2008$), Alternative 3
Agency Burden and Cost Estimates for Sanitary Survey (2008$), Alternative 1
Agency Burden and Cost Estimates for Sanitary Survey (2008$), Alternative 2
Agency Burden and Cost Estimates for Sanitary Survey (2008$), Alternative 3
Exhibit
Number
C.O
C.1a
C.1b
C.1c
C.2a
C.2b
C.2c
C.2d
C.2e
C.2f
C.3a
C.3b
C.3c
C.3d
C.3e
C.3f
C.4a
C.4b
C.4c
C.4d
C.4e
C.4f
C.5a
C.5b
C.5c
C.5d
C.5e
C.5f
C.6a
C.6b
C.6c
C.6d
C.6e
C.6f
C.7a
C.7b
C.7c
C.7d
C.7e
C.7f
C.8a
C.8b
C.8c
C.8d
C.8e
C.8f
C.9a
C.9b
C.9c
C.10a
C.10b
C.10c
C.10d
C.10e
C.1 Of
Page C-l
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Section
Number
C.11
C.12
C.13
C.14
C.15
Section Title
Rule Schedule
Nominal Costs
Present Value
at 3 Percent
Present Value
at 7 Percent
Summary
Exhibit Title
Rule Schedule
Nominal Rule Activity Costs for Alternative 1 , by Year
Nominal Air Carrier Activity Costs for Alternative 1 , by Year
Nominal Agency Activity Costs for Alternative 1 , by Year
Nominal Rule Activity Costs for Alternative 2, by Year
Nominal Air Carrier Activity Costs for Alternative 2, by Year
Nominal Agency Activity Costs for Alternative 2, by Year
Nominal Rule Activity Costs for Alternative 3, by Year
Nominal Air Carrier Activity Costs for Alternative 3, by Year
Nominal Agency Activity Costs for Alternative 3, by Year
Nominal Rule Activity Costs for Alternative 4 (Final Rule), by Year
Nominal Air Carrier Activity Costs for Alternative 4 (Final Rule), by Year
Nominal Agency Activity Costs for Alternative 4 (Final Rule), by Year
Present Value of Rule Activity Costs for Alternative 1 at 3 Percent, by Year
Present Value of Air Carrier Activity Costs for Alternative 1 at 3 Percent, by Year
Present Value of Agency Activity Costs for Alternative 1 at 3 Percent, by Year
Present Value of Rule Activity Costs for Alternative 2 at 3 Percent, by Year
Present Value of Air Carrier Activity Costs for Alternative 2 at 3 Percent, by Year
Present Value of Agency Activity Costs for Alternative 2 at 3 Percent, by Year
Present Value of Rule Activity Costs for Alternative 3 at 3 Percent, by Year
Present Value of Air Carrier Activity Costs for Alternative 3 at 3 Percent, by Year
Present Value of Agency Activity Costs for Alternative 3 at 3 Percent, by Year
Present Value of Rule Activity Costs for Alternative 4 (Final Rule) at 3 Percent, by Year
Present Value of Air Carrier Activity Costs for Alternative 4 (Final Rule) at 3 Percent, by Year
Present Value of Agency Activity Costs for Alternative 4 (Final Rule) at 3 Percent, by Year
Present Value of Rule Activity Costs for Alternative 1 at 7 Percent, by Year
Present Value of Air Carrier Activity Costs for Alternative 1 at 7 Percent, by Year
Present Value of Agency Activity Costs for Alternative 1 at 7 Percent, by Year
Present Value of Rule Activity Costs for Alternative 2 at 7 Percent, by Year
Present Value of Air Carrier Activity Costs for Alternative 2 at 7 Percent, by Year
Present Value of Agency Activity Costs for Alternative 2 at 7 Percent, by Year
Present Value of Rule Activity Costs for Alternative 3 at 7 Percent, by Year
Present Value of Air Carrier Activity Costs for Alternative 3 at 7 Percent, by Year
Present Value of Agency Activity Costs for Alternative 3 at 7 Percent, by Year
Present Value of Rule Activity Costs for Alternative 4 (Final Rule) at 7 Percent, by Year
Present Value of Air Carrier Activity Costs for Alternative 4 (Final Rule) at 7 Percent, by Year
Present Value of Agency Activity Costs for Alternative 4 (Final Rule) at 7 Percent, by Year
Summary of Rule Costs (Millions of 2008$)
Summary of Rule Costs (Millions of 2008$), Alternative 1
Summary of Rule Costs (Millions of 2008$), Alternative 2
Summary of Rule Costs (Millions of 2008$), Alternative 3
Summary of Rule Costs (Millions of 2008$), Alternative 4 (Final Rule)
Exhibit
Number
C.11
C.12a
C.12b
C.12c
C.12d
C.12e
C.12f
C.12g
C.12h
C.12I
C.12J
C.12k
C.12I
C.13a
C.13b
C.13c
C.13d
C.13e
C.13f
C.13g
C.13h
C.13I
C.13J
C.13k
C.13I
C.14a
C.14b
C.14c
C.14d
C.14e
C.14f
C.14g
C.14h
C.14I
C.14J
C.14k
C.14I
C.15a
C.15b
C.15c
C.15d
C.15e
Page C-2
-------
C 0 Assumptions
Page C-3
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
C.O Assumptions
Implementation & Annual
Administration
Monitoring Plan
O&M Plan
Coliform Monitoring
Disinfectant Residual
Monitoring
Turbidity Monitoring
Nitrate/Nitrite Monitoring
Routine Disinfection &
Flushing
Corrective Action Disinfection
& Flushing
Sanitary Survey/ Compliance
Audit
Alt 1 (Current Regulations)
Alt 2 (AOCs)
Alt 3 (WSG 29)
Alt 4 (Final Rule)
Identical for all alternatives
Develop Sample Siting Plan to include sample
collection locations fall air carriers).
Not required
1) One TC sample collected monthly/aircraft.
2)15%TC+.
3) 4% of aircraft with initial TC+ samples will
have at least one additional TC+ during repeat
sampling.
4) Four repeat samples collected within 24
hours of notification of TC+.
5) Four additional coliform samples collected
per aircraft with routine coliform monitoring TC+
(assume no waivers).
6) No post disinfection monitoring samples
collected.
Collected monthly at same locations as routine
coliform monitoring samples.
Not required
Not required
1) Not required
2) Self-certification not required
Not required
EPA performs surveys. Only recordkeeping
burden for aircraft.
Develop QAPP, Develop Mentoring Plan (all air
carriers).
Not required
1) One galley and one lavatory TC sample
collected annually/aircraft.
2)3.6%TC+.
3) 5.7% of aircraft with initial TC+ samples will
have at least one additional TC+ during repeat
sampling.
4) Four repeat samples collected within 24
hours of notification of TC+.
5) No additional colform samples collected.
6) Four corrective action follow-up samples
collected per aircraft with positive routine
coliform monitoring sample that undergoes
corrective action disinfection and flushing.
Collected annually at 1 lavatory and 1 galley on
each aircraft.
Not required
Not required
1) Quarterly/aircraft
2) Quarterly self-certification
After TC+
Not required
Develop Monitoring Plan (50% of air carriers).
50% of air carriers will develop O&M plans in
lieu of required monitoring.
1) One TC sample collected quarterly/aircraft
not implementing O&M plan. Assuming 50% of
aircraft implement O&M plan.
2)3.6%TC+.
3) 5.7% of aircraft with initial TC+ samples will
have at least one additional TC+ during repeat
sampling.
4) Repeat monitoring not specified, assumed
no repeat monitoring samples.
4) No additional coliform samples collected.
5) No corrective action follow-up samples
collected.
Not required
Daily/aircraft. Assuming 50% of aircraft
implement O&M plan.
Not required
1) Quarterly/aircraft
2) Self-certification not required
After TC+
Not required
Develop Sampling Plan per ADWR requirements and report sampling frequency to
Agency (all air carriers).
Update existing O&M manual and practices with ADWR specific requirements and submit
statement to Agency indicating that O&M manual has been updated (all air carriers).
1) One galley and one lavatory TC sample collected/aircraft. 30% annually, 30% twice
annually, 30% quarterly, and 10% monthly.
2)3.6%TC+.
3) 5.7% of aircraft performing repeat sampling will have at least one additional TC+ during
repeat sampling.
4) 0% of aircraft performing annual routine coliform monitoring, 0% of aircraft performing
twice annual routine coliform monitoring, 50% of aircraft performing quarterly routine
coliform monitoring, and 46% of aircraft performing monthly routine coliform monitoring
with TC+ will collect three repeat samples within 24 hours of notification of TC+ as an
option to immediate corrective action.
5) No additional coliform samples collected.
6) Two corrective action follow-up samples taken per aircraft that undergoes corrective
action flushing and disinfecting.
Not required
Not required
Not required
1) 30% quarterly, 30% thrice annually, 30% twice annually, and 10% annually.
2) Self-certification not required
1) 100% of aircraft performing annual routine coliform monitoring, 100% of aircraft
performing twice annual routine coliform monitoring, 50% of aircraft performing quarterly
routine coliform monitoring, and 54% of aircraft performing monthly routine coliform
monitoring perform corrective action disinfection and flushing after TC+ routine sample.
Assume the remainder of aircraft will perform repeat sampling.
2) EPA assumes the corrective action disinfection and flushing procedure will be
conducted during routine disinfection and flushing events whenever possible, and
therefore, would not incur separate costs for corrective action disinfection and flushing
events other than the cost of collection, shipping, and analysis of two follow-up coliform
samples required as part of corrective action.
3) EPA assumes that of the aircraft with a positive routine coliform sample, 0 percent of
the aircraft performing annual, twice annual, and quarterly monitoring, and 46 percent of
aircraft performing monthly monitoring will not coordinate the events and will incur the full
cost for corrective action disinfection and flushing.
EPA performs compliance audit. Aircraft confirm self-inspection and report any
deficiencies.
Page C-4
-------
C.1 Implementation and
Annual Administration
Page C-5
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.1a Air Carrier Burden and Cost Estimates for Implementation (2008$)
Compliance Activity
Read and Understand Rule
Train Personnel
Total
Labor Cost
($/hour)
A
$42.86
$42.86
One-time labor burden
(hours/air carrier)
B
8
8
16
Unit Cost
C=A*B
$ 343
$ 343
$ 686
Total Labor Burden
(hours)
D=B*63
504
504
1,008
Total Cost ($)
E=C*63
$ 21,600
$ 21,600
$ 43,201
Notes:
(1) Detail may not add due to independent rounding.
(2) Air carrier burden and cost estimates for Implementation activities are assumed to be identical for Alternatives 1-3 and the Final Rule.
Sources:
(A) Air carrier labor costs from Exhibit 5.1. EPA used the transportation inspector category because it was the highest-paid technical labor category. Transportation
inspectors are assumed to have a technical background, as well as some management or oversight responsibility.
(B) Labor hours for start-up activities reflect EPA estimate.
(D), (E) National totals for all 63 U.S. air carriers subject to ADWR to perform implementation activities. Assumes all air carriers spend equal time performing
implementation activities, regardless of fleet size or aircraft type.
Page C-6
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.1b Agency Burden and Cost Estimates for Implementation (2008$)
Compliance Activity
Read and Understand Rule
Program Development
Modify/Develop Data Management Systems
Air Carrier Training and Technical Assistance
Staff Training
Total
Labor Cost
($/hour)
A
$50.14
$50.14
$50.14
$50.14
$50.14
One-time labor burden
(hours/Region)
B
8
40
115
80
40
283
Unit Cost
C=A*B
$ 401
$ 2,006
$ 5,767
$ 4,012
$ 2,006
$ 14,191
Total Labor
Burden (hours)
D=B*10
80
400
1,150
800
400
2,830
Total Cost ($)
E=C*10
$ 4,012
$ 20,058
$ 57,666
$ 40,115
$ 20,058
$ 141,908
Notes:
(1) Detail may not add due to independent rounding.
(2) Agency burden and cost estimates for Implementation activities are assumed to be identical for Alternatives 1-3 and the Final Rule.
Sources:
(A) Agency labor costs from Section 5.2.1
(B) Labor hours for start-up activities reflect EPA estimate.
(D), (E) National totals for Agency (EPA Regions) to implement ADWR for 63 U.S. air carriers subject to ADWR. Assumes each region spends equal time performing
implementation activities, regardless of number of air carriers headquartered in their region, air carrier fleet size or aircraft type.
Page C-7
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.1c Agency Burden and Cost Estimates for Annual Administrative Activities (2008$)
Compliance Activity
Lab Certification
Ongoing Technical Assistance
Staff Training
Total
Labor Cost
($/hour)
A
$50.14
$50.14
$50.14
Labor
(hours/Region/year)
B
-
500
16
516
Cost ($/year)
C=A*B
$
$ 25,072
$ 802
$ 25,874
Total Labor
Burden
(hours/year)
D=B*10
-
5,000
160
5,160
Total Cost ($/year)
E=C*10
$
$ 250,720
$ 8,023
$ 258,743
Notes:
(1) Detail may not add due to independent rounding.
(2) Agency burden and cost estimates for annual administrative activities are assumed to be identical for Alternatives 1-3 and the Final Rule.
(3) No costs are associated with lab certification under the ADWR because it is not anticipated that the Agency will need to oversee lab certification programs in
addition to what is being done for the Total Coliform Rule.
Sources:
(A) Agency labor costs from Section 5.2.1.
(B) Labor hours for start-up activities reflect EPA estimate.
(D), (E) National totals for Agency (EPA Regions) to implement ADWR for 63 U.S. air carriers subject to ADWR. Assumes each region spends equal time performing
implementation activities, regardless of number of air carriers headquartered in their region, air carrier fleet size or aircraft type.
Page C-8
-------
C.2 Monitoring Plan
Page C-9
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.2a Air Carrier Burden and Cost Estimates for Monitoring Plan (2008$), Alternative 1
Compliance Activity
Develop Sample Siting Plan to include sample collection
locations
Total
Labor Cost
($/hour)
A
$42.86
One-time labor burden
(hours/air carrier)
B
10
10
Unit Cost
C=A*B
$ 429
$ 429
Total Labor Burden
(hours)
D=B*63
630
630
Total Cost ($)
E=C*63
$ 27,001
$ 27,001
Sources:
(A) Air carrier labor costs from Exhibit 5.1. EPA used the transportation inspector category because it was the highest-paid technical labor category. Transportation
inspectors are assumed to have a technical background, as well as some management or oversight responsibility.
(B) Labor hours for developing sampling siting plans reflect EPA estimate.
(D), (E) Assume all 63 U.S. air carriers subject to ADWR will develop sample siting plans. Assumes all air carriers spend equal time developing and sample siting plans,
regardless of fleet size or aircraft type.
Page C-10
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.2b Air Carrier Burden and Cost Estimates for Monitoring Plan (2008$), Alternative 2
Compliance Activity
Develop QAPP
Develop Monitoring Plan
Total
Labor Cost
($/hour)
A
$42.86
$42.86
One-time labor burden
(hours/air carrier)
B
10
10
20
Unit Cost
C=A*B
$ 429
$ 429
$ 857
Total Labor Burden
(hours)
D=B*63
630
630
1,260
Total Cost ($)
E=C*63
$ 27,001
$ 27,001
$ 54,001
Sources:
(A) Air carrier labor costs from Exhibit 5.1. EPA used the transportation inspector category because it was the highest-paid technical labor category. Transportation
inspectors are assumed to have a technical background, as well as some management or oversight responsibility.
(B) Labor hours for developing QAPP and monitoring plans reflect EPA estimate.
(D), (E) Assume all 63 U.S. air carriers subject to ADWR will develop QAPPs and monitoring plans. Assumes all air carriers spend equal time developing QAPPs and
monitoring plans, regardless of fleet size or aircraft type.
Page C-11
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.2c Air Carrier Burden and Cost Estimates for Monitoring Plan (2008$), Alternative 3
Compliance Activity
Develop Monitoring Plan
Total
Labor Cost
($/hour)
A
$42.86
One-time labor burden
(hours/air carrier)
B
10
10
Unit Cost
C=A*B
$ 429
$ 429
Total Labor Burden
(hours)
D=B*(63/2)
315
315
Total Cost ($)
E=C*(63/2)
$ 13,500
$ 13,500
Sources:
(A) Air carrier labor costs from Exhibit 5.1. EPA used the transportation inspector category because it was the highest-paid technical labor category. Transportation
inspectors are assumed to have a technical background, as well as some management or oversight responsibility.
(B) Labor hours for developing monitoring plans reflect EPA estimate.
(D), (E) Assume 50% of the 63 U.S. air carriers subject to ADWR will develop monitoring plans. Assumes all air carriers spend equal time developing monitoring plans,
regardless of fleet size or aircraft type.
Page C-12
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.2d Agency Burden and Cost Estimates for Monitoring Plan (2008$), Alternative 1
Compliance Activity
Review Air Carrier Sample Siting Plan
Total
Labor Cost
($/hour)
A
$50.14
One-time labor burden
(hours/air carrier)
B
5
5
Unit Cost
C=A*B
$ 251
$ 251
Total Labor Burden
(hours)
D=B*63
315
315
Total Cost ($)
E=C*63
$ 15,795
$ 15,795
Sources:
(A) Agency labor costs from Section 5.2.1.
(B) Labor hours for reviewing sample siting plan reflect EPA estimate.
(D), (E) Assume all 63 U.S. air carriers subject to ADWR will develop sample siting plans. Assumes Agency spends equal time reviewing air carrier sample siting plans,
regardless of fleet size or aircraft type.
Page C-13
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.2e Agency Burden and Cost Estimates for Monitoring Plan (2008$), Alternative 2
Compliance Activity
Review Air Carrier QAPP
Review Air Carrier Monitoring Plan
Total
Labor Cost
($/hour)
A
$50.14
$50.14
One-time labor burden
(hours/air carrier)
B
5
5
5
Unit Cost
C=A*B
$ 251
$ 251
$ 251
Total Labor Burden
(hours)
D=B*63
315
315
315
Total Cost ($)
E=C*63
$ 15,795
$ 15,795
$ 15,795
Sources:
(A) Agency labor costs from Section 5.2.1.
(B) Labor hours for reviewing QAPP and monitoring plan reflect EPA estimate.
(D), (E) Assume all 63 U.S. air carriers subject to ADWR will develop QAPPs and monitoring plans. Assumes Agency spends equal time reviewing air carrier QAPPs and
monitoring plans, regardless of fleet size or aircraft type.
Page C-14
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.2f Agency Burden and Cost Estimates for Monitoring Plan (2008$), Alternative 3
Compliance Activity
Review Air Carrier Monitoring Plan
Total
Labor Cost
($/hour)
A
$50.14
One-time labor burden
(hours/air carrier)
B
5
5
Unit Cost
C=A*B
$ 251
$ 251
Total Labor Burden
(hours)
D=B*(63/2)
158
158
Total Cost ($)
E=C*(63/2)
$ 7,898
$ 7,898
Sources:
(A) Agency labor costs from Section 5.2.1.
(B) Labor hours for reviewing monitoring plans reflect EPA estimate.
(D), (E) Assume 50% of the 63 U.S. air carriers subject to ADWR will develop monitoring plans. Assumes Agency spends equal time reviewing air carrier monitoring plans,
regardless of fleet size or aircraft type.
Page C-15
-------
C.3 Coliform Monitoring
Page C-16
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.3a Air Carrier Burden and Cost Estimates for Coliform Monitoring (2008$), Alternative 1
# of Available
Sampling Points
A
1
2
3
4
5
6
7
8
>9
Total
# of Aircraft
B
381
2,080
756
421
956
871
298
809
755
7,327
Total* of Available
Sampling Points
C=B*A
381
4,160
2,268
1,684
4,780
5,226
2,086
6,472
9,354
36,411
TC Samples
Routine Coliform
Monitoring
(samples/year)
D=12*B
4,572
24,960
9,072
5,052
1 1 ,472
10,452
3,576
9,708
9,060
87,924
Routine Coliform
Monitoring TC+
(samples/year)
E=D*0.15
686
3,744
1,361
758
1,721
1,568
536
1,456
1,359
13,189
Additional TC+
(samples/year)
F=E*0.04
27
150
54
30
69
63
21
58
54
528
Repeat
(samples/year)
G=E*4
2,743
14,976
5,443
3,031
6,883
6,271
2,146
5,825
5,436
52,754
Additional
Routine Coliform
Monitoring
(samples/year)
H=G*4
10,973
59,904
21,773
12,125
27,533
25,085
8,582
23,299
21 ,744
211,018
Corrective Action
Coliform Follow-
up Sample (post-
disinfection
sample)
(samples/year)
I
0
TC Sampling
Sampling Labor
Burden
(hours/sample)
J
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
Total Sampling
Burden
(hours/year)
K=J(D+G+H+I|
9,144
49,920
18,144
10,104
22,944
20,904
7,152
19,416
18,120
175,848
Total Sampling
Cost IS/year)
L=K*AA
$ 313,403
$ 1,710,966
$ 621,870
$ 346,306
$ 786,386
$ 716,467
$ 245,129
$ 665,467
$ 621,048
$ 6,027,042
Analysis
Analysis Labor
Burden
(hours/sample)
M
0
0
0
0
0
0
0
0
0
Total Analysis
Burden
(hours/year)
N=M(D+G+H+I|
-
-
-
-
0
Unit Shipping
Cost (S/sample
set)
O
$107
$107
$107
$107
$107
$107
$107
$107
$107
Total Shipping
Cost IS/year)
P=O(D-K3/4)
565,110
3,085,117
1,121,321
624,440
1,417,967
1,291,893
442,002
1,199,933
1,119,838
$ 10,867,622
Notes:
(C) Average number of available sampling points usedfopQ sampling points size category.
(D) One TC sample collected monthly per aircraft.
(E) Assume 15% of coliform samples will be TC+.
(F) Assume 4% of aircraft with initial TC+ samples will have at least one additional TC+ during repeat sampling.
(G) Four repeat samples collected within 24 hours of notification ofTC+.
(H) Four additional routine coliform monitoring samples collected per aircraft with positive routine coliform monitoring sample in the month following notification of TC+. Assume no systems receive waiver.
(I) Post disinfection monitoring not specified, assumed no follow-up samples collected.
(J) Assume 0.5 hour for sample collection and for process, storage, and shipping of sample. (Sample set burden is 0.5 hour for (1) routine samples, 2 hours for (4) repeat samples, and 0 hour for (0) corrective action follow-up samples.)
(M) Assume all analysis conducted by outside lab.
(O) Estimated courier fees based on costs from various courier services in major cities. Assumed courier services required for each sample set. (Sample set consists of 1 routine samples, and 4 repeat samples. Assumed airport distance of 20-30 miles from
return cooler to air carrier. 100% of shipping costs incurred by TC monitoring, since residual samples are analyzed immediately and do not require shipping, turbidity samples are not required under Alt. 1, and the space required to ship annual nitrate/nitrate
(Q) Average coliform analysis costs based on costs from various labs across the country. Assume all analysis conducted by outside lab.
(S) Assume air carriers will replace coolers, gel packs, and thermometers once a year. 100% of the unit equipment cost is incurred by total coliform monitoring, since residual samples are immediately read and will not require shipping in a cooler.
(T) Coolers, gel packs, and thermometers are purchased by air carriers. The costs for this equipment are assumed to be distributed evenly across the 7,327 aircraft. Fractional burden is shown for calculation purposes only.
(U) Assume each air carrier will purchase three new refrigerators. 100% of the refrigerator cost is incurred by total coliform monitoring, since disinfectant residual monitoring does not require the use of a refrigerator.
(V) Refrigerators are purchased by air carriers. Assume costs for 63 airlines are distributed evenly across the 7,327 aircraft. Fractional burden is shown for calculation purposes only.
(W), (X), (Y) Based on EPA estimate.
(Y) Air carriers must report their water system inventory within 18 months of promulgation of the Final Rule. For modeling purposes, this reporting burden is captured in Year 3 and follows the same schedule as coliform monitoring.
(Z) Assume burden for 63 airlines is distributed evenly across the 7,327 aircraft. Fractional burden is shown for calculation purposes only.
(AA) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1.
(AB) Columns W and X applied on a sample set basis. Assume a sample set consists of (1) routine sample, (4) repeat samples, and (0) corrective action follow-up samples.
i lab. Assumed courier would
samples is negligible.
Page C-17
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.3a Air Carrier Burden and Cost Estimates for Coliform Monitoring (2008$), Alternative 1 (conf d)
# of Available
Sampling Points
A
1
2
3
4
5
6
7
8
>9
Total
Analysis
Unit Analysis
Cost IS/sample)
Q
$22.16
$22.16
$22.16
$22.16
$22.16
$22.16
$22.16
$22.16
$22.16
Total Analysis
Cost IS/year)
R=Q(D-K3+H+I)
405,307
2,212,700
804,231
447,859
1,016,991
926,568
317,012
860,613
803,167
$ 7,794,448
Annual Unit
Equipment Cost
($/air
carrier/year)
S
$ 219
$ 219
$ 219
$ 219
$ 219
$ 219
$ 219
$ 219
$ 219
Total Annual
Equipment Cost
($/year)
T
$ 717
$ 3,917
$ 1 ,424
$ 793
$ 1 ,800
$ 1 ,640
$ 561
$ 1 ,523
$ 1 ,422
$ 13,797
Periodic
Equipment
Cost ($/air
carrier)
U
$ 597
$ 597
$ 597
$ 597
$ 597
$ 597
$ 597
$ 597
$ 597
Total Periodic
Equipment Cost
($)
V
$ 1 ,956
$ 10,677
$ 3,881
$ 2,161
$ 4,907
$ 4,471
$ 1 ,530
$ 4,153
$ 3,876
$ 37,611
Recordkeeping
Maintain
Maintenance Log
(hours/sample
set)
W
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Report
Monitoring
Results
(hours/sample
set)
X
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Report Water
System
Inventory /Changes
(hours/air carrier)
Y
.00
.00
.00
.00
.00
.00
.00
.00
.00
Report Water
System
Inventory /Changes
Burden
(hours/year)
Z
3.28
17.88
6.50
3.62
8.22
7.49
2.56
6.96
6.49
63
Labor Cost
($/hour)
AA
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
Recordkeeping
and Reporting
Labor
(hours/year)
AB=((W+X|*
(D-K3/4-tH/4))+Z
4,004
21,858
7,945
4,424
10,046
9,153
3,132
8,501
7,934
Recordkeeping
Cost IS/year)
AC=AB*AA
$ 137,226
$ 749,161
$ 272,291
$ 151,633
$ 344,326
$ 313,711
$ 107,332
$ 291,380
$ 271,931
$ 2,638,990
Totals
Total Burden
(hours/year)
AD=K+M+AB
13,148
71,778
26,089
14,528
32,990
30,057
10,284
27,917
26,054
252,845
Total O&M Cost
($/year)
AE=L+P+R+T+AC
$ 1 ,421 ,764
$ 7,761 ,860
$ 2,821,138
$ 1,571,030
$ 3,567,470
$ 3,250,279
$ 1,112,036
$ 3,018,916
$ 2,817,406
$ 27,341,900
Total
Capital
Cost ($)
AF=V
$ 1 ,956
$ 10,677
$ 3,881
$ 2,161
$ 4,907
$ 4,471
$ 1,530
$ 4,153
$ 3,876
$ 37,611
Page C-18
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.3b Air Carrier Burden and Cost Estimates for Coliform Monitoring (2008$), Alternative 2
# of Available
Sampling
Points
A
1
2
3
4
5
6
7
8
>9
Total
# of Aircraft
B
381
2,080
756
421
956
871
298
809
755
7,327
Total # of
Available
Sampling Points
C=B*A
381
4,160
2,268
1,684
4,780
5,226
2,086
6,472
9,354
36,411
TC Samples
Routine Coliform
Monitoring
(samples/year)
D
762
4,160
1,512
842
1,912
1,742
596
1,618
1,510
14,654
Routine Coliform
Monitoring TC+
(samples/year)
E=D*0.036
27
150
54
30
69
63
21
58
54
528
Additional TC+
(samples/year)
F=E*0.057
2
9
3
2
4
4
1
3
3
30
Repeat
(samples/year)
G=E*4
110
599
218
121
275
251
86
233
217
2,110
Additional Routine
Coliform
Monitoring
(samples/year)
H
0
0
0
0
0
0
0
0
0
0
Corrective Action
Coliform Follow-up
Sample (post-
disinfection
monitoring)
(samples/year)
I
110
599
218
121
275
251
86
233
217
2,110
TC Sampling
Sampling Labor
Burden
(hours/sample)
J
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
Total Sampling
Burden
(hours/year)
K=J(D+G+H-H|
491
2,679
974
542
1,231
1,122
384
1,042
972
9,437
Total Sampling
Cost (S/year)
L=K*AA
$ 16,819
$ 91,822
$ 33,374
$ 18,585
$ 42,203
$ 38,450
$ 13,155
$ 35,713
$ 33,330
$ 323,451
Analysis
Analysis Labor
Burden
(hours/sample)
M
0
0
0
0
0
0
0
0
0
Total Analysis
Burden
(hours/year)
N=M(D+G+H+I)
-
-
-
-
-
0
Unit Shipping
Cost ($/sample
set)
O
$107
$107
$107
$107
$107
$107
$107
$107
$107
Total Shipping
Cost ($/year)
P=O(D/2+G/4+l/4)
46,847
255,752
92,956
51,765
117,547
107,096
36,641
99,473
92,833
$ 900,910
Notes:
(C) Average number of available sampling points used for > 9 sampling points size category.
(D) One galley and one lavatory TC sample collected annually per aircraft.
(E) Assume 3.6% of coliform samples will be TC+ based on AOC data.
(F) Assume 5.7% of aircraft with initial TC+ samples will have at least one additional TC+ during repeat sampling (based on AOC data).
(G) Four repeat samples collected within 24 hours of notification ofTC+. Assume aircraft with less than four sampling points collect a total of 400mL of samples from all available sampling points.
(H) Additional routine coliform monitoring not specified, assumed no additional routine coliform monitoring samples collected.
(I) Four follow-up samples collected per aircraft with positive routine coliform monitoring sample that undergoes corrective action disinfection and flushing.
(J) Assume 0.5 hour for sample collection and for process, storage, and shipping of sample. (Sample set burden is 1 hour for (2) routine samples, 2 hours for (4) repeat samples, and 2 hour for (4) corrective action follow-up samples.)
(M) Assume all analysis conducted by outside lab.
(O) Estimated courier fees based on costs from various courier services in major cities. Assumed courier services required for each sample set. (Sample set consists of 2 routine samples, 4 repeat samples, and 4 corrective action follow-up samples.) Assumed airport distance of 20-30 milt
lab. Assumed courier would return cooler to air carrier. 100% of shipping costs incurred by TC monitoring, since residual samples are analyzed immediately and do not require shipping.
(Q) Average coliform analysis costs based on costs from various labs across the country. Assume all analysis conducted by outside lab.
(S) Assume air carriers will replace coolers, gel packs, and thermometers once a year. 100% of the unit equipment cost is incurred by total coliform monitoring, since residual samples are immediately read and will not require shipping in a cooler.
(T) Coolers, gel packs, and thermometers are purchased by air carriers. The costs for this equipment are assumed to be distributed evenly across the 7,327 aircraft. Fractional burden is shown for calculation purposes only.
(U) Assume each aircraft will purchase three new refrigerators. 100% of the refrigerator cost is incurred by total coliform monitoring, since disinfectant residual monitoring does not require the use of a refrigerator.
(V) Refrigerators are purchased by air carriers. Assume costs for 63 airlines are distributed evenly across the 7,327 aircraft. Fractional burden is shown for calculation purposes only.
(W), (X), (Y) Based on EPA estimate.
(Y) Air carriers must report their water system inventory within 18 months of promulgation of the Final Rule. For modeling purposes, this reporting burden is captured in Year 3 and follows the same schedule as coliform monitoring.
(Z) Assume burden for 63 airlines is distributed evenly across the 7,327 aircraft. Fractional burden is shown for calculation purposes only.
(AA) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1.
(AB) Columns W and X applied on a sample set basis. Assume a sample set consists of (2) routine samples, (4) repeat samples, and (4) corrective action follow-up samples.
Page C-19
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.3b Air Carrier Burden and Cost Estimates for Coliform Monitoring (2008$), Alternative 2 (cont'd)
# of Available
Sampling
Points
A
1
2
3
4
5
6
7
8
>9
Total
Analysis
Unit Analysis
Cost (S/sample)
Q
$22.16
$22.16
$22.16
$22.16
$22.16
$22.16
$22.16
$22.16
$22.16
Total Analysis
Cost ($/year)
R=Q(D+G+H+I)
21 ,751
118,748
43,160
24,035
54,579
49,726
17,013
46,186
43,103
$ 418,302
Annual Unit
Equipment Cost
($/air carrier/year)
S
$ 219
$ 219
$ 219
$ 219
$ 219
$ 219
$ 219
$ 219
$ 219
Total Annual
Equipment Cost
($/year)
T
$ 717
$ 3,917
$ 1,424
$ 793
$ 1,800
$ 1,640
$ 561
$ 1,523
$ 1,422
$ 13,797
Periodic
Equipment
Cost ($/air
carrier)
U
$ 597
$ 597
$ 597
$ 597
$ 597
$ 597
$ 597
$ 597
$ 597
Total Periodic
Equipment Cost
($)
V
$ 1,956
$ 10,677
$ 3,881
$ 2,161
$ 4,907
$ 4,471
$ 1,530
$ 4,153
$ 3,876
$ 37,611
Recordkeeping
Maintain
Maintenance Log
(hours/sample set)
W
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Report Monitoring
Results
(hours/sample set)
X
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Report Water
System
Inventory/Changes
(hours/air carrier)
Y
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
Report Water System
Inventory/Changes
Burden (hours/year)
Z
3.28
17.88
6.50
3.62
8.22
7.49
2.56
6.96
6.49
63
Labor Cost
(Wiour)
AA
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
Recordkeeping
and Reporting
Labor
(hours/year)
AB=((W+X|*
(D/2+G/4+H +1/4))+
Z
221
1,208
439
244
555
506
173
470
438
Recordkeeping
Cost ($/year)
AC=AB*AA
$ 7,582
$ 41 ,391
$ 15,044
$ 8,378
$ 19,024
$ 17,332
$ 5,930
$ 16,099
$ 15,024
$ 145,804
Totals
Total Burden
(hours/year)
AD=K+M+AB
712
3,887
1,413
787
1,786
1,628
557
1,512
1,411
13,691
Total O&M Cost
($/year)
AE=L+P+R+T+AC
$ 93,717
$ 511,630
$ 185,958
$ 103,556
$ 235,153
$ 214,245
$ 73,301
$ 198,994
$ 185,712
$ 1,802,264
Total
Capital
Cost ($)
AF=V
$ 1,956
$ 10,677
$ 3,881
$ 2,161
$ 4,907
$ 4,471
$ 1,530
$ 4,153
$ 3,876
$ 37,611
Page C-20
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.3c Air Carrier Burden and Cost Estimates for Coliform Monitoring (2008$), Alternative 3
# of Available
Sampling
Points
A
1
2
3
4
5
6
7
8
>9
Total
# of Aircraft
B
381
2,080
756
421
956
871
298
809
755
7,327
Total* of Available
Sampling Points
C=B*A
381
4,160
2,268
1,684
4,780
5,226
2,086
6,472
9,354
36,411
TC Samples
Routine Coliform
Monitoring
(samples/year)
D = 4*B*0.5
762
4,160
1,512
842
1,912
1,742
596
1,618
1,510
14,654
Routine Coliform
Monitoring TC+
(samples/year)
E=D*0.036
27
150
54
30
69
63
21
58
54
528
Additional TC+
(samples/year)
F=E*0.057
2
9
3
2
4
4
1
3
3
30
Repeat
(samples/year)
G
0
0
0
0
0
0
0
0
0
0
Additional Routine
Coliform Monitoring
(samples/year)
H
0
0
0
0
0
0
0
0
0
0
Corrective Action
Coliform Follow-up
Sample (post-
disinfection sample)
(samples/year)
I
n K
fl c.
fl K
n«0
TC Sampling
Sampling Labor
Burden
(hours/sample)
J
Total Sampling
Burden
(hours/year)
K=J(D+G+H+I|
381
2,080
756
421
956
871
298
809
755
7,327
Total Sampling
Cost ($/year)
L=K*AA
$ 13,058
$ 71 ,290
$ 25,911
$ 14,429
$ 32,766
$ 29,853
$ 10,214
$ 27,728
$ 25,877
$ 251,127
Analysis
Analysis Labor
Burden
(hours/sample)
M
0
0
0
0
0
0
0
0
0
Total Analysis
Burden
(hours/year)
N=M(D+G+H+I|
-
-
-
-
0
Unit Shipping
Cost ($/sample
set)
O
$107
$107
$107
$107
$107
$107
$107
$107
$107
Total Shipping
Cost ($/year)
P=O*D
81 ,900
447,118
162,510
90,498
205,503
187,231
64,058
173,903
162,295
$ 1,575,018
0.5
0.5
0.5
0.5
0.5
Notes:
(C) Average number of available sampling points used for > 9 sampling points size category.
(D) One TC sample collected quarterly per aircraft not implementing O&M plan. Assuming 50% of aircraft implement O&M plan.
(E) Assume 3.6% of coliform samples will be TC+ based on AOC data.
(F) Assume 5.7% of aircraft with initial TC+ samples will have at least one additional TC+ during repeat sampling (based on AOC data).
(G) Repeat monitoring not specified in Water Supply Guidance 29, assumed no repeat monitoring samples.
(H) Additional routine coliform monitoring not specified, assumed no additional routine coliform monitoring samples collected.
(I) Post disinfection monitoring not specified, assumed no follow-up samples collected.
(J) Assume 0.5 hour for sample collection and for process, storage, and shipping of sample. (Sample set burden is 0.5 hour for (1) routine samples, 0 hours for (0) repeat samples, and 0 hour for (0) corrective action follow-up samples.)
(M) Assume all analysis conducted by outside lab.
(O) Estimated courier fees based on costs from various courier services in major cities. Assumed courier services required for each sample set. (Sample set consists of 1 routine sample.) Assumed airport distance of 20-30 miles from lab. Assumed courier would return cooler to air carrier. 100% of
shipping costs incurred by TC monitoring, since quarterly turbidity samples will not take up a significant amount of space, and residual samples are analyzed immediately and do not require shipping, and nitrate/nitrite monitoring is not required under Alt.3.
(Q) Average coliform analysis costs based on costs from various labs across the country. Assume all analysis conducted by outside lab.
(S) Assume air carriers will replace coolers, gel packs, and thermometers once a year. 100% of the unit equipment cost is incurred by total coliform monitoring, since quarterly turbidity samples will not take up a significant amount of space, residual samples are immediately read and will not require
shipping in a cooler, and nitrate/nitrite monitoring is not required under Alt.3.
(T) Coolers, gel packs, and thermometers are purchased by air carriers. The costs for this equipment are assumed to be distributed evenly across the 7,327 aircraft. Fractional burden is shown for calculation purposes only.
(U) Assume each aircraft will purchase three new refrigerators. 100% of the refrigerator cost is incurred total coliform monitoring, since quarterly turbidity samples will not take up a significant amount of space, disinfectant residual monitoring does not require the use of a refrigerator, and nitrate/nitrite
monitoring is not required under Alt.3.
(V) Refrigerators are purchased by air carriers. Assume costs for 63 airlines are distributed evenly across the 7,327 aircraft. Fractional burden is shown for calculation purposes only.
(W), (X), (Y) Based on EPA estimate.
(Y) Air carriers must report their water system inventory within 18 months of promulgation of the Final Rule. For modeling purposes, this reporting burden is captured in Year 3 and follows the same schedule as coliform monitoring.
(Z) Assume burden for 63 airlines is distributed evenly across the 7,327 aircraft. Fractional burden is shown for calculation purposes only.
(AA) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1.
(AB) Columns Wand X applied on a sample set basis. Assume a sample set consists of (1) routine samples, (0) repeat samples, (0) corrective action follow-up samples
Page C-21
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.3c Air Carrier Burden and Cost Estimates for Coliform Monitoring (2008$), Alternative 3 (cont'd)
# of Available
Sampling
Points
A
1
2
3
4
5
6
7
8
>9
Total
Analysis
Unit Analysis
Cost (S/sample)
Q
$22.16
$22.16
$22.16
$22.16
$22.16
$22.16
$22.16
$22.16
$22.16
Total Analysis
Cost ($/year)
R=Q(D+G+H+I)
16,888
92,196
33,510
18,661
42,375
38,607
13,209
35,859
33,465
$ 324,769
Annual Unit
Equipment Cost
($/air carrier/year)
S
$ 219
$ 219
$ 219
$ 219
$ 219
$ 219
$ 219
$ 219
$ 219
Total Annual
Equipment Cost
($/year)
T
$ 717
$ 3,917
$ 1,424
$ 793
$ 1,800
$ 1,640
$ 561
$ 1,523
$ 1 ,422
$ 13,797
Periodic
Equipment
Cost ($/air
carrier)
U
$ 597
$ 597
$ 597
$ 597
$ 597
$ 597
$ 597
$ 597
$ 597
Total Periodic
Equipment Cost
($)
V
$ 1,956
$ 10,677
$ 3,881
$ 2,161
$ 4,907
$ 4,471
$ 1 ,530
$ 4,153
$ 3,876
$ 37,611
Recordkeeping
Maintain
Maintenance Log
(hours/sample set)
W
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Report Monitoring
Results
(hours/sample set)
X
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Report Water
System
Inventory/Changes
(hours/air carrier)
Y
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
Report Water
System
Inventory /Changes
Burden (hours/year)
Z
3.28
17.88
6.50
3.62
8.22
7.49
2.56
6.96
6.49
63
Labor Cost
($/hour)
AA
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
Recordkeeping
and Reporting
Labor
(hours/year)
AB=((W+X|*
(D+H)+Z
384
2,098
763
425
964
878
301
816
761
Recordkeeping
Cost ($/year)
AC=AB*AA
$ 13,171
$ 71,903
$ 26,134
$ 14,553
$ 33,048
$ 30,109
$ 10,302
$ 27,966
$ 26,099
$ 253,286
Totals
Total Burden
(hours/year)
AD=K+M+AB
765
4,178
1,519
846
1,920
1,749
599
1,625
1,516
14,717
Total O&M Cost
($/year)
AE=L+P+R+T+AC
$ 125,734
$ 686,424
$ 249,489
$ 138,935
$ 315,491
$ 287,440
$ 98,344
$ 266,980
$ 249,159
$ 2,417,996
Total
Capital
Cost ($)
AF=V
$ 1,956
$ 10,677
$ 3,881
$ 2,161
$ 4,907
$ 4,471
$ 1,530
$ 4,153
$ 3,876
$ 37,611
Page C-22
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.3d Agency Burden and Cost Estimates for Coliform Monitoring (2008$), Alternative 1
Compliance Activity
Review Aircraft Monitoring Results
Review Aircraft Water System Inventory/Changes
Total
TC Samples
Labor Cost
($/hour)
A
$50.14
$50.14
Unit labor burden
(hours/TC+ sample)
B
0.5
0.5
0.5
Unit Cost ($/TC+
sample)
C=A*B
$ 25
$ 25
$ 25
Total Labor
Burden (hours)
D
6,594
32
6,594
Total Cost ($)
E
$ 330,665
$ 790
$ 330,665
Sources:
(A) Agency labor costs from Section 5.2.1.
(B) Labor hours for reviewing aircraft monitoring results reflect EPA estimate.
(D) Total labor burden = unit labor burden * total number of TC+ samples (Exhibit C.3a). Total labor burden for reviewing inventory = unit labor burden * 63 air carriers.
(E) Total cost = unit cost * total number of TC+ samples (Exhibit C.3a). Total cost for reviewing inventory = unit cost * total burden for reviewing inventory.
(F) Air carriers must report their water system inventory within 18 months of promulgation of the Final Rule. For modeling purposes, burden associated with reviewing
aircraft water system inventory/changes is captured in Year 3 and follows the same schedule as coliform monitoring.
Page C-23
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.3e Agency Burden and Cost Estimates for Coliform Monitoring (2008$), Alternative 2
Compliance Activity
Review Aircraft Monitoring Results
Review Aircraft Water System Inventory/Changes
Total
TC Samples
Labor Cost
($/hour)
A
$50.14
$50.14
Unit labor burden
(hours/TC+ sample)
B
0.5
0.5
0.5
Unit Cost ($/TC+
sample)
C=A*B
$ 25
$ 25
$ 25
Total Labor
Burden (hours)
D
264
32
264
Total Cost ($)
E
$ 13,227
$ 790
$ 13,227
Sources:
(A) Agency labor costs from Section 5.2.1.
(B) Labor hours for reviewing aircraft monitoring results reflect EPA estimate.
(D) Total labor burden = unit labor burden * total number of TC+ samples (Exhibit C.3b). Total labor burden for reviewing inventory = unit labor burden * 63 air
carriers.
(E) Total cost = unit cost * total number of TC+ samples (Exhibit C.3b). Total cost for reviewing inventory = unit cost * total burden for reviewing inventory.
(F) Air carriers must report their water system inventory within 18 months of promulgation of the Final Rule. For modeling purposes, burden associated with
reviewing aircraft water system inventory/changes is captured in Year 3 and follows the same schedule as coliform monitoring.
Page C-24
-------
C.4 Residual Monitoring
Page C-25
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.4a Air Carrier Burden and Cost Estimates for Disinfectant Residual Monitoring (2008$), Alternative 1
# of Available
Sampling Points
A
1
2
3
4
5
6
7
8
>9
Total
# of Aircraft
B
381
2,080
756
421
956
871
298
809
755
7,327
Total* of Available
Sampling Points
C=B*A
381
4,160
2,268
1,684
4,780
5,226
2,086
6,472
9,354
36,411
Disinfectant
Residual
Samples
Disinfectant
Residual
(samples/year)
D=12*B
4,572
24,960
9,072
5,052
1 1 ,472
10,452
3,576
9,708
9,060
87,924
Disinfectant Residual Sampling
Sampling Labor
Burden
(hours/sample)
E
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
Total Sampling
Burden
(hours/year)
F=E*D
2,286
12,480
4,536
2,526
5,736
5,226
1,788
4,854
4,530
43,962
Total Sampling
Cost (S/year)
G
$ 78,351
$ 427,741
$ 155,468
$ 86,577
$ 196,597
$ 179,117
$ 61,282
$ 166,367
$ 155,262
$ 1,506,761
Analysis
Analysis Labor
Burden
(hours/sample)
H
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Total Analysis
Burden
(hours/year)
I=H*D
1,143
6,240
2,268
1,263
2,868
2,613
894
2,427
2,265
21,981
Unit Shipping
Cost IS/year)
J
$
$
$
$
$
$
$
$
$
Total Shipping
Cost IS/year )
K=J*D
$
Unit Analysis
Cost IS/sample)
L
$2.96
$2.96
$2.96
$2.96
$2.96
$2.96
$2.96
$2.96
$2.96
Total Analysis
Cost ($/year)
M=L*D
13,533
73,882
26,853
14,954
33,957
30,938
10,585
28,736
26,818
$ 260,255
Annual Unit
Equipment
Cost ($/air
carrier/year)
N
$
$
$
$
$
$
$
$
$
Notes:
(C) Average number of available sampling points used for > 9 sampling points size category.
(D) Disinfectant residual sample needed for each routine coliform monitoring sample. Disinfectant residual samples collected monthly, at same locations as routine coliform monitoring samples.
(E) Assume one hour for sample collection and for process, storage, and shipping of sample.
(H) Based on EPA estimate.
(J) Assume disinfectant residual samples will be analyzed immediately and will not require shipping.
(L) Cost of disinfectant residual sampling kit (see Exhibit 5.2).
(N) Assume air carrier will replace coolers, gel packs, and thermometers once a year. Unit equipment cost is not incurred by disinfectant residual monitoring, since disinfectant residual monitoring
shipping or storage.
(P) Assume each air carrier will purchase three new refrigerators. Refrigerator cost is not incurred by disinfectant residual monitoring since residual samples are analyzed immediately and will not
(R), (S), (T) Based on EPA estimate. EPA estimates that aircraft will not have significant inventory changes.
(U) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1.
(Z) Assumed that if a refrigerator is purchased, it purchased two times (in years years 3 and 13) in the 25-year evaluation period.
samples are analyzed immediately and will not require
require shipping or storage.
Page C-26
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
# of Available
Sampling Points
A
1
2
3
4
5
6
7
8
>9
Total
Analysis
Total Annual
Equipment
Cost IS/year)
O
$
$
$
$
$
$
$
$
$
$
Periodic
Equipment Cost
(S/air carrier)
P
$
$
$
$
$
$
$
$
$
Total Periodic
Equipment Cost
($>
Q
$
$
$
$
$
$
$
$
$
$
Recordkeeping
Maintain
Maintenance Log
(hours/sample)
R
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Report
Monitoring
Results
(hours/sample)
S
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Report Water
System
Inventory/Changes
(hours/sample)
T
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
Labor Cost
($/hour)
U
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
Recordkeeping
Labor
(hours/year)
V=(R-tS+T|*D
2,286
12,480
4,536
2,526
5,736
5,226
1,788
4,854
4,530
Recordkeeping
Cost IS/year)
W=U*V
$ 78,351
$ 427,741
$ 155,468
$ 86,577
$ 196,597
$ 179,117
$ 61,282
$ 166,367
$ 155,262
$ 1,506,761
Totals
Total Burden
(hours/year)
X=F+I+V
5,715
31,200
1 1 ,340
6,315
14,340
13,065
4,470
12,135
11,325
109,905
Total O&M Cost
($/year)
Y=G+K+M-K)+W
$ 170,235
$ 929,365
$ 337,788
$ 188,107
$ 427,150
$ 389,171
$ 133,149
$ 361,469
$ 337,341
$ 3,273,776
Total Capital Cost
($)
Z=Q
$
$
$
$
$
$
$
$
$
$
Page C-27
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.4b Air Carrier Burden and Cost Estimates for Disinfectant Residual Monitoring (2008$), Alternative 2
# of Available
Sampling
Points
A
1
2
3
4
5
6
7
8
>9
Total
# of Aircraft
B
381
2,080
756
421
956
871
298
809
755
7,327
Total # of
Available
Sampling Points
C=B*A
381
4,160
2,268
1,684
4,780
5,226
2,086
6,472
9,354
36,411
Disinfectant
Residual Samples
Disinfectant
Residual
(samples/year)
D
762
4,160
1,512
842
1,912
1,742
596
1,618
1,510
14,654
Disinfectant Residual Sampling
Sampling Labor
Burden
(hours/sample)
E
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
Total Sampling
Burden
(hours/year)
F=E*D
381
2,080
756
421
956
871
298
809
755
7,327
Total Sampling
Cost ($/year)
G
$ 13,058
$ 71 ,290
$ 25,911
$ 14,429
$ 32,766
$ 29,853
$ 10,214
$ 27,728
$ 25,877
$ 251,127
Analysis
Analysis Labor
Burden
(hours/sample)
H
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Total Analysis
Burden (hours/year)
I=H*D
191
1040
378
211
478
436
149
405
378
3664
Unit Shipping
Cost ($/year)
J
$
$
$
$
$
$
$
$
$
Total Shipping
Cost ($/year)
K=J*D
$
Unit Analysis
Cost (S/sample)
L
$2.96
$2.96
$2.96
$2.96
$2.96
$2.96
$2.96
$2.96
$2.96
Total Analysis
Cost ($/year)
M=L*D
2,256
12,314
4,476
2,492
5,660
5,156
1,764
4,789
4,470
$ 43,376
Annual Unit
Equipment Cost
($/air
carrier/year)
N
$
$
$
$
$
$
$
$
$
Notes:
(C) Average number of available sampling points used for > 9 sampling points size category.
(D) Disinfectant residual sample collected annually at 1 lavatory and 1 galley on each aircraft.
(E) Assume one hour for sample collection and for process, storage, and shipping of sample.
(H) Based on EPA estimate.
(J) Assume disinfectant residual samples will be analyzed immediately and will not require shipping.
(L) Cost of disinfectant residual sampling kit (see Exhibit 5.2).
(N) Assume air carriers will replace coolers, gel packs, and thermometers once a year. Unit equipment cost is not incurred by disinfectant residual monitoring since disinfectant residual monitoring samples are analyzed im
or storage.
(P) Assume air carriers will purchase three new refrigerators. Refrigerator cost is not incurred by disinfectant residual monitoring since disinfectant residual samples are analyzed immediately and will not require shipping or
(R), (S), (T) Based on EPA estimate. EPA estimates that aircraft will not have significant inventory changes.
(U) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1 .
(Z) Assumed that if a refrigerator is purchased, it purchased two times (in years years 3 and 13) in the 25-year evaluation period.
ediately and will not require shipping
storage.
Page C-28
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.4b Air Carrier Burden and Cost Estimates for Disinfectant Residual Monitoring (2008$), Alternative 2 (cont'd)
# of Available
Sampling
Points
A
1
2
3
4
5
6
7
8
>9
Total
Analysis
Total Annual
Equipment Cost
($/year)
O
$
$
$
$
$
$
$
$
$
$
Periodic
Equipment Cost
($/air carrier)
P
$
$
$
$
$
$
$
$
$
Total Periodic
Equipment Cost
($)
Q
$
$
$
$
$
$
$
$
$
$
Recordkeeping
Maintain
Maintenance Log
(hours/sample)
R
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Report Monitoring
Results
(hours/sample)
S
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Report Water
System
Inventory/Change
s (hours/sample)
T
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
Labor Cost
(S/hour)
U
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
Recordkeeping
Labor
(hours/year)
V=(R+S+T)*D
381
2,080
756
421
956
871
298
809
755
Recordkeeping
Cost ($/year)
W=U*V
$ 13,058
$ 71,290
$ 25,91 1
$ 14,429
$ 32,766
$ 29,853
$ 10,214
$ 27,728
$ 25,877
$ 251,127
Totals
Total Burden
(hours/year)
X=F+I+V
953
5,200
1,890
1,053
2,390
2,178
745
2,023
1,888
18,318
Total O&M Cost
($/year)
Y=G+K+M+O+W
$ 28,372
$ 154,894
$ 56,298
$ 31,351
$ 71,192
$ 64,862
$ 22,192
$ 60,245
$ 56,224
$ 545,629
Total Capital Cost ($)
Z=Q
$
$
$
$
$
$
$
$
$
$
Page C-29
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.4c Air Carrier Burden and Cost Estimates for Disinfectant Residual Monitoring (2008$), Alternative 3
# of Available
Sampling
Points
A
1
2
3
4
5
6
7
8
>9
Total
# of Aircraft
B
381
2,080
756
421
956
871
298
809
755
7,327
Total* of Available
Sampling Points
C=B*A
381
4160
2268
1684
4780
5226
2086
6472
9354
36,411
Disinfectant
Residual Samples
Disinfectant
Residual
(samples/year)
D
-
-
-
-
0
Disinfectant Residual Sampling
Sampling Labor
Burden
(hours/sample)
E
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
Total Sampling
Burden
(hours/year)
F=E*D
0
Total Sampling
Cost ($/year)
G
$
$
$
$
$
$
$
$
$
$
Residual Analysis
Analysis Labor
Burden
(hours/sample)
H
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Total Analysis
Burden (hours/year)
I=H*D
0
0
0
0
0
0
0
0
0
0
Unit Shipping
Cost ($/year)
J
$
$
$
$
$
$
$
$
$
Total Shipping
Cost ($/year|
K=J*D
-
-
-
-
$
Unit Analysis
Cost ($/sample)
L
$2.96
$2.96
$2.96
$2.96
$2.96
$2.96
$2.96
$2.96
$2.96
Total Analysis
Cost ($/year)
M=L*D
$
Annual Unit
Equipment Cost
($/air
carrier/year)
N
$
$
$
$
$
$
$
$
$
Notes:
(C) Average number of available sampling points used for > 9 sampling points size category.
(D) Disinfectant residual sampling not required under Alt. 3.
(E) Assume one hour for sample collection and for process, storage, and shipping of sample.
(H) Based on EPA estimate.
(J) Shipping costs are not incurred by disinfectant residual monitoring since disinfectant residual monitoring is not required under Alt. 3.
(L) Cost of disinfectant residual sampling kit (see Exhibit 5.2).
(N) Assume air carriers will replace coolers, gel packs, and thermometers once a year. Unit equipment cost is not incurred by disinfectant residual monitoring since disinfectant residual monitoring is not required under Alt.;
(P) Assume air carriers will purchase three new refrigerators. Refrigerator cost is not incurred by disinfectant residual monitoring since disinfectant residual monitoring is not required under Alt. 3.
(R), (S), (T) Based on EPA estimate. EPA estimates that aircraft will not have significant inventory changes.
(U) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1.
(Z) Assumed that if a refrigerator is purchased, it purchased two times (in years years 3 and 13) in the 25-year evaluation period.
Page C-30
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.4c Air Carrier Burden and Cost Estimates for Disinfectant Residual Monitoring (2008$), Alternative 3 (cont'd)
# of Available
Sampling
Points
A
1
2
3
4
5
6
7
8
>9
Total
Residual Analysis
Total Annual
Equipment Cost
($/year)
O
$
$
$
$
$
$
$
$
$
$
Periodic
Equipment Cost
($/air carrier)
P
$
$
$
$
$
$
$
$
$
Total Periodic
Equipment Cost
($)
Q
$
$
$
$
$
$
$
$
$
$
Recordkeeping
Maintain
Maintenance Log
(hours/sample)
R
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Report Monitoring
Results
(hours/sample)
S
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Reporty Water
System
Inventory /Changes
(hours/sample)
T
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
Labor Cost
($/hour|
U
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
Recordkeeping
Labor
(hours/year)
V=(R+S+T|*D
-
-
-
-
-
Recordkeeping
Cost ($/year)
W=U*V
$
$
$
$
$
$
$
$
$
$
Totals
Total Burden
(hours/year)
X=F+I+V
0
Total O&M Cost
($/year)
Y=G+K+M+O+W
$
$
$
$
$
$
$
$
$
$
Total Capital Cost
($)
Z=Q
$
$
$
$
$
$
$
$
$
$
PageC-31
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.4d Agency Burden and Cost Estimates for Disinfectant Residual Monitoring (2008$), Alternative 1
Compliance Activity
Review Aircraft Monitoring Results
Review Aircraft Water System Inventory/Changes
Total
Disinfectant Residual Samples
Labor Cost
($/hour)
A
$50.14
$50.14
Unit labor burden
(hours/aircraft)
B
0.5
0.5
0.5
Unit Cost
($/aircraft)
C=A*B
$ 25
$ 25
$ 25
Total Labor
Burden (hours)
D=B*7,327
3,664
-
3,664
Total Cost ($)
E=C*7,327
$ 183,703
$
$ 183,703
Sources:
(A) Agency labor costs from Section 5.2.1.
(B) Labor hours for reviewing aircraft monitoring results reflect EPA estimate.
(D) Total labor burden = unit labor burden * total number of aircraft subject to ADWR
(E) Total cost = unit cost * total number of aircraft subject to ADWR .
Page C-32
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.4e Agency Burden and Cost Estimates for Disinfectant Residual Monitoring (2008$), Alternative 2
Compliance Activity
Review Aircraft Monitoring Results
Review Aircraft Water System Inventory/Changes
Total
Disinfectant Residual Samples
Labor Cost
($/hour)
A
$50.14
$50.14
Unit labor burden
(hours/aircraft)
B
0.5
0.5
0.5
Unit Cost
($/aircraft)
C=A*B
$ 25
$ 25
$ 25
Total Labor
Burden (hours)
D=B*7,327
3,664
-
3,664
Total Cost ($)
E=C*7,327
$ 183,703
$
$ 183,703
Sources:
(A) Agency labor costs from Section 5.2.1.
(B) Labor hours for reviewing aircraft monitoring results reflect EPA estimate.
(D) Total labor burden = unit labor burden * total number of aircraft subject to ADWR
(E) Total cost = unit cost * total number of aircraft subject to ADWR .
Page C-33
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.4f Agency Burden and Cost Estimates for Disinfectant Residual Monitoring (2008$), Alternative 3
Compliance Activity
Review Aircraft Monitoring Results
Review Aircraft Water System Inventory/Changes
Total
Disinfectant Residual Samples
Labor Cost
($/hour)
A
$50.14
$50.14
Unit labor burden
(hours/aircraft)
B
0.5
0.5
0.5
Unit Cost
($/aircraft)
C=A*B
$ 25
$ 25
$ 25
Total Labor
Burden (hours)
D
-
-
-
Total Cost ($)
E
$
$
$
Sources:
(A) Agency labor costs from Section 5.2.1.
(B) Labor hours for reviewing aircraft monitoring results reflect EPA estimate.
(D), (E) Disinfectant Residual sampling not required under Alt. 3.
Page C-34
-------
C.5 Turbidity Monitoring
Page C-35
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.5a Air Carrier Burden and Cost Estimates for Turbidity Monitoring (2008$), Alternative 1
#of
Available
Sampling
Points
A
1
2
3
4
5
6
7
8
>9
Total
# of Aircraft
B
381
2,080
756
421
956
871
298
809
755
7,327
Total* of Available
Sampling Points
C=B*A
381
4,160
2,268
1,684
4,780
5,226
2,086
6,472
9,354
36,41 1
Turbidity Samples
Turbidity
(samples/year)
D
-
Turbidity Samplinc
Sampling Labor
Burden
(hours/sample)
E
0.13
0.13
0.13
0.13
0.13
0.13
0.13
0.13
0.13
Total Sampling
Burden
(hours/year)
F=E*D
-
Total Turbidity
Sampling Cost
($/year)
G=F*T
$
$
$
$
$
$
$
$
$
$
Analysis
Analysis Labor
Burden
(hours/sample)
H
0.13
0.13
0.13
0.13
0.13
0.13
0.13
0.13
0.13
Total Analysis
Burden
(hours/year)
I=H*D
-
Unit Shipping
Cost ($/sam pie)
J
$
$
$
$
$
$
$
$
$
Total Shipping
Cost ($/year)
K=J*D
$
Total Analysis
Cost ($/year)
L=I*T
$
$
$
$
$
$
$
$
$
$
Annual Unit
Equipment Cost -
Calibration Kit
($/air carrier/year)
M
$
$
$
$
$
$
$
$
$
Notes:
(C) Average number of available sampling points used for >. 9 sampling points size category.
(D) Turbidity sampling not required under Alt 1.
(E) Assume 7.5 minutes for sample collection and in-house processing and storage of sample.
(H) Based on EPA estimate.
(R), (S) Based on EPA estimate.
(T) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from E
Page C-36
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.5a Air Carrier Burden and Cost Estimates for Turbidity Monitoring (2008$), Alternative 1 (cont'd)
#of
Available
Sampling
Points
A
1
2
3
4
5
6
7
8
>9
Total
Analysis
Annual Unit
Equipment Cost -
Secondary
Standards ($/air
carrier/year)
N
$
$
$
$
$
$
$
$
$
Total Annual
Equipment Cost
($/year)
O
$
$
$
$
$
$
$
$
$
$
Periodic
Equipment Cost
($/air carrier)
P
$
$
$
$
$
$
$
$
$
Periodic
Equipment
Cost ($)
Q
$
$
$
$
$
$
$
$
$
$
Recordkeeping
Maintain
Maintenance Log
(hours/sample)
R
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Report Monitoring
Results
(hours/sample)
S
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Labor Cost
($/hour)
T
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
Recordkeeping
Labor
(hours/year)
U=(R+S)*D
Recordkeeping
Cost ($/year)
V=T*U
$
$
$
$
$
$
$
$
$
$
Totals
Total Burden
(hours/year)
W=F+I+U
-
Total O&M Cost
($/year)
X=G+K+L+O+V
$
$
$
$
$
$
$
$
$
$
Total Capital
Cost ($)
Y=Q
$
$
$
$
$
$
$
$
$
$
Page C-37
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.5b Air Carrier Burden and Cost Estimates for Turbidity Monitoring (2008$), Alternative 2
#of
Available
Sampling
Points
A
1
2
3
4
5
6
7
8
>9
Total
# of Aircraft
B
381
2,080
756
421
956
871
298
809
755
7,327
Total # of Available
Sampling Points
C=B*A
381
4,160
2,268
1,684
4,780
5,226
2,086
6,472
9,354
36,411
Turbidity Samples
Turbidity
(samples/year)
D
-
-
-
-
-
-
Turbidity Sampling
Sampling Labor
Burden
(hours/sample)
E
0.13
0.13
0.13
0.13
0.13
0.13
0.13
0.13
0.13
Total Sampling
Burden
(hours/year)
F=PD
-
-
-
-
-
-
Total Turbidity
Sampling Cost
($/year)
G=PT
$
$
$
$
$
$
$
$
$
$
Analysis
Analysis Labor
Burden
(hours/sample)
H
0.13
0.13
0.13
0.13
0.13
0.13
0.13
0.13
0.13
Total Analysis
Burden
(hours/year)
I=H*D
-
-
-
-
-
-
Unit Shipping
Cost ($/sample)
J
$
$
$
$
-
$
$
$
$
Total Shipping
Cost ($/year)
K=J*D
-
-
-
-
-
$
Total Analysis
Cost ($/year)
L=I*T
$
$
$
$
$
$
$
$
$
$
Annual Unit
Equipment Cost -
Calibration Kit
($/air carrier/year)
M
$
$
$
$
-
$
$
$
$
Notes:
(C) Average number of available sampling points used for^ 9 sampling points size category.
(D) Turbidity sampling not required under Alt 2.
(E) Assume 7.5 minutes for sample collection and in-house processing and storage of sample.
(H) Based on EPA estimate.
(R), (S) Based on EPA estimate.
(T) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1.
Page C-38
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.5b Air Carrier Burden and Cost Estimates for Turbidity Monitoring (2008$), Alternative 2 (cont'd)
#of
Available
Sampling
Points
A
1
2
3
4
5
6
7
8
>9
Total
Analysis
Annual Unit
Equipment Cost
Secondary
Standards ($/air
carrier/year)
N
$
$
$
$
-
$
$
-
-
Total Annual
Equipment Cost
($/year)
O
$
$
$
$
-
$
$
-
$
$
Periodic
Equipment Cost
($/air carrier)
P
$
$
$
$
-
$
$
-
-
Periodic
Equipment
Cost ($)
Q
$
$
$
$
$
$
$
$
$
$
Recordkeeping
Maintain
Maintenance Log
(hours/sample)
R
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Report
Monitoring
Results
(hours/sample)
S
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Labor Cost
($/hour)
T
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
Recordkeeping
Labor
(hours/year)
U=(R+S)*D
-
-
-
-
-
-
Recordkeeping
Cost ($/year)
V=TU
$
$
$
$
$
$
$
$
$
$
Totals
Total Burden
(hours/year)
W=F+I+U
-
-
-
-
-
-
-
Total O&M Cost
($/year)
X=G+K+L+O+V
$
$
$
$
-
$
$
-
$
$
Total Capital
Cost ($)
Y=Q
$
$
$
$
-
$
$
-
$
$
Page C-39
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.5c Air Carrier Burden and Cost Estimates for Turbidity Monitoring (2008$), Alternative 3
# of Available
Sampling
Points
A
1
2
3
4
5
6
7
8
>9
Total
# of Aircraft
B
381
2,080
756
421
956
871
298
809
755
7,327
Total # of Available
Sampling Points
C=B*A
381
4,160
2,268
1,684
4,780
5,226
2,086
6,472
9,354
36,411
Turbidity Samples
Turbidity
(samples/year)
D=365*B*0.5
69,533
379,600
137,970
76,833
174,470
158,958
54,385
147,643
137,788
1,337,178
Turbidity Sampling
Sampling Labor
Burden
(hours/sample)
E
0.13
0.13
0.13
0.13
0.13
0.13
0.13
0.13
0.13
Total Sampling
Burden
(hours/year)
F=E*D
8,692
47,450
17,246
9,604
21,809
19,870
6,798
18,455
17,223
167,147
Total Turbidity
Sampling Cost
($/year)
G=PT
$ 297,896
$ 1,626,309
$ 591,101
$ 329,171
$ 747,477
$ 681,017
$ 233,000
$ 632,540
$ 590,319
$ 5,728,829
Analysis
Analysis Labor
Burden
(hours/sample)
H
0.13
0.13
0.13
0.13
0.13
0.13
0.13
0.13
0.13
Total Analysis
Burden
(hours/year)
I=H*D
8,692
47,450
17,246
9,604
21,809
19,870
6,798
18,455
17,223
167,147
Unit Shipping
Cost ($/sample)
J
$
$
$
$
$
$
$
$
$
Total Shipping
Cost ($/year)
K=J*D
-
-
-
-
-
-
$
Total Analysis
Cost ($/year)
L=I*T
$ 297,896
$ 1,626,309
$ 591,101
$ 329,171
$ 747,477
$ 681,017
$ 233,000
$ 632,540
$ 590,319
$ 5,728,829
Annual Unit
Equipment Cost -
Calibration Kit
($/air carrier/year)
M
$ 97.69
$ 97.69
$ 97.69
$ 97.69
$ 97.69
$ 97.69
$ 97.69
$ 97.69
$ 97.69
Notes:
(C) Average number of available sampling points used for> 9 sampling points size category.
(D) One turbidity sample collected daily per aircraft not implementing O&M plan. Assuming 50% of aircraft implement O&M plan.
(E) Assume 7.5 minutes for sample collection and in-house processing and storage of sample.
(H) Based on EPA estimate.
(J) Estimated courier fees based on costs from various courier services in major cities. Assumed airport distance of 20-30 miles from lab. Assumed courier would return cooler to air carrier. Courier costs are not incurred by turbidity
monitoring since the space taken up by turbidity sample is negligible. 100% of the courier cost is incurred by coliform monitoring.
(M), (N) Assume air carrier will replace calibration kits and secondary standards once a year.
(P) Assume each air carrier will purchase one turbidimeter every five years.
(R), (S) Based on EPA estimate.
(T) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibits. 1.
(U) Assume air carriers perform reporting and recordkeeping activities on a monthly basis for each aircraft.
Page C-40
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.5c Air Carrier Burden and Cost Estimates for Turbidity Monitoring (2008$), Alternative 3 (cont'd)
# of Available
Sampling
Points
A
1
2
3
4
5
6
7
8
>9
Total
Analysis
Annual Unit
Equipment Cost
Secondary
Standards ($/air
carrier/year)
N
$ 124
$ 124
$ 124
$ 124
$ 124
$ 124
$ 124
$ 124
$ 124
Total Annual
Equipment Cost
($/year)
0
$ 726
$ 3,965
$ 1,441
$ 802
$ 1,822
$ 1,660
$ 568
$ 1,542
$ 1,439
$ 13,966
Periodic
Equipment Cost
($/air carrier)
P
$ 858
$ 858
$ 858
$ 858
$ 858
$ 858
$ 858
$ 858
$ 858
Periodic
Equipment
Cost ($)
Q
$ 2,811
$ 15,345
$ 5,577
$ 3,106
$ 7,053
$ 6,426
$ 2,198
$ 5,968
$ 5,570
$ 54,054
Recordkeeping
Maintain
Maintenance Log
(hours/sample)
R
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Report
Monitoring
Results
(hours/sample)
S
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Labor Cost
($/hour)
T
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
Recordkeeping
Labor
(hours/year)
U=(R+S)*B*12
2,286
12,480
4,536
2,526
5,736
5,226
1,788
4,854
4,530
Recordkeeping
Cost ($/year)
V=TU
$ 78,351
$ 427,741
$ 155,468
$ 86,577
$ 196,597
$ 179,117
$ 61,282
$ 166,367
$ 155,262
$ 1,506,761
Totals
Total Burden
(hours/year)
W=F+I+U
19,669
107,380
39,029
21,734
49,354
44,965
15,384
41,765
38,977
378,256
Total O&M Cost
($/year)
X=G+K+L+0+V
$ 674,869
$ 3,684,324
$ 1,339,110
$ 745,721
$ 1,693,372
$ 1,542,811
$ 527,850
$ 1,432,989
$ 1,337,339
$ 12,978,385
Total Capital
Cost ($)
Y=Q
$ 2,811
$ 15,345
$ 5,577
$ 3,106
$ 7,053
$ 6,426
$ 2,198
$ 5,968
$ 5,570
$ 54,054
Page C-41
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.5d Agency Burden and Cost Estimates for Turbidity Monitoring (2008$), Alternative 1
Compliance Activity
Review Aircraft Monitoring Results
Total
Turbidity Monitoring
Labor Cost
($/hour)
A
$50.14
Unit labor burden
(hours/aircraft)
B
0.5
0.5
Unit Cost
($/aircraft)
C=A*B
$ 25
$ 25
Total Labor Burden
(hours)
D
-
-
Total Cost ($)
E
$
$
Sources:
(A) Agency labor costs from Section 5.2.1.
(B) Labor hours for reviewing aircraft monitoring results reflect EPA estimate.
(D), (E) Turbidity monitoring not required under Alt 1.
Page C-42
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.5e Agency Burden and Cost Estimates for Turbidity Monitoring (2008$), Alternative 2
Compliance Activity
Review Aircraft Monitoring Results
Total
Turbidity Monitoring
Labor Cost
($/hour)
A
$50.14
Unit labor burden
(hours/aircraft)
B
0.5
0.5
Unit Cost
($/aircraft)
C=A*B
$ 25
$ 25
Total Labor Burden
(hours)
D
-
-
Total Cost ($)
E
$
$
Sources:
(A) Agency labor costs from Section 5.2.1.
(B) Labor hours for reviewing aircraft monitoring results reflect EPA estimate.
(D), (E) Turbidity monitoring not required under Alt 2.
Page C-43
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.5f Agency Burden and Cost Estimates for Turbidity Monitoring (2008$), Alternative 3
Compliance Activity
Review Aircraft Monitoring Results
Total
Turbidity Monitoring
Labor Cost
($/hour)
A
$50.14
Unit labor burden
(hours/aircraft)
B
0.5
0.5
Unit Cost
($/aircraft)
C=A*B
$ 25
$ 25
Total Labor Burden
(hours)
D=B*(7,327/2)*12
21,981
21,981
Total Cost ($)
E=C*(7,327/2)*12
$ 1,102,215
$ 1,102,215
Sources:
(A) Agency labor costs from Section 5.2.1.
(B) Labor hours for reviewing aircraft monitoring results reflect EPA estimate.
(D) Total labor burden = unit labor burden * (total number of aircraft subject to ADWR/2)*12 monthly reports
(E) Total cost = unit cost * (total number of aircraft subject to ADWR/2)*12 monthly reports .
Page C-44
-------
C. 6 Nitrate/Nitrite Monitoring
Page C-45
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.6a Air Carrier Burden and Cost Estimates for Nitrate/Nitrite Sampling (2008$), Alternative 1
# of Available
Sampling
Points
A
1
2
3
4
5
6
7
8
>9
Total
# of Aircraft
B
381
2,080
756
421
956
871
298
809
755
7,327
Total # of Available
Sampling Points
C=B*A
381
4,160
2,268
1,684
4,780
5,226
2,086
6,472
9,354
36,411
Nitrate/Nitrite Samples
Nitrate/Nitrite
(samples/year)
D
-
-
-
-
1
1
1 0
Nitrate/Nitrite Sampling
Sampling Labor
Burden
(hours/sample)
E
Total Sampling
Burden
(hours/year)
F=E*D
-
-
-
-
-
0
Total
Nitrate/Nitrite
Sampling Cost
($/year)
G
$
$
$
$
$
$
$
$
$
$
Analysis
Analysis Labor
Burden
(hours/sample)
H
0
0
0
0
0
0
0
0
0
Total Analysis
Burden
(hours/year)
I=H*D
-
-
-
-
-
-
0
Unit Shipping
Cost ($/year)
J
$
$
$
$
$
$
$
$
$
Total Shipping
Cost ($/year)
K=J*D
-
-
-
-
-
-
$
Unit Nitrate
Analysis Cost
($/sample)
L
$23.72
$23.72
$23.72
$23.72
$23.72
$23.72
$23.72
$23.72
$23.72
Unit Nitrite
Analysis Cost
($/sample)
M
$22.69
$22.69
$22.69
$22.69
$22.69
$22.69
$22.69
$22.69
$22.69
Notes:
(C) Average number of available sampling points used for> 9 Sampling points size category.
(D) Nitrate/nitrite sampling not required under Alt 1. 1
(E) Assume one hour for sample collection and for process, storage, and shipping of sample.
(H) Assume all analysis conducted by outside lab. 1
(S), (T) Based on EPA estimate. 1
(U) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1.
Page C-46
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.6a Air Carrier Burden and Cost Estimates for Nitrate/Nitrite Sampling (2008$), Alternative 1 (cont'd)
# of Available
Sampling
Points
A
1
2
3
4
5
6
7
8
>9
Total
Analysis
Total Analysis
Cost ($/year)
N=D*(L+M)
-
-
-
-
-
$
Annual Unit
Equipment Cost
($/year)
O
$
$
$
$
$
$
$
$
$
Total Annual
Equipment Cost
($/year)
P=O*B
$
$
$
$
$
$
$
$
$
$
One-time
Equipment
Cost ($)
Q
$
$
$
$
$
$
$
$
$
Total One-time
Equipment Cost
R=Q*B
$
$
$
$
$
$
$
$
$
$
Record keeping
Maintain
Maintenance Log
(hours/sample)
S
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Report Monitoring
Results
(hours/sample)
T
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Labor Cost
($/hour)
U
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
Record keeping
Labor
(hours/year)
V=(S+T)*D
-
-
-
-
-
-
Recordkeeping
Cost ($/year)
W=U*V
$
$
$
$
$
$
$
$
$
$
Totals
Total Burden
(hours/year)
X=F+H+V
-
-
-
-
-
-
0
Total O&M Cost
($/year)
Y=G+K+N+P+W
$
$
$
$
$
$
$
$
$
$
Total Capital
Cost ($)
Z=R
$
$
$
$
$
$
$
$
$
$
Page C-47
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.6b Air Carrier Burden and Cost Estimates for Nitrate/Nitrite Sampling (2008$), Alternative 2
# of Available
Sampling
Points
A
1
2
3
4
5
6
7
8
>9
Total
# of Aircraft
B
381
2,080
756
421
956
871
298
809
755
7,327
Total # of Available
Sampling Points
C=B*A
381
4,160
2,268
1,684
4,780
5,226
2,086
6,472
9,354
36,411
Nitrate/Nitrite Samples
Nitrate/Nitrite
(samples/year)
D
-
-
-
-
-
0
Nitrate/Nitrite Sampling
Sampling Labor
Burden
(hours/sample)
E
1
1
1
1
1
1
1
1
1
Total Sampling
Burden
(hours/year)
F=E*D
-
-
-
-
-
0
Total
Nitrate/Nitrite
Sampling Cost
($/year)
G
$
$
$
$
$
-
$
$
$
$
Analysis
Analysis Labor
Burden
(hours/sample)
H
0
0
0
0
0
0
0
0
0
Total Analysis
Burden
(hours/year)
I=H*D
-
-
-
-
-
0
Unit Shipping
Cost ($/year)
J
$
$
$
$
$
-
$
$
$
Total Shipping
Cost ($/year)
K=J*D
-
-
-
-
-
$
Unit Nitrate
Analysis Cost
($/sample)
L
$23.72
$23.72
$23.72
$23.72
$23.72
$23.72
$23.72
$23.72
$23.72
Unit Nitrite
Analysis Cost
($/sample)
M
$22.69
$22.69
$22.69
$22.69
$22.69
$22.69
$22.69
$22.69
$22.69
Notes:
(C) Average number of available sampling points used for> 9 sampling points size category.
(D) Nitrate/nitrite sampling not required under Alt 2.
(E) Assume one hour for sample collection and for process, storage, and shipping of sample.
(H) Assume all analysis conducted by outside lab.
(S), (T) Based on EPA estimate.
(U) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibits. 1.
Page C-48
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.6b Air Carrier Burden and Cost Estimates for Nitrate/Nitrite Sampling (2008$), Alternative 2 (cont'd)
# of Available
Sampling
Points
A
1
2
3
4
5
6
7
8
>9
Total
Analysis
Total Analysis
Cost ($/year)
N=D*(L+M)
-
-
-
-
$
Annual Unit
Equipment Cost
($/year)
0
$
$
$
$
$
-
$
$
$
Total Annual
Equipment Cost
($/year)
P=0*B
$
$
$
$
$
-
$
$
$
$
One-time
Equipment
Cost ($)
Q
$
$
$
$
$
$
$
$
$
Total One-time
Equipment Cost
R=Q*B
$
$
$
$
$
$
$
$
$
$
Recordkeeping
Maintain
Maintenance Log
(hours/sample)
S
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Report Monitoring
Results
(hours/sample)
T
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Labor Cost
($/hour)
U
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
Recordkeeping
Labor (hours/year)
V=(S+T)*D
-
-
-
Recordkeeping
Cost ($/year)
W=U*V
$
$
$
$
$
$
$
$
$
$
Totals
Total Burden
(hours/year)
X=F+H+V
-
-
-
0
Total O&M Cost
($/year)
Y=G+K+N+P+W
$
$
$
$
$
$
$
$
$
$
Total Capital
Cost ($)
Z=R
$
$
$
$
$
$
$
$
$
$
Page C-49
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.6c Air Carrier Burden and Cost Estimates for Nitrate/Nitrite Sampling (2008$), Alternative 3
# of Available
Sampling
Points
A
1
2
3
4
5
6
7
8
>9
Total
# of Aircraft
B
381
2,080
756
421
956
871
298
809
755
7,327
Total # of Available
Sampling Points
C=B*A
381
4,160
2,268
1,684
4,780
5,226
2,086
6,472
9,354
36,411
Nitrate/Nitrite Samples
Nitrate/Nitrite
(samples/year)
D
-
-
-
-
-
0
Nitrate/Nitrite Sampling
Sampling Labor
Burden
(hours/sample)
E
1
1
1
1
1
1
1
1
1
Total Sampling
Burden
(hours/year)
F=E*D
-
-
-
-
-
0
Total
Nitrate/Nitrite
Sampling Cost
($/year)
G
$
$
$
$
$
$
$
$
$
$
Analysis
Analysis Labor
Burden
(hours/sample)
H
0
0
0
0
0
0
0
0
0
Total Analysis
Burden
(hours/year)
I=H*D
-
-
-
-
-
0
Unit Shipping
Cost ($/year)
J
$
$
$
$
$
-
$
$
$
Total Shipping
Cost ($/year)
K=J*D
-
-
-
-
-
$
Unit Nitrate
Analysis Cost
($/sample)
L
$23.72
$23.72
$23.72
$23.72
$23.72
$23.72
$23.72
$23.72
$23.72
Unit Nitrite
Analysis Cost
($/sample)
M
$22.69
$22.69
$22.69
$22.69
$22.69
$22.69
$22.69
$22.69
$22.69
Notes:
(C) Average number of available sampling points used for> 9 sampling points size category.
(D) Nitrate/nitrite sampling not required under Alt 3.
(E) Assume one hour for sample collection and for process, storage, and shipping of sample.
(H) Assume all analysis conducted by outside lab.
(S), (T) Based on EPA estimate.
(U) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibits. 1.
Page C-50
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.6c Air Carrier Burden and Cost Estimates for Nitrate/Nitrite Sampling (2008$), Alternative 3 (cont'd)
# of Available
Sampling
Points
A
1
2
3
4
5
6
7
8
>9
Total
Analysis
Total Analysis
Cost ($/year)
N=D*(L+M)
-
-
-
-
$
Annual Unit
Equipment Cost
($/year)
0
$
$
$
$
$
$
$
$
$
Total Annual
Equipment Cost
($/year)
P=0*B
$
$
$
$
$
$
$
$
$
$
One-time
Equipment
Cost ($)
Q
$
$
$
$
$
$
$
$
$
Total One-time
Equipment Cost
R=Q*B
$
$
$
$
$
$
$
$
$
$
Recordkeeping
Maintain
Maintenance
Log
(hours/sample)
S
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Report
Monitoring
Results
(hours/sample)
T
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Labor Cost
($/hour)
U
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
Recordkeeping
Labor (hours/year)
V=(S+T)*D
-
-
-
Recordkeeping
Cost ($/year)
W=U*V
$
$
$
$
$
$
$
$
$
$
Totals
Total Burden
(hours/year)
X=F+H+V
-
-
-
0
Total O&M Cost
($/year)
Y=G+K+N+P+W
$
$
$
$
$
$
$
$
$
$
Total Capital
Cost ($)
Z=R
$
$
$
$
$
$
$
$
$
$
PageC-51
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.6d Agency Burden and Cost Estimates for Nitrate/Nitrite Sampling (2008$), Alternative 1
Compliance Activity
Review Aircraft Monitoring Results
Total
Nitrate&Nitrite Monitoring
Labor Cost
($/hour)
A
$50.14
Unit labor burden
(hours/aircraft)
B
0.5
0.5
Unit Cost
($/aircraft)
C=A*B
$ 25
$ 25
Total Labor
Burden (hours)
D
-
-
Total Cost ($)
E
-
$
Sources:
(A) Agency labor costs from Section 5.2.1.
(B) Labor hours for reviewing aircraft monitoring results reflect EPA estimate.
(D), (E) Nitrate/nitrite monitoring not required under Alt 1.
Page C-52
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.6e Agency Burden and Cost Estimates for Nitrate/Nitrite Sampling (2008$), Alternative 2
Compliance Activity
Review Aircraft Monitoring Results
Total
Nitrate&Nitrite Monitoring
Labor Cost
($/hour)
A
$50.14
Unit labor burden
(hours/aircraft)
B
0.5
0.5
Unit Cost
($/aircraft)
C=A*B
$ 25
$ 25
Total Labor
Burden (hours)
D
-
-
Total Cost ($)
E
-
$
Sources:
(A) Agency labor costs from Section 5.2.1.
(B) Labor hours for reviewing aircraft monitoring results reflect EPA estimate.
(D), (E) Nitrate/nitrite monitoring not required under Alt 2.
Page C-53
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.6f Agency Burden and Cost Estimates for Nitrate/Nitrite Sampling (2008$), Alternative 3
Compliance Activity
Review Aircraft Monitoring Results
Total
Nitrate&Nitrite Monitoring
Labor Cost
($/hour)
A
$50.14
Unit labor burden
(hours/aircraft)
B
0.5
0.5
Unit Cost
($/aircraft)
C=A*B
$ 25
$ 25
Total Labor
Burden (hours)
D
-
-
Total Cost ($)
E
-
$
Sources:
(A) Agency labor costs from Section 5.2.1.
(B) Labor hours for reviewing aircraft monitoring results reflect EPA estimate.
(D), (E) Nitrate/nitrite monitoring not required under Alt 3.
Page C-54
-------
CJO&MPlan
Page C-55
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.7a Air Carrier Burden and Cost Estimates for O&M Plan (2008$), Alternative 1
Compliance Activity
Update existing O&M manual and practices with ADWR
specific requirements
Total
Labor Cost
($/hour)
A
$42.86
One-time Labor Burden
(hours/air carrier)
B
80
80
Unit Cost
C=A*B
$ 3,429
$ 3,429
Total Labor Burden
(hours)
D
.
-
Total Cost ($)
E
$
$
Sources:
(A) Air carrier labor costs from Exhibit 5.1. EPA used the transportation inspector category because it was the highest-paid technical labor category. Transportation
inspectors are assumed to have a technical background, as well as some management or oversight responsibility.
(B) Labor hours for developing and implementing O&M plan reflect EPA estimate.
(D), (E) O&M plans not required under Alt 1.
Page C-56
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.7b Air Carrier Burden and Cost Estimates for O&M Plan (2008$), Alternative 2
Compliance Activity
Update existing O&M manual and practices with ADWR
specific requirements
Total
Labor Cost
($/hour)
A
$42.86
One-time Labor Burden
(hours/air carrier)
B
80
80
Unit Cost
C=A*B
$ 3,429
$ 3,429
Total Labor Burden
(hours)
D
.
-
Total Cost ($)
E
$
$
Sources:
(A) Air carrier labor costs from Exhibit 5.1. EPA used the transportation inspector category because it was the highest-paid technical labor category. Transportation inspectors
are assumed to have a technical background, as well as some management or oversight responsibility.
(B) Labor hours for developing and implementing O&M plan reflect EPA estimate.
(D), (E) O&M plans not required under Alt 2.
Page C-57
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.7c Air Carrier Burden and Cost Estimates for O&M Plan (2008$), Alternative 3
Compliance Activity
Update existing O&M manual and practices with ADWR
specific requirements
Total
Labor Cost
($/hour)
A
$42.86
One-time Labor Burden
(hours/air carrier)
B
80
80
Unit Cost
C=A*B
$ 3,429
$ 3,429
Total Labor Burden
(hours)
D=B*(63/2)
2,520
2,520
Total Cost ($)
E=C*(63/2)
$ 108,002
$ 108,002
Sources:
(A) Air carrier labor costs from Exhibit 5.1. EPA used the transportation inspector category because it was the highest-paid technical labor category. Transportation inspectors
are assumed to have a technical background, as well as some management or oversight responsibility.
(B) Labor hours for developing and implementing O&M plan reflect EPA estimate.
(D), (E) Assume 50% of the 63 U.S. air carriers subject to ADWR will develop O&M plans in lieu of required monitoring. Assumes all air carriers spend equal time developing
and implementing O&M plan, regardless of fleet size or aircraft type.
Page C-58
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.7d Agency Burden and Cost Estimates for O&M Plan (2008$), Alternative 1
Compliance Activity
Review and approve O&M manual and practices
Total
Labor Cost
($/hour)
A
$50.14
One-time Labor Burden
(hours/air carrier)
B
10
10
Unit Cost
C=A*B
$ 501
$ 501
Total Labor Burden
(hours)
D
-
-
Total Cost ($)
E=C
$
$
Sources:
(A) Agency labor costs from Section 5.2.1.
(B) Labor hours for reviewing and approving O&M plan reflect EPA estimate.
(D), (E) O&M plans not required under Alt 1.
Page C-59
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.7e Agency Burden and Cost Estimates for O&M Plan (2008$), Alternative 2
Compliance Activity
Review and approve O&M manual and practices
Total
Labor Cost
($/hour)
A
$50.14
One-time Labor Burden
(hours/air carrier)
B
10
10
Unit Cost
C=A*B
$ 501
$ 501
Total Labor Burden
(hours)
D
-
-
Total Cost ($)
E=C
$
$
Sources:
(A) Agency labor costs from Section 5.2.1.
(B) Labor hours for reviewing and approving O&M plan reflect EPA estimate.
(D), (E) O&M plans not required under Alt 2.
Page C-60
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.7f Agency Burden and Cost Estimates for O&M Plan (2008$), Alternative 3
Compliance Activity
Review and approve O&M manual and practices
Total
Labor Cost
($/hour)
A
$50.14
One-time Labor Burden
(hours/air carrier)
B
10
10
Unit Cost
C=A*B
$ 501
$ 501
Total Labor Burden
(hours)
D=B*(63/2)
315
315
Total Cost ($)
E=C*(63/2)
$ 15,795
$ 15,795
Sources:
(A) Agency labor costs from Section 5.2.1.
(B) Labor hours for reviewing and approving O&M plan reflect EPA estimate.
(D), (E) Assume 50% of the 63 U.S. air carriers subject to ADWR will develop O&M plans in lieu of required monitoring. Assumes all Regional Agency offices spend equal time
reviewing and approving O&M plan, regardless of fleet size or aircraft type.
Page C-61
-------
C. 8 Routine Disinfection and Flushing
Page C-62
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.8a Air Carrier Burden and Cost Estimates for Routine Disinfection and Flushing (2008$), Alternative 1
# of Available
Sampling
Points
A
1
2
3
4
5
6
7
8
>9
Total
# of Aircraft
B
381
2,080
756
421
956
871
298
809
755
7,327
Total # of
Available
Sampling Points
C=B*A
381
4,160
2,268
1,684
4,780
5,226
2,086
6,472
9,354
36,411
Routine Disinfection and Flushing
Routine
Disinfection and
Flushing
(aircraft/year)
D
-
-
-
-
-
-
-
-
-
-
Self-
Certification
(aircraft/year)
E
-
-
-
-
-
-
-
-
-
-
Routine
Disinfection
and Flushing
Labor Burden
(hours/aircraft)
F
5
5
5
5
5
5
5
5
5
Self
Certification
Labor Burden
(hours/aircraft)
G
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
Unit
Disinfection
and Flushing
Cost ($/hour)
H
$20.19
$20.19
$20.19
$20.19
$20.19
$20.19
$20.19
$20.19
$20.19
Unit Self-Certification
Cost ($/hour)
I
$65.42
$65.42
$65.42
$65.42
$65.42
$65.42
$65.42
$65.42
$65.42
Unit Chemical Costs
($/application)
J
$ 1
$ 1
$ 1
$ 1
$ 1
$ 1
$ 1
$ 1
$ 1
Total Routine
Disinfection and
Flushing Costs
($/year)
K=(D*PH)+(D*J)
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
Notes:
(C) Average number of available sampling points used for >_ 9 sampling points size category.
(D) Routine disinfection and flushing not required under Alt 1.
(E) Self-certification submittal not required under Alt 1.
(F) EPA estimate based on observation of flushing and disinfection practices.
(G) Labor hours for self-certification reflects EPA estimate.
(H) Based on costs for cleaners of vehicles and equipment from Exhibit 5.1.
(I) Based on costs for transportation, storage, and distribution managers from Exhibit 5.1.
(J) Chemicals used for disinfection cost approximately $1 per application (based on 12.5% chlorine solution from Harcros Chemicals, which costs $12 per 4 gallon jugs).
(M) Based on EPA estimate.
(O) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1.
Page C-63
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.8a Air Carrier Burden and Cost Estimates for Routine Disinfection and Flushing (2008$), Alternative 1 (cont'd)
# of Available
Sampling
Points
A
1
2
3
4
5
6
7
8
>9
Total
Recordkeeping
Total Cost for
Self
Certification
($/year)
L=E*G*I
$
$
$
$
$
$
$
$
$
$0
Maintain Maintenance
Log for Disinfection
Activities Burden
(hours/aircraft)
M
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Maintain Maintenance
Log for Disinfection
Activities Burden
(hours/year)
N=D*M
-
-
-
-
-
-
-
-
-
Recordkeeping
Labor Cost
($/hour)
O
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
Maintain
Maintenance
Log for
Disinfection
Activities
Costs ($/year)
P=N*O
$
$
$
$
$
$
$
$
$
$
Totals
Total Routine
Disinfection/Flushing
Labor Burden
(hours/year)
Q=(D*F)+(E*G) + N
-
-
-
-
-
-
-
-
-
0
Total O&M Cost
($/year)
R=K+L+P
$
$
$
$
$
$
$
$
$
$
Total Capital
Cost ($)
S
$
Page C-64
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.8b Air Carrier Burden and Cost Estimates for Routine Disinfection and Flushing (2008$), Alternative 2
# of Available
Sampling
Points
A
1
2
3
4
5
6
7
8
>9
Total
# of Aircraft
B
381
2,080
756
421
956
871
298
809
755
7,327
Total# of Available
Sampling Points
C=B*A
381
4,160
2,268
1,684
4,780
5,226
2,086
6,472
9,354
36,41 1
Routine Disinfection and Flushing
Routine
Disinfection and
Flushing
(aircraft/year)
D=BM
1,524
8,320
3,024
1,684
3,824
3,484
1,192
3,236
3,020
29,308
Self-Certification
(aircraft/year)
E=B*4
1524
8320
3024
1684
3824
3484
1192
3236
3020
29,308
Routine Disinfection
and Flushing Burden
(hours/aircraft)
F
5
5
5
5
5
5
5
5
5
Self Certification
Labor Burden
(hours/aircraft)
G
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
Unit Disinfection
and Flushing
Cost ($/hour)
H
$20.19
$20.19
$20.19
$20.19
$20.19
$20.19
$20.19
$20.19
$20.19
Unit Self-
Certification Cost
($/hour)
I
$65.42
$65.42
$65.42
$65.42
$65.42
$65.42
$65.42
$65.42
$65.42
Unit Chemical
Costs
($/application)
J
$ 1
$ 1
$ 1
$ 1
$ 1
$ 1
$ 1
$ 1
$ 1
Total Routine
Disinfection
and Flushing
Costs ($/year)
K=(D*PH)+(D*J
)
$155,508
$848,966
$308,567
$171,834
$390,198
$355,505
$121,631
$330,199
$308,158
$2,990,566
Notes:
(C) Average number of available sampling points used fori 9 sampling points size category.
(D) Quarterly routine disinfection and flushing required per aircraft.
(E) Aircraft is required to submit self-certification quarterly.
(F) EPA estimate based on observation of flushing and disinfection practices.
(G) Labor hours for self-certification reflects EPA estimate.
(H) Based on costs for cleaners of vehicles and equipment from Exhibit 5.1.
(I) Based on costs for transportation, storage, and distribution managers from Exhibit 5.1.
(J) Chemicals used for disinfection cost approximately $1 per application (based on 12.5% chlorine solution from Harcros Chemicals, which costs $12 per 4 gallon jugs).
(M) Based on EPA estimate.
(O) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1.
Page C-65
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.8b Air Carrier Burden and Cost Estimates for Routine Disinfection and Flushing (2008$), Alternative 2 (cont'd)
# of Available
Sampling
Points
A
1
2
3
4
5
6
7
8
>9
Total
Recordkeeping
Total Cost for
Self
Certification
($/year)
L=E*G*I
$ 49,847
$ 272,129
$ 98,909
$ 55,080
$ 125,075
$ 113,954
$ 38,988
$ 105,843
$ 98,778
$958,602
Maintain Maintenance
Log for Disinfection
Activities Burden
(hours/aircraft)
M
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Maintain Maintenance
Log for Disinfection
Activities Burden
(hours/year)
N=D*M
381
2,080
756
421
956
871
298
809
755
Recordkeeping
Labor Cost
($/hour)
O
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
Maintain
Maintenance
Log for
Disinfection
Activities
Costs ($/year)
P=N*O
$ 13,058
$ 71,290
$ 25,911
$ 14,429
$ 32,766
$ 29,853
$ 10,214
$ 27,728
$ 25,877
$ 251,127
Totals
Total Routine
Disinfection/Flushing
Labor Burden
(hours/year)
Q=(D*F)+(E*G) + N
8,763
47,840
17,388
9,683
21,988
20,033
6,854
18,607
17,365
168,521
Total O&M
Cost ($/year)
R=K+L+P
$ 218,413
$ 1,192,386
$ 433,386
$ 241 ,344
$ 548,039
$ 499,312
$ 170,832
$ 463,769
$ 432,813
$ 4,200,295
Total
Capital
Cost ($)
S
$
Page C-66
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.8c Air Carrier Burden and Cost Estimates for Routine Disinfection and Flushing (2008$), Alternative 3
# of Available
Sampling
Points
A
1
2
3
4
5
6
7
8
>9
Total
# of Aircraft
B
381
2,080
756
421
956
871
298
809
755
7,327
Total # of
Available
Sampling
Points
C=B*A
381
4,160
2,268
1,684
4,780
5,226
2,086
6,472
9,354
36,411
Routine Disinfection and Flushing
Routine
Disinfection and
Flushing
(aircraft/year)
D = 4*B
1,524
8,320
3,024
1,684
3,824
3,484
1,192
3,236
3,020
29,308
Self-
Certification
(aircraft/year)
E
0
0
0
0
0
0
0
0
0
0
Routine
Disinfection and
Flushing Burden
(hours/aircraft)
F
5
5
5
5
5
5
5
5
5
Self Certification
Labor Burden
(hours/aircraft)
G
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
Unit
Disinfection
and Flushing
Cost ($/hour)
H
$20.19
$20.19
$20.19
$20.19
$20.19
$20.19
$20.19
$20.19
$20.19
Unit Self-
Certification Cost
($/hour)
I
$65.42
$65.42
$65.42
$65.42
$65.42
$65.42
$65.42
$65.42
$65.42
Unit Chemical
Costs
($/application)
J
$ 1
$ 1
$ 1
$ 1
$ 1
$ 1
$ 1
$ 1
$ 1
Total Routine
Disinfection and
Flushing Costs
($/year)
K=(D*F*H)+(D*J)
$155,508
$848,966
$308,567
$171,834
$390,198
$355,505
$121,631
$330,199
$308,158
$2,990,566
Notes:
(C) Average number of available sampling points used for > 9 sampling points size category.
(D) Quarterly routine disinfection and flushing per aircraft. Routine disinfection and flushing also required after any aircraft service or repairs. Assume aircraft service and repairs occur in
same quarter as required routine disinfection and flushing.
(E) Self-certification submittal not required under Alternative 3.
(F) EPA estimate based on observation of flushing and disinfection practices.
(G) Labor hours for self-certification reflects EPA estimate.
(H) Based on costs for cleaners of vehicles and equipment from Exhibit 5.1.
(I) Based on costs for transportation, storage, and distribution managers from Exhibit 5.1.
(J) Chemicals used for disinfection cost approximately $1 per application (based on 12.5% chlorine solution from Harcros Chemicals, which costs $12 per 4 gallon jugs).
(M) Based on EPA estimate.
(O) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1.
Page C-67
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.8c Air Carrier Burden and Cost Estimates for Routine Disinfection and Flushing (2008$), Alternative 3 (cont'd)
# of Available
Sampling
Points
A
1
2
3
4
5
6
7
8
>9
Total
Recordkeeping
Total Cost for
Self
Certification
($/year)
L=E*G*I
$
$
$
$
$
$
$
$
$
$0
Maintain Maintenance
Log for Disinfection
Activities Burden
(hours/aircraft)
M
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Maintain Maintenance
Log for Disinfection
Activities Burden
(hours/year)
N=D*M
381
2,080
756
421
956
871
298
809
755
Recordkeeping
Labor Cost
($/hour)
O
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
Maintain
Maintenance
Log for
Disinfection
Activities
Costs ($/year)
P=N*O
$ 13,058
$ 71 ,290
$ 25,911
$ 14,429
$ 32,766
$ 29,853
$ 10,214
$ 27,728
$ 25,877
$ 251,127
Totals
Total Routine
Disinfection/Flushing
Labor Burden
(hours/year)
Q=(D*F)+(E*G) + N
8,001
43,680
15,876
8,841
20,076
18,291
6,258
16,989
15,855
153,867
Total O&M Cost
($/year)
R=K+L+P
$ 168,566
$ 920,257
$ 334,478
$ 186,263
$ 422,964
$ 385,357
$ 131,844
$ 357,927
$ 334,035
$ 3,241 ,692
Total Capital
Cost ($)
S
$
Page C-68
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.8d Agency Burden and Cost Estimates for Routine Disinfection and Flushing (2008$), Alternative 1
Compliance Activity
Review Aircraft Self-Certification
Total
Routine Disinfection and Flushing
Labor Cost
($/hour)
A
$50.14
Unit labor burden
(hours/aircraft)
B
0.5
0.5
Unit Cost
($/aircraft)
C=A*B
$ 25
$ 25
Total Labor Burden
(hours/year)
D
-
-
Total Cost ($/year)
E
$
$
Sources:
(A) Agency labor costs from Section 5.2.1.
(B) Labor hours for reviewing aircraft self-certification reflect EPA estimate.
(D) Total labor burden = unit labor burden * number of aircraft submitting self-certification (Ex. C8a).
(E) Total cost = unit cost * number of aircraft submitting self-certification (Ex. C8a).
Page C-69
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.8e Agency Burden and Cost Estimates for Routine Disinfection and Flushing (2008$), Alternative 2
Compliance Activity
Review Aircraft Self-Certification
Total
Routine Disinfection and Flushing
Labor Cost
($/hour)
A
$50.14
Unit labor burden
(hours/aircraft)
B
0.5
0.5
Unit Cost
($/aircraft)
C=A*B
$ 25
$ 25
Total Labor Burden
(hours/year)
D
14,654
14,654
Total Cost ($/year)
E
$ 734,810
$ 734,810
Sources:
(A) Agency labor costs from Section 5.2.1.
(B) Labor hours for reviewing aircraft self-certification reflect EPA estimate.
(D) Total labor burden = unit labor burden * number of aircraft submitting self-certification (Ex. C8b).
(E) Total cost = unit cost * number of aircraft submitting self-certification (Ex. C8b).
Page C-70
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.8f Agency Burden and Cost Estimates for Routine Disinfection and Flushing (2008$), Alternative 3
Compliance Activity
Review Aircraft Self-Certification
Total
Routine Disinfection and Flushing
Labor Cost
($/hour)
A
$50.14
Unit labor burden
(hours/aircraft)
B
0.5
0.5
Unit Cost
($/aircraft)
C=A*B
$ 25
$ 25
Total Labor Burden
(hours/year)
D
-
-
Total Cost ($/year)
E
$
$
Sources:
(A) Agency labor costs from Section 5.2.1.
(B) Labor hours for reviewing aircraft self-certification reflect EPA estimate.
(D) Total labor burden = unit labor burden * number of aircraft submitting self-certification (Ex. C8c).
(E) Total cost = unit cost * number of aircraft submitting self-certification (Ex. 8c).
Page C-71
-------
C.9 Corrective Action
Disinfection and Flushing
Page C-72
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.9a Air Carrier Burden and Cost Estimates for Corrective Action Disinfection and Flushing (2008$), Alternative 1
# of Available
Sampling
Points
A
1
2
3
4
5
6
7
8
>9
Total
# of Aircraft
B
381
2,080
756
421
956
871
298
809
755
7,327
Total # of
Available
Sampling Points
C=B«A
381
4,160
2,268
1,684
4,780
5,226
2,086
6,472
9,354
36,411
Corrective Action Disinfection and Flushing
Corrective
Action
Disinfection and
Flushing
(aircraft/year)
D
-
Repeat
Disinfection
and Flushing
(aircraft/year)
E
-
Corrective
Action
Disinfection
and Flushing
Labor Burden
(hours/aircraft)
F
5
5
5
5
5
5
5
5
5
Unit
Disinfection
and Flushing
Cost ($/hour)
G
$20. 9
$20. 9
$20. 9
$20. 9
$20. 9
$20. 9
$20. 9
$20. 9
$20. 9
Unit Chemical
Costs
($/application)
H
$
$
$
$
$
$
$
$
$
Total Corrective Action
Disinfection and Flushim
Costs ($/year)
l=((D-t€)«(F«G)HD+E)«H)
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
Recordkeeping
Maintain Maintenance
Log for Disinfection
Activities Burden
(hours/aircraft)
J
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Maintain
Maintenance Log
for Disinfection
Activities Burden
(hours/year)
K=(D-tE)*J
Recordkeeping
Labor Cost
($/hour)
L
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
Maintain Maintenance
Log for Disinfection
Activities Costs
($/year)
M=K*L
$
$
$
$
$
$
$
$
$
Totals
Total Corrective
Action
Disinfection/Flushing
Labor Burden
(hours/year)
N=((D+E)*F)+K
-
-
-
-
0
Total O&M Cost
($/year)
O=I+M
$
$
$
$
$
$
$
$
$
$
Total Capital
Cost ($)
P
$
Notes:
(C) Average number of available sampling points usedfop 9 sampling points size category.
(D) Corrective action disinfection and flushing not required under Alt 1.
(E) Assumes first flushing/disinfecting is successful.
(F) EPA estimate based on observation of flushing and disinfection practices.
(G) Based on costs for cleaners of vehicles and equipment from Exhibit 5.1.
(H) Chemicals used for disinfection cost approximately $1 per application (based on 12.5% chlorine solution from Harcros Chemicals, which costs $12 per 4 gallon jugs).
(J) Based on EPA estimate.
(L) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1.
Page C-73
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.9b Air Carrier Burden and Cost Estimates for Corrective Action Disinfection and Flushing (2008$), Alternative 2
# of Available
Sampling
Points
A
1
2
3
4
5
6
7
8
>9
Total
# of Aircraft
B
381
2,080
756
421
956
871
298
809
755
7,327
Total* of Available
Sampling Points
C=B*A
381
4,160
2,268
1,684
4,780
5,226
2,086
6,472
9,354
36,411
Corrective Action Disinfection and Flushing
Corrective Action
Disinfection and
Flushing
(aircraft/year)
D
27
150
54
30
69
63
21
58
54
528
Repeat
Disinfection and
Flushing
(aircraft/year)
E
0
0
0
0
0
0
0
0
0
0
Corrective Action
Disinfection and
Flushing Labor
Burden
(hours/aircraft)
F
5
5
5
5
5
5
5
5
5
Unit Disinfection
and Flushing
Cost ($/hour)
G
$20. 9
$20. 9
$20. 9
$20. 9
$20. 9
$20. 9
$20. 9
$20. 9
$20. 9
Unit Chemical
Costs
($/application)
H
$ 1
$ 1
$ 1
$ 1
$ 1
$ 1
$ 1
$ 1
$ 1
Total Corrective
Action
Disinfection and
Flushing Costs
($/year)
I=((D+E|«(F«G))+(D
$2,799
$15,281
$5,554
$3,093
$7,024
$6,399
$2,189
$5,944
$5,547
$53,830
Recordkeeping
Maintain
Maintenance
Log for
Disinfection
Activities
Burden
(hours/aircraft
)
J
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Maintain
Maintenance
Log for
Disinfection
Activities
Burden
(hours/year)
K=(D+E|*J
7
37
14
8
17
16
5
15
14
Recordkeeping
Labor Cost
(S/liour)
L
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
Maintain Maintenance
Log for Disinfection
Activities Costs
($/year)
M=K*L
$ 235
$ 1,283
$ 466
$ 260
$ 590
$ 537
$ 184
$ 499
$ 466
Totals
Total Corrective
Action
Disinfection/Flushing
Labor Burden
(hours/year)
N=((D+E|*F|-tK
144
786
286
159
361
329
113
306
285
2,770
Total O&M Cost
($/year)
O=I+M
$ 3,034
$ 16,565
$ 6,021
$ 3,353
$ 7,613
$ 6,936
$ 2,373
$ 6,443
$ 6,013
$ 58,350
Total Capital
Cost ($)
P
$
Notes:
(C) Average number of available sampling points usedfop 9 sampling points size category.
(D) Corrective action disinfection and flushing required after positive total coliform sample. Assume entire aircraft flu shed if either lavatory or galley has a positive total coliform sample. Assume
more than one TC+ per aircraft.
(E) Assumes first flushing/disinfecting is successful.
(F) EPA estimate based on observation of flushing and disinfection practices.
(G) Based on costs for cleaners of vehicles and equipment from Exhibit 5.1.
(H) Chemicals used for disinfection cost approximately $1 per application (based on 12.5% chlorine solution from Harcros Chemicals, which costs $12 per 4 gallon jugs).
(J) Based on EPA estimate.
(L) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1.
Page C-74
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.9c Air Carrier Burden and Cost Estimates for Corrective Action Disinfection and Flushing (2008$), Alternative 3
# of Available
Sampling
Points
A
1
2
3
4
5
6
7
8
>9
Total
# of Aircraft
B
381
2,080
756
421
956
871
298
809
755
7,327
Total # of
Available
Sampling
Points
C=B*A
381
4,160
2,268
1,684
4,780
5,226
2,086
6,472
9,354
36,411
Corrective Action Disinfection and Flushing
Corrective Action
Disinfection and
Flushing
(aircraft/year)
D
27
150
54
30
69
63
21
58
54
528
Repeat
Disinfection
and Flushing
(aircraft/year)
E
0
0
0
0
0
0
0
0
0
0
Corrective Action
Disinfection and
Flushing Labor
Burden
(hours/aircraft)
F
5
5
5
5
5
5
5
5
5
Unit Disinfection
and Flushing
Cost ($/hour)
G
$20. 9
$20. 9
$20. 9
$20. 9
$20. 9
$20. 9
$20. 9
$20. 9
$20. 9
Unit Chemical
Costs
($/application)
H
$ 1
$ 1
$ 1
$ 1
$ 1
$ 1
$ 1
$ 1
$ 1
Total Corrective
Action Disinfectior
and Flushing
Costs ($/year)
I=((D+E|«(F«G))+(D
$2,799
$15,281
$5,554
$3,093
$7,024
$6,399
$2,189
$5,944
$5,547
$53,830
Recordkeeping
Maintain
Maintenance
Log for
Disinfection
Activities
Burden
(hours/aircraft
J
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Maintain
Maintenance Log for
Disinfection
Activities Burden
(hours/year)
K=(D+E|*J
7
37
14
8
17
16
5
15
14
Recordkeeping
Labor Cost
($/hour)
L
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
$34.27
Maintain Maintenance
Log for Disinfection
Activities Costs ($/year
M=K*L
$ 235
$ 1,283
$ 466
$ 260
$ 590
$ 537
$ 184
$ 499
$ 466
Totals
Total Corrective
Action
Disinfection/Flushing
Labor Burden
(hours/year)
N=((D+E|*F|+K
144
786
286
159
361
329
113
306
285
2,770
Total O&M Cost
($/year)
O=I+M
$ 3,034
$ 16,565
$ 6,021
$ 3,353
$ 7,613
$ 6,936
$ 2,373
$ 6,443
$ 6,013
$ 58,350
Total Capital
Cost ($)
P
$
Notes:
(C) Average number of available sampling points usedfop 9 sampling points size category.
(D) Corrective action disinfection and flushing required after positive total coliform sample. Assume entire aircraft flu shed if either lavatory or galley has a positive total coliform sample.
Assume no more than one TC+ per aircraft.
(E) Assumes first flushing/disinfecting is successful.
(F) EPA estimate based on observation of flushing and disinfection practices.
(G) Based on costs for cleaners of vehicles and equipment from Exhibit 5.1.
(H) Chemicals used for disinfection cost approximately $1 per application (based on 12.5% chlorine solution from Harcros Chemicals, which costs $12 per 4 gallon jugs).
(J) Based on EPA estimate.
(L) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1.
Page C-75
-------
C.10 Sanitary Survey/
Compliance Audit
Page C-76
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.10a Air Carrier Burden and Cost Estimates for Sanitary Survey (2008$), Alternative 1
# of Available Sampling Points
A
1
2
3
4
5
6
7
8
>9
Total
# of Aircraft
B
381
2,080
756
421
956
871
298
809
755
7,327
Reporting and Recordkeeping costs associated with
Sanitary Survey of Aircraft PWS
Total # of
Available
Sampling Points
C=B*A
381
4,160
2,268
1,684
4,780
5,226
2,086
6,472
9,354
36,411
Unit Labor Cost
($/hour)
D
$42.86
$42.86
$42.86
$42.86
$42.86
$42.86
$42.86
$42.86
$42.86
Unit labor burden
(hours/aircraft)
E
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
Totals
Total Labor Burden (hours/SS
cycle)
F=B*E
190.50
1,040.00
378.00
210.50
478.00
435.50
149.00
404.50
377.50
3,664
Total O&M Cost ($/SS cycle)
G=D*F
$ 8,164
$ 44,572
$ 16,200
$ 9,022
$ 20,486
$ 18,665
$ 6,386
$ 17,336
$ 16,179
$ 157,010
Total Capital
Cost ($)
H
$
$
$
$
$
$
$
$
$
$
Sources:
(D) Air carrier labor costs from Exhibit 5.1. EPA used the transportation inspector category because it was the highest-paid technical labor category. Transportation inspectors are assumed to have a technical
background, as well as some management or oversight responsibility.
(E) Labor burden reflects EPA estimate for reporting and recordkeeping only. EPA assumes that air carriers already conduct major maintenance checks, which include sanitary survey components, every 5 years for each aircraft.
Therefore, with the exception of reporting and recordkeeping burden, no additional costs for sanitary surveys are incurred by air carriers under the ADWR.
(F), (G) All aircraft undergo sanitary surveys once in 5 years.
Page C-77
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.10b Air Carrier Burden and Cost Estimates for Sanitary Survey (2008$), Alternative 2
#of Available Sampling Points
A
1
2
3
4
5
6
7
8
>9
Total
# of Aircraft
B
381
2,080
756
421
956
871
298
809
755
7,327
Reporting and Recordkeeping costs associated with
Sanitary Survey of Aircraft PWS
Total # of
Available
Sampling Points
C=B*A
381
4,160
2,268
1,684
4,780
5,226
2,086
6,472
9,354
36,411
Unit Labor Cost
($/hour)
D
$42.86
$42.86
$42.86
$42.86
$42.86
$42.86
$42.86
$42.86
$42.86
Unit labor burden
(hours/aircraft)
E
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
Totals
Total Labor Burden
(hours/year)
F
-
-
-
-
-
-
.
-
-
Total O&M
Cost ($/year)
G=D*F
$
-
$
$
$
-
$
$
$
$
Total Capital
Cost ($)
H
$
$
$
$
$
$
$
$
$
$
Sources:
(D) Air carrier labor costs from Exhibit 5.1. EPA used the transportation inspector category because it was the highest-paid technical labor category. Transportation inspectors are
assumed to have a technical background, as well as some management or oversight responsibility.
(E) Labor burden reflects EPA estimate for reporting and recordkeeping only. EPA assumes that air carriers already conduct major maintenance checks, which include sanitary survey components,
every 5 years for each aircraft. Therefore, with the exception of reporting and recordkeeping burden, no additional costs for sanitary surveys are incurred by air carriers under the ADWR.
(F), (G) Sanitary surveys not specified under Alternative 2. Assume no sanitary surveys conducted.
Page C-78
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.10c Air Carrier Burden and Cost Estimates for Sanitary Survey (2008$), Alternative 3
# of Available Sampling Points
A
1
2
3
4
5
6
7
8
>9
Total
# of Aircraft
B
381
2,080
756
421
956
871
298
809
755
7,327
Reporting and Recordkeeping costs associated with
Sanitary Survey of Aircraft PWS
Total # of
Available
Sampling Points
C=B*A
381
4,160
2,268
1,684
4,780
5,226
2,086
6,472
9,354
36,411
Unit Labor Cost
($/hour)
D
$42.86
$42.86
$42.86
$42.86
$42.86
$42.86
$42.86
$42.86
$42.86
Unit labor burden
(hours/aircraft)
E
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
Totals
Total Labor
Burden
(hours/year)
F=B*E
-
-
-
.
-
Total O&M
Cost ($/year)
G=D*F
$
$
$
$
$
$
$
$
$
$
Total Capital
Cost ($)
H
$
$
$
$
$
$
$
$
$
$
Sources:
(D) Air carrier labor costs from Exhibit 5.1. EPA used the transportation inspector category because it was the highest-paid technical labor category. Transportation inspectors are
assumed to have a technical background, as well as some management or oversight responsibility.
(E) Labor burden reflects EPA estimate for reporting and recordkeeping only. EPA assumes that air carriers already conduct major maintenance checks, which include sanitary survey components,
every 5 years for each aircraft. Therefore, with the exception of reporting and recordkeeping burden, no additional costs for sanitary surveys are incurred by air carriers under the ADWR.
(F), (G) Sanitary surveys not specified under Alternative 3. Assume no sanitary surveys conducted.
Page C-79
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.10d Agency Burden and Cost Estimates for Sanitary Survey (2008$), Alternative 1
# of Available
Sampling Points
A
1
2
3
4
5
6
7
8
>9
Total
# of Aircraft
B
381
2,080
756
421
956
871
298
809
755
7,327
Total # of
Available
Sampling Points
C=B*A
381
4,160
2,268
1,684
4,780
5,226
2,086
6,472
9,354
36,411
Unit Labor
Cost
($/hour)
D
$50.14
$50.14
$50.14
$50.14
$50.14
$50.14
$50.14
$50.14
$50.14
Conducting Sanitary Surveys of Aircraft PWSs
Review/Inspect
Aircraft Distribution
System
E
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.6
Report
Documentation/File
Review
F
1.5
1.5
1.5
1.5
1.5
1.5
1.5
1.5
1.5
Report
Development
G
5.2
5.2
5.2
5.2
5.2
5.2
5.2
5.2
5.2
Data Entry
H
0.8
0.8
0.8
0.8
0.8
0.8
0.8
0.8
0.8
Travel
I
1.8
1.8
1.8
1.8
1.8
1.8
1.8
1.8
1.8
Unit labor burden
(hours/aircraft)
J=E+F+G+H+I
10
10
10
10
10
10
10
10
10
Unit Cost
($/aircraft)
K=D*J
$ 496
$ 496
$ 496
$ 496
$ 496
$ 496
$ 496
$ 496
$ 496
Totals
Total Labor Burden
(hours/SS cycle)
L=B*J
3,772
20,592
7,484
4,168
9,464
8,623
2,950
8,009
7,475
72,537
Total Labor Cost
($/SS cycle)
M=B*K
$ 189,138
$ 1,032,565
$ 375,298
$ 208,995
$ 474,583
$ 432,387
$ 147,935
$ 401,608
$ 374,801
$ 3,637,310
Total Capital
Costs ($)
N
(C) Average number of available sampling points used for^ 9 sampling points size category.
(D) Agency labor costs from Section 5.2.1.
(E)-(l
(L), (M) National totals for Agency to conduct sanitary surveys for 7,327 aircraft subject to ADWR once every 5 years. Assumes Agency spends equal time conducting sanitary surveys of each aircraft, regardless of aircraft type.
Page C-80
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.10e Agency Burden and Cost Estimates for Sanitary Survey (2008$), Alternative 2
Compliance Activity
Conducting Sanitary Survey of aircraft PWSs
Total
Labor Cost
($/hour)
A
$50.14
Unit labor burden
(hours/air carrier)
B
16
16
Unit Cost ($/air
carrier)
C=A*B
$ 802
$ 802
Total Labor Burden
(hours/SS cycle)
D
-
-
Total Labor Cost ($/SS cycle)
E
$
$
Sources:
(A) Agency labor costs from Section 5.2.1.
(B) Labor hours for conducting sanitary survey reflect EPA estimate.
(D), (E) Sanitary survey requirements are not specified for Alt. 2. Assumed no sanitary surveys conducted.
Page C-81
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.10f Agency Burden and Cost Estimates for Sanitary Survey (2008$), Alternative 3
Compliance Activity
Conducting Sanitary Survey of aircraft PWSs
Total
Labor Cost
($/hour)
A
$50.14
Unit labor burden
(hours/air carrier)
B
16
16
Unit Cost ($/air
carrier)
C=A*B
$ 802
$ 802
Total Labor Burden
(hours/SS cycle)
D
-
-
Total Labor Cost ($/SS cycle)
E
$
$
Sources:
(A) Agency labor costs from Section 5.2.1.
(B) Labor hours for conducting sanitary survey reflect EPA estimate.
(D), (E) Sanitary survey requirements are not specified for Alt. 3. Assumed no sanitary surveys conducted.
Page C-82
-------
C.11 Rule Schedule
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.11 Rule Schedule
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Implementation
50%
50%
Annual
Administration
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
Monitoring Plan
50%
50%
Monitoring - TC
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
Monitoring -
Disinfectant
Residual
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
Turbidity
Monitoring
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
Nitrate/Nitrite
Monitoring
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
O&M Plan
50%
50%
Routine Disinfection
& Flushing
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
CA Disinfection &
Flushing
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
Sanitary
Survey/Compliance
Audit
20%
20%
20%
20%
20%
20%
20%
20%
20%
20%
20%
20%
20%
20%
20%
20%
20%
20%
20%
20%
20%
20%
20%
Notes:
1) Public notification is not covered under ADWR, but is covered under PNR.
Page C-84
-------
C.12 Nominal Costs
Page C-85
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.12a Nominal Rule Activity Costs for Alternative 1, by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Implementation
$ 0.09
$ 0.09
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Annual
Administration
$
$
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
Monitoring Plan
$ 0.02
$ 0.02
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Monitoring - TC
$
$
$ 27.71
$ 27.67
$ 27.67
$ 27.67
$ 27.67
$ 27.67
$ 27.67
$ 27.67
$ 27.67
$ 27.67
$ 27.71
$ 27.67
$ 27.67
$ 27.67
$ 27.67
$ 27.67
$ 27.67
$ 27.67
$ 27.67
$ 27.67
$ 27.67
$ 27.67
$ 27.67
Monitoring -
Disinfectant
Residual
$
$
$ 3.46
$ 3.46
$ 3.46
$ 3.46
$ 3.46
$ 3.46
$ 3.46
$ 3.46
$ 3.46
$ 3.46
$ 3.46
$ 3.46
$ 3.46
$ 3.46
$ 3.46
$ 3.46
$ 3.46
$ 3.46
$ 3.46
$ 3.46
$ 3.46
$ 3.46
$ 3.46
Turbidity
Monitoring
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Nitrate/Nitrite
Monitoring
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
O&M Plan
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Routine Disinfection
& Flushing
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
CA Disinfection &
Flushing
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Sanitary Survey
$
$
$ 0.76
$ 0.76
$ 0.76
$ 0.76
$ 0.76
$ 0.76
$ 0.76
$ 0.76
$ 0.76
$ 0.76
$ 0.76
$ 0.76
$ 0.76
$ 0.76
$ 0.76
$ 0.76
$ 0.76
$ 0.76
$ 0.76
$ 0.76
$ 0.76
$ 0.76
$ 0.76
Notes:
1) Public notification is not covered under ADWR, but is covered under PNR.
2) Values in millions of 2008 dollars.
3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.
Page C-86
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.12b Nominal Air Carrier Activity Costs for Alternative 1, by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Implementation
$ 0.02
$ 0.02
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Annual
Administration
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Monitoring Plan
$ 0.01
$ 0.01
$
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Monitoring - TC
$
$
$ 27.38
$ 27.34
$ 27.34
$ 27.34
$ 27.34
$ 27.34
$ 27.34
$ 27.34
$ 27.34
$ 27.34
$ 27.38
$ 27.34
$ 27.34
$ 27.34
$ 27.34
$ 27.34
$ 27.34
$ 27.34
$ 27.34
$ 27.34
$ 27.34
$ 27.34
$ 27.34
Monitoring -
Disinfectant
Residual
$
$
$ 3.27
$ 3.27
$ 3.27
$ 3.27
$ 3.27
$ 3.27
$ 3.27
$ 3.27
$ 3.27
$ 3.27
$ 3.27
$ 3.27
$ 3.27
$ 3.27
$ 3.27
$ 3.27
$ 3.27
$ 3.27
$ 3.27
$ 3.27
$ 3.27
$ 3.27
$ 3.27
Turbidity
Monitoring
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Nitrate/Nitrite
Monitoring
$
$
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
O&M Plan
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Routine Disinfection
& Flushing
$
$
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
CA Disinfection &
Flushing
$
$
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Sanitary Survey
$
$
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
Notes:
1) Public notification is not covered under ADWR, but is covered under PNR.
2) Values in millions of 2008 dollars.
3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.
Page C-87
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.12c Nominal Agency Activity Costs for Alternative 1, by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Implementation
$ 0.07
$ 0.07
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Annual
Administration
$
$
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
Monitoring Plan
$ 0.01
$ 0.01
$
-
-
-
-
-
-
-
-
-
-
-
-
$
$
-
-
-
-
-
-
$
$
Monitoring - TC
$
$
$ 0.33
$ 0.33
$ 0.33
$ 0.33
$ 0.33
$ 0.33
$ 0.33
$ 0.33
$ 0.33
$ 0.33
$ 0.33
$ 0.33
$ 0.33
$ 0.33
$ 0.33
$ 0.33
$ 0.33
$ 0.33
$ 0.33
$ 0.33
$ 0.33
$ 0.33
$ 0.33
Monitoring -
Disinfectant
Residual
$
$
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
Turbidity
Monitoring
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Nitrate/Nitrite
Monitoring
$
$
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
O&M Plan
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Routine Disinfection
& Flushing
$
$
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
CA Disinfection &
Flushing
$
$
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Sanitary Survey
$
$
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
Notes:
1) Public notification is not covered under ADWR, but is covered under PNR.
2) Values in millions of 2008 dollars.
3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.
Page C-8
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.12d Nominal Rule Activity Costs for Alternative 2, by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Implementation
$ 0.09
$ 0.09
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Annual
Administration
$
$
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
Monitoring Plan
$ 0.02
$ 0.02
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Monitoring - TC
$
$
$ 1.85
$ 1.82
$ 1.82
$ 1.82
$ 1.82
$ 1.82
$ 1.82
$ 1.82
$ 1.82
$ 1.82
$ 1.85
$ 1.82
$ 1.82
$ 1.82
$ 1.82
$ 1.82
$ 1.82
$ 1.82
$ 1.82
$ 1.82
$ 1.82
$ 1.82
$ 1.82
Monitoring -
Disinfectant
Residual
$
$
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
Turbidity
Monitoring
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Nitrate/Nitrite
Monitoring
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
O&M Plan
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Routine
Disinfection &
Flushing
$
$
$ 4.94
$ 4.94
$ 4.94
$ 4.94
$ 4.94
$ 4.94
$ 4.94
$ 4.94
$ 4.94
$ 4.94
$ 4.94
$ 4.94
$ 4.94
$ 4.94
$ 4.94
$ 4.94
$ 4.94
$ 4.94
$ 4.94
$ 4.94
$ 4.94
$ 4.94
$ 4.94
CA Disinfection &
Flushing
$
$
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
Sanitary Survey
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Notes:
1) Public notification is not covered under ADWR, but is covered under PNR.
2) Values in millions of 2008 dollars.
3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation
period.
Page C-89
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.12e Nominal Air Carrier Activity Costs for Alternative 2, by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Implementation
$ 0.02
$ 0.02
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Annual
Administration
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Monitoring Plan
$ 0.01
$ 0.01
$
-
-
-
-
-
-
-
-
-
-
-
-
$
$
-
-
-
-
-
-
-
-
Monitoring - TC
$
$
$ 1.84
$ 1.80
$ 1.80
$ 1.80
$ 1.80
$ 1.80
$ 1.80
$ 1.80
$ 1.80
$ 1.80
$ 1.84
$ 1.80
$ 1.80
$ 1.80
$ 1.80
$ 1.80
$ 1.80
$ 1.80
$ 1.80
$ 1.80
$ 1.80
$ 1.80
$ 1.80
Monitoring -
Disinfectant
Residual
$
$
$ 0.55
$ 0.55
$ 0.55
$ 0.55
$ 0.55
$ 0.55
$ 0.55
$ 0.55
$ 0.55
$ 0.55
$ 0.55
$ 0.55
$ 0.55
$ 0.55
$ 0.55
$ 0.55
$ 0.55
$ 0.55
$ 0.55
$ 0.55
$ 0.55
$ 0.55
$ 0.55
Turbidity
Monitoring
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Nitrate/Nitrite
Monitoring
$
$
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
O&M Plan
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Routine Disinfection
& Flushing
$
$
$ 4.20
$ 4.20
$ 4.20
$ 4.20
$ 4.20
$ 4.20
$ 4.20
$ 4.20
$ 4.20
$ 4.20
$ 4.20
$ 4.20
$ 4.20
$ 4.20
$ 4.20
$ 4.20
$ 4.20
$ 4.20
$ 4.20
$ 4.20
$ 4.20
$ 4.20
$ 4.20
CA Disinfection &
Flushing
$
$
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
Sanitary Survey
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Notes:
1) Public notification is not covered under ADWR, but is covered under PNR.
2) Values in millions of 2008 dollars.
3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.
Page C-90
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.12f Nominal Agency Activity Costs for Alternative 2, by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Implementation
$ 0.07
$ 0.07
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
-
-
-
-
-
-
-
-
Annual
Administration
$
$
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
Monitoring Plan
$ 0.01
$ 0.01
$
-
-
-
-
-
-
-
-
-
-
-
-
$
$
$
$
$
$
$
$
$
$
Monitoring - TC
$
$
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
Monitoring -
Disinfectant
Residual
$
$
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
$ 0.18
Turbidity
Monitoring
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Nitrate/Nitrite
Monitoring
$
$
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
O&M Plan
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Routine Disinfection
& Flushing
$
$
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
$ 0.73
CA Disinfection &
Flushing
$
$
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Sanitary Survey
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Notes:
1) Public notification is not covered under ADWR, but is covered under PNR.
2) Values in millions of 2008 dollars.
3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.
Page C-91
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.12g Nominal Rule Activity Costs for Alternative 3, by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Implementation
$ 0.09
$ 0.09
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Annual
Administration
$
$
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
Monitoring Plan
$ 0.01
$ 0.01
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
-
-
Monitoring - TC
$
$
$ 2.47
$ 2.43
$ 2.43
$ 2.43
$ 2.43
$ 2.43
$ 2.43
$ 2.43
$ 2.43
$ 2.43
$ 2.47
$ 2.43
$ 2.43
$ 2.43
$ 2.43
$ 2.43
$ 2.43
$ 2.43
$ 2.43
$ 2.43
$ 2.43
$ 2.43
$ 2.43
monitoring -
Disinfectant
Residual
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Turbidity
Monitoring
$
$
$ 14.13
$ 14.08
$ 14.08
$ 14.08
$ 14.08
$ 14.13
$ 14.08
$ 14.08
$ 14.08
$ 14.08
$ 14.13
$ 14.08
$ 14.08
$ 14.08
$ 14.08
$ 14.13
$ 14.08
$ 14.08
$ 14.08
$ 14.08
$ 14.13
$ 14.08
$ 14.08
Nitrate/Nitrite
Monitoring
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
-
-
O&M Plan
$ 0.06
$ 0.06
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Routine
Disinfection &
Flushing
$
$
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
CA Disinfection &
Flushing
$
$
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
Sanitary Survey
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Notes:
1) Public notification is not covered under ADWR, but is covered under PNR.
2) Values in millions of 2008 dollars.
3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.
Page C-92
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.12h Nominal Air Carrier Activity Costs for Alternative 3, by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Implementation
$ 0.02
$ 0.02
$
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Annual
Administration
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Monitoring Plan
$ 0.01
$ 0.01
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Monitoring - TC
$
$
$ 2.46
$ 2.42
$ 2.42
$ 2.42
$ 2.42
$ 2.42
$ 2.42
$ 2.42
$ 2.42
$ 2.42
$ 2.46
$ 2.42
$ 2.42
$ 2.42
$ 2.42
$ 2.42
$ 2.42
$ 2.42
$ 2.42
$ 2.42
$ 2.42
$ 2.42
$ 2.42
Monitoring -
Disinfectant
Residual
$
$
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Turbidity
Monitoring
$
$
$ 13.03
$ 12.98
$ 12.98
$ 12.98
$ 12.98
$ 13.03
$ 12.98
$ 12.98
$ 12.98
$ 12.98
$ 13.03
$ 12.98
$ 12.98
$ 12.98
$ 12.98
$ 13.03
$ 12.98
$ 12.98
$ 12.98
$ 12.98
$ 13.03
$ 12.98
$ 12.98
Nitrate/Nitrite
Monitoring
$
$
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
O&M Plan
$ 0.05
$ 0.05
$
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Routine Disinfection
& Flushing
$
$
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
$ 3.24
CA Disinfection &
Flushing
$
$
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
$ 0.06
Sanitary Survey
$
$
-
-
-
-
-
-
-
-
-
-
-
-
$
$
-
-
-
-
-
-
-
-
-
Notes:
1) Public notification is not covered under ADWR, but is covered under PNR.
2) Values in millions of 2008 dollars.
3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.
Page C-93
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.12J Nominal Agency Activity Costs for Alternative 3, by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Implementation
$ 0.07
$ 0.07
$
-
-
-
-
$
$
-
-
-
-
-
-
$
$
-
-
-
-
-
-
-
-
Annual
Administration
$
$
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
Monitoring Plan
$ 0.00
$ 0.00
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Monitoring - TC
$
$
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
Monitoring -
Disinfectant
Residual
$
$
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Turbidity
Monitoring
$
$
$ 1.10
$ 1.10
$ 1.10
$ 1.10
$ 1.10
$ 1.10
$ 1.10
$ 1.10
$ 1.10
$ 1.10
$ 1.10
$ 1.10
$ 1.10
$ 1.10
$ 1.10
$ 1.10
$ 1.10
$ 1.10
$ 1.10
$ 1.10
$ 1.10
$ 1.10
$ 1.10
Nitrate/Nitrite
Monitoring
$
$
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
O&M Plan
$ 0.01
$ 0.01
$
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Routine Disinfection
& Flushing
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
CA Disinfection &
Flushing
$
$
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Sanitary Survey
$
$
-
-
-
-
$
$
-
-
-
-
-
-
$
$
-
-
-
-
-
-
-
-
-
Notes:
1) Public notification is not covered under ADWR, but is covered under PNR.
2) Values in millions of 2008 dollars.
3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.
Page C-94
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.12J Nominal Rule Activity Costs for Alternative 4 (Final Rule), by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Implementation
$ 0.09
$ 0.09
$
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Annual
Administration
$
$
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
Sampling Plan
$ 0.02
$ 0.02
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Monitoring - TC
$
$
$ 5.41
$ 5.37
$ 5.37
$ 5.37
$ 5.37
$ 5.37
$ 5.37
$ 5.37
$ 5.37
$ 5.37
$ 5.41
$ 5.37
$ 5.37
$ 5.37
$ 5.37
$ 5.37
$ 5.37
$ 5.37
$ 5.37
$ 5.37
$ 5.37
$ 5.37
$ 5.37
Monitoring -
Disinfectant
Residual
$
$
-
-
-
-
-
-
-
-
-
-
-
$
$
$
-
-
-
-
-
$
$
$
$
Turbidity
Monitoring
$
$
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Nitrate/Nitrite
Monitoring
$
$
-
-
-
-
-
-
-
-
-
-
-
$
$
$
-
-
-
-
-
$
$
$
$
O&M Plan
$ 0.11
$ 0.11
$
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Routine Disinfection
& Flushing
$
$
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
CA Disinfection &
Flushing
$
$
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
Compliance Audit
$
$
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
Notes:
1) Public notification is not covered under ADWR, but is covered under PNR.
2) Values in millions of 2008 dollars.
3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.
Page C-95
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.12k Nominal Air Carrier Activity Costs for Alternative 4 (Final Rule), by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Implementation
$ 0.02
$ 0.02
$
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Annual
Administration
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Sampling Plan
$ 0.01
$ 0.01
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Monitoring - TC
$
$
$ 5.37
$ 5.33
$ 5.33
$ 5.33
$ 5.33
$ 5.33
$ 5.33
$ 5.33
$ 5.33
$ 5.33
$ 5.37
$ 5.33
$ 5.33
$ 5.33
$ 5.33
$ 5.33
$ 5.33
$ 5.33
$ 5.33
$ 5.33
$ 5.33
$ 5.33
$ 5.33
Monitoring -
Disinfectant
Residual
$
$
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Turbidity
Monitoring
$
$
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Nitrate/Nitrite
Monitoring
$
$
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
O&M Plan
$ 0.11
$ 0.11
$
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Routine Disinfection
& Flushing
$
$
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
$ 2.27
CA Disinfection &
Flushing
$
$
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
Compliance Audit
$
$
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
Notes:
1) Public notification is not covered under ADWR, but is covered under PNR.
2) Values in millions of 2008 dollars.
3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.
Page C-96
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.12I Nominal Agency Activity Costs for Alternative 4 (Final Rule), by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Implementation
$ 0.07
$ 0.07
$
-
-
-
-
-
-
-
-
-
-
-
-
$
$
-
-
-
-
-
-
-
-
Annual
Administration
$
$
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
$ 0.26
Sampling Plan
$ 0.01
$ 0.01
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Monitoring - TC
$
$
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
Monitoring -
Disinfectant
Residual
$
$
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Turbidity
Monitoring
$
$
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Nitrate/Nitrite
Monitoring
$
$
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
O&M Plan
$ 0.00
$ 0.00
$
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Routine Disinfection
& Flushing
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
CA Disinfection &
Flushing
$
$
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Compliance Audit
$
$
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
Notes:
1) Public notification is not covered under ADWR, but is covered under PNR.
2) Values in millions of 2008 dollars.
3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.
Page C-97
-------
C.13 Present Value at 3 Percent
Page C-98
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.13a Present Value of Rule Activity Costs for Alternative 1 at 3 Percent, by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Total
PV
Annua
lized
Implementati
on
$ 0.09
$ 0.09
$
$
$
$
-
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$ 0.18
$ 0.01
Annual
Administration
$
$
$ 0.24
$ 0.24
$ 0.23
$ 0.22
$ 0.22
$ 0.21
$ 0.20
$ 0.20
$ 0.19
$ 0.19
$ 0.18
$ 0.18
$ 0.17
$ 0.17
$ 0.16
$ 0.16
$ 0.15
$ 0.15
$ 0.14
$ 0.14
$ 0.14
$ 0.13
$ 0.13
$ 4.13
$ 0.24
Monitoring
Plan
$ 0.02
$ 0.02
$
$
$
$
-
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$ 0.04
$ 0.00
Monitoring -
TC
$
$
$ 26.12
$ 25.32
$ 24.59
$ 23.87
$ 23.18
$ 22.50
$ 21.84
$ 21.21
$ 20.59
$ 19.99
$ 19.44
$ 18.84
$ 18.29
$ 17.76
$ 17.24
$ 16.74
$ 16.25
$ 15.78
$ 15.32
$ 14.88
$ 14.44
$ 14.02
$ 13.61
$ 441.85
$ 25.37
Monitoring -
Disinfectant
Residual
$
$
$ 3.26
$ 3.16
$ 3.07
$ 2.98
$ 2.90
$ 2.81
$ 2.73
$ 2.65
$ 2.57
$ 2.50
$ 2.43
$ 2.35
$ 2.29
$ 2.22
$ 2.15
$ 2.09
$ 2.03
$ 1.97
$ 1.91
$ 1.86
$ 1.80
$ 1.75
$ 1.70
$ 55.20
$ 3.17
Turbidity
Monitoring
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
Nitrate/
Nitrite
Monitoring
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
-
$
$
$
$
$
$
$
O&M
Plan
$ -
$ -
$ -
$ -
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
Routine
Disinfection &
Flushing
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
CA
Disinfection &
Flushing
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Sanitary
Survey
$ -
$ -
$ 0.72
$ 0.69
$ 0.67
$ 0.65
$ 0.64
$ 0.62
$ 0.60
$ 0.58
$ 0.56
$ 0.55
$ 0.53
$ 0.52
$ 0.50
$ 0.49
$ 0.47
$ 0.46
$ 0.45
$ 0.43
$ 0.42
$ 0.41
$ 0.40
$ 0.38
$ 0.37
$ 12.12
$ 0.70
Notes:
1) Public notification is not covered under ADWR, but is covered
2) Present values in millions of 2008 dollars, discounted to Y1.
3) Assume refrigerators are purchased two times (in years 3 and
under PNR.
13) in the 25-year evaluation period.
Page C-99
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.13b Present Value of Air Carrier Activity Costs for Alternative 1 at 3 Percent, by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
lotal
PV
Annual!
zed
Implementation
$ 0.02
$ 0.02
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$ 0.04
$ 0.00
Annual
Administration
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Monitoring
Plan
$ 0.01
$ 0.01
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
$ 0.03
$ 0.00
Monitoring -
TC
$
$
$ 25.81
$ 25.02
$ 24.29
$ 23.59
$ 22.90
$ 22.23
$ 21.58
$ 20.96
$ 20.34
$ 19.75
$ 19.20
$ 18.62
$ 18.08
$ 17.55
$ 17.04
$ 16.54
$ 16.06
$ 15.59
$ 15.14
$ 14.70
$ 14.27
$ 13.85
$ 13.45
$ 436.57
$ 25.07
Monitoring -
Disinfectant
Residual
$
$
$ 3.09
$ 3.00
$ 2.91
$ 2.82
$ 2.74
$ 2.66
$ 2.58
$ 2.51
$ 2.44
$ 2.37
$ 2.30
$ 2.23
$ 2.16
$ 2.10
$ 2.04
$ 1.98
$ 1.92
$ 1.87
$ 1.81
$ 1.76
$ 1.71
$ 1.66
$ 1.61
$ 52.26
$ 3.00
Turbidity
Monitoring
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Nitrate/
Nitrite
Monitoring
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
O&M
Plan
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
Routine
Disinfection &
Flushing
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
CA
Disinfection
& Flushing
-
$
$
$
-
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
$
$
Sanitary
Survey
$ -
$ -
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.50
$ 0.03
Notes:
1) Public notification is not covered under ADWR, but is covered
2) Present values in millions of 2008 dollars, discounted to Y1.
3) Assume refrigerators are purchased two times (in years 3 and
under PNR.
13) in the 25-year evaluation period.
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.13c Present Value of Agency Activity Costs for Alternative 1 at 3 Percent, by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Total
PV
Annual!
zed
Implementation
$ 0.07
$ 0.07
$
$
$
$
$
$
$
$
$
-
$
$
$
$
$
$
$
-
$
$
$
$
$
$ 0.14
$ 0.01
Annual
Administration
$
$
$ 0.24
$ 0.24
$ 0.23
$ 0.22
$ 0.22
$ 0.21
$ 0.20
$ 0.20
$ 0.19
$ 0.19
$ 0.18
$ 0.18
$ 0.17
$ 0.17
$ 0.16
$ 0.16
$ 0.15
$ 0.15
$ 0.14
$ 0.14
$ 0.14
$ 0.13
$ 0.13
$ 4.13
$ 0.24
Monitoring
Plan
$ 0.01
$ 0.01
$
$
$
$
$
-
$
$
$
-
$
$
$
$
$
$
$
-
$
$
$
-
$
$ 0.02
$ 0.00
Monitoring -
TC
$
$
$ 0.31
$ 0.30
$ 0.29
$ 0.29
$ 0.28
$ 0.27
$ 0.26
$ 0.25
$ 0.25
$ 0.24
$ 0.23
$ 0.23
$ 0.22
$ 0.21
$ 0.21
$ 0.20
$ 0.19
$ 0.19
$ 0.18
$ 0.18
$ 0.17
$ 0.17
$ 0.16
$ 5.28
$ 0.30
Monitoring -
Disinfectant
Residual
$
$
$ 0.17
$ 0.17
$ 0.16
$ 0.16
$ 0.15
$ 0.15
$ 0.15
$ 0.14
$ 0.14
$ 0.13
$ 0.13
$ 0.13
$ 0.12
$ 0.12
$ 0.11
$ 0.11
$ 0.11
$ 0.10
$ 0.10
$ 0.10
$ 0.10
$ 0.09
$ 0.09
$ 2.93
$ 0.17
Turbidity
Monitoring
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Nitrate/
Nitrite
Monitoring
$
$
$
$
$
$
$
$
$
$
$
-
$
$
$
$
$
$
$
-
$
$
$
$
$
$
$
O&M
Plan
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
-
$ -
$ -
$ -
$ -
$ -
$ -
$ -
-
$ -
$ -
$ -
$ -
$ -
$ -
$ -
Routine
Disinfection
& Flushing
$
$
$
$
$
$
$
$
$
$
$
-
$
$
$
$
$
$
$
-
$
$
$
$
$
$
$
CA
Disinfection
& Flushing
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Sanitary
Survey
$
$
$ 0.69
$ 0.67
$ 0.65
$ 0.63
$ 0.61
$ 0.59
$ 0.57
$ 0.56
$ 0.54
$ 0.53
$ 0.51
$ 0.50
$ 0.48
$ 0.47
$ 0.45
$ 0.44
$ 0.43
$ 0.41
$ 0.40
$ 0.39
$ 0.38
$ 0.37
$ 0.36
$ 11.61
$ 0.67
Notes:
1) Public notification is not covered under ADWR, but is covered
2) Present values in millions of 2008 dollars, discounted to Y1.
3) Assume refrigerators are purchased two times (in years 3 and
under PNR.
13) in the 25-year evaluation period.
Page C-101
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.13d Present Value of Rule Activity Costs for Alternative 2 at 3 Percent, by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Total PV
Annual!
zed
Implementation
$ 0.09
$ 0.09
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$ 0.18
$ 0.01
Annual
Administration
$
$
$ 0.24
$ 0.24
$ 0.23
$ 0.22
$ 0.22
$ 0.21
$ 0.20
$ 0.20
$ 0.19
$ 0.19
$ 0.18
$ 0.18
$ 0.17
$ 0.17
$ 0.16
$ 0.16
$ 0.15
$ 0.15
$ 0.14
$ 0.14
$ 0.14
$ 0.13
$ 0.13
$ 4.13
$ 0.24
Monitoring
Plan
$ 0.02
$ 0.02
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$ 0.04
$ 0.00
Monitoring -
TC
$
$
$ 1.75
$ 1.66
$ 1.61
$ 1.57
$ 1.52
$ 1.48
$ 1.43
$ 1.39
$ 1.35
$ 1.31
$ 1.30
$ 1.24
$ 1.20
$ 1.17
$ 1.13
$ 1.10
$ 1.07
$ 1.04
$ 1.01
$ 0.98
$ 0.95
$ 0.92
$ 0.89
$ 29.05
$ 1.67
Monitoring -
Disinfectant
Residual
$
$
$ 0.69
$ 0.67
$ 0.65
$ 0.63
$ 0.61
$ 0.59
$ 0.58
$ 0.56
$ 0.54
$ 0.53
$ 0.51
$ 0.50
$ 0.48
$ 0.47
$ 0.45
$ 0.44
$ 0.43
$ 0.42
$ 0.40
$ 0.39
$ 0.38
$ 0.37
$ 0.36
$ 11.64
$ 0.67
Turbidity
Monitoring
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Nitrate/
Nitrite
Monitoring
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
O&M
Plan
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
Routine
Disinfection
& Flushing
$
$
$ 4.65
$ 4.52
$ 4.38
$ 4.26
$ 4.13
$ 4.01
$ 3.90
$ 3.78
$ 3.67
$ 3.57
$ 3.46
$ 3.36
$ 3.26
$ 3.17
$ 3.08
$ 2.99
$ 2.90
$ 2.81
$ 2.73
$ 2.65
$ 2.58
$ 2.50
$ 2.43
$ 78.79
$ 4.52
CA
Disinfection &
Flushing
$
$
$ 0.06
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.93
$ 0.05
Sanitary
Survey
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Notes:
1) Public notification is not covered under ADWR, but is covered under PNR.
2) Present values in millions of 2008 dollars, discounted to Y1.
3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.
Page C-102
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.13e Present Value of Air Carrier Activity Costs for Alternative 2 at 3 Percent, by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Total PV
Annualiz
ed
Implementation
$ 0.02
$ 0.02
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$ 0.04
$ 0.00
Annual
Administration
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Monitoring
Plan
$ 0.01
$ 0.01
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
$ 0.03
$ 0.00
Monitoring -
TC
$
$
$ 1.73
$ 1.65
$ 1.60
$ 1.55
$ 1.51
$ 1.47
$ 1.42
$ 1.38
$ 1.34
$ 1.30
$ 1.29
$ 1.23
$ 1.19
$ 1.16
$ 1.12
$ 1.09
$ 1.06
$ 1.03
$ 1.00
$ 0.97
$ 0.94
$ 0.91
$ 0.89
$ 28.83
$ 1.66
Monitoring -
Disinfectant
Residual
-
$
$ 0.51
$ 0.50
$ 0.48
$ 0.47
$ 0.46
$ 0.44
$ 0.43
$ 0.42
$ 0.41
$ 0.39
$ 0.38
$ 0.37
$ 0.36
$ 0.35
$ 0.34
$ 0.33
$ 0.32
$ 0.31
$ 0.30
$ 0.29
$ 0.28
$ 0.28
$ 0.27
$ 8.71
$ 0.50
Turbidity
Monitoring
-
$
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
$
$
$
$
$
$
$
$
$
$
Nitrate/
Nitrite
Monitoring
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
$
$
O&M
Plan
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
Routine
Disinfection &
Flushing
$
$
$ 3.96
$ 3.84
$ 3.73
$ 3.62
$ 3.52
$ 3.42
$ 3.32
$ 3.22
$ 3.13
$ 3.03
$ 2.95
$ 2.86
$ 2.78
$ 2.70
$ 2.62
$ 2.54
$ 2.47
$ 2.40
$ 2.33
$ 2.26
$ 2.19
$ 2.13
$ 2.07
$ 67.06
$ 3.85
CA
Disinfection &
Flushing
$
$
$ 0.06
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.93
$ 0.05
Sanitary
Survey
-
$
$
$
$
$
$
$
$
-
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Notes:
1) Public notification is not covered under ADWR, but is covered under PNR.
2) Present values in millions of 2008 dollars, discounted to Y1.
3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.
Page C-103
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.13f Present Value of Agency Activity Costs for Alternative 2 at 3 Percent, by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Total PV
Annualized
Implementation
$ 0.07
$ 0.07
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
-
$
$
$ 0.14
$ 0.01
Annual
Administration
$
$
$ 0.24
$ 0.24
$ 0.23
$ 0.22
$ 0.22
$ 0.21
$ 0.20
$ 0.20
$ 0.19
$ 0.19
$ 0.18
$ 0.18
$ 0.17
$ 0.17
$ 0.16
$ 0.16
$ 0.15
$ 0.15
$ 0.14
$ 0.14
$ 0.14
$ 0.13
$ 0.13
$ 4.13
$ 0.24
Monitoring
Plan
$ 0.01
$ 0.01
$
$
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
$
$
$ 0.02
$ 0.00
Monitoring -
TC
$
$
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.21
$ 0.01
Monitoring -
Disinfectant
Residual
-
$
$ 0.17
$ 0.17
$ 0.16
$ 0.16
$ 0.15
$ 0.15
$ 0.15
$ 0.14
$ 0.14
$ 0.13
$ 0.13
$ 0.13
$ 0.12
$ 0.12
$ 0.11
$ 0.11
$ 0.11
$ 0.10
$ 0.10
$ 0.10
$ 0.10
$ 0.09
$ 0.09
$ 2.93
$ 0.17
Turbidity
Monitoring
$
$
$
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
$
$
$
$
Nitrate/Nitrite
Monitoring
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
O&M
Plan
$ -
$ -
$ -
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
$ -
$ -
$ -
$ -
Routine
Disinfection
& Flushing
-
$
$ 0.69
$ 0.67
$ 0.65
$ 0.63
$ 0.62
$ 0.60
$ 0.58
$ 0.56
$ 0.55
$ 0.53
$ 0.52
$ 0.50
$ 0.49
$ 0.47
$ 0.46
$ 0.44
$ 0.43
$ 0.42
$ 0.41
$ 0.39
$ 0.38
$ 0.37
$ 0.36
$ 11.73
$ 0.67
CA
Disinfection
& Flushing
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
-
$
$
$
$
$
Sanitary
Survey
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
-
$ -
$ -
$ -
$ -
$ -
Notes:
1) Public notification is not covered under ADWR, but is covered
2) Present values in millions of 2008 dollars, discounted to Y1.
3) Assume refrigerators are purchased two times (in years 3 and
under PNR.
13) in the 25-year evaluation period.
Page C-104
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.13g Present Value of Rule Activity Costs for Alternative 3 at 3 Percent, by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Total PV
Annual!
zed
Implement
ation
$ 0.09
$ 0.09
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
$ 0.18
$ 0.01
Annual
Administration
-
$
$ 0.24
$ 0.24
$ 0.23
$ 0.22
$ 0.22
$ 0.21
$ 0.20
$ 0.20
$ 0.19
$ 0.19
$ 0.18
$ 0.18
$ 0.17
$ 0.17
$ 0.16
$ 0.16
$ 0.15
$ 0.15
$ 0.14
$ 0.14
$ 0.14
$ 0.13
$ 0.13
$ 4.13
$ 0.24
Monitoring
Plan
$ 0.01
$ 0.01
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$ 0.02
$ 0.00
Monitoring -
TC
$
$
$ 2.33
$ 2.22
$ 2.16
$ 2.10
$ 2.04
$ 1.98
$ 1.92
$ 1.86
$ 1.81
$ 1.76
$ 1.73
$ 1.66
$ 1.61
$ 1.56
$ 1.52
$ 1.47
$ 1.43
$ 1.39
$ 1.35
$ 1.31
$ 1.27
$ 1.23
$ 1.20
$ 38.88
$ 2.23
Monitoring -
Disinfectant
Residual
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Turbidity
Monitoring
$
$
$ 13.32
$ 12.89
$ 12.51
$ 12.15
$ 11.79
$ 11.49
$ 11.12
$ 10.79
$ 10.48
$ 10.17
$ 9.91
$ 9.59
$ 9.31
$ 9.04
$ 8.77
$ 8.55
$ 8.27
$ 8.03
$ 7.80
$ 7.57
$ 7.38
$ 7.13
$ 6.93
$ 224.99
$ 12.92
Nitrate/
Nitrite
Monitoring
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
O&M
Plan
$0.06
$0.06
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
$0.12
$0.01
Routine
Disinfection &
Flushing
-
$
$ 3.06
$ 2.97
$ 2.88
$ 2.80
$ 2.71
$ 2.64
$ 2.56
$ 2.48
$ 2.41
$ 2.34
$ 2.27
$ 2.21
$ 2.14
$ 2.08
$ 2.02
$ 1.96
$ 1.90
$ 1.85
$ 1.79
$ 1.74
$ 1.69
$ 1.64
$ 1.59
$ 51.75
$ 2.97
CA
Disinfection &
Flushing
-
$
$ 0.06
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.93
$ 0.05
Sanitary
Survey
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$ -
$
Notes:
1) Public notification is not covered under ADWR, but is covered
2) Present values in millions of 2008 dollars, discounted to Y1.
3) Assume refrigerators are purchased two times (in years 3 and
under PNR.
13) in the 25-year evaluation period.
Page C-105
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.13h Present Value of Air Carrier Activity Costs for Alternative 3 at 3 Percent, by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Total P\
Annual
ized
Implement
ation
$ 0.02
$ 0.02
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
$ 0.04
$ 0.00
Annual
Administration
-
$
$
$
-
$
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
$
$
Monitoring
Plan
$ 0.01
$ 0.01
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$ 0.01
$ 0.00
Monitoring -
TC
$
$
$ 2.31
$ 2.21
$ 2.15
$ 2.09
$ 2.03
$ 1.97
$ 1.91
$ 1.85
$ 1.80
$ 1.75
$ 1.72
$ 1.65
$ 1.60
$ 1.55
$ 1.51
$ 1.46
$ 1.42
$ 1.38
$ 1.34
$ 1.30
$ 1.26
$ 1.23
$ 1.19
$ 38.66
$ 2.22
Monitoring -
Disinfectant
Residual
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Turbidity
Monitoring
$
$
$ 12.28
$ 11.88
$ 11.53
$ 11.20
$ 10.87
$ 10.60
$ 10.25
$ 9.95
$ 9.66
$ 9.38
$ 9.14
$ 8.84
$ 8.58
$ 8.33
$ 8.09
$ 7.88
$ 7.62
$ 7.40
$ 7.19
$ 6.98
$ 6.80
$ 6.58
$ 6.38
$ 207.39
$ 11.91
Nitrate/
Nitrite
Monitoring
$
$
$
$
-
-
$
$
$
-
$
$
$
-
$
$
$
$
$
$
$
$
$
$
$
$
$
O&M
Plan
$ 0.05
$ 0.05
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ 0.11
$ 0.01
Routine
Disinfection &
Flushing
-
$
$ 3.06
$ 2.97
$ 2.88
$ 2.80
$ 2.71
$ 2.64
$ 2.56
$ 2.48
$ 2.41
$ 2.34
$ 2.27
$ 2.21
$ 2.14
$ 2.08
$ 2.02
$ 1.96
$ 1.90
$ 1.85
$ 1.79
$ 1.74
$ 1.69
$ 1.64
$ 1.59
$ 51.75
$ 2.97
CA Disinfection
& Flushing
$
$
$ 0.06
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.05
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.93
$ 0.05
Sanitary
Survey
$ -
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$ -
$ -
Notes:
1) Public notification is not covered under ADWR, but is covered under PNR.
2) Present values in millions of 2008 dollars, discounted to Y1.
3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.
Page C-106
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.13i Present Value of Agency Activity Costs for Alternative 3 at 3 Percent, by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Total PV
Annual!
zed
Impleme
ntation
$ 0.07
$ 0.07
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
-
$ -
$ -
$ -
$ 0.14
$ 0.01
Annual
Administration
$
$
$ 0.24
$ 0.24
$ 0.23
$ 0.22
$ 0.22
$ 0.21
$ 0.20
$ 0.20
$ 0.19
$ 0.19
$ 0.18
$ 0.18
$ 0.17
$ 0.17
$ 0.16
$ 0.16
$ 0.15
$ 0.15
$ 0.14
$ 0.14
$ 0.14
$ 0.13
$ 0.13
$ 4.13
$ 0.24
Monitoring
Plan
$ 0.00
$ 0.00
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$ 0.01
$ 0.00
Monitoring -
TC
$
$
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.21
$ 0.01
Monitoring -
Disinfectant
Residual
-
$
$
$
-
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
$
$
Turbidity
Monitoring
$
$
$ 1.04
$ 1.01
$ 0.98
$ 0.95
$ 0.92
$ 0.90
$ 0.87
$ 0.84
$ 0.82
$ 0.80
$ 0.77
$ 0.75
$ 0.73
$ 0.71
$ 0.69
$ 0.67
$ 0.65
$ 0.63
$ 0.61
$ 0.59
$ 0.58
$ 0.56
$ 0.54
$ 17.60
$ 1.01
Nitrate/
Nitrite
Monitoring
-
$
$
$
-
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
$
$
O&M
Plan
$0.01
$0.01
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
$0.02
$0.00
Routine
Disinfection
& Flushing
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
$
$
CA
Disinfection
& Flushing
-
$
$
$
-
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
$
$
Sanitary
Survey
-
$ -
$ -
$ -
-
-
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
$ -
$ -
Notes:
1) Public notification is not covered under ADWR, but is covered under PNR.
2) Present values in millions of 2008 dollars, discounted to Y1.
3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.
Page C-107
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.13J Present Value of Rule Activity Costs for Alternative 4 (Final Rule) at 3 Percent, by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Total
PV
Annual!
zed
Implement
ation
$ 0.09
$ 0.09
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$ 0.18
$ 0.01
Annual
Administrat
ion
$
$
$ 0.24
$ 0.24
$ 0.23
$ 0.22
$ 0.22
$ 0.21
$ 0.20
$ 0.20
$ 0.19
$ 0.19
$ 0.18
$ 0.18
$ 0.17
$ 0.17
$ 0.16
$ 0.16
$ 0.15
$ 0.15
$ 0.14
$ 0.14
$ 0.14
$ 0.13
$ 0.13
$ 4.13
$ 0.24
Sampling
Plan
$ 0.02
$ 0.02
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
$ 0.04
$ 0.00
Monitoring -
TC
$
$
$ 5.10
$ 4.92
$ 4.77
$ 4.63
$ 4.50
$ 4.37
$ 4.24
$ 4.12
$ 4.00
$ 3.88
$ 3.79
$ 3.66
$ 3.55
$ 3.45
$ 3.35
$ 3.25
$ 3.16
$ 3.06
$ 2.97
$ 2.89
$ 2.80
$ 2.72
$ 2.64
$ 85.84
$ 4.93
Monitoring -
Disinfectant
Residual
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Turbidity
Monitoring
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Nitrate/
Nitrite
Monitoring
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
O&M
Plan
$ 0.11
$ 0.11
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ 0.21
$ 0.01
Routine
Disinfection &
Flushing
-
$
$ 2.14
$ 2.08
$ 2.02
$ 1.96
$ 1.90
$ 1.85
$ 1.79
$ 1.74
$ 1.69
$ 1.64
$ 1.59
$ 1.55
$ 1.50
$ 1.46
$ 1.41
$ 1.37
$ 1.33
$ 1.29
$ 1.26
$ 1.22
$ 1.18
$ 1.15
$ 1.12
$ 36.23
$ 2.08
CA
Disinfection &
Flushing
$
$
$ 0.05
$ 0.05
$ 0.05
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.81
$ 0.05
Compliance
Audit
$
$
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.37
$ 0.02
Notes:
1) Public notification is not covered under ADWR, but is covered
2) Present values in millions of 2008 dollars, discounted to Y1.
3) Assume refrigerators are purchased two times (in years 3 and
under PNR.
13) in the 25-year evaluation period.
Page C-108
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.13k Present Value of Air Carrier Activity Costs for Alternative 4 (Final Rule) at 3 Percent, by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Total
PV
Annual!
zed
Implement
ation
$ 0.02
$ 0.02
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$ 0.04
$ 0.00
Annual
Administrati
on
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Sampling
Plan
$ 0.01
$ 0.01
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
$ 0.03
$ 0.00
Monitoring -
TC
$
$
$ 5.06
$ 4.88
$ 4.73
$ 4.60
$ 4.46
$ 4.33
$ 4.21
$ 4.08
$ 3.96
$ 3.85
$ 3.76
$ 3.63
$ 3.52
$ 3.42
$ 3.32
$ 3.22
$ 3.13
$ 3.04
$ 2.95
$ 2.86
$ 2.78
$ 2.70
$ 2.62
$ 85.13
$ 4.89
Monitoring -
Disinfectant
Residual
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Turbidity
Monitoring
-
$
$
$
-
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
$
$
Nitrate/
Nitrite
Monitoring
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
O&M
Plan
$ 0.11
$ 0.10
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ 0.21
$ 0.01
Routine
Disinfection &
Flushing
$
$
$ 2.14
$ 2.08
$ 2.02
$ 1.96
$ 1.90
$ 1.85
$ 1.79
$ 1.74
$ 1.69
$ 1.64
$ 1.59
$ 1.55
$ 1.50
$ 1.46
$ 1.41
$ 1.37
$ 1.33
$ 1.29
$ 1.26
$ 1.22
$ 1.18
$ 1.15
$ 1.12
$ 36.23
$ 2.08
CA
Disinfection &
Flushing
$
$
$ 0.05
$ 0.05
$ 0.05
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.81
$ 0.05
Compliance
Audit
$
$
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.21
$ 0.01
Notes:
1) Public notification is not covered under ADWR, but is covered under PNR.
2) Present values in millions of 2008 dollars, discounted to Y1.
3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.
Page C-109
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.13I Present Value of Agency Activity Costs for Alternative 4 (Final Rule) at 3 Percent, by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Total
PV
Annual
ized
Implement
ation
$ 0.07
$ 0.07
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$ 0.14
$ 0.01
Annual
Administrat
ion
$
$
$ 0.24
$ 0.24
$ 0.23
$ 0.22
$ 0.22
$ 0.21
$ 0.20
$ 0.20
$ 0.19
$ 0.19
$ 0.18
$ 0.18
$ 0.17
$ 0.17
$ 0.16
$ 0.16
$ 0.15
$ 0.15
$ 0.14
$ 0.14
$ 0.14
$ 0.13
$ 0.13
$ 4.13
$ 0.24
Sampling
Plan
$ 0.01
$ 0.01
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$ 0.01
$ 0.00
Monitoring -
TC
$
$
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.71
$ 0.04
Monitoring -
Disinfectant
Residual
$
$
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
$
$
Turbidity
Monitoring
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
-
$
$
$
$
$
Nitrate/ Nitrite
Monitoring
$
$
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
$
$
O&M
Plan
$0.00
$0.00
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
-
$ -
$ -
$ -
$0.00
$0.00
Routine
Disinfection &
Flushing
$
$
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
$
$
CA Disinfection
& Flushing
-
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Compliance
Audit
$
$
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.00
$ 0.16
$ 0.01
Notes:
1) Public notification is not covered under ADWR, but is covered
2) Present values in millions of 2008 dollars, discounted to Y1.
3) Assume refrigerators are purchased two times (in years 3 and
under PNR.
13) in the 25-year evaluation period.
PageC-110
-------
C.14 Present Value Costs at 7 Percent
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.14a Present Value of Rule Activity Costs for Alternative 1 at 7 Percent, by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Total
PV
Annual!
zed
Implementa
tion
$ 0.09
$ 0.09
$
$
$
$
-
-
$
$
$
-
$
$
$
-
$
$
$
$
$
$
$
$
$
$ 0.18
$ 0.02
Annual
Administra
tion
$
$
$ 0.23
$ 0.21
$ 0.20
$ 0.18
$ 0.17
$ 0.16
$ 0.15
$ 0.14
$ 0.13
$ 0.12
$ 0.11
$ 0.11
$ 0.10
$ 0.09
$ 0.09
$ 0.08
$ 0.08
$ 0.07
$ 0.07
$ 0.06
$ 0.06
$ 0.05
$ 0.05
$ 2.73
$ 0.23
Monitoring
Plan
$ 0.02
$ 0.02
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$ 0.04
$ 0.00
Monitoring -
TC
$
$
$ 24.20
$ 22.59
$ 21.11
$ 19.73
$ 18.44
$ 17.23
$ 16.11
$ 15.05
$ 14.07
$ 13.15
$ 12.30
$ 11.48
$ 10.73
$ 10.03
$ 9.37
$ 8.76
$ 8.19
$ 7.65
$ 7.15
$ 6.68
$ 6.25
$ 5.84
$ 5.46
$ 291.57
$ 25.02
Monitoring -
Disinfectant
Residual
$
$
$ 3.02
$ 2.82
$ 2.64
$ 2.47
$ 2.30
$ 2.15
$ 2.01
$ 1.88
$ 1.76
$ 1.64
$ 1.54
$ 1.43
$ 1.34
$ 1.25
$ 1.17
$ 1.09
$ 1.02
$ 0.96
$ 0.89
$ 0.84
$ 0.78
$ 0.73
$ 0.68
$ 36.42
$ 3.13
Turbidity
Monitoring
$
$
$
$
$
$
$
$
$
$
$
-
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
Nitrate/ Nitrite
Monitoring
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
O&M
Plan
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
-
$ -
$ -
$ -
$ -
$ -
$ -
$ -
-
$ -
$ -
$ -
$ -
$ -
$ -
$ -
Routine
Disinfection &
Flushing
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
CA
Disinfection &
Flushing
$
$
$
$
$
$
$
$
$
$
$
-
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
Sanitary
Survey
$
$
$ 0.66
$ 0.62
$ 0.58
$ 0.54
$ 0.51
$ 0.47
$ 0.44
$ 0.41
$ 0.39
$ 0.36
$ 0.34
$ 0.31
$ 0.29
$ 0.28
$ 0.26
$ 0.24
$ 0.22
$ 0.21
$ 0.20
$ 0.18
$ 0.17
$ 0.16
$ 0.15
$ 7.99
$ 0.69
Notes:
1) Public notification is not covered under ADWR, but is covered
2) Present values in millions of 2008 dollars, discounted to Y1.
3) Assume refrigerators are purchased two times (in years 3 and
under PNR.
13) in the 25-year evaluation period.
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.14b Present Value of Air Carrier Activity Costs for Alternative 1 at 7 Percent, by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Total
PV
Annual!
zed
Implement
ation
$ 0.02
$ 0.02
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$ 0.04
$ 0.00
Annual
Administrat
ion
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Monitoring
Plan
$ 0.01
$ 0.01
$
$
$
$
-
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$ 0.03
$ 0.00
Monitoring -
TC
$
$
$ 23.91
$ 22.32
$ 20.86
$ 19.49
$ 18.22
$ 17.03
$ 15.91
$ 14.87
$ 13.90
$ 12.99
$ 12.16
$ 11.35
$ 10.60
$ 9.91
$ 9.26
$ 8.66
$ 8.09
$ 7.56
$ 7.07
$ 6.60
$ 6.17
$ 5.77
$ 5.39
$ 288.09
$ 24.72
Monitoring -
Disinfectant
Residual
$
$
$ 2.86
$ 2.67
$ 2.50
$ 2.33
$ 2.18
$ 2.04
$ 1.91
$ 1.78
$ 1.66
$ 1.56
$ 1.45
$ 1.36
$ 1.27
$ 1.19
$ 1.11
$ 1.04
$ 0.97
$ 0.91
$ 0.85
$ 0.79
$ 0.74
$ 0.69
$ 0.65
$ 34.49
$ 2.96
Turbidity
Monitoring
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Nitrate/ Nitrite
Monitoring
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
O&M
Plan
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
Routine
Disinfection &
Flushing
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
CA
Disinfection &
Flushing
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
Sanitary
Survey
$ -
$ -
$ 0.03
$ 0.03
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.33
$ 0.03
Notes:
1) Public notification is not covered under ADWR, but is covered under PNR.
2) Present values in millions of 2008 dollars, discounted to Y1.
3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.
PageC-113
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.14c Present Value of Agency Activity Costs for Alternative 1 at 7 Percent, by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Total
PV
Annual
ized
Implement
ation
$ 0.07
$ 0.07
$
$
$
$
-
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$ 0.14
$ 0.01
Annual
Administra
tion
$
$
$ 0.23
$ 0.21
$ 0.20
$ 0.18
$ 0.17
$ 0.16
$ 0.15
$ 0.14
$ 0.13
$ 0.12
$ 0.11
$ 0.11
$ 0.10
$ 0.09
$ 0.09
$ 0.08
$ 0.08
$ 0.07
$ 0.07
$ 0.06
$ 0.06
$ 0.05
$ 0.05
$ 2.73
$ 0.23
Monitoring
Plan
$ 0.01
$ 0.01
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$ 0.02
$ 0.00
Monitoring -
TC
$
$
$ 0.29
$ 0.27
$ 0.25
$ 0.24
$ 0.22
$ 0.21
$ 0.19
$ 0.18
$ 0.17
$ 0.16
$ 0.15
$ 0.14
$ 0.13
$ 0.12
$ 0.11
$ 0.10
$ 0.10
$ 0.09
$ 0.09
$ 0.08
$ 0.07
$ 0.07
$ 0.07
$ 3.48
$ 0.30
Monitoring -
Disinfectant
Residual
$
$
$ 0.16
$ 0.15
$ 0.14
$ 0.13
$ 0.12
$ 0.11
$ 0.11
$ 0.10
$ 0.09
$ 0.09
$ 0.08
$ 0.08
$ 0.07
$ 0.07
$ 0.06
$ 0.06
$ 0.05
$ 0.05
$ 0.05
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 1.94
$ 0.17
Turbidity
Monitoring
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Nitrate/
Nitrite
Monitoring
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
O&M
Plan
$ -
$ -
$ -
$ -
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
Routine
Disinfection &
Flushing
$
$
$
$
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
CA Disinfection
& Flushing
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Sanitary
Survey
$
$
$ 0.64
$ 0.59
$ 0.55
$ 0.52
$ 0.48
$ 0.45
$ 0.42
$ 0.40
$ 0.37
$ 0.35
$ 0.32
$ 0.30
$ 0.28
$ 0.26
$ 0.25
$ 0.23
$ 0.22
$ 0.20
$ 0.19
$ 0.18
$ 0.16
$ 0.15
$ 0.14
$ 7.66
$ 0.66
Notes:
1) Public notification is not covered under ADWR, but is covered
2) Present values in millions of 2008 dollars, discounted to Y1.
3) Assume refrigerators are purchased two times (in years 3 and
under PNR.
13) in the 25-year evaluation period.
PageC-114
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.14d Present Value of Rule Activity Costs for Alternative 2 at 7 Percent, by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Total
PV
Annual
ized
Implemen
tation
$ 0.09
$ 0.09
$
$
$
$
$
$
$
$
$
-
$
$
$
$
$
$
$
-
$
$
$
-
$
$ 0.18
$ 0.02
Annual
Administrati
on
$
$
$ 0.23
$ 0.21
$ 0.20
$ 0.18
$ 0.17
$ 0.16
$ 0.15
$ 0.14
$ 0.13
$ 0.12
$ 0.11
$ 0.11
$ 0.10
$ 0.09
$ 0.09
$ 0.08
$ 0.08
$ 0.07
$ 0.07
$ 0.06
$ 0.06
$ 0.05
$ 0.05
$ 2.73
$ 0.23
Monitoring
Plan
$ 0.02
$ 0.02
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$ 0.04
$ 0.00
Monitoring -
TC
$
$
$ 1.62
$ 1.48
$ 1.39
$ 1.29
$ 1.21
$ 1.13
$ 1.06
$ 0.99
$ 0.92
$ 0.86
$ 0.82
$ 0.75
$ 0.70
$ 0.66
$ 0.61
$ 0.57
$ 0.54
$ 0.50
$ 0.47
$ 0.44
$ 0.41
$ 0.38
$ 0.36
$ 19.18
$ 1.65
Monitoring -
Disinfectant
Residual
$
$
$ 0.64
$ 0.60
$ 0.56
$ 0.52
$ 0.49
$ 0.45
$ 0.42
$ 0.40
$ 0.37
$ 0.35
$ 0.32
$ 0.30
$ 0.28
$ 0.26
$ 0.25
$ 0.23
$ 0.22
$ 0.20
$ 0.19
$ 0.18
$ 0.16
$ 0.15
$ 0.14
$ 7.68
$ 0.66
Turbidity
Monitoring
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Nitrate/ Nitrite
Monitoring
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
O&M
Plan
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
Routine
Disinfection &
Flushing
$
$
$ 4.31
$ 4.03
$ 3.76
$ 3.52
$ 3.29
$ 3.07
$ 2.87
$ 2.68
$ 2.51
$ 2.34
$ 2.19
$ 2.05
$ 1.91
$ 1.79
$ 1.67
$ 1.56
$ 1.46
$ 1.36
$ 1.28
$ 1.19
$ 1.11
$ 1.04
$ 0.97
$ 51.99
$ 4.46
CA
Disinfection &
Flushing
$
$
$ 0.05
$ 0.05
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.61
$ 0.05
Sanitary
Survey
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
Notes:
1) Public notification is not covered under ADWR, but is covered under PNR.
2) Present values in millions of 2008 dollars, discounted to Y1.
3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.
PageC-115
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.14e Present Value of Air Carrier Activity Costs for Alternative 2 at 7 Percent, by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Total
PV
Annua
lized
Implementa
tion
$ 0.02
$ 0.02
$
$
$
$
$
$
$
$
$
-
$
$
$
$
$
$
$
$
$
$
$
$
$
$ 0.04
$ 0.00
Annual
Administration
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
Monitoring
Plan
$ 0.01
$ 0.01
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$ 0.03
$ 0.00
Monitoring -
TC
$
$
$ 1.61
$ 1.47
$ 1.37
$ 1.28
$ 1.20
$ 1.12
$ 1.05
$ 0.98
$ 0.92
$ 0.86
$ 0.82
$ 0.75
$ 0.70
$ 0.65
$ 0.61
$ 0.57
$ 0.53
$ 0.50
$ 0.47
$ 0.44
$ 0.41
$ 0.38
$ 0.36
$ 19.04
$ 1.63
Monitoring -
Disinfectant
Residual
$
$
$ 0.48
$ 0.45
$ 0.42
$ 0.39
$ 0.36
$ 0.34
$ 0.32
$ 0.30
$ 0.28
$ 0.26
$ 0.24
$ 0.23
$ 0.21
$ 0.20
$ 0.18
$ 0.17
$ 0.16
$ 0.15
$ 0.14
$ 0.13
$ 0.12
$ 0.12
$ 0.11
$ 5.75
$ 0.49
Turbidity
Monitoring
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Nitrate/
Nitrite
Monitoring
$
$
$
$
$
$
$
$
$
$
$
-
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
O&M
Plan
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
-
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
Routine
Disinfection &
Flushing
$
$
$ 3.67
$ 3.43
$ 3.20
$ 2.99
$ 2.80
$ 2.62
$ 2.44
$ 2.28
$ 2.14
$ 2.00
$ 1.86
$ 1.74
$ 1.63
$ 1.52
$ 1.42
$ 1.33
$ 1.24
$ 1.16
$ 1.09
$ 1.01
$ 0.95
$ 0.89
$ 0.83
$ 44.25
$ 3.80
CA Disinfection
& Flushing
$
$
$ 0.05
$ 0.05
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.61
$ 0.05
Sanitary
Survey
$ -
$ -
$ -
$ -
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
Notes:
1) Public notification is not covered under ADWR, but is covered under PNR.
2) Present values in millions of 2008 dollars, discounted to Y1.
3) Assume refrigerators are purchased two times (in years 3 and 13") in the 25-year evaluation period.
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.14f Present Value of Agency Activity Costs for Alternative 2 at 7 Percent, by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Total
PV
Annua
lized
Implementa
tion
$ 0.07
$ 0.07
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
-
$
$ 0.14
$ 0.01
Annual
Administration
$
$
$ 0.23
$ 0.21
$ 0.20
$ 0.18
$ 0.17
$ 0.16
$ 0.15
$ 0.14
$ 0.13
$ 0.12
$ 0.11
$ 0.11
$ 0.10
$ 0.09
$ 0.09
$ 0.08
$ 0.08
$ 0.07
$ 0.07
$ 0.06
$ 0.06
$ 0.05
$ 0.05
$ 2.73
$ 0.23
Monitoring
Plan
$ 0.01
$ 0.01
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
-
$
$ 0.02
$ 0.00
Monitoring -
TC
$
$
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.14
$ 0.01
Monitoring -
Disinfectant
Residual
$
$
$ 0.16
$ 0.15
$ 0.14
$ 0.13
$ 0.12
$ 0.11
$ 0.11
$ 0.10
$ 0.09
$ 0.09
$ 0.08
$ 0.08
$ 0.07
$ 0.07
$ 0.06
$ 0.06
$ 0.05
$ 0.05
$ 0.05
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 1.94
$ 0.17
Turbidity
Monitoring
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
-
$
$
$
Nitrate/
Nitrite
Monitoring
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
-
$
$
$
O&M
Plan
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
-
$ -
$ -
$ -
Routine
Disinfection &
Flushing
$
$
$ 0.64
$ 0.60
$ 0.56
$ 0.52
$ 0.49
$ 0.46
$ 0.43
$ 0.40
$ 0.37
$ 0.35
$ 0.33
$ 0.30
$ 0.28
$ 0.27
$ 0.25
$ 0.23
$ 0.22
$ 0.20
$ 0.19
$ 0.18
$ 0.17
$ 0.16
$ 0.14
$ 7.74
$ 0.66
CA Disinfection &
Flushing
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
-
$
$
$
Sanitary
Survey
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
-
$
$
$
Notes:
1) Public notification is not covered under ADWR, but is covered under PNR.
2) Present values in millions of 2008 dollars, discounted to Y1.
3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.
PageC-117
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.14g Present Value of Rule Activity Costs for Alternative 3 at 7 Percent, by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Total
PV
Annua
lized
Implement
ation
$ 0.09
$ 0.09
$
$
$
$
-
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$ 0.18
$ 0.02
Annual
Ad minis
tration
$ -
$ -
$ 0.23
$ 0.21
$ 0.20
$ 0.18
$ 0.17
$ 0.16
$ 0.15
$ 0.14
$ 0.13
$ 0.12
$ 0.11
$ 0.11
$ 0.10
$ 0.09
$ 0.09
$ 0.08
$ 0.08
$ 0.07
$ 0.07
$ 0.06
$ 0.06
$ 0.05
$ 0.05
$ 2.73
$ 0.23
Monitoring
Plan
$ 0.01
$ 0.01
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$ 0.02
$ 0.00
Monitoring -
TC
$
$
$ 2.16
$ 1.98
$ 1.85
$ 1.73
$ 1.62
$ 1.51
$ 1.41
$ 1.32
$ 1.24
$ 1.16
$ 1.10
$ 1.01
$ 0.94
$ 0.88
$ 0.82
$ 0.77
$ 0.72
$ 0.67
$ 0.63
$ 0.59
$ 0.55
$ 0.51
$ 0.48
$ 25.66
$ 2.20
Monitoring -
Disinfectant
Residual
$
$
$
$
$
$
-
-
$
$
$
-
$
$
$
$
$
$
$
-
$
$
$
$
$
$
$
Turbidity
Monitoring
$
$
$ 12.35
$ 11.49
$ 10.74
$ 10.04
$ 9.38
$ 8.80
$ 8.20
$ 7.66
$ 7.16
$ 6.69
$ 6.28
$ 5.84
$ 5.46
$ 5.10
$ 4.77
$ 4.47
$ 4.17
$ 3.89
$ 3.64
$ 3.40
$ 3.19
$ 2.97
$ 2.78
$ 148.47
$ 12.74
Nitrate/
Nitrite
Monitoring
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
O&M
Plan
$0.06
$0.06
$ -
$ -
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
$ -
$ -
$ -
$ -
-
$ -
$ -
$ -
$ -
$ -
$0.12
$0.01
Routine
Disinfection
& Flushing
$
$
$ 2.83
$ 2.65
$ 2.47
$ 2.31
$ 2.16
$ 2.02
$ 1.89
$ 1.76
$ 1.65
$ 1.54
$ 1.44
$ 1.35
$ 1.26
$ 1.17
$ 1.10
$ 1.03
$ 0.96
$ 0.90
$ 0.84
$ 0.78
$ 0.73
$ 0.68
$ 0.64
$ 34.15
$ 2.93
CA Disinfection
& Flushing
$
$
$ 0.05
$ 0.05
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.61
$ 0.05
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
Notes:
1) Public notification is not covered under ADWR, but is covered under PNR.
2) Present values in millions of 2008 dollars, discounted to Y1.
3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.
PageC-118
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.14h Present Value of Air Carrier Activity Costs for Alternative 3 at 7 Percent, by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Total
PV
Annua
lized
Implementa
tion
$ 0.02
$ 0.02
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$ 0.04
$ 0.00
Annual
Administra
tion
$
$
$
$
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
Monitoring
Plan
$ 0.01
$ 0.01
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$ 0.01
$ 0.00
Monitoring -
TC
$
$
$ 2.14
$ 1.97
$ 1.84
$ 1.72
$ 1.61
$ 1.51
$ 1.41
$ 1.32
$ 1.23
$ 1.15
$ 1.09
$ 1.00
$ 0.94
$ 0.88
$ 0.82
$ 0.77
$ 0.72
$ 0.67
$ 0.62
$ 0.58
$ 0.55
$ 0.51
$ 0.48
$ 25.52
$ 2.19
Monitoring -
Disinfectant
Residual
$
$
$
$
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
Turbidity
Monitoring
$
$
$ 11.38
$ 10.59
$ 9.90
$ 9.25
$ 8.65
$ 8.12
$ 7.55
$ 7.06
$ 6.60
$ 6.17
$ 5.79
$ 5.39
$ 5.03
$ 4.70
$ 4.40
$ 4.13
$ 3.84
$ 3.59
$ 3.35
$ 3.13
$ 2.94
$ 2.74
$ 2.56
$ 136.86
$ 11.74
Nitrate/Nitrite
Monitoring
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
O&M
Plan
$0.05
$0.05
$ -
$ -
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$0.10
$0.01
Routine
Disinfection &
Flushing
$
$
$ 2.83
$ 2.65
$ 2.47
$ 2.31
$ 2.16
$ 2.02
$ 1.89
$ 1.76
$ 1.65
$ 1.54
$ 1.44
$ 1.35
$ 1.26
$ 1.17
$ 1.10
$ 1.03
$ 0.96
$ 0.90
$ 0.84
$ 0.78
$ 0.73
$ 0.68
$ 0.64
$ 34.15
$ 2.93
CA Disinfection
& Flushing
$
$
$ 0.05
$ 0.05
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.61
$ 0.05
Sanitary
Survey
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Notes:
1) Public notification is not covered under ADWR, but is covered under PNR.
2) Present values in millions of 2008 dollars, discounted to Y1.
3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.
PageC-119
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.14i Present Value of Agency Activity Costs for Alternative 3 at 7 Percent, by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Total
PV
Annua
lized
Implementa
tion
$ 0.07
$ 0.07
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
$ 0.14
$ 0.01
Annual
Administra
tion
$
$
$ 0.23
$ 0.21
$ 0.20
$ 0.18
$ 0.17
$ 0.16
$ 0.15
$ 0.14
$ 0.13
$ 0.12
$ 0.11
$ 0.11
$ 0.10
$ 0.09
$ 0.09
$ 0.08
$ 0.08
$ 0.07
$ 0.07
$ 0.06
$ 0.06
$ 0.05
$ 0.05
$ 2.73
$ 0.23
Monitoring
Plan
$ 0.00
$ 0.00
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
$
$
$
$
$
$
$
$
$ 0.01
$ 0.00
Monitoring -
TC
$
$
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.14
$ 0.01
Monitoring -
Disinfectant
Residual
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
-
$
$
$
$
$
Turbidity
Monitoring
-
$
$ 0.96
$ 0.90
$ 0.84
$ 0.79
$ 0.73
$ 0.69
$ 0.64
$ 0.60
$ 0.56
$ 0.52
$ 0.49
$ 0.46
$ 0.43
$ 0.40
$ 0.37
$ 0.35
$ 0.33
$ 0.30
$ 0.28
$ 0.27
$ 0.25
$ 0.23
$ 0.22
$ 11.61
$ 1.00
Nitrate/Nitrite
Monitoring
-
$
$
$
-
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
$
$
O&M
Plan
$0.01
$0.01
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
$0.02
$0.00
Routine
Disinfection &
Flushing
-
$
$
$
-
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
$
$
CA Disinfection
& Flushing
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Sanitary
Survey
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
$
$
Notes:
1) Public notification is not covered under ADWR, but is covered under PNR.
2) Present values in millions of 2008 dollars, discounted to Y1.
3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.
Page C-120
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.14J Present Value of Rule Activity Costs for Alternative 4 (Final Rule) at 7 Percent, by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Total
PV
Annua
lized
Implementa
tion
$ 0.09
$ 0.09
$
$
$
$
$
$
$
$
$
-
$
$
$
$
$
$
$
$
$
$
$
$
$
$ 0.18
$ 0.02
Annual
Administra
tion
$
$
$ 0.23
$ 0.21
$ 0.20
$ 0.18
$ 0.17
$ 0.16
$ 0.15
$ 0.14
$ 0.13
$ 0.12
$ 0.11
$ 0.11
$ 0.10
$ 0.09
$ 0.09
$ 0.08
$ 0.08
$ 0.07
$ 0.07
$ 0.06
$ 0.06
$ 0.05
$ 0.05
$ 2.73
$ 0.23
Sampling
Plan
$ 0.02
$ 0.02
$
$
$
$
-
-
$
$
$
-
$
$
$
$
$
$
$
$
$
$
$
$
$
$ 0.04
$ 0.00
Monitoring -
TC
$
$
$ 4.73
$ 4.39
$ 4.10
$ 3.83
$ 3.58
$ 3.35
$ 3.13
$ 2.92
$ 2.73
$ 2.55
$ 2.40
$ 2.23
$ 2.08
$ 1.95
$ 1.82
$ 1.70
$ 1.59
$ 1.49
$ 1.39
$ 1.30
$ 1.21
$ 1.13
$ 1.06
$ 56.65
$ 4.86
Monitoring -
Disinfectant
Residual
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
-
$
$
$
$
$
$
$
Turbidity
Monitoring
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
$
$
$
$
$
$
$
$
-
$
$
$
Nitrate/
Nitrite
Monitoring
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
O&M
Plan
$0.11
$0.10
$ -
$ -
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$0.21
$0.02
Routine
Disinfection &
Flushing
$
$
$ 1.98
$ 1.85
$ 1.73
$ 1.62
$ 1.51
$ 1.41
$ 1.32
$ 1.23
$ 1.15
$ 1.08
$ 1.01
$ 0.94
$ 0.88
$ 0.82
$ 0.77
$ 0.72
$ 0.67
$ 0.63
$ 0.59
$ 0.55
$ 0.51
$ 0.48
$ 0.45
$ 23.91
$ 2.05
CA Disinfection
& Flushing
$
$
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.54
$ 0.05
Compliance
Audit
$
$
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.00
$ 0.00
$ 0.24
$ 0.02
Notes:
1) Public notification is not covered under ADWR, but is covered under PNR.
2) Present values in millions of 2008 dollars, discounted to Y1.
3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.
Page C-121
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.14k Present Value of Air Carrier Activity Costs for Alternative 4 (Final Rule) at 7 Percent, by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Total
PV
Annua
lized
Implementa
tion
$ 0.02
$ 0.02
$
$
$
$
-
-
$
$
$
-
$
$
$
$
$
$
$
$
$
$
$
$
$
$ 0.04
$ 0.00
Annual
Administra
tion
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Sampling
Plan
$ 0.01
$ 0.01
$
$
$
$
-
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$ 0.03
$ 0.00
Monitoring -
TC
$
$
$ 4.69
$ 4.35
$ 4.06
$ 3.80
$ 3.55
$ 3.32
$ 3.10
$ 2.90
$ 2.71
$ 2.53
$ 2.38
$ 2.21
$ 2.07
$ 1.93
$ 1.80
$ 1.69
$ 1.58
$ 1.47
$ 1.38
$ 1.29
$ 1.20
$ 1.12
$ 1.05
$ 56.18
$ 4.82
Monitoring -
Disinfectant
Residual
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
Turbidity
Monitoring
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
Nitrate/Nitrite
Monitoring
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
O&M
Plan
$0.11
$0.10
$ -
$ -
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$0.21
$0.02
Routine
Disinfection &
Flushing
$
$
$ 1.98
$ 1.85
$ 1.73
$ 1.62
$ 1.51
$ 1.41
$ 1.32
$ 1.23
$ 1.15
$ 1.08
$ 1.01
$ 0.94
$ 0.88
$ 0.82
$ 0.77
$ 0.72
$ 0.67
$ 0.63
$ 0.59
$ 0.55
$ 0.51
$ 0.48
$ 0.45
$ 23.91
$ 2.05
CA Disinfection
& Flushing
$
$
$ 0.04
$ 0.04
$ 0.04
$ 0.04
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.54
$ 0.05
Compliance
Audit
$
$
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.14
$ 0.01
Notes:
1) Public notification is not covered under ADWR, but is covered under PNR.
2) Present values in millions of 2008 dollars, discounted to Y1.
3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.
Page C-122
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.14I Present Value of Agency Activity Costs for Alternative 4 (Final Rule) at 7 Percent, by Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Total
PV
Annua
lized
Implementa
tion
$ 0.07
$ 0.07
$
$
$
$
-
-
$
$
$
-
$
$
$
$
$
$
$
$
$
$
$
$
$
$ 0.14
$ 0.01
Annual
Administra
tion
$
$
$ 0.23
$ 0.21
$ 0.20
$ 0.18
$ 0.17
$ 0.16
$ 0.15
$ 0.14
$ 0.13
$ 0.12
$ 0.11
$ 0.11
$ 0.10
$ 0.09
$ 0.09
$ 0.08
$ 0.08
$ 0.07
$ 0.07
$ 0.06
$ 0.06
$ 0.05
$ 0.05
$ 2.73
$ 0.23
Sampling
Plan
$ 0.01
$ 0.01
$
$
$
$
-
-
$
$
$
-
$
$
$
$
$
$
$
$
$
$
$
$
$
$ 0.01
$ 0.00
Monitoring -
TC
$
$
$ 0.04
$ 0.04
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.03
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.02
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.47
$ 0.04
Monitoring -
Disinfectant
Residual
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
Turbidity
Monitoring
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
Nitrate/Nitrite
Monitoring
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
O&M
Plan
$0.00
$0.00
$ -
$ -
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$ -
$ -
-
$ -
$0.00
$0.00
Routine
Disinfection &
Flushing
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
-
$
$
$
CA Disinfection
& Flushing
$
$
$
$
$
$
$
-
$
$
$
-
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Compliance
Audit
$
$
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.11
$ 0.01
Notes:
1) Public notification is not covered under ADWR, but is covered under PNR.
2) Present values in millions of 2008 dollars, discounted to Y1.
3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.
Page C-123
-------
C.15 Summary
Page C-124
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.15a Summary of Rule Costs (Millions of 2008$)
Summary of Implementation and Annual Administration Costs (Millions of 2008$)
Implementation
Annual Administration
Total
AIM
Alt 2
Alt3
Alt 4
3%
0.01
0.24
0.25
0.01
0.24
0.25
0.01
0.24
0.25
0.01
0.24
0.25
AIM
Alt 2
Alt3
Alt 4
7%
0.02
0.23
0.25
0.02
0.23
0.25
0.02
0.23
0.25
0.02
0.23
0.25
Summary of Annualized Monitoring Plan Costs (Millions of 2008$)
Monitoring Plan
Total
AIM
Alt 2
Alt3
Alt 4
3%
0.002
0.002
0.002
0.002
0.001
0.001
0.002
0.002
AIM
Alt 2
AltS
Alt 4
7%
0.004
0.004
0.004
0.004
0.002
0.002
0.003
0.003
Summary of Annualized Monitoring Costs (Millions of 2008$)
Coliform Monitoring
Total
AIM
Alt 2
AltS
Alt 4
3%
25.37
25.37
1.67
1.67
2.23
2.23
4.93
4.93
AIM
Alt 2
AltS
Alt 4
7%
25.02
25.02
1.65
1.65
2.20
2.20
4.86
4.86
Summary of Annualized Monitoring Costs (Millions of 2008$)
Disinfectant Residual
Monitoring
Total
AIM
Alt 2
AltS
Alt 4
3%
3.17
3.17
0.67
0.67
_
-
_
-
AIM
Alt 2
AltS
Alt 4
7%
3.13
3.13
0.66
0.66
_
-
_
-
Summary of Annualized Turbidity Monitoring Costs (Millions of 2008$)
Turbidity Monitoring
Total
AIM
Alt 2
AltS
Alt 4
3%
-
-
-
-
12.92
12.92
-
-
AIM
Alt 2
AltS
Alt 4
7%
-
-
-
-
12.74
12.74
-
-
Summary of Annualized Nitrate/Nitrite Monitoring Costs (Millions of 2008$)
Nitrate/Nitrite Monitoring
Total
AIM
Alt 2
AltS
Alt 4
3%
-
-
-
-
-
-
-
-
AIM
Alt 2
AltS
Alt 4
7%
-
-
-
-
-
-
-
-
Summary of Annualized O&M Plan Costs (Millions of 2008$)
O&M Plan
Total
AIM
Alt 2
AltS
Alt 4
3%
-
-
-
-
0.01
0.01
0.01
0.01
AIM
Alt 2
AltS
Alt 4
7%
-
-
-
-
0.01
0.01
0.02
0.02
Page C-125
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.15a Summary of Rule Costs (Millions of 2008$)
Summary of Annualized Disinfection and Flushing Costs (Millions of 2008$)
Routine Disinfection and
Flushing
Total
AIM
Alt 2
Alt3
Alt 4
3%
_
-
4.52
4.52
2.97
2.97
2.08
2.08
AIM
Alt 2
Alt3
Alt 4
7%
_
-
4.46
4.46
2.93
2.93
2.05
2.05
Summary of Annualized Disinfection and Flushing Costs (Millions of 2008$)
Corrective Action
Disinfection and Flushing
Total
AIM
Alt 2
Alt 3
Alt 4
3%
_
-
0.05
0.05
0.05
0.05
0.05
0.05
AIM
Alt 2
Alt 3
Alt 4
7%
_
-
0.05
0.05
0.05
0.05
0.05
0.05
Summary of Annualized Sanitary Survey/Compliance Audit Costs (Millions of 2008$)
Sanitary Survey; Compliance
Audit
Total
AIM
Alt 2
Alt 3
Alt 4
3%
0.70
0.70
_
-
_
-
0.02
0.02
AIM
Alt 2
Alt 3
Alt 4
7%
0.69
0.69
_
-
_
-
0.02
0.02
Summary of Annualized ADWR Costs (Millions of 2008$)
Total
AIM | Alt 2 | Alt 3 | Alt 4
3%
29.49 | 7.16 | 18.43 | 7.34
AIM | Alt 2 | Alt 3 | Alt 4
7%
29.08 | 7.07 | 18.19 | 7.25
Page C-126
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.15b Summary of Rule Costs (Millions of 2008$), Alternative 1
Summary of Implementation and Annual Administration Costs (Millions of 2008$)
Implementation
Annual Administration
Total
Air Carriers
Agency
Total
3%
$ 0.002
$
$ 0.002
$ 0.01
$ 0.24
$ 0.25
$ 0.01
$ 0.24
$ 0.25
Air Carriers
Agency
Total
7%
$ 0.004
$
$ 0.004
$ 0.01
$ 0.23
$ 0.25
$ 0.02
$ 0.23
$ 0.25
Summary of Annualized Monitoring Plan Costs (Millions of 2008$)
Monitoring Plan
Total
Air Carriers
Agency
Total
3%
$ 0.002
$ 0.002
$ 0.001
$ 0.001
$ 0.002
$ 0.002
Air Carriers
Agency
Total
7%
$ 0.002
$ 0.002
$ 0.001
$ 0.001
$ 0.004
$ 0.004
Summary of Annualized Coliform Monitoring Costs (Millions of 2008$)
Coliform Monitoring
Total
Air Carriers
Agency
Total
3%
$ 25.07
$ 25.07
$ 0.30
$ 0.30
$ 25.37
$ 25.37
Air Carriers
Agency
Total
7%
$ 24.72
$ 24.72
$ 0.30
$ 0.30
$ 25.02
$ 25.02
Summary of Annualized Disinfectant Residual Monitoring Costs (Millions of 2008$)
Disinfectant Residual
Monitoring
Total
Air Carriers
Agency
Total
3%
$ 3.00
$ 3.00
$ 0.17
$ 0.17
$ 3.17
$ 3.17
Air Carriers
Agency
Total
7%
$ 2.96
$ 2.96
$ 0.17
$ 0.17
$ 3.13
$ 3.13
Summary of Annualized Turbidity Monitoring Costs (Millions of 2008$)
Turbidity Monitoring
Total
Air Carriers
Agency
Total
3%
$
$
$
$
$
$
Air Carriers
Agency
Total
7%
$
$
$
$
$
$
Summary of Annualized Nitrate/Nitrite Monitoring Costs (Millions of 2008$)
Nitrate/Nitrite Monitoring
Total
Air Carriers
Agency
Total
3%
$
$
$
$
$
$
Air Carriers
Agency
Total
7%
$
$
$
$
$
$
Summary of Annualized O&M Plan Costs (Millions of 2008$)
O&M Plan
Total
Air Carriers
Agency
Total
3%
$
$
$
$
$
$
Air Carriers
Agency
Total
7%
$
$
$
$
$
$
Page C-127
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.15b Summary of Rule Costs (Millions of 2008$), Alternative 1
Summary of Annualized Routine Disinfection and Flushing Costs (Millions of 2008$)
Routine Disinfection and
Flushing
Total
Air Carriers
Agency
Total
3%
$
$
$
$
$
$
Air Carriers
Agency
Total
7%
$
$
$
$
$
$
Summary of Annualized Corrective Action Disinfection and Flushing Costs (Millions of 2008$)
Corrective Action
Disinfection and Flushing
Total
Air Carriers
Agency
Total
3%
$
$
$
$
$
$
Air Carriers
Agency
Total
7%
$
$
$
$
$
$
Summary of Annualized Sanitary Survey/Compliance Audit Costs (Millions of 2008$)
Sanitary Survey/
Compliance Audit
Total
Air Carriers
Agency
Total
3%
$ 0.03
$ 0.03
$ 0.67
$ 0.67
$ 0.70
$ 0.70
Air Carriers
Agency
Total
7%
$ 0.03
$ 0.03
$ 0.66
$ 0.66
$ 0.69
$ 0.69
Summary of Annualized ADWR Costs (Millions of 2008$)
Total
Air Carriers
$ 28.11
I
|$
Agency
3%
1.38
I
|$
Total
29.49
Air
$
Carriers |
27.71 |
$
Agency
7%
1.37
I
|$
Total
29.08
Page C-128
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.15c Summary of Rule Costs (Millions of 2008$), Alternative 2
Summary of Implementation and Annual Administration Costs (Millions of 2008$)
Implementation
Annual Administration
Total
Air Carriers
Agency
Total
3%
$ 0.002
$
$ 0.002
$ 0.01
$ 0.24
$ 0.25
$ 0.01
$ 0.24
$ 0.25
Air Carriers
Agency
Total
7%
$ 0.004
$
$ 0.004
$ 0.01
$ 0.23
$ 0.25
$ 0.02
$ 0.23
$ 0.25
Summary of Annualized Monitoring Plan Costs (Millions of 2008$)
Monitoring Plan
Total
Air Carriers
Agency
Total
3%
$ 0.002
$ 0.002
$ 0.001
$ 0.001
$ 0.002
$ 0.002
Air Carriers
Agency
Total
7%
$ 0.002
$ 0.002
$ 0.001
$ 0.001
$ 0.004
$ 0.004
Summary of Annualized Coliform Monitoring Costs (Millions of 2008$)
Coliform Monitoring
Total
Air Carriers
Agency
Total
3%
$ 1.66
$ 1.66
$ 0.01
$ 0.01
$ 1.67
$ 1.67
Air Carriers
Agency
Total
7%
$ 1.63
$ 1.63
$ 0.01
$ 0.01
$ 1.65
$ 1.65
Summary of Annualized Disinfectant Residual Monitoring Costs (Millions of 2008$)
Disinfectant Residual
Monitoring
Total
Air Carriers
Agency
Total
3%
$ 0.50
$ 0.50
$ 0.17
$ 0.17
$ 0.67
$ 0.67
Air Carriers
Agency
Total
7%
$ 0.49
$ 0.49
$ 0.17
$ 0.17
$ 0.66
$ 0.66
Summary of Annualized Turbidity Monitoring Costs (Millions of 2008$)
Turbidity Monitoring
Total
Air Carriers
Agency
Total
3%
$
$
$
$
$
$
Air Carriers
Agency
Total
7%
$
$
$
$
$
$
Summary of Annualized Nitrate/Nitrite Monitoring Costs (Millions of 2008$)
Nitrate/Nitrite Monitoring
Total
Air Carriers
Agency
Total
3%
$
$
$
$
$
$
Air Carriers
Agency
Total
7%
$
$
$
$
$
$
Summary of Annualized O&M Plan Costs (Millions of 2008$)
O&M Plan
Total
Air Carriers
Agency
Total
3%
$
$
$
$
$
$
Air Carriers
Agency
Total
7%
$
$
$
$
$
$
Page C-129
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.15c Summary of Rule Costs (Millions of 2008$), Alternative 2
Summary of Annualized Routine Disinfection and Flushing Costs (Millions of 2008$)
Routine Disinfection and
Flushing
Total
Air Carriers
Agency
Total
3%
$ 3.85
$ 3.85
$ 0.67
$ 0.67
$ 4.52
$ 4.52
Air Carriers
Agency
Total
7%
$ 3.80
$ 3.80
$ 0.66
$ 0.66
$ 4.46
$ 4.46
Summary of Annualized Corrective Action Disinfection and Flushing Costs (Millions of 2008$)
Corrective Action
Disinfection and Flushing
Total
Air Carriers
Agency
Total
3%
$ 0.05
$ 0.05
$
$
$ 0.05
$ 0.05
Air Carriers
Agency
Total
7%
$ 0.05
$ 0.05
$
$
$ 0.05
$ 0.05
Summary of Annualized Sanitary Survey/Compliance Audit Costs (Millions of 2008$)
Sanitary Survey/
Compliance Audit
Total
Air Carriers
Agency
Total
3%
$
$
$
$
$
$
Air Carriers
Agency
Total
7%
$
$
$
$
$
$
Summary of Annualized ADWR Costs (Millions of 2008$)
Total
Air
$
Carriers
6.06
I
|$
Agency
3%
1.10
I
|$
Total
7.16
Air Carriers
$ 5.98
I
|$
Agency
7%
1.09
I
|$
Total
7.07
Page C-130
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.15d Summary of Rule Costs (Millions of 2008$), Alternative 3
Summary of Implementation and Annual Administration Costs (Millions of 2008$)
Implementation
Annual Administration
Total
Air Carriers
Agency
Total
3%
$ 0.002
$
$ 0.002
$ 0.01
$ 0.24
$ 0.25
$ 0.01
$ 0.24
$ 0.25
Air Carriers
Agency
Total
7%
$ 0.004
$
$ 0.004
$ 0.01
$ 0.23
$ 0.25
$ 0.02
$ 0.23
$ 0.25
Summary of Annualized Monitoring Plan Costs (Millions of 2008$)
Monitoring Plan
Total
Air Carriers
Agency
Total
3%
$ 0.001
$ 0.001
$ 0.0004
$ 0.0004
$ 0.001
$ 0.001
Air Carriers
Agency
Total
7%
$ 0.001
$ 0.001
$ 0.001
$ 0.001
$ 0.002
$ 0.002
Summary of Annualized Coliform Monitoring Costs (Millions of 2008$)
Coliform Monitoring
Total
Air Carriers
Agency
Total
3%
$ 2.22
$ 2.22
$ 0.01
$ 0.01
$ 2.23
$ 2.23
Air Carriers
Agency
Total
7%
$ 2.19
$ 2.19
$ 0.01
$ 0.01
$ 2.20
$ 2.20
Summary of Annualized Disinfectant Residual Monitoring Costs (Millions of 2008$)
Disinfectant Residual
Monitoring
Total
Air Carriers
Agency
Total
3%
$
$
$
$
$
$
Air Carriers
Agency
Total
7%
$
$
$
$
$
$
Summary of Annualized Turbidity Monitoring Costs (Millions of 2008$)
Turbidity Monitoring
Total
Air Carriers
Agency
Total
3%
$ 11.910
$ 11.91
$ 1.01
$ 1.01
$ 12.92
$ 12.92
Air Carriers
Agency
Total
7%
$ 11.74
$ 11.74
$ 1.00
$ 1.00
$ 12.74
$ 12.74
Summary of Annualized Nitrate/Nitrite Monitoring Costs (Millions of 2008$)
Nitrate/Nitrite Monitoring
Total
Air Carriers
Agency
Total
3%
$
$
$
$
$
$
Air Carriers
Agency
Total
7%
$
$
$
$
$
$
Summary of Annualized O&M Plan Costs (Millions of 2008$)
O&M Plan
Total
Air Carriers
Agency
Total
3%
$ 0.01
$ 0.01
$ 0.001
$ 0.001
$ 0.01
$ 0.01
Air Carriers
Agency
Total
7%
$ 0.01
$ 0.01
$ 0.001
$ 0.001
$ 0.01
$ 0.01
PageC-131
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.15d Summary of Rule Costs (Millions of 2008$), Alternative 3
Summary of Annualized Routine Disinfection and Flushing Costs (Millions of 2008$)
Routine Disinfection and
Flushing
Total
Air Carriers
Agency
Total
3%
$ 2.97
$ 2.97
$
$
$ 2.97
$ 2.97
Air Carriers
Agency
Total
7%
$ 2.93
$ 2.93
$
$
$ 2.93
$ 2.93
Summary of Annualized Corrective Action Disinfection and Flushing Costs (Millions of 2008$)
Corrective Action
Disinfection and Flushing
Total
Air Carriers
Agency
Total
3%
$ 0.05
$ 0.05
$
$
$ 0.05
$ 0.05
Air Carriers
Agency
Total
7%
$ 0.05
$ 0.05
$
$
$ 0.05
$ 0.05
Summary of Annualized Sanitary Survey/Compliance Audit Costs (Millions of 2008$)
Sanitary Survey/
Compliance Audit
Total
Air Carriers
Agency
Total
3%
$
$
$
$
$
$
Air Carriers
Agency
Total
7%
$
$
$
$
$
$
Summary of Annualized ADWR Costs (Millions of 2008$)
Total
Air Carriers
$ 17.17
I
|$
Agency
3%
1.27
I
|$
Total
18.43
Air
$
Carriers |
16.93 |
$
Agency
7%
1.26
I
|$
Total
18.19
Page C-132
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.15e Summary of Rule Costs (Millions of 2008$), Alternative 4 (Final Rule
Summary of Implementation and Annual Administration Costs (Millions of 2008$)
Implementation
Annual Administration
Total
Air Carriers
Agency
Total
3%
$ 0.002
$
$ 0.002
$ 0.01
$ 0.24
$ 0.25
$ 0.01
$ 0.24
$ 0.25
Air Carriers
Agency
Total
7%
$ 0.004
$
$ 0.004
$ 0.01
$ 0.23
$ 0.25
$ 0.02
$ 0.23
$ 0.25
Summary of Annualized Sampling Plan Costs (Millions of 2008$)
Sampling Plan
Total
Air Carriers
Agency
Total
3%
$ 0.002
$ 0.002
$ 0.001
$ 0.001
$ 0.002
$ 0.002
Air Carriers
Agency
Total
7%
$ 0.002
$ 0.002
$ 0.001
$ 0.001
$ 0.003
$ 0.003
Summary of Annualized Coliform Monitoring Costs (Millions of 2008$)
Coliform Monitoring
Total
Air Carriers
Agency
Total
3%
$ 4.89
$ 4.89
$ 0.04
$ 0.04
$ 4.93
$ 4.93
Air Carriers
Agency
Total
7%
$ 4.82
$ 4.82
$ 0.04
$ 0.04
$ 4.86
$ 4.86
Summary of Annualized Disinfectant Residual Monitoring Costs (Millions of 2008$)
Disinfectant Residual
Monitoring
Total
Air Carriers
Agency
Total
3%
$
$
$
$
$
$
Air Carriers
Agency
Total
7%
$
$
$
$
$
$
Summary of Annualized Turbidity Monitoring Costs (Millions of 2008$)
Turbidity Monitoring
Total
Air Carriers
Agency
Total
3%
$
$
$
$
$
$
Air Carriers
Agency
Total
7%
$
$
$
$
$
$
Summary of Annualized Nitrate/Nitrite Monitoring Costs (Millions of 2008$)
Nitrate/Nitrite Monitoring
Total
Air Carriers
Agency
Total
3%
$
$
$
$
$
$
Air Carriers
Agency
Total
7%
$
$
$
$
$
$
Summary of Annualized O&M Plan Costs (Millions of 2008$)
O&M Plan
Total
Air Carriers
Agency
Total
3%
$ 0.01
$ 0.01
$ 0.0001
$ 0.0001
$ 0.01
$ 0.01
Air Carriers
Agency
Total
7%
$ 0.02
$ 0.02
$ 0.0001
$ 0.0001
$ 0.02
$ 0.02
Page C-133
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit C.15e Summary of Rule Costs (Millions of 2008$), Alternative 4 (Final Rule
Summary of Annualized Routine Disinfection and Flushing Costs (Millions of 2008$)
Routine Disinfection and
Flushing
Total
Air Carriers
Agency
Total
3%
$ 2.08
$ 2.08
$
$
$ 2.08
$ 2.08
Air Carriers
Agency
Total
7%
$ 2.05
$ 2.05
$
$
$ 2.05
$ 2.05
Summary of Annualized Corrective Action Disinfection and Flushing
Corrective Action
Disinfection and Flushing
Total
Air Carriers
Agency
Total
3%
$ 0.05
$ 0.05
$
$
$ 0.05
$ 0.05
Costs (Millions of 2008$)
Air Carriers
Agency
Total
7%
$ 0.05
$ 0.05
$
$
$ 0.05
$ 0.05
Summary of Annualized Compliance Audit Costs (Millions of 2008$)
Compliance Audit
Total
Air Carriers
Agency
Total
3%
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.02
$ 0.02
Air Carriers
Agency
Total
7%
$ 0.01
$ 0.01
$ 0.01
$ 0.01
$ 0.02
$ 0.02
Summary of Annualized ADWR Costs (Millions of 2008$)
Total
Air Carriers
$ 7.04
I
|$
Agency
3%
0.30
I
|$
Total
7.34
Air
$
Carriers |
6.95 |
$
Agency
7%
0.30
I
|$
Total
7.25
Page C-134
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Page C-135
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Appendix D
Screening Analysis
-------
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
D.I Introduction and General Approach
EPA has conducted a screening analysis to consider the economic impact of the final rule
on small entities that own or operate air carriers. This analysis has been completed using the
methodology described in the Regulatory Flexibility Act (RFA) as amended by the Small
Business Regulatory Enforcement Fairness Act (SBREFA) of 1996 (5 U.S.C. §601 et seq.).
The remaining sections of this document include the following information:
• Section D.2—Definition of a Small Business
• Section D.3—Screening Analysis of Small Entities
• Section D.4—Baseline Information
• Section D.5—Cost Information
• Section D.6—Revenue Information
• Section D.7—Results of Screening Analysis
D.2 Definition of a Small Business
U.S. aircraft are owned and operated exclusively by businesses. Therefore, the screening
analysis for the ADWR uses the following definition for small entities: A "small business" is any
firm that is independently owned and operated and is not dominant in its field of operation
(Small Business Act, 15 U.S.C. 632). The RFA references this definition of "small business"
and defines small entities as including "small businesses," "small governments," and "small
organizations" (5 U.S.C. 601).
The Small Business Administration's (SBA) definitions of small businesses use
categories are defined by National American Industry Classification System (NAICS) codes.
For example, in the manufacturing sector, the SBA generally defines small businesses in terms of
number of employees, but in the agriculture, mining, electric, gas, and sanitary services sectors,
the SBA generally defines small businesses in terms of number of employees or annual receipts
(ranging from $0.5 million for crops to $25 million for certain types of pipelines).
EPA has determined that the following businesses would be affected by the Aircraft
Drinking Water Rule (ADWR) based on the NAICS:
• 481111 - Scheduled passenger air transportation
• 481211 - Nonscheduled chartered passenger air transportation
SBA defines a small business for air carriers (NAICS codes 481111 and 481211) as
having fewer than 1,500 employees (13 CFR 121.201).
D.3 Screening Analysis of Small Entities
The screening analysis determines whether the ADWR will impose a significant
economic impact on a substantial number of small entities. The Interim Guidance for EPA
Page D-l
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
Rulewriters for the RFA as amended by the SBREFA (USEPA 1999) suggests using 1 percent of
revenue as a threshold for determining if a cost impact of a regulation is "significant," although
additional factors may be considered. If the compliance costs for a new regulation are greater
than 1 percent of sales or revenues for 100 or more entities and for more than 20 percent of all
affected small entities, then in most cases there would be a significant impact. If more than 100
entities experience economic impacts of 3 percent of their revenues or greater, then in most cases
there would be a significant impact. Since there are fewer than 100 entities considered in this
analysis, it is more meaningful to consider the percent of costs compared to revenue.
Based on information available on the internet, industries, and from best professional
judgment, EPA estimated costs associated with implementing the various components of the
ADWR. Chapter 5 of this EA provides details on labor rates and estimated costs to air carriers.
Revenue data (year 2005) for small businesses were obtained from Dun & Bradstreet
(D&B) reports, which present an estimate of annual sales. Data were based on individual
companies, rather than the parent company, using the conservative assumption that parent
companies will not supplement the finances of their subsidiaries.
The revenue of small air carriers does not reflect the low and sometimes negative profits
of numerous air carriers in recent years, which may be influenced by a variety of factors. The
following air carriers filed for Chapter 11 or Chapter 7 bankruptcy between 2004 and 2006 (Air
Transport Association 2006):
• U.S. Airways
Comair, Independence Air
• Atlas Air
• ERA Aviation
• Delta Airlines
• Florida Coastal Airlines
• Northwest
• Southeast
• Aloha
• TransMeridian
• American Trans Air
• Great Plains
• Mesaba Airlines
Several issues that affect air carrier profitability are summarized below:
The air carrier industry must accommodate a high tax burden, which can affect the
profitability of businesses.
• The air carrier industry is a heavily regulated industry. U.S. Federal Aviation
Administration (FAA) requirements cover, among other things, retirement of older
aircraft, security measures, collision avoidance systems, airborne windshear
avoidance systems, noise abatement and other environmental concerns, commuter
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
aircraft safety, and increased inspections and maintenance procedures in older
aircraft.
• In general, air carriers have limited pricing power due to the substantial price
competition in the air carrier industry, especially in domestic markets.
• Although many air carriers continue to cut benefits as labor agreements are
renegotiated, benefits of air carrier employees have increased rapidly.
• Crude oil prices have continued to rise dramatically.
• World events (e.g., war, pandemic illnesses, terrorist attacks) and economic health
affect numbers of air carrier passengers and, therefore, air carriers' revenue and
profit.
In spite of these issues, air carriers have voiced a continuous commitment to ensure that
drinking water on aircraft is safe for the public.
D.4 Baseline Information
Air carriers were considered individually, including those owned by a parent company.
Air carriers subject to the rule usually operate aircraft serving 30 or more passengers. Aircraft
that carry fewer than 30 passengers generally are not capable of taking water onboard, except
chartered aircraft.
Of the approximately 63 air carriers that may be subject to the ADWR, 30 are small
businesses. These 30 air carriers represent 48 percent of the universe of air carriers subject to the
final rule, and all will be subject to the various provisions. Therefore, EPA has determined that a
substantial number of small entities will be impacted by the ADWR.
Although each aircraft will be regulated as a separate water system, the economic impact
of the rule is considered for air carriers in this analysis. The rationale for using this approach
considers that one-time costs (e.g., developing a monitoring plan) will apply to the entire air
carrier fleet and that revenue information is only available for air carriers.
D.5 Revenue information
Revenue information for most small air carriers was available from the private database,
D&B. Revenue data were obtained from D&B in July 2006 and adjusted to 2008$. When
revenue information was not available for a specific air carrier, EPA used the median revenue
from air carriers included in this analysis. The average revenue for small air carriers subject to
the ADWR is $106.6 million, and the median revenue is $57.2 million. One air carrier is a
subsidiary of a large company and provides various services related to private jets. Although the
company has fewer than 1,500 employees, it has substantially higher revenues than other small
air carriers. Removing this company decreases the average revenue to $84.3 million.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
D.6 Cost Information
Because many air carriers have been experiencing financial difficulties in recent years,
EPA has made an effort to minimize the impact of the rule on these businesses. Air carriers have
the flexibility to choose one of four disinfection/monitoring schedules that can be integrated into
their current operations and maintenance (O&M) schedule. In addition, air carriers are only
required to monitor for total coliform, similar to other transient noncommunity water systems
(TNCWS) that obtain treated water from a parent system (i.e., consecutive systems do not have
to monitor for nitrates and turbidity).
As part of the regulatory development process, EPA has identified related existing
programs and practices, and has determined how the new regulatory requirements can be
integrated with them to avoid duplicative burden (e.g., inspections). Aircraft water systems have
many different on-going programs and practices for assessing and correcting deficiencies and
risks associated with the drinking water supply and related security and sanitation issues
including:
• U.S. Food and Drug Administration's (FDA) regulations for Interstate Conveyance
Sanitation (USFDA 2005);
• FAA Airworthiness Standards: Transport Category Airplanes (Airworthiness
maintenance and inspection program);
• Vulnerability assessments/security program;
• FDA sanitary surveys of watering points and servicing areas;
• FDA approval and certification of watering points;
• FDA certification of aircraft sanitation systems including potable water, sewage, and
galleys.
To estimate costs for small air carriers, EPA followed the same methodology as was used
to develop the annualized implementation and incremental costs for the rule overall, as described
in Chapter 5 of this EA. Exhibits D.I and D.2 show present value costs by rule activity,
annualized over 25 years using 3 and 7 percent discount rates, respectively. Total annual costs
for all small air carriers are estimated to be $524,380 and $521,110, annualized at a 3 and 7
percent discount rate, respectively. Average annual rule costs associated with the 30 individual
small air carriers is approximately $17,543 (annualized at 3 percent).
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit D.1 Total Present Value Implementation Costs for Small Air carriers, Annualized at 3 Percent over 25
Years
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Total PV
Annualized
Implementation
$ 10,286
$ 9,986
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$ 20,272
$ 1,164
Annual
Administration
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Sampling Plan
$ 6,429
$ 6,241
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$ 12,670
$ 728
Monitoring - TC
$
$
$ 383,523
$ 355,962
$ 345,595
$ 335,529
$ 325,756
$ 316,268
$ 307,056
$ 298,113
$ 289,430
$ 281,000
$ 285,377
$ 264,869
$ 257,155
$ 249,665
$ 242,393
$ 235,333
$ 228,479
$ 221,824
$ 215,363
$ 209,090
$ 203,000
$ 197,088
$ 191,347
$ 6,239,216
$ 358,305
Monitoring -
Disinfectant
Residual
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Turbidity
Monitoring
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Nitrate/Nitrite
Monitoring
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
O&M Plan
$ 51,430
$ 49,932
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$ 101,361
$ 5,821
Routine
Disinfection &
Flushing
$
$
$ 153,552
$ 149,079
$ 144,737
$ 140,522
$ 136,429
$ 132,455
$ 128,597
$ 124,852
$ 121,215
$ 117,685
$ 114,257
$ 110,929
$ 107,698
$ 104,561
$ 101,516
$ 98,559
$ 95,688
$ 92,901
$ 90,196
$ 87,568
$ 85,018
$ 82,542
$ 80,138
$ 2,600,694
$ 149,352
CA Disinfection
& Flushing
$
$
$ 3,446
$ 3,345
$ 3,248
$ 3,153
$ 3,061
$ 2,972
$ 2,886
$ 2,802
$ 2,720
$ 2,641
$ 2,564
$ 2,489
$ 2,417
$ 2,346
$ 2,278
$ 2,212
$ 2,147
$ 2,085
$ 2,024
$ 1,965
$ 1,908
$ 1,852
$ 1,798
$ 58,357
$ 3,351
Compliance Audit
$
$
$ 5,817
$ 5,648
$ 5,483
$ 5,324
$ 5,169
$ 5,018
$ 4,872
$ 4,730
$ 4,592
$ 4,458
$ 4,329
$ 4,203
$ 4,080
$ 3,961
$ 3,846
$ 3,734
$ 3,625
$ 3,520
$ 3,417
$ 3,318
$ 3,221
$ 3,127
$ 3,036
$ 98,527
$ 5,658
Total Costs
$ 68,144
$ 66,160
$ 546,338
$ 514,035
$ 499,063
$ 484,527
$ 470,415
$ 456,713
$ 443,411
$ 430,496
$ 417,957
$ 405,784
$ 406,527
$ 382,490
$ 371 ,350
$ 360,534
$ 350,033
$ 339,838
$ 329,939
$ 320,330
$ 311,000
$ 301,941
$ 293,147
$ 284,609
$ 276,319
$ 9,131,098
$ 524,380
Notes:
1) Public notification is not covered under ADWR, but is covered under PNR.
2) Present values in 2008 dollars, discounted to Y1.
3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.
Page D-5
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit D.2 Total Present Value Implementation Costs for Small Air carriers, Annualized at 7 Percent over 25
Years
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Total PV
Annualized
Implementation
$ 10,286
$ 9,613
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$ 19,899
$ 1,708
Annual
Administration
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Sampling
Plan
$ 6,429
$ 6,008
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$ 12,437
$ 1,067
Monitoring - TC
$
$
$ 355,384
$ 317,515
$ 296,743
$ 277,330
$ 259,187
$ 242,231
$ 226,384
$ 211,574
$ 197,732
$ 184,797
$ 180,659
$ 161,409
$ 150,849
$ 140,981
$ 131,757
$ 123,138
$ 115,082
$ 107,553
$ 100,517
$ 93,941
$ 87,796
$ 82,052
$ 76,684
$ 4,121,296
$ 353,651
Monitoring -
Disinfectant
Residual
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Turbidity
Monitoring
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Nitrate/Nitrite
Monitoring
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
O&M Plan
$ 51,430
$ 48,065
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$ 99,495
$ 8,538
Routine
Disinfection
& Flushing
$
$
$ 142,286
$ 132,977
$ 124,278
$ 116,148
$ 108,549
$ 101,448
$ 94,811
$ 88,609
$ 82,812
$ 77,394
$ 72,331
$ 67,599
$ 63,177
$ 59,044
$ 55,181
$ 51,571
$ 48,197
$ 45,044
$ 42,097
$ 39,343
$ 36,769
$ 34,364
$ 32,116
$ 1,716,144
$ 147,263
CA Disinfection
& Flushing
$
$
$ 3,193
$ 2,984
$ 2,789
$ 2,606
$ 2,436
$ 2,276
$ 2,127
$ 1 ,988
$ 1 ,858
$ 1,737
$ 1 ,623
$ 1,517
$ 1,418
$ 1 ,325
$ 1 ,238
$ 1,157
$ 1,081
$ 1,011
$ 945
$ 883
$ 825
$ 771
$ 721
$ 38,509
$ 3,304
Compliance Audit
$
$
$ 5,390
$ 5,038
$ 4,708
$ 4,400
$ 4,112
$ 3,843
$ 3,592
$ 3,357
$ 3,137
$ 2,932
$ 2,740
$ 2,561
$ 2,393
$ 2,237
$ 2,091
$ 1 ,954
$ 1 ,826
$ 1 ,706
$ 1 ,595
$ 1,491
$ 1 ,393
$ 1 ,302
$ 1,217
$ 65,016
$ 5,579
Total Costs
$ 68,144
$ 63,686
$ 506,254
$ 458,514
$ 428,518
$ 400,484
$ 374,284
$ 349,798
$ 326,914
$ 305,527
$ 285,540
$ 266,860
$ 257,354
$ 233,085
$ 217,837
$ 203,586
$ 190,267
$ 177,820
$ 166,187
$ 155,315
$ 145,154
$ 135,658
$ 126,783
$ 118,489
$ 110,737
$ 6,072,795
$ 521,110
Notes:
1) Public notification is not covered under ADWR, but is covered under PNR.
2) Present values in 2008 dollars, discounted to Y1.
3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation
period.
Page D-6
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
EPA estimates that the average annual incremental rule cost (the difference between the
final rule and Alternative 1, compliance with the existing NPDWRs), is a reduction in cost of
$258,599 at a 3 percent discount rate, and the average annual incremental rule costs between the
final rule and Alternative 2, compliance with requirements similar to the Administrative Orders
on Consent (AOCs), is a reduction in cost of $32,188 at a 3 percent discount rate. These results,
shown in Exhibit D.3, demonstrate a cost savings for small entities by choosing the final rule
over compliance with either the existing NPDWRs or compliance with requirements similar to
the AOCs, which are the first two alternatives, respectively.
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Economic and Supporting Analyses Document for the Final Aircraft Drinking Water Rule
October 2009
Exhibit D3: Results of the Screening Analysis for Alternatives 1, 2, and 4
Total Number of Aircraft Owned by Small Air
Carriers
Total Number of Small Air Carriers
Average Revenues for Small Air Carriers
514
30
$106,576,591
Average Rule Costs for Small Air Carriers
Average Cost/Revenue
Alt1
(Existing
NPDWRs)
$276,142
0.26%
Alt 2
(Similar to
AOCs)
$49 731
0.05%
Small Air Carriers Experiencing Costs >1% of their Revenues
N^e'rMnt
Small Air Carriers Experiencing Costs >3% of their Revenues
NPetent
Alt 4
(Final ADWR)
$1 7 543
0.02%
Alt 4 - Alt1
$(258,599)
0.00%
0.00%
Alt4 - Alt2
$(32,188)
0.00%
0.00%
Source: Derived from the ADWR Cost Model. Average rule costs in 2008$.
Note: Average revenue for small air carriers based on 2005
data.
Page D-8
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009
Recognizing the variation of sized companies within this group, EPA has estimated the
average annual incremental cost for small air carriers with fewer than 500 employees and for
small air carriers with 500 or more employees. The number of employees was taken from the
baseline and from 2006 Bureau of Transportation Statistics (BTS) data1. For air carriers with
fewer than 500 employees, the incremental cost between the final rule and Alternative lisa
reduction of $78,042 at a 3 percent discount rate, and the incremental average rule cost between
the final rule and Alternative 2 is a reduction of $7,781 at a 3 percent discount rate (Exhibit D4).
For air carriers with 500 or more employees, the incremental cost between the final rule and
Alternative 1 is a reduction of $230,712 at a 3 percent discount rate, and the incremental average
rule cost between the final rule and Alternative 2 is a reduction of $20,104 at a 3 percent
discount rate (Exhibit D5).
1 Employee data from ATA Execujet was not available from any source. Since the air carrier only has one aircraft,
EPA assumed that ATA Execujet has fewer than 500 employees.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit D4: Results of the Screening Analysis for Small Air Carriers with Fewer than 500 Employees
Total Number of Aircraft Owned by Small Air
Carriers w/< 500 employees
Total Number of Small Air Carriers w/< 500
employees
Average Revenues for Small Air Carriers w/<
500 employees
129
17
$72,903,528
Average Rule Costs for Small Air Carriers w/<
500 employees
Average Cost/Revenue
Alt1
(Existing
NPDWRs)
$8fi 751
0.12%
Alt 2
(Similar to
AOCs)
$1fi49f)
0.02%
Small Air Carriers w/< 500 employees Experiencing Costs >1% of their
Revenues
N^e'rMnt
Small Air Carriers w/< 500 employees Experiencing Costs >3% of their
Revenues
NPetent
Alt 4
(Final ADWR)
$8 709
0.01%
Alt 4 - Alt1
$(78,042)
0.00%
0.00%
Alt4 - Alt2
$(7,781)
0.00%
0.00%
Source: Derived from the ADWR Cost Model. Average rule costs in 2008$ at 3%
discount rate.
Note: Average revenue for small air carriers based on 2005
data.
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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule
October 2009
Exhibit D5: Results of the Screening Analysis for Small Air Carriers with 500 or More Employees
Total Number of Aircraft Owned by Small Air
Carriers w/ >500 Employees
Total Number of Small Air Carriers w/ >500
Employees
Average Revenues for Small Air Carriers w/
>500 Employees
385
13
$151,063,274
Average Rule Costs for Small Air Carriers w/
>500 Employees
Average Cost/Revenue
AIM
(Existing
NPDWRs)
$259,752
0.17%
Alt 2
(Similar to
AOCs)
$49 144
0.03%
Small Air Carriers w/ >500 Employees Experiencing Costs >1% of their
Revenues
N^e'rMnt
Small Air Carriers w/ >500 Employees Experiencing Costs >3% of their
Revenues
NPetent
Alt 4
(Final ADWR)
$?9 040
0.02%
Alt 4 - Alt1
$(230,712)
0.00%
0.00%
Alt4 - Alt2
$(20,104)
0.00%
0.00%
Source: Derived from the ADWR Cost Model. Average rule costs in 2008$ at 3%
discount rate.
Note: Average revenue for small air carriers based on 2005
data.
Page D-11
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