Technology and Cost Document for
the Revised Total Coliform Rule

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                                             Disclaimer

Readers may use the information presented in this document to evaluate the available technologies, operational
practices, and compliance activities available to PWSs in complying with the proposed revised Total Coliform
Rule.

Information presented in this document serves as a foundation for making comparisons between regulatory
alternatives developed by EPA, States, and other interested parties.  This information is meant to be used for
evaluation and comparison purposes at the national level only and not as direct input into system-specific
design or budget preparation for non-EPA entities.

 Mention of trade names or commercial products does not constitute an EPA endorsement.
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CONTENTS
List of Acronyms/Abbreviations
1 Introduction
1.1 Purpose of the Document
1.2 Background of RTCR
1.3 Document Organization
2 Estimated Unit Costs of Labor
2. 1 Water System Labor Rates
2.2 State Drinking Water Program Personnel Labor Rates
2.3 Escalated Labor Rates
2.4 Labor Rates for RTCR Alternative Size Categories
3 Estimated Unit Costs of TCR Monitor/no Reauirements
3.1 Introduction
3.2 Sample Collection and Delivery
3.2.1 Sample Collection
3.2.1.1 Sample Collection Labor Burden
3.2.1.2 Unit Sample Collection Costs
3.2.2 Sample Delivery
3.3 Sample Analysis
3.3.1 Available Analytical Methods
3.3.2 Sample Analysis Cost
3.3.2.1 Contractor Labs
3.3.2.2 In-house Analysis
3.4 Estimated Average Unit Monitoring Costs
4 Estimated Unit Costs of Assessments
4. 1 Overview of Assessments
4.1.1 Level 1 Assessments
4.1.2 Level 2 Assessments
4.2 Elements of Assessments
4.2.1 Notification Element
4.2.2 System Specific Element
4.2.3 Sample Analytical Element
4.2.4 Sample Methodology Element
4.2.5 Event Situational Element
4.2.6 Operational Data Element
4.2.7 Historical Trend Element
4.2.8 Sample Tap Element
4.2.9 Sample Site Element
4.2.10 Sample Area Element
4.2.11 Third Party Element
4.2.12 Report Element
4.3 Unit Cost Estimates of Assessments
4.3.1 Methodology

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4.3.2 Assumptions
5 Estimated Unit Costs of Corrective Actions
5.1 Flushing
5.1.1 Scheduled / Routine Flushing
5.1.2 Unscheduled /Spot Flushing
5.2 Sampler Training
5.3 Replacement / Repair of Distribution System Components
5.3.1 Valves
5.3.2 Water Mains
5.3.3 Fittings
5.3.4 Hydrants
5.3.5 Meters
5.3.6 Dedicated Sample Taps
5.4 Maintenance of Adequate Pressure
5.4.1 Booster Pumping Station
5.4.2 Modify or Replace Existing Pumps
5.4.3 Install Variable Frequency Drives
5.4.4 Elevated Storage Facility
5.4.5 Install Surge Relief Valve
5.4.6 Install Surge Tanks
5.5 Maintenance of Appropriate Hydraulic Residence Time
5.5.1 Loop Dead Ends
5.5.2 Install Appropriate Main Sizes
5.5.3 Install Automated Flushing Devices
5.5.4 Storage Facility Modifications
5.5.4.1 Modify Inlet/Outlet Piping
5.5.4.2 Install Mixing Devices
5.5.4.3 Modify Storage Operation
5.5.4.4 Decommission Storage
5.6 Storage Facility Maintenance
5.6.1 Inspecting/Cleaning of Tanks
5.6.2 Lining of Storage Tanks
5.6.3 Vent/Hatch Repair
5.6.4 Tank Repair
5.7 Booster Disinfection
5.7.1 Chlorine System
5.7.1.1 Permanent System
5.7.1.2 Temporary System
5.7.2 Chloramine System
5.7.2.1 Permanent System
5.7.2.2 Temporary System
5.8 Cross-connection Control and Backflow Prevention Program
5.8.1 Backflow Prevention Assemblies and Devices
5.8.2 Program Administration
5.9 Addition or Upgrade of On-line Monitoring and Control
5.9.1 Water Quality Monitoring and Control
5.9.1.1 Chlorinated Systems
5.9.1.2 Chloraminated Systems
5.9.2 Pressure Monitoring and Control
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   5.10   Addition of Security Measures	5-44

   5.11   Development and Implementation of an Operations Plan	5-45
     5.11.1     Operation and Maintenance Standard Operating Procedure (SOP) Training	5-46
     5.11.2     Operation and Maintenance Plan Revision	5-47

References	    R-l
Appendix A	  A-l
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                                      List of Exhibits

Exhibit 2-1: Water System Labor Rates by System Size (2003$)	2-3
Exhibit 2-2: State Program Wage Rates (2003$)	2-4
Exhibit 2-3: Water System Wage Rates by System Size (2007$)	2-4
Exhibit 2-4: State Program Personnel Wage Rates (2007$)	2-5
Exhibit 2-5: Comparison of the Number of Systems in each System Size Category for the GWR EA and
the Proposed RTCR	2-5
Exhibit 2-6: Water System Labor Rates by TCRDSAC TWG System Size Categories (2007$)	2-6
Exhibit 3-1: Estimated Travel and Sample Time by PWS Population Served	3-2
Exhibit 3-2: Estimated Sampling Collection Cost (2007$)	3-3
Exhibit 3-3: Estimated Sample Delivery Cost Per Shipment (2007$)	3-3
Exhibit 3-4: Estimated Per-Sample Delivery Cost (2007$)	3-4
Exhibit 3-5: Estimated Cost for Sample Self-Delivery1 (2007$)	3-4
Exhibit 3-6: Per Sample Cost Estimate for Sample Self-Delivery (2007$)	3-4
Exhibit 3-7: Estimated Percentages1 of Systems Using Each Type of Sample Delivery	3-5
Exhibit 3-8: Estimated Per Sample Shipping/Delivery Cost as a Function of System Size (2007$)	3-6
Exhibit 3-9: Common TC and ฃ. co/; Analytical Methods and their Average Contractor Lab Analytical Fee
(2007$)1	3-8
Exhibit 3-10: Estimated  Sample Cost for In-House Analysis  (2007$)	3-9
Exhibit 3-12: Estimated  Average Unit Cost of Monitoring (2007$)	3-10
Exhibit 4-2: Categories for which cost estimates are developed	4-8
Exhibit 4-3: Violations and triggers leading to assessments	4-8
Exhibit 4-4: Current TCR (as implemented) Labor Burden Estimate for Assessments done by CWSs
serving  1,001-4,100	4-9
Exhibit 4-6: Estimated Labor Burden Associated with Assessments  (hours)	4-12
Exhibit 4-7: Estimated Labor Burden Associated with Assessments  (2007$)	4-12
Exhibit 5-1: Summary of Corrective Actions	5-1
Exhibit 5-2: Estimated Costs for Routine Flushing	5-4
Exhibit 5-3: Estimated Costs for Spot Flushing	5-6
Exhibit 5-4: Estimated Costs Operator Training/Certification	5-7
Exhibit 5-5: Estimated Costs to  Replace Valve	5-8
Exhibit 5-6: Estimated Costs to Replace Ductile Iron Pipe	5-9
Exhibit 5-7: Estimated Costs to  Replace Fittings	5-10
Exhibit 5-8: Estimated Costs to  Replace Hydrants	5-11
Exhibit 5-9: Estimated Costs to  Replace Meters	5-12
Exhibit 5-10: Dedicated  Sampling Station Schematic	5-13
Exhibit 5-11: Dedicated  Sampling Station	5-14
Exhibit 5-12: Estimated  Costs of Installing a Dedicated Sampling Tap	5-14
Exhibit 5-13: Estimated  Costs to Install a New Booster Pump Station	5-16
Exhibit 5-14: Estimated  Costs to Replace Existing Pump	5-17
Exhibit 5-15: Estimated  Costs to Install a Variable Frequency Drive	5-18
Exhibit 5-16: Estimated  Costs to Install a New Elevated Storage Tank	5-19
Exhibit 5-17: Estimated  Costs to Install a Surge Relief Valve	5-19
Exhibit 5-18: Estimated  Costs to Install a Surge Control Tank	5-21
Exhibit 5-19: Estimated  Costs to Install Automated Flushing Devices	5-22
Exhibit 5-20: Estimated  Costs to Modify Inlet/Outlet Piping	5-24
Exhibit 5-21: Estimated  Costs to Install Mixing Devices	5-25
Exhibit 5-22: Estimated  Costs to Modify Storage Operation	5-26
Exhibit 5-23: Estimated  Costs to Decommission Storage	5-26
Exhibit 5-24: Estimated  Costs for the Inspection and  Cleaning of Storage Tanks	5-27
Exhibit 5-25: Estimated  Costs for the Lining of Storage Tanks	5-28
Exhibit 5-26: Estimated  Costs for the Repair/Replacement of a Storage Tank Vent	5-29
Exhibit 5-27: Estimated  Costs for the Repair/Replacement of a Storage Tank Hatch	5-29
Exhibit 5-28: Estimated  Costs for the Repair of Storage Tanks	5-30
Exhibit 5-29: Estimated  Costs to Install a Permanent Chlorine  Booster Disinfection Station	5-32
Exhibit 5-30: Estimated  Costs to Install a Temporary Chlorine Booster Disinfection Station	5-33
Exhibit 5-31: Estimated  Costs to Install a Permanent Chloramines Booster Disinfection Station	5-35
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Exhibit 5-32: Estimated Costs to Install a Temporary Chloramine Booster Disinfection Station	5-37
Exhibit 5-33: Estimated Costs for a Backflow Prevention Assembly	5-39
Exhibit 5-34: Cost Components of Program Administration for a Cross-Connection Control and Backflow
Prevention Program	5-40
Exhibit 5-35: Estimated Costs for Online Chlorine Monitoring and Programming	5-42
Exhibit 5-36: Estimated Costs for Online Chloramine Monitoring and Programming	5-43
Exhibit 5-37: Estimated Costs for Online Pressure Monitoring and Programming	5-44
Exhibit 5-38: Estimated Costs for Installation of Security Measures	5-45
Exhibit 5-39: Estimated Costs to Develop and Implement an Operations Plan	5-46
Exhibit 5-40: Estimated Costs for Operator Training/Certification	5-47
Exhibit 5-41: Estimated Costs to Maintain an Operations Plan	5-48
Exhibit A-1.1: Current TCR (as implemented) Labor Burden Estimate for Assessments done by NCWSs
serving <= 1,000	1
Exhibit A-2.1: Current TCR (as implemented) Labor Burden Estimate for Assessments done by NCWSs
serving 1,001 -4,100	3
Exhibit A-3.1: Current TCR (as implemented) Labor Burden Estimate for Assessments done by CWSs
serving <= 100	5
Exhibit A-4.1: Current TCR (as implemented) Labor Burden Estimate for Assessments done by CWSs
serving 101 -500	7
Exhibit A-5.1: Current TCR (as implemented) Labor Burden Estimate for Assessments done by CWSs
serving 501 -1,000	9
Exhibit A-6.1: Current TCR (as implemented) Labor Burden Estimate for Assessments done by CWSs
serving 1,001 -4,100	11
Exhibit A-7.1: Current TCR (as implemented) Labor Burden Estimate for Assessments done by CWSs
serving 4,001 -33,000	13
Exhibit A-8.1: Current TCR (as implemented) Labor Burden Estimate for Assessments done by CWSs
serving 33,001  - 96,000	15
Exhibit A-9.1: Current TCR (as implemented) Labor Burden Estimate for Assessments done by CWSs
serving > 96,000	17
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                           List of Acronyms/Abbreviations
Acronym/Abbreviation
AIP
ASDWA
AWWA
AWWARF
BLS
CA
CCCBFP
CO
cy
CWS
DBP
DC
EA
EPA
FACA
FED
FR
ft
FTE
CIS
GPCD
GPM
GSA
GWR
GWREA
HRT
HVAC
ID
IN
in
kgal
KY
gpm
MA
MCL
MGD
mg/L
Ml
MMO/MUG
NCS
NCWS
NOM
NPDWR
Agency/Organization/Definition
Agreement in Principle
Association of State Drinking Water Administrators
American Water Works Association
American Water Works Association Research Foundation
U.S. Bureau of Labor Statistics
California
cross connection control and backflow prevention program
Colorado
cubic yard
Community Water System
disinfection byproduct
District of Columbia
Economic Analysis
U.S. Environmental Protection Agency
Federal Advisory Committee Act
Federal
Federal Register
Feet
full time equivalent
Geographic Information Systems
gallons per capita per day
Gallons per Minute
U.S. General Services Administration
Ground Water Rule
Economic Analysis for the Ground Water Rule
Hydraulic residence time
heating, ventilation, air conditioning
Idaho
Indiana
Inches
Thousand gallons
Kentucky
gallons per minute
Massachusetts
Maximum Contaminant Level
million gallons per day
milligrams per liter
Michigan
minimal medium o-nitrophenyl-beta-D-galactopyranoside
National Compensation Survey
non-community water system
natural organic matter
National Primary Drinking Water Regulations
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NRWA
O&M
OES
OH
PA
psi
PWS
QA/QC
RTCR
SCADA
SDWA
SDWIS/FED
sf
SIC
SM
SOP
TC
TCR
TCRDSAC
TWG
US
USA
USEPA
UV
VFD
WV
National Rural Water Association
operations and maintenance
Occupational Employment Survey
Ohio
Pennsylvania
pounds per square inch
Public Water System
Quality Assurance/Quality Control
Revised Total Coliform Rule
supervisory control and data acquisition
Safe Drinking Water Act
Safe Drinking Water Information System/Federal Version
square feet
Standard Industrial Classification
Standard Methods
Standard Operating Procedures
Total Coliform
Total Coliform Rule
Total Coliform Rule Distribution System Advisory Committee
Technical Work Group
United States
United States of America
United States Environmental Protection Agency
Ultraviolet
variable  frequency drive
West Virginia
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                                  1   Introduction
1.1    Purpose of the Document

       This Technologies and Cost document is one of several technical documents developed in
support of the proposed Revised Total Coliform Rule (RTCR). It describes available
technologies, operational practices, and compliance activities that would be performed by public
water systems (PWSs) in compliance with the proposed rule.  The document also provides
estimated unit costs associated with these technologies, operational practices, and compliance
activities and descriptions of approaches used in developing estimates.

1.2    Background of RTCR

       The U.S. Environmental Protection Agency (EPA) is required to review existing national
primary drinking water regulations every six years. In 2003, EPA completed its review of the
Total Coliform Rule (TCR) and 68 National Primary Drinking Water Regulations (NPDWRs)
for chemicals that were established prior to 1997.  The purpose of the review was to identify
current health risk assessments, changes in technology, and other factors that would provide a
health or technological basis to support a regulatory revision that would maintain or improve
public health protection.  In the Six-Year Review determination published in July 2003, EPA
noticed its intent to revise the TCR.

       In June 2007, EPA established a federal advisory  committee, the Total Coliform Rule
Distribution System Advisory Committee (TCRDSAC), under the Federal Advisory Committee
Act (FACA). One of the goals of convening the TCRDSAC was to make recommendations to
EPA on revisions to the TCR promulgated in 1989 (54 FR 27565, June 29, 1989).

       The TCRDSAC included organizational members selected by EPA based on the diverse
perspectives, expertise, and experience needed to provide balanced recommendations to EPA on
issues related to the TCR and issues related to distribution systems. From July 2007 through
September 2008, the committee met 13 times in Washington, DC. The TCRDSAC considered
the technical and policy issues involved in the monitoring, assessment, and corresponding
corrective actions of problems in the distribution systems to better understand and address public
health impacts from degradation of drinking water quality due to sanitary defects in the
distribution system.  This RTCR applies to all PWSs nationwide.

       The goal of the TCRDSAC in making recommendations on revisions to the TCR is to
achieve the objectives of the 1989 TCR more effectively  and efficiently,  taking into account the
changes in the regulatory framework for implementing the Safe Drinking Water Act (SDWA)
over the past 20 years and the knowledge gained throughout implementation of the 1989 TCR.
The TCRDSAC drew on a variety of data sources  to capture experience with the existing TCR,
on analyses conducted for TCRDSAC, and on the collective experience of the member
organizations.

       In concert with other rules promulgated by EPA under SDWA, the revised rule construct
will better address the TCR objectives and enhance the multiple barrier approach to protecting
public health, especially with respect to smaller groundwater systems. The RTCR paradigm is
designed to trigger systems with positive total coliform (TC)/E. coli monitoring results to do an

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assessment, to identify whether any sanitary defects are present, and to correct such defects
accordingly. This is an improvement over the current TCR framework in that it takes a more
proactive approach to identifying and fixing problems that affect or may affect public health.

       The follow-up actions described in the proposed RTCR also will improve the cost-
effectiveness of the rule as investigations and corrective actions provide an opportunity to
improve public health.  In addition to the corrective actions that might be directly related to total
coliform positive samples in the distribution system, water systems may decide to undertake a
variety of advanced projects to optimize distribution system water quality.  These would
generally require cooperation of multiple departments, including operations, laboratory, water
quality, production, distribution and engineering staff.  Programmatic efforts to optimize
distribution system water quality could include asset management, work-order management and
tracking, mapping and data management using GIS and related databases, hydraulic modeling,
pressure transient modeling, and advanced distribution system monitoring.  Infrastructure
programs such as condition assessment and leak detection could also play a role in a water
quality management effort.  These types of projects require extensive investment in hardware,
software and expertise and often take several years to develop and fully implement. These
advanced distribution system technologies are not specifically addressed in this document.

       For more information on the RTCR including its background, please see the preamble to
the proposed RCTR, provisions and rationale, summary of national costs and benefits, and other
information.

1.3    Document Organization

       This  document is divided into six chapters and one appendix:

       Chapter 1 - Introduction

       This  chapter provides an overview of the RTCR development process, as well as a
       detailed summary of each chapter found in this document.

       Chapter 2 - Estimated Unit Cost of Labor

       This  chapter presents the estimated unit cost of the labor rate.

       Chapter 3 - Estimated Unit Costs of TCR Monitoring Requirements

       This  chapter describes the monitoring requirements under the RTCR based upon system
       characterization. This chapter is not intended to provide guidance for PWS compliance
       with  the RTCR but rather to provide background information relevant to derivation of
       unit monitoring cost.

       Chapter 4 - Estimated Unit Costs of Assessments

       This  chapter describes the estimated cost of realistic examples of specific elements of a
       public water distribution system assessment resulting from compliance with the RTCR.
       Specific assessments required under the RTCR will be determined by the primacy

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       agency.

       Chapter 5 - Estimated Unit Costs of Corrective Actions

       This chapter provides examples of corrective actions and the associated costs that could
       result from deficiencies or sanitary defects as determined by the required assessments
       under the proposed RTCR.

       References

       This section lists the references for the citations used in this document.

       Appendix A - RTCR Labor Burden for Assessments

       The appendix contains tables with labor burden estimates for performing various
       assessments. Tables are broken out by system type i.e. community vs. non-community
       and by the population served.
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                        2  Estimated Unit Costs of Labor

       Much of the burden associated with the proposed RTCR is due to the labor that would be
required to comply with the provisions of the rule including collecting routine and repeat
samples, conducting assessments, and taking follow-up and corrective actions.  The following
labor classes are used to estimate the costs associated with compliance activities:

    •   Water system technical staff
    •   Water system management staff
    •   State field engineering staff
    •   State program office staff

       Other chapters of this document provide estimates of the labor time (burden) that PWS
staff will expend in implementing these management and operational improvements. This
chapter presents the estimated unit cost of this labor burden in terms of a loaded wage rate that
incorporates both what systems and  States pay their staff and an estimate of the dollar value of
benefits associated with their employment.

2.1   Water System Labor Rates

       The unit cost of labor is the wage per unit of time expended in performing compliance
activities.  This section presents estimated labor rates for the labor categories identified above.

       National Analysis of Labor Rates. EPA performed an analysis of available data sources
to derive a nationally representative  set of labor rates corresponding to the primary labor
categories involved in SDWA compliance activities.  The results of this study, Labor Costs for
National Drinking Water Rules (USEPA 2003), have been used in the development of the
economic  analyses of several NPDWRs including the Ground Water Rule (USEPA, 2006).
These documents serve as the basis for the summary of the national labor rates below. The
national labor rates were used by the TCRDSAC in support of the Agreement in Principle (AIP)
signed for the proposed RTCR and consequently will be used to further analyze the national
economic  impact of the proposed RTCR.

       The EPA identified several data sources for water industry-specific labor rates:

          •  Bureau of Labor Statistics, Occupational Employment Survey (OES)
          •  Bureau of Labor Statistics, National Compensation Survey (NCS)
          •  U.S. Census Bureau,  1997 U.S. Economic Census
          •  American Water Works Association (AWWA), Utility Compensation Survey
             (2001)

       These national databases were supplemented with information provided in two EPA
Drinking Water Program databases:  the Safe Drinking Water Information System and the 2000
Community Water System Survey.

       The OES tracked compensation by Standard Industrial Classification (SIC).  Wage data
from two industry classes were particularly relevant to this analysis: SIC 494 - Water Supply,
which contained privately-owned drinking water systems, and SIC 903 - Local Government,
which contained publicly-owned systems (USEPA, 2003).  The NCS collects mean hourly	
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earnings data not by industry but by occupation using a national survey of private and public
establishments. The 2000 NCS sampled 15,840 private sector establishments (including 1,158
establishments in transportation and public utilities) with one or more employees, and 2,489 state
and local governments with 50 or more employees (USEPA, 2003).  The NCS provided an
occupational subgroup, comprised of water and sewer treatment plant operators, that was used to
derive labor rates for technical labor.  Other NCS occupational categories provided data for
managerial, clerical, and administrative labor rates.

       The 1997 Economic Census provided total payroll figures, but did not provide hourly
wage rate or sufficient additional information required to estimate labor rates. The AWWA's
Utility Compensation  Survey provided annual salaries for 44 occupational categories. From
these occupational categories, EPA was able to build hourly wage rates using the corresponding
category salaries and assumptions regarding the number of hours per year worked per employee
in these categories. Wage rates were derived for managerial, technical, and clerical positions
using the occupational category descriptions in the AWWA database. EPA determined, based on
further analysis and response rates, that the AWWA survey database is biased towards the larger
water system size categories.  Therefore, the AWWA-based wage rates were  determined to be
less accurate for smaller sized water systems.

       EPA considered several factors in evaluating whether these data sources provided an
accurate estimate of labor rates. Given the analytical needs of EPA's national regulatory cost
models and data quality considerations, EPA selected the OES-based labor rates as nationally
representative for use  in national economic impact analyses.

       Fringe Benefit Rates.  In developing the unit labor costs, EPA also considered the
additional indirect labor costs associated with fringe benefits paid to water system  employees.
The NCS reported fringe benefits on a per hour basis for select occupational categories.
However, there was not a specific fringe benefit rate corresponding to water industry
occupations. EPA identified fringe benefit rates for suitable occupational categories related to
technical and managerial labor. These fringe benefit multipliers ranged from 1.3 to 1.5 times
direct labor dollar across the establishment size and occupational categories considered. These
rates were applied to the OES-based wage rates to produce fully-loaded labor rates which are
presented in Exhibit 2-1.

       National Labor Rates. Exhibit 2-1 presents unit labor costs for Technical and
Managerial labor categories in 2003$ corresponding to the original EPA labor rate analysis
(USEPA 2003).
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               Exhibit 2-1: Water System Labor Rates by System Size (2003$)
Labor
Category/Rates
Fringe Benefit
Rate1
Technical Wage
Rate
Managerial Wage
Rate
Weighted Labor
Rate2
System Size (Population Served)
25-100
1.3
$21.44
$ 44.36
$21.44
101-500
1.4
$23.09
$47.78
$23.09
501-
3,300
1.5
$24.74
$51.20
$24.74
3,301-10k
1.5
$25.34
$51.20
$30.51
10,001-
100k
1.5
$26.05
$51.20
$31.08
>100k
1.5
$31.26
$51.20
$35.25
    1 Figures represent loaded rates that include a fringe benefit multiplier ranging from 1.3 to 1.5 across size categories.
    2 EPA estimates that systems with population served greater than 3,300 use a combination of operators (technical) and
    engineers (managerial), with an 80/20 ratio between the two, respectively. EPA also estimates that systems serving 3,300
    or less use 100% (technical) labor.
    Source: Economic Analysis for the Final Ground Water Rule (USEPA, 2006), the Stage 2 Disinfectants and Disinfection
    Byproducts Rule (USEPA-1996), and the Long Term 2 Enhanced Surface Water Treatment Rule (USEPA-1996).

       These labor rates were applied to each of the economic analyses supporting the Ground
Water Rule (USEPA-2006), the Stage 2 Disinfectants and Disinfection Byproducts Rule
(USEPA-1996), and the Long Term 2 Enhanced Surface Water Treatment Rule (USEPA-1996).
Systems serving 3,300 people or fewer are assumed by EPA to use only technical labor to
perform RTCR activities (the same assumption that was made for the other rules).  Therefore the
technical rate shown in Exhibit 2-1  applies to these smaller water systems. For systems serving
more than 3,300 people, EPA assumes a ratio of 80 percent technical labor to 20 percent
managerial labor to arrive at a labor cost, or weighted labor rate, of $30.51 for systems serving
3,301-10,000 people, $31.08 for systems serving 10,001-100,000 people, and $35.25 for systems
serving greater than 100,000 people. Exhibit 2-1 also presents these weighted labor rates.

2.2    State Drinking Water Program Personnel Labor  Rates

       The unit labor cost for State staff performing administrative tasks were estimated based
on data from the 2001  State Drinking Water Needs Analysis (ASDWA, 2001). EPA estimated
an average annual  full  time equivalent (FTE) labor cost, including overhead and fringe benefits,
of $70,132 (2003$) which was converted to  an hourly rate of $33.60 assuming an FTE is
equivalent to one person working 2,080 hours per year.  EPA used R.S. Means (1998) data to
establish a wage rate of $31.00 for a field engineer. A 60 percent loading factor was also
assumed to account for the cost of fringe benefits.  When escalated to 2003$, the loaded wage
rate for State field engineering staff was $37.34 per hour.  Exhibit 2-2 presents the State Program
personnel loaded labor rates in 2003$.
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                        Exhibit 2-2: State Program Wage Rates (2003$)
State Labor Category
Field Engineer
Administrative
Labor Cost
$37.34
$33.60
      Source: Economic Analysis for the Final Ground Water Rule (USEPA, 2006), the Stage 2 Disinfectants and
      Disinfection Byproducts Rule (USEPA-1996), and the Long Term 2 Enhanced Surface Water Treatment Rule (USEPA-
      1996).

2.3   Escalated Labor Rates

       The Agency continues to improve the basis from which it estimates the cost of its rules.
Newer data from EPA's own national surveys, updated U.S. Bureau of Labor Statistics (BLS)
data, and other industry surveys are currently under evaluation and are not yet ready to be
incorporated into the Economic Analysis for the proposed RTCR. EPA intends to use these
more recent data sources for the final RTCR.  To ensure these labor rates are presented
consistently with other cost analyses and to present results that reflect current values, EPA has
adjusted the water system and State Program  labor rates to 2007$ using an appropriate labor
price index.  At the time this document was prepared, 2007 was the latest year that a complete
price index was available.

       Water system technical and managerial labor rates were escalated from 2003$ to 2007$
using a BLS Employment Cost Index - Series Index CIU20144000000001 (B), Total
Compensation; Utilities.  An escalation rate was computed using the price index for 4th Quarter
2003 (90.2) and 4th Quarter 2007 (105.2) as follows: 105.2 + 90.2 = 1.17. The escalation rate
was applied to the 2003 labor rates to derive the corresponding 2007 labor rate values. Exhibit
2-3 presents the escalated labor rates for water system labor categories.

               Exhibit 2-3: Water System Wage Rates by System Size (2007$)
Loaded Wage Rate (2007$)
Technical Wage Rate
Managerial Wage Rate
Weighted Labor Rate
System Size (Population Served)
25-100
$25.10
$51.93
$25.10
101-500
$27.03
$55.94
$27.03
501-3,300
$28.96
$59.94
$28.96
3,301 -10k
$29.67
$59.94
$35.72
10,001-100k
$30.50
$59.94
$36.39
>100k
$36.60
$59.94
$41 .27
       Notes:
       1. Figures represent loaded rates that include a fringe benefit multiplier ranging from 1.3 to 1.5 across size categories.
       2. EPA estimates that systems with population greater than 3,300 use a combination of operators (technical) and
       engineers (managerial), with an 80/20 ratio between the two, respectively. EPA also estimates that systems serving
       3,300 or less use 100% (technical) labor.
       3. Labor costs adjusted from 2003 to 2007 dollars using BLS Employment Cost Index, Series Index
       CIU2014400000000I (B), Total Compensation; Utilities.

       Source: Economic Analysis for the  Final Ground Water Rule (USEPA, 2006), the Stage 2 Disinfectants and
       Disinfection Byproducts Rule (USEPA-1996), and the Long Term 2 Enhanced Surface Water Treatment Rule (USEPA-
       1996).

        State program administrative and field engineering staff labor rates were escalated from
$2003 to 2007$ using BLS Employment Cost Index CIS3010000000000I (B) - Total
Compensation, State and Local Government. An escalation rate was computed using the price
index for 4th Quarter 2003 (92.7) and 4th Quarter 2007 (108.2) as follows: 108.2 - 92.7 = 1.17.
The escalation rate was applied to the 2003 labor rates to derive the corresponding 2007 labor
rate values. Exhibit 2-4 presents the escalated labor rates for the State labor categories.
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              Exhibit 2-4: State Program Personnel Wage Rates (2007$)
State Labor Category
Field Engineer
Administrative
Labor Cost
$43.58
$39.22
            Notes:  Labor rates escalated using the BLS Employment Cost Index - Total Compensation State and Local
            Government, CIS30100000000001 (B).
            Source: Economic Analysis for the Final Ground Water Rule (USEPA, 2006), the Stage 2 Disinfectants and
            Disinfection Byproducts Rule (USEPA-1996), and the Long Term 2 Enhanced Surface Water Treatment Rule
            (USEPA-1996).

2.4    Labor Rates for RTCR Alternative Size Categories

       The TCRDSAC Technical Working Group (TWG) analyzed the impact on PWSs using a
modified set of system sizes based on the requirements of the proposed RTCR.  This is because
certain rule provisions differ for systems above or below different population breaks (e.g., those
serving more or less than 1,000, 4,100, or 33,000 people). Exhibit 2-5 presents the number of
systems in each system size category for both the Economic Analysis for the Ground Water Rule
(GWR EA) and the proposed RTCR.

          Exhibit 2-5: Comparison of the Number of Systems in each System Size
                  Category for the GWR EA and the Proposed RTCR
GWR EA Categories
(population served)
<100
101-500
501-3,300
3,301-10,000
10,001-100,000
>100,000
Number of Systems
according to GWR
EA Categories
83,746
42,692
19,204
5,069
3,761
407
Alternative Size
Categories for RTCR
(population served)
<100
101-500
a) 501-1,000
b) 1,001-4,100
a) 1,001-4,100
b) 4,101-33,000
a) 4101-33,000
b) 33,001-96,000
c) >96,000
>96,000
Number of Systems
according to RTCR
Alternative Size
Categories
83,746
42,692
a) 9,498
b) 10,952
a) 10,952
b) 6,498
a) 6,498
b) 1,063
c) 430
430
   Source: 4th quarter freeze from Safe Drinking Water Information System/Federal Version (SDWIS/Fed).

       Exhibit 2-6 presents the water system labor rates using these alternative system size
classifications. These were developed from the weighted labor rates presented in Exhibit 2-3 and
reclassified into the system sizes presented below by weighing the labor rates by the numbers of
systems in each size category outlined in Exhibit 2-5 above.
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         Exhibit 2-6: Water System Labor Rates by TCRDSAC TWG System Size
                                Categories (2007$)
Loaded
Wage Rate
(2007$)
Weighted
Labor Rate
System Size (Population Served)
<100
$25.10
101 -500
$27.03
501 -
1,000
$28.96
1,001 -
4,100
$29.73
4,101 -
33,000
$36.00
33,001 -
96,000
$36.39
>96,000
$41.01
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           3   Estimated Unit Costs of TCR Monitoring Requirements

3.1    Introduction

       The current TCR requires PWSs to test for the presence of total coliforms and either E.
coli or fecal coliform at designated frequencies and locations in the distribution system as part of
the routine, repeat, and additional routine monitoring provisions of the rule.  The proposed
RTCR would remove fecal coliforms as an indicator, but the general framework of monitoring
would remain the same.

       This chapter presents the methodology, data, and assumptions used in developing
estimates of the unit costs of compliance monitoring for both the current TCR and for the RTCR.
The general approach used to develop these estimates was developed by the TCRDSAC  TWG
during the federal advisory committee process in order to approximate relative costs of different
rule options.  EPA further refined this approach to develop the final unit costs presented  in this
document.  Any assumptions that differ from those made by the TCRDSAC TWG are
highlighted. The unit costs and the approach to develop them are presented below.

       The costs presented in this chapter serve as a foundation for making comparisons
between regulatory alternatives developed by EPA. They  are meant to capture national averages
of unit costs and not the unit costs of any  particular system.  Some components  of monitoring
costs, such as the purchase and wear-and-tear of vehicles, were discussed but not quantified here
because of either limited data or inability  to attribute these costs directly to the TCR or RTCR.
Thus, the unit costs presented in this document may over-  or under-estimate the unit costs of any
particular system. The information is meant to be used for evaluation and comparison purposes
at the national level only and not as direct input for system-specific design or budget preparation
for non-EPA entities.

       The following sections of this chapter present unit  cost estimates for each component of
monitoring costs under the RTCR. A concluding section presents a weighted average unit cost
of monitoring. These sections are:

          •  Sample Collection and Delivery
          •  Sample Analysis
          •  Estimated Average Unit Monitoring Costs

3.2    Sample  Collection and Delivery

       Sample collection and delivery unit costs are determined by the labor burden, or
estimated staff time, to collect samples and the cost to deliver the samples to contracted
laboratories (where applicable).  For systems that use in-house labs, no additional delivery cost is
applied. Approved sampling procedures for TC/E1. coli require very short hold times: not more
than 30 hours from the time the sample is collected to the time the sample analysis begins.
Delivery to a contracted laboratory, therefore, requires rapid response on the part of system staff
or lab courier service.  The TCRDSAC TWG discussed sample collection and delivery in detail
during the proceedings of the TCRDSAC. A variety of delivery methods were discussed, each
with a different  cost.  The TWG used available data along with best professional judgment in
assuming the proportions of systems using each delivery method and developing the unit cost
estimates.
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3.2.1   Sample Collection

       Sample collection unit costs include all activities and the time to execute such activities
in the collection of all routine, repeat, and additional routine samples by water system staff.
Proper procedures must be followed to ensure the sample is representative of the distribution
system water quality and is not contaminated during sampling and subsequent handling.  There
are 12 approved methods under the TCR. All methods generally require that the same sample
collection procedure is followed.  The TCRDSAC TWG used best professional judgment to
estimate the labor burden for system staff to take a single sample for compliance with the TCR.
For costing purposes, a simplifying assumption was made that systems collect their own samples
(as opposed to contracting  sample collection).

3.2.1.1 Sample Collection Labor Burden

       The TCRDSAC TWG estimated the time (in hours) to collect a single sample based upon
approved collection procedures and practices, including: gaining access to the sampling site,
disinfection of the sampling tap, sample collection, completion of requisite forms and associated
paperwork, and travel to and from the sampling site. Per-sample labor burden estimates were
informed both by best professional judgment and by estimating the time required for collecting
the total number of samples over a period of time.  For example, a PWS may take 100 TC
samples per month with an estimated total sample collection time for the entire month of 75
hours which would be equivalent to a per-sample burden of 0.75 hours. Per-sample labor burden
was estimated by water system size and included travel and sample collection time based on
approved sample collection procedures.  Larger systems would likely have longer travel  times
between sampling sites compared to smaller systems and therefore greater estimated costs.

       Exhibit 3-1  presents the estimated average sample collection  labor burden for three PWS
population size categories.

    Exhibit 3-1: Estimated Travel and Sample Time by PWS Population  Served
Population Served
<500
501 -96,000
>96,000
Time (hours) required per sample1
0.5
0.75
1.0
                   'Developed by TCRDSAC TWG based on experience and best professional judgment of TWG members.

3.2.1.2  Unit Sample Collection Costs

       Exhibit 3-2 presents the unit cost per sample collected.  These costs, which represent a
total labor cost per sample, were derived by multiplying the labor burden estimates in Exhibit 3-1
and the appropriate staff labor rate for each PWS size category.  The labor rates presented in
Exhibit 3-2 represent technical wage rates originally reported in the Economic Analysis for the
Final Ground Water Rule -USEPA, October 2006. See chapter 2 for a detailed description of
how these labor rates were derived.
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              Exhibit 3-2: Estimated Sampling Collection Cost (2007$)
System Size
A
<100
101-500
501-1,000
1,001-4,100
4,100-33,000
33,001-96,000
>96,000
Labor Rate1
B
$25.10
$27.03
$28.96
$29.73
$36.00
$36.39
$41.01
Sampling Time (hours)*1
C
0.5
0.5
0.75
0.75
0.75
0.75
1.0
Total Labor Cost
D=B*C
$12.55
$13.52
$21.72
$22.30
$27.00
$27.29
$41.01
              'includes travel time between sites and sample collection
              "Estimated by TCRDSAC TWO

3.2.2   Sample Delivery

       EPA considered the various options that PWSs have for delivery of proposed RTCR
compliance monitoring samples to approved laboratories for analysis. These delivery methods
included using a contract lab's courier service or ground next day, standard next day, and priority
overnight shipping options through private delivery companies such as FedEx. Given the
constraint of sample hold times (no more than 30 hours from time sample is drawn to analysis)
and the requirement for a national delivery route, FedEx was deemed to be a reasonable cost
basis.  The derived costs are based on the delivery rates for delivering a package a distance of
100 miles, a distance based on experience of members of TCRDSAC TWG.  The delivery
package is assumed to be a cooler with dimensions of 17" x 12" x 15" sufficient to contain
between one and five samples with ice packs at a single price per shipment (except ground next
day service which varies with package weight). Exhibit 3-3 presents the estimated unit cost for
sample delivery.

        Exhibit 3-3:  Estimated  Sample Delivery Cost Per Shipment (2007$)
Type of Delivery
Lab Courier Service
Ground Next Day1
Standard Next Day1
Priority Overnight1
1 sample
$3.50
$6.65
$38.48
$45.12
2 samples
$3.50
$6.77
$38.48
$45.12
3 samples
$3.50
$6.88
$38.48
$45.12
4 samples
$3.50
$7.00
$38.48
$45.12
5 samples
$3.50
$7.12
$38.48
$45.12
        Source of Cost Quotes: FedEx

       Exhibit 3-4 below presents the shipping cost on a per-sample basis which is applied to
those systems that are permitted to take all of their samples on the same day and to those systems
required to take repeat samples or additional routine samples (and would thus be taking and
delivering multiple samples at the same time). The effect on cost of taking multiple samples
diminishes as the number of samples shipped or delivered simultaneously increases. Thus, the
estimated delivery costs for systems taking more than five  samples simultaneously or grouped
together was assumed to be the same as the costs of shipping or delivering five samples.
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               Exhibit 3-4: Estimated Per-Sample Delivery Cost (2007$)
Type of Delivery
Lab Courier Service
Ground Next Day
Standard Next Day
Priority Overnight
Number of Samples Shipped or Delivered Simultaneously
1
$3.50
$6.65
$38.48
$45.12
2
$1.75
$3.39
$19.24
$22.56
3
$1.17
$2.29
$12.83
$15.04
4
$0.88
$1.75
$9.62
$11.28
5
$0.70
$1.42
$7.70
$9.02
          Note: Per-sample delivery cost is calculated by dividing the delivery cost per shipment in the previous exhibit by the
          number of samples shipped or delivered simultaneously.

       Some systems deliver samples to contract laboratories themselves, sometimes driving
long distances. The cost to these systems to self-deliver will vary based on the distance driven
and the labor rate of the employee delivering the samples. The TCRDSAC TWG discussed the
wide range of distances that are driven by different systems when self-delivering samples by
personally owned vehicles to labs.  Based on best professional judgment and discussions with
industry, EPA estimates that when a system employee delivers the samples to a lab in a
personally owned vehicle, the employee will drive, on average, 15 miles (30 miles round trip).
The estimated costs for sample self-delivery by personally owned vehicle are presented in
Exhibit 3-5.

             Exhibit 3-5: Estimated Cost for Sample Self-Delivery1 (2007$)
System Size
A
<100
101-500
501-1,000
1,001-4,100
4,100-33,000
33,001-96,000
>96,000
Labor
Rate
B
$25.10
$27.03
$28.96
$29.73
$36.00
$36.39
$41.01
Drive Time
(hours)1
C
0.5
0.5
0.5
0.5
0.5
0.5
0.5
Total Labor
Cost
D=B*C
$12.55
$13.52
$14.48
$14.87
$18.00
$18.20
$20.51
Personal Vehicle Use
Reimbursement2
E
$15.15
$15.15
$15.15
$15.15
$15.15
$15.15
$15.15
Total Delivery
Cost
F=D+E
$27.70
$28.67
$29.63
$30.02
$33.15
$33.35
$35.66
'Distance of 15 miles (30 miles roundtrip) and average speed of 60 mph.
Estimated 3/19/2008 using the U.S. General Services Administration (GSA) rate at that time of $0.505 per mile.

       Consistent with the use of a courier or parcel delivery service, the unit cost of self-
delivery of samples decreases as the number of samples per shipment increases.  These bulk
shipment  unit costs are presented in Exhibit 3-6.

       Exhibit 3-6: Per Sample Cost Estimate for Sample Self-Delivery (2007$)
System Size
<100
101-500
501-1,000
1,001-4,100
4,100-33,000
33,001-96,000
>96,000
Number of Samples Shipped or Delivered Simultaneously
1
$27.70
$28.67
$29.63
$30.02
$33.15
$33.35
$35.66
2
$13.85
$14.33
$14.82
$15.01
$16.58
$16.68
$17.83
3
$9.23
$9.56
$9.88
$10.01
$11.05
$11.12
$11.89
4
$6.93
$7.17
$7.41
$7.51
$8.29
$8.34
$8.92
5
$5.54
$5.73
$5.93
$6.00
$6.63
$6.67
$7.13
            Note: Per sample cost delivery cost is calculated by dividing the total delivery cost from the previous
            exhibit by the number of samples being driven simultaneously.
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       The TCRDSAC TWO developed estimates of the percentage of systems using the
different types of sample delivery methods based on its best professional judgment. These
percentages are provided as Exhibit 3-7. These percentages were used along with the other unit
costs above to derive a weighted average unit cost of sample delivery among those systems that
deliver or ship samples to a certified laboratory. The same delivery process was used for all
system sizes that deliver or ship samples.

            Exhibit 3-7: Estimated Percentages1 of Systems Using Each
                               Type of Sample Delivery
Delivery Type
Lab Courier Service Pick-up
Ground Next Day
Standard Next Day
Priority Overnight
Self-Delivery by Car
Percentage of Systems
20%
50%
12.5%
12.5%
5%
                    'Based on best professional judgment of TCRDSAC TWO

       Exhibit 3-8 shows the weighted average unit delivery costs by PWS size category. As an
example calculation to demonstrate how the preceding exhibits come together to form the values
in Exhibit 3-8, consider the average cost to a system serving <100 people to ship one sample.
The cost is calculated as follows:

(0.2 * $3.50) + (0.5 * $6.65) + (0.125 *  $38.48) + (0.125 * $45.12) + (0.05* $27.70) = $15.86

       The percentages (0.2, 0.5, 0.125, 0.125, and 0.05) were obtained from Exhibit 3-7. The
dollar values for all delivery methods, except for self-delivery by vehicle, were obtained from the
first column of Exhibit 3-4.  The first column is used because, in this example, it is specified that
only one sample is being delivered. The dollar value for self-delivery by vehicle was obtained
from the first row and first column of Exhibit 3-6, corresponding to the smallest sized system
shipping only one sample. The dollar values are  multiplied by their corresponding percentages
to derive the weighted average delivery  cost of $15.86.

       As another example, consider the average per-sample cost incurred by a system serving
101-500 persons.  The cost is calculated as follows:

(0.2 * $1.75) + (0.5 * $3.39) + (0.125 *  $19.24) + (0.125 * $22.56) + (0.05 * $14.33) = $7.98.

       In this example, the per-sample costs are drawn from the second columns of Exhibits 3-4
and 3-6 which corresponds to two samples shipped at the same time and resulting in a lower
weighted average per-sample shipping/delivery cost.
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    Exhibit 3-8: Estimated Per Sample Shipping/Delivery Cost as a Function of
                                 System Size (2007$)
System Size
<100
101-500
501-1,000
1,001-4,100
4,100-33,000
33,001-96,000
>96,000
Number of Samples Shi
1
$15.86
$15.91
$15.96
$15.98
$16.13
$16.14
$16.26
2
$7.96
$7.98
$8.01
$8.02
$8.10
$8.10
$8.16
pped or Delivered Simultaneously
3
$5.33
$5.34
$5.36
$5.36
$5.42
$5.42
$5.46
4
$4.01
$4.02
$4.03
$4.04
$4.08
$4.08
$4.11
5
$3.22
$3.23
$3.24
$3.24
$3.27
$3.28
$3.30
3.3    Sample Analysis

       This section briefly describes two analytical methods for simultaneous sample analysis of
TC and E.co//: SM 9223-B (most common) and SM 9222-D membrane filtration (most labor
intensive) and presents an approach for estimating the average unit cost of sample analysis.  The
unit costs of sample analysis are presented in two ways: (1) the cost for those systems that send
out the analysis to a certified contract laboratory and (2) the cost for those systems that perform
the analysis using in-house staff and laboratories.

       Sample analysis costs for systems that contract the services are derived from the
analytical fees charged by certified laboratories.  Systems that perform the sample analyses in-
house are assumed to incur both labor and operations and maintenance (O&M) costs.  O&M
costs are those expenses associated with operating a laboratory and performing an approved
analytical method in-house.  They include the laboratory facility, equipment and maintenance,
supplies such as reagents, glassware and sample containers, as well as lab certification fees.  In
the final section of this chapter, a weighted average sample analysis unit cost is calculated based
upon the percentages of systems conducting sample analysis in-house versus sending samples
out to contract labs.

3.3.1   Available Analytical Methods

       Several common analytical methods exist that provide for simultaneous detection of TC
and E. coli  in single samples. Simultaneous detection is often preferred because it reduces the
total time required for analysis of E. coli, as non-simultaneous methods can require an  additional
24- to 48-hour incubation time for E. coli detection.

       A commonly-used analytical method for simultaneous TC and E. coli analysis utilizes
enzyme substrate technology. Various commercially available formulations are available in
disposable tubes for the multiple tube procedure, in disposable multi-wells or in containers that
will hold 100-ml samples for presence-absence determination.  This type of method can typically
utilize various nutrient indicators to produce a  chromogenic or fluorogenic reaction with natural
enzyme substrates (i.e., p-galactosidase for TC and p-glucorinidase forE.coli).

       Another common simultaneous method utilizes an enriched lactose growth media and an
incubation temperature of 44.5ฐC ฑ 0.2 ฐC for selectivity.  This method requires membrane
filtration of the bacteria with subsequent differentiation ofE.coli. E. coli bacteria are detected by
transferring the membrane after the TC test to a 4-methyl umbelliferyl P-D glucuronide (MUG)
nutrient agar substrate. E. coli bacteria are detected by observing any coliform colonies with a
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fluorescent blue periphery.  The colony forming units counted on each membrane are added
together for a reportable result as number per 100 ml.

       The preamble to the proposed RTCR provides a complete discussion on analytical
methods for detection of total coliforms and E. coli utilized under this proposed rule.

3.3.2  Sample Analysis Cost

       The cost of sample analysis is one of the key components of the overall unit cost of
monitoring.  The cost of sample analysis will vary depending on whether a system contracts the
analysis to a certified laboratory or conducts the analytical methods in-house. The following
sections discuss the approach for determining sample analysis cost for contractor labs versus in-
house labs.

3.3.2.1 Contractor Labs

       Any laboratory that performs analyses for a PWS that is not performing sample analysis
for itself under the TCR is considered to be a contractor laboratory. Typically contract
laboratories are commercial laboratories holding certification in one or more States to perform
sample analysis by approved methods under the TCR.  Some larger PWSs also perform contract
sample analysis typically for smaller systems.  Some States also provide analytical support
services to PWSs.

       Contract laboratories normally bid on annual contracts to perform compliance sample
analysis for PWSs. Purchasing requirements typically include state or primacy  agency
certification and sample analysis unit cost for each contracted method. Sample analysis fees may
also include sample pick-up. Contractor laboratory fees include direct labor and overhead as
well as O&M. Therefore, no estimates of direct labor or O&M are required to  determine the
direct cost to a PWS for contracted sample analysis.

       Information for sample analysis costs for each of the two commonly performed methods
described previously for simultaneous analysis of TC andE. coli was reviewed to estimate
average contractor lab analytical fees.  This data is presented below in Exhibit 3-9.

       Based on the best professional judgment and experience of the TCRDSAC TWO and
EPA, the majority of systems employ substrate methods (e.g., SM 9223 B) rather than membrane
filtration methods (e.g., 9222 D). Thus, the estimated unit costs of monitoring  presented at the
end of this chapter assume the use of substrate methods. However, the contractor lab fees for
both SM 9223 B and SM 9222 D are presented in Exhibit 3-9 to allow the reader to compare
costs between the two methods.  The data were derived from an informal survey of nine
commercial laboratories in April 2008. Only four of the laboratories contacted were certified to
perform both methods.  As a simplifying assumption the TCRDSAC TWO assumed the
analytical pricing was equivalent to 2007 costs.

       Although not explicitly discussed here, contracted lab fees may also include the cost of
reporting to the primacy agency. Certain States require the laboratory performing the analysis to
also perform the reporting function.
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  Exhibit 3-9: Common TC and E. coli Analytical Methods and their Average Contractor
                               Lab Analytical Fee (2007S)1
Lab
(Location)
CA
KY
OH
IN
CA
NY
Ml
NY
WV
Average
Analytical Method
SM 9223 B
$18.00
$25.00
$15.00
$25.00
$20.00
$25.00
$30.00
$18.00
$23.25
$22.13
SM 9222 D
$27.75
$35.00
$25.00
$30.50

$29.56
                     'Based on 2008 data from nine laboratories across the United States.

3.3.2.2 In-house Analysis

       Water systems serving a population greater than 33,000 persons typically perform sample
analysis in-house.  Larger systems are more likely to have the staff, equipment, and facilities
required to hold certifications and perform analysis for one or more of the approved methods
under the TCR. The cost of sample analysis performed in-house should also account for O&M
costs which can include equipment and maintenance such as incubators, UV lights, glassware,
miscellaneous lab equipment and supplies, as well as perishables including reagents, sampling
containers, etc. Certification fees must also be included in O&M costs. Certification fees can be
highly variable and may range from a few hundred dollars to several thousand dollars a year.
Some States,  Indiana for example, do not have laboratory certification fees.  Certification fees
are typically based upon specific methods performed or by analyte groups such as  inorganics,
organics, or microbiology. Certification requirements are also specific with regard to facilities,
equipment, and staff.  Laboratory work stations must be properly maintained with  adequate
facilities, be of an adequate size, and possess safety equipment including safety showers,
eyewash stations, and hoods.  All of these items must be included in O&M costs.

       For purposes of this document, EPA is applying the same estimate for O&M costs
($8.95) that was used in the GWR EA escalated to 2007 dollar values ($10.09).  In addition to
O&M, labor burden was considered a key criterion for estimating cost for sample analysis
performed in-house.  The TCRDSAC TWO agreed that 0.5 hours per sample was a reasonable
estimate for labor burden.  The site-specific technical labor rate was also considered as a key
component to the estimation of sample analysis cost. Again, the TWG agreed to use the labor
rates from the GWR EA adjusted to 2007 dollars. Exhibit 3-10 demonstrates the estimated
sample cost for analysis performed in-house.
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         Exhibit 3-10: Estimated Sample Cost for In-House Analysis (2007$)
System Size
A
<100
101-500
501-1,000
1,001-4,100
4,100-33,000
33,001-96,000
>96,000
Labor Rate
B
$25.10
$27.03
$28.96
$29.73
$36.00
$36.39
$41.01
Labor Burden (hours)
C
0.5
0.5
0.5
0.5
0.5
0.5
0.5
O&M
D
$10.09
$10.09
$10.09
$10.09
$10.09
$10.09
$10.09
Total Labor Cost
E=B*C+D
$22.64
$23.61
$24.57
$24.96
$28.09
$28.29
$30.60
3.4    Estimated Average Unit Monitoring Costs

       This chapter has presented the methodology, data, and assumptions used in developing
estimates of the unit costs of compliance monitoring for both the current TCR and for the
proposed RTCR based on whether the system uses a contract lab or tests samples in-house. The
general approach used to develop these estimates is the same that was used by TCRDSAC TWO
during the federal advisory committee process in order to approximate relative costs of different
rule options.  The components of unit monitoring costs are as follows:

       For in-house sample analysis:

                 •  Sample collection
                 •  Sample analysis

       For contract lab sample analysis:

                 •  Sample collection
                 •  Shipping/delivery
                 •  Lab fee

       Unit costs were derived for both of these monitoring approaches and for each of the
different system size categories. A weighted average for sample analysis cost incorporating both
in-house and  contractor sample analysis cost is presented. This weighted average is based on the
estimated percentage of systems using in-house versus contractor labs and is shown in Exhibit 3-
11. Large systems typically have the staff, facilities and equipment required to obtain
certifications  and perform one or more of the approved analytical methods.  Small systems
typically contract a certified laboratory to perform the sample analysis.  The assumptions
presented in Exhibit 3-11 demonstrate that systems serving 33,000 persons or less contract 100
percent of their sample analysis to a certified laboratory.  Systems serving between 33,001 and
96,000 persons are equally divided between using in-house labs and using contractor labs. For
the largest systems, those serving >96,000 persons, 90 percent are assumed to use an in-house
laboratory and 10 percent to use contract labs.  These percentages were used to derive the
weighted average unit monitoring cost of in-house and contract labs for the different size
categories presented in Exhibit 3-12.
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 Exhibit 3-11: Percentage of Systems Using In-House vs. Contracted Laboratories
System Size
<100
101-500
501-1,000
1,001-4,100
4,100-33,000
33,001-96,000
>96,000
Percent Using
In-House Laboratory
0%
0%
0%
0%
0%
50%
90%
Percent Using
Contract Laboratory
1 00%
1 00%
1 00%
1 00%
1 00%
50%
10%
              'Developed by TCRDSAC TWG based on the experience of the group and best professional judgment.

       An example calculation is presented below to demonstrate the source of the data
presented in Exhibit 3-12.  Consider a system serving 33,001-96,000 persons that takes five
samples simultaneously. As presented in Exhibit 3-12, the estimated average unit cost of
monitoring (per sample cost) is $54.14.
                                        Unit cost for contract lab
                                    f                        \
        0.5 * ($27.29 + $28.29) + 0.5 * ($27.29 + $3.28 + $22.13) = $54.14
             _ _ _
                    Y
            Unit cost for in-house
       0.5 =         Percentage of systems in this size category using in-house labs and
                    percentage of systems in this size category using contract labs (from
                    Exhibit 3-11)
       $27.29 =     Sampling cost (from Exhibit 3-2)
       $28.29 =     In-house analytical cost (labor + O&M) (from Exhibit 3-10)
       $3.28 =      Average per-sample shipping cost for a system in this system size when
                    collecting 5 samples at once (from Exhibit 3-8)
       $22.13 =     Average lab fee to test one sample for TC/E1. coli using substrate method
                    (from Exhibit 3-9)

          Exhibit 3-12: Estimated Average Unit Cost of Monitoring (2007$)
System Size
<100
101-500
501-1,000
1,001-4,100
4,100-33,000
33,001-96,000
>96,000
Number of Samples Taken Simultaneously
1
$50.54
$51.55
$59.81
$60.40
$65.26
$60.57
$72.38
2
$42.64
$43.63
$51 .86
$52.45
$57.23
$56.55
$71.57
3
$40.01
$40.99
$49.21
$49.79
$54.55
$55.21
$71.30
4
$38.69
$39.67
$47.88
$48.47
$53.21
$54.54
$71.17
5
$37.90
$38.87
$47.09
$47.67
$52.40
$54.14
$71.09
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                     4   Estimated Unit Costs of Assessments
       The current federal requirements of the TCR do not include assessments of PWSs
following nonacute violations or acute violations.  However, under the current TCR, as it is
actually implemented, many systems are either conducting some level of assessments themselves
or receiving some level of assessments from States following Maximum Contaminant Level
(MCL) violations.  This chapter estimates the level of effort currently incurred by systems to
conduct assessments following TCR MCL violations under the current TCR, as implemented. In
addition, the chapter provides an overview of the assessment provisions proposed as part of
RTCR and their associated costs for drinking water systems. The cost estimates presented in this
chapter were informed by input from States and industry received during the proceedings of the
TCRDSAC. They are described in more detail later in the chapter.  State costs associated with
assessments are included in the RTCR Economic Analysis.
       This chapter is organized into three sections. Each section builds on the previous section
to describe how the unit costs incurred by systems to perform assessments were estimated. The
three sections are as follows:

    1.  Overview of Assessments
    2. Elements of Assessments
    3. Unit Cost Estimates of Assessments

4.1    Overview of Assessments

       The purpose of performing assessments is to proactively enhance public health protection
by identifying the presence of "sanitary defects" and defects in distribution system coliform
monitoring practices.  EPA believes that assessments will strengthen the drinking water system's
capacity to ensure that barriers to intrusion or contamination are in  place and effective.  The
proposed assessment triggers represent a significant improvement over the current TCR
paradigm in that sampling results will trigger an assessment to take a closer look at the  system
and to identify whether one or more sanitary defects are present. This is a more proactive
approach than the current TCR and will lead to the identification and correction of problems that
may compromise public health. The RTCR includes two levels of assessments: Level  land
Level 2.  For either Level 1 or 2 assessments, the PWS will complete the assessment as soon as
practicable after notification of their monitoring results. The PWS will provide the primacy
agency a complete Level 1 or 2 assessment report within 30 days after notification of exceeding
the trigger.

      EPA proposes that minimum elements of both Level 1 and 2 assessments should include
a review and identification of the following:

    1. Inadequacies in sample  sites, sampling protocol, and sample processing

    2. Atypical events that may have affected distributed water quality or indicate that
       distributed water quality was impaired
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    3.  Changes in distribution system maintenance and operation that may have affected or are
       affecting distributed water quality including water storage

    4.  An evaluation of source water quality and treatment changes or conditions that may
       affect distributed water quality, where appropriate (e.g., small ground water systems)

    5.  Existing water quality monitoring data

       Appendix X of the AIP contains forms that serve as examples of Level  1 and 2
assessments.  These forms are intended as conceptual examples to describe practical expectations
for the level of resources committed to undertaking a Level 1 or 2 assessments.  Assessments
conducted under the RTCR should reflect the substance and effect of the elements of these
example Level  1 and 2 assessment checklists. The following two sections describe the Level 1
and Level 2 assessments in more detail.

4.1.1   Level 1 Assessments

       The Level 1 assessment will consist of a simple examination of the system and relevant
operational practices. The Level 1 assessment is intended as a self-assessment (EPA anticipates
that these  will be completed by the PWS and reviewed by the primacy agency). If the primacy
agency determines the assessment report insufficient, it will consult with the PWS.

       A Level 1 assessment is triggered if sampling results in one of the following:

    1.  For systems collecting 40 or more samples per month, the PWS exceeds 5.0% TC
       positive samples for the month; or

    2.  For systems collecting fewer than 40 samples per month, the PWS has two or more TC-
       positive samples in the same monitoring period; or

    3.  Failure to collect every required repeat sample after a single TC-positive sample.

       The assessment report will identify sanitary defects detected, corrective actions
completed, and a timetable for any corrective actions not already completed. The assessment
report may also note that no sanitary defects were identified.  Upon completion and submission
of the assessment report by  the PWS, the primacy agency will determine if the system has
identified  a likely cause for the Level  1 trigger and establish whether the system has corrected
the problem.

4.1.2   Level 2 Assessments

       A Level 2 assessment is a more detailed examination of the system, its monitoring
program and results, and its operational practices. It is comprised essentially of the same
elements as a Level 1 assessment, but each element is investigated in greater detail.  The level of
effort and resources required to implement the Level 2 assessments will be commensurate with a
more comprehensive investigation, a higher level review of available information, and may
involve the engagement of additional parties and expertise.
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       A Level 2 assessment is triggered if sampling results in any of the following:

    1.  An acute violation as determined by an E. coli MCL violation; or

    2.  An E. coli monitoring violation (defined as failing within 24 hours to collect repeat
       samples following an E. co//-positive sample); or

    3.  A second Level 1  trigger, within a rolling 12 month period, unless the primacy agency
       has determined a likely reason that the initial Level 1 samples were TC-positive and
       establishes that the system has corrected the problem; or

    4.  For systems with approved reduced annual monitoring, a Level  1 trigger in two
       consecutive years.

       EPA anticipates that the system burden incurred by conducting Level 2 assessments
following triggers associated with the presence of E. coli (referred to later in this document as
Level 2 [acute]) may be higher than the system burden incurred by conducting Level 2
assessments following triggers in which there is not E. coli (referred to later in this document as
Level 2 [nonacute]).

       Level 2 assessments will be conducted by the PWS, where the system has staff or
management with the certification or qualifications specified below, unless otherwise directed or
approved by the primacy  agency:

    1.  A certified operator with a minimum of two (2) years of experience as a certified operator
       in systems requiring similar or more extensive certification requirements, or

    2.  Individuals with equivalent training or experience as approved by the primacy agency.

       As with the Level 1 assessment report, the Level 2 assessment report will identify
sanitary defects detected, corrective actions completed,  and a timetable for any corrective actions
not already completed. The assessment report may also note that no sanitary defects were
identified. Upon completion and submission of the assessment report by the PWS, the primacy
agency will determine if the system has identified a likely cause for the Level 2 trigger and
establish whether the system has corrected the  problem. If the primacy agency determines that
the Level 2 assessment report is insufficient, it will consult with the PWS and, if necessary,
provide assistance or require appropriate action.
       The cost associated with the State conducting the assessment will be considered in the
economic analysis in addition to other State implementation costs. In this document, only the
costs incurred by systems are considered.

4.2    Elements of Assessments

       The TCRDSAC TWG discussed the various elements that assessments would likely
encompass including those that are currently implemented by  some systems and States under the
existing TCR. This list of elements was based on the collective experience and best professional
judgment of TCRDSAC TWG members and their colleagues.  They are summarized in Exhibit
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4-1 below and described further in the sections that follow. The list is not intended to represent
required elements of an assessment and should not be interpreted as such. Rather, the list is an
interpretation by the TCRDSAC TWG of both what is occurring under the existing TCR and of
what is anticipated to occur under the revised TCR and is meant to provide estimates of system
labor burden associated with assessments. The different types of assessments are made up of the
same elements, but the degree to which the elements are implemented varies. Because of
differences among systems and States, EPA anticipates that primacy agencies will tailor specific
assessment elements to the size and type  of a water system and that PWSs will adapt their
assessment activities based on the characteristics of the distribution system.  The actual
assessment costs will  be highly dependent upon the specific system characteristics and the
primacy agency requirements.

 Exhibit 4-1: Summary of TCRDSAC TWG Investigative Spreadsheet Assessment
                                      Elements
Element
Notification Element
System Specific Element
Sample Analytical Element
Sample Methodology Element
Event Situational Element
Operational Data Element
Historical Trend Element
Sample Tap Element
Sample Site Element
Sample Area Element
Third Party Element
Report Element
Description
Notification of the state authority. Includes time for the system to review
sample data, notify superiors, and contact state authority.
Includes time for personnel to gather system specific information (system
ID, size, active sources, sample site plan, etc.) if necessary.
Evaluate Lab Quality Assurance/Quality Control (QA/QC). Includes time
for systems with labs to evaluate QA/QC procedures or for systems
without labs to call contract lab with questions.
Includes time for personnel to evaluate whether proper sampling and
sampling handling techniques were used and to identify and note any
deviations.
Includes time for personnel to review and evaluate any significant
system events that may have influenced the sample(s) (main breaks,
main repair, pressure events, treatment problems, source water
changes, weather events, etc.).
Includes time for personnel to compile other data that may be important
to the event (such as chlorine residual, other water quality parameters,
treatment parameters), if available.
Includes time for personnel to review the history of samples in the
system and at the site in question.
Includes time to inspect and evaluate the condition of the sampling
tap(s).
Includes time to inspect and evaluate the facility in which the sample was
taken.
Includes time to inspect and evaluate other positive follow-up samples (if
applicable) away from the original site.
Includes time for contracting with a third party consultant.
Includes time for the personnel to complete the report and provide the
results to state authority.
       The sections that follow describe the elements in more detail and include some of the
assumptions discussed by the TCRDSAC TWG that helped to inform that cost estimates
associated with each one.  These elements differ in some respects with the elements contained in
the example assessment forms provided in Appendix X of the AIP. However, most of the
elements are equivalent or contain significant overlap, and while the investigations spreadsheet
was developed to provide a basis for the cost estimate developed by the TCRDSAC TWG to
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perform Level 1 and 2 assessments, the assessment forms found in Appendix X of the AIP are
intended to be used as investigation concept examples for performing assessments.

4.2.1   Notification Element

       The Notification Element involves notification of monitoring results to the state
authority.  Cost estimates are based on the time for sample data review, notification of superiors,
state authority contact, and external advisor contact for guidance. Sample data review includes
preparing information relevant to recent monitoring and the violation for dialog with the State,
and a review of state code and guidance for the situation.  Notification of superiors assumes
contact within the chain of command extending to a local government entity.  State authority
contact assumes the State maintains a 24-hour call center or accepts email or fax communication.
Under external advisor contact, after determining that a threshold has been exceeded, it is
assumed that the system manager will contact a contract engineer, a colleague, National Rural
Water Association (NRWA) Rider, or state employee to assess the implication or significance of
the violation.

       Normally, notification is limited to monthly filing of RTCR routine monitoring report
and information related to the triggering of a Level 1  or 2 assessment would be provided by the
system to the State in the  routine monitoring report.

4.2.2   System Specific Element

       The System Specific Element includes personnel time to gather system specific
information, such as system ID,  size, active sources, a description of the sample site plan, etc.
Cost estimates assume that this information is available and that if it is not compiled yet, some
time will be spent gathering the information and  checking against previous permits and
submissions to state authorities.  Subsequent reporting will require minimal time to fulfill this
element. Systems serving at least 4,100 customers will usually spend more time gathering
information for this element because they typically have more complex community water system
(CWS) identification assignments, retail and wholesale relationships, etc., which will need to be
reviewed to properly associate positive sample sites to CWS identifiers.

4.2.3   Sample Analytical Element

       The main purpose of the  Sample Analytical Element is to  document and evaluate
laboratory QA/QC.  Cost  estimation assumes the State will provide this information for systems
serving 1,000 or fewer customers. The estimated time burden for larger systems may include
evaluating QA/QC procedures, or for systems without a laboratory, time to contact contract
laboratories to obtain QA/QC information.

4.2.4   Sample Methodology Element

       The Sample Methodology Element includes the time to evaluate whether proper sampling
techniques were used and whether proper sample handling procedures were followed.  Any
deviations are identified, documented, and corrected.  Cost estimates for systems serving 1,000

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customers or fewer are based on time spent contacting an external advisor to evaluate the
situation and to determine or receive confirmation on the steps to follow, as well as time for a
review of procedures and equipment.  Cost estimates for systems serving more than 1,000
customers include time for communication between a technician and a manager to evaluate
whether proper sampling techniques were used, time for a review of proper procedures, and will
likely involve time for a discussion with external advisors, such as a laboratory and the State.
Adherence to proper sample handling techniques is also evaluated, so this step could occur
concurrently with the initial evaluation. Some additional time will be devoted towards preparing
handouts to guide and support the discussion, such as current sample handling, Standard
Operating Procedures (SOPs), and methods (such as Standard Methods or EPA methods). Time
will also be needed to identify and correct any deviations from established sampling and sample
handling protocol.

4.2.5   Event Situational Element

       Event Situational Elements include a review of any significant system events that may
have influenced the samples. These may include main breaks, main repairs, pressure events,
treatment problems, source water changes, power outages, distribution system operations (such
as flushing), weather events, or vandalism. Cost estimation was based on the time needed to
match specific sampling dates with specific event dates. In addition, this review may require
interacting with non-water system personnel, such as construction crews.  Time required will
increase with increasing size and complexity of the system (multiple sources, larger distribution
systems, etc.). For systems serving 4,100 customers and larger, additional time was allotted to
evaluate the information collected through the review process and to evaluate the significance of
this information.

4.2.6   Operational Data Element

       The Operational Data Element involves collecting other data that may have influenced
the sample, such as chlorine residual,  other water quality parameters, and treatment parameters.
The information collected is evaluated through a review process to determine whether it may
have affected water quality at the time and location of sampling.  Time estimates consider that
the review is taking place at the end of the month and therefore specific data collected will have
to be matched to specific sampling events.  Aside from those associated with a significant effect
on operations, treatment problems will likely not be recognized without reviewing available data
from wells or treatment facilities to link changes in performance to specific results of collected
samples. Cost estimates for this element also assume some time spent evaluating the
significance of the data collected through a review process.

4.2.7   Historical Trend Element

       The Historical Trend Element includes time for personnel to review the history of
samples in the system, and a review of the history of samples at the site in question. Each of
these review phases is further subdivided into three phases for time estimation purposes: data
compilation, summarization, and evaluation.  Data compilation includes compiling data
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associated with collected TC samples for trend analysis, such as sources in production, tank
release patterns, and water quality parameters.

4.2.8   Sample Tap Element

       The Sample Tap Element involves an inspection and evaluation of the condition of the
sampling tap. In addition, some time is allotted to evaluate the condition of the sampling taps.
These time estimates were consistent across all trigger levels.

4.2.9   Sample Site Element

       The Sample Site Element includes the time for an inspection and evaluation of the facility
in which the sample was collected. For most utilities, there will likely be limited opportunities to
make any changes to the facility where the sample tap is located. Therefore, the focus will be on
the sample tap and associated plumbing.

4.2.10  Sample Area Element

       The Sample Area Element is included if positive follow-up samples are present at other
locations away from the original sample site. This assessment may include some or all of the
above elements (such as Sample Tap and Sample Site Elements), and also includes inspection of
valves and tanks.

4.2.11  Third Party Element

       This element includes time for contracting with a third party consultant: identification of
contractor options, drafting a scope, procurement review, management review, governing board
approval, proposal distribution, proposal review, management review of proposals, drafting a
contract, financial and legal review, dialog with State, and governing board approval. With
increasing system size, some additional time is devoted towards management review of
proposals and the financial and legal review.

4.2.12  Report Element

       A report of the results of the assessment performed by the PWS in response to a trigger
will need to be completed and submitted to the state authority.  The cost estimate is based  on
time to complete the report, a chain of command review, and possibly a legal review and
briefing.

4.3  Unit Cost Estimates of Assessments

4.3.1   Methodology

       The cost estimates presented in this chapter were informed by input from States and
industry received during the proceedings of the TCRDSAC and the associated  TCRDSAC TWG
meetings.  Specific cost estimates are provided for each system type, either a CWS or non-
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community water system (NCWS), on the size categories presented in Exhibit 4-2 and for the
triggers listed in Exhibit 4-3.  For each of the elements presented in Exhibit 4-1, an estimate is
made for:  (1) the percentages of systems that currently spend time on that element (under the
existing TCR, as implemented) or the percentage of systems that are anticipated to spend time on
that element (under the RTCR) and (2) the number of hours that are currently spent on that
element (under the existing TCR, as implemented) or the number of hours that are anticipated to
be spent on that element (under the RTCR).  The product of (1) and (2) is taken for each element
and these products are summed to calculate the estimated average labor burden incurred by a
given system type/size for a given type of assessment. This approach recognizes the differences
in responses to the various triggers  and system size/type categories and the differences between
what is happening under the existing TCR, as implemented, and what is anticipated to happen
under the RTCR.

           Exhibit 4-2: Categories for which cost estimates are developed
                                  NCWS <1,000
                                  NCWS 1,001-4,100
                                  NCWS 4,101-33,OOP
                                  NCWS 33,001-96,000
                                  NCWS >96,000
                                  CWS<100
                                  CWS 101-500
                                  CWS 501-1,000
                                  CWS 1,001-4,100
                                  CWS 4,100-33,OOP
                                  CWS 33,001-96,000
                                  CWS >96,000
            Exhibit 4-3: Violations and triggers leading to assessments
                            Current TCR, as implemented
                               Nonacute MCL Violation
                               Acute MCL Violation
                            RTCR
                               Level 1 Trigger
                               Level 2 Trigger (Nonacute)
                               Level 2 Trigger (Acute)
       As an example, consider the labor burden estimates for the existing TCR, as
implemented, incurred by CWSs serving between 1,001 and 4,100 people. Exhibit 4-4 includes
the elements that might make up an assessment and how the percentages of systems
implementing those elements and the labor hours associated with those elements vary depending
on the type of MCL violation. The exhibit indicates that, on average, under the existing TCR as
it is implanted now, 22 system labor hours are spent on assessment activities following a
nonacute MCL violation and 29 system labor hours are spent on assessment activities following
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an acute MCL violation. Some systems spend more time that this on assessments and some
spend less.  This methodology is meant to capture the average for the purposes of developing
national cost estimates for the comparison of rule options.

       Exhibit 4-4: Current TCR (as implemented) Labor Burden Estimate for
                 Assessments done by CWSs serving 1,001-4,100


Notification
Element
System
Specific
Element
Sample
Analytical
Element
Sample
Methodology
Element
Event
Situational
Element
Operational
Data Element
Historical
Trend
Element
Sample Tap
Element
Sample Site
Element
Sample Area
Element
Third Party
Consulting
Element
Report
Element
Total
Nonacute MCL Violation
Percentage
of Systems
performing
Element
A
100%
100%
0%
80%
10%
60%
100%
80%
5%
30%
0%
100%

Estimated
Hours
Associated
with
performing
Element
B
3
1
0
3
5.5
4
3
1.5
2
4
0
7.5

Average
Burden
Associated
with
Element
(hrs)
C = A*B
3
1
0
2.4
0.55
2.4
3
1.2
0.1
1.2
0
7.5
22.35
Acute MCL Violation
Percentage
of Systems
performing
Element
D
1 00%
1 00%
0%
80%
100%
60%
1 00%
100%
100%
5%
0%
100%

Estimated
Hours
Associated
with
performing
Element
E
3
1
0
3
5.5
4
3
2
2
3
0
7.5

Average
Burden
Associated
with
Element
(hrs)
F = D*E
3
1
0
2.4
5.5
2.4
3
2
2
0.15
0
7.5
28.95
March 2009 Revised Total Coliform Rule
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       As a second example, consider NCWSs serving < 1,000 conducting assessments under
the RTCR. The elements and estimates of percentages of systems implementing the elements
and labor hours associated with implementing the elements are presented in Exhibit 4-5.  The
exhibit indicates that, on average, 7, 9, and 21 system labor hours are anticipated to be spent on
Level 1, Level 2 (nonacute), and  Level 2 (acute) assessments, respectively.  Recall that for the
purposes of this document, a Level 2 (acute) assessment refers to a Level 2 assessment that is
associated with the presence of E. coli while a Level 2 (nonacute) assessment is not associated
with the presence of E. coli.  Based on input from industry and States, EPA believes that the
system burden associated with conducting a Level 2 assessment will likely vary depending  on
whether there is E. coli present.
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            Exhibit 4-5: RTCR Labor Burden Estimate for Assessments done by NCWSs serving <1,000


Notification
Element
System
Specific
Element
Sample
Analytical
Element
Sample
Methodology
Element
Event
Situational
Element
Operational
Data Element
Historical
Trend Element
Sample Tap
Element
Sample Site
Element
Sample Area
Element
Third Party
Element
Report
Element
Total
Level 1 Assessment
Percentage of
Systems doing
Element
G
100%
0%
0%
50%
100%
60%
100%
100%
100%
100%
0%
100%

Estimated
Hours
Associated
with Element
H
0
0
0
1
1
0.3
0.5
1
1
1
0
2

Average
Burden
Associated with
Element (hrs)
I = G* H
0
0
0
0.5
1
0.18
0.5
1
1
1
0
2
7.18
Level 2 Assessment (nonacutej
Percentage of
Systems doing
Element
J
100%
100%
100%
100%
100%
40%
100%
100%
100%
100%
0%
100%

Estimated
Hours
Associated
with Element
K
0.5
0.3
0
0.5
2
0.5
0.5
1
1
1
0
2

Average
Burden
Associated with
Element (hrs)
L = J* K
0.5
0.3
0
0.5
2
0.2
0.5
1
1
1
0
2
9
Level 2 Assessment (acute)
Percentage of
Systems doing
Element
M
100%
100%
100%
100%
100%
40%
5%
100%
100%
20%
50%
100%

Estimated
Hours
Associated
with Element
N
2
1
1
1
2
1
4
1
1
7
16
2

Average
Burden
Associated with
Element (hrs)
O = M* N
2
1
1
1
2
0.4
0.2
1
1
1.4
8
2
21
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       Exhibit 4-6 summarizes the labor burden associated with conducting assessments for all
of the system categories and types of triggers, both under the existing TCR and the proposed
RTCR. Exhibit 4-7 presents the monetary burden. Labor hours in Exhibit 4-6 are multiplied
with the hourly labor rates presented in chapter 2 of this document to calculate the monetary
burden in Exhibit 4-7.  Appendix A includes detailed tables with the elements of assessments,
percentages, and hours (similar to Exhibit 4-4 and 4-5) for all system type/size categories.

    Exhibit 4-6: Estimated Labor Burden Associated with Assessments (hours)
System Type/Size
NCWS <1 ,000
NCWS 1,001-4, 100
NCWS 4,101-33,000
NCWS 33,001 -96, 000
NCWS >96,000
CWS<100
CWS101-500
CWS 501 -1,000
CWS 1,001 -4, 100
CWS 4, 100-33,000
CWS 33,001 -96,000
CWS >96,000
Current TCR, as
implemented
Nonacute
MCL
Violation
4
4
30
59
108
11
11
13
22
30
59
108
Acute
MCL
Violation
6
6
36
75
117
14
14
15
29
36
75
117
Proposed RTCR
Level 1
Trigger
7
8
41
68
159
19
19
20
31
41
68
159
Level 2
Trigger
(nonacute)
9
10
69
116
238
22
22
23
46
69
116
238
Level 2
Trigger
(Acute)
21
29
71
121
252
23
23
24
48
71
121
252
    Exhibit 4-7: Estimated Labor Burden Associated with Assessments (2007$)
System Type/Size
NCWS <1 00
NCWS 101 -500
NCWS 501 -1,000
NCWS 1,001-4,100
NCWS 4,1 01-33,000
NCWS 33, 001 -96, 000
NCWS >96,000
CWS <1 00
CWS 101-500
CWS 501 -1,000
CWS 1,001-4,100
CWS 4,1 00-33,000
CWS 33,001 -96, 000
CWS >96;000
Current TCR, as
implemented
Nonacute
MCL
Violation
$100.40
$108.12
$115.84
$118.92
$1,080.00
$2,147.01
$4,429.08
$276.10
$297.33
$376.48
$654.06
$1,080.00
$2,147.01
$4,429.08
Acute
MCL
Violation
$150.60
$162.18
$173.76
$178.38
1,296.00
2,729.25
4,798.17
$351.40
$378.42
$434.40
$862.17
1,296.00
2,729.25
,798.17
Proposed RTCR
Level 1
Trigger
$175.70
$189.21
$202.72
$237.84
$1,476.00
$2,474.52
$6,520.59
$476.90
$513.57
$579.20
$921.63
$1,476.00
$2,474.52
$6,520.59
Level 2
Trigger
(nonacute)
$225.90
$243.27
$260.64
$297.30
$2,484.00
$4,221.24
$9,760.38
$552.20
$594.66
$666.08
$1,367.58
$2,484.00
$4,221.24
$9,760.38
Level 2
Trigger
(Acute)
$527.10
$567.63
$608.16
$862.17
$2,556.00
$4,403.19
10,334.52
$577.30
$621 .69
$695.04
$1,427.04
$2,556.00
$4,403.19
10,334.52
March 2009 Revised Total Coliform Rule
Technology and Cost Document
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4.3.2  Assumptions

       Several underlying assumptions were made for the cost estimation development as
       follows:

       •  The costs estimates presented in this chapter and the assumptions that support those
          estimates were informed by input from States and industry received during the
          proceedings of the TCRDSAC and the associated TCRDSAC TWO meetings.

       •  Estimated percentage of systems undertaking actions is a function of estimated value,
          expertise at different system sizes, and available resources.

       •  As system size increases, there is an increasing level of expertise, and there are also
          increasing levels of potential complexity, greater numbers of positive samples
          required to trigger investigation, larger numbers of individuals engaged in aspects of
          investigation, and increased levels of management and supervisory involvement.

       •  At very small system sizes, State direction will dominate what actions systems tend to
          focus on in the investigation process.

       •  As system size increases, there is greater automation of data systems but a parallel
          increase in the complexity of interpreting any data.

       •  Separate estimates were not developed for NCWSs serving >4,100. Rather, the
          burden estimates for these larger NCWSs are assumed to be the same as similarly
          sized CWSs.

       •  For all levels of investigation, it is assumed that a "toolbox" type of approach is used
          such that not all systems will necessarily conduct all elements of the investigation.
          Systems may stop  conducting assessments once they have found the apparent cause
          of the problem.
March 2009 Revised Total Coliform Rule           4-13       Draft - Please do not cite, quote, or distribute
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                   5   Estimated Unit Costs of Corrective Actions
       This chapter discusses various examples of corrective actions that can help mitigate or
eliminate sources of coliform contamination that may occur during operation and maintenance of
a treatment process or a water system. Exhibit 5-1 provides a summary of those corrective
actions, and the purpose or type of water quality problem addressed by each action.

                      Exhibit 5-1: Summary of Corrective Actions
                    Action
                   Purpose
Flushing - Section 5.1
Scheduled / Routine Flushing (Section 5.1.1)
Unscheduled / Spot Flushing (Section 5.1.2)
  Keep system clean and free of sediment
  Reduce disinfectant demand of pipe surfaces
  Remove stagnant, untreated, or contaminated
  water
  Address water quality deterioration at dead-ends
Sampler Training - Section 5.2
  Reinforces proper sampling and sample handling
  procedures to obtain uncontaminated samples
Replacement / Repair of Distribution System
Components - Section 5.3
Valves (Section 5.3.1)
Water Mains (Section 5.3.2)
Fittings (Section 5.3.3)
Hydrants (Section 5.3.4)
Meters (Section 5.3.5)
Dedicated Sample Taps (Section 5.3.6)
  Reduce potential sources / pathways of
  contamination from improper installation or
  material degradation
Maintenance of Adequate Pressure -Section
5.4
Booster Pumping Stations (Section 5.4.1)
Pump Modifications or Replacement (Section 5.4.2)
Variable Frequency Drives (Section 5.4.3)
Elevated Storage Facilities (Section 5.4.4)
Surge Relief Valves (Section 5.4.5)
Surge Tanks (Section 5.4.6)
  Minimize sudden changes in water velocity which
  impact system pressure
  Reduce risk of backflow and intrusion
  contamination resulting from low pressures
  Reduce risk of hydraulic disturbances to pipe
  surface biofilm
Maintenance of Appropriate Hydraulic
Residence Time - Section 5.5
Looping Dead Ends (Section 5.5.1)
Installing Appropriate Main Sizes (Section 5.5.2)
Automated Flushing Devices (Section 5.5.3)
Storage Facility Modifications (Section 5.5.4)
  Mitigate water quality problems associated with
  increased water age (e.g. higher DBP formation,
  reduced disinfectant residual, increased microbial
  activity, nitrification, and taste-and-odor problems)
Storage Facility Maintenance - Section 5.6
Inspecting /Cleaning of Tanks (Section 5.6.1)
Lining of Storage Tanks (Section 5.6.2)
Vent / Hatch Repair (Section 5.6.3)
Tank Repair (Section 5.6.4)
  Remove contamination from birds and insects
  Remove accumulated sediment
  Protect against tank wall corrosion
Booster Disinfection - Section 5.7
Chlorine (Section 5.7.1)
Chloramine (Section 5.7.2)
  Improve or maintain disinfectant residual in the
  distribution system
March 2009 Revised Total Coliform Rule
Technology and Cost Document
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                   Action
Cross Connection Control and Backflow
Prevention Program - Section 5.8
Backflow Prevention Devices (Section 5.8.1)
Program Administration (Section 5.8.2)
                   Purpose
  Prevent flow of non-potable substances into the
  distribution system
Addition or Upgrade of On-line Monitoring and
Control - Section 5.9
Water Quality Monitoring & Control (Section 5.9.1)
Pressure Monitoring & Control (Section 5.9.2)
  Automatically control and monitor disinfectant
  dosages and water quality parameters (other than
  total coliform)
  Monitor pressure levels to identify physical
  problems in the system (e.g. pipe breaks, leaking
  valves, etc.)
Addition of Security Measures - Section 5.10
  Monitor potential locations for vandalism or
  security breaches that could lead to water
  contamination
  Increase public confidence in protection of their
  drinking water
Development and Implementation of an
Operations Plan - Section 5.11
O&M SOP Training (Section 5.11.1)
O&M Plan Revision (Section 5.11.2)
  Integrate all operations and maintenance
  functions to meet the goals of flow, pressure, and
  water quality
  Establish a routine distribution system sampling
  plan
  Implement an inspections and maintenance
  program
  Define an emergency response plan for the
  distribution system
       The costs incurred for implementing each of these corrective actions is described in detail
in the following sections.  The costs represent a typical estimate for each type of corrective
action. However, system specific characteristics such as system configuration, climate, soil
conditions, local construction practices and requirements, and labor rates may impact the final
cost for a particular water utility to implement a corrective action.

       The costs provided in this chapter were obtained from equipment price lists and quotes,
cost estimates from similar projects, best practices from public water systems, and from
engineering cost data sources (R.S. Means). Where appropriate, the costs are separated into
categories of public water systems (PWS) based on the population size that each system serves.
The labor wage rates used in this chapter are described in Chapter 2 of this document.
Assumptions regarding labor burden, including number of employees and shift hours, were based
on best professional judgment and typical practices from public water systems and are described
in each of the following sub-sections.  All labor costs are assumed to include basic items that
would be part of normal operations for a water system such as tools, field equipment, vehicle
access and  incidentals.

       All  costs are  presented in 2007 dollars; however, some estimates were obtained from
vendors in  2008 and 2009 and were subsequently adjusted to 2007 using construction cost
indices (R.S. Means, 2009). For some items, installed costs were not available so installation
was assumed to be a percentage of the capital cost based on public water system information and
project experience.
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       Wherever it was assumed that a contractor would execute the work to implement any of
the corrective actions, a 22.5% factor for overhead and profit was applied (R.S. Means, 2009).
This overhead factor includes items such as insurance, permits, field offices, temporary facilities,
storage, mobilization and demobilization, barricades, signs, and security measures for the
contractors.

5.1    Flushing

       A water main flushing program helps to keep the system clean and free of sediment, can
reduce the disinfectant demand of pipe surfaces, and removes stagnant water and any untreated
or contaminated water that may have entered the system (Kirmeyer et al. 2000b). Flushing can
also be used to address water quality deterioration at dead-ends. The following sections discuss
scheduled system-wide flushing, and periodic unscheduled (or "spot") flushing which can be
used to address isolated water quality problems, including total coliform positive samples.

       The volume of water flushed is related to the length of flushing time and flow rate from
the hydrant.  Typically, water systems flush until a disinfectant residual can be measured or other
water quality target is reached. These practices are similar for all types of disinfectants and
would also hold true for undisinfected systems.

5.1.1   Scheduled / Routine Flushing

       Minimum elements of a flushing program are outlined in the AWWA G200 Standard
(AWWA 2004) and include: (1) a preventive approach to address local problems or customer
concerns and routine flushing to avoid water quality problems;  (2) use of an appropriate flushing
velocity to address water quality concerns; and (3) written procedures for all elements of the
flushing program including water quality monitoring, regulatory requirements and specific
flushing procedures.

       Exhibit 5-2 summarizes the estimated annual cost for routine flushing a complete water
distribution system (at a rate of once per year).  These costs include estimates of labor, cost of
lost water, and cost of treatment (dechlorination) prior to disposal. In smaller systems,
maintenance of a routine flushing program may be only one aspect of an operator's duties;
however, in larger  systems one or more full-time employees may be entirely dedicated to this
program. Column  D presents the estimated percent  commitment of operators to a routine
flushing program, based on PWS size. Estimates of the volume of water flushed  are based on
mid-point population of each PWS category, water usage rate of 100 gallons per person per day
(GPCD), and 0.47% average percentage of water flushed per water produced, as obtained from
Cost and Benefit Analysis of Flushing (Hasit, 2004). Value of lost water is based on an average
billing rate of $3.00 per thousand gallons (kgal), also obtained from Cost and Benefit Analysis of
Flushing, and adjusted to 2007 dollars. Dechlorination costs were estimated based on chemical
consumption of dechlorinating agents per gallon of water flushed.  However, treatment
requirements for discharge of flushing water will vary according to locality and should be
examined on a case-by-case basis. Public notification costs were not included in this estimate.
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                                                Exhibit 5-2: Estimated Costs for Routine  Flushing
System Size
A
<500
501 -1,000
1,001 -4,100
4,101 -33,000
33,001 -96,000
96,001 -500,000
500,001 -1,000,000
> 1,000,001
Average
System
Population
B
250
1,400
6,650
30,000
75,000
300,000
750,000
1,500,000
Labor
Rate1
C
$25.75
$28.96
$29.73
$36.00
$36.39
$41.01
$41.01
$41.01
Number of
employees
involved in
flushing
program
D
1
1
1
1
1
2
3
6
Percent
time
Committed
to Flushing2
E
2-3%
3-4%
4-5%
18-20%
80-90%
100%
100%
100%
Total Labor
(hours per
year)
F=D*E*2080
48
72
96
384
1920
4160
6240
12480
Total
Labor
Cost
G=C*F
$1,240
$2,090
$2,860
$13,830
$69,870
$170,610
$255,910
$511,810
Flushed
Water
Volume3'4
(kgal/yr)
H=0.0047*B
*1 00*365
/1000
50
250
1,150
5,150
12,870
51,470
128,670
257,330
Value of
Water
Flushed
per year5
I=H*$3.00
150
750
3,450
15,450
38,610
154,410
386,010
771,990
Cost of
Disposal of
Flushed
Water per
year6*8
J=H*$3.00
/8.5
20
90
410
1,820
4,550
18,170
45,420
90,830
Total
Annual
Cost9
(2007$)
K=G+I+J
$1,410
$2,930
$6,720
$31,100
$113,030
$343,190
$687,340
$1,374,630
1 See Exhibit 2-6 in Chapter 2. Estimated Unit Costs of Labor. *Note: A weighted labor rate was used for system size serving < 500 based on the number of systems serving <
500-see exhibit 2-5 for the number of systems in each population size category. The weighted labor rate for system size < 500 was calculated as follows ((83,746 x $25.10) +
$27.03)/(83,746 + 42,690) = $25.75 .
2 Estimate based on typical PWS practices.
3 Average ratio of water flushed per water produced = 0.47%, as reported in Cost and Benefit Analysis of Flushing (Hasit, 2004).
4 Water produced based on mid-point population of each PWS category, and average usage rate of 100 GPCD.
5 Value based on average price that PWSs charge for water, as reported in Cost and Benefit Analysis of Flushing (Hasit, 2004) and adjusted to 2007 dollars ($3.00 / kgal).
6 Assumes that dechlorinator attachments are part of typical equipment already owned by the PWS.
7 Cost per dechlorination tablet obtained from USA Bluebook catalog, 2008 and adjusted to 2007 dollars ($3.00 / tablet)
8 Each dechlorination tablet neutralizes 8,500 gallons of water with 1 ppm of chlorine according to manufacturer recommendations.
9 Estimates rounded up to the nearest $10
                             100 and 101 -
                             (42,692 x
March 2009 Revised Total Coliform Rule
Technology and Cost Document
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5.1.2  Unscheduled / Spot Flushing

       Upon obtaining a positive sample for total coliform (TC), a common response is to flush
the area near the sample site to draw in fresh water and remove any contaminated water that may
be present. This unscheduled spot flushing is different than a routine flushing program in that
the flushing only occurs when triggered by a water quality measurement, customer complaint, or
similar event.

       Exhibit 5-3 summarizes the estimated cost for a single unscheduled / spot flushing event.
As in Section 5.1.1, these costs include estimates of labor, cost of lost water, and cost of
treatment (dechlorination) prior to disposal. Labor estimates were based on half-day flushing
events, with 1 or 2 person crews depending on system size.  Flushed water volumes were based
on a single hydrant flushing event, size of the hydrant and maximum discharge flows, and an
assumed 1-hour flush time.  Duration was based on the assumption that it takes longer to achieve
a reasonable disinfectant residual when spot flushing problem areas than it takes when
performing routine flushing in a healthy system. According to Cost and Benefit Analysis of
Flushing, routine flushing is normally maintained for 5 to 40 minutes (with 15 minutes being the
most common); however, actual durations are based on time it takes for water quality to
improve, water color to clear, or both.
March 2009 Revised Total Coliform Rule              5-5      Draft - Please do not cite, quote, or distribute
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                                                  Exhibit 5-3: Estimated Costs for Spot Flushing
System Size
A
<500
501 -1,000
1,001 -4,100
4,101 -33,000
33,001 -96,000
96,001 -500,000
500,001 -1,000,000
> 1,000,001
Labor Rate1
B
$25.75
$28.96
$29.73
$36.00
$36.39
$41.01
$41.01
$41.01
Shift Hours2
C
4
4
4
8
8
8
8
8
Total Labor
Cost
D=B*C
$110
$120
$120
$290
$300
$330
$330
$330
Average
Hydrant Size
E
4
4
6
6
6
8
8
8
Maximum
Flushing
Flow (GPM)
F
500
500
750
750
750
1000
1000
1000
Flushed
Water
Volume
(kgal)3
G=F*60/1000
30
30
45
45
45
60
60
60
Value of
Water
Flushed4
H=G*$3.00
90
90
135
135
135
180
180
180
Cost of
Disposal of
Flushed
Water5'6'7
I=H*$3.00 /
8.5
20
20
20
20
20
30
30
30
Total Cost8
(2007$)
J=D+H+I
220
230
280
450
460
540
540
540
1 See Exhibit 2-6 in Chapter 2. Estimated Unit Costs of Labor.
2 Shift hours for systems serving < 500 to 4,100 assume 1-person crew, and half-day flushing event.  Systems serving > 4,100 assume 2-person crew and half-day flushing event.
3 Flushed water volume based on 1 -hour flushing event.
4 Value based on average price that PWSs charge for water, as reported in Cost and Benefit Analysis of Flushing (Hasit, 2004) and adjusted to 2007 dollars ($3.00 / kgal).
5 Assumes that dechlorinator attachments are part of typical equipment already owned by the PWS.
6 Cost per dechlorination tablet obtained from USA Bluebook catalog, 2008 and adjusted to 2007 dollars ($3.00 / tablet).
7 Each dechlorination tablet neutralizes 8,500 gallons of water with 1 ppm of chlorine according to manufacturer recommendations.
8 Estimates rounded up to the nearest $10.
March 2009 Revised Total Coliform Rule
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5.2    Sampler Training

       EPA establishes sampling requirements to determine if a distribution system is in
compliance with regulatory requirements.  Implementation of a sampler training program
provides guidelines for procedures that samplers must follow to collect valid, uncontaminated
samples for analysis of total coliform in the distribution system. Training sessions for operators
reinforce proper sampling and sample handling procedures to  obtain uncontaminated samples.

       The costs for sampler training assume that the operator/sampler attends an external, 8-
hour training class. The costs include travel costs, training fees, and the operator labor costs
associated with the time spent at the training session. Exhibit 5-4 summarizes the cost for
sampler training.

             Exhibit 5-4: Estimated Costs Operator Training/Certification
System Size
A
<500
501 -1,000
1,001 -4,100
4,101 -33,000
33,001 -96,000
96,001 -500,000
500,001 -1,000,000
> 1,000,001
Labor
Rate1
B
$25.75
$28.96
$29.73
$36.00
$36.39
$41.01
$41.01
$41.01
Course
Time
(hours)2
C
8
8
8
8
8
8
8
8
Total Labor
Cost
D = B*C
$210
$240
$240
$290
$300
$330
$330
$330
Travel3
E
$31
$31
$31
$31
$31
$31
$31
$31
Training/
Certification
Fees4
F
$125
$125
$125
$125
$125
$125
$125
$125
Total
(2007$)5
G=D+E+F
$370
$400
$400
$450
$460
$490
$490
$490
1 See Exhibit 2-6 in Chapter 2. Estimated Unit Costs of Labor.
2 Assumes an 8-hour training/certification course
3 Assumes 60 miles of round-trip driving distance at $0.52/mi.
4 Assumes a $125 training fee for members based on costs from the National Rural Water Association.
5 Estimates rounded up to the nearest $10.

5.3    Replacement / Repair of Distribution System Components

       Distribution system components and appurtenances such as valves, pipe, fittings,
hydrants, meters, and sample taps are integral parts of a water system.  These components are
also potential sources of contamination if improper installation or material degradation allows
leaks or other entry points for coliforms into a distribution system.

       These individual components are described in the following sections and costs for the
repair or replacement of these components are presented. In general, a three-person labor crew
was assumed for replacement / repair of underground facilities (which require digging,
replacement of pavement or turf, trench safety considerations, maintenance of traffic, etc.) and a
two-person crew was assumed for above-ground / exposed facilities. All activities were assumed
to take a full 8-hour day, based on the need to mobilize equipment, perform the necessary
excavation, setup,  and restore the surface condition after replacement / repair.  Where
appropriate, assumptions on component size were made based on the population range served by
a distribution system. The most common pipe diameters are 6 and 8 inches, even for large
March 2009 Revised Total Coliform Rule
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systems, from the TCR Issue Paper: Distribution System Inventory, Integrity, and Water Quality
(EPA 2007).

5.3.1  Valves

       Valves are located throughout a distribution system to isolate portions of the system as
needed.  Leaks at the connection points between the valve and the adjacent pipe, as well as a
valve seat or valve body, can create a pathway for contamination.

       Prior to replacing or repairing a valve, it should be identified as the cause of the leak.
Some isolation valves throughout the distribution system are located below grade, making a leak
difficult to locate.  A number of technologies, discussed in Chapter 7, have been developed to
locate leaks below grade.

       As butterfly valves are typically the most common type of valve encountered in a water
distribution system, this type of valve was used as the basis for the cost estimation presented in
Exhibit 5-5.  Costs are presented on a per valve basis.  Labor estimates are based on an 8-hour
shift and 3-person crew.

                     Exhibit  5-5: Estimated Costs to Replace Valve
System Size
A
<500
501 -1,000
1,001 -4,100
4,101 -33,000
33,001 -96,000
96,001 -500,000
500,001 -1,000,000
> 1,000,001
Labor
Rate1
B
$25.75
$28.96
$29.73
$36.00
$36.39
$41.01
$41.01
$41.01
Shift Time
(hours)2
C
8
8
8
8
8
8
8
8
Total Labor
Cost3
D=B*C*3
$620
$700
$720
$870
$880
$990
$990
$990
Valve Size
(in.)4
E
4
4
6
6
6
8
8
8
Valve
Cost5'6
F
$385
$385
$565
$565
$565
$785
$785
$785
Total Cost
(2007$)7
G=D+F
$1,010
$1,090
$1,290
$1,440
$1,450
$1,780
$1,780
$1,780
  1 See Exhibit 2-6 in Chapter 2. Estimated Unit Costs of Labor.
  2 Shift time assumes 8 hours needed for mobilization, setup, and cleanup of site.
  3 Labor cost assumes a three-person crew needed for underground valve replacement.
  4 Based on commonly-occurring valve sizes in similarly-sized systems (EPA, 2007).
  5 Valve cost assumed a cast iron, mechanical joint, butterfly valve with box.
  6Valve costs obtained from R.S. Means, 2007.
  7 Estimates rounded up to the nearest $10.

5.3.2  Water Mains

       The condition of distribution system piping can be vital to the quality of water being
conveyed to a community.  Contaminants may enter through holes, breaks, cracks or joints in the
piping.  The condition of a pipe can vary based on type, age, and location of the pipe.
Depending on the condition of the  pipe, the water main can be replaced or repaired to stop
infiltration into the system.
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       Prior to replacing or repairing a water main, the location of the break or leak must be
determined.  Since most of the distribution system is below grade, locating a leak can be
difficult.  A number of technologies have been developed to evaluate the condition of below
grade piping to locate leaks.

       Costs presented in Exhibit 5-6 are based on replacement of a 20-foot pipe segment, which
is the nominal  laying length of standard ductile iron pipe.  Labor estimates are based on an 8-
hour shift and 3-person crew.

               Exhibit 5-6:  Estimated Costs to Replace Ductile Iron Pipe
System Size
A
<500
501 -1,000
1,001 -4,100
4,101 -33,000
33,001 -96,000
96,001 -500,000
500,001 -1,000,000
> 1,000,001
Labor Rate1
B
$25.75
$28.96
$29.73
$36.00
$36.39
$41.01
$41.01
$41.01
Shift Time
(hours)2
C
8
8
8
8
8
8
8
8
Total Labor
Cost3
D=B*C*3
$620
$700
$720
$870
$880
$990
$990
$990
Pipe Size
(in.)4
E
4
4
6
6
6
8
8
8
Pipe
Cost5'6'7
(per 20 ft.)
F
$167
$167
$196
$196
$196
$265
$265
$265
Total Cost
(2007$)8
G=D+F
$790
$860
$910
$1,060
$1,070
$1,250
$1,250
$1,250
1 See Exhibit 2-6 in Chapter 2. Estimated Unit Costs of Labor.
2 Shift time assumes 8 hours needed for mobilization, setup, and cleanup of site.
3 Labor cost assumes a three-person crew needed for underground pipe replacement.
4 Based on commonly-occurring valve sizes in similarly-sized systems (EPA, 2007).
5 Pipe cost assumed cement lined, ductile iron, push-on joint pipe.
6 Pipe cost based on 20 feet segments, as standard nominal pipe laying lengths are 20 feet (American Pipe Manual, 18th Edition,
2004).
7 Pipe costs obtained from R.S. Means, 2007.
8 Estimates rounded up to the nearest $10.

5.3.3   Fittings

        There are many types of fittings located throughout a distribution system.  The most
common type of distribution system fitting is a cross.  A cross has four connections; therefore
making it more susceptible to leaks. Leaks  can occur because of a crack on the fitting or through
the gasket between the fitting and another appurtenance, e.g. valve, cap, or pipe.

        Once a leak is located and it is confirmed that the fitting is the cause of the leak, it can be
replaced or repaired depending on the condition of the fitting.  A portion of the distribution
system will be placed out of service as this work is performed; therefore, interrupting water
service.

        Costs are presented in Exhibit 5-7 and are calculated based on material costs and labor,
assuming an 8-hour shift and 3-person work crew.
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                     Exhibit 5-7: Estimated Costs to Replace Fittings
System Size
A
<500
501 -1,000
1,001 -4,100
4,101 -33,000
33,001 -96,000
96,001 -500,000
500,001 -1,000,000
> 1,000,001
Labor Rate1
B
$25.75
$28.96
$29.73
$36.00
$36.39
$41.01
$41.01
$41.01
Shift Time
(hours)2
C
8
8
8
8
8
8
8
8
Total Labor
Cost3
D=B*C*3
$620
$700
$720
$870
$880
$990
$990
$990
Fitting Size
(in.)4
E
4x4
4x4
6x6
6x6
6x6
8x8
8x8
8x8
Fitting
Cost5*7
F
$368
$368
$480
$480
$480
$686
$686
$686
Total Cost
(2007$)8
G=D+F
$990
$1,070
$1,200
$1,350
$1,360
$1,680
$1,680
$1,680
1 See Exhibit 2-6 in Chapter 2. Estimated Unit Costs of Labor.
2 Shift time assumes 8 hours needed for mobilization, setup, and cleanup of site.
3 Labor cost assumes a three-person crew needed for replacement of underground fittings.
4 Based on commonly-occurring fitting sizes in similarly-sized systems.
5 Fitting cost assumed cement lined, ductile iron, and mechanical joint cross, with gaskets.
6 Fitting costs obtained from R.S. Means, 2007, by multiplying the tee cost by the ratio of the weight of a cross and a tee.
7 Fitting weights obtain from American Pipe Manual, 19th Edition.
8 Estimates rounded up to the nearest $10.

5.3.4   Hydrants

        Hydrants  are located throughout a distribution system to provide potable water at
required fire flow pressures for emergency  situations.  Hydrant connections are tapped off the
distribution system; therefore, these connections can be possible locations for coliform
contamination to enter a distribution system.

        Replacing a damaged or faulty fire hydrant can  help eliminate sources of contamination
into the distribution system as it eliminates a pathway for contamination. The costs included to
replace a fire hydrant are presented in Exhibit  5-8.  Costs are calculated based on labor rate data
per population range, assumptions on the number of workers and the time required, as well  as
material costs.
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                   Exhibit 5-8: Estimated Costs to Replace Hydrants
System Size
A
<500
501 -1,000
1,001 -4,100
4,101 -33,000
33,001 -96,000
96,001 -500,000
500,001 -1,000,000
> 1,000,001
Labor Rate1
B
$25.75
$28.96
$29.73
$36.00
$36.39
$41.01
$41.01
$41.01
Shift Time
(hours)2
C
8
8
8
8
8
8
8
8
Total Labor
Cost3
D=B*C*2
$420
$470
$480
$580
$590
$660
$660
$660
Hydrant
Cost4'5
E
$1,225
$1,225
$1,225
$1,225
$1,225
$1,225
$1,225
$1,225
Total Cost
(2007$)6
F=D+E
$1,645
$1,700
$1,710
$1,810
$1,820
$1,890
$1,890
$1,890
1 See Exhibit 2-6 in Chapter 2. Estimated Unit Costs of Labor.
2 Shift time assumes 8 hours needed for mobilization, setup, and cleanup of site.
3 Labor cost assumes a two-person crew needed for replacement of partially-exposed hydrants.
4 Hydrant cost assumes a two-way, 4-1/2 inch valve size, hydrant, partially excavated at a depth of 3 feet.
5 Hydrant costs obtained from R.S. Means, 2007.
6 Estimates rounded up to the nearest $10.
5.3.5  Meters

       Meters are located at entry points to commercial, residential, and industrial facilities to
measure the amount of water that is consumed at a particular location.  Sizes for each of the
meters will vary based on the type and usage requirements of a facility.  Contamination may
enter through the connection points of the meter and the distribution system.  Replacing a meter
can help prevent contamination into the distribution system through leaks, as it eliminates a
pathway for contamination.
       Costs presented in Exhibit 5-9 are based on the standard meter size for a commercial/
industrial user (such as a farm or food processing plant), as these users would likely have a much
higher potential for coliform contamination.  Costs are calculated based on an 8-hour shift and 2-
person crew.
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                    Exhibit 5-9: Estimated Costs to Replace Meters
System Size
A
<500
501 -1,000
1,001 -4,100
4,101 -33,000
33,001 -96,000
96,001 -500,000
500,001 -1,000,000
> 1,000,001
Labor Rate1
B
$25.75
$28.96
$29.73
$36.00
$36.39
$41.01
$41.01
$41.01
Shift Time
(hours)2
C
8
8
8
8
8
8
8
8
Total Labor
Cost3
D=B*C*2
$420
$470
$480
$580
$590
$660
$660
$660
Meter Cost4'5
E
$330
$330
$330
$330
$330
$330
$330
$330
Total Cost
(2007$)6
F=D+E
$750
$800
$810
$910
$920
$990
$990
$990
1 See Exhibit 2-6 in Chapter 2. Estimated Unit Costs of Labor.
2 Shift time assumes 8 hours needed for mobilization, setup, and cleanup of site.
3 Labor cost assumes a two-person crew needed for replacement of exposed meters.
4 Meter costs assume a standard 1-1/2 inch bronze commercial meter, which is typically the same, regardless of system size.
5 Meter costs obtained from R.S. Means, 2007.
6 Estimates rounded up to the nearest $10.
5.3.6  Dedicated Sample Taps

       The TCRDSAC recommends that routine and repeat sample siting plans should ensure
that the quality of the water is representative of the distribution system, and further recommends
such samples could be drawn from a dedicated sampling station, or sampling tap, among other
locations.  A dedicated sampling station is a device that is plumbed directly into a distribution
system line to provide "improved access to the distribution system water and provide
reproducible samples that are representative of water quality at the customer's meter" (Kirmeyer
-AWWARF, 2000). Dedicated sampling stations should be metal construction and have
unthreaded nozzles or an approved design and should be located so as to be representative of the
water in the distribution  system. They are typically covered to protect them from birds, insects,
dirt and other sources of outside contamination.  Exhibit 5-10 is a graphic schematic detailing the
components of a dedicated sampling station. Exhibit 5-11 is a photograph of an actual dedicated
sampling station.
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                    Exhibit 5-10: Dedicated Sampling Station Schematic

                                   1/4 in. (6.3 mm) brass compression fitting

                                 - Vซ X 1/4 in. (3.1 x 6.3 mm) shutoff valve

                                 -- Vป in. (3.1 mm) brass coupling

                                   Vs in. (3.1 mm) brass nipple
                                               — 6 X4in. X4in.
                                                 (150 X 100 X 100 mm) box

                                               >l    ]/ — Bracket to clamp
                                                  A   valve to box
                 Stainless-steel hose clamp
                           1/4 in. (6.3 mm)
                           shutoff valve
                                       /
                                      /
       Any domestic meter

       Hinge and hasp for locking box



—Ve in. (3.1 mm) tap in angle meter stop
                                                                \
                                                                   Conduit lock-nuts

                                                                       12 in. (31.3 X 300 mm) steel nipple
                                                                 "- 11/4 in. (31.3 mm) coupling
                        _— jo meter -
                                                                  1T/4 in. (31.3 mm) steel bend
                                           1/4 in. (6.3 mm) copper tubing
     Sox should be located near a stationary object, such as a power pole, for protection, or
     place sufficient concrete around riser below ground.
      Source: Water Distribution System Operation and Maintenance, A Field Study Training Program. USEPA
      Office of Drinking Water and California Department of Health Services, Sanitary Engineering Branch.
      Hornet Foundation Inc., Sacramento, Calif. (1989, 2nded.).
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                        Exhibit 5-11: Dedicated Sampling Station
                        Source: With permission courtesy of Koraleen Enterprises.
        The cost of a new sampling station will vary depending on site conditions including cold
weather vs. warm weather installation.  Exhibit 5-12 provides unit cost estimates for installation
of new sampling stations.  Actual cost will vary depending on whether an existing meter service
could be tapped into, or whether a new service line must be installed from the main line.  For the
purposes of this estimate, it has been assumed that an existing meter service could be tapped into,
and that a 2-person crew can achieve installation in one 8-hour shift.

        Exhibit 5-12: Estimated Costs of Installing a Dedicated Sampling Tap
System Size
A
<500
501 - 1,000
1,001 -4,100
4,101 -33,000
33,001 - 96,000
96,001 - 500,000
500,001-1,000,000
> 1,000,001
Labor Rate1
B
$25.75
$28.96
$29.73
$36.00
$36.39
$41.01
$41.01
$41.01
Shift Time
(hours)2
C
8
8
8
8
8
8
8
8
Total Labor
Cost3
D=B*C*2
$420
$470
$480
$580
$590
$660
$660
$660
Sampling
Tap Cost4
E
$600
$600
$600
$600
$600
$600
$600
$600
Total Cost
(2007$)5
F=D+E
$1,020
$1,070
$1,080
$1,180
$1,190
$1,260
$1,260
$1,260
1 See Exhibit 2-6 in Chapter 2. Estimated Unit Costs of Labor.
2 Shift time assumes 8 hours needed for mobilization, setup, and cleanup of site.
3 Labor cost assumes a two-person crew needed for installation / replacement of exposed sample taps.
4 Material cost assumes Koraleen Enterprises cold weather station, provided by manufacturer / distributor and adjusted to 2007
dollars.
5 Estimates rounded up to the nearest $10.
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5.4    Maintenance of Adequate Pressure

       Pressure losses can occur in the distribution system as a result of events such as flushing,
main breaks, power outages, service line breaks, and fires.  Pressure transients (also called
pressure surges or water hammer) can occur when an abrupt change in water velocity occurs due
to a sudden valve closure, pump shutdown or loss of power. The resulting pressure wave, with
alternating low and high pressures, travels back and forth through the distribution system until
the pressure is stabilized. Low pressure conditions in the distribution system can allow a flow
reversal or backflow of non-potable water to enter the system from a cross connection or other
source.  Pressure transients can  also create hydraulic disturbances that allow biofilm material on
pipe surfaces to enter the bulk water.  Industry guidelines suggest that system pressure should be
maintained within the range of 35 to 100 psi at all points in the distribution system (AWWA
1996). The AWWA G200 standard indicates that the minimum residual pressure at the service
connection under all operating conditions should be > 20 psi (AWWA 2004). Written standard
operating procedures for pump, hydrant and valve operation under routine and emergency
conditions  can help minimize sudden changes in water velocity that impact system pressure.

       Other actions that can help to maintain an adequate pressure in the distribution system
include building new booster pump stations and elevated storage facilities, modifying existing
high services pumps, and installing surge relief valves and surge tanks. The following sections
discuss costs associated with each of these options.

5.4.1  Booster Pumping Station

       Booster pumping  stations are used in the distribution systems to move water from lower
pressure zones to  higher pressure zones and to maintain pressure at desirable levels. As the
water system grows and changes,  existing booster pump stations may no longer be able to
maintain the desired pressure across the distribution system. In those cases, the construction of a
new booster station may be required.

       Exhibit 5-13 presents the estimated cost for the installation of a new booster pump station
including equipment, required piping and appurtenances, electrical and instrumentation
equipment, a building, installation, and overhead and profit.
March 2009 Revised Total Coliform Rule             5-15     Draft - Please do not cite, quote, or distribute
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                                 Exhibit 5-13: Estimated Costs to Install a  New Booster Pump Station
Cost Component1
Pump Station Size (MGD)
Number of Pumps
Pump Size (gpm)
Pump & Motor Cost
Pipes and related materials
Equipment Installation2
Total Cost of Installed
Equipment
Building Size (sf)
Building Cost3
Slab-on-grade Cost4'5
Electrical and Instrumentation"
Total Cost (2007$)7'8
A
B
C
D
E
F=0.3*(D+E)
G=D+E+F
H
I
J
K=0.2*G
L=1.225*(G+I+J+K)
Population Size Category
<500
0.03
1 duty
1 stand-by
17
$1,960
$1,930
$1,170
$5,060
72
$3,940
$230
$1,020
$12,560
501
to
1,000
0.08
1 duty
1 stand-by
52
$2,140
$5,130
$2,190
$9,460
72
$3,940
$230
$1,900
$19,030
1,001
to
4,100
0.09
1 duty
1 stand-by
59
$2,140
$5,770
$2,380
$10,290
72
$3,940
$230
$2,060
$20,240
4,101
to
33,000
0.6
1 duty
1 stand-by
429
$15,280
$38,460
$16,130
$69,870
167
$9,120
$530
$13,980
$114,540
33,001
to
96,000
2.2
2 duty
1 stand-by
747
$26,520
$141,000
$50,260
$217,780
264
$14,420
$830
$43,560
$338,830
96,001
to
500,000
3.0
2 duty
1 stand-by
1,042
$36,780
$192,280
$68,720
$297,780
366
$19,980
$1,140
$59,560
$463,620
500,001
to
1,000,000
7.5
2 duty
1 stand-by
2,604
$92,440
$480,690
$171,940
$745,070
920
$50,260
$2,870
$149,020
$1,160,350
>1, 000,001
15
2 duty
1 stand-by
5,208
$184,860
$961,370
$343,870
$1,490,100
1,841
$100,510
$5,730
$298,020
$2,320,600
1 All costs on a per pump station basis.
2 Assumes 30% of pump, motor, pipes and related materials total cost.
3 Assumes the median cost ($60/sf) of a Warehouse & Storage Building type (includes site work, masonry, plumbing, electrical, HVAC & labor). Source: R.S. Means, 2009 (adjusted to 2007
dollars).
4 Assumes $184.43/cubic yard. Source: R.S. Means, 2009.
5 Assumes a 6-inch slab.
6 Assumes 20% of the total installed equipment.
7 Cost rounded up to the nearest $10.
8 Includes 22.5% overhead and profit, based on R.S. Means (2009).
March 2009 Revised Total Coliform Rule
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5.4.2  Modify or Replace Existing Pumps

       The construction of a completely new booster pump station is not always required to
maintain an appropriate pressure in a water system.  There may be situations where a
modification or replacement of an existing pump is sufficient.

       Exhibit 5-14 presents the estimated cost for replacing a new booster pump including
equipment, required piping and appurtenances, installation, and overhead and profit.  For smaller
systems, the pump and motor were provided in a package cost estimate; however for pumps
greater than 59 GPM, the pump and motor were quoted separately and summed in Row D.

              Exhibit 5-14: Estimated  Costs to Replace Existing  Pump
Cost Component 1
Pump Size (gpm)
Pump Cost
Motor Cost
Pump & Motor
Cost
Related Pump
Equipment2
Installation3
Total Cost
(2007$)4'5
A
B
C
D=B+C
E=0.3*D
F=0.2*(D+E)
G=1.225*
(D+E+F)
Population Size Category
<500
17
-
-
$980
$300
$260
$1,890
50
to
1,000
52
-
-
$1,070
$330
$280
$2,060
1,001
to
4,100
59
-
-
$1,070
$330
$280
$2,060
4,100
to
33,000
429
$4,390
$3,250
$7,640
$2,300
$1,990
$14,620
33,001
to
96,000
747
$7,620
$5,640
$13,260
$3,980
$3,450
$25,350
96,001
to
500,000
1035
$10,560
$7,830
$18,390
$5,520
$4,790
$35,160
500,001
to
1,000,000
2604
$26,550
$19,670
$46,220
$13,870
$12,020
$88,340
>1, 000,001
5208
$53,100
$39,330
$92,430
$27,730
$24,040
$176,650
  1 All costs on a per pump basis. Source: USABIueBook Catalog, 2008 (adjusted to 2007 dollars).
  2 Assumes 30% of the pump and motor cost.
  3 Assumes 20% of the pump, motor and related equipment cost.
  4 Cost rounded up to the nearest $10.
  Includes 22.5% overhead and profit, based on R.S. Means (2009).

5.4.3   Install Variable Frequency Drives

       A variable frequency drive (VFD), also called a variable speed drive, allows a booster
pump to supply the required amount of flow based on system demand with a pressure set point to
maintain constant system discharge pressure, controlled to within a few psi of an operator-
adjustable system pressure set point. VFDs work with a system pressure transmitter to control
the system pressure set point.

       Exhibit 5-15 presents the estimated cost to install a VFD, including installation, overhead
and profit.
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         Exhibit 5-15:  Estimated Costs to Install a Variable Frequency Drive
System Size
A
<500
501 -1,000
1,001 -4,100
4,101 -33,000
33,001 -96,000
96,001 -500,000
500,001 -1,000,000
> 1,000,001
Pump Size (gpm)
B
17
52
59
429
747
1,042
2,604
5,208
VFD Cost1
C
$1,150
$3,440
$3,900
$28,340
$49,260
$68,730
$171,830
$343,650
Total Cost
(2007$)2'3
D=C*1.225
$1,410
$4,220
$4,780
$34,720
$60,350
$84,200
$210,500
$420,980
  1 Based on installed cost, per equipment vendor quotes and adjusted to 2007 dollars.
  2 Cost rounded up to the nearest $10
  3 Includes 22.5% overhead and profit, based on R.S. Means (2009).

5.4.4  Elevated Storage Facility

       Elevated storage is provided within the distribution system to supply peak demand rates
and equalize system pressures.  In certain systems, elevated storage is more effective and
economical than ground storage because by nature of the elevated supply, pumping requirements
may be reduced, and the storage can serve as a source of emergency supply since system
pressure requirements can still be met temporarily when pumps are out of service.

       Elevated storage tanks are often sited in areas having the lowest system pressures during
intervals of high water use.  These areas are often those of greatest water demand or those
farthest from pump stations.  Elevated tanks are generally located at some distance from the
pump station serving a distribution  pressure level, but ideally are not placed outside of
boundaries of the service area unless the facility can be located on a nearby hill. Elevated tanks
are built on the highest available ground so as to minimize the required construction cost and the
height requirements.

       Exhibit 5-16 presents the estimated costs to install a new elevated storage tank. These
costs are per tank and include the installed tank cost, the foundation, pipe and related materials
costs, installation and profit and overhead.
March 2009 Revised Total Coliform Rule
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        Exhibit 5-16: Estimated Costs to Install a New Elevated Storage Tank
System Size
A
<500
501 -1,000
1,001 -4,100
4,101 -33,000
33,001 -96,000
96,001 -500,000
500,001 -1,000,000
> 1,000,001
Tank Size
(gai)
B
50,000
100,000
250,000
500,000
1,000,000
1,000,000
2,000,000
2,000,000
Tank Cost1
C
$202,240
$278,770
$384,440
$620,390
$859,980
$859,980
$1,719,970
$1,719,970
Foundation
Cost2'3
D=0.15*C
$30,340
$41,820
$57,670
$93,060
$129,000
$129,000
$258,000
$258,000
Piping & Related
Materials Cost4
E=0.3*(C+D)
$69,770
$96,180
$132,630
$214,040
$296,690
$296,690
$593,390
$593,390
Total Cost
(2007$)5
F=(C+D+E)*1.225
$370,380
$510,550
$704,060
$1,136,180
$1,574,950
$1,574,950
$3,149,920
$3,149,920
      1 Assumes installed cost. Source: R.S. Means (2009), adjusted to 2007 dollars.
      2Assumes 15% of tank cost, based on project experience.
      3 Foundation cost depends on soil conditions, good soil conditions assumed.
      4 Assumes 30% of tank and foundation combined cost.
      Includes 22.5% overhead and profit, based on R.S. Means (2009).

5.4.5  Install  Surge Relief Valve

       Surge relief valves provide pressure management by ejecting water out of a side orifice to
prevent excessive high-pressure surges and can also be triggered to open on a downsurge in
pressure in anticipation of an upsurge to follow. Surge relief valves must always be used with
caution for they can make low-pressure conditions in a line worse than they would be without the
valve.

       Exhibit 5-17 presents the estimated costs to install a surge relief valve.

             Exhibit 5-17: Estimated Costs to Install a Surge Relief Valve
System Size
A
<500
501 -1,000
1,001 -4,100
4,101 -33,000
33,001 -96,000
96,001 -500,000
500,001 -1,000,000
> 1,000,001
Valve Size
(in)
B
4
4
6
10
12
20
24
24
Surge Relief Valve
Cost1
C
$4,040
$4,040
$5,920
$15,510
$23,590
$41,830
$51,040
$51,040
Total Cost2
(2007$)
D = C*1.225
$4,950
$4,950
$7,250
$19,000
$28,900
$51,240
$62,520
$62,520
  1 Assumes installed cost. Source: Apollo Valves catalog, 2008.
  2 Includes 22.5% overhead and profit, based on R.S. Means (2009).

5.4.6  Install Surge Tanks

       The four common types of surge tanks include pneumatic or closed tanks, open
standpipes (or air chambers), one-way surge tanks (allows water to flow only from the tank into
the pipeline) and two-way surge tanks (allows flow to and from the tank). If water is stored in

March 2009 Revised Total Coliform Rule          5-19         Draft - Please do not cite, quote, or distribute
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these tanks for long periods of time, the water may lose its disinfectant residual and microbial
growth and other water quality problems may results. Proper operations and maintenance of
surge tanks is required to prevent poor quality or contaminated water from entering the
distribution system.

       Hydropneumatic tank systems are a popular way to provide pressure control and
stabilization in smaller water distribution systems; however, they are not typically used in larger
systems (serving > 500,000 customers).  A hydropneumatic tank system allows for fluctuations
in water distribution system pressure, and a potential cushion against water hammer. The system
also minimizes booster pump on-off cycles.

       The pressure tank uses a compressed air head-space to maintain system pressure. As
water system demand increases, water in the pressure tank discharges into the system and
reduces the pressure tank's water level, which expands the air cushion above the water and
decreases the tank air pressure. When the air reaches a determined set point, the air compressor
comes on to recharge the air space and cycles off when the high pressure set point is met. If the
water demand continues to increase, the booster pumps will cycle on at the low water level and
replenish the water level in the pressure tank.  The pressure tank must be sized correctly, because
its size determines the frequency of pump cycling.

       Exhibit 5-18 presents the estimated cost to install a hydropneumatic tank system.  The
hydropneumatic tank system consists of a hydropneumatic pressure tank,  and air compressor and
associated piping and controls. The cost of the slab-on-grade where the tank will be installed on
is also included in this estimated cost as well as installation and overhead and profit costs.
March 2009 Revised Total Coliform Rule          5-20         Draft - Please do not cite, quote, or distribute
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            Exhibit 5-18: Estimated Costs to Install a Surge Control Tank
System Size
A
<500
501 -1,000
1,001 -4,100
4,101 -33,000
33,001 -96,000
96,001 -500,000
500,001 -1,000,0009
>1,000,0019
Tank Size
(gai)
B
500
1,000
2,000
7,500
10,000
12,000
NA
NA
Tank
Cost1'2
C
$6,650
$9,020
$12,660
$29,790
$34,980
$39,630
NA
NA
Tank Control &
Accessories3
D= C*0.4
$2,660
$3,610
$5,070
$11,920
$14,000
$15,860
NA
NA
Slab-on-
grade4'5
E
$1,180
$1,640
$2,100
$4,010
$5,280
$6,290
NA
NA
Installation6
F=(C+D+E)*
0.2
$2,100
$2,850
$3,970
$9,140
$10,850
$12,360
NA
NA
Total Cost
(2007$)7'8
G=(C+D+E+
F)*1.225
$15,430
$20,980
$29,160
$67,210
$79,760
$90,830
NA
NA
  1 Assumes standard horizontal tanks for 100 psi working pressure including standard fittings and freight.
  2 Cost estimates obtained from USABIueBook Catalog (2008) adjusted to 2007 dollars.
  3 Assumes 40% of the Tank Cost.
  4 Assumes a 4-inch slab.
  5 Assumes $184.43/cubic yard. Source: R.S. Means, 2009.
  6 Assumes 20% of the total cost of the tank, tank control and accessories, and slab-on-grade.
  7 Includes 22.5% overhead and profit, based on  R.S. Means (2009).
  8 Estimates rounded up to the nearest $10.
  9 Surge control tanks not typically used in larger systems (serving >500,000 customers).

5.5    Maintenance of Appropriate Hydraulic Residence Time

       As water travels through the distribution system, chlorine continues to react with natural
organic matter (NOM) to form disinfection by-products (DBFs). Thus, increased water age can
lead to higher DBF concentrations. Other water quality problems associated with increased
water age include reduced disinfectant residual, increased microbial activity, nitrification, and/or
taste and odor problems. Water systems should develop an overall strategy to manage the water
age in their distribution systems.  Establishing a water age goal is system-specific depending on
system design and operation, water demands, and water quality (e.g. DBF formation potential).
In the US,  the average distribution system retention time is 1.3 days and the average maximum
retention time is 3.0 days based on a survey of 800 medium and large water utilities (AWWA
and AwwaRF 1992). Water age can be controlled through a variety of techniques including
management of finished water storage facilities, looping of dead-ends, and re-routing of water by
changing valve settings.  Additional guidance is provided in the AwwaRF report, Managing
Distribution System Retention Time to Improve Water Quality (Brandt et al. 2004).

5.5.1  Loop Dead Ends

       Dead end pipes often result in stagnant water conditions where water age increases,
which can cause water quality problems.  One of the solutions to address the stagnant water issue
is looping of dead ends.  However, looping should be evaluated carefully on a case-by-case basis
as it may not actually reduce the long detention times present in those areas.

       The cost associated with installing loops to eliminate dead ends is the same as to replace
or repair ductile iron pipe lines presented in Exhibit 5-6.
March 2009 Revised Total Coliform Rule
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5.5.2  Install Appropriate Main Sizes

       Most distribution systems have been designed to meet a minimum hydraulic capacity.
Additional capacity is generally included at the design stage to accommodate for future growth
or to allow more flexibility in the configuration of a distribution system network.  A PWS may
also have a policy to limit the number of different pipe diameters within the system in order to
simplify construction and maintenance. Consequently network pipes tend to be larger than is
necessary to meet the daily demand from the network leading to increased retention time.
Hence, there can be an option to replace mains with smaller diameter pipes but still maintain the
required hydraulic capacity.

       The cost associated with installing  appropriate water main sizes is the same as to replace
or repair ductile iron pipe lines presented in Exhibit 5-6.

5.5.3  Install Automated Flushing Devices

       Automated flushing devices are used to purge accumulated sediments at low spots and
dead-ends of pipelines at regular intervals and for draining pipelines for repairs, maintenance,
and inspection.  These devices are best suited to rural networks in which security of the units and
disposal of the water flushed is less problematic.  An additional drawback of installing these
devices is the volume and value of the wasted water may be unacceptable.  However, in
networks with long pipe runs terminating in dead ends, there may be few viable alternatives to
flushing for controlling retention time.

       Exhibit 5-19 presents the cost of installing automatic flushing devices, including the
material cost and in-house labor, assuming an 8-hour shift and 2-person work crew are required
for installation of an above-ground flushing device.

        Exhibit 5-19:  Estimated Costs to Install Automated Flushing Devices
System Size
A
<500
501 -1,000
1,001 -4,100
4,101 -33,000
33,001 -
96,000
96,001 -
500,000
500,001 -
1,000,000
> 1,000,001
Labor
Rate1
B
$25.75
$28.96
$29.73
$36.00
$36.39
$41.01
$41.01
$41.01
Shift
Time (hours)
C
8
8
8
8
8
8
8
8
Total
Labor Cost2
D=B*C*2
$420
$470
$480
$580
$590
$660
$660
$660
Automate
d Flushing
Device Cost3'4
E
$3,190
$3,190
$3,190
$3,190
$3,190
$3,190
$3,190
$3,190
Total Cost
(2007$)5
F=D+E
$3,610
$3,660
$3,670
$3,770
$3,780
$3,850
$3,850
$3,850
  1 See Exhibit 2-6 in Chapter 2. Estimated Unit Costs of Labor.
  2 Labor cost assumes a two person crew working for a total of 8 hours each.
  3 Assumes a long-neck standard unit, installed at a depth of 3 feet.
  4 Automated flushing device costs obtained from Hydro Guardฎ catalog, 2008.
  5 Estimates rounded up to the nearest $10.
March 2009 Revised Total Coliform Rule
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5.5.4  Storage Facility Modifications

       Most storage facilities have been designed focusing more on quantity, cost, service life,
appearance and shape than on maintaining water quality.  Water quality in storage facilities is
affected by the mixing patterns that occur primarily during the filling cycle, the long term
residence time, and the interaction between these two phenomena.

       Increasing volume turnover reduces the average hydraulic residence time (HRT) in
finished water storage facilities, thereby reducing DBF formation, loss of disinfectant and
microbial growth. Kirmeyer et al. (2000b) recommend complete turnover every three to five
days but suggest that water systems establish their own turnover goal based on system-specific
needs and goals.

       Improving mixing in finished water storage facilities can help eliminate stagnant zones.
Old water in stagnant zones can often have very high DBFs and no or low disinfectant residual.
This water can be released into the system during periods of high demand.  Mixing can be
improved by increasing inlet momentum, changing the inlet configuration, increasing the fill
time, and by installing mixing devices within the storage facility.

5.5.4.1 Modify Inlet/Outlet Piping

       Inlet/outlet configuration is critical in the development of proper mixing in a finished
water storage facility.  The inlet/outlet structure should be located and sized to disperse the jet
into the storage facility as well as to maintain a jet sufficient for mixing. In particular, the
location and orientation of the inlet pipe relative to the tank walls can have a significant impact
on mixing characteristics, while the outflow characteristics do not significantly influence mixing.
The physical modifications to the inlet pipe for improving mixing within the tanks include:

            • Changing the orientation of the inlet pipe and/or
            • Decreasing the inlet diameter to increase the jetting action.

       When the inlet/outlet is a common pipe, the ability to reduce the inlet diameter to achieve
a higher inflow velocity and better jetting action will be constrained by the need to maintain an
outflow capacity  adequate to satisfy system operational and fire flow requirements.  For this
reason, it is  recommended to eliminate the common inlet/outlet pipe.

       Exhibit 5-20 presents the cost of modifying the inlet/outlet configuration, including the
pipes and related materials (e.g. valves), installation, and profit and overhead costs.  Because
these modifications are very site-specific and based on tank geometry, materials costs were
estimated as 10% of the piping and related materials cost associated with installation of a new
elevated storage tank, as identified in Exhibit 5-16 (column E). Installation was estimated as
20% of the materials cost based on similar experience at several PWSs. Note that this estimate
does not include the cost of designing the new inlet/outlet configuration.
March 2009 Revised Total Coliform Rule         5-23        Draft - Please do not cite, quote, or distribute
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              Exhibit 5-20: Estimated Costs to Modify Inlet/Outlet Piping
System Size
A
<500
501 -1,000
1,001 -4,100
4,101 -33,000
33,001 -96,000
96,001 -500,000
500,001 -
1,000,000
> 1,000,001
Tank Size
(gai)
B
50,000
100,000
250,000
500,000
1,000,000
1,000,000
2,000,000
2,000,000
PipeS
Related
Materials Cost1
C
$6,980
$9,620
$13,260
$21,400
$29,670
$29,670
$59,340
$59,340
Installation
Cost2
D=0.2*C
$1,400
$1,930
$2,660
$4,280
$5,940
$5,940
$11,870
$11,870
Total Cost
(2007$)3'4
E=(C+D)*1.225
$10,270
$14,150
$19,500
$31,460
$43,620
$43,620
$87,230
$87,230
  1 Assumes 10% of the Piping & Related Materials Cost of installing a new storage tank presented in Exhibit 5-16, column E.
  2 Assumes installation equal to 20% of the materials cost.
  3 Estimates rounded up to the nearest $10.
  4Assumes and includes a 22.5% Overhead and Profit cost, based on R.S. Means (2009).

5.5.4.2 Install Mixing Devices

       Mixing the storage facility contents to reduce stagnant zones can also be accomplished by
installing mixing devices.  Special precautions are needed with mechanical mixing devices
because of potential contamination to finished water by the mixer mechanism lubrication system.
Multiple mixing devices may be needed and the PWS should consider the increased maintenance
requirements inside the storage facility.

       Exhibit 5-21 presents the cost of installing mixing devices in the storage facilities,
including the mixing device, the pipes and related materials (e.g. valves) and installation costs.
Mixing system costs were obtained from vendor quotes, while piping and related materials costs
were assumed to be 10% of the piping and related materials costs associated with installation of a
new elevated storage tank, as identified in Exhibit 5-16 (column E).  Installation was estimated
as 20% of the total equipment and materials cost based on  similar experience at several PWSs.
March 2009 Revised Total Coliform Rule
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                Exhibit 5-21: Estimated Costs to Install Mixing Devices
System Size
A
<500
501 - 1,000
1,001 -4,100
4,101 -33,000
33,001 - 96,000
96,001 - 500,000
500,001 -
1,000,000
> 1,000,001
Tank Size
(gal)
B
50,000
100,000
250,000
500,000
1,000,000
1,000,000
2,000,000
2,000,000
Mixing
System
Cost1
C
$1,650
$3,290
$8,230
$16,450
$32,900
$32,900
$65,800
$65,800
Pipes &
Related
Materials Cost2
D
$6,980
$9,620
$13,260
$21 ,400
$29,670
$29,670
$59,340
$59,340
Installation
Cost3
E=0.2*(C+D)
$1,730
$2,590
$4,300
$7,570
$12,520
$12,520
$25,030
$25,030
Total Cost4
(2007$)
F=1.225*(C+
D+E)
$12,690
$18,990
$31,590
$55,640
$91,990
$91,990
$183,960
$183,960
  1 Assumes a mixing system by TideFlex Technologies (Carnegie, PA).
  2 Assumes 10% of the Piping & Related Materials Cost of installing a new storage tank presented in Exhibit 5-16, column E.
  3 Assumes installation equal to 20% of the total equipment and materials cost.
  4Assumes and includes a 22.5% Overhead and Profit cost, based on R.S. Means (2009).

5.5.4.3  Modify Storage Operation
       As mentioned earlier in this section, increasing the volume turnover reduces the average
HRT in the storage tank. Turnover can be accomplished by making operational modifications to
the storage tank such as increasing the water level fluctuation or drawdown between fill and
draw cycles.  The water level should be lowered in one continuous operation not small
incremental drops throughout the day.
       Operational modifications may be limited by the following considerations:

             • Control of flow rates during tank filling may be needed to minimize the potential
       for low pressure in the distribution system;

             • Changes in operating protocol for booster stations and other tanks to achieve
       turnover while maintaining adequate pressure system-wide.
       Exhibit 5-22 presents the costs associated with modifying a storage operation. The costs
included in this action are the operator labor costs associated with the time spent analyzing the
different storage operation alternatives, selecting the most appropriate for their system and
implementing it.  For PWSs serving more than 1,001 customers, it was assumed that it would
also be necessary to reprogram the Supervisory Control and Data Acquisition SCADA system
and therefore there is an additional cost for the programmer time. In many systems, a SCADA
system is used to automatically control pumps, and the system would need to be reprogrammed
to incorporate any changes to the control logic.
March 2009 Revised Total Coliform Rule
Technology and Cost Document
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              Exhibit 5-22: Estimated Costs to Modify Storage Operation
System Size
A
<500
501 - 1,000
1,001 -4,100
4,101 -33,000
33,001 - 96,000
96,001 - 500,000
500,001 - 1,000,000
> 1,000,001
Labor Rate1
B
$25.75
$28.96
$29.73
$36.00
$36.39
$41.01
$41.01
$41.01
Labor Time
(hours)2
C
8
8
8
8
8
8
8
8
Programmer
Rate3'4
D
NA
NA
$120
$120
$120
$120
$120
$120
Programming
Time (hours)
E
NA
NA
8
8
8
8
8
8
Total Cost
(2007$)
F=B*C+D*E
$210
$240
$1,200
$1,250
$1,260
$1,290
$1,290
$1,290
  1 See Exhibit 2-6 in Chapter 2. Estimated Unit Costs of Labor.
  2 Assumes 8 hours of operator time to analyze operational changes.
  3 Assumes average programmer rate of $120 per hour (in 2007 dollars), which is independent of system size.
  4 Assumes systems serving <1,000 do not use SCADA systems and therefore require no programming time.

5.5.4.4 Decommission Storage

       Decommissioning storage facilities may be an appropriate strategy to reduce water age if
existing facilities are oversized and not needed for emergency conditions, fire protection, or for
maintaining system pressure.  A professional engineer should review system needs, system
design, and operation to determine if the existing storage capacity is appropriate.

       Exhibit 5-23 presents the  cost associated with the decommissioning of a storage tank,
including the labor hours of in-house staff to drain the storage tank, close valves and oversee the
work of the outside company that will clean the tank.

                Exhibit 5-23: Estimated  Costs to Decommission Storage
System Size
A
<500
501 -1,000
1,001 -4,100
4,101 -33,000
33,001 -96,000
96,001 -500,000
500,001 -1,000,000
> 1,000,001
Tank Size (gal)
B
50,000
100,000
250,000
500,000
1,000,000
1,000,000
2,000,000
2,000,000
Labor Rate1
C
$25.75
$28.96
$29.73
$36.00
$36.39
$41.01
$41.01
$41.01
Time
(hours)
D
8
8
8
8
8
8
8
8
Total Labor
Cost2
E=C*D*2
$420
$470
$480
$580
$590
$660
$660
$660
Tank
Cleaning
Cost3
F
$1,510
$1,830
$3,190
$5,020
$7,750
$7,750
$9,110
$9,110
Total Cost
(2007$)4
G=E+F
$1,930
$2,300
$3,670
$5,600
$8,340
$8,410
$9,770
$9,770
  1 See Exhibit 2-6 in Chapter 2. Estimated Unit Costs of Labor.
  2 Labor cost assumes a two-person crew and 8-hour shift.
  3 Includes cost of tank cleaning, as presented in Exhibit 5-24.
  4 Estimates rounded up to the nearest $10.
March 2009 Revised Total Coliform Rule
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5.6    Storage Facility Maintenance

       Finished water storage tanks are an important component of a PWS's distribution system.
Tanks are usually designed for three purposes: reduce pressure fluctuations in the distribution
system, equalize water demands, and provide water reserves for emergencies such as fires and
power outages.

       The two main categories of water storage tanks include ground storage tanks and elevated
storage tanks. Ground storage tanks can be below grade, partially below grade, or at ground
level in a distribution system and are usually constructed of a variety of materials, including
steel, concrete, and fiberglass reinforced plastic.  Elevated storage tanks are typically constructed
of steel.

       Contamination from birds and insects can be a source of microbial contamination in the
distribution system.  Maintenance to a storage tank can significantly reduce the possibility of
contamination. Some actions include  inspecting and cleaning,  lining the interior of the tank,
repairing vents and/or hatches, and repairing the tank itself.

5.6.1   Inspecting/Cleaning of Tanks

       Tank inspections can provide useful information on the physical condition of the exterior
and interior of the tank, identifying potential sources of microbial contamination. Inspections
can also identify the  accumulation of sediment within storage tanks due to particle settling in the
tank or the dissolving of cementitious materials of a concrete tank from soft, low alkalinity, low
pH waters. There are several water quality issues associated with sediment buildup in a storage
tank, including increased disinfection  demand, microbial growth, disinfection by-product
formation, and increased turbidity.

       Exhibit 5-24  presents the costs associated with inspecting and cleaning various sized
finished water storage tanks. Assumptions regarding tank size were made based on population
served.  All tanks were assumed as elevated; ground storage tanks may have slightly lower costs
as they are easier to access.  The costs include inspection, cleaning, labor, equipment, and
insurance costs.

  Exhibit 5-24: Estimated Costs for the Inspection and Cleaning of Storage Tanks
System Size
A
<500
501 -1,000
1,001 -4,100
4,101 -33,000
33,001 - 96,000
96,001 - 500,000
500,001 -1,000,000
> 1,000,001
Tank Size
(gal)
B
50,000
100,000
250,000
500,000
1,000,000
1,000,000
2,000,000
2,000,000
Tank Type
C
Elevated
Elevated
Elevated
Elevated
Elevated
Elevated
Elevated
Elevated
Total Cost1'2
(2007$)
D
$1,510
$1,830
$3,190
$5,020
$7,750
$7,750
$9,110
$9,110
  1 Cost includes inspection, labor, equipment, and insurance.
  2 Costs obtained from Pittsburg Tank & Tower Maintenance Co., Inc.
March 2009 Revised Total Coliform Rule
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       5.6.2  Lining of Storage Tanks

       Lining the interior of a water storage tank is another action that can be taken to reduce the
potential for coliform contamination of a distribution system. Corrosion and corrosion product
buildup from excessive interior corrosion can also result in water quality issues such as increased
disinfection demand, microbial growth, and increased turbidity.

       The costs associated with lining the interior of various sized water storage tanks are
presented in Exhibit 5-25.  The tank sizes and types presented were assumed to be present in a
distribution system serving the associated population range. The costs include material, labor,
equipment, and insurance costs, and assume an existing layer is required to be stripped from the
tank's interior surface.

            Exhibit 5-25: Estimated Costs for the Lining of Storage Tanks
System Size
A
<500
501 -1,000
1,001 -4,100
4,101 -33,000
33,001 - 96,000
96,001 - 500,000
500,001 -
1,000,000
> 1,000,001
Tank Size (gal)
B
50,000
100,000
250,000
500,000
1,000,000
1,000,000
2,000,000
2,000,000
Tank Type
C
Elevated
Elevated
Elevated
Elevated
Elevated
Elevated
Elevated
Elevated
Total Cost
(2007$)1'2
D
$28,380
$35,530
$63,770
$88,830
$150,320
$150,320
$200,420
$200,420
  1 Cost includes stripping existing coating, material, labor, equipment, and insurance
  2 Costs obtained from Pittsburg Tank & Tower Maintenance Co., Inc

5.6.3  Vent/Hatch Repair

       One of the most common sources of contamination in a water storage tank is the
improper design and maintenance of vents and roof hatches. These accessories can provide entry
points for debris as well as microbial contamination from birds and insects.

       Exhibit 5-26 presents the costs associated with replacing a storage tank's vent screen.
Costs are presented on a per vent screen basis. Labor costs were calculated based on a two-
person crew and two hours for installation. Exhibit  5-27 presents similar installed costs of repair
or replacement of a storage tank hatch.
March 2009 Revised Total Coliform Rule
Technology and Cost Document
5-28
Draft - Please do not cite, quote, or distribute

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 Exhibit 5-26: Estimated Costs for the Repair/Replacement of a Storage Tank Vent
System Size
A
<500
501 -1,000
1,001 -4,100
4,101 -33,000
33,001 -96,000
96,001 -500,000
500,001 -1,000,000
> 1,000,001
Labor Rate1
C
$25.75
$28.96
$29.73
$36.00
$36.39
$41.01
$41.01
$41.01
Shift Time
(hours)
D
2
2
2
2
2
2
2
2
Total Labor
Cost2
E=C*D*2
$110
$120
$120
$150
$150
$170
$170
$170
Vent Screen
Cost3
F
$50
$50
$50
$50
$50
$50
$50
$50
Total Cost
(2007$)
G=E+F
$160
$170
$170
$200
$200
$220
$220
$220
  1 See Exhibit 2-6 in Chapter 2. Estimated Unit Costs of Labor
  2 Labor cost assumes a two-person crew working for a total of 2 hours
  3 Assumes 2-inch wide steel screen frame, 12-inch vent diameter, 6.9 Ib/ft2 area weight, $1.37/lb frame cost and $45 screen cost


    Exhibit 5-27:  Estimated Costs for the Repair/Replacement of a Storage Tank
                                           Hatch
Item
A
6 ft. x 6 ft. Hatch
Total Cost (2007$)1'2
B
$3,190
  1 Hatch cost assumed 6 ft. by 6 ft. fiberglass hatch, including materials, labor, and mobilization.
  2 Hatch costs obtained from The Crom Corporation.

5.6.4   Tank Repair

        Aging water storage tanks with damaged tank covers can also be a source of microbial
contamination. Exhibit 5-28 presents estimated costs for repairing water storage tank covers for
various tank sizes and types assumed to be present in a distribution system serving the associated
population range. These cost estimates assume a repair cost equal  to 20% of the installed cost of
a new tank, which includes material, labor, overhead, and profit.
March 2009 Revised Total Coliform Rule
Technology and Cost Document
5-29
Draft - Please do not cite, quote, or distribute

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            Exhibit 5-28: Estimated Costs for the Repair of Storage Tanks
System Size
A
<500
501 -1,000
1,001 -4,100
4,101 -33,000
33,001 - 96,000
96,001 - 500,000
500,001 -
1,000,000
> 1,000,001
Tank Size
(gal)
B
50,000
100,000
250,000
500,000
1,000,000
1,000,000
2,000,000
2,000,000
Tank
Type
C
Elevated
Elevated
Elevated
Elevated
Elevated
Elevated
Elevated
Elevated
New Tank
Cost1
D
$202,240
$278,770
$384,440
$620,390
$859,980
$859,980
$1,719,970
$1,719,970
Total Cost2
(2007$)
E=0.2*D
$40,448
$55,754
$76,888
$124,078
$171,996
$171,996
$343,994
$343,994
  1 Assumes installed cost of a new elevated storage tank, as presented in Exhibit 5-16.
  2 Tank repair costs estimated at 20% of new tank costs.

5.7    Booster Disinfection

       Booster disinfection facilities located throughout a distribution system can provide
additional chemical treatment in the system.  Booster disinfection can improve or maintain
disinfectant residual levels  in a distribution system.  Prior to discharge into the system, potable
water from a treatment facility must have a certain disinfectant residual level to minimize
microbial growth.  These levels are defined by state  and government regulations.  Organics and
reduced metals in the water also consume disinfectant residuals; therefore, it is vital to maintain
an appropriate disinfectant  residual level in the system in order to avoid increased levels of total
coliform in the system.

       The following sections present costs associated with installation of both chlorine and
chloramines booster disinfection facilities. The booster disinfection facilities were sized based
on the system size, type of  chemical treatment, and permanent or temporary system.  Permanent
systems were assumed to be operating all year round and providing 30 days of chemical storage.
It is assumed that an operator would visit the facility for one hour each day. These systems are
assumed to constantly maintain disinfectant residual levels in a system. They would be placed in
locations that typically had low disinfectant residual levels.  Temporary systems were assumed to
operate one day and provide one day of chemical storage. It is assumed that an operator would
visit the facility for two hours for the day the system was in operation. These systems are
assumed to operate at times when disinfectant residuals levels were low for a distribution system;
however, these distribution systems would only experience low residuals at various times of the
year.  Some systems experience higher levels of organic growth at certain times of the year,
particularly the summer months. Therefore, the booster disinfection facilities are not required to
operate all year round.

       The capital costs of the facilities include feed equipment, storage, required piping and
appurtenances, electrical and instrumentation equipment, a building, and installation. Buildings
were sized to provide adequate spacing between the  chemical feed equipment. Yearly operation
and maintenance costs include labor, chemical, and parts and maintenance costs.
March 2009 Revised Total Coliform Rule
Technology and Cost Document
5-30
Draft - Please do not cite, quote, or distribute

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5.7.1  Chlorine System

       Most systems currently use chlorine as their main disinfectant. Exhibits 5-29 and 5-30
show various chlorine facility sizes. Based on the facility size, either a tablet chlorinator or a
liquid hypochlorite system was provided. It was assumed that these systems would provide a 1.0
mg/L chlorine dosage.

       The tablet chlorinator systems used calcium hypochlorite tablets.  These tablets are
placed in a chlorinator where water from the main line is introduced at a controlled rate to erode
the tablets. A pump then injects the chlorinated solution back into the main line. These facilities
did not require a storage container. The manufacturer provided the tablets in large buckets.
Liquid hypochlorite systems consisted of solenoid diaphragm feed pumps and chemical storage.

5.7.1.1  Permanent System

       For permanent systems, it is assumed that either one tablet chlorinator system was
provided or two feed pumps were provided depending on the system size. Two feed pumps were
provided to have one pump in operation and one on standby.  It is assumed that polyethylene
storage tanks were provided for liquid sodium hypochlorite storage. The number of tanks varied
depending on the system size. Exhibit 5-29 presents the estimated cost for the installation of a
permanent chlorine disinfection booster station. Costs to rehabilitate an  existing chlorine booster
station are assumed to be equal to the total cost of equipment for a new station, as presented in
Exhibit 5-29, Row K.

5.7.1.2  Temporary System

       For temporary systems, it was assumed that each of the facilities  would have liquid
hypochlorite systems; therefore, each facility was equipped with a single feed pump. There was
no permanent chemical storage at these facilities. Exhibit 5-30 presents  the estimated cost for
the installation of a temporary chlorine disinfection booster station.
March 2009 Revised Total Coliform Rule         5-31         Draft - Please do not cite, quote, or distribute
Technology and Cost Document

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                     Exhibit 5-29:  Estimated Costs to Install a Permanent Chlorine Booster Disinfection Station
Cost Component
Tablet Chlorinator System1
Usage Rate (Ib/hr)
System Size (Ib/hr)
System Cost2
Liquid Hypochlorite System1
Usage Rate (gal/hr)
Pump Size (gal/hr)
Total Pump Cost (two pumps)3
Storage Requirement4 (gal)
Storage Tank Cost3
Cost of Piping and Appurtenances5
Cost of Instrumentation and Electrical5
Total Cost of Equipment
Total Structure CostB
Cost of Installation'
Total Capital Cost (2007$f
Labor Cost ($/year)9
Chemical Cost ($/year)10
Parts and Maintenance Cost ($/year)11
Yearly Operation and Maintenance Cost

A
B
C

D
E
F
G
H
I
J
K=C+F+H+I+J
L
M=0.15*(K+L)
N=K+L+M
O
P
Q=0.1*K
R=O+P+Q
Population Size Category
<500

0.01
0.5
$6,840

-
-
-
-
-
$250
$250
$7,340
$4,200
$1,740
$16,270
$9,400
$1,200
$740
$11,540
501 to
1,000

0.01
0.5
$6,840

-
-
-
-
-
$250
$250
$7,340
$4,200
$1,740
$16,270
$10,800
$1,200
$740
$12,740
1,001 to
4,100

0.04
0.5
$6,840

-
-
-
-
-
$250
$250
$7,340
$4,200
$1,740
$16,270
$10,800
$1,200
$740
$12,740
4, 100 to
33,000

-
-
-

0.32
0.55
$1,100
300
$640
$270
$270
$2,280
$9,660
$1,800
$16,840
$13,200
$6,000
$230
$19,430
33,001 to
96,000

-
-
-

1.12
1.9
$1,190
900
$1,190
$360
$360
$3,100
$9,660
$1,920
$17,990
$13,200
$15,600
$310
$29,110
96,001 to
500,000

-
-
-

1.55
1.9
$1,190
1,200
$1,010
$330
$330
$2,860
$12,940
$2,370
$22,260
$14,400
$20,400
$290
$35,090
500,001 to
1,000,000

-
-
-

3.91
5
$1,190
2,900
$2,010
$480
$480
$4,160
$23,780
$4,200
$39,380
$14,400
$48,000
$420
$62,820
>1, 000,001

-
-
-

7.82
8.4
$1,640
5,700
$6,930
$1,290
$1,290
$11,150
$26,060
$5,590
$52,430
$14,400
$92,400
$1,120
$107,920
1 Tablet chlorinator systems assumed for system sizes 10,000 and less; liquid hypochlorite systems assumed for system sizes 10,001 and greater
2 Table chlorinator system cost obtained from vendor.
3 Pump and tank cost per Cole Palmer catalog (2008), adjusted to 2007 dollars. Pumps are solenoid diaphragm metering pumps and tanks are polyethylene tanks.
4 Storage requirements based on providing approximately 30 days of chemical storage.
5 Assumes 15% of chemical system and storage costs.
6 Structure cost includes building and slab per R.S. Means (2009), adjusted to 2007 dollars.
7 Assumes 15% of equipment and structure costs.
8 Includes 22.5% overhead and profit, based on R.S. Means (2009).
9 Assumes one hour of maintenance a day and labor rates presented in Exhibit 2-6 of Section 2. Estimated Unit Costs of Labor.
10 Chemical cost per chemical supplier ($2.50 per Ib of chlorine tablets and $1.35 per gallon of hypochlorite).
11 Assumes 10% of equipment cost.
March 2009 Revised Total Coliform Rule
Technology and Cost Document
5-32
Draft - Please do not cite, quote, or distribute

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                   Exhibit 5-30: Estimated Costs to Install a Temporary Chlorine Booster Disinfection Station
Cost Component
Usage Rate (gal/hr)
Pump Size (gal/hr)
Total Pump Cost (one pump)1
Storage Requirement (gal)
Type of Storage Container2
Cost of Piping and Appurtenances'3
Cost of Instrumentation and Electrical3
Total Cost of Equipment
Total Structure Cost4
Cost of Installation5
Total Capital Cost (2007$)6
Labor Cost ($/year)7
Chemical Cost($/year)8
Parts and Maintenance Cost ($/year)9
Yearly Operation and Maintenance Cost
A
B
C
D
E
F=0.15*C
G=0.15*C
H=C+F+G
I
J=0.15*(H+I)
K=H+I+J
L
M
N=0.1*H
O=L+M+N
Population Size Category
<500
0.01
0.19
$540
10
Carboy
$90
$90
$720
$930
$250
$1,900
$60
$90
$80
$230
501 to
1,000
0.04
0.19
$540
10
Carboy
$90
$90
$720
$1,000
$260
$1,980
$60
$90
$80
$230
1,001 to
4,100
0.04
0.19
$540
10
Carboy
$90
$90
$720
$1,000
$260
$1,980
$60
$90
$80
$240
4, 100 to
33,000
0.32
0.55
$560
10
Drum
$90
$90
$740
$1,460
$330
$2,530
$80
$90
$80
$250
33,001 to
96,000
1.12
1.9
$640
30
Drum
$100
$100
$840
$1,660
$380
$2,880
$80
$90
$90
$260
96,001 to
500,000
1.55
1.9
$640
40
Drum
$100
$100
$840
$1,660
$380
$2,880
$90
$90
$90
$270
500,001 to
1,000,000
3.91
5
$730
100
Drum
$110
$110
$950
$2,100
$460
$3,510
$90
$170
$100
$360
>1, 000,001
7.82
8.4
$820
190
Tote
$130
$130
$1,080
$4,190
$800
$6,070
$90
$450
$110
$650
1 Pump cost per Cole Palmer catalog (2008), adjusted to 2007 dollars. Pumps are solenoid diaphragm metering pumps.
2 Assumes storage containers obtained from chemical supplier, and returned for refund of any applicable deposit.
3 Assumes 15% of pump costs.
4Structure cost includes building and slab per R.S. Means, 2009.
5 Assume 15% of equipment and structure costs.
6 Assume two hours of maintenance a day based on labor rates presented in Exhibit 2-6 of Section 2. Estimated Unit Costs of Labor
1 Includes 22.5% overhead and profit, based on R.S. Means, 2009.
8 Chemical cost based on minimum chemical delivery volume per chemical vendor.
9 Assumes 10% of equipment cost.
March 2009 Revised Total Coliform Rule
Technology and Cost Document
5-33
Draft - Please do not cite, quote, or distribute

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5.7.2  Chloramine System

       Some utilities use combined chlorine, or chloramine, as a secondary disinfectant.  For
these systems to provide residual boosting, an aqua ammonia feed is required in addition to a
chlorine feed system. Exhibits 5-31 and 5-32 outline costs for a chloramine feed system similar
to the permanent and temporary systems that were previously described for free chlorine. It was
assumed that these systems would provide a 1.0 mg/L total chlorine dosage. In addition to the
chlorine system, an aqua ammonia feed system was provided in order to produce chloramines. It
was assumed that these systems would provide a 0.2 mg/L of ammonia dosage.

5.7.2.1 Permanent System

       For permanent systems, the aqua ammonia feed system included two solenoid pumps,
one in operation and one on standby.  Chemical storage varied depending on the required amount
of ammonia. It was assumed that systems requiring 500 gallons or greater of storage would
install stainless steel storage tanks.  Systems that required less would either obtain a 250 gallon
tote or 55 gallon drum from the chemical supplier depending on the required amount of
ammonia. Exhibit 5-31 presents the estimated cost for the installation of a permanent
chloramine booster station. Estimated costs to rehabilitate an existing chloramine booster station
are  assumed to be equal to the total cost of equipment for a new station, as presented in Exhibit
5-31, Row P.

5.7.2.2 Temporary System

       For temporary systems, it was assumed each was equipped with a  single feed pump.
There was no permanent chemical storage at these facilities. Exhibit 5-32 presents the estimated
cost for the installation of a temporary chloramine booster station.
March 2009 Revised Total Coliform Rule             5-34      Draft - Please do not cite, quote, or distribute
Technology and Cost Document

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              Exhibit 5-31: Estimated Costs to Install a Permanent Chloramines Booster Disinfection Station
Cost Component
Tablet Chlorinator System1
Usage Rate (Ib/hr)
System Size (Ib/hr)
System Cost2
Liquid Hypochlorite System1
Usage Rate (gal/hr)
Pump Size (gal/hr)
Pump Cost3
Storage Requirement (gal)4
Storage Tank Cost3
Aqua Ammonia System
Usage Rate (gal/hr)
Pump Size (gal/hr)
Pump Cost3
Storage Requirement(gal)4
Storage Tank Cost3
Cost of Piping and
Appurtenances5
Cost of Instrumentation and
Electrical5
Total Cost of Equipment
Total Structure Cost($/year)6
Cost of Installation7
Total Capital Cost (2007$f

A
B
C

D
E
F
G
H

I
J
K
L
M
N=0.15*(C+F+
H+K+M)
O=0.15*(C+F+
H+K+M)
P=C+F+H+K+
M+N+O
Q
R=0.15*(P+Q)
S=P+Q+R
Population Size Category
<500

0.01
0.5
$6,840

-
-
-
-
-

0.002
0.19
$1,100
10
-
$420
$420
$8,780
$7,870
$2,500
$23,460
501 to
1,000

0.01
0.5
$6,840

-
-
-
-
-

0.002
0.19
$1,100
10
-
$420
$420
$8,780
$7,930
$2,510
$23,550
1,001 to
4,100

0.04
0.5
$6,840

-
-
-
-
-

0.007
0.19
$1,100
10
-
$420
$420
$8,780
$7,930
$2,510
$23,550
4, 100 to
33,000

-
-
-

0.32
0.55
$1,100
300
$640

0.049
0.19
$1,100
40
-
$430
$430
$3,700
$15,580
$2,900
$27,180
33,001 to
96,000

-
-
-

1.12
1.9
$1,190
900
$1,190

0.169
0.29
$1,100
130
-
$530
$530
$4,540
$15,580
$3,020
$28,350
96,001 to
500,000

-
-
-

1.55
1.9
$1,190
1200
$1,010

0.235
0.29
$1,100
170
-
$500
$500
$4,300
$19,590
$3,590
$33,670
500,001 to
1,000,000

-
-
-

3.91
5
$1,190
2900
$2,010

0.591
1.10
$1,190
430
$18,220
$3,400
$3,400
$29,410
$37,450
$10,030
$94,200
>1, 000, 001

-
-
-

7.82
8.4
$1,640
5700
$6,930

1.183
1.90
$1,640
860
$20,780
$4,650
$4,650
$40,290
$41,910
$12,330
$115,800
March 2009 Revised Total Coliform Rule
Technology and Cost Document
5-35
Draft - Please do not cite, quote, or distribute

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Cost Component
Population Size Category
<500
501 to
1,000
1,001 to
4,100
4, 100 to
33,000
33,001 to
96,000
96,001 to
500,000
500,001 to
1,000,000
>1, 000,001
Operations & Maintenance Costs
Labor Cost($/year)9
Chemical Cost($/year)10
Parts and Maintenance Cost
($/year)11
Yearly O&M Cost
T
U
V=0.1*P
W=T+U+V
$9,400
$2,400
$880
$15,780
$10,800
$2,400
$880
$17,250
$10,800
$2,400
$880
$17,250
$13,200
$7,200
$370
$25,450
$13,200
$19,200
$460
$40,260
$14,400
$24,000
$430
$47,570
$14,400
$54,000
$2,950
$87,410
$14,400
$103,200
$4,030
$149,000
1 Tablet chlorinator systems assumed for system sizes 10,000 and less; liquid hypochlorite system assumed for system sizes 10,001 and greater.
2 Table chlorinator system cost obtained from vendor.
3 Pump and tank cost per Cole Palmer catalog (2008), adjusted to 2007 dollars. Pumps are solenoid diaphragm metering pumps and tanks are polyethylene tanks.
4 Storage requirements based on providing approximately 30 days of chemical storage.
5 Assume 15% of chemical system and storage costs
6 Structure cost includes building and slab per R.S. Means 2009
7 Assume 15% of equipment and structure costs
8 Includes 22.5% overhead and profit, based on R.S. Means
9 Assumes one hour of maintenance a day based on labor rates presented in Exhibit 2-6 of Section 2. Estimated Unit Costs of Labor.
10 Chemical cost per chemical supplier in 2009. ($2.50 per Ib of chlorine tablets, $1.35 per gallon of hypochlorite, and $0.99 per gallon of aqua ammonia).
11 Assumes 10% of equipment cost.
March 2009 Revised Total Coliform Rule
Technology and Cost Document
5-36
Draft - Please do not cite, quote, or distribute

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                 Exhibit 5-32: Estimated Costs to Install a Temporary Chloramine Booster Disinfection Station
Cost Component1
Liquid Hypochlorite System
Usage Rate (gal/hr)
Pump Size (gal/hr)
Pump Cost1
Storage Requirement (gal)
Type of Storage Container2
Aqua Ammonia System
Usage Rate (gal/hr)
Pump Size (gal/hr)
Pump Cost1
Storage Requirement (gal)
Type of Storage Container2
Cost of Piping and Appurtenances3
Cost of Instrumentation and Electrical'3
Total Cost of Equipment
Total Structure Cost4
Cost of Installation5
Total Capital Cost (2009$)6
Labor Cost7
Chemical CostB
Parts and Maintenance Cost9
Yearly Operation and Maintenance Cost

A
B
C
D
E

F
G
H
I
J
K=0.15*(C+H)
L=0.15*(C+H)
M=C+H+K+L
N
O=0.15*(M+N)
P
Q
R
S
T
Population Size Category
<500

0.01
0.19
$540
10
Carboy

0.002
0.19
$540
10
Carboy
$170
$170
$1,420
$1,920
$510
$4,720
$60
$150
$150
$370
501 to
1,000

0.01
0.19
$540
10
Carboy

0.002
0.19
$540
10
Carboy
$170
$170
$1,420
$1,920
$510
$4,720
$60
$150
$150
$370
1,001 to
4,100

0.04
0.19
$540
10
Carboy

0.007
0.19
$540
10
Carboy
$170
$170
$1,420
$1,920
$510
$4,720
$60
$150
$150
$370
4, 100 to
33,000

0.32
0.55
$560
10
Drum

0.049
0.19
$540
10
Carboy
$170
$170
$1,440
$2,920
$660
$6,150
$80
$150
$150
$390
33,001 to
96,000

1.12
1.90
$560
30
Drum

0.169
0.29
$540
10
Carboy
$170
$170
$1,440
$2,920
$660
$6,150
$80
$150
$150
$390
96,001 to
500,000

1.55
1.90
$560
40
Drum

0.235
0.29
$540
10
Carboy
$170
$170
$1,440
$2,920
$660
$6,150
$90
$150
$150
$400
500,001 to
1,000,000

3.91
5.00
$560
100
Drum

0.591
1.10
$560
20
Drum
$170
$170
$1,460
$3,560
$760
$7,090
$90
$230
$150
$490
>1, 000,001

7.82
8.40
$820
190
Tote

1.183
1.90
$820
30
Drum
$250
$250
$2,140
$6,020
$1,230
$11,510
$90
$510
$220
$840
 Pump cost per Cole Palmer catalog. Pumps are solenoid diaphragm metering pumps.
2 Assumes storage containers obtained from chemical supplier, and returned for refund of any applicable deposit.
3 Assume 15% of chemical systems costs
4 Structure cost includes building and slab per R.S. Means 2009
5 Assume 15% of equipment and structure costs
6 Includes 22.5% overhead and profit, based on R.S. Means
7Assume two hours of maintenance a day based on labor rates presented in Exhibit 2-6 of Section 2. Estimated Unit Costs of Labor
8 Chemical cost based on minimum chemical delivery volume (For hypochlorite a 55 gallon drum is $82.50 and a 300 gallon tote is $450.00, and for ammonia a 55 gallon drum is $54.45)
9 Assumes 10% of equipment cost.
March 2009 Revised Total Coliform Rule
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5.8    Cross-connection Control and Backflow Prevention Program

       Implementing a Cross-Connection Control and Backflow Prevention (CCCBFP)
Program, including the installation of backflow prevention assemblies and devices, can prevent
the flow of non-potable substances into the distribution system. When implementing the
CCCBFP Program, the drinking water system should adhere to applicable state and/or local
criteria, codes, and/or regulations.  Some codes or regulations may include documenting
installation procedures and the periodic testing of backflow prevention assemblies.

       CCCBFP can prevent the introduction of non-potable substances into the public water
supply due to backsiphonage or backpressure.  The cost components of a cross-connection
control and backflow prevention program can be broadly classified as:

   •   Cost of Backflow Prevention Assemblies and Devices, and
   •   Cost of Program Administration.  This can be further classified as program organization,
       system survey, record keeping costs, and enforcement.

       The relative cost of program administration is usually more significant for small systems
(i.e., typically systems serving populations less than or equal to 10,000) as these systems have
limited personnel performing many duties at once.  For large systems, the costs of the backflow
devices and assemblies' costs are usually more significant than the program administration costs.
This section provides the costs of installing a backflow prevention device and describes the items
included under program administration.

5.8.1   Backflow Prevention Assemblies and Devices

       Exhibit 5-33 presents the costs of installing a backflow prevention assembly (i.e., a
reduced pressure flanged iron assembly). This is usually the most expensive assembly and is
used in situations of highest hazard when backpressure and backsiphonage are both possible.
More information can  be found at (www.usc.edu/dept/fccchr).

       Systems should install above-grade housing with drainage and heat to protect the
equipment from freezing where systems cannot install valves indoors. Installation costs do not
include costs for this housing, or costs for engineering/construction. Maintenance of these
assemblies includes a minimum of annual testing and inspection.  In addition, the frequency for
performance monitoring and internal inspections (dismantling, cleaning, and repairs) should
occur based on local water quality conditions, the probability of contamination due to potential
backflow, and manufacturers' recommendations for the specific backflow prevention assembly.

       Backflow prevention equipment installation and maintenance is generally the consumer's
responsibility. However, depending on how a system implements the cross-connection control
and backflow prevention program, the customer and the PWS can share costs for the equipment
and equipment installation, inspection, testing, and maintenance.  The PWS, on the other hand, is
primarily responsible for the administration of cross-connection control and backflow prevention
and the inspection, review, and approval of all backflow prevention assemblies and devices.
Labor costs assume a three-person crew is required to dig a new vault and install the backflow
prevention device.

March 2009 Revised Total Coliform Rule             5-38     Draft - Please do not cite,  quote, or distribute
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         Exhibit 5-33: Estimated Costs for a Backflow Prevention Assembly
System Size
A
<500
501 -1,000
1,001 -4,100
4,101 -33,000
33,001 -96,000
96,001 -500,000
500,001 -1,000,000
> 1,000,001
Labor
Rate1
B
$25.75
$28.96
$29.73
$36.00
$36.39
$41.01
$41.01
$41.01
Shift
Time
(hours)
C
8
8
8
8
8
8
8
8
Total Labor
Cost2
D=B*C*3
$620
$700
$720
$870
$880
$990
$990
$990
Backflow
Preventer
Pipe Size (in.)
E
2.5
2.5
2.5
3
3
4
6
6
Backflow
Preventer
Cost3'4
F
$2,825
$2,825
$2,825
$2,950
$2,950
$3,725
$5,375
$5,375
Total Cost (2007$)5
G+D+F
$3,450
$3,530
$3,550
$3,820
$3,830
$4,720
$6,370
$6,370
1 See Exhibit 2-6 in Chapter 2. Estimated Unit Costs of Labor
2 Labor cost assumes a three-person crew working for a total of 8 hours.
3 Backflow preventer cost assumed a reduced pressure principle, flanged, including valves, four test cocks, and corrosion resistant.
4 Costs do not include design or permit costs.
5 Estimates rounded up to the nearest $10

5.8.2  Program Administration

       The administration of a CCCBPP is typically the responsibility of the PWS.  Costs for
program administration depend on the system  size (population served and area covered), system
demographics (number of industrial, residential, and institutional customers), available staffing
resources, maintenance, record keeping, and specific code and regulatory requirements.  Another
factor in the administrative costs, in some cases, is overcoming political resistance.  The Cross-
Connection Control Manual provides additional guidance on program administration (USEPA,
1989c). Program administration will require availability  of technical and administrative staff. If
sufficient staff is available, appropriate division of program oversight duties may apply.
Otherwise, these tasks may require additional  staffer temporary help. In some cases, program
administration is contracted out. The Program Administration costs can be classified under three
headings:

    •  Program Organization: It involves establishing the legal foundation for the plan,
       establishing responsibilities and chain of command, conducting employee and consumer
       education programs, implementing required codes and regulations for enforcing the
       program, and monitoring the progress of the program.
    •  System Survey: It involves surveying the system for potential cross-connections and
       identifying and prioritizing hazardous connections.
    •  Record Keeping: It involves updating and maintaining records that are pertinent to the
       implementation of the CCCBPP.

       Exhibit 5-34 summarizes the activities  included under each of the three components of
Program Administration.
March 2009 Revised Total Coliform Rule
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      Exhibit 5-34: Cost Components of Program Administration for a Cross-
               Connection Control and  Backflow Prevention Program
    Cost Component
Specific Items Included
    Program Organization
   Consulting with relevant local and State administrations
   Establishing responsibilities and authorities for required program activities
   (inspections, maintenance, reporting, etc.)
   Notifying and educating employees and consumers of program and implications
   Developing and implementing a local ordinance
   Program enforcement by the PWS
      System Survey
                          •  Recording number and sites of connections Identifying potential hazardous
                             connections
                             Prioritizing hazardous connections
                             Developing inspection schedules and records
      Record Keeping
   Inspection records
   Installation, repair, and maintenance of records
   Customer correspondence records
   Ordinance development records
   Assembly test records
       In addition to the other items presented in this section, a successful cross connection
control program will require development of testing and enforcement programs to ensure proper
operation and compliance.  Such programs represent additional costs that would typically be
handled by a department other than then PWS (e.g. writing notices of violation, issuing fines,
preparing litigation); therefore these costs have not been included.

5.9    Addition or Upgrade of On-line Monitoring and Control

       Currently, monitoring of total coliform is performed through grab samples at the
treatment plant and throughout the distribution system. These grab samples are then analyzed in
a laboratory to determine whether TC is present or not in the grab sample.

       To ensure sufficient treatment has been provided, grab samples, disinfectant dosages, and
certain water quality parameters, such as disinfectant residual levels, can be correlated. Since
automatic monitoring is not available for TC, communities can control and monitor disinfectant
dosages and water quality parameters.

       Controlling and monitoring disinfectant dosages and water quality parameters through the
SCADA system performed at a treatment facility is relatively easily. Disinfectant dosing
equipment can be monitored and analyzers can be placed in the treatment process to monitor
water quality parameters.

       Monitoring water quality parameters via SCADA in a distribution system is possible;
however, it can be costly. Determining the number and location of the analyzers is challenging
and highly dependent upon the system size.  Typically, analyzer equipment will draw samples
from an above grade pipe or a sample tap to  an analyzer that is placed  in a building. Sample
locations will require analyzer equipment, a  building, electric power, and, in the case of some
systems, integration to the PWS's existing SCADA system.
March 2009 Revised Total Coliform Rule
Technology and Cost Document
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       In addition to water quality monitoring, a PWS can monitor pressure levels throughout
the distribution system to determine if there are any physical problems in the system, e.g., a
crack in a pipe, a leaking valve, etc., that cause changes to the water quality of the system.
Similar to the water quality monitoring, determining the number of pressure monitors and their
locations is dependent upon the system size. Pressure monitoring locations will also require the
same equipment as water quality sampling locations.

       On-line distribution system monitoring through the SCADA system can alert operators if
there are possible issues with the distribution system; however, monitoring the water quality or
pressure will not identify the  source of the contamination nor will it necessarily identify the
location of the contamination.

       The following sections provide costs for on-line monitoring equipment.  Costs provided
are for the installation of a single analyzer into an existing building; therefore, costs of a building
and electrical and instrumentation equipment are not included.

5.9.1  Water Quality Monitoring and Control

       The ability of a PWS to monitor water quality parameters, particularly disinfectant
residuals, in the distribution system can allow the PWS to determine if there is an area of
possible contamination or an  area that requires additional treatment. Low levels of disinfectant
residuals in a system can be caused by an increase of organics in a system, which consume
disinfectant residuals, or insufficient disinfectant dosages at the treatment facility.  Maintenance
of sufficient disinfectant residual levels in a distribution  system is important in maintaining
minimal levels  of TC in the system.

5.9.1.1 Chlorinated Systems

      Most systems currently utilize chlorine as the main disinfectant.  There are a number of
chlorine-based treatment technologies available: chlorine gas, hypochlorite, chlorine dioxide, and
anodic oxidation.

      Exhibit 5-35 presents the costs associated with incorporating a chlorine residual analyzer
in the distribution system. The costs below include a chlorine residual analyzer, installation of
the analyzer based on system size, required piping and appurtenances, and programming costs.
March 2009 Revised Total Coliform Rule              5-41      Draft - Please do not cite, quote, or distribute
Technology and Cost Document

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  Exhibit 5-35: Estimated Costs for Online Chlorine Monitoring and Programming
System Size
A
<500
501 -1,000
1,001 -4,100
4,101 -33,000
33,001 -96,000
96,001 -500,000
500,001 -1,000,000
> 1,000,001
Labor
Rate1
B
$25.75
$28.96
$29.73
$36.00
$36.39
$41.01
$41.01
$41.01
Labor
Time
(hours)2
C
24
24
24
24
24
24
24
24
Programmer
Rate3
D
$120
$120
$120
$120
$120
$120
$120
$120
Program.
Time
(hours)4
E
8
8
8
8
8
8
8
8
Total Labor
& Program.
Cost2
F=B*C*2+D*E
$2,200
$2,360
$2,390
$2,690
$2,710
$2,930
$2,930
$2,930
Chlorine
Analyzer
Cost5
G
$2,770
$2,770
$2,770
$2,770
$2,770
$2,770
$2,770
$2,770
Piping
and
related6
H
$460
$460
$460
$460
$460
$460
$460
$460
Total
Cost7'8
(2007$)
I=F+G+H
$5,430
$5,590
$5,620
$5,920
$5,940
$6,160
$6,160
$6,160
1 See Exhibit 2-6 in Chapter 2. Estimated Unit Costs of Labor.
2 Assumes a two-person crew required over a three-day period to install chlorine monitoring device and associated equipment
(electrical wiring, installing a sample drain, etc.).
3 Assumes average programmer rate of $120 per hour (in 2007 dollars), which is independent of system size.
4 Programming time includes integration of analyzer signals into a SCADA system.
5 Chlorine analyzer cost per vendor research
6 Assume an additional $460 for sample lines.
7 Estimates rounded up to the nearest $10.
8 Costs assume that analyzer will be installed at an existing facility.
5.9.1.2 Chloraminated Systems

       Exhibit 5-36 presents the costs associated with incorporating an ammonia and
monochloramine analyzers in the distribution system.  The costs below include an ammonia and
monochloramine residual  analyzer, installation of the analyzer based on system size, required
piping and appurtenances, and programming costs.
March 2009 Revised Total Coliform Rule
Technology and Cost Document
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         Exhibit 5-36: Estimated Costs for Online Chloramine Monitoring and
                                         Programming
System Size
A
<500
501 -1,000
1,001 -4,100
4,101 -33,000
33,001 -96,000
96,001 -500,000
500,001 -1,000,000
> 1,000,001
Labor
Rate1
B
$25.75
$28.96
$29.73
$36.00
$36.39
$41.01
$41.01
$41.01
Labor
Time
(hours)2
C
24
24
24
24
24
24
24
24
Programmer
Rate3
D
$120
$120
$120
$120
$120
$120
$120
$120
Program.
Time
(hours)4
E
8
8
8
8
8
8
8
8
Total Labor
& Program.
Cost2
F=B*C*2+D*
E
$2,200
$2,360
$2,390
$2,690
$2,710
$2,930
$2,930
$2,930
Chloramines
Analyzer
Cost5
G
$11,230
$11,230
$11,230
$11,230
$11,230
$11,230
$11,230
$11,230
Piping
and
related6
H
$460
$460
$460
$460
$460
$460
$460
$460
Total Cost
(2007$)7'8
I=F+G+H
$13,890
$14,050
$14,080
$14,380
$14,400
$14,620
$14,620
$14,620
1 See Exhibit 2-6 in Chapter 2. Estimated Unit Costs of Labor.
2 Assumes a two-person crew required over a three-day period to install chloramine monitoring device and associated equipment
(electrical wiring, installing a sample drain, etc.).
3 Assumes average programmer rate of $120 per hour (in 2007 dollars), which is independent of system size.
4 Programming time includes integration of analyzer signals into a SCADA system.
5 Chloramine analyzer cost per vendor.
6 Assume an additional $460 for sample lines.
7 Estimates rounded up to the nearest $10.
8 Costs assume that analyzer will be installed at an existing facility.
5.9.2   Pressure Monitoring and Control

        The ability of a PWS to monitor pressure throughout its distribution system can provide
useful information for responding to water quality events and ensuring that pressure maintenance
is adequate.  Pressure readings can also be used to help locate areas of deficiency in a
distribution system.
        Exhibit 5-37 presents the costs associated with incorporating pressure monitoring
equipment in the distribution system. The costs below include pressure monitoring equipment,
installation of a pressure transmitter based on system size, and programming costs.
March 2009 Revised Total Coliform Rule
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  Exhibit 5-37: Estimated Costs for Online Pressure Monitoring and Programming
System Size
A
<500
501 -1,000
1,001 -4,100
4,101 -33,000
33,001 -96,000
96,001 -500,000
500,001 -1,000,000
> 1,000, 001
Labor
Rate1
B
$25.75
$28.96
$29.73
$36.00
$36.39
$41.01
$41.01
$41.01
Labor
Time
(hours)2
C
16
16
16
16
16
16
16
16
Programmer
Rate3
D
$120
$120
$120
$120
$120
$120
$120
$120
Program.
Time
(hours)4
E
8
8
8
8
8
8
8
8
Total Labor &
Programming
Cost2
F=B*C*2+D*E
$1,790
$1,890
$1,920
$2,120
$2,130
$2,280
$2,280
$2,280
Pressure
Transmitter
Cost5
G
$2,740
$2,740
$2,740
$2,740
$2,740
$2,740
$2,740
$2,740
Total
Cost6'7
(2007$)
H=F+G
$4,530
$4,630
$4,660
$4,860
$4,870
$5,020
$5,020
$5,020
1 See Exhibit 2-6 in Chapter 2. Estimated Unit Costs of Labor
2 Assumes a two-person crew working for a total of two days to install analyzer.
3 Assumes average programmer rate of $120 per hour (in 2007 dollars), which is independent of system size.
4 Programming time includes integration of transmitter signals into a SCADA system.
5 Pressure transmitter cost per vendor.
6 Estimates rounded up to the nearest $10.
7 Costs assumes that pressure transmitter will be installed at an existing facility.

5.10   Addition of Security Measures

       Systems may need to install security measures in circumstances where the sanitary survey
or onsite inspection reveals vandalism or security breaches that could lead to water
contamination. Measures that a water system may take to correct security breaches include
installing a fence or locking buildings to restrict access to the system. In addition, alarms and
cameras may be used to detect security breaches.

       Water systems should prioritize their security measures and concentrate on the most
vulnerable parts of the system, such as unstaffed facilities (e.g., finished water storage tanks).
An important implementation issue is determining the extent to which the water system needs to
be secured.  This would depend on how widely  spread the system/facility is, the number and
complexity of the treatment trains,  the extent of the watershed, the distance of the treatment  plant
from the influent wells, accessibility  of the distribution system, etc. Possible security measures
include locked fence enclosures and employing a full time, on-site security staff.

       Installing security measures can increase the public's confidence in the protection of their
drinking water and indeed can provide substantial protection against vandalism that might result
in contamination of the water. However, security measures are not always foolproof or absolute
in combating vandalism or security breaches.

       Exhibit 5-38 presents the cost components for installing fencing, gates, and security
lighting for 0.5 and 1-acre lots. A site size of 0.5-acres was assumed for systems serving
populations of 10,000 or fewer,  and a 1-acre site size was assumed for systems serving
populations greater than 10,000.  Costs include  materials, installation and overhead and profit.
March 2009 Revised Total Coliform Rule
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         Exhibit 5-38: Estimated Costs for Installation of Security Measures
System Size
A
<500
501 -1,000
1,001 -4,100
4,101 -33,000
33,001 -96,000
96,001 -500,000
500,001-1,000,000
> 1,000,001
Fence
Cost1'2'5
B
$8,400
$8,400
$8,400
$11,900
$11,900
$11,900
$11,900
$11,900
Gate
Cost3'5
C
$795
$795
$795
$795
$795
$795
$795
$795
Lighting
Cost4'5^
D
$880
$880
$880
$880
$880
$880
$880
$880
Security
Capital Cost
E=B+C+D
$10,075
$10,075
$10,075
$13,575
$13,575
$13,575
$13,575
$13,575
Installation
Cost6
F=0.3*E
$3,023
$3,023
$3,023
$4,073
$4,073
$4,073
$4,073
$4,073
Total Cost
(2007$)7'8
G=(E+F)*1.225
$13,100
$13,100
$13,100
$17,650
$17,650
$17,650
$17,650
$17,650
1 Fence cost assumed a 0.5 acre site (600 linear feet) for systems less than 10,000 and a 1.0 acre site (850 linear feet) for systems
greater than 10,000.
2 Fence cost assumed to be industrial chain link, three strands barbed wire, 2 inch posts, set in concrete, 6 feet high, with 9 ga. wire,
galvanized steel.
3 Gate cost  assumed double swing gates, including posts and hardware, 6 feet high, 12 feet opening.
4 Lighting cost assumed four wall-mounted, 35 watt, low pressure sodium fixtures per site.
5 Cost obtained from R.S. Means, 2007.
6 Installation costs assumed to be 30% of security capital cost based on project experience and assuming installation includes
electrical work.
7 Cost rounded up to the nearest $10
8Assumes and includes a 22.5% Overhead and Profit cost, from R.S. Means 2009.

5.11   Development and Implementation of an Operations Plan

       A water system should develop a  distribution system operations plan to integrate all
operations and maintenance functions to meet the goals of flow, pressure and water quality.
AWWA G200-04 standard describes the  critical requirements for the effective operation and
management of drinking water distribution systems.  According to this standard, a water system
should develop standard operating procedures (SOPs), comprehensive monitoring plans, routine
inspections, and emergency response plans.

       SOPs should be developed for each operation and  maintenance function that affects
system water quality (e.g. flushing programs, storage facility inspections). The water quality
goals for both the distribution system and the particular function should be specified in the SOP.
SOPs should be developed from information gathered from the various departments and crews
involved in  a given function.  The SOPs should be written in terms that everybody will
understand and they should include all activities needed to conduct the procedures, and describe
the labor, equipment and materials needed to complete the activity.

       The  water system should establish a routine distribution system sampling plan that is
representative of the entire distribution system. The  sample sites shall include, at a minimum,
sites required for regulatory compliance monitoring.  Additional sites shall be sampled as
necessary to provide a complete picture of the water  quality in the system. All samples should
be collected in accordance with latest edition of Standard Methods for the Examination of Water
and Wastewater.
       Routine inspections of various distribution system components such as finished water
storage facilities, water mains, pump stations, chemical storage facilities, valves, and fire
                                               5-45      Draft - Please do not cite, quote, or distribute
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hydrants are necessary to ensure high-quality water. The water systems should implement
inspection and maintenance programs of these components.

       A written emergency response plan for the distribution system allows operating personnel
to respond efficiently, effectively and rapidly to an emergency situation.  Water quality system
safety and reliability are improved if a water system has an emergency response plan. Exhibit 5-
39 presents the estimated cost of developing and implementing an operations and maintenance
plan.  The estimated cost assumes that both technical and managerial staff will be involved in
this task.

   Exhibit 5-39: Estimated  Costs to  Develop and Implement an Operations Plan
System Size
A
<500
501 -1,000
1,001 -4,100
4,101 -33,000
33,001 -96,000
96,001 -500,000
500,001-1,000,000
> 1,000,001
Labor Rate1
B
$25.75
$28.96
$29.73
$36.00
$36.39
$41.01
$41.01
$41.01
Time (hours)2
C
96
144
192
384
384
1152
1152
1152
Total Cost (2007$)3
D=B*C
$2,480
$4,170
$5,710
$13,820
$13,970
$47,240
$47,240
$47,240
1 See Exhibit 2-6 in Chapter 2. Estimated Unit Costs of Labor
2 Time includes hours for both operator and managerial staff.
3 Cost rounded up to the nearest $10.

5.11.1 Operation and Maintenance Standard Operating Procedure (SOP) Training

       EPA established an operator certification program with minimum professional standards
for the operation and maintenance of water systems. The EPA program issued guidelines that
specify standards for certification and recertification of operators.  States implement the
minimum standards of the certification program guidelines. While the specific requirements
vary from state to state, the goal of the program is to ensure that skilled professionals are
overseeing the treatment and distribution of safe drinking water and compliance with the Safe
Drinking Water Act.

       Implementation of an operator certification and training program provides guidelines for
the standards operators must uphold to operate and maintain a treatment facility or system.  This
is one component necessary for the protection of public health and the maintenance of a safe and
reliable PWS. Training sessions for operators reinforce proper operation and maintenance of
these facilities and systems. In addition, these  sessions can help to educate PWS staff on
emerging treatment technologies, regulatory requirements, and other advances in the drinking
water industry.

       The costs for operator training or certification include travel costs, training/certification
fees, and the operator labor costs associated with the time spent at the training or certification
session.  Increased operator knowledge could potentially decrease the possibility of
contamination within the distribution system. Exhibit 5-40 summarizes the cost for operator
training and certification.
March 2009 Revised Total Coliform Rule
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          Exhibit 5-40: Estimated Costs for Operator Training/Certification
System Size
A
<500
501 -1,000
1,001 -4,100
4,101 -33,000
33,001 -96,000
96,001 -500,000
500,001 -1,000,000
> 1,000,001
Labor
Rate1
B
$25.75
$28.96
$29.73
$36.00
$36.39
$41.01
$41.01
$41.01
Course
Time
(hours)2
C
8
8
8
8
8
8
8
8
Total Labor
Cost
D=B*C
$210
$240
$240
$290
$300
$330
$330
$330
Travel3
E
$31
$31
$31
$31
$31
$31
$31
$31
Training/
Certification
Fees4
F
$125
$125
$125
$125
$125
$125
$125
$125
Total Cost
(2007$)5
G=D+E+F
$370
$400
$400
$450
$460
$490
$490
$490
1 See Exhibit 2-6 in Chapter 2. Estimated Unit Costs of Labor.
2 Assumes an eight hour training/certification course
3 Assumes 60 miles of round-trip driving distance at $0.52/mi.
4 Assumes a $125 training/certification fee for members according to the National Rural Water Association.
5 Estimates rounded up to the nearest $10.

5.11.2  Operation and Maintenance Plan Revision

        The operations and maintenance programs described earlier in this section should be
reviewed periodically and modified based on input from all affected groups so they remain
accurate, beneficial, and easy to follow. AWWA Standard G200-04 outlines that the modified
documents should be approved for adequacy prior to issue and the current revision status of
documents should be identified.  Following the approval of the modified documents a copy of
the updated documents should be made available  at the points of use.

        Exhibit 5-41 presents the yearly estimated cost of maintaining an operations and
maintenance plan.  The estimated cost assumes that both technical and managerial staff will be
involved in this task.
March 2009 Revised Total Coliform Rule
Technology and Cost Document
5-47
Draft - Please do not cite, quote, or distribute

-------
             Exhibit 5-41: Estimated Costs to Maintain an Operations Plan
System Size
A
<500
501 -1,000
1,001 -4,100
4,101 -33,000
33,001 -96,000
96,001 -500,000
500,001-1,000,000
> 1,000,001
Labor Rate1
B
$25.75
$28.96
$29.73
$36.00
$36.39
$41.01
$41.01
$41.01
Time (hours)2
C
14
29
29
48
48
48
96
96
Total Cost (2007$)3
E=B*C
$370
$830
$860
$1,730
$1,750
$1,970
$3,940
$3,940
1 See Exhibit 2-6 in Chapter 2. Estimated Unit Costs of Labor
2 Assumes both technical and managerial time3 Cost rounded up to the nearest $10
3 Estimates rounded up to the nearest $10.
March 2009 Revised Total Coliform Rule
Technology and Cost Document
5-48
Draft - Please do not cite, quote, or distribute

-------
                                      References
       The references included in this section contain additional information for readers who
wish to pursue in greater detail, the specific topics discussed in this document. Many of these
references (especially the EPA references) are freely available on the internet. The references
are listed alphabetically, based on the last name of the first author(s). In cases where there are
two or more works by the same author (e.g. AWWA, AwwaRF, and EPA), the entries are listed
by the year, with the most recent document listed first. The reverse chronological order makes it
easy for the reader to look up the  most recent publication first.
American Water Works Association (AWWA). 2001 Utility Compensation Survey.  AWWA.
       October 2001.

American Water Works Association, 2004. AWWA G200 - AWWA Standard for Distributions
       Systems Operation and Management. Denver, CO: AWWA

Association of State Drinking Water Administrators (ASDWA). 2001. Drinking water program
       resource needs assessment. Version 9. November 27, 2001.

Brandt, M. 1, Clement, 1, Powell, I, Casey, R., Holt, D., Harris, N., and Ta, C.T. 2004.
       Managing Distribution System Retention Time to Improve Water Quality Denver, CO:
       AWWARF

Bureau  of  Labor   Statistics,   U.S.  Department   of  Labor,  Employment   Cost  Index,
       [www.bls.gov/news.release/eci.toc.htm].

Bureau of  Labor Statistics, U.S.  Department of  Labor,  National  Compensation  Survey,
       [www.bls.gov/ncs/].

Bureau of Labor Statistics,  U.S. Department of Labor,  Occupational Employment Statistics,
       [www.bls.gov/oes/].

Clesceri, Lenore & Greenberg, Arnold & Eaton, Andrew. Standard Methods for the Examination
       of Water and Wastewater, 20th Edition. Washington, DC: American Public Health
       Association, American Waterworks Association, Water Environment Federation; 1998:
       Pages 9-47 - 9-78.

Davis, G., Moraca, T.  and O'Connell, S, 2008. Get a Grip on Fluctuating Pressures and Flows.
       Opflow Magazine. Denver, CO:AWWA

Hasit, YJ. 2004. Cost and Benefit Analysis on Flushing. Denver, Co: AWWARF
March 2009 Revised Total Coliform Rule             R-l      Draft - Please do not cite, quote, or distribute
Technology and Cost Document

-------
Kirmeyer, GJ and Friedman M. 2000. Guidance Manual for Maintaining Distribution System
       Water Quality. Denver, CO: AWWARF and AWWA

Means, R.S. 2009 Building Construction Cost Data. 62nd Annual Edition. Kingston, MA
       Construction Publishers and Consultants

R.S. Means. 1998 Mechanical Cost Data. R.S. Means Company, Inc. Kingston, MA.

U.S. Bureau of the Census, Economic Census. Census Bureau. 1997. Available:
       http://www.census.gov/epcd/www/econ97.html [3 Mar 2006].

U.S. Environmental Protection Agency. 2007. Total Coliform Rule Issue Paper: Distribution
       System Inventory, Integrity, and Water Quality.

U.S. Environmental Protection Agency. 2006 Technology and Cost Document for the Final
       Ground Water Rule. EPA 815-R-06-014

U.S. Environmental Protection Agency. 2007. Simultaneous Compliance Guidance Manual for
       the Long Term 2 and Stage 2 DBF Rules EPA 815-R-07-017

USEPA, Safe Drinking Water Act (SOWA). USEPA. Available:
       http://www.epa.gov/safewater/sdwa/ [17 Mar 2009].

USEPA, Safe Drinking Water Information System (SDWIS). USEPA. Available:
       http://www.epa.gov/enviro/html/sdwis/ [1 Feb 2008].

USEPA. 2009. Total Coliform Rule / Distribution Systems Advisory Committee Agreement in
       Principle. 74 FR 1683. January 13, 2009.

USEPA. 2007. Meeting of the Total Coliform Rule Distribution System Advisory Committee--
       Notice of Public Meeting. 72 FR 35870, June 29, 2007.

USEPA. 2006. National Primary Drinking Water Regulations:  Stage 2 Disinfectants and
       Disinfection Byproducts Rule. 71  FR 388. January 4, 2006.

USEPA. 2006. Economic Analysis for the Final Ground Water Rule.  October, 2006. EPA-815-
       R-06-014.

USEPA.  2006.  National Primary Drinking Water Regulations:  Ground Water  Rule. 71  FR
       65574. November 8, 2006.

USEPA. 2003. National Primary Drinking Water Regulations: Long Term 2 Enhanced Surface
       Water Treatment Rule. 68 FR 47739. August 11, 2003.

USEPA. 2003. National Primary Drinking Water Regulations; Announcement of Completion of
       EPAs Review of Existing Drinking Water Standards. 68 FR 42907, July  18, 2003.

March 2009 Revised Total Coliform Rule             R-2      Draft - Please do not cite,  quote, or distribute
Technology and Cost Document

-------
USEPA. 2003. Consideration of Other Regulatory Revisions for Chemical Contaminants in
       Support of the Six-Year Review of National Primary Drinking Water Regulations. June,
       2003. EPA 815-R-03-005.

USEPA. 2003. The Safe Drinking Water Information System - Federal Version (SDWIS/FED)
       data (4th quarter freeze year 2003 data).

USEPA. 2003. Labor Costs for National Drinking Water Rules.

USEPA. 2002. 2000 Community Water System (CWS) Survey. December, 2002. EPA 815-R-
       02-005A.

USEPA. 1989. National Primary Drinking Water Regulations; Total Coliforms (Including Fecal
       Coliforms and E. Coli); Final Rule. 54 FR 27544. June, 29,  1989.

U.S. General Services Administration (GSA). GSA. Available:
       http://www.gsa.gov/Portal/gsa/ep/content View.do?programld=l 5580&channelld=-
       2465l&ooid=10359&contentId=9646&pageTvpeId=17113&contentType=GSA BASIC
       &programPage=%2Fep%2Fprogram%2FgsaBasic.isp&P=MTT [10Feb2009].
March 2009 Revised Total Coliform Rule            R-3      Draft - Please do not cite, quote, or distribute
Technology and Cost Document

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                                  Appendix A
     Exhibit A-1.1: Current TCR (as implemented) Labor Burden Estimate for
                 Assessments done by NCWSs serving <= 1,000


Notification
Element
System
Specific
Element
Sample
Analytical
Element
Sample
Methodology
Element
Event
Situational
Element
Operational
Data Element
Historical
Trend
Element
Sample Tap
Element
Sample Site
Element
Sample Area
Element
Third Party
Consulting
Element
Report
Element
Total
Nonacute MCL Violation
Percentage
of Systems
doing
Element
A
1 00%
1 00%
0%
0%
0%
0%
0%
0%
0%
0%
0%
100%

Estimated
Hours
Associated
with
Element
B
1
1
0
0
0
0
0
0
0
0
0
2

Average
Burden
Associated
with
Element
C = A*B
1
1
0
0
0
0
0
0
0
0
0
2
4
Acute MCL Violation
Percentage
of Systems
doing
Element
D
100%
100%
0%
0%
0%
0%
0%
0%
0%
0%
0%
100%

Estimated
Hours
Associated
with
Element
E
1.75
0.5
0
0
0
0
0
0
0
0
0
4

Average
Burden
Associated
with
Element
F = D*E
1.75
0.5
0
0
0
0
0
0
0
0
0
4
6.25
A.  March 2009 Revised Total Coliform Rule
Technology and Cost Document
A-l
Draft - Please do not cite, quote, or distribute

-------
          Exhibit A-1.2: RTCR Labor Burden Estimate for Assessments done by NCWSs serving <= 1,000


Notification
Element
System
Specific
Element
Sample
Analytical
Element
Sample
Methodology
Element
Event
Situational
Element
Operational
Data Element
Historical
Trend Element
Sample Tap
Element
Sample Site
Element
Sample Area
Element
Third Party
Element
Report
Element
Total
Level 1 Assessment
Percentage of
Systems doing
Element
G
100%
0%
0%
50%
100%
60%
100%
100%
100%
100%
0%
100%

Estimated
Hours
Associated
with Element
H
0
0
0
1
1
0.3
0.5
1
1
1
0
2

Average
Burden
Associated with
Element
I = G* H
0
0
0
0.5
1
0.18
0.5
1
1
1
0
2
7.18
Level 2 Assessment (nonacutej
Percentage of
Systems doing
Element
J
100%
100%
100%
100%
100%
40%
100%
100%
100%
100%
0%
100%

Estimated
Hours
Associated with
Element
K
0.5
0.3
0
0.5
2
0.5
0.5
1
1
1
0
2

Average
Burden
Associated with
Element
L = J* K
0.5
0.3
0
0.5
2
0.2
0.5
1
1
1
0
2
9
Level 2 Assessment (acute)
Percentage of
Systems doing
Element
M
100%
100%
100%
100%
100%
40%
5%
100%
100%
20%
50%
100%

Estimated
Hours
Associated with
Element
N
2
1
1
1
2
1
4
1
1
7
16
2

Average
Burden
Associated with
Element
O = M* N
2
1
1
1
2
0.4
0.2
1
1
1.4
8
2
21
March 2009 Revised Total Coliform Rule
Technology and Cost Document
A-2
Draft - Please do not cite, quote, or distribute

-------
     Exhibit A-2.1: Current TCR (as implemented) Labor Burden Estimate for
               Assessments done by NCWSs serving 1,001 - 4,100


Notification
Element
System
Specific
Element
Sample
Analytical
Element
Sample
Methodology
Element
Event
Situational
Element
Operational
Data Element
Historical
Trend
Element
Sample Tap
Element
Sample Site
Element
Sample Area
Element
Third Party
Consulting
Element
Report
Element
Total
Nonacute MCL Violation
Percentage
of Systems
doing
Element
A
1 00%
1 00%
50%
80%
100%
100%
100%
0%
0%
0%
0%
100%

Estimated
Hours
Associated
with
Element
B
1
1
0
0
0
0
0
0
0
0
0
2

Average
Burden
Associated
with
Element
C = A*B
1
1
0
0
0
0
0
0
0
0
0
2
4
Acute MCL Violation
Percentage
of Systems
doing
Element
D
100%
100%
0%
0%
0%
0%
0%
0%
0%
0%
0%
100%

Estimated
Hours
Associated
with
Element
E
1.8
0.5
0
0
0
0
0
0
0
0
0
3.5

Average
Burden
Associated
with
Element
F = D*E
1.8
0.5
0
0
0
0
0
0
0
0
0
3.5
5.8
March 2009 Revised Total Coliform Rule
Technology and Cost Document
A-3
Draft - Please do not cite, quote, or distribute

-------
        Exhibit A-2.2: RTCR Labor Burden Estimate for Assessments done by NCWSs serving 1,001 - 4,100


Notification
Element
System
Specific
Element
Sample
Analytical
Element
Sample
Methodology
Element
Event
Situational
Element
Operational
Data Element
Historical
Trend Element
Sample Tap
Element
Sample Site
Element
Sample Area
Element
Third Party
Element
Report
Element
Total
Level 1 Assessment
Percentage of
Systems doing
Element
G
100%
0%
0%
50%
100%
60%
100%
100%
100%
100%
0%
100%

Estimated
Hours
Associated
with Element
H
0
0
0
1
1
0.3
0.5
1
1
2
0
2

Average
Burden
Associated with
Element
I = G* H
0
0
0
0.5
1
0.18
0.5
1
1
2
0
2
8.18
Level 2 Assessment (nonacutej
Percentage of
Systems doing
Element
J
100%
100%
100%
100%
100%
40%
100%
100%
100%
100%
0%
100%

Estimated
Hours
Associated with
Element
K
0.5
0.3
0
0.5
2
0.5
0.5
1
1
2
0
2

Average
Burden
Associated with
Element
L = J* K
0.5
0.3
0
0.5
2
0.2
0.5
1
1
2
0
2
10
Level 2 Assessment (acute)
Percentage of
Systems doing
Element
M
100%
100%
100%
100%
100%
40%
5%
100%
100%
20%
50%
100%

Estimated
Hours
Associated with
Element
N
2
1
1
1
2
1
4
1
1
7
16
2

Average
Burden
Associated with
Element
O = M* N
2
1
1
1
2
0.4
0.2
1
1
1.4
8
2
21
March 2009 Revised Total Coliform Rule
Technology and Cost Document
A-4
Draft - Please do not cite, quote, or distribute

-------
     Exhibit A-3.1: Current TCR (as implemented) Labor Burden Estimate for
                   Assessments done by CWSs serving <= 100


Notification
Element
System
Specific
Element
Sample
Analytical
Element
Sample
Methodology
Element
Event
Situational
Element
Operational
Data Element
Historical
Trend
Element
Sample Tap
Element
Sample Site
Element
Sample Area
Element
Third Party
Consulting
Element
Report
Element
Total
Nonacute MCL Violation
Percentage
of Systems
doing
Element
A
1 00%
1 00%
0%
80%
10%
60%
0%
80%
5%
0%

1 00%

Estimated
Hours
Associated
with
Element
B
1
1
0
2
2
2
0
1
2
0

5.5

Average
Burden
Associated
with
Element
C = A*B
1
1
0
1.6
0.2
1.2
0
0.8
0.1
0
0
5.5
11.4
Acute MCL Violation
Percentage
of Systems
doing
Element
D
100%
100%
0%
80%
100%
60%
10%
100%
5%
0%
0%
100%

Estimated
Hours
Associated
with
Element
E
1.5
1
0
2
2
2
1
1
2
0
0
5.5

Average
Burden
Associated
with
Element
F = D*E
1.5
1
0
1.6
2
1.2
0.1
1
0.1
0
0
5.5
14
March 2009 Revised Total Coliform Rule
Technology and Cost Document
A-5
Draft - Please do not cite, quote, or distribute

-------
           Exhibit A-3.2: RTCR Labor Burden Estimate for Assessments done by CWSs serving <= 100


Notification
Element
System
Specific
Element
Sample
Analytical
Element
Sample
Methodology
Element
Event
Situational
Element
Operational
Data Element
Historical
Trend Element
Sample Tap
Element
Sample Site
Element
Sample Area
Element
Third Party
Element
Report
Element
Total
Level 1 Assessment
Percentage of
Systems doing
Element
G
100%
100%
0%
100%
100%
60%0
100%
100%
5%
100%

100%

Estimated
Hours
Associated
with Element
H
2
1
0
2
2
2
2
1
2
2.5

5.5

Average
Burden
Associated with
Element
I = G* H
2
1
0
2
2
1.2
2
1
0.1
2.5

5.5
19.3
Level 2 Assessment (nonacutej
Percentage of
Systems doing
Element
J
100%
100%
0%
100%
100%
60%
100%
100%
5%
100%

100%

Estimated
Hours
Associated with
Element
K
2
1
0
2
2
2
2
1
2
2.5

8.5

Average
Burden
Associated with
Element
L = J* K
2
1
0
2
2
1.2
2
1
0.1
2.5
0
8.5
22.3
Level 2 Assessment (acute)
Percentage of
Systems doing
Element
M
100%
100%
0%
100%
100%
60%
100%
100%
100%
100%

100%

Estimated
Hours
Associated with
Element
N
2
1
0
2
2
2
2
1
1
2.5

8.5

Average
Burden
Associated with
Element
O = M* N
2
1
0
2
2
1.2
2
1
1
2.5
0
8.5
23.2
March 2009 Revised Total Coliform Rule
Technology and Cost Document
A-6
Draft - Please do not cite, quote, or distribute

-------
     Exhibit A-4.1: Current TCR (as implemented) Labor Burden Estimate for
                  Assessments done by CWSs serving 101 -500


Notification
Element
System
Specific
Element
Sample
Analytical
Element
Sample
Methodology
Element
Event
Situational
Element
Operational
Data Element
Historical
Trend
Element
Sample Tap
Element
Sample Site
Element
Sample Area
Element
Third Party
Consulting
Element
Report
Element
Total
Nonacute MCL Violation
Percentage
of Systems
doing
Element
A
1 00%
1 00%
0%
80%
10%
60%
0%
80%
5%
0%

1 00%

Estimated
Hours
Associated
with
Element
B
1
1
0
2
2
2
0
1
2
0

5.5

Average
Burden
Associated
with
Element
C = A*B
1
1
0
1.6
0.2
1.2
0
0.8
0.1
0
0
5.5
11.4
Acute MCL Violation
Percentage
of Systems
doing
Element
D
100%
100%
0%
80%
100%
60%
10%
100%
5%
5%
0%
100%

Estimated
Hours
Associated
with
Element
E
1.5
1
0
2
2
2
1
1
2
2
0
5.5

Average
Burden
Associated
with
Element
F = D*E
1.5
1
0
1.6
2
1.2
0.1
1
0.1
0.1
0
5.5
14.1
March 2009 Revised Total Coliform Rule
Technology and Cost Document
A-7
Draft - Please do not cite, quote, or distribute

-------
          Exhibit A-4.2: RTCR Labor Burden Estimate for Assessments done by CWSs serving 101 - 500


Notification
Element
System
Specific
Element
Sample
Analytical
Element
Sample
Methodology
Element
Event
Situational
Element
Operational
Data Element
Historical
Trend Element
Sample Tap
Element
Sample Site
Element
Sample Area
Element
Third Party
Element
Report
Element
Total
Level 1 Assessment
Percentage of
Systems doing
Element
G
100%
100%
0%
100%
100%
60%0
100%
100%
5%
100%

100%

Estimated
Hours
Associated
with Element
H
2
1
0
2
2
2
2
1
2
2.5

5.5

Average
Burden
Associated with
Element
I = G* H
2
1
0
2
2
1.2
2
1
0.1
2.5

5.5
19.3
Level 2 Assessment (nonacutej
Percentage of
Systems doing
Element
J
100%
100%
0%
100%
100%
60%
100%
100%
5%
100%

100%

Estimated
Hours
Associated with
Element
K
2
1
0
2
2
2
2
1
2
2.5

8.5

Average
Burden
Associated with
Element
L = J* K
2
1
0
2
2
1.2
2
1
0.1
2.5
0
8.5
22.3
Level 2 Assessment (acute)
Percentage of
Systems doing
Element
M
100%
100%
0%
100%
100%
60%
100%
100%
100%
100%

100%

Estimated
Hours
Associated with
Element
N
2
1
0
2
2
2
2
1
1
2.5

8.5

Average
Burden
Associated with
Element
O = M* N
2
1
0
2
2
1.2
2
1
1
2.5
0
8.5
23.2
March 2009 Revised Total Coliform Rule
Technology and Cost Document
A-8
Draft - Please do not cite, quote, or distribute

-------
     Exhibit A-5.1: Current TCR (as implemented) Labor Burden Estimate for
                 Assessments done by CWSs serving 501 -1,000


Notification
Element
System
Specific
Element
Sample
Analytical
Element
Sample
Methodology
Element
Event
Situational
Element
Operational
Data Element
Historical
Trend
Element
Sample Tap
Element
Sample Site
Element
Sample Area
Element
Third Party
Consulting
Element
Report
Element
Total
Nonacute MCL Violation
Percentage
of Systems
doing
Element
A
1 00%
1 00%
0%
80%
10%
60%
0%
80%
5%
0%

1 00%

Estimated
Hours
Associated
with
Element
B
2.5
1
0
2
2
2
0
1
2
0

5.5

Average
Burden
Associated
with
Element
C = A*B
2.5
1
0
1.6
0.2
1.2
0
0.8
0.1
0
0
5.5
12.9
Acute MCL Violation
Percentage
of Systems
doing
Element
D
100%
100%
0%
80%
100%
60%
10%
100%
5%
5%
0%
100%

Estimated
Hours
Associated
with
Element
E
2.5
1
0
2
2
2
1
1
1
2
0
5.5

Average
Burden
Associated
with
Element
F = D*E
2.5
1
0
1.6
2
1.2
0.1
1
0.05
0.1
0
5.5
15.05
March 2009 Revised Total Coliform Rule
Technology and Cost Document
A-9
Draft - Please do not cite, quote, or distribute

-------
         Exhibit A-5.2: RTCR Labor Burden Estimate for Assessments done by CWSs serving 501 -1,000


Notification
Element
System
Specific
Element
Sample
Analytical
Element
Sample
Methodology
Element
Event
Situational
Element
Operational
Data Element
Historical
Trend Element
Sample Tap
Element
Sample Site
Element
Sample Area
Element
Third Party
Element
Report
Element
Total
Level 1 Assessment
Percentage of
Systems doing
Element
G
100%
100%
0%
100%
100%
60%0
100%
100%
5%
100%

100%

Estimated
Hours
Associated
with Element
H
2.5
1
0
2
2
2
2
1
2
2.5

5.5

Average
Burden
Associated with
Element
I = G* H
2.5
1
0
2
2
1.2
2
1
0.1
2.5

5.5
19.8
Level 2 Assessment (nonacutej
Percentage of
Systems doing
Element
J
100%
100%
0%
100%
100%
60%
100%
100%
5%
100%

100%

Estimated
Hours
Associated with
Element
K
2.5
1
0
2
2.5
2
2
1
2
2.5

8.5

Average
Burden
Associated with
Element
L = J* K
2.5
1
0
2
2.5
1.2
2
1
0.1
2.5
0
8.5
23.3
Level 2 Assessment (acute)
Percentage of
Systems doing
Element
M
100%
100%
0%
100%
100%
60%
100%
100%
100%
100%

100%

Estimated
Hours
Associated with
Element
N
2.5
1
0
2
2
2
2
1
1
2.5

8.5

Average
Burden
Associated with
Element
O = M* N
2.5
1
0
2
2
1.2
2
1
1
2.5
0
8.5
23.7
March 2009 Revised Total Coliform Rule
Technology and Cost Document
A-10
Draft - Please do not cite, quote, or distribute

-------
     Exhibit A-6.1: Current TCR (as implemented) Labor Burden Estimate for
                Assessments done by CWSs serving 1,001 - 4,100


Notification
Element
System
Specific
Element
Sample
Analytical
Element
Sample
Methodology
Element
Event
Situational
Element
Operational
Data Element
Historical
Trend
Element
Sample Tap
Element
Sample Site
Element
Sample Area
Element
Third Party
Consulting
Element
Report
Element
Total
Nonacute MCL Violation
Percentage
of Systems
doing
Element
A
1 00%
1 00%
0%
80%
10%
60%
1 00%
80%
5%
30%

1 00%

Estimated
Hours
Associated
with
Element
B
3
1
0
3
5.5
4
3
1.5
2
4

7.5

Average
Burden
Associated
with
Element
C = A*B
3
1
0
2.4
0.55
2.4
3
1.2
0.1
1.2
0
7.5
22.35
Acute MCL Violation
Percentage
of Systems
doing
Element
D
100%
100%
0%
80%
100%
60%
100%
100%
100%
5%
0%
100%

Estimated
Hours
Associated
with
Element
E
3
1
0
3
5.5
4
3
2
2
3
0
7.5

Average
Burden
Associated
with
Element
F = D*E
3
1
0
2.4
5.5
2.4
3
2
2
0.15
0
7.5
28.95
March 2009 Revised Total Coliform Rule
Technology and Cost Document
A-ll
Draft - Please do not cite, quote, or distribute

-------
        Exhibit A-6.2: RTCR Labor Burden Estimate for Assessments done by CWSs serving 1,001 - 4,100


Notification
Element
System
Specific
Element
Sample
Analytical
Element
Sample
Methodology
Element
Event
Situational
Element
Operational
Data Element
Historical
Trend Element
Sample Tap
Element
Sample Site
Element
Sample Area
Element
Third Party
Element
Report
Element
Total
Level 1 Assessment
Percentage of
Systems doing
Element
G
100%
100%
0%
100%
100%
60%0
100%
100%
5%
100%

100%

Estimated
Hours
Associated
with Element
H
2.5
1
0
2
5.5
4
3
2
2
5

7.5

Average
Burden
Associated with
Element
I = G* H
2.5
1
0
2
5.5
2.4
3
2
0.1
5

7.5
31
Level 2 Assessment (nonacutej
Percentage of
Systems doing
Element
J
100%
100%
0%
100%
100%
60%
100%
100%
5%
100%

100%

Estimated
Hours
Associated with
Element
K
3
2.5
0
2
2.5
4
3
2
2
7.5

20.5

Average
Burden
Associated with
Element
L = J* K
3
2.5
0
2
2.5
2.4
3
2
0.1
7.5
0
20.5
45.5
Level 2 Assessment (acute)
Percentage of
Systems doing
Element
M
100%
100%
0%
100%
100%
60%
100%
100%
100%
100%

100%

Estimated
Hours
Associated with
Element
N
3
1
0
2
5.5
4
3
2
1.5
7.5

20.5

Average
Burden
Associated with
Element
O = M* N
3
1
0
2
5.5
2.4
3
2
1.5
7.5
0
20.5
48.4
March 2009 Revised Total Coliform Rule
Technology and Cost Document
A-ll
Draft - Please do not cite, quote, or distribute

-------
     Exhibit A-7.1: Current TCR (as implemented) Labor Burden Estimate for
               Assessments done by CWSs serving 4,001 - 33,000


Notification
Element
System
Specific
Element
Sample
Analytical
Element
Sample
Methodology
Element
Event
Situational
Element
Operational
Data Element
Historical
Trend
Element
Sample Tap
Element
Sample Site
Element
Sample Area
Element
Third Party
Consulting
Element
Report
Element
Total
Nonacute MCL Violation
Percentage
of Systems
doing
Element
A
1 00%
1 00%
0%
80%
10%
75%
1 00%
1 00%
5%
30%

1 00%

Estimated
Hours
Associated
with
Element
B
3
1.5
0
3
5.5
4
9
1.5
2
4

7.5

Average
Burden
Associated
with
Element
C = A*B
3
1.5
0
2.4
0.55
3
9
1.5
0.1
1.2
0
7.5
29.75
Acute MCL Violation
Percentage
of Systems
doing
Element
D
100%
100%
0%
80%
100%
75%
100%
100%
100%
5%
0%
100%

Estimated
Hours
Associated
with
Element
E
3
1.5
0
3
5.5
4
9
2
2
3
0
7.5

Average
Burden
Associated
with
Element
F = D*E
3
1.5
0
2.4
5.5
3
9
2
2
0.15
0
7.5
36.05
March 2009 Revised Total Coliform Rule
Technology and Cost Document
A-13
Draft - Please do not cite, quote, or distribute

-------
        Exhibit A-7.2: RTCR Labor Burden Estimate for Assessments done by CWSs serving 4,100 - 33,000


Notification
Element
System
Specific
Element
Sample
Analytical
Element
Sample
Methodology
Element
Event
Situational
Element
Operational
Data Element
Historical
Trend Element
Sample Tap
Element
Sample Site
Element
Sample Area
Element
Third Party
Element
Report
Element
Total
Level 1 Assessment
Percentage of
Systems doing
Element
G
100%
100%
0%
100%
100%
75%
100%
100%
5%
100%

100%

Estimated
Hours
Associated
with Element
H
3
1.5
0
3
5.5
4
9
2
2
5.5

8.5

Average
Burden
Associated with
Element
I = G* H
3
1.5
0
3
5.5
3
9
2
0.1
5.5

8.5
41.1
Level 2 Assessment (nonacutej
Percentage of
Systems doing
Element
J
100%
100%
0%
100%
100%
75%
100%
100%
5%
100%
10%
100%

Estimated
Hours
Associated with
Element
K
3
1.5
0
3
7
4
9
2
2
7
109
22

Average
Burden
Associated with
Element
L = J* K
3
1.5
0
3
7
3
9
2
0.1
7
10.9
22
68.5
Level 2 Assessment (acute)
Percentage of
Systems doing
Element
M
100%
100%
0%
100%
100%
75%
100%
100%
100%
100%
10%
100%

Estimated
Hours
Associated with
Element
N
3
1.5
0
3
7
4
9
2
2
7.5
109
22

Average
Burden
Associated with
Element
O = M* N
3
1.5
0
3
7
3
9
2
2
7.5
10.9
22
70.9
March 2009 Revised Total Coliform Rule
Technology and Cost Document
A-14
Draft - Please do not cite, quote, or distribute
                      0

-------
     Exhibit A-8.1: Current TCR (as implemented) Labor Burden Estimate for
               Assessments done by CWSs serving 33,001 - 96,000


Notification
Element
System
Specific
Element
Sample
Analytical
Element
Sample
Methodology
Element
Event
Situational
Element
Operational
Data Element
Historical
Trend
Element
Sample Tap
Element
Sample Site
Element
Sample Area
Element
Third Party
Consulting
Element
Report
Element
Total
Nonacute MCL Violation
Percentage
of Systems
doing
Element
A
1 00%
1 00%
50%
90%
10%
90%
1 00%
100%
10%
30%

1 00%

Estimated
Hours
Associated
with
Element
B
6
1.5
4
4
17
14
11
3.5
4
14

12.5

Average
Burden
Associated
with
Element
C = A*B
6
1.5
2
3.6
1.7
12.6
11
3.5
0.4
4.2
0
12.5
59
Acute MCL Violation
Percentage
of Systems
doing
Element
D
100%
100%
50%
90%
100%
90%
100%
100%
100%
30%
0%
100%

Estimated
Hours
Associated
with
Element
E
6
1.5
4
4
9.5
14
16
3.5
4
14
0
12.5

Average
Burden
Associated
with
Element
F = D*E
6
1.5
2
3.6
9.5
12.6
16
3.5
4
4.2
0
12.5
75.4
March 2009 Revised Total Coliform Rule
Technology and Cost Document
A-15
Draft - Please do not cite, quote, or distribute

-------
       Exhibit A-8.2: RTCR Labor Burden Estimate for Assessments done by CWSs serving 33,001 - 96,000


Notification
Element
System
Specific
Element
Sample
Analytical
Element
Sample
Methodology
Element
Event
Situational
Element
Operational
Data Element
Historical
Trend Element
Sample Tap
Element
Sample Site
Element
Sample Area
Element
Third Party
Element
Report
Element
Total
Level 1 Assessment
Percentage of
Systems doing
Element
G
100%
100%
50%
100%
100%
75%
100%
100%
10%
100%
0%
100%

Estimated
Hours
Associated
with Element
H
6
1.5
4
4
10
14
11
3.5
4
7
0
12.5

Average
Burden
Associated with
Element
I = G* H
6
1.5
2
4
10
10.5
11
3.5
0.4
7
0
12.5
68.4
Level 2 Assessment (nonacutej
Percentage of
Systems doing
Element
J
100%
100%
50%
100%
100%
75%
100%
100%
10%
100%
10%
100%

Estimated
Hours
Associated with
Element
K
6
3.5
4
4
10
14
11
5
5
21
146
28

Average
Burden
Associated with
Element
L = J* K
6
3.5
2
4
10
10.5
11
5
0.5
21
14.6
28
116.1
Level 2 Assessment (acute)
Percentage of
Systems doing
Element
M
100%
100%
50%
100%
100%
75%
100%
100%
10%
100%
10%
100%

Estimated
Hours
Associated with
Element
N
6
3.5
4
4
10
14
16
5
5
21
146
28

Average
Burden
Associated with
Element
O = M* N
6
3.5
2
4
10
10.5
16
5
0.5
21
14.6
28
121.1
March 2009 Revised Total Coliform Rule
Technology and Cost Document
A-16
Draft - Please do not cite, quote, or distribute

-------
   Exhibit A-8.2: RTCR Labor Burden Estimate for Assessments done by CWSs
                               serving > 96,000
     Exhibit A-9.1: Current TCR (as implemented) Labor Burden Estimate for
                 Assessments done by CWSs serving > 96,000


Notification
Element
System
Specific
Element
Sample
Analytical
Element
Sample
Methodology
Element
Event
Situational
Element
Operational
Data Element
Historical
Trend
Element
Sample Tap
Element
Sample Site
Element
Sample Area
Element
Third Party
Consulting
Element
Report
Element
Total
Nonacute MCL Violation
Percentage
of Systems
doing
Element
A
1 00%
1 00%
90%
1 00%
10%
1 00%
1 00%
1 00%
10%
30%

1 00%

Estimated
Hours
Associated
with
Element
B
8
1.5
6
5
24
14.5
23.5
9.5
10
47.5

23

Average
Burden
Associated
with
Element
C = A*B
8
1.5
5.4
5
2.4
14.5
23.5
9.5
1
14.25
0
23
108.05
Acute MCL Violation
Percentage
of Systems
doing
Element
D
100%
100%
90%
100%
100%
100%
100%
100%
100%
30%
0%
100%

Estimated
Hours
Associated
with
Element
E
8
1.5
6
5
13
21
23.5
11.5
11.5
14
0
12.5

Average
Burden
Associated
with
Element
F = D*E
8
1.5
5.4
5
13
21
23.5
11.5
11.5
4.2
0
12.5
117.1
March 2009 Revised Total Coliform Rule
Technology and Cost Document
A-17
Draft - Please do not cite, quote, or distribute

-------
          Exhibit A-8.2: RTCR Labor Burden Estimate for Assessments done by CWSs serving > 96,000


Notification
Element
System
Specific
Element
Sample
Analytical
Element
Sample
Methodology
Element
Event
Situational
Element
Operational
Data Element
Historical
Trend Element
Sample Tap
Element
Sample Site
Element
Sample Area
Element
Third Party
Element
Report
Element
Total
Level 1 Assessment
Percentage of
Systems doing
Element
G
100%
100%
90%
100%
100%
100%
100%
100%
10%
100%
0%
100%

Estimated
Hours
Associated
with Element
H
8
1.5
6
5
20
14.5
23.5
9.5
10
47.5
0
23

Average
Burden
Associated with
Element
I = G* H
8
1.5
5.4
5
20
14.5
23.5
9.5
1
47.5
0
23
158.9
Level 2 Assessment (nonacutej
Percentage of
Systems doing
Element
J
100%
100%
90%
100%
100%
75%
100%
100%
10%
100%
10%
100%

Estimated
Hours
Associated with
Element
K
8
4
6
5
20.5
14.5
23.5
18.5
23.5
78
181
44

Average
Burden
Associated with
Element
L = J* K
8
4
5.4
5
20.5
10.875
23.5
18.5
2.35
78
18.1
44
238.225
Level 2 Assessment (acute)
Percentage of
Systems doing
Element
M
100%
100%
90%
100%
100%
100%
100%
100%
10%
100%
10%
100%

Estimated
Hours
Associated with
Element
N
8
4
6
6
22
21
23.5
18.5
23.5
78
192
44

Average
Burden
Associated with
Element
O = M* N
8
4
5.4
6
22
21
23.5
18.5
2.35
78
19.2
44
251.95
March 2009 Revised Total Coliform Rule
Technology and Cost Document
A-18
Draft - Please do not cite, quote, or distribute

-------