ICR
for
LT2ESWTR
Proposal
1
June
2003
Information
Collection
Request
for
The
National
Primary
Drinking
Water
Regulations;
Long
Term
2
Enhanced
Surface
Water
Treatment
Rule
Supporting
Statement
for
Recordkeeping
and
Reporting
1
Identification
of
the
Information
Collection
1a
Title
of
the
Information
Collection
Title:
National
Primary
Drinking
Water
Regulations;
Long
Term
2
Enhanced
Surface
Water
Treatment
Rule
(
Proposed
Rule)

U.
S.
EPA
Tracking
Number:
2097.01
1b
Short
Characterization
This
document
estimates
the
burden
and
cost
impacts
of
the
reporting
and
recordkeeping
requirements
of
the
Long
Term
2
Enhanced
Surface
Water
Treatment
Rule
(
LT2ESWTR).
The
LT2ESWTR
applies
to
public
drinking
water
systems
using
surface
water
or
ground
water
under
the
direct
influence
of
surface
water
(
GWUDI)
as
a
source.

The
proposed
LT2ESWTR
continues
to
strengthen
control
of
microbial
pathogens,
specifically
Cryptosporidium.
The
major
component
of
the
rule
involves
incorporation
of
system­
specific
treatment
requirements
based
on
a
"
microbial
framework"
approach.
This
approach
generally
involves
assignment
of
systems
into
different
categories
(
or
bins)
based
on
the
results
of
source
water
Cryptosporidium
monitoring.
Additional
treatment
requirements
depend
on
the
bin
to
which
the
system
is
assigned.
Systems
will
choose
technologies
to
comply
with
additional
treatment
requirements
from
a
"
toolbox"
of
options.

This
Information
Collection
Request
(
ICR)
estimates
the
burden
and
cost
associated
with
public
water
system
(
PWS)
operators
and
States
for
becoming
familiar
with
the
requirements
of
the
LT2ESWTR
and
source
water
monitoring.
The
information
collection
will
involve
a
total
of
437,563
labor
hours,
and
will
cost
a
total
of
$
41.0
million
to
7,622
respondents
during
the
three­
year
ICR
clearance
period.

Note:
The
reporting
and
recordkeeping
activities
required
for
the
full
rule
implementation
extend
beyond
the
3­
year
approval
period
for
this
Information
Collection
Request
(
ICR).
For
the
purposes
of
clarity
and
context,
all
the
requirements
of
the
rule
(
i.
e.,
even
those
beyond
this
3­
year
collection)
are
described
in
Section
4;
the
initial
3­
year
costs
and
burden
are
described
in
Sections
4
and
6,
with
supporting
tables
at
the
end
of
the
document.

This
ICR
has
been
completed
in
accordance
with
the
February
1999
version
of
EPA's
Guide
to
Writing
Information
Collection
Requests
Under
the
Paperwork
Reduction
Act
(
PRA)
of
1995
(
hereafter,
the
"
ICR
Handbook").
The
ICR
Handbook
was
prepared
by
EPA's
Office
of
Environmental
Information,
Office
of
Information
Collection,
Collection
Strategies
Division.
The
ICR
Handbook
provides
the
most
current
instructions
for
ICR
preparation
to
ensure
compliance
with
the
1995
PRA
Amendments
and
OMB's
implementing
guidelines.
ICR
for
LT2ESWTR
Proposal
2
June
2003
2
Need
for
and
Use
of
the
Collection
The
following
sections
describe
the
need
for
this
information
collection,
the
legal
authority
under
which
this
information
will
be
collected,
and
how
the
information
will
be
used.

2a
Need/
Authority
for
the
Collection
The
information
collected
under
this
rule
is
required
by
the
U.
S.
Environmental
Protection
Agency
(
EPA
or
Agency)
to
carry
out
its
monitoring
and
enforcement
responsibilities
under
the
Safe
Drinking
Water
Act
(
SDWA).
Without
comprehensive,
up­
to­
date
information
on
drinking
water
contamination,
the
Agency
would
not
be
able
to
meet
the
SDWA
statutory
requirements.

Sections
1401(
l)
and
1412(
a)(
3)
of
the
SDWA
require
EPA
to
publish
a
Maximum
Contaminant
Level
Goal
(
MCLG)
when
it
publishes
a
National
Primary
Drinking
Water
Regulation
(
NPDWR)
specifying
a
Maximum
Contaminant
Level
(
MCL)
or
treatment
technique.
EPA
is
authorized
to
promulgate
a
NPDWR
that
"
requires
the
use
of
a
treatment
technique
in
lieu
of
establishing
an
MCL,"
if
the
Agency
finds
that
"
it
is
not
economically
feasible
to
ascertain
the
level
of
the
contaminant."

Section
1445
of
the
SDWA
requires
that
Yevery
person
who
is
a
supplier
of
water
shall
establish
and
maintain
such
records,
make
such
reports,
conduct
such
monitoring,
and
provide
such
information
as
the
Administrator
may
reasonably
require
by
regulation
to
assist
him
in
establishing
regulations,
in
determining
whether
such
person
has
acted
or
is
in
compliance
with
this
title.
Y
The
1996
reauthorization
for
the
SDWA
mandated
new
drinking
water
requirements.
EPA's
general
authority
to
set
NPDWRs
was
modified
to
apply
to
contaminants
that
"
may
have
an
adverse
effect
on
the
health
of
persons"
or
that
are
"
known
to
occur
or
there
is
a
substantial
likelihood
that
the
contaminant
will
occur
in
public
water
systems
with
a
frequency
and
at
levels
of
public
health
concern.
Y"
Pathogens
are
examples
of
such
contaminants.

Two
existing
regulations,
the
Interim
Enhanced
Surface
Water
Treatment
Rule
(
IESWTR)
and
the
Long
Term
1
Enhanced
Surface
Water
Treatment
Rule
(
LT1ESWTR),
require
99
percent
removal
of
Cryptosporidium,
demonstrated
by
compliance
with
strict
limits
on
filter
effluent
turbidity.
Through
these
tightened
limits
on
turbidity,
these
rules
also
improve
removal
of
Giardia
and
viruses.
EPA
promulgated
the
Stage
1
Disinfectant/
Disinfection
Byproducts
Rule
(
DBPR)
at
the
same
time
as
the
IESWTR
and
plans
to
propose
a
Stage
2
DBPR
regulating
the
levels
of
disinfection
byproducts
(
DBPs).
DBPs
result
from
chemical
reactions
between
organic
and
inorganic
compounds
in
the
water
and
disinfectants
used
to
inactivate
microbial
pathogens.
Some
DBPs
are
associated
with
adverse
health
risks,
including
adverse
developmental
and
reproductive
health
effects
and
cancer.

EPA
expects
some
systems
to
change
treatment
practices
in
response
to
Stage
2
DBPR
requirements.
These
changes
have
the
potential
to
increase
the
occurrence
of
microbial
pathogens
in
drinking
water
as
systems
alter
the
use
of
disinfectants
to
comply
with
the
new
DBP
requirements.
The
LT2ESTWR
has
additional
benchmarking
provisions
to
ensure
that
systems
maintain
control
of
microbial
risks
as
they
take
steps
to
reduce
the
formation
of
DBPs.

EPA
is
making
a
concerted
effort
to
understand
and
balance
potential
DBP
risks,
microbial
risks,
and
the
costs
and
benefits
of
addressing
those
risks
in
its
rulemaking
efforts.
In
order
to
allow
for
ICR
for
LT2ESWTR
Proposal
3
June
2003
simultaneous
compliance
and
balancing
of
risk­
risk
trade­
offs
between
microbial
pathogens
and
DBPs,
EPA
is
promulgating
the
LT2ESWTR
concurrently
with
the
Stage
2
DBPR.
For
detailed
information
on
the
LT2ESWTR,
see
the
Economic
Analysis
for
the
Long
Term
2
Enhanced
Surface
Water
Treatment
Rule
or
the
Federal
Register
notice
for
the
rule.
For
detailed
information
regarding
the
Stage
2
DBPR,
see
the
draft
Economic
Analysis
for
the
Stage
2
Disinfectants
and
Disinfection
Byproducts
Rule.

The
LT2ESWTR,
proposed
to
further
strengthen
control
of
microbial
pathogens,
specifically
Cryptosporidium,
applies
to
public
drinking
water
systems
using
surface
water
or
GWUDI
as
a
source.
Separate
rule
provisions
apply
to
filtered
systems,
unfiltered
systems,
and
systems
with
uncovered
finished
water
reservoirs.

2b
Practical
Utility/
Users
of
the
Data
The
primary
data
items
collected
are
E.
coli
and
Cryptosporidium
concentrations
and
turbidity
of
source
water
at
PWSs.
EPA
intends
to
use
this
monitoring
data
to
do
the
following:

$
Determine
bins
for
treatment
requirements
$
Prescribe
the
appropriate
treatment
requirements
for
each
PWS,
using
the
bin
classifications,
and,
thereby,
provide
targeted
protection
for
systems
with
the
highest
risk
of
pathogen
contamination
$
Determine
the
potential
of
turbidity
and
E.
coli
concentration
to
indicate
Cryptosporidium
occurrence
Monitoring,
reporting,
and
recordkeeping
are
required
at
both
PWS
and
State
levels
under
the
NPDWRs.
States
must
maintain
records
essential
for
program
implementation
and
oversight.
These
records,
retained
in
EPA's
Safe
Drinking
Water
Information
System
(
SDWIS)
or
State
offices,
will
be
used
to
do
the
following:

$
Track
PWS
compliance
with
the
NPDWRs
ICR
for
LT2ESWTR
Proposal
4
June
2003
3
Non­
Duplication,
Consultations,
and
Other
Collection
Criteria
The
following
sections
verify
and
affirm
that
this
ICR
satisfies
the
Office
of
Management
and
Budget
(
OMB)
data­
collection
guidelines,
has
public
support,
and
does
not
duplicate
another
collection.

3a
Non­
Duplication
EPA
has
searched
the
Federal
Information
Locator
System
in
an
effort
to
ensure
non­
duplication
of
the
data
collection
efforts.
To
the
best
of
the
Agency's
knowledge,
data
currently
required
by
this
rule
are
not
available
from
any
other
source.

3b
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
Agencies
must
solicit
public
comments
on
an
ICR
for
a
60­
day
period
prior
to
submitting
the
request
to
Office
of
Management
and
Budget.
A
notice
for
public
comment
on
the
rule,
including
the
estimated
burden
and
cost,
is
included
in
the
Federal
Register
preamble
for
the
proposed
rule.

3c
Consultations
The
specific
provisions
of
the
LT2ESWTR
and
its
companion
regulation,
the
Stage
2
DBPR,
are
based
on
stakeholder
agreements
reached
by
the
Stage
2
Microbial
Disinfectants
and
Disinfection
Byproducts
(
M­
DBP)
Advisory
Committee,
convened
under
the
Federal
Advisory
Committee
Act
(
FACA).
EPA
convened
14
formal
negotiation
meetings
of
the
Stage
2
M­
DBP
Advisory
Committee
between
March
1999
and
September
2000.
Prior
to
convening
the
committee,
EPA
held
three
preparatory
stakeholder
meetings
on
pathogen
and
DBP
health
effects,
occurrence,
and
treatment.
The
following
is
a
list
of
non­
EPA
members
(
and
the
organizations
represented)
of
the
committee.
Contributors
included
a
broad
crosssection
of
participants:

Michael
Dimitriou
International
Ozone
Association
David
Esparza
All
Indian
Pueblo
Council
Cathey
Falvo
Physicians
for
Social
Responsibility
Peggy
Geimer
Chlorine
Chemistry
Council
Jeffrey
Griffiths
National
Association
of
People
with
AIDS
Richard
Haberman
Association
of
State
Drinking
Water
Agencies
Barker
Hamill
Environmental
Council
of
the
States
Christine
Hoover
National
Association
of
State
Utility
Consumer
Advocates
Rosemary
Menard
Portland
Water
Bureau
(
unfiltered
system
representative)
Richard
Moser
National
Association
of
Water
Companies
Erik
Olson
Natural
Resources
Defense
Council
David
Ozonoff
Conservation
Law
Foundation
David
Paris
American
Water
Works
Association
Brian
Ramaley
National
Association
of
Metropolitan
Water
Agencies
Charles
R.
Reading,
Jr.
Water
and
Wastewater
Equipment
Manufacturer's
Association
Mayor
Bruce
Tobey
National
League
of
Cities
Rodney
Tart
National
Rural
Water
Association
Chris
Wiant
National
Environmental
Health
Association
National
Association
of
County
and
City
Health
Officials
ICR
for
LT2ESWTR
Proposal
5
June
2003
John
Williams
National
Association
of
Regulatory
Utility
Commissioners
Marguerite
Young
Clean
Water
Action
EPA
obtained
input
through
other
channels
besides
the
Advisory
Committee,
working
closely
with
State,
Local,
and
Tribal
governments.
EPA
held
several
conference
calls
with
small
entity
representatives
(
SERs),
including
local
government
and
small
system
operators,
to
get
their
input
and
convened
a
Small
Business
Advocacy
Review
Panel
(
which
included
small
governments)
as
required
by
the
Small
Business
Regulatory
Enforcement
Fairness
Act
(
SBREFA).

During
the
first
call,
held
on
January
28,
2000,
EPA
presented
an
overview
of
the
SDWA
as
amended
in
1996
and
of
SBREFA.
Issues
and
schedules
for
the
LT2ESWTR
rules
were
also
discussed.
EPA
held
the
second
call
on
February
25,
2000.
EPA
presented
the
stakeholders
with
an
overview
of
the
EPA
regulatory
development
process,
background
on
the
development
of
the
M­
DBP
Rules,
particularly
regarding
health
risks,
issues/
options
identified
by
the
Advisory
Committee,
and
DBP
and
microbial
occurrence
in
small
systems.
EPA
held
the
third
meeting
on
April
7,
2000.
EPA
presented
SERs
with
a
cost
estimate
and
an
impact
analysis
for
selected
regulatory
alternatives.
In
addition,
EPA
presented
SERs
with
schedules
for
the
FACA
and
SBREFA
processes.
The
Agency
used
the
feedback
received
during
these
three
calls
in
developing
the
LT2ESWTR.
EPA
also
mailed
a
draft
version
of
the
preamble
to
the
attendees
of
these
conference
calls.

In
addition
to
obtaining
FACA
Tribal
input,
EPA
presented
the
LT2ESWTR
at
the
16th
Annual
Consumer
Conference
of
the
National
Indian
Health
Board,
the
Environmental
Council's
Annual
Conference
in
April
2000,
and
the
EPA/
Inter­
Tribal
Council
of
Arizona,
Inc.,
Tribal
Consultation
Meeting.
Over
900
attendees
representing
Tribes
from
across
the
country
attended
the
National
Indian
Health
Board's
Consumer
Conference,
and
over
100
Tribes
were
represented
at
the
annual
conference
of
the
National
Tribal
Environmental
Council.
Representatives
from
15
Tribes
participated
at
the
EPA/
Inter
Tribal
Council
of
Arizona
meeting.
At
the
first
two
conferences,
an
EPA
representative
conducted
two
workshops
on
EPA's
drinking
water
program
and
upcoming
regulations,
including
the
LT2ESWTR.
EPA
sent
the
presentation
materials
and
meeting
summary
to
over
500
Tribes
and
Tribal
organizations.

Fact
sheets
describing
the
requirements
of
the
proposed
rule
and
requesting
Tribal
input
were
distributed
at
an
annual
EPA
Tribal
meeting
in
San
Francisco
and
at
a
Native
American
Water
Works
Association
meeting
in
Scottsdale,
Arizona.
EPA
also
worked
through
its
Regional
Indian
Coordinators
and
the
National
Tribal
Operations
Committee
to
raise
awareness
of
the
development
of
the
proposed
rule.
In
addition,
EPA
mailed
all
federal
Tribes
the
fact
sheets
in
November
2000.
In
January
2002,
EPA
sent
updated
fact
sheets
to
all
Tribes
and
invited
them
to
participate
in
a
conference
call.
The
fact
sheets
described
the
need
for
the
LT2ESWTR
and
the
estimated
impact
on
Tribal
PWSs.
During
the
call,
some
Tribes
expressed
concern
about
the
need
for
additional
funding
to
implement
the
rule.
In
response
to
the
concerns
expressed
by
Tribal
representatives,
EPA
noted
that
the
LT2ESWTR
proposal
is
designed
to
minimize
costs
by
targeting
higher
risk
systems,
and
includes
other
provisions,
described
earlier,
to
reduce
burden.
Moreover,
the
projected
benefits
of
the
rule
substantially
exceed
costs.
EPA
also
explained
that
capital
projects
related
to
the
rule
would
be
eligible
for
Federal
funding
sources,
such
as
the
Drinking
Water
State
Revolving
Fund,
due
to
the
health
risks
associated
with
Cryptosporidium.

3d
Effects
of
Less
Frequent
Collection
The
Agency
has
determined
that
less
frequent
data
collection
may
fail
to
identify,
in
a
timely
manner,
significant
contaminant
concentrations
that
may
threaten
the
health
and
safety
of
drinking
water
consumers.
EPA
has
considered
alternatives
for
a
wide
range
of
frequency
and
burden
estimates
for
data
ICR
for
LT2ESWTR
Proposal
6
June
2003
collection.
It
has
selected
the
approach
that
requires
the
lowest
frequency
possible
while
maintaining
its
public
health
protection
objectives.

The
sampling
frequencies
required
by
the
LT2ESWTR
are
described
in
Section
4
of
this
document.
Monitoring
frequencies
have
been
carefully
devised
based
on
the
following
factors.

°
Type
of
contaminant
°
Source
water
type
and
size
(
population
served)
of
system
°
Recovery
efficiency
of
the
sampling
method
°
Simultaneous
compliance
with
the
provisions
of
the
Stage
2
DBPR
3e
General
Guidelines
The
LT2ESWTR
complies
with
the
guidelines
(
5
CFR
1320.6)
implemented
under
the
Paperwork
Reduction
Act
with
one
exception:
records
must
be
maintained
for
a
period
of
5
years
or
more.
Under
SDWA,
monitoring
records
must
be
maintained
on
a
constant
basis;
therefore,
the
collection
period
is
supported
by
statutory
requirement.
The
rule
does
not
alter
the
record
maintenance
requirements
that
are
found
in
CFR
§
141.33.
Section
141.33
stipulates
that
records
of
bacteriological
analyses
shall
be
kept
for
not
less
than
5
years,
and
records
of
actions
taken
by
a
system
to
correct
violations
of
primary
drinking
water
regulations
shall
be
kept
for
a
period
of
not
less
than
3
years.

3f
Confidentiality
and
Sensitive
Questions
The
data
collection
proposed
does
not
raise
confidentiality
issues
or
ask
any
sensitive
questions
concerning
sex,
behavior,
attitudes,
religious
beliefs,
or
other
matters.
ICR
for
LT2ESWTR
Proposal
7
June
2003
4
The
Respondents
and
the
Information
Requested
The
following
sections
provide
information
on
the
respondents
in
this
information
collection,
the
information
they
are
being
requested
to
provide,
and
the
activities
they
will
perform
to
gather
this
information.

4a
Respondent/
SIC
Codes
Respondents
under
the
LT2ESWTR
include
the
operators
and
owners
of
PWSs.
The
Standard
Industrial
Classification
(
SIC)
code
for
investor­
owned
water
systems
is
4941.
The
North
American
Industry
Classification
System
(
NAICS)
code
is
22131,
Water
Supply
and
Irrigation
Systems.
The
SIC
code
for
both
publicly
owned
water
systems
and
State
agencies
is
9511.
The
NAICS
code
is
92411,
Administration
of
Air
and
Water
Resource
and
Solid
Waste
Management
Programs.
State/
Primacy
Agency
officials
serve
in
the
role
of
respondent
when
reporting
compliance
data
to
EPA.

PWSs
are
defined
as
those
systems
that
provide
piped
water
for
human
consumption
and
have
at
least
15
service
connections
or
regularly
serve
at
least
25
people
at
least
60
days
of
the
year.
A
community
water
system
(
CWS)
is
one
that
serves
at
least
15
connections
used
by
year­
round
residents
or
regularly
serves
at
least
25
year­
round
residents.
Noncommunity
systems,
by
definition,
are
all
other
PWSs.
Noncommunity
systems
include
transient
systems
and
nontransient
systems.
Nontransient
systems
serve
the
same
25
people
at
least
6
months
of
the
year.
Transient
systems
do
not
regularly
serve
the
same
25
people
6
months
of
the
year.

Although
PWSs
are
the
entities
regulated
by
the
LT2ESWTR,
water
treatment
plants
(
which
have
the
same
NAICS
and
SIC
codes
and
which
may
or
may
not
be
self­
contained
PWSs)
are
also
respondents
under
the
LT2ESWTR.
Some
PWSs
have
more
than
one
source
and
more
than
one
plant,
and
the
LT2ESWTR
requires
monitoring
of
each
surface
water
or
GWUDI
source
unless
the
associated
plant
has
a
specified
level
of
treatment
in
place.
In
addition,
the
models
used
to
estimate
the
burden
and
associated
costs
for
this
ICR
are
based
on
plant­
level
Cryptosporidium
and
other
data
obtained
during
the
Information
Collection
Rule
study
in
1997­
1998.
(
The
economic
analysis
for
the
LT2ESWTR
also
models
burden
and
cost
based
on
plant­
level
data
from
the
Information
Collection
Rule
Supplemental
Surveys
conducted
in
1999
and
2000.
These
distributions
were
not
used
here
because
the
1997­
1998
study
has
more
conservative
data
on
a
larger
number
of
plants.)
Therefore,
except
for
burden
associated
with
start­
up,
burden
and
costs
for
operators
and
owners
of
PWSs
are
shown
by
plant
in
this
ICR.

4b
Information
Requested
The
following
sections
provide
details
on
data
items
requested
and
on
associated
activities
respondents
will
be
required
to
undertake
to
provide
this
information.

4b(
i)
Data
Items
Under
this
information
collection,
all
PWSs
conducting
source
water
monitoring
must
submit
a
sampling
schedule
that
includes
planned
dates
for
source
water
sampling.
ICR
for
LT2ESWTR
Proposal
8
June
2003
Medium
and
large
systems
(
serving
at
least
10,000
people)
will
provide
the
following:

°
Monthly
E.
coli
and
Cryptosporidium
monitoring
results,
to
be
taken
over
a
period
of
2
years,
plus
two
matrix
spike
samples
for
Cryptosporidium
to
be
analyzed
over
the
course
of
the
monitoring
period.

$
Monthly
turbidity
monitoring
results
(
sampled
concurrently
with
Cryptosporidium
and
E.
coli)
taken
over
a
2­
year
period.

Small
systems
(
serving
fewer
than
10,000
people)
will
provide
the
following:

$
Biweekly
E.
coli
monitoring
results,
to
be
taken
over
a
period
of
1
year.
(
Some
of
this
monitoring
will
occur
outside
of
the
ICR
clearance
period.
Future
ICRs
will
address
the
burden
for
that
monitoring.)

$
24
Cryptosporidium
samples
taken
over
a
period
of
1
year
plus
2
matrix
spike
samples,
only
for
those
systems
that
exceed
the
Cryptosporidium
monitoring
trigger
based
on
E.
coli
monitoring
results,
as
described
in
Section
4b(
ii)(
a),
below.
(
This
monitoring
will
occur
outside
of
the
ICR
clearance
period.)

All
medium
and
large
system
monitoring
data
will
be
furnished
to
EPA
electronically
by
the
laboratory
conducting
the
analysis.

PWSs
of
all
sizes
that
install
new
technology
as
a
result
of
their
bin
classifications
will
be
required
to
demonstrate
compliance
with
certain
criteria
for
each
technology.
(
This
reporting
will
occur
outside
the
ICR
clearance
period).

PWSs
of
all
sizes
that
conduct
Cryptosporidium
monitoring
will
be
required
to
apply
for
approval
of
existing
inactivation
benchmarks,
to
calculate
a
benchmark
based
on
existing
profiling
data,
or
to
conduct
inactivation
profiling.
Profiling
would
involve
one
year
of
monitoring
disinfectant
residual
concentrations,
water
temperature,
contact
time,
and
pH
and
calculating
log
inactivation
levels
for
Giardia
and
viruses.
Some
small
PWSs
that
do
not
have
to
monitor
Cryptosporidium
may
also
have
to
conduct
inactivation
profiling
if
their
trihalomethane
or
haloacetic
acid
levels
exceed
certain
limits.
For
PWSs
serving
10,000
or
more
people,
disinfection
profiling
must
begin
two
years
after
rule
promulgation.

PWSs
that
choose
not
to
cover
their
uncovered
finished
water
reservoirs
or
treat
the
water
leaving
such
reservoirs
(
see
section
4b(
ii))
must
each
submit
a
risk
mitigation
plan
to
their
States
for
approval.
The
plans
must
address
physical
access
to
reservoirs,
surface
water
runoff,
animal
and
bird
waste,
and
ongoing
water
quality
assessment.

PWSs
must
keep
all
monitoring
data
collected
under
the
LT2ESWTR
on
file
for
6
years.
These
data
must
be
available
for
review
during
sanitary
surveys
and
during
future
monitoring
or
bin
reassessment
efforts.

State/
Primacy
Agency
Recordkeeping
Requirements
Under
the
LT2ESWTR,
States
must
keep
records
as
prescribed
at
§
142.14.
EPA
will
maintain
the
first
2
years
of
medium
and
large
system
E.
coli
and
Cryptosporidium
monitoring
data.
States
will
maintain
the
small
system
E.
coli
and
Cryptosporidium
data,
beginning
30
months
after
promulgation.
ICR
for
LT2ESWTR
Proposal
9
June
2003
States
will
be
required
to
maintain
the
following
data
(
with
the
exception
of
the
initial
source
water
monitoring
data,
all
data
will
be
collected
outside
of
the
3­
year
ICR
clearance
period):

$
Results
of
initial
and
reassessment
source
water
monitoring
for
small
systems
$
Initial
bin
determinations
for
each
system
$
Records
of
toolbox
treatment
technologies
that
systems
choose
to
meet
their
treatment
technique
requirements,
plus
any
changes
in
toolbox
treatment
technologies,
including
all
documentation
necessary
to
demonstrate
compliance
with
required
design
and
implementation
criteria
for
receiving
log
credit
for
toolbox
options
$
Any
changes
to
initial
bin
classifications
based
on
sanitary
survey
review
$
Records
of
technologies
employed
by
unfiltered
systems
to
meet
virus,
Giardia,
and
Cryptosporidium
inactivation
requirements
$
List
of
systems
required
to
cover
or
treat
effluent
of
an
uncovered
finished
water
reservoir
$
List
of
systems
for
which
the
State
has
waived
the
requirement
to
treat
or
cover
reservoirs
and
supporting
documentation
$
Documentation
submitted
by
systems
required
to
cover
or
treat
uncovered
finished
water
reservoirs
regarding
steps
they
have
taken
to
meet
requirements,
including
risk
mitigation
plans.

State/
Primacy
Agency
Reporting
Requirements
The
LT2ESWTR
contains
several
additions
to
§
142.15
(
Reports
Made
by
States/
Primacy
Agencies).
The
following
must
be
reported
to
EPA,
although
with
the
exception
of
the
source
water
monitoring
data,
not
during
the
3­
year
ICR
clearance
period:

$
Results
of
initial
and
reassessment
source
water
monitoring
(
for
small
systems)

$
Initial
bin
characterizations
for
each
system
and
any
changes
in
bin
classifications
$
Toolbox
treatment
technologies
chosen
by
systems
to
meet
bin
requirements
$
Disinfectants/
treatment
technologies
employed
by
unfiltered
systems
to
meet
inactivation
requirements
$
Any
finding
that
a
system
is
not
effectively
meeting
the
required
treatment
level
for
the
systemspecific
bin
classification
4b(
ii)
Respondent
Activities
As
mentioned
above,
respondents
include
both
PWSs
and
State
officials.
Their
information
collection
activities
are
described
separately
below.
ICR
for
LT2ESWTR
Proposal
10
June
2003
4b(
ii)(
a)
Public
Water
System
Activities
Activities
under
this
information
collection
are
related
to
start­
up
and
training
on
the
rule
and
required
E.
coli
and
Cryptosporidium
monitoring.
A
summary
of
the
rule
requirements
is
provided
below,
followed
by
a
summary
of
the
activities
for
which
systems
will
incur
a
burden.

Treatment
Requirements
for
Filtered
Systems
For
filtered
systems,
the
LT2ESWTR
incorporates
system­
specific
treatment
requirements
based
on
a
"
microbial
framework"
approach.
This
approach
involves
assignment
of
systems
into
different
"
action
bins."
Bin
classification
and
subsequent
Cryptosporidium
reduction
requirements
for
filtered
surface
water
and
GWUDI
systems
will
be
based
on
results
of
plant­
specific
source
water
monitoring
(
see
below).
Monitoring
schedules
and
start
dates
will
be
different
for
systems
serving
fewer
than
10,000
and
those
serving
at
least
10,000
people.

Depending
on
their
bin
classification,
systems
will
be
required
to
achieve
Cryptosporidium
treatment
requirements
that
are
in
addition
to
the
2
log
(
99
percent)
removal
required
under
the
IESWTR
and
the
LT1ESWTR.
The
levels
of
additional
Cryptosporidium
reduction
summarized
in
Exhibit
1
are
for
systems
that
employ
conventional
rapid
sand,
slow
sand,
diatomaceous
earth,
or
alternative
filtration
technologies.
Systems
using
direct
filtration
(
i.
e.,
coagulation
with
rapid
granular
filtration
but
no
sedimentation)
must
achieve
an
additional
0.5
log
of
Cryptosporidium
reduction
if
they
are
classified
in
bins
2,
3,
or
4.

Exhibit
1
Action
Bin
Requirements
Bin
Number
Cryptosporidium
Concentration
(
oocysts/
liter)
Additional
Treatment
Beyond
the
2
Log
Required
Under
IESWTR
and
LT1ESWTR
1
<
0.075
No
action
2

0.075
and
<
1.0
1
log
treatment
(
systems
may
use
any
technology
or
combination
of
technologies
from
the
microbial
toolbox
as
long
as
total
credit
is
at
least
1
log)

3

1.0
and
<
3.0
2
log
treatment
(
systems
must
achieve
at
least
1
log
treatment
using
ozone,
chlorine
dioxide,
UV,
membranes,
bag/
cartridge
filters,
or
in­
bank
filtration)

4

3.0
2.5
log
treatment
(
systems
must
achieve
at
least
1
log
treatment
using
ozone,
chlorine
dioxide,
UV,
membranes,
bag/
cartridge
filters,
or
in­
bank
filtration)

Note(
s):
Cryptosporidium
concentration
for
large
systems
is
based
on
the
highest
running
annual
average
of
2
years
of
monthly
data,
or
the
24­
month
mean
of
bimonthly
data.
The
concentration
for
small
systems
is
the
average
of
all
Cryptosporidium
concentrations
from
semimonthly
sampling.
Additional
treatment
requirements
shown
are
for
conventional
rapid
sand,
slow
sand,
diatomaceous
earth,
or
alternative
filtration
technologies.
Direct
filtration
systems
must
achieve
an
additional
½
log
of
treatment
if
they
fall
in
bins
2,
3,
or
4.
ICR
for
LT2ESWTR
Proposal
11
June
2003
Systems
have
3
years
following
initial
bin
classification
to
meet
the
treatment
requirements
associated
with
the
bin.
Individual
States/
Primacy
Agencies
may
grant
systems
an
additional
2­
year
extension
to
comply
when
capital
investments
are
necessary.
To
meet
the
Cryptosporidium
treatment
requirements
for
the
bin
in
which
they
are
classified,
systems
may
select
from
a
"
toolbox"
of
treatment
or
management
options.
Systems
currently
using
ozone,
chlorine
dioxide,
ultraviolet
(
UV)
light,
or
membranes
in
addition
to
conventional
treatment
may
receive
credit
for
those
technologies
toward
meeting
bin
requirements.

Six
years
after
initial
bin
classification,
systems
will
be
required
to
conduct
a
second
round
of
monitoring
for
bin
reclassification
Systems
that
provide
a
total
of
5.5
log
treatment
for
Cryptosporidium
are
exempt
from
future
monitoring
and
reclassification.

In
addition
to
the
reassessment
and
bin
reclassification
described
above,
the
State/
Primacy
Agency
will
assess
any
significant
changes
in
the
watershed
and
source
water
as
part
of
the
3­
year
sanitary
survey
process.
The
State/
Primacy
Agency
will
then
determine
what
follow­
up
action
is
appropriate
in
response
to
source
water
changes.
Such
actions
could
include
options
from
the
microbial
toolbox.

Treatment
Requirements
for
Unfiltered
Systems
The
LT2ESWTR
will
require
unfiltered
systems
to
continue
to
meet
the
filtration
avoidance
criteria
under
the
1989
Surface
Water
Treatment
Rule
(
SWTR)
and
continue
to
provide
4
log
virus
and
3
log
Giardia
inactivation.
Building
on
the
SWTR
requirements,
the
LT2ESWTR
requires
unfiltered
systems
to
provide
a
minimum
of
2
log
and
in
some
cases
3
log
Cryptosporidium
inactivation.
This
inactivation
requirement
must
be
met
using
a
minimum
of
two
disinfectants.

All
unfiltered
systems,
except
those
already
providing
3
log
Cryptosporidium
inactivation,
must
monitor
for
Cryptosporidium
using
the
same
schedule
as
filtered
systems.
Unlike
filtered
systems,
however,
unfiltered
systems
are
not
required
to
monitor
E.
coli
and
turbidity.
Systems
with
Cryptosporidium
occurrence
levels
less
than
or
equal
to
0.01
oocysts/
liter
(
oocysts/
L)
will
be
required
to
provide
2
log
inactivation;
those
with
levels
above
0.01
oocysts/
L
must
provide
3
log
Cryptosporidium
inactivation.

Requirements
for
Existing
Uncovered
Finished
Water
Reservoirs
Systems
with
uncovered
finished
water
reservoirs
must
cover
the
reservoir
or
treat
reservoir
discharge
to
the
distribution
system
to
achieve
4
log
virus
inactivation,
unless
the
State/
Primacy
Agency
determines
that
existing
risk
mitigation
is
adequate.
Risk
mitigation
plans
must,
at
a
minimum,
address
physical
access,
surface
water
run­
off,
animal
and
bird
waste,
and
on­
going
water
quality
assessment.

Medium
and
Large
Systems
(
Those
Serving
at
Least
10,000
People)

All
systems
subject
to
the
LT2ESWTR
will
conduct
rule
start­
up
activities.
Start­
up
activities
associated
with
the
LT2ESWTR
that
are
expected
to
have
negligible
costs
include
preparing
a
schedule
for
monitoring
and
making
arrangements
for
sample
analysis.
Significant
activities
include
the
following:

°
Reading
and
understanding
the
rule
°
Participating
in
training
concerning
the
requirements
of
the
rule
ICR
for
LT2ESWTR
Proposal
12
June
2003
Systems
will
be
required
to
conduct
monthly
source
water
monitoring
and
analysis
on
a
predetermined
schedule
for
24
months,
beginning
6
months
after
promulgation.
Unfiltered
systems
will
monitor
Cryptosporidium,
while
filtered
systems
will
monitor
Cryptosporidium,
E.
coli,
and
turbidity.
(
PWSs
commonly
monitor
source
water
turbidity
for
operational
control.
Also,
to
meet
SWTR,
IESWTR,
and
LT1ESWTR
requirements,
PWSs
have
turbidity
analytical
equipment
in­
house
and
operators
are
experienced
with
turbidity
measurement.
Based
on
this,
EPA
assumes
that
the
incremental
turbidity
monitoring
burden
associated
with
the
LT2ESWTR
is
negligible.)

Information
collection
activities
associated
with
E.
coli
and
Cryptosporidium
source
water
monitoring
include
the
following:

°
Drawing
the
required
sample
°
Conducting
the
analysis
or,
for
systems
without
the
necessary
analytical
equipment,
shipping
the
sample
to
a
commercial
laboratory
for
analysis
$
Reporting
data
monthly
$
Keeping
monitoring
records
on
file
for
6
years
after
the
end
of
the
monitoring
period
$
Determining
bin
classification
Small
Systems
(
Those
Serving
Fewer
Than
10,000
People)

Start­
up
activities
associated
with
the
LT2ESWTR
expected
to
have
negligible
costs
include
preparing
a
schedule
for
monitoring
and
making
arrangements
for
sample
analysis.
Significant
activities
include
the
following:

$
Reading
and
understanding
the
rule
$
Participating
in
training
concerning
the
requirements
of
the
rule
Source
water
monitoring
will
begin
2
years
after
the
large
and
medium
systems
initiate
source
water
Cryptosporidium
monitoring.
Small
filtered
systems
will
conduct
1
year
of
biweekly
E.
coli
source
water
monitoring
and
will
be
required
to
conduct
Cryptosporidium
monitoring
only
if
E.
coli
concentrations
exceed
specified
trigger
levels.
Small
unfiltered
systems
will
all
conduct
1
year
of
semimonthly
Cryptosporidium
monitoring.
Information
collection
activities
associated
with
E.
coli
and
Cryptosporidium
source
water
monitoring
include
the
following:

°
Drawing
the
required
sample
°
Conducting
the
analysis
or,
for
systems
without
the
necessary
analytical
equipment,
shipping
the
sample
to
a
commercial
laboratory
for
analysis.

$
Reporting
data
monthly
$
Keeping
monitoring
records
on
file
for
6
years
after
the
end
of
the
monitoring
period
$
Determining
bin
classification
ICR
for
LT2ESWTR
Proposal
13
June
2003
4b(
ii)(
b)
State
Activities
State
officials
usually
serve
in
the
role
of
respondents
when
reporting
compliance
data
to
EPA.
States
with
primacy
are
currently
required
to
maintain
records
of
State
verification
activities
and
each
determination
made
and
to
report
to
EPA
in
accordance
with
State
recordkeeping
requirements
(
§
142.14)
through
SDWIS.

States
with
primacy
will
act
as
the
Agency
in
ensuring
the
implementation
of
the
LT2ESWTR.
To
successfully
meet
their
responsibilities,
the
States
are
expected
to
be
involved
in
the
following
activities:

$
Reading
and
understanding
the
rule
$
Developing
the
framework
for
implementing
the
LT2ESWTR
program
$
Maintaining
and
updating
the
data
management
system
$
Training
and
assisting
PWS
staff
$
Training
State/
Primacy
Agency
staff
EPA
will
maintain
the
medium
and
large
system
Cryptosporidium
monitoring
data
during
initial
monitoring.
Consequently,
there
are
no
State
activities
associated
with
medium
and
large
system
monitoring.
EPA
will
turn
over
data
associated
with
medium
and
large
system
monitoring
to
the
States
and
Territories.
States
will
manage
and
maintain
E.
coli
and
Cryptosporidium
monitoring
data
from
small
systems,
analyze
small
systems'
monitoring
reports
and
make
bin
classifications,
and
respond
to
systems'
inquiries.
During
bin
reclassification,
States
will
review
data
from
systems
of
all
sizes.

State/
Primacy
Agency
Reporting
and
Recordkeeping
Requirements
See
section
4b(
i).

State/
Primacy
Agency
Primacy
Requirements
To
obtain
primacy
for
the
LT2ESWTR,
States/
Primacy
Agencies
must
apply
under
§
142.16.
The
primacy
application
must
be
submitted
to
the
Agency
for
approval
and
must
describe
how
the
State
will
accomplish
the
LT2ESWTR
primacy
requirements.
Specifically,
the
plan
must
address
special
requirements
for
approving
watershed
control
programs,
approving
risk
mitigation
plans
for
systems
that
would
like
to
avoid
the
requirement
to
cover
finished
water
reservoirs,
and
assessing
changes
in
source
water
quality
and
the
watershed
as
part
of
a
sanitary
survey.

4c
ICR
Approval
Activities
Many
of
the
required
regulatory
monitoring,
reporting,
and
recordkeeping
activities
described
above
will
occur
outside
the
3­
year
ICR
approval
period.
This
section
clarifies
the
activities
that
are
included
in
the
ICR
burden
and
cost
estimates
that
cover
the
first
3
years
after
promulgation.
ICR
for
LT2ESWTR
Proposal
14
June
2003
4c(
i)
PWSs
Start­
up
activities
for
systems
include
reading
and
understanding
the
rule
and
preparing
sampling
schedules.
Systems
will
also
need
to
make
arrangements
for
Cryptosporidium
sample
analysis.
Monitoring
activities
to
be
completed
are
shown
in
Exhibit
2.
Eventually,
but
not
in
this
or
the
next
clearance
period,
systems
will
have
to
demonstrate
to
the
State
that
they
meet
the
criteria
for
the
toolbox
treatment
technologies
they
have
selected.

Exhibit
2
LT2ESWTR
Activities
to
Be
Completed
by
Systems
During
the
3
Years
Following
Promulgation
Activity
Medium
and
Large
Systems
Small
Systems
Start­
up
All
All
Assessment
for
binning
E.
coli
monitoring
All
6
of
12
months
complete
Cryptosporidium
monitoring
All
None
Reporting
and
recordkeeping
All
6
of
12
months
complete
Treatment
Installation
Reporting
to
demonstrate
compliance
with
technology
None
None
Disinfection
benchmarking
(
for
systems
changing
technologies)
None
None
Assessment
for
bin
reclassification
E.
coli
monitoring
None
None
Cryptosporidium
monitoring
None
None
Reporting
and
recordkeeping
None
None
4c(
ii)
States/
Primacy
Agencies
During
the
3­
year
ICR
clearance
period,
States
will
be
involved
in
start­
up
activities,
including
reading
and
understanding
the
rule,
training
staff
as
well
as
PWSs,
regulatory
adoption,
and
primacy
application.
Because
medium
and
large
systems
report
their
microbial
data
directly
to
EPA
through
the
Internet,
States
will
not
be
responsible
for
recordkeeping
for
these
systems.
However,
small
systems
will
report
their
microbial
data
to
the
States;
States
will
have
to
maintain
these
data.

Because
medium
and
large
systems
will
use
the
Internet
reporting
software
to
determine
their
bin
characterizations,
States
will
not
be
responsible
for
bin
characterization
for
these
systems.
States
will
determine
the
bin
assignments
for
small
systems,
but
not
within
this
3­
year
clearance
period.
ICR
for
LT2ESWTR
Proposal
15
June
2003
5
The
Information
Collected,
Agency
Activities,
Collection
Methodology,
and
Information
Management
The
following
sections
describe
the
Agency
activities
related
to
analyzing,
maintaining,
and
distributing
the
information
collected.

5a
Agency
Activities
EPA
will
be
responsible
for
promulgating
this
rule
and
overseeing
its
implementation.
Implementation
of
monitoring
requirements
(
with
the
exception
of
medium
and
large
system
Cryptosporidium
monitoring
data)
will
rely
extensively
on
those
States
that
have
assumed
primacy
under
Section
1413
of
the
SDWA
and
40
CFR
142.16.
The
Agency
will
be
involved
in
the
following
activities:

$
Developing
the
rule
and
guidance
materials
$
Reviewing
and
analyzing
data
submission
from
the
States
$
Processing
and
maintaining
SDWIS
$
Collecting
and
manage
monitoring
data
submitted
by
medium
and
large
systems.

5b
Collection
Methodology
and
Management
The
1996
SDWA
Amendments
require
EPA
to
develop
rules
to
balance
the
risks
between
microbial
pathogens
and
DBPs.
To
do
so,
EPA
consulted
with
and
received
recommendations
from
the
Advisory
Committee
on
the
development
of
the
LT2ESWTR
and
the
Stage
2
DBPR.

This
rule
does
not
mandate
specific
requirements
on
information
collection
methodology
and
management.
The
LT2ESWTR
does
expect
systems
to
be
responsible
for
validating
the
information
collected.
States
are
expected
to
maintain
records
essential
for
program
implementation
and
oversight.
These
records
are
retained
in
SDWIS,
allowing
both
EPA
and
the
general
public
to
track
system
compliance.

Medium
and
large
systems
are
expected
to
use
commercial
laboratories
for
Cryptosporidium
analysis.
Because
laboratories
for
these
systems
will
submit
data
directly
to
EPA
using
an
Internet­
based
data
entry
system,
EPA
assumed
that
PWSs
will
incur
no
burden
or
cost
for
data
collection.

5c
Small
Entity
Flexibility
The
Regulatory
Flexibility
Act,
5
U.
S.
C.
602
et
seq.,
requires
the
Agency
to
explicitly
consider
the
effects
of
regulations
on
small
entities
and
to
develop
(
under
certain
circumstances)
a
Regulatory
Flexibility
Analysis
(
RFA)
describing
these
impacts.
For
the
purposes
of
this
rule,
the
Agency
defines
small
entities
(
PWSs)
as
those
serving
fewer
than
10,000
people.
ICR
for
LT2ESWTR
Proposal
16
June
2003
5c(
i)
Minimizing
Burden
EPA
is
proposing
monitoring
requirements
that
will
help
PWSs
better
understand
the
levels
of
Cryptosporidium
in
their
source
water.
The
information
submitted
will
help
EPA
and
systems
to
determine
the
most
appropriate
treatment
requirements
for
effectively
reducing
the
risks
to
human
health
from
waterborne
pathogens.
The
Agency
has
taken
the
following
steps
to
minimize
the
burden
associated
with
this
monitoring
on
small
PWSs:

$
In
lieu
of
additional
Cryptosporidium
compliance
monitoring,
systems
with
at
least
2
years
of
historical
Cryptosporidium
data
that
are
equivalent
in
sample
number,
frequency,
and
data
quality
to
data
collected
under
the
LT2ESWTR
may
submit
their
data
to
the
State/
Primacy
Agency
for
consideration
in
determining
bin
classification.

$
Small
filtered
PWSs
will
not
have
to
monitor
for
Cryptosporidium
unless
their
E.
coli
concentrations
exceed
certain
levels.
For
small
PWSs,
any
required
monitoring
would
not
begin
until
2
years
after
medium
and
large
systems
initiate
monitoring.
During
the
time
between
rule
promulgation
and
the
start
of
small
system
monitoring,
EPA
intends
to
work
with
stakeholders
to
evaluate
indicators
and
system
characterization
scenarios
using
medium
and
large
system
data
for
predicting
Cryptosporidium
occurrence.
If
feasible,
EPA
may
modify
the
Cryptosporidium
monitoring
requirement
to
reduce
the
burden
for
small
systems.

5c(
ii)
Consideration
of
Alternatives
In
developing
the
specific
provisions
of
the
LT2ESWTR
and
the
Stage
2
DBPR,
EPA
convened
14
formal
negotiation
meetings
of
the
M­
DBP
Advisory
Committee,
along
with
three
stakeholder
meetings,
to
reach
consensus
regarding
the
provisions
of
the
two
rules.
A
Technical
Work
Group
supported
the
Advisory
Committee
by
collecting,
developing,
evaluating,
and
presenting
key
data
related
to
the
LT2ESWTR,
including
new
data
on
pathogenicity,
occurrence,
and
treatment
of
microbial
contaminants,
specifically
Cryptosporidium.

EPA,
in
consultation
with
nationally
recognized
experts
in
statistics,
evaluated
data
collected
under
the
Information
Collection
Rule
and
the
Information
Collection
Rule
Supplemental
Surveys
to
generate
estimates
of
the
national
occurrence
of
Cryptosporidium
in
surface
water.
These
data
were
evaluated
under
various
regulatory
scenarios
to
determine
the
benefits
and
costs
under
various
monitoring
and
treatment
schemes,
with
the
ultimate
goal
of
reducing
the
occurrence
of
Cryptosporidium
in
finished
water,
while
minimizing
the
cost
impacts
to
PWSs.

The
M­
DBP
Advisory
Committee
focused
on
several
issues,
including
the
effectiveness
of
conventional
versus
direct
filtration
in
the
removal
of
Cryptosporidium,
water
quality
parameter
surrogates
for
Cryptosporidium
monitoring,
and
alternative
monitoring
strategies
to
minimize
monitoring
costs
to
small
drinking
water
systems.
All
four
regulatory
alternatives
considered
for
filtered
systems
allow
systems
to
select
treatment
technologies
based
on
the
amount
of
treatment
needed
and
the
effectiveness
of
each
technology.
One
alternative
requires
inactivation
of
Cryptosporidium
by
all
systems,
while
the
other
three
base
treatment
requirements
on
the
amount
of
Cryptosporidium
found
in
a
system's
source
water.
These
measurements
place
a
system
in
one
of
several
"
bins,"
ranging
from
"
no
action"
to
an
additional
2.5
log
treatment.

Exhibit
3
summarizes
binning
and
treatment
scenarios
for
filtered
systems
for
each
specific
regulatory
alternative.
These
rule
alternatives
were
defined
by
two
criteria:
(
1)
bin
boundaries
as
defined
ICR
for
LT2ESWTR
Proposal
17
June
2003
by
results
of
Cryptosporidium
monitoring,
and
(
2)
treatment
scenarios
(
log
contaminant
removal
requirements)
required
for
each
bin.

Exhibit
3
Summary
of
Binning
and
Treatment
Scenarios
for
Filtered
Systems
for
Each
Regulatory
Alternative
Source
Water
Cryptosporidium
Monitoring
Results
(
oocysts/
L)
Additional
Treatment
Requirements
Alternative
A1
2.0
log
inactivation
required
for
all
systems
Alternative
A2
<
0.03
No
action

0.03
­
0.1
0.5
log

0.1
­
1.0
1.5
log

1.0
2.5
log
Alternative
A3
­
Preferred
Alternative
<
0.075
No
action

0.075
­
1.0
1
log

1.0
­
3.0
2
log

3.0
2.5
log
Alternative
A4
<
0.10
No
action

0.1­
1.0
0.5
log

1.0
1
log
Note:
Additional
treatment
requirements
are
in
addition
to
levels
already
required
under
existing
rules
(
e.
g.,
in
addition
to
the
2
log
removal
requirements
of
the
IESWTR
and
LT1ESWTR).
Source:
LT2ESWTR
Economic
Analysis
In
evaluating
binning
scenarios,
the
committee
asked
the
following
questions.

°
How
many
systems
will
be
required
to
add
treatment?

°
What
are
the
chances
that
systems
with
high
source
water
concentrations
will
not
be
captured
in
a
treatment
bin?

°
What
is
the
likelihood
of
misclassification?

°
Do
the
treatment
requirements
adequately
reduce
Cryptosporidium
concentrations
in
finished
water?

Based
on
estimated
impacts
of
the
binning
and
treatment
classifications,
EPA
selected
a
Preferred
Regulatory
Alternative
for
the
LT2ESWTR.
Alternative
A1
(
across­
the­
board
2
log
inactivation)
was
ICR
for
LT2ESWTR
Proposal
18
June
2003
eliminated
because
it
was
the
highest
cost
option
and
provided
few
benefits
to
populations
in
many
systems,
especially
in
systems
with
good
source
water
quality.
The
other
alternatives
(
A2
 
A4)
were
evaluated
based
on
several
factors,
including
predictions
of
costs
and
benefits,
implementability,
and
other
specific
impacts
(
e.
g.,
impacts
on
small
systems
or
sensitive
subpopulations).
Alternative
A3
was
chosen
by
EPA
as
the
Preferred
Regulatory
Alternative
because
it
provided
the
most
public
health
benefits
in
terms
of
avoided
illnesses
and
deaths
for
an
acceptable
cost.

The
M­
DBP
Advisory
Committee
also
considered
different
alternatives
to
Cryptosporidium
monitoring,
which
is
expensive,
especially
for
small
systems.
However,
based
on
evaluations
of
Information
Collection
Rule
and
Information
Collection
Rule
Supplemental
Survey
data,
surrogate
parameters
were
not
found
to
correlate
well
with
Cryptosporidium
concentrations.
The
committee
requested
that
large
systems
collect
E.
coli
and
turbidity
data
along
with
Cryptosporidium
data
in
order
to
determine
whether
E.
coli
or
turbidity
could
be
used
to
indicate
the
presence
of
Cryptosporidium.

The
committee
also
considered
several
alternative
monitoring
frequencies
for
Cryptosporidium.
The
concern
was
that
some
systems
could
mistakenly
be
classified
into
the
bin
that
did
not
require
additional
treatment,
or
vice
versa.
The
committee
decided
that
requiring
48
rather
than
24
samples
would
not
decrease
the
error
significantly
but
would
increase
the
burden.
Therefore,
it
chose
to
require
24
samples.

5d
Collection
Schedule
The
major
compliance
milestones
under
the
LT2ESWTR
include
source
water
monitoring,
bin
assignment,
installation
of
treatment
technologies,
and
reassessment
and
future
monitoring
for
bin
reclassfication.
The
LT2ESWTR
compliance
schedule,
which
differs
for
large/
medium
and
small
PWSs,
is
shown
in
Exhibit
4.
This
rule
is
expected
to
be
promulgated
in
July
2004.

A
detailed
schedule
for
the
LT2ESWTR
and
the
Stage
2
DBPR
is
presented
in
Appendix
C,
Exhibit
C.
3.
This
exhibit
includes
the
schedule
for
the
Stage
2
DBPR
as
well,
because
these
rules
will
be
promulgated
in
concert
to
address
the
need
to
balance
microbial
controls
with
concerns
over
increased
levels
of
DBPs.
PWSs
will
be
required
to
comply
with
the
rules
simultaneously.

Exhibit
4
Implementation
Milestones
for
the
LT2ESWTR
Large
and
Medium
PWSs
Small
PWSs
Rule
promulgation
July
2004
E.
coli
monitoring
Begin
6
months
after
promulgation
Begin
30
months
after
promulgation
Cryptosporidium
monitoring
Begin
6
months
after
promulgation
Begin
48
months
after
promulgation
Bin
determination
No
later
than
36
months
after
promulgation
No
later
than
60
months
after
promulgation
Treatment
installation
No
later
than
72
months
after
promulgation
No
later
than
102
months
after
promulgation
Assessment
for
bin
reclassification
108
months
after
promulgation
132
months
after
promulgation
Note:
Unfiltered
systems
are
not
required
to
conduct
E.
coli
monitoring.
Small
filtered
system
monitoring
for
Cryptosporidium
is
required
only
if
systems
exceed
trigger
levels
during
their
E.
coli
monitoring.
ICR
for
LT2ESWTR
Proposal
19
June
2003
6
Estimating
the
Burden
and
Cost
of
the
Collection
The
following
sections
discuss
costs
and
burden
for
monitoring,
recordkeeping,
and
reporting
requirements
for
the
LT2ESWTR
ICR.
Exhibits
A.
1
through
A.
5
in
Appendix
A
summarize
the
burden,
number
of
respondents,
number
of
responses,
and
costs
over
the
3­
year
ICR
clearance
period.
Annual
burden
and
cost
for
each
of
the
3
years
are
provided,
along
with
the
3­
year
total
and
annual
average.
Exhibits
B.
1
through
B.
15
in
Appendix
B
provide
detail
on
the
burden
and
cost
calculations
for
CWSs,
nontransient
noncommunity
water
systems
(
NTNCWSs),
and
transient
noncommunity
water
systems
(
TNCWSs)
of
all
sizes.
In
Appendix
C,
Exhibits
C.
1
and
C.
2
show
the
burden
and
cost
for
full
implementation
of
the
monitoring,
reporting,
and
recordkeeping
requirements.

6a
Estimating
Respondent
Burden
This
section
discusses
the
burden
faced
by
PWSs/
plants
and
States/
Primacy
Agencies.
Respondent
burden
is
defined
as
the
hours
required
to
complete
a
given
information
collection
or
recordkeeping
activity.
Respondent
activities
have
been
separated
into
rule
start­
up
and
monitoring.

During
the
clearance
period
covered
by
this
ICR,
system
personnel
will
become
familiar
with
and
be
trained
in
the
requirements
of
the
LT2ESWTR.
Medium
and
large
PWSs
will
monitor
their
source
water
for
E.
coli,
Cryptosporidium,
and
turbidity.
Small
filtered
systems
will
begin
E.
coli
monitoring
in
the
last
6
months
of
Year
3.
A
subset
of
these
small
systems
will
commence
Cryptosporidium
monitoring
in
Year
5
(
outside
of
the
clearance
period).
The
results
of
this
monitoring
will
be
used
to
determine
treatment
requirements
later
in
the
implementation
process.
Installation
of
new
treatment
technologies
to
meet
bin
requirements
would
occur
after
monitoring
and
bin
assignment
(
i.
e.,
outside
of
the
clearance
period).
A
second
round
of
monitoring
for
E.
coli
and
Cryptosporidium
will
take
place
in
Years
8
through
12.
The
compliance
schedule
for
the
LT2ESWTR
is
presented
in
Exhibit
C.
3.

Over
the
3
years
covered
by
this
ICR,
the
total
national
respondent
burden
to
PWSs
and
States/
Primacy
Agencies
is
estimated
at
437,563
labor
hours,
an
annual
average
of
145,854
hours
(
see
Exhibits
A.
1
and
A.
2).
The
next
two
sections
describe
the
burden
estimates
in
greater
detail.

6a(
i)
Burden
on
PWSs/
Plants
As
stated
above,
the
burden
to
PWSs
and
plants
associated
with
the
LT2ESWTR
during
the
clearance
period
will
be
for
rule
start­
up
activities;
monitoring
for
turbidity,
E.
coli,
and
Cryptosporidium;
and
reporting
of
these
monitoring
results.
Burden
associated
with
the
period
after
the
clearance
period
includes
reporting
to
demonstrate
compliance
with
new
technologies,
reporting
of
disinfection
benchmarks,
monitoring
for
bin
reclassification,
and
reporting
associated
with
requirements
for
uncovered
finished
water
reservoirs.

Rule
Start­
Up
The
burden
associated
with
rule
start­
up
includes
the
time
it
will
take
PWS
staff
to
read
and
become
familiar
with
the
rule
and
participate
in
training
activities.
It
also
includes
the
time
needed
to
prepare
and
submit
the
required
sampling
schedule
(
this
burden
is
assumed
to
be
negligible).
This
burden
will
be
incurred
by
all
small,
medium,
and
large
PWSs
subject
to
the
rule,
since
all
of
these
systems
will
have
to
implement
the
rule.
ICR
for
LT2ESWTR
Proposal
20
June
2003
All
large
and
medium
systems
will
begin
rule
start­
up
activities
in
Year
1.
Small
systems
will
start
these
activities
in
Year
3.

Columns
A
and
B
of
Exhibit
B.
2
present
the
burden
to
PWSs
associated
with
rule
start­
up
activities.
Burden
hours
per
system
range
from
8
to
9
hours;
estimates
will
vary
depending
on
system
size.

Since
States/
Primacy
Agencies
will
be
mainly
responsible
for
understanding
and
adopting
these
regulations
and
for
notifying
PWSs
of
specific
rule
requirements,
PWSs,
especially
small
ones,
are
assumed
to
bear
a
relatively
moderate
burden
associated
with
rule
start­
up.
EPA
estimates
that
the
burden
associated
with
reading
the
rule
is
4
hours
per
system
and
that
the
burden
associated
with
required
training
will
be
4
or
5
hours
per
system,
depending
on
system
size.

Monitoring
The
labor
burden
associated
with
monitoring
is
the
time
needed
to
take
a
sample
and
either
perform
the
required
analysis
or
ship
it
to
a
commercial
laboratory
for
analysis.
As
stated
above,
during
the
ICR
clearance
period,
medium
and
large
systems
will
perform
2
years
of
E.
coli
and/
or
Cryptosporidium
monitoring,
and
small
filtered
systems
will
conduct
the
first
6
months
of
E.
coli
monitoring.
Because
there
are
only
92
unfiltered
plants
out
of
a
total
of
7,565
plants
subject
to
monitoring
requirements,
EPA
did
not
calculate
the
monitoring
costs
for
unfiltered
systems
separately.

The
LT2ESWTR
also
requires
medium
and
large
filtered
systems
to
monitor
for
turbidity
once
per
month
for
24
months.
Given
that
systems
are
currently
required
to
monitor
turbidity,
the
incremental
turbidity
monitoring
burden
associated
with
the
LT2ESWTR
is
assumed
to
be
negligible.
The
paragraphs
below
describe
the
burden
associated
with
E.
coli
and
Cryptosporidium
monitoring.
As
noted
earlier,
the
burden
for
monitoring
was
calculated
on
a
per­
plant
basis,
rather
than
for
PWSs.

E.
coli
Monitoring
Exhibit
B.
4
presents
the
burden
associated
with
E.
coli
monitoring
for
bin
determination.
Under
the
LT2ESWTR,
medium
and
large
systems
are
required
to
take
one
sample
per
month
for
24
months,
a
total
of
24
E.
coli
samples.
(
Under
the
LT2ESWTR,
PWSs
have
the
option
of
taking
more
samples,
but
for
this
ICR,
they
are
assumed
to
take
the
minimum
number
of
samples.)

In
the
last
6
months
of
Year
3,
small
systems
will
begin
1
year
of
E.
coli
monitoring.
These
systems
will
take
26
biweekly
(
i.
e.,
every
14
days)
samples
between
Years
3
and
4
(
13
of
these
samples
will
be
taken
during
this
ICR
clearance
period).

The
burden
associated
with
taking
each
E.
coli
sample
is
15
minutes
(
0.25
hour);
see
Column
C
of
Exhibit
B.
4.
This
represents
the
time
needed
to
collect
a
sample
(
usually
less
than
1
liter)
and
prepare
it
for
shipping
to
a
commercial
laboratory
for
analysis,
if
needed.

For
systems
that
conduct
E.
coli
sample
analysis
in­
house,
the
analysis
burden
is
assumed
to
be
30
minutes
(
0.5
hours).
The
percentage
of
systems
analyzing
E.
coli
in­
house
varies
with
system
size.

Cryptosporidium
Monitoring
Exhibit
B.
5
presents
the
burden
associated
with
Cryptosporidium
monitoring
for
bin
determination.
All
systems
required
to
monitor
must
draw
at
least
26
Cryptosporidium
samples
at
each
plant.
This
includes
24
monthly
samples
over
2
years
for
large
and
medium
systems
and
two
matrix
spike
ICR
for
LT2ESWTR
Proposal
21
June
2003
samples
to
be
analyzed
over
the
course
of
the
monitoring
period.
Systems
may
monitor
more
frequently
than
monthly
but
are
assumed
to
do
the
minimum.

The
burden
associated
with
taking
each
Cryptosporidium
sample
is
30
minutes
(
0.5
hour);
see
Column
C
of
Exhibit
B.
5.
This
represents
the
time
needed
to
collect
a
10­
liter
sample
and
prepare
it
for
shipping
to
a
laboratory
(
it
is
assumed
that
the
laboratory
will
filter
the
sample).
This
estimate
is
based
on
the
requirements
of
EPA
Method
1623.

For
small
systems
required
to
monitor
for
Cryptosporidium,
twice­
monthly
monitoring
will
begin
at
the
beginning
of
Year
5
and
end
12
months
later,
in
Year
6
(
i.
e.,
outside
of
the
clearance
period
for
this
ICR).
The
Cryptosporidium
monitoring
burden
for
small
systems
is
shown
in
Exhibit
B.
5
for
reference.

Reporting
for
E.
coli
and
Cryptosporidium
Monitoring
As
the
laboratories
perform
analyses
for
medium
and
large
systems,
the
monitoring
data
will
be
entered
automatically
into
an
EPA
database;
however,
the
systems
will
still
review
the
data.
Small
systems
will
report
monitoring
results
to
their
Primacy
Agencies.
Results
for
all
system
sizes
must
be
reported
within
two
months
after
the
month
in
which
the
sample
was
taken.
The
total
reporting
burden
is
assumed
to
be
0.25
hours
per
sample
(
6
hours
total
for
medium
and
large
systems
and
6.5
hours
total
for
small
systems
over
the
monitoring
period).
This
burden
includes
recordkeeping
and
the
calculating
and
reporting
of
the
mean
Cryptosporidium
concentration
for
bin
classification.
Exhibit
B.
6
presents
this
burden
for
reference.

Demonstration
of
Compliance
with
New
Technologies
In
order
to
get
log
removal
credit
for
Cryptosporidium,
PWSs
will
be
required
to
demonstrate
that
they
are
complying
with
design
and
operational
criteria
for
any
new
toolbox
technologies
they
install.
For
some
technologies
the
demonstration
of
compliance
will
be
similar
to
that
required
for
existing
technologies,
and
no
additional
burden
will
be
incurred.
For
instance,
the
lower
finished
water
turbidity
toolbox
option
requires
monitoring
of
turbidity
of
the
effluent
from
each
filter.
Since
systems
are
already
required
to
do
the
same
monitoring
under
the
IESWTR
and
the
LT1ESWTR,
no
new
burden
is
assumed
for
these
systems.
Other
technologies
are
assumed
to
be
implemented
by
few
systems
(
based
on
technology
distributions
modeled
for
the
LT2ESWTR
Economic
Analysis);
therefore,
burden
for
demonstrating
compliance
for
these
technologies
is
negligible.
Few
systems,
for
example,
are
expected
to
implement
watershed
control
programs
for
log
removal
credit.

For
unfiltered
systems,
reporting
burden
is
predicted
to
be
incurred
only
by
systems
(
CWSs
only)
adding
UV
radiation
or
ozone
for
disinfection
(
in
addition
to
their
existing
disinfectants).
No
unfiltered
systems
are
expected
to
add
chlorine
dioxide
disinfection.
For
filtered
systems,
new
burden
is
predicted
to
be
incurred
only
by
systems
switching
to
UV,
microfiltration/
ultrafiltration,
and
bank
filtration.
The
reporting
and
recordkeeping
burden
for
each
plant
is
assumed
to
be
3
hours
per
month,
or
36
hours
per
year.
This
burden
will
be
ongoing
beginning
in
Year
7
once
new
technologies
are
installed
and
is
shown
in
Exhibits
B.
9
and
B.
10.

Disinfection
Benchmarking
All
PWSs
that
conduct
Cryptosporidium
monitoring
will
be
required
to
apply
for
approval
of
existing
inactivation
benchmarks,
to
calculate
a
benchmark
based
on
existing
profiling
data,
or
to
conduct
inactivation
profiling.
Small
PWSs
that
are
not
required
to
monitor
Cryptosporidium
may
be
required
to
conduct
inactivation
profiling
if
their
trihalomethane
or
haloacetic
acid
levels
exceed
certain
limits.
Most
ICR
for
LT2ESWTR
Proposal
22
June
2003
plants
will
already
have
existing
benchmarks
due
to
similar
requirements
under
the
IESWTR
and
LT1ESWTR.
If
they
do
not,
they
should
be
able
to
calculate
benchmarks
based
on
existing
operational
data
collected
as
part
of
the
SWTR
requirements.
Most
of
these
plants
need
to
maintain
these
data
onsite
but
do
not
need
to
report
them.
The
burden
for
profiling
and
calculating
benchmarks
is
assumed
to
be
negligible.
Plants
that
wish
to
make
a
major
change
to
their
disinfection
process
must
compile
and
submit
disinfection
profiles
and
benchmarks
to
their
States
and
consult
with
their
States
about
the
change.
The
burden
for
this
is
estimated
to
be
4
hours
per
plant
and
is
shown
in
Exhibit
B.
11.

Assessment
for
Bin
Reclassification
In
Years
8
through
12,
certain
systems
will
conduct
a
second
round
of
E.
coli
and
Cryptosporidium
monitoring.
Plants
that
do
not
have
5.5
log
treatment
in
place
before
monitoring
starts
will
be
required
to
monitor.
This
burden
and
cost
will
be
incurred
by
affected
systems
outside
of
the
ICR
clearance
period.
For
reference,
Exhibits
B.
11,
B.
12,
and
B.
13
present
the
burden
and
cost
associated
with
these
activities.

Uncovered
Finished
Water
Reservoirs
PWSs
with
uncovered
finished
water
reservoirs
are
required
either
to
cover
their
reservoirs,
to
treat
the
water
leaving
the
reservoirs
to
achieve
4
log
virus
inactivation,
or
to
submit
and
implement
an
approved
risk
mitigation
plan.
The
burden
for
this
requirement
will
be
incurred
outside
of
the
ICR
clearance
period.
Very
few
PWSs
have
uncovered
finished
water
reservoirs;
most
PWSs
are
expected
to
either
cover
them
or
treat
the
effluent,
incurring
no
additional
reporting
burden.
The
burden
for
preparing
a
risk
mitigation
plan
is
expected
to
be
negligible
since
very
few
plants
will
choose
to
implement
this
option.

6a(
ii)
Burden
on
States/
Primacy
Agencies
The
burden
to
State/
Primacy
Agency
staff
includes
the
time
required
to
perform
start­
up
activities.
States/
Primacy
Agencies
will
begin
start­
up
activities
in
Year
1
in
order
to
support
PWSs.
It
is
assumed
that
State
activities
will
parallel
system
activities.
Thus,
States
will
begin
start­
up
activities
associated
with
large/
medium
systems
in
Year
1,
as
these
systems
complete
rule
training,
and
will
conduct
the
bulk
of
their
start­
up
activities
in
Year
3,
as
small
systems
begin
LT2ESWTR
activities.

Exhibit
B.
3
presents
the
State/
Primacy
Agency
burden
associated
with
rule
start­
up
activities.
Start­
up
activities
that
will
occur
during
the
ICR
approval
period
include
regulation
adoption
and
program
development;
training
State/
Primacy
Agency
staff,
PWS
staff,
and
technical
assistants;
and
updating
data
management
systems.
EPA
estimates
that
each
State/
Primacy
Agency
will
devote
1.95
Full­
Time
Equivalents
(
FTEs),
or
4,056
hours
to
these
activities.
A
FTE
equals
2,080
hours,
assuming
that
full­
time
employees
are
paid
for
40
hours
a
week,
52
weeks
a
year.

Exhibit
B.
7
presents
the
State/
Primacy
Agency
burden
associated
with
bin
determination.
Each
State/
Primacy
Agency
will
devote
1.5
FTEs,
or
3,120
hours,
to
these
activities.
(
Much
of
this
burden
will
be
incurred
outside
of
the
ICR
clearance
period.)

States/
Primacy
Agencies
will
not
yet
have
primacy
when
medium
and
large
systems
begin
monitoring.
EPA
will
manage
the
first
2
years
of
medium
and
large
system
monitoring;
thus,
no
State
burden
is
associated
with
PWS
reporting
and
bin
classification
during
this
information
collection
period.
EPA
will
provide
data
to
States
and
will
help
determine
if
Cryptosporidium
data
previously
collected
exempts
systems
from
further
monitoring
requirements.
States
will
be
responsible
for
administering
removal
credits
based
on
bin
assignments
(
the
burden
for
bin
assignment
itself
is
assumed
to
be
negligible).
ICR
for
LT2ESWTR
Proposal
23
June
2003
States
will
incur
a
burden
for
managing
monitoring
results
and
bin
assignments
for
small
systems
during
the
last
6
months
of
the
ICR
clearance
period.

Exhibit
B.
8
shows
the
total
State/
Primacy
Agency
burden
associated
with
reviewing
reports
demonstrating
compliance
with
operational
and
design
criteria
for
new
technologies.
The
burden
for
reviewing
each
plant's
report
is
estimated
to
be
0.5
hours
per
month,
or
6
hours
per
year.
(
This
burden
will
be
incurred
outside
of
the
ICR
clearance
period
starting
in
Year
7).

6b
Estimating
Respondent
Cost
This
section
presents
the
costs
that
are
expected
to
be
incurred
by
PWSs
and
States/
Primacy
Agencies
as
a
result
of
the
LT2ESWTR.
For
the
ICR
clearance
period,
the
total
national
respondent
cost
is
estimated
at
$
41.0
million
over
the
3
years,
with
an
annual
national
average
of
$
13.7
million
(
see
Exhibit
A.
5).
Of
this,
$
11.6
million
is
labor
costs,
and
$
29.4
million
is
operating
and
maintenance
(
O&
M)
costs
(
i.
e.,
E.
coli
and
Cryptosporidium
fee­
for­
service
analysis
costs).

6b(
i)
Cost
to
PWSs/
Plants
The
costs
to
PWSs
and
plants
associated
with
the
LT2ESWTR
include
the
cost
of
the
labor
described
in
Section
6a
and
E.
coli
and
Cryptosporidium
sample
analysis
costs.
EPA
estimates
that
PWSs
and
plants
will
not
incur
any
capital
costs
during
start­
up,
data
collection,
or
data
reporting.
Systems
are
expected
to
already
have
on
hand
any
necessary
equipment
for
monitoring
and
for
reporting
monitoring
results
(
for
the
E.
coli,
Cryptosporidium,
and
turbidity
monitoring),
as
part
of
normal
operations
and
to
comply
with
existing
or
previous
rule
requirements.
Any
capital
costs
for
monitoring
equipment
needed
to
ensure
compliance
with
new
technologies
are
built
into
the
estimated
capital
costs
for
the
technologies.
These
costs
need
not
be
addressed
in
the
ICR
because
they
are
not
incurred
specifically
for
monitoring
but
for
ensuring
proper
operation
of
the
technologies.
The
capital
costs
for
installation
of
new
technologies
required
as
a
result
of
monitoring
done
for
bin
classification
are
provided
in
detail
in
the
economic
analysis
for
the
LT2ESWTR.

Labor
costs
for
each
information
collection
activity
were
calculated
by
multiplying
the
burden
estimates
presented
in
Section
6a
by
the
appropriate
hourly
labor
rate
adjusted
to
include
benefits.
For
technical
labor,
the
year
2000
mean
hourly
wage
rate
of
$
15.60
for
Standard
Occupational
Classification
(
SOC)
51­
8031,
"
Water
and
Liquid
Waste
Treatment
Plant
and
System
Operators,"
is
For
managerial
labor,
the
year
2000
mean
hourly
wage
rate
of
$
28.07
for
SOC
17­
2051,
"
Civil
Engineers,"
is
To
account
for
the
cost
of
fringe
benefits,
to
each
of
the
Bureau
of
Labor
Statistics
(
BLS)
rates,
resulting
in
a
technical
rate
of
$
24.96
per
hour
and
a
managerial
rate
of
$
44.91
per
hour.

For
implementation
and
reporting
burden,
EPA
assumes
an
80
percent/
20
percent
split
between
technical
and
managerial
labor
rates,
resulting
in
a
labor
rate
of
$
28.95
per
hour,
with
the
exception
of
systems
serving
fewer
than
500
people,
for
which
all
labor
is
assumed
to
be
technical
labor.
For
sample
collection,
all
labor
is
assumed
to
be
performed
at
the
technical
rate.
Labor
costs
for
activities
within
the
clearance
period
are
presented
in
Column
F
of
Exhibit
B.
2
(
for
rule
start­
up),
Column
E
of
Exhibits
B.
4
and
B.
5
(
for
monitoring),
and
Column
D
of
Exhibit
B.
6
(
for
reporting
results
of
monitoring).
Only
a
portion
of
these
costs
are
incurred
during
the
ICR
clearance
period.
1
Kevin
Connell.
Dyncorp,
Inc.
2002.
E­
mail
to
Curtis
Haymore
at
The
Cadmus
Group,
Inc.,
May
22,
2002.

ICR
for
LT2ESWTR
Proposal
24
June
2003
In
addition
to
labor
costs,
systems
will
incur
laboratory
costs
for
analysis
of
E.
coli
and
Cryptosporidium
samples.
EPA
estimates
no
incremental
costs
associated
with
required
turbidity
monitoring.

E.
coli
Monitoring
Costs
E.
coli
analysis
costs
vary
depending
on
whether
the
analysis
is
performed
by
the
utility
or
shipped
to
a
commercial
laboratory
for
analysis.
EPA
estimates
a
cost
of
$
70
per
sample
for
commercial
laboratory
analysis
($
35
for
analysis
and
$
35
for
standard
overnight
shipping)
1
and
$
8.52
plus
the
cost
of
half
an
hour
of
technical
labor
($
12.48)
per
sample
for
in­
house
analysis.

EPA
assumes
that
all
large
systems
and
lesser
percentages
of
small
and
medium
systems
will
have
E.
coli
analytical
equipment.
The
percentage
of
systems
conducting
their
own
analyses
for
E.
coli
is
shown
in
Exhibit
B.
4.

Cryptosporidium
Monitoring
Costs
EPA
assumes
the
total
cost
to
each
system
for
Cryptosporidium
sample
analysis
is
$
529.50
(
see
Column
F
of
Exhibit
B.
5).
This
cost
figure
includes
the
cost
of
analysis,
shipping,
and
additional
processing,
as
described
below,
and
assumes
no
in­
house
analysis.

Based
on
commercial
laboratory
estimates
for
Cryptosporidium
analysis
using
EPA
Method
1623,
the
cost
of
each
monthly
sample
taken
during
the
2­
year
monitoring
period
is
$
403.
An
additional
$
88.70
is
estimated
for
shipping
samples
to
a
laboratory
for
analysis.
Because
Cryptosporidium
samples
must
be
shipped
overnight
to
meet
24­
hour
holding
time
requirements,
priority
overnight
shipping
is
assumed.
EPA's
estimate
is
based
on
Federal
Express
priority
overnight
rates
to
ship
a
10­
liter
(
22­
pound)
sample,
based
on
the
median
cost
for
all
shipping
zones.

Another
$
37.80
is
added
to
the
analysis
costs
to
account
for
additional
sample
processing.
Samples
generating
a
pellet
volume
of
greater
than
0.5
milliliters
require
multiple
sub­
sample
processing,
at
an
average
cost
of
$
140
each.
In
the
Information
Collection
Rule
Supplemental
Survey
conducted
by
EPA
to
collect
data
on
pathogen
occurrence,
approximately
27
percent
of
field
samples
required
analysis
of
multiple
sub­
samples.
Assuming
that
similar
percentages
of
LT2ESWTR
samples
would
require
multiple
sample
analysis,
an
additional
charge
of
$
37.80
($
140
×
0.27)
is
applied
to
all
samples.

6b(
ii)
Cost
to
States/
Primacy
Agencies
Costs
to
States/
Primacy
Agencies
for
rule
start­
up
activities
are
estimated
in
Column
D
of
Exhibit
B.
3.
State/
Primacy
Agency
start­
up
costs
are
expected
to
be
higher
than
for
PWSs.
Labor
costs
attributable
to
States
or
other
Primacy
Agencies
are
estimated
based
on
an
average
annual
FTE
labor
cost,
including
fringe
benefits,
of
$
55,000
(
in
1997
dollars).
This
rate
was
established
based
on
State
input
during
the
development
of
the
State
Workload
Model
in
1997.
This
The
cost
per
State/
Primacy
Agency
is
then
multiplied
by
57
(
the
number
of
States/
Primacy
Agencies,
including
Territories
and
Tribes)
to
arrive
at
a
total
cost
estimate
for
start­
up
activities.
The
Territories
include
Guam,
American
Samoa,
the
Trust
Territories,
the
Northern
Mariana
ICR
for
LT2ESWTR
Proposal
25
June
2003
Islands,
Puerto
Rico,
and
the
Virgin
Islands.
They
(
along
with
the
State
of
Wyoming
and
the
District
of
Columbia)
do
not
have
primacy
but
are
included
here
because
EPA
acts
as
the
Primacy
Agency
for
them.
The
Navajo
Nation
is
the
only
Tribe
with
primacy.

Only
labor
costs
are
incurred
by
States/
Primacy
Agencies.
The
breakdown
of
activities
for
startup
is
described
in
Exhibit
B.
3.
Costs
incurred
for
reviewing
small
systems'
monitoring
results
during
the
first
round
of
monitoring
are
shown
in
the
first
table
in
Exhibit
B.
7.
(
States
will
not
review
these
data
for
large
and
medium
systems
since
they
will
not
yet
have
primacy;
EPA
will
do
so.)
Only
part
of
the
burden
in
Exhibits
B.
3
and
B.
7
is
incurred
during
the
ICR
clearance
period
since
small
systems
will
not
start
monitoring
until
30
months
after
promulgation.
The
second
table
in
Exhibit
B.
7
shows
the
State
burden
for
reviewing
monitoring
results
during
bin
reclassification.

The
burden
for
reviewing
plants'
demonstrations
of
compliance
with
newly
installed
technologies
(
0.5
hours
per
plant
per
month,
or
6
hours
per
year)
is
shown
in
Exhibit
B.
8.
This
burden
is
incurred
outside
of
the
ICR
clearance
period.

The
burden
for
reviewing
disinfection
benchmarks
and
plants'
requests
to
change
disinfection
processes
(
2
hours
per
plant)
is
shown
in
Exhibit
B.
12.
This
burden
will
be
incurred
outside
of
the
ICR
period
because
plants
are
not
required
to
comply
with
new
treatment
techniques
until
at
least
6
years
after
rule
promulgation.

6c
Agency
Burden
and
Cost
EPA's
costs
include
those
incurred
by
both
regional
offices
and
headquarters
to
process,
analyze,
and
maintain
SDWIS.
These
costs
cannot
be
broken
down
in
detail
by
each
drinking
water
rule
but
are
presented
as
an
overall
program
cost
in
the
Public
Water
System
Supervision
(
PWSS)
Program
ICR.
Headquarters
personnel
who
design
and
administer
SDWIS
believe
that
the
net
additional
cost
of
the
new
LT2ESWTR
requirements
is
not
significantly
greater
than
that
already
accounted
for
under
the
PWSS
Program
ICR.

EPA
has
primacy
for
small
PWSs
on
Tribal
lands,
the
State
of
Wyoming,
the
District
of
Columbia,
and
the
Territories
mentioned
previously.
For
these
systems,
EPA
will
incur
costs
and
burdens
similar
to
those
incurred
by
States
with
primacy.
Since
these
PWSs
are
potential
respondents
to
the
rule,
the
associated
start­
up
costs
and
burden
that
EPA
will
incur
have
been
included
as
part
of
the
State
costs
and
burdens.
If
Wyoming
is
granted
primacy
again,
it
will
assume
the
burden
of
rule
start­
up
from
the
Agency.
Given
this
possibility,
and
the
difficulty
of
distinguishing
small
PWSs
on
Tribal
lands
from
systems
that
are
not
on
Tribal
lands,
this
analysis
does
not
attempt
to
distinguish
between
the
start­
up
burden
and
costs
incurred
by
States
and
the
small
portion
that
will
be
incurred
by
EPA
(
i.
e.,
the
estimated
EPA
burden
and
costs
incurred
under
the
LT2ESWTR
have
been
included
in
the
State
burden
and
cost
estimates
presented
above).

6d
Estimating
the
Respondent
Universe
and
Total
Burden
and
Cost
6d(
i)
PWSs
All
nonpurchasing
surface
water
and
GWUDI
PWSs
are
subject
to
the
LT2ESWTR
requirements.
A
total
of
7,066
surface
water
and
GWUDI
PWSs
will
submit
information
to
fulfill
LT2ESWTR
requirements
(
see
Exhibit
B.
1).
2
Systems
that
expect
to
achieve
a
total
of
5.5
log
removal
will
not
be
required
to
perform
source
water
monitoring
under
the
LT2ESWTR.

ICR
for
LT2ESWTR
Proposal
26
June
2003
All
types
and
sizes
of
systems
subject
to
the
LT2ESWTR,
a
total
of
7,066
systems,
will
perform
rule
start­
up
activities,
(
see
Exhibit
B.
2,
Column
E).
Medium
and
large
systems
will
monitor
for
E.
coli
and
Cryptosporidium
beginning
6
months
after
the
rule
is
promulgated.
Small
systems
will
begin
to
conduct
E.
coli
sampling
and
analysis
in
the
last
6
months
of
Year
3.

Systems
that
purchase
water
from
other
systems
and
systems
meeting
treatment
criteria2
will
not
be
required
to
monitor
for
E.
coli
and
Cryptosporidium.
EPA
assumes
that
E.
coli
monitoring
will
be
conducted
at
7,565
plants
(
see
Column
A
of
Exhibit
B.
4).
All
medium
and
large
systems
and
those
small
systems
with
E.
coli
levels
high
enough
to
trigger
Cryptosporidium
monitoring
requirements
will
be
required
to
monitor
for
Cryptosporidium
(
EPA
estimates
that
35
percent
of
small
systems
monitoring
for
E.
coli
will
exceed
trigger
levels).
The
estimated
total
number
of
plants
conducting
Cryptosporidium
monitoring
is
3,789
(
see
Column
A
of
Exhibit
B.
5);
however,
only
1,774
plants
will
conduct
Cryptosporidium
monitoring
during
the
clearance
period.
No
small
system
Cryptosporidium
sampling
will
occur
under
the
LT2ESWTR
during
the
ICR
clearance
period.

In
determining
the
number
of
plants
performing
monitoring,
and
therefore
the
number
of
respondents,
EPA
assumes
that
the
ratio
of
plants
per
system
varies
from
1.0
to
2.8
depending
on
the
populations
served
by
the
system
(
see
the
Economic
Analysis
for
the
LT2ESWTR
for
further
explanation
of
the
ratio).
These
ratios
are
shown
in
Exhibit
B.
1.
EPA
also
subtracts
the
number
of
plants
estimated
to
already
have
5.5
log
Cryptosporidium
removal
treatment
in
place.

6d(
ii)
States/
Primacy
Agencies
Fifty­
seven
States
and
Territories
(
or
Primacy
Agencies)
are
respondents
under
this
information
collection.

Total
Burden
and
Cost
Total
annual
burden
is
calculated
as
the
hours
per
response
times
the
number
of
responses.
The
total
annual
cost
for
each
activity
is
the
sum
of
labor
costs
and
O&
M
costs
(
in
this
case,
lab
costs)
per
response
times
the
number
of
responses.
These
are
presented
in
the
far
right
columns
of
each
exhibit.
The
total
annual
burden
for
all
system
types
is
summarized
in
Exhibit
A.
2;
the
total
annual
cost
is
summarized
in
Exhibit
A.
5.

6e
Bottom
Line
Burden
Hours
and
Costs
6e(
i)
Respondent
Tally
The
total
burden
associated
with
LT2ESWTR
requirements
over
the
3
years
covered
by
this
information
collection
is
437,563
hours,
an
average
of
145,854
hours
per
year.
Of
this,
155,983
hours
(
an
average
of
51,994
hours
per
year)
will
be
incurred
by
PWSs
and
281,580
hours
(
an
average
of
93,860
hours
per
year)
will
be
incurred
by
States.
See
Exhibit
A.
2
for
more
detailed
burden
information.

The
total
cost
over
the
3
years
covered
by
this
information
collection
is
$
41.0
million,
an
average
of
$
13.7
million
per
year.
Of
this,
$
32.8
million
(
an
average
of
$
10.9
million
per
year)
will
be
incurred
by
ICR
for
LT2ESWTR
Proposal
27
June
2003
PWSsC$
3.4
million
is
the
cost
of
labor,
and
$
29.4
million
is
O&
M
costs.
There
are
no
capital
costs
associated
this
ICR.
Over
the
3­
year
clearance
period,
$
8.1
million
(
an
average
of
$
2.7
million
per
year)
will
be
incurred
by
StatesCall
of
which
is
labor
cost.
See
Exhibit
A.
5
for
detailed
cost
information.

The
total
number
of
respondents
over
the
3
years
covered
by
this
information
collection
is
7,622,
an
average
of
2,560
respondents
per
year.
Of
this,
7,565
respondents
are
PWSs
(
an
average
of
2,522
respondents
per
year),
and
57
are
States
and
Territories
(
an
average
of
38
per
year).
Total
numbers
of
respondents
are
calculated
using
the
maximum
number
of
respondents
in
a
year;
this
avoids
double
counting
of
respondents
that
complete
more
than
one
activity
in
a
year
or
whose
activities
span
multiple
years.
To
calculate
the
annual
average
number
of
respondents
for
PWSs,
EPA
divided
the
total
number
of
respondents
by
3.
To
calculate
the
annual
average
number
of
respondents
for
States
and
Territories,
EPA
added
the
number
of
State/
Territory
respondents
for
each
response
for
each
year
and
divided
by
3.
This
was
done
to
account
for
the
fact
that
State
and
Territory
respondents
will
not
conduct
activities
during
every
year
of
the
information
collection
period.
EPA
then
took
the
maximum
number
of
annual
respondents
for
the
two
responses.
See
Exhibit
A.
3
for
more
detailed
respondent
information.

The
total
number
of
responses
for
the
information
collection
approval
period
is
296,713,
an
average
of
98,904
responses
per
year.
PWSs
accounted
for
295,972
responses,
or
98,657
responses
per
year.
States
and
Territories
had
741
responses,
or
247
responses
per
year.
See
Exhibit
A.
4
for
more
information
about
the
number
of
respondents.

Exhibit
A.
1
shows
the
total
burden
and
cost
per
respondent
for
the
information
collection
period.
The
total
burden
per
respondent
is
57.4
hours.
The
burden
per
respondent
for
PWSs
is
20.6
hours
and
for
States
and
Territories
is
4,940
hours.
The
total
cost
per
respondent
is
$
5,376.
The
cost
per
respondent
for
PWSs
is
$
4,342
and
for
States
and
Territories
is
$
142,717.

Exhibit
5
shows
the
annual
average
burden
per
respondent,
burden
per
response,
and
number
of
responses
per
respondent.
The
total
annual
average
burden
per
respondent
is
57.0
hours.
The
total
annual
average
burden
per
response
is
1.5
hours.
The
annual
average
number
of
responses
per
respondent
is
38.6.
ICR
for
LT2ESWTR
Proposal
28
June
2003
Exhibit
5
3­
Year
Annual
Average
Burden,
Respondents,
and
Responses
Annual
Burden
(
hours)
Annual
Respondents
Annual
Burden/
Respondent
Annual
Responses
Annual
Burden/
Response
Annual
Responses/
Respondent
Annualized
Capital
Costs
Annual
O&
M
Costs
PWSs
51,994
2,522
20.6
98,657
0.5
39.1
$
0
$
9,805,020
States
and
Territories
93,860
38
2,470
247
380
6.5
$
0
$
0
Total
145,854
2,560
57.0
98,904
1.5
38.6
$
0
$
9,805,020
Source:
Data
from
Exhibit
A.
1.
ICR
for
LT2ESWTR
Proposal
29
June
2003
6e(
ii)
Variations
in
the
Annual
Bottom
Line
As
Exhibits
A.
2
and
A.
5
show,
the
burden
and
cost
to
both
PWSs
and
States/
Primacy
Agencies
varies
throughout
the
information
collection.
This
is
due
to
the
schedule
for
beginning
start­
up
and
monitoring
requirements:

$
EPA
anticipates
that
large
and
medium
systems
will
complete
their
rule
start­
up
activities
in
Year
1.
No
rule
start­
up
activities
will
take
place
in
Year
2.
Small
systems
will
initiate
these
activities
in
Year
3;
however,
only
half
of
the
start­
up
burden
and
cost
to
small
systems
will
be
incurred
during
the
clearance
period,
as
they
will
complete
rule
training
in
Year
4.
State
startup
activities,
burden,
and
costs
will
mirror
this
schedule.

$
Source
water
monitoring
by
medium
and
large
systems
will
not
commence
until
6
months
after
the
rule
is
promulgated
and
will
conclude
6
months
before
the
end
of
the
ICR
clearance
period.
E.
coli
and
Cryptosporidium
analysis
costs
constitute
a
significant
portion
of
the
costs
to
PWSs/
plants.

$
Small
systems
will
not
begin
source
water
monitoring
for
E.
coli
until
Year
3.
While
this
monitoring
will
only
occur
in
the
last
6
months
of
the
collection,
the
high
number
of
small
systems
performing
monitoring
contributes
greatly
to
the
burden
and
cost
in
Year
3.

6f
Reasons
for
Change
in
Burden
The
LT2ESWTR
is
a
new
regulation.
As
stated
above,
water
systems
and
State
Primacy
Agencies
will
incur
437,563
hours
of
labor
and
spend
approximately
$
41.0
million
to
implement
the
LT2ESWTR
over
the
3­
year
ICR
clearance
period.
The
burden
and
costs
are
offset
by
the
benefits
of
the
LT2ESWTR
in
terms
of
the
reduction
in
risk
of
adverse
health
effects,
specifically
morbidity
and
mortality
resulting
from
a
cryptosporidiosis
infection.
These
benefits
are
described
in
detail
in
Chapter
5
of
the
Economic
Analysis.

6g
Burden
Statement
The
burden
per
respondent
for
this
ICR
is
estimated
to
be
57.4
hours;
the
cost
of
this
information
collection
is
estimated
to
average
$
5,376
per
respondent.
The
burden
per
respondent
to
PWSs
is
estimated
to
be
20.6
hours;
the
cost
of
this
information
collection
is
estimated
to
average
$
4,342
per
PWS
respondent.
This
includes
the
time
for
becoming
familiar
with
the
rule,
monitoring,
reporting,
and
recordkeeping.
For
State
Primacy
Agencies,
the
burden
per
respondent
is
4,940
hours;
the
cost
per
respondent
is
estimated
to
average
$
142,717.
This
includes
the
time
needed
to
become
familiar
with
the
rule,
train
staff
and
PWSs,
and
maintain
data
management
systems.
See
Exhibit
A.
1
for
burden
and
cost
breakdowns.

Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
disclose,
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
the
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and,
transmit
or
otherwise
disclose
the
ICR
for
LT2ESWTR
Proposal
30
June
2003
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
9
and
48
CFR
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
OW­
2002­
0039,
which
is
available
for
public
viewing
at
the
Water
Docket
in
the
EPA
Docket
Center,
(
EPA/
DC)
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Water
Docket
is
(
202)
566­
2426.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
N.
W.,
Washington,
DC
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
and
OMB
control
number
in
any
correspondence.
ICR
for
LT2ESWTR
Proposal
31
June
2003
Appendix
A
Summary
Exhibits
for
the
ICR
Approval
Period
Exhibit
A.
1:
Burden,
Respondents,
Responses,
and
Costs
for
the
ICR
Approval
Period
Exhibit
A.
2:
Burden
for
the
ICR
Approval
Period
(
Hours)
Exhibit
A.
3:
Respondents
for
the
ICR
Approval
Period
Exhibit
A.
4:
Responses
for
the
ICR
Approval
Period
Exhibit
A.
5:
Cost
for
the
ICR
Approval
Period
ICR
for
LT2ESWTR
Proposal
32
June
2003
Year
1
Year
2
Year
3
Source
July­
03
July­
04
July­
05
Annual
(
Exhibit)
June­
04
June­
05
June­
06
Total
Average
PWSs
Burden
(
hours)
A.
2
26,831
30,698
98,455
155,983
51,994
Respondents
(
number)
A.
3
1,774
1,774
7,565
7,565
2,522
Responses
(
number)
A.
4
35,581
65,628
194,764
295,972
98,657
Costs
(
dollars)
A.
5
6,945,175
$
13,225,542
$
12,675,356
$
32,846,073
$
10,948,691
$
Labor
619,720
$
574,631
$
2,236,663
$
3,431,013
$
1,143,671
$
O&
M
6,325,455
$
12,650,911
$
10,438,694
$
29,415,060
$
9,805,020
$
Capital
­
$
­
$
­
$
­
$
­
$

Burden
per
respondent
20.6
Cost
per
respondent
4,342
$
States
Burden
(
hours)
A.
2
45,267
­
236,313
281,580
93,860
Respondents
(
number)
A.
3
57
­
57
57
38
Responses
(
number)
A.
4
285
­
456
741
247
Costs
(
dollars)
A.
5
1,307,768
$
­
$
6,827,079
$
8,134,846
$
2,711,615
$
Labor
1,307,768
$
­
$
6,827,079
$
8,134,846
$
2,711,615
$
O
&
M
­
$
­
$
­
$
­
$
­
$
Capital
­
$
­
$
­
$
­
$
­
$

Burden
per
respondent
4,940.0
Cost
per
respondent
142,717
$
Total
­
PWS
and
States
Burden
(
hours)
A.
2
72,098
30,698
334,767
437,563
145,854
Respondents
(
number)
A.
3
1,831
1,774
7,622
7,622
2,560
Responses
(
number)
A.
4
35,866
65,628
195,220
296,713
98,904
Cost
(
dollars)
A.
5
8,252,943
$
13,225,542
$
19,502,435
$
40,980,919
$
13,660,306
$
Labor
1,927,487
$
574,631
$
9,063,741
$
11,565,860
$
3,855,287
$
O
&
M
6,325,455
$
12,650,911
$
10,438,694
$
29,415,060
$
9,805,020
$
Capital
­
$
­
$
­
$
­
$
­
$

Burden
per
respondent
57.4
Cost
per
respondent
5,376
$
Note:
Detail
may
not
add
to
total
due
to
independent
rounding.
Exhibit
A.
1
Summary
of
Burden,
Respondents,
Responses,
and
Costs
for
the
ICR
Approval
Period
The
number
of
respondents
is
not
added;
rather
the
maximum
number
of
respondents
for
the
3
years
for
a
given
activity
is
used
to
avoid
double­
counting.
ICR
for
LT2ESWTR
Proposal
33
June
2003
Exhibit
A.
2
Burden
for
the
ICR
Approval
Period
(
Hours)

Year
1
Year
2
Year
3
Source
July­
03
July­
04
July­
05
Annual
(
Exhibit)
June­
04
June­
05
June­
06
Total
Average
PWSs
Start­
up
[
1]
B.
2
11,482
­
45,459
56,941
18,980
Assessment
for
binning
[
2]
E.
coli
Monitoring
B.
4
6,924
13,847
35,158
55,930
18,643
Cryptosporidium
Monitoring
B.
5
5,765
11,529
5,765
23,058
7,686
Reporting
B.
6
2,661
5,321
12,072
20,054
6,685
PWSs
­
Total
26,831
30,698
98,455
155,983
51,994
States
and
Territories
Start­
up
[
3]
B.
3
45,267
­
185,925
231,192
77,064
Reporting
and
bin
determination
B.
7
­
­
50,388
50,388
16,796
States
and
Territories
­
Total
45,267
­
236,313
281,580
93,860
Total
72,098
30,698
334,767
437,563
145,854
Note:
Detail
may
not
add
to
total
due
to
independent
rounding.
Sources
See
Exhibit
C.
1
for
breakdown
of
burden
by
year
and
system
type.
(
1)
All
medium
and
large
PWS
start­
up
burden
will
be
incurred
in
Year
1.
Small
PWS
start­
up
burden
will
be
incurred
in
Year
3.
(
2)
1/
4
of
E.
coli
and
Cryptosporidium
monitoring
by
medium
and
large
systems
will
take
place
in
Year
1.
1/
2
of
E.
coli
and
Cryptosporidium
monitoring
by
medium
and
large
systems
will
take
place
in
Year
2.
1/
4
of
E.
coli
and
Cryptosporidium
monitoring
by
medium/
large
systems
and
1/
2
of
E.
coli
monitoring
by
small
systems
will
take
place
in
Year
3.
(
3)
State
rule
start­
up
activities
will
parallel
system
activities.
Thus,
20
percent
(
the
relative
proportion
of
systems
that
are
large/
medium­
sized)
of
this
work
will
be
done
in
Year
1,
as
these
systems
perform
rule
training,
and
the
remaining
80
percent
will
be
done
in
Year
3.
ICR
for
LT2ESWTR
Proposal
34
June
2003
Exhibit
A.
3
Respondents
for
the
ICR
Approval
Period
Year
1
Year
2
Year
3
Source
July­
03
July­
04
July­
05
Annual
(
Exhibit)
June­
04
June­
05
June­
06
Total
[
7]
Average
PWSs
Start­
up
[
1,2]
B.
2
1,384
­
5,682
7,066
2,355
Assessment
for
binning
[
3,
4]
E.
coli
Monitoring
B.
4
1,774
1,774
7,565
7,565
2,522
Cryptosporidium
Monitoring
B.
5
1,774
1,774
1,774
1,774
591
Reporting
11
1,774
1,774
7,565
7,565
2,522
PWSs
­
Total
1,774
1,774
7,565
7,565
2,522
States
and
Territories
Start­
up
[
5]
B.
3
57
­
57
57
38
Reporting
and
bin
determination
[
6]
B.
7
­
­
57
57
19
States
and
Territories
­
Total
57
­
57
57
38
Total
1,831
1,774
7,622
7,622
2,560
Note:
Detail
may
not
add
to
total
due
to
independent
rounding.

Sources
(
1)
Each
PWS
is
assumed
to
be
a
respondent.

(
3)
Each
plant
is
assumed
to
be
a
respondent.

(
5)
Each
State
is
assumed
to
be
a
respondent
for
s
tart­
up
in
Years
1
and
3.
(
6)
Each
State
will
be
a
respondent
associated
with
reviewing
small
system
monitoring
data
in
Year
3.

(
7)
To
avoid
double­
counting
the
num
ber
of
respondents
for
asses
sment
for
binning
and
for
State
activities,
the
highest
number
of
respondents
for
an
activity
for
each
year
is
used
for
the
total
num
ber
of
respondents.
(
4)
For
E.
coli
and
Cryptosporidium
monitoring,
all
m
edium
and
large
plants
required
to
monitor
will
be
respondents
in
Years
1
and
2.
For
E.
coli
and
Cryptosporidium
monitoring,
all
small,
medium,
and
large
plants
required
to
m
onitor
will
be
respondents
in
Year
3.
(
2)
All
medium/
large
PWSs
will
perform
s
tart­
up
activities
in
Year
1.
All
small
PWSs
will
perform
s
tart­
up
activities
in
Year
3.
ICR
for
LT2ESWTR
Proposal
35
June
2003
Exhibit
A.
4
Responses
for
the
ICR
Approval
Period
Year
1
Year
2
Year
3
Source
July­
03
July­
04
July­
05
Annual
(
Exhibit)
June­
04
June­
05
June­
06
Total
Average
PWSs
Start­
up
[
1,2]
B.
2
2,767
­
11,365
14,132
4,711
Assessment
for
binning
[
3,
4]
E.
coli
Monitoring
B.
4
10,642
21,285
85,935
117,862
39,287
Cryptosporidium
Monitoring
B.
5
11,529
23,058
11,529
46,117
15,372
Reporting
B.
6
10,642
21,285
85,935
117,862
39,287
PWSs
­
Total
35,581
65,628
194,764
295,972
98,657
States
and
Territories
Start­
up
[
4]
B.
3
285
­
285
570
190
Reporting
and
bin
determination
[
5]
B.
7
­
­
171
171
57
States
and
Territories
­
Total
285
­
456
741
247
Total
35,866
65,628
195,220
296,713
98,904
Note:
Detail
may
not
add
to
total
due
to
independent
rounding.

Sources
(
1)
Each
PWS
will
have
2
responses
(
reading
and
training)
for
start­
up
activities.

(
3)
For
monitoring,
each
sample
taken
is
considered
to
be
a
response.
(
4)
Each
State
will
have
4
responses
for
start­
up
activities
(
see
Exhibit
B.
3).
(
5)
Each
State
will
have
3
responses
associated
with
binning
and
reviewing
monitoring
data
in
Year
3
(
see
Exhibit
B.
7).
(
2)
All
medium/
large
PWSs
will
perform
start­
up
activities
in
Year
1.
All
small
PWSs
will
perform
start­
up
activities
in
Year
3.
ICR
for
LT2ESWTR
Proposal
36
June
2003
Exhibit
A.
5
Cost
for
the
ICR
Approval
Period
Year
1
Year
2
Year
3
Total
Source
July­
03
to
June­
04
July­
04
to
June­
05
July­
05
to
June­
06
July­
03
to
June­
06
Annual
(
Exhibit)
Labor
O&
M
Capital
Labor
O&
M
Capital
Labor
O&
M
Capital
Labor
O&
M
Capital
Total
Average
PWSs
Start­
up
[
1]
B.
2
332,404
$
­

$
­

$
­

$
­

$
­

$
1,225,515
$
­

$
­

$
1,557,919
$
­

$
­

$
1,557,919
$
519,306
$

E.
coli
Monitoring
B.
4
66,408
$
220,763
$
­

$
132,816
$
441,526
$
­

$
536,234
$
4,334,001
$
­

$
735,458
$
4,996,290
$
­

$
5,731,748
$
1,910,583
$

Cryptosporidium
Monitoring
B.
5
143,884
$
6,104,692
$
­

$
287,768
$
12,209,385
$
­

$
143,884
$
6,104,692
$
­

$
575,536
$
24,418,770
$
­

$
24,994,306
$
8,331,435
$

Reporting
B.
6
77,024
$
­

$
­

$
154,047
$
­

$
­

$
331,029
$
­

$
­

$
562,100
$
­

$
­

$
562,100
$
187,367
$

PWSs
­
Total
619,720
$
6,325,455
$
­

$
574,631
$
12,650,911
$
­

$
2,236,663
$
10,438,694
$
­

$
3,431,013
$
29,415,060
$
­

$
32,846,073
$
10,948,691
$

States
and
Territories
Start­
up
[
3]
B.
3
1,307,768
$
­

$
­

$
­

$
­

$
­

$
5,371,369
$
­

$
­

$
6,679,137
$
­

$
­

$
6,679,137
$
2,226,379
$

Reporting
and
bin
determination
B.
7
­

$
­

$
­

$
­

$
­

$
­

$
1,455,709
$
­

$
­

$
1,455,709
$
­

$
­

$
1,455,709
$
485,236
$

States
and
Territories
­
Total
1,307,768
$
­

$
­

$
­

$
­

$
­

$
6,827,079
$
­

$
­

$
8,134,846
$
­

$
­

$
8,134,846
$
2,711,615
$

Total
1,927,487
$
6,325,455
$
­

$
574,631
$
12,650,911
$
­

$
9,063,741
$
10,438,694
$
­

$
11,565,860
$
29,415,060
$
­

$
40,980,919
$
13,660,306
$

Note:
Detail
may
not
add
to
total
due
to
independent
rounding.

Sources
See
Exhibit
C.
2
for
a
breakdown
of
cost
by
year
and
system
type.

(
1)
All
medium
and
large
PWS
start­
up
cost
will
be
incurred
in
Year
1.

All
small
PWS
start­
up
cost
will
be
incurred
in
Year
3.

(
2)
1/
4
of
E.
coli
and
Cryptosporidium
monitoring
by
medium
and
large
systems
will
take
place
in
Year
1.

1/
2
of
E.
coli
and
Cryptosporidium
monitoring
by
medium
and
large
systems
will
take
place
in
Year
2.

1/
4
of
E.
coli
and
Cryptosporidium
monitoring
by
medium/
large
systems
and
1/
2
of
E.
coli
monitoring
by
small
systems
will
take
place
in
Year
3.

(
3)
State
rule
start­
up
activities
will
parallel
system
activities.
Thus,
20
percent
(
medium
and
large
systems
are
20
percent
of
those
monitoring)
of
this
work
will
be
done
in
Year
1,
as
medium
and
large
systems
do
rule
training,
and
the
remaining
80
percent
will
be
done
in
Year
3.
ICR
for
LT2ESWTR
Proposal
37
June
2003
Appendix
B
Supporting
Exhibits
for
Full
Implementation
of
the
Rule
Exhibit
B.
1
Baseline
Number
of
Plants
for
Rule
Start­
up
and
Monitoring
Activities
Exhibit
B.
2
Burden
and
Cost
to
PWSs
Associated
with
Rule
Start­
up
Activities
Exhibit
B.
3
Burden
and
Cost
to
States
and
Primacy
Agencies
Associated
with
Rule
Start­
up
Activities
Exhibit
B.
4
Burden
and
Cost
to
Plants
Associated
with
E.
coli
Monitoring
for
Bin
Determination
Exhibit
B.
5
Burden
and
Cost
to
Plants
Associated
with
Cryptosporidium
Monitoring
for
Bin
Determination
Exhibit
B.
6
Burden
and
Cost
to
Plants
Associated
with
Reporting
for
Bin
Classification
Monitoring
(
Years
4
and
5)
Exhibit
B.
7
Burden
and
Cost
to
States
Associated
with
E.
coli
and
Cryptosporidium
Monitoring
for
Bin
Determination
Exhibit
B.
8
Burden
and
Cost
to
States
Associated
with
Reviewing
Plants'
Reports
on
Technology
Compliance
(
Beginning
Year
7)
Exhibit
B.
9
Filtered
Plant
Burden
and
Cost
for
Preparing
Reports
Demonstrating
Technology
Compliance
(
Beginning
Year
7)
Exhibit
B.
10
Unfiltered
Plant
Burden
and
Cost
for
Reports
Demonstrating
Technology
Compliance
(
Beginning
Year
7)
Exhibit
B.
11
Plant
Burden
and
Cost
for
Benchmarking
Reports
Exhibit
B.
12
State
Burden
and
Cost
for
Benchmarking
Reports
Exhibit
B.
13
Burden
and
Cost
to
Plants
Associated
with
E.
coli
Monitoring
for
Bin
Reclassification
Exhibit
B.
14
Burden
and
Cost
to
Plants
Associated
with
Cryptosporidium
Monitoring
for
Bin
Reclassification
Exhibit
B.
15
Burden
and
Cost
to
Plants
Associated
with
Reporting
for
Bin
Reclassification
Monitoring
ICR
for
LT2ESWTR
Proposal
38
June
2003
Exhibit
B.
1
Baseline
Number
of
Plants
for
Rule
Start­
up
and
Monitoring
Activities
Implementation
Monitoring
for
Initial
Bin
Classification
Future
Monitoring
for
Re­
Binning
Baseline
#
PWSs
Percent
of
Plants
with
>
5.5
Log
Treatment
Prior
to
Rule
Promulgation
Plants
Per
System
Baseline
#
of
Plants
Conducting
E.
coli
Monitoring
Percent
of
Plants
Triggered
to
Monitor
for
Cryptosporidium
Baseline
#
of
Plants
Conducting
Cryptosporidium
Monitoring
Percent
of
Plants
with
>
5.5
Log
Treatment
for
LT2
Compliance
Percent
of
Plants
with
>
5.5
Log
Treatment
for
Stage
2
Compliance
Baseline
#
of
Plants
Conducting
E.
coli
Monitoring
Baseline
#
of
Plants
Conducting
Cryptosporidium
Monitoring
A
B
C
D
=
A*
C*(
1­
B)
E
F
=
D*
E
G
H
I
=
D*(
1­
G­
H)
J
=
E*
I
CWSs
 
100
530
3.6%
1.0
511
35%
178
5.3%
15.0%
407
142
101­
500
757
3.6%
1.1
803
35%
279
5.3%
6.3%
710
247
501­
1000
456
3.6%
1.0
440
35%
153
9.3%
6.3%
371
129
1001­
3,300
1,087
3.6%
1.0
1,048
35%
365
9.3%
1.8%
931
324
3,301­
10,000
1,017
3.6%
1.2
1,176
35%
409
9.3%
1.8%
1,045
364
10,001­
50,000
959
0.4%
1.1
1,051
­
1,051
27.1%
1.5%
751
751
50,001­
100,000
193
0.4%
1.8
346
­
346
27.1%
1.5%
247
247
100,001­
1
Million
205
0.4%
1.6
327
­
327
25.5%
1.5%
239
239
>
1
Million
13
0.4%
2.8
36
­
36
25.5%
1.5%
26
26
National
Totals
5,217
5,738
3,144
4,728
2,469
NTNCWSs
 
100
202
3.6%
1.0
195
35%
68
5.3%
15.0%
155
54
101­
500
236
3.6%
1.0
228
35%
79
5.3%
6.3%
201
70
501­
1000
84
3.6%
1.0
81
35%
28
9.3%
6.3%
68
24
1001­
3,300
55
3.6%
1.0
53
35%
18
9.3%
1.8%
47
16
3,301­
10,000
13
3.6%
1.0
13
35%
4
9.3%
1.8%
11
4
10,001­
50,000
3
0.4%
1.0
3
­
3
27.5%
1.5%
2
2
50,001­
100,000
­
0.4%
1.0
­
­
0
27.5%
1.5%
­
­
100,001­
1
Million
­
0.4%
1.0
­
­
0
26.0%
1.5%
­
­
>
1
Million
­
0.4%
1.0
­
­
0
0.0%
1.5%
­
­
National
Totals
593
572
201
485
170
TCWSs
 
100
731
0.0%
1.0
731
35%
254
5.3%
0.0%
693
241
101­
500
380
0.0%
1.0
380
35%
132
5.3%
0.0%
360
125
501­
1000
57
0.0%
1.0
57
35%
20
9.3%
0.0%
51
18
1001­
3,300
53
0.0%
1.0
53
35%
18
9.3%
0.0%
48
17
3,301­
10,000
25
0.0%
1.0
25
35%
9
9.3%
0.0%
22
8
10,001­
50,000
8
0.0%
1.0
8
­
8
27.5%
0.0%
5
5
50,001­
100,000
3
0.0%
1.0
3
­
3
27.5%
0.0%
2
2
100,001­
1
Million
­
0.0%
1.0
­
­
0
0.0%
0.0%
­
­
>
1
Million
­
0.0%
1.0
­
­
0
0.0%
0.0%
­
­
National
Totals
1,256
1,256
444
1,182
416
Grand
Totals
7,066
7,565
3,789
6,395
3,056
Notes:
Detail
may
not
add
exactly
to
totals
due
to
rounding.
Sources:
System
Size
(
Population
Served)

(
G)
Derived
from
Appendix
G
of
the
LT2ESWTR
Economic
Analysis;
this
number
is
calculated
by
dividing
the
number
of
plants
achieving
5.5
log
treatment
for
the
LT2ESWTR
by
the
total
number
of
plants
for
the
size
category.

(
H)
EPA
assumes
only
membrane
plants
will
have
>
5.5
log
Cryptosporidium
treatment
as
a
result
of
the
Stage
2
DBPR.
Estimates
from
the
Economic
Analysis
for
the
Stage
2
DBPR.
(
A)
Number
of
non­
purchased
SW
&
GWUDI
systems
is
from
EPA's
Safe
Drinking
Water
Information
System
as
of
September
30,
2000.

(
B)
EPA
assumes
only
membrane
filtration
plants
will
have
>
5.5
log
Cryptosporidium
treatment
prior
to
rule
promulgation.
Plants
estimated
to
have
membrane
filtration
as
a
result
of
Stage
1
DBPR
compliance
are
from
the
Economic
Analysis
for
the
Stage
2
DBPR.
(
C)
Estimate
of
the
number
of
plants,
or
entry
points
per
system.
Derived
from
1995
Community
Water
System
Survey
data.
(
E)
Percentage
of
plants
triggered
into
Cryptosporidium
monitoring
is
estimated
from
the
modelled
Information
Collection
Rule
Occurrence
Distribution.
ICR
for
LT2ESWTR
Proposal
39
June
2003
Exhibit
B.
2
Burden
and
Cost
to
PWSs
Associated
with
Rule
Start­
Up
Activities
System
Size
(
Population
Served)
Read
Hours
per
PWS
Train
Hours
per
PWS
Total
Hours
per
PWS
Cost
per
Labor
Hour
Baseline
#
of
Systems
Conducting
Implementation
Total
Cost
Total
Burden
(
Hours)
Total
Burden
(
FTEs)
A
B
C
=
A
+
B
D
E
F
=
C*
D*
E
G
=
C*
E
H
=
G/
2080
CWSs
 
100
4
4
8
24.96
$
530
105,830
$
4,240
2.0
101­
500
4
4
8
24.96
757
151,158
6,056
2.9
501­
1000
4
4
8
28.95
456
105,610
3,648
1.8
1001­
3,300
4
4
8
28.95
1,087
251,749
8,696
4.2
3,301­
10,000
4
4
8
28.95
1,017
235,537
8,136
3.9
10,001­
50,000
4
4
8
28.95
959
222,104
7,672
3.7
50,001­
100,000
4
5
9
28.95
193
50,286
1,737
0.8
100,001­
1
Million
4
5
9
28.95
205
53,413
1,845
0.9
>
1
Million
4
5
9
28.95
13
3,387
117
0.1
National
Totals
5,217
1,179,075
$
42,147
20.3
NTNCWSs
 
100
4
4
8
24.96
$
202
40,335
$
1,616
0.8
101­
500
4
4
8
24.96
236
47,124
1,888
0.9
501­
1000
4
4
8
28.95
84
19,454
672
0.3
1001­
3,300
4
4
8
28.95
55
12,738
440
0.2
3,301­
10,000
4
4
8
28.95
13
3,011
104
0.1
10,001­
50,000
4
4
8
28.95
3
695
24
0.0
50,001­
100,000
4
5
9
28.95
­
­
­
­
100,001­
1
Million
4
5
9
28.95
­
­
­
­
>
1
Million
4
5
9
28.95
­
­
­
­
National
Totals
593
123,358
$
4,744
2.3
TCWSs
 
100
4
4
8
24.96
$
731
145,995
$
5,849
2.8
101­
500
4
4
8
24.96
380
75,904
3,041
1.5
501­
1000
4
4
8
28.95
57
13,137
454
0.2
1001­
3,300
4
4
8
28.95
53
12,189
421
0.2
3,301­
10,000
4
4
8
28.95
25
5,744
198
0.1
10,001­
50,000
4
4
8
28.95
8
1,737
60
0.0
50,001­
100,000
4
5
9
28.95
3
782
27
0.0
100,001­
1
Million
4
5
9
28.95
­
­
­
­
>
1
Million
4
5
9
28.95
­
­
­
­
National
Totals
1,256
255,487
$
10,050
4.8
Grand
Totals
7,066
1,557,919
$
56,941
27.4
Notes:
Detail
may
not
add
exactly
to
totals
due
to
rounding.
Sources:
(
A
&
B)
Burden
estimates
for
each
activity
are
based
on
EPA
experience
with
s
imilar
rules.

(
D)
For
plants
serving
up
to
500
people,
the
full
technical
rate
($
24.96/
hour)
was
applied.
For
plants
serving
more
than
500
people,
cost
are
based
on
an
80%/
20%
split
between
technical
and
managerial
($
44.91/
hour)
rates.
Rates
are
based
on
Bureau
of
Labor
Statistics
data.
(
E)
Taken
from
Exhibit
B.
1,
column
A.
ICR
for
LT2ESWTR
Proposal
40
June
2003
Exhibit
B.
3
Burden
and
Cost
to
States
and
Primacy
Agencies
Associated
with
Rule
Startup
Activities
Implementation
Activities
Cost
per
Labor
Hour
FTEs
per
State
Hours
per
State
Cost
Per
State
A
B
C
=
B*
2080
D
=
A*
C
Regulation
Adoption
and
Program
Development
28.89
$
0.50
1,040
30,046
$
Training
State
Staff
28.89
0.25
520
15,023
Training
PWS
Staff
and
Technical
Assistants
28.89
1.00
2,080
60,091
Updating
Data
Management
System
28.89
0.10
208
6,009
Public
Notification
28.89
0.10
208
6,009
Totals
per
State
1.95
4,056
117,178
$
National
Totals
(
57
States/
Primacy
Agencies)
111.15
231,192
6,679,137
$

Notes:
Detail
may
not
add
to
totals
due
to
rounding.
All
States/
Primacy
Agencies
are
assumed
to
incur
some
costs
for
each
activity.
1
FTE
=
2,080
hours
(
40
hours/
week;
52
weeks/
year)
Sources:
(
A)
State
labor
rates
based
on
the
State
Workload
Model,
updated
to
current
dollar
values.
(
B)
FTEs
per
State/
Primacy
Agency
based
on
EPA
experience
with
previous
regulations.
ICR
for
LT2ESWTR
Proposal
41
June
2003
Exhibit
B.
4
Burden
and
Cost
to
Plants
Associated
with
E.
coli
Monitoring
for
Bin
Determination
Sampling
Sample
Analysis
#
of
E.

coli
Samples
Hours
per
Sample
Cost
per
Labor
Hour
Total
Sampling
Labor
Cost
Commercial
Analysis
(
Includes
Shipping)
Utility
Analysis
Hours
per
Sample
(
Labor)
Utility
Analysis
Cost
per
Sample
(
O&
M)
Utility
Analysis
Cost
per
Sample
(
Total)
Percent
Utilities
with
E.
coli
Analysis
Capabilities
Total
Laboratory
Analysis
Cost
(
Labor)
Total
Laboratory
Analysis
Cost
(
O&
M)

A
B
C
D
E
=
A*
B*
C*
D
F
G
H
I
=

H+
G*
D
J
K
=
D*
G*
J*
A*
B
L
=
F*
A*
B*(
1­

J)+
H*
A*
B*
J
M
=
E+
K+
L
N
=

A*
B*
C+
A*
B*
G*
J
CWSs
 
100
511
26
0.25
24.96
$
82,892
$
70.00
$
0.5
8.52
$
21.00
$
25%
41,446
$
725,701
$
850,038
$
4,981
101­
500
803
26
0.25
24.96
130,234
70.00
0.5
8.52
21.00
25%
65,117
1,140,171
1,335,522
7,827
501­
1000
440
26
0.25
24.96
71,318
70.00
0.5
8.52
21.00
25%
35,659
624,376
731,353
4,286
1001­
3,300
1,048
26
0.25
24.96
170,006
70.00
0.5
8.52
21.00
25%
85,003
1,488,371
1,743,380
10,217
3,301­
10,000
1,176
26
0.25
24.96
190,870
70.00
0.5
8.52
21.00
25%
95,435
1,671,028
1,957,333
11,471
10,001­
50,000
1,051
24
0.25
24.96
157,403
70.00
0.5
8.52
21.00
75%
236,105
602,622
996,130
15,766
50,001­
100,000
346
24
0.25
24.96
51,836
70.00
0.5
8.52
21.00
75%
77,754
198,456
328,046
5,192
100,001­
1
Million
327
24
0.25
24.96
48,941
70.00
0.5
8.52
21.00
100%
97,883
66,824
213,648
5,882
>
1
Million
36
24
0.25
24.96
5,431
70.00
0.5
8.52
21.00
100%
10,863
7,416
23,710
653
National
Totals
5,738
908,931
$
745,264
$
6,524,964
$
8,179,159
$
66,274
NTNCWSs
 
100
195
26
0.25
24.96
$
31,593
$
70.00
$
0.5
8.52
$
21.00
$
25%
15,796
$
276,588
$
323,977
$
1,899
101­
500
228
26
0.25
24.96
$
36,910
70.00
0.5
8.52
21.00
25%
18,455
323,142
378,508
2,218
501­
1000
81
26
0.25
24.96
$
13,138
70.00
0.5
8.52
21.00
25%
6,569
115,017
134,723
790
1001­
3,300
53
26
0.25
24.96
$
8,602
70.00
0.5
8.52
21.00
25%
4,301
75,309
88,211
517
3,301­
10,000
13
26
0.25
24.96
$
2,033
70.00
0.5
8.52
21.00
25%
1,017
17,800
20,850
122
10,001­
50,000
3
24
0.25
24.96
$
448
70.00
0.5
8.52
21.00
75%
671
1,714
2,833
45
50,001­
100,000
­
24
0.25
24.96
$
­
70.00
0.5
8.52
21.00
75%
­
­
­
­

100,001­
1
Million
­
24
0.25
24.96
$
­
70.00
0.5
8.52
21.00
100%
­
­
­
­

>
1
Million
­
24
0.25
24.96
$
­
70.00
0.5
8.52
21.00
100%
­
­
­
­

National
Totals
572
92,723
$
46,809
$
809,569
$
949,102
$
5,590
TNCWSs
 
100
731
26
0.25
24.96
$
118,621
$
70.00
$
0.5
8.52
$
21.00
$
25%
59,310
$
1,038,500
$
1,216,431
$
7,129
101­
500
380
26
0.25
24.96
61,672
70.00
0.5
8.52
21.00
25%
30,836
539,925
632,432
3,706
501­
1000
57
26
0.25
24.96
9,203
70.00
0.5
8.52
21.00
25%
4,601
80,567
94,371
553
1001­
3,300
53
26
0.25
24.96
8,539
70.00
0.5
8.52
21.00
25%
4,269
74,757
87,565
513
3,301­
10,000
25
26
0.25
24.96
4,024
70.00
0.5
8.52
21.00
25%
2,012
35,225
41,261
242
10,001­
50,000
8
24
0.25
24.96
1,123
70.00
0.5
8.52
21.00
75%
1,685
4,300
7,108
113
50,001­
100,000
3
24
0.25
24.96
449
70.00
0.5
8.52
21.00
75%
674
1,720
2,843
45
100,001­
1
Million
­
24
0.25
24.96
­
70.00
0.5
8.52
21.00
100%
­
­
­
­

>
1
Million
­
24
0.25
24.96
­
70.00
0.5
8.52
21.00
100%
­
­
­
­

National
Totals
1,256
203,630
$
103,387
$
1,774,994
$
2,082,012
$
12,300
Grand
Totals
7,565
1,205,284
$
895,460
$
9,109,528
$
11,210,273
$
84,164
Notes:

Detail
may
not
add
exactly
to
totals
due
to
independent
rounding.

Sources:

(
A)
Taken
from
Exhibit
B.
1,
column
D.

(
B)
Bi­
weekly
source
water
monitoring
for
one
year
for
small
systems
and
monthly
samples
for
24
months
for
medium
and
large
systems.

(
C)
Estimate
of
labor
for
collecting
sample
and
shipping,
based
on
expert
opinion.

(
D)
All
size
categories
were
assumed
to
use
a
technical
rate
of
$
24.96/
hour,
based
on
Bureau
of
Labor
Statistics
rates.

(
F)
DynCorp
study,
Kevin
Connell,
June
2002.

(
G)
Based
on
professional
judgment.

(
H)
The
amount
left
after
half
an
hour
of
labor
is
subtracted
from
the
amount
in
column
I.

(
I)
DynCorp
study,
Kevin
Connell,
December
2000.

(
J)
Estimate
based
on
Third
Edition
Baseline
Handbook
data.
Total
Burden
(
Hours)

System
Size
(
Population
Served)
Baseline
#

of
Plants
Conducting
E.
coli
Monitoring
Total
Cost
ICR
for
LT2ESWTR
Proposal
42
June
2003
Exhibit
B.
5
Burden
and
Cost
to
Plants
Associated
with
Cryptosporidium
Monitoring
for
Bin
Determination
Sampling
Sample
Analysis
#
of
Cryptosporidium
Samples
Hours
per
Sample
Cost
per
Labor
Hour
Total
Sampling
Labor
Cost
Cost
per
Sample
Total
Laboratory
Analysis
Cost
(
O&
M)

A
B
C
D
E
=
A*
B*
C*
D
F
G
=
A*
B*
F
H
=
E+
G
I
=
A*
B*
C
CWSs
 
100
178
26
0.5
24.96
$
57,693
$
529.50
$
2,447,775
$
2,505,467
$
2,311
101­
500
279
26
0.5
24.96
90,643
529.50
$
3,845,778
3,936,420
3,632
501­
1000
153
26
0.5
24.96
49,637
529.50
$
2,106,010
2,155,647
1,989
1001­
3,300
365
26
0.5
24.96
118,324
529.50
$
5,020,248
5,138,572
4,741
3,301­
10,000
409
26
0.5
24.96
132,845
529.50
$
5,636,348
5,769,193
5,322
10,001­
50,000
1,051
26
0.5
24.96
341,040
529.50
$
14,469,611
14,810,651
13,663
50,001­
100,000
346
26
0.5
24.96
112,311
529.50
$
4,765,137
4,877,448
4,500
100,001­
1
Million
327
26
0.5
24.96
106,040
529.50
$
4,499,035
4,605,075
4,248
>
1
Million
36
26
0.5
24.96
11,768
529.50
$
499,283
511,051
471
National
Totals
3,144
1,020,301
$
43,289,225
$
44,309,526
$
40,877
NTNCWSs
 
100
68
26
0.5
24.96
$
21,988
$
529.50
$
932,925
$
954,914
$
881
101­
500
79
26
0.5
24.96
25,690
529.50
1,089,953
1,115,642
1,029
501­
1000
28
26
0.5
24.96
9,144
529.50
387,949
397,093
366
1001­
3,300
18
26
0.5
24.96
5,987
529.50
254,014
260,001
240
3,301­
10,000
4
26
0.5
24.96
1,415
529.50
60,040
61,455
57
10,001­
50,000
3
26
0.5
24.96
970
529.50
41,150
42,120
39
50,001­
100,000
­
26
0.5
24.96
­
529.50
­
­
­
100,001­
1
Million
­
26
0.5
24.96
­
529.50
­
­
­
>
1
Million
­
26
0.5
24.96
­
529.50
­
­
­
National
Totals
201
65,194
$
2,766,031
$
2,831,225
$
2,612
TNCWSs
 
100
254
26
0.5
24.96
$
82,560
$
529.50
$
3,502,842
$
3,585,402
$
3,308
101­
500
132
26
0.5
24.96
42,924
529.50
1,821,156
1,864,080
1,720
501­
1000
20
26
0.5
24.96
6,405
529.50
271,751
278,156
257
1001­
3,300
18
26
0.5
24.96
5,943
529.50
252,153
258,097
238
3,301­
10,000
9
26
0.5
24.96
2,800
529.50
118,815
121,615
112
10,001­
50,000
8
26
0.5
24.96
2,434
529.50
103,253
105,686
98
50,001­
100,000
3
26
0.5
24.96
973
529.50
41,301
42,274
39
100,001­
1
Million
­
26
0.5
24.96
­
529.50
­
­
­
>
1
Million
­
26
0.5
24.96
­
529.50
­
­
­
National
Totals
444
144,039
$
6,111,271
$
6,255,310
$
5,771
Grand
Totals
3,789
1,229,534
$
52,166,527
$
53,396,061
$
49,260
Notes:
Detail
may
not
add
exactly
to
totals
due
to
independent
rounding.
Sources:
(
A)
Taken
from
Exhibit
B.
1,
column
F.

(
C)
Estimate
of
labor
for
collecting
sample
and
shipping,
based
on
expert
opinion.
(
D)
All
size
categories
were
assumed
to
use
a
technical
rate
of
$
24.96/
hour,
based
on
Bureau
of
Labor
Statistics
rates.
System
Size
(
Population
Served)
Baseline
#
of
Plants
Conducting
Cryptosporidium
Monitoring
Total
Cost
Total
Burden
(
Hours)

(
B)
Semimonthly
source
water
monitoring
for
one
year
for
small
systems
and
monthly
samples
for
24
months
for
medium
and
large
systems,
plus
two
matrix
spike
samples.

(
F)
Cost
per
sample
includes
$
403
in
lab
costs,
$
88.70
for
shipping,
and
$
37.80
in
additional
costs.
Assumes
all
plants
must
ship
samples
to
private
lab
for
Cryptosporidium
analysis.
Samples
must
be
shipped
overnight
to
meet
24­
hour
holding
time
requirements.
Costs
based
on
FedEx
priority
overnight
rates
for
10
L
sample
(
22
lb.)
shipped
in
a
34­
quart
polyethylene
cooler
packed
with
wet
ice,
median
cost
for
all
zones.
Samples
generating
a
pellet
volume
of
>
0.5
ml
require
multiple
subsample
processing
at
a
cost
of
$
140
each.
During
the
ICR
Supplemental
Survey,
approximately
27
percent
of
field
samples
required
analysis
of
multiple
subsamples,
resulting
in
an
additional
per­
plant
charge
of
$
38
($
140
x
0.27).
ICR
for
LT2ESWTR
Proposal
43
June
2003
System
Size
(
Population
Served)
Hours
per
Plant
Cost
per
Labor
Hour
Baseline
#
of
Plants
Reporting
Total
Cost
Total
Burden
(
Hours)
A
B
C
D
=
A*
B*
C
E
=
A*
C
CWSs
 
100
6.5
24.96
$
511
82,892
$
3,321
101­
500
6.5
24.96
803
130,234
5,218
501­
1000
6.5
28.95
440
82,719
2,857
1001­
3,300
6.5
28.95
1,048
197,183
6,811
3,301­
10,000
6.5
28.95
1,176
221,381
7,647
10,001­
50,000
6
28.95
1,051
182,565
6,306
50,001­
100,000
6
28.95
346
60,122
2,077
100,001­
1
Million
6
28.95
327
56,765
1,961
>
1
Million
6
28.95
36
6,300
218
National
Totals
5,738
1,020,160
$
36,416
NTNCWSs
 
100
6.5
24.96
$
195
31,593
$
1,266
101­
500
6.5
24.96
228
36,910
1,479
501­
1000
6.5
28.95
81
15,238
526
1001­
3,300
6.5
28.95
53
9,977
345
3,301­
10,000
6.5
28.95
13
2,358
81
10,001­
50,000
6
28.95
3
519
18
50,001­
100,000
6
28.95
0
­
­
100,001­
1
Million
6
28.95
0
­
­
>
1
Million
6
28.95
0
­
­
National
Totals
572
96,595
$
3,715
TCWSs
 
100
6.5
24.96
$
731
118,621
$
4,752
101­
500
6.5
24.96
380
61,672
2,471
501­
1000
6.5
28.95
57
10,674
369
1001­
3,300
6.5
28.95
53
9,904
342
3,301­
10,000
6.5
28.95
25
4,667
161
10,001­
50,000
6
28.95
8
1,303
45
50,001­
100,000
6
28.95
3
521
18
100,001­
1
Million
6
28.95
0
­
­
>
1
Million
6
28.95
0
­
­
National
Totals
1,256
207,361
$
8,158
Grand
Totals
7,565
1,324,115
$
48,289
Notes:
Detail
may
not
add
exactly
to
totals
due
to
independent
rounding.
Sources:

(
C)
Taken
from
Exhibit
B.
1,
column
D.
Exhibit
B.
6
Burden
and
Cost
to
Plants
Associated
with
Reporting
for
Initial
Bin
Classification
Monitoring
(
A)
Hours
per
plant
reporting
to
the
State/
Primacy
Agency
for
bin
classification
exemption
and
to
report
E.
coli
and
Cryptosporidium
monitoring
data
and
bin
classification.
Assumes
15
minutes
per
sample.
Based
on
24
monthly
E.
coli
and
Cryptosporidium
samples
for
medium
and
large
systems
and
26
biweekly
E.
coli
and
24
semimonthly
Cryptosporidium
samples
for
small
systems.
Although
small
systems
will
not
report
E.
coli
and
Cryptosporidium
results
at
the
same
time,
the
additional
reporting
burden
is
assumed
to
be
negligible.
The
decrease
in
burden
for
small
plants
that
report
E.
coli
but
are
exempt
from
Cryptosporidium
monitoring
is
also
assumed
to
be
negligible.

(
B)
For
plants
serving
up
to
500
people,
the
full
technical
rate
($
24.96/
hour)
was
applied.
For
plants
serving
more
than
500
people,
costs
are
based
on
an
80%/
20%
split
between
technical
and
managerial
($
44.91/
hour)
rates.
Rates
are
based
on
Bureau
of
Labor
Statistics
data.
ICR
for
LT2ESWTR
Proposal
44
June
2003
Exhibit
B.
7
Burden
and
Cost
to
States
Associated
with
E.
coli
and
Cryptosporidium
Monitoring
and
Bin
Determination
(
Initial
and
Future
Rounds)

Initial
Monitoring
for
Small
Systems
State
Activity
FTEs
per
State
for
E.

coli
Monitoring
Total
Hours
for
E.
coli
FTEs
Per
State
for
Cryptosporidium
Monitoring
Total
Hours
for
Cryptosporidium
Total
FTEs
Per
State
Total
Hours
Cost
per
Labor
Hour
Total
Cost
A
B
=

A*
2080
C
D
=
C*
2080
E
=
A+
C
F
=
B+
D
G
H
=
F*
G
Analyze
PWS
Reports
and
Make
Bin
Classifications
0.3
624
0.2
416
0.5
1040
28.89
$
30,046
$

Respond
to
PWS
0.3
624
0.2
416
0.5
1040
28.89
30,046
Recordkeeping
0.25
520
0.25
520
0.5
1040
28.89
30,046
Totals
per
State
0.9
1,768
0.7
1,352
1.5
3,120
90,137
$

National
Totals
(
57
States/
Primacy
Agencies)
48.5
100,776
37.1
77,064
85.5
177,840
5,137,798
$

Notes:

Detail
may
not
add
to
totals
due
to
independent
rounding.

All
States/
Primacy
Agencies
are
assumed
to
incur
some
costs
for
each
activity.

1
FTE
=
2,080
hours
(
40
hours/
week;
52
weeks/
year)

Sources
(
A),
(
C)
EPA
estimated
FTEs
based
on
experience
with
similar
regulations.

(
G)
Based
on
information
gathered
during
the
development
of
the
State
Workload
Model.

Future
Monitoring
State
Activity
FTEs
per
State
for
E.

coli
Monitoring
in
Small
Systems
Total
Hours
for
E.
coli
in
Small
Systems
FTEs
Per
State
for
Cryptosporidium
Monitoring
in
Small
Systems
Total
Hours
for
Cryptosporidium
in
Small
Systems
FTEs
Per
State
for
Cryptosporidium
Monitoring
in
Medium
&

Large
Systems
Total
Hours
for
Cryptosporidi
um
in
Medium
&

Large
Systems
Total
FTEs
Per
State
Total
Hours
Cost
per
Labor
Hour
Total
Cost
A
B
=

A*
2080
C
D
=
C*
2080
E
F
=
E*
2080
G
=
A+
C+
E
H
=
B+
D+
F
I
J
=
H*
I
Analyze
PWS
Report
and
Make
Bin
Classifications
0.2
416
0.1
208
0.1
208
0.4
832
28.89
$
24,036
$

Respond
to
PWS
0.2
416
0.1
208
0.1
208
0.4
832
28.89
24,036
$

Recordkeeping
0.25
520
0.25
520
0.25
520
0.75
1560
28.89
45,068
$

Totals
per
State
0.7
1,352
0.5
936
0.5
936
1.6
3,224
93,141
$

National
Totals
(
57
States/
Primacy
Agencies)
37.1
77,064
25.7
53,352
25.7
53,352
88.4
183,768
5,309,058
$

Notes:

Detail
may
not
add
to
totals
due
to
independent
rounding.

All
States/
Primacy
Agencies
are
assumed
to
incur
some
costs
for
each
activity.

1
FTE
=
2,080
hours
(
40
hours/
week;
52
weeks/
year)

Sources
(
A),
(
C),
(
E)
EPA
estimated
FTEs
based
on
experience
with
similar
regulations.

(
I)
Based
on
information
gathered
during
the
development
of
the
State
Workload
Model.
ICR
for
LT2ESWTR
Proposal
45
June
2003
Exhibit
B.
8
Burden
and
Cost
to
States
Associated
w
ith
Review
ing
Plants'
Reports
on
Technology
Compliance
(
Beginning
Year
7
)

System
S
ize
(
Population
Se
rved)
Num
be
r
of
P
la
nts
Insta
lling
UV
Numbe
r
of
P
la
nts
Insta
lling
MF/
UF
Numbe
r
of
Unfil
tere
d
Pla
nts
Installing
Ozone
Numbe
r
o
f
P
lants
Instal
ling
Ba
nk
Fil
tra
tion
Total
Plants
Annua
l
La
bor
Hours
pe
r
P
la
nt
La
bor
Ra
te
Total
Annua
l
La
bor
Hours
Total
Annua
l
Costs
A
B
C
D
A+
B+
C+
D
F
G
H
=
E*
F
I
=
G*
H
 
100
100
118
­
­
218
6
28.89
$
1,305
37,703
$
101­
500
87
69
­
­
156
6
28.89
938
27,105
501­
1000
60
36
1
­
97
6
28.89
581
16,788
1001­
3,300
117
21
1
­
140
6
28.89
837
24,195
3,301­
10,000
138
20
2
­
160
6
28.89
961
27,764
10,001­
50,000
333
20
1
3
358
6
28.89
2,149
62,076
50,001­
100,000
121
5
0
1
127
6
28.89
764
22,067
100,001­
1
M
illion
106
5
1
1
112
6
28.89
674
19,486
>
1
Million
21
0
1
0
22
6
28.89
133
3,838
Na
tiona
l
Tota
ls
1,083
296
7
5
1,390
8,343
241,022
$

Notes:
Detail
m
ay
not
add
exactly
to
totals
due
to
independent
rounding.
UV
s
tands
for
ultraviolet
disinfection
and
MF/
UF
stands
for
microfilt
ration/
ultrafiltrat
ion.
Sources
:
(
A)­(
D)
Taken
from
A
ppendix
G
of
the
E
conomic
A
nalysis
for
the
LT2
ESWTR.
(
F)
Based
on
an
es
t
imate
of
0.5
hours
per
m
onth
needed
to
review
each
plant's
reports.
(
G)
Based
on
information
gathered
during
the
development
of
the
S
tate
W
orkload
M
odel.
ICR
for
LT2ESWTR
Proposal
46
June
2003
Exhibit
B.
9
Filtered
Plant
Burden
and
Cost
for
Preparing
Reports
Demonstrating
Technology
Compliance
(
Beginning
Year
7)

System
Size
(
Population
Served)
Number
of
Plants
Installing
UV
Number
of
Plants
Installing
MF/
UF
Number
of
Plants
Installing
Bank
Filtration
Total
Plants
Annual
Labor
Hours
per
Plant
Labor
Rate
Total
Annual
Labor
Hours
Total
Annual
Costs
A
B
C
D=
A+
B+
C
E
F
G=
D*
E
H=
F*
G
CWS
 
100
21
73
­
94
36
24.96
$
3,388
84,568
$
101­
500
42
51
­
92
36
24.96
3,318
82,809
501­
1000
38
29
­
66
36
28.95
2,392
69,251
1001­
3,300
92
20
­
112
36
28.95
4,025
116,525
3,301­
10,000
109
20
­
129
36
28.95
4,633
134,117
10,001­
50,000
312
20
3
335
36
28.95
12,076
349,599
50,001­
100,000
115
5
1
121
36
28.95
4,348
125,880
100,001­
1
Million
100
5
1
106
36
28.95
3,807
110,206
>
1
Million
13
0
0
14
36
28.95
495
14,323
National
Totals
841
223
5
1,069
38,481
1,087,279
$
NTNCWS
 
100
13
45
­
57
36
24.96
$
2,066
51,574
$
101­
500
14
19
­
33
36
24.96
1,192
29,753
501­
1000
9
7
­
16
36
28.95
572
16,547
1001­
3,300
6
1
­
8
36
28.95
272
7,864
3,301­
10,000
2
0
­
2
36
28.95
88
2,548
10,001­
50,000
2
0
0
2
36
28.95
83
2,393
50,001­
100,000
0
0
0
0
36
28.95
10
299
100,001­
1
Million
0
0
0
0
36
28.95
10
284
>
1
Million
­
­
­
­
36
28.95
­
­
National
Totals
47
72
0
119
4,292
111,262
$
TNCWS
 
100
65
­
­
65
36
24.96
$
2,340
58,404
$
101­
500
26
­
­
26
36
24.96
922
23,002
501­
1000
7
0
­
8
36
28.95
271
7,845
1001­
3,300
6
0
­
6
36
28.95
224
6,489
3,301­
10,000
3
0
­
3
36
28.95
104
3,003
10,001­
50,000
3
0
0
3
36
28.95
100
2,892
50,001­
100,000
1
0
0
1
36
28.95
30
868
100,001­
1
Million
­
­
­
­
36
28.95
­
­
>
1
Million
­
­
­
­
36
28.95
­
­
National
Totals
111
0
0
111
3,990
102,503
$
Grand
Totals
998
296
5
1,299
46,764
1,301,044
$

Notes:
Detail
may
not
add
exactly
to
totals
due
to
independent
rounding.
UV
stands
for
ultraviolet
disinfection
and
MF/
UF
stands
for
microfiltration/
ultrafiltration.
Sources:
(
A),
(
B),
(
C)
Taken
from
Appendix
G
of
the
LT2ESWTR
Economic
Analysis.
(
E)
Based
on
an
estimate
of
3
hours
per
month
to
prepare
each
report.
(
F)
For
plants
serving
up
to
500
people,
the
full
technical
rate
($
24.96/
hour)
was
applied.
For
plants
serving
more
than
500
people,
costs
are
based
on
an
80%/
20%
split
between
technical
and
managerial
($
44.91/
hour)
rates.
Rates
are
based
on
Bureau
of
Labor
Statistics
data.
ICR
for
LT2ESWTR
Proposal
47
June
2003
Exhibit
B.
10
Unfiltered
Plant
Burden
and
Cost
for
Reports
Demonstrating
Technology
Compliance
(
Beginning
Year
7)

CWS
System
Size
(
Population
Served)
Number
of
Plants
Installing
UV
Number
of
Plants
Installing
Ozone
Annual
Labor
Hours
per
Plant
Labor
Rate
Total
Annual
Labor
Hours
Total
Annual
Costs
A
B
C
D
E
=
(
A+
B)*
C
F
=
(
A+
B)
C*
D
 
100
1
­
36
24.96
$
36
899
$
101­
500
6
­
36
24.96
198
4,942
501­
1000
6
1
36
28.95
252
7,295
1001­
3,300
13
1
36
28.95
504
14,591
3,301­
10,000
24
2
36
28.95
942
27,264
10,001­
50,000
16
1
36
28.95
634
18,343
50,001­
100,000
5
0
36
28.95
194
5,628
100,001­
1
Million
6
1
36
28.95
230
6,670
>
1
Million
8
1
36
28.95
302
8,754
National
Totals
85
7
3,293
94,386
$

Notes:
Detail
may
not
add
exactly
to
totals
due
to
independent
rounding.

Sources:

(
C)
Based
on
an
estimate
of
3
hours
per
month
to
prepare
each
report.

(
D)
For
plants
serving
up
to
500
people,
the
full
technical
rate
($
24.96/
hour)
was
applied.
For
plants
serving
more
than
500
people,
costs
are
based
on
an
80%/
20%
split
between
technical
and
managerial
($
44.91/
hour)
rates.
Rates
are
based
on
Bureau
of
Labor
Statistics
data.
(
A),
(
B)
From
Chapter
6
of
the
Economic
Analysis
for
the
LT2ESWTR.
There
is
only
one
noncommunity
unfiltered
system,
which
was
grouped
with
the
CWSs
for
this
analysis.
UV
stands
for
ultraviolet
disinfection.
ICR
for
LT2ESWTR
Proposal
48
June
2003
Exhibit
B.
11
Plant
Burden
and
Cost
for
Benchmarking
Reports
System
Size
(
Population
Served)
Number
of
Plants
Insta
lling
UV
Number
of
Plants
Installing
MF/
UF
Number
of
Plants
Insta
lling
Ozone
Number
of
Plants
Installing
ClO2
Tota
l
Plants
Labor
Hours
per
Plant
Labor
Rate
Total
Labor
Hours
Total
Costs
A
B
C
D
E
=
A+
B+
C+
D
F
G
H
=
E*
F
I
=
G*
H
CWS
 
100
22
­
­
­
22
4
24.96
$
87
2,183
$
101­
500
47
­
­
­
47
4
24.96
189
4,707
501­
1000
44
0
2
0
47
4
28.95
187
5,412
1001­
3,300
105
1
5
1
111
4
28.95
444
12,864
3,301­
10,000
133
1
7
1
141
4
28.95
565
16,355
10,001­
50,000
329
4
28
40
401
4
28.95
1,602
46,383
50,001­
100,000
120
2
10
15
146
4
28.95
583
16,892
100,001­
1
Million
106
1
9
18
134
4
28.95
537
15,544
>
1
Million
21
0
2
2
25
4
28.95
101
2,926
National
Totals
925
9
63
76
1,074
4,296
123,266
$
NTNCWS
 
100
13
­
­
­
13
4
24.96
$
51
1,271
$
101­
500
14
­
­
­
14
4
24.96
57
1,416
501­
1000
9
0
0
0
9
4
28.95
38
1,099
1001­
3,300
6
0
0
0
7
4
28.95
26
759
3,301­
10,000
2
0
0
0
2
4
28.95
8
246
10,001­
50,000
2
0
0
0
3
4
28.95
10
302
50,001­
100,000
0
0
0
0
0
4
28.95
1
38
100,001­
1
Million
0
0
0
0
0
4
28.95
1
37
>
1
Million
­
­
­
­
­
4
28.95
­
­
National
Totals
47
0
1
0
48
193
5,168
$
TNCWS
 
100
65
­
­
­
65
4
24.96
$
260
6,489
$
101­
500
26
­
­
­
26
4
24.96
102
2,556
501­
1000
7
0
0
0
8
4
28.95
32
915
1001­
3,300
6
0
0
0
7
4
28.95
26
757
3,301­
10,000
3
0
0
0
3
4
28.95
12
350
10,001­
50,000
3
0
0
0
3
4
28.95
13
384
50,001­
100,000
1
0
0
0
1
4
28.95
4
115
100,001­
1
Million
­
­
­
­
­
4
28.95
­
­
>
1
Million
­
­
­
­
­
4
28.95
­
­
National
Totals
111
0
1
1
112
450
11,568
$
Grand
Totals
1,083
10
65
77
1,235
4,939
140,002
Notes:
Detail
may
not
add
exactly
to
totals
due
to
independent
rounding.
UV
stands
for
ultraviolet
disinfection
and
MF/
UF
stands
for
microfiltration/
ultrafiltration.
Sources:
(
A)
­
(
D)
From
Appendix
G
of
the
Economic
Analysis
for
the
LT2ESWTR.
(
F)
Based
on
expert
opinion.
(
G)
For
plants
serving
up
to
500
people,
the
full
technical
rate
($
24.96/
hour)
was
applied.
For
plants
serving
more
than
500
people,
costs
are
based
on
an
80%/
20%
split
between
technical
and
managerial
($
44.91/
hour)
rates.
Rates
are
based
on
Bureau
of
Labor
Statistics
data.
ICR
for
LT2ESWTR
Proposal
49
June
2003
Exhibit
B.
12
State
Burden
and
Cost
for
Benchmarking
Reports
System
Size
(
Population
Served)
Number
of
Plants
Installing
UV
Number
of
Plants
Installing
MF/
UF
Number
of
Plants
Installing
Ozone
Number
of
Plants
Installing
ClO2
Total
Number
of
Plants
Changing
Disinfection
Labor
Hours
per
Plant
Labor
Rate
Total
Labor
Hours
Total
Costs
A
B
C
D
E
=
A
+
B
+
C
+
D
F
G
H
=
E*
F
I
=
G*
H
 
100
100
­
­
­
100
2
28.89
$
199
5,755
$
101­
500
87
­
­
­
87
2
28.89
174
5,023
501­
1000
60
0
3
0
64
2
28.89
128
3,706
1001­
3,300
117
1
6
1
124
2
28.89
248
7,175
3,301­
10,000
138
1
7
1
146
2
28.89
293
8,458
10,001­
50,000
333
4
28
40
406
2
28.89
813
23,486
50,001­
100,000
121
2
10
15
147
2
28.89
294
8,505
100,001­
1
Million
106
1
9
18
135
2
28.89
269
7,775
>
1
Million
21
0
2
2
25
2
28.89
51
1,460
National
Totals
1,083
10
65
77
1,235
18
2,469
71,341
$

Notes:
Detail
may
not
add
exactly
to
totals
due
to
independent
rounding.
UV
stands
for
ultraviolet
disinfection
and
MF/
UF
s
tands
for
microfiltration/
ultrafiltration.
Sources:
(
A)
­
(
D)
From
Appendix
G
of
the
Economic
Analysis
for
the
LT2ESWTR.
(
F)
Based
on
expert
opinion.
(
G)
Based
on
information
gathered
during
the
development
of
the
State
Workload
Model.
ICR
for
LT2ESWTR
Proposal
50
June
2003
Sampling
Sample
Analysis
#
of
E.

coli
Samples
Hours
per
Sample
Cost
per
Labor
Hour
Total
Sampling
Labor
Cost
Commercial
Analysis
(
Includes
Shipping)
Utility
Analysis
Hours
per
Sample
(
Labor)
Utility
Analysis
Cost
per
Sample
(
O&
M)
Utility
Analysis
Cost
per
Sample
(
Total)
Percent
Utilities
with
E.
coli
Analysis
Capabilities
Total
Laboratory
Analysis
Cost
(
Labor)
Total
Laboratory
Analysis
Cost
(
O&
M)

A
B
C
D
E
=
A*
B*
C*
D
F
G
H
I
=
H+
G*
D
J
K
=
D*
G*
J*
A*
B
L
=
F*
A*
B*(
1­

J)+
H*
A*
B*
J
M
=
E+
K+
L
N
=
A*
B*
C+

A*
B*
G*
J
CWSs
 
100
407
26
0.25
24.96
$
66,059
$
70.00
$
0.5
8.52
$
21.00
$
25%
33,029.34
$
578,331
$
677,419
$
3,970
101­
500
710
26
0.25
24.96
115,130
70.00
0.5
8.52
21.00
25%
57,565.14
1,007,943
1,180,639
6,919
501­
1000
371
26
0.25
24.96
60,176
70.00
0.5
8.52
21.00
25%
30,087.83
526,826
617,090
3,616
1001­
3,300
931
26
0.25
24.96
151,078
70.00
0.5
8.52
21.00
25%
75,539.15
1,322,661
1,549,279
9,079
3,301­
10,000
1,045
26
0.25
24.96
169,619
70.00
0.5
8.52
21.00
25%
84,809.55
1,484,983
1,739,411
10,193
10,001­
50,000
751
24
0.25
24.96
112,504
70.00
0.5
8.52
21.00
75%
168,755.28
430,723
711,981
11,268
50,001­
100,000
247
24
0.25
24.96
37,050
70.00
0.5
8.52
21.00
75%
55,574.54
141,846
234,470
3,711
100,001­
1
Million
239
24
0.25
24.96
35,721
70.00
0.5
8.52
21.00
100%
71,442.71
48,773
155,937
4,293
>
1
Million
26
24
0.25
24.96
3,964
70.00
0.5
8.52
21.00
100%
7,928.40
5,413
17,305
476
National
Totals
4,728
751,301
$
584,732
$
5,547,499
$
6,883,532
$
53,527
NTNCWSs
 
100
155
26
0.25
24.96
$
25,177
$
70.00
$
0.5
8.52
$
21.00
$
25%
12,588.54
$
220,421
$
258,186
$
1,513
101­
500
201
26
0.25
24.96
32,630
70.00
0.5
8.52
21.00
25%
16,314.85
285,667
334,611
1,961
501­
1000
68
26
0.25
24.96
11,085
70.00
0.5
8.52
21.00
25%
5,542.49
97,047
113,674
666
1001­
3,300
47
26
0.25
24.96
7,644
70.00
0.5
8.52
21.00
25%
3,822.13
66,924
78,390
459
3,301­
10,000
11
26
0.25
24.96
1,807
70.00
0.5
8.52
21.00
25%
903.41
15,818
18,529
109
10,001­
50,000
2
24
0.25
24.96
318
70.00
0.5
8.52
21.00
75%
476.92
1,217
2,012
32
50,001­
100,000
­
24
0.25
24.96
­
70.00
0.5
8.52
21.00
75%
­
­
­
­

100,001­
1
Million
­
24
0.25
24.96
­
70.00
0.5
8.52
21.00
100%
­
­
­
­

>
1
Million
­
24
0.25
24.96
­
70.00
0.5
8.52
21.00
100%
­
­
­
­

National
Totals
485
78,661
$
39,648
$
687,094
$
805,403
$
4,740
TNCWSs
 
100
693
26
0.25
24.96
$
112,373
$
70.00
$
0.5
8.52
$
21.00
$
25%
56,186.28
$
983,800
$
1,152,359
$
6,753
101­
500
360
26
0.25
24.96
58,423
70.00
0.5
8.52
21.00
25%
29,211.71
511,486
599,121
3,511
501­
1000
51
26
0.25
24.96
8,347
70.00
0.5
8.52
21.00
25%
4,173.68
73,080
85,601
502
1001­
3,300
48
26
0.25
24.96
7,745
70.00
0.5
8.52
21.00
25%
3,872.69
67,809
79,427
465
3,301­
10,000
22
26
0.25
24.96
3,650
70.00
0.5
8.52
21.00
25%
1,824.81
31,952
37,426
219
10,001­
50,000
5
24
0.25
24.96
814
70.00
0.5
8.52
21.00
75%
1,221.36
3,117
5,153
82
50,001­
100,000
2
24
0.25
24.96
326
70.00
0.5
8.52
21.00
75%
488.55
1,247
2,061
33
100,001­
1
Million
­
24
0.25
24.96
­
70.00
0.5
8.52
21.00
100%
­
­
­
­

>
1
Million
­
24
0.25
24.96
­
70.00
0.5
8.52
21.00
100%
­
­
­
­

National
Totals
1,182
191,678
$
96,979
$
1,672,491
$
1,961,148
$
11,565
Grand
Totals
6,395
1,021,640
$
721,359
$
7,907,084
$
9,650,083
$
69,832
Notes:

Detail
may
not
add
exactly
to
totals
due
to
independent
rounding.

Sources:

(
A)
Taken
from
Exhibit
B.
1,
column
I.

(
B)
Bi­
weekly
source
water
monitoring
for
one
year
for
small
systems
and
monthly
samples
for
24
months
for
medium
and
large
systems.

(
C)
Estimate
of
labor
for
collecting
sample
and
shipping,
based
on
expert
opinion.

(
D)
All
size
categories
were
assumed
to
use
a
technical
rate
of
$
24.96/
hour,
based
on
Bureau
of
Labor
Statistics
rates.

(
F)
DynCorp
study,
Kevin
Connell,
June
2002.

(
G)
Based
on
expert
opinion.

(
H)
The
amount
left
over
after
the
cost
of
half
an
hour
of
labor
is
subtracted
from
the
cost
of
utility
analysis
provided
in
Column
I.

(
I)
DynCorp
study,
Kevin
Connell,
December
2000.

(
J)
Estimate
based
on
Third
Edition
Baseline
Handbook
data.

Exhibit
B.
13
Burden
and
Cost
to
Plants
Associated
with
E.
coli
Monitoring
for
Bin
Reclassification
System
Size
(
Population
Served)
Baseline
#

of
Plants
Conducting
E.
coli
Monitoring
Total
Cost
Total
Burden
(
Hours)
ICR
for
LT2ESWTR
Proposal
51
June
2003
Sampling
Sample
Analysis
#
of
Cryptosporidium
Samples
Hours
per
Sample
Cost
per
Labor
Hour
Total
Sampling
Labor
Cost
Cost
per
Sample
Total
Laboratory
Analysis
Cost
(
O&
M)

A
B
C
D
E
=
A*
B*
C*
D
F
G
=
A*
B*
F
H
=
E+
G
I
=
A*
B*
C
CWSs
 
100
142
26
0.5
24.96
$
45,977
$
529.50
$
1,950,700
$
1,996,677
$
1,842
101­
500
247
26
0.5
24.96
80,131
529.50
3,399,775
3,479,906
3,210
501­
1,000
129
26
0.5
24.96
41,882
529.50
1,776,975
1,818,858
1,678
1,001­
3,300
324
26
0.5
24.96
105,150
529.50
4,461,313
4,566,464
4,213
3,301­
10,000
364
26
0.5
24.96
118,055
529.50
5,008,819
5,126,874
4,730
10,001­
50,000
751
26
0.5
24.96
243,758
529.50
10,342,120
10,585,878
9,766
50,001­
100,000
247
26
0.5
24.96
80,274
529.50
3,405,870
3,486,145
3,216
100,001­
1
Million
239
26
0.5
24.96
77,396
529.50
3,283,760
3,361,156
3,101
>
1
Million
26
26
0.5
24.96
8,589
529.50
364,417
373,006
344
National
Totals
2,469
801,212
$
33,993,751
$
34,794,964
$
32,100
NTNCWSs
 
100
54
26
0.5
24.96
$
17,523
$
529.50
$
743,474
$
760,998
$
702
101­
500
70
26
0.5
24.96
22,710
529.50
963,549
986,259
910
501­
1000
24
26
0.5
24.96
7,715
529.50
327,338
335,053
309
1001­
3,300
16
26
0.5
24.96
5,320
529.50
225,733
231,054
213
3,301­
10,000
4
26
0.5
24.96
1,258
529.50
53,355
54,613
50
10,001­
50,000
2
26
0.5
24.96
689
529.50
29,228
29,917
28
50,001­
100,000
­
26
0.5
24.96
­
529.50
­
­
­
100,001­
1
Million
­
26
0.5
24.96
­
529.50
­
­
­
>
1
Million
­
26
0.5
24.96
­
529.50
­
­
­
National
Totals
170
55,216
$
2,342,677
$
2,397,892
$
2,212
TNCWSs
 
100
241
26
0.5
24.96
$
78,211
$
529.50
$
3,318,340
$
3,396,551
$
3,133
101­
500
125
26
0.5
24.96
40,663
529.50
1,725,232
1,765,895
1,629
501­
1000
18
26
0.5
24.96
5,810
529.50
246,496
252,306
233
1001­
3,300
17
26
0.5
24.96
5,391
529.50
228,719
234,110
216
3,301­
10,000
8
26
0.5
24.96
2,540
529.50
107,773
110,313
102
10,001­
50,000
5
26
0.5
24.96
1,764
529.50
74,851
76,615
71
50,001­
100,000
2
26
0.5
24.96
706
529.50
29,940
30,646
28
100,001­
1
Million
­
26
0.5
24.96
­
529.50
­
­
­
>
1
Million
­
26
0.5
24.96
­
529.50
­
­
­
National
Totals
416
135,085
$
5,731,352
$
5,866,436
$
5,412
Grand
Totals
3,056
991,513
$
42,067,780
$
43,059,292
$
39,724
Notes:

(
A)
Taken
from
Exhibit
B.
1,
column
J.

(
C)
Estimate
of
labor
for
collecting
sample
and
shipping,
based
on
expert
opinion.
(
D)
All
size
categories
were
assumed
to
use
a
technical
rate
of
$
24.96/
hour,
based
on
Bureau
of
Labor
Statistics
rates.
(
B)
Semimonthly
source
water
monitoring
for
one
year
for
small
systems
and
monthly
samples
for
24
months
for
medium
and
large
systems,
plus
two
matrix
spike
samples.

(
F)
Cost
per
sample
includes
$
403
in
lab
costs,
$
88.70
for
shipping,
and
$
37.80
in
additional
costs.
Assumes
all
plants
must
ship
samples
to
private
lab
for
Cryptosporidium
analysis.
Samples
must
be
shipped
overnight
to
meet
24­
hour
holding
time
requirements.
Costs
based
on
FedEx
priority
overnight
rates
for
10
L
sample
(
22
lb.)
shipped
in
a
34­
quart
polyethylene
cooler
packed
with
wet
ice,
median
cost
for
all
zones.
Samples
generating
a
pellet
volume
of
>
0.5
ml
require
multiple
subsample
processing
at
a
cost
of
$
140
each.
During
the
ICR
Supplemental
Survey,
approximately
27
percent
of
field
samples
required
analysis
of
multiple
subsamples,
resulting
in
an
additional
per­
plant
charge
of
$
38
($
140
x
0.27).
Exhibit
B.
14
Burden
and
Cost
to
Plants
Associated
with
Cryptosporidium
Monitoring
for
Bin
Reclassification
Detail
may
not
add
exactly
to
totals
due
to
independent
rounding.
System
Size
(
Population
Served)
Baseline
#
of
Plants
Conducting
Cryptosporidium
Monitoring
Total
Cost
Total
Burden
(
Hours)
ICR
for
LT2ESWTR
Proposal
52
June
2003
System
Size
(
Population
Served)
Hours
per
Plant
Cost
per
Labor
Hour
Baseline
#
of
Plants
Reporting
Total
Cost
Total
Burden
(
Hours)
A
B
C
D
=
A*
B*
C
E
=
A*
C
CWSs
 
100
6.5
24.96
$
407
66,059
$
2,647
101­
500
6.5
24.96
710
115,130
4,613
501­
1000
6.5
28.95
371
69,795
2,411
1001­
3,300
6.5
28.95
931
175,229
6,053
3,301­
10,000
6.5
28.95
1,045
196,734
6,796
10,001­
50,000
6
28.95
751
130,488
4,507
50,001­
100,000
6
28.95
247
42,972
1,484
100,001­
1
Million
6
28.95
239
41,432
1,431
>
1
Million
6
28.95
26
4,598
159
National
Totals
4,728
842,436
$
30,100
NTNCWSs
 
100
6.5
24.96
$
155
25,177
$
1,009
101­
500
6.5
24.96
201
32,630
1,307
501­
1000
6.5
28.95
68
12,857
444
1001­
3,300
6.5
28.95
47
8,866
306
3,301­
10,000
6.5
28.95
11
2,096
72
10,001­
50,000
6
28.95
2
369
13
50,001­
100,000
6
28.95
­
­
­
100,001­
1
Million
6
28.95
­
­
­
>
1
Million
6
28.95
­
­
­
National
Totals
485
81,994
$
3,151
TCWSs
 
100
6.5
24.96
$
693
112,373
$
4,502
101­
500
6.5
24.96
360
58,423
2,341
501­
1000
6.5
28.95
51
9,682
334
1001­
3,300
6.5
28.95
48
8,984
310
3,301­
10,000
6.5
28.95
22
4,233
146
10,001­
50,000
6
28.95
5
944
33
50,001­
100,000
6
28.95
2
378
13
100,001­
1
Million
6
28.95
­
­
­
>
1
Million
6
28.95
­
­
­
National
Totals
1,182
195,016
$
7,679
Grand
Totals
6,395
1,119,447
$
40,931
Sources
Exhibit
B.
15
Burden
and
Cost
to
Plants
Associated
with
Reporting
for
Bin
Re­
Classification
Monitoring
(
A)
Hours
per
plant
reporting
to
the
State/
Primacy
Agency
for
bin
classification
exemption
and
to
report
E.
coli
and
Cryptosporidium
monitoring
data
and
bin
classification.
Assumes
15
minutes
per
sample.
Based
on
24
monthly
E.
coli
and
Cryptosporidium
samples
for
medium
and
large
systems
and
26
biweekly
E.
coli
and
24
semimonthly
Cryptosporidium
samples
for
small
systems.
Although
small
systems
will
not
report
E.
coli
and
Cryptosporidium
results
at
the
same
time,
the
additional
reporting
burden
is
assumed
to
be
negligible.
The
decrease
in
burden
for
small
plants
that
report
E.
coli
but
are
exempt
from
Cryptosporidium
monitoring
is
also
assumed
to
be
negligible.

(
B)
For
plants
serving
up
to
500
people,
the
full
technical
rate
($
24.96/
hour)
was
applied.
For
plants
serving
more
than
500
people,
costs
are
based
on
an
80%/
20%
split
between
technical
and
managerial
($
44.91/
hour)
rates.
Rates
are
based
on
Bureau
of
Labor
Statistics
data.
(
C)
Taken
from
Exhibit
B.
1,
column
I.
ICR
for
LT2ESWTR
Proposal
53
June
2003
Appendix
C
Summary
Exhibits
for
Full
Implementation
of
the
Rule
Exhibit
C.
1
12­
Year
Summary
of
Burden
Associated
with
Implementing
the
LT2ESWTR
Exhibit
C.
2
12­
Year
Summary
of
Cost
Associated
with
Implementing
the
LT2ESWTR
Exhibit
C.
3
Implementation
Timeline
for
the
Stage
2
DBPR
and
LT2ESWTR
ICR
for
LT2ESWTR
Proposal
54
June
2003
Exhibit
C.
1
12­
Year
Summary
of
Burden
Associated
with
Implementing
the
LT2ESWTR
(
Hours)

Activity
Source
Year
1
Year
2
Year
3
Year
4
Year
5
Year
6
Year
7
Year
8
Year
9
Year
10
Year
11
Year
12
CWSs
Start­
up
[
1]
Exhibit
B.
2,
Column
G
11,371
30,776
Assessment
for
Binning
[
2]

E.
coli
Monitoring
Exhibit
B.
4,
Column
N
6,873
13,746
26,264
19,391
Cryptosporidium
Monitoring
Exhibit
B.
5,
Column
I
5,721
11,441
5,721
17,994
Reporting
Exhibit
B.
6,
Column
E
2,640
5,281
9,104
6,464
12,927
Technology
Reporting
[
3]
Exhibit
B.
9,
Column
G
&
Exhibit
10,
Column
E
22,086
22,086
31,930
41,774
41,774
41,774
Disinfection
Benchmarking
[
4]
Exhibit
B.
11,
Column
H
2,824
1,472
Assessment
for
Bin
Reclassification
[
5]

E.
coli
Monitoring
Exhibit
B.
13,
Column
N
4,937
9,875
21,826
16,889
Cryptosporidium
Monitoring
Exhibit
B.
14,
Column
I
4,107
8,213
4,107
Reporting
Exhibit
B.
15,
Column
E
1,895
3,791
7,525
5,630
Yearly
Total
26,605
30,468
71,864
28,678
30,922
1,472
22,086
22,086
42,870
63,653
75,232
64,292
NTNCWSs
Start­
up
[
1]
Exhibit
B.
2,
Column
G
24
4,720
Assessment
for
Binning
[
2]

E.
coli
Monitoring
Exhibit
B.
4,
Column
N
11
22
2,784
2,773
Cryptosporidium
Monitoring
Exhibit
B.
5,
Column
I
10
19
10
2,573
Reporting
Exhibit
B.
6,
Column
E
4
9
929
924
1,848
Technology
Reporting
[
3]
Exhibit
B.
9,
Column
G
103
103
2,198
4,292
4,292
4,292
Disinfection
Benchmarking
[
4]
Exhibit
B.
11,
Column
H
13
180
Assessment
for
Bin
Reclassification
[
5]

E.
coli
Monitoring
Exhibit
B.
13,
Column
N
8
16
2,362
2,354
Cryptosporidium
Monitoring
Exhibit
B.
14,
Column
I
7
14
7
Reporting
Exhibit
B.
15,
Column
E
3
6
788
785
Yearly
Totals
49
51
8,442
3,710
4,422
180
103
103
2,216
4,328
7,449
7,431
ICR
for
LT2ESWTR
Proposal
55
June
2003
TNCWSs
Start­
up
[
1]
Exhibit
B.
2,
Column
G
87
9,963
Assessment
for
B
inning
[
2]

E
.
coli
Monitoring
Exhibit
B.
4,
Column
N
39
79
6,111
6,071
Cryptosporidium
Monitoring
Exhibit
B.
5,
Column
I
34
68
34
5,634
Reporting
Exhibit
B.
6,
Column
E
16
32
2,040
2,024
4,048
Technology
Reporting
[
3]
Exhibit
B.
9,
Column
G
130
130
2,060
3,990
3,990
3,990
Disinfec
tion
B
enchmarking
[
4]
Exhibit
B.
11,
Column
H
17
432
Assessment
for
B
in
Reclassification
[
5]

E
.
coli
Monitoring
Exhibit
B.
13,
Column
N
29
57
5,754
5,725
Cryptosporidium
Monitoring
Exhibit
B.
14,
Column
I
50
100
50
Reporting
Exhibit
B.
15,
Column
E
11
23
1,920
1,908
Ye
a
rly
Tota
ls
176
179
18,148
8,113
9,682
432
130
130
2,150
4,170
11,714
11,624
Sta
tes
a
nd
Territories
Start­
up
[
6]
Exhibit
B.
3,
Column
C
45,267
185,925
Bin
Determination
and
Reviewing
Monitoring
Data[
7]
Exhibit
B.
7,
Column
F
(
Initial)
&
Column
H
(
Future)
50,388
50,388
77,064
13,338
26,676
51,870
38,532
Technology
Reporting
[
8]
Exhibit
B.
8,
Column
G
3,720
3,720
6,031
8,343
8,343
8,343
Disinfec
tion
B
enchmarking
[
9]
Exhibit
B.
12,
Column
H
1,427
1042
Ye
a
rly
Tota
ls
45,267
0
236,313
51,815
77,064
1,042
3,720
3,720
19,369
35,019
60,213
46,875
Grand
Tota
ls
72,098
30,698
334,767
92,315
122,089
3,127
26,039
26,039
66,605
107,170
154,608
130,222
Notes
:

(
1)
Rule
s
tart­
up:
All
activities
for
m
edium/
large
s
ystems
will
oc
cur
in
Year
1.
Small
sy
stems
will
complete
rule
s
tart­
up
activities
in
Year
3.

(
9)
S
tate
activities
will
parallel
system
activities.

(
8)
S
tate
activities
will
parallel
system
activities.

(
3)
M
edium
and
large
sy
stems
m
ust
begin
to
demons
trate
compliance
with
tec
hnologies
within
72
months
(
6
years)
after
promulgation.
Small
sy
stems
must
begin
to
demons
trate
compliance
within
102
m
onths
(
8.5
years
)
after
promulgation.

(
2)
A
ss
essments
for
binning:
medium/
large
sy
stems
will
begin
E.
coli
and
Cryptosporidium
m
onitoring
in
Year
1,
6
months
after
rule
promulgation.

This
monitoring
will
be
completed
24
months
later,
in
Y
ear
3.
Small
systems
will
begin
1
year
of
E.
coli
monitoring
6
months
into
Year
3;
small
sy
stems
that
are
triggered
into
Cryptosporidium
monitoring
will
begin
this
6
months
into
Year
5.

(
5)
A
ss
essments
for
re­
binning:
A
sec
ond
round
of
E.
coli
and
Cryptosporidium
monitoring
for
re­
binning
will
tak
e
plac
e
starting
6
years
after
the
completion
of
initial
m
onitoring.

(
6)
S
tate
rule
s
tart­
up
activities:
S
tate
ac
tivities
will
parallel
s
ystem
activities.
Thus
,
20
perc
ent
(
the
relative
proportion
of
sys
tems
that
are
large/
medium­
s
ized)
of
this
work
will
be
done
in
Year
1,
as
these
s
ystems
do
rule
training,
and
the
remaining
80
perc
ent
will
be
done
in
Y
ears
3
and
4.

(
7)
EPA
will
perform
these
activities
for
medium
and
large
sy
stems
;
S
tates
will
perform
these
activities
for
small
systems
while
small
systems
monitor,
in
Year
5.

(
4)
M
edium
and
large
sy
stems
m
ust
complete
disinfection
profiling
36
months
after
promulgation;
small
sys
tems
must
complete
profiling
by
66
months
(
5.5
years
)
after
promulgation
(
some
small
sy
stems
are
required
to
complete
profiling
within
54
months
(
4.5
years)
based
on
disinfection
by
product
levels
,
however,
for
s
implicity
all
small
sys
tems
are
assumed
to
meet
the
66
month
deadline).
The
burden
for
profiling
is
assumed
to
be
negligible;
however,
sometime
after
the
profiling
deadline,
systems
mus
t
prepare
a
report
and
consult
with
the
state
regarding
proposed
c
hanges
in
disinfection.
Exhibit
C.
1
12­
Year
Summary
of
Burden
Associated
with
Implementing
the
LT2ESWTR
(
Hours)
(
continued)
ICR
for
LT2ESWTR
Proposal
56
June
2003
Exhibit
C.
2
12­
Year
Summary
of
Cost
Associated
with
Implementing
the
LT2ESWTR
Activity
Source
Year
1
Year
2
Year
3
Year
4
Year
5
Year
6
Year
7
Year
8
Year
9
Year
10
Year
11
CWSs
Start­
up
[
1]
Exhibit
B.
2,
Column
F
$
329,190
$
849,884
Assessment
for
Binning
[
2]

E.
coli
Monitoring
Exhibit
B.
4,
Column
M
390,383
$
780,767
$
3,699,196
$
3,308,813
$

Cryptosporidium
Monitoring
Exhibit
B.
5,
Column
H
6,201,056
$
12,402,113
$
6,201,056
$
19,505,300
$

Reporting
Exhibit
B.
6,
Column
D
76,438
$
152,876
$
255,040
$
178,602
$
357,204
$

Technology
Reporting
[
3]
Exhibit
B.
9,
Column
H
&
Exhibit
B.
10,
Column
F
639,404
$
639,404
$
910,534
$
1,181,665
$
1,181,665
$

Disinfection
Benchmarking
[
4]
Exhibit
B.
11,
Column
I
81,745
$
41,521
$

Assessment
for
Bin
Reclassification
[
5]

E.
coli
Monitoring
Exhibit
B.
13,
Column
279,924
$
559,847
$
3,161,842
$

Cryptosporidium
Monitoring
Exhibit
B.
14,
Column
H
4,451,546
$
8,903,093
$
4,451,546
$

Reporting
Exhibit
B.
15,
Column
D
54,872
$
109,745
$
210,609
$

Yearly
Total
6,997,068
$
13,335,755
$
11,005,177
$
3,569,160
$
19,862,504
$
41,521
$
639,404
$
639,404
$
5,696,877
$
10,754,350
$
9,005,663
$

NTNCWSs
Start­
up
[
1]
Exhibit
B.
2,
Column
F
$
695
$
122,663
Assessment
for
Binning
[
2]

E.
coli
Monitoring
Exhibit
B.
4,
Column
M
708
$
1,416
$
473,843
$
473,134
$

Cryptosporidium
Monitoring
Exhibit
B.
5,
Column
H
10,530
$
21,060
$
10,530
$
2,789,105
$

Reporting
Exhibit
B.
6,
Column
D
130
$
260
$
24,149
$
24,019
$
48,038
$

Technology
Reporting
[
3]
Exhibit
B.
9,
Column
H
2,976
$
2,976
$
57,119
$
111,262
$
111,262
$

Disinfection
Benchmarking
[
4]
Exhibit
B.
11,
Column
I
377
$
4,791
$

Assessment
for
Bin
Reclassification
[
5]

E.
coli
Monitoring
Exhibit
B.
13,
Column
M
503
$
1,006
$
402,198
$

Cryptosporidium
Monitoring
Exhibit
B.
14,
Column
H
7,479
$
14,958
$
7,479
$

Reporting
Exhibit
B.
15,
Column
D
92
$
184
$
20,499
$

Yearly
Totals
12,063
$
22,736
$
631,184
$
497,530
$
2,837,143
$
4,791
$
2,976
$
2,976
$
65,194
$
127,411
$
541,438
$
ICR
for
LT2ESWTR
Proposal
57
June
2003
TNCWSs
Start­
up
[
1]
Exhibit
B.
2,
Column
F
$
2,519
$
252,968
Assessment
for
Binning
[
2]

E.
coli
Monitoring
Exhibit
B.
4,
Column
M
2,488
$
4,976
$
1,038,518
$
1,036,030
$

Cryptosporidium
Monitoring
Exhibit
B.
5,
Column
H
36,990
$
73,980
$
36,990
$
6,107,350
$

Reporting
Exhibit
B.
6,
Column
D
456
$
912
$
51,840
$
51,384
$
102,768
$

Technology
Reporting
[
3]
Exhibit
B.
9,
Column
H
3,759
$
3,759
$
53,131
$
102,503
$
102,503
$

Disinfection
Benchmarking
[
4]
Exhibit
B.
11,
Column
I
500
$
11,068
$

Assessment
for
Bin
Reclassification
[
5]

E.
coli
Monitoring
Exhibit
B.
13,
Column
M
1,804
$
3,607
$
978,771
$

Cryptosporidium
Monitoring
Exhibit
B.
14,
Column
H
54,393
$
108,787
$
54,393
$

Reporting
Exhibit
B.
15,
Column
D
331
$
661
$
48,754
$

Yearly
Totals
42,453
$
79,868
$
1,380,317
$
1,087,914
$
6,210,118
$
11,068
$
3,759
$
3,759
$
109,659
$
215,558
$
1,184,421
$

States
and
Territories
Start­
up
[
6]
Exhibit
B.
3,
Column
D
1,307,768
$
5,371,369
$

Bin
Determination
and
Reviewing
Monitoring
Data
[
7]
Exhibit
B.
7,
Column
H
(
Initial)
&
Column
J
(
Future)
1,455,709
$
1,455,709
$
2,226,379
$
385,335
$
770,670
$
1,498,524
$

Technology
Reporting
[
8]
Exhibit
B.
8,
Column
I
107,467
$
107,467
$
174,244
$
241,022
$
241,022
$

Disinfection
Benchmarking
[
9]
Exhibit
B.
12,
Column
I
41,225
$
30,116
$

Yearly
Totals
1,307,768
$
­

$
6,827,079
$
1,496,935
$
2,226,379
$
30,116
$
107,467
$
107,467
$
559,579
$
1,011,691
$
1,739,546
$

Grand
Totals
8,359,351
$
13,438,359
$
19,843,756
$
6,651,539
$
31,136,144
$
87,497
$
753,606
$
753,606
$
6,431,308
$
12,109,010
$
12,471,068
$

Notes:

(
1)
Rule
start­
up:
All
ac
tivities
for
medium/
large
systems
will
occur
in
Year
1.
Small
systems
will
complete
rule
start­
up
activities
in
Year
3.

(
8)
State
activities
will
parallel
system
activities.

(
9)
State
activities
will
parallel
system
activities.

(
7)
EPA
will
perform
these
activities
for
medium
and
large
systems;
States
will
perform
these
activities
for
small
systems
while
small
systems
monitor,
in
Year
5.

(
4)
Medium
and
large
systems
must
complete
disinfection
profiling
36
months
after
promulgation;
small
systems
must
complete
profiling
by
66
months
(
5.5
years)
after
promulgation
(
some
small
systems
are
required
to
complete
profiling
within
54
months
(
4.5
years)
based
on
disinfection
byproduct
levels,
however,
for
simplicity
all
small
systems
are
assumed
to
meet
the
66
month
deadline).
The
burden
for
profiling
is
assumed
to
be
negligible;
however,
sometime
after
the
profiling
deadline,
systems
must
prepare
a
report
and
consult
with
the
state
regarding
proposed
changes
in
disinfection.

(
2)
Assessments
for
binning:
medium/
large
systems
will
begin
E.
coli
and
Cryptosporidium
monitoring
in
Year
1,
6
months
after
rule
promulgation.
This
monitoring
will
be
completed
24
months
later,
in
Year
3.
Small
systems
will
begin
1
year
of
E.
coli
monitoring
6
months
into
Year
3;
small
systems
that
are
triggered
into
Cryptosporidium
monitoring
will
begin
this
in
Year
5.

(
5)
Assessments
for
re­
binning:
A
second
round
of
E.
coli
and
Cryptosporidium
monitoring
for
re­
binning
will
take
plac
e
starting
6
years
after
completion
of
initial
monitoring.

(
6)
S
tate
rule
start­
up
activities:
State
activities
will
parallel
system
activities.
Thus,
20
percent
(
the
relative
proportion
of
sy
stems
that
are
large/
medium­
sized)
of
this
work
will
be
done
in
Year
1,
as
these
systems
do
rule
training,
and
the
remaining
80
percent
will
be
done
in
Years
3
and
4.

(
3)
Medium
and
large
systems
must
begin
to
demonstrate
compliance
with
technologies
within
72
months
(
6
years)
after
promulgation.
Small
systems
must
begin
to
demonstrate
compliance
within
102
months
(
8.5
years)
after
promulgation.

Exhibit
C.
2
12­
Year
Summary
of
Cost
Associated
with
Implementing
the
LT2ESWTR
(
continued)
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
Final
Rules
Proposed
Rule
State
Primacy
Process
Large
and
Medium
Systems
(
Serving
>
10,000
People)

LT2ESWTR
Requirements
Crypto
Startup
Crypto
Monitoring
Treatment
Installation
Possible
Extens
ions
Bin
Determination
Crypto
&
80/
60
LRAA
Compliance
Stage
2
DBPR
Requirements
Submit
IDSE
Systems
Mus
t
Comply
with
Phase
1
Possible
Extens
ions
Phase
2
Compliance
Crypto
&
Phase
2
Compliance
For
Those
Receiving
Extensions
Small
Systems
(
Serving
<
10,000
People)
Crypto
Monitoring
LT2ESWTR
Requirements
E.
coli
Monitoring
Treatment
Installation
Possible
Extensions
Crypto
Start­
Up
Bin
Determination
Crypto
&
80/
60
LRAA
Compliance
Stage
2
DBPR
Requirements
for
Systems
Conducting
Crypto
Monitoring
Submit
IDSE
Systems
Must
Comply
with
Phase
1
Pos
sible
Extensions
Phas
e
2
Compliance
Crypto
&
80/
60
LRAA
Complianc
For
Those
Receiving
Extensions
Stage
2
DBPR
Requirements
for
Systems
Not
Conducting
Crypto
Monitoring
Submit
IDSE
Systems
Must
Comply
with
Phase
1
Possible
Extensions
Phase
2
Compliance
80/
60
LRAA
Compliance
For
Those
Receiving
Extensions
Exhibit
C.
3
Implementation
Timeline
for
the
Stage
2
DBPR
and
LT2ESWTR
Year
1
Year
2
Year
3
Year
4
Year
5
Year
6
Year
7
Year
8
Year
9
Year
10
Year
11
Year
12
