Information
Collection
Request
for
the
Proposed
Arsenic
in
Drinking
Water
Rule
Prepared
By:
Abt
Associates
Inc.
4800
Montgomery
Lane
Suite
600
Bethesda,
MD
20814
Mr.
John
Bennett
Work
Assignment
Manager
U.
S.
Environmental
Protection
Agency
Office
of
Groundwater
and
Drinking
Water
Washington,
D.
C.

December
2000
TABLE
OF
CONTENTS
1
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
1
1.1
Title
and
Number
of
the
Information
Collection
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
1
1.2
Short
Characterization
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
1
2
NEED
FOR
AND
USE
OF
THE
COLLECTION
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3
2.1
Need/
Authority
for
the
Collection
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3
2.2
Use/
Users
of
the
Data
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3
3
NON­
DUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5
3.1
Non­
duplication
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5
3.2
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5
3.3
Consultations
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5
3.4
Effects
of
Less
Frequent
Collection
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6
3.5
General
Guidelines
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6
3.6
Confidentiality
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6
3.7
Sensitive
Questions
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6
4
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
7
4.1
Respondents
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
7
4.2
Information
Requested
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
7
4.2.1
Data
Items
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
7
4.2.2
Respondent
Activities
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
7
4.2.2.1
Public
Water
System
Activities
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
7
4.2.2.2
State
Activities
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
9
5
THE
INFORMATION
COLLECTEDCAGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
11
5.1
Agency
Activities
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
11
5.2
Collection
Methodology
and
Management
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
11
5.3
Small
Entity
Flexibility
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
11
5.4
Collection
Schedule
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
11
6
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
.
.
.
.
.
.
.
.
.
.
.
.
13
6.1
Respondent
Burden
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
14
6.1.1
Burden
to
Public
Water
Systems
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
14
6.1.2
Burden
to
States
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
16
6.2
Respondent
Costs
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
19
6.2.1
Cost
to
Public
Water
Systems
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
19
6.2.2
Cost
to
States
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
21
6.3
Agency
Burden
And
Cost
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
22
6.4
Respondent
Universe
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
23
6.5
Bottom
Line
Burden
and
Cost
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
24
6.6
Reason
for
Change
in
PWS
Burden
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
25
6.7
Burden
Statement
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
25
LIST
OF
EXHIBITS
Exhibit
5­
1:
Time
Line
for
Implementation
of
Revised
Arsenic
Rule
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
12
Exhibit
6­
1:
Hour
Burden
per
Activity:
Public
Water
Systems
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
14
Exhibit
6­
2:
Annual
Burden
(
2001­
2003):
Public
Water
Systems
(
Hours)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
16
Exhibit
6­
3:
One
Time
Start­
Up
Burden:
States
(
Hours)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
17
Exhibit
6­
4:
Hour
Burden
per
Activity:
States
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
17
Exhibit
6­
5:
Annual
Burden
(
2001­
2003):
States
(
Hours)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
18
Exhibit
6­
6:
Annual
Cost
(
2001­
2003):
Public
Water
Systems
(
Dollars)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
20
Exhibit
6­
7:
Annual
Cost
(
2001­
2003):
States
(
Dollars)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
21
Exhibit
6­
8:
Three­
Year
Burden
(
2001­
2003):
Agency
(
Hours)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
22
Exhibit
6­
9:
Three­
Year
Cost
(
2001­
1003):
Agency
(
Dollars)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
23
Exhibit
6­
10:
Three­
Year
Burden
(
2001­
2003):
All
Respondents
(
Hours)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
23
Exhibit
6­
11:
Three­
Year
Cost
(
2001­
2003):
All
Respondents
(
Dollars)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
24
Exhibit
6­
12:
Bottom
Line
Burden
and
Cost
(
2001­
2003)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
24
1
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1.1
Title
and
Number
of
the
Information
Collection
Title:
Information
Collection
Request
for
the
Proposed
Arsenic
in
Drinking
Water
Rule
1.2
Short
Characterization
The
1996
Safe
Drinking
Water
Act
(
SDWA)
Amendments
require
that
the
Environmental
Protection
Agency
(
EPA
or
the
Agency)
revises,
under
Section
1412(
b)(
12)(
A),
the
existing
drinking
water
standards
for
arsenic:

The
Administrator
shall
propose
a
national
primary
drinking
water
regulation
for
arsenic
not
later
than
January
1,
2000
.
.
.
and
not
later
than
January
1,
2001,
after
notice
and
opportunity
for
public
comment,
the
Administrator
shall
promulgate
a
national
primary
drinking
water
regulation
for
arsenic.

As
a
result
of
this
mandate,
both
the
designated
Maximum
Contaminant
Level
(
MCL)
and
the
monitoring
requirements
for
arsenic
have
been
revised.
The
monitoring
schedule
now
follows
the
Standardized
Monitoring
Framework
(
SMF)
and
the
MCL
has
been
reduced
from
50
µ
g/
L
to
10
µ
g/
L.

Arsenic
is
an
element
that
occurs
in
the
earth's
crust.
Therefore,
there
are
natural
sources
of
exposure,
including
weathering
of
rocks
and
erosion
depositing
arsenic
in
water
bodies
and
uptake
of
the
metal
by
animals
and
plants.
Consumption
of
food
and
water
are
the
major
sources
of
arsenic
exposure
for
the
majority
of
U.
S.
citizens.
People
may
also
be
exposed
from
industrial
sources,
as
arsenic
is
used
in
semiconductor
manufacturing,
petroleum
refining,
wood
preservatives,
animal
feed
additives
and
herbicides.

In
1996,
EPA
commissioned
the
National
Research
Council
(
NRC)
of
the
National
Academy
of
Sciences
(
NAS)
to
review
the
current
state
of
the
science
for
estimating
risks
associated
with
arsenic
in
drinking
water.
Based
on
recent
research
findings
and
data,
NAS's
report
recommended
lowering
the
current
drinking
water
standard
of
50
micrograms
per
liter
(
ug/
L;
equivalent
to
parts
per
billion
(
ppb))
drinking
water
standard.
This
revision
to
the
MCL
was
recommended
as
a
measure
to
protect
human
health.

The
Revised
Arsenic
Rule
Regulatory
Impact
Analysis
contains
detailed
descriptions
of
the
possible
health
effects
that
may
result
from
exposure
to
arsenic
in
public
drinking
water
supplies.
EPA
expected
the
NRC
to
recommend
lowering
the
MCL
and
was
prepared,
with
the
NRC
report
providing
the
needed
update
to
the
science,
to
revise
the
current
MCL.
1
The
estimated
difference
was
determined
through
use
of
occurrence
data
and
EPA's
SafeWater
XL
computer
model.

2
The
proposed
revisions
will
reduce
the
current
arsenic
maximum
contaminant
level
(
MCL)
for
Community
Water
Systems
(
CWSs)
from
50
µ
g/
L
to
10
µ
g/
L.
As
a
result,
more
systems
will
be
in
violation
under
the
new
MCL
than
under
the
previous
MCL.
1
This
revision
will
affect
the
final
cost
of
the
rule
and
its
cost
relative
to
the
existing
standard.
In
addition
to
a
change
in
the
MCL,
the
current
monitoring
requirements
for
arsenic
(
40
CFR
141.23
(
l))
will
be
changed
to
the
SMF
(
40
CFR
141.23
(
c)).
Detailed
differences
between
the
two
monitoring
requirements
are
discussed
in
4
(
b)(
ii)(
1).
Two
general
distinctions
between
the
monitoring
scenarios
are
the
timing
of
triggered
sampling
and
the
granting
of
waivers.
Particularly,
a
change
in
the
use
of
waivers
has
a
substantial
impact
on
the
difference
in
cost
between
the
two
requirements.

Finally,
the
monitoring
requirements
of
the
revised
rule
would
apply
to
non­
transient
noncommunity
water
systems
(
NTNCWS);
currently
only
CWSs
are
required
to
monitor
for
arsenic.
Although
this
change
will
cause
the
overall
cost
of
the
rule
to
increase,
the
expansion
of
the
rule
will
ensure
more
extensive
public
health
protection
to
a
larger
segment
of
the
population.
Throughout
this
document,
public
water
systems
(
PWSs)
will
refer
to
both
CWSs
and
NTNCWSs,
unless
otherwise
noted.

This
Information
Collection
Request
(
ICR)
provides
burden
and
cost
estimates
for
the
revised
Arsenic
Rule.
Monitoring,
reporting,
record
keeping
costs,
enforcement
costs,
burden,
and
net
burden
are
all
evaluated
for
the
three­
year
period
beginning
at
the
promulgation
of
the
rule
on
January
1,
2001.
3
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2.1
Need/
Authority
for
the
Collection
EPA
is
required
to
establish
an
MCL
for
contaminants
that
are
commonly
found
in
drinking
water
supplies
and
which
may
pose
a
threat
to
human
health.
The
1996
Safe
Drinking
Water
Act
(
SDWA)
Amendments
mandated
that
by
January
1,
2000,
EPA
must
have
established
an
updated
MCL
for
arsenic.
In
order
to
maintain
this
standard
and
ensure
that
the
levels
of
arsenic
in
drinking
water
are
consistently
below
the
MCL,
EPA
instituted
a
monitoring
requirement,
as
described
in
Primary
Drinking
Water
Regulations,
40
CFR
141.23
(
c).

Monitoring
by
water
systems
involves
sampling
sources,
recording
results,
and
reporting
results
to
the
State.
Mandatory
PWS
monitoring
and
primacy
regulations
allow
States
to
oversee
the
water
quality
being
provided
by
the
systems
and
perform
necessary
enforcement
actions
against
those
systems
not
in
compliance.
Without
mandatory
monitoring,
EPA
would
not
be
able
to
guarantee
that
all
systems
are
either
in
compliance
with
current
standards
or
are
in
the
process
of
complying.
Also,
the
information
generated
as
a
result
of
monitoring
is
a
necessary
component
of
future
rule
development.
Specifically,
monitoring
results
indicate
the
efficacy
of
treatment
and
the
overall
quality
of
the
water
being
delivered
to
customers.

2.2
Use/
Users
of
the
Data
Monitoring
is
the
first
step
in
a
process
that
is
in
place
to
protect
the
nation's
drinking
water
from
harmful
contaminants.
The
primary
use
of
data
collected
during
monitoring
is
to
verify
compliance
with
the
designated
MCL.
Regular
sampling,
as
dictated
by
the
statute,
ensures
that
the
water
delivered
to
customers
is
consistently
safe.
In
cases
where
violations
are
detected,
prompt
reporting
allows
States
to
issue
violations
and
begin
the
process
of
public
notification.

In
order
to
estimate
current
and
future
compliance
costs
and
benefits,
EPA
needs
an
estimate
of
the
national
distribution
of
arsenic
concentrations
in
water
systems,
the
range
of
arsenic
within
systems
with
multiple
entry
points,
and
the
number
of
systems
with
at
least
one
site
above
the
proposed
standard.
Data
derived
from
compliance
monitoring
is
a
better
source
of
information
than
that
collected
by
EPA
or
utility
industry
national
surveys.
Therefore,
the
continued
collection
of
sampling
data
is
critical
for
accurate
and
reliable
occurrence
analysis.

Occurrence
information
collected
during
monitoring
can
contribute
to
health
studies.
The
effects
of
exposure
to
arsenic
in
drinking
water
is
still
a
subject
of
intense
research.
Government
and
private
sector
researchers
can
use
occurrence
information
combined
with
data
from
third­
party
sources
to
determine
the
short
and
long­
term
health
effects
of
arsenic
exposure.
4
Occurrence
information
can
also
assist
the
general
public.
The
public
is
entitled
to
access
information
regarding
the
quality
of
water
in
their
community.
When
data
are
reported
to
the
States
and
recorded
in
the
Safe
Drinking
Water
Information
System
(
SDWIS)
database,
the
information
becomes
accessible
to
the
public.
Only
with
mandatory
monitoring
can
the
Agency
guarantee
that
information
on
water
quality
is
available
to
all
citizens.
5
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3.1
Nonduplication
EPA
has
examined
the
possible
data
sources
that
may
also
contain
the
information
required
in
this
information
collection
and
has
found
that
it
is
not
available.

3.2
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
EPA
requested
public
comment
on
this
ICR
document
for
a
period
of
60
days
prior
to
its
submission
to
the
Office
of
Management
and
Budget
(
OMB).
The
public
was
able
to
review
this
ICR
in
the
Federal
Register,
as
required
by
the
1995
Amendments
to
the
Paperwork
Reduction
Act.
Comments
were
reviewed
by
the
Agency
and
incorporated
into
the
final
document
as
necessary.

3.3
Consultations
During
the
entire
rulemaking
process,
EPA
solicited
written
comment
from
interested
and
affected
parties.
In
addition,
several
stakeholder
meetings
were
held
at
locations
across
the
country,
with
the
intent
of
collecting
input
from
those
directly
affected
by
the
revisions
to
the
arsenic
MCL
and
to
the
monitoring
requirements.
Stakeholder
meetings
helped
to
refocus
priorities
in
the
drinking
water
program
and
improve
relationships
among
EPA,
States,
Tribes,
local
governments,
water
utilities,
and
the
public.
The
Agency
held
four
stakeholder
meetings
to
discuss
revisions
to
the
proposed
arsenic
rule:

$
September
11­
12,
1997
­
Washington,
DC;

$
February
25,
1998
­
San
Antonio,
Texas,
following
a
two­
day
American
Water
Works
Association
(
AWWA)
workshop
on
inorganics;

$
May
5,
1998
­
Monterey,
California,
prior
to
the
semi­
annual
Association
of
California
Water
Agencies
(
ACWA)
meeting;

$
June
2­
3,
1999
­
Washington,
DC
(
including
a
half­
day
conference
call).

The
meeting
formats
included
presentation
of
information,
questions
and
answers,
and
open
discussion.
Topics
of
particular
interest
to
the
stakeholders
were
the
following:
the
inclusion
of
waivers
in
the
new
monitoring
schedule,
the
cost
of
detection
methods,
and
small
system
capital
extensions.
For
example,
at
the
June
2
to
June
3
meeting,
stakeholders
expressed
their
support
of
the
two­
year
capital
extension
to
small
systems.
The
capital
extension
allows
small
systems
additional
time
to
collect
the
resources
needed
to
comply
with
the
new
standards.
6
In
addition
to
stakeholder
meetings,
EPA
also
participated
in
association
meetings,
utilized
the
Agency
website,
contributed
to
trade
newsletters,
and
maintained
mailing
lists
as
methods
for
increasing
communication.

3.4
Effects
of
Less
Frequent
Collection
EPA
determined
that
data
collection
that
is
less
frequent
than
established
in
the
SMF
may
fail
to
identify,
in
a
timely
manner,
significant
contaminant
concentrations
that
may
threaten
the
health
and
safety
of
drinking
water
consumers.
EPA
considered
alternatives
for
a
wide
range
of
frequency
and
burden
estimates
for
data
collection.
Among
these
alternatives,
the
Agency
selected
the
least
burdensome
approach
that
still
satisfies
its
contaminant
monitoring
objectives.

Under
this
chosen
alternative,
monitoring
waivers
will
reduce
collection
frequency
for
those
systems
that
are
consistently
below
the
MCL.
A
surface
water
system
without
a
waiver
must
monitor
nine
times
during
a
compliance
cycle;
a
system
with
a
waiver,
one
time.
A
groundwater
system
without
a
waiver
must
monitor
three
times
during
a
compliance
cycle;
a
system
with
a
waiver,
one
time.

3.5
General
Guidelines
The
revised
arsenic
rule
complies
with
all
aspects
of
OMB's
general
guidelines
(
5
CFR
1320.
5(
a)(
2))
implemented
under
the
Paperwork
Reduction
Act,
with
two
exceptions:
EPA
requires
systems
in
violation
of
primary
drinking
water
regulations
to
report
information
to
the
State
within
48
hours
of
detecting
the
violation
(
40
CFR,
Section
141.31).
This
requirement
is
necessary
to
allow
systems
and
States
to
respond
quickly
to
situations
that
may
pose
public
health
risks.
Additionally,
chemical
analyses
records
must
be
maintained
for
at
least
10
years
by
40
CFR,
Section
141.33.
Such
information
is
also
critical
to
protect
public
health
and
evaluate
water
treatment
effectiveness.

3.6
Confidentiality
No
confidential
information
will
be
collected
for
purposes
of
this
ICR.

3.7
Sensitive
Questions
No
information
of
a
sensitive
nature
will
be
collected
as
a
result
of
this
ICR.
7
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4.1
Respondents
The
primary
respondents
to
the
revised
arsenic
rule
include
owners/
operators
of
PWSs
and
States.
The
owners/
operators
of
PWSs
are
responsible
for
collecting
the
original
information
and
reporting
it
to
the
States,
which
must
keep
records
of
the
PWS
results
and
report
to
the
Agency.

The
Standard
Industrial
Classification
(
SIC)
for
investor­
owned
water
systems
is
4941.
The
SIC
for
both
PWSs
and
State
agencies
is
9511
(
Air
and
Water
Resources,
and
Solid
Waste
Management).

4.2
Information
Requested
Sections
4(
b)(
I)
and
4(
b)(
ii)
describe
the
information
collected
by
each
group
of
respondents.

4.2.1
Data
Items
The
recordkeeping
requirements
state
that
records
must
be
retained
for
at
least
ten
years.
Systems
must
report
all
the
information
described
in
this
section
for
all
arsenic
samples
within
the
first
10
days
following
the
end
of
each
applicable
monitoring
period.
They
must
also
notify
states
within
48
hours
if
they
fail
to
comply
with
the
designated
MCL
or
the
monitoring
requirements.
Finally,
copies
of
each
public
notification
must
be
sent
to
the
State
within
10
days
of
completion.
These
requirements
are
the
same
as
the
under
the
previous
rule
(
40
CFR
141.3,
40
CFR
141.31).

4.2.2
Respondent
Activities
The
activities
required
of
the
public
water
systems
and
States
are
described
in
detail
in
the
sections
below.

4.2.2.1
Public
Water
System
Activities
Monitoring
Requirements
The
Safe
Drinking
Water
Act
(
SDWA),
as
amended
in
1986,
requires
EPA
to
propose
new
arsenic
standards
by
January
1,
2000,
and
promulgate
the
rule
by
January
1,
2001.
EPA
proposed
that
CWSs
and
NTNCWSs
follow
the
monitoring
schedule
defined
in
40
CFR
141.23
(
c),
also
referred
to
as
the
Standard
Monitoring
Framework
(
SMF).
The
SMF
is
conducted
within
the
schedule
of
a
nine­
year
compliance
cycle.
The
compliance
cycle
is
subsequently
composed
of
three,
three­
year
compliance
periods.

The
SDWA
mandates
that
systems
must
take
one
sample
at
each
designated
sampling
point
during
the
initial
compliance
period
following
the
promulgation
of
the
rule.
However,
systems
8
serving
fewer
than
10,000
people
may
be
granted
an
additional
two
years
to
comply
with
the
regulation.

The
first
round
of
triggered
monitoring
will
begin
three
years
after
promulgation,
in
2004.
All
groundwater
and
surface
water
systems
serving
over
10,000
people
are
required
to
complete
the
initial
round
of
monitoring
by
December
31,
2004.
Surface
water
systems
serving
fewer
than
10,000
people
will
have
until
December
31,
2006,
to
complete
initial
monitoring,
and
groundwater
systems
serving
fewer
than
10,000
people
will
have
until
December
31,
2007,
to
complete
the
initial
monitoring.
The
new
requirements
will
require
NTNCWSs
to
follow
the
same
monitoring
regimen
as
CWSs.

Routine
sampling
cycles
will
remain
the
same
as
under
the
existing
Arsenic
Rule:
groundwater
systems
must
take
a
sample
at
each
sampling
point
once
every
three
years;
surface
water
systems
must
take
a
sample
at
each
sampling
point
annually.
However,
triggered
monitoring
as
a
result
of
a
violation
differs
from
that
in
the
original
rule:
once
a
violation
has
occurred,
a
system
must
monitor
quarterly
beginning
in
the
next
quarter
after
the
violation
has
occurred.
Only
after
a
system
had
taken
two
consecutive
groundwater
samples
or
four
consecutive
surface
water
samples
and
the
State
has
determined
that
the
system
is
"
reliably
and
consistently"
below
the
MCL
(
40
CFR
141.23
(
c)(
8))
may
the
system
return
to
routine
monitoring.

The
revised
requirements
also
allow
systems
to
receive
nine­
year
monitoring
waivers.
During
the
waiver
period,
a
system
must
take
a
minimum
of
one
sample.
In
order
to
receive
a
waiver,
a
system
must
demonstrate
that
during
the
previous
three
rounds
of
monitoring
all
results
were
less
than
the
current
MCL
and
there
was
adequate
source
protection.
In
the
initial
compliance
period
following
promulgation
of
the
revised
rule,
many
States
may
not
have
sufficient
historic
data
to
grant
waivers.
Before
granting
waivers
a
State
must
wait
until
three
years
of
monitoring
have
occurred
at
a
level
of
detection
sensitive
enough
to
monitor
for
the
current
MCL.

Reporting
Requirements
Reporting
requirements
for
PWSs
under
the
Primary
Drinking
Water
Regulations
are
described
in
40
CFR
141.31(
a).
These
requirements
remain
the
same
as
under
the
existing
Arsenic
Rule.
The
system
must
report
the
sampling
results
to
the
State
within
10
days
following
the
end
of
each
applicable
monitoring
period.
If
laboratory
results
indicate
a
violation,
the
system
must
report
to
the
State
within
48
hours.

Recordkeeping
Requirements
Recordkeeping
is
vital
not
only
to
evaluate
the
long­
term
effectiveness
of
regulation,
but
also
to
9
determine
which
systems
are
eligible
for
compliance
waivers.
Recording
requirements
for
the
proposed
Arsenic
Rule
have
not
changed
from
the
existing
Arsenic
Rule:
States
and
water
systems
are
still
required
to
keep
records
for
10
years
(
40
CFR
141.32).

Public
Notification
The
process
of
public
notification
has
not
changed
under
the
revised
Arsenic
Rule.
All
systems
in
violation
of
the
MCL
must
report
to
the
State
within
48
hours
and
begin
the
process
of
public
notification.
No
burden
estimate
for
public
notification
was
included
in
this
ICR
as
it
will
be
included
in
the
Public
Notification
Rule
ICR
renewal.

Consumer
Confidence
Reports
Any
system
with
levels
of
arsenic
at
5
µ
g/
L
(
half
the
MCL)
or
above
will
need
to
provide
in
their
annual
consumer
confidence
report
information
regarding
arsenic
levels
in
the
source.
The
additional
burden
incurred
as
a
result
of
this
action
will
be
included
in
the
Consumer
Confidence
Report
Rule
ICR
Renewal.

4.2.2.2
State
Activities
Revision
of
the
arsenic
standard
will
result
in
several
new
responsibilities
for
States:
first,
States
will
be
required
to
review
the
rule
in
order
to
revise
State
regulations
accordingly.
States
will
also
be
required
to
complete
a
primacy
revision
application.

States
will
continue
to
act
as
the
primary
oversight
body
for
system
activity.
Many
systems
will
be
out
of
compliance
with
the
new
MCL;
therefore,
there
will
be
an
increase
in
the
number
of
permits
for
the
States
to
review.
States
will
also
need
to
review
treatment
plans
that
may
be
required
to
comply
with
the
revised
MCL.
They
will
also
need
to
ensure
that
systems
have
been
informed
of
the
revised
monitoring
requirements.
Some
systems
will
be
eligible
for
a
two­
year
compliance
extension;
States
will
review
and
grant
these
requests.
When
systems
are
not
in
compliance,
States
will
need
to
issue
violations
and
oversee
the
process
of
public
notification.

A
final
responsibility
of
the
States
will
be
to
maintain
records
of
all
results
reported
by
the
systems.
All
information
collected
at
the
system
level
will
be
recorded
and
reviewed
at
the
State
level.
Because
of
this
requirement,
States
have
a
substantial
administrative
burden.
Some
of
the
records
maintained
by
the
State
may
include
an
inventory
of
PWSs,
site
specific
concentration
levels,
number
of
samples
analyzed,
State
decisions
regarding
extensions,
treatment
in­
place,
enforcement
actions,
and
waivers
granted.
State
record
keeping
requirements
are
detailed
in
40
CFR,
Section
142.14.

States
may
also
be
required
to
submit
information
to
EPA
Headquarters,
as
established
in
40
CFR,
Section
142.15(
a).
In
addition
to
primacy
requirements
and
an
annual
report
updating
EPA
Headquarters
on
the
total
number
of
systems
in
the
State,
EPA
Headquarters
may
request
information
from
States
on
violations,
enforcement
actions,
and
waivers.
10
2SDWIS
is
a
comprehensive
data
of
SDWA
violations
and
compliance
information.

11
5.
THE
INFORMATION
COLLECTED
­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY
AND
INFORMATION
MANAGEMENT
5.1
Agency
Activities
The
primary
role
of
the
Agency
is
oversight
and
data
maintenance.
The
Agency
uses
the
collected
information
to
ensure
that
States
are
executing
their
duties
with
respect
to
the
primacy
arrangement.
In
addition,
the
Agency
maintains
the
Safe
Drinking
Water
Information
System
(
SDWIS)
database.
2
5.2
Collection
Methodology
and
Management
The
collection
methodology
and
management
will
not
change
as
a
result
of
the
revised
arsenic
rule.

5.3
Small
Entity
Flexibility
The
1996
Regulatory
Flexibility
Act,
as
incorporated
into
the
1995
Paperwork
Reduction
Act,
requires
that
EPA
considers
the
impact
of
the
Revised
Arsenic
Rule
on
small
entities.
The
Agency
must
consider
regulatory
alternatives
if
the
rule
has
a
significant
economic
impact
on
a
substantial
number
of
small
entities.
In
order
to
assist
small
entities,
States
will
grant
monitoring
waivers
to
systems
that
are
consistently
below
the
MCL.
These
waivers
will
reduce
the
compliance
cost
for
some
small
systems
and
will
decrease
the
number
of
times
of
system
must
conduct
routine
monitoring.
In
addition,
the
monitoring
requirements
still
allow
systems
to
composite
up
to
five
samples.
Compositing
samples
allows
systems
to
reduce
the
laboratory
costs
associated
with
monitoring.

5.4
Collection
Schedule
Under
the
revised
Arsenic
Rule,
promulgated
in
January
2001,
surface
water
systems
will
continue
to
monitor
annually
and
groundwater
systems
will
continue
to
monitor
every
three
years;
however,
when
triggered
by
a
violation,
the
system
will
collect
samples
quarterly
rather
than
collecting
three
additional
samples
in
one
month.

All
surface
water
community
water
systems
must
comply
with
the
Revised
Arsenic
Rule
by
January
1,
2006.
In
order
to
maintain
the
existing
monitoring
schedule,
groundwater
community
water
systems
and
all
non­
transient
non­
community
water
systems
must
comply
by
January
1,
2007.
Exhibit
5­
1
is
a
time
line
for
first
10­
years
of
the
revised
Arsenic
Rule,
beginning
in
the
year
of
promulgation,
2001.
12
Exhibit
5­
1
Time
Line
for
Implementation
of
Revised
Arsenic
Rule
Source/
Year
CWSs
Groundwater
CWSs
Surface
Water
NTNCWSs
All
Sources
2001
Promulgation;
All
Community
Water
Systems
Monitor
2002
Annual
Monitoring
2003
Annual
Monitoring
2004
Triennial
Monitoring
Annual
Monitoring
2005
Annual
Monitoring
2006
Annual
Monitoring;
Triggered
Monitoring;
Apply
for
Waivers
2007
Triennial
Monitoring;
Triggered
Monitoring;
Apply
for
Waivers
Annual
Monitoring
All
Systems
Monitor;
Triggered
Monitoring;
Apply
for
Waivers
2008
Annual
Monitoring
2009
Annual
Monitoring
2010
Triennial
Monitoring
Annual
Monitoring
Triennial
Monitoring
3
Prior
the
effective
date
of
the
revised
Arsenic
Rule,
the
monitoring
requirements
are
based
on
the
current
rule,
not
the
revised
rule.

13
6.
ESTIMATING
THE
BURDEN
AND
THE
COST
OF
THE
COLLECTION
This
ICR
describes
the
"
paperwork"
burden
to
PWSs
and
States
as
a
result
of
the
Revised
Arsenic
Rule.
Because
this
is
a
revised
rule,
the
estimated
burden
and
costs
are
compared
to
the
burden
and
cost
under
the
current
requirements.
The
assumptions
made
in
the
preparation
of
this
document
are
based
on
historic
data,
other
Agency
publications,
and
private
sector
sources.

The
costs
in
this
ICR
are
summarized
for
a
three­
year
time
horizon.
Systems
will
complete
the
initial
round
of
monitoring
under
the
revised
rule
at
some
point
between
2006
and
2007;
as
such,
the
additional
cost
to
these
systems
will
not
be
represented
in
the
ICR
analysis.
3
The
1995
Amendments
to
the
Paperwork
Reduction
Act
have
mandated
what
costs
must
be
considered
in
this
ICR.
The
following
requirements
were
included
in
the
cost
and
burden
calculations
for
the
revised
arsenic
rule
ICR:

$
Recurring
operation
and
maintenance
(
e.
g.
postage,
envelopes,
printing);

$
Initial
start­
up
costs
(
e.
g.
training
operators,
reviewing
rule);

$
Contracted
services
(
e.
g.
laboratory
analysis).

As
a
guide
for
the
preparation
of
this
document,
EPA
reviewed
other
drinking
water
ICRs,
including
rules
that
utilized
the
SMF.
The
ICR
for
the
Public
Water
System
Supervision
Program
contained
many
assumptions
that
were
adopted
by
this
document.

The
number
of
systems
and
sites
expected
to
be
in
violation
of
the
proposed
MCL
across
CWSs
(
except
those
serving
over
one
million
people)
was
estimated
using
SafeWater
XL,
a
Monte­
Carlo
simulation
model
developed
in
Microsoft
Excel
©
using
the
Crystal
Ball
©
Monte­
Carlo
simulation
add­
in.
SafeWater
XL
forecasts
a
distribution
of
costs
around
the
mean
compliance
cost
expected
for
each
system
size
category.

OMB
approves
Information
Collection
Requests
for
a
maximum
three­
year
period.
For
this
reason,
EPA
has
provided
the
expected
impact
of
the
rule
on
PWSs
during
the
first
three
years
after
promulgation
of
the
proposed
rule
(
2001
­
2003).
Since
triggered
monitoring
will
not
begin
during
the
three­
year
period,
the
only
additional
burden
that
PWSs,
States,
and
the
Agency
will
incur
is
an
initial
one­
time
start
up
cost.
The
annual
hour
burden
and
cost
are
provided
as
well.
Appendix
D
provides
a
detailed
description
of
the
calculations
used
to
determine
costs
and
burden.

6.1
Respondent
Burden
14
The
burden
for
PWSs
and
States
are
determined
separately
in
the
sections
below.
The
cost
of
monitoring
and
reporting
are
included
in
the
cost
and
burden
calculations.

6.1.1
Burden
to
PWSs
Start­
Up
Burden
There
are
several
start­
up
activities
that
PWSs
must
perform
in
order
to
comply
with
the
revised
Arsenic
Rule.
Start­
up
activities
include
reading
the
final
rule
to
become
familiar
with
the
requirements
and
training
staff
to
perform
the
required
activities.
The
number
of
hours
required
to
perform
these
activities
varies
by
system
size.
The
total
start­
up
burden
per
system
for
systems
serving
fewer
or
equal
to
10,000
people
is
approximately
24
hours;
the
total
start­
up
burden
per
system
for
systems
serving
more
than
10,000
people
is
approximately
40
hours.
The
Agency
assumes
that
PWSs
have
all
the
necessary
materials
to
perform
monitoring
under
the
revised
rule:
therefore,
capital
costs
are
not
included
in
the
start­
up
costs.

Monitoring
Burden
For
those
activities
present
under
both
the
revised
and
the
existing
rule,
the
hour
burden
per
activity
is
the
same;
however,
not
all
respondent
activities
are
consistent
across
the
two
rules.
For
example,
systems
may
apply
for
waivers
under
the
revised
rule
but
not
under
the
existing
rule.

Exhibit
6­
1
lists
the
activities
and
corresponding
burden
required
by
the
revised
and
existing
rule.
Hourly
estimates
are
based
on
previous
Agency
ICRs.

Exhibit
6­
1
Hour
Burden
per
Activity
Public
Water
Systems
PWS
Activity
Number
of
Hours
Apply
for
Waiver
16
Take
Single
Sample
1
Report
Results
1
The
following
assumptions
were
made
when
computing
the
burden
to
PWSs:


Any
exceedance
of
the
MCL
will
occur
in
the
initial
round
of
monitoring.
After
the
initial
round
of
monitoring,
all
systems
are
assumed
to
be
in
compliance.
As
a
4See
Appendix
B
for
a
detailed
description
of
how
the
number
of
systems
eligible
for
waivers
was
derived.

15
Community
Water
Systems
2001
2002
2003
3­
year
Average
Current
Monitoring
144,010
21,494
21,494
62,333
Proposed
Start­
Up
1,361,664
0
0
453,888
Proposed
Monitoring
144,010
21,494
21,494
62,333
Net
Change
1,361,664
­
­
453,888
Non­
Transient
Non­
Community
Water
Systems
2001
2002
2003
3­
year
Average
Current
Monitoring
0
0
0
0
Proposed
Start­
Up
486,120
0
0
162,040
Proposed
Monitoring
0
0
0
0
Net
Change
486,120
­
­
162,040
Exhibit
6­
2
Annual
Burden
(
2001­
2003)
PWSs
(
Hours)
result,
triggered
monitoring
will
only
occur
in
one
year;
the
year
of
triggered
monitoring
will
depend
on
system
size
and
source
water.


Every
system
that
exceeds
the
designated
MCL
will
complete
three
rounds
of
quarterly
monitoring.


Routine
monitoring
occurs
triennially
for
groundwater
systems
and
non­
transient
non­
community
systems,
and
annually
for
surface
water
systems,
except
for
those
systems
that
have
received
monitoring
waivers.


The
number
of
systems
eligible
for
monitoring
waivers
is
based
on
data
from
20
states
that
currently
collect
occurrence
information
below
10
µ
g/
L.
These
states
provide
an
estimate
of
the
percentage
of
systems
that
would
be
eligible
for
waivers
under
the
proposed
MCLs.
This
percentage
is
then
multiplied
by
the
total
number
of
systems
that
do
not
exceed
the
MCL.
Finally,
in
order
to
weight
the
result
to
reflect
the
number
of
systems
that
would
be
eligible
for
waivers,
the
result
of
the
previous
calculation
is
multiplied
by
the
percentage
of
States
that
have
sufficient
data
to
grant
waivers
(
40%).
4
This
ICR
evaluates
the
first
three
years
after
promulgation.
However,
yearly
net
burden
for
the
first
20
years
following
promulgation
are
provided
in
Exhibit
C­
1
in
Appendix
C.
Exhibit
6­
2
provides
the
average
three­
year
annual
hour
burden
for
PWS
using
the
hourly
burden
assumption
in
Exhibit
6­
1
and
the
system
assumptions
from
the
Safewater
XL
model.
16
6.1.2
Burden
to
States
There
are
an
estimated
56
States
and
primacy
agencies
(
including
tribal
lands)
that
will
be
affected
by
the
revised
Arsenic
Rule.
The
two
primary
proposed
changes
in
the
Arsenic
Rule,
decreasing
the
MCL
and
revising
the
monitoring
requirements,
will
both
increase
State
burden
in
the
year
the
rule
becomes
effective.
State
burden
is
dependent
on
the
number
of
systems
that
either
exceed
the
MCL,
are
in
compliance
with
the
MCL,
or
are
eligible
for
waivers.

Start­
Up
Burden
The
start­
up
burden
per
State
include
reviewing
the
Revised
Arsenic
Rule
and
training
staff,
both
at
the
State­
level
and
system­
level.
These
activities
are
defined
by
the
number
of
Full­
Time
Equivalents
(
FTEs).
Exhibit
6­
3
also
shows
the
total
number
of
hours
per
State,
which
is
equal
to
the
number
of
FTEs
multiplied
by
2,080
(
the
number
of
working
hours
in
a
year).
17
Exhibit
6­
3
One
Time
Start­
Up
Burden
States
Administrative
Activity
Estimated
Resources
per
State
(
FTE)
Hours
per
State
Revise
Regulation
for
New
MCL
0.2
416
System
Training
and
Technical
Assistance
(
CWS)
0.5
1,040
System
Training
and
Technical
Assistance
(
NTNC)
0.5
1,040
Staff
Training
0.12
250
Monitoring
Burden
State
burden
for
issuing
permits
will
increase
in
the
first
year
of
triggered
monitoring
because
more
systems
will
be
out
of
compliance
and
will
be
required
to
submit
a
new
treatment
plan
as
a
result
of
the
lower
MCL.
Under
the
proposed
monitoring
requirements,
systems
may
submit
waiver
applications,
thus
adding
to
the
States'
activities
and
burden.
Exhibit
6­
4
lists
the
individual
activities
and
corresponding
burden
required
by
the
revised
and
existing
rule.
Hourly
estimates
are
based
on
previous
Agency
ICRs.

Exhibit
6­
4
Hour
Burden
per
Activity
States
PWS
Activity
Number
of
Hours
<
10,000
people
>
10,000
people
Review
Waiver
Application
8
8
Record
Monitoring
of
a
Single
Sample
1
1
Review
a
Single
Permit
16
32
Exhibit
6­
5
documents
the
average
three­
year
annual
hour
burden
to
states
for
each
of
the
regulatory
scenarios
investigated.
18
2001
2002
2003
3­
Year
Average
Current
Monitoring
72,005
10,747
10,747
31,166
Proposed
Start­
Up
153,754
0
0
51,251
Proposed
Monitoring
72,005
10,747
10,747
31,166
Net
Change
153,754
0
0
51,251
Exhibit
6­
5
Annual
Burden
(
2001­
2003)
States
(
Hours)
19
6.2
Respondent
Costs
PWS
and
State
costs
are
based
on
the
difference
between
the
cost
of
the
proposed
Arsenic
Rule
and
the
current
Arsenic
Rule.

6.2.1
Cost
to
PWSs
Start­
Up
Costs
All
PWS's
start­
up
activities,
which
include
reading
the
final
rule
to
become
familiar
with
the
requirements
and
training
staff
to
perform
the
required
activities,
are
performed
at
an
hourly
rate
of
$
15.03
for
systems
serving
fewer
than
10,000
people
and
$
29.03
for
systems
serving
more
than
10,000
people.

Monitoring
Costs
The
Agency
applied
an
average
labor
rate
that
is
dependant
on
system
size
and
respondent
activity.
The
descriptions
listed
below
detail
the
components
of
the
cost
to
PWSs.
Not
all
costs
are
incurred
by
all
systems
or
at
the
same
frequency.
In
the
cost
calculations,
labor
rates
are
the
same
for
the
revised
and
existing
rule.

$
Sample
Collection
and
Reporting.
The
Agency
assumes
the
hourly
rate
for
labor
activities
directly
related
to
sample
collection
and
reporting
the
results
of
the
samples
to
the
State
is
$
15.03
for
systems
serving
fewer
or
equal
to
3,300
people
and
$
29.03
for
systems
serving
more
than
3,300
people.
These
rates
are
based
on
assumptions
in
the
July
1997
Public
Water
System
Supervision
Program
ICR,
escalated
to
May
1999
dollars
using
the
Bureau
of
Labor
Statistics
Consumer
Price
Index
(
CPI).

$
Waiver
Application.
The
hourly
labor
rate
for
individuals
applying
for
a
waiver
is
also
derived
from
the
July
1997
Public
Water
System
Supervision
Program
ICR,
escalated
to
May
1999
dollars.
The
rate
for
completing
a
waiver
application
is
$
15.03
for
systems
serving
fewer
or
equal
to
3,300
people
and
$
29.03
for
systems
serving
more
than
3,300
people.

In
addition
to
the
labor
costs,
the
average
annual
cost
of
the
revised
Arsenic
Rule
monitoring
requirements
includes
the
cost
of
analyzing
and
mailing
samples.
The
Agency
has
approved
several
analytical
methods
to
support
compliance
monitoring
of
arsenic.
The
two
methods
that
will
be
most
commonly
utilized
are
Stabilized
Temperature
Platform
Graphite
Furnace
Atomic
Absorption
(
STP­
GFAA)
and
Graphite
Furnace
Atomic
Absorption
(
GFAA).
Both
methods
have
an
estimated
cost
of
$
40.

Total
laboratory
analysis
cost
is
estimated
as
$
47.50
per
sample,
including
$
7.50
shipping
and
20
Community
Water
Systems
2001
2002
2003
3­
year
Average
Current
Monitoring
$
6,008,741
$
945,925
$
945,925
$
2,633,530
Proposed
Start­
Up
$
23,918,292
$
0
$
0
$
7,972,764
Proposed
Monitoring
$
6,008,741
$
945,925
$
945,925
$
2,633,530
Net
Labor
Cost
$
23,918,292
$
0
$
0
$
7,972,764
Net
Non­
Labor
Cost
$
0
$
0
$
0
$
0
Non­
Transient
Non­
Community
Water
Systems
2001
2002
2003
3­
year
Average
Current
Monitoring
$
0
$
0
$
0
$
0
Proposed
Start­
Up
$
7,308,134
$
0
$
0
$
2,436,045
Proposed
Monitoring
$
0
$
0
$
0
$
0
Net
Labor
Cost
$
7,308,134
$
0
$
0
$
2,436,045
Net
Non­
Labor
Cost
$
0
$
0
$
0
$
0
Exhibit
6­
6
Annual
Cost
(
2001­
2003)
PWSs
(
Dollars)
handling.
Exhibit
6­
6
shows
the
annual
net
cost
of
monitoring
under
the
revised
Arsenic
Rule
over
the
three­
year
period
beginning
at
promulgation.
21
2001
2002
2003
3­
Year
Average
Current
Monitoring
$
2,986,191
$
445,700
$
445,700
$
1,292,530
Proposed
Start­
Up
$
4,767,840
$
0
$
0
$
1,589,280
Proposed
Monitoring
$
2,986,191
$
445,700
$
445,700
$
1,292,530
Net
Labor
Cost
$
4,767,840
$
0
$
0
$
1,589,280
Net
Non­
Labor
Cost
$
0
$
0
$
0
$
0
Exhibit
6­
7
Annual
Cost
(
2001­
2003)
States
(
Dollars)
6.2.2
Cost
to
States
Start­
Up
Costs
The
start­
up
costs
per
State
are
based
on
the
number
of
FTEs
needed
to
perform
the
start­
up
duties
(
Exhibit
6­
3).
The
average
rate
per
FTE
is
$
64,500.

Monitoring
Costs
To
determine
the
State
cost
of
the
revised
and
existing
Arsenic
Rule,
the
Agency
applied
an
average
labor
rate
that
is
dependant
on
system
size
and
respondent
activity.
The
descriptions
below
describe
the
components
of
State
rule­
related
cost.
In
the
cost
calculations,
labor
rates
are
the
same
for
the
revised
and
existing
rule.
States
do
not
have
any
non­
labor
costs
(
e.
g.
laboratory
analysis).

$
Record
Monitoring.
The
Agency
assumes
a
$
41.47
hourly
rate
for
labor
activities
directly
related
to
recording
the
results
of
monitoring
of
a
single
sample.
These
rates
are
based
on
assumptions
in
the
July
1997
Public
Water
System
Supervision
Program
ICR,
escalated
to
May
1999
dollars
using
the
Bureau
of
Labor
Statistics
Consumer
Price
Index
(
CPI).

$
Waiver
Application.
The
hourly
labor
rate
for
individuals
reviewing
waiver
applications
is
$
41.47.
This
cost
is
derived
from
the
July
1997
Public
Water
System
Supervision
Program
ICR,
escalated
to
May
1999
dollars.

$
Review
a
Permit.
The
hourly
labor
rate
for
reviewing
a
permit
is
$
41.47.
This
rate
is
derived
from
the
July
1997
Public
Water
System
Supervision
Program
ICR,
escalated
to
May
1999
dollars.
Exhibit
6­
7
lists
the
national
annual
State
costs.
22
6.3
Agency
Burden
and
Costs
Headquarters
and
Regions
incur
costs
when
assisting
States
implement
drinking
water
regulations.
The
Agency's
enforcement
and
compliance
staff
also
incur
costs
throughout
the
monitoring
process.
The
Agency
burden
and
costs
were
calculated
using
assumptions
from
the
PWSS
ICR.

In
the
PWSS
ICR,
the
annual
burden
for
all
contaminants
regulated
was
41,760
hours
at
Headquarters
and
313,200
hours
at
the
Regions.
A
total
of
11
contaminants
were
regulated.
The
calculation
for
one
contaminant,
arsenic,
is
shown
in
Exhibit
6­
8
below:

Exhibit
6­
8
Three­
Year
Burden
(
2001­
2003)
Agency
(
Hours)

Headquarters
Current
Regulations
3,796
Proposed
Regulations
3,796
Net
Change
0
Regions
Current
Regulations
28,473
Proposed
Regulations
28,473
Net
Change
0
The
average
salary
at
Headquarters
is
$
69,008
(
GS
13,
Step
5),
and
the
average
salary
at
the
Regions
is
$
36,696
(
GS
9,
Step
5).
It
is
assumed
that
there
are
2,080
working
hours
per
person
year.
The
calculations
in
Exhibit
6­
9
below
use
the
annual
burden
hours
from
the
PWSS
ICR
multiplied
by
the
average
rate
per
hour,
divided
by
the
number
of
contaminants,
to
estimate
the
cost
for
arsenic.
23
CWS
NTNCWS
State
3­
Year
Average
Current
Regulations
186,998
0
93,499
93,499
Proposed
Regulations
1,548,662
486,120
247,253
760,678
Net
Change
1,361,664
486,120
153,754
667,179
Exhibit
6­
10
Three­
Year
Burden
(
2001­
2003)
All
Respondents
(
Hours)
Exhibit
6­
9
Three­
Year
Cost
(
2001­
2003)
Agency
(
Dollars)

Headquarters
Current
Regulations
$
11,450
Proposed
Regulations
$
11,450
Net
Change
$
0
Regions
Current
Regulations
$
45,666
Proposed
Regulations
$
45,666
Net
Change
$
0
6.4
Respondent
Universe
The
analysis
in
this
ICR
is
based
on
a
respondent
universe
of
74,607
PWSs,
56
States
and
Territories,
and
the
Agency.
NTNCWS
are
included
in
the
total
number
of
PWSs.

6.5
Bottom
Line
Burden
Hours
and
Cost
Exhibits
.
Exhibit
6­
10
is
a
summary
of
the
current
and
proposed
burden
for
all
respondent
groups.
During
the
three­
year
period
discussed
in
this
ICR,
the
only
difference
between
the
current
and
proposed
burden
is
a
result
of
start­
up
costs.
This
effect
is
also
reflected
in
Exhibit
6­
11
for
the
current
and
proposed
costs.

Exhibit
6­
12
summarizes
the
net
cost
across
all
respondent
groups.
Again,
the
net
cost
and
burden
in
all
categories
represents
the
impact
of
start­
up
costs
incurred
in
the
year
of
promulgation.
24
CWS
NTNCWS
State
3­
Year
Average
Current
$
7,900,591
$
0
$
3,877,591
$
3,926,061
Proposed
$
31,818,883
$
7,308,134
$
8,645,431
$
15,924,149
Net
Labor
Cost
$
23,918,292
$
7,308,134
$
4,767,840
$
11,998,088
Net
Non­
Labor
Cost
$
0
$
0
$
0
$
0
Exhibit
6­
11
Three­
Year
Cost
(
2001­
2003)
All
Respondents
(
Dollars)

Respondent
PWSs
States
Total
Total
Respondents
1
74,607
56
74,663
Total
Net
Burden
1,847,784
153,754
2,001,538
Net
Labor
Cost
$
31,226,425
$
4,767,840
$
35,994,265
Net
Non­
Labor
Cost
$
0
$
0
$
0
Average
Burden
per
Year
615,928
51,251
667,179
Average
Labor
Cost
per
Year
$
10,408,808
$
1,589,280
$
11,998,088
Average
Non­
Labor
Cost
per
Year
$
0
$
0
$
0
Average
Number
of
Responses
per
Year
2
49,738
75
49,813
1.
The
total
number
of
PWSs
includes
54,352
CWSs
and
20,255
NTNCs.

2.
Assuming
four
responses
in
year
2001
for
each
state
and
two
responses
in
year
2001
for
each
PWS.
Exhibit
6­
12
Bottom
Line
Burden
and
Cost
(
2001­
2003)
25
6.6
Reason
for
Change
in
PWS
Burden
The
1997
Information
Collection
Request
for
Public
Water
System
Supervision
Program
included
the
cost
of
arsenic
monitoring.
However,
this
ICR
did
not
distinguish
the
cost
of
arsenic
from
the
cost
of
related
contaminants.
For
this
reason,
it
is
not
possible
to
directly
determine
the
change
in
burden.
Instead,
the
description
that
follows
will
note
the
change
in
assumptions
between
the
two
documents.

The
proposed
revisions
to
the
Arsenic
Rule
lower
the
MCL
for
CWSs
from
50
µ
g/
L
to
10
µ
g/
L.
As
a
result
of
the
new
MCL,
more
systems
will
be
out
of
compliance.
This
will
increase
the
number
of
systems
that
must
install
treatment
and
perform
triggered
monitoring.
States
will
need
to
review
an
increased
number
of
permits
and
perform
additional
recordkeeping
as
a
result
of
the
new
MCL.
Both
PWSs
and
States
will
have
an
increased
cost
and
burden
in
the
year
the
rule
is
promulgated
and
becomes
effective.

A
crucial
aspect
of
the
revised
Arsenic
Rule
is
the
change
in
the
monitoring
schedule.
In
this
ICR,
arsenic
follows
the
SMF
as
defined
in
40
CFR
141.23
(
c).
Previously,
arsenic
followed
the
monitoring
schedule
in
40
CFR
141.23
(
l).
As
well
as
changing
the
timing
of
triggered
monitoring,
the
new
monitoring
requirements
allow
systems
to
receive
waivers.
The
waivers
reduce
the
number
of
systems
required
to
conduct
routine
monitoring.

Labor
rates
for
both
PWSs
employees
and
State
employees
are
based
on
rates
used
in
the
1997
Information
Collection
Request
for
Public
Water
System
Supervision
Program.
The
labor
rates
have
been
updated
to
May
1999
dollars
using
the
Bureau
of
Labor
Statistics
Consumer
Price
Index.
Estimates
of
the
number
of
hours
required
per
monitoring
activity
have
been
updated
based
on
a
more
recent
EPA
analysis.

6.7
Burden
Statement
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
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,
Part
9
and
48
CFR,
Chapter
15.
26
Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques
to
the
Director,
Collection
Strategies
Division,
U.
S.
Environmental
Protection
Agency
(
2822),
401
M
St.,
SW,
Washington,
D.
C.
20460;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
and
OMB
control
number
in
any
correspondence.
Appendices
Appendix
A:
Safe
Drinking
Water
Sections
that
Provide
Authority
for
the
Collection
Appendix
B:
Assumptions
Used
to
Develop
ICR
Burdens
and
Costs
for
the
Revised
Arsenic
Rule
Appendix
C:
Annual
Burdens
and
Costs
Estimates
for
Systems
and
States
(
2001­
2020)

Appendix
D:
Detailed
Spreadsheets
from
System
and
State
Burden
and
Costs
Models
Appendix
A:
Safe
Drinking
Water
Sections
that
Provide
Authority
for
the
Collection
Appendix
A
­
1
SEC.
109.
ARSENIC,
SULFATE,
AND
RADON
(
a)
Arsenic
and
Sulfate.­­
Section
1412(
b)
(
42
U.
S.
C.
300g­
1(
b))
is
amended
by
inserting
after
paragraph
(
11)
the
following:
(
12)
Certain
contaminants.­­
(
A)
Arsenic.­­
(
i)
Schedule
and
standard.
­­
Notwithstanding
the
deadlines
set
forth
in
paragraph
(
1),
the
Administrator
shall
promulgate
a
national
primary
drinking
water
regulation
for
arsenic
pursuant
to
this
subsection,
in
accordance
with
the
schedule
established
by
this
paragraph.
(
ii)
Study
plan.
­­
Not
later
than
180
days
after
the
date
of
enactment
of
this
paragraph,
the
Administrator
shall
develop
a
comprehensive
plan
for
study
in
support
of
drinking
water
rulemaking
to
reduce
the
uncertainty
in
assessing
health
risks
associated
with
exposure
to
low
levels
of
arsenic.
In
conducting
such
study,
the
Administrator
shall
consult
with
the
National
Academy
of
Sciences,
other
Federal
agencies,
and
interested
public
and
private
entities.
 
(
iii)
Cooperative
agreements.
­­
In
carrying
out
the
study
plan,
the
Administrator
may
enter
into
cooperative
agreements
with
other
Federal
agencies,
State
and
local
governments,
and
other
interested
public
and
private
entities.
(
iv)
Proposed
regulations.
­­
The
Administrator
shall
propose
a
national
primary
drinking
water
regulation
for
arsenic
not
later
than
January
1,
2000.
(
v)
Final
regulations.
­­
Not
later
than
January
1,
2001,
after
notice
and
opportunity
for
public
comment,
the
Administrator
shall
promulgate
a
national
primary
drinking
water
regulation
for
arsenic.
(
vi)
Authorization.
­­
There
are
authorized
to
be
appropriated
$
2,500,000
for
each
of
fiscal
years
1997
through
2000
for
the
studies
required
by
this
paragraph.
Appendix
A
­
2
Effective
Dates
§
141.6
Effective
dates.

Section
141.6
is
amended
in
paragraph
(
a)
by
revising
the
reference
"
paragraphs
(
a)
through
(
i)"
to
read
"
paragraphs
(
a)
through
(
j)"
and
by
adding
paragraph
(
j))
to
read
as
follows:

(
j)
Regulations
for
compliance
with
the
arsenic
MCL
listed
in
§
141.62
are
effective
for
community
water
systems
serving
10,000
people
or
less
(
insert
date
5
years
after
promulgation
date),
and
for
all
other
community
water
systems
(
insert
date
3
years
after
promulgation
date)
for
the
following
sections:

Section
Topic
or
Subpart
§
141.23(
a)(
4)
Sample
compositing
allowed
by
the
State
141.23(
a)(
4)(
i)
Detection
limit
for
arsenic
141.23(
a)(
5)
Frequency
of
monitoring
for
arsenic
determined
in
§
141.23(
c)
141.23(
c)
Standard
inorganic
monitoring
framework,
with
State
waivers
possible
141.23(
f)(
1)
Confirmation
sampling
may
be
required
by
the
State
141.23(
g)
More
frequent
monitoring
may
be
required
by
the
State
141.23(
i)
Compliance
determination
141.23(
k)(
1)
Approved
methodology
141.23(
k)(
2)
Container,
preservation,
and
holding
time
141.23(
k)(
3)(
ii)
Acceptance
limit
for
certified
laboratories
141.32(
b)(
3)
Public
Notification
other
violations,
variances,
exemptions
141.32(
d)
General
content
of
public
notice
141.62(
b)(
16)
MCL
for
arsenic
141.62(
c)
BATs
for
arsenic
141.153
Subpart
O
Content
of
Consumer
Confidence
Reports
Appendix
A
­
3
Maximum
Contaminant
Levels
§
141.11
Maximum
contaminant
levels
for
inorganic
chemicals.

Section
141.11(
a)
is
amended
by
revising
the
second
sentence
to
read
as
follows:
Compliance
with
the
MCL
for
arsenic
in
§
141.11(
b)
is
calculated
using
§
141.23(
l).

(
a)
The
maximum
contaminant
level
for
arsenic
applies
only
to
community
water
systems.
Compliance
with
the
MCL
for
arsenic
is
calculated
pursuant
to
§
141.23.

Revise
§
141.11(
b)
to
read
as
follows:
The
maximum
contaminant
level
for
arsenic
is
0.05
milligrams
per
liter
for
community
water
systems
serving
10,000
people
or
less
until
(
insert
date
5
years
after
promulgation
date),
and
for
all
other
community
water
systems
until
(
insert
date
3
years
after
promulgation
date).

(
b)
The
maximum
contaminant
level
for
arsenic
is
0.05
milligrams
per
liter.

(
c)
[
Reserved]
(
d)
At
the
discretion
of
the
State,
nitrate
levels
not
to
exceed
20
mg/
l
may
be
allowed
in
a
noncommunity
water
system
if
the
supplier
of
water
demonstrates
to
the
satisfaction
of
the
State
that:
(
1)
Such
water
will
not
be
available
to
children
under
6
months
of
age;
and
(
2)
There
will
be
continuous
posting
of
the
fact
that
nitrate
levels
exceed
10
mg/
l
and
the
potential
health
effects
of
exposure;
and
(
3)
Local
and
State
public
health
authorities
will
be
notified
annually
of
nitrate
levels
that
exceed
10
mg/
l;
and
(
4)
No
adverse
health
effects
shall
result.

[
40
FR
59570,
Dec.
24,
1975,
as
amended
at
45FR
57342,
Aug.
27,
1980;
47
FR
10998,
Mar.
12,
1982;
51
FR
11410,
Apr.
2,
1986;
56
FR
3578,
Jan.
30,
1991;
56
FR
26548,
June
7,
1991;
56
FR
30274,
July
1,
1991;
56
FR
32113,
July
15,
1991;
60
FR
33932,
June
29,
1995]
Appendix
A
­
4
Routine
Monitoring
§
141.23
Inorganic
chemical
sampling
and
analytical
requirements.

§
141.23
Inorganic
chemical
sampling
and
analytical
requirements.
Revise
§
141.23(
a)(
5),
(
c),
(
f)(
1),
(
i)(
1),
(
i)(
2),
(
k)(
2),
(
k)(
3)
to
add
"
arsenic"
in
alphabetical
order
to
the
list
of
contaminants:

(
a)
Monitoring
shall
be
conducted
as
follows:
(
1)
Groundwater
systems
shall
take
a
minimum
of
one
sample
at
every
entry
point
to
the
distribution
system
which
is
representative
of
each
well
after
treatment
(
hereafter
called
a
sampling
point)
beginning
in
the
initial
compliance
period.
The
system
shall
take
each
sample
at
the
same
sampling
point
unless
conditions
make
another
sampling
point
more
representative
of
each
source
or
treatment
plant.
(
2)
Surface
water
systems
shall
take
a
minimum
of
one
sample
at
every
entry
point
to
the
distribution
system
after
any
application
of
treatment
or
in
the
distribution
system
at
a
point
which
is
representative
of
each
source
after
treatment
(
hereafter
called
a
sampling
point)
beginning
in
the
initial
compliance
period.
The
system
shall
take
each
sample
at
the
same
sampling
point
unless
conditions
make
another
sampling
point
more
representative
of
each
source
or
treatment
plant.
NOTE:
For
purposes
of
this
paragraph,
surface
water
systems
include
systems
with
a
combination
of
surface
and
ground
sources.
(
3)
If
a
system
draws
water
from
more
than
one
source
and
the
sources
are
combined
before
distribution,
the
system
must
sample
at
an
entry
point
to
the
distribution
system
during
periods
operating
conditions
(
i.
e.,
when
water
is
representative
of
all
sources
being
used).
(
4)
The
State
may
reduce
the
total
number
of
samples
which
must
be
analyzed
by
allowing
the
use
of
compositing.
Composite
samples
from
a
maximum
of
five
samples
are
al­
lowed,
provided
that
the
detection
limit
of
the
method
used
for
analysis
is
less
than
one­
fifth
of
the
MCL.
Compositing
of
samples
must
be
done
in
the
laboratory.
(
i)
If
the
concentration
in
the
composite
sample
is
greater
than
or
equal
to
one­
fifth
of
the
MCL
of
any
inorganic
chemical,
then
a
follow­
up
sample
must
be
taken
within
14
days
at
each
sampling
point
included
in
the
composite.
These
samples
must
be
analyzed
for
the
contaminants
which
exceeded
one­
fifth
of
the
MCL
in
the
composite
sample
...
(
ii)
If
the
population
served
by
the
system
is
>
3,300
persons,
then
compositing
may
only
be
permitted
by
the
State
at
sampling
points
within
a
single
system.
In
systems
serving
£
3,300
persons,
the
State
may
permit
compositing
among
different
systems
provided
the
5­
sample
limit
is
maintained.
(
iii)
If
duplicates
of
the
original
sample
taken
from
each
sampling
point
used
in
the
composite
are
available,
the
system
may
use
these
instead
of
re­
sampling.
The
duplicates
must
be
analyzed
and
the
results
reported
to
the
State
within
14
days
of
collection...
Appendix
A
­
5
Triggered
Monitoring
§
141.23
Inorganic
chemical
sampling
and
analytical
requirements
(
c)
The
frequency
of
monitoring
conducted
to
determine
compliance
with
the
maximum
contaminant
levels
in
§
141.62
for
antimony,
barium,
beryllium,
cadmium,
chromium,
cyanide,
fluoride,
mercury,
nickel,
selenium,
and
thallium
shall
be
as
follows:
(
1)
Groundwater
systems
shall
take
one
sample
at
each
sampling
point
during
each
compliance
period.
Surface
water
systems
(
or
combined
surface/
ground)
shall
take
one
sample
annually
at
each
sampling
point.
(
2)
The
system
may
apply
to
the
State
for
a
waiver
from
the
monitoring
frequencies
specified
in
paragraph
c(
1)
of
this
section.
.
.
.
(
3)
A
condition
of
the
waiver
shall
require
that
a
system
shall
take
a
minimum
of
one
sample
while
the
waiver
is
effective.
The
term
during
which
the
waiver
is
effective
shall
not
exceed
one
compliance
cycle
(
i.
e.,
nine
years).
(
4)
The
State
may
grant
a
waiver
provided
surface
water
systems
have
monitored
annually
for
at
least
three
years
and
groundwater
systems
have
conducted
a
minimum
of
three
rounds
of
monitoring.
.
.
.
Both
surface
and
groundwater
systems
shall
demonstrate
that
all
previous
analytical
results
were
less
than
the
maximum
contaminant
level.
Systems
that
use
a
new
water
source
are
not
eligible
for
a
waiver
until
three
rounds
of
monitoring
from
the
new
source
have
been
completed.
(
5)
In
determining
the
appropriate
reduced
monitoring
frequency,
the
State
shall
consider:
(
i)
Reported
concentrations
from
all
previous
monitoring;
(
ii)
The
degree
of
variation
in
reported
concentrations;
and
(
iii)
Other
factors
which
may
affect
contaminant
concentrations
such
as
changes
in
groundwater
pumping
rates,
changes
in
the
system's
configuration,
changes
in
the
system's
operating
procedures,
or
changes
in
stream
flows
or
characteristics.
(
6)
A
decision
by
the
State
to
grant
a
waiver
shall
be
made
in
writing
and
shall
set
forth
the
basis
for
determination.
The
determination
may
be
initiated
by
the
State
or
upon
an
application
by
the
public
water
system.
The
public
water
system
shall
specify
the
basis
for
its
request.
The
State
shall
review
and,
where
appropriate,
revise
its
determination
of
the
appropriate
monitoring
frequency
when
the
system
submits
new
monitoring
data
or
when
other
data
relevant
to
the
system's
appropriate
monitoring
frequency
become
available.
(
7)
Systems
which
exceed
the
maximum
contaminant
levels
as
calculated
in
§
141.23(
l)
of
this
section
shall
monitor
quarterly
beginning
in
the
next
quarter
after
the
violation
occurred.
(
8)
The
State
may
decrease
the
quarterly
monitoring
requirement
to
the
frequencies
specified
in
paragraphs
(
c)(
1)
and
(
c)(
2)
of
this
section
provided
it
has
determined
that
the
system
is
reliably
and
consistently
below
the
maximum
contaminant
level.
In
no
case
can
a
State
make
this
determination
unless
a
groundwater
unless
a
groundwater
system
takes
a
minimum
of
two
quarterly
samples
and
a
surface
water
system
takes
a
minimum
of
four
quarterly
samples.
Appendix
A
­
6
Appendix
B:
Assumptions
Used
to
Develop
ICR
Burdens
and
Costs
for
the
Revised
Arsenic
Rule
ICR
Appendix
B
­
1
Appendix
B
Assumptions
Used
to
Develop
ICR
Burdens
and
Costs
for
the
Revised
Arsenic
Rule
ICR
Overview
EPA
has
estimated
the
cost
of
the
arsenic
rule
under
the
proposed
monitoring
schedule
and
under
the
existing
schedule.
Listed
below
are
the
assumptions
used
to
develop
the
burden
and
cost
estimates
in
the
arsenic
ICR:

Overall
Assumptions
1.
The
inventory
of
systems
was
obtained
from
the
December
1998
SDWIS.
The
total
number
of
community
water
systems
is
54,352
and
the
total
number
of
NTNC
water
systems
is
20,255.

2.
The
number
of
systems
exceeding
the
designated
MCL
was
determined
using
SafeWaterXL.

3.
Systems
and
States
will
follow
the
schedule
as
outlined
in
Exhibit
5­
1
and
are
assumed
to
require
the
maximum
time
allowed
by
regulation.

4.
To
calculate
the
number
of
systems
that
will
receive
a
waiver,
three
pieces
of
information
are
used:
the
total
number
of
systems,
the
percentage
of
systems
that
exceed
the
designated
MCL,
and
the
percentage
of
states
that
have
sufficient
historic
data
to
distribute
waivers.
For
purposes
of
this
analysis,
there
is
the
additional
requirement
that
systems
must
meet
a
standard
of
50
percent
of
the
MCL
to
receive
a
waiver.
The
percentage
of
systems
exceeding
the
MCL,
as
represented
in
Exhibit
B­
1,
is
from
Exhibit
6­
3
in
Arsenic
Occurrence
in
Public
Water
Supplies.

Exhibit
B­
1
Percentage
of
Systems
Not
Eligible
for
a
Waiver
Source
Water
5
µ
g/
L
Groundwater
11.99%

Surface
water
2.96%

Twenty
states,
or
40
percent
of
States,
have
sufficient
historic
data
to
meet
the
waiver
requirements.
The
total
number
of
systems
by
source
is
from
SDWIS
December
1998.
Examples
of
the
final
equations
used
to
determine
the
number
of
systems
receiving
a
waiver
are
shown
below.
This
calculation
is
based
on
the
occurrence
estimates
provided
in
Exhibit
B­
1.
Appendix
B
­
2
5
µ
g/
L
(
MCL
10)
GW:
[(
1­.
1199)*
0.4]
*
Number
of
GW
Systems
=
Number
of
Systems
Receiving
Waiver
SW:
[(
1­.
0296)*
0.4]
*
Number
of
SW
Systems
=
Number
of
Systems
Receiving
Waiver
System
Monitoring
Assumptions
1.
All
systems
will
be
in
compliance
with
the
proposed
standards
after
the
first
round
of
triggered
monitoring.
Also,
systems
in
violation
of
the
MCL
will
install
treatment
during
the
initial
year
of
triggered
monitoring.
Therefore,
all
systems
will
be
in
compliance
during
subsequent
years.

2.
The
system
labor
rate
varies
by
population
served.
Labor
cost
for
systems
serving
less
than
or
equal
to
3,300
people
is
based
on
a
$
14.50
an
hour
rate,
escalated
to
$
15.03
in
May
1999
dollars
using
the
Bureau
of
Labor
Statistics
Consumer
Price
Index
(
CPI).
The
labor
rate
for
PWS
employees
working
in
systems
serving
more
than
3,300
people
is
based
on
$
28.00,
escalated
to
$
29.03
in
May
1999
dollars
using
the
CPI.

3.
For
all
systems
the
burden
assumptions
are
as
follows:
Apply
for
a
waiver
16
hours
Take
a
sample
1
hour
Report
a
sample
1
hour
4.
The
proposed
and
existing
regulations
differ
in
that
the
existing
regulation
does
not
include
any
activities
related
to
waivers.

State
Monitoring
Assumptions
1.
The
State
labor
rate
is
constant
across
population
served
and
activities.
All
State
labor
costs
are
based
on
a
$
40
an
hour
rate,
escalated
to
$
41.47
in
May
1999
dollars
using
the
CPI.

2.
For
States
to
complete
tasks
from
systems
serving
less
than
or
equal
to
10,000
people,
the
burden
assumptions
are
as
follows:
Review
waiver
application
8
hours
Record
monitoring
1
hour
Review
a
permit
16
hours
3.
For
States
to
complete
tasks
from
systems
serving
more
than
10,000
people,
the
burden
assumptions
are
as
follows:
Review
waiver
application
8
hours
Record
monitoring
1
hour
Review
a
permit
32
hours
Appendix
B
­
3
Number
of
Systems
by
Category
Tables
B­
2
and
B­
3
below
present
a
count
of
the
total
number
of
systems
affected
by
the
revised
arsenic
rule,
including
the
number
of
systems
and
entry
points
that
will
be
required
to
install
treatment.
The
sources
for
these
data
are
as
follows:

$
Total
number
of
systems:
the
1998
December
SDWIS
"
freeze."

$
Number
of
Systems
Treating:
the
SafeWaterXL
model.

$
Number
of
Entry
Points
Treating:
the
SafeWaterXL
model.

Table
B­
2
Number
of
Community
Groundwater
Systems
by
Category
System
Size
Total
Number
of
Systems
Number
of
Systems
Treating
Number
of
Entry
Points
Treating
MCL=
10
<
100
14,277
855
954
101­
500
15,058
940
1,177
501­
1,000
4,689
310
382
1,001­
3,300
5,714
421
612
3,301­
10,000
2,459
215
359
10,001­
50,000
1,216
142
358
50,001­
100,000
131
118
75
100,001­
1,000,000
61
11
52
Appendix
B
­
4
Table
B­
3
Number
of
Community
Surface
Water
Systems
by
Category
System
Size
Total
Number
of
Systems
Number
of
Systems
Treating
Number
of
Entry
Points
Treating
MCL=
10
<
100
1,092
11
11
101­
500
2,003
21
21
501­
1,000
1,220
12
12
1,001­
3,300
2,420
24
25
3,301­
10,000
1,844
18
20
10,001­
50,000
1,607
15
15
50,001­
100,000
300
4
5
100,001­
1,000,000
261
4
5
Appendix
C:
Annual
Burden
and
Cost
Estimates
for
Systems
and
States
(
2001­
2020)
Appendix
C
­
1
Appendix
C
This
ICR
describes
the
impact
on
PWSs
and
States
for
the
first
three
years
of
the
Revised
Arsenic
Rule.
Appendix
C
presents
the
20­
year
burden
and
costs
for
all
systems.
A
20­
year
perspective
includes
two
full
compliance
cycles,
which
include
triggered
monitoring,
the
waiver
application
process,
and
several
rounds
of
monitoring
when
a
portion
of
systems
will
not
be
required
to
monitor
(
due
to
waivers).
Appendix
C
­
2
Proposed
Burden
Curre
nt
Burde
n
Net
Burde
n
2001
1,505,674
144,010
1,361,664
2002
21,494
21,494
0
2003
21,494
21,494
0
2004
144,010
144,010
0
2005
21,494
21,494
0
2006
88,851
21,494
67,357
2007
405,200
144,010
261,190
2008
13,151
21,494
­
8,343
2009
13,151
21,494
­
8,343
2010
92,536
144,010
­
51,474
2011
13,151
21,494
­
8,343
2012
13,151
21,494
­
8,343
2013
92,536
144,010
­
51,474
2014
13,151
21,494
­
8,343
2015
88,239
21,494
66,745
2016
381,278
144,010
237,268
2017
13,151
21,494
­
8,343
2018
13,151
21,494
­
8,343
2019
92,536
144,010
­
51,474
2020
13,151
21,494
­
8,343
Exhibit
C­
1
Annual
Burden
(
2001­
2020)
CWSs
(
Hours)
Appendix
C
­
3
Proposed
Burde
n
Curre
nt
Burde
n
Ne
t
Burde
n
2001
486,120
0
486,120
2002
0
0
0
2003
0
0
0
2004
0
0
0
2005
0
0
0
2006
0
0
0
2007
160,835
0
160,835
2008
0
0
0
2009
0
0
0
2010
26,267
0
26,267
2011
0
0
0
2012
0
0
0
2013
26,267
0
26,267
2014
0
0
0
2015
0
0
0
2016
154,457
0
154,457
2017
0
0
0
2018
0
0
0
2019
26,267
0
26,267
2020
0
0
0
Exhibit
C­
2
Annual
Burden
(
2001­
2020)
NTNCs
(
Hours)
Appendix
C
­
4
Proposed
Burden
Curre
nt
Burde
n
Net
Burde
n
2001
225,759
72,005
153,754
2002
10,747
10,747
0
2003
10,747
10,747
0
2004
72,005
72,005
0
2005
10,747
10,747
0
2006
46,409
10,747
35,662
2007
274,312
72,005
202,307
2008
6,575
10,747
­
4,172
2009
6,575
10,747
­
4,172
2010
46,268
72,005
­
25,737
2011
6,575
10,747
­
4,172
2012
6,575
10,747
­
4,172
2013
46,268
72,005
­
25,737
2014
6,575
10,747
­
4,172
2015
44,119
10,747
33,372
2016
190,639
72,005
118,634
2017
6,575
10,747
­
4,172
2018
6,575
10,747
­
4,172
2019
46,268
72,005
­
25,737
2020
6,575
10,747
­
4,172
Exhibit
C­
3
Annual
Burden
(
2001­
2020)
States
(
Hours)
Appendix
C
­
5
Propose
d
Cost
Curre
nt
Cost
Net
Cost
2001
$
29,927,033
$
6,008,741
$
23,918,292
2002
$
945,925
$
945,925
$
0
2003
$
945,925
$
945,925
$
0
2004
$
6,008,741
$
6,008,741
$
0
2005
$
945,925
$
945,925
$
0
2006
$
2,325,107
$
945,925
$
1,379,182
2007
$
10,638,784
$
6,008,741
$
4,630,042
2008
$
578,755
$
945,925
­$
367,170
2009
$
578,755
$
945,925
­$
367,170
2010
$
3,859,257
$
6,008,741
­$
2,149,484
2011
$
578,755
$
945,925
­$
367,170
2012
$
578,755
$
945,925
­$
367,170
2013
$
3,859,257
$
6,008,741
­$
2,149,484
2014
$
578,755
$
945,925
­$
367,170
2015
$
2,298,096
$
945,925
$
1,352,171
2016
$
9,638,863
$
6,008,741
$
3,630,121
2017
$
578,755
$
945,925
­$
367,170
2018
$
578,755
$
945,925
­$
367,170
2019
$
3,859,257
$
6,008,741
­$
2,149,484
2020
$
578,755
$
945,925
­$
367,170
Exhibit
C­
4
Annual
Cost
(
2001­
2020)
CWSs
(
Dollars)
Appendix
C
­
6
Propose
d
Cost
Curre
nt
Cost
Net
Cost
2001
$
7,308,134
$
0
$
7,308,134
2002
$
0
$
0
$
0
2003
$
0
$
0
$
0
2004
$
0
$
0
$
0
2005
$
0
$
0
$
0
2006
$
0
$
0
$
0
2007
$
3,531,512
$
0
$
3,531,512
2008
$
0
$
0
$
0
2009
$
0
$
0
$
0
2010
$
1,018,717
$
0
$
1,018,717
2011
$
0
$
0
$
0
2012
$
0
$
0
$
0
2013
$
1,018,717
$
0
$
1,018,717
2014
$
0
$
0
$
0
2015
$
0
$
0
$
0
2016
$
3,284,150
$
0
$
3,284,150
2017
$
0
$
0
$
0
2018
$
0
$
0
$
0
2019
$
1,018,717
$
0
$
1,018,717
2020
$
0
$
0
$
0
Exhibit
C­
5
Annual
Cost
(
2001­
2020)
NTNCs
(
Dollars)
Appendix
C
­
7
Proposed
Cost
Current
Cost
Net
Cost
2001
$
7,754,031
$
2,986,191
$
4,767,840
2002
$
445,700
$
445,700
$
0
2003
$
445,700
$
445,700
$
0
2004
$
2,986,191
$
2,986,191
$
0
2005
$
445,700
$
445,700
$
0
2006
$
1,924,692
$
445,700
$
1,478,993
2007
$
11,376,271
$
2,986,191
$
8,390,079
2008
$
272,697
$
445,700
­$
173,003
2009
$
272,697
$
445,700
­$
173,003
2010
$
1,918,834
$
2,986,191
­$
1,067,357
2011
$
272,697
$
445,700
­$
173,003
2012
$
272,697
$
445,700
­$
173,003
2013
$
1,918,834
$
2,986,191
­$
1,067,357
2014
$
272,697
$
445,700
­$
173,003
2015
$
1,829,722
$
445,700
$
1,384,022
2016
$
7,906,184
$
2,986,191
$
4,919,992
2017
$
272,697
$
445,700
­$
173,003
2018
$
272,697
$
445,700
­$
173,003
2019
$
1,918,834
$
2,986,191
­$
1,067,357
2020
$
272,697
$
445,700
­$
173,003
Exhibit
C­
6
Annual
Cost
(
2001­
2020)
States
(
Dollars)
Appendix
D:
Detailed
Spreadsheet
from
System
and
State
Burden
and
Cost
Models
Please
attach
print­
ready
PDF
file
of
Appendix
D.
