  SEQ CHAPTER \h \r 1 

Information Collection Request 

for UCMR 2

-- Renewal --

May 2009

David Munch and Brenda Parris

U.S. Environmental Protection Agency

Office of Ground Water and Drinking Water

26 West Martin Luther King Drive

Cincinnati, OH 45268

TABLE OF CONTENTS

  TOC \t "H1,2,H2,3,H3,4,H4,5,H1a,1"  	

— PART A OF THE SUPPORTING STATEMENT —  PAGEREF _Toc229826436 \h  1 

1	IDENTIFICATION OF THE INFORMATION COLLECTION	  PAGEREF _Toc229826437
\h  1 

1(a)	Title and Number of the Information Collection	  PAGEREF
_Toc229826438 \h  1 

1(b)	Short Characterization	  PAGEREF _Toc229826439 \h  1 

2	NEED FOR AND USE OF THE COLLECTION	  PAGEREF _Toc229826440 \h  3 

2(a)	Need/Authority for the Collection	  PAGEREF _Toc229826441 \h  3 

2(b)	Practical Utility/Users of the Data	  PAGEREF _Toc229826442 \h  3 

3	NON-DUPLICATION, CONSULTATIONS AND OTHER COLLECTION CRITERIA	  PAGEREF
_Toc229826443 \h  3 

3(a)	Non-duplication	  PAGEREF _Toc229826444 \h  3 

3(b)	Public Notice Required Prior to ICR Submission to OMB	  PAGEREF
_Toc229826445 \h  3 

3(c)	Consultations	  PAGEREF _Toc229826446 \h  3 

3(d)	Effects of Less Frequent Collection	  PAGEREF _Toc229826447 \h  3 

3(e)	General Guidelines	  PAGEREF _Toc229826448 \h  3 

3(f)	Confidentiality	  PAGEREF _Toc229826449 \h  4 

3(g)	Sensitive Questions	  PAGEREF _Toc229826450 \h  4 

4	RESPONDENTS AND THE INFORMATION	  PAGEREF _Toc229826451 \h  4 

4(a)	Respondents and NAICS/SIC Codes	  PAGEREF _Toc229826452 \h  4 

4(b)	Information Requested	  PAGEREF _Toc229826453 \h  4 

4(b)(i) Data Items	  PAGEREF _Toc229826454 \h  4 

4(b)(i)(a) Public Water System Reporting and Recordkeeping	  PAGEREF
_Toc229826455 \h  4 

4(b)(i)(b) State Reporting and Recordkeeping	  PAGEREF _Toc229826456 \h 
4 

4(b)(ii) Respondent Activities	  PAGEREF _Toc229826457 \h  4 

4(b)(ii)(a) Public Water System Activities	  PAGEREF _Toc229826458 \h  4


4(b)(ii)(b) State Activities	  PAGEREF _Toc229826459 \h  6 

5	INFORMATION COLLECTED–AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND
INFORMATION MANAGEMENT	  PAGEREF _Toc229826460 \h  8 

5(a)	Agency Activities	  PAGEREF _Toc229826461 \h  8 

5(a)(i) Regulatory Support Activities	  PAGEREF _Toc229826462 \h  8 

5(a)(ii) National and Regional Oversight/Data Analysis	  PAGEREF
_Toc229826463 \h  9 

5(a)(iii) Costs for Small System Testing Program	  PAGEREF _Toc229826464
\h  9 

5(b)	Information Collection Methodology and Management	  PAGEREF
_Toc229826465 \h  10 

5(c)	Small Entity Flexibility	  PAGEREF _Toc229826466 \h  10 

5(d)	Collection Schedule	  PAGEREF _Toc229826467 \h  10 

6	ESTIMATING THE BURDEN AND COST OF THE COLLECTION	  PAGEREF
_Toc229826468 \h  10 

6(a)	Estimating Burden and Cost to Public Water Systems	  PAGEREF
_Toc229826469 \h  11 

6(a)(i) Estimating Burden and Labor Costs	  PAGEREF _Toc229826470 \h  12


6(a)(i)(a) Reading the Regulations/Guidance Letter	  PAGEREF
_Toc229826471 \h  14 

6(a)(i)(b) Monitoring Burden	  PAGEREF _Toc229826472 \h  14 

6(a)(i)(c) Reporting and Recordkeeping	  PAGEREF _Toc229826473 \h  14 

6(a)(i)(d) Public Notification	  PAGEREF _Toc229826474 \h  15 

6(a)(ii) Estimating Non-labor Costs	  PAGEREF _Toc229826475 \h  15 

6(a)(iii) Summary of Labor and Non-labor Costs to Public Water Systems	 
PAGEREF _Toc229826476 \h  15 

6(b)	Estimating the Burden and Cost to States	  PAGEREF _Toc229826477 \h
 18 

6(c)	Estimating Agency Burden and Cost	  PAGEREF _Toc229826478 \h  20 

6(c)(i) Regulatory Support Activities	  PAGEREF _Toc229826479 \h  21 

6(c)(ii) National and Regional Oversight and Data Analysis	  PAGEREF
_Toc229826480 \h  22 

6(c)(iii) Costs for Small System Testing Program	  PAGEREF _Toc229826481
\h  22 

6(c)(iv) Estimated Agency Cost and Burden	  PAGEREF _Toc229826482 \h  23


6(d)	Estimating the Respondent Universe and Total Burden and Costs	 
PAGEREF _Toc229826483 \h  24 

6(e)	Reasons for Change in Burden	  PAGEREF _Toc229826484 \h  25 

6(f)	Burden Statement	  PAGEREF _Toc229826485 \h  26 

— PART B OF THE SUPPORTING STATEMENT —  PAGEREF _Toc229826486 \h  30


1	SURVEY OBJECTIVES, KEY VARIABLES, AND OTHER PRELIMINARIES	  PAGEREF
_Toc229826487 \h  30 

1(a)	Survey Objectives	  PAGEREF _Toc229826488 \h  30 

1(b)	Key Variables	  PAGEREF _Toc229826489 \h  30 

1(c)	Statistical Approach	  PAGEREF _Toc229826490 \h  30 

1(d)	Feasibility	  PAGEREF _Toc229826491 \h  30 

2	SURVEY DESIGN	  PAGEREF _Toc229826492 \h  30 

2(a)	Target Population and Coverage	  PAGEREF _Toc229826493 \h  30 

2(b)	Sample Design	  PAGEREF _Toc229826494 \h  30 

2(b)(i) Sampling Frame	  PAGEREF _Toc229826495 \h  30 

2(b)(ii) Sample Size	  PAGEREF _Toc229826496 \h  30 

2(b)(iii) Stratification Variables	  PAGEREF _Toc229826497 \h  31 

2(b)(iv) Sampling Method	  PAGEREF _Toc229826498 \h  31 

2(b)(v) Multi-Stage Sampling	  PAGEREF _Toc229826499 \h  31 

2(c)	Precision Requirements	  PAGEREF _Toc229826500 \h  31 

2(c)(i) Precision Targets	  PAGEREF _Toc229826501 \h  31 

2(c)(ii) Nonsampling error	  PAGEREF _Toc229826502 \h  31 

2(d)	Questionnaire Design	  PAGEREF _Toc229826503 \h  31 

3	PRETESTS AND PILOT TESTS	  PAGEREF _Toc229826504 \h  31 

4	COLLECTION METHODS AND FOLLOW-UP	  PAGEREF _Toc229826505 \h  31 

4(a)	Collection Methods	  PAGEREF _Toc229826506 \h  31 

4(b)	Survey Response and Follow-up	  PAGEREF _Toc229826507 \h  31 

5	ANALYZING AND REPORTING SURVEY RESULTS	  PAGEREF _Toc229826508 \h  32 

5(a)	Data Preparation	  PAGEREF _Toc229826509 \h  32 

5(b)	Analysis	  PAGEREF _Toc229826510 \h  32 

5(c)	Reporting Results	  PAGEREF _Toc229826511 \h  32 

— APPENDICES —  PAGEREF _Toc229826512 \h  33 

APPENDIX A: Relevant Authorities in the SDWA 1996 Amendments	  PAGEREF
_Toc229826513 \h  A-1 

APPENDIX B: Burden and Cost Exhibits for the Five-Year UCMR 2 Cycle of
2007-2011	  PAGEREF _Toc229826514 \h  B-1 

 LIST OF EXHIBITS

  TOC \t "Exhibit,1" \c "Figure"  Exhibit 1: Time Line of UCMR
Activities	  PAGEREF _Toc229825863 \h  9 

Exhibit 2: Systems to Participate in UCMR 2 Monitoring (January
2008-December 2010)	  PAGEREF _Toc229825864 \h  12 

Exhibit 3: UCMR 2 Sampling Activity Time Line for Cost and Burden
Estimations	  PAGEREF _Toc229825865 \h  13 

Exhibit 4: Labor Rates Applied for Public Water Systems	  PAGEREF
_Toc229825866 \h  14 

Exhibit 5a: Yearly Cost to Systems, by System Size and by Type of Cost
(2010-2012)	  PAGEREF _Toc229825868 \h  17 

Exhibit 5b: Per System (Respondent) and Per Respondent UCMR Costs
(2010-2012)	  PAGEREF _Toc229825869 \h  18 

Exhibit 6: Number of States in Each Size Category (State Resource Model
Assumptions)	  PAGEREF _Toc229825870 \h  19 

Exhibit 7a: Yearly Cost and Burden to States for Implementation of UCMR
(2010-2012)	  PAGEREF _Toc229825871 \h  20 

Exhibit 7b: Per State (Respondent) and Per Response UCMR Costs
(2010-2012)	  PAGEREF _Toc229825872 \h  20 

Exhibit 8a: Yearly Cost to EPA for UCMR Implementation, by Type of Cost
(2010-2012)	  PAGEREF _Toc229825873 \h  23 

Exhibit 8b: Summary of EPA Burdens and Costs for UCMR Implementation
(2010-2012)	  PAGEREF _Toc229825874 \h  24 

Exhibit 9: UCMR 2 National Cost Summary for the ICR period (2010-2012)1	
 PAGEREF _Toc229825875 \h  25 

Exhibit 10: UCMR 2 Per Respondent Burden and Cost Summary for the ICR
Period (2010-2012)	  PAGEREF _Toc229825876 \h  27 

Exhibit B-1a: Yearly Cost to Systems, by System Size and by Type of Cost
(2007-2011)	  PAGEREF _Toc229825877 \h  B-1 

Exhibit B-1b: Per System (Respondent) and Per Response UCMR Costs
(2007-2011)	  PAGEREF _Toc229825878 \h  B-2 

Exhibit B-2a: Yearly Cost and Burden to States for Implementation of
UCMR (2007-2011)	  PAGEREF _Toc229825879 \h  B-2 

Exhibit B-2b: Per State (Respondent) and Per Response UCMR Costs
(2007-2011)	  PAGEREF _Toc229825880 \h  B-2 

Exhibit B-3a: Yearly Cost to EPA for UCMR Implementation, by Type of
Cost (2007-2011)	  PAGEREF _Toc229825881 \h  B-3 

Exhibit B-3b: Summary of EPA Burdens and Costs for UCMR Implementation
(2007-2011)	  PAGEREF _Toc229825882 \h  B-4 

Exhibit B-4: National Cost Summary for UCMR 2 Implementation
(2007-2011)1	  PAGEREF _Toc229825883 \h  B-4 

Exhibit B-5: UCMR 2 Per Respondent Burden and Cost Summary (2007-2011)	 
PAGEREF _Toc229825884 \h  B-5 

 



ACRONYMS

ASDWA		Association of State Drinking Water Administrators

CCL			Contaminant Candidate List

CCR			Consumer Confidence Report

CFR			Code of Federal Regulations 

CWS			Community Water System

DBP			Disinfection Byproduct

DBPR			Stage 1 Disinfection Byproducts Rule

DSMRT		Distribution System Maximum Residence Time

EPA			Environmental Protection Agency

EPTDS		Entry Point to the Distribution System

FR			Federal Register 

FTE			Full Time Equivalent

GS			General Schedule

GWUDI		Ground Water under the Direct Influence of Surface Water

ICR			Information Collection Request

LCMRL		Lowest Concentration Minimum Reporting Level 

MCL			Maximum Contaminant Level

MCLG			Maximum Contaminant Level Goal

MRL			Minimum Reporting Level

NAICS		North American Industry Classification System

NCOD			National Contaminant Occurrence Database

NPDWR		National Primary Drinking Water Regulation 

NTNCWS		Non-transient Non-community Water System

OMB			Office of Management and Budget 

OW			Office of Water

PA			Partnership Agreement

PT			Proficiency Testing

PWS			Public Water System

PWSID		Public Water System Identification 

QA/QC		Quality Assurance/Quality Control

RFA			Regulatory Flexibility Act

SDWA			Safe Drinking Water Act

UCMR			Unregulated Contaminant Monitoring Regulation

	— PART A OF THE SUPPORTING STATEMENT —

1	IDENTIFICATION OF THE INFORMATION COLLECTION

1(a)	Title and Number of the Information Collection

Title: 				Information Collection Request for UCMR 2

OMB Control Number:	2040-0270

	EPA Tracking Number: 	2192.03

1(b)	Short Characterization

	Section 1445(a)(2) of the Safe Drinking Water Act (SDWA), as amended in
1996, requires that once every 5 years, beginning in August 1999, the
United States Environmental Protection Agency (EPA) issue a new list of
no more than 30 contaminants to be monitored, and procedures for
placement of the monitoring data in the National Contaminant Occurrence
Database (NCOD). EPA’s program must also include a nationally
“representative sample of systems serving 10,000 or fewer persons”
that will be required to monitor, and a frequency and schedule for
monitoring.

	EPA published the revisions to the Unregulated Contaminant Monitoring
Regulation (UCMR) for public water systems (PWSs) on September 17, 1999
(64 FR 50556).  This revised regulation included programmatic changes,
and provided a list of contaminants for which monitoring was required or
would be required in the future.  In this first UCMR cycle (UCMR 1), EPA
established a three-tiered approach for monitoring contaminants based on
the availability of analytical methods and contaminant properties. 

	EPA developed a contaminant list and sampling design for the second
UCMR cycle (i.e., UCMR 2) of 2007-2011. The rule for UCMR 2 (published
January 4, 2007 (72 FR 367)) builds on the established structure of UCMR
1 and makes some changes to the rule design. UCMR 2 monitoring is taking
place from January 2008 through December 2010.  The applicable
Information Collection Request (ICR) renewal period is 2010-2012.
Estimates of implementation burden and cost over the entire five-year
UCMR 2 cycle of 2007-2011 are attached as Appendix B to this ICR. Note
that the complete five-year UCMR 2 cycle of 2007-2011 overlaps with the
applicable ICR renewal period only during 2010 and 2011. Moreover, PWSs
will only be involved in active monitoring during 2010 (i.e., one-third
of this ICR period).  

	Assessment Monitoring, the largest in scale of the three UCMR
monitoring components, is being conducted from January 2008 through
December 2010 by 800 systems serving 10,000 or fewer people (hereafter
referred to as small systems), and by all systems serving 10,001 and
over people, for 10 “List 1” contaminants.  Under Assessment
Monitoring, contaminants for which standard analytical techniques are
available are monitored to assess national occurrence in drinking water.
The Screening Survey (for 15 “List 2” contaminants) is being
conducted from January 2008 through December 2010 by 800 systems serving
100,000 or fewer people, and all systems serving more than 100,000
people (407 systems). Small systems will not be subject to more than one
component of UCMR 2 monitoring. For cost estimation and scheduling
purposes, EPA assumes that approximately one-third of systems will
monitor during each of the three monitoring years (2008 - 2010); thus,
two-thirds of all systems required to conduct UCMR 2 monitoring were
assumed to monitor during the first UCMR 2 ICR period of 2007-2009, and
one-third of systems required to conduct UCMR 2 monitoring are assumed
to monitor during the second UCMR 2 ICR period of 2010-2012.  

	Respondents to UCMR 2 include 1,280 small water systems (800 for
Assessment Monitoring, and 480 for the Screening Survey), the 3,633
large and very large PWSs, and the 56 States and primacy agents
(referred to collectively as “States” for simplicity in this
document), for a total of 4,969 respondents (over the UCMR 2
implementation period of 2007-2011). The frequency of response varies
across respondents and years. 

	Small systems (those serving 10,000 or fewer) that are selected for
UCMR 2 monitoring will sample an average of 2.7 times per system (i.e.,
number of responses per system) across the three-year ICR renewal period
of 2010-2012. The average total burden per response for small systems is
estimated to be 1.8 hours. Large systems (those serving 10,001 to
100,000) and very large systems (those serving more than 100,000) will
sample and report an average of 3.1 and 3.6 times per system,
respectively, across the three-year ICR period of 2010-2012. The average
total burdens per response for large and very large systems are
estimated to be 3.8 and 8.7 hours, respectively. The larger burden per
response for the very large systems reflects the fact that these systems
typically have more sampling locations than large systems. States are
assumed to incur 2 responses over the three-year ICR period related to
coordination with EPA and systems, with an average burden per response
of 95.2 hours. In aggregate, during the ICR period of 2010-2012, the
average response (e.g., responses from systems and States) is associated
with a total burden of 5.8 hours, with a labor plus non-labor cost of
$1,939 per response. 

	The annual average per respondent burden hours and costs for the ICR
period of 2010-2012 are: small systems — 1.6 hour burden at $44 for
labor; large systems — 3.8 hours at $114 for labor, and $1,747 for
analytical costs; very large systems — 10.4 hours at $369 for labor,
and $7,260 for analytical costs; and States — 63.5 hours at $3,499 for
labor. Annual average burden and cost per respondent (including both
systems and States) is estimated to be 5.8 hours, with a labor plus
non-labor cost of $1,919 per respondent (note that small systems do not
pay for testing costs, so they only incur labor costs). The total annual
burden for the ICR reporting period of 2010-2012 is 9,761 (with a labor
cost of $387,096); the total annual analytical cost is $2.86 million.

	The Agency estimates the annual burden to EPA for UCMR program
activities during the ICR years of 2010-2012 to be 5,720 hours, at an
annual labor cost of $0.4 million. EPA’s annual non-labor costs are
estimated to be $1.1 million. Non-labor costs are primarily attributed
to the cost of sample testing for small systems (testing is just under
95 percent of non-labor).

2	NEED FOR AND USE OF THE COLLECTION

2(a)	Need/Authority for the Collection

This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

2(b)	Practical Utility/Users of the Data

This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

3	NON-DUPLICATION, CONSULTATIONS AND OTHER COLLECTION CRITERIA

3(a)	Non-duplication

This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

3(b)	Public Notice Required Prior to ICR Submission to OMB

This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

3(c)	Consultations

This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

3(d)	Effects of Less Frequent Collection

This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

3(e)	General Guidelines

This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

3(f)	Confidentiality

This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

3(g)	Sensitive Questions

This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

4	RESPONDENTS AND THE INFORMATION

4(a)	Respondents and NAICS/SIC Codes

This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

4(b)	Information Requested

	This ICR summarizes the data items and respondent activities associated
with UCMR 2.

4(b)(i) Data Items

This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

4(b)(i)(a) Public Water System Reporting and Recordkeeping

This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

4(b)(i)(b) State Reporting and Recordkeeping

This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

4(b)(ii) Respondent Activities

	Respondents include both PWSs and States. System activities and State
activities are discussed below in sections 4(b)(ii)(a) and 4(b)(ii)(b),
respectively (Part A of this ICR document). Changes to this Respondent
Activities section primarily address clarifications of the timing of
activities relative to this ICR renewal period.

4(b)(ii)(a) Public Water System Activities

	To comply with the requirements in this regulation, systems are
expected to conduct the following activities:

read regulations and/or letter from State or EPA which outline
requirements;

monitor or provide monitoring assistance (e.g., sample collection and
shipping);

report and maintain records; and 

report to the public.

Each of these activities is discussed in more detail below. 

	Read Regulations/State Letter: All PWSs that are participating in UCMR
monitoring are assumed to have read the UCMR regulations and/or a
State-issued guidance letter during the 2007-2009 ICR period. Small
systems can rely on summarized information from the State or EPA for
information pertaining to the regulation, rather than reading the
regulation. 

	Monitoring or Monitoring Assistance: Monitoring activities that are
considered in the system cost and burden estimates include receiving
sampling kits from the laboratory, reading sampling instructions, and
collecting and shipping the sample. Assessment Monitoring is scheduled
to occur during January 2008 through December 2010 for 10 chemical
contaminants. The Screening Survey is scheduled for January 2008 through
December 2010 for 15 other chemical contaminants. For cost estimation
and scheduling purposes, EPA assumes that approximately one-third of
systems will monitor during each of the three monitoring years (2008 -
2010); thus, two-thirds of all systems required to conduct UCMR 2
monitoring were assumed to monitor during the first UCMR 2 ICR period of
2007-2009, and one-third of systems required to conduct UCMR 2
monitoring are assumed to monitor during the second UCMR 2 ICR period of
2010-2012.  Appendix B provides a comprehensive cost estimate for
implementation of the rule, including labor and non-labor costs for the
entire five-year UCMR cycle of 2007 - 2011. Note that the complete
five-year UCMR 2 cycle of 2007-2011 overlaps with the applicable ICR
period only during 2010 and 2011 (and, PWSs will only be involved in
active monitoring during 2010 (i.e., one-third of this ICR period)).

	For both Assessment Monitoring and the Screening Survey, surface water
(and GWUDI) sampling points will be monitored four times during the
applicable year of monitoring, and ground water sampling points will be
monitored twice during the applicable year of monitoring. Monitoring
will be conducted at EPTDSs. Large ground water systems with multiple
EPTDSs will only be required to sample at representative sampling
locations for each ground water source, as long as those sites have been
approved by EPA or the State. In addition, Screening Survey systems that
are required to monitor for DBPs will be required to sample for
nitrosamines at one distribution system sampling point per treatment
plant (i.e., at the distribution system maximum residence time (DSMRT)),
as well as their EPTDS sampling locations.

	Reporting and Recordkeeping: As noted in section 4(b)(i)(a), Part A of
this ICR document, several of the requirements related to reporting of
contact information, reporting of sampling location data, electronic
reporting by laboratories, and data elements associated with monitoring
data were modified by the UCMR 2  rule. Activities related to these
reporting requirements include: 

Reporting Prior to Monitoring - This section has not changed as compared
to the UCMR 2 ICR for 2007-2009: EPA ICR No. 2192.02; OMB Number
2040-0270.

Reporting Monitoring Results - This section has not changed as compared
to the UCMR 2 ICR for 2007-2009: EPA ICR No. 2192.02; OMB Number
2040-0270.

Recordkeeping - This section has not changed as compared to the UCMR 2
ICR for 2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

	Reporting to the Public: SDWA section 1445(a)(2)(E) requires
notification of the results of the UCMR program to be made available to
those served by the system. CWSs are required to notify their users of
the detection of any contaminants (including unregulated contaminants)
in their Consumer Confidence Reports (CCRs), pursuant to
§141.153(d)(3)(iv), published in the Federal Register (63 FR 44512).
Monitoring and reporting violations for all systems (CWSs and NTNCWSs)
will be reportable under the Public Notification Rule (64 FR 25964 (May
13, 1999)). 

4(b)(ii)(b) State Activities

	For UCMR 1, EPA estimated State burdens and costs using the 1993 State
Resource Model (documented in the “Resource Analysis Computer Program
for State Drinking Water Agencies”). That model was designed by EPA,
in coordination with ASDWA and required specific input for a list of
activities and variables related to State operation of the UCMR drinking
water program (e.g., number of systems affected, estimates of violation
rates, etc.). Since that time, EPA and ASDWA have worked together to
update and improve the previous version of the resource model. EPA used
the updated resource model (the “2001 ASDWA Drinking Water Program
Resource Needs Self Assessment”, as documented in: “Public Health
Protection Threatened by Inadequate Resources for State Drinking Water
Programs - An Analysis of State Drinking Water Program Resources, Needs,
and Barriers”; ASDWA, April 2003) to estimate resources that States
may need for the oversight and implementation of UCMR 2. Assumptions
that were applied in using this resource assessment tool are described
in section 6(b), Part A of this ICR document. EPA assumes that State
participation will closely reflect that which occurred during UCMR 1.
Therefore, model estimates were adjusted to account for actual levels of
prior State participation. 

	Since UCMR is a “direct implementation” rule, specifics of each
State’s role will be delineated in PAs between the States and EPA.
However, in response to the regulation, EPA anticipates that State
activities will generally include EPA coordination activities/PAs, data
management and support, program implementation, and training/overhead.
Though some States may choose to conduct sampling for their systems,
this activity is not part of the PA agreement and is optional for
States. Burden for sampling is currently attributed to systems only. If
States choose to conduct monitoring for systems, burden would be similar
to that estimated for systems.

	State Coordination with EPA/PAs: State activities that involve
coordination with EPA include coordination and drafting of a PA, review
of and response to EPA’s proposed State Monitoring Plan, review of PWS
proposals for representative EPTDSs, and general ongoing coordination. 

	Review of State Monitoring Plans was one of the first UCMR activities
to take place at the State level. Each State received a proposed initial
State Monitoring Plan from EPA, which  listed all systems that would be
required to conduct Assessment Monitoring and the Screening Surveys. 
For systems that are part of the sample, EPA generated a list to provide
similar replacement systems for States to select from, for those systems
that may not have been correctly specified in the initial plan. If a
State identified systems on the original proposed State Monitoring Plan
that it determined were not appropriate for the representative sample
(e.g., if systems were inactive, or had switched to purchased water),
the State could propose an alternative plan by selecting other systems
from EPA’s alternate list to replace the ineligible systems. The State
Monitoring Plans also specified the year and months during which systems
would monitor. States were given the option to modify these schedules.
Since these UCMR 2 activities were completed by States in 2007, they are
not applicable to the current ICR period of 2010-2012.

	Some systems that use ground water as a source of water have submitted
a proposal for monitoring at representative entry point(s), rather than
monitor at every EPTDS. State involvement in the review of these
proposals was determined in the PA process. 

	EPA recognizes the necessity for States to maintain ongoing
communications with EPA regarding the requirements of UCMR. An example
of this would be instances when States need clarification and guidance
regarding a specific requirement of the regulation. These ongoing
communication activities are included in estimated burdens across the
entire UCMR 2 implementation period of 2007-2011.

	Data Management and Support: Though there are no data management and
support activities included in UCMR, EPA recognizes that many States may
update their databases to accommodate the revised UCMR data elements.
Activities likely include data entry/downloading of data, and general
recordkeeping. 

	Program Implementation: Program implementation activities for each
State may include notification and guidance letter to systems, data
review, ongoing system support, and enforcement. 

	Following review and finalization of State Monitoring Plans,
participating States prepared a notification letter that described
system monitoring schedules and requirements under the regulation. The
participating States notified each applicable system and sent the list
of these notified systems to EPA. It is also likely that States will
receive telephone calls from water systems asking for clarification and
guidance pertaining to the requirements of UCMR. States may choose to
review monitoring results, in part to determine whether a system has met
its monitoring and reporting requirements.

	State Staff Training and Overhead: Technical staff are assumed to
participate in rule-specific training designed to assist them in
understanding the regulation, their roles and responsibilities, and to
allow the State to better provide technical assistance to the systems.
In addition, general overhead costs, such as clerical and managerial
needs, are allocated to the UCMR staff requirements in the standard
State Resource Model, which allocates support staff needs as a
percentage of professional staff needs. See section 6(b), Part A of this
ICR document, for further discussion of model assumptions.

5	INFORMATION COLLECTED–AGENCY ACTIVITIES, 	COLLECTION METHODOLOGY,
AND INFORMATION 	MANAGEMENT

5(a)	Agency Activities

	EPA Headquarters and Regional offices are responsible for oversight of
State PWS programs, and processing and analysis of the UCMR data. EPA
implementation activities are categorized, as follows, into three major
categories: regulatory support activities; program oversight and data
analysis; and small system testing program, which are described below,
in 5(a)(i)-(iii).

5(a)(i) Regulatory Support Activities

	Regulatory support activities include: laboratory approval and quality
assurance/quality control; and technical support to PWSs, such as
guidance documents. 

	Laboratory Approval and Quality Assurance/Quality Control (QA/QC)
Activities: EPA incurs various costs related to laboratory approvals and
laboratory quality assurance and control, including the following
activities:

QC audits of contract laboratories - EPA will be conducting QC audits at
each of the approved laboratories during each year of UCMR 2 monitoring
(January 2008 through December 2010). Only those QC audits for 2010
coincide with this ICR period.

Analytical standards provision and coordination - Specialized analytical
standards are distributed to participating laboratories by EPA during
each year of UCMR 2 monitoring (January 2008 through December 2010).
This ICR includes EPA’s coordination and distribution of these
standards in 2010 only.

	

5(a)(ii) National and Regional Oversight/Data Analysis

	EPA’s UCMR program activities include data analysis, management
oversight, and implementation assistance to States. These are key
management and oversight activities that must be conducted by EPA
Headquarters or its Regional offices. Exhibit 1, below, illustrates the
time line for UCMR implementation activities. EPA developed its PAs with
States and the State Monitoring Plans prior to the beginning of PWS
monitoring activities. EPA is conducting its ongoing evaluation of the
data during 2007-2011 (i.e., the five-year UCMR 2 cycle). 

Exhibit 1: Time Line of UCMR Activities

2006 and 2007	2008	2009	2010	2011



EPA Lab approval program

Representative Sample of PWSs Selected by EPA

EPA/State PAs and State Monitoring Plans Developed

Inform PWSs/Establish Monitoring Plans

Next RegDet1 scheduled for CCL 2 contaminants



	

Final EPA data analysis









	Assessment Monitoring:

List 1 Contaminants

All systems serving more than 10,000;

800 systems serving 10,000 or fewer people











Screening Survey:

List 2 Contaminants

All systems serving more than 100,000 people;

800 systems serving 100,000 or fewer people 























1 RegDet = Regulatory Determination

5(a)(iii) Costs for Small System Testing Program

	Implementation of small system testing program is the largest portion
of Agency costs for the UCMR program. Prior to monitoring, EPA
activities for logistical support of the small system testing program
include coordination of small system testing and provision of testing
supplies. 

	The single largest cost to EPA for implementation of UCMR is for small
system sample analyses. During the ICR period of 2010-2012, EPA will pay
for the analytical and shipping costs for just one-third of small
systems selected for Assessment Monitoring and Screening Survey
monitoring (two-thirds of monitoring was completed during 2008 and 2009,
covered under the previous UCMR 2 ICR period of 2007-2009). EPA is
conducting some QC activities that apply only to small systems.
Specifically, EPA is sending “duplicates” of 10 percent of small
system samples to separate laboratories for analysis. The quality
control duplicates are intended to provide standard, real time, QC
checks among the different contract laboratories. 

5(b)	Information Collection Methodology and Management

	UCMR 2 specifies that laboratories must report the analytical results
and associated data elements to EPA’s electronic data reporting
system. UCMR 2 clarifies that large systems must ensure that their
laboratory posts the data in EPA’s electronic data reporting system,
and must review, approve, and submit the data to the State and EPA via
the EPA electronic reporting system. After 60 days from the
laboratory’s posting, if the PWS has not approved and submitted the
data, the data will be considered approved and final for EPA review.
Electronic reporting will provide significant collection efficiencies,
and reduce the possibility of data input error. 

	EPA is conducting ongoing data analysis, including checks for anomalies
in the data that may be related to data entry or laboratory errors. Data
quality review and analysis includes: continuous analysis of laboratory
results, review of all program data, and NCOD review.

	The UCMR data are maintained and analyzed through NCOD. The data
collected under UCMR are used for regulation development, to analyze the
significance of occurrence and health effects, and to support the
critical Agency function of program oversight. The public will receive
information regarding UCMR monitoring results through the CCRs, and will
be able to access data through the NCOD. In addition, systems that fail
to monitor for unregulated contaminants will be required to notify the
public of their failure to monitor.

5(c)	Small Entity Flexibility

This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

5(d)	Collection Schedule

This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

6	ESTIMATING THE BURDEN AND COST OF THE COLLECTION

	This section describes the respondent burden and cost for activities
under UCMR 2. The burden and cost estimates for PWSs are shown in
section 6(a), burden and costs to States are shown in section 6(b), and
the Agency’s burden and cost estimates are shown in section 6(c) (all
in Part A of this ICR document). 

	This ICR focuses only on the cost of the UCMR data collection over the
years 2010-2012. Cost tables that are presented in this section have
analogous tables in Appendix B, which present costs for the entire UCMR
2 cycle (2007-2011). 

	There are two primary categories of costs associated with UCMR: (1)
labor costs, such as program implementation, sample collection,
recordkeeping, reporting, and data analysis; and (2) non-labor costs,
such as laboratory fees for analyses of samples, shipping charges, and
contractor costs. The majority of costs are attributed to monitoring
activities and the fees for laboratory analytical services. Assessment
Monitoring targets a list of 10 contaminants and the Screening Survey
targets 15 contaminants.

	EPA is committed to accurately characterizing the burden and costs of
rules it promulgates. In the development of various drinking water
program rule ICRs, EPA has developed a consistent set of assumptions to
use in calculations. These have been developed and utilized in other
drinking water program evaluations. Pertinent to the UCMR ICR are the
standard assumptions for labor rates, system inventory numbers (the
number of water systems in the various size categories by primary water
source), the number of sampling points for each system, and analytical
services. The sources and assumptions used in estimating costs and
burdens are described below. For consistency, the sources and
assumptions that were used for the 2007-2009 UCMR 2 ICR period are also
used for the 2010-2012 UCMR 2 ICR period.

6(a)	Estimating Burden and Cost to Public Water Systems

	Specific assumptions used in estimating system labor burden and cost,
as well as non-labor costs are discussed in sections 6(a)(i) and
6(a)(ii), respectively (Part A of this ICR document). A summary of the
costs estimates is provided in section 6(a)(iii), Part A of this ICR
document.

	EPA used the following sources of system information to develop cost
and burden estimates: 

Inventory Data: Small system inventory was based on the same source as
that used for the current drinking water ICR entitled:
Disinfectants/Disinfection Byproducts, Chemical, and Radionuclides
Information Collection Request (OMB Control Number: 2040-0204; EPA
Tracking Number: 1896.05). Large system inventory data are from UCMR
data collected for UCMR 1 implementation, as of March 2006.

EPTDS Data: All EPTDS data were taken from Community Water System Survey
2000, Volume II Detailed Tables and Survey Methodology, Table 7,
entitled “Average Number of Entry Points to the Distribution System By
Primary Source Water”, which gives the average number of entry points
for ground water and surface water systems. 

DSMRT Data: Number of DSMRT samples per system per sampling period were
estimated by multiplying the number of treatment plants per system (from
Community Water System Survey 2000, Volume II Detailed Tables and Survey
Methodology, Table 11) by the percentage of systems disinfecting (Fourth
Edition of the Baseline Handbook, Table B1.3.3, originally derived from
the 1995 Community Water System Survey). As a conservative measure, the
average number of CWSs treatment plants were also used to represent the
number of NTNCWS treatment plants (i.e., it is likely that NTNCWSs have
fewer treatment plants than CWSs, and thus lower actual costs for DSMRT
sampling than estimated).

6(a)(i) Estimating Burden and Labor Costs

	Both Assessment Monitoring and Screening Survey monitoring are being
conducted from January 2008 through December 2010. Assessment Monitoring
is being conducted by 800 systems serving 10,000 or fewer people, and
all systems serving 10,001 and over. Screening Survey monitoring is
being conducted by 800 systems serving 100,000 or fewer people, plus all
systems serving more than 100,000 people. It is assumed for this cost
estimation that one-third of systems will conduct monitoring each year.
The UCMR program will affect a total of 4,913 systems, one-third of
which will conduct monitoring during the ICR years of 2010-2012. Exhibit
2 below presents the estimated numbers of regulated systems required to
participate in UCMR 2. Exhibit 3 presents the time line in which the
system monitoring activities will take place.

Exhibit 2: Systems to Participate in UCMR 2 Monitoring (January
2008-December 2010)

System Size	Assessment Monitoring

List 1	Screening Survey

List 2	TOTAL1

Small (serving 25 - 10,000)	800 (selected systems)	480 (selected
systems; 

different from those for List 1)	1,280

Large (serving 10,001-100,000)	3,226 (all)	320 (selected systems)	3,226

Very Large (serving >100,000)	407 (all)	407 (all)	407

TOTAL	4,433	1,207	4,913

1. Totals for large and very large systems are not additive, since
Screening Survey systems are a subset of those conducting Assessment
Monitoring (i.e., some large and all very large systems will conduct
both Assessment Monitoring and Screening Survey monitoring).

Exhibit 3: UCMR 2 Sampling Activity Time Line for Cost and Burden
Estimations

2007	2008	2009	2010	2011



	(designated ICR years are 2010-2012)

No UCMR monitoring activity	Assessment Monitoring1	No UCMR monitoring
activity

	~a systems sample

(~1,478 PWSs)	~a systems sample

(~1,478 PWSs)	~a systems sample

(~1,478 PWSs)



Screening Survey1



~a systems sample

(~402 PWSs)	~a systems sample

(~402 PWSs)	~a systems sample

(~402 PWSs)

	1 The following assumptions, based on the specifications in UCMR 2,
were used to estimate cost and burden: 

•	Approximately one-third of systems will monitor during each of the
three monitoring years (2008 - 2010); thus, only one-third of all
systems required to conduct UCMR 2 monitoring are assumed to monitor
during the ICR renewal period of 2010-2012. (The other two-thirds of
participating systems have completed monitoring during 2008 and 2009,
which fell within the previous UCMR 2 ICR period of 2007-2009. 

	•	Systems serving more than 100,000 people must conduct both
Assessment Monitoring and Screening Surveys.

	The water system labor burden consists of three primary activities: (1)
reading the regulations or State guidance letter; (2) monitoring or
monitoring assistance; and (3) reporting and recordkeeping. Hourly labor
rates (including overhead) vary by system size and are taken from the
October 20, 2003 document Labor Costs for National Drinking Water Rules,
Exhibit 20. The loaded wage rates are escalated to 2007 dollars using
the December 2005 Employment Cost Index for wages and salaries in
electric, gas, and sanitary services; and by applying an inflation
factor of 3 percent. Estimated hourly rates range from approximately
$25.30 per hour for staff in water systems serving 500 or fewer people
to almost $35.60 per hour for systems serving more than 100,000 people
(see Exhibit 4 for details). 

Exhibit 4: Labor Rates Applied for Public Water Systems

System Size	Labor Rate1

500 and under	$25.29 (for ground water)

$25.48 (for surface water/GWUDI)

501 to 3,300	$28.15

3,301 to 10,000	$28.83

10,001 to 50,000	$29.65

50,001 to 100,000	$29.65

100,001 and over	$35.57

1 PWS hourly labor rates (including overhead) are taken from Labor Costs
for National Drinking Water Rules, Exhibit 20. All rates represent that
for both ground water and surface water/GWUDI systems, except as noted.
The loaded wage rates are escalated to 2007 dollars using the December
2005 Employment Cost Index for wages and salaries in electric, gas, and
sanitary services; and by applying an inflation factor of 3 percent. 

6(a)(i)(a) Reading the Regulations/Guidance Letter

	For each required UCMR component (Assessment Monitoring and/or
Screening Surveys), systems are assumed to have read the regulations
and/or a State-issued guidance letter during 2007, when UCMR 2 was
established. Thus, this reading burden for UCMR 2 is considered to be
complete, and not part of the applicable ICR period of 2010-2012. The
reading burden was accounted for in the first UCMR 2 ICR period of
2007-2009. 

6(a)(i)(b) Monitoring Burden

	For Assessment Monitoring, it is assumed that all participating systems
would collect samples during January 2008 through December 2010, with
approximately one-third of systems involved during each of the years.
Thus, only one-third of all systems required to conduct UCMR 2
monitoring are assumed to monitor during the ICR period of 2010 - 2012.
The other two-thirds of participating systems would have conducted
monitoring during 2008 and 2009, which was accounted for in the previous
UCMR 2 ICR period of 2007-2009. See Exhibit 3, above, for an
illustration of the time line for system sampling activity. For both
Assessment Monitoring and the Screening Survey, EPA assumes that each
system will incur an estimated burden of 0.5 hours per sampling point to
collect chemical samples for analysis. This monitoring burden includes
receipt of monitoring kit, reading laboratory instructions, and
collection and shipping of samples. It is calculated by: (hour burden
per sampling point) times (number of sampling points) times (number of
systems) times (number of sample events per year). Many ground water
systems may realize savings in their sampling burden as a result of the
allowance to sample at representative EPTDSs. Thus, sampling burden is
calculated to account for the estimated reduction in entry points where
these systems will sample (as described below in section 6(a)(ii), Part
A of this ICR document).

6(a)(i)(c) Reporting and Recordkeeping

	Under UCMR 2, regulated systems are required to report specific
information prior to monitoring, and with their monitoring results. 

Reporting Prior to Monitoring - As with the reading burden (described
above, in Section 6(a)(i)(a)), all initial reporting prior to UCMR 2
monitoring (including proposals for representative EPTDSs) is considered
to be complete, and not part of the applicable ICR period of 2010-2012.
The initial reporting burden was accounted for in the first UCMR 2 ICR
period of 2007-2009, and is included in Appendix B, which presents costs
for the entire UCMR 2 cycle (2007-2011). 

Small systems: EPA assumed that small systems only needed to send and
confirm contact information prior to monitoring. These systems were
allotted a one-time reporting burden of 2 hours.

Large surface water (and GWUDI) systems: EPA assumed that large surface
water/GWUDI systems would send contact and sampling point information,
and were allotted a one-time reporting burden of 6 hours.

Large ground water systems: EPA assumed that large ground water systems
would send contact and sampling point information, which would require a
one-time burden of 6 hours. An additional 8 hours were allotted to some
ground water systems to account for compilation and submission of
representative EPTDS proposal. Since it was unlikely that all systems
would submit these proposals, EPA conservatively assumed that half of
ground water systems serving 10,001 to 100,000 people would compile and
submit this proposal; and assumes that all ground water systems serving
more than 100,000 people would do so. 

Reporting with Monitoring Results

	This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

6(a)(i)(d) Public Notification

	This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

6(a)(ii) Estimating Non-labor Costs

	This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

6(a)(iii) Summary of Labor and Non-labor Costs to Public Water Systems

	Exhibit 5a displays a summary of labor and non-labor costs, by year,
for the three-year ICR period. As previously noted, the UCMR 2 cycle is
2007-2011, and all participating systems are collecting samples between
January 2008 and December 2010, thus the ICR period of 2010-2012
coincides with only one year of UCMR 2 monitoring, and just two years of
program implementation. Information presenting estimated costs over the
five-year UCMR 2 implementation period is provided in Exhibit B-1a, in
Appendix B. Small systems incur labor costs only. Large systems incur
both labor and non-labor costs, as they are responsible for analytical
costs.

	The nationwide cost to systems for implementing the total UCMR program
over the three-year ICR period of 2010-2012 is estimated to be $9.2
million. Large and very large systems are expected to incur about 99
percent of this cost, $9.1 million. Annual cost per small system for
UCMR implementation over the three-year ICR period is estimated to be
$44 per system, all attributed to labor. Annual cost per large system is
estimated to be $114 for labor plus $1,747 for analytical (non-labor)
costs; with very large systems costs of $369 for labor plus $7,260 for
analytical (non-labor) costs. Exhibits 2 and 3 illustrate numbers of
systems participating and timing of monitoring. Per system labor burdens
and costs for the UCMR program are presented in Exhibit 5b. In addition,
this exhibit presents a summary of burden and cost per response.
Analogous information for the five-year implementation period is
provided in Exhibit B-1b, in Appendix B. “Response” is defined as
each required reporting event for a system. All labor and non-labor
costs associated with a reporting event (reading the regulations,
monitoring, and reporting) are included in the per response cost
estimate. 



Exhibit 5a: Yearly Cost to Systems, by System Size and by Type of Cost
(2010-2012)



Cost Description	2010	2011	2012	Total

SMALL SYSTEMS (serving 10,000 or fewer people)

Labor Costs

Reading and Initial Reporting 	$0	$0	$0	$0

Monitoring	$40,693	$0	$0	$40,693

Reporting of Results	$15,814	$0	$0	$15,814

Non-Labor Costs (Laboratory Analysis and Shipping (paid for by EPA))

	$0	$0	$0	$0

Subtotal – Small Systems	$56,506	$0	$0	$56,506

LARGE SYSTEMS (serving 10,001 to 100,000 people)

Labor Costs

Reading and Initial Reporting 	$0	$0	$0	$0

Monitoring	$152,444	$0	$0	$152,444

Reporting of Results	$214,281	$0	$0	$214,281

Non-Labor Costs (Laboratory Analysis and Shipping)

	$5,635,795	$0	$0	$5,635,795

Subtotal – Large Systems	$6,002,521	$0	$0	$6,002,521

VERY LARGE SYSTEMS (serving greater than 100,000 people)

Labor Costs

Reading and Initial Reporting 	$0	$0	$0	$0

Monitoring	$80,865	$0	$0	$80,865

Reporting of Results	$69,428	$0	$0	$69,428

Non-Labor Costs (Laboratory Analysis and Shipping)

	$2,954,765	$0	$0	$2,954,765

Subtotal – Very Large Systems	$3,105,058	$0	$0	$3,105,058

ALL SYSTEMS

Total Labor for 

All Systems	$573,525	$0	$0	$573,525

Total Non-Labor for 

All Systems	$8,590,560	$0	$0	$8,590,560

Total Labor and Non-Labor for All Systems	$9,164,085	$0	$0	$9,164,085

1 Labor costs were estimated by system size and water source by
multiplying estimated burden (as described in Section 6(a)(i)) for each
activity by estimated system labor rates (see Exhibit 4 in Section
6(a)(i)). Non-labor costs were also estimated by system size and water
source, and by multiplying “number of systems” by “number of
sampling points” by “number of required samples” by “lab and
shipping fees”.

Exhibit 5b: Per System (Respondent) and Per Respondent UCMR Costs
(2010-2012)



Burden / Cost	Total over 2010-2012	Annual Average over 2010-2012

	Small Systems	Large Systems	Very Large Systems	Small Systems	Large
Systems	Very Large Systems

PER RESPONDENT: 

Labor Cost	$132	$341	$1,108	$44	$114	$369

Non-Labor Cost	$0	$5,241	$21,780	$0	$1,747	$7,260

Burden (labor hours)	4.7	11.5	31.1	1.6	3.8	10.4

PER RESPONSE: 

Number of Responses per Respondent	2.7	3.1	3.6	0.9	1.0	1.2

Labor Cost per Response	$50	$111	$308	$17	$37	$103

Non-Labor Cost per Response	$0	$1,711	$6,055	$0	$570	$2,018

Burden (labor hours) per Response	1.8	3.8	8.7	0.6	1.3	2.9



6(b)	Estimating the Burden and Cost to States

	Since UCMR is a direct implementation rule, individual State costs will
largely depend on specifications in their PA. EPA assumed that States
will incur only labor costs, because no capital investments are expected
for this second cycle of the program. Because States will be involved in
a variety of UCMR implementation and oversight activities but have few
defined responses, burden estimates are based on yearly activities.
Thus, for “per response” estimates, States are assumed to have an
average of 1.0 response per year during each year of the UCMR 2 cycle;
2007-2011.

	EPA used the “2001 ASDWA Drinking Water Program Resource Needs Self
Assessment” to estimate State burden and cost for the implementation
and oversight of UCMR 2. This assessment tool (or model) was developed
by ASDWA to assist States in estimating the resources needed to
implement their Statewide drinking water programs (in both full-time
equivalent staff (FTEs) and dollars). In 2000, the United States General
Accounting Office had used a previous version of this model to estimate
nationwide drinking water program needs for Congress. The tool was later
updated and improved based on comments from 27 States. To make the model
easier to use, ASDWA established suggested salary and benefit ranges
(i.e., default values), resource needs for the various NPDWRs, and other
key variables. 

	EPA used the defaults values (or average values within a default range)
that were provided in the model to estimate the national burden and cost
for State UCMR 2 activities. Defaults included: 

	•	one FTE is equivalent to 1,800 hours per year; overhead and
holidays, sick leave, etc. are accounted for through default loading of
base salaries;

	•	professional and support staff salaries vary for different sized
States (very small, small, medium, large, very large); and

	•	suggested ranges of FTEs for the implementation of the Phase II/V,
Arsenic, and UCMR programs (i.e., the relevant subsection of the model).

	Understandably, the model had bundled the State resource needs for
Phase II/V, Arsenic, and UCMR, because of the inherent overlap and
similarities in the programs. However, because these programs were
bundled, EPA needed to “extract” the UCMR costs from the aggregated
costs. Based on best professional estimates, and consultations with
staff from three State drinking water programs (California, Connecticut,
and Nebraska) regarding the relative magnitude of the UCMR program, EPA
assumed that: 

during the first UCMR 2 ICR period (2007-2009), preparatory and
organizational activities included State Monitoring Plans finalized,
system notifications sent, and Assessment Monitoring and Screening
Survey monitoring being conducted; thus UCMR 2 was estimated to
represent 3 percent of the bundled program resource needs (though these
are not relevant to the current ICR estimations for 2010-2012); and 

during the last two years of the five-year cycle (2010 and 2011), there
are fewer organizational activities; thus, UCMR 2 is estimated to
represent 1 percent of the bundled program resource needs (applicable to
2 of the 3 ICR years, 2010-2012).

	EPA ran the model for each of the State size categories that were based
on the number of systems for which States have drinking water program
oversight responsibilities. To estimate nationwide costs, the
size-specific “per State” estimates that are generated by the model
were then multiplied by the number of States in each size category, as
shown in Exhibit 6. 

	EPA further refined the model estimates by taking the level of State
participation under UCMR 1 into consideration. EPA reviewed five key
areas of State participation under UCMR 1, including: review and
revision to the State Monitoring Plans; assisting EPA with update to
information for large systems; two separate sets of system
notifications; and compliance assistance. Based on levels of involvement
in each of these UCMR activities, States typically participated in
between 40 and 100 percent of their optional UCMR activities. However,
some States chose not to participate at all. Burden estimates generated
from the resource model were multiplied by this “percent participation
in UCMR 1” to approximate State costs at expected participation levels
under UCMR 2. 

Exhibit 6: Number of States in Each Size Category (State Resource Model
Assumptions)

Size Category	Number of States

Very Small	10

Small	11

Medium	23

Large	10

Very Large	2

Total	56



	EPA estimates that the average annual burden over 3 years (2010-2012)
for 56 States to implement UCMR will be 3,555 hours (or 63.5 hours per
State per year), with an average annual cost (labor only) of $195,921
(or $3,499 per State per year). See Exhibits 7a and 7b for a summary of
estimated State burdens and costs (analogous five-year information for
2007-2011 provided in Exhibits B-2a and B-2b, in Appendix B).

Exhibit 7a: Yearly Cost and Burden to States for Implementation of UCMR
(2010-2012) 



Cost/Burden	2010	2011	2012	Total	Annual Average

Costs to All States for labor related to UCMR implementation and
oversight

	$313,317	$274,447	$0	$587,763	$195,921

Labor burden for all States for UCMR implementation and oversight

	5,371	5,295	0	10,666	3,555



Exhibit 7b: Per State (Respondent) and Per Response UCMR Costs
(2010-2012)



Burden / Cost	Total over 2010-2012	Annual Average 

over 2010-2012

PER RESPONDENT:

Labor Cost	$10,496	$3,499

Non-Labor Cost	$0	$0

Burden (labor hours)	190.5	63.5

PER RESPONSE:

Number Responses per Respondent1	2.0	0.7

Labor Cost per Response	$5,248	$1,749

Non-Labor Cost per Response	$0	$0

Burden (labor hours) per Response	95.2	31.7



6(c)	Estimating Agency Burden and Cost

	EPA will incur burden and costs related to UCMR implementation
activities, including: regulatory support activities; national and
regional oversight and data analysis; and the small system testing
program. These activities are described in detail in section 5(a), Part
A of this ICR document. Labor and contractual costs are estimated using
the federal government general schedule (GS) pay scale; assuming a labor
level of GS 13, step 5, and taken from the Maryland/District of Columbia
rate schedule during the first quarter of 2006 (see the U.S. Office of
Personnel Management Web site: www.opm.gov). With these assumptions,
labor and contractor rates were determined to be $69.46 per hour, based
on a 2,080 hour work year, with a $87,664 annual salary plus a 3 percent
inflation factor for 2007 salaries, and 60 percent overhead. Additional
cost assumptions are described below in sections 6(c)(i)-(iii), Part A
of this ICR document. Cost and burden estimates are presented in
Exhibits 8a and 8b, respectively. 

6(c)(i) Regulatory Support Activities

	Regulatory support activities include the labor and non-labor costs for
laboratory approval process and QA/QC activities; and general technical
support and guidance documents. Cost and burden assumptions for these
activities are as follows: 

Laboratory Approvals and QA/QC Activities: EPA incurs various labor or
contractor costs related to the laboratory PT/approvals; laboratory
QA/QC; and provision of analytical standards, as follows: 

Laboratory approval (PT program) is estimated to have cost EPA $200,000
prior to the beginning of monitoring. Cost estimates from best
professional judgment were based on costs realized by the Agency for
prior similar activities. Costs for the PT program were included within
the 2007 costs to reflect the costs of the UCMR 2 program. Though not
relevant to the applicable ICR period of 2010-2012, these costs are
included in Appendix B, which presents costs for the entire UCMR 2 cycle
(2007-2011). 

QC audits of contract laboratories are occurring throughout active UCMR
monitoring. Labor (hours) for each trip includes: a 3-day site
inspection (for 2 individuals); 1 full-day travel for 2 individuals
(assume 2 half days); and 3 days of report writing (for 1 individual),
which includes review and response to laboratory comments. Travel costs
for 2 individuals include: $500 round trip flight, 3 nights hotel stay,
2 full day food per diem, and 2 days at the proportional meals rate from
the 2006 Federal rate for the Continental U.S. (from the U.S. Government
Services Administration Web site: http://www.gsa.gov). Also included is
$150 for rental of one car for both travelers. It is estimated that
these QC audits will take place 4 times each year, at an estimated
$7,896 per trip (only applicable to this ICR period during 2010). 

Analytical standards provision and coordination is estimated to cost EPA
$600,000 total for three ICR years (or $200,000 per full year of
monitoring). Cost estimates from best professional judgment are based on
costs realized by the Agency for prior similar activities (only
applicable in to this ICR period during 2010). 

Technical Support/Guidance Document Development: These activities are
estimated to cost EPA $150,000 total over the ICR period; including
costs for developing and distributing guidance for laboratories that
will participate in UCMR 2 testing; health effects fact sheets; and
other pertinent guidance related to UCMR 2 implementation. These
activities took place in the previous UCMR 2 ICR period of 2007-2009,
and thus are not applicable to this ICR period (2010-2012). However,
these costs are included in Appendix B, which presents costs for the
entire UCMR 2 cycle (2007-2011). Cost estimates from best professional
judgment are based on costs realized by the Agency for prior similar
activities.

6(c)(ii) National and Regional Oversight and Data Analysis

	EPA activities include data analysis, management oversight, and support
at both the regional and national level for assistance to States with
UCMR implementation. During the core period of UCMR 2 activity
(2008-2010), EPA is dedicating approximately 5.5 FTEs each year to
program oversight and data analysis. During 2011, scheduled monitoring
will be complete, thus, only data analysis and follow-up activities will
take place. EPA estimates that during 2011, approximately 2.75 FTEs will
be needed. This final year of data analysis was not included in the
previous UCMR 2 ICR estimations. These activities are estimated as labor
cost and burden to the Agency (see the corresponding description of
these activities in section 5(a)(ii), Part A of this ICR document).
These activities are estimated to cost EPA $1.19 million in total over
the three-year ICR period of 2010-2012. 

6(c)(iii) Costs for Small System Testing Program

	EPA provides logistical support for the small system testing program.
This activity includes costs for contractual labor and sampling
supplies, and is estimated at $400 per sampling event per sampling site,
based on actual costs incurred during UCMR 1 for this same activity.
These activities are estimated to cost EPA $1.16 million in total over
the three ICR years of 2010-2012. 

	The single largest cost to EPA for implementation of UCMR is for small
system sample analyses. EPA pays for small system sample analyses and
shipping for Assessment Monitoring and Screening Survey. EPA also pays
for quality control duplicates for 10 percent of all samples. 

	As estimated for large systems, shipping fees were calculated per
required sample (accounting for both the representative EPTDS allowance,
and the additional DSMRT samples, as described above in section
6(a)(ii), Part A of this ICR document). To address public comments to
the proposed rule ICR, EPA revisited key shipping company pricing lists
to ensure that shipping cost assumptions were as accurate and current as
possible. Estimated shipping costs were based on the average cost of
shipping a 15-pound package overnight; plus a ground shipment of the
empty package which is sent to the PWSs prior to their required
sampling. Specifically, EPA approximated that, for each sampling point,
a package of empty sample bottles is shipped via ground transportation
to the system; estimated at $7.50 per package. Following sample
collection, the system sends the package with full bottles via overnight
air back to the laboratory. To estimate the cost of this overnight
shipment, EPA applied the approximate cost of shipping a 15-pound
package across an average number of shipping zones at $68.50. For small
systems, shipping includes the cost for one extra ground trip, for
sending the empty bottles from the laboratory to the sampling
coordinator, so that the sampling kit can be reused. Thus, shipping cost
for a small PWS is estimated at $83.50 per sample set. 

	These analytical and shipping fees are estimated to cost EPA $1.8
million in total over the three ICR years of 2010-2012. See section
6(a)(ii), Part A of this ICR document, for assumptions regarding
applicable laboratory fees for individual methods. Total costs that EPA
will incur for the small system testing program were calculated by
multiplying the laboratory and shipping fees by: (number of systems)
times (number of sampling periods per year (including an additional 10
percent QA samples)) times (number of sampling points per system). 

6(c)(iv) Estimated Agency Cost and Burden

	The EPA cost for the UCMR 2 program during the ICR period of 2010-2012
is estimated to be $4.43 million (with annual average cost over the ICR
period of $1.48 million). EPA costs for UCMR implementation are shown in
Exhibit 8a; average annual labor and non-labor costs, as well as small
system testing program costs are shown in Exhibit 8b. Appendix B,
Exhibits B-3a and B-3b provide analogous information over the five-year
UCMR 2 implementation period 2007-2011. 

Exhibit 8a: Yearly Cost to EPA for UCMR Implementation, by Type of Cost
(2010-2012)



Cost Description	2010	2011	2012	Total	Average

Regulatory Support Activities: laboratory proficiency testing; QC
audits; analytical standards provision; and technical support, guidance
document development (non-labor costs) 

Lab PT	$0	$0	$0	$0	$0

QC Audits	$31,582	$0	$0	$31,582	$10,527

Analytical Standards	$200,000	$0	$0	$200,000	$66,667

Technical Support	$0	$0	$0	$0	$0

Subtotal – 

Regulatory Support	$231,582	$0	$0	$231,582	$77,194

National and Regional Oversight and Data Analysis: UCMR management
oversight; review and evaluation of data from Assessment Monitoring
(labor costs)

	$794,622	$397,311	$0	$1,191,934	$397,311

Small System Testing: implementation coordination; and analytical and
shipping costs for small system testing for both Assessment Monitoring
and Screening Surveys (non-labor costs)

Implementation Coordination	$1,163,562	$0	$0	$1,163,562	$387,854

Fees for Analysis and shipping	$1,844,421	$0	$0	$1,844,421	$614,807

Subtotal – 

Small System Testing	$3,007,983	$0	$0	$3,007,983	$1,002,661

TOTAL	$4,034,187	$397,311	$0	$4,431,498	$1,477,166

  

Exhibit 8b: Summary of EPA Burdens and Costs for UCMR Implementation
(2010-2012)



Burden/Cost	Annual Average Burden/Cost over Three-year 

ICR Period of 2010-2012

Labor Cost	$397,311

Non-Labor Cost	$1,079,855

Total Cost to EPA for UCMR Implementation	$1,477,166

Burden (labor hours)	5,720



6(d)	Estimating the Respondent Universe and Total Burden and Costs

	For the UCMR 2 cycle of 2007-2011, the universe of respondents includes
4,913 PWS respondents, comprised of non-purchased CWSs and non-purchased
NTNCWSs, as well as 56 State respondents. Assessment Monitoring will be
conducted by 800 systems serving 10,000 or fewer people, plus all 3,633
systems that serve more than 10,000 people. Screening Survey monitoring
is being conducted by 800 systems serving 100,000 or fewer people, plus
all 407 serving more than 100,000 people. As described previously, PWS
sampling is conducted four times during the monitoring year for surface
water/GWUDI sampling locations, and twice for ground water sampling
locations (i.e., frequency of response depends on water source). States
will be involved in a variety of UCMR implementation and oversight
activities, but have few defined responses; thus, States are assumed to
have an average of 1 response per year (during active UCMR years 2010
and 2011, or two-thirds of the ICR period of 2010-2012). 

	Exhibit 9 summarizes national hours and costs for UCMR 2 during the ICR
period of 2010-2012. Analogous information for the entire five-year UCMR
2 cycle of 2007-2011 is presented in Exhibit B-4 in Appendix B.  The
total labor and non-labor costs are presented for each category of
respondent. The total labor burden to small systems is 2,022 hours, with
a cost of $56,506 (small systems only incur labor costs, EPA pays for
all laboratory fees and shipping costs). The total labor burden to large
systems is 12,370 hours, with a labor cost of $366,726, and non-labor
costs for analysis and shipping of $5.64 million. Very large systems are
estimated to have a total labor burden for the ICR period of 4,226
hours, with a labor and non-labor costs of $150,293 and $2.95 million,
respectively. The total burden to States over the three-year ICR period
is 10,666 hours, with a labor cost of $0.59 million. EPA anticipates
that States will not incur any significant non-labor costs. The EPA
total burden over the same time frame is 17,160 hours, with labor costs
of $1.19 million, and non-labor costs of $3.24 million.

Exhibit 9: UCMR 2 National Cost Summary for the ICR period (2010-2012)1



Type of Cost	2010	2011	2012	TOTAL

Small Systems 

Labor Cost	$56,506	$0	$0	$56,506

Non-Labor Cost	$0	$0	$0	$0

Total Small System Cost	$56,506	$0	$0	$56,506

Large Systems

Labor Cost	$366,726	$0	$0	$366,726

Non-Labor Cost	$5,635,795	$0	$0	$5,635,795

Total Large System Cost	$6,002,521	$0	$0	$6,002,521

Very Large Systems

Labor Cost	$150,293	$0	$0	$150,293

Non-Labor Cost	$2,954,765	$0	$0	$2,954,765

Total Very Large 

System Cost	$3,105,058	$0	$0	$3,105,058

States

Labor Cost	$313,317	$274,447	$0	$587,763

Non-Labor Cost	$0	$0	$0	$0

Total State Cost	$313,317	$274,447	$0	$587,763

EPA2

Labor Cost	$794,622	$397,311	$0	$1,191,934

Non-Labor Cost	$3,239,565	$0	$0	$3,239,565

Total EPA Cost	$4,034,187	$397,311	$0	$4,431,498

National Total

Total with EPA	$13,511,589	$671,758	$0	$14,183,346

Total without EPA	$9,477,402	$274,447	$0	$9,751,848

Total Burden (hours) for All Responses

Small Systems	2,022	0	0	2,022

Large Systems	12,370	0	0	12,370

Very Large Systems	4,226	0	0	4,226

States	5,371	5,295	0	10,666

EPA	11,440	5,720	0	17,160

Total with EPA	35,429	11,015	0	46,443

Total without EPA	23,989	5,295	0	29,284

1.  See Exhibit 5a for further PWS cost estimation details.

2. Although EPA is not considered a respondent to the UCMR regulations,
Agency burdens are shown here to illustrate the national costs of the
program. National totals are shown with and without the Agency costs.

6(e)	Reasons for Change in Burden

	The renewal of this ICR will result in an overall decrease of 91,875
hours in the total estimated respondent burden identified in the
currently approved ICR. The reasons that respondents to UCMR 2 will
incur a different burden during this second ICR period of 2010-2012,
than respondents incurred during the first UCMR 2 ICR period of
2007-2009 include: 

Fewer PWSs participating during this ICR period: UCMR 2 monitoring takes
place from 2008-2010, with approximately 1/3 of systems participating in
each of those three years.  Thus, during the first ICR period of
2007-2009, approximately 2/3 of participating systems (~ 3,275 systems)
completed their required monitoring, and during the second ICR period of
2010-2012, the remaining 1/3 (~ 1,638 systems) will complete their
required monitoring. See Section 6(a)(i) Estimating Burden and Labor
Costs for detailed explanations.

Schedule of activities for PWSs different during this ICR period: Some
initial activities were assumed to be conducted by all systems during
2007 (or prior to monitoring), including reading regulations, and
reporting prior to monitoring (contact and sampling location
information, and representative EPTDS proposals). Thus, there are some
PWS activities that took place during the first UCMR 2 ICR period of
2007-2009, that will not take place during the second ICR period of
2010-2012. See Section 4(b)(ii)(a) Public Water System Activities for
detailed explanations. 

Schedule of activities also different for participating States and EPA:
Management and support activities for States and EPA also vary with the
UCMR 2 monitoring schedule. Thus, both States and EPA are expected to
have different burdens during this second UCMR 2 ICR period of
2010-2012. See Section 4(b)(ii)(b) State Activities and Section 5(a)
Agency Activities for details.

6(f)	Burden Statement

	With respect to per system burden estimates, EPA notes that all burden
estimates represent average burden hours, which include surface water
systems that may have very few sampling points, and thus lower sampling
burden, as well as those systems with higher numbers of sampling points
that would therefore have greater sampling activity labor burden.
Moreover, a system’s burden is primarily incurred during its one year
of required UCMR monitoring (between January 2008 and December 2010). In
compliance with the requirements of the Paperwork Reduction Act (44
U.S.C. 3501 et seq.), these cost and burden estimates are presented as
an average over the applicable three-year ICR period (2010-2012). Small
systems (those serving 10,000 or fewer people) have the lowest burden
not only because of the relative smaller size of their infrastructure,
but also because these systems will receive a great deal of direct
assistance from EPA and/or their State. 

	Small systems (those serving 10,000 or fewer) that are selected for
UCMR 2 monitoring will sample an average of 2.7 times per system (i.e.,
number of responses per system) across the three-year ICR period of
2010-2012. The average total burden per response for small systems is
estimated to be 1.8 hours. Large systems (those serving 10,001 to
100,000) and very large systems (those serving more than 100,000) will
sample and report an average of 3.1 and 3.6 times per system,
respectively, across the three-year ICR period of 2010-2012. The average
total burdens per response for large and very large systems are
estimated to be 3.8 and 8.7 hours, respectively. The larger burden per
response for the very large systems reflects the fact that these systems
typically have more sampling locations than large systems. States are
assumed to incur 2 responses over the three-year ICR period related to
coordination with EPA and systems, with an average burden per response
of 95.2 hours. In aggregate, during the ICR period of 2010-2012, the
average response (e.g., responses from systems and States) is associated
with a total burden of 5.8 hours, with a labor plus non-labor cost of
$1,939 per response. 

	The annual average per respondent burden hours and costs for the ICR
period of 2010-2012 are: small systems — 1.6 hour burden at $44 for
labor; large systems — 3.8 hours at $114 for labor, and $1,747 for
analytical costs; very large systems — 10.4 hours at $369 for labor,
and $7,260 for analytical costs; and States — 63.5 hours at $3,499 for
labor. Annual average burden and cost per respondent (including both
systems and States) is estimated to be 5.8 hours, with a labor plus
non-labor cost of $1,919 per respondent (note that small systems do not
pay for testing costs, so they only incur labor costs). The total annual
burden for the ICR reporting period of 2010-2012 is 9,761 (with a labor
cost of $387,096); the total annual analytical cost is $2.86 million.

	The Agency estimates the annual burden to EPA for UCMR program
activities during the ICR years of 2010-2012 to be 5,720 hours, at an
annual labor cost of $0.4 million. EPA’s annual non-labor costs are
estimated to be $1.1 million. Non-labor costs are primarily attributed
to the cost of sample testing for small systems (testing is just under
90 percent of non-labor).

	Exhibit 10 presents per respondent and per response burdens and costs
over the UCMR ICR period of 2010-2012 (analogous information for the
2007-2011 UCMR 2 implementation period is provided in Exhibit B-5,
Appendix B).. This exhibit also presents average annual burdens and
costs. 

Exhibit 10: UCMR 2 Per Respondent Burden and Cost Summary for the ICR
Period (2010-2012)



Burden (hours)/ 

Cost (dollars)	Small Systems	Large Systems	Very Large Systems	States	EPA
National Average with EPA1	National Average without EPA

Three-Year Total per Respondent

Total # of Responses Per Respondent	2.7	3.1	3.6	2.0	n/a	n/a	3.0

Labor Cost Per Respondent	$132	$341	$1,108	$10,496	$1,191,934	$1,389
$686

Non-Labor Cost Per Respondent	$0	$5,241	$21,780	$0	$3,239,565	$6,981
$5,072

Total Cost (Labor plus Non-Labor)	$132	$5,582	$22,887	$10,496	$4,431,498
$8,369	$5,758

Total Cost Per Response	$50	$1,822	$6,363	$5,248	n/a	n/a	$1,939

Total Burden Per Respondent (hours)	4.7	11.5	31.1	190.5	17,160.0	27.4
17.3

Total Burden Per Response (hours)	1.8	3.8	8.7	95.2	n/a	n/a	5.8

Average Annual per Respondent

Ave. # of Responses Per Respondent	0.9	1.0	1.2	0.7	n/a	n/a	1.0

Labor Cost Per Respondent	$44	$114	$369	$3,499	$397,311	$463	$229

Non-Labor Cost Per Respondent	$0	$1,747	$7,260	$0	$1,079,855	$2,327
$1,691

Ave. Cost (Labor plus Non-Labor)	$44	$1,861	$7,629	$3,499	$1,477,166
$2,790	$1,919

Ave. Cost Per Response	$17	$607	$2,121	$1,749	n/a	n/a	$646

Ave. Burden Per Respondent (hours)	1.6	3.8	10.4	63.5	5,720.0	9.1	5.8

Ave. Burden Per Response (hours)	0.6	1.3	2.9	31.7	n/a	n/a	1.9

1 National average burdens and costs differ greatly between the State
respondents and the various system respondents. This should be taken
into consideration when looking at the national average with or without
EPA. PWS labor costs were estimated by system size and water source by
multiplying estimated burden (as described in Section 6(a)(i)) for each
activity by estimated system labor rates (see Exhibit 4 in Section
6(a)(i)). Non-labor costs were also estimated by system size and water
source, and by multiplying “number of systems” by “number of
sampling points” by “number of required samples” by “lab and
shipping fees”. All burden and cost estimation assumptions for systems
and States are described in Section 6(a) and 6(b) in Part A of this
document. Average “per respondent” costs were derived by dividing
through by the number of respondents from each category. 

	This UCMR is necessary for several reasons. Its primary purpose is to
support the development of the CCL, the Administrator’s determination
of whether to regulate a contaminant, and regulation development. The
data collected under UCMR may also be used as a basis for determining
exposure, for establishing the baseline for health effects and economic
analyses, for contaminant co-occurrence analyses, and for treatment
technology evaluation, including contaminant source management. Further,
the data may indicate the need to initiate research on health effects
and treatment technology research, if they suggest that certain
contaminants have significant occurrence. Finally, as a secondary use,
the data may guide future source water protection efforts.

	Burden means the total time, effort, or financial resources expended by
persons to generate, maintain, retain, or disclose or provide
information to or for a Federal agency. This includes the time needed to
review instructions; develop, acquire, install, and utilize technology
and systems for the purposes of collecting, validating, and verifying
information, processing and maintaining information, and disclosing and
providing information; adjust the existing ways to comply with any
previously applicable instructions and requirements; train personnel to
be able to respond to a collection of information; search data sources;
complete and review the collection of information; and transmit or
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. 

	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 Number
OW xxxxx, which is available for online viewing at   HYPERLINK
"http://www.regulations.gov"  www.regulations.gov , or in person viewing
at the Water Docket in the EPA Docket Center (EPA/DC), EPA West, Room
B102, 1301 Constitution Avenue, NW, Washington, D.C. 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 at   HYPERLINK "http://www.regulations.gov" 
www.regulations.gov . This site can be used 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. When 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, NW, Washington, D.C. 20503, Attention: Desk
Officer for EPA. Please include the EPA Docket ID Number (OW 2009-0089)
and OMB Control Number OMB Control No. 2040-0270 in any correspondence.



	— PART B OF THE SUPPORTING STATEMENT —

1	SURVEY OBJECTIVES, KEY VARIABLES, AND OTHER PRELIMINARIES

1(a)	Survey Objectives

This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

1(b)	Key Variables

This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

1(c)	Statistical Approach

This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

1(d)	Feasibility

This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

2	SURVEY DESIGN

2(a)	Target Population and Coverage

This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

2(b)	Sample Design

2(b)(i) Sampling Frame

This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

2(b)(ii) Sample Size

This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

2(b)(iii) Stratification Variables

This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

2(b)(iv) Sampling Method

This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

2(b)(v) Multi-Stage Sampling

This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

2(c)	Precision Requirements

2(c)(i) Precision Targets

This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

2(c)(ii) Nonsampling error

This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

2(d)	Questionnaire Design

This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

3	PRETESTS AND PILOT TESTS

This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

4	COLLECTION METHODS AND FOLLOW-UP

4(a)	Collection Methods

This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

4(b)	Survey Response and Follow-up

This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

5	ANALYZING AND REPORTING SURVEY RESULTS

5(a)	Data Preparation

This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

5(b)	Analysis

This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

5(c)	Reporting Results

This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.



— APPENDICES —APPENDIX A: Relevant Authorities in the SDWA 1996
Amendments

A

This section has not changed as compared to the UCMR 2 ICR for
2007-2009: EPA ICR No. 2192.02; OMB Number 2040-0270.

APPENDIX B: Burden and Cost Exhibits for the Five-Year UCMR 2 Cycle of
2007-2011

B

Exhibit B-1a: Yearly Cost to Systems, by System Size and by Type of Cost
(2007-2011)

(corresponds to Exhibit 6a)

Cost Description	2007	2008	2009	2010	2011	Total

SMALL SYSTEMS (serving 10,000 or fewer people)

Labor Costs

Reading and Initial Reporting 	$106,942	$0	$0	$0	$0	$106,942

Monitoring	$0	$40,693	$40,693	$40,693	$0	$122,078

Reporting of Results	$0	$15,814	$15,814	$15,814	$0	$47,441

Non-Labor Costs (Laboratory Analysis and Shipping (paid for by EPA))

	$0	$0	$0	$0	$0	$0

Subtotal – Small Systems	$106,942	$56,506	$56,506	$56,506	$0	$276,460

LARGE SYSTEMS (serving 10,001 to 100,000 people)

Labor Costs

Reading and Initial Reporting 	$1,173,506	$0	$0	$0	$0	$1,173,506

Monitoring	$0	$152,444	$152,444	$152,444	$0	$457,333

Reporting of Results	$0	$214,281	$214,281	$214,281	$0	$642,843

Non-Labor Costs (Laboratory Analysis and Shipping)

	$0	$5,635,795	$5,635,795	$5,635,795	$0	$16,907,385

Subtotal – Large Systems	$1,173,506	$6,002,521	$6,002,521	$6,002,521
$0	$19,181,068

VERY LARGE SYSTEMS (serving greater than 100,000 people)

Labor Costs

Reading and Initial Reporting 	$225,998	$0	$0	$0	$0	$225,998

Monitoring	$0	$80,865	$80,865	$80,865	$0	$242,594

Reporting of Results	$0	$69,428	$69,428	$69,428	$0	$208,285

Non-Labor Costs (Laboratory Analysis and Shipping)

	$0	$2,954,765	$2,954,765	$2,954,765	$0	$8,864,295

Subtotal – Very Large Systems	$225,998	$3,105,058	$3,105,058
$3,105,058	$0	$9,541,172

ALL SYSTEMS

Total Labor for 

All Systems	$1,506,446	$573,525	$573,525	$573,525	$0	$3,227,021

Total Non-Labor for All Systems	$0	$8,590,560	$8,590,560	$8,590,560	$0
$25,771,680

Total Labor and Non-Labor for All Systems	$1,506,446	$9,164,085
$9,164,085	$9,164,085	$0	$28,998,701



Exhibit B-1b: Per System (Respondent) and Per Response UCMR Costs
(2007-2011)

(corresponds with Exhibit 6b)

Burden / Cost	Total over 2007-2011	Annual Average over 2007-2011

	Small Systems	Large Systems	Very Large Systems	Small Systems	Large
Systems	Very Large Systems

PER RESPONDENT:

Labor Cost	$216	$705	$1,663	$43	$141	$333

Non-Labor Cost	$0	$5,241	$21,780	$0	$1,048	$4,356

Burden (labor hours)	7.7	23.8	46.8	1.5	4.8	9.4

PER RESPONSE:

Number Responses per Respondent	2.7	3.1	3.6	0.5	0.6	0.7

Labor Cost per Response	$81	$230	$462	$16	$46	$92

Non-Labor Cost per Response	$0	$1,711	$6,055	$0	$342	$1,211

Burden (labor hours) per Response 	2.9	7.8	13.0	0.6	1.6	2.6



Exhibit B-2a: Yearly Cost and Burden to States for Implementation of
UCMR (2007-2011)

(corresponds with Exhibit 8a)1

Cost/Burden	2007	2008	2009	2010	2011	Total	Annual Average

Costs to All States for labor related to UCMR implementation and
oversight

	$617,360	$648,343	$600,227	$313,317	$274,447	$2,453,694	$490,739

Labor burden for all States for UCMR implementation and oversight

	11,635	11,861	10,649	5,371	5,295	44,811	8,962

1. Costs are attributed to labor and are estimated over the period
2007-2011. 

Exhibit B-2b: Per State (Respondent) and Per Response UCMR Costs
(2007-2011)

(corresponds with Exhibit 8b)

Burden / Cost	Total over 2007-2011	Annual Average 

over 2007-2011

PER RESPONDENT:

Labor Cost	$43,816	$8,763

Non-Labor Cost	$0	$0

Burden (labor hours)	800.2	160.0

PER RESPONSE:

Number Responses per Respondent1	5.0	1.0

Labor Cost per Response	$8,763	$1,753

Non-Labor Cost per Response	$0	$0

Burden (labor hours) per Response	160.0	32.0

1. States are assumed to have 1 response per year during the UCMR 2
cycle of 2007-2011, since there are no specific cyclical State reporting
requirements under the UCMR program. 

Exhibit B-3a: Yearly Cost to EPA for UCMR Implementation, by Type of
Cost (2007-2011) 

(corresponds with Exhibit 9a)1

Cost Description	2007	2008	2009	2010	2011	Total	Average

Regulatory Support Activities: laboratory proficiency testing; QC
audits; analytical standards provision; and technical support, guidance
document development (non-labor costs)

Lab PT	$200,000	$0	$0	$0	$0	$200,000	$40,000

QC Audits	$0	$31,582	$31,582	$31,582	$0	$94,746	$18,949

Analytical Standards	$0	$200,000	$200,000	$200,000	$0	$600,000	$120,000

Technical Support	$100,000	$50,000	$0	$0	$0	$150,000	$30,000

Subtotal – 

Regulatory Support	$300,000	$281,582	$231,582	$231,582	$0	$1,044,746
$208,949

National and Regional Oversight and Data Analysis: UCMR management
oversight; review and evaluation of data from Assessment Monitoring
(labor costs)

	$397,311	$794,622	$794,622	$794,622	$397311	$3,178,490	$635,698

Small System Testing: implementation coordination; and analytical and
shipping costs for small system testing for both Assessment Monitoring
and Screening Surveys (non-labor costs)

Implementation Coordination	$0	$1,163,562	$1,163,562	$1,163,562	$0
$3,490,686	$698,137

Fees for Analysis and shipping	$0	$1,844,421	$1,844,421	$1,844,421	$0
$5,533,262	$1,106,653

Subtotal – 

Small System Testing	$0	$3,007,983	$3,007,983	$3,007,983	$0	$9,023,948
$1,804,790

TOTAL	$697,311	$4,084,187	$4,034,187	$4,034,187	$0	$13,247,184
$2,649,437

1. Agency costs are estimated over the period 2007-2011. Though some
start-up costs likely began in 2006, costs are presented beginning in
2007, with beginning of rule implementation activities.

Exhibit B-3b: Summary of EPA Burdens and Costs for UCMR Implementation
(2007-2011)

(corresponds with Exhibit 9b)

Burden / Cost	Annual Average Cost over (2007-2011)

Labor Cost	$635,698

Non-Labor Cost	$2,013,739

Total Cost to EPA for UCMR Implementation	$2,649,437

Burden (labor hours)	9,152



Exhibit B-4: National Cost Summary for UCMR 2 Implementation
(2007-2011)1

(corresponds with Exhibit 10)

Type of Cost	2007	2008	2009	2010	2011	TOTAL

Small Systems

Labor Cost	$106,942	$56,506	$56,506	$56,506	$0	$276,460

Non-Labor Cost	$0	$0	$0	$0	$0	$0

Total Small System Cost	$106,942	$56,506	$56,506	$56,506	$0	$276,460

Large Systems

Labor Cost	$1,173,506	$366,726	$366,726	$366,726	$0	$2,273,683

Non-Labor Cost	$0	$5,635,795	$5,635,795	$5,635,795	$0	$16,907,385

Total Large System Cost	$1,173,506	$6,002,521	$6,002,521	$6,002,521	$0
$19,181,068

Very Large Systems

Labor Cost	$225,998	$150,293	$150,293	$150,293	$0	$676,877

Non-Labor Cost	$0	$2,954,765	$2,954,765	$2,954,765	$0	$8,864,295

Total Very Large 

System Cost	$225,998	$3,105,058	$3,105,058	$3,105,058	$0	$9,541,172

States

Labor Cost	$617,360	$648,343	$600,227	$313,317	$274,447	$2,453,694

Non-Labor Cost	$0	$0	$0	$0	$0	$0

Total State Cost	$617,360	$648,343	$600,227	$313,317	$274,447	$2,453,694

EPA2

Labor Cost	$397,311	$794,622	$794,622	$794,622	$397,311	$3,178,490

Non-Labor Cost	$300,000	$3,289,565	$3,239,565	$3,239,565	$0	$10,068,694

Total EPA Cost	$697,311	$4,084,187	$4,034,187	$4,034,187	$0	$13,247,184

National Total

Total with EPA	$2,821,118	$13,896,615	$13,798,499	$13,511,589	$671,758
$44,699,578

Total without EPA	$2,123,806	$9,812,428	$9,764,312	$9,477,402	$274,447
$31,452,394

Total Burden (hours) for All Responses

Small Systems	3,840	2,022	2,022	2,022	0	9,905

Large Systems	39,584	12,370	12,370	12,370	0	76,694

Very Large Systems	6,354	4,226	4,226	4,226	0	19,031

States	11,635	11,861	10,649	5,371	5,295	44,811

EPA	5,720	11,440	11,440	11,440	5,720	45,760

Total with EPA	67,133	41,918	40,706	35,428	11,015	196,201

Total without EPA	61,413	30,478	29,266	23,988	5,295	150,441

1. During 2007, all systems are assumed to incur some reading and
reporting burden, as described in Part A, Section 4(b)(ii)(a) of this
document. See Exhibit 6a for further PWS cost estimation details.

2. Although EPA is not considered a respondent to the UCMR regulations,
Agency burdens are shown here to illustrate the national costs of the
program. National totals are shown with and without the Agency costs.

Exhibit B-5: UCMR 2 Per Respondent Burden and Cost Summary (2007-2011)

(corresponds with Exhibit 11)

Burden (hours)/ 

Cost (dollars)	Small Systems	Large Systems	Very Large Systems	States	EPA
National Average with EPA1 	National Average without EPA

Five-Year Total per Respondent

Total # of Responses Per Respondent	2.7	3.1	3.6	5.0	n/a	n/a	3.0

Labor Cost Per Respondent	$216	$705	$1,663	$43,816	$3,178,490	$1,783
$1,143

Non-Labor Cost Per Respondent	$0	$5,241	$21,780	$0	$10,068,694	$7,211
$5,186

Total Cost (Labor plus Non-Labor)	$216	$5,946	$23,443	$43,816
$13,247,184	$8,994	$6,330

Total Cost Per Response	$81	$1,941	$6,517	$8,763	n/a	n/a	$2,093

Total Burden Per Respondent	7.7	23.8	46.8	800.2	45,760.0	39.5	30.3

Total Burden Per Response	2.9	7.8	13.0	160.0	n/a	n/a	10.0

Average Annual per Respondent

Ave. # of Responses Per Respondent	0.5	0.6	0.7	1.0	n/a	n/a	0.6

Labor Cost Per Respondent	$43	$141	$333	$8,763	$635,698	$357	$229

Non-Labor Cost Per Respondent	$0	$1,048	$4,356	$0	$2,013,739	$1,442
$1,037

Ave. Cost (Labor plus Non-Labor)	$43	$1,189	$4,689	$8,763	$2,649,437
$1,799	$1,266

Ave. Cost Per Response	$16	$388	$1,303	$1,753	n/a	n/a	$419

Ave. Burden Per Respondent	1.5	4.8	9.4	160.0	9,152.0	7.9	6.1

Ave. Burden Per Response	0.6	1.6	2.6	32.0	n/a	n/a	2.0

1. National average burdens and costs differ greatly between the State
respondents and the various system respondents. This should be taken
into consideration when looking at the national average with or without
EPA. PWS labor costs were estimated by system size and water source by
multiplying estimated burden (as described in Section 6(a)(i)) for each
activity by estimated system labor rates (see Exhibit 4 in Section
6(a)(i)). Non-labor costs were also estimated by system size and water
source, and by multiplying “number of systems” by “number of
sampling points” by “number of required samples” by “lab and
shipping fees”. All burden and cost estimation assumptions for systems
and States are described in Section 6(a) and 6(b) in Part A of this
document. Average “per respondent” costs were derived by dividing
through by the number of respondents from each category. 

	 Transient non-community water systems and those systems that purchase
all of their water from another PWS
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Draft ICR for UCMR 2 Proposed Rule	May 2005

  PAGE  B-5 

