United States

Environmental Protection

Agency

Office of Water

(4606)

EPA 816-R-01-020

July 2001

www.epa.gov/safewater

Economic Analysis 

for the 

Filter Backwash

Recycling Rule 
FBRR Final RIA -i- April, 2001

TABLE OF CONTENTS

1. Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1–1

1.1 Need for the Proposal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1–1

1.2 Consideration of Regulatory Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1–3

1.3 Baseline Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1–3

1.4 Benefits of the FBRR . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1–4

1.5 Costs of the FBRR . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1–5

1.6 Economic Impact Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1–6

1.7 Weighing of Benefits and Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1–7

2. Need for the Proposal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2–1

2.1 Issue Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2–2

2.1.1 Treatment Processes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2–2

2.1.2 Recycling Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2–4

2.1.3 Recycle Flows . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2–6

2.2 Public Health Concerns . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2–7

2.2.1 Contaminants and Their Associated Health Effects . . . . . . . . . . . . . . . 2–7

2.2.2 Sensitive Subpopulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2–8

2.2.3 Sources of Contaminants . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2–8

2.2.4 Waterborne Disease Outbreaks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2–9

2.2.5 Filter Backwash and Other Process Flows: Occurrence and Impact 

Studies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2–11

2.2.6 Current Control and Potential for Improvement ................. 2–15

2.3 Regulatory History and Current Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2–16

2.3.1 1979 Total Trihalomethane Rule ............................. 2–16

2.3.2 Surface Water Treatment Rule ............................... 2–16

2.3.3 Information Collection Rule ................................ 2–16

2.3.4 Interim Enhanced Surface Water Treatment Rule ................ 2–17

2.3.5 Stage 1 Disinfection Byproduct Rule .......................... 2–17

2.3.6 Long Term 1 Enhanced Surface Water Treatment Rule ........... 2–18

2.3.7 Stakeholder Involvement ................................... 2–18

2.4 Economic Rationale . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2–19

2.4.1 Introduction ............................................. 2–19

2.4.2 Statutory Authority for Promulgating the Rule .................. 2–19

2.4.3 The Economic Rationale for Regulation ....................... 2–20

2.5 Rule Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2–21

3. Consideration of Regulatory Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3–1

3.1 Recycle Provisions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3–1

3.2 EPA’s Selected Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3–4
FBRR Final RIA -ii- April, 2001

4. Baseline Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4–1

4.1 Baseline Profile of Surface Water and GWUDI Systems . . . . . . . . . . . . . . . . . 4–2

4.1.1 Number of Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4–3

4.1.2 Population Served . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4–5

4.2 Profile of Systems Subject to the FBRR . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4–6

4.2.1 Profile of Filtration Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4–6

4.2.2 Profile of Recycling Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4–8

4.3 Profile of Systems Subject to Each FBRR Provision . . . . . . . . . . . . . . . . . . . 4–10

4.3.1 Recycle Return Location ................................... 4–10

4.3.2 Conventional Filtration Recycle Reporting ..................... 4–11

4.3.3 Direct Filtration Recycling Reporting ......................... 4–12

4.3.4 Systems Serving More Than 1 Million Persons .................. 4–13

5. Benefits Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5–1

5.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5–1

5.2 Risk Associated with the Recycle of Filter Backwash . . . . . . . . . . . . . . . . . . . . 5–2

5.2.1 Reduction in Cryptosporidium . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5–3

5.2.2 Reduction of Other Pathogens . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5–6

5.2.3 Reduction in Outbreak Risk . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5–6

5.2.4 Cost to Households to Avert Infection . . . . . . . . . . . . . . . . . . . . . . . . . . 5–7

5.3 Health Benefits from Recycle Provisions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5–7

5.4 Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5–10

6. Cost Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6–1

6.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6–1

6.1.1 Cost Assumptions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6–1

6.2 FBRR Cost Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6–4

6.2.1 Startup Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6–4

6.2.2 Recycle to New Return Location . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6–5

6.2.3 Conventional Filtration Recycle Reporting Costs . . . . . . . . . . . . . . . . . 6–8

6.2.4 Direct Filtration Recycle Reporting Costs ...................... 6–10

6.3 Summary of Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6–13

6.3.1 Omissions, Biases, and Uncertainty ........................... 6–15

6.4 Household Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6–16

6.5 Cost of Regulatory Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6–18

7. Economic Impact Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7–1

7.1 Impacts on Governments and Business Units . . . . . . . . . . . . . . . . . . . . . . . . . . 7–2

7.1.1 Indian Tribal Governments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7–2

7.1.2 Regulatory Flexibility Act and Small Business Regulatory 

Enforcement Fairness Act . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7–2

7.1.3 Effect of Compliance With the FBRR on the Technical, 

Financial, and Managerial Capacity of Public Water Systems . . . . . . . 7–5

7.1.4 Paperwork Reduction Act . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7–7

7.1.5 Unfunded Mandates Reform Act . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7–8

7.2 Impacts on Subpopulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7–9
FBRR Final RIA -iii- April, 2001

7.2.1 Impacts on the Immunocomprimised . . . . . . . . . . . . . . . . . . . . . . . . . . . 7–9

7.2.2 Protecting Children From Environmental Health and Safety Risks . . 7–10

7.3 Environmental Justice . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7–11

8. Weighing the Benefits and the Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8–1

8.1 Incremental and Marginal Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8–1

8.2 Benefit-Cost Comparisons . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8–1

8.3 Breakeven Analysis for the Recycle Provisions . . . . . . . . . . . . . . . . . . . . . . . . 8–2

8.4 Summary of Uncertainty/Sensitivity Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . 8–4

8.5 Cost Effectiveness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8–4

8.6 Combined Regulatory Effects with Other Rules . . . . . . . . . . . . . . . . . . . . . . . . 8–5

9. References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9–1
FBRR Final RIA -iv- April, 2001

LIST OF APPENDICES

Appendix A . . . . . . . . . . . . . . . . . . . Compliance Forecasts and Total Capital Costs of Treatment

Appendix B . . . . . . . . . . . . . . . Annualized Capital and O&M Costs at 3 Percent Cost of Capital

Appendix C . . . . . . . . . . . . . . . Annualized Capital and O&M Costs at 7 Percent Cost of Capital

Appendix D . . . . . . . . . . . . Annualized Capital and O&M Costs in Cents per Thousand Gallons

Appendix E . . . . . . . . . . . . . . . . . . . . . . . System and State Reporting and Recordkeeping Costs

Appendix F . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Calculation of Average Household Costs

Appendix G . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Baseline Data

Appendix H . . . . . . . . . . . . . . . Costs and Technologies for the Filter Backwash Recycling Rule
1 The FBRR and Long Term 1 Enhanced Surface Water Treatment Rule (LT1ESWTR) were proposed

together as one rule in the Federal Register (65 FR 19046; April 10, 2000). As a result, all documents supporting the

proposal address both rules. These rules have since been split and developed as separate rules for final publication. 

This RIA addresses only those costs and benefits that apply to the FBRR.

FBRR Final RIA 1-1 April 2001

1. Executive Summary

1.1 Need for the Proposal

The practice of recycling filter backwash water reintroduces contaminants into the treatment

processes. This practice can impair treatment process performance if not performed properly. 

Filter backwash is the water that results from the backwash of filters, which is an important step

in the proper operation of conventional and direct filtration plants. Filter backwash contains all

of the particles trapped in the filter during operation, including coagulants, metals, and pathogens

such as Cryptosporidium. This rule would ensure that these recycle waters are handled with at

least the same level of multi-barrier treatment as raw source water. 

The Filter Backwash Recycling Rule (FBRR) addresses filter backwash water and two additional

recycle streams—sludge thickener supernatant and liquids from dewatering processes. Sludge

thickener supernatant is the “clear water” that exists in sedimentation basins or clarifies after

particles have been allowed to settle out. Recent research has documented concentrations of

Cryptosporidium oocysts in thickener supernatant from 82 to 420 oocysts per hundred liters

(EE&T, 1999). Dewatering processes remove water from waste solids in order to reduce the

solids volume that must disposed. The waters that are removed during these processes can also

contain significant levels of Cryptosporidium since the waste solids that enter the processes

contain Cryptosporidium oocysts that have been removed from the treatment train (EE&T,

1999).

According to EPA’s Science Advisory Board (SAB), an independent panel of experts established

by Congress, disease-causing microbial contaminants (i.e., bacteria, protozoa, and viruses) are

probably the greatest remaining health risk management challenge for drinking water suppliers 

(U.S. EPA/SAB, 1990). The FBRR undertakes the challenge to improve the control of

microbial contaminants such as Cryptosporidium in public drinking water systems by helping to

ensure that recycle practices do not compromise treatment effectiveness.1

Cryptosporidium, which is a common protozoan in the environment, is transported in watersheds

from sources of oocysts (e.g., agricultural runoff and untreated wastewater) to water bodies that

serve as drinking water sources. If a system’s treatment operates inefficiently, oocysts may enter

finished water at levels that pose health risks. Cryptosporidium is of particular concern to EPA as

it develops the LT1ESWTR because—unlike pathogens such as viruses and

bacteria—Cryptosporidium oocysts are resistant to inactivation using standard disinfection

practices. Although recent research indicates some methods of disinfection may hold promise,

such as medium-pressure ultraviolet light disinfection, the results are still preliminary. Until

effective and practical disinfection methods are available, the control of Cryptosporidium is
2

 For instance, a follow-up study of the 1993 Milwaukee waterborne disease outbreak reported that at least

50 Cryptosporidium-associated deaths occurred among the severely immunocompromised (Hoxie et al., 1997).

FBRR Final RIA 1-2 April 2001

dependent on physical removal processes. Other emerging disinfection-resistant pathogens such

as microsporidia, Cyclospora, and Toxoplasma are also a concern for similar reasons.

Cryptosporidiosis is the disease caused by ingesting Cryptosporidium oocysts. Dupont, et al.

(1995) found that a dose of even a few Cryptosporidium parvum (or C. parvum) oocysts is

sufficient to cause infection in healthy adults. Cryptosporidiosis is a common protozoal infection

that usually causes 7 to 14 days of diarrhea with possibly a low-grade fever, nausea, and

abdominal cramps in individuals with healthy immune systems (Juranek, 1998). There is

currently no therapeutic cure for cryptosporidiosis, but the disease is self-limiting in healthy

individuals. It does, however, pose serious health and mortality risks for sensitive

subpopulations including children, the elderly, pregnant women, and the immunocompromised2

(Gerba et al., 1996; Fayer and Ungar, 1986; U.S. EPA 1998a), which represent almost 20 percent

of the population in the United States (Gerba et al., 1996).

Cryptosporidium oocysts in drinking water pose both an epidemic health risk and a health risk

associated with isolated cases (an endemic health risk). Evidence on epidemic risk suggests that

improving the performance of water systems will generate health benefits. Of the 20 waterborne

cryptosporidiosis outbreaks that occurred over the past 25 years, 3 took place because of

contaminated drinking water from water utilities where waste stream recycle was identified as a

possible cause (Craun, 1998). Because statistics on isolated cases of waterborne illnesses are not

tracked, there are no systematic data to determine the extent of the endemic health impact in the

United States.

The two primary methods for treating drinking water for microbial contaminants are chemical

disinfection (inactivation) and physical removal. The main goal of the FBRR, which is discussed

in greater detail in Chapter 2, is to improve the physical removal of microbial contaminants

through the management of recycle practices. Recycle practices are of concern because recycle

of flows such as filter backwash and thickener supernatant within the treatment process can

potentially return a significant number of oocysts to the treatment plant in a short amount of time,

particularly if the recycle is returned to the treatment process without prior treatment,

equalization, or some other type of hydraulic detention. Improper recycle practices can disrupt

normal treatment operations and reduce treatment efficiency, thereby increasing the risk that 

high concentrations of oocysts may pass through the plant into finished drinking water. These

improper practices are at the center of the FBRR. In fact, limited studies show that when recycle

is performed properly, namely when recycle is returned through all processes of the plant’s

existing treatment system and normal plant operations are not disrupted with hydraulic surges or

increased overall plant flow, the return of recycle does not perceptively impair plant treatment

with respect to Cryptosporidium or turbidity removal (Cornwell and MacPhee, 2001).

The FBRR addresses one of the requirements of the Safe Drinking Water Act as amended in

1996. Those amendments established a number of regulatory deadlines, including schedules for

a Stage 1 and a Stage 2 Disinfectants and Disinfection Byproducts Rule (DBPR), two stages of

the Enhanced Surface Water Treatment Rule (ESWTR) 1412(b)(2)(C), and a requirement that
3

Systems may apply to the State to recycle at an alternative location.

FBRR Final RIA 1-3 April 2001

EPA promulgate regulations to “govern” filter backwash recycling within the treatment process

of public utilities (Section 1412(b)(14)). The FBRR applies to all public drinking water systems

using surface water or ground water under the direct influence of surface water (GWUDI) as a

source. Chapters 2 and 3 describe the provisions of the rule in detail.

1.2 Consideration of Regulatory Alternatives

To reduce the potential burden of the FBRR on systems, EPA developed and evaluated the cost

implications and effectiveness of several regulatory alternatives for recycle provisions. Chapter 3

discusses the alternatives in detail and describes why EPA selected the alternative included in the

rule. The rule requires (with some exceptions) that recycle be returned through the processes of a

system’s existing conventional or direct filtration (as defined in §141.2 of 40 CFR) that the

Agency has recognized capable of achieving 2-log (or 99%) Cryptosporidium removal.3

 The rule

also contains provisions that require conventional and direct filtration systems that recycle to

collect, report, and maintain data that help the system and State understand the extent to which

the treatment process may be susceptible to hydraulic disruptions as a result of improper

recycling practices, and whether the existing recycle practices sufficiently address potential

health risks. 

1.3 Baseline Analysis

The FBRR affects water systems that use surface water or GWUDI, that practice conventional or

direct filtration, and that recycle spent filter backwash water, sludge thickener supernatant, or

liquids from dewatering processes. Estimates of systems that are affected by each rule provision

were developed from an analysis of primary water treatment and recycling practices. Chapter 4

discusses the methods and sources used to arrive at these estimates. Exhibit 1–1 provides the

system size categories and the number of systems that may be affected by the provisions of the

FBRR. 
FBRR Final RIA 1-4 April 2001

Exhibit 1–1. Number of Systems Subject to FBRR Provisions

System Population

Size Category Number of Systems

@100 488

101-500 660

 501-1,000 491

1,001-3,300 967

3,301-9,999 885

10,000-50,000 860

 50,001-100,000 157

 100,001-1,000,000 135

>1,000,000 71

Total 4,650

1

This estimates reflects 7 individual plants that belong to systems serving more than

1,000,000 people.

1.4 Benefits of the FBRR

Health Benefits

Chapter 5 provides EPA’s analysis of potential benefits of the rule. As discussed in that chapter, 

EPA expects that the benefits associated with the FBRR, although impossible to accurately

monetize at this time, justify the costs associated with the rule. The Agency expects that the

rule’s health benefits will accrue from a reduction in mortality and morbidity since improved

recycle practices as a result of the FBRR are expected to reduce the levels of Cryptosporidium

and Giardia lamblia in water supplies. 

Besides reducing the endemic risk of cryptosporidiosis, the FBRR will reduce the likelihood of

major outbreaks, such as the Milwaukee outbreak, from occurring. The economic value of

reducing the risk of outbreaks could be quite high when the magnitude of potential costs is

considered. For example, based on current-dollar estimates of the mean value of statistical life

(62 FR 59485; November 3, 1997), just one death could represent a cost of $6.3 million. Other

types of costs associated with outbreaks include spending by local, State, and national public

health agencies; emergency corrective actions by utilities; and possible legal costs, if liability is a

factor. Additional discussion regarding costs associated with outbreaks is found in Section

5.2.3.
FBRR Final RIA 1-5 April 2001

Non-health Benefits

The rule’s benefits are expected also to include non-health benefits. The non-health benefits

include avoided outbreak responses (e.g., provision of bottled water by water systems and local

governments, issuance of public notices) and avoided costs of averting behavior (e.g., out-ofpocket costs such as purchasing bottled water and opportunity costs such as not having to spend

time boiling water). 

Although the costs of the non-health benefits have not been monetized, these costs can be

significant. For example, the costs of averting behaviors, such as hauling in safe water, boiling

water, and purchasing bottled water, were estimated at between $1.74 to $5.53 per person per day

during one outbreak (Harrington et al., 1989). If these figures are applied to a small drinking

water system serving 10,000 customers, total expenditures on averting behavior during a

Cryptosporidium outbreak could range between $17,400 and $55,300 per day. Determining the

precise reduction in outbreak risk and resulting benefits due to reduced or avoided averting

behavior is not possible given current information, but potential benefits could be substantial.

1.5 Costs of the FBRR

Chapter 6 summarizes the methods EPA used to analyze costs for the FBRR. Total annual costs

for the rule are estimated at $5.84 million assuming a 3 percent discount rate and $7.19 million

assuming a 7 percent discount rate (both in 1999 dollars using a 20-year discount period). The

cost estimate includes capital and O&M costs for treatment changes and start-up and annual

labor costs for reporting activities for the rule’s recycle return location and conventional and

direct filtration reporting requirements. The labor costs incorporate both system and State

estimates.

To reduce the potential cost to systems, EPA developed and evaluated the cost implications of

several regulatory alternatives. In addition, EPA reviewed public comments received on the

proposed rule. See Chapter 3 for a detailed discussion of the alternatives considered and the

chosen rule option, which was further modified from its proposal to reduce the costs imposed on

systems and States. 

Water system cost increases are often passed on to customers in the form of higher monthly

water bills. EPA estimated the potential impact on households by developing a distribution of

costs across all affected systems and converting that distribution to a per-household basis. The

recycling provisions could affect approximately 31.4 million households based on EPA’s

assumptions. Annual incremental costs would be less than $1.70 for approximately 99 percent of

households and less than $10 for over 99.9 percent of households. The average cost per affected

household is estimated at only $0.19 per year.
4

The analyses supporting this certification are contained in the Regulatory Flexibility Screening Analysis prepared for

this final rule and can be found in the docket supporting the final rule (EPA, 2000g).

FBRR Final RIA 1-6 April 2001

1.6 Economic Impact Analysis

As part of the rule promulgation process, EPA is required to perform analyses that address the

potential regulatory burden placed on entities that are directly or indirectly affected by the rule. 

The impacts considered were the cost of compliance for State, local, and Tribal governments, and

small businesses; the effect of rule implementation on sensitive subpopulations; and the potential

for disproportionate impacts on low-income and minority populations. Chapter 7 discusses these

economic impact analyses and findings. In addition, EPA’s breakeven analysis indicates that the

monetized health benefits would exceed the cost of the rule if only one mortality per year were

avoided as a result of this rule. This analysis does not include any monetized costs associated

with illnesses. 

EPA has determined that FBRR does not contain a Federal mandate that may result in

expenditures of $100 million or more for the State, local and Tribal governments, in the

aggregate, or the private sector in any one year. The estimated annual cost of this rule is

approximately $5.84 million. Thus, the rule is not subject to the requirements of Sections 202

and 205 of the Unfunded Mandate Reform Act. In addition, EPA has concluded that this rule

will not have a disproportionate effect on systems operated by Indian Tribal governments. In

particular, this rule will affect fewer than 22 of the 987 total Tribal government drinking water

systems (approximately 2 percent). 

The Regulatory Flexibility Act, as amended by the Small Business Regulatory Enforcement

Fairness Act (SBREFA), requires EPA to consider the financial impact of FBRR on small

business entities. After considering the economic impact estimates for small entities, EPA

certifies that this regulation will not have a significant economic impact on a substantial number

of small entities.4

A primary purpose of the FBRR is to improve control of microbial pathogens, specifically the

protozoan Cryptosporidium. Under Executive Order 13045, the implementing agency must

evaluate the environmental health or safety effects of the planned rule on children, and explain

why the planned regulation is preferable to other potentially effective and reasonably feasible

alternatives considered. While FBRR is not subject to Executive Order 13045—because it is not

economically significant as defined by Executive Order 12866—the Agency believes that the

environmental health or safety risk addressed by this action may have a disproportionately

positive effect on children—a sensitive subpopulation.

As required under Executive Order 12898, EPA must identify and address disproportionately

high and adverse human health or environmental effects the adoption of the FBRR may have on

minority and low-income populations. The Agency has identified and addressed environmental

justice-related issues concerning the potential impacts of this action and has consulted with

minority and low-income stakeholders in the rule development process.
FBRR Final RIA 1-7 April 2001

1.7 Weighing of Benefits and Costs

Although data are unavailable to quantify benefits, EPA expects that the benefits of the FBRR

justify their cost on a qualitative basis (Chapter 8). For example, the changes to lower risk at

over 4,600 water systems nationwide is expected to cost approximately $5.84 million annually

assuming a 3 percent discount rate and $7.19 million annually assuming a 7 percent discount

rate. The mean estimate for the value of a statistical life is $6.3 million. If these changes prevent

even one outbreak and avoid one resulting death per year, the rule is quantitatively justified.

The recycle provisions will reduce the potential for certain recycle practices to lower or upset

treatment plant performance during recycle events; therefore, the provisions will help prevent

Cryptosporidium oocysts from entering finished drinking water supplies and will increase public

health protection.

The Agency strongly believes that returning Cryptosporidium to the treatment process in recycle

flows, if performed improperly, can create additional public health risk. EPA believes the public

health protection benefits provided by the FBRR justifies their cost because they are based upon

sound engineering principles and are designed to reduce public health risk by eliminating

improper recycle practices that increase the risk of high concentrations of oocysts passing

through the filtration plant into finished drinking water. 
1

 The Long Term 1 Enhanced Surface Water Treatment Rule (LT1ESWTR) and FBRR were proposed

together as one rule in the Federal Register (65 FR 19046; April 10, 2000). As a result, all documents supporting the

proposal address both rules. These rules have since been split and developed as separate rules for final publication. 

This RIA addresses only those costs and benefits that apply to the FBRR.

FBRR Final RIA 2-1 April 2001

2. Need for the Proposal

The Safe Drinking Water Act (SDWA) requires EPA to promulgate a regulation which

“governs” the recycle of filter backwash within the treatment process of public water systems. 

EPA is publishing a final Filter Backwash Recycling Rule (FBRR)1

 to address this statutory

requirement. Executive Order 12866, Regulatory Planning and Review, requires EPA to

estimate the costs and benefits of regulations in a regulatory impact analysis (RIA) and to submit

the analysis in conjunction with publishing the rule. RIAs provide background on the rule,

summarize key components, and discuss regulatory alternatives.

The FBRR applies to conventional and direct filtration public drinking water systems that use

surface water or ground water under the direct influence of surface water (GWUDI) as a source. 

It is designed to improve control of waterborne bacterial and viral pathogens, such as

Cryptosporidium and Giardia. 

This chapter of the RIA summarizes the technical and regulatory issues associated with the need

for the FBRR. It identifies the public health concerns addressed by the rule and summarizes the

key components of the rule. Specifically, it is organized into the following sections:

` Section 2.1 - characterizes the issues addressed by the rule. 

` Section 2.2 - identifies the public health concerns addressed by the rule.

` Section 2.3 - lists existing regulations and their impact on water quality. 

` Section 2.4 - reviews the economic rationale for promulgating the rule.

` Section 2.5 - summarizes key components of the rule.

Chapters 3 through 8 of this document are intended to meet the requirements of Executive Order

12866 by responding to specific analytical questions. Below is a description of each chapter. 

` Chapter 3 - reviews alternative approaches considered as the rule was being

developed.

` Chapter 4 - presents public water system (PWS) data to establish a baseline of

information for use in the following four chapters. 

` Chapter 5 - examines the rule’s potential benefits by reviewing occurrence data,

treatment efficiencies, and dose-response relationships. 

` Chapter 6 - presents an estimate of the costs to implement the rule. 

` Chapter 7 - reviews the distribution of the costs and benefits of the rule on various

entities and subpopulations. 

` Chapter 8 - weighs the overall benefits and costs of the various alternatives

considered for the rule.
FBRR Final RIA 2-2 April 2001

Raw Water Rapid Mix Flocculation Sedimentation Filtration

Coagulants

Exhibit 2–1. Flow Schematics for Conventional Water Treatment Systems

2.1 Issue Description 

Recycling reintroduces contaminants which were removed during treatment. This practice can

degrade influent water quality and impair treatment process performance if not properly

performed. The primary issue addressed by the FBRR is the minimization of public health risk

through improved physical removal of microbial contaminants. FBRR helps achieve such goals

by instituting changes to the return of recycle flows within the treatment process to reduce the

potential for improper recycling practices to compromise microbial control. 

2.1.1 Treatment Processes

Public water systems use a variety of processes to physically remove particles from the water

they treat. The FBRR applies only to plants that employ either conventional or direct filtration,

as defined in 40 CFR, Section 141.2. The configuration of unit processes within conventional

treatment or direct filtration facilities may include softening processes, contact clarification,

dissolved air flotation, and others. In all cases, direct filtration and conventional treatment rely

on final particle removal by rapid granular filtration. 

Conventional filtration, the most widely used type of filtration, consists of chemical coagulation,

rapid mix, flocculation, and sedimentation followed by filtration. A general flow schematic for a

conventional water treatment plant is presented in Exhibit 2-1. Source water is treated with

chemical coagulant(s), such as aluminum sulfate (alum), ferric or ferrous sulfate, ferric chloride,

and/or a coagulant aid to destabilize suspended particles and improve sedimentation as the water

enters the treatment system.

Coagulants promote the attachment of suspended particles to each other by destabilizing particle

inherent negative charges or by “sweeping’”particles into an aggregate, or “floc.” Coagulant aids

assist floc formation by attaching smaller floc particles to each other to form a stronger and more

settleable mass. Application of the appropriate coagulant and coagulant aid dose is critical to

optimized and reliable water treatment. As raw water quality changes, coagulant and coagulant

aid doses must be adjusted accordingly. 

After coagulants and coagulant aids are added in the rapid mix stage, the flocculation step gently

stirs the coagulated water to allow particle collision and adherence to form the settleable (or, for

direct filtration, a filterable) floc. The speed of stirring and the detention time of the water in the
FBRR Final RIA 2-3 April 2001

flocculation basin are critical for floc formation. In a conventional treatment process, the formed

floc is subsequently removed by sedimentation. As water flows through the sedimentation basin,

solids are settled by gravity as the clarified water passes slowly upward and out of the basin. The

rate of water flow out of the basin, termed surface overflow rate, is critical to enabling gravity

settling of the floc without carryover of particles to the filters. For direct filtration, sedimentation

is omitted and floc is removed solely by filtration. 

For both conventional and direct filtration, control of the flow of water is critical to effective

performance of each of the individual flocculation, sedimentation and filtration steps. Hydraulic

surges, which are significant, temporary increases in flow, can disrupt the treatment process. 

Disruption may result from short-circuiting of water within a flocculation or sedimentation basin

or significantly increasing flow through a filter. 

In the direct filtration process, suspended solids are removed solely by filters (AWWA/ASCE,

1998). As depicted in Exhibit 2-2, direct filtration consists of coagulation followed by rapid

mixing, flocculation, and filtration. Unlike conventional treatment, direct filtration does not

include a sedimentation step. Instead, it directly applies the chemically-conditioned and

flocculated water to the filters. A variation of direct filtration, in-line filtration, excludes the

flocculation process and instead relies on flocculation to occur in the pipes between the rapid mix

and the filters. In both direct and in-line filtration, the filters are the only means of suspended

solid, particle, and pathogen removal. Some small surface water treatment facilities are

configured as package plants. A package plant can be defined as a complete modular treatment

plant, designed as a factory-assembled, skid-mounted unit. A package plant may consist of either

direct filtration or conventional treatment processes, and therefore may include chemical

coagulation, flocculation, sedimentation, and filtration. 
FBRR Final RIA 2-4 April 2001

Raw Water Rapid Mix Flocculation Filtration

Coagulants

(a) Direct Filtration

Raw Water Rapid Mix Filtration

Coagulants

(b) In-Line Filtration

Exhibit 2–2. Flow Schematics for Direct Filtration Systems

Another type of treatment used by some systems is the lime softening process. Lime softening is

a type of conventional treatment that also removes hardness (calcium and magnesium ions)

through chemical precipitation. Most lime softening plants use a contact clarification process to

remove turbidity and hardness. In a contact clarification treatment process, the flocculation and

sedimentation (and often the rapid mix) processes are combined in one unit—an upflow solids

contactor or contact clarifier. 

2.1.2 Recycling Practices

The treatment processes discussed in Section 2.1.1 remove particles and pathogenic

microorganisms from the water during the sedimentation and filtration processes. Particles and

pathogens are then removed from the treatment facility by discharge of sedimentation basin

sludge or by backwashing filters. Water systems may discharge sludge accumulated during

sedimentation to a waste-handling facility on a continuous basis or periodically. 

Filter backwash is initiated when particle build-up within the filter bed results in increased

headloss or imminent turbidity breakthrough. Filter backwash may also be initiated if the filter

has been in service for a predetermined maximum period of time. During filter backwash, water

is forced through the filter, counter to the flow direction used during treatment operations, to

dislodge accumulated particles and pathogens retained in the filter media. This backwashing of
FBRR Final RIA 2-5 April 2001

Raw Water Rapid Mix Flocculation Sedimentation Filtration

Coagulants

Equalization

or

Sedimentation

Treated Recycle

Direct Recycle

Raw Water Rapid Mix Flocculation Sedimentation Filtration

Coagulants

Recycle Flows

Recycle Flows

Exhibit 2–3. Flow Schematics for Systems that Recycle

the filter reestablishes filter removal capability and is important for maintaining optimal filter

performance.

As Exhibit 2-3 shows, recycle flows generated during treatment, such as spent filter backwash

water, liquids from sludge dewatering, and sludge thickener supernatant, are often recovered and

returned to the treatment train.
FBRR Final RIA 2-6 April 2001

Some treatment plants may not perform optimally during filter backwash recycle events and may

experience greater risk because of certain recycle practices. Recycle flows may contain high

concentrations of pathogens, including disinfection-resistant Cryptosporidium oocysts, and

chemicals added during the treatment process (e.g., oxidants, coagulants, and polymers). If the

recycle flow is not adequately treated before being returned to the primary treatment train,

significant numbers of oocysts may be returned to the plant. This increases the overall number of

oocysts entering the plant and increases the risk that some disinfectant-resistant pathogens such as

Cryptosporidium can slip through filtration. Also, recycle flow returned to the clarification

process may not achieve sufficient residence time for oocysts in the recycle flow to be removed,

or it may create hydraulic currents that lower the unit’s overall oocyst removal efficiency. 

Improper recycle practices may cause plants to exceed State-approved operating capacity during

recycle events. This can cause clarification and filter loading rates to be exceeded, which may

lower overall oocyst removal provided by the plant and increase finished water oocyst

concentrations. The FBRR addresses these concerns. As indicated previously, limited work has

shown that when recycle is performed in accordance with the requirements of the FBRR,

Cryptosporidium removal is not impaired. 

2.1.3 Recycle Flows

The following five recycle flows are discussed in more detail because they are the most likely to

present a threat to treatment plant performance or finished water quality when recycled. These

recycle flows are also the most likely to contain Cryptosporidium.

` Untreated Spent Filter Backwash Water. Backwash water is generated when water is

forced through the filter, counter to the flow direction used during treatment operations to

dislodge accumulated particles and pathogens captured by the filter media. Untreated

spent filter backwash water refers to water used for filter backwash which has not

received treatment to remove oocysts from the waste stream. 

` Gravity Settled Spent Filter Backwash Water. Gravity settled spent filter backwash

water is generated by the same process described above, except that this wastestream is

treated by gravity settling to remove solids prior to its return to the primary treatment

process. 

` Combined Gravity Thickener Supernatant. A combination of the supernatant from spent

filter backwash water and a gravity thickener. A gravity thickener removes water from the

sedimentation and filtration backwash sludge mass to reduce the volume of sludge that

must be handled. Gravity thickeners settle solids to the bottom of a basin by gravity

sedimentation. The supernatant remaining on top of the settled sludge is decanted and

may be recycled.

` Gravity Thickener Supernatant from Sedimentation Solids. This potential recycle flow

is similar to that for the combined gravity thickener supernatant, but includes only the

supernatant from a gravity thickener.
FBRR Final RIA 2-7 April 2001

` Mechanical Dewatering Device Liquids. Liquids resulting from devices used to

mechanically separate water treatment plant residuals (usually thickened sludge) into

solids and water. Devices used to mechanically dewater thickened sludge include belt

filter presses, centrifuges, filter presses, and vacuum filters.

2.2 Public Health Concerns

In 1990, EPA’s Science Advisory Board (SAB), an independent panel of experts established by

Congress, cited drinking water contamination as one of the most important environmental risks

and indicated that disease-causing microbial contaminants (i.e., bacteria, protozoa, and viruses)

are probably the greatest remaining health risk management challenge for drinking water

suppliers (U.S. EPA/SAB, 1990). Information on the number of waterborne disease outbreaks

from the U.S. Centers for Disease Control and Prevention (CDC) underscores this concern. CDC

indicates that 401 waterborne disease outbreaks were reported between 1980 and 1996, with over

750,000 associated cases of disease (CDC, 1996). Of these outbreaks, at least nineteen were

associated with Cryptospordium, and three occured at water treatment plants where recycle was

implicated as a possible cause for the outbreak.

Additional information on waterborne disease outbreaks is provided in Section 2.2.4 of this

chapter. Because outbreak information is not required to be reported by State agencies and

endemic waterborne disease often goes undiagnosed and unreported, these data likely represent

an underestimate of diseases caused by Cryptosporidium.

2.2.1 Contaminants and Their Associated Health Effects

Cryptosporidium is of particular concern to EPA as it develops the FBRR because—unlike

pathogens such as viruses and bacteria—Cryptosporidium oocysts are resistant to inactivation

using standard disinfection practices. Although recent research indicates some methods of

disinfection may hold promise, such as medium-pressure ultraviolet light disinfection, the results

are still preliminary. Until effective and practical disinfection methods are available, the control

of Cryptosporidium is dependent on physical removal processes. In addition, currently there is no

therapeutic cure for cryptosporidiosis (unlike giardiasis). Other emerging disinfection-resistant

pathogens, such as microsporidia, Cyclospora, and Toxoplasma, are also a concern of FBRR for

similar reasons. 

The effects of waterborne disease is usually acute—its onset is sudden and its duration typically

short in healthy people. Some pathogens (e.g., Giardia and Cryptosporidium) may cause

extended illness that lasts for weeks or longer in otherwise healthy individuals, and the infection

can prove fatal to members of sensitive populations, such as the immunocompromised. Most

waterborne pathogens cause gastrointestinal illness, with diarrhea, abdominal discomfort, nausea,

vomiting, or other symptoms. Other waterborne pathogens cause, or at least are associated with,

more serious disorders such as hepatitis, gastric cancer, peptic ulcers, myocarditis, swollen lymph

glands, meningitis, and encephalitis, among other diseases. 
FBRR Final RIA 2-8 April 2001

Cryptosporidiosis is caused by ingestion of Cryptosporidium oocysts, which are readily carried by

the waterborne route. The most common source of oocysts in water is the feces of infected hosts

(Walker et al., 1998). Dupont, et al. (1995) found through a human feeding study that a low dose

of Cryptosporidium parvum (or C. parvum) is sufficient to cause infection in healthy adults. 

Infected humans and other animals may excrete Cryptosporidium oocysts, which can then be

transmitted to others. Cryptosporidiosis is often spread by ingesting infective oocysts in

contaminated food or water, and by direct or indirect contact with infected persons or animals

(Casemore, 1990; Cordell and Addiss, 1994).

Cryptosporidiosis is a common protozoal infection that usually causes 7–14 days of diarrhea and 

possibly a low-grade fever, nausea, and abdominal cramps in individuals with healthy immune

systems (Juranek, 1998). There appears to be an immune response to Cryptosporidium, but it is

not known if this results in complete protection (Fayer and Ungar, 1986). When prior exposure

or chronic contamination of the water by low levels of oocysts confers short-term immunity to

immunocompetent residents in a community (Okhuysen et al., 1998), most cases of symptomatic

illness in that community occur in newly exposed individuals, such as young children, visitors,

and new residents (Frost et al., 1997).

2.2.2 Sensitive Subpopulations

A number of sensitive populations are at greater risk of serious illness (morbidity) or mortality

than is the general population (Frost et al., 1997) from either epidemic or endemic infection by

Cryptosporidium. These sensitive populations include children, especially the very young; the

elderly; pregnant women; and the immunocompromised. They represent almost 20 percent of the

population of the United States (Gerba et al., 1996; Fayer and Ungar, 1986; U.S. EPA, 1998a).

Gastrointestinal illness caused by cryptosporidiosis may be chronic in these sensitive populations.

EPA has a particular concern regarding drinking water exposure to Cryptosporidium, especially

in severely immunocompromised persons, because there is no effective therapeutic drug to cure

the disease (Framm and Soave, 1997). Therefore, prevention of infection is critical (Petersen,

1992). The severity and duration of illness is often greater in immunocompromised persons than

in healthy individuals and may be fatal among this population. For instance, a follow-up study of

the 1993 Milwaukee waterborne disease outbreak reported that at least 50 Cryptosporidiumassociated deaths occurred among the severely immunocompromised (Hoxie et al., 1997).

2.2.3 Sources of Contaminants 

Cryptosporidium is common in the environment (Rose, 1997, Soave, 1995, LeChevallier et al.,

1991a). Runoff from unprotected watersheds allows these microorganisms to be transported from

sources of oocysts (e.g., feces of wildlife, untreated wastewater, livestock operations, and

agricultural runoff) to water bodies used as drinking water sources. If a treatment plant operates

inefficiently, oocysts may enter the finished water at levels sufficient to cause public health

concerns. Increasing disinfectant dosages (i.e., chlorine or chloramines) is not an effective

strategy for controlling Cryptosporidium, because the Cryptosporidium oocyst is especially

resistant to disinfection practices. 
FBRR Final RIA 2-9 April 2001

Cryptosporidium oocysts have been detected in wastewater, pristine surface water, surface water

receiving agricultural runoff or contaminated by sewage, ground water under the direct influence

of surface water (GWUDI), water for recreational use, and drinking water (Rose, 1997; Soave,

1995). Over 30 environmental surveys have reported Cryptosporidium source water occurrence

data from surface water and GWUDI. Many of these studies are summarized in the Occurrence

Assessment for the Long Term 1 Enhanced Surface Water Treatment and Filter Backwash

Recycling Rules (U.S. EPA, 2001a).

2.2.4 Waterborne Disease Outbreaks

CDC, EPA, and the Council of State and Territorial Epidemiologists have maintained a

collaborative surveillance program for collection and periodic reporting of data on waterborne

disease outbreaks since 1971. The CDC database and biennial CDC–EPA surveillance

summaries include data reported voluntarily by the States on the incidence and prevalence of

waterborne illnesses. According to the CDC–EPA database, between 1971 and 1996 a total of

672 outbreaks and 567,321 cases of illnesses were reported (see Exhibit 2–4). The reported

outbreaks were due to contamination by protozoa, viruses, bacteria, chemicals, and unknown

factors.

Exhibit 2–4. Comparison of Outbreaks and Outbreak-related Illnesses from

Ground Water and Surface Water for the Period 1971–1996

Water 

Source

Total 

Outbreaks

Cases of

Illnesses

Outbreaks 

in Community

Water Systems

(CWSs)

Outbreaks in

Noncommunity

Water Systems

(NCWSs)1

 

Ground 389 (58%) 85,214 (15%) 71 269

Surface 225 (33%) 471,468 (83%) 104 60

Other 58 (9%) 10,639 (2%) 107 61

All Systems 672 (100%) 567,321 (100%) 282 390

1

Includes outbreaks in NCWSs and private wells.

Source: Craun and Calderon (1996), Levy et. al. (1998). 

From 1984 to 1994, there were 19 reported outbreaks of cryptosporidiosis in the United States

(Craun, 1998). As mentioned previously, C. parvum was not identified as a human pathogen

until 1976. Furthermore, data on cryptosporidiosis outbreaks were not collected in the United

States before 1984. Ten of the reported cryptosporidiosis outbreaks were associated with

drinking water sources (CWSs, NCWSs, and a private water system) (Moore et al., 1993; Kramer

et al., 1996; Levy et al., 1998; Craun, 1996; Craun et al., 1998). They are summarized in Exhibit

2–5. The remaining nine outbreaks were associated with water-based recreational activities

(Craun et al., 1998). 
FBRR Final RIA 2-10 April 2001

Exhibit 2–5. Cryptosporidiosis Outbreaks in U.S. Drinking Water Systems1

Year

Location and

System Type

Cases of Illness

(Estimated)

Source 

Water Treatment

Suspected 

Cause

1984 Braun Station, TX

CWS 117 (2,000) Well Chlorination Sewagecontaminated well

1987 Carrollton, GA,

CWS (13,000) River

Conventional filtration/

chlorination; inadequate

backwashing of some

filters

Treatment 

deficiencies

1991 Berks County,

PA, NCWS (551) Well Chlorination

Ground water

under the influence of

surface water 

1992

Medford (Jackson

County), OR,

CWS

(3,000; combined

total 

for Jackson County

and Talent, below)

Spring/River Chlorination/package

filtration plant Source not identified

1992 Talent, OR,

CWS see Medford, OR Spring/River Chlorination/package

filtration plant

Treatment

deficiencies

1993 Milwaukee, WI,

CWS (403,000) Lake Conventional filtration 

High source water

contamination and

treatment deficiencies

1993 Yakima, WA,

private 7 Well

Ground water under

the influence of

surface water

1993 Cook County, MN,

NCWS 27 Lake Filtered, chlorinated

Possible sewage

backflow from

toilet/septic tank

1994 Clark County, NV,

CWS

103; many

confirmed for

cryptosporidiosis

were HIV positve

River/Lake

Prechlorination,

filtration and postfiltration chlorinationSource not identified

1994 Walla Walla, WA,

CWS 134 Well None reported Sewagecontamination

1

Adapted from Craun, et al. (1998).

Three of the 10 outbreaks cited in Exhibit 2–5 (Carollton, GA [1987]; Talent, OR [1992]; and

Milwaukee, WI [1993]) were caused by water supplied by treatment plants whose process stream

recycle was implicated as a possible cause. In total, the nine outbreaks occurring in PWSs caused

approximately 419,939 cases of illness with the largest outbreak (Milwaukee, WI [1993]) having

recycle flows implicated as a possible cause. They show that, when treatment is not operating

optimally or when source water is highly contaminated, Cryptosporidium may enter the finished

drinking water and cause waterborne disease outbreaks.

The occurrence of waterborne gastrointestinal infections including Cryptosporidiosis may be

much greater than suggested by reported surveillance data (Craun and Calderon, 1996). The

CDC database is based on responses to a voluntary and confidential survey that is completed by

State and local public health officials. The U.S. National Research Council strongly suggests that

the number of identified and reported outbreaks in the CDC database (for surface and ground

waters) represents a small percentage of actual waterborne disease outbreaks (National Research

Council, 1997; Bennett et al., 1987). In practice, most of these outbreaks in CWSs are not
FBRR Final RIA 2-11 April 2001

recognized until a sizable proportion of the population is ill (Perz et al., 1998; Craun, 1996),

perhaps 1 to 2 percent of the population (Craun, 1996).

In addition, healthy adults with cryptosporidiosis may not suffer severe symptoms from the

disease; therefore, infected individuals may not seek medical assistance, and their cases may go

unreported. Even if infected individuals consult a physician, Cryptosporidium is not analyzed by

routine diagnostic tests for gastroenteritis and, therefore, tends to be under-reported in the general

population (Juranek, 1995; Craun, 1996). Such obstacles to outbreak reporting indicate that the

incidence of disease and outbreaks of cryptosporidiosis may be much higher than officially

reported by the CDC.

Endemic waterborne disease is a factor that should also be considered and is defined as any

waterborne disease not associated with an outbreak. EPA, however, is not aware of any data

documenting the incidence of waterborne endemic cryptosporidiosis in the United States. But 14

to 40 percent of the normal gastrointestinal illness in a community in Quebec was associated with

treated drinking water from a surface water source (Payment et al., 1997). Given the lack of

endemic waterborne disease occurrence data, combined with the strong possibility that outbreaks

are under-reported, it is likely that there are more instances of cryptosporidiosis and other

waterborne diseases than are currently recorded.

2.2.5 Filter Backwash and Other Process Flows: Occurrence and Impact Studies

In addition to evaluating waterborne disease outbreak data, EPA also evaluated data regarding the

occurrence of Cryptosporidium in recycle flows. In particular, EPA, in conjunction with the

American Water Works Association (AWWA), the American Water Works Service Company

(AWWSCo), and Cincinnati Water Works, compiled issue papers on each of these recycle flows: 

spent filter backwash water, sedimentation basin solids, combined thickener supernatant, ionexchange regenerate, membrane concentrate, lagoon decant, mechanical dewatering device

concentrate, monofill leachate, sludge drying bed leachate, and small-volume flows (e.g., floor,

roof, lab drains) (EE&T, 1999). In addition, EPA compiled the existing Cryptosporidium

occurrence data and occurrence data on other constituents of the recycle flows with the data

presented in AWWA’s white papers. 

These efforts resulted in Cryptosporidium occurrence data for five types of recycle flows: 

untreated spent filter backwash water, gravity settled spent filter backwash water, combined

gravity thickener supernatant (a combination of spent filter backwash and clarification process

solids), gravity thickener supernatant from clarification process solids, and mechanical

dewatering device liquids. Nine studies have reported the occurrence of Cryptosporidium in

these process flows. Each study’s scope and results are presented in Exhibit 2–6, and brief

narratives on each major study follow the table. Note that the results of the studies, if not

presented in the published report as oocysts per 100L, have been converted into oocysts per 100L.
FBRR Final RIA 2-12 April 2001

Exhibit 2–6. Cryptosporidium Occurrence in Filter Backwash 

and Other Recycle Flows

Name/

Location 

of Study

Number

of 

Samples

Type 

of Sample

Cyst/Oocyst 

Concentration

Number of

Treatment

Plants

Sampled Reference

Drinking water

treatment

facilities

2 backwash

waters from

rapid sand

filters

sample 1: 26,000 oocysts/gal

(calc. as 686,900 oocysts/100L);

sample 2: 92,000 oocysts/gal

(calc. as 2,430,600

oocysts/100L)

2 Rose et al. 1986

Farmoor water

treatment plant,

England

not reported backwash

water from

rapid sand filter

Over 1,000,000 oocysts/100L in

backwash water on 2/19/89

100,000 oocysts/100L in 

supernatant from settlement

tanks during the next few days

1 Colbourne 1989

Potable water

supplies in 

17 States

not reported filter backwash

from rapid sand

filters (10 to 40-

L sample vol.)

217 oocysts/100L

 (geometric mean)

not 

reported

Rose et al. 1991

Name/Location

not reported

not reported raw water

initial

backwash

water

7 to 108 oocysts/100L

detected at levels 57 to 61 times

higher than in the raw water

not reported LeChevallier 

et al. 1991a

Bangor Water

Treatment Plant

(PA)

Round 1:

1 (8-hour

composite)

raw water

filter backwash

supernatant

recycle

6 oocysts/100L

902 oocysts/100L

141 oocysts/100L

1 Cornwell and Lee

1993a,b

Round 2:

1 (8-hour

composite)

raw water

filter backwash

supernatant

recycle

140 oocysts/100L

850 oocysts/100L

750 oocysts/100L

Moshannon

Valley Water

Treatment Plant 

Round 1:

1 (8-hour

composite)

spent 

backwash

supernatant

recycle raw

water sludge

16,613 oocysts/100L

82 oocysts/100L

13 oocysts/100L

2,642 oocysts/100L

1 Cornwell and Lee

1993a,b

Round 2:

1 (8-hour

composite)

raw water

supernatant

recycle

20 oocysts/100L

420 oocysts/100L

Plant “C” 11 samples

using

continuous

flow

centrifugation; 

39 samples

using

cartridge

filters 

backwash

water from

rapid sand

filters; samples

collected from

sedimentation

basins during

sedimentation

phase of

backwash

water at depths

of 1, 2, 3, and

3.3 m. 

continuous flow: range 1 to 69

oocysts/100L; 8 of 11 samples

positive

cartridge filters: ranges 0.8 to

252/100L; 33 of 39 samples

positive

1 Karanis et al.

1996
Exhibit 2–6. Cryptosporidium Occurrence in Filter Backwash 

and Other Recycle Flows

Name/

Location 

of Study

Number

of 

Samples

Type 

of Sample

Cyst/Oocyst 

Concentration

Number of

Treatment

Plants

Sampled Reference

FBRR Final RIA 2-13 April 2001

Pittsburgh

Drinking Water

Treatment Plant

24 (two

years of

monthly

samples)

filter backwash 328 oocysts/100L (mean);

(38 percent occurrence rate)

non-detect-13,158 oocysts/100L

1 States et al. 1997

“Plant 

Number 3"

not reported raw water

spent

backwash

140 oocysts/100L

850 oocysts/100L

not reported Cornwell 1997

“Plant C”

(see Karanis, et

al., 1996)

“Plant A”

12

50

1

raw water

backwash

water from

rapid sand

filters

rapid sand filter

(sample taken

10 min. after

start of

backwashing)

avg. 23.2 oocysts/100L (max.

109 oocysts/100L) in 8 of 12

samples

avg. 22.1 oocysts/100L (max.

257 oocysts/100L) in 41 of 50

samples

150 oocysts/100L

1 Karanis et al.

1998 (Table 8, 

p.14)

As shown in Exhibit 2–6, oocysts generally are found in greater concentrations in backwash water

and other recycle flows than in raw water. For example, four studies (Cornwell and Lee, 1993b;

States et al., 1997; Rose et al., 1986; and Colbourne, 1989) have reported Cryptosporidium

oocysts over a wide range of concentrations in filter backwash water (from zero oocysts/100L to

over 1 million oocysts/100L). However, each of these studies reported some samples of oocyst

concentration in excess of 10,000 oocysts/100 L. Such concentrations indicate that the treatment

plant has been performing properly and is removing oocysts from the influent water during the

sedimentation and/or filtration processes. As expected, the oocysts have concentrated on the

filters or in the sedimentation basin sludge. Therefore, the recycling of such process flows (e.g.,

filter backwash, thickener supernatant, sedimentation basin sludge) re-introduces high

concentrations of oocysts to the drinking water treatment train since these flow contain the

majority of oocysts that were removed by the filters and sedimentation units. Recycle may return

a significant number of oocysts to the treatment plant in a short period of time, particularly if the

recycle is returned to the treatment process without prior treatment, equalization, or some other

type of hydraulic detention. If the recycle disrupts normal treatment operations or if treatment

does not function efficiently due to other deficiencies, high concentrations of oocysts may pass

through the plant into finished drinking water. The major recycle flow studies presented in

Exhibit 2–6 are described in further detail below.
FBRR Final RIA 2-14 April 2001

Rose, et al.

Rose, et al. (1991) reported the geometric mean of the backwash samples at 217 Cryptosporidium

oocysts/100L. This was the highest reported average Cryptosporidium concentration of any of the

water types tested.

LeChevallier, et al.

In the analysis of pathogen concentrations in raw water and in the filter backwash water of water

treatment process, LeChevallier et al. (1991b) found very high oocyst levels in backwash water of

systems that had low raw water parasite concentrations. Cryptosporidium levels in the initial

backwash water were 57 to 61 times higher than in the raw water supplies. Raw water samples

were found to contain from 7 to 108 oocysts/100L. LeChevallier et al. (1991b) also noted that for

12 of 13 times when Cryptosporidium were detected in plant effluent samples, the organisms were

also observed in the backwash samples. They concluded that the consistency of these results

shows that the accumulation of parasites in treatment filters (and their subsequent release in the

backwash water) could be related to subsequent penetration of the treatment barriers.

Cornwell and Lee

Cornwell and Lee (1993b) detected Cryptosporidium concentrations of over 15,000

Cryptosporidium oocysts/100L in the spent filter backwash at an adsorption clarifier plant

(Moshannon Valley) and over 800 Cryptosporidium oocysts/100L in backwash water from a

direct filtration plant (Bangor). The parasite levels in the backwash samples were significantly

higher than in raw source water, which contained Cryptosporidium oocyst concentrations of

6–140 oocysts/100L at the Bangor plant and 13–20 oocysts/100L at Moshannon Valley.

In addition, Cornwell and Lee determined oocyst concentrations for two other recycle flows,

combined thickener supernatant and sedimentation basin solids. The supernatant pathogen

concentrations was reported at 141 Cryptosporidium oocysts/100L at the Bangor plant, and at 82

and 420 cysts/100L for the Moshannon plant in Rounds 1 and 2 of sampling, respectively. The

sedimentation basin sludge was reported at 2,642 Cryptosporidium oocysts/100L in the clarifier

sludge from the Moshannon Valley plant.
FBRR Final RIA 2-15 April 2001

States, et al.

Cryptosporidium occurred in raw Allegheny river water supplying a plant at a geometric mean of

31 oocysts/100L in 63 percent of samples collected, and ranged from non-detect to 2,333

oocysts/100L (States et al., 1997). Of the filter backwash samples, a geometric mean of 328

oocysts/100L was found at an occurrence rate of 38 percent of samples, with a range from nondetect to 13,158 oocysts/100L. The fact that the mean concentration of Cryptosporidium oocysts

can be substantially higher in backwash water than in untreated river water suggests that recycling

untreated filter backwash water can be a significant source of this parasite in the treatment

process. 

2.2.6 Current Control and Potential for Improvement

One of EPA’s key regulations to counter pathogens in drinking water is the Surface Water

Treatment Rule (SWTR) (54 FR 27486, June 29, 1989). Among its provisions is the requirement

that surface water systems have sufficient treatment to reduce the source water concentration of

Giardia and viruses by at least 99.9 percent (3 logs) and 99.99 percent (4 logs), respectively. A

shortcoming of the SWTR, however, is that the rule does not specifically control for the protozoan

Cryptosporidium. The first report of a recognized outbreak caused by Cryptosporidium was

published during the development of the SWTR (D’Antonio et al., 1985). 

In 1998, the Agency finalized the IESWTR, designed to enhance the SWTR protections from

microbial pathogens, specifically Cryptosporidium, for systems serving 10,000 or more persons. 

The IESWTR provisions included a Maximum Contaminant Level Goal (MCLG) of zero for

Cryptosporidium. In addition, the IESWTR requires a minimum 2-log (99 percent) removal of

Cryptosporidium, linked to enhanced combined filter effluent and individual filter turbidity

monitoring provisions, although this requirement currently applies only to surface and GWUDI

systems serving at least 10,000 persons and that must filter under the SWTR. The LT1ESWTR is

expected to be finalized in early 2001, and will address these issues for systems serving less than

10,000 people.

Degradation in treatment performance caused by improper plant process flow recycle or other

treatment deficiencies may hinder efforts to control Cryptosporidium, Giardia lamblia, and other

emerging pathogens, particularly during periods of heavy precipitation or high runoff. 

Cryptosporidium oocysts have been found in filtered drinking water from facilities meeting the

treatment technique requirements of the SWTR (LeChevallier, et al., 1991a; U.S. EPA, 1993), and

many individuals affected by waterborne disease outbreaks caused by Cryptosporidium were

served by filtered surface water supplies (Solo-Gabriele and Neumeister, 1996). These instances

indicate surface water supplies that filter and disinfect may still be vulnerable to Cryptosporidium,

depending on the quality of their source water and the effectiveness of their treatment. The FBRR

will help ensure recycle practices are not contributing excessive concentrations of

Cryptosporidium to the source water and are not disrupting the multiple barriers of water

treatment processes through chemical imbalance or hydraulic surges. As an added benefit, these

practices that control Cryptosporidium will control other microbiological contaminants of

concern, such as Giardia.
FBRR Final RIA 2-16 April 2001

The FBRR addresses the concern that for all PWSs which recycle their process flow,

Cryptosporidium (and other emerging pathogens resistant to standard disinfection) are

reintroduced to the treatment process by the recycling of spent filter backwash water, solids

treatment residuals, and other process flows. Insufficient treatment practices have been cited as

the cause of several reported waterborne disease outbreaks (Rose, 1997). Therefore, the recycle

flow provisions of the rule would help ensure that the treatment process is not disrupted or

operating inefficiently. The regulatory history that led to development of the FBRR is

summarized in the next section.

2.3 Regulatory History and Current Controls

2.3.1 1979 Total Trihalomethane Rule

In November 1979 (44 FR 68624), EPA set an interim MCL for total trihalomethanes (TTHM -

the sum of chloroform, bromoform, bromodichloromethane, chlorodibromomethane) of 0.10 mg/l

as an annual average.

The interim TTHM standard applies to community water systems (CWSs) that use surface water

and/or ground water, that serve at least 10,000 persons, and that add a disinfectant to the drinking

water during any part of the treatment process. At their discretion, States may extend coverage to

smaller water systems; however, most States have not exercised this option. 

2.3.2 Surface Water Treatment Rule

Under the Surface Water Treatment Rule (SWTR) (54 FR 27486; June 29, 1989), EPA set

maximum contaminant level goals of zero for Giardia lamblia, viruses, and Legionella; and

promulgated regulatory requirements for all PWSs using surface water or GWUDI sources. The

SWTR includes treatment technique requirements for filtered and unfiltered systems that are

intended to protect against the adverse health effects of exposure to Giardia lamblia, viruses, and

Legionella, as well as many other pathogenic organisms. Briefly, those requirements include 1)

requirements for maintenance of a disinfectant residual in the distribution system; 2) removal

and/or inactivation of 3 log (99.9 percent) for Giardia and 4 log (99.99 percent) for viruses; 3)

combined filter effluent turbidity performance standard of 5 nephelometric turbidity units (NTUs)

as a maximum and 0.5 NTU at the 95th percentile monthly, based on four-hour monitoring for

treatment plants using conventional treatment or direct filtration (with separate standards for other

filtration technologies); and 4) watershed protection and other requirements for unfiltered

systems.

2.3.3 Information Collection Rule

The Information Collection Rule (ICR), which was promulgated on May 14,1996 (61 FR 24354),

applied to large public water systems serving populations of more than 100,000 persons; a more

limited set of ICR requirements pertain to ground water systems serving between 50,000 and

100,000 persons.
2

The chloroform MCLG of 0 is withdrawn per a D.C. Court of Appeals May 2000 decision.

FBRR Final RIA 2-17 April 2001

The purpose of the ICR was to collect occurrence and treatment information to help evaluate the

need for possible changes to the current microbial requirements and existing microbial treatment

practices, and to help evaluate the need for future regulation for disinfectants and disinfection

byproducts (DBPs). The ICR provided EPA with additional information on the national

occurrence in drinking water of 1) chemical byproducts that form when disinfectants used for

microbial control react with naturally occurring compounds present in source water; and 2)

disease-causing microorganisms, including Cryptosporidium, Giardia, and viruses. The ICR also

collected engineering data on how PWSs currently control for such contaminants. The ICR

monthly sampling data provided 18 months worth of information on the quality of the recycle

waters via monthly monitoring of pH, alkalinity, turbidity, temperature, calcium and total

hardness, TOC, UV254, bromide, ammonia, and disinfectant residual (if disinfection is used). 

These data will provide some indication of the “treatability” of the water, the extent to which

contaminant concentration effects may occur, and the potential for contribution to DBP formation.

2.3.4 Interim Enhanced Surface Water Treatment Rule

Public water systems that serve 10,000 or more persons and use surface water or GWUDI are

required to comply with the IESWTR (63 FR 69477; December 16, 1998) by December 2001. 

The purposes of the IESWTR are to improve control of the protozoan Cryptosporidium and to

address risk trade-offs between pathogens and disinfection byproducts. Key provisions

established by the rule include an MCLG of zero for Cryptosporidium; 2-log Cryptosporidium

removal requirements for systems that filter; strengthened combined filter effluent turbidity

performance standards of 1.0 NTU as a maximum and 0.3 NTU at the 95th percentile monthly,

based on 4-hour monitoring for treatment plants using conventional treatment or direct filtration;

requirements for individual filter turbidity monitoring; disinfection benchmark provisions to

assess the level of microbial protection provided as facilities take the necessary steps to comply

with new disinfection byproduct standards; inclusion of Cryptosporidium in the definition of

GWUDI and in the watershed control requirements for unfiltered public water systems;

requirements for covers on new finished water reservoirs; and sanitary surveys for all surface

water systems regardless of size. 

2.3.5 Stage 1 Disinfection Byproduct Rule

The Stage 1 DBPR (63 FR 69389; December 16, 1998) applies to every PWSs that is either a

CWS or a nontransient noncommunity water system (NTNCWS) that treats its water with a

chemical disinfectant for either primary or residual treatment. In addition, certain requirements

for chlorine dioxide apply to transient noncommunity water systems (TNCWSs). The Stage 1

DBPR was published at the same time as the IESWTR (63 FR 69477; December 16, 1998).

The Stage 1 DBPR finalizes maximum residual disinfectant level goals (MRDLGs) for chlorine,

chloramines, and chlorine dioxide; MCLGs for four trihalomethanes (chloroform2

,

bromodichloromethane, dibromochloromethane, and bromoform), two haloacetic acids

(dichloroacetic acid and trichloroacetic acid), bromate, and chlorite; and for three disinfectants

(chlorine, chloramines, and chlorine dioxide), two groups of organic disinfection byproducts, total
FBRR Final RIA 2-18 April 2001

trihalomethanes (TTHMs) and five Halocetic Acids (HAA5), and two inorganic disinfection

byproducts (chlorite and bromate). The NPDWRs consist of maximum residual disinfectant

levels (MRDLs), maximum contaminant levels (MCLs), or treatment techniques for these

disinfectants and their byproducts. The NPDWRs also include monitoring, reporting, and public

notification requirements for these compounds. The Stage 1 DBPR includes the best available

technologies (BATs) upon which the MRDLs and MCLs are based. EPA believes the

implementation of the Stage 1 DBPR will reduce the levels of disinfectants and disinfection

byproducts in drinking water supplies. The Agency also believes the rule will extend public

health protection to an additional 20 million households that were not previously covered by

drinking water rules for disinfection byproducts.

2.3.6 Long Term 1 Enhanced Surface Water Treatment Rule 

LT1ESWTR will extend protections against Cryptosporidium and other disease-causing microbes

to small water systems that serve fewer than 10,000 people annually and that use surface water or

GWUDI sources. This rule was originally proposed together with FBRR as one rule in the

Federal Register (65 FR 19046; April 10, 2000) and is expected to be finalized early in 2001. 

Like the IESWTR, which addresses treatment processes at larger systems, the purposes of the

LT1ESWTR are to improve control of the protozoan Cryptosporidium and to address risk

trade-offs between pathogens and disinfection byproducts

LT1ESWTR uses the same framework as the IESWTR, while providing flexibility to small

systems. Key provisions established by the rule include an MCLG of zero for Cryptosporidium;

2-log Cryptosporidium removal requirements for systems that filter; strengthened combined filter

effluent turbidity performance standards of 1.0 NTU as a maximum and 0.3 NTU at the 95th

percentile monthly, based on four-hour monitoring for treatment plants using conventional

treatment or direct filtration; requirements for individual filter turbidity monitoring; disinfection

benchmark provisions to assess the level of microbial protection provided as facilities take the

necessary steps to comply with new disinfection byproduct standards; inclusion of

Cryptosporidium in the definition of GWUDI and in the watershed control requirements for

unfiltered public water systems; and requirements for covering new finished water reservoirs.

2.3.7 Stakeholder Involvement

EPA conducted two meetings to solicit feedback and information from the regulated community

and other concerned stakeholders on issues relating to the FBRR. The first meeting was held on

July 22 and 23, 1998 in Lakewood, CO. EPA presented potential regulatory components for the

FBRR. Breakout sessions with stakeholders were held to generate feedback on the regulatory

provisions being considered and to solicit feedback on next steps for rule development and

stakeholder involvement. Additionally, information was presented summarizing ongoing research

and data gathering regarding the recycle of filter backwash. The presentations generated useful

discussion and provided substantial feedback to EPA regarding technical issues, stakeholder

concerns, and possible regulatory options.

The second stakeholder meeting was held in Dallas, TX on March 3 and 4, 1999. EPA presented

new analysis, summaries of current research, revised regulatory options, and data collected since
FBRR Final RIA 2-19 April 2001

the July stakeholder meeting. Four breakout sessions were extremely useful and generated a wide

range of information, issues, and technical input from a diverse group of stakeholders.

In early June 1999, EPA mailed an informal draft of the FBRR preamble to the approximately 100

stakeholders who attended either of the public stakeholder meetings. Members of trade

associations and the Small Business Advocacy Review (SBAR) panel also received the draft

preamble. EPA received valuable comments and stakeholder input from 15 state representatives,

trade associations, environmental interest groups, and individual stakeholders.

During the comment period for the rule, the Agency held a public meeting in Washington DC on

April 14. Additionally, the proposed rule was either presented or discussed in nearly 50 meetings

across the United States. Finally, EPA mailed approximately 200 copies of the proposed rule to

stakeholders requesting comment. EPA received 67 comments from a variety of stakeholders

including, States, municipalities, tribes, elected officials, consultants, trade groups, and private

industry. These comments were reviewed and evaluated while developing the final rule.

2.4 Economic Rationale

2.4.1 Introduction

This section of the RIA discusses the statutory authority and the economic rationale for choosing a

regulatory approach to protect public health from drinking water contamination. The economic

rationale is provided in response to Executive Order 12866, Regulatory Planning and Review,

which states:

[E]ach agency shall identify the problem that it intends to address (including, where

applicable, the failures of the private market or public institutions that warrant new agency

action) as well as assess the significance of that problem (Sect. 1b(1)).

In addition, OMB guidance dated January 11, 1996, states that “in order to establish the need for

the proposed action, the analysis should discuss whether the problem constitutes a significant

market failure (p. 3).” Therefore, the economic rationale laid out in this section should not be

interpreted as the Agency’s approach to implementing the Safe Drinking Water Act (SDWA). 

Rather, it is the Agency’s economic analysis, as required by the Executive Order, to support a

regulatory approach to the public health issue at hand.

2.4.2 Statutory Authority for Promulgating the Rule

Section 1412(b)(1)(A) of SDWA requires EPA to establish NPDWRs for contaminants that may

have an adverse public health effect, that are known to occur, or present a substantial likelihood of

occurrence in public water systems at a frequency and level of public health concern and that

present a meaningful opportunity for health risk reduction for persons served by PWSs.

SDWA provides the authority to promulgate the FBRR. Specifically, it contains a provision

regarding the recycle of process flows, which states, “The Administrator shall promulgate a
FBRR Final RIA 2-20 April 2001

regulation to govern the recycling of filter backwash water within the treatment process of a

public water system.”(1412(b)(14)). 

2.4.3 The Economic Rationale for Regulation

In addition to the statutory directive to regulate surface water treatment and recycling, there is a

strong economic rationale for government regulation. The need for regulation is a direct result of

the structure of the market for publically provided drinking water. Economic theory suggests that

society’s well being is maximized when goods are produced and sold in well-functioning

competitive markets. A perfectly competitive market is said to exist when there are many

producers of a product selling to many buyers, and producers and consumers have complete

knowledge regarding the products of each firm. There must also be no barriers to entry in the

industry, and firms in the industry must not have any advantage over potential new producers. 

Two major factors in the public water supply industry do not satisfy the requirements for a

competitive market and lead to market failures that require regulation.

First, the public water market has monopolistic tendencies. These monopolies tend to exist

because it is not economically efficient to have multiple suppliers competing to build multiple

systems of pipelines, reservoirs, wells, and other facilities in the same locality. Instead, a single

firm or government entity performs these functions under public control. Under monopolistic

conditions, consumers are provided only one level of service with respect to the quality of a

product, in this case drinking water. Because water purveyors often operate in a monopolistic

environment, they may not respond to the usual market incentive to satisfy their consumers’ desire

for safety and high-quality drinking water.

Second, high information and transaction costs impede public understanding of the health and

safety issues concerning drinking water quality. The type of health risk potentially posed by trace

quantities of drinking water contaminants involve analysis and distillation of complex

toxicological and health sciences data. EPA has finalized the development of the Consumer

Confidence Report Rule, which makes water quality information more easily available to

consumers. This rule requires CWSs to post or to mail to their customers an annual report on

local drinking water quality. However, consumers will still have to analyze this information for

its health implications. Even if informed consumers are able to engage systems regarding these

health issues, the costs of such engagement, known as transaction costs and measured in personal

time and commitment, present significant impediments to consumer expressions of risk

preference.

SDWA regulations are intended to provide protection that would not otherwise occur from

exposure to drinking water contaminants in the existing market environment for public water

supply. The regulations set minimum performance requirements for all public water supplies in

order to protect all consumers from exposures to contaminants. SDWA regulations are not

intended to restructure flawed market mechanisms or to establish competition in supply, but

rather, to regulate the “product” produced within these markets. In other words, SDWA standards

establish the level of service to be provided in order to better reflect public preferences for safety. 

Also, by acting on behalf of all consumers in balancing the risk reduction and the social costs of
FBRR Final RIA 2-21 April 2001

achieving this reduction in risk, the federal regulations remove the high information and

transaction costs that would be required for consumers to make informed purchasing decisions.

2.5 Rule Summary 

EPA proposes the following requirements to meet the public health protection goals of the FBRR,

which will fulfill the statutory requirements of the SDWA. Exhibit 2-7 shows the rule’s

provisions that address recycle practices. The flow chart in Exhibit 2-8 illustrates how a system

using surface water or GWUDI as a source determines which provisions apply to it.

As Exhibit 2-7 shows, the three recycle provisions in the rule apply to water systems that:

` Use surface water or ground water under the direct influence of surface water,

` Use direct or conventional filtration processes, and 

` Recycle spent filter backwash water, sludge thickener supernatant, or liquids from

dewatering processes. 

The first provision generally requires that recycled filter backwash water, sludge thickener

supernatant, and liquids from dewatering processes be returned through the processes of a

system’s existing conventional or direct filtration system as defined in 40 CFR, Section 141.2. 

Plants that require an alternative recycle location to maintain optimal finished water quality, that

are designed to employ recycle flow as an intrinsic component of the treatment process, or that

have unique treatment requirements or processes may apply to the State if they want to return

recycle to an alternative location.

The second provision requires systems that practice conventional filtration and recycle spent filter

backwash, sludge thickener supernatant, or liquids from dewatering processes, notify the State in

writing that they practice recycle. When notifying the State, these systems must also provide

information characterizing their recycle flows. Specifically, they must provide:

` A plant schematic showing the origin of all recycle flows, the hydraulic conveyance used

to transport them, and the location where they are recycled back into the plant; and 

` Typical recycle flow in gallons per minute (gpm), highest observed plant flow

experienced in the previous year (gpm), design flow for the treatment plant (gpm), and, if

applicable, the State-approved operating capacity for the plant.

Additionally, the systems must collect and maintain information for review by the State as listed

below. States, which after evaluating the information, may require a system to modify their

recycle location or recycle practices. 

` Copy of the recycle notification and information submitted to the State.
FBRR Final RIA 2-22 April 2001

` List of all recycle flows and the frequency with which they are returned.

` Average and maximum backwash flow rate through the filters and the average and

maximum duration of the filter backwash process in minutes.

` Typical filter run length and a written summary of how filter run length is determined.

` The type of treatment provided for the recycle flow.

` Data on the physical dimensions of the equalization and/or treatment units, typical and

maximum hydraulic loading rates, type of treatment chemicals used and average dose and

frequency of use, and frequency at which solids are removed, if applicable. 

If a system does not recycle spent filter backwash water, sludge thickener supernatant, or liquids

from dewatering processes through the processes of a system’s existing conventional or direct

filtration system (including specifically: coagulation, flocculation, sedimentation, and filtration),

it must propose a schedule for making the necessary capital improvements associated with

managing the location of recycle or request approval of an alternate location.

The third provision requires systems that practice direct filtration and recycle spent filter

backwash, sludge thickener supernatant, or liquids from dewatering processes, notify the State in

writing that they practice recycle. When notifying the State, these systems must also provide

information characterizing their recycle flows. Specifically, they must provide:

` A plant schematic showing the origin of all recycle flows, the hydraulic conveyance used

to transport them, and the location where they are recycled back into the plant; and 

` Typical recycle flow in gallons per minute (gpm), highest observed plant flow

experienced in the previous year (gpm), design flow for the treatment plant (gpm), and, if

applicable, the State-approved operating capacity for the plant.

Additionally, the systems must collect and maintain information for review by the State as listed

below. States, which after evaluating the information, may require a system to modify their

recycle location or recycle practices. 

` Copy of the recycle notification and information submitted to the State.

` List of all recycle flows and the frequency with which they are returned.

` Average and maximum backwash flow rate through the filters and the average and

maximum duration of the filter backwash process in minutes.

` Typical filter run length and a written summary of how filter run length is determined.

` The type of treatment provided for the recycle flow.
FBRR Final RIA 2-23 April 2001

` Data on the physical dimensions of the equalization and/or treatment units, typical and

maximum hydraulic loading rates, type of treatment chemicals used and average dose and

frequency of use, and frequency at which solids are removed, if applicable. 

Exhibit 2-7. Summary of How the FBRR is Organized
FBRR Final RIA 2-24 April 2001

Does 

system use 

SW or 

GWUDI?

Done

No

Yes

No

Does 

recycle flows undergo

all steps of the filtration

process?

Must return before

coagulant addition or

obtain approval for

an alternate location.

No

No

Does

the system employ 

conventional or direct

filtration?

Must meet conventional

filtration requirements

Does

system employ

conventional or direct

filtration?

Does

the system

recycle?

Yes

Yes

Yes

Must meet direct

filtration requirements

Conventional

Filtration

Direct

Filtration

Exhibit 2-8. Illustration of How Provisions Apply to Different Types of Surface 

Water or GWUDI Systems
1

EPA has refined the language used to describe this provision, which would have required systems to return

recycle flows “prior to the point of primary coagulant addition” under the proposed rule. Language describing the

requirements that apply to conventional or direct systems that recycle has also been refined.

FBRR Final RIA 3-1 April 2001

3. Consideration of Regulatory Alternatives

In addition to the Filter Backwash Recycling Rule (FBRR) provisions described in the previous

section, EPA considered, and sought public comment on, four alternative regulatory options. 

The remainder of this chapter provides a detailed description of these regulatory alternatives and

presents EPA’s selected alternative and the rationale underlying its choice. 

3.1 Recycle Provisions

EPA considered four regulatory options for the recycle return location requirement. All of the

alternatives considered require select recycle flows to be returned prior to the point of primary

coagulant addition.1

 Alternatives R2, R3, and R4 place additional requirements on systems that

practice direct recycle or direct filtration, as well as other conventional systems that recycle. 

Exhibit 3-1 provides an overview of the alternatives that EPA considered for the recycling

provisions of the rule. Each of these alternatives is discussed in detail following the exhibit. 

Exhibit 3-1. Filter Backwash Alternatives (as Proposed)

System

Recycle Type Alternative R1 Alternative R2 Alternative R3 Alternative R4

Recycle Return

Location

Prior to primary coagulant addition.

State reviews requests for alternate recycle return location.

Direct Recycle

Systems

No Provision. Report selfassessment to State.Equalization for

recycle flows.

Sedimentation or

better for recycle

flows.1

State reviews

monitoring plan and

self-assessment

report and reports to

EPA whether a

change in recycle

practice is necessary.

Direct Filtration

Systems

No Provision. Report recycle practices to State. Sedimentation or

better for recycle

State reviews data characterizing recycle flows.

practice and reports to EPA whether a

change in recycle practice is necessary.

1

Note: This requirement would apply to all conventional filtration systems that do not provide sedimentation or

more advanced treatment for their recycle flows.
FBRR Final RIA 3-2 April 2001

Alternative R1

As proposed, the first alternative considered by the Agency required that subject plants using

surface water or GWUDI as a source return filter backwash, thickener supernatent, and liquids

from dewatering processes prior to the point of primary coagulant addition; see Section 2.1 of

this document for a description of these recycle flows. Plants that require an alternative recycle

return location to maintain optimal finished water quality (as indicated by finished water or intraplant turbidity levels), plants that are designed to employ recycle flow as an intrinsic component

of the treatment process, or plants with unique treatment requirements or processes may request

that the State allow an alternative recycle return location. 

Alternative R2

Alternative R2 was the alternative chosen for the rule. As proposed, Alternative R2, like the

other alternatives, would have required conventional or direct filtration plants to return select

recycle flows prior to the point of primary coagulant addition. This alternative would also have

required some direct recycle systems to perform a self-assessment of their recycle practice and

report the results to the State. The public water systems that would have been required to

conduct a self-assessment were those that met all of the following criteria:

1. Use surface water or GWUDI as a source and employ conventional rapid granular

filtration treatment.

2. Employ 20 or fewer filters to meet production requirements during the highest

production month in the 12-month period prior to the rule’s compliance date.

3. Recycle spent filter backwash or thickener supernatant directly to the treatment

process (i.e., recycle flow is returned within the treatment process of a PWS without

first passing the recycle flow through a treatment process designed to remove solids,

a raw water storage reservoir, or some other structure with a volume equal to or

greater than the volume of spent filter backwash water produced by one filter

backwash event).

The systems that met all the above criteria would have been required to develop and submit a

recycle self-assessment monitoring plan to the State no later than 3 months after the rule’s

effective date. At a minimum, the monitoring plan was to identify the month during which

monitoring will be conducted, contain a schematic identifying the location of raw and recycle

flow monitoring devices, describe the type of flow monitoring devices to be used, and describe

how data from the raw and recycle flow monitoring devices will be simultaneously retrieved and

recorded.

As proposed, systems were to submit a self-assessment report containing the results of

monitoring to the State within 1 month of completing the monitoring. At a minimum, the report

was to provide the following information:
FBRR Final RIA 3-3 April 2001

1. All source and recycle flow measurements taken and the dates they were taken. For

all events monitored, a report of the times the filter backwash recycle event was

initiated, the flow measurements taken at three minute intervals, and the time the

filter backwash recycle event ended. The system must also report the number of

filters in use when the backwash recycle event was monitored.

2. All data used and calculations performed to determine whether the system exceeded

operating capacity during monitored recycle events and the number of event flow

values that exceeded State approved operating capacity.

3. A plant schematic showing the origin of all recycle flows, the hydraulic conveyance

used to transport them, and their final destination in the plant.

4. A list of all the recycle flows and the frequency at which they are returned to the

plant.

5. Average and maximum backwash flow through the filters and the average and

maximum duration of backwash events in minutes, for each monitoring event.

6. Typical filter run length, number of filters typically employed, and a written

summary of how filter run length is determined (e.g., preset run time, headloss, or

turbidity level).

The proposal envisioned that systems would develop and submit the self-assessment monitoring

plan to the State within three months after the rule’s compliance date for each plant subject to the

requirements.

EPA had proposed to require that the States review all self-assessment reports submitted by

PWSs and report to the Agency one of the following for each individual plant:

1. A finding that modifications to recycle practice are necessary, followed by a brief

description of the required change and a summary of the reason(s) the change is

required.

2. A finding that changes to recycle practice are not necessary and a brief description of

the reason(s) this determination was made.

As proposed, Alternative R2 also required direct filtration plants using surface water and

GWUDI that recycle to the treatment process to report certain data that characterize their recycle

practice to the State:

1. Whether recycle flow treatment or equalization is in place.

2. The type of treatment provided for the recycle flow.
FBRR Final RIA 3-4 April 2001

3. If equalization, sedimentation, or some type of clarification process is used, the

following information should be provided: the physical dimensions of the unit

sufficient to allow calculation of its volume, and the type, typical dose, and frequency

at which treatment chemicals are used, if applicable.

4. The minimum and maximum hydraulic loading the treatment unit experiences.

5. The maximum backwash rate, duration, typical filter run length, and the number of

filters at the plant.

The purpose of this requirement was to allow States to assess whether the existing recycle

practice of direct filtration plants addresses the potential risks posed by recycle. The Agency

believes that direct filtration plants need to remove oocysts from recycle flow prior to

reintroducing it to the treatment process. The proposal anticipated that States would be required

to report their determination for each system to EPA and provide a brief explanation of the

reason(s) for the decision.

Alternative R3

As with the previously described alternatives, this alternative (R3) would require conventional or

direct filtration systems to return select recycle flows prior to the point of primary coagulant

addition. Unlike Alternative R2, however, this option would not require a self-assessment. It

would, instead, require all recycle plants without existing recycle flow equalization or treatment

to install recycle flow equalization. In addition, direct filtration plants would have to report data

on recycle treatment to the State.

Alternative R4

As with all other alternatives, Alternative R4 would require conventional or direct filtration

systems to return select recycle flows prior to the point of primary coagulant addition. Unlike

Alternatives R2 and R3, respectively, this option would not require a self-assessment nor would

it require direct filtration plants to report on their recycle practices. It would, instead, require

conventional filtration plants that recycle within the treatment process to provide sedimentation

or more advanced recycle treatment. Similarly, direct filtration plants would also need to provide

sedimentation or more advanced recycle treatment.

3.2 EPA’s Selected Alternative 

EPA evaluated all of the above alternatives and considered public comments received on these

alternatives in making its choice to promulgate a refinement of Alternative R2. EPA concluded

that a national treatment requirement is inappropriate at this time due to data deficiencies. 

However, the Agency believes that the collection and reporting of information characterizing

recycle practices will aid the States in targeting recycle treatment for higher risk recycle

practices. 
2

EPA has refined the language used to describe this provision, which would have required systems to return

recycle flows “prior to the point of primary coagulant addition” under the proposed rule. Language describing the

requirements that apply to conventional or direct systems that recycle has also been refined.

FBRR Final RIA 3-5 April 2001

Regarding recycle return location, the Agency recognizes the value of having recycle be returned

early in the treatment train; however, it also recognizes unique site-specific conditions. As a

result, the recycle return provision provides flexibility. Specifically, it allows the State to

approve an alternate recycling location for systems on a case-by-case basis.

Each of the final three FBRR requirements and rationale for their selection is discussed in detail

below.

Recycle Location

Many commenters agreed with the proposal requiring recycle be returned prior to the point of

primary coagulant addition was appropriate, while several others noted that recycle should be

allowed concurrent with the point of primary coagulant addition. Still others, most notably

EPA’s Science Advisory Board (SAB), indicated that because of the site-specific characteristics

of recycle, defining a single acceptable recycle return location was inappropriate because it could

reduce the performance of the system. 

After evaluating the data provided by those submitting public comments, EPA believes that a 

level of health protection comparable to the proposal can be achieved by refining the recycle

return location. Specifically, the FBRR requires that recycled filter backwash water, sludge

thickener supernatant, and liquids from dewatering processes be returned through the processes

of a system’s existing conventional or direct filtration system as defined in 40 CFR, Section

141.2.2

 EPA believes this alternate recycle location will ensure that recycle flows are given

adequate treatment to achieve 2-log (99%) removal of Cryptosporidium. The proposal originally

required that recycle be returned prior to the point of primary coagulant addition.

Like all of the proposed alternatives, plants that require an alternate location to maintain optimal

finished water quality, that are designed to employ recycle flow as an intrinsic component of the

treatment process, or that have unique treatment requirements or processes may request an

alternative recycling location from the State. 

Conventional Filtration Recycle Requirement

Given the variety and site-specific nature of recycle practices throughout the country, the Agency

believes it is necessary to require systems to notify States that they practice recycle, and provide

information the State could utilize to evaluate whether a treatment plant may be susceptible to

hydraulic disruptions as a result of recycling. The second FBRR provision specifies the

components of this notification requirement. Specifically, it requires systems that practice

conventional filtration and recycle spent filter backwash, sludge thickener supernatant, or liquids

from dewatering processes notify the State in writing that they practice recycle. 
FBRR Final RIA 3-6 April 2001

The original proposal addressed the need for recycle information by attempting to identify the

subset of systems that would be most susceptible to hydraulic surges by requiring that only

systems without equalization or treatment (referred to as “direct recycle”) meet the reporting

requirements. This provision required that systems employing 20 or fewer filters and recycling

spent filter backwash water, thickener supernatant, or liquids from dewatering process within the

treatment process must perform a one month, one-time recycle self-assessment. The self

assessment required a monitoring plan, hydraulic flow monitoring, and a self-assessment report

containing additional recycle information be submitted to the State, which could require

modifications to a system’s recycle practice in order to protect public health.

The Agency received many comments regarding what was originally titled Direct Recycle

Reporting in the proposed rule. Many commenters believed that the operational values used in

the analysis conducted by the Agency to arrive at a 20 filter cut-off did not accurately represent

the true range of values witnessed throughout the country. Similarly, many commenters noted

that excluding systems that treat or equalize recycle flows was inappropriate because of the lack

of clearly defined, widely-used parameters for the definitions of equalization and treatment of

recycle. Once again this requirement may fail to accurately characterize hydraulic surge potential

at systems with significantly different equalization or treatment practices than those assumed by

the Agency and documented by research. Accordingly, EPA has modified this requirement, such

that it now applies to all conventional filtration systems that recycle. 

The system reporting and recordkeeping components of the requirements are discussed below.

These requirements were also refined from the proposal to collect basic flow information rather

than flow monitoring data originally required. EPA believes these less burdensome requirements

still provide information that can be used by States to evaluate whether hydraulic surges may

pose problems.

System Reporting Requirements

When notifying the State, these systems must also provide information characterizing their

recycle flows. Specifically, they must provide:

• A plant schematic showing the origin of all recycle flows, the hydraulic conveyance

used to transport them, and the location where they are recycled back into the plant;

and 

• Typical recycle flow in gallons per minute (gpm), highest observed plant flow

experienced in the previous year (gpm), design flow for the treatment plant (gpm),

and, if applicable, the State-approved operating capacity for the plant.

System Recordkeeping Requirements

Additionally, the systems must collect and maintain information for review by the State as listed

below. States, which after evaluating the information, may require a system to modify their

recycle location or recycle practices. 
FBRR Final RIA 3-7 April 2001

• Copy of the recycle notification and information submitted to the State.

• List of all recycle flows and the frequency with which they are returned.

• Average and maximum backwash flow rate through the filters and the average and

maximum duration of the filter backwash process in minutes.

• Typical filter run length and a written summary of how filter run length is

determined.

• The type of treatment provided for the recycle flow.

• Data on the physical dimensions of the equalization and/or treatment units, typical

and maximum hydraulic loading rates, type of treatment chemicals used and average

dose and frequency of use, and frequency at which solids are removed, if applicable. 

 

Direct Filtration Recycle Requirement

The third FBRR provision is identical to the second provision described immediately above,

except it extends the recycle information recordkeeping and reporting requirements to direct

filtration systems. 

The Agency believes the reporting and maintenance of the recycle information is critical given

the nature of direct filtration systems. By definition, direct filtration does not have a

sedimentation or solids removal step. Any solids which enter the process either are deposited on

the filter or travel through the filter. If the recycle flow is not adequately treated before being

returned to the primary treatment train, significant numbers of the oocysts captured on a filter

during a filter run will be returned to the plant. These oocysts are again loaded onto the filters,

increasing the risk that disinfectant-resistant pathogens such as Cryptosporidium can slip

through filtration, thereby posing a public health risk. Therefore, EPA believes States should be

provided with and have access to information they can use to evaluate whether a treatment plant

may be susceptible to hydraulic disruptions as a result of recycling, and whether the existing

recycle practices sufficiently addresses potential health risks.

Many States commented that information required to be submitted as part of the proposed Direct

Filtration Reporting was often duplicative of information already available to the State. States

also noted that submittal of direct filtration reports would result in an increased burden, and

could be problematic, given resource limitations. 

To eliminate redundant reporting and minimize burden, EPA modified the Direct Filtration

Reporting requirement, so that a system must collect the data and keep it on file for State review. 

This will provide States the ability to reduce transaction costs by incorporating review of the
FBRR Final RIA 3-8 April 2001

recycle practice data into Sanitary Surveys, other inspections (i.e., comprehensive performance

evaluations), or other State-specific program elements.

EPA believes that data collection and maintenance for this FBRR requirement allows systems

and States to evaluate recycle practices and determine whether existing recycle practices

sufficiently address potential health risks.

 
FBRR Final RIA 4-1 April 2001

4. Baseline Analysis

To understand the benefits of the Filter Backwash Recycling Rule (FBRR) and estimate the

economic and financial impact of the rule’s regulatory options on the water supply industry and

ultimately on customers, EPA developed a baseline before considering the effect of any single

regulatory option. A baseline is defined as a characterization of the industry and its operations

prior to the rulemaking. Much of the data used to develop the baseline are provided in the

Occurrence Assessment for the Long Term 1 Enhanced Surface Water Treatment and Filter

Backwash Recycling Rules (U.S. EPA, 2001a), which provides data on the occurrence of

Cryptosporidium in recycle flows and on the health effects and hazards posed by

Cryptosporidium in drinking water. 

To develop additional baseline information for the FBRR, EPA collected and analyzed data on

the number of systems that use surface water and ground water under the direct influence of

surface water (GWUDI), the percentage of GWUDI systems that use conventional or direct

filtration, and the percentage of these systems that recycle. These data are used to estimate the

number of water systems impacted by the rule. The exception to this approach is EPA’s analysis

of systems serving more than one million persons. EPA used the system schematics submitted as

part of the Information Collection Rule (ICR) and data from the Safe Drinking Water

Information System (SDWIS) to determine whether systems serving more than 1 million persons

would be affected by the rule. 

This chapter discusses the sources of information used to develop the baseline, the approaches

used to analyze these data, key assumptions associated with the analyses, and the resulting

estimates. Specifically, this chapter presents the information used to estimate the number of

systems affected by the rule’s provisions in the following sections:

` Section 4.1, Baseline Profile of Surface Water and GWUDI Systems, provides

information on the universe of surface water systems and the populations they serve. 

` Section 4.2, Profile of Systems Subject to the FBRR, explains how EPA estimated the

number of systems potentially affected by the FBRR—i.e., those surface water and

GWUDI systems that use conventional or direct filtration and recycle spent filter

backwash water, sludge thickener supernatant, or liquids from dewatering processes. 

` Section 4.3, Profile of Systems Subject to Each FBRR Provision, uses the

assumptions in Sections 4.1 and 4.2 to estimate the number of systems subject to

each provision of the FBRR. 
FBRR Final RIA 4-2 April 2001

How many surface water and GWUDI systems use

conventional or direct filtration? (Section 4.2)

How many water systems use surface water or

GWUDI, and how many people do they serve?

(Section 4.1)

How many of these systems recycle--i.e., How many

systems are potentially impacted by the FBRR?

(Section 4.2)

How many of

these must move

their recycle return

location?

 (Section 4.3)

How many of these

must meet the

reporting

requirements for

conventional filtration

systems?

(Section 4.3)

How many of these

must meet the

reporting

requirements for

direct filtration

systems?

(Section 4.3)

Summary of the Baseline Analysis

4.1 Baseline Profile of Surface Water and GWUDI Systems

EPA analyzed data on the number of systems that use surface water and GWUDI and the

resources available to the systems. Data inputs included the total number of affected systems, the

households and populations served

by these systems, average and

maximum system flow rates, costs of

employing system operators, and

system revenues and expenses. This

analysis involved input from

knowledgeable stakeholders and

incorporated the latest available

research.

Prior to presenting baseline

information for public surface water

and GWUDI water systems, it is

necessary to first define some terms

used to describe water systems. EPA

uses the following classifications. 

• A public water system

(PWS) is one that serves

25 or more persons or

has 15 or more service

connections and operates

at least 60 days per year. PWSs can be publicly or privately owned. They can also

be classified as either a community or a noncommunity system (as defined below). 

• A community water system (CWS) is one that serves at least 15 service connections

used by year-round residents or regularly serves at least 25 year-round residents.

• A noncommunity water system (NCWS) does not have year-round residents, but

serves at least 15 service connections used by travelers or intermittent users for at

least 60 days each year, or serves an average of 25 individuals for at least 60 days a

year. 

Noncommunity water systems can be further classified as either transient or nontransient:

• A nontransient noncommunity water system (NTNCWS) serves at least 25 of the

same persons over six months per year (e.g., factories, schools, office buildings, and

hospitals with their own water source).
FBRR Final RIA 4-3 April 2001

• A transient noncommunity water system (TNCWS) meets the definition of a “public

water system,” but does not serve at least 25 of the same persons over six months per

year (e.g., many restaurants, rest stops, parks).

Public water systems are also classified by the source water they use as being either surface water

(e.g., drawn from lakes, streams, rivers, etc.) or ground water (e.g., drawn from wells or springs). 

Some ground water sources (e.g., riverbank infiltration/galleries) are directly impacted by

adjacent surface water bodies and are referred to as “ground water under the direct influence of

surface water.” As noted in Chapter 2, the FBRR addresses surface water systems and GWUDI

systems. 

The Agency used two sources to characterize the universe of surface water and GWUDI systems: 

the Safe Drinking Water Information System (SDWIS) and the Community Water Supply

Survey. The following paragraphs provide a brief overview of each of the data sources. 

` Safe Drinking Water Information System (SDWIS). SDWIS contains information

about public water systems including violations of EPA’s regulations for safe

drinking water. Although SDWIS includes a variety of information including system

name, identification number, population served, geographic location, type of source

water, type of treatment (if provided), and known violations, the only SDWIS data

that were used in this RIA were type of PWS (CWS, NTNCWS, or TNCWS),

population served; and type of source water (surface water, GWUDI, or ground

water). 

` Community Water System Survey (CWSS). EPA conducted the 1995 Community

Water System Survey to obtain data to support its development and evaluation of

drinking water regulations. The survey consisted of a stratified random sample of

3,700 water systems nationwide (surface water and ground water). The survey asked

24 operational and 13 financial questions.

EPA has compiled much of this information in the Drinking Water Baseline Handbook (EPA

2000b). The Baseline Handbook was developed to serve as a single integrated set of data that

defines baseline characteristics or conditions of the regulated community, the customers, and

governmental entities. Data contained in the handbook were compiled from SDWIS (fourth

quarter 1998) and the CWSS.

4.1.1 Number of Systems

Nationally, SDWIS indicates that there are approximately 13,608 public water systems that use

surface water or GWUDI as the primary source (U.S. EPA, 2000b). This number includes 13

systems that serve one million persons or more. 

Exhibit 4–1 presents the number of surface water systems in the United States by population

served. The totals in Exhibit 4–1 include water systems that treat their own surface water (either

drawn from their own source or purchased from other systems), as well as systems that purchase

treated water from other systems (called “purchased water systems”). Although the provisions of
FBRR Final RIA 4-4 April 2001

Population Size

Categories 

System Type

 CWS TNCWS NTNCWS Total

<100 1,092 1,363 271 2,726

101 - 500 2,003 517 295 2,815

501 - 1,000 1,220 88 106 1,414

1,001 - 3,300 2,420 61 80 2,561

3,301 - 9,999 1,844 28 23 1,895

Small System

Subtotal 8,579 2,057 775 11,411

10,000 - 50,000 1,607 7 4 1,618

50,001 - 100,000 300 3 1 304

100,001 - 1,000,000 261 0 1 262

> 1,000,000 13 0 0 13

Large System 

Subtotal 2,181 10 6 2,197

Total Number of

Systems 10,760 2,067 781 13,608

Exhibit 4–1. Total Number of Systems Using Surface Water or GWUDI by System

Type and Service Population Category

the FBRR apply only to systems that treat their water, the Agency chose to include purchased

water systems in order to estimate the total population affected by FBRR. Purchased water

systems must be included to properly estimate the total number of persons affected by the rule. 

When EPA estimates the number of persons served by a water system, it counts only the local

retail population of each system. Thus, the official “population served” by a system that sells

water to other systems does not count the customers of those other systems that purchase its

water. EPA included purchased water systems in the analysis to obtain an estimate for benefits

passed on the purchased water systems, whose customers are not included in EPA’s data on retail

population served. 

Of the 13,608 water systems that use surface water or GWUDI, about 79 percent are CWSs, with

TNCWSs making up 15 percent and NTNCWSs making up about 6 percent. In addition, systems

are divided into the seven size categories used throughout the analysis. These categories are

consistent with industry definitions of system size categories. According to SDWIS, about 80

percent of the CWSs and over 99 percent of both the TNCWSs and NTNCWSs that use surface

water or GWUDI serve fewer than 10,000 persons, which EPA defines as a small system. 

Collectively, almost 84 percent of water systems that use surface water or GWUDI systems are

small systems. 
FBRR Final RIA 4-5 April 2001

System Population Size Category Total Population Potentially Affected 

<100 135,138

101–500 773,064

501–1,000 1,068,556

1,001–3,300 5,051,439

3,301–9,999 11,276,617

Small System Subtotal 18,304,814

10,000–50,000 37,085,605

50,001–100,000 20,772,814

100,001-1,000,000 65,527,262

>1,000,000 28,658,586 

Large System Subtotal 152,044,447

Total 170,349,081 

Exhibit 4–2. System Population Size Categories and Total Population

Potentially Affected

EPA integrated data on the number of systems in each size category into the national compliance

cost model to estimate unit costs, determine treatment developed for compliance forecast or

decision trees, and size equipment. Average and system design flows, expressed in millions of

gallons per day (mgd), were developed separately from the cost model but are key components in

generating unit costs. The model uses data on system flows to estimate equipment size, basin

dimensions, filter bed and media requirements, and energy costs.

4.1.2 Population Served

System population characteristics are important to this analysis for several reasons. For example,

it is important to know the total population served by surface water and GWUDI systems in order

to address the distribution of costs and to estimate household costs. As presented in Exhibit 4–2,

CWSs that use surface water or GWUDI serve over 170 million persons. Although almost 84

percent of surface water and GWUDI systems serve fewer than 10,000 persons (Exhibit 4–1),

these small systems serve just over 10 percent of the consumers who use surface water or

GWUDI. 
FBRR Final RIA 4-6 April 2001

4.2 Profile of Systems Subject to the FBRR

This section summarizes the number of systems potentially affected by the FBRR. For water

systems that serve fewer than one million people (the vast majority of systems), Sections 4.2.1

and 4.2.2 explain how EPA used the results of the baseline profile of surface water and GWUDI

systems, along with data on treatment and recycle practices, to estimate the number of systems

that meet the rule’s criteria. The number systems serving greater than 1 million persons is also

presented in Sections 4.2.1 and 4.2.2. However, an alternative approach was used to estimate

how the rule applies to water systems that serve more than one million people—Section 4.3.4

summarizes this approach.

The FBRR applies to all surface water and GWUDI systems that use conventional or direct

filtration and recycle spent filter backwash water, sludge thickener supernatant, or liquids from

dewatering processes. The previous section presented the derivation of the number of surface

water and GWUDI systems, based on data from SDWIS and compiled in the Drinking Water

Baseline Handbook (U.S. EPA, 2000b). This section shows EPA’s approach for characterizing

filtration and recycle practices of surface water and GWUDI systems, based on data from the

CWSS (U.S. EPA 1997a), the 1996 Information Collection Rule, as well as data from a survey

performed by the American Water Works Association (AWWA, 1998). 

4.2.1 Profile of Filtration Practices

The FBRR applies to water systems using surface water or GWUDI, that use conventional and

direct filtration, and practice recycling. Using the data contained in Exhibit 4–1, the Agency

applied the percentages of surface water and GWUDI systems that filter (as noted in the CWSS)

to develop an estimate of the number of systems that filter. This resulted in an estimated 11,062

surface water and GWUDI systems that filter, as shown below:

Number Systems Using

Surface Water or

GWUDI

X % of Systems that

Filter = Number of Systemsthat Filter = 11,062

Exhibit 4-3 provides this estimate broken down by system size and type.

Given the estimate of 11,062 systems that filter, EPA used information in the CWSS database to

estimate the number of systems that use conventional or direct filtration. This resulted in an

estimated 7,738 surface water and GWUDI systems that use conventional or direct filtration, as

shown below immediately following Exhibit 4-3.
FBRR Final RIA 4-7 April 2001

Population Size

Categories 

Est. % that

Filter2

Number of Systems by System Type3

 Community TNCWS NTNCWS Total

<100 75.1% 857 1,070 213 2,140

101 - 500 71.0% 1,422 367 209 1,999

501 - 1,000 79.3% 967 70 84 1,121

1,001 - 3,300 81.7% 1,977 50 65 2,092

3,301 - 9,999 86.5% 1,595 24 20 1,639

Small System

Subtotal 6,818 1,581 591 8,991

10,000 - 50,000 96.3% 1,548 7 4 1,558

50,001 - 100,000 88.0% 264 3 1 268

100,001 - 1,000,000 93.4% 244 0 1 245

Large System

Subtotal 2,055 9 6 2,070

Total Number of

Systems 8,874 1,590 598 11,062

Note: Columns and row might not add to total due to rounding.

1

Because the recycling practices for systems serving more than 1 million persons are determined directly from ICR

data, the intermediate step of determining the number of these systems that filter is not included in this analysis. See

Section 4.3.4 in this chapter for a detailed explanation of this calculation.

2

Source: CWSS (U.S. EPA, 1997a).

3

Based on the number of systems reported in Exhibit 4–1.

Exhibit 4–3. Estimated Number of Systems that Filter1

Number Systems That

Filter X

% of Filtration

Systems that Are

Conventional or

Direct

=

Number of Systems

that Use Conventional

or Direct Filtration

= 7,738

Exhibit 4–4 provides this estimate broken down by system size and type.
FBRR Final RIA 4-8 April 2001

Population Size

Categories 

Est. % that

Use Conv. or

Direct2

Number of Systems by System Type3

 Community TNCWS NTNCWS Total

<100 38% 326 407 81 813

101 - 500 55% 782 202 115 1,099

501 - 1,000 73% 706 51 61 819

1,001 - 3,300 77% 1,522 38 50 1,611

3,301 - 9,999 90% 1,436 22 18 1,475

Small System

Subtotal 4,772 720 326 5,817

10,000 - 50,000 92% 1,426 6 4 1,434

50,001 - 100,000 98% 259 3 1 262

100,001 - 1,000,000 92% 224 0 1 225

Large System

Subtotal 1,909 9 5 1,921

Total Number of

Systems 6,695 728 331 7,738

Note: Columns and row might not add to total due to rounding.

1

Because the recycling practices for systems serving more than 1 million persons are determined directly from ICR

data, the intermediate step of determining the number of these systems that use conventional or direct filtration is not

included in this analysis. See Section 4.3.4 in this chapter for a detailed explanation of this calculation.

2

Source: CWSS (U.S. EPA, 1997a).

3

Based on the number of systems reported in Exhibit 4–3.

Exhibit 4–4. Estimated Number of Filtration Systems that Use Conventional or

Direct Filtration1

4.2.2 Profile of Recycling Practices

As noted above, the FBRR applies to conventional or direct filtration systems that recycle spent

filter backwash water, sludge thickener supernatant, or liquids from dewatering processes. EPA

estimated this universe of potentially affected systems (except for those serving 1 million persons

or more) as follows:

Number Conventional

Filtration Systems that

Use Surface Water or

GWUDI

X % That Recycle 

Universe of Systems 

Potentially Affected by

the FBRR

(@1,000,000)

 4,643

EPA then added to this estimate seven plants operated by systems serving greater than 1 million

people (see Section 4.3.4 for discussion), resulting in a total of 4,650 systems.
FBRR Final RIA 4-9 April 2001

Population Size

Categories 

Est. Percent of

Systems that

Recycle1

Number of Systems by System Type2

 CWS TNC NTNCWS Total

<100 60% 196 244 49 488

101 - 500 60% 469 121 69 660

501 - 1,000 60% 424 31 37 491

1,001 - 3,300 60% 913 23 30 967

3,301 - 9,999 60% 861 13 11 885 

Small System

Subtotal 2,863 432 195 3,490 

10,000 - 50,000 60% 854 4 2 860

50,001 - 100,000 60% 155 2 1 157

100,001 - 1,000,000 60% 135 0 1 135

>1,000,000 see Section 4.3.4 7 007

Large System

Subtotal 1,151 5 4 1,160

Total Number of

Systems 4,014 437 199 4,650

Note: Columns and row might not add to total due to rounding.

1

Source: Cornwell and Lee, 1994.

2

Based on the number of systems reported in Exhibit 4–4.

Exhibit 4–5. Number of Conventional or Direct Systems that Use Surface Water

or GWUDI and Recycle1

The total number of conventional and direct filtration systems was derived based on filtration

techniques cited in the CWSS (Exhibit 4–4). EPA estimates that 60 percent of these systems

recycle filter backwash (Cornwell and Lee, 1994). Exhibit 4-5 applies this estimated percentage

to the universe of conventional and direct filtration systems to derive the number of potentially

affected systems by size and type category. 
FBRR Final RIA 4-10 April 2001

4.3 Profile of Systems Subject to Each FBRR Provision

The FBRR contains three key provisions. Sections 4.3.1 through 4.3.4 summarize the derivation

of the estimated portion of the 4,650 recycling systems that are expected to be impacted by each

of these provisions. 

4.3.1 Recycle Return Location

The purpose of the first provision of the FBRR is to protect the integrity of chemical treatment

and ensure that recycle flows are passed through as many physical removal processes as possible

to provide maximum opportunity for removal of Cryptosporidium oocysts from the recycle flow.

The first provision of FBRR requires surface water and GWUDI systems that use conventional or

direct filtration to provide complete treatment for recycled filter backwash, thickener supernatant,

and liquids from dewatering processes, or obtain State approval to recycle to an alternate

location. In other words, systems potentially affected by the provision include systems that:

` Use surface water or GWUDI,

` Use conventional or direct filtration,

` Recycle backwash waters, and

` Do not return backwash flows through the processes of a system’s existing

conventional or direct filtration system as defined in 40 CFR, Section 141.2.

To characterize water systems’ recycle practices, EPA analyzed data from the Information

Collection Rule and the AWWA “FAX” Survey (1998). The ICR (61 FR 24354) required large

PWSs to monitor for microbial contaminants and disinfection byproducts. The rule also required

these systems to report whether recycle is practiced for sample washwater (i.e., recycle flow)

between the washwater treatment plant (if one existed) and the point at which recycle is added to

the process train. The AWWA sent the FAX survey (AWWA, 1998) to its membership in June

1998 to gather information on recycle practices. The survey was completed by water systems

operating a total of 335 plants. The Regulatory Impact Analysis for the proposed LT1ESWTR

and FBRR (U.S. EPA., 2000e) contains a detailed analysis of the ICR and FAX survey data.

EPA used data from the ICR and FAX survey to calculate an estimation of the number of systems

that must move their recycle return location or obtain State approval to recycle at an alternate

location, as follows:

Number Conventional

and Direct Filtration

Systems that Use

Surface Water or

GWUDI and Recycle

X

% Whose Recycle

Flows Do Not

Undergo all

Filtration Steps



Number of Systems

Potentially Impacted

by the Recycling

Return 

Location Provision

(@1,000,000)

 464
FBRR Final RIA 4-11 April 2001

Population Size

Categories 

Est. Percent of

Systems1

Number of Systems by System Type2

CWS TNCWS NTNCWS Total

<100 10% 20 24 5 49

101 - 500 10% 47 12 7 66

501 - 1,000 10% 42 3 4 49

1,001 - 3,300 10% 91 2 3 97

3,301 - 9,999 10% 86 1 1 89

Small System

Subtotal 286 43 20 349

10,000 - 50,000 10% 85 <1 <1 86

50,001 - 100,000 10% 16 <1 <1 16

100,001 - 1,000,000 10% 14 - <1 14

>1,000,000 see Section 4.3.4 2 0 0 2

Large System

Subtotal 116 <1 <1 117

Total Number of

Systems 403 44 20 466

Note: Columns and row might not add to total due to rounding.

1

Percentages reflect the estimated percent of systems that use surface water or GWUDI, that recycle, and that do not

return recycle flows to a point in the treatment train such that all step’s of a system’s conventional or direct filtration

are not employed. Source: FAX Survey.

2

Based on the number of systems reported in Exhibit 4–5.

Exhibit 4–6. Number of Systems that Must Move Their Recycle Return Location

or Obtain State Approval to Recycle at an Alternate Location

EPA then added to this estimate two plants operated by systems serving greater than 1 million

people (see Section 4.3.4 for discussion), resulting in a total of 466 systems.

Based on an analysis of survey results, EPA estimates that 23 percent of recycling systems return

prior to rapid mix. Of those that do not return prior to rapid mix, EPA estimates that 50 to 60

percent return to another location that ensures that all steps of a system’s conventional or direct

filtration are employed. Thus, between 40 and 50 percent of systems that do not currently return

to a point prior to rapid mix—conservatively about 10 percent of all systems that recycle—are

affected by the recycling return provision. Exhibit 4–6 presents these systems by type and size

category. 

4.3.2 Conventional Filtration Recycle Reporting

The FBRR requires systems which practice conventional filtration and recycle spent filter

backwash, sludge thickener supernatant, or liquids from dewatering processes to notify the State

in writing that they practice recycle. To calculate the number of systems that must meet this
FBRR Final RIA 4-12 April 2001

Population Size

Categories 

Est. Percent of

Systems1

Number of Systems by System Type2

CWS TNCWS NTNCWS Total

<100 93% 182 227 45 454

101 - 500 93% 436 113 64 613

501 - 1,000 93% 394 28 34 457

1,001 - 3,300 93% 849 21 28 899

3,301 - 9,999 93% 801 12 10 823

Small System

Subtotal 2,663 402 182 3,246

10,000 - 50,000 93% 794 3 2 800

50,001 - 100,000 93% 144 1 <1 146

100,001 - 1,000,000 93% 125 - <1 126

>1,000,000 see Section 4.3.4 3 0 0 3

Large System

Subtotal 1,067 5 3 1,075

Total Number of

Systems 3,730 406 185 4,321

Note: Columns and row might not add to total due to rounding.

1

Percentages reflect the potentially affected universe that use conventional filtration.

2

Based on the number of systems reported in Exhibit 4–5.

Exhibit 4–7. Number of Systems Affected by Conventional Filtration

Reporting Requirements

reporting requirement, EPA used FAX survey data to calculate the number of systems that use

conventional filtration, as follows:

Number Conventional

and Direct Filtration

Systems that Use

Surface Water or

GWUDI and Recycle

X

% that Use

Conventional

Filtration



Number of Systems

that Use

Conventional

Filtration

(@1,000,000)

 4,318

EPA then added to this estimate three plants operated by systems serving greater than 1 million

people (see Section 4.3.4 for discussion), resulting in a total of 4,321 systems. Exhibit 4–7 shows

the estimated number of conventional filtration systems, by size and type. 

4.3.3 Direct Filtration Recycling Reporting

The FBRR requires systems that practice direct filtration and recycle spent filter backwash,

sludge thickener supernatant, or liquids from dewatering processes to report their recycling
FBRR Final RIA 4-13 April 2001

Population Size

Categories 

Est. Percent of

Systems1

Number of Systems by System Type2

CWS TNCWS NTNCWS Total

<100 7% 14 17 3 34

101 - 500 7% 33 8 5 46

501 - 1,000 7% 30 2 3 34

1,001 - 3,300 7% 64 2 2 68

3,301 - 9,999 7% 60 1 1 62

Small System

Subtotal 200 30 14 244

10,000 - 50,000 7% 60 <1 <1 60

50,001 - 100,000 7% 11 <1 0 11

100,001 - 1,000,000 7% 9 - 0 9

>1,000,000 see Section 4.3.4 4 0 0 4

Large System

Subtotal 84 <1 <1 85

Total Number of

Systems 285 31 14 329

Note: Columns and row might not add to total due to rounding.

1

Percentages reflect the potentially affected universe that use direct filtration.

2

Based on the number of systems reported in Exhibit 4–5.

Exhibit 4–8. Number of Systems Affected by Direct Filtration

Reporting Requirements

practices to the State. This provision is expected to impact about 325 water systems serving

fewer than 1 million people, as shown in the calculation below:

Number Conventional

and Direct Filtration

Systems that Use

Surface Water or

GWUDI and Recycle

X % that Use Direct

Filtration 

Number of Recycling

Systems that Use

Direct Filtration

(@1,000,000)

 325

EPA then added to this estimate four plants operated by systems serving greater than 1 million

people (see Section 4.3.4 for discussion), resulting in a total of 329 systems. Exhibit 4–8 breaks

down this number of systems by size and type:

4.3.4 Systems Serving More Than 1 Million Persons

As discussed above, EPA determined the number of affected systems by analyzing water

systems’ treatment and recycling practices and, based on this analysis, estimating the percent of
FBRR Final RIA 4-14 April 2001

surface water systems potentially affected by the rule. The exception to this approach is EPA’s

analysis of systems serving more than 1 million. EPA used the schematic of ICR systems and

SDWIS to determine whether these systems would be affected by the recycle provisions. 

First, EPA reviewed the schematics of the individual plants within the 13 ICR systems that serve

more than 1 million persons. This review identified 24 plants, only seven of which would be

affected by the rule. Two plants (both serving 10,000 to 50,000 people) would have to move

their recycle return location, three plants (all serving 10,000 to 50,000 people) would be required

to meet conventional filtration reporting requirements, and four direct filtration plants (two

serving 50,001 to 100,000 people and two serving more than 100,000 people) would be required

to meet direct filtration reporting requirements. EPA included these individual plants in the cost

analysis.
FBRR Final RIA 5-1 April 2001 

5. Benefits Analysis

5.1 Introduction

The health benefits of a drinking water standard come from reducing the probability that

consumers will suffer health damages and other losses due to contaminants present in finished

water. For the Filter Backwash Recycling Rule (FBRR), benefits reflect reductions in the risks of

microbial illness. The benefits associated with the recycle provisions are summarized in Exhibit

5–1.

Exhibit 5–1. Overview of FBRR Benefit Categories and Associated Components

Health Benefits

Reduced mortality and morbidity

rates by changes to recycle

practices in small and large

surface water and GWUDI

treatment facilities

• Changing recycle practices is expected to generate positive

benefits by lowering the risk of contracting cryptosporidiosis from

drinking water. See Sections 5.2.1 and 5.2.2.

Non-Health Benefits

Reduced outbreak responses • Avoided costs to affected water systems and local governments

(provision of alternative water, issuing warnings and alerts, and

costs associated with negative publicity).

• Time spent on averting behavior during outbreaks (e.g.,

hauling/boiling water).

• See Section 5.2.3.

Costs to households to avert

infection

• Averting behavior is associated with both out-of-pocket costs

(e.g., purchase of bottled water) and opportunity costs (e.g., time

required to boil water) to the consumer. See Section 5.2.4.

EPA has not developed a national benefit estimate because the overall impact on finished water

quality of different treatment changes brought about by the provisions depends on a wide variety

of system operational parameters that cannot be easily modeled. In order to model the effect of

recycle practice, data regarding the ability of a wide range of unit processes (sedimentation,

dissolved-air flotation [DAF], contact clarification, filtration) to remove oocysts from a wide

variety of source water types, under a range of treatment conditions, is needed to calibrate the

model. These data are currently not extensive enough to model the impact of recycle on a wide

variety of treatment configurations.

However, data show that oocysts occur in recycle flows and in the finished water of

unchallenged, well-performing plants. Recycle adds additional oocysts to the plant and risks

reducing plant treatment efficiency during improperly conducted recycle events because of

hydraulic and chemical disruption. Research of the available literature demonstrates that

increased hydraulic loadings or disruptive hydraulic current, which may be experienced when

plants exceed State-approved operating capacity, can disrupt filter and sedimentation

performance. However, the literature does not quantify the extent to which performance can be
FBRR Final RIA 5-2 April 2001 

reduced and, more specifically, does not quantify the log reduction in Cryptosporidium removal

that may be experienced during direct recycle events. Section 5.2 discusses the risks associated

with the improper recycle of filter backwash and of exposure to waterborne pathogens such as

Cryptosporidium and Giardia lamblia. Section 5.3 discusses the health benefits of the rule. It

also reviews the approaches used by EPA to monetize health benefits associated with drinking

water regulations and describes how these benefits could apply to the FBRR, and Section 5.4

summarizes the discussion of benefits. As discussed in Chapter 8 of this document, EPA expects

that the health benefits associated with the FBRR, although impossible to accurately monetize at

this time, justify the costs associated with the rule. 

5.2 Risks Associated with the Improper Recycle of Filter Backwash

The FBRR recycle provisions apply to surface water and GWUDI drinking water systems that

recycle treatment process flows within the primary treatment process. EPA has identified three

primary public health concerns arising from the improper recycle of spent filter backwash,

thickener supernatant, and liquids from dewatering processes within the treatment process of

public water systems.

1. Data show that recycle flows can contain Cryptosporidium oocysts, often at higher

concentrations than plant source waters, and recycling these flows may increase the

number of oocysts entering the plant, reaching the filters, and entering the finished water. 

Since Cryptosporidium is not inactivated by standard disinfection practice, it is critical

that all available physical removal processes (coagulation, flocculation, clarification,

filtration) be protected from the hydraulic and chemical treatment disruptions recycle

events may cause. Recycle returns oocysts to the plant at precisely the time treatment

efficiency may be challenged by hydraulic and chemical disruption caused by improper

recycle practices. This may cause more oocysts to enter the finished water.

2. Returning spent filter backwash, thickener supernatant, or liquids from dewatering to a

location that does not precede processes of a system’s existing conventional or direct

filtration (as defined in Section, 141.2 of 40 CFR) may disrupt treatment chemistry by

introducing residual coagulant or other treatment chemicals to the process stream. If

recycle flows are improperly managed and returned directly into a sedimentation basin,

these flows may not reside in the basin long enough for recycled oocysts to settle.

Additionally, if these recycle flows are improperly managed they can create hydraulic

currents within the basin that reduce the unit’s overall oocyst removal efficiency. 

Additionally, improper recycle practices can cause large variations in influent flow, which

may reduce treatment efficiency if chemical doses are not adjusted appropriately. (Patania

et al., 1995; Edzwald and Kelley, 1998; Bellamy et al., 1993; Conley, 1965; Dugan et al.,

1999; Robeck et al., 1964).

3. The direct recycle of spent filter backwash without first providing treatment, equalization,

or some form of hydraulic detention for the flow, may cause plants to exceed Stateapproved operating capacity during recycle events. Exceeding operating capacity can

cause sedimentation/clarification and filter loading rates to be exceeded, which may lower
FBRR Final RIA 5-3 April 2001 

overall oocyst removal provided by the plant and increase finished water oocyst

concentrations. 

The FBRR is intended to reduce the risk of Cryptosporidium and other pathogens passing

through treatment into finished drinking water and reduce the risk of waterborne disease

outbreaks. The four stages associated with a waterborne outbreak that may impose costs on

society are discovery, survey and testing, reaction, and aftermath (Harrington et al., 1985):

1. Discovery. Health care providers or State, local, or hospital laboratory technicians

send reports to State authorities notifying them of the need for further investigation

when the rate of new cases suddenly increases above the normal rate.

2. Survey and testing. A host of epidemiological surveys may be conducted, along

with tests of the water supply, once a few cases are confirmed.

3. Reaction. Local authorities and the water system may issue boil-water advisories, or

other warnings to reduce exposure, once a link is made between the drinking water

supply and the disease outbreak. Businesses, as well as households, may be affected

by such action, requiring government agencies to begin surveillance and enforcement

activities and in some cases, provide alternative water sources.

4. Aftermath. This final stage involves discussions of any long-term solutions to the

problem, and how the costs of the outbreak and prevention of future ones may be

shared. These discussions can only take place once the outbreak is contained by

actions taken during the previous phase.

The reductions in the risk of waterborne disease outbreaks and in the expenditures that are

avoided as a result of outbreak prevention are benefits of the FBRR. These benefits are

discussed in the following sections.

5.2.1 Reduction in Cryptosporidium

Health Risks Associated with Cryptosporidium

Cryptosporidium and other pathogens have been identified as the cause of waterborne disease

outbreaks (Centers for Disease Control, 1996). In particular, drinking water supplies

contaminated with Cryptosporidium pose a health risk to the public because the pathogen is

highly infectious, resistant to inactivation by chlorine, widespread among many animal species,

and small in size and consequently difficult to filter (Guerrant, 1997). This benefits analysis

discusses the potential benefits of reducing human exposure to Cryptosporidium in drinking

water supplies through improved operation and performance of the drinking water recycling

process. Other benefits from the rule include reduced exposure to Giardia lamblia and other

emerging pathogens in drinking water.

As discussed in Chapter 2, Cryptosporidium in surface water sources is relatively common. 

Cryptosporidium oocysts can cause cryptosporidiosis, an acute, self-limiting illness lasting 7 to
FBRR Final RIA 5-4 April 2001 

14 days. Its symptoms include diarrhea, abdominal cramping, nausea, vomiting, and fever

(Juranek, 1995). There is no effective treatment for cryptosporidiosis (Guerrant, 1997). 

Several subpopulations are especially sensitive to cryptosporidiosis. They include young,

elderly, malnourished, disease impaired persons (especially those with diabetes), and a broad

group whose immune systems are compromised (Rose, 1997). This last group includes persons

with AIDS, Lupus, or cystic fibrosis; transplant recipients; and persons undergoing chemotherapy

(Rose, 1997). Symptoms in the immunocompromised subpopulations are much more severe than

those in other groups (Juranek, 1995). Mortality is a substantial threat to the

immunocompromised infected with Cryptosporidium:

“The duration and severity of the disease are significant: whereas 1 percent of

the immunocompetent population may be hospitalized with very little risk of

mortality (< 0.001), Cryptosporidium infections are associated with a high rate

of mortality in the immunocompromised (50 percent)” (Rose, 1997).

Waterborne disease outbreak data from the Centers for Disease Control and Prevention (CDC)

for the period 1993–1994 estimates that Cryptosporidium was responsible for over 400,000 cases

of gastrointestinal infection (Craun et al., 1998). The vast majority of these cases occurred in a

single outbreak in Milwaukee, Wisconsin, the largest recorded outbreak of waterborne disease in

the United States. CDC estimated that of the approximately 800,000 persons served by the water

system, over 400,000 (50 percent) became ill (Exhibit 5–2). Of those, 4,000 required

hospitalization (approximately 1 percent of those who become ill), and at least 50

immunocompromised individuals died from causes related to cryptosporidiosis (as reported on

death certificates) (Mackenzie et al., 1994; Hoxie et al., 1997). Exhibit 5–2 contains detailed

information on some of the symptoms of patients with cryptosporidiosis observed during the

Milwaukee outbreak.

Exhibit 5–2. Symptoms of 205 Patients with Confirmed Cases of

Cryptosporidiosis during the Milwaukee Outbreak

Symptom Percent of Patients Mean Range

Diarrhea 93 Duration: 12 days 1–55 days

Abdominal Cramps 84 N/A N/A

Weight Loss 75 10 pounds 1–40 pounds

Fever 57 100.9LF 99.0L–104.9LF

Vomiting 48 N/A N/A

Source: Mackenzie et al., 1994.

The Milwaukee outbreak represents the largest number of cases in a single cryptosporidiosis

outbreak in the United States, but most cryptosporidiosis outbreaks have occurred in small

systems serving fewer than 10,000 persons (Exhibit 2–5). Between 1991 and 1996, sixteen

outbreaks caused by either Cryptosporidium or Giardia lamblia in small water systems resulted

in 1,036 reported cases of cryptosporidiosis and 518 reported cases of giardiasis. Two of the 16

outbreaks were associated with Cryptosporidium in small surface-water systems, and four

Cryptosporidium outbreaks occurred in ground water assumed to be under the direct influence of
FBRR Final RIA 5-5 April 2001 

surface water. During small system Cryptosporidium outbreaks, between 28 and 80 percent of

the exposed population can become ill (U.S. EPA, 2001a).

Outbreak data represent only a portion of the incidence of cryptosporidiosis. Only numerous

cases of cryptosporidiosis concentrated in a specific location have a chance of being detected and

reported. Isolated cases (endemic) are much less likely to be reported. Many, perhaps most,

infected individuals may not seek medical treatment for their symptoms, so primary care

physicians may not be able to isolate Cryptosporidium as the cause of the illness. Even if

cryptosporidiosis is diagnosed, physicians may not make a report to the CDC. These

compounded impacts could lead to gross under-reporting and under-estimating of

cryptosporidiosis cases (Okun et al., 1997).

How the FBRR Addresses Risks Associated with Cryptosporidium

Cryptosporidium is exceptionally resistant to inactivation by chlorine, so physical removal by

clarification and filtration is extremely important to control this organism. Over time, these

pathogens accumulate with other particles in the treatment plant filters. During backwash events

to clear filters and maintain performance, plants run a higher risk of pathogens reaching the

finished water if recycle is performed improperly. The FBRR has three recycle provisions

designed to help prevent Cryptosporidium from reaching the finished water supply. They are

based on the assumption that improving practices will prevent the accumulation of

Cryptosporidium within the treatment plant and minimize the risk of oocysts entering into the

finished water. The provisions are as follows: 

1. First, the rule requires (with some exceptions) that recycle be returned through the

processes of a system’s existing conventional or direct filtration (as defined in

Section, 141.2 of 40 CFR). The rule includes a provision allowing States to approve

alternate recycling locations for systems on a case-by-case basis.

2. Second, plants that practice conventional filtration must report their recycle practices

to the State in writing. When notifying the State, systems must provide a plant

schematic showing the origin of all recycle flows, the hydraulic conveyance used to

transport them and the location where they are recycled back into the plant. In

addition, systems must also provide typical recycle flow in gallons per minute (gpm),

highest observed plant flow experienced in the previous year (gpm), design flow for

the treatment plant (gpm), and if applicable, the State-approved operating capacity

for the plant.

3. Third, direct filtration plants must report their recycle practices to the State, including

a plant schematic showing the origin of all recycle flows, the hydraulic conveyance

used to transport them and the location where they are recycled back into the plant. 

Direct filtration plants must also report typical recycle flow (gpm), highest observed

plant flow experienced in the previous year (gpm), design flow for the treatment

plant (gpm), and if applicable, the State-approved operating capacity for the plant.

5.2.2 Reduction of Other Pathogens
FBRR Final RIA 5-6 April 2001 

The FBRR is intended to decrease the risk that improper recycle practices will allow

Cryptosporidium oocysts to pass through the treatment plant and into the finished water. 

However, EPA expects that the FBRR will also reduce the risk that other microbial pathogens

such as Giardia lamblia will pass through the treatment plant and into the finished water due to

improper recycle practices, since Giardia has been identified in backwash water. For example, a

study of 25 water treatment plants (Arora et al., 1999) found levels of Giardia and

Cryptosporidium to be 16 and 21 times higher, respectively, in spent filter backwash water than

in raw water. The researchers concluded that, based on the observed levels of Giardia and

Cryptosporidium, a recycle ratio of 5 to 10 percent should be sufficient to minimize the impact of

the protozoa on raw water levels.

Cornwell and Lee (1993) found that Cryptosporidium and Giardia can be present in spent filter

backwash water. One plant in their study had more than 150 cysts/L in its spent filter backwash

water, compared to 0.2 to 3 cysts/L in its raw water. They also found that sedimentation was

effective in reducing cysts prior to recycle.

The changes in recycle practices that result from this rule also may reduce the risk from other

disinfection-resistant pathogens, such as Toxoplasma, microsporidia, and Cyclospora, that may

be found in source water and so in filter backwash. Data from the Information Collection Rule

(ICR) Initial Sampling database, which mainly consists of large water treatment plants, found

that 90 percent of them (226 facilities) had a recycle stream that could contain such organisms

(Hamele and Bonner, 1998).

As indicated previously, limited work has shown that when recycle is performed in accordance

with the requirements of the FBRR, Cryptosporidium removal is not impaired. 

5.2.3 Reduction in Outbreak Risk

Besides reducing the endemic risk of cryptosporidiosis, the FBRR will reduce the likelihood of

major outbreaks, such as the Milwaukee outbreak. The economic value of reducing the risk of

outbreaks could be quite high when the magnitude of potential costs associated with illnesses is

considered. Other types of costs associated with outbreaks include spending by local, State, and

national public health agencies; emergency corrective actions by utilities; and possible legal

costs, if liability is a factor. Affected water systems and local governments may incur costs to

provide alternative water supplies and issue customer water use warnings and health alerts. 

Commercial establishments (e.g., restaurants) and their customers may incur costs due to

interrupted and lost service (e.g., lost producer and consumer surplus). To the extent that FBRR

reduces the likelihood of waterborne disease outbreaks, avoided response costs are potentially

significant.

5.2.4 Costs to Households to Avert Infection

Local businesses, institutions, and households may incur costs associated with undertaking

averting and defensive actions. During outbreaks or periods of high turbidity, consumers and

businesses may use alternative water sources or practice behaviors to reduce risk, such as boiling

water. If the rule reduces the need for these averting behaviors, an economic benefit will accrue. 
FBRR Final RIA 5-7 April 2001 

During an outbreak of giardiasis, expenditures on averting behaviors, such as hauling in safe

water, boiling water, and purchasing bottled water, were estimated at between $1.74 and $5.53

per person per day during the outbreak (Harrington et al., 1989). If these figures are applied to a

small drinking water system serving 10,000 customers, daily expenditures on averting behavior

during a Cryptosporidium outbreak could total between $17,400 and $55,300. Determining the

precise reduction in outbreak risk and resulting benefits due to reduced or avoided averting

behavior is not possible given current information, but potential benefits are expected to be

substantial.

Five additional studies were identified that used the averting cost approach to estimate household

and other costs attributable to short-term contamination of drinking water supplies (Abdalla,

1990; Abdalla et al., 1992; Harrington et al., 1985; Sun et al., 1992; Van Houtven, et al., 1997). 

The most relevant of these for the FBRR analysis is a study by Harrington et al., (1985), that

analyzes the costs associated with drinking water contamination by Giardia in Luzerne County,

Pennsylvania. The December 1983 outbreak resulted in 366 confirmed giardiasis cases resulting

from sewage leaking into the unfiltered source water. The total affected population was 75,000

individuals across Pittston Burough and 17 other municipalities. The Harrington study also

developed a theoretical and empirical example of how outbreak costs are incurred, based on the

Luzerne County example.

The Luzerne County outbreak resulted in estimated losses, due to actions taken by individuals to

avoid the contaminated water, of between $20.8 million and $61.8 million. The predominant

cost was time lost to boiling water. Estimated losses due to averting actions for restaurants, bars,

schools and other businesses during the outbreak averaged $1.0 million. The burden for

government agencies was $230,000 and the outbreak cost the water supply utility $1.8 million. 

These costs do not include legal fees, outbreak effects on businesses that were not investigated,

leisure activities, or net losses due to substituting more expensive beverages for tap water.

5.3 Health Benefits from Recycle Provisions

This section describes the health benefits associated with the FBRR and discusses approaches for

monetizing these benefits. Although available data limits EPA’s ability to accurately monetize

the health benefits associated with FBRR, the information provided in this section provides the

basis for EPA’s assumption that the rule provides significant health-related benefits. 
FBRR Final RIA 5-8 April 2001 

Benefits Associated with Reduced Exposure to Cryptosporidium

Reducing the risk of exposure to Cryptosporidium, Giardia, and other pathogens is a benefit of

the FBRR. Often, the value of such a benefit (risk reduction) is estimated to be the health

damages (medical cost and lost productivity) that will be avoided—referred to as “cost-ofillness” (COI). COI measures, however, are thought to understate total benefits because they do

not capture the full value that consumers place on reducing risk and avoiding illness. 

COI avoided due to adverse health effects includes medical costs, lost income, reduced

productivity, and averting expenditures. These goods have observable market values and are,

therefore, easier to quantify than willingness-to-pay (WTP) values.

The WTP concept goes beyond the expected value of avoided COI to include the total value of

health benefits. In principle, WTP is a comprehensive measure of the welfare effect of a change

in risk and is expected to exceed the out-of-pocket financial effect of the change (Chestnut and

Alberini, 1997). WTP includes the intuitive notion that illness is disagreeable and that one

would be willing to pay to avoid the pain and suffering associated with an adverse health effect

beyond the cost of the illness. Since there are no markets for avoided pain and suffering, there

are no observable market transactions by which their value can be measured.

Another reason that WTP for reduced health risk is likely to exceed the expected value of

avoided COI is the general acceptance of additional costs to avoid risk. WTP values for

avoidance of premature death include the value of reductions in the risk of out-of-pocket costs

(i.e., COI) plus the value of reduced risk of the lost enjoyment of life (Chestnut and Alberini,

1997). The use of expected COI, instead of WTP, tends to understate the economic value of risk

reduction because COI does not incorporate nonpecuniary benefits such as avoided pain and

suffering.

Monetizing Illness

Information is not available on direct measurements of either COI or WTP to reduce risk

specifically for Cryptosporidium. 

These results can be compared against previous studies. Mauskopf and French (1991) estimated

WTP to avoid food-borne illnesses based on the nature and length of the illness, integrated with

the value of a statistical life and indices of self-reported health status to value the losses in quality

and length of life. The WTP estimates (1999$) for illnesses similar to cryptosporidiosis range

from $166 to $7,424 for mild to moderate cases of botulism (5 to 21 days of weakness, vomiting,

and nausea) and $284 to $1,139 for salmonellosis (3 to 7 days of similar symptoms). Using these

estimates, the value for cryptosporidiosis (7 to 14 day duration) could range from $233

($33.25/day for 7 days) to $4,942 ($353/day for 14 days). The cost of illness estimates (with a

mean of $2,403) fall within this range and are a reasonable approximation of the value to avoid

health damages associated with cryptosporidiosis, recognizing that some costs (such as averting

expenditures, and pain and suffering) have not been monetized.

Monetizing Mortality
FBRR Final RIA 5-9 April 2001 

A recent EPA study characterized a range of credible estimates of the VSL saved as a Weibull

distribution with a mean of $4.8 million and a standard deviation of $3.24 million, capped at

$13.5 million (in 1990$), based on 26 individual study estimates (62 FR 59485; November 3,

1997). Updating the VSL to 1999 price levels results in a distribution with a mean of $6.3

million.

Because cryptosporidiosis mortalities are expected to occur primarily in sensitive subpopulations,

there may be some arguments for adjusting the VSL. The typical valuation methodology used to

derive the VSL generally measures the individuals’ WTP to reduce the risk of a premature death

by a small amount. The small reduction in risk is then spread across a broad population. The

mortality risk associated with cryptosporidiosis is different because a smaller sensitive

subpopulation faces a higher baseline risk. 

Monetizing Health Effects to Sensitive Subpopulations

As noted in Section 5.2, the health effects of Cryptosporidium on sensitive subpopulations are

much more severe and debilitating than the health effects on the general public. The estimated

COI avoided calculated above likely does not capture the total costs to sensitive subpopulations;

health trials were conducted only with healthy individuals, and symptomatic responses are more

severe in sensitive populations. For example, the duration of cryptosporidiosis in persons whose 

immune systems are compromised is considerably longer than in those with competent immune

systems, and the more severe symptoms suffered by immunocompromised individuals often

require lengthy hospital stays.

COI from cryptosporidiosis for sensitive subpopulations is expected to be much greater than the

COI for the general population. During the Milwaukee outbreak, 33 AIDS patients with

cryptosporidiosis accounted for 400 hospital days at an additional cost of nearly $760,000 (Rose,

1997). COI due to these hospital days alone was estimated at $23,000 per case ($760,000/33

patients). Although the COI for sensitive populations is expected to be greater than the general

population, no attempt was made to quantify these effects for this regulatory impact analysis. 

Also, the cost of averting expenditures could be higher in sensitive subpopulations. Sensitive

subpopulations are more susceptible to Cryptosporidium infections, thus these individuals may

purchase bottled water, boil water, or take other health precautions on a daily basis.

Monetizing Risk Reduction from Emerging Pathogens

EPA is unable to quantify the benefit associated with a reduction in risk from exposure to

emerging pathogens due to current data limitations.
FBRR Final RIA 5-10 April 2001 

5.4 Summary

EPA expects that there will be a variety of positive benefits associated with the FBRR. In

summary, benefits associated with changes to recycle practices are expected to include the

following:

` Reducing mortality and morbidity rates, in the general population and among sensitive

subpopulations, by reducing the risk of Cryptosporidium, Giardia, and other pathogens

passing through the treatment plant into finished drinking water. 

` Avoided outbreak response costs, including:

• Avoided costs to affected water systems and local governments (provision of

alternative water, issuing warnings and alerts, and costs associated with negative

publicity).

• Avoided costs to households to avert illness.

As discussed in Chapter 8 of this document, EPA expects that the health benefits associated with

the FBRR, although impossible to accurately monetize at this time, justify the costs associated

with the rule. 
1

Throughout the cost analysis, the term “State” refers to the 56 States, Commonwealths, Territories, and the District of Columbia that

are eligible for primary enforcement authority or primacy. This definition is consistent with the assumption used for the cost analysis in the final

IESWTR RIA. Currently, however, Wyoming and the District of Columbia do not have primacy; EPA regional offices administer their drinking

water programs. Indian Tribes are also eligible for primacy, although none have yet obtained it and EPA regional offices also administer drinking

water programs for Tribal lands.

2

This analysis of costs is limited to compliance cost estimates.The analysis assumes that drinking water systems pass incremental

costs on to consumers in the form of higher water prices and there are no savings from system consolidation or adverse impacts such as system

closure.

FBRR Final RIA 6-1 April 2001

6. Cost Analysis

6.1 Introduction

This chapter reports national cost estimates for the Filter Backwash Recycling Rule (FBRR) and

discusses the methods EPA used to estimate implementation costs incurred by drinking water

systems and States.1

 EPA anticipates that water system compliance with the FBRR provisions

will increase reporting burdens and, in some cases, require changes to treatment processes and

plant operations. EPA also expects the rule to increase the labor requirements for additional

compliance tracking activities for States. Consequently, the cost analysis includes labor costs

associated with additional reporting and compliance requirements, as well as capital and

operating and maintenance (O&M) expenditures associated with changes in water treatment

processes.2

Chapter 6 contains the following sections:

• Section 6.2 - provides detailed cost information for each component included in the

quantitative analysis. It includes the cost assumptions and data

elements used in the analysis, descriptions of how the costs were

estimated, and reports of the results. Additional documentation for the

cost estimates in this chapter are in the appendices.

• Section 6.3 - summarizes total national costs for the provisions of the final FBRR. 

This section also includes a discussion of the impact of potential

biases, omissions, and uncertainties on the national cost estimate. 

• Section 6.4 - discusses how system-level costs were translated into annual cost

increases per household.

• Section 6.5 - compares costs associated with the final FBRR with the costs of the

proposed alternative presented in Chapter 3.

6.1.1 Cost Assumptions

EPA estimated costs at the water system- and State-level, then multiplied these costs by the

number of affected entities to obtain total costs. EPA relied on existing data sources and input

from stakeholders to identify potential treatment process improvements, estimate their cost, and

estimate the labor burden associated with the reporting requirements. These costs were based on

industry cost models, equipment prices, wage rates from standard engineering sources, and
FBRR Final RIA 6-2 April 2001

stakeholder inputs. System costs were estimated for several different service population size

categories to account for cost differences attributable to system size. Chapter 4 discusses the

assumptions that EPA used to estimate the number of systems affected by the FBRR. This

section summarizes additional assumptions that were used to estimate costs.

• Total and annual costs. The RIA presents costs on a total and annual basis. All onetime costs such as investments in capital equipment or training were annualized

before they were added to annual O&M expenditures. Capital costs for most process

improvements were annualized over a 20-year period to reflect a typical capital

investment lifetime. Two results are reported because EPA used two different

discount rates that have been recommended for policy analysis: a 3 percent rate,

which is in the range recommended in EPA’s publication, Guidelines for Preparing

Economic Analyses (U.S. EPA, 1999b) and a 7 percent rate, which is recommended

by OMB guidance (OMB, 1993 and 1996). Start-up labor costs were also annualized

over 20 years to obtain equivalent annual values.

• Unit costs for process improvements. The set of feasible process improvements was

limited. To develop a list of potential treatment changes, EPA relied on information

provided in stakeholder and SBREFA meetings, best professional judgment, the

schematics of Information Collection Rule (ICR) systems, and the AWWA survey

(1998) of recycling practices, which collectively indicated the current range of

recycling techniques. Appendix H, Costs and Technologies for the FBRR, explains

how EPA estimated the unit costs associated with treatment modifications.

• Costs associated with noncommunity water systems. System-level cost estimates for

all recycle modifications are described in detail in Appendix H. Capital and O&M

costs are functions of system flow rates, which were obtained from the Community

Water System Survey database. Consequently, these costs are more representative of

costs for community water systems, but EPA used the same flows for noncommunity

systems as well, because of a lack of data concerning the flow capacities and

technologies employed by these systems. Because noncommunity systems may have

smaller flows than community systems, this assumption may overestimate costs for

noncommunity systems.

• Systems with multiple treatment plants. As described in Appendix H, unit capital

and O&M costs were estimated using engineering models and system-level flow

rates. Using these unit costs to develop cost estimates for large systems introduced

some uncertainty because total system flows at large systems—especially systems

serving more than 100,000—may be treated by two or more plants, some of which

may not recycle flow to the treatment process. Consequently, EPA potentially

overestimated compliance costs for large systems that do not need to change recycle

practices at all of their plants. Conversely, EPA may have underestimated

compliance costs for large systems that need to change recycle practices for all of

their plants. This underestimation is possible because installing new equipment at

two or more plants with smaller flow rates may cost more than the estimated unit
3

 The exception to this approach is EPA’s analysis of systems serving more than 1 million people. EPA used the schematics of ICR

systems and SDWIS to determine whether these systems would be affected by the recycle provisions. First, EPA identified 13 systems in

SDWIS that serve populations greater than 1 million. Then EPA identified schematics of the individual plants within these systems. Of the 24

plants identified, only 7 would be affected by the rule. Two plants (both serving 10,000 to 50,000) would have to move their recycle return

location. One conventional filtration plant (serving 10,000 to 50,000) and and 4 direct filtration plants (two serving 50,000 to 100,000 and 2

serving more than 100,000) would be required to report their recycle practices to the State. EPA included these individual plants in the cost

analysis.

FBRR Final RIA 6-3 April 2001

cost of installing equipment at a single large plant that handles the same flow rate. 

Although these biases will tend to offset one another, EPA cannot determine whether

total costs are more likely to be over or underestimated because it does not have

details about the plant configurations of all large plants that recycle.3

• Hourly labor rates. EPA’s labor cost estimates incorporate assumptions about

incremental system and State labor hours and hourly labor rates for managerial and

technical labor categories. The Agency proposed the FBRR in early 2000 using labor

rate recommendations of a Technical Design Panel of industry engineers which met

in Denver for two days in the fall of 1997. Additional analysis as recommended by

the panel has yielded updated labor rates which were used in developing costs for the

final FBRR. EPA has included these analyses in the docket for the final rule (EPA,

2001). The loaded technical labor rate for systems serving 9,999 or fewer people is

$14.50 per hour, and the rate for systems serving 10,000 or more is $28.00 per hour. 

EPA assumed that systems serving 1,000 or more also have a management labor

category, which has a loaded labor rate of $40.00 per hour. The loaded hourly rate

for State technical staff is $21.29 and the loaded rate for State managerial staff is

$31.23.
FBRR Final RIA 6-4 April 2001

6.2 FBRR Cost Analysis

The FBRR applies to surface water or GWUDI systems that employ either conventional or direct

filtration and recycle spent filter backwash, sludge thickener supernatent, or liquids from

dewatering processes. Exhibit 6–1 summarizes the number of systems potentially affected by

system type and population size category.

Exhibit 6–1. Number of Systems Potentially Affected by the 

Rule’s Recycling Provisions

Type of System Affected by a Provision

System Population Size Category

Small Systems

<10,000

Large Systems

A10,0001 Total

Total conventional and direct filtration systems

that recycle (see Exhibit 4-5) 3,490 1,160 4,650

Systems affected by the recycle return location

provision (see Exhibit 4-6) 349 117 466

Systems affected by conventional filtration

reporting requirements (see Exhibit 4-7) 3,246 1,075 4,321

Systems affected by direct filtration reporting

requirements (see Exhibit 4-8) 244 85 329

1

Totals include systems that serve more than 1 million people, which were analyzed on a case-by-case basis. Seven

of these systems are affected by the rule. Of those, two are affected by the recycle return location provision, four are

impacted by the conventional filtration reporting requirements, and three are impacted by the direct filtration

reporting requirements. 

6.2.1 Startup Costs

System Startup Costs

EPA assumed that systems will incur start-up costs for reading and understanding the rule as well

as mobilization and planning for rule implementation. Exhibit 6-2 summarizes system startup

costs.
FBRR Final RIA 6-5 April 2001

Exhibit 6–2. Total Annualized System Startup Costs for FBRR 

(January 1999 dollars)

Compliance Activity Number of

Systems

Annual Cost

(3%)

Annual Cost

(7%)

Read and Understand the Rule

4,650 $48,860 $68,609

Mobilization and Planning $97,720 $137,218

Total Annual Cost 4,650 $146,580 $205,827

State Startup Costs

State start-up activities are classified in two categories, regulatory adoption/program

development and miscellaneous training. EPA estimated that these activities will require an

average of 260 hours per State. Exhibit 6-3 summarizes these start-up costs.

Exhibit 6–3. Total Annualized State Startup Costs for FBRR 

(January 1999 dollars)

Compliance Activity Number of

States Annual Cost (3%) Annual Cost (7%)

Regulatory Adoption/Program

Development 56

$17,528 $24,613

Miscellaneous Training $5,258 $7,383

Total Annual Cost 56 $22,786 $31,996

6.2.2 Recycle to New Return Location

Generally, conventional and direct filtration systems that do not return select recycle flows

through the processes of a system’s existing treatment system, as defined in 40 CFR, Section

141.2, will be required to move the return point to such a location. As noted in Exhibit 6–1, an

estimated 466 systems will be affected by this provision. EPA based this estimate on

information provided by a sample of large and small systems that responded to a 1998 AWWA

survey on recycle practices (AWWA, 1998) and plant schematics gathered under the Information

Collection Rule (61 FR 24354; May 14, 1996). 

Systems that must move their recycle return location will need to install additional pipe and may

need to install additional pump capacity to recycle to the new location. Additional energy will be

required to pump water the extra distance, which increases annual operating costs. Thus, EPA

also estimated capital and O&M expenditures associated with these changes in recycling

practices.

The rule allows water systems to request State approval for use of an alternative recycle location. 

States will review the requests and decide whether to approve them on a case-by-case basis. 
4

Appendices A-2 and A-3 summarize the capital and O&M costs per system for conventional and direct

filtration systems that need to redirect their recycle flows. Appendix F discusses how these costs were derived.

FBRR Final RIA 6-6 April 2001

Based on its review of data from the AWWA Survey (1998), EPA estimates that 20 percent of

affected systems will obtain State approval to use an alternate location. 

Reporting Costs

EPA assumed that systems will incur reporting costs to request an alternate recycle location,

meet with the State, and maintain records. The system-level burden across these activities totals

21 hours. Exhibit 6–4 summarizes total costs by system size category. Total cost is $38,071, and

annualized cost is approximately $2,559, assuming a 3 percent discount rate and $3,594 using a 7

percent discount rate.

Exhibit 6–4. Total Annualized System Costs for Requesting an Alternate

Recycle Return Location by System Size (January 1999 dollars) 1

System Size

Number of

Affected

Systems

Cost Per System Total Cost

@ 1,000 33 $305 $9,979

1,001–3,300 19 $361 $6,983

3,301–9,999 18 $361 $6,394

A 10,000 2 23 $638 $14,715

Total 93 N/A $38,071

Annualized Cost (3%)

Annualized Cost (7%)

$2,559

$3,594

1 See Appendices E–1a through E–1c for detail.

System Capital and O&M Costs

To obtain total capital and O&M costs for this provision, unit costs were first multiplied by the

373 systems EPA assumed would move their recycle return location.4 Capital costs were then

annualized over a 20-year period, assuming a 3 percent and a 7 percent discount rate. EPA added

1 year of O&M expenditures to annualized capital costs to obtain total annualized capital and

O&M costs. Appendices B and C provide detailed cost estimates by system size category and

Exhibit 6–5 summarizes capital and O&M costs. The total capital and O&M cost of this

provision is $5.5 million, assuming a 3 percent discount rate and $6.8 million using a 7 percent

discount rate.
FBRR Final RIA 6-7 April 2001

Exhibit 6–5. Total Annualized Capital and O&M Costs for New Recycling Return

Location by System Size (January 1999 dollars)1

System Size

Category

Number of

Affected

Systems

Total Cost at

3% Discount Rate

Total Cost at

7% Discount Rate

@ 1,000 131 $289,045 $330,112

1,001–3,300 77 $249,529 $287,884

3,301–9,999 71 $380,148 $442,231

A 10,0002 94 $4,606,754 $5,693,849

Total3 373 $5,525,475 $6,754,076

1 See Appendices B–3 and C–3 for detail.

2 Total cost includes expected modification costs (i.e., probability of modification multiplied by unit cost) for two

plants that belong to systems serving 1 million or more.

3

Detail may not add to total due to independent rounding.

Review Costs

States will also need to review the requests submitted by systems, and meet with systems to

discuss recycling changes. These State activities will require about 13 hours per system. Total

costs for all State activities, which are summarized in Exhibit 6–6, are approximately $28,104 for

this rule provision. The annualized costs are $1,889, assuming a 3 percent discount rate and

$2,653 using a 7 percent discount rate.

Exhibit 6–6. State Cost Estimate to Review and Approve Plans to

Move Recycle Return Location (January 1999 dollars) 1

Compliance Activities Number of

Reviews

Cost Per

Review Total Cost

State Plan Review Cost 93 (1 per system) $303 $28,104

Annualized Cost (3%)

Annualized Cost (7%)

$1,889

$2,653 1

 See Appendices E–1a, E–1b, and E–1d for detail.
FBRR Final RIA 6-8 April 2001

6.2.3 Conventional Filtration Recycle Reporting Costs

EPA developed a provision to address the risks posed by recycle practices of conventional

filtration systems. Costs for this provision include only a reporting component.

System Reporting Costs

A system will need to prepare a recycle report only if it satisfies all of the following criteria:

• The system uses surface water or GWUDI as a source; 

• Employs conventional filtration treatment; and

• The system recycles spent filter backwash, sludge thickener supernatant, or liquids

from dewatering processes.

The rule requires that each affected system notify the State in writing that they practice recycle. 

When notifying the State, systems must also provide the following information:

• A plant schematic showing the origin of all recycle flows, the hydraulic conveyance

used to transport them, and the location where they are recycled back into the plant;

and

• Typical recycle flow in gallons per minute (gpm), highest observed plant flow

experienced in the previous year (gpm), design flow for the treatment plant (gpm),

and if applicable, the State-approved operating capacity for the plant.

Additionally, systems must collect and maintain the following information for review by

the State:

• Copy of the recycle notification and information submitted to the State; 

• List of all recycle flows and the frequency with which they are returned;

• Average and maximum backwash flow rate through the filters and the average and

maximum duration of the filter backwash process in minutes;

• Typical filter run length and a written summary of how filter run length is

determined;

• The type of treatment provided for the recycle flow; and

• Data on the physical dimensions of the equalization and/or treatment units, typical

and maximum hydraulic loading rates, type of treatment chemicals used and average

dose and frequency of use, and frequency at which solids are removed, if applicable. 

EPA estimated that the reporting and recordkeeping activities will require 15 hours. This

consists of 6 hours to report recycle status and plant information to the State, 8 hours to collect

additional recycle data, and 1 hour for recordkeeping. Costs per system range from $102 to $222

and vary with system size because the labor rate assumptions and labor mix between operator

and manager, as well as the burden assumptions, differ by system size.
FBRR Final RIA 6-9 April 2001

Exhibit 6–7 summarizes total conventional filtration reporting provision cost estimates by system

size category, combining the three smallest categories in one entry and all of the large systems in

another. The total cost is estimated at approximately $1.27 million. Annualized cost for the

provision is $85,092, assuming a 3 percent discount rate and $119,486 using a 7 percent discount

rate.

Exhibit 6–7. Total System Reporting and Recordkeeping Costs by System Size

for the Conventional Filtration Recycle Reporting Provision

(January 1999 dollars)1

System Size Category Number of 

Affected Systems Cost

@ 1,000 1,524 $331,445

1,001–3,300 899 $231,940

3,301–9,999 823 $212,384

A 10,000 2 1,075 $490,108

Total3 4,321 $1,265,877

Annualized Cost (3%)

Annualized Cost (7%)

$85,092

$119,486

1

 See Appendices E–2a through E–2c for detail.

2

 The cost estimates include four plants belonging to systems that serve more than 1 million.

3 Detail may not add to total due to independent rounding.

State Review Costs

State activities include reviewing reports and recordkeeping. EPA estimates that this represents

an incremental increase to States’ burden for sanitary surveys. The estimated State burden is 6

hours per system.

Exhibit 6–8 summarizes State costs. The total cost is estimated at $620,342. The annualized

cost for the States is $41,699, assuming a 3 percent discount rate and $58,554 using a 7 percent

discount rate.

Exhibit 6–8. Total State Review Costs for the Conventional Filtration Recycle

Report Provision (January 1999 dollars)1

Compliance Activities Cost

Review and Follow-up Costs $603,297

Recordkeeping $16,766

Total Cost 2 $620,342

Annualized Cost (3%)

Annualized Cost (7%)

$41,699

$58,554

1 See Appendices E–2a, E–2b, and E–2d for detail.

2 Detail may not add to total due to independent rounding.
FBRR Final RIA 6-10 April 2001

6.2.4 Direct Filtration Recycle Reporting Costs

EPA estimated that direct filtration plants account for approximately 7 percent of all systems that

use conventional or direct filtration (i.e., 329 systems). Because these plants do not have

sedimentation basins in their main treatment train, recycling can lead to higher concentrations of

Cryptosporidium oocysts in the system compared to conventional filtration systems, unless

recycle streams are treated to remove oocysts. This rule provision requires that all direct

filtration systems report their recycling practices to their State.

System Start-up and Reporting Costs

The provision requires that each affected system notify the State in writing that they practice

recycle. When notifying the State, systems must also provide the following information:

• A plant schematic showing the origin of all recycle flows, the hydraulic conveyance

used to transport them, and the location where they are recycled back into the plant;

and

• Typical recycle flow in gallons per minute (gpm), highest observed plant flow

experienced in the previous year (gpm), design flow for the treatment plant (gpm),

and if applicable, the State-approved operating capacity for the plant.

Additionally, systems must collect and maintain the following information for review by

the State:

• Copy of the recycle notification and information submitted to the State; 

• List of all recycle flows and the frequency with which they are returned;

• Average and maximum backwash flow rate through the filters and the average and

maximum duration of the filter backwash process in minutes;

• Typical filter run length and a written summary of how filter run length is

determined;

• The type of treatment provided for the recycle flow; and

• Data on the physical dimensions of the equalization and/or treatment units, typical

and maximum hydraulic loading rates, type of treatment chemicals used and average

dose and frequency of use, and frequency at which solids are removed, if applicable.

It is estimated that these reporting and recordkeeping activities will require a total of 15 hours per

system. 

Exhibit 6–9 reports total costs and annualized costs for system start-up and reporting activities by

system size category. Total costs for the provision are estimated at $97,002, resulting in

annualized costs of $6,520, assuming a 3 percent discount rate and $9,156 using a 7 percent

discount rate.
FBRR Final RIA 6-11 April 2001

Exhibit 6–9. Total System Reporting Costs for the Direct Filtration Recycle

Reporting Provision by System Size (January 1999 dollars)1

System Size Category Number of 

Affected Systems Total Cost

@ 1,000 115 $24,947

1,001–3,300 68 $17,458

3,301–9,999 62 $15,986

A 10,000 2 85 $38,611

Total Cost 329 $97,002

Annualized Cost (3%)

Annualized Cost (7%)

$6,520

$9,156

1

 See Appendices E–3a through E–3c for detail.

2

 Costs include three plants that belong to systems serving more than 1 million.

State Review Cost

EPA assumed that States will spend 4 hours reviewing a system’s report and incur a

recordkeeping burden of 2 hours. Total cost for all States is estimated at $47,234 resulting in an

annualized cost of $3,175, assuming a 3 percent discount rate and $4,458 using a 7 percent

discount rate(Exhibit 6–10).

Exhibit 6–10. Total State Review Costs for the Direct Filtration Recycle

Reporting Provision (January 1999 dollars)1

Compliance Activities Total Cost

State Review and Follow-up Costs $45,958

Recordkeeping $1,277

Total Cost2 $47,234

Annualized Cost (3%)

Annualized Cost (7%)

$3,175

$4,458

1

 See Appendices E–3a through E–3c for detail.

2 Detail may not add to total due to independent rounding. 
FBRR Final RIA 6-12 April 2001

6.3 Summary of Costs

National costs for the FBRR are the sum of individual requirement costs (Exhibit 6–11). Annual

costs include annualized capital and start-up costs, as well as annual O&M and labor costs. On

an annual basis, the cost of the FBRR is estimated to be $5.84 million, assuming a 3 percent

discount rate and $7.19 million using a 7 percent discount rate. 

Exhibit 6–11. Total Annual Costs for the FBRR Provisions

(January 1999 dollars)

Compliance Activity Costs ($000)

Using 3% Discount Rate Using 7% Discount Rate

System Costs

Startup Costs $147 $206

Recycle Return Location $5,528 $6,758

Conventional Filtration

Recycling Reporting $85 $119

Direct Filtration Recycling

Reporting $7 $9

Total System Costs $5,766 $7,092

State Costs

Startup Costs $23 $32

Recycle Return Location $2 $3

Conventional Filtration

Recycling Reporting $42 $59

Direct Filtration Recycling

Reporting $3 $4

Total State Costs $70 $98

Total Costs1 $5,836 $7,190

1

 Detail may not add to total due to independent rounding.

Exhibit 6-12 shows the system, State, and total cost broken down by system size category.
FBRR Final RIA 6-13 April 2001

Exhibit 6–12a. Summary of Total Annual Costs for the Recycle Provisions by

System Size (3% discount rate & January 1999 dollars)

Compliance

Activity

Total Annual Costs by System Size Category

@100 101–500 501–1,000 1,001–3,300 3,301–9,999 A10,000

System Costs $86,934 $147,126 $117,942 $293,586 $420,490 $4,700,087

Total State Costs $7,298 $9,865 $7,346 $14,459 $13,240 $17,061

Total Costs $94,232 $156,991 $125,288 $308,045 $433,730 $4,717,148

Exhibit 6–12b. Summary of Total Annual Costs for the Recycle Provisions by

System Size (7% discount rate & January 1999 dollars)

Compliance

Activity

Total Annual Costs by System Size Category

@100 101–500 501–1,000 1,001–3,300 3,301–9,999 A10,000

System Costs $105,643 $178,789 $143,324 $356,770 $510,986 $5,796,488

Total State Costs $10,217 $13,811 $10,284 $20,242 $18,536 $24,910

Total Costs $115,860 $192,600 $153,608 $377,012 $529,522 $5,821,398
FBRR Final RIA 6-14 April 2001

6.3.1 Biases and Uncertainty

There are several biases and uncertainties that affect EPA’s estimate of total costs, which are

summarized in Exhibit 6–13.

Exhibit 6–13. Summary of Cost Analysis Uncertainty

Item

Potential Effect

on Costs if

Resolved

Comments

Biases

Assumed no market responses to

system cost increases

– Demand responses to price changes may

mitigate total costs.

Assumed system-level costs for

community systems were applicable to

noncommunity systems

– Noncommunity systems may have lower flow

rates than community systems, which would

generate lower system-level costs using the

engineering cost models.

Included purchased water systems – Excluding these systems from the baseline and

compliance forecast would reduce costs.

Uncertainties

Cost estimates based on model

drinking water systems and aggregate

costs based on compliance forecasts

constructed from SDWIS, AWWA, and

ICR data

+/> The engineering models and burden

analyses are based on model systems or

expected burdens. Actual costs and burdens

will differ across systems. The compliance

forecasts are based on sample data; the

actual number of systems implementing

treatment changes may differ from EPA’s

projections.

+ = resolving the omission, bias, or uncertainty will tend to increase costs.

> = resolving the omission, bias, or uncertainty will tend to reduce costs.

+/> = the effect of the omission, bias, or uncertainty on costs is undetermined.

Capital and O&M costs are functions of system flow rates, which were obtained from the

Community Water System Survey database. Consequently, these costs are more representative

of costs for community water systems, but EPA used the same flows for noncommunity systems

as well, because of a lack of data concerning the flow capacities and technologies employed by

these systems. Because noncommunity systems may have smaller flows than community

systems, this assumption may overestimate costs for noncommunity systems.

The system estimates in the compliance forecasts include purchased water systems. The majority

of these systems will not actually incur the costs discussed in this chapter because they purchase

treated water from a wholesale system. This approach will overstate costs for the provisions that

affect only small systems because EPA is including costs for small wholesale systems and for the

small systems that purchase treated water from them, although only the wholesale systems treat

water. EPA cannot determine the extent of this effect on the cost analysis and chose to retain all

small systems to develop consistent cost and benefit analyses.
FBRR Final RIA 6-15 April 2001

Finally, the methods used to estimate costs introduced uncertainty into the analysis because

actual system- and State-level costs will vary from the modeled treatment costs or estimated

burden costs. Furthermore, the compliance forecasts are EPA’s estimates of the numbers of

systems potentially affected by various provisions. These forecasts are based on a variety of

sources including sample data from the AWWA recycle survey and information gathered under

the ICR. They may over or under estimate the actual number of systems affected by various

provisions and/or the number of systems altering treatment practices. EPA cannot determine

whether the methods and data tend to over or under estimate total costs.

6.4 Household Costs

Water system cost increases are often passed on to customers, on a per household basis, in the

form of higher monthly water bills. This section approximates potential household impacts of

the FBRR by estimating a distribution of household costs based on the system costs for the

recycle provisions discussed above. EPA expects approximately 4,650 systems to be affected by

the FBRR. The procedure used to calculate household costs and the results of those calculations

are described below.

Using the Drinking Water Baseline Handbook data, system populations for all community

drinking water systems were cross-tabulated according to source (i.e., SW, GWUDI, and GW)

against the established system size categories. EPA limited the analysis to community water

systems because only those systems serve residential customers. The proportion of the total that

each size/source category represented was multiplied by the total number of households using

public water reported in U.S. Census data to arrive at a household distribution by source and

system size. The number of households affected by the rule was then estimated based on the

ratios used in the baseline to calculate the number of systems affected by the rule. 

This approach was used to calculate the number of households affected by each of the three

regulatory outcomes (i.e., direct/conventional reporting, applying for an alternate recycle

location, and relocating recycle return) were then calculated by multiplying the percentage of

systems affected by each regulatory outcome. Using Drinking Water Baseline Handbook data for

water consumption by system size category, household water consumption by regulatory

outcome and size was calculated. Finally, to arrive at household costs by system size category,

household flow data (kgal) and cost ($/kgal) were organized by system size and regulatory

outcome, and were multiplied together. Since the direct/conventional reporting procedure is

required for all systems, the flow costs ($/kgal) for the direct/conventional reporting requirement

were added to both the alternate location and the recycling outcomes prior to multiplying the

flow cost data by the household data. These cost data were then matched with the household

data to compile a cumulative distribution of household costs. Household cost estimate details are

shown in Appendix F.

Exhibit 6-14 illustrates the distribution of household costs for the recycle provisions. The

average cost per household is $0.19 per year. The household cost is less than $1.70 per year for

over 99 percent of the 31.4 million households potentially affected by the rule and less than $9.36

per year for 99.97 percent. The maximum cost of $97.37 per year ($8.11 monthly) is potentially
FBRR Final RIA 6-16 April 2001

0.00%

10.00%

20.00%

30.00%

40.00%

50.00%

60.00%

70.00%

80.00%

90.00%

100.00%

$0.00 $0.01 $0.10 $1.00 $10.00 $100.00

Annual Cost per Household

Cumulative Percent of Households

99 Percent of all 

households are 

impacted by less than 

$1.70 per household 

per year.

incurred by a subset of only 321 households.

Exhibit 6–14. Distribution of Annual Household Costs for the Recycle Provisions
FBRR Final RIA 6-17 April 2001

6.5 Cost of Regulatory Alternatives

EPA also developed cost estimates for each of the alternative provisions described in Chapter 3

of this RIA. Exhibit 6-15 summarizes the costs for each of the different provisions considered.

Exhibit 6-15. Annual Cost Comparison of Alternate Rule Provisions

Recycle Return Location Provision

Option Cost ($ million, 3% discount rate)

Alternative R1 $6.47

Alternative R2 (Rule Option) $5.54

Alternative R3 $6.47

Alternative R4 $6.47

Conventional/Direct Recycle Provision

Option Cost ($ million, 3% discount rate)

Alternative R1 $0.00

Alternative R2 (Rule Option) $1.27

Alternative R3 $30.21

Alternative R4 $106.82

Direct Filtration Provision

Option Cost ($ million, 3% discount rate)

Alternative R1 $0.00

Alternative R2 (Rule Option) $0.01

Alternative R3 $1.62

Alternative R4 $1.25

EPA’s rational for selection of the rule options along with a detailed description of all the

alternatives considered is given in Chapter 3. Cost differences for each alternative are a function

of the frequency and duration of system monitoring, reporting and recordkeeping activities,

variations in capital requirements, and variations in O&M requirements. These variations

between the different provisions are also described in Chapter 3. Overall, EPA chose a

combination of regulatory options that provided adequate public health protection while trying to

minimize the financial burdens imposed on small systems.
FBRR Final RIA April, 2001 7-1

7. Economic Impact Analysis

As part of the rule promulgation process, EPA is required to perform a series of distributional

analyses that address the potential regulatory burden placed on entities that are affected directly

or indirectly by the various rule requirements. This chapter contains all or part of EPA’s analyses

and statements with regard to the following six Federal mandates: 

1. Executive Order 13084 (Consultation With Indian Tribal Governments);

2. The Regulatory Flexibility Act (RFA) of 1980, as amended by the Small Business

Regulatory Enforcement Fairness Act (SBREFA) of 1996;

3. Technical, Financial, and Managerial Capacity Assessment required by Section

1420(d)(3) of the 1996 amendments to the Safe Drinking Water Act (SDWA);

4. Impacts on Sensitive Sub-Populations as required by Section 1412(b)(3)(c)(i) of

the SDWA Amendments; 

5. Executive Order 13045 (Protection of Children From Environmental Health Risks

and Safety Risks); and 

6. Executive Order 12898 (Federal Actions to Address Environmental Justice in

Minority Populations and Low-Income Populations).

This chapter discusses these six mandates; several of which contain provisions requiring an

explanation of why the rule is necessary, the statutory authority upon which it is based, and the

primary objectives it is intended to achieve. A complete discussion of the background

information and the statutory authority for this rulemaking is located in Chapter 2, “Need for the

Proposal.” 

In addition, this chapter contains a summary of the analysis conducted to fulfill requirements set

forth by the Paperwork Reduction Act. A separate Information Collection Request (ICR)

document, the Information Collection Request for the Filter Backwash Recycling Rule, contains

the complete analysis and is available in the Office of Water Docket.

This chapter is organized into three sections. Specifically:

` Section 7.1 - addresses how the rule pertains to those mandates concerning

potential impacts to government and business entities.

` Section 7.2 - considers the impact of the rule on possible sensitive

subpopulations, such as children.

` Section 7.3 - evaluates the potential impact to minority and low-income

populations.
 FBRR Final RIA April, 2001 7-2

7.1 Impacts on Governments and Business Units

The following sections contain the analyses necessary to fulfill Executive Orders pertaining to

governments and businesses. Section 7.1.1 discusses possible impacts on Indian Tribal

Governments. Section 7.1.2 is the required RFA and SBREFA analysis. Section 7.1.3 is the

capacity analysis, and Section 7.1.4 provides a summary of the ICR.

7.1.1 Indian Tribal Governments

Under Executive Order 13084, EPA may not issue a regulation, which is not required by statute,

that significantly or uniquely affects the communities of Indian Tribal governments, and that

imposes substantial direct compliance costs on those communities, unless the Federal

government provides the funds necessary to pay the direct compliance costs incurred by the

Tribal governments or EPA consults with those governments. 

If EPA complies by consulting, Executive Order 13084 requires EPA to provide to the Office of

Management and Budget, in a separately identified section of the preamble to the rule, a

description of the extent of EPA’s prior consultation with representatives of affected Tribal

governments, a summary of the nature of their concerns, and a statement supporting the need to

issue the regulation. In addition, Executive Order 13084 requires EPA to develop an effective

process permitting elected officials and other representatives of Indian Tribal governments “to

provide meaningful and timely input in the development of regulatory policies on matters that

significantly or uniquely affect their communities.” In developing this rule, EPA consulted with

representatives of Tribal governments pursuant to the Unfunded Mandates Reform Act (UMRA)

and Executive Order 13084. EPA held extensive meetings that provided the opportunity for

meaningful and timely input in the development of the rule. The public docket for this

rulemaking includes summaries of the meetings.

EPA has concluded that this rule does not significantly or uniquely affect the communities of

Indian Tribal governments, nor will it impose substantial direct compliance costs on them. This

rule will affect fewer than 22 of the 987 (or 2 percent) total Tribal drinking water systems. Of

these 22 systems, 20 are estimated to incur annualized compliance costs of more than $50 per

year or 0.001 percent of average annual revenue. The remaining two systems are estimated to

incur annualized compliance costs of approximately $2,200 per year or 0.08 percent of average

annual revenue. Accordingly, the requirements of Section 3(b) of Executive Order 13084 do not

apply to this rule. 

7.1.2 Regulatory Flexibility Act and Small Business Regulatory Enforcement Fairness Act

The provisions of the Regulatory Flexibility Act, 5 U.S.C. 601 et seq., as amended by the Small

Business Regulatory Enforcement Fairness Act of 1996, require EPA to prepare a regulatory

flexibility analysis unless the Agency certifies that the rule will not have “a significant economic

impact on a substantial number of small entities.” A regulatory flexibility analysis describes the

impact of the regulatory action on small entities as part of the rule promulgation process. 
1

EPA used 11,411 systems in this analysis, recognizing that only 4,650 systems are expected to be subject to the

FBRR. Using the entire universe of small surface and GWUDI systems allowed an accurate calculation of ownership type.

2

The Drinking Water Baseline Handbook separates system ownership data into public, private or other (U.S. EPA,

2000b). For this analysis, EPA assumed, for the small systems, that public represents small government, private represents small

business, and other represented small non-profit.

FBRR Final RIA April, 2001 7-3

The 1996 amendments to the SDWA define a small public water system (PWS) as a system

serving fewer than 10,000 persons. This definition reflects the fact that the original 1979

standard for total trihalomethanes applied only to systems serving at least 10,000 people. The

definition thus recognizes that baseline conditions from which systems serving fewer than 10,000

people will approach disinfection byproduct control and simultaneous control of microbial

pathogens is different from that for systems serving 10,000 or more persons. 

Background and Quantitative Analysis

When a rule may potentially have an adverse effect on one or more small entities, RFA and

SBREFA require EPA to determine the extent of the impact and the number of small entities

affected. If it is determined that the rule would not have a “significant impact on a substantial

number of small entities,” then the Agency can certify the rule. If the Agency determines that the

rule will have an impact then the RFA/SBREFA requires that EPA prepare an Initial Regulatory

Flexibility Analysis (IRFA) for a proposed rule, or Final Regulatory Flexibility Analysis (FRFA)

for a final rule. Chapter 4 of this document provides data on the small entities potentially

affected by the FBRR, and Chapter 6 discusses the changes systems would have to make and the

likely costs. Using information found in these two chapters, along with additional information

from Safe Drinking Water Information System (SDWIS) and Community Water System Survey

(CWSS), EPA conducted a quantitative analysis to assist in determining whether to certify the

rule or prepare an FRFA.

The Agency recognizes that economic characteristics will vary among entities affected by a given

rule. Therefore, EPA evaluated the potential economic impact by comparing compliance costs as

a percentage of sales, revenues, and operating expenses for small businesses, governments, and

non profit organizations respectively. Statistics on the characteristics of water systems are

updated frequently, making it difficult to describe the universe of surface water systems at any

given time. Similarly, ownership data is difficult to ascertain because most data sets, such as

SDWIS, do not maintain such information. For this analysis, the number of publicly and

privately owned water systems was derived using the ratio of public to private water systems as

reported in the 1995 CWSS. Using SDWIS and CWSS, EPA evaluated the universe of 11,411

small surface water and GWUDI systems to estimate the distribution of ownership type (i.e.,

public vs. private).1

 EPA estimates that for small systems, 34.0 percent are owned by small

businesses, 59.7 percent are owned by small governments, and 6.3 percent are owned by

nonprofit organizations.2

 While it was not possible to use existing data to establish the exact

profile of water system ownership, EPA used information in the Drinking Water Baseline
3

A public water system provides piped water for human consumption. The term “public water system” applies not only

to water utilities, but also to a wide range of privately or publicly owned businesses and entities that provide drinking water (e.g.,

campgrounds, factories, restaurants, and schools). Public water systems are classified as community, nontransient

noncommunity, or transient noncommunity systems.

 FBRR Final RIA April, 2001 7-4

Handbook (U.S. EPA, 2000b) to approximate an ownership profile. As shown in Exhibit 7–1,

the data suggest that a majority of small systems are publicly owned.3

Exhibit 7–1. Number and Percent of Small Public and Private Systems, 

by Size of System

System

Type

System Population Size Category

<100 101–500 501–1,000 1,001–3,300 3,301–9,999 Total

Public 725 (26.6%) 1,346 (47.8%) 979 (69.2%) 2,075 (81.0%) 1,683 (88.8%) 6,808 (59.7%)

Private 1,635 (60.0%) 1,266 (45.0%) 369 (26.1%) 428 (16.7%) 188 (9.9%) 3,886 (34.0%)

Other 366 (13.4%) 203 (7.2%) 66 (4.7%) 58 (2.3%) 24 (1.3%) 717 (6.3%)

Total 2,726 (24%) 2,815 (25%) 1,414 (12%) 2,561 (23%) 1,895 (16%) 11,411 (100%)

Note: Figures represent number (percent) of systems within system size category.

The FBRR contains a provision for filter backwash recycling. Chapter 6 discusses this provision

in detail and Exhibit 7–2 summarizes EPA’s estimate of the number of small entities that the

provision will affect. The 349 systems affected by the recycle return location provision are also

affected by one of the other two provisions. 

Exhibit 7–2. Small Entities Affected by the Filter Backwash

Recycle Provisions of the FBRR

System Size

(population served)

Systems Moving

Recycle Return

Location or

Requesting Approval

of Alternate Location 

Systems

that Must Meet

Conventional

Filtration

Requirements

Systems that Must

Meet Direct Filtration

Requirements

< 100 49 454 34

101–500 66 613 46

501–1,000 49 457 34

1,001–3,300 96 899 68

3,301–9,999 89 823 62

Totals 349 3,246 244
4

The analyses supporting this certification are contained in the Regulatory Flexibility Screening Analysis prepared for

this final rule and can be found in the docket supporting the final rule (U.S. EPA, 2000g).

FBRR Final RIA April, 2001 7-5

After considering the economic impacts of the rule on small entities, EPA certifies that this

regulation will not have a significant economic impact on a substantial number of small entities.4

7.1.3 Effect of Compliance With the FBRR on the Technical, Financial, and Managerial

Capacity of Public Water Systems

Section 1420(d)(3) of the SDWA as amended requires that, in promulgating a National Primary

Drinking Water Regulation (NPDWR), the Administrator shall include an analysis of the likely

effect of compliance with the regulation on the technical, financial, and managerial capacity of

PWSs. The following analysis fulfills this statutory obligation. In EPA guidance (EPA

816-R-98-006) (U.S. EPA, 1998) the Agency defines water system capacity as the ability to plan

for, achieve, and maintain compliance with applicable drinking water standards. 

Capacity has three components: technical, managerial, and financial. Technical capacity is the

physical and operational ability of a water system to meet SDWA requirements. Technical

capacity refers to the physical infrastructure of the water system, including the adequacy of

source water and the adequacy of treatment, storage, and distribution infrastructure. It also refers

to the ability of system personnel to adequately operate and maintain the system and to otherwise

implement requisite technical knowledge. Examining key issues and questions can determine a

water system’s technical capacity, including:

• Source water adequacy. Does the system have a reliable source of water? Is the

source of generally good quality and adequately protected?

• Infrastructure adequacy. Can the system provide water that meets SDWA

standards? What is the condition of its infrastructure, including well(s) or source

water intakes, treatment, storage, and distribution? What is the infrastructure's life

expectancy? Does the system have a capital improvement plan?

• Technical knowledge and implementation. Is the system's operator certified? Does

the operator have sufficient technical knowledge of applicable standards? Can the

operator effectively implement this technical knowledge? Does the operator

understand the system's technical and operational characteristics? Does the system

have an effective operation and maintenance program?

Managerial capacity is the ability of a water system to conduct its affairs in a manner enabling

the system to achieve and maintain compliance with SDWA requirements. Managerial capacity

can be assessed through key issues and questions, including:

• Ownership accountability. Are the system owner(s) clearly identified? Can they be

held accountable for the system?
 FBRR Final RIA April, 2001 7-6

• Staffing and organization. Are the system operator(s) and manager(s) clearly

identified? Is the system properly organized and staffed? Do personnel understand

the management aspects of regulatory requirements and system operations? Do they

have adequate expertise to manage water system operations? Do personnel have the

necessary licenses and certifications?

• Effective external linkages. Does the system interact well with customers,

regulators, and other entities? Is the system aware of available external resources,

such as technical and financial assistance?

Financial capacity is a water system's ability to acquire and manage sufficient financial resources

to allow the system to achieve and maintain compliance with SDWA requirements. Financial

capacity can be assessed through key issues and questions, including:

• Revenue sufficiency. Do revenues cover costs? Are water rates and charges

adequate to cover the cost of water?

• Credit worthiness. Is the system financially healthy? Does it have access to capital

through public or private sources?

• Fiscal management and controls. Are adequate books and records maintained? Are

appropriate budgeting, accounting, and financial planning methods used? Does the

system manage its revenues effectively?

A total of 4,650 large and small systems are potentially subject to the FBRR. Of these, EPA

estimates that 373 systems would need to modify treatment to come into compliance with the

rule—the remainder or subject to reporting requirements only. Some large or small systems may

require significantly increased technical, financial, or managerial capacity to comply with these

new requirements.

Systems modifying treatment to meet recycling provisions may need to move recycle return to

the plant headworks or alter treatment processes. As noted above, the compliance forecast

estimated that 373 plants would need to move their recycling return flow to the head of the plant. 

Exhibits in the appendices detail the unit capital and O&M costs for direct and conventional

filtration plants that need to redirect their recycle flows. Generally, systems affected by this rule

are not required to make significant modifications to the treatment process to meet FBRR

requirements. Therefore, systems are not expected to experience a significant impact on their

technical, financial, or managerial capacity.

The final rule also requires that systems which practice conventional filtration and recycle spent

filter backwash, sludge thickener supernatant, or liquids from dewatering processes, must notify
FBRR Final RIA April, 2001 7-7

the State in writing that they practice recycle. Additionally, systems must collect and maintain

information for review by the State. When notifying the State, systems must also provide the

following information:

 

` A plant schematic showing the origin of all recycle flows, the hydraulic conveyance used

to transport them, and the location where they are recycled back into the plant; and 

` Typical recycle flow in gallons per minute (gpm), highest observed plant flow

experienced in the previous year (gpm), design flow for the treatment plant (gpm), and, if

applicable, the State-approved operating capacity for the plant.

7.1.4 Paperwork Reduction Act

The information collected as a result of this rule will allow the States and EPA to determine

appropriate requirements for specific systems, in some cases, and to evaluate compliance with

the rule. For the first 3 years after promulgation of this rule, the major information requirements

pertain to compliance reporting. Responses to the request for information are mandatory (40

CFR, Part 141). The information collected is not confidential.

The Paperwork Reduction Act requires EPA to estimate the burden on PWS, States, and

territories for complying with the final rule. Burden refers to 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.

Information collection activities of PWSs required under this rule during the first 3 years

following promulgation will result in an average annual burden of 60,513 person-hours

collectively for the PWSs. For States and territories, the analysis suggests the annual average

burden to be 5,849 hours. The national, average annual labor cost of PWSs associated with

information collection activities averages $1,281,512. Nationally, States will incur annual

average costs of $136,182. Exhibit 7–3 presents a summary of the burden hours and costs

associated with the FBRR for the 3 years covered by the ICR.

The costs and burdens during ICR approval period do not reflect all the costs and burdens that

would result from the rule. The total burden and costs to systems for the FBRR provisions would

be 183,295 hours and $3.5 million, respectively. For States, the FBRR provisions would result in

a burden of 17,548 hours, and a cost of $408,546. 
 FBRR Final RIA April, 2001 7-8

Exhibit 7–3. Summary Average Annual Burden and

Costs for PWSs and States for the ICR Approval

Period

Average Annual Burden Average Annual Labor

Cost

PWSs 60,513 $1,281,512

States 5,849 $136,182 

Total 66,362 $1,417,694 

The derivation of all FBRR burdens and costs for start-up and annual information collection

activities can be found in Information Collection Request for the Filter Backwash Recycling

Rule.

7.1.5 Unfunded Mandates Reform Act

Title II of the Unfunded Mandates Reform Act of 1995 (UMRA), Public Law 104-4, establishes

requirements for Federal agencies to assess the effects of their regulatory actions on State, local,

and Tribal governments and the private sector. Under UMRA Section 202, EPA generally must

prepare a written statement, including a cost-benefit analysis, for proposed and final rules with

"Federal mandates" that may result in expenditures by State, local, and Tribal governments, in

the aggregate, or to the private sector, of $100 million or more in any one year. Before

promulgating an EPA rule, for which a written statement is needed, Section 205 of the UMRA

generally requires EPA to identify and consider a reasonable number of regulatory alternatives

and adopt the least costly, most cost-effective or least burdensome alternative that achieves the

objectives of the rule. The provisions of Section 205 do not apply when they are inconsistent

with applicable law. Moreover, Section 205 allows EPA to adopt an alternative other than the

least costly, most cost-effective or least burdensome alternative if the Administrator publishes

with the final rule an explanation why that alternative was not adopted. 

Before EPA establishes any regulatory requirements that may significantly or uniquely affect

small governments, including Tribal governments, it must have developed, under Section 203 of

the UMRA, a small government agency plan. The plan must provide for notification to

potentially affected small governments, enabling officials of affected small governments to have

meaningful and timely input in the development of EPA regulatory proposals with significant

Federal intergovernmental mandates and informing, educating, and advising small governments

on compliance with the regulatory requirements. 

EPA has determined that this rule does not contain a Federal mandate that may result in

expenditures of $100 million or more for the State, local and Tribal governments, in the

aggregate, or the private sector in any one year. Thus, FBRR is not subject to the requirements of

Sections 202 and 205 of the UMRA. The Agency estimated annual aggregate State, local, and

Tribal government expenditures by adding State program costs to the share of system costs

potentially incurred by publicly owned systems. These systems account for approximately 64

percent of the $5.77-$6.18 million (3 percent and 7 percent discount rates) in total annual system
FBRR Final RIA April, 2001 7-9

costs, which is $3.71-$3.96 million (3 percent and 7 percent discount rates) per year. Thus, State

program costs and publicly owned system costs total $3.78-$4.05 million (3 percent and 7

percent discount rates) per year.

Consistent with the intergovernmental consultation provisions of Section 204 of UMRA, EPA

consulted with small governments to address impacts of regulatory requirements in the rule that

might significantly or uniquely affect small governments. As discussed next, a variety of

stakeholders, including small governments, were provided the opportunity for timely and

meaningful participation in the regulatory development process. EPA used these opportunities to

notify potentially affected small governments of regulatory requirements being considered.

EPA began outreach efforts to develop the FBRR in the summer of 1998. Two public

stakeholder meetings, which were announced in the Federal Register, were held on July 22-23,

1998, in Lakewood, Colorado, and on March 3-4, 1999, in Dallas, Texas. In addition to these

meetings, EPA has held several formal and informal meetings with stakeholders including the

Association of State Drinking Water Administrators. A summary of each meeting and attendees

is available in the public docket for this rule. EPA also convened a Small Business Advocacy

Review (SBAR) Panel in accordance with the RFA, as amended by SBREFA to address small

entity concerns including those of small local governments. The SBAR Panel allows small

regulated entities to provide input to EPA early in the regulatory development process. In early

June, 1999, EPA mailed an informal draft of the FBRR preamble to the approximately 100

stakeholders who attended one of the public stakeholder meetings. Members of trade

associations and the SBREFA Panel also received the draft preamble. EPA received valuable

suggestions and stakeholder input from 15 State representatives, trade associations,

environmental interest groups, and individual stakeholders. The majority of concerns dealt with

reducing burden on small systems and maintaining flexibility.

7.2 Impacts on Subpopulations

A primary purpose of the FBRR is to improve control of microbial pathogens, specifically the

protozoan Cryptosporidium. The health effect of cryptosporidiosis on sensitive subpopulations

is much more severe and debilitating than on the general population. Several subpopulations are

more sensitive to cryptosporidiosis, including the young, elderly, malnourished, disease impaired

(especially those with diabetes), and a broad category of those with compromised immune

systems, such as AIDS patients, those with Lupus or cystic fibrosis, transplant recipients, and

those on chemotherapy (Rose, 1997).

7.2.1 Impacts on the Immunocompromised

Mortality, as a result of cryptosporidiosis infection, is a much greater risk for sensitive

subpopulations than it is for the general population, particularly for the immunocompromised.

The duration and severity of the disease are significant: whereas the disease may hospitalize 1

percent of the immunocompetent population with very little risk of mortality (< 0.001),
 FBRR Final RIA April, 2001 7-10

Cryptosporidium infections are associated with a high rate of mortality in the

immunocompromised (50 percent) (Rose, 1997).

The duration of cryptosporidiosis in those with compromised immune systems is considerably

longer than in those with competent immune systems, with more severe symptoms often

requiring lengthy hospital stays. In those subpopulations, the cost-of-illness (COI) from

cryptosporidiosis would be much greater than for the general populace. During a 1993 outbreak

in Milwaukee, 33 AIDS patients with Cryptosporidium accounted for 400 hospital days at an

additional cost of nearly $760,000 (Rose, 1997). COI due to these hospital days alone is

estimated at $23,000 per case ($760,000/33 patients).

Because of the severity of illness and high costs for treatment experienced by sensitive

subpopulations, as a result of Cryptosporidium infection, the Agency expects the FBRR to have a

disproportionately positive impact on the subpopulations mentioned earlier.

7.2.2 Protecting Children From Environmental Health Risks and Safety Risks

Executive Order 13045 (62 FR 19885; April 23, 1997) applies to any rule initiated after

April 21,1997, or after April 21, 1998, that (1) is determined to be “economically significant” as

defined under Executive Order 12866 and (2) concerns an environmental health or safety risk

that EPA has reason to believe may have a disproportionate effect on children. If the regulatory

action meets both criteria, EPA must evaluate the environmental health or safety effects of the

planned rule on children, and explain why the planned regulation is preferable to other

potentially effective and reasonably feasible alternatives considered by EPA.

While FBRR is not subject to the Executive Order because it is not economically significant as

defined by Executive Order 12866, the Agency nonetheless has reason to believe that the

environmental health or safety risk addressed by this action may have a disproportionate effect on

children. As a matter of policy, EPA assessed available Cryptosporidium-related health effects

data for children.

In promulgating the FBRR, EPA recognizes that the health risks associated with exposure to the

protozoan Cryptosporidium are of particular concern for certain sensitive subpopulations,

including children and immunocompromised individuals. The risk of illness and death due to

cryptosporidiosis depends on several factors, including age, nutrition, exposure, genetic

variability, disease and immune status of the individual. Mortality resulting from diarrhea shows

the greatest risk of mortality occurring among the very young and elderly (Gerba et al., 1996). 

For Cryptosporidium, young children are a vulnerable population subject to infectious diarrhea 

(CDC 1994). Cryptosporidiosis is prevalent worldwide, and its occurrence is higher in children

than in adults (Fayer and Ungar, 1986). 

Cryptosporidiosis appears to be more prevalent in populations such as infants, that may not have

established immunity against the disease and may be in greater contact with environmentally
FBRR Final RIA April, 2001 7-11

contaminated surfaces (DuPont et al., 1995). An infected child may spread the disease to other

children or family members. Evidence of such secondary transmission of cryptosporidiosis from

children to household and other close contacts has been found in a number of outbreak

investigations (Casemore, 1990; Cordell et al., 1997; Frost et al., 1997). Chapell et al. (1999)

found that prior exposure to Cryptosporidium through the ingestion of a low oocyst dose

provides protection from infection and illness. However, it is not known whether this immunity

is life-long or temporary. Data also indicate that either mothers confer short term immunity to

their children or that babies have reduced exposure to Cryptosporidium, resulting in a decreased

incidence of infection during the first year of life. For example, in a survey of over 30,000 stool

sample analyses from different patients in the United Kingdom, the 1-5 year age group suffered a

much higher infection rate than individuals less than one year of age. For children under one

year of age, those older than six months of age showed a higher rate of infection than individuals

aged fewer than six months (Casemore, 1990).

EPA has not been able to quantify the health effects for children as a result of Cryptosporidiumcontaminated drinking water. However, the result of the FBRR will be a reduction in the risk of

illness for the entire population, including children. Because available evidence indicates that

children may be more vulnerable to cryptosporidiosis than the rest of the population, the FBRR

would, therefore, result in greater risk reduction for children than for the general population.

7.3 Environmental Justice

Executive Order 12898 (59 FR 7629) establishes a Federal policy for incorporating

environmental justice into Federal agency missions by directing agencies to identify and address

disproportionately high and adverse human health or environmental effects of its programs,

policies, and activities on minority and low-income populations. The Agency has considered

environmental justice-related issues concerning the potential impacts of this action and has

consulted with minority and low-income stakeholders. 

The overall nature of the FBRR mimics the 1998 IESWTR by regulating small PWSs to improve

control of microbial pathogens. As such, the Agency also built on the efforts conducted during

the IESWTR’s development to comply with Executive Order 12898. On March 12, 1998, the

Agency held a stakeholder meeting to address various components of pending drinking water

regulations and how they may impact sensitive sub-populations, minority populations, and

low-income populations. Topics discussed included treatment techniques, costs and benefits,

data quality, health effects, and the regulatory process. Participants included national, State,

Tribal, municipal, and individual stakeholders. EPA conducted the meetings by video

conference call between eleven cities. This meeting was a continuation of stakeholder meetings

that started in 1995 to obtain input on the Agency's Drinking Water Programs. The major

objectives for the March 12, 1998 meeting were to:

(1) Solicit ideas from stakeholders on known issues concerning current drinking water

regulatory efforts;
 FBRR Final RIA April, 2001 7-12

(2) Identify key issues of concern to stakeholders, and;

(3) Receive suggestions from stakeholders concerning ways to increase representation of

communities in Office of Ground Water and Drinking Water regulatory efforts.

In addition, EPA developed a plain-English guide specifically for this meeting to assist

stakeholders in understanding the multiple and sometimes complex issues surrounding drinking

water regulation. 
FBRR Final RIA 8–1 April 2001

8. Weighing the Benefits and the Costs

This chapter compares the benefit estimates discussed in Chapter 5 with the cost estimates

discussed in Chapter 6. Because data were not available to accurately estimate the annual

benefits, the Regulatory Impact Analysis (RIA) does not present a mathematical comparison

between costs and benefits. Instead, a breakeven analysis is presented to assess potential benefits

of the rule in relation to the calculated costs. EPA expects that the benefits associated with the

FBRR justify the costs associated with the rule.

The chapter is organized as follows:

• Section 8.1 - briefly discusses the cost and benefit analyses in this RIA.

• Section 8.2 - describes EPA’s determination that the costs associated with the Filter

Backwash Recycling Rule (FBRR) are justified by potential benefits.

• Section 8.3 - describes how the breakeven analysis was used to assess the benefits of

the recycle provisions, given the scientific uncertainties surrounding the

risk posed by the recycling practices.

• Section 8.4 - describes the uncertainties involved in the development of the benefit

and cost analyses.

• Section 8.5 - examines the cost effectiveness of the rule, based on the value of

avoided illness.

• Section 8.6 - shows the combined regulatory affect of the FBRR and several other

rules that potentially affect drinking water systems that use surface water

or ground water under the direct influence of surface water (GWUDI).

8.1 Incremental and Marginal Analysis

Chapter 6 of this RIA estimates the incremental costs of the FBRR, which are the costs expected

to accrue compared to a baseline in which the provisions of the rule are not implemented. 

Annual costs are estimated at $5.84 million (assuming a 3 percent discount rate) and $7.19

million (assuming a 7 percent discount rate). This cost includes annualized capital investments

to alter treatment processes, annual reporting and recordkeeping costs, and annual operation and

maintenance (O&M) expenditures. It also includes annualized start-up cost estimates for all of

the provisions of the rule. EPA has also presented a comparison of the costs associated with the

final rule provisions with the costs that would be associated with proposed provisions. Data are

not available to accurately estimate the benefits associated with the rule.

8.2 Benefit-Cost Comparisons

Under the 1996 amendments to the Safe Drinking Water Act, EPA is required to make a

determination of whether benefits justify costs for the rulemaking. EPA has determined that the

benefits of the FBRR justify the costs. 
FBRR Final RIA 8–2 April 2001

The Agency has determined that the benefits of the provisions justify their cost on a qualitative

basis although the analysis in the following section provides a quantitative perspective on the

health benefits needed to break even given EPA’s cost estimates. The recycle provisions will

reduce the potential for certain recycle practices to lower or upset treatment plant performance

during recycle events. Therefore, the provisions will help prevent Cryptosporidium oocysts from

entering finished drinking water supplies and will increase the level of public health protection.

Returning Cryptosporidium to the treatment process in recycle flows, if performed in a manner

that is inconsistent with fundamental engineering and water treatment principles, can increase

public health risks. EPA believes that there are three instances, in particular, that potentially

increase health risks. First, returning recycle flow directly to the plant—without equalization or

treatment—can cause large variations in the influent flow magnitude and the influent water

quality. If chemical dosing is not adjusted to reflect these variations, then less than optimal

chemical dosing can occur, which may lower sedimentation and filtration performance. 

Returning recycle flows through the processes of a system’s existing conventional or direct

filtration system, as defined in 40 CFR, Section 141.2, will help diminish the likelihood of this

occurring. Second, exceeding State-approved operating capacity, which may be more likely to

occur if recycle equalization or treatment is not in place, can hydraulically overload plants and

diminish the ability of individual unit processes to remove Cryptosporidium. Exceeding

approved operating capacity violates fundamental engineering principles and water treatment

objectives. States set limits on plant operating capacity and loading rates for individual unit

processes to ensure that treatment plants and individual treatment processes operate within their

capabilities and, thereby, provide the necessary levels of public health protection. Third,

improper recycle practices, such as returning recycle flows directly into flocculation or

sedimentation basins, generate disruptive hydraulic currents, which may lower the performance

of these units and increase the risk Cryptosporidium will be present in finished water supplies.

The objective of the FBRR is to eliminate practices that do not use sound engineering judgement

and that create additional and preventable risk to public health. EPA’s rule addresses these

practices, while providing States and affected systems with the flexibility necessary to implement

the most cost-effective solutions. Consequently, EPA believes the public health protection

benefit provided by the FBRR justifies its cost.

8.3 Breakeven Analysis for the Recycle Provisions

The FBRR provisions are expected to improve recycle practices, thereby preventing the

accumulation of Cryptosporidium within the treatment plant and minimizing the risk of oocysts

entering into the finished water. EPA cannot estimate the magnitude of the risk reduction

because the overall impact on finished water quality of different treatment changes brought about

by the provisions depends on a wide variety of system operational parameters that cannot be

easily modeled. Given the large population served by systems that are potentially subject to the

rule (over 80 million people) small risk reduction could have a substantial impact. To assess the

costs of the recycle provisions against the possible range of risks, EPA used a breakeven analysis

to explore net benefits of the alternatives. Breakeven analysis represents an approach to
FBRR Final RIA 8–3 April 2001

assessing the benefits of the recycle provisions given the scientific uncertainties surrounding the

risk posed by recycling practices.

Breakeven is a standard benchmark of cost effectiveness and economic efficiency and is

essentially the point where the benefits of the recycle provisions would be equal to the costs. 

Normally, the benefits and costs of an option are calculated separately and then compared to

assess whether and by what amount benefits exceed costs. In the case of the recycle provisions,

independently estimating benefits is difficult, if not impossible, because of the uncertainty

surrounding the risk and resulting risk reduction. Instead, the breakeven analysis works

backwards from those variables that are less uncertain. In this case, implementation costs for the

rule and the monetary value associated with the health endpoints are used to calculate what risk

reduction estimates are needed for the rule to just pay for itself in avoided health damages

associated with cryptosporidiosis.

In an ideal situation, the first step in the breakeven analysis is to calculate the number of

cryptosporidiosis cases that would need to be avoided for the benefits of avoiding those cases to

be equal to the cost of the rule. The simple calculation is to divide the annual costs of the rule by

the value per cryptosporidiosis case to derive the number of cryptosporidiosis cases needed to

cover the costs of the rule. However as indicated previously, information is not available on

direct measurements of either COI or WTP to reduce risk specifically for Cryptosporidium. The

Agency was able to develop a breakeven analysis based solely on mortalities. Exhibit 8-1 shows

that the estimated annual cost of the FBRR (assuming a 3 percent discount rate) is less than the

estimated value of one statistical life. 

Exhibit 8–1. Breakeven Analysis Summary

Annual cost of FBRR: $5.8 and $7.19 million 

(at 3% and 7% respectively) 

Estimated cost of 1 mortality avoided: $6.3 million

Breakeven Point: 1 mortality
FBRR Final RIA 8–4 April 2001

8.4 Summary of Uncertainty/Sensitivity Analysis

Uncertainties affected EPA’s ability to estimate the benefits and costs associated with the FBRR. 

EPA expects that there will be a variety of positive benefits associated with the FBRR, but,

because of uncertainties, EPA cannot quantify these benefits. EPA has not developed a national

benefit estimate because the overall impact on finished water quality of different treatment

changes brought about by the provisions depends on a wide variety of system operational

parameters that cannot be easily modeled. In order to model the effect of recycle practice, data

regarding the ability of a wide range of unit processes (sedimentation, dissolved-air flotation

[DAF], contact clarification, filtration) to remove oocysts from a wide variety of source water

types, under a range of treatment conditions, is needed to calibrate the model. These data are

currently not extensive enough to model the impact of recycle on a wide variety of treatment

configurations. 

Capital and O&M expenditures account for a majority of total costs. EPA derived these costs for

a “model” system in each size category using engineering models, best professional judgement,

and existing cost and technology documents. To account for uncertainty, EPA presents costs at

both a 3 percent and a 7 percent discount rate throughout Chapter 6. Additional uncertainties

associated with the cost analysis are caused primarily by baseline assumptions made about how

many systems will be affected by various provisions. Costs for systems affected by the rule

could be higher or lower, which would affect total costs. Section 6.3.1 provides more detail on

the biases and uncertainties associated with the cost estimate. 

8.5 Cost Effectiveness

The cost effectiveness of the rule can be measured as the cost per case of avoided illness. EPA

expects the FBRR to be cost effective, but data are not available to formally assess the actual

number of cryptosporidiosis cases that would be reduced by the rule. For illustrative purposes,

Exhibit 8–2 provides a cost-effectiveness analysis under two example scenarios—a scenario in

which implementation of the FBRR results in the prevention of 2 percent of the illnesses

remaining after implementation of LT1ESWTR and IESWTR and a scenario in which the FBRR

results in the prevention of 5 percent of the remaining illnesses. 
FBRR Final RIA 8–5 April 2001

Exhibit 8-2. Example Cost Effectiveness Derivations

(January 1999 dollars)

Annual Cost of FBRR: $5.84 million

Assumption1

Number of

Illnesses

Avoided

Cost per Illness

Avoided

 The FBRR prevents 2% of the illnesses remaining after

 implementation of IEWSTR and LT1ESWTR 1,800 - 5,400 $1,100 - $3,200

 The FBRR results prevents 5% of the illnesses remaining

 after implementation of IEWSTR and LT1ESWTR 4,500 - 13,500 $400 - $1,300 

1

Number of illnesses avoided is based on mid-improved Cryptosporidium removal assumptions from the RIAs for

LT1ESWTR and IESWTR. For small systems, 2.0- and 2.5-log baseline removal assumptions are used; for large systems, 

baseline removal assumptions of 2.5 logs and 3 logs are used. 

8.6 Combined Regulatory Effects with Other Rules

The FBRR is one of several proposed and final rules that potentially affect surface water and

GWUDI drinking water systems. Other rules include the IESWTR, the Stage 1 Disinfectants and

Disinfection Byproducts Rule (Stage 1 DBPR), and the LT1ESWTR. Thus far, EPA’s cost

estimates suggest that costs associated with small surface water systems will total approximately

$93 million. Costs associated with larger surface water systems are greater, potentially totaling

approximately $575 million. These costs do not include costs associated with the Long Term 2

Enhanced Surface Water Treatment Rule (LT2ESWTR) or Stage 2 Disinfection Byproducts Rule

(Stage 2 DBPR) which are expected to be proposed in the near future. Adding costs across rules

may overstate the social costs of regulatory activities because actions to satisfy one rule may

reduce the costs of subsequent rules that have related public health goals.
FBRR Final RIA 9-1 April 2001

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(SRA 557–05/14). February 24.

U.S. EPA. 1998b. Guidance on Implementing the Capacity Development Provisions of the Safe

Drinking Water Act Amendments of 1996. EPA Document Number: 816-R-98-006.

U.S. EPA. 1998c. National Primary Drinking Water Regulations: Disinfectants and Disinfection

Byproducts; Final Rule. 63 FR 69389, December 16, 1998.

U.S. EPA. 1998d. National Primary Drinking Water Regulations: Interim Enhanced Surface

Water Treatment Rule; Final Rule. 63 FR 69477, December 16, 1998.

U.S. EPA. 1998e. Occurrence Assessment of the Interim Enhanced Surface Water Treatment 

Rule. Office of Ground Water and Drinking Water.
FBRR Final RIA 9-10 April 2001

U.S. EPA. 1997a. Community Water System Survey. Volumes I and II. Office of Water. EPA

815-R-97-001a and 815-R-97-001b

U.S. EPA. 1997b. Drinking Water State Revolving Fund Program Guidelines. Office of Water,

Washington, D.C. 

U.S. EPA. 1997c. IESWTR Notice of Data Availability. 62 FR 59485, November 3, 1997.

U.S. EPA. 1996. National Primary Drinking Water Regulations: Monitoring Requirements for

Public Drinking Water Systems; Final Rule. 61 FR 24354, May 14, 1996.

U.S. EPA. 1993. Very Small Systems. Best Available Technology Document. Office of Ground

Water and Drinking Water, Washington, DC.

U.S. EPA. 1992. Notice of regulatory negotiation (RegNeg) process. 63 FR 53866, November

13, 1992.

U.S. EPA. 1989a. National Primary Drinking Water Regulations: Disinfection; Turbidity;

Giardia Lamblia; Viruses; Legionella; and Heterotropic Bacteria; Final Rule. 54 FR

27486, June 29, 1989.

U.S. EPA. 1989b. National Primary Drinking Water Regulations: Total Coliforms (including

Fecal Coliforms and E. Coli); Final Rule. 54 FR 27544, June 29, 1989.

U.S. EPA. 1979a. National Interim Primary Drinking Water Regulations: Control of

Trihalomethanes in Drinking Water. 44 FR 68624, November 29, 1979.

U.S. EPA. 1979b. National Primary Drinking Water Regulations: Control of Trihalomethanes

in Drinking Water; Final Rule. 44 FR 68624, November 29, 1979.

U.S. Environmental Protection Agency/Science Advisory Board (U.S. EPA/SAB). 1990.

Reducing Risk: Setting Priorities and Strategies for Environmental Protection.

September. 

Van Houtven, G.L., J.C. Whitehead, T.H. Bingham, and B. Depro. 1997. Valuing Drinking

Water Benefits: Theory, Methods, and Research Needs. Draft Report Prepared for U.S.

EPA Office of Groundwater and Drinking Water. Research Triangle Park, NC: Research

Triangle Institute.

Van Houtven, G.L. 1997. “Altruistic Preferences for Life-Saving Public Programs: Do Baseline

Risks Matter.” Risk Analysis. 17:85–92.

Walker, M.J., C.D. Montemagno, and M.B. Jenkins. 1998. Source water assessment and

nonpoint sources of acutely toxic contaminants: A review of research related to survival

and transport of Cryptosporidium parvum. Wat. Resour. Res. 34(12): 3383–3392.
Appendix A

Compliance Forecasts and

Total Capital Costs of Treatment
mpliance Forecast for Final FBRR Provisions

<100 101-500

501-

1,000

1,001-

3,300

3,301-

10,000

10,001- 

50,000

50,001-

100,000

100,001-

1,000,000

488 660 491 967 885 860 157 135454 613 457 899 823 800 146 126

34 46 34 68 62 60 11 9

454 613 457 899 823 800 146 126

rks 8.0 8.0 8.0 8.0 8.0 8.0 8.0 8.0

34 46 34 68 62 60 11 9

rks 8.0 8.0 8.0 8.0 8.0 8.0 8.0 8.0

 ------------------------------------------------------------%-----------------------------------------------------------------

 ------------------------------------------------------------%-----------------------------------------------------------------

DIRECT FILTRATION PLANTS ONLY:

ONVENTIONAL FILTRATION PLANTS ONLY:

DIRECT FILTRATION PLANTS ONLY:

L RECYCLE PLANTS (Conventional & Direct):

SYSTEM POPULATION SIZE CATEGORY:

ONVENTIONAL FILTRATION PLANTS ONLY:

April, 2001
<100 101-500

501-

1,000

1,001-

3,300

3,301-

10,000

10,001- 

50,000

50,001-

100,000

100,001-

1,000,000

488 660 491 967 885 860 157 135454 613 457 899 823 800 146 126

34 46 34 68 62 60 11 9

454 613 457 899 823 800 146 126

rks 6.7 13.5 13.7 18.3 32.3 84.1 291.0 2826.1

34 46 34 68 62 60 11 9

6.7 13.5 13.7 18.3 32.3 84.1 291.0 2826.1

em-Level Capital Costs for Recycle Modifications 

L RECYCLE PLANTS (Conventional & Direct):

ONVENTIONAL FILTRATION PLANTS ONLY:

SYSTEM POPULATION SIZE CATEGORY:

ONVENTIONAL FILTRATION PLANTS ONLY:

rks

 ------------------------------------------------------------$1,000------------------------------------------------------------

DIRECT FILTRATION PLANTS ONLY:DIRECT FILTRATION PLANTS ONLY:

 ------------------------------------------------------------$000------------------------------------------------------------

April, 2001
<100 101-500

501-

1,000

1,001-

3,300

3,301-

10,000

10,001- 

50,000

50,001-

100,000

100,001-

1,000,000

488 660 491 967 885 860 157 135454 613 457 899 823 800 146 126

34 46 34 68 62 60 11 9

454 613 457 899 823 800 146 126

rks 1.3 1.4 1.6 2.0 3.2 10.2 22.5 86.2

34 46 34 68 62 60 11 9

rks 1.3 1.4 1.6 2.0 3.2 10.2 22.5 86.2

 ------------------------------------------------------------$000------------------------------------------------------------ ------------------------------------------------------------$000------------------------------------------------------------

DIRECT FILTRATION PLANTS ONLY:

ONVENTIONAL FILTRATION PLANTS ONLY:

SYSTEM POPULATION SIZE CATEGORY:

em-Level O&M Costs for Recycle Modifications

DIRECT FILTRATION PLANTS ONLY:

L RECYCLE PLANTS (Conventional & Direct):

ONVENTIONAL FILTRATION PLANTS ONLY:

April, 2001
 Capital Costs for All Systems Requiring Modifications for Final FBRR Provision

s

<100 101-500

501-

1,000

1,001-

3,300

3,301-

10,000

Subtotal

Small 

Systems

10,001- 

50,000

50,001-

100,000

100,001-

1,000,000

Subtotal

Large 

Systems Total

488 660 491 967 885 3,490 860 157 135 1,152 4,643454 613 457 899 823 3,246 800 146 126 1,072 4,318

34 46 34 68 62 244 60 11 9 81 325

454 613 457 899 823 3,246 802 a 146 126 1,072 4,318

ks 241.4 662.9 501.0 1312.5 2124.5 4842.3 5393.1 3405.8 28402.2 37201.1 42043.5

34 46 34 68 62 244 60 11 9 81 325

18.2 49.9 37.7 98.8 159.9 364.5 404.9 256.3 2137.8 2799.1 3163.5

259.6 712.8 538.7 1411.3 2284.4 5206.8 5798.1 3662.1 30540.0 40000.2 45207.0

e recycle location costs include two additional plants that belong to systems serving more than one million. (See Section 4.3.4 of the RIA for discussion)

ks

-----------------------------------------------------------------------------------------$000----------------------------------------------------------------------------------------

DIRECT FILTRATION PLANTS ONLY:

-----------------------------------------------------------------------------------------$000----------------------------------------------------------------------------------------

DIRECT FILTRATION PLANTS ONLY:

NTIONAL FILTRATION PLANTS ONLY:

YCLE PLANTS (Conventional & Direct):

NTIONAL FILTRATION PLANTS ONLY:

TEM POPULATION SIZE CATEGORY:

April, 2001
Appendix B

Annualized Capital and O&M Costs

at 3 Percent Discount Rate
al Annualized Capital Costs ($000s) at 3% Discount Rate for Final FBRR Provisions

<100 101-500

501-

1,000

1,001-

3,300

3,301-

10,000

Subtotal

Small 

Systems

10,001- 

50,000

50,001-

100,000

100,001-

1,000,000

Subtotal

Large 

Systems Total

488 660 491 967 885 3,490 860 157 135 1,152 4,643454 613 457 899 823 3,246 800 146 126 1,072 4,318

34 46 34 68 62 244 60 11 9 81 325

454 613 457 899 823 3,246 802 a 146 126 1,072 4,318

rks 16.2 44.6 33.7 88.2 142.8 325.5 362.5 228.9 1909.1 2500.5 2826.0

34 46 34 68 62 244 60 11 9 81 325

1.2 3.4 2.5 6.6 10.7 24.5 27.2 17.2 143.7 188.1 212.6

17.4 47.9 36.2 94.9 153.5 350.0 389.7 246.2 2052.8 2688.6 3038.6

he recycle location costs include two additional plants that belong to systems serving more than one million. (See Section 4.3.4 of the RIA for discussion

rks

DIRECT FILTRATION PLANTS ONLY:

-------------------------------------------------------------------------------------------$000---------------------------------------------------------------------------------------

DIRECT FILTRATION PLANTS ONLY:

-------------------------------------------------------------------------------------------$000---------------------------------------------------------------------------------------

CYCLE PLANTS (Conventional & Direct):

ENTIONAL FILTRATION PLANTS ONLY:

STEM POPULATION SIZE CATEGORY:

ENTIONAL FILTRATION PLANTS ONLY:

April, 2001
al Annual Operation & Maintenance Costs for Final FBRR Provisions

<100 101-500

501-

1,000

1,001-

3,300

3,301-

10,000

Subtotal

Small 

Systems

10,001- 

50,000

50,001-

100,000

100,001-

1,000,000

Subtotal

Large 

Systems Total

488 660 491 967 885 3,490 860 157 135 1,152 4,643454 613 457 899 823 3,246 800 146 126 1,072 4,318

34 46 34 68 62 244 60 11 9 81 325

454 613 457 899 823 3,246 802 a 146 126 1,072 4,318

rks 47.2 68.7 58.5 143.8 210.7 528.9 654.3 263.3 866.3 1784.0 2312.9

34 46 34 68 62 244 60 11 9 81 325

3.6 5.2 4.4 10.8 15.9 39.8 49.1 19.8 65.2 134.2 174.0

50.7 73.9 62.9 154.7 226.6 568.7 703.5 283.1 931.5 1918.1 2486.9

he recycle location costs include two additional plants that belong to systems serving more than one million. (See Section 4.3.4 of the RIA for discussion)

ENTIONAL FILTRATION PLANTS ONLY:

STEM POPULATION SIZE CATEGORY:

-------------------------------------------------------------------------------------------$000--------------------------------------------------------------------------------------

ENTIONAL FILTRATION PLANTS ONLY:

rks

DIRECT FILTRATION PLANTS ONLY:

-------------------------------------------------------------------------------------------$000--------------------------------------------------------------------------------------

DIRECT FILTRATION PLANTS ONLY:

CYCLE PLANTS (Conventional & Direct):

April, 2001
l Annual Costs (Capital and O&M) at 3% Discount Rate for Final FBRR Provisions

<100 101-500

501-

1,000

1,001-

3,300

3,301-

10,000

Subtotal

Small 

Systems

10,001- 

50,000

50,001-

100,000

100,001-

1,000,000

Subtotal

Large 

Systems Total

488 660 491 967 885 3,490 860 157 135 1,152 4,643454 613 457 899 823 3,246 800 146 126 1,072 4,318

34 46 34 68 62 244 60 11 9 81 325

454 613 457 899 823 3,246 802 a 146 126 1,072 4,318

ks 63.4 113.3 92.1 232.1 353.5 854.4 1016.8 492.2 2775.4 4284.5 5138.9

34 46 34 68 62 244 60 11 9 81 325

4.8 8.5 6.9 17.5 26.6 64.3 76.3 37.1 208.9 322.3 386.6

68.2 121.8 99.1 249.5 380.1 918.7 1093.2 529.3 2984.3 4606.8 5525.5

e recycle location costs include two additional plants that belong to systems serving more than one million. (See Section 4.3.4 of the RIA for discussion)

ks

DIRECT FILTRATION PLANTS ONLY:

-----------------------------------------------------------------------------------------$000----------------------------------------------------------------------------------------

DIRECT FILTRATION PLANTS ONLY:

-----------------------------------------------------------------------------------------$000----------------------------------------------------------------------------------------

CYCLE PLANTS (Conventional & Direct):

ENTIONAL FILTRATION PLANTS ONLY:

YSTEM POPULATION SIZE CATEGORY:

ENTIONAL FILTRATION PLANTS ONLY:

April, 2001
Appendix C

Annualized Capital and O&M Costs

at 7 Percent Discount Rate
l Annualized Capital Costs at 7% Discount Rate for Final FBRR Provisions

<100 101-500

501-

1,000

1,001-

3,300

3,301-

10,000

Subtotal

Small 

Systems

10,001- 

50,000

50,001-

100,000

100,001-

1,000,000

Subtotal

Large 

Systems Total

488 660 491 967 885 3,490 860 157 135 1,152 4,643454 613 457 899 823 3,246 800 146 126 1,072 4,318

34 46 34 68 62 244 60 11 9 81 325

454 613 457 899 823 3,246 802 a 146 126 1,072 4,318

ks 22.8 62.6 47.3 123.9 200.5 457.1 509.1 321.5 2681.0 3511.5 3968.6

34 46 34 68 62 244 60 11 9 81 325

1.7 4.7 3.6 9.3 15.1 34.4 38.2 24.2 201.8 264.2 298.6

24.5 67.3 50.8 133.2 215.6 491.5 547.3 345.7 2882.8 3775.7 4267.2

e recycle location costs include two additional plants that belong to systems serving more than one million. (See Section 4.3.4 of the RIA for discussion)

ks

DIRECT FILTRATION PLANTS ONLY:

----------------------------------------------------------------------------------------$000---------------------------------------------------------------------------------------

DIRECT FILTRATION PLANTS ONLY:

----------------------------------------------------------------------------------------$000---------------------------------------------------------------------------------------

ECYCLE PLANTS (Conventional & Direct):

VENTIONAL FILTRATION PLANTS ONLY:

YSTEM POPULATION SIZE CATEGORY:

VENTIONAL FILTRATION PLANTS ONLY:

April, 2001
al Annual Operation & Maintenance Costs for Final FBRR Provisions

<100 101-500

501-

1,000

1,001-

3,300

3,301-

10,000

Subtotal

Small 

Systems

10,001- 

50,000

50,001-

100,000

100,001-

1,000,000

Subtotal

Large 

Systems Total

488 660 491 967 885 3,490 860 157 135 1,152 4,643454 613 457 899 823 3,246 800 146 126 1,072 4,318

34 46 34 68 62 244 60 11 9 81 325

454 613 457 899 823 3,246 802 a 146 126 1,072 4,318

rks 47.2 68.7 58.5 143.8 210.7 528.9 654.3 263.3 866.3 1784.0 2312.9

34 46 34 68 62 244 60 11 9 81 325

3.6 5.2 4.4 10.8 15.9 39.8 49.1 19.8 65.2 134.2 174.0

50.7 73.9 62.9 154.7 226.6 568.7 703.5 283.1 931.5 1918.1 2486.9

he recycle location costs include two additional plants that belong to systems serving more than one million. (See Section 4.3.4 of the RIA for discussion)

ENTIONAL FILTRATION PLANTS ONLY:

STEM POPULATION SIZE CATEGORY:

-------------------------------------------------------------------------------------------$000--------------------------------------------------------------------------------------

ENTIONAL FILTRATION PLANTS ONLY:

rks

DIRECT FILTRATION PLANTS ONLY:

-------------------------------------------------------------------------------------------$000--------------------------------------------------------------------------------------

DIRECT FILTRATION PLANTS ONLY:

CYCLE PLANTS (Conventional & Direct):

April, 2001
l AnnualCosts (Capital and O&M) at 7% Discount Rate for Final FBRR Provisions

<100 101-500

501-

1,000

1,001-

3,300

3,301-

10,000

Subtotal

Small 

Systems

10,001- 

50,000

50,001-

100,000

100,001-

1,000,000

Subtotal

Large 

Systems Total

488 660 491 967 885 3,490 860 157 135 1,152 4,643454 613 457 899 823 3,246 800 146 126 1,072 4,318

34 46 34 68 62 244 60 11 9 81 325

454 613 457 899 823 3,246 802 a 146 126 1,072 4,318

ks 70.0 131.3 105.8 267.7 411.3 986.0 1163.4 584.8 3547.3 5295.5 6281.5

34 46 34 68 62 244 60 11 9 81 325

5.3 9.9 8.0 20.2 31.0 74.2 87.4 44.0 267.0 398.4 472.6

75.2 141.2 113.7 287.9 442.2 1060.2 1250.8 628.8 3814.3 5693.8 6754.1

e recycle location costs include two additional plants that belong to systems serving more than one million. (See Section 4.3.4 of the RIA for discussion)

ks

DIRECT FILTRATION PLANTS ONLY:

----------------------------------------------------------------------------------------$000---------------------------------------------------------------------------------------

DIRECT FILTRATION PLANTS ONLY:

----------------------------------------------------------------------------------------$000---------------------------------------------------------------------------------------

CYCLE PLANTS (Conventional & Direct):

ENTIONAL FILTRATION PLANTS ONLY:

YSTEM POPULATION SIZE CATEGORY:

ENTIONAL FILTRATION PLANTS ONLY:

April, 2001
Appendix D

Annualized Capital and O&M Costs

in Cents per Thousand Gallons
lized System-Level Capital Costs (cents/kilogallon) at 7% Discount Rate for Final FBRR Provisions

<100 101-500

501-

1,000

1,001-

3,300

3,301-

10,000

10,001- 

50,000

50,001-

100,000

100,001-

1,000,000

488 660 491 967 885 860 157 135454 613 457 899 823 800 146 126

34 46 34 68 62 60 11 9

454 613 457 899 823 802 a 146 126

s 7.7 4.0 1.5 0.8 0.5 0.3 0.4 0.9

34 46 34 68 62 60 11 9

7.7 4.0 1.5 0.8 0.5 0.3 0.4 0.9

IRECT FILTRATION PLANTS ONLY:

-------------------------------------------------------------cents---------------------------------------------------------

CLE PLANTS (Conventional & Direct):

IONAL FILTRATION PLANTS ONLY:

EM POPULATION SIZE CATEGORY:

IONAL FILTRATION PLANTS ONLY:

 recycle location costs include two additional plants that belong to systems serving more than one million. (See Section 4.3.4 of the 

IRECT FILTRATION PLANTS ONLY:

s

-------------------------------------------------------------cents---------------------------------------------------------

April 2001
ualized System-Level Capital Costs (cents/kilogallon) at 3% Discount Rate for Final FBRR Provisions

<100 101-500

501-

1,000

1,001-

3,300

3,301-

10,000

10,001- 

50,000

50,001-

100,000

100,001-

1,000,000

488 660 491 967 885 860 157 135454 613 457 899 823 800 146 126

34 46 34 68 62 60 11 9

454 613 457 899 823 802 a 146 126

rks 5.5 2.8 1.1 0.6 0.3 0.2 0.3 0.6

34 46 34 68 62 60 11 9

5.5 2.8 1.1 0.6 0.3 0.2 0.3 0.6

DIRECT FILTRATION PLANTS ONLY:

-----------------------------------------------------------------cents-------------------------------------------------------------

he recycle location costs include two additional plants that belong to systems serving more than one million. (See Section 4.3.4 of the RIA for 

rks

DIRECT FILTRATION PLANTS ONLY:

-----------------------------------------------------------------cents-------------------------------------------------------------

CYCLE PLANTS (Conventional & Direct):

ENTIONAL FILTRATION PLANTS ONLY:

STEM POPULATION SIZE CATEGORY:

ENTIONAL FILTRATION PLANTS ONLY:

April 2001
ual System-Level O&M Costs (cents/kilogallon) for Final FBRR Provisions

<100 101-500

501-

1,000

1,001-

3,300

3,301-

10,000

10,001- 

50,000

50,001-

100,000

100,001-

1,000,000

488 660 491 967 885 860 157 135454 613 457 899 823 800 146 126

34 46 34 68 62 60 11 9

454 613 457 899 823 802 a 146 126

rks 51.3 13.9 5.9 2.6 1.2 0.9 0.6 0.6

34 46 34 68 62 60 11 9

51.3 13.9 5.9 2.6 1.2 0.9 0.6 0.6

DIRECT FILTRATION PLANTS ONLY:

------------------------------------------------------------------cents--------------------------------------------------------------

he recycle location costs include two additional plants that belong to systems serving more than one million. (See Section 4.3.4 of the RIA for 

rks

DIRECT FILTRATION PLANTS ONLY:

------------------------------------------------------------------cents--------------------------------------------------------------

CYCLE PLANTS (Conventional & Direct):

ENTIONAL FILTRATION PLANTS ONLY:

STEM POPULATION SIZE CATEGORY:

ENTIONAL FILTRATION PLANTS ONLY:

April 2001
l Annual System-Level Costs (Capital and O&M) at 3% Discount Rate for Final FBRR Provisions (cents/kgal)

<100 101-500

501-

1,000

1,001-

3,300

3,301-

10,000

10,001- 

50,000

50,001-

100,000

100,001-

1,000,000

488 660 491 967 885 860 157 135454 613 457 899 823 800 146 126

34 46 34 68 62 60 11 9

454 613 457 899 823 802 a 146 126

rks 56.8 16.8 6.9 3.1 1.5 1.1 0.9 1.2

34 46 34 68 62 60 11 9

56.8 16.8 6.9 3.1 1.5 1.1 0.9 1.2

CYCLE PLANTS (Conventional & Direct):

ENTIONAL FILTRATION PLANTS ONLY:

STEM POPULATION SIZE CATEGORY:

he recycle location costs include two additional plants that belong to systems serving more than one million. (See Section 4.3.4 of the RIA for 

ENTIONAL FILTRATION PLANTS ONLY:

DIRECT FILTRATION PLANTS ONLY:

-----------------------------------------------------------------cents-------------------------------------------------------------

rks

DIRECT FILTRATION PLANTS ONLY:

-----------------------------------------------------------------cents-------------------------------------------------------------

April 2001
l Annual System-Level Costs (Capital and O&M) at 7% Discount Rate for Final FBRR Provisions (cents/kgal)

<100 101-500

501-

1,000

1,001-

3,300

3,301-

10,000

10,001- 

50,000

50,001-

100,000

100,001-

1,000,000

488 660 491 967 885 860 157 135454 613 457 899 823 800 146 126

34 46 34 68 62 60 11 9

454 613 457 899 823 802 a 146 126

rks 59.1 17.9 7.4 3.4 1.6 1.2 1.0 1.4

34 46 34 68 62 60 11 9

59.1 17.9 7.4 3.4 1.6 1.2 1.0 1.4

CYCLE PLANTS (Conventional & Direct):

ENTIONAL FILTRATION PLANTS ONLY:

STEM POPULATION SIZE CATEGORY:

he recycle location costs include two additional plants that belong to systems serving more than one million. (See Section 4.3.4 of the RIA for 

ENTIONAL FILTRATION PLANTS ONLY:

DIRECT FILTRATION PLANTS ONLY:

------------------------------------------------------------------cents--------------------------------------------------------------

rks

DIRECT FILTRATION PLANTS ONLY:

------------------------------------------------------------------cents--------------------------------------------------------------

April 2001
Appendix E

System and State Reporting and 

Record Keeping Costs
System Population Size Category: <1,000 1,001-3,300 3,301-10,000 10,001 - 1 milliona Totala Annualized Costsb

Systems Expected to Move Return Location: 131 77 71 94 373

Systems Requesting a Waiver: 33 19 18 23 93

vities

o State $7,603 $5,320 $4,872 $11,211 $29,007

$1,901 $1,330 $1,218 $2,803 $7,252

$475 $333 $304 $701 $1,813

$9,979 $6,983 $6,394 $14,715 $38,071 $2,559

ation Requests $6,104 $3,601 $3,297 $4,293 $17,295

$3,052 $1,800 $1,649 $2,146 $8,647

$763 $450 $412 $537 $2,162

$9,919 $5,851 $5,358 $6,976 $28,104 $1,889

$66,175 $4,448

g to systems serving more than 1 million people.

alization factor (CF) of 0.06722. The CF is calculated using the discount rate (3%) and the number of years of capitalization (20 years).

Appendix E-1a

System and State Costs for New Return Location at 3% Discount Rate, Alternative R2

April 2001
System PopulationSize Category: <1,000 1,001-3,300 3,301-10,000 10,001 - 1 milliona Totala Annualized Costsb

Systems Expected to Move Return Location: 131 77 71 94 373

Systems Requesting a Waiver: 33 19 18 23 93

vities

o State $7,603 $5,320 $4,872 $11,211 $29,007

$1,901 $1,330 $1,218 $2,803 $7,252

$475 $333 $304 $701 $1,813

$9,979 $6,983 $6,394 $14,715 $38,071 $3,594

ation Requests $6,104 $3,601 $3,297 $4,293 $17,295

$3,052 $1,800 $1,649 $2,146 $8,647

$763 $450 $412 $537 $2,162

$9,919 $5,851 $5,358 $6,976 $28,104 $2,653

$66,175 $6,246

g to systems serving more than 1 million people.

alization factor (CF) of 0.09439. The CF is calculated using the discount rate (7%) and the number of years of capitalization (20 years).

Appendix E-1b

System and State Costs for New Return Location at 7% Discount Rate, Alternative R2

April 2001
Hrs./ Annual Rate/ Rate/

Freq. Freq. Hours Hrs. Hour Cost Hrs. Hour Cost Costs FTEb

Activities

Submit Alternate Location Requests to State 1 16 16 0 $0.00 $0 16 $14.50 $232 $232 0.01

Consult with State 1 4 4 0 $0.00 $0 4 $14.50 $58 $58 0.00

Recordkeeping 1 1 1 0 $0.00 $0 1 $14.50 $15 $15 0.00

Total Cost per System $0 $305 $305 0.01 

Hrs./ Annual Rate/ Rate/

Freq. Freq. Hours Hrs. Hour Cost Hrs. Hour Cost Costs FTEb

Activities

Submit Alternate Location Requests to State 1 16 16 3.2 $28.00 $90 12.8 $14.50 $186 $275 0.01

Consult with State 1 4 4 0.8 $28.00 $22 3.2 $14.50 $46 $69 0.00

Recordkeeping 1 1 1 0.2 $28.00 $6 0.8 $14.50 $12 $17 0.00

Total Cost per System $118 $244 $361 0.01 

Hrs./ Annual Rate/ Rate/

Freq. Freq. Hours Hrs. Hour Cost Hrs. Hour Cost Costs FTEb

Activities

Submit Alternate Location Requests to State 1 16 16 3.2 $28.00 $90 12.8 $14.50 $186 $275 0.01

Consult with State 1 4 4 0.8 $28.00 $22 3.2 $14.50 $46 $69 0.00

Recordkeeping 1 1 1 0.2 $28.00 $6 0.8 $14.50 $12 $17 0.00

Total Cost per System $118 $244 $361 0.01 

Hrs./ Annual Rate/ Rate/

Freq. Freq. Hours Hrs. Hour Cost Hrs. Hour Cost Costs FTEb

Activities

Submit Alternate Location Requests to State 1 16 16 3.2 $40.00 $128 12.8 $28.00 $358 $486 0.01

Consult with State 1 4 4 0.8 $40.00 $32 3.2 $28.00 $90 $122 0.00

Recordkeeping 1 1 1 0.2 $40.00 $8 0.8 $28.00 $22 $30 0.00

Total Cost per System $168 $470 $638 0.01 

a. Labor is split between management and technical. Generally, 20% is allocated to management and 80% to technical.

Alternative R2

Detail of System Activities, System Size: <1,000

Appendix E1c

System Reporting Activities and Burden for New Return Location

Managementa Technicala Total Burden

Detail of System Activities, System Size: 1,000-3,300

Managementa Technicala Total Burden

Detail of System Activities, System Size: 3,300-10,000

Alternative R2

Managementa Technicala Total Burden

Detail of System Activities, System Size: 10,000-1 million

Alternative R2

Managementa Technicala Total Burden

FBRR Final RIA April 2001
ce Activities

Hrs./ Annual Rate/ Rate/

Freq. Freq. Hours Hrs. Hour Cost Hrs. Hour Cost Total Cost FTEb

te Location Requests 1 8 8 1.6 $31.23 $50 6.4 21.29 $ $136 $186 0.004

1 4 4 0.8 $31.23 $25 3.2 21.29 $ $68 $93 0.002

1 1 1 0.2 $31.23 $6 0.8 21.29 $ $17 $23 0.0005

93 Systems $303 0.006

$28,104 0.58

view Costs (3%)c $1,889

view Costs (7%)c $2,653

gement and technical. Generally, 20% is allocated to management and 80% to technical.

s based on 2080 hours worked annually.

ized by a capitalization factor (CF) of 0.06722 or 0.9439. The CF is calculated using the discount rate (3% or 7%) and the number of year

Total Burden

Appendix E-1d

State Reporting Activities for New Return Location

Activity Frequency Management Labora Technical Labora

April 2001
System Population Size Category: <1,000 1,001-3,300 3,301-10,000 10,001 - 1 milliona Totala Annualized Costsb

Systems Preparing Recycle Reports: 1524 899 823 1075 4321

vities

ows $132,578 $92,776 $84,954 $196,043 $506,351

$176,770 $123,702 $113,271 $261,391 $675,134

$22,096 $15,463 $14,159 $32,674 $84,392

$331,445 $231,940 $212,384 $490,108 $1,265,877 $85,092

$141,913 $83,719 $76,661 $100,091 $402,384

$70,956 $41,860 $38,330 $50,046 $201,192

$5,913 $3,488 $3,194 $4,170 $16,766

$218,782 $129,067 $118,185 $154,307 $620,342 $41,699

porting Costs $550,227 $361,008 $330,569 $644,415 $1,886,219 $126,792

ong to systems serving more than 1 million people.

alization factor (CF) of 0.06722. The CF is calculated using the discount rate (3%) and the number of years of capitalization (20 years).

Appendix E-2a

ystem and State Conventional Filtration Recycle Reporting Costs at 3% Discount Rate, Alternative R2

April 2001
System Population Size Category: <1,000 1,001-3,300 3,301-10,000 10,001 - 1 milliona Totala Annualized Costsb

Systems Preparing Recycle Reports: 1524 899 823 1075 4321

vities

ows $132,578 $92,776 $84,954 $196,043 $506,351

$176,770 $123,702 $113,271 $261,391 $675,134

$22,096 $15,463 $14,159 $32,674 $84,392

$331,445 $231,940 $212,384 $490,108 $1,265,877 $119,486

$141,913 $83,719 $76,661 $100,091 $402,384

$70,956 $41,860 $38,330 $50,046 $201,192

$5,913 $3,488 $3,194 $4,170 $16,766

$218,782 $129,067 $118,185 $154,307 $620,342 $58,554

porting Costs $550,227 $361,008 $330,569 $644,415 $1,886,219 $178,040

ong to systems serving more than 1 million people.

alization factor (CF) of 0.09439. The CF is calculated using the discount rate (7%) and the number of years of capitalization (20 years).

Appendix E-2b

ystem and State Conventional Filtration Recycle Reporting Costs at 7% Discount Rate, Alternative R2

April 2001
Total

Hrs./ Total Rate/ Rate/

Freq. Freq. Hours Hrs. Hour Cost Hrs. Hour Cost Costs

Recycle Reporting Activiites

Report Recycle Status, Schematic, Flows 1 6 6 0 $0.00 $0 6 $14.50 $87 $87

Collect Additional Recycle Data 1 8 8 0 $0.00 $0 8 $14.50 $116 $116

Recordkeeping 1 1 1 0 $0.00 $0 1 $14.50 $15 $15

Total Cost per System $0 $218 $218

Total

Hrs./ Total Rate/ Rate/

Freq. Freq. Hours Hrs. Hour Cost Hrs. Hour Cost Costs

Recycle Reporting Activiites

Report Recycle Status, Schematic, Flows 1 6 6 1.2 $28.00 $34 4.8 $14.50 $70 $103

Collect Additional Recycle Data 1 8 8 1.6 $28.00 $45 6.4 $14.50 $93 $138

Recordkeeping 1 1 1 0.2 $28.00 $6 0.8 $14.50 $12 $17

Total Cost per System $84 $174 $258

Total

Hrs./ Total Rate/ Rate/

Freq. Freq. Hours Hrs. Hour Cost Hrs. Hour Cost Costs

Recycle Reporting Activiites

Report Recycle Status, Schematic, Flows 1 6 6 1.2 $28.00 $34 4.8 $14.50 $70 $103

Collect Additional Recycle Data 1 8 8 1.6 $28.00 $45 6.4 $14.50 $93 $138

Recordkeeping 1 1 1 0.2 $28.00 $6 0.8 $14.50 $12 $17

Total Cost per System $84 $174 $258

Total

Hrs./ Total Rate/ Rate/

Freq. Freq. Hours Hrs. Hour Cost Hrs. Hour Cost Costs

Recycle Reporting Activiites

Report Recycle Status, Schematic, Flows 1 6 6 1.2 $40.00 $48 4.8 $28.00 $134 $182

Collect Additional Recycle Data 1 8 8 1.6 $40.00 $64 6.4 $28.00 $179 $243

Recordkeeping 1 1 1 0.2 $40.00 $8 0.8 $28.00 $22 $30

Total Cost per System $120 $336 $456

a. Labor is split between management and technical. Generally, 20% is allocated to management and 80% to technical.

Managementa Technicala

Appendix E-2c

System Conventional Filtration Recycle Reporting Activities and Burden

Detail of System Activities, System Size: <1,000

Alternative R2

Detail of System Activities, System Size: 3,301-10,000

Technicala Managementa

Detail of System Activities, System Size: 1,001-3,300

Detail of System Activities, System Size: 10,001-1 million

Managementa Technicala

Managementa Technicala

FBRR Final RIA April 2001
ce Activities

Hrs./ Annual Rate/ Rate/

Freq. Freq. Hours Hrs. Hour Cost Hrs. Hour Cost Total Cost FTEb

r System

1 4 4 0.8 $31.23 $25 3.2 21.29 $ $68 $93 0.002

1 2 2 0.4 $31.23 $12 1.6 21.29 $ $34 $47 0.001

1 0.17 0.17 0.03 $31.23 $1 0.13 21.29 $ $3 $4 0.000

4321 Systems $144 0.003

ts $620,342 12.46

porting Costs (3%)c $41,699porting Costs (7%)c $58,554

gement and technical. Generally, 20% is allocated to management and 80% to technical.

s based on 2080 hours worked annually.

ized by a capitalization factor (CF) of 0.06722 or 0.9439. The CF is calculated using the discount rate (3% or 7%) and the number of year

Total Burden

Appendix E-2d

onventional Filtration Recycle Reporting Activities and Burden, Alternative R2

Activity Frequency Management Labora Technical Labora

April 2001
System Population Size Category: <1,000 1,001-3,300 3,301-10,000 10,001 - 1 milliona Totala Annualized Costsc

tration Systems Reporting Recycling Practices: 115 68 62 85 329

vities

ows $9,979 $6,983 $6,394 $15,444 $38,801

$13,305 $9,311 $8,526 $20,592 $51,734

$1,663 $1,164 $1,066 $2,574 $6,467

$24,947 $17,458 $15,986 $38,611 $97,002 $6,520

$10,682 $6,301 $5,770 $7,885 $30,638

$5,341 $3,151 $2,885 $3,943 $15,319

$445 $263 $240 $329 $1,277

$16,467 $9,715 $8,896 $12,156 $47,234 $3,175

porting Costs $41,415 $27,173 $24,882 $50,767 $144,236 $9,696

ong to systems serving more than 1 million people.

alization factor (CF) of 0.06722. The CF is calculated using the discount rate (3%) and the number of years of capitalization (20 years).

Appendix E-3a

System and State Direct Filtration Recycle Reporting Costs at 3% Discount Rate, Alternative R2

April 2001
System Population Size Category: <1,000 1,001-3,300 3,301-10,000 10,001 - 1 milliona Totala Annualized Costsc

tration Systems Reporting Recycling Practices: 115 68 62 85 329

vities

ows $9,979 $6,983 $6,394 $15,444 $38,801

$13,305 $9,311 $8,526 $20,592 $51,734

$1,663 $1,164 $1,066 $2,574 $6,467

$24,947 $17,458 $15,986 $38,611 $97,002 $9,156

$10,682 $6,301 $5,770 $7,885 $30,638

$5,341 $3,151 $2,885 $3,943 $15,319

$445 $263 $240 $329 $1,277

$16,467 $9,715 $8,896 $12,156 $47,234 $4,458

porting Costs $41,415 $27,173 $24,882 $50,767 $144,236 $13,614

ong to systems serving more than 1 million people.

alization factor (CF) of 0.09439. The CF is calculated using the discount rate (7%) and the number of years of capitalization (20 years).

Appendix E-3b

System and State Direct Filtration Recycle Reporting Costs at 7% Discount Rate, Alternative R2

April 2001
Hrs./ Annual Rate/ Rate/

Freq. Freq. Hours Hrs. Hour Cost Hrs. Hour Cost Costs FTEb

Recycle Reporting Activiites

Report Recycle Status, Schematic, Flows 1 6 6 0 $0.00 $0 6 $14.50 $87 $87 0.00

Collect Additional Recycle Data 1 8 8 0 $0.00 $0 8 $14.50 $116 $116 0.00

Recordkeeping 1 1 1 0 $0.00 $0 1 $14.50 $15 $15 0.00

Total Cost per System $0 $218 $218 0.01 

Hrs./ Annual Rate/ Rate/

Freq. Freq. Hours Hrs. Hour Cost Hrs. Hour Cost Costs FTEb

Recycle Reporting Activiites

Report Recycle Status, Schematic, Flows 1 6 6 1.2 $28.00 $34 4.8 $14.50 $70 $103 0.00

Collect Additional Recycle Data 1 8 8 1.6 $28.00 $45 6.4 $14.50 $93 $138 0.00

Recordkeeping 1 1 1 0.2 $28.00 $6 0.8 $14.50 $12 $17 0.00

Total Cost per System $84 $174 $258 0.01 

Hrs./ Annual Rate/ Rate/

Freq. Freq. Hours Hrs. Hour Cost Hrs. Hour Cost Costs FTEb

Recycle Reporting Activiites

Report Recycle Status, Schematic, Flows 1 6 6 1.2 $28.00 $34 4.8 $14.50 $70 $103 0.00

Collect Additional Recycle Data 1 8 8 1.6 $28.00 $45 6.4 $14.50 $93 $138 0.00

Recordkeeping 1 1 1 0.2 $28.00 $6 0.8 $14.50 $12 $17 0.00

Total Cost per System $84 $174 $258 0.01 

Hrs./ Annual Rate/ Rate/

Freq. Freq. Hours Hrs. Hour Cost Hrs. Hour Cost Costs FTEb

Recycle Reporting Activiites

Report Recycle Status, Schematic, Flows 1 6 6 1.2 $40.00 $48 4.8 $28.00 $134 $182 0.00

Collect Additional Recycle Data 1 8 8 1.6 $40.00 $64 6.4 $28.00 $179 $243 0.00

Recordkeeping 1 1 1 0.2 $40.00 $8 0.8 $28.00 $22 $30 0.00

Total Cost per System $120 $336 $456 0.01 

a. Labor is split between management and technical. Generally, 20% is allocated to management and 80% to technical.

Detail of System Activities, System Size: 10,000-1 million

Alternative R2

Management a Technical a Total Burden

Management a Technical a Total Burden

Detail of System Activities, System Size: 3,300-10,000

Alternative R2

Detail of System Activities, System Size: 1,000-3,300

Alternative R2

Management a Technical a Total Burden

Management a Technical a Total Burden

Alternative R2

Detail of System Activities, System Size: <1,000

Appendix E3c

System Direct Filtration Recycle Reporting Activities and Burden

FBRR Final RIA April 2001
ce Activities

Hrs./ Annual Rate/ Rate/

Freq. Freq. Hours Hrs. Hour Cost Hrs. Hour Cost Total Cost FTEb

r System

1 4 4 0.8 $31.23 $25 3.2 21.29 $ $68 $93 0.002

1 2 2 0.4 $31.23 $12 1.6 21.29 $ $34 $47 0.001

1 0.17 0.17 0.03 $31.23 $1 0.13 21.29 $ $3 $4 0.000

329 Systems $144 0.003

ts $47,234 0.95

porting Costs (3%)c $3,175

porting Costs (7%)c $4,458

gement and technical. Generally, 20% is allocated to management and 80% to technical.

s based on 2080 hours worked annually.

ized by a capitalization factor (CF) of 0.06722 or 0.9439. The CF is calculated using the discount rate (3% or 7%) and the number of year

f money ($1).

Total Burden

Appendix E-3d

rect Filtration Recycle Reporting Review Activities and Burden, Alternative R2

Activity Frequency Management Labora Technical Labora

April 2001
Compliance Activities

Hrs./ Annual Rate/ Rate/

Freq. Freq. Hours Hrs. Hour Cost Hrs. Hour Cost Total Cost FTEb

STATES

Start-up Costs

Reg Adoption/Program Development 1 200 200 40 $31.23 $1,249 160 21.29 $ $3,407 $4,656 0.10

Miscellaneous training 1 60 60 12 $31.23 $375 48 21.29 $ $1,022 $1,397 0.03

Subtotal 56 States $6,053 0.13

SYSTEMS

Hrs./ Annual Rate/ Rate/

Freq. Freq. Hours Hrs. Hour Cost Hrs. Hour Cost Costs FTEb

Start-up Cost per System

Read & Understand Rule 1 8 8 0 $0.00 $0 8 $14.50 $116 $116 0.00

Mobilization/Planning 1 16 16 0 $0.00 $0 16 $14.50 $232 $232 0.01

Subtotal 1639 Systems $348 0.01

Hrs./ Annual Rate/ Rate/

Freq. Freq. Hours Hrs. Hour Cost Hrs. Hour Cost Costs FTEb

Start-up Cost per System

Read & Understand Rule 1 8 8 1.6 $28.00 $45 6.4 $14.50 $93 $138 0.00

Mobilization/Planning 1 16 16 3.2 $28.00 $90 12.8 $14.50 $186 $275 0.01

Subtotal 967 Systems $413 0.01

Hrs./ Annual Rate/ Rate/

Freq. Freq. Hours Hrs. Hour Cost Hrs. Hour Cost Costs FTEb

Start-up Cost per System

Read & Understand Rule 1 8 8 1.6 $28.00 $45 6.4 $14.50 $93 $138 0.00

Mobilization/Planning 1 16 16 3.2 $28.00 $90 12.8 $14.50 $186 $275 0.01

Subtotal 885 Systems $413 0.01

Hrs./ Annual Rate/ Rate/

Freq. Freq. Hours Hrs. Hour Cost Hrs. Hour Cost Costs FTEb

Start-up Cost per System

Read & Understand Rule 1 8 8 1.6 $40.00 $64 6.4 $28.00 $179 $243 0.00

Mobilization/Planning 1 16 16 3.2 $40.00 $128 12.8 $28.00 $358 $486 0.01

Subtotal 1159 Systems $730 0.01

Total State Start-Up Costs 56 States $338,978 7.00

Total System Start-Up Costs 4650 Systems $2,180,606 53.65

State Annualized Start-Up Costs (3%)c $22,786

State Annualized Start-Up Costs (7%)c $31,996

System Annualized Start-Up Costs (3%)c $146,580

System Annualized Start-Up Costs (7%)c $205,827

Total Start Up Costs $2,519,584 53.78

Total Annualized Start-Up Costs (3%)c $169,366

Total Annualized Start-Up Costs (7%)c $237,824

Notes:

a. Labor rates include a load facter of 1.4.

b. Full Time Equivalent (FTE) is based on 2080 hours worked annually.

d. Number of conventional filtration systems expected to require different recycle return location.

Total Burden

Appendix E-4

State and System Start-Up Activities

Activity Frequency Management Labora Technical Labora

Detail of System Activities, System Size: <1,000

Managementa,b Technicala Total Burden

Managementa,b Technicala Total Burden

Detail of System Activities, System Size: 1,000-3,300

Alternative R2

Detail of System Activities, System Size: 10,000-1 million

Alternative R2

Detail of System Activities, System Size: 3,300-10,000

Alternative R2

Managementa,b Technicala Total Burden

c. All start-up costs are annualized by a capitalization factor (CF) of 0.06722 or 0.9439. The CF is calculated using the discount rate (3% or 7%) and the number of 

years of capitalization (20 years).

Managementa,b Technicala Total Burden

FBRR Final RIA April 2001
Appendix F

Calculation of Average Household Costs
Constants and Assumptions

92,228,739

eet conventional or direct reporting requirements only. 90.00%eet conventional or direct reporting requirements plus apply for a waiver. 2.00%eet conventional OR direct reporting requirements plus move recycle return location. 8.00%

cted System Processes

Filtration Direct/Conventional Recycle

78.50% 38.00% 60.00%71.00% 55.00% 60.00%79.30% 73.00% 60.00%81.70% 77.00% 60.00%86.50% 90.00% 60.00%96.30% 92.00% 60.00%88.00% 98.00% 60.00%93.40% 92.00% 60.00%93.40% 92.00% 60.00%

us Data

F - 1 April 2001
System Population Data by Size Category and Water Source*

Surface Water GWUDI GW All Systems

m Size

55,600 5,850 859,777 921,227

0 544,621 25,827 3,741,017 4,311,46500 889,855 31,594 3,457,163 4,378,612

3,300 4,679,394 118,461 10,631,422 15,429,277

 10,000 10,770,339 225,641 14,095,015 25,090,995

 - 50,000 36,496,803 322,772 25,004,779 61,824,354-100,000 20,440,370 60,000 8,609,455 29,109,8250-1,000,000 64,955,183 420,000 14,575,556 79,950,739

28,658,586 0 2,855,494 31,514,080

167,490,751 1,210,145 83,829,678 252,530,574

ce: Drinking Water Baseline Handbook

F - 2 April 2001
Household Calculations for Surface and GWUDI Systems that Recycle by System Size

GWUDI GW All Systems

Affected SW and GWUDI Systems (Recycle, Filtration, and Direct/Conventional)

Households Percent Households Percent Households Percent Households Households

% 20,306 0.00% 2,137 0.34% 314,006 0.36% 336,449 4,017% 198,905 0.01% 9,432 1.48% 1,366,287 1.71% 1,574,625 48,814% 324,991 0.01% 11,539 1.37% 1,262,619 1.73% 1,599,148 116,888% 1,708,999 0.05% 43,264 4.21% 3,882,788 6.11% 5,635,051 661,399% 3,933,523 0.09% 82,408 5.58% 5,147,755 9.94% 9,163,686 1,875,841

% 13,329,293 0.13% 117,882 9.90% 9,132,198 24.48% 22,579,374 7,148,196

% 7,465,193 0.02% 21,913 3.41% 3,144,329 11.53% 10,631,435 3,874,128

% 23,722,809 0.17% 153,392 5.77% 5,323,257 31.66% 29,199,458 12,309,805% 10,466,635 0.00% 0 1.13% 1,042,878 12.48% 11,509,513 5,396,262% 61,170,656 0.48% 441,967 33.20% 30,616,117 100% 92,228,739 31,435,350

F - 3 April 2001
Annual Consumption by Regulatory Outcome and System Size

Households Household Consumption (kgal/year)

e Total Report Only Report plus 

Waiver

Report and 

Move

Average 

Annual*

Report Only 

(Total)

Report plus 

Waiver (Total)

Report and 

Move (Total)

4,017 3,615 80 321 123 444,658 9,881 39,525

48,814 43,932 976 3,905 99 4,349,290 96,651 386,604

116,888 105,199 2,338 9,351 104 10,940,741 243,128 972,510661,399 595,259 13,228 52,912 87 51,787,532 1,150,834 4,603,336

1,875,841 1,688,257 37,517 150,067 97 163,760,953 3,639,132 14,556,529

0 7,148,196 6,433,376 142,964 571,856 109 701,238,010 15,583,067 62,332,2680 3,874,128 3,486,715 77,483 309,930 119 414,919,144 9,220,425 36,881,702

000 12,309,805 11,078,825 246,196 984,784 125 1,384,853,072 30,774,513 123,098,051

5,396,262 4,856,636 107,925 431,701 125 607,079,461 13,490,655 53,962,619

31,435,350 28,291,815 628,707 2,514,828 3,339,372,862 74,208,286 296,833,143

nking Water Baseline Handbook

F - 4 April 2001
Size Report (Cost/kgal) Report plus Waiver (Cost/kgal) Report and Move (Cost/kgal) Report (Cost/Household) Report plus Waiver (Cost/Household) Report and Move (Cost/Household)

$0.2232 $0.3148 $0.7916 $27.46 $38.72 $97.37$0.0563 $0.0795 $0.2241 $5.58 $7.87 $22.18$0.0207 $0.0292 $0.0900 $2.16 $3.04 $9.36$0.0086 $0.0122 $0.0400 $0.75 $1.06 $3.48

00 $0.0025 $0.0035 $0.0175 $0.24 $0.34 $1.70000 $0.0011 $0.0015 $0.0123 $0.12 $0.16 $1.34000 $0.0003 $0.0005 $0.0092 $0.04 $0.05 $1.1000,000 $0.0001 $0.0001 $0.0120 $0.01 $0.01 $1.49

$0.0001 $0.0001 $0.0120 $0.01 $0.01 $1.49

Annual Costs by Regulatory Outcome and System Size

F - 5 April 2001
Appendix G

Baseline Data
Appendix G. Baseline Data

0-100 101-500 501-1000 1,001-3,300 3,301 - 9,999 10,001 - 50,000 50,001-100,000 100,001-1M 1 mill+ Total <10,000 Total >10K Total

996 1,899 1,178 2,356 1,802 1,592 299 259 13 8,231 2,163 10,394

1,308 491 85 58 28 7 3 0 0 1,970 10 1,980

261 284 102 79 22 4 1 1 0 748 6 754

2,565 2,674 1,365 2,493 1,852 1,603 303 260 13 10,949 2,179 13,128

96 104 42 64 42 15 1 2 0 348 18 366

55 26 3 3 0 0 0 0 0 87 0 87

10 11 4 1 1 0 0 0 0 27 0 27

161 141 49 68 43 15 1 2 0 462 18 480

1,092 2,003 1,220 2,420 1,844 1,607 300 261 0 8,579 2,168 10,760

1,363 517 88 61 28 7 3 0 0 2,057 10 2,067

271 295 106 80 23 4 1 1 0 775 6 781

2,726 2,815 1,414 2,561 1,895 1,618 304 262 0 11,411 2,184 13,608

55,600 544,621 889,855 4,679,394 10,770,339 36,496,803 20,440,370 64,955,183 28,658,586 16,939,809 150,550,942 167,490,751

57,445 119,180 64,476 102,909 155,833 148,030 179,240 0 0 499,843 327,270 827,113

13,339 76,151 77,693 142,987 119,104 118,000 93,204 152,079 0 429,274 363,283 792,557

126,384 739,952 1,032,024 4,925,290 11,045,276 36,762,833 20,712,814 65,107,262 28,658,586 17,868,926 151,241,495 169,110,421

5,850 25,827 31,594 118,461 225,641 322,772 60,000 420,000 0 407,373 802,772 1,210,145

2,470 5,002 1,935 6,151 0 0 0 0 0 15,558 0 15,558

434 2,283 3,003 1,537 5,700 0 0 0 0 12,957 0 12,957

8,754 33,112 36,532 126,149 231,341 322,772 60,000 420,000 0 435,888 802,772 1,238,660

61,450 570,448 921,449 4,797,855 10,995,980 36,819,575 20,500,370 65,375,183 28,658,586 17,347,182 151,353,714 168,700,896

59,915 124,182 66,411 109,060 155,833 148,030 544 0 0 515,401 327,270 842,671

13,773 78,434 80,696 144,524 124,804 118,000 93,204 152,079 0 442,231 363,283 805,514

135,138 773,064 1,068,556 5,051,439 11,276,617 37,085,605 20,772,814 65,527,262 28,658,586 18,304,814 152,044,267 170,349,081

78.5% 71.0% 79.3% 81.7% 86.5% 96.3% 88.0% 93.4% Note 1

857 1,422 967 1,977 1,595 1,548 264 244 N/A 6,819 2,055 8,874

1,070 367 70 50 24 7 3 0 N/A 1,581 9 1,590

213 209 84 65 20 4 1 1 N/A 591 6 597

2,140 1,999 1,121 2,092 1,639 1,558 268 245 N/A 8,991 2,070 11,062

48,238 405,018 730,709 3,919,848 9,511,523 35,457,251 18,040,326 61,060,421 N/A 14,615,335.6 114,557,997.2 129,173,333

47,033 88,169 52,664 89,102 134,796 142,553 479 0 N/A 411,764.0 143,031.6 554,796

10,812 55,688 63,992 118,076 107,955 113,634 82,020 142,042 N/A 356,523.4 337,695.3 694,219

106,083 548,875 847,365 4,127,026 9,754,274 35,713,438 18,122,824 61,202,463 N/A 15,383,623.0 115,038,724.2 130,422,347

April 2001
Appendix G. Baseline Data

0-100 101-500 501-1000 1,001-3,300 3,301 - 9,999 10,001 - 50,000 50,001-100,000 100,001-1M 1 mill+ Total <10,000 Total >10K Total

38.0% 55.0% 73.0% 77.0% 90.0% 92.0% 98.0% 92.0% Note 1

325.7 782.2 706.2 1,522.4 1,435.6 1,423.7 258.7 224.3 N/A 4,772.1 1,906.7 6,679

406.6 201.9 50.9 38.4 21.8 6.2 2.6 - N/A 719.6 8.8 728

80.8 115.2 61.4 50.3 17.9 3.5 0.9 0.9 N/A 325.6 5.3 331

813.2 1,099.3 818.6 1,611.1 1,475.3 1,433.5 262.2 225.1 N/A 5,817.3 1,920.8 7,738

18,330.5 222,759.9 533,417.6 3,018,282.6 8,560,370.4 32,620,670.7 17,679,519.1 56,175,587.2 N/A 12,353,161.1 106,475,777.0 118,828,938

17,872.6 48,493.1 38,444.7 68,608.6 121,316.0 131,148.7 469.1 - N/A 294,734.9 131,617.8 426,353

4,108.5 30,628.5 46,714.1 90,918.6 97,159.9 104,543.3 80,379.1 130,678.4 N/A 269,529.6 315,600.9 585,130

40,311.7 301,881.5 618,576.4 3,177,809.8 8,778,846.3 32,856,362.6 17,760,367.4 56,306,265.7 N/A 12,917,425.6 106,922,995.7 119,840,421

60.0% 60.0% 60.0% 60.0% 60.0% 60.0% 60.0% 60.0% Note 1

195.4 469.3 423.7 913.4 861.3 854.2 155.2 134.6 7.0 2,863.3 1,151.0 4,014

243.9 121.1 30.6 23.0 13.1 3.7 1.6 - - 431.8 5.3 437

48.5 69.1 36.8 30.2 10.7 2.1 0.5 0.5 - 195.4 3.2 199

487.9 659.6 491.1 966.7 885.2 860.1 157.3 135.1 7.0 3,490.4 1,159.5 4,650

10,998.3 133,656.0 320,050.6 1,810,969.6 5,136,222.3 19,572,402.4 10,607,711.5 33,705,352.3 715,053.6 7,411,896.7 64,600,519.8 72,012,416

10,723.6 29,095.8 23,066.8 41,165.1 72,789.6 78,689.2 281.5 - - 176,841.0 78,970.7 255,812

2,465.1 18,377.1 28,028.5 54,551.2 58,295.9 62,726.0 48,227.5 78,407.1 - 161,717.8 189,360.5 351,078

24,187.0 181,128.9 371,145.8 1,906,685.9 5,267,307.8 19,713,817.6 10,656,220.4 33,783,759.4 715,053.6 7,750,455.4 64,868,851.0 72,619,306

ps 10.0% 10.0% 10.0% 10.0% 10.0% 10.0% 10.0% 10.0% Note 1

19.5 46.9 42.4 91.3 86.1 85.4 15.5 13.5 2.0 286.3 116.4 403

24.4 12.1 3.1 2.3 1.3 0.4 0.2 - - 43.2 0.5 44

4.9 6.9 3.7 3.0 1.1 0.2 0.1 0.1 - 19.5 0.3 20

48.8 66.0 49.1 96.7 88.5 86.0 15.7 13.5 2.0 349.0 117.2 466

1,099.8 13,365.6 32,005.1 181,097.0 513,622.2 1,957,240.2 1,060,771.1 3,370,535.2 46,318.9 741,189.7 6,434,865.5 7,176,055

1,072.4 2,909.6 2,306.7 4,116.5 7,279.0 7,868.9 28.1 - - 17,684.1 7,897.1 25,581

246.5 1,837.7 2,802.8 5,455.1 5,829.6 6,272.6 4,822.7 7,840.7 - 16,171.8 18,936.1 35,108

2,418.7 18,112.9 37,114.6 190,668.6 526,730.8 1,971,381.8 1,065,622.0 3,378,375.9 46,318.9 775,045.5 6,461,698.6 7,236,744

8.0% 8.0% 8.0% 8.0% 8.0% 8.0% 8.0% 8.0% Note 1

14.5 34.9 31.5 68.0 64.1 63.6 11.5 10.0 2.0 213.0 87.1 300

18.1 9.0 2.3 1.7 1.0 0.3 0.1 - - 32.1 0.4 33

3.6 5.1 2.7 2.2 0.8 0.2 0.0 0.0 - 14.5 0.2 15

36.3 49.1 36.5 71.9 65.9 64.0 11.7 10.0 2.0 259.7 87.7 347

818.3 9,944.0 23,811.8 134,736.1 382,134.9 1,456,186.7 789,213.7 2,507,678.2 46,318.9 551,445.1 4,799,397.6 5,350,843

797.8 2,164.7 1,716.2 3,062.7 5,415.5 5,854.5 20.9 - - 13,157.0 5,875.4 19,032

183.4 1,367.3 2,085.3 4,058.6 4,337.2 4,666.8 3,588.1 5,833.5 - 12,031.8 14,088.4 26,120

1,799.5 13,476.0 27,613.2 141,857.4 391,887.7 1,466,708.0 792,822.8 2,513,511.7 46,318.9 576,633.9 4,819,361.4 5,395,995

April 2001
Appendix G. Baseline Data

0-100 101-500 501-1000 1,001-3,300 3,301 - 9,999 10,001 - 50,000 50,001-100,000 100,001-1M 1 mill+ Total <10,000 Total >10K Total

2.0% 2.0% 2.0% 2.0% 2.0% 2.0% 2.0% 2.0% Note 1

3.6 8.7 7.9 17.0 16.0 15.9 2.9 2.5 N/A 53.3 21.3 75

4.5 2.3 0.6 0.4 0.2 0.1 0.0 - N/A 8.0 0.1 8

0.9 1.3 0.7 0.6 0.2 0.0 0.0 0.0 N/A 3.6 0.1 4

9.1 12.3 9.1 18.0 16.5 16.0 2.9 2.5 N/A 64.9 21.4 86

204.6 2,486.0 5,952.9 33,684.0 95,533.7 364,046.7 197,303.4 626,919.6 N/A 137,861.3 1,188,269.7 1,326,131

199.5 541.2 429.0 765.7 1,353.9 1,463.6 5.2 - N/A 3,289.2 1,468.9 4,758

45.9 341.8 521.3 1,014.7 1,084.3 1,166.7 897.0 1,458.4 N/A 3,008.0 3,522.1 6,530

449.9 3,369.0 6,903.3 35,464.4 97,971.9 366,677.0 198,205.7 628,377.9 N/A 144,158.5 1,193,260.6 1,337,419

93.0% 93.0% 93.0% 93.0% 93.0% 93.0% 93.0% 93.0% Note 1

181.8 436.5 394.1 849.5 801.0 794.4 144.4 125.1 3.0 2,662.8 1,067.0 3,730

226.9 112.7 28.4 21.4 12.2 3.5 1.4 - - 401.5 4.9 406

45.1 64.3 34.2 28.1 10.0 2.0 0.5 0.5 - 181.7 2.9 185

453.7 613.4 456.8 899.0 823.2 799.9 146.3 125.6 3.0 3,246.1 1,074.8 4,321

-

-

10,228.4 124,300.0 297,647.0 1,684,201.7 4,776,686.7 18,202,334.2 9,865,171.7 31,345,977.7 69,478.3 6,893,063.9 59,482,961.9 66,376,026

9,972.9 27,059.1 21,452.1 38,283.6 67,694.3 73,181.0 261.8 - - 164,462.1 73,442.7 237,905

2,292.5 17,090.7 26,066.5 50,732.6 54,215.2 58,335.2 44,851.6 72,918.6 - 150,397.5 176,105.3 326,503

22,493.9 168,449.9 345,165.6 1,773,217.8 4,898,596.3 18,333,850.3 9,910,285.0 31,418,896.3 69,478.3 7,207,923.5 59,732,509.9 66,940,433

7.0% 7.0% 7.0% 7.0% 7.0% 7.0% 7.0% 7.0% Note 1

13.7 32.9 29.7 63.9 60.3 59.8 10.9 9.4 4.0 200.4 84.1 285

17.1 8.5 2.1 1.6 0.9 0.3 0.1 - - 30.2 0.4 31

3.4 4.8 2.6 2.1 0.8 0.1 0.0 0.0 - 13.7 0.2 14

34.2 46.2 34.4 67.7 62.0 60.2 11.0 9.5 4.0 244.3 84.7 329

769.9 9,355.9 22,403.5 126,767.9 359,535.6 1,370,068.2 742,539.8 2,359,374.7 645,575.3 518,832.8 5,117,557.9 5,636,391

750.7 2,036.7 1,614.7 2,881.6 5,095.3 5,508.2 19.7 - - 12,378.9 5,527.9 17,907

172.6 1,286.4 1,962.0 3,818.6 4,080.7 4,390.8 3,375.9 5,488.5 - 11,320.2 13,255.2 24,575

1,693.1 12,679.0 25,980.2 133,468.0 368,711.5 1,379,967.2 745,935.4 2,364,863.2 645,575 542,531.9 5,136,341.1 5,678,873

illion persons are based on a separate analysis of individual plants within those systems. See Section 4.3.4 of the RIA for a detailed explanation of this process.

April 2001
Appendix H

Costs and Technologies for the

Filter Backwash Recycling Rule
FBRR Final RIA H-1 April 2001

Filter Backwash Recycling Rule: Costs and Technologies

The purpose of this appendix is to describe, in detail, the cost estimating approach for recycle

process modifications that may be required in order to comply with the Filter Backwash

Recycling Rule (FBRR). EPA developed provisions requiring systems that recycle filter

backwash water, sludge thickener supernatant, and liquids from dewatering processes to return

these flows through the processes of a system’s existing conventional or direct filtration (as

defined in 40 CFR, Section 141.2) that the Agency has recognized as capable of achieving 2-log

Cryptosporidium removal. To comply with this requirement, systems may be required to install

piping and additional pump capacity.

Selection of Representative Systems for Cost Analysis

Based on data submitted by community water systems for the 1995 Community Water

Systems Survey (CWSS), EPA has estimated representative mean populations for eight

population categories. EPA has also developed a regression equation correlating population with

system characteristics like design and average flow.

Systems from all population size categories are covered by the FBRR. Small treatment systems

are defined as systems serving a population of fewer than 10,000 persons. Systems serving a

population serving fewer than 10,000 persons are stratified into five population size categories. 

They are: <100; 101-500; 501-1,000; 1,001-3,300; and 3,301-10,000. In addition, three

population size categories for service populations of 10,001-50,000; 50,001-100,000; and greater

than 100,000 persons are employed. 

To estimate a representative system’s design flow for each population size category, the

estimated mean population for the population size category was used in the equation below. The

average flow was calculated from the design flow using a design to average flow ratio developed

from CWSS data. These average flow estimates are then used in determining the cost curves for

capital and operation and maintenance (O&M) costs. Table H-1 presents the design and average

flows that were used to determine the cost of the options considered. The filter area and

backwash production used in the cost calculations are also presented in this table.
FBRR Final RIA H-2 April 2001

Table H-1. Backwash Production and Filtration Assumptions

for Flow Categories Used to Estimate Costs

Population Size

Category

Design

Flow

(mgd)

Average

Flow

(mgd)

Area

per Filter1,2

(sq. ft.)

One Backwash

Volume

(mgd/filter)

Number

of

Filters

 Backwash

Volume from all

Filters (mgd)

< 100 0.022 0.0069 6.5 0.0019 2 0.0038

101–500 0.088 0.0275 26 0.0077 2 0.0154

501–1,000 0.239 0.074 69 0.0208 2 0.0416

1,001–3,300 0.593 0.211 57 0.0171 4 0.0684

3,301–10,000 1.800 0.747 104 0.0312 6 0.1872

10,001–50,000 7.36 3.06 427 0.128 6 0.768

50,001–100,000 19.87 9.93 640 0.192 10 1.92

>100,000 83.59 41.79 692 0.208 36 7.488

1

 The number of filters and filter areas presented in this table were used for calculation of backwash volumes only.

2

 Maximum filter area is assumed to be 700 square feet per the IESWTR RIA.

The backwash volume calculation was determined by using the following methodology:

Backwash Volume = Filter Area × Backwash Rate × Backwash Duration

where Filter Area = Design Flow /Filter Loading Rate × Hours per Day Filter in Use

The following inputs were used:

o Backwash rate = 20 gpm/sq. ft. (Ten State Standards)

o Backwash duration = 15 minutes (Ten State Standards)

o Filter loading rate = 2.5 gpm/sq. ft.

o Hours per day filter is in use = 23

Cost Estimating Approach

Capital and O&M cost estimates were developed for installation of piping and additional pump

capacity in order to enable systems to return recycle flows to a location such that they are

returned through the processes of a system’s existing conventional or direct filtration (as defined

in 40 CFR, Section 141.2) that the Agency has recognized as capable of achieving 2-log

Cryptosporidium removal.. These estimates are based on the backwash volume from all filters

for that population size category. Specific cost estimation models were not available for these

process improvements, and, as a result, a direct engineering cost estimation method was used. 

This method entails the use of best professional engineering judgement (BPJ) and manufactureror vendor-supplied data.

To employ BPJ and direct cost estimating to develop unit process costs, a conceptual

design for each unit process was formulated. The conceptual design utilizes all of the major

design parameters that have a meaningful affect on costs. Equipment is sized using system

production as the primary design parameter. Other design parameters used to size equipment or
FBRR Final RIA H-3 April 2001

treatment units are based on engineering experience. Some equipment and material costs were

obtained from manufacturers or from R.S. Means cost estimating references.

Using best professional judgment, the installation costs (construction costs) for the major

elements of the technology are used to estimate non-construction cost components. Nonconstruction costs, or indirect capital costs such as engineering design fees, contractor’s overhead

and profit, and contingencies are estimated by applying a percentage factor to direct capital costs

(equipment installation costs).

For estimating the total annual labor costs for technologies costed using engineering

judgment, the labor rate is $14.50 for systems serving populations less than 10,000 (average

flow O 0.75 mgd) and $28.00 for systems serving populations 10,000 or greater (average flow >

0.75 mgd). The Agency proposed the FBRR in early 2000 using labor rate recommendations of a

Technical Design Panel of industry engineers which met in Denver for two days in the Fall of

1997. Additional analysis as recommended by the panel has yielded updated labor rates, which

were used in developing costs for the final FBRR. EPA has included these analyses in the docket

for the final rule (EPA, 2000f).

Costs of Installing Piping and Additional Pump Capacity 

Additional piping and pump capacity may have to be installed to convey the spent filter

backwash, thickener supernatant, and liquids from dewatering processes such that it passes

through the processes of a system’s existing conventional or direct filtration (as defined in 40

CFR, Section 141.2) that the Agency has recognized as capable of achieving 2-log

Cryptosporidium removal.

Cost and Process Description — Cost estimates for the installation of additional piping

were estimated by using BPJ. The calculations assumed that the length of flanged cast iron pipes

needed to recycle from filters to headworks is the sum of four times the length of a single filter

multiplied by the width and the number of filters. For redundancy, the cost of two pumps

capable of delivering 150 ft of total dynamic head (TDH) and a pump motor efficiency of 0.67

were costed. The fittings include one solenoid valve per filter and a gate valve, check valve, and

two reducers per pump. It also included four horizontal and vertical elbows and one tee per

filter. The unit costs for pipes and fittings were obtained from the 1998 R.S. Means Plumbing

Cost Data Handbook (4th edtition). Total costs also included an additional 25 percent for

contingencies, engineering and permitting costs and interest. The unit costs for installing piping

to move recycle flow to the headworks were assumed to be similar, regardless of whether the

system practices direct recycle or has an existing recycle treatment.

Operation and Maintenance Cost — The O&M costs include the annual cost of

painting the pipes, replacement of pipe sections and fittings, and pump and motor service. These

costs were estimated assuming 15 minutes of labor per day. Total O&M costs were obtained by

adding the above cost component and the power cost per annum to operate the pumps. Relative

to the power costs of the smaller flows, the annual power costs are much higher than the

maintenance costs for the piping and pumps for design flows greater than 7.36 mgd. It is likely

that in smaller systems, the extra pumping distance is small and requires negligible additional

power. This cost estimate conservatively assumes additional power is necessary for all system
FBRR Final RIA H-4 April 2001

sizes. For flows in the vicinity of 83 mgd, the general maintenance costs are almost negligible

compared to the annual power costs.

Estimated Cost Equations — The estimated capital and O&M costs for each design

flow size are presented in Table H-2. Microsoft Excel was used to fit a flow versus cost equation

using the trendline function, which generates an equation for the best-fit curve. The estimated

cost equations are presented in Table H-3.

Table H–2. Capital and O&M Costs for Installing Piping and Additional Pump Capacity

Design Flow (mgd) Capital Cost ($) Average Flow (mgd) O&M Cost ($)

0.022 $6,600 0.0069 $1,350

0.088 $13,400 0.028 $1,450

0.24 $13,600 0.075 $1,570

0.59 $18,100 0.21 $1,950

1.8 $32,000 0.75 $3,170

7.37 $83,400 3.07 $10,200

19.87 $288,700 9.94 $22,550

83.59 $2,803,700 41.79 $86,200

Table H–3. Cost Equations for Installing Piping and Additional Pump Capacity

Capital Cost Equation O&M Cost Equation

Capital Cost ($) = 305.9x2

 + 7830.2x + 11790

for 0.022 @ x @ 83.59 mgd; x = design flow

O&M Cost ($) = –4.57y2

 + 2213.4y + 1650.1

for 0.0069 @ y @ 41.79 mgd; y = average flow

Detailed Cost Summary — The following tables present the detailed cost information

used to develop the equations described above.
Detailed Cost Summary

Install Piping to Move Recycle Flow to the Headworks

Assumptions:

1. Recycling via equalization basin, which discharges the backwash flow over a 23 hour period.

2. Recycling costs presented below are those incurred for a single filter only.

3. Backwash rate = 20 gpm/sq. ft. for 15 minutes per filter.

4. Conceptual design parameters assume a filter loading rate of 2.5 gpm/sq. ft.

Design Average Total filter area BW vol. Area per Filter dim. No. of filters

flow (mgd) flow (mgd) (ft2) (gallons) filter (ft2) (ft*ft)

0.02 0.0069 7 1050 3.5 5x0.7 2

0.09 0.028 25 3750 12.5 5x2.5 2

0.24 0.075 67 10050 33.5 7x4.8 2

0.59 0.21 164 12300 41 10x4.1 4

1.80 0.75 500 25200 84 10x8.4 6

7.37 3.07 2048 102600 342 30x11.4 6

19.87 9.94 5520 165600 552 40x13.8 10

83.59 41.79 23220 193500 645 43x15 36

Design Average Recycle flow BW recycle Return to Recycle flow Return to

flow flow 23 hr recycle pipe dia. design flow ratio 15 min. recycle design flow ratio

(mgd) (mgd) (gpm) (inches)* (23 hr based) (gpm) (15 min based)

0.02 0.0069 0.8 0.5 0.053 70 4.59

0.09 0.028 2.8 1 0.046 250 4.1

0.24 0.075 7.3 1 0.044 670 4.02

0.59 0.21 9 1 0.022 820 2.01

1.80 0.75 18.3 2 0.015 1680 1.35

7.37 3.07 74.4 3.5 0.015 6840 1.34

19.87 9.94 120 3.5 0.009 11040 0.81

83.59 41.79 140.3 8 0.003 12900 0.23

* Based on BPJ and RS Means data.

flow (gpm) pipe dia.

(inches) cost ($/ft)

2 0.5 $7

7 1 $9

15 1 $9

39 2 $12

115 3.5 $13

478 8 $20

1261 14 $60

5283 24 $90

FBRR Final RIA H-5 April 2001
Detailed Cost Summary (cont.)

Design Flows (mgd)

0.022 0.088 0.24 0.59 1.8 7.37 19.87 83.59 Comments

60 60 70 80 120 230 400 720

$7 $9 $9 $9 $12 $13 $13 $20

$420 $540 $630 $720 $1,440 $2,990 $5,200 $14,400

8 8 8 12 28 36 44 164 4 horizontal and vertical elbows per filter

2 2 2 3 7 9 11 41 1 tee per filter

$65 $75 $75 $75 $100 $140 $140 $310

$100 $120 $120 $120 $140 $180 $180 $282

$720 $840 $840 $1,260 $3,780 $6,660 $8,140 $62,402

$200 $400 $400 $400 $850 $1,000 $1,000 $3,063 1 per filter

$100 $200 $200 $200 $425 $525 $525 $835 1 per pump

$100 $200 $200 $200 $340 $400 $400 $1,225 1 per pump

2 2 2 2 2 2 2 2

$628 $2,223 $2,223 $2,223 $2,981 $4,100 $9,075 $26,732

$1,256 $1,256 $1,256 $1,256 $1,256 $1,256 $1,256 $1,256

$600 $1,200 $1,200 $1,200 $2,380 $2,850 $2,850 $7,183

$3,000 $3,000 $3,000 $3,000 $3,000 $3,000 $3,000 $3,000 Lumpsum (BPJ)

$5,996 $10,226 $10,316 $13,766 $24,377 $63,585 $219,970 $2,136,139

$600 $1,023 $1,032 $1,377 $2,438 $3,180 $10,999 $106,807 10% of cost for < 2 mgd and 5% for >= 2 mgd

$6,596 $13,400 $13,600 $18,100 $32,000 $83,400 $288,700 $2,803,700 Includes 25% of subtotal for contingen., eng. & permitting.

Average Flows (mgd)

0.0069 0.028 0.075 0.21 0.75 3.07 9.93 41.79 Comments

0.1 1 1 3 7 27 71 297 150 ft TDH and pump & motor efficiency = 0.67

410 1800 4100 10400 30700 127000 333000 1394000

$25 $108 $246 $624 $1,842 $7,620 $19,980 $83,640 $ 0.06/kWhr (BPJ)

$1,323 $1,323 $1,323 $1,323 $1,323 $2,555 $2,555 $2,555 Pipe painting, pump/motor servicing. 15 mins./day @

$28/hr for > 10K systems and $14.5/hr for <= 10K systems

$1,348 $1,431 $1,569 $1,947 $3,165 $10,175 $22,535 $86,195

H-6 April 2001