Information Collection Request 

for the Unregulated Contaminant 

Monitoring Regulation (UCMR 3)

September 2010 

Prepared by: 

The Cadmus Group, Inc. 

57 Water Street 

Watertown, MA 02472 

Prepared for:

David J. Munch, Project Officer 

Brenda D. Parris, Alternate Project Officer 

U.S. Environmental Protection Agency 

Office of Ground Water and Drinking Water 

26 West Martin Luther King Drive 

Cincinnati, OH 45268 
Draft ICR for UCMR 3 Proposed Rule September 2010

TABLE OF CONTENTS

— PART A OF THE SUPPORTING STATEMENT —............................................................... 6

1 IDENTIFICATION OF THE INFORMATION COLLECTION......................................................................6

1(a) Title and Number of the Information Collection ...................................................................................6

1(b) Short Characterization ...........................................................................................................................6

2 NEED FOR AND USE OF THE COLLECTION.............................................................................................9

2(a) Need/Authority for the Collection .........................................................................................................9

2(b) Practical Utility/Users of the Data .......................................................................................................10

3 NON-DUPLICATION, CONSULTATIONS AND OTHER COLLECTION CRITERIA.............................12

3(a) Non-duplication ...................................................................................................................................12

3(b) Public Notice Required Prior to ICR Submission to OMB..................................................................12

3(c) Consultations .......................................................................................................................................12

3(d) Effects of Less Frequent Collection.....................................................................................................13

3(e) General Guidelines ..............................................................................................................................16

3(f) Confidentiality .....................................................................................................................................16

3(g) Sensitive Questions..............................................................................................................................16

4 RESPONDENTS AND THE INFORMATION..............................................................................................17

4(a) Respondents and NAICS/SIC Codes...................................................................................................17

4(b) Information Requested.........................................................................................................................17

4(b)(i) Data Items ............................................................................................................................................17

4(b)(i)(a) Public Water System Reporting and Record Keeping .................................................................17

4(b)(i)(b) State Reporting and Record Keeping...........................................................................................19

4(b)(ii) Respondent Activities .........................................................................................................................19

4(b)(ii)(a) Public Water System Activities ..................................................................................................19

4(b)(ii)(b) State Activities............................................................................................................................22

5 INFORMATION COLLECTED–AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND 

INFORMATION MANAGEMENT........................................................................................................................24

5(a) Agency Activities ................................................................................................................................24

5(a)(i) Regulatory Support Activities ..............................................................................................................24

5(a)(ii) National and Regional Oversight/Data Analysis.................................................................................25

5(a)(iii) Costs for Small System Testing Program...........................................................................................25

5(b) Information Collection Methodology and Management......................................................................26

5(c) Small Entity Flexibility........................................................................................................................26

5(d) Collection Schedule .............................................................................................................................31

6 ESTIMATING THE BURDEN AND COST OF THE COLLECTION .........................................................33

6(a) Estimating Burden and Cost to Public Water Systems........................................................................33

6(a)(i) Estimating Burden and Labor Costs.....................................................................................................34

6(a)(i)(a) Reading the Regulations/Guidance Letter....................................................................................36

6(a)(i)(b) Monitoring Burden.......................................................................................................................37

6(a)(i)(c) Reporting and Record Keeping ....................................................................................................37

6(a)(i)(d) Public Notification.......................................................................................................................38

6(a)(ii) Estimating Non-labor Costs ................................................................................................................38

6(a)(iii) Summary of Labor and Non-labor Costs to Public Water Systems....................................................40

6(b) Estimating the Burden and Cost to States............................................................................................42

6(c) Estimating Agency Burden and Cost...................................................................................................45

6(c)(i) Regulatory Support Activities ..............................................................................................................45

6(c)(ii) National and Regional Oversight and Data Analysis ..........................................................................46

6(c)(iii) Costs for Small System Testing Program...........................................................................................46

6(c)(iv) Estimated Agency Cost and Burden ...................................................................................................47

6(d) Estimating the Respondent Universe and Total Burden and Costs......................................................49

6(e) Reasons for Change in Burden ............................................................................................................51
Draft ICR for UCMR 3 Proposed Rule September 2010

6(f) Burden Statement.................................................................................................................................51

— PART B OF THE SUPPORTING STATEMENT — ............................................................. 55

1 SURVEY OBJECTIVES, KEY VARIABLES, AND OTHER PRELIMINARIES .......................................55

1(a) Survey Objectives................................................................................................................................55

1(b) Key Variables ......................................................................................................................................55

1(c) Statistical Approach.............................................................................................................................55

1(d) Feasibility ............................................................................................................................................55

2 SURVEY DESIGN..........................................................................................................................................56

2(a) Target Population and Coverage..........................................................................................................56

2(b) Sample Design.....................................................................................................................................56

2(b)(i) Sampling Frame ...................................................................................................................................56

2(b)(ii) Sample Size.........................................................................................................................................56

2(b)(iii) Stratification Variables.......................................................................................................................57

2(b)(iv) Sampling Method ...............................................................................................................................57

2(b)(v) Multi-Stage Sampling..........................................................................................................................57

2(c) Precision Requirements .......................................................................................................................58

2(c)(i) Precision Targets..................................................................................................................................58

2(c)(ii) Non-sampling error .............................................................................................................................58

2(d) Questionnaire Design...........................................................................................................................58

3 PRETESTS AND PILOT TESTS....................................................................................................................58

4 COLLECTION METHODS AND FOLLOW-UP ..........................................................................................59

4(a) Collection Methods..............................................................................................................................59

4(b) Survey Response and Follow-up .........................................................................................................59

5 ANALYZING AND REPORTING SURVEY RESULTS..............................................................................59

5(a) Data Preparation ..................................................................................................................................59

5(b) Analysis...............................................................................................................................................60

5(c) Reporting Results.................................................................................................................................61

APPENDICES .............................................................................................................................. 62

APPENDIX A: Relevant Authorities in the SDWA 1996 Amendments.................................................................63

APPENDIX B: Burden and Cost Exhibits for the Five-Year UCMR 3 Cycle of 2012-2016..................................70
Draft ICR for UCMR 3 Proposed Rule September 2010

LIST OF EXHIBITS

Exhibit 1: Proposed UCMR 3 Contaminant Lists........................................................................................................18

Exhibit 2: UCMR 3 Reporting Requirements..............................................................................................................19

Exhibit 3: Proposed Timeline of UCMR 3 Activities..................................................................................................25

Exhibit 4: Number of Publicly- and Privately-Owned Small Systems Subject to UCMR 3 .......................................28

Exhibit 5: EPA and Systems Costs for Implementation of UCMR 3 at Small Systems..............................................29

Exhibit 6: UCMR 3 Relative Cost Analysis for Small Publicly-Owned Systems (2012-2016) ..................................30

Exhibit 7: UCMR 3 Relative Cost Analysis for Small Privately-Owned Systems (2012-2016).................................31

Exhibit 8: Systems to Participate in UCMR 3 Monitoring ..........................................................................................35

Exhibit 9: UCMR 3 Sampling Activity Time Line for Cost and Burden Estimations.................................................35

Exhibit 10: Labor Rates Applied for Public Water Systems .......................................................................................36

Exhibit 11a: Yearly Cost to Systems, by System Size and by Type of Cost (2012-2014) (corresponds to Exhibit B1a)................................................................................................................................................................................41

Exhibit 11b: Per System (Respondent) and Per Response UCMR Costs (2012-2014) ...............................................42

(corresponds with Exhibit B-1b)..................................................................................................................................42

Exhibit 12: Number of States in Each Size Category (State Resource Model Assumptions)......................................44

Exhibit 13a: Yearly Cost and Burden to States for Implementation of UCMR 3 (2012-2014)1(corresponds with 

Exhibit B-2a) ...............................................................................................................................................................44

Exhibit 13b: Per State (Respondent) and Per Response UCMR 3 Costs (2012-2014) (corresponds with Exhibit B-2b)

.....................................................................................................................................................................................44

Exhibit 14a: Yearly Cost to EPA for UCMR Implementation, by Type of Cost (2012-2014) 1(corresponds with 

Exhibit B-3a) ...............................................................................................................................................................48

Exhibit 14b: Summary of EPA Burdens and Costs for UCMR Implementation (2012-2014) (corresponds with 

Exhibit B-3b) ...............................................................................................................................................................48

Exhibit 15: UCMR 3 National Cost Summary for the ICR period (2012-2014) (corresponds with Exhibit B-4).......49

Exhibit 16: UCMR 3 Per Respondent Burden and Cost Summary for the ICR Period (2012-2014) (corresponds with 

Exhibit B-5).................................................................................................................................................................53

Exhibit B-1a: Yearly Cost to Systems, by System Size and by Type of Cost (2012-2016) (corresponds to Exhibit 

11a)..............................................................................................................................................................................70

Exhibit B-1b: Per System (Respondent) and Per Response UCMR 3 Costs (2012-2016) (corresponds with Exhibit 

11b)..............................................................................................................................................................................71

Exhibit B-2a: Yearly Cost and Burden to States for Implementation of UCMR 3 (2012-2016)1(corresponds with 

Exhibit 13a) .................................................................................................................................................................71

Exhibit B-2b: Per State (Respondent) and Per Response UCMR 3 Costs (2012-2016) (corresponds with Exhibit 13b)

.....................................................................................................................................................................................71

Exhibit B-3a: Yearly Cost to EPA for UCMR 3 Implementation, by Type of Cost (2012-2016) 1(corresponds with 

Exhibit 14a) .................................................................................................................................................................72

Exhibit B-3b: Summary of EPA Burdens and Costs for UCMR 3 Implementation (2012-2016) (corresponds with 

Exhibit 14b) .................................................................................................................................................................73

Exhibit B-4: National Cost Summary for UCMR 3 Implementation (2012-2016) (corresponds with Exhibit 15).....73

Exhibit B-5: UCMR 3 Per Respondent Burden and Cost Summary (2012-2016) (corresponds with Exhibit 16)......74
Draft ICR for UCMR 3 Proposed Rule September 2010

ACRONYMS

ASDWA Association of State Drinking Water Administrators

CCL Contaminant Candidate List

CCR Consumer Confidence Report

CFR Code of Federal Regulations 

CWS Community Water System

DBP Disinfection Byproduct

DBPR Stage 2 Disinfection Byproducts Rule

DSMRT Distribution System Maximum Residence Time

EPA Environmental Protection Agency

EPTDS Entry Point to the Distribution System

FR Federal Register 

FTE Full Time Equivalent

GS General Schedule

GWUDI Ground Water Under the Direct Influence of Surface Water

ICR Information Collection Request

LCMRL Lowest Concentration Minimum Reporting Level 

MCL Maximum Contaminant Level

MCLG Maximum Contaminant Level Goal

MRL Minimum Reporting Level

NAICS North American Industry Classification System

NCOD National Contaminant Occurrence Database

NPDWR National Primary Drinking Water Regulation 

NTNCWS Non-Transient Non-Community Water System

OMB Office of Management and Budget 

OW Office of Water

PA Partnership Agreement

PT Proficiency Testing

PWS Public Water System

PWSID Public Water System Identification 

QA/QC Quality Assurance/Quality Control

RFA Regulatory Flexibility Act

SBA Small Business Administration

SDWA Safe Drinking Water Act

SRF State Revolving Fund

TNCWS Transient Non-Community Water System

UCMR Unregulated Contaminant Monitoring Regulation
Draft ICR for UCMR 3 Proposed Rule September 2010

6

— PART A OF THE SUPPORTING STATEMENT —

1 IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Number of the Information Collection 

Title: Information Collection Request for UCMR 3

OMB Control Number: 2040-xxxx

EPA Tracking Number: 2192.01

1(b) Short Characterization 

Section 1445(a)(2) of the 1996 amendments to the Safe Drinking Water Act (SDWA) 

requires that once every five years, beginning in 1999, the United States Environmental 

Protection Agency (EPA) issue a new list of no more than 30 unregulated contaminants to be 

monitored by public water systems (PWSs). SDWA requires that EPA vary the frequency and 

schedule for monitoring based on the number of persons served, the source of supply, and the 

contaminants likely to be found. It requires that EPA only include a representative sample of 

systems serving 10,000 or fewer people. SDWA also requires EPA to enter the monitoring data 

into the National Drinking Water Contaminant Occurrence Database (NCOD). 

EPA published the first cycle of the Unregulated Contaminant Monitoring Regulation 

(UCMR 1) for PWSs on September 17, 1999 (64 FR 50556). Several supplemental rules 

established analytical methods, and provided clarifications and refinements to the initial rule 

(March 2, 2000 (65 FR 11372), January 11, 2001 (66 FR 2273), and October 29, 2002 (67 FR 

65888))1. UCMR 1 established a three-tiered approach for monitoring contaminants based on the 

availability of analytical methods and contaminant properties. 

The second cycle (UCMR 2) was published in the Federal Register on January 4, 2007 

and built on the established structure of UCMR 1 while making some changes to the rule design. 

The primary changes to UCMR 1 included: redesign of the Screening Survey for List 2 

contaminants to increase the statistical strength of the sampling results by incorporating 

additional systems; updates to the lists of contaminants to be monitored and the analytical 

 

1

Additional technical corrections to the rule, as well as adjustments to the initial reporting process, were published 

including: May 16, 2001 (66 FR 27215); September 4, 2001 (66 FR 46221); and March 12, 2002 (67 FR 11043). In 

total, these rules and revisions constitute "UCMR 1".
Draft ICR for UCMR 3 Proposed Rule September 2010

7

methods approved to conduct that monitoring; revisions to the data elements required to be 

reported; and some revisions to the implementation of the monitoring program to reflect lessons 

learned during UCMR 1. A systematic procedure for the determination of a Minimum Reporting 

Level (MRL) was also included.

The third cycle (UCMR 3) builds on the established structure of UCMR 1 and UCMR 2, 

and proposes some changes to improve the rule design. EPA revised the contaminant list and 

sampling design for the third cycle (UCMR 3). Hereafter, references to what EPA or regulated 

entities ―will do‖ or ―must do‖ presume that the rule is published as proposed.

UCMR 3 monitoring will take place from 2013 through 2015. The applicable Information 

Collection Request (ICR) period is 2012-2014. Estimates of implementation burden and cost 

over the entire five-year UCMR cycle of 2012-2016 are attached as Appendix B to this ICR. 

Assessment Monitoring (List 1), the largest tier of the three UCMR monitoring 

components, will be conducted from January 2013 through December 2015 by 800 systems 

serving 10,000 or fewer (hereafter referred to as small systems), and by all systems serving 

10,001 and over, for 28 List 1 contaminants.

2 Under Assessment Monitoring, contaminants for 

which standard analytical methods are available are monitored to assess national occurrence in 

drinking water. It is assumed for this cost estimation that one-third of systems will monitor each 

year. 

There are currently no contaminants included for Screening Survey (List 2) for UCMR 3;

therefore no systems will be selected for UCMR 3.

Pre-Screen Testing (List 3) for two contaminants will also be conducted during January 

2013 through December 2015. EPA will select 800 small, undisinfected ground water wells that 

may be vulnerable to contamination. This sample of small systems may include non-transient 

non-community water systems (NTNCWSs) and transient non-community water systems 

(TNCWSs), and will include only wells from small systems that serve 1,000 or fewer customers. 

Small systems will not be subject to more than one component of UCMR 3 monitoring. 

Respondents to UCMR 3 will include 1,600 small systems (800 for Assessment 

Monitoring, and 800 for the Pre-Screen Testing), the 4,191 large and very large systems, and the 

56 States and primacy agents (referred to collectively as ―States‖ for simplicity in this 

document), for a total of 5,847 respondents. The frequency of response varies across respondents 

and years. 

Small systems selected for UCMR 3 monitoring will sample an average of 1.5 times per 

system (i.e., number of responses per system) across the three-year ICR period of 2012 through 

2014. The estimated burden per response for small systems is 3.0 hours. Large systems (those 

 

2

Transient non-community water systems and those systems that sell all of their water to another PWS are excluded 

from Assessment Monitoring. 
Draft ICR for UCMR 3 Proposed Rule September 2010

8

serving 10,001 to 100,000 people) and very large systems (those serving more than 100,000 

people) will sample and report an average of 2.7 and 3.7 times per system, respectively, across 

the three-year ICR period of 2012-2014. The estimated burden per response for large and very 

large systems, respectively are 6.1 and 6.3 hours.

EPA expects that States will incur only labor costs associated with UCMR 3

implementation. State activities are determined through their individual Partnership Agreements 

with EPA. To estimate State burden, it was assumed that State participation levels would reflect 

the participation levels which occurred in UCMR 1 and UCMR 2. States are assumed to incur 

3.0 responses over the three-year ICR period related to coordination with EPA and systems, with 

an average burden per response of 184 hours. In aggregate, during the ICR period of 2012-2014, 

the average response (e.g., responses from systems and States) is associated with a burden of 8.3

hours, with a labor plus non-labor cost of $2,714 per response.

The annual average per respondent burden hours and costs for the ICR period of 2012-

2014 are: small systems — 1.5 hour burden at $34 for labor; large systems — 5.6 hours at $170

for labor, and $2,381 for analytical costs; very large systems — 7.7 hours at $295 for labor, and 

$5,460 for analytical costs; and States — 233.4 hours at $13,992 for labor. Annual average 

burden and cost per respondent (including both systems and States) is estimated to be 8.3 hours, 

with a labor plus non-labor cost of $1,952 per respondent (note that small systems do not pay for 

testing costs, so they only incur labor costs). 

The Agency estimates the annual burden to EPA for proposed UCMR program activities during 

the ICR years of 2012-2014 to be approximately 8,008 hours, at an annual labor cost of $0.62

million. EPA's annual non-labor costs are estimated to be $2.9 million. EPA's non-labor costs are 

primarily attributed to the cost of sample analysis for small systems (sample analysis represents

approximately 88 percent of non-labor cost).
Draft ICR for UCMR 3 Proposed Rule September 2010

9

2 NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection 

The information collected under this action is required by EPA to carry out its regulatory 

development responsibilities under SDWA section 1445(a)(2), Monitoring Program for 

Unregulated Contaminants. This section, as amended in 1996, requires that once every 5 years,

the Agency issue a new list of no more than 30 contaminants to be monitored, and procedures for 

placement of the monitoring data in NCOD. EPA's program must also include a nationally 

―representative sample of systems serving 10,000 or fewer persons‖ that will be required to 

monitor, and a frequency and schedule for monitoring.

Section 1412(b)(4) of SDWA, as amended in 1996, requires EPA to promulgate 

maximum contaminant level goals (MCLGs) and promulgate National Primary Drinking Water 

Regulations (NPDWRs) for contaminants that: may have adverse human health effects; are 

known to or anticipated to occur in systems; or, in the opinion of the Administrator, present an 

opportunity for reducing health risks. The NPDWRs specify maximum contaminant levels 

(MCLs) or treatment techniques for drinking water contaminants (42 USC 300g-1). An MCL 

must be set as close to the MCLG as possible. NPDWRs apply to systems (42 USC 300f(1)(A)). 

Section 1412(b)(1) requires the Agency to develop a list of unregulated contaminants for 

regulatory consideration (i.e., the candidate contaminant list (CCL)), to issue regulations that 

establish criteria for listing contaminants, and to carry out the UCMR Program. 

Section 1445(a)(1) of SDWA requires each PWS to ―establish and maintain such records, 

make such reports, conduct such monitoring, and provide such information as the Administrator 

may reasonably require by regulation to assist him in establishing regulations, [or] ... in 

evaluating the health risks of unregulated contaminants ...‖. This section authorizes EPA to 

require systems to monitor, provide the Agency with these data, and to maintain records of this 

information.

In addition, section 1401(1)(d) of the SDWA 1996 Amendments defines NPDWRs to 

include ―criteria and procedures to assure a supply of drinking water which dependably complies 

with such maximum contaminant levels including accepted methods for quality control and 

testing procedures ...‖. This section authorizes EPA to require systems and laboratories to use 

Agency-approved methods and quality assurance criteria for collecting and analyzing water 

samples.

The sections from the SDWA 1996 Amendments, discussed above, are included as 

Appendix A of this document, in order by section number. 
Draft ICR for UCMR 3 Proposed Rule September 2010

10

2(b) Practical Utility/Users of the Data 

The UCMR 3 data will support: the development and interactive evolution of the CCL; 

the Administrator's determination of whether to regulate a contaminant; and regulation 

development. In addition, if the contaminant has significant occurrence and health effects, EPA 

will use the results: as part of an exposure assessment; for establishing the baseline for health 

effects and economic analyses; for contaminant co-occurrence analysis; and for treatment 

technology evaluation, including contaminant source management. Further, the results may 

suggest that the occurrence of certain contaminants may be significant enough to initiate research 

on health effects and treatment technology. Finally, the data may guide future source water 

protection efforts.

Each PWS will maintain system level records of the analytical results of this monitoring. 

EPA-approved laboratories will report these results to EPA's electronic data reporting system. 

PWSs will review the information posted by the laboratory and submit the approved data to the 

State and EPA, via the electronic reporting system. The data collected through the UCMR 

program is stored in the NCOD to facilitate analysis and review of contaminant occurrence.

The primary user of the information collected under this ICR will be EPA's Office of 

Water (OW). Other users of this information may include the following:

• Primacy agencies, which include State regulators, Indian Tribes, and, in some 

instances, EPA Regional Administrators 

• PWS managers

• Staff from other EPA programs (such as Comprehensive Environmental 

Response, Compensation, and Liability Act; the Resource Conservation and 

Recovery Act; and the Office of Enforcement and Compliance Assurance)

• Federal Emergency Management Administration

• Centers for Disease Control and Prevention

• Military bases

• Rural Development Administration/Farmers Home Administration

• Department of Interior

• Department of Housing and Urban Development

• United States Army Corps of Engineers

• White House Task Forces

• American Water Works Association

• Association of Metropolitan Water Agencies

• National Rural Water Association

• National Association of Water Companies

• Association of State Drinking Water Administrators (ASDWA)

• Natural Resources Defense Council

• Consumers Federation of America

• Small Business Administration
Draft ICR for UCMR 3 Proposed Rule September 2010

11

• Other environmental and industry groups

• News organizations

• Private industries

• Individuals
Draft ICR for UCMR 3 Proposed Rule September 2010

12

3 NON-DUPLICATION, CONSULTATIONS AND OTHER 

COLLECTION CRITERIA

3(a) Non-duplication 

The data required by UCMR are not available from any other source and are not 

duplicative of information otherwise accessible to EPA. With public health protection as its top 

priority, EPA drew upon several different sources in developing the UCMR 3 contaminant list. 

EPA used a stepwise contaminant identification prioritization process for UCMR 3. As a first 

step, EPA reviewed the recently promulgated Contaminant Candidate List (CCL 3) and the ―preCCL‖ contaminants considered in the development of CCL 3. (Under the CCL 3 process, the 

Agency considered the best available data on health effects and occurrence, and evaluated 7,500 

unregulated contaminants; the final CCL 3 was comprised of 104 chemicals or chemical groups, 

and 12 microbiological contaminants.) EPA used CCL 3, along with additional sources of 

information about emerging contaminants of concern, to establish an initial list of approximately 

150 potential UCMR 3 contaminants. EPA then narrowed that list by eliminating contaminants 

for which methods would not be ready in time for UCMR 3 monitoring. An EPA and State 

working group further considered this narrowed list and used health effects data and other critical 

endpoints to arrive at the proposed list of 30 UCMR 3 analytes.

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

To comply with the 1995 Amendments to the Paperwork Reduction Act, EPA is seeking 

public comment on this ICR. To comment on the Agency's need for this information, the 

accuracy of the provided burden estimates, and any suggested methods for minimizing 

respondent burden, including the use of automated collection techniques, EPA has established a 

public docket for UCMR 3, which includes this ICR, under Docket ID No. OW-2009-0090. The 

public can submit any comments related to the ICR for this proposed action to EPA and the

Office of Management and Budget (OMB). 

3(c) Consultations 

EPA's Office of Ground Water and Drinking Water (OGWDW) incorporated stakeholder 

involvement early in the regulatory development process. In the late 1990s, EPA held meetings 

for the design and development of both the CCL and UCMR programs. Stakeholders who 

provided comments concerning the development of the UCMR program include PWSs, States, 

industry, and other organizations. A total of seventeen meetings were held specifically 
Draft ICR for UCMR 3 Proposed Rule September 2010

13

concerning UCMR development. A description of public involvement activities related to 

UCMR are provided in the September 1999, UCMR Final Rule Federal Register at 64 FR 

50556. A stakeholder meeting was also held for development of UCMR 2 in Washington DC on 

October 29, 2003. State agencies, federal agencies, laboratories, PWSs, and drinking water 

associations discussed: the rationale for selecting a new list of contaminants; analytical methods 

to be used in measuring these contaminants; sampling design, particularly for the Screening 

Survey monitoring; procedure for determining the lowest concentration minimum reporting 

levels (LCMRLs); validation of laboratory performance at or below the minimum reporting level 

(MRL); revisions to data elements; and other proposed revisions based on lessons learned during 

implementation of UCMR 1.

A UCMR 3 stakeholder meeting was held on April 7, 2010, in Washington, DC. There 

were 22 attendees, representing State agencies, laboratories, PWSs, environmental groups, and 

drinking water associations. The presentations and discussions included the following: status of 

UCMR 2; rationale for developing a new list of potential contaminants; analytical methods that 

could be used in measuring these contaminants; sampling design; procedure for determining 

MRLs; laboratory approval; and other potential revisions based on lessons learned during 

implementation of UCMR 1 and UCMR 2.

3(d) Effects of Less Frequent Collection 

The Agency considered a wide range of alternatives for frequency of collection that 

would still allow the Agency to meet its statutory requirements and overall objectives. Less 

frequent data collection than that being implemented would seriously affect the integrity of the 

data and result in insufficient data to fulfill the needs envisioned by the 1996 SDWA 

Amendments, including the continued development of the CCL, support of the Administrator's 

regulatory determinations, and overall regulation development. 

Monitoring frequencies were determined based on statutory requirements, which specify 

that monitoring be varied based on the number of people served by a system, contaminants likely 

to be found, and source of supply. The monitoring frequency design also considers that the 

number of people served affects exposure to contaminants, as well as the resources available to 

undertake monitoring activity. The collection frequencies in this rule are discussed further in 

section 4(b), Part A of this ICR document. Monitoring frequencies have been carefully devised

based on the following factors:

• data quality needed for a representative sample;

• precision and accuracy needed from the representative sample;

• number of people served by the system;

• source of the supply (e.g., surface water or ground water);

• likelihood of finding contaminants; and

• temporal variability in occurrence.
Draft ICR for UCMR 3 Proposed Rule September 2010

14

Assessment Monitoring will be conducted from January 2013 through December 2015 by 

all large systems (those systems serving 10,001 to 100,000 people) and very large systems (those 

systems serving more than 100,000 people), and by a nationally representative sample of 800 

small PWSs (those serving 10,000 people or fewer). Pre-Screen Testing will be conducted from

January 2013 through December 2015 by a sample of 800 undisinfected ground water wells from 

small systems serving 1,000 or fewer people. Samples will be collected from entry points to the 

distribution system (EPTDSs) for all contaminants. In addition, samples for the four metals and 

chlorate under Assessment Monitoring will be collected from the DSMRT. As specified in the 

proposed rule, ground water systems with multiple EPTDSs will only be required to sample at 

representative sampling locations for each ground water source, as long as those sites have been 

approved.

Sampling locations3fed by ground water will be collected twice during the monitoring 

year (i.e., 12-month monitoring cycle), and locations fed by surface water or ground water under 

the direct influence of surface water (GWUDI) will be collected four times during the monitoring

year. Multiple samples during a year are necessary to capture the temporal variability in 

contaminant occurrence to support an adequate characterization of potential exposure. The 

required sampling frequencies help provide the quality and quantity of data that will be 

statistically necessary for regulatory determinations. The Agency will schedule the year and 

months of system monitoring. PWSs will have the option of changing their schedules by 

coordinating a new schedule with EPA.

EPA is maintaining the same statistical design established under UCMR 1 for its UCMR 

3 national representative sample of 800 small systems and continuing with a census of large 

systems for Assessment Monitoring. EPA believes that the combination of a nationally 

representative sample of small systems and a census of large systems provides a powerful tool 

for assessing contaminant occurrence in PWSs; this is the most effective and accurate survey 

approach. A sample of 800 PWSs from the universe of over 63,000 small systems will provide a 

confidence level of 99 percent with an allowable error of ±1 percent. The set of representative 

PWSs are distributed among different size categories, but weighted by population served, to 

ensure that the sample can provide estimates of exposure.

EPA has selected this design to ensure the quality of the results. EPA considered larger 

sample frames because of the many uncertainties involved, but the sample size of 800 was 

deemed adequate to meet the needs for the national estimate. Smaller sample sizes (i.e., fewer 

systems monitored) were also considered, but rejected. Some population surveys with continuous 

variables use a lower level of confidence (95 percent) and/or a larger allowable error. However, 

the larger possible error is not considered acceptable for this program. Examination and analysis 

 

3

Ground water systems are required to sample only two times per year because they generally show less seasonal 

fluctuation than surface water or GWUDI systems. Rule language regarding sampling schedule/frequency ensures 

that both surface and ground water systems collect at least one of their samples during the most vulnerable period, 

which the rule specifies by default to be May - July. 
Draft ICR for UCMR 3 Proposed Rule September 2010

15

of current occurrence data show that many contaminants that are currently regulated, or being 

considered for regulation occur in 1 percent or less of systems on a national basis. For many 

contaminants, a 1 percent occurrence nationally translates into a substantially larger occurrence 

regionally. Also, even a small percentage of systems with detections can translate into a 

significant population affected. With a greater margin of error, and the resultant smaller sample 

size, such occurrence might be missed entirely. Also, it is necessary for EPA to make some 

judgments about the occurrence of contaminants in relation to source waters and different size 

categories of systems. Many statutes and current regulations differentiate implementation 

requirements based on system size or water source. While combining sampling results from the 

representative sample of small systems with that from all large systems provides increased power 

in the total sample, EPA must be able to evaluate occurrence, and possible regulatory options, 

related to the small systems. SDWA and many current rules focus on burden reduction for small 

systems when feasible. Also, there are many other uncertainties and sources of variance in such a 

sample program. For example, all contaminants have censored distributions (i.e., ―less than 

detection level‖ analytical results) and there are a myriad of factors that affect variability and 

vulnerability of ground water systems. It remains unclear how normal sampling theory 

accommodates these. Hence, the high confidence level, low allowable error, and larger sample 

size should help to ensure adequate data to meet the objectives of the UCMR program. 

Screening Surveys were conducted under both UCMR 1 and UCMR 2 to help assess 

contaminant occurrence. There is no ―Screening Survey‖ component to the UCMR 3 program 

because there are currently no contaminants on List 2; all UCMR 3 contaminants were deemed 

appropriate for List 1 or List 3.

The objectives of Pre-Screen Testing are to: obtain occurrence information to support 

regulatory determination of enterovirus and norovirus; gain a better understanding of pathogen 

indicator and viral co-occurrence; and gain more exposure/health risk information on viruses and 

indicators. The sample of systems selected to monitor for Pre-Screen Testing is a targeted sample 

consisting of wells that EPA has determined are most vulnerable to the List 3 contaminants. The 

wells will be selected from areas of karst or fractured bedrock. The sample size of 800 

undisinfected ground water wells will include CWSs, NTNCWSs, and TNCWSs, which ensures 

that sample results are representative of different types of water systems. 

Since it is possible that certain contaminants are not likely to be found in a particular 

State, UCMR includes a provision for waivers for large systems on a State-wide, chemicalspecific basis. However, for small systems, waivers will not be considered because eliminating 

small systems from the nationally representative sample would compromise the data quality and 

consistency requirements of a representative sample. The representative sample must provide 

adequate information on both the presence and absence of contaminants for the systems sampled. 

Furthermore, since EPA will pay for this testing, there is no significant burden on these small 

systems. 
Draft ICR for UCMR 3 Proposed Rule September 2010

16

3(e) General Guidelines 

This ICR has been completed in accordance with the November 2005 version of EPA's 

Guide to Writing Information Collection Requests Under the Paperwork Reduction Act of 1995

(hereafter, the ―ICR Handbook‖). The ICR Handbook was prepared by EPA's Office of 

Environmental Information, Collection Strategies Division. The ICR Handbook provides the 

most current instructions for ICR preparation to ensure compliance with the 1995 Paperwork 

Reduction Act Amendments and OMB's implementing guidelines.

EPA is taking an approach that minimizes burden on the respondents. In addition, this 

collection complies with all OMB guidelines for information collection activities. Specifically, 

the respondents are not required to:

• Report information to EPA more than quarterly.

• Prepare a written response to a collection of information in fewer than 30 days 

after receipt of a request.

• Submit more than an original and two copies of any document.

• Retain records, other than health, medical, government contract, grant-in-aid or 

tax records, for more than three years.

• Participate in a statistical survey that is not designed to produce data that can be 

generalized to the universe of the study.

• Use a statistical data classification that has not been reviewed and approved by 

OMB.

• Receive a pledge of confidentiality that is not supported by authority established 

in statute or regulation, that is not supported by disclosure and data security 

policies that are consistent with the pledge, or which unnecessarily impedes 

sharing of data with other agencies for compatible confidential use.

• Submit proprietary, trade secret, or other confidential information unless EPA can 

demonstrate that it has instituted procedures to protect the information's 

confidentiality to the extent permitted by law.

3(f) Confidentiality 

This information collection does not require respondents to disclose confidential 

information.

3(g) Sensitive Questions 

No questions of a sensitive nature are included in any of the information collection 

requirements outlined in this ICR.
Draft ICR for UCMR 3 Proposed Rule September 2010

17

4 RESPONDENTS AND THE INFORMATION

4(a) Respondents and NAICS/SIC Codes 

Data associated with this ICR are collected and maintained by PWSs. States, Territories, 

and Tribes with primacy to administer the regulatory program for PWSs under SDWA may 

participate in UCMR 3 implementation through a Partnership Agreement (PA). These primacy 

agencies may sometimes conduct monitoring and maintain records. The North American 

Industry Classification System (NAICS) code for PWSs is 22131. The NAICS code for State 

agencies that include drinking water programs are classified as 92411 (Administration of Air and 

Water Resources and Solid Waste Management Programs) or 92312 (Administration of Public 

Health Programs). 

4(b) Information Requested 

This ICR summarizes the data items and respondent activities associated with UCMR 3.

4(b)(i) Data Items 

A discussion of data and information that are part of the reporting and record keeping 

requirements for systems is found below in section 4(b)(i)(a), Part A of this ICR document. The 

requirements for States are discussed below in section 4(b)(i)(b), Part A of this ICR document.

4(b)(i)(a) Public Water System Reporting and Record Keeping 

Section 141.35 requires PWSs that are subject to the UCMR requirements to report 

monitoring results for the 30 contaminants listed in §141.40 to EPA (see Exhibit 1 for the 

contaminant list). The proposed rule adds codes for the chlorine residual treatment information 

that is required to be reported by all PWSs. 
Draft ICR for UCMR 3 Proposed Rule September 2010

18

Exhibit 1: Proposed UCMR 3 Contaminant Lists

Assessment Monitoring (List 1)

17-β-estradiol chlorodifluoromethane (HCFC-22)

17-α-ethynylestradiol (ethinyl estradiol) bromochloromethane (Halon 1011)

estriol 1,4-dioxane

equilin vanadium

estrone molybdenum

testosterone cobalt

4-androstene-3,17-dione strontium

1,2,3-trichloropropane chlorate

1,3-butadiene perfluorooctane sulfonic acid (PFOS) 

chloromethane (methyl chloride) perfluorooctanoic acid (PFOA)

1,1-dichloroethane perfluorononanoic acid (PFNA) 

n-propylbenzene perfluorohexane sulfonic acid (PFHxS) 

bromomethane (methyl bromide) perfluoroheptanoic acid (PFHpA) 

sec-butylbenzene perfluorobutanesulfonic acid (PFBS)

Pre-Screen Testing (List 3)

enteroviruses noroviruses

The proposed action also modifies the reporting requirements to make reported results 

more useful for sound scientific analyses of the occurrence of unregulated contaminants. The 15 

required data elements are listed in Exhibit 2. All systems must electronically report all 15 data 

elements with their Assessment Monitoring and Pre-Screen Testing samples. All systems 

participating in UCMR monitoring must inform EPA of any changes to data elements 1 through 

6, if applicable. 
Draft ICR for UCMR 3 Proposed Rule September 2010

19

Exhibit 2: UCMR 3 Reporting Requirements

1. Public Water System Identification (PWSID) Code 9. Contaminant

2. Public Water System Facility Identification Code 10. Analytical Method Code

3. Water Source Type 11. Sample Analysis Type

4. Sampling Point Identification Code and Zip Code 12. Analytical Results – Sign

5. Sampling Point Type Identification Code 13. Analytical Result – Value

6. Disinfectant Type 14. Laboratory Identification Code

7. Sample Collection Date 15. Sample Event Code

8. Sample Identification Code

4(b)(i)(b) State Reporting and Record Keeping 

As was true for UCMR 1 and UCMR 2, the UCMR 3 proposed regulation will be a direct 

implementation rule, and therefore States will not be required to report to EPA. Implementation 

activities for each State will be identified and determined through PAs with EPA. If participating 

in a PA, States will at a minimum be reviewing and revising Initial State Monitoring Plans, 

notifying systems of their UCMR responsibilities, and providing EPA with a list of the systems 

notified. Because States have no specified reporting cycle, it is assumed that States have 1.0 

response per year, encompassing all communication and coordination activities with EPA and 

systems. 

4(b)(ii) Respondent Activities 

Respondents include both PWSs and States. PWS and State activities are discussed below 

in sections 4(b)(ii)(a) and 4(b)(ii)(b), respectively (Part A of this ICR document).

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

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

following activities:

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

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

• report and maintain records; and 

• report to the public.

Each of these activities is discussed in more detail below. 
Draft ICR for UCMR 3 Proposed Rule September 2010

20

Read Regulations/State Letter: All PWSs participating in UCMR monitoring are assumed 

to read the UCMR regulations and/or a State-issued guidance letter during the year in which their 

monitoring will occur. Small PWSs can rely on summarized information from the State or EPA

for information pertaining to the regulation, rather than reading the regulation. 

Monitoring or Monitoring Assistance: Monitoring activities that are considered in the 

system cost and burden estimates include receiving sampling kits from the laboratory, reading 

sampling instructions, and collecting and shipping the sample. Assessment Monitoring and PreScreen Testing are scheduled to occur from January 2013 through December 2015 for 30 

contaminants. Because an equal percentage of systems are assumed to monitor during each 

consecutive 12-month period, two-thirds of systems required to conduct Assessment Monitoring 

and Pre-Screen Testing will monitor during the ICR period of 2012-2014, however, the last 

group of systems will monitor in 2015, which is outside of the time period covered by this ICR. 

To provide a comprehensive cost estimate for the proposed rule, Appendix B provides 

monitoring costs for the entire monitoring period of 2013-2015.

For Assessment Monitoring, surface water (and GWUDI) sampling points will be 

monitored four times during the applicable year of monitoring, and ground water sampling points 

will be monitored twice during the applicable year of monitoring. Monitoring will be conducted 

at EPTDSs. Large ground water systems with multiple EPTDSs will only be required to sample 

at representative sampling locations for each ground water source, as long as those sites have 

been approved by EPA or the State. In addition, samples for the four metals and chlorate under 

Assessment Monitoring will be collected from the DSMRT. For Pre-Screen Testing, two samples 

will be collected from wells during one 12-month monitoring period during 2013-2015. 

Reporting and Record Keeping: Activities related to these reporting requirements 

include: 

• Reporting Prior to Monitoring

Contact information: As under UCMR 1 and UCMR 2, large systems are required 

to report contact information to EPA. This information includes the name, 

affiliation, mailing address, phone number, facsimile number, and e-mail address 

for the PWS Technical Contact and PWS Official (i.e., the official spokesperson 

for a PWS’s UCMR activities). Information must be submitted to EPA’s 

electronic data reporting system within a specified time frame after rule 

promulgation. Small systems must provide this information in response to a 

specific written request that they will receive from EPA. 

Sampling location information: Prior to sampling, large PWSs must also provide 

inventory information related to each applicable sampling location. For each

sampling location or each approved representative sampling location, large PWSs 

must submit: PWS identification (PWSID) code; PWS facility identification code; 
Draft ICR for UCMR 3 Proposed Rule September 2010

21

sampling point identification code and zip code; sampling point type 

identification code; sampling location water type. 

Representative EPTDS proposal: Some systems that use ground water as a source 

and have multiple EPTDSs may monitor at representative entry point(s), rather 

than at each EPTDS. To qualify, these ground water systems must have either the 

same treatment or no treatment at all of their well sources and they must have an 

EPTDS for each well within a well field (resulting in multiple EPTDSs from the 

same source, such as an aquifer). Systems meeting these criteria can submit a 

proposal to EPA or the State. The proposal must demonstrate that any EPTDS 

selected as representative of the ground water supplied from multiple wells be 

associated with an individual well that draws from the same aquifer as the 

multiple wells (i.e., those being represented). The representative well must be one 

of the higher annual volume producing and more consistently active wells in the 

representative array. If that representative well is not in use at the scheduled 

sampling time, an alternative representative well must be sampled.

• Reporting Monitoring Results

Small systems: As under UCMR 2, small systems are only required to record 

system and sample location information on the sampling forms and bottles that 

are sent to them by the UCMR Sampling Coordinator. The schedule for 

submitting this information is specified in the instructions sent to the system. 

Large systems: UCMR 3 specifies that laboratories must post the analytical 

results and associated data elements to EPA’s electronic data reporting system 

within 60 days of sample collection. Under UCMR 1 and UCMR 2, results were 

to be reported to EPA’s data system within 120 days. This time period made it 

difficult to ensure compliance with monitoring schedules. The shorter reporting 

period will help ensure that scheduled monitoring is conducted. Large systems 

also must ensure that their laboratory meets this requirement, and that systems 

review, approve, and submit the data to the State and EPA via the electronic 

reporting system within 30 days from when the laboratory posts the data. After 30

days from the laboratory's posting, if the PWS has not taken action, the data are

considered approved and final for EPA review.

• Record Keeping

Section 141.33 requires systems to maintain records of chemical monitoring data 

for 10 years. No changes are being made to those record keeping requirements.

Reporting to the Public: SDWA section 1445(a)(2)(E) requires notification of the results 

of the UCMR program to be made available to those served by the system. CWSs are required to 
Draft ICR for UCMR 3 Proposed Rule September 2010

22

notify their users of the detection of any contaminants (including unregulated contaminants) in 

their Consumer Confidence Reports (CCRs), pursuant to §141.153(d)(3)(iv), published in the 

Federal Register (63 FR 44512 (August 19, 1998)). Monitoring and reporting violations for all 

systems (CWSs, NTNCWSs, and TNCWSs) will be reportable under the Public Notification 

Rule (64 FR 25964 (May 13, 1999)). No changes are being made to these reporting 

requirements.

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

For UCMR 1, EPA estimated State burdens and costs using the 1993 State Resource 

Model (documented in the ―Resource Analysis Computer Program for State Drinking Water 

Agencies‖). That model was designed by EPA in coordination with ASDWA and required 

specific input for a list of activities and variables related to State operation of the UCMR 

drinking water program (e.g., number of systems affected, estimates of violation rates, etc.). 

Since that time, EPA and ASDWA have worked together to update and improve the previous 

version of the resource model. EPA used the updated resource model (the ―2001 ASDWA 

Drinking Water Program Resource Needs Self Assessment‖, as documented in: ―Public Health 

Protection Threatened by Inadequate Resources for State Drinking Water Programs - An 

Analysis of State Drinking Water Program Resources, Needs, and Barriers‖; ASDWA, April 

2003) to estimate resources that States may need for the oversight and implementation of UCMR 

3. Assumptions that were applied in using this resource assessment tool are described in section 

6(b), Part A of this ICR document. EPA assumes that State participation will closely reflect that 

which occurred during UCMR 2. Therefore, model estimates were adjusted to account for actual 

levels of prior State participation. 

Since UCMR is a direct implementation rule, specifics of each State’s role will be 

delineated in PAs between the States and EPA. However, in response to the regulation, EPA 

anticipates that State activities will generally include EPA coordination activities/PAs, data 

management and support, program implementation, and training/overhead. Though some States 

may choose to conduct sampling for their systems, this activity is not part of the PA agreement 

and is optional for States. Burden for sampling is currently attributed to systems only. If States 

choose to conduct monitoring for systems, burden would be similar to that estimated for systems.

State Coordination with EPA/PAs: State activities that involve coordination with EPA 

include coordination and drafting of a PA, review of and response to EPA’s proposed State 

Monitoring Plan, review of PWS proposals for representative EPTDSs, and general ongoing 

coordination. 

Review of State Monitoring Plans will be one of the first UCMR activities to take place

at the State level. Each State will receive a proposed initial State Monitoring Plan from EPA. 

This plan will list all systems that will be required to conduct Assessment Monitoring and PreScreen Testing, including small and large systems that were statistically selected as a sample, 

and those large systems subject to the rule by meeting applicability criteria. For systems that are 

part of the sample, EPA will also generate a list to provide similar replacement systems for 
Draft ICR for UCMR 3 Proposed Rule September 2010

23

States to select from, for those systems that may not have been correctly specified in the initial 

plan. If a State identifies systems on the original proposed State Monitoring Plan that it 

determines are not appropriate for the representative sample (e.g., if systems are inactive, or sell 

all of their water and do not have their own retail customers), the State can propose an alternative 

plan by selecting other systems from EPA’s alternate list to replace the ineligible systems. The 

State Monitoring Plans will also specify the year and months during which regulated systems 

will monitor. States will have the option to modify these schedules. 

Some systems that use ground water as a source of water are expected to submit a 

proposal for monitoring at representative entry point(s), rather than monitor at every EPTDS. 

State involvement in the review of these proposals will be determined in the PA process. 

EPA also recognizes that it will be necessary for States to maintain ongoing 

communications with EPA regarding the requirements of UCMR. An example of this would be 

instances when States need clarification and guidance regarding a specific requirement of the 

regulation. 

Data Management and Support: Though there are no data management and support 

activities included in UCMR, EPA recognizes that many States will update their databases to 

accommodate the revised UCMR data elements. Activities will likely include data 

entry/downloading of data, and general record keeping. 

Program Implementation: Program implementation activities for each State may include 

notification and guidance letter to systems, data review, ongoing system support, and 

enforcement. 

Following review and finalization of State Monitoring Plans, participating States will 

prepare a notification letter that describes system monitoring schedules and requirements under 

the regulation. These States will send notification to each applicable system and send the list of 

these notified systems to EPA. It is also likely that States will receive telephone calls from water 

systems asking for clarification and guidance pertaining to the requirements of UCMR. States 

may choose to review monitoring results, in part to determine whether a system has met its 

monitoring and reporting requirements.

State Staff Training and Overhead: Technical staff members are assumed to participate in 

rule-specific training designed to assist them in understanding the regulation, their roles and 

responsibilities, and to allow the State to better provide technical assistance to the systems. In 

addition, general overhead costs, such as clerical and managerial needs, are allocated to the 

UCMR staff requirements in the standard State Resource Model, which allocates support staff 

needs as a percentage of professional staff needs. See section 6(b), Part A of this ICR document, 

for further discussion of model assumptions.
Draft ICR for UCMR 3 Proposed Rule September 2010

24

5 INFORMATION COLLECTED–AGENCY ACTIVITIES, 

COLLECTION METHODOLOGY, AND INFORMATION 

MANAGEMENT

5(a) Agency Activities 

EPA Headquarters and Regional offices will be responsible for oversight of State PWS 

programs, and processing and analysis of the UCMR data. EPA implementation activities are 

categorized, as follows, into three major categories: regulatory support activities; program 

oversight and data analysis; and small system testing program, which are described below, in 

5(a)(i)-(iii).

5(a)(i) Regulatory Support Activities 

Regulatory support activities include: laboratory approval and quality assurance/quality 

control; and technical support to PWSs, such as guidance documents. 

Laboratory Approval and Quality Assurance/Quality Control (QA/QC) Activities: EPA 

anticipates incurring various costs related to laboratory approvals and laboratory quality 

assurance and control, including the following activities:

• Laboratory approvals/Proficiency Testing (PT) program - EPA will assess 

whether laboratories meet the required equipment, laboratory performance, and 

data reporting criteria. EPA will register and evaluate laboratories based on the 

applications. Selected laboratories will then participate in the UCMR 3 PT 

program. EPA plans to conduct these laboratory assessments during 2012.

• QC audits of contract laboratories - EPA expects to conduct QC audits at each of 

the approved laboratories during each year of UCMR 3 monitoring (January 2013

through December 2015).

• Analytical standards provision and coordination - EPA will coordinate and 

distribute specialized analytical standards to participating laboratories.

Technical Support/Guidance Document Development: Technical support and guidance 

document includes developing and distributing guidance for laboratory calculations and 

background information about the health effects (e.g., fact sheets) of the UCMR 3 contaminants. 
Draft ICR for UCMR 3 Proposed Rule September 2010

25

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

EPA’s UCMR program activities include data analysis, management oversight, and 

implementation assistance to States. These are key management and oversight activities that 

must be conducted by EPA Headquarters or its Regional offices. Exhibit 3, below, illustrates the 

timeline for UCMR implementation activities. EPA will develop its PAs with States and the 

State Monitoring Plans prior to January 2013, when monitoring will begin. 

Exhibit 3: Proposed Timeline of UCMR 3 Activities

2012 2013 2014 2015 2016

EPA lab approval 

program begins

EPA/State PAs 

and state 

monitoring plans 

developed 

(including Nat. 

Rep. sample, and 

Ground Water 

systems for List 

3)

Inform PWSs/ 

establish 

monitoring plans

Complete 

reporting and 

Assessment Monitoring analysis of data

List 1 Contaminants

All systems serving more than 10,000; 800 systems 

serving 10,000 or fewer

Pre-Screen Testing

List 3 Contaminants 

800 non-disinfecting ground water wells from 

systems serving 1,000 or fewer

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

 EPA expects that implementation of the small system testing program will be the largest 

portion of Agency costs for the UCMR program. Prior to monitoring, EPA activities for 

logistical support of the small system testing program will include coordination of small system 

testing and provision of testing supplies. 

 The single largest cost to EPA for implementation of UCMR is for small system sample 

analyses. During the ICR period of 2012-2014, EPA will pay for the analytical and shipping 

costs for small systems in the national representative sample for two-thirds of Assessment 

Monitoring and Pre-Screen Testing (the monitoring period of January through December 2015 
Draft ICR for UCMR 3 Proposed Rule September 2010

26

falls outside of the ICR period). EPA also expects to conduct some QC activities that will not be 

required of the large systems. Specifically, EPA plans to send duplicates of 10 percent of small 

system samples to a separate laboratory for analysis. The quality control duplicates are intended 

to provide standard, real time, QC checks among the different contract laboratories. 

5(b) Information Collection Methodology and Management 

As under UCMR 2, UCMR 3 continues to specify that laboratories must report the 

analytical results and associated data elements to EPA’s electronic data reporting system. Large 

systems must ensure that their laboratory posts the data in EPA’s electronic data reporting 

system, and must review, approve, and submit the data to the State and EPA via the EPA 

electronic reporting system. UCMR 3 shortens the amount of time allotted for reporting and 

review to ensure timely compliance with monitoring and reporting. Laboratories now have 60 

days rather than 120 days from sample collection to report. Systems have 30 days (rather than 60 

days) from the laboratory’s posting to review and approve the reported results. After this, if the 

PWS has not taken action, the data will be considered approved and final for EPA review. 

Electronic reporting provides significant collection efficiencies, and reduces the possibility of

data input error.

The UCMR data will be maintained and analyzed through NCOD. The data collected 

under UCMR will be used for regulation development, to analyze the significance of occurrence 

and health effects, and to support the critical Agency function of program oversight. The public 

will receive information regarding UCMR monitoring results through the CCRs, and will be able 

to access data through the NCOD. In addition, systems that fail to monitor for unregulated 

contaminants will be required to notify the public of their failure to monitor.

EPA plans to conduct ongoing data analysis which will include checks for anomalies in 

the data that may be related to data entry or laboratory errors. Data quality review and analysis 

includes: continuous analysis of laboratory results, review of all program data, and NCOD 

review.

5(c) Small Entity Flexibility 

Note: The following Small Business Regulatory Enforcement Fairness Act analysis 

summary is the same as that provided in the preamble to the proposed rule. The 

Regulatory Flexibility Act analysis is based on the entire five-year UCMR 

implementation period of 2012-2016, rather the three-year ICR period of 2012-2014.

The Regulatory Flexibility Act (RFA) generally requires an agency to prepare a 

regulatory flexibility analysis of any rule subject to notice and comment rulemaking 
Draft ICR for UCMR 3 Proposed Rule September 2010

27

requirements under the Administrative Procedure Act or any other statute unless the agency 

certifies that the rule will not have a significant economic impact on a substantial number of 

small entities. Small entities include small businesses, small organizations, and small 

governmental jurisdictions.

The RFA provides default definitions for each type of small entity. Small entities are 

defined as: (1) a small business as defined by the Small Business Administration's (SBA) 

regulations at 13 CFR 121.201; (2) a small governmental jurisdiction that is a government of a 

city, county, town, school district or special district with a population of less than 50,000; and (3) 

a small organization that is any ―not-for-profit enterprise which is independently owned and 

operated and is not dominant in its field.‖ However, the RFA also authorizes an agency to use 

alternative definitions for each category of small entity, ―which are appropriate to the activities 

of the agency‖ after proposing the alternative definition(s) in the Federal Register and taking 

comment (5 U.S.C. 601(3) - (5)). In addition, to establish an alternative small business definition, 

agencies must consult with SBA's Chief Counsel for Advocacy. 

For purposes of assessing the impacts of today's proposed rule on small entities, EPA 

considered small entities to be PWSs serving 10,000 or fewer people, because this is the system 

size specified in SDWA as requiring special consideration with respect to small system 

flexibility. As required by the RFA, EPA proposed using this alternative definition in the Federal 

Register, (63 FR 7605, February 13, 1998), requested public comment, consulted with the SBA, 

and finalized the alternative definition in the Consumer Confidence Reports rulemaking, (63 FR 

44511, August 19, 1998). As stated in that Final rule, the alternative definition would be applied 

to this regulation as well.

After considering the economic impacts of today's proposed rule on small entities, EPA 

has determined that this action will not have a significant economic impact on a substantial 

number of small entities. The small entities directly regulated by this proposed rule are PWSs 

serving 10,000 or fewer people. EPA has determined that the small entities subject to the 

requirements of this proposed rule are a subset of the small PWSs (those serving 10,000 or fewer 

people). The Agency has determined that 1,600 small PWSs (across Assessment Monitoring and 

Pre-Screen Testing), or approximately 3 percent of small systems, will experience an impact of 

less than 0.4 percent of revenues; the remainder of small systems will not be impacted.

Although this proposed rule will not have a significant economic impact on a substantial 

number of small entities, EPA nonetheless has tried to reduce the impact of this rule on small 

entities. To ensure that this proposed rule will not have a significant economic impact on a 

substantial number of small entities, EPA will assume all costs for analyses of the samples and 

for shipping the samples from these systems to the laboratories contracted by EPA to analyze 

UCMR 3 samples. EPA has set aside $2.0 million each year from the State Revolving Fund 

(SRF) with its authority to use SRF monies for the purposes of implementing this provision of 

SDWA. Thus, the costs to these small systems will be limited to the labor hours associated with 

collecting a sample and preparing it for shipping. 
Draft ICR for UCMR 3 Proposed Rule September 2010

28

The Agency continues to be interested in the potential impacts of the proposed rule on 

small entities and welcomes comments on issues related to such impacts.

The evaluation of the overall impact on small systems, summarized in the preceding 

discussion, is further described as follows. EPA analyzed the impacts for privately-owned and 

publicly-owned water systems separately, due to the different economic characteristics of these 

ownership types, such as different rate structures and profit goals. However, for both publiclyand privately-owned systems, EPA used the ―revenue test,‖ which compares annual system costs 

attributed to the rule to the system’s annual revenues. Median revenue data from the 2006 

Community Water System Survey were used for public and private water systems. EPA assumes 

that the distribution of the sample of participating small systems will reflect the proportions of 

publicly- and privately-owned systems in the national inventory. The estimated distribution of 

the representative sample, categorized by ownership type, source water, and system size, is 

presented in Exhibit 4.

Exhibit 4: Number of Publicly- and Privately-Owned Small Systems Subject to UCMR 3

System Size Publicly-Owned Privately-Owned Total

Ground Water

500 and under 126 378 504

501 to 3,300 477 182 659

3,301 to 10,000 207 48 255

Subtotal GW 810 608 1,418

Surface Water (and GWUDI)

500 and under 2 3 5

501 to 3,300 35 13 48

3,301 to 10,000 100 29 129

Subtotal SW 137 45 182

Total of Small Water 

Systems 947 653 1,600

The basis for the UCMR 3 RFA certification for this proposed rule is as follows: for the 

1,600 small water systems that will be affected, the average annual costs for complying with this 

rule represent less than 0.4 percent of system revenues (the highest estimated percentage is for 
Draft ICR for UCMR 3 Proposed Rule September 2010

29

ground water systems serving 500 or fewer people, at 0.38 percent of its median revenue). 

Exhibit 5 presents the yearly costs to small systems, and to EPA for the small system sampling 

program, along with an illustration of system participation for each year of the UCMR 3 

program.

Exhibit 5: EPA and Systems Costs for Implementation of UCMR 3 at Small Systems

Cost 

Description 2012 2013 2014 2015 2016 Total

Costs to EPA for Small System Program (including Assessment Monitoring, and Pre-Screen 

Testing)

$0 $3,943,827 $3,943,827 $3,943,827 $0 $11,831,480

Costs to Small Systems (including Assessment Monitoring, and Pre-Screen Testing):

$0 $81,707 $81,707 $81,707 $0 $245,120

Total Costs to EPA and Small Systems for UCMR 3

$0 $4,025,533 $4,025,533 $4,025,533 $0 $12,076,599

System Monitoring Activity Timeline:1

Assessment 

Monitoring

1/3 PWSs 

Sample

1/3 PWSs 

Sample

1/3 PWSs 

Sample 800

Pre-Screen 

Testing

1/3 PWSs 

Sample

1/3 PWSs 

Sample

1/3 PWSs 

Sample 800

1

Total number of systems is 1,600. No small system conducts more than one type of monitoring study.

System costs are attributed to the labor required for reading about their requirements, 

monitoring, reporting, and record keeping. The estimated average annual burden across the fiveyear UCMR 3 implementation period of 2012-2016 is estimated to be 1.3 hours at $31 per small 

system. Average annual cost, in all cases, is less than 0.4 percent of system revenues. As 

required by the SDWA, the Agency specifically structured the rule to avoid significantly 

affecting small entities by assuming all costs for laboratory analyses, shipping, and quality 

control for small entities. As a result, EPA incurs the entirety of the non-labor costs associated 

with UCMR 3 small system monitoring, or 98 percent of total small system testing costs. 

Exhibits 6 and 7 present the estimated economic impacts in the form of a revenue test for 

publicly- and privately-owned systems. 
Draft ICR for UCMR 3 Proposed Rule September 2010

30

Exhibit 6: UCMR 3 Relative Cost Analysis for Small Publicly-Owned Systems (2012-

2016)

System Size

Annual Number 

of Systems 

Impacted 

Average Annual 

Hours per 

System (2012-

2016)

Average Annual 

Cost per System 

(2012-2016)

Revenue Test 1

Ground Water Systems

500 and under 25 1.1 $22.63 0.07%

501 to 3,300 96 1.2 $26.84 0.02%

3,301 to 10,000 41 1.7 $43.71 0.01%

Surface Water (and GWUDI) Systems

500 and under 1 1.8 $38.06 0.07%

501 to 3,300 7 1.9 $41.99 0.02%

3,301 to 10,000 20 2.0 $51.02 0.005%

1 The Revenue Test was used to evaluate the economic impact of an information collection on small government entities 

(e.g., publicly-owned systems); costs are presented as a percentage of median annual revenue in each size category.
Draft ICR for UCMR 3 Proposed Rule September 2010

31

Exhibit 7: UCMR 3 Relative Cost Analysis for Small Privately-Owned Systems (2012-

2016) 

System Size

Annual Number 

of Systems 

Impacted 

Average Annual 

Hours per 

System (2012-

2016)

Average Annual 

Cost per System 

(2012-2016)

Revenue Test 1

Ground Water Systems

500 and under 76 1.1 $22.63 0.38%

501 to 3,300 36 1.2 $26.84 0.02%

3,301 to 10,000 10 1.7 $43.71 0.004%

Surface Water (and GWUDI) Systems

500 and under 1 1.8 $38.06 0.11%

501 to 3,300 3 1.9 $41.99 0.02%

3,301 to 10,000 6 2.0 $51.02 0.005%

1

The "Revenue Test" was used to evaluate the economic impact of an information collection on small private entities (e.g., 

privately-owned systems); costs are presented as a percentage of median annual revenue in each size category.

5(d) Collection Schedule 

EPA is proposing to use the same monitoring frequency as that used under UCMR 1 and 

2 for Assessment Monitoring because the Agency believes that the frequency is sufficient to 

gather necessary information on occurrence of unregulated contaminants, without significantly 

burdening small systems. Assessment Monitoring and Pre-Screen Testing activities are expected 

to occur from January 2013 through December 2015. 

For Assessment Monitoring, surface water or GWUDI systems will collect four samples 

as follows: systems will select either the first, second, or third month of a quarter and sample in 

that same month of each of four consecutive quarters to ensure that one of those sampling events 

occurs during the vulnerable time. Ground water systems will collect samples two times in a year 

as follows: systems will sample during one month of the vulnerable time (typically May through 

July) and during one month, five to seven months earlier or later. For Pre-Screen Testing, small 

systems will collect two samples at selected undisinfected ground water wells for enteroviruses

and noroviruses on the same schedule as for ground water systems under Assessment 

Monitoring. Small systems must also allow the collection of samples for E. coli, Coliphage, 

Enterococci, and aerobic spores. Small systems will be selected for no more than one component 
Draft ICR for UCMR 3 Proposed Rule September 2010

32

of UCMR monitoring. UCMR activities that occur after the year 2014 are not included in this 

ICR analysis. However, Appendix B contains estimations for the five-year UCMR 3 program, 

2012-2016. Exhibits 3 and 9 illustrate the timeline of general UCMR activities, and system 

monitoring activities, respectively. 
Draft ICR for UCMR 3 Proposed Rule September 2010

33

6 ESTIMATING THE BURDEN AND COST OF THE COLLECTION

This section describes the respondent burden and cost for activities under UCMR 3. The 

burden and cost estimates for PWSs are shown in section 6(a), burden and costs to States are 

shown in section 6(b), and the Agency's burden and cost estimates are shown in section 6(c) (all 

in Part A of this ICR document). 

This ICR focuses only on the cost of the UCMR data collection over the years 2012-

2014. Cost tables that are presented in this section have analogous tables in Appendix B, which 

present costs for the entire monitoring cycle (2012-2016). 

There are two primary categories of costs associated with UCMR: (1) labor costs, such as 

program implementation, sample collection, record keeping, reporting, and data analysis; and (2) 

non-labor costs, such as laboratory fees for analyses of samples, shipping charges, and contractor 

costs. The majority of costs are directly attributed to monitoring activities and the fees for 

laboratory analytical services. Assessment Monitoring targets a list of 28 contaminants and the 

Pre-Screen Testing targets 2 contaminants.

EPA is committed to accurately characterizing the burden and costs of rules it 

promulgates. In the development of various drinking water program rule ICRs, EPA has

developed a consistent set of assumptions to use in calculations. These have been developed and 

utilized in other drinking water program evaluations. Pertinent to the UCMR ICR are the 

standard assumptions for labor rates, system inventory numbers (the number of water systems in 

the various size categories by primary water source), the number of sampling points for each 

system, and analytical services. The sources and assumptions used in estimating costs and 

burdens are described below.

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

Specific assumptions used in estimating system labor burden and cost, as well as nonlabor costs are discussed in sections 6(a)(i) and 6(a)(ii), respectively (Part A of this ICR 

document). A summary of the costs estimates is provided in section 6(a)(iii), Part A of this ICR 

document.

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

estimates: 

• Inventory Data: CWS and NTNCWS inventory was based on a June 6, 2010 

inventory extract from SDWIS/Fed.
Draft ICR for UCMR 3 Proposed Rule September 2010

34

• EPTDS Data: All EPTDS data were taken from the 2006 CWSS (EPA, 

forthcoming). 

• DSMRT Data: The number of DSMRT samples per system was estimated by 

taking the average number of treatment plants per system from the 2006 CWSS. 

As a conservative measure, the average number of CWS treatment plants were 

also used to represent the number of NTNCWS treatment plants (i.e., it is likely 

that NTNCWSs have fewer treatment plants than CWSs, and thus lower actual 

costs for DSMRT sampling than estimated).

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

Assessment Monitoring will be conducted from January 2013 through December 2015 by 

800 systems serving 10,000 or fewer people, and all systems serving 10,001 and over. PreScreen Testing will be conducted from January 2013 through December 2015 by 800 systems 

serving 1,000 or fewer people. It is assumed for this cost estimation that one-third of systems 

will conduct Assessment Monitoring and Pre-Screen Testing each monitoring year. The UCMR 

program will affect approximately 5,791 systems, two-thirds of which will conduct monitoring 

during the ICR years of 2012-2014. One-third of systems will conduct monitoring in JanuaryDecember of 2015. Exhibit 8 below presents the estimated numbers of regulated systems to 

participate. Exhibit 9 presents the time line in which the system monitoring activities will take 

place.
Draft ICR for UCMR 3 Proposed Rule September 2010

35

Exhibit 8: Systems to Participate in UCMR 3 Monitoring 

System Size

Assessment Monitoring for

28 List 1 Chemicals

Pre-Screen Testing 

for 2 List 3 

Microbials1

TOTAL2

National Sample

Small Systems

25 – 10,000 800 randomly selected systems

800 selected 

undisinfected ground 

water wells at PWSs

serving 1,000 or 

fewer

~1,600

Large Systems

10,001 and over All (~4,191) 0 ~4,191

TOTAL ~4,991 800 ~5,791

1

Sampling for List 3 contaminants to be conducted at 800 undisinfected wells at systems serving 1,000 or fewer 

customers.

2 Total for small systems is additive because these systems would only be selected for one component of UCMR 3 

sampling.

Exhibit 9: UCMR 3 Sampling Activity Time Line for Cost and Burden Estimations

UCMR 3 – 2012 - 2016

2012 2013 2014

2015 2016

Designated ICR Years

No UCMR 

Monitoring 

Activity

Assessment Monitoring1

No UCMR 

Monitoring 

Activity

~ 1/3 of 

systems 

sample

~ 1/3 of 

systems 

sample

~ 1/3 of 

systems 

sample

Pre-Screen Testing

~ 1/3 of 

systems 

sample

~ 1/3 of 

systems 

sample

~ 1/3 of 

systems 

sample

1 The following assumptions, based on the proposed UCMR 3, were used to estimate cost and burden: 

• All Assessment Monitoring and Pre-Screen Testing systems will conduct sampling evenly across January

2013-December 2015 (i.e., one-third in each of the 3 consecutive 12-month periods). 

• Systems will conduct monitoring during the ICR years of 2013-2014; however, the last group of systems to 

conduct Assessment Monitoring and Pre-Screen Testing will monitor in January-December of 2015. 
Draft ICR for UCMR 3 Proposed Rule September 2010

36

The water system labor burden consists of three primary activities: (1) reading the 

regulations or State guidance letter; (2) monitoring or monitoring assistance; and (3) reporting 

and record keeping. Hourly labor rates (including overhead) vary by system size and are taken 

from the 2006 CWSS. Estimated hourly rates range from $21 per hour for staff in water systems 

serving 500 or fewer people to $38 per hour for systems serving more than 100,000 people (see 

Exhibit 10 for details). 

Exhibit 10: Labor Rates Applied for Public Water Systems 

System Size Labor Rate1

500 and under $21.24

501 to 3,300 $22.34

3,301 to 10,000 $25.36

10,001 to 50,000 $30.90

50,001 to 100,000 $32.95

100,001 and over $38.30

1

PWS hourly labor rates (including overhead) are taken from the 2006 CWSS. All rates represent 

that for both ground water and surface water/GWUDI systems. Wage rates are converted to 2010

dollars using the Employment Cost Index for wages and salaries in trade, transport, and utilities 

for 2006, and in utilities for December 2009; accessed http://www.bls.gov on April 14, 2010.

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

For each required UCMR tier (Assessment Monitoring or Pre-Screen Testing), systems 

are assumed to read the regulations and/or a State-issued guidance letter during the year in which 

systems will monitor (2013-2015). Small systems can rely on the State and EPA for information 

pertaining to their requirements, rather than reading the regulation; and are expected to spend 1 

hour, on average, reading the letter or guidance. Systems serving more than 10,000 people are 

assumed to read both the regulation and information from the State, requiring on average 4 

hours. National costs are estimated by multiplying the average burden hours by the average 

system labor rate, times the number of systems affected. This reading burden is assumed for each 

UCMR component. All systems will only be selected for one component of UCMR. Thus, 

reading burden would be 1 hour for any one small system and 4 hours for large and very large 

systems.
Draft ICR for UCMR 3 Proposed Rule September 2010

37

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

For Assessment Monitoring, it is assumed that all participating systems will collect 

samples during January 2013 through December 2015, with approximately one-third of systems 

involved during each of the 3 consecutive 12-month periods. In addition, the last group of 

systems (or approximately one-third of systems) will monitor outside of the applicable ICR 

period of 2012-2014, and will conduct their monitoring January through December 2015. See 

Exhibit 9, above, for an illustration of the time line for system sampling activity. For both 

Assessment Monitoring and Pre-Screen Testing, EPA assumes that each system will incur an 

estimated burden of 0.5 hours per sampling point to collect chemical samples for analysis. This 

monitoring burden includes receipt of monitoring kit, reading laboratory instructions, and 

collection and shipping of samples. It is calculated by: (hour burden per sampling point) times 

(number of sampling points) times (number of systems) times (number of sample events per 

year). Many ground water systems may realize savings in their sampling burden as a result of the 

allowance for representative EPTDSs. Thus, sampling burden is calculated to account for the 

estimated reduction in entry points where these systems will sample (as described below in 

section 6(a)(ii), Part A of this ICR document).

6(a)(i)(c) Reporting and Record Keeping 

Under UCMR 3, regulated systems are required to report specific information prior to 

monitoring, and with their monitoring results. 

• Reporting Prior to Monitoring

Small systems: EPA assumes that small systems will only need to send and 

confirm contact information prior to monitoring. These systems are allotted a onetime reporting burden of 2 hours.

Large surface water (and GWUDI) systems: EPA assumes that large surface 

water/GWUDI systems will be sending contact and sampling point information, 

and are allotted a one-time reporting burden of 6 hours.

Large ground water systems: EPA assumes that large ground water systems will 

be sending contact and sampling point information, which will require a one-time 

burden of 6 hours. An additional 8 hours are allotted to some ground water 

systems to account for compilation and submission of representative EPTDS 

proposal. Since it is unlikely that all systems will submit these proposals, EPA 

conservatively assumes that half of ground water systems serving 10,001 to 

100,000 people would compile and submit this proposal; and assumes that all 

ground water systems serving more than 100,000 people would do so. 
Draft ICR for UCMR 3 Proposed Rule September 2010

38

• Reporting with Monitoring Results

Small systems: Small systems can choose whether to review their UCMR 

monitoring results. Because EPA is paying for and coordinating laboratory 

analyses, small systems are not required to review and approve their analytical 

results. Some systems may choose not to review at all, while others may review in 

detail. However, as a conservative assumption, small systems are each allotted 0.5 

hours per sampling period for data review.

Large systems: Large systems must review, approve, and submit the data to the 

State and EPA via the EPA electronic reporting system. These systems are 

allotted 2 hours per sampling period for this activity. 

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

Systems are required to notify their users of the detection of any unregulated chemicals. 

Specifically, UCMR monitoring results will be reported by CWSs through the CCRs (63 FR 

44512 (August 19, 1998)). CWSs, NTNCWSs, and TNCWSs must report any failure to monitor 

for unregulated contaminants required through UCMR under the Public Notification Rule (64 FR 

25964 (May 13, 1999)). Therefore, no additional public notification burden is assumed under 

UCMR.

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

Under UCMR, small systems will only incur labor costs. By design of the rule, EPA 

assumes all laboratory and shipping costs for systems in the national representative sample of 

small systems. Thus, the laboratory fee and shipping cost estimates described here are the basis 

for EPA and large system non-labor costs.

The most significant cost associated with the implementation of UCMR is the cost of 

laboratory services for contaminant analysis. Estimates of laboratory analytical costs associated 

with the analysis of each sample are presented below. These methods will not coincide with 

other compliance monitoring. EPA estimates of laboratory fees are based on consultations with 

national drinking water laboratories and costs of analytical methods similar to those that will be 

used for UCMR 3. For systems serving 10,000 or fewer people, EPA will pay for the costs for 

shipping and laboratory analysis. 
Draft ICR for UCMR 3 Proposed Rule September 2010

39

Assessment Monitoring (List 1):

GC/MS (for 1 contaminant) .................................................................................................................$161.67

GC/MS (for 9 contaminants) ...............................................................................................................$171.67

Chlorate (for 1 contaminant)..................................................................................................................$33.33

LC/MS/MS (for 7 hormones)...............................................................................................................$491.67

ICP/MS (for 4 metals)............................................................................................................................$69.33

ICP/MS (for 6 PFCs) ...........................................................................................................................$391.67

TOTAL .............................................................................................................................................$1,319.33

Pre-Screen Testing (List 3):

EPA Methods (for 2 viruses, and indicators) .........................................................................................$1,650

TOTAL ..................................................................................................................................................$1,650

UCMR 3 specifies that all samples be collected at EPTDSs. Some large systems that use 

ground water sources and have multiple EPTDSs may be able to realize significant savings by 

sampling representative entry point(s) rather than at each EPTDS. Systems can do this if: they 

meet certain system configuration criteria; submit a proposal regarding representative entry 

points; and receive approval from EPA or the State. Labor related to submission and 

coordination of these proposals is discussed above in section 6(a)(i)(c), Part A of this ICR 

document. To account for the savings on laboratory fees that will be realized by large ground 

water systems, EPA assumed that approximately 75 percent of the current EPTDSs will be 

sampled at systems serving 10,001 to 100,000 people, and at ground water systems that serve 

more than 100,000 people 50 percent of EPTDSs will be sampled. 

In addition to EPTDS samples, systems that are required to conduct Assessment 

Monitoring are also required to collect samples for four metals and chlorate at the DSMRT. If 

systems do not disinfect their water and have not determined a DSMRT for compliance with the 

Disinfection By-Products Rule, samples must be collected from a location that best represents

maximum residence time in the distribution system. EPA assumed that systems have one 

DSMRT per treatment plant. The number of treatment plants was multiplied by the number of 

sampling events and includes 10 percent QA samples for the small systems. 

Shipping fees were calculated per required sample. It is assumed that, for each sampling 

point, a package of empty sample bottles is shipped via ground transportation to the system; 

estimated at $17 per package. Following sample collection, the system sends the package with 

full bottles via overnight air back to the laboratory. To estimate the cost of this overnight 

shipment, EPA applied the approximate cost of shipping a 25 pound package across an average 

number of shipping zones at $80. Thus, shipping cost for a large PWS is estimated at $97 per 

sample (again, small system laboratory and shipping costs are paid for by EPA). Shipping costs 

were estimated based on pricing information posted on: http://www.fedex.com/ and 

http://www.ups.com/; accessed May 2010. 
Draft ICR for UCMR 3 Proposed Rule September 2010

40

Total laboratory and shipping fees were estimated per required sampling location 

(accounting for both the representative EPTDS allowance, and the additional DSMRT samples, 

as described above), per sampling event, as follows: (number of systems) times (number of 

periods per year) times (number of sampling points per system) times (method and shipping 

costs). 

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

Exhibit 11a displays a summary of labor and non-labor costs, by year, for the three-year 

ICR period. As previously discussed, the UCMR 3 cycle is 2012-2016, and the ICR period of 

2012-2014 coincides with the first three years of program implementation. One year of 

monitoring, January through December 2015 is outside of the ICR period. Analogous 

information presenting estimated costs over the five-year UCMR 3 implementation period is 

provided in Exhibit B-1a, in Appendix B. Small systems incur labor costs only. Large systems 

will incur both labor and non-labor costs, as they are responsible for analytical costs.

The nationwide cost to systems for implementing the total UCMR program over the 

three-year ICR period of 2012-2014 is estimated to be $36.1 million. Large and very large 

systems are expected to incur about 99 percent of the total system cost, $36.0 million. Annual 

cost per small system for UCMR implementation over the three-year ICR period is estimated to 

be $34 per system, all attributed to labor. Annual cost per large system is estimated to be $170

for labor plus $2,381 for analytical (non-labor) costs; with very large systems costs of $295 for 

labor plus $5,460 for analytical (non-labor) costs. Exhibits 8 and 9 illustrate numbers of systems 

participating and timing of monitoring. Per system labor burdens and costs for the UCMR 

program are presented in Exhibit 11b. In addition, this exhibit presents a summary of burden and 

cost per response. Analogous information for the five-year implementation period is provided in 

Exhibit B-1b, in Appendix B. ―Response‖ is defined as each required reporting event for a 

system. All labor and non-labor costs associated with a reporting event (reading the regulations, 

monitoring, and reporting) are included in the per response cost estimate.
Draft ICR for UCMR 3 Proposed Rule September 2010

41

Exhibit 11a: Yearly Cost to Systems, by System Size and by Type of Cost (2012-2014)

(corresponds to Exhibit B-1a)

Cost Description 2012 2013 2014 Total

SMALL SYSTEMS (standard sample serving 10,000 or fewer people)

Labor Costs

Reading and Initial 

Reporting $0 $36,338 $36,338 $72,676

Monitoring $0 $31,773 $31,773 $63,546

Reporting of Results $0 $13,596 $13,596 $27,191

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

$0 $0 $0 $0

Subtotal – Small Systems $0 $81,707 $81,707 $163,413

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

Labor Costs

Reading and Initial 

Reporting $0 $454,279 $454,279 $908,558

Monitoring $0 $258,264 $258,264 $516,528

Reporting of Results $0 $253,244 $253,244 $506,487

Non-Labor Costs (Laboratory Analysis and Shipping)

$0 $13,504,932 $13,504,932 $27,009,864

Subtotal – Large Systems $0 $14,470,719 $14,470,719 $28,941,437

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

Labor Costs

Reading and Initial 

Reporting $0 $59,085 $59,085 $118,169

Monitoring $0 $83,637 $83,637 $167,273

Reporting of Results $0 $38,505 $38,505 $77,009

Non-Labor Costs (Laboratory Analysis and Shipping)

$0 $3,537,633 $3,537,633 6,715,266

Subtotal – Very Large 

Systems $0 $3,538,859 $3,538,859 $7,077,718

ALL SYSTEMS

Total Labor for All 

Systems $0 $1,228,719 $1,228,719 $2,457,439

Total Non-Labor for All 

Systems $0 $16,862,565 $16,862,565 $33,725,130

Total Labor and NonLabor for All Systems $0 $18,091,284 $18,091,284 $36,182,568
Draft ICR for UCMR 3 Proposed Rule September 2010

42

Exhibit 11b: Per System (Respondent) and Per Response UCMR Costs (2012-2014) 

(corresponds with Exhibit B-1b)

Burden / Cost

Total over 2012-2014 Annual Average over 2012-2014

Small Systems Large Systems

Very Large 

Systems Small Systems Large Systems

Very Large 

Systems

PER RESPONDENT:

Labor Cost $102 $511 $884 $34 $170 $295

Non-Labor Cost $0 $7,144 $16,379 $0 $2,381 $5,460

Burden (labor hours) 4.4 16.4 23.1 1.5 5.5 7.7

PER RESPONSE:

Number Responses per 

Respondent 1.5 2.7 3.7 0.5 0.9 1.2

Labor Cost per 

Response $69 $190 $240 $23 $63 $80

Non-Labor Cost per 

Response $0 $2,663 $4,453 $0 $888 $1,484

Burden (labor hours) 

per Response 3.0 6.1 6.3 1.0 2.0 2.1

6(b) Estimating the Burden and Cost to States 

Since UCMR is a direct implementation rule, individual State costs will largely depend 

on specifications in their PA. EPA assumed that States will incur only labor costs, because no 

capital investments are expected for this third cycle of the program. Because States will be 

involved in a variety of UCMR implementation and oversight activities but have few defined 

responses, burden estimates are based on yearly activities. Thus, for ―per response‖ estimates, 

States are assumed to have an average of 1.0 response per year.

EPA used the ―2001 ASDWA Drinking Water Program Resource Needs Self 

Assessment‖ to estimate State burden and cost for the implementation and oversight of UCMR 3. 

This assessment tool (or model) was developed by ASDWA to assist States in estimating the 

resources needed to implement their Statewide drinking water programs (in both full-time 

equivalent staff (FTEs) and dollars). In 2000, the United States General Accounting Office had 

used a previous version of this model to estimate nationwide drinking water program needs for 

Congress. The tool was later updated and improved based on comments from 27 States. To make 

the model easier to use, ASDWA established suggested salary and benefit ranges (i.e., default 

values), resource needs for the various NPDWRs, and other key variables. 
Draft ICR for UCMR 3 Proposed Rule September 2010

43

EPA used the defaults values (or average values within a default range) that were 

provided in the model to estimate the national burden and cost for State UCMR 3 activities. 

Defaults included: 

one FTE is equivalent to 1,800 hours per year; overhead and holidays, sick leave, etc. are 

accounted for in default loading of base salaries;

professional and support staff salaries vary for different sized States (very small, small, 

medium, large, very large); and

suggested ranges of FTEs for the implementation of the Phase II/V, Arsenic, and UCMR 

programs (i.e., the relevant subsection of the model).

Understandably, the model had bundled the State resource needs for Phase II/V, Arsenic, 

and UCMR, because of the inherent overlap and similarities in the programs. However, because 

these programs were bundled, EPA needed to ―extract‖ the UCMR costs from the aggregated 

costs. Based on best professional estimates and consultations with staff from three State drinking 

water programs (California, Connecticut, and Nebraska) regarding the relative magnitude of the 

UCMR program, EPA assumed that: 

during the first and last year of the five-year UCMR cycle (2012 and 2016), when there 

are no monitoring activities, UCMR represents 1 percent of the bundled program 

resource needs (although the costs for 2016 are not relevant to the current ICR 

estimations for 2012-2014);

during the three years (2013-2015) when Assessment Monitoring and Pre-Screen Testing 

are being conducted, UCMR represents three percent of the bundled program resource 

needs (although the costs for 2015 are not relevant to the current ICR estimations for 

2012-2014).

EPA ran the model for each of the State size categories that were based on the number of 

systems for which States have drinking water program oversight responsibilities. To estimate 

nationwide costs, the size-specific ―per State‖ estimates that are generated by the model were 

then multiplied by the number of States in each size category, as shown in Exhibit 12. 

EPA further refined the model estimates by taking the level of State participation under 

UCMR 2 into consideration. EPA reviewed key areas of State participation under UCMR 2, 

including: review and revision to the State Monitoring Plans; assisting EPA with updates to 

information for large systems; two separate sets of system notifications; and compliance 

assistance. Based on levels of involvement in each of these UCMR activities, States typically 

participated in between 50 and 100 percent of their optional UCMR activities. However, some 

States chose not to participate at all. Burden estimates generated from the resource model were 
Draft ICR for UCMR 3 Proposed Rule September 2010

44

multiplied by this ―percent participation in UCMR 2‖ to approximate State costs at expected 

participation levels under UCMR 3. 

Exhibit 12: Number of States in Each Size Category (State 

Resource Model Assumptions) 

Size Category Number of States

Very Small 10

Small 11

Medium 23

Large 10

Very Large 2

Total 56

EPA estimates that the average annual burden over the 3 ICR years (2012-2014) for 56 

States to implement UCMR will be 13,069 hours (or 233 hours per State per year), with an 

average annual cost (labor only) of $783,534 (or $13,992 per State per year). See Exhibits 13a 

and 13b for a summary of estimated State burdens and costs (analogous five-year information for 

2012-2016 provided in Exhibits B-2a and B-2b, in Appendix B).

Exhibit 13a: Yearly Cost and Burden to States for Implementation of UCMR 3 (2012-

2014)

1

(corresponds with Exhibit B-2a)

Cost/Burden 2012 2013 2014 Total Annual 

Average

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

$331,538 $994,614 $1,024,452 $2,350,603 $783,534

Labor burden for all States for UCMR implementation and oversight (number of hours)

13,342 13,625 12,238 39,205 13,068

1 All costs are attributed to labor and are estimated over the period 2012-2014. 

Exhibit 13b: Per State (Respondent) and Per Response UCMR 3 Costs (2012-2014) 

(corresponds with Exhibit B-2b)

Burden / Cost Total over 2012-2014

Annual Average 

over 2012-2014

PER RESPONDENT:

Labor Cost $41,976 $13,992

Non-Labor Cost $0 $0

Burden (labor hours) 700.2 233.4
Draft ICR for UCMR 3 Proposed Rule September 2010

45

Exhibit 13b: Per State (Respondent) and Per Response UCMR 3 Costs (2012-2014) 

(corresponds with Exhibit B-2b)

Burden / Cost Total over 2012-2014

Annual Average 

over 2012-2014

PER RESPONSE:

Number Responses per Respondent13.0 1.0

Labor Cost per Response $13,992 $4,664

Non-Labor Cost per Response $0 $0

Burden (labor hours) per Response 184 61.3

1

States are assumed to have 1 response per year, since there are no specific cyclical State reporting requirements under the 

UCMR program. 

6(c) Estimating Agency Burden and Cost 

EPA will incur UCMR-related burden and costs related to UCMR implementation 

activities, including: regulatory support activities; national and regional oversight and data 

analysis; and the small system testing program. These activities are described in detail in section 

5(a), Part A of this ICR document. Labor and contractual costs are estimated using the federal 

government general schedule (GS) pay scale; assuming a labor level of GS 13, step 5, and taken 

from the Maryland/District of Columbia rate schedule during the first quarter of 2010 (see the 

U.S. Office of Personnel Management website: www.opm.gov). With these assumptions, labor 

and contractor rates were based on a 2,080 hour work year, with a $81,723 annual salary plus 60 

percent overhead, or $62.86 per hour. Additional cost assumptions are described below in

sections 6(c)(i)-(iii), Part A of this ICR document. Cost and burden estimates are presented in 

Exhibits 14a and 14b, respectively. 

6(c)(i) Regulatory Support Activities 

Regulatory support activities include the labor and non-labor costs for laboratory 

approval process and QA/QC activities; and general technical support and guidance documents. 

Cost and burden assumptions for these activities are as follows: 

Laboratory Approvals and QA/QC Activities: EPA anticipates incurring various labor or 

contractor costs related to the laboratory PT/approvals; laboratory QA/QC; and provision 

of analytical standards, as follows: 

• Laboratory approval (PT program) is estimated to cost EPA $231,855 prior to the 

beginning of monitoring, in 2012. Cost estimates from best professional judgment are 

based on costs realized by the Agency for prior similar activities for UCMR 2. A three 

percent inflation rate was added to the costs of UCMR 2 to estimate the costs for 

UCMR 3. 
Draft ICR for UCMR 3 Proposed Rule September 2010

46

• QC Audits of contract laboratories to occur throughout active UCMR monitoring. Labor 

(hours) for each trip includes: a 3-day site inspection (for 2 individuals); 1 full-day travel 

for 2 individuals (assume 2 half days); and 3 days of report writing (for 1 individual), 

which includes review and response to laboratory comments. Travel costs for 2 

individuals include: $500 round trip flight, 3 nights hotel stay, 2 full day food per diem, 

and 2 days at the proportional meals rate from the 2010 Federal rate for the Continental 

U.S. (from the U.S. Government Services Administration website: 

http://www.gsa.gov/Portal/gsa/ep/home.do?tabId=0). Also included is $150 for rental of 

one car for both travelers. It is estimated that these QC audits will take place 4 times each 

year, at an estimated $8,699.68 per trip.

• Analytical standards provision and coordination is estimated to cost EPA $600,713 total 

for three ICR years (or $200,238 per ICR year). Cost estimates from best professional 

judgment are based on costs realized by the Agency for prior similar activities, and 

inflated by three percent each year. 

Technical Support/Guidance Document Development: These activities are estimated to 

cost EPA $175,630 total over the ICR period including: costs for developing and 

distributing guidance for laboratories that will participate in UCMR 3 testing; health 

effects fact sheets; and other pertinent guidance related to UCMR 3 implementation. 

These activities are expected to take place in 2012 and 2013. Cost estimates from best 

professional judgment are based on costs realized by the Agency for prior similar 

activities. For UCMR 3, a three percent inflation rate was added to the costs of UCMR 2. 

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

EPA activities will include data analysis, management oversight, and support at both the 

regional and national level for assistance to States with UCMR implementation. During the core 

period of UCMR 3 activity, EPA estimates that it will dedicate 5.5 FTEs each year to program 

oversight and data analysis. These activities are estimated as labor cost and burden to the Agency 

(see the corresponding description of these activities in section 5(a)(ii), Part A of this ICR 

document). These activities are estimated to cost EPA $2.2 million in total over the three-year 

ICR period. 

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

EPA will provide logistical support for the small system testing program. This activity 

includes costs for contractual labor and sampling supplies, and is estimated at $400 per sampling 

event per sampling site, based on actual costs incurred during UCMR 1 for this same activity. 

These activities are estimated to cost EPA $2.2 million in total over the three ICR years.
Draft ICR for UCMR 3 Proposed Rule September 2010

47

The single largest cost to EPA for implementation of UCMR is for small system sample 

analyses. EPA will pay small system sample analyses and shipping for Assessment Monitoring 

and Pre-Screen Testing. EPA will also pay for quality control duplicates for 10 percent of all 

samples. 

EPA assumes that, for each sampling point, a package of empty sample bottles is shipped 

via ground transportation to the system; estimated at $17 per package. Following sample 

collection, the system sends the package with full bottles via overnight air back to the laboratory. 

To estimate the cost of this overnight shipment, EPA applied the approximate cost of shipping a 

25 pound package across an average number of shipping zones at $80. Thus, shipping cost for a 

large PWS is estimated at $97 per sample. Small system sampling includes the cost for one extra 

ground trip, for sending the empty bottles from the laboratory to the sampling coordinator, so 

that the sampling kit can be reused. Thus, shipping cost for a small PWS is estimated at $114 per 

sample.

These analytical and shipping fees are estimated to cost EPA $7.9 million in total over 

the three ICR years for Assessment Monitoring and Pre-Screen Testing. See section 6(a)(ii), Part 

A of this ICR document, for assumptions regarding applicable laboratory fees for individual 

methods. Total costs that EPA will incur for the small system testing program were calculated by 

multiplying the laboratory and shipping fees by: (number of systems) times (number of sampling 

periods per year (including an additional 10 percent QA samples)) times (number of sampling 

points per system). 

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

The EPA cost for the UCMR 3 program during the ICR period of 2012-2014 is estimated 

to be $11.2 million; (with annual average cost over the ICR period of $3.7 million). EPA costs 

for UCMR implementation are shown in Exhibit 14a; average annual labor and non-labor costs, 

as well as small system testing program costs are shown in Exhibit 14b. Appendix B, Exhibits B3a and B-3b provide analogous information over the five-year UCMR 3 implementation period. 
Draft ICR for UCMR 3 Proposed Rule September 2010

48

Exhibit 14a: Yearly Cost to EPA for UCMR Implementation, by Type of Cost (2012-2014) 

1

(corresponds with Exhibit B-3a)

Cost Description 2012 2013 2014 Total Annual Average

Regulatory Support Activities: laboratory proficiency testing; QC audits; analytical standards provision; and 

technical support, guidance document development

Lab PT $231,855 $0 $0 $231,855 $77,285

QC Audits $17,399 $34,799 $34,799 $86,997 $28,999

Analytical Standards $115,927 $238,811 $245,975 $600,713 $200,238

Technical Support $115,927 $59,703 $0 $175,630 $58,543

Subtotal –

Regulatory Support $481,108 $333,313 $280,774 $1,095,195 $365,065

National and Regional Oversight and Data Analysis: UCMR management oversight; review and evaluation of 

data from Assessment Monitoring

$442,499 $884,998 $884,998 $2,212,496 $737,499

Small System Testing: implementation coordination; and analytical and shipping costs for small system testing for 

both Assessment Monitoring and Screening Surveys

Implementation 

Coordination $0 $1,081,021 $1,081,021 $2,162,043 $720,681

Fees for Analysis and 

shipping – standard 

sample $0 $2,862,805 $2,862,805 $5,725,610 $1,908,538

Subtotal –

Small System Testing $0 $3,943,827 $3,943,827 $7,887,653 $2,629,218

TOTAL $923,607 $5,162,138 $5,109,599 $11,195,344 $3,731,781

1 Agency costs are estimated over the period 2012-2014.

Exhibit 14b: Summary of EPA Burdens and Costs for UCMR Implementation (2012-

2014) (corresponds with Exhibit B-3b)

Burden / Cost

Annual Average Cost over Three-year 

ICR Period of 2012-2014

Labor Cost $737,499

Non-Labor Cost $2,994,283

Total Cost to EPA for UCMR Implementation $3,731,781

Burden (labor hours) 9,533
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49

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

For the UCMR 3 cycle of 2012-2015, the universe of respondents includes 5,791 PWS 

respondents comprised of CWSs, NTNCWSs, and TNCWSs (which do not sell all of their water 

to other water systems) as well as 56 State respondents. Assessment Monitoring will be 

conducted by 800 systems serving 10,000 or fewer people, plus all 4,191 systems that serve more 

than 10,000 people. Pre-Screen Testing monitoring will be conducted by 800 undisinfected 

ground water wells from systems serving 1,000 or fewer customers. As described previously, 

PWS sampling is conducted four times during the monitoring year for surface water/GWUDI 

sampling locations, and twice for ground water sampling locations (i.e., frequency of response 

depends on water source) for Assessment Monitoring. Systems conducing Pre-Screen Testing 

will monitor twice during the 2013-2015 monitoring period. States will be involved in a variety 

of UCMR implementation and oversight activities, but have few defined responses; thus, States 

are assumed to have an average of 1.0 response per year. 

Exhibit 15 summarizes national hours and costs for UCMR 3 during the ICR period of 

2012-2014. Analogous information for the entire five-year UCMR 3 cycle of 2012-2016 is 

presented in Exhibit B-4 in Appendix B. The total labor and non-labor costs are presented for 

each category of respondent. The total labor burden to the sample of small systems is 7,091

hours, with a cost of $163,413 (small systems only incur labor costs, EPA pays for all laboratory 

fees and shipping costs). The total labor burden to large systems is 61,852 hours, with a labor 

cost of $1.9 million, and non-labor costs for analysis and shipping of $27.0 million. Very large 

systems are estimated to have a total labor burden for the ICR period of 9,463 hours, with a labor 

and non-labor costs of $0.4 million and $6.7 million, respectively. The total burden to States 

over the three-year ICR period is 39,205 hours, with a labor cost of $2.4 million. EPA anticipates 

that States will not incur any significant non-labor costs. The EPA total burden over the same 

time frame is 28,600 hours, with labor costs of $2.2 million, and non-labor costs of $9.0 million. 

Exhibit 15: UCMR 3 National Cost Summary for the ICR period (2012-2014)

(corresponds with Exhibit B-4)

Type of Cost 2012 2013 2014 TOTAL

Small Systems 

Labor Cost $0 $81,707 $81,707 $163,413

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

Total Small System Cost $0 $81,707 $81,707 $163,413

Large Systems

Labor Cost $0 $965,787 $965,787 $1,931,574

Non-Labor Cost $0 $13,504,932 $13,504,932 $27,009,864
Draft ICR for UCMR 3 Proposed Rule September 2010

50

Exhibit 15: UCMR 3 National Cost Summary for the ICR period (2012-2014)

(corresponds with Exhibit B-4)

Type of Cost 2012 2013 2014 TOTAL

Total Large System Cost $0 $14,470,719 $14,470,719 $28,941,437

Very Large Systems

Labor Cost $0 $181,226 $181,226 $362,452

Non-Labor Cost $0 $3,357,633 $3,357,633 $6,715,266

Total Very Large 

System Cost 0 $3,538,849 $3,538,849 $7,077,718

States

Labor Cost $331,538 $994,614 $1,024,452 $2,350,603

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

Total State Cost $331,538 $994,614 $1,024,452 $2,350,603

EPA

Labor Cost $442,499 $884,998 $884,998 $2,212,496

Non-Labor Cost $481,108 $4,277,139 $4,224,600 $8,982,848

Total EPA Cost $923,607 $5,162,138 $5,109,599 $11,195,344

National Total

Total with EPA $1,255,145 $24,248,035 $24,225,335 $49,728,516

Total without EPA $331,538 $19,085,898 $19,115,736 $38,533,172

Total Burden (hours) for All Responses

Small Systems 0 3,545 3,545 7,091

Large Systems 0 30,926 30,926 61,852

Very Large Systems 0 4,732 4,732 9,463

States 13,342 13,625 12,238 39,205

EPA 5,720 11,440 11,440 28,600

Total with EPA 19,062 64,268 62,881 146,211

Total without EPA 13,342 52,828 51,441 117,611

1 Although EPA is not considered a respondent to the UCMR regulations, Agency burdens are shown here to 

illustrate the national costs of the program. National totals are shown with and without the Agency costs.
Draft ICR for UCMR 3 Proposed Rule September 2010

51

6(e) Reasons for Change in Burden 

This ICR builds upon the ICR developed for UCMR 2, entitled: Information Collection 

Request for UCMR 2, ICR Number 2192.03, OMB Control No. 2040-0270. After the UCMR 1 

program was established in 1999, subsequent UCMR cost and burden estimates were 

incorporated into the larger Chem/Rads ICR. However, the UCMR 2 ICR, and subsequent 

UCMR ICRs will be developed and tracked separately from the Chem/Rads ICR, because the 

Chem/Rads ICR is a ―renewal‖ ICR, whereas the UCMR program is, per SDWA, a program that 

must change every five years.

The reasons that respondents to UCMR 3 will incur a different burden than those 

responding to UCMR 2 include: 

UCMR 3 establishes a new list of 30 priority contaminants, including 28 chemicals using 

six EPA-developed analytical methods, and four equivalent consensus organizationdeveloped methods, and two viruses using one analytical method. The cost for sample 

analysis is different than for UCMR 2. EPA plans to have laboratories under EPA 

contract to conduct sample analysis for the two viruses using one analytical method (see 

Exhibit 1 in section 4(b)(i), Part A of this ICR document). 

UCMR 3 does not exclude systems that purchase all of their water from monitoring. 

Because of this change, more large and very large systems are expected to monitor for 

UCMR 3 than for UCMR 2 (see Exhibit 8 in section 6(a)(i), Part A of this ICR 

document).

Samples for the four metals and chlorate (under Assessment Monitoring) for all systems 

will be collected at the DSMRT in addition to the required EPTDS locations (see 

explanation in section 4(b)(ii), Part A of this ICR document).

UCMR 3 includes monitoring for Pre-Screen Testing instead of a Screening Survey (see 

section 1(b) for a description of Pre-Screen Testing). 

TNCWSs are no longer excluded from UCMR monitoring, and may be selected to 

conduct Pre-Screen Testing (see section 1(b) for a description of Pre-Screen Testing).

6(f) Burden Statement 

Small systems (those serving 10,000 or fewer) that are selected for UCMR 3 monitoring 

will sample an average of 1.5 times per system (i.e., number of responses per system) across the 

three-year ICR period of 2012-2014. The average burden per response for small systems is 

estimated to be 3.0 hours. Large systems (those serving 10,001 to 100,000) and very large 
Draft ICR for UCMR 3 Proposed Rule September 2010

52

systems (those serving more than 100,000) will sample and report an average of 2.7 and 3.7

times per system, respectively, across the three-year ICR period of 2012-2014. The average 

burden per response for large and very large systems is estimated to be 6.1 and 6.3 hours, 

respectively. States are assumed to incur 3.0 responses over the three-year ICR period related to 

coordination with EPA and systems, with an average burden per response of 184 hours. In 

aggregate during the ICR period of 2012-2014, the average response (e.g., responses from 

systems and States) is associated with a burden of 8.3 hours, with a labor plus non-labor cost of 

$2,714 per response. 

The annual average per respondent burden hours and costs for the ICR period of 2012-

2014 are: small systems – 1.5 hour burden at $34 for labor; large systems – 5.5 hours at $170 for 

labor, and $2,381 for analytical costs; very large systems –7.7 hours at $295 for labor, and 

$5,460 for analytical costs; and States – 233 hours at $13,992 for labor. Annual average burden 

and cost per respondent (including systems and States) is estimated to be 6.7 hours, with a labor 

plus non-labor cost of $2,197 per respondent (note that small systems do not pay for testing 

costs, so they only incur labor costs). 

The Agency estimates the annual burden to EPA for proposed UCMR program activities 

during the ICR years of 2012-2014 to be 9,533 hours, at an annual labor cost of $0.7 million. 

EPA's annual non-labor costs are estimated to be $3.0 million. Non-labor costs are primarily 

attributed to the cost of sample testing for small systems (testing is 88 percent of non-labor

costs).

Exhibit 16 presents per respondent and per response burdens and costs over the UCMR 

ICR period of 2012-2014 (analogous information for the 2012-2016 UCMR 3 implementation 

period is provided in Exhibit B-5, Appendix B). This Exhibit also presents average annual 

burdens and costs.
Draft ICR for UCMR 3 Proposed Rule September 2010

53

Exhibit 16: UCMR 3 Per Respondent Burden and Cost Summary for the ICR Period 

(2012-2014) (corresponds with Exhibit B-5)

Burden (hours)/

Cost (dollars)

Small 

Systems

Large 

Systems

Very Large 

Systems States EPA

National 

Average 

with EPA1

National 

Average 

without 

EPA

Three-Year Total per Respondent

Total # of 

Responses Per 

Respondent 1.5 2.7 3.7 3.0 n/a n/a 2.4

Labor Cost Per 

Respondent $102 $511 $884 $41,975 $2,212,496 $1,201 $822

Non-Labor Cost 

Per Respondent $0 $7,144 $16,379 $0 $8,982,848 $7,303 $5,768

Total Cost 

(Labor plus 

Non-Labor) $102 $7,654 $17,263 $41,975 $11,195,344 $8,504 $6,590

Total Cost Per 

Response $69 $2,853 $4,693 $13,992 n/a n/a $2,714

Total Burden Per 

Respondent 4.4 16.4 23.1 700.1 28,599 25.0 20.1

Total Burden Per 

Response 3.0 6.1 6.3 184.0 n/a n/a 8.3

Average Annual per Respondent

Ave. # of 

Responses Per 

Respondent 0.5 0.9 1.2 1.0 n/a n/a 0.8

Labor Cost Per 

Respondent $34 $170 $295 $13,992 $737,499 $400 $274

Non-Labor Cost 

Per Respondent $0 $2,381 $5,460 $0 $2,994,283 $2,434 $1,923

Ave. Cost (Labor 

plus Non-Labor) $34 $2,551 $5,754 $13,992 $3,731,781 $2,835 $2,197

Ave. Cost Per 

Response $23 $951 $1,564 $4,664 n/a n/a $905

Ave. Burden Per 

Respondent 1.5 5.5 7.7 233.4 9,533 8.3 6.7

Ave. Burden Per 

Response 1.0 2.0 2.1 61.3 n/a n/a 2.8

1 National average burdens and costs differ greatly between the State respondents and the various system respondents. This 

should be taken into consideration when looking at the national average with or without EPA.
Draft ICR for UCMR 3 Proposed Rule September 2010

54

Burden means the total time, effort, or financial resources expended by persons to 

generate, maintain, retain, or disclose or provide information to or for a Federal agency. This 

includes: the time needed to review instructions; develop, acquire, install, and utilize technology 

and systems for the purposes of collecting, validating, and verifying information, processing and 

maintaining information, and disclosing and providing information; adjust the existing ways to 

comply with any previously applicable instructions and requirements; train personnel to be able 

to respond to a collection of information; search data sources; complete and review the collection 

of information; and transmit or otherwise disclose the information. An agency may not conduct 

or sponsor, and a person is not required to respond to, a collection of information unless it 

displays a currently valid OMB control number. The OMB control numbers for EPA's 

regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID No. OW-2009-0009, which is available for public viewing at the Water Docket in the 

EPA Docket Center (EPA/DC), EPA West, Room B102, 1301 Constitution Ave., NW, 

Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 

p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading 

Room is (202) 566-1744, and the telephone number for the Water Docket is (202) 566-2426. All 

documents in the docket are also listed in the www.regulations.gov index. Although listed in the 

index, some information is not publicly available, e.g., CBI or other information whose 

disclosure is restricted by statute. Certain other material, such as copyrighted material, will be 

publicly available only in hard copy.
Draft ICR for UCMR 3 Proposed Rule September 2010

55

— PART B OF THE SUPPORTING STATEMENT —

1 SURVEY OBJECTIVES, KEY VARIABLES, AND OTHER 

PRELIMINARIES

1(a) Survey Objectives 

The primary objective of the statistical methods applied in this information collection is 

for EPA to identify and select a sample of PWSs that is representative of PWSs nationwide. The 

selected sample of PWSs will conduct monitoring of contaminants identified by the UCMR 

program. The representativeness of this sample of systems is critical to the UCMR program 

because the drinking water contaminant occurrence data collected by the PWSs will be used to: 

estimate national occurrence and exposure, establish a baseline for health effects and economic 

analyses, and provide information for regulatory determinations.

1(b) Key Variables 

Key variables associated with selecting a nationally representative sample of PWSs 

include: system size, source water type, and geographical location.

1(c) Statistical Approach 

Section 1445(a)(2) of SDWA (as amended in 1996) requires that the UCMR program 

include only a representative sample of systems serving 10,000 or fewer people. In addition to 

satisfying statutory requirements, selection of a sample of systems for participation in UCMR 

allows for significant national costs savings, as compared to monitoring by all PWSs. To 

estimate national occurrence and exposure, the primary UCMR program objective, the 

representative sample of PWSs must allow EPA to collect high quality data about contaminant 

occurrence. 

1(d) Feasibility 

EPA anticipates that the survey (the statistical sample) objectives are achievable given 

the existing time and resource constraints. 

• High PWS response/participation rates (>95%) during UCMR 1 and 2 have given EPA 

confidence that equivalent or better can be achieved during UCMR 3. 
Draft ICR for UCMR 3 Proposed Rule September 2010

56

• The statistical approach to this data collection requires only a fraction of small systems to 

conduct monitoring, resulting in much smaller cost and burden at the national level than 

would be incurred if all systems monitored. Small systems that are selected for UCMR 3

monitoring will incur only a few hours of labor burden. EPA will pay for all laboratory 

fees and shipping costs related to small system testing. 

• The survey results will be completed in time to inform the corresponding cycle of CCL 

regulatory determinations. 

2 SURVEY DESIGN

2(a) Target Population and Coverage 

PWSs are the target population for UCMR monitoring. PWSs that sell all of their water to 

other system(s) are not subject to UCMR 3. All other PWSs that serve more than 10,000 people 

will be subject to the Assessment Monitoring component of UCMR 3 monitoring. Eligible small 

PWSs (serving 10,000 or fewer people) will only be required to conduct UCMR 3 monitoring if 

they are part of the statistical selection for Assessment Monitoring, or if they have been selected 

to monitor for Pre-Screen Testing, as described below. Small PWSs will only be selected to 

monitor for either Assessment Monitoring or Pre-Screen Testing, not both.

2(b) Sample Design 

2(b)(i) Sampling Frame 

EPA will develop the sample frame for the statistical selection of UCMR systems, 

including the system PWSID, name, source water category, and population-served data for each 

UCMR-eligible PWS. Initial data will be pulled from EPA's Safe Drinking Water Information 

System (SDWIS/FED) inventory database, and will be adjusted to account for known anomalies 

in population and inventory reporting (for example, how wholesalers report their population 

data). 

2(b)(ii) Sample Size 

UCMR 3 monitoring will include: Assessment Monitoring conducted by all PWSs 

serving more than 10,000 people (―large‖ PWSs), and 800 representative PWSs serving 10,000 
Draft ICR for UCMR 3 Proposed Rule September 2010

57

or fewer people (―small‖ PWSs); and Pre-Screen Testing conducted by 800 undisinfected ground 

water wells from systems serving 1,000 or fewer people. 

2(b)(iii) Stratification Variables 

In developing the representative sample, EPA consider factors such as population served, 

water source, and geographic location. The sample PWSs will be stratified by population served 

(system size), allocating samples proportionately to each State by system size, and then by water 

source type. (Other provisions, presented below, ensure broad geographic coverage.)

2(b)(iv) Sampling Method 

To satisfy the specifications of SDWA section 1445(a)(2)(A), the representative sample 

of systems will account for different system sizes, sources of water supply, and geographic 

location (e.g., States). The sample will be stratified by water source type (i.e., ground or surface 

water) and by system size category (i.e., serves 25 to 500 people, 501 to 3,300 people, etc.). This 

stratification allows EPA to account for different exposure risks of contaminant occurrence that 

may be related to the vulnerability differences between surface and ground water sources and 

differing management and financial capacity that can vary across system sizes. 

With contaminant exposure assessment as a primary goal, systems will be selected in 

proportion to the population served, as was generally done under UCMR 1 and UCMR 2. This 

population-weighted allocation leads to statistically valid estimates of national exposure. To 

ensure the sample provides equity across States for involvement in the UCMR, EPA will include 

at least two systems from each State. This additional PWS selection requirement will provide 

allocation across all the States and territories to account for differences in spatial vulnerability 

and contaminant occurrence, and to ensure equity in participation. Small Tribal water systems 

across the EPA Regions are grouped into a single category (equivalent to a ―State‖) for the 

representative sample. 

2(b)(v) Multi-Stage Sampling 

Because PWS status often changes over time, EPA will also select ―alternate‖ systems 

that fit the size/source water strata of the originally selected system. Through an interactive 

review process with the States, systems that no longer meet eligibility criteria (for example, if 

they are in a different size category than when originally selected, have become inactive, or sell

all of their water) will be replaced by an alternate system that meets the stratification criteria.
Draft ICR for UCMR 3 Proposed Rule September 2010

58

2(c) Precision Requirements 

2(c)(i) Precision Targets 

The representative sample of PWSs must be selected so that the data collected yield 

accurate and precise estimates of national contaminant occurrence (the fraction of systems in 

which a contaminant occurs) and exposure (the fraction of people exposed to a contaminant). For 

estimates of exposure fractions, EPA will allow a margin of error of ± 1% with 99% confidence, 

when the estimated exposure fraction is 1%. That is, if the estimated exposure fraction is 1%, 

EPA will be able to state with 99% confidence that the true exposure fraction is between 0% and 

2%. Because there are uncertainties and sources of variation in this and other such sampling 

programs, statistical sampling theory used to derive levels of accuracy and precision may not 

account for all of these sources of variation. Hence, the high confidence level, low allowable 

error, and consequent large sample size should help ensure adequate data to meet the objectives 

of the UCMR program. 

2(c)(ii) Non-sampling error 

For those PWSs required to conduct UCMR monitoring, response is a requirement. As 

with any regulation, some non-compliance can be expected. However, high compliance levels 

(>95%) during UCMR 1 and 2 (attributable to extensive outreach and compliance assistance) 

give EPA confidence that the same or better can be achieved during UCMR 3. EPA plans to 

continue outreach and compliance assistance efforts, as needed.

2(d) Questionnaire Design 

No questionnaires will be used for the UCMR. Analytical results for contaminant 

occurrence will be electronically reported directly by the laboratories to EPA’s electronic 

reporting system.

3 PRETESTS AND PILOT TESTS

For UCMR 3, EPA will apply the same basic statistical methods that were used for the 

UCMR 1 and UCMR 2 national representative sample of small systems. Following sample 

adjustments made through communications with States, >99% of the final sample of small 

systems (and >95% of large systems) completed their required monitoring and reporting.
Draft ICR for UCMR 3 Proposed Rule September 2010

59

4 COLLECTION METHODS AND FOLLOW-UP

4(a) Collection Methods 

Large PWSs (those serving more than 10,000 people) are required to submit their data 

through EPA's electronic data reporting system. Small PWSs (those serving 10,000 or fewer 

people) will be working directly with an EPA-appointed UCMR Sampling Coordinator, and 

monitoring data from the small PWSs will be submitted directly to EPA's electronic reporting 

system by the laboratories conducting the analyses. 

4(b) Survey Response and Follow-up 

High compliance levels (>95%) during UCMR 1 and 2 have given EPA confidence that 

equivalent or better levels can be achieved during UCMR 3. EPA plans to continue outreach and 

compliance assistance efforts, as needed. Each small system will be working with a UCMR 

Sampling Coordinator, and will have minimal reporting requirements and one-on-one 

compliance assistance. 

Lessons learned during UCMR 1 and UCMR 2 helped refine several UCMR 3

requirements. Reporting deadlines have been more clearly defined for UCMR 3. Laboratories 

now have 60 days, rather than 120 days to electronically report sample results, and systems have 

30 days to review, approve, and report data. With the previous turn-around times, it was 

sometimes difficult to ensure compliance with established monitoring schedules; these new, 

turnaround times will reduce the chance of scheduled monitoring being missed or delayed. In 

addition, sampling frequency requirements have been refined, and now require that sampling 

schedules be adjusted based on sample point availability. 

5 ANALYZING AND REPORTING SURVEY RESULTS

5(a) Data Preparation 

After PWSs or their laboratories post their UCMR 3 monitoring results and required data 

elements to EPA's electronic reporting system, EPA allows a specified time for quality control 

review by the PWSs, States, and the Agency before placing the data in the NCOD for public 

access. 

Data problems may occur, but the following efforts will be taken by EPA to reduce 

problems and increase the dependability and quality of the occurrence data. The UCMR 
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60

electronic data reporting system and EPA QA/QC assessments will screen for the use of 

inappropriate measurement units and other improper data. In addition, EPA plans to have other 

automated QC functions in place to identify possible data quality issues such as duplicate data 

submissions, and data completeness. All samples will be collected by trained PWS staff and 

analytical results will be generated by laboratories that are approved for UCMR 3 drinking water 

analysis. Electronic data submission also avoids potential re-keying errors. Therefore, some

assumptions are made regarding the general quality of the raw data that will be received. As part 

of the data QA/QC procedures, all edits or changes made to the data will be documented.

5(b) Analysis

For UCMR 1 and UCMR 2, EPA developed a two-stage analytical approach for the 

evaluation of the national occurrence of contaminants. EPA expects to use the same 2-tier 

approach to analyzing the data for UCMR 3.

The first stage of analysis, Stage 1, provides a straightforward evaluation of occurrence 

for simple and conservative assessments of contaminant occurrence. The Stage 1 analysis of the 

UCMR data consists of non-parametric, unweighted counts and simple descriptive statistics of 

analytical results for each of the contaminants. These occurrence analyses are conducted at the 

sample level, system level and population-served level. For each contaminant, occurrence 

measures include the number and percent of samples for each contaminant with analytical 

detections, and the minimum, median, maximum, and 99th percentile values of those detections. 

System-level occurrence measures include the number and percent of systems with one or more 

analytical detections, and the number and percent of systems with two or more analytical 

detections of a given contaminant. Population-served occurrence measures include: the number 

and percent of population served by systems with one or more analytical detections, and the 

number and percent of population served by systems with two or more analytical detections of a 

given contaminant. Similar measures may also be conducted for each entry point to the 

distribution system for each system. Since these contaminant and system level occurrence 

measures are based on raw occurrence data (that have not been adjusted for populationweighting and sampling), they are less accurate representations of national occurrence than 

occurrence measures based on adjusted occurrence data. 

Based on the findings of the Stage 1 analysis, EPA can select contaminant(s) for which 

more detailed and sophisticated statistical evaluations – the Stage 2 analysis – may be warranted 

as a next step to generate national probability estimates of contaminant occurrence and exposure. 

Specifically, the modeling and estimation of system mean contaminant concentrations may be 

desired. The Stage 2 analysis uses a Bayesian-based hierarchical model to estimate the percent 

(and number) of systems with a mean contaminant concentration above any specified 

concentration threshold. The Bayesian-based Hierarchical Model also provides quantified error 

of estimation, and enables estimates of mean contaminant concentrations below the MRL. This 
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61

statistical model was used to generate the contaminant occurrence estimates for 60 regulated

contaminants for the first Six-Year Review of NPDWRs, for which it underwent a peer review. 

5(c) Reporting Results 

After final review, formatting, and analysis of the data collected through this ICR, the 

data will be made available to the public through the NCOD, as is being done with the data 

collected and analyzed for UCMR 1 and UCMR 2. A full report, including detailed descriptions 

of the occurrence analysis approach; data characteristics (including data quality and limitations); 

analytical methodology; and analytical results, will be provided to the public and posted on the 

UCMR 3 website once complete. The analytical results and report will provide support for 

regulatory determinations for the drinking water CCL.
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APPENDICES
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APPENDIX A: Relevant Authorities in the SDWA 1996 Amendments 

Section 1401 For purposes of this title:

(1) The term ―primary drinking water regulation‖ means a regulation which-

(A) applies to public water systems;

(B) specifies contaminants which, in the judgment of the Administrator, may have any 

adverse effect on the health of persons;

(C) specifies for each such contaminant either–

(i) a maximum contaminant level, if, in the judgment of the Administrator, it is 

economically or technologically feasible to ascertain the level of such 

contaminant in water in public water systems, or

(ii) if, in the judgment of the Administrator, it is not economically or 

technologically feasible to ascertain the level of such contaminant sufficient to 

satisfy the requirements of section 1412; and

(D) contains criteria and procedures to assure a supply of drinking water which 

dependably complies with such maximum contaminant levels; including accepted 

methods for quality control and testing procedures to ensure compliance with such levels 

and to ensure proper operation and maintenance of the system, and requirements as to (i) 

the minimum quality of water which may be taken into the system and (ii) siting for new 

facilities for public water systems. At any time after promulgation of a regulation referred 

to in this paragraph, the Administrator may add equally effective quality control and 

testing procedures by guidance published in the Federal Register. Such procedures shall 

be treated as an alternative for public water systems to the quality control and testing 

procedures listed in the regulation.

Section 1412(b)(1) Identification of contaminants for listing:

(A) General authority – The Administrator shall, in accordance with the procedures 

established by this subsection, publish a maximum contaminant level goal and 

promulgate a national primary drinking water regulation for a contaminant (other than a 

contaminant referred to in paragraph (2) for which a national primary drinking water 

regulation has been promulgated as of the date of enactment of the Safe Drinking Water 

Act Amendments of 1996) if the Administrator determines that:

(i) the contaminant may have an adverse effect on the health of persons;

(ii) the contaminant is known to occur or there is a substantial likelihood that the 

contaminant will occur in public water systems with a frequency and at levels of 

public health concern; and 

(iii) in the sole judgment of the Administrator, regulation of such contaminant 

presents a meaningful opportunity for health risk reduction for persons served by 

public water systems. 

(B) Regulation of unregulated contaminants–

(i) Listing of contaminants for consideration–

(I) Not later than 18 months after the date of enactment of the Safe 

Drinking Water Act Amendments of 1996 and every 5 years thereafter, the 
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Administrator, after consultation with the scientific community, including 

the Science Advisory Board, after notice and opportunity for public 

comment, and after considering the occurrence data base established under 

section 1445(g), shall publish a list of contaminants which, at the time of 

publication, are not subject to any proposed or promulgated national 

primary drinking water regulation, which are known or anticipated to 

occur in public water systems, and which may require regulation under 

this title. 

(II) The unregulated contaminants considered under subclause (i) shall 

include, but not be limited to, substances referred to in section 101(14) of 

the Comprehensive Environmental Response, Compensation, and Liability 

Act of 1980, and substances registered as pesticides under the Federal 

Insecticide, Fungicide, and Rodenticide Act. 

(III) The Administrator's decision whether or not to select an unregulated 

contaminant for a list under this clause shall not be subject to judicial 

review. 

(ii) Determination to regulate–

(I) Not later than 5 years after the date of enactment of the Safe Drinking 

Water Act Amendments of 1996, and every 5 years thereafter, the 

Administrator shall, after notice of the preliminary determination and 

opportunity for public comment, for not fewer than 5 contaminants 

included on the list published under clause (i), make determinations of 

whether or not to regulate such contaminants.

(II) A determination to regulate a contaminant shall be based on findings 

that the criteria of clauses (i), (ii), and (iii) of subparagraph (A) are 

satisfied. Such findings shall be based on the best available public health 

information, including the occurrence data base established under section 

1445(g).

(III) The Administrator may make a determination to regulate a 

contaminant that does not appear on a list under clause (i) if the 

determination to regulate is made pursuant to subclause (II).

(IV) A determination under this clause not to regulate a contaminant shall 

be considered final agency action and subject to judicial review. 

(iii) Review – Each document setting forth the determination for a contaminant 

under clause (ii) shall be available for public comment at such time as the 

determination is published.

(C) Priorities – In selecting unregulated contaminants for consideration under 

subparagraph (B), the Administrator shall select contaminants that present the greatest 

public health concern. The Administrator, in making such selection, shall take into 

consideration, among other factors of public health concern, the effect of such 

contaminants upon subgroups that comprise a meaningful portion of the general 

population (such as infants, children, pregnant women, the elderly, individuals with a 

history of serious illness, or other subpopulations) that are identifiable as being at greater 

risk of adverse health effects due to exposure to contaminants in drinking water than the 

general population.
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(D) Urgent threats to public health – The Administrator may promulgate an interim 

national primary drinking water regulation for a contaminant without making a 

determination for the contaminant under paragraph (4)(C), or completing the analysis 

under paragraph (3)(C), to address an urgent threat to public health as determined by the 

Administrator after consultation with and written response to any comments provided by 

the Secretary of Health and Human Services, acting through the director of the Centers 

for Disease Control and Prevention or the director of the National Institutes of Health. A 

determination for any contaminant in accordance with paragraph (4)(C) subject to an 

interim regulation under this subparagraph shall be issued, and a completed analysis 

meeting the requirements of paragraph (3)(C) shall be published, not later than 3 years 

after the date on which the regulation is promulgated and the regulation shall be 

repromulgated, or revised if appropriate, not later than 5 years after that date.

(E) Regulation – For each contaminant that the Administrator determines to regulate 

under subparagraph (B), the Administrator shall publish maximum contaminant level 

goals and promulgate, by rule, national primary drinking water regulations under this 

subsection. The Administrator shall propose the maximum contaminant level goal and 

national primary drinking water regulation for a contaminant not later than 24 months 

after the determination to regulate under subparagraph (B), and may publish such 

proposed regulation concurrent with the determination to regulate. The Administrator 

shall publish a maximum contaminant level goal and promulgate a national primary 

drinking water regulation within 18 months after the proposal thereof. The Administrator, 

by notice in the Federal Register, may extend the deadline for such promulgation for up 

to 9 months.

(F) Health advisories and other actions – The Administrator may publish health 

advisories (which are not regulations) or take other appropriate actions for contaminants 

not subject to any national primary drinking water regulation.

Section 1412(b)(4) Goals and standards:

(A) Maximum contaminant level goals – Each maximum contaminant level goal 

established under this subsection shall be set at the level at which no known or 

anticipated adverse effects of health of persons occur and which allows an adequate 

margin of safety.

(B) Maximum contaminant levels – Except as provided in paragraphs (5) and (6), each 

national primary drinking water regulation for a contaminant for which a maximum 

contaminant level goal is established under this subsection shall specify a maximum

contaminant level for such a contaminant which is as close to the maximum contaminant 

level goal as is feasible.

(C) Determination – At the time the Administrator proposes a national primary drinking 

water regulation under this paragraph, the Administrator shall publish a determination as 

to whether the benefits of the maximum contaminant level justify, or do not justify, the 

costs based on the analysis conducted under paragraph (3)(C).

(D) Definition of feasible – For the purposes of this subsection, the term ―feasible‖ means 

feasible with the use of the best technology, treatment techniques, and other means which 

the Administrator finds, after examination for efficacy under field conditions and not 

solely under laboratory conditions, are available (taking cost into consideration). For the 
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66

purpose of this paragraph, granular activated carbon is feasible for the control of 

synthetic organic chemicals, and any technology, treatment technique, or other means 

found to be the best available for the control of synthetic organic chemicals must be at 

least as effective in controlling synthetic organic chemicals as granular activated carbon.

(E) Feasible technologies:

(i) In general – Each national primary drinking water regulation which establishes 

a maximum contaminant level shall list the technology, treatment techniques, and 

other means which the Administrator finds to be feasible for purposes of meeting 

such maximum contaminant level, but regulation under this subsection shall not 

require that any specified technology, treatment technique, or other means be used 

for purposes of meeting such maximum contaminant level.

(ii) List of technologies for small systems – The Administrator shall include in the 

list any technology, treatment technique, or other means that is affordable, as 

determined by the Administrator in consultation with the States, for small public 

water systems serving:

(I) a population of 10,000 or fewer but more than 3,300;

(II) a population of 3,300 or fewer but more than 500; and 

(III) a population of 500 or fewer but more than 25; 

and that achieves compliance with the maximum contaminant level or treatment 

technique, including packaged or modular systems and point- of-entry or point-ofuse treatment units. Point- of-entry and point-of-use treatment units shall be 

owned, controlled and maintained by the public water system or by a person 

under contract with the public water system to ensure proper operation and 

maintenance and compliance with the maximum contaminant level or treatment 

technique and equipped with mechanical warnings to ensure that customers are 

automatically notified of operational problems. The Administrator shall not 

include in the list any point-of-use treatment technology, treatment technique, or 

other means to achieve compliance with a maximum contaminant level or 

treatment technique requirement for a microbial contaminant (or an indicator of a 

microbial contaminant). If the American National Standards Institute has issued 

product standards applicable to a specific type of point-of-entry or point-of-use 

treatment unit, individual units of that type shall not be accepted for compliance 

with a maximum contaminant level or treatment technique requirement unless 

they are independently certified in accordance with such standards. In listing any 

technology, treatment technique, or other means pursuant to this clause, the 

Administrator shall consider the quality of the source water to be treated. 

(iii) List of technologies that achieve compliance – Except as provided in clause 

(v), not later than 2 years after the date of enactment of this clause and after 

consultation with the States, the Administrator shall issue a list of technologies 

that achieve compliance with the maximum contaminant level or treatment 

technique for each category of public water systems described in subclauses (I), 

(II), and (III) of clause (ii) for each national primary drinking water regulation 

promulgated prior to the date of enactment of this paragraph.

(iv) Additional technologies – The Administrator may, at any time after a national 

primary drinking water regulation has been promulgated, supplement the list of 

technologies describing additional or new or innovative treatment technologies 
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that meet the requirements of this paragraph for categories of small public water 

systems described in subclauses (I), (II), and (III) of clause (ii) that are subject to 

the regulation. 

(v) Technologies that meet surface water treatment rule – Within one year after 

the date of enactment of this clause, the Administrator shall list technologies that 

meet the Surface Water Treatment Rule for each category of public water systems 

described in subclauses (I), (II), and (III) of clause (ii).

Section 1445(a)(1)(A) Every person who is subject to any requirement of this title or who is a 

grantee, shall establish and maintain such records, make such reports, conduct such monitoring, 

and provide such information as the Administrator may reasonably require by regulation to assist 

the Administrator in establishing regulations under this title, in determining whether such person 

has acted or is acting in compliance with this title, in administering any program of financial 

assistance under this title, in evaluating the health risks of unregulated contaminants, or in 

advising the public of such risks. In requiring a public water system to monitor under this 

subsection, the Administrator may take into consideration the system size and the contaminants 

likely to be found in the system's drinking water. 

(B) Every person who is subject to a national primary drinking water regulation under 

section 1412 shall provide such information as the Administrator may reasonably require, 

after consultation with the State in which such person is located if such State has primary 

enforcement responsibility for public water systems, on a case-by-case basis, to 

determine whether such person has acted or is acting in compliance with this title. 

(C) Every person who is subject to a national primary drinking water regulation under 

section 1412 shall provide such information as the Administrator may reasonably require 

to assist the Administrator in establishing regulations under section 1412 of this title, 

after consultation with States and suppliers of water. The Administrator may not require 

under this subparagraph the installation of treatment equipment or process changes, the 

testing of treatment technology, or the analysis or processing of monitoring samples, 

except where the Administrator provides the funding for such activities. Before 

exercising this authority, the Administrator shall first seek to obtain the information by 

voluntary submission. 

(D) The Administrator shall not later than 2 years after the date of enactment of this 

subparagraph, after consultation with public health experts, representatives of the general 

public, and officials of State and local governments, review the monitoring requirements 

for not fewer than 12 contaminants identified by the Administrator, and promulgate any 

necessary modifications.

(2) MONITORING PROGRAM FOR UNREGULATED CONTAMINANTS:

(A) ESTABLISHMENT – The Administrator shall promulgate regulations establishing 

the criteria for a monitoring program for unregulated contaminants. The regulations shall 

require monitoring of drinking water supplied by public water systems and shall vary the 

frequency and schedule for monitoring requirements for systems based on the number of 

persons served by the system, the source of supply, and the contaminants likely to be 

found, ensuring that only a representative sample of systems serving 10,000 persons or 

fewer are required to monitor.
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(B) MONITORING PROGRAM FOR CERTAIN UNREGULATED 

CONTAMINANTS:

(i) INITIAL LIST – Not later than 3 years after the date of enactment of the Safe 

Drinking Water Act Amendments of 1996 and every 5 years thereafter, the 

Administrator shall issue a list pursuant to subparagraph (A) of not more than 30 

unregulated contaminants to be monitored by public water systems and to be 

included in the national drinking water occurrence data base maintained pursuant 

to subsection (g).

(ii) GOVERNORS' PETITION – The Administrator shall include among the list 

of contaminants for which monitoring is required under this paragraph each 

contaminant recommended in a petition signed by the Governor of each of 7 or 

more States, unless the Administrator determines that the action would prevent 

the listing of other contaminants of a higher public health concern.

(C) MONITORING PLAN FOR SMALL AND MEDIUM SYSTEMS 

(i) IN GENERAL – Based on the regulations promulgated by the Administrator, 

each State may develop a representative monitoring plan to assess the occurrence 

of unregulated contaminants in public water systems that serve a population of 

10,000 or fewer in that State. The plan shall require monitoring for systems 

representative of different sizes, types, and geographic locations in the State.

(ii) GRANTS FOR SMALL SYSTEM COSTS – From funds reserved under 

section 1452(o) or appropriated under subparagraph (H), the Administrator shall 

pay the reasonable cost of such testing and laboratory analysis as are necessary to 

carry out monitoring under the plan.

(D) MONITORING RESULTS – Each public water system that conducts monitoring of 

unregulated contaminants pursuant to this paragraph shall provide the results of the 

monitoring to the primary enforcement authority for the system.

(E) NOTIFICATION – Notification of the availability of the results of monitoring 

programs required under paragraph (2)(A) shall be given to the persons served by the 

system.

(F) WAIVER OF MONITORING REQUIREMENT – The Administrator shall waive the 

requirement for monitoring for a contaminant under this paragraph in a State, if the State 

demonstrates that the criteria for listing the contaminant do not apply in that State.

(G) ANALYTICAL METHODS – The State may use screening methods approved by the 

Administrator under subsection (i) in lieu of monitoring for particular contaminants under 

this paragraph.

(H) AUTHORIZATION OF APPROPRIATIONS – There are authorized to be 

appropriated to carry out this paragraph $10,000,000 for each of the fiscal years 1997 

through 2003.

(d) SCREENING METHODS – Section 1445 (42 U.S.C. 300j_4) is amended by adding the 

following after subsection (h):

(I) SCREENING METHODS – The Administrator shall review new analytical methods 

to screen for regulated contaminants and may approve such methods as are more accurate 

or cost-effective than established reference methods for use in compliance monitoring.

(g) OCCURRENCE DATA BASE 
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69

(1) IN GENERAL – Not later than 3 years after the date of enactment of the Safe 

Drinking Water Act Amendments of 1996, the Administrator shall assemble and maintain 

a national drinking water contaminant occurrence data base, using information on the 

occurrence of both regulated and unregulated contaminants in public water systems 

obtained under subsection (a)(1)(A) or subsection (a)(2) and reliable information from 

other public and private sources.

(2) PUBLIC INPUT – In establishing the occurrence data base, the Administrator shall 

solicit recommendations from the Science Advisory Board, the States, and other 

interested parties concerning the development and maintenance of a national drinking 

water contaminant occurrence data base, including such issues as the structure and design 

of the data base, data input parameters and requirements, and the use and interpretation of 

data.

(3) USE – The data shall be used by the Administrator in making determinations under 

section 1412(b)(1) with respect to the occurrence of a contaminant in drinking water at a 

level of public health concern.

(4) PUBLIC RECOMMENDATIONS – The Administrator shall periodically solicit 

recommendations from the appropriate officials of the National Academy of Sciences and 

the States, and any person may submit recommendations to the Administrator, with 

respect to contaminants that should be included in the national drinking water 

contaminant occurrence data base, including recommendations with respect to additional 

unregulated contaminants that should be listed under subsection (a)(2). Any 

recommendation submitted under this clause shall be accompanied by reasonable 

documentation that–

(A) the contaminant occurs or is likely to occur in drinking water; and

(B) the contaminant poses a risk to public health.

(5) PUBLIC AVAILABILITY – The information from the data base shall be available to 

the public in readily accessible form.

(6) REGULATED CONTAMINANTS – With respect to each contaminant for which a 

national primary drinking water regulation has been established, the data base shall 

include information on the detection of the contaminant at a quantifiable level in public 

water systems (including detection of the contaminant at levels not constituting a 

violation of the maximum contaminant level for the contaminant).

(7) UNREGULATED CONTAMINANTS – With respect to contaminants for which a 

national primary drinking water regulation has not been established, the data base shall 

include:

(A) monitoring information collected by public water systems that serve a 

population of more than 10,000, as required by the Administrator under 

subsection (a);

(B) monitoring information collected from a representative sampling of public 

water systems that serve a population of 10,000 or fewer; and

(C) other reliable and appropriate monitoring information on the occurrence of the 

contaminants in public water systems that is available to the Administrator.
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APPENDIX B: Burden and Cost Exhibits for the Five-Year UCMR 3 Cycle of 

2012-2016

Exhibit B-1a: Yearly Cost to Systems, by System Size and by Type of Cost (2012-2016) 

(corresponds to Exhibit 11a)

Cost Description 2012 2013 2014 2015 2016 Total

SMALL SYSTEMS (serving 10,000 or fewer people)

Labor Costs

Reading and Initial 

Reporting $0 $36,338 $36,338 $36,338 $0 $109,014

Monitoring $0 $31,773 $31,773 $31,773 $0 $95,319

Reporting of Results $0 $13,596 $13,596 $13,596 $0 $40,787

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

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

Subtotal – Small 

Systems $0 $81,707 $81,707 $81,707 $0 $245,120

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

Labor Costs

Reading and Initial 

Reporting $0 $454,279 $454,279 $454,279 $0 $1,362,837

Monitoring $0 $258,264 $258,264 $258,264 $0 $774,793

Reporting of Results $0 $253,244 $253,244 $253,244 $0 $759,731

Non-Labor Costs (Laboratory Analysis and Shipping)

$0 $13,504,932 $13,504,932 $13,504,932 $0 $40,514,795

Subtotal – Large 

Systems $0 $14,470,719 $14,470,719 $14,470,719 $0 $43,412,156

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

Labor Costs

Reading and Initial 

Reporting $0 $59,085 $59,085 $59,085 $0 $177,254

Monitoring $0 $83,637 $83,637 $83,637 $0 $250,910

Reporting of Results $0 $38,505 $38,505 $38,505 $0 $115,514

Non-Labor Costs (Laboratory Analysis and Shipping)

$0 $3,357,633 $3,357,633 $3,357,633 $0 $10,072,899

Subtotal – Very Large 

Systems $0 $3,538,859 $3,538,859 $3,538,859 $0 $10,616,577

ALL SYSTEMS

Total Labor for 

All Systems $0 $1,228,719 $1,228,719 $1,225,524 $0 $3,686,158

Total Non-Labor for All 

Systems $0 $16,862,565 $16,862,565 $16,862,565 $0 $50,587,694

Total Labor and NonLabor for All Systems $0 $18,091,284 $18,091,284 $18,091,284 $0 $54,273,852
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Exhibit B-1b: Per System (Respondent) and Per Response UCMR 3 Costs (2012-2016) 

(corresponds with Exhibit 11b)

Burden / Cost

Total over 2012-2016 Annual Average over 2012-2016

Small Systems Large Systems Very Large 

Systems Small Systems Large Systems Very Large Systems

PER RESPONDENT:

Labor Cost $92 $460 $796 $31 $153 $265

Non-Labor Cost $0 $6,429 $14,741 $0 $2,143 $4,914

Burden (labor hours) 4.0 14.7 20.8 1.3 4.9 6.9

PER RESPONSE:

Number Responses per 

Respondent 2.2 3.2 3.7 0.7 1.1 1.2

Labor Cost per 

Response $69 $238 $361 $23 $79 $120

Non-Labor Cost per 

Response $0 $3,329 $6,680 $0 $1,110 $2,227

Burden (labor hours) 

per Response 3.0 7.6 9.4 1.0 2.5 3.1

Exhibit B-2a: Yearly Cost and Burden to States for Implementation of UCMR 3 (2012-

2016)

1

(corresponds with Exhibit 13a)

Cost/

Burden 2012 2013 2014 2015 2016 Total Annual Average

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

$331,538 $994,614 $1,024,452 $1,055,186 $362,280 $3,768,069 $753,614

Labor burden for all States for UCMR implementation and oversight (number of hours) 

13,342 13,625 12,238 6,202 6,108 51,515 10,303

1 All costs are attributed to labor and are estimated over the period 2012-2016. 

Exhibit B-2b: Per State (Respondent) and Per Response UCMR 3 Costs (2012-2016) 

(corresponds with Exhibit 13b)

Burden / Cost Total over 2012-2016

Annual Average 

over 2012-2016

PER RESPONDENT:

Labor Cost $67,285 $13,457

Non-Labor Cost $0 $0

Burden (labor hours) 920 184

PER RESPONSE:
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Exhibit B-2b: Per State (Respondent) and Per Response UCMR 3 Costs (2012-2016) 

(corresponds with Exhibit 13b)

Burden / Cost Total over 2012-2016

Annual Average 

over 2012-2016

Number Responses per Respondent15.0 1.0

Labor Cost per Response $13,457 $2,691

Non-Labor Cost per Response $0 $0

Burden (labor hours) per Response 184 37

1

States are assumed to have 1 response per year, since there are no specific cyclical State reporting requirements under the 

UCMR program. 

Exhibit B-3a: Yearly Cost to EPA for UCMR 3 Implementation, by Type of Cost (2012-

2016) 1(corresponds with Exhibit 14a)

Cost Description 2012 2013 2014 2015 2016 Total Average

Regulatory Support Activities: laboratory proficiency testing; QC audits; analytical standards provision; and 

technical support, guidance document development

Lab PT $231,855 $0 $0 $0 $0 $231,855 $46,371

QC Audits $17,399 $34,799 $34,799 $17,399 $0 $104,396 $20,879

Analytical 

Standards

$115,927 $238,811 $245,975 $253,354 $0 $854,067 $170,813

Technical Support $115,927 $59,703 $0 $0 $0 $175,630 $35,126

Subtotal –

Regulatory 

Support

$481,108 $333,313 $280,774 $270,753 $0 $1,365,948 $273,190

National and Regional Oversight and Data Analysis: UCMR management oversight; review and evaluation of 

data from Assessment Monitoring

$442,499 $884,998 $884,998 $884,998 $0 $3,079,494 $619,499

Small System Testing: implementation coordination; and analytical and shipping costs for small system testing for 

both Assessment Monitoring and Screening Surveys

Implementation 

Coordination $0 $1,081,021 $1,081,021 $1,081,021 $0 $3,243,064 $648,613

Fees for Analysis 

and shipping $0 $2,862,805 $2,862,805 $2,862,805 $0 $8,588,416 $11,717,683

Subtotal –

Small System 

Testing

$0 $3,943,827 $3,943,827 $3,943,827 $0 $11,831,480 $2,366,296

TOTAL $923,607 $5,162,138 $5,109,599 $5,099,578 $0 $16,294,922 $3,258,984

1 Agency costs are estimated over the period 2012-2016. 
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Exhibit B-3b: Summary of EPA Burdens and Costs for UCMR 3 Implementation (2012-

2016) (corresponds with Exhibit 14b)

Burden / Cost Annual Average Cost over Five-Year UCMR Period 

(2012-2016)

Labor Cost $619,499

Non-Labor Cost $2,639,486

Total Cost to EPA for UCMR Implementation $3,258,985

Burden (labor hours) 8,008

Exhibit B-4: National Cost Summary for UCMR 3 Implementation (2012-2016) 

(corresponds with Exhibit 15)

Type of Cost 2012 2013 2014 2015 2016 TOTAL

Small Systems

Labor Cost $0 $81,707 $81,707 $81,707 $0 $245,120

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

Total Small 

System Cost $0 $81,707 $81,707 $81,707 $0 $245,120

Large Systems

Labor Cost $0 $965,787 $965,787 $965,787 $0 $2,897,360

Non-Labor Cost $0 $13,504,932 $13,504,932 $13,504,932 $0 $40,514,795

Total Large 

System Cost $0 $14,470,719 $14,470,719 $14,470,719 $0 $43,412,156

Very Large Systems

Labor Cost $0 $181,226 $181,226 $181,226 $0 $543,678

Non-Labor Cost $0 $3,357,633 $3,357,633 $3,357,633 $0 $10,072,899

Total Very 

Large 

System Cost $0 $3,538,859 $3,538,859 $3,538,859 $0 $10,616,577

States

Labor Cost $331,538 $994,614 $1,024,452 $1,055,186 $362,280 $3,768,069

Non-Labor Cost 0 0 0 0 0 0

Total State Cost $331,538 $994,614 $1,024,452 $1,055,186 $362,280 $3,768,069

EPA

Labor Cost $442,499 $884,998 $884,998 $884,998 $0 $3,097,494

Non-Labor Cost $481,108 $4,277,139 $4,224,600 $4,214,580 $0 $13,197,428

Total EPA Cost $923,608 $5,162,138 $5,109,599 $5,099,578 $0 $16,294,922

National Total

Total with EPA $1,255,145 $24,248,035 $24,225,335 $24,246,048 $362,280 $74,336,844
Draft ICR for UCMR 3 Proposed Rule September 2010

74

Exhibit B-4: National Cost Summary for UCMR 3 Implementation (2012-2016) 

(corresponds with Exhibit 15)

Type of Cost 2012 2013 2014 2015 2016 TOTAL

Total without 

EPA $331,538 $19,085,898 $19,115,736 $19,146,470 $362,280 $58,041,922

Total Burden (hours) for All Responses

Small Systems 0 3,545 3,545 3,545 0 10,636

Large Systems 0 30,926 30,926 30,926 0 92,777

Very Large 

Systems 0 4,732 4,732 4,732 0 14,195

States 13,342 13,625 12,238 6,202 6,108 51,515

EPA 5,720 11,440 11,440 11,440 0 40,040

Total with EPA 19,062 64,268 62,881 56,845 6,108 209,164

Total without 

EPA 13,342 52,828 51,441 45,405 6,108 169,124

1 Although EPA is not considered a respondent to the UCMR regulations, Agency burdens are shown here to 

illustrate the national costs of the program. National totals are shown with and without the Agency costs.

Exhibit B-5: UCMR 3 Per Respondent Burden and Cost Summary (2012-2016) 

(corresponds with Exhibit 16)

Burden (hours)/

Cost (dollars)

Small 

Systems

Large 

Systems

Very Large 

Systems States EPA

National 

Average 

with EPA1

National 

Average 

without 

EPA

Five-Year Total per Respondent

Total # of 

Responses Per 

Respondent 2.2 3.2 3.7 5.0 n/a n/a 3.0

Labor Cost Per 

Respondent $153 $766 $1,326 $67,287 $3,097,494 $1,804 $1,275

Non-Labor Cost 

Per Respondent n/a $10,715 $24,568 n/a $13,197,428 $10,907 $8,652

Total Cost 

(Labor plus 

Non-Labor) $153 $11,482 $25,894 $67,287 $16,294,922 $12,711 $9,927

Total Cost Per 

Response $69 $3,567 $7,040 $13,457 n/a n/a $3,312

Total Burden Per 

Respondent 6.6 24.5 34.6 919.9 40040.0 35.8 28.9

Total Burden Per 

Response 3.0 3.2 3.7 184.0 n/a n/a 9.7

Average Annual per Respondent
Draft ICR for UCMR 3 Proposed Rule September 2010

75

Exhibit B-5: UCMR 3 Per Respondent Burden and Cost Summary (2012-2016) 

(corresponds with Exhibit 16)

Burden (hours)/

Cost (dollars)

Small 

Systems

Large 

Systems

Very Large 

Systems States EPA

National 

Average 

with EPA1

National 

Average 

without 

EPA

Ave. # of 

Responses Per 

Respondent 0.4 0.6 0.7 1.0 n/a n/a 0.6

Labor Cost Per 

Respondent $31 $153 $265 $13,457 $619,499 $361 $255

Non-Labor Cost 

Per Respondent n/a $2,143 $4,914 n/a $2,639,486 $2,181 $1,730

Ave. Cost (Labor 

plus Non-Labor) $31 $2,296 $5,179 $13,457 $3,258,984 $2,542 $1,985

Ave. Cost Per 

Response $14 $713 $1,408 $2,691 n/a n/a $662

Ave. Burden Per 

Respondent 1.3 4.9 6.9 184.0 8008.0 7.2 5.8

Ave. Burden Per 

Response 0.6 0.6 0.7 36.8 n/a n/a 1.9

1 National average burdens and costs differ greatly between the State respondents and the various system 

respondents. This should be taken into consideration when looking at the national average with or without EPA.