## DRAFT Information Collection Request
for the Unregulated Contaminant Monitoring Rule ( UCMR 4)

November 2015

P repared by: The Cadmus Group, Inc.
100 5 th Ave.
Waltham , MA 02451

P repared for: Brenda D. Parris, Project Officer Melissa Simic, Alternate Project Officer U.S. Environmental Protection Agency Office of Ground Water and Drinking Water 26 West Martin Luther King Drive Cincinnati, OH 45268

Office of Water (MS -140) EPA 815-B-15-003 November 2015Draft ICR for UCMR 4 Proposed Rule November 2015



### TABLE OF CONTENTS

– PART A OF THE SUPPORTING STATEMENT – .............................................................. 1

1 IDENTIFICATION OF THE INFORMATION COLLECTION ......................................... 1 1(a) Title and Number of the Information Collection .......................................................... 1 1(b) Short Characterization .................................................................................................. 1

2 NEED FOR AND USE OF THE COLLECTION

................................ ............................. 4 2(a) Need/Authority for the Collection ................................................................................ 4 2(b) Practical Utility/Users of the Data ................................................................................ 4
3 NON

- DUPLICATION, CONSULTATIONS AND OTHER COLLECTION CRITERIA . 6 3(a) Non -duplication ............................................................................................................ 6 3(b) Public Notice Required Prior to ICR Submission to OMB .......................................... 6 3(c) Consultations ................................................................................................................ 7 3(d) Effects of Less Frequent Collection ............................................................................. 7 3(e) General Guidelines ....................................................................................................... 9 3(f) Confidentiality ............................................................................................................ 10 3(g) Sensitive Questions..................................................................................................... 10

4 RESPONDENTS AND THE INFORMATION ................................................................. 11 4(a) Respondents and North American Industry Classification System (NAICS)/Standard Industrial Classification (SIC) Codes ..................................................................................... 11 4(b) Information Requested ............................................................................................... 11
5 INFORMATION COLLECTED

– AGENCY ACTIVITIES, COLLECTION
METHODOLOGY AND INFORMATION MANAGEMENT ................................................ 19 5(a) Agency Activities ....................................................................................................... 19 5(b) Information Collection Methodology and Management ............................................ 20 5(c) Small Entity Flexibility .............................................................................................. 21 5(d) Collection Schedule .................................................................................................... 25

6 ESTIMATING THE BURDEN AND COST OF THE COLLECTION ............................ 28 6(a) Estimating Burden and Cost to PWSs ........................................................................ 28 6(b) Estimating the Burden and Cost to States .................................................................. 38 6(c) Estimating Agency Burden and Cost .......................................................................... 42 6(d) Estimating the Respondent Universe and Total Burden and Costs ............................ 45 6(e) Reasons for Change in Burden ................................................................................... 46 6(f) Burden Statement ....................................................................................................... 47

– PART B OF THE SUPPORTING STATEMENT – ............................................................. 51

1 SURVEY OBJECTIVES, KEY VARIABLES, AND OTHER PRELIMINARIES .......... 51 1(a) Survey Objectives ....................................................................................................... 51 1(b) Key Variables ............................................................................................................. 51 1(c) Statistical Approach .................................................................................................... 51 1(d) Feasibility ................................................................................................................... 51

2 SURVEY DESIGN ............................................................................................................. 52 2(a) Target Population and Coverage ................................................................................ 52Draft ICR for UCMR 4 Proposed Rule November 2015

ii 2(b) Sample Design ............................................................................................................ 52 2(c) Precision Requirements .............................................................................................. 54 2(d) Q uestionnaire Design ................................................................................................. 54
3 PRETESTS AND PILOT TESTS ....................................................................................... 54

4 COLLECTION METHODS AND FOLLOW

- UP ............................................................. 55 4(a) Collection Methods..................................................................................................... 55 4(b) Survey Response and Follow-up ................................................................................ 55
5 ANALYZING AND REPORTING SURVEY RESULTS ................................................. 56 5(a) Data Preparation ......................................................................................................... 56 5(b) A nalysis ...................................................................................................................... 56 5(c) Reporting Results ....................................................................................................... 57
APPENDICES ............................................................................................................................. 58

APPENDIX A: Relevant Authorities in SDWA 1996 Amendments ........................................ 59
APPENDIX B: Burden and Cost Exhibits for the Five- Year UCMR 4 Period of 2017-2021 .. 66Draft ICR for UCMR 4 Proposed Rule November 2015

iii 

### LIST OF EXHIBITS

Ex hibit 1: Proposed UCMR 4 List 1 Analytes.............................................................................. 11 Exhibit 2: UCMR 4 Proposed Reporting Requirements ............................................................... 13 Exhibit 3: Proposed Timeline of UCMR 4 Activities ................................................................... 20 Exhibit 4: Number of Publicly- and Privately

- Owned Small Systems Subject to

UCMR 4 .................................................................................................................................. 22
Exhibit 5: I mplementation of UCMR 4 at Small Systems ............................................................ 23
Exhibit 6: UCMR 4 Relative Cost Analysis for Small Publicly -Owned Systems (2017- 2021) ....................................................................................................................................... 24
Exhibit 7: UCMR 4 Relative Cost Analysis for Small Privately -Owned Systems (2017- 2021) ....................................................................................................................................... 24 Exhibit 8: Systems to Participate in UCMR 4 Monitoring ........................................................... 30
Exhibit 9: UCMR 4 Sampling Activity Timeline for Cost and Burden Estimations ................... 30 Exhibit 10: Assessment Monitoring (List 1) Analytical Costs ..................................................... 35 Exhibit 11a: Yearly Cost to Systems, by PWS Size and by Type of Cost (2017-2019) (corresponds with Exhibit B-1a) ............................................................................................. 37
Exhibit 11b: Per System (Respondent) and Per Response UCMR Costs (2017-2019) (corresponds with Exhibit B-1b) ............................................................................................. 38 Exhibit 12: Number of States in Each Size Category (State Resource Model Assumptions) .......................................................................................................................... 41 Exhibit 13a: Yearly Cost and Burden to States for Implementation of UCMR 4 (2017- 2019) 1 (corresponds with Exhibit B-2a) ................................................................................. 41 Exhibit 13b: Per State (Respondent) and Per Response UCMR 4 Costs (2017-2019) (corresponds with Exhibit B-2b) ............................................................................................. 41 Exhibit 14a: Yearly Cost to EPA for UCMR Implementation, by Type of Cost (2017- 2019) 1 (corresponds with Exhibit B-3a) ................................................................................. 44 Exhibit 14b: Summary of EPA Burdens and Costs for UCMR Implementation (2017- 2019) (corresponds with Exhibit B-3b) ................................................................................... 45 Exhibit 15: UCMR 4 National Cost Summary for the ICR period (2017-2019) (corresponds with Exhibit B-4) ............................................................................................... 45
Exhibit 16: UCMR 4 Per R espondent Burden and Cost Summary for the ICR Period (2017-2019) (corresponds with Exhibit B-5) .......................................................................... 48 Exhibit B-1a: Yearly Cost to Systems, by PWS Size and by Type of Cost (2017-2021) (corresponds with Exhibit 11a)

.............................................................................................. 66 Exhibit B-1b: Per System (Respondent) and Per Response UCMR 4 Costs (2017-2021) (corresponds with Exhibit 11b) ............................................................................................... 67 Exhibit B-2a: Yearly Cost and Burden to States for Implementation of UCMR 4 (2017- 2021) 1 (corresponds with Exhibit 13a) ................................................................................... 67 Exhibit B-2b: Per State (Respondent) and Per Response UCMR 4 Costs (2017-2021) (corresponds with Exhibit 13b) ............................................................................................... 68Draft ICR for UCMR 4 Proposed Rule November 201 5

iv Exhibit B

- 3a: Yearly Cost to EPA for UCMR 4 Implementation, by Type of Cos t (2017

- 2021) 1 (corresponds with Exhibit 14a)

................................ ................................ ....... 68
Exhibit B

- 3b: Summary of EPA Burdens and Costs for UCMR 4 Implementation (2017

- 2 021) (corresponds with Exhibit 14b)

................................ ................................ .......... 69
Exhibit B

- 4: National Cost Summary for UCMR 4 Implementation (2017

- 2021) (corresponds with Exhibit 15)

................................ ................................ ................................ . 70
Exhibit B

- 5: UCMR 4 Per Respondent Burden and Cost Summary (2017

- 2021) (corresponds with Exhibit 16)

................................ ................................ ................................ . 71Draft ICR for UCMR 4 Proposed Rule November 201 5

v ACRONYMS

μg/L Microgram per liter

ADDA (2S, 3S, 8S, 9S, 4E, 6E)

- 3

- amino

- 9

- methoxy

- 2,6,8

- trimethyl

- 10

- phenyl

- 4,

6

- decadienoic acid

ASDWA Association of State Drinking Water Administrators

ASTM American Society for Testing Materials

BLS United States Bureau of Labor Statistics

CCL Contaminant Candidate List

CCR Consumer Confidence Report

CFR Code of Federal Regulations

CWS Community Water System

DBPR Disinfectants and Disinfection Byproducts Rule

DSMRT Distribution System Maximum Residence Time

EPA United States Environmental Protection Agency

ELISA Enzyme

- linked Immunosorbent Assay

EPTDS Entry Point to the Distri bution System

FR Federal Register

FTE Full

- Time Equivalent

GC Gas Chromatography

GC/MS Gas Chromatography/Mass S pectrometry
GS General Schedule

GW Ground Water

GWUDI Ground Water U nder the Direct Influence of Surface Water

HAAs Haloacetic Acids
HAA5 Dibromoacetic Acid, D ichloroacetic Acid, Monobromoacetic Acid,

M onochlo roacetic Acid, Trichloroacetic A cid

HAA6Br Bromochloroacetic Acid, Bromodichloroacetic Acid, Dibromoacetic Acid, Dibromochloroacetic Acid, M onobr omoacetic Acid, Tribromoaceti c A cid
HAA9 Bromochloroacetic Acid, B romodich loroacetic Acid, Chlorodibromoacetic Acid, Dibromoacetic Acid, D ichlo roacetic Acid, Monobromoacetic Acid, Monochloroacetic Acid, Tribromoacetic Acid, Trichloroacetic A cid

IC

- MS/MS Ion Chromatography/Tandem Mass Spectrometry
ICP

- MS Inductively Coupled Plasma Mass Spectrometry

ICR Information Collection Request

LC/MS/MS Liquid Chromatography/T andem M ass S pectrometry
LT2 Long Term 2 Enhanced Surface Water Treatment Rule

M Million

MRL Minimum Reporting Level

NAICS North American Industry Classification System

NCOD National Drinking Water Contaminant Occurrence Database

NPDWR National Primary Drinking Water RegulationDraft ICR for UCMR 4 Proposed Rule November 201 5

vi NTNCWS Non

- Transient Non

- C ommunity Water System

OES Occupational Employment Stat istics

OGWDW Office of Ground Water and Drinking Water

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 Quality Assurance QA/QC Quality Assurance/Quality Control QC Quality Control

RFA Regulatory Flexibility Act

SBA Small Business Administration

SDWA Safe Drinking Water Act

SIC Standard Industrial Classification

SM Standard Methods

SMP State Monitorin g Plan

SPE Solid Phase Extraction

SRF State Revolving Fund

SW Surface Water

SVOC Semivolatile Organic Chemicals

TNCWS Transient Non

- Community Water System

TOC Total Organic Carbon

UCMR Unregulated Contaminant Monitoring RuleDraft ICR for UCMR 4 Proposed Rule November 201 5

1 

### – PART A OF THE SUPPORTING STATEMENT

–

1 IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Number of the Information Collection

Title : Informati on Collection Request for UCMR 4

OMB Control Number: 2040

- 0270

EPA Tracking Number : 2192.0 7

1(b) Short Characterization
Section 1445(a)(2) of 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). Information collected under the program supports the A gency decision making regarding whether or not to regulat e particular contaminants in drinki ng water. SDWA requires that EPA vary the frequency and schedule for the monitoring prog r am based on the number of persons served, the source of supply

, and the contaminants likely to be found. EPA is required by SDWA

to only include a representative sampl e of PWS s 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 Unregulated Contaminant Monitoring Rule ( UCMR 1 ) for PWSs in th e Federal Register (FR) on September 17, 1999 (64 FR 50556)

. In addition, EPA published

s everal supplemental rules that establish ed analytical methods, and provide d clarifications and
refinements to the initial rule

. The second UCMR ( UCMR 2 ) published in the FR on January 4,
2007

, and the third UCMR (UCMR 3)

, published in the FR on May 2, 2012 (77 FR 26071)

, built

on the established structure of the previous UCMR s , while making some changes to the rule design

. E PA revised the contaminant list , analytical methods , cost assumptions and sampling design for the proposed UCMR 4

.

The five

- year UCMR 4 period spans 2017

- 2021. As proposed, UCMR 4 m onitoring begins in

201 8 and continues through 20 20

. The applicable three

- year period for this particular
Information Collect ion Request (ICR) is 201 7

- 20 19

. T he applicable ICR period overlaps withDraft ICR for UCMR 4 Proposed Rule November 201 5

2 the first three yea rs of the five year UCMR 4 period

. Estimates of implementation burden and
cost over the e ntire five

- year UCMR 4 period (including pre

- monitoring activity and post

monitoring reporting) are attached as Appendix B to this ICR

.

As proposed

, a total of 1,600 PWS s serving 10,000 or fewer people (hereafter referred to as
small PWS s)

, will conduct monitor ing : 800 small PWSs served by surface water ( SW ) or ground water under the direct influence ( GWUDI ) sources will monitor for 10 List 1 cyanotoxins and a
different set of 800 small PWSs served by SW, GWUDI, and ground water ( GW ) will monitor
for 20 Additional List 1 chemicals

. A ll PWS s serving more than 10,000 people will monitor for
the 30 List 1 chemicals. 1 EPA pays for all sample kit pr eparation, sample shipping fees and analysis costs for small PWSs. UCMR 4 List 1 Assessment Monitoring includes monitoring for contaminants for which standard analytical methods or techniques are available

.

The UCMR 4 proposed rule does not include a Screening Survey (List 2) or Pre

- Screen Testing (List 3) component.

Water systems would be required to collect samples during a continuous 12

- month period (excluding December through February) during the sampling time frame

. With the exception of cyanotoxin monitoring, sampling would take place every two months for SW and GWUDI
systems (a total of four samp ling events) , and at 6

- m onth intervals for GW system s (a total of two sampling events ) . For cyanotoxin monitoring, SW and GWUDI systems would collect samples twice a month for four consecutive months (total of eight sampling events). GW PWSs
would be exclu ded from cyanotoxin monitoring.

EPA expects that approximately one

- third of the PWS s will monitor during each of the three monitoring years (20 1 8

- 20 20 ) ; approximately two

- thirds of the PWSs are expected to monitor
between 2018

- 2019

. Approximately o ne

- third of the PWS s will monitor during the second (renewal) UCMR 4 ICR period of 20 20

- 20 2 1

.

Respondents to UCMR 4 include 1,600 small PWS s ( 800 for cyanotoxins monitoring and 8 0 0
for monitoring of the 20 additional chemicals ), 4,292 large and very large PWS s, and 56 s tates and primacy agen cies (referred to collectively as “ s tates ” for simplicity), for a total of 5,948 respondents

. The frequency of response varies across respondents and years

.

Small PWS s selected for UCMR 4 monitori ng sample an average of 6.7 times per PWS ( i.e.

, number of responses per PWS ) across the three

- year ICR period

. The estimated burden per

r esponse for small PWS s is 2.8 hours

. Large PWS s and very large PWS s sam ple and report an average of 11. 4 and 14.1 times per PWS , respectively, across the three

- year ICR period

. The estimated burden per response f or large and very large PWS s, respectively

, are 6.1 and 9.9 hours.

1 Transient non

- community water systems are excluded from Assessment Monitoring under UCMR 4. PWSs served by ground water are excluded from cyanotoxin monitoring.Draft ICR for UCMR 4 Proposed Rule November 201 5

3 States incur only la bor costs associated with UCMR 4 implementation

. State activities are determined through individual Partnership Agreements (PAs) with EPA

. EPA assumed that s tate participation levels would reflect the participation levels that occurred in UCMR 3

. States incur

3 .0 responses over the three

- year ICR period related to coordination with EPA and PWS s, with an average burden per response of 366.5 hours

. In aggregate, during the ICR period, the average response ( i.e., responses from PWS s and s tate s) is associated with a burden of 6.9 hours, with a labor plus non

- labor cost of $ 1,705 per response

.

The annual average per respondent burden hours and costs for the ICR period are : small PWS s

– 6.2 hour s burden at $ 171 for labor; large PWS s

– 23. 3 hours at $ 682 for labor, and $ 6,047 for
anal ytical costs; very large PWS s

– 46.5 hours at $ 1,248 for labor, and $ 16,298 for analytical

costs; and state s

– 244.3 hours at $ 11, 598 for labor

. Annual average burden and cost per respondent is 23.4 hours, with a labor plus non

- labor cost of $ 3,470 per respondent

.

T he annual burden to EPA for UCMR 4 program activit ies during the ICR years is 11,440 hours, at an annual labor cost of $ 905,819

. E PA's annual non

- labor costs are $ 4. 4 million

. EPA's non

labor costs are primarily attributed to the cost of sample analysis for small PWS s ( sample analysis represents approximately 9 1 % of non

- labor cost).Draft ICR for UCMR 4 Proposed Rule November 201 5

4 

### 2 NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection

As part of its responsibilities under SDWA, EPA implements section 1445(a)(2), Monitoring Program for Unregulated Contaminants. This section, as amended in 1996, requires that once every five years, beginning in August 1999, EPA issue a list of no more than 30 unregulated contaminants to be monitored by PWSs. SDWA requires that EPA enter the monitoring data into the Agency ' s NCOD . EPA's UCMR program must ensure that only a national ly representative sample of PWSs serving 10,000 or fewer people are required to monitor . EPA must vary the frequency and schedule for mo nitoring based on the number of persons served, the source of supply and the contaminants likely to be found. EPA is using this authority as the basis for monitoring 29 of 30 contaminants proposed under this rule.

Section 1445(a)(1)(A) of SDWA , as amende d in 1996, requires that every person who is subject to any SDWA requirement 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 th e Administrator in establishing SDWA regulations. Pursuant to this provision, EPA can require the monitoring of contaminants already subject to EPA’s drinking water standards. EPA is using this authority as the basis for monitoring one of the chemical

grou ps (Haloacetic Acids 5 (HAA5)) proposed under this rule.

The sections from SDWA, discussed in the previous paragraphs , are included as Appendix A of this document, in order by section number.

2(b) Practical Utility/Users of the Data

The UCMR 4 data s upport s the Administrator's determination of whether to regulate a
contaminant through the Regulatory Determination process and , as appropriate, regulation development

. I f the contaminant has significant occurrence and health effects, EPA use s the
results to : support an exposure assessment; establish the baseline for health effects and economic analyses; analyze contaminant co

- occurrence; and evaluate treatment technolog ies , including contaminant source management

. T he results can suggest that contaminant occurrence is significant enough to initiate research on health effects and treatment technolog ies

. Finally, the
data can guide future source water protection efforts.

Each PWS maintain s reco rds of the analytical results of this monitoring

. EPA

- approved

l aboratories report these results to EPA's electronic data reporting system

. PWSs review the information posted by the laboratory and submit the approved data to the s tate and EPA, via theDraft ICR for UCMR 4 Proposed Rule November 201 5

5 electronic reporting system

. The data collected th rough the UCMR pro gram are stored in the NCOD to facilitate analysis and review of contaminant occurrence

.

The primary user of the information collected under this ICR is EPA's Office of Water (OW)

. Other users of this information could include the following:

• Primacy ag encies, which include s tate regulators, Indian t ribes, and, in some instances, EPA r egional administrators

.

• PWS managers

.

• Staff from other EPA programs (such as the Office of Superfund Remediation and Technology Innovation ; the Office of Resource Conservation and Recovery; the Office of Enforcement and Compliance Assurance ; the Office of Pesticide Programs; and the Office of Research and Development )

.

• 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 F orces

.

• 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 Administr ation (SBA)

.

• Other environmental and industry groups

.

• News organizations

.

• Private industries

.

• Individuals

.Draft ICR for UCMR 4 Proposed Rule November 201 5

6 

### 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

. Under the 1996 amendments to SDWA, Congress established a step wise risk

- based approach for determining which contaminants would become subjec t to drinking water standards. The first step is the requir ement for EPA to publish, every
five years, a list of contaminants that are not yet regulated but which are known or anticipated to
occur in PWSs ; this is the Contaminant Candidate List ( CCL )

. The second step is the requirement for EPA t o monitor , every five years, up to 30 unregulated contaminants to determine their occurrence in drinking water systems; this is the UCMR program. The third step

i s the requirement for EPA to determine, every five years, whether or not at least five
contami nants from the CCL warrant regulation, based, in part, on the UCMR occurrence information; these are known as Regulatory Determinations. Finally, SDWA requires EPA to
issue national primary drinking water regulations (NPDWRs) for contaminants the Agency ha s determined should be regulated.

This statutory approach makes clear that Congress designed the CCL and UCMR as complementary programs

. The C CL process identifi es contaminants that may require regulation, while UCMR helps provide the data necessary for the Regulatory Determination process to
determine if a contaminant occurs with a frequency and at levels of public health concern so that there is a meaningful opportunity for health risk reduction

. Th e data collected through UCMR
are stored in the NCOD to facilitate analysis and review of contaminant occurrence and support the Administrator's determination on whether to regulate a contaminant in the interest of protecting public health, as required under SDWA section 1412 (b)(1).

3(b) Public Notice Requi red 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 approaches for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for

UCMR 4 , which includes this ICR, under Docket ID No. EPA

- HQ

- OW

- 20 15

- 0 218

. The public can submit any comments related to the ICR for this proposed action to EPA and the Office of Management and Budget (OMB).Draft ICR for UCMR 4 Proposed Rule November 201 5

7 3(c) Consultations

EPA's Office of Ground Water and Drinking Water (OGWDW) incorporated early stakeholder
involvement i n 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, s tates, industry,

a nd other organizations. S eventeen meetings were held concerning UCMR program development. A description of public involvement activities related to UCMR are provided in the September 17, 1999, UCMR Final Rule at 64 FR 50556. S takeholder meeting feedback an d public comment input were considered for both UCMR 2 and UCMR 3

.

Specific to the development of UCMR 4 , EPA held two public stakeholder meetings

. EPA held
the first meeting

, focused on drinking water methods for CCL contaminants

, on May 15, 2013, in Cincinnati, Ohio. Participants included representatives of state agencies, laboratories, PWSs, environmental organizations and drinking water associations. Meeting topics included an overview of the regulatory process (CCL, UCMR and Re gulatory Determination) and drinking water methods under development, primarily for CCL contaminants

. EPA held a second stakeholder meeting on June 25, 2014, in Washington, DC. Attendees representing state agencies, laboratories, PWSs, tribes, environmenta l organizations and drinking water associations participated in the meeting via webinar and in person. Meeting topics included the
status of UCMR 3

, UCMR 4 potential sampling design changes relative to UCMR 3 ; UCMR 4 candidate analytes and rationale ; and t he laboratory approval process

.

EPA will hold a third public stakeholder meeting (via webinar) after publication of the proposed
rule . Topics will include the proposed UCMR 4 monitoring requirements, analyte selection and rationale, analytical methods, th e laboratory approval process

, and GW representative monitoring plans

.

3(d) Effects of Less Frequent Collection

EPA considered a wide range of alternatives for frequency of collection that c ould still allow the

A gency to meet its statutory requirements and overall objectives

. Less frequent data collection would affect the integrity of the data and result in insufficient data to fulfill the needs envisioned by the 1996 SDWA Amendments, including the continued developmen t of the CCL, support of the Administrator's regulatory determinations and drinking water regulation development

.

Monitoring frequencies are determined based on statutory requirements, which specify that monitoring be varied based on the number of people served by a PWS , contaminants likely to be
found and source of water supply

. The monitoring frequ ency design also considers that the number of people served affects exposure to contaminants and considers resources available to undertake monitoring activit y

. The collection frequencies in this rule are discussed further inDraft ICR for UCMR 4 Proposed Rule November 201 5

8 section 5 (b), p art A of this ICR document

. Monitoring frequencies have been carefully devised based on the following factors:

• D ata quality needed for a representative sample;

• P recision and accuracy needed from the representative sample;

• N umber of people served by the PWS ;

• S ource of the supply ( e.g. , SW or GW );

• L ikelihood of finding contaminants; and

• T emporal variability in occurrence.

The general timing of monitoring and the number of PWSs required to monitor for each component of the UCMR can be found in section 1(b) Part A of this ICR document. More detailed information on monitoring schedules can be found in section 5(d) Part A of th is ICR
document.

EPA used the statistical design establi shed under UCMR 1 for its UCMR 4 national
representa tive sample of small PWS s (800 PWSs for cyanotoxins, and 800 different PWSs for 20
additional List 1 chemicals ) and census of large PWS s for Asses sment Monitoring

. EPA
determined that the combination of a nationally repres entative sample of small PWS s and a census of large PWS s 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 PWS s p rovide s a confidence level of 99% with an allowable error
of ±1 %

. The set of representative PWS s are distributed among different siz e categories, but weighted by population served, to ensure that the sample can provide estimates of exposure.

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 PWS s monitored) were also considered, but rejected

. Some population surveys with continuous variables use a lower level of confidence (95 % ) and/or a larger allowable error

. T he larger possible error is not acceptable for this program

. Examination and analysis of current occurrence data show that many contaminants that are currently regulated, or being consi dered for regulation occur in a fraction of PWSs on a national basis

. For many contaminants, low occurrence nationally can correspond to a substantially larger occurrence regionally

. E ven a small percentage of PWS s with detections can translate into a significant population affected

. With a greater margin of error, and the r esultant smaller sample size, such occurrence could be missed entirely

. EPA ma d e some judgments about the occurrence of contaminants in relation to
source waters and different PWS size categories

. Many statutes and current regulations differentiate impleme ntation requirements based on PWS size or water source

. While combining sampling results from the representative sample of small PWS s with that from all large PWS s provides increased statistical power in the total sample, EPA must be able to evaluate

occur rence, and possible regulatory options, related to the small PWS s

. SDWA and many current
rules focus on burden reduction for small PWS s when feasible

. T here are many otherDraft ICR for UCMR 4 Proposed Rule November 201 5

9 uncertainties and sources of variance in such a sample program

. For example, all con taminants have censored distributions ( i.e.

, “ less than detection level ” analytical results) and there are a myriad of factors that affect variability and vulnerability of GW PWS s

. It remains unclear how normal sampling theory accommodates these factors

. T he high confidence level, low allowable error, and larger sample size help s to ensure adequate data to meet the objectives of the UCMR

program

.

UCMR includes a provision for waivers for large PWSs on a s tate

- wide, chemical

- specific basis
because some con taminants may not occur in a particular state

. W aivers were not considered for
small PWSs because eliminating them from the nationally representative sample would compromise the data quality and consistency requirements of a representative sample

. The

repr esentative sample must provide adequate information on the presence and absence of
contaminants for the PWS s sampled

. S ince EPA pay s for this testing, there is no significant
burden on small PWSs

.

3(e) General Guidelines

This ICR was completed in accor dance with the November 200 9 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 took an approach that minimizes burden on the r espondents

. T his collection complies with
all OMB guidelines for information collection activities

. Specifically, the respondents are not required to:

• Prepare a written response to a collection of information in fewer than 30 days after receipt of a req uest.

• 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 pr oduce 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 securityDraft ICR for UCMR 4 Proposed Rule November 201 5

10 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
outlin ed in this ICR.Draft ICR for UCMR 4 Proposed Rule November 2015

11 

### 4 RESPONDENTS AND THE INFORMATION

4(a) Respondents and North American Industry Classification System ( NAICS )/ Standard Industrial Classification ( SIC ) Codes

Data associated with this ICR would be collected and maintained by PWSs . S tates , t erritories,
and t ribes with primacy to administer the regulatory program for PWSs unde r SDWA would participate in UCMR 4 implementation through a PA with EPA

. These primacy agencies would
sometimes collect samples and maintain records. The North American Industry Classification System (NAICS) code for privately -owned PWSs is 22131 0. The NAICS code for municipal PWS operators and s tate agencies that include drinking water programs is 924110 (Administration of Air and Water Resources and S olid Waste Management Programs)

.

4(b) Information Requested

This ICR summarizes the data items and respondent activities associated with UCMR 4.

4(b)(i) Data Items , including recordkeeping requirements

A discussion of data and other information that are part of the reporting and record keeping requirements for PWS s is found in section 4(b)(i)(a), Part A of this ICR document. The requirements for s tates are discussed in section 4(b)(i)(b), Part A of this ICR document.

4(b)(i)(a) PWS Reporting and Record Keeping

40 Code of Federal Regulations ( CF R) 141.35 requires PWSs that are subject to the UCMR requirements to report monitoring results for the 30 contaminants listed in 40 CFR 141.40 to EPA (see Exhibit 1 for the contaminant list)

.

Exhibit 1 : Proposed UCMR 4 List 1 Analytes

Nine Cyanotoxins

.
anatoxin

- a microcystin

- LY

cylindrospermopsin microcystin

- RR

microcystin

- LA microcystin

- YR

microcystin

- LF nodularin

microcystin

- LR

.Draft ICR for UCMR 4 Proposed Rule November 2015

12 One Cyanotoxin Group

.

t otal microcystin s

.

Two Metals

.

g ermanium manganese

Nine Pesticides

. alpha

- hexachlorocyclohexane profenofos

chlorpyrifos tebuconazole

d imethipin total permethrin (cis
- & trans -)

e thoprop tribufos

o xyfluorfen

.

Three Brominated Haloacetic Acid ( HAA ) Groups

.

HAA5 HAA9

HAA6Br

.

Three Alcohols

.
1

- butanol 2

- propen

- 1

- ol

2- methoxyethanol

.

Three Semivolatile Organic Chemicals (SVOCs)

. butylated hydroxyanisole quinoline

o

- toluidine

.

T he required data elements are listed in Exhibit 2

. All PWS s must electronically report all 26
data elements with their Assessment Monitoring samples

. All PWS s participating in UCMR monitoring must inform EPA of any changes to data elements 1 through 9 , if applicable

.Draft ICR for UCMR 4 Proposed Rule November 2015

13 Exhibit 2: UCMR 4 Proposed Reporting Requirements

1. P ublic Water System Identification (PWSID) Code 14 . Sample Identification Code

2

. PWS Name 15

. C ontaminant

3

. PWS Facility Identification Code 16

. A nalytical Method Code

4

. PWS Facility Name 17. E xtraction Batch Identification Code

5

. PWS Facility Type 18. E xtraction Date

6. W ater Source Type 19. A nalysis Batch ID

7. S ampling Point Identification Code 20. A nalysis Date

8. S ampling Point Name 21. S ample Analysis Type

9. S ampling Point Type Code 22. A nalytical Results

– Sign

10

. D isinfectant Type (primary disinfectants) 23. A nalytical Result

– Measured Value

11.Treatment Information (includes basic treatment information) 24. A dditional Value

12. D isinfectant Residual Type (secondary disinfectant residual type added in distribution system) 25. L aboratory Identification Code

13. S am ple Collection Date 2 6. S ample Event Code

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

UC MR 4 is a direct implementation rule ; therefore s tates would not be required to report to EPA. Implementation activities for each s tate would be identified and determined through PAs with

EPA

. If participating in a PA, state s would voluntarily review and revis e Initial Sta te Monitoring Plans ( SMPs ), notify PWSs of their UCMR responsibilities, and provide EPA with a list of the

PWS s notified

. These s tate activities would be completed in 2017. Because state s have no specified reporting cycle, this analysis assumes that state s have 1.0 response per year during the ICR years , encompassing all communication and coordination activities with EPA and PWSs

.

4 (b)(ii) Respondent Activities

R espondents include both PWSs and s tates

. PWS and s tate activities are discussed in sections 4(b)(ii)(a) and 4(b)(ii)(b), respectively (Part A of this ICR document).

4 (b)(ii)(a) PWS Activities

T o comply with the requirements in this regulation, PWSs would conduct the following
activities:

• Read regulations and/or letter from s tate or EPA whic h outline requirements; • Monitor or provide monitoring assistance ( e.g. , sample collection and shipping);Draft ICR for UCMR 4 Proposed Rule November 201 5

14 • R eport and maintain records; and

• R eport monitoring results to the public.

Each of these activities is discussed in more detail below

. Read Regulations/State Letter : All PWSs participating in UCMR monitoring read the UCMR regulations and/or a s tate

- issued guidance letter during the year in which their monitoring occur s

. Small PWSs can rely on summarized information from the s tate or EPA for in formation pertaining to the regulation, rather than reading the regulation , because of the more limited scope of their responsibilities

.

Monitoring or Monitoring Assistance : Monitoring activities that are considered in the PWS cost and burden estimates include receiving sampling kits from the laboratory, reading sampling instructions, traveling to the sampling location and collecting and shipping the sample

.

As noted earlier, cyanotoxin monitoring would occur twice a month fo r four consecutive months (a total of eight sampling events) for SW and GWUDI systems. For the 20 additional List 1 chemicals, SW and GWUDI systems will sample every two months (four sampling events), and GW systems will sample twice (at 6

- month intervals) . All monitoring will take place during a
continuous 12

- month period (excluding December through February

, except for resampling), during the sampling time frame.

Sample collection for the UCMR 4 contaminants would take place at the e ntry p oint to the
d i stribution s ystem ( EPTDS ) , with the following exceptions/additions. Sampling for “total microcystins

, ” would also take place at the source water intake (concurrent with the collection of cyanotoxin samples at the EPTDS) unless the PWS purchases 100 percent of their water; “consecutive systems” would only sample for cyanotoxins at their EPTDS. Measurements for temperature and pH would take place at the source water intake (concurrent with total microcystin sampling). HAA sampling would take place in the distribution system. Sampling for Total Organic Carbon ( TOC ) and bromide would take place at a source wat er intake (concurrent with HAA sampling in the distribution system).

Large GW PWS s with multiple EPTDSs would only be required to sample at representative sampling locations for each GW source, as long as those sites have been approved by EPA or the

stat e

.

Reporting and Record Keeping : Activities related to these reporting requirements include :

• Reporting Prior to Monitoring

Contact and zip code information : L arge PWS s w ould be required to report
contact information to EPA

. This information include s the name, affiliation, mailing address, phone number and email address for the PWS Technical ContactDraft ICR for UCMR 4 Proposed Rule November 2015

15 and PWS Official ( i.e. , the official spokesperson for a PWS’ s UCMR activities)

. Information would be submitted to EPA ’ s electronic data reporting system within a specified time frame after rule promulgation

. Small PWSs would provide this
information in response to a specific written request that they receive from EPA

. As a one-time reporting requirement under UCMR 4 , PWSs would be required to
report the U.S. Postal Service Zip Code(s ) for all areas being served water by the

PWS.

Sam pling location and inventory information : PWSs would be required to provide sampling location (s) and to associate each source water location with its entry point location(s) prior to sampling. For each sampling location or each approved representative sampling location, PWSs would be required to submit : PWSID Code; PWS N ame ; PWS F acility I dentification Code; PWS F aci lity N ame; PWS Facility Type, Water Source Type; Sampling Point Identification Code; Sampling
Point Name ; and Sampling Point Type Code.

R epresentative sampling plan proposal : Some PWS s that use GW as a source and have multiple EPTDSs can monitor at representative sampling location (s), rather
than at each EPTDS . To qualify, these GW PWS s 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)

. PWSs meeting these criteria would be allowed

to submit a proposal to EPA or the state (if such a proposal has not been previously approved) . The proposal must demonstrate that any EPTDS selected as representative of the GW supplied from multiple wells was 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 produci ng 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.

R epresentative Intakes from Wholesaler: PWSs that purchase wa ter with multiple connections from the same wholesaler would be permitted to monitor from one representative connection from that wholesaler. PWSs would choose a sampling location from among the higher annual volume EPTDS connections. If the
connection sel ected as the representative EPTDS is not available for sampling, an alternate representative connection would be sampled.

• R eporting Monitoring Results

Sm all PWSs : S mall PWSs would only be required to record PWS and sample location information on the sampling forms and bottles that are sent to them byDraft ICR for UCMR 4 Proposed Rule November 2015

16 the UCMR Sampling Coordinator. The schedule for submitting this information is

sp ecified in the instructions sent to the PWS

.

L arge PWSs : Laboratories would post the analytical results and associated data elements to EPA’s electronic data reporting system within 120 days of sample
collection . L arge PWSs must ensure that their laboratory meets this requirement,
and those PWS s must review, approve, and submit the dat a to the s tate and EPA via the electronic reporting system within 60 days from when the laboratory posts
the data

. After 60 days from the laboratory's posting, if the PWS has not taken action, the data are considered approved and final for EPA review.

• R ecord Keeping

S ection 141.33 requires PWSs to maintain records of chemical monitoring data for 10 years

. No changes were made to those record keeping requirements.

R eporting 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 PWS

. Community water systems ( CWSs ) are required to notify their users of the detection of any contaminants (including unregulated contaminants) in their Consumer Confidence Reports (CCRs), pursuant to §141.153(d)(3)(iv), published in 63 FR 44512, August 19, 1998. Monitoring and reporting
violations for all PWS s ( CWSs , non-transient non- community water systems ( NTNCWSs ) and
transie nt non- community water systems ( TNCWSs )), are reportable under the Public Notification Rule ( 65 FR 25982, May 4, 2000). No changes were made to these reporting requirements

.

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

Fo r 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 Association of State Drinking Water Administrators ( A SDWA ) 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 PWSs affected, estimates of violation rates, etc.)

. Since that time, ASDWA update d and improved the

prev ious version of the resource model. EPA used the updated resource model as documented in : “Insufficient Resources for State Drinking Water Programs Threaten Public Health : an Analysis of State Drinking Water Programs’ Resources and Needs” ( December 201 3)

, to estimate
resources that states may need for the oversight and implementation of UCMR 4. Assumptions that were applied in using this resource assessment tool are described in section 6(b), Part A of
this ICR document. EPA assume d that s tate participation would closely reflect that whichDraft ICR for UCMR 4 Proposed Rule November 2015

17 occurred during UCMR 3. Therefore, model estimates were adjusted to account for actual levels of prior s tate participation

.

S ince UCMR is a direct implementation rule, specifics of each s tate ’ s role wou ld be delineated in
PAs between the s tates and EPA

. State activities include coordination, data management and support, program implementation and training/overhead. Though some s tates may choose to conduct sampling for their PWSs

, this activity is not par t of the PA agreement and is optional. Burden for sampling is currently attributed to PWSs

. If states choose to conduct monitoring for

PWSs , burden would be similar to that estimated for PWSs and would not impact the overall
burden estimate.

St ate Coordin ation with EPA : State activities that involve coordination with EPA include coordination and development of a PA , review of and response to EPA’s proposed SMP , review of PWS proposals for representative GW sampling locations, and general ongoing coordination.

R eview of SMPs would be one of the first UCMR activities to take place at the s tate level

. Each

s tate would receive a proposed initial SMP from EPA

, which list s all PWS s that would be required to conduct Assessment Moni toring, including small PWSs that were statistically selected as a sample, and all large PWSs subject to the rule by meeting applicability criteria

. For
PWSs that are part of the sample, EPA would also generate a list to provide similar replacement

PWSs for s tates to select from, for those PWSs that may not have been correctly specified in the initial plan

. If a s tate identifie s PWSs on the original proposed SMP that it determin es are not appropriate for the representative GW sampl ing locations ( e.g. , if PWSs are inactive, or sell all
of their water and do not have their own retail customers), the s tate could propose an alternative plan by s electing other PWSs from EPA’ s alternate list to replace the ineligible PWSs

. The

SMPs would also specif y the year an d months during which PWSs would monitor. States would
be given the option to modify these schedules.

E PA assumed that s ome PWSs that use GW as a source of water would submit a proposal for monitoring at representative sample location (s), rather than monitoring at every EPTDS

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

E PA also recognize d that it would be necessary for states to maintain ongoing communications with EPA regarding UCMR requirements

. For example , s tates could need clarification and guidance on a specific requirement of the regulation

. These ongoing communication activities
are included in estimated burdens across the entire UCMR 4 period of 2017-2021.

D ata Management and Support : Though t here are no state data management and support activities included in UCMR, EPA recognizes that many s tates update their databases to
accommodate the revised UCMR data elements

. Activities likely include data entry/downloading of data and general record keeping.Draft ICR for UCMR 4 Proposed Rule November 2015

18 Program Implementation : Program implementation activities for each s tate can include notification and guidance letter to PWSs , data review, ongoing PWS support and enforcement. Following review and finalization of SMP s, participating s tates would prepare a notification
letter that describe d PWS monitoring schedules and requirements under the regulation. These

s tates would sen d notification to each applicable PWS and sen d the list of these notified PWSs to
EPA

. EPA assumed that PWSs would periodical ly call s tates asking for clarification and guidance about UCMR requirements

. States can elect to review monitoring results, in part, to
determine whether a PWS has met its monitoring and reporting requirements.

St ate Staff Training and Overhead : EPA assu med that t echnical staff members would participate in training to assist them in understanding the regulation, their roles and responsibilities, and to
allow the s tate to better provide technical assistance to PWSs . G eneral overhead costs, such as
clerical and managerial needs, are allocated to the UCMR staff requirements in ASDWA’s estimates of state resource needs, 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 4 Proposed Rule November 2015

19 

### 5 INFORMATION COLLECTED

– AGENCY ACTIVITIES,
COLLEC TION METHODOLOGY AND INFORMATION
MANAGEMENT

5( a) Agency Activities

E PA Headquarters and r egional offices are responsible for oversight of s tate PWS programs and processing and analysis of UCMR data. EPA implementation activities are categorized into three major categories : regulatory support activities; program oversight and data analysis; and small

PWS testing prog ram, which are described in 5(a)(i)

- (iii).

5( a)(i) Regulato ry Support Activities

R egulatory support activities include : laboratory approval and quality assurance/quality control (QA/QC) ; and technical support to PWSs, such as guidance documents.

L aboratory Approval and QA/QC Activities : EPA incurs various cost s related to laboratory approval and laboratory quality assurance and control, including the following activities:

• L aboratory approval/Proficiency Testing (PT) program
- EPA would assess whether laboratories me et the required equipment, laboratory perfo rmance and data reporting criteria

. EPA would register and evaluate laboratories based on the applications. Selected laboratories would then participate in the UCMR 4 PT

program. EPA expects to conduct these laboratory assessments during 2017.

• QC audits of contract laboratories - EPA conducts Quality Control ( QC ) audits at each of the approved laboratories not more than annually during each UCMR 4 monitoring year ( January 2017 through December 2019).

• A nalytical standards provision and coordination - EPA coordinates and
distribute s specialized analytical standards to participating laboratories.

T

echnical Support/Guidance Document Development : EPA expects to develop and distribute guidance for laboratory calculations and background information abo ut the health effects ( e.g. , fact sheets) of UCMR 4 contaminants. EPA expects to provide technical support during 2018
and 2019.Draft ICR for UCMR 4 Proposed Rule November 2015

20 5(a)(ii) National and Regional Oversight/Data Analysis

EP A ’s UCMR program activities include data analysis, management oversight and implementation assistance to s tates

. These are key management and oversight activities that must be conducted by EPA Headquarters or its r egional offices . Exhibit 3 illustrates the proposed timeline for UCMR implementation activities

. EPA expects to develop its PAs with s tates and
the SMP s prior to 2018 , when monitoring would beg in.

E xhibit 3: Proposed Timeline of UCMR 4 Activities

2017 2018 2019 2020 2021
After proposed rule publication: EPA lab approval program begins
After final rule publication: EPA/state primacy authorities (1) develop SMPs (including the nationally representative sample); and (2)
inform PWSs/
establish monitoring plans .

Assessment Monitoring

List 1 Contaminants

A ll large systems serving more than 10,000 people ;

800 s mall systems serving 10,000 or fewer people for cyanotoxins;
800 small systems serving 10,000 or fewer people for the 20
additional chemicals. . Complete reporting and analysis of data

5( a)(iii) Costs for Small System Testing Program
Implementation of the small PWS testing program is the largest portion of A gency costs for the UCMR program. Prior to monitoring, EPA activities for logistical support of the small PWS testing program would include coordination of small PWS testing and provision of testing supplies.

D uring the ICR period, EPA would pay for the sample kit preparation, sample shipping fees and analysis costs.

5 (b) Information Collection Methodology and Management

L ab oratories report analytical results and associated data elements to EPA’s electronic data reporting system . L arge PWS s are expected to ensure that their laboratory posts the data in

EPA ’ s electronic data reporting system ; the PWS then has the opportunity to review, approve,Draft ICR for UCMR 4 Proposed Rule November 2015

21 and submit the data to the state and EPA via the EPA electronic reporting system . As proposed,

l aboratories have 120 days from sample collection to report analytical results and required data
elements

. PWS s have 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 would be considered approved and
final for EPA review . Electronic reporting provides significant collection efficiencies, and
reduce s the possibility of data input error. This approach has worked well in prior UCMRs.

The UCMR data are maintained and analyzed through NCOD. The data collected under UCMR

are used to support regulation development, to analyze the significance of occurrence and health effects, and to support the critical Agency function of program oversight. The public receives information regarding UCMR monitoring results through the CCRs, and will be able to access data through the NCOD. PWSs that fail to monitor for unregulated contaminants must notify the public of their failure to monitor.

EPA conducts ongoing data analysis

, which includ es checks for anomalies in the data that may be related to data entry or laboratory errors

. Data quality review and ana lysis 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 rule. The Regulatory Flexibility Act (RFA) analysis is based on the entire five

- year UCMR implementation period of 2017-2021 , rather than the three

- year ICR period of 2017-2019.

I certi fy that this action will not have a significant economic impact on a substantial number of small entities under the RFA. In making this determination, the impact of concern is any significant adverse economic impact on small entities. An agency may certify that a rule will not have a significant economic impact on a substantial number of small entities if the rule relieves regulatory burden, has no net burden or otherwise has a positive economic effect on the small entities subject to the rule.

For purposes of assessing the impacts of this 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 FR, (63 FR 7606, February 13, 1998), requested public comment, consulted with the Small Business Administration, and finalized the alternative definition in the Cons umer Confidence Reports rulemaking, (63 FR 44512, August 19, 1998). As stated in that Final Rule, the alternative definition would be applied to future drinking water rules, including this rule.Draft ICR for UCMR 4 Proposed Rule November 2015

22 The evaluation of the overall impact on small systems, summ arized in the preceding discussion,is further described as follows. EPA analyzed the impacts for privately-owned and publiclyowned water systems separately, due to the different economic characteristics of these ownership types, such as different rate st ructures and profit goals. However, for both publicly- and privately

- owned systems, EPA used the "revenue test," which compares annual system costs attributed to the rule to the system's annual revenues. EPA used median revenue data from the

2006 CWS Surve y for public and private water systems. The revenue figures were updated to 2014 dollars, and to account for three percent inflation. EPA assumes that the distribution of the sample of participating small systems will reflect the proportions of publicly - and privatelyowned 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 4

System Size (# of people served) Publicly

- Owned Privately

- Owned Total 1

Ground Water

500 and under 21 64 85

501 to 3,300 16 1 6 2 223

3,301 to 10,000 179 41 220

Subtotal GW 361 167 528

Surface Water (and GWUDI)

500 and under 18 21 39

501 to 3,300 241 86 327

3,301 to 10,000 548 158 706

Subtotal SW 807 265 1,072

Total of Small Water Systems 1,168 432 1,600

1 PWS counts were adjusted to display whole numbers in each size category.

The basi s for the proposed UCMR 4 RFA certification is as follows: for the 1,600 small water systems that would be affected, the average annual cost for complying with this rule represent no
more than 0.8 % of system revenues (the highest estimated percentage is for GW systems serving 500 or fewer people, at 0.8% 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 UCMR 4.Draft ICR for UCMR 4 Proposed Rule November 2015

23 Ex hibit 5 : Implementation of UCMR 4 at Small Systems

Cost Description 2017 2018 2019 2020 2021 Total 1

Costs to EPA for Small System Program (Assessment Monitoring)

$0 $5,971,948 $5,971,948 $5,971,948 $0 $17,915,845

Costs to Small Systems (Assessment Monitoring)

$0 $273,210 $273,210 $273,210 $0 $819,630

Total Costs to EPA and Small Systems for UCMR 4

$0 $6,245,159 $6,245,159 $6,245,159 $0 $18,735,476

System Monitoring Activity Timeline 2

Assessment Monitoring: Cyanotoxins 1/3 PWSs Sample 1/3 PWSs Sample 1/3 PWSs Sample 800

Assessment Monitoring: 20
Additional
Chemicals 1/3 PWSs Sample 1/3 PWSs Sample 1/3 PWSs Sample

800

1 Totals may not equal the sum of components due to rounding.

2 Total number of systems is 1,600. No small system conducts Assessment Monitoring for both cyanotoxins and the 20 additional
chemicals.

PW S costs are attributed to the labor required for reading about UCMR 4 requirements,monitoring, reporting, and record keeping. The estimated average annual burden across the fiveyear UCMR 4 implementation period of 2017-2021 is estimated to be 2.8 hours at $103 per small system. Average annual cost, in all cases, is no more than 0.8% of system revenues. By assuming all costs for laboratory analyses, shipping, and QC for small entities, EPA incurs the entirety of the non- labor costs associated with UCMR 4 small system monitoring, or 9 6 % 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 4 Proposed Rule November 2015

24 Exhibit 6 : UCMR 4 Relative Cost Analysis for Small Publicly

- Owned Systems (201 7-2021)

System Size (# of people

served) An nual Number of Systems Impacted 1 Average Annual Hours per System (2017-
20 21 ) Average Annual Cost per System (2017-2021) Revenue Test 2

Ground Water Systems

500 and under 4 1.6 $59 0.16%

501 to 3,300 32 1.7 $6 3 0.04%

3,301 to 10,000 36 1.9 $6 7 0.01%

Surface Water (and GWUDI) Systems

500 and under 4 3.3 $118 0.17%

501 to 3,300 48 3.3 $118 0.04%

3,301 to 10,000 109 3. 4 $123 0.01%

1 PWS counts were adjusted to display as whole numbers in each size category

. 2 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.

Exhibit 7 : UCMR 4 Relative Cost Analysis for Small P rivately

- Owned Systems (201 7-2021)

System Size (# of people

served) Annual Number of Systems Impacted 1 Average Annual Hours per System (2017-
20 21 ) Average Annual Cost per System (2017-2021) Revenue Test 2

Ground Water Systems

500 and under 13 1.6 $59 0.81%

501 to 3,300 12 1.7 $6 3 0.05%

3,301 to 10,000 8 1.9 $6 7 0.01%

Surface Water (and GWUDI) Systems

500 and under 4 3.3 $118 0.29%

501 to 3,300 17 3.3 $118 0.04%

3,301 to 10,000 32 3.4 $123 0.01%

1 PWS counts were adjusted to display as whole numbers in each size category.

.Draft ICR for UCMR 4 Proposed Rule November 2015

25 2 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.

T he Agency has determined that 1,600 small PWSs (for Assessment Monitoring), or approximately 4.2% of small systems, would experience an impact of less than 0.8% of revenues; the remainder of small systems would not be impacted.

A lthough this proposed rule will not have a significant economic impact on a substantial number of small entities, EPA has attempted to reduce the impact of this rule on them. EPA will assume all costs for analyses of the samples and for shipping the samples from small systems to laboratories contracted by EPA to analyze UCMR 4 samples (the cost of shipping is now included in the cost of each analytical method). EPA has set aside $2.0 million each year from

the Drinking Water 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.

W e have therefore concluded that this action will have no significant net regulatory burden for all directly regulated small entities. 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.

5(d) Collection Schedule

P ublic w ater systems would be required to collect samples during a continuous 12-month period (excluding December through February) during the sampling time frame . With the exception of cyanotoxin monitoring, sampling would take place every two months, for SW and GWUDI
systems (a total of four sampling events), and at 6-month intervals for GW system s (a total of two sampling events). For cyanotoxin monitoring, SW and GWUDI systems would collect samples twice a month for four consecutive months (total of eight sampling events). GW systems would be excluded from cyanotoxin monitoring.

T he Assessment Monitoring sampling time frame would take place during the compressed period of March through November to better characterize occurrence in drinking water; EPA anticipates that sampling in the December through February period would not accurately reflect occurrence for some of the contaminants, particularly pesticides and cyanotoxins. Therefore, no sampling will take place during th e months of December, January or February, except for resampling

purposes.

S ample collection for the UCMR 4 contaminants would take place at the EPTDS , with the following exceptions/additions. EPA is proposing a phased sample-analysis approach for microcystins to reduce analytical costs (i.e., PWSs must collect all required samples for each sampling event but not all samples may need to be analyzed). Initially, source water intakeDraft ICR for UCMR 4 Proposed Rule November 2015

26 samples (colle cted by “non -consecutive” SW and GWUDI PWSs) would be analyzed for total microcystins with an ADDA

- based (( 2S, 3S, 8S, 9S, 4E, 6E )-3- amino -9-methoxy-2,6,8- trimethyl -10- phenyl -4, 6- decadienoic acid ) Enzyme

- linked Immunosorbent Assay ( ELISA ) methodology. If the source water intake ELISA result is less than 0.3 m icrogram s per liter (μg/L) (i.e., the reporting limit for total microcystins), then the other collected samples (from the EPTDS) would not be analyzed for that sample event and only that source water result would be reported to EPA. If the ELISA result from the source water intake is greater than or equal to 0.3 μg/L, that result would be reported to EPA and the sample from the EPTDS would then also be analyzed for total microcystins by ELISA. (ELISA analysis of the EPTDS sample would be the first step for consecutive systems.) If the EPTDS ELISA result is less than 0.3 μg/L, then no additional analyses would be needed for that particular sample event and that result would be reported to EPA. If the EPTDS ELISA result is greater than or equal to 0.3 μg/L, then that result would be reported to EPA and the other microcystin sample collected at the EPTDS would be analyzed using EPA Method 544, to identify particular microcystin congeners. Measurements for temperature and pH would take place at the source water intake (concurrent wi th total microcystin sampling).

T his phased sample- analysis approach for microcystins has the potential to achieve significant cost savings. A similar approach is not feasible for cylindrospermopsin and anatoxin- a samples. Therefore, EPA proposes that cylindrospermopsin and anatoxin-a sampling be conducted simultaneously with the microcystins, twice a month for four consecutive months only at the EPTDS, and that the samples be analyzed using EPA Method 545.

H AA sampling would take place in the distribution system. Sampling for TOC and bromide would take place at a single source water intake (concurrent with HAA sampling in the distribution system). The TOC and bromide data, along with the disinfectant type and water treatment information, would aid in the understanding of brominated HAA formation.

E PA proposes that PWSs monitor for HAAs only in the distribution system. If the system's treatment plant/water source is subject to sam pling requirements under 40 CFR 141.622 (monitoring requirements for Stage 2 DBPR), the water systems must collect samples for the HAAs at the sampling locations identified for that rule ( 71 FR 388, January 4, 2006 ). If a treatment plant/water source is not subject to Stage 2 DBPR monitoring, then the water system must collect HAA distribution system samples at a location that represents the distribution system maximum residence time ( DSMRT ). UCMR 4 HAA samples and HAA Stage 2 DBPR compliance monitoring sam ples may be collected by the PWS at the same time. However in such cases, PWSs would need to arrange for UCMR 4 HAA samples to be analyzed by an approved lab using EPA Method 552.3; this is one of multiple method options for analysis of Stage 2 DBPR sample s.

F or purposes of total-microcystin sampling, temperature and pH measurement, and TOC and bromide sampling, EPA defines source water under UCMR as untreated water entering the waterDraft ICR for UCMR 4 Proposed Rule November 2015

27 treatment plant (i.e., a location prior to any treatment). Systems that are subject to Long Term 2 Enhanced Surface Water Treatment Rule (LT2) should use their source water sampling site(s) (71 FR 654, January 5, 2006 ). Systems subject to Stage 1 Disinfectants and Disinfection Byproducts Rule (DBPR) should use their TOC source water sampling site(s) ( 66 FR 3770, January 16, 2001 ). TOC source water sampling site(s) were set under Stage 1 DBPR and remain unchanged under Stage 2 DBPR. If a system has two different source water sampling locations for LT2 and Stage 1 DBPR, the system should select the sample point that best represents the
definition of source wate r sample location(s) for UCMR.

W ith the exception of the increased sample frequency, phased sample-analysis for microcystins, revised sampling locations, and the compressed monitoring schedule , the approach to UCMR 4 Assessment Monitoring remains consistent with that for UCMR 3.

La rge system schedules (year and months of monitoring) would initially be determined by EPA in conjunction with the s tates ; these PWSs would have an opportunity to modify this schedule for planning purposes or other reasons (e.g., to conduct monitoring during the months the system or the state believes the PWS is most vulnerable, because of budget constraints, if a sampling
location will be closed d uring the scheduled month of monitoring, etc.). EPA proposes to schedule and coordinate small system monitoring, working closely with partnering s tates. SMPs provide an opportunity for s tates to review and revise the initial sampling schedules that EPA

pro poses.

U CMR activities that occur after 2019 are not included in the body of this ICR analysis

. Appendix B contains estimations for the five- year UCMR 4 period, 2017-2021. Exhibits 3 and 9 illustrate the timeline of general UCMR activities, and PWS monitoring activities, respectively

.Draft ICR for UCMR 4 Proposed Rule November 2015

28 

### 6 ESTIMATING THE BURDEN AND COST OF THE COLLECTION

T his section describes the respondent burden and cost for activities under UCMR 4. The burden and cost estimates for PWSs are shown in section 6(a), burden and costs to s tates are shown in section 6(b), and the A gency 's burden and cost estimates are shown in section 6(c) (all in Part A of this ICR document).

The body of this ICR focuses only on the cost of the UCMR data collection over the years 2017-
2019. Cost table s that are presented in this section have analogous tables in Appendix B, which present costs for the entire monitoring period (2017-2021).

T here 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 the fees for laboratory analytical services

.

E PA is committed to accurately characterizing the burden and costs of rules it promulgates. In the development of various drinking water program rule ICRs, EPA developed a consistent set of assumptions to use in calculations. These h ave been developed and utilized in other drinking water program evaluations . Pertinent to the UCMR ICR are the standard assumptions for labor

rates, PWS inventory numbers (the number of PWSs in the various size categories by primary water source), the numb er of sampling points for each PWS and analytical services

. The sources and assumptions used in estimating costs and burdens are described in this section

.

6( a) Estimating Burden and Cost to PWS s

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

E PA used the following sources of PWS information to develop cost and burden estimates :

• I nventory Data : CWS and NTNCWS inventory was based on a September 30

, 2014, inventory extract from SDWIS/Fed.

• EPTDS Data : All EPTDS data were taken from the Community Water System Survey Volum e II: Detailed Tables and Survey Methodology ( http://water.epa .gov/infrastructure/drinkingwater/pws/upload/cwssreportvolumeI I2006.pdf ).

• DSMRT Data : The n umber of DSMRT samples per PWS is b ased on the number of samples required to be collected for the Stage 2 DBPR. The Stage 2 DBPR andDraft ICR for UCMR 4 Proposed Rule November 2015

29 UCMR 4 PWS size categories differ for the large PWSs. Under the Stage 2 DBPR, SW or GWUDI PWSs serving more than 100,000 people, are binned into four different size categories. PWSs in these size categories collect Stage 2 DBPR samples from eight , 12, 16, or 20 locations per monitoring period. Because the

UCMR 4 has only one size category for PWSs serving more than 100,000 people,

EPA used an average number of sample locations to determine costs, and assumes
that all SW or GWUDI PWSs in this size category would c ollect samples from 14
locations. GW PWSs serving over 100,000 people collect samples from either six

or eight locations under the Stage 2 DBPR. EPA used an average of seven samples for the cost estimates for the UCMR 4, for th o se GW PWSs serving more than 100,000 people. This may overestimate the number of samples required for some PWSs, while underestimating the number of samples required for others

.

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

T he general timing of monitoring was discussed in section 1(b) of Part A of this document (Short Characterization)

. The UCMR program affect s approximately 5,892 PWS s, roughly two

- third s of which will conduct monitoring in 2018 and 2019. Exhibit 8 presents the estimated numbers of regulated PWSs expected to participate

. Exhibit 9 presents the time line in which the PWS monitoring activities take place.

W hile developing the cost estimates for UCMR 3, s ome public commenters suggested that EPA underestimated PWS burden. In response to these comments, EPA reviewed the UCMR burden estimates against burden estimates used in recently published drinking water rules . In all aspects of burden assumptions (e.g., time allotted for reading rule requirements, sampling reporting, etc.), the UCMR estimates were on par with, or more conservative (higher) than estimates made for other drinking water regulations. For UCMR 4 , EPA re

- examined all cost estimates and assumptions to ensure that the most recently available data were used. A ll PWS burden esti mates represent average burden hours, which include SW and GWUDI PWSs that may have very few sampling points, and thus lower sampling burden, as well as those PWSs with higher numbers of sampling points that would therefore have greater sampling activity labor burden. A PWS 's burden is primarily incurred during its one year of required UCMR monitoring. However, in compliance with the requirements of the Paperwork Reduction Act (44 U.S.C. 3501 et seq.), these cost and burden estimates are presented as an ave rage over the applicable three- year ICR period. Small PWSs have the lowest burden because of the smaller size of their infrastructure,
and because these PWSs receive a great deal of direct assistance from EPA and/or their s tate.Draft ICR for UCMR 4 Proposed Rule November 2015

30 Exhibit 8: Systems to Participate in UCMR 4 Monitoring

System Size (# of people

served) National Sample Assessment Monitoring Total # of Systems per Size Category

10 List 1 Cyanotoxins 20 Additional List 1
Chemicals

Small Systems 1

25

– 10,000 800 randomly selected SW or GWUDI systems 800 randomly selected SW, GWUDI and GW systems 1,600

Large Systems 2

10,001 and over All SW or GWUDI systems (1,987) All SW, GWUDI and GW systems (4,292) 4,292

TOTAL 2,787 5,092 5,892

1 Total for small systems is additive because these systems would only be selected for one component of UCMR 4 sampling (10 cyanotoxins or 20 additional chemicals)

. EPA would pay for all analytical costs associated with monitoring at small
systems.

2 Large system counts are approximate. The number of large systems is not additive. All SW and GWUDI systems would monitor for cyanotoxins; those same systems would also monitor for the 20 additional List 1 c hemicals , as would the large GW systems

.

Exhibit 9: UCM R 4 Sampling Activity Timeline for Cost and Burden Estimations

UC MR 4 – 2017 – 2021

2017 2018 2019 2020 2021

D esignated ICR Years

No UCMR Monitoring Activity Assessment Monitoring 1 No UCMR Monitoring Activity ~ 1/3 of PWS s sample ~ 1/3 of PWS s sample ~ 1/3 of PWS s sample

1 The following assumptions, based on the specifications in UCMR 4 , were used to estimate cost and burden :

• All Assessment Monitoring PWS s w ould conduct sampling evenly across March 20 18- November 2020 (i.e., one

- third
in each of the three consecutive periods)

.

• Approximately two

- thirds of PWS s would conduct monitor ing in the current ICR years of 201 8 and 201 9 , and approximately one

- third of PWS s would conduct monitoring during the ICR years of 2020 -20 22

.

T he PWS 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.

H ourly labor rates (including overhead) are taken from the Bureau of Labor Statistics (BLS)

, National Occupational Employment and Wage Estimates, United States, BLS SOC Code 51

-Draft ICR for UCMR 4 Proposed Rule November 2015

31 8031, "Local Government - Water and Liquid Waste Treatment Plant and System Operators". May 2013 data (published in April 2014). http://stats.bls.gov/oes/current/oes518031.htm. The
lo cal government Occupational Employment Statistics ( OES ) Designation of $ 22 was multiplied by a loading rate of 1.6 to account for benefits to remain consistent with the estimates used by
the renewal ICR for the drinking water regulations (in progress). The wage rate was then escalated to 2014 dollars. Thus, the hourly wage rate for all PWSs was estimated to be $36.

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

E PA assumed that PWSs read the regulati ons and/or a s tate

- is sued guidance letter during the year in which PWSs monitor. Approxim ately two

- third s of PWSs would therefore read the regulations or a state

- issued guidance letter in 2018 and 2019. Small PWSs can rely on the s tate and EPA for information pertaining to their requirements, rather than reading the regulation;
EPA assumed small PWSs would spend one hour, on average, reading the letter or guidance.

EPA assume d that PWSs serving more than 10,000 people read the regulation and information
from the state, requiring on average four hours. National costs are estimated by multiplying the average burden hours by the average PWS labor rate, times the number of PWS s affected

. Small

PWSs would only be selected to monitor for the 10 cyanotoxins or the 20 additional Assessment Monitoring chemicals . E ach small PWS selected to monitor would have one hour to read a letter or guidance document. All large and very large PWSs served by SW or GWUDI are expected to monitor for the 10 cyanotoxins. All large and very large PWSs also monitor for 20 additional Assessment Monitoring chemicals

. The large and very large PWSs may need extra time to read about and understand the cyanotoxin and HAA monitoring requirements because the requirements differ from the other Assessment Monitoring chemicals ; thus, these PWSs are allotted four hours for this purpose. This may overestimate burden for some of these PWSs, thus EPA is providing a conservative cos t estimate.

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

E xhibit 9 provides an illustration of the timeline for PWS sampling activity

. For Assessment Monitoring, EPA assume d that each PWS would incur an estimated burden of 0.5 hours per sampling point to collect sampl es for analysis . EPA assumed that PWSs would not be able to collect all samples at the same time or at the same locations. The monitoring burden includes separate sample collection burden estimates for PWSs to collect EPTDS samples and certain
distribution samples

. PWSs will also need additional time to collect cyanotoxins samples at the
EPTDS and at source water locations. EPA assumed that PWSs would collect source water TOC and bromide samples at the same time as HAA samples. Since PWSs may collect some samples at the same time, the burden estimate may overestimate the time needed for some PWSs and therefore, EPA is providing a conservative cost estimate.Draft ICR for UCMR 4 Proposed Rule November 2015

32 Th e monitoring burden for Assessment Monitoring includes receipt of monitoring kit, reading laboratory instructions, travel time to collect samples and collection and shipping of samples. It is calculated by : (hour burden per sampling point) times (number of sampling points) times (number of PWSs ) times (number of sample events per year) . T his est imate is an average. Some

PWSs need less than 0.5 hours per sampling point to collect a sample, while other PWSs need
more time. Many GW PWSs realize savings in their sampling burden as a result of the allowance for representative sample points. Thus, sampling burden accounts for the estimated reduction in entry points where these PWSs will sample (as described in section 6(a)(ii), Part A of this ICR document). Certain PWSs that purchase all of their water from a single wholesaler , and that have
more than one connection to that wholesaler , may elect to sample from only one entry point.

Because t his cost savings has not been factored into the cost estimates, the sampling costs are
conservative.

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

PW Ss would be required to report specific information prior to monitoring, and would be required to report some information with their monitoring results

.

• R eporting Prior to Monitoring: As with the reading burden (described above, in Section 6(a)(i)(a)), all initia l reporting prior to UCMR 4 monitoring (including proposals for representative EPTDSs) would be complete d in 2017.

Sm all PWSs : EPA assume d that small PWSs would send contact and sampling point information prior to monitoring. EPA estimated this one

- time reporting
burden would take PWSs two hours.

L arge SW (and GWUDI) PWSs : EPA assume d that large SW and GWUDI PWSs would send contact and sampling point information prior to monitoring. E PA allotted a one-time reporting burden of six hours.

L arge GW PWSs : EPA assume d that large GW PWSs would send contact and sampling point information, which would require a one-time burden of six hours.
An additional eight hours were allotted to some GW PWSs to account for compilation and submission of GW representative s ampling locations proposals.
Since it was unlikely that all PWSs would submit these proposals, EPA conservatively assume d that half of GW PWSs serving 10,001 to 100,000 people would compile and submit this proposal; EPA assume d that all GW PWSs serving more than 100,000 people would submit these proposals.Draft ICR for UCMR 4 Proposed Rule November 2015

33 • Reporting with Monitoring Results

Sm all PWSs : Small PWSs can review their UCMR monitoring results, but would not be required to do so. Some PWSs may not review sample results at all, whil e others may review the sample results in detail . As a conservative assumption,
EPA estimated that it would take each small PWS 0.5 hours per sampling period
for data review.

L arge PWSs : L arge PWSs are expected to review, approve, and submit the data to
the s tate and EPA via the EP A electronic reporting system. EPA assumed it would
take these PWSs two hours per samp ling period for data review and submission.

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

PW Ss are required to no tify their consumers of the detection of any unregulated contaminants. CWSs must report UCMR monitoring results in CCRs (6 3 FR 44512 (August 19, 1998)). CWSs
and NTNCWSs must report any failure to monitor for unregulated contaminants required through UCMR under the Public Notification Rule (65 FR 25982, May 4, 2000). No additional public notification burden is assumed under UCMR.

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

U nder UCMR, small PWSs only incur la bor costs. By design of the rule, EPA will assume all costs for analyses of the samples and for shipping the samples from small systems to laboratories contracted by EPA to analyze UCMR 4 samples (the cost of shipping is now included in the cost of each analytical method).

T hus, the laboratory analysis and shipping cost estimates described here are the basis for EPA and large PWS non-labor costs. Separate shipping fees are no longer calculated for UCMR 4. Laboratories that provided method costs estimates informed EPA that the cost of shipping is generally included in the method costs. Laboratories provide PWSs with pre-paid shipping labels so samples can be shipped back to the laboratory for analysis.

T he most significant cost associated with the implementation of UCMR is the cost of laboratory services for sample analysis. E stimates of laboratory analytical costs associated with the analysis of each sample are presented in this section

. UCMR 4 sampling and analysis does not coincide
wit h other compliance monitoring. EPA estimates are based on c onsultations with national drinking water laboratories.Draft ICR for UCMR 4 Proposed Rule November 2015

34 For those PWSs that collect samples for cyanotoxins, not all samples collected would necessarily need to be analyzed. Initially, source water intake samples would be analyzed for total microcystins with an ADDA -based ELISA methodology. If the source water intake ELISA result is less than 0.3 μg/L (i.e., the reporting limit for total microcystins), then the other collected samples (from the EPTDS) would not be analyzed for that sample event and only that source water result would be reported to EPA. If the ELISA result from the source water intake is greater than or equal to 0.3 μg/L, that result would be reported to EPA and the sample from the EPTDS would then also be analyzed for total microcystins by ELISA. (ELISA analysis of the EPTDS sample would be the first step for consecutive systems.) If the EPTDS ELISA result is less than 0.3 μg/L, then no additional analyses would be needed for that particular sample event and that result would be reported to EPA. If the EPTDS ELISA result is greater than or equal to 0.3 μg/L, then that result would be reported to EPA and the other microcystin sample collected at the EPTDS would be analyzed using EPA Method 544, to identify particular microcystin congeners. S amples for cylindrospermopsin and anatoxin- a sampling would be conducted twice a month for four consecutive months only at the EPTDS, and those samples would be analyzed only by EPA Method 545.

T o estimate the percentage of positive samples, and the percentage of samples that would need to be subsequently analyzed, EPA discussed the matter with several states that have been affected by algal blooms and associated cyanotoxins. Based on those discussions , EPA estimated that 20 percent of the source water in take ELISA samples would be positive, and the corresponding EPTDS samples would need to be analyzed. EPA then assumed that two percent of the EPTDS samples would be positive, and the EPTDS samples would need to be analyzed using Method
544. Measurements fo r temperature and pH would take place at the source water intake (concurrent with total microcystin sampling). Consecutive SW and GWUDI PWSs are not expected to collect source water intake samples.

E xhibit 10 shows the analytical costs per sample.Draft ICR for UCMR 4 Proposed Rule November 2015

35 Exhibit 10: Assessment Monitoring (List 1) Analytical Costs

Method Type Average Analysis Cost per
UCMR 4 Sample 1
3 Alcohols using EPA Method 541 ( Gas Chromatography/Mass
S pectrometry ( GC/MS) ) $337

Bromide 2 $55

3 Brominated HAA Groups using EPA Method 552.3 ( Gas Chromatography ( GC) or 557 ( Ion Chromatography/Tandem Mass Spectrometry ( IC

- MS/MS) ) $194

One Cyanotoxin group using ELISA $163

7 Cyanotoxins using EPA Method 544 ( Solid Phase Extraction (SPE) Liquid Chromatography/Tandem Mass Spectrometry ( LC/ MS/MS) ) $445

2 Cyanotoxins using EPA Method 545 (LC/MS/MS) $428

2 Metals using EPA Method 200.8 ( Inductively Coupled Plasma Mass Spectrometry ( ICP

- MS) ) $80

9 Pesticides and a Pesticide Byproduct using EPA Method 525.3 (SPE GC/MS) $415

3 Semivolatile Organic Chemicals using EPA Method 530 (GC/MS) $384

TOC ( TBD ) 2 $61

Total $ 2 ,56 2

1 The average analytical cost for Assessment Monitoring was determined by averaging estimates provided by three drinking water
la boratories.
2 TOC and Bromide are HAA indicators and are analyzed using methods to be determined by PWSs and their laboratories. TOC

methods include: Standard Method ( SM ) 5310 B or 5310 B

- 00, SM 5310 C or 5310 C

- 00, SM 5310 D or 5310 D

- 00, EPA Method 415.3 (Rev. 1.1 or 1.2) (40 C.F.R. § 141.131 (d)(3). Bromide methods include: EPA Methods 300.0, 300.1, 317.0 (Rev. 2.0), 326.0 or American Society for Testing Materials ( ASTM ) D 6581

- 00) (40 C.F.R. § 141.131 (d)(2)).

T he UCMR 4 proposal specifies that some samples be collected at EPTDSs

. Some large PWS s that use GW sources and have multiple EPTDSs may be able to realize significant savings by sampling representative sample point (s) rather than sampling each EPTDS. PWSs must meet
certain PWS configuration criteria; submit a proposal regardi ng representative sample points;
and receive a pproval from EPA or the s tate. Labor related to submission and coordination of these proposals is discussed 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 GW PWS s, EPA assumed that large

PWSs would sample approximately 75% of the current EPTDSs, and that very large PWSs would sample at 50% of the current EPTDS.

PW S s that purchase all of their water from a wholesale PWS , and that have more than one intake from that wholesaler may collect EPTDS samples from a representative intake. The representative site has to be one of the higher annual volume EPTDS connections. Because this
is the first time this allowance has been ma de, EPA did not attempt to estimate the number of

PWSs that would take advantage of this allowance. Thus, the cost estimates presented in this
ICR are conservative.Draft ICR for UCMR 4 Proposed Rule November 2015

36 T otal laboratory and shipping fees were estimated per required sampling location, p er sam pling event, as follows: (number of PWSs ) times (number of periods per year) times (number of sampling points per PWS ) times (method and shipping costs).

6( a)(iii) Summary of Labor and Non-labor Costs to PWS s

E xhibit 11a displays a summary of labor and non-labor costs, by year, for the three

- year ICR period. Analogous information presenting estimated costs over the five- year UCMR 4 implementation period is provided in Exhibit B-1a, in Appendix B. Small PWSs incur labor costs only. Large PWSs incur both labor and non- labor costs.

T he nationwide cost to PWSs for implementing the total UCMR program over the three

- year ICR period is $67.1 million. Large and very large PWSs incur about 99 % of th e total PWS cost, $66.6 million. Annual cost per small PWSs for UCMR implementation over the three

- year ICR period is $171 per PWSs

, all attributed to labor. Annual cost per large PWSs is $682 for labor plus $ 6,047 for analytical (non- labor) costs

, with very large PWSs costs of $1,248 for labor plus $16,298 for analytical (non

- labor) costs. Exhibits 8 and 9 illustrate the number of participating

PWSs and timing of monitoring. Per

- PWSs labor burdens and costs are presented in Exhibit 11b. This exhibit presents a summary of burden and cost per response. Analog ous 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 PWS . All labor and non- labor costs associatedwith a reporting event (reading the regulations, monitoring and reporting) are included in the perresponse cost estimate.Draft ICR for UCMR 4 Proposed Rule November 2015

37 E x hibit 1 1a: Yearly Cost to Systems, by PWS Size a nd by T ype o f C ost ( 2017-2019) (corresponds with Exhibit B-1a)
Cost Description 20 1 7 20 1 8 20 1 9 Total 1

SMALL PWSs (standard sample serving 10,000 or fewer people)

Labor Costs
Reading and Initial Reporting $0 $57,6 20 $57,6 20 $ 115,2 40

Monitoring $0 $151,440 $151,440 $302,88 1

Reporting of Results $0 $64,150 $64,150 $ 128,300

Non

- Labor Costs (Laboratory Analysis and Shipping (paid for by EPA)) $0 $0 $0 $0

Subtotal

– Small PWSs $0 $ 273,210 $ 273,210 $546,42 1

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

Labor Costs
Reading and Initial Reporting $0 $652,904 $652,904 $1,305,80 9

Monitoring $0 $938,43 7 $938,43 7 $1,876,87 4

Reporting of Results $0 $1,059,3 40 $1,059,3 40 $2,118,6 80

Non

- Labor Costs (Laboratory Analysis and Shipping) $0 $ 23,491,630 $ 23,491,630 $ 46,983,259

Subtotal

– Large PWSs $0 $26,142,31 1 $26,142,31 1 $52,284,621

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

Labor Costs
Reading and Initial Reporting $0 $ 71,47 3 $ 71,47 3 $142,945

Monitoring $0 $298,629 $298,629 $597,258

Reporting of Results $0 $137,903 $137,903 $275,80 7

Non

- Labor Costs (Laboratory Analysis and Shipping) $0 $6,633,27 4 $6,633,27 4 $13,266,547

Subtotal

– Very Large PWSs $0 $7,141,27 9 $7,141,27 9 $14,282,557

ALL PWSs
Total Labor for All Systems $0 $3,431,896 $3,431,896 $6,863,79 3

Total Non

- Labor for All Systems $0 $30,124,903 $30,124,903 $ 60,249,80 7

Total Labor and Non

- Labor
for All PWSs $0 $33,556,800 $33,556,800 $67,113,599

1 Totals may not equal the sum of components due to rounding

.Draft ICR for UCMR 4 Proposed Rule November 2015

38 Exhibit 11b : Per System (Respondent) and Per Response UCMR Costs ( 2017-2019 ) (corresponds with Exhibit B -1b)

Burden / Cost Total over 2017

- 2019 Annual Average over 2017

- 2019

Small PWSs Large PWSs Very Large
PWSs Small PWSs Large PWSs Very Large
PWSs

PER RESPONDENT:

Labor Cost $ 512 $2,047 $3,745 $171 $682 $1,248

Non

- Labor Cost $0 $18,140 $48,894 $0 $6,047 $16,298

Burden (labor hours) 18.5 69.8 139.4 6.2 23.3 46.5

PER RESPONSE:

Number Responses per Respondent 6.7 11.4 14.1 2.2 3.8 4.7

Labor Cost per Response $77 $180 $265 $26 $60 $88

Non

- Labor Cost per Response $0 $1,596 $3,463 $0 $532 $1,154

Burden (labor hours) per Response 2.8 6.1 9.9 0.9 2.0 3.3

6(b ) Estimating the Burden and Cost to States

S ince the UCMR is a direct implementation rule, individual s tate costs largely depend on specifications in their PA. EPA assumed that states incur only labor costs, because no capital investments are expected for UCMR 4. Because s tates are involved in a variety of UCMR implementation and oversight activities but have few defined responses, burden estimates are based on y early activities . Thus, for “per response” estimates, s tates have an average of 1 .0

response per year.

E PA used updated estimates from ASDWA’s “Insufficient Resources for State Drinking Water Programs Threaten Public Health: an Analysis of State Drinking Water Programs’ Resources and
Needs.” to estimate state burden and cost for the implementation and oversight of UCMR 4. In 2000, the United States General Accounting Office used a previous version of this model to estimate nationwide drinking wa ter program needs for Congress.

E PA reviewed the estimates used by ASDWA for various aspects of drinking water program implementation activities, and used best professional judgement to determine which estimates would apply to UCMR 4 activities. Assumptions include:Draft ICR for UCMR 4 Proposed Rule November 2015

39 • O n e full

- time equivalent ( FTE ) is equivalent to 2,080 hours per year; this represents a change from UCMR 3, as the previous estimates used 1,800 hours per year for one FTE.

• St ates would need one supervisor per seven technical FTEs, and one support staff for every 20 technical FTEs.

• W ag e rate information for states from the BLS was used since these rates are more recent than the rates used by ASDWA . This same wage rate information is being used for the renewal ICRs for current drinking water regulations, and was calculated as follows: The

s tate labor rate of $29 was m ultiplied by a loadin g rate of 1.6 to account for benefits. The wage rate was then escalated to 201 4 dollars using the Employment Cost Index for wages and salaries in trade, transport, and utilities for March 2013 and December 2014. The index value ( accessed from http://www.bl s.gov on March 12, 2015), was 116.9 for March
2013 and 121.7 for December 2014. State Employee wage rates from National Occupational Employment and Wage Estimates, United States, BLS SOC Code 19-2041,

"State Government - Environmental Scientists and Specia lists, Including Health," hourly mean wage rate. May 2013 data (published in April 2014). http://stats.bls.gov/oes/current/oes192041.htm. The average estimated wage rate for states is $47.

The model included s tate resource needs for different aspects of the Phase II/V and nitrate regulations. EPA needed to isolate the UCMR co sts from the aggregated costs. Based on professional judgment regarding the relative magnitude of the UCMR program, EPA assumed
that:

• A SDWA's estimates of hours include the following activities for implementation of the chemical program : setting up monitoring schedules for PWSs ; notifying PWSs of requirements; reviewing data/information submitted to the state; determining compliance; assigning violations; commencing enforcement action s; and data entry/ recordkeeping /reporting to EPA. ASDWA also included hours for running a waiver program. The
estimates also a ssume d most states have a state

- wide waiver and that most systems have individual use or susceptibility waivers for some analytes. EPA used the same labor
estimates as a base in order to provide a conservative estimate for UCMR 4 activities.
Under UCMR 4 , states are anticipated to: assist PWSs with monitoring schedules ; notify PWSs of requirements ; and possibly review data. S tates were given 10.75 hour s per small

PWS , and 13.25 hours per large PWS to help implement the UCMR program. EPA
assumed that during the first and last year of the five

- year UCMR period (201 7 and 2021), when there are no monitorin g activities, UCMR represents 1% of the bundled program resource needs ( al though the costs for 2020 and 2021 are not relevant to theDraft ICR for UCMR 4 Proposed Rule November 201 5

40 current ICR estimations ) ; during the three years when monitoring is conducted, UCMR represents 3% of the bund led program re source needs.

• While not required by EPA for the UCMR program, estimates include time for state staff training on database use; inventory updates; responses to data queries (e.g., producing monthly violation reports for program staff); quarterly reporting and recordkeeping; and QC of data entered for compliance oversight. ASDWA assumed one FTE per year for
small and very small states, 1.75 FTEs for medium states, five FTEs for large states, and
six FTEs for very large states. For UCMR, EPA assumed that stat es would use th is time
to review PWS data . In some instances, states may enter and track UCMR data in their own database systems.

• States are estimated to need 20 hours in the first ICR year of 2017 to read and understand
UCMR 4

.

• States are assumed to nee d 0 .15 FTEs in 2017 to develop PAs with EPA. This estimate assumes that two FTEs would devote three weeks in the first year of UCMR 4 to complete this task.

• ASDWA provided estimates for PWS training and technical a ssistance with estimates ranging from .67 hours per PWS to two hours per PWS , based on population served . For
UCMR 4

, s tates were given one hour per PWS for technical assistance for all t hree monitoring years. This would also assist states in writing monitoring schedule letters to PWSs, and providing other technical assistance during monitoring years

.

• ASDWA estimated that states would need to train technical staff on new rule requirements, noting that 11 hours were needed p er technical FTE for three new rules.
ASDWA assumed that t raining w ou l d include one day of classroom training per technical
FTE and three hours per technical FTE for follow

- up questions; reading rule; and
discussions. EPA assume d that training will occur only in the first year, and that 3.67 hours per FTE for tra ining would be needed for UCMR 4

.

Some of the state labor estimates depend on the size of the state. Exhibit 1 2 shows the number of states in each size category. EPA further refined the labor burden estimates by taking the level of

s tate participation under UCMR 3 into consideration

. EPA reviewed key areas of s tate participation under UCMR 3 including : review and revision to the SMP s; assisting EPA with update s to information for large PWSs ; two separate sets of PWS notifications; and compliance
assistance

. Based on prior UCMR activities, 80 percent of s tates typ ically participated in their optional UCMR activities

. Burden estimates generated from the ASDWA estimates were multiplied by this “ percent participation in UCMR 3 ” to approxim ate s tate costs at expected participation lev els under UCMR 4

.Draft ICR for UCMR 4 Proposed Rule November 2015

41 Exhibit 1 2 : 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

E PA estimates that the average annual burden over the three ICR years ( 2017-2019 ) for 56 s tates to implement UCMR is 13,681 hours (or 244 hours per s tate per year), with an average annual cost of $649,467 (or $ 11,598 per s tate per year)

. See Exhibits 1 3 a and 13b for a summary of
estimated state burdens and costs (analogous five- year information for 2017-2021 provided in Exhibits B-2a and B-2b, in Appendix B).

E xhibit 1 3a : Yearly Cost and Burden to States for Implementation of UCMR 4 (2017- 2019) 1 (corresponds with Exhibit B-2a)

Cost/Burden 2017 2018 2019 Total 2 Annual Average Costs to all states for labor related to UCMR implementation and oversight
$ 876,636 $ 535,883 $ 535,883 $ 1,948,402 $ 649,467
Labor burden for all states for UCMR implementation and oversight (number of hours)

18,466 11,288 11,288 41,043 13,681

1 All costs are attributed to labor and are estimated over the period 2017

- 2019

. 2 Totals may not equal the sum of components due to rounding.

E xhibit 13b : Per State (Respondent) and Per Response UCMR 4 Costs (2017 -2019) (corresponds with Exhibit B-2b)

Burden / Cost Total over 2017-2019 Annual Average

over 2017

- 2019

PER RESPONDENT:

Labor Cost $ 34,793 $ 11,598

Non

- Labor Cost $0 $0

Burden (labor hours) 732.9 244.3

PER RESPONSE:
Number Responses per Respondent 1 3

. 0 1.0

Labor Cost per Response $ 17,397 $ 5,799

Non

- Labor Cost per Response $0 $0

Burden (labor hours) per Response 366.5 122.2

1 States have 1 response per year, since there are no specific cyclical s tate reporting requirements under the UCMR program.Draft ICR for UCMR 4 Proposed Rule November 201 5

42 6(c) Estimating Agency Burden and Cost

EPA incur s burden and costs related to UCMR implementation activities, including : regulator y support activities; national and regional oversight and data analysis; and the small PWS 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 g overnment 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 last quarter of 201 4 (see the U.S. Office of Personnel Management website : www.opm.gov)

. With thes e assumptions, labor and contractor rates were based on a 2,080 hour work year, with a $ 164,694 annual salary plus 60% overhead, or $ 79 per hour

. Additional cost assumptions are described in sections 6( c) (i)

- (iii), Part A of this ICR
document

. Cost and bur den estimates are presented in Exhibits 14 a and 14 b , 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 incur s various labor or contractor costs related to the laboratory PT/approvals; laboratory QA/QC; and provision of analytical standards, as follows :

• The l aboratory approval (PT program) is estimated to cost EPA $2 3 8

, 8 1 1 prior to the beginning of monitoring

, in 201 7

. Cost estimates were based on costs realized by the A gency for similar activities during UCMR 2 and UCMR 3

. A three
percent inflation rate was applied to the costs of UCMR 3 to estimate the costs for

UCMR 4

. T hese costs are also included in Append ix B.

• QC Audits of contract laboratories occur s throughout active UCMR monitoring

. Labor (hours) for each trip includes : a 3

- day site inspection (for two individuals);

one full

- day travel for two individuals (assume t wo half days); and three days of report writing (for one individual), which includes review and response to laboratory comments

. Travel costs for two individuals include : round trip flight,
three nights hotel stay, two full day food per diem, and two days at the proportional meal s rate from the 201 5 f ederal rate for the Continental U.S. (from
the U.S. Government Services Administration website: http://www.gsa.gov )

. Also
included is rental of one car f or both travelers

. EPA estimated that these QC
audits would take place four times each monitoring year, at an estimated cost of $ 9,087 per trip.Draft ICR for UCMR 4 Proposed Rule November 201 5

43 • EPA estimated that a nalytical standar ds provision and coordination would cost $ 618,734 total for three ICR years (or $ 206,245 per ICR year). Cost estimates are based on costs realized by the A gency for prior similar activities

.

Technical Support/Guidance Document Development : These activities cost EPA approximately $ 180,89 9 total over the ICR period including : costs for developing and distributing guidance for laboratories that will participate in UCMR 4 testing; health effects fact sheets; and other pert inent guidance related to UCMR 4 implementation

. T hese activities would take place in 201 7 and 201 8

. T hese costs are included in Appendix B, which presents costs for the entire UCMR 4 period. Cost estimates were based on costs realized by the A gency for prior similar activities. For UCMR 4 , a 3%
inflation rate was applied to the costs of UCMR 3

.

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

EPA activities include data analysis, management oversight and support at both the regional and
national level for assistance to s tates with UCMR implementation

. During the core period of

UCMR 4 activity, EPA estimate d that it would dedicate 5.5 FTEs each year to program oversight and data analysis. These activities are estimated as labor cost and burden to the A gency (see the corresponding description of these activities in section 5(a) (ii), Part A of this ICR document)

. These activities will cost EPA $ 2.7 million in total over the three

- year ICR period

.

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

EPA provide s logistical support for the small PWS testing program

. This activity includes costs
for contractual labor

, sampling supplies, and shipping costs, and is estimated to cost EPA $4 25 per sampling event per sampling site, based on actual historical costs incurred during UCMR 3 for this same activity

. These activities , plus analytical and shipping f ees are estimated to cost EPA $ 11 .9 million in total over the three ICR years

. See section 6(a)(ii), Part A of this ICR document, for assumptions regarding applicable laboratory fees for individual methods

. Total
costs that EPA inc ur s for the small PWS testing program were calculated by multiplying the laboratory and shipping fees by : (number of PWSs ) times (number of sampling periods per y ear ) times (number of sampling points per PWS )

.

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

EPA estimates that the cost for the UCMR 4 program during the ICR period of 2017

- 2019 is $ 15.8 million ; (with annual average cost over the ICR period of $ 5. 3 million)

. EPA costs for UCMR implementation are shown in Exhibit 14 a ; average annual labor and non

- labor costs, asDraft ICR for UCMR 4 Proposed Rule November 2015

44 well as small PWS testing program costs are shown in Exhibit 14 b. Appendix B, Exhibits B

- 3a and B-3b provide analogous information over the five- year UCMR 4 implementation period.

Exh ibit 14a: Yearly Cost to EPA for UCMR Implementation, by Type of Cost (2017-2019) 1 (corresponds with Exhibit B-3a)

Cost Description 20 1 7 20 1 8 20 1 9 Total 2 Annual Average

Regulatory Support Activities : laboratory PT ; QC audits; analytical standards provision; and technical support, guidance document development

Lab PT $ 238,81 1 $0.00 $ 0.00 $ 238,81 1 $ 79,60 4

QC Audits $1 8,17 4 $ 36,347 $ 36,347 $ 90,868 $ 30,290

Analytical Standards $ 119,40 5 $ 245,975 $ 253,354 $ 618,734 $ 206,24 5

Technical Support $ 119,40 5 $ 61,494 $0 $ 180,899 $ 60, 300

Subtotal

– Regulatory Support $ 495,79 4 $ 343,81 7 $2 89,70 2 $ 1,129,312 $ 376,43 8

National and Regional Oversight and Data Analysis : UCMR management oversight; review and evaluation of data from all UCMR monitoring

$ 905,819 $905,819 $905,819 $ 2,717,45 8 $ 905,819

Small PWS Testing : implementation coordination; and analytical and shipping costs for small PWS testing for Assessment Monitoring

Implementation
Coordination $0.00 $ 2,336,055 $ 2,336,055 $ 4,672,110.00 $ 1,557,370.00
Fees for Analysis and shipping

– standard sample $0.00 $ 3,635,893 $ 3,635,893 $ 7,271,787 $ 2,423,929

Subtotal

– Small PWS Testing $0.00 $ 5,971,948 $ 5,971,948 $ 11,943,897 $ 3,981,29 9

TOTAL $ 1,401,613 $ 7,221,584 $ 7,16 7, 469 $ 15,790,66 7 $ 5,263,55 6

1 Agency costs we re estimated over the period 2017

- 2019

. 2 Totals may not equal the sum of components due to rounding.Draft ICR for UCMR 4 Proposed Rule November 2015

45 Exhibit 14 b: Summary of EPA Burdens and Costs for UCMR Implementation ( 2017-2019 ) (corresponds with Exhibit B-3b)

Burden / Cost Annual Average Cost over Three

- year ICR Period of 2017

- 2019 1

Labor Cost $ 905,819

Non

- Labor Cost $ 4,357,736

Total Cost to EPA for UCMR Implementation $ 5,263,55 6

Burden (labor hours) 11,440.0

1 Totals may not equal the sum of components due to rounding.

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

Se ction 1(b) of Part A of this ICR describes the general timing of monitoring. Exhibit 8 presents the estimated numbers of regulated PWSs affected by UCMR 4, and E xhibit 9 presents the
time line in which the PWS monitoring activities is expected to take place. The frequency of responses for PWSs is described in Section 4(b)(ii)(a).

Ex hibit 15 summarizes nat ional hours and costs for UCMR 4 during the ICR period. Analogous
information for the entire five- year UCMR 4 period 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 PWSs is 15,173 hours, with a cost of $546,421. The total labor burden to large PWSs is 147,209.5 hours, with a labor cost of $5.3 million , and non- labor costs for analysis and shipping of $47.0 million

. Very large PWSs have a total labor burden for the ICR period of 28,212.83 hours, with labor and non-labor costs of $1.0 million and $13.3 million, respectively . The total burden to s tates over the three -year ICR period is 41,043 hours, with a labor cost of $1.9 million

. EPA anticipates that s tates will not incur any significant non-labor

costs

. EPA ’s total burden over the same time frame is 34,320 hours, with labor costs of $2.7

million , and non-labor costs of $13.1 million

.

Ex hibit 1 5 : UCMR 4 National Cost Summary for the ICR period (2017-2019 ) (corresponds
with Exhibit B -4)

Type of Cost 201 7 201 8 201 9 TOTAL 1 Annual Average

Small PWSs

Labor Cost $0 $273,210 $273,210 $ 546,42 1 $ 182,140

Non

- Labor Cost $0 $0 $ 0 $0.00 $0.00

Total Small PWS Cost $0 $273,210 $273,210 $ 546,42 1 $ 182,140Draft ICR for UCMR 4 Proposed Rule November 2015

46 Type of Cost 201 7 201 8 201 9 TOTAL 1 Annual Average

Large PWSs

Labor Cost $0 $ 2,650,681 $2,650,681 $ 5,301,362 $ 1,767,12 1

Non

- Labor Cost $0 $23,491.630 $23,491.630 $ 46,983,259 $ 15,661,086

Total Large PWS Cost $0 $26,14 2 ,31 1 $ 26,14,311 $52,284,621 $17,428,207

Very Large PWSs

Labor Cost $0 $508,00 5 $ 508,005 $ 1,016,0 10 $ 338,6 70

Non

- Labor Cost $0 $6,633,274 $6,633,274 $ 13,266,547 $ 4,422,18 3

Total Very Large

PWS Cost $0 $7,141,27 9 $ 7,141,279 $14,282,557 $4,760,852

States

Labor Cost $ 876,636 $ 535,883 $ 535,883 $ 1,948,402 $ 649,467

Non

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

Total S tate Cost $ 876,636 $ 535,883 $ 535,883 $ 1,948,402 $ 649,467

EPA

Labor Cost $ 905,819 $ 905,819 $ 905,819 $ 2,717,458 $ 905,819

Non

- Labor Cost $ 495,794 $ 6,315,765 $ 6,261,650 $ 13,073,209 $ 4,357,736

Total EPA Cost $ 1,401,613 $ 7,221,584 $ 7,167,469 $ 15,790,667 $ 5,263,55 6

National Total

Total with EPA $ 2,278,249 $ 41,314,267 $ 41,260,152 $ 84,852,668 $ 28,284,22 3

Total without EPA $876,636 $ 34,092,683 $ 34,092,683 $69,062,001 $23,020,667

Total Burden (hours) for All Responses 2

Small PWS s 0.0 7,586. 6 7 ,586.6 15,173.1 5,057.7

Large PWS s 0.0 73,604.7 73,604.7 147,209.5 49,069.8

Very Large PWS s 0.0 14,106.4 14,106.4 28,212.8 9,404. 3

States 18,466 .2 11,288.3 11,288.3 41,042.9 13,68 11.0

EPA 11,440 .0 11,440.0 11,440.0 34,320.0 11,440. 0

Total with EPA 29,90 6.2 118,026.0 118,026.0 265,958.3 88,652. 8

Total without EPA 18,466 .2 106,586 .0 106,586.0 231,638.3 77,212. 8

1 Totals may not equal the sum of components due to rounding.

2 Although EPA is not consi dered a respondent to the UCMR

, Agency burdens are shown here to illustrate the national costs of the program

. National totals are shown with and without the Agency costs.

6(e) Reasons for Change in Burden

Thi s ICR builds upon the ICR developed for UCMR 3, entitled: Information Collection Request for UCMR 3, ICR Number 2192.05, OMB Control No. 2040-0270 . After the UCMR 1 programDraft ICR for UCMR 4 Proposed Rule November 2015

47 was established in 1999, subsequent UCMR cost and burden estimates were incorporated into the larger Chemical/Rad ionuclides ICR. However, the UCMR 2 and UCMR 3 ICR s w ere developed and tracked separately from the Chemical/Rad ionuclide s ICR, because the
Chemical/Rad ionuclide s ICR was a “renewal” ICR, whereas the UCMR program is, per SDWA, a program that must change every five years. Like the UCMR 2 and UCMR 3 ICR s, this action and subsequent ICRs will be developed and tracked separately. The re asons that respondents to
this ICR incur a different burden than those responding to the previous UCMR ICR s include:

• UC MR 4 includes only one monitoring component; Assessment Monitoring.

• UCMR 4 includes a new list of 30 contaminants. Because the laboratory methods are different, the cost of laboratory analysis differs for UCMR 4.

• EPA will not collect duplicate Quality Assuran ce ( QA) field samples for the small PWSs

.

• EPA updated wage rates, and re-examined labor burden estimates for states, EPA, and
PWS activities.

• PWSs will collect samples from EPTDS, distribution locations, and source water
locations. Because not all of thes e samples will be collected at the same time , and at the
same locations

, EPA estimated more time for sample collection activities than in previous

UCMRs.

6(f) Burden Statement

S mall PWSs that were selected for UCMR 4 monitoring are expected to sample an average of

6.7 times per PWS ( i.e. , number of responses per PWS ) across the three

- year ICR period

. The average burden per response for small PWSs is 2.8 hours. Large PWSs and very large PWSs are expected to sam ple and report an average of 11.4 and 14.1 times per PWS , respectively, across
the three

- year ICR period

. The average estimated burden per response for large and very large

PWSs is 6.1 and 9.9 hours, respectively. States are projected to incur 3 .0 responses over the
three

- year ICR period related t o coordination with EPA and PWS s, with an average burden per

response of 366.5 hours. In aggregate during the ICR period, the average response ( e.g. , responses from PWS and s tates) is associated with a burden of 6.9 hours, with a labor plus nonlabor cost of $1,705 per response.

T he annual average per -respondent burden hours and costs for the ICR period are : small PWSs

– 6.2 hour burden at $171 for labor; large PWSs – 23.3 hours at $682 for labor, and $6,047 for analytical costs; very large PWS s –46.5 hours at $1,248 for labor, and $16,298 for analytical costs; and s tates – 244.3 hours at $11,598 for labor . Annual average burden and cost per respondent (including PWSs and s tates) is 23.4 hours, with a labor plus non-labor cost of $5,778

per respondent.Draft ICR for UCMR 4 Proposed Rule November 2015

48 The annual average burden to EPA for UCMR 4 program activities during the ICR years is 11,440 hours, with an annual labor cost of $ 905,819. EPA's annual average non-labor costs are $4.4 million

. Non

- labor costs are primarily attributed to the cost of sample testing for small

PWS s (testing is 91 % of non-labor costs ).

Ex hibit 16 presents per -respondent and per-response burdens and costs over the UCMR 4 ICR period of 2017-2019 (analogous information for the 2017-2021 UCMR 4 implementation period is provided in Exhibit B-5, Appendix B). This exhibit also presents average annual burdens and

costs.

Ex hibit 1 6 : UCMR 4 Per Respondent Burden and Cost Summary for the ICR Period (2017-2019 ) (corresponds with Exhibit B -5)

Burden (hours)/ Cost (dollars) Small
PWSs Large
PWSs Very Large
PWSs States EPA National Average
with EPA 1 National Average
without

EPA

Three

- Year Total per Respondent

Total # of Responses Per Respondent 6. 7 11. 4 14.1 3.0 n/a n/a 10. 2

Labor Cost Per Respondent $5 12 $ 2,04 7 $ 3,745 $34,79 3 $2,717,45 8 $ 2,893 $2,21 2

Non

- Labor Cost Per Respondent $0 $1 8, 140 $ 48,89 4 $0 $13,073,209 $18, 400 $15,12 3

Total Cost (Labor plus Non

Labor) $512 $ 20,187 $52,638 $34,792 3 $15,790,66 7 $21,293 $ 17,33 5

Total Cost Per Response $7 7 $ 1,77 7 $ 3,72 8 $17,39 6 n/a n/a $ 1,705

Total Burden Per Respondent (hr) 18.5 69.8 139. 4 732.9 34,320 78.7 70.1

Total Burden Per Response (hr) 2. 8 6.1 9. 9 3 66. 5 n/a n/a 6.9
Average Annual per Respondent

Ave. # of Responses Per Respondent 2.2 3. 8 4.7 1.0 n/a n/a 3. 4

Labor Cost Per Respondent $17 1 $682 $1,248 $11,59 8 $905,819 $964 $7 37

Non

- Labor Cost Per Respondent $0 $6,04 7 $16,29 8 $0 $4,357,736 $6,133 $5,04 1

Ave. Cost (Labor plus Non

- Labor) $17 1 $6,729 $17,546 $11,59 8 $5,263,55 6 $7,09 8 $5,778Draft ICR for UCMR 4 Proposed Rule November 2015

49 Burden (hours)/ Cost (dollars) Small
PWSs Large
PWSs Very Large
PWSs States EPA National Average
with EPA 1 National Average
without

EPA Average Annual per Respondent (cont)

Ave. Cost Per Response $2 6 $ 592 $ 1,24 3 $5,79 9 n/a n/a $ 568

Ave. Burden Per Respondent (hr) 6. 2 23. 3 46. 5 244.3 11,440.0 26.2 23. 4

Ave. Burden Per Response (hr) 0.9 2.0 3. 3 122. 2 n/a n/a 2. 3

1 National average burdens and costs differ greatly between the s tate respondents and the various PWS respondents

. This should be taken into consideration when looking at the national average with or without EPA.

B urden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a f ederal 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 co ntrol numbers for EPA's regulations are
listed in 40 CFR part 9 and 48 CFR chapter 15.

T o comment on EPA’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 established a public docket for this ICR. Docket ID N umber EPA

HQ

- OW -2015-0218 , is available for public viewing at the Water Docket in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. Th is
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 th is Public Reading Room is (202) 566-1744, and the telephone number for the Water Docket is (202) 566-2426. An electronic version of the public docket is available at www.regulations.gov. This site can be used to submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronically. When in the system, select “search,” then key in the Docket ID Number identified above. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Des k Officer for EPA. PleaseDraft ICR for UCMR 4 Proposed Rule November 2015

50 include the EPA Docket ID Number EPA

- HQ
- OW -2015-0218 and OMB Control Number 2040- 0270 in any correspondence.Draft ICR for UCMR 4 Proposed Rule November 2015

51 

### – PART B OF THE SUPPORTING STATEMENT

–

1 SURVEY OBJECTIVES, KEY VARIABLES, AND OTHER
PRELIMINARIES

1( a) Survey Objectives

T he 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 monitors for contaminants identified by the UCMR rule

. The representativeness of this sample of PWSs is critical to the UCMR program because the drinking water contaminant occurrence data collected by the PWSs is used to : estimate national occurrence and exposure ; establish a baseline for health effects and economic analyses ; and provide information for regulatory determinations and, as appropriate, regulatory development.

1 (b) Key Variables

K ey variables associated with selecting a nationally representative sample of PWSs include : PWS size, source water type and geographical location.

1 (c) Statistical Approach

S ection 1445(a)(2) of SDWA (as amended in 1996) requires that the UCMR program include only a representative sample of PWSs serving 10,000 or fewer people. In addition to satisfying statutory requirements, selection of a sample of PWSs 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

E PA anticipates that the survey (the statistical sample) objectives are achievable given the existing time a nd resource constraints.

• H igh PWS response/participation rates (>95%) during UCMR 1 and UCMR 2 (and, thus far, in UCMR 3) give EPA confidence that equivalent or bett er participation rates can be achieved during UCMR 4.Draft ICR for UCMR 4 Proposed Rule November 2015

52 • The statistical approach to this data collection requires only a fraction of small PWSs to conduct monitoring, resulting in much smaller cost and burden at the national level than
would be incurred if all PWSs monitored. Small PWSs that are selected for UC MR 4 monitoring incur only a few hours of labor burden. EPA pay s for all laboratory fees and shipping costs related to small PWS testing.

• The survey results will be completed in time to inform the next cycle of CCL and regulatory determinations.



### 2 SURVEY DESIGN

2( a) Target Population and Coverage

PW Ss are the target population for UCMR monitoring. All PWSs that serve more than 10,000
retail customers are subject to the Assessmen t Monitoring component of UCMR 4 monitoring. Eligible small PWSs (ser ving 10,000 or fewer people) are only required to conduct UCMR 4 monitoring if they are part of the statistical selection for Assessment Monitoring or the Screening Survey, or if they have been selected to monitor for Pre- Screen Testing . UCMR 4 does not currently include a Screening Survey or Pre- Screen Testing

. Small PWSs a re only selected to monitor for one component of UCMR 4 List 1 Assessment Monitoring

.

2 (b) Sample Design

2( b)(i) Sampling Frame

E PA develop ed the sample frame for the statistical selection of UCMR PWSs , including the system PWSID, name, source water category, and population- served data for each UCMR

eligible PWS

. Initial data were pulled from EPA's Safe Drinking Water Information System (SDWIS /FED ) inventory database and were adjusted to account for known anomalies in population and inventory reporting (for example, how wholesalers report their population data).

2( b)(ii) Sample Size

A s proposed, UCMR 4 monitoring would include Assessment Monitoring conducted by all PWSs serving more than 10,000 people (“ large ” and “very large” PWSs) , and Assessment Monitoring conducted by 1,600 representative PWSs serving 10,000 or fewer people (“ small ” PWSs) . 800 small SW and GWUDI PWSs would monitor for 10 cyanotoxins and a different group of 800 small systems would monitor for 20 additional chemicals

.Draft ICR for UCMR 4 Proposed Rule November 201 5

53 2 (b)(iii) Stratification Variables

In developing the representative sampl e, EPA consider s fact ors such as population served, water source and geographic location

. The sample of PWSs , as propos ed, is stratified by population served ( PWS size), allocating samples proportionately to each s tate by PWS 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 PWSs

account s for different PWS sizes, sources of water supply and geographic location (e.g., s tates)

. The sample is expected to be stratified by water source type (i.e., GW or SW and GWUDI ) and by PWS size category (i.e., serves 25 to 500 people, 501 to 3,300 people, etc.)

. This stratification
allow s EPA to account for different exposure risks of contaminant occurrence that could be
related to the vulnerability differences between SW and GW sources and differing technical,
management

, and /or financial capacity that can vary across PWS sizes

.

With contaminant exposure assessment as a primary goal, PWSs are expected to be selected in proportion to t he population served

. This population

- weighted allocation leads to statistically valid estimates of national exposure

. To ensure the sample provides equity across s tates for involvement in the UCMR, EPA expects to include at least two PWS s from each s tate

. This additional PWS selection requirement provide s allocation across all the s tates and territories to account for differences in spatial vulnerability and contaminant occurrence, and to ensure equity in participation

. Small t ribal PWSs across the EPA r e gions are expected to be grouped into a single category (equivalent to a “ s tate ” ) for the representative sample.

2(b)(v) Multi

- Stage Sampling

Because PWS status often changes over time, EPA also expects to select “ alternate ” PWSs that
fit the size/sour ce water strata of the originally selected PWS

. Through an interactive review process with the s tates, PWSs that no longer meet eligibility criteria (for example, if they are in a different size category than when originally selected, have become inactive, or do not have a
retail customer base ) w ould be replaced by an alternate PWS that meets the stratification criteria.Draft ICR for UCMR 4 Proposed Rule November 2015

54 2(c) Precision Requirements

2( c)(i) Precision Targets

T he representative sample of PWSs must be selected so that the data collected yield accurate and precise estimates of national contaminant occurrence (the fraction of PWSs at which a contaminant occurs) and exposure (the fraction of people exposed to a contaminant). For estimates of exposure fractions, EPA allows 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 a llowable 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

F or those PWSs selected to conduct UCMR monitoring, response is a requirement. As with any regulat ion, some non- compliance can be expected . However, high compliance levels (>95%) during prior UCMR monitoring (attributable to extensive outreach and compliance assistance) give EPA confidence that the same or bett er compliance levels can be achieved durin g UCMR 4. EPA plans to continue outreach and compliance assistance efforts as needed.

2 (d) Questionnaire Design

N o questionnaires are anticipated for UCMR 4. Analytical results for contaminant occurrence are expected to be reported directly by the laboratories to EPA’s electronic reporting system.



### 3 PRETESTS AND PILOT TESTS

Fo r UCMR 4 , EPA expects to apply the same basic statistical methods that were used to select
the UCMR 1, 2 and 3 national representative sample s of small PWSs

. Following sample adjustments made through communications with s tates, >99% of the final sample of small PWSs (and >95% of large PWSs ) completed their required monitoring and reporting.Draft ICR for UCMR 4 Proposed Rule November 2015

55 

### 4 COLLECTION METHODS AND FOLLOW

- UP

4( a) Collection Methods

La rge P WSs are required to submit their data through EPA's electronic data reporting system. Small PWSs work directly with an EPA -appointed UCMR Sampling Coordinator, and monitoring data from the small PWSs are submitted directly to EPA's electronic reporting system by the laboratories conducting the analyses.

4 (b) Survey Response and Follow- up

H igh compliance levels (>95%) during prior UCMR s give EPA confidence that equivalent or
better leve ls can be achieved during UCMR 4. EPA continues outreach and compliance
assistance efforts as needed

. Each small PWS work s with a UCMR Sampling Coordinator, and
has minimal reporting requirements and one-on- one compliance assistance

.

L essons learned during UCMR 1, 2 and 3 helped refine UCMR 4 require ments

. UCMR 4:

• H as an increased sample frequency for cyanotoxins

, and uses a phased sample- analysis for microcystins

.

• R evise s sampling locations

.

• Compresses the monitoring schedule by eliminating sampling during December

February

.

• Updates, revises, adds and removes data elements to account for the contaminants being proposed, and requires the reporting of QC data by all laboratories.

In UC MR 3 , EPA establish ed a requirement that PWSs report contact information and zip codes
for customers they serve. In UCMR 4, EPA proposes to continue the requirement. Zip code reporting specifications appear in 40 CFR 141.35(c)(1) and (d)(1) for large and small PWSs

, respectively. EPA proposes to continu e to collect zip codes for each PWS ' s service area , as collected und er UCMR 3, to support, among other things, an assessment of whether or not minority, low- income and/or indigenous-population communities are uniquely impacted by particular drinking water contaminants

.Draft ICR for UCMR 4 Proposed Rule November 2015

56 

### 5 ANALYZING AND REPORTING SURVEY RESULTS

5( a) Data Preparation

A fter laboratories post UCMR 4 monitoring results and required data elements to EPA's electronic reporting system, EPA allow s time for QC review by the PWS s, s tates, and the Agency before placing the data in the NCOD for public access

.

D ata problems may occur , but EPA take s the following efforts to reduce problems and increase the dependability and quality of the occurrence data. The UCMR electronic data reporting system and EPA QA/QC assessments screen for the use of inappropriate measu rement units and other improper data. Additional automated QC functions are already in place to identify possible data quality issues such as duplicate data submissions and incomplete data

. All Assessment Monitoring samples are collected by trained PWS sta ff and analytical results are generated by laboratories that are approved for UCMR 4 drinking water analysis . Electronic data submission also avoids potential re- keying errors

. As part of the data QA/QC procedures, all edits or changes
made to the data are documented.

5 (b) Analysis

Fo r UCMR 1, 2 and 3, EPA developed a two-stage analytical approach for the evaluation of the
national occurrence of contaminants. EPA expects to use the same two

- tier approach to analyz e the data for UCMR 4.

T he 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, PWS level and population- served level

. For each contaminant, occurrence
measures include the number an d percent of samples with analytical det ections and the minimum, median, maximum, and 99th percentile values of those detections. PWS

- level occurrence measures include the number and percent of PWSs with one or more analytical detections and the number and percent of PWSs with two or more analyt ical detections of a given contaminant . Population- served occurrence measures include : the number and percent of population served by PWSs with one or more analytical detections, and the number and percent of population served by PWSs with two or more analytical detections of a given contaminant. Similar measures may also be conducted for each EPTDS for each PWS

. Since these
contaminant and PWS
- level occurrence measures are based on raw occurrence data (that haveDraft ICR for UCMR 4 Proposed Rule November 2015

57 not been adjusted for population-weighting and sampling), they are less accurate representations of national occurrence than occurrence measures based on adjusted occurrence data.

B ased on the findings of the Stage 1 analysis, EPA can select contaminant( s) for which more detailed and sophistic ated 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 PW S mean contaminant concentrations may be
desired

. The Stage 2 analysis uses a Bayesian

- based hierarchical model to estimate the percent (and number) of PWSs with a mean contaminant concentration above any specified

concent ration threshold. The Bayesian

- bas ed Hierarchical Model also provides quantified error of estimation, and enables estimates of mean contaminant concentrations below the minimum reporting level ( MRL ) . This statistical model was used to generate the contaminant occurrence
estimates for 60 re gulated contaminants for the first Six

- Year Review of NPDWRs, an approach
that underwent peer review.

5 (c) Reporting Results

A fter final review and formatting the data collected through this ICR, the data are expected to be made available to the public through the NCOD, as was done with the data collected for

UCMR 1, 2 and 3. Th e analytical results from UCMR 4 monitoring will support regulatory
determinations and, as appropriate, regulation development. For contaminants with significant occurrence and health effects, EPA expects to use the results: to support an exposure assessment; to establish the baseline for health effects and economic analyses; to analyze contaminant co

occurrence; and to evaluate tr eatment technology, 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.Draft ICR for UCMR 4 Proposed Rule August 2015

58 

### APPENDICESDraft ICR for UCMR 4 Proposed Rule August 2015

59 

### APPENDIX A : Relevant Authorities in SDWA 1996 Amendments

S ection 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 w ater 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 kn own 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

presen ts 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 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
Admini strator 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) areDraft ICR for UCMR 4 Proposed Rule August 2015

60 satisfied. Such findings shall be based on the best available public health information, including the occurrenc e 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 dete rmination 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 pub lic 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 Ad ministrator, 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. (D) Urg ent 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 Diseas e 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
meetin g 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 FR , 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 subjec t to any national primary drinking water regulation.Draft ICR for UCMR 4 Proposed Rule August 2015

61 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 o r antici pated adverse effects on the 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 maxi mum contaminant level for such contaminant which is as close to the maximum contaminant level goal as is feasible. (C) Determination

– At the time the Administrator pr oposes 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 unde r paragraph (3)(C). (D) Definition of feasible – For the purposes of this subsection, the term “feasible” means
feasible with the use of the best t echnology, 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 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 gen eral – 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 contamin ant level, but a 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 Admin istrator 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 treatmenttechnique, 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, orDraft ICR for UCMR 4 Proposed Rule August 2015

62 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 Ameri can 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 t echnique 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 t reated. (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 inno vative treatment technologies 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 wa ter 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).

S ection 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 unde r 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 co ntaminants 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, theDraft ICR for UCMR 4 Proposed Rule August 2015

63 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 ye ars 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. (B) MONITORING PROGRAM FOR CERTAIN UNREGULATED CONTAMINANTS (i) INITIAL LIST

– Not la ter 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 p ublic 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) MO NITORING 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 conduct s monitoring of unregulated contaminants pursuant to this paragraph shall provide the results of the monitoring to the primary enforcement authority for the system.Draft ICR for UCMR 4 Proposed Rule August 2015

64 (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
demonstra tes 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.

( i) SCREENING METHODS.

— The Administrator shall review new analytical methods

to scr een for regulated contaminants and may approve such methods as are more accurate or

cost -effective than established reference methods for use in compliance monitoring. [42 U.S.C. 300j– 4]

( g) OCCURRENCE DATA BASE (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 c ontaminants 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 recomm endations 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 A dministrator, 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.Draft ICR for UCMR 4 Proposed Rule August 2015

65 (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 establishe d, 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.Draft ICR for UCMR 4 Proposed Rule July 2015

66 

### APPENDIX B : Burden a nd Cost E xhibits f or t he F ive -Y ear UCMR 4 Period

o f 2017

- 2021

E x hibit B -1a: Yearly Cost to S y stems , by PW S Size a nd by T ype o f C ost ( 2017-2021) (corresponds with Exhibit 11a) Cost Description 20 1 7 20 1 8 20 1 9 20 20 20 21 Total 1
SMALL PWSs (serving 10,000 or fewer people)

Labor Costs Reading and Initial Reporting $0 $57,620 $57,620 $57,620 $0 $172,859

Monitoring $0 $151,440 $151,440 $151,440 $0 $454,321

Reporting of Results $0 $64,150 $64,150 $64,150 $0 $192,450

Non

- Labor Costs (Laboratory Analysis and Shipping (paid for by EPA)) $0 $0 $0 $0 $0 $0.00

Subtotal

– Small PWSs $0 $273,210 $273,210 $273,210 $0 $819,631 LARGE PWSs (serving 10,001 to 100,000 people)

Labor Costs Reading and Initial Reporting $0 $652,904 $652,904 $652,904 $0.00 $1,958,713

Monitoring $0 $938,437 $938,437 $938,437 $0.00 $2,815,310

Reporting of Results $0 $1,059,340 $1,059,340 $1,059,340 $0.00 $3,178,020

Non

- Labor Costs (Laboratory Analysis and Shipping) $0 $23,491,630 $23,491,630 $23,491,630 $0.00 $70,474,889

Subtotal

– Large PWSs $0 $26,142,311 $26,142,311 $26,142,311 $0.00 $78,426,932 VERY LARGE PWSs (serving greater than 100,000 people)

Labor Costs Reading and Initial Reporting $0 $71,47 3 $71,47 3 $71,47 3 $0 $214,41 8

Monitoring $0 $298,629 $298,629 $298,629 $0 $895,887 Reporting of Results $0 $137,903 $137,903 $137,903 $0 $413,710

Non

- Labor Costs (Laboratory Analysis and Shipping) $0 $6,633,274 $6,633,274 $6,633,274 $0 $19,899,821

Subtotal

– Very Large
PWSs $0 $7,141,279 $7,141,279 $7,141,279 $0 $21,423,83 6

ALL PWSs

Total Labor for
All PWSs $0 $3,431,896 $3,431,896 $3,431,896 $0 $10,295,689

Total Non

- Labor for All

PWSs $0 $30,124,903 $30,124,903 $30,124,903 $0 $90,374,7 1 0

Total Labor and Non

Labor for All PWSs $0 $33,556,800 $33,556,800 $33,556,800 $0 $100,670,39 9

1 Totals may not equal the sum of components due to rounding.Draft ICR for UCMR 4 Proposed Rule July 2015

67 Exhibit B

- 1b: Per System (Respondent) and Per Response UCMR 4 Costs ( 2017-2021 ) (corresponds with Exhibit 11b)

Burden / Cost Total over 2017-2021 Annual Average over 2017-2021

Small PWSs Large PWSs Very Large
PWSs Small PWSs Large PWSs Very Large
PWSs

PER RESPONDENT:

Labor Cost $ 512 $ 2,04 7 $ 3,745 $ 10 3 $ 409 $7 49

Non

- Labor Cost $0 $ 18,140 $48, 89 4 $0 .0 $3 ,628 $ 9,77 9

Burden (labor hours) 14.2 56.8 10 4.0 2.8 11. 4 20.8

PER RESPONSE:

Number Responses per Respondent 6. 7 11. 4 14.11 1. 3 2.3 2.8

Labor Cost per Response $7 7 $ 180 $ 265 $1 5 $36 $ 53

Non

- Labor Cost per Response $0 $ 1,59 7 $3,46 4 $0 $3 19 $ 693

Burden (labor hours) per Response 2. 1 5.0 7.4 0. 4 1.0 1. 5

Exhibit B -2a: Yearly Cost and Burden to States for Implementation of UCMR 4 (2017- 2021) 1 (corresponds with Exhibit 13a)

Cost/

Burden 2017 2018 2019 2020 2021 Total 2 Annual Average
Costs to All States for labor related to UCMR implementation and oversight

$876,63 6 $ 535,883 $ 535,883 $ 535,883 $ 32,833 $ 2,517,11 9 $ 503,42 4
Labor burden for all States for UCMR implementation and oversight (number of hours)

1 8,466.2 11,288.3 11,288.3 11,288.3 691.6 5 3,022.8 10,604.6

1 All costs are attributed to labor and are estimated over the period 2017

- 2021

. 2 Totals may not equal sum of components due to rounding.Draft ICR for UCMR 4 Proposed Rule July 2015

68 Exhibit B

- 2b: Per State (Respondent) and Per Response UCMR 4 Costs ( 2017-2021 ) (corresponds with Exhibit 1 3b)

Burden / Cost Total over 2017-2021 Annual Average
over 2017-2021

PER RESPONDENT:

Labor Cost $ 44,94 9 $ 8,99 0

Non

- Labor Cost $0 $0 .00
Burden (labor hours) 9 46.8 189. 4

PER RESPONSE:
Number Responses per Respondent 1 3 .0 1.0 0
Labor Cost per Response $ 8

, 9 90 $ 2

, 997

Non

- Labor Cost per Response $0 $0
Burden (labor hours) per Response 189. 4 63.1

1 States have 1 response per year, since there are no specific cyclical state reporting requirements under the UCMR program.

Ex hibit B -3a: Yearly Cost to EPA for UCMR 4 Implementation, by Type of Cost (2017- 2021) 1 (corresponds with Exhibit 14a)

Cost Description 2017 2018 2019 2020 2021 Total 2 Annual Average

Cost

Regulatory Support Activities : laboratory PT; QC audits; analytical standards provision; and technical support, guidance document development

Lab PT $23 8

, 81 1 $0 $0 $0 $0 $ 238,81 1 $4 7,762

QC Audits $1 8,17 4 $3 6,347 $ 36,347 $ 18,17 4 $0 $10 9,042 $ 21,808
Analytical Standards $119,40 5 $245,975 $253,354 $260,95 5 $0 $8 89,689 $ 175,938
Technical Support $119,40 5 $61,494 $0 $0 $0 $1 80,899 $ 36,18 0

Subtotal

– Regulatory Support $495,79 4 $3 43,817 $ 289,70 2 $ 279,128 $0 $1, 408,44 1 $2 81,688

National and Regional Oversight and Data Analysis : UCMR management oversight; review and evaluation of data from all UCMR monitoring

$905,819 $ 905,819 $ 905,819 $ 905,819 $ 452,9 10 $4,0 76,186 $ 815,237

Small PWS Testing : implementation coordination; and analytical and shipping costs for small PWS testing

Implementation
Coordination $0 $2,336,055 $2,336,055 $2,336,055 $0 $7,008,165 $1,401,633

Fees for Analysis and shipping $0 $ 3,635,893 $3,635,893 $3,635,893 $0 $ 10,907,680 $ 2,181,536

Subtotal

– Small PWS Testing $0 $5,971,948 $5,971,948 $5,971,948 $0 $17,915,845 $3,583,169

TOTAL $1,401,613 $7,221,584 $7,167,469 $7,156,986 $452,910 $23,400,472 $4,680,094

1 Agency costs are estimated over the period 2017

- 2021

. 2 Totals may not equal sum of components due to rounding.Draft ICR for UCMR 4 Proposed Rule July 2015

69 Exhibit B

- 3b: Summary of EPA Burdens and Costs for UCMR 4 Implementation ( 2017-
2021 ) (corresponds with Exhibit 14b)

Burden / Cost Annual Average Cost over Five

- Year UCMR
Period (2017-2021 )

Labor Cost $ 815,237

Non

- Labor Cost $ 3,864,857

Total Cost to EPA for UCMR Implementation $ 4,680,094

Burden (labor hours) 10,296Draft ICR for UCMR 4 Proposed Rule July 2015

70 Exhibit B -4: National Cost Summary for UCMR 4 Implementation (2017-2021 ) (corresponds with Exhibit 15)

Type of Cost 20 17 20 18 20 19 2020 2021 TOTAL 1

Small PWSs

Labor Cost $0 $273,210 $273,210 $273,210 $0 $819,631

Non

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

Total Small PWS
Cost $0 $273,210 $273,210 $273,210 $0 $819,63 1

Large PWSs

Labor Cost $0 $2,650,681 $2,650,681 $2,650,681 $0 $7,952,043

Non

- Labor Cost $0 $23,491,6 30 $23,491,62 30 $23,491,6 30 $0 $70,474,88 9
Total Large PWS
Cost $0 $26,142,31 1 $26,142,31 1 $26,142,31 1 $0 $78,426,932

Very Large PWSs

Labor Cost $0 $508,00 5 $508,00 5 $508,00 5 $0 $ 1,524,015

Non

- Labor Cost $0 $6,633,274 $6,633,274 $6,633,274 $0 $19,899,821
Total Very Large
PWS Cost $0 $7,141,279 $7,141,279 $7,141,279 $0 $21,423,83 6

States

Labor Cost $876,63 6 $535,883 $535,883 $535,883 $32,833 $2,517,11 9

Non

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

Total State Cost $876,63 6 $535,883 $535,883 $535,883 $32,833 $2,517,11 9

EPA

Labor Cost $905,819 $905,819 $905,819 $905,819 $452,910 $4,076,186

Non

- Labor Cost $495,794 $6,315,765 $6,261,650 $6,2 5 1, 077 $0.00 $19,324,286

Total EPA Cost $1,401,613 $7,221,584 $7,167,469 $ 7,156,896 $452,910 $23,400,472

National Total

Total with EPA $2,278,249 $41,314,267 $41,260,152 $41,249,57 9 $485,74 3 $126,587,99 0

Total without EPA $876,63 6 $34,092,68 3 $34,092,68 3 $34,092,68 3 $32,833 $103,187,517
Total Burden (hours) for All Responses 2

Small PWSs 0 .0 7,586. 6 7,586. 6 7 ,586.6 $0 22,759.7
Large PWSs 0. 0 73,604.7 73,604.7 73,604.7 $0 220,814.2
Very Large PWSs 0 .0 14,106.4 14,106.4 14,106.4 $0 42,319.2

States 18,466. 2 11,288.3 11,288.3 11,288.3 691.6 53,022.8

EPA 11,440.0 11,440.0 11,440.0 11,440 .0 5,720.0 51,480.0

Total with EPA 29,906.2 118,026.0 118,026.0 118,026.0 6,411.6 390,395.9

Total without EPA 18,466.2 106,586.0 106,586.0 106,586.0 691.6 338,915.9

1 Totals may not equal the sum of components due to rounding.

2 Although EPA is not considered a respondent to the UCMR, 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 4 Proposed Rule July 2015

71 Exhibit B

- 5: UCMR 4 Per Respondent Burden and Cost Summary ( 2017-2021 ) (corresponds with Exhibit 16)

Burden (hours)/

Cost (dollars) Small
PWSs Large PWSs Very Large
PWSs States EPA National Average
with EPA 1 National Average
without

EPA

Five

- Year Total per Respondent

Total # of Responses Per Respondent 6. 7 11. 4 14.1 5 .0 n/a n/a 10

. 2

Labor Cost Per Respondent $ 512 $ 2,04 7 $ 3,74 5 $ 44,94 9 $ 4,076,186 $ 2,83 9 $ 2,154

Non

- Labor Cost Per Respondent n/a $ 1 8,140 $ 4 8

, 89 4 n/a $ 19,324,28 6 $ 1 8,4 40 $ 15,194

Total Cost (Labor plus Non

Labor) $ 512 $ 20,187 $ 52,638 $ 44,94 9 $ 2 3,400,472 $ 21,27 9 $ 1 7

, 348

Total Cost Per Response $ 7 7 $ 1,777 $ 3,7 30 $ 8,99 0 n/a n/a $ 1,696

Total Burden Per Respondent (hr) 14.2 56.8 10 4

. 0 9 46

. 8 51,480.0 65.6 5 7.0

Total Burden Per Response (hr) 2. 1 11. 4 14.1 18 9

. 4 n/a n/a 5. 6 Average Annual per Respondent

Ave. # of Responses Per Respondent 1.3 2

. 3 2

. 8 1 .0 n/a n/a 2

. 1

Labor Cost Per Respondent $103 $ 409 $ 749 $ 8,9 9 0 $ 815,237 $ 56 8 $ 4 3 1

Non

- Labor Cost Per Respondent n/a $ 3

, 6 28 $ 9,77 9 n/a $ 3, 864,857 $ 3,688 $ 3,03 9
Ave. Cost (Labor plus Non

- Labor) $ 10 3 $ 4,037 $ 10,528 $ 8,99 0 $ 4, 680,095 $ 4,25 6 $ 3

, 4 70

Ave. Cost Per Response $ 1 5 $ 35 6 $ 74 6 $ 1,79 8 n/a n/a $ 339

Ave. Burden Per Respondent (hr) 2

. 8 11

. 4 20.8 18 9

. 4 10,296

. 0 13.1 11.4

Ave. Burden Per Response (hr) 0. 4 2

. 3 2

. 8 3 7

. 9 n/a n/a 1. 1

1 National average burdens and costs differ greatly between the state respondents and the various PWS respondents

. This should be taken into consideration when looking at the national average with or without EPA.