DRAFT Information Collection Request 

for the Unregulated Contaminant 

Monitoring Rule (UCMR 4) 

November 2015 

Prepared by: 

The Cadmus Group, Inc. 

100 5th Ave. 

Waltham, MA 02451 

Prepared 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 2015
Draft 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 ................................................................................ 52
Draft ICR for UCMR 4 Proposed Rule November 2015

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2(b) Sample Design ............................................................................................................ 52

2(c) Precision Requirements .............................................................................................. 54

2(d) Questionnaire 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) Analysis ...................................................................................................................... 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 .. 66
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LIST OF EXHIBITS

Exhibit 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: Implementation 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 Respondent 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) ............................................................................................... 68
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Exhibit B-3a: Yearly Cost to EPA for UCMR 4 Implementation, by Type of Cost 

(2017-2021) 1 (corresponds with Exhibit 14a) ....................................................................... 68

Exhibit B-3b: Summary of EPA Burdens and Costs for UCMR 4 Implementation 

(2017-2021) (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)................................................................................................. 71
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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 Distribution System

FR Federal Register 

FTE Full-Time Equivalent

GC Gas Chromatography

GC/MS Gas Chromatography/Mass Spectrometry

GS General Schedule

GW Ground Water

GWUDI Ground Water Under the Direct Influence of Surface Water

HAAs Haloacetic Acids

HAA5 Dibromoacetic Acid, Dichloroacetic Acid, Monobromoacetic Acid, 

Monochloroacetic Acid, Trichloroacetic Acid

HAA6Br Bromochloroacetic Acid, Bromodichloroacetic Acid, Dibromoacetic Acid, 

Dibromochloroacetic Acid, Monobromoacetic Acid, Tribromoacetic Acid

HAA9 Bromochloroacetic Acid, Bromodichloroacetic Acid, Chlorodibromoacetic 

Acid, Dibromoacetic Acid, Dichloroacetic Acid, Monobromoacetic Acid, 

Monochloroacetic Acid, Tribromoacetic Acid, Trichloroacetic Acid

IC-MS/MS Ion Chromatography/Tandem Mass Spectrometry

ICP-MS Inductively Coupled Plasma Mass Spectrometry

ICR Information Collection Request

LC/MS/MS Liquid Chromatography/Tandem Mass Spectrometry

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 Regulation 
Draft ICR for UCMR 4 Proposed Rule November 2015

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NTNCWS Non-Transient Non-Community Water System

OES Occupational Employment Statistics

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 Monitoring 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 Rule
Draft ICR for UCMR 4 Proposed Rule November 2015

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– PART A OF THE SUPPORTING STATEMENT –

1 IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Number of the Information Collection 

Title: Information Collection Request for UCMR 4

OMB Control Number: 2040-0270

EPA Tracking Number: 2192.07

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 Agency decision making regarding 

whether or not to regulate particular contaminants in drinking water. SDWA requires that EPA 

vary the frequency and schedule for the monitoring program 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 sample of PWSs 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 the 

Federal Register (FR) on September 17, 1999 (64 FR 50556). In addition, EPA published 

several supplemental rules that established analytical methods, and provided 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 UCMRs, while making some changes to the rule 

design. EPA 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 monitoring begins in

2018 and continues through 2020. The applicable three-year period for this particular 

Information Collection Request (ICR) is 2017-2019. The applicable ICR period overlaps with 
Draft ICR for UCMR 4 Proposed Rule November 2015

2

the first three years of the five year UCMR 4 period. Estimates of implementation burden and 

cost over the entire five-year UCMR 4 period (including pre-monitoring activity and postmonitoring reporting) are attached as Appendix B to this ICR. 

As proposed, a total of 1,600 PWSs serving 10,000 or fewer people (hereafter referred to as 

small PWSs), will conduct monitoring: 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. All PWSs serving more than 10,000 people will monitor for

the 30 List 1 chemicals.1 EPA pays for all sample kit preparation, 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 sampling events), and at 6-month intervals for GW systems (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 excluded from cyanotoxin monitoring.

EPA expects that approximately one-third of the PWSs will monitor during each of the three 

monitoring years (2018-2020); approximately two-thirds of the PWSs are expected to monitor 

between 2018-2019. Approximately one-third of the PWSs will monitor during the second 

(renewal) UCMR 4 ICR period of 2020-2021.

Respondents to UCMR 4 include 1,600 small PWSs (800 for cyanotoxins monitoring and 800

for monitoring of the 20 additional chemicals), 4,292 large and very large PWSs, and 56 states 

and primacy agencies (referred to collectively as “states” for simplicity), for a total of 5,948

respondents. The frequency of response varies across respondents and years. 

Small PWSs selected for UCMR 4 monitoring 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 

response for small PWSs is 2.8 hours. Large PWSs and very large PWSs sample 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 for large and very large PWSs, 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 2015

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States incur only labor costs associated with UCMR 4 implementation. State activities are 

determined through individual Partnership Agreements (PAs) with EPA. EPA assumed that state 

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 PWSs, with 

an average burden per response of 366.5 hours. In aggregate, during the ICR period, the average 

response (i.e., responses from PWSs and states) 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 PWSs –

6.2 hours burden at $171 for labor; large PWSs – 23.3 hours at $682 for labor, and $6,047 for 

analytical costs; very large PWSs – 46.5 hours at $1,248 for labor, and $16,298 for analytical 

costs; and states – 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. 

The annual burden to EPA for UCMR 4 program activities during the ICR years is 11,440 hours, 

at an annual labor cost of $905,819. EPA's annual non-labor costs are $4.4 million. EPA's nonlabor costs are primarily attributed to the cost of sample analysis for small PWSs (sample 

analysis represents approximately 91% of non-labor cost).
Draft ICR for UCMR 4 Proposed Rule November 2015

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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 nationally representative 

sample of PWSs serving 10,000 or fewer people are required to monitor. EPA must vary the 

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

supply and the contaminants likely to be found. 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 amended 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 the 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 

groups (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 supports the Administrator's determination of whether to regulate a 

contaminant through the Regulatory Determination process and, as appropriate, regulation 

development. If the contaminant has significant occurrence and health effects, EPA uses the 

results to: support an exposure assessment; establish the baseline for health effects and economic 

analyses; analyze contaminant co-occurrence; and evaluate treatment technologies, including 

contaminant source management. The results can suggest that contaminant occurrence is

significant enough to initiate research on health effects and treatment technologies. Finally, the 

data can guide future source water protection efforts.

Each PWS maintains records of the analytical results of this monitoring. EPA-approved 

laboratories 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 state and EPA, via the 
Draft ICR for UCMR 4 Proposed Rule November 2015

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electronic reporting system. The data collected through the UCMR program 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 agencies, which include state regulators, Indian tribes, and, in some 

instances, EPA regional 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 Forces.

• American Water Works Association.

• Association of Metropolitan Water Agencies.

• National Rural Water Association.

• National Association of Water Companies.

• Association of State Drinking Water Administrators (ASDWA).

• Natural Resources Defense Council.

• Consumers Federation of America.

• Small Business Administration (SBA).

• Other environmental and industry groups.

• News organizations.

• Private industries.

• Individuals.
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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 stepwise risk-based approach for determining which contaminants would become 

subject to drinking water standards. The first step is the requirement 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 to 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 

is the requirement for EPA to determine, every five years, whether or not at least five

contaminants 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 has 

determined should be regulated. 

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

complementary programs. The CCL process identifies 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. The 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 Required Prior to ICR Submission to OMB 

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

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

the provided burden estimates, and any suggested 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-2015-0218. 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 2015

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3(c) Consultations 

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

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

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

comments concerning the development of the UCMR program include PWSs, states, industry, 

and other organizations. Seventeen 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. Stakeholder meeting feedback and 

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 Regulatory 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, environmental 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 the 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, the 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 could still allow the 

Agency 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 development 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 frequency design also considers that the 

number of people served affects exposure to contaminants and considers resources available to 

undertake monitoring activity. The collection frequencies in this rule are discussed further in 
Draft ICR for UCMR 4 Proposed Rule November 2015

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section 5(b), part A of this ICR document. Monitoring frequencies have been carefully devised

based on the following factors:

• Data quality needed for a representative sample;

• Precision and accuracy needed from the representative sample;

• Number of people served by the PWS;

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

• Likelihood of finding contaminants; and

• Temporal 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 this ICR 

document. 

EPA used the statistical design established under UCMR 1 for its UCMR 4 national 

representative sample of small PWSs (800 PWSs for cyanotoxins, and 800 different PWSs for 20 

additional List 1 chemicals) and census of large PWSs for Assessment Monitoring. EPA 

determined that the combination of a nationally representative sample of small PWSs and a 

census of large PWSs 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 PWSs provides a confidence level of 99% with an allowable error 

of ±1%. The set of representative PWSs are distributed among different size categories, but 

weighted by population served, to ensure that the sample can provide estimates of exposure.

EPA 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 PWSs 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. 

The 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 considered 

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. Even a 

small percentage of PWSs with detections can translate into a significant population affected. 

With a greater margin of error, and the resultant smaller sample size, such occurrence could be 

missed entirely. EPA made some judgments about the occurrence of contaminants in relation to 

source waters and different PWS size categories. Many statutes and current regulations 

differentiate implementation requirements based on PWS size or water source. While combining 

sampling results from the representative sample of small PWSs with that from all large PWSs 

provides increased statistical power in the total sample, EPA must be able to evaluate 

occurrence, and possible regulatory options, related to the small PWSs. SDWA and many current 

rules focus on burden reduction for small PWSs when feasible. There are many other 
Draft ICR for UCMR 4 Proposed Rule November 2015

9

uncertainties and sources of variance in such a sample program. For example, all contaminants 

have censored distributions (i.e., “less than detection level” analytical results) and there are a 

myriad of factors that affect variability and vulnerability of GW PWSs. It remains unclear how 

normal sampling theory accommodates these factors. The high confidence level, low allowable 

error, and larger sample size helps to ensure adequate data to meet the objectives of the UCMR 

program. 

UCMR includes a provision for waivers for large PWSs on a state-wide, chemical-specific basis

because some contaminants may not occur in a particular state. Waivers 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 

representative sample must provide adequate information on the presence and absence of 

contaminants for the PWSs sampled. Since EPA pays for this testing, there is no significant 

burden on small PWSs. 

3(e) General Guidelines 

This ICR was completed in accordance with the November 2009 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 respondents. This 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 request.

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

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

tax records, for more than three years.

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

generalized to the universe of the study.

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

OMB.

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

in statute or regulation, that is not supported by disclosure and data security 
Draft ICR for UCMR 4 Proposed Rule November 2015

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 

outlined in this ICR.
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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. States, territories, 

and tribes with primacy to administer the regulatory program for PWSs under 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 221310. The NAICS code for municipal 

PWS operators and state agencies that include drinking water programs is 924110 

(Administration of Air and Water Resources and Solid 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 PWSs is found in section 4(b)(i)(a), Part A of this ICR document. The 

requirements for states 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 (CFR) 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 .
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One Cyanotoxin Group .

 total microcystins .

Two Metals .

 germanium manganese

Nine Pesticides .

alpha-hexachlorocyclohexane profenofos

chlorpyrifos tebuconazole

 dimethipin total permethrin (cis- & trans-) 

 ethoprop tribufos

 oxyfluorfen .

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 .

The required data elements are listed in Exhibit 2. All PWSs must electronically report all 26 

data elements with their Assessment Monitoring samples. All PWSs 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

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Exhibit 2: UCMR 4 Proposed Reporting Requirements

1. Public Water System Identification (PWSID) Code 14. Sample Identification Code

2. PWS Name 15. Contaminant

3. PWS Facility Identification Code 16. Analytical Method Code

4. PWS Facility Name 17. Extraction Batch Identification Code

5. PWS Facility Type 18. Extraction Date

6. Water Source Type 19. Analysis Batch ID

7. Sampling Point Identification Code 20. Analysis Date

8. Sampling Point Name 21. Sample Analysis Type

9. Sampling Point Type Code 22. Analytical Results – Sign

10. Disinfectant Type (primary disinfectants) 23. Analytical Result – Measured Value

11.Treatment Information (includes basic treatment 

information) 

24. Additional Value

12. Disinfectant Residual Type (secondary disinfectant

residual type added in distribution system) 

25. Laboratory Identification Code

13. Sample Collection Date 26. Sample Event Code

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

UCMR 4 is a direct implementation rule; therefore states would not be required to report to EPA. 

Implementation activities for each state would be identified and determined through PAs with 

EPA. If participating in a PA, states would voluntarily review and revise Initial State Monitoring 

Plans (SMPs), notify PWSs of their UCMR responsibilities, and provide EPA with a list of the 

PWSs notified. These state activities would be completed in 2017. Because states have no 

specified reporting cycle, this analysis assumes that states 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 

Respondents include both PWSs and states. PWS and state 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

To comply with the requirements in this regulation, PWSs would conduct the following 

activities:

• Read regulations and/or letter from state or EPA which outline requirements;

• Monitor or provide monitoring assistance (e.g., sample collection and shipping);
Draft ICR for UCMR 4 Proposed Rule November 2015

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• Report and maintain records; and 

• Report 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 state-issued guidance letter during the year in which their monitoring occurs. 

Small PWSs can rely on summarized information from the state or EPA for information 

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 for 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 entry point to the 

distribution system (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 water intake (concurrent 

with HAA sampling in the distribution system). 

Large GW PWSs 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 

state. 

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

• Reporting Prior to MonitoringContact and zip code information: Large PWSs would be required to report 

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

mailing address, phone number and email address for the PWS Technical Contact 
Draft 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. 

Sampling 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 Name; PWS Facility Identification Code; PWS Facility Name; PWS 

Facility Type, Water Source Type; Sampling Point Identification Code; Sampling 

Point Name; and Sampling Point Type Code. 

Representative sampling plan proposal: Some PWSs 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 PWSs 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 producing and more consistently active wells in the representative array. 

If that representative well is not in use at the scheduled sampling time, an 

alternative representative well must be sampled.

Representative Intakes from Wholesaler: PWSs that purchase water 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 selected as the representative EPTDS is not available for sampling, an 

alternate representative connection would be sampled. 

• Reporting Monitoring Results

Small PWSs: Small PWSs would only be required to record PWS and sample

location information on the sampling forms and bottles that are sent to them by
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the UCMR Sampling Coordinator. The schedule for submitting this information is 

specified in the instructions sent to the PWS. 

Large PWSs: Laboratories would post the analytical results and associated data 

elements to EPA’s electronic data reporting system within 120 days of sample 

collection. Large PWSs must ensure that their laboratory meets this requirement, 

and those PWSs must review, approve, and submit the data to the state 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. 

• Record Keeping

Section 141.33 requires PWSs to maintain records of chemical monitoring data

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

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

UCMR program to be made available to those served by the 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 PWSs (CWSs, non-transient non-community water systems (NTNCWSs) and 

transient 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 

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

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

Agencies”). That model was designed by EPA in coordination with Association of State 

Drinking Water Administrators (ASDWA) and required specific input for a list of activities and 

variables related to state operation of the UCMR drinking water program (e.g., number of PWSs 

affected, estimates of violation rates, etc.). Since that time, ASDWA updated and improved the 

previous 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 2013), 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 assumed that state participation would closely reflect that which 
Draft 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 state participation. 

Since UCMR is a direct implementation rule, specifics of each state’s role would be delineated in 

PAs between the states and EPA. State activities include coordination, data management and 

support, program implementation and training/overhead. Though some states may choose to 

conduct sampling for their PWSs, this activity is not part 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. 

State Coordination 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. 

Review of SMPs would be one of the first UCMR activities to take place at the state level. Each 

state would receive a proposed initial SMP from EPA, which lists all PWSs that would be 

required to conduct Assessment Monitoring, 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 states to select from, for those PWSs that may not have been correctly specified in the 

initial plan. If a state identifies PWSs on the original proposed SMP that it determines are not 

appropriate for the representative GW sampling locations (e.g., if PWSs are inactive, or sell all 

of their water and do not have their own retail customers), the state could propose an alternative 

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

SMPs would also specify the year and months during which PWSs would monitor. States would 

be given the option to modify these schedules. 

EPA assumed that some 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. 

EPA also recognized that it would be necessary for states to maintain ongoing communications 

with EPA regarding UCMR requirements. For example, states 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. 

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

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

accommodate the revised UCMR data elements. Activities likely include data entry/downloading 

of data and general record keeping. 
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Program Implementation: Program implementation activities for each state can include 

notification and guidance letter to PWSs, data review, ongoing PWS support and enforcement. 

Following review and finalization of SMPs, participating states would prepare a notification 

letter that described PWS monitoring schedules and requirements under the regulation. These 

states would send notification to each applicable PWS and send the list of these notified PWSs to 

EPA. EPA assumed that PWSs would periodically call states 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.

State Staff Training and Overhead: EPA assumed that technical staff members would participate 

in training to assist them in understanding the regulation, their roles and responsibilities, and to 

allow the state to better provide technical assistance to PWSs. General 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

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5 INFORMATION COLLECTED–AGENCY ACTIVITIES, 

COLLECTION METHODOLOGY AND INFORMATION 

MANAGEMENT

5(a) Agency Activities 

EPA Headquarters and regional offices are responsible for oversight of state PWS programs and 

processing and analysis of UCMR data. EPA implementation activities are categorized into three 

major categories: regulatory support activities; program oversight and data analysis; and small 

PWS testing program, which are described in 5(a)(i)-(iii).

5(a)(i) Regulatory Support Activities 

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

(QA/QC); and technical support to PWSs, such as guidance documents. 

Laboratory Approval and QA/QC Activities: EPA incurs various costs related to laboratory 

approval and laboratory quality assurance and control, including the following activities: 

• Laboratory approval/Proficiency Testing (PT) program - EPA would assess

whether laboratories meet the required equipment, laboratory performance 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).

• Analytical standards provision and coordination - EPA coordinates and

distributes specialized analytical standards to participating laboratories.

Technical Support/Guidance Document Development: EPA expects to develop and distribute 

guidance for laboratory calculations and background information about the health effects (e.g., 

fact sheets) of UCMR 4 contaminants. EPA expects to provide technical support during 2018 

and 2019. 
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5(a)(ii) National and Regional Oversight/Data Analysis 

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

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

be conducted by EPA Headquarters or its regional offices. Exhibit 3 illustrates the proposed 

timeline for UCMR implementation activities. EPA expects to develop its PAs with states and 

the SMPs prior to 2018, when monitoring would begin. 

Exhibit 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 

All large systems serving more than 10,000 people; 

800 small 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 Agency 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. 

During the ICR period, EPA would pay for the sample kit preparation, sample shipping fees and 

analysis costs. 

5(b) Information Collection Methodology and Management 

Laboratories report analytical results and associated data elements to EPA’s electronic data 

reporting system. Large PWSs 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, 

laboratories have 120 days from sample collection to report analytical results and required data 

elements. PWSs 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 

reduces 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 includes checks for anomalies in the data that may 

be related to data entry or laboratory errors. Data quality review and analysis includes: 

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

5(c) Small Entity Flexibility 

Note: The following Small Business Regulatory Enforcement Fairness Act analysis 

summary is the same as that provided in the preamble to the 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 certify 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 Consumer 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

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

is further described as follows. EPA analyzed the impacts for privately-owned and publiclyowned water systems separately, due to the different economic characteristics of these ownership 

types, such as different rate structures 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 Survey 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 Total1

Ground Water

500 and under 21 64 85

501 to 3,300 161 62 223

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 basis 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. 
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Exhibit 5: Implementation of UCMR 4 at Small Systems

Cost 

Description 2017 2018 2019 2020 2021 Total1

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 Timeline2

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.

PWS 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 96% 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

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Exhibit 6: UCMR 4 Relative Cost Analysis for Small Publicly-Owned Systems (2017-2021) 

System Size

(# of people 

served)

Annual Number 

of Systems 

Impacted1

Average Annual 

Hours per 

System (2017-

2021)

Average Annual 

Cost per System 

(2017-2021) 

Revenue Test2

Ground Water Systems

500 and under 4 1.6 $59 0.16%

501 to 3,300 32 1.7 $63 0.04%

3,301 to 10,000 36 1.9 $67 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 Privately-Owned Systems (2017-2021) 

System Size

(# of people 

served)

Annual Number 

of Systems 

Impacted1

Average Annual 

Hours per 

System (2017-

2021)

Average Annual 

Cost per System 

(2017-2021) 

Revenue Test2

Ground Water Systems

500 and under 13 1.6 $59 0.81%

501 to 3,300 12 1.7 $63 0.05%

3,301 to 10,000 8 1.9 $67 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

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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.

The 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. 

Although 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. 

We 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 

Public 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 sampling events), and at 6-month intervals for GW systems (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. 

The 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 the months of December, January or February, except for resampling 

purposes. 

Sample 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 intake 
Draft ICR for UCMR 4 Proposed Rule November 2015

26

samples (collected 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 micrograms 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 with total 

microcystin sampling).

This 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. 

HAA 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. 

EPA proposes that PWSs monitor for HAAs only in the distribution system. If the system's 

treatment plant/water source is subject to sampling 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 samples 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 samples.

For 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 water 
Draft 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 water sample location(s) for UCMR.

With 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. 

Large system schedules (year and months of monitoring) would initially be determined by EPA 

in conjunction with the states; 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 during the scheduled month of monitoring, etc.). EPA proposes to 

schedule and coordinate small system monitoring, working closely with partnering states. SMPs 

provide an opportunity for states to review and revise the initial sampling schedules that EPA 

proposes. 

UCMR 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

This 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 states are shown in 

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

of this ICR document). 

The body of this ICR focuses only on the cost of the UCMR data collection over the years 2017-

2019. Cost tables that are presented in this section have analogous tables in Appendix B, which 

present costs for the entire monitoring period (2017-2021). 

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

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

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

costs. The majority of costs are directly attributed to the fees for laboratory analytical services. 

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

the development of various drinking water program rule ICRs, EPA developed a consistent set of 

assumptions to use in calculations. These have been developed and utilized in other drinking 

water program evaluations. Pertinent to the UCMR ICR are the standard assumptions for labor 

rates, PWS inventory numbers (the number of PWSs in the various size categories by primary 

water source), the number 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 PWSs 

Specific 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.

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

• Inventory 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 Volume II: Detailed Tables and Survey Methodology

(http://water.epa.gov/infrastructure/drinkingwater/pws/upload/cwssreportvolumeI

I2006.pdf).

• DSMRT Data: The number of DSMRT samples per PWS is based on the number

of samples required to be collected for the Stage 2 DBPR. The Stage 2 DBPR and
Draft 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 collect 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 those 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 

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

Characterization). The UCMR program affects approximately 5,892 PWSs, roughly two-thirds 

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 timeline in which the PWS

monitoring activities take place.

While developing the cost estimates for UCMR 3, some 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. All PWS burden estimates 

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 average 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 state.
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 Systems1

25 – 10,000 800 randomly selected SW or 

GWUDI systems

800 randomly selected SW, 

GWUDI and GW systems 1,600

Large Systems2

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

1Total 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 chemicals, as would the large 

GW systems. 

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

UCMR 4 – 2017 – 2021 

2017 2018 2019 2020 2021 

Designated ICR Years

No UCMR 

Monitoring 

Activity

Assessment Monitoring1

No UCMR 

Monitoring 

~ 1/3 of PWSs sample ~ 1/3 of PWSs sample ~ 1/3 of PWSs sample Activity

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

• All Assessment Monitoring PWSs would conduct sampling evenly across March 2018-November 2020 (i.e., one-third

in each of the three consecutive periods). 

• Approximately two-thirds of PWSs would conduct monitoring in the current ICR years of 2018 and 2019, and

approximately one-third of PWSs would conduct monitoring during the ICR years of 2020-2022. 

The 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. 

Hourly 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 

local 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 

EPA assumed that PWSs read the regulations and/or a state-issued guidance letter during the 

year in which PWSs monitor. Approximately two-thirds of PWSs would therefore read the 

regulations or a state-issued guidance letter in 2018 and 2019. Small PWSs can rely on the state 

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 assumed 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 PWSs affected. Small 

PWSs would only be selected to monitor for the 10 cyanotoxins or the 20 additional Assessment 

Monitoring chemicals. Each 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 cost estimate. 

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

Exhibit 9 provides an illustration of the timeline for PWS sampling activity. For Assessment 

Monitoring, EPA assumed that each PWS would incur an estimated burden of 0.5 hours per 

sampling point to collect samples 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

The 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). This estimate 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 this cost savings has not been factored into the cost estimates, the sampling costs are 

conservative. 

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

PWSs would be required to report specific information prior to monitoring, and would be 

required to report some information with their monitoring results. 

• Reporting Prior to Monitoring: As with the reading burden (described above, in

Section 6(a)(i)(a)), all initial reporting prior to UCMR 4 monitoring (including

proposals for representative EPTDSs) would be completed in 2017.

Small PWSs: EPA assumed 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.

Large SW (and GWUDI) PWSs: EPA assumed that large SW and GWUDI PWSs

would send contact and sampling point information prior to monitoring. EPA

allotted a one-time reporting burden of six hours.

Large GW PWSs: EPA assumed 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 sampling locations proposals.

Since it was unlikely that all PWSs would submit these proposals, EPA

conservatively assumed that half of GW PWSs serving 10,001 to 100,000 people

would compile and submit this proposal; EPA assumed 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

Small 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, while

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.

Large PWSs: Large PWSs are expected to review, approve, and submit the data to

the state and EPA via the EPA electronic reporting system. EPA assumed it would

take these PWSs two hours per sampling period for data review and submission.

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

PWSs are required to notify their consumers of the detection of any unregulated contaminants. 

CWSs must report UCMR monitoring results in CCRs (63 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 

Under UCMR, small PWSs only incur labor 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).

Thus, 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. 

The most significant cost associated with the implementation of UCMR is the cost of laboratory

services for sample analysis. Estimates of laboratory analytical costs associated with the analysis 

of each sample are presented in this section. UCMR 4 sampling and analysis does not coincide 

with other compliance monitoring. EPA estimates are based on consultations 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. Samples 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. 

To 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 intake 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 for 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. 

Exhibit 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 

Spectrometry (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 $2,562

1 The average analytical cost for Assessment Monitoring was determined by averaging estimates provided by three drinking water 

laboratories. 

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)). 

The UCMR 4 proposal specifies that some samples be collected at EPTDSs. Some large PWSs 

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 regarding representative sample points; 

and receive approval from EPA or the state. 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 PWSs, 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. 

PWSs 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 made, 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

Total laboratory and shipping fees were estimated per required sampling location, per sampling 

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 PWSs 

Exhibit 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.

The 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 the 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. Analogous information for the 

five-year implementation period is provided in Exhibit B-1b, in Appendix B. “Response” is 

defined as each required reporting event for a PWS. All labor and non-labor costs associated 

with 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

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Exhibit 11a: Yearly Cost to Systems, by PWS Size and by Type of Cost 

(2017-2019) (corresponds with Exhibit B-1a)

Cost Description 2017 2018 2019 Total1

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

Labor Costs

Reading and Initial Reporting $0 $57,620 $57,620 $115,240

Monitoring $0 $151,440 $151,440 $302,881

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 $546,421

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

Labor Costs

Reading and Initial Reporting $0 $652,904 $652,904 $1,305,809

Monitoring $0 $938,437 $938,437 $1,876,874

Reporting of Results $0 $1,059,340 $1,059,340 $2,118,680

Non-Labor Costs (Laboratory 

Analysis and Shipping) $0 $23,491,630 $23,491,630 $46,983,259

Subtotal – Large PWSs $0 $26,142,311 $26,142,311 $52,284,621

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

Labor Costs

Reading and Initial Reporting $0 $71,473 $71,473 $142,945

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

Reporting of Results $0 $137,903 $137,903 $275,807

Non-Labor Costs (Laboratory 

Analysis and Shipping) $0 $6,633,274 $6,633,274 $13,266,547

Subtotal – Very Large PWSs $0 $7,141,279 $7,141,279 $14,282,557

ALL PWSs

Total Labor for All Systems $0 $3,431,896 $3,431,896 $6,863,793

Total Non-Labor for All 

Systems $0 $30,124,903 $30,124,903 $60,249,807

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

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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 

Since the UCMR is a direct implementation rule, individual state 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 states are involved in a variety of UCMR 

implementation and oversight activities but have few defined responses, burden estimates are 

based on yearly activities. Thus, for “per response” estimates, states have an average of 1.0 

response per year. 

EPA 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 water program needs for Congress. 

EPA 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

• One 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.

• States would need one supervisor per seven technical FTEs, and one support staff for

every 20 technical FTEs.

• Wage 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

state labor rate of $29 was multiplied by a loading rate of 1.6 to account for benefits. The

wage rate was then escalated to 2014 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.bls.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 Specialists, 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 state resource needs for different aspects of the Phase II/V and nitrate 

regulations. EPA needed to isolate the UCMR costs from the aggregated costs. Based on 

professional judgment regarding the relative magnitude of the UCMR program, EPA assumed 

that: 

• ASDWA'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 actions; and data entry/ recordkeeping

/reporting to EPA. ASDWA also included hours for running a waiver program. The

estimates also assumed 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. States were given 10.75 hours 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 (2017 and

2021), when there are no monitoring activities, UCMR represents 1% of the bundled

program resource needs (although the costs for 2020 and 2021 are not relevant to the
Draft ICR for UCMR 4 Proposed Rule November 2015

40

current ICR estimations); during the three years when monitoring is conducted, UCMR 

represents 3% of the bundled program resource 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 states would use this 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 need 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 assistance with estimates 

ranging from .67 hours per PWS to two hours per PWS, based on population served. For 

UCMR 4, states were given one hour per PWS for technical assistance for all three 

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 per technical FTE for three new rules. 

ASDWA assumed that training would include one day of classroom training per technical 

FTE and three hours per technical FTE for follow-up questions; reading rule; and 

discussions. EPA assumed that training will occur only in the first year, and that 3.67 

hours per FTE for training would be needed for UCMR 4.

Some of the state labor estimates depend on the size of the state. Exhibit 12 shows the number of 

states in each size category. EPA further refined the labor burden estimates by taking the level of 

state participation under UCMR 3 into consideration. EPA reviewed key areas of state 

participation under UCMR 3 including: review and revision to the SMPs; assisting EPA with 

updates to information for large PWSs; two separate sets of PWS notifications; and compliance 

assistance. Based on prior UCMR activities, 80 percent of states typically participated in their 

optional UCMR activities. Burden estimates generated from the ASDWA estimates were 

multiplied by this “percent participation in UCMR 3” to approximate state costs at expected 

participation levels under UCMR 4. 
Draft ICR for UCMR 4 Proposed Rule November 2015

41

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

Size Category Number of States

Very Small 10

Small 11

Medium 23

Large 10

Very Large 2

Total 56

EPA estimates that the average annual burden over the three ICR years (2017-2019) for 56 states 

to implement UCMR is 13,681 hours (or 244 hours per state per year), with an average annual 

cost of $649,467 (or $11,598 per state per year). See Exhibits 13a 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). 

Exhibit 13a: Yearly Cost and Burden to States for Implementation of UCMR 4 (2017-

2019)1 (corresponds with Exhibit B-2a)

Cost/Burden 2017 2018 2019 Total2 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.

Exhibit 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 Respondent1 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 state reporting requirements under the UCMR program. 
Draft ICR for UCMR 4 Proposed Rule November 2015

42

6(c) Estimating Agency Burden and Cost 

EPA incurs burden and costs related to UCMR implementation activities, including: regulatory 

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 government general schedule (GS) 

pay scale; assuming a labor level of GS 13, step 5, and taken from the Maryland/District of 

Columbia rate schedule during the last quarter of 2014 (see the U.S. Office of Personnel 

Management website: www.opm.gov). With these assumptions, labor and contractor rates were 

based on a 2,080 hour work year, with a $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 burden estimates are presented in Exhibits 14a and 14b, respectively. 

6(c)(i) Regulatory Support Activities 

Regulatory support activities include the labor and non-labor costs for laboratory approval 

process and QA/QC activities; and general technical support and guidance documents. Cost and 

burden assumptions for these activities are as follows: 

Laboratory Approvals and QA/QC Activities: EPA incurs various labor or contractor 

costs related to the laboratory PT/approvals; laboratory QA/QC; and provision of 

analytical standards, as follows: 

• The laboratory approval (PT program) is estimated to cost EPA $238,811 prior to 

the beginning of monitoring, in 2017. Cost estimates were based on costs realized 

by the Agency 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. These costs are also included in Appendix B.

• QC Audits of contract laboratories occurs 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 two 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 meals rate from the 2015 federal 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 for 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 2015

43

• EPA estimated that analytical standards 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 Agency for prior similar activities. 

Technical Support/Guidance Document Development: These activities cost EPA 

approximately $180,899 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 pertinent guidance related to UCMR 4 implementation. 

These activities would take place in 2017 and 2018. These costs are included in 

Appendix B, which presents costs for the entire UCMR 4 period. Cost estimates were

based on costs realized by the Agency 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 states with UCMR implementation. During the core period of 

UCMR 4 activity, EPA estimated 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 Agency (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 provides 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 $425

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 fees 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 incurs 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 year) 

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 14a; average annual labor and non-labor costs, as 
Draft ICR for UCMR 4 Proposed Rule November 2015

44

well as small PWS testing program costs are shown in Exhibit 14b. Appendix B, Exhibits B-3a 

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

Exhibit 14a: Yearly Cost to EPA for UCMR Implementation, by Type of Cost (2017-2019)1

(corresponds with Exhibit B-3a)

Cost Description 2017 2018 2019 Total2

Annual 

Average

Regulatory Support Activities: laboratory PT; QC audits; analytical standards provision; and technical 

support, guidance document development

Lab PT $238,811 $0.00 $0.00 $238,811 $79,604

QC Audits $18,174 $36,347 $36,347 $90,868 $30,290

Analytical Standards $119,405 $245,975 $253,354 $618,734 $206,245

Technical Support $119,405 $61,494 $0 $180,899 $60,300

Subtotal –

Regulatory Support $495,794 $343,817 $289,702 $1,129,312 $376,438

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 $2,717,458 $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 $3,981,299

TOTAL $1,401,613 $7,221,584 $7,167,469 $15,790,667 $5,263,556

1 Agency costs were 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 14b: 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 2017-20191

Labor Cost $905,819

Non-Labor Cost $4,357,736

Total Cost to EPA for UCMR Implementation $5,263,556

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

Section 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 Exhibit 9 presents the 

timeline 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). 

Exhibit 15 summarizes national 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 states over the three-year ICR period is 41,043 hours, with a 

labor cost of $1.9 million. EPA anticipates that states 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. 

Exhibit 15: UCMR 4 National Cost Summary for the ICR period (2017-2019) (corresponds 

with Exhibit B-4)

Type of Cost 2017 2018 2019 TOTAL1

Annual 

Average

Small PWSs

Labor Cost $0 $273,210 $273,210 $546,421 $182,140

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

Total Small PWS Cost $0 $273,210 $273,210 $546,421 $182,140
Draft ICR for UCMR 4 Proposed Rule November 2015

46

Type of Cost 2017 2018 2019 TOTAL1

Annual 

Average

Large PWSs

Labor Cost $0 $2,650,681 $2,650,681 $5,301,362 $1,767,121

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

Total Large PWS Cost $0 $26,142,311 $26,14,311 $52,284,621 $17,428,207

Very Large PWSs

Labor Cost $0 $508,005 $508,005 $1,016,010 $338,670

Non-Labor Cost $0 $6,633,274 $6,633,274 $13,266,547 $4,422,183

Total Very Large 

PWS Cost $0 $7,141,279 $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 State 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 $5,263,556

National Total 

Total with EPA $2,278,249 $41,314,267 $41,260,152 $84,852,668 $28,284,223

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 PWSs 0.0 7,586.6 7,586.6 15,173.1 5,057.7

Large PWSs 0.0 73,604.7 73,604.7 147,209.5 49,069.8

Very Large PWSs 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 13,6811.0

EPA 11,440.0 11,440.0 11,440.0 34,320.0 11,440.0

Total with EPA 29,906.2 118,026.0 118,026.0 265,958.3 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 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.

6(e) Reasons for Change in Burden 

This 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 program 
Draft 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/Radionuclides ICR. However, the UCMR 2 and UCMR 3 ICRs were developed 

and tracked separately from the Chemical/Radionuclides ICR, because the 

Chemical/Radionuclides 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 ICRs, this action 

and subsequent ICRs will be developed and tracked separately. The reasons that respondents to 

this ICR incur a different burden than those responding to the previous UCMR ICRs include: 

• UCMR 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 Assurance (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 these 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

Small 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 sample 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 to coordination with EPA and PWSs, 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 states) is associated with a burden of 6.9 hours, with a labor plus nonlabor cost of $1,705 per response. 

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

costs; and states – 244.3 hours at $11,598 for labor. Annual average burden and cost per 

respondent (including PWSs and states) 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

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

Exhibit 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.

Exhibit 16: 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 EPA1

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 $512 $2,047 $3,745 $34,793 $2,717,458 $2,893 $2,212

Non-Labor Cost 

Per Respondent $0 $18,140 $48,894 $0 $13,073,209 $18,400 $15,123

Total Cost 

(Labor plus NonLabor) $512 $20,187 $52,638 $34,7923 $15,790,667 $21,293 $17,335

Total Cost Per 

Response $77 $1,777 $3,728 $17,396 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 9.9 366.5 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 $171 $682 $1,248 $11,598 $905,819 $964 $737

Non-Labor Cost 

Per Respondent $0 $6,047 $16,298 $0 $4,357,736 $6,133 $5,041

Ave. Cost (Labor 

plus Non-Labor) $171 $6,729 $17,546 $11,598 $5,263,556 $7,098 $5,778
Draft 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 EPA1

National 

Average 

without 

EPA

Average Annual per Respondent (cont)

Ave. Cost Per 

Response $26 $592 $1,243 $5,799 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 state respondents and the various PWS respondents. This should 

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

Burden means the total time, effort, or financial resources expended by persons to generate, 

maintain, retain, or disclose or provide information to or for a federal agency. This includes the 

time needed to: review instructions; develop, acquire, install, and utilize technology and systems 

for the purposes of collecting, validating, and verifying information, processing and maintaining 

information, and disclosing and providing information; adjust the existing ways to comply with 

any previously applicable instructions and requirements; train personnel to be able to respond to 

a collection of information; search data sources; complete and review the collection of 

information; and transmit or otherwise disclose the information. An agency may not conduct or 

sponsor, and a person is not required to respond to, a collection of information unless it displays 

a currently valid OMB control number. The OMB control numbers for EPA's regulations are 

listed in 40 CFR part 9 and 48 CFR chapter 15. 

To comment on 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 Number EPAHQ-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. This 

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 this 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: Desk Officer for EPA. Please 
Draft 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

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– PART B OF THE SUPPORTING STATEMENT –

1 SURVEY OBJECTIVES, KEY VARIABLES, AND OTHER 

PRELIMINARIES

1(a) Survey Objectives 

The primary objective of the statistical methods applied in this information collection is for EPA 

to identify and select a sample of PWSs that is representative of PWSs nationwide. The selected 

sample of PWSs 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 

Key variables associated with selecting a nationally representative sample of PWSs include: 

PWS size, source water type and geographical location.

1(c) Statistical Approach 

Section 1445(a)(2) of SDWA (as amended in 1996) requires that the UCMR program include 

only a representative sample of 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 

EPA anticipates that the survey (the statistical sample) objectives are achievable given the 

existing time and resource constraints. 

• High PWS response/participation rates (>95%) during UCMR 1 and UCMR 2 (and, thus

far, in UCMR 3) give EPA confidence that equivalent or better participation rates can be

achieved during UCMR 4.
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• 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 UCMR 4

monitoring incur only a few hours of labor burden. EPA pays 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 

PWSs are the target population for UCMR monitoring. All PWSs that serve more than 10,000 

retail customers are subject to the Assessment Monitoring component of UCMR 4 monitoring. 

Eligible small PWSs (serving 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 are only selected to 

monitor for one component of UCMR 4 List 1 Assessment Monitoring. 

2(b) Sample Design 

2(b)(i) Sampling Frame 

EPA developed the sample frame for the statistical selection of UCMR PWSs, including the 

system PWSID, name, source water category, and population-served data for each UCMReligible 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 

As 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. 
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2(b)(iii) Stratification Variables 

In developing the representative sample, EPA considers factors such as population served, water 

source and geographic location. The sample of PWSs, as proposed, is stratified by population 

served (PWS size), allocating samples proportionately to each state 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

accounts for different PWS sizes, sources of water supply and geographic location (e.g., states). 

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 

allows 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 the population served. This population-weighted allocation leads to statistically 

valid estimates of national exposure. To ensure the sample provides equity across states for 

involvement in the UCMR, EPA expects to include at least two PWSs from each state. This 

additional PWS selection requirement provides allocation across all the states and territories to 

account for differences in spatial vulnerability and contaminant occurrence, and to ensure equity 

in participation. Small tribal PWSs across the EPA regions are expected to be grouped into a 

single category (equivalent to a “state”) for the representative sample. 

2(b)(v) Multi-Stage Sampling 

Because PWS status often changes over time, EPA also expects to select “alternate” PWSs that 

fit the size/source water strata of the originally selected PWS. Through an interactive review 

process with the states, 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) would be replaced by an alternate PWS that meets the stratification criteria.
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2(c) Precision Requirements 

2(c)(i) Precision Targets 

The representative sample of PWSs must be selected so that the data collected yield accurate and 

precise estimates of national contaminant occurrence (the fraction of 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 allowable 

error, and consequent large sample size should help ensure adequate data to meet the objectives 

of the UCMR program. 

2(c)(ii) Non-sampling error 

For those PWSs selected to conduct UCMR monitoring, response is a requirement. As with any 

regulation, 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 better compliance levels can be achieved during UCMR 4. 

EPA plans to continue outreach and compliance assistance efforts as needed. 

2(d) Questionnaire Design 

No 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

For UCMR 4, EPA expects to apply the same basic statistical methods that were used to select

the UCMR 1, 2 and 3 national representative samples of small PWSs. Following sample 

adjustments made through communications with states, >99% of the final sample of small PWSs

(and >95% of large PWSs) completed their required monitoring and reporting. 
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4 COLLECTION METHODS AND FOLLOW-UP

4(a) Collection Methods 

Large PWSs 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 

High compliance levels (>95%) during prior UCMRs give EPA confidence that equivalent or 

better levels can be achieved during UCMR 4. EPA continues outreach and compliance 

assistance efforts as needed. Each small PWS works with a UCMR Sampling Coordinator, and 

has minimal reporting requirements and one-on-one compliance assistance. 

Lessons learned during UCMR 1, 2 and 3 helped refine UCMR 4 requirements. UCMR 4:

• Has an increased sample frequency for cyanotoxins, and uses a phased sample-analysis

for microcystins. 

• Revises sampling locations.

• Compresses the monitoring schedule by eliminating sampling during DecemberFebruary.

• 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 UCMR 3, EPA established 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 continue to collect zip codes for each PWS's service area, as 

collected under 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. 
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5 ANALYZING AND REPORTING SURVEY RESULTS

5(a) Data Preparation 

After laboratories post UCMR 4 monitoring results and required data elements to EPA's 

electronic reporting system, EPA allows time for QC review by the PWSs, states, and the 

Agency before placing the data in the NCOD for public access. 

Data problems may occur, but EPA takes 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 measurement 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 staff 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 

For 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 analyze 

the data for UCMR 4. 

The first stage of analysis, Stage 1, provides a straightforward evaluation of occurrence for 

simple and conservative assessments of contaminant occurrence. The Stage 1 analysis of the 

UCMR data consists of non-parametric, unweighted counts and simple descriptive statistics of 

analytical results for each of the contaminants. These occurrence analyses are conducted at the 

sample level, PWS level and population-served level. For each contaminant, occurrence 

measures include the number and percent of samples with analytical detections 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 analytical 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 have 
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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. 

Based on the findings of the Stage 1 analysis, EPA can select contaminant(s) for which more 

detailed and sophisticated statistical evaluations – the Stage 2 analysis – may be warranted as a 

next step to generate national probability estimates of contaminant occurrence and exposure. 

Specifically, the modeling and estimation of PWS 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 

concentration threshold. The Bayesian-based 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 regulated contaminants for the first Six-Year Review of NPDWRs, an approach 

that underwent peer review. 

5(c) Reporting Results 

After 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. The 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 cooccurrence; and to evaluate treatment 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.
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APPENDICES
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APPENDIX A: Relevant Authorities in SDWA 1996 Amendments 

Section 1412(b)(1) Identification of contaminants for listing: 

(A) General authority – The Administrator shall, in accordance with the procedures 

established by this subsection, publish a maximum contaminant level goal and 

promulgate a national primary drinking water regulation for a contaminant (other than a 

contaminant referred to in paragraph (2) for which a national primary drinking water 

regulation has been promulgated as of the date of enactment of the Safe Drinking Water 

Act Amendments of 1996) if the Administrator determines that

(i) the contaminant may have an adverse effect on the health of persons; 

(ii) the contaminant is known to occur or there is a substantial likelihood that the 

contaminant will occur in public water systems with a frequency and at levels of 

public health concern; and 

(iii) in the sole judgment of the Administrator, regulation of such contaminant 

presents a meaningful opportunity for health risk reduction for persons served by 

public water systems. 

(B) Regulation of unregulated contaminants– 

(i) Listing of contaminants for consideration– 

(I) Not later than 18 months after the date of enactment of the Safe 

Drinking Water Act Amendments of 1996 and every 5 years thereafter, the 

Administrator, after consultation with the scientific community, including 

the Science Advisory Board, after notice and opportunity for public 

comment, and after considering the occurrence data base established under 

section 1445(g), shall publish a list of contaminants which, at the time of 

publication, are not subject to any proposed or promulgated national 

primary drinking water regulation, which are known or anticipated to 

occur in public water systems, and which may require regulation under 

this title. 

(II) The unregulated contaminants considered under subclause (i) shall 

include, but not be limited to, substances referred to in section 101(14) of 

the Comprehensive Environmental Response, Compensation, and Liability 

Act of 1980, and substances registered as pesticides under the Federal 

Insecticide, Fungicide, and Rodenticide Act. 

(III) The Administrator's decision whether or not to select an unregulated 

contaminant for a list under this clause shall not be subject to judicial 

review. 

(ii) Determination to regulate– 

(I) Not later than 5 years after the date of enactment of the Safe Drinking 

Water Act Amendments of 1996, and every 5 years thereafter, the 

Administrator shall, after notice of the preliminary determination and 

opportunity for public comment, for not fewer than 5 contaminants 

included on the list published under clause (i), make determinations of 

whether or not to regulate such contaminants. 

(II) A determination to regulate a contaminant shall be based on findings 

that the criteria of clauses (i), (ii), and (iii) of subparagraph (A) are 
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60 

satisfied. Such findings shall be based on the best available public health 

information, including the occurrence data base established under section 

1445(g). 

(III) The Administrator may make a determination to regulate a 

contaminant that does not appear on a list under clause (i) if the 

determination to regulate is made pursuant to subclause (II). 

(IV) A determination under this clause not to regulate a contaminant shall 

be considered final Agency action and subject to judicial review. 

(iii) Review – Each document setting forth the determination for a contaminant 

under clause (ii) shall be available for public comment at such time as the 

determination is published. 

(C) Priorities – In selecting unregulated contaminants for consideration under 

subparagraph (B), the Administrator shall select contaminants that present the greatest 

public health concern. The Administrator, in making such selection, shall take into 

consideration, among other factors of public health concern, the effect of such 

contaminants upon subgroups that comprise a meaningful portion of the general 

population (such as infants, children, pregnant women, the elderly, individuals with a 

history of serious illness, or other subpopulations) that are identifiable as being at greater 

risk of adverse health effects due to exposure to contaminants in drinking water than the 

general population. 

(D) Urgent threats to public health – The Administrator may promulgate an interim 

national primary drinking water regulation for a contaminant without making a 

determination for the contaminant under paragraph (4)(C), or completing the analysis 

under paragraph (3)(C), to address an urgent threat to public health as determined by the 

Administrator after consultation with and written response to any comments provided by 

the Secretary of Health and Human Services, acting through the director of the Centers 

for Disease Control and Prevention or the director of the National Institutes of Health. A 

determination for any contaminant in accordance with paragraph (4)(C) subject to an 

interim regulation under this subparagraph shall be issued, and a completed analysis 

meeting the requirements of paragraph (3)(C) shall be published, not later than 3 years 

after the date on which the regulation is promulgated and the regulation shall be 

repromulgated, or revised if appropriate, not later than 5 years after that date. 

(E) Regulation – For each contaminant that the Administrator determines to regulate 

under subparagraph (B), the Administrator shall publish maximum contaminant level 

goals and promulgate, by rule, national primary drinking water regulations under this 

subsection. The Administrator shall propose the maximum contaminant level goal and 

national primary drinking water regulation for a contaminant not later than 24 months 

after the determination to regulate under subparagraph (B), and may publish such 

proposed regulation concurrent with the determination to regulate. The Administrator 

shall publish a maximum contaminant level goal and promulgate a national primary 

drinking water regulation within 18 months after the proposal thereof. The Administrator, 

by notice in the 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 subject to any national primary drinking water regulation.
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Section 1412(b)(4) Goals and standards: 

(A) Maximum contaminant level goals – Each maximum contaminant level goal 

established under this subsection shall be set at the level at which no known or 

anticipated adverse effects 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 maximum 

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 proposes a national primary drinking 

water regulation under this paragraph, the Administrator shall publish a determination as 

to whether the benefits of the maximum contaminant level justify, or do not justify, the 

costs based on the analysis conducted under paragraph (3)(C).

(D) Definition of feasible – For the purposes of this subsection, the term “feasible” means 

feasible with the use of the best technology, treatment techniques and other means which 

the Administrator finds, after examination for efficacy under field conditions and not 

solely under laboratory conditions, are available (taking cost into consideration). For the 

purpose of this paragraph, granular activated carbon is feasible for the control of 

synthetic organic chemicals, and any technology, treatment technique, or other means 

found to be the best available for the control of synthetic organic chemicals must be at 

least as effective in controlling synthetic organic chemicals as granular activated carbon.

(E) Feasible technologies

(i) In general – Each national primary drinking water regulation which establishes 

a maximum contaminant level shall list the technology, treatment techniques, and 

other means which the Administrator finds to be feasible for purposes of meeting 

such maximum contaminant level, but 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 Administrator shall include in the 

list any technology, treatment technique, or other means that is affordable, as 

determined by the Administrator in consultation with the States, for small public 

water systems serving

(I) a population of 10,000 or fewer but more than 3,300; 

(II) a population of 3,300 or fewer but more than 500; and 

(III) a population of 500 or fewer but more than 25; 

and that achieves compliance with the maximum contaminant level or treatment 

technique, including packaged or modular systems and point- of-entry or point-ofuse treatment units. Point- of-entry and point-of-use treatment units shall be 

owned, controlled and maintained by the public water system or by a person 

under contract with the public water system to ensure proper operation and 

maintenance and compliance with the maximum contaminant level or treatment 

technique and equipped with mechanical warnings to ensure that customers are 

automatically notified of operational problems. The Administrator shall not 

include in the list any point-of-use treatment technology, treatment technique, or 
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other means to achieve compliance with a maximum contaminant level or 

treatment technique requirement for a microbial contaminant (or an indicator of a 

microbial contaminant). If the American National Standards Institute has issued 

product standards applicable to a specific type of point-of-entry or point-of-use 

treatment unit, individual units of that type shall not be accepted for compliance 

with a maximum contaminant level or treatment technique requirement unless 

they are independently certified in accordance with such standards. In listing any 

technology, treatment technique, or other means pursuant to this clause, the 

Administrator shall consider the quality of the source water to be treated. 

(iii) List of technologies that achieve compliance – Except as provided in clause 

(v), not later than 2 years after the date of enactment of this clause and after 

consultation with the States, the Administrator shall issue a list of technologies

that achieve compliance with the maximum contaminant level or treatment 

technique for each category of public water systems described in subclauses (I), 

(II), and (III) of clause (ii) for each national primary drinking water regulation 

promulgated prior to the date of enactment of this paragraph. 

(iv) Additional technologies – The Administrator may, at any time after a national 

primary drinking water regulation has been promulgated, supplement the list of 

technologies describing additional or new or innovative treatment technologies 

that meet the requirements of this paragraph for categories of small public water 

systems described in subclauses (I), (II), and (III) of clause (ii) that are subject to 

the regulation. 

(v) Technologies that meet surface water treatment rule – Within one year after 

the date of enactment of this clause, the Administrator shall list technologies that 

meet the Surface Water Treatment Rule for each category of public water systems 

described in subclauses (I), (II), and (III) of clause (ii).

Section 1445(a)(1)(A) Every person who is subject to any requirement of this title or who is a 

grantee, shall establish and maintain such records, make such reports, conduct such monitoring, 

and provide such information as the Administrator may reasonably require by regulation to assist 

the Administrator in establishing regulations under this title, in determining whether such person 

has acted or is acting in compliance with this title, in administering any program of financial 

assistance under this title, in evaluating the health risks of unregulated contaminants, or in 

advising the public of such risks. In requiring a public water system to monitor under this 

subsection, the Administrator may take into consideration the system size and the contaminants 

likely to be found in the system's drinking water. 

(B) Every person who is subject to a national primary drinking water regulation under 

section 1412 shall provide such information as the Administrator may reasonably require, 

after consultation with the State in which such person is located if such State has primary 

enforcement responsibility for public water systems, on a case-by-case basis, to 

determine whether such person has acted or is acting in compliance with this title. 

(C) Every person who is subject to a national primary drinking water regulation under 

section 1412 shall provide such information as the Administrator may reasonably require 

to assist the Administrator in establishing regulations under section 1412 of this title, 

after consultation with States and suppliers of water. The Administrator may not require 

under this subparagraph the installation of treatment equipment or process changes, the 
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testing of treatment technology, or the analysis or processing of monitoring samples, 

except where the Administrator provides the funding for such activities. Before 

exercising this authority, the Administrator shall first seek to obtain the information by 

voluntary submission. 

(D) The Administrator shall not later than 2 years after the date of enactment of this 

subparagraph, after consultation with public health experts, representatives of the general 

public, and officials of State and local governments, review the monitoring requirements 

for not fewer than 12 contaminants identified by the Administrator, and promulgate any 

necessary modifications.

(2) MONITORING PROGRAM FOR UNREGULATED CONTAMINANTS

(A) ESTABLISHMENT – The Administrator shall promulgate regulations establishing 

the criteria for a monitoring program for unregulated contaminants. The regulations shall 

require monitoring of drinking water supplied by public water systems and shall vary the 

frequency and schedule for monitoring requirements for systems based on the number of 

persons served by the system, the source of supply, and the contaminants likely to be 

found, ensuring that only a representative sample of systems serving 10,000 persons or 

fewer are required to monitor. 

(B) MONITORING PROGRAM FOR CERTAIN UNREGULATED CONTAMINANTS

(i) INITIAL LIST – Not later than 3 years after the date of enactment of the Safe 

Drinking Water Act Amendments of 1996 and every 5 years thereafter, the 

Administrator shall issue a list pursuant to subparagraph (A) of not more than 30 

unregulated contaminants to be monitored by public water systems and to be 

included in the national drinking water occurrence data base maintained pursuant 

to subsection (g). 

(ii) GOVERNORS' PETITION – The Administrator shall include among the list 

of contaminants for which monitoring is required under this paragraph each 

contaminant recommended in a petition signed by the Governor of each of 7 or 

more States, unless the Administrator determines that the action would prevent 

the listing of other contaminants of a higher public health concern. 

(C) MONITORING PLAN FOR SMALL AND MEDIUM SYSTEMS 

(i) IN GENERAL – Based on the regulations promulgated by the Administrator, 

each State may develop a representative monitoring plan to assess the occurrence 

of unregulated contaminants in public water systems that serve a population of 

10,000 or fewer in that State. The plan shall require monitoring for systems 

representative of different sizes, types, and geographic locations in the State.

(ii) GRANTS FOR SMALL SYSTEM COSTS – From funds reserved under 

section 1452(o) or appropriated under subparagraph (H), the Administrator shall 

pay the reasonable cost of such testing and laboratory analysis as are necessary to 

carry out monitoring under the plan. 

(D) MONITORING RESULTS – Each public water system that conducts monitoring of 

unregulated contaminants pursuant to this paragraph shall provide the results of the 

monitoring to the primary enforcement authority for the system. 
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(E) NOTIFICATION – Notification of the availability of the results of monitoring 

programs required under paragraph (2)(A) shall be given to the persons served by the 

system.

(F) WAIVER OF MONITORING REQUIREMENT – The Administrator shall waive the 

requirement for monitoring for a contaminant under this paragraph in a State, if the State 

demonstrates that the criteria for listing the contaminant do not apply in that State.

(G) ANALYTICAL METHODS – The State may use screening methods approved by the 

Administrator under subsection (i) in lieu of monitoring for particular contaminants under 

this paragraph. 

(H) AUTHORIZATION OF APPROPRIATIONS – There are authorized to be 

appropriated to carry out this paragraph $10,000,000 for each of the fiscal years 1997 

through 2003. 

(i) SCREENING METHODS.—The Administrator shall review new analytical methods 

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

cost-effective than established reference methods for use in compliance monitoring. 

[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 contaminants in public water systems 

obtained under subsection (a)(1)(A) or subsection (a)(2) and reliable information from 

other public and private sources. 

(2) PUBLIC INPUT – In establishing the occurrence data base, the Administrator shall 

solicit recommendations from the Science Advisory Board, the States, and other 

interested parties concerning the development and maintenance of a national drinking 

water contaminant occurrence data base, including such issues as the structure and design 

of the data base, data input parameters and requirements, and the use and interpretation of 

data.

(3) USE – The data shall be used by the Administrator in making determinations under 

section 1412(b)(1) with respect to the occurrence of a contaminant in drinking water at a 

level of public health concern. 

(4) PUBLIC RECOMMENDATIONS – The Administrator shall periodically solicit 

recommendations from the appropriate officials of the National Academy of Sciences and 

the States, and any person may submit recommendations to the Administrator, with 

respect to contaminants that should be included in the national drinking water 

contaminant occurrence data base, including recommendations with respect to additional 

unregulated contaminants that should be listed under subsection (a)(2). Any 

recommendation submitted under this clause shall be accompanied by reasonable 

documentation that– 

(A) the contaminant occurs or is likely to occur in drinking water; and 

(B) the contaminant poses a risk to public health. 

(5) PUBLIC AVAILABILITY – The information from the data base shall be available to 

the public in readily accessible form. 
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(6) REGULATED CONTAMINANTS – With respect to each contaminant for which a 

national primary drinking water regulation has been established, the data base shall 

include information on the detection of the contaminant at a quantifiable level in public 

water systems (including detection of the contaminant at levels not constituting a 

violation of the maximum contaminant level for the contaminant).

(7) UNREGULATED CONTAMINANTS – With respect to contaminants for which a 

national primary drinking water regulation has not been established, the data base shall 

include 

(A) monitoring information collected by public water systems that serve a 

population of more than 10,000, as required by the Administrator under 

subsection (a); 

(B) monitoring information collected from a representative sampling of public 

water systems that serve a population of 10,000 or fewer; and 

(C) other reliable and appropriate monitoring information on the occurrence of the 

contaminants in public water systems that is available to the Administrator.
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APPENDIX B: Burden and Cost Exhibits for the Five-Year UCMR 4 Period

of 2017-2021

Exhibit B-1a: Yearly Cost to Systems, by PWS Size and by Type of Cost (2017-2021) 

(corresponds with Exhibit 11a)

Cost Description 2017 2018 2019 2020 2021 Total1

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 $71,473 $71,473 $71,473 $0 $214,418

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 $21,423,836

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 $90,374,710

Total Labor and NonLabor for All PWSs $0 $33,556,800 $33,556,800 $33,556,800 $0 $100,670,399

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

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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 $2,047 $3,745 $103 $409 $749

Non-Labor Cost $0 $18,140 $48,894 $0.0 $3,628 $9,779

Burden (labor hours) 14.2 56.8 104.0 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 $77 $180 $265 $15 $36 $53

Non-Labor Cost per 

Response $0 $1,597 $3,464 $0 $319 $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 Total2 Annual 

Average

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

$876,636 $535,883 $535,883 $535,883 $32,833 $2,517,119 $503,424

Labor burden for all States for UCMR implementation and oversight (number of hours) 

18,466.2 11,288.3 11,288.3 11,288.3 691.6 53,022.8 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

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Exhibit B-2b: Per State (Respondent) and Per Response UCMR 4 Costs (2017-2021) 

(corresponds with Exhibit 13b)

Burden / Cost Total over 2017-2021

Annual Average 

over 2017-2021

PER RESPONDENT:

Labor Cost $44,949 $8,990

Non-Labor Cost $0 $0.00

Burden (labor hours) 946.8 189.4

PER RESPONSE:

Number Responses per Respondent1 3.0 1.00

Labor Cost per Response $8,990 $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. 

Exhibit 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 Total2

Annual 

Average 

Cost

Regulatory Support Activities: laboratory PT; QC audits; analytical standards provision; and 

technical support, guidance document development 

Lab PT $238,811 $0 $0 $0 $0 $238,811 $47,762

QC Audits $18,174 $36,347 $36,347 $18,174 $0 $109,042 $21,808

Analytical Standards $119,405 $245,975 $253,354 $260,955 $0 $889,689 $175,938

Technical Support $119,405 $61,494 $0 $0 $0 $180,899 $36,180

Subtotal –

Regulatory Support $495,794 $343,817 $289,702 $279,128 $0 $1,408,441 $281,688

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 $452,910 $4,076,186 $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

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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) 10,296
Draft ICR for UCMR 4 Proposed Rule July 2015

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Exhibit B-4: National Cost Summary for UCMR 4 Implementation (2017-2021) 

(corresponds with Exhibit 15)

Type of Cost 2017 2018 2019 2020 2021 TOTAL1

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 $819,631

Large PWSs

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

Non-Labor Cost $0 $23,491,630 $23,491,6230 $23,491,630 $0 $70,474,889

Total Large PWS 

Cost $0 $26,142,311 $26,142,311 $26,142,311 $0 $78,426,932

Very Large PWSs

Labor Cost $0 $508,005 $508,005 $508,005 $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 $21,423,836

States

Labor Cost $876,636 $535,883 $535,883 $535,883 $32,833 $2,517,119

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

Total State Cost $876,636 $535,883 $535,883 $535,883 $32,833 $2,517,119

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 $6,251,077 $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 $41,249,579 $485,743 $126,587,990

Total without EPA $876,636 $34,092,683 $34,092,683 $34,092,683 $32,833 $103,187,517

Total Burden (hours) for All Responses2

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

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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 EPA1

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 $2,047 $3,745 $44,949 $4,076,186 $2,839 $2,154

Non-Labor Cost 

Per Respondent n/a $18,140 $48,894 n/a $19,324,286 $18,440 $15,194

Total Cost 

(Labor plus NonLabor) $512 $20,187 $52,638 $44,949 $23,400,472 $21,279 $17,348

Total Cost Per 

Response $77 $1,777 $3,730 $8,990 n/a n/a $1,696

Total Burden Per 

Respondent (hr) 14.2 56.8 104.0 946.8 51,480.0 65.6 57.0

Total Burden Per 

Response (hr) 2.1 11.4 14.1 189.4 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 $8,990 $815,237 $568 $431

Non-Labor Cost 

Per Respondent n/a $3,628 $9,779 n/a $3,864,857 $3,688 $3,039

Ave. Cost (Labor 

plus Non-Labor) $103 $4,037 $10,528 $8,990 $4,680,095 $4,256 $3,470

Ave. Cost Per 

Response $15 $356 $746 $1,798 n/a n/a $339

Ave. Burden Per 

Respondent (hr) 2.8 11.4 20.8 189.4 10,296.0 13.1 11.4

Ave. Burden Per 

Response (hr) 0.4 2.3 2.8 37.9 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.