# Technology and Cost Document for

the Final Revised Total Coliform Rule

Office of Water ( 4707M ) EPA

- 815

- R- 12

- 005 December 2012 water.epa.gov/safewaterTechnology and Cost Document for the ii

Final Revised T otal C oliform Rule 

### Disclaimer

Readers may use the information presented in this document to evaluate the available technologies, operational practices, and compliance activities available to P ublic W ater S ystem s (PWSs) in complying with the R evised

Total Coliform Rule.

Information presented in this document serves as a foundation for making comparisons between regulatory alternatives developed by EPA, States, and other interested parties. This information is meant to be used for evaluation and comparison purposes at the national level only and not as direct input into syst em

- specific design or budget preparation for non- EPA entities.

Mention of trade names or commercial products does not constitute an EPA endorsement.Technology and Cost Document for the iii

Final Revised T otal C oliform Rule 

### CONTENTS

List of Acronyms/Abbreviations viii

1 Introduction 1-1

1.1 Purpose of the Document 1-1

1.2 Backgroun d of the RTCR 1-1

1.3 Document Organization 1-2



### 2 Estimated Unit Costs of Labor 2-1

2.1 PWS Labor Rates 2-1

2.2 State Drinking Water Program Personnel Labor Rates 2-3

2.3 Escalated Labor Rates 2-4

2.4 Labor Rates for RTCR Alternative Size Categories 2-5



### 3 Estimated Unit Costs of RTCR Monitoring Requirements 3-1

3.1 Introduction 3-1

3.2 Sample Collection and Delivery 3-1

3.2.1 Sampl e Collection 3-2

3.2.2 Sample Delivery 3-3



### 3.3 Sample Analysis 3-6

3.3.1 Available Analytical Methods 3-6

3.3.2 Sample Analysis Cost 3-7



### 3.4 Estimated Average Unit Monitoring Costs 3-9



### 4 Estimated Unit Costs of Assessments 4-1

4.1 Overview of Assessments 4-1

4.1.1 Level 1 Assessments 4-2

4.1.2 Level 2 Assessments 4-2



### 4.2 Elements of Assessments 4-3

4.2.1 Notification Element 4-5

4.2.2 System Specific Element 4-5

4.2.3 Sample Analytical Element 4-5

4.2.4 Sample Methodology Element 4-5

4.2.5 Event Situational Element 4-6

4.2.6 Operational Data Element 4-6

4.2.7 Historical Trend Element 4-6

4.2.8 Sample Tap Element 4-7

4.2.9 Sample Site Element 4-7

4.2.10 Sample Area Element 4-7

4.2.11 Third Party Element 4-7

4.2.12 Report Element 4-7



### 4.3 Unit Cost Estimates of Assessments 4-7

4.3.1 Methodology 4-7

4.3.2 Assumptions 4- 13



### 5 Estimated Unit Costs of Corrective Actions 5-1

5.1 Flushing 5-3Technology and Cost Document for the iv

Final Revised T otal C oliform Rule 5.1.1 Scheduled / Routine Flushing 5-3

5.1.2 Unscheduled / Spot Flushing 5-6



### 5.2 Sampler Training 5-8

5.3 Replacement / Repair of Distribution System Components 5-8

5.3.1 Valves 5-9

5.3.2 Water Mains 5-9

5.3.3 Fittings 5- 10

5.3.4 Hydrants 5- 11

5.3.5 Meters 5- 12

5.3.6 Dedicated Sample Taps 5- 13



### 5.4 Maintenance of Adequate Pressure 5- 16

5.4.1 Booster Pumping Station 5- 16

5.4.2 Modify or Replace Existing Pumps 5- 18

5.4.3 Install Variable Frequency Drives 5-18

5.4.4 Elevated Storage Facility 5- 19

5.4.5 Install Surge Relief Valve 5- 20

5.4.6 Install Surge Tanks 5- 21



### 5.5 Maint enance of Appropriate Hydraulic Residence Time 5- 22

5.5.1 Loop Dead Ends 5- 22

5.5.2 Install Appropriate Main Sizes 5- 23

5.5.3 Install Automated Flushing Devices 5- 23

5.5.4 Storage Facility Modifications 5- 24



### 5.6 S torage Facility Maintenance 5

- 28

5.6.1 Inspecting/Cleaning of Tanks 5- 28

5.6.2 Lining of Storage Tanks 5- 29

5.6.3 Vent/Hatch Repair 5- 30

5.6.4 Tank Repair 5- 31



### 5.7 Booster Disinfection 5- 31

5.7.1 Chlorine System 5- 32

5.7.2 Chloramines System 5- 36



### 5.8 Cross

- connection Control and Backflow Prevention Program 5- 41

5.8.1 Backflow Prevention Assemblies and Devices 5- 41

5.8.2 Program Administration 5- 42



### 5.9 Addition or Upgrade of On

- line Monitoring and Control 5- 44

5.9.1 Water Quality Monitor ing and Control 5- 45

5.9.2 Pressure Monitoring and Control 5- 48



### 5.10 Addition of Security Measures 5- 49

5.11 Development and Implementation of an Operations Plan 5- 51

5.11.1 Operation and Maintenance Standard Operating Procedure (SOP) Training 5- 52

5.11.2 Operation and Maintenance Plan Revision 5- 53



### References

_______________________________________________________________ R-1 Appendix A

_______________________________________________________________ A-1Technology and Cost Document for the v Final Revised T otal C oliform RuleTechnology and Cost Document for the vi

Final Revised T otal C oliform Rule 

## List of Exhibits

Exhibit 0-1 : PWS Labor Rates by System Size (2003$)

_________________________________________________ 2-3

Exhibit 0-2 : State Program Labor Rates (2003$)

_____________________________________________________ 2-4

Exhibit 0-3 : PWS Labor Rates by System Size (2007$)

_________________________________________________ 2-4

Exhibit 0-4 : State Program Personnel Labor Rates (2007$)

____________________________________________ 2-5

Exhibit 0-5 : PWS Labor Rates by RTCR Size Categories (2007$)

________________________________________ 2-6

Exhibit 3

- 1: Estimated Travel and Sample Time by PWS Population Served

___________________________ 3-2

Exhibit 3

- 2: Estimated Sampling Collection Cost Per Sample (2007$)

________________________________ _ 3-3

Exhibit 3

- 3: Estimated Sample Delivery Cost Per Shipment (2007$)

___________________________________ 3-3

Exhibit 3

- 4: Estimated Per

- Sample Delivery Cost (2007$)

___________________________________________ 3-4

Exhibit 3

- 5: Estimated Cost for Sample Self

- Delivery 1 (2007$)

_______________________________________ 3-4

Exhibit 3

- 6: Per Sample Cost Estimate for Sample Self

- Delivery (2007$)

_______________________________ 3-5

Exhibit 3

- 7: Estimated Percentages 1 of Systems Using Each Type of Sample Delivery

___________________ 3-5

Exhibit 3

- 8: Estimated Per Sample Shipping/Delivery Cost as a Function of System Size (2007$)

__________ 3-6

Exhibit 3

- 9: Common TC and E. coli Analytical Methods and their Average Contractor Lab Analytical Fee (2007$) 1

_________________________________________________________________________________ 3-8

Exhibit 3

- 10: Estimated Sample Cost for In

- House Analysis (2007$)

__________________________________ 3-9

Exhibit 3

- 11: Percentage of Systems Using In

- House vs. Contracted Laboratories

______________________ 3- 10

Exhibit 3

- 12: Estimated Average Unit Cost of Monitoring Per Sample (2007$)

_________________________ 3- 10

Exhibit 4

- 1: Summary of TCRDSAC TWG Investigative Spreadsheet Assessment Elements

______________ 4-4

Exhibit 4

- 2: Categories for which cost estimates are developed

_______________________________________ 4-8

Exhibit 4

- 3: Violations and triggers leading to assessments

__________________________________________ 4-8

Exhibit 4

- 4: 1989 TCR (as implemented) Labor Burden Estimate for Assessme nts done by CWSs serving 1,001

- 4,100

___________________________________________________________________________________ 4-9

Exhibit 4

- 5: RTCR Labor Burden Estimate for Assessments done by NCWSs serving ≤1,000

____________ 4- 11

Exh ibit 4

- 6: Estimated Labor Burden Associated with Assessments (Hours)

___________________________ 4- 12

Exhibit 4

- 7: Estimated Unit Costs Associated with Assessments (2007$)

______________________________ 4- 12

Exhibit 5

- 1: Summary of Corrective Actions

______________________________________________________ 5-1

Exhibit 5

- 2: Average System Flow Rates

__________________________________________________________ 5-3

Exhibit 5

- 3: Estimated Annual Costs for Routine Flushing (2007$)

____________________________________ 5-5

Exhibit 5

- 4: Estimated Unit Cost for Spot Flushing (2007$)

__________________________________________ 5-7

Exhibit 5

- 5: Estimated Costs Op erator Training/Certification (2007$)

________________________________ _ 5-8

Exhibit 5

- 6: Estimated Costs to Replace Valve (2007$)

______________________________________________ 5-9

Exhibit 5

- 7: Estimated Costs to R eplace Ductile Iron Pipe (2007$)

___________________________________ 5- 10

Exhibit 5

- 8: Estimated Costs to Replace Fittings (2007$)

___________________________________________ 5- 11

Exhibit 5

- 9: Estimated Costs to Re place Hydrants (2007$)

__________________________________________ 5- 12

Exhibit 5

- 10: Estimated Costs to Replace Meters (2007$)

___________________________________________ 5- 13

Exhibit 5

- 11: Dedicated Sampling Station Sche matic

______________________________________________ 5- 14

Exhibit 5

- 12: Dedicated Sampling Station

________________________________________________________ 5- 15

Exhibit 5

- 13: Estimated Costs of Installing a Dedicated Sampling Tap (2007$)

_________________________ 5- 15

Exhibit 5

- 14: Estimated Costs to Install a New Booster Pump Station (2007$)

_________________________ 5- 17

Exhibit 5

- 15: Estimated Costs to Replace Existin g Pump (2007$)

____________________________________ 5- 18

Exhibit 5

- 16: Estimated Costs to Install a Variable Frequency Drive (2007$)

__________________________ 5- 19

Exhibit 5

- 17: Estimated Costs to Install a New Elevated Storage Tank (2007$)

_________________________ 5- 20

Exhibit 5

- 18: Estimated Costs to Install a Surge Relief Valve (2007$)

________________________________ _ 5- 20

Exhibit 5

- 19: Estimated Costs to Install a Surge Control Tank (2007$)

_______________________________ 5- 22

Exhibit 5

- 20: Estimated Costs to Install Automated Flushing Devices (2007$)

_________________________ 5- 24

Exhibit 5

- 21: Estimated Costs to Modify Inlet/Outlet Piping (2007$)

________________________________ _ 5- 25

Exhibit 5

- 22: Estimated Costs to Install Mixing Devices (2007$)

_____________________________________ 5- 26

Exhibit 5

- 23: Estimated Costs to Modify Storage Operation (2007$)

________________________________ _ 5- 27

Exhibit 5

- 24: Estimated Costs to Decommission Storage (2007$)

_____________________________________ 5- 28

Exhibit 5

- 25: Estimated Costs for the Inspection and Cleaning of Storage Tanks (2007$)

________________ 5- 29

Exhibit 5

- 26: Estimated Costs for the Lining of Storage Tanks (2007$)

_______________________________ 5- 30

Exhibit 5

- 27: Estimated Costs for the Repair/Replacement of a Storage Tank Vent (2007$)

______________ 5- 30Technology and Cost Document for the vii

Final Revised T otal C oliform Rule Exhibit 5

- 28: Estimated Costs for the Repair/ Replacement of a Storage Tank Hatch (2007$)

_____________ 5- 31

Exhibit 5

- 29: Estimated Costs for the Repair of Storage Tanks (2007$)

_______________________________ 5- 31

Exhibit 5

- 30: Estimated Costs to Install a Permanent Chlorine Booster Disinfection Station (2007$)

______ 5- 34

Exhibit 5

- 31: Estimated Costs to Install a Temporary Chlorine Booster Disinfection Station (2007$)

______ 5- 35

Exhibit 5

- 32: Estimated Costs to Install a Permanent Chloramines Booster Disinfection Station (2007$)

___ 5- 37

Exhibit 5

- 34: Estimated Costs for a Backflow Prevention Assembly Installation (2007$)

________________ 5- 42

Exhibit 5

- 35: Cost Components of Program Administration for a Cross

- Connection Control and Backflow Prevention Program

_____________________________________________________________________ 5- 43

Exhibit 5

- 36: Estimated Annual Cost of a Cross

- Connection Control and Backflow Prevention Program (2007$)

_______________________________________________________________________________________ 5- 44

Exhibit 5

- 37: Estimated Costs for Online Chlorine Monitoring and Programming (2007$)

______________ 5- 46

Exhibit 5

- 38: Estimated Annual Operation and Maintenance Costs for an Online Chlorine Analyzer (2007$) 5-

46

Exhibit 5

- 39: Estimated Costs for Online Chloramines Monitoring and Programming (2007$)

___________ 5- 47

Exhibit 5

- 40: Estimated Annual Operation and Maintenance Costs for Online Ammonia and Monochloramines Analyzer (2007$)

________________________________________________________________________ 5- 48

Exhibit 5

- 41: Estimated Costs for Online Pressure Monitoring (2007$)

_______________________________ 5- 49

E xhibit 5

- 42: Estimated Annual Operation and Maintenance Costs for Online Pressure Transmitter (2007$) 5-

49

Exhibit 5

- 43: Estimated Costs for Installation of Security Measures (2007$)

___________________________ 5- 50

Exhibit 5

- 44: Estimated Costs to Develop and Implement an Operations Plan (2007$)

__________________ 5- 52

Exhibit 5

- 45: Estimated Costs for Operator Training/Certification (2007$)

___________________________ 5- 53

Exhibit 5

- 46: Estimated Costs to Maintain an Operations Plan (2007$)

_______________________________ 5- 54

Exhibit 5

- 47: Estimated Annual Costs for Operation and Maintenance Plan Implementation (2007$)

_____ 5- 54

Exhibit A

- 1.1: 1989 TCR (as implemented) Labor Burden Estimate for Assessments done by NCWSs serving ≤ 1,000

_____________________________________________________________________________________ 1

Exhibit A

- 1.2: RTCR Labor Burden Estimate for Assessments done by NCWSs serving ≤ 1,000

_____________ 2

Exhibit A

- 2.1: 1989 TCR (as implemented) Labor Burden Estimate for Assessments done by NCWSs serving 1,001 - 4,100

_______________________________________________________________________________ 3

Exhibit A

- 2.2: RTCR Labor Burden Estimate for Assessments done by NCWSs serving 1,001 - 4,100

________ 4

Exhibit A

- 3.1: 1989 TCR (as implemented) Labor Burden Estimate for Assessments done by CWSs serving ≤

100

_______________________________________________________________________________________ 5

Exhibit A

- 3.2: RTCR Labor Burden Estimate for Assessments done by CWSs serving ≤ 100

_______________ 6

Exhibit A

- 4.1: 1989 TCR (as implemented) Labor Burden Estimate for Assessments done by CWSs serving 101

- 500

______________________________________________________________________________________ 7

Exhibit A

- 4.2: RTCR La bor Burden Estimate for Assessments done by CWSs serving 101 - 500

____________ 8

Exhibit A

- 5.1: 1989 TCR (as implemented) Labor Burden Estimate for Assessments done by CWSs serving 501

- 1,000

____________________________________________________________________________________ 9

Exhibit A

- 5.2: RTCR Labor Burden Estimate for Assessments done by CWSs serving 501 - 1,000

__________ 10

Exhibit A

- 6.1: 1989 TCR (as implemented) Labor Burde n Estimate for Assessments done by CWSs serving 1,001 - 4,100

______________________________________________________________________________ 11

Exhibit A

- 6.2: RTCR Labor Burden Estimate for Assessments done by CWSs serving 1,001 - 4,100

________ 12

Exhibit A

- 7.1: 1989 TCR (as implemented) Labor Burden Estimate for Assessments done by CWSs serving 4,001 - 33,000

_____________________________________________________________________________ 13

Exhibit A

- 7.2: RTCR Labor Burden Estimate for Asse ssments done by CWSs serving 4,100 - 33,000

_______ 14

Exhibit A

- 8.1: 1989 TCR (as implemented) Labor Burden Estimate for Assessments done by CWSs serving 33,001 - 96,000

____________________________________________________________________________ 15

Exhibit A

- 8.2: RTCR Labor Burden Estimate for Assessments done by CWSs serving 33,001 - 96,000

______ 16

Exhibit A

- 9.1: 1989 TCR (as implemented) Labor Burden Estimate fo r Assessments done by CWSs serving > 96,000

___________________________________________________________________________________ 17

Exhibit A

- 9.2: RTCR Labor Burden Estimate for Assessments done by CWSs serving > 96,000

____________ 18Technology and Cost Document for the viii

Final Revised T otal C oliform Rule 

## List of Acronyms/Abbrev iations

Acronym/Abbreviation Agency/Organization/Definition

ABPA American Backflow Prevention Association

AIP Agreement in Principle

ASDWA Association of State Drinking Water Administrators

AWWA American Water Works Association

AWWARF Ame rican Water Works Association Research Foundation

BLS U.S. Bureau of Labor Statistics

CCCBFP C ross C onnection C ontrol and B ackflow P revention P rogram

CWS Community Water S ystem

DBP D isinfection B yproduct

EA Economic Analysis

EPA U.S. Environmental P rotection Agency

FACA Federal Advisory Committee Act

FED Federal

FR Federal Register

ft Feet

FTE F ull T ime E quivalent

GPCD G allons p er C apita per D ay

GPM Gallons per Minute

GSA U.S. General Services Administration

GWR Ground Water Rule

GWR EA Eco nomic Analysis for the Ground Water Rule

HRT Hydraulic residence time

HVAC H eating, V entilation, A ir C onditioning

in Inches

k Thousand
kgal Thousand gallons

G pm G allons per M inute

M Million

MCL Maximum Contaminant Level

MGD M illion G allons per D ay mg/L M illigrams per L iter

NCS National Compensation Survey

NCWS N on

- community W ater S ystem

NOM N atural O rganic M atter

NRWA National Rural Water Association

O&M O perations and M aintenance

OES Occupational Employment Survey

p si pounds per square inc h

PWS Public W ater S ystem

QA/QC Quality Assurance/Quality Control

RTCR Revised Total Coliform Rule

SCADA S upervisory C ontrol and D ata A cquisition

SDWA Safe Drinking Water ActTechnology and Cost Document for the ix

Final Revised T otal C oliform Rule SDWIS /FED Safe Drinking Water Information System /Federal Version

S f S quare F eet

SIC Standard Industrial Classification

SM Standard Methods

SOP Standard Operating Procedures

TC Total C oliform

TCR Total Coliform Rule

TCRDSAC Total Coliform Rule Distribution System Advisory Committee

TWG Technical Work Group

US United State s

USA United States of America

USEPA United States Environmental Protection Agency

UV Ultraviolet

VFD V ariable F requency D riveTechnology and Cost Document for the 1-1

Final Revised T otal C oliform Rule 

## 1 Introduction

1.1 Purpose of the Document

This document is one of several technical documents developed in support of the fina l Revised Total Coliform Rule (RTCR). It describes a vailable technologies, o perational practices,

and activities t hat may be performed by public water systems (PWSs) to comply with the requirements of the RTCR . The document also provides estimated unit c osts associated with

these technologies, operational practices, and compliance activities and descriptions of approaches used in developing the estimates.



## 1.2 Background of the RTCR

The U.S. Environmental Protection Agency (EPA) is required to review existi ng national primary drinking wate r regulations every six years. In 2003, EPA completed its review of the

1989 Total Coliform Rule ( 1989 TCR) and 68 National Primary Drinking Water Regulations ( NPDWRs ) for chemicals that were established prior to 1997. Th e purpose of the review was to identify current health risk assessments, changes in technology, and other factors that would provide a health or technological basis to support a regulatory revision that would maintain or improve public health protection. In July 2003 and as part of the Agency’s Six

- Year Review

, EPA published its intent to revise the 1989 TCR (USEPA 2003a).

In June 2007, EPA established a federal advisory committee, the Total Coliform Rule Distribution System Advisory Committee (TCRDSAC), under the Federal Advisory Committee Act (FACA) (USEPA 2007c). One of the goals of convening th e TCRDSAC was to make

recommendations to EPA on revisions to the TCR promulgated in 1989 (USEPA 1989).

The TCRDSAC included organizational members selected b y EPA based on the diverse perspectives, expertise , and experience needed to provide balanced recommendations to EPA on issues related to the TCR and issues related to distribution systems. From July 2007 through September 2008, t he committee met 13 times in Washington, DC. The TCRDSAC considered the technical and policy issues involved in the monitoring, assessment, and corresponding corrective actions of problems in the distribution systems to better understand and address public health impacts from deg radation of drinking water quality due to sanitary defects in the distribution system. This RTCR applies to all PWSs nationwide.

The goal of the TCRDSAC in making recommendations on revisions to the 1989 TCR is to achieve the objectives of the 1989 TCR more effectively and efficiently, taking into account the changes in the regulatory framework for implementing the Safe Drinking Water Act ( SDWA ) over the past 20 years and the knowledge gained throughout implementation of the 1989 TCR. The objectives of the 1989 TCR, and maintained by the RTCR, are: (1) to evaluate the effectiveness of treatment; (2) to determine the integrity of the distribution system; and (3) to signal the possible presence of fecal contamination. The TCRDSAC drew on a variety of data sources to capture experience with the 1989 TCR , on analyses conducted for TCRDSAC, and on the collective experience of the member organizations.Technology and Cost Document for the 1-2

Final Revised T otal C oliform Rule 

### In concert with other rules promulgated by EPA under SDWA, the RTCR construct will

better address the 1989 TC R objectives and enhance the multiple barrier approach to protecting public health, especially with respect to smaller groundwater systems. The RTCR paradigm is designed to trigger systems with a certain level of positive total coliform (TC)/ E. coli monitoring results to do an assessment, to identify whether a ny sanitary defect s are present, and to correct such defects accordingly. This is an improvement over the 1989 TCR framework by tak ing a more proactive approach to identifying and fixing problems tha t affect or may affect public

health.

The requirements of the RTCR can be found in 40 CFR Part 141, Subpart Y and the accompanying preamble (USEPA 2012b).



## 1.3 Document Organization

This document is divided into five chapters , reference s, and one appendix:

Ch apter 1

– Introduction

This chapter p rovides an overview of the RTCR development process, as well as a detailed summary of each chapter found in this document.

Chapter 2

– Estimated Unit Cost of Labor

This chapter presents the estimated unit cost of labor and describes in detail how the

labor rates used in this document were derived

.

Chapter 3

– Estimated Unit Costs of TCR Monitoring Requirements

This chapter describes the estimated unit monitoring cost under the RTCR based upon system characterization. This chapter is not intended to provide guidance for PWS compliance with the RTCR but rather to provide background information relevant to derivation of unit monitoring cost used to compare relative costs of regulatory options.

Chapter 4

– Estimated Unit Costs of Assessments

This chapter describes the estimated cost of conducting Level 1 and Level 2 assessments

based on realistic examples of elements that public water systems might include in their

assessments

. System

- and site

- specific elements of ass essments are determined by the primacy agency

.

Chapter 5

– Estimated Unit Costs of Corrective Actions

This chapter provides examples of corrective actions that might be implemented to correct sanitary defects discovered during Level 1 or Level 2 assessmen ts and other actions that might be taken by PWSs to implement the RTCR an d the associated unit

costs associated with the corrective actions.Technology and Cost Document for the 1-3

Final Revised T otal C oliform Rule 

### References

This section lists the references for the citations used in this document.

Appendix A

– RTCR Labor Bur den for Assessments

The appendix contains tables with labor burden estimates in hours for performing various

assessments. The t ables are broken out by system type, that is, community vs. noncommunity and by the population served by the PWSs

.Technology and Cost Document for the 2-1

Final Revised T otal C oliform Rule 

## 2 Estimated Unit Costs of Labor

Much of the burden associated with the RTCR is due to the labor that would be required to comply with the provisions of the rule including collecting routine and repeat samples, conducting assessments, taking f ollow- up action, and /or implementing corrective action. The following labor classes are used to estimate the costs associated with compliance activities:

• PWS technical staff

• PWS management staff

• State field engineering staff

• State p rogram o ffice staff

Other chapters and the appendi x of this document provide estimates of the labor time (burden ) that PWS staff will expend in implementing these management and operational improvements. This chapter presents the estimated unit cost of this labor burden in terms of a loaded labor rate that incorporates both what systems and States pay their staff and an estimate of the dollar value of benefits associated with their employment.

2.1 PWS Labor Rates

The unit cost of labor is the wage and the associated fringe benefits cost of a unit of labor

per unit of time expended in performing compliance activities. This section presents estimated labor rates for the labor categories identified above.

National Analysis of Labor Rates . EPA performed an analysis of available data sources to derive a nationally representative set of labor rates corresponding to the primary labor categories involved in SDWA compliance activities. The results of this study, Labor Costs for National Drinking Water Rules (USEPA 2003b ), have been used in the development of the

e con omic a nalys e s of several NPDWRs including the Ground Water Rule (USEPA 2006b ). These documents serve as the basis for the summary of the national labor rates below. The

national labor rates were used by the TCRDSAC in support of the Agreement in Principle (AIP) and consequently were used to further analyze the national economic impact of the proposed

RTCR and the final RTCR.

EPA identified several data sources for water industry

- specific labor rates:

• Bureau of Labor Statistics, Occupational Employment Sur vey (OES)

• Bureau of Labor Statistics, National Compensation Survey (NCS)

• U.S. Census Bureau, 1997 U.S. Economic Census

• American Water Works Association (AWWA), Utility Compensation Survey (2001)

• Safe Drinking Water Information Systems (USEPA 200 7d)

• Community Water System Survey (USEPA 2002)

The OES tracked compensation by Standard Industrial Classification (SIC). Wage data from two industry classes were particularly relevant to this analysis: SIC 494 – Water Supply,

which contained privately -owned drinking water systems, and SIC 903 – Local Government, which contained publicly-owned systems (USEPA 2003b). The NCS collects mean hourly earnings data not by industry but by occupation using a national survey of private and publicTechnology and Cost Document for the 2-2

Final Revised T otal C oliform Rule 

### establishments. The 2000 NCS sampled 15,840 private sector establishments (including 1,158 establishments in transportation and public utilities) with one or more employees, and 2,489 state and local governments with 50 or more employees (USEPA 2003b). The NCS provided an occupational subgroup, comprised of water and sewer treatment plant operators, that was used to derive labor rates for technical labor. Other NCS occupational categories provided data for managerial, clerical , and administrative labor rates.

The 1997 Economic Census provided total payroll figures, but did not provide hourly wage rate or sufficient additional information required to estimate labor rates. The AWWA’s Utility Compensation Survey provided annual salaries for 44 occupational categories. From

these occ upational categories, EPA was able to build hourly wage rates using the corresponding category salaries and assumptions regarding the number of hours per year worked per employee in these categories. Wage rates were derived for manageria l, technical, and clerical positions using the occupational category descriptions in the AWWA database. EPA determined, based on further analysis and response rates, that the AWWA survey database is biased towards the larger water system size categories. Therefore, the AW WA

- based wage rates were determined to be less accurate for smaller sized water systems.

EPA considered several factors in evaluating whether these data sources provided an accurate estimate of labor rates. Given the analytical needs of EPA’s national r egulatory cost models and data quality considerations, EPA selected the OES- based labor rates as nationally representative for use in national economic impact analyses.

The Agency continues to improve the basis from which it estimates the costs of its ru les. Newer data from EPA’s own national surveys, updated U.S. Bureau of Labor Statistics (BLS) data, and other industry surveys are currently under evaluation and are not yet ready to be incorporated into the economic analysis for the final RTCR.

Fringe Benefit Rates . In developing the unit labor costs, EPA also considered the additional indirect labor costs associated with fringe benefits paid to water system employees. The NCS reported fringe benefits on a per hour basis for select occupational categor ies. However, there was not a specific fringe benefit rate corresponding to water industry occupations. EPA identified fringe benefit rates for suitable occupational categories related to technical and managerial labor. These fringe benefit multipliers ranged from 1.3 to 1.5 times

direct labor dollar across the establishment size and occupational categories considered. These rates were applied to the OES

- based wage rates to produce fully

- loaded labor rates which are presented in Exhibit 2-1.

National La bor Rates

. Exhibit 2-1 present s unit labor costs for Technical and Managerial labor categories in 2003$ corresponding to the original EPA labor rate analysis (USEPA 2003b ).Technology and Cost Document for the 2-3

Final Revised T otal C oliform Rule 

### Exhibit 2-1: PWS Labor Rates by System Size (2003$)

Labor Category/Rates System Size (Population Served)

25

- 100 101

- 500 501

- 3,300 3,301

- 10k 10,001

- 100k >100k
Fringe Benefit Rate 1 1.3 1.4 1.5 1.5 1.5 1.5

Technical Labor Rate $ 21.44 $ 23.09 $ 24.74 $ 25.3 4 $ 26.05 $ 31.26

Managerial Labor Rate $ 44.36 $ 47.78 $ 51.20 $ 51.20 $ 51.20 $ 51.20
Weighted Labor Rate 2 $ 21.44 $ 23.09 $ 24.74 $ 30.51 $ 31.08 $ 35.25

1 Figures represent loaded rates that include a fringe benefit multiplier ranging from 1.3 to 1 .5 across size categories.

2 EPA estimates that systems with population served greater than 3,300 use a combination of operators (technical) and engineers (managerial), with an 80/20 ratio between the two, respectively. EPA also estimates that systems ser ving 3,300 or less use 100% (technical) labor.

Source: Economic analyse s for the Final Ground Water Rule (USEPA 2006 b ), the Stage 2 Disinfectants and Disinfection Byproducts Rule (USEPA 2006 d ), and the Long Term 2 Enhanced Surface Water Treatment Rule (U SEPA

2006 c).



### These labor rates were applied to each of the e conomic a nalys es supporting the Ground

Water Rule (USEPA 2006b), the Stage 2 Disinfectants and Disinfection Byproducts Rule (USEPA 2006d), and the Long Term 2 Enhanced Surface Water Treatment Ru le (USEPA 2006c) , respectively . Systems serving 3,300 people or fewer are assumed by EPA to use only technical labor to perform RTCR activities (the same assumption that was made for the other rules) . Therefore, the technical rate shown in Exhibit 2-1 applies to these smaller water systems. For systems serving more than 3,300 people, EPA assumes a ratio of 80 percent technical labor to 20 percent managerial labor to arrive at a labor cost, or weighted labor rate, of $30.51 for systems serving 3,301-10,000 people, $31.08 for systems serving 10,001-100,000 people, and $35.25 for systems serving greater than 100,000 people. Exhibit 2-1 also presents these weighted labor rates.



## 2.2 State Drinking Water Program Personnel Labor Rates

The unit labor cost for State staff performing administrative tasks were estimated based on data from the 2001 State Drinking Water Needs Analysis (ASDWA, 2001). EPA estimated an average annual full time equivalent (FTE) labor cost , including overhead and fringe benefits, of $70,132 (2003$) which was converted to an hourly rate of $33.60 assuming an FTE is equivalent to one person working 2,080 hours per year. EPA used R.S. Means (1998) data to establish a wage rate of $31.00 for a field engineer. A 60 percent loading factor was also assumed to account for the cost of fringe benefits. When escalated to 2003$, the loaded wage rate for State field engineering staff was $37.34 per hour. Exhibit 2-2 presents the State Program personnel loaded labor rates in 2003$.Technology and Cost Document for the 2-4

Final Revised T otal C oliform Rule 

### Exhibit 2-2: State Program Labor Rates (2003$)

State Labor Category Labor Cost

Field Engineer $37.34

Administrative $33.60

Source: Economic analyse s for the Final Ground Water Rule (USEPA 2006 b ), the Stage 2 Disinfectants and Disinfection Byproducts Rule (USEPA 2006 d ), and the Long Term 2 Enhanced Surface Water Treatment Rule (USEPA 2006 c) , respectively

.



## 2.3 Escalated Labor Rates

To ensure these labor rates are presented consistently with other cost analyses, EPA has adjusted the water system and State p rogram labor rates to 2007$ using an appropriate labor price index . EPA used the BLS Employment Cost Index – Series Index CIU2014400000000I (B), Total Compensation; Utilities. An escalation rate was computed using the price index for 4 th



### Quarter 2003 (90.2) and 4 th 

### Quarter 2007 (105.2) as follows: 105.2 ÷ 90.2 = 1.17. The escalation rate was applied to the 2003 labor rates to derive the corresponding 2007 labor rate values.

Exhibit 2-3 and Exhibit 2-4 present the escalated labor rates for water system s and State personnel , respectively.

Exhibit 2-3: PWS Labor Rates by System Size (2007$)

Loaded Labor Rate (2007$) System Size (Population Served)

25

- 100 101

- 500 501

- 3,300 3,301

- 10k 10,001

- 100k >100k

Technical Labor Rate $25.10 $27.03 $28.96 $29.67 $30.50 $36.60
Managerial Labor Rate $51.93 $55. 94 $59.94 $59.94 $59.94 $59.94

Weighted Labor Rate $25.10 $27.03 $28.96 $35.72 $36.39 $41.27

Notes: 1. Figures represent loaded rates that include a fringe benefit multiplier ranging from 1.3 to 1.5 across size categories. 2. EPA estimates that systems with population greater than 3,300 use a combination of operators (technical) and engineers (managerial), with an 80/20 ratio between the two, respectively

. EPA also estimates that systems serving 3,300 or less use 100% (technical) labor. 3. Labor costs adjusted from 2003 to 2007 dollars using BLS Employment Cost Index, Series Index CIU2014400000000I (B), Total Compensation; Utilities.

Source: Economic a nalys e s for the Final Ground Water Rule (USEPA 2006 b ), the Stage 2 Disinfectants and Disinfection

B yproducts Rule (USEPA 2006 d ), and the Long Term 2 Enhanced Surface Water Treatment Rule (USEPA 2006 c)

, respectively

.Technology and Cost Document for the 2-5

Final Revised T otal C oliform Rule 

### Exhibit 2-4: State Program Personnel Labor Rates (2007$)

State Labor Categor y Labor Cost

Field Engineer $ 43.58

Administrative $ 39.22

Notes: Labor rates escalated using the BLS Employment Cost Index

– Total Compensation State and Local Government, CIS3010000000000I (B).

Source: Economic analyse s for the Final Ground Water Ru le (USEPA 2006 b ), the Stage 2 Disinfectants and

Disinfec tion Byproducts Rule (USEPA 2006 d ), and the Long Term 2 Enhanced Surface Water Treatment Rule (USEPA 2006 c) , respectively

.



## 2.4 Labor Rates for RTCR Alternative Size Categories

The TCRDSA C Technical Wor king Group ( TWG ) analyzed the impact on PWS s using a modified set of system sizes based on the requirements of the RTCR. This is because certain rule provisions differ for systems above or below different population breaks (e.g., those serving

more or les s than 1,000, 4,100, or 33,000 people). Exhibit 2-5 presents how the labor rates for the size categories used in the RTCR were derived using the labor rates for the size categories

used in the Economic Analysis for the Ground Wat er Rule (GWR EA) (i.e., size categories

shown in Exhibit 2-3 ). The weighted labor rates from Exhibit 2-3 were reclassified into the new size categories by weighting them by the number of systems in each new size category.Technology and Cost Document for the 2-6

Final Revised T otal C oliform Rule 

### Exhibit 2-5: PWS Labor Rates by RTCR Size Categories (2007$)

GWR EA Size Categories <100 101 - 500 501 – 3,300 3,301 - 10k 10,001 - 100k >100k

GWR EA Labor Rates (2007$) $25.10 $27.03 $28.96 $35.72 $36.39 $41.27

RTCR Size Categories <100 101 - 500 501 – 1k 1,001 - 4,100 4,100 – 33k 33,001 – 96k >96 k

Subcategories for weighting 1 1

, 001

- 3

, 300 3

, 301

- 4

, 100 4

, 101

- 10k 10,001-33k 96

, 001

- 100k >100k

Number of PWSs in subcategory 2 9,706 1,246 3,823 2,675 23 407

Percentage of PWSs in subcategory 3 0.89 0.11 0.59 0.41 0.05 0.95

Rate for subcateogries 4 $28.96 $35.72 $35.72 $36.39 $36.39 $41.27

Weighted average rate for

RTCR size categories 5 $25.10 $27.03 $28.96 $29.73 $36.00 $36.39 $41.01

Note: Details may not add due to individual rounding.

1 Based on size categories tracked in SDWIS.

2 From SDWIS Fed Inventory 2007 4th Quarter Freeze

. 3 Number of PWSs in subcategory divided by the total number of PWSs in RTCR size category ( e.g., for 1,001

- 3,300 subcategory, 0.89 = 9,706 / (9,706 + 1,246)).

4 From size categories used in GWR EA

. 5 This is the s um of the rates for the subcategories weighted by the percentage of PWSs in each subcategory (e.g., for 1,001

- 4,100, $29.73 = ($28.96*0.89) + ($35.72*0.11)).Technology and Cost Document for the 3-1

Final Revised T otal C oliform Rule 

## 3 Estimated Unit Costs of R TCR Monitoring Requirements

3.1 Introduction

The 1989 TCR requires PWSs to test for the presence of total coliforms and either E. coli or fecal coliform at designated frequencies and locations in the dis tribution system as part of the routine, repeat, and additional routine monitoring provisions of the rule. The RTCR removes fecal coliforms as an indicator, but the general framework of monitoring remains the same.

This chapter presents the methodology, data, and assumptions used in developing estimates of the unit costs of compliance monitoring for both the 1989 TCR and for the RTCR. The general approach used to develop these estimates was developed by the TCRDSAC TWG during the federal advisory committee process in order to approximate relative costs of different rule options. EPA further refined this approach to develop the final unit costs presented in this document. Any assumptions that differ from those made by the TCRDSAC TWG are highlighted. The unit costs and the approach to develop them are presented below.

The costs presented in this chapter serve as a foundation for making comparisons between regulatory alternatives developed by EPA. They are meant to capture national averages of unit costs and not the unit costs of any particular PWS . Some components of monitoring costs, such as the purchase and wear- and -tear of vehicles, were discussed but not quantified here because of either limited data or inability to attribute these costs directly to the 1989 TCR or the RTCR. Thus, the unit costs presented in this document may over- or under- estimate the unit costs of any particular PWS . The information is meant to be used for evaluation and comparison purposes at the national level only and not as direct input for system- specific design or budget preparation for non- EPA entities.

The following sections of this chapter present unit cost estimates for each component of monitoring costs under the RTCR. A concluding section presents a weighted average unit cost of monitoring. These sections are:

• Sample Collection and Delivery

• Sample Analysis

• Estimated Average Unit Monitoring Costs

3.2 Sample Collection and Delivery

Sample collection and delivery unit costs are determined by the labor burden, or

e stimated staff time, to collect samples and the cost to deliver the samples to contracted laboratories (where applicable). For systems that use in -house labs, no additional delivery cost is applied. Approved sampling procedures for TC/ E. coli require ver y short hold times , not more than 30 hours from the time the sample is collected to the time the sample analysis begins. Delivery to a contracted laboratory, therefore, requires rapid response on the part of system staff or lab courier service. The TCRDSAC TWG discussed sample collection and delivery in detail during the proceedings of the TCRDSAC. A variety of delivery methods were discussed, each with a different cost. The TWG used available data along with best professional judgment in assuming the proportions of systems using each delivery method and developing the unit cost

estimates.Technology and Cost Document for the 3-2

Final Revised T otal C oliform Rule 

### 3.2.1 Sample Collection

Sample collection unit costs include all activities and the time to execute such activities in the collection of all routine, repeat, and additional routine samples by PWS staff. Proper procedures must be followed to ensure the sample is representative of the distribution system water quality and is not contaminated during sampling and subsequent handling. There are 12 approved methods under the 1989 TCR . All methods generally require that the same sample collection procedure is followed. The TCRDSAC TWG used best professional judgment to estimate the labor burden for system staff to take a single sample for compliance with the 1989

TCR . For costin g purposes, a simplifying assumption was made that systems collect their own samples (as opposed to contracting sample collection).

3.2.1.1 Sample Collection Labor Burden

The TCRDSAC TWG estimated the time (in hours) to collect a single sample based upon approved collection procedures and practices, including: gaining access to the sampling site, disinfection of the sampling tap, sample collection, completion of requisite forms and associated paperwork, and travel to and from the sampling site. Per- sample labor burden estimates were informed both by best professional judgment and by estimating the time required for collecting the total number of samples over a period of time. For example, a PWS may take 100 TC samples per month with an estimated total sample collection time for the entire month of 75 hours which would be equivalent to a per-sample burden of 0.75 hours. Per-sample labor burden was estimated by PWS size and included travel and sample collection time based on approved sample collection procedures. Larger systems would likely have longer travel times between sampling sites compared to smaller systems and therefore greater estimated costs.

Exhibit 3-1 presents the estimated average sample collection labor burden for three PWS population size categ ories.

Exhibit 3-1: Estimated Travel and Sample Time by PWS Population Served

Population Served Time (hours) required per sample 1

≤500 0.5

501

– 96,000 0.75

>96,000 1.0

1 Developed by TCRDSAC TWG based o n experience and be st professional judgment of TWG m embers.



### 3.2.1.2 Unit Sample Collection Costs

Exhibit 3- 2 presents the unit cost per sample collected. These costs, which represent a total labor cost per sample, were derived by multiplying the labor burden esti mates in Exhibit 3-1 and the appropriate staff labor rate for each PWS size category , from Exhibit 2-5.Technology and Cost Document for the 3-3

Final Revised T otal C oliform Rule 

### Exhibit 3-2: Estimated Sampling Collection Cost Per Sample (2007$)

System Size Labor Rate 1 Samplin g Time (hours) 2 Total Labor Cost

A B C D=B*C

≤100 $25.10 0.5 $12.55

101

- 500 $27.03 0.5 $13.52

501

- 1,000 $28.96 0.75 $21.72

1,001

- 4,100 $29.73 0.75 $22.30

4,100

- 33,000 $36.00 0.75 $27.00

33,001

- 96,000 $36.39 0.75 $27.29

>96,000 $41.01 1.0 $41.01

1 Includes travel time between sites and sample collection

. 2 Estimate developed by TCRDSAC TWG

.



### 3.2.2 Sample Delivery

EPA considered the various options that PWSs have for delivery of RTCR compliance monitoring samples to approved laboratories for analysis. These delivery methods included using a contract lab’s courier service or ground next day, standard next day, and priority overnight shipping options through private delivery companies such as FedEx. Given the constraint of sample hold times (no more than 30 h ours from time sample is drawn to analysis) and the requirement for a national delivery route, FedEx was deemed to be a reasonable cost basis. The derived costs are based on the delivery rates for delivering a package a distance of 100 miles, a distance b ased on experience of members of TCRDSAC TWG. The delivery package is assumed to be a cooler with dimensions of 17” x 12” x 15” sufficient to contain between one and five samples with ice packs at a single price per shipment (except ground next day service which varies with package weight). Exhibit 3-3 presents the estimated unit cost for sample delivery.

Exhibit 3-3: Estimated Sample Delivery Cost Per Shipment (2007$)

Type of Delivery 1 sample 2 samples 3 samples 4 samples 5 samples

Lab Courier Service $3.50 $3.50 $3.50 $3.50 $3.50

Ground Next Day 1 $6.65 $6.77 $6.88 $7.00 $7.12

Standard Next Day 1 $38.48 $38.48 $38.48 $38.48 $38.48

Priority Overnight 1 $45.12 $45.12 $45.12 $45.12 $45.12

1 Source of Cos t Quotes: FedEx



### Exhibit 3-4 below presents the shipping cost on a per- sample basis which is applied to those systems that are permitted to take all of their samples on the same day and to those systems required to take repeat samples or additional routine samples (and would thus be taking and delivering multiple samples at the same time). The effect on cost of taking multiple samples diminishes as the number of samples shipped or delivered simultaneously increases. Thus, the estimated delivery costs for s ystems taking more than five samples simultaneously or grouped together was assumed to be the same as the costs of shipping or delivering five samples.Technology and Cost Document for the 3-4

Final Revised T otal C oliform Rule 

### Exhibit 3-4 : Estimated Per -Sample Delivery Cost (2007$)

Type of Delivery Number of Samples Shipped or Delivered Simultaneously

1 2 3 4 5

Lab Courier Service $3.50 $1.75 $1.17 $0.88 $0.70

Ground Next Day $6.65 $3.39 $2.29 $1.75 $1.42

Standard Next Day $38.48 $19.24 $12.83 $9.62 $7.70

Priority Overnight $45.12 $22.56 $15.04 $11.28 $9.02

Note: Per

- sample delivery cost is calculated by dividing the delivery cost per shipment in the previous exhibit by the number of samples shipped or delivered simultaneously.



### Some systems deliver samples to contract laboratories themselves, sometimes driving long distances. The cost to these systems to self

- deliver varies based on the distance driven and the labor rate of the employee delivering the samples. The TCRDSAC TWG discussed the wide range of distances that are driven by different systems when self

- delivering samples by personally owned vehicles to labs. Based on best professional judgment and discussions with industry, EPA estimates that when a system employee delivers the samples to a lab in a personally owned vehicle, the employee will drive, on average, 15 miles (30 miles round trip). The estimated costs for sample self -delivery by personally owned vehicle are presented in

Exhibit 3-5.

Exhibit 3-5 : Estimat ed Cost for Sample Self

- Delivery 1 

### (2007$)

System Size Labor Rate Drive Time (hours) 1 Total Labor

Cost Personal Vehicle Use

Reimbursement 2 Total Delivery Cost

A B C D=B*C E F=D+E

≤100 $25.10 0.5 $12.55 $15.15 $27.70

101

- 500 $27.03 0.5 $13.52 $15.15 $28.6 7

501

- 1,000 $28.96 0.5 $14.48 $15.15 $29.63

1,001

- 4,100 $29.73 0.5 $14.87 $15.15 $30.02

4,100

- 33,000 $36.00 0.5 $18.00 $15.15 $33.15

33,001

- 96,000 $36.39 0.5 $18.20 $15.15 $33.35

>96,000 $41.01 0.5 $20.51 $15.15 $35.66

1 Distance of 15 miles (30 mile s roundtrip) and average speed of 60 mph.

2 Estimated 3/19/2008 using the U.S. General Services Administration (GSA) rate at that time of $0.505 per mile.



### Consistent with the use of a courier or parcel delivery service, the unit cost of selfdelivery of samples decreases as the number of samples per shipment increases. These bulk shipment unit costs are presented in Exhibit 3 -6.Technology and Cost Document for the 3-5

Final Revised T otal C oliform Rule 

### Exhibit 3-6 : Per Sample Cost Estimate for Sample Self

- Delivery (2007$)

Syst em Size Number of Samples Shipped or Delivered Simultaneously

1 2 3 4 5

≤100 $27.70 $13.85 $9.23 $6.93 $5.54

101

- 500 $28.67 $14.33 $9.56 $7.17 $5.73

501

- 1,000 $29.63 $14.82 $9.88 $7.41 $5.93

1,001

- 4,100 $30.02 $15.01 $10.01 $7.51 $6.00

4,100

- 33,000 $33.15 $16.58 $11.05 $8.29 $6.63

33,001

- 96,000 $33.35 $16.68 $11.12 $8.34 $6.67

>96,000 $35.66 $17.83 $11.89 $8.92 $7.13

Note: Per sample cost delivery cost is calculated by dividing the total delivery cost from the previous exhibit by the number of samples being driven simultaneously.



### The TCRDSAC TWG developed estimates of the percentage of systems using the different types of sample delivery methods based on its best professional judgment. These percentages are provided as Exhibit 3 -7. These percentages were used along with the other unit costs above to derive a weighted average unit cost of sample delivery among those systems that deliver or ship samples to a certified laboratory. The same delivery process was used for all system sizes that deliver or ship samples.

Exhibit 3-7 : Estimated Percentages 1 

### of Systems Using Each Type of Sample Delivery

Delivery Type Percentage of Systems

Lab Courier Service Pick

- up 20%
Ground Next Day 50%
Standard Next Day 12.5%
Priority Overnight 12.5%

Self

- Delivery by Car 5%

1 Based on best professional judgment of TCRDSAC TWG

.



### Exhibit 3-8 shows the weighted average unit delivery costs by PWS size category. As an example calculation to demonstrate how the preceding exhibits come together to form the values

in Exhibit 3 -8, consider the a verage cost to a system serving ≤100 people to ship one sample.

The cost is calculated as follows:

(0.2 * $3.50) + (0.5 * $6.65) + (0.125 * $38.48) + (0.125 * $45.12) + (0.05* $27.70) = $15.86

The percentages (0.2, 0.5, 0.125, 0.125, and 0.05) were obta ined from Exhibit 3-7 . The dollar values for all delivery methods, except for self- delivery by vehicle, were obtained from the

first column of Exhibit 3 -4. The first column is used because, in this example, it is specified that only one sample is being delivered. The dollar value for self- delivery by vehicle was obtained from the first row and first column of Exhibit 3-6, corresponding to the smallest sized system shipping only one sample. The dollar values are multiplied by their corresponding percentages to derive the weighted average shipping/delivery cost of $15.86 for one sample.

As another example, consider the average per

- sample cost incurred by a system serving 101-500 persons. The cost is calculated as follows:Technology and Cost Document for the 3-6

Final Revised T otal C oliform Rule 

### (0.2 * $1.75) + (0.5 * $3.39) + (0.125 * $19.24) + (0.125 * $22.56) + (0.05 * $14.33) = $7.98.

In this example, the per-sample costs are drawn from the second columns of Exhibits 3-4 and 3-6 which corresponds to two samples shipped at the same time and resulting in a lower weighted average per -sample shipping/delivery cost.

Exhibit 3-8 : Estimated Per Sample Shipping/Delivery Cost as a Function of System Size (2007$)

System Size Number of Sample s Shipped or Delivered Simultaneously

1 2 3 4 5

≤100 $15.86 $7.96 $5.33 $4.01 $3.22

101

- 500 $15.91 $7.98 $5.34 $4.02 $3.23

501

- 1,000 $15.96 $8.01 $5.36 $4.03 $3.24

1,001

- 4,100 $15.98 $8.02 $5.36 $4.04 $3.24

4,100

- 33,000 $16.13 $8.10 $5.42 $4.08 $3.27

33,001

- 96,000 $16.14 $8.10 $5.42 $4.08 $3.28

>9 6,000 $16.26 $8.16 $5.46 $4.11 $3.30



### 3.3 Sample Analysis

This section briefly describes two analytical methods for simultaneous sample analysis of

TC and E. coli : SM 9223-B (most common) and SM 9222- D membrane filtration (most labor intensive) and presents an approach for estimating the average unit cost of sample analysis. The unit costs of sample analysis are presented in two ways: (1) the cost for those systems that send

out the sample for analysis to a certified contract laboratory and (2) the cost for t hose systems that perform the analysis using in-house staff and laboratories.

Sample analysis costs for systems that contract the services are derived from the analytical fees charged by certified laboratories. Systems that perform the sample analyses in

house are assumed to incur both labor and operations and maintenance (O&M) costs. O&M costs are those expenses associated with operating a laboratory and performing an approved analytical method in -house. They include the laboratory facility, equipment and maintenance, supplies such as reagents, glassware and sample containers, as well as lab certification fees. In the final section of this chapter, a weighted average sample analysis unit cost is calculated based upon the percentages of systems conduc ting sample analysis in -house versus sending samples

out to contract labs.

3.3.1 Available Analytical Methods

Several common analytical methods exist that provide for simultaneous detection of TC

and E. coli in single samples. Simultaneous detection is often preferred because it reduces the total time required for analysis of E. coli , as non-simultaneous methods can require an additional

24- to 48-hour incubation time for E. coli detection

.

A commonly-used analytical method for simultaneous TC and E. coli an alysis utilizes enzyme substrate technology. Various commercially available formulations are available in disposable tubes for the multiple tube procedure, in disposable multi- wells or in containers that

will hold 100- ml samples for presence

- absence deter mination. This type of method can typicallyTechnology and Cost Document for the 3-7

Final Revised T otal C oliform Rule 

### utilize various nutrient indicators to produce a chromogenic or fluorogenic reaction with natural enzyme substrates (i.e., β

- galactosidase for TC and β

- glucorinidase for E.coli ).

Another common simultaneous method utilizes an enriched lactose growth media and an incubation temperature of 44.5oC ± 0.2 oC for selectivity. This method requires membrane filtration of the bacteria with subsequent differentiation of E. coli. E. coli bacteria are detected by transfe rring the membrane after the TC test to a 4

- methyl umbe lliferyl β -D glucuronide (MUG) nutrient agar substrate. E. coli bacteria are detected by observing any coliform colonies with a fluorescent blue periphery. The colony forming units counted on each membrane are added together for a reportable result as nu mber per 100 ml.

The preamble to the final RTCR (USEPA 20 12b ) provides a complete discussion on analytical methods for detection of total coliforms and E. coli utilized under this proposed rule.

3.3.2 Sample Analysis Cost

The cost of sample analysis is one of the key components of the overall unit cost of monitoring. The cost of sample analysis will vary depending on whether a system contracts the analysis to a certified laboratory or conducts the analytical methods in -house. The following

sections discuss th e approach for determining sample analysis cost for contractor labs versus inhouse labs.

3.3.2.1 Contract Lab oratories

Any laboratory that performs analyse s for a PWS that is not performing sample analysis

for itself under the 1989 TCR is considered to be a contr act laboratory. Typically contract laboratories are commercial laboratories holding certification in one or more States to perform sample analysis by approved methods under the 1989 TCR . Some larger PWSs also perform contract sample analysis typically for smaller systems. Some States also provide analytical support services to PWSs.

Contract laboratories normally bid on annual contracts to perform compliance sample analysis for PWSs. Purchasing requirements typically include state or primacy agency

certi fication and sample analysis unit cost for each contracted method. Sample analysis fees may also include sample pick -up. Contractor laboratory fees include direct labor and overhead as well as O&M. Therefore, no estimates of direct labor or O&M are requ ired to determine the direct cost to a PWS for contracted sample analysis.

Information for sample analysis costs for each of the two commonly performed methods described previously for simultaneous analysis of TC and E. coli was reviewed to estimate average contractor lab analytical fees. This data is presented below in Exhibit 3 -9.

Based on the best professional judgment and experience of the TCRDSAC TWG and EPA, the majority of systems employ substrate methods (e.g., SM 9223 B) rather than membrane filtration methods (e.g., 9222 D). Thus, the estimated unit costs of monitoring presented at the end of this chapter assume the use of substrate methods. However, the contractor lab fees for both SM 9223 B and SM 9222 D are presented in Exhibit 3-9 to all ow the reader to compare

costs between the two methods. The data were informed by informal discussions with nine commercial laboratories in April 2008. Only four of the laboratories contacted were certified toTechnology and Cost Document for the 3-8

Final Revised T otal C oliform Rule 

### perform both methods. As a simplifying assumption, analytical pricing was assumed to be equivalent to 2007 costs.

Although not expli citly discussed here, contract lab fees may also include the cost of reporting to the primacy agency. Certain States require the laboratory performing the analysis to also perform the reporting function.

Exhibit 3-9: Common TC and E. coli Analytical Methods and their Average Contractor Lab Analytical Fee (2007$) 1

Lab (Location) Analytical Method

SM 9223 B SM 9222 D

CA $18.00 $27.75

KY $25.00 $35.00

OH $15.00 $25.00

IN $25.00 $30.50

CA $20.00

NY $25.00

MI $30.00

NY $18.00

WV $23.25

Average $22.13 $29.56

1 Based on 2008 data from nine laboratories across the United States.



### 3.3.2.2 In -house Analysis

PWS s serving a population greater than 33,000 persons typically perform sample analysis

in -house. Larger systems are more likely to have the staff, equipment, and facilities required to hold certifications and perform analysis for one or more of the approved methods under the 1989

TCR than smaller systems . The cost of sample analysis performed in -house should also account for O&M costs which can include equipment and maintenance such as incubators, UV lights, glassware, miscellaneous lab equipment and supplies, as well as perishables including reagents, sampling containers, etc. Certification fees must also be included in O&M costs. Certification fees can be highly variable and may range from a few hundred dollars to several thousand dollars a year. Some States, In diana for example, do not have laboratory certification fees. Certification fees are typically based upon specific methods performed or by analyte groups such as inorganics, organics, or microbiology. Certification requirements are also specific with regard to facilities, equipment, and staff. Laboratory work stations must be properly maintained with adequate facilities, be of an adequate size, and possess safety equipment including safety showers, eyewash stations, and hoods. All of these items must be included in O&M costs.

For purposes of this document, EPA is applying the same estimate for O&M costs ($8.95) that was used in the GWR EA but has escalated the estimate up to 2007 dollar values ($10.09). In addition to O&M, labor burden was considered a key criterion for estimating cost for sample analysis performed in -house. The TCRDSAC TWG agreed that 0.5 hours per sample

was a reasonable estimate for labor burden. The site

- specific technical labor rate was also considered as a key component to the estimation of sample analysis cost. Again, the TWGTechnology and Cost Document for the 3-9

Final Revised T otal C oliform Rule 

### agreed to use the labor rates from the GWR EA adjusted to 2007 dollars. Exhibit 3-10 demonstrates the estimated sample cost for analysis performed in -house.

Exhibit 3-10 : Estimated Sample Cost for In -House Analysis (2007$)

System Size Labor Rate Labor Burden (hours) O&M Total Labor Cost

A B C D E=B*C+D

≤100 $25.10 0.5 $10.09 $22.64

101

- 500 $27.03 0.5 $10.09 $23.61

501

- 1,000 $28.96 0.5 $10.09 $24.57

1,001

- 4,100 $29.73 0.5 $10.09 $24.96

4,100

- 33,000 $36.00 0.5 $10.09 $28.09

33,001

- 96,000 $36.39 0.5 $10.09 $28.29

>96,000 $41.01 0.5 $10.09 $30.60

Note : Systems serving 33,000 or less people typically will not perform in

- house sample analysis. See Exhibit 3

- 11.



### 3.4 Estimated Average Unit Monitoring Costs

This chapter has presented the methodology, data, and assumptions used in developing

estimates of the unit costs of compliance monitoring for both the 1989 TCR and for the RTCR based on whether the system uses a contract lab or tests samples in -house. The general approach used to develop these estimates is the same that was used by TCRDSAC TWG during the federal advisory committee process in order to approximate relative costs of different rule options. The components of unit monitoring costs are as follows:

For in

- house sample analysis:

• Sample collection

• Sample analysis

For contract lab sample analysis :

• Sample collection

• Shipping/delivery

• Lab fee

Unit costs were derived for both of these monitoring approaches and for each of the different system size categories. A weighted average for sample analysis cost incorporating both

in -house and contractor sa mple analysis cost is presented. This weighted average is based on the estimated percentage of systems using in -house versus contractor labs and is shown in Exhibit 3- 11. Large systems typically have the staff, facilities and equipment required to obtain certifications and perform one or more of the approved analytical methods. Small systems typically contract a certified laboratory to perform the sample analysis. The assumptions presented in Exhibit 3-11 demonstrate that systems serving 33,000 persons or fewer contract 100 percent of their sample analysis to a certified laboratory. Systems serving between 33,001 and 96,000 persons are equally divided between using in-house labs and using contractor labs. For the largest systems, those serving >96,000 persons, 90 percent are assumed to use an in-house laboratory and 10 percent to use contract labs. These percentages were used to derive the weighted average unit monitoring cost of in-house and contract labs for the different size categories presented in Exhibit 3-12.Technology and Cost Document for the 3- 10

Final Revised T otal C oliform Rule 

### Exhibit 3-11 : Percentage of Systems Using In -House vs. Contracted Laboratories

System Size Percent Using

In

- House Laboratory Percent Using Contract Laboratory

≤100 0% 100%

101

- 500 0% 100 %

501

- 1,000 0% 100%

1,001

- 4,100 0% 100%

4,100

- 33,000 0% 100%

33,001

- 96,000 50% 50%

>96,000 90% 10%

1 Developed by TCRDSAC TWG based on the experience of the group and best professional judgment.



### An example calculation is presented below to demonstrate the source of the data presented in Exhibit 3-12. Consider a system serving 33,001-96,000 persons that takes five samples simultaneously. As presented in Exhibit 3-12, the estimated average unit cost of monitoring (per sample cost) is $54.14.

0.5 = Percentage of systems in this size category using in -house labs and percentage of systems in this size category using contract labs (from Exhibit 3-11) $27.29 = Sampling cost (from Exhibit 3 -2) $28.29 = In

- house analytical cost (labor + O&M) (from Exhibit 3-10) $3.28 = Average per

- sample shipping cost for a system in this system size when collecting 5 samples at once (from Exhibit 3 -8) $22.13 = Average lab fee to test one sample for TC/ E. coli using substrate method (from Exhibit 3 -9)

Exhibit 3-12: Estimated Average Unit Cost of Monitoring Per Sample (2007$)

System Size Number of Samples Taken Simultaneously

1 2 3 4 5

≤100 $50.54 $42.64 $40.01 $38.69 $37.90

101

- 500 $51. 55 $43.63 $40.99 $39.67 $38.87

501

- 1,000 $59.81 $51.86 $49.21 $47.88 $47.09

1,001

- 4,100 $60.40 $52.45 $49.79 $48.47 $47.67

4,100

- 33,000 $65.26 $57.23 $54.55 $53.21 $52.40

33,001

- 96,000 $60.57 $56.55 $55.21 $54.54 $54.14

>96,000 $72.38 $71.57 $71.30 $7 1.17 $71.09 Unit cost for contract lab



### 0.5 * ($27.29 + $28.29) + 0.5 * ($27.29 + $3.28 + $22.13) = $54.14

Unit cost for in -houseTechnology and Cost Document for the 4-1

Final Revised T otal C olifo rm Rule 

## 4 Estimated Unit Costs of Assessments

The federal requirements of the 1989 TCR do not include assessments of PWSs following nonacute violations or acute violations. However, under the 1989 TCR , as it is actually implemented, many systems are either conducting some level of assessments themselves or receiving some level of assessments from States following Maximum Contaminant Level (MCL) violations. This chapter estimates the level of effort currently incurred by systems to

conduct assessments following TCR MCL violations under the 1989 TCR, as implemented. In addition, the chapter provides an overview of the assessment provisions in the RTCR and

estimates of their associated costs for PWS s. The cost estimates presented in this chapter were informed by input from States and industry received during the proceedings of the TCRDSAC. They are described in more detail later in the chapter. State costs associated with assessments

are included in the Economic Analysis for the Final Revised Total Co liform Rule ( USEPA 2012a).

This chapter is organized into three sections. Each section builds on the previous section

to describe how the unit costs incurred by systems to perform assessments were estimated. The

three sections are as follows:

1. Overview of Assessments

2. Elements of Assessments

3. Unit Cost Estimates of Assessments



## 4.1 Overview of Assessments

The purpose of performing assessments is to proactively enhance public health protection by identifying the presence of "sanitary defects” (which are defined as “defect[s] that could provide a pathway of entry for microbial contamination into the distribution system or that [are] indicative of a failure or imminent failure in a barrier that is already in place”) and defects in distribution system coliform monit oring practices. EPA believes that assessments will strengthen the PWS ’ capacity to ensure that barriers to intrusion or contamination are in place

and effective. The assessment triggers represent a significant improvement over the 1989 TCR paradigm in t hat sampling results will trigger an assessment to take a closer look at the system

and to identify whether one or more sanitary defects are present . This is a more proactive approach than the 1989 TCR and will lead to the identification and correction of problems that

may compromise public health. The RTCR includes two levels of assessments: Level 1 and

Level 2. For either Level 1 or 2 assessments, the PWS will complete the assessment as soon as practicable after notification of their monitoring result s. The PWS will provide the primacy agency a complete Level 1 or 2 assessment report within 30 days after notification of exceeding the trigger.

The minimum elements of both Level 1 and 2 assessments should include a review and

identification of the follo wing:

1. Inadequacies in sample sites, sampling protocol, and sample processingTechnology and Cost Document for the 4-2

Final Revised T otal C olifo rm Rule 

### 2. Atypical events that may have affected distributed water quality or indicate that distributed water quality was impaired

3. Changes in distribution system maintenance and operation t hat may have affected or are affecting distributed water quality including water storage

4. An evaluation of source water quality and treatment changes or conditions that may affect distributed water quality, where appropriate (e.g., small ground PWS s)

5. Exist ing water quality monitoring data

Appendix X of the AIP (USEPA 2009) contains forms that serve as examples of Level 1

and 2 assessments. These forms are intended as conceptual examples to describe practical expectations for the level of resources committe d to undertaking a Level 1 or 2 assessments.

Assessments conducted under the RTCR should reflect the substance and effect of the elements of these example Level 1 and 2 assessment checklists. The following two sections describe the

Level 1 and Level 2 as sessments in more detail.

4.1.1 Level 1 Assessments

The Level 1 assessment will consist of a simple examination of the system and relevant operational practices. The Level 1 assessment is intended as a self

- assessment (EPA anticipates

that these will be complet ed by the PWS and reviewed by the primacy agency ) . If the primacy agency determines the assessment report insufficient, it will consult with the PWS.

A Level 1 assessment is triggered if sampling results in one of the following:

1. For systems collecting 4 0 or more samples per month, the PWS exceeds 5.0% total

coliform -positive samples for the month; or

2. For systems collecting fewer than 40 samples per month, the PWS has two or more total

coliform

- positive samples in the same month ; or

3. The PWS fails to take every required repeat sample after any single routine total

coliform

- positive sample

.

The assessment report identifies any sanitary defects detected, corrective actions completed, and a timetable for any corrective actions not already completed. The asse ssment report may also note that no sanitary defects were identified. Upon completion and submission

of the assessment form by the PWS, the primacy agency determines if the PWS has identified a likely cause for the Level 1 trigger and establish whether the system has corrected the problem.

4.1.2 Level 2 Assessments

A Level 2 assessment is a more detailed examination of the system, its monitoring program and results, and its operational practices. It is comprised essentially of the same

elements as a Level 1 as sessment, but each element is investigated in greater detail . T he level ofTechnology and Cost Document for the 4-3

Final Revised T otal C olifo rm Rule 

### effort and resources required to implement the Level 2 assessments will be commensurate with a more comprehensive investigation, a higher level review of available information, and may involve the engagement of additional parties and expertise.

A Level 2 assessment is triggered if sampling results in any of the following:

1. The PWS has a n E. coli MCL violation; or

2. The PWs has a second Level 1 treatment technique within a rolling 12-month period, unless the State has determined a likely reason that the samples that caused the initial Level 1 treatment technique trigger were total coliform -positive and establishes that the system has fully corrected the problem; or

3. For systems with app roved reduced annual monitoring, a Level 1 treatment technique trigger in two consecutive years.

EPA anticipates that the system burden incurred by conducting Level 2 assessments following triggers associated with the presence of E. coli (referred to later in this document as Level 2 [acute]) may be higher than the system burden incurred by conducting Level 2 assessments following triggers in which there is no E. coli (referred to later in this document as Level 2 [nonacute]).

L evel 2 assessment s will be conducted by the PWS, where the system has staff or management with the certification or qualifications specified below, unless otherwise directed or approved by the primacy agency:

1. A certified operator with a minimum of two (2) years of experience as a cert ified operator in systems requiring similar or more extensive certification requirements, or

2. Individuals with equivalent training or experience as approved by the primacy agency.

As with the Level 1 assessment form , the Level 2 assessment form identifies s anitary defects detected, corrective actions completed, and a timetable for any corrective actions not already completed. The assessment form may also note that no sanitary defects were identified. Upon completion and submission of the assessment form by the PWS, the primacy agency

determine s if the PWS has identified a likely cause for the Level 2 trigger and establish es whether the system has corrected the problem. If the primacy agency determines that the Level 2 assessment report is insufficient, it will consult with the PWS and, if necessary, provide assistance or require appropriate action.

4.2 Elements of Assessments

The TCRDSAC TWG discussed the various elements that assessments would likely encompass including those that are currently implemented by some systems and States under the

1989 TCR. This list of elements was based on the collective experience and best professional judgment of TCRDSAC TWG members and their colleagues. Exhibit 4-1 below and the

sections that follow were informed by the discussions of the TCRDSAC TWG . The list is notTechnology and Cost Document for the 4-4

Final Revised T otal C olifo rm Rule 

### intended to represent required elements of an assessment and should not be interpreted as such. Rather, the list is an interpretation by the TCRDSAC TWG of both what is occurring under the

1989 TCR and of what is anticipated to occur under the RTCR and is meant to provide estimates

of PWS labor burden associated with assessments. The different types of assessments are made up of the same elements, but the degree to which the elements are implemented varies. Be cause of differences among systems and States, EPA anticipates that primacy agencies will tailor specific assessment elements to the size and type of a PWS and that the PWSs will adapt their

assessment activities based on the characteristics of the ir distr ibution systems . The actual assessment costs will be highly dependent upon the specific system characteristics and the primacy agency requirements.

Exhibit 4

- 1: Summary of TCRDSAC TWG Investigative Spreadsheet Assessment Elements

Element Description

Noti fication Element Notification of the state authority. Includes time for the system to review
sample data, notify superiors, and contact state authority.
System Specific Element Includes time for personnel to gather system specific information (system ID, size, active sources, sample site plan, etc.) if necessary.
Sample Analytical Element Evaluate Lab Quality Assurance/Quality Control (QA/QC). Includes time for systems with labs to evaluate QA/QC procedures or for systems without labs to

call contract l ab with questions.
Sample Methodology Element Includes time for personnel to evaluate whether p roper sampling and sampling handling techniques were used and to identify and note any deviations.

Event Situational Element Includes time for personnel to rev iew and evaluate any significant system events that may have influenced the sample(s) (main breaks, main repair,
pressure events, treatment problems, source water changes, weather events, etc.).
Operational Data Element Includes time for personnel to comp ile other data that may be important to the event (such as chlorine residual, other water quality parameters, treatment parameters), if available.

Historical Trend Element Includes time for personnel to review the history of samples in the system and

at t he site in question.
Sample Tap Element Includes time to inspect and evaluate the condition of the sampling tap(s).
Sample Site Element Includes time to inspect and evaluate the facility in which the sample was

taken.
Sample Area Element Includes time t o inspect and evaluate other positive follow

- up samples (if applicable) away from the original site.
Third Party Element Includes time for contracting with a third party consultant.
Report Element Includes time for the personnel to complete the report and provide the results
to state authority.

Note: The above list of elements is not intended to represent required elements of an assessment and should not be interprete d as such. Rather, the list is an interpretation by the TCRDSAC TWG of both what is occurring under the 1989 TCR and of what is anticipated to occur under the RTCR for purposes of estimating PWS labor burden associated with assessments.



### The sections that follow describe the elements in more detail and were informed by the assumptions di scussed by the TCRDSAC TWG that helped to inform that cost estimates

associated with each one. The se elements differ in some respects with the elements contained in

the example assessment forms provided in Appendix X of the AIP (USEPA 2009). However, most of the elements are equivalent or contain significant overlap, and while the investigationsTechnology and Cost Document for the 4-5

Final Revised T otal C olifo rm Rule 

### spreadsheet was developed to provide a basis for the cost estimate developed by the TCRDSAC TWG to perform Level 1 and Level 2 assessments, the assessment forms f ound in Appendix X of

the AIP are intended to be used as c onceptual examples for performing assessments.

4.2.1 Notification Element

The Notification Element involves notification of monitoring results to the state authority. Cost estimates are based on the time for sample data review, notification of superiors, state authority contact, and external advisor contact for guidance. Sample data review includes preparing information relevant to recent monitoring and the violation for dialog with the State,

and a revi ew of state code and guidance for the situation. Notification of superiors assumes contact within the chain of command extending to a local government entity. State authority

contact assumes the State maintains a 24

- hour call center or accepts email or f ax communication. Under external advisor contact, after determining that a threshold has been exceeded, it is assumed that the system manager will contact a contract engineer, a colleague, National Rural

Water Association ( NRWA ) Rider, or state employee t o assess the implication or significance of

the violation.

Normally, notification is limited to monthly filing of RTCR routine monitoring report

and information related to the triggering of a Level 1 or Level 2 assessment would be provided by the system t o the State in the routine monitoring report.

4.2.2 System Specific Element

The System Specific Element includes personnel time to gather system specific information, such as system ID, size, active sources, a description of the sample site plan, etc.

Cost esti mates assume that this information is available and that if it is not compiled yet, some time will be spent gathering the information and checking against previous permits and submissions to state authorities. Subsequent reporting will require minimal time to fulfill this element. Systems serving at least 4,100 customers will usually spend more time gathering information for this element because they typically have more complex community w ater s ystem (CWS) i dentification assignments, retail and wholesale relationships, etc., which will need to be reviewed to properly associate positive sample sites to CWS identifiers.

4.2.3 Sample Analytical Element

The main purpose of the Sample Analytical Element is to document and evaluate laboratory QA/QC. Cost estimation assumes that the State will provide this information for systems serving 1,000 or fewer customers. The estimated time burden for larger systems may include evaluating QA/QC procedures, or for systems without a laboratory, time to contact

contract laborato ries to obtain QA/QC information.

4.2.4 Sample Methodology Element

The Sample Methodology Element includes the time to evaluate whether proper sampling techniques were used and whether proper sample handling procedures were followed. AnyTechnology and Cost Document for the 4-6

Final Revised T otal C olifo rm Rule 

### deviations are identifi ed, documented

, and corrected. Cost estimates for systems serving 1,000 customers or fewer are based on time spent contacting an external advisor to evaluate the situation and to determine or receive confirmation on the steps to follow, as well as time fo r a review of procedures and equipment. Cost estimates for systems serving more than 1,000 customers include time for communication between a technician and a manager to evaluate whether proper sampling techniques were used, time for a review of proper procedures, and will likely involve time for a discussion with external ad visors, such as a laboratory and/or the State. Adherence to proper sample handling techniques is also evaluated, so this step could occur concurrently with the initial evaluation. So me additional time will be devoted towards preparing handouts to guide and support the discussion, such as current sample handling, Standard Operating Procedures ( SOPs ), and methods (such as Standard Methods or EPA methods). Time will also be needed to identify and correct any deviations from established sampling and sample handling protocol.

4.2.5 Event Situational Element

Event Situational Element include s a review of any significant system events that may have influenced the samples. These may include main breaks, main repairs, pressure events, treatment problems, source water changes, power outages, distribution system operations (such as flushing), weather events, or vandalism. Cost estimation was based on the time needed to match specific sampling dates w ith specific event dates. In addition, this review may require interacting with non

- PWS personnel, such as construction crews. Time required will increase with increasing size and complexity of the system (multiple sources, larger distribution systems,

e tc.) . For systems serving 4,100 customers and larger, additional time was allotted to evaluate the information collected through the review process and to evaluate the significance of this

information.

4.2.6 Operational Data Element

The Operational Data Elemen t involves collecting other data that may have influenced the sample, such as chlorine residual, other water quality parameters, and treatment parameters. The information collected is evaluated through a review process to determine whether it may

have aff ected water quality at the time and location of sampling. Time estimates consider that the review is taking place at the end of the month and therefore specific data collected will have to be matched to specific sampling events. Aside from those associat ed with a significant effect on operations, treatment problems will likely not be recognized without reviewing available data from wells or treatment facilities to link changes in performance to specific results of collected samples. Cost estimates for this element also assume some time spent evaluating the significance of the data collected through a review process.

4.2.7 Historical Trend Element

The Historical Trend Element includes time for personnel to review the history of samples in the system, and a revi ew of the history of samples at the site in question. Each of these review phases is further subdivided into three phases for time estimation purposes: data compilation, summarization, and evaluation. Data compilation includes compiling dataTechnology and Cost Document for the 4-7

Final Revised T otal C olifo rm Rule 

### associated with collected TC samples for trend analysis, such as sources in production, tank release patterns, and water quality parameters.

4.2.8 Sample Tap Element

The Sample Tap Element involves an inspection and evaluation of the condition of the sampling tap

. In ad dition, some time is allotted to evaluate the condition of the sampling taps

. These time estimates were consistent across all trigger levels.

4.2.9 Sample Site Element

The Sample Site Element includes the time for an inspection and evaluation of the facility in which the sample was collected. For most utilities, there will likely be limited opportunities to make any changes to the facility where the sample tap is located. Therefore, the focus will be on the sample tap and associated plumbing.

4.2.10 Sample Area Ele ment

The Sample Area Element is included if positive follow

- up samples are present at other locations away from the original sample site. This assessment may include some or all of the above elements (such as Sample Tap and Sample Site Elements), and also includes inspection of

valves and tanks.

4.2.11 Third Party Element

This element includes time for contracting with a third party consultant: identification of contractor options, drafting a scope, procurement review, management review, governing board approval, proposal distribution, proposal review, management review of proposals, drafting a contract, financial and legal review, dialog with State , and governing board approval. With increasing system size, some additional time is devoted towards management rev iew of proposals and the financial and legal review.

4.2.12 Report Element

A report of the results of the assessment performed by the PWS in response to a treatment technique trigger will need to be completed and submitted to the state authority. The cost

esti mate is based on time to complete the report, a chain of command review, and possibly a legal review and briefing.



## 4.3 Unit Cost Estimates of Assessments

4.3.1 Methodology

The cost estimates presented in this chapter were informed by input from States and industry received during the proceedings of the TCRDSAC and the associated TCRDSAC TWG meetings. Specific cost estimates are provided for each system type, either a CWS or non

-Technology and Cost Document for the 4-8

Final Revised T otal C olifo rm Rule 

### community water system (NCWS), on the size categories presented in Exhibit 4 -2 and for t he triggers listed in Exhibit 4 -3. For each of the elements presented in Exhibit 4-1, an estimate is

made for: (1) the percentages of systems that currently spend time on that element (under the

1989 TCR, as implemented) or the percentage of systems that are anticipated to spend time on that element (under the R TCR) and (2) the number of hours that are currently spent on that element (under the 1989 TCR, as implemented) or the number of hours that are anticipated to be spent on that element (under the R TC R). The product of (1) and (2) is taken for each element and these products are summed to calculate the estimated average labor burden incurred by a given system type/size for a given type of assessment. This approach recognizes the differences in responses to the various triggers and system size/type categories and the differences between what is happening under the 1989 TCR, as implemented, and what is anticipated to happen under

the RTCR.

Exhibit 4

- 2: Categories for which cost estimates are developed

NCWS ≤ 1,000

1,001

- 4,100

4,101

- 33,000

33,001

- 96,000

>96,000

CWS ≤ 100

101

- 500

501

- 1,000

1,001

- 4,100

4,100

- 33,000

33,001

- 96,000

>96,000



### Exhibit 4 -3: Violations and triggers leading to assessments

1989 TCR, as implemented Nonacute MCL Viola tion

Acute MCL Violation

RTCR Level 1 Trigger

Level 2 Trigger (Nonacute)

Level 2 Trigger (Acute)



### As an example, consider the labor burden estimates for the 1989 TCR, as implemented, incurred by CWSs serving between 1,001 and 4,100 people. Exhi bit 4

- 4 includes the elements that might make up an assessment and how the percentages of systems implementing those elements and the labor hours associated with those elements vary depending on the type of MCL violation. The exhibit indicates that, on average, under the 1989 TCR as it is implanted now, 22 system labor hours are spent on assessment activities following a nonacute MCL violation and 29 system labor hours are spent on assessment activities following an acute MCL violation.

S ome systems spend more time than this on assessments and some spend less. ThisTechnology and Cost Document for the 4-9

Final Revised T otal C olifo rm Rule 

### methodology is meant to capture the average for the purposes of developing national cost estimates for the comparison of rule options.

Exhibit 4

- 4: 1989 TCR (as implemented) Labor Burden Estim ate for Assessments done by CWSs serving 1,001-4,100

Nonacute MCL Violation Acute MCL Violation

Percentage of Systems
performing

Element Estimated

Hours

Associated

with
performing

Element Average

Burden

Associated

with Element (hrs) Percentage of System s performing

Element Estimated

Hours

Associated

with
performing

Element Average

Burden

Associated

with Element (hrs)

A B C = A* B D E F = D * E

Notification

Element 100% 3 3 100% 3 3

System Specific

Element 100% 1 1 100% 1 1

Sample
Analytical

Element 0% 0 0 0% 0 0

Sample
Methodology

Element 80% 3 2.4 80% 3 2.4

Event

Situational

Element 10% 5.5 0.55 100% 5.5 5.5

Operational

Data Element 60% 4 2.4 60% 4 2.4

Historical

Trend Element 100% 3 3 100% 3 3

Sample Tap

Element 80% 1.5 1.2 100% 2 2

Sample Site

Element 5% 2 0.1 100% 2 2

Sample Area

Element 30% 4 1.2 5% 3 0.15

Third Party
Consulting

Element 0% 0 0 0% 0 0

Report

Element 100% 7.5 7.5 100% 7.5 7.5

Total 22.35 28.95Technology and Cost Document for the 4- 10

Final Revised T otal C olifo rm Rule 

### As a second example, consider NCWSs serving 1,000 or less people condu cting assessments under the RTCR. The elements and estimates of percentages of systems implementing the elements and labor hours associated with implementing the elements are presented in Exhibit 4-5. The exhibit indicates that, on average, 7, 9, and 21 system labor hours are anticipated to be spent on Level 1, Level 2 (nonacute), and Level 2 (acute) assessments, respectively. Recall that for the purposes of this document, a Level 2 (acute) assessment refers

to a Level 2 assessment that is associated wit h the presence of E. coli while a Level 2 (nonacute) assessment is not associated with the presence of E. coli. Based on input from industry and States, EPA believes that the system burden associated with conducting a Level 2 assessment will likely vary d epending on whether there is E. coli present.Technology and Cost Document for the 4- 11 Final Revised Total Coliform Rule 

### Exhibit 4

- 5: RTCR Labor Burden Estimate for Assessments done by NCWSs serving ≤1,000

Level 1 Assessment Level 2 Assessment (nonacute ) Level 2 Assessment (acute)

Percentage of
Systems doing

Element Estimated

Hours

Associated

with Element Average Burden

Associated with

Element (hrs) Percentage of
Systems doing

Element Estimated H ours
Associated with

Element Average Burden

Associated with

Element (hrs) Percentage of
Systems doing

Element Estimated Hours

Associated with

Element Average Burden

Associated with

Element (hrs)

G H I = G * H J K L = J * K M N O = M * N

Notification

El ement 100% 0 0 100% 0.5 0.5 100% 2 2

System Specific

Element 0% 0 0 100% 0.3 0.3 100% 1 1

Sample Analytical

Element 0% 0 0 100% 0 0 100% 1 1

Sample
Methodology

Element 50% 1 0.5 100% 0.5 0.5 100% 1 1

Event

Situational

Element 100% 1 1 100% 2 2 100% 2 2

Operational

Data Element 60% 0.3 0.18 40% 0.5 0.2 40% 1 0.4

Historical Trend

Element 100% 0.5 0.5 100% 0.5 0.5 5% 4 0.2

Sample Tap

Element 100% 1 1 100% 1 1 100% 1 1

Sample Site

Element 100% 1 1 100% 1 1 100% 1 1

Sample Area

Element 100% 1 1 100% 1 1 20% 7 1.4

Third Party

Element 0% 0 0 0% 0 0 50% 16 8

Report Element 100% 2 2 100% 2 2 100% 2 2

Total 7.18 9 21Technology and Cost Document for the 4- 12 Final Revised Total Coliform Rule 

### Exhibit 4-6 summarizes the labor burden associated with conducting assessments for all categories and types of treatment technique triggers, both under the 1989 TCR and the RTCR. Exhibit 4-7 presents the unit costs (2007$). Labor hours in Exhibit 4- 6 are multiplied with the hourly labor rates presented in Chapter 2 of this document to calculate the monetary burden in Exhibit 4-7. Appendix A includes detailed tables with the elements of assessments, percentages, and hours (similar to Exhibit 4-4 and 4- 5) for all system categories.

Exhibit 4

- 6: Estimated Labor Burden Associated with Assessments ( H ours)

System Type/Size 1989 TCR , as implemented RTCR

Nonacute

MCL

Violation Acute MCL

Violation Level 1
Trigger Level 2
Trigger ( N onacute) Level 2
Trigger (Acute)

NCWS ≤ 1,000 4 6 7 9 21

NCWS 1,001

- 4,100 4 6 8 10 29

NCWS 4,101

- 33,000 30 36 41 69 71

NCWS 33,001

- 96,000 59 75 68 116 121

N CWS >96,000 108 117 159 238 252

CWS ≤ 100 11 14 19 22 23

CWS 101

- 500 11 14 19 22 23

CWS 501

- 1,000 13 15 20 23 24

CWS 1,001

- 4,100 22 29 31 46 48

CWS 4,100

- 33,000 30 36 41 69 71

CWS 33,001

- 96,000 59 75 68 116 121

CWS >96,000 108 117 159 238 252



### Exhi bit 4

- 7: Estimated Unit Costs Associated with Assessments (2007$)

System Type/Size 1989 TCR , as implemented R TCR

Nonacute

MCL

Violation Acute MCL

Violation Level 1
Trigger Level 2
Trigger ( N onacute) Level 2
Trigger (Acute)

NCWS <100 $ 100.40 $ 150.60 $ 175 .70 $ 225.90 $ 527.10

NCWS 101

- 500 $108.12 $162.18 $189.21 $243.27 $567.63

NCWS 501

- 1000 $115.84 $173.76 $202.72 $260.64 $608.16

NCWS 1001

- 4100 $118.92 $178.37 $237.83 $297.29 $862.14

NCWS 4101

- 33000 $1,079.87 $1,295.85 $1,475.83 $2,483.71 $2,555.70

NCW S 33001

- 96000 $2,147.01 $2,7 29.25 $2,4 74.52 $4,22 1.24 $4,40 3.19

NCWS >96000 $4,428.97 $4,802.27 $6,516.49 $9,769.61 $10,332.47

CWS <100 $2 76 .10 $3 51.40 $ 476.90 $5 52.20 $ 577.30

CWS 101

- 500 $297.33 $3 78.42 $51 3.57 $ 594.66 $6 21.69

CWS 501

- 1000 $376.48 $ 43 4.40 $5 79.20 $6 66.08 $6 95.04

CWS 1001

- 4100 $6 54.04 $86 2.14 $92 1.60 $1,3 67.54 $1,4 27.00

CWS 4100

- 33000 $1,07 9.87 $1,29 5.85 $1,47 5.83 $2,4 83.71 $2,55 5.70

CWS 33001

- 96000 $2,147.01 $2,7 29.25 $2,4 74.52 $4,224. 24 $4,40 3.19

CWS >96000 $4, 428.97 $4, 798.05 $6, 5 20.43 $9,76 0.14 $10,33 4.26Technology and Cost Document for the 4- 13 Final Revised Total Coliform Rule 

### 4.3.2 Assumptions

Several underlying assumptions were made for the cost est imation development as

follows:

• The costs estimates presented in this chapter and the assumptions that support those

estimates were informed by input from Sta tes and industry received during the proceedings of the TCRDSAC and the associated TCRDSAC TWG meetings.

• Estimated percentage of systems undertaking actions is a function of estimated value, expertise at different system sizes, and available resources.

• As system size increases

, there is an increasing level of expertise, and there are also increasing levels of potential complexity, greater numbers of positive samples required to trigger investigation, larger numbers of individuals engaged in aspects of investigation, and increased levels of management and supervisory involvement.

• At very small system sizes, State direction will dominate what actions systems tend to focus on in the investigation process.

• As system size increases

, there is greater automation of data systems but a parallel increase in the comp lexity of interpreting any data.

• Separate estimates were not developed for NCWSs serving >4,100 people. Rather, the burden estimates for these larger NCWSs are assumed to be the same as similarly

sized CWSs

.

• For all levels of investigation, it is assumed that a “toolbox” type of approach is used such that not all systems will necessarily conduct all elements of the investigation.Technology and Cost Documen t for the 5-1 Final Revised Total Coliform Rule 

## 5 Estimated Unit Costs of Corrective Actions

This chapter discusses various examples of corrective actions that can help mitigate or eliminate sources of coliform contamination that may occur during operation and maintenance of

a treatment process or a water system. Exhibit 5 -1 provides a summary of those corrective actions, and the purpose or type of water quality problem addressed by each action.

Exhibit 5-1 : Summary of Corrective Actions

Action Purpose

Flushing – Section 5.1
 Keep system clean and free of sediment
Scheduled / Routine Flushing (Section 5.1.1)

 Reduce disinfectant demand of pipe surfaces

Unsche duled / Spot Flushing (Section 5.1.2)

 Remove stagnant, untreated, or contaminated water

 Address water quality deterioration at dead

- ends

Sampler Training – Section 5.2
 Rein forces proper sampling and sample handling
procedures to obtain uncontaminated samples

Replacement / Repair of Distribution System

 Reduce potential sources / pathways of

Components – Section 5.3 contamination from improper installation or material

Valves (Section 5.3.1) degradation

Water Mains (Section 5.3.2)

Fittings (Section 5.3.3)

Hydrants (Section 5.3.4 )

Meters (Section 5.3.5)

Dedicated Sample Taps (Section 5.3.6)

Maintenance of Adequate Pressure – Section 5.4
 Minimize sudden changes in water velocity which

Booster Pumping Stations (Section 5.4.1) impact s ystem pressure

Pump Modifications or Replacement (Section 5.4.2)  Reduce risk of backflow and intrusion contamination
resulting from low pressures Variable Frequency Drives (Section 5.4.3)

 Reduce risk of hydraulic disturbances to pipe surface Elevated Storage Facilities (Section 5.4.4) biofilm Surge Relief Valves (Section 5.4.5)

Surge Tanks (Section 5.4.6)

Maintenance of Appropriate Hydraulic Residence Time

 Mitigate water quality problems associated with

– Section 5.5 increased water age (e.g. higher disinfection

Looping Dead Ends (Section 5.5. 1) byproduct ( DBP ) for mation, reduced disinfectant
residual, increased microbial activity, nitrification, and Installing Appropriate Main Sizes (Section 5.5.2)

taste

- and

- odor problems) Automated Flushing Devices (Section 5.5.3)

Storage Facility Modifications (Section 5.5.4)

Storage Facility Maintenance – Section 5.6
 Remove contamination from birds and insects
Inspecting / Cleaning of Tanks (Section 5.6.1)

 Remove accumulated sediment

Lining of Storage Tanks (Section 5.6.2)

 Protect against tank wall corrosion

Vent / Hatch Repair (Section 5.6.3)

Tank Repair (Section 5.6.4)

Booster Disinfection – Section 5.7
 Improve or maintain disinfectant residual in the

Chlorine (Section 5.7.1) distribution system

Chloramine (Section 5.7.2)Technology and Cost Documen t for the 5-2 Final Revised Total Coliform Rule Action Purpose

Cross Connection Control and Backflow Prevention

 Prevent flow of non

- potable substances i nto the

Program – Section 5.8 distribution system

Backflow Prevention Devices (Section 5.8.1)

Program Administration (Section 5.8.2)

Addition or Upgrade of On

- line Monitoring and

 Automatically control and monitor disinfectant

Control – Section 5.9 dosages and wat er quality parameters (other than

Water Quality Monitoring & Control (Section 5.9.1) total coliform)

Pressure Monitoring & Control (Section 5.9.2)  Monitor pressure levels to identify physical problems in the system (e.g. pipe breaks, leaking valves, etc.)

Addition of Security Measures – Section 5.10
 Monitor potential locations for vandalism or securi ty

breaches that could lead to water contamination

 Increase public confidence in protection of their

drinking water

Development and Implementation of an Operations

 In tegrate all operations and maintenance functions to

Plan – Section 5.11 meet the goals of flow, pressure, and water quality

O&M SOP Training (Section 5.11.1)

 Establish a routine distribution system sampling plan

O&M Plan Revision (Section 5.11.2)

 Implement an inspections and maintenance program

 Define an emergency response plan for the

distrib ution system



### The costs incurred for implementing each of these corrective actions is described in detail in the following sections. The costs represent a typical estimate for each type of corrective action. However, system specific characteristics such as system configuration, climate, soil conditions, local construction practices and requirements, and labor rates may impact the final cost for a particular water utility to implement a corrective action.

The c osts provided in this chapter were obtained f rom equipment price lists and quotes, cost estimates from similar projects, best practices from PWS s, and from engineering cost data sources ( R.S. Means). Where appropriate, the costs are separated into categories of PWS s based on the population size that each system serve s. The labor rates used in this chapter are described in Chapter 2 of this document. Assumptions regarding labor burden, including number of employees and shift hours, were based on best professional judgment and typical practices from

PWSs and are described in each of the following sub- sections. All labor costs are assumed to include basic items that would be part of normal operations for a PWS such as tools, field equipment, vehicle access and incidentals.

All costs are presented in 2 007 dollars; however, some estimates were obtained from vendors in 2008 and 2009 and were subsequently adjusted to 2007 using construction cost indices (R.S. Means, 2009). For some items, installed costs were not available so installation was assumed to be a percentage of the capital cost based on PWS information and project experience. Wherever it was assumed that a contractor would execute the work to implement any of the corrective actions, a 22.5% factor for overhead and profit was applied (R.S. Means, 2009). This overhead factor includes items such as insurance, construction permits, field offices, temporary facilities, storage, mobilization and demobilization, barricades, signs, and security

measures for the contractors.Technology and Cost Documen t for the 5-3 Final Revised Total Coliform Rule 

### For corrective actions requi ring construction of new facilities or significant modification of existing facilities, a PWS will incur additional costs related to architectural and engineering services, surveying, land acquisition, and permitting. The extent of these costs will vary b ased on a number of factors including PWS staff availability to perform services in-house, quantity and location of land available for construction, and other site- specific considerations. These

costs have been excluded from all estimates.

For all costs t hat required a pumping capacity in the calculations, the annual average flow rates by system presented in Exhibit -5- 2 were assumed.

Exhibit 5-2 : Average System Flow Rates

System Size Average Population Aver age Flow (gpd) 1 Percent of
Average
per Pump

Station Total Flow

per Pump Station (gpm) Total Flow

per Pump

Station (MGD) # Duty
Pumps

per
Station Flow per

Pump (gpm) 2

A B C=B*100 D E=C*D/1440 F=C*D/10 6 G H=E/G

< 100 50 5,000 100% 3 0.01 1 10

101 - 500 300 30,000 100% 21 0.03 1 30

501 - 1,000 750 75,000 100% 52 0.08 1 60

1,001

- 4,100 2,550 255,000 33% 58 0.08 1 60

4,101

- 33,000 18,550 1,855,000 33% 425 0.6 1 430

33,001 - 96,000 64,500 6,450,000 33% 1,478 2.1 2 740

96,001 - 500,000 298,00 0 29,800,000 10% 2,069 3.0 2 1,040

500,001

- 1,000,000 750,000 75,000,000 10% 5,208 7.5 2 2,6 10

> 1,000,00 0 1,500,000 150,000,000 10% 10,417 15.0 2 5,2 10

1 Estimate assumes average usage rate of 100 gallons per person per day

.

2 Estimates r ounded up to the nearest 10.



## 5.1 Flushing

A water main flushing program helps to keep the system clean and free of sediment, can reduce the disinfectant demand of pipe surfaces, and removes stagnant water and any untreated or contaminated water that may have entered the system (Kirmeyer and Friedman 2000). Flushing can also be used to address water quality deterioration at dead-ends. The following sections discuss scheduled system-wide flushing, and periodic unscheduled (or “spot”) flushing

which can be used to addr ess isolated water quality problems, including total coliform positive samples.

The volume of water flushed is related to the length of flushing time and flow rate from the hydrant. Typically, PWS s flush until a disinfectant residual can be measured or ot her water quality target is reached. These practices are similar for all types of disinfectants and would also hold true for undisinfected systems.

5.1.1 Scheduled / Routine Flushing

Minimum elements of a flushing program are outlined in the AWWA G200 Standard (AWWA 2004a) and include: (1) a preventive approach to address local problems or customer concerns and routine flushing to avoid water quality problems; (2) use of an appropriate flushingTechnology and Cost Documen t for the 5-4 Final Revised Total Coliform Rule 

### velocity to address water quality concerns; and (3) written procedur es for all elements of the flushing program including water quality monitoring, regulatory requirements and specific flushing procedures.

Exhibit 5-3 summarizes the estimated annual cost for routine flushing a complete water distribution system (at a rate of once per year). These costs include estimates of labor, cost of lost water, and cost of treatment (dechlorination) prior to disposal. In smaller systems, maintenance of a routine flushing program may be only one aspect of an operator’s duties; however, in larger systems one or more full- time employees may be entirely dedicated to this program. Column E presents the estimated percent commitment of operators to a routine flushing program, based on PWS size. Estimates of the volume of water flushed are based on

mid -point population of each PWS category, water usage rate of 100 gallons per person per day (or gallons per capita per day (GPCD )), and 0.47% average percentage of water flushed per water produced, as obtained from Cost and Benefit Analysis of Flushing (Hasit, 2004). Value of lost water is based on an average billing rate of $3.00 per thousand gallons (kgal), also obtained

from Cost and Benefit Analysis of Flushing , and adjusted to 2007 dollars. Dechlorination costs

were estimated based on chemical consumption of dechlorinating agents per gallon of water flushed. However, treatment requirements for discharge of flushing water will vary according to locality and should be examined on a case- by

- case basis. Public notification costs were not

inc luded in this estimate.Technology and Cost Document for the 5-5 Final Revised Total Coliform Rule 

### Exhibit 5-3 : Estimated Annual Costs for Routine Flushing (2007$)

System Size Average
System Population Labor

Rate 1 Number of
Employees

Involved in

Flushing

Program Percent Time

Co mmitted to Flushing 2 Total Labor (hours per

year) Total Labor

Cost Flushed

Water

Volume 3

(kgal/yr) Value of

Water Flushed per

year 4 Cost of Disposal of

Flushed
Water per

year 5,6,7,8 Total

Annual Cost

(2007$) 9

A B C D E F=D*E*2080 G=C*F H=B*100

*0.0047*36

5 /1000 I=H*3 J=H*3/8.5 K=G+I+J

< 100 50 $25.10 1 1% 21 $522 9 $26 $3 $ 560

101 - 500 300 $27.03 1 3% 62 $1,687 51 $154 $18 $1,860

501 - 1,000 750 $28.96 1 4% 83 $2,409 129 $386 $45 $2,850

1,001

- 4,100 2,550 $29.73 1 5% 104 $3,092 437 $1,312 $ 154 $4, 560

4,101

- 33,000 18,550 $36.00 1 20% 416 $14,976 3,182 $9,547 $1,123 $25, 650

33,001 - 96,000 64,500 $36.39 1 90% 1,872 $68,122 11,065 $33,195 $3,905 $105,230

96,001 - 500,000 298,000 $41.01 2 100% 4,160 $170,602 51,122 $153,366 $18,043 $342,010

500,001

- 1,000,000 750,000 $41.01 3 100% 6,240 $255,902 128,663 $385,988 $45,410 $687,300

> 1,000,00 0 1,500,000 $41.01 6 100% 12,480 $511,805 257,325 $771,975 $90,821 $1,374,600

1 See Exhibit 2 -5 in Chapter 2

, Estimated Unit Costs of L abor.

2 Estimate based on typical PWS practices.

3 Average ratio of water flushed per water produced = 0.47%, as reported in Cost and Benefit Analysis of Flushing (Hasit, 2004).

4 Water produced based on mid

- point population of each PWS category, and aver age usage rate of 100 GPCD.

5 Value based on average price that PWSs charge for water, as reported in Cost and Benefit Analysis of Flushing (Hasit, 2004) and adjusted to 2007 dollars ($3.00 / kgal).

6 Assumes that dechlorinator attachments are part of typi cal equipment already owned by the PWS.

7 Cost per dechlorination tablet obtained from USA Bluebook catalog, 2008 and adjusted to 2007 dollars ($3.00 / tablet)

.
8 Each dechlorination tablet neutralizes 8,500 gallons of water with 1ppm of chlorine accordi ng to manufacturer recommendations.

9 Estimates rounded up to the nearest $10.Technology and Cost Document for the 5-6

Fina l Revised Total Coliform Rule 

### 5.1.2 Unscheduled / Spot Flushing

Upon obtaining a positive sample for TC, a common response is to flush the area near the sample site to draw in fresh water and remove any contaminated water that may be present. This unscheduled spot flushing is different than a routine flushing program in that the flushing only occurs when triggered by a water quality measurement, customer complaint, or similar event.

Exhibit 5-4 summarizes the estimated cost for a single unscheduled / spot flushing event. As in Section 5.1.1, these costs include estimates of labor, cost of lost water, and cost of treatment (dechlorination) prior to disposal. Labor estimates were based on half-day flushing

even ts, with 1 or 2 person crews depending on system size. Flushed water volumes were based on a single hydrant flushing event, size of the hydrant and maximum discharge flows, and an

assumed 1 -hour flush time. Duration was based on the assumption that it takes longer to achieve a reasonable disinfectant residual when spot flushing problem areas than it takes when performing routine flushing in a healthy system. According to Cost and Benefit Analysis of Flushing , routine flushing is normally maintained for 5 to 40 minutes (with 15 minutes being the most common); however, actual durations are based on time it takes for water quality to improve, water color to clear, or both.Technology and Cost Document for the 5-7 Final Revised Total Coliform Rule 

### Exhibit 5-4 : Estimated Unit Cost f or Spot Flushing (2007$)

System Size Labor Rate 1 Shift Hours 2 Total Labor

Cost Average Hydrant Size Maximum Flushing Flow (GPM) Flushed Water Volume (kgal) 3 Value of Water

Flushed 4 Cost of
Disposal of

Flushed

Water 5,6,7 Total Cost 8

A B C D=B*C E F G=F*60 /1000 H=G*$3.00 I=G*$3.00/8.5 J=D+H+I

< 100 $25.10 4 $100 4 500 30 $90 $11 $210

101 - 500 $27.03 4 $108 4 500 30 $90 $11 $210

501

- 1,000 $28.96 4 $116 4 500 30 $90 $11 $ 220

1,001

- 4,100 $29.73 4 $119 6 750 45 $135 $16 $270

4,101 - 33,000 $36.00 8 $288 6 750 45 $135 $16 $440

33,001 - 96,000 $36.39 8 $291 6 750 45 $135 $16 $450

96,001

- 500,000 $41.01 8 $328 8 1000 60 $180 $21 $ 530

500,001

- 1,000,000 $41.01 8 $328 8 1000 60 $180 $21 $ 530

> 1,000,00 0 $41.01 8 $328 8 1000 60 $180 $21 $530

1 See Exhibit 2 -5 in Chapter 2

, Estimated Unit Costs of Labor.

2 Shift hours for systems serving < 500 to 4,100 assume 1

- person crew, and half

- day flushing event. Systems serving > 4,100 assume 2

- person crew and half

- day flushing event.

3 Flush ed water volume based on 1

- hour (60

- minute) flushing event.

4 Value based on average price that PWSs charge for water, as reported in Cost and Benefit Analysis of Flushing (Hasit, 2004) and adjusted to 2007 dollars ($3.00 / kgal).

5 Assumes that dechlorina tor attachments are part of typical equipment already owned by the PWS.

6 Cost per dechlorination tablet obtained from USA Bluebook catalog, 2008 and adjusted to 2007 dollars ($3.00 / tablet).

7 Each dechlorination tablet neutralizes 8,500 gallons of water with 1ppm of chlorine according to manufacturer recommendations.

8 Estimates rounded up to the nearest $10.Technology and Cost Document for the 5-8 Final Revised Total Coliform Rule 

## 5.2 Sampler Training

EPA establishes sampling requirements to determine if a distribution system is in compliance with regulatory requirements. Impl ementation of a sampler training program provides guidelines for procedures that samplers must follow to collect valid, uncontaminated samples for analysis of total coliform in the distribution system. Training sessions for operators reinforce proper samp ling and sample handling procedures to obtain uncontaminated samples.

The costs for sampler training assume that the operator/sampler attends an external, 8

- hour training class. The costs include travel costs, training fees, and the operator labor costs

a ssociated with the time spent at the training session . Exhibit 5-5 summarizes the cost for sampler training.

Exhibit 5-5 : Estimated Costs Operator Training/Certification (2007$)

System Size Labor Rate 1 Cou rse
Time (hours) 2 Total Labor

Cost Travel 3 Training/

Certification

Fees 4 Total (2007$) 5

A B C D = B*C E F G = D + E + F

< 100 $25.10 8 $201 $31 $125 $360

101

- 500 $27.03 8 $216 $31 $125 $ 380

501 - 1,000 $28.96 8 $232 $31 $125 $390

1,001 - 4,100 $29.73 8 $238 $31 $125 $400

4,101 - 33,000 $36.00 8 $288 $31 $125 $450

33,001

- 96,000 $36.39 8 $291 $31 $125 $ 450

96,001 - 500,000 $41.01 8 $328 $31 $125 $490

500,001 - 1,000,000 $41.01 8 $328 $31 $125 $490

> 1,000,00 0 $41.01 8 $328 $31 $125 $4 9 0

1 See Exhibit 2 -5 in Chapter 2

, Estimated Unit Costs of Labor.

2 Assumes an 8

- hour training/certification course

.
3 Assumes 60 miles of round

- trip driving distance at $0.52/mi.

4 Assumes a $125 training fee for members based on costs from the National R ural Water Association.

5 Estimates rounded up to the nearest $10.



## 5.3 Replacement / Repair of Distribution System Components

Distribution system components and appurtenances such as valves, pipe, fittings, hydrants, meters, and sample taps are integral parts of a PWS . These components are also potential sources of contamination if improper installation or material degradation allows leaks or other entry points for coliforms into a distribution system.

These individual components are described in the following sections and costs for the repair or replacement of these components are presented. In general, a three

- person labor crew was assumed for replacement / repair of underground facilities (which require digging, replacement of pavement or turf, trench safety considerations, maintenance of traffic, etc.) and a

two -person crew was assumed for above- ground / exposed facilities. All activities were assumed

to take a full 8 -hour day, based on the need to mobilize equipment, perform the necessaryTechnology and Cost Document for the 5-9 Final Revised Total Coliform Rule 

### excavation, setu p, and restore the surface condition after replacement / repair. Where appropriate, assumptions on component size were made based on the population range served by a distribution system. The most common pipe diameters are 6 and 8 inches, even for large

s ystems, from the TCR Issue Paper: Distribution System Inventory, Integrity, and Water Quality (EPA 2007).

5.3.1 Valves

Valves are located throughout a distribution system to isolate portions of the system as needed. Leaks at the connection points between the va lve and the adjacent pipe, as well as a valve seat or valve body, can create a pathway for contamination.

Prior to replacing or repairing a valve, it should be identified as the cause of the leak. Some isolation valves throughout the distribution system are located below grade, making a leak

difficult to locate. A number of technologies have been developed to locate leaks below grade.

As butterfly valves are typically the most common type of valve encountered in a water distribution system, this type o f valve was used as the basis for the cost estimation presented in

Exhibit 5-6 . Costs are presented on a per valve basis. Labor estimates are based on an 8 -hour

shift and 3- person crew.

Exhibit 5-6 : Estima ted Costs to Replace Valve (2007$)

System Size Labor Rate 1 Shift Time (hours) 2 Total Labor

Cost 3 Valve Size (in.) 4 Valve Cost 5,6 Total Cost (2007$) 7

A B C D=B*C*3 E F G=D+F

<100 $25.10 8 $602 4 $385 $990

101

- 500 $27.03 8 $649 4 $385 $1, 040

501

- 1,000 $28.96 8 $695 4 $385 $1,080

1,001

- 4,100 $29.73 8 $714 6 $565 $1,280

4,101

- 33,000 $36.00 8 $864 6 $565 $1,430

33,001

- 96,000 $36.39 8 $873 6 $565 $1, 440

96,001

- 500,000 $41.01 8 $984 8 $785 $1, 770

500,001-1,000,000 $41.01 8 $984 8 $785 $1,770

> 1,000,00 0 $41.01 8 $984 8 $785 $1,770

1 See Exhibit 2 -5 in Chapter 2

, Estimated Unit Costs of Labor.

2 Shift time assumes 8 hours needed for mobilization, setup, and cleanup of site.

3 Labor cost assumes a t hree

- person crew needed for underground valve replacement.

4 Based on commonly

- occurring valve sizes in similarly

- sized systems (EPA, 2007).

5 Valve cost assumed a cast iron, mechanical joint, butterfly valve with box.

6 Valve costs obtained from R.S. Mean s, 2007.

7 Estimates rounded up to the nearest $10.



### 5.3.2 Water Mains

The condition of distribution system piping can be vital to the quality of water being conveyed to a community. Contaminants may enter through holes, breaks, cracks or joints in the piping. The condition of a pipe can vary based on type, age, and location of the pipe.Technology and Cost Document for the 5- 10 Final Revised Total Coliform Rule 

### Depending on the condition of the pipe, the water main can be replaced or repaired to stop infiltration into the system.

Prior to replacing or repairing a water main, the locat ion of the break or leak must be determined. Since most of the distribution system is below grade, locating a leak can be difficult. A number of technologies have been developed to evaluate the condition of below grade piping to locate leaks.

Costs presented in Exhibit 5 -7 are based on replacement of a 20 -foot pipe segment, which is the nominal laying length of standard ductile iron pipe. Labor estimates are based on an 8

- hour shift and 3-person crew.

Exhibit 5-7 : Estimated Costs to Replace Ductile Iron Pipe (2007$)

System Size Labor Rate 1 Shift Time (hours) 2 Total Labor

Cost 3 Pipe Size (in.) 4 Pipe Cost 5,6,7

(per 20 ft.) Total Cost (2007$) 8

A B C D=B*C*3 E F G=D+F

< 100 $25.10 8 $602 3 $167 $770

101 - 500 $27.03 8 $649 4 $167 $820

501

- 1,000 $28.96 8 $695 4 $167 $ 870

1,001

- 4,100 $29.73 8 $714 6 $196 $910

4,101

- 33,000 $36.00 8 $864 6 $196 $1,060

33,001

- 96,000 $36.39 8 $873 6 $196 $1,070

96,001

- 500,000 $41.01 8 $984 8 $265 $1, 250

500,001

- 1,000,000 $41.01 8 $984 8 $265 $1, 250

> 1,000,00 0 $41.01 8 $984 8 $265 $1,250

1 See Exhibit 2 -5 in Chapter 2

, Estimated Unit Costs of Labor.

2 Shift time assumes 8 hours needed for mobilization, setup, and cle anup of site.

3 Labor cost assumes a three

- person crew needed for underground pipe replacement.

4 Based on commonly

- occurring valve sizes in similarly

- sized systems (EPA, 2007).

5 Pipe cost assumed cement lined, ductile iron, push

- on joint pipe.

6 Pipe cos t based on 20 feet segments, as standard nominal pipe laying lengths are 20 feet (American Pipe Manual, 18th Edition,

2004).

7 Pipe costs obtained from R.S. Means, 2007.

8 Estimates rounded up to the nearest $10.



### 5.3.3 Fittings

There are many types of fittings l ocated throughout a distribution system. The most common type of distribution system fitting is a cross. A cross has four connections; therefore making it more susceptible to leaks. Leaks can occur because of a crack on the fitting or through the gasket between the fitting and another appurtenance, e.g. valve, cap, or pipe.

Once a leak is located and it is confirmed that the fitting is the cause of the leak, it can be replaced or repaired depending on the condition of the fitting. A portion of the distribution system will be placed out of service as this work is performed; therefore, interrupting water

service.Technology and Cost Document for the 5- 11 Final Revised Total Coliform Rule 

### Costs are presented in Exhibit 5-8 and are calculated based on material costs and labor, assuming an 8-hour shift and 3-person work crew.

Exhi bit 5-8 : Estimated Costs to Replace Fittings (2007$)

System Size Labor Rate 1 Shift Time (hours) 2 Total Labor

Cost 3 Fitting Size (in.) 4 Fitting

Cost 5,6,7 Total Cost (2007$) 8

A B C D=B*C*3 E F G=D+F

< 100 $ 25.10 8 $602 4 x 4 $368 $970

101 - 500 $27.03 8 $649 4 x 4 $368 $1,020

501 - 1,000 $28.96 8 $695 4 x 4 $368 $1,070

1,001

- 4,100 $29.73 8 $714 6 x 6 $480 $1, 200

4,101

- 33,000 $36.00 8 $864 6 x 6 $480 $1, 350

33,001 - 96,000 $36.39 8 $873 6 x 6 $480 $1,360

96,001 - 500,000 $41.01 8 $984 8 x 8 $686 $1,670

500,001

- 1,000,000 $41.01 8 $984 8 x 8 $686 $1,670

> 1,000,00 0 $41.01 8 $984 8 x 8 $686 $1,670

1 See Exhibit 2 -5 in Chapter 2

, Estimated Unit Costs of Labor.

2 Shift time assumes 8 hours needed for mobilization, setup, and cleanup of site.

3 Labor cost assumes a three

- person crew needed for replacement of underground fittings.

4 Based on commonly

- occurring fitting sizes in similarly

- sized systems.

5 Fitting cost assumed ce ment lined, ductile iron, and mechanical joint cross, with gaskets.

6 Fitting costs obtained from R.S. Means, 2007, by multiplying the tee cost by the ratio of the weight of a cross and a tee.

7 Fitting weights obtain from American Pipe Manual, 19 th Editio n.

8 Estimates rounded up to the nearest $10.



### 5.3.4 Hydrants

Hydrants are located throughout a distribution system to provide potable water at required fire flow pressures for emergency situations. Hydrant connections are tapped off the distribution system; the refore, these connections can be possible locations for coliform contamination to enter a distribution system.

Replacing a damaged or faulty fire hydrant can help eliminate sources of contamination into the distribution system as it eliminates a pathway fo r contamination. The costs included to replace a fire hydrant are presented in Exhibit 5 -9 . Costs are calculated based on material costs and labor, assuming an 8-hour shift and a 2- person crew.Technology and Cost Document for the 5- 12 Final Revised Total Coliform Rule 

### Exhibit 5-9 : Estimated Costs to Replace Hydrants (2007$)

System Size Labor Rate 1 Shift Time (hours) 2 Total Labor

Cost 3 Hydrant

Cost 4,5 Total Cost (2007$) 6

A B C D=B*C*2 E F=D+E

< 100 $25.10 8 $402 $1,225 $1,630

101

- 500 $27.03 8 $432 $1,225 $1, 660

501

- 1,000 $28.96 8 $463 $1,225 $1, 690

1,001 - 4,100 $29.73 8 $476 $1,225 $1,710

4,101 - 33,000 $36.00 8 $576 $1,225 $1,810

33,001

- 96,000 $36.39 8 $582 $1,225 $1, 810

96,001

- 500,000 $41.01 8 $656 $1,225 $1, 890

500,001-1,000,000 $41.01 8 $656 $1,225 $1,890

> 1,000,00 0 $41.01 8 $656 $1,225 $1,890

1 See Exhibit 2 -5 in Chapter 2

, Estimated Unit Costs of Labor.

2 Shift time assumes 8 hours needed for mobilization, setup, and cleanup of site.

3 Labor cost assumes a two

- pe rson crew needed for replacement of partially

- exposed hydrants.

4 Hydrant cost assumes a two

- way, 4

- 1/2 inch valve size, hydrant, partially excavated at a depth of 3 feet.

5 Hydrant costs obtained from R.S. Means, 2007.

6 Estimates rounded up to the neares t $10.



### 5.3.5 Meters

Meters are located at entry points to commercial, residential, and industrial facilities to measure the amount of water that is consumed at a particular location. Sizes for each of the meters will vary based on the type and usage requirement s of a facility. Contamination may enter through the connection points of the meter and the distribution system. Replacing a meter can help prevent contamination into the distribution system through leaks, as it eliminates a pathway for contamination.

Costs presented in Exhibit 5 -10 are based on the standard meter size for a commercial/ industrial user (such as a farm or food processing plant), as these users would likely have a much higher potential for coliform contamination. Costs are calculated bas ed on an 8 -hour shift and 2-

person crew.Technology and Cost Document for the 5- 13 Final Revised Total Coliform Rule 

### Exhibit 5-10 : Estimated Costs to Replace Meters (2007$)

System Size Labor Rate 1 Shift Time (hours) 2 Total Labor

Cost 3 Meter Cost 4,5 Total Cost (2007$) 6

A B C D=B*C* 2 E F=D+E

< 100 $25.10 8 $402 $329 $ 740

101

- 500 $27.03 8 $432 $330 $7 70

501 - 1,000 $28.96 8 $463 $330 $800

1,001 - 4,100 $29.73 8 $476 $330 $810

4,101

- 33,000 $36.00 8 $576 $330 $9 10

33,001 - 96,000 $36.39 8 $582 $330 $920

96,001 - 500,000 $41.01 8 $656 $330 $990

500,001-1,000,000 $41.01 8 $656 $330 $990

> 1,000,00 0 $41.01 8 $656 $330 $9 90

1 See Exhibit 2 -5 in Chapter 2

, Estimated Unit Costs of Labor.

2 Shift time assumes 8 hours needed for mobilization, setup, and cleanup of site.

3 Labor cost assumes a two

- person crew needed for replacement of exposed meters.

4 Meter costs assume a standard 1

- 1/2 inch bronze commercial meter, which is typically the same, regardless of system size.

5 Meter costs obtained fr om R.S. Means, 2007.

6 Estimates rounded up to the nearest $10.



### 5.3.6 Dedicated Sample Taps

The TCRDSAC recommends that routine and repeat sample siting plans should ensure that the quality of the water is representative of the distribution system, and further r ecommends

that dedicated sampling station s, or sampling taps

, be explicitly permitted . A dedicated sampling station is a device that is plumbed directly into a distribution system line to provide “improved access to the distribution system water and provi de reproducible samples that are representative of water quality at the customer’s meter” (Kirmeyer and Friedman 2000). Dedicated sampling stations should be metal construction and have unthreaded nozzles or an approved design and should be located so as to be representative of the water in the distribution system. They are typically covered to protect them from birds, insects, dirt and other sources of outside

contamination. Exhibit 5-11 is a graphic schematic detailing the components of a dedicated

sam pling station. Exhibit 5-12 is a photograph of an actual dedicated sampling station.Technology and Cost Document for the 5- 14 Final Revised Total Coliform Rule 

### Exhibit 5-11 : Dedicated Sampling Station Schematic

Source: Water Distribution System Operation and Maintenance , A Field Study Training Program. USEPA Office of

Ground Water and Drinking Water and California Department of Health Services, Sanitary Engineering Branch. Hornet Foundation Inc., Sacramento, Calif. (1989, 2nd ed.).Technology and Cost Document for the 5- 15 Final Revised Total Coliform Rule 

### Exhibit 5-12 : Dedicated Sampling Station

Source: With permission courtesy of Koraleen Enterprises.



### The c ost of a new s ampling s tation will vary depending on site conditions including cold

weather vs. warm weather installation. Exhibit 5-13 provides unit cost estimates for installation of new sampling stations. Actual cost will vary depending on whether an existing meter service could be tapped into, or whether a new service line must be installed from the main line. For the purposes of thi s estimate, it has been assumed that an existing meter service could be tapped into,

and that a 2 -person crew can achieve installation in one 8-hour shift.

Exhibit 5-13: Estimated Costs of Installing a Dedicated Sampling Tap (2007$)

System Size Labor Rate 1 Shift Time (hours) 2 Total Labor Cost 3 Sampling Tap

Cost 4 Total Cost (2007$) 5

A B C D=B*C*2 E F=D+E

< 100 $25.10 8 $402 $592 $1000

101 - 500 $27.03 8 $432 $592 $1,030

501 - 1,000 $28.96 8 $463 $592 $1,060

1,001

- 4,100 $29.73 8 $476 $592 $1,0 70

4,101

- 33,000 $36.00 8 $576 $592 $1,1 70

33,001 - 96,000 $36.39 8 $582 $592 $1,180

96,001 - 500,000 $41.01 8 $656 $592 $1,250

500,001

- 1,000,000 $41.01 8 $656 $592 $1,2 50

> 1,0 00,00 0 $41.01 8 $656 $592 $1,2 50

1 See Exhibit 2 -5 in Chapter 2

, Estimated Unit Costs of Labor.

2 Shift time assumes 8 hours needed for mobilization, setup, and cleanup of site.

3 Labor cost assumes a two

- person crew needed for installation / replace ment of exposed sample taps.

4 Material cost assumes Koraleen Enterprises cold weather station, provided by manufacturer / distributor and adjusted to 2007

dollars.

5 Estimates rounded up to the nearest $10.Technology and Cost Document for the 5- 16 Final Revised Total Coliform Rule 

## 5.4 Maintenance of Adequate Pressure

Pressure losse s can occur in the distribution system as a result of events such as flushing, main breaks, power outages, service line breaks, and fires. Pressure transients (also called pressure surges or water hammer) can occur when an abrupt change in water velocity occurs due to a sudden valve closure, pump shutdown or loss of power. The resulting pressure wave, with alternating low and high pressures, travels back and forth through the distribution system until the pressure is stabilized. Low pressure conditions i n the distribution system can allow a flow reversal or backflow of non-potable water to enter the system from a cross connection or other source. Pressure transients can also create hydraulic disturbances that allow biofilm material on pipe surfaces to en ter the bulk water. Industry guidelines suggest that system pressure should be maintained within the range of 35 to 100 psi at all points in the distribution system (AWWA 2004a). The AWWA G200 standard indicates that the minimum residual pressure at the service connection under all operating conditions should be > 20 psi (AWWA 2004a). Written standard operating procedures for pump, hydrant and valve operation under routine and emergency conditions can help minimize sudden changes in water velocity that i mpact s y stem pressure.

Other actions that can help to maintain an adequate pressure in the distribution system include building new booster pump stations and elevated storage facilities, modifying existing high service pumps, and installing surge relief valves and surge tanks. The following sections discuss costs associated with each of these options.

5.4.1 Booster Pumping Station

Booster pumping stations are used in distribution systems to move water from lower pressure zones to higher pressure zones and to m aintain pressure at desirable levels. As the PWS grows and changes, existing booster pump stations may no longer be able to maintain the desired pressure across the distribution system. In those cases, the construction of a new booster station may be req uired.

Exhibit 5-14 presents the estimated cost for the installation of a new booster pump station including equipment, required piping and appurtenances, electrical and instrumentation equipment, a building, installation, overhead and profit. Engineering, surveying, and land acquisition costs are not included in the estimates

.Tech nology and Cost Document for the 5- 17 Final Revised Total Coliform Rule 

### Exhibit 5-14 : Estimated Costs to Install a New Booster Pump Station (2007$)

Cost Component 1 Population Size Category

<100 101 - 500 501 - 1,000 1,001 -

4,100 4,101 – 33k 33,001 to

96k 96,001 -

500k 500,001 –

1M >1 M

Pump Station Size (MGD) 2 A 0.01 0.03 0.08 0.08 0.6 2.1 3 7.5 15

Number of Pumps 2 B 1 duty

1 stand

- by 1 duty

1 stand

- by 1 duty

1 stand

- by 1 duty

1 stand

- by 1 duty

1 stand

- by 2 duty

1 stand

- by 2 duty

1 stand

- by 2 duty

1 stand

- by 2 duty

1 stand

- by

Pumps Size (gpm) 2 C 10 30 60 60 430 740 1,040 2,610 5,210

Total Pumps & Motors Cost D $780 $1,960 $2,140 $2,140 $15,280 $26,520 $36,780 $92,440 $184,860

Pipes a nd related materials E $650 $1,930 $5,130 $5,770 $38,460 $141,000 $192,280 $480,690 $961,370

Equipment Installation 3 F=0.3*(D+E) $429 $1,167 $2,181 $2,373 $16,122 $50,256 $68,718 $171,939 $343,869

Total Cost of Equipment

Installed G=D+E+F $1,859 $5,057 $9,451 $10,283 $69,862 $217,776 $297,778 $745,069 $1,490,099

Building Size ( ft 2 ) H 72 72 72 72 167 264 387 950 1,866

Building cost 4 I $3,940 $3,940 $3,940 $3,940 $9,120 $14,420 $19,980 $50,260 $100,510

Slab

- on

- grade 5,6 J $230 $230 $230 $230 $530 $830 $1,140 $2,870 $5,730

Electrical and

Instrumentation 7 K=0.2*G $372 $1,011 $1,890 $2,057 $13,972 $43,555 $59,556 $149,014 $298,020

Total Cost (2007$) 8 ,9 L=1.225*(G+I+J+K) $7,850 $12,550 $19,010 $20,230 $114,520 $338,820 $463,610 $1,160,340 $2,320,590

1 All costs on a per pump station basis.

2 See Exhibit 5 -2.

3 Assumes 30% of pump, motor, pipes and related materials total cost.

4 Assumes the median cost ($60/sf) of a Warehouse & Storage Building type (includes site work, masonry, plumbing, electrical, HVAC & labor). Source: R.S. Means, 2009 (adjusted to 2007 dollars).

5 Assumes concrete cost is $184.43/cubic yard. Source: R.S. Means, 2009.

6 Assumes a 6

- inch slab.

7 Assumes 20% of the total installed equipment.

8 Includes 22.5% overhead and profit, based on R.S. Means (2009).

9 Estimates rounded up to the nearest $10.Technology and Cost Document for the 5- 18 Final Revised Total Coliform Rule 

### 5.4.2 Modify or Replace Existing Pumps

The construction of a completely new booster pump station is not always required to maintain an appropriate pressure in a PWS . There may be situations where a modification or replacement of an existing pump is sufficient.

Exhibit 5-15 presents the estimated cost for replacing a new booster pump including equipment, required piping and appurtenances, installation, and overhead and profit. For smaller systems, the pump and motor were provided in a package cost estimate; however for pumps greater than 60 GPM, the pump and motor were quoted separately and summed in Row D.

Exhibit 5-15 : Estimated Costs to Rep lace Existing Pump (2007$)

Cost Component 1 Population Size Category

<100 101 -

500 501 -
1,000 1,001 -
4,100 4,101 - 33k 33,001 –

96k 96,001 -

500k 500,001 -

1M >1 M

Pump Size (gpm) 2 A 10 30 60 60 430 740 1,040 2,610 5,210

Pump Cost B - - - - $4,390 $7,620 $10,560 $26,550 $53,100

Motors C - - - - $3,520 $5,640 $7,830 $19,670 $39,330

Pump & Motor Cost D=B+C $390 $980 $1,070 $1,070 $7,910 $13,260 $18,390 $46,220 $92,430

Related pump
equipment 3 E=0.3*D $117 $294 $321 $321 $2,373 $3,978 $5,517 $13,866 $27,729

Installation 4 F=0.2* (D+E) $101 $255 $278 $278 $2,057 $3,448 $4,781 $12,017 $24,032

Total Cost (2007$) 5 ,6 G=1.225* (D+E+F) $750 $1,880 $2,050 $2,050 $15,120 $25,340 $35,150 $88,330 $176,640

1 All costs on a per pump basis. Source: USABlueBook Catalog, 2008 (adjusted to 2007 dollars).

2 See Exhibit 5 -2.

3 Assumes 30% of the pump and motor cost.

4 Assumes 20% of the pump, motor and related equipment cost.

5 Includes 22.5% overhead and profit, based on R.S. Means (2009).

6 Estimates rounded up to the nearest $10.



### 5.4.3 Install Variable Frequency Drives

A variable frequency drive (VFD), also called a variable speed drive, allows a booster pump to supply the required amount of flow based on system demand with a pressure set point to maintain constant system di scharge pressure, controlled to within a few psi of an operator– adjustable system pressure set point. VFDs work with a system pressure transmitter to control the system pressure set point.

Exhibit 5-16 presents the estimated cost to install a VFD, includi ng installation, overhead and profit.Technology and Cost Document for the 5- 19 Final Revised Total Coliform Rule 

### Exhibit 5-16: Estimated Costs to Install a Variable Frequency Drive (2007$)

System Size Pump Size (gpm) 1 VFD Cost 2 Total Cost (2007$) 3

A B C D=C*1.225

< 100 10 $700 $860

101 - 500 30 $1,150 $1,410

501

- 1,000 60 $3,440 $4,220

1,001 - 4,100 60 $3,900 $4,780

4,101 - 33,000 430 $28,340 $34,720

33,001

- 96,000 7 4 0 $49,260 $60,350

96,001

- 500,000 1,0 40 $68,730 $84,200

500,001

- 1,000,000 2, 610 $171,8 30 $210,500

> 1,000,00 0 5,210 $343,650 $420,980

1 See Exhibit 5 -2.

2 Based on installed cost, per equipment vendor quotes and adjusted to 2007 dollars.

3 Includes 22.5% overhead and profit, based on R.S. Means (2009).

4 Estimates rounded up to the ne arest $10

.



### 5.4.4 Elevated Storage Facility

Elevated storage is provided within the distribution system to supply peak demand rates and equalize system pressures. In certain systems, elevated storage is more effective and economical than ground storage because by nature of the elevated supply, pumping requirements may be reduced, and the storage can serve as a source of emergency supply since system pressure requirements can still be met temporarily when pumps are out of service.

Elevated storage tanks are often sited in areas having the lowest system pressures during intervals of high water use. These areas are often those of greatest water demand or those farthest from pump stations. Elevated tanks are generally located at some distance from the pump station serving a distribution pressure level, but ideally are not placed outside of boundaries of the service area unless the facility can be located on a nearby hill. Elevated tanks are built on the highest available ground so as to minimize the required construction cost and the height requirements.

Exhibit 5-17 presents the estimated costs to install a new elevated storage tank. These costs are per tank and include the installed tank cost, the foundation, pipe and related materials

costs , installation and profit and overhead. Engineering, surveying, land acquisition and permitting are not included in the estimates.Technology and Cost Document for the 5- 20 Final Revised Total Coliform Rule 

### Exhibit 5-17: Estimated Costs to Install a New Elevated Storage Tank (2007$)

System Size Tank Siz e (gal) Tank Cost 1 Foundation

Cost 2,3 Piping & Related

Materials Cost 4 Total Cost (2007$) 5 ,6

A B C D=0.15*C E=0.3*(C+D) F=(C+D+E)*1.225

< 100 25,000 $146,720 $22,008 $50,618 $268,700

101 - 500 50,000 $202,240 $30,336 $69,773 $370,380

501

- 1 ,000 100,000 $278,770 $41,816 $96,176 $510,5 40

1,001 - 4,100 250,000 $384,440 $57,666 $132,632 $704,060

4,101 - 33,000 500,000 $620,390 $93,059 $214,035 $1,136,170

33,001

- 96,000 1,000,000 $859,980 $128,997 $296,693 $1,574,9 50

96,001

- 500,000 1,000,000 $859,980 $128,997 $296,693 $1,574,9 50

500,001

- 1,000,000 2,000,000 $1,719,970 $257,996 $593,390 $3,149,910

> 1,000,00 0 2,000,000 $1,719,970 $257,996 $593,390 $3,149,910

1 Assumes installed cost. Source: R.S. Means (2009) , adjusted to 2007 dollars.

2 Assumes 15% of tank cost, based on project experience.

3 Foundation cost depends on soil conditions, good soil conditions assumed.

4 Assumes 30% of tank and foundation combined cost.

5 Includes 22.5% overhead and profit, based on R.S. Means (2009).

6 Estimates rounded up to the nearest $10.



### 5.4.5 Install Surge Relief Valve

Surge relief valves provide pressure management by eject ing water out of a side orifice to prevent excessive high

- pressure surges and can also be triggered to open on a downsurge in pressure in anticipation of an upsurge to follow. Surge relief valves must always be used with caution for they can make low-pressure conditions in a line worse than they would be without the

valve.

Exhibit 5-18 presents the estimated costs to install a surge relief valve.

Exhibit 5-18: Estimated Costs to Install a Surge Relief Valve (2007$)

System Size Valve Size (in) Surge Relief Valve

Cost 1 Total Cost (2007$) 2 ,3

A B C D = C*1.225

< 100 4 $4,040 $4,950

101

- 500 4 $4,040 $4, 950

501

- 1,000 4 $4,040 $4, 950

1,001

- 4,100 6 $5,920 $7, 260

4,101 - 33,000 10 $15,510 $19,000

33,001 - 96,000 12 $23,590 $28,900

96,001

- 500,000 20 $41,380 $50, 700

500,001 - 1,000,000 24 $51,040 $62,530

> 1,000,00 0 24 $51,040 $62,530

1 Assumes installed cost. Source: Apollo Valves catalog, 2008.

2 Includes 22.5% overhead and profit, based on R.S. Means (2009).

3 Estimates rounded up to the nearest $10.Technology and Cost Document for the 5- 21 Final Revised Total Coliform Rule 

### 5.4.6 Install Surge Tanks

The four common types of surge tanks include pneumatic or closed tanks, open standpipes (or air chambers), one-way surge tanks (allows water to flow only from the tank into the pipeline) and two-way surge tanks (allows flow to and from the tank). If water is stored in these tanks for long periods of time, the water may lose its disinfectant residual and microbial growth and other water quality problems may results. Proper operations and maintenance of surge tanks is required to prevent poor quality or contaminated wat er from entering the distribution system.

Hydropneumatic tank systems are a popular way to provide pressure control and stabilization in smaller water distribution systems; however, they are not typically used in larger systems (serving > 500,000 customers). A hydropneumatic tank system allows for fluctuations in water distribution system pressure, and a potential cushion against water hammer. The system also minimizes booster pump on- off cycles.

The pressure tank uses a compressed air head

- space to mai ntain system pressure. As

PWS demand increase s , water in the pressure tank discharges into the system and reduces the pressure tank ’ s water level, which expands the air cushion above the water and decreases the tank air pressure. When the air reaches a de termined set point, the air compressor comes on to recharge the air space and cycles off when the high pressure set point is met. If the water demand continues to increase, the booster pumps will cycle on at the low water level and replenish the water level in the pressure tank. The pressure tank must be sized correctly, because its size determines the frequency of pump cycling.

Exhibit 5-19 presents the estimated cost to install a hydropneumatic tank system. The hydropneumatic tank system consists of a hydropneumatic pressure tank, air compressor and associated piping and controls. The cost of the slab -on- grade w here the tank will be installed is also included in this estimated cost as well as installation and overhead and profit costs. Engineering, surv eying , land acquisition and permitting are not included in the estimates.Technology and Cost Document for the 5- 22 Final Revised Total Coliform Rule 

### Exhibit 5-19: Estimated Costs to Install a Surge Control Tank (2007$)

System Size Tank Size (gal) Tank

Cost 1,2 Tank Control &

Access ories 3 Slab

- on

grade 4,5 Installation 6 Total Cost (2007$) 7 ,9

A B C D= C*0.4 E F=(C+D+E)*0.2 G=(C+D+E+F)

*1.225

< 100 500 $6,650 $2,660 $1,180 $2,098 $15,420

101

- 500 500 $6,650 $2,660 $1,180 $2,098 $15,420

501 - 1,000 1,000 $9,020 $3,608 $1,640 $2,854 $20,980

1,001 - 4,100 2,000 $12,660 $5,064 $2,100 $3,965 $29,150

4,101

- 33,000 7,500 $29,790 $11,9 16 $4,010 $9,14 3 $67,2 10

33,001

- 96,000 10,000 $34,980 $1 3

, 992 $5,280 $10,85 0 $79,7 5 0

96,001

- 500,000 12,000 $39, 630 $15,8 52 $6,290 $12,35 4 $90,8 10

500,001 - 1,000,000 8 NA NA NA NA NA NA

> 1,000,00 0 8 NA NA NA NA NA NA

1 Assumes standard horizontal tanks for 100 psi working pressure including standard fittings and freight.

2 Cost estimates obtained from US ABlueBook Catalog (2008) adjusted to 2007 dollars.

3 Assumes 40% of the Tank Cost.

4 Assumes a 4

- inch slab.

5 Assumes $184.43/cubic yard. Source: R.S. Means, 2009.

6 Assumes 20% of the total cost of the tank, tank control and accessories, and slab

- on

- grad e.

7 Includes 22.5% overhead and profit, based on R.S. Means (2009).

8 Surge control tanks not typically used in larger systems (serving >500,000 customers).

9 Estimates rounded up to the nearest $10.



## 5.5 Maintenance of Appropriate Hydraulic Residence Time

As water travels through the distribution system, free chlorine continues to react with natural organic matter ( NOM ) to form disinfection by -products ( DBPs ) . Thus, increased water age can lead to higher DBP concentrations for systems using free chlorine. Oth er water quality problems associated with increased water age include reduced disinfectant residual, increased microbial activity, nitrification, and/or taste and odor problems. PWS s should develop an overall strategy to manage the water age in their dist ribution systems. Establishing a water age goal is

system -specific depending on system design and operation, water demands, and water quality (e.g. DBP formation potential). In the US, the average distribution system retention time is 1.3 days and the av erage maximum retention time is 3.0 days based on a survey of 800 medium and large water utilities ( AWWA and AwwaRF 1992 ). Water age can be controlled through a variety of techniques including management of finished water storage facilities, looping of de ad

ends, and re- routing of water by changing valve settings. Additional guidance is provided in the AwwaRF report, Managing Distribution System Retention Time to Improve Water Quality (Brandt et al. 2004).

5.5.1 Loop Dead Ends

Dead end pipes often result in sta gnant water conditions where water age increases, which can cause water quality problems. One of the solutions to address the stagnant water issue is looping of dead ends. However, looping should be evaluated carefully on a case- by

- case basis as it may n ot actually reduce the long detention times present in those areas.Technology and Cost Document for the 5- 23 Final Revised Total Coliform Rule 

### The cost associated with installing loops to eliminate dead ends is the same as to replace or repair ductile iron pipe lines presented in Exhibit 5-7.

5.5.2 Install Appropriate Main Sizes

Most d istribution systems have been designed to meet a minimum hydraulic capacity. Additional capacity is generally included at the design stage to accommodate for future growth or to allow more flexibility in the configuration of a distribution system network. A PWS may also have a policy to limit the number of different pipe diameters within the system in order to simplify construction and maintenance. Furthermore, water use is declining in many areas due to

installation of water -saving appliances, reduced household size, and conservation measures. Consequently network pipes tend to be larger than is necessary to meet the daily demand from the network leading to increased retention time. Hence, there can be an option to replace mains with smaller diameter p ipes but still maintain the required hydraulic capacity.

The cost associated with installing appropriate water main sizes is the same as to replace or repair ductile iron pipe lines presented in Exhibit 5-7.

5.5.3 Install Automated Flushing Devices

Automated fl ushing devices are used to purge accumulated sediments at low spots and

dead -ends of pipelines at regular intervals and for draining pipelines for repairs, maintenance, and inspection. These devices are best suited to suburban or rural areas in which secu rity of the units and disposal of the water flushed is less problematic. An additional drawback of installing these devices is the volume and value of the wasted water may be unacceptable. However, in networks with long pipe runs terminating in dead ends , there may be few viable alternatives to flushing for controlling retention time.

Exhibit 5-20 presents the cost of installing automatic flushing devices, including the

material cost and in -house labor, assuming an 8-hour shift and 2-person work crew are required for installation of an above-ground flushing device.Technology and Cost Document for the 5- 24 Final Revised Total Coliform Rule 

### Exhibit 5-20 : Estimated Costs to Install Automated Flushing Devices (2007$)

System Size Labor Rate 1 Shift Time (hours) Total Labor

Cost 2 Autom ated
Flushing Device

Cost 3,4 Total Cost (2007$) 5

A B C D=B*C*2 E F=D+E

< 100 $25.10 8 $402 $3,190 $3, 600

< 500 $27.03 8 $432 $3,190 $3,630

501 - 1,000 $28.96 8 $463 $3,190 $3,660

1,001

- 4,100 $29.73 8 $476 $3,190 $3, 670

4,101

- 33,00 0 $36.00 8 $576 $3,190 $3, 770

33,001 - 96,000 $36.39 8 $582 $3,190 $3,780

96,001 - 500,000 $41.01 8 $656 $3,190 $3,850

500,001

- 1,000,000 $41.01 8 $656 $3,190 $3, 850

> 1,000,00 0 $41.01 8 $656 $3,190 $3,850

1 See Exhibit 2 -5 in Chapt er 2

, Estimated Unit Costs of Labor.

2 Labor cost assumes a two person crew working for a total of 8 hours each.

3 Assumes a long

- neck standard unit, installed at a depth of 3 feet.

4 Automated flushing device costs obtained from Hydro Guard ® catalog, 2008

.
5 Estimates rounded up to the nearest $10.



### 5.5.4 Storage Facility Modifications

Some storage facilities have been designed focusing more on quantity, cost, service life, appearance and shape than on maintaining water quality. Water quality in storage faciliti es is affected by the mixing patterns that occur primarily during the filling cycle, the long term residence time, and the interaction between these two phenomena.

Increasing volume turnover reduces the average hydraulic residence time (HRT) in

finished wa ter storage facilities, thereby reducing DBP formation, loss of disinfectant and microbial growth. Kirmeyer and Friedman (2000) recommend complete turnover every three to five days but suggest that PWS s establish their own turnover goal based on system- sp ecific needs and goals.

Improving mixing in finished water storage facilities can help eliminate stagnant zones. Old water in stagnant zones can often have very high DBPs and no or low disinfectant residual. This water can be released into the system duri ng periods of high demand. Mixing can be improved by increasing inlet momentum, changing the inlet configuration, increasing the fill time, and by installing mixing devices within the storage facility.

5.5.4.1 Modify Inlet/Outlet Piping

Inlet/outlet configuration is critical in the development of proper mixing in a finished water storage facility. The inlet/outlet structure should be located and sized to disperse the incoming water jet into the storage facility as well as to maintain a jet sufficient for mixing. In particular, the location and orientation of the inlet pipe relative to the tank walls can have a significant impact on mixing characteristics, while the outflow characteristics do not significantly influence mixing. The physical modifications to the inlet pipe for improving mixing within the tanks include:Technology and Cost Document for the 5- 25 Final Revised Total Coliform Rule 

### • Changing the orientation of the inlet pipe and/or

• Decreasing the inlet diameter to increase the jetting action.

When the inlet/outlet is a common pipe, the ability to reduce the inlet diameter to a chieve a higher inflow velocity and better jetting action will be constrained by the need to maintain an outflow capacity adequate to satisfy system operational and fire flow requirements. For this reason, it is recommended to eliminate the common inlet/outlet pipe in many storage facilities

.

Exhibit 5-21 presents the cost of modifying the inlet/outlet configuration, including the pipes and related materials (e.g. valves), installation, and profit and overhead costs. Because these modifications are very site

- specific and based on tank geometry, materials costs were estimated as 10% of the piping and related materials cost associated with installation of a new elevated storage tank, as identified in Exhibit 5- 16 (column E). Installation was estimated as

2 0% of the materials cost based on similar experience at several PWSs. Note that this estimate

does not include the engineering cost for designing the new inlet/outlet configuration.

Exhibit 5-21 : Estimated Costs to Modify Inlet/Outlet Piping (2007$)

System Size Tank Size (gal) Pipe & Related

Materials Cost 1 Installation Cost 2 Total Cost (2007$) 3 ,4

A B C D=0.2*C E=(C+D)*1.225

< 100 25,000 $5,062 $1,012 $7,450

101

- 500 50,000 $6,977 $1,395 $10, 260

501

- 1,000 100,000 $9,618 $1,924 $14, 140

1,001 - 4,100 250,000 $13,263 $2,653 $19,500

4,101 - 33,000 500,000 $21,403 $4,281 $31,470

33,001

- 96,000 1,000,000 $29,669 $5,934 $43, 620

96,001

- 500,000 1,000,000 $29,669 $5,934 $43, 620

500,001 - 1,000,000 2,000,000 $59,339 $11,868 $87,230

> 1,000,00 0 2,000,000 $59,339 $11,868 $87,230

1 Assumes 10% of the Piping & Related Materials Cost of installing a new storage tank presented in Exhibit 5

- 17 , column E.

2 Assumes installation equal to 20% of the materials cost.

3 Assumes and includes a 22.5% Overhead and Profit cost, based on R.S. Means (2009).

4 Estimates rounded up to the nearest $10.



### 5.5.4.2 Install Mixing Devices

Mixing the storage facility contents to reduce stagnant zones can also b e accomplished by installing mixing devices. Special precautions are needed with mechanical mixing devices because of potential contamination to finished water by the mixer mechanism lubrication system. Multiple mixing devices may be needed and the PWS s hould consider the increased maintenance requirements inside the storage facility.

Exhibit 5-22 presents the cost of installing mixing devices in the storage facilities, including the mixing device, the pipes and related materials (e.g. valves) and install ation costs. Mixing system costs were obtained from vendor quotes, while piping and related materials costs were assumed to be 10% of the piping and related materials costs associated with installation of a new elevated storage tank, as identified in Exhi bit 5 -16 (column E). Installation was estimated as 20% of the total equipment and materials cost based on similar experience at several PWSs.Technology and Cost Document for the 5- 26 Final Revised Total Coliform Rule 

### Exhibit 5-22: Estimated Costs to Install Mixing Devices (2007 $)

System Size Tank Size (gal) Mixing System

Cost 1 Pipes & Related

Materials Cost 2 Installation 3 Total Cost (2007$) 4 ,5

A B C D E=0.2*(C+D) F=(C+D+E)*1.225

< 100 25,000 $1,650 $5,06 2 $1,342 $9, 870

101

- 500 50,000 $1,650 $6, 977 $1,726 $12, 690

501 - 1,000 100,000 $3,290 $9,618 $2,582 $18,980

1,001 - 4,100 250,000 $8,230 $13,263 $4,298 $31,600

4,101

- 33,000 500,000 $16,450 $21,40 3 $7,570 $55, 650

33,001

- 96,000 1,000,000 $32,900 $29, 669 $12,514 $91, 980

96,001 - 500,000 1,000,000 $32,900 $29,669 $12,514 $91,980

500,001 - 1,000,000 2,000,000 $65,800 $59,339 $25,028 $183,960

> 1,000,00 0 2,000,000 $65,800 $59, 339 $25,028 $183, 960

1 Assumes a mixing system by TideFlex Technologies (Carnegie, PA).

2 Assumes 10% of the Piping & Related Materials Cost of installing a new storage tank presented in Exhibit 5

- 16, column E

.
3 Assumes installation equal to 20% of the total equipment and materials cost.

4 Assumes and includes a 22.5% Overhead and Profit cost, based on R.S. Means (2009).

5 Estimates rounded up to the nearest $10.



### 5.5.4.3 Modify Storage Operation

As mentioned earlier in this section, increasing the volume turnover reduces the average HRT in the storage tank. Turnover can be accomplished by making operational modifications to the storage tank such as increasing the water level fluctuation or drawdown between fill and draw cycles. The water level should be lowered in one continuous operation not small incremental drops throughout the day.

Operational modifications may be limited by the following considerations:

• Control of flow rates during tank filling may be needed to minimize the potential for low pressure in the distribution system;

• Changes in operating protocol for booster stations and other tanks to achieve

turnover while ma intaining adequate pressure system

- wide.

Exhibit 5-23 presents the costs associated with modifying a storage operation. The costs included in this action are the operator labor costs associated with the time spent analyzing the

different storage operation alternatives, selecting the most appropriate for their system and implementing it. For PWSs serving more than 1,000 customers, it was assumed that it would also be necessary to reprogram the Supervisory Control and Data Acquisition ( SCADA ) system
and the refore there is an additional cost for the programmer time. In many systems, a SCADA system is used to automatically control pumps, and the system would need to be reprogrammed to incorporate any changes to the control logic.Technology and Cost Document for the 5- 27 Final Revised Total Coliform Rule 

### Exhibit 5-23: Estimated Costs to Modify Storage Operation (2007$)

System Size Labor Rate 1 Labor Time (hours) 2 Programmer

Rate 3,4 Programming Time (hours) Total Labor &
Programming

Cost 5

A B C D E F = B*C + D*E

< 100 $25.10 8 NA NA $210

101

- 500 $27.03 8 NA NA $2 20

501

- 1,000 $28.96 8 NA NA $2 40

1,001 - 4,100 $29.73 8 $120 8 $1,200

4,101 - 33,000 $36.00 8 $120 8 $1,250

33,001

- 96,000 $36.39 8 $120 8 $1,2 60

96,001

- 500,000 $41.01 8 $120 8 $1,2 90

500,001 - 1,000,000 $41.01 8 $120 8 $1,290

> 1,000,00 0 $41.01 8 $120 8 $1,290

1 See Exhibit 2 -5 in Chapter 2

, Estimated Unit Costs of Labor.

2 Assumes 8 hours of operator time to analyze operational changes.

3 Assumes average programmer rate of $120 per hour (in 2007 dollars), which is independent of system size.

4 Assumes systems serving <1,000 do not use SCADA systems and therefore require no programming time.

5 Estimates r ounded up to the nearest $10.



### 5.5.4.4 Decommission Storage

Decommissioning storage facilities may be an app ropriate strategy to reduce water age if existing facilities are oversized and not needed for emergency conditions, fire protection, or for maintaining system pressure. A professional engineer should review system needs, system design, and operation to de termine if the existing storage capacity is appropriate.

Exhibit 5-24 presents the cost associated with the decommissioning of a storage tank, including the labor hours of in-house staff to drain the storage tank, close valves and oversee the

work of the o utside company that will clean the tank.Technology and Cost Document for the 5- 28 Final Revised Total Coliform Rule 

### Exhibit 5-24 : Estimated Costs to Decommission Storage (2007$)

System Size Tank Size (gal) Labor Rate 1 Time (hours) Total Labor

Cost 2 Tank Cleaning

Cost 3 To tal Cost (2007$) 4

A B C D E=C*D*2 F G=E+F

< 100 25,000 $25.10 8 $402 $1,340 $1, 750

101 - 500 50,000 $27.03 8 $432 $1,510 $1,950

501 - 1,000 100,000 $28.96 8 $463 $1,830 $2,300

1,001

- 4,100 250,000 $29.73 8 $476 $3,190 $3, 670

4,101

- 33,000 500,000 $36.00 8 $576 $5,020 $5, 600

33,001 - 96,000 1,000,000 $36.39 8 $582 $7,750 $8,340

96,001 - 500,000 1,000,000 $41.01 8 $656 $7,750 $8,410

500,001

- 1,000,000 2,000,000 $41.01 8 $656 $9,110 $9, 770

> 1,000,00 0 2,000,000 $41.0 1 8 $656 $9,110 $9,7 70

1 See Exhibit 2 -5 in Chapter 2

, Estimated Unit Costs of Labor.

2 Labor cost assumes a two

- person crew and 8

- hour shift.

3 Includes cost of tank cleaning, as presented in Exhibit 5

- 25

.
4 Estimates rounded up to the nearest $10

.



## 5.6 Storage Facility Maintenance

Finished water storage tanks are an important component of a PWS ’s distribution system. Tanks are usually designed for three purposes: reduce pressure fluctuations in the distribution system, equalize water demands, and provide water reserves for emergencies such as fires and

power outages.

The two main categories of water storage tanks include ground storage tanks and elevated storage tanks. Ground storage tanks can be below grade, partially below grade, or at ground

level in a distribution system and are usually constructed of a variety of materials, including steel, concrete, and fiberglass reinforced plastic. Elevated storage tanks are typically constructed

of steel.

Contamination from birds and insects can be a source o f microbial contamination in the distribution system. Maintenance to a storage tank can significantly reduce the possibility of contamination. Some actions include inspecting and cleaning, lining the interior of the tank, repairing vents and/or hatches, and repairing the tank itself.

5.6.1 Inspecting/Cleaning of Tanks

Tank inspections can provide useful information on the physical condition of the exterior and interior of the tank, identifying potential sources of microbial contamination. Inspections

can also identify the accumulation of sediment within storage tanks due to particle settling in the tank or the dissolving of cementitious materials of a concrete tank from soft, low alkalinity, low pH waters. There are several water quality issues associated with sediment buildup in a storage tank, including increased disinfection demand, microbial growth, disinfection by-product formation, and increased turbidity.Technology and Cost Document for the 5- 29 Final Revised Total Coliform Rule 

### Exhibit 5-25 presents the costs associated with inspecting and cleaning various sized

finished water storage tanks. Assumptions regarding t ank size were made based on population served. All tanks were assumed as elevated; ground storage tanks may have slightly lower costs as they are easier to access . The costs include inspection, cleaning, labor, equipment, and

insurance costs.

Exhibit 5-25: Estimated Costs for the Inspection and Cleaning of Storage Tanks (2007$)

System Size Tank Size (gal) Tank Type Total Cost 1,2
(2007$)

A B C D

< 100 25,000 Elevated $1,340

101

- 500 50,000 Elevated $1,510

501

- 1,000 100,000 Elevated $1,830

1,001 - 4,100 250,000 Elevated $3,190

4,101 – 33,000 500,000 Elevated $5,020

33,001

- 96,000 1,000,000 Elevated $7,750

96,001

- 500,000 1,000,000 Elevated $7,7 50

500,001 - 1,000,000 2,000,000 Elevated $9,110

> 1,000,00 0 2,000,000 Elevated $9,110

1 Cost includes inspection, labor, equipment, and insurance.

2 Costs obtained from Pittsburg Tank & Tower Maintenance Co., Inc

.



### 5.6.2 Lining of Storage Tanks

Lining th e interior of a water storage tank is another action that can be taken to reduce the potential for coliform contamination of a distribution system. Corrosion and corrosion product buildup from excessive interior corrosion can also result in water quality issues such as increased disinfection demand, microbial growth, and increased turbidity.

The costs associated with lining the interior of various sized water storage tanks are presented in Exhibit 5 -26. The tank sizes and types presented were assumed to b e present in a distribution system serving the associated population range. The costs include material, labor, equipment, and insurance costs, and assume an existing layer is required to be stripped from the

tank’s interior surface.Technology and Cost Document for the 5- 30 Final Revised Total Coliform Rule 

### Exhibit 5-26: Estimated Costs for the Lining of Storage Tanks (2007$)

System Size Tank Size (gal) Tank Type Total Cost (2007$) 1,2

A B C D

< 100 25,000 Elevated $24,800

101 - 500 50,000 Elevated $28,380

501

- 1,000 100,000 Elevated $35,530

1,001 - 4,100 250,000 Elevated $63,770

4,101 – 33,000 500,000 Elevated $88,830

33,001

- 96,000 1,000,000 Elevated $150,320

96,001

- 500,000 1,000,000 Elevated $150,320

500,001

- 1,000,000 2,000,000 Elevated $200,420

> 1,000,0 00 2,000,000 Elevated $200,420

1 Cost includes stripping existing coating, material, labor, equipment, and insurance

.
2 Costs obtained from Pittsburg Tank & Tower Maintenance Co., Inc

.



### 5.6.3 Vent/Hatch Repair

One of the most common sources of cont amination in a water storage tank is the

im proper design and maintenance of vents and roof hatches. These accessories can provide entry points for debris as well as microbial contamination from birds and insects.

Exhibit 5-27 presents the costs associated with replacing a storage tank’s vent screen. Costs are presented on a per vent screen basis . Labor costs were calculated based on a two

person crew and two hours for installation. Exhibit 5-28 presents similar installed costs of repair or replacement of a storage tank hatch. In this case, the installation was assumed to be performed by the manufacturer/vendor and labor costs are included in the total cost.

Exhibit 5-27 : Estimated Costs for the Repair/Repl acement of a Storage Tank Vent (2007$)

System Size Labor Rate 1 Shift Time (hours) Total Labor Cost 2 Vent Screen

Cost 3 Total Cost (2007$)

A B C D=B*C*2 E F=D+E

< 100 $25.10 2 $100 $50 $150

101 - 500 $27.03 2 $108 $50 $158

501

- 1,000 $28.96 2 $ 116 $50 $166

1,001 - 4,100 $29.73 2 $119 $50 $169

4,101 - 33,000 $36.00 2 $144 $50 $194

33,001 - 96,000 $36.39 2 $146 $50 $195

96,001

- 500,000 $41.01 2 $164 $50 $214

500,001

- 1,000,000 $41.01 2 $164 $50 $214

> 1,000,00 0 $41.01 2 $164 $50 $214

1 See Exhibit 2

- 5 in Chapter 2, Estimated Unit Costs of Labor.

2 Labor cost assumes a two

- person crew working for a total of 2 hours

.
3 Assumes 2

- inch wide steel screen frame, 12

- inch vent diameter, 6.9 lb/ft2 area weight, $1.37/lb f rame cost and $45 screen cost

.Technology and Cost Document for the 5- 31 Final Revised Total Coliform Rule 

### Exhibit 5-28: Estimated Costs for the Repair/Replacement of a Storage Tank Hatch (2007$)

Item Total Cost (2007$) 1,2

A B

6 ft. x 6 ft. Hatch $3,190

1 Hatch cost assumed 6 ft. by 6 ft. fiberglass hatch, including materials, labor, and

mobilization.

2 Hatch costs obtained from The Crom Corporation.



### 5.6.4 Tank Repair

Aging water storage tanks with damaged tank structure can also be a source of microbial

contamination. Exhibit 5 -29 presents estimated costs for repairing water storage tank s for various tank sizes and types assumed to be present in a distribution system serving the associated population range. These cost estimates assume a repair cost equal to 20 % of the installed cos t of

a new tank , which includes material, labor, overhead, and profit.

Exhibit 5-29: Estimated Costs for the Repair of Storage Tanks (2007$)

System Size Tank Size (gal) Tank Type New Tank Cost 1 Total Cost 2 ,3 (2007$)

A B C D E=D*0.2

< 100 25,000 Elevated $146,720 $29, 350

101

- 500 50,000 Elevated $202,240 $40,450

501

- 1,000 100,000 Elevated $278,770 $55,760

1,001

- 4,100 250,000 Elevated $384,440 $76, 890

4,101

- 33,000 500,000 Elevated $620 ,390 $124, 080

33,001

- 96,000 1,000,000 Elevated $859,980 $172,000

96,001

- 500,000 1,000,000 Elevated $859,980 $172,000

500,001

- 1,000,000 2,000,000 Elevated $1,719,970 $344,000

> 1,000,00 0 2,000,000 Elevated $1,719,970 $34 4

, 000

1 Assu mes installed cost of a new elevated storage tank, as presented in Exhibit 5 -17.

2 Tank repair costs estimated at 20% of new tank costs.

3 Estimates rounded up to the nearest $10.



## 5.7 Booster Disinfection

Booster disinfection facilities located throughout a distribution system can provide additional chemical treatment in the system. Booster disinfection can improve or maintain disinfectant residual levels in a distribution system. Prior to discharge into the distribution system, potable water from a treatment facility should have a certain disinfectant residual level to minimize microbial growth. These levels are defined by state and government regulations. Organics and reduced metals in the water also consume disinfectant residuals; therefore, it is

vital t o maintain an appropriate disinfectant residual level in the system in order to avoid increased levels of total coliform in the system.

The following sections present costs associated with installation of both chlorine and

chloramines booster disinfection facilities. The booster disinfection facilities were sized basedTechnology and Cost Document for the 5- 32 Final Revised Total Coliform Rule 

### on the system size, type of chemical treatment, and permanent or temporary system. Permanent systems were assumed to be operating all year round and providing 30 days of chemical storage. It is assumed that an operator would visit the facility to perform maintenance and verify operations for one hour each day. These systems are assumed to constantly maintain disinfectant residual levels in a system. They would be placed in locations that typically had low disinfectant

residual levels.

Temporary booster chlorination systems were assumed to operate for seven days and provide seven day s of chemical storage. It is assumed that an operator would visit the facility for two hours to verify operation for the day the disinfection system begins operation. These systems are assumed to operate at times when disinfectant residuals levels were low for a distribution system; however, these distribution systems would only experience low residuals at

p articular times of the year. Some systems experience higher levels of organic growth at certain times of the year, particularly the summer months. Therefore, the temporary booster disinfection facilities may not be required to operate all year round.

The capital costs of the facilities include feed equipment, storage, required piping and appurtenances, electrical and instrumentation equipment, a building, and installation. Buildings were sized to provide adequate spacing between the chemical feed equipme nt. Yearly operation and maintenance costs include labor, chemical, and parts and maintenance costs.

5.7.1 Chlorine System

Most systems currently use chlorine as their main disinfectant. Exhibits 5 -30 and 5-31 show various chlorine facility sizes. Based o n the facility size, either a tablet chlorinator or a liquid hypochlorite system was provided. It was assumed that these systems would provide a 1.0 mg/L chlorine dosage.

The tablet chlorinator systems use calcium hypochlorite tablets. These tablets are placed

in a chlorinator where water from the main line is introduced at a controlled rate to erode the tablets. A pump then injects the chlorinated solution back into the main line. These facilities do not require a storage container. The manufacturer provides the tablets in large buckets. Liquid hypochlorite systems consisted of solenoid diaphragm feed pumps and chemical storage.

5.7.1.1 Permanent System

For permanent systems, it is assumed that either one tablet chlorinator system was provided or two feed pumps were provided depending on the system size. Two feed pumps were provided to have one pump in operation and one on standby. It is assumed that polyethylene storage tanks were provided for liquid sodium hypochlorite storage. The number of tanks varied depending on the system size. Exhibit 5 -30 presents the estimated cost for the installation of a permanent chlorine disinfection booster station. Costs to rehabilitate an existing chlorine booster station are assumed to be equal to the total cost of equipment for a new station, as presented in

Exhibit 5-30 , Row K.Technology and Cost Document for the 5- 33 Final Revised Total Coliform Rule 

### 5.7.1.2 Temporary System

For temporary systems, it was assumed that each of the facilities would have liquid hypochlorite systems; therefore, each facility was equipped with a single feed pump. Ther e was no permanent chemical storage at these facilities. Exhibit 5 -31 presents the estimated cost for the installation of a temporary chlorine disinfection booster station.Technology and Cost Document for the 5- 34 Final Revised Total Coliform Rule 

### Exhibit 5-30 : Estimated Costs to Install a Permanent Chlorine Booster Disinfection Station (2007$)

Cost Component Population Size Category

<100 101 - 500 501 - 1,000 1,001 -

4,100 4,101 – 33k 33,001 –

96k 96,001 -

500k 500,001 -

1M > 1 M

Tablet Chlorinator System 1

Usage Rate (lb/hr) A 0.002 0.01 0.03 0.03

Tablet Feed System Size (lb/hr) B 0.5 0.5 0.5 0.5

System Cost 2 C $6,840 $6,840 $6,840 $6,840

Liquid Hypochlorite System 1

Usage Rate (gal/hr) D 0.32 1.12 1.55 3.91 7.82
Pump Size (gal/hr) E 0.55 1.9 1.9 5 8.4

Total Pump Cost (two pumps) 3 F $1,100 $1,190 $1,190 $1,190 $1,640

Storage Requirement 4 (gal) G 300 900 1,200 2,900 5,700

Storage Tank Cost 3 H $640 $1,190 $1,600 $2,010 $6,930

Cost of Piping and Appurtenances 5 I $250 $250 $250 $250 $261 $357 $419 $480 $1,286

Cost of Instrumentation and Electrical 5 J $250 $250 $250 $250 $261 $357 $419 $480 $1,286

Total Cost of Equipment K=C+F+H+I+J $7,340 $7,340 $7,340 $7,340 $2,262 $3,094 $3,627 $4,160 $11,141

Total Structure Cost 6 L $4,200 $4,200 $4,200 $4,200 $9,660 $9,660 $12,940 $23,780 $26,060

Cost of Installation 7 M=0.15*(K+L) $1,731 $1,731 $1,731 $1,731 $1,788 $1,913 $2,485 $4,191 $5,580

Total Capital Cost (2007$) 8

, 13 N=1.225*(K+L+M) $16,260 $16,2 60 $16,260 $16,260 $16, 800 $17,970 $23,340 $39,360 $52,4 10

Labor Cost ($/year) 9 O $9,162 $9,866 $10,570 $10,851 $13,140 $13,282 $14,969 $14,969 $14,969

Chemical Cost ($/year) 10 P 11 $33 $241 $569 $635 $3,813 $13,260 $18,378 $46,254 $92,509

Parts and Maintenance Cost ($/year) 12 Q=0.1*K $734 $734 $734 $734 $226 $309 $363 $416 $1,114

Yearly Operation and Maintenance Cost 13 R=O+P+Q $9,930 $10,8 50 $11,880 $12,230 $17,180 $26,860 $33,710 $61,640 $108, 600

1 Tablet chlorinator sy stems assumed for system sizes 4,100 and less; liquid hypochlorite systems assumed for system sizes 4100 and greater

. 2 Table chlorinator system cost obtained from vendor.

3 Pump and tank cost per Cole Palmer catalog (2008), adjusted to 2007 dollars. Pumps are solenoid diaphragm metering pumps based upon usage rate and available pump sizes and tanks are polyethylene tanks.

4 Storage requirements based on providing approximately 30 days of chemical storage.

5 Assumes 15% of chemical system and storage costs for liquid hypochlorite systems

. Assume cost for incidentals of $250 for tablet systems.

6 Structure cost includes building and slab per R.S. Means (2009), adjusted to 2007 dollars.

7 Assumes 15% of equipment and structure costs.

8 Includes 22.5% overhead and profit, based on R.S. Means (2009).

9 Assumes one hour of maintenance a day and labor rates presented in Exhibit 2 -5 of Chapter 2

, Estimated Unit Costs of Labor

. 10 Chemical cost per chemical supplier ($2.50 per lb of chlorine tablets and $1.35 per gallon of hypochlorite).

11 P = (A*$2.50*8760 hrs/yr) + (D*$1.35*8760 hrs/yr)

12 Assumes 10% of equipment cost.

13 Estimates r ounded up to the nearest $10.Technology and Cost Document for the 5- 35 Final Revised Total Coliform Rule 

### Exhibit 5-31 : Estimated Costs to Install a Tempora ry Chlorine Booster Disinfection Station (2007$)

Cost Component Population Size Category

<100 101 - 500 501 -

1,000 1,001 -

4,100 4,101 –

33k 33,001 –

96k 96,001 -

500k 500,001 -

1M > 1 M

Usage Rate (gal/hr) A 0.003 0.01 0.04 0.09 0.32 1.12 1.55 3.91 7.82

Pump Size (gal/hr) B 0.19 0.19 0.19 0.19 0.55 1.9 1.9 5 8.4

Total Pump Cost (one pump) 1 C $540 $540 $540 $540 $560 $640 $640 $730 $820

Storage Requirement (gal) D 15 15 15 15 54 188 261 657 1,314

Type of Storage Container 2 E Carboy Carboy Carboy Carb oy Drum Drum Drum Tote Tote

Cost of Piping and Appurtenances 3 F=0.15*C $81 $81 $81 $81 $84 $96 $96 $110 $123

Cost of Instrumentation and Electrical 3 G=0.15*C $81 $81 $81 $81 $84 $96 $96 $110 $123

Total Cost of Equipment H=C+F+G $702 $702 $702 $702 $728 $832 $832 $949 $1,066

Total Structure Cost 4 I $930 $930 $1,000 $1,000 $1,460 $1,660 $1,660 $2,100 $4,190

Cost of Installation 5 J=0.15*(H+I) $245 $245 $255 $255 $328 $374 $374 $457 $788

Total Capital Cost (2007$) 6 ,10 K=1.225*(H+ I+J) $2,300 $2,300 $2,400 $2,400 $3,090 $3,520 $3,520 $4,300 $7,410

Labor Cost ($/year) 7 L $50 $54 $58 $59 $72 $73 $82 $82 $82

Chemical Cost ($/year) 8 M $70 $70 $70 $70 $83 $330 $413 $900 $2,250

Parts and Maintenance Cost ($/year) 9 N=0.1*H $70 $70 $70 $70 $73 $83 $83 $95 $107

Yearly Operation and Maintenance Cost 10 O=L+M+N $190 $200 $200 $200 $230 $490 $580 $1,080 $2,440

1 Pump cost per Cole Palmer catalog (2008), adjusted to 2007 dollars. Pumps are solenoid diaphragm metering pumps based upon u sage rate and available pump si zes in A and B

.

2 Assumes storage containers obtained from chemical supplier, and returned for refund of any applicable deposit. Sized based on 7 days of continuous chemical feed, minimum size 15 gallons.

3 Assumes 15% of pump costs.

4 Structure cost inclu des building and slab per R.S. Means ( 2009 ), adjusted to 2007 dollars

.
5 Assume 15% of equipment and structure costs.

6 Includes 22.5% overhead and profit, based on R.S. Means (2009).

7 Assume two hours of maintenance a day based on labor rates presented i n Exhibit 2 -5 of Chapter 2

, Estimated Unit Costs of Labor

. 8 Chemical cost based on minimum chemical delivery volume per chemical vendor. (For hypochlorite a 55 gallon drum is $82.50 and a 300 gallon tote is $450.00.)

9 Assumes 10% of equipment cost.

10 E stimates r ounded up to the nearest $10.Technology and Cost Document for the 5- 36 Final Revised Total Coliform Rule 

### 5.7.2 Chloramines System

Some utilities use combined chlorine, or chloramines , as a secondary disinfectant. For these systems to provide residual boosting, an aqua ammonia feed is often required in addition to a chlorine feed system. Exhibits 5-32 and 5-33 outline costs for a chloramines feed system similar to the permanent and temporary systems that were previously described for free chlorine. It was assumed that these systems would provide a 1.0 mg/L total chlorine dosage. In addition to the chlorine system, an aqua ammonia feed system was provided in order to produce chloramines. It was assumed that these systems would provide a 0.2 mg/L ammonia dosage.

5.7.2.1 Permanent System

For permanent systems, the aqua ammonia feed system included two solenoid pumps, one in operation and one on standby. Chemical storage varied depending on the required amount of ammonia. It was assumed that systems requiring 500 gallons or greater of storage would install stainless steel storage ta nks. Systems that required less would either obtain a 250 gallon tote or 55 gallon drum from the chemical supplier depending on the required amount of

ammonia. Exhibit 5 -32 presents the estimated cost for the installation of a permanent

chloramines boost er station. Estimated costs to rehabilitate an existing chloramine booster station are assumed to be equal to the total cost of equipment for a new station, as presented in Exhibit 5-32, Row P.

5.7.2.2 Temporary System

For temporary systems, it was assumed each was equipped with a single feed pump. There was no permanent chemical storage at these facilities. Exhibit 5 -33 presents the estimated cost for the installation of a temporary chloramine booster station.Technology and Cost Document for the 5- 37

Final Revised Total Col iform Rule 

### Exhibit 5-32 : Estimated Costs to Install a Permanent Chloramines Booster Disinfection Station (2007$)

Cost Component Population Size Category

<100 101 - 500 501 - 1,000 1,001 - 4,100 4,101 - 33k 33,001 – 96k 96,001 -

500k 500,001 -

1M > 1 M

Tablet Chlor inator System 1

Usage Rate (lb/hr) A 0.002 0.01 0.03 0.03
Tablet Feed System Size (lb/hr) B 0.5 0.5 0.5 0.5

System Cost 2 C $6,840 $6,840 $6,840 $6,840

Liquid Hypochlorite System 1

Usa ge Rate (gal/hr) D 0.32 1.12 1.55 3.91 7.82

Pump Size (gal/hr) E 0.55 1.9 1.9 5 8.4

Pump Cost 3 F $1,100 $1,190 $1,190 $1,190 $1,640

Storage Requirement 4 (gal) G 300 900 1200 2900 5700

Storage Tank Cost 3 H $640 $1,190 $1,600 $2,010 $6,930

Aqua Ammonia System

Usage Rate (gal/hr) I 0.0004 0.002 0.002 0.007 0.05 0.17 0.23 0.59 1.18

Pump Size (gal/hr) J 0.19 0.19 0.19 0.19 0.19 0.29 0.29 1.1 1.9

Pump Cost 3 K $1,100 $1,100 $1,100 $1,100 $1,100 $1,100 $1,100 $1,190 $1,640

Storage Requirement 4 (gal) L 10 10 10 10 40 130 170 430 860

Storage Tank Cost 3 M $18,220 $20,780

Cost of Piping and Appurtenances 5 N=0.15*(C+F+H+ K+M) $250 $250 $250 $250 $426 $522 $584 $3,392 $4,649

Cost of Ins trumentation and Electrical 5 O=(0.15*(C+F+H
+K+M) $250 $250 $250 $250 $426 $522 $584 $3,392 $4,649

Total Cost of Equipment P=C+F+H+K+M+

N+O $8,440 $8,440 $8,440 $8,440 $3,692 $4,524 $5,057 $29,393 $40,287

Total Structure Cost 6 Q $7,870 $7,870 $7,930 $7,930 $15,580 $15,580 $19,590 $37,450 $41,910

Cost of Installation 7 R=0.15*(P+Q) $2,447 $2,447 $2,456 $2,456 $2,891 $3,016 $3,697 $10,026 $12,330

Total Capital Cost (2007$) 8 ,13 S=1.225(P+Q+R) $22,980 $22,980 $23,070 $23,070 $27,150 $28,330 $34,730 $94,170 $115,800

Operations & Maintenance Costs

Labor Cost ($/year) 9 T $9,162 $9,866 $10,570 $10,851 $13,140 $13,282 $14,969 $14,969 $14,969

Chemical Cost ($/year) 10 U 11 $36 $258 $587 $693 $4,236 $14,730 $20,416 $51,382 $102,764

Parts and Maintenance C ost ($/year) 12 V=0.1*P $844 $844 $844 $844 $369 $452 $506 $2,939 $4,029

Yearly Operation and Maintenance

Cost 13 W=T+U+V $10,050 $10,970 $12,010 $12,390 $17,750 $28,470 $35,890 $69,290 $121,770Technology and Cost Document for the 5- 38

Final Revised Total Col iform Rule 1 Tablet chlorinator systems assumed for system sizes 10,000 and less; liquid hypochlorite system assumed for system sizes 10,001 and greater.

2 Table chlorinator system cost obtained from vendor.

3 Pump and tank cost per Cole Palmer catalog (2008), adjusted to 2007 dollars. Pumps are solenoid diaphragm metering p umps based upon usage rate and available pump sizes and tanks are

polyethylene tanks.

4 Storage requirements based on providing approximately 30 days of chemical storage.

5 Assume 15% of chemical system and storage costs for liquid hypochlorite systems. Assume cost for incidentals of $250 for tablet systems.

6 Structure cost includes building and slab per R.S. Means ( 2009 ), adjusted to 2007 dollars

7 Assume 15% of equipment and structure costs

.
8 Includes 22.5% overhead and profit, based on R.S. Means (2009).

9 Assumes one hour of maintenance a day based on labor rates presented in Exhibit 2 -5 of Chapter 2

, Estimated Unit Costs of Labor

.
10 Chemical cost per chemical supplier in 2009. ($2.50 per lb of chlorine tablets, $1.35 per gallon of hypochlorite, and $0.99 per gallon of aqua ammonia).

11 U=(A*$2.50*8760 hrs/yr) +(D*$1.35*8760 hrs/yr) +(I*$0.99*8760 hrs/yr)

12 Assumes 10% of equipment cost.

13 Estimates rounded up to the nearest $10.Technology and Cost Document for the 5- 39

Final Revised Total Col iform Rule 

### Exhibit 5-33 : Est imated Costs to Install a Temporary Chloramines Booster Disinfection Station (2007$)

Cost Component Population Size Category

<100 101 - 500 501 - 1,000 1,001 -
4,100 4,101 – 33k 33,001 -

96k 96,001 –

500k 500,001 -

1M > 1 M

Liquid Hypochlorite System

Usage Rate (gal/hr) A 0.003 0.01 0.04 0.09 0.32 1.12 1.55 3.91 7.82

Pump Size (gal/hr) B 0.19 0.19 0.19 0.19 0.55 1.90 1.90 5.00 8.40

Pump Cost 1 C $540 $540 $540 $540 $560 $560 $560 $560 $820

Storage Requirement (gal) D 15 15 15 15 5 4 188 261 657 1,314

Type of Storage Container 2 E Carboy Carboy Carboy Carboy Drum Drum Drum Tote Tote

Aqua Ammonia System

Usage Rate (gal/hr) F 0.002 0.002 0.002 0.01 0.05 0.17 0.23 0.59 1.18

Pump Size (gal/hr) G 0.19 0.19 0.19 0.19 0.19 0.29 0.29 1.1 1.9

Pump Cost 1 H $540 $540 $540 $540 $540 $540 $540 $560 $820

Storage Requirement (gal) I 15 15 15 15 15 28 39 99 199

Type of Storage Container 2 J Carboy Carboy Carboy Carboy Carboy Drum Drum Drum Drum

Cost of Piping and Appurtenan ces 3 K=0.15*(C+H) $162 $162 $162 $162 $165 $165 $165 $168 $246

Cost of Instrumentation and Electrical 3 L=0.15*(C+H) $170 $170 $170 $170 $170 $170 $170 $170 $250

Total Cost of Equipment M=C+H+K+L $1,404 $1,404 $1,404 $1,404 $1,430 $1,430 $1,430 $1,456 $2,132

Total Structure Cost 4 N $1,920 $1,920 $1,920 $1,920 $2,920 $2,920 $2,920 $3,560 $6,020

Cost of Installation 5 O=0.15*(M+N) $499 $499 $499 $499 $653 $653 $653 $752 $1,223

Total Capital Cost (2007$) 6 ,10 P=1.225*(M+N+ O) $4,690 $4,690 $4,690 $4,690 $6,130 $6,130 $6,130 $7,070 $11,490

Labor Cost 7 Q $50 $54 $58 $59 $72 $73 $82 $82 $82

Chemical Cost 8 R $110 $110 $110 $110 $123 $384 $467 $1,009 $2,468

Parts and Maintenance Cost 9 S $140 $140 $140 $140 $143 $143 $143 $146 $213

Yearly Operation and Maintenance Cost 10 T=Q+R+S $310 $310 $310 $310 $340 $600 $700 $1,240 $2,770Technology and Cost Document for the 5- 40

Final Revised Total Col iform Rule 1 Pump cost per Cole Palmer catalog. Pumps are solenoid diaphragm metering pumps based upon usage rate and available pump sizes

. 2 Assumes storage containers obtained from chemical supplier, and returned for refund of any applicable deposit. Sized based on 7 days of continuous chemical feed, minimum size 15 gallons.

3 Assume 15% of chemical systems costs

. 4 Structure cost includes building and slab per R.S. Means ( 2009 ) adjusted to 2007 dollars.

5 Assume 15% of equipment and structure costs

. 6 Includes 22.5% overhead and profit, based on R.S. Means (2009).

7 Assume two hours of maintenance a day based on labor rates presented in Exhibit 2 -5 of Chapter 2

. 8 Chemical cost based on mi nimum chemical delivery volume (For hypochlorite a 55 gallon drum is $82.50 and a 300 gallon tote is $450.00, and for ammonia a 55 gallon drum is $54.45)

. 9 Assumes 10% of equipment cost.

10 Estimates rounded up to the nearest $10.Technology and Cost Document for the 5- 41 Final Revised Total Coliform Rule 

## 5.8 Cross-connection Control and Backflow Prevention Program

Implementing a Cross -Connection Control and Backflow Prevention (CCCBFP) Program, including the installation of backflow prevention assemblies and devices, can prevent the flow of non-potable substances into the distribution system. When implementing the CCCBFP Program, the PWS should adhere to applicable state and/or local criteria, codes, and/or regulations. Some codes or regulations may include documenting installation procedures and the periodic testing of backflow pr evention assemblies.

CCCBFP can prevent the introduction of non-potable substances into the public water supply due to backsiphonage or backpressure. The cost components of a cross-connection control and backflow prevention program can be broadly classifi ed as:

• Cost of Backflow Prevention Assemblies and Devices, and

• Cost of Program Administration. This can be further classified as program organization, system survey, record keeping costs, and enforcement.

The relative cost of program administration is usually more significant for small systems (i.e., typically systems serving populations less than or equal to 10,000) as these systems have limited personnel performing many duties at once. For large systems, the costs of the backflow

devices and assemblies are usually more significant than the program administration costs. This section provides the costs of installing a backflow prevention device and describes the items included under program administration.

5.8.1 Backflow Prevention Assemblies and Devices

Exhibi t 5 -34 presents the costs of installing a backflow prevention assembly (i.e., a reduced pressure flanged iron assembly). This is usually the most expensive assembly and is used in situations of highest hazard when backpressure and backsiphonage are both possible. More information can be found at ( http://www.usc.edu/dept/fccchr ).

Systems should install above-grade housing with drainage and heat to protect the equipment from freezing where systems cannot install v alves indoors. Installation costs do not include costs for this housing, or costs for engineering/construction. Maintenance of these assemblies includes a minimum of annual testing and inspection. In addition, the frequency for performance monitoring an d internal inspections (dismantling, cleaning, and repairs) should occur based on local water quality conditions, the probability of contamination due to potential backflow, and manufacturers’ recommendations for the specific backflow prevention assembly.

Backflow prevention equipment installation and maintenance is generally the consumer’s responsibility. However, depending on how a system implements the cross-connection control and backflow prevention program, the customer and the PWS can share costs for the equipment and equipment installation, inspection, testing, and maintenance. The PWS , on the other hand, is primarily responsible for the administration of cross-connection control and backflow prevention and the inspection, review, and approval of all backflow prevention assemblies and devices.

Labor costs assume a three -person crew is required to dig a new vault and install the backflow prevention device.Technology and Cost Document for the 5- 42 Final Revised Total Coliform Rule 

### Exhibit 5-34: Estimated Costs for a Backflow P revention Assembly Installation (2007$)

System Size Labor

Rate 1 Shift

Time (hours) Total Labor

Cost 2 Backflow
Preventer Pipe Size (in.) Backflow

Preventer

Cost 3,4 Total Cost (2007$) 5

A B C D=B*C*3 E F G+D+F

< 100 $25.10 8 $602 2.5 $2,825 $3,430

101 - 500 $27.03 8 $649 2.5 $2,825 $3,480

501

- 1,000 $28.96 8 $695 2.5 $2,825 $3,520

1,001

- 4,100 $29.73 8 $714 2.5 $2,825 $3, 540

4,101 - 33,000 $36.00 8 $864 3 $2,950 $3,820

33,001 - 96,000 $36.39 8 $873 3 $2,950 $3,830

96,001

- 500,000 $41.01 8 $984 4 $3,725 $4, 710

500,001

- 1,000,000 $41.01 8 $984 6 $5,375 $6, 360

> 1,000,00 0 $41.01 8 $984 6 $5,375 $6,360

1 See Exhibit 2 -5 in Chapter 2

, Estimated Unit Costs of Labor.

2 Labor cost assumes a three

- person crew wo rking for a total of 8 hours.

3 Backflow preventer cost per vendor, assumed a reduced pressure principle, flanged, including valves, four test cocks, and

corrosion resistant.

4 Costs do not include design or permit costs.

5 Estimates rounded up to the near est $10.



### 5.8.2 Program Administration

The administration of a CCCBPP is typically the responsibility of the PWS . Costs for program administration depend on the system size (population served and area covered), system demographics (number of industrial, resident ial, and institutional customers), available staffing resources, maintenance , record keeping, and specific code and regulatory requirements. Another

factor in the administrative costs

, in some cases , is overcoming political resistance. The CrossConnection Control Manual provides additional guidance on program administration (USEPA

2003e ). Program administration will require availability of technical and administrative staff. If sufficient staff is available, appropriate division of program oversight du ties may apply. Otherwise, these tasks may require additional staff or temporary help. In some cases, program administration is contracted out. The Program Administration costs can be classified under three headings:

• Program Organization: It involves establishing the legal foundation for the plan, establishing responsibilities and chain of command, conducting employee and consumer education programs, implementing required codes and regulations for enforcing the program, and monitoring the progress of the program.

• System Survey: It involves surveying the system for potential cross-connections and identifying and prioritizing hazardous connections.

• Record Keeping: It involves updating and maintaining records that are pertinent to the implementation of the C CCBPP.

Exhibit 5-35 summarizes the activities included under each of the three components of Program Administrati on.Technology and Cost Document for the 5- 43 Final Revised Total Coliform Rule 

### Exhibit 5-35: Cost Components of Program Administration for a Cross- Connection

Control a nd Backflow Prevention Program

Cost Component Specific Items Included

Program Organization • Consulting with relevant local and State administrations

• Establishing responsibilities and authorities for required program activities (inspections, maintenance, reporting, etc.)

• Notifying and educating employees and consumers of program and implications

• Developing and implementing a local ordinance

• Program enforcement by the PWS

System Survey • Recording number and sites of connections Identifying potential hazar dous

connections

• Prioritizing hazardous connections

• Developing inspection schedules and records

Record Keeping • Inspection records

• Installation, repair, and maintenance of records

• Customer correspondence records

• Ordinance development records

• Assembly tes t records



### In addition to the other items presented in this section, a successful cross connection control program will require development of testing and enforcement programs to ensure proper operation and compliance. Such programs represent additional c osts that would typically be handled by a department other than then PWS (e.g. writing notices of violation, issuing fines, preparing litigation); therefore these costs have not been included.

Exhibit 5-36 presents the annual cost of administering a CCC program including labor costs, equipment and materials, and related activities. The numbers presented in Exhibit 5- 36 are of the same order of magnitude as the ones presented in the 1999 ABPA Water Systems Survey (ABPA 1999) which listed an average annual c ost for small systems (under 10,000 population) of $6,056.78 based on 25 utilities surveyed; and for large systems (over 10,000 population ) of $92,596.01 based on 103 utilities surveyed.Technology and Cost Document for the 5- 44 Final Revised Total Coliform Rule 

### Exhibit 5-36 : Estima ted Annual Cost of a Cross-Connection Control and Backflow Prevention Program (2007$)

System Size Total Labor Cost Equipment

Material Others Total Cost 1 (2007$)

A B C D E=B + C+D

< 100 $840 $390 $190 $1,410

101 - 500 $4,170 $1,950 $940 $7,050

501 - 1,000 $8,340 $3,890 $1,880 $14,100

1,001

- 4,100 $15,630 $5,700 $8,560 $29,880

4,101

- 33,000 $22,970 $6,040 $5,350 $34,340

33,001 - 96,000 $51,110 $11,190 $7,660 $69,950

96,001 - 500,000 $169,260 $37,600 $62,530 $269,390

500,001

- 1,000,000 $975,090 $200, 480 $44,320 $1,219,880

> 1,000,001 $1,462,640 $300,710 $66,470 $1,829,810

Source: E stimate s adapted from T able 3.5 of the AWWA Research Foundation Report Impacts of Cross

- Connections in North American Water Supplies

, 2004

. Analysis assumes 2.5 people per water connections. Values adjusted to account for differences

in population categories and dollar values are adjusted from 2004 to 2007 dollars.



## 5.9 Addition or Upgrade of On-line Monitoring and Control

Currently, monitoring of total coliform is performed through grab samples at the treatment plant and throughout the distribution system. These grab samples are then analyzed in a laboratory to determine whether TC is present or not in the grab sample.

To ensure sufficient treatment has been provided, grab samples, disinfectant dosages, and certain water quality parameters, such as disinfectant residual levels, can be correlated. Since automatic monitoring is not available for TC, communities can control and monitor disinfectant dosages and water quality para meters.

Controlling and monitoring disinfectant dosages and water quality parameters through the SCADA system performed at a treatment facility is relatively easily. Disinfectant dosing equipment can be monitored and analyzers can be placed in the treatme nt process to monitor water quality parameters.

Monitoring water quality parameters via SCADA in a distribution system is possible; however, it can be costly. Determining the number and location of the analyzers is challenging and highly dependent upon t he system size. Typically, analyzer equipment will draw samples from an above grade pipe or a sample tap to an analyzer that is placed in a building. Sample locations will require analyzer equipment, a building, electric power, and, in the case of some

s ystems, integration to the PWS’s existing SCADA system.

In addition to water quality monitoring, a PWS can monitor pressure levels throughout the distribution system to determine if there are any physical problems in the system, e.g., a crack in a pipe, a leaking valve, etc., that cause changes to the water quality of the system. Similar to the water quality monitoring, determining the number of pressure monitors and their locations is dependent upon the system size. Pressure monitoring locations will also require the same equipment as water quality sampling locations.Technology and Cost Document for the 5- 45 Final Revised Total Coliform Rule 

### On

- line distribution system monitoring through the SCADA system can alert operators if there are possible issues with the distribution system; however, monitoring the water quality or

pr essure will not identify the source of the contamination nor will it necessarily identify the

location of the contamination.

The following sections provide costs for on-line monitoring equipment. Costs provided are for the installation of a single analyze r into an existing building; therefore, costs of a building and electrical and instrumentation equipment are not included.

5.9.1 Water Quality Monitoring and Control

The ability of a PWS to monitor water quality parameters, particularly disinfectant residuals, i n the distribution system can allow the PWS to determine if there is an area of possible contamination or an area that requires additional treatment. Low levels of disinfectant residuals in a system can be caused by an increase of organics in a system, wh ich consume disinfectant residuals, or insufficient disinfectant dosages at the treatment facility. Maintenance of sufficient disinfectant residual levels in a distribution system is important in maintaining minimal levels of TC in the system.

5.9.1.1 Chlorinat ed Systems

Most systems currently utilize chlorine as the main disinfectant. There are a number of chlorine-based treatment technologies available: chlorine gas, hypochlorite, chlorine dioxide, and

anodic oxidation.

Exhibit 5-37 presents the costs associ ated with incorporating a chlorine residual analyzer in the distribution system. The costs below include a chlorine residual analyzer, installation of the analyzer based on system size, required piping and appurtenances, and programming costs.

Exhibit 5-38 present s the annual costs to operate and maintain a single chlorine analyzer including labor, reagents , and parts and maintenance costs.Technology and Cost Document for the 5- 46 Final Revised Total Coliform Rule



### Exhibit 5-37: Estimated Costs for Online Chlorine Monitoring and Programming (2007$)

System Size Labor

Rate 1 Labor

Time (hours) 2 Programmer

Rate 3 Program mer
Time (hours) 4 Total Labor &

Program mer

Cost 2 Chlorine Analyzer

Cost 5 Piping

and

related 6 Total

Cost 7 ,8
(2007$)

A B C D E F=B*C*2+D*E G H I=F+G+H

< 100 $25.10 24 $120 8 $2,165 $2,770 $460 $5,400

101 - 500 $27.03 24 $120 8 $2,257 $2,770 $460 $5,490

501 -1,000 $28.96 24 $120 8 $2,350 $2,770 $460 $5,580

1,001 - 4,100 $29.73 24 $120 8 $2,387 $2,770 $460 $5,620

4,101 - 33,000 $36.00 24 $120 8 $2,688 $2,770 $460 $5,920

33,001 - 96,000 $36.39 24 $120 8 $2,707 $2,770 $460 $5,940

96,001 - 500,000 $41.01 24 $120 8 $2,928 $2,770 $460 $6,160

500,001 - 1,000,000 $41.01 24 $120 8 $2,928 $2,770 $460 $6,160

> 1,000,00 0 $41.01 24 $120 8 $2,928 $2,770 $460 $6,160

1 See Exhibi t 2 -5 in Chapter 2

, Estimated Unit Costs of Labor.

2 Assumes a two

- person crew required over a three

- day period to install chlorine monitoring device and associated equipment (electrical wiring, installing a sample drain, etc.).

3 Assumes average programme r rate of $120 per hour (in 2007 dollars), which is independent of system size.

4 Programming time includes integration of analyzer signals into a SCADA system.

5 Chlorine analyzer cost per vendor research

6 Assume an additional $460 for sample lines.

7 Co sts assume that analyzer will be installed at an existing facility.

8 Estimates rounded up to the nearest $10.



### Exhibit 5-38 : Estimated Annual Operation and Maintenance Costs for an Online Chlorine Analyzer (2007$)

System Size Labor Rate 1 Labor Time (hours) 2 Reagents kit

Cost 3,5 Maintenance Kit

Cost 4,5 Total Cost (2007$)

A B C D E F=( (B*C+D)*12 ) +E

< 100 $25.10 1 $42 $110 $ 920

101 - 500 $27.03 1 $42 $110 $ 940

501 -1,000 $28.96 1 $42 $110 $ 970

1,001 - 4,100 $29.73 1 $42 $110 $ 980

4,101 - 33,000 $36.00 1 $42 $110 $1, 050

33,001 - 96,000 $36.39 1 $42 $110 $1, 060

96,001 - 500,000 $41.01 1 $42 $110 $1, 110

500,001 - 1,000,000 $41.01 1 $42 $110 $1, 110

> 1,000,00 0 $41.01 1 $42 $110 $1, 110

1 See Exhi bit 2 -5 in Chapter 2

, Estimated Unit Costs of Labor.

2 Assumes a one

- person crew required for 1 hour of maintenance a month per analyzer.

3 Reagent kit cost per vendor research. Kit includes buffer and indicator solutions, and DBD indicator powder for mont hly supply.

4 Maintenance kit cost per vendor research. Kit includes reagent tubing, reagent caps and fittings for annual replacement.

5 Cost obtain ed from 2009 vendor catalogs and adjusted to 2007 dollars.

8 Estimates rounded up to the nearest $10.Technology and Cost Document for the 5- 47 Final Revised Total Coliform Rule 

### 5.9.1.2 Chlor aminated Systems

Exhibit 5-39 presents the costs associated with incorporating ammonia and monochloramine analyzers in the distribution system. The costs below include an ammonia and monochloramine residual analyzer, installation of the analyzer based on system size, required piping and appurtenances, and programming costs.

Exhibit 5-40 presents the annual costs to operate and maintain a si n gle ammo nia and monochloramine analyzer including labor, reagents , and parts and maintenance costs.

Exhibit 5-39 : Estimated Costs for Online Chloramines Monitoring and Programming (2007$)

System Size Labor

Rate 1 Labor

Time (hours) 2 Programmer

Rate 3 Program mer Time (hours) 4 Total Labor &

Program mer

Cost 2 Chloramines Analyz er Cost 5 Piping and

Related 6 Total Cost (2007$) 7 ,8

A B C D E F=B*C*2+D*E G H I=F+G+H

< 100 $25.10 24 $120 8 $2,165 $11,230 $ 460 $13, 860

101

- 500 $27.03 24 $120 8 $2,257 $11,230 $ 460 $13, 950

501 - 1,000 $28.96 24 $120 8 $2,350 $11,230 $460 $14,040

1,0 01

- 4,100 $29.73 24 $120 8 $2,387 $11,230 $ 4460 $14, 080

4,101

- 33,000 $36.00 24 $120 8 $2,688 $11,230 $ 460 $14, 380

33,001

- 96,000 $36.39 24 $120 8 $2,707 $11,230 $ 460 $14, 400

96,001 - 500,000 $41.01 24 $120 8 $2,928 $11,230 $460 $14,620

500,001 - 1,000,000 $41.01 24 $120 8 $2,928 $11,230 $460 $14,620

> 1,000,00 0 $41.01 24 $120 8 $2,928 $11,230 $460 $14,620

1 See Exhibit 2 -5 in Chapter 2

, Estimated Unit Costs of Labor.

2 Assumes a two

- person crew required over a three

- day period to install chloramine s monitoring device and associated equipment (electrical wiring, installing a sample drain, etc.).

3 Assumes average programmer rate of $120 per hour (in 2007 dollars), which is independent of system size.

4 Programming time includes integration of analyze r signals into a SCADA system.

5 Chloramines analyzer cost per vendor.

6 Assume an additional $460 for sample lines.

7 Costs assume that analyzer will be installed at an existing facility.

8 Estimates rounded up to the nearest $10.Technology and Cost Document for the 5- 48 Final Revised Total Coliform Rule



### Exhibit 5-40 : Estimated Annual Operation and Maintenance Costs for Online Ammonia

and Monoc hloramines Analyzer (2007$)

System Size Labor Rate 1 Monthly Labor Time (hours) 2 Reagents &

Standards Kit

Cost 4,5 Maintenance Kit

Cost 3,5 T otal Cost (2007$) 6

A B C E F G= ( (B*C)*12 )+( (E+F)*4 )

< 100 $25.10 1 $123 $429 $2,510

101 - 500 $27.03 1 $123 $429 $2,530

501 -1,000 $28.96 1 $123 $429 $2,560

1,001 - 4,100 $29.73 1 $123 $429 $2,570

4,101 - 33,000 $36.00 1 $123 $429 $2,640

33,001 - 96,000 $36.39 1 $123 $429 $2,650

96,001 - 500,000 $41.01 1 $123 $429 $2,700

500,001 - 1,000,000 $41.01 1 $123 $429 $2,700

> 1,000,00 0 $41.01 1 $123 $429 $2,700

1 See Exhibit 2 -5 in Chapter 2

, Estimated Unit Costs of Labor.

2 Assumes a o ne

- person crew required for approximately 1 hour of maintenance every month per analyzer.

3 Maintenance kit cost per vendor research. Kit includes iron buret pistol seals, grease tube, o rings, and valve rotor for quarterly

replacement.

4 Reagent and Stan dards kit cost per vendo r research. Kit includes buffer, indicator and hypochlorite solutions, standards and

cleaning solution for quarterly supply. Assuming a utomatic calibration by the instrument once a day

5 Cost obtain from 2009 vendor catalogs and ad justed to 2007 dollars

.

6 Estimates rounded up to the nearest $10.



### 5.9.2 P ressure Monitoring and Control

The ability of a PWS to monitor pressure throughout its distribution system can provide useful information for responding to water quality events and ensurin g that pressure maintenance is adequate. Pressure readings can also be used to help locate areas of deficiency in a distribution system.

Exhibit 5-41 presents the costs associated with incorporating pressure monitoring equipment in the distribution system. The costs below include pressure monitoring equipment, installation of a pressure transmitter based on system size, and programming costs.

Exhibit 5-42 presents the annual costs to operate and maintain a si n gle pressure transmitter base d on labor onl y, given that a pressure transmitter does not require reagents or replacement parts.Technology and Cost Document for the 5- 49 Final Revised Total Coliform Rule 

### Exhibit 5-41 : Estimated Costs for Online Pressure Monitoring (2007$)

System Size Labor

Rate 1 Labor

Time (hours) 2 Program mer

Rate 3 Program. Time (hours) 4 Total Labor &
Programming

Cost 2 Pressure

Transmitter

Cost 5 Total Cost 6 ,7
(2007$)

A B C D E F=B*C*2+D*E G H=F+G

< 100 $25.10 16 $120 8 $1,763 $2,740 $4, 510

101

- 500 $27.03 16 $120 8 $1,825 $2,740 $4, 570

501 - 1,000 $28.96 16 $120 8 $1,887 $2,740 $4,630

1,001

- 4,100 $29.73 16 $120 8 $1,911 $2,740 $4, 660

4,101

- 33,000 $36.00 16 $120 8 $2,112 $2,740 $4, 860

33,001 - 96,000 $36.39 16 $120 8 $2,124 $2,740 $4,870

96,001 - 500,000 $41.01 16 $120 8 $2,272 $2,740 $5,020

500,001

- 1,000,000 $41.01 16 $120 8 $2,272 $2,740 $5, 020

> 1,000,00 0 $41.01 16 $120 8 $2,272 $2,740 $5,020

1 See Exhibit 2 -5 in Chapter 2

, Estimated Unit Costs of Labor.

2 Assumes a two

- person crew working for a total of two day s to install analyzer.

3 Assumes average programmer rate of $120 per hour (in 2007 dollars), which is independent of system size.

4 Programming time includes integration of transmitter signals into a SCADA system.

5 Pressure transmitter cost per vendor.

6 Costs assumes that pressure transmitter will be installed at an existing facility.

7 Estimates rounded up to the nearest $10.



### Exhibit 5-42 : Estimated Annual Operation and Maintenance Costs for Online Pressure

Transmitter (2007$)

System Size Labor Rate 1 Labor Time (hours) 2 Annual Total Cost (2007$) 3

A B C D=B*C

< 100 $25.10 4 $100

101 - 500 $27.03 4 $110

501 -1,000 $28.96 4 $120

1,001 - 4,100 $29.73 4 $120

4,101 - 33,000 $36.00 4 $150

33,001 - 96,000 $36.39 4 $150

96,001 - 500,000 $41.01 4 $170

500,001 - 1,000,000 $41.01 4 $170

> 1,000,00 0 $41.01 4 $170

1 See Exhibit 2 -5 in Chapter 2

, Estimated Unit Costs of Labor.

2 Assumes a one

- person crew required for approximately 4 hour s of maintena nce a year per analyzer.

3 Estimates rounded up to the nearest $10.



## 5.10 Addition of Security Measures

Systems may need to install security measures in circumstances where the sanitary survey or onsite inspection reveals vandalism or security breaches that co uld lead to water

contamination. Measures that a PWS may take to correct security breaches include installing aTechnology and Cost Document for the 5- 50 Final Revised Total Coliform Rule 

### fence or locking buildings to restrict access to the system. In addition, alarms and cameras may be used to detect security breaches.

PWS s sho uld prioritize their security measures and concentrate on the most vulnerable parts of the system, such as unstaffed facilities (e.g., finished water storage tanks). An important implementation issue is determining the extent to which the PWS needs to be secured. This would depend on how widely spread the system/facility is, the number and complexity of the treatment trains, the extent of the watershed, the distance of the treatment plant from the influent wells, accessibility of the distribution system, etc. Possible security measures include locked fence enclosures and employing a full time, on

- site security staff.

Installing security measures can increase the public’s confidence in the protection of their drinking water and indeed can provide substanti al protection against vandalism that might result in contamination of the water. However, security measures are not always foolproof or absolute in combating vandalism or security breaches.

Exhibit 5-43 presents the cost components for installing fencing, gates, and security lighting for 0.5 and 1-acre lots. A site size of 0.5- acres was assumed for systems serving populations of 10,000 or fewer, and a 1- acre site size was assumed for systems serving populations greater than 10,000. Costs include materials, installation and overhead and profit.

Exhibit 5-43 : Estimated Costs for Installation of Security Measures (2007$)

System Size Fence

Cost 1,2,5 Gate Cost 3,5 Lighting

Cost 4,5 Security Capital Cost Installatio n

Cost 6 Total Cost (2007$) 7 ,8

A B C D E=B+C+D F=0.3*E G=(E+F)*1.225

< 100 $8,400 $795 $880 $10,075 $3,023 $16, 050

101 - 500 $8,400 $795 $880 $10,075 $3,023 $16, 050

501 - 1,000 $8,400 $795 $880 $10,075 $3,023 $16, 050

1,001

- 4,100 $8 ,400 $795 $880 $10,075 $3,023 $16, 050

4,101

- 33,000 $11,900 $795 $880 $13,575 $4,073 $21, 620

33,001 - 96,000 $11,900 $795 $880 $13,575 $4,073 $21, 620

96,001 - 500,000 $11,900 $795 $880 $13,575 $4,073 $21, 620

500,001

- 1,000,000 $ 11,900 $795 $880 $13,575 $4,073 $21, 620

> 1,000,00 0 $11,900 $795 $880 $13,575 $4,073 $21, 620

1 Fence cost assumed a 0.5 acre site (600 linear feet) for systems less than 10,000 and a 1.0 acre site (850 linear feet) for s ystems greater than 10 ,000.

2 Fence cost assumed to be industrial chain link, three strands barbed wire, 2 inch posts, set in concrete, 6 feet high, with 9 ga. wire, galvanized steel.

3 Gate cost assumed double swing gates, including posts and hardware, 6 feet high, 12 feet ope ning.

4 Lighting cost assumed four wall

- mounted, 35 watt, low pressure sodium fixtures per site.

5 Cost obtained from R.S. Means, 2007.

6 Installation costs assumed to be 30% of security capital cost based on project experience and assuming installation in cludes

electrical work.

7 Assumes and includes a 22.5% Overhead and Profit cost, from R.S. Means 2009.

8 Estimates rounded up to the nearest $10.Technology and Cost Document for the 5- 51 Final Revised Total Coliform Rule 

## 5.11 Development and Implementation of an Operations Plan

A PWS should develop a distribution system operations p lan to integrate all operations and maintenance functions to meet the goals of flow, pressure and water quality. AWWA G200- 04 standard describes the critical requirements for the effective operation and management of drinking water distribution systems. According to this standard, a PWS should develop standard operating procedures (SOPs), comprehensive monitoring plans, routine inspections, and emergency response plans.

SOPs should be developed for each operation and maintenance function that affects

syst em water quality (e.g. flushing programs, storage facility inspections). The water quality goals for both the distribution system and the particular function should be specified in the SOP. SOPs should be developed from information gathered from the vario us departments and crews involved in a given function. The SOPs should be written in terms that everybody will understand and they should include all activities needed to conduct the procedures, and describe the labor, equipment and materials needed to co mplete the activity.

The PWS should establish a routine distribution system sampling plan that is representative of the entire distribution system. The sample sites shall include, at a minimum, sites required for regulatory compliance monitoring. Additio nal sites shall be sampled as necessary to provide a complete picture of the water quality in the system. All samples should

be collected in accordance with latest edition of Standard Methods for the Examination of Water

and Wastewater

.

Routine inspections of various distribution system components such as finished water storage facilities, water mains, pump stations, chemical storage facilities, valves, and fire hydrants are necessary to ensure high

- quality water. The PWS s should implement inspection

and maintenance programs of these components as part of the SOPs

.

A written emergency response plan for the distribution system allows operating personnel to respond efficiently, effectively and rapidly to an emergency situation. Water quality system safety and reliability are improved if a PWS has an emergency response plan.

Exhibit 5-44 presents the estimated one- time cost of developing and implementing an operations and maintenance plan. The estimated cost assumes that both technical and managerial

staf f will be involved in this task.Technology and Cost Document for the 5- 52 Final Revised Total Coliform Rule 

### Exhibit 5-44: Estimated Costs to Develop and Implement an Operations Plan (2007$)

System Size Labor Rate 1 Time (hours) 2 Total Cost (2007$) 3

A B C D= B*C

< 100 $25.10 4 8 $1, 210

101

- 500 $27.03 96 $2, 600

501

- 1,000 $28.96 144 $4, 180

1,001

- 4,100 $29.73 192 $5, 710

4,101

- 33,000 $36.00 384 $13, 830

33,001

- 96,000 $36.39 384 $13, 980

96,001

- 500,000 $41.01 1152 $47, 250

500,001

- 1,000,000 $41.01 1152 $47, 250

> 1,00 0,00 0 $41.01 1152 $47, 250

1 See Exhibit 2

- 6 in Chapter 2

.
2 Time includes hours for both operator and managerial staff.

3 Estimates rounded up to the nearest $10.



### 5.11.1 Operation and Maintenance Standard Operating Procedure (SOP) Training

EPA established an o perator certification program with minimum professional standards for the operation and maintenance of PWS s. The EPA program issued guidelines that specify standards for certification and recertification of operators. States implement the minimum

standar ds of the certification program guidelines. While the specific requirements vary from

s tate to state, the goal of the program is to ensure that skilled professionals are overseeing the treatment and distribution of safe drinking water and compliance with the Safe Drinking Water

Act.

Implementation of an operator certification and training program provides guidelines f or the standards operators must uphold to operate and maintain a treatment facility or system. This

is one component necessary for the prote ction of public health and the maintenance of a safe and

reliable PWS . Training sessions for operators reinforce proper operation and maintenance of these facilities and systems. In addition, these sessions can help to educate PWS staff on emerging treat ment technologies, regulatory requirements, and other advances in the drinking

water industry.

The costs for operator training or certification include travel costs, training/certification fees, and the operator labor costs associated with the time spent a t the training or certification

session. Increased operator knowledge could potentially decrease the possibility of contamination within the distribution system. Exhibit 5 -45 summarizes the cost for operator training and certification.Technology and Cost Document for the 5- 53 Final Revised Total Coliform Rule 

### Exhibit 5-45 : Estimated Costs for Operator Training/Certification (2007$)

System Size Labor Rate 1 Course

Time (hours) 2 Total Labor

Cost Travel 3 Training/

Certification

Fees 4 Total Cost (2007$) 5

A B C D=B*C E F G=D+E+F

<100 $25.10 8 $201 $31 $125 $ 360

101

- 500 $27.03 8 $216 $31 $125 $ 380

501 - 1,000 $28.96 8 $232 $31 $125 $390

1,001 - 4,100 $29.73 8 $238 $31 $125 $400

4,101

- 33,000 $36.00 8 $288 $31 $125 $ 450

33,001 - 96,000 $36.39 8 $291 $31 $125 $450

96,001 - 500,000 $41.01 8 $328 $31 $125 $490

500,001 - 1,000,000 $41.01 8 $328 $31 $125 $490

> 1,000,00 0 $41.01 8 $328 $31 $125 $490

1 See Exhibit 2 -5 in Chapter 2. Estimated Unit Costs of Labor

.
2 Assumes an eight hour training/certification course

3 Assumes 6 0 miles of round

- trip driving distance at $0.52/mi.

4 Assumes a $125 training/certification fee for members according to the National Rural Water Association.

5 Estimates rounded up to the nearest $10.



### 5.11.2 Operation and Maintenance Plan Revision

The operations and maintenance programs described earlier in this section should be reviewed periodically and modified based on input from all affected groups so they remain accurate, beneficial, and easy to follow. AWWA Standard G200-04 outlines that the modified documents should be approved for adequacy prior to issue and the current revision status of documents should be identified. Following the approval of the modified documents a copy of the updated documents should be made available at the points of use.

Exhibi t 5 -46 presents the one time estimated cost of revising and updating an operations and maintenance plan. The estimated cost assumes that both technical and managerial staff will

be involved in this task.Technology and Cost Document for the 5- 54 Final Revised Total Coliform Rule 

### Exhibit 5-46: Estimated Costs to Maintain an Operations Plan (2007$)

System Size Labor Rate 1 Time (hours) 2 Total Cost (2007$) 3

A B C E= B*C

< 100 $25.10 10 $260

101

– 500 $27.03 14 $ 380

501

- 1,000 $28.96 29 $840

1,001

- 4,100 $29.73 29 $870

4,101

- 33,000 $36.00 48 $1,730

33,001

- 96,000 $36.39 48 $1, 750

96,001

- 500,000 $41.01 48 $1, 970

500,001-1,000,000 $41.01 96 $3,940

> 1,000,000 $41.01 96 $3,940

1 See Exhibit 2 -5 in Chapter 2

, Estimated Unit Costs of Labor

.
2 Assumes both technical and managerial time

3 Estimates rounded up to the nearest $10.



### Exhibit 5-47 presents the annual cost to implement an operation and maintenance plan.

This would include time for review of practices to ensure compliance with SOPs, document

manage ment, data collection, and related activities.

Exhibit 5-47 : Estimated Annual Costs for Operation and Maintenance Plan

I mplementation (2007$)

System Size Labor Rate 1 Time (hours) 2 Total Cost (2007$) 3

A B C E=B*C

< 100 $25.10 1 $30

101

- 500 $27.03 1 $ 30

501

- 1,000 $28.96 2 $60

1,001

- 4,100 $29.73 2 $60

4,101

- 33,000 $36.00 2 $ 80

33,001

- 96,000 $36.39 4 $ 150

96,001

- 500,000 $41.01 4 $ 170

500,001-1,000,000 $41.01 4 $170

> 1,000,000 $41.01 4 $170

1 See Exhibit 2 -5 in Chapter 2

, Estimated Unit Costs of Labor

.
2 Based on best professional judgment and typical practices

3 Estimates rounded up to the nearest $10.Technology and Cost Document for the R-1 Final Revised Total Coliform Rule 

## References

The references included in this section contain additional information for readers who wish to pursue in greater detail, the specific topics discussed in this document. Many of these references (especially the EPA references) are freely available on the internet. The references are listed alphabetically, based on the last name of the first author(s). In cases where there are two or more works by the same author (e.g. AWWA, EPA , etc.), the entries are listed by chronological order.

American Backflow Prevention Association (ABPA). 1999. ABPA Survey of State & Public Water System Cross Connection Control Programs.

American Water Works Association ( AWWA ). 2001. Utility Compensation Survey. October

2001.

AWWA . 2004a. AWWA G200 – AWWA Standard for Distributions Systems Operation and Management. Denver, CO: AWWA.

AWWA . 2004b. Impacts of Cross-Connections in North American Water Supplies. January

2001.

AWWA and AwwaRF. 1992. Water Industry Data Base: Utility Profiles. Denver, CO.

Association of State Drinking Water Administrators (ASDWA). 2001. Drinking water pro gram resource needs assessment. Version 9. November 27, 2001.

Brandt, M. J., Clement, J., Powell, J., Casey, R., Holt, D., Harris, N., and Ta, C.T. 2004. Managing Distribution System Retention Time to Improve Water Quality Denver, CO:

AWWARF

Bureau of Labor Statistics, U.S. Department of Labor, Employment Cost Index, [www.bls.gov/news.release/eci.toc.htm].

Bureau of Labor Statistics, U.S. Department of Labor, National Compensation Survey, [www.bls.gov/ncs/].

Bureau of Labor Statistics, U.S. Department of Labor, Occupational Employment Statistics, [www.bls.gov/oes/].

Clesceri, L., Greenberg , J., and Eaton , A. 1998. Standard Methods for the Examination of Water and Wastewater, 20 th 

### Edition. Washington, DC: American Public HealthTechnology and Cost Document for the R-2 Final Revised Total Coliform Rule 

### Association, American Waterworks Association, Water Environment Federation . Pp. 9-

47 to 9-78.

Davis, G., Moraca, T. and O’Connell, S, 2008. Get a Grip on Fluctuating Pressures and Flows. Opflow Magazine. Denver, CO:AWWA

Hasit, Y.J. 2004. Cost and Benefit Analysis on Flushing. Denver, CO : AWWARF

Kirmeyer, G.J and Friedman M. 2000. Guidance Manual for Maintaining Distribution System Water Quality. Denver, CO: AWWARF and AWWA

Means, R.S. 2009 Building Construction Cost Data. 62 nd 

### Annual Edition. Kingston, MA

Construction Publ ishers and Consultants

R.S. Means. 1998. Mechanical Cost Data. R.S. Means Company, Inc. Kingston, MA.

U.S. Bureau of the Census, Economic Census. Census Bureau. 1997. Available: http://www.census.gov/epcd/www/econ97.html [3 Mar 2006].

U.S. Environmental Protection Agency (USEPA). 1989. National Primary Drinking Water Regulations; Total Coliforms (Including Fecal Coliforms and E. Coli); Final Rule. 54 FR 27544. June, 29, 1989.

USEPA. 2002. 2000 Community Water System (CWS) Survey. December, 2002. EPA 815-R02-005A.

USEPA. 2003a. Consideration of Other Regulatory Revisions for Chemical Contaminants in Support of the Six-Year Review of National Primary Drinking Water Regulations. June,

2003. EPA 815-R-03-005.

USEPA. 2003b. Labor Costs for National Drinkin g Water Rules.

USEPA. 2003c. National Primary Drinking Water Regulations: Announcement of Completion of EPA's Review of Existing Drinking Water Standards. 68 FR 42907, July 18, 2003.

USEPA. 2003d. The Safe Drinking Water Information System - Federal Vers ion (SDWIS/FED) data (4th quarter freeze year 2003 data).

USEPA. 2003e. Cross-Connection Control Manual. February 2003. EPA-816-R-03-002.

USEPA. 2006a. Technology and Cost Document for the Final Ground Water Rule. EPA 815-R06-014.

USEPA. 2006b. Economic Analysis for the Final Ground Water Rule. October, 2006. EPA-815-

R-06-014.Technology and Cost Document for the R-3 Final Revised Total Coliform Rule 

### USEPA. 2006c. Economic Analysis for the Final Long Term 2 Enhanced Surface Water Treatment Rule. January, 2006. EPA-815-R-06-001.

USEPA. 2006d. Economic Analysis for the Final Stage 2 Disinfectants and Disinfection Byproducts Rule. January, 2006. EPA-715-R-05-010.

USEPA. 2006e. National Primary Drinking Water Regulations: Ground Water Rule. 71 FR 65574. November 8, 2006.

USEPA. 2006f. National Primary Drinking Water Regulations: Long Term 2 Enhanced Surface Water Treatment Rule. 71 FR 654. January 5, 2006.

USEPA. 2006g. National Primary Drinking Water Regulations: Stage 2 Disinfectants and Disinfection Byproducts Rule. 71 FR 388. January 4, 2006.

USEPA. 2007a. Total Coliform Rule Issue Paper: Distribution System Inventory, Integrity, and Water Quality.

USEPA. 2007b. Simultaneous Compliance Guidance Manual for the Long Term 2 and Stage 2

DBP Rules. EPA 815-R-07-017.

USEPA. 2007c. Meeting of the Total Coliform Rule Distrib ution System Advisory Committee

-- Notice of Public Meeting. 72 FR 35870, June 29, 2007.

USEPA. 2007d. The Safe Drinking Water Information System – Federal Version (SDWIS/FED) data. Available online: http://epa.gov/enviro/html/sdwis/ [29 Apr 2009].

USEPA. 2009. Total Coliform Rule / Distribution Systems Advisory Committee Agreement in Principle. 74 FR 1683. January 13, 2009.

USEPA. 2012a. Economic Analysis for the Proposed Revised Total Coliform Rule. EPA-815-R12-004.December 2012.

USEPA. 2012b. Nation al Primary Drinking Water Regulations: Revisions to the Total Coliform Rule; Final Rule. Federal Register.

U.S. General Services Administration (GSA). GSA. Available: http://www.gsa.gov . Privately Owned Vehicle (POV) M ileage Reimbursement Rates. [10 Feb 2009].Technology and Cost Documen t for the A-1 Final Revised Total Coliform Rule 

## Appendix A

Exhibit A -1.1: 1989 TCR (as implemented) Labor Burden Estimate for Assessments done by NCWSs serving ≤ 1,000

Nonacute MCL Violation Acute MCL Violation

Percentage of
Systems

doing

Element Estimat ed

Hours

Associated

with Element Average

Burden

Associated

with Element Percentage of
Systems

doing

Element Estimated

Hours

Associated

with Element Average

Burden

Associated

with Element

A B C = A * B D E F = D * E

Notification

Element 100% 1 1 100% 1. 75 1.75

System Specific

Element 100% 1 1 100% 0.5 0.5

Sample
Analytical

Element 0% 0 0 0% 0 0

Sample
Methodology

Element 0% 0 0 0% 0 0

Event

Situational

Element 0% 0 0 0% 0 0

Operational

Data Element 0% 0 0 0% 0 0

Historical

Trend Element 0% 0 0 0% 0 0

Sample Tap

Element 0% 0 0 0% 0 0

Sample Site

Element 0% 0 0 0% 0 0

Sample Area

Element 0% 0 0 0% 0 0

Third Party
Consulting

Element 0% 0 0 0% 0 0

Report

Element 100% 2 2 100% 4 4

Total 4 6.25
Note: Estimates informed by the collective experi ence and best professional judgment of TCRDSAC TWG members and their colleagues. The table is not intended to represent required elements of assessments and should not be interpreted as such. Rather, the table interprets both what may be occurring under the 1989 TCR and of what is anticipated to occur under the RTCR for purposes of informing the net change in labor burden associated with assessments under the R TCR.Technology and Cost Document for the A-2 Final Revised Total Coliform Rule 

### Exhibit A

- 1.2: RTCR Labor Burden Estimate for Assessments done by NCWSs serving ≤ 1,000

Level 1 Assessment Level 2 Assessment (nonacute ) Level 2 Assessment (acute)

Percentage of
Systems doing

Element Estimated

Hours

Associated

with Element Average Burden

Associated with

Element Percentage of
Systems doing

Element Estimated Hours

Associate d with

Element Average Burden

Associated with

Element Percentage of
Systems doing

Element Estimated Hours

Associated with

Element Average Burden

Associated with

Element

G H I = G * H J K L = J * K M N O = M * N

Notification

Element 100% 0 0 100% 0.5 0. 5 100% 2 2

System Specific

Element 0% 0 0 100% 0.3 0.3 100% 1 1

Sample Analytical

Element 0% 0 0 100% 0 0 100% 1 1

Sample
Methodology

Element 50% 1 0.5 100% 0.5 0.5 100% 1 1

Event Situational

Element 100% 1 1 100% 2 2 100% 2 2

Operational

Data Elemen t 60% 0.3 0.18 40% 0.5 0.2 40% 1 0.4

Historical Trend

Element 100% 0.5 0.5 100% 0.5 0.5 5% 4 0.2

Sample Tap

Element 100% 1 1 100% 1 1 100% 1 1

Sample Site

Element 100% 1 1 100% 1 1 100% 1 1

Sample Area

Element 100% 1 1 100% 1 1 20% 7 1.4

Third Party

E lement 0% 0 0 0% 0 0 50% 16 8

Report Element 100% 2 2 100% 2 2 100% 2 2

Total 7.18 9 21
Note: Estimates informed by the collective experience and best professional judgment of TCRDSAC TWG members and their colleag ues. The table is not intended to represent required elements of assessments and should not be interpreted as such. Rather, the table interprets both what may be occurr ing under the 1989 TCR and of what is anticipated to

occur under the R TCR for purposes of informing the net change in labor burden associated with assessments under the R TCR.Technology and Cost Document for the A-3 Final Revised Total Coliform Rule



### Exhibit A -2.1: 1989 TCR (as implemented) Labor Burden Estimate for Assessments done by NCWSs serving 1,001 - 4,100

Nonacute MCL Violation Acute MCL Violation

Percentage of
Systems

doing

Element E stimated

Hours

Associated

with Element Average

Burden

Associated

with Element Percentage of
Systems

doing

Element Estimated

Hours

Associated

with Element Average

Burden

Associated

with Element

A B C = A * B D E F = D * E

Notification

Element 100% 1 1 1 00% 1.8 1.8

System Specific

Element 100% 1 1 100% 0.5 0.5

Sample
Analytical

Element 50% 0 0 0% 0 0

Sample
Methodology

Element 80% 0 0 0% 0 0

Event

Situational

Element 100% 0 0 0% 0 0

Operational

Data Element 100% 0 0 0% 0 0

Historical

Trend Element 100% 0 0 0% 0 0

Sample Tap

Element 0% 0 0 0% 0 0

Sample Site

Element 0% 0 0 0% 0 0

Sample Area

Element 0% 0 0 0% 0 0

Third Party
Consulting

Element 0% 0 0 0% 0 0

Report

Element 100% 2 2 100% 3.5 3.5

Total 4 5.8
Note: Estimates informed by the co llective experience and best professional judgment of TCRDSAC TWG members and their colleagues. The table is not intended to represent required elements of assessments and should not be interpreted as such. Rather, the table interprets both what may be o ccurring under the 1989 TCR and of what is anticipated to occur under the RTCR for purposes of informing the net change in labor burden associated with assessments under the R TCR.Technology and Cost Document for the A-4 Final Revised Total Coliform Rule 

### Exhibit A

- 2.2: RTCR Labor Burden Estimate for Assessments done by NCWS s serving 1,001

- 4,100

Level 1 Assessment Level 2 Assessment (nonacute ) Level 2 Assessment (acute)

Percentage of
Systems doing

Element Estimated

Hours

Associated

with Element Average Burden

Associated with

Element Percentage of
Systems doing

Element Estimated Hours

Associated with

Element Average Burden

Associated with

Element Percentage of
Systems doing

Element Estimated Hours

Associated with

Element Average Burden

Associated with

Element

G H I = G * H J K L = J * K M N O = M * N

Notification

Ele ment 100% 0 0 100% 0.5 0.5 100% 2 2

System Specific

Element 0% 0 0 100% 0.3 0.3 100% 1 1

Sample Analytical

Element 0% 0 0 100% 0 0 100% 1 1

Sample
Methodology

Element 50% 1 0.5 100% 0.5 0.5 100% 1 1

Event Situational

Element 100% 1 1 100% 2 2 100% 2 2

Operational

Data Element 60% 0.3 0.18 40% 0.5 0.2 40% 1 0.4

Historical Trend

Element 100% 0.5 0.5 100% 0.5 0.5 5% 4 0.2

Sample Tap

Element 100% 1 1 100% 1 1 100% 1 1

Sample Site

Element 100% 1 1 100% 1 1 100% 1 1

Sample Area

Element 100% 2 2 100% 2 2 20% 7 1.4

Third Party

Element 0% 0 0 0% 0 0 50% 16 8

Report Element 100% 2 2 100% 2 2 100% 2 2

Total 8.18 10 21
Note: Estimates informed by the collective experience and best professional judgment of TCRDSAC TWG members and their colleag ues. Th e table is not intended to represent required elements of assessments and should not be interpreted as such. Rather, the table interprets both what may be occurr ing under the 1989 TCR and of what is anticipated to

occur under the R TCR for purposes of informing the net change in labor burden associated with assessments under the R TCR.Technology and Cost Document for the A-5 Final Revised Total Coliform Rule



### Exhibit A -3.1: 1989 TCR (as implemented) Labor Burden Estimate for Assessments done by CWSs serving ≤ 100

Nonacute MCL Violation Acute MCL Violation

Percentage of
Systems

doing

Element Estimated

Hours

Associated

with Element Average

Burden

Associated

with Element Percentage of
Systems

doing

Element Estimated

Hours

Associated

with Element Average

Burden

Associated

with Element

A B C = A * B D E F = D * E

Notification

E lement 100% 1 1 100% 1.5 1.5

System Specific

Element 100% 1 1 100% 1 1

Sample
Analytical

Element 0% 0 0 0% 0 0

Sample
Methodology

Element 80% 2 1.6 80% 2 1.6

Event

Situational

Element 10% 2 0.2 100% 2 2

Operational

Data Element 60% 2 1.2 60% 2 1.2

H istorical

Trend Element 0% 0 0 10% 1 0.1

Sample Tap

Element 80% 1 0.8 100% 1 1

Sample Site

Element 5% 2 0.1 5% 2 0.1

Sample Area

Element 0% 0 0 0% 0 0

Third Party
Consulting

Element 0 0% 0 0

Report

Element 100% 5.5 5.5 100% 5.5 5.5

Total 11.4 1 4 Note: Estimates informed by the collective experience and best professional judgment of TCRDSAC TWG members and their colleagues. The table is not intended to represent required elements of assessments and should not be interpreted as such. Rather, th e table interprets both what may be occurring under the 1989 TCR and of what is anticipated to occur under the RTCR for purposes of informing the net change in labor burden associated with assessments under the RTCR.Technology and Cost Document for the A-6 Final Revised Total Coliform Rule 

### Exhibit A

- 3.2: RTCR Labor Burden Esti mate for Assessments done by CWSs serving ≤ 100

Level 1 Assessment Level 2 Assessment (nonacute ) Level 2 Assessment (acute)

Percentage of
Systems doing

Element Estimated

Hours

Associated

with Element Average Burden

Associated with

Element Percentage of
Systems doing

Element Estimated Hours

As sociated with

Element Average Burden

Associated with

Element Percentage of
Systems doing

Element Estimated Hours

Associated with

Element Average Burden

Associated with

Element

G H I = G * H J K L = J * K M N O = M * N

Notification

Element 100% 2 2 100% 2 2 100% 2 2

System Specific

Element 100% 1 1 100% 1 1 100% 1 1

Sample Analytical

Element 0% 0 0 0% 0 0 0% 0 0

Sample
Methodology

Element 100% 2 2 100% 2 2 100% 2 2

Event Situational

Element 100% 2 2 100% 2 2 100% 2 2

Operational

Data Element 60% 2 1.2 60% 2 1.2 60% 2 1.2

Historical Trend

Element 100% 2 2 100% 2 2 100% 2 2

Sample Tap

Element 100% 1 1 100% 1 1 100% 1 1

Sample Site

Element 5% 2 0.1 5% 2 0.1 100% 1 1

Sample Area

Element 100% 2.5 2.5 100% 2.5 2.5 100% 2.5 2.5

Third Party

Element 0 0 0

Report Element 100% 5.5 5.5 100% 8.5 8.5 100% 8.5 8.5

Total 19.3 22.3 23.2
Note: Estimates informed by the collective experience and best professional judgment of TCRDSAC TWG members and their colleag ues. The table is not intended to rep resent required elements of assessments and should not be interpreted as such. Rather, the table interprets both what may be occurr ing under the 1989 TCR and of what is anticipated to

occur under the R TCR for purposes of informing the net change in labor burden associated with assessments under the RTCR.Technology and Cost Document for the A-7 Final Revised Total Coliform Rule



### Exhibit A -4.1: 1989 TCR (as implemented) Labor Burden Estimate for Assessments done by CWSs serving 101 - 500

Nonacute MCL Violation Acute MCL Violation

Percentage of
Systems

doing

Element Estimated

Ho urs
Associated

with Element Average

Burden

Associated

with Element Percentage of
Systems

doing

Element Estimated

Hours

Associated

with Element Average

Burden

Associated

with Element

A B C = A * B D E F = D * E

Notification

Element 100% 1 1 100% 1.5 1.5

System Specific

Element 100% 1 1 100% 1 1

Sample
Analytical

Element 0% 0 0 0% 0 0

Sample
Methodology

Element 80% 2 1.6 80% 2 1.6

Event

Situational

Element 10% 2 0.2 100% 2 2

Operational

Data Element 60% 2 1.2 60% 2 1.2

Historical

Trend Element 0% 0 0 10% 1 0.1

Sample Tap

Element 80% 1 0.8 100% 1 1

Sample Site

Element 5% 2 0.1 5% 2 0.1

Sample Area

Element 0% 0 0 5% 2 0.1

Third Party
Consulting

Element 0 0% 0 0

Report

Element 100% 5.5 5.5 100% 5.5 5.5

Total 11.4 14.1

Note: Estimates infor med by the collective experience and best professional judgment of TCRDSAC TWG members and their colleagues. The table is not intended to represent required elements of assessments and should not be interpreted as such. Rather, the table interprets both what may be occurring under the 1989 TCR and of what is anticipated to occur under the RTCR for purposes of informing the net change in labor burden associated with assessments under the RTCR.Technology and Cost Document for the A-8 Final Revised Total Coliform Rule 

### Exhibit A

- 4.2: RTCR Labor Burden Estimate for Assessments don e by CWSs serving 101

- 500

Level 1 Assessment Level 2 Assessment (nonacute ) Level 2 Assessment (acute)

Percentage of
Systems doing

Element Estimated

Hours

Associated

with Element Average Burden

Associated with

Element Percentage of
Systems doing

Elem ent Estimated Hours

Associated with

Element Average Burden

Associated with

Element Percentage of
Systems doing

Element Estimated Hours

Associated with

Element Average Burden

Associated with

Element

G H I = G * H J K L = J * K M N O = M * N

Notification

Element 100% 2 2 100% 2 2 100% 2 2

System Specific

Element 100% 1 1 100% 1 1 100% 1 1

Sample Analytical

Element 0% 0 0 0% 0 0 0% 0 0

Sample
Methodology

Element 100% 2 2 100% 2 2 100% 2 2

Event Situational

Element 100% 2 2 100% 2 2 100% 2 2

Operation al

Data Element 60% 2 1.2 60% 2 1.2 60% 2 1.2

Historical Trend

Element 100% 2 2 100% 2 2 100% 2 2

Sample Tap

Element 100% 1 1 100% 1 1 100% 1 1

Sample Site

Element 5% 2 0.1 5% 2 0.1 100% 1 1

Sample Area

Element 100% 2.5 2.5 100% 2.5 2.5 100% 2.5 2.5

T hird Party

Element 0 0 0

Report Element 100% 5.5 5.5 100% 8.5 8.5 100% 8.5 8.5

Total 19.3 22.3 23.2
Note: Estimates informed by the collective experience and best professional judgment of TCRDSAC TWG members and their colleagues. The table is not intended to represent required elements of assessments and should not be interpreted as such. Rather, the table interprets both what may be occurr ing under the 1989 TCR and of what is anticipated to

occur under the R TCR for purposes of informing the net change in labor burden associated with assessments under the RTCR.Technology and Cost Document for the A-9 Final Revised Total Coliform Rule



### Exhibit A -5.1: 1989 TCR (as implemented) Labor Burden Estimate for Assessments done by CWSs serving 501 - 1,000

Nonacute MCL Violation Acute MCL Violation

Percentage of
Systems

do ing

Element Estimated

Hours

Associated

with Element Average

Burden

Associated

with Element Percentage of
Systems

doing

Element Estimated

Hours

Associated

with Element Average

Burden

Associated

with Element

A B C = A * B D E F = D * E

Notification

Eleme nt 100% 2.5 2.5 100% 2.5 2.5

System Specific

Element 100% 1 1 100% 1 1

Sample
Analytical

Element 0% 0 0 0% 0 0

Sample
Methodology

Element 80% 2 1.6 80% 2 1.6

Event

Situational

Element 10% 2 0.2 100% 2 2

Operational

Data Element 60% 2 1.2 60% 2 1.2

H istorical

Trend Element 0% 0 0 10% 1 0.1

Sample Tap

Element 80% 1 0.8 100% 1 1

Sample Site

Element 5% 2 0.1 5% 1 0.05

Sample Area

Element 0% 0 0 5% 2 0.1

Third Party
Consulting

Element 0 0% 0 0

Report

Element 100% 5.5 5.5 100% 5.5 5.5

Total 12.9 15.05
Note: Estimates informed by the collective experience and best professional judgment of TCRDSAC TWG members and their colleagues. The table is not intended to represent required elements of assessments and should not be interpreted as such.

Rath er, the table interprets both what may be occurring under the 1989 TCR and of what is anticipated to occur under the RTCR for purposes of informing the net change in labor burden associated with assessments under the RTCR.Technology and Cost Document for the A- 10

F inal Revised Total Coliform Rule 

### Exhibit A

- 5.2: RTCR Labor Burde n Estimate for Assessments done by CWSs serving 501

- 1,000

Level 1 Assessment Level 2 Assessment (nonacute ) Level 2 Assessment (acute)

Percentage of
Systems doing

Element Estimated

Hours

Associated

with Element Average Burden

Associated with

Element Percentage of
Systems doing

Element Estimated Hours

Associated with

Element Average Burden

Associated with

Element Percentage of
Systems doing

Element Estimated Hours

Associated with

Element Average Burden

Associated with

Element

G H I = G * H J K L = J * K M N O = M * N

Notification

Element 100% 2.5 2.5 100% 2.5 2.5 100% 2.5 2.5

System Specific

Element 100% 1 1 100% 1 1 100% 1 1

Sample Analytical

Element 0% 0 0 0% 0 0 0% 0 0

Sample
Methodology

Element 100% 2 2 100% 2 2 100% 2 2

Event Situational

E lement 100% 2 2 100% 2.5 2.5 100% 2 2

Operational

Data Element 60% 2 1.2 60% 2 1.2 60% 2 1.2

Historical Trend

Element 100% 2 2 100% 2 2 100% 2 2

Sample Tap

Element 100% 1 1 100% 1 1 100% 1 1

Sample Site

Element 5% 2 0.1 5% 2 0.1 100% 1 1

Sample Area

E lement 100% 2.5 2.5 100% 2.5 2.5 100% 2.5 2.5

Third Party

Element 0 0 0

Report Element 100% 5.5 5.5 100% 8.5 8.5 100% 8.5 8.5

Total 19.8 23.3 23.7
Note: Estimates informed by the collective experience and best professional judgment of TCRDS AC TWG members and their colleagues. The table is not intended to represent required elements of assessments and should not be interpreted as such. Rather, the table interprets both what may be occurr ing under the 1989 TCR and of what is anticipated to

o ccur under the R TCR for purposes of informing the net change in labor burden associated with assessments under the RTCR.Technology and Cost Document for the A- 11 Final Revised Total Coliform Rule



### Exhibit A -6.1: 1989 TCR (as implemented) Labor Burden Estimate for Assessments done by CWSs serving 1,001 - 4,100

Nonacute MCL Violat ion Acute MCL Violation

Percentage of
Systems

doing

Element Estimated

Hours

Associated

with Element Average

Burden

Associated

with Element Percentage of
Systems

doing

Element Estimated

Hours

Associated

with Element Average

Burden

Associated

with Element

A B C = A * B D E F = D * E

Notification

Element 100% 3 3 100% 3 3

System Specific

Element 100% 1 1 100% 1 1

Sample
Analytical

Element 0% 0 0 0% 0 0

Sample
Methodology

Element 80% 3 2.4 80% 3 2.4

Event

Situational

Element 10% 5.5 0.55 100% 5.5 5.5

Operational

Data Element 60% 4 2.4 60% 4 2.4

Historical

Trend Element 100% 3 3 100% 3 3

Sample Tap

Element 80% 1.5 1.2 100% 2 2

Sample Site

Element 5% 2 0.1 100% 2 2

Sample Area

Element 30% 4 1.2 5% 3 0.15

Third Party
Consulting

Element 0 0% 0 0

Report

Element 100% 7.5 7.5 100% 7.5 7.5

Total 22.35 28.95
Note: Estimates informed by the collective experience and best professional judgment of TCRDSAC TWG members and their colleagues. The table is not intended to represent required elements of assessments and should not be interpreted as such. Rather, the table interprets both what may be occurring under the 1989 TCR and of what is anticipated to occur under the RTCR for purposes of informing the net change in labor burden associated with asses sments under the RTCR.Technology and Cost Document for the A- 12 Final Revised Total Coliform Rule 

### Exhibit A

- 6.2: RTCR Labor Burden Estimate for Assessments done by CWSs serving 1,001

- 4,100

Level 1 Assessment Level 2 Assessment (nonacute ) Level 2 Assessment (acute)

Percentage of
Systems doing

Element Estimated

Hours

Assoc iated

with Element Average Burden

Associated with

Element Percentage of
Systems doing

Element Estimated Hours

Associated with

Element Average Burden

Associated with

Element Percentage of
Systems doing

Element Estimated Hours

Associated with

Element Average Burden

Associated with

Element

G H I = G * H J K L = J * K M N O = M * N

Notification

Element 100% 2.5 2.5 100% 3 3 100% 3 3

System Specific

Element 100% 1 1 100% 2.5 2.5 100% 1 1

Sample Analytical

Element 0% 0 0 0% 0 0 0% 0 0

Sample
Methodology

E lement 100% 2 2 100% 2 2 100% 2 2

Event Situational

Element 100% 5.5 5.5 100% 2.5 2.5 100% 5.5 5.5

Operational

Data Element 60% 4 2.4 60% 4 2.4 60% 4 2.4

Historical Trend

Element 100% 3 3 100% 3 3 100% 3 3

Sample Tap

Element 100% 2 2 100% 2 2 100% 2 2

Sample Site

Element 5% 2 0.1 5% 2 0.1 100% 1.5 1.5

Sample Area

Element 100% 5 5 100% 7.5 7.5 100% 7.5 7.5

Third Party

Element 0 0 0

Report Element 100% 7.5 7.5 100% 20.5 20.5 100% 20.5 20.5

Total 31 45.5 48.4
Note: Estimates informed by t he collective experience and best professional judgment of TCRDSAC TWG members and their colleagues. The table is not intend ed to represent required elements of assessments and should not be interpreted as such. Rather, the table interprets both what may be occurring under the 1989 TCR and of what is anticipated to

occur under the R TCR for purposes of informing the net change in labor burden associated with assessments under the RTCR.Technology and Cost Document for the A- 13 Final Revised Total Coliform Rule



### Exhibit A -7.1: 1989 TCR (as implemented) Labor Burden Estimate for Asse ssments done by CWSs serving 4,001 - 33,000

Nonacute MCL Violation Acute MCL Violation

Percentage of
Systems

doing

Element Estimated

Hours

Associated

with Element Average

Burden

Associated

with Element Percentage of
Systems

doing

Element Estimated

Hour s
Associated

with Element Average

Burden

Associated

with Element

A B C = A * B D E F = D * E

Notification

Element 100% 3 3 100% 3 3

System Specific

Element 100% 1.5 1.5 100% 1.5 1.5

Sample
Analytical

Element 0% 0 0 0% 0 0

Sample
Methodology

Element 80% 3 2.4 80% 3 2.4

Event

Situational

Element 10% 5.5 0.55 100% 5.5 5.5

Operational

Data Element 75% 4 3 75% 4 3

Historical

Trend Element 100% 9 9 100% 9 9

Sample Tap

Element 100% 1.5 1.5 100% 2 2

Sample Site

Element 5% 2 0.1 100% 2 2

Sample Area

El ement 30% 4 1.2 5% 3 0.15

Third Party
Consulting

Element 0 0% 0 0

Report

Element 100% 7.5 7.5 100% 7.5 7.5

Total 29.75 36.05
Note: Estimates informed by the collective experience and best professional judgment of TCRDSAC TWG members and their

col leagues. The table is not intended to represent required elements of assessments and should not be interpreted as such. Rather, the table interprets both what may be occurring under the 1989 TCR and of what is anticipated to occur under the RTCR for purposes of informing the net change in labor burden associated with assessments under the RTCR.Technology and Cost Document for the A- 14 Final Revised Total Coliform Rule 

### Exhibit A

- 7.2: RTCR Labor Burden Estimate for Assessments done by CWSs serving 4,100

- 33,000

Level 1 Assessment Level 2 Assessment (nonacute ) Level 2 Assessm ent (acute)

Percentage of
Systems doing

Element Estimated

Hours

Associated

with Element Average Burden

Associated with

Element Percentage of
Systems doing

Element Estimated Hours

Associated with

Element Average Burden

Associated with

Element Percentage o f
Systems doing

Element Estimated Hours

Associated with

Element Average Burden

Associated with

Element

G H I = G * H J K L = J * K M N O = M * N

Notification

Element 100% 3 3 100% 3 3 100% 3 3

System Specific

Element 100% 1.5 1.5 100% 1.5 1.5 100% 1.5 1.5

Sample Analytical

Element 0% 0 0 0% 0 0 0% 0 0

Sample
Methodology

Element 100% 3 3 100% 3 3 100% 3 3

Event Situational

Element 100% 5.5 5.5 100% 7 7 100% 7 7

Operational

Data Element 75% 4 3 75% 4 3 75% 4 3

Historical Trend

Element 100% 9 9 100% 9 9 100% 9 9

Sample Tap

Element 100% 2 2 100% 2 2 100% 2 2

Sample Site

Element 5% 2 0.1 5% 2 0.1 100% 2 2

Sample Area

Element 100% 5.5 5.5 100% 7 7 100% 7.5 7.5

Third Party

Element 0 10% 109 10.9 10% 109 10.9

Report Element 100% 8.5 8.5 100% 22 22 100% 22 22

Total 41.1 68.5 70.9
Note: Estimates informed by the collective experience and best professional judgment of TCRDSAC TWG members and their colleag ues. The table is not intended to represent required elements of assessments and should not be interpreted as such. Rather, the table interprets both what may be occurring under the 1989 TCR and of what is anticipated to

occur under the RTCR for purposes of informing the net change in labor burden associated with assessments under the RTCR

.Technology and Cost Document for the A- 15 Final Revised Total Coliform Rule



### E xhibit A -8.1: 1989 TCR (as implemented) Labor Burden Estimate for Assessments done by CWSs serving 33,001 - 96,000

Nonacute MCL Violation Acute MCL Violation

Percentage of
Systems

doing

Element Estimated

Hours

Associated

with Element Average

Burden

Ass ociated

with Element Percentage of
Systems

doing

Element Estimated

Hours

Associated

with Element Average

Burden

Associated

with Element

A B C = A * B D E F = D * E

Notification

Element 100% 6 6 100% 6 6

System Specific

Element 100% 1.5 1.5 100% 1.5 1. 5

Sample
Analytical

Element 50% 4 2 50% 4 2

Sample
Methodology

Element 90% 4 3.6 90% 4 3.6

Event

Situational

Element 10% 17 1.7 100% 9.5 9.5

Operational

Data Element 90% 14 12.6 90% 14 12.6

Historical

Trend Element 100% 11 11 100% 16 16

Sample Tap

E lement 100% 3.5 3.5 100% 3.5 3.5

Sample Site

Element 10% 4 0.4 100% 4 4

Sample Area

Element 30% 14 4.2 30% 14 4.2

Third Party
Consulting

Element 0 0% 0 0

Report

Element 100% 12.5 12.5 100% 12.5 12.5

Total 59 75.4 Note: Estimates informed by the collective experience and best professional judgment of TCRDSAC TWG members and their colleagues. The table is not intended to represent required elements of assessments and should not be interpreted as such. Rather, the table interprets both what may b e occurring under the 1989 TCR and of what is anticipated to occur under the RTCR for purposes of informing the net change in labor burden associated with assessments under the RTCR.Technology and Cost Document for the A- 16 Final Revised Total Coliform Rule 

### Exhibit A

- 8.2: RTCR Labor Burden Estimate for Assessments done by CWSs serving 33,001

- 96,000

Level 1 Assessment Level 2 Assessment (nonacute ) Level 2 Assessment (acute)

Percentage of
Systems doing

Element Estimated

Hours

Associated

with Element Average Burden

Associated with

Element Percentage of
Systems doing

Element Estimated Hours

Associated with

Element Average Burden

Associated with

Element Percentage of
Systems doing

Element Estimated Hours

Associated with

Element Average Burden

Associated with

Element

G H I = G * H J K L = J * K M N O = M * N

Notification

Ele ment 100% 6 6 100% 6 6 100% 6 6

System Specific

Element 100% 1.5 1.5 100% 3.5 3.5 100% 3.5 3.5

Sample Analytical

Element 50% 4 2 50% 4 2 50% 4 2

Sample
Methodology

Element 100% 4 4 100% 4 4 100% 4 4

Event Situational

Element 100% 10 10 100% 10 10 100% 10 10

Operational

Data Element 75% 14 10.5 75% 14 10.5 75% 14 10.5

Historical Trend

Element 100% 11 11 100% 11 11 100% 16 16

Sample Tap

Element 100% 3.5 3.5 100% 5 5 100% 5 5

Sample Site

Element 10% 4 0.4 10% 5 0.5 10% 5 0.5

Sample Area

Element 100% 7 7 100% 21 21 100% 21 21

Third Party

Element 0% 0 0 10% 146 14.6 10% 146 14.6

Report Element 100% 12.5 12.5 100% 28 28 100% 28 28

Total 68.4 116.1 121.1
Note: Estimates informed by the collective experience and best professional judgment of TCRD SAC TWG members and their colleagues. The table is not intended to represent required elements of assessments and should not be interpreted as such. Rather, the table interprets both what may be occurr ing under the 1989 TCR and of what is anticipated to

occur under the RTCR for purposes of informing the net change in labor burden associated with assessments under the RTCR.Technology and Cost Document for the A- 17 Final Revised Total Coliform Rule



### Exhibit A -9.1: 1989 TCR (as implemented) Labor Burden Estimate for Assessments done by CWSs serving > 96,000

Nonacute MCL Violation Acute MCL Violation

Percentage of
Systems

doing

Element Estimated

Hours

Associated

with Element Average

Burden

Associated

with Element Percentage of
Systems

doing

Element Estimated

Hours

Associated

with Element Average

Burd en
Associated

with Element

A B C = A * B D E F = D * E

Notification

Element 100% 8 8 100% 8 8

System Specific

Element 100% 1.5 1.5 100% 1.5 1.5

Sample
Analytical

Element 90% 6 5.4 90% 6 5.4

Sample
Methodology

Element 100% 5 5 100% 5 5

Event

Situat ional

Element 10% 24 2.4 100% 13 13

Operational

Data Element 100% 14.5 14.5 100% 21 21

Historical

Trend Element 100% 23.5 23.5 100% 23.5 23.5

Sample Tap

Element 100% 9.5 9.5 100% 11.5 11.5

Sample Site

Element 10% 10 1 100% 11.5 11.5

Sample Area

Elemen t 30% 47.5 14.25 30% 14 4.2

Third Party
Consulting

Element 0 0% 0 0

Report

Element 100% 23 23 100% 12.5 12.5

Total 108.05 117.1 Note: Estimates informed by the collective experience and best professional judgment of TCRDSAC TWG members and their colleagues. The table is not intended to represent required elements of assessments and should not be interpreted as such. Rather, the table interprets both what may be occurring under the 1989 TCR and of what is anticipated to occur under the RTCR for p urposes of informing the net change in labor burden associated with assessments under the RTCR.Technology and Cost Document for the A- 18 Final Revised Total Coliform Rule 

### Exhibit A

- 9.2: RTCR Labor Burden Estimate for Assessments done by CWSs serving > 96,000

Level 1 Assessment Level 2 Assessment (nonacute ) Level 2 Assessment (acute)

Percentage of
Systems doing

Element Estimated

Hours

Associated

with Element Average Burden

Associated with

Element Percentage of
Systems doing

Element Estimated Hours

Associated with

Element Average Burden

Associated with

Element Percentage of

S ystems doing

Element Estimated Hours

Associated with

Element Average Burden

Associated with

Element

G H I = G * H J K L = J * K M N O = M * N

Notification

Element 100% 8 8 100% 8 8 100% 8 8

System Specific

Element 100% 1.5 1.5 100% 4 4 100% 4 4

Sampl e Analytical

Element 90% 6 5.4 90% 6 5.4 90% 6 5.4

Sample
Methodology

Element 100% 5 5 100% 5 5 100% 6 6

Event Situational

Element 100% 20 20 100% 20.5 20.5 100% 22 22

Operational

Data Element 100% 14.5 14.5 75% 14.5 10.875 100% 21 21

Historical Trend

Element 100% 23.5 23.5 100% 23.5 23.5 100% 23.5 23.5

Sample Tap

Element 100% 9.5 9.5 100% 18.5 18.5 100% 18.5 18.5

Sample Site

Element 10% 10 1 10% 23.5 2.35 10% 23.5 2.35

Sample Area

Element 100% 47.5 47.5 100% 78 78 100% 78 78

Third Party

Element 0% 0 0 10% 181 18.1 10% 192 19.2

Report Element 100% 23 23 100% 44 44 100% 44 44

Total 158.9 238.225 251.95
Note: Estimates informed by the collective experience and best professional judgment of TCRDSAC TWG members and their colleagues. The table is not intended to represent required elements of assessments and should not be interpreted as such. Rather, the table interprets both what may be occurr ing under the 1989 TCR and of what is anticipated to

occur under the RTCR for purposes of informing the net change in labor burden associated with assessments under the RTCR

.