Technology and Cost Document for 

the Proposed Revised Total Coliform 

Rule  

Office of Water (4607M) EPA-815-R-10-003 June 2010 www.epa.gov/safewater
Technology and Cost Document for the ii 

Proposed Revised Total Coliform Rule 

Disclaimer 

Readers may use the information presented in this document to evaluate the available technologies, operational 

practices, and compliance activities available to PWSs in complying with the proposed Revised 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 system-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 

Proposed Revised Total Coliform Rule 

CONTENTS

List of Acronyms/Abbreviations __________________________________________________viii

1 Introduction _____________________________________________________________ 1‐1

1.1 Purpose of the Document _____________________________________________________ 1‐1

1.2 Background of RTCR__________________________________________________________ 1‐1

1.3 Document Organization_______________________________________________________ 1‐2

2 Estimated Unit Costs of Labor _______________________________________________ 2‐1

2.1 Water System 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 TCR Monitoring Requirements ___________________________ 3‐1

3.1 Introduction ________________________________________________________________ 3‐1

3.2 Sample Collection and Delivery_________________________________________________ 3‐1

3.2.1 Sample Collection _________________________________________________________________ 3‐2

3.2.1.1 Sample Collection Labor Burden _________________________________________________ 3‐2

3.2.1.2 Unit Sample Collection Costs ____________________________________________________ 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

3.3.2.1 Contract Laboratories _________________________________________________________ 3‐7

3.3.2.2 In‐house Analysis _____________________________________________________________ 3‐8

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 _______________________________________________________ 4‐6

4.2.5 Event Situational Element ___________________________________________________________ 4‐6

4.2.6 Operational Data Element ___________________________________________________________ 4‐6

4.2.7 Historical Trend Element ____________________________________________________________ 4‐7

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 _____________________________________________ 4‐8

4.3.1 Methodology _____________________________________________________________________ 4‐8
Technology and Cost Document for the iv 

Proposed Revised Total Coliform Rule 

4.3.2 Assumptions_____________________________________________________________________ 4‐13

5 Estimated Unit Costs of Corrective Actions _____________________________________ 5‐1

5.1 Flushing____________________________________________________________________ 5‐3

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 Maintenance 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

5.5.4.1 Modify Inlet/Outlet Piping _____________________________________________________ 5‐24

5.5.4.2 Install Mixing Devices_________________________________________________________ 5‐25

5.5.4.3 Modify Storage Operation _____________________________________________________ 5‐26

5.5.4.4 Decommission Storage________________________________________________________ 5‐27

5.6 Storage 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 _____________________________________________________________________ 5‐30

5.7 Booster Disinfection_________________________________________________________ 5‐31

5.7.1 Chlorine System __________________________________________________________________ 5‐32

5.7.1.1 Permanent System___________________________________________________________ 5‐32

5.7.1.2 Temporary System ___________________________________________________________ 5‐32

5.7.2 Chloramines System ______________________________________________________________ 5‐35

5.7.2.1 Permanent System___________________________________________________________ 5‐35

5.7.2.2 Temporary System ___________________________________________________________ 5‐35

5.8 Cross‐connection Control and Backflow Prevention Program _______________________ 5‐39

5.8.1 Backflow Prevention Assemblies and Devices __________________________________________ 5‐39

5.8.2 Program Administration ___________________________________________________________ 5‐40

5.9 Addition or Upgrade of On‐line Monitoring and Control ___________________________ 5‐42

5.9.1 Water Quality Monitoring and Control ________________________________________________ 5‐43

5.9.1.1 Chlorinated Systems__________________________________________________________ 5‐43

5.9.1.2 Chloraminated Systems _______________________________________________________ 5‐45

5.9.2 Pressure Monitoring and Control ____________________________________________________ 5‐46
Technology and Cost Document for the v 

Proposed Revised Total Coliform Rule 

5.10 Addition of Security Measures ________________________________________________ 5‐47

5.11 Development and Implementation of an Operations Plan __________________________ 5‐48

5.11.1 Operation and Maintenance Standard Operating Procedure (SOP) Training ________________ 5‐50

5.11.2 Operation and Maintenance Plan Revision __________________________________________ 5‐51

References _______________________________________________________________ R‐1

Appendix A _______________________________________________________________ A‐1
Technology and Cost Document for the vi 

Proposed Revised Total Coliform Rule 

List of Exhibits

Exhibit 2‐1: Water System Labor Rates by System Size (2003$) __________________________________________ 2‐3

Exhibit 2‐2: State Program Wage Rates (2003$)______________________________________________________ 2‐4

Exhibit 2‐3: Water System Wage Rates by System Size (2007$) __________________________________________ 2‐4

Exhibit 2‐4: State Program Personnel Wage Rates (2007$) _____________________________________________ 2‐5

Exhibit 2‐5: Comparison of the Number of Systems in each System Size Category for the GWR EA and the         

Proposed RTCR ________________________________________________________________________________ 2‐5

Exhibit 2‐6: Water System Labor Rates by TCRDSAC TWG System 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 (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‐Delivery1 (2007$) ___________________________________________ 3‐4

Exhibit 3‐6: Per Sample Cost Estimate for Sample Self‐Delivery (2007$) ___________________________________ 3‐4

Exhibit 3‐7: Estimated Percentages1 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 (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: Current TCR (as implemented) Labor Burden Estimate for Assessments 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

Exhibit 4‐6: Estimated Labor Burden Associated with Assessments (hours)________________________________ 4‐12

Exhibit 4‐7: Estimated Labor Burden 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 Operator Training/Certification (2007$) _____________________________________ 5‐8

Exhibit 5‐6: Estimated Costs to Replace Valve (2007$) _________________________________________________ 5‐9

Exhibit 5‐7:  Estimated Costs to Replace Ductile Iron Pipe (2007$)_______________________________________ 5‐10

Exhibit 5‐8: Estimated Costs to Replace Fittings (2007$) ______________________________________________ 5‐11

Exhibit 5‐9: Estimated Costs to Replace Hydrants (2007$) _____________________________________________ 5‐12

Exhibit 5‐10: Estimated Costs to Replace Meters (2007$)______________________________________________ 5‐13

Exhibit 5‐11: Dedicated Sampling Station Schematic _________________________________________________ 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 Existing 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$)______________________________ 5‐23

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$)________________________________________ 5‐27

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$) ___________________________________ 5‐29
Technology and Cost Document for the vii 

Proposed Revised Total Coliform Rule 

Exhibit 5‐27: Estimated Costs for the Repair/Replacement of a Storage Tank Vent (2007$)___________________ 5‐30

Exhibit 5‐28: Estimated Costs for the Repair/Replacement of a Storage Tank Hatch (2007$)__________________ 5‐30

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$) ____________ 5‐33

Exhibit 5‐31: Estimated Costs to Install a Temporary Chlorine Booster Disinfection Station (2007$) ____________ 5‐34

Exhibit 5‐32: Estimated Costs to Install a Permanent Chloramines Booster Disinfection Station (2007$)_________ 5‐36

Exhibit 5‐33: Estimated Costs to Install a Temporary Chloramines Booster Disinfection Station (2007$)_________ 5‐38

Exhibit 5‐34: Estimated Costs for a Backflow Prevention Assembly (2007$) _______________________________ 5‐40

Exhibit 5‐35: Cost Components of Program Administration for a Cross‐Connection Control and Backflow        

Prevention Program___________________________________________________________________________ 5‐41

Exhibit 5‐36: Estimated Annual Cost of a Cross‐Connection Control and Backflow Prevention Program (2007$)___ 5‐42

Exhibit 5‐37: Estimated Costs for Online Chlorine Monitoring and Programming (2007$) ____________________ 5‐44

Exhibit 5‐38: Estimated Annual Operation and Maintenance Costs for an Online Chlorine Analyzer (2007$) _____ 5‐44

Exhibit 5‐39: Estimated Costs for Online Chloramines Monitoring and Programming (2007$) _________________ 5‐45

Exhibit 5‐40: Estimated Annual Operation and Maintenance Costs for Online Ammonia and Monochloramines

Analyzer (2007$) _____________________________________________________________________________ 5‐46

Exhibit 5‐41: Estimated Costs for Online Pressure Monitoring (2007$) ___________________________________ 5‐47

Exhibit 5‐42: Estimated Annual Operation and Maintenance Costs for Online Pressure Transmitter (2007$) _____ 5‐47

Exhibit 5‐43: Estimated Costs for Installation of Security Measures (2007$) _______________________________ 5‐48

Exhibit 5‐44: Estimated Costs to Develop and Implement an Operations Plan (2007$)_______________________ 5‐49

Exhibit 5‐45: Estimated Costs for Operator Training/Certification (2007$) ________________________________ 5‐50

Exhibit 5‐46: Estimated Costs to Maintain an Operations Plan (2007$)___________________________________ 5‐51

Exhibit 5‐47: Estimated Annual Costs for Operation and Maintenance Plan Implementation (2007$) ___________ 5‐52

Exhibit A‐1.1: Current TCR (as implemented) Labor Burden Estimate for Assessments done by NCWSs                   

serving <= 1,000_______________________________________________________________________________ A‐1

Exhibit A‐1.2: RTCR Labor Burden Estimate for Assessments done by NCWSs serving <= 1,000 _________________ A‐2

Exhibit A‐2.1: Current TCR (as implemented) Labor Burden Estimate for Assessments done by NCWSs                    

serving 1,001 ‐ 4,100 ___________________________________________________________________________ A‐3

Exhibit A‐2.2: RTCR Labor Burden Estimate for Assessments done by NCWSs serving 1,001 ‐ 4,100 _____________ A‐4

Exhibit A‐3.1: Current TCR (as implemented) Labor Burden Estimate for Assessments done by CWSs                      

serving <= 100 ________________________________________________________________________________ A‐5

Exhibit A‐3.2: RTCR Labor Burden Estimate for Assessments done by CWSs serving <= 100 ____________________ A‐6

Exhibit A‐4.1: Current TCR (as implemented) Labor Burden Estimate for Assessments done by CWSs                        

serving 101 ‐500_______________________________________________________________________________ A‐7

Exhibit A‐4.2: RTCR Labor Burden Estimate for Assessments done by CWSs serving 101 ‐ 500 __________________ A‐8

Exhibit A‐5.1: Current TCR (as implemented) Labor Burden Estimate for Assessments done by CWSs                      

serving 501 ‐ 1,000_____________________________________________________________________________ A‐9

Exhibit A‐5.2: RTCR Labor Burden Estimate for Assessments done by CWSs serving 501 ‐ 1,000 _______________ A‐10

Exhibit A‐6.1: Current TCR (as implemented) Labor Burden Estimate for Assessments done by CWSs                      

serving 1,001 ‐ 4,100 __________________________________________________________________________ A‐11

Exhibit A‐6.2: RTCR Labor Burden Estimate for Assessments done by CWSs serving 1,001 ‐ 4,100 ______________ A‐12

Exhibit A‐7.1: Current TCR (as implemented) Labor Burden Estimate for Assessments done by CWSs                      

serving 4,001 ‐ 33,000 _________________________________________________________________________ A‐13

Exhibit A‐7.2: RTCR Labor Burden Estimate for Assessments done by CWSs serving 4,100 ‐ 33,000_____________ A‐14

Exhibit A‐8.1: Current TCR (as implemented) Labor Burden Estimate for Assessments done by CWSs                      

serving 33,001 ‐ 96,000 ________________________________________________________________________ A‐15

Exhibit A‐8.2: RTCR Labor Burden Estimate for Assessments done by CWSs serving 33,001 ‐ 96,000____________ A‐16

Exhibit A‐9.1: Current TCR (as implemented) Labor Burden Estimate for Assessments done by CWSs                      

serving > 96,000______________________________________________________________________________ A‐17

Exhibit A‐9.2: RTCR Labor Burden Estimate for Assessments done by CWSs serving > 96,000 _________________ A‐18
Technology and Cost Document for the viii 

Proposed Revised Total Coliform Rule 

List of Acronyms/Abbreviations 

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 American Water Works Association Research Foundation 

BLS U.S. Bureau of Labor Statistics 

CA California 

CCCBFP cross connection control and backflow prevention program 

CO Colorado 

cy cubic yard 

CWS Community Water System 

DBP disinfection byproduct 

DC District of Columbia 

EA Economic Analysis 

EPA U.S. Environmental Protection Agency 

FACA Federal Advisory Committee Act 

FED Federal 

FR Federal Register 

ft Feet 

FTE full time equivalent 

GIS Geographic Information Systems 

GPCD gallons per capita per day 

GPM Gallons per Minute 

GSA U.S. General Services Administration 

GWR Ground Water Rule 

GWR EA Economic Analysis for the Ground Water Rule 

HRT Hydraulic residence time 

HVAC heating, ventilation, air conditioning 

ID Idaho 

IN Indiana 

in Inches 

kgal Thousand gallons 

KY Kentucky 

gpm gallons per minute 

MA Massachusetts 

MCL Maximum Contaminant Level 

MGD million gallons per day 

mg/L milligrams per liter 

MI Michigan 

MMO/MUG minimal medium o-nitrophenyl-beta-D-galactopyranoside 

NCS National Compensation Survey 

NCWS non-community water system 

NOM natural organic matter 
Technology and Cost Document for the ix 

Proposed Revised Total Coliform Rule 

NPDWR National Primary Drinking Water Regulations 

NRWA National Rural Water Association 

O&M operations and maintenance 

OES Occupational Employment Survey 

OH Ohio 

PA Pennsylvania 

psi pounds per square inch 

PWS Public Water System 

QA/QC Quality Assurance/Quality Control 

RTCR Revised Total Coliform Rule 

SCADA supervisory control and data acquisition 

SDWA Safe Drinking Water Act 

SDWIS/FED Safe Drinking Water Information System/Federal Version 

sf square feet 

SIC Standard Industrial Classification 

SM Standard Methods 

SOP Standard Operating Procedures 

TC Total Coliform 

TCR Total Coliform Rule 

TCRDSAC Total Coliform Rule Distribution System Advisory Committee 

TWG Technical Work Group 

US United States 

USA United States of America 

USEPA United States Environmental Protection Agency 

UV Ultraviolet 

VFD variable frequency drive 

WV West Virginia 
Technology and Cost Document for the 1-1 

Proposed Revised Total Coliform Rule 

1 Introduction 

1.1 Purpose of the Document 

This document is one of several technical documents developed in support of the 

proposed Revised Total Coliform Rule (RTCR). It describes available technologies, operational 

practices, and compliance activities that may be performed by public water systems (PWSs) in 

compliance with the proposed rule. The document also provides estimated unit costs associated 

with these technologies, operational practices, and compliance activities and descriptions of 

approaches used in developing the estimates. 

1.2 Background of RTCR 

The U.S. Environmental Protection Agency (EPA) is required to review existing national 

primary drinking water regulations every six years. In 2003, EPA completed its review of the 

Total Coliform Rule (TCR) and 68 National Primary Drinking Water Regulations (NPDWRs) 

for chemicals that were established prior to 1997. The 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 the Six-Year Review determination published in July 2003, EPA 

noticed its intent to revise the TCR. 

 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). One of the goals of convening the TCRDSAC was to make recommendations to 

EPA on revisions to the TCR promulgated in 1989 (54 FR 27565, June 29, 1989). 

 The TCRDSAC included organizational members selected by 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, the 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 degradation 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 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 TCRDSAC drew on a variety of data sources to capture experience with the current TCR, on 

analyses conducted for TCRDSAC, and on the collective experience of the member 

organizations. 

 In concert with other rules promulgated by EPA under SDWA, the revised rule construct 

will better address the TCR 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 positive total coliform (TC)/E. coli monitoring results to do an 
Technology and Cost Document for the 1-2 

Proposed Revised Total Coliform Rule 

assessment, to identify whether any sanitary defects are present, and to correct such defects 

accordingly. This is an improvement over the current TCR framework in that it takes a more 

proactive approach to identifying and fixing problems that affect or may affect public health. 

For more information on the RTCR including its background, please see the preamble to 

the proposed RCTR (USEPA 2010b). 

1.3 Document Organization 

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

Chapter 1 – Introduction 

This chapter provides 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. 

Chapter 3 – Estimated Unit Costs of TCR Monitoring Requirements 

This chapter describes the monitoring requirements 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 specific elements that public water systems might include 

in their assessments. Specific assessments required under the RTCR 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 assessments and other 

actions that might be taken by PWSs to implement the proposed RTCR and the 

associated unit costs associated with the actions. 

References 

This section lists the references for the citations used in this document. 
Technology and Cost Document for the 1-3 

Proposed Revised Total Coliform Rule 

Appendix A – RTCR Labor Burden for Assessments 

The appendix contains tables with labor burden estimates for performing various 

assessments. Tables 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 

Proposed Revised Total Coliform Rule 

2 Estimated Unit Costs of Labor 

Much of the burden associated with the proposed 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 follow-up action, and/or implementing corrective 

action. The following labor classes are used to estimate the costs associated with compliance 

activities: 

• Water system technical staff 

• Water system management staff 

• State field engineering staff 

• State program office staff 

Other chapters 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 wage 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 Water System Labor Rates 

The unit cost of labor is the wage 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 

economic analyses of several NPDWRs including that of the Ground Water Rule (USEPA, 

2006a). 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) signed for the proposed RTCR and consequently will be used to further analyze the 

national economic impact of the proposed RTCR. 

EPA identified several data sources for water industry-specific labor rates: 

• Bureau of Labor Statistics, Occupational Employment Survey (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) 

These national databases were supplemented with information provided in two EPA 

Drinking Water Program databases: the Safe Drinking Water Information System (USEPA 2008) 

and the 2000 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, 
Technology and Cost Document for the 2-2 

Proposed Revised Total Coliform Rule 

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 public 

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 occupational 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 managerial, 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 AWWA-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 regulatory cost 

models and data quality considerations, EPA selected the OES-based labor rates as nationally 

representative for use in national economic impact analyses. 

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 categories. 

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 Labor Rates. Exhibit 2-1 presents 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 

Proposed Revised Total Coliform Rule 

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

System Size (Population Served) 

Labor 

Category/Rates 25-100 101-500 

501-

3,300 3,301-10k

10,001-

100k >100k 

Fringe Benefit 

Rate1 1.3 1.4 1.5 1.5 1.5 1.5 

Technical Wage 

Rate $ 21.44 $ 23.09 $ 24.74 $ 25.34 $ 26.05 $ 31.26

Managerial Wage 

Rate $ 44.36 $ 47.78 $ 51.20 $ 51.20 $ 51.20 $ 51.20

Weighted Labor 

Rate2 $ 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 serving 3,300 

or less use 100% (technical) labor. 

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

Byproducts Rule (USEPA 2006c), and the Long Term 2 Enhanced Surface Water Treatment Rule (USEPA 2006b). 

These labor rates were applied to each of the economic analyses supporting the Ground 

Water Rule (USEPA 2006a), the Stage 2 Disinfectants and Disinfection Byproducts Rule 

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

2006b), 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 

Proposed Revised Total Coliform Rule 

Exhibit 2-2: State Program Wage Rates (2003$) 

State Labor Category Labor Cost 

Field Engineer $37.34 

Administrative $33.60 

Source: Economic analyses for the Final Ground Water Rule (USEPA, 2006a), the Stage 2 Disinfectants and 

Disinfection Byproducts Rule (USEPA 2006c), and the Long Term 2 Enhanced Surface Water Treatment Rule (USEPA 

2006b), respectively. 

2.3 Escalated Labor Rates 

The Agency continues to improve the basis from which it estimates the costs of its rules. 

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 proposed RTCR. EPA intends to use these more 

recent data sources for the final RTCR. To ensure these labor rates are presented consistently 

with other cost analyses and to present results that reflect current values, EPA has adjusted the 

water system and State program labor rates to 2007$ using an appropriate labor price index. At 

the time this document was prepared, 2007 was the latest year that a complete price index was 

available. 

Water system technical and managerial labor rates were escalated from 2003$ to 2007$ 

using a BLS Employment Cost Index – Series Index CIU2014400000000I (B), Total 

Compensation; Utilities. An escalation rate was computed using the price index for 4th Quarter 

2003 (90.2) and 4th 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 presents the escalated labor rates for water system labor categories. 

Exhibit 2-3: Water System Wage Rates by System Size (2007$) 

System Size (Population Served) 

Loaded Wage Rate (2007$) 25-100 101-500 501-3,300 3,301 -10k 10,001-100k >100k 

Technical Wage Rate $25.10 $27.03 $28.96 $29.67 $30.50 $36.60

Managerial Wage 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 analyses for the Final Ground Water Rule (USEPA, 2006a), the Stage 2 Disinfectants and 

Disinfection Byproducts Rule (USEPA 2006c), and the Long Term 2 Enhanced Surface Water Treatment Rule (USEPA 

2006b), respectively. 

State program administrative and field engineering staff labor rates were escalated from 

$2003 to 2007$ using BLS Employment Cost Index CIS3010000000000I (B) – Total 

Compensation, State and Local Government. An escalation rate was computed using the price 

index for 4th Quarter 2003 (92.7) and 4th Quarter 2007 (108.2) as follows: 108.2 ÷ 92.7 = 1.17. 

The escalation rate was applied to the 2003 labor rates to derive the corresponding 2007 labor 

rate values. Exhibit 2-4 presents the escalated labor rates for the State labor categories. 
Technology and Cost Document for the 2-5 

Proposed Revised Total Coliform Rule 

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

Notes: Labor rates escalated using the BLS Employment Cost Index – Total Compensation State and Local 

Government, CIS3010000000000I (B). 

Source: Economic analyses for the Final Ground Water Rule (USEPA, 2006a), the Stage 2 Disinfectants and 

Disinfection Byproducts Rule (USEPA 2006c), and the Long Term 2 Enhanced Surface Water Treatment Rule 

(USEPA 2006b), respectively. 

2.4 Labor Rates for RTCR Alternative Size Categories 

The TCRDSAC Technical Working Group (TWG) analyzed the impact on PWSs using a 

modified set of system sizes based on the requirements of the proposed RTCR. This is because 

certain rule provisions differ for systems above or below different population breaks (e.g., those 

serving more or less than 1,000, 4,100, or 33,000 people). Exhibit 2-5 presents the number of 

systems in each system size category for both the Economic Analysis for the Ground Water Rule 

(GWR EA) and the proposed RTCR. 

Exhibit 2-5: Comparison of the Number of Systems in each System Size 

Category for the GWR EA and the Proposed RTCR 

GWR EA Categories 

(population served) 

Number of Systems 

according to GWR 

EA Categories 

Alternative Size 

Categories for RTCR 

(population served) 

Number of Systems 

according to RTCR 

Alternative Size 

Categories 

≤100 83,746 ≤100 83,746 

101-500 42,692 101-500 42,692 

501-3,300 19,204 a) 501-1,000 

b) 1,001-4,100 

a) 9,498 

b) 10,952 

3,301-10,000 5,069 a) 1,001-4,100 

b) 4,101-33,000 

a) 10,952 

b) 6,498 

10,001-100,000 3,761 a) 4101-33,000 

b) 33,001-96,000 

c) >96,000 

a) 6,498 

b) 1,063 

c) 430 

>100,000 407 >96,000 430 

Source: USEPA 2007b. 

Exhibit 2-6 presents the water system labor rates using these alternative system size 

classifications. These were developed from the weighted labor rates presented in Exhibit 2-3 and 

reclassified into the system sizes presented below by weighing the labor rates by the numbers of 

systems in each size category outlined in Exhibit 2-5 above. 

State Labor Category Labor Cost

Field Engineer $43.58

Administrative $39.22
Technology and Cost Document for the 2-6 

Proposed Revised Total Coliform Rule 

Exhibit 2-6: Water System Labor Rates by TCRDSAC TWG System Size 

Categories (2007$) 

Note: Values developed from the weighted labor rates presented in Exhibit 2-3 and reclassified into the 

system sizes presented above by weighing the labor rates by the numbers of systems in each size 

category outlined in Exhibit 2-5 above. 

Loaded System Size (Population Served) 

Wage Rate 

(2007$) ≤100 

101 – 

500 

501 - 

1,000 

1,001 - 

4,100 

4,101 – 

33,000 

33,001 – 

96,000 >96,000 

Weighted 

Labor Rate $25.10 $27.03 $28.96 $29.73 $36.00 $36.39 $41.01 
Technology and Cost Document for the 3-1 

Proposed Revised Total Coliform Rule 

3 Estimated Unit Costs of TCR Monitoring Requirements 

3.1 Introduction 

The current 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 distribution system as part of 

the routine, repeat, and additional routine monitoring provisions of the rule. The proposed 

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 current TCR and for the 

proposed 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 TCR or proposed 

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 proposed 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 

estimated 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 very 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 

Proposed Revised Total Coliform 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 water system 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 current 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 

current TCR. For costing 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 water system 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 categories.

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

Population Served Time (hours) required per sample1

≤500 0.5 

501 – 96,000 0.75 

>96,000 1.0 

1

Developed by TCRDSAC TWG based on experience and best professional judgment of TWG members. 

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 estimates in Exhibit 3-1 

and the appropriate staff labor rate for each PWS size category. The labor rates presented in 

Exhibit 3-2 represent technical wage rates originally reported in the economic analyses of the 

final Ground Water Rule (USEPA, 2006a), the Stage 2 Disinfectants and Disinfection 

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

Rule (USEPA 2006b), respectively. See Chapter 2 for a detailed description of how these labor 

rates were derived. 
Technology and Cost Document for the 3-3 

Proposed Revised Total Coliform Rule 

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

System Size Labor Rate1 Sampling 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 proposed 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 hours 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 based 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 Day1 $6.65 $6.77 $6.88 $7.00 $7.12 

Standard Next Day1 $38.48 $38.48 $38.48 $38.48 $38.48 

Priority Overnight1 $45.12 $45.12 $45.12 $45.12 $45.12 1

Source of Cost 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 systems 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 

Proposed Revised Total Coliform Rule 

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

Number of Samples Shipped or Delivered Simultaneously Type of Delivery 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: Estimated Cost for Sample Self-Delivery1

 (2007$) 

System Size Labor 

Rate 

Drive Time 

(hours)1

Total Labor 

Cost 

Personal Vehicle Use 

Reimbursement2

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 $28.67 

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 miles 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. 

Exhibit 3-6: Per Sample Cost Estimate for Sample Self-Delivery (2007$) 

Number of Samples Shipped or Delivered Simultaneously System Size 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. 
Technology and Cost Document for the 3-5 

Proposed Revised Total Coliform Rule 

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 Percentages1

 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 average 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 obtained 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 delivery cost of $15.86. 

As another example, consider the average per-sample cost incurred by a system serving 

101-500 persons. The cost is calculated as follows: 

(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. 
Technology and Cost Document for the 3-6 

Proposed Revised Total Coliform Rule 

Exhibit 3-8: Estimated Per Sample Shipping/Delivery Cost as a Function of 

System Size (2007$) 

Number of Samples Shipped or Delivered Simultaneously System Size 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 

>96,000 $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 those 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 inhouse 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 conducting 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 analysis 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 determination. This type of method can typically 

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 

transferring the membrane after the TC test to a 4-methyl umbelliferyl β-D glucuronide (MUG) 

nutrient agar substrate. E. coli bacteria are detected by observing any coliform colonies with a 
Technology and Cost Document for the 3-7 

Proposed Revised Total Coliform Rule 

fluorescent blue periphery. The colony forming units counted on each membrane are added 

together for a reportable result as number per 100 ml. 

The preamble to the proposed RTCR (USEPA 2010b) 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 the approach for determining sample analysis cost for contractor labs versus inhouse labs. 

3.3.2.1 Contract Laboratories 

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

for itself under the current TCR is considered to be a contract laboratory. Typically contract 

laboratories are commercial laboratories holding certification in one or more States to perform 

sample analysis by approved methods under the current 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 

certification 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 required 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 allow 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 to 

perform both methods. As a simplifying assumption, analytical pricing was assumed to be 

equivalent to 2007 costs. 

Although not explicitly 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. 
Technology and Cost Document for the 3-8 

Proposed Revised Total Coliform Rule 

Exhibit 3-9: Common TC and E. coli Analytical Methods and their Average 

Contractor Lab Analytical Fee (2007$)1 

Analytical Method 

Lab (Location) 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 

Water systems 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 current 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, Indiana 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 TWG 

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. 
Technology and Cost Document for the 3-9 

Proposed Revised Total Coliform Rule 

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 

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 current TCR and for the 

proposed 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 sample 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 

Proposed Revised Total Coliform 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 (2007$) 

Number of Samples Taken Simultaneously System Size 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 $71.17 $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-house
Technology and Cost Document for the 4-1 

Proposed Revised Total Coliform Rule 

4 Estimated Unit Costs of Assessments 

The federal requirements of the current TCR do not include assessments of PWSs 

following nonacute violations or acute violations. However, under the current 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 current TCR, as implemented. In 

addition, the chapter provides an overview of the assessment provisions in the proposed RTCR 

and estimates of their associated costs for drinking water systems. 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 Proposed Revised Total Coliform 

Rule (USEPA 2010a). 

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 monitoring practices. EPA believes that assessments will 

strengthen the drinking water system’s capacity to ensure that barriers to intrusion or 

contamination are in place and effective. The proposed assessment triggers represent a 

significant improvement over the current TCR paradigm in that 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 current 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 results. The PWS will provide the primacy agency a complete Level 1 or 2 

assessment report within 30 days after notification of exceeding the trigger. 

EPA proposes that minimum elements of both Level 1 and 2 assessments should include 

a review and identification of the following: 

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

Proposed Revised Total Coliform 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 that 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 water systems) 

5. Existing 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 committed to undertaking a Level 1 or 2 assessments. 

Assessments conducted under the proposed 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 assessments 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 completed 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 40 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 assessment 

report may also note that no sanitary defects were identified. Upon completion and submission 

of the assessment report 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 assessment, but each element is investigated in greater detail. The level of 
Technology and Cost Document for the 4-3 

Proposed Revised Total Coliform 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 an 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 approved 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 not E. coli (referred to later in this document as 

Level 2 [nonacute]). 

Level 2 assessments 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 certified 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 report, the Level 2 assessment report identifies sanitary 

defects detected, corrective actions completed, and a timetable for any corrective actions not 

already completed. The assessment report may also note that no sanitary defects were identified. 

Upon completion and submission of the assessment report by the PWS, the primacy agency 

determines if the PWS has identified a likely cause for the Level 2 trigger and establishes 

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 

existing 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 not 
Technology and Cost Document for the 4-4 

Proposed Revised Total Coliform 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 

current TCR and of what is anticipated to occur under the proposed revised TCR 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. Because 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 their distribution 

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 

Notification 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 lab with questions. 

Sample Methodology Element Includes time for personnel to evaluate whether proper sampling and 

sampling handling techniques were used and to identify and note any 

deviations. 

Event Situational Element Includes time for personnel to review 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 compile 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 the 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 to 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 interpreted as such. Rather, the list is an interpretation by the TCRDSAC TWG of both 

what is occurring under the current TCR and of what is anticipated to occur under the proposed revised 

TCR 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 discussed by the TCRDSAC TWG that helped to inform that cost estimates 

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

the example assessment forms provided in Appendix X of the AIP (USEPA 2009). However, 
Technology and Cost Document for the 4-5 

Proposed Revised Total Coliform Rule 

most of the elements are equivalent or contain significant overlap, and while the investigations 

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 found in Appendix X of 

the AIP are intended to be used as conceptual 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 review 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 fax 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 to 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 to 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 estimates 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 water system 

(CWS) identification 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 laboratories to obtain QA/QC information. 
Technology and Cost Document for the 4-6 

Proposed Revised Total Coliform Rule 

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. Any 

deviations are identified, 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 for 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 advisors, 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. Some 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 includes 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 with specific event dates. In addition, this review may require 

interacting with non-water system personnel, such as construction crews. Time required will 

increase with increasing size and complexity of the system (multiple sources, larger distribution 

systems, etc.). 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 Element 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 affected 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 associated 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. 
Technology and Cost Document for the 4-7 

Proposed Revised Total Coliform Rule 

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 review 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 data 

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 addition, 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 Element 

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 review 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 

estimate is based on time to complete the report, a chain of command review, and possibly a 

legal review and briefing. 
Technology and Cost Document for the 4-8 

Proposed Revised Total Coliform Rule 

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 noncommunity water system (NCWS), on the size categories presented in Exhibit 4-2 and for the 

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 

existing TCR, as implemented) or the percentage of systems that are anticipated to spend time on 

that element (under the RTCR) and (2) the number of hours that are currently spent on that 

element (under the existing TCR, as implemented) or the number of hours that are anticipated to 

be spent on that element (under the RTCR). 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 existing TCR, as implemented, and what is anticipated to happen 

under the proposed RTCR. 

Exhibit 4-2: Categories for which cost estimates are developed 

NCWS ≤1,000 

NCWS 1,001-4,100 

NCWS 4,101-33,000 

NCWS 33,001-96,000 

NCWS >96,000 

CWS ≤100 

CWS 101-500 

CWS 501-1,000 

CWS 1,001-4,100 

CWS 4,100-33,000 

CWS 33,001-96,000 

CWS >96,000 

Exhibit 4-3: Violations and triggers leading to assessments 

Current TCR, as implemented 

Nonacute MCL Violation 

Acute MCL Violation 

Proposed RTCR 

Level 1 Trigger 

Level 2 Trigger (Nonacute) 

Level 2 Trigger (Acute) 
Technology and Cost Document for the 4-9 

Proposed Revised Total Coliform Rule 

 As an example, consider the labor burden estimates for the existing TCR, as 

implemented, incurred by CWSs serving between 1,001 and 4,100 people. Exhibit 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 existing 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. Some systems spend more time than this on assessments and some 

spend less. This methodology is meant to capture the average for the purposes of developing 

national cost estimates for the comparison of rule options. 

Exhibit 4-4: Current TCR (as implemented) Labor Burden Estimate 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 Systems 

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 0% 0 0 0% 0 0
Technology and Cost Document for the 4-10 

Proposed Revised Total Coliform Rule 

Consulting 

Element 

Report 

Element 100% 7.5 7.5 100% 7.5 7.5

Total 22.35 28.95

As a second example, consider NCWSs serving ≤ 1,000 conducting 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 with 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 depending on 

whether there is E. coli present. 
Technology and Cost Document for the 4-11 

Proposed Revised Total Coliform Rule 

Exhibit 4-5: RTCR Labor Burden Estimate for Assessments done by NCWSs serv

Level 1 Assessment Level 2 Assessment (nonacute) Level 2 As

Percentage of Systems doing Element 

Estimated Hours 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) 

Percentage of Systems doing Element 

EstimHourAssowith 

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

Notification Element 100% 0 0 100% 0.5 0.5 100% System Specific Element 0% 0 0 100% 0.3 0.3 100% Sample Analytical Element 0% 0 0 100% 0 0 100% Sample Methodology Element 50% 1 0.5 100% 0.5 0.5 100% Event Situational Element 100% 1 1 100% 2 2 100% Operational Data Element 60% 0.3 0.18 40% 0.5 0.2 40% Historical Trend Element 100% 0.5 0.5 100% 0.5 0.5 5% Sample Tap Element 100% 1 1 100% 1 1 100% Sample Site Element 100% 1 1 100% 1 1 100% Sample Area Element 100% 1 1 100% 1 1 20% Third Party Element 0% 0 0 0% 0 0 50% Report Element 100% 2 2 100% 2 2 100% Total 7.18 9 
Technology and Cost Document for the 4-12 

Proposed 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 existing TCR and the 

proposed 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 (hours) 

Current TCR, as 

implemented Proposed RTCR 

System Type/Size 

Nonacute 

MCL 

Violation 

Acute 

MCL 

Violation

Level 1 

Trigger 

Level 2 

Trigger 

(nonacute) 

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

NCWS >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

 

Exhibit 4-7: Estimated Labor Burden Associated with Assessments (2007$) 

Current TCR, as 

implemented Proposed RTCR 

System Type/Size 

Nonacute 

MCL 

Violation 

Acute 

MCL 

Violation 

Level 1 

Trigger 

Level 2 

Trigger 

(nonacute) 

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 501-1,000 $115.84 $173.76 $202.72 $260.64 $608.16 

NCWS 1,001-4,100 $118.92 $178.38 $237.84 $297.30 $862.17 

NCWS 4,101-33,000 $1,080.00 1,296.00 $1,476.00 $2,484.00 $2,556.00 

NCWS 33,001-96,000 $2,147.01 2,729.25 $2,474.52 $4,221.24 $4,403.19 

NCWS >96,000 $4,429.08 4,798.17 $6,520.59 $9,760.38 10,334.52 

CWS ≤100 $276.10 $351.40 $476.90 $552.20 $577.30 

CWS 101-500 $297.33 $378.42 $513.57 $594.66 $621.69 

CWS 501-1,000 $376.48 $434.40 $579.20 $666.08 $695.04 

CWS 1,001-4,100 $654.06 $862.17 $921.63 $1,367.58 $1,427.04 

CWS 4,100-33,000 $1,080.00 1,296.00 $1,476.00 $2,484.00 $2,556.00 

CWS 33,001-96,000 $2,147.01 2,729.25 $2,474.52 $4,221.24 $4,403.19 

CWS >96;000 $4,429.08 ,798.17 $6,520.59 $9,760.38 10,334.52 
Technology and Cost Document for the 4-13 

Proposed Revised Total Coliform Rule 

4.3.2 Assumptions 

Several underlying assumptions were made for the cost estimation development as 

follows: 

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

estimates were informed by input from States 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 complexity of interpreting any data. 

• Separate estimates were not developed for NCWSs serving >4,100. 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. 

Systems may stop conducting assessments once they have found the apparent cause 

of the problem. 
Technology and Cost Document for the 5-1 

Proposed 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 

Scheduled / Routine Flushing (Section 5.1.1) 

Unscheduled / Spot Flushing (Section 5.1.2) 

 Keep system clean and free of sediment 

 Reduce disinfectant demand of pipe surfaces 

 Remove stagnant, untreated, or contaminated 

water 

 Address water quality deterioration at dead-ends 

Sampler Training – Section 5.2  Reinforces proper sampling and sample handling 

procedures to obtain uncontaminated samples 

Replacement / Repair of Distribution System 

Components – Section 5.3 

Valves (Section 5.3.1) 

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) 

 Reduce potential sources / pathways of 

contamination from improper installation or 

material degradation 

Maintenance of Adequate Pressure – Section 

5.4 

Booster Pumping Stations (Section 5.4.1) 

Pump Modifications or Replacement (Section 5.4.2)

Variable Frequency Drives (Section 5.4.3) 

Elevated Storage Facilities (Section 5.4.4) 

Surge Relief Valves (Section 5.4.5) 

Surge Tanks (Section 5.4.6) 

 Minimize sudden changes in water velocity which 

impact system pressure 

 Reduce risk of backflow and intrusion 

contamination resulting from low pressures 

 Reduce risk of hydraulic disturbances to pipe 

surface biofilm 

Maintenance of Appropriate Hydraulic 

Residence Time – Section 5.5 

Looping Dead Ends (Section 5.5.1) 

Installing Appropriate Main Sizes (Section 5.5.2) 

Automated Flushing Devices (Section 5.5.3) 

Storage Facility Modifications (Section 5.5.4) 

 Mitigate water quality problems associated with 

increased water age (e.g. higher DBP formation, 

reduced disinfectant residual, increased microbial 

activity, nitrification, and taste-and-odor problems)

Storage Facility Maintenance – Section 5.6 

Inspecting / Cleaning of Tanks (Section 5.6.1) 

Lining of Storage Tanks (Section 5.6.2) 

Vent / Hatch Repair (Section 5.6.3) 

Tank Repair (Section 5.6.4) 

 Remove contamination from birds and insects 

 Remove accumulated sediment 

 Protect against tank wall corrosion 

Booster Disinfection – Section 5.7 

Chlorine (Section 5.7.1) 

Chloramine (Section 5.7.2) 

 Improve or maintain disinfectant residual in the 

distribution system 
Technology and Cost Document for the 5-2 

Proposed Revised Total Coliform Rule 

Action Purpose 

Cross Connection Control and Backflow 

Prevention Program – Section 5.8 

Backflow Prevention Devices (Section 5.8.1) 

Program Administration (Section 5.8.2)

 Prevent flow of non-potable substances into the 

distribution system 

Addition or Upgrade of On-line Monitoring and 

Control – Section 5.9 

Water Quality Monitoring & Control (Section 5.9.1) 

Pressure Monitoring & Control (Section 5.9.2)

 Automatically control and monitor disinfectant 

dosages and water quality parameters (other than 

total coliform) 

 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 

security breaches that could lead to water 

contamination 

 Increase public confidence in protection of their 

drinking water 

Development and Implementation of an 

Operations Plan – Section 5.11 

O&M SOP Training (Section 5.11.1) 

O&M Plan Revision (Section 5.11.2)

 Integrate all operations and maintenance 

functions to meet the goals of flow, pressure, and 

water quality 

 Establish a routine distribution system sampling 

plan 

 Implement an inspections and maintenance 

program 

 Define an emergency response plan for the 

distribution 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 costs provided in this chapter were obtained from equipment price lists and quotes, 

cost estimates from similar projects, best practices from public water systems, and from 

engineering cost data sources (R.S. Means). Where appropriate, the costs are separated into 

categories of public water systems (PWS) based on the population size that each system serves. 

The labor wage 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 public water systems 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 water system such as tools, field equipment, vehicle 

access and incidentals. 

All costs are presented in 2007 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 public water system information and 

project experience. 
Technology and Cost Document for the 5-3 

Proposed Revised Total Coliform Rule 

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, permits, field offices, temporary facilities, 

storage, mobilization and demobilization, barricades, signs, and security measures for the 

contractors. 

For all costs that 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 

Average 

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) 

A B C=B*100 D E=C*D/1440 F=C*D/106 F G=E/F 

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

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

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

1,001 - 4,100 2,550 255,000 33% 60 0.09 1 60 

4,101 - 33,000 18,550 1,855,000 33% 430 0.7 1 430 

33,001 - 96,000 64,500 6,450,000 33% 1,500 2.2 2 750 

96,001 - 500,000 298,000 29,800,000 10% 2,070 3.0 2 1,100 

500,001 - 1,000,000 750,000 75,000,000 10% 5,210 7.5 2 2,700 

> 1,000,000 1,500,000 150,000,000 10% 10,420 15.0 2 5,300 

1

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

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 et al. 2000b). 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 address 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, water systems flush until a disinfectant residual can be measured or other 

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 2004) 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 flushing 

velocity to address water quality concerns; and (3) written procedures for all elements of the 

flushing program including water quality monitoring, regulatory requirements and specific 

flushing procedures. 
Technology and Cost Document for the 5-4 

Proposed Revised Total Coliform Rule 

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 

(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 included in this estimate. 
Technology and Cost Document for the 5-5 

Proposed Revised Total Coliform Rule 

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

System Size 

Average 

System 

Population 

Labor 

Rate1

Number of 

employees 

involved in 

flushing 

program 

Percent 

time 

Committed 

to Flushing2

Total Labor 

(hours per 

year) 

Total 

Labor 

Cost 

Flushed 

Water 

Volume3,4

(kgal/yr) 

Value of 

Water 

Flushed 

per year5

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

H=0.0047*B

*100*365 

/1000 

I=H*$3.00 

<100 50 $25.10 1 <1% 8 $210 10 30 101- 500 300 $27.03 1 2-3% 48 $1,300 60 180 501 - 1,000 750 $28.96 1 3-4% 72 $2,090 130 390 1,001 - 4,100 2,550 $29.73 1 4-5% 96 $2,860 440 1,320 4,101 - 33,000 18,550 $36.00 1 18-20% 384 $13,830 3,190 9,570 33,001 - 96,000 64,500 $36.39 1 80-90% 1920 $69,870 11,070 33,210 96,001 - 500,000 298,000 $41.01 2 100% 4160 $170,610 51,130 153,390 500,001 - 1,000,000 750,000 $41.01 3 100% 6240 $255,910 128,670 386,010 > 1,000,000 1,500,000 $41.01 6 100% 12480 $511,810 257,330 771,990 

1 See Exhibit 2-6 in Chapter 2. Estimated Unit Costs of Labor. * 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 average 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 ($6 Assumes that dechlorinator attachments are part of typical 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 according to manufacturer recommendations.9 Estimates rounded up to the nearest $10 
Technology and Cost Document for the 5-6 

Proposed Revised Total Coliform Rule 

5.1.2 Unscheduled / Spot Flushing 

Upon obtaining a positive sample for total coliform (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 

events, 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

Proposed Revised Total Coliform Rule 

Exhibit 5-4: Estimated Unit Cost for Spot Flushing (2007$) 

System Size Labor Rate1 Shift Hours2 Total Labor Cost Average Hydrant Size Maximum Flushing Flow (GPM) Flushed Water Volume (kgal)3 Value of Water Flushed4 

A B C D=B*C E F G=F*60/1000 H=G*$3.00 

<100 $25.10 4 $110 4 500 30 90 101 - 500 $27.03 4 $110 4 500 30 90 501 - 1,000 $28.96 4 $120 4 500 30 90 1,001 - 4,100 $29.73 4 $120 6 750 45 135 4,101 - 33,000 $36.00 8 $290 6 750 45 135 33,001 - 96,000 $36.39 8 $300 6 750 45 135 96,001 - 500,000 $41.01 8 $330 8 1000 60 180 500,001 - 1,000,000 $41.01 8 $330 8 1000 60 180 > 1,000,000 $41.01 8 $330 8 1000 60 180 1 See Exhibit 2-6 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 half3 Flushed 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 ($5 Assumes that dechlorinator 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 

Proposed Revised Total Coliform Rule 

5.2 Sampler Training 

EPA establishes sampling requirements to determine if a distribution system is in 

compliance with regulatory requirements. Implementation 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 sampling 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 

associated 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 

Rate1

Course 

Time 

(hours)2

Total Labor 

Cost Travel3 Training/ 

Certification 

Fees4

Total 

(2007$)5

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

<100 $25.10 8 $210 $31 $125 $370 

100 - 500 $27.03 8 $220 $31 $125 $380 

501 - 1,000 $28.96 8 $240 $31 $125 $400 

1,001 - 4,100 $29.73 8 $240 $31 $125 $400 

4,101 - 33,000 $36.00 8 $290 $31 $125 $450 

33,001 - 96,000 $36.39 8 $300 $31 $125 $460 

96,001 - 500,000 $41.01 8 $330 $31 $125 $490 

500,001 - 1,000,000 $41.01 8 $330 $31 $125 $490 

> 1,000,000 $41.01 8 $330 $31 $125 $490 

1 See Exhibit 2-6 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 Rural 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 water system. 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 necessary 

excavation, setup, and restore the surface condition after replacement / repair. Where 

appropriate, assumptions on component size were made based on the population range served by 
Technology and Cost Document for the 5-9 

Proposed Revised Total Coliform Rule 

a distribution system. The most common pipe diameters are 6 and 8 inches, even for large 

systems, 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 valve 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 of 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: Estimated Costs to Replace Valve (2007$) 

System Size Labor 

Rate1 Shift Time 

(hours)2 Total Labor Cost3 Valve Size (in.)4 Valve Cost5,6

Total Cost 

(2007$)7

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

<100 $25.10 8 $610 4 $385 $1,000 

101 – 500 $27.03 8 $650 4 $385 $1,040 

501 - 1,000 $28.96 8 $700 4 $385 $1,090 

1,001 - 4,100 $29.73 8 $720 6 $565 $1,290 

4,101 - 33,000 $36.00 8 $870 6 $565 $1,440 

33,001 - 96,000 $36.39 8 $880 6 $565 $1,450 

96,001 - 500,000 $41.01 8 $990 8 $785 $1,780 

500,001 - 1,000,000 $41.01 8 $990 8 $785 $1,780 

> 1,000,000 $41.01 8 $990 8 $785 $1,780 

1 See Exhibit 2-6 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 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. Means, 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. 

Depending on the condition of the pipe, the water main can be replaced or repaired to stop 

infiltration into the system. 
Technology and Cost Document for the 5-10 

Proposed Revised Total Coliform Rule 

Prior to replacing or repairing a water main, the location 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 Rate1 Shift Time 

(hours)2 Total Labor 

Cost3 Pipe Size (in.)4

Pipe 

Cost5,6,7 

(per 20 ft.) 

Total Cost 

(2007$)8

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

<100 $25.10 8 $610 3 $167 $780 

101 – 500 $27.03 8 $650 4 $167 $820 

501 - 1,000 $28.96 8 $700 4 $167 $870 

1,001 - 4,100 $29.73 8 $720 6 $196 $920 

4,101 - 33,000 $36.00 8 $870 6 $196 $1,070 

33,001 - 96,000 $36.39 8 $880 6 $196 $1,080 

96,001 - 500,000 $41.01 8 $990 8 $265 $1,260 

500,001 - 1,000,000 $41.01 8 $990 8 $265 $1,260 

> 1,000,000 $41.01 8 $990 8 $265 $1,260 

1 See Exhibit 2-6 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 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 cost 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 located 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. 

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. 
Technology and Cost Document for the 5-11 

Proposed Revised Total Coliform Rule 

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

System Size Labor Rate1 Shift Time 

(hours)2 Total Labor 

Cost3 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 $610 4 x 4 $368 $980 

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

501 - 1,000 $28.96 8 $700 4 x 4 $368 $1,070 

1,001 - 4,100 $29.73 8 $720 6 x 6 $480 $1,200 

4,101 - 33,000 $36.00 8 $870 6 x 6 $480 $1,350 

33,001 - 96,000 $36.39 8 $880 6 x 6 $480 $1,360 

96,001 - 500,000 $41.01 8 $990 8 x 8 $686 $1,680 

500,001 - 1,000,000 $41.01 8 $990 8 x 8 $686 $1,680 

> 1,000,000 $41.01 8 $990 8 x 8 $686 $1,680 

1 See Exhibit 2-6 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 cement 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, 19th Edition. 

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; therefore, 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 for contamination. The costs included to 

replace a fire hydrant are presented in Exhibit 5-9. Costs are calculated based on labor rate data 

per population range, assumptions on the number of workers and the time required, as well as 

material costs. 
Technology and Cost Document for the 5-12 

Proposed Revised Total Coliform Rule 

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

System Size Labor Rate1 Shift Time 

(hours)2 Total Labor 

Cost3 Hydrant Cost4,5

Total Cost 

(2007$)6

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

<100 $25.10 8 $410 $1,225 $1,640 

101 – 500 $27.03 8 $440 $1,225 $1,670 

501 - 1,000 $28.96 8 $470 $1,225 $1,700 

1,001 - 4,100 $29.73 8 $480 $1,225 $1,710 

4,101 - 33,000 $36.00 8 $580 $1,225 $1,810 

33,001 - 96,000 $36.39 8 $590 $1,225 $1,820 

96,001 - 500,000 $41.01 8 $660 $1,225 $1,890 

500,001 - 1,000,000 $41.01 8 $660 $1,225 $1,890 

> 1,000,000 $41.01 8 $660 $1,225 $1,890 

1 See Exhibit 2-6 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 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 nearest $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 requirements 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 based on an 8-hour shift and 2-

person crew. 
Technology and Cost Document for the 5-13 

Proposed Revised Total Coliform Rule 

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

System Size Labor Rate1 Shift Time 

(hours)2 Total Labor 

Cost3 Meter Cost4,5 Total Cost 

(2007$)6

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

< 100 $25.10 8 $410 $329 $740 

101 - 500 $27.03 8 $440 $330 $770 

501 - 1,000 $28.96 8 $470 $330 $800 

1,001 - 4,100 $29.73 8 $480 $330 $810 

4,101 - 33,000 $36.00 8 $580 $330 $910 

33,001 - 96,000 $36.39 8 $590 $330 $920 

96,001 - 500,000 $41.01 8 $660 $330 $990 

500,001 - 1,000,000 $41.01 8 $660 $330 $990 

> 1,000,000 $41.01 8 $660 $330 $990 

1 See Exhibit 2-6 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 from 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 recommends 

that dedicated sampling stations, 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 provide reproducible samples that are representative 

of water quality at the customer’s meter” (Kirmeyer -AWWARF, 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 

sampling station. Exhibit 5-12 is a photograph of an actual dedicated sampling station. 
Technology and Cost Document for the 5-14 

Proposed 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 

Proposed Revised Total Coliform Rule 

Exhibit 5-12: Dedicated Sampling Station 

Source: With permission courtesy of Koraleen Enterprises. 

The cost of a new sampling station 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 this 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 Rate1 Shift Time 

(hours)2

Total Labor 

Cost3

Sampling 

Tap Cost4

Total Cost 

(2007$)5

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

< 100 $25.10 8 $410 $600 $1,010 

101 - 500 $27.03 8 $440 $600 $1,040 

501 - 1,000 $28.96 8 $470 $600 $1,070 

1,001 - 4,100 $29.73 8 $480 $600 $1,080 

4,101 - 33,000 $36.00 8 $580 $600 $1,180 

33,001 - 96,000 $36.39 8 $590 $600 $1,190 

96,001 - 500,000 $41.01 8 $660 $600 $1,260 

500,001-1,000,000 $41.01 8 $660 $600 $1,260 

> 1,000,000 $41.01 8 $660 $600 $1,260 

1 See Exhibit 2-6 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 / replacement 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 

Proposed Revised Total Coliform Rule 

5.4 Maintenance of Adequate Pressure 

Pressure losses 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 in 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 enter 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 

1996). The AWWA G200 standard indicates that the minimum residual pressure at the service 

connection under all operating conditions should be > 20 psi (AWWA 2004). Written standard 

operating procedures for pump, hydrant and valve operation under routine and emergency 

conditions can help minimize sudden changes in water velocity that impact system 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 maintain pressure at desirable levels. As the 

water system 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 required. 

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. 
Technology and Cost Document for the 5-17 

Proposed Revised Total Coliform Rule

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

Population Size Category 

Cost Component1

<100 

101 

to 

500 

501 

to 

1,000 

1,001 

to 

4,100 

4,101 

to 

33,000 

33,001 

to 

96,000 

96,00

to 

500,0

Pump Station Size (MGD)2 A 0.01 0.03 0.08 0.09 0.7 2.2 3.0 Number of Pumps 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 dut

1 stand

Pump Size (gpm) C 10 30 60 60 430 750 1100 Pump & Motor Cost D $780 $1,960 $2,140 $2,140 $15,280 $26,520 $36,7Pipes and related materials E $650 $1,930 $5,130 $5,770 $38,460 $141,000 $192,2Equipment Installation3 F=0.3*(D+E) $430 $1,170 $2,190 $2,380 $16,130 $50,260 $68,7Total Cost of Installed Equipment G=D+E+F $1,860 $5,060 $9,460 $10,290 $69,870 $217,780 $297,7Building Size (sf) H 72 72 72 72 167 264 366 Building Cost4 I $3,940 $3,940 $3,940 $3,940 $9,120 $14,420 $19,9Slab-on-grade Cost5,6 J $230 $230 $230 $230 $530 $830 $1,14Electrical and Instrumentation7 K=0.2*G $380 $1,020 $1,900 $2,060 $13,980 $43,560 $59,5Total Cost (2007$)8,9 L=1.225*(G+I+J+K) $7,860 $12,560 $19,030 $20,240 $114,540 $338,830 $463,61 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. 

dollars). 

5 Assumes $184.43/cubic yard. Source: R.S. Means, 2009. 6 Assumes a 6-inch slab. 7 Assumes 20% of the total installed equipment. 8 Cost rounded up to the nearest $10. 9 Includes 22.5% overhead and profit, based on R.S. Means (2009). 
Technology and Cost Document for the 5-18

Proposed 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 water system. 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 59 GPM, the pump and motor were quoted separately and summed in Row D. 

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

Population Size Category 

Cost Component 1

<100 

101 

to 

500 

50 

to 

1,000 

1,001 

to 

4,100 

4,100 

to 

33,000 

33,001 

to 

96,000 

96,001 

to 

500,000 

500,001 

to 

1,000,000 

>1,000,000

Pump Size 

(gpm)2 A 10 30 60 60 430 750 1100 2,700 5,300 

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

Motor Cost C - - - - $3,250 $5,640 $7,830 $19,670 $39,330 

Pump & Motor 

Cost D=B+C $390 $980 $1,070 $1,070 $7,640 $13,260 $18,390 $46,220 $92,430 

Related Pump 

Equipment2 E=0.3*D $120 $300 $330 $330 $2,300 $3,980 $5,520 $13,870 $27,730 

Installation3 F=0.2*(D+E) $110 $260 $280 $280 $1,990 $3,450 $4,790 $12,020 $24,040 

Total Cost 

(2007$)4,5

G=1.225* 

(D+E+F) $760 $1,890 $2,060 $2,060 $14,620 $25,350 $35,160 $88,340 $176,650 

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

 Cost rounded up to the nearest $10. 

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

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 discharge 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, including installation, overhead 

and profit. 
Technology and Cost Document for the 5-19

Proposed Revised Total Coliform Rule

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

System Size Pump Size (gpm)1 VFD Cost2 Total Cost 

(2007$)3,4

A B C D=C*1.225 

< 100 10 $700 $900 

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 - 96,000 750 $49,260 $60,350 

96,001 - 500,000 1,035 $68,730 $84,200 

500,001 - 1,000,000 2,605 $171,830 $210,500 

> 1,000,000 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

 Cost rounded up to the nearest $10 

4

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

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. 
Technology and Cost Document for the 5-20

Proposed Revised Total Coliform Rule

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

System Size Tank Size 

(gal) Tank Cost1 Foundation Cost2,3 Piping & Related 

Materials Cost4 Total Cost (2007$)5

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

< 100 25,000 $146,720 $24,159 $55,565 $294,960 

101 - 500 50,000 $202,240 $30,340 $69,770 $370,380 

501 - 1,000 100,000 $278,770 $41,820 $96,180 $510,550 

1,001 - 4,100 250,000 $384,440 $57,670 $132,630 $704,060 

4,101 - 33,000 500,000 $620,390 $93,060 $214,040 $1,136,180 

33,001 - 96,000 1,000,000 $859,980 $129,000 $296,690 $1,574,950 

96,001 - 500,000 1,000,000 $859,980 $129,000 $296,690 $1,574,950 

500,001 - 1,000,000 2,000,000 $1,719,970 $258,000 $593,390 $3,149,920 

> 1,000,000 2,000,000 $1,719,970 $258,000 $593,390 $3,149,920 

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). 

5.4.5 Install Surge Relief Valve 

Surge relief valves provide pressure management by ejecting 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 

Cost1 Total Cost2

 

(2007$) 

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 $7,250 

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

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

96,001 - 500,000 20 $41,830 $51,240 

500,001 - 1,000,000 24 $51,040 $62,520 

> 1,000,000 24 $51,040 $62,520 

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

2

 Includes 22.5% overhead and profit, based on R.S. Means (2009). 
Technology and Cost Document for the 5-21

Proposed 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 water 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 maintain system pressure. As 

water system demand increases, 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 determined 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 where the tank will be installed is 

also included in this estimated cost as well as installation and overhead and profit costs. 
Technology and Cost Document for the 5-22

Proposed Revised Total Coliform Rule

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

System Size Tank Size 

(gal) 

Tank 

Cost1,2

Tank Control & 

Accessories3 Slab-ongrade4,5 Installation6 Total Cost 

(2007$)7,8

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 $2,100 $15,430 

101 - 500 500 $6,650 $2,660 $1,180 $2,100 $15,430 

501 - 1,000 1,000 $9,020 $3,610 $1,640 $2,850 $20,980 

1,001 - 4,100 2,000 $12,660 $5,070 $2,100 $3,970 $29,160 

4,101 - 33,000 7,500 $29,790 $11,920 $4,010 $9,140 $67,210 

33,001 - 96,000 10,000 $34,980 $14,000 $5,280 $10,850 $79,760 

96,001 - 500,000 12,000 $39,630 $15,860 $6,290 $12,360 $90,830 

500,001 - 1,000,0009 NA NA NA NA NA NA 

> 1,000,0009 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 USABlueBook 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-grade. 7 Includes 22.5% overhead and profit, based on R.S. Means (2009). 8 Estimates rounded up to the nearest $10. 

9

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

5.5 Maintenance of Appropriate Hydraulic Residence Time 

As water travels through the distribution system, 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. Other water quality problems associated with increased 

water age include reduced disinfectant residual, increased microbial activity, nitrification, and/or 

taste and odor problems. Water systems should develop an overall strategy to manage the water 

age in their distribution 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 average 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 dead-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 stagnant 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 not actually reduce the long detention times present in those areas. 

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. 
Technology and Cost Document for the 5-23

Proposed Revised Total Coliform Rule

5.5.2 Install Appropriate Main Sizes 

Most distribution 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. 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 pipes 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 flushing devices are used to purge accumulated sediments at low spots and 

the dead-ends of pipelines at regular intervals and for draining pipelines for repairs, maintenance, 

and inspection. These devices are best suited to rural networks in which security 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. 

Exhibit 5-20: Estimated Costs to Install Automated Flushing Devices (2007$) 

System Size Labor Rate1 Shift Time 

(hours) 

Total Labor 

Cost2

Automated 

Flushing Device 

Cost3,4

Total Cost 

(2007$)5

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

<100 $25.10 8 $410 $3,190 $3,600 

101 - 500 $27.03 8 $440 $3,190 $3,630 

501 - 1,000 $28.96 8 $470 $3,190 $3,660 

1,001 - 4,100 $29.73 8 $480 $3,190 $3,670 

4,101 - 33,000 $36.00 8 $580 $3,190 $3,770 

33,001 - 96,000 $36.39 8 $590 $3,190 $3,780 

96,001 - 500,000 $41.01 8 $660 $3,190 $3,850 

500,001 - 1,000,000 $41.01 8 $660 $3,190 $3,850 

> 1,000,000 $41.01 8 $660 $3,190 $3,850 

1

 See Exhibit 2-6 in Chapter 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. 
Technology and Cost Document for the 5-24

Proposed Revised Total Coliform Rule

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 facilities 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 water storage facilities, thereby reducing DBP formation, loss of disinfectant and 

microbial growth. Kirmeyer et al. (2000b) recommend complete turnover every three to five 

days but suggest that water systems establish their own turnover goal based on system-specific 

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 during 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 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: 

• 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 achieve 

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. 

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 

20% of the materials cost based on similar experience at several PWSs. Note that this estimate 

does not include the cost of designing the new inlet/outlet configuration. 
Technology and Cost Document for the 5-25

Proposed Revised Total Coliform Rule

Exhibit 5-21: Estimated Costs to Modify Inlet/Outlet Piping (2007$) 

System Size Tank Size (gal) Pipe & Related 

Materials Cost1 Installation Cost2

 Total Cost (2007$)3,4

A B C D=0.2*C E=(C+D)*1.225 

< 100 25,000 $5,060 $1,020 $7,450 

101 - 500 50,000 $6,980 $1,400 $10,270 

501 - 1,000 100,000 $9,620 $1,930 $14,150 

1,001 - 4,100 250,000 $13,260 $2,660 $19,500 

4,101 - 33,000 500,000 $21,400 $4,280 $31,460 

33,001 - 96,000 1,000,000 $29,670 $5,940 $43,620 

96,001 - 500,000 1,000,000 $29,670 $5,940 $43,620 

500,001 - 1,000,000 2,000,000 $59,340 $11,870 $87,230 

> 1,000,000 2,000,000 $59,340 $11,870 $87,230 

1 Assumes 10% of the Piping & Related Materials Cost of installing a new storage tank presented in Exhibit 5-16, column E. 

2

 Assumes installation equal to 20% of the materials cost. 

3 Estimates rounded up to the nearest $10. 

4 Assumes and includes a 22.5% Overhead and Profit cost, based on R.S. Means (2009). 

5.5.4.2 Install Mixing Devices 

Mixing the storage facility contents to reduce stagnant zones can also be 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 should 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 installation 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 Exhibit 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

Proposed Revised Total Coliform Rule

Exhibit 5-22: Estimated Costs to Install Mixing Devices (2007$) 

System Size Tank Size 

(gal) 

Mixing 

System 

Cost1

Pipes & 

Related 

Materials Cost2

Installation 

Cost3

Total Cost4

(2007$) 

A B C D E=0.2*(C+D) F=1.225*(C+

D+E) 

< 100 50,000 $1,650 $6,980 $1,730 $12,690 

101 - 500 50,000 $1,650 $6,980 $1,730 $12,690 

501 - 1,000 100,000 $3,290 $9,620 $2,590 $18,990 

1,001 - 4,100 250,000 $8,230 $13,260 $4,300 $31,590 

4,101 - 33,000 500,000 $16,450 $21,400 $7,570 $55,640 

33,001 - 96,000 1,000,000 $32,900 $29,670 $12,520 $91,990 

96,001 - 500,000 1,000,000 $32,900 $29,670 $12,520 $91,990 

500,001 - 1,000,000 2,000,000 $65,800 $59,340 $25,030 $183,960 

> 1,000,000 2,000,000 $65,800 $59,340 $25,030 $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). 

5.5.4.3 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 maintaining 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 therefore 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

Proposed Revised Total Coliform Rule

Exhibit 5-23: Estimated Costs to Modify Storage Operation (2007$) 

System Size Labor Rate1 Labor Time 

(hours)2 Programmer 

Rate3,4 Programming Time (hours) 

Total Cost 

(2007$) 

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

< 100 $25.10 8 NA NA $210 

101 - 500 $27.03 8 NA NA $220 

501 - 1,000 $28.96 8 NA NA $240 

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 $1,260 

96,001 - 500,000 $41.01 8 $120 8 $1,290 

500,001 - 1,000,000 $41.01 8 $120 8 $1,290 

> 1,000,000 $41.01 8 $120 8 $1,290 

1

 See Exhibit 2-6 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. 

5.5.4.4 Decommission Storage 

Decommissioning storage facilities may be an appropriate 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 determine 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 outside company that will clean the tank. 

Exhibit 5-24: Estimated Costs to Decommission Storage (2007$) 

System Size Tank Size (gal) Labor Rate1 Time 

(hours) 

Total Labor 

Cost2

Tank 

Cleaning 

Cost3

Total Cost 

(2007$)4

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

< 100 25,000 $25.10 8 $410 $1,340 $1750 

101 -500 50,000 $27.03 8 $440 $1,510 $1,950 

501 - 1,000 100,000 $28.96 8 $470 $1,830 $2,300 

1,001 - 4,100 250,000 $29.73 8 $480 $3,190 $3,670 

4,101 - 33,000 500,000 $36.00 8 $580 $5,020 $5,600 

33,001 - 96,000 1,000,000 $36.39 8 $590 $7,750 $8,340 

96,001 - 500,000 1,000,000 $41.01 8 $660 $7,750 $8,410 

500,001 - 1,000,000 2,000,000 $41.01 8 $660 $9,110 $9,770 

> 1,000,000 2,000,000 $41.01 8 $660 $9,110 $9,770 

1 See Exhibit 2-6 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 5-24. 

4

 Estimates rounded up to the nearest $10. 
Technology and Cost Document for the 5-28

Proposed Revised Total Coliform Rule

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 of 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. 

Exhibit 5-25 presents the costs associated with inspecting and cleaning various sized 

finished water storage tanks. Assumptions regarding tank 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. 
Technology and Cost Document for the 5-29

Proposed Revised Total Coliform Rule

Exhibit 5-25: Estimated Costs for the Inspection and Cleaning of Storage Tanks 

(2007$) 

System Size Tank Size 

(gal) Tank Type Total Cost1,2 

(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 $7,750 

500,001 - 1,000,000 2,000,000 Elevated $9,110 

> 1,000,000 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 the 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 be 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. 

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 

> 1,000,000 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 
Technology and Cost Document for the 5-30

Proposed Revised Total Coliform Rule

5.6.3 Vent/Hatch Repair 

One of the most common sources of contamination in a water storage tank is the 

improper 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 twoperson crew and two hours for installation. Exhibit 5-28 presents similar installed costs of repair 

or replacement of a storage tank hatch. 

Exhibit 5-27: Estimated Costs for the Repair/Replacement of a Storage Tank Vent 

(2007$) 

System Size Labor Rate1 Shift Time 

(hours) 

Total Labor 

Cost2 Vent Screen 

Cost3 Total Cost (2007$) 

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

< 100 $25.10 2 $110 $50 $160 

101 - 500 $27.03 2 $110 $50 $160 

501 - 1,000 $28.96 2 $120 $50 $170 

1,001 - 4,100 $29.73 2 $120 $50 $170 

4,101 – 33,000 $36.00 2 $150 $50 $200 

33,001 - 96,000 $36.39 2 $150 $50 $200 

96,001 - 500,000 $41.01 2 $170 $50 $220 

500,001 - 1,000,000 $41.01 2 $170 $50 $220 

> 1,000,000 $41.01 2 $170 $50 $220 

1 See Exhibit 2-6 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 frame cost and $45 screen cost

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 covers can also be a source of microbial 

contamination. Exhibit 5-29 presents estimated costs for repairing water storage tank covers 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 cost of 

a new tank, which includes material, labor, overhead, and profit. 
Technology and Cost Document for the 5-31

Proposed Revised Total Coliform Rule

Exhibit 5-29: Estimated Costs for the Repair of Storage Tanks (2007$) 

System Size Tank Size 

(gal) Tank Type New Tank Cost1 Total Cost2

 

(2007$) 

A B C D E=0.2*D 

< 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 

> 1,000,000 2,000,000 Elevated $1,719,970 $344,000 

1 Assumes installed cost of a new elevated storage tank, as presented in Exhibit 5-16. 

2

 Tank repair costs estimated at 20% of new tank costs. 

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 system, potable 

water from a treatment facility must 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 to 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 based 

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 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 systems were assumed to 

operate one day and provide one day of chemical storage. It is assumed that an operator would 

visit the facility for two hours for the day the system was in 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 various times of the 

year. Some systems experience higher levels of organic growth at certain times of the year, 

particularly the summer months. Therefore, the booster disinfection facilities are not 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 equipment. Yearly operation 

and maintenance costs include labor, chemical, and parts and maintenance costs. 
Technology and Cost Document for the 5-32

Proposed Revised Total Coliform Rule

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 on 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 used 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 

did not require a storage container. The manufacturer provided 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. 

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. There 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 5-33

Proposed Revised Total Coliform Rule

Exhibit 5-30: Estimated Costs to Install a Permanent Chlorine Booster Disinfection Stat

1 Tablet chlorinator systems assumed for system sizes 10,000 and less; liquid hypochlorite systems 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 pumps 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. 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 2-6 of Section 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 Assumes 10% of equipment cost. 

Population Size Category 

Cost Component 

<100 

101 to 

500 

501 to 

1,000 

1,001 to

4,100 

4,100 to

33,000 

33,001 to 

96,000 

96,001 to 

500,000 

500,00

1,000

Tablet Chlorinator System1

Usage Rate (lb/hr) A 0.003 0.01 0.01 0.04 - - - - 

System Size (lb/hr) B 0.5 0.5 0.5 0.5 - - - - 

System Cost2 C $6,840 $6,840 $6,840 $6,840 - - - - 

Liquid Hypochlorite System1

Usage Rate (gal/hr) D - - - - 0.32 1.12 1.55 3.9

Pump Size (gal/hr) E - - - - 0.55 1.9 1.9 5 

Total Pump Cost (two pumps)3 F - - - - $1,100 $1,190 $1,190 $1,1

Storage Requirement4 (gal) G - - - - 300 900 1,200 2,90

Storage Tank Cost3 H - - - - $640 $1,190 $1,010 $2,0

Cost of Piping and Appurtenances5 I $250 $250 $250 $250 $270 $360 $330 $48Cost of Instrumentation and Electrical5 J $250 $250 $250 $250 $270 $360 $330 $48Total Cost of Equipment K=C+F+H+I+J $7,340 $7,340 $7,340 $7,340 $2,280 $3,100 $2,860 $4,1Total Structure Cost6 L $4,200 $4,200 $4,200 $4,200 $9,660 $9,660 $12,940 $23,7Cost of Installation7 M=0.15*(K+L) $1,740 $1,740 $1,740 $1,740 $1,800 $1,920 $2,370 $4,2Total Capital Cost (2007$)8 N=1.225*(K+L+M) $16,270 $16,270 $16,270 $16,270 $16,840 $17,990 $22,260 $39,3Labor Cost ($/year)9 O $8,520 $9,120 $9,840 $10,080 $12,120 $12,240 $13,800 $13,8Chemical Cost ($/year)10 P $120 $360 $360 $960 $6,000 $15,600 $20,400 $48,0Parts and Maintenance Cost ($/year)11 Q=0.1*K $740 $740 $740 $740 $230 $310 $290 $42Yearly Operation and Maintenance Cost R=O+P+Q $9,380 $10,220 $10,940 $11,780 $18,350 $28,150 $34,490 $62,2
Technology and Cost Document for the 5-34

Proposed Revised Total Coliform Rule

Exhibit 5-31: Estimated Costs to Install a Temporary Chlorine Booster Disinfection Stat

Population Size Category 

Cost Component 

<100 

101 to 

500 

501 to 

1,000 

1,001 to 

4,100 

4,100 to 

33,000 

33,001 to 

96,000 

96,00

500,

Usage Rate (gal/hr) A 0.003 0.01 0.04 0.04 0.32 1.12 1.5Pump Size (gal/hr) B 0.19 0.19 0.19 0.19 0.55 1.9 1.Total Pump Cost (one pump)1 C $540 $540 $540 $540 $560 $640 $6Storage Requirement (gal) D 10 10 10 10 10 30 4Type of Storage Container2 E Carboy Carboy Carboy Carboy Drum Drum DruCost of Piping and Appurtenances3 F=0.15*C $90 $90 $90 $90 $90 $100 $1Cost of Instrumentation and Electrical3 G=0.15*C $90 $90 $90 $90 $90 $100 $1Total Cost of Equipment H=C+F+G $720 $720 $720 $720 $740 $840 $8Total Structure Cost4 I $930 $930 $1,000 $1,000 $1,460 $1,660 $1,6Cost of Installation5 J=0.15*(H+I) $250 $250 $260 $260 $330 $380 $3Total Capital Cost (2007$)6 K=1.225*(H +I+J) $1,900 $1,900 $1,980 $1,980 $2,530 $2,880 $2,8Labor Cost ($/year)7 L $60 $60 $60 $60 $80 $80 $9Chemical Cost($/year)8 M $90 $90 $90 $90 $90 $90 $9Parts and Maintenance Cost ($/year)9 N=0.1*H $80 $80 $80 $80 $80 $90 $9Yearly Operation and Maintenance Cost O=L+M+N $230 $230 $230 $240 $250 $260 $21 Pump cost per Cole Palmer catalog (2008), adjusted to 2007 dollars. Pumps are solenoid diaphragm metering pumps. 2 Assumes storage containers obtained from chemical supplier, and returned for refund of any applicable deposit. 3 Assumes 15% of pump costs. 4 Structure cost includes building and slab per R.S. Means, 2009. 5 Assume 15% of equipment and structure costs. 6 Assume two hours of maintenance a day based on labor rates presented in Exhibit 2-6 of Section 2. Estimated Unit Costs of Labor7 Includes 22.5% overhead and profit, based on R.S. Means, 2009. 8 Chemical cost based on minimum chemical delivery volume per chemical vendor. 9 Assumes 10% of equipment cost.
Technology and Cost Document for the 5-35 

Proposed 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 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 of 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 tanks. 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 booster 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 5-36

Proposed Revised Total Coliform Rule

Exhibit 5-32: Estimated Costs to Install a Permanent Chloramines Booster Disinfection St

Population Size Category 

Cost Component 

<100 

101 to 

500 

501 to 

1,000 

1,001 to 

4,100 

4,100 to 

33,000 

33,001 to 

96,000 

96,001 

500,00

Tablet Chlorinator System1

Usage Rate (lb/hr) A 0.003 0.01 0.01 0.04 - - - 

System Size (lb/hr) B 0.5 0.5 0.5 0.5 - - - 

System Cost2 C $6,840 $6,840 $6,840 $6,840 - - - 

Liquid Hypochlorite System1

Usage Rate (gal/hr) D - - - - 0.32 1.12 1.55 

Pump Size (gal/hr) E - - - - 0.55 1.9 1.9 

Pump Cost3 F - - - - $1,100 $1,190 $1,190 

Storage Requirement (gal)4 G - - - - 300 900 1200 

Storage Tank Cost3 H - - - - $640 $1,190 $1,010 

Aqua Ammonia System 

Usage Rate (gal/hr) I 0.0004 0.002 0.002 0.007 0.049 0.169 0.235 

Pump Size (gal/hr) J 0.19 0.19 0.19 0.19 0.19 0.29 0.29 

Pump Cost3 K $1,100 $1,100 $1,100 $1,100 $1,100 $1,100 $1,100 

Storage Requirement(gal)4 L 10 10 10 10 40 130 170 

Storage Tank Cost3 M - - - - - - - 

Cost of Piping and Appurtenances5 N=0.15*(C+F +H+K+M) $420 $420 $420 $420 $430 $530 $500 Cost of Instrumentation and Electrical5 O=0.15*(C+F +H+K+M) $420 $420 $420 $420 $430 $530 $500 Total Cost of Equipment P=C+F+H+K

+M+N+O $8,780 $8,780 $8,780 $8,780 $3,700 $4,540 $4,300 

Total Structure Cost($/year)6 Q $7,870 $7,870 $7,930 $7,930 $15,580 $15,580 $19,59Cost of Installation7 R=0.15*(P+Q ) $2,500 $2,500 $2,510 $2,510 $2,900 $3,020 $3,590 Total Capital Cost (2007$)8 S=1.225(P+Q +R) $23,460 $23,460 $23,550 $23,550 $27,180 $28,350 $33,67
Technology and Cost Document for the 5-37

Proposed Revised Total Coliform Rule

Population Size Category 

Cost Component 

<100 

101 to 

500 

501 to 

1,000 

1,001 to 

4,100 

4,100 to 

33,000 

33,001 to 

96,000 

96,001 

500,00

Operations & Maintenance Costs Labor Cost($/year)9 T $8,600 $9,200 $9,900 $10,100 $12,200 $12,300 $13,80Chemical Cost($/year)10 U $200 $500 $500 $1,100 $9,500 $19,200 $24,00Parts and Maintenance Cost ($/year)11

V=0.1*P 

$880 $880 $880 $880 $370 $460 $430 

Yearly O&M Cost W=T+U+V $9,700 $10,600 $11,300 $12,100 $22,100 $32,000 $38,301 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 pumps and tanks are polyethylene ta4 Storage requirements based on providing approximately 30 days of chemical storage. 5 Assume 15% of chemical system and storage costs 6 Structure cost includes building and slab per R.S. Means 2009 7 Assume 15% of equipment and structure costs 8 Includes 22.5% overhead and profit, based on R.S. Means 9 Assumes one hour of maintenance a day based on labor rates presented in Exhibit 2-6 of Section 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 Assumes 10% of equipment cost. 
Technology and Cost Document for the 5-38

Proposed Revised Total Coliform Rule

Exhibit 5-33: Estimated Costs to Install a Temporary Chloramines Booster Disinfection St

1 Pump cost per Cole Palmer catalog. Pumps are solenoid diaphragm metering pumps. 2 Assumes storage containers obtained from chemical supplier, and returned for refund of any applicable deposit. 3 Assume 15% of chemical systems costs 4 Structure cost includes building and slab per R.S. Means 2009 5 Assume 15% of equipment and structure costs 6 Includes 22.5% overhead and profit, based on R.S. Means 7Assume two hours of maintenance a day based on labor rates presented in Exhibit 2-6 of Section 2. Estimated Unit Costs of Labor8 Chemical cost based on minimum chemical delivery volume (For hypochlorite a 55 gallon drum is $82.50 and a 300 gallon tote is $450.00, and for ammonia 9 Assumes 10% of equipment cost.

Population Size Category 

Cost Component1 <100 <500 501 to 1,000 1,001 to 4,100 4,100 to 33,000 33,001 to 96,000 96,00

500,

Liquid Hypochlorite System 

Usage Rate (gal/hr) A 0.003 0.01 0.01 0.04 0.32 1.12 1.5

Pump Size (gal/hr) B 0.19 0.19 0.19 0.19 0.55 1.90 1.9

Pump Cost1 C $540 $540 $540 $540 $560 $560 $56

Storage Requirement (gal) D 10 10 10 10 10 30 40 

Type of Storage Container2 E Carboy Carboy Carboy Carboy Drum Drum Dru

Aqua Ammonia System 

Usage Rate (gal/hr) F 0.002 0.002 0.002 0.007 0.049 0.169 0.2

Pump Size (gal/hr) G 0.19 0.19 0.19 0.19 0.19 0.29 0.2

Pump Cost1 H $540 $540 $540 $540 $540 $540 $54

Storage Requirement (gal) I 10 10 10 10 10 10 10 

Type of Storage Container2 J Carboy Carboy Carboy Carboy Carboy Carboy Carb

Cost of Piping and Appurtenances3 K=0.15*(C+H) $170 $170 $170 $170 $170 $170 $17Cost of Instrumentation and Electrical3 L=0.15*(C+H) $170 $170 $170 $170 $170 $170 $17Total Cost of Equipment M=C+H+K+L $1,420 $1,420 $1,420 $1,420 $1,440 $1,440 $1,4Total Structure Cost4 N $1,920 $1,920 $1,920 $1,920 $2,920 $2,920 $2,9Cost of Installation5 O=0.15*(M+N) $510 $510 $510 $510 $660 $660 $66Total Capital Cost (2009$)6 P $4,720 $4,720 $4,720 $4,720 $6,150 $6,150 $6,1Labor Cost7 Q $60 $60 $60 $60 $80 $80 $9Chemical Cost8 R $150 $150 $150 $150 $150 $150 $15Parts and Maintenance Cost9 S $150 $150 $150 $150 $150 $150 $15Yearly Operation and Maintenance Cost T $370 $370 $370 $370 $390 $390 $40
Technology and Cost Document for the 5-39 

Proposed 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 drinking water system 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 prevention 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 classified 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’ costs 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 

Exhibit 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 valves 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 and 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 5-40 

Proposed Revised Total Coliform Rule 

Exhibit 5-34: Estimated Costs for a Backflow Prevention Assembly (2007$) 

System Size Labor 

Rate1

Shift 

Time 

(hours) 

Total Labor 

Cost2

Backflow 

Preventer 

Pipe Size (in.) 

Backflow 

Preventer 

Cost3,4 Total Cost (2007$)5

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

< 100 $25.10 8 $610 2.5 $2,825 $3,440 

101 - 500 $27.03 8 $650 2.5 $2,825 $3,480 

501 - 1,000 $28.96 8 $700 2.5 $2,825 $3,530 

1,001 - 4,100 $29.73 8 $720 2.5 $2,825 $3,550 

4,101 - 33,000 $36.00 8 $870 3 $2,950 $3,820 

33,001 - 96,000 $36.39 8 $880 3 $2,950 $3,830 

96,001 - 500,000 $41.01 8 $990 4 $3,725 $4,720 

500,001 - 1,000,000 $41.01 8 $990 6 $5,375 $6,370 

> 1,000,000 $41.01 8 $990 6 $5,375 $6,370 

1 See Exhibit 2-6 in Chapter 2. Estimated Unit Costs of Labor

2

 Labor cost assumes a three-person crew working for a total of 8 hours. 

3

 Backflow preventer cost 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 nearest $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, residential, 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 duties 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 CCCBPP. 

Exhibit 5-35 summarizes the activities included under each of the three components of 

Program Administration. 
Technology and Cost Document for the 5-41 

Proposed Revised Total Coliform Rule 

Exhibit 5-35: Cost Components of Program Administration for a CrossConnection Control and 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 hazardous 

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 test 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 costs 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 cost 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 5-42 

Proposed Revised Total Coliform Rule 

Exhibit 5-36: Estimated Annual Cost of a Cross-Connection Control and Backflow 

Prevention Program (2007$) 

System Size Total Labor Cost Equipment 

Material Others Total Cost1

 (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 

> 1,000,000 $1,462,640 $300,710 $66,470 $1,829,810 

Source: Estimates adapted from Table 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 parameters. 

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 treatment 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 the 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 

systems, 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 5-43 

Proposed 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 

pressure 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 analyzer 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, in 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, which 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 Chlorinated 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 associated 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 presents 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 5-44 

Proposed Revised Total Coliform Rule 

Exhibit 5-37: Estimated Costs for Online Chlorine Monitoring and Programming 

(2007$) 

System Size Labor 

Rate1

Labor 

Time 

(hours)2

Programmer 

Rate3

Program.

Time 

(hours)4

Total Labor 

& Program. 

Cost2

Chlorine 

Analyzer 

Cost5

Piping 

and 

related6

Total 

Cost7,8 

(2007$) 

A B C D E F=B*C*2+D*E G H I=F+G+H 

< 100 $25.10 24 $120 8 $2,170 $2,770 $460 $5,400 

101 - 500 $27.03 24 $120 8 $2,260 $2,770 $460 $5,490 

501 -1,000 $28.96 24 $120 8 $2,360 $2,770 $460 $5,590 

1,001 - 4,100 $29.73 24 $120 8 $2,390 $2,770 $460 $5,620 

4,101 - 33,000 $36.00 24 $120 8 $2,690 $2,770 $460 $5,920 

33,001 - 96,000 $36.39 24 $120 8 $2,710 $2,770 $460 $5,940 

96,001 - 500,000 $41.01 24 $120 8 $2,930 $2,770 $460 $6,160 

500,001 - 

1,000,000 $41.01 24 $120 8 $2,930 $2,770 $460 $6,160 

> 1,000,000 $41.01 24 $120 8 $2,930 $2,770 $460 $6,160 

1

 See Exhibit 2-6 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 programmer 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

 Estimates rounded up to the nearest $10. 

8

 Costs assume that analyzer will be installed at an existing facility. 

Exhibit 5-38: Estimated Annual Operation and Maintenance Costs for an Online 

Chlorine Analyzer (2007$) 

System Size Labor 

Rate1 Labor Time 

(hours)2 Reagents kit Cost3,5

Maintenance Kit 

Cost4,5

Total Cost6 

(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 

> 1,000,000 $41.01 1 $42 $110 $1,110 

1

 See Exhibit 2-6 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 monthly supply. 

4

 Maintenance kit cost per vendor research. Kit includes reagent tubing, reagent caps and fittings for annual replacement. 

5

 Cost obtained from 2009 vendor catalogs and adjusted to 2007 dollars. 

6

 Estimates rounded up to the nearest $10. 
Technology and Cost Document for the 5-45 

Proposed Revised Total Coliform Rule 

5.9.1.2 Chloraminated 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 single ammonia 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 

Rate1

Labor 

Time 

(hours)2 

Programmer 

Rate3

Program.

Time 

(hours)4

Total Labor 

& Program. 

Cost2

Chloramines 

Analyzer 

Cost5

Piping 

and 

relate

d6

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 $2,170 $11,230 $460 $13,860 

101 - 500 $27.03 24 $120 8 $2,260 $11,230 $460 $13,950 

501 - 1,000 $28.96 24 $120 8 $2,360 $11,230 $460 $14,050 

1,001 -4,100 $29.73 24 $120 8 $2,390 $11,230 $460 $14,080 

4,101 - 33,000 $36.00 24 $120 8 $2,690 $11,230 $460 $14,380 

33,001 - 96,000 $36.39 24 $120 8 $2,710 $11,230 $460 $14,400 

96,001 - 500,000 $41.01 24 $120 8 $2,930 $11,230 $460 $14,620 

500,001 - 

1,000,000 $41.01 24 $120 8 $2,930 $11,230 $460 $14,620 

> 1,000,000 $41.01 24 $120 8 $2,930 $11,230 $460 $14,620 

1

 See Exhibit 2-6 in Chapter 2. Estimated Unit Costs of Labor. 

2

 Assumes a two-person crew required over a three-day period to install chloramines 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 analyzer signals into a SCADA system. 

5

 Chloramines analyzer cost per vendor. 

6

 Assume an additional $460 for sample lines. 

7

 Estimates rounded up to the nearest $10. 

8

 Costs assume that analyzer will be installed at an existing facility. 
Technology and Cost Document for the 5-46 

Proposed Revised Total Coliform Rule 

Exhibit 5-40: Estimated Annual Operation and Maintenance Costs for Online 

Ammonia and Monochloramines Analyzer (2007$) 

System Size Labor Rate1 Monthly 

Labor Time 

(hours)2

Reagents & 

Standards Kit 

Cost4,5

Maintenance 

Kit Cost3,5

Total Cost6 

(2007$) 

A B C E F G=((B*C)*12)+((E+F)*4)

< 100 $25.10 1 $123 $430 $2,520 

101 - 500 $27.03 1 $123 $430 $2,540 

501 -1,000 $28.96 1 $123 $430 $2,560 

1,001 - 4,100 $29.73 1 $123 $430 $2,570 

4,101 - 33,000 $36.00 1 $123 $430 $2,650 

33,001 - 96,000 $36.39 1 $123 $430 $2,650 

96,001 - 500,000 $41.01 1 $123 $430 $2,710 

500,001 - 1,000,000 $41.01 1 $123 $430 $2,710 

> 1,000,000 $41.01 1 $123 $430 $2,710 

1

 See Exhibit 2-6 in Chapter 2. Estimated Unit Costs of Labor. 

2

 Assumes a one-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 Standards kit cost per vendor research. Kit includes buffer, indicator and hypochlorite solutions, standards and 

cleaning solution for quarterly supply. Assuming automatic calibration by the instrument once a day 

5

 Cost obtain from 2009 vendor catalogs and adjusted to 2007 dollars. 

6

 Estimates rounded up to the nearest $10. 

5.9.2 Pressure 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 ensuring 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 single pressure 

transmitter based on labor only, given that a pressure transmitter does not require reagents or 

replacement parts. 
Technology and Cost Document for the 5-47 

Proposed Revised Total Coliform Rule 

Exhibit 5-41: Estimated Costs for Online Pressure Monitoring (2007$) 

System Size Labor 

Rate1

Labor 

Time 

(hours)2

Programmer 

Rate3

Program. 

Time 

(hours)4

Total Labor & 

Programming 

Cost2

Pressure 

Transmitter 

Cost5

Total 

Cost6,7 

(2007$) 

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

< 100 $25.10 16 $120 8 $1,770 $2,740 $4,510 

101 - 500 $27.03 16 $120 8 $1,830 $2,740 $4,570 

501 - 1,000 $28.96 16 $120 8 $1,890 $2,740 $4,630 

1,001 - 4,100 $29.73 16 $120 8 $1,920 $2,740 $4,660 

4,101 - 33,000 $36.00 16 $120 8 $2,120 $2,740 $4,860 

33,001 - 96,000 $36.39 16 $120 8 $2,130 $2,740 $4,870 

96,001 - 500,000 $41.01 16 $120 8 $2,280 $2,740 $5,020 

500,001 - 

1,000,000 $41.01 16 $120 8 $2,280 $2,740 $5,020 

> 1,000,000 $41.01 16 $120 8 $2,280 $2,740 $5,020 

1

 See Exhibit 2-6 in Chapter 2. Estimated Unit Costs of Labor

2

 Assumes a two-person crew working for a total of two days 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

 Estimates rounded up to the nearest $10. 

7

 Costs assumes that pressure transmitter will be installed at an existing facility. 

Exhibit 5-42: Estimated Annual Operation and Maintenance Costs for Online 

Pressure Transmitter (2007$) 

System Size Labor Rate1 Labor Time (hours)2 Annual Total Cost3 

(2007$) 

A B C D=B*C 

< 100 $25.10 4 $110 

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 

> 1,000,000 $41.01 4 $170 

1

 See Exhibit 2-6 in Chapter 2. Estimated Unit Costs of Labor. 

2

 Assumes a one-person crew required for approximately 4 hours of maintenance 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 could lead to water 

contamination. Measures that a water system may take to correct security breaches include 
Technology and Cost Document for the 5-48 

Proposed Revised Total Coliform Rule 

installing a fence or locking buildings to restrict access to the system. In addition, alarms and 

cameras may be used to detect security breaches. 

Water systems should 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 water system 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 substantial 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 

Cost1,2,5

Gate 

Cost3,5 Lighting Cost4,5 Security Capital Cost 

Installation 

Cost6 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 $13,100 

 101 - 500 $8,400 $795 $880 $10,075 $3,023 $13,100 

501 - 1,000 $8,400 $795 $880 $10,075 $3,023 $13,100 

1,001 - 4,100 $8,400 $795 $880 $10,075 $3,023 $13,100 

4,101 - 33,000 $11,900 $795 $880 $13,575 $4,073 $17,650 

33,001 - 96,000 $11,900 $795 $880 $13,575 $4,073 $17,650 

96,001 - 500,000 $11,900 $795 $880 $13,575 $4,073 $17,650 

500,001-1,000,000 $11,900 $795 $880 $13,575 $4,073 $17,650 

> 1,000,000 $11,900 $795 $880 $13,575 $4,073 $17,650 

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 systems 

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 opening. 

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 includes 

electrical work. 

7

 Cost rounded up to the nearest $10 

8 Assumes and includes a 22.5% Overhead and Profit cost, from R.S. Means 2009. 

5.11 Development and Implementation of an Operations Plan 

A water system should develop a distribution system operations plan to integrate all 

operations and maintenance functions to meet the goals of flow, pressure and water quality. 
Technology and Cost Document for the 5-49 

Proposed Revised Total Coliform Rule 

AWWA G200-04 standard describes the critical requirements for the effective operation and 

management of drinking water distribution systems. According to this standard, a water system 

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 

system 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 various 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 complete the activity. 

The water system 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. Additional 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 water systems 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 water system 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 

staff will be involved in this task. 

Exhibit 5-44: Estimated Costs to Develop and Implement an Operations Plan 

(2007$) 
Technology and Cost Document for the 5-50 

Proposed Revised Total Coliform Rule 

System Size Labor Rate1 Time (hours)2 Total Cost (2007$)3

A B C D=B*C 

<100 $25.10 48 $1,200 

101 - 500 $27.03 96 $2,590 

501 - 1,000 $28.96 144 $4,170 

1,001 - 4,100 $29.73 192 $5,710 

4,101 - 33,000 $36.00 384 $13,820 

33,001 - 96,000 $36.39 384 $13,970 

96,001 - 500,000 $41.01 1152 $47,240 

500,001-1,000,000 $41.01 1152 $47,240 

> 1,000,000 $41.01 1152 $47,240 

1

 See Exhibit 2-6 in Chapter 2. Estimated Unit Costs of Labor

2

 Time includes hours for both operator and managerial staff. 

3

 Cost rounded up to the nearest $10. 

5.11.1 Operation and Maintenance Standard Operating Procedure (SOP) Training 

EPA established an operator certification program with minimum professional standards 

for the operation and maintenance of water systems. The EPA program issued guidelines that 

specify standards for certification and recertification of operators. States implement the 

minimum standards of the certification program guidelines. While the specific requirements 

vary from state 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 for 

the standards operators must uphold to operate and maintain a treatment facility or system. This 

is one component necessary for the protection 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 treatment 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 at 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. 

Exhibit 5-45: Estimated Costs for Operator Training/Certification (2007$) 
Technology and Cost Document for the 5-51 

Proposed Revised Total Coliform Rule 

System Size Labor 

Rate1

Course 

Time 

(hours)2

Total Labor 

Cost Travel3 Training/ 

Certification 

Fees4

Total Cost 

(2007$)5

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

<100 $25.10 8 $210 $31 $125 $370 

101 - 500 $27.03 8 $220 $31 $125 $380 

501 - 1,000 $28.96 8 $240 $31 $125 $400 

1,001 - 4,100 $29.73 8 $240 $31 $125 $400 

4,101 - 33,000 $36.00 8 $290 $31 $125 $450 

33,001 - 96,000 $36.39 8 $300 $31 $125 $460 

96,001 - 500,000 $41.01 8 $330 $31 $125 $490 

500,001 - 1,000,000 $41.01 8 $330 $31 $125 $490 

> 1,000,000 $41.01 8 $330 $31 $125 $490 

1 See Exhibit 2-6 in Chapter 2. Estimated Unit Costs of Labor. 

2

 Assumes an eight hour training/certification course

3

 Assumes 60 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. 

Exhibit 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. 

Exhibit 5-46: Estimated Costs to Maintain an Operations Plan (2007$) 

System Size Labor Rate1 Time (hours)2 Total Cost (2007$)3

A B C E=B*C 

< 100 $25.10 10 $240 

 101 - 500 $27.03 14 $390 

501 - 1,000 $28.96 29 $830 

1,001 - 4,100 $29.73 29 $860 

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 2-6 in Chapter 2. Estimated Unit Costs of Labor

2

 Assumes both technical and managerial time 

3 Estimates rounded up to the nearest $10. 
Technology and Cost Document for the 5-52 

Proposed Revised Total Coliform Rule 

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 

management, data collection, and related activities. 

Exhibit 5-47: Estimated Annual Costs for Operation and Maintenance Plan 

Implementation (2007$) 

System Size Labor Rate1 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 $70 

33,001 - 96,000 $36.39 4 $150 

96,001 - 500,000 $41.01 4 $160 

500,001-1,000,000 $41.01 4 $160 

> 1,000,000 $41.01 4 $160 

1

 See Exhibit 2-6 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 

Proposed 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, AwwaRF, and EPA), the entries are listed 

by the year, with the most recent document listed first. The reverse chronological order makes it 

easy for the reader to look up the most recent publication first. 

American Backflow Prevention Association (ABPA). 1999 ABPA Survey of State & Public 

Water System Cross Connection Control Programs 

American Water Works Association (AWWA). 2004 Impacts of Cross-Connections in North 

American Water Supplies AWWA. January 2001. 

American Water Works Association (AWWA). 2001 Utility Compensation Survey. AWWA. 

October 2001. 

American Water Works Association, 2004. AWWA G200 – AWWA Standard for Distributions 

Systems Operation and Management. Denver, CO: AWWA 

Association of State Drinking Water Administrators (ASDWA). 2001. Drinking water program 

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, Lenore & Greenberg, Arnold & Eaton, Andrew. Standard Methods for the Examination 

of Water and Wastewater, 20th Edition. Washington, DC: American Public Health 

Association, American Waterworks Association, Water Environment Federation; 1998: 

Pages 9-47 – 9-78. 
Technology and Cost Document for the R-2 

Proposed Revised Total Coliform Rule 

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. 62nd Annual Edition. Kingston, MA 

Construction Publishers 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. 2007. Total Coliform Rule Issue Paper: Distribution 

System Inventory, Integrity, and Water Quality. 

U.S. Environmental Protection Agency. 2006 Technology and Cost Document for the Final 

Ground Water Rule. EPA 815-R-06-014 

U.S. Environmental Protection Agency. 2007. Simultaneous Compliance Guidance Manual for 

the Long Term 2 and Stage 2 DBP Rules EPA 815-R-07-017 

USEPA, Safe Drinking Water Act (SDWA). USEPA. Available: 

http://www.epa.gov/safewater/sdwa/ [17 Mar 2009]. 

USEPA. 2009. Total Coliform Rule / Distribution Systems Advisory Committee Agreement in 

Principle. 74 FR 1683. January 13, 2009. 

USEPA. 2010a. Economic Analysis for the Proposed Revised Total Coliform Rule. EPA-XXXXX-XX. June 2010. 

USEPA. 2010b. National Primary Drinking Water Regulations: Revisions to the Total Coliform 

Rule. xx FR xxx. XX X, 2010. 

USEPA. 2007a. Meeting of the Total Coliform Rule Distribution System Advisory Committee--

Notice of Public Meeting. 72 FR 35870, June 29, 2007. 

USEPA. 2007b. The Safe Drinking Water Information System – Federal Version 

(SDWIS/FED) data. Available online: http://epa.gov/enviro/html/sdwis/ [29 Apr 2009]. 

USEPA. 2006a. Economic Analysis for the Final Ground Water Rule. October, 2006. EPA-815-

R-06-014. 
Technology and Cost Document for the R-3 

Proposed Revised Total Coliform Rule 

USEPA. 2006b. Economic Analysis for the Final Long Term 2 Enhanced Surface Water 

Treatment Rule. January, 2006. EPA-815-R-06-001. 

USEPA. 2006c. Economic Analysis for the Final Stage 2 Disinfectants and Disinfection 

Byproducts Rule. January, 2006. EPA-715-R-05-010. 

USEPA. 2006d. National Primary Drinking Water Regulations: Ground Water Rule. 71 FR 

65574. November 8, 2006. 

USEPA. 2006e. National Primary Drinking Water Regulations: Long Term 2 Enhanced Surface 

Water Treatment Rule. 71 FR 654. January 5, 2006. 

USEPA. 2006f. National Primary Drinking Water Regulations: Stage 2 Disinfectants and 

Disinfection Byproducts Rule. 71 FR 388. January 4, 2006. 

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 Drinking 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 Version (SDWIS/FED) 

data (4th quarter freeze year 2003 data). 

USEPA. 2003e. Cross-Connection Control manual. February 2003. EPA-816-R-03-002. 

USEPA. 2002. 2000 Community Water System (CWS) Survey. December, 2002. EPA 815-R02-005A. 

USEPA. 1989. National Primary Drinking Water Regulations; Total Coliforms (Including Fecal 

Coliforms and E. Coli); Final Rule. 54 FR 27544. June, 29, 1989. 

U.S. General Services Administration (GSA). GSA. Available: 

http://www.gsa.gov/Portal/gsa/ep/contentView.do?programId=15580&channelId=-

24651&ooid=10359&contentId=9646&pageTypeId=17113&contentType=GSA_BASIC

&programPage=%2Fep%2Fprogram%2FgsaBasic.jsp&P=MTT [10 Feb 2009]. 
Technology and Cost Document for the A-1 

Proposed Revised Total Coliform Rule 

Appendix A 

Exhibit A-1.1: Current 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 

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% 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 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 current TCR and of what is anticipated to occur under the 

proposed revised TCR for purposes of informing the net change in labor burden associated with assessments under the proposed 

revised TCR. 
Technology and Cost Document for the A-2

Proposed Revised Total Coliform Rule 

Exhibit A-1.2: RTCR Labor Burden Estimate for Assessments done by NCWSs serv

Level 1 Assessment Level 2 Assessment (nonacute) Level 2 As

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 

EstimHouAssoElem

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

Notification Element 100% 0 0 100% 0.5 0.5 100% System Specific Element 0% 0 0 100% 0.3 0.3 100% Sample Analytical Element 0% 0 0 100% 0 0 100% Sample Methodology Element 50% 1 0.5 100% 0.5 0.5 100% Event Situational Element 100% 1 1 100% 2 2 100% Operational Data Element 60% 0.3 0.18 40% 0.5 0.2 40% Historical Trend Element 100% 0.5 0.5 100% 0.5 0.5 5% Sample Tap Element 100% 1 1 100% 1 1 100% Sample Site Element 100% 1 1 100% 1 1 100% Sample Area Element 100% 1 1 100% 1 1 20% Third Party Element 0% 0 0 0% 0 0 50% Report Element 100% 2 2 100% 2 2 100% Total 7.18 9 Note: Estimates informed by the collective experience and best professional judgment of TCRDSAC TWG members and their colleagues. The table is norequired elements of assessments and should not be interpreted as such. Rather, the table interprets both what may be occurring under the current TCR occur under the proposed revised TCR for purposes of informing the net change in labor burden associated with assessments under the proposed revise
Technology and Cost Document for the A-3 

Proposed Revised Total Coliform Rule 

Exhibit A-2.1: Current 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 

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% 1 1 100% 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 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 current TCR and of what is anticipated to occur under the 

proposed revised TCR for purposes of informing the net change in labor burden associated with assessments under the proposed 

revised TCR. 
Technology and Cost Document for the A-4

Proposed Revised Total Coliform Rule 

Exhibit A-2.2: RTCR Labor Burden Estimate for Assessments done by NCWSs servin

Level 1 Assessment Level 2 Assessment (nonacute) Level 2 As

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 

EstimHouAssoElem

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

Notification Element 100% 0 0 100% 0.5 0.5 100% System Specific Element 0% 0 0 100% 0.3 0.3 100% Sample Analytical Element 0% 0 0 100% 0 0 100% Sample Methodology Element 50% 1 0.5 100% 0.5 0.5 100% Event Situational Element 100% 1 1 100% 2 2 100% Operational Data Element 60% 0.3 0.18 40% 0.5 0.2 40% Historical Trend Element 100% 0.5 0.5 100% 0.5 0.5 5% Sample Tap Element 100% 1 1 100% 1 1 100% Sample Site Element 100% 1 1 100% 1 1 100% Sample Area Element 100% 2 2 100% 2 2 20% Third Party Element 0% 0 0 0% 0 0 50% Report Element 100% 2 2 100% 2 2 100% Total 8.18 10 Note: Estimates informed by the collective experience and best professional judgment of TCRDSAC TWG members and their colleagues. The table is norequired elements of assessments and should not be interpreted as such. Rather, the table interprets both what may be occurring under the current TCR occur under the proposed revised TCR for purposes of informing the net change in labor burden associated with assessments under the proposed revise
Technology and Cost Document for the A-5 

Proposed Revised Total Coliform Rule 

Exhibit A-3.1: Current 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 

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 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 14

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 current TCR and of what is anticipated to occur under the 

proposed revised TCR for purposes of informing the net change in labor burden associated with assessments under the proposed 

revised TCR.
Technology and Cost Document for the A-6

Proposed Revised Total Coliform Rule 

Exhibit A-3.2: RTCR Labor Burden Estimate for Assessments done by CWSs serv

Level 1 Assessment Level 2 Assessment (nonacute) Level 2 As

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 

EstimHouAssoElem

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

Notification Element 100% 2 2 100% 2 2 100% System Specific Element 100% 1 1 100% 1 1 100% Sample Analytical Element 0% 0 0 0% 0 0 0% Sample Methodology Element 100% 2 2 100% 2 2 100% Event Situational Element 100% 2 2 100% 2 2 100% Operational Data Element 60% 2 1.2 60% 2 1.2 60% Historical Trend Element 100% 2 2 100% 2 2 100% Sample Tap Element 100% 1 1 100% 1 1 100% Sample Site Element 5% 2 0.1 5% 2 0.1 100% Sample Area Element 100% 2.5 2.5 100% 2.5 2.5 100% Third Party Element 00Report Element 100% 5.5 5.5 100% 8.5 8.5 100% Total 19.3 22.3 Note: Estimates informed by the collective experience and best professional judgment of TCRDSAC TWG members and their colleagues. The table is norequired elements of assessments and should not be interpreted as such. Rather, the table interprets both what may be occurring under the current TCR occur under the proposed revised TCR for purposes of informing the net change in labor burden associated with assessments under the proposed revise
Technology and Cost Document for the A-7 

Proposed Revised Total Coliform Rule 

Exhibit A-4.1: Current 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 

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% 1.5 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 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 current TCR and of what is anticipated to occur under the 

proposed revised TCR for purposes of informing the net change in labor burden associated with assessments under the proposed 

revised TCR.
Technology and Cost Document for the A-8

Proposed Revised Total Coliform Rule 

Exhibit A-4.2: RTCR Labor Burden Estimate for Assessments done by CWSs servi

Level 1 Assessment Level 2 Assessment (nonacute) Level 2 As

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 

EstimHouAssoElem

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

Notification Element 100% 2 2 100% 2 2 100% System Specific Element 100% 1 1 100% 1 1 100% Sample Analytical Element 0% 0 0 0% 0 0 0% Sample Methodology Element 100% 2 2 100% 2 2 100% Event Situational Element 100% 2 2 100% 2 2 100% Operational Data Element 60% 2 1.2 60% 2 1.2 60% Historical Trend Element 100% 2 2 100% 2 2 100% Sample Tap Element 100% 1 1 100% 1 1 100% Sample Site Element 5% 2 0.1 5% 2 0.1 100% Sample Area Element 100% 2.5 2.5 100% 2.5 2.5 100% Third Party Element 00Report Element 100% 5.5 5.5 100% 8.5 8.5 100% Total 19.3 22.3 Note: Estimates informed by the collective experience and best professional judgment of TCRDSAC TWG members and their colleagues. The table is norequired elements of assessments and should not be interpreted as such. Rather, the table interprets both what may be occurring under the current TCR occur under the proposed revised TCR for purposes of informing the net change in labor burden associated with assessments under the proposed revise
Technology and Cost Document for the A-9 

Proposed Revised Total Coliform Rule 

Exhibit A-5.1: Current TCR (as implemented) Labor Burden Estimate for 

Assessments done by CWSs serving 501 - 1,000 

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 

Burden 

Associated 

with 

Element 

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

Notification 

Element 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

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% 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. 

Rather, the table interprets both what may be occurring under the current TCR and of what is anticipated to occur under the 

proposed revised TCR for purposes of informing the net change in labor burden associated with assessments under the proposed 

revised TCR.
Technology and Cost Document for the A-10 

Proposed Revised Total Coliform Rule 

Exhibit A-5.2: RTCR Labor Burden Estimate for Assessments done by CWSs servin

Level 1 Assessment Level 2 Assessment (nonacute) Level 2 As

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 

EstimHouAssoElem

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

Notification Element 100% 2.5 2.5 100% 2.5 2.5 100% System Specific Element 100% 1 1 100% 1 1 100% Sample Analytical Element 0% 0 0 0% 0 0 0% Sample Methodology Element 100% 2 2 100% 2 2 100% Event Situational Element 100% 2 2 100% 2.5 2.5 100% Operational Data Element 60% 2 1.2 60% 2 1.2 60% Historical Trend Element 100% 2 2 100% 2 2 100% Sample Tap Element 100% 1 1 100% 1 1 100% Sample Site Element 5% 2 0.1 5% 2 0.1 100% Sample Area Element 100% 2.5 2.5 100% 2.5 2.5 100% Third Party Element 00Report Element 100% 5.5 5.5 100% 8.5 8.5 100% Total 19.8 23.3 Note: Estimates informed by the collective experience and best professional judgment of TCRDSAC TWG members and their colleagues. The table is norequired elements of assessments and should not be interpreted as such. Rather, the table interprets both what may be occurring under the current TCR occur under the proposed revised TCR for purposes of informing the net change in labor burden associated with assessments under the proposed revise
Technology and Cost Document for the A-11 

Proposed Revised Total Coliform Rule 

Exhibit A-6.1: Current TCR (as implemented) Labor Burden Estimate for 

Assessments done by CWSs serving 1,001 - 4,100 

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 

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 current TCR and of what is anticipated to occur under the 

proposed revised TCR for purposes of informing the net change in labor burden associated with assessments under the proposed 

revised TCR.
Technology and Cost Document for the A-12 

Proposed Revised Total Coliform Rule 

Exhibit A-6.2: RTCR Labor Burden Estimate for Assessments done by CWSs serving 

Level 1 Assessment Level 2 Assessment (nonacute) Level 2 As

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 

EstimHouAssoElem

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

Notification Element 100% 2.5 2.5 100% 3 3 100% System Specific Element 100% 1 1 100% 2.5 2.5 100% Sample Analytical Element 0% 0 0 0% 0 0 0% Sample Methodology Element 100% 2 2 100% 2 2 100% Event Situational Element 100% 5.5 5.5 100% 2.5 2.5 100% Operational Data Element 60% 4 2.4 60% 4 2.4 60% Historical Trend Element 100% 3 3 100% 3 3 100% Sample Tap Element 100% 2 2 100% 2 2 100% Sample Site Element 5% 2 0.1 5% 2 0.1 100% Sample Area Element 100% 5 5 100% 7.5 7.5 100% Third Party Element 00Report Element 100% 7.5 7.5 100% 20.5 20.5 100% Total 31 45.5 Note: Estimates informed by the collective experience and best professional judgment of TCRDSAC TWG members and their colleagues. The table is norequired elements of assessments and should not be interpreted as such. Rather, the table interprets both what may be occurring under the current TCR occur under the proposed revised TCR for purposes of informing the net change in labor burden associated with assessments under the proposed revise
Technology and Cost Document for the A-13 

Proposed Revised Total Coliform Rule 

Exhibit A-7.1: Current TCR (as implemented) Labor Burden Estimate for 

Assessments 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 

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% 1.5 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 

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 29.75 36.05

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. 

Rather, the table interprets both what may be occurring under the current TCR and of what is anticipated to occur under the 

proposed revised TCR for purposes of informing the net change in labor burden associated with assessments under the proposed 

revised TCR.
Technology and Cost Document for the A-14 

Proposed Revised Total Coliform Rule 

Exhibit A-7.2: RTCR Labor Burden Estimate for Assessments done by CWSs serving 

Level 1 Assessment Level 2 Assessment (nonacute) Level 2 As

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 

EstimHouAssoElem

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

Notification Element 100% 3 3 100% 3 3 100% System Specific Element 100% 1.5 1.5 100% 1.5 1.5 100% Sample Analytical Element 0% 0 0 0% 0 0 0% Sample Methodology Element 100% 3 3 100% 3 3 100% Event Situational Element 100% 5.5 5.5 100% 7 7 100% Operational Data Element 75% 4 3 75% 4 3 75% Historical Trend Element 100% 9 9 100% 9 9 100% Sample Tap Element 100% 2 2 100% 2 2 100% Sample Site Element 5% 2 0.1 5% 2 0.1 100% Sample Area Element 100% 5.5 5.5 100% 7 7 100% Third Party Element 0 10% 109 10.9 10% Report Element 100% 8.5 8.5 100% 22 22 100% Total 41.1 68.5 Note: Estimates informed by the collective experience and best professional judgment of TCRDSAC TWG members and their colleagues. The table is norequired elements of assessments and should not be interpreted as such. Rather, the table interprets both what may be occurring under the current TCR occur under the proposed revised TCR for purposes of informing the net change in labor burden associated with assessments under the proposed revise
Technology and Cost Document for the A-15 

Proposed Revised Total Coliform Rule 

Exhibit A-8.1: Current 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 

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% 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 

Element 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 be occurring under the current TCR and of what is anticipated to occur under the 

proposed revised TCR for purposes of informing the net change in labor burden associated with assessments under the proposed 

revised TCR.
Technology and Cost Document for the A-16 

Proposed Revised Total Coliform Rule 

Exhibit A-8.2: RTCR Labor Burden Estimate for Assessments done by CWSs serving 

Level 1 Assessment Level 2 Assessment (nonacute) Level 2 As

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 

EstimHouAssoElem

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

Notification Element 100% 6 6 100% 6 6 100% System Specific Element 100% 1.5 1.5 100% 3.5 3.5 100% Sample Analytical Element 50% 4 2 50% 4 2 50% Sample Methodology Element 100% 4 4 100% 4 4 100% Event Situational Element 100% 10 10 100% 10 10 100% Operational Data Element 75% 14 10.5 75% 14 10.5 75% Historical Trend Element 100% 11 11 100% 11 11 100% Sample Tap Element 100% 3.5 3.5 100% 5 5 100% Sample Site Element 10% 4 0.4 10% 5 0.5 10% Sample Area Element 100% 7 7 100% 21 21 100% Third Party Element 0% 0 0 10% 146 14.6 10% Report Element 100% 12.5 12.5 100% 28 28 100% Total 68.4 116.1 Note: Estimates informed by the collective experience and best professional judgment of TCRDSAC TWG members and their colleagues. The table is norequired elements of assessments and should not be interpreted as such. Rather, the table interprets both what may be occurring under the current TCR occur under the proposed revised TCR for purposes of informing the net change in labor burden associated with assessments under the proposed revise
Technology and Cost Document for the A-17 

Proposed Revised Total Coliform Rule 

Exhibit A-9.1: Current 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 

Burden 

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 

Situational 

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 

Element 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 current TCR and of what is anticipated to occur under the 

proposed revised TCR for purposes of informing the net change in labor burden associated with assessments under the proposed 

revised TCR.
Technology and Cost Document for the A-18 

Proposed Revised Total Coliform Rule 

Exhibit A-9.2: RTCR Labor Burden Estimate for Assessments done by CWSs serv

Level 1 Assessment Level 2 Assessment (nonacute) Level 2 As

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 

EstimHouAssoElem

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

Notification Element 100% 8 8 100% 8 8 100% System Specific Element 100% 1.5 1.5 100% 4 4 100% Sample Analytical Element 90% 6 5.4 90% 6 5.4 90% Sample Methodology Element 100% 5 5 100% 5 5 100% Event Situational Element 100% 20 20 100% 20.5 20.5 100% Operational Data Element 100% 14.5 14.5 75% 14.5 10.875 100% Historical Trend Element 100% 23.5 23.5 100% 23.5 23.5 100% Sample Tap Element 100% 9.5 9.5 100% 18.5 18.5 100% Sample Site Element 10% 10 1 10% 23.5 2.35 10% Sample Area Element 100% 47.5 47.5 100% 78 78 100% Third Party Element 0% 0 0 10% 181 18.1 10% Report Element 100% 23 23 100% 44 44 100% Total 158.9 238.225 Note: Estimates informed by the collective experience and best professional judgment of TCRDSAC TWG members and their colleagues. The table is norequired elements of assessments and should not be interpreted as such. Rather, the table interprets both what may be occurring under the current TCR occur under the proposed revised TCR for purposes of informing the net change in labor burden associated with assessments under the proposed revise