# 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/safewaterTechnology and Cost Document for the ii Proposed Revised Total Coliform Rule 

### Disclaimer

Readers may use the information presente d in this document to evaluate th e 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/Abbr eviations __________________________________________________ viii

1 Introduction _____________________________________________________________ 1

‐ 1

1.1 Purp ose of the Document _____________________________________________________ 1

‐ 1

1.2 Background of RTCR

__________________________________________________________ 1

‐ 1

1.3 Docum ent Organization_______________________________________________________ 1

‐ 2



### 2 Estimated Unit Costs of Labor _______________________________________________ 2

‐ 1

2.1 Water System La bor Rates ____________________________________________________ 2

‐ 1

2.2 St ate Drinking Water Program Personnel Labor Rates ______________________________ 2

‐ 3

2.3 Escala ted Labor Rates ________________________________________________________ 2

‐ 4

2.4 Lab or Rates for RTCR Alternative Size Categories __________________________________ 2

‐ 5



### 3 Estimated Unit Costs of TCR Monitoring Requirements ___________________________ 3

‐ 1

3.1 Intr oduction ________________________________________________________________ 3

‐ 1

3.2 Sample C ollection 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 Anal ysis _____________________________________________________________ 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 Estim ated Average Unit Monitoring Costs ________________________________________ 3

‐ 9



### 4 Estimated Unit Costs of Assessm ents _________________________________________ 4

‐ 1

4.1 Overview of Assessme nts _____________________________________________________ 4

‐ 1

4.1.1 Level 1 Assessments _______________________________________________________________ 4

‐ 2
4.1.2 Level 2 Assessments _______________________________________________________________ 4

‐ 2



### 4.2 Eleme nts 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 Uni t Cost Estimates of Assessments _____________________________________________ 4

‐ 8

4.3.1 Methodology _____________________________________________________________________ 4

‐ 8Technology 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 Trai ning ____________________________________________________________ 5

‐ 8

5.3 Replacement / Repair of Dist ribution 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 Ade quate 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 Appr opriate 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 St orage 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 Boos ter 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

‐ connec tion 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 Additi on 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

‐ 46Technology and Cost Document for the v Proposed Revised Total Coliform Rule 

### 5.10 Addition of Security Measures ________________________________________________ 5

‐ 47

5.11 Develo pment 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

‐ 1Technology 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

‐ Delivery 1 (2007$) ___________________________________________ 3

‐ 4 Exhibit 3

‐ 6: Per Sample Cost Estimate for Sample Self

‐ Delivery (2007$) ___________________________________ 3

‐ 4 Exhibit 3

‐ 7: Estimated Percentages 1 of Systems Using Each Type of Sample Delivery ________________________ 3

‐ 5 Exhibit 3

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

‐ 6 Exhibit 3

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

‐ 8 Exhibit 3

‐ 10: Estimated Sample Cost for In

‐ House Analysis (2007$)_______________________________________ 3

‐ 9 Exhibit 3

‐ 11: Percentage of Systems Using In

‐ House vs. Contracted Laboratories___________________________ 3

‐ 10 Exhibit 3

‐ 12: Estimated Average Unit Cost of Monitoring (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

‐ 29Technology 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

‐ 18Technology 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 Asso ciation 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 matterTechnology 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 VirginiaTechnology 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 se veral technical documents de veloped in support of the proposed Revised Total Coliform Ru le (RTCR). It describes avai lable technologies, operational practices, and compliance activities that may be performed by public water systems (PWSs) in compliance with the proposed rule. The documen t also provides estimated unit costs associated with these technologies, operationa l practices, and compliance acti vities and descriptions of approaches used in developing the estimates.



## 1.2 Background of RTCR

The U.S. Environmental Protection Agency (EPA ) is required to revi ew existing national primary drinking water regulations every six years. In 2003, EPA completed its review of the Total Coliform Rule (TCR) and 68 National Prim ary Drinking Water Re gulations (NPDWRs) for chemicals that were established prior to 1997. The purpose of the re view was to identify current health risk assessments, changes in t echnology, and other factors that would provide a health or technological basis to support a regulatory revision th at would maintain or improve public health protection. In the Six-Year Re view determination published in July 2003, EPA noticed its intent to revise the TCR.

In June 2007, EPA established a federal a dvisory committee, the Total Coliform Rule Distribution System Advisory Committee (TCRD SAC), under the Federal Advisory Committee Act (FACA). One of the goals of convening th e TCRDSAC was to make recommendations to EPA on revisions to the TCR promulgate d in 1989 (54 FR 27565, June 29, 1989).

The TCRDSAC included organizational member s selected by EPA based on the diverse perspectives, expertise, and e xperience needed to provide bala nced 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 distribut ion systems to better understand and address public health impacts from degradation of drinking wa ter quality due to sani tary defects in the distribution system. This RTCR ap plies to all PWSs nationwide.

The goal of the TCRDSAC in making recomm endations on revisions to the TCR is to achieve the objectives of the 1989 TCR more effec tively and efficiently, ta king into account the changes in the regulatory framework for impl ementing 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 th e 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 sma ller groundwater systems. The RTCR paradigm is designed to trigger systems with positive total coliform (TC)/ E. coli monitoring results to do anTechnology and Cost Document for the 1-2 Proposed Revised Total Coliform Rule 

### assessment, to identify whether any sanitary defe cts are present, and to correct such defects accordingly. This is an improvement over the cu rrent TCR framework in that it takes a more proactive approach to id entifying and fixing problems that a ffect 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 ch apters, 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 re quirements under the RTCR based upon system characterization. This chapte r is not intended to provide guidance for PWS compliance with the RTCR but rather to provide backgr ound 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 elemen ts that public water systems might include in their assessments. Specific assessment s required under the RTCR are determined by the primacy agency.

Chapter 5 – Estimated Unit Costs of Corrective Actions

This chapter provides examples of correctiv e 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 labo r burden estimates for performing various assessments. Tables are broken out by system type, that is, community vs. noncommunity and by the populat ion 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 propos ed RTCR is due to the labor that would be required to comply with the provisions of the rule including collecti ng routine and repeat samples, conducting assessments, taking follo w-up action, and/or implementing corrective action. The following labor classes are used to estimate the costs associ ated 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 es timates of the labor time (burden) that PWS staff will expend in implementing these manage ment and operational improvements. This chapter presents the estimated unit cost of this la bor burden in terms of a loaded wage rate that incorporates both what systems and States pay thei r 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 un it of time expended in performing compliance activities. This section presents estimated labor rates for the labor cate gories identified above.

National Analysis of Labor Rates . EPA performed an analysis of available data sources to derive a nationally represen tative set of labor rates co rresponding to the primary labor categories involved in SDWA compliance act ivities. 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 includi ng that of the Ground Water Rule (USEPA, 2006a). These documents serve as the basis for th e summary of the nationa l labor rates below. The national labor rates were used by the TCRD SAC in support of the Agreement in Principle (AIP) signed for the proposed RTCR and conse quently 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, Occ upational Employment Survey (OES)

• Bureau of Labor Statistics, Na tional Compensation Survey (NCS)

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

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

These national databases were supplemente d with information provided in two EPA Drinking Water Program database s: the Safe Drinking Water Information System (USEPA 2008) and the 2000 Community Water Sy stem Survey (USEPA 2002).

The OES tracked compensation by Standard Indu strial Classification (SIC). Wage data from two industry classes were particularly re levant to this analys is: SIC 494 – Water Supply, which contained privately-owned drinking wate r systems, and SIC 903 – Local Government,Technology and Cost Document for the 2-2 Proposed Revised Total Coliform Rule 

### which contained publicly-owned systems (U SEPA, 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 pr ivate 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 em ployees (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 occupationa l categories provided data for managerial, clerical, and ad ministrative labor rates.

The 1997 Economic Census provided total pa yroll figures, but di d 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 hour s 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 AW WA-based wage rates were determined to be less accurate for smaller sized water systems.

EPA considered several factors in evaluati ng whether these data sources provided an accurate estimate of labor rates. Given the anal ytical needs of EPA’s national regulatory cost models and data quality considerations, EPA sel ected the OES-based labor rates as nationally representative for use in nationa l economic impact analyses.

Fringe Benefit Rates . In developing the unit labor costs, EPA also considered the additional indirect labor costs as sociated with fringe benefits pa id to water system employees. The NCS reported fringe benefits on a per hour basis for select occ upational categories. However, there was not a specific fringe be nefit rate corresponding to water industry occupations. EPA identified fringe benefit rate s 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 categorie s 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 Rate 1 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 Rate 2 $ 21.44 $ 23.09 $ 24.74 $ 30.51 $ 31.08 $ 35.25

1 Figures represent loaded rates that include a fringe benefit mu ltiplier 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 Fi nal 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 app lied to each of the economic analyses supporting the Ground Water Rule (USEPA 2006a), the Stage 2 Disi nfectants and Disinfection Byproducts Rule (USEPA 2006c), and the Long Term 2 Enhan ced Surface Water Treatment Rule (USEPA 2006b), respectively. Systems se rving 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 peopl e. Exhibit 2-1 also presents these weighted labor rates.



## 2.2 State Drinking Water Prog ram Personnel Labor Rates

The unit labor cost for State staff performi ng administrative tasks were estimated based on data from the 2001 State Drinking Water N eeds Analysis (ASDWA, 2001). EPA estimated an average annual full time equivalent (FTE) labo r 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 $31.00 for a field engi neer. A 60 percent loading factor was also assumed to account for the cost of fringe benefits. When escalated to 2003$, the loaded wage rate for State field engineering staff was $37.34 pe r hour. Exhibit 2-2 presents the State Program personnel loaded la bor rates in 2003$.Technology and Cost Document for the 2-4 Proposed Revised Total Coliform Rule 

### Exhibit 2-2: State Prog ram Wage Rates (2003$)

State Labor Category Labor Cost Field Engineer $37.34 Administrative $33.60

Source: Economic analyses for the Final Ground Wa ter 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, up dated 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 ensu re 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 2 007$ 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 la bor 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 4 th 

### Quarter 2003 (90.2) and 4 th 

### Quarter 2007 (105.2) as follows: 105.2 ÷ 90.2 = 1.17. The escalation rate was applied to the 2003 labor rate s to derive the corre sponding 2007 labor rate values. Exhibit 2-3 presents the escalated labor rate s 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 Wa ter 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 a nd 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 com puted using the price index for 4 th 

### Quarter 2003 (92.7) and 4 th 

### Quarter 2007 (108.2) as follows: 108.2 ÷ 92.7 = 1.17. The escalation rate was applie d to the 2003 labor rates to de rive the corresponding 2007 labor rate values. Exhibit 2-4 presents the escalat ed 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 Wa ter Rule (USEPA, 2006a), the Stage 2 Disinfectants and Disinfection Byproducts Rule (US EPA 2006c), and the Long Term 2 Enhanced Surface Water Treatment Rule (USEPA 2006b), respectively.



## 2.4 Labor Rates for RTCR Alte rnat ive 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 peopl e). Exhibit 2-5 presents the number of systems in each system size category for both th e 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 we ighted labor rates presented in Exhibit 2-3 and reclassified into the system sizes presented be low 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 $39.22Technology and Cost Document for the 2-6 Proposed Revised Total Coliform Rule 

### Exhibit 2-6: Water System Labor Ra tes 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 nu mbers of systems in each size category outlined in Exhibit 2-5 above. System Size (Population Served) Loaded 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 $41.01Technology and Cost Document for the 3-1 Proposed Revised Total Coliform Rule 

## 3 Estimated Unit Costs of TCR Monitoring Requirements

3.1 Introduction

The curren t 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, da ta, and assumptions used in developing estimates of the unit costs of compliance m onitoring 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 committ ee 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 appr oach 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 part icular 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 attr ibute these costs directly to the TCR or proposed RTCR. Thus, the unit costs pres ented 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 di rect input for system-specific design or budget preparation for non-EPA entities.

The following sections of this chapter presen t unit cost estimates for each component of monitoring costs under the proposed RTCR. A conc luding 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

Sa mple collection and delivery unit costs are determined by the labor burden, or estimated staff time, to collect samples and th e 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 collect ed to the time the sample analysis begins. Delivery to a contracted laborator y, therefore, requires rapid res ponse on the part of system staff or lab courier service. The TCRDSAC TWG disc ussed 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 pr ofessional 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

Sam ple collection unit costs include all activit ies 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 th e sample is representati ve 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 simplifyi ng assumption was made that systems collect their own samples (as opposed to co ntracting sample collection).

3.2.1.1 Sample Collection Labor Burden

The TCRDSAC TWG es timated the time (in hour s) to collect a singl e sample based upon approved collection procedures and practices, including: gaining access to the sampling site, disinfection of the sampling tap, sample collectio n, 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 professi onal judgment and by estimating th e 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 samp le collection time for the entire month of 75 hours which would be equivalent to a per-sampl e 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 syst ems 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 Samp le Time by PWS Population Served

Population Served Time (hours) required per sample 1

≤ 500 0.5 501 – 96,000 0.75 >96,000 1.0

1 Developed by TCRDSAC TW G based on experience and best profe ssional judgment of TWG members.



### 3.2.1.2 Unit Sample Collection Costs

Exhibit 3-2 presents the unit cost per sam ple 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 PW S size category. The labor rates presented in Exhibit 3-2 represent technical wa ge 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 de scription of how these labor rates were derived.Technology and Cost Document for the 3-3 Proposed Revised Total Coliform Rule 

### Exhibit 3-2: Estimated Samp ling Collection Cost (2007$)

System Size Labor Rate 1 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

com pliance monitoring samples to approved laborato ries 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 deli very 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 ba sed on the delivery rates for de livering 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 dimens ions 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 p ackage weight). Exhibit 3-3 presents the estimated unit cost for sample delivery.

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

Type of Delivery 1 sample 2 samples 3 samples 4 samples 5 samples Lab Courier Service $3. 50 $3.50 $3.50 $3.50 $3.50 Ground Next Day 1 $6.65 $6.77 $6.88 $7.00 $7.12 Standard Next Day 1 $38.48 $38.48 $38.48 $38.48 $38.48 Priority Overnight 1 $45.12 $45.12 $45.12 $45.12 $45.12

1 Source of 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 th eir 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 co sts of shipping or delive ring 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 se lf-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 differe nt systems when self-delivering samples by personally owned vehicles to labs. Based on be st professional judgment and discussions with industry, EPA estimates that when a system em ployee 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-Delivery 1 

### (2007$)

System Size Labor Rate Drive Time (hours) 1 Total Labor Cost Personal Vehicle Use Reimbursement 2 Total Delivery Cost A B C D=B*C E F=D+E

≤ 100 $25.10 0.5 $12.55 $15.15 $27.70 101-500 $27.03 0.5 $13.52 $15.15 $28.67 501-1,000 $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 Admini stration (GSA) rate at that time of $0.505 per mile.



### Consistent with the use of a courier or parcel delivery se rvice, 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 Estima te 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 samp les 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 ba sed on its best professi onal 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 laborator y. The same delivery process was used for all system sizes that deliver or ship samples.

Exhibit 3-7: Estimated Percentages 1 

### of Systems Using Each Type of Sample Delivery

Delivery Type Percentage of Systems Lab Courier Service Pick-up 20% Ground Next Day 50% Standard Next Day 12.5% Priority Overnight 12.5% Self-Delivery by Car 5%

1 Based on best professional judgment of TCRDSAC TWG



### Exhibit 3-8 shows the weighted average unit deli very costs by PWS size category. As an example calculation to demonstrate how the precedi ng exhibits come together to form the values in Exhibit 3-8, consider the aver age 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 m ethods, except for self-delivery by vehicle, were obtained from the first column of Exhibit 3-4. The first column is us ed 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 incurre d 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 shippe d 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 m ethods for simu ltaneous 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 estimatin g the average unit cost of sample analysis. The unit costs of sample analysis are presented in tw o ways: (1) the cost for those systems that send out the sample for analysis to a certified contr act 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 opera tions and maintenance (O&M) costs. O&M costs are those expenses associated with ope rating a laboratory and performing an approved analytical method in-house. They include the la boratory facility, equipment and maintenance, supplies such as reagents, glassware and sample c ontainers, as well as lab certification fees. In the final section of this chapter, a weighted aver age 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 m ethods exist that provide for simultaneous detection of TC and E. coli in single samples. Simultaneous detecti on 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 commercial ly 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 indicator s to produce a chromogenic or fl uorogenic 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 se lectivity. 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 aTechnology and Cost Document for the 3-7 Proposed Revised Total Coliform Rule 

### fluorescent blue periphery. The colony formi ng units counted on each membrane are added together for a reportable resu lt 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 sam ple analysis is one of th e key components of th e 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 cont ractor labs versus inhouse labs.

3.3.2.1 Contract Laboratories

Any laboratory that perf orms analyses for a PWS that is not performing sample analysis for itself under the current TCR is considered to be a contract laborator y. Typically contract laboratories are commercial laboratories holding cer tification in one or mo re States to perform sample analysis by approved methods under the curre nt TCR. Some larger PWSs also perform contract sample analysis typically for smaller sy stems. Some States also provide analytical support services to PWSs.

Contract laboratories normally bid on annua l contracts to perform compliance sample analysis for PWSs. Purchasing requirements typically include state or primacy agency certification and sample analysis unit cost for eac h contracted method. Samp le analysis fees may also include sample pick-up. C ontractor laboratory f ees 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 professi onal judgment and experien ce 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 estima ted 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 E xhibit 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 assump tion, 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 perfo rming the analysis to also perform the repo rting 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 labor atories across the United States.



### 3.3.2.2 In-house Analysis

Water system s serving a population greater th an 33,000 persons typically perform sample analysis in-house. Larger systems are more likel y to have the staff, equipment, and facilities required to hold certifications and perform anal ysis 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 in clude equipment and maintenance such as incubators, UV lights, glassware, miscellaneous lab equipment and supplies, as well as perishables including reagents, sampli ng containers, etc. Certificati on fees must also be included in O&M costs. Certification fees can be hi ghly variable and may range from a few hundred dollars to several thousand dolla rs a year. Some States, Indi ana for example, do not have laboratory certification fees. Certification fees are typically based upon specific methods performed or by analyte groups such as inorga nics, organics, or micr obiology. Certification requirements are also specific with regard to facilities, equipmen t, and staff. Laboratory work stations must be properly maintained with adequate facilities, be of an adequate size, and possess safety equipment including safety showers, eyewas h stations, and hoods. All of these items must be included in O&M costs.

For purposes of this document, EPA is a pplying 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, la bor 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. Th e site-specific technical labor rate was also considered as a key component to the estimati on 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 Co st 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 m ethodology, da ta, and assumptions used in developing estimates of the unit costs of compliance m onitoring 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 estima tes is the same that was used by TCRDSAC TWG during the federal advisory committ ee process in order to approxima te 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 m onitoring 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 vers us 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 th e approved analytical methods. Small systems typically contract a certified laboratory to pe rform the sample analysis. The assumptions presented in Exhibit 3-11 demonstrate that sy stems 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 person s, 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 Us ing 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 TW G based on the experience of the gr oup and best professional judgment.


### An example calculation is presented below to demonstrate the source of the data presented in Exhibit 3-12. Consider a syst em serving 33,001-96,000 persons that takes five samples simultaneously. As presented in Exhi bit 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 (l abor + 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-houseTechnology 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 co nducting some level of assessments themselves or receiving some level of assessments from States following Maximum Contaminant Level (MCL) violations. This chapter estimates the le vel 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 drinki ng water systems. The cost estimates presented in this chapter were informed by input from St ates and industry receive d during the proceedings of the TCRDSAC. They are described in more deta il 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 system s 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 contamina tion into the distribution system or that [are] indicative of a failure or imminent failure in a ba rrier that is already in place”) and defects in distribution system coliform m onitoring practices. EPA belie ves that assessments will strengthen the drinking water system’s capacity to ensure that barrie rs to intrusion or contamination are in place and effective. The proposed assessment triggers represent a significant improvement over the current TCR paradi gm 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 a pproach 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 bot h Level 1 and 2 assessments should include a review and identification of the following:

1. Inadequacies in sample sites, samp ling protocol, and sample processingTechnology 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 a nd operation that may have affected or are affecting distributed water qua lity including water storage

4. An evaluation of source water quality and tr eatment changes or conditions that may affect distributed water quality, where a ppropriate (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 committe d to undertaking a Level 1 or 2 assessments. Assessments conducted under the proposed RTCR s hould reflect the substance and effect of the elements of these example Level 1 and 2 assess ment 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 assessm ent 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 revi ewed 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 repe at 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 ac tions not already completed. The assessment report may also note that no sanitary defects we re identified. Upon co mpletion and submission of the assessment report by the PW S, 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 assessm ent is a more detailed examination of the system, its monitoring program and results, and its operational practices . It is comprised e ssentially of the same elements as a Level 1 assessment, but each element is investigated in greater detail. The level ofTechnology 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 leve l review of available information, and may involve the engagement of additi onal parties and expertise.

A Level 2 assessment is triggered if sa mpling 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 tec hnique 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 to tal 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 ex tensive certificati on requirements, or

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

As with the Level 1 assessment report, the Level 2 assessment report identifies sanitary defects detected, corrective acti ons completed, and a timetable for any corrective actions not already completed. The assessment report may also note that no sanitary def ects were identified. Upon completion and submission of the assessment report by th e 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 cons ult with the PWS and, if necessary, provide assistance or require appropriate action.

4.2 Elements of Assessments

The TCRDSAC TWG di scussed the various el ements that assessments would likely encompass including those that are currently im plemented by some systems and States under the existing TCR. This list of elements was based on the collective experien ce and best professional judgment of TCRDSAC TWG memb ers and their colleagues. Exhibit 4-1 below and the sections that follow were informed by the disc ussions of the TCRDSAC TWG. The list is notTechnology and Cost Document for the 4-4 Proposed Revised Total Coliform Rule 

### intended to represent required elements of an as sessment 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 am ong systems and States, EPA anticipates that primacy agencies will tailor specific assessment el ements to the size and type of a PWS and that the PWSs will adapt their assessment activities ba sed 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 author ity. 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 Assu rance/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 per sonnel to review and evaluate any significant system events that may have infl uenced the sample(s) (main breaks, main repair, pressure events, tr eatment problems, source water changes, weather events, etc.). Operational Data Element Includes time for perso nnel 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 perso nnel 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 ti me to inspect and evaluate the fa cility 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 cont racting 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 elemen ts 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 equiva lent or contain significant overla p, 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 concep tual examples for performing assessments.

4.2.1 Notification Element

The Notification Elem ent involves notificati on of monitoring results to the state authority. Cost estimates are based on the time fo r sample data review, notification of superiors, state authority contact, and external advisor cont act for guidance. Sample data review includes preparing information relevant to recent monito ring and the violation for dialog with the State, and a review of state code and guidance for th e situation. Notification of superiors assumes contact within the chain of co mmand extending to a local govern ment 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 thresh old 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 employ ee to assess the implication or significance of the violation.

Normally, notification is limited to monthly filing of RTCR routin e 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 pe rsonnel 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 av ailable 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 re porting 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 typica lly have more complex community water system (CWS) identification assignments, retail and wholes ale relationships, etc., which will need to be reviewed to properly associate positiv e sample sites to CWS identifiers.

4.2.3 Sample Analytical Element

The m ain purpose of the Sample Analyti cal 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 sy stems 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 Sam ple Methodology Element includes the time to evaluate whether proper sampling techniques were used and whether proper samp le handling procedures were followed. Any deviations are identified, documented, and corr ected. Cost estimates for systems serving 1,000 customers or fewer are based on time spent cont acting 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 betwee n a technician and a manager to evaluate whether proper sampling techniques were used, ti me for a review of proper procedures, and will likely involve time for a discussion with external advi sors, 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, su ch 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 Situa tional 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. Co st 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 constructi on crews. Time required will increase with increasing size and complexity of the system (multiple sources, larger distribution systems, etc.). For systems serving 4,100 custom ers 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 Elem ent involves collect ing other data that may have influenced the sample, such as chlorine residual, other wate r 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 loca tion of sampling. Time estimates consider that the review is taking place at the end of the mont h 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 Elem ent includes time for personnel to review the history of samples in the system, and a review of the histor y 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 tre nd analysis, such as s ources in production, tank release patterns, and wate r quality parameters.

4.2.8 Sample Tap Element

The Sam ple Tap Element involves an inspec tion 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 Sam ple Site Element includes the time for an inspection and evaluation of the facility in which the sample was collected. For most utilit ies, 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 Sam ple 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 elem ent includes time for contracting with a third party consultant: identification of contractor options, drafting a scope, procuremen t review, management review, governing board approval, proposal distribution, pr oposal review, management re view of proposals, drafting a contract, financial and legal re view, dialog with State, and g overning 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 perf orm ed 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 estim ates presented in this chapte r 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 provide d for each system type, either a CWS or noncommunity water system (NCWS), on the size cate gories presented in Exhibit 4-2 and for the triggers listed in Exhibit 4-3. For each of the elements presente d 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 numbe r of hours that are curr ently spent on that element (under the existing TCR, as implemented) or the number of hours th at are anticipated to be spent on that element (under the RTCR). The pr oduct of (1) and (2) is taken for each element and these products are summed to calculate th e estimated average labor burden incurred by a given system type/size for a given type of assess ment. This approach re cognizes 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 im plemented, and what is anticipated to happen under the proposed RTCR.

Exhibit 4-2: Categories for whic h 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 tr iggers 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 asse ssment and how the percentages of systems implementing those elements and the labor hours a ssociated with those elements vary depending on the type of MCL violation. Th e exhibit indicates that, on aver age, 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 hour s 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 captu re the average for the purposes of developing national cost estimates for the comparison of rule options.

Exhibit 4-4: Current TCR (as implem ented) 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 0Technology 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 per centages of systems impl ementing 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 sy stem 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) asse ssment 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 an d States, EPA believes that the system burden associated with conducting a Le vel 2 assessment will likely vary depending on whether there is E. coli present.Technology and Cost Document for the4-11Proposed Revised Total Coliform RuleExhibit 4-5: RTCR Labor Burden Estimate for Assessments done by NCWSs serving≤1,000Level 1 AssessmentLevel 2 Assessment (nonacute)Level 2 Assessment (acute)Percentage ofSystems doingElementEstimatedHoursAssociatedwith ElementAverageBurdenAssociated withElement (hrs)Percentage ofSystems doingElementEstimatedHoursAssociatedwith ElementAverageBurdenAssociated withElement (hrs)Percentage ofSystems doingElementEstimatedHoursAssociatedwith ElementAverageBurdenAssociated withElement (hrs)GHI = G * HJKL = J * KMNO = M * NNotificationElement100% 0 0 100% 0.5 0.5 100% 2 2SystemSpecificElement 0% 0 0 100% 0.3 0.3 100% 1 1SampleAnalyticalElement0% 0 0 100% 0 0 100% 1 1SampleMethodologyElement50% 1 0.5 100% 0.5 0.5 100% 1 1EventSituationalElement 100% 1 1 100% 2 2 100% 2 2OperationalData Element60% 0.3 0.18 40% 0.5 0.2 40% 1 0.4HistoricalTrend Element100% 0.5 0.5 100% 0.5 0.5 5% 4 0.2Sample TapElement 100% 1 1 100% 1 1 100% 1 1Sample SiteElement 100% 1 1 100% 1 1 100% 1 1Sample AreaElement 100% 1 1 100% 1 1 20% 7 1.4Third PartyElement 0% 0 0 0% 0 0 50% 16 8ReportElement100% 2 2 100% 2 2 100% 2 2Total7.18921Technology and Cost Document for the 4-12 Proposed Revised Total Coliform Rule 

### Exhibit 4-6 summarizes the labor burden asso ciated with conducti ng 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 w ith 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 10,334.52Technology and Cost Document for the 4-13 Proposed Revised Total Coliform Rule 

### 4.3.2 Assumptions

Several underlying assumptions were m ade for the cost estimation development as follows:

• The costs estimates presented in this chap ter and the assumptions that support those estimates were informed by input from St ates and industry received during the proceedings of the TCRDSAC and the associated TCRDSA C 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 increas ing level of expertise, and there are also increasing levels of potential complexity, greater numbers of positive samples required to trigger investigat ion, larger numbers of indivi duals 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 develope d 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 investigati on, 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 on ce 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. Exhi bit 5-1 provides a summar y 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 resi dual, 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 systemTechnology 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 dist ribution 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 thes e 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 pract ices and requirements, and labor rates may impact the final cost for a particular water utilit y to implement a corrective action.

The costs provided in this chapter were obt ained from equipment price lists and quotes, cost estimates from similar projects, best pr actices 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 ar e described in Chapter 2 of this document. Assumptions regarding labor burde n, including number of employ ees 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 sy stem such as tools, field equipment, vehicle access and incidentals.

All costs are presented in 2007 dollars; howev er, 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, inst alled 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 overhea d and profit was applied (R.S. Means, 2009). This overhead factor includes items such as insurance, permits, field offices, temporary facilities, storage, mobilization and dem obilization, barricades, signs, a nd security measures for the

contractors.

For all costs that required a pum ping capacity in the calculati ons, 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/10 6 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 64,50 0 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 - 1,000,000 750,0 00 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 sta gnant 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 un scheduled (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 flus hing 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

Minim um elements of a flushing program are outlined in the AWWA G200 Standard (AWWA 2004) and include: (1) a preventive appro ach 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 proce dures for all elements of the flushing program including water quality mon itoring, 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 co st for routine flushing a complete water distribution system (at a rate of once per year). These costs incl ude estimates of labor, cost of lost water, and cost of treatment (dechlorinat ion) 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-tim e employees may be entirely dedicated to this program. Column E presents the estimated pe rcent 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 us age 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 $3.00 per thousand ga llons (kgal), also obtained from Cost and Benefit Analysis of Flushing , and adjusted to 2007 dollars. Dechlorination costs were estimated based on chemical consumption of dechlorinating agents per ga llon of water flushed. However, treatment requirements for discharge of flushing water wi ll vary according to locality and should be examined on a case-by-case basis. Public notification costs were not included in this estimate.Technology and Cost Document for the5-5Proposed Revised Total Coliform RuleExhibit 5-3: Estimated Annual Costs for Routine Flushing (2007$)System SizeAverageSystemPopulationLaborRate1Number ofemployeesinvolved influshingprogramPercenttimeCommittedto Flushing2Total Labor(hours peryear)TotalLaborCostFlushedWaterVolume3,4(kgal/yr)Value ofWaterFlushedper year5Cost ofDisposal ofFlushedWater peryear6,7,8TotalAnnualCost9(2007$)ABC D E F=D*E*2080 G=C*FH=0.0047*B*100*365/1000I=H*$3.00J=H*$3.00/8.5K=G+I+J<10050 $25.10 1<1%8 $210 103010 $250101- 500300 $27.03 12-3%48 $1,300 6018030 $1,510501 - 1,000750 $28.96 13-4%72 $2,090 130 390 50 $2,5301,001 - 4,1002,550 $29.73 14-5% 96 $2,860 440 1,320 160 $4,3404,101 - 33,000 18,550 $36.00 1 18-20% 384 $13,830 3,1909,570 1,130 $24,53033,001 - 96,000 64,500 $36.39 1 80-90%1920 $69,870 11,070 33,210 3,910 $106,99096,001 - 500,000 298,000 $41.01 2100% 4160$170,610 51,130 153,390 18,050 $342,050500,001 - 1,000,000 750,000 $41.01 3 100% 6240 $255,910 128,670 386,010 45,420 $687,340> 1,000,000 1,500,000 $41.016 100% 12480 $511,810 257,330771,990 90,830 $1,374,6301See Exhibit 2-6 in Chapter 2.Estimated Unit Costs of Labor. *2Estimate based on typical PWS practices.3Average ratio of water flushed per water produced = 0.47%, as reported inCost and Benefit Analysis of Flushing(Hasit, 2004).4Water produced based on mid-pointpopulation of each PWS category, and average usage rate of 100 GPCD.5Value based on average price that PWSscharge for water, as reported inCost and Benefit Analysis of Flushing(Hasit, 2004) and adjusted to 2007 dollars ($3.00 / kgal).6Assumes that dechlorinator attachments are partof typical equipment already owned by the PWS.7Cost per dechlorination tablet obtained from USA Bluebookcatalog, 2008 and adjusted to 2007 dollars ($3.00 / tablet)8Each dechlorination tablet neutralizes 8,500 gallons of water with 1ppm of chlorineaccording to manufacturer recommendations.9Estimates rounded up to the nearest $10Technology and Cost Document for the 5-6 Proposed Revised Total Coliform Rule 

### 5.1.2 Unscheduled / Spot Flushing

Upon obtaining a positive sam ple for total coli form (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 sy stem size. Flushed water volumes were based on a single hydrant flushing event, size of th e 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 resi dual 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 fo r 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 the5-7Proposed Revised Total Coliform RuleExhibit 5-4: Estimated Unit Cost for Spot Flushing (2007$)System Size Labor Rate1Shift Hours2Total LaborCostAverageHydrant SizeMaximumFlushingFlow (GPM)FlushedWaterVolume(kgal)3Value ofWaterFlushed4Cost ofDisposal ofFlushedWater5,6,7Total Cost8(2007$)A B C D=B*C E F G=F*60/1000H=G*$3.00I=H*$3.00 /8.5J=D+H+I<100 $25.10 4 $110 4 500 30 90 20 220101 - 500$27.034$1104500309020220501 - 1,000$28.964$12045003090202301,001 - 4,100$29.734$120675045135202804,101 - 33,000$36.008$2906750451352045033,001 - 96,000$36.398$3006750451352046096,001 - 500,000 $41.018$330810006018030540500,001 - 1,000,000 $41.018$330810006018030540>1,000,000 $41.01 8 $330 8 1000 60 180 30 5401See Exhibit 2-6 in Chapter 2.Estimated Unit Costs of Labor.2Shift hours for systems serving < 500 to 4,100 assume 1-personcrew, and half-day flushing event. Systems serving > 4,100 assume 2-person crew and half-day flushing event.3Flushed water volume based on 1-hour (60-minute) flushing event.4Value based on average price that PWSscharge for water, as reported inCost and Benefit Analysis of Flushing(Hasit, 2004) and adjusted to 2007 dollars ($3.00 / kgal).5Assumes that dechlorinator attachments are partof typical equipment already owned by the PWS.6Cost per dechlorination tablet obtained from USA Bluebookcatalog, 2008 and adjusted to 2007 dollars ($3.00 / tablet).7Each dechlorination tablet neutralizes 8,500 gallons of water with 1ppm of chlorineaccording to manufacturer recommendations.8Estimates 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 de termine if a distribution system is in compliance with regulatory requirements. Implementation of a sampler training program provides guidelines for procedures that sample rs must follow to collect valid, uncontaminated samples for analysis of total coliform in the di stribution system. Training sessions for operators reinforce proper sampling and sample handling pr ocedures 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 co sts, 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 Operat or Training/Certif ication (2007$)

System Size Labor Rate 1 Course Time (hours) 2 Total Labor Cost Travel 3 Training/ Certification Fees 4 Total (2007$) 5

A B C D = B*C E F G = D + E + F
<100 $25.10 8 $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 Dist ribution Syste m Components

Distribution system component s and appurtenances such as valves, pipe, fittings, hydrants, meters, and sample taps are integral pa rts 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 pres ented. 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, main tenance 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 c ondition after replacement / repair. Where appropriate, assumptions on component size were made based on the population range served byTechnology 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 sy stem 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 loca ted 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 Co sts to Replace Valve (2007$)

System Size Labor Rate 1 Shift Time (hours) 2 Total Labor Cost 3 Valve Size (in.) 4 Valve Cost 5,6 Total Cost (2007$) 7

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

<100 $25.10 8 $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, mec hanical 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 base d 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 esti mates are based on an 8- hour shift and 3-person crew.

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

System Size Labor Rate 1 Shift Time (hours) 2 Total Labor Cost 3 Pipe Size (in.) 4 Pipe Cost 5,6,7 (per 20 ft.) Total Cost (2007$) 8

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

<100 $25.10 8 $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 st andard nominal pipe laying lengths are 20 f eet (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 fitti ngs located th roughout 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 o ccur 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 wo rk is performed; therefore, interrupting water service.

Costs are presented in Exhibit 5-8 and are ca lculated based on mate rial 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 Rate 1 Shift Time (hours) 2 Total Labor Cost 3 Fitting Size (in.) 4 Fitting Cost ,5,6,7 Total Cost (2007$) 8

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

<100 $25.10 8 $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 ir on, and mechanical joint cross, with gaskets.

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

7 Fitting weights obtain from American Pipe Manual, 19 th 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 situ ations. Hydrant connections are tapped off the distribution system; therefore, these connect ions can be possible locations for coliform contamination to enter a distribution system.

Replacing a damaged or faulty fire hydrant ca n 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 presente d 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 Cost s to Replace Hydrants (2007$)

System Size Labor Rate 1 Shift Time (hours) 2 Total Labor Cost 3 Hydrant Cost 4,5 Total Cost (2007$) 6

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

<100 $25.10 8 $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 poi nts to commercial, residential, and industrial facilities to

m easure 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 re quirements 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 distri bution system through leak s, 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 contam ination. 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 Rate 1 Shift Time (hours) 2 Total Labor Cost 3 Meter Cost 4,5 Total Cost (2007$) 6

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

< 100 $25.10 8 $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 mete r, 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 re peat sam ple siting plans should ensure that the quality of the water is representative of the distributio n system, and further recommends that dedicated sampling stations, or sampling taps , be explicitly permitted. A dedicated sampling station is a device that is plum bed 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 distri bution system. They are typically covered to protect th em from birds, insects, dirt and other sources of outside contamination. Exhibit 5-11 is a graphic schema tic detailing the compon ents 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 Sa mpling Station Schematic

Source: Water Distribution System Operation and Main tenance, 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 installa tion. 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 Inst alling a Dedicated Sampling Tap (2007$)

System Size Labor Rate 1 Shift Time (hours) 2 Total Labor Cost 3 Sampling Tap Cost 4 Total Cost (2007$) 5

A B C D=B*C*2 E F=D+E
< 100 $25.10 8 $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 inst allation / replacement of exposed sample taps.

4 Material cost assumes Koraleen Enterprises cold weather stat ion, 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 sy stem 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 conditio ns in the distribution system can allow a flow reversal or backflow of non-pot able water to enter the system from a cross connection or other source. Pressure transients can also create hydrau lic disturbances that al low biofilm material on pipe surfaces to enter the bulk water. Industry gu idelines suggest that system pressure should be maintained within the range of 35 to 100 psi at all points in the dist ribution system (AWWA 1996). The AWWA G200 standard i ndicates that the minimum resi dual 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 r outine and emergency conditions can help minimize sudden changes in wate r 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 el evated storage facilities, modifying existing high service pumps, and installi ng 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 dist ribution system s 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 boos ter 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 fo r the installation of a new booster pump station including equipment, required piping and a ppurtenances, electrical and instrumentation equipment, a building, installa tion, overhead and profit.Technology and Cost Document for the5-17Proposed Revised Total Coliform RuleExhibit 5-14: Estimated Costs to Install a New Booster Pump Station (2007$)Population Size CategoryCost Component1<100101to500501to1,0001,001to4,1004,101to33,00033,001to96,00096,001to500,000500,001to1,000,000>1,000,000Pump Station Size (MGD)2A 0.01 0.03 0.08 0.090.7 2.2 3.0 7.5 15Number of PumpsB1 duty1 stand-by1 duty1 stand-by1 duty1 stand-by1 duty1 stand-by1 duty1 stand-by2 duty1 stand-by2 duty1 stand-by2 duty1 stand-by2 duty1 stand-byPump Size (gpm)C10 30 60 60 430 750 1100 2,700 5,300Pump & Motor CostD$780 $1,960 $2,140$2,140 $15,280 $26,520 $36,780 $92,440 $184,860Pipes and related materials E$650 $1,930 $5,130$5,770 $38,460 $141,000 $192,280 $480,690 $961,370Equipment Installation3F=0.3*(D+E) $430 $1,170 $2,190 $2,380$16,130 $50,260 $68,720$171,940 $343,870Total Cost of InstalledEquipmentG=D+E+F $1,860 $5,060 $9,460 $10,290 $69,870 $217,780 $297,780$745,070 $1,490,100Building Size (sf)H72 72 72 72 167 264 366 920 1,841Building Cost4I $3,940 $3,940 $3,940 $3,940 $9,120 $14,420 $19,980 $50,260 $100,510Slab-on-grade Cost5,6J $230 $230 $230 $230 $530 $830 $1,140 $2,870 $5,730Electrical andInstrumentation7K=0.2*G $380 $1,020 $1,900 $2,060 $13,980 $43,560 $59,560 $149,020 $298,020Total Cost (2007$)8,9L=1.225*(G+I+J+K) $7,860 $12,560$19,030 $20,240 $114,540 $338,830$463,620 $1,160,350 $2,320,6001All costs on a per pump station basis.2See Exhibit 5-23Assumes 30% of pump, motor, pipes and related materials total cost.4Assumes the median cost ($60/sf) of a Warehouse & Storage Building type (includes site work, masonry, plumbing, electrical, HVAC & labor). Source: R.S. Means, 2009 (adjusted to 2007dollars).5Assumes $184.43/cubic yard. Source: R.S. Means, 2009.6Assumes a 6-inch slab.7Assumes 20% of the total installed equipment.8Cost rounded up to the nearest $10.9Includes 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 pum p station is not always required to maintain an appropriate pressure in a wate r 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 a nd 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 Equipment 2 E=0.3*D $120 $300 $330 $330 $2, 300 $3,980 $5,520 $13,870 $27,730

Installation 3 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: USABlueB ook 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 profi t, based on R.S. Means (2009).



### 5.4.3 Install Variable Frequency Drives

A variable frequency drive (VFD), also calle d a variable speed drive, allows a booster

pum p to supply the required amount of flow based on system demand with a pressure set point to maintain constant system discharge pressure, co ntrolled to within a few psi of an operator– adjustable system pressure set point. VFDs wo rk 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 Instal l a Variable Frequency Drive (2007$)

System Size Pump Size (gpm) 1 VFD Cost 2 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 prof it, based on R.S. Means (2009).



### 5.4.4 Elevated Storage Facility

Elevated storage is provided within the dist ribution system to supply peak demand rates and equalize system pressures. In certain sy stems, 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 te mporarily when pumps are out of service.

Elevated storage tanks are often sited in ar eas 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 lo cated at some distance from the pump station serving a distribut ion 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 c onstruction 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 Inst all a New Elevated St orage Tank (2007$)

System Size Tank Size (gal) Tank Cost 1 Foundation Cost 2,3 Piping & Related Materials Cost 4 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 $21 4,040 $1,136,180
33,001 - 96,000 1,000,000 $859,980 $129,000 $29 6,690 $1,574,950
96,001 - 500,000 1,000,000 $859,980 $129,000 $29 6,690 $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 condi tions, good soil conditions assumed.

4 Assumes 30% of tank and foundation combined cost.

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



### 5.4.5 Install Surge Relief Valve

Surge relief valves provide pressure m anageme nt 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-pres sure conditions in a line worse than they would be without the valve.

Exhibit 5-18 presents the estimated co sts to install a su rge relief valve.

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

System Size Valve Size (in) Surge Relief Valve Cost 1 Total Cost 2 (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 prof it, 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 in clude pneum atic 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 disinfectan t residual and microbial growth and other water quality problems may results. Proper operations and maintenance of surge tanks is required to pr event 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 t ypically used in larger systems (serving > 500,000 customers). A hydropneum atic tank system allows for fluctuations in water distribution system pressure, and a poten tial 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 pr essure tank discharges into the system and reduces the pressure tank’s water level, whic h expands the air cushion above the water and decreases the tank air pressure. When the air re aches 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. Th e 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 hydropne umatic 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 In stall a Surge Control Tank (2007$)

System Size Tank Size (gal) Tank Cost 1,2 Tank Control & Accessories 3 Slab-ongrade 4,5 Installation 6 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 $2,66 0 $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 - 1,000,000 9 NA NA NA NA NA NA
> 1,000,000 9 NA NA NA NA NA NA

1 Assumes standard horizontal tanks for 100 psi worki ng 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 profi t, 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-p roducts (DBPs). Thus, increased water age can lead to higher DBP concentrations. Other wate r quality problems associated with increased water age include reduced disinfect ant residual, increased microbial activity, nitrif ication, and/or taste and odor problems. Water systems should develop an overal l strategy to manage the water age in their distribution systems. Establishing a water age goal is system-specific depending on system design and operation, wate r demands, and water quality (e .g. DBP formation potential). In the US, the average distribu tion 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 controlle d 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. A dditional guidance is provide d in the AwwaRF report, Managing Distribution System Retention Ti me to Improve Water Quality (Brandt et al. 2004).

5.5.1 Loop Dead Ends

Dead end pipes often result in stagnant water con ditions where water age increases, which can cause water quality problems. One of th e solutions to address th e stagnant water issue is looping of dead ends. However, looping shoul d be evaluated carefully on a case-by-case basis as it may not actually reduce the long de tention times present in those areas.

The cost associated with installing loops to el iminate 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 m eet a minimum hydraulic capacity. Additional capacity is generally included at th e design stage to accommodate for future growth or to allow more flexibility in the configura tion of a distribution system network. A PWS may also have a policy to limit the num ber of different pipe diameters within the system in order to simplify construction and maintenan ce. Consequently network pipe s tend to be larger than is necessary to meet the daily de mand 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 insta lling 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

Autom ated flushing devices are used to purge accumulated sediments at low spots and the dead-ends of pipelines at regul ar intervals and for draining pipe lines for repairs, maintenance, and inspection. These devices are be st 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 controlli ng retention time.

Exhibit 5-20 presents the cost of insta lling 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 Inst all Automated Flushing Devices (2007$)

System Size Labor Rate 1 Shift Time (hours) Total Labor Cost 2 Automated Flushing Device Cost 3,4 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

Som e storage facilities have been designed focusing more on quantity, cost, service life, appearance and shape than on maintaining water qua lity. Water quality in storage facilities is affected by the mixing patterns that occur prim arily during the filling cycle, the long term residence time, and the interaction between these two phenomena.

Increasing volume turnover reduces the aver age hydraulic reside nce time (HRT) in finished water storage facilities, thereby re ducing 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 faci lities 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 de mand. Mixing can be improved by increasing inlet momentum, changing the inlet configuration, increasing the fill time, and by installing mixing device s within the storage facility.

5.5.4.1 Modify Inlet/Outlet Piping

Inle t/outlet configuration is critical in the development of proper mixing in a finished water storage facility. The inle t/outlet structure should be locate d and sized to disperse the jet into the storage facility as we ll as to maintain a jet sufficien t 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 th e 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 abi lity to reduce the inlet diameter to achieve a higher inflow velocity and bett er jetting action will be constraine d by the need to maintain an outflow capacity adequate to satisfy system opera tional and fire flow requirements. For this reason, it is recommended to elimin ate the common inlet/outlet pipe.

Exhibit 5-21 presents the cost of modifyi ng the inlet/outlet confi guration, including the pipes and related materials (e.g. valves), installation, and profit and overhead costs. Because these modifications are very site-specific a nd based on tank geometry, materials costs were estimated as 10% of the piping and related materi als cost associated with installation of a new elevated storage tank, as identifi ed in Exhibit 5-16 (column E). Installation was estimated as 20% of the materials cost based on similar experi ence 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 M odify Inlet/Outlet Piping (2007$)

System Size Tank Size (gal) Pipe & Related Materials Cost 1 Installation Cost 2 Total Cost (2007$) 3,4

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

< 100 25,000 $5,060 $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 1,000,0 00 $29,670 $5,940 $43,620
96,001 - 500,000 1,000,0 00 $29,670 $5,940 $43,620
500,001 - 1,000,000 2,000,0 00 $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 insta lling 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 redu ce stagnant zones can also be accom plished 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 installi ng mixing devices in th e storage facilities, including the mixing device, the pi pes and related materials (e.g. va lves) 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 id entified in Exhibit 5-16 (column E). Installation was estimated as 20% of the total equipment a nd 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

Cost 1 Pipes & Related Materials Cost 2 Installation Cost 3 Total Cost 4 (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 $3,29 0 $9,620 $2,590 $18,990
1,001 - 4,100 250,000 $8,23 0 $13,260 $4,300 $31,590
4,101 - 33,000 500,000 $16,4 50 $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 $65,8 00 $59,340 $25,030 $183,960

1 Assumes a mixing system by Tide Flex Technologies (Carnegie, PA).

2 Assumes 10% of the Piping & Related Materials Cost of insta lling 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 m entioned earlier in this section, incr easing the volume turnove r reduces the average HRT in the storage tank. Turnover can be acco mplished by making operational modifications to the storage tank such as increasing the water le vel 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 booste r stations and other tanks to achieve turnover while maintaining ade quate pressure system-wide.
Exhibit 5-23 presents the costs associated with modifying a storage operation. The costs included in this action are the ope rator labor costs associated w ith the time spent analyzing the different storage operation altern atives, selecting the most appr opriate 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 Supervis ory Control and Data Acquisition SCADA system and therefore there is an additional cost for th e 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 Rate 1 Labor Time (hours) 2 Programmer Rate 3,4 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 (i n 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

Decomm issioning storage faciliti es may be an appropriate st rategy to reduce water age if existing facilities are oversized and not needed for emergency conditions, fire protection, or for maintaining system pressure. A professional e ngineer should review system needs, system design, and operation to determine if the ex isting 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 Rate 1 Time (hours) Total Labor Cost 2 Tank Cleaning

Cost 3 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 th ree purposes: reduce pressure fl uctuations 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 storag e tanks and elevated storage tanks. Ground storage tanks can be belo w grade, partially below grade, or at ground level in a distribution system a nd 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 inspectin g 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 inform ati on on the physical condition of the exterior and interior of the tank, identifying potential so urces of microbial contamination. Inspections can also identify the accumulation of sediment with in 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 wa ter quality issues associated w ith 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 rega rding 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 in clude 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 In spection and Cleaning of Storage Tanks (2007$)

System Size Tank Size (gal) Tank Type Total Cost 1,2 (2007$)

A B C D

<100 25,000 Elevated $1,340

101 - 500 50,000 Elevated $1,510
501 - 1,000 100,000 Elevated $1,830
1,001 - 4,100 250,000 Elevated $3,190
4,101 – 33,000 500,000 Elevated $5,020
33,001 - 96,000 1,000,000 Elevated $7,750
96,001 - 500,000 1,000,000 Elevated $7,750
500,001 - 1,000,000 2,000,0 00 Elevated $9,110
> 1,000,000 2,000,000 Elevated $9,110

1 Cost includes inspection, l abor, 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 st orage tank is another action that can be taken to reduce the potential for coliform contamination of a dist ribution system. Corrosion and corrosion product buildup from excessive interior corr osion can also result in water quality issues such as increased disinfection demand, microbial gr owth, 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 ty pes presented were assumed to be present in a distribution system serving the associated popula tion range. The costs in clude material, labor, equipment, and insurance costs, and assume an ex isting 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., IncTechnology 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 contam ination in a water sto rage 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 Repa ir/Replacement of a Storage Tank Vent (2007$)

System Size Labor Rate 1 Shift Time (hours) Total Labor Cost 2 Vent Screen Cost 3 Total Cost (2007$)

A 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 diam eter, 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 dam aged tank co vers can also be a source of microbial contamination. Exhibit 5-29 presents estimated co sts for repairing water storage tank covers for various tank sizes and types assume d to be present in a distributi on system serving the associated population range. These cost estimates assume a repa ir cost equal to 20% of the installed cost of a new tank, which includes materi al, labor, overhead, and profit.Technology and Cost Document for the 5-31 Proposed Revised Total Coliform Rule 

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

System Size Tank Size (gal) Tank Type New Tank Cost 1 Total Cost 2 (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 st orage tank, as presented in Exhibit 5-16.

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



## 5.7 Booster Disinfection

Booster disinfection facilitie s located throughout a distri bution 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 associat ed with installation of both chlorine and chloramines booster disinfection facilities. The b ooster disinfection facili ties were sized based on the system size, type of chem ical treatment, and permanent or temporary system. Permanent systems were assumed to be operating all year r ound 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 residua l levels in a system. They would be placed in locations that typically had low disinfectant residu al levels. Temporary systems were assumed to operate one day and provide one day of chemical st orage. 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 we re low for a distribution system; however, these distribution systems would only expe rience 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, th e booster disinfection facilit ies are not required to operate all year round.

The capital costs of the fac ilities include feed equipment, storage, required piping and appurtenances, electrical and instrumentation eq uipment, a building, and installation. Buildings were sized to provide adequate spacing between th e 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 sys tems currently use chlorine as thei r main disinfectant. Exhibits 5-30 and 5-31 show various chlorine facility si zes. Based on the facility size, e ither 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 lin e is introduced at a controlled rate to erode the tablets. A pump then injects the chlorinated so lution back into the main line. These facilities did not require a storage containe r. 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 perm anent 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 li quid sodium hypochlorite storage. The number of tanks varied depending on the system size. Exhibit 5-30 presen ts the estimated cost for the installation of a permanent chlorine disinfection boos ter station. Costs to rehabilita te 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 tem porary systems, it was assumed that each of the facilities would have liquid hypochlorite systems; therefore, e ach 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 ch lorine disinfection booster station.Technology and Cost Document for the5-33Proposed Revised Total Coliform RuleExhibit 5-30: Estimated Costs toInstall a Permanent Chlorine Booster DisinfectionStation (2007$)1 Tablet chlorinator systems assumed for system sizes 10,000 and less; liquid hypochlorite systems assumed for system sizes 10,001 and greater2 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 andtanks 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 andlabor rates presented in Exhibit 2-6 of Section 2. Estimated Unit Costs of Labor.10 Chemical cost per chemical supplier ($2.50 per lb ofchlorine tablets and $1.35per gallon of hypochlorite).11 Assumes 10% of equipment cost.Population Size CategoryCost Component<100101 to500501 to1,0001,001 to4,1004,100 to33,00033,001 to96,00096,001 to500,000500,001 to1,000,000>1,000,000Tablet Chlorinator System1Usage 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 Cost2C $6,840 $6,840 $6,840 $6,840 - - - - -Liquid Hypochlorite System1Usage Rate (gal/hr) D - - - - 0.32 1.12 1.55 3.91 7.82Pump Size (gal/hr) E - - - - 0.55 1.9 1.9 5 8.4Total Pump Cost (two pumps)3F - - - - $1,100 $1,190 $1,190 $1,190 $1,640Storage Requirement4(gal) G - - - - 300 900 1,200 2,900 5,700Storage Tank Cost3H - - - - $640 $1,190 $1,010 $2,010 $6,930Cost of Piping and Appurtenances5I $250 $250 $250 $250 $270 $360 $330 $480 $1,290Cost of Instrumentation and Electrical5J $250 $250 $250 $250 $270 $360 $330 $480 $1,290Total Cost of EquipmentK=C+F+H+I+J $7,340 $7,340 $7,340 $7,340 $2,280 $3,100 $2,860 $4,160 $11,150Total Structure Cost6L $4,200 $4,200 $4,200 $4,200 $9,660 $9,660 $12,940 $23,780 $26,060Cost of Installation7M=0.15*(K+L) $1,740 $1,740 $1,740 $1,740 $1,800 $1,920 $2,370 $4,200 $5,590Total Capital Cost (2007$)8N=1.225*(K+L+M) $16,270 $16,270 $16,270 $16,270 $16,840 $17,990 $22,260 $39,380 $52,430Labor Cost ($/year)9O $8,520 $9,120 $9,840 $10,080 $12,120 $12,240 $13,800 $13,800 $13,800Chemical Cost ($/year)10P $120 $360 $360 $960 $6,000$15,600 $20,400 $48,000 $92,400Parts and Maintenance Cost ($/year)11Q=0.1*K $740 $740 $740 $740 $230 $310 $290 $420 $1,120Yearly Operation and Maintenance Cost R=O+P+Q$9,380 $10,220 $10,940 $11,780 $18,350 $28,150 $34,490 $62,220 $107,320Technology and Cost Document for the5-34Proposed Revised Total Coliform RuleExhibit 5-31: Estimated Costs toInstall a Temporary Chlorine Booster Disinfection Station (2007$)Population Size CategoryCost Component<100101 to500501 to1,0001,001 to4,1004,100 to33,00033,001 to96,00096,001 to500,000500,001 to1,000,000>1,000,000Usage Rate (gal/hr)A 0.003 0.010.04 0.04 0.32 1.12 1.55 3.91 7.82Pump Size (gal/hr)B 0.19 0.19 0.19 0.19 0.551.9 1.9 5 8.4Total Pump Cost (one pump)1C $540 $540 $540 $540 $560 $640 $640 $730 $820Storage Requirement (gal)D 10 10 10 10 10 30 40 100 190Type of Storage Container2E Carboy Carboy Carboy Carboy Drum Drum Drum Drum ToteCost of Piping and Appurtenances3F=0.15*C $90 $90 $90 $90 $90 $100 $100 $110 $130Cost of Instrumentation and Electrical3G=0.15*C $90 $90 $90 $90 $90 $100 $100 $110 $130Total Cost of Equipment H=C+F+G $720 $720 $720 $720 $740 $840 $840 $950 $1,080Total Structure Cost4I $930 $930 $1,000 $1,000 $1,460 $1,660 $1,660 $2,100 $4,190Cost of Installation5J=0.15*(H+I) $250 $250 $260 $260 $330 $380 $380 $460 $800Total Capital Cost (2007$)6K=1.225*(H+I+J)$1,900 $1,900 $1,980$1,980 $2,530 $2,880 $2,880 $3,510 $6,070Labor Cost ($/year)7L $60 $60 $60 $60 $80 $80 $90 $90 $90Chemical Cost($/year)8M $90 $90 $90 $90 $90 $90 $90 $170 $450Parts and Maintenance Cost ($/year)9N=0.1*H $80 $80 $80 $80 $80 $90 $90 $100 $110Yearly Operation and MaintenanceCostO=L+M+N$230 $230 $230 $240 $250 $260 $270 $360 $6501Pump cost per Cole Palmer catalog (2008), adjusted to2007 dollars. Pumps are solenoid diaphragm metering pumps.2Assumes storage containers obtained from chemical supplier, and returned for refund of any applicable deposit.3Assumes 15% of pump costs.4Structure cost includes building and slab per R.S. Means, 2009.5Assume 15% of equipment and structure costs.6Assume two hours of maintenance a day based on labor rates presented in Exhibit 2-6 of Section 2.Estimated Unit Costs of Labor7Includes 22.5% overhead and profit, based on R.S. Means, 2009.8Chemical cost based on minimum chemicaldelivery volume per chemical vendor.9Assumes 10% of equipment cost.Technology and Cost Document for the 5-35 Proposed Revised Total Coliform Rule 

### 5.7.2 Chloramines System

Som e utilities use combined chlorine, or chlo ramines, as a secondary disinfectant. For these systems to provide residual boosting, an aq ua ammonia feed is required in addition to a chlorine feed system. Exhibits 5-32 and 5-33 outline costs for a ch loramines 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 wa s 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 perm anent systems, the aqua ammonia feed system included two solenoid pumps, one in operation and one on standby. Chemical st orage varied depending on the required amount of ammonia. It was assumed that systems re quiring 500 gallons or grea ter of storage would install stainless steel storage tanks. Systems th at required less would e ither 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 tem porary 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 te mporary chloramine booster station.Technology and Cost Document for the5-36Proposed Revised Total Coliform RuleExhibit 5-32: Estimated Costs toInstall a Permanent Chloramines Booster Disinfection Station (2007$)Population Size CategoryCost Component<100101 to500501 to1,0001,001 to4,1004,100 to33,00033,001 to96,00096,001 to500,000500,001 to1,000,000>1,000,000Tablet Chlorinator System1UsageRate(lb/hr) A 0.003 0.01 0.01 0.04 - - - - -SystemSize(lb/hr) B 0.5 0.5 0.5 0.5 - - - - -System Cost2C $6,840 $6,840 $6,840 $6,840 - - - - -Liquid Hypochlorite System1Usage Rate (gal/hr) D - - - - 0.32 1.12 1.55 3.91 7.82Pump Size (gal/hr) E---- 0.55 1.9 1.9 5 8.4Pump Cost3F - - - - $1,100 $1,190 $1,190 $1,190 $1,640Storage Requirement (gal)4G - - - - 300 900 1200 2900 5700Storage Tank Cost3H - - - - $640 $1,190 $1,010 $2,010 $6,930AquaAmmoniaSystemUsage Rate (gal/hr) I 0.0004 0.002 0.002 0.007 0.049 0.169 0.235 0.591 1.183Pump Size (gal/hr) J0.19 0.190.19 0.19 0.19 0.29 0.29 1.10 1.90Pump Cost3K $1,100 $1,100 $1,100 $1,100 $1,100 $1,100 $1,100 $1,190 $1,640Storage Requirement(gal)4L 10 10 10 10 40 130 170 430 860Storage Tank Cost3M - - - - - - - $18,220 $20,780Cost of Piping andAppurtenances5N=0.15*(C+F+H+K+M)$420 $420 $420 $420 $430 $530 $500 $3,400 $4,650Cost of Instrumentation andElectrical5O=0.15*(C+F+H+K+M)$420 $420 $420 $420 $430 $530 $500 $3,400 $4,650Total 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 $29,410 $40,290Total Structure Cost($/year)6Q $7,870 $7,870 $7,930 $7,930 $15,580 $15,580 $19,590 $37,450 $41,910Cost of Installation7R=0.15*(P+Q)$2,500 $2,500 $2,510 $2,510 $2,900 $3,020$3,590 $10,030 $12,330Total Capital Cost (2007$)8S=1.225(P+Q+R)$23,460 $23,460 $23,550 $23,550 $27,180 $28,350 $33,670 $94,200 $115,800Technology and Cost Document for the5-37Proposed Revised Total Coliform RulePopulation Size CategoryCost Component<100101 to500501 to1,0001,001 to4,1004,100 to33,00033,001 to96,00096,001 to500,000500,001 to1,000,000>1,000,000Operations & Maintenance CostsLabor Cost($/year)9T$8,600 $9,200 $9,900$10,100 $12,200 $12,300 $13,800 $13,800 $13,800Chemical Cost($/year)10U$200 $500 $500 $1,100 $9,500 $19,200 $24,000 $54,000 $103,200Parts and Maintenance Cost($/year)11V=0.1*P$880 $880 $880 $880 $370 $460 $430 $2,950 $4,030Yearly O&M CostW=T+U+V$9,700 $10,600 $11,300 $12,100 $22,100 $32,000 $38,300 $70,800 $121,1001Tablet chlorinator systems assumed for system sizes 10,000 andless; liquid hypochlorite system assumed for system sizes 10,001 and greater.2Table chlorinator system cost obtained from vendor.3Pump and tank cost per Cole Palmer catalog (2008), adjusted to 2007 dollars. Pumps are solenoid diaphragm metering pumps and tanks are polyethylene tanks.4Storage requirements based on providing approximately 30 days of chemical storage.5Assume 15% of chemical system and storage costs6Structure cost includes building and slab per R.S. Means 20097Assume 15% of equipment and structure costs8Includes 22.5% overhead and profit, based on R.S. Means9Assumes one hour of maintenance a day based on labor rates presented in Exhibit 2-6 of Section 2.Estimated Unit Costs of Labor.10Chemical cost per chemical supplier in 2009. ($2.50 per lb ofchlorine tablets, $1.35 per gallon of hypochlorite, and $0.99 per gallon of aqua ammonia).11Assumes 10% of equipment cost.Technology and Cost Document for the5-38Proposed Revised Total Coliform RuleExhibit 5-33: Estimated Costs toInstall a Temporary Chloramines Booster Disinfection Station (2007$)1Pump cost per Cole Palmer catalog.Pumps are solenoid diaphragm metering pumps.2Assumes storage containers obtained from chemical supplier, and returned for refund of any applicable deposit.3Assume 15% of chemical systems costs4Structure cost includes building and slab per R.S. Means 20095Assume 15% of equipment and structure costs6Includes 22.5% overhead and profit, based on R.S. Means7Assume two hours of maintenance a day based on labor rates presented in Exhibit 2-6 of Section 2.Estimated Unit Costs of Labor8Chemical cost based on minimum chemicaldelivery volume (For hypochlorite a 55 gallon drum is $82.50 and a 300 gallon tote is$450.00, and for ammonia a 55 gallon drum is $54.45)9Assumes 10% of equipment cost.Population Size CategoryCost Component1<100 <500501 to1,0001,001 to4,1004,100 to33,00033,001 to96,00096,001 to500,000500,001 to1,000,000>1,000,000LiquidHypochloriteSystemUsage Rate (gal/hr) A 0.003 0.010.01 0.04 0.32 1.12 1.55 3.91 7.82Pump Size (gal/hr) B 0.19 0.190.19 0.19 0.55 1.90 1.90 5.00 8.40Pump Cost1C $540 $540 $540 $540 $560 $560 $560 $560 $820Storage Requirement (gal) D 10 10 10 10 10 30 40 100 190Type of Storage Container2E Carboy Carboy Carboy Carboy Drum Drum Drum Drum ToteAquaAmmoniaSystemUsage Rate (gal/hr) F 0.002 0.0020.002 0.007 0.049 0.169 0.235 0.591 1.183Pump Size (gal/hr) G 0.19 0.190.19 0.19 0.19 0.29 0.29 1.10 1.90Pump Cost1H $540 $540 $540 $540 $540 $540 $540 $560 $820Storage Requirement (gal) I 10 10 10 10 10 10 10 20 30Type of Storage Container2J Carboy Carboy Carboy Carboy Carboy Carboy Carboy Drum DrumCost of Piping and Appurtenances3K=0.15*(C+H) $170 $170 $170 $170 $170 $170 $170 $170 $250Cost of Instrumentation and Electrical3L=0.15*(C+H) $170 $170 $170 $170 $170 $170 $170 $170 $250Total Cost of EquipmentM=C+H+K+L $1,420 $1,420 $1,420 $1,420 $1,440 $1,440 $1,440 $1,460 $2,140Total Structure Cost4N $1,920 $1,920 $1,920 $1,920 $2,920 $2,920 $2,920 $3,560 $6,020Cost of Installation5O=0.15*(M+N) $510 $510 $510 $510 $660 $660 $660 $760 $1,230Total Capital Cost (2009$)6P $4,720 $4,720 $4,720 $4,720 $6,150 $6,150 $6,150 $7,090 $11,510Labor Cost7Q $60 $60 $60 $60 $80 $80 $90 $90 $90Chemical Cost8R $150 $150 $150 $150 $150 $150 $150 $230 $510Parts and Maintenance Cost9S $150 $150 $150 $150 $150 $150 $150 $150 $220Yearly Operation and MaintenanceCostT $370 $370 $370 $370 $390 $390 $400 $490 $840Technology and Cost Document for the 5-39 Proposed Revised Total Coliform Rule 

## 5.8 Cross-connection Control and Ba ckflow Prevention Program

Implementing a Cross-Connection Contro l 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 regul ations. Some codes or regul ations may include documenting installation procedures and th e periodic testing of backflow prevention assemblies.

CCCBFP can prevent the introduction of non-pot able substances into the public water supply due to backsiphonage or backpressure. The cost components of a cross-connection control and backflow prevention prog ram 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 dutie s 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 instal ling a backflow prevention assem bly (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 inst all valves indoors. Installation costs do not include costs for this housing, or costs for e ngineering/construction. Maintenance of these assemblies includes a minimum of annual testing and inspection. In addition, the frequency for performance monitoring and internal inspections (dismantling, cleani ng, 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 syst em implements the cross-connection control and backflow prevention program, the customer and the PWS can share costs for the equipment and equipment installation, inspec tion, testing, and mainte nance. The PWS, on the other hand, is primarily responsible for the ad ministration of cross-connection control and backflow prevention and the inspection, review, and a pproval of all backflow prevention assemblies and devices. Labor costs assume a three-person crew is require d 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 Rate 1 Shift Time (hours) Total Labor Cost 2 Backflow Preventer Pipe Size (in.) Backflow Preventer

Cost 3,4 Total Cost (2007$) 5

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

< 100 $25.10 8 $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 $72 0 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 $99 0 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 principl e, flanged, including valves, four test cocks, and corrosion resist ant.

4 Costs do not include design or permit costs.

5 Estimates rounded up to the nearest $10



### 5.8.2 Program Administration

The adm inistration 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 custom ers), available staffing resources, maintenance, record keeping, and spec ific code and regulatory requirements. Another factor in the administrative costs, in some cases , is overcoming political resistance. The CrossConnection Control Manual provides additiona l 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 sta ff or temporary help. In some cases, program administration is contracted out. The Program Ad ministration costs can be classified under three headings:

• Program Organization: It involves establishing the le gal 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 cr oss-connections and identifying and prioritizing hazardous connections.

• Record Keeping: It involves updating and main taining records that are pertinent to the implementation of the CCCBPP.

Exhibit 5-35 summarizes the activities includ ed 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 succe ssful 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 th ese 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 activ ities. The numbers presented in Exhibit 5-36 are of the same order of magnitude as the ones pr esented 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 utilitie s 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 Cost 1 (2007$)

A B C D E=B+C+D

< 100 $840 $390 $190 $1,410
101 - 500 $4,170 $1,950 $940 $7,050 501 - 1,000 $8,340 $3,890 $1,880 $14,100 1,001 - 4,100 $15,630 $5,700 $8,560 $29,880 4,101 - 33,000 $22,970 $6,040 $5,350 $34,340 33,001 - 96,000 $51,110 $11,190 $7,660 $69,950 96,001 - 500,000 $169,260 $37,600 $62,530 $269,390 500,001 - 1,000,000 $975,090 $200,480 $44,320 $1,219,880 > 1,000,000 $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 ar e 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, disi nfectant dosages, and certain water quality parameters, such as disinfec tant residual levels, can be correlated. Since automatic monitoring is not available for TC, co mmunities 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 SCAD A in a distribution system is possible; however, it can be costly. Determining the numbe r and location of the an alyzers is challenging and highly dependent upon the system size. T ypically, 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 build ing, 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 cau se changes to the water quality of the system. Similar to the water quality monitoring, determin ing the number of pressure monitors and their locations is dependent upon the system size. Pr essure 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 thr ough the SCADA system ca n alert operators if there are possible issues with th e distribution system; however, m onitoring the water quality or pressure will not identify the source of the c ontamination 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 instrumenta tion equipment are not included.

5.9.1 Water Quality Monitoring and Control

The ability o f a PWS to monitor water qual ity parameters, particularly disinfectant residuals, in the distribution system can allow th e 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 in crease of organics in a system, which consume disinfectant residuals, or insuffici ent disinfectant dosages at the tr eatment facility. Maintenance of sufficient disinfectant residua l levels in a distribution system is important in maintaining minimal levels of TC in the system.

5.9.1.1 Chlorinated Systems

Most sys tems currently utilize chlorine as th e 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 w ith incorporating a chlo rine residual analyzer in the distribution system. The costs below includ e a chlorine residual analyzer, installation of the analyzer based on system size, required pipi ng and appurtenances, and programming costs.

Exhibit 5-38 presents the annual costs to opera te 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 Rate 1 Labor Time (hours) 2 Programmer Rate 3 Program. Time (hours) 4 Total Labor & Program. Cost 2 Chlorine Analyzer

Cost 5 Piping and related 6 Total Cost 7,8 (2007$)

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

< 100 $25.10 24 $120 8 $2,170 $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 peri od to install chlorine monitoring device and associated equipment (electrical wiring, installing a sample drain, etc.).

3 Assumes average programmer rate of $120 per hour (i n 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 Operati on and Maintenance Costs for an Online Chlorine Analyzer (2007$)

System Size Labor Rate 1 Labor Time (hours) 2 Reagents kit Cost 3,5 Maintenance Kit Cost 4,5 Total Cost 6 (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 i ndicator solutions, and DBD indica tor powder for monthly supply

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

5 Cost obtained from 2009 vendor ca talogs 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 associ ated with in corpor ating ammonia and monochloramine analyzers in the distribution system. The costs below include an ammonia and monochloramine residual analyzer, installation of the an alyzer 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, reag ents, and parts and maintenance costs.

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

System Size Labor Rate 1 Labor Time (hours) 2 Programmer Rate 3 Program. Time (hours) 4 Total Labor & Program. Cost 2 Chloramines Analyzer

Cost 5 Piping and relate

d 6 Total Cost (2007$) 7,8

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

< 100 $25.10 24 $120 8 $2,170 $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 (i n 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 Operati on and Maintenance Costs for Online Ammonia and Monochloramines Analyzer (2007$)

System Size Labor Rate 1 Monthly Labor Time

(hours) 2 Reagents & Standards Kit Cost 4,5 Maintenance Kit Cost 3,5 Total Cost 6 (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 approximatel y 1 hour of maintenance every month per analyzer.

3 Maintenance kit cost per vendor research. Kit includes iron buret pistol seals, gr ease tube, o rings, and valve rotor for quar terly 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 th roughout its distribution system can provide useful inform ation for responding to water quality events and ensuring that pressure maintenance is adequate. Pressure readings can also be us ed 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 cost s 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 Rate 1 Labor Time (hours) 2 Programmer Rate 3 Program. Time (hours) 4 Total Labor & Programming Cost 2 Pressure Transmitter Cost 5 Total Cost 6,7 (2007$)

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

< 100 $25.10 16 $120 8 $1,770 $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 $12 0 8 $1,920 $2,740 $4,660 4,101 - 33,000 $36.00 16 $12 0 8 $2,120 $2,740 $4,860 33,001 - 96,000 $36.39 16 $12 0 8 $2,130 $2,740 $4,870 96,001 - 500,000 $41.01 16 $12 0 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 (i n 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 transmitte r will be installed at an existing facility.



### Exhibit 5-42: Estimated Annual Operati on and Maintenance Costs for Online Pressure Transmitter (2007$)

System Size Labor Rate 1 Labor Time (hours) 2 Annual Total Cost 3 (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 approximat ely 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 secu rity breaches that could lead to water contamination. Measures that a water system may take to correct security breaches includeTechnology and Cost Document for the 5-48 Proposed Revised Total Coliform Rule 

### installing a fence or locking buildings to restri ct access to the system. In addition, alarms and cameras may be used to detect security breaches.

Water systems should prioritize their secur ity 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, accessibi lity of the distribution system, et c. Possible security measures include locked fence enclosures and empl oying a full time, on-site security staff.

Installing security measures can increase the public’s confidence in th e protection of their drinking water and indeed can provide substantia l 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 assume d 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. Co sts include materials, insta llation and overhead and profit.

Exhibit 5-43: Estimated Costs for Inst allation of Security Measures (2007$)

System Size Fence Cost 1,2,5 Gate Cost 3,5 Lighting Cost 4,5 Security Capital Cost Installation Cost 6 Total Cost (2007$) 7,8

A B C D E=B+C+D F=0. 3*E G=(E+F)*1.225

< 100 $8,400 $795 $880 $10,075 $3,023 $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 $88 0 $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 sy stems greater than 10,000.

2 Fence cost assumed to be industrial chain link, three strands ba rbed 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 th e goals of flow, pressu re and water quality.Technology and Cost Document for the 5-49 Proposed Revised Total Coliform Rule 

### AWWA G200-04 standard describe s the critical requirements for the effective operation and management of drinking water dist ribution 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 operati on 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 partic ular function should be sp ecified in the SOP. SOPs should be developed from information gath ered from the various departments and crews involved in a given function. The SOPs s hould 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 di stribution system. The sample s ites shall include, at a minimum, sites required for regulatory compliance monito ring. 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 component s as part of the SOPs.

A written emergency response plan for the di stribution system allows operating personnel to respond efficiently, effectively and rapidly to an emergency situation. Water quality system safety and reliability are improved if a wate r system has an emergency response plan.

Exhibit 5-44 presents the estimated one-ti me cost of developing and implementing an operations and maintenance plan. The estimated co st assumes that both technical and managerial staff will be involved in this task.

Exhibit 5-44: Estimated Costs to Devel op and Implement an Operations Plan (2007$)Technology and Cost Document for the 5-50 Proposed Revised Total Coliform Rule System Size Labor Rate 1 Time (hours) 2 Total Cost (2007$) 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 Proced ure (SOP) Training

EPA established an operator certification pr ogram with minimum professional standards for the operation and maintenance of water system s. The EPA program issued guidelines that specify standards for certification and recertif ication of operators. States implement the minimum standards of the certification program guidelines. While th e specific requirements vary from state to state, the goal of the program is to ensure that sk illed 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 pr ogram provides guidelines for the standards operators must uphold to operate and maintain a treatm ent 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 operati on and maintenance of these facilities and systems. In addition, th ese sessions can help to educate PWS staff on emerging treatment technologies, regulatory requir ements, 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 coul d potentially decrease the possibility of contamination within the distri bution system. Exhibit 5-45 summ arizes the cost for operator training and certification.

Exhibit 5-45: Estimated Costs for Op erator Training/Ce rtification (2007$)Technology and Cost Document for the 5-51 Proposed Revised Total Coliform Rule System Size Labor Rate 1 Course Time (hours) 2 Total Labor Cost Travel 3 Training/ Certification Fees 4 Total Cost (2007$) 5

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

<100 $25.10 8 $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 m aintenance programs de scribed earlier in this section should be reviewed periodically and modifi ed 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 a pproval 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 estimate d cost of revising and updating an operations and maintenance plan. The estimated cost assume s that both technical and managerial staff will be involved in this task.

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

System Size Labor Rate 1 Time (hours) 2 Total Cost (2007$) 3

A B C E=B*C

< 100 $25.10 10 $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 practic es 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 Rate 1 Time (hours) 2 Total Cost (2007$) 3

A B C E=B*C

< 100 $25.10 1 $30

101 - 500 $27.03 1 $30
501 - 1,000 $28.96 2 $60
1,001 - 4,100 $29.73 2 $60
4,101 - 33,000 $36.00 2 $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 fr eely 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 th e most recent publication first.

American Backflow Prevention Association (A BPA). 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., Case y, 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. Depart ment of Labor, Employment Cost Index, [www.bls.gov/news.release/eci.toc.htm].

Bureau of Labor Statistics, U.S. Departme nt of Labor, National Compensation Survey, [www.bls.gov/ncs/].

Bureau of Labor Statistics, U.S. Department of Labor, Occupational Em ployment Statistics, [www.bls.gov/oes/].

Clesceri, Lenore & Greenberg, Arnold & Eaton, A ndrew. Standard Methods for the Examination of Water and Wastewater, 20 th 

### Edition. Washington, DC: American Public Health Association, American Waterworks Associat ion, 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 Maintain ing Distribution System Water Quality. Denver, CO: AWWARF and AWWA

Means, R.S. 2009 Building Construction Cost Data. 62 nd 

### 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, Inte grity, 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 / Distributio n 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 Re gulations: Revisions to the Total Coliform Rule. xx FR xxx. XX X, 2010.

USEPA. 2007a. Meeting of the Total Coliform Ru le 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/envi ro/html/sdwis/ [29 Apr 2009].

USEPA. 2006a. Economic Analysis for the Fi nal 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 Fi nal Long Term 2 Enhanced Surface Water Treatment Rule. January, 2006. EPA-815-R-06-001.

USEPA. 2006c. Economic Analysis for the Fi nal Stage 2 Disinfectants and Disinfection Byproducts Rule. January, 2006. EPA-715-R-05-010.

USEPA. 2006d. National Primary Drinking Wate r 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 Wate r Regulations: Stage 2 Disinfectants and Disinfection Byproducts Rule. 71 FR 388. January 4, 2006.

USEPA. 2003a. Consideration of Other Regulator y Revisions for Chemical Contaminants in Support of the Six-Year Review of Nationa l 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 Wate r Regulations: Announcement of Completion of EPA's Review of Existing Drinking Wa ter 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 Contro l 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 Dr inking Water Regulations; Total Coliforms (Including Fecal Coliforms and E. Coli); Fina l Rule. 54 FR 27544. June, 29, 1989.

U.S. General Services Admini stration (GSA). GSA. Available: http://www.gsa.gov/Portal/gsa/ep/conten tView.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 implem ented) 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 bes t professional judgment of TCRDSAC TWG members and their colleagues. The table is not intended to re present 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 info rming the net change in labor burden associated with assessments under the proposed revised TCR.Technology and Cost Document for theA-2Proposed Revised Total Coliform RuleExhibit A-1.2: RTCR Labor Burden Estimatefor Assessments done by NCWSs serving <= 1,000Level 1 AssessmentLevel 2 Assessment (nonacute)Level 2 Assessment (acute)Percentage ofSystems doingElementEstimatedHoursAssociatedwith ElementAverageBurdenAssociated withElementPercentage ofSystems doingElementEstimatedHoursAssociated withElementAverageBurdenAssociated withElementPercentage ofSystems doingElementEstimatedHoursAssociated withElementAverageBurdenAssociated withElementGHI = G * HJKL = J * KMNO = M * NNotificationElement100% 00 100%0.50.5 100%22SystemSpecificElement0% 00 100%0.30.3 100%11SampleAnalyticalElement0% 00 100%00 100%11SampleMethodologyElement50% 10.5 100%0.50.5 100%11EventSituationalElement100% 11 100%22 100%22OperationalData Element60% 0.3 0.18 40%0.50.2 40%10.4HistoricalTrend Element100% 0.50.5 100%0.50.55%40.2Sample TapElement100% 11 100%11 100%11Sample SiteElement100% 11 100%11 100%11Sample AreaElement100% 11 100%11 20%71.4Third PartyElement0% 000%00 50%168ReportElement100% 22 100%22 100%22Total7.18921Note: Estimates informed by the collective experience and best professional judgment of TCRDSAC TWG members and their colleagues. The table is not intended to representrequired 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 tooccur under the proposed revised TCR for purposes of informing the net change in labor burden associated with assessments underthe proposed revised TCR.Technology and Cost Document for the A-3 Proposed Revised Total Coliform Rule 

### Exhibit A-2.1: Current TCR (as implem ented) 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 bes t professional judgment of TCRDSAC TWG members and their colleagues. The table is not intended to re present 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 info rming the net change in labor burden associated with assessments under the proposed revised TCR.Technology and Cost Document for theA-4Proposed Revised Total Coliform RuleExhibit A-2.2: RTCR Labor Burden Estimate for Assessments done by NCWSs serving 1,001 - 4,100Level 1 AssessmentLevel 2 Assessment (nonacute)Level 2 Assessment (acute)Percentage ofSystems doingElementEstimatedHoursAssociatedwith ElementAverageBurdenAssociated withElementPercentage ofSystems doingElementEstimatedHoursAssociated withElementAverageBurdenAssociated withElementPercentage ofSystems doingElementEstimatedHoursAssociated withElementAverageBurdenAssociated withElementGHI = G * HJKL = J * KMNO = M * NNotificationElement100% 00 100%0.50.5 100%22SystemSpecificElement0% 00 100%0.30.3 100%11SampleAnalyticalElement0% 00 100%00 100%11SampleMethodologyElement50% 10.5 100%0.50.5 100%11EventSituationalElement100% 11 100%22 100%22OperationalData Element60% 0.3 0.18 40%0.50.2 40%10.4HistoricalTrend Element100% 0.50.5 100%0.50.55%40.2Sample TapElement100% 11 100%11 100%11Sample SiteElement100% 11 100%11 100%11Sample AreaElement100% 22 100%22 20%71.4Third PartyElement0% 000%00 50%168ReportElement100% 22 100%22 100%22Total8.181021Note: Estimates informed by the collective experience and best professional judgment of TCRDSAC TWG members and their colleagues. The table is not intended to representrequired 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 tooccur under the proposed revised TCR for purposes of informing the net change in labor burden associated with assessments underthe proposed revised TCR.Technology and Cost Document for the A-5 Proposed Revised Total Coliform Rule 

### Exhibit A-3.1: Current TCR (as implem ented) 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 bes t professional judgment of TCRDSAC TWG members and their colleagues. The table is not intended to re present 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 info rming the net change in labor burden associated with assessments under the proposed revised TCR.Technology and Cost Document for theA-6Proposed Revised Total Coliform RuleExhibit A-3.2: RTCR Labor Burden Estimatefor Assessments done by CWSs serving <= 100Level 1 AssessmentLevel 2 Assessment (nonacute)Level 2 Assessment (acute)Percentage ofSystems doingElementEstimatedHoursAssociatedwith ElementAverageBurdenAssociated withElementPercentage ofSystems doingElementEstimatedHoursAssociated withElementAverageBurdenAssociated withElementPercentage ofSystems doingElementEstimatedHoursAssociated withElementAverageBurdenAssociated withElementGHI = G * HJKL = J * KMNO = M * NNotificationElement100% 22 100%22 100%22SystemSpecificElement100% 11 100%11 100%11SampleAnalyticalElement0% 000%000%00SampleMethodologyElement100% 22 100%22 100%22EventSituationalElement100% 22 100%22 100%22OperationalData Element60% 21.2 60%21.2 60%21.2HistoricalTrend Element100% 22 100%22 100%22Sample TapElement100% 11 100%11 100%11Sample SiteElement5% 20.15%20.1 100%11Sample AreaElement100% 2.52.5 100%2.52.5 100%2.52.5Third PartyElement000ReportElement100% 5.55.5 100%8.58.5 100%8.58.5Total19.322.323.2Note: Estimates informed by the collective experience and best professional judgment of TCRDSAC TWG members and their colleagues. The table is not intended to representrequired 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 tooccur under the proposed revised TCR for purposes of informing the net change in labor burden associated with assessments underthe proposed revised TCR.Technology and Cost Document for the A-7 Proposed Revised Total Coliform Rule 

### Exhibit A-4.1: Current TCR (as implem ented) 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 bes t professional judgment of TCRDSAC TWG members and their colleagues. The table is not intended to re present 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 info rming the net change in labor burden associated with assessments under the proposed revised TCR.Technology and Cost Document for theA-8Proposed Revised Total Coliform RuleExhibit A-4.2: RTCR Labor Burden Estimatefor Assessments done by CWSs serving 101 - 500Level 1 AssessmentLevel 2 Assessment (nonacute)Level 2 Assessment (acute)Percentage ofSystems doingElementEstimatedHoursAssociatedwith ElementAverageBurdenAssociated withElementPercentage ofSystems doingElementEstimatedHoursAssociated withElementAverageBurdenAssociated withElementPercentage ofSystems doingElementEstimatedHoursAssociated withElementAverageBurdenAssociated withElementGHI = G * HJKL = J * KMNO = M * NNotificationElement100% 22 100%22 100%22SystemSpecificElement100% 11 100%11 100%11SampleAnalyticalElement0% 000%000%00SampleMethodologyElement100% 22 100%22 100%22EventSituationalElement100% 22 100%22 100%22OperationalData Element60% 21.2 60%21.2 60%21.2HistoricalTrend Element100% 22 100%22 100%22Sample TapElement100% 11 100%11 100%11Sample SiteElement5% 20.15%20.1 100%11Sample AreaElement100% 2.52.5 100%2.52.5 100%2.52.5Third PartyElement000ReportElement100% 5.55.5 100%8.58.5 100%8.58.5Total19.322.323.2Note: Estimates informed by the collective experience and best professional judgment of TCRDSAC TWG members and their colleagues. The table is not intended to representrequired 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 tooccur under the proposed revised TCR for purposes of informing the net change in labor burden associated with assessments underthe proposed revised TCR.Technology and Cost Document for the A-9 Proposed Revised Total Coliform Rule 

### Exhibit A-5.1: Current TCR (as implem ented) 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 bes t professional judgment of TCRDSAC TWG members and their colleagues. The table is not intended to re present 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 info rming the net change in labor burden associated with assessments under the proposed revised TCR.Technology and Cost Document for theA-10Proposed Revised Total Coliform RuleExhibit A-5.2: RTCR Labor Burden Estimatefor Assessments done by CWSs serving 501 - 1,000Level 1 AssessmentLevel 2 Assessment (nonacute)Level 2 Assessment (acute)Percentage ofSystems doingElementEstimatedHoursAssociatedwith ElementAverageBurdenAssociated withElementPercentage ofSystems doingElementEstimatedHoursAssociated withElementAverageBurdenAssociated withElementPercentage ofSystems doingElementEstimatedHoursAssociated withElementAverageBurdenAssociated withElementGHI = G * HJKL = J * KMNO = M * NNotificationElement100% 2.52.5 100%2.52.5 100%2.52.5SystemSpecificElement100% 11 100%11 100%11SampleAnalyticalElement0% 000%000%00SampleMethodologyElement100% 22 100%22 100%22EventSituationalElement100% 22 100%2.52.5 100%22OperationalData Element60% 21.2 60%21.2 60%21.2HistoricalTrend Element100% 22 100%22 100%22Sample TapElement100% 11 100%11 100%11Sample SiteElement5% 20.15%20.1 100%11Sample AreaElement100% 2.52.5 100%2.52.5 100%2.52.5Third PartyElement000ReportElement100% 5.55.5 100%8.58.5 100%8.58.5Total19.823.323.7Note: Estimates informed by the collective experience and best professional judgment of TCRDSAC TWG members and their colleagues. The table is not intended to representrequired 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 tooccur under the proposed revised TCR for purposes of informing the net change in labor burden associated with assessments underthe proposed revised TCR.Technology and Cost Document for the A-11 Proposed Revised Total Coliform Rule 

### Exhibit A-6.1: Current TCR (as implem ented) 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 bes t professional judgment of TCRDSAC TWG members and their colleagues. The table is not intended to re present 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 info rming the net change in labor burden associated with assessments under the proposed revised TCR.Technology and Cost Document for theA-12Proposed Revised Total Coliform RuleExhibit A-6.2: RTCR Labor Burden Estimate for Assessments done by CWSs serving 1,001 - 4,100Level 1 AssessmentLevel 2 Assessment (nonacute)Level 2 Assessment (acute)Percentage ofSystems doingElementEstimatedHoursAssociatedwith ElementAverageBurdenAssociated withElementPercentage ofSystems doingElementEstimatedHoursAssociated withElementAverageBurdenAssociated withElementPercentage ofSystems doingElementEstimatedHoursAssociated withElementAverageBurdenAssociated withElementGHI = G * HJKL = J * KMNO = M * NNotificationElement100% 2.52.5 100%33 100%33SystemSpecificElement100% 11 100%2.52.5 100%11SampleAnalyticalElement0% 000%000%00SampleMethodologyElement100% 22 100%22 100%22EventSituationalElement100% 5.55.5 100%2.52.5 100%5.55.5OperationalData Element60% 42.4 60%42.4 60%42.4HistoricalTrend Element100% 33 100%33 100%33Sample TapElement100% 22 100%22 100%22Sample SiteElement5% 20.15%20.1 100%1.51.5Sample AreaElement100% 55 100%7.57.5 100%7.57.5Third PartyElement000ReportElement100% 7.57.5 100% 20.5 20.5 100% 20.5 20.5Total3145.548.4Note: Estimates informed by the collective experience and best professional judgment of TCRDSAC TWG members and their colleagues. The table is not intended to representrequired 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 tooccur under the proposed revised TCR for purposes of informing the net change in labor burden associated with assessments underthe proposed revised TCR.Technology and Cost Document for the A-13 Proposed Revised Total Coliform Rule 

### Exhibit A-7.1: Current TCR (as implem ented) 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 bes t professional judgment of TCRDSAC TWG members and their colleagues. The table is not intended to re present 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 info rming the net change in labor burden associated with assessments under the proposed revised TCR.Technology and Cost Document for theA-14Proposed Revised Total Coliform RuleExhibit A-7.2: RTCR Labor Burden Estimate forAssessments done by CWSs serving 4,100 - 33,000Level 1 AssessmentLevel 2 Assessment (nonacute)Level 2 Assessment (acute)Percentage ofSystems doingElementEstimatedHoursAssociatedwith ElementAverageBurdenAssociated withElementPercentage ofSystems doingElementEstimatedHoursAssociated withElementAverageBurdenAssociated withElementPercentage ofSystems doingElementEstimatedHoursAssociated withElementAverageBurdenAssociated withElementGHI = G * HJKL = J * KMNO = M * NNotificationElement100% 33 100%33 100%33SystemSpecificElement100% 1.51.5 100%1.51.5 100%1.51.5SampleAnalyticalElement0% 000%000%00SampleMethodologyElement100% 33 100%33 100%33EventSituationalElement100% 5.55.5 100%77 100%77OperationalData Element75% 43 75%43 75%43HistoricalTrend Element100% 99 100%99 100%99Sample TapElement100% 22 100%22 100%22Sample SiteElement5% 20.15%20.1 100%22Sample AreaElement100% 5.55.5 100%77 100%7.57.5Third PartyElement0 10%109 10.9 10%109 10.9ReportElement100% 8.58.5 100%2222 100%2222Total41.168.570.9Note: Estimates informed by the collective experience and best professional judgment of TCRDSAC TWG members and their colleagues. The table is not intended to representrequired 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 tooccur under the proposed revised TCR for purposes of informing the net change in labor burden associated with assessments underthe proposed revised TCR.Technology and Cost Document for the A-15 Proposed Revised Total Coliform Rule 

### Exhibit A-8.1: Current TCR (as implem ented) 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 bes t professional judgment of TCRDSAC TWG members and their colleagues. The table is not intended to re present 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 info rming the net change in labor burden associated with assessments under the proposed revised TCR.Technology and Cost Document for theA-16Proposed Revised Total Coliform RuleExhibit A-8.2: RTCR Labor Burden Estimate for Assessments done by CWSs serving 33,001 - 96,000Level 1 AssessmentLevel 2 Assessment (nonacute)Level 2 Assessment (acute)Percentage ofSystems doingElementEstimatedHoursAssociatedwith ElementAverageBurdenAssociated withElementPercentage ofSystems doingElementEstimatedHoursAssociated withElementAverageBurdenAssociated withElementPercentage ofSystems doingElementEstimatedHoursAssociated withElementAverageBurdenAssociated withElementGHI = G * HJKL = J * KMNO = M * NNotificationElement100% 66 100%66 100%66SystemSpecificElement100% 1.51.5 100%3.53.5 100%3.53.5SampleAnalyticalElement50% 42 50%42 50%42SampleMethodologyElement100% 44 100%44 100%44EventSituationalElement100% 1010 100%1010 100%1010OperationalData Element75% 14 10.5 75%14 10.5 75%14 10.5HistoricalTrend Element100% 1111 100%1111 100%1616Sample TapElement100% 3.53.5 100%55 100%55Sample SiteElement10% 40.4 10%50.5 10%50.5Sample AreaElement100% 77 100%2121 100%2121Third PartyElement0% 00 10%146 14.6 10%146 14.6ReportElement100% 12.5 12.5 100%2828 100%2828Total68.4116.1121.1Note: Estimates informed by the collective experience and best professional judgment of TCRDSAC TWG members and their colleagues. The table is not intended to representrequired 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 tooccur under the proposed revised TCR for purposes of informing the net change in labor burden associated with assessments underthe proposed revised TCR.Technology and Cost Document for the A-17 Proposed Revised Total Coliform Rule 

### Exhibit A-9.1: Current TCR (as implem ented) 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 bes t professional judgment of TCRDSAC TWG members and their colleagues. The table is not intended to re present 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 info rming the net change in labor burden associated with assessments under the proposed revised TCR.Technology and Cost Document for theA-18Proposed Revised Total Coliform RuleExhibit A-9.2: RTCR Labor Burden Estimatefor Assessments done by CWSs serving > 96,000Level 1 AssessmentLevel 2 Assessment (nonacute)Level 2 Assessment (acute)Percentage ofSystems doingElementEstimatedHoursAssociatedwith ElementAverageBurdenAssociated withElementPercentage ofSystems doingElementEstimatedHoursAssociated withElementAverageBurdenAssociated withElementPercentage ofSystems doingElementEstimatedHoursAssociated withElementAverageBurdenAssociated withElementGHI = G * HJKL = J * KMNO = M * NNotificationElement100% 88 100%88 100%88SystemSpecificElement100% 1.51.5 100%44 100%44SampleAnalyticalElement90% 65.4 90%65.4 90%65.4SampleMethodologyElement100% 55 100%55 100%66EventSituationalElement100% 2020 100% 20.5 20.5 100%2222OperationalData Element100% 14.5 14.5 75% 14.5 10.875 100%2121HistoricalTrend Element100% 23.5 23.5 100% 23.5 23.5 100% 23.5 23.5Sample TapElement100% 9.59.5 100% 18.5 18.5 100% 18.5 18.5Sample SiteElement10% 101 10% 23.5 2.35 10% 23.5 2.35Sample AreaElement100% 47.5 47.5 100%7878 100%7878Third PartyElement0% 00 10%181 18.1 10%192 19.2ReportElement100% 2323 100%4444 100%4444Total158.9238.225251.95Note: Estimates informed by the collective experience and best professional judgment of TCRDSAC TWG members and their colleagues. The table is not intended to representrequired 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 tooccur under the proposed revised TCR for purposes of informing the net change in labor burden associated with assessments underthe proposed revised TCR.