INFORMATION COLLECTION REQUEST FOR NATIONAL PRIMARY DRINKING WATER REGULATIONS: RADIONUCLIDES FINAL Prepared for:

U. S. Environmental Protection Agency 1200 Pennsylvania Ave., N. W. Washington, D. C. 20460 Prepared by:

ISSI Consulting Group 8455 Colesville Road, Suite 915 Silver Spring, MD 20910 EPA Contract No. 68 C7 0005 Work Assignment No. 2 06 September 22, 2000 TABLE OF CONTENTS IDENTIFICATION OF THE INFORMATION COLLECTION 1a Title and Number of the Information Collection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1b Short Characterization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 NEED FOR AND USE OF THE COLLECTION 2a Need/ Authority for the Collection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 2b Practical Utility/ Users of the Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA 3a Nonduplication . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 3b Public Notice Required Prior to Submission to OMB . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 3c Consultations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 3d Effects of Less Frequent Collection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 3e General Guidelines . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 3f Confidentiality and Sensitive Questions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 THE RESPONDENTS AND THE INFORMATION REQUESTED 4a Respondents/ SIC Codes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 4b Information Requested . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 ( i) Data Items ( ii) Respondent Activities ( a) State Activities ( b) Public Water System Activities 4c ICR Approval Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 THE INFORMATION COLLECTED   AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT 5a Agency Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 5b Collection Methodology and Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 5c Small Entity Flexibility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 5d Collection Schedule . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 ESTIMATING THE BURDEN AND COST OF THE COLLECTION 6a Estimating Respondent Burden and Cost . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 ( i) Burden and Cost to PWSs ( a) Start up Activities ( b) Annual Monitoring ( ii) Burden and Cost to States ( a) Start up Activities ( b) Annual Activities 6b Timeframe for Cost and Burden Estimates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 6c Estimating Agency Burden and Cost . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 6d Respondent Universe . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29 6e Bottom Line Burden Hours and Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29 6f Reasons for Change in Burden . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29 6g Burden Statement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 SURVEY INFORMATION LIST OF TABLES Table 1 1. Radionuclides Rule Summary Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 Table 1 2. PWS Monitoring Costs by Radionuclide and Labor . . . . . . . . . . . . . . . . . . . . . . 2 Table 4 1. Revised Radionuclides Federal Reporting Violations . . . . . . . . . . . . . . . . . . . . . 15 Table 4 2: State Rule Implementation and Revision Timetable . . . . . . . . . . . . . . . . . . . . . . 16 Table 4 3. General Radionuclides Monitoring Frequency . . . . . . . . . . . . . . . . . . . . . . . . . . 19 Table 5  1: Public Water System Timetable for the Radionuclides Requirements . . . . . . . . . 24 Table 6 1. Summary of Burden and Costs for the Radionuclides Rule for the ICR Approval Period . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 Table 6 2. Summary of Burden and Costs for the Radionuclides Rule for the Post ICR Approval Period . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 Table 6 3. Average Burden, Respondents, and Responses During the Three Year ICR Approval Period . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29 Table 6 4. Comparison of Monitoring Burden and Costs Associated with 2000 Radionuclides Rule with the 1976 Rule ( Baseline) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 LIST OF EXHIBITS EXHIBIT 1. BURDEN, RESPONDENTS, RESPONSES, AND COSTS FOR THE ICR APPROVAL PERIOD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 EXHIBIT 2. BURDEN ESTIMATES FOR THE ICR APPROVAL PERIOD BY ACTIVITY BY YEAR ( HOURS) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 EXHIBIT 3. RESPONDENT ESTIMATES FOR THE ICR APPROVAL PERIOD BY ACTIVITY BY YEAR ( NUMBER) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35 EXHIBIT 4. RESPONSES ESTIMATES FOR THE ICR APPROVAL PERIOD BY ACTIVITY BY YEAR ( NUMBER) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36 EXHIBIT 5. COST ESTIMATES FOR THE ICR APPROVAL PERIOD BY ACTIVITY BY YEAR ( DOLLARS) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37 EXHIBIT 6. BURDEN, RESPONDENTS, RESPONSES, AND COSTS FOR THE POST ICR APPROVAL PERIOD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38 EXHIBIT 7. BURDEN ESTIMATE FOR THE POST ICR APPROVAL PERIOD BY ACTIVITY BY YEAR ( HOURS) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39 EXHIBIT 8. RESPONDENTS ESTIMATE FOR THE POST ICR APPROVAL PERIOD BY ACTIVITY BY YEAR ( NUMBER) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40 EXHIBIT 9. RESPONSES ESTIMATE FOR THE POST ICR APPROVAL PERIOD BY ACTIVITY BY YEAR ( NUMBER) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41 EXHIBIT 10. COST ESTIMATE FOR THE POST ICR APPROVAL PERIOD BY ACTIVITY BY YEAR ( DOLLARS) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42 LIST OF WORK SHEETS WORKSHEET 1. ASSUMPTIONS AND ANALYSIS FOR PWS START UP ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43 WORKSHEET 2. ASSUMPTIONS AND ANALYSES FOR PWS MONITORING ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45 WORKSHEET 3. ASSUMPTIONS AND ANALYSIS FOR STATE START UP ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46 WORKSHEET 4. ASSUMPTIONS AND ANALYSIS FOR STATE ACTIVITIES RELATED TO MONITORING SUPERVISION . . . . . . . . . . . . . . . . . 49 APPENDIX  FLOW CHARTS AND COST SHEETS FOR MONITORING SCENARIOS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51 1 INFORMATION COLLECTION REQUEST FOR NATIONAL PRIMARY DRINKING WATER REGULATIONS: RADIONUCLIDES SUPPORTING STATEMENT FOR RECORD KEEPING AND REPORTING 1 IDENTIFICATION OF THE INFORMATION COLLECTION 1a Title and Number of the Information Collection Title: Information Collection Request for National Primary Drinking Water Regulations: 2000 Radionuclides Final Rule U. S. EPA Tracking Number: 1972.01 Note: The description of reporting and record keeping burden in this supporting statement covers all that is required for the existing National Primary Drinking Water Regulations for radionuclides and the amendments that will result from the 2000 final rule. These requirements exceed the 3 year approval period for the Information Collection Request ( ICR). For purposes of the ICR approval period, the 3 year costs and burden are described in Section 6, with the supporting tables at the end of the document.

1b Short Characterization This regulation includes information collection requirements for four categories of radionuclide standards: gross alpha ( minus uranium and radon), combined radiums ( 226 and 228), beta/ photon emitters and uranium. Three of these radionuclide standards ( gross alpha particle activity, combined radium 226 and 228, and the beta particle/ photon emitters) have been regulated since 1976. Some of the main elements of the 2000 final radionuclides rule that will subsequently result in information collection include: a maximum contaminant level for ( MCL) uranium, separate monitoring requirements for radium 226 and radium 228 and implementation of entry point monitoring and a standardized monitoring framework ( SMF) scheme. State and local respondents will be required to collect and report information on the levels of radionuclides in drinking water supplies on a quarterly, annual, and in some cases, on a monthly basis. The U. S. Environmental Protection Agency ( the Agency), through the Safe Drinking Water Information System ( SDWIS), uses the information to ensure compliance with these regulations to protect public health.

Monitoring, reporting, and record keeping are required at both the system and State levels under the National Primary Drinking Water Regulations ( NPDWRs) ( § 141.26, § 142.14, § 142.15, § 142.16). All public water systems ( PWSs) must maintain and report to the State information documenting compliance with the treatment and monitoring requirements under the NPDWRs. 2 The radionuclides rule is only applicable to community water systems. States must maintain records sufficient to support program implementation and oversight. Reports provided by States are stored in SDWIS and assist the Agency in evaluating State compliance activities, including the implementation of NPDWRs for radionuclides.

Radionuclide data will be collected under the authority of the Safe Drinking Water Act ( SDWA) and are used by the Agency's Office of Ground Water and Drinking Water ( OGWDW). These data also support analyses for the Agency's Superfund and Resource Conservation and Recovery Act ( RCRA) hazardous waste programs. External agencies, such as the Department of the Interior, U. S. Army Corps of Engineers, State environmental agencies, public interest groups, and private companies, all utilize these data.

This information collection effort will involve 53,121 private sector respondents, 56 public sector respondents, and $ 4.9 million in annual costs ( see Table 1 1). These costs include operational expenditure annualized over 23 years. The start up costs annualized over the first 3 years after promulgation of the final rule are $ 10.2 million. The annualized PWS monitoring costs over 23 years broken out by radionuclide category, are shown below in Table 1 2.

Table 1 1. Radionuclides Rule Summary Costs*

Category 3 Year Total 3 Year Annualized 23 Year Total 23 Year Annualized PWS Start Up $ 26,046,448 $ 9,925,042 PWS Monitoring $ 54,730,515 $ 4,855,439 State Start Up $ 650,578 $ 247,905 State Monitoring $ 718,299 $ 63,723 TOTAL $ 26,697,026 $ 10,172,947 $ 55,448,814 $ 4,919,162 * Present Value at 7% discount rate Table 1 2. PWS Monitoring Costs by Radionuclide and Labor*

Category 23 Year Total 23 Year Annualized Gross Alpha Analysis $ 4,953,727 $ 438,565 Gross Beta Analysis $ 12,833,302 $ 1,138,493 Combined Radiums Analysis $ 29,163,035 $ 2,578,167 Uranium Analysis $ 1,720,814 $ 152,660 Analysis Subtotal $ 48,670,878 $ 4,317,885 PWS Labor $ 6,059,637 $ 537,574 TOTAL $ 54,730,515 $ 4,855,439 * Present Value at 7% discount rate 3 2 NEED FOR AND USE OF THE COLLECTION The following sections describe the need for this information collection and the legal authority under which the information will be collected, as well as identifies the specific uses and users of the data.

2a Need/ Authority for the Collection The information collected under this rule is required by EPA to carry out its monitoring and enforcement responsibilities under the Safe Drinking Water Act. Without comprehensive, upto date information on drinking water contaminants, the Agency would not be able to meet the SDWA statutory requirements. The Act requires that " there must be criteria and standards to assure a supply of drinking water which dependably complies with such maximum contaminant levels; including quality control and testing procedures to insure compliance with such levels and to insure proper operation and maintenance of the system..."

Furthermore, section 1445 of the SDWA requires that " every person who is a supplier of water shall establish and maintain such records, make such reports, conduct such monitoring, and provide such information as the Administrator may reasonably require by regulation to assist him in establishing regulations, in determining whether such person has acted or is in compliance with this title..."

Under the authority of the Safe Drinking Water Act ( SDWA) and its amendments, EPA sets drinking water standards for contaminants, which potentially pose a threat to public health via a public drinking water source. In 1976, EPA promulgated National Interim Primary Drinking Water Regulations ( NIPDWR) for three categories of radionuclides: gross alpha particl activity, combined radium 226 and 228, and gross beta particle and photon radioactivity. The 1976 NIPDWRs for these radionuclides regulated:

° gross alpha at 15 picoCuries per liter ( pCi/ L)( excluding radon and uranium); ° radium 226 and radium 228 combined at 5 pCi/ L; ° and beta/ photon emitters at a 4 millirem dose of radioactivity.

The SDWA Amendments of 1986 required EPA to establish health based regulatory targets, called Maximum Contaminant Level Goals ( MCLGs) and an enforceable standard, the Maximum Contaminant Level ( MCL). In addition, the 1986 amendments identified 83 contaminants for the Agency to regulate, including the currently regulated radionuclides that lacked MCLGs, and two additional radionuclides, uranium and radon. Also, the 1986 amendments declared the 1976 interim standards to be NPDWRs.

On July 18, 1991 ( 56 FR 33050), EPA proposed: 4

A Maximum Contaminant Level Goal ( MCLG) of zero for all radionuclides;

An NPDWR for uranium at 20 ug/ L ( or 30 pCi/ L);

An NPDWR for radon of 300 pCi/ L;

To revise the standards for the combined radiums ( 226 and 228) from an MCL of 5 pCi/ L to a MCL of 20 pCi/ L each;

To revise gross alpha to exclude not only uranium and radon but also radium 226 ( while keeping the gross alpha MCL of 15 pCi/ L);

To revise the MCL for beta/ photon emitters from 4 mrem to 4 mrem ede;

Entry point sampling;

A standardized monitoring framework; and

To extend the applicability of the radionuclide NPDWRs to include Non Transient Non community Water Systems ( NTNCWS).

Comments on the proposed rule were received from approximately 600 individuals and organizations. Due largely to concerns by commenters and Congress over the most effective way to regulate radon, the proposed rule was never finalized. The 1996 reauthorization of the Safe Drinking Water Act withdrew the radon portion of the 1991 radionuclides proposal. In the 1996 amendments, Congress did not specify a new time frame for finalizing rulemaking for the other radionuclides, as it did for radon. Subsequent to the 1996 SDWA amendments, EPA was sued by an Oregon plaintiff ( Bull Run Coalition) for failure to finalize the radionuclides rule. EPA entered into a court stipulated agreement with the Oregon Bull Run Coalition to promulgate a final action for the non radon portion of the 1991 proposal by November 21, 2000.

On April 21, 2000, EPA published a Notice of Data Availability ( NODA) to update the public and the regulated community on issues regarding radionuclides since the publication of the 1991 proposed rule. This notice presented additional information about the occurrence, health effects, and treatment options for radionuclides in drinking water, as well as analytical methods, and monitoring requirements. The NODA also presented data concerning the costs and benefits of several regulatory options for uranium. EPA received approximately 70 comments ( on time and late) in response to the NODA. The additional information and analyses provided in the NODA, as well as public comments, were taken into account as EPA evaluated the 1991 proposal and made the final decisions for the radionuclides NPDWR.

This 2000 radionuclides regulatory action will revise and amend 40 CFR Part 141 ( National Primary Drinking Water Regulations) and Part 142 ( National Primary Drinking Water Regulations Implementation) and includes the following elements:

An MCLG of zero for all radionuclides.

Maintaining the 1976 gross alpha MCL of 15 pCi/ L ( which includes radium 226 and excludes uranium and radon), which is more protective than the 1991 proposed changes.

Maintaining the 1976 MCL of 5 pCi/ L for combined radium 226 and  228, which is more protective than the 1991 proposed changes. 5

Maintaining the 1976 beta particle and photon radioactivity MCL of 4 mrem/ year, which is more protective than the 1991 proposed changes.

An MCL of 30 ug/ L for uranium for community water systems.

Separate monitoring requirements for radium 226 and radium 228.

Maintaining the beta/ photon screening levels set in the 1976 rule for vulnerable systems ( as deemed by the State). Surface water systems serving greater than 100,000 persons will no longer be required to monitor unless they are deemed vulnerable.

Sampling, compliance, and monitoring waivers revised to standardized monitoring framework at entry points to the distribution system. States will have discretion in grandfathering existing distribution system data for determining initial monitoring baselines.

Non transient, non community water systems will not be regulated for radionuclides in drinking water at this time.

2b Practical Utility/ Users of the Data Compliance data collected under this rule will be used by PWSs, State primacy agencies, this Agency, other Federal agencies, public interest groups, and private companies. For PWSs primary uses will include:

determination of system specific water quality improvement needs,

optimization of monitoring schedules and frequencies, and

alerting the public of water quality problems and violations.

States and primacy agencies will utilize the data to monitor the compliance of public water systems with drinking water standards. Data will also be used to keep track of State approvals of plans and specifications, enforcement activities, and variances and exemptions for public water systems. State level planning is enhanced by being able to target PWSs for enforcement actions and remedial actions.

Because the information is captured in SDWIS, it will become available to the general public through the Envirofacts web interface. Federal agencies, scholars, State agencies, private companies, and private citizens can all access this information through the Internet. Geographic and time series research on trends in water quality can be conducted to advance the science of drinking water quality. System level data can be compared and trends associated with individual PWSs can be established. 6 In their regulatory role, the Agency and the States can ask certain key questions:

Is each PWS in compliance with each drinking water standard?

For systems that are not in compliance, why are they not in compliance?

For systems not in compliance, how can compliance be achieved?

What is the threat to public health for a system that is not in compliance?

What are the National, regional, State, and local trends in drinking water quality?

What changes in policy or regulations may be needed to increase compliance?

Is noncompliance a function of location, size, or some other characteristic of a system?

In addition, this information will be useful in satisfying Freedom of Information requests from members of the general public who are often interested in the performance of their local public water systems.

3 NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA 7 The following sections verify and affirm that this ICR satisfies the Office of Management and Budget's ( OMB) collection guidelines, has public support, and does not duplicate another collection.

3a Non duplication The Agency has searched the Federal Information Locator System ( FILS) in an effort to ensure non duplication of the data collection efforts. To the best of the Agency's knowledge, data currently required by this rule are not available from any other source.

3b Public Notice Required Prior to Submission to OMB The Agency published a Proposed Rule for " National Primary Drinking Water Regulations: Radionuclides" in the Federal Register on July 18, 1991 ( 56 FR 33050) and a Notice of Data Availability ( NODA) in the Federal Register on April 21, 2000 ( 65 FR 21576). Comments received on both of these actions are germane and valuable to this ICR. These comments were used in making the final decisions for the this 2000 radionuclides rulemaking.

3c Consultations EPA encourages public input into regulation development. To gather stakeholder input, a Radionuclide Stakeholder Meeting took place on December 11 12, 1997. EPA consulted with a broad range of stakeholders and technical experts. During the meeting, EPA discussed a range of regulation development issues with the stakeholders, including the statutory requirements, court stipulated agreement, MCLs for each of the radionuclides, new scientific information on health effects, occurrence, analytical methods, treatment technologies, and current and proposed monitoring framework. The presentations generated useful discussion and provided feedback to EPA regarding technical issues, stakeholder concerns and possible regulatory options. Participants in EPA's stakeholder meeting included representatives from the Association of Metropolitan Water Agencies ( AMWA), Association of State Drinking Water Administrators ( ASDWA), American Water Works Association ( AWWA), National Association of Water Companies, State departments of environmental protection, State health departments, State drinking water programs, Federal agencies, environmental groups, and city water systems. Meeting notes are available at http:// www. epa. gov/ safewater/ ndwac/ sum_ radn. html. The following is a complete list of the stakeholder participants:

Meeting Attendees Affiliation Brad Addison Georgia Department of Natural Resources/ Environmental Protection Division James Bachmaier US Department of Energy Ambika Bathija EPA Office of Water, Office of Science and Technology Gerald Bever City of DeKalb, IL 8 Teresa Boepple New York State Department of Health, Bureau of Public Water Supply Protection Dori Burg Residents and Children of DeKalb, IL Mitchell Childrey Virginia Department of Health Jeannie Cho Vicki Cochran Kilpatrick Stockton Peter Coon NAWC Richard Cunningham US Department of Energy Miguel Del Toral EPA Region V, Safe Drinking Water Branch Bill Diamond, Director, EPA Office Ground Water and Drinking Water Dennis Duffield City of Joliet Mike Focazio US Geological Survey Harold Fuhrman City of Waukesha Water Utility John Guggi EPA NAREL Baker Hamill Chief, New Jersey Department of Environmental Protection, Bureau of Safe Drinking Water Joseph Harrison Water Quality Association William Roy Harrison US Department of Energy Scott Hay S. Cohen & Associates, Inc.

David Huber EPA Office of Ground Water and Drinking Water Ben Hull EPA Office of Radiation and Indoor Air Amit Kapadia EPA Office of Ground Water and Drinking Water John Karhnak EPA Office of Radiation and Indoor Air James Scott Kirk Nuclear Fuel Services Debbie Kopsick EPA Office of Radiation and Indoor Air Ron Kovach EPA Region V Max Kukoy ASDWA Bill Labiosa EPA Office of Ground Water and Drinking Water Diane Larsen US Department of Energy Patricia Lawson National Safety Council Vicki Lloyd EPA Office of Radiation and Indoor Air Bernard Lucey New Hampshire Department of Environmental Services Frank Marcinowski EPA 9 Corey McDaniel EOP Group Jim McFarland EPA Office of Ground Water and Drinking Water Dr. Neal Nelson EPA Office of Radiation and Indoor Air Erik Olson Natural Resources Defense Council Mike Osinski EPA Office of Ground Water and Drinking Water Marc Parrotta EPA Office of Ground Water and Drinking Water Glenn Patterson US Geological Survey David Pauel EPA Office of Radiation and Indoor Air Dan Pedersen American Water Works Association Pat Phibbs Environmental Health Letter Stephen Pia EPA Office of Research and Development/ ESD Dawn Porto Designers & Planners Jerry Puskin EPA Office of Radiation and Indoor Air Lowell Ralston EPA Office of Radiation and Indoor Air Edward Regnier US Department of Energy Nancy Reilman Maryland Department of the Environment Edward Regnier DOE Waste Management Unit David Robbins EPA Region 8 Dr. Robert Rowland Waukesha Water Utility System Tom Schaeffer AMWA Roger Selburg Illinois EPA, DPWS Shantini Senanjahe Nancy Stanley New Jersey Department of Environmental Protection, Radiation Protection Programs Todd Steiner International Consultants, Inc.

Katie Sweeney National Mining Association Zoltan Szabo US Geological Survey Mark Thaggard US Nuclear Regulatory Commission Chao Hsiung Tung SAIC Sherri Umansky EPA, Office of Ground Water and Drinking Water Pat Ware Bureau of National Affairs Michael Weber US Nuclear Regulatory Commission Corry Westbrook EPA, Office of Ground Water and Drinking Water 10 Jim York ASE, Inc.

Conference Call Participants Sylvia Barrett Metropolitan Water District of Southern California Jennifer Cox South Carolina Drinking Water Program Thomas DeGaetano EPA Region IV Peter Denk Daily Chronicle Jacob Dumelle American Lung Association of Chicago Julia Fauci Northern Illinois University John Hepperley Janet Johnson Shepard Miller, Inc.

Linda Lahey Ellen Partridge Partridge & Niro Fred Pontius AWWA Dr. Terry Sandman Jane Smith Indiana State Department of Health Gene Taylor EPA Region X In addition to the 1997 stakeholder meeting, the Office of Ground Water and Drinking Water ( OGWDW) staff gave presentations on the radionuclides regulation at meetings sponsored by AWWA, ASDWA, and EPA State/ Regional conferences, and met with States from Regions 2, 3, 7, and 8 regarding radionuclides issues and the upcoming final rule. The staff participated in AWWA's Technical Advisory Workgroup ( TAW), which meets annually to discuss technical issues including treatment, occurrence, and health risks. State public health department and drinking water program representatives, large and small drinking water districts participated in TAW meetings. The OGWDW staff also held frequent conference calls with interested State drinking water programs about the development of the rule. The staff made presentations and received input at Tribal meetings in Nevada, Alaska, and California. Finally, a one day meeting was held with associations that represent State, county, and local government elected officials on May 30, 2000 to discuss five upcoming drinking water regulations, including radionuclides.

Stakeholders were also asked to comment on a variety of issues in the April 21, 2000 Notice of Data Availability. The feedback received from the stakeholders during all these meetings and comments from the NODA were used in developing the final 2000 radionuclides rule.

3d Effects of Less Frequent Collection The Agency has determined that less frequent data collection may fail to identify significant contaminant concentrations in a timely manner. Such concentrations may threaten the 11 health and safety of drinking water consumers. The Agency believes it has considered a wide range of alternatives in terms of the frequency and burden of data collection. It has selected the approach requiring the least possible frequency consistent with contaminant monitoring requirements.

3e General Guidelines The Radionuclides Rule complies with the guidelines ( 5 CFR 1320.5( d)( 2)) implemented under the Paperwork Reduction Act. In addition, this rule does not alter existing record maintenance requirements that require records of chemical analyses be kept for not less than 10 years, and records of actions taken by a PWS to correct violations of NPDWRs be kept for a period of not less than three years.

3f Confidentiality and Sensitive Questions This data collection effort does not raise confidentiality issues or ask sensitive questions concerning sex behavior or attitudes, religious beliefs, or other personal matters.

4 THE RESPONDENTS AND THE INFORMATION REQUESTED The following sections provide information on the respondents and the information they are being requested to provide. 12 4a Respondents/ SIC Codes Under this rule, respondents to the monitoring, reporting, and record keeping requirements include the owners and operators of PWSs that are more specifically, community water systems. Respondents also include State officials who must report data to the Agency. The Standard Industrial Classification ( SIC) code for investor owned water systems is 4941 and the SIC code for both publically owned water systems and State agencies is 9511.

PWSs are defined as those systems that provide piped water for human consumption and have at least 15 service connections or regularly serve at least 25 people at least 60 days per year. A community water system is one that serves at least 15 connections used by year round residents or regularly serves at least 25 year round residents. By definition, all other PWSs are noncommunity systems. Non community systems include transient systems and non transient systems. Non transient systems serve the same 25 people at least six months per year. ( See 40 CFR 141.2.)

The radionuclides rule is only applicable to community water systems. At this time, transient and non transient non community water systems ( NTNCWSs) will not be covered by these regulations. The Agency does not have sufficient information to consider regulating these water systems at a national level.

4b Information Requested ( § 142.14 and § 142.15 )

The following sections provide details on data items requested and associated activities respondents will be required to undertake to provide this information.

4b( i) Data Items Currently, § 142.14 of the regulations already require States with primacy enforcement responsibility to keep records of analytical results to determine compliance, system inventories, sanitary surveys, State approvals, vulnerability determinations, monitoring requirements, monitoring frequency decisions, enforcement actions, and the issuance of variances and exemptions. The aforementioned data items are already required for gross alpha particle activity, combined radium 228 and 226, and beta particle and photon radioactivity. The current rule already require the following records to be for radionuclides:

Any determination of a system's vulnerability to contamination by beta and photon emitters ( § 142.14( d)( 4)); and

Any determination that a system can reduce or increase monitoring frequency for gross alpha particle activity, gross beta particle and photon radioactivity, radium 13 226 and 228. The records must include the basis for the decision, and the repeat monitoring frequency ( § 142.14( d)( 5)).

Since uranium is a newly regulated radionuclide, records will need to be kept for uranium as well. Since these requirements are generally included in 142.14( d)( 4) and ( 5), revisions under the current rule will not necessary.

Currently, States must report to EPA information under 40 CFR 142.15 regarding violations, variances and exemptions, enforcement actions and general operations of State public water supply programs. Under sections 142.15( c)( 6) and ( 7) of today's rule, the States are required to provide the following additional information to EPA:

A list of community water systems the State assessed to determine their vulnerability to contamination by beta particle and photon radioactivity, the dates of the assessments, the results of the assessments, and the basis for the State's determination as to whether or not a system is vulnerable; and

A list of community water systems for which the State is requiring repeat monitoring for gross beta particle and photon radioactivity, the results of the assessment, and the basis for that determination.

4b( ii) Respondent Activities Respondents to this rule include States and PWSs. In this rule, the Agency is adding new record keeping and reporting requirements for States and PWSs due to the new uranium standard, separate monitoring for radium 226 and 228 and changes in the monitoring frequency. These new requirements are discussed in sections below.

4b( ii)( a) State Activities State officials serve in the role of respondents when reporting compliance data to the Agency. States are currently required to maintain records of State verification activities and for each determination made, report to the Agency ( § 142.15) in accordance with the SDWA, through SDWIS.

States with primacy act as the Agency in ensuring implementation of the radionuclides rule. To successfully meet their responsibilities, States will engage in the following activities:

regulation, adoption and program development;

coordination and data reporting to the Agency;

formal enforcement, including the certification of laboratories, as well as on going technical assistance and compliance verification;

vulnerability assessments;

notification to PWSs of requirements; 14

on going, rule specific training for drinking water staff and PWS staff;

data management, system maintenance and enhancements;

monitoring compliance schedule development and statusing;

laboratory and testing capacity expansion, training, and regulatory enforcement;

treatment and construction plan review and approvals; and,

data entry and record keeping.

Detailed below are descriptions of the specific State activities which are currently required for radionuclides and any additional requirements which result from this final rule.

State Record keeping Requirements Currently, § 142.14 of the regulations already require States with primacy enforcement responsibility to keep records of analytical results to determine compliance, system inventories, sanitary surveys, State approvals, vulnerability determinations, monitoring requirements, monitoring frequency decisions, enforcement actions, and the issuance of variances and exemptions. The aforementioned data items are already required for gross alpha particle activity, combined radium 228 and 226, and beta particle and photon radioactivity. The current rule already require the following records to be for radionuclides:

Any determination of a system's vulnerability to contamination by beta and photon emitters § 142.14( d)( 4)); and

Any determination that a system can reduce or increase monitoring frequency for gross beta, radium 226 or 228 or increase monitoring frequency. The records must include the basis for the decision, and the repeat monitoring frequency ( § 142.14( d)( 5)).

Since uranium is a newly regulated radionuclide, records will need to be kept for uranium as well. Since these requirements are generally included in 142.14( d)( 4) and ( 5), revisions under the current rule will not necessary.

State Reporting Requirements As required by 142.15, States with primacy enforcement responsibility are required to submit quarterly reports to the Agency on:

new violations by PWSs that occurred during the previous quarter;

new enforcement actions that occurred during the previous quarter;

variance and exemptions that have been granted and the reasons for granting them. 15 On an annual basis, States are required to submit reports on the additions or corrections to the States inventory of PWSs and the status of variance and exemptions.

The Safe Drinking Water Information System/ Federal Version ( SDWIS/ FED) is an Environmental Protection Agency ( EPA) database which stores basic information about the nation's drinking water supply. The information in SDWIS/ FED comes from the States and EPA's regional offices and is reported for every PWS in the United States. States report information quarterly to EPA on whether any PWSs have violated these standards. SDWIS/ FED contains basic information on every public water system, including, but not limited to:

the name of the public water system

information about the type of area served by the water system ( e. g., households, schools, restaurants, gas stations, or rest areas)

how many people the water system serves and its operating season ( year round or seasonal)

who regulates the water system ( typically, states regulate systems within their jurisdictions; EPA currently regulates Tribal systems and systems in Wyoming)

when ( or if) a water system has violated any national drinking water standard

what ( if any) follow up actions, including enforcement actions, have been taken to make sure the water system returns to compliance following a violation.

Table 4 1 is a summary of SDWIS/ FED reporting requirements specific to this radionuclides. The summary contains SDWIS/ FED violation and contaminant codes. The violation summary table only lists potential Federal violations.

Table 4 1. Revised Radionuclides Federal Reporting Violations Contaminant Code Contaminant Violation 4000 Gross Alpha 01, 02, 03, 06 4010 Combined Radium ( 226 & 228) 01, 02, 03, 06 4006 Uranium 01, 02, 03, 06 4101 Man Made Beta Particle and Photon Emitters 01, 02, 03, 06 4102 Tritium 02, 03, 06 4174 Strontium 90 02, 03, 06 4264 Iodine 131 02, 03, 06 4270 Cesium 134 02, 03, 06 4172 Strontium 89 02, 03, 06 Note: Violation Types and Definitions 01  MCL, Single Sample 02  MCL, Average 03  Failure to Monitor/ Report 06  Failure to Provide the Appropriate Public Notification 16 Primacy Revision Applications Pursuant to 40 CFR § 142.12, Revision of State Programs, complete and final requests for approval of program revisions to adopt new or revised Agency regulations must be submitted to the Administrator no later than 2 years after promulgation of the new or revised federal regulations ( see Table 4 2). Until those applications are approved, EPA Regions have responsibility for directly implementing the Radionuclides Rule. The State and the Agency can agree to implement the rule together during this period. However, if a State is eligible for interim primacy, once it submits a complete and final revision package, it will have full implementation and enforcement authority. A State may be granted additional time, up to two years, to submit its application package. During this period, a Memorandum of Understanding ( MOU) outlining the State's and the Agency's responsibilities is required.

Table 4 2: State Rule Implementation and Revision Timetable EPA/ State Action Time Frame*

Rules published by EPA November 2000 State and Region establish a process and agree upon a schedule for application review and approval April 2001 State, at its option, submits draft program revision package including: Preliminary Approval Request Draft State Regulations and/ or Statutes Regulation Crosswalk August 2001 Regional ( and Headquarters if necessary) review of draft Completed within 90 days of State submission of Draft State submits final program revision package including: Adopted State Regulations Regulation Crosswalk 40 CFR 142.10 Primacy Update Checklist 40 CFR 142.14 and 142.15 Reporting and Record keeping 40 CFR 142.16 Special Primacy Requirements Attorney General's Enforceability Certification November 2002**

EPA final review and determination: Regional review ( program and ORC) Headquarters concurrence and waivers ( OGWDW, OECA, OGC) Public Notice Opportunity for hearing EPA's Determination Completed within 90 days of State submittal of final 45 days Region 45 days Headquarters Rule Effective Date 3 years after publication ( November 2003)

* Timetable is based on a projected promulgation date of November 2000 for the final rule. ** An extension of up to 2 additional years may be requested by the State. 17 The approval of State program revisions is recommended to be a two step process comprising submission of a draft request ( optional) and then submission of a complete and final request for program approval.

Draft Request C At the State's option, it may submit a draft request for EPA review and tentative determination. The request should contain drafts of all required primacy application materials. A draft request should be submitted within 9 months after rule promulgation. EPA will make a tentative determination on whether the State program meets the applicable requirements. The tentative determination should be made within 90 days.

Complete and Final Request C This submission must be in accordance with § 142.12( c)( 1) and ( 2) and include the Attorney General's statement. The State must also include its response to any comments and/ or program deficiencies identified in the tentative determination ( if applicable). Regions should make States aware that submission of only a final request may make it more difficult for the States to address any necessary changes within the allowable time for State rule adoption.

EPA requests that States submit their complete and final revision package within 21 months of rule promulgation. This will ensure that States will have interim primacy within 24 months and will prevent States from becoming backlogged with revision applications to adopt future federal requirements. The State and Region should agree to a plan and timetable for submitting the State primacy revision application as soon as possible after rule promulgation C ideally within 5 months of promulgation.

4b( ii)( b) PWS Activities Each PWS is required to take samples at intervals specified in this rule and keep records of the data obtained during sampling. Owners and operators of PWSs are required to report laboratory results to the State ( or to the Agency in non primacy States) at frequencies specified in the Federal and State regulations implemented under the SDWA. In general, each PWS will be involved in the following activities:

reading this rule;

planning activities as required by this rule;

training staff;

gathering information by identifying sample sites and taking samples;

gathering information by conducting tests on samples collected;

processing, compiling, and reviewing information collected;

developing and distributing public notices when violations occur;

producing and submitting reports and other documentation; and,

recording and maintaining the information in accordance with record keeping requirements. 18 Detailed below are descriptions of the specific PWS activities that will occur with implementation of this rule.

PWS Monitoring ( 40 CFR § 141.26 ( a) and ( b))

Under the 1976 rule, CWSs were required to monitor and comply with the MCLs for gross alpha particle activity ( minus uranium and radon), combined radium 226 and 228, and the beta particle and photon emitters. To be consistent with other SDWA analytes ( i. e. the chemical analytes), this 2000 radionuclides rule will implement a standard monitoring framework ( SMF) for the currently regulated gross alpha particle activity and combined radium 226/ 228 standards and the new uranium standard. Also, whereas the 1976 rule required samples to be taken in the distribution system, this final rule will require samples to be taken at the entry point to the distribution system. In addition, this final rule will require separate monitoring for radium 226 and radium 228 to determine compliance with the combined radium standard.

Monitoring for radionuclides is complex, in part, because of the inter relationship of the analytes ( i. e., the alpha emitters, radium 226, and uranium contribute to gross alpha activity). Due to this relationship, results from gross alpha and gross beta monitoring can be used as a trigger to guide other monitoring. Table 4 3 summarizes the monitoring framework for radionuclides that incorporates the Standard Monitoring Framework that allows reduced monitoring under conditions where it safe to do so. Through initial monitoring, or the use of historic data ( some of which may be formally grandfathered), public water systems can determine their reduced monitoring frequency for gross alpha, combined radiums and uranium. Vulnerable systems, which have to monitor for beta/ photons, is not allowed to reduce the monitoring frequency.

Ideally, a system would establish initial compliance by collecting 4 consecutive quarterly samples for gross alpha, radium 226, radium 228, and uranium concurrently, at each entry point to the distribution system ( EPTDS), during the initial round of monitoring. The annual average of the quarterly results will determine a system's reduced monitoring frequency. The results from the initial sampling can be used to establish its continuing ( repeat) monitoring framework.

Table 4 3. General Radionuclides Monitoring Frequency Routine ( Initial) Reduced ( Repeat)

GROSS ALPHA PARTICLE ACTIVITY CWSs: Four consecutive quarters of monitoring at each entry point, anytime during first 3 years. Systems will be allowed to substitute historical distribution point data, in some cases, to determine if they can go to reduced monitoring. Compositing will be allowed. CWSs: One sample every three years if previous monitoring is reliably and consistently at or below MCL; one sample every six years if previous results are reliably and consistently at or below ½ MCL; or one sample every nine years if previous monitoring results are reliably and consistently at or below the detection limit ( DL). 19 COMBINED RADIUM 226 AND 228 CWSs: If the system has no data for Ra 228, the system will be required to meet the 4 quarterly sample requirement to determine the baseline. For radium 226, as with the 1976 rule, a system can substitute the gross alpha value for the radium 226 measurement or measure 226 specifically. Systems will be allowed to use historical data, if available. To reduce burden, after adding the radium 228 and 226 results, if the first two quarters are less than 50% of the combined MCL, then the system may be immediately be placed into the " once every six years" category; if the first two results are less than the regulatory detection limit, the system may be placed immediately into the " once every nine years" category. Compositing will be allowed as long as a system can meet the DL. CWSs: One sample every three years if previous monitoring is reliably and consistently at or below MCL; one sample every six years if previous results are reliably and consistently at or below ½ MCL; or one sample every nine years if previous monitoring results are reliably and consistently at or below the DL.

URANIUM CWSs: Four consecutive quarters of monitoring for uranium any time during first 3 years. Gross alpha will be allowed to substitute for uranium when gross alpha values are less than 30 pCi/ L. If gross alpha is > 15 pCi/ L, systems already check for uranium. Grandfathering data and compositing will be allowed. CWSs: One sample every three years if previous monitoring is reliably and consistently at or below MCL; one sample every six years if previous results are reliably and consistently at or below ½ MCL; or one sample every nine years if previous monitoring results are reliably and consistently at or below the DL.

BETA AND PHOTON EMITTERS Vulnerable CWSs ( as designated by the State): Two gross beta screening levels depending on location from an emitting source or whether a system is using a contaminated source. Systems within 15 miles of a radioactive source, use a screen of 30 pCi/ L; quarterly monitoring for gross beta required, along with annual monitoring for tritium and strontium 90. If quarterly average > 30 pCi/ L, speciate for radioactive constituents. Systems using radioactive contaminated source, use screen of 15 pCi/ L; quarterly monitoring for gross beta and I 131 required, H 3 and Sr 90 annually. If quarterly > 15, analyze for Sr 89 and Cs 134; if > 30, speciate for radioactive constituents. Vulnerable systems only ( as designated by the State): Since only vulnerable systems are required to monitor, no reduced monitoring is allowed.

Grandfathering of data: Since gross alpha particle activity, combined radium 226 and 228, and beta particle and photon emitters have been regulated since 1976, many systems have historic data that can be used as an indicator of the most likely radionuclide activity levels. Many systems that have had gross alpha levels greater than 15 pCi/ L and had to determine their adjusted gross alpha to demonstrate compliance already have historic data on uranium as well. Depending on the concentrations of this historical data, systems may opt to collect some or all of these samples to determine the reduced monitoring frequency. This will save systems some monitoring expense and burden. 20 Compositing: Systems will still be allowed to composite ( over time or temporally) their gross alpha particle activity, radium 226, radium 228, and uranium samples.

PWS Record keeping Requirements In addition to the record keeping requirements that are already required for the currently regulated categories of radionuclides, the standard record keeping requirements for PWSs monitoring programs under the SDWA still apply to the revisions to the radionuclides. ( 40 CFR § 141.33, Records Maintenance).

Records of analyses should be kept for at least 10 years. Data may be kept as laboratory reports, or can be transferred to tabular summaries including the date, place, and time of sampling; the name of the person who collected the sample; identification of the sample as a routine distribution system sample, check sample, raw or process water sample, or other special purpose sample; date of analysis; laboratory and person responsible for performing analysis; the analytical technique/ method used; and the results of the analysis.

Records of action taken by the system to correct violations of primary drinking water regulations must be kept for at least 3 years after the last action taken with respect to the particular violation involved.

Records concerning a variance or exemption granted to the system must be kept for at least 5 years following the expiration of such variance or exemption. PWS Reporting Requirements Reports to the State: The standard reporting requirements for PWS monitoring programs under the SDWA already apply to the currently regulated radionuclides. The reporting requirements will apply to the 2000 revisions to radionuclides. A water supplier must report analysis results to the State within either the first 10 days following the month in which the result is received, or the first 10 days following the end of the required monitoring period, as stipulated by the State, whichever of these is shorter. The water supplier must report to the State within 48 hours the failure to comply with any NPDWRs ( including failure to comply with monitoring requirements). The water supplier is not required to report analytical results to the State in cases where a State laboratory performs the analysis and reports the results to the State office. The water supply system, within ten days of completion of each public notification required pursuant to SDWA § 141.32, must submit to the State a representative copy of each type of notice distributed, published, posted, and/ or made available to the persons served by the system and/ or to the media. The water supply system must submit to the State within the time stated in the request copies of any records required to be maintained under SDWA § 141.33 hereof or copies of any documents then in existence which the State or the Administrator is entitled to inspect pursuant to the authority of SDWA § 1445 of the Safe Drinking Water Act or the equivalent provisions of State law.

4c ICR Approval Activities 21 The preponderance of the burden associated with this rule does not occur during the first three years after promulgation ( ICR approval period). Typically, the activities that will occur during this ICR approval period will include the following:

reading the rule;

statutory and regulatory adoption;

planning and budgeting for the program;

training personnel to implement the program;

acquiring equipment, materials, and other supplies;

updating public information notifications;

laboratory expansions and certifications;

technical assistance and development of guidance and training materials;

reviewing plans and specifications; and

enforcement staff training.

Burden and cost estimates associated with both the ICR Approval Period and the post ICR approval period are provided in Exhibits 1 and 6, respectively, presented at the end of this ICR. 22 5 THE INFORMATION COLLECTED   AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT The following sections describe the Agency's activities related to analyzing, maintaining, and distributing the information collected.

5a Agency Activities The Agency will be responsible for promulgating this rule and overseeing its implementation. Implementation of monitoring requirements will rely extensively on State governments in those States that have assumed primacy under the SDWA. The Agency will be involved in the following activities:

Developing this rule and guidance materials;

Reviewing and analyzing data submissions from the States; and,

Processing and maintaining SDWIS.

5b Collection Methodology and Management No specific requirements on information collection methodology and management are mandated in this rule. PWSs are expected to be responsible for validating the information collected.

5c Small Entity Flexibility The Regulatory Flexibility Act requires the Agency to explicitly consider the effects of regulations on small entities and develop a regulatory flexibility analysis ( RFA) describing these impacts. For the purposes of this rule, the Agency defines small entities as PWSs that serve fewer than 10,000 people. The Agency regards any impact on small entities as significant.

It is believed that the provisions of these regulations intended to minimize the burden on all PWSs will significantly reduce the burden on small water systems. A RFA incorporated in the Health, Risk Reduction, and Cost Analysis ( HRRCA) supporting this rule describes the steps considered by the Agency to minimize the burden on small entities. These provisions are described below.

Minimizing Burden The Agency is promulgating monitoring requirements that meet the goal of achieving compliance and providing efficient use of the State and PWS resources to decrease the overall national costs of this rule. The Agency has taken steps to minimize the burden on PWSs. These measures include the following:

Designating sampling locations and frequencies that permit simultaneous monitoring for all regulated contaminants whenever possible and advantageous. 23

Using recent monitoring data in lieu of conducting initial monitoring for systems that are currently conducting a monitoring program using reliable methods.

Allowing States to use historical monitoring data reflecting and other available records to make decisions regarding vulnerability.

Providing latitude to the States to target monitoring efforts based on the vulnerability of the system to a particular contaminant if its occurrence is not widespread, thus avoiding unnecessary monitoring efforts.

Reducing the frequency of monitoring for systems that obtain occurrence data consistently and reliably below MCLs.

Allowing the compositing of gross alpha and uranium samples.

Allowing initial monitoring to be phased in over the first three year compliance cycle in order to allow States enough time to obtain necessary resources.

Consideration of Alternatives The Agency developed and considered several alternatives for each of the key provisions of the final rule. The development and evaluation of alternatives included the following tasks:

Examination of available analytical methods for assessing compliance with MCLs and/ or performance requirements to determine whether they were economically and technologically feasible;

Identification of pertinent compliance monitoring issues;

Evaluation of available occurrence data to determine the adequacy of existing interim drinking water regulations for radionuclides;

Requesting comments from water systems, State regulators, and the scientific community to redefine alternatives and select the proposed requirements; and,

Projecting costs and burden associated with the monitoring requirements.

5d Collection Schedule The Agency has considered a wide range of alternatives for frequency of data collection, and has chosen the option requiring the least frequent collection possible while still remaining consistent with its overall monitoring objectives. Where possible, State discretion in adjusting these 24 frequencies has been allowed. Monitoring frequencies for public water systems have been carefully devised based on the following factors:

type of contaminant;

type and size of system;

system vulnerability; and

contaminant occurrence history.

As described in Section 4 of this ICR, this proposed rule applies the Standard Monitoring Framework ( SMF) to monitoring and allows for reduced monitoring under conditions where the health and safety of the public is reasonably assured.

The effective date for the revised radionuclides drinking water regulation is November 2003 and all systems must complete the initial monitoring requirements by December 31, 2007. The timetable and key dates for the Radionuclides Regulation are presented in Table 5 1. The table is based on a promulgation date of November 2000 for the radionuclides final rule.

Table 5  1: Public Water System Timetable for the Radionuclides Requirements Actual or Potential Date Radionuclides Rule Action or Requirements July 9, 1976 Radionuclides Drinking Water Regulation Final Rule July 18, 1991 Revised Radionuclides Proposed Rule June 24, 1996 Data collected at the entry point to the distribution system after 6/ 96 can be used as grandfathered data to satisfy the initial monitoring requirements for gross alpha, radium 226/ 228 and uranium. ( Note: All systems with 1 EPTDS can use grandfathered data at the States discretion.)

April 21, 2000 Revised Radionuclides Notice of Data Availability ( NODA).

Nov. 2000 Revised Radionuclides Final Rule.

Nov. 2002 State primacy revision application package due.

Nov. 2003 Rule effective date.

Nov. 2004 State primacy revision application package due for those States requesting 2 year extensions.

Jan 1, 2005 All systems must begin initial monitoring.

Dec 31, 2007 All systems must complete initial monitoring.

If the rule is finalized in November of 2000, enforcement of the new monitoring requirements would begin in November of 2003. If the Agency implements a one year extension, water systems would have until November of 2007 to complete the required initial monitoring. This 25 would allow for the " one third of systems per year" strategy in the SMF, while allowing one additional year to address laboratory capacity issues. 26 6 ESTIMATING THE BURDEN AND COST OF THE COLLECTION The following sections discuss costs and burden for monitoring requirements associated with this rule.

6a Estimating Respondent Burden and Cost The following sections discuss and compare the costs and burden faced by the States and PWSs . This analysis also separates the start up activities from the routine, annual monitoring activities.

Table 6 1 provides a summary of the total respondents, responses, burden and costs associated with the implementation of this rule for PWSs and States associated with the ICR approval period. The figures in this table are disaggregated by year in Exhibit 1, which in turn is supported by Exhibits 2, 3, 4, and 5 presented at the conclusion of this ICR.

Table 6 1. Summary of Burden and Costs for the Radionuclides Rule for the ICR Approval Period Respondent Category Number of Respondents Annually Number of Responses Annually Total Annual Burden Total Annual Labor Costs Total Annual Capital Cost Total Annual O& M Cost PWSs 53,121 ( preparation only) 336,433 $ 9,925,042 0 0 States 56 33 ( 2 per respondent over 3 year period) 6,440 $ 247,905 0 0 TOTAL 53,177 33 342,873 $ 10,172,947 0 0 Table 6 2 provides a summary of the total respondents, responses, burden and costs associated with the implementation of this rule for PWSs and States associated with the post ICR approval period. The figures in this table are supported by Exhibit 6, which in turn is supported by Exhibits 7, 8, 9, and 10 presented at the conclusion of this ICR. 27 Table 6 2. Summary of Burden and Costs for the Radionuclides Rule for the Post ICR Approval Period Respondent Category Number of Respondents Annually Number of Responses Annually Total Annual Burden ( hours) Total Annual Labor Costs Total Annual Capital Cost Total Annual O& M Cost ( Monitoring)

PWSs 53,121 50,394 25,197 $ 537,574 0 $ 4,855,439 States 56 224 4,170 $ 63,723 0 $ 63,723 TOTAL 53,177 50,618 29,367 $ 601,297 0 $ 4,919,162 ( i) Burden and Cost to PWSs The sections below describe the activities and other assumptions that affect the burden and cost analysis for PWSs provided in Tables 6 1 and 6 2.

( a) Start up Activities Start up activities for PWS include reading the final rule to become familiar with the requirements and training staff to perform the required activities. Since States will be mainly responsible for understanding and adopting these regulations and for notifying PWSs of specific rule requirements, especially small systems, PWSs are believed to bear a relatively moderate burden and cost in conducting these activities.

For PWSs, labor costs per hour are assumed to range from $ 32 for supervisory staff to $ 18 for an administrative assistant in year 2000 dollars. Labor costs of reading and training are estimated by multiplying the hours estimated to read the rule and train staff by each labor category to estimate the cost per system. This number was then multiplied by the number of systems expected to have to change their monitoring requirements under this rule. ( See Worksheet 1)

( b) Annual Monitoring Monitoring activities for PWSs will begin three years following promulgation of the rule. Thus there will be no monitoring burden or cost during the ICR approval period.

Monitoring costs during the post ICR approval period represent the burden and cost incurred by implementing this rule, and do not include existing monitoring efforts. ( See Worksheet 2) 28 ( ii) Burden and Cost to States The sections below describe the activities and other assumptions that affect the burden and cost analysis for States provided in Tables 6 1 and 6 2.

( a) Start up Activities State start up costs are more extensive than for PWSs, since States must implement the rule. State start up costs are estimated using labor hour assumptions for each anticipated activity. One FTE is assumed to work 1,680 person hours per year. The number of labor hours estimated for each activity is multiplied by the appropriate labor rate to obtain the start up costs. ( See Worksheet 3)

( b) Annual Activities States will begin annual activities when PWSs begin monitoring. State costs and burden for annual activities are calculated on the basis of the number of analyses that the States will be supervising. State activities consist primarily of keeping records received from PWSs and coordinating activities with the Agency. States must also submit information to SDWIS to assist both the Agency and States in tracking PWS compliance. ( See Worksheet 4)

6b Timeframe for Cost and Burden Estimates The effective date for the revised radionuclides drinking water regulation is November 2003 and all systems must complete the initial monitoring requirements by December 31, 2007, based on a promulgation date of November 2000 for the radionuclides final rule. If the rule is finalized in November of 2000, enforcement of the new monitoring requirements would begin in November of 2003. If the Agency implements a one year extension, water systems would have until November of 2007 to complete the required initial monitoring. All PWSs will have begun monitoring by January 1, 2005, and all PWSs will have completed initial monitoring by December 31, 2007.

States will begin their start up activities in Year 1 ( November 2000 to October 2001) in order to be prepared to regulate the monitoring activities that will begin in Year 4 ( starting November 2003). State annual cost and burden are assumed to be incurred in the same schedule and proportion as PWS monitoring during the transition period between 2004 and 2007.

6c Estimating Agency Burden and Cost Agency costs include those incurred by regional offices and headquarters to process, analyze, and maintain SDWIS for the additional information generated by this rule. This additional cost is not believed to be significant relative to the overall level of effort for all other monitored contaminants.

6d Respondent Universe 29 There are approximately 53,121 PWSs and 56 States and Territories considered in this Information Collection Request.

6e Bottom Line Burden Hours and Costs Table 6 3 presents the average annual respondent burden over the three year ICR approval period for PWSs and States.

Table 6 3. Average Burden, Respondents, and Responses During the Three Year ICR Approval Period PWSs States TOTAL Average Burden Hours per Year 336,433 6,440 342,873 Average Respondents per Year 53,121 56 53,177 Average Burden Hours per Respondent per Year 6 115 121 Average Responses per Year 0 ( preparation only) 33 33 Average Burden Hours per Response per Year 0 ( preparation only) 17 17 Average Responses per Respondent per Year 0 ( preparation only) .66 ( 2 over 3 year period) .66 6f Reasons for Change in Burden National burden estimates increase because of the preparation costs borne by States and PWSs for the new rule ( displayed previously in Figure 6 1), and three monitoring requirements under the 2000 final radionuclides rule ( see Table 6 4):

° the requirement for separate monitoring of radium 228 and radium 226 ( § 141.26( a)) ° the adoption of the uranium MCL of 30 ug/ L ( § 141.66( e)) and its monitoring requirements ( § 141.26( a)); and 30 ° the requirement for entry point monitoring as part of the standard monitoring ( § 141.26 ( a) and ( b)).

To alleviate much of the burden associated with these changes, the Agency is allowing grandfathering for many systems which have historical data [ § 141.26( a)( 2)( ii)], compositing for certain categories of radionuclides [ § 141.26( a)( 4)] and a gross alpha screen to substitute ( under some circumstances) for uranium [ § 141.26)( a)( 8)]. In order to determine compliance with gross alpha ( excluding radon and uranium), many systems which had a gross alpha value greater than 15 pCi/ L will also have historical data on uranium. These systems will be allowed ( with State discretion) to grandfather this uranium data.

It should be noted that the 1993 Public Water Supply Supervision Program ICR estimated annual burden and cost for radionuclides at 5,637 hours and $ 594,790. For this ICR and for comparison, the burden and costs for the current rule ( 1976) were recalculated to establish a more detailed baseline. The recalculated 1976 baseline burden and cost are shown in Table 6 4 After adjustment of the radionuclides portion of the programmatic ICR to year 2000 dollars ($ 678,061), this ICR estimates the 1976 baseline ($ 2,004,674) to be above the values calculated in the programmatic ICR.

6g Burden Statement The annual burden for this Information Collection Request is estimated to be 19 hours per PWS respondent and 345 hours per State for the three year ICR approval period ( 2001 2003), including time for reading and reviewing the rule and training the staff necessary to comply with the rule.

Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, disclose, or provide information to or for a Federal agency. This includes the time needed to review instructions; adjust the existing schedule to comply with any previously applicable instruction and requirements; train personnel to be able to respond to the information collection requirements; and, transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The OMB control numbers for the Agency's regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15. 31 Table 6 4. Comparison of Monitoring Burden and Costs Associated with 2000 Radionuclides Rule with the 1976 Rule ( see Appendix for the derivation monitoring burden and cost by scenario)

Total Analyses Total Burden ( hours) Annual Burden ( hours) 23 Year Total Cost ($, present value) 23 Yr. Annual Cost ($, present value)

1976 Baseline Gross Alpha 323,252 161,626 7,027 7,310,686 648,560 Gross Beta 293,250 146,625 6,375 10,072,779 893,596 Combined Radiums 30,490 15,245 663 1,091,458 96,828 TOTAL 646,992 323,496 14,065 18,474,923 1,638,984 PWS labor rate 26 26 26 26 PWS labor costs 8,410,896 365,690 4,410,734 391,294 Total PWS costs 26,885,819 2,004,674 2000 Rule Gross Alpha 254,638 127,319 5,536 4,953,727 439,565 Gross Beta 423,646 211,823 9,210 12,833,302 1,138,493 Combined Radiums 453,427 226,713 9,857 29,163,035 2,587,167 Uranium 27,345 13,672 594 1,720,814 152,660 TOTAL 1,159,056 579,527 25,197 48,670,878 4,317,885 PWS labor rate** 26 26 26 26 PWS labor costs ($) 15,067,702 655,122 6,059,637 537,574 Total PWS costs ($) 54,730,515 4,855,439 * 7% discount rate ** dollars per hour, fully loaded 32 7 SURVEY INFORMATION This information collection is not a survey. 33 EXHIBIT 1. BURDEN, RESPONDENTS, RESPONSES, AND COSTS FOR THE ICR APPROVAL PERIOD PWSs Source Year 1 Year 2 Year 3 Annual Average Burden ( hours) Exhibit 2 424,968 371,847 212,484 336,433 Respondents ( number) Exhibit 3 53,121 53,121 53,121 53,121 Responses ( number) Exhibit 4 0 0 0 0 Costs* ( dollars) Exhibit 5 $ 11,686,620 $ 9,880,506 $ 5,843,310 $ 9,925,042 STATES Source Year 1 Year 2 Year 3 Annual Average Burden ( hours) Exhibit 2 6,440 6,160 6,720 6,440 Respondents ( number) Exhibit 3 56 56 56 56 Responses ( number) Exhibit 4 49 49 0 32.7 Costs* ( dollars) Exhibit 5 $ 259,056 $ 240,224 $ 151,298 $ 247,905 * Present Value over 3 years 34 EXHIBIT 2. BURDEN ESTIMATES FOR THE ICR APPROVAL PERIOD BY ACTIVITY BY YEAR ( HOURS)

PWSs ( see Worksheet 1)

Activity Year 1 Year 2 Year 3 Total Annual Average Read and Understand Rule 424,968 424,968 141,656 Mobilization and Planning 371,847 371,847 123,949 Train PWS Staff 212,484 212,484 70,828 TOTAL 424,968 371,847 212,484 1,009,299 336,433 STATES ( see Worksheet 3)

Activity Year 1 Year 2 Year 3 Total Annual Average Read and Understand Rule 560 560 187 Mobilization and Planning 2,240 2,240 747 Train State Staff 2,240 2,240 747 Train PWS Staff and Provide Technical Assistance 4,480 4,480 1,493 Primacy Application Revision and Regulation Adoption 5,880 3,920 9,800 3,267 TOTAL 6,440 6,160 6,720 19,320 6,440 35 EXHIBIT 3. RESPONDENT ESTIMATES FOR THE ICR APPROVAL PERIOD BY ACTIVITY BY YEAR ( NUMBER)

PWSs Activity Year 1 Year 2 Year 3 Read and Understand Rule 53,121 Mobilization and Planning 53,121 Train PWS Staff 53,121 STATES Activity Year 1 Year 2 Year 3 Read and Understand Rule 56 Mobilization and Planning 56 56 Train State Staff 56 Train PWS Staff and Provide Technical Assistance 56 Primacy Application Revision and Regulation Adoption 49 49 36 EXHIBIT 4. RESPONSES ESTIMATES FOR THE ICR APPROVAL PERIOD BY ACTIVITY BY YEAR ( NUMBER)

PWSs Activity Year 1 Year 2 Year 3 Read and Understand Rule* 0 0 0 Mobilization and Planning* 0 0 0 Train State Staff* 0 0 0 * No responses are applicable, preparation activities only.

STATES Activity Year 1 Year 2 Year 3 Read and Understand Rule* 0 0 0 Mobilization and Planning* 0 0 0 Train State Staff* 0 0 0 Train PWS Staff and Provide Technical Assistance* 0 0 0 Primacy Application Revision and Regulation Adoption 49** 49*** 0 * No responses are applicable, preparation activities only. ** Draft Primacy Revision Applications *** Final Primacy Revisions Applications 37 EXHIBIT 5. COST ESTIMATES FOR THE ICR APPROVAL PERIOD BY ACTIVITY BY YEAR ( DOLLARS)

PWSs ( see Worksheet 1)

Activity Year 1 Year 2 Year 3 Total Present Value* Annualized Present Value**

Read and Understand Rule $ 11,686,620 $ 11,686,620 $ 4,453,206 Mobilization and Planning $ 9,880,506 $ 9,234,118 $ 3,518,676 Train PWS Staff $ 5,843,310 $ 5,125,710 $ 1,953,160 TOTAL $ 11,686,620 $ 9,880,506 $ 5,843,310 $ 26,046,448 $ 9,925,042 * discount rate = 7%; ** calculated over 3 years STATES ( see Worksheet 3)

Activity Year 1 Year 2 Year 3 Total Present Value* Annualized Present Value**

Read and Understand Rule $ 16,016 $ 16,016 $ 6,103 Mobilization and Planning $ 57,120 $ 53,383 $ 20,342 Train State Staff $ 57,120 $ 50,105 $ 19,093 Train PWS Staff and Provide Technical Assistance $ 115,360 $ 101,193 $ 38,560 Primacy Application Revision and Regulation Adoption $ 243,040 $ 199,920 $ 429,881 $ 163,807 TOTAL $ 259,056 $ 257,040 $ 172,480 $ 650,578 $ 247,905 * discount rate = 7%; ** calculated over 3 years 38 EXHIBIT 6. BURDEN, RESPONDENTS, RESPONSES, AND COSTS FOR THE POSTICR APPROVAL PERIOD PWSs Source 23 Year Total Annual Average Burden ( hours) Exhibit 7 579,527 25,197 Respondents ( number) Exhibit 8 53,121 17,707 Responses ( number) Exhibit 9 1,159,056 50,394 Costs ( dollars)* Exhibit 10 $ 54,730,515 $ 4,855,439 STATES Source 23 Year Total Annual Average Burden ( hours) Exhibit 7 69,543 3,024 Respondents ( number) Exhibit 8 56 56 Responses ( number) Exhibit 9 5,152 224 Costs ( dollars)* Exhibit 10 $ 718,299 $ 63,723 * discounted over 23 years at 7% 39 EXHIBIT 7. BURDEN ESTIMATE FOR THE POST ICR APPROVAL PERIOD BY ACTIVITY BY YEAR ( HOURS)

PWSs ( see Worksheet 2)

Activity Radionuclide 23 Year Total Annual Average Sample Collection Gross Alpha 127,319 5,536 Sample Collection Gross Beta 211,823 9,210 Sample Collection Combined Radiums 226,713 9,857 Sample Collection Uranium 13,672 594 Total 579,527 25,197 STATES ( see Worksheet 4)

Activity 23 Year Total Annual Average Record keeping 13,909 605 Reporting 30,135 1,310 Compliance Tracking and Analysis 25,499 1,109 Total 69,543 3,024 40 EXHIBIT 8. RESPONDENTS ESTIMATE FOR THE POST ICR APPROVAL PERIOD BY ACTIVITY BY YEAR ( NUMBER)

PWSs Activity Radionuclide 23 Year Total Universe Annual Estimate Sample Collection and Analysis Gross Alpha 53,121 17,707*

Sample Collection and Analysis Gross Beta 2,114 2,114 Sample Collection and Analysis Combined Radiums 53,121 17,707*

Sample Collection and Analysis Uranium 1,507 644 Total 53,121 17,707*

* estimate based on SMF goal of 1/ 3 per year STATES Activity 23 Year Total Universe Annual Estimate Record keeping 56 56 Reporting 56 56 Compliance Tracking and Analysis 56 56 Total 56 56 41 EXHIBIT 9. RESPONSES ESTIMATE FOR THE POST ICR APPROVAL PERIOD BY ACTIVITY ( NUMBER)

PWSs ( see Worksheet 2)

Activity Radionuclide 23 Year Total Annual Average Analyses Gross Alpha 254,638 11,071 Analyses Gross Beta 423,646 18,419 Analyses Combined Radiums 453,427 19,714 Analyses Uranium 27,345 1,189 Total 1,159,056 50,394 STATES Activity 23 Year Total Annual Average Record keeping 0 0 Reporting 5,152 224 Compliance Tracking and Analysis 0* 0*

Total 5,152 224 * integrated with quarterly reporting 42 EXHIBIT 10. COST ESTIMATE FOR THE POST ICR APPROVAL PERIOD BY ACTIVITY BY YEAR ( DOLLARS)

PWSs ( see Worksheet 2)

Activity Radionuclide 23 Year Total* Annual Average*

Analysis Gross Alpha $ 4,953,727 $ 439,565 Analysis Gross Beta $ 12,833,302 $ 1,138,493 Analysis Combined Radiums $ 29,163,035 $ 2,587,167 Analysis Uranium $ 1,720,814 $ 152,660 Sample Collection  all radionuclides $ 6,059,637 $ 537,574 Total $ 54,730,515 $ 4,855,439 STATES ( see Worksheet 4)

Activity 23 Year Total* Annual Average*

Record keeping $ 129,294 $ 11,470 Reporting $ 280,137 $ 24,852 Compliance Tracking and Analysis $ 308,869 $ 27,401 Total $ 718,299 $ 63,723 * discounted over 23 years at 7% 43 WORKSHEET 1 ASSUMPTIONS AND ANALYSIS FOR PWS START UP ACTIVITIES ACTIVITIES FOR EACH PWS Read and Understand Rule STAFF HOURS RATE TOTAL COST Supervisor 2 $ 32/ hr $ 64 Tech./ Prog. Analyst 6 $ 26/ hr $ 156 Administrative Asst. $ 18/ hr TOTAL 8 $ 220 Mobilization and Planning STAFF HOURS RATE TOTAL COST Supervisor 2 $ 32/ hr $ 64 Tech./ Prog. Analyst 4 $ 26/ hr $ 104 Administrative Asst. 1 $ 18/ hr $ 18 TOTAL 7 $ 186 Train PWS Staff STAFF HOURS RATE TOTAL COST Supervisor 1 $ 32/ hr $ 32 Tech./ Prog. Analyst 3 $ 26/ hr $ 78 Administrative. Asst. $ 18/ hr TOTAL 4 $ 110 44 NATIONAL SUMMARIES FOR INITIAL THREE YEAR PERIOD BURDEN TOTAL COST ANNUALIZED COST*

19 hours per PWS x 53,121 PWSs = 1,009,299 hours or 601 FTE $ 516 per PWS x 53,121 PWSs = $ 27,410,436 or $ 27.16 per hour $ 9,789,460 * at 7% over 3 years assuming costs are spread evenly over first three years 45 WORKSHEET 2. ASSUMPTIONS AND ANALYSIS FOR PWS MONITORING ACTIVITIES ( see Appendix for derivation of cost and burden estimates for monitoring scenarios)

Total Analyses Total Burden ( hours) Annual Burden ( hours) 23 Year Total Cost ($, present value) 23 Yr. Annual Cost ($, present value) 1976 Baseline Gross Alpha 323,252 161,626 7,027 7,310,686 648,560 Gross Beta 293,250 146,625 6,375 10,072,779 893,596 Combined Radiums 30,490 15,245 663 1,091,458 96,828 TOTAL 646,992 323,496 14,065 18,474,923 1,638,984 PWS labor rate 26 26 26 26 PWS labor costs 8,410,896 365,690 4,410,734 391,294 Total PWS costs 26,885,819 2,004,674 2000 Rule Gross Alpha 254,638 127,319 5,536 4,953,727 439,565 Gross Beta 423,646 211,823 9,210 12,833,302 1,138,493 Combined Radiums 453,427 226,713 9,857 29,163,035 2,587,167 Uranium 27,345 13,672 594 1,720,814 152,660 TOTAL 1,159,056 579,527 25,197 48,670,878 4,317,885 PWS labor rate** 26 26 26 26 PWS labor costs ($) 15,067,702 655,122 6,059,637 537,574 Total PWS costs ($) 54,730,515 4,855,439 * 7% discount rate ** dollars per hour, fully loaded 46 WORKSHEET 3 ASSUMPTIONS AND ANALYSIS FOR STATE START UP ACTIVITIES GENERAL PREPARATION ACTIVITIES FOR EACH JURISDICTION Read and Understand Rule ( 56 Jurisdictions)

STAFF HOURS RATE TOTAL COST Supervisor 4 $ 32/ hr $ 128 Tech./ Prog. Analyst 6 $ 26/ hr $ 158 Administrative Asst. $ 18/ hr TOTAL 10 $ 286 Mobilization and Planning ( 56 Jurisdictions)

STAFF HOURS RATE TOTAL COST Supervisor 10 $ 32/ hr $ 320 Tech./ Prog. Analyst 20 $ 26/ hr $ 520 Administrative Asst. 10 $ 18/ hr $ 180 TOTAL 40 $ 1,020 Train State Staff ( 56 Jurisdictions)

STAFF HOURS RATE TOTAL COST Supervisor 10 $ 32/ hr $ 320 Tech./ Prog. Analyst 20 $ 26/ hr $ 520 Administrative Asst. 10 $ 18/ hr $ 180 TOTAL 40 $ 1,020 47 Train PWSs and Provide Technical Assistance ( 56 Jurisdictions)

STAFF HOURS RATE TOTAL COST Supervisor 10 $ 32/ hr $ 320 Tech./ Prog. Analyst 60 $ 26/ hr $ 1,560 Administrative Asst. 10 $ 18/ hr $ 180 TOTAL 80 $ 2,060 STATE PRIMACY APPLICATION REVISIONS AND ASSOCIATED REGULATORY ADOPTION Draft Application in Year 1 ( 49 Jurisdictions)

STAFF HOURS RATE TOTAL COST Lawyer 40 $ 80/ hr $ 3,200 Tech./ Prog. Analyst 40 $ 26/ hr $ 1,040 Administrative Asst. 40 $ 18/ hr $ 720 TOTAL 120 $ 4,960 Final Application in Year 2 ( 49 Jurisdictions)

STAFF HOURS RATE TOTAL COST Lawyer 40 $ 80/ hr $ 3,200 Tech./ Prog. Analyst 20 $ 26/ hr $ 520 Administrative Asst. 20 $ 18/ hr $ 360 TOTAL 80 $ 4,080 48 NATIONAL SUMMARIES FOR INITIAL THREE YEAR PERIOD GENERAL PREPARATION ACTIVITIES FOR EACH JURISDICTION BURDEN TOTAL COST 170 hours per jurisdiction x 56 jurisdictions 9,520 = hours or 5.7 FTE $ 4,386 per jurisdiction x 56 jurisdictions = $ 245,616 or $ 25.80 per hour STATE PRIMACY APPLICATION REVISIONS AND ASSOCIATED REGULATORY ADOPTION BURDEN TOTAL COST 200 hours per jurisdiction x 49 jurisdictions = 9,800 hours or 5.8 FTE $ 9,040 per jurisdiction x 49 jurisdictions = $ 442,960 or $ 45.20 per hour THREE YEAR NATIONAL SUMMARY BURDEN TOTAL COST ANNUALIZED COSTS*

19,320 hours or 11.5 FTE $ 688,576 or $ 35.64 per hour $ 262,383 or $ 4,685 per jurisdiction * over 3 years at 7% assuming all costs occur in first year 49 WORKSHEET 4 ASSUMPTIONS AND ANALYSIS FOR STATE ACTIVITIES RELATED TO MONITORING SUPERVISON Recordkeeping activities per 1000 analyses STAFF HOURS RATE TOTAL COST Supervisor 1 $ 32/ hr $ 32 Tech./ Prog. Analyst 1 $ 26/ hr $ 26 Administrative Asst. 10 $ 18/ hr $ 180 TOTAL 12 $ 238 Reporting Activities per 1000 analyses STAFF HOURS RATE TOTAL COST Supervisor 1 $ 32/ hr $ 32 Tech./ Prog. Analyst 5 $ 26/ hr $ 130 Administrative Asst. 20 $ 18/ hr $ 360 TOTAL 26 $ 522 Compliance Tracking and Analysis Activities per 1000 analyses STAFF HOURS RATE TOTAL COST Supervisor 2 $ 32/ hr $ 64 Tech./ Prog. Analyst 20 $ 26/ hr $ 520 Administrative Asst. $ 18/ hr TOTAL 22 $ 584 50 NATIONAL SUMMARIES STATE BURDEN AND COST FOR STATES TO SUPERVISE MONITORING PER 1000 ANALYSES TOTAL BURDEN TOTAL COST 60 hours or .06 hours per analysis ( response) $ 1,344 or $ 22.40 per hour or $ 1.34 per analysis ( response)

NATIONAL SUMMARIES STATE BURDEN AND COST FOR STATES TO SUPERVISE MONITORING FOR THE PROPOSED RULE  YEAR 2000 SCENARIOS TOTAL BURDEN TOTAL COST 1,159,056 total analyses at .06 hours per analysis ( response)

equals 69,543 hours divide by 23 years equals 3,024 hours per year 1,159,056 total analyses or $ 1.34 per analysis ( response)

equals $ 1,553,135 divided by 20 years ( Years 4 through 23) equals $ 77,657 per year discounted at 7% over 23 years equals a present value of $ 718,299 or an annualized cost of $ 63,723 51 APPENDIX  FLOW CHARTS AND COST SHEETS FOR MONITORING SCENARIOS BASELINE GROSS ALPHA 2000 GROSS ALPHA BASELINE GROSS BETA 2000 GROSS BETA BASELINE COMBINED RADIUMS 2000 COMBINED RADIUMS 2000 URANIUM 52 BASELINE GROSS ALPHA 53 Initial Monitoring Perform Gross Alpha Screen  Based on the results of 4 quarterlies Gross Alpha Screen > 15 Check for uranium and adjust.

Adjusted Gross Alpha > 15  Systems are out of Compliance for Gross alpha MCL

Assume that States will require systems to monitor 1 per yr.

Adjusted Gross Alpha < 15  Systems are in compliance for gross alpha MCL  monitor 4 times in 4 years Gross Alpha between > 7.5 and < or = to 15 then monitor 4 times in 4 years.

Gross Alpha between <

or = to 7.5, then 1 every 4 years. Gross Alpha  1976 Baseline Monitoring 94.7% ofSmall CWSs 93.1% of Large CWSs 0.8 % of Small CWSs 1.3% of Large CWSs Gross Alpha Std = 15 pCi/ L Cost of Analyis fo r GA is $ 45 Cost of Analysis for Uranium is $ 128 Samples are taken from the distribution system No Compositing 3.2% of Small CWSs 4.7% of Large CWSs 1.4% of Small CWSs 0.9% of Large CWSs 54 BASELINE GROSS ALPHA YEAR 1 YEAR 2 YEAR 3 YEAR 4 YEAR 5 YEAR 6 GA< 7.5 SM Samples per System 0 0 0 1 0 0 Systems 29,738 29,738 29,738 29,738 29,738 29,738 Total Samples 0 0 0 29738 0 0 Cost per Sample 45 45 Total Cost 0 0 0 1338210 0 0 Discount Rate 1 1.07 1.14 1.23 1.31 1.4 Present Value Cost 0 0 0 1087976 0 0 GA< 7.5 LG Samples per System 0 0 0 1 0 0 Systems 20,220 20,220 20,220 20,220 20,220 20,220 Total Samples 0 0 0 20220 0 0 Cost per Sample 45 45 Total Cost 0 0 0 909900 0 0 Discount Rate 1 1.07 1.14 1.23 1.31 1.4 Present Value Cost 0 0 0 739756.1 0 0 7.5< GA< 15 SM Samples per System 1 1 1 1 1 1 Systems 1,005 1,005 1,005 1,005 1,005 1,005 Total Samples 1005 1005 1005 1005 1005 1005 Cost per Sample 45 45 45 45 45 45 Total Cost 45225 45225 45225 45225 45225 45225 Discount Rate 1 1.07 1.14 1.23 1.31 1.4 Present Value Cost 45225 42266.36 39671.05 36768.29 34522.9 32303.57 7.5< GA< 15 LG Samples per System 1 1 1 1 1 1 Systems 1,021 1,021 1,021 1,021 1,021 1,021 Total Samples 1021 1021 1021 1021 1021 1021 Cost per Sample 45 45 45 45 45 45 Total Cost 45945 45945 45945 45945 45945 45945 Discount Rate 1 1.07 1.14 1.23 1.31 1.4 Present Value Cost 45945 42939.25 40302.63 37353.66 35072.52 32817.86 GA> 15 AND AGA< 15 SM Samples per System 1 1 1 1 1 1 Systems 440 440 440 440 440 440 Total Samples 440 440 440 440 440 440 Cost per Sample 45 45 45 45 45 45 Total Cost 19800 19800 19800 19800 19800 19800 Discount Rate 1 1.07 1.14 1.23 1.31 1.4 Present Value Cost 19800 18504.67 17368.42 16097.56 15114.5 14142.86 55 BASELINE GROSS ALPHA YEAR 7 YEAR 8 YEAR 9 YEAR 10 YEAR 11 YEAR 12 GA< 7.5 SM Samples per System 0 1 0 0 0 1 Systems 29,738 29,738 29,738 29,738 29,738 29,738 Total Samples 0 29738 0 0 0 29738 Cost per Sample 45 45 Total Cost 0 1338210 0 0 01338210 Discount Rate 1.5 1.61 1.72 1.84 1.97 2.1 Present Value Cost 0 831186.3 0 0 0637242.9 GA< 7.5 LG Samples per System 0 1 0 0 0 1 Systems 20,220 20,220 20,220 20,220 20,220 20,220 Total Samples 0 20220 0 0 0 20220 Cost per Sample 45 45 Total Cost 0 909900 0 0 0 909900 Discount Rate 1.5 1.61 1.72 1.84 1.97 2.1 Present Value Cost 0 565155.3 0 0 0433285.7 7.5< GA< 15 SM Samples per System 1 1 1 1 1 1 Systems 1,005 1,005 1,005 1,005 1,005 1,005 Total Samples 1005 1005 1005 1005 1005 1005 Cost per Sample 45 45 45 45 45 45 Total Cost 45225 45225 45225 45225 45225 45225 Discount Rate 1.5 1.61 1.72 1.84 1.97 2.1 Present Value Cost 30150 28090.06 26293.6 24578.8 22956.85 21535.71 7.5< GA< 15 LG Samples per System 1 1 1 1 1 1 Systems 1,021 1,021 1,021 1,021 1,021 1,021 Total Samples 1021 1021 1021 1021 1021 1021 Cost per Sample 45 45 45 45 45 45 Total Cost 45945 45945 45945 45945 45945 45945 Discount Rate 1.5 1.61 1.72 1.84 1.97 2.1 Present Value Cost 30630 28537.27 26712.21 24970.11 23322.34 21878.57 GA> 15 AND AGA< 15 SM Samples per System 1 1 1 1 1 1 Systems 440 440 440 440 440 440 Total Samples 440 440 440 440 440 440 Cost per Sample 45 45 45 45 45 45 Total Cost 19800 19800 19800 19800 19800 19800 Discount Rate 1.5 1.61 1.72 1.84 1.97 2.1 Present Value Cost 13200 12298.14 11511.63 10760.87 10050.76 9428.571 56 BASELINE GROSS ALPHA YEAR 13 YEAR 14 YEAR 15 YEAR 16 YEAR 17 YEAR 18 GA< 7.5 SM Samples per System 0 0 0 1 0 0 Systems 29,738 29,738 29,738 29,738 29,738 29,738 Total Samples 0 0 0 29738 0 0 Cost per Sample 45 Total Cost 0 0 0 1338210 0 0 Discount Rate 2.25 2.41 2.58 2.76 2.95 3.16 Present Value Cost 0 0 0 484858.7 0 0 GA< 7.5 LG Samples per System 0 0 0 1 0 0 Systems 20,220 20,220 20,220 20,220 20,220 20,220 Total Samples 0 0 0 20220 0 0 Cost per Sample 45 Total Cost 0 0 0 909900 0 0 Discount Rate 2.25 2.41 2.58 2.76 2.95 3.16 Present Value Cost 0 0 0 329673.9 0 0 7.5< GA< 15 SM Samples per System 1 1 1 1 1 1 Systems 1,005 1,005 1,005 1,005 1,005 1,005 Total Samples 1005 1005 1005 1005 1005 1005 Cost per Sample 45 45 45 45 45 45 Total Cost 45225 45225 45225 45225 45225 45225 Discount Rate 2.25 2.41 2.58 2.76 2.95 3.16 Present Value Cost 20100 18765.56 17529.07 16385.87 15330.51 14311.71 7.5< GA< 15 LG Samples per System 1 1 1 1 1 1 Systems 1,021 1,021 1,021 1,021 1,021 1,021 Total Samples 1021 1021 1021 1021 1021 1021 Cost per Sample 45 45 45 45 45 45 Total Cost 45945 45945 45945 45945 45945 45945 Discount Rate 2.25 2.41 2.58 2.76 2.95 3.16 Present Value Cost 20420 19064.32 17808.14 16646.74 15574.58 14539.56 GA> 15 AND AGA< 15 SM Samples per System 1 1 1 1 1 1 Systems 440 440 440 440 440 440 Total Samples 440 440 440 440 440 440 Cost per Sample 45 45 45 45 45 45 Total Cost 19800 19800 19800 19800 19800 19800 Discount Rate 2.25 2.41 2.58 2.76 2.95 3.16 Present Value Cost 8800 8215.768 7674.419 7173.913 6711.864 6265.823 57 BASELINE GROSS ALPHA YEAR 19 YEAR 20 YEAR 21 YEAR 22 YEAR 23 GA< 7.5 SM Samples per System 0 1 0 0 0 Systems 29,738 29,738 29,738 29,738 29,738 Total Samples 0 29738 0 0 0 Cost per Sample 45 Total Cost 0 1338210 0 0 0 Discount Rate 3.38 3.62 3.87 4.14 4.43 Present Value Cost 0 369671.3 0 0 0 GA< 7.5 LG Samples per System 0 1 0 0 0 Systems 20,220 20,220 20,220 20,220 20,220 Total Samples 0 20220 0 0 0 Cost per Sample 45 Total Cost 0 909900 0 0 0 Discount Rate 3.38 3.62 3.87 4.14 4.43 Present Value Cost 0 251353.6 0 0 0 7.5< GA< 15 SM Samples per System 1 1 1 1 1 Systems 1,005 1,005 1,005 1,005 1,005 Total Samples 1005 1005 1005 1005 1005 Cost per Sample 45 45 45 45 45 Total Cost 45225 45225 45225 45225 45225 Discount Rate 3.38 3.62 3.87 4.14 4.43 Present Value Cost 13380.18 12493.09 11686.05 10923.91 10208.8 7.5< GA< 15 LG Samples per System 1 1 1 1 1 Systems 1,021 1,021 1,021 1,021 1,021 Total Samples 1021 1021 1021 1021 1021 Cost per Sample 45 45 45 45 45 Total Cost 45945 45945 45945 45945 45945 Discount Rate 3.38 3.62 3.87 4.14 4.43 Present Value Cost 13593.2 12691.99 11872.09 11097.83 10371.33 GA> 15 AND AGA< 15 SM Samples per System 1 1 1 1 1 Systems 440 440 440 440 440 Total Samples 440 440 440 440 440 Cost per Sample 45 45 45 45 45 Total Cost 19800 19800 19800 19800 19800 Discount Rate 3.38 3.62 3.87 4.14 4.43 Present Value Cost 5857.988 5469.613 5116.279 4782.609 4469.526 58 BASELINE GROSS ALPHA TOTAL TOTAL TOTAL GA< 7.5 SM Samples per System Systems Total Samples 148690 Cost per Sample Total Cost Discount Rate Present Value Cost 3410934.769 GA< 7.5 LG Samples per System Systems Total Samples 101100 Cost per Sample Total Cost Discount Rate Present Value Cost 2319224.596 7.5< GA< 15 SM Samples per System Systems Total Samples 23115 Cost per Sample Total Cost Discount Rate Present Value Cost 545476.9623 7.5< GA< 15 LG Samples per System Systems Total Samples 23483 Cost per Sample Total Cost Discount Rate Present Value Cost 554161.1726 GA> 15 AND AGA< 15 SM Samples per System Systems Total Samples 10120 Cost per Sample Total Cost Discount Rate Present Value Cost 238815.7845 59 BASELINE GROSS ALPHA YEAR 1 YEAR 2 YEAR 3 YEAR 4 YEAR 5 YEAR 6 GA> 15 AND AGA< 15 LG Samples per System 1 1 1 1 1 1 Systems 195 195 195 195 195 195 Total Samples 195 195 195 195 195 195 Cost per Sample 45 45 45 45 45 45 Total Cost 8775 8775 8775 8775 8775 8775 Discount Rate 1 1.07 1.14 1.23 1.31 1.4 Present Value Cost 8775 8200.935 7697.368 7134.146 6698.473 6267.857 GA> 15 and AGA> 15 SM Samples per System 1 1 1 1 1 1 Systems 251 251 251 251 251 251 Total Samples 251 251 251 251 251 251 Cost per Sample 45 45 45 45 45 45 Total Cost 11295 11295 11295 11295 11295 11295 Discount Rate 1 1.07 1.14 1.23 1.31 1.4 Present Value Cost 11295 10556.07 9907.895 9182.927 8622.137 8067.857 GA> 15 and AGA> 15 LG Samples per System 1 1 1 1 1 1 Systems 282 282 282 282 282 282 Total Samples 282 282 282 282 282 282 Cost per Sample 45 45 45 45 45 45 Total Cost 12690 12690 12690 12690 12690 12690 Discount Rate 1 1.07 1.14 1.23 1.31 1.4 Present Value Cost 12690 11859.81 11131.58 10317.07 9687.023 9064.286 TOTAL PRESENT VALUE YEARS COVERED INTEREST RATE ANNUALIZED PRESENT VALUE TOTAL SAMPLES BURDEN PER SAMPLE ( HRS.) TOTAL BURDEN ( HRS.) YEARS COVERED AVERAGE ANNUAL BURDEN ( HRS.)

THREE YEAR TOTAL COST THREE YEAR ANNUALIZED COST 60 BASELINE GROSS ALPHA YEAR 7 YEAR 8 YEAR 9 YEAR 10 YEAR 11 YEAR 12 GA> 15 AND AGA< 15 LG Samples per System 1 1 1 1 1 1 Systems 195 195 195 195 195 195 Total Samples 195 195 195 195 195 195 Cost per Sample 45 45 45 45 45 45 Total Cost 8775 8775 8775 8775 8775 8775 Discount Rate 1.5 1.61 1.72 1.84 1.97 2.1 Present Value Cost 5850 5450.311 5101.744 4769.022 4454.315 4178.571 GA> 15 and AGA> 15 SM Samples per System 1 1 1 1 1 1 Systems 251 251 251 251 251 251 Total Samples 251 251 251 251 251 251 Cost per Sample 45 45 45 45 45 45 Total Cost 11295 11295 11295 11295 11295 11295 Discount Rate 1.5 1.61 1.72 1.84 1.97 2.1 Present Value Cost 7530 7015.528 6566.86 6138.587 5733.503 5378.571 GA> 15 and AGA> 15 LG Samples per System 1 1 1 1 1 1 Systems 282 282 282 282 282 282 Total Samples 282 282 282 282 282 282 Cost per Sample 45 45 45 45 45 45 Total Cost 12690 12690 12690 12690 12690 12690 Discount Rate 1.5 1.61 1.72 1.84 1.97 2.1 Present Value Cost 8460 7881.988 7377.907 6896.739 6441.624 6042.857 TOTAL PRESENT VALUE YEARS COVERED INTEREST RATE ANNUALIZED PRESENT VALUE TOTAL SAMPLES BURDEN PER SAMPLE ( HRS.) TOTAL BURDEN ( HRS.) YEARS COVERED AVERAGE ANNUAL BURDEN ( HRS.)

THREE YEAR TOTAL COST THREE YEAR ANNUALIZED COST 61 BASELINE GROSS ALPHA YEAR 13 YEAR 14 YEAR 15 YEAR 16 YEAR 17 YEAR 18 GA> 15 AND AGA< 15 LG Samples per System 1 1 1 1 1 1 Systems 195 195 195 195 195 195 Total Samples 195 195 195 195 195 195 Cost per Sample 45 45 45 45 45 45 Total Cost 8775 8775 8775 8775 8775 8775 Discount Rate 2.25 2.41 2.58 2.76 2.95 3.16 Present Value Cost 3900 3641.079 3401.163 3179.348 2974.576 2776.899 GA> 15 and AGA> 15 SM Samples per System 1 1 1 1 1 1 Systems 251 251 251 251 251 251 Total Samples 251 251 251 251 251 251 Cost per Sample 45 45 45 45 45 45 Total Cost 11295 11295 11295 11295 11295 11295 Discount Rate 2.25 2.41 2.58 2.76 2.95 3.16 Present Value Cost 5020 4686.722 4377.907 4092.391 3828.814 3574.367 GA> 15 and AGA> 15 LG Samples per System 1 1 1 1 1 1 Systems 282 282 282 282 282 282 Total Samples 282 282 282 282 282 282 Cost per Sample 45 45 45 45 45 45 Total Cost 12690 12690 12690 12690 12690 12690 Discount Rate 2.25 2.41 2.58 2.76 2.95 3.16 Present Value Cost 5640 5265.56 4918.605 4597.826 4301.695 4015.823 TOTAL PRESENT VALUE YEARS COVERED INTEREST RATE ANNUALIZED PRESENT VALUE TOTAL SAMPLES BURDEN PER SAMPLE ( HRS.) TOTAL BURDEN ( HRS.) YEARS COVERED AVERAGE ANNUAL BURDEN ( HRS.)

THREE YEAR TOTAL COST THREE YEAR ANNUALIZED COST 62 BASELINE GROSS ALPHA YEAR 19 YEAR 20 YEAR 21 YEAR 22 YEAR 23 GA> 15 AND AGA< 15 LG Samples per System 1 1 1 1 1 Systems 195 195 195 195 195 Total Samples 195 195 195 195 195 Cost per Sample 45 45 45 45 45 Total Cost 8775 8775 8775 8775 8775 Discount Rate 3.38 3.62 3.87 4.14 4.43 Present Value Cost 2596.154 2424.033 2267.442 2119.565 1980.813 GA> 15 and AGA> 15 SM Samples per System 1 1 1 1 1 Systems 251 251 251 251 251 Total Samples 251 251 251 251 251 Cost per Sample 45 45 45 45 45 Total Cost 11295 11295 11295 11295 11295 Discount Rate 3.38 3.62 3.87 4.14 4.43 Present Value Cost 3341.716 3120.166 2918.605 2728.261 2549.661 GA> 15 and AGA> 15 LG Samples per System 1 1 1 1 1 Systems 282 282 282 282 282 Total Samples 282 282 282 282 282 Cost per Sample 45 45 45 45 45 Total Cost 12690 12690 12690 12690 12690 Discount Rate 3.38 3.62 3.87 4.14 4.43 Present Value Cost 3754.438 3505.525 3279.07 3065.217 2864.56 TOTAL PRESENT VALUE YEARS COVERED INTEREST RATE ANNUALIZED PRESENT VALUE TOTAL SAMPLES BURDEN PER SAMPLE ( HRS.) TOTAL BURDEN ( HRS.) YEARS COVERED AVERAGE ANNUAL BURDEN ( HRS.)

THREE YEAR TOTAL COST THREE YEAR ANNUALIZED COST 63 BASELINE GROSS ALPHA TOTAL TOTAL TOTAL GA> 15 AND AGA< 15 LG Samples per System Systems Total Samples 4485 Cost per Sample Total Cost Discount Rate Present Value Cost 105838.8136 GA> 15 and AGA> 15 SM Samples per System Systems Total Samples 5773 Cost per Sample Total Cost Discount Rate Present Value Cost 136233.5498 GA> 15 and AGA> 15 LG Samples per System Systems Total Samples 6486 Cost per Sample Total Cost Discount Rate Present Value Cost 153059.2073 TOTAL PRESENT VALUE 7310685.647 YEARS COVERED 23 INTEREST RATE 7% ANNUALIZED PRESENT VALUE ($ 648,559.63)

TOTAL SAMPLES 323252 BURDEN PER SAMPLE ( HRS.) 0.5 TOTAL BURDEN ( HRS.) 161626 YEARS COVERED 23 AVERAGE ANNUAL BURDEN ( HRS.) 7027.217391 THREE YEAR TOTAL COST 182835.5017 THREE YEAR ANNUALIZED COST ($ 69,669.77) 64 2000 GROSS ALPHA 65 Initial M onitoring P erform Gross Alpha Screen  B ased on the results o f 4 quarterlies in 3 yrs Gross A lpha Screen >

15. C heck for uranium and ad just.*

Adjusted G ross A lpha > 15  System s a re out of C ompliance fo r Gross a lpha M CL

Assume that States will require sy stems to monitor 1 / y r Adjusted G ross A lpha < 15  System s a re in compliance for gross a lpha M CL  monitor 1 in 9 y ears**

Gross A lpha between >

7.5 and < or = to 15 then monitor 1 every 3 yrs.

Gross A lpha < or = 3 , then 1 every 9 yrs Gross A lpha  2000 Monitoring ( Scenario 3A: Initial m onitoring in Y rs. 4  7, SM F 3 yr. cycles thereafter)

88.8% o f Small CWSs 88.4% o f L arge CWSs Gross A lpha S td = 15 pC i/ L Cost of A nalysis for GA is $ 45 Cost of A nalysis for U ranium is $ 128 Samples taken from entry point to distribution system Assumes N o Compositing Assumes grandfathering for all systems except those for out o f compliance. Gross A lpha between > 3 and < or = to 7 .5,

then 1 every 6 yrs Can GF a ll data Can GF a ll data Can GF a ll data Assume all new monitoring  no grandfathering 5.9% of Small CWSs 4.7% of Large CWSs 3 .2% o f Small CWSs 4 .7% o f Large CWSs 1.4% of Small CWSs 0.9% of Large CWSs 0 .8% o f Small CWSs 1 .3% o f L arge CWSs * U costs calculated in the U ranium scenario.

** GA and U do not u sua lly co occur, so GA w ill be v ery small. 66 2000 GROSS ALPHA SCENARIO 3 YEAR 1 YEAR 2 YEAR 3 YEAR 4 YEAR 5 YEAR 6 GA< 3 SM GF Sites per System 1.25 1.25 1.25 1.25 1.25 1.25 Sampling Frequency per Site Systems 27,885 27,885 27,885 27,885 27,885 27,885 Total Samples 0 0 0 0 0 0 Cost per Sample 45 45 45 45 45 45 Total Cost 0 0 0 0 0 0 Discount Rate 1 1.07 1.14 1.23 1.31 1.4 Present Value Cost 0 0 0 0 0 0 GA< 3 LG GF Sites per System 2.28 2.28 2.28 2.28 2.28 2.28 Sampling Frequency per Site 0 0 0 0 0 0 Systems 19,200 19,200 19,200 19,200 19,200 19,200 Total Samples 0 0 0 0 0 0 Cost per Sample 45 45 45 45 45 45 Total Cost 0 0 0 0 0 0 Discount Rate 1 1.07 1.14 1.23 1.31 1.4 Present Value Cost 0 0 0 0 0 0 3< GA< 7.5 SM GF Sites per System 1.25 1.25 1.25 1.25 1.25 1.25 Sampling Frequency per Site 0 0 0 0 0 0 Systems 1,853 1,853 1,853 1,853 1,853 1,853 Total Samples 0 0 0 0 0 0 Cost per Sample 45 45 45 45 45 45 Total Cost 0 0 0 0 0 0 Discount Rate 1 1.07 1.14 1.23 1.31 1.4 Present Value Cost 0 0 0 0 0 0 3< GA< 7.5 LG GF Sites per System 2.28 2.28 2.28 2.28 2.28 2.28 Sampling Frequency per Site 0 0 0 0 0 0 Systems 1,021 1,021 1,021 1,021 1,021 1,021 Total Samples 0 0 0 0 0 0 Cost per Sample 45 45 45 45 45 45 Total Cost 0 0 0 0 0 0 Discount Rate 1 1.07 1.14 1.23 1.31 1.4 Present Value Cost 0 0 0 0 0 0 7.5< GA< 15 SM GF Sites per System 1.25 1.25 1.25 1.25 1.25 1.25 Sampling Frequency per Site 0 0 0 0 0 0 Systems 1,005 1,005 1,005 1,005 1,005 1,005 Total Samples 0 0 0 0 0 0 Cost per Sample 45 45 45 45 45 45 Total Cost 0 0 0 0 0 0 Discount Rate 1 1.07 1.14 1.23 1.31 1.4 Present Value Cost 0 0 0 0 0 0 67 2000 GROSS ALPHA SCENARIO 3 YEAR 7 YEAR 8 YEAR 9 YEAR 10 YEAR 11 YEAR 12 GA< 3 SM GF Sites per System 1.25 1.25 1.25 1.25 1.25 1.25 Sampling Frequency per Site 1 Systems 27,885 27,885 27,885 27,885 27,885 27,885 Total Samples 0 34856.25 0 0 0 0 Cost per Sample 45 45 45 45 45 45 Total Cost 0 1568531 0 0 0 0 Discount Rate 1.5 1.61 1.72 1.84 1.97 2.1 Present Value Cost 0 974243 0 0 0 0 GA< 3 LG GF Sites per System 2.28 2.28 2.28 2.28 2.28 2.28 Sampling Frequency per Site 0 0 1 0 0 0 Systems 19,200 19,200 19,200 19,200 19,200 19,200 Total Samples 0 0 43776 0 0 0 Cost per Sample 45 45 45 45 45 45 Total Cost 0 0 1969920 0 0 0 Discount Rate 1.5 1.61 1.72 1.84 1.97 2.1 Present Value Cost 0 0 1145302 0 0 0 3< GA< 7.5 SM GF Sites per System 1.25 1.25 1.25 1.25 1.25 1.25 Sampling Frequency per Site 0 0 1 0 0 0 Systems 1,853 1,853 1,853 1,853 1,853 1,853 Total Samples 0 0 2316.25 0 0 0 Cost per Sample 45 45 45 45 45 45 Total Cost 0 0 104231.3 0 0 0 Discount Rate 1.5 1.61 1.72 1.84 1.97 2.1 Present Value Cost 0 0 60599.56 0 0 0 3< GA< 7.5 LG GF Sites per System 2.28 2.28 2.28 2.28 2.28 2.28 Sampling Frequency per Site 0 0 1 0 0 0 Systems 1,021 1,021 1,021 1,021 1,021 1,021 Total Samples 0 0 2327.88 0 0 0 Cost per Sample 45 45 45 45 45 45 Total Cost 0 0 104754.6 0 0 0 Discount Rate 1.5 1.61 1.72 1.84 1.97 2.1 Present Value Cost 0 0 60903.84 0 0 0 7.5< GA< 15 SM GF Sites per System 1.25 1.25 1.25 1.25 1.25 1.25 Sampling Frequency per Site 0 0 0 1 0 0 Systems 1,005 1,005 1,005 1,005 1,005 1,005 Total Samples 0 0 0 1256.25 0 0 Cost per Sample 45 45 45 45 45 45 Total Cost 0 0 0 56531.25 0 0 Discount Rate 1.5 1.61 1.72 1.84 1.97 2.1 Present Value Cost 0 0 0 30723.51 0 0 68 2000 GROSS ALPHA SCENARIO 3 YEAR 13 YEAR 14 YEAR 15 YEAR 16 YEAR 17 YEAR 18 GA< 3 SM GF Sites per System 1.25 1.25 1.25 1.25 1.25 1.25 Sampling Frequency per Site 1 Systems 27,885 27,885 27,885 27,885 27,885 27,885 Total Samples 0 0 0 0 34856.25 0 Cost per Sample 45 45 45 45 45 45 Total Cost 0 0 0 0 1568531 0 Discount Rate 2.25 2.41 2.58 2.76 2.95 3.16 Present Value Cost 0 0 0 0 531705.5 0 GA< 3 LG GF Sites per System 2.28 2.28 2.28 2.28 2.28 2.28 Sampling Frequency per Site 0 0 1 0 0 0 Systems 19,200 19,200 19,200 19,200 19,200 19,200 Total Samples 0 0 43776 0 0 0 Cost per Sample 45 45 45 45 45 45 Total Cost 0 0 1969920 0 0 0 Discount Rate 2.25 2.41 2.58 2.76 2.95 3.16 Present Value Cost 0 0 763534.9 0 0 0 3< GA< 7.5 SM GF Sites per System 1.25 1.25 1.25 1.25 1.25 1.25 Sampling Frequency per Site 0 0 1 0 0 0 Systems 1,853 1,853 1,853 1,853 1,853 1,853 Total Samples 0 0 2316.25 0 0 0 Cost per Sample 45 45 45 45 45 45 Total Cost 0 0 104231.3 0 0 0 Discount Rate 2.25 2.41 2.58 2.76 2.95 3.16 Present Value Cost 0 0 40399.71 0 0 0 3< GA< 7.5 LG GF Sites per System 2.28 2.28 2.28 2.28 2.28 2.28 Sampling Frequency per Site 0 0 1 0 0 0 Systems 1,021 1,021 1,021 1,021 1,021 1,021 Total Samples 0 0 2327.88 0 0 0 Cost per Sample 45 45 45 45 45 45 Total Cost 0 0 104754.6 0 0 0 Discount Rate 2.25 2.41 2.58 2.76 2.95 3.16 Present Value Cost 0 0 40602.56 0 0 0 7.5< GA< 15 SM GF Sites per System 1.25 1.25 1.25 1.25 1.25 1.25 Sampling Frequency per Site 1 0 0 1 0 0 Systems 1,005 1,005 1,005 1,005 1,005 1,005 Total Samples 1256.25 0 0 1256.25 0 0 Cost per Sample 45 45 45 45 45 45 Total Cost 56531.25 0 0 56531.25 0 0 Discount Rate 2.25 2.41 2.58 2.76 2.95 3.16 Present Value Cost 25125 0 0 20482.34 0 0 69 2000 GROSS ALPHA SCENARIO 3 YEAR 19 YEAR 20 YEAR 21 YEAR 22 YEAR 23 GA< 3 SM GF Sites per System 1.25 1.25 1.25 1.25 1.25 Sampling Frequency per Site Systems 27,885 27,885 27,885 27,885 27,885 Total Samples 0 0 0 0 0 Cost per Sample 45 45 45 45 45 Total Cost 0 0 0 0 0 Discount Rate 3.38 3.62 3.87 4.14 4.43 Present Value Cost 0 0 0 0 0 GA< 3 LG GF Sites per System 2.28 2.28 2.28 2.28 2.28 Sampling Frequency per Site 0 0 1 0 0 Systems 19,200 19,200 19,200 19,200 19,200 Total Samples 0 0 43776 0 0 Cost per Sample 45 45 45 45 45 Total Cost 0 0 1969920 0 0 Discount Rate 3.38 3.62 3.87 4.14 4.43 Present Value Cost 0 0 509023.3 0 0 3< GA< 7.5 SM GF Sites per System 1.25 1.25 1.25 1.25 1.25 Sampling Frequency per Site 0 0 1 0 0 Systems 1,853 1,853 1,853 1,853 1,853 Total Samples 0 0 2316.25 0 0 Cost per Sample 45 45 45 45 45 Total Cost 0 0 104231.3 0 0 Discount Rate 3.38 3.62 3.87 4.14 4.43 Present Value Cost 0 0 26933.14 0 0 3< GA< 7.5 LG GF Sites per System 2.28 2.28 2.28 2.28 2.28 Sampling Frequency per Site 0 0 1 0 0 Systems 1,021 1,021 1,021 1,021 1,021 Total Samples 0 0 2327.88 0 0 Cost per Sample 45 45 45 45 45 Total Cost 0 0 104754.6 0 0 Discount Rate 3.38 3.62 3.87 4.14 4.43 Present Value Cost 0 0 27068.37 0 0 7.5< GA< 15 SM GF Sites per System 1.25 1.25 1.25 1.25 1.25 Sampling Frequency per Site 1 0 0 1 0 Systems 1,005 1,005 1,005 1,005 1,005 Total Samples 1256.25 0 0 1256.25 0 Cost per Sample 45 45 45 45 45 Total Cost 56531.25 0 0 56531.25 0 Discount Rate 3.38 3.62 3.87 4.14 4.43 Present Value Cost 16725.22 0 0 13654.89 0 70 2000 GROSS ALPHA SCENARIO 3 TOTAL TOTAL TOTAL GA< 3 SM GF Sites per System Sampling Frequency per Site Systems Total Samples 69712.5 Cost per Sample Total Cost Discount Rate Present Value Cost 1505948.521 GA< 3 LG GF Sites per System Sampling Frequency per Site Systems Total Samples 131328 Cost per Sample Total Cost Discount Rate Present Value Cost 2417860.465 3< GA< 7.5 SM GF Sites per System Sampling Frequency per Site Systems Total Samples 6948.75 Cost per Sample Total Cost Discount Rate Present Value Cost 127932.4128 3< GA< 7.5 LG GF Sites per System Sampling Frequency per Site Systems Total Samples 6983.64 Cost per Sample Total Cost Discount Rate Present Value Cost 128574.7674 7.5< GA< 15 SM GF Sites per System Sampling Frequency per Site Systems Total Samples 6281.25 Cost per Sample Total Cost Discount Rate Present Value Cost 106710.9556 71 2000 GROSS ALPHA SCENARIO 3 YEAR 1 YEAR 2 YEAR 3 YEAR 4 YEAR 5 YEAR 6 7.5< GA< 15 LG GF Sites per System 2.28 2.28 2.28 2.28 2.28 2.28 Sampling Frequency per Site 0 0 0 0 0 0 Systems 1,021 1,021 1,021 1,021 1,021 1,021 Total Samples 0 0 0 0 0 0 Cost per Sample 45 45 45 45 45 45 Total Cost 0 0 0 0 0 0 Discount Rate 1 1.07 1.14 1.23 1.31 1.4 Present Value Cost 0 0 0 0 0 0 GA> 15 AND AGA< 15 SM GF Sites per System 1.25 1.25 1.25 1.25 1.25 1.25 Sampling Frequency per Site 0 0 0 0 0 0 Systems 440 440 440 440 440 440 Total Samples 0 0 0 0 0 0 Cost per Sample 45 128 45 45 45 45 Total Cost 0 0 0 0 0 0 Discount Rate 1 1.07 1.14 1.23 1.31 1.4 Present Value Cost 0 0 0 0 0 0 GA> 15 AND AGA< 15 LG GF Sites per System 2.28 2.28 2.28 2.28 2.28 2.28 Sampling Frequency per Site 0 0 0 0 0 0 Systems 195 195 195 195 195 195 Total Samples 0 0 0 0 0 0 Cost per Sample 45 128 45 45 45 45 Total Cost 0 0 0 0 0 0 Discount Rate 1 1.07 1.14 1.23 1.31 1.4 Present Value Cost 0 0 0 0 0 0 GA> 15 and AGA> 15 SM NO GF Sites per System 1.25 1.25 1.25 1.25 1.25 1.25 Sampling Frequency per Site 0 0 0 2 1 1 Systems 251 251 251 251 251 251 Total Samples 0 0 0 627.5 313.75 313.75 Cost per Sample 45 128 45 45 45 45 Total Cost 0 0 0 28237.5 14118.75 14118.75 Discount Rate 1 1.07 1.14 1.23 1.31 1.4 Present Value Cost 0 0 0 22957.32 10777.67 10084.82 GA> 15 and AGA> 15 LG NO GF Sites per System 2.28 2.28 2.28 2.28 2.28 2.28 Sampling Frequency per Site 0 0 0 2 1 1 Systems 275 275 275 275 275 275 Total Samples 0 0 0 1254 627 627 Cost per Sample 45 128 45 45 45 45 Total Cost 0 0 0 56430 28215 28215 Discount Rate 1 1.07 1.14 1.23 1.31 1.4 Present Value Cost 0 0 0 45878.05 21538.17 20153.57 72 2000 GROSS ALPHA SCENARIO 3 YEAR 7 YEAR 8 YEAR 9 YEAR 10 YEAR 11 YEAR 12 7.5< GA< 15 LG GF Sites per System 2.28 2.28 2.28 2.28 2.28 2.28 Sampling Frequency per Site 0 0 0 1 0 0 Systems 1,021 1,021 1,021 1,021 1,021 1,021 Total Samples 0 0 0 2327.88 0 0 Cost per Sample 45 45 45 45 45 45 Total Cost 0 0 0 104754.6 0 0 Discount Rate 1.5 1.61 1.72 1.84 1.97 2.1 Present Value Cost 0 0 0 56931.85 0 0 GA> 15 AND AGA< 15 SM GF Sites per System 1.25 1.25 1.25 1.25 1.25 1.25 Sampling Frequency per Site 0 1 0 0 0 0 Systems 440 440 440 440 440 440 Total Samples 0 550 0 0 0 0 Cost per Sample 45 45 45 45 45 45 Total Cost 0 24750 0 0 0 0 Discount Rate 1.5 1.61 1.72 1.84 1.97 2.1 Present Value Cost 0 15372.67 0 0 0 0 GA> 15 AND AGA< 15 LG GF Sites per System 2.28 2.28 2.28 2.28 2.28 2.28 Sampling Frequency per Site 0 1 0 0 0 0 Systems 195 195 195 195 195 195 Total Samples 0 444.6 0 0 0 0 Cost per Sample 45 45 45 45 45 45 Total Cost 0 20007 0 0 0 0 Discount Rate 1.5 1.61 1.72 1.84 1.97 2.1 Present Value Cost 0 12426.71 0 0 0 0 GA> 15 and AGA> 15 SM NO GF Sites per System 1.25 1.25 1.25 1.25 1.25 1.25 Sampling Frequency per Site 1 1 1 1 1 1 Systems 251 251 251 251 251 251 Total Samples 313.75 313.75 313.75 313.75 313.75 313.75 Cost per Sample 45 45 45 45 45 45 Total Cost 14118.75 14118.75 14118.75 14118.75 14118.75 14118.75 Discount Rate 1.5 1.61 1.72 1.84 1.97 2.1 Present Value Cost 9412.5 8769.41 8208.576 7673.234 7166.878 6723.214 GA> 15 and AGA> 15 LG NO GF Sites per System 2.28 2.28 2.28 2.28 2.28 2.28 Sampling Frequency per Site 1 1 1 1 1 1 Systems 275 275 275 275 275 275 Total Samples 627 627 627 627 627 627 Cost per Sample 45 45 45 45 45 45 Total Cost 28215 28215 28215 28215 28215 28215 Discount Rate 1.5 1.61 1.72 1.84 1.97 2.1 Present Value Cost 18810 17524.84 16404.07 15334.24 14322.34 13435.71 73 2000 GROSS ALPHA SCENARIO 3 YEAR 13 YEAR 14 YEAR 15 YEAR 16 YEAR 17 YEAR 18 7.5< GA< 15 LG GF Sites per System 2.28 2.28 2.28 2.28 2.28 2.28 Sampling Frequency per Site 1 0 0 1 0 0 Systems 1,021 1,021 1,021 1,021 1,021 1,021 Total Samples 2327.88 0 0 2327.88 0 0 Cost per Sample 45 45 45 45 45 45 Total Cost 104755 0 0 104755 0 0 Discount Rate 2.25 2.41 2.58 2.76 2.95 3.16 Present Value Cost 46557.6 0 0 37954.6 0 0 GA> 15 AND AGA< 15 SM GF Sites per System 1.25 1.25 1.25 1.25 1.25 1.25 Sampling Frequency per Site 0 0 0 0 1 0 Systems 440 440 440 440 440 440 Total Samples 0 0 0 0 550 0 Cost per Sample 45 45 45 45 45 45 Total Cost 0 0 0 0 24750 0 Discount Rate 2.25 2.41 2.58 2.76 2.95 3.16 Present Value Cost 0 0 0 0 8389.83 0 GA> 15 AND AGA< 15 LG GF Sites per System 2.28 2.28 2.28 2.28 2.28 2.28 Sampling Frequency per Site 0 0 0 0 1 0 Systems 195 195 195 195 195 195 Total Samples 0 0 0 0 444.6 0 Cost per Sample 45 45 45 45 45 45 Total Cost 0 0 0 0 20007 0 Discount Rate 2.25 2.41 2.58 2.76 2.95 3.16 Present Value Cost 0 0 0 0 6782.03 0 GA> 15 and AGA> 15 SM NO GF Sites per System 1.25 1.25 1.25 1.25 1.25 1.25 Sampling Frequency per Site 1 1 1 1 1 1 Systems 251 251 251 251 251 251 Total Samples 313.75 313.75 313.75 313.75 313.75 313.75 Cost per Sample 45 45 45 45 45 45 Total Cost 14118.8 14118.8 14118.8 14118.8 14118.8 14118.8 Discount Rate 2.25 2.41 2.58 2.76 2.95 3.16 Present Value Cost 6275 5858.4 5472.38 5115.49 4786.02 4467.96 GA> 15 and AGA> 15 LG NO GF Sites per System 2.28 2.28 2.28 2.28 2.28 2.28 Sampling Frequency per Site 1 1 1 1 1 1 Systems 275 275 275 275 275 275 Total Samples 627 627 627 627 627 627 Cost per Sample 45 45 45 45 45 45 Total Cost 28215 28215 28215 28215 28215 28215 Discount Rate 2.25 2.41 2.58 2.76 2.95 3.16 Present Value Cost 12540 11707.5 10936 10222.8 9564.41 8928.8 74 2000 GROSS ALPHA SCENARIO 3 YEAR 19 YEAR 20 YEAR 21 YEAR 22 YEAR 23 7.5< GA< 15 LG GF Sites per System 2.28 2.28 2.28 2.28 2.28 Sampling Frequency per Site 1 0 0 1 0 Systems 1,021 1,021 1,021 1,021 1,021 Total Samples 2327.88 0 0 2327.88 0 Cost per Sample 45 45 45 45 45 Total Cost 104755 0 0 104755 0 Discount Rate 3.38 3.62 3.87 4.14 4.43 Present Value Cost 30992.5 0 0 25303 0 GA> 15 AND AGA< 15 SM GF Sites per System 1.25 1.25 1.25 1.25 1.25 Sampling Frequency per Site 0 0 0 0 0 Systems 440 440 440 440 440 Total Samples 0 0 0 0 0 Cost per Sample 45 45 45 45 45 Total Cost 0 0 0 0 0 Discount Rate 3.38 3.62 3.87 4.14 4.43 Present Value Cost 0 0 0 0 0 GA> 15 AND AGA< 15 LG GF Sites per System 2.28 2.28 2.28 2.28 2.28 Sampling Frequency per Site 0 0 0 0 0 Systems 195 195 195 195 195 Total Samples 0 0 0 0 0 Cost per Sample 45 45 45 45 45 Total Cost 0 0 0 0 0 Discount Rate 3.38 3.62 3.87 4.14 4.43 Present Value Cost 0 0 0 0 0 GA> 15 and AGA> 15 SM NO GF Sites per System 1.25 1.25 1.25 1.25 1.25 Sampling Frequency per Site 1 1 1 1 1 Systems 251 251 251 251 251 Total Samples 313.75 313.75 313.75 313.75 313.75 Cost per Sample 45 45 45 45 45 Total Cost 14118.8 14118.8 14118.8 14118.8 14118.8 Discount Rate 3.38 3.62 3.87 4.14 4.43 Present Value Cost 4177.14 3900.21 3648.26 3410.33 3187.08 GA> 15 and AGA> 15 LG NO GF Sites per System 2.28 2.28 2.28 2.28 2.28 Sampling Frequency per Site 1 1 1 1 1 Systems 275 275 275 275 275 Total Samples 627 627 627 627 627 Cost per Sample 45 45 45 45 45 Total Cost 28215 28215 28215 28215 28215 Discount Rate 3.38 3.62 3.87 4.14 4.43 Present Value Cost 8347.63 7794.2 7290.7 6815.22 6369.07 75 2000 GROSS ALPHA SCENARIO 3 TOTAL TOTAL TOTAL 7.5< GA< 15 LG GF Sites per System Sampling Frequency per Site Systems Total Samples 11639.4 Cost per Sample Total Cost Discount Rate Present Value Cost 197739.5417 GA> 15 AND AGA< 15 SM GF Sites per System Sampling Frequency per Site Systems Total Samples 1100 Cost per Sample Total Cost Discount Rate Present Value Cost 23762.50132 GA> 15 AND AGA< 15 LG GF Sites per System Sampling Frequency per Site Systems Total Samples 889.2 Cost per Sample Total Cost Discount Rate Present Value Cost 19208.74197 GA> 15 and AGA> 15 SM NO GF Sites per System Sampling Frequency per Site Systems Total Samples 6588.75 Cost per Sample Total Cost Discount Rate Present Value Cost 142071.8839 GA> 15 and AGA> 15 LG NO GF Sites per System Sampling Frequency per Site Systems Total Samples 13167 Cost per Sample Total Cost Discount Rate Present Value Cost 283917.3584 76 2000 GROSS ALPHA SCENARIO 3 TOTAL TOTAL TOTAL TOTAL PRESENT VALUE 4953727.149 YEARS COVERED 23 INTEREST RATE 7% ANNUALIZED PRESENT VALUE ($ 439,464.58)

TOTAL SAMPLES 254638.49 BURDEN PER SAMPLE ( HRS.) 0.5 TOTAL BURDEN ( HRS.) 127319.245 YEARS COVERED 23 AVERAGE ANNUAL BURDEN ( HRS.) 5535.619348 THREE YEAR TOTAL COST 0 THREE YEAR ANNUALIZED COST $ 0.00 77 BASELINE GROSS BETA 78 SurfaceWater Systems > 100,000 or systems targeted as vulnerable by the State ? Is the system known to be using contaminated source?

Gross Beta  1976 Baseline Monitoring Monitoring not required Quarterly Gross Beta screen of 15 pCi/ L;

quarterly iodine 131;

and annual tritium and strontium Yes No No Yes Gross Beta quarterly screen of 50 pCi/ L and annual tritium and strontium.

96 % of CWSs 4 % of CWSs 0 % of CWSs Monthly gross beta and quarterly tritium and strontium Quarterly Gross Beta; annual tritium and strontium > 4 mrem < or = 4 mrem 0 % of CWSs 4 % of CWSs Gross Beta MCL = 4 mrem Gross Beta analysis $ 45 Tritium analysis = $ 60 Strontium analysis = $ 153 Iodine 131 analysis = $ 131 79 BASELINE GROSS BETA YEAR 1 YEAR 2 YEAR 3 YEAR 4 YEAR 5 YEAR 6 Not Vulnerable Samples per System 0 0 0 0 0 0 Systems 50,996 50,996 50,996 50,996 50,996 50,996 Total Samples 0 0 0 0 0 0 Cost per Sample 45 45 Total Cost 0 0 0 0 0 0 Discount Rate 1 1.07 1.14 1.23 1.31 1.4 Present Value Cost 0 0 0 0 0 0 Vulnerable w/ o known contam., GB < 4 Samples per System 6 6 6 6 6 6 Systems 2,125 2,125 2,125 2,125 2,125 2,125 Total Samples 12750 12750 12750 12750 12750 12750 Cost per Sample 65.5 65.5 65.5 65.5 65.5 65.5 Total Cost 835125 835125 835125 835125 835125 835125 Discount Rate 1 1.07 1.14 1.23 1.31 1.4 Present Value Cost 835125 780490.7 732565.8 678963.4 637500 596517.9 Vulnerable w/ o known contam., GB > 4 Samples per System 20 20 20 20 20 20 Systems 0 0 0 0 0 0 Total Samples 0 0 0 0 0 0 Cost per Sample 69.5 69.5 69.5 69.5 69.5 69.5 Total Cost 0 0 0 0 0 0 Discount Rate 1 1.07 1.14 1.23 1.31 1.4 Present Value Cost 0 0 0 0 0 0 Vulnerable w/ known contam. Samples per System 10 10 10 10 10 10 Systems 0 0 0 0 0 0 Total Samples 0 0 0 0 0 0 Cost per Sample 91.7 91.7 91.7 91.7 91.7 91.7 Total Cost 0 0 0 0 0 0 Discount Rate 1 1.07 1.14 1.23 1.31 1.4 Present Value Cost 0 0 0 0 0 0 TOTAL PRESENT VALUE YEARS COVERED INTEREST RATE ANNUALIZED PRESENT VALUE TOTAL SAMPLES BURDEN PER SAMPLE ( HRS.) TOTAL BURDEN ( HRS.) YEARS COVERED AVERAGE ANNUAL BURDEN ( HRS.)

THREE YEAR TOTAL COST 80 THREE YEAR ANNUALIZED COST 81 BASELINE GROSS BETA YEAR 7 YEAR 8 YEAR 9 YEAR 10 YEAR 11 YEAR 12 Not Vulnerable Samples per System 0 0 0 0 0 0 Systems 50,996 50,996 50,996 50,996 50,996 50,996 Total Samples 0 0 0 0 0 0 Cost per Sample 45 45 Total Cost 0 0 0 0 0 0 Discount Rate 1.5 1.61 1.72 1.84 1.97 2.1 Present Value Cost 0 0 0 0 0 0 Vulnerable w/ o known contam., GB < 4 Samples per System 6 6 6 6 6 6 Systems 2,125 2,125 2,125 2,125 2,125 2,125 Total Samples 12750 12750 12750 12750 12750 12750 Cost per Sample 65.5 65.5 65.5 65.5 65.5 65.5 Total Cost 835125 835125 835125 835125 835125 835125 Discount Rate 1.5 1.61 1.72 1.84 1.97 2.1 Present Value Cost 556750 518711.2 485537.8 453872.3 423921.3 397678.6 Vulnerable w/ o known contam., GB > 4 Samples per System 20 20 20 20 20 20 Systems 0 0 0 0 0 0 Total Samples 0 0 0 0 0 0 Cost per Sample 69.5 69.5 69.5 69.5 69.5 69.5 Total Cost 0 0 0 0 0 0 Discount Rate 1.5 1.61 1.72 1.84 1.97 2.1 Present Value Cost 0 0 0 0 0 0 Vulnerable w/ known contam. Samples per System 10 10 10 10 10 10 Systems 0 0 0 0 0 0 Total Samples 0 0 0 0 0 0 Cost per Sample 91.7 91.7 91.7 91.7 91.7 91.7 Total Cost 0 0 0 0 0 0 Discount Rate 1.5 1.61 1.72 1.84 1.97 2.1 Present Value Cost 0 0 0 0 0 0 TOTAL PRESENT VALUE YEARS COVERED INTEREST RATE ANNUALIZED PRESENT VALUE TOTAL SAMPLES BURDEN PER SAMPLE ( HRS.) TOTAL BURDEN ( HRS.) YEARS COVERED AVERAGE ANNUAL BURDEN ( HRS.)

THREE YEAR TOTAL COST THREE YEAR ANNUALIZED COST 82 83 BASELINE GROSS BETA YEAR 13 YEAR 14 YEAR 15 YEAR 16 YEAR 17 YEAR 18 Not Vulnerable Samples per System 0 0 0 0 0 0 Systems 50,996 50,996 50,996 50,996 50,996 50,996 Total Samples 0 0 0 0 0 0 Cost per Sample 45 Total Cost 0 0 0 0 0 0 Discount Rate 2.25 2.41 2.58 2.76 2.95 3.16 Present Value Cost 0 0 0 0 0 0 Vulnerable w/ o known contam., GB < 4 Samples per System 6 6 6 6 6 6 Systems 2,125 2,125 2,125 2,125 2,125 2,125 Total Samples 12750 12750 12750 12750 12750 12750 Cost per Sample 65.5 65.5 65.5 65.5 65.5 65.5 Total Cost 835125 835125 835125 835125 835125 835125 Discount Rate 2.25 2.41 2.58 2.76 2.95 3.16 Present Value Cost 371166.7 346524.9 323691.9 302581.5 283093.2 264280.1 Vulnerable w/ o known contam., GB > 4 Samples per System 20 20 20 20 20 20 Systems 0 0 0 0 0 0 Total Samples 0 0 0 0 0 0 Cost per Sample 69.5 69.5 69.5 69.5 69.5 69.5 Total Cost 0 0 0 0 0 0 Discount Rate 2.25 2.41 2.58 2.76 2.95 3.16 Present Value Cost 0 0 0 0 0 0 Vulnerable w/ known contam. Samples per System 10 10 10 10 10 10 Systems 0 0 0 0 0 0 Total Samples 0 0 0 0 0 0 Cost per Sample 91.7 91.7 91.7 91.7 91.7 91.7 Total Cost 0 0 0 0 0 0 Discount Rate 2.25 2.41 2.58 2.76 2.95 3.16 Present Value Cost 0 0 0 0 0 0 TOTAL PRESENT VALUE YEARS COVERED INTEREST RATE ANNUALIZED PRESENT VALUE TOTAL SAMPLES BURDEN PER SAMPLE ( HRS.) TOTAL BURDEN ( HRS.) YEARS COVERED AVERAGE ANNUAL BURDEN ( HRS.)

THREE YEAR TOTAL COST THREE YEAR ANNUALIZED COST 84 85 BASELINE GROSS BETA YEAR 19 YEAR 20 YEAR 21 YEAR 22 YEAR 23 Not Vulnerable Samples per System 0 0 0 0 0 Systems 50,996 50,996 50,996 50,996 50,996 Total Samples 0 0 0 0 0 Cost per Sample 45 Total Cost 0 0 0 0 0 Discount Rate 3.38 3.62 3.87 4.14 4.43 Present Value Cost 0 0 0 0 0 Vulnerable w/ o known contam., GB < 4 Samples per System 6 6 6 6 6 Systems 2,125 2,125 2,125 2,125 2,125 Total Samples 12750 12750 12750 12750 12750 Cost per Sample 65.5 65.5 65.5 65.5 65.5 Total Cost 835125 835125 835125 835125 835125 Discount Rate 3.38 3.62 3.87 4.14 4.43 Present Value Cost 247078.4 230697.5 215794.6 201721 188515.8 Vulnerable w/ o known contam., GB > 4 Samples per System 20 20 20 20 20 Systems 0 0 0 0 0 Total Samples 0 0 0 0 0 Cost per Sample 69.5 69.5 69.5 69.5 69.5 Total Cost 0 0 0 0 0 Discount Rate 3.38 3.62 3.87 4.14 4.43 Present Value Cost 0 0 0 0 0 Vulnerable w/ known contam. Samples per System 10 10 10 10 10 Systems 0 0 0 0 0 Total Samples 0 0 0 0 0 Cost per Sample 91.7 91.7 91.7 91.7 91.7 Total Cost 0 0 0 0 0 Discount Rate 3.38 3.62 3.87 4.14 4.43 Present Value Cost 0 0 0 0 0 TOTAL PRESENT VALUE YEARS COVERED INTEREST RATE ANNUALIZED PRESENT VALUE TOTAL SAMPLES BURDEN PER SAMPLE ( HRS.) TOTAL BURDEN ( HRS.) YEARS COVERED AVERAGE ANNUAL BURDEN ( HRS.)

THREE YEAR TOTAL COST THREE YEAR ANNUALIZED COST 86 87 BASELINE GROSS BETA TOTAL TOTAL Not Vulnerable Samples per System Systems Total Samples 0 Cost per Sample Total Cost Discount Rate Present Value Cost 0 Vulnerable w/ o known contam., GB < 4 Samples per System Systems Total Samples 293250 Cost per Sample Total Cost Discount Rate Present Value Cost 10072779.39 Vulnerable w/ o known contam., GB > 4 Samples per System Systems Total Samples 0 Cost per Sample Total Cost Discount Rate Present Value Cost 0 Vulnerable w/ known contam. Samples per System Systems Total Samples 0 Cost per Sample Total Cost Discount Rate Present Value Cost 0 TOTAL PRESENT VALUE 10072779.39 YEARS COVERED 23 INTEREST RATE 7% ANNUALIZED PRESENT VALUE ($ 893,595.81)

TOTAL SAMPLES 293250 BURDEN PER SAMPLE ( HRS.) 0.5 TOTAL BURDEN ( HRS.) 146625 YEARS COVERED 23 AVERAGE ANNUAL BURDEN ( HRS.) 6375 THREE YEAR TOTAL COST 2348181.444 88 THREE YEAR ANNUALIZED COST ($ 894,778.45) 89 2000 GROSS BETA 90 Only systems targeted as vulnerable by the State Is the system known to be using contaminated source?

Gross Beta  2000 Monitoring ( Initial monitoring to begin in the 4th year)

Monitoring not required Quarterly Gross Beta screen of 15 pCi/ L;

quarterly iodine 131;

and annual tritium and strontium Yes No No Yes Gross Beta quarterly screen of 50 pCi/ L and annual tritium and strontium.

96 % of CWSs 4 % of CWSs ( then subtract out SW >

100,000)

0 % of CWSs Monthly gross beta and quarterly tritium and strontium Quarterly Gross Beta; annual tritium and strontium > 4 mrem < or = 4 mrem 0 % of CWSs 4 % of CWSs minus SW >

100K Gross Beta MCL = 4 mrem Gross Beta analysis $ 45 Tritium analysis = $ 60 Strontium analysis = $ 153 Iodine 131 = $ 131 Is the system a SW system > 100,000?