Information Collection Request for UCMR 2 May 2005 Prepared by: The Cadmus Group, Inc. 57 Water Street Watertown, MA 02472 Prepared for: Jane Holtorf, Project Officer Phyllis Branson, Work Assignment Manager David Munch, Alternate Work Assignment Manager U. S. Environmental Protection Agency Office of Ground Water and Drinking Water 26 West Martin Luther King Drive Cincinnati, OH 45268 Draft ICR for UCMR 2 Proposed Rule May 2005 i TABLE OF CONTENTS   PART A OF THE SUPPORTING STATEMENT   1 IDENTIFICATION OF THE INFORMATION COLLECTION . . . . . . . . . . . . . . . . . . 1 1( a) Title and Number of the Information Collection . . . . . . . . . . . . . . . . . . . . . . . . . 1 1( b) Short Characterization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 2 NEED FOR AND USE OF THE COLLECTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2( a) Need/ Authority for the Collection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2( b) Practical Utility/ Users of the Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 3 NON DUPLICATION, CONSULTATIONS AND OTHER COLLECTION CRITERIA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 3( a) Non duplication . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 3( b) Public Notice Required Prior to ICR Submission to OMB . . . . . . . . . . . . . . . . . 7 3( c) Consultations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 3( d) Effects of Less Frequent Collection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 3( e) General Guidelines . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 3( f) Confidentiality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 3( g) Sensitive Questions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 4 RESPONDENTS AND THE INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 4( a) Respondents and NAICS/ SIC Codes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 4( b) Information Requested . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 4( b)( i) Data Items . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 4( b)( i)( a) Public Water System Reporting and Record Keeping . . . . . . . 13 4( b)( i)( b) State Reporting and Record Keeping . . . . . . . . . . . . . . . . . . . 15 4( b)( ii) Respondent Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 4( b)( ii)( a) Public Water System Activities . . . . . . . . . . . . . . . . . . . . . . . 15 4( b)( ii)( b) State Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 5 INFORMATION COLLECTED   AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT . . . . . . . . . . . . . . . . . . 20 5( a) Agency Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 5( a)( i) Regulatory Support Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 5( a)( ii) National and Regional Oversight/ Data Analysis . . . . . . . . . . . . . . . . . . . 20 5( a)( iii) Costs for Small System Testing Program . . . . . . . . . . . . . . . . . . . . . . . 21 5( b) Information Collection Methodology and Management . . . . . . . . . . . . . . . . . . . 22 5( c) Small Entity Flexibility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 5( d) Collection Schedule . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 Draft ICR for UCMR 2 Proposed Rule May 2005 ii TABLE OF CONTENTS, continued...

6 ESTIMATING THE BURDEN AND COST OF THE COLLECTION . . . . . . . . . . . . 28 6( a) Estimating Burden and Cost to Public Water Systems . . . . . . . . . . . . . . . . . . . . 28 6( a)( i) Estimating Burden and Labor Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29 6( a)( i)( a) Reading the Regulations/ Guidance Letter . . . . . . . . . . . . . . . . 31 6( a)( i)( b) Monitoring Burden . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32 6( a)( i)( c) Reporting and Record Keeping . . . . . . . . . . . . . . . . . . . . . . . 32 6( a)( i)( d) Public Notification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 6( a)( ii) Estimating Non labor Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 6( a)( iii) Summary of Labor and Non labor Costs to Public Water Systems . . . . 35 6( b) Estimating the Burden and Cost to States . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37 6( c) Estimating Agency Burden and Cost . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40 6( c)( i) Regulatory Support Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40 6( c)( ii) National and Regional Oversight and Data Analysis . . . . . . . . . . . . . . . 41 6( c)( iii) Costs for Small System Testing Program . . . . . . . . . . . . . . . . . . . . . . . 41 6( c)( iv) Estimated Agency Cost and Burden . . . . . . . . . . . . . . . . . . . . . . . . . . . 42 6( d) Estimating the Respondent Universe and Total Burden and Costs . . . . . . . . . . . 44 6( e) Reasons for Change in Burden . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45 6( f) Burden Statement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46   PART B OF THE SUPPORTING STATEMENT   1 SURVEY OBJECTIVES, KEY VARIABLES, AND OTHER PRELIMINARIES . . . 50 1( a) Survey Objectives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50 1( b) Key Variables . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50 1( c) Statistical Approach . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50 1( d) Feasibility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50 2 SURVEY DESIGN . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51 2( a) Target Population and Coverage . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51 2( b) Sample Design . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51 2( b)( i) Sampling Frame . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51 2( b)( ii) Sample Size . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51 2( b)( iii) Stratification Variables . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51 2( b)( iv) Sampling Method . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52 2( b)( v) Multi Stage Sampling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52 2( c) Precision Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52 2( c)( i) Precision Targets . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52 2( c)( ii) Nonsampling error . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53 2( d) Questionnaire Design . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53 Draft ICR for UCMR 2 Proposed Rule May 2005 iii TABLE OF CONTENTS, continued...

3 PRETESTS AND PILOT TESTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53 4 COLLECTION METHODS AND FOLLOW UP . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53 4( a) Collection Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53 4( b) Survey Response and Follow up . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53 5 ANALYZING AND REPORTING SURVEY RESULTS . . . . . . . . . . . . . . . . . . . . . . 54 5( a) Data Preparation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54 5( b) Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54 5( c) Reporting Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 55 APPENDICES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A 56 APPENDIX A: Relevant Authorities in the SDWA 1996 Amendments . . . . . . . . . . . A 1 APPENDIX B: Burden and Cost Exhibits for the Five Year UCMR 2 Cycle of 2007 2011 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B 1 LIST OF EXHIBITS Exhibit 1: Proposed Contaminant List and Sampling Design . . . . . . . . . . . . . . . . . . . . . . . . . . 13 Exhibit 2: Unregulated Contaminant Monitoring Reporting Requirements . . . . . . . . . . . . . . . . 14 Exhibit 3: Time Line of UCMR Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 Exhibit 4: Number of Publicly and Privately Owned Systems Subject to UCMR 2 . . . . . . . . . 24 Exhibit 5: EPA and Small Systems Costs for Implementation UCMR 2 . . . . . . . . . . . . . . . . . . 25 Exhibit 6a: UCMR 2 Relative Cost Analysis for Publicly Owned Systems ( 2007 2011) . . . . . . 26 Exhibit 6b: UCMR 2 Relative Cost Analysis for Privately Owned Systems ( 2007 2011) . . . . . 26 Exhibit 7: Systems to Participate in UCMR 2 Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 Exhibit 8: UCMR 2 Sampling Activity Time Line for Cost and Burden Estimations . . . . . . . . 30 Exhibit 9: Labor Rates Applied for Public Water Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 Exhibit 10: Contaminant Group or Analytical Method . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 Exhibit 11a: Yearly Cost to Systems, by System Size and by Type of Cost ( 2007 2009) . . . . . 36 Exhibit 11b: Per System ( Respondent) and Per Response UCMR Costs ( 2007 2009) . . . . . . . 37 Exhibit 12: Number of States in Each Size Category ( State Resource Model Assumptions) . . . 39 Exhibit 13a: Yearly Cost and Burden to States for Implementation of UCMR ( 2007 2009) . . . 39 Exhibit 13b: Per State ( Respondent) and Per Response UCMR Costs ( 2007 2009) . . . . . . . . . 39 Exhibit 14a: Yearly Cost to EPA for UCMR Implementation, by Type of Cost ( 2007 2009) . . 42 Exhibit 14b: Summary of EPA Burdens and Costs for UCMR Implementation ( 2007 2009) . . 43 Exhibit 15: UCMR 2 National Cost Summary for the ICR period ( 2007 2009) . . . . . . . . . . . . 44 Draft ICR for UCMR 2 Proposed Rule May 2005 iv LIST OF EXHIBITS, continued...

Exhibit 16: UCMR 2 Per Respondent Burden and Cost Summary for the ICR Period ( 2007 2009) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47 Exhibit B 1a: Yearly Cost to Systems, by System Size and by Type of Cost ( 2007 2011) . . . B 1 Exhibit B 1b: Per System ( Respondent) and Per Response UCMR Costs ( 2007 2011) . . . . . B 2 Exhibit B 2a: Yearly Cost and Burden to States for Implementation of UCMR ( 2007 2011) . B 2 Exhibit B 2b: Per State ( Respondent) and Per Response UCMR Costs ( 2007 2011) . . . . . . . B 2 Exhibit B 3a: Yearly Cost to EPA for UCMR Implementation, by Type of Cost ( 2007 2011) B 3 Exhibit B 3b: Summary of EPA Burdens and Costs for UCMR Implementation ( 2007 2011) B 4 Exhibit B 4: National Cost Summary for UCMR 2 Implementation ( 2007 2011) . . . . . . . . . B 4 Exhibit B 5: UCMR 2 Per Respondent Burden and Cost Summary ( 2007 2011) . . . . . . . . . . B 5 Draft ICR for UCMR 2 Proposed Rule May 2005 v ACRONYMS ASDWA Association of State Drinking Water Administrators CCL Contaminant Candidate List CCR Consumer Confidence Report CFR Code of Federal Regulations CWS Community Water System DBP Disinfection Byproduct DBPR Stage 1 Disinfection Byproducts Rule DSMRT Distribution System Maximum Residence Time EPA Environmental Protection Agency EPTDS Entry Point to the Distribution System FR Federal Register FTE Full Time Equivalent GS General Schedule GWUDI Ground Water under the Direct Influence of Surface Water ICR Information Collection Request LCMRL Lowest Concentration Minimum Reporting Level MCL Maximum Contaminant Level MCLG Maximum Contaminant Level Goal MRL Minimum Reporting Level NAICS North American Industry Classification System NCOD National Contaminant Occurrence Database NPDWR National Primary Drinking Water Regulation NTNCWS Non transient Non community Water System OMB Office of Management and Budget OW Office of Water PA Partnership Agreement PT Proficiency Testing PWS Public Water System PWSID Public Water System Identification QA/ QC Quality Assurance/ Quality Control RFA Regulatory Flexibility Act SBA Small Business Administration SDWA Safe Drinking Water Act SRF State Revolving Fund UCMR Unregulated Contaminant Monitoring Regulation Draft ICR for UCMR 2 Proposed Rule May 2005 1 Additional technical corrections to the rule, as well as adjustments to the initial reporting process, were published including: May 16, 2001 ( 66 FR 27215); September 4, 2001 ( 66 FR 46221); and March 12, 2002 ( 67 FR 11043). In total, these rules and revisions constitute " UCMR 1".

1   PART A OF THE SUPPORTING STATEMENT   1 IDENTIFICATION OF THE INFORMATION COLLECTION 1( a) Title and Number of the Information Collection Title: Information Collection Request for UCMR 2 OMB Control Number: 2040 xxxx EPA Tracking Number: 2192.01 1( b) Short Characterization Section 1445( a)( 2) of the Safe Drinking Water Act ( SDWA), as amended in 1996, requires that once every 5 years, beginning in August 1999, the United States Environmental Protection Agency ( EPA) issue a new list of no more than 30 contaminants to be monitored, and procedures for placement of the monitoring data in the National Contaminant Occurrence Database ( NCOD). EPA's program must also include a nationally " representative sample of systems serving 10,000 or fewer persons" that will be required to monitor, and a frequency and schedule for monitoring.

EPA published the revisions to the Unregulated Contaminant Monitoring Regulation ( UCMR) for public water systems ( PWSs) on September 17, 1999 ( 64 FR 50556). This revised regulation included programmatic changes, and provided a list of contaminants for which monitoring was required or would be required in the future. Several supplemental rules were published to establish analytical methods and to provide clarifications and refinements to the initial rule ( March 2, 2000 ( 65 FR 11372), January 11, 2001 ( 66 FR 2273), and October 29, 2002 ( 67 FR 65888)) 1. UCMR 1 established a three tiered approach for monitoring contaminants based on the availability of analytical methods and contaminant properties.

EPA has developed a contaminant list and sampling design for the second UCMR cycle ( i. e., UCMR 2). The rule for UCMR 2 builds on the established structure of UCMR 1, and proposes some changes to the rule design. UCMR 2 monitoring will take place in 2007 2011. The applicable Information Collection Request ( ICR) period is 2007 2009. Estimates of implementation burden and cost over the entire five year UCMR cycle of 2007 2011 are attached as Appendix B to this ICR. Draft ICR for UCMR 2 Proposed Rule May 2005 2 Transient non community water systems and those systems that purchase all of their water from another PWS are excluded from regulation.

2 Assessment Monitoring, the largest in scale of the three UCMR monitoring components, will be conducted from July 2007 through June 2010 by 800 systems serving 10,000 or fewer ( hereafter referred to as small systems), and by all systems serving 10,001 and over, for 11 List 1 contaminants. 2 Under Assessment Monitoring, contaminants for which standard analytical methods are available are monitored to assess national occurrence in drinking water. It is assumed for this cost estimation that one third of systems will monitor each year.

The Screening Survey ( for 15 List 2 contaminants) will be conducted from July 2007 through June 2009 by 800 systems serving 100,000 or fewer, and all systems serving more than 100,000 people ( 322 systems). Small systems will not be subject to more than one component of UCMR 2 monitoring.

Respondents to UCMR 2 will include 1,280 small water systems ( 800 for Assessment Monitoring, and 480 for the Screening Survey), the 3,110 large and very large PWSs, and the 56 States and primacy agents ( referred to collectively as " States" for simplicity in this document), for a total of 4,446 respondents. The frequency of response varies across respondents and years.

Small systems that are selected for UCMR 2 monitoring will sample an average of 2.2 times per system ( i. e., number of responses per system) across the three year ICR period of 2007 2009. The estimated burden per response for small systems is 3.1 hours. Large systems ( those serving 10,001 to 100,000 people) and very large systems ( those serving more than 100,000 people) will sample and report an average of 2.5 and 3.6 times per system, respectively, across the three year ICR period of 2007 2009. The estimated burdens per response for large and very large systems are 8.9 and 12.9 hours, respectively.

EPA expects that States will incur only labor costs associated with UCMR 2 implementation. State activities are determined through their individual Partnership Agreements with EPA. To estimate State burden, it was assumed that State participation levels would reflect the participation levels which occurred in UCMR 1. States are assumed to incur 3.0 responses over the three year ICR period related to coordination with EPA and systems, with an average burden per response of 203.2 hours. In aggregate, during the ICR period of 2007 2009, the average response ( e. g., responses from systems and States) is associated with a burden of 10.7 hours, with a labor plus non labor cost of $ 1,609 per response.

The annual average per respondent burden hours and costs for the ICR period of 2007 2009 are: small systems   2.3 hour burden at $ 57 for labor; large systems   7.5 hours at $ 204 for labor, and $ 1,894 for analytical costs; very large systems   15.6 hours at $ 512 for labor, and $ 7,392 for analytical costs; and States   203.2 hours at $ 11,107 for labor. Annual average burden and cost per respondent ( including both systems and States) is estimated to be 9.02 hours, with a labor plus non labor cost of $ 1,355 per respondent ( note that small systems do not pay for testing costs, so they only incur labor costs). Draft ICR for UCMR 2 Proposed Rule May 2005 3 The Agency estimates the annual burden to EPA for proposed UCMR program activities during the ICR years of 2007 2009 to be approximately 9,533 hours, at an annual labor cost of $ 0.60 million. EPA's annual non labor costs are estimated to be $ 2.8 million. EPA's non labor costs are primarily attributed to the cost of sample testing for small systems ( testing is just under 90 percent of non labor cost). Draft ICR for UCMR 2 Proposed Rule May 2005 4 2 NEED FOR AND USE OF THE COLLECTION 2( a) Need/ Authority for the Collection The information collected under this action is required by EPA to carry out its regulatory development responsibilities under SDWA section 1445( a)( 2), Monitoring Program for Unregulated Contaminants. This section, as amended in 1996, requires that once every 5 years beginning in August 1999, the Agency issue a new list of no more than 30 contaminants to be monitored, and procedures for placement of the monitoring data in NCOD. EPA's program must also include a nationally " representative sample of systems serving 10,000 or fewer persons" that will be required to monitor, and a frequency and schedule for monitoring.

Section 1412( b)( 4) of SDWA, as amended in 1996, requires EPA to promulgate maximum contaminant level goals ( MCLGs) and promulgate National Primary Drinking Water Regulations ( NPDWRs) for contaminants that: may have adverse human health effects; are known to or anticipated to occur in PWSs; or, in the opinion of the Administrator, present an opportunity for reducing health risks. The NPDWRs specify maximum contaminant levels ( MCLs) or treatment techniques for drinking water contaminants ( 42 USC 300g 1). An MCL must be set as close to the MCLG as possible. NPDWRs apply to PWSs ( 42 USC 300f( 1)( A)). Section 1412( b)( 1) requires the Agency to develop a list of unregulated contaminants for regulatory consideration ( i. e., the candidate contaminant list ( CCL)), to issue regulations that establish criteria for listing contaminants, and to carry out the UCMR Program. The Agency was required to issue the list of contaminants by August 1999, and every 5 years thereafter.

Section 1445( a)( 1) of the Act requires each PWS to " 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, [ or] ... in evaluating the health risks of unregulated contaminants ...". This section authorizes EPA to require systems to monitor, provide the Agency with these data, and to maintain records of this information.

In addition, section 1401( 1)( d) of the SDWA 1996 Amendments defines NPDWRs to include " criteria and procedures to assure a supply of drinking water which dependably complies with such maximum contaminant levels; including accepted methods for quality control and testing procedures ...". This section authorizes EPA to require systems and laboratories to use Agency approved methods and quality assurance criteria for collecting and analyzing water samples.

The sections from the SDWA 1996 Amendments, discussed above, are included as Appendix A of this document, in order by section number. Draft ICR for UCMR 2 Proposed Rule May 2005 5 2( b) Practical Utility/ Users of the Data The unregulated contaminant monitoring data collected under this rule will be used to support: ( 1) the development and interactive evolution of the CCL; ( 2) the Administrator's determination of whether to regulate a contaminant; and ( 3) regulation development. In addition, if the contaminant has significant occurrence and health effects, EPA will use the results as part of an exposure assessment; for establishing the baseline for health effects and economic analyses; for contaminant co occurrence analysis; and for treatment technology evaluation, including contaminant source management. Further, the results may suggest that the occurrence of certain contaminants may be significant enough to initiate research on health effects and treatment technology. Finally, the data may guide future source water protection efforts.

System level records of the analytical results of this monitoring will be maintained by each PWS. EPA approved laboratories will report these results to EPA's electronic data reporting system. PWSs will review the information posted by the laboratory and submit the approved data to the State and EPA, via the electronic reporting system.

The data collected through the UCMR program is being stored in the NCOD to facilitate analysis and review of contaminant occurrence, to guide the development of the CCL process, and to support the Administrator's determination of whether or not to regulate a contaminant in the interest of protecting public health.

The primary user of the information collected under this ICR will be EPA's Office of Water ( OW). Other users of this information may include the following:

° Primacy agencies, which include State regulators, Indian Tribes, and, in some instances, EPA Regional Administrators ° PWS managers ° Staff from other EPA programs ( such as Comprehensive Environmental Response, Compensation, and Liability Act; the Resource Conservation and Recovery Act; and the Office of Enforcement and Compliance Assurance) ° Federal Emergency Management Administration ° Centers for Disease Control and Prevention ° Military bases ° Rural Development Administration/ Farmers Home Administration ° Department of Interior ° Department of Housing and Urban Development ° United States Army Corps of Engineers ° White House task forces ° American Water Works Association ° Association of Metropolitan Water Agencies ° National Rural Water Association ° National Association of Water Companies ° Association of State Drinking Water Administrators ( ASDWA) Draft ICR for UCMR 2 Proposed Rule May 2005 6 ° Natural Resources Defense Council ° Consumers Federation of America ° Small Business Administration ° Other environmental and industry groups ° News organizations ° Private industries ° Individuals. Draft ICR for UCMR 2 Proposed Rule May 2005 7 3 NON DUPLICATION, CONSULTATIONS AND OTHER COLLECTION CRITERIA 3( a) Non duplication The data required by UCMR are not available from any other source and are not duplicative of information otherwise accessible to EPA. With public health protection as its top priority, EPA drew upon several different sources in developing the UCMR 2 contaminant list. In the early stages of list development, EPA began by identifying a broad list of over 200 contaminants. These contaminants were: ( 1) UCMR " reserved" contaminants ( i. e., those identified as priorities under UCMR 1 but reserved for later monitoring because methods were not yet available); ( 2) contaminants on the first CCL ( either deferred pesticides for which additional information was needed or suspected endocrine disruptors); or ( 3) other emerging contaminants ( those identified as probable carcinogens or those that could be identified by analytical methods used in measuring other priority UCMR contaminants). EPA pared down the list based on previously established priorities, health effects, and the availability of an analytical method and analytical reference standard.

3( b) Public Notice Required Prior to ICR Submission to OMB To comply with the 1995 Amendments to the Paperwork Reduction Act, EPA is seeking public comment on this ICR. To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for UCMR 2, which includes this ICR, under Docket ID No. OW 2004 0001. The public can submit any comments related to the ICR for this proposed action to EPA and the Office of Management and Budget ( OMB).

3( c) Consultations EPA's Office of Ground Water and Drinking Water developed a process for stakeholder involvement in its regulatory activities for the purpose of providing early input to regulation development. When designing and developing the UCMR program, prior to 1999, EPA held meetings for: developing the CCL; establishing the information requirements of the NCOD; and contaminant selection. During the initial development of the UCMR program, stakeholders including PWSs, States, industry, and other organizations attended meetings to discuss UCMR. Seventeen other meetings were held specifically concerning UCMR development. A description of public involvement activities related to UCMR are provided in the September 1999, UCMR Final Rule Federal Register at 64 FR 50556.

Specific to the development of UCMR 2, a stakeholder meeting was held on October 29, 2003 in Washington, DC. There were 25 attendees, representing State agencies, federal agencies, laboratories, PWSs, and drinking water associations. The topics of presentations and discussions included: the rationale for selecting a new list of contaminants; analytical methods to be used in Draft ICR for UCMR 2 Proposed Rule May 2005 8 measuring these contaminants; sampling design, particularly for the Screening Survey monitoring; procedure for determining the lowest concentration minimum reporting levels ( LCMRLs); validation of laboratory performance at or below the minimum reporting level ( MRL); revisions to data elements; and other proposed revisions based on lessons learned during implementation of UCMR 1.

3( d) Effects of Less Frequent Collection The Agency has considered a wide range of alternatives for frequency of collection that would still allow the Agency to meet its statutory requirements and overall objectives. Less frequent data collection than that being implemented would seriously affect the integrity of the data and result in insufficient data to fulfill the needs envisioned by the 1996 SDWA Amendments, including the continued development of the CCL, support of the Administrator's regulatory determinations, and overall regulation development.

Monitoring frequencies were determined based on statutory requirements, which specify that monitoring be varied based on the number of people served by a system, contaminants likely to be found, and source of supply. The monitoring frequency design also considers that the number of people served affects exposure to contaminants, as well as the resources available to undertake monitoring activity. The collection frequencies in this rule are discussed further in section 5( b), Part A of this ICR document. Monitoring frequencies have been carefully devised based on the following factors:

° data quality needed for a representative sample; ° precision and accuracy needed from the representative sample; ° number of people served by the system; ° source of the supply ( e. g., surface water or ground water); ° contaminants likely to be found; and ° temporal variability in occurrence.

The Assessment Monitoring component of data collection will be conducted in July 2007 through June 2010 by all large ( those systems serving 10,001 to 100,000 people) and very large systems ( those systems serving more than 100,000 people), and by a nationally representative sample of 800 small systems ( those serving 10,000 people or fewer). The Screening Survey component will be conducted in July 2007 through June 2009 by all very large systems and by a sample of 800 systems serving 100,000 or fewer people. Samples will be collected from entry points to the distribution system ( EPTDSs). As specified in the proposed rule, ground water systems with multiple EPTDSs will only be required to sample at representative sampling locations for each ground water source, as long as those sites have been approved. In addition, Screening Survey systems that are required to monitor for disinfection byproducts ( DBPs) under the Stage 1 Disinfection Byproducts Rule ( DBPR) will be required to sample for nitrosamines at one distribution system sampling point per treatment plant, as well as their EPTDS sampling locations. Draft ICR for UCMR 2 Proposed Rule May 2005 3 Ground water systems are required to sample only two times per year because they generally show less seasonal fluctuation than surface water or GWUDI systems. Rule language regarding sampling schedule/ frequency ensures that both surface and ground water systems collect at least one of their samples during the most vulnerable period, which the rule specifies by default to be May  July.

9 For both Assessment Monitoring and Screening Surveys, samples will be collected twice during the monitoring year for ground water sampling locations3, and four times during the monitoring year for sampling locations that are fed in whole or part by a surface water or ground water under the direct influence of surface water ( GWUDI) source. Multiple samples during a year are necessary to capture the annual variability in contaminant occurrence to approach an adequate characterization of potential exposure. The required sampling frequencies will help provide the quality and quantity of data that will be statistically necessary for regulatory determinations. The Agency will schedule the year and months of system monitoring. Though large systems will have the option of changing their schedules by coordinating a new schedule with EPA.

EPA is maintaining the same statistical design that was established under UCMR 1 for its UCMR 2 national representative sample of 800 small systems and continuing with a census of large water systems for Assessment Monitoring. EPA believes that the combination of a nationally representative sample of small systems and a census of large systems provides a powerful tool for assessing contaminant occurrence in PWSs, and that this is the most effective and accurate survey approach. A sample of 800 systems from the universe of over 61,000 small systems will provide a confidence level of 99 percent with an allowable error of ± 1 percent. The set of representative systems are distributed among different size categories, but weighted by population served, to ensure that the sample can provide estimates of exposure.

EPA has selected these high standards to ensure the quality of the estimation. EPA considered larger sample frames because of the many uncertainties involved, but the sample size of 800 was deemed adequate to meet the needs for the national estimate. Smaller sample sizes ( i. e., fewer systems monitored) were also considered, but rejected. In general, many population surveys with continuous variables use a lower level of confidence ( 95 percent) and/ or a larger allowable error. However, the larger possible error is not considered acceptable for this program. Examination and analysis of current occurrence data show that many contaminants that are currently regulated, or being considered for regulation occur in 1 percent or less of systems on a national basis. For many contaminants, a 1 percent occurrence nationally translates into a substantially larger occurrence regionally. Also, even a small percentage of systems with detections can translate into a significant population affected. With a greater margin of error, and the resultant smaller sample size, such occurrence might be missed entirely. Also, it is necessary for EPA to make some judgements about the occurrence of contaminants in relation to source waters and different size categories of systems. Many statutes and current regulations differentiate implementation requirements based on system size or water source. While combining sampling results from the representative sample of small systems with that from all large systems provides increased power in the total sample, EPA must be able to evaluate occurrence, and Draft ICR for UCMR 2 Proposed Rule May 2005 10 possible regulatory options, related to the small systems. SDWA and many current rules focus on burden reduction for small systems when feasible. Also, there are many other uncertainties and sources of variance in such a sample program. For example, all contaminants have censored distributions ( i. e., " less than detection level" analytical results) and there are a myriad of factors that affect variability and vulnerability of ground water systems. It remains unclear how normal sampling theory accommodates these. Hence, the high confidence level, low allowable error, and larger sample size should help to ensure adequate data to meet the objectives of the UCMR program.

The sample size for the Screening Survey under UCMR 2 will be increased to ensure the data can be used to support regulatory determinations, and rule development, if warranted. Thus, if a contaminant of concern is found to occur with some significance during the Screening Survey, it may not be necessary to conduct Assessment Monitoring. EPA may instead be able to make a regulatory determination based on these data and move to protect public health more quickly. The new Screening Survey design also accounts for possible laboratory capacity issues related to the use of uncommon methods.

The proposed design increases confidence in the sampling results in two ways. First, the Screening Survey would use a larger stratified random sample of 800 systems ( compared to 300 under UCMR 1), allocated across five strata for systems serving 100,000 or fewer people. The sample size is derived from the same rationale as that for Assessment Monitoring, but the sample frame is expanded to include large systems serving between 10,001 and 100,000 people. Second, the Screening Survey will include a census of the largest PWSs, those serving 100,001 or more people ( 322 systems), referred to as " very large" systems. Using a census of these very large systems will minimize the possibility of missing contaminant occurrence at the systems that serve the largest portion of the population, while keeping the number of systems required to conduct the Screening Survey relatively small.

There will be no " Index System" component to the UCMR 2 program. Under UCMR 1, samples were collected from 30 small Index Systems during all 5 years of the monitoring cycle to assess any trends in temporal occurrence, other data variability, or program problems. EPA is not proposing Index System monitoring for UCMR 2 based on the lack of contaminant occurrence observed at Index Systems monitored in UCMR 1.

EPA has further reduced the number of systems burdened by not requiring systems that purchase all of their water to monitor. The national sample ( described above) will exclude systems that purchase the entirety of their water from other systems, to minimize redundant sampling of sources. Further, exposure estimates can be extrapolated to purchased systems from the monitoring data of the original source systems.

The UCMR program will also exclude transient, non community systems. Furthermore, projecting exposure from such systems is complex and inconclusive because of the transient nature of the population served by them. The results from the small community water systems Draft ICR for UCMR 2 Proposed Rule May 2005 11 ( CWSs) and non transient non community water systems ( NTNCWSs) can be extrapolated to these systems.

Since it is possible that certain contaminants are not likely to be found if their associated chemical use does not occur in a particular State, UCMR includes a provision for waivers for large systems on a State wide, chemical specific basis. However, for small systems, waivers will not be considered because eliminating small systems from the nationally representative sample would compromise the data quality and consistency requirements of a representative sample. The representative sample must provide adequate information on both the presence and absence of contaminants for the systems sampled. Furthermore, since EPA will pay for this testing, it does not place a significant burden on these small systems.

3( e) General Guidelines This ICR has been completed in accordance with the October 2001 version of EPA's Guide to Writing Information Collection Requests Under the Paperwork Reduction Act of 1995 ( hereafter, the " ICR Handbook"). The ICR Handbook was prepared by EPA's Office of Environmental Information, Office of Information Collection, Collection Strategies Division. The ICR Handbook provides the most current instructions for ICR preparation to ensure compliance with the 1995 Paperwork Reduction Act Amendments and OMB's implementing guidelines.

EPA is taking an approach that minimizes burden to the respondents. In addition, this collection does not violate any of the OMB guidelines for information collection activities. Specifically, the respondents are not required to:

° Report information to EPA more than quarterly. ° Prepare a written response to a collection of information in fewer than 30 days after receipt of a request. ° Submit more than an original and two copies of any document. ° Retain records, other than health, medical, government contract, grant in aid or tax records, for more than three years. ° Participate in a statistical survey that is not designed to produce data that can be generalized to the universe of the study. ° Use a statistical data classification that has not been reviewed and approved by OMB. ° Receive a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use. ° Submit proprietary, trade secret, or other confidential information unless EPA can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law. Draft ICR for UCMR 2 Proposed Rule May 2005 12 3( f) Confidentiality This information collection does not require respondents to disclose confidential information.

3( g) Sensitive Questions No questions of a sensitive nature are included in any of the information collection requirements outlined in this ICR. Draft ICR for UCMR 2 Proposed Rule May 2005 13 4 RESPONDENTS AND THE INFORMATION 4( a) Respondents and NAICS/ SIC Codes Data associated with this ICR are collected and maintained by PWSs. States, Territories, and Tribes with primacy to administer the regulatory program for PWSs under SDWA may participate in UCMR 2 implementation through a Partnership Agreement ( PA). These primacy agencies may sometimes conduct monitoring and maintain records. The North American Industry Classification System ( NAICS) code for PWSs is 22131. The NAICS code for State agencies that include drinking water programs are classified as 92411 ( Administration of Air and Water Resources and Solid Waste Management Programs) or 92312 ( Administration of Public Health Programs).

4( b) Information Requested This ICR summarizes the data items and respondent activities associated with UCMR 2.

4( b)( i) Data Items A discussion of data and information that are part of the reporting and record keeping requirements for systems is found below in section 4( b)( i)( a), Part A of this ICR document. The requirements for States are discussed below in section 4( b)( i)( b), Part A of this ICR document.

4( b)( i)( a) Public Water System Reporting and Record Keeping Section 141.35 requires PWSs that are subject to the UCMR requirements to report monitoring results for the 26 contaminants listed in § 141.40 to EPA ( see Exhibit 1 for the contaminant list). The proposed rule modifies and clarifies several of the requirements related to reporting of contact information by all PWSs. Modifications and clarifications to reporting requirements for large systems include: reporting sampling location and contact information prior to monitoring; submitting proposals for representative EPTDSs; ensuring electronic reporting of analytical results and associated data elements by laboratories; and reviewing, approving, and submitting monitoring data that was posted by laboratories.

Exhibit 1: Proposed Contaminant List and Sampling Design List 1, Assessment Monitoring 1,3 dinitrobenzene 2,4,6 trinitrotoluene ( TNT)

2,2', 4,4' tetrabromodiphenyl ether ( BDE 47) Dimethoate 2,2', 4,4', 5 pentabromodiphenyl ether ( BDE 99) Hexahydro 1,3,5 trinitro 1,3,5 triazine ( RDX)

2,2', 4,4', 5,5' hexabromobiphenyl ( 245 HBB) Terbufos sulfone Draft ICR for UCMR 2 Proposed Rule May 2005 Exhibit 1: Proposed Contaminant List and Sampling Design List 1, Assessment Monitoring 14 2,2', 4,4', 5,5' hexabromodiphenyl ether ( BDE 153) Perchlorate 2,2', 4,4', 6 pentabromodiphenyl ether ( BDE 100)

List 2, Screening Survey Acetochlor Metolachlor OA Acetochlor ESA N nitroso diethylamine ( NDEA)

Acetochlor OA N nitroso dimethylamine ( NDMA)

Alachlor N nitroso di n butylamine ( NDBA)

Alachlor ESA N nitroso di n propylamine ( NDPA)

Alachlor OA N nitroso methylethylamine ( NMEA)

Metolachlor N nitroso pyrrolidine ( NPYR)

Metolachlor ESA The proposed action also modifies the reporting requirements to make reported results more useful for sound scientific analyses of the occurrence of unregulated contaminants. Some of the reporting requirements will remain the same, a few are clarified, some have been removed, and one new additional data element is being proposed. The 15 required data elements are listed in Exhibit 2. Large systems must electronically report data elements 1 through 5, and 7 through 15 if conducting Assessment Monitoring, and all 15 if conducting Screening Survey. Small systems must record data elements 1 through 5, and 7 if conducting Assessment Monitoring, and 1 through 7 if conducting Screening Survey. All systems participating in UCMR monitoring must inform EPA of any changes to data elements 1 through 6, if applicable.

Exhibit 2: Unregulated Contaminant Monitoring Reporting Requirements 1. Public Water System Identification ( PWSID) Code 9. Contaminant 2. Public Water System Facility Identification Code 10. Analytical Method Code 3. Water Source Type 11. Sample Analysis Type 4. Sampling Point Identification Code 12. Analytical Results  Sign 5. Sampling Point Type Identification Code 13. Analytical Result  Value 6. Disinfectant Residual Type ( applies only to those systems required to conduct the Screening Survey) 14. Laboratory Identification Code 7. Sample Collection Date 15. Sample Event Code 8. Sample Identification Code Draft ICR for UCMR 2 Proposed Rule May 2005 15 4( b)( i)( b) State Reporting and Record Keeping As was true for UCMR 1, the UCMR 2 proposed regulation will be a direct implementation rule, and therefore States will not be required to report to EPA. Implementation activities for each State will be identified and determined through PAs with EPA. If participating in a PA, States will at a minimum be reviewing and revising Initial State Monitoring Plans, notifying systems of their UCMR responsibilities, and providing EPA with a list of the systems notified. Because States have no specified reporting cycle, it is assumed that States have 1.0 response per year, encompassing all communication and coordination activities with EPA and systems.

4( b)( ii) Respondent Activities Respondents include both PWSs and States. System activities and State activities are discussed below in sections 4( b)( ii)( a) and 4( b)( ii)( b), respectively ( Part A of this ICR document).

4( b)( ii)( a) Public Water System Activities To comply with the requirements in this regulation, systems are expected to conduct the following activities:

° read regulations and/ or letter from State or EPA which outline requirements; ° monitor or provide monitoring assistance ( e. g., sample collection and shipping); ° report and maintain records; and ° report to the public.

Each of these activities are discussed in more detail below.

Read Regulations/ State Letter: All PWSs that are participating in UCMR monitoring are assumed to read the UCMR regulations and/ or a State issued guidance letter during 2007. Small systems can rely on summarized information from the State or EPA for information pertaining to the regulation, rather than reading the regulation.

Monitoring or Monitoring Assistance: Monitoring activities that are considered in the system cost and burden estimates include receiving sampling kits from the laboratory, reading sampling instructions, and collecting and shipping the sample. Assessment Monitoring is scheduled to occur during July 2007 through June 2010 for 11 chemical contaminants. The Screening Survey is scheduled for July 2007 through June 2009 for 15 other chemical contaminants. Because an equal percentage of systems are assumed to monitor during each consecutive 12 month period, all systems required to conduct Assessment Monitoring will monitor during the ICR period of 2007 2009, however, the last group of systems will have only one half of their monitoring completed ( with January through June of 2010 to complete their monitoring). All required Screening Survey monitoring will take place during the ICR period. To Draft ICR for UCMR 2 Proposed Rule May 2005 16 provide a comprehensive cost estimate for the proposed rule, Appendix B provides monitoring costs for the entire monitoring period of 2007 2011.

For both Assessment Monitoring and the Screening Survey, surface water ( and GWUDI) sampling points will be monitored four times during the applicable year of monitoring, and ground water sampling points will be monitored twice during the applicable year of monitoring. Monitoring will be conducted at EPTDSs. Large ground water systems with multiple EPTDSs will only be required to sample at representative sampling locations for each ground water source, as long as those sites have been approved by EPA or the State. In addition, Screening Survey systems that are required to monitor for DBPs will be required to sample for nitrosamines at one distribution system sampling point per treatment plant ( i. e., at the distribution system maximum residence time ( DSMRT)), as well as their EPTDS sampling locations.

Reporting and Record Keeping: As noted in section 4( b)( i)( a), Part A of this ICR document, the proposed rule modifies and clarifies several of the requirements related to reporting of contact information, reporting of sampling location data, electronic reporting by laboratories, and data elements associated with monitoring data. Activities related to these reporting requirements include:

° Reporting Prior to Monitoring Contact information: As under UCMR 1, large systems are required to report contact information to EPA. This information includes the name, affiliation, mailing address, phone number, facsimile number, and e mail address for the PWS Technical Contact and PWS Official ( i. e., the official spokesperson for a PWS's UCMR activities). The proposed rule clarifies that the information must be submitted to EPA's electronic data reporting system within a specified time frame after rule promulgation. Small systems must provide this information by mail, in response to a specific written request that they will receive from EPA.

Sampling location information: Prior to sampling, large PWSs must also provide inventory information related to each applicable sampling location. For each sampling location or each approved representative sampling location, large PWSs must submit: PWS identification ( PWSID) code; PWS facility identification code; sampling point identification code; sampling point type identification code; sampling location water type. In addition, large systems that are required to conduct Screening Survey monitoring must report the disinfectant( s) used to maintain a residual in the distribution system for each distribution system sampling location.

Representative EPTDS proposal: Some systems that use ground water as a source and have multiple EPTDSs may monitor at representative entry point( s), rather than at each EPTDS. To qualify, these ground water systems must have either the same treatment or no treatment at all of their well sources; and they must Draft ICR for UCMR 2 Proposed Rule May 2005 17 have an EPTDS for each well within a well field ( resulting in multiple EPTDSs from the same source, such as an aquifer). Systems meeting these criteria can submit a proposal to EPA or the State. The proposal must demonstrate that any EPTDS selected as representative of the ground water supplied from multiple wells be associated with an individual well that draws from the same aquifer as the multiple wells ( i. e., those being represented).

° Reporting Monitoring Results Small systems: Under UCMR 1, small systems were technically held to the same data review and approval requirements as those for large systems. However, because EPA pays for and organizes the small system testing program, this review and approval step for small systems proved impractical. Under UCMR 2, small systems would only be required to record system and sample location information on the sampling forms and bottles that are sent to them by the UCMR Sampling Coordinator. The schedule for submitting this information will be specified in the instructions sent to the system.

Large systems: The proposed rule specifies that laboratories must post the analytical results and associated data elements to EPA's electronic data reporting system within 120 days of sample collection. The proposed rule also clarifies that large systems must ensure that their laboratory meets this requirement, and that systems review, approve, and submit the data to the State and EPA via the electronic reporting system within 60 days from when the laboratory posts the data. After 60 days from the laboratory's posting, if the PWS has not approved and submitted the data, the data will be considered approved and final for EPA review.

° Record Keeping Section 141.33 requires systems to maintain records of chemical monitoring data for 10 years. No changes are being made to those record keeping requirements.

Reporting to the Public: SDWA section 1445( a)( 2)( E) requires notification of the results of the UCMR program to be made available to those served by the system. CWSs are required to notify their users of the detection of any contaminants ( including unregulated contaminants) in their Consumer Confidence Reports ( CCRs), pursuant to § 141.153( d)( 3)( iv), published in the Federal Register ( 63 FR 44512). Monitoring and reporting violations for all systems ( CWSs and NTNCWSs) will be reportable under the Public Notification Rule ( 64 FR 25964 ( May 13, 1999)).

4( b)( ii)( b) State Activities For UCMR 1, EPA estimated State burdens and costs using the 1993 State Resource Model ( documented in the " Resource Analysis Computer Program for State Drinking Water Draft ICR for UCMR 2 Proposed Rule May 2005 18 Agencies"). That model was designed by EPA in coordination with ASDWA and required specific input for a list of activities and variables related to State operation of the UCMR drinking water program ( e. g., number of systems affected, estimates of violation rates, etc.). Since that time, EPA and ASDWA have worked together to update and improve the previous version of the resource model. EPA used the updated resource model ( the " 2001 ASDWA Drinking Water Program Resource Needs Self Assessment", as documented in: " Public Health Protection Threatened by Inadequate Resources for State Drinking Water Programs  An Analysis of State Drinking Water Program Resources, Needs, and Barriers"; ASDWA, April 2003) to estimate resources that States may need for the oversight and implementation of UCMR 2. Assumptions that were applied in using this resource assessment tool are described in section 6( b), Part A of this ICR document. EPA assumes that State participation will closely reflect that which occurred during UCMR 1. Therefore, model estimates were adjusted to account for actual levels of prior State participation.

Since UCMR is a " direct implementation" rule, specifics of each State's role will be delineated in PAs between the States and EPA. However, in response to the regulation, EPA anticipates that State activities will generally include EPA coordination activities/ PAs, data management and support, program implementation, and training/ overhead. Though some States may choose to conduct sampling for their systems, this activity is not part of the PA agreement and is optional for States. Burden for sampling is currently attributed to systems only. If States choose to conduct monitoring for systems, burden would be similar to that estimated for systems.

State Coordination with EPA/ PAs: State activities that involve coordination with EPA include coordination and drafting of a PA, review of and response to EPA's proposed State Monitoring Plan, review of PWS proposals for representative EPTDSs, and general ongoing coordination.

Review of State Monitoring Plans will be one of the first UCMR activities to take place at the State level. Each State will receive a proposed initial State Monitoring Plan from EPA. This plan will list all systems that will be required to conduct Assessment Monitoring and the Screening Surveys, including small and large systems that were statistically selected as a sample, and those large systems subject to the rule by meeting applicability criteria. For systems that are part of the sample, EPA will also generate a list to provide similar replacement systems for States to select from, for those systems that may not have been correctly specified in the initial plan. If a State identifies systems on the original proposed State Monitoring Plan that it determines are not appropriate for the representative sample ( e. g., if systems are inactive, or have switched to purchased water), the State can propose an alternative plan by selecting other systems from EPA's alternate list to replace the ineligible systems. The State Monitoring Plans will also specify the year and months during which regulated systems will monitor. States will have the option to modify these schedules.

Some systems that use ground water as a source of water are expected to submit a proposal for monitoring at representative entry point( s), rather than monitor at every EPTDS. State involvement in the review of these proposals will be determined in the PA process. Draft ICR for UCMR 2 Proposed Rule May 2005 19 EPA also recognizes that it will be necessary for States to maintain ongoing communications with EPA regarding the requirements of UCMR. An example of this would be instances when States need clarification and guidance regarding a specific requirement of the regulation.

Data Management and Support: Though there are no data management and support activities included in UCMR, EPA recognizes that many States will update their databases to accommodate the revised UCMR data elements. Activities will likely include data entry/ downloading of data, and general record keeping.

Program Implementation: Program implementation activities for each State may include notification and guidance letter to systems, data review, ongoing system support, and enforcement.

Following review and finalization of State Monitoring Plans, participating States will prepare a notification letter that describes system monitoring schedules and requirements under the regulation. These States will send notification to each applicable system and send the list of these notified systems to EPA. It is also likely that States will receive telephone calls from water systems asking for clarification and guidance pertaining to the requirements of UCMR. States may choose to review monitoring results, in part to determine whether a system has met its monitoring and reporting requirements.

State Staff Training and Overhead: Technical staff are assumed to participate in rulespecific training designed to assist them in understanding the regulation, their roles and responsibilities, and to allow the State to better provide technical assistance to the systems. In addition, general overhead costs, such as clerical and managerial needs, are allocated to the UCMR staff requirements in the standard State Resource Model, which allocates support staff needs as a percentage of professional staff needs. See section 6( b), Part A of this ICR document, for further discussion of model assumptions. Draft ICR for UCMR 2 Proposed Rule May 2005 20 5 INFORMATION COLLECTED   AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT 5( a) Agency Activities EPA Headquarters and Regional offices will be responsible for oversight of State PWS programs, and processing and analysis of the UCMR data. EPA implementation activities are categorized, as follows, into three major categories: regulatory support activities; program oversight and data analysis; and small system testing program, which are described below, in 5( a)( i)( iii).

5( a)( i) Regulatory Support Activities Regulatory support activities include: laboratory approval and quality assurance/ quality control; and technical support to PWSs, such as guidance documents.

Laboratory Approval and Quality Assurance/ Quality Control ( QA/ QC) Activities: EPA anticipates incurring various costs related to laboratory approvals and laboratory quality assurance and control, including the following activities:

° Laboratory approvals/ Proficiency Testing ( PT) program  EPA will assess whether laboratories meet the required equipment, laboratory performance, and data reporting criteria. EPA will register and evaluate laboratories based on the applications. Selected laboratories will then participate in the UCMR 2 PT program. EPA plans to conduct these laboratory assessments during 2006; however, these costs are included with the 2007 costs to reflect the costs of the five year UCMR 2 program ( 2007 2011). ° QC audits of contract laboratories  EPA expects to conduct QC audits at each of the approved laboratories during each year of UCMR 2 monitoring ( July 2007 through June 2010). ° Analytical standards provision and coordination  EPA will coordinate and distribute specialized analytical standards to participating laboratories.

Technical Support/ Guidance Document Development: Technical support and guidance document include: developing and distributing guidance for laboratory calculations MRL/ LCMRL; and background information about the health effects ( e. g., fact sheets) of the UCMR 2 contaminants.

5( a)( ii) National and Regional Oversight/ Data Analysis EPA's UCMR program activities include data analysis, management oversight, and implementation assistance to States. These are key management and oversight activities that must be conducted by EPA Headquarters or its Regional offices. Exhibit 3, below, illustrates the time Draft ICR for UCMR 2 Proposed Rule May 2005 21 line for UCMR implementation activities. EPA will develop its PAs with States and the State Monitoring Plans prior to 2007. EPA will conduct its ongoing evaluation of the data during 2007 2011.

Exhibit 3: Time Line of UCMR Activities 2006 2007 2008 2009 2010 2011 EPA Lab approval program begins Representative Sample of PWSs Selected by EPA EPA/ State PAs and State Monitoring Plans Developed Inform PWSs/ Establish Monitoring Plans Next RegDet1 scheduled for CCL2 contaminants Assessment Monitoring: List 1 Contaminants All systems serving more than 10,000; 800 systems serving 10,000 or fewer people Screening Survey: List 2 Contaminants All systems serving more than 100,000 people; 800 systems serving 100,000 or fewer people Potential Additional Screening Survey: Potential monitoring for emerging contaminants not identified in today's action 1 RegDet = Regulatory Determination 5( a)( iii) Costs for Small System Testing Program EPA expects that implementation of small system testing program will be the largest portion of Agency costs for the UCMR program. Prior to monitoring, EPA activities for logistical support of the small system testing program will include coordination of small system testing and provision of testing supplies. Draft ICR for UCMR 2 Proposed Rule May 2005 22 The single largest cost to EPA for implementation of UCMR is for small system sample analyses. During the ICR period of 2007 2009, EPA will pay for the analytical and shipping costs for small systems in the national representative sample for most of Assessment Monitoring ( the monitoring period of January through June 2010 falls outside of the ICR period), and for the entire Screening Survey. EPA also expects to conduct some QC activities that will not be required of the large systems. Specifically, EPA plans to send duplicates of 10 percent of small system samples to a separate laboratory for analysis. The quality control duplicates are intended to provide standard, real time, QC checks among the different contract laboratories.

5( b) Information Collection Methodology and Management This proposed rule specifies that laboratories must report the analytical results and associated data elements to EPA's electronic data reporting system. The proposed rule clarifies that large systems must ensure that their laboratory posts the data in EPA's electronic data reporting system, and must review, approve, and submit the data to the State and EPA via the EPA electronic reporting system. After 60 days from the laboratory's posting, if the PWS has not approved and submitted the data, the data will be considered approved and final for EPA review. Electronic reporting will provide significant collection efficiencies, and reduce the possibility of data input error.

EPA plans to conduct ongoing data analysis which will include checks for anomalies in the data that may be related to data entry or laboratory errors. Data quality review and analysis will include: continuous analysis of laboratory results, review of all program data, and NCOD review.

The UCMR data will be maintained and analyzed through NCOD. The data collected under UCMR will be used for regulation development, to analyze the significance of occurrence and health effects, and to support the critical Agency function of program oversight. The public will receive information regarding UCMR monitoring results through the CCRs, and will be able to access data through the NCOD. In addition, systems that fail to monitor for unregulated contaminants will be required to notify the public of their failure to monitor.

5( c) Small Entity Flexibility Note: The following Small Business Regulatory Enforcement Fairness Act analysis summary is the same as that provided in the preamble to the proposed rule. The Regulatory Flexibility Act analysis is based on the entire five year UCMR implementation period of 2007 2011, rather the three year ICR period of 2007 2009.

The Regulatory Flexibility Act ( RFA) generally requires an agency to prepare a regulatory flexibility analysis of any rule subject to notice and comment rulemaking requirements under the Administrative Procedure Act or any other statute unless the agency certifies that the rule will not have a significant economic impact on a substantial number of small entities. Small entities include small businesses, small organizations, and small governmental jurisdictions. Draft ICR for UCMR 2 Proposed Rule May 2005 23 The RFA provides default definitions for each type of small entity. Small entities are defined as: ( 1) a small business as defined by the Small Business Administration's ( SBA) regulations at 13 CFR 121.201; ( 2) a small governmental jurisdiction that is a government of a city, county, town, school district or special district with a population of less than 50,000; and ( 3) a small organization that is any " not for profit enterprise which is independently owned and operated and is not dominant in its field." However, the RFA also authorizes an agency to use alternative definitions for each category of small entity, " which are appropriate to the activities of the agency" after proposing the alternative definition( s) in the Federal Register and taking comment 5 USC 601( 3)  ( 5). In addition, to establish an alternative small business definition, agencies must consult with SBA's Chief Counsel for Advocacy.

For purposes of assessing the impacts of today's proposed rule on small entities, EPA considered small entities to be PWSs serving 10,000 or fewer people, because this is the system size specified in SDWA as requiring special consideration with respect to small system flexibility. As required by the RFA, EPA proposed using this alternative definition in the Federal Register, ( 63 FR 7605, February 13, 1998 ( USEPA, 1998a)), requested public comment, consulted with the SBA, and finalized the alternative definition in the Consumer Confidence Reports rulemaking, ( 63 FR 44511, August 19, 1998 ( USEPA, 1998c)). As stated in that Final rule, the alternative definition would be applied to this regulation as well.

The small entities directly regulated by this proposed rule are PWSs serving 10,000 or fewer people. EPA has determined that the small entities subject to the requirements of this proposed rule are a subset of the small PWSs ( those serving 10,000 or fewer people). The Agency has determined that 1,280 small PWSs ( across Assessment Monitoring and the Screening Survey), or approximately 2 percent of small systems, will experience an impact of less than 0.6 percent of revenues/ sales; the remainder of systems will not be impacted.

Although this proposed rule will not have a significant economic impact on a substantial number of small entities, EPA nonetheless has tried to reduce the impact of this rule on small entities. To ensure that this proposed rule will not have a significant economic impact on a substantial number of small entities, EPA will assume all costs for analyses of the samples and for shipping the samples from these systems to the laboratories contracted by EPA to analyze UCMR 2 samples. EPA has set aside $ 2.0 million each year from the State Revolving Fund ( SRF) with its authority to use SRF monies for the purposes of implementing this provision of SDWA. Thus, the costs to these small systems will be limited to the labor hours associated with collecting a sample and preparing it for shipping.

EPA continues to be interested in the potential impacts of the proposed rule on small entities and welcome comments on issues related to such impacts.

To evaluate the overall impact on small entities, EPA analyzed the impacts for privatelyowned and publicly owned water systems separately, due to the different economic characteristics of these ownership types. For publicly owned systems, EPA used the " revenue test," which compares annual system costs attributed to the rule to the system's annual revenues. EPA used a Draft ICR for UCMR 2 Proposed Rule May 2005 24 " sales test" for privately owned systems, which involves the analogous comparison of UCMRrelated costs to a privately owned system's sales. EPA assumes that the distribution of the sample of participating small systems will reflect the proportions of publicly and privately owned systems in the national inventory. The estimated distribution of the representative sample, categorized by ownership type, source water, and system size, is presented below in Exhibit 4.

Exhibit 4: Number of Publicly and Privately Owned Systems Subject to UCMR 2 System Size Publicly Owned Privately Owned Total Ground Water 500 and under 102 528 630 501 to 3,300 179 61 240 3,301 to 10,000 95 19 114 Subtotal GW 376 608 984 Surface Water ( and GWUDI)

500 and under 48 53 101 501 to 3,300 95 6 101 3,301 to 10,000 87 7 94 Subtotal SW 230 66 296 Total of Small Water Systems 606 674 1,280 The basis for the UCMR RFA certification for this proposed rule is as follows: for the 1,280 small water systems that will be affected, the average annual costs for complying with this rule represent less than 0.6 percent of system revenues or sales ( the highest estimated percentage is for surface water/ GWUDI systems serving 500 or fewer people, at 0.53 percent of its median sales). Therefore, the Administrator certifies that this proposed action will not have a significant economic impact on small entities. Exhibit 5 presents the yearly costs to small systems, and to EPA for the small system sampling program, along with an illustration of system participation for each year of the program. Draft ICR for UCMR 2 Proposed Rule May 2005 25 Exhibit 5: EPA and Small Systems Costs for Implementation UCMR 2 Cost Description 2007 2008 2009 2010 2011 Total Costs to EPA for Small System Program ( including Assessment Monitoring, and the Screening Survey):

$ 1,747,951 $ 3,495,903 $ 2,278,325 $ 530,374 $ 0 $ 8,052,553 Costs to Small Systems ( including Assessment Monitoring, and the Screening Survey):

$ 122,838 $ 56,789 $ 37,731 $ 9,337 $ 0 $ 226,695 Total Costs to EPA and Small Systems for UCMR 2:

$ 1,870,789 $ 3,552,692 $ 2,316,056 $ 539,711 $ 0 $ 8,279,248 System Monitoring Activity Time Line: 1 Assessment Monitoring a PWSs Sample a PWSs Sample a PWSs Sample 800 Screening Survey ½ PWSs Sample ½ PWSs Sample 480 1 Total number of systems is 1,280. No small system conducts both Assessment Monitoring and Screening Survey.

System costs are attributed to the additional labor required for reading about their requirements, monitoring, reporting, and record keeping. The estimated average annual burden across the five year UCMR 2 implementation period of 2007 2011 is estimated to be 1.4 hours at $ 35 per small system. Average annual cost, in all cases, is less than 0.6 percent of system revenues/ sales. As required by SDWA, the Agency specifically structured the rule to avoid significantly affecting small entities by assuming all costs for laboratory analyses, shipping, and quality control for small entities. As a result, EPA incurs the entirety of the non labor costs associated with UCMR 2 small system monitoring, or 97 percent of small system testing costs. Exhibits 6a and 6b present the estimated economic impacts in the form of a revenue test for publicly owned systems and a sales test for privately owned systems, respectively. Draft ICR for UCMR 2 Proposed Rule May 2005 26 Exhibit 6a: UCMR 2 Relative Cost Analysis for Publicly Owned Systems ( 2007 2011)

System Size Annual Number of Systems Impacted Average Annual Hours per System ( 2007 2011) Average Annual Cost per System ( 2007 2011) " Revenue Test" 1 Ground Water Systems 500 and under 20 1.1 $ 26.38 0.11%

501 to 3,300 36 1.3 $ 33.43 0.02%

3,301 to 10,000 19 1.8 $ 46.50 0.01%

Surface Water ( and GWUDI) Systems 500 and under 9 2.0 $ 47.45 0.20%

501 to 3,300 19 2.0 $ 50.63 0.04%

3,301 to 10,000 17 2.2 $ 58.46 0.01%

1 The " Revenue Test" was used to evaluate the economic impact of an information collection on small government entities ( e. g., publicly owned systems); costs are presented as a percentage of median annual revenue in each size category.

Exhibit 6b: UCMR 2 Relative Cost Analysis for Privately Owned Systems ( 2007 2011)

System Size Annual Number of Systems Impacted Average Annual Hours per System ( 2007 2011) Average Annual Cost per System ( 2007 2011) " Sales Test" 1 Ground Water Systems 500 and under 105 1.1 $ 26.38 0.30%

501 to 3,300 12 1.3 $ 33.43 0.02%

3,301 to 10,000 4 1.8 $ 46.50 0.01%

Surface Water ( and GWUDI) Systems 500 and under 11 2.0 $ 47.45 0.53%

501 to 3,300 1 2.0 $ 50.63 0.03%

3,301 to 10,000 1 2.2 $ 58.46 0.01%

1 The " Sales Test" was used to evaluate the economic impact of an information collection on small private entities ( e. g., privately owned systems); costs are presented as a percentage of median annual sales in each size category. Draft ICR for UCMR 2 Proposed Rule May 2005 27 5( d) Collection Schedule EPA is proposing to use the same monitoring frequency as that used under UCMR 1 because, as detailed in section 3( d), Part A of this ICR document, the Agency believes that it is sufficient to gather necessary information on occurrence of unregulated contaminants, without significantly burdening small systems. Assessment Monitoring activities are expected to occur from July 2007 through June 2010, and the Screening Survey will take place from July 2007 through June 2009. Monitoring frequency specifications are the same for both Assessment Monitoring and Screening Surveys. Surface water or GWUDI systems will collect four samples for each required component of UCMR monitoring, taken as follows: systems will select either the first, second, or third month of a quarter and sample in that same month of each of four consecutive quarters to ensure that one of those sampling events occurs during the vulnerable time. Ground water systems will collect samples two times in a year for each required component of UCMR monitoring, taken as follows: systems will sample during one month of the vulnerable time ( typically May through July) and during one month, five to seven months earlier or later. Small systems will only be selected for one component of UCMR monitoring, if at all. UCMR activities that occur after the year 2009 are not included in this ICR analysis ( Appendix B contains estimations for the five year UCMR 2 program, 2007 2011). Exhibits 3 and 8 illustrate the time line of general UCMR activities, and system monitoring activities, respectively. Draft ICR for UCMR 2 Proposed Rule May 2005 28 6 ESTIMATING THE BURDEN AND COST OF THE COLLECTION This section describes the respondent burden and cost for activities under UCMR 2. The burden and cost estimates for PWSs are shown in section 6( a), burden and costs to States are shown in section 6( b), and the Agency's burden and cost estimates are shown in section 6( c) ( all in Part A of this ICR document).

This ICR focuses only on the cost of the UCMR data collection over the years 2007 2009. Cost tables that are presented in this section have analogous tables in Appendix B, which present costs for the entire monitoring cycle ( 2007 2011).

There are two primary categories of costs associated with UCMR: ( 1) labor costs, such as program implementation, sample collection, record keeping, reporting, and data analysis; and ( 2) non labor costs, such as laboratory fees for analyses of samples, shipping charges, and contractor costs. The majority of costs are directly attributed to monitoring activities and the fees for laboratory analytical services. Assessment Monitoring targets a list of 11 contaminants and the Screening Survey targets 15 contaminants.

EPA is committed to accurately characterizing the burden and costs of rules it promulgates. In the development of various drinking water program rule ICRs, EPA has developed a consistent set of assumptions to use in calculations. These have been developed and utilized in other drinking water program evaluations. Pertinent to the UCMR ICR are the standard assumptions for labor rates, system inventory numbers ( the number of water systems in the various size categories by primary water source), the number of sampling points for each system, and analytical services. The sources and assumptions used in estimating costs and burdens are described below.

6( a) Estimating Burden and Cost to Public Water Systems Specific assumptions used in estimating system labor burden and cost, as well as non labor costs are discussed in sections 6( a)( i) and 6( a)( ii), respectively ( Part A of this ICR document). A summary of the costs estimates is provided in section 6( a)( iii), Part A of this ICR document.

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

° Inventory Data: Small system inventory was based on the same source as that used for the current drinking water ICR entitled: Disinfectants/ Disinfection Byproducts, Chemical, and Radionuclides Information Collection Request ( OMB Control Number: 2040 0204; EPA Tracking Number: 1896.05). Inventory data frozen on December 31, 2003 was extracted from EPA's Safe Drinking Water Information System. Large system inventory data are from UCMR data collected for UCMR 1 implementation, as of October 2004. Draft ICR for UCMR 2 Proposed Rule May 2005 29 ° EPTDS Data: All EPTDS data were taken from Community Water System Survey 2000, Volume II Detailed Tables and Survey Methodology, Table 7, entitled " Average Number of Entry Points to the Distribution System By Primary Source Water", which gives the average number of entry points for ground water and surface water systems.

° DSMRT Data: Number of DSMRT samples per system per sampling period were estimated by multiplying the number of treatment plants per system ( from Community Water System Survey 2000, Volume II Detailed Tables and Survey Methodology, Table 11) by the percentage of systems disinfecting ( Fourth Edition of the Baseline Handbook, Table B1.3.3, originally derived from the 1995 Community Water System Survey). As a conservative measure, the average number of CWSs treatment plants were also used to represent the number of NTNCWS treatment plants ( i. e., it is likely that NTNCWSs have fewer treatment plants than CWSs, and thus lower actual costs for DSMRT sampling than estimated).

6( a)( i) Estimating Burden and Labor Costs Assessment Monitoring will be conducted from July 2007 through June 2010 by 800 systems serving 10,000 or fewer people, and all systems serving 10,001 and over. Screening Survey monitoring will be conducted from July 2007 through June 2009 by 800 systems serving 100,000 or fewer people, plus all systems serving more than 100,000 people. It is assumed for this cost estimation that one third of systems will conduct Assessment Monitoring each year with one exception: the very large systems ( 322) that are required to conduct the Screening Survey must also conduct Assessment Monitoring. Thus, these systems are assumed to complete their Assessment Monitoring along with Screening Survey monitoring during July 2007 through June 2009. The UCMR program will affect a total of 4,390 systems, all of which will conduct monitoring during the ICR years of 2007 2009. However, the last group of systems to conduct Assessment Monitoring will only have completed the first half of their UCMR sampling in 2009, with the remaining sampling to be conducted in January June of 2010. Exhibit 7 below presents the estimated numbers of regulated systems to participate. Exhibit 8 presents the time line in which the system monitoring activities will take place. Draft ICR for UCMR 2 Proposed Rule May 2005 30 Exhibit 7: Systems to Participate in UCMR 2 Monitoring System Size Assessment Monitoring Screening Survey TOTAL1 List 1 ( July 2007 June 2010) List 2 ( July 2007 June 2009)

Small ( serving 25  10,000) 800 ( selected systems) 480 ( selected systems; different from those for List 1) 1,280 Large ( serving 10,001 100,000) 2,788 ( all) 320 ( selected systems) 2,788 Very Large ( serving > 100,000) 322 ( all) 322 ( all) 322 TOTAL 3,910 1,122 4,390 1 Totals for large and very large systems are not additive, since Screening Survey systems are a subset of those conducting Assessment Monitoring ( i. e., some large and all very large systems will conduct both Assessment Monitoring and Screening Survey monitoring).

Exhibit 8: UCMR 2 Sampling Activity Time Line for Cost and Burden Estimations 2007 2008 2009 2010 2011 ( designated ICR years)

No UCMR monitoring activity No UCMR monitoring activity No UCMR monitoring activity Assessment Monitoring1 July 2007 June 2008: ~ a systems sample (~ 1,357 PWSs) July 2008 June 2009: ~ a systems sample (~ 1,357 PWSs) July 2009 June 2010: ~ a systems sample (~ 1,196 PWSs)

Screening Survey1 July 2007 June 2008: ½ systems sample ( 561 PWSs) July 2008 June 2009: ½ systems sample ( 561 PWSs)

1 The following assumptions, based on the proposed UCMR 2, were used to estimate cost and burden:

° Most Assessment Monitoring systems will conduct sampling evenly across July 2007 June 2010 ( i. e., one third in each of the 3 consecutive 12 month periods).

° All Screening Survey systems will conduct sampling evenly across July 2007 June 2008 ( i. e., one half in each of the 2 consecutive 12 month periods).

° Systems serving more than 100,000 people must conduct both Assessment Monitoring and Screening Surveys. It is assumed that these systems will conduct Assessment Monitoring and Screening Surveys simultaneously, during either July 2007 June 2008 or July 2008 June 2009.

° Systems will conduct monitoring during the ICR years of 2007 2009; however, the last group of systems to conduct Assessment Monitoring will only have completed the first half of their UCMR sampling in 2009, with the remaining sampling to be conducted in January June of 2010. Draft ICR for UCMR 2 Proposed Rule May 2005 31 The water system labor burden consists of three primary activities: ( 1) reading the regulations or State guidance letter; ( 2) monitoring or monitoring assistance; and ( 3) reporting and record keeping. Hourly labor rates ( including overhead) vary by system size and are taken from the October 20, 2003 document Labor Costs for National Drinking Water Rules, Exhibit 20. Estimated hourly rates range from $ 23 per hour for staff in water systems serving 500 or fewer people to almost $ 33 per hour for systems serving more than 100,000 people ( see Exhibit 9 for details).

Exhibit 9: Labor Rates Applied for Public Water Systems System Size Labor Rate1 500 and under $ 23.35 ( for ground water) $ 23.52 ( for surface water/ GWUDI)

501 to 3,300 $ 25.99 3,301 to 10,000 $ 26.62 10,001 to 50,000 $ 27.37 50,001 to 100,000 $ 27.37 100,001 and over $ 32.84 1 PWS hourly labor rates ( including overhead) are taken from Labor Costs for National Drinking Water Rules, Exhibit 20. All rates represent that for both ground water and surface water/ GWUDI systems, except as noted. Wage rates are converted to 2004 dollars using the Employment Cost Index for wages and salaries in electric, gas, and sanitary services; accessed http:// www. bls. gov on March 11, 2005.

6( a)( i)( a) Reading the Regulations/ Guidance Letter For each required UCMR component ( Assessment Monitoring and/ or Screening Surveys), systems are assumed to read the regulations and/ or a State issued guidance letter during 2007. Small systems can rely on the State and EPA for information pertaining to their requirements, rather than reading the regulation; and are expected to spend 1 hour, on average, reading this letter or guidance. Systems serving more than 10,000 people are assumed to read both the regulation and information from the State, requiring on average 4 hours. National costs are estimated by multiplying the average burden hours by the average system labor rate, times the number of systems affected. This reading burden is assumed for each UCMR component. Small systems ( those serving 10,000 or fewer) will only be selected for one component of UCMR. Large systems ( those serving 10,001 to 100,000) are subject to Assessment Monitoring, with a subset of 160 of these systems subject to the Screening Survey. Very large systems ( those serving more than 100,000) are subject to both Assessment Monitoring and the Screening Survey. Thus, reading burden for any one small system would be 1 hour; 4 or 8 hours for large systems; and 8 hours for very large systems. Draft ICR for UCMR 2 Proposed Rule May 2005 32 6( a)( i)( b) Monitoring Burden For Assessment Monitoring, it is assumed that all participating systems will collect samples during July 2007 through June 2010, with approximately one third of systems involved during each of the 3 consecutive 12 month periods. The exception, as noted above, are the very large systems that are required to conduct Screening Survey monitoring. For this cost estimation, it is assumed that these systems will conduct their Screening Survey and Assessment Monitoring at the same time. In addition, for the last group of systems to monitor ( i. e., those monitoring from July 2090 through June 2010), only one half of their monitoring will be completed during the ICR period of 2007 2009. The second half of their monitoring will be completed during January through June 2010, which is after the applicable ICR period. See Exhibit 8, above, for an illustration of the time line for system sampling activity. For both Assessment Monitoring and the Screening Survey, EPA assumes that each system will incur an estimated burden of 0.5 hours per sampling point to collect chemical samples for analysis. This monitoring burden includes receipt of monitoring kit, reading laboratory instructions, and collection and shipping of samples. It is calculated by: ( hour burden per sampling point) times ( number of sampling points) times ( number of systems) times ( number of sample events per year). Many ground water systems may realize savings in their sampling burden as a result of the allowance for representative EPTDSs. Thus, sampling burden is calculated to account for the estimated reduction in entry points where these systems will sample ( as described below in section 6( a)( ii), Part A of this ICR document).

6( a)( i)( c) Reporting and Record Keeping Under UCMR 2, regulated systems are required to report specific information prior to monitoring, and with their monitoring results.

° Reporting Prior to Monitoring Small systems: EPA assumes that small systems will only need to send and confirm contact information prior to monitoring. These systems are allotted a onetime reporting burden of 2 hours.

Large surface water ( and GWUDI) systems: EPA assumes that large surface water/ GWUDI systems will be sending contact and sampling point information, and are allotted a one time reporting burden of 6 hours.

Large ground water systems: EPA assumes that large ground water systems will be sending contact and sampling point information, which will require a one time burden of 6 hours. An additional 8 hours are allotted to some ground water systems to account for compilation and submission of representative EPTDS proposal. Since it is unlikely that all systems will submit these proposals, EPA conservatively assumes that half of ground water systems serving 10,001 to 100,000 people would compile and submit this proposal; and assumes that all ground water systems serving more than 100,000 people would do so. Draft ICR for UCMR 2 Proposed Rule May 2005 33 ° Reporting with Monitoring Results Small systems: Small systems can choose whether to review their UCMR monitoring results. Because EPA is paying for and coordinating laboratory analyses, small systems are not required to review and approve their analytical results. Some systems may choose not to review at all, while others may review in detail. However, as a conservative assumption, small systems are each allotted 0.5 hours per sampling period for data review.

Large systems: This proposed rule clarifies that large systems must review, approve, and submit the data to the State and EPA via the EPA electronic reporting system. These systems are allotted 2 hours per sampling period for this activity.

6( a)( i)( d) Public Notification Systems are required to notify their users of the detection of any unregulated chemicals. Specifically, UCMR monitoring results will be reported by CWSs through the CCRs ( 63 FR 44512 ( August 19, 1998)). Both CWSs and NTNCWSs must report any failure to monitor for unregulated contaminants required through UCMR under the Public Notification Rule ( 64 FR 25964 ( May 13, 1999)). Therefore, no additional public notification burden is assumed under UCMR.

6( a)( ii) Estimating Non labor Costs Under UCMR, small systems will only incur labor costs. By design of the rule, EPA assumes all laboratory and shipping costs for systems in the national representative sample of small systems. Thus, the laboratory fee and shipping cost estimates described here are the basis for EPA and large system non labor costs.

The most significant cost associated with the implementation of UCMR is the cost of laboratory services for contaminant analysis. Exhibit 10 provides estimates of laboratory analytical costs associated with the analysis of each sample. These methods are comparatively new ( with the exception of Method 525.2 for the parent acetanilides), and will not coincide with other compliance monitoring. EPA estimates of laboratory fees are based on consultations with national drinking water laboratories and costs of analytical methods similar to those that will be used for UCMR 2. For systems serving 10,000 or fewer people, EPA will pay for the costs for shipping and laboratory analysis. Draft ICR for UCMR 2 Proposed Rule May 2005 34 Exhibit 10: Contaminant Group or Analytical Method Contaminant/ Contaminant Group Cost List 1  Assessment Monitoring Gas Chromatography ( GC)/ Mass Spectrometry ( MS) ( for 7 contaminants) . . . . . . . . . . . . . . . . . Perchlorate ( for 1 contaminant) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Explosives ( for 3 contaminants) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $ 225 $ 150 $ 225 Total $ 600 List 2  Screening Survey Monitoring Nitrosamines ( for 6 contaminants) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Acetanilides ( for 6 contaminants) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Acetanilide parents ( for 2 contaminants) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $ 300 $ 350 $ 125 Total $ 775 UCMR 2 specifies that all samples be collected at EPTDSs. Some large systems that use ground water sources and have multiple EPTDSs may be able to realize significant savings by sampling representative entry point( s) rather than at each EPTDS. Systems can do this if: they meet certain system configuration criteria; submit a proposal regarding representative entry points; and receive approval from EPA or the State. Labor related to submission and coordination of these proposals is discussed above in section 6( a)( i)( c), Part A of this ICR document. To account for the savings on laboratory fees that will be realized by large ground water systems, EPA assumed that effectively 75 percent of the current EPTDSs will be sampled at systems serving 10,001 to 100,000 people, and at ground water systems that serve more than 100,000 people 50 percent of EPTDSs will be sampled.

In addition to EPTDS samples, systems that are required to conduct Screening Survey sampling, and are subject to the distribution system sampling requirements of the DBPR, are required to also sample for nitrosamines at the point of DSMRT. Thus, large systems that are required to collect samples at both locations will incur additional costs for laboratory fees for the nitrosamine analyses. All surface water/ GWUDI systems are assumed to disinfect, and thus have one DSMRT sampling point per treatment plant ( surface water/ GWUDI systems had an average number of 1 to 2 treatment plants per system). Whereas, ground water systems are estimated to disinfect at between 65 to 96 percent of their treatment plants ( average number of treatment plants ranged from 1 to 7), depending on system size. These percentages were multiplied by the number of treatment plants to estimate the number of DSMRT samples collected by large ground water systems.

Shipping fees were calculated per required sample. It is assumed that, for each sampling point, a package of empty sample bottles is shipped via ground transportation to the system; estimated at $ 20 per package. Following sample collection, the system sends the package with full bottles via overnight air back to the laboratory. To estimate the cost of this overnight shipment, EPA applied the approximate cost of shipping a 15 pound package across an average Draft ICR for UCMR 2 Proposed Rule May 2005 35 number of shipping zones at $ 60. Thus, shipping cost for a large PWS is estimated at $ 80 per sample ( again, small system laboratory and shipping costs are paid for by EPA). Shipping costs were estimated based on pricing information posted on: http:// www. fedex. com/ and http:// www. ups. com/; accessed January 2004.

Total laboratory and shipping fees were estimated per required sampling location ( accounting for both the representative EPTDS allowance, and the additional DSMRT samples, as described above), per sampling event, as follows: ( number systems) times ( number of periods per year) times ( number of sampling points per system) times ( method and shipping costs).

6( a)( iii) Summary of Labor and Non labor Costs to Public Water Systems Exhibit 11a displays a summary of labor and non labor costs, by year, for the three year ICR period. As previously discussed, the UCMR 2 cycle is 2007 2011, and the ICR period of 2007 2009 coincides with the three primary years of program implementation. Analogous information presenting estimated costs over the five year UCMR 2 implementation period is provided in Exhibit B 1a, in Appendix B. Small systems incur labor costs only. Large systems will incur both labor and non labor costs, as they are responsible for analytical costs.

The nationwide cost to systems for implementing the total UCMR program over the threeyear ICR period of 2007 2009 is estimated to be $ 25.4 million. Large and very large systems are expected to incur about 99 percent of this cost, $ 25.2 million. Annual cost per small system for UCMR implementation over the three year ICR period is estimated to be $ 57 per system, all attributed to labor. Annual cost per large system is estimated to be $ 204 for labor plus $ 1,894 for analytical ( non labor) costs; with very large systems costs of $ 512 for labor plus $ 7,392 for analytical ( non labor) costs. Exhibits 7 and 8 illustrate numbers of systems participating and timing of monitoring. Per system labor burdens and costs for the UCMR program are presented in Exhibit 11b. In addition, this exhibit presents a summary of burden and cost per response. Analogous information for the five year implementation period is provided in Exhibit B 1b, in Appendix B. " Response" is defined as each required reporting event for a system. All labor and non labor costs associated with a reporting event ( reading the regulations, monitoring, and reporting) are included in the per response cost estimate. Draft ICR for UCMR 2 Proposed Rule May 2005 36 Exhibit 11a: Yearly Cost to Systems, by System Size and by Type of Cost ( 2007 2009) ( corresponds to Exhibit B 1a)

Cost Description 2007 2008 2009 Total SMALL SYSTEMS ( serving 10,000 or fewer people)

Labor Costs Reading and Initial Reporting $ 94,444 $ 0 $ 0 $ 94,444 Monitoring $ 20,375 $ 40,749 $ 26,256 $ 87,380 Reporting of Results $ 8,020 $ 16,039 $ 11,475 $ 35,534 Non Labor Costs ( Laboratory Analysis and Shipping ( paid for by EPA))

$ 0 $ 0 $ 0 $ 0 Subtotal   Small Systems $ 122,839 $ 56,788 $ 37,731 $ 217,358 LARGE SYSTEMS ( serving 10,001 to 100,000 people)

Labor Costs Reading and Initial Reporting $ 946,564 $ 0 $ 0 $ 946,564 Monitoring $ 67,802 $ 135,605 $ 118,104 $ 321,511 Reporting of Results $ 90,139 $ 180,277 $ 167,139 $ 437,555 Non Labor Costs ( Laboratory Analysis and Shipping)

$ 3,335,493 $ 6,670,985 $ 5,834,963 $ 15,841,441 Subtotal   Large Systems $ 4,439,998 $ 6,986,867 $ 6,120,206 $ 17,547,071 VERY LARGE SYSTEMS ( serving greater than 100,000 people)

Labor Costs Reading and Initial Reporting $ 164,069 $ 0 $ 0 $ 164,069 Monitoring $ 44,384 $ 88,768 $ 44,384 $ 177,536 Reporting of Results $ 38,291 $ 76,583 $ 38,291 $ 153,165 Non Labor Costs ( Laboratory Analysis and Shipping)

$ 2,905,235 $ 3,570,317 $ 665,083 $ 7,140,635 Subtotal   Very Large Systems $ 3,151,979 $ 3,735,668 $ 747,758 $ 7,635,405 ALL SYSTEMS Total Labor for All Systems $ 1,474,088 $ 538,021 $ 405,649 $ 2,417,758 Total Non Labor for All Systems $ 6,240,728 $ 10,241,302 $ 6,500,046 $ 22,982,076 Total Labor and Non Labor for All Systems $ 7,714,816 $ 10,779,323 $ 6,905,695 $ 25,399,834 Draft ICR for UCMR 2 Proposed Rule May 2005 37 Exhibit 11b: Per System ( Respondent) and Per Response UCMR Costs ( 2007 2009) ( corresponds with Exhibit B 1b)

Burden / Cost Total over 2007 2009 Annual Average over 2007 2009 Small Systems Large Systems Very Large Systems Small Systems Large Systems Very Large Systems PER RESPONDENT:

Labor Cost $ 171 $ 612 $ 1,537 $ 57 $ 204 $ 512 Non Labor Cost $ 0 $ 5,682 $ 22,176 $ 0 $ 1,894 $ 7,392 Burden ( labor hours) 6.8 22.4 46.8 2.3 7.5 15.6 PER RESPONSE:

Number Responses per Respondent 2.2 2.5 3.6 0.7 0.8 1.2 Labor Cost per Response $ 76 $ 243 $ 424 $ 25 $ 81 $ 141 Non Labor Cost per Response $ 0 $ 2,252 $ 6,124 $ 0 $ 751 $ 2,041 Burden ( labor hours) per Response 3.1 8.9 12.9 1.0 3.0 4.3 6( b) Estimating the Burden and Cost to States Since UCMR is a direct implementation rule, individual State costs will largely depend on specifications in their PA. EPA assumed that States will incur only labor costs, because no capital investments are expected for this second cycle of the program. Because States will be involved in a variety of UCMR implementation and oversight activities but have few defined responses, burden estimates are based on yearly activities. Thus, for " per response" estimates, States are assumed to have an average of 1.0 response per year.

EPA used the " 2001 ASDWA Drinking Water Program Resource Needs Self Assessment" to estimate State burden and cost for the implementation and oversight of UCMR 2. This assessment tool ( or model) was developed by ASDWA to assist States in estimating the resources needed to implement their Statewide drinking water programs ( in both full time equivalent staff ( FTEs) and dollars). In 2000, the United States General Accounting Office had used a previous version of this model to estimate nationwide drinking water program needs for Congress. The tool was later updated and improved based on comments from 27 States. To make the model easier to use, ASDWA established suggested salary and benefit ranges ( i. e., default values), resource needs for the various NPDWRs, and other key variables. Draft ICR for UCMR 2 Proposed Rule May 2005 38 EPA used the defaults values ( or average values within a default range) that were provided in the model to estimate the national burden and cost for State UCMR 2 activities. Defaults included:

° one FTE is equivalent to 1,800 hours per year; overhead and holidays, sick leave, etc. are accounted for in through default loading of base salaries; ° professional and support staff salaries vary for different sized States ( very small, small, medium, large, very large); and ° suggested ranges of FTEs for the implementation of the Phase II/ V, Arsenic, and UCMR programs ( i. e., the relevant subsection of the model).

Understandably, the model had bundled the State resource needs for Phase II/ V, Arsenic, and UCMR, because of the inherent overlap and similarities in the programs. However, because these programs were bundled, EPA needed to " extract" the UCMR costs from the aggregated costs. Based on best professional estimates, and consultations with staff from three State drinking water programs ( California, Connecticut, and Nebraska) regarding the relative magnitude of the UCMR program, EPA assumed that:

° during the first three years of implementation ( 2007 2009), i. e., when the State Monitoring Plans are finalized, system notifications sent, and Assessment Monitoring and Screening Survey monitoring are being conducted, UCMR represents 3 percent of the bundled program resource needs; and ° during the last years of the five year cycle, when there are little or no monitoring activities, UCMR represents 1 percent of the bundled program resource needs ( though these are not relevant to the current ICR estimations for 2007 2009).

EPA ran the model for each of the State size categories that were based on the number of systems for which States have drinking water program oversight responsibilities. To estimate nationwide costs, the size specific " per State" estimates that are generated by the model were then multiplied by the number of States in each size category, as shown in Exhibit 12.

EPA further refined the model estimates by taking the level of State participation under UCMR 1 into consideration. EPA reviewed 5 key areas of State participation under UCMR 1, including: review and revision to the State Monitoring Plans; assisting EPA with update to information for large systems; 2 separate sets of system notifications; and compliance assistance. Based on levels of involvement in each of these UCMR activities, States typically participated in between 40 and 100 percent of their optional UCMR activities. However, some States chose not to participate at all. Burden estimates generated from the resource model were multiplied by this " percent participation in UCMR 1" to approximate State costs at expected participation levels under UCMR 2. Draft ICR for UCMR 2 Proposed Rule May 2005 39 Exhibit 12: Number of States in Each Size Category ( State Resource Model Assumptions)

Size Category Number of States Very Small 10 Small 11 Medium 23 Large 10 Very Large 2 Total 56 EPA estimates that the average annual burden over 3 years ( 2007 2009) for 56 States to implement UCMR will be 11,382 hours ( or 203 hours per State per year), with an average annual cost ( labor only) of $ 621,977 ( or $ 11,107 per State per year). See Exhibits 13a and 13b for a summary of estimated State burdens and costs ( analogous five year information for 2007 2011 provided in Exhibits B 2a and B 2b, in Appendix B).

Exhibit 13a: Yearly Cost and Burden to States for Implementation of UCMR ( 2007 2009) 1 ( corresponds with Exhibit B 2a)

Cost/ Burden 2007 2008 2009 Total Annual Average Costs to All States for labor related to UCMR implementation and oversight $ 617,360 $ 648,343 $ 600,227 $ 1,865,930 $ 621,977 Labor burden for all States for UCMR implementation and oversight 11,635 11,861 10,649 34,145 11,382 1 All costs are attributed to labor and are estimated over the period 2007 2009.

Exhibit 13b: Per State ( Respondent) and Per Response UCMR Costs ( 2007 2009) ( corresponds with Exhibit B 2b)

Burden / Cost Total over 2007 2009 Annual Average over 2007 2009 PER RESPONDENT:

Labor Cost $ 33,320 $ 11,107 Non Labor Cost $ 0 $ 0 Burden ( labor hours) 609.7 203.2 Draft ICR for UCMR 2 Proposed Rule May 2005 Exhibit 13b: Per State ( Respondent) and Per Response UCMR Costs ( 2007 2009) ( corresponds with Exhibit B 2b)

Burden / Cost Total over 2007 2009 Annual Average over 2007 2009 40 PER RESPONSE:

Number Responses per Respondent1 3.0 1.0 Labor Cost per Response $ 11,107 $ 3,702 Non Labor Cost per Response $ 0 $ 0 Burden ( labor hours) per Response 203.2 67.7 1 States are assumed to have 1 response per year, since there are no specific cyclical State reporting requirements under the UCMR program.

6( c) Estimating Agency Burden and Cost EPA will incur UCMR related burden and costs related to UCMR implementation activities, including: regulatory support activities; national and regional oversight and data analysis; and the small system testing program. These activities are described in detail in section 5( a), Part A of this ICR document. Labor and contractual costs are estimated using the federal government general schedule ( GS) pay scale; assuming a labor level of GS 13, step 5, and taken from the Maryland/ District of Columbia rate schedule during the third quarter of 2004 ( see the U. S. Office of Personnel Management website: www. opm. gov). With these assumptions, labor and contractor rates were based on a 2,080 hour work year, with a $ 81,723 annual salary plus 60 percent overhead, or $ 62.86 per hour. Additional cost assumptions are described below in sections 6( b)( i)( iii), Part A of this ICR document. Cost and burden estimates are presented in Exhibits 14a and 14b, respectively.

6( c)( i) Regulatory Support Activities Regulatory support activities include the labor and non labor costs for laboratory approval process and QA/ QC activities; and general technical support and guidance documents. Cost and burden assumptions for these activities are as follows:

Laboratory Approvals and QA/ QC Activities: EPA anticipates incurring various labor or contractor costs related to the laboratory PT/ approvals; laboratory QA/ QC; and provision of analytical standards, as follows:

° Laboratory approval ( PT program) is estimated to cost EPA $ 200,000 prior to the beginning of monitoring. Cost estimates from best professional judgement are based on costs realized by the Agency for prior similar activities. Costs for the PT program may partially occur during 2006; however, these costs are included within the 2007 costs to better reflect the costs of the UCMR 2 program. Draft ICR for UCMR 2 Proposed Rule May 2005 41 ° QC Audits of contract laboratories to occur throughout active UCMR monitoring. Labor ( hours) for each trip includes: a 3 day site inspection ( for 2 individuals); 1 full day travel for 2 individuals ( assume 2 half days); and 3 days of report writing ( for 1 individual), which includes review and response to laboratory comments. Travel costs for 2 individuals include: $ 500 round trip flight, 3 nights hotel stay, 2 full day food per diem, and 2 days at the proportional meals rate from the 2004 Federal rate for the Continental U. S. ( from the U. S. Government Services Administration website: http:// policyworks. gov/ org/ main/ mt/ homepage/ mtt/ perdiem/ perd04d. html). Also included is $ 150 for rental of one car for both travelers. It is estimated that these QC audits will take place 4 times each year, at an estimated $ 7,229 per trip.

° Analytical standards provision and coordination is estimated to cost EPA $ 500,000 total for three ICR years ( or $ 200,000 per full year of monitoring). Cost estimates from best professional judgement are based on costs realized by the Agency for prior similar activities.

Technical Support/ Guidance Document Development: These activities are estimated to cost EPA $ 150,000 total over the ICR period; including costs for developing and distributing guidance for laboratories that will participate in UCMR 2 testing; health effects fact sheets; and other pertinent guidance related to UCMR 2 implementation. Some of these activities may take place before 2007, but are included to best reflect the estimated costs of UCMR 2 implementation. Cost estimates from best professional judgement are based on costs realized by the Agency for prior similar activities.

6( c)( ii) National and Regional Oversight and Data Analysis EPA activities will include data analysis, management oversight, and support at both the regional and national level for assistance to States with UCMR implementation. During the core period of UCMR 2 activity, EPA estimates that it will dedicate 5.5 FTEs each year to program oversight and data analysis. In 2007, when monitoring will not begin until half way through the year, EPA estimates that only half as many FTEs will be needed. No burden for these activities are expected during 2011. These activities are estimated as labor cost and burden to the Agency ( see the corresponding description of these activities in section 5( a)( ii), Part A of this ICR document). These activities are estimated to cost EPA $ 1.8 million in total over the three year ICR period.

6( c)( iii) Costs for Small System Testing Program EPA will provide logistical support for the small system testing program. This activity includes costs for contractual labor and sampling supplies, and is estimated at $ 400 per sampling event per sampling site, based on actual costs incurred during UCMR 1 for this same activity. These activities are estimated to cost EPA $ 2.8 million in total over the three ICR years. Draft ICR for UCMR 2 Proposed Rule May 2005 42 The single largest cost to EPA for implementation of UCMR is for small system sample analyses. EPA will pay small system sample analyses and shipping for Assessment Monitoring and Screening Survey. EPA will also pay for quality control duplicates for 10 percent of all samples.

As estimated for large systems, shipping fees were calculated per required sample ( accounting for both the representative EPTDS allowance, and the additional DSMRT samples, as described above in section 6( a)( ii), Part A of this ICR document). EPA assumes that, for each sampling point, a package of empty sample bottles is shipped via ground transportation to the system; estimated at $ 20 per package. Following sample collection, the system sends the package with full bottles via overnight air back to the laboratory. To estimate the cost of this overnight shipment, EPA applied the approximate cost of shipping a 15 pound package across an average number of shipping zones at $ 60. Thus, shipping cost for a large PWS is estimated at $ 80 per sample. Small system sampling includes the cost for one extra ground trip, for sending the empty bottles from the laboratory to the sampling coordinator, so that the sampling kit can be reused. Thus, shipping cost for a small PWS is estimated at $ 100 per sample.

These analytical and shipping fees are estimated to cost EPA $ 4.7 million in total over the three ICR years. See Exhibit 10, in section 6( a)( ii), Part A of this ICR document, for assumptions regarding applicable laboratory fees for individual methods. Total costs that EPA will incur for the small system testing program were calculated by multiplying the laboratory and shipping fees by: ( number of systems) times ( number of sampling periods per year ( including an additional 10 percent QA samples)) times ( number of sampling points per system).

6( c)( iv) Estimated Agency Cost and Burden The EPA cost for the UCMR 2 program during the ICR period of 2007 2009 is estimated to be $ 10.24 million ( with annual average cost over the ICR period of $ 3.4 million). EPA costs for UCMR implementation are shown in Exhibit 14a; average annual labor and non labor costs, as well as small system testing program costs are shown in Exhibit 14b. Appendix B, Exhibits B 3a and B 3b provide analogous information over the five year UCMR 2 implementation period.

Exhibit 14a: Yearly Cost to EPA for UCMR Implementation, by Type of Cost ( 2007 2009) 1 ( corresponds with Exhibit B 3a)

Cost Description 2007 2008 2009 Total Average Regulatory Support Activities: laboratory proficiency testing; QC audits; analytical standards provision; and technical support, guidance document development Lab PT $ 200,000 $ 0 $ 0 $ 200,000 $ 66,667 QC Audits $ 14,457 $ 28,915 $ 28,915 $ 72,287 $ 24,096 Analytical Standards $ 100,000 $ 200,000 $ 200,000 $ 500,000 $ 166,667 Technical Support $ 100,000 $ 50,000 $ 0 $ 150,000 $ 50,000 Draft ICR for UCMR 2 Proposed Rule May 2005 Exhibit 14a: Yearly Cost to EPA for UCMR Implementation, by Type of Cost ( 2007 2009) 1 ( corresponds with Exhibit B 3a)

Cost Description 2007 2008 2009 Total Average 43 Subtotal   Regulatory Support $ 414,457 $ 278,915 $ 228,915 $ 922,287 $ 307,429 National and Regional Oversight and Data Analysis: UCMR management oversight; review and evaluation of data from Assessment Monitoring $ 359,559 $ 719,118 $ 719,118 $ 1,797,795 $ 599,265 Small System Testing: implementation coordination; and analytical and shipping costs for small system testing for both Assessment Monitoring and Screening Surveys Implementation Coordination $ 646,855 $ 1,293,710 $ 839,718 $ 2,780,283 $ 926,761 Fees for Analysis and shipping $ 1,101,096 $ 2,202,193 $ 1,438,607 $ 4,741,896 $ 1,580,632 Subtotal   Small System Testing $ 1,747,951 $ 3,495,903 $ 2,278,325 $ 7,522,179 $ 2,507,393 TOTAL $ 2,521,967 $ 4,493,936 $ 3,226,358 $ 10,242,261 $ 3,414,087 1 Agency costs are estimated over the period 2007 2009. Though some start up costs will likely begin in 2006, costs are presented beginning in 2007, with beginning of rule implementation activities.

Exhibit 14b: Summary of EPA Burdens and Costs for UCMR Implementation ( 2007 2009) ( corresponds with Exhibit B 3b)

Burden / Cost Annual Average Cost over Three year ICR Period of 2007 2009 Labor Cost $ 599,265 Non Labor Cost $ 2,814,822 Total Cost to EPA for UCMR Implementation $ 3,414,087 Burden ( labor hours) 9,533 6( d) Estimating the Respondent Universe and Total Burden and Costs For the UCMR 2 cycle of 2007 2011, the universe of respondents includes 4,390 PWS respondents, comprised of non purchased CWSs and non purchased NTNCWSs, as well as 56 State respondents. Assessment Monitoring will be conducted by 800 systems serving 10,000 or fewer people, plus all 2,788 systems that serve more than 10,000 people. Screening Survey monitoring will be conducted by 800 systems serving 100,000 or fewer people, plus all 322 serving more than 100,000 people. As described previously, PWS sampling is conducted four times during the monitoring year for surface water/ GWUDI sampling locations, and twice for Draft ICR for UCMR 2 Proposed Rule May 2005 44 ground water sampling locations ( i. e., frequency of response depends on water source). States will be involved in a variety of UCMR implementation and oversight activities, but have few defined responses; thus, States are assumed to have an average of 1 response per year.

Exhibit 15 summarizes national hours and costs for UCMR 2 during the ICR period of 2007 2009. Analogous information for the entire five year UCMR 2 cycle of 2007 2011 is presented in Exhibit B 4 in Appendix B. The total labor and non labor costs are presented for each category of respondent. The total labor burden to small systems is 8,749 hours, with a cost of $ 217,358 ( small systems only incur labor costs, EPA pays for all laboratory fees and shipping costs). The total labor burden to large systems is 62,318 hours, with a labor cost of $ 1.7 million, and non labor costs for analysis and shipping of $ 15.8 million. Very large systems are estimated to have a total labor burden for the ICR period of 15,067 hours, with a labor and non labor costs of $ 0.5 million and $ 7.1 million, respectively. The total burden to States over the three year ICR period is 34,145 hours, with a labor cost of $ 1.9 million. EPA anticipates that States will not incur any significant non labor costs. The EPA total burden over the same time frame is 28,600 hours, with labor costs of $ 1.8 million, and non labor costs of $ 8.4 million.

Exhibit 15: UCMR 2 National Cost Summary for the ICR period ( 2007 2009) ( corresponds with Exhibit B 4)

Type of Cost 2007 2008 2009 TOTAL Small Systems Labor Cost $ 122,838 $ 56,789 $ 37,731 $ 217,358 Non Labor Cost $ 0 $ 0 $ 0 $ 0 Total Small System Cost $ 122,838 $ 56,789 $ 37,731 $ 217,358 Large Systems Labor Cost $ 1,104,505 $ 315,882 $ 285,244 $ 1,705,631 Non Labor Cost $ 3,335,493 $ 6,670,985 $ 5,834,963 $ 15,841,441 Total Large System Cost $ 4,439,998 $ 6,986,866 $ 6,120,207 $ 17,547,071 Very Large Systems Labor Cost $ 246,744 $ 165,351 $ 82,676 $ 494,770 Non Labor Cost $ 2,905,235 $ 3,570,317 $ 665,083 $ 7,140,635 Total Very Large System Cost $ 3,151,979 $ 3,735,668 $ 747,759 $ 7,635,405 States Labor Cost $ 617,360 $ 648,343 $ 600,227 $ 1,865,930 Non Labor Cost $ 0 $ 0 $ 0 $ 0 Total State Cost $ 617,360 $ 648,343 $ 600,227 $ 1,865,930 Draft ICR for UCMR 2 Proposed Rule May 2005 Exhibit 15: UCMR 2 National Cost Summary for the ICR period ( 2007 2009) ( corresponds with Exhibit B 4)

Type of Cost 2007 2008 2009 TOTAL 45 EPA Labor Cost $ 359,559 $ 719,118 $ 719,118 $ 1,797,795 Non Labor Cost $ 2,162,409 $ 3,774,818 $ 2,507,240 $ 8,444,467 Total EPA Cost $ 2,521,968 $ 4,493,936 $ 3,226,358 $ 10,242,262 National Total Total with EPA $ 10,854,143 $ 15,921,602 $ 10,732,282 $ 37,508,026 Total without EPA $ 8,332,175 $ 11,427,666 $ 7,505,924 $ 27,265,764 Total Burden ( hours) for All Responses Small Systems 4,971 2,263 1,515 8,749 Large Systems 40,355 11,541 10,422 62,318 Very Large Systems 7,514 5,035 2,518 15,067 States 11,635 11,861 10,649 34,145 EPA 5,720 11,440 11,440 28,600 Total with EPA 70,195 42,140 36,544 148,879 Total without EPA 64,475 30,700 25,104 120,279 1 Although EPA is not considered a respondent to the UCMR regulations, Agency burdens are shown here to illustrate the national costs of the program. National totals are shown with and without the Agency costs.

6( e) Reasons for Change in Burden This ICR, in effect, amends the current drinking water program ICR entitled: Disinfectants/ Disinfection Byproducts, Chemical, and Radionuclides Information Collection Request (" Chem/ Rads ICR"; OMB Control Number: 2040 0204; EPA Tracking Number: 1896.05). After the UCMR 1 program was established in 1999, subsequent UCMR cost and burden estimates were incorporated into the larger Chem/ Rads ICR. However, the UCMR 2 ICR, and subsequent UCMR ICRs will be developed and tracked separately from the Chem/ Rads ICR, because the Chem/ Rads ICR is essentially a renewal ICR, whereas the UCMR program is, per SDWA, a program that must change every five years.

The reasons that respondents to UCMR 2 will incur a different burden than those responding to UCMR 1 include: ° UCMR 2 establishes a new list of 26 priority contaminants, and 9 analytical methods ( see Exhibit 1 in section 4( b)( i), Part A of this ICR document); ° more systems to monitor for Screening Survey ( see Exhibit 7 in section 6( a)( i), Part A of this ICR document); Draft ICR for UCMR 2 Proposed Rule May 2005 46 ° nitrosamines samples ( under the Screening Survey) for PWSs subject to Stage 1 D/ DBP Rule will be collected at DSMRT in addition to the required EPTDS locations ( see explanation in section 4( b)( i), Part A of this ICR document); and ° representative EPTDSs proposals by PWSs with multiple ground water EPTDSs will allow some large PWSs to reduce their required sampling points ( see explanation in section 4( b)( i), Part A of this ICR document).

6( f) Burden Statement Small systems ( those serving 10,000 or fewer) that are selected for UCMR 2 monitoring will sample an average of 2.2 times per system ( i. e., number of responses per system) across the three year ICR period of 2007 2009. The average burden per response for small systems is estimated to be 3.1 hours. Large systems ( those serving 10,001 to 100,000) and very large systems ( those serving more than 100,000) will sample and report an average of 2.5 and 3.6 times per system, respectively, across the three year ICR period of 2007 2009. The average burden per response for large and very large systems are estimated to be 8.9 and 12.9 hours, respectively. The larger burden per response for the very large systems reflects the fact these systems typically have more sampling locations than large systems. States are assumed to incur 3.0 responses over the three year ICR period related to coordination with EPA and systems, with an average burden per response of 203.2 hours. In aggregate, during the ICR period of 2007 2009, the average response ( e. g., responses from systems and States) is associated with a burden of 10.7 hours, with a labor plus non labor cost of $ 1,609 per response.

The annual average per respondent burden hours and costs for the ICR period of 2007 2009 are: small systems   2.3 hour burden at $ 57 for labor; large systems   7.5 hours at $ 204 for labor, and $ 1,894 for analytical costs; very large systems   15.6 hours at $ 512 for labor, and $ 7,392 for analytical costs; and States   203.2 hours at $ 11,107 for labor. Annual average burden and cost per respondent ( including both systems and States) is estimated to be 9.02 hours, with a labor plus non labor cost of $ 1,355 per respondent ( note that small systems do not pay for testing costs, so they only incur labor costs).

The Agency estimates the annual burden to EPA for proposed UCMR program activities during the ICR years of 2007 2009 to be 9,533 hours, at an annual labor cost of $ 0.6 million. EPA's annual non labor costs are estimated to be $ 2.8 million. Non labor costs are primarily attributed to the cost of sample testing for small systems ( testing is just under 90 percent of nonlabor

Exhibit 16 presents per respondent and per response burdens and costs over the UCMR ICR period of 2007 2009 ( analogous information for the 2007 2011 UCMR 2 implementation period is provided in Exhibit B 5, Appendix B). This Exhibit also presents average annual burdens and costs. Draft ICR for UCMR 2 Proposed Rule May 2005 47 Exhibit 16: UCMR 2 Per Respondent Burden and Cost Summary for the ICR Period ( 2007 2009) ( corresponds with Exhibit B 5)

Burden ( hours)/ Cost ( dollars) Small Systems Large Systems Very Large Systems States EPA National Average with EPA1 National Average without EPA Three Year Total per Respondent Total # of Responses Per Respondent 2.2 2.5 3.6 3.0 n/ a n/ a 2.5 Labor Cost Per Respondent $ 171 $ 612 $ 1,537 $ 33,320 $ 1,797,795 $ 1,368 $ 963 Non Labor Cost Per Respondent $ 0 $ 5,682 $ 22,176 $ 0 $ 8,444,467 $ 7,068 $ 5,169 Total Cost ( Labor plus Non Labor) $ 171 $ 6,294 $ 23,713 $ 33,320 $ 10,242,262 $ 8,436 $ 6,132 Total Cost Per Response $ 76 $ 2,495 $ 6,548 $ 11,107 n/ a n/ a $ 1,609 Total Burden Per Respondent 6.8 22.4 46.8 609.7 28,600.0 33.5 27.1 Total Burden Per Response 3.1 8.9 12.9 203.2 n/ a n/ a 10.7 Average Annual per Respondent Ave. # of Responses Per Respondent 0.7 0.8 1.2 1.0 n/ a n/ a 0.8 Labor Cost Per Respondent $ 57 $ 204 $ 512 $ 11,107 $ 599,265 $ 456 $ 321 Non Labor Cost Per Respondent $ 0 $ 1,894 $ 7,392 $ 0 $ 2,814,822 $ 2,356 $ 1,723 Ave. Cost ( Labor plus Non Labor) $ 57 $ 2,098 $ 7,904 $ 11,107 $ 3,414,087 $ 2,812 $ 2,044 Ave. Cost Per Response $ 25 $ 832 $ 2,183 $ 3,702 n/ a n/ a $ 536 Ave. Burden Per Respondent 2.3 7.5 15.6 203.2 9,533.3 11.2 9.0 Ave. Burden Per Response 1.0 3.0 4.3 67.7 n/ a n/ a 3.6 1 National average burdens and costs differ greatly between the State respondents and the various system respondents. This should be taken into consideration when looking at the national average with or without EPA. Draft ICR for UCMR 2 Proposed Rule May 2005 48 This UCMR is necessary for several reasons. Its primary purpose is to support the development of the CCL, the Administrator's determination of whether to regulate a contaminant, and regulation development. The data collected under UCMR may also be used as a basis for determining exposure, for establishing the baseline for health effects and economic analyses, for contaminant co occurrence analyses, and for treatment technology evaluation, including contaminant source management. Further, the data may indicate the need to initiate research on health effects and treatment technology research, if they suggest that certain contaminants have significant occurrence. Finally, as a secondary use, the data may guide future source water protection efforts.

Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.