Economic Analysis for the Stage 2 DBPR Proposal July 2003 Volume II Contents Appendix H: National Costs for Non Treatment Related Rule Activities Appendix I: Cost Implications for Alternative Monitoring Requirements and Alternative Approaches to Implementing the IDSE Appendix J: Unit Costs for Technologies Considered in the Stage 2 DBPR Appendix K: Stage 2 DBPR Cost Projections Appendix L: Benefit and Cost Models Appendix M: Quality Assurance Supplemental Information 1 All industry baseline data reflect revisions to SDWIS 4th Quarter Year 2000 Freeze to account for reporting errors in Massachusetts and Montana.

Economic Analysis for Stage 2 DBPR Proposal H 1 July 2003 Appendix H National Costs for Non Treatment Related Rule Activities This appendix presents calculation summaries and cost tables for Stage 2 Disinfectants and Disinfection Byproducts Rule ( DBPR) activities associated with rule implementation, Initial Distribution System Evaluations ( IDSEs), additional routine monitoring, and significant excursion evaluations. It supports the discussion of these rule activities in Chapter 6. For systems, each activity is described separately in sections H. 2 through H. 5. A summary of all non treatment activities and costs for systems is presented in H. 6. State/ Primacy Agency activities are described in sections H. 7 through H. 9.

Each of the cost summaries presented in this appendix detail the labor hours and corresponding labor costs for each activity. The derivation of the labor rates, based on Bureau of Labor Statistics ( BLS) 2000 data ( published in 2001), used for each activity is discussed in further detail in Chapter 6 ( section <IP_ADDRESS>).

H. 1 Derivation of the Stage 2 Monitoring Baseline The Stage 2 DBPR monitoring requirements ( both IDSE and compliance monitoring) are based on alternative system size category breakouts which the Environmental Protection Agency ( EPA) believes to be more appropriate for setting forth numbers of samples per system than the standard nine system size categories used to generate treatment costs in this Economic Analysis ( EA). Thus, a separate Stage 2 monitoring baseline for systems is needed. The final Stage 2 DBPR monitoring baseline, as presented in Columns F through I in Exhibit H. 2, is derived using three steps as described below.

Step 1  Convert Inventory to Stage 2 DBPR Monitoring Categories Exhibit H. 1 ( the baseline adjustment matrix) shows the percentage of systems in the EPA's nine standard categories that are in the Stage 2 monitoring size categories based on evaluation of Safe Drinking Water Information System ( SDWIS) 4th Quarter 2000 Frozen data. 1 The first step in developing the Stage 2 monitoring baseline is to multiply the number of disinfecting systems in the Stage 2 system baseline ( Exhibit 3.3) by the baseline adjustment matrix to place systems in the appropriate categories for monitoring costs. For example, according to the Stage 2 system baseline ( Exhibit 3.3, sum of columns G and H), there are 911 purchased surface water and mixed community water systems ( CWSs) serving a population between 3,301 10,000 ( a standard size category). To move these systems into the Stage 2 monitoring size categories, 40.2 percent ( or 366 systems) are placed in the monitoring population category of 500 4,999, 58.4 percent ( or 532 systems) are placed in the monitoring population category or 5,000 9,999, and 1.4 percent ( or 13 systems) are placed in the monitoring population category of 10,000 24,999).

The results of this step are shown in columns A through C in Exhibit H. 2. Note that the total number of systems in the Stage 2 monitoring baseline ( Exhibit H. 2, column C) is the same as the total number of systems in the Stage 2 DBPR system baseline ( Exhibit 3.3, column K). Economic Analysis for Stage 2 DBPR Proposal H 2 July 2003 < 500 500 4,999 5,000 9,999 10,000 24,999 25,000 49,999 50,000 99,999 100,000 499,999 500,000 1,499,999 1.5 M  < 5 M ³ 5   M < 100 100.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 101 500 94.6% 5.4% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

501 1,000 0.0% 100.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

1,001 3,300 0.0% 100.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

3,301 10,000 0.0% 40.0% 58.8% 1.2% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

10,001 50,000 0.0% 0.0% 0.0% 61.5% 38.0% 0.5% 0.0% 0.0% 0.0% 0.0% 50,001 100,000 0.0% 0.0% 0.0% 0.0% 0.0% 98.4% 1.6% 0.0% 0.0% 0.0% 100,001 1,000,000 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 87.3% 12.7% 0.0% 0.0% > 1,000,000 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 38.5% 53.8% 7.7%

< 100 100.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

101 500 95.5% 4.5% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

501 1,000 0.0% 100.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

1,001 3,300 0.0% 100.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

3,301 10,000 0.0% 40.2% 58.4% 1.4% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 10,001 50,000 0.0% 0.0% 0.0% 67.0% 32.6% 0.4% 0.0% 0.0% 0.0% 0.0% 50,001 100,000 0.0% 0.0% 0.0% 0.0% 0.0% 98.3% 1.7% 0.0% 0.0% 0.0% 100,001 1,000,000 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 93.0% 7.0% 0.0% 0.0% > 1,000,000 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

< 100 100.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

101 500 93.6% 6.4% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

501 1,000 0.0% 100.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

1,001 3,300 0.0% 100.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 3,301 10,000 0.0% 61.5% 38.5% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 10,001 50,000 0.0% 0.0% 0.0% 66.7% 33.3% 0.0% 0.0% 0.0% 0.0% 0.0% 50,001 100,000 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 100,001 1,000,000 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% > 1,000,000 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

< 100 100.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

101 500 86.4% 13.6% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

501 1,000 0.0% 100.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 1,001 3,300 0.0% 100.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 3,301 10,000 0.0% 33.3% 66.7% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 10,001 50,000 0.0% 0.0% 0.0% 33.3% 66.7% 0.0% 0.0% 0.0% 0.0% 0.0% 50,001 100,000 0.0% 0.0% 0.0% 0.0% 0.0% 100.0% 0.0% 0.0% 0.0% 0.0% 100,001 1,000,000 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 100.0% 0.0% 0.0% 0.0% > 1,000,000 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Source: SDWIS 4th Quarter Year 2000 Freeze data, adjusted for reporting errors in Montana and Massachusetts ( USEPA, 2000d). Non Purchased Purchased SW CWS Non Purchased Purchased SW NTNCWS Standard Size Categories ( Population Served) Stage 2 Monitoring Size Categories ( Population Served) Exhibit H. 1a Baseline Adjustment Matrix from Standard Nine Size Categories to Stage 2 Monitoring Categories for Surface Water Economic Analysis for Stage 2 DBPR Proposal H 3 July 2003 < 500 500 9,999 10,000 99,999 100,000 499,999 500,000 1,499,999 1.5 M  < 5 M ³ 5   M < 100 100.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 101 500 97.6% 2.4% 0.0% 0.0% 0.0% 0.0% 0.0% 501 1,000 0.0% 100.0% 0.0% 0.0% 0.0% 0.0% 0.0% 1,001 3,300 0.0% 100.0% 0.0% 0.0% 0.0% 0.0% 0.0% 3,301 10,000 0.0% 99.4% 0.6% 0.0% 0.0% 0.0% 0.0% 10,001 50,000 0.0% 0.0% 100.0% 0.0% 0.0% 0.0% 0.0% 50,001 100,000 0.0% 0.0% 100.0% 0.0% 0.0% 0.0% 0.0% 100,001 1,000,000 0.0% 0.0% 0.0% 93.0% 7.0% 0.0% 0.0% > 1,000,000 0.0% 0.0% 0.0% 0.0% 50.0% 50.0% 0.0%

< 100 100.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 101 500 97.2% 2.8% 0.0% 0.0% 0.0% 0.0% 0.0% 501 1,000 0.0% 100.0% 0.0% 0.0% 0.0% 0.0% 0.0% 1,001 3,300 0.0% 100.0% 0.0% 0.0% 0.0% 0.0% 0.0% 3,301 10,000 0.0% 100.0% 0.0% 0.0% 0.0% 0.0% 0.0% 10,001 50,000 0.0% 0.0% 100.0% 0.0% 0.0% 0.0% 0.0% 50,001 100,000 0.0% 0.0% 100.0% 0.0% 0.0% 0.0% 0.0% 100,001 1,000,000 0.0% 0.0% 0.0% 100.0% 0.0% 0.0% 0.0% > 1,000,000 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

< 100 100.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 101 500 96.0% 4.0% 0.0% 0.0% 0.0% 0.0% 0.0% 501 1,000 0.0% 100.0% 0.0% 0.0% 0.0% 0.0% 0.0% 1,001 3,300 0.0% 100.0% 0.0% 0.0% 0.0% 0.0% 0.0% 3,301 10,000 0.0% 98.6% 1.4% 0.0% 0.0% 0.0% 0.0% 10,001 50,000 0.0% 0.0% 100.0% 0.0% 0.0% 0.0% 0.0% 50,001 100,000 0.0% 0.0% 100.0% 0.0% 0.0% 0.0% 0.0% 100,001 1,000,000 0.0% 0.0% 0.0% 100.0% 0.0% 0.0% 0.0% > 1,000,000 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

< 100 100.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 101 500 94.1% 5.9% 0.0% 0.0% 0.0% 0.0% 0.0% 501 1,000 0.0% 100.0% 0.0% 0.0% 0.0% 0.0% 0.0% 1,001 3,300 0.0% 100.0% 0.0% 0.0% 0.0% 0.0% 0.0% 3,301 10,000 0.0% 100.0% 0.0% 0.0% 0.0% 0.0% 0.0% 10,001 50,000 0.0% 0.0% 100.0% 0.0% 0.0% 0.0% 0.0% 50,001 100,000 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 100,001 1,000,000 0.0% 0.0% 0.0% 100.0% 0.0% 0.0% 0.0% > 1,000,000 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% Source: SDWIS 4th Quarter Year 2000 Freeze data, adjusted for reporting errors in Montana and Massachusetts ( USEPA, 2000d). GW CWS Non Purchased Purchased GW NTNCWS Non Purchased Purchased Standard Size Categories ( Population Served) Stage 2 Monitoring Size Categories ( Population Served) Exhibit H. 1b Baseline Adjustment Matrix from Standard Nine Size Categories to Stage 2 Monitoring Categories for Ground Water Economic Analysis for Stage 2 DBPR Proposal H 4 July 2003 Baseline Number of Systems and Plants Subject to Stage 2 DBPR by System Type 100% Purchasing Systems Producing Systems Systems Plants Systems Plants A B C = A+ B D E F= Round [ B* D] G= Round [ E* F] H= Round [ CF I= Round [ E* H]

1,246 2,055 3,301 95% 1.4 1,961 2,745 1,340 1,876 1,991 2,664 4,655 95% 1.3 2,542 3,305 2,113 2,747 598 532 1,130 95% 1.7 508 864 622 1,057 602 503 1,105 95% 2.0 480 960 625 1,250 364 238 602 95% 2.2 227 499 375 825 195 121 316 95% 3.4 115 391 201 683 182 68 250 95% 3.0 65 195 185 555 31 5 36 95% 5.8 5 29 31 180 7  7 95% 5.8   7 41 1  1 95% 5.8   1 6 5,217 6,186 11,403 5,903 8,988 5,500 9,220 18,335 815 19,150 100% 1.4 815 1,141 18,335 25,669 10,752 768 11,520 100% 1.8 768 1,382 10,752 19,354 1,333 40 1,373 100% 4.3 40 172 1,333 5,732 52 4 56 100% 9.9 4 40 52 515 5  5 100% 9.9   5 50 1  1 100% 9.9   1 10    100% 9.9

30,478 1,628 32,105 1,627 2,735 30,478 51,330 423 158 581 100% 1.0 158 158 423 423 162 56 218 100% 1.0 56 56 162 162 5 6 11 100% 1.0 6 6 5 5 2 2 4 100% 1.0 2 2 2 2 1 4 5 100% 1.0 4 4 1 1  1 1 100% 1.0 1 1

 1 1 100% 1.0 1 1

   100% 1.0

   100% 1.0

   100% 1.0

593 228 821 228 228 593 593 6,155 26 6,180 100% 1.0 26 26 6,154 6,154 1,109 8 1,117 100% 1.0 8 8 1,109 1,109 4 1 5 100% 1.0 1 1 4 4 0 0 1 100% 1.0   1 1    100% 1.0        100% 1.0

   100% 1.0     7,269 34 7,303 35 35 7,268 7,268 Grand Totals 43,556 8,076 51,632 7,793 11,986 43,839 68,411 Notes: 100 percent purchasing systems buy or otherwise receive all of their finished water from one or more system year round.

Producing systems do not buy 100 percent of their water year round ( i. e., they produce some or all of their own finished water). Sources: Size Category ( D) Percent of consecutive systems that buy or otherwise receive all of their finished water ( 100 percent purchasing systems) based on an EPA estimate. 1.5 M  < 5 M ³ 5   M National Totals 500 9,999 < 500 National Totals < 500 10,000 99,999 ( E) Plants per system based on analysis of 1995 CWSS data, Q18, SDWIS source water categories, and Stage 2 monitoring size classifications. 100,000 499,999 500,000 1,499,999 ³ 5   M 1.5 M  < 5 M ³ 5   M 500 4,999 Detail may not add due to independent rounding. 5,000 9,999 500,000 1,499,999 < 500 500 4,999 10,000 24,999 25,000 49,999 5,000 9,999 50,000 99,999 100,000 499,999 500,000 1,499,999 10,000 99,999 10,000 24,999 25,000 49,999 National Totals < 500 100,000 499,999 500,000 1,499,999 1.5 M  < 5 M 50,000 99,999 ( A) and ( B) derived by multiplying Stage 2 system baseline ( Exhibit 3.3) by the baseline adjustment matrix ( Exhibits H. 1a and H. 1b). Surface Water and Mixed CWSs Disinfecting Ground Water Only CWSs Surface Water and Mixed NTNCWSs Disinfecting Ground Water Only NTNCWSs 1.5 M  < 5 M ³ 5   M National Totals 500 9,999 100,000 499,999 Total Number of Systems Non Purchased Percent of Purchased Systems that Buy all of Their Water ( 100% Purchasing Systems) Plants Per System Purchased Total Exhibit H. 2 Stage 2 DBPR Monitoring Baseline 2 EPA defines a consecutive system as a system that buys or otherwise receives some or all of its finished water from one or more wholesale systems for at least 60 days per year.

3 As described in the Stage 2 DBPR rule language, " plants" include consecutive system entry points that operate for at least 60 consecutive days per year.

4 For the purposes of this EA, systems supplying ground water under the influence of surface water ( GWUDI) are included with surface water systems. EPA also refers to the grouping of surface water and GWUDI systems as " subpart H" systems in the Stage 2 DBPR rule language. Surface water and GWUDI systems are grouped together because they fall under the same requirements in the Safe Drinking Water Act ( SDWA) regulations.

Economic Analysis for Stage 2 DBPR Proposal H 5 July 2003 Step 2  Differentiate 100 Percent Purchasing Systems from Other Systems The second step in developing the Stage 2 monitoring baseline involves differentiating systems according to their buying and selling relationships with other systems. This is needed because the Stage 2 DBPR uses two monitoring approaches for the IDSE and for compliance monitoring based on selling and buying relationships:

° The population based monitoring is dependent only on source water type and population served and applies only to consecutive systems2 that buy or otherwise receive all of their finished water from another system.

° The plant based monitoring approach is dependent on source water type, population served, AND number of plants3 in a system ( consistent with Stage 1 DBPR compliance monitoring) and applies to systems that produce some or all of their own finished water.

Population and plant based monitoring approaches are discussed further in sections H. 3 and H. 4. For the purposes of this EA, systems that buy all of their water are called " 100 percent purchasing systems." Systems that do not buy all of their water ( i. e., systems that produce some or all of their own water) are called " producing systems." Baselines for each IDSE and additional routine monitoring activity are presented separately for these two categories in this appendix.

SDWIS purchased system inventory data were used as a starting point for estimating the baseline number of 100 percent purchasing systems. As explained in Chapter 3, in SDWIS and the Baseline Handbook ( USEPA 2001h), systems are assigned a source type using the following hierarchy, in descending order: Surface Water4, Purchased Surface Water, Ground Water, and Purchased Ground Water. The presence of the first source in this list determines the source assignment for that system. As a result, all purchased ground water CWSs and nontransient noncommunity water systems ( NTNCWSs) are, by SDWIS definition, 100 percent purchasing systems.

Unlike purchased ground water systems, purchased surface water systems may have nonpurchased supplies. To determine how many purchased surface water CWSs buy 100 percent of their water, EPA reviewed the results of the system linking exercise in section <IP_ADDRESS>. As explained in that section, the " linked" surface water system inventory was created by adding the population of 100 percent purchasing systems to their sellers and removing those systems from the inventory. A system was not " linked" to its seller if it had its own treatment plant or bought water from a system of a different type ( e. g., a CWS buying water from a NTNCWS). Thus, remaining unlinked purchased surface water Economic Analysis for Stage 2 DBPR Proposal H 6 July 2003 systems ( shown in Exhibit 3.4, columns A and B) represent either systems that purchased finished water and have their own source, or systems that buy from a different system type. In other words, those purchased surface water systems that were able to be linked represents the minimum number of 100 percent purchasing systems. Using the percentage of purchased systems that could be linked to estimate 100 percent purchasing systems may create a bias in the number of estimated 100 percent purchasing systems, but the error introduced is expected to be minimal since the number of remaining unlinked surface water CWSs is small.

From Exhibits 3.3 and 3.4, the total number SDWIS purchased surface water CWSs that could be linked is 5,890 ( 4776+ 1410 234 62), and the percent of the total is 95 [ 5890/( 4776+ 1410)]. Note that this calculation was not performed for each Stage 2 DBPR monitoring size category because inventory data in Chapter 3 is organized according to the standard nine size categories ( not the Stage 2 DBPR monitoring categories). The percentage of all purchased surface water systems that could be linked ( 95 percent) was used in Exhibit H. 2 to estimate the baseline number of purchased surface water CWSs that buy 100 percent of their water ( see column D).

Because a large portion of NTNCWSs could not be linked because they purchase water from different system types ( in many cases, a NTNCWS purchases water from a CWS and was therefore, not linked), a different methodology was used to estimate the percent of purchased surface water NTNCWS that buy 100 percent of their water. All NTNCWSs are assumed to have just one entry point per system ( as explained in section <IP_ADDRESS>, these systems are most often a single building or located in a small area). Following this logic, a purchased surface water NTNCWS is unlikely to have a second treated source   all are assumed to be 100 percent purchasing systems.

Step 3  Convert System Inventory to Plant Inventory The third step in developing the Stage 2 DBPR monitoring baseline is to estimate the baseline number of plants ( as noted earlier in this section, " plants" includes consecutive system entry points that operate for at least 60 consecutive days). This is needed because IDSE and compliance monitoring requirements for producing systems are based on the number of plants per system.

Column E in Exhibit H. 2 shows the mean number of plants per system for ( 1) surface water and all mixed systems, and ( 2) disinfecting ground water only systems that is used to transform the Stage 2 monitoring system baseline to a plant baseline. These values are based on analysis of 1995 CWSS data, question 18. Note that although they are generated using the same data set, the plant per system values for surface water and mixed systems in Exhibit H. 2 are different than plant per system values for primarily surface water systems in Exhibit 3.4 ( treatment plant baseline). This is because the " primarily surface water" category used in the treatment plant baseline contains only those mixed systems with more than 50 percent of their water from surface water sources. The " surface water and all mixed" category used for the Stage 2 DBPR monitoring includes those mixed systems using mostly ground water. Mostly ground water systems typically have more plants per system than surface water systems. Thus, mean plant per system estimates for " surface water and all mixed" are typically greater than for " primarily surface water systems. 5 Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, disclose, or provide information to or for a federal agency. This includes the time needed to review instructions; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to the collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information.

Economic Analysis for Stage 2 DBPR Proposal H 7 July 2003 H. 2 Rule Implementation Activities for Systems Exhibit H. 3 presents the costs and burden5 for systems to perform implementation activities associated with the Stage 2 DBPR. These costs represent the labor hours incurred by public water systems ( PWSs) to read the appropriate Stage 2 DBPR documents and train staff on the requirements. All systems subject to the Stage 2 DBPR are expected to undertake these implementation activities. Exhibit H. 3 presents estimates of implementation hours and costs by system type, system size, and source water type. Economic Analysis for Stage 2 DBPR Proposal H 8 July 2003 Number of Systems Read Hours per PWS Train Hours per PWS Cost per Labor Hour Total Cost Total Burden ( Hours) Total Burden ( FTEs)

A B C D E = A*( B+ C)* D F = A*( B+ C) G = F/ 2,080 3,301 4 2 24.96 $ 494,358 $ 19,806 9.52 4,655 4 2 28.95 $ 808,574 $ 27,930 13.43 1,130 4 2 28.95 $ 196,281 $ 6,780 3.26 1,105 4 2 28.95 $ 191,939 $ 6,630 3.19 602 4 2 28.95 $ 104,567 $ 3,612 1.74 316 4 4 28.95 $ 73,186 $ 2,528 1.22 250 4 4 28.95 $ 57,900 $ 2,000 0.96 36 4 4 28.95 $ 8,338 $ 288 0.14 7 4 4 28.95 $ 1,621 $ 56 0.03 1 4 4 28.95 $ 232 $ 8 0.00 National Totals 11,403 1,936,994 $ 69,638 33.48 19,150 4 1 24.96 $ 2,389,920 $ 95,750 46.03 11,520 4 1 28.95 $ 1,667,520 $ 57,600 27.69 1,373 4 1 28.95 $ 198,742 $ 6,865 3.30 56 4 1 28.95 $ 8,106 $ 280 0.13 5 4 1 28.95 $ 724 $ 25 0.01 1 4 2 28.95 $ 174 $ 6 0.00  4 2 28.95 $  $   National Totals 32,105 4,265,185 $ 160,526 77.18 581 4 1 24.96 $ 72,509 $ 2,905 1.40 218 4 1 28.95 $ 31,556 $ 1,090 0.52 11 4 1 28.95 $ 1,592 $ 55 0.03 4 4 1 28.95 $ 579 $ 20 0.01 5 4 1 28.95 $ 724 $ 25 0.01 1 4 2 28.95 $ 174 $ 6 0.00 1 4 2 28.95 $ 174 $ 6 0.00  4 2 28.95 $  $    4 2 28.95 $  $

 4 2 28.95 $  $   National Totals 821 107,307 $ 4,107 1.97 6,180 4 1 24.96 $ 771,264 $ 30,900 14.86 1,117 4 1 28.95 $ 161,686 $ 5,585 2.69 5 4 1 28.95 $ 724 $ 25 0.01 1 4 1 28.95 $ 145 $ 5 0.00  4 1 28.95 $  $    4 2 28.95 $  $

 4 2 28.95 $  $   National Totals 7,303 933,818 $ 36,515 17.56 Grand Totals 51,632 7,243,304 $ 270,786 130.19 Notes:

Sources: 1 FTE= 2,080 hours ( 40 hours/ week; 52 weeks/ year). 100,000 499,999 500,000 1,499,999 1.5 M  < 5 M ³ 5   M Detail may not add due to independent rounding. Disinfecting Ground Water Only NTNCWSs < 500 500 9,999 10,000 99,999 ³ 5   M 500,000 1,499,999 Disinfecting Ground Water Only CWSs < 500 500 9,999 10,000 99,999 100,000 499,999 500,000 1,499,999 1.5 M  < 5 M ³ 5   M < 500 Surface Water and Mixed NTNCWSs 100,000 499,999 1.5 M  < 5 M 50,000 99,999 500 4,999 5,000 9,999 10,000 24,999 25,000 49,999 100,000 499,999 1.5 M  < 5 M ³ 5   M 500,000 1,499,999 Surface Water and Mixed CWSs Size Category 50,000 99,999 < 500 500 4,999 5,000 9,999 10,000 24,999 25,000 49,999 ( A) Number of disinfecting systems ( sum of columns F and H) from Exhibit H. 2.

( B and C) Hour estimates for reading the rule and training appropriate personel estimated based on EPA experience implementing previous regulations.

( D) Labor rates from the Bureau of Labor Statistics ( 2000). An 80: 20 split between technical and managerial labor rates was assumed, except for systems serving 500 or fewer people, for which only a technical rate was applied. Exhibit H. 3 Rule Implementation Costs for Systems 6 Stage 2B requires that maximum contaminant levels ( MCLs) of 80 m g/ L for total trihalomethane ( TTHM) and 60 m g/ L for haloacetic acid ( HAA5) be met at revised sampling locations identified during the IDSE. Systems must also meet transitional MCLs of 120 m g/ L for TTHM and 100 m g/ L for HAA5, calculated as the locational running annual average ( LRAA) based on Stage 1 DBPR monitoring sites under Stage 2A.

Economic Analysis for Stage 2 DBPR Proposal H 9 July 2003 H. 3 IDSE Activities for Systems The purpose of the IDSE is to aide PWSs in determining compliance monitoring sites within their distribution systems for the Stage 2B6 DBPR. Some systems are not subject to IDSE requirements or may receive waivers. The first step in estimating costs for the IDSE is to categorize the systems into one of the five IDSE options listed below.

Systems Performing the IDSE:

° Systems conducting a standard monitoring program ( SMP)

° Systems using system specific studies ( SSS) Systems Not Performing the IDSE:

° All NTNCWSs serving fewer than 10,000 people are not subject to IDSE requirements.

° Systems serving fewer than 500 people with Stage 1 DBPR sites that represent both the highest TTHM and highest HAA5 can receive a very small system waiver.

° Systems with all TTHM and HAA5 data less than or equal to 40/ 30 µ g/ L, respectively, during the two years prior to the start of the IDSE can qualify for the 40/ 30 certification.

Costs and burden associated with IDSE activities differ depending on whether or not the system performs the IDSE and, if so, which option a system chooses. All systems performing the IDSE are expected to incur some costs.

Section H. 3.1 describes the assumptions for allocating systems to the five categories. Section H. 3.2 provides cost estimates for those systems performing the IDSE ( SMP or SSS option). Section H. 3.3 provides the rationale and, if appropriate, cost estimates for systems not performing the IDSE ( NTNCWSs serving < 10,000; systems serving < 500 that receive a waiver; and systems that qualify for the 40/ 30 certification).

H. 3.1 Categorization of Systems Exhibits H. 4a and H. 4b summarize the percentages and estimated number of systems that will conduct each IDSE activity for 100 percent purchasing systems and producing systems, respectively. The percentages associated with each IDSE activity have been derived for the total population of systems in each size category, but are applied to the number of systems in a size category sequentially. First, the small systems waiver is applied to the total number of systems; then the percentage of systems qualifying for the 40/ 30 certification is applied to the remaining systems; finally, the percentage of systems Economic Analysis for Stage 2 DBPR Proposal H 10 July 2003 conducting a SSS is applied to the systems that cannot be granted either the waiver or certification. The reason the percentages are applied sequentially is that each individual system will only select one option. For example, if they are able to receive the small system waiver they will not seek the 40/ 30 certification, even though they may qualify for it. Therefore the sub population of systems receiving the waiver is subtracted from the total population. The assumptions underlying the percentages are discussed in detail in the remainder of this section. Total numbers of systems for the IDSE categories expected to result in system costs ( SMP, SSS, and 40/ 30 certification) are presented in the last three columns of the exhibits. Note that the results in Exhibit H. 4a and H. 4b are rounded to whole systems.

NTNCWSs Serving < 10,000 People None of the NTNCWSs serving fewer than 10,000 people are subject to the IDSE requirements. The exhibits in this appendix note " N/ A" for these NTNCWS population categories.

Systems Receiving a Very Small System Waiver Systems serving fewer than 500 people may receive a very small system waiver from the IDSE requirements. For a system to qualify, the State/ Primacy Agency must determine that the monitoring site approved for Stage 1 DBPR compliance is sufficient to represent both the highest TTHM and the highest HAA5 concentrations within the distribution system. EPA estimates that 75 percent of these small systems will be able to receive a very small system waiver.

Systems Qualifying for the 40/ 30 Certification EPA used various data sources to estimate the percentage of systems that could potentially qualify for 40/ 30 certification. Based on analysis of Information Collection Rule ( ICR) data, it was estimated that 14 percent of large and medium surface water systems could show that all compliance monitoring data were less than or equal to 40 µ g/ L for TTHM and 30 µ g/ L for HAA5. EPA believes this may be an underestimate because it is based on pre Stage 1 data ( systems may make changes to meet Stage 1 requirements that will result in all of their samples being less than or equal to 40/ 30). In the absence of other information, however, EPA believes that 14 percent is the best estimate of large and medium surface water systems that could meet the 40/ 30 certification requirements.

For small surface water systems, analysis of National Rural Water Association ( NRWA) Winter and Summer data indicates that 12 percent could qualify for the 40/ 30 certification. However, small systems have a later start date for the IDSE, and some systems will most likely make treatment changes to meet the Stage 1 DBPR before the start of the IDSE. Therefore, the percent with all compliance data less than or equal to 40/ 30 for small systems is estimated to be the same as large systems at 14 percent.

For all ground water systems, ICR data were used to estimate the percentage that could qualify for the 40/ 30 certification. Approximately 24 percent of ICR ground water systems are located in Florida where total organic carbon ( TOC) levels ( and consequently disinfection byproduct [ DBP] levels) are high. Appendix B describes the analysis of Florida and non Florida ICR data, which shows that 18 percent of Florida systems have all data less than or equal to 40/ 30 and 92 percent of non Florida systems have all data less than or equal to 40/ 30. These percentages were applied to the Florida and non Florida systems in each system size category, respectively to produce the percent estimates in column C of Exhibit H. 4. Economic Analysis for Stage 2 DBPR Proposal H 11 July 2003 Total Number of 100% Purchasing Systems Percentage Receiving a Very Small System Waiver Percentage Less than or Equal to 40/ 30 Percentage Using Studies Systems Conducting IDSE SMP Systems Qualifying for the 40/ 30 Certification Systems Using Studies A B C D E= Round [ A*( 1 B)*( 1 C)*( 1 D)] F= Round [ A*( 1 B)* C] G= Round [ A*( 1 B)*( 1 C)* D]

1,961 75% 7% 0% 456 34  2,542 0% 7% 0% 2,364 178

508 0% 7% 0% 472 36  480 0% 14% 0% 413 67  227 0% 14% 0% 195 32  115 0% 14% 5% 94 16 5 65 0% 14% 10% 50 9 6 5 0% 14% 10% 4 1   0% 14% 10%

 0% 14% 10%    National Totals 5,903 4,048 373 11 815 75% 88% 0% 25 178  768 0% 88% 0% 91 677  40 0% 82% 0% 7 33  4 0% 67% 10% 1 3   0% 92% 10%     0% 18% 10%     0% 0% 10%    National Totals 1,627 124 891 0 N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A 2 0% 14% 0% 2

4 0% 14% 0% 3 1  1 0% 14% 0% 1   1 0% 14% 0% 1

 0% 14% 0%     0% 14% 0%     0% 14% 0%    National Totals 8 7 1 0 N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A 1 0% 79% 0%  1   0% 92% 0%     0% 92% 0%     0% 92% 0%     0% 92% 0%    National Totals 1 0 1 0 Grand Totals 7,539 4,179 1,266 11 Notes:

Sources:

( C) Percentage of systems with all data less than or equal to 40/ 30 for Surface Water and Mixed systems based on ICR and NRWA data. See Below 40 30. xls file in the Stage 2 cost model for the analysis ( USEPA, 2003j). Percentage below 40/ 30 for disinfecting ground water systems derived from ICR data and Florida/ non Florida stratification of systems. The estimated percentage of small surface water systems less than or equal to 40/ 30 were adjusted by 50% to account for the consecutive systems that may not have any Stage 1 sampling sites given the Stage 1 monitoring schemes for combined distribution systems were determined by the state. Size Category ( D) Percentage of systems able to use historical data based on expert opinion. 500,000 1,499,999 1.5 M  < 5 M ³ 5   M ( B) The percentage of small systems to receive a very small system waiver is an assumption based on EPA experience with small systems. Detail may not add due to independent rounding. Results in columns E, F, and G are rounded to whole systems.

( A) Number of disinfecting 100 percent purchasing systems ( Exhibit H. 2, column F). 10,000 99,999 100,000 499,999 50,000 99,999 100,000 499,999 500,000 1,499,999 1.5 M  < 5 M Disinfecting Ground Water Only NTNCWSs ³ 5   M < 500 500 9,999 500 4,999 5,000 9,999 10,000 24,999 25,000 49,999 Disinfecting Ground Water Only CWSs ³ 5   M Surface Water and Mixed NTNCWSs < 500 10,000 99,999 100,000 499,999 500,000 1,499,999 1.5 M  < 5 M 100,000 499,999 500,000 1,499,999 1.5 M  < 5 M ³ 5   M < 500 Surface Water and Mixed CWSs Shaded areas represent systems that are not subject to IDSE requirements. 500 4,999 5,000 9,999 10,000 24,999 25,000 49,999 < 500 500 9,999 50,000 99,999 Exhibit H. 4a Percent and Number of 100 Percent Purchasing Systems in Each IDSE Category Economic Analysis for Stage 2 DBPR Proposal H 12 July 2003 Total Number of Producing Systems Percentage Receiving a Very Small System Waiver Percentage Less than or Equal to 40/ 30 Percentage Using Studies Systems Conducting IDSE SMP Systems Qualifying for the 40/ 30 Certification Systems Using Studies A B C D E= Round [ A*( 1 B)*( 1 C)*( 1 D)] F= Round [ A*( 1 B)* C] G= Round [ A*( 1 B)*( 1 C)* D]

Surface Water and Mixed CWSs 1,340 75% 14% 0% 288 47  2,113 0% 14% 0% 1,817 296

622 0% 14% 0% 535 87  625 0% 14% 0% 538 88  375 0% 14% 0% 323 53

201 0% 14% 5% 164 28 9 185 0% 14% 10% 143 26 16 31 0% 14% 10% 24 4 3 7 0% 14% 10% 5 1 1 1 0% 14% 10% 1   National Totals 5,500 3,838 630 29 18,335 75% 88% 0% 570 4,014  10,752 0% 88% 0% 1,267 9,485  1,333 0% 82% 0% 236 1,097  52 0% 67% 10% 15 35 2 5 0% 92% 10%  5  1 0% 18% 10% 1    0% 0% 10%    National Totals 30,478 2,089 14,636 2 N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A 2 0% 14% 0% 2   1 0% 14% 0% 1    0% 14% 0%

 0% 14% 0%     0% 14% 10%     0% 14% 10%     0% 14% 10%    National Totals 3 3

N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A 4 0% 79% 0% 1 3  1 0% 92% 0%  1   0% 92% 0%     0% 92% 0%     0% 92% 0%    National Totals 5 1 4

Grand Totals 35,986 5,931 15,270 31 Notes:

Sources: 500,000 1,499,999 50,000 99,999 ( B) The percentage of small systems to receive a very small system waiver is an assumption based on EPA experience with small systems. < 500 500 9,999 10,000 99,999 Disinfecting Ground Water Only NTNCWSs 100,000 499,999 500,000 1,499,999 500,000 1,499,999 ( C) Percentage of systems with all data less than or equal to 40/ 30 for Surface Water and Mixed systems based on ICR and NRWA data. See Below 40 30. xls file in the Stage 2 cost model for the analysis ( USEPA, 2003j). Percentage less than or equal to 40/ 30 for disinfecting ground water systems derived from ICR data and Florida/ Non Florida stratification of systems. Surface Water and Mixed NTNCWSs Detail may not add due to independent rounding.

( A) Number of disinfecting producing systems ( Exhibit H. 2, column H). Results in columns E, F, and G are rounded to whole systems. 1.5 M  < 5 M ³ 5   M ³ 5   M 25,000 49,999 100,000 499,999 1.5 M  < 5 M < 500 500 4,999 5,000 9,999 10,000 24,999 < 500 500 4,999 Size Category ( D) Percentage of systems able to use historical data based on expert opinion. 5,000 9,999 10,000 24,999 25,000 49,999 50,000 99,999 100,000 499,999 1.5 M  < 5 M ³ 5   M < 500 Disinfecting Ground Water Only CWSs Shaded areas represent systems that are not subject to IDSE requirements. 1.5 M  < 5 M ³ 5   M 500 9,999 10,000 99,999 100,000 499,999 500,000 1,499,999 Exhibit H. 4b Percent and Number of Producing Systems in Each IDSE Category Economic Analysis for Stage 2 DBPR Proposal H 13 July 2003 The estimated percentage of 100 percent purchasing surface water systems serving less than 10,000 people that could qualify for the 40/ 30 certification has been adjusted to account for changes from Stage 1 to Stage 2 monitoring requirements. The Stage 1 DBPR monitoring requirements for 100 percent purchasing systems were left to the State/ Primacy Agency to determine, allowing them to develop a monitoring plan with consideration of the combined distribution system. It is possible that some smaller systems do not have any Stage 1 monitoring sites in their distribution system and, therefore, have no data to support the 40/ 30 certification. To account for this situation, the estimated percentage below 40/ 30 was decreased for 100 percent purchasing surface water systems serving less than 10,000 people. EPA assumed that the 40/ 30 certification would not be possible for 100 percent purchasing systems serving less than 10,000 people that purchase water from systems serving more than 10,000 people ( the percentage of purchased systems serving < 10,000 that buy from systems serving > 10,000 was obtained from the Geometries and Characteristics for Public Water Systems [ USEPA 2000c]). EPA believes this results in a low estimate of the systems that could qualify for the certification, meaning it is likely that more systems will be able to meet the 40/ 30 certification criteria than accounted for in the IDSE cost calculations.

Conducting an SSS An SSS can be used instead of an SMP if the system can show that an SSS provides equivalent or superior Stage 2B site selection. An SSS can be based on hydraulic modeling results and historical data, among other things. EPA estimates that 10 percent of the surface water and disinfecting ground water systems serving more than 100,000 people and 5 percent of surface water systems serving 50,000 to 100,000 people will be able to complete an SSS in lieu of monitoring. It is assumed that surface water systems serving fewer than 50,000 people and ground water systems serving fewer than 100,000 people will not have adequate historical data or models to meet the SSS requirements.

Conducting an SMP All systems that do not receive a waiver, do not qualify for the 40/ 30 certification, or cannot use an SSS are required to perform the SMP. The SMP involves selecting specific types of sample sites in the distribution system ( e. g., maximum TTHM sites, sites near the entry point) and monitoring at those sites for 1 year. The number and type of required samples are based on system size, the number of plants in the system ( for producing systems), source water type, and residual disinfectant type. The system must prepare a report summarizing the results of the SMP and justifying selection of Stage 2B compliance monitoring sites.

H. 3.2 Costs for Systems Performing the IDSE Systems Conducting the SMP An SMP consists of three activities   site selection, monitoring, and reporting. Costs associated with site selection result from the labor effort required to evaluate the distribution system and select the sites. Labor hours are estimated on a per system basis and vary by system size, with the assumption that larger systems need more time to select sites. The labor hour estimates for site selection are based on expert opinion and experience with other rules.

Monitoring costs include labor for sample collection and laboratory costs for sample analysis. These costs are estimated from the number of samples required. EPA estimates an average of one hour Economic Analysis for Stage 2 DBPR Proposal H 14 July 2003 to collect one sample. Laboratory costs include $ 200 for analysis of TTHM and HAA5 paired samples and $ 20 in delivery charges. These costs represent averages obtained from the ICR ( see Chapter 6, section 6.1.1 for more information on laboratory cost assumptions). Costs per sample for ground and surface water plants are not expected to differ substantially.

As noted in section H. 1, the total number of sampling sites and frequency of sampling for 100 percent purchasing systems is a function of system size ( population served) and source water type, not the number of plants. For producing systems, the total number of sampling sites is a function of system size, source water type, and the number of plants in the system. The frequency of sampling is a function of the system size and source water type. For both 100 percent purchasing and producing systems, larger systems must sample at more sites and more frequently than smaller ones, which typically have shorter and less complex distribution systems. Surface water sources generally have higher DBP precursor levels than ground water sources; therefore, they have a greater potential for high DBP occurrence.

Reporting costs reflect the labor required for systems to prepare and submit a report to their State/ Primacy Agency on IDSE results and their proposed Stage 2B DBPR compliance monitoring sites. These costs are estimated on a per system basis for all systems. The reporting labor rate is the same rate that is used for site selection.

Exhibits H. 5a and H. 5b show the calculations and estimated costs and burden for 100 percent purchasing and producing systems, respectively, expected to monitor for the IDSE.

Systems That Perform an SSS Cost estimates for systems conducting an SSS consist only of system level reporting costs. These reporting costs are associated with activities that include gathering, researching, and analyzing distribution system information. As a result, EPA estimates that more reporting labor hours will be required than would be required only to report the results of monitoring ( as presented in Exhibits H. 5a and H. 5b). Exhibits H. 6a and H. 6b show the calculations and estimated costs and burden for 100 percent purchasing and producing systems, respectively, for completing an SSS in lieu of an SMP to fulfill IDSE requirements. Economic Analysis for Stage 2 DBPR Proposal H 15 July 2003 Number of Dual Sample Sets per System Hours per Sample Sampling Cost per Labor Hour Laboratory Cost per Sample Site Selection Hours per System Reporting Hours per System Site Selection/ Reporting Cost per Labor Hour A B C D E F G H I= A*( B*( C* D+ E)+ H*( F+ G)) J= A*( B* C+ F+ G) K= J/ 2,080 456 4 1 24.96 $ 220 $ 4 2 24.96 $ 515,098 $ 4,560 2.2 2,364 8 1 24.96 $ 220 $ 4 2 28.95 $ 5,043,310 $ 33,096 15.9 472 16 1 24.96 $ 220 $ 4 2 28.95 $ 1,931,924 $ 10,384 5.0 413 48 1 24.96 $ 220 $ 4 4 28.95 $ 4,951,738 $ 23,128 11.1 195 72 1 24.96 $ 220 $ 8 4 28.95 $ 3,506,981 $ 16,380 7.9 94 96 1 24.96 $ 220 $ 8 8 28.95 $ 2,254,060 $ 10,528 5.1 50 144 1 24.96 $ 220 $ 12 12 28.95 $ 1,798,452 $ 8,400 4.0 4 192 1 24.96 $ 220 $ 16 24 28.95 $ 192,761 $ 928 0.4  240 1 24.96 $ 220 $ 20 24 28.95 $  $    288 1 24.96 $ 220 $ 24 24 28.95 $  $   4,048 20,194,325 $ 107,404 51.6 25 4 1 24.96 $ 220 $ 4 2 24.96 $ 28,240 $ 250 0.1 91 8 1 24.96 $ 220 $ 4 2 28.95 $ 194,138 $ 1,274 0.6 7 24 1 24.96 $ 220 $ 8 8 28.95 $ 44,396 $ 280 0.1 1 32 1 24.96 $ 220 $ 12 12 28.95 $ 8,534 $ 56 0.0 0 48 1 24.96 $ 220 $ 16 24 28.95 $  $   0 48 1 24.96 $ 220 $ 20 24 28.95 $  $

0 48 1 24.96 $ 220 $ 24 24 28.95 $  $   124 275,307 $ 1,860 0.9 N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A 2 48 1 24.96 $ 220 $ 4 4 28.95 $ 23,979 $ 112 0.1 3 72 1 24.96 $ 220 $ 8 4 28.95 $ 53,954 $ 252 0.1 1 96 1 24.96 $ 220 $ 8 8 28.95 $ 23,979 $ 112 0.1 1 144 1 24.96 $ 220 $ 12 12 28.95 $ 35,969 $ 168 0.1 0 192 1 24.96 $ 220 $ 16 24 28.95 $  $   0 240 1 24.96 $ 220 $ 20 24 28.95 $  $   0 288 1 24.96 $ 220 $ 24 24 28.95 $  $

7 137,881 $ 644 0.3 Disinfecting Ground Water Only NTNCWSs N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A 0 24 1 24.96 $ 220 $ 8 8 28.95 $  $   0 32 1 24.96 $ 220 $ 12 12 28.95 $  $   0 48 1 24.96 $ 220 $ 16 24 28.95 $  $

0 48 1 24.96 $ 220 $ 20 24 28.95 $  $   0 48 1 24.96 $ 220 $ 24 24 28.95 $  $   0  $ 0 0.0 Grand Totals 4,179 20,607,513 $ 109,908 52.8 Notes:

Sources: Number of 100% Purchasing Systems That Monitor Total Cost Total Burden ( Hours) Total Burden ( FTEs) Sampling Site Selection and Reporting < 500 500 4,999 5,000 9,999 Size Category 10,000 24,999 25,000 49,999 50,000 99,999 100,000 499,999 500,000 1,499,999 1.5 M  < 5 M ³ 5   M National Totals < 500 500 9,999 10,000 99,999 100,000 499,999 500,000 1,499,999 1.5 M  < 5 M ³ 5   M National Totals < 500 500 4,999 10,000 99,999 100,000 499,999 5,000 9,999 10,000 24,999 25,000 49,999 50,000 99,999 National Totals < 500 100,000 499,999 500,000 1,499,999 National Totals Surface Water and Mixed CWSs Disinfecting Ground Water Only CWSs Surface Water and Mixed NTNCWSs 1.5 M  < 5 M ³ 5   M 500 9,999 500,000 1,499,999 1.5 M  < 5 M ³ 5   M Detail may not add due to independent rounding. Shaded areas represent systems that are not subject to IDSE requirements.

( H) Site selection and reporting labor rates estimated based on labor rates from the Bureau of Labor Statistics ( 2000). An 80: 20 split between technical and managerial labor rates was assumed, except for systems serving 500 or fewer people, for which only a technical rate was applied. ( D) Sampling labor rates estimated based on technical labor rates from the Bureau of Labor Statistics ( 2000). ( E) Laboratory cost for TTHM and HAA5 analyses per sample based on costs incurred for the ICR. 1 FTE= 2,080 hours ( 40 hours/ week; 52 weeks/ year).

( A) From Exhibit H. 4a, column E. ( B) Number of IDSE samples per system based on rule requirements for conducting IDSE monitoring ( population based approach for 100 percent purchasing systems). ( C) Labor hours per sample reflects EPA estimate.

( F and G) Labor hours for site selection and reporting based on expert opinion received during regulatory development process. Exhibit H. 5a IDSE Costs for 100 Percent Purchasing Systems Using SMPs Economic Analysis for Stage 2 DBPR Proposal H 16 July 2003 Number of Producing Plants that Monitor Number of Dual Sample Sets per Plant Hours per Sample Sampling Cost per Labor Hour Laboratory Cost per Sample Number of Producing Systems that Monitor Site Selection Hours per System Reporting Hours per System Cost per Labor Hour A B C D E F G H I J=( A*( B*( C* D+ E))+ ( F*( G+ H)* I) K= A* B* C+ F* ( G+ H) L= K/ 2,080 403 4 1 24.96 $ 220 $ 288 4 2 24.96 $ 438,202 $ 3,341 1.6 2,362 8 1 24.96 $ 220 $ 1,817 4 2 28.95 $ 4,944,573 $ 29,799 14.3 910 8 1 24.96 $ 220 $ 535 4 2 28.95 $ 1,875,258 $ 10,486 5.0 1,076 48 1 24.96 $ 220 $ 538 4 4 28.95 $ 12,776,295 $ 55,952 26.9 711 48 1 24.96 $ 220 $ 323 8 4 28.95 $ 8,467,502 $ 37,985 18.3 558 48 1 24.96 $ 220 $ 164 8 8 28.95 $ 6,632,270 $ 29,389 14.1 429 48 1 24.96 $ 220 $ 143 12 12 28.95 $ 5,143,573 $ 24,024 11.6 139 48 1 24.96 $ 220 $ 24 16 24 28.95 $ 1,664,517 $ 7,642 3.7 29 48 1 24.96 $ 200 $ 5 20 24 28.95 $ 319,513 $ 1,612 0.8 6 48 1 24.96 $ 200 $ 1 24 24 28.95 $ 64,018 $ 326 0.2 National Totals 6,622 3,838 42,325,722 $ 200,555 96.4 798 4 1 24.96 $ 220 $ 570 4 2 24.96 $ 867,276 $ 6,612 3.2 2,281 4 1 24.96 $ 220 $ 1,267 4 2 28.95 $ 2,454,701 $ 16,724 8.0 1,015 8 1 24.96 $ 220 $ 236 8 8 28.95 $ 2,097,998 $ 11,894 5.7 149 8 1 24.96 $ 220 $ 15 12 12 28.95 $ 301,434 $ 1,548 0.7  8 1 24.96 $ 220 $  16 24 28.95 $  $   10 8 1 24.96 $ 220 $ 1 20 24 28.95 $ 20,675 $ 123 0.1  8 1 24.96 $ 220 $  24 24 28.95 $  $   National Totals 4,252 2,089 5,742,084 $ 36,902 17.7 N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A 2 48 1 24.96 $ 220 $ 2 4 4 28.95 $ 23,979 $ 112 0.1 1 48 1 24.96 $ 220 $ 1 8 4 28.95 $ 12,105 $ 60 0.0  48 1 24.96 $ 220 $ 0 8 8 28.95 $  $    48 1 24.96 $ 220 $ 0 12 12 28.95 $  $    48 1 24.96 $ 220 $ 0 16 24 28.95 $  $    48 1 24.96 $ 200 $ 0 20 24 28.95 $  $    48 1 24.96 $ 200 $ 0 24 24 28.95 $  $   National Totals 3 3 36,085 $ 172 0.1 N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A 1 8 1 24.96 $ 220 $ 1 8 8 28.95 $ 2,423 $ 24 0.0  8 1 24.96 $ 220 $ 0 12 12 28.95 $  $    8 1 24.96 $ 220 $ 0 16 24 28.95 $  $    8 1 24.96 $ 220 $ 0 20 24 28.95 $  $    8 1 24.96 $ 220 $ 0 24 24 28.95 $  $   National Totals 1 1 2,423 $ 24 0.0 Grand Totals 10,878 48,106,314 $ 237,653 114.3 Notes:

Sources: < 500 ( F) Number of systems that monitor from Exhibit H. 4b ( column E).

( I) Site selection and reporting labor rates estimated based on labor rates from the Bureau of Labor Statistics ( 2000). An 80: 20 split between technical and managerial labor rates was assumed, except for systems serving 500 or fewer people, for which only a technical rate was applied. 1 FTE= 2,080 hours ( 40 hours/ week; 52 weeks/ year).

( C) Labor hours per sample reflects EPA estimate.

( E) Laboratory cost for TTHM and HAA5 analyses per sample based on costs incurred for the ICR.

( G) and ( H) Labor hours for site selection and reporting based on expert opinion received during regulatory development process. ( A) Number of systems that monitor from Exhibit H. 4b ( column E) times the number of plants per system in Exhibit H. 2 ( column E).

( B) Number of IDSE samples per plant based on rule requirements ( Plant based approach for producing systems). Detail may not add due to independent rounding.

( D) Sampling labor rates estimated based on technical labor rates from the Bureau of Labor Statistics ( 2000). Shaded areas represent systems that are not subject to IDSE requirements. 1.5 M  < 5 M ³ 5   M ³ 5   M < 500 Surface Water and Mixed NTNCWSs 500 4,999 5,000 9,999 10,000 24,999 100,000 499,999 500,000 1,499,999 ³ 5   M Disinfecting Ground Water Only NTNCWSs < 500 100,000 499,999 500,000 1,499,999 1.5 M  < 5 M 100,000 499,999 500 9,999 25,000 49,999 50,000 99,999 10,000 99,999 500,000 1,499,999 1.5 M  < 5 M 10,000 99,999 1.5 M  < 5 M Surface Water and Mixed CWSs 500 4,999 < 500 ³ 5   M 500 9,999 Disinfecting Ground Water Only CWSs 50,000 99,999 500,000 1,499,999 Size Category 100,000 499,999 Total Burden ( Hours) Total Burden ( FTEs) Site Selection and Reporting Sampling Total Cost 25,000 49,999 5,000 9,999 10,000 24,999 Exhibit H. 5b IDSE Costs for Producing Systems using SMPs Economic Analysis for Stage 2 DBPR Proposal H 17 July 2003 Number of 100% Purchasing Systems Qualifying for 40/ 30 Certification Reporting Hours per System Cost per Labor Hour Total Cost Total Burden ( Hours) Total Burden ( FTEs) A B C D = A* B* C E = A* B F = E/ 2,080    $      $      $      $

   $   5 40 28.95 $ 5,790 $ 200 0.1 6 40 28.95 $ 6,948 $ 240 0.1    $      $      $

National Total 11 12,738 $ 440 0.2    $      $      $      $      $      $      $      $      $

National Total   $

N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A    $      $      $      $      $      $      $   National Total   $

N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A    $      $      $      $      $   National Total   $

Grand Totals 11 12,738 $ 440 0.2 Notes:

Sources: Surface Water and Mixed CWSs Size Category < 500 500 4,999 5,000 9,999 10,000 24,999 ³   5   M Disinfecting Ground Water Only CWSs < 500 25,000 49,999 50,000 99,999 500,000 1,499,999 1.5 M  < 5 M 100,000 499,999 50,000 99,999 100,000 499,999 Surface Water and Mixed NTNCWSs 500 4,999 5,000 9,999 10,000 24,999 25,000 49,999 1.5 M  < 5 M ³ 5   M < 500 500 4,999 5,000 9,999 10,000 24,999 Disinfecting Ground Water Only NTNCWSs < 500 25,000 49,999 50,000 99,999 100,000 499,999 500,000 1,499,999 1.5 M  < 5 M ³ 5   M ³ 5   M Shaded areas represent systems that are not subject to IDSE requirements. 1.5 M  < 5 M Detail may not add due to independent rounding. 10,000 99,999 100,000 499,999 500,000 1,499,999 500 9,999 ( C) Labor rates from the Bureau of Labor Statistics. An 80: 20 split between technical and managerial labor rates was assumed, except for systems serving 500 or fewer people, for which only a technical rate was applied. 1 FTE= 2,080 hours ( 40 hours/ week; 52 weeks/ year). ( A) Number of systems using studies to satisfy IDSE requirements from Exhibit H. 4a, column G.

( B) Reporting hours required per system based on expert opinion. Exhibit H. 6a IDSE Costs for 100 Percent Purchasing Systems Using SSSs Economic Analysis for Stage 2 DBPR Proposal H 18 July 2003 Producing Systems Qualifying for 40/ 30 Certification Reporting Hours per System Cost per Labor Hour Total Cost Total Burden ( Hours) Total Burden ( FTEs) A B C D = A* B* C E = A* B F = E/ 2,080   $     $     $     $     $   9  $

16 40 28.95 $ 18,528 $ 640 0.3 3 40 28.95 $ 3,474 $ 120 0.1 1 40 28.95 $ 1,158 $ 40 0.0   $   National Total 29 23,160 $ 800 0.4   $     $     $   2 40 28.95 $ 2,316 $ 80 0.0   $     $     $   National Total 2 2,316 $ 80 0.0 N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A   $     $

  $     $     $     $     $   National Total   $

N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A   $     $     $     $     $   National Total   $

Grand Totals 31 25,476 $ 880 0.4 Notes:

Sources: 500 4,999 100,000 499,999 Disinfecting Ground Water Only NTNCWSs 1.5 M  < 5 M 500 9,999 100,000 499,999 5,000 9,999 10,000 24,999 25,000 49,999 50,000 99,999 < 500 Surface Water and Mixed CWSs Size Category 100,000 499,999 ³ 5   M < 500 < 500 Disinfecting Ground Water Only CWSs 500 9,999 10,000 99,999 500,000 1,499,999 1.5 M  < 5 M 500,000 1,499,999 1.5 M  < 5 M ³ 5   M 500 4,999 5,000 9,999 10,000 24,999 100,000 499,999 500,000 1,499,999 25,000 49,999 1.5 M  < 5 M ³ 5   M Surface Water and Mixed NTNCWSs Detail may not add due to independent rounding. 500,000 1,499,999 < 500 10,000 99,999 50,000 99,999 ³ 5   M Shaded areas represent systems that are not subject to IDSE requirements.

( A) Number of systems using studies to satisfy IDSE requirements from Exhibit H. 4b, column G. ( B) Reporting hours required per system based on expert opinion. ( C) Labor rates from the Bureau of Labor Statistics. An 80: 20 split between technical and managerial labor rates was assumed, except for systems serving 500 or fewer people, for which only a technical rate was applied. 1 FTE= 2,080 hours ( 40 hours/ week; 52 weeks/ year). Exhibit H. 6b IDSE Costs for Producing Systems Using SSSs Economic Analysis for Stage 2 DBPR Proposal H 19 July 2003 H. 3.3 Costs for Systems Not Performing the IDSE As noted in the beginning of section H. 3, there are three types of systems that do not have to perform the IDSE:

° All NTNCWSs serving fewer than 10,000 people ( they are not subject to IDSE requirements)

° Systems receiving the very small system waiver ( States/ Primacy Agencies can grant this waiver if they determine that a system's high TTHM and HAA5 concentrations can be represented by one site)

° Systems qualifying for the 40/ 30 certification ( all TTHM and HAA5 compliance monitoring data must be less than or equal to 40/ 30 µ g/ L, respectively)

Since NTNCWSs serving fewer than 10,000 people are not subject to IDSE requirements, they are assumed to bear no costs. EPA estimates a minimal burden for systems to obtain a very small system waiver from their State/ Primacy Agency, given this activity is considered to be part of their routine communication. Therefore, this EA does not include costs for systems getting the very small system waiver.

Systems qualifying for 40/ 30 certification are expected to bear some costs for the IDSE since they must submit a report with their TTHM/ HAA5 monitoring results and a schematic of their distribution system with the results, locations, and date of all compliance samples noted. Cost calculations are shown in Exhibit H. 7a and H. 7b. Because some components of IDSE reports for 40/ 30 certification and for SMPs are similar, the labor cost to prepare a report for 40/ 30 certification was estimated to be some fraction of the labor cost estimate for preparing the IDSE report for systems performing monitoring ( see section H. 3.2 for a derivation of costs for the IDSE SMP). Reporting hours for the IDSE SMP are in Exhibit H. 5a, column G for 100 percent purchasing systems and Exhibit H. 5b, column H for producing systems. For systems serving fewer than 10,000 people, reporting hours for 40/ 30 certification reports were estimated to be half ( 50 percent) of the reporting hours for IDSE SMPs. For systems serving at least 10,000 people, reporting hours for 40/ 30 certification were estimated to be one quarter ( 25 percent) of the reporting hours for IDSE SMPs. Resulting reporting hours for systems qualifying for 40/ 30 certification are shown in column D of Exhibit H. 7a and column B of Exhibit H. 7b EPA also considers costs for those systems that qualify for the 40/ 30 certification and do not have to perform the IDSE, but must select additional Stage 2B sites compared to Stage 1 DBPR requirements. Producing systems not performing the IDSE have the option of maintaining their Stage 1 DBPR site locations as their Stage 2B sites. Therefore, EPA does not attribute site selection costs for producing systems that qualify for the 40/ 30 certification. There are changes, however, in site requirements for 100 percent purchasing systems from Stage 1 to Stage 2B because of the change from plant to population based monitoring requirements. Some 100 percent purchasing systems are predicted to show a reduction in the required number of sites from Stage 1 to Stage 2B, but many are predicted to add sites. Exhibit H. 7a shows EPA's estimated site selection costs and burden for 100 percent purchasing systems that qualify for the 40/ 30 certification and do not conduct the IDSE, but are predicted to add sample sites for the Stage 2B DBPR ( see section H. 4 for estimates of 100 percent purchasing systems adding sites for the Stage 2 DBPR). Economic Analysis for Stage 2 DBPR Proposal H 20 July 2003 Systems Qualifying for 40/ 30 Certification but Adding Stage 2B site( s) Hours per System Number of 100% Purchasing Systems Qualifying for 40/ 30 Certification Reporting Hours per System A B C D E F = ( A* B+ C* D)* E G = A* B+ C* D H = G/ 2,080  1 34 1 28.95 $ 984 $ 34 0.0 178 3 178 1 28.95 $ 20,612 $ 712 0.3 36 3 36 1 28.95 $ 4,169 $ 144 0.1  8 67 1 28.95 $ 1,940 $ 67 0.0  8 32 1 28.95 $ 926 $ 32 0.0  8 16 2 28.95 $ 926 $ 32 0.0  8 9 3 28.95 $ 782 $ 27 0.0  8 1 6 28.95 $ 174 $ 6 0.0  8  6 28.95 $  $    8  6 28.95 $  $   National Total 214 373 30,513 $ 1,054 0.5  1 178 1 28.95 $ 5,153 $ 178 0.1 677 3 677 1 28.95 $ 78,397 $ 2,708 1.3 33 8 33 2 28.95 $ 9,554 $ 330 0.2  8 3 3 28.95 $ 261 $ 9 0.0  8  6 28.95 $  $    8  6 28.95 $  $    8  6 28.95 $  $   National Total 710 891 93,364 $ 3,225 1.6 N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A  8  1 28.95 $  $   1 8 1 1 28.95 $ 261 $ 9 0.0  8  2 28.95 $  $    8  3 28.95 $  $    8  6 28.95 $  $    8  6 28.95 $  $    8  6 28.95 $  $   National Total 1 1 261 $ 9 0.0 N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A 1 8 1 2 28.95 $ 290 $ 10 0.0  8  3 28.95 $  $    8  6 28.95 $  $    8  6 28.95 $  $    8  6 28.95 $  $   National Total 1 1 290 $ 10 0.0 Grand Totals 926 1,266 124,427 $ 4,298 2.1 Notes:

Sources: Detail may not add due to independent rounding.

Shaded areas represent systems that are not subject to IDSE requirements. 1 FTE= 2,080 hours ( 40 hours/ week; 52 weeks/ year).

( A) Number of systems less than or equal to 40/ 30 from Exhibit H. 4a ( column F) for only those system size categories that are predicted to have additional routine monitoring from Stage 1 to Stage 2b ( see Exhibit H. 8a, column D).

( B) Hours per system required to select new sites for Stage 2B based on expert opinion.

( E) Labor rates from the Bureau of Labor Statistics. An 80: 20 split between technical and managerial labor rates was assumed, except for systems serving 500 or fewer people, for which only a technical rate was applied. ( C) Number of systems that qualify for 40/ 30 certification from Exhibit H. 4a, column F. 100,000 499,999 500,000 1,499,999 1.5 M  < 5 M ³ 5   M Disinfecting Ground Water Only NTNCWSs < 500 500 9,999 10,000 99,999 100,000 499,999 500,000 1,499,999 1.5 M  < 5 M ³ 5   M 1.5 M  < 5 M ³ 5   M Surface Water and Mixed NTNCWSs ( D) Reporting hours are a fraction of reporting hours estimated for IDSE monitoring ( Exhibit H. 5a, column G). For systems serving < 10,000, reporting hours for systems qualifying for 40/ 30 certification are estimated to be 1/ 2 that of reporting hours for systems conducting the IDSE SMP. For systems serving > 10,000, reporting hours for systems qualifying for 40/ 30 certification are estimated to be 1/ 4 that of reporting hours for systems conducting the IDSE SMP. < 500 500 4,999 5,000 9,999 10,000 24,999 25,000 49,999 50,000 99,999 500 9,999 10,000 99,999 100,000 499,999 500,000 1,499,999 1.5 M  < 5 M ³   5   M Disinfecting Ground Water Only CWSs < 500 25,000 49,999 50,000 99,999 100,000 499,999 500,000 1,499,999 5,000 9,999 10,000 24,999 Surface Water and Mixed CWSs < 500 Selecting additional sites Size Category Cost per Labor Hour 500 4,999 Total Cost Total Burden ( Hours) Total Burden ( FTEs) Preparing IDSE Report Exhibit H. 7a IDSE Costs for 100 Percent Purchasing Systems Qualifying for the 40/ 30 Certification Economic Analysis for Stage 2 DBPR Proposal H 21 July 2003 Number of Producing Systems Qualifying for 40/ 30 Certification Reporting Hours per System Cost per Labor Hour Total Cost Total Burden ( Hours) Total Burden ( FTEs)

A B C D = A* B* C E = A* B F = E/ 2,080 47 1 28.95 $ 1,361 $ 47 0.0 296 1 28.95 $ 8,569 $ 296 0.1 87 1 28.95 $ 2,519 $ 87 0.0 88 1 28.95 $ 2,548 $ 88 0.0 53 1 28.95 $ 1,534 $ 53 0.0 28 2 28.95 $ 1,621 $ 56 0.0 26 3 28.95 $ 2,258 $ 78 0.0 4 6 28.95 $ 695 $ 24 0.0 1 6 28.95 $ 174 $ 6 0.0  6 28.95 $  $   National Total 630 21,278 $ 735 0.4 4,014 1 28.95 $ 116,205 $ 4,014 1.9 9,485 1 28.95 $ 274,591 $ 9,485 4.6 1,097 2 28.95 $ 63,516 $ 2,194 1.1 35 3 28.95 $ 3,040 $ 105 0.1 5 6 28.95 $ 869 $ 30 0.0  6 28.95 $  $    6 28.95 $  $

National Total 14,636 458,221 $ 15,828 7.6 N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A  1 28.95 $  $

 1 28.95 $  $    2 28.95 $  $    3 28.95 $  $    6 28.95 $  $

 6 28.95 $  $    6 28.95 $  $

National Total   $

N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A 3 2 28.95 $ 174 $ 6 0.0 1 3 28.95 $ 87 $ 3 0.0  6 28.95 $  $    6 28.95 $  $

 6 28.95 $  $   National Total 4 261 $ 9 0.0 Grand Totals 15,270 479,759 $ 16,572 8.0 Notes:

Sources: Size Category 25,000 49,999 50,000 99,999 100,000 499,999 500 4,999 5,000 9,999 10,000 24,999 Surface Water and Mixed CWSs < 500 500,000 1,499,999 1.5 M  < 5 M ³   5   M Disinfecting Ground Water Only CWSs < 500 < 500 500 9,999 10,000 99,999 100,000 499,999 500,000 1,499,999 1.5 M  < 5 M ³ 5   M Surface Water and Mixed NTNCWSs 500 4,999 5,000 9,999 10,000 24,999 ³ 5   M 1.5 M  < 5 M 25,000 49,999 50,000 99,999 100,000 499,999 500,000 1,499,999 Disinfecting Ground Water Only NTNCWSs < 500 500 9,999 10,000 99,999 100,000 499,999 500,000 1,499,999 1.5 M  < 5 M ³ 5   M Detail may not add due to independent rounding.

Shaded areas represent systems that are not subject to IDSE requirements.

( C) Labor rates from the Bureau of Labor Statistics ( 2000). An 80: 20 split between technical and managerial labor rates was assumed, except for systems serving 500 or fewer people, for which only a technical rate was applied. 1 FTE= 2,080 hours ( 40 hours/ week; 52 weeks/ year).

( A) Number of systems that qualify for 40/ 30 certification from Exhibit H. 4b, column F.

( B) Reporting hours are a fraction of reporting hours estimated for IDSE monitoring ( Exhibit H. 5b, column H). For systems serving < 10,000, reporting hours for systems qualifying for 40/ 30 certification are estimated to be 1/ 2 that of reporting hours for systems conducting the IDSE SMP. For systems serving > 10,000, reporting hours for systems qualifying for 40/ 30 certification are estimated to be 1/ 4 that of reporting hours for systems conducting the IDSE SMP. Exhibit H. 7b IDSE Costs for Producing Systems Qualifying for the 40/ 30 Certification 7 This was based on the average of four quarters of data for each of four distribution system sites ( AVE1, AVE2, DSE, and MAX for plants with at least three quarters of data). Plants with the highest four quarter HAA5 average and highest four quarter TTHM average occurring at the same location were assumed to be able to qualify for a reduction in number of monitoring sites under the Stage 2 DBPR.

Economic Analysis for Stage 2 DBPR Proposal H 22 July 2003 H. 4 Additional Routine Monitoring Costs for Systems This section presents the costs for systems to perform additional routine monitoring associated with the Stage 2B DBPR. The additional routine monitoring cost estimates are dependent on the change in the number of samples to be collected from the Stage 1 to the Stage 2B DBPR.

100 Percent Purchasing Systems The Stage 2B DBPR monitoring requirements for 100 percent purchasing systems are based only on population served and source water type, while the Stage 1 DBPR requirements are also based on the number of treatment plants. With this modification in monitoring scheme, the number of samples required is estimated to decrease from the Stage 1 to the Stage 2 DBPR for many systems. Exhibit H. 8a summarizes the estimated change in number of samples required and the associated cost. An explanation of this exhibit is provided in the following paragraphs.

Columns E and I show the number of Stage 2B DBPR routine samples per system required for 100 percent purchasing systems. For surface water systems serving less than 5,000 people and disinfecting ground water systems serving less than 500 people, two sites per system are required, one representing the high TTHM and the other representing the high HAA5 site. ( Note that for surface water systems serving 500 to 4,999 people, samples must be collected every 90 days, resulting in a total of 8 samples per system. Surface and ground water systems serving less than 500 people only have to collect one sample per year, resulting in two samples per system as shown in Exhibit H. 8a). The Stage 2 DBPR allows these systems to use one instead of two sites if it represents both the high TTHM and high HAA5 location.

The percent of systems that can use one monitoring site ( instead of 2) to represent both high TTHM and high HAA5 concentrations is estimated separately for those that perform the IDSE and those that do not. This is because systems that conduct the IDSE will have TTHM and HAA5 data, while those that do not conduct the IDSE will not have DBP data and will have to rely on an indicator. For 100 percent purchasing CWSs that perform the IDSE, EPA evaluated data from the last four quarters of the ICR to estimate the percentage of systems that had their highest TTHM and HAA5 at the same location7 and thus, qualify for only one site and half the number of samples per year shown in Exhibit H. 8a. Results of this analysis show that approximately 56 percent of surface water and 46 percent of ground water plants have their high TTHM and HAA5 sites at the same location and will collect half the maximum possible number of samples required.

For 100 percent purchasing CWSs not performing the IDSE, the percentage of systems qualifying for reduced monitoring can be estimated using disinfectant residual data. This is because conditions of low or no disinfectant residual could lead to biological degradation of HAA5 concentrations ( Singer and Reckhow 1999). Thus, the maximum HAA5 site might be closer to the treatment plant if there are sites with no or low residual. Economic Analysis for Stage 2 DBPR Proposal H 23 July 2003 Total 100% Purchasing Systems Performing the IDSE Routine Samples per System Percent of Systems with Reduced Sample Sites Number of Stage 2B Samples Total 100% Purchasing Systems Not Performing IDSE Routine Samples per System Percent of Systems with Reduced Sample Sites Number of Stage 2B Samples A B C= A* B D E F G=[ D* E*( 1 F)] +[ D* E/ 2* F] H I J K=[ H* I*( 1 J)]+ [ H* I/ 2* J] L= G+ K 2,745 1 2,745 456 2 56% 654 1,505 2 75% 1,881 2,536 3,305 4 13,220 2,364 8 56% 13,571 178 8 75% 890 14,461 864 4 3,456 472 8 0% 3,776 36 8 0% 288 4,064 960 16 15,360 413 16 0% 6,608 67 16 0% 1,072 7,680 499 16 7,984 195 24 0% 4,680 32 24 0% 768 5,448 391 16 6,256 99 32 0% 3,168 16 32 0% 512 3,680 195 16 3,120 56 48 0% 2,688 9 48 0% 432 3,120 29 16 464 4 64 0% 256 1 64 0% 64 320  16   80 0%  0 80 0%    16   96 0%  0 96 0%   National Totals 8,988 52,605 4,059 35,401 1,844 5,907 41,308 1,141 1 1,141 25 2 46% 38 790 2 65% 1,067 1,105 1,382 1 1,382 91 2 0% 182 677 2 0% 1,354 1,536 172 1 172 7 16 0% 112 33 16 0% 528 640 40 4 160 1 24 0% 24 3 24 0% 72 96  4   32 0% 0 0 32 0%    4   32 0% 0 0 32 0%    4   32 0% 0 0 32 0%   National Totals 2,735 2,855 124 356 1,503 3,021 3,377 158 1 158  2 100% 0 158 2 100% 158 158 56 4 224  8 100% 0 56 8 100% 224 224 6 4 24  8 0% 0 6 8 0% 48 48 2 16 32 2 16 0% 32 0 16 0% 0 32 4 16 64 3 24 0% 72 1 24 0% 24 96 1 16 16 1 32 0% 32 0 32 0% 0 32 1 16 16 1 48 0% 48 0 48 0% 0 48  16   64 0% 0 0 64 0% 0   16   80 0% 0 0 80 0% 0   16   96 0% 0 0 96 0% 0  National Totals 228 534 7 184 221 454 638 26 1 26  2 100% 0 26 2 100% 26 26 8 1 8  2 0% 0 8 2 0% 16 16 1 1 1  16 0% 0 1 16 0% 16 16  4   24 0% 0 0 24 0% 0   4   32 0% 0 0 32 0% 0   4   32 0% 0 0 32 0% 0   4   32 0% 0 0 32 0% 0  National Totals 35 35   35 58 Grand Totals 11,986 56,029 4,190 35,942 3,603 32 45,381 Notes: Detail may not added due to independent rounding.

Sources:

( H) Number of systems not perfomring IDSE is the total of 100% purchasing systems ( Exhibit H. 2, column F) minus those performing an SSS or SMP ( column D).

( J) Percentage of plants with reduced sample sites based on analysis of Information Collection Rule and NRWA data, percent of systems that do have a detectable residual at all sample locations. Systems will incur only routine monitoring costs for sites and samples that are required beyond those required under the Stage 1 DBPR ( i. e., systems that, as a result of the IDSE, only move sample sites will incur no additional costs). 1 FTE = 2,080 hours ( 40 hours/ week; 52 weeks/ year). ( A) Number of plants from Exhibit H. 2 ( column G). Disinfecting Ground Water Only NTNCWSs 500,000 1,499,999 1.5 M  < 5 M ³ 5   M ( B) Based on Stage 1 rule requirements.

( D) Number of systems performing the IDSE from Exhibit H. 4a, Columns E and G. ( E) Number of routine samples per system based on Stage 2B rule requirements ( population based approach for 100% purchasing systems). Number of samples may be less for SW systems serving < 5,000 and GW systems serving < 500 if high TTHM and HAA5 locations are the same. ( F) Estimated percent of systems that will have only one sampling site because their high TTHM and HAA5 site occur at the same location based on analysis of Information Collection Rule data from 4 distribution system locations ( See "% same location" sheet in the Stage 2 non treatment cost model. xls). 100,000 499,999 500,000 1,499,999 1.5 M  < 5 M ³ 5   M < 500 500 9,999 100,000 499,999 10,000 99,999 500 4,999 10,000 24,999 25,000 49,999 50,000 99,999 5,000 9,999 ³ 5   M < 500 500 9,999 10,000 99,999 500,000 1,499,999 1.5 M  < 5 M 100,000 499,999 Surface Water and Mixed NTNCWSs 1.5 M  < 5 M ³ 5   M < 500 Disinfecting Ground Water Only CWSs 500,000 1,499,999 < 500 Stage 2B Sampling Stage 1 Sampling 500 4,999 10,000 24,999 Routine Samples per Plant 50,000 99,999 100,000 499,999 25,000 49,999 5,000 9,999 Surface Water and Mixed CWSs Systems Performing the IDSE Total Samples Systems Not Performing IDSE Total Samples Size Category Total Plants for 100% Purchasing Systems Exhibit H. 8a Additional Routine Monitoring Costs for 100 Percent Purchasing Systems Economic Analysis for Stage 2 DBPR Proposal H 24 July 2003 M= L C N O P Q= N*( N* O+ P) R= M* N S= R/ 2080 ( 209) 1 24.96 $ 220 $ ( 51,276) $ ( 209) $ ( 0) $

1,241 1 24.96 $ 220 $ 303,933 $ 1,241 $ 1 $ 608 1 24.96 $ 220 $ 148,936 $ 608 $ 0 $

( 7,680) 1 24.96 $ 220 $ ( 1,881,293) $ ( 7,680) $ ( 4) $

( 2,536) 1 24.96 $ 220 $ ( 621,219) $ ( 2,536) $ ( 1) $

( 2,576) 1 24.96 $ 220 $ ( 631,017) $ ( 2,576) $ ( 1) $

 1 24.96 $ 220 $  $  $  $

( 144) 1 24.96 $ 220 $ ( 35,274) $ ( 144) $ ( 0) $  1 24.96 $ 220 $  $  $  $

 1 24.96 $ 220 $  $  $  $

National Totals ( 11,297) ( 2,767,210) $ ( 11,297) $ ( 5) $

 36 1 24.96 $ 220 $ ( 8,845) $ ( 36) $ ( 0) $

154 1 24.96 $ 220 $ 37,724 $ 154 $ 0 $ 468 1 24.96 $ 220 $ 114,641 $ 468 $ 0 $  64 1 24.96 $ 220 $ ( 15,677) $ ( 64) $ ( 0) $

0 1 24.96 $ 220 $  $  $  $ 0 1 24.96 $ 220 $  $  $  $ 0 1 24.96 $ 220 $  $  $  $

National Totals 522 127,843 522 0.25 0 1 24.96 $ 220 $  $  $  $ 0 1 24.96 $ 220 $  $  $  $

24 1 24.96 $ 220 $ 5,879 $ 24 $ 0 $ 0 1 24.96 $ 220 $  $  $  $ 32 1 24.96 $ 220 $ 7,839 $ 32 $ 0 $

16 1 24.96 $ 220 $ 3,919 $ 16 $ 0 $ 32 1 24.96 $ 220 $ 7,839 $ 32 $ 0 $ 0 1 24.96 $ 200 $  $  $  $

0 1 24.96 $ 200 $  $  $  $ 0 1 24.96 $ 200 $  $  $  $

National Totals 104 25,476 $ 104 0.05 0 1 24.96 $ 220 $  $  $  $

8 1 24.96 $ 220 $ 1,960 $ 8 $ 0 $ 15 1 24.96 $ 220 $ 3,674 $ 15 $ 0 $

0 1 24.96 $ 220 $  $  $  $ 0 1 24.96 $ 220 $  $  $  $ 0 1 24.96 $ 220 $  $  $  $

0 1 24.96 $ 220 $  $  $  $ National Totals 23 5,634 $ 23 0.01 Grand Totals ( 10,648) ( 2,608,257) ( 10,648) ( 5) Detail may not added due to independent rounding. Systems will incur only routine monitoring costs for sites and samples that are required beyond those required under the Stage 1 DBPR ( i. e., systems that, as a result of the IDSE, only move sample sites will incur no additional costs).

1 FTE = 2,080 hours ( 40 hours/ week; 52 weeks/ year). ( N) Labor hours per sample reflects EPA estimate.

( O) Technical labor rates from the Bureau of Labor Statistics ( 2000).

( P) Laboratory cost for TTHM and HAA5 analyses per sample based on costs incurred for the ICR. Surface Water and Mixed CWSs Disinfecting Ground Water Only CWSs Surface Water and Mixed NTNCWSs 1.5 M  < 5 M ³ 5   M < 500 500 4,999 Disinfecting Ground Water Only NTNCWSs 5,000 9,999 < 500 500 9,999 25,000 49,999 50,000 99,999 100,000 499,999 500,000 1,499,999 10,000 24,999 100,000 499,999 500,000 1,499,999 1.5 M  < 5 M ³ 5   M 25,000 49,999 50,000 99,999 100,000 499,999 500,000 1,499,999 500,000 1,499,999 1.5 M  < 5 M ³ 5   M 10,000 99,999 100,000 499,999 500 9,999 10,000 99,999 1.5 M  < 5 M ³ 5   M < 500 Total Burden ( FTEs) Hours per Sample Sampling Cost per Labor Hour Additional Samples Required for Stage 2B Monitoring Size Category < 500 500 4,999 5,000 9,999 10,000 24,999 Cost per Sample Total Cost Total Burden ( Hours) Exhibit H. 8a Additional Routine Monitoring Costs for 100 Percent Purchasing Systems ( Continued) Economic Analysis for Stage 2 DBPR Proposal H 25 July 2003 ICR and NRWA data were evaluated to assess the portion of systems that did not report a detectable disinfectant residual at all sample locations. The data showed that approximately 25 percent of small surface water plants ( based on NRWA data), and 35 percent of large ground water plants ( based on ICR data) reported no or low residual at one or more of their distribution sample sites ( meaning 75 and 65 percent of surface and ground water systems could potentially collect half the number of samples, as shown in column J of Exhibit H. 8a).

For 100 percent purchasing NTNCWSs, high TTHM and HAA5 concentrations are more likely to be at the same location because these systems are typically small and have small distribution systems. Thus, EPA believes that all eligible NTNCWSs ( surface water NTNCWSs serving less than 10,000 people and ground water NTNCWSs serving less than 500 people) will qualify for reduced monitoring site requirements.

Producing Systems The Stage 2B DBPR monitoring requirements for producing systems are based on the same criteria ( source water type, population served, and number of treatment plants) as the Stage 1 DBPR. Most systems will be required to collect the same number of samples as under the Stage 1 DBPR and, thus, will incur no additional costs. The following systems may have to take an additional sample for each sample period if their high TTHM concentrations occur at a different location than their high HAA5 concentrations.

° Surface water CWSs and NTNCWSs serving 500 to 9,999 people ° Disinfecting ground water CWSs and NTNCWSs serving at least 500 people Exhibit H. 8b summarizes the estimated change in the number of samples required and the associated cost. An explanation of this exhibit is provided in the following paragraphs.

Like 100 percent purchasing systems, EPA estimated the percentage of systems that would have to add a site separately for those that perform the IDSE and those that do not ( this is because small systems that conduct the IDSE will have TTHM and HAA5 data, while those that do not conduct the IDSE will not have DBP data and will have to rely on an indicator). The derivation of the percentage of systems with their high TTHM and HAA5 at different locations is the same as for the 100 percent purchasing system analysis, resulting in the following:

° For CWSs conducting the IDSE, 44 percent of surface water and 54 percent of ground water systems will have to add a site because their high TTHM and HAA5 concentrations occur at different locations based on evaluation of ICR data. ( See footnote 7 on page H 22.)

° For CWSs not performing the IDSE, 25 percent of surface water and 35 percent of ground water systems will have to add a site because their high TTHM and HAA5 concentrations occur at different locations based on evaluation of NRWA and ICR disinfectant residual data.

° For NTNCWSs serving less than 10,000 people, all systems are likely to have high TTHM and HAA5 concentrations at the same location because NTNCWSs are typically small and have small distribution systems. Economic Analysis for Stage 2 DBPR Proposal H 26 July 2003 Systems Performing the IDSE Systems Not Performing IDSE Total Systems Performing the IDSE Percentage Requiring Additional Monitoring Systems w/ Additional Monitoring Total Systems Not Performing IDSE Percentage Requiring Additional Monitoring Systems w/ Additional Monitoring A B C = A* B D E F = D* E 288 0% 0 1,052 0% 0 1,817 44% 791 296 25% 74 535 44% 233 87 25% 22 538 0% 0 87 0% 0 323 0% 0 52 0% 0 173 0% 0 28 0% 0 159 0% 0 26 0% 0 27 0% 0 4 0% 0 6 0% 0 1 0% 0 1 0% 0 0 0% 0 National Totals 3,867 1,023 1,633 96 570 0% 0 17,765 0% 0 1,267 54% 679 9,485 35% 3,320 236 54% 126 1,097 35% 384 17 54% 9 35 35% 12  54% 0 5 35% 2 1 54% 1 0 35% 0  54% 0 0 35% 0 National Totals 2,091 815 28,387 3,718  0% 0 423 0% 0  0% 0 162 0% 0  0% 0 5 0% 0 2 0% 0 0 0% 0 1 0% 0 0 0% 0  0% 0 0 0% 0  0% 0 0 0% 0  0% 0 0 0% 0  0% 0 0 0% 0  0% 0 0 0% 0 National Totals 3  590

 0% 0 6,154 0% 0  0% 0 1,109 0% 0 1 0% 0 3 0% 0  0% 0 1 0% 0  0% 0 0 0% 0  0% 0 0 0% 0  0% 0 0 0% 0 National Totals 1  7,267

Grand Totals 5,962 1,838 37,877 3,813 Notes: Detail may not added due to independent rounding.

Sources: 1 FTE = 2,080 hours ( 40 hours/ week; 52 weeks/ year).

( A) Number of systems performing the IDSE from Exhibit H. 4b, columns E and G.

( B) Percentage of plants requiring additional routine monitoring are systems with high TTHM and high HAA5 occuring at same location based on analysis of Information Collection Rule data in the Stage 2 DBPR Occurrence Document ( USEPA 2003l). NTNCWSs are not expected to need additional routine monitoring due to the simplicity of their distribution systems.

( D) Total systems not performing IDSE = total systems from Exhibit H. 2 ( column H) minus the number of systems performing the IDSE ( column A, this sheet). ( E) Percentage of plants requiring additional routine monitoring based on analysis of Information Collection Rule and NRWA data, percent of systems that DO NOT have a detectable residual at all sample locations. Disinfecting Ground Water Only CWSs Surface Water CWSs 500 9,999 100,000 499,999 500,000 1,499,999 1.5 M  < 5 M ³ 5   M 10,000 99,999 500,000 1,499,999 Surface Water NTNCWSs 100,000 499,999 5,000 9,999 10,000 24,999 500 9,999 ³ 5   M 10,000 99,999 < 500 Disinfecting Ground Water Only NTNCWSs 500,000 1,499,999 ³ 5   M 1.5 M  < 5 M Systems will incur only routine monitoring costs for sites and samples that are required beyond those required under the Stage 1 DBPR ( i. e., systems that, as a result of the IDSE, just move sample sites will incur no additional costs). 100,000 499,999 < 500 500 4,999 ³ 5   M 5,000 9,999 10,000 24,999 25,000 49,999 < 500 < 500 500 4,999 1.5 M  < 5 M 50,000 99,999 100,000 499,999 500,000 1,499,999 1.5 M  < 5 M 25,000 49,999 50,000 99,999 Size Category Exhibit H. 8b Additional Routine Monitoring Costs for Producing Systems Economic Analysis for Stage 2 DBPR Proposal H 27 July 2003 G = C+ F H I = G* H J K L M N= I* J* ( K* L+ M) O= I* J* K P= O/ 2,080 0 1.4   1 24.96 $ 220 $  $   865 1.3 1,124 4 1 24.96 $ 220 $ 1,101,340 $ 4,496 2.16 255 1.7 433 4 1 24.96 $ 220 $ 424,271 $ 1,732 0.83 0 2.0   1 24.96 $ 220 $  $   0 2.2   1 24.96 $ 220 $  $

0 3.4   1 24.96 $ 220 $  $   0 3.0   1 24.96 $ 220 $  $

0 5.8   1 24.96 $ 220 $  $   0 5.8   1 24.96 $ 220 $  $   0 5.8   1 24.96 $ 220 $  $   National Totals 1,119 1,557 1,525,611 $ 6,228 2.99 0 1.4   1 24.96 $ 220 $  $   3,999 1.8 7,197 1 1 24.96 $ 220 $ 1,762,977 $ 7,197 3.46 510 4.3 2,195 4 1 24.96 $ 220 $ 2,150,749 $ 8,780 4.22 21 9.9 211 4 1 24.96 $ 220 $ 206,746 $ 844 0.41 2 9.9 17 4 1 24.96 $ 220 $ 16,657 $ 68 0.03 1 9.9 5 4 1 24.96 $ 220 $ 4,899 $ 20 0.01 0 9.9  4 1 24.96 $ 220 $  $   National Totals 4,533 9,625 4,142,029 $ 16,909 8.13 0 1.0   1 24.96 $ 220 $  $   0 1.0   1 24.96 $ 220 $  $   0 1.0   1 24.96 $ 220 $  $   0 1.0   1 24.96 $ 220 $  $

0 1.0   1 24.96 $ 220 $  $

0 1.0   1 24.96 $ 220 $  $   0 1.0   1 24.96 $ 220 $  $   0 1.0   1 24.96 $ 220 $  $   0 1.0   1 24.96 $ 220 $  $   0 1.0   1 24.96 $ 220 $  $   National Totals    $

0 1.0   1 24.96 $ 220 $  $   0 1.0   1 24.96 $ 220 $  $   0 1.0  4 1 24.96 $ 220 $  $   0 1.0  4 1 24.96 $ 220 $  $   0 1.0   1 24.96 $ 220 $  $   0 1.0   1 24.96 $ 220 $  $   0 1.0   1 24.96 $ 220 $  $   National Totals    $

Grand Totals 5,652 11,182 5,667,640 $ 23,137 11.12 Notes: Detail may not added due to independent rounding.

Sources: ( H) Number of plants per system from Exhibit H. 2, ( column E). ( J) Number of additional routine samples per plant based on rule requirements. ( K) Labor hours per sample reflects EPA estimate. ( L) Technical labor rates from the Bureau of Labor Statisitics ( 2000). ( M) Laboratory cost for TTHM and HAA5 analyses per sample based on costs incurred for the ICR. Surface Water CWSs Disinfecting Ground Water Only CWSs 500,000 1,499,999 1.5 M  < 5 M ³ 5   M 500 9,999 10,000 99,999 100,000 499,999 500,000 1,499,999 500,000 1,499,999 1.5 M  < 5 M ³ 5   M < 500 Disinfecting Ground Water Only NTNCWSs 10,000 24,999 25,000 49,999 50,000 99,999 100,000 499,999 < 500 500 4,999 5,000 9,999 10,000 99,999 100,000 499,999 500,000 1,499,999 1.5 M  < 5 M Surface Water NTNCWSs ³ 5   M 500 9,999 Size Category < 500 500 4,999 5,000 9,999 < 500 10,000 24,999 25,000 49,999 50,000 99,999 100,000 499,999 ³ 5   M Systems will incur only routine monitoring costs for sites and samples that are required beyond those required under the Stage 1 DBPR ( i. e., systems that, as a result of the IDSE, just move sample sites will incur no additional costs). 1.5 M  < 5 M 1 FTE = 2,080 hours ( 40 hours/ week; 52 weeks/ year). Additional Routine Samples Total Burden ( Hours) Total Burden ( FTEs) Hours per Sample Sampling Cost per Labor Hour Cost per Sample Total Cost Total Systems w/ Additional Monitoring Plants per System Plants w/ Additional Monitoring Exhibit H. 8b Additional Routine Monitoring Costs for Producing Systems ( continued) Economic Analysis for Stage 2 DBPR Proposal H 28 July 2003 Effects of Reduced Monitoring Both the Stage 1 and Stage 2 DBPRs have a provision for reduced monitoring if compliance monitoring results are below 40 µ g/ L for TTHM and 30 µ g/ L for HAA5. EPA believes most systems currently on a reduced monitoring schedule will be able to meet the criteria for reduced monitoring under the Stage 2 DBPR. Monitoring costs incurred for the reduced monitoring systems from Stage 1 to Stage 2B are expected to change minimally. This EA does not calculate costs associated with changes in reduced monitoring status.

H. 5 National Costs for Significant Excursion Evaluations This section discusses the national costs and benefits of significant excursions that may occur after implementing the Stage 2 DBPR.

° Section H. 5.1 defines a significant excursion.

° Section H. 5.2 describes the evaluation procedure for systems that experience significant excursions.

° Section H. 5.3 presents the costs associated with significant excursion evaluations and the estimated number of systems affected.

° Section H. 5.4 explains the benefits of significant excursion evaluation requirements.

H. 5.1 Definition of " Significant Excursion"

Although the number and level of peak DBP events is expected to be reduced by the Stage 2 DBPR ( see Chapter 5, section 5.4.1), EPA recognizes that excursions above 80 : g/ L for TTHM and 60 : g/ L for HAA5 may still occur, even when systems are in full compliance with MCLs. In the rule, EPA has not included specific criteria that systems must use for initiating a significant excursion evaluation. However, the draft guidance includes a number of options that States/ Primacy Agencies may use to determine that a significant excursion has occurred. If a significant excursion occurs, the system is required to conduct a significant excursion evaluation. For purposes of costing in the primary cost analysis, EPA has used one of the options to develop compliance costs and burdens. The option selected for the primary cost analysis assumes that systems will conduct a significant excursion evaluation if a Stage 2B compliance sample exceeds either a TTHM concentration of 100 : g/ L or an HAA5 concentration of 75 : g/ L.

H. 5.2 System Requirements for Significant Excursions If a significant excursion occurs, systems must conduct a significant excursion evaluation and discuss the evaluation with the State/ Primacy Agency no later than the next sanitary survey. A significant excursion evaluation must include an examination of distribution system operational practices and how these practices may be modified to reduce TTHM and HAA5 levels.

A significant excursion, as defined in section H. 5.1, is not a violation of the Stage 2 DBPR and does not require any public notification or explanation in Consumer Confidence Reports ( CCR). Systems 8At least 3 of 4 quarters must have TTHM and HAA5 data for at least 3 of 4 distribution system locations ( TTHM and HAA5 data do not have to be present at the same location, however) for a plant to be included in this analysis.

9Exhibit H. 9 also shows the results for samples exceeding a TTHM level of 120 : g/ L and/ or HAA5 level of 90 : g/ L ( representing + 50 percent of Stage 2 TTHM and HAA5 MCLs) as a sensitivity analysis.

10For the ICR GW plant analyses, there was one Stage 2 compliant plant that exceeded 75 : g/ L HAA5. However, a review f the data showed that the sample maost likely represented the water quality of the SW plant in that system. This plant was removed from the analysis, resulting in no Stage 2 compliant GW plants with peaks.

Economic Analysis for Stage 2 DBPR Proposal H 29 July 2003 are not required to take any action to reduce DBP concentrations as a result of a significant excursion; however, reducing peaks is a primary objective of the Stage 2 DBPR and is an important goal in providing safe drinking water. EPA is providing guidance to systems on operational alternatives to reduce DBP peaks in the distribution system.

H. 5.3 Cost Implications of Significant Excursions Each significant excursion event is expected to result in some labor costs for systems to evaluate the excursion and document its cause. To determine national costs for significant excursion evaluations, this section presents an estimate of: ( 1) the percent of all Stage 2 DBPR sampling results that are significant excursions ( i. e., samples exceeding 100 µ g/ L for TTHM or 75 µ g/ L for HAA5), and ( 2) the burden for each significant excursion evaluation.

Percent of samples that are peaks and percent of systems experiencing peaks The methodology for predicting the percent of samples exceeding 100 µ g/ L for TTHM or 75 µ g/ L for HAA5 for large systems is similar to the methodology for predicting occurrence of peak DBPs following the Stage 2 DBPR, as described in section 5.4.1. Predicted occurrence of TTHM and HAA5 peaks were based on ICR distribution system sampling results from January 1998 through December 1998. Four distribution system sampling locations were evaluated: DSE, AVG1, AVG2, and DS maximum ( see Chapter 3, section 3.7.1, for a description of these sampling locations). ICR plants were first screened to ensure that they met minimum data criteria, 8 then evaluated for compliance with Stage 2B DBPR MCLs, given a 20 percent safety factor ( 64 and 48 : g/ L for TTHM and HAA5, respectively). A total of 136 surface water plants and 75 ground water plants met the screening criteria and were found to be compliance with the Stage 2B DBPR.

Exhibit H. 9 shows the results of the ICR analysis, which include the total number of samples, plants, and systems evaluated and the percent of each exceeding a TTHM level of 100 : g/ L, an HAA5 level of 75 : g/ L, or both. 910 The results in H. 9 based on ICR data are assumed to adequately represent the percent of samples that are peaks for large CWSs serving 100,000 or more people. For medium CWSs serving 10,000 to 99,999 people, the percent of samples that are peaks is estimated to be the same as that for large systems. This is because medium systems have similar source water quality, disinfectant use, and distribution system TTHM and HAA5 concentrations as large systems ( see Appendix A for comparison of surface water system data). For small surface water and mixed CWSs serving 500 to 9,999 people, the estimated incidence of peaks for large systems ( 0.3% of all samples) is used. The occurrence of peaks in NTNCWSs is assumed to be zero because these systems typically have very small distribution Economic Analysis for Stage 2 DBPR Proposal H 30 July 2003 No. (%) of SAMPLES that are peaks No. (%) of PLANTS that have peaks No. (%) of SYSTEMS that have peaks 1975 136 97 100 m g/ L TTHM 4 ( 0.20%) 3 ( 2,2%) 3 ( 3.1%) 75 m g/ L HAA5 2 ( 0.1%) 2 ( 1.5%) 2 ( 2.1%) 100 or 75 TTHM/ HAA5 6 ( 0.3%) 4 ( 2.9%) 4 ( 4.1%) 120 m g/ L TTHM 0 0 0 90 m g/ L HAA5 0 0 0 120 or 90 TTHM/ HAA5 0 0 0 Notes:

Source Surface Water Systems DBP Peak Level Main Analysis for Costing Sensitivity Analysis Number of samples/ plants/ systems evaluated ( 1) Represents analysis of Stage 2 compliant plants, evaluated considering a 20% safety factor. Results in bold are used in the cost analysis Based on evaluation of last 4 quarters of ICR data, subset of plants with at least 3 quarters of data having 3 locations with TTHM and HAA5 data, subset of plants meeting Stage 2 DBPR MCLs with a 20% safety factor. Mixed, purchased, and blended plants were not included in the analysis. systems and will not have a much variability in TTHM/ HAA5 data. The estimated percent of Stage 2B monitoring samples that are peaks for all system types and sizes are presented in Exhibit H. 10.

Exhibit H. 9 Predicted Occurrence of Significant Excursions in Large Systems To estimate the percent of systems experiencing at least one peak per year, EPA first considered using ICR data from the last column in Exhibit H. 9. However, the data was not applicable to all systems for two reasons. First, the ICR dataset has roughly 20 samples per system on average. Sampling requirements for the Stage 2B DBPR vary from as little as 1 per year to 96 samples per year. Using the ICR data would overestimate the number of systems for systems with fewer than 20 samples per year and underestimate the number of systems with more than 20 samples per year. Second, the usable subset of ICR data only contains 97 surface water systems and 57 ground water systems currently meeting Stage 2 requirements. This is a small sample size from which to extrapolate to all CWSs with varying numbers of sample per year requirements.

To overcome these limitations but still make use of the ICR data to estimate peak occurrences, EPA has assumed that the full data set of 1,975 surface water samples and the 1,087 ground water samples are representative as a whole of probability that any one sample in treated water meeting the Stage 2 requirements will be a peak. Those single sample probabilities are 0.3% ( 6/ 1,975) and 0% ( 0/ 1,087) for surface water and ground water systems, respectively. To calculate the probability of finding a peak in a year given that plants take multiple samples, the following procedure was used. Assuming independence from one sample to the next, one can calculate the probability of at least one peak occurring for N samples from 1( 1 p) N, where p is the probability of observing a peak. In this calculation, ( 1 p) is the probability of not observing a peak in any one sample, and ( 1 p) N is the probability of not observing a peak after N samples. For example, it can be estimated that a surface water plant taking 16 samples has a probability of ( 1 0.003) 16 = 0.9531 of not observing a peak in those 16 samples. Therefore, the probability of observing at least one peak when 16 samples are taken is simply 1 minus that value, or 1  0.9531 = 0.0469 ( 4.69%). This approach was used to estimate the probability of observing a peak in surface and ground water plants and systems ( using plant per system data where appropriate) as displayed in Exhibits H. 10a and H. 10b. Economic Analysis for Stage 2 DBPR Proposal H 31 July 2003 No. of Systems No. Annual Stage 2 Samples/ System Percent of Samples that are Peaks Estimated Number of Samples/ yr that are Peaks Percent of Systems Without Peaks Percent of Systems with at Least One Peak / yr Predicted # of Systems with at Least One Peak / yr A B C D = Round [ A* B* C] E = ( 1 C) B F = 1 E G = Round [ A* F]

1,961 2 0.0%  100.00% 0.0% 0 2,542 8 0.3% 61 97.63% 2.4% 60 508 8 0.3% 12 97.63% 2.4% 12 480 16 0.3% 23 95.31% 4.7% 23 227 24 0.3% 16 93.04% 7.0% 16 115 32 0.3% 11 90.83% 9.2% 11 65 48 0.3% 9 86.57% 13.4% 9 5 64 0.3% 1 82.51% 17.5% 1  80 0.3%  78.63% 21.4% 0  96 0.3%  74.94% 25.1% 0 5,903 133 132 815 2 0.0%  100.00% 0.0% 0 768 2 0.0%  100.00% 0.0% 0 40 8 0.0%  100.00% 0.0% 0 4 16 0.0%  100.00% 0.0% 0  32 0.0%  100.00% 0.0% 0  32 0.0%  100.00% 0.0% 0  32 0.0%  100.00% 0.0% 0 1,627 0.00 0 158 2 0.0%  100.00% 0.0% 0 56 8 0.0%  100.00% 0.0% 0 6 8 0.0%  100.00% 0.0% 0 2 16 0.0%  100.00% 0.0% 0 4 24 0.0%  100.00% 0.0% 0 1 32 0.0%  100.00% 0.0% 0 1 48 0.0%  100.00% 0.0% 0  64 0.0%  100.00% 0.0% 0  80 0.0%  100.00% 0.0% 0  96 0.0%  100.00% 0.0% 0 228  0 26 2 0.0%  100.00% 0.0% 0 8 2 0.0%  100.00% 0.0% 0 1 8 0.0%  100.00% 0.0% 0  24 0.0%  100.00% 0.0% 0  32 0.0%  100.00% 0.0% 0  32 0.0%  100.00% 0.0% 0  32 0.0%  100.00% 0.0% 0 35  0 7,793 133 132 Notes:

Sources: ( A) Exhibit H. 2, column F. 500 9,999 100,000 499,999 < 500 ³ 5   M Detail may not add to totals due to independent rounding. 500,000 1,499,999 ³ 5   M < 500 National Totals 10,000 99,999 50,000 99,999 ³ 5   M National Totals 500 9,999 < 500 < 500 500 4,999 10,000 24,999 25,000 49,999 5,000 9,999 For the purposes of deterimining the frequency of occurrence of significant excursions, EPA used the assumptions discussed in section H. 5.1 ( i. e., systems will conduct a significant excursion if a Stage 2B compliance sample exceeds either a TTHM concentration of 100 ug/ L or an HAA5 concentration of 75 ug/ L). This is only one of several options  if a different option were selected, the number of systems with significant excursions would vary. 10,000 24,999 500,000 1,499,999 5,000 9,999 ³ 5   M 500 4,999 Grand Totals National Totals 50,000 99,999 100,000 499,999 100,000 499,999 1.5 M  < 5 M 10,000 99,999 25,000 49,999 National Totals 1.5 M  < 5 M ( B) Stage 2B sample requirements presented in Chapter 1. Data shown are the total number of samples required per year. 1.5 M  < 5 M Disinfecting Ground Water Only NTNCWSs 500,000 1,499,999 ( C) Percentage of samples experiencing peaks greater than 100 ug/ L for TTHM or 75 ug/ L for HAA5 from Exhibit H. 9 for large CWSs. See section H. 5.2 for derivation of percent of samples with peaks for medium and small CWSSs and NTNCWSs. Size Category 1.5 M  < 5 M 500,000 1,499,999 Surface Water and Mixed CWSs Disinfecting Ground Water Only CWSs Surface Water and Mixed NTNCWSs 100,000 499,999 Exhibit H. 10a 100 Percent Purchasing Systems Having at Least One Significant Excursion per Year Economic Analysis for Stage 2 DBPR Proposal H 32 July 2003 No. of Systems Plants / System No. Annual Stage 2B Samples/ Plant Percent of Samples that are Peaks Estimated Number of Samples/ yr that are Peaks Percent of Plants Without Peaks Percent of Plants with at Least One Peak / yr Predicted # of Systems with at Least One Peak / yr A B C D E = Round [ A* B* C* D] F = ( 1 D) C G = 1 F H = Round [( 1( 1 G) B)* A]

1,340 1.4 1 0.0%  100.00% 0.00% 0 2,113 1.3 4 0.3% 33 98.81% 1.19% 33 622 1.7 4 0.3% 13 98.81% 1.19% 13 625 2.0 16 0.3% 60 95.31% 4.69% 57 375 2.2 16 0.3% 40 95.31% 4.69% 38 201 3.4 16 0.3% 33 95.31% 4.69% 30 185 3.0 16 0.3% 27 95.31% 4.69% 25 31 5.8 16 0.3% 9 95.31% 4.69% 8 7 5.8 16 0.3% 2 95.31% 4.69% 2 1 5.8 16 0.3%  95.31% 4.69% 0 5,500 32 217 206 18,335 1.4 1 0.0%  100.00% 0.00% 0 10,752 1.8 4 0.0%  100.00% 0.00% 0 1,333 4.3 16 0.0%  100.00% 0.00% 0 52 9.9 16 0.0%  100.00% 0.00% 0 5 9.9 16 0.0%  100.00% 0.00% 0 1 9.9 16 0.0%  100.00% 0.00% 0  9.9 16 0.0%  100.00% 0.00% 0 30,478  0 423 1.0 1 0.0%  100.00% 0.00% 0 162 1.0 4 0.0%  100.00% 0.00% 0 5 1.0 4 0.0%  100.00% 0.00% 0 2 1.0 16 0.0%  100.00% 0.00% 0 1 1.0 16 0.0%  100.00% 0.00% 0  1.0 16 0.0%  100.00% 0.00% 0  1.0 16 0.0%  100.00% 0.00% 0  1.0 16 0.0%  100.00% 0.00% 0  1.0 16 0.0%  100.00% 0.00% 0  1.0 16 0.0%  100.00% 0.00% 0 593  0 6,154 1.0 1 0.0%  100.00% 0.00% 0 1,109 1.0 4 0.0%  100.00% 0.00% 0 4 1.0 16 0.0%  100.00% 0.00% 0 1 1.0 16 0.0%  100.00% 0.00% 0  1.0 16 0.0%  100.00% 0.00% 0  1.0 16 0.0%  100.00% 0.00% 0  1.0 16 0.0%  100.00% 0.00% 0 7,268  0 43,839 217 206 Notes:

Sources: Size Category 500,000 1,499,999 ³ 5   M 1.5 M  < 5 M ³ 5   M 500 4,999 10,000 24,999 25,000 49,999 50,000 99,999 5,000 9,999 25,000 49,999 < 500 National Totals < 500 1.5 M  < 5 M ³ 5   M National Totals 500 9,999 < 500 100,000 499,999 Disinfecting Ground Water Only NTNCWSs 5,000 9,999 Surface Water and Mixed CWSs Disinfecting Ground Water Only CWSs Surface Water and Mixed NTNCWSs 50,000 99,999 100,000 499,999 500,000 1,499,999 10,000 99,999 10,000 24,999 500,000 1,499,999 For the purposes of deterimining the frequency of occurrence of significant excursions, EPA used the assumptions discussed in section H. 5.1 ( i. e., systems will conduct a significant excursion if a Stage 2B compliance sample exceeds either a TTHM concentration of 100 ug/ L or an HAA5 concentration of 75 ug/ L). This is only one of several options  if a different option were selected, the number of systems with significant excursions would vary. 500 4,999 500 9,999 10,000 99,999 National Totals < 500 100,000 499,999 500,000 1,499,999 1.5 M  < 5 M ( D) Percentage of samples experiencing peaks greater than 100 ug/ L for TTHM or 75 ug/ L for HAA5 from Exhibit H. 9 for large CWSs. See section H. 5.2 for derivation of percent of samples with peaks for medium and small CWSSs and NTNCWSs. Grand Totals 100,000 499,999 Detail may not add to totals due to independent rounding.

( A and B) Exhibit H. 2, columns H and E.

( C) Stage 2B sample requirements presented in Chapter 1. Data shown are the total number of samples required per year. 1.5 M  < 5 M ³ 5   M National Totals Exhibit H. 10b Producing Systems Having at Least One Significant Excursion per Year Economic Analysis for Stage 2 DBPR Proposal H 33 July 2003 Level of Effort Required for Significant Excursion Evaluations EPA estimates that systems will spend 1 to 2 hours to perform a significant excursion evaluation, depending on system size ( large systems with more complex distribution systems are expected to spend 2 hours per excursion, while small systems with simpler distribution systems are expected to spend 1 hour per excursion). There may be reduced effort for systems that experience more than one significant excursion yearly; however, this effect could not be quantified. EPA also expects the rate of excursions to decrease over time as systems begin identifying the cause and working with their States/ Primacy Agencies to reduce future excursions.

Cost Summary The total costs for significant excursion evaluations are summarized in Exhibits H. 11a and H. 11b for 100 percent purchasing and producing systems, respectively. Note that the burden to systems is very small ($ 16,820). EPA assumes that review of significant DBP excursion evaluations will occur as part of the normal review process during the sanitary survey and allocates no additional cost to systems or States/ Primacy Agencies for this activity.

Other Cost Implications Although systems are not required to make changes as a result of significant DBP excursions, they may still decide to change their operations to reduce the likelihood of future significant excursions and potential MCL violations. These changes can range from minimal to significant depending on the nature of the solution and size of the system. Because changes are not required by EPA, the costs for responding to significant excursions are not included as part of the national costs of the Stage 2 DBPR; however, examples of typical system level costs are provided below to show potential implications.

Systems have a number of operational and distribution system modification options available to reduce DBP concentrations and eliminate significant excursions. These include low cost options, such as longer or more frequent drain/ fill cycles to improve storage tank turnover and mixing, as well as more expensive options involving distribution system looping and inlet/ outlet piping modifications to storage tanks. Where possible, it is expected that systems would first choose a low cost option to reduce peak DBP concentrations.

If a system determines that a storage tank is the cause of an excursion, it may be possible to implement operational changes, such as lengthening drain/ fill cycles or increasing the frequency of drain/ fill cycles, to improve tank mixing. A system may also consider decommissioning excess storage, or maintaining excess storage for emergency use only. Generally, these options will require minimal additional expenditures by the system; however, in some cases their feasibility may depend on system pressure requirements. When excess storage is to be maintained for emergency use only, it is still important to maintain water quality in the storage tank. This may require periodic manual disinfection ( i. e., addition of calcium hypochlorite tablets) to prevent significant microbiological activity in the storage tank. This can involve some chemical cost ( chlorination tablets are available for about $ 65 per 25 pounds), as well as additional labor cost ( e. g., a few hours for a two person crew). When excess storage is to be maintained for emergency use only, it is important to adequately flush the system after the tank has been used. Economic Analysis for Stage 2 DBPR Proposal H 34 July 2003 Estimated No. of Samples / yr that are Peaks Hours per Sample for Excursion Evaluation Cost per Labor Hour Total Cost Total Burden ( Hours) Total Burden ( FTEs) A B C D = A* B* C E = A* B F= E/ 2,080  1 24.96 $  $   61 1 28.95 $ 1,766 $ 61 0.0 12 1 28.95 $ 347 $ 12 0.0 23 2 28.95 $ 1,332 $ 46 0.0 16 2 28.95 $ 926 $ 32 0.0 11 2 28.95 $ 637 $ 22 0.0 9 2 28.95 $ 521 $ 18 0.0 1 2 28.95 $ 58 $ 2 0.0  2 28.95 $  $    2 28.95 $  $   133 5,587 $ 193 0.1  1 24.96 $  $    1 28.95 $  $    2 28.95 $  $    2 28.95 $  $    2 28.95 $  $    2 28.95 $  $    2 28.95 $  $   0.00  $ 0 0.0  1 24.96 $  $

 1 28.95 $  $    1 28.95 $  $    2 28.95 $  $    2 28.95 $  $    2 28.95 $  $    2 28.95 $  $    2 28.95 $  $    2 28.95 $  $    2 28.95 $  $     $ 0 0.0  1 24.96 $  $    1 28.95 $  $    2 28.95 $  $    2 28.95 $  $    2 28.95 $  $    2 28.95 $  $    2 28.95 $  $     $ 0 0.0 133 5,587 $ 193 0.1 Notes:

Sources: Size Category 1.5 M  < 5 M 500,000 1,499,999 ( C) Labor rates from the Bureau of Labor Statistics ( 2000). An 80: 20 split between technical and managerial labor rates was assumed, except for systems serving 500 or fewer people, for which only a technical rate was applied. ( B) Hours estimated by EPA to complete the significant excursion report. EPA expects it to take less time for small systems given they have simpler distribution systems. 10,000 99,999 25,000 49,999 National Totals 1.5 M  < 5 M 1 FTE = 2,080 hours ( 40 hours/ week; 52 weeks/ year). 1.5 M  < 5 M Surface Water and Mixed CWSs Disinfecting Ground Water Only CWSs Disinfecting Ground Water Only NTNCWSs Surface Water and Mixed NTNCWSs 100,000 499,999 500,000 1,499,999 ³ 5   M 5,000 9,999 National Totals 10,000 99,999 < 500 < 500 500 4,999 10,000 24,999 25,000 49,999 5,000 9,999 100,000 499,999 500,000 1,499,999 50,000 99,999 Grand Totals Detail may not add to totals due to independent rounding. 10,000 24,999 1.5 M  < 5 M ³ 5   M National Totals 500 9,999 < 500 ³ 5   M 500 4,999 For the purposes of deterimining the frequency of occurrence of significant excursions and associated cost and burden, EPA used the assumptions discussed in section H. 5.1 ( i. e., systems will conduct a significant excursion if a Stage 2B compliance sample exceeds either a TTHM concentration of 100 ug/ L or an HAA5 concentration of 75 ug/ L). This is only one of several options  if a different option were selected, the number of systems with significant excursions would vary. 50,000 99,999 ( A) Exhibit H. 10a, column D. 500 9,999 100,000 499,999 < 500 100,000 499,999 500,000 1,499,999 ³ 5   M National Totals Exhibit H. 11a Significant Excursion Costs for 100 Percent Purchasing Systems Economic Analysis for Stage 2 DBPR Proposal H 35 July 2003 Estimated No. of Samples / yr that are Peaks Hours per Sample for Excursion Evaluation Cost per Labor Hour Total Cost Total Burden ( Hours) Total Burden ( FTEs)

A B C D = A* B* C E = A* B F= E/ 2,080  1 24.96 $  $   33 1 28.95 $ 955 $ 33 0.0 13 1 28.95 $ 376 $ 13 0.0 60 2 28.95 $ 3,474 $ 120 0.1 40 2 28.95 $ 2,316 $ 80 0.0 33 2 28.95 $ 1,911 $ 66 0.0 27 2 28.95 $ 1,563 $ 54 0.0 9 2 28.95 $ 521 $ 18 0.0 2 2 28.95 $ 116 $ 4 0.0  2 28.95 $  $   217 11,233 $ 388 0.2  1 24.96 $  $    1 28.95 $  $

 2 28.95 $  $    2 28.95 $  $

 2 28.95 $  $    2 28.95 $  $    2 28.95 $  $     $ 0 0.0  1 24.96 $  $    1 28.95 $  $    1 28.95 $  $    2 28.95 $  $    2 28.95 $  $    2 28.95 $  $    2 28.95 $  $    2 28.95 $  $    2 28.95 $  $

 2 28.95 $  $     $ 0 0.0  1 24.96 $  $    1 28.95 $  $    2 28.95 $  $    2 28.95 $  $    2 28.95 $  $    2 28.95 $  $    2 28.95 $  $     $ 0 0.0 217 11,233 $ 388 0.2 Notes:

Sources: Grand Totals ( B) Hours estimated by EPA to complete the significant excursion report. EPA expects it to take less time for small systems given they have simpler distribution systems.

( C) Labor rates from the Bureau of Labor Statistics ( 2000). An 80: 20 split between technical and managerial labor rates was assumed, except for systems serving 500 or fewer people, for which only a technical rate was applied. 100,000 499,999 Detail may not add to totals due to independent rounding.

( A) Exhibit H. 10b, column E. 1.5 M  < 5 M ³ 5   M National Totals 500,000 1,499,999 < 500 500 4,999 500 9,999 10,000 99,999 National Totals < 500 100,000 499,999 500,000 1,499,999 1.5 M  < 5 M Disinfecting Ground Water Only NTNCWSs Size Category Surface Water and Mixed CWSs Disinfecting Ground Water Only CWSs Surface Water and Mixed NTNCWSs 50,000 99,999 100,000 499,999 500,000 1,499,999 10,000 99,999 10,000 24,999 25,000 49,999 50,000 99,999 5,000 9,999 5,000 9,999 National Totals < 500 1.5 M  < 5 M ³ 5   M National Totals 500 9,999 < 500 For the purposes of deterimining the frequency of occurrence of significant excursions and associated cost and burden, EPA used the assumptions discussed in section H. 5.1 ( i. e., systems will conduct a significant excursion if a Stage 2B compliance sample exceeds either a TTHM concentration of 100 ug/ L or an HAA5 concentration of 75 ug/ L). This is only one of several options  if a different option were selected, the number of systems with significant excursions would vary. 1 FTE = 2,080 hours ( 40 hours/ week; 52 weeks/ year). 100,000 499,999 500,000 1,499,999 ³ 5   M 1.5 M  < 5 M ³ 5   M 500 4,999 10,000 24,999 25,000 49,999 Exhibit H. 11b Significant Excursion Costs for Producing Systems Economic Analysis for Stage 2 DBPR Proposal H 36 July 2003 If a system determines that the source of a significant DBP excursion is a storage tank and is unable to improve tank water quality using operational modifications ( i. e., changes in drain/ fill patterns), then it may be necessary to make inlet/ outlet piping modifications, install baffles, or add a recirculation system to improve tank mixing. The costs for these types of improvements are widely variable and depend on the size and configuration of the existing tank. For example, capital costs for modifications to inlet/ outlet piping in six standpipes ( 2 million gallon ( MG) to 4 MG capacity) may range from $ 78,000 to $ 94,000 for one system. Costs for modifications to elevated tanks ( all 1 MG capacity) may range from $ 19,000 to $ 90,000 for the same system. These costs do not include the installation of sample probes and temperature sensors ( estimated at $ 34,000 per tank including tie in to an existing Supervisory Control and Data Acquisition ( SCADA) system) used to verify proper tank mixing.

Another operational option available to systems is the use of flushing and blow offs in highresidence time areas. Costs for these options can vary significantly from system to system depending on size, amount of labor involved, and if system modifications are required. Some large systems employ one or more flushing crews, whose sole responsibility is to flush system dead ends. For a two person crew at a labor rate of $ 25 per hour ( including fringe benefits), a system would incur a cost of over $ 100,000 per year. Assuming installation of a fire hydrant as a conservative estimate, the cost to add a dead end blowoff or flushing station could be $ 8,000 or more ( RS Means 1999). Where runoff from blow offs or flushing locations contains chloramines and may enter open waterways, neutralization of chloraminated discharges will be necessary. This can be done by laying burlap sacks filled with ammonium sulfate or sodium sulfite in the path of the runoff. Ammonium sulfate is available for about $ 0.35 per pound and sodium sulfite can be purchased for about $ 0.50 per pound. Water losses may also be a concern in water scarce regions. The costs associated with water losses are system specific and no attempt has been made to quantify these costs here.

If long residence times in distribution system dead ends are the source of a significant excursion, then systems may be able to improve flow in dead end areas and reduce water residence time by " looping" dead ends together. For looping to be effective, it is critical that sufficient demand exists in the looped area to create a flow pattern that eliminates the dead end, rather than creating a larger one. The costs associated with looping will vary from system to system, depending on the size and length of pipe involved. Based on cost data presented in RS Means ( 1999), the cost for looping may range from $ 3,500 per 100 feet for a 6 inch line to $ 20,000 per 100 feet for a 24 inch line.

Variability from system to system makes it difficult to quantify the possible costs associated with significant excursion remedies. The most effective option will vary from system to system, as will the costs for similar types of improvements.

H. 5.4 Benefits Implications of the Significant Excursion Requirements As discussed in detail in Chapter 5 of this EA, a primary objective of the Stage 2 DBPR is to reduce peak DBP occurrence, thereby reducing potential adverse developmental and reproductive health effects and cancers associated with DBPs. Although systems are not required to make changes in response to significant DBP excursions, EPA believes that the requirement to perform a significant excursion evaluation and review it with the State/ Primacy Agency will encourage attention to peak events and foster better understanding of peak TTHM and HAA5 occurrence in the distribution system. Economic Analysis for Stage 2 DBPR Proposal H 37 July 2003 H. 6 Summary of Systems Costs for Non Treatment Related Rule Activities This section summarizes the estimated number of systems performing various rule activities and their associated costs, derived previously in sections H. 2 through H. 5. Exhibit H. 12a shows the number of systems performing each rule activity, and Exhibit H. 12b shows their associated costs. The estimates in Exhibits H. 12a and b are broken out by the Stage 2 DBPR monitoring size categories. To combine system and cost breakouts comparable with treatment costs ( derived in Chapter 6), results in H. 12a and b need to be transformed into EPA's standard nine system size categories. Exhibit H. 13 ( the baseline adjustment matrix) shows the percentage of systems from each of the Stage 2 DBPR monitoring size categories that is in each of EPA's nine standard size categories ( see section H. 1 for an additional description of this calculation). Data in this exhibit are derived from SDWIS 4th Quarter Freeze data ( USEPA 2000d) Results from Exhibits H. 12a and b are multiplied by the baseline adjustment matrix in Exhibit H. 13 to produce system and cost results in EPA's nine standard size categories ( Exhibits H. 14a and b). Economic Analysis for Stage 2 DBPR Proposal H 38 July 2003 Baseline No. of Systems Implementation IDSE SMP Additional Routine Monitoring Significant Excursion Evaluations A B = A C D E < 500 3,301 3,301 744 0 0 500 4,999 4,655 4,655 4,181 1,938 93 5,000 9,999 1,130 1,130 1,007 763 25 10,000 24,999 1,105 1,105 951 0 80 25,000 49,999 602 602 518 0 54 50,000 99,999 316 316 258 0 41 100,000 499,999 250 250 193 0 34 500,000 1,499,999 36 36 28 0 9 1.5 M  < 5 M 7 7 5 0 2 ³ 5   M 1 1 1 0 0 National Totals 11,403 11,403 7,886 2,700 338 < 500 19,150 19,150 595 0 0 500 9,999 11,520 11,520 1,358 4,767 0 10,000 99,999 1,373 1,373 243 550 0 100,000 499,999 56 56 16 21 0 500,000 1,499,999 5 5 0 2 0 1.5 M  < 5 M 1 1 1 1 0 ³ 5   M 0 0 0 0 0 National Totals 32,105 32,105 2,213 5,341 0 < 500 581 581  0 0 500 4,999 218 218  0 0 5,000 9,999 11 11  6 0 10,000 24,999 4 4 4 0 0 25,000 49,999 5 5 4 4 0 50,000 99,999 1 1 1 1 0 100,000 499,999 1 1 1 1 0 500,000 1,499,999 0 0 0 0 0 1.5 M  < 5 M 0 0 0 0 0 ³ 5   M 0 0 0 0 0 National Totals 821 821 10 12 0 < 500 6,180 6,180  0 0 500 9,999 1,117 1,117  8 0 10,000 99,999 5 5 1 1 0 100,000 499,999 1 1 0 0 0 500,000 1,499,999 0 0 0 0 0 1.5 M  < 5 M 0 0 0 0 0 ³ 5   M 0 0 0 0 0 National Totals 7,303 7,303 1 9 0 Grand Total All Systems 51,632 51,632 10,110 8,062 338 Note: Detail may not add due to independent rounding. Sources: ( A) and ( B) Exhibit H. 3 ( column A). ( C) Sum of Exhibits H. 4a and H. 4b ( column E).

( E) Sum of Exhibits H. 10a ( column G) and H. 10b ( column H). ( D) Sum of Exhibits H. 8a ( column D*( 1 column F) + column H*( 1 column J)) and H. 8b ( column G). The number of systems is NOT reduced to account for those sytems that have reduced monitoring requirements from Stage 1 to Stage 2 ( only those systems that have to add a site are listed). System Size ( Population Served)

Disinfecting Ground Water Only NTNCWSs Surface Water and Mixed CWSs Disinfecting Ground Water Only CWSs Surface Water and Mixed NTNCWSs Exhibit H. 12a Systems Performing Various Rule Activities, Stage 2 Monitoring Size Categories Economic Analysis for Stage 2 DBPR Proposal H 39 July 2003 Implementation IDSE Additional Routine Monitoring Significant Excursion Evaluations A B C D < 500 $ 494,358 $ 955,645 ($ 51,276) $ 0 500 4,999 $ 808,574 $ 10,017,065 $ 1,405,273 $ 2,721 5,000 9,999 $ 196,281 $ 3,813,870 $ 573,206 $ 724 10,000 24,999 $ 191,939 $ 17,732,520 ($ 1,881,293) $ 4,806 25,000 49,999 $ 104,567 $ 11,976,944 ($ 621,219) $ 3,242 50,000 99,999 $ 73,186 $ 8,894,668 ($ 631,017) $ 2,548 100,000 499,999 $ 57,900 $ 6,970,540 $ 0 $ 2,084 500,000 1,499,999 $ 8,338 $ 1,861,621 ($ 35,274) $ 579 1.5 M  < 5 M $ 1,621 $ 320,845 $ 0 $ 116 ³ 5   M $ 232 $ 64,018 $ 0 $ 0 National Totals $ 1,936,994 $ 62,607,736 ($ 1,241,599) $ 16,820 < 500 $ 2,389,920 $ 1,016,874 ($ 8,845) $ 0 500 9,999 $ 1,667,520 $ 3,001,826 $ 1,800,701 $ 0 10,000 99,999 $ 198,742 $ 2,215,464 $ 2,265,390 $ 0 100,000 499,999 $ 8,106 $ 315,584 $ 191,069 $ 0 500,000 1,499,999 $ 724 $ 869 $ 16,657 $ 0 1.5 M  < 5 M $ 174 $ 20,675 $ 4,899 $ 0 ³ 5   M $ 0 $ 0 $ 0 $ 0 National Totals $ 4,265,185 $ 6,571,291 $ 4,269,872 $ 0 < 500 $ 72,509 $ 0 $ 0 $ 0 500 4,999 $ 31,556 $ 0 $ 0 $ 0 5,000 9,999 $ 1,592 $ 0 $ 5,879 $ 0 10,000 24,999 $ 579 $ 47,959 $ 0 $ 0 25,000 49,999 $ 724 $ 66,320 $ 7,839 $ 0 50,000 99,999 $ 174 $ 23,979 $ 3,919 $ 0 100,000 499,999 $ 174 $ 35,969 $ 7,839 $ 0 500,000 1,499,999 $ 0 $ 0 $ 0 $ 0 1.5 M  < 5 M $ 0 $ 0 $ 0 $ 0 ³ 5   M $ 0 $ 0 $ 0 $ 0 National Totals $ 107,307 $ 174,227 $ 25,476 $ 0 < 500 $ 771,264 $ 0 $ 0 $ 0 500 9,999 $ 161,686 $ 0 $ 1,960 $ 0 10,000 99,999 $ 724 $ 2,886 $ 3,674 $ 0 100,000 499,999 $ 145 $ 87 $ 0 $ 0 500,000 1,499,999 $ 0 $ 0 $ 0 $ 0 1.5 M  < 5 M $ 0 $ 0 $ 0 $ 0 ³ 5   M $ 0 $ 0 $ 0 $ 0 National Totals $ 933,818 $ 2,973 $ 5,634 $ 0 Grand Total $ 7,243,304 $ 69,356,227 $ 3,059,382 $ 16,820 Notes: Detail may not add to totals due to independent rounding.

Sources: ( A) Exhibit H. 3 ( column E).

( C) Sum of Exhibit H. 8 a ( column Q) and b ( column N). ( D) Sum of Exhibit H. 11a and b ( column D). ( B) Sum of Exhibit H. 5a ( column I) and b ( column J), Exhibit H. 6 a and b ( column D), and H. 7a ( column F) and b ( column D). Surface Water and Mixed NTNCWSs Disinfecting Ground Water Only NTNCWSs System Size ( Population Served) Surface Water and Mixed CWSs Disinfecting Ground Water Only CWSs Exhibit H. 12b Non Treatment Cost Summary, Stage 2 Monitoring Size Categories Economic Analysis for Stage 2 DBPR Proposal H 40 July 2003 < 100 101 500 501 1,000 1,001 3,300 3,301 10,000 10,001 50,000 50,001 100,000 100,001 1,000,000 > 1,000,000 < 500 38.9% 61.1% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 500 4,999 0.0% 2.2% 28.2% 53.0% 16.6% 0.0% 0.0% 0.0% 0.0%

5,000 9,999 0.0% 0.0% 0.0% 0.0% 100.0% 0.0% 0.0% 0.0% 0.0%

10,000 24,999 0.0% 0.0% 0.0% 0.0% 2.3% 97.7% 0.0% 0.0% 0.0%

25,000 49,999 0.0% 0.0% 0.0% 0.0% 0.0% 100.0% 0.0% 0.0% 0.0% 50,000 99,999 0.0% 0.0% 0.0% 0.0% 0.0% 2.5% 97.5% 0.0% 0.0%

100,000 499,999 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 2.0% 98.0% 0.0%

500,000 1,499,999 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 86.1% 13.9%

1.5 M  < 5 M 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 100.0% ³ 5   M 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 100.0%

< 500 39.7% 60.3% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 500 9,999 0.0% 2.5% 35.5% 42.3% 19.8% 0.0% 0.0% 0.0% 0.0%

10,000 99,999 0.0% 0.0% 0.0% 0.0% 0.9% 89.7% 9.4% 0.0% 0.0%

100,000 499,999 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 100.0% 0.0%

500,000 1,499,999 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 79.8% 20.2%

1.5 M  < 5 M 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 100.0% ³ 5   M 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

< 500 52.2% 47.8% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

500 4,999 0.0% 11.0% 50.0% 33.9% 5.0% 0.0% 0.0% 0.0% 0.0%

5,000 9,999 0.0% 0.0% 0.0% 0.0% 100.0% 0.0% 0.0% 0.0% 0.0%

10,000 24,999 0.0% 0.0% 0.0% 0.0% 0.0% 100.0% 0.0% 0.0% 0.0% 25,000 49,999 0.0% 0.0% 0.0% 0.0% 0.0% 100.0% 0.0% 0.0% 0.0%

50,000 99,999 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 100.0% 0.0% 0.0%

100,000 499,999 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 100.0% 0.0%

500,000 1,499,999 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 1.5 M  < 5 M 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% ³ 5   M 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

< 500 59.3% 40.7% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

500 9,999 0.0% 9.5% 64.2% 23.9% 2.4% 0.0% 0.0% 0.0% 0.0%

10,000 99,999 0.0% 0.0% 0.0% 0.0% 7.1% 85.7% 7.1% 0.0% 0.0%

100,000 499,999 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 100.0% 0.0% 500,000 1,499,999 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

1.5 M  < 5 M 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% ³ 5   M 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% Source: SDWIS 4th Quarter Year 2000 Freeze data, adjusted for reporting errors in Montana and Massachusetts ( USEPA, 2000d). SW NTNCWS GW NTNCWS Standard Size Categories ( Population Served) Stage 2 Monitoring Size Categories ( Population Served)

SW CWS GW CWS Exhibit H. 13 Baseline Adjustment Matrix from Stage 2 Monitoring Categories to Standard Nine Categories Economic Analysis for Stage 2 DBPR Proposal H 41 July 2003 Baseline No. of Systems Implementation IDSE SMP Additional Routine Monitoring Significant Excursion Evaluations A B= A C D E < 100 1,283 1,283 289 0 0 101 500 2,120 2,120 546 42 2 501 1,000 1,313 1,313 1,179 547 26 1,001 3,300 2,467 2,467 2,216 1,027 49 3,301 10K 1,928 1,928 1,723 1,084 42 10,001 50K 1,690 1,690 1,454 0 133 50,001 100K 313 313 255 0 41 100,001 1M 276 276 213 0 41 > 1 Million 13 13 10 0 3 National Totals 11,403 11,403 7,886 2,700 338 < 100 7,601 7,601 236 0 0 101 500 11,836 11,836 393 119 0 501 1,000 4,089 4,089 482 1,692 0 1,001 3,300 4,869 4,869 574 2,015 0 3,301 10K 2,288 2,288 270 947 0 10,001 50K 1,232 1,232 218 494 0 50,001 100K 129 129 23 52 0 100,001 1M 60 60 16 23 0 > 1 Million 2 2 1 1 0 National Totals 32,105 32,105 2,213 5,341 0 < 100 303 303 0 0 0 101 500 302 302 0 0 0 501 1,000 109 109 0 0 0 1,001 3,300 74 74 0 0 0 3,301 10K 22 22 0 6 0 10,001 50K 9 9 8 4 0 50,001 100K 1 1 1 1 0 100,001 1M 1 1 1 1 0 > 1 Million 0 0 0 0 0 National Totals 821 821 10 12 0 < 100 3,662 3,662

101 500 2,624 2,624  1

501 1,000 717 717  5

1,001 3,300 267 267  2

3,301 10K 27 27 0 0

10,001 50K 4 4 1 1

50,001 100K 0 0 0 0

100,001 1M 1 1

> 1 Million

National Totals 7,303 7,303 1 9

Grand Total All Systems 51,632 51,632 10,110 8,062 338 Notes: Detail may not add to totals due to independent rounding.

Source: Derived by multiplying results in H. 12a by the baseline adjustment matrix in H. 13. Surface Water and Mixed CWSs System Size ( Population Served)

Disinfecting Ground Water Only CWSs Surface Water and Mixed NTNCWSs Disinfecting Ground Water Only NTNCWSs Exhibit H. 14a Systems Performing Various Rule Activities, Standard Nine Size Categories Economic Analysis for Stage 2 DBPR Proposal H 42 July 2003 Implementation IDSE Additional Routine Monitoring Significant Excursion Evaluations A B C D < 100 192,142.08 $ 371,430.61 $ ( 19,929.38) $  $

101 500 319,933.08 $ 803,707.46 $ ( 554.21) $ 59.63 $

501 1,000 228,068.10 $ 2,825,436.36 $ 396,374.53 $ 767.58 $

1,001 3,300 428,517.90 $ 5,308,721.64 $ 744,749.41 $ 1,442.20 $

3,301 10K 334,893.60 $ 5,878,472.26 $ 764,000.04 $ 1,284.37 $

10,001 50K 294,016.20 $ 29,533,457.19 $ ( 2,475,923.29) $ 8,003.87 $

50,001 100K 72,490.80 $ 8,808,897.00 $ ( 615,041.85) $ 2,524.79 $

100,001 1M 63,921.60 $ 8,434,191.77 $ ( 30,375.04) $ 2,541.30 $

> 1 Million 3,010.80 $ 643,421.89 $ ( 4,899.20) $ 196.22 $

National Totals 1,936,994.16 $ 62,607,736.18 $ ( 1,241,598.98) $ 16,819.95 $

Disinfecting Ground Water Only CWSs < 100 948,626.86 $ 403,626.03 $ ( 3,510.75) $  $

101 500 1,482,800.06 $ 687,967.57 $ 39,487.93 $  $

501 1,000 591,883.31 $ 1,065,492.86 $ 639,155.66 $  $

1,001 3,300 704,759.87 $ 1,268,690.31 $ 761,047.41 $  $

3,301 10K 331,201.57 $ 613,341.57 $ 376,554.53 $  $

10,001 50K 178,272.05 $ 1,987,278.96 $ 2,032,062.88 $  $

50,001 100K 18,638.03 $ 207,766.50 $ 212,448.58 $  $

100,001 1M 8,683.71 $ 316,277.56 $ 204,365.05 $  $

> 1 Million 319.74 $ 20,849.87 $ 8,260.23 $  $

National Totals 4,265,185.20 $ 6,571,291.23 $ 4,269,871.51 $  $

< 100 37,814.40 $  $  $  $

101 500 38,168.40 $  $  $  $

501 1,000 15,777.75 $  $  $  $

1,001 3,300 10,711.50 $  $  $  $

3,301 10K 3,184.50 $  $ 5,879.04 $  $

10,001 50K 1,302.75 $ 114,278.31 $ 7,838.72 $  $

50,001 100K 173.70 $ 23,979.36 $ 3,919.36 $  $

100,001 1M 173.70 $ 35,969.04 $ 7,838.72 $  $

> 1 Million  $  $  $  $

National Totals 107,306.70 $ 174,226.71 $ 25,475.84 $  $

< 100 457,014.55 $  $  $  $

101 500 329,625.13 $  $ 186.36 $  $

501 1,000 103,772.46 $  $ 1,257.75 $  $

1,001 3,300 38,626.71 $  $ 468.17 $  $

3,301 10K 3,962.58 $ 206.15 $ 309.86 $  $

10,001 50K 620.36 $ 2,473.78 $ 3,149.49 $  $

50,001 100K 51.70 $ 206.15 $ 262.46 $  $

100,001 1M 144.75 $ 86.85 $  $  $

> 1 Million  $  $  $  $

National Totals 933,818.25 $ 2,972.93 $ 5,634.08 $  $

Grand Total All Systems 7,243,304.31 $ 69,356,227.05 $ 3,059,382.46 $ 16,819.95 $

Notes: Detail may not add to totals due to independent rounding.

Source: Derived by multiplying results in H. 12b by the baseline adjustment matrix in H. 13. Surface Water and Mixed CWSs System Size ( Population Served)